• EPA New England1 s "Source-Specific VOC RACT Checklist:," 11/94
Z. APPLICABILITY
A) Does State non-CTG RACT
rule contain presumptive norms
for RACT?
B) Does submittal meet the
presumptive norms?
C) Does the submittal include
all VOC emitting processes at
the facility?
D) Are the facility's
potential emissions included?
The following States have non-
CTG RACT rules with
presumptive norms:
Connecticut, New Hampshire,
Rhode Island, Vermont, and
Maine presumptive norms: 85%
reduction with add on controls
or 80% reduction with
reformulation. If submittal
is from one of these states,
continue on to B)
Massachusetts rule does not
contain presumptive norms. If
submittal is from this state,
continue on to C)
If the presumptive norms are
met, the source does not
require a source-specific SIP
revision. If not, a SIP
revision is required and this
checklist should be continued.
The submittal should include a
description of the facility
and VOC emitting processes,
SIC codes, etc.
Potential emissions should be
given for each unit or
process.
* Calculation of potential
emissions should be based on
maximum production capacity
unless federally enforceable
restrictions exist which limit
production.
* Fugitive emissions should be
included in the calculation of
potential emissions.
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* Typically, 1990 is used as
the baseline, however, another
representative year, or years,
may be used in some cases.
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E) Have any of the processes
been exempted?
II. RACT DETERMINATION
A) Does the submittal include
a description of each process
subject to RACT?
B) Does the submittal include
actual daily and annual
emissions for each process,
for 1990 or other
representative year(s)?
C) Has the "RACT" emission
reduction strategy been
identified for each subject
process?
Identify exemptions and the
reasons for these exemptions.
(e.g., process is covered by a
NESHAP, LAER, or a CTG, etc.)
See list of exemptions in
state rule.
The submittal should include a
detailed description of all
processes including type of
process/equipment, maximum
capacity, source of emissions
(e.g., stack, oven, fugitive)
and type solvent(s) or fuel(s)
used, etc.
Actual emissions should be
calculated using material
balance where possible. If
material balance calculations
are not appropriate, then
emissions should be calculated
using an emission factor and
actual throughput for 1990 or
the representative year.
Emission factors may be from
stack testing, AP-42, or other
sources. If an emission
factor is used, the factor
should be evaluated to
determine whether the factor
is appropriate to estimate
emissions during average
operating conditions at the
subject facility. The State
should list references for
emission factors.
In the RACT plan, the facility
should identify which of the
control options evaluated is
their chosen RACT strategy.
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For each subject process or unit, answer the applicable questions
(D) through (J):
D) Does the RACT emission
reduction strategy meet the
more stringent of EPA or State
presumptive norms for RACT?
Are averaging times and units
of compliance enforceable and
consistent with the ambient
standard? If so, continue to
section III, Test Methods.
If not, are all applicable
emission reduction strategies
for each process identified?
£) Has the averaging time and
units of compliance been
included for each applicable
emission reduction strategy?
EPA presumptive norm for VOC:
81% overall control with add-
on control equipment, or 3.5
Ib VOC/galIon coating for
surface coating sources.
State norms for VOC:
Connecticut. New Hampshire,
Rhode Islana, Vermont, and
Maine presumptive norms: 85%
reduction with add-on controls
or 80% reduction with
reformulation.
List of all possible pollution
prevention/control techniques
for each process:
Reformulation
Source Reduction
Innovative Technology
Add-On Controls
Resources for pollution
prevention/control techniques
include EPA's Control
Techniques Guidelines,
Alternative Control Techniques
Guidelines, the RACT/BACT/LAER
Clearinghouse, Control
Technology Center, OAQPS
Technology Transfer Network,
STAPPA/ALAPCO, Air and Waste
Management Association, State
environmental agencies, etc.
The averaging time in
plan/order must be consistent
with protecting ambient
standard in question.
Averaging time must in no case
be greater than 24 hours for
VOC unless submitted under
December 4, 1986 Emission
Trading Policy Statement (51
FR 43814), or under April 7,
1994 Economic Incentive
Program rules (59 FR 16690).
