FINAL REPORT
FOR
WASHINGTON AND OREGON VOC PROGRAM EVALUATION
ASSIGNMENT NO. 19
TECHNICAL SERVICE AREA
CONTRACT NO. 68-02-4467
SUBMITTED TO
AIR PROGRAMS DEVELOPMENT SECTION
AIR PROGRAMS BRANCH
AIR AND TOXICS DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 10
1200 SIXTH AVENUE
SEATTLE, WA 98101
JULY 1988
PREPARED BY
ENGINEERING-SCIENCE, INC.
75 N. Fair Oaks Avenue
P.O. Box 7107
Pasadena, California 91109
-------
FINAL REPORT
FOR
WASHINGTON AND OREGON VOC PROGRAM EVALUATION
ASSIGNMENT NO. 19
TECHNICAL SERVICE AREA
CONTRACT NO. 68-02-4467
SUBMITTED TO
AIR PROGRAMS DEVELOPMENT SECTION
AIR PROGRAMS BRANCH
AIR AND TOXICS DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 10
1200 SIXTH AVENUE
SEATTLE, WA 98101
JULY 1988
PREPARED BY
ENGINEERING-SCIENCE, INC.
75 N. Fair Oaks Avenue
P.O. Box 7107
Pasadena, California 91109
-------
TABLE OF CONTENTS
INTRODUCTION
METHODOLOGY AND RESULTS
o Washington
o Oregon
SUMMARY AND CONCLUSIONS
o Washington
o Oregon
TABLE 1 GENERAL REQUIREMENTS FOR ALL SOURCES - WASHINGTON
TABLE 2 GENERAL REQUIREMENTS FOR GROUP I CTGs - WASHINGTON
TABLE 3 VOC RULE EVALUATION BY SOURCE CATEGORY - WASHINGTON
Group I CTGs
o Surface Coating
Cans
- Coils
Paper
Fabrics
- Auto/Lt. Duty Trucks
- Metal furniture
Magnetic wire
Large appliances
o Petroleum Storage in Fixed Roof Tanks
o Bulk Terminals
o Bulk Plants
o Solvent Metal Cleaning
o Petroleum Refining Misc.
o Cut Back Asphalt
Group II CTGs
o Petroleum Refining Leaks
o Surface Coating - Miscellaneous Metal Parts and Products
o Surface Coating - Panels
o Graphic Arts
ii
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o Petroleum Storage in Floating Roof Tanks
o Perchloroethylene Dry Cleaning System
o Tank Truck Leaks
TABLE 4 VOC RULE EVALUATION BY SOURCE CATEGORY - OREGON
Group I CTGs
o Surface Coating
Cans
Paper
Fabrics
- Autos/Lt. Duty Trucks
- Metal furniture
Magnetic wire
Large appliances
o Petroleum Storage in Fixed Roof Tanks
o Bulk Terminals
o Bulk Plants
o Solvent Metal Cleaning
o Petroleum Refining Misc.
o Cutback Asphalt
Group II CTGs
o Petroleum Refining Leaks
o Surface Coating - Misc, Metal Parts & Products
o Surface Coating - Panels
o Graphic Arts
o Petroleum Storage in Floating Roof Tanks
o Perc. Dry Cleaning
o Tank Truck Leaks
TABLE 5 SUMMARY OF RULES FOR WHICH SIGNIFICANT COMMENTS WHERE NOTED
IN TABLE 3 OR TABLE 4
iii
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INTRODUCTION
The EPA administrator has adopted a program to ensure that state
and local agencies are implementing the commitments in their approved
State Implementation Plans for carbon monoxide and ozone. The first
part of the program was used to determine if the regulations and
commitments had been adopted. The second part of the evaluation is to
review the adequacy of the adopted measures and regulations. Finally,
an on-going program to determine whether adopted measures are being
effectively implemented will be initiated. This review of the State's
VOC emission control rules, which is the second part of the EPA's
program, characterizes their consistency with federal requirements.
METHODOLOGY AND RESULTS
Washington
The results of the VOC rule evaluation for the State of Washington
are summarized in Tables 1, 2 and 3. Table 1 lists general requirements
for Washington rules applicable to all source categories. Table 2 lists
general requirements for Washington rules applicable to the source
categories listed. These include surface coating operations, petroleum
refineries, petroleum liquid storage tanks, gasoline loading terminals,
bulk gasoline plants, degreasing operations, cold cleaners, and cutback
asphalt paving. Table 3 summarizes the results of the VOC rule
evaluation for each of the industrial source categories for which
Washington has published a rule for VOC emissions control.
The review for Washington rules included a 14 point checklist for
each source category. The items considered in the checklist included
definitions, applicability, compliance schedules, test method
requirements, recordkeeping, calculation methods, transfer efficiency,
capture efficiency, averaging periods used for compliance, exemptions
written into the rule (director discretion, grandfather, specific VOCs,
and key wording), and trading requirements. Each item was considered in
reviewing Washington VOC rules. Deviations from EPA recommendations in
the CTG were identified in Table 3. General requirements in the
Washington State rules were also summarized and included in Table 3 for
completeness.
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It should be noted that not all differences in the State's rules
identified in this evaluation are necessarily inconsistent with EPA
requirements. In some cases the CTG may recommend that economic impacts
be considered when exempting small sources from regulation. If the
State exempted sources of a certain size it would be identified as a
deviation from CTG requirements in Table 3 in this report.
Such an exemption in the State rules would require a case-by-case
evaluation to fully evaluate its merits. Thus, this evaluation is
intended as a screening tool to identify areas which may warrant further
cons ideration.
The rule evaluation for the State of Washington identified at least
four general categories which warrant additional consideration in
improving the State's VOC emissions control program. These include:
° Additional definitions for some VOC rules
0 Identifying additional EPA test procedures to be used for
compliance determinations
° Including averaging times associated with emission limits in
the rules
° Lowering or eliminating size cutoffs in VOC rules.
The definitions used for certain equipment items may exclude some
sources from regulation which contribute significant VOC emissions to
the atmosphere. Additionally, the State's definition of VOCs should be
revised to reflect EPA's current requirements.
The State of Washington has not adopted a test method to determine
the VOC content of coatings. EPA method 24 or equivalent ASTM methods
should be specified by the Department of Ecology for compliance
determinations. Additionally, leak detection monitoring procedures
including equipment items to be used should be identified by the State.
Emission limits should have averaging times identified in the rule.
Long averaging periods in certain cases may reduce the effectiveness of
a VOC rule. Averaging times specified in the rule will also ensure that
the limits are enforceable.
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Some rules allow exemptions for sources of VOC emissions up to 100
tons per year. Depending on the number of these sources, significant
reductions in VOC emissions could be realized by lowering these cutoffs.
Oregon
The results of the VOC rule evaluation for the State of Oregon are
summarized in Table 4. Table 4 summarizes the results of the VOC rule
evaluation for each of the industrial source categories for which Oregon
has published a rule.
The rule evaluation for Oregon identified four general areas which
warrant additional consideration in improving the State's VOC emissions
control program including:
0 Revising or adding definitions
° Identifying additional EPA test procedures
° Identifying averaging times associated with emission limits
° Lowering or eliminating size cutoffs in VOC rules
Table 5 contains a summary of rules for which significant comments
were identified in Table 3 or Table 4. In most cases where a difference
existed, it was assumed that the state rule would be less effective than
the CTG. The magnitude of the difference was not quantified since,
quite often, this would require extensive investigation. These areas
warrant more attention because they may reduce the effectiveness of the
rules.
SUMMARY AND CONCLUSIONS
The results of this evaluation indicated that there are potential
rule changes which would strengthen the State's VOC emission control
program. These changes should be evaluated to determine if they could
be adopted while minimizing economic impacts.
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TABLE 1
GENERAL REQUIREMENTS FOR ALL SOURCES - WASHINGTON
EPA Requirements
VOC Rules -
Washington
Comments
1.0 GENERAL APPLICABILITY
The EPA recommends
that the State adopt
requirements consis-
tent with the Control
Technology Guidelines
(CTG) which recommend
the "presumptive norm"
for Reasonably Avail-
able Control Tech-
nology (RACT). The
CTG recommends RACT to
reduce emissions of
VOCs from specified
sources.
2.0 SCHEDOLE OF CONTROL
DATES
The regulations for the
State of Washington apply
to specified sources of
emissions located or
operating in designated
ozone nonattainment areas
except for the following:
1) Sources of VOCs to be
permanently shutdown by
January 1, 1983.
2) Sources under the
jurisdiction of the
Energy Facility Site
Evaluation Council
(EFSEC).
3) Sources not specific-
ally identified in the
Emission Standards —
VOCs but located on the
same property as other
regulated sources.
4) Development operations
used exclusively for
research, laboratory
analysis, quality
control — if emissions
are less than 660
pounds per month.
The Control Technology
Guidelines do not
provide for the
exemptions listed
herein.
(Please refer to the
specific source category in
question; Table 3 of this
report).
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TABLE 1
GENERAL REQUIREMENTS FOR ALL SOURCES - WASHINGTON
(Continued)
EPA Requirements
VOC Rules -
Washington
Comments
3.0 ALTERNATIVE SCHEDULE
OF CONTROL DATES
4.0 GENERAL EXEMPTIONS
The director may exempt a
source from compliance with
the dates specified in
Section 2.0 above if
1) the delay is justified.
2) an alternative schedule
is submitted with
increments of progress.
3) Final Compliance is
achieved prior to the
photochemical oxidant
attainment date.
Equivalent emission reduc-
tion standards may be used
if the source operator
demonstrates to the depart-
ment that they are as
effective as the required
methods for equipment in
WAG 173-490-040.
N.G, fired incinerators are
required to be operated
only 4 months per year
unless they are required
for other than VOC control.
Alternative control
schedules should be
approved by the EPA.
The methodology for
establishing equiva-
lent control should be
identified to ensure
consistency with EPA
requirements.
This exemption would
not be in accordance
with EPA policy if
violations occur
during the months the
incinerators are shut
down.
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TABLE 1
GENERAL REQUIREMENTS FOR ALL SOURCES - WASHINGTON
(Continued)
EPA Requirements
VOC Rules -
Washington
Comments
5.0 DEFINITION OF VOLATILE
ORGANIC COMPOUNDS
Volatile Orcranic
Compound (VOC) - Any
organic compound which
participates in atmos-
pheric photochemical
reactions; that is,
any organic compound
other than those which
the Administrator
designates as having
negligible photo-
chemical reactivity.
VOC may be measured by
a reference method, an
equivalent method, an
alternative method or
by procedures spec-
ified under 40 CPR
Part 60. A reference
method, an equivalent
method, or an alterna-
tive method, however,
may also measure non-
reactive organic com-
pounds. In such
cases, an owner or
operator may exclude
the nonreactive
organic compounds when
determining compliance
with a standard.
"Volatile organic compound"
means a hydrocarbon or
derivative of hydrocarbon
that has a vapor pressure
greater than 0.1 mm of Hg
(millimeters of mercury) at
a temperature of 20"C.
Excluded compounds are:
methane, ethane, trichloro-
fluoromethane (CFC-11),
dichlorodifluorome thane
(CFC-12), chlorodifluoro-
me thane (CFC-22), tri-
fluorome thane (PC-23), tri-
chlorotrifluoroe thane
(CFC-113), dichlorotetra-
fluoroe thane (CFC-114),
chloropenta fluoroe thane
(CFC-115), methylene
chloride, and 1, 1,
1-trichloroe thane (me thyl
chloroform).
The definition of VOC
should include all
organic compounds
which evaporate and
participate in
atmospheric photo-
chemical reactions.
Thus, a vapor pressure
of o.1 mm Hg should
not be used to define
VOC. The vapor
pressure exclusion
will exclude naphtha
blends and other
compounds which are
photochemically
reactive.
The specific compounds
exempted by the State
in the definition of
VOC are exempted in
accordance with EPA
policy.
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TABLE 2
GENERAL REQUIREMENTS FOR GROUP I CTGs - WASHINGTON
EPA Requirements
VOC Rules -
Washington
Comments
1.0 COMPLIANCE SCHEDULES
The CTGs do not
establish compliance
deadlines but they
should consider
economic impacts in
accordance with EPA
policy.
The following emission
sources are required to
achieve final compliance
with Washington's Rules
within the period of months
listed following approval
of chapter 173-490 WAG by
the EPA.
Petroleum Refineries - 24
MO.
Petroleum Liquid Storage
Tanks - 30 Mo.
Gasoline Loading Terminals
- 12 Mo.
Bulk Gasoline Plants - 18
Mo.
Gasoline Dispensing - 18
Mo.
The latest date for
attainment of the
ozone National Ambient
Air Quality Standard
is December 31, 1987
for the Vancouver Area
and September 30, 1984
for other non-
attainment areas in
Washington.
The Emission Standards
and Controls for
Sources Emitting
Volatile Organic
Compounds were
conditionally approved
as SIP revisions prior
to December 17, 1982
by EPA.
2.0 EXEMPTIONS
a) The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of N.G.
fired afterburners
under certain circum-
stances if provided
for in the SIP.
Surface Coaters - 12 Mo.
Degreasers (All) - 8 Mo.
Cold Cleaners - 8 Mo.
a) The installation and
use of N.G. fired
incinerators and
capture systems for VOC
control is required
only during the months
of June, July, August,
and September.
a) This requirement
may be revised if
attainment of the
ozone standard
cannot be achieved
following a study
of the VOC reduc-
tions controlled
by incinerators in
the non-attainment
area(s).
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TABLE 2
GENERAL REQUIREMENTS FOR GROUP I CTGS
(Continued)
- WASHINGTON
EPA Requirements
VOC Rules -
Washington
Comments
b) Alternative source
control reductions
are specified for
individual source
categories.
b) Alternative emission
reduction methods may
be used if the source
operator demonstrates
that they are at least
as effective as the re-
quired methods.
b) Procedures for
calculating
equivalency are
not specified in
the State rules.
3.0 TEST METHOD
REQUIREMENTS
The VOC content of
coatings shall be
determined by EPA
Reference Method 24
or equivalent ASTM
Methods.
The Department of
Ecology has adopted
only EPA test methods
25 and 25A (19A and 19B
as designated by the
Department) for applicable
VOC emissions.
The State rule should
specify that EPA test
method 24 is the method
that should be used for
sources in the surface
coating category.
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TABLE 3
VOC ROLE EVALUATION BY SOURCE CATEGORY-WASHINGTON
CTG SOURCE CATEGORY: SURFACE COATING OF CANS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS.
(See Automobile and
Lt-Duty Trucks)
2.0 APPLICABILITY.
Applies to two-piece
and three-piece con-
tinuous can manufac-
turing operations
including fabrication,
coating, and drying.
3.0 EMISSION STANDARDS
a) Sheet basecoat and
over varnish two-piece
can exterior 2.8
Ib/gal.
b) Two- and Three-piece
can Interior - 4.2
Ib/gal.
c) Three-piece can side
seam - 5.5 Ib/gal.
d) End Seal - 3.7 Ib/gal.
WAC 173-490-020
(See Automobile and Lt-Duty
Trucks)
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash off areas and dryer
would be greater than 40
pounds in 24 hours.
WAC 173-490-040 (6)
a) 2.8 Ib/gal.
b) 4.2 Ib/gal.
c) 5.5 Ib/gal.
d) 3.7 Ib/gal.
Some key definitions
are not included.
Sources under 40
Ib/day are exempt.
The emission limits
are consistent with
CTG requirements.
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF CANS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Commute nts
4.0 AVERAGING TIME
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTIONS.
Coating lines with
small quantities of
emissions may be
exempt from
regulation.
Averaging times are not
stated in the rule.
Sources with emissions less
than 40 pounds per 24 hour
period are exempt.
The VOC rules should
state explicity the
compliance time frame
associated with emis-
sion limits (e.g. in-
stantaneous or daily).
40 Ib/day exemption.
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OP METAL COILS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS.
(See Definitions for
Automobile and Lt.
Duty Trucks)
2.0 APPLICABILITY.
Applies to equipment
used to coat coils
including the
coater(s), the
oven(s), and the
quench area(s).
3.0 EMISSION STANDARDS.
Prime and topcoat or
single coat operation
2.6 Ib/gal.
4.0 AVERAGING TIME.
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTIONS.
Coating lines with
small quantities of
emissions may be
exempt from
regulation.
WAG 173-490-020
(See Definitions for Lt.
Duty Trucks)
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash off areas, and dryer
would be greater than 40
pounds in 24 hours.
WAC 173-490-040 (6)
2.6 Ib/gal.
Some key definitions
are not included.
Sources under 40 lb/
day are exempt.
Averaging times are not
stated in the rule.
WAC 173-490-040 (6)
Sources with emissions less
than 40 pounds per 24-hour
period may be exempt.
The VOC rules should
state explicitly the
compliance time frame
associated with emis-
sion limits (e.g. in-
stantaneous or daily).
Emission sources of
less than 40 Ib/day
are exempt.
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF PAPER PRODUCTS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS.
(See Definitions for
Autos and Lt. Duty
Trucks)
2.0 APPLICABILITY.
Applies to equipment
coating paper, pres-
sure sensitive tape
(including paper,
fabric, or plastic
film), and web coating
processes on plastic
film such as type-
writer ribbons, photo-
graphic film, and mag-
netic tape.
3.0 EMISSION STANDARDS.
Coating Line - 2.9
Ib/gal.
WAC 173-490-020
_JSee Definitions in
section for Autos and
Lt. Duty Trucks)
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash-off areas, and the
dryer would be greater than
40 pounds in 24 hours.
Some key definitions
have not been
included.
The applicability sec-
tion should be more
explicit.
Sources under 40 lb/
day are exempt.
WAC 173-490-040 (6)
2.9 Ib/gal.
4.0 AVERAGING TIME.
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
Averaging times are not
stated in the rule.
The VOC rules should
state explicitly the
compliance time frame
associated with
emission limits (e.g.
instantaneous or
daily).
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF PAPER PRODUCTS
(Continued)
U.S. EPA Control
Technology Guideline
Requirement State Rule Comments
5-° EXEMPTIONS WAC 173-490-040 (6)
Coating lines with small Sources with emissions less Sources under 40 Ibs./
quantities of emissions than 40 pounds per 24-hour day may be exempted.
may be exempt from period may be exempt.
regulation.
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF FABRICS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
(See Definitions for
Automobiles and Lt.
Duty Trucks)
2.0 APPLICABILITY
Applies to fabric
coating equipment used
to apply all types of
coatings to fabric,
including rubber, rain-
wear , tents, gaskets,
and diaphragms. "Vinyl
Coating " refers to any
printing or decorative
or protective topcoat
applied over vinyl coated
fabric or plastic sheets.
3^-0 EMISSION STANDARDS
a) Fabric Coating Line
2.9 Ib/gal.
b) Vinyl Coating Line 3.8
Ib/gal.
4.0 AVERAGING TIMS
Averaging time is
limited to 24 hours
unless otherwise approved
in the SIP.
WAC 173-490-020
(See Definitions in
section for Autombiles
and Lt. Duty Trucks)
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash-off areas and the
dryer would be greater than
40 pounds in 24 hours.
Some key definitions
have not been included.
Sources under 40 lb/
day are exempt.
WAC 173-490-040 (6)
a) 2.9 Ib/gal.
b)
3.8 Ib/gal.
Averaging times-are not
stated in the rule.
The VOC rules should
state explicitly the
averaging time frame
associated with emission
limits (e.g., instan-
taneous or daily).
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF FABRICS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.0 EXEMPTIONS.
Coating Lines with
small quantities of
emissions may be
exempt from
regulation.
WAC 173-490-040 (6)
Sources with emissions less
than 40 pounds per 24-hour
period may be exempt.
Sources under 40 lb/
day may be exempt.
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TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF AUTOMOBILES AND LIGHT DUTY TRUCKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a)
"Coating Applicator"
means an apparatus
used to apply a
surface coating.
b) "Oven" means a chamber
within which heat is
used to bake, cure,
polymerize, and/or dry
a surface coating.
c)
d)
e)
f)
WAC 173-490-020
a) Not defined
Some definitions not
defined.
b)
Not defined
"Coating Line" means
one or more apparatus
or operations
comprised of a coating
applicator, flash-off
area, and oven wherein
a surface coating is
applied, dried, and/or
cured.
