ISSUES RELATING TO VOC REGULATION
OUTPOINTS, DEFICIENCIES, AND DEVIATIONS
Clarification to
of November 24, 1987 FEDERAL REGISTER
May 25,
Ozone/Carbon Monoxide
Air Quality Managemen
Office of Air Quality Planning and Standards
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ISSUES RELATING TO VOC REGULATION
OUTPOINTS, DEFICIENCIES, AND DEVIATIONS
Clarification to Appendix D
of November 24, 1987 FEDERAL REGISTER
May 25, 1988
Revised 1/11/90
Ozone/Carbon Monoxide Program Branch
Air Quality Management Division
Office of Air Quality Planning and Standards
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INTRODUCTION
On November 24, 1987, EPA proposed its post-1987 ozone and carbon
monoxide policy statement. In that proposal the Agency described a
process to make SIP deficiency "calls" pursuant to Section 110(a)(2)(H)
of the Clean Air Act. Appendix D of the proposed policy statement
contained a listing of SIP deficiencies and inconsistencies that
should be addressed and corrected when States respond to such SIP calls.
The purpose of this document is to provide additional clarification of
those areas described in Appendix D in which existing Reasonably Available
Control Technology (RACT) regulations for volatile organic compounds (VOC)
have not been adopted and/or implemented on a nationally consistent basis.
This clarification does not expand or modify existing federal regulatory
requirements, but merely enhances Appendix D by providing more specific
information in cases where past EPA guidance or approved rulemaking was
vague or ambiguous. This document does not address issues covered in
Appendix D related to new source review regulations.
In the April 1987 letter from the EPA Administrator to the Governors
of 42 States, EPA announced its intention to undertake a three-part
process in its post-1987 SIP revisions. First, EPA was to review all
federally-approved control commitments in the State implementation plan
to determine whether they have been adopted. Second, EPA was to review
whether these adopted measures are technically adequate and meet minimum
national standards for consistency. Third, EPA was to initiate a compre-
hensive program to determine whether adopted measures are being effectively
implemented. This document addresses many of the "Appendix D" problems
uncovered during the second part of this process. Corrections of the
deficiencies described herein provide for a greater degree of equity
and national consistency among all States and localities that receive
post-1987 ozone SIP calls.
NOTE: This update includes revisions to pages 1-2, 2-5, and 2-6 of
this document. The revisions are technical corrections to
reflect the addition of four\compounds to the list of those
that are exempt from EPA's definition of "volatile organic
compounds." This change was made in the Federal Register of
January 18, 1989 (54 FR 1987).
Revised 1/11/90
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ISSUES RELATING TO VOC REGULATION OUTPOINTS.
DEFICIENCIES AND DEVIATIONS
Executive Summary
Based on Appendix D of Federal Register of November 24, 1987
1. RACT Regulation Exemptions--
• Where EPA has previously specified a regulation size cutoff (in
CTG or other guidance documents—e.g., model regulation documents,
such as EPA-45u/2-7y-004 and EPA-90b/2-7b-UUl), State must incorporate
these cutoffs if their existing regulations are less stringent.
(See Attachment 1)
• Where EPA has previously specified 3 lb VOC/hr or 15 lb VOC/day
cutoff, State may use it on actual emissions basis or use 10 tpy
theoretical potential emissions (design capacity [or maximum
productionj and 876u hr/yr) before add-on control. Care should be
taken to make enforceable any regulations specified on an "actual"
emissions basis.
• Cutoff total determined from the sum of individual emission sources
within same CTG category. (Exception: Petroleum marketing —
storage tanks, terminals, and loading racks must be combined.)
• States may only use higher cutoffs if supported by 5% analysis on
an emissions basis (showing that no significant emissions differential
occurs between EPA guidance and State choice). (See Attachment 2)
2. Definition of 100 tpy non-CTG source—
• Aggregate all unregulated sources (including sources which would
have been covered by a CTG if they had been above the EPA-accepted
size cutoff--e.g., <100 tpy graphic arts sources).
• Base on theoretical potential emissions (design capacity [or
maximum production] and 876U hr/yr) before add-on control.
• Cannot merely apply 1ess-than-RACT controls to avoid applicability.
• Can restrict nours of operation by legally and federally enforceable
permit conditions to limit emissions below 100 tpy.
• "Once-in-always-in" concept must apply (i.e., if emissions are
found above cutoff, then State must apply RACT thereafter).
3. Form of Surface Coating Emission Limit Units—
• Regulations should be expressed as lb VOC/gal of coating (less
water and "exempt" solvents). "Exempt" solvents are those
determined by EPA to have negligible photochemical reactivity.
See VOC definition, page 1-2.
• If "equivalent" add-on controls, transfer efficiency, or emission
trading (cross line averaging) are contemplated, then regulation
should also be expressed as lb VOC/gal of solids (or lb VOC/lb
solids for graphic arts).
• Alternatively, the regulation can contain a calculation conversion
procedure to determine compliance. Procedure must be clearly defined,
replicable, and consider the above factors. (See Attachment 3)
• Daily emission caps are desirable but not mandatory unless estab-
lished as part of the SIP control ,strategy. They cannot be used
in exchange for a relaxation of RACT.
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1 -2a
4. Exempt Solvents-
Treat as water in "lb VOC/gal coating less water" calculations.
Cannot take credit in emissions inventory and attainment
demonstration or new source review for control of exempt solvents.
Exempt only those solvents determined to have negligible
photochemical reactivity listed in the five Federal Register notices
(see RECOMMENDATION FOR EXEMPT SOLVENTS, Page 2-5.)
5. VOC Definition--
Cannot use 0.1 mm Hg vapor pressure cutoff -- inconsistent with EPA
reactivity policy. Such a definition would exempt compounds of low
volatility, which, under certain processes, would volatilize and,
therefore, participate in photochemical reactions. !
Model definition:
"Volatile organic compound (VOC)--Any organic compound which
participates in atmospheric photochemical reactions. This includes
any organic compound other than the following compounds: methane,
ethane, methyl chloroform (1,1,1-trichloroethane), CFC-113
(trichlorotrifluoroethane), methylene chloride, CFC-11
(trichlorofluoromethane), CFC-12 (dichlorodifluoromethane), CFC-22
(chlorodifluoromethane), FC-23 (trifluoromethane),
CFC-114(dichlorotetrafluoroethane), CFC-115
(chloropentafluoroethane), HCFC-123 (dichlorotrifluoroethane), HFC-
134a (tetrafluoroethane), HCFC-141b (dichlorofluoroethane), and
HCFC-142b (chlorodifluoroethane). These compounds have been
determined to have negligible photochemical reactivity. For
purposes of determining compliance with emission limits, VOC will fa-
measured by the approved test methods. Where such a method also
inadvertently measures compounds with negligible photochemical
reactivity, an owner or operator may exclude these negligibly
reactive compounds when determining compliance with an emissions
standard."
6. Corrections for Other VOC Rule Definitions--
List from Appendix D: (coating, coating line, refinishing, paper
coating, fabric coating, vinyl coating)
EPA Regions to make SIP calls on State-specific definitional
problems to ensure consistency with CTG's and to avoid vague and
ambiguous wording.
7. Transfer Efficiency (TE)--
Where SIP allows credit for TE, SIP must clearly state the
applicable baseline, emission limit, and test procedure. A
replicable baseline should be no less stringent than standard
industry practice.
60 percent default baseline acceptable for most large appliances,
metal furniture, and miscellaneous metal coating operations;
however, testing for actual TE above 60 percent default baseline is
needed to determine final compliance.
Revised 1/11/90
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1 -2b
30 percent default baseline generally acceptable for certain auto
coatings: i.e. surfacer and top coat waterborne equivalence (i.e.,
2.8 lb VOC/gal coating, less water at 30 percent TE). See
page 2-22.
TE cannot be used as an alternative means of control unless baseline
is specified and test method is approved as part of the SIP.
Source-specific SIP revision is required unless use of TE is
approved pursuant to generic SIP provision (see discussion, page 2-
14).
Actual TE's must be used; no NSPS TE table values allowed for final
RACT compliance.
Revised 1/11/90
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1-3
8. Cross-Line Averaging (Bubble) —
* In cases where a State, prior to the post-1987 SIP call, has
previously granted (without EPA approval) cross-line averaging to
a source, the State must include the cross-line averaging scheme
for approval as a source-specific SIP revision under the emissions
trading (ET) policy (see 51 FR 43814, 12-4-86). Treat this as a
de facto pending bubble, but only for purposes of the additional
20% control requirement.
* Source-specific revision must meet ET policy on daily weighted
average basis
* If approved under generic bubble rule, generic rule must also meet
provisions of ET policy
* The following situations are examples of cross-line averaging:
(1) The source averages emissions between two or more separate
operations (e.g., auto prime coat and top coat) with the same or
different regulatory limits; and
(2) The source averages emissions between two or more similar
processes (e.g., separate conveyor lines of similar machines)
with the same or different regulatory limits.
9. Compliance Periods—
* SIP must clearly state compliance period (e.g., hourly, daily) and
averaging method (arithmetic or weighted).
* Regulation must require compliance on no longer than
daily basis (generally acceptable).
* Longer than 24-hr averaging must meet EPA policy (O'Connor memo
1-20-84)
* Compliance date extensions must meet EPA policy (Potter memo
8-7-86)
10. Recordkeeping Requirements—
* Must keep records consistent with compliance time frames—daily
compliance requires daily records
* Employ most recent EPA recordkeeping guidance (guidance forthcoming).
11. Test Methods—Use most current EPA acceptable methods. All methods
must be specified in the SIP. (See Attachment 4) For auto topcoating
operations, see page 2-22.
12. Capture Efficiency—
* Specify capture efficiency test method where capture efficiency is
discussed or implied in limit (e.g., web-coating operations with
add-on control).
Employ most recent guidance on capture efficiency testing (guidance
forthcoming).
13. Equipment Leak Components —
Inaccessible valves are required to be monitored at least annually.
Unsafe-to-monitor valves are required to be monitored when conditions
would allow these valves to be monitored safely, e.g., during shutdown.