Units of compliance must be
enforceable.
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F) Has -the technological
feasibility of each applicable
strategy been evaluated?The
technological infeasibility of
all potential emission
reduction strategies not
further considered must be
documented.
G) Does the submittal include
the total- cost, total
reductions, and cost/ton for
each technically feasible
control?
H) Has a ranking of emission
reduction strategies been
included?
The economic feasibility of
all technologically feasible'
emission reduction strategies,
including those not imposed,
must be documented.
The following resources
provide guidance on economic
matters:
* OAQPS Control Cost Manual,
fourth edition (EPA 450/3-90-
006, January 1990) Most
recent supplement is Chapter
10, "Hoods, Ductwork, and
Stacks."
* The Clean Air Act Section
183(d) Guidance on Cost-
Effectiveness (EPA-450/2-91-
008, November, 1991)
* "Determining Reasonably
Available Control Technology
for an Individual Facility
Emitting Volatile Organic
Compounds" (By David Conroy,
EPA Region I, November 2,
1988.)
The emission reduction
strategies should be ranked by
total reductions and cost
effectiveness.
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I) Is the selected RACT
strategy the strategy that
achieves the most reductions
that are technologically and
economically feasible? If so,
continue to section III, Test
Methods.
If not, has the source
provided financial
documentation showing they
cannot reasonably afford to
implement the strategies
ranked higher in emission
reductions than the strategy
they have chosen?
If the source cannot
reasonably afford to implement
the strategies ranked higher
in emission*-reductions then
the state should submit to EPA
three to five consecutive
years of tax returns from the
source. These returns must be
signed and attested to its
accuracy. Financial
statements may also be
submitted, but not as a
replacement for the tax
returns. The facility should
also submit a copy of the
company's audited financial
statements for a minimum of
three years. In addition, the
facility should submit
documentation of any material
which supports its claim that
they may not be able to obtain
financing.
J) If the source's RACT
strategy, selected on an
economic basis, does not
achieve the same reductions as
RACT selected for an average
facility, has the source
included a schedule to achieve
additional reductions in the
future?
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III. TEST METHODS AND MONITORING
A) Which -test: methods are
required for initial
compliance?
1) emission limit
2) required parameter limits
Test methods to be used to
determine initial and ongoing
compliance must be explicitly
stated. Initial compliance
testing should be consistent
with appropriate EPA approved
test methods. The following
test methods should be
considered:
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* Method 18 of 40 CFR Part 60,
Appendix A for certain VOC
streams, as applicable;
* Method 21 of 40 CFR Part 60,
Appendix A for leak detection
and repair from process
equipment (e.g., valves,
pumps, flanges, compressors,
etc.) "in VOC service;11
* Method 24 of 40 CFR Part 60,
Appendix A for VOC quantity of
compliant surface coatings;
* Method 24A of 40 CFR Part
60, Appendix A for solvent-
borne inks or related
coatings;
* Method 25, 25A, or 25B of 40
CFR Part 60, Appendix A for
VOC streams as applicable;
* 40 CFR Part 52.741, Appendix
B ("the Chicago FIP") .for
capture efficiency, etc.
* Alternative test methods may
be allowed where approved by
the State and EPA.
Some operations may require
more than one test to be run
for same requirement, such as
tests for capture efficiency
and control device efficiency
to test for an overall control
efficiency.
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B) Is transfer efficiency (TE)
considered?
C) When must: test methods be
performed?
D) What is the averaging time
in the compliance test method?
E) Does submittal include
requirements for assessing
ongoing compliance?
Consideration for transfer
efficiency is given only if
the baseline TE and the TE
test methods are contained in
the RACT permit.
Timing of initial emission
testing should be specified.
Conditions for additional
periodic testing may also be
specified, where state
requires.
Averaging time and application
of limit must be explicit.
Averaging time must not be
greater than 24 hours, unless
specifically approved by the
State and EPA.