"Owner" or "Operator"
means any person who
owns, leases,
opera tes, controls, or
supervises a surface
coating operation or a
plant of which a
surface coating
operation is a part.
"Standard Conditions"
means a temperature of
20°C (68°F) and
pressure of 760 mm of
Hg (29.92 inches of
Hg).
"Volatile Organic
Compounds'1 - the EPA
definition exists in
Table 1, Section 5 of
this report.
c) Not defined
d)
Not defined
e) Not defined
f)
See Table 1, Section 5
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TABLE 3
CTG SOURCE CATEGORY:
SURFACE COATING OP AUTOMOBILES AND LIGHT DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
g)
h)
i)
"Day" means a 24 hour
period beginning at
midnight.
"Capture System" means
the equipment
(including hoods,
ducts, fans, etc.)
used to contain,
capture, or transport
a pollutant to a
control device.
"Control Device" means
equipment
(incinerator,
adsorber, or the like)
used to destroy or
remove a pollutant
from a discharge gas
stream.
g) Not defined
h)
i)
j)
"Approved" means
approved by the
designated air
pollution control
official.
"Vapor Collection
System" means a closed
system to conduct
vapors displaced from
a tank being filled
into the tank being
emptied, a vapor
holding tank, or a
vapor control system.
"Control System" means
one or more control
devices, including
condensers, that are
designed and operated
to reduce the quantity
of VOC emitted to the
atmosphere.
"Vapor Control System"
means a system
designed and operated
to reduce or limit the
emission of VOC, or to
recover the VOC to
prevent their emission
into the ambient air.
j) Not defined
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TABLE 3
CTG SOURCE CATEGORY:
SURFACE COATING OF AUTOMOBILES AND LIGHT DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.0 APPLICABILITY
Applies to equipment
or processes used to
coat automobiles and
light duty trucks in
assembly plants.
3.0 EMISSION STANDARDS
a) Prime Application
1) Water-borne (elec-
trodeposition)
(1.9 Ib/gal.) 80-
93%
>50% v/v solids
0-65%
2) Incineration 90%
3) Carbon Adsorption
85%
b) Prime cure oven
1) Water-borne (elec-
trode po s i tion)
(1.9 Ib/gal)
80-93%
>50% v/V solids
0-65%
2) Incineration 90%
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash-off areas and dryer
would be greater than 40
pounds in 24 hours.
WAC 173-490-040 (6)
Sources with emissions
less than 40 Ib/day
are exempt from this
rule.
Equivalent emission
reduction performance
criteria are not
specified.
1.9 Ib/gal
(1)
Equivalent emission
reduction performance
criteria are not
specified.
1.9 Ib/gal
(1)
R 226
18
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF AUTOMOBILES AND LIGHT DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
c) Topcoat application
and flashoff area
1) Waterborne topcoat
(2.26 Ib/gal)
40-92%
>50% V/v solids
topcoat 0-86%
2) Incineration 90%
3) Carbon Adsorption
85%
d) Topcoat cure oven
1) Water-borne top-
coat (2.76 Ib/gal)
40-92%
>50% V/V topcoat
0-86%
2) Incineration 90%
4.0 AVERAGING TIME
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
2.8 Ib/gal
(1)
2.8 Ib/gal
(1)
Averaging times are not
stated in the rule.
Equivalent emission
reduction performance
criteria are not
specified.
Equivalent emission
reduction performance
criteria are not
specified.
The VOC rules should
state explicitly the
compliance time frame
associated with
emission limits (e.g.,
instantaneous or
daily).
(1) Ib/gal of coating excluding water
R 226
19
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF AUTOMOBILES AND LIGHT DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.0 EXEMPTIONS
Coating lines with
small quantities of
emissions nay be
exempt from regula-
tion.
WAC 173-490-040 (6)
Sources with emissions
less than 40 Ibs per 24
hour period are exempt.
Sources with emissions
less than 40 Ibs per
24 hour period are
exempt from regula-
tion.
R 226
20
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINTIIONS
"Prime coat" means the
first film of coating
applied in a 2-coat
application.
"Top coat" means the
final film of coating
applied in a 2-coat
operation.
"Single Coat" means
only one film of
coating is applied on
the metal substrate.
"Faraday caging" means
a repelling force
generated during
electrostatic spraying
of powders in corners
and small enclosed
areas of a metal
subtrate.
"Blocking Agent" means
an agent which is
released from the
polymer matrix during
the curing process.
It is normally an
organic radical and
splits from the
monomer or oligmer at
a predetermined
tempera ture, thereby
exposing reactive
sites which then
combine to form the
polymer. Such re-
actions during the
curing process may
release additional
VQCs to the atmos-
phere.
R 226
WAG 173-490-020
(See Autos and Lt. Duty
Trucks).
The definitions in the
CTG are not found in
the State rule.
21
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY:
SURFACE COATING OF METAL FURNITURE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
"Low organic Solvent
Coating" refers to
coatings which contain
less organic solvent
than the conventional
coatings used by
industry. Low organic
solvent coatings
include water-borne,
higher solids,
electrodeposition and
powder coatings.
2.0 APPLICABILITY.
Applies to equipment
used for the surface
coating of metal
furniture which
includes any furniture
made of metal or any
metal part which will
be assembled with
other metal, wood,
fabric, plastic, or
glass.
2.2 TEST METHOD
REQUIREMENTS
The VOC content of
coatings should be
determined by EPA
reference method 24 or
equivalent ASTM
methods.
WAC 173-490-040 (6)
Applies to the operation of
a coater or dryer that may
serve one or more process
lines.
The applicability
section of the State
rule is consistent
with EPA requirements.
WAC 173-490-040 (6)
The State rule requires
test methods to be in
accordance with procedures
on file with the Depart-
ment. The Department has
not adopted a test method
for determining the VOC
content of coatings.
Alternative test
methods may reduce the
effectiveness of the
rule.
R 226
22
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Metal Furniture
Coating - 3.0 Ib/gal.
coating minus water.
b) Add on controls - 80%
reduction overall
a)
WAC 173-490-040 (6)
3.0 Ib/gal. coating
less water
The solvent content
standard is consistent
with EPA requirements.
b) Not specified
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effic-
iencies are calculated
from VOC reductions on
an equivalent solids
basis.
Not Specified
The State rule does
not define equivalent
emission reduction
calculation
procedures.
3.2 CAPTURE EFFICIENCY
Limits are based on
overall efficiencies,
therefore the capture
efficiency is equip-
ment specific.
Not Specified
State rule does not
explicitly comment on
capture efficiency.
4.0 AVERAGING TIME
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTIONS
Not specified
Not Specified
WAC 173-490-020 (6)
Sources with emissions less
than 40 pounds in 24 hours
would be exempt from the
regulations.
The VOC rules should state
explicitly the compliance
time frame associated with
emission limits (e.g.,
instantaneous or daily).
The CTG does not
specify an exemption
for small sources.
R 226
23
6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
5.1 "DIRECTOR DISCRETION"
EXEMPTIONS
None Listed There are no "Director
Discretion" exemptions
listed in WAC 173-490-
040 (6) which are
specific to Metal
Furniture Coating.
No Grandfather exemp-
tions are listed in
WAC 173-490-040 (6).
24
R 226 6/27/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
SURFACE COATING FOR INSULATION OF MAGNETIC WIRES
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None specified in the
CTG.
2.0 APPLICABILITY
Applies to equipment
used to apply varnish
or enamel to electric
wire for insulation.
WAC 173-490-020
None Specified.
WAC 173-490-040 (6)
Applies to the operation of
a coater and dryer that may
serve one or more process
lines if the uncontrolled
emissions from the coater,
flash-off areas and dryer
would be greater than 40
pounds in 24 hours.
Sources emitting < 40
Ibs. per day are
exempt.
2.2 TEST METHOD
REQUIREMENTS
The VOC content of
coatings shall be
determined by EPA
Reference Method 24 or
equivalent ASTM
methods.
2.3 RECORDKEEPING
Recordkeeping require-
ments are not identi-
fied in the CTG.
3.0 EMISSION STANDARDS
a) Wire Coating Oven -
1.7 Ib/gal.
b) Incineration of
solvent emissions.
WAC 173-490-040
Sources shall demonstrate
compliance with the
requirements herein using
sampling procedures on file
with and approved by the
director.
Recordkeeping requirements
for surface coating equip-
ment are not specified.
a)
WAC 173-490-040 (6)
1.7 Ib/gal. excluding
water.
Alternate test methods
may reduce the effec-
tiveness of the rule.
The VOC content limits
for coatings are con-
sistent with EPA
requirements.
R 226
25
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
SURFACE COATING FOR INSULATION OF MAGNETIC WIRES
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effic-
iencies are calculated
from VOC reductions on
an equivalent solids
basis.
Calculation methods are not
defined in the Washington
State rules.
The State rule does
not define equivalent
emission reduction
calculation
procedures.
5.0 EXEMPTIONS
The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas
fired burners under
certain circumstances
if provided for in the
SIP.
The installation of a N.G.
fired incinerator and
capture system shall be
required to operate only
during the months of June,
July, August, and Septem-
ber. Sources < 40 Ibs. per
day are exempt.
The EPA allows the
seasonal use of
incinerators for VOC
control if certain
conditions are met.
Small emission sources
exempt (40 pounds per
day).
R 226
26
6/28/38-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
EXISTING STATIONARY SURFACE COATING OF LARGE APPLIANCES
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Same as those for
Metal Furniture
2.0 APPLICABILITY
Applies to equipment
used for the coating
of large appliances
including doors,
cases, lids, panels,
parts of washers,
dryers, range s,
refrigerators,
freezers, water
heaters, dishwashers,
trash compactors, air
conditioners and other
associated products.
2.2 TEST METHOD
REQUIREMENTS
The VOC content of
coatings shall be
determined by EPA
Reference Method 24.
WAC 173-490-020
Same as those for Autos and
Lt-Duty Trucks
WAC 173-490-040 (6)
Applies to the operation of
a coater or dryer that may
serve one or more process
lines.
CTG definitions not
stated in State rule.
The applicability
section is consistent
with EPA requirements.
WAC 173-490-040
Sources shall demonstrate
compliance with the
requirements herein using
sampling procedures on file
with and approved by the
director.
Alternative test
methods may reduce the
effectiveness of the
rule.
2.3 RECORDKEEPING
Recordkeeping require-
ments are not identi-
fied in the CTG,
Recordkeeping requirements
for surface coating equip-
ment is not specified in
the rule.
R 226
27
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
EXISTING STATIONARY SURFACE COATING OF LARGE APPLIANCES
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
2.8 Ib/gal. coating
excluding water.
WAC 173-490-040 (6)
2.8 Ib/gal. coating
excluding water.
The VOC content limit
for coatings is
consistent with EPA
requirements.
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effic-
iencies are calculated
from VOC reductions on
an equivalent solids
basis.
5.0 EXEMPTIONS.
The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas
fired after burners
under certain circum-
stances if provided
for in the SIP.
WAC 173-490-040 (6)
Calculation methods are not
defined in the Washington
State VOC Rules.
The State rule does
not define equivalent
emission reduction
calculation methods.
The installation of a N.G.
fired incinerator S capture
system shall be required to
operate only during the
months of June, July,
August, and September.
Not Approvable
R 226
28
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Condensate means
hydrocarbon liquid
separated from natural
gas which condenses
due to changes in the
temperature and/or
pressure and remains
liquid at standard
conditions.
b) Crude oil means a
naturally occurring
mixture which consists
of hydrocarbons and/or
sulfur, nitrogen and/
or oxygen derivatives
of hydrocarbons and
which is a liquid at
standard conditions.
c) Custody transfer means
the transfer of pro-
duced crude oil and/or
condensate, after
processing and/or
treating in the
producing operations,
from storage tanks or
automatic transfer
facilities to pipe-
lines or any other
forms of transporta-
tion.
WAC 173-490-020
a) "Condensate" means
hydrocarbon liquid
separated from natural
gas which condenses
due to changes in the
temperature or pres-
sure and remains
liquid at standard
conditions.
b) "Crude oil" means a
naturally occurring
mixture which consists
of hydrocarbons and
sulfur, nitrogen or
oxygen derivatives of
hydrocarbons which is
a liquid at standard
conditions.
c) "Lease custody
transfer" means
the transfer of pro-
duced crude oil ar
condensate, after
processing or treating
in the producing
operations, from
storage tanks or
automatic transfer
facilities to pipe-
lines or any other
forms of transporta-
tion.
The State's definition
of petroleum liquids
excludes fuel oils.
They would probably
not be regulated, how-
ever, due to their low
vapor pressure.
R 226
29
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
d) External floating roof
means a storage vessel
cover in an open top
tank consisting of a
double deck or pontoon
single deck which
rests upon and is
supported by the
petroleum liquid being
contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
d)
"External floating
roof" means a storage
vessel cover in an
open top tank consist-
ing of a double deck
or pontoon single deck
which rests upon and
is supported by the
petroleum liquid being
contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank wall.
e) Internal floating roof
means a cover or roof
in a fixed roof tank
which rests upon or is
floated upon the
petroleum liquid being
contained, and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
f) Petroleum liquids
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery.
f) "Petroleum liquids"
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery,
excluding No. 2
through 6 fuel oils
(ASTM D-396-69), No.
2GT through 4 GT gas
turbine fuel oils
R 226
30
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
g)
Petroleum refinery
means any facility
engaged in producing
gasoline, kerosene,
distillate fuel oils,
residual fuel oils,
lubricants, or other
products through
distillation of crude
oil, or through re-
distillation cracking,
extraction, or reform-
ing of unfinished
petroleum derivatives.
g)
h)
True vapor pressure
means the equilibrium
partial pressure
exerted by a petroleum
liquid as determined
in accordance with
methods described in
American Petroleum
Institute Bulletin
2517, Evaporation Loss
from Floating Roof
Tanks, 1962.
h)
(ASTM D2880-71) or No.
2D and 4D diesel fuel
oils (ASTM D975-68).
"Petroleum refinery"
means a facility
engaged in producing
gasoline, aromatics,
kerosene, distillate
fuel, oils, residual
fuel oils, lubricants,
asphalt, or other
products by distilling
crude oils or re-
distilling , era eking,
extracting or reform-
ing unfinished petro-
leum derivatives. Not
included are facil-
ities re-refining used
motor oils or waste
chemicals, processing
finished petroleum
products, separa ting
blended products, or
air blowing asphalt.
"True vapor pressure"
means the equilibrium
partial pressure of a
petroleum liquid as
determined with
methods described in
American Petroleum
Institute Bulletin
2517, 1980.
R 226
31
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs PROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.0 APPLICABILIY
Applies to storage
vessels with a capac-
ity greater than
150,000 liters
containing petroleum
liquids whose true
vapor pressure is
greater than 10.5 kPa,
(1.5 PSI)
2.2 TEST METHOD
REQUIREMENTS
Fixed-roof tanks with
an internal floating
roof shall be visually
inspected as described
below.
WAC 173-490-040 (2)
Applies to fixed-roof
storage vessels with a
capacity greater than
150,000 liters (40,000
gal.) storing volatile
organic petroleum liquids
with a true vapor pressure,
as stored, greater than
(10.5 kPa) 78 mm Hg, but
less than 570 mm Hg (76.5
kPa) at actual monthly
average storage
tempera turea.
Testing is not required.
This section excludes
from regulation
liquids with a vapor
pressure greater than
570 mm Hg (76.5 kPa).
The State rules make
no requirement for
inspection/testing.
2.3 RECORDKEEPING
Routine inspections
are to be conducted at
6 month, or shorter,
intervals. Evidence
of malfunction is to
be recorded. Addi-
tionally, whenever the
tank is emptied, the
condition of the cover
and seal is to be
recorded. A record of
the average monthly
storage tempera ture
and true vapor
pressure of the stored
liquid.
Recordkeeping requirements
are not described in the
State of Washington regula-
tion for fixed-roof storage
tanks.
The state rule does
not specify record-
keeping requirements.
R 226
32
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EQUIPMENT.STANDARDS
Fixed roof tanks
(>150,000 liters)
shall be retrofitted
as follows:
1)
2)
3)
a) Internal floating
roof
b) Al terna ti ve
equivalent control
No visible defects
All openings should be
covered.
4.0 AVERAGING TIME
The true vapor
pressure of petroleum
liquids shall be based
on an average monthly
stora ge tempera ture.
WAC 173-490-040 (2)
Fixed roof tanks (>150,000
liters) shall satisfy one
of the following:
1) Meet the NSPSs spec-
ified in 40 CFR 60,
subpart K.
2) Be retrofitted with a
floating roof or
internal floating
cover using a metallic
seal or non-metallic
resilient seal which
meets the NSPS
equipment standards.
3) Be retrofitted with a
floating roof or
interval floating
cover meeting the
manufacturer's
specifications.
WAC 173-490-040 (2)
The liquid storage tank
regulation specifies an
average monthly storage
temperature be used to
determine the true vapor
pressure.
The equipment
standards are
consistent with EPA
requiremen ts.
Averaging times are
consistent with EPA
requirements.
R 226
33
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
5.0 EXEMPTIONS WAC 173-490-040 (2)
Fixed roof tanks hav- Tanks used in bulk gasoline Bulk gasoline plants
ing capacities less plants and equipped with are covered by another
than 1,600,000 liters vapor balance systems are rule.
used to store crude exempt.
oil & condensate prior
to lease custody
transfer are exempt.
R 226 4 6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF HYDROCARBONS
FROM TANK TRUCK GASOLINE LOADING TERMINALS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Tank Truck Gasoline
Terminal. A primary
distribution point for
delivering gasoline to
bulk plants, service
stations, and other
distribution points,
where the total gaso-
line throughput is
greater than 76,000
liters/day.
b) Loading Rack. An
aggregation or combi-
nation of gasoline
loading equipment
arranged so that all
loading outlets in the
combination can be
connected to a tank
truck or trailer park-
ed in a specified
loading space.
c) Continuous Vapor
Processing Device. A
hydrocarbon vapor con-
trol system that
treats vapors from
tank trucks or
trailers on a demand
basis without inter-
mediate accumulation.
d) Intermittent Vapor
Processing Device. A
hydrocarbon vapor
control system that
employs an inter-
mediate vapor holder
to accumulate re-
covered vapors from
WAC 173-490-020
"Gasoline loading terminal"
means a gasoline transfer
facility that receives more
than ten percent of its
annual gasoline throughput
solely or in combination by
pipeline, ship or barge,
and loads gasoline into
transport tanks.
The State definitions
of "gasoline loading
terminal" includes
facilities that
receive >10% of
throughput from pipe-
line, ship, or barge.
R 226
35
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF HYDROCARBONS
FROM TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
tank trucks or trail-
ers. The processing
unit treats the
accumulated vapors
only during automatic-
ally controlled
cycles.
2.0 APPLICABILITY
Applies to tank truck
terminals with daily
throughputs greater
than 76,000 liters
(20,000 gallons) of
gasoline.
2.2 TEST METHOD
REQUIREMENTS
Hydrocarbon mass
emission rates are
determined using flow
meters and hydrocarbon
analyzers. Combusti-
ble gas detectors or
EIP or NDIR type
hydrocarbon analyzers
may be used depending
on the sample point
and type of vapor
recovery system used.
WAC 173-490-040 (3)
Applies to all gasoline
loading terminals with an
average annual daily
throughput greater than
75,000 liters (20,000
gallons).
WAC 173-490-040
Test methods shall be on
file with and approved by
the Department.
The Department has not
adopted test methods for
portable analyzers.
The State rule is
consistent with EPA
requirements .
Alternative test
methods may reduce the
effectiveness of the
rule.
R 226
36
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF HYDROCARBONS
FROM TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.3 RECORDKEEPING
Portable Analzers may
be used to monitor for
leaks. Recordkeeping
requirements are not
identified in the CTG
but should be consis-
tent with time frames
for compliance.