14. Exemptions, Variances, and Alternative Means of Control —
Generic approval of emission trades is already covered by EPA's
emission trading policy statement (51 FR 43814, December 4, 1986).
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1-4
* All SIP's must specify whether approval of source-specific exemptions,
variances, and/or alternative means of control shall be accomplished
as a source-specific SIP revision or by a determination of approval by
the State Director (a "generic" provision). All such generic determina-
tions and supporting documentation shall be submitted to the appropriate
Regional Office,
* To be approvable, a provision for generic approval of source-specific
exemptions, variances, and/or alternative means of control must —
** specify appropriate test methods and other replicable criteria
in accordance with guidance issued by EPA; AND
** require that any source seeking approval of an exemption, variance,
or alternative means of control demonstrates that its control
method achieves emissions reductions equal to or greater than the
emission reductions required by the SIP.
* Provisions that are intended to be generic (i.e., not requiring case-
by-case EPA approval for the alternative means to be federally effective)
must meet the general principle of replicability described in EPA's
emissions trading policy statement (51 FR 43850, December 4, 1986).
" Federal Register notices that approve SIP revisions containing general
provisions that may be construed as generic procedures should include
EPA's "warning" about residual authority to ensure consistent actions
under generic procedures. See page 2-14.
Seasonal controls (other than shutdown of natural gas afterburners
or use of emulsified asphalt) not allowed
State redesignation to attainment classification must not affect
applicability of regulations. The EPA will approve a redesignation
under 40 CFR Part 81 only if it meets EPA's redesignation policy.
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WHAT DOES SIP CALL MEAN?
(Regarding VOC RACT Rules)
Response to SIP calls will be made in two phases as described below:
FIRST PHASE—LIMITED RESPONSE
(SIP revision due 1 year after work plan is submitted under SIP call)
* No additional regulatory requirements added
* Meet all previously applicable requirements for 1987 extension
areas and 1982 SIP call areas ("Level Playing Field") (e.g.,
consistent cutoffs, test methods). All such areas must meet
requirements of Groups I, II, and III CTG source categories.
* No additional RACT requirement <100 tpy for contiguous rural county.
SECOND PHASE—FULL RESPONSE
(After EPA Publishes Final Ozone/CO Policy)
New additional requirements possible for additional MSA and new
contiguous (rural) SIP call areas. (May be mandatory or discretionary—
depends upon final policy).
Groups I and II
Group III
_> 100 tpy non CTG
New requirements possible for new isolated rural SIP call areas. Again,
depends upon final policy.
Groups 1 and 11: _> 100 tpy coverage only
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2-2
CTG RACT REGULATION CUTOFFS/EXEMPTIONS
* Recommended cutoffs contained in CTG's, model regulations, or EPA
policy memorandums (See Attachment 1)
* For additional CTG categories size cutoffs, see SELECTED COATINGS
CTG CATEGORY RECOMMENDED EXEMPTION LEVEL, page 16.
* Calculating regulation size cutoffs for CTG sources
** Base tpy cutoff on theoretical potential to emit (design capacity
[or maximum production] and 8760 hr/yr) before add-on controls.
Care should be taken to make enforceable any regulations specified
on an "actual" emissions basis.
** Cutoff total determined from the sum of individual emission
sources within same CTG category (Exception: petroleum
marketing—storage tanks, terminals and loading racks must
be combined)
** Apply RACT if plantwide emissions > cutoff limit
If caught with emissions > cutoff limit in the future, then
State must apply RACT ("once in, always in")
** CTG area sources have no cutoff (e.g., cold cleaner degreasers
and tank trucks)
* SIP call requires States to assess their existing VOC regulations and
address cutoffs in EPA guidance. Exemptions can be granted only by
way of the 5% rule (see Attachment 2)
* In cases where past guidance recommends high cutoff (e.g., 100 tpy),
SIP call should also recommend that State investigate small exemption
levels to prepare for additional emission reductions under full response
to SIP call
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2-3
DEFINITION OF 100 TPY NON-CTG SOURCE
* Based on theoretical potential to emit (design capacity [or maximum
production] and 8760 hr/yr) before add-on controls
* To determine if _> 100 tpy:
*" aggregate emissions of all nonregulated sources
—include sources which would have been covered by a CTG
if they had been above the EPA-accepted size cutoff—e.g.,
<100 tpy graphic arts sources
—exclude regulated CTG sources
If > 100 tpy, evaluate RACT on all unregulated source types in plant
Even "status quo" (RACT-level) emissions must be put in regulation or
federally enforceable permit form to avoid increases (e.g., emission
levels without any additional controls)
To achieve "below 100 tpy" (and avoid RACT), a State may limit production
or capacity and specify this limitation in a federally enforceable
permit (cannot just apply minimal controls to go below 100 tpy)
Employ "once-in-always-in" concept for applicability
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2-4
FORM OF SURFACE COATING EMISSION LIMIT UNITS
* Recommended form of emission limit—pounds VOC per gallon coating
(less water and "exempt" solvents*)
* However, if rule or SIP allows:
** determination of compliance from "equivalent" add-on controls,
** credit for transfer efficiency, or
** emissions trades and cross-line averaging
" Then rule must have VOC limits expressed as both:
"* pounds VOC per gallon coating (less water and exempt solvents)
to aid in compliance determination
and
pounds VOC per gallon solids (or pounds VOC per pound of solids for
graphic arts)
or
** provide clearly defined, replicable conversion calculation procedure
to obtain equivalent limit (See Attachment 3)
Daily emission caps are desirable, but not mandatory unless they are
established as part of the SIP control strategy. Daily emission caps
cannot be used in exchange for a relaxation of RACT.
*"Exempt" solvents are those determined by EPA to have negligible
photochemical reactivity. See VOC DEFINITION, page 2-6.
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2-5
RECOMMENDATION FOR EXEMPT SOLVENTS
Check all regulations
Cannot allow circumvention of EPA reactivity policy based on other VOC
definitions and exemptions
For calculation purposes, any exempt compounds shall be treated as water
Cannot take credit for control of exempt solvents for purposes of
emissions inventory and attainment demonstrations or new source review
Exempt solvents are only those identified in the following Federal
Register notices:
•• 42 FR 35314, 7/8/77 (Table 1)
•• 42 FR 38931, 8/1/77 (corrects 7/8/77 FR)
•• 44 FR 32042, 6/4/79
•• 45 FR 32424, 5/16/80 (clarifies 6/4/79 FR)
•• 45 FR 48941, 7/22/80
•• 54 FR 1987, 1/18/89
Revised 1/11/90
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2-6
VOC DEFINITION
* Cannot use 0.1 mm Hg vapor pressure cutoff to define VOC—Inconsistent
with EPA reactivity policy. Such a definition would exempt compounds
of low volatility, which, under certain processes, would volatilize
and, therefore, would participate in photochemical reactions. A State
must eliminate this loophole from the SIP.
* Model definition:
Any organic compound which participates in atmospheric
photochemical reactions. This Includes any organic
compound other than the following compounds: methane, ethane,
methyl chloroform (1,1,1-trichloroethane), CFC-113
(trichlorotrifluoroethane), methylene chloride, CFC-11
(trichlorofluoromethane), CFC-12 (dichlorodlfluoromethane),
CFC-22 (chlorodifluoromethane), FC-23 (tr1fluoromethane),
CFC-114 (dichlorotetrafluoroethane), CFC-115 (chloropenta-
fluoroethane).* These compounds have been determined to have
negligible photochemical reactivity. For purposes of determining
compliance with emission limits, VOC will be measured by the
approved test methods. Where such a method also inadvertently
measures compounds with negligible photochemical reactivity,
an owner or operator may exclude these negligibly reactive
compounds when determining compliance with an emissions standard.
* Also includes the following compounds exempted bv EPA on
Jan 18, 1989 (54 FR 1987):
(1) Dichlorotrifluoroethane (HCFC-123)
(2) Tetrafluoroethane (HFC-134a)
(3) Dichlorofluoroethane (HCFC-141b)
(4) Chlorodifluoroethane (HCFC-142b)
Revised 1/5/90
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2-7
CORRECTIONS FOR OTHER VOC RULE DEFINITIONS
* List from proposed ozone policy—
Appendix D
** coating
** coating line
** refinishing
** paper coating
** fabric coating
** vinyl coating
* EPA Regions to make SIP calls on State-specific definitional problems
to ensure consistency with CTG's and to avoid vague or ambiguous
wording.
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2-8
TRANSFER EFFICIENCY (TE)
Where SIP allows credit for TE, SIP must clearly state the applicable
baseline based on standard industry practice, emission limit, and fully
replicable* test procedure for transfer efficiency.
Current guidance: in most cases, can accept use of 60S transfer
efficiency as baseline for:
—Large appliances
—Metal furniture
—Miscellaneous metal parts
Testing for actual TE above the 60S default baseline is needed
to determine final compliance
In most cases accept use of 30% TE as baseline for auto surfacer and
topcoat waterborne equivalence (i.e., 2.8 lb VOC/gal coating less water
at 30S TE) (see page 2-22)
TE cannot be used as an alternative means of control unless baseline is
specified and test method is approved as part of the SIP
Source-specific SIP revision is required unless use of TE is approved
pursuant to generic SIP provision (see discussion on EXEMPTIONS,
VARIANCES, AND ALTERNATIVE MEANS OF CONTROL, page 2-14)
Actual TE's must be used; TE table values (e.g., from NSPS) are
unacceptable for final RACT compliance.
For a discussion of replicabi1ity, see 51 FR 43850, 12/4/86
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2-9
CROSS-LINE AVERAGING (BUBBLE)
' In cases where a State, prior to the post-1987 SIP call, has previously
granted (without EPA approval) cross-line averaging to a source, the
State must include the cross-line averaging scheme for approval as a
source-specific SIP revision under the emissions trading (ET) policy
(see 51 FR 43814, 12/4/86). Treat this as a de facto pending bubble,
but only for purposes of the additional 20% control- requirement.
