United States
Environmental Protection
Agency
Office of Air Quality
P'.inning and Standards
Research Triangle Paik, NC 27711
Guidance for the Control
Of Volatile Organic Compounds
Emitted by Ten Selected
Source Categories
-------
CLEAN AIR ACT
CALLS FOR STATE
POLLUTION CONTROL
PROGRAMS
The 1977 Clean Air Act Amendments require the U.S. Environmental
Protection Agency (EPA) to develop a comprehensive national program
for reducing air pollution and improving air quality. To help
meet this clean air goal, states are required to develop pollution
control programs that will achieve the National Ambient Air Quality
Standards (NAAQS). These programs are referred to as "State
Implementation Plans" (SIPs), and are intended to control emissions
of the major or "criteria" pollutants: carbon monoxide, sulfur
dioxide, particulates, lead, nitrogen oxides, and ozone (which
includes volatile organic compounds, or VOC).
The portion of SIPs directed at VOC emission control must contain
regulations for industrial categories identified as major VOC sources.
Regulations controlling these stationary industrial sources must
reflect the application of reasonably available control technology
(RACT). EPA defines RACT as the lowest emission limitation that
a particular source is capable of meeting by applying control
technology that is reasonably available, considering technological
and economic feasibility.
CTG DOCUMENTS To assist states with the task of defining RACT, EPA has issued
PUBLISHED TO ASSIST control technique guideline (CTG) documents for major VOC sources.
STATES IN VOC
EMISSION CONTROL
The CTG documents 1) recommend control technology, 2) provide
information on the economic and technological feasibility of
available techniques for reducing VOC emissions, and, in some
cases, 3) suggest limits on VOC emissions. Eleven CTG documents
(Group I) covering 15 source categories for VOC were published
prior to January 1978. A guidance document on these categories
was issued to help state and local agencies meet the January 1979
SIP submittal date..*
*The guidance document dealing with the Group I sources is "Regulatory
Guidance for Control of Volatile Organic Compound Emissions from
15 categories of Stationary Sources," (EPA-905/2-78-001).
-------
EPA has published CTG documents (Group II) for an additional 10 VOC
source categories. These categories (and corresponding report numbers)
are: Petroleum Refinery Equipment Leaks (PB 286-158**), Surface
Coating of Miscellaneous Metal Parts and Products (PB 286-157),
Surface Coating of Flat Wood Paneling (PB 286-199), Manufacture of
Synthesized Pharmaceutical Products (PB 290-580), Manufacture of
Pneumatic Rubber Tires (PB 290-557), Graphics Arts-- Rotogravure
and Flexography (PB 292-490), Perchloroethylene Dry Cleaning Systems
(PB 290-613), Leaks from Gasoline Tank Trucks and Vapor Collection
Systems (PB 290-568), Vegetable Oil Manufacture (PB 286-307), and
Petroleum Liquid Storage in External Floating Roof Tanks (PB 290-579).
SIP regulations for these sources must be submitted to EPA by July 1,
1980.
GUIDANCE AVAILABLE To assist state and local agencies in meeting SIP submittal dates,
IN DEVELOPING RACT EPA has published the document "Guidance to State and Local Agencies
REGULATIONS FOR VOC in Preparing Regulations to Control Volatile Organic Compounds from
SOURCE CATEGORIES Ten Stationary Source Categories" (EPA-450/2-79-004). This document
contains sample regulations and discussion sections on the "thought
processes" behind the regulations, and is intended to help state and
local agencies develop industry-specific RACT regulations.
NOTIFICATION TO The purpose of this pamphlet is to inform affected industries that
INDUSTRY OF FUTURE the 10 source categories listed above are subject to future state
STATE REGULATIONS regulation in all ozone nonattainment areas. In addition, this
pamphlet briefly discusses selection and application of RACT for
these categories.
**Publications identified by a "PB" number are available for a nominal
fee from the National Technical Information Service (NTIS), 5285
Port Royal Road, Springfield, VA 22161.
-------
ADDITIONAL
INFORMATION
MAY BE OBTAINED
Industries needing additional information should contact their
respective state/local air pollution control agencies, or
contact the EPA regional offices listed on the inside back
cover of this brochure. During the spring of 1980, many
states will be drafting RACT regulations, holding public
hearings, and adopting regulations for these industries.
PETROLEUM REFINERY
EQUIPMENT LEAKS
Regulations to control VOCs from petroleum refinery equipment
leaks affect all existing petroleum refineries, regardless of
size. Operational and equipment maintenance requirements suggested
for emission control must include a carefully organized testing
and monitoring program to ensure timely dectection and repair
of VOC leaks from seals, valves, flanges, and similar components.
Leaks with a VOC concentration exceeding 10,000 ppm at the source
should be repaired within 15 days. Valves (except pressure
relief valves) located at the end of pipes or lines containing
VOCs must be sealed with a second valve, cap, or plug.