3.0 EMISSION STANDARDS
RACT for loading
terminals is 80 milli-
grams of hydrocarbon
emissions per liter of
gasoline loaded.
Vapor control is re-
quired to control
emissions for top-
splash facilities.
Other facilities may
be equipped with top-
submerged or bottom-
fill.
Recordkeeping requirements
are not identified in the
rule.
Re cordkeeping
requirements can aid
enforcement activities
and help identify
equipment which
requires repair.
WAC 173-490-040 (3)
A vapor recovery system is
required and the following:
a) Submerged or bottom
loading.
b) 90% efficient vapor
recovery system and a
maximum of 80 mg/L
emissions.
The State rule is con-
sistent with EPA re-
quirements.
4.0 AVERAGING TIME
Testing at loading
terminals should be
based on a complete
loading cycle to
determine mass emis-
sion rates per volume
of gasoline trans-
ferred. Testing shall
be at least three
8-hour test repeti-
tions.
The State rule does not
specify averaging times for
compliance determinations.
Compliance tests
should comply with EPA
procedures.
R 226
37
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF HYDROCARBONS
FROM TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
5.0 EXEMPTIONS WAC 173-490-040 (3)
Terminals with daily Terminals with average The State rule is
throughputs less than daily throughput less than virtually consistent
76,000 liters (20,000 75,000 liters (20,000 with EPA requirements.
gallons). gallons).
38
R 226 6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM
BULK GASOLINE PLANTS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
There are no defini-
tions specified in the
CTG.
2.0 APPLICABILITY
Applicable to the
control of VOC
emissions from bulk
plants with daily
throughput of 76,000
liters of gasoline or
less.
2.2 TEST METHOD
REQUIREMENTS
The CTG does not
specify any test
methods for bulk
plants.
R 226
WAG 173-490-020
"Gasoline" means a petro-
leum distillate having a
true vapor pressure greater
than 200 mm of Hg (4 psia)
at 20°C, that is a liquid
at standard conditions of
760 mm of Hg and 20"C, and
is used as a fuel for
internal combustion
engines.
"Transport tank" means a
container having a useable
liquid volume greater than
1,000 liters (260 gallons)
used for shipping gasoline
on land, including but not
limited to, tank trucks,
tank trailers, railroad
tank cars, and metallic or
nonaetallic tanks or cells
conveyed on any vehicle.
WAC 173-490-040 (4)
Applicable to bulk gasoline
plants with an annual
average daily throughput
greater than 15,000 liters.
WAC 173-490-040
The State requires test
methods used for compliance
to be on file with and
approved by the Department.
39
The definition of
transport: tank
excludes tanks with
volumes less than 1000
liters.
Bulk plants with a
throughput less than
15,000 liters are not
regulated by the
State. EPA suggests
that severe economic
impacts may occur if
controls are required
for plants with
throughputs smaller
than 15,000 liters.
The State and the EPA
do not identify test
methods.
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM
BULK GASOLINE PLANTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
EPA lists three levels
of control:
I - submerged filling
of account trucks
II - I + Vapor balance
for gasoline delivery
to the storage tank.
Ill _ ii + vapor
balance for gasoline
delivery to account
trucks.
5.0 EXEMPTIONS
The CTG does not apply
to bulk plants with
daily throughputs of
more than 76,000
liters of gasoline.
WAC 173-490-040 (4)
Submerged fill line and
vapor balance system.
System provides for control
of vapor leaks during
transfer. Pressure relief
valves set at highest
setting.
The State regulation
is consistent with EPA
requirements.
WAC 173-490-040 (4)
a) Average daily through-
put £ 15,000 liters
(4000 gallons).
b) Stationary tanks with
a capacity ^ 550
gallons".
The State exemptions
for small sources
(£ 15,000 liters) may
be based on economic
effects on small
independent bulk
plants. The CTG
recommends considering
economic impacts for
small sources.
R 226
40
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM METAL CLEANING
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
WAG 173-490-020
None listed in the CTG
for solvent metal
cleaning.
2.0 APPLICABILITY
Applies to equipment
used for solvent metal
cleaning including
cold cleaners, open
top vapor degreasers,
and conveyorized
degreasers employing
organic solvents to
remove soluble impur-
ities from metal
surfaces.
2.2 TEST METHOD
REQUIREMENTS
a) Add-on control equip-
ment efficiencies
shall be determined
using EPA Method 23:
"Determination of
Total Non-methane
Hydrocarbons as
Perchloroe thylene
from Stationary
Sources."
None listed in WAC 173-490-
020.
WAC 173-490-040 (7)
Open Top Degreasers:
Applies to open top
degreasing equipment.
WAC 173-490-040 (8)
Conveyorized Degreasers:
Applies to conveyorized
cold cleaners and convey-
orized vapor degreasers.
WAC 173-490-040 (10)
Cold Cleaners: Applies to
cold cleaners.
WAC 173-490-040
Sources shall demonstrate
compliance with the
requirements herein using
sampling procedures on file
with and approved by the
director. The Department
has not
EPA Method 23 should
be used to determine
the concentration of
organics in accordance
with the CTG.
R 226
41
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY:
CONTROL OF VOC EMISSIONS FROM METAL CLEANING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
b) Vinyl chloride monomer
(VCM) shall be
determined by EPA
Method 106: "Deter-
mination of Vinyl
Chloride from
Stationary Sources."
c) EPA Methods 1 and 2
shall be used for
velocity and flow
measurements.
3 • ° EMISSION (OR EQUIPMENT) STANDARDS
adopted test methods for
VCM. EPA Method 25 is
specified by the Department
for determining the concen-
tration of organics.
a) Open top vapor
degreasers:
b) Conveyorized
Degreasers:
c) Cold Cleaners:
Equipment Specifications
are listed in WAC 173-490-
040 (7).
Equipment Specifications
are listed in WAC 173-490-
040 (8).
Equipment Specifications
are listed in WAC 173-490-
040 (10).
Power covers are not
required for surface
areas less than 1m.
The following require-
ments are excluded: 1)
drying tunnel, 2) min-
imized openings, and
downtime covers.
Approvable
R 226
42
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY:
CONTROL OF VOC EMISSIONS PROM METAL CLEANING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.0 EXEMPTIONS
a) The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas-
fired after-burners
under certain circum-
stances if provided
for in the SIP.
a) The installaion of a
N.G. fired incinerator
& capture system shall
be required during the
months of June, July,
August, and September.
WAC 173-490-040 (8) (f)
b) Major control devices
are required for con-
veyorized vapor de-
greasers and cold
cleaners with air/
vapor2interfaces of
2.0 m or greater.
This requirement may
be revised if attain-
ment of the ozone
standard cannot be
achieved following a
study of the VOC
reductions controlled
by incinerators in the
non-attainment
area(s).
2
The 2.0 m exemption
is contrary to CTG
requirements.
R 226
43
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM
REFINERY VACUUM PRODUCING SYSTEMS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
There are no defini-
tions listed in the
CTG.
2.0 APPLICABILITY
Applies to petroleum
refinery equipment
including vacuum
producing systems,
wastewater separators,
and process unit turn-
around (i.e., shut
down, repair or in-
spection and start-up
of a process unit.
WAC 173-490-020
"Crude oil" means a
naturally occurring mixture
which consist of hydro-
carbons and sulfur, mitro-
gen or oxygen derivatives
of hydrocarbons which is a
liquid at standard condi-
tions.
"Refinery unit" means a set
of components that are a
part of a basic process
operation, such as distil-
lation, hydrotreating,
cracking or reforming of
hydrocarbons.
WAC 173-490-040 (1)
Applies to petroleum
refineries with a crude oil
or feed stock capacity
greater than 1.5 million
liters (9000 bbl) per day.
The CTG does not spec-
ifically exempt equip-
ment in small refiner-
ies.
R 226
44
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM
REFINERY VACUUM PRODUCING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.3 RECORPKEEPING
Refinery operators
should maintain a
record of process unit
turnarounds and the
approximate quantity
of hydrocarbons
emitted to the
atmosphere. The
records should be
maintained for two
years.
3.0 EQUIPMENT STANDARDS
a) Non-condensibles from
condensers and hot
wells or accumulators
from vacuum producing
systems should be
incinerated.
b) Forelays and waste-
water separators
should be covered.
c) Process units shut
down for a turnaround
should be depress-
urized to vapor re-
covery, flare or a
firebox.
5.0 EXEMPTIONS
The CTG does not list
any exemptions for
petroleum refinery
equipment.
R 226
The State rule does not
specify any recordkeeping
requirements.
WAC 173-490-040 (1)
a) Emissions from vacuum
producing systems
piped to firebox,
incinerator, or closed
refinery system.
b) Wastewater separators:
floating pontoon or
fixed solid cover.
c) Process unit turn-
around VOC emissions
introduced to a closed
refinery system, com-
busted by a flare or
vented to a disposal
system. Pressure <5.0
PSIG before venting.
WAC 173-490-040 (1)
a) Petroleum refineries
with a crude oil or
feed stock capacity
<9000 bbl./day.
b) Wastewater separator
emitting < 25 T.P.Y.
45
EPA's recordkeeping
requirements are not
described in the State
rule.
The equipment stand-
ards are consistent
with EPA requirements.
Washington rules
provide exemptions.
Washington does not
have a refinery in the
Vancouver-Portland
nonattainment area.
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM THE USE OF CUTBACK ASPHALT
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None cited in the CTG.
2.0 APPLICABILITY
Applies to the emis-
sion of VOCs from the
use of paving asphalts
liquified with petro-
leum distillate.
WAC 173-490-020
"Cutback asphalt" means an
asphalt that has been
blended with petroleum
distillates to reduce the
viscosity for ease of
handling and lower applica-
tion tempera tore. An
inserted emulsified asphalt
shall be considered a
cutback asphalt when the
continuous phase of the
emulsion is cutback
asphalt.
WAC 173-490-040 (9)
Applies to paving opera-
tions using "cutback
asphalts."
The State rule is
consistent with EPA
requirements.
2.1 COMPLIANCE SCHEDULES
Compliance schedules
should be established
in the rules in accor-
dance with EPA policy.
The State rule applies to
all paving operations after
June 1, 1981.
2.2 TEST METHOD REQUIRE-
MENTS.
WAC 173-490-040
The CTG does not
specify testing
methods for cutback
asphalt.
Sampling procedures shall
be on file with and
approved by the director.
R 226
46
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY:
CONTROL OF VOCs FROM THE USE OF CUTBACK ASPHALT
(Continued)
U.S. EPA Control
Technology Guide-
-line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
VOC emissions from
cutback, asphalt shall
be controlled by
substitution of
emulsions during warm
weather.
WAC 173-490-040 (9)
Paving operations using
cutback asphalt are pro-
hibited during the months
of June, July, August, and
September.
The State restricts
the use of cutback
asphalt only during
the summer months.
This should reduce the
formation of oxidants
during the summer
months when ozone
exceedences occur.
5.0 EXEMPTIONS
There are no exemp-
tions identified in
the CTG.
WAC 173-490-040 (9)
a) Penetrating prime
coats
b) The manufacture of
patching mixes used
solely for pavement
maintenance and needed
to be stockpiled for
times longer than one
month.
c) Any paving when the
temperature is below
10°C (50"F).
The CTG does not spec-
ifically provide for
the exemptions cited,
but these exemptions
are not expected to
significantly impact
oxidant levels.
R 226
47
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: PETROLEUM REFINERY EQUIPMENT VOC LEAKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
WAC 173-490-020
The CTG does not
recommend that the
states define words or
phrases related to
petroleum refinery
equipment. However,
Zero Drift,
Calibration Error,
Calibration Drift, and
Response Time are
defined for instrument
performance.
2.0 APPLICABILITY
Applies to VOC leaks
from equipment in
petroleum refineries
including pump seals,
compressor seals and
oil degassing vents,
pipeline valves,
flanges and other
connections, pressure
relief devices,
process drains, and
open ended pipes.
"Petroleum refinery" means
a facility engaged in pro-
ducing gasoline, kerosene,
distillate fuel oil, resi-
dual fuel oils, lubricants,
or other products through
distillation of crude oil,
or through redistillation
cracking, extraction, or
reforming of unfinished
petroleum derivatives. Not
included are facilities
re-refining used motor oils
or waste chemicals,
processing finished petro-
leum products separating
blended groundwater, or air
blowing asphalt.
WAC 173-490-200 (1)
Applies to equipment in
petroleum refineries.
The applicability
sections are consis-
tent.
R 226
48
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: PETROLEUM REFINERY EQUIPMENT VOC LEAKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.1 COMPLIANCE SCHEDULES
Compliance schedules
should be established
in accordance with EPA
policy.
2.2 TEST METHOD REQUIRE-
MENTS
VOC leaks may be
detected by any
instrument designed to
respond .to total
hydrocarbons or
combustible gases.
a) Pump seals, valves,
and drains shall be
monitored annually,
with a portable VOC
device.
b) Compressor seals,
valves in gas service,
and pressure relief
valves shall be moni-
tored quarterly with a
portable VOC device.
c) Pump seals shall be
visually monitored
weekly.
WAC 173-490-200 (3)
Petroleum refineries are
required to submit monitor-
ing programs by July 1,
1981 and complete the first
quarter of monitoring by
December 15, 1981. The
State may approve an
alternate schedule of
control dates as specified
in WAC 173-490-071.
WAC 173-490-200 (4)
Testing and monitoring
shall be determined in
accordance with testing and
calibration procedures
approved by the director.
The Department has not
adopted test methods for
VOC leaks.
Consistent with EPA
requirements.
Alternate test methods
may reduce the effec-
tiveness of the rule.
R 226
49
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: PETROLEUM REFINERY EQUIPMENT VOC LEAKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.3 RECORDKEEPING
The owner/operator
shall maintain records
in accordance with
compliance time frames
specified in the rule.
3.0 EMISSION STANDARDS
Sources with VOC
concentrations which
exceed 10,000 ppm
shall be identified
for repairs.
4.0 AVERAGING TIME
VOC concentrations at
the source of equip-
ment leaks are instan-
tane ous rea dings.
5.0 EXEMPTIONS
None specified in the
CTG.
WAC 173-490-200 (6)
A leaking components moni-
toring log shall be main-
tained by the owner or
operator of a petroleum
refinery for two years.
WAC 173-490-130
Leaking components which
have a VOC concentration
greater than 10,000 ppm
shall be identified and
repaired as soon as
possible but within 15
days.
Not specified in the rule.
WAC 173-490-200 (8)
Alternative monitoring
schedules may be approved
by the director under
certain circumstances if
the owner/operator submits
a petition for a reduction
in monitoring frequency.
The State rule
requires recordkeeping
of leaking components
and the total number
of components tested.
The limits are consis-
tent with EPA policy.
Monitoring require-
ments for VOC detec-
tion should specify
that instantaneous
readings be used to
detect leaks.
R 226
50
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS
METAL PARTS AND PRODUCTS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Single coat means only
one film of coating is
applied to the metal
substrate.
b) Prime coat means the
first of two or more
films of coating
applied in an
operation.
c) Topcoat means the
final film or series
of films of coating
applied in a two-coat
(or more) operation.
d) Faraday caging means a
repelling force
generated in corners
and small enclosed
areas of the metal
substrate during
electrostatic spraying
of powders.
e) Blocking agent means
an organic agent which
blocks or inhibits
certain cross-linking
or polymerization
reactions. It is
designed to separate
from the monomer at
some elevated
WAC 173-490-020
The State rule does not
define any of the terms
identified in the CTG.
Some key definitions
are not included in
the State rule.
R 226
51
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS
METAL PARTS AND PRODUCTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
temperature thereby
allowing the reactions
to proceed.
f) Low organic solvent
coating (LOSC) refers
to coatings which
contain less organic
solvent than the
conventional coatings
used by the industry.
Low organic solvent
coatings include
wa ter-borne, higher
solids, electro-
deposition and powder
coa tings.
g) Heat sensitive mate-
rial, means materials
which cannot be
exposed to tempera-
tures greater than 80"
to 95°C (180° to
200°F).
h) Transfer efficiency
means the portion of
coating which is not
lost or wasted during
the application
process expressed as
percent.
2.0 APPLICABILITY
Applies to the surface
coating of miscellane-
ous metal parts and
products from job
shops and original
equipment manufactur-
ing industries, which
apply metal coatings
R 226
WAC 173-490-205 (1)
Applies to the surface
coating of miscellaneous
metal parts and products
for industries listed in
the rule with VOC emissions
greater than 235 pounds per
day.
52
Sources with emissions
up to 235 pounds per
pay and included in
the CTG are excluded
from regulation in
Wa shington's rule.
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS
METAL PARTS AND PRODUCTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
on metal substrates
not covered by other
CTGs. This includes:
1) Large farm machinery
2) Small farm machinery
3) Small appliances
4) Commercial machinery
5) Industrial machinery
6) Fabricated metal parts
7) Industrial Categories
in SIC Code Major
Group 33 through 41.
2.1 COMPLIANCE SCHEDULES
Compliance schedules
to be established in
accordance with EPA
policy.
2.2 TEST METHOD REQUIRE-
MENTS
EPA Reference Method
24 shall be used to
determine the VOC
content of coatings.
Washington's rule does
not include SIC Code
Major Group 40 (Rail-
road transportation)
or Major Group 41
(Transit Passenger
Transportation).
R 226
WAG 173-490-205 (3)
Final compliance is
required by January 1, 1983
if low solvent coatings are
to be used. Final compli-
ance for the installation
of add-on control devices
is required by January 1,
1983.
WAC 173-490-205 (4)
Testing and calibration
procedures to determine
compliance with coating
limits shall be consistent
with procedures on file and
approved by the Department.
The Department has not
adopted VOC content test
methods.
53
Consistent with EPA
policy.
Alternate test methods
may reduce the effec-
tiveness of the rule.
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OP MISCELLANEOUS
METAL PARTS AND PRODUCTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.3 RECORDKEEPING
Specific recordkeeping
requirements are not
identified in the CTG.
3.0 EMISSION STANDARDS
The State does not require
recordkeeping for indus-
tries in the miscellaneous
surface coating category.
WAC 173-490-205 (2)
a) Low Solvent Coatings -
Limit ranges from 0.4
to 4.4 Ibs/gal.
depending on the
coating. Powder
Coatings are limited
to 0.4 Ib/gal.
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effic-
iences are calculated
from VOC reductions on
an equivalent solids
basis.
a) Clear coatings - 4.3
Ib/gal.
b) Extreme performance
coatings - 3.5 Ib/gal.
c) Air-dried coatings -
3.5 Ib/gal.
d) All others - 3.0
Ib/gal.
e) Powder Coatings - 0.4
Ib/gal.
The least stringent limit
is used when more than one
category applies.
WAC 173-490-205 (2)
The required VOC emission
reduction shall be
calculated on a unit volume
of uncured solids basis.
The State standards
are in accordance with
EPA limits.
Equivalency should be
defined to avoid ambi-
guous limits for
alternate control
technologies.
R 226
54
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS
METAL PARTS AND PRODUCTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.2 CAPTURE EFFICIENCY
Equivalent emission
reductions for add-on
controls shall be
determined on an
equivalent solids
basis. The overall
reduction efficiency
shall be used for the
add-on control equip-
ment efficiency
including the perform-
ance of the capture
system.
5.0 EXEMPTIONS
The CTG for surface
coating of miscellane-
ous metal parts
excludes industries
covered in other
guidelines including:
1} Can;
2) Coil;
3) Automobile and Lt.
Duty Trucks;
4) Metal Furniture;
5) Magnetic Wire;
6} Large Appliances.
WAC 173-490-205 (2)
The State rule requires
that equivalent emission
reductions achieved with
add-on controls include the
performance of the capture
system.
The requirements in
the State role are
consistent with EPA
requirements.
WAC 173-490-205 (1)
The surface coating of
miscellaneous metal
parts does not apply
to 1) - 6) as listed
in CTG and:
1) Airplanes;
2) Automobile
refinishing;
3) Custom Auto top
coating for equip-
ment coating less
than 35 vehicles
per day;
The exemptions in the
State rule may reduce
its effectiveness.