' Based on daily weighted average
' No credit for downtime; however, credit allowed when there are
enforceable production limits.
' Must be submitted as source-specific SIP revision, unless processed by
the State under an EPA-approved bubble rule. Must be consistent with
provisions of EPA ET policy
' If allowed under EPA-a.pproved generic bubble rule, generic rule must
meet EPA ET policy*
' Fix deficiencies in calculation procedures or compliance techniques
associated with generic regulations
' The following situations are examples of cross-line averaging:
** the source averages emissions between two or more separate
operations (e.g., auto prime coat and top coat) with the same
or different regulatory limits; and
the source averages emissions between two or more similar
processes (e.g., separate conveyor lines of similar machines)
with the same or different regulatory limits
""NOTE: SIP call needed for currently approved generic bubble rules
that are inconsistent with EPA ET policy
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2-10
COMPLIANCE PERIODS
* SIP must clearly state compliance period (e.g., hourly, daily) and
averaging method (arithmetic or weighted)
In general, regulation must require compliance on no longer than a
daily basis
* Averaging times longer than 24 hours allowed ONLY in accordance
with established EPA policy (O'Connor memo—1/20/84)
* Averaging periods in excess of 24 hours are not allowed generically.
Must receive EPA approval as SIP revision
Reexamine pre-0'Connor memo approvals of _> daily averaging to
ensure that RACT levels of control are applied
* Compliance date extensions allowed only in accordance with Potter
memo (8/7/86)
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2-11
RECORDKEEPING REQUIREMENTS
* Keep records consistent with compliance time frames—daily
compliance requires daily records
* Record or calculate coating solids use and VOC emitted consistent
with compliance time frames
EXAMPLES: gallons of solids per day
pounds of VOC per day
(This allows, for instance, one to calculate compliance with a VOC
limit in terms of lb VOC/gal of solids)
* List amount of diluents and (where relevant to determining compliance)
wash and clean-up solvents
* Document use of EPA test methods or EPA-approved State method in
calculating VOC content of coatings
Document methods used to calculate volume percent solids content of
coati ngs
Separately enforceable provisions must clearly require recordkeeping
Employ most recent EPA recordkeeping guidance
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2-12
TEST METHODS AND CAPTURE EFFICIENCY
Use most current VOC test methods (See Attachment 4). For auto topcoating
operations, see page 2-22.
All methods must be specified in the SIP.
Procedures should allow verification of accuracy, of test data.
Prescribe capture efficiency test method where capture efficiency
is discussed or implied in limit (e.g., web-coating operations with
add-on control).
Employ most recent EPA guidance on capture efficiency testing.
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2-13
EQUIPMENT LEAK COMPONENTS
* Sources previously exempt from monitoring (e.g, plug and ball valves)
subject to SIP requirements
* Inaccessible valves are required to be monitored at least annually.
* Unsafe-to-monitor valves are required to be monitored when conditions
would allow these valves to be monitored safely, e.g., during shutdown.
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2-14
EXEMPTIONS, VARIANCES, AND ALTERNATIVE MEANS OF CONTROL
Generic approval of emission trades is already covered by EPA1s
emission trading policy statement (51 FR 43814, December 4, 1986).
For information on emissions trading, see page 2-9.
All SIP's must specify whether approval of source-specific exemptions,
variances, and/or alternative means of control shall be accomplished
as a source-specific SIP revision or by a determination of approval by
the State Director (a "generic" provision). All such generic determina-
tions and supporting documentation shall be submitted to the appropriate
Regional Office.
To be approvable, a provision for generic approval of source-specific
exemptions, variances, and/or alternative means of control must —
** specify appropriate test methods and other replicable criteria
in accordance with guidance issued by EPA; AND
require that any source seeking approval of an exemption, variance,
or alternative means of control demonstrates that its control
method achieves emissions reductions equal to or greater than the
emission reductions required by the SIP.
Provisions that are intended to be generic (i.e., not requiring case-
by-case EPA approval for the alternative means to be federally effective)
must meet the general principle of replicabi1ity described in EPA's
emissions trading policy statement (51 FR 43850, December 4, 1986).
Federal Register notices that approve SIP revisions containing general
provisions that may be construed as generic procedures should include
the following statement:
It should be noted that, similar to EPA's treatment of
generic bubble rules (51 FR 43853, column 3, 12-4-86),
if a State-approved action under a generic rule does
not meet all the requirements for replicabi1ity, it
cannot be considered part of the SIP and by definition
cannot replace prior valid emission limits in the SIP.
Should EPA determine, as a result of its oversight
activities that a State-approved action is inconsistent
with the above recuirements, it will notify the State
and source in writing and specify any necessary remedial
measures. In such circumstances, EPA may take appropriate
remedial action to assure attainment and maintenance,
including direct enforcement of the original SIP limits.
Seasonal controls (other than shutdown of natural gas afterburners
or use of emulsified asphalt) are not allowed.
State redesignation to attainment classification must not affect
applicability of regulations. The EPA will approve a redesignation
under 40 CFR Part 81 only if it meets EPA's redesignation policy.
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2-15
ADDITIONAL CLARIFICATION BY CTG SOURCE CATEGORY
(For Selected Categories)
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2-16
SELECTED COATINGS CTG CATEGORY RECOMMENDED EXEMPTION LEVEL
Applicable Source Categories:
Can
Metal Coil
Metal Furniture
Magnet Wire
Large Appliance
Miscellaneous Metal Parts
Flat Wood Paneling
Paper Coating
Fabric Coating
State may use:
* 10 tpy theoretical potential emissions (design capacity [or maximum
production] and 8760 hrs/yr) before add-on control
* 3 lb VOC/hr or 15 lb/day actual emissions before add-on control
' To show that there is no significant difference between "State-derived
cutoffs" and EPA guidance, States must apply "5% rule" (See Attachment
2) to allow higher cutoff. Analysis must be based on comparison of:
** emissions after control under presumptive cutoff—with
** emissions after control under higher cutoff
** NOTE: 52 rule applies to entire source category, not individual
sources. RACT is the test for individual sources.
* Allow coatings usage rate (gal/day) as basis for exemption if shown
equivalent to emission rate exemption (see EPA guidance memo from
Tom Helms, EPA/OAQPS, to Air Branch Chiefs, Regions I-X, Additional
Information Concerning Emission Cut-off—3 lbs/hr, 15 lbs/day.
Movember 4, 1987).
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2-17
GASOLINE LOADING TERMINALS
* > 20,000 gal/day—considered terminal
* <_ 20,000 gal/day = bulk plant
* Allow rolling 30-day average to determine applicability—but not
for determining compliance with emission limit
* Employ "once-in-always-in" concept for applicability
* CTG limit recommendation—80 mg/1
Ensure that trucks using terminals pass leak-tight test
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2-18
GASOLINE BULK PLANTS
* Defined as _< 20,000 gal/day throughput
* Allowed exemption—< 4,000 gal/day throughput
* Recommend CTG control alternative #3 (Submerged fill + vapor
balance—in and out)
* Allow rolling 30-day average for determining applicability—but
not for determining compliance
* Employ "once-in-always-in" concept for applicability
Recommend tank truck must be certified leak tight at bulk plant
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2-19
LEAKS FROM PETROLEUM REFINERIES
* Define "leak" as VOC concentration > 10,000 ppm; VOC concentration
_< 10,000 ppm is not a leak
* No CTG cutoff for petroleum refinery size
—applies to all refineries
* Recommend consistency with SOCMI leak CTG guidance, i.e., valves
located such that monitoring personnel must be elevated 2 meters
above permanent support surfaces or require scaffolding might be
exempt from quarterly monitoring. Annual- monitoring still required.
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2-20
MISCELLANEOUS REFINERY SOURCES
* Vacuum producing systems, wastewater separators, and process unit
turnarounds
" No CTG cutoffs
* Recommended cutoff—only recovered petroleum products with Reid
vapor pressure C.5 pounds or greater are covered. Affected sources
are not covered if throughput of these recovered petroleum products
is < 200 gal/day.
May also wish to consider NSPS where no cutoff is recommended.
Segregated storm water runoff drain systems and non-contact
cooling water systems are exempt.
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2-21
SERVICE STATIONS—STAGE I
* Regulation can be written two ways:
—tank size, or
—gasoline throughput
* Tank size:
—Exempt storage tanks < 550 gal capacity for agricultural use
—exempt < 2,000 gal capacity storage tanks in place before 1/1/79
—exempt < 250 gal capacity storage tanks in place after 12/31/78
* Gasoline throughput:
—exempt < 10,000 gal/mo (120,000 gal/yr) throughput for service stations
—allow rolling 30-day average for applicability level—but not for
compliance
* Employ "once-in-always-in" concept for applicability
Apply 5% rule for other than 10,000 gal/mo (120,000 gal/yr) exemption
(52 rule applies to the entire source category and not individual
faci li ties).
-------
2-22
AUTOMOBILE AND LIGHT DUTY TRUCK COATING
EPA autocoating protocol is the preferred method for calculating daily
topcoat emission rate (protocol forthcoming)
Topcoat regulation must be amenable to use of EPA autocoating protocol:
*" Emission limit must be in units of lb YOC/gal of solids
deposited (2.8 lb VOC/gal coating, less water at
30 percent TE translates to 15.1 lb VOC/gal solids deposited)
** Compliance must be calculated on a daily weighted average basis
** Topcoat operation must include all spray booths,
flash-off areas and ovens in which topcoat is applied, dried
and cured (excludes final off-line repair).
Emission limit for surfacer (guidecoat) should be expressed in pounds of
VOC per gallon of solids deposited with compliance calculated on a daily
weighted average basis if transfer efficiency is to be considered in
determining compliance. In these cases, the EPA protocol may be applicable
for calculating daily surfacer emission rate.
The SIP should specify whether anti-chip materials applied to main body
parts (e.g., rocker panels, bottom of doors and fenders, and leading edge
of roof) are treated as surfacer or miscellaneoous metal coating.