Monitoring of ongoing
compliance may include the use
of periodic testing,
continuous emission monitoring
systems (CEMS), parameter
monitoring, recordkeeping,
etc., with the frequency of
data collection consistent
with the averaging period of
the standard or State rule.
Parameters used to monitor
compliance should be
correlated to the emissions
limit during initial stack
testing, unless established
relationships are approved
(e.g., based on engineering
analysis and manufacturer's
recommendations). Monitored
parameters should at a minimum
include the following:
* With carbon adsorbers,
carbon bed temperature and
regeneration stream flow, &
exit organic compound
concentration should be
monitored continuously.
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* With surface condensers<
exit gas temperature should be .
monitored continuously.
* With thermal incinerators,
firebox temperature should be
monitored continuously.
* With catalytic incinerators,
temperature immediately before
and after the catalyst should
be monitored continuously.
* With thermal destruction in
boilers or process heaters,
firebox temperature should be
monitored continuously.
* With flares, pilot light
should be monitored
continuously with a heat
sensing device.
* With steam stripper, steam
flow rate, wastewater feed
mass flow rate, and wastewater
feed temperatures should be
monitored continuously.
* With scrubbers, pressure
drop and pH of scrubber liquor
should be monitored
continuously.
* For coating sources with
compliant coatings, records of
daily coating usage may serve
as monitoring method. -
For VOCs, it is often
difficult to utilize GEMS.
However, since continuous VOC
emission monitors continue to
improve, the following
requirements would apply to
sources monitoring VOC
emissions via OEMS:
- Performance specification,
monitor location, calibration
and operating procedures,
quality assurance procedures
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for each monitor and sample
'calculation showing how
'concentrations from OEMs will
be converted into applicable
units and averaging time of
emission limit must be
submitted to State.
- All emission data shall be
continuously monitored and
recorded.
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- Each CEM system shall be
operated at all times except
for periods of CEMs calibra-
tion checks, zero and span
adjustment and preventative
maintenance. Not withstanding
such exceptions, in all cases
valid CEMs data shall be
obtained for at least 75% of
the hours per day, 75% of the
days of the month, and 90% of
the hours per quarter that the
stationary source is
operating.
IV. GENERAL RECORDKEEPING AND REPORTING
A) Does the non-CTG RACT
plan/order affirmatively
require records to be kept?
B) Does the plan/order specify
how long records are to be
kept?
C) Does the plan/order specify
in what form of units (Ib/gal,
gr/dscf, etc.) the records
must be kept?
There must be a clear
separately enforceable
provision that requires
records to be kept.
The owner or operator of the
subject source shall maintain
these records in a readily
accessible location for a
minimum of 5 years.
The units of the records
should be consistent with the
units of compliance including
the applicable time period.
For example, units should be
in: Ibs VOC/gallon of solids
and Ibs of VOC/gallon of
coating (minus water and non-
reactive photochemicals) for
surface coating sources. The
time basis can be instantane-
ously, hourly, or daily.
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D) How frequently are reports
submitted?
E) Is control equipment being
used to meet* RACT?
Sources-subject to.emission.
statements are required-to
submit annually. •If state
desires more frequent
reporting, a provision must be
included in the plan/order.
At a minimum, the following
records should be required:
* The results of all tests and
calculations necessary to
demonstrate that RACT is met.
* A log of operating time.
* A maintenance log for
control device detailing all
routine and nonroutine
maintenance performed
including dates and duration
of any outages.
* Continuous records of all
periods of operation,
including those in which
parameter boundaries
established during most recent
performance test are exceeded,
for example:
- For thermal incinerators,
all 3-hour periods of
operation in which average
combustion temperature was
more than 28°C (50°F) below
the average combustion
temperature during most recent
performance test that demon-
strated that facility was in
compliance.
- For catalytic incinerators,
all 3-hour periods of opera-
tion in which the average
temperature of process vent
stream immediately before
catalyst bed is more than 28°C
(50°F) below average temp-
erature of process vent stream
immediately before catalyst
bed during most recent
performance test that
10 demonstrated that the facility
was in compliance.