R 226
55
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS
METAL PARTS AND PRODUCTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
4) Marine vessel
exteriors;
5) Applications
covered by other
CTGs;
6) Coating formula-
tions controlled
by federal speci-
fications and the
use of which are
required by-
federal agencies.
7) Sources with
emissions less
than 235
pounds/day.
R 226 56
6/28/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
STATIONARY SOURCES, VOLUME VII: FACTORY COATING OF FLATWOOD PANELING
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
"Printed panels" means
panels whose grain or
natural surface is
obscured by fillers
and basecoats upon
which a simulated
grain or decorative
pattern is printed.
"Hardwood plywood" is
plywood whose surface
layer is a veneer of
hardwood.
"Particleboard" is a
manufactured board
made of individual
wood particles which
have been coated with
a binder and formed
into flat sheets by
pressure. Thin
particleboard has a
thickness of one-
fourth inch or less.
"Natural finish hard-
wood plywood panels"
means panels whose
original grain pattern
is enhanced by essen-
tially transparent
finishes frequently
supplemented by
fillers and toners.
WAC 173-490-020
"Printed interior panels"
means panels whose grain or
natural surface is obscured
by fillers and basecoats
upon which a simulated
grain or decorative pattern
is printed.
"Thin particleboard" means
a manufactured board one-
quarter inch or less in
thickness made of individal
wood particles which have
been coated with a binder
and formed into flat sheets
by pressure.
"Class II hardboard
paneling finish" means
finishes which meet the
specifications of Voluntary
Product Standard PS-59-73
as approved by the American
National Standards Insti-
tute.
"Natural finish hardwood
plywood panels" means
panels whose original grain
pattern is enhanced by
essentially transparent
finishes frequently supple-
mented by fillers and
toners.
Some definitions iden-
tified in the CTG are
not defined in the
State rule.
R 226
57
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
STATIONARY SOURCES, VOLUME VII: FACTORY COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
"Hardboard" is a panel
manufactured primarily
from inter-felted
lignocellulosic fibers
which are consolidated
under heat and
pressure in a hot-
press .
"Class II hardboard
paneling finishes"
means finishes which
meet the specifica-
tions of Voluntary
Product Standard
PS-59-73 as approved
by the American
National Standards
Institute.
"Hardboard" means a panel
manufactured primarily from
interfelted lignocellulosic
fibers which are consoli-
dated under heat and
pressure in a hot press.
"Hardboard plywood" means
plywood whose surface layer
is a veneer of hardwood.
"Lauan" is an imported
tropical hardwood.
2.0 APPLICABILITY
a) Applies to flatwood
panel manufacturers
including:
1) Printed interior
wall panels made
of hardwood ply-
wood S thin
particleboard.
b) Natural finish hard-
wood plywood panels.
c) Class II finishes for
hardboard paneling.
R 226
WAC 173-490-207 (1)
a) Applies to all flat-
wood panel manufac-
tures and surface
finishers including
the following
products:
1) Printed interior
panels of hardwood
plywood and thin
particleboard.
2) Natural finish
hardwood panels.
3) Hardwood paneling
with Class II
finishes.
58
The applicability
section is consistent
with EPA requirements.
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
STATIONARY SOURCES, VOLUME VII: FACTORY COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.1 COMPLIANCE SCHEDULES
WAC 173-490-207 (3)
Compliance schedule
should be established
in accordance with EPA
policy.
2.2 TEST METHOD
REQUIREMENTS
The VOC content and
other properties of
coatings shall be
determined by EPA
reference method 24.
2.3 RECORDKEEPING
Low solvent coating tech-
nologies and the use of
add-on controls shall
achieve final compliance
before January 1, 1983.
WAC 173-490-207 (4)
Test methods shall be those
on file with and approved
by -die Department. The
Department has not identi-
fied a test method for the
VOC content of coatings.
Consistent with EPA
policy.
Alternative test
methods may reduce the
effectiveness of the
rule.
The CTG does not list
any recordkeeping
requirements.
The State rule does not
require flatwood paneling
surface coaters to maintain
records.
3.0 EMISSION STANDARDS
a) Printed interior
panels - 6.0 -
Ib VOC/1,000 ft^
product
b) Natural finish
hardwood - 12.0_
Ib VOC/1,000 ft
product
WAC 173-490-207 (2)
a) 6.0 Ib VOC/1,000 ft
product
b) 12.0 Ib VOC/1,000 ft
product
The emission standards
are consistent with
EPA requirements.
c) Class II finishes
hardboard - 10,0
Ib VOC/1,000 ft
product
c) 10.0 Ib VOC/1,000 ft
product.
R 226
59
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM EXISTING
STATIONARY SOURCES, VOLUME VIII FACTORY COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.1 CALCTTIATION METHODS
The p of VOC per 1000
ft. of product
finished is calculated
from the Ib VOC per
gal. coating and the
coating spread rate in
ft per gallon.
The CTG suggests that
an alternate procedure
to determine the Ib
VOC per ft of
product is to estimate
the quantity of VOCs
used and the quantity
of product finished
during a specified
time period. Current
EPA policy would limit
this time period to 24
hours.
4.0 AVERAGING TIME
See Calculation Pro-
cedures
5.0 EXEMPTIONS
Exterior siding, tile
board, and particle-
board-used as furni-
ture components.
d) An incineration sytem
which oxides 90% of
the VOC to C02 & H,0
using a capture with
good engineering
design.
Calculation methods are
defined in the State's
rules for equivalent VOC
reductions.
not Long term averaging
periods used for
compliance may reduce
the effectiveness of
the State rule.
WAC 173-490-207 (1)
Exterior siding, tileboard,
or particleboard used as a
furniture component.
The exemptions are
consistent with EPA
requirements.
R 226
60
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: GRAPHIC ARTS SYSTEMS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None Listed
WAC 173-490-020
"Flexographic Printing"
means the application of
words, designs and pictures
to a substrate by means of
a roll printing technique
in which the pattern to be
applied is raised above the
printing roll and the image
carrier is made of rubber
or other elastomeric
materials.
"Packaging Rotogravure
Printing" means rotogravure
printing upon paper, paper
board, metal foil, plastic
fill, and other substrates
which are in subsequent
operations formed into
packaging products and
labels for articles to be
sold.
"Roll Printing" means the
application of words,
designs, and pictures to a
substrate usually by means
of a series of hard rubber
or steel rolls each with
only partial coverage.
R 226
61
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: GRAPHIC ARTS SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
"Rotogravure Printing"
means the application of
words, designs, and
pictures to a substrate by
means of a rollprinting
technique which involves an
intaglio or recessed image
areas in the form of cells.
2.0 APPLICABILITY
Applies to printing
operations including
letter presses, off-
set lithography, roto-
gravure, and flexo-
graphy. This does
not apply to off set
lithography or letter
press printing.
2.1 COMPLIANCE SCHEDULES
Compliance schedules
to be established in
accordance with EPA
policy.
WAC 173-490-204 (1)
Applies to all packaging
ro togravure, publica tion
rotogravure, specialty
printing operations, and
flexographic printing
facilities that use more
than 100 tons per year of
volatile organic compounds
as a component of ink for
the thinning of ink,
cleaning of presses, press
components, and equipment.
Also applies to machines
with coating and printing
units.
WAC 173-490-204 (3)
Final compliance with this
rule is required by January
1, 1983 for low solvent
coating technology.
The 100 ton per year
exemption is not
identified in the CTG
for this source
category.
Consistent with EPA
policy.
R 226
62
6/29/88-CA-]
-------
TABLE 3
CTG SOURCE CATEGORY: GRAPHIC ARTS SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
None specified in the
CTG.
2.3 RECORDKEEPING
State rules should
require explicitly
that sources keep
records needed to
assess compliance for
the time frames
specified in the rule.
3.0 EMISSION STANDARDS
a} Add-on Controls
(Rotogravure)
1) Carbon Adsorption
- 90%
2) Incineration - 90%
3) Capture Efficiency
- 75-85%
Compliance for add-on
control is required by
January 1, 1987.
WAC 173-490-204 (4)
Test methods shall be on
file with and approved by
the Department.
None Required
WAC 173-490-204 (2)
90%
90%
The CTG does not iden-
tify a monitoring
frequency for compli-
ance but does require
periodic monitoring of
incinerator operating
parame ters. There-
fore, suitable records
may be appropriate.
The State rule does
not specify capture
efficiencies for
graphic arts systems.
The 75% efficiency for
rotogravure is not
discussed in the CTG.
R 226
63
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: GRAPHIC ARTS SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
4) Overall Efficiency
- 65%
b) Flexography
1) Overall Efficiency
_ 60%
2) Capture Efficiency
- 70%
For Coating Operation
Limits see the section
for cans, coils,
paper, fabrics, or
automobiles and it.
duty trucks.
3,2 CAPTURE EFFICIENCY
a) Rotogravure 75-85%
b) Flexography 70%
5.0 EXEMPTIONS
None listed in the
CTG.
65% for package rotogravure
or 75% for publication
rotogravure.
60%
5.1 "DIRECTOR DISCRETION"
EXEMPTIONS
None listed in the
CTG.
<. 25% V/V solvent & _>_
75% water
>, 60% V/V nonvolatile
material.
WAC 173-490-204 (2)
Overall efficiency spec-
ified instead of capture
efficiency.
WAC 173-490-204 (1)
Sources that use less than
100 tons per year of VOCs
as a component of ink, for
the thinning of ink,
cleaning of presses, press
components and equipment.
None Specified in WAC 173-
490-204
The State rule should
state efficiencies in
terms defined by CTG.
The EPA does not allow
an exemption for
sources with emissions
less than 100 tons per
year of VOCs.
R 226
64
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Condensate means a)
hydrocarbon liquid
separated from natural
gas which condenses
due to changes in the
temperature and/or
pressure and remains
liquid at standard
conditions.
b) Cost Effectiveness -
Cost (or credit) per
megagram of controlled
emissions. Given in
general by: (recovered
petroleum liquid value
- net annual control
system cost) 7 (mega-
rams of controlled
emissions) « cost (or
credit)/Mg, controlled
emissions.
c) Crude oil means a c)
naturally occurring
mixture consisting of
hydrocarbons and/or
sulfur, nitrogen
and/or oxygen
derivatives of
hydrocarbons and which
is a liquid in the
reservoir and at
standard conditions.
WAC 173-490-020
"Condensate" means
hydrocarbon liquid
separated from natural
gas which condenses
due to changes in the
temperature or
pressure and remains
liquid at standard
conditions.
"Crude oil" means a
naturally occurring
mixture which consists
of hydrocarbons and
sulfur, nitrogen or
oxygen derivatives of
hydrocarbons which is
a liquid at standard
conditions.
The State definition
of petroleum liquids
excludes fuel oils.
Therefore this rule
would not apply to the
storage of fuel oils.
d) Custody transfer means
the transfer of
produced crude oil
d) "Lease custody
transfer" means the
transfer of produced
R 226
65
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OP VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF-TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
and/or condensate,
after processing
and/or treating in the
producing operations,
from storage tanks or
automatic transfer
facilities to
pipelines or any other
forms of transporat-
ion.
crude oil or
condensate, after
processing or treat-
ing in the producing
opera tions, from
storage tanks or auto-
matic transfer facili-
ties to pipelines or
any other forms of
transpor ta tion.
e) External floating roof
means a storage vessel
cover in an open top
tank consisting of a
double deck or pontoon
single deck which
rests upon and is
supported by the
petroleum liquid being
contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
e)
"External floating
roof" means a storage
vessel cover in an
open top tank
consisting of a double
deck or pontoon single
deck which rests upon
and is supported by
the petroleum liquid
being contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank wall.
f) Internal floating roof
means a cover or roof
in a fixed roof tank
which rests upon or is
floated upon the
petroleum liquid being
contained, and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
R 226
66
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
g) Liauid-mounted means a g)
primary seal mounted
so the bottom of the
seal covers the liquid
surface between the
tank shell and the
floating roof.
h) Vapor-mounted means a h)
primary seal mounted
so there is an annular
vapor space underneath
the seal. The annular
vapor space is bounded
by the bottom of the
primary seal, the tank
shell, the liquid
surface, and the
floating roof.
i) Petroleum liquids i)
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery.
"Liquid-mounted seal"
means a primary seal
mounted in continuous
contact with the
liquid between the
tank wall and the
floating roof around
the circumference of
the tank.
"Vapor-mounted seal"
means a primary seal
mounted so there is an
annular vapor space
underneath the seal.
The annular vapor
space is bounded by
the bottom of the
primary seal, the tank
wall, the liquid
surface, and the
floating roof.
"Petroleum liquids"
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery,
excluding No.2 through
6 fuel oils (ASTM
D396-69), No. 2GT
through 4 GT gas
turbine fuel oils
(ASTM D2880-71) or No.
2D and 4D diesel fuel
oils (ASTM D975-68).
R 226
67
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
j) True vapor pressure
means the equilibrium
partial pressure
exerted by a petroleum
liquid as determined
in accordance with
methods described in
American Petroleum
Institute (API)
Bulletin 2517,
Evaporation Loss from
Floating Roof Tanks,
1962. The API
procedure may not be
applicable to some
high viscosity or high
pour crudes.
Available estimates of
true vapor pressure
may be used in special
cases such as these.
k) Volatile Organic
Compounds (VOC ? - see
Table 1, Section 5
2«0 APPLICABILITY
Applies to the control
of VOCs from the
storage of petroleum
liquids in external
floating roof tanks
larger than 150,000
liters with a true VP
greater than 1.5 psi.
These requirements do
not apply to fixed
roof tanks (with or
without internal
floating roofs) or to
small production
tanks.
R 226
j)
"True vapor pressure"
means the equilibrium
partial pressure of a
petroleum liquid as
determined with
methods described in
American Petroleum
Institute Bulletin
2517, 1980.
k) "Volatile Organic
Compound" - see Table
1, Section 5
WAC 173-490-201 (1)
Applies to all liquid
storage vessels equipped
with external floating
roofs having a capacity
greater than 150,000 liters
(40,000 gal) with a true VP
greater than 1.5 psi.
State rule is
consistent with CTG.
68
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS PROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.1 COMPLIANCE SCHEDULES
Compliance schedule
to be determined in
accordance with EPA
policy.
2.2 TEST METHOD
REQUIREMENTS
Visual inspections
required as described
below.
WAC 173-490-201 (3)
Final compliance with the
requirements in the rule is
required before January 1,
1982.
WAC 173-490-201 (4)
Visual inspections required
as described below.
Consistent with EPA
policy
2.3 RECORDKEEPING
a) Annual visual inspec-
tions should be con-
ducted and secondary
seal gaps measured.
Evidence of any type
of malfunction should
be recorded.
b) A record of the aver-
age monthly storage
temperature and vapor
pressure (VP) of
liquids stored in
tanks without second-
ary seals should be
maintained for not
more than 2 years.
WAC 173-490-201 (2)
a) Records are required
for:
1} The type of
liquids stored and
the max. VP;
2) The results of
annual
inspections;
3} Storage tempera-
ture, liquid type
and VP for liquids
with a VP greater
than 7.0 kPa (1.0
psi) and exempt
from regulation.
b) Copies of all records
shall be retained by
the owner or operator
for a minimum of 2
years after the date
on which the record
was made.
Recordkeeping require-
ments are consistent
with EPA requirements.
R 226
69
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EQUIPMENT STANDARDS
Vessels must have
- rim mounted second-
ary seal
- an equally effec-
tive seal closure
device
- no holes, tears, or
other openings.
intact and uni-
formly placed seal.
- gaps >1/8 in. accu-
mulate to <1.0 in /
ft
- openings covered.
5.0 EXEMPTIONS
a) RACT for External
Floating Roof Tanks
(EFRT) is not required
for the following:
1) Welded EFRT equip-
ped with primary
seals if the TVP
is less than 27.6
kPa (4 psi).
2) A welded or
riveted EFRT with
primary seals and
a VP less than
10.5 kPa (1.5
psi).
WAC 173-490-201 (2)
Vessels must have
- rim mounted secondary
seal
- an equally effective
seal closure device
- no holes, tears, or
openings
- uniform and intact seal
- gaps 1/8 in. accumulate
to <1.0 in. /ft
- openings covered
WAC 173-490-201 (1)
The following are exempt
from this regulation:
a) Petroleum liquids with
a VP less than 27.6
kPa (4.0 psia') of
welded construction
and have specified
seals.
b) Tanks with storage
capacities less than
1,600,000 liters,
prior to lease custody
transfer.
The exemptions are similai
to CTG requirements.
R 226
70
6/29/88-CAT
-------
TABLE 3
GIG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM
PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3} A riveted EFRT
equipped with
primary metallic
shoe or liquid
mounted seals if
the TVP is less
than 10.5 kPa (1.5
psi).
4) EFRTs having capa-
cities less than
1,600,000 liters
used to store pro-
duced crude oil
and condensate
prior to custody
transfer.
5) Liquid storage, of
waxy, heavy pour
crudes.
6) Welded tanks with
shoe-mounted
secondary seals.
c) Liquid storage of
waxy, heavy pour crude
oil.
d) Welded tanks with shoe
mounted secondary
seals.
e) Petroleum liquids with
a true VP less than
10.5 kpa (1.5 psia).
R 226
71
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Affected facilities
should include the
washer, dryer, filter
and purification
systems, waste dis-
posal systems, holding
tanks, pumps, and
attendant piping and
valves.
2.0 APPLICABILITY
a) Applies to all dry
cleaning equipment
using perchloro-
ethylene except coin-
operated facilities
and facilities with
insufficient space or
steam for adsorbing
the adsorber.
WAC 173-490-020
"Dry Cleaning facility"
means a facility engaged in
the cleaning of fabrics in
an essentially nonaqueous
solvent by means of one or
more washes in solvent,
extraction of excess
solvent by spinning, and
drying by tumbling in an
airstream. The facility
includes but is not limited
to, any washer, dryer,
filter, and purification
systems, waste disposal
systems, holding tanks,
pumps and attendant piping
and valves.
WAC 173-490-203 (1)
a) Applies to all dry
cleaning equipment
using perchloro-
ethylene except those
which are coin-
operated, have
emissions less than
two tons per year and
systems with insuffi-
cient steam capacity
to desorb adsorbers.
Consistent with EPA
requirements.
The two ton per year
exemption should be
deleted to conform to
EPA requirements.
R 226
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6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
Sta te Rule
Comments
2.1 COMPLIANCE SCHEDULES
Compliance schedule
to be determined in
accordance with EPA
policy.
2.2 TEST METHOD
REQUIREMENTS
Perchloroe thylene
emissions from an
adsorber vent shall be
determined using an
integrated bag
sampling procedure
followed by gas
chromatographic/flame
ionization detector in
accordance with Draft
EPA Method 23. Liquid
leakage shall be
determined by visual
inspection.
WAC 173-490-203 (3)
a) Final Compliance is
required by July 1,
1982, for perchloro-
ethylene dry cleaning
systems.
WAC 173-490-203 (4)
Liquid leakage of equipment
shall be determined by a
visual inpsection. The
Department has adopted EPA
Method 25 for the deter-
mination of organics.
Consistent with EPA
policy.
EPA Method 23 should
be used as specified
in the CTG.
3.0 EMISSION STAND-
ARDS
a) Organic solvent a)
concentration from the
dryer control device
shall not exceed 100
ppm before dilution.
b) The filter residue b)
shall not contain over
25 kg VOCs/100 kg of
wet waste
WAC 173-490-203 (2)
VOC emissions from the
dryer control device
shall be limited to
100 ppmv before
dilution.
The filter residue
shall not contain over
25 kg of VOCs per 100
kg of wet waste.
Equivalency should be
defined in State rule. IT
WAC 173-490-203 (2,a,i), i
typographical error noted:
"absorption" should be
"adsorption."