These anti-chip materials should generally be treated as surfacer,
especially if transfer efficiency is to be considered in compliance
demonstrations. Underbody anti-chip (e.g., underbody plastisol) should
be specified as a miscellaneous metal coating.
Coatings other than primer, surfacer, topcoat and final repair should
generally be considered miscellaneous metal coatings. (See memorandum
from Richard Rhoads, EPA/OAQPS, to Directors, Air and Hazardous Materials
Division, Regions I-X, Applicability of VOC Control Techniques Guidelines
(CTG's) to the Automobile Manufacturing Industry. July 31, 1980.)
No CTG cutoffs
Should define exemption level on plantwide basis
CTG applies only to manufacture of new vehicles
New and modified sources must also meet new source review requirements,
which may include BACT and LAER.
-------
2-23
CUTBACK OR EMULSIFIED ASPHALT
* No CTG cutoffs
* Recommend seasonal exemptions (i.e., outside of ozone season) as opposed
to temperature forecasting (e.g., < 50°F). (See memorandum from Richard
Rhoads, EPA/OAQPS, to Air & Hazardous Materials Division Directors,
Regions I-X. Cutback Asphalt-acceptable RACT Regulation. December 19,
1978).
* Specify (1) no higher than 1% oil distillate as maximum allowable solvent
content in emulsified asphalt, as determined by ASTM distillation test
D-244, or (2) allow use of certain grades or applications of emulsified
asphalt with the following maximum solvent contents as determined by
ASTM D-244: (a) 32 limit for seal coats used in early spring or late
fall; (b) 3% limit when chip seals used when aggregate is dusty or
dirty; (c) 8% limit when mixing with open graded aggregate that is not
well washed; and (d) 12* limit when mixing with dense graded aggregate
(See memorandum from Richard Rhoads to Director, Air & Hazardous Materials
Division, Regions I-X, Clarification for Final SIP Actions on Asphalt
Regulations, October 4, 1979)
Other exemptions for use solely as penetrating prime coat and when
stockpiled for extended periods (longer than 1 month) (See memorandum
from Richard Rhoads to Director, Air & Hazardous Materials Division,
Regions I-X, Cutback Asphalt-Acceptable RACT Regulation. December 19,
1978).
-------
2-24
SOLVENT METAL CLEANING
Exemptions: See CTG for appropriate cutoffs
No 3 lb/hr, 15 lb/day exemption for small cold cleaner degreasers
(area source). (See memorandum from Richard Rhoads, EPA/OAQPS, to
Director, Air & Hazardous Materials Division, Regions I-X, Clarificati
of Degreasing Regulation Requirements, September 7, 1978).
-------
2-25
GRAPHIC ARTS
* CTG cutoff < 100 tpy potential emissions (design capacity and 8760 hr
or maximum production) before control
* EPA will accept as an alternative emission limit 0.5 lb VOC/lb solids
on- a per line basis. (See memorandum from Darryl Tyler, EPA/OAQPS,
to Director, Air Division, Regions I-X, Alternative Compliance for
Graphic Arts RACT, September 9, 1987.)
* If a source wishes to average emissions across lines, it must meet
the general provisions of the EPA emissions trading policy.
* Employ "once-in-always-in" concept for applicability
-------
ATTACHMENT 1
CTG APPLICABILITY:
CUTOFFS, EXEMPTIONS, AND GENERAL
APPLICABILITY
-------
CTG APPLICABILITY:
CUTOFFS, EXEMPTIONS, AND GENERAL
APPLICABILITY
The EPA has issued control technique guideline (CTG) documents for
30 source categories, two regulatory guideline documents covering 25 of
these 30 source categories, and several policy and other miscellaneous
guidance memoranda. Part of the guidance provided in the CTG's, the
two regulatory documents, and the guidance memoranda concerns cutoffs,
exemptions, and other similar guidance on the applicability of the recom-
mended control techniques. This information is summarized in Tables 1, 2,
and 3 for 29 of the 30 source categories. The CTG for the 30th source cate-
gory, Vegetable Oil, was recommended by EPA not to be implemented by the
States until test method uncertainties were resolved, and thus is not included
in these tables. A complete list of references is provided at the end of
these tables.
This information represents guidance issued prior to May, 1988. For
categories with cutoffs listed as "None", no specific guidance on cutoffs has
been issued for this particular category although a 3 lb/hr or 15 lb/day
general exemption has been discussed in pre-1988 guidance. For current
guidance on cutoffs for categories listed here as "None", see "Issues Relating
to VOC Regulations. Cutpoints, Deficiencies, and Deviations - Clarification
to Appendix D of November 24, 1987. Federal Register," May 1988.
Also, for CTG Groups I and II for nonattainment areas that neither
received an attainment date extension beyond 1982 nor received a notice of
SIP deficiencies ("SIP calls"), States were not required to cover sources
with emissions less than 100 tons per year, even if the CTG or EPA guidance
contained no applicability size cutoff.
Last Update: 5/16/88
-------
TABLE 1. CUTOFFS FOR GROUP I CT6 CATEGORIES
Source
Category
1. Gasoline Loading
Terminals
2. Gasoline Bulk
Plants
Service Stations-
Stage I
Cutoffs
• None
(a)Storage tanks with less
than 2,000 gal Ions
sl.orage capacity (Ref.
2, p. 5-1).
( b)l:xeinpt ion for bulk
plants with throughputs
of 1 ess than 4,000 gals
per day (Ref 3, p. 1).
(a)Statior.ory gasoline
storage containers of
less than 2,085 liters
(550 gallons) capacity
used exclusively for the
fueling of implements of
husbandry, provided the
containers are equipped
with submerged fill
pipes (Ref. 4, p. 29).
(b)<7,580 liters (2,000
gallons) capacity
storage tanks in place
before 1/1/79 (Ref. 4,
P. 29).
(c)<948 liters (250 gal-
lons) capacity storage
tanks in place after
12/31/78 (Ref. 4, p.29).
Comments
Terminals are defined as >76,000 liters (20,000
gallons)/day throughput.
¦Bulk plants are defined as _<76,000 liters
(20,000 gal Ions)/day throughput.
References
1
2, 3
4, 5
-------
TABLE 1. CUTOFFS FOR GROUP I CTG CATEGORIES (continued)
Source
Category
Cutof fs
(d)Exemptions for service
station tanks with
throughputs of no more
than 10,000 gals/month
or 120,000 gals/year
(Ref. 5, p. 2).
Comments
References
4. Fixed Roof Petro-
leum Tanks
(a)<150,000 liters (10,000
gallons) storage
capacity of volatile
petrolpi'in liquids (grea-
ter than 10.5kPa TVP)
(Ref. 6, p. 6-1).
(b)<1,600,000 liters
(420,000 gal Ions)
storage capacity of
crude oil and
condensate prior to
lease custody transfer
(Ref. 6, p. 6-2).
•Does not apply to storage vessels equipped with
external floating roofs before 1/1/79
•Does not apply to horizontal, underground
storage tanks storing JP-4 jet fuel (Ref. 7,
p. 2).
6, 7
5. Miscellaneous Re-
finery Sources
(Vacuum Producing
Systems, Wastewater
Separators, and
Process Unit Turn-
arounds)
•None for vacuum producing
systems and process unit
turnarounds.
•<200 gal/day for waste-
water separators (Ref. 4,
p. A-68)
•CTG recommends case-by-case addressing of in-
stances In which control may not be justified
(Ref. 8, p. 6-1).
4, 8
6. Cutback Asphalt
•None (see comment)
•If a State chooses a 100 ton per year cutoff,
the State must consider all State, local, and
private use In an area for which the control
strategy demonstration is developed (Ref. 10,
P. 6).
9, 10, 11
-------
TAIU.E 1. cuiorrs FOR GROUP I CTG CATEGORIES (continued)
Sou rce
Category
Cutoffs
Comments
References
6. Cutback Asphalt
(continued)
•Use of cutback asphalt is approvable under the
following circumstances: (1) where it can
be demonstrated that long-life stockpiling
is necessary, (2) where the asphalt is to be
used solely as a penetrating prime coat,
(3) months during the year where temperatures
do not linger above 50°F for periods of time
adequate for emulsified asphalt application
and setting, and (4) where it can be demon-
strated that no VOC emissions will occur from
the use of the cutback (Ref. 11, pp. 2,3).
7. Sol vent Metal
Cleaning
(a) In urban nonattainment
areas, open top vapor
degreasers with an
open area of less than
1 from equipment
standards (Ref. 12,
p. 7-4) and conveyo-
rized degreasers with
less than 2.0 of
air/vapor interface
from requirement of a
major control device
(e„g., carbon adsor-
ber) (Ref. 12, p.
3-34).
(b) In rural nonattainment
areas, all cold clean-
ers can be exempted
and open top vapor or
conveyorized degreas-
ing operations at one
plant location where
emissions are 100 tons
•No size cutoffs from operational standards
•Volatility of solvent is used to require grea-
ter control 1n cold cleaners for the same con-
trol techniques (Ref. 12, p. 3-31).
•Operating and equipment requirement exemp-
tions for cold cleaners with remote solvent
reservoirs; no other exemptions for cold
cleaners 1n urban non-attainment areas (Ref.
13, p. 1).
12, 13, 14
-------
rAliLE 1. CUTOFFS FOR GROUP I CTG CATEGORIES (concluded)
Source
Category
7. Solvent Metal
Cleaning
(continued)
Cutoffs
or less on a faciIity-
wide basis based on
annual solvent pur-
chase records can be
exempted (Ref. 14,
P. 1).
Comments
References
8. Can Coating
•None
15
9. Metal Coils
•None
15
10. Fabrics
•None
15
11. Paper
•None
15
12. Automobile and
Light-Duty Trucks
•None
15
13. Metal Furniture
•None
16
14. Magnet Wire
•None
17
15. Large Appliances
•None
•Quick drying lacquers used to repair scratches
and nicks that occur during assembly are
exempt from meeting any emission limits
(Ref. 18, p. 1-2).