SURFACE COATING
OF MISCELLANEOUS
METAL PARTS
AND PRODUCTS
VOC emission regulations for the surface coating of miscellaneous metal
parts and products apply to all coating operations for decorative
or protective purposes such as prime-coat, top-coat, and single-coat
applications. The emission limits are stated in terms of pounds
of VOC per gallon of coating used, less water. VOC emission
limits suggested by EPA for these operations may be met by
1) conversion to low-solvent coatings; 2) implementing an
incineration system that oxidizes 90.0 percent of nonmethane
VOC to carbon dioxide and water, and is used in conjunction with
a capture system, or 3) using an equivalent means of VOC removal.
SURFACE COATINGS OF VOC emitted during surface coating operations for flatwood
FLATWOOD PANELING
paneling may be reduced through application of those control
technologies recommended for the miscellaneous parts and products
surface coatings category. Regulations for flatwood paneling
coating operations are directed at manufacturers of 1) printed
interior panels mai.de of hardwood plywood and thin (1/4 inch or
-------
less) particle boards, 2) natural finish hardwood plywood panels,
or 3) hardboard paneling with Class II finishes.
The regulations do not apply to the coating of exterior siding,
tile-board, or particleboard used as a furniture component. Emission
limits are stated in terms of pounds of VOC per 1,000 square feet of
coated, finished product.
MANUFACTURE OF
SYNTHESIZED
PHARMACEUTICAL
PRODUCTS
Control options for the manufacture of synthesized pharmaceutical
products address the separate operations involved in this production
process, and include all reactors, distillation units, dryers, VOC
storage and transfer units, extraction equipment, filters,
crystallizers, and centrifuges that have the potential to emit
15 pounds per day or more of VOC. Operators of these manufacturing
plants should maintain good operational and maintenance practices.
Such "good housekeeping" practices might include repairing sources
of VOC leaks, and covering exposed VOC liquid in tanks or other
containers.
In addition, surface condensers (or equivalent controls) may be
used to lower VOC emission levels from reactors, distillation
units, crystallizers, centrifuges, and vacuum dryers. The amount
of VOC emitted during the truck or railcar transfer of liquid
to storage tanks may be controlled by vapor balance systems (or
the equivalent).
PNEUMATIC TIRE
MANUFACTURE
Production operations covered by emission control regulations
for pneumatic tire manufacturing plants include undertread cementing,
tread-end cementing, bead dipping, and green-tire spraying. Possible
control options for these operations are installation and operation
of a capture system capable of achieving maximum reasonable
VOC vapor capture, as well as installation and operation of a
control device such as 1) a carbon adsorption system to remove at
least 95.0 percent of VOC (by weight) ducted to the adsorption device,
2) incineration system to oxidize at least 90.0 percent of all non-
methane VOC (ducted to the device) to carbon dioxide and water,
-------
or 3) an alternative system that has at least a 90-percent reduction
efficiency.
There is an additional option for controlling VOC emissions
from green-tire spraying operations. Water-based sprays may
be substituted for the normal solvent-based compound.
GRAPHIC ARTS
Regulations for the graphic arts industries cover all packaging
rotogravure, publication rotogravure, and flexographic printing
facilities whose potential VOC emissions equal or are greater than
100 tons per year. Graphic art facilities may meet RACT emission
limits by using low-solvent inks, high-solid inks, or add-on
control equipment. Low-solvent inks are identified as inks in
which the volatile fraction contains 25 percent or less (by
volume) organic solvent, and 75 percent or more water. High-
solid inks must contain 60 percent or more (by volume) of non-
volatile material, less water.
Add-on control equipment could include: 1) a carbon adsorption
system that reduces VOC across the control device by 90.0 percent,
2) an incineration system that oxidizes at least 90.0 percent of
the nonmethane VOC to carbon dioxide and water, or 3) any system
demonstrated to reduce VOC emissions by at least 90.0 percent.
Carbon adsorption or incineration systems must be used with a capture
system whose design and operation are consistent with good engineering
practices. These capture systems, in conjunction with the control
devices, must produce an overall VOC emission reduction of at least
75 percent for publication rotogravure facilities, 65 percent for
packaging rotogravure facilities, and 60 percent for flexographic
printing facilities.
PERCHLOROETHYLENE
DRY CLEANERS
VOC emissions from perchloroethylene dry cleaning facilities
can be controlled by 1) venting dryer exhausts through a carbon
adsorption system or equally effective control device; 2) allowing
no more than 100 ppm (by volume) of VOC from each dryer control
-------
device, 3) immediately repairing any machinery from which VOC is
leaking, 4) treating all diatomaceous earth filters so that the
residue contains 25 kg or less of VOC per 100 kg of wet waste
material, 5) draining all filtration cartridges for at least
24 hours before their disposal, 6) reducing VOC from all solvent
stills to 60 kg or less per 100 kg of wet waste material, and
when possible, 7) drying all drained cartridges in a way that
will prevent VOC emissions from escaping into the atmosphere.