R 226
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6/29/88-CAT
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TABLE 3
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
c) Filters must be c)
drained for 24 hours
d) All components found d)
to be leaking VOCs
shall be repaired.
e) Equivalent systems e)
shall reduce waste
loses to 1 kg
solvent/100 kg clothes
cleaned.
Filters must be
drained for 24 hours.
All components found
to be leaking VOCs
shall be Immediately
repaired.
Equivalency is not
defined.
3.1 CALCULATION METHODS
Use a material balance
to estimate solvent
losses.
5.0 EXEMPTIONS
Carbon adsorbers are
not required for
plants where inade-
quate space or
insufficient steam
capacity are avail-
able. Plants may also
be exempt from instal-
ling carbon adsorbers
due to other unspec-
ified hardships in the
CTG.
None listed
WAC 173-490-203 (1)
Carbon adsorbers are not
required for:
a) Coin-operated systems
b) Systems located in a
facility with
inadequate space
c) Systems with an
average monthly loss
less than 25 gallons
(2 tons per year)
d) Systems with
insufficient steam
capacity.
State rule does not
comment on calculation
procedures.
The exemption for
small sources (Approx.
11 Ib/day) are not
discussed in the CTG.
R 226
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6/29/88-CAT
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TABLE 3
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.1 DIRECTOR DISCRETION
EXEMPTIONS
None Listed
WAC 173-490-203 (1)
The director may grant an
exemption from the
requirement to install a
carbon adsorder when
sufficient evidence is
submitted to justify the
exemption. Refer to the
conditions listed in 5.0
above.
The director may
exempt sources from
control requirements.
R 226
75
6/29/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC LEAKS FROM
GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Truck Tank - Any
conta iner, including
associated pipes and
fittings, that is used
for the transport of
gasoline
Truck Tank Vapor
Collection Equipment -
Any piping, hoses, and
devices on the truck
tank used to collect
and route gasoline
vapors in the tank to
the bulk terminal,
bulk plant or service
station vapor control
system.
Vapor Control System -
Any piping, hoses,
equipment, and devices
at the bulk terminal,
bulk plant, or service
station, which is used
to collect, store,
and/or process
gasoline vapors.
Compartment•- A
liquid-tight division
of a truck tank.
2.0 APPLICABILITY
Applies to gasoline
tank trucks and vapor
collection systems at
bulk terminals, bulk
plants, and service
stations.
WAC 173-490-020
"Transport tank" means a
container greater than 1000
liters (260 gallons) used
for shipping gasoline on
land, including but not
limited to, tank trucks,
tank trailers, railroad
tank cars, and metallic or
non metallic tanks or cells
conveyed on any vehicle.
The State definition
does not include tank
trucks less than 1000
liters.
"Vapor control system"
means a system designed and
operated to reduce or limit
the emission of VOC, or to
recover the VOC to prevent
their emission into the
ambient air.
WAC 173-490-202 (1)
Applies to gasoline
transport tanks equipped
for gasoline vapor
collection and all vapor
collection systems at
gasoline loading terminals,
Note that the
definition of
transport tank has a
size cutoff.
R 226
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6/30/88-CAT
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC LEAKS FROM
GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
bulk gasoline plants, and
gasoline dispensing
facilities.
2.1 COMPLIANCE SCHEDULES
Compliance schedule to
be determined in
accordance with EPA
policy.
2.2 TEST METHOD REQUIRE-
MENTS
a) Truck leak test -
Pressure and vacuum
are applied and
changes noted.
b) Leak detection for
monitoring should be
performed with a
portable gas detector
or a bag capture
procedure.
2.3 RECORDKEEPING
a) Tank trucks shall be
labeled to indicate
the date of the last
pressure test.
WAC 173-490-202 (3)
Certification of vapor
collection systems shall be
completed before July 1,
1982. Alternative compli-
ance schedules may be
allowed in accordance with
WAC 173-490-071 not to
exceed the photochemical
oxidant attainment date.
WAC 173-490-202 (4)
Test procedures shall be
consistent with the
procedures on file with and
approved by the Department.
The Department has not
adopted source test methods
for leak detection.
WAC 173-490-202 (5)
a) Owners/Operators of
gasoline transport
tanks or vapor collec-
tion systems shall
maintain records for
at least 2 yrs.
Consistent with EPA
policy.
Alternative test
procedures may reduce
the effectiveness of
the rule.
Recordkeeping require-
ments are consistent
with EPA requirements
for tanks and collec-
tion systems.
R 226
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TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC LEAKS FROM
GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
b) Bulk terminal, bulk
plant, and service
station owners must
keep records for 2 yrs
indicating the results
of a leak test using a
portable gas detector.
3.0 EQUIPMENT STANDARDS
a) Sustain a pressure
change <.75 kPa in 5
min. when pressurized
to 4.5 kPa or evacu-
ated to 1.5 kPa.
WAG 173-490-202 (2)
a) Tested annually for
certification; sus-
tains a pressure
change <0.75 kPa in 5
min. when pressurized
to 4.5 kPa or evacu-
ated to 1.5 kPa.
The equipment stand-
ards are consistent
with EPA requirements.
b) No visible leaks.
c) Vapor collection
system:
Pressure specifica-
tions
- Cone, of gas vapors
-------
TABLE 3
CTG SOURCE CATEGORY: CONTROL OF VOC LEAKS FROM
GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.0 EXEMPTIONS
There are no specific
exemptions listed in
the CTG.
WAC 173-490-020 (41)
The definition of
"transport tank"
excludes sources less
than 1000 liters.
Small tank trucks are
excluded from State
requirements.
R 226
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6/30/88-CA3
-------
TABLE 4
VOC RULE EVALUATION BY SOURCE CATEGORY - OREGON
CTG SOURCE CATEGORY: SURFACE COATING OF CANS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
(See Automobile and
Lt. Duty Trucks in
Table 3)
OAR 340-22-102
(See Auto and Lt. Duty
Trucks in Table 4)
2.0 APPLICABILITY
Applies to two-piece
and three-piece con-
tinuous can manufac-
turing operations
including fabrication,
coating, and drying.
2.1 COMPLIANCE SCHEDULES
Not specified but required
by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-170 (2),(3)
All coating lines includ-
ing: application areas,
flashoff areas, air and
forced air driers, and
ovens; all sources emitting
>40 tons per year.
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
Some key definitions
are not included.
CTG has some common
terminology defined in
Appendix C.
OAR is specific for
gasoline dispenser;
storing could be more
general to encompass
all sources. Similar-
ly, both make stipula-
tion that 0.1 mm Hg is
determining VP.
Sources under 40
tons/year are exempt.
The State rule should
specifically refer to
EPA test methods if this
is, in fact, the intention.
Otherwise, approval of
state test methods is
pending.
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF CANS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Sheet basecoat and
overvarnish two-piece
can exterior 2.8
Ib/gal.
b) Two- and Three-piece
can Interior -4.2
Ib/gal.
c) Three-piece can side
seam - 5.5 Ib/gal.
d) End Seal - 3.7 Ib/gal.
4.0 AVERAGING TIME
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTIONS
Coating lines with
small quantities of
emissions may be
exempt from regula-
tion.
a)
OAR 340-22-170 (4)
Sheet basecoat, 2.8
Ib/gal.
b) Two- and three-piece
can, 4.2 Ib/gal.
c) Three-piece can side
seam, 5.5 Ib/gal.
d) End sealing compound,
3.7 Ib/gal.
OAR 340-22-170 (1)
Daily
OAR 340-22-170 (2)
Sources with emissions
<40 tons/year.
The emission limits
are consistent with
CTG requirements.
State rule quantifies
emission limit in
definition of small
emission.
R 226
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TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF PAPER
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
(See Definitions for
Autos and Lt. Duty
Trucks in Table 3)
2.0 APPLICABILITY
Applies to equipment
coating paper, pres-
sure sensitive tape
(including paper,
fabric, or plastic
film), and web coating
processes on plastic
film such as type-
writer ribbons, photo-
graphic film, and
magnetic tape.
2.1 COMPLIANCE SCHEDULES
Not specified but
required by EPA policy
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-102
(See Definitions for Autos
and Lt. Duty Trucks in
Table 4)
OAR 340-22-170 (2),(3)
Sources emitting >40
tons/year. This rule
applies to each coating
line, which includes the
application area(s), flash-
off area(s), air and forced
air drier(s), and oven(s).
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
Some key definitions
have not been includ-
ed. The CTG gives
common terminology
definitions.
Sources under 40
tons/year are exempt.
State rule is less
specific in applica-
bility statement.
The State rule should
specifically refer to
EPA test methods if this
is, in fact, the inten-
tion. Otherwise, approval
of state test methods is
pending.
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF PAPER
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
Coating Line - 2.9
Ib/gal.
4.0 AVERAGING TIMES
Averaging tines are
limited to 24 hours
unless otherwise
approved in the SIP
5.0 EXEMPTIONS
Coating lines with
small quantities of
emissions may be
exempt from
regulation.
OAR 340-22-170 (4)
2.9 Ib/gal
If more than one emission
limitation in 340-22-170
applies to a specific
coating, then the least
stringent emission limi-
tation shall be applied.
For existing coating of
paper and film in the
Medford-Ashland AQMA,
emission limitation of 55
lb VOC/1000 sq. yds. of
material per pass.
OAR 340-22-170 (1)
Daily
Limitations shall be based
on a monthly average for
existing coating of paper
and film in the Medford-
Ashland AQMA.
OAR 340-22-170 (2)
Sources with emissions <40
tons/year.
OAR meets emission
limitation. However,
standard in Medford-
Ashland AQMA may
reduce effectiveness
of the rule.
State specifies
emission limit for
"small quantities."
R 226
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TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF FABRICS AND VINYL
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS.
(See Definitions for
Autos and Lt. Duty
Trucks in Table 3)
2.0 APPLICABILITY
Applies to fabric
coating equipment used
to apply all types of
coatings to fabric,
including rubber,
rainwear, tents,
gaskets, and dia-
phragms. "Vinyl Coat-
ing" refers to any
printing or decorative
or protective topcoat
applied over vinyl
coated fabric or
plastic sheets.
2.1 COMPLIANCE SCHEDULES
Not specified but re~
quired by EPA policy
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods
OAR 340-22-102
(See Definitions for Autos
and Lt. Duty Trucks in
Table 4)
OAR 340-22-170 (2),(3)
Sources emitting >40
tons/year.
Applies to each coating
line which includes the
applica tion area(s),
flashoff area(s), air and
forced air drier(s), and
oven(s).
Some definitions
missing. Definitions
in the categories
would be useful in
avoiding ambiguity.
The CTG does not
exempt emission
sources with less than
40 tons/year.
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
The State rule should
specifically refer to
EPA test methods if this
is, in fact, the intention.
Otherwise, approval of
state test methods is
pending.
R 226
84
6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF FABRICS AND VINYL
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Fabric Coating Line
2.9 Ib/gal.
b) Vinyl Coating Line 3.8
Ib/gal.
4.0 AVERAGING TIME
Averaging time is
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTION
Coating Lines with
small quantities of
emissions may be
exempt from regula-
tion.
OAR 340-22-170 (4)
a) Fabric - 2.9 Ib/gal
b) Vinyl - 3.8 Ib/gal
If more than one emission
limitation in 340-22-170
applies to a specific
coating, then the least
stringent emission
limitation shall be
applied.
OAR 340-22-170 (1)
Daily average
OAR 340-22-170 (2)
Sources that emit <40
tons/year.
The State rule quanti-
fies the statement in
the CTG concerning
small emissions.
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1-° DEFINITIONS
a) "Coating Applicator"
b) "Oven"
c) "Coating Line"
a)
OAR 340-22-102
Not defined
Some key definitions
not mentioned at all
within this rule.
b) Not defined
c) "Coating line" means
one or more apparatus
or operations which
include a coating
applicator, flash-off
area, and oven or
drying station where-
in a surface coating
is applied, dried,
and/or cured.
d)
"Owner" or "Operator
d)
"Operator" means any
person who leases,
operates, controls, or
supervises a facility
at which gasoline is
dispensed.
"Owner" means any
person who has legal
or equitable title to
the gasoline storage
tanks at a facility.
e)
"Standard Conditions
e) Not defined in OAR
340-22-(100 to 220)
R 226
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6/30/88-CAT
-------
CTG SOURCE CATEGORY:
TABLE 4
SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
f) "Volatile Organic
Compounds"
f) "Volatile Organic
Compound," (VOC),
means any compound of
carbon that is photo-
chemically reactive.
Excluded from the cat-
egory of Volatile
Organic Compounds are
carbon monoxide, car-
bon dioxide, carbonic
acid, metallic car-
bides or carbonates,
ammonium carbonate,
and those compounds
which the U.S. Envir-
onmental Protection
Agency classifies as
being of negligible
photochemical reacti-
vity which are
me thane, e thane,
methyl chloroform,
methylene chloride,
and trichlorotri-
fluoroe thane.
g) "Day*
g) "Day" means a 24-hour
period beginning at
midnight.
h) "Capture System"
i) "Control Device"
j) "Approved"
h) Not explicitly defined
i) Not explicitly de-
fined; description in
OAR 340-22-170 (6)
j)
Not defined
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.0 APPLICABILITY
Applies to equipment
or processes, used to
coat automobiles and
light duty trucks in
assembly plants.
2.1 COMPLIANCE SCHEDULES
Not specified but re-
quired by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-170 (2),(3)
Sources emitting >40
tons/year.
Prime
Topcoat
Repair
Including application
areas, flash-off areas, air
and forced air driers and
ovens.
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Compliance determined
by testing in accor-
dance with Method 24,
25, a material balance
method, or an equiva-
lent plant specific
method approved by and
on file with the
Department.
OAR includes "repair"
areas. State rule
includes exemption for
small sources of a
size less than
specified limit.
The State rule should
specifically refer to
EPA test methods if
this is, in fact, the
intention. Otherwise,
approval of state test
methods is pending.
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
SURFACE COATING OF AUTOMOBILES AND LIGHT DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Prime Application
1) Water-borne (elec-
trodeposition)
(1.9 Ib/gal.) 80-
93%
>50% v/v solids
0-65%
2) Incineration 90%
3) Carbon Adsorption
85%
b) Prime cure oven
1) Wa ter-borne (elec-
trodeposition}
(1.9 Ib/gal)
80-93%
>50% v/v solids
0-65%
2) incineration 90%
c) Topcoat application
and flashoff area
1) Waterborne topcoat
(2.26 Ib/gal)
40-92%
>50% v/v solids
topcoat 0-86%
2) Incineration 90%
3) Carbon Adsorption
85%
OAR 340-22-170 (4)
Prime Coat 1.9 Ib/gal
Topcoat 2.8 Ib/gal
Repair 4.8 Ib/gal
(All excluding water).
OAR limitations meet
recommended limita-
tions.
R 226
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6/30/88-CAT
-------
CTG SOURCE CATEGORY:
TABLE 4
SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
d) Topcoat cure oven
1) Water-borne top-
coat (2.76 Ib/gal)
40-92%
>50% v/v topcoat
0-86%
2) Incineration 90%
4.0 AVERAGING TIME
Averaging times are
limited to 24 hours
unless otherwise
approved in the SIP.
5.0 EXEMPTIONS
Coating lines with
small quantities of
emissions may be
exempt from regula-
tion.
OAR 340-22-170 (1)
Daily
This is consistent
with EPA requirements
OAR 340-22-170 (2)
Sources with emissions
<40 tons/year.
The State rule defines
a small emission in
quantitative terms.
R 226
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6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
1.0 DEFINITIONS
"Prime coat" means the None of the CTG definitions Key definitions not
first film of coating listed here can be found in defined in OAR.
applied in a 2-coat OAR. (See definitions in Definitions listed in
application. Autos and Lt. Duty Trucks specific CTG cate-
in Table 4). gories would be
"Top coat" means the helpful.
final film of coating
applied in a 2-coat
operation.
"Single Coat" means
only one film of
coating is applied on
the metal substrate.
"Faraday caging" means
a repelling force
generated during
electrostatic spraying
of powders in corners
and small enclosed
areas of metal
substrate.
"Blocking Agent" means
an agent which is
released from the
polymer matrix during
the curing process.
It is normally an
organic radical and
splits from the
monomer or oligmer at
a predetermined
temperature, thereby
exposing reactive
sites which then
combine to form the
polymer. Such re-
actions during the
curing process may
release additional
VOCs to the atmos-
phere .
R 226 91
6/30/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
"Low Organic Solvent
Coating" refers to
coatings which contain
less organic solvent
than the conventional
coatings used by
industry. Low organic
solvent coatings
include water-borne,
higher solids, elec-
trodeposition and
powder coatings.
2.0 APPLICABILITY
Applies to equipment
used for the surface
coating of metal
furniture which
includes any furniture
made of metal or any
metal part which will
be assembled with
other metal, wood,
fabric, plastic, or
glass.
2.1 COMPLIANCE SCHEDULES"
Not specified but re-
required by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-170 (3)
All facilities emitting
>40 tons/year.
Applies to each coating
line, which includes the
application area(s), flash-
off area(s), air and forced
air drier(s), and oven(s)
used in the surface coat-
ing of metal parts and pro-
ducts in 340-22-170 (4).
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
Because rule is
written around
low-organic or water-
borne solvents, a
specific definition
should be included.
The State rule should
specifically refer to
EPA test methods if
this is, in fact,
the intention. Other-
wise, approval of state
test methods is pending.
R 226
92
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF METAL FURNITURE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Metal Furniture
Coating - 3.0 Ib/gal.
coating minus water.
b) Add on controls - 80%
reduction overall
OAR 340-22-170 (4)
3.0 Ib/gal coating less
water
The solvent content
standard is consistent
with EPA requirements.
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effi-
ciencies are calcu-
lated from VOC reduc-
tions on an equiva-
lent solids basis.
Not specified
in detail
The State rule does
not define specifics of
equivalent emission
reduction calculation
procedures.
3.2 CAPTURE EFFICIENCY
Limits are based on
overall efficiencies,
therefore the capture
efficiency is equip-
ment specific.
4.0 AVERAGING TIME
Daily, as in other
surface coating cate-
gories
5.0 EXEMPTIONS
Not specified
Not specified
State rule does not
explicitly comment on
capture efficiency.
OAR 340-22-170 (1)
Daily
OAR 340-22-170 (2)
High performance inorganic
zinc coatings which are
air-dried and applied to
fabricated steel. Any
source emitting <40
tons/year.
This is consistent
with EPA policy.
OAR does not distin-
guish if fabricated
steel is being used
for furniture —
exemption is unclear.
R 226
93
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF MAGNETIC WIRE
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None specified in the
CTG.
OAR 340-22-102
^•Coating line" means one or
more apparatus or opera-
tions which include a coat-
ing applicator, flash-off
area, and oven or drying
station wherein a surface
coating is applied, dried,
and/or cured.
2.0 APPLICABILITY
Applies to equipment
used to apply varnish
or enamel to electric
wire for insulation.
OAR 340-22-170 (2),(3)
Ovens, flash-off areas,
air- and forced air-driers,
application areas.
Sources emitting >40
tons/year.
State rule is not
applicable to small
sources.
2.1 COMPLIANCE SCHEDULES
Not specified but
required by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-170 CD
December 31, 1982
OAR 340-22-170 (5)
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
The State rule should
specifically refer to
EPA test methods if
this is, in fact, the
intention. Otherwise,
approval of state
test methods is pending.
3.0 EMISSION STANDARDS
a) Wire Coating Oven -
1.7 Ib/gal.
b) Incineration of
solvent emissions.
R 226
OAR 340-22-170 (4)
1.7 Ib. solvent/gal.
coating. Does not specify
technique of reduction.
94
The VOC content limits
for coatings are
consistent with EPA
requirements.
7/01/88-CAT
-------
•TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF MAGNETIC WIRE
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effi-
ciencies are calcula-
ted from VOC reduc-
tions on an equiva-
lent solids basis.
Calculation methods are not
defined in detail within the
State rule.
The State rule does
not define specifics
of equivalent emission
reduction calculation
procedures.
4.0 AVERAGING TIME
Not specified
OAR 346-22-170 (1)
Daily
5.0 EXEMPTIONS
The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas
fired burners under
certain circumstances
if provided for in the
SIP.