18
-------
TABLE 2. CUTOFFS FOR GROUP II CTG CATEGORIES
Source
Category
1. Leak from Petro-
leum Ref i neri es
Cutoffs
•Leaks of concentrations
less than or equal to
10,000 ppm (Ref. 19, p.
6-1).
Comments
•No cutoff for petroleum refinery size; applies
to all refineries.
•Not intended to affect facilities that recycle
waste oil (Ref. 20, p. 13).
References
19, 20
2. Miscellaneous Metal
Part s
• None
•This regulation is not intended to cover sur-
face coating of the following metal parts and
products: (1) automobile and light-duty
trucks, (2) metal cans, (3) flat metal sheets
and strips in the form of rolls or coils,
(4) magnet wire for use in electrical machin-
ery, (5) metal furniture, (6) large appli-
ances, (7) exterior of planes, (0) automobile
refinishing, (9) customized topcoating of
automobiles and trucks, if production is less
than 35 vehicles per day, and (10) exterior of
marine vessels (Ref. 20, pp. 28 and 29).
20, 21
3. FlatWood Paneling
•None
•Does not apply to the manufacture of exterior
siding, tlleboard, or particleboard used as a
furniture component (Ref. 20, p. 49).
20, 22
4. Synthesized Pharma-
ceutical Products
•<15 lbs/day; for each
vent from reactors,
distillation opera-
tions, crystal 11 zers,
centrifuges, and va-
cuum dryers (Ref. 23,
p. 1-5).
•Recommends cutoffs If case-by-case approach
is not practical (Ref. 23, p. 1-5).
•Requirement for air dryers and production
equipment exhaust systems differ at 330 lb/
day (Ref. 23, p. 1-6).
•Does not cover fermentation, extraction of
organic chemicals from vegetable materials or
animal tissues, and formulation and packaging
of the products (Ref. 20, p. 61).
20, 23
-------
TABLE 2. GROUP II CTG CATEGORIES (continued)
Source
Category
Cutof fs
Comments
References
5. Rubber Tire Mfg.
•None
•Does not apply to the production of specialty
tires for antique or other vehicles when pro-
duced on an irregular basis or with short
production runs only if these tires are pro-
duced on equipment separate from normal pro-
duction lines for passenger type tires (Ref.
20, p. 74).
20,
24
6. External Floating
Roof Petroleum
Tanks
(a) <150,000 1i ters
740,000 gal Ions ) of
storage capacity
(Ref. 25, p. 5-1).
(b) <1,600,000 1 i ters
(420,000 gal Ions)
storage capacity used
to store produced
crude oil and conden-
sate prior to custody
transfer (Ref. 25,
p. 5-3).
•Does not apply to fixed roof tanks with or
without internal floating roofs, or to small
production tanks (Ref. 25, p. 1-2).
•Does not apply to tanks with a metallic-type
shoe seal In a welded tank which has a secon-
dary seal from the top of the shoe seal to the
tank wall or external floating roof tanks
storing waxy, heavy pour crudes (Ref. 25,
p. 5-3).
•Does not apply to petroleum liquid storage
vessels: (1) that contain petroleum liquid
with a true vapor pressure of less than 10.5
kPa (1.5 psla), and (2) containing petroleum
liquid with a true vapor pressure less than
27.6 kPA (4.0 psia) that are of welded con-
struction and presently possess a metallic-
type shoe seal, a liquid-mounted foam seal, a
liquid-mounted liquid filled type seal, or
other approved closure device of demonstrated
equivalence (Ref. 20, p. 105).
20,
25
-------
TABLE 2. CUTOFFS FOR GROUP II CTG CATEGORIES (concluded)
Source
Category
Cutoffs
Comments
References
6. External Floating
Roof Petroleum
Tanks (continued)
?Does not apply to horizontal underground
storage tanks storing JP-4 jet fuel (Ref. 25,
P. 2.)
7. Graphic Arts
•<100 lons/yr (Ref. 20,
P. 91).
20, 26
8. Perchloroethylene
Dry Cleaning
• None
•Adsorbers are not required where there is
inadequate space to accommodate them or
where there is no way to desorb them. Other
hardships may be found to exclude plants
from using adsorbers (Ref. 27, p. 1-4).
•Adsorbers are also not required at coin-
operated facilities (Ref. 20, p. 118).
20, 27
9. Gasoline Tank
Trucks and Vapor
Col lection
System Leaks
• None
•The affected facilities are (1) gasoline tank
trucks that are equipped for vapor collection
and (2) the vapor collection systems at bulk
terminals, bulk plants, and service stations
that are equipped with vapor balance and/or
vapor processing systems (Ref. 28, p. 2).
28
-------
TABLE 3. CUTOFFS FOR GROUP III CTG CATEGORIES
Source
Category
Cutoffs
Comments
References
1. Polymer Manu-
facturi ng
•Approximately 1,000 tons
of 1i ght 1iquid and
gaseous VOC processed
(see comment).
•Provides guidelines to States to calculate
uncontrolled emission rates below which RACT
may be unreasonable and States could consider
the exemption of plants with uncontrolled
emissions at or below these emission levels
(Ref. 29, p. 4-1).
29
2. SOCMI and Polymer
Mfg. Equipment
Leaks
•Leaks of concentrations
less than 10,000 ppin
(Ref. 30, p. 3-2).
•Small process units may he exempted from
implementing routine leak detection and repair
programs on the basis of cost effectiveness
for these small units (Ref. 30, p. 4-1).
•Process units processing only heavy liquid
VOC or processing only non-VOC and equipment
operating under vacuum may also be exempted
(Ref. 30, p. 4-1).
30
3. Large Petroleum
Dry Cleaners
•Does not apply to petro-
leum solvent dry cleaning
facilities that consume
less than 123,000 liters
(32,500 gal Ions) of
petroleum solvent
annually (Ref. 31,
P. E-2).
31
4. Air Oxidation
Processes - SOCMI
•Facilities having a total
resources effectiveness
(TRE) index value greater
than one (1) would not be
required to meet RACT
(Ref. 32, p. 4-2).
32
5. Equipment Leaks
from Natural Gas/
Gasoline Processing
Plants
(a)Leaks with VOC concen-
trations less than
10,000 ppm
•Does not apply to equipment operating under
vacuum and to equipment in heavy liquid
service (Ref. 33, p. 4-2).
33
-------
TABLE 3. CUTOFFS FUR GROUP III CTG CATEGORIES (concluded)
Source
Category
Cutoffs
Comments
References
5. Equipment Leaks
from Natural Gas/
Gasoline Processing
Plants (continued)
(b)States may consider
exempting non-complex
gas plants that have
design throughputs of
less than 10 million
srfd (Ref. 33, p.
3-22)
(c )RACT should apply
only to equipment
containing or contac-
ting a process stream
with a VOC concentra-
tion of 1.0 percent
by weight or more
(Ref. 33, p. 4-2).
•Does not apply to wet gas service reciproca-
ting compressors that do not have a VOC
control device (Ref. 33, p. 4-2).
-------
REFERENCES
1. Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals.
EPA-450/2-77-026. U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards. October 1977. OAQPS No. 1.2-082.
2. Control of Volatile Organic Emissions from Bulk Gasoline Plants.
EPA-450/2-77-035. U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. December 1977. OAQPS No. 1.2-085.
3. Correspondence. W. C. Barber, Director, OAQPS, EPA, to Hon. L. Gudger,
House of Representatives. November 13, 1978.
4. Regulatory Guidance for Control of Volatile Organic Compound Emissions
from 15 Categories of Stationary Sources. EPA-905/2-78-001. U.S.
Environmental Protection Agency, Region V, Air and Hazardous Materials
Division. April 1978.
5. Memorandum. Richard G. Rhoads, Director, CPDD, EPA, to Director, Air and
Hazardous Materials Division, Regions I-X. Evaluation of 10,000 gals/month
Throughput Exemptions for Petroleum Marketing Operations. August 17, 1979.
6. Control of Volatile Organic Emissions from Storage of Petroleum Liquids
in Fixed-Roof Tanks. EPA-450/2-77-036. U. S. Environmental Protection
Agency. Office of Air Quality Planning and Standards. December 1977.
OAQPS No. 1.2-089.
7. Memorandum. B. Polglase, Technical Guidance Section, EPA, to G. T. Helms,
Chief, Control Programs Operation Branch, EPA. Applicability of Fuel
Storage Regulations to JP-4 Jet Fuel. December 23, 1981.
8. Control of Refinery Vacuum Producing Systems, Wastewater Separators
and Process Unit Turnarounds. EPA-450/2-77-025. U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards.
October 1977. OAQPS No. 1.2-081.
9. Control of Volatile Organic Compounds from Use of Cutback Asphalt.
EPA-450/2-77-037. U.S. Environmental Protection Agency, Office of
Air Ouality Planning and Standards. December 1977. OAQPS No. 1.2-090.
10. Memorandum. R. G. Rhoads, Director, CPDD, EPA, to Director, Air and
Hazardous Materials Division, Regions I-X. Cutback Asphalt VOC Regulation.
March 6, 1979.
11. Memorandum. R. G. Rhoads, Director, CPDD, EPA, to Director, Air and
Hazardous Materials Division, Regions I-X. Cutback Asphalt - Acceptable
RACT Regulation. December 19, 1978.
12. Control of Volatile Organic Emissions from Solvent Metal Cleaning.
EPA-450/2-77-022. U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards. November 1977.
-------
13. Memorandum. R. G. Rhoads, Director, CPDD, EPA, to Director, Air and
Hazardous Materials Division, Regions I-X. Exemption for Cold Cleaner
Degreasers. July 2, 1980.
14. Memorandum. R. G. Rhoads, Director, CPDD, EPA, to Director, Air and
Hazardous Materials Division, Regions I, 111-X, and Director, Environ-
mental Programs Division, Region II. Clarification of Degreasing Regu-
lation Requirements. September 7, 1978.
15. Control of Volatile Organic Emissions from Existing Stationary Sources
- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automo-
biles, and Lignt-Duty Trucks. EPA-450/2-77-008. U.S. Environmental
Protection Agencv, Office of Air Quality Planning and Standards. May
1977. OAQPS No. 1.2-073.
16. Control of Volatile Organic Emissions from Existing Stationary Sources
- Volume III: Surface Coating of Metal Furniture. EPA-450/2-77-032.