GASOLINE TANK VOC emissions from gas tank truck leaks and vapor collection systems
TRUCKS AND VAPOR may be controlled by annually testing gas tank trucks, and by meeting
COLLECTION SYSTEMS performance specifications for all vapor collection and control
systems at bulk plants, bulk terminals, and gasoline dispensing
facilities.
Owners and operators of gasoline tank trucks must ensure that
trucks subject to these air pollution regulations can sustain
a pressure change no greater than 3 inches HO in 5 minutes
when pressurized to a gauge pressure of 18 inches HO, or
evacuated to a gauge pressure of 6 inches HO during the
certification test. Trucks that do not meet specifications must
be repaired and retested within 15 days of initial testing.
Trucks that meet emission criteria must be marked with identifying
stickers.
Owners and operators of vapor collection and control systems are
required to meet specific design and operational requirements as
outlined in the CTG document.
VEGETABLE OIL
MANUFACTURE
States are not required, at this time, to develop regulations for
the vegetable oil manufacturing industry.
PETROLEUM LIQUID VOC emissions from petroleum liquid storage tanks with external
STORAGE IN floating roofs can be controlled by equipping each tank with
EXTERNAL FLOATING a continuous, rim-mounted secondary seal extending from the
ROOF TANKS floating roof to the tank wall, or by equipping tanks with any
other equivalent closure device. This rule would be applicable
-------
to those tanks with a capacity greater than 40,000 gallons.
Recommended exemptions include: 1) tanks used to store waxy,
heavy-pour crude oil, 2) tanks less than 420,000 gallons that
are used for petroleum products storage prior to lease custody
transfer, 3) tanks storing petroleum liquids that have a true
vapor pressure less than 1.5 pounds per square inch absolute
(psia), at storage conditions, 4) tanks storing petroleum liquids
that have a true vapor pressure less than 4.0 psia at storage
conditions (providing they are of welded construction, and are
equipped with a metallic shoe seal or other equivalent closure
device), and 5) tanks of welded construction with a metallic
shoe primary seal, and a shoe-mounted secondary seal.
All secondary seal closure devices must be free of visible tears,
holes, or other similar openings in the seal fabric. Seals must
remain intact, and be placed uniformly around the roof circumference,
between the roof and tank wall. If vapor-mounted primary seals
are used, the accumulated areas of gaps (only those larger than
1/8 inch) between the secondary seal and tank wall must measure
no more than 1.0 square inch per foot of tank diameter. For
example, the sum total of the area of gaps existing between the
seals of a 100-foot diameter storage tank could not exceed 100
square inches.
Tank owners and operators also should comply with specified
operational and inspection procedures to further minimize VOC
emissions. These procedures are outlined in the CTG document.
-------
FOR FURTHER EPA REGION 1 • JFK Federal Building • Boston MA 02203 •
INFORMATION Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island,
Vermont • 617-223-7223
EPA REGION 2 • 26 Federal Plaza • New York NY 10007 • New Jersey,
New York, Puerto Rico, Virgin Islands • 212-264-2515
EPA REGION 3 • 6th and Walnut Streets • Philadelphia PA 19106 •
Deleware, Maryland, Pennsylvania, Virginia, West Virginia, District
of Columbia • 215-597-4081.
EPA REGION 4 • 345 Courtland Street NE • Atlanta GA 30308 o
Alabama, Georgia, Florida, Mississippi, North Carolina, South
Carolina, Kentucky o 404-881-3004.
EPA REGION 5 • 230 S. Dearborn • Chicago IL 60604 • Illinios,
Indiana, Ohio, Michigan, Wisconsin, Minnesota • 312-353-2072
EPA REGION 6 • 1201 Elm Street • Dallas TX 75270 • Arkansas,
Louisiana, Oklahoma, Texas, New Mexico • 214-767-2630
EPA REGION 7 • 324 East llth Street • Kansas City MO 64106 •
Iowa, Kansas, Missouri, Nebraska • 816-374-6201
EPA REGION 8 • 1860 Lincoln Street • Denver CO 80295 • Colorado,
Utah, Wyoming, Montana, North Dakota, South Dakota • 303-837-3878
EPA REGION 9 • 215 Fremont Street • San Francisco CA 94105 •
Arizona, California, Hawaii, Nevada, Pacific Islands • 415-556-1840
EPA REGION 10 • 1200 Sixth Avenue • Seattle WA 98101 • Alaska,
Idaho, Oregon, Washington • 206-442-1203
-------
------- |