OAR 340-22-170 (2)
Sources emitting <40
tons/year.
The State rule has an
exemption for small
emission sources of
<40 tons/year.
R 226
95
7/01/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF LARGE APPLIANCES
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Same as those for
Metal Furniture
None of the CTG definitions
are found in OAR (See de-
finitions in Autos and Lt.
Duty Trucks in Table 4).
See definition of "Coating
Line" from OAR in Table 4,
Surface Coating of Magnetic
Wire.
OAR does not make key
definitions.
2.0 APPLICABILITY
Applies to equipment
used for the coating
of large appliances
including doors,
cases, lids, panels,
parts of washers,
dryers, ranges,
refrigerators,
freezers, water
heaters, dishwashers,
trash compactors, air
conditioners and other
associated produces.
2.1 COMPLIANCE SCHEDULES
Not specified but
required by EPA policy.
OAR 340-22-170 (3)
Applies to each coating
line, which includes the
application area(s), flash-
off area(s), air- and
forced air-drier(s), and
oven(s) used in the surface
coating of the metal parts
and products in 340-22-170
(4).
OAR 340-22-170 (1)
December 31, 1982
OAR should be specific
in this regard.
2.2 TEST METHOD
REQUIREMENTS
CTG references EPA
Method 24 or equiva-
lent ASTM Methods.
OAR 340-22-170 (55
Compliance determined by
testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
The State rule should
specifically refer to
EPA test methods if this
is, in fact, the inten-
tion . Otherwise, approval
of state test methods is
pending.
R 226
96
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OP LARGE APPLIANCES
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
2.8 Ib/gal. coating
excluding water.
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effi-
ciencies are calcula-
ted from VOC reduc-
tions on an equiva-
lent solids basis.
OAR 340-22-170 (4)
2.8 Ib/gal coating
excluding water.
Not defined in detail
The VOC content limit
for coatings is
consistent with EPA
requirements.
The State rule does
not define the specifics
of equivalent emission
reduction calculation
methods.
4.0 AVERAGING TIME
Not defined
5.0 EXEMPTIONS
The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas
fired after burners
under certain circum-
stances, if provided
for in the SIP.
OAR 340-22-170 (1)
Daily
OAR 340-22-170 (2)
Any source emitting <40
tons/year.
The State rules
include an exemption
for small emission
sources less than 40
tons/year.
R 226
97
7/01/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Condensate means
hydrocarbon liquid
separated from natural
gas which condenses
due to changes in the
temperature and/or
pressure and remains
liquid at standard
conditions.
b) Crude oil means a
naturally occurring
mixture which consists
of hydrocarbons and/or
sulfur, nitrogen and/
or oxygen derivatives
of hydrocarbons and
which is a liquid at
standard conditions.
c) Custody transfer means
the transfer of pro-
duced crude oil and/or
condensate, after
processing and/or
treating the producing
operations, from stor-
age tanks or automatic
transfer facilities to
piplines or any other
forms of transporta-
tion.
d) External floating roof
means a storage vessel
cover in an open top
tank consisting of a
double deck or pontoon
single deck which
rests upon and is
supported by the
petroleum liquid being
R 226
OAR 340-22-102
a) Not defined
Some key definitions
not defined in OAR
340-22-O02 to 220).
b)
Not defined
c) Not defined
d)
Not defined
98
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
e) Internal floating roof
means a cover or roof
in a fixed roof tank
which rests upon or is
floated upon the
petroleum liquid being
contained, and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
f) Petroleum liquids
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery.
g) Petroleum refinery
means any facility
engaged in producing
ga soline, kerosens,
distillate fuel oils,
residual fuel oils,
lubricants, or other
products through dis-
tillation of crude
oil, or through re-
distillation cracking,
extraction, or reform-
ing of unfinished
petroleum derivatives.
R 226
e) Not defined
f)
Not defined
g)
"Petroleum refinery"
means any facility en-
gaged in producing
gasoline, aromatics,
kerosene, distillate
fuel oils, residual
fuel oils, lubricants,
asphalt, or other
products through
distillation of petro-
leum, crude oil, or
through redistilla-
tion, cracking, or re-
forming of unfinished
99
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOCs PROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
h) True vapor pressure
means the equilibrium
partial pressure
exerted by a petroleum
liquid as determined
in accordance with
methods described in
American Petroleum
Institute Bulletin
2517, "Evaporation
Loss from Floating
Roof Tanks," 1962.
2.0 APPLICABILITY
Applies to storage
vessels with a capac-
ity greater than
150,000 liters con-
taining petroleum
liquids whose true
vapor pressure is
greater than 10.5 kPa.
(1.5 PSI)
2.1 COMPLIANCE SCHEDULES
Not specified but
required by EPA policy.
h)
petroleum derivatives.
It does not mean a re-
refinery of used motor
oils or other waste
chemicals. It does
not include asphalt
blowing or separation
of products shipped
together.
"True vapor pressure"
means the equilibrium
pressure exerted by a
petroleum liquid as
determined in accor-
dance with methods
described in American
Petroleum Institute
Bulletin 2517,
"Evaporation Loss from
Floating Roof Tanks,"
February 1980.
OAR 340-22-160 (1)
All storage tanks contain-
ing VOCs with a true vapor
pressure >10.5 kPa but
<76.7 kPa and capacity
>39,000 gals.
OAR 340-22-160 (1)
April 1, 1981
There is a discrepancy
in the upper vapor
pressure limitations.
R 226
100
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
Fixed-roof tanks with
an internal floating
roof shall be visually
inspected as described
below.
2.3 RECORDKEEPING
Routine inspections
are to be conducted at
6 month, or shorter,
intervals. Evidence
of malfunction is to
be recorded. Addi-
tionally, whenever the
tank is emptied, the
condition of the cover
and seal is to be
recorded. A record of
the average monthly
storage temperature
and true vapor
pressure of the stored
liquid.
OAR 340-22-160 (4)
Routine inspections
annually and yearly report
are a minimum. The Depart-
ment reserves the right,
upon written notice, to
require more frequent
reports or modify the
monitoring and record-
keeping requirements, when
necessary to accomplish the
purposes of this rule.
OAR 340-22-160 (4)
Annual report of routine
yearly inspection is the
required minimum.
The State rule does
not require inspec-
tions as frequently as
the CTG.
R 226
101
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOCs FROM STORAGE OF
PETROLEUM LIQUIDS IN FIXED ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
Fixed roof tanks
(>150,000 liters)
shall be retrofitted
as follows:
1) a) Internal floating
roof
b) Alternative equiv-
alent control
2) No visible defects
3) All openings should be
covered.
4.0 AVERAGING TIME
The true vapor pres-
sure of petroleum
liquids shall be based
on an average monthly
storage temperature.
5.0 EXEMPTIONS
Fixed roof tanks hav-
ing capacities less
than 1,600,000 liters
used to store crude
oil and condensate
prior to lease custody
transfer are exempt.
OAR 340-22-160 (1)
Equipment specifications
are used from 40 CFR 60,
Subpart K and Ka.
Not specified
State rule should
discuss averaging
time.
OAR 340-22-160 (2)
Tanks containing a VOC with
a vapor pressure <4 psia
(27.6 kPa) of a welded
construction and presently
possessing a metallic-type
shoe seal, a liquid-mounted
foam seal, a liquid-filled
type seal, or of a welded
construction equipped with
a metallic-type shoe,
primary seal, and possess-
ing a secondary seal from
the top of the shoe seal to
the tank wall.
R 226
102
7/01/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: TANK TRUCK GASOLINE LOADING TERMINALS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
a) Tank Truck Gasoline
Terminal. A primary
distribution point for
delivering gasoline to
bulk plants, service
stations, and other
distribution points,
where the total gaso-
line throughput is
greater than 76,000
liters/day.
OAR 340-22-102
"Bulk Gasoline Terminal"
means a gasoline storage
facility which receives
gasoline from refineries
primarily by pipeline,
ship, or barge, and
delivers gasoline to bulk
gasoline plants or to
commercial or retail
accounts primarily by tank
truck.
CTG definitions found
in Appendix A of the
CTG.
Some key definitions
are not defined in
OAR 340-22-(102 to
220)
b) Loading Rack. An
aggregation of combi-
nation of gasoline
loading equipment
arranged so that all
loading outlets in the
combination can be
connected to a tank
truck or trailer park-
ed in a specified
loading space.
c) Continuous Vapor
Processing Device. A
hydrocarbon vapor con-
trol system that
treats vapors from
tank trucks or
trailers on a demand
basis without inter-
mediate accumulation.
d) Intermittent Vaoor
Processing Device. A
hydrocarbon vapor
control system that
employs an inter-
mediate vapor holder
to accumulate re-
covered vapors from
tank trucks or trail-
R 226ers*
Other terms with definitions
in State•rule:
- "Bulk Gasoline Plant"
- "Delivery Vessel"
- "Gasoline"
- "Gasoline Dispensing
Facility"
- "Splash Filling"
_ "Submerged Fill"
103
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
nnit treats the
accumulated vapors
only during automatic-
ally controlled
cycles.
2.0 APPLICABILITY
Applies to tank truck
terminals with daily
throughputs greater
than 76,000 liters
(20,000 gallons) of
gasoline.
2.1 COMPLIANCE SCHEDULE
RACT Application
2.2 TEST METHOD
REQUIREMENTS
Hydrocarbon mass
emission rates are
determined using flow
meters and hydrocarbon
analyzers. Combusti-
ble gas detectors or
EIP or NDIR type
hydrocarbon analyzers
may be used depending
on the sample point
and type of vapor
recovery system used.
OAR 340-22-130 (1)
Gasoline terminals with
daily throughputs of
>76,000 liters (20,000
gallons)/day of gasoline.
The daily throughput is the
annual throughput divided
by 365 days.
OAR 340-22-130 (2)
After April 1, 1981,
compliance shall be deter-
mined by testing in accor-
dance with Method 33 on
file at the Department.
OAR 340-22-130 (2)
Compliance test according
to test method 33 on file
with the Department.
Delivery vessels shall be
tested annually according
to the test method 32 on
file with the Department,
or with EPA Method 21.
The State rule is
consistent with EPA
requirements.
No specific date for
RACT
The test methods
should be equivalent
and, if so, defined
similarly. Methods 32
and 33 yet to be
approved by EPA. EPA
should review Department
test methods.
R 226
104
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.3 RECORDKEEPING
Portable Analyzers may
be used to monitor for
leaks. Recordkeeping
requirements are not
identified in the CTG
but should be consis-
tent with time frames
for compliance.
3.0 EMISSION STANDARDS
RACT for loading
terminals is 80 milli-
grams of hydrocarbon
emissions per liter of
gasoline loaded.
Vapor control is re-
quired to control
emissions for top-
splash facilities.
Other facilities may
be equipped with top-
submerged or bottom-
fill.
R 226
OAR 340-22-130 (3)
OAR 340-22-137 (4)
If more than 5 gallons
spilled, operator must
report spillage in accor-
dance with 340-21-065 to
-075. Records of tests
and repairs must be main-
tained for at least two years
after the date of testing or
repair was completed.
OAR 340-22-130 (3)
All displaced vapors and
gases during loading
operations are vented only
to the vapor control
system.
Loading device must not
leak when in use and be
designed/operated to allow
<10 cm drainage per
disconnect on the basis of
5 consecutive disconnects.
All loading liquid lines
shall be equipped with
fittings which make vapor-
tight connections and close
automatically and immedi-
ately when disconnected.
All vapor lines shall be
equipped with fittings
which make vapor-tight con-
nections and which close
automatically and immedi-
ately when disconnected or
which contain vapor-tight
unidirectional valves.
105
No defined policy on
recordkeeping in CTG.
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
TANK TRUCK GASOLINE LOADING TERMINALS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
4.0 AVERAGING TIME
Testing at loading
terminals should be
based on a complete
loading cycle to
determine mass emis-
sion rates per volume
of gasoline trans-
ferred. Testing shall
be at least three
8-hour test repeti-
tions.
OAR 340-22-130
OAR 340-22-137
Not specified
explicitly.
The State rule mentions
a few test methods so
averaging times may be
included implicitly.
5.0 EXEMPTIONS
Terminals with daily
throughputs less than
76,000 liters (20,000
gallons).
OAR 340-22-130 (1),(3)
When gas delivery vessels
are switched to diesel
delivery service or to
delivery of other VOC with
a Reid vapor pressure <27.6
kPa (4 psia).
Terminals with daily
throughputs of less than
76,000 liters of gasoline.
R 226
106
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: BULK GASOLINE PLANTS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
There are no defini-
tions specified in the
CTG.
2.0 APPLICABILITY
Applicable to the
control of VOC
emissions from bulk
plants with daily
throughputs of 76,000
liters of gasoline or
less.
OAR 340-22-102
"Bulk Gasoline Plant" means
a gasoline storage and dis-
tribution facility which
receives gasoline from bulk
terminals by railroad car
or trailer transport,
stores it in tanks, and
subsequently dispenses it
via account trucks to local
farms, businesses, and ser-
vice stations.
Other definitions:
- "Bulk Gasoline Terminal"
- "Delivery Vessel"
- "Gasoline"
- "Gasoline Dispensing
Facility"
- "splash Filling"
- "Submerged Fill"
OAR 340-22-120 (5)
The State rules apply to
bulk plants which load more
than 600,000 gallons of
gasoline per year.
The CTG includes des-
criptions but not
definitions.
State rule has a small
source cutoff not in
the CTG.
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA policy.
OAR 340-22-120 (2)
Compliance is required by
April 1, 1981. With added
equipment required by rule
changes adopted in 1980,
compliance is delayed until
April 1, 1983.
R 226
107
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: BULK GASOLINE PLANTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
Compliance for bottom
fill or top-submerged
fill requires only
visual inspection to
ensure minimal spil-
lage of gasoline and
proper installation of
loading arm or bottom
loading couples.
Other compliance and
monitoring procedures
to be published at a
later date.
2.3 RECORDKEEPING/
MONITORING
Monitoring by visual
inspection of equip-
ment is required. The
CTG does not require
records of inspec-
tions.
3.0 EMISSION STANDARDS
EPA lists three levels
of control:
I » Submerged filling
of account trucks
II » I + Vapor balance
for gasoline delivery
to the storage tank.
Ill - II + vapor
balance for gasoline
delivery to account
trucks.
OAR 340-22-120 (3)
Method 31 and/or 32 on file
with the Department.
OAR 340-22-120 (3)
Report spillage. All other
monitoring done in accor-
dance with applicable por-
tions of rule OAR 340-22-
137
OAR 340-22-120 (1),(3)
Determined by approved use
of equipment.
Each stationary gasoline
storage tank may release
vapor to the atmosphere
through a pressure relief
valve set to release at no
less than 3.4 kPa or some
other setting approved in
writing by the Department.
The State specifies
particular test
methods yet to be
approved.
The State rule is more
detailed in this area.
The CTG recommends
that pressure relief
valves be set as high
as possible.
R 226
108
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: BULK GASOLINE PLANTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
5.0 EXEMPTIONS
The CTG does not apply
to bulk plants with
daily throughputs of
more than 76,000
liters of gasoline.
OAR 340-22-120
In the Portland area AQMA:
if a bulk gasoline plant
transfers <4,000
gallons/day, or if each
dispensing facility to
which the plant delivers
receives <10,000 gallons/
month, then the capture of
displaced vapors during the
filling of delivery vessels
is not required. Similar-
ly, a bulk gasoline plant
located in the Medford-
Ashland AQMA or in the
Salem SATS is exempted from
the vapor balance system
requirement. The State
rule does not apply to bulk
plants which load 600,000
gallons of gasoline per
year or less.
The State rules pro-
vide specific exemp-
tions , not included
in the CTG, for small
plants.
R 226
109
7/01/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM METAL CLEANING
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None listed in the CTG
for solvent metal
cleaning.
2.0 APPLICABILITY
Applies to equipment
used for solvent metal
cleaning including
cold cleaners, open
top vapor degreasers,
and conveyorized
degreasers employing
organic solvents to
remove soluble impuri-
ties from metal stir-
faces.
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
a) Add-on control equip-
ment efficiencies
shall be determined
using EPA Method 23:
"Determination of
Total Non-methane
Hydrocarbons as
Perchloroethylene from
Stationary Sources."
b) Vinyl chloride monomer
(VCM) shall be deter-
mined by EPA Method
106: "Determination of
Vinyl Chloride from
Stationary Sources."
R 226
OAR 340-22-102
•'Freeboard Ratio" means the
freeboard height divided by
the width (not length) of
the degreaser's air/solvent
area.
OAR 340-22-(180,183,186)
1) cold cleaners
2) open top vapor de-
greasers
3) conveyorized de-
greasers
Few, if any,
definitions in this
area within CTG or
State rule.
OAR 340-22-(180,183,186)
April 1, 1980
OAR 340-22-(183,186)
A routine inspection
program shall be implement-
ed for open top vapor and
conveyorized degreasers.
OAR should be explicit
in test method re-
quirements to ensure
effectiveness.
110
7/05/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: CONTROL OF VOC EMISSIONS FROM METAL CLEANING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
c) EPA Methods 1 and 2.
shall be used for
velocity and flow
measurements.
3.0 EMISSION (OR EQUIPMENT) OAR 340-22-(180,183,186)
STANDARDS
Equipment standards for State rules list equipment
open top vapor degreasers, standards that are generally
conveyorized degreasers, consistent with CTG.
and cold cleaners are
stated in CTG.
OAR does not specify a
disposal evaporation
limitation.
5.0 EXEMPTIONS
The EPA policy memo-
randa dated July 28,
1976 allows the
seasonal use of gas-
fired after-burners
under certain circum-
stances if provided
for in the SIP.
OAR 340-22-180
Any degreaser is exempt
from the rules if it uses a
fluid which is not photo-
chemically reactive. These
fluids are:
The State rule pro-
vides exemptions for
degreasers in certain
circumstances.
C^ Cl P ; a
'2 *3 ^V
Cl,; 1,1,
R 226
111
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: MISCELLANEOUS REFINERY SOURCES
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None listed
2.0 APPLICABILITY
Industries emitting
significant amounts of
VOC where NAAQS are
not being attained.
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA policy,
OAR 340-22-102
"Leaking component" means
any petroleum refinery
source which has a volatile
organic compound concentra-
tion exceeding 10,000 ppm
when tested in the manner
described in methods 31 and
33 on file with the Depart-
ment. These sources
include, but are not limi-
ted to, pumping seals, com-
pressor seals, seal oil
degassing vents, pipeline
valves, flanges and other
connections, pressure
relief devices, process
drains, and open-ended
pipes. Excluded from these
sources are valves which
are not externally regula-
ted.
OAR 340-22-150 (1),{2},(3)
All petroleum refineries:
a) vacuum producing
systems
b) wastewater separators
c) process unit
turnaround
OAR 340-22-150
After April 1, 1979
The State rules have a
few pertinent defini-
tions listed. Because
this category encom-
passes diverse
sources, more defini-
tions would be
helpful.
R 226
112
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: MISCELLANEOUS REFINERY SOURCES
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
RACT emission factors.
a)
b)
steam ejectors with
contact condensers,
steam ejectors with
surface condensers,
mechanical vacuum
pumps.
30 Kg/1000m by cover-
ing the forebay and
separator
OAR 340-22-150 (1),(2),(3)
Equipment specifications
for:
a) non-condensable VOCs
shall be piped to an
appropriate firebox,
incinerator or to a
closed refinery
system; hot wells
associated with
contact condensers
shall be tightly
covered and the
collected VOCs sent to
a closed refinery
system.
b) Forebays shall incor-
porate a floating
pontoon or fixed solid
cover with all open-
ings sealed, or a
floating pontoon or
double deck-type cover
equipped with closure
with suitable covers
when not in use.
c) 15 Kg/1000m by de-
pressurizing to flare
R 226
113
7/05/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: CUTBACK ASPHALT
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None cited in the CTG.
2.0 APPLICABILITY
Applies to the emis-
sion of VOCs from the
use of paving asphalts
liquified with petro-
leum distillate.