U.S. Environmental Protection Agency, Office of Air Quality Planning and
Standards. December 1977. OAQPS No. 1.2-086.
17. Control of Volatile Organic Emissions from Existing Stationary Sources
- Volume IV: Surface Coating for Insulation of Magnet Wire. EPA-450/
2-77-033. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. Decent>er 1977. OAQPS No. 1.2-087.
18. Control of Volatile Organic Emissions from Existing Stationary Sources
- Volume V: Surface Coating of Large Appliances. EPA 450/2-77-034.
U.S. Environmental Protection Agency, Office of Planning and Standards.
December 1977. 0A0PS No. 1.2-088.
19. Control of Volatile Organic Leaks from Petroleum Refinery Equipment.
EPA 450/2-78-036. U.S. Environmental Protection Agency, Office of
Air Quality Planning ana Standards. June 1978. OAQPS No. 1.2-111.
20. Guidance to State and Local Agencies in Preparing Regulations to Control
Volatile Organic Compounds from Ten Stationary Source Categories.
EPA-450/2-79-004, U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. September 1979.
21. Control of Volatile Organic Emissions from Existing Stationary Sources-
Volume VI: Surface Coating of Miscellaneous Parts and Products. EPA-
450/2-78-015. U.S. Environmental Protection Agency, Office of Air Quality
Planning ana S'snaaras. June 1978. OAQPS No. 1.2-101.
22. Control of Volatile Organic Emissions from Existing Stationary Sources-
Volume VII: Factory Surface Coating of Flat Wood Paneling. EPA-450/2-
78-032. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. June 1978- OAQPS No. 1.2-112.
23. Control of Volatile Organic Emissions from Manufacture of Synthesized
Pharmaceutical Products. EPA-450/2-78-029. U.S. Environmental Protec-
tion Agency, Office of Air Quality Planning and Standards. December 1978.
OAQPS No. 1.2-105.
-------
24. Control of Volatile Organic Emissions from Manufacture of Pneumatic
Rubber Tires. EPA-450/2-78-030. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. December 1978. QAQPS
No. 1.2-106.
25. Control of Volatile Organic Emissions from Petroleum Liquid Storage in
External Floating Roof Tanks. EPA-450/2-78-047. U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards. December
1978. OAQPS No. 1.2-116.
26. Control of Volatile Organic Compounds from Existing Stationary Sources-
Volume VIII: Graphic Arts - Rotogravure and Flexography. EPA-450/2-
78-033. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards. December 1978. OAQPS No. 1.2-109.
27. Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning
Systems: EPA-450/2-78-050. U.S. Environmental Protection Agency, Office
of Air Quality Planning ana Standards. December 1978. OAQPS No. 1.2-117.
28. Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks
and Vapor Collection Systems. EPA-450/2-78-051. U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards. December
1978. OAQPS No. 1.2-119,
29. Control of Volatile Organic Compound Emissions from Manufacture of
High-Density Polyethylene, Polypropylene, and Polystyrene Resins.
EPA-450/3-83-008. U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. November 1983.
30. Control of Volatile Organic Compound Leaks from Synthetic Organic Chemi-
cal and Polymer Manufacturing Equipment. EPA-450/3-83-006. U.S. Envi-
ronmental Protection Agency, Office of Air Quality Planning and Standards.
March 1984.
31. Control of Volatile Organic Compound Emissions from Large Petroleum Dry
Cleaners. EPA-450/3-82-009. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. September 1982.
32. Control of Volatile Organic Compound Emissions from Air Oxidation
Processes in Synthetic Organic Chemical Manufacturing Industry. EPA-
450/3-84-015. U.S. Environmental Protection Agency. December 1984.
33. Control of Volatile Organic Compound Equipment Leaks from Natural
Gas/Gasoline Processing Plants. EPA-450/3-83-007. U.S. Environmental
Protection Agency. December 1983.
-------
ATTACHMENT 2
EXAMPLE 5% RULE CALCULATION
-------
EXAMPLE OFAM APPLICATION OF THE 5 PERCENT EQUIVALENCY RULE
State "X" was in the process of developing volatile organic compound
(VOC) regulations for the "Metal Furniture" control technique guideline
(CTG) category.
An analysis of their emission inventory for their ozone nonattainment
area disclosed the following with regards to metal furniture plant
potential emissions.
(81% Overall Control Efficiency)
Pre-control
(Potential)
Post Control
(CTG Allowable)
Post Control
(St. Rec. Allowable)
Plant "A"
Plant "B"
Plant "C"
Plant "D"
Plant "E"
100 t/yr
300 t/yr
18.5 t/yr
80 t/yr
90 t/yr
19
57
3.5
15.2
17.1
t/yr
t/yr
t/yr
t/yr
t/yr
19
57
18.5
15.2
17.1
t/yr
t/yr
t/yr
t/yr
t/yr
Total
588.5 t/yr
111.8 t/yr
126.8 t/yr
The cutpoint recommended by EPA for the metal furniture source
category was a VOC emissions level of 10 tons per year potential. The
State was considering a cutpoint of 25 tons per year potential in order
to provide relief to Plant "C". It was intended to show that with a 25
ton/yr cutoff, allowable emissions would be within 5 percent of potential
emissions by applying a 10 ton/yr cutoff.
An evaluation of the various plant potential emissions (assuming 90%
capture efficiency and 90S control) indicated that post control (CTG)
allowable VOC emissions (with a 10 ton per year cutoff) would be 111.8
tons/yr.
Post control allowable VOC emissions (with the State's recommended
25 ton per year cutoff) would be 126.8 tons/yr.
The difference in post control allowable emissions from the metal
furniture source category would be 126.8 - 111.8 = 15.0 tons/yr.
15
111.8 x 100 = 13.4 percent
Therefore, allowable emissions with a 25 tons per year cutoff would
not be within 5 percent of allowable emissions with a 10 ton per year cutoff;
thus, the 25 ton/yr cutoff would not be acceptable.
-------
ATTACHMENT 3
VOC CONVERSION CALCULATIONS: COATINGS
-------
VOC CONVERSION CALCULATIONS:
COATINGS
OZONE AND CO PROGRAMS BRANCH
OFFICE OF AIR QUALITY PLANNING S STANDARDS
FEBRUARY, 19BB
-------
COMPARISON OF VOC REGULATION FORMATS
#VOC/GAL COATING vs #VOC/GAL SOLIDS
EXAMPLE CONVERSION
GIVEN: COATING OF'3.0 #VOC/GAL COATING (LESS WATER)
VOC DENSITY 7.36 //VOC/GAL
PROBLEM: CONVERT COATING TO //VOC/GAL SOLIDS
STEP #1— WHAT'S VOLUME OF VOC IN 1 GAL OF COATING?
3.0#V0C * 1 GAL VOC = 0,408 GAL VOC
GAL COAT 7.36# VOC GAL COATING
STEP #2— WHAT'S THE VOL OF SOLIDS IN 1 GAL COATING ?
1 GAL COATING -VOL VOC = VOL SOLIDS
1 - 0.408 = 0.592 GAL SOLIDS
STEP#3— HOW MANY GAL OF COATING DOES IT TAKE TO GET
A GAL OF SOLIDS ? (INVERSE OF STEP #2)
1 GAL COAT = 1.689 GAL COATING
0.592 GAL SOLIDS GAL SOLIDS
STEP#4— CONVERT 3.0# VOC/GAL COATING TO #VOC/GAL SOLIDS
3.0# VOC * 1.689 GAL COAT = 5.07# VOC
GAL COAT GAL SOLIDS GAL SOLIDS
ANSWER: 3.0# VOC/GAL - 5.07# VOC/GAL SOLIDS
OZONE/ CO BRANCH
G.T. HELMS
-------
COMPARISON OF VOC REGULATION FORMATS
#VOC/GAL COATING vs #VOC/GAL SOLIDS
FOR DENSITY=7.36jll
X
#VOC/GAL OF COATING (LESS WATER)
OZONE/ CO BRANCH
G.T. HELMS
12/24/87
fifinMOTiftiw
-------
1/28/S8' GTH
PROGRAM TO COWERT #VOC/GAL OF COATING TO
#VOC/GAL SOLIDS ?< #VOC/#SOLIDS
#VOC/GAL COATING
#VOC/GAL SOLIDS
#VQC/#SQLIDS
0
4
6
a
o
2. 4
2.6
2.8
3. 0
"T* ^
3. 4
3.6
3.8
4. 0
4.2
4.4
4.6
4.8
5.0
5.5
5.6
5.7
5.8
5.9
6.0
6. 1
6. 2
6.3
6.4
6.5
6.6
6.7
6. 3
6.9
7. 0
7. 1
4
4
4
7
0
4
7
1
6
0
5
1
7
_i
6. 3
7.0
7.9
8. 8
9.8
10.9
12.3
13.8
15. 6
21 . 8
23. 4
25. 3
27. 4
29. 7
-•2. zi
35. 6
39. 3
43. 7
4°. 1
55. 6
63. 9
~ 4. 7
89 . 1
11':-. 4
L 4 3 . i
:o l .
0. 1
0. 1
0. 1
0. 1
0. 1
0.2
0. 2
0. 2
0. 3
0. 3
0. 3
0
0
0
0
0
0,
0
0.
0,
1,
1.
1,
1,
1.
1.
3. 1
3.5
4.0
4. 7
ASSUMES VOC DENSITY = 7.3o ttVOC/GAL
SOLIDS DENSITY = 16.0 tt/'GAL
-------
2 REM PROGRAM CALLED "SOLIDCALCULATE"
17
20
10 REM PROGRAM
15 LF'RINT "
RINT
lo LPRINT"
LPRINT "
LPRINT "
LPRINT "
LPRINT
FOR X = 1 TO 5
Y=X/7.36
Z=l-Y
W=l/Z
ANS=X*W
LBSOL=ANS/16!