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F) Are continuous emission
monitoring (CEM) systems
used?
- For carbon adsorbers, all 3-
hour periods of operation
during which either'the
average VOC concentration or
the reading of organics in the
exhaust gases is more than 20
percent greater than the
average exhaust gas
concentration or reading
measured by the organics
monitoring device during the
most recent determination of
the recovery efficiency of the.
carbon adsorber that
demonstrated that the facility
was in compliance.
- For surface condensers, when
exit gas temperature monitored
outside established range.
- For thermal destruction in
boilers or process heaters,
when firebox temperature
monitored outside established
range.
- For flares, when heat
sensing device shows no pilot
light.
- For steam stripper, when
steam flow rate, wastewater
feed mass flow rate, and
wastewater feed temperatures
monitored outside the
established range.
- For scrubbers, when pressure
drop and pH of scrubber liquor
monitored outside established
range.
- For coating sources with
compliant coatings, when
records show non-compliant
coatings used (e.g., what
quantity, composition,etc?).
If so, records of all
measurements, performance
evaluations, calibration
checks, and maintenance or
adjustments for each monitor
shall be maintained.
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G) Does the submittal include
what: to do if excess emissions
are measured by a CEM?
V. COMPLIANCE SCHEDULE
A) Does submittal include a
compliance date?
B) Does the submittal include
a schedule for periodic
increments of progress?
A written.report of excess
emissions as measured by a
continuous emission monitor
shall be submitted and shall
include the following
information:
* The date and time of
commencement and completion of
each period of-excess
emissions and the magnitude of
the excess emissions.
* Identification of the
suspected reason for the
excess emissions and any
corrective action taken.
* The date and time period any
continuous emission monitor
was inoperative, except for
zero and span checks and the
nature of system repairs and
adjustments.
* The date and time periods of
any missing data or periods
where compliance could not be
determined and the steps taken
to cure the cause of the
missing data.
Final compliance date must not
be later than May 31, 1995.
Sources that become subject to
RACT after the effective date
of the rule must comply with
RACT within the applicable
timeframe specified in the
state rule.
Including but not limited to:
* Results of R&D studies.
* Submittal to the Department
of engineering plans
* Schedule for ordering of
equipment, awarding of
contracts
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* Installation date after:
conf innation. of ~* order. by .
manufacturer
OR
* Date of full conversion; and
* Date RACT will be achieved.
VI. ADMINISTRATIVE MATERIAL NECESSARY FOR EPA PROCESSING
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A) Has a formal letter of
submittal from the Governor or
his/her designee, requesting
EPA approval of the plan, been
submitted to EPA?
B) Does the State have
adequate authority to adopt
and implement the
plan/order(s) which are being
submitted?
C) Is there evidence that the
State is submitting fully
adopted rules to EPA for
formal action? The only
exception is the case where
parallel processing is
requested.
D) Is there evidence that
State followed all procedural
requirements of the State's
laws and constitution in
conduction and completing the
adoption/issuance of the plan?
E) Does the non-CTG RACT
order/plan submitted to EPA
for formal action contain
evidence that 30-day public
notice was held and that
public hearing was either held
or made available. The only
exception for this requirement
is when EPA is requested to
parallel process an action.
(See section (C) above)
The State should explicitly
list the State Code or
authority which allows for
this rulemaking. In some
instances, where new
rulemaking is needed, the
State should submit a copy of
the legislation too.
The State submittal should
have an adopted and effective
date. In some cases these
dates may be the same,
however, the SIP revision
should state this.
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F) Does -the State address all
the public comments received
during the public comment
period and provide a response
thereto. These must be
submitted to EPA.
G) The State should submit
only those parts of the non-
CTG RACT plan/order/consent
agreement that EPA is expected
to take action on. Portions
of the submittal which EPA is
not taking action on should be
crossed out bv the State.
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