2.1 COMPLIANCE SCHEDULE
Compliance schedules
should be established
in the rules in accor-
dance with EPA policy.
2.2 TEST METHOD
REQUIREMENTS
The CTG does not
specify testing
methods for cutback
asphalt.
OAR 340-22-102
"Cutback Asphalt" means a
mixture of a base asphalt
with a solvent such as gas-
oline, naphtha, or kero-
sene. Cutback asphalts are
rapid, medium, or slow
curing (known as RC, MC,
SO , as defined in ASTM
D2399.
OAR 340-22-140
1) Use of any cutback
asphalts for paving
roads and parking
areas
2)
3)
4)
slow or medium curing
cutback asphalts
rapid curing grades of
cutback asphalt
emulsified asphalts
OAR 340-22-140
After April 1, 1979
OAR 340-22-140 (4)
Grades of emulsion per
AASHTO designation M
208-72; Maximum solvent
content by weight is
determined by ASTM
distillation test D-244.
Few, if any, definitions
in the CTG or State rules
The State rule is more
specific in this area.
R 226
114
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CUTBACK ASPHALT
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSIONS STANDARDS
VOC emissions from
cutback asphalt shall
be controlled by sub-
stitution of emulsions
during warm weather.
OAR 340-22-140 (1),(2),(4)
The use of cutback asphalts
is prohibited for paving
roads and parking areas
during the months April
through October (with
exceptions for cool
weather, patching mixes,
and penetrating prime coats
for aggregate bases prior
to paving). Use of emulsi-
fied asphalts is
unrestricted if solvent
content kept below listed
values:
OAR - good interpreta-
tion of CTG and formu-
lation of rule.
CTG states possibility
for 100% conversion of
cutback to emulsified
asphalts.
5.0 EXEMPTIONS
There are no exemp-
tions identified in
the CTG.
CRS-1
CRS-2
CSS-1
CSS-1h
CMS- 2
CMS-2h
CMS-2S
- 3%
- 3%
- 3%
- 3%
- 8%
- 8%
- 12%
OAR 340-22-140 (2)
For slow or medium curing
cutback asphalt:
a) When used solely as a
penetrating prime coat
for aggregate bases
prior to paving;
The CTG does not spec-
ifically provide for
the exemptions cited,
but these exemptions
are not expected to
significantly impact
oxidant levels.
R 226
115
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: CUTBACK ASPHALT
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
b) For the manufacture of
medium-curing patching
mixes to provide long-
period storage stock-
piles used exclusively
for pavement mainte-
nance;
c) When the National
Weather Service
forecast of the high
temperature during the
24 hour period
following application
is below SOT.
R 226
116
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: VOC LEAKS FROM PETROLEUM REFINERY EQUIPMENT
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
The CTG does not
recommend that the
states define words or
phrases related to
petroleum refinery
equipment. However,
Zero Drift,
Calibration Error,
Calibration Drift, and
Response Time are
defined for instrument
performance.
2.0 APPLICABILITY
Applies to VOC leaks
from equipment in
petroleum refineries
including pump seals,
compressor seals and
oil degassing vents,
pipeline valves,
flanges and other
connections, pressure
relief devices,
process drains, and
open-ended pipes. A
component is deter-
mined to be leaking if
a VOC concentration
over 10,000 ppm is
detected.
2.1 COMPLIANCE SCHEDULE
Compliance schedules
should be established
in accordance with EPA
policy.
OAR 340-22-102
Some related definitions
previously defined in this
report:
- "Leaking Component"
- "Petroleum Refinery"
(See "Miscellaneous
Refinery Sources" and
"Storage of Petroleum
Liquids in Fixed Roof
Tanks" for above defi-
nitions) .
OAR 340-22-153
Applies to leaking compo-
nents detected in a petro-
leum refinery complex.
Petroleum refineries should
monitor for leaks which
produce a VOC concentration
exceeding 10,000 ppm.
Few definitions in the CTi
or State rules.
OAR 340-22-153
October 1, 1980
R 226
117
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
VOC LEAKS FROM PETROLEUM REFINERY EQUIPMENT
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
VOC leaks may be
detected by any
instrument designed to
respond to total
hydrocarbons or
combustible gases.
a) Pump seals, valves,
and drains shall be
monitored annually,
with a portable VOC
device.
b) Compressor seals,
valves in gas service,
and pressure relief
valves shall be
monitored quarterly
with a portable VOC
device.
OAR 340-22-153 (2)
Testing and calibration
procedures shall be done in
accordance with EPA Method
21.
This rule is primarily
taken from the CTG.
c) Pump seals shall be
visually monitored
weekly.
2.3 RECORDKEEPING
The owner/operator
shall maintain records
in accordance with
compliance time frames
specified in the rule.
R 226
OAR 340-22-153 (3)
The Department may, upon
written notice, modify the
monitoring, recordkeeping,
and reporting requirements.
The State rules are de-
tailed in this section.
Yearly monitoring is re-
quired for all pump seals,
pipeline valves in liquid
service, and process
drains. Quarterly moni-
toring is required for all
compressor seals, and pipe-
line valves and pressure
118
The monitoring,
repair, and record-
keeping programs in
the State rule are
consistent with the
CTG.
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
VOC LEAKS FROM PETROLEUM REFINERY EQUIPMENT
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
Sources with VOC
concentrations which
exceed 10,000 ppm
shall be identified
for repairs.
4.0 AVERAGING TIME
VOC concentrations at
the source of equip-
ment leaks are instan-
taneous readings.
5.0 EXEMPTIONS
None specified in the
CTG.
relief valves in gaseous
service. Weekly monitoring
by visual methods is re-
quired for all pump seals.
Special considerations are
stated for repair and ob-
servation of leaks and
drips. A report to the
Department is required four
times a year. Copies of
all records and reports
should be maintained for a
minimum of two years.
OAR 340-22-153 (1)
Sources with VOC concentra-
tions which exceed 10,000
ppm shall be identified and
repaired.
OAR 340-22-153
Instantaneous
measurement
OAR 340-22-153 (4)
Does not apply to compo-
nents handling liquids with
a true vapor pressure <10..5
kPa.
The CTG does not
exempt liquids with a
low vapor pressure.
R 226
119
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS METAL PARTS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS.
a)
b)
O
d)
e)
Single coat means only
one film of coating is
applied to the metal
substrate.
Prime coat means the
first of two or more
films of coating
applied in an
operation.
Topcoat means the
final film or series
of films of coating
applied in a two-coat
(or more) operation.
Faraday caging means a
repelling force gener-
ated in corners and
small enclosed areas
of the metal substrate
during electrostatic
Spraying of powders.
Blocking agent means
an organic agent which
blocks or inhibits
certain cross-linking
or polymerization
reactions. It is
designed to separate
from the monomer at
some elevated tempera-
ture thereby allowing
the reactions to
proceed.
OAR 340-22-102
See "Autos and Lt. Duty
Trucks" in Table 4 for
definitions listed in State
rules that correspond to
definitions in the CTG
general surface coating
category.
Some key definitions
are not included in
the State rule.
R 226
120
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF MISCELLANEOUS METAL PARTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
f) Low organic solvent
coating (LOSC) refers
to coatings which
contain less organic
solvent than the
conventional coatings
used by the industry-
Low organic solvent
coatings include
wa ter-bome, higher
solids, electro-
deposition, and powder
coatings.
g) Heat sensitive mate-
rial means materials
which cannot be ex-
posed to temperatures
greater than 80* to
95«C (180° to 200-F).
h) Transfer efficiency
means the portion of
coating which is not
lost or wasted during
the application
process expressed as
percent.
2.0 APPLICABILITY OAR 340-22-170 (2),(3)
Applies to the surface Coating lines with VOC Sources under 40
coating of miscellane- emissions >40 tons/year. tons/year are exempt.
ous metal parts and
products from job Applies to each coating
shops and original line:
equipment manufac-
turing industries, Application and flashoff
areas, air and forced air
driers, and ovens.
236
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
SURFACE COATING OF MISCELLANEOUS METAL PARTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
which apply metal
coatings on metal
substrates not covered
by other CTGs. This
includes:
1) Large farm machinery
2} Small farm machinery
3) Small appliances
4) Commercial machinery
5) Industrial machinery
6} Fabricated metal parts
7) Industrial Categories
in SIC Code Major
Group 33 through 41.
2.1 COMPLIANCE SCHEDULE
Not specified but re-
quired by EPA policy.
2.2 TEST METHOD
REQUIREMENTS
EPA Reference Method
24 shall be used to
determine the VOC
content of coatings.
OAR 340-22-170 (1)
December 31, 1982
OAR 340-22-170 (5)
Testing in accordance with
Method 24, 25, a material
balance method, or an
equivalent plant specific
method approved by and on
file with the Department.
R 226
122
OAR refers to EPA Memo
dated May 5, 1980:
"Procedures to Calcu-
late Equivalency with
the CTG Recommenda-
tions for Surface
Coating."
The State rule should
specifically refer to
EPA test methods if this
is, in fact, the inten-
tion, otherwise, approval
of state test methods is
pending.
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
SURFACE COATING OF MISCELLANEOUS METAL PARTS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EMISSION STANDARDS
a) Low Solvent Coatings-
Limit ranges from 0.4
to 4.4 Ibs/gal.
depending on the coat-
ing. Powder Coatings
are limited to 0.4
Ib/gal.
3.1 CALCULATION METHODS
Equivalent overall
add-on control equip-
ment reduction effi-
ciences are calcula-
ted from VOC reduc-
tions on an equiva-
lent solids basis.
OAR 340-22-170 (4)
"Other Coatings" (i.e.,
powder, oven dried)— 3.0
Ibs/gal.
The State rule does not
outline specific cal-
culation procedures.
OAR should not put
powders in category
with "Others" because
emission limit set
forth by CTG is great-
ly exceeded (i.e., CTG
•0.4 Ibs/gal compared
to OAR - 3.0 Ibs/gal).
Should be better
agreement between
classification used by
CTG and State rule.
The state rule should
be more detailed.
3.2 CAPTURE EFFICIENCY
Equivalent emission
reductions for add-
on controls shall be
determined on an
equivalent solids
basis. The overall
reduction efficiency
shall be used for the
add-on control equip-
ment efficiency in-
cluding the perfor-
mance of the capture
system.
5.0 EXEMPTIONS
None listed
R 226
Not specifically
declared
OAR 340-22-170 (2)
Sources with emissions <40
tons/year.
123
The State rule does
not discuss capture
efficiency although it
does discuss reduction
methods.
The State rule
provides specific
exemption.
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OP PLATWOOD PANELING
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Printed panels means
panels whose grain or
natural surface is
obscured by fillers
and basecoats upon
which a simulated
grain or decorative
pattern is printed.
Hardwood plywood is
plywood whose surface
layer is a veneer of
hardwood.
Particleboard is a
manufactured board
made of individual
wood particles which
have been coated with
a binder and formed
into flat sheets by
pressure. Thin
particleboard has a
thickness of one-
fourth inch or less.
Natural finish hard-
wood plywood panels
means panels whose
original grain pattern
is enhanced by essen-
tially transparent
finishes frequently
supplemented by
fillers and toners.
OAR 340-22-102
Most definitions taken
directly from glossary of
CTG.
Most definitions are
the same.
"Lauan" not defined in
OAR.
"Particleboard" not
defined in OAR
340-22-CIOO to 220).
Apparently defined
elsewhere in OAR
(340-25-305).
R 226
124
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
Hardboard is a panel
manufactured primarily
from inter-felted
ligno-cellulosic
fibers which are
consolidated under
heat and pressure in a
hot-press.
Class II hardboard
paneling finishes
means finishes which
meet the specifica-
tions of Voluntary
Product Standard
PS-59-73 as approved
by the American
National Standards
Institute.
Lauan is an imported
tropical hardwood.
2.0 APPLICABILITY
Applies to flatwood
panel manufacturers
including:
a) Printed interior wall
panels made of
hardwood plywood and
thin particleboard.
b) Natural finish hard-
wood plywood panels,
c) Class II finishes for
hardboard paneling.
2.1 COMPLIANCE SCHEDULES
Not specified but
required by EPA policy.
R 226
OAR 340-22-200 (1)
Same as in CTG.
OAR 340-22-200 (3)
December 31, 1982
125
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
The CTG specifies
three test methods:
ASTM D 1475-60, ASTM D
1644-59, and ASTM D
2369-73.
EPA Method 24 is based
upon updated versions
of these methods.
3.0 EMISSION STANDARDS
a) Printed interior
panels -26.0 Ib VOC/
1,000 ft product
b) Natural finish
hardwood - 12,.0 Ib
VOC/1,000 ft product
c) Class II finishes -
hardboard - 10.0 Ib
VOC/1,000 ft product
3.1 CALCULATION METHODS
The Jb of VOC per 1000
ft. of product
finished is calculated
from the Ib VOC per'
gallon coating and the
coating spread rate in
ft. per gallon.
OAR 340-22-200 (8)
The rule requires that test
methods be consistent with
EPA document 450/2-78-041
and App A of EPA document
450/C 2')-77-008 (which
references ASTM test methods)
The latter is the CTG for
surface coating of cans,
coils, paper, fabrics,
automobiles, and light-duty
trucks.
OAR 340-22-200 (3)
Same standards
Equivalent means of VOC
removal must be approved by
the Department. The
Department may accept this
instead of coating
analysis. A certification
by the coating manufacturer
of the composition of the
coating, if supported by
actual batch formulation
records, may also be used.
•2' is left out of
rule «-. probably typo-
graphical error.
The test methods
listed in the CTG are
in Appendix A of the
EPA document refer-
enced within the State
rule.
OAR contains a stipu-
lation that emission
standards must be met
"regardless of the
number of coats
applied."
R 226
126
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: SURFACE COATING OF FLATWOOD PANELING
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
The CTG suggests that
an alternate procedure
to determine.,the Ib
VOC per ft. of
product is to esti-
mate the quantity of
VOCs used and the
quantity of product
finished during a
specified time period.
Current EPA policy
would limit this time
period to 24 hours.
5.0 EXEMPTIONS
Exterior siding, tile
board, and particle-
board used as furni-
ture components.
Calculation methods are not
defined in the State's
rules for equivalent VOC
reductions.
Long term averaging
periods used for
compliance may reduce
the effectiveness of
the State rule.
OAR 340-22-200 (2)
Exterior siding, tileboard,
particleboard used as
furniture components, or
paper or plastic laminates
on wood or wood-derived
substrates are exempt from
regulation.
R 226
127
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: GRAPHIC ARTS-ROTOGRAVURE AND FLEXOGRAPHY
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
None listed
OAR 340-22-102
"Flexographic Printing"
means the application of
words, designs, and pic-
tures to a substrate by
means of a roll printing
technique in which the
pattern to be applied is
raised above the printing
roll and the image carrier
is made of rubber or other
elastomeric materials.
"Packaging Rotogravure
Printing" means rotogravure
printing upon paper, paper
board, metal foil, plastic
film, and other substrates,
which are, in subsequent
operations, formed into
packaging products and
labels for articles to be
sold.
"Printing" means the
formation of words,
designs, and pictures
usually by a series of
application rolls each with
only partial coverage.
"Publication Rotogravure
Printing" means rotogravure
printing upon paper which
is subsequently formed into
books, magazines, cata-
logues, brochures, direc-
tories, newspaper supple-
ments, and other types of
printed materials.
R 226
128
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: GRAPHIC ARTS-ROTOGRAVURE AND FLEXOGRAPHY
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.0 APPLICABILITY
The CTG covers both
flexographic and roto-
gravure processes as
applied to both publi-
cation and packaging
printing. It does not
apply to offset litho-
graphy or letterpress
printing.
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA policy.
"Roll Printing" means the
application of words,
designs, and pictures to a
substrate by means of hard
rubber or steel rolls.
"Specialty Printing" means
all gravure and flexogra-
phic operations which print
a design or image, exclud-
ing publication gravure and
packaging printing.
Specialty Printing includes
printing on paper plates
and cups, patterned gift
wrap, wallpaper, and floor
coverings.
OAR 340-22-210 (1)
Packaging rotogravure,
publication rotogravure,
flexographic, or specialty
printing facilities that
emit > 90 Mg/year (100
tons/year) and employ ink
containing solvent.
OAR 340-22-210 (1)
July 1, 1982
The 100 tons/year
exemption is not
identified in the CTG,
R 226
129
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY:
GRAPHIC ARTS-ROTOGRAVURE AND FLEXOGRAPHY
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
None specified in the
CTG.
3.0 EMISSION STANDARD
a) Add-on Controls
(Rotogravure)
1) Carbon Adsorption
- 90%
2) Incineration - 90%
3) Capture Efficiency
- 75-85%
4) Overall Efficiency
- 65%
b) Flexography
1) Overall Efficiency
- 60%
2) Capture Efficiency
- 70%
For Coating Operation
Limits see the section
for cans, coils,
paper, fabrics, and
automobiles and It.
duty trucks.
OAR 340-22-210 (3)
Must notify Department at
least 30 days in advance so
they can observe test.
Test must be approved by
Department and be
consistent with EPA
document EPA-450/2-78-041
and Appendix A of EPA
document EPA-450/2-77-008.
OAR 340-22-210 (3)
The Department may accept a
certification by the ink
manufacturer of the compo-
sition of the ink, if
supported by actual batch
formulation records,
instead of an ink-solvent
analysis.
OAR references
documents published by
the EPA for
test/measurement
methods.
All other emission
standards in the OAR
are taken directly
from the CTG.
R 226
130
7/05/88-CAT
-------
CTG SOURCE CATEGORY:
TABLE 4
GRAPHIC ARTS-ROTOGRAVURE AND FLEXOGRAPHY
(Continued)
U.S. SPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.2 CAPTURE EFFICIENCY
a) Rotogravure 75-85%
b) Flexography 70%
Overall efficiency speci-
fied instead of capture
efficiency.
The State rule should
state efficiencies in
terms defined by CTG.
5.0 EXEMPTIONS
None specified
OAR 340-22-210 (1)
Printing facilities that
emit < 90 Mg/year (100
tons/year).
No exemptions in the
CTG for small emission
sources.
R 226
131
7/05/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
U.S. EPA Control
Technology Guide-
line Requirement State Rule Comments
1.0
a)
DEFINITIONS
Condensate means
OAR 340-22-102
OAR 340-22-160 (1)
Some definitions in
hydrocarbon liquid The OAR references 40 CFR the CTG are not
separated from natural 60 Subparts K and Ka defined in the OAR.
gas which condenses wherein the definitions of
due to changes in the many of these terms are
temperature and/or located. The definitions
pressure and remains are not explicitly stated
liquid at standard in the OAR.
conditions.
b) Cost Effectiveness -
Cost (or credit) per
megagram of controlled
emissions. Given in
general by: (recovered
petroleum liquid value
- net annual control
system cost) / (mega-
grams of controlled
emissions) - cost (or
credit/Mg, controlled
emissions).
c) Crude oil means a
naturally occurring
mixture consisting of
hydrocarbons and/or
sulfur, nitrogen
and/or oxygen
derivatives of hydro-
carbons and which is a
liquid in the reser-
voir and at standard
conditions.
d) Custody transfer means
the transfer of pro-
duced crude oil and/or
condensate, after
processing and/or
treating in the
producing operations,
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
from storage tanks or
automatic transfer
facilities to pipe-
lines or any other
forms of transporta-
tion.
e) External floating roof
means a storage vessel
cover in an open top
tank consisting of a
double deck or pontoon
single deck which
rests upon and is
supported by the
petroleum liquid being
contained and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
f) Internal floating roof
means a cover or roof
in a fixed roof tank
which rests upon or is
floated upon the
petroleum liquid being
contained, and is
equipped with a
closure seal or seals
to close the space
between the roof edge
and tank shell.
g) Liquid-mounted means a
primary seal mounted
so the bottom of the
seal covers the liquid
surface between the
tank shell and the
floating roof.