REM LPRINT USING
REM
REM
TO CALCULATE VQC
30LIDS
1/2S/88 GTH":L
PROGRAM TO CONVERT #VOC/GAL OF COATING TO"
#VOC/GAL COATING
#VOC/GAL SOLIDS
#VOC/#SOLIDS"
50
100
200
300
400
450
475
477
478
500
3 00
L 000
, 005
1200
1300
1400
1425
1450
1500
1600
1300
STEP .Z
FORMAT PRINTS OUT ANSWERS WITH
ALSO SKIPS SPACES PER ALL THE #############'
SEE PAGE 7-197 OF GUI-BASIC MANUAL
ONE
3
DICIMAL PLACE
LPRINT USING "##############.; X ;ANS:LBSOL
NEXT X
FOR X=5.5 TO 7.36 STEP .1
Y=X/7.36
Z = 1 - Y
W= 1 / Z
ANS=X*W
REM DENSITY OF SOLIDS IS 16 #VOC/GAL
LBSOL=ANS/16!
LPRINT USING "##############.#":X;ANSsLBSOL
NEXT X
LPRINT:LPRINT:LPRINT "
1900 LPRINT:LPRINT
1950 LPRINT"
ASSUMES VOC DENSITY = 7.36 ttVOC/GAL"
SOLIDS DENSITY = 16.0 #/GAL"
-------
ATTACHMENT 4
TEST METHODS OR PROCEDURES
FOR GROUP I, II, AND III CTG'S
-------
ATTACHMENT TO MEMO FROM DARRVL TYLER, EPA/OAQPS, btPltMBtR 14, 1984
Table I
TEST METHODS OK PROCEDURES FOR GROUP I CTGS
Industry
Cans, Coils, Paper, Fabric, and
Automobiles and Light-Duty
T rucks
Metal Furniture
Magnetic Wire Coating
Large Appliance
CTG
Document Number
EiPA-450/2-77-008
EPA-450/2-77-032
EPA-4t>0/2-7 7-033
tPA-450/2-77-034
Applicable
Control Options
Low solvent
coatings
Add-onl
Low solvent
coatings
Add-on 1
Add-on1
Low solvent
coatings
Add-on 1
Recommended Method(s) and
Document(s) Citiny
Test Method
Method 24, 4U CFR Part 60
Document
May Be
Ordered From
Method 2b, 40 CFR Part 60 or
methods in "Measurement of
VoIati 1 Organic Compounds,"
EPA 4b0/2-78-041
(CTG pp.b-1 to 5-5)
Method 24, 40 CFR Part 60
Method 25, 40 CFR Part 60 or
methods in "Measurement of
Volatile Organic Compounds,"
EPA 450/2-78-041
Method 25, 40 CFR Part 60 or
methods in "Measurement of
Volatile Organic Compounds,"
EPA 450/2-78-041
(CTG pp. 5-1 to 5-4)
Method 24, 40 CFR Part 60
Method 25, 40 CFR Part 60 or
methods in "Measurement ot
Volatile Organic Compounds,"
EPA 4bU/2-78-041
GPO?
GPO7
NTIS2
NTIS^
GPO7
GPO7
NTIS2
GPO?
NT1S2
NTIS?
GPO?
GPO7
NTIS?
-------
Iat>le 1 (cont. in tied)
fLb r Mi llions OK I'KOCEDIIHLS I OK (il I CHiS
I 11,
Document. Number
l.l'A- 1!)0/l' -11
EI»A-4r»ll/2-7/-03b
Design Criteria
Document (DID)
tl'A-4'j0/i?-y/-0:i6
App I icah I e
Control Options
Add on'
Vapor ISalaiice
System'' tqii iii-
men t Specifica-
t ions and Opera-
ting Procedures
r«jij i |niioiiL Spec I -
licat ions ami
Operating Pro-
cedures Vapor
Hal mice System''
I:c|ti ipiiient Speci-
t i Cd11ons and
Ma inLenanee
lU'ipi 11 cincnt s
InternaI
Moating Wool,J
Keconmiended Method(s) and
DocunienL( s) Citing
lest Method
Document.
May Hi.*
Ordered I mm
'10 Cl'-H (iO.'jOJ "lest Methods
and Procedures" , Methods ifbA ,
Z'M, ^1$ (il'O^
leak Ies t s--Mon i Lor my During
transfer (see tank truck ClLi)
L(|iii|Hue111 Inspection,
tr« pp. 6-3 nrI
Leak lests--Monitoriny During
Iransfer (see tank truck CfG)
l(|inpinent Inspection,
DCD pp. 3-b KSL'D^
leak Tests--Monitoring During
transfer (see tank truck CTG)
Clli pp.6-2; NI I
Add-on'
Method 21j. -10 CI~K Part 60
L.I'O-'
-------
|jy 1-3
Table I (continued)
TEST METHODS OR PROCEDURES FOR GROUP I CTGS
Industry _
Peiroleum Refineries
Vacuum Producing Systems, Waste-
water Separators and Process
Unit turnaround
'Cutback Aspha I L
*Deyreas iny
CTG
Document Member
EPA-4t>0/if - /7-02'j
EPA-4MI/2- //-UJ/
EPA-4bO/i?-7/-022
ApplicabIe
Con t^roj Options
Recommended Method(s) and
Document(s) Citing
Test Method
Various Equipment (!f(i pp. b-2
Specifications and
Opei'iit 11nj Procedures
Water Emulsion
Emulsion Solvent
Content
Equipment Speci-
f icat ions and
Operat iinj Pro-
cedures
Direct Observation l>y
Inspector
AS1M DistiIlation
Fes I U-244
C f(i pp. 3-31 , 3-33, 3-35,
and 7-1 to 7-7
Document
M
-------
TtST Millions OK
Industry
Petroleum Kefinery Fugitive
Emissions (LeJi>
EPA-'i'jD/^-ya-ni'j
EPA-450/2-/B-032
EPA-4!>0/2-7H-02lJ
EPA-4!>0/2-"/H-U30
LPA-450/2-/U-DJ3
i:PA-4'jU/2-/tl-047
EPA-450/2- 7M-051I
Tabli? 2
PKOCEDUKLS FOK GKOIIP II CTGS
Appl icahIe
ions
Inspect ion Mom I Lor
ing Md intenauce
low Solvent
COill IIHJS
Add -on'
Low Solvent
Coat Iimjs
Add-on'
Ma iiitenance and
OperaL )on
Add-on'
Add-on I
low Solvent Inks,
lligli Sol ids Inks
Add-on I
In spec tion Ma InLe-
nance Monitoring
Opei 0 <;i>()/
(CIG pp. 6-1) N I 1 S^
or Method .24, 40 CFK Part 60 liPl)'
Method 25, 40 CFR Part 60 GPO'
(CIG pp. 1-2) N11S^
Method 25, 40 CFK Part 60 GPL)?
Mi.'tliod 25, 40 CFK Part 60 GPO?
Method 24 , 40 CFK Part 60 GPi)/
Method 25, 40 CFK Part 60 GPl)/
C Hi pp. 5-1 to 5-4 N I I S^"
C 1(1 pp. (>- 1 t o (»-4 N I I
l>i iilt test Method 2 4 0Al)PS()
-------
Idhle ? (cout inued)
TEST Mt'milllS 0|{ IMIOCCDUIIES 10|{ CKOUI' II CTGS
Hecoiiuiiended Motliori(s) and Document
1'» Applicable Document(s) Citimj May lie
Dociiiiu.'iit Milliliter tonlroj Opi ions les^ Method Ordered fr
•i i
LI'A-4!»0/?- I I'ressure-Vacuuii MeLhod 21, 41) Cl:lt 60, or
lest ('.I(i, Appendix 1$
Inspection, Mom- (J I ti-Append i x li -1 eak Tests
toi imj, Maintenance lor Monltorlmj Uurimj
loading NIIS^
-------
laDle J. Fl'SI Methods or Procedures tor (irou|t III CTG's
Document
Wecouimended Method(s) and May lit?
Industry
CTG
Document Number
Appl icahI e
Control Opt ions
Document(s) Citimj
Tost Method
Ordered
I run
Large Petroleum
Dry Cleaners
EPA-41)0/3-112-00'.)
Operat ion <1 it>I
M.i intenance
C li;, Appendix E
HNS?
Add-on
40 CI li Part 60,
Method 2 b
GI'O"/
Natural GdS/Gasoline
Process iiuj PldiiLs
SOCMI-Fuyi tive
EPA-4bO/J-UJ-00/
EPA-4b0/3-U3-006
Manufacture of
IIi«jti Density Poly-
ethylene Polypropy-
lene and Polystyrene EPA-4bO/3-83-OOtl
Inspect ion
Mon i tor in
-------
Footnotes
1. Add-on: Incineration, carbon adsorbers, refrigeration, refrigeration/compression/absorption, etc.
2. Order by document number from the National Technical Information Service, !>2Hb Port Royal Road,
S|»ringf ield, VA 22161 (nominal fee required).
3. Order from U.S. I:l»A, Office ol Air (Juality Planning and Standards, Imission Standards and Engineeriny Division,
Chemical and Petroleum Dranch, Mail Drop 13, Research Triangle I'ark , N. C. 27/11. Document Title: "Design Criteria lot
Stage I Vapor Control Systems Gasoline Service Stations", November 10
4. Visual inspection except tor leaks.
5. Visual uiSjiecL ion only.
6. Order rrom: O.S. tl'A, Office of Air l)ualily I'lanning and Standards, Emission Measurement branch, Mail Drop 10,
Research Triangle Park, N. C. 27711. Method Title: "Method 23--Determin.it ion of llulogenated Organics from Stationary
Sources." proposed 4b fit 39766, June II, 19HII.
7. Order from: Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402, Document title.
"Code of Federal Regulations, 40 CIR Protection of fnvironment, Parts 60 to 00."
* Test method currently not included in 40 CFU Part 60.
-------
Taole *cm Sma'. i
Stac:
-------
ATTACHMENT 5
INDEX TO EPA GUIDANCE MEMORANDUMS AND POLICIES
-------
1CGI
Updated - 1/13/S
INDEX
1. 7/08/77 Recarensnded Policy on Control
of Volatile Organic Compounds
2. 8/01/77 Recarmended Policy on Control
of Volatile Organic Ccnpounds, Correction
3. 1/03/78 Attainment/Nonattainment - Status Designations
4. 2/02/78 Implementation of RACT on Hydrocarbon
Stationary Sources
5. 2/24/78 Criteria for Approval of 1979 SIP Revisions
6. 3A6/78 Example Demonstration of Attainment for
Photochemical Oxidants
7. 4/03/78 Stage I Vapor Recovery - Bulk Plants
8. 4/28/78 Develcoment of Regulations for HC RACT frcm
CTG's '
9. 5/19/78 Criteria for Proposing Approval of Revision
to Plans for Nonattairment Areas
10. 6/05/78 Regulations for HC Sources Covered by CTGs
11. 6/13/78 Application of RACT to Point Sources of VOC
in Rural Areas
12. 6/30/78 Vapor Recovery Regulations Required to Meet
RACT Requirements for the 1979 SIP
13. 7/03/78 Internal Offsets for RACT Categories
14. 7/10/78 Procedures for Measuring Volatile Organic
Ccnpounds
15. 8/04/78 Requirement for VOC RACT Regulations in all
Oxidant Nonattainnent Areas
16. 8/16/78 Clarification of Attainment/ttonattainment
Evaluation Guidance
17. 8/23/78 Oxidant Standard
18. 8/24/78 Clarification of EPA Policy on Emissions of
Methyl Chloroform
19. 9/07/78 Clarification of Degreasing Regulation
Requirements
20. 9/11/78 Continuity of SIP Regulations
42 FR 35313
42 FR 38931
Hawkins
Hawkins
Administrator
Rhoads
Barber
Barber
43 FR 21673
Helms
Neligan
Rhoads
Hawkins
Rhoads
Hawkins
Rhoads
Hawkins
Barber
Rhoads
Hawkins
-------
40. 12/29/78
41. 1/16/79
Categorical Compliance Schedules for VDC Sources Rasnic
V^por Recovery Meeting Ouestions
Comments on Auto Industry Proposals
2 CGI
21. 9/18/78
22. 9/29/78
23. 10/06/78 Comments on Auto Industry Proposals Rhoads
24. 10/12/78 Unclassified Counties with Significant VDC Hawkins
Point Source Emissions
25. 10/26/78 Czone Transport Values for SIP Revisions Barber
26. 10/26/78 Definition of Volatile Organic Compounds Helms
27. 10/27/78 Cfcidant Standard Work Group Meeting on 10/19/78 Heim
28. 11/03/78 \blatile Organic Compounds Einissions Inventory Barber
29. 11/03/78 Categorical Compliance Schedule for MX Sources Barber
30. 11/09/78 Clarification of Paper Coating Definition for Rhoads
VLC Sources
31. 11/13/78 Veste Disposal Regulations for \KJC Calcagni
32. 11/13/78 Clarification of RFP for Oxidant Control Barber
Strategies
33. 11/16/78 \tolatile Organic Ccnpound Emissions Reductions Barber
at GM
34. 11/21/78 RACT Cptions for Can Coating Operations Rhoads
35. 12/07/78 Selection of Ox Design Value Rhoads
36. 12/19/78 Cutback Asphalt - Acceptable RACT Regulation Rhoads
37. 12/20/78 Availability of End Seal Ccmpounds for Can Helms
Manufacturing Operations
38. 12/21/78 Reasonable Further Progress Requirements for James
Areas with Difficult Oxidant Problens
39. 12/22/78 Request for Response to Prqposed Compliance Hoftnan
Schedules by the New England States for
Coordinated Air Use Management (NESCADM)
PSD and NSR SIP Revision Submittals Hchman
Continuity of SIP Regulations - Revised Hawkins
Enclosure
42. 1/16/79 New England States for Coordinated Air Use Rhoads
Management (NESCAIM) Compliance Program for VUC
Sources
43.
1/25/79
Consistency in \OC Regulations
Helios
-------
3 CGI
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
2/21/79
3/06/79
3/06/79
3/15/79
4/04/79
4/13/79
5/01/79
5/03/79
5/04/79
5/16/79
5/18/79
5/21/79
5/24/79
5/25/79
6/04/79
6/15/79
6/20/79
7/03/79
8/17/79
8/17/79
determination of Reductions Necessary to Attain
the Ozone Standard
Regulation of Methyl Chloroform (1, 1, 1,
Tricboloroethane) and Methyl Chloride.
Qatback Asphalt VX. Regulations
Ouestions and Answers on VOC Regulations
State Implementation Plans; General Preamble
for Proposed Rulemaking on approval of Plan
Revisions for Nonattairment Areas
Fabric Coating Emission Limits
letter to 3M on Bubbling
Paper Coating Emission Limits
Need for Emission Offsets in Rural O3 Non-
attainrent Areas
Need for Rural Ehission Offset in Approved
State Plans
Implerentation of RFP Requirements
Draft Language - Preambles for SIP Proposals
and Approvals
Evaluation of RACT for an Automobile Assembly
Prime Coating Cperation
Rhoads
Barber
Rhoads
Rslglase
44 FR 20372
Helms
Rhoads
Helms
Rhoads
Rhoads
Barber
Rhoads
Rhoads
Submission of State Air Pennits as SIP Revisions Rhoads
Air Oiality; Clarification of Agency Italicy 44 FR 32042
Concerning Ozone SIP Revisions and Solvent
Reactivities
Baseline Transfer Efficiency for Spray Applica-
tion cf Vater-borne Autorotive Coatings
Modifications to Reconmendations for Solvent
Metal Cleaning
Appropriate Transfer Efficiency for "Waterborne
Equivalence"
Evaluation of 10,000 gals/month throughout
Exemptions for Itetrolem Marketing (Operations
5% Demonstration
Walsh
Rhoads
Rhoads
Rhoads
Rhoads
-------
4CGI
64.
65.
66.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
8/22/79
8/28/79
9/19/79
67. 10/04/79
11/15/79
12/12/79
12/21/79
1/03/80
1/28/80
3/20/80
4/18/80
4/25/80
4/30/80
5/05/80
5/16/80
6/16/80
7/02/80
7/07/80
7/18/80
7/21/80
State Implementation Plans/Revised Schedules Hawkins
for Submitting Reasonably Available Control Tech-
nology Regulation for Stationary Sources of \OC
SIP; General Preamble for Proposed Rulemaking
on Approval of Plan Revisions for Nonattainment
Areas-Supplement
Summary of State Implementation Plan TrtJC
Regulations
Clarification for Final SIP Actions on Asphalt
Regulations
VX Test Methods of Procedures
Exemptions for Degreasers
VDC Regulations Issues
VDC Regulations Issues
State and Regional Agencies Continue to Make
Sericus Errors in Calculating Equivalence with
the RACT PecOTnenidations for Surface Coating
Applicability of \KJC Emissions Guidelines:
General Motors Corporation, North Tarrytown
Assembly Plant
Letter to N.Y. DEC, Pharmaceutical CTG
Solvent Reactivities
fesoline Tank Truck Regulations
Exemption for Cold Cleaner Degreasers
Determination of Capture Efficiency
Letter to Texas Oil Marketers Association
Calculation cf Evaporation Loss fron External
Floating Roof Tanks
44 FR 50371
Pslglase/
Calcagni
Rhoads
Rhoads
Rhoads
Helms
Helms
Salman
New Fugitive Hydrocarbons Emissions Factors for Rhoads
Etetroleum Refineries and Itetrochemical Plants
Gi accone
Compliance Schedules for Low Solvent Technology Rhoads
Programs of the Graphic Arts CTG Category
Williams
Procedure to Calculate Equivalency with the Clti Rhoads
Recommendations for Surface Coating
45 FR 32424
Rhoads
Rhoads
Berry
Rhoads
Williams
84.
7/22/80
Solvent Reactivities List Additions
45 FR 48941
-------
5CGI
85. 7/23/80
86. 7/30/80
87. 7/31/80
88.
89.
90.
91.
92.
93.
94.
95.
96.
98.
99.
100.
101.
102.
8/04/80
8/08/80
8/22/80
8/25/80
8/28/80
9/03/80
10/17/80
10/24/80
10/28/80
97. 11/20/80
11/20/80
11/20/80
11/25/80
11/28/80
12/01/80
Letter to NESCAUM on Tank Trucks Barter
Leaks fro* Gasoline lark Trucks Helms
Applicability of Control Technique Guide- Rhoads
lines (CTGs) to the Autcmobile Manufacturing
Industry
Applicability of Fbper Coating, Fabric Coating, Helms
and Graphic Arts CTG
Request for Confinnation of the Definition of Helms
a 100 Tbn Source as Applied to Controls in the
Gasoline Storage and Marketing Chain
The Use of Remit Conditions to Define Rat en- Rhoads
tial to Onit
Fabric Printing Definition Berry
Issues Concerning WC RACT II Regulations Helms
Development
Miscellaneous Metal Parts and Products CTG Helms
Emission Limits for Coating of Shipping Pails
and Drums
Equivalency Calculations with the CTG Recoi»- Rhoads
mendations for Surface Coating
Set II VJC Regulation Approval
Standards of Performance for New Stationary
Sources: Graphic Arts Industry; Publication
Rotogravure Printing; Proposed Rule and Notice
of Public Hearing
Role of Improved Transfer Efficiency in remon-
strating Compliance with the CTG Reccnmendations
for Surface Coating
Appropriate Transfer Efficiencies for Metal
Furniture and large Appliance Coating
Compliance with MXZ Emission Limitations for
Can Coating Operations
Approval and Pronulgation cf Implementation
Plans; Revised Deadline for Submission of VUC
RACT Regulations for Set II CIG
Appropriate Transfer Efficiencies for Metal
Furniture and large Appliance coating
Revised Seasonal Afterburner Eblicy
Hawkins
45 FR 71