R 226
133
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
h) Vapor-mounted means a
primary seal mounted
so there is an annular
vapor space underneath
the seal. The annular
vapor space is bounded
by the bottom of the
primary seal, the tank
shell, the liquid
surface, and the
floating roof.
i) Petroleum liquids
means crude oil,
condensate, and any
finished or inter-
mediate products
manufactured or
extracted in a
petroleum refinery.
j) True vapor pressure
means the equilibrium
partial pressure
exerted by a petroleum
liquid as determined
in accordance with
methods described in
American Petroleum
Institute (API)
Bulletin 2517,
"Evaporation Loss from
Floating Roof Tanks,"
1962. The API proce-
dure may not be
applicable to some
high viscosity or high
pour crudes. Avail-
able estimates of true
vapor pressure may be
used in special cases
such as these.
j) "True vapor pressure"
means the equilibrium
pressure exerted by a
petroleum liquid as
determined in accor-
dance with methods
described in American
Petroleum Institute
Bulletin 2517,
"Evaporation Loss from
Floating Roof Tanks,"
February 1980.
R 226
134
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
k) Volatile Organic
Compounds (VOC) means
compounds which under
favorable conditions
may participate in
photochemical
reactions to form
oxidants. (See Table
1, Section 5).
2.0 APPLICABILITY
Applies to the control
of VOCs from the
storage of petroleum
liquids in external
floating roof tanks
larger than 150,000
liters with a true VP
greater than 1.5 psi.
These requirements do
not apply to fixed
roof tanks (with or
without internal
floating roofs) or to
small production
tanks.
2.1 COMPLIANCE SCHEDULE
None specified but
required by EPA policy.
k) VOC - Any compound of
carbon that is photo-
chemically reactive.
Excluded from the
category of VOCs are
CO, CO., carbonic
acid, metallic car-
bides or carbonates,
ammonium carbonate,
and those compounds
which the U.S. EPA
classifies as being of
negligible photochem-
ical reactivity which
are methane, ethane,
methyl chloroform,
methylene chloride,
and trichlorotri-
fluoroethane.
OAR 340-22-160 (1)
Owners or operators that
have tanks storing methanol
or other VOC liquids with a
true vapor pressure, as
stored, >10.5 kPa and <76.7
kPa and having a capacity
greater than 150,000 liters
(approx. 39,000 gallons).
OAR 340-22-160 (4)
December 31, 1981
OAR puts an upper
limit on true vapor
pressure of liquid.
R 226
135
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
Visual inspections
required as described
in 2.3.
OAR 340-22-160 (4)
Visual inspections required
as described in 2.3.
2.3 RECORDKEEPING
a) Annual visual inspec-
tions should be con-
ducted and secondary
seal gaps measured.
Evidence of any type
of malfunction should
be recorded.
b) A record of the aver-
age monthly storage
temperature, the type
of liquid, and the
Reid vapor pressure of
the liquid should be
maintained for no more
than 2 years when a
liquid having a true
vapor pressure greater
than 7.0 kPa (1.0 psi)
is stored in tanks
without a secondary
seal or approved
alternative control
technology.
OAR 340-22-160 (4)
a) Same as in CTG
b)
Same as in CTG
Copies of all records and
reports are to be made
available to the Department
upon verbal or written
request at any reasonable
time. Copies of all
records and reports shall
be retained by the owner or
operator for a minimum of
two years after the date on
which the record was made
or the report submitted.
R 226
136
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3.0 EQUIPMENT STANDARDS
Vessels must have:
- rim mounted second-
ary seal
- an equally effec-
tive seal closure
device
- no holes, tears, or
other openings
- intact and uniform-
ly placed seal
- gaps >1/8 in. accu-
mulate to <1.0 in /
ft of tank diameter
- openings covered
5.0 EXEMPTIONS
a) RACT for External
Floating Roof Tanks
(EFRT) is not required
for the following:
1) Welded EFRT equip-
ped with primary
seals if the TVP
is less than 27.6
kPa (4 psi).
2) A welded or
riveted EFRT with
primary seals and
a VP less than
10.5 kPa (1.5
psi).
OAR 340-22-160 (4)
Same as in CTG
OAR taken directly
from CTG.
OAR 340-22-160 (4)
Tanks which contain a VOC
liquid with a true vapor
pressure less than 27.6
kPa, are of welded con-
struction and presently has
a metallic type shoe seal,
a liquid-mounted foam seal,
a liquid-mounted liquid-
filled type seal, or other
closure device of demon-
strated equivalence
approved by the Department.
State rules are
consistent with the
CTG.
R 226
137
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PETROLEUM LIQUID STORAGE IN EXTERNAL FLOATING ROOF TANKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
3) A riveted EFRT
equipped with
primary metallic
shoe or liquid
mounted seals if
the TVP is less
than 10.5 kPa (1.5
psi).
b) EFRTs with capacities
less than 1,600,000
liters used to store
crude prior to lease
custody transfer.
c) EFRTs used to store
waxy heavy pour
crudes.
d) Welded tanks with a
shoe mounted secondary
seal.
Petroleum liquid storage
vessels which:
are used to store waxy,
heavy pour crude oil;
have capacities less
than 1,600,000 liters
(420,000 gal) and are
used to store pro-
duced crude oil and
condensate prior to
lease custody transfer;
contain a VOC liquid
with a true vapor
pressure of less than
10.5 kPa (1.5 psia)
where the vapor pres-
sure is measured at the
storage temperature;
are of welded construc-
tion, equipped with a
metallic-type shoe
primary seal and have a
secondary seal from the
top of the shoe seal to
the tank wall (shoe-
mounted secondary
seal).
R 226
138
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Affected facilities
should include the
washer, dryer, filter
and purification
systems, waste dis-
posal systems, holding
tanks, pumps, and
attendant piping and
valves.
2.0 APPLICABILITY
Applies to all dry
cleaning facilities
using perchloro-
ethylene except most
coin-operated
facilities (due to
size and steam capa-
city), facilities with
inadequate space for
an adsorber, or
facilities with insuf-
ficient steam capacity
available to desorb
adsorbers.
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA
policy.
OAR 340-22-102
"Dry cleaning facility"
means any facility engaged
in the cleaning of fabrics
in an essentially
nonaqueous solvent by means
of one or more washes in
solvent, extraction of
excess solvent by spinning,
and drying by tumbling in
an airstream. The facility
includes but is not limited
to any washer, dryer,
filter and purification
systems, waste disposal
systems, holding tanks,
pumps, and attendant piping
and valves.
OAR 340-22-220 (2)
Virtually the same applica-
bility as stated in CTG.
In addition, facilities
which consume greater than
320 gallons of perchloro-
ethylene per year.
The CTG has no set
limit for exemption
based upon size of
facility operation.
OAR 340-22-220 (1)
January 1, 1982
R 226
139
7/06/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: PERCHLOROETHYLENE DRY CLEANING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.2 TEST METHOD
REQUIREMENTS
Perchloroethylene
emissions from an
adsorber vent shall be
determined using an
integrated bag
sampling procedure
followed by gas
chroma tographic/flame
.ionization detector in
accordance with Draft
EPA Method 23. Liquid
leakage shall be
determined by visual
inspection.
3.0 EMISSION STANDARD
a) Organic solvent con-
centration from the
dryer control device
shall not exceed 100
ppm before dilution.
b) The filter residue
shall not contain over
25 kg VOCs/100 kg of
wet waste.
c) Filters must be
drained for 24 hours.
OAR 340-22-220 (3)
Visual inspection. Also,
test methods consistent
with procedures in
EPA-450/2-78-041 or
ANSI/ASTM D 322.
OAR should identify
method.
OAR 340-22-220 (1)
A per chloroe thylene dry
cleaning facility shall:
a) Emit no more than 100
ppmv of VOCs from the
dryer control device
before dilution;
b) Cook or treat all dia-
tomaceous earth
filters so that the
residue contains 25 kg
or less of VOCs/100 kg
of wet waste material;
c) Drain all filtration
cartridges, in the
filter housing, for at
least 24 hours before
discarding the
cartridges;
Most emission stan-
dards are identical
to CTG standards.
Equivalent systems
should be specified.
R 226
140
7/06/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: PERCHLOROETHYLBNE DRY CLEANING SYSTEMS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
d) All components found d)
to be leaking VOCs
shall be repaired.
e) Equivalent systems
shall reduce waste
loses to 1 kg solvent/
100 kg clothes
cleaned.
3.1 CALCULATION METHODS
Use a material balance
to estimate solvent
losses.
Immediately repair all
components found to be
leaking VOCs;
e) Not defined.
None listed
5.0 EXEMPTIONS
Carbon adsorbers are a)
not required for
plants where inade-
quate space or b)
insufficient steam
capacity are avail-
able. Plants may also
be exempt from instal-
ling carbon adsorbers
due to other unspec-
ified hardships in the c)
CTG. All such facili-
ties would be exempted
(this would include
most coin-operated d)
facilities).
OAR 340-22-220 (2)
All coin-operated
facilities;
Facilities where an
adsorber or other
necessary control
equipment cannot be
accomodated because
inadequate space;
of
Facilities with insuf-
ficient steam capacity
to desorb adsorbers;
Small facilities which
consume less than 320
gallons of perchloro-
ethylene per year.
State rule does not
explicitly comment on
calculation
procedures.
CTG does not specify a
size limit for a
"small facility" in
terms of operation.
R 226
141
7/06/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: GASOLINE TANK TRUCK VOC LEAKS
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
1.0 DEFINITIONS
Truck Tank - Any
con ta iner, including
associated pipes and
fittings, that is used
for the transport of
gasoline.
Truck Tank Vapor
Collection Equipment -
Any piping, hoses, and
devices on the truck
tank used to collect
and route gasoline
vapors in the tank to
the bulk terminal,
bulk plant or service
station vapor control
system.
Vapor Control System -
Any piping, hoses,
equipment, and devices
at the bulk terminal,
bulk plant, or service
station, which is used
to collect, store,
and/or process gaso-
line vapors.
Compartment - A
liquid-tight division
of a truck tank.
2.0 APPLICABILITY
Applies to gasoline
tank trucks and vapor
collection systems at
bulk terminals, bulk
plants, and service
stations.
R 226
OAR 340-22-102
"Delivery vessel" means any
tank truck or trailer used
for the transport of
gasoline from sources of
supply to stationary
storage tanks.
None Listed
"Vapor balance system"
means a combination of
pipes or hoses which create
a closed system between the
vapor spaces of an unload-
ing tank and a receiving
tank such that vapors dis-
placed from the receiving
tank are transferred to the
tank being unloaded.
None Listed
OAR 340-22-(120,137)
Vapor-laden delivery vessel
subject to OAR 340-22-120.
Testing vapor transfer and
collection systems
associated with a delivery
vessel is subject to OAR
340-22-137.
142
Some definitions
should be defined in
the State rule.
7/06/88-CAT
-------
TABLE 4
CTG SOURCE CATEGORY: GASOLINE TANK TRUCK VOC LEAKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
2.1 COMPLIANCE SCHEDULE
Not specified but
required by EPA policy.
OAR 340-22-120 (2)
OAR 340-22-137 (2)
April 1, 1981
2.2 TEST METHOD
REQUIREMENTS
a) Truck leak test -
Pressure and vacuum
tests are applied and
changes noted.
b) Leak detection for
monitoring should be
performed with a
portable gas detector
or a bag capture
procedure.
2.3 RECORDKEEPINC
Leak-tight certifica-
tion testing on
delivery vessels must
be performed annually.
Owners or operators
must keep records for
two years indicating
the last time the
vapor collection
facility passed test
requirements and
identifying points at
which VOC leakage
exceeded specified
provisions.
OAR 340-22-120 (3)
OAR 340-22-137 (1)
Delivery vessels shall be
tested annually according
to test methods 31 and/or
32 on file with the
Department or EPA Method
21.
R 226
OAR 340-22-120 (1)
OAR 340-22-137 (4)
If more than five gallons
of gasoline are spilled,
the operator shall report
the spillage in accordance
with 340-21-065 to -075.
The owner or operator shall
maintain records of all
certification testing and
repairs performed annually
on the vapor transfer and
collection systems. The
records must identify the
gasoline tank truck, vapor
collection system, or vapor
control system; the date of
the test or repair; and, if
applicable, the type of
repair and the date of
143
CTG references EPA
Method 27 and 21. OAR
should reference both.
Methods 31 and 32 not
yet approved.
7/06/88-CAT
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TABLE 4
CTG SOURCE CATEGORY: GASOLINE TANK TRUCK VOC LEAKS
(Continued)
U.S. EPA Control
Technology Guide-
line Requirement
State Rule
Comments
re test. The records must
be readily available for at
least two years after the
date of testing or repair
was completed.
3.0 EMISSION STANDARDS
a) Sustain a pressure
change <.75 kPa in 5
min. when pressurized
to 4.5 kPa or evacu-
ated to 1.5 kPa.
b) No visible leaks.
c) Vapor collection
system:
- Pressure specifica-
tion
- Cone, of gas vapors
-------
TABLE 5
SUMMARY OP RULES FOR WHICH SIGNIFICANT COMMENTS
NOTED IN TABLE 3 OR TABLE 4
Washington Rules
Oregon
Rules
1.0 DEFINITIONS
2.0 APPLICABILITY
Surface Coating of Cans
Surface Coating Metal Colls
Surface Coating of Paper Products
Surface Coating of Fabrics
Surface Coating of Automobiles
and Light Duty Trucks
Surface Coating of Metal
Furniture
Surface Coating of Large
Appliances
Bulk Gasoline Loading Terminals
Bulk Gasoline Plants
Surface Coating of Misc. Metal
Parts and Products
Surface Coating of Flatwood
Paneling
Petroleum Liquids in External
Floating Roof Tanks
Leaks from Gasoline Tank Trucks
and Vapor Collection Systems
Surface Coating of Cans
Surface Coating of Metal Coils
Surface Coating of Paper Products
Surface Coating of Fabrics
Surface Coating of Automobiles and
Light Duty Trucks
Surface Coating of Magnetic Wire
Petroleum Liquids in Fixed Roof
Tanks
Refinery Vacuum Producing Systems
Surface Coating of Cans
Surface Coating of Paper products
Surface Coating of Fabrics
Surface Coating of Automobiles and
Light Duty Trucks
Surface Coating of Metal Furniture
Surface Coating of Large Appliances
Petroleum Liquid in Fixed Roof Tanks
Bulk Gasoline Loading Terminals
Surface Coating of Misc. Metal Parts
and Products
Petroleum Liquids in External Floating
Roof Tanks
Leaks from Gasoline Tank Trucks
Surface Coating of Cans
Surface Coating of Paper products
Surface Coating of Fabrics
Surface Coating of Automobiles and
Light Duty Trucks
Surface Coating of Metal Furniture
Surface Coating of Magnetic Wire
Surface Coating of Large Appliances
petroleum Liquid in Fixed Roof Tanks
-------
TABLE 5
SUMMARY OF ROLES FOR WHICH SIGNIFICANT COMMENTS
NOTED IN TABLE 3 OR TABLE 4
(Continued)
Washington Rules
Oregon Rules
2.1 COMPLIANCE
SCHEDULES
2.2 TEST METHOD
REQUIREMENTS
Surface Coating of Misc. Metal
Farts and Products
Graphic Art Systems
Perchloroethylene Dry Cleaning
Systems
Leaks from Gasoline Tank Trucks
and Vapor Collection Systems
None
(All surface coatings in Group I
CTGs—per Table 2)
petroleum Liquids in Fixed Roof
Tanks
Bulk Gasoline Loading Terminals
Solvent Metal Cleaning
Petroleum Refinery Equipment
Leaks
Surface Coating of Miscellaneous
Metal Parts and Products
Surface Coating of Flatwood
Paneling
Perc. Dry Cleaning Systems
Leaks from Gasoline Tank Trucks
and Vapor Collection Systems
Bulk Gasoline Plants
Surface Coating of Misc. Metal Parts
and Products
Graphic Arts Systems
Petroleum Liquids in External
Floating Roof Tanks
Perchloroethylene Dry Cleaning
Systems
None
(All surface coatings in Group I
CTGs—significance depends on the
test method referenced)
Bulk Gasoline Loading Terminals
Solvent Metal Cleaning
(Surface Coating of Miscellaneous
Metal Parts—significance depends on
the test method referenced)
Perc. Dry Cleaning Systems
Leaks from Gasoline Tank Truck and
Vapor Collection Systems
-------
TABLE 5
SUMMARY OP RULES FOR WHICH SIGNIFICANT COMMENTS
NOTED IN TABLE 3 OR TABLE 4
(Continued)
Washington Rules
Oregon Rules
2.3 RECORDKEEPING
3.0 EMISSION (OR
EQUIPMENT)
STANDARDS
3.1 CALCULATION
METHODS
3.2 CAPTURE
EFFICIENCY
Petroleum Liquids in Fixed Roof
Tanks
Refinery Vacuum Producing
Systems
Graphic Arts Systems
Surface Coating of Automobiles
and Light Duty Trucks
Solvent Metal Cleaning
Cutback Asphalt
Graphic Arts Systems
Perc. Dry Cleaning Systems
Surface Coating of Metal
Furniture
Surface Coating of Magnetic
Wires
Surface Coating of Large
Appliances
Surface Coating of Misc. Metal
Parts and Products
Surface Coating of Flatwood
Paneling
Perc. Dry Cleaning Systems
Surface Coating of Metal
Furniture
Graphic Art Systems
Petroleum liquids in Fixed Roof Tanks
Surface Coating of Paper
Bulk Gasoline Plants
Solvent Metal Cleaning
Surface Coating of Misc. Metal Parts
and Products
Perc. Dry Cleaning Systems
Surface Coating of
Surface Coating of
Surface Coating of
Surface Coating of
Metal Parts
Surface Coating of
Perc. Dry Cleaning
Metal Furniture
Magnetic Wires
Large Appliances
Miscellaneous
Flatwood Paneling
Systems
Surface Coating of Metal Furniture
Surface Coating of Miscellaneous Metal
Parts
Graphic Art Systems
-------
TABLE 5
SUMMARY OF RULES FOR WHICH SIGNIFICANT COMMENTS
NOTED IN TABLE 3 OR TABLE 4
(Continued)
Washington Rules
Oregon Rules
4.0
AVERAGING
TIME
ao
5.0 EXEMPTIONS
Surface Coating of Cans
Surface Coating of Metal Coils
Surface Coating of Paper Products
Surface Coating of Fabrics
Surface Coating of Automobiles
and Light Duty Trucks
Surface Coating of Metal
Furniture
Bulk Gasoline Loading Terminals
Petroleum Refinery Equipment
Leaks
Surface Coating of Cans
Surface Coating of Metal Coils
Surface Coating of Paper Products
Surface Coating of Fabrics
Surface Coating of Automobiles
and Light Duty Trucks
Surface Coating of Metal
Furniture
Surface Coating of Magnetic Wire
Surface Coating of Large
Appliances
Bulk Gasoline Plants
Solvent Metal Cleaning
Refinery Vacuum Producing
Systems
Surface Coating of Misc. Metal
Parts and Products
Graphic Arts Systems
Petroleum Liquids in Fixed Roof Tanks
Bulk Gasoline Loading Terminals
Surface Coating of Cans
Surface Coating of Paper Products
Surface Coating of Fabrics
Surface Coating of Automobiles and
and Light Duty Trucks
Surface Coating of Magnetic Wire
Surface Coating of Metal Furniture
Surface Coating of Large Appliances
Bulk Gasoline Plants
Solvent Metal Cleaning
Petroleum Refinery Equipment Leaks
Surface Coating of Miscellaneous
Metal Parts
Graphic Art Systems
Perc. Dry Cleaning Systems
-------
TABLE 5
SUMMARY OF RULES FOR WHICH SIGNIFICANT COMMENTS
NOTED IN TABLE 3 OR TABLE 4
(Continued)
Washington Rules Oregon Rules
Perc. Dry Cleaning Systems
Leaks from Tank Trucks and
Vapor Collection Systems
5<1 "DIRECTOR Perc. Dry Cleaning Systems NOne
DISCRETION1
EXEMPTIONS
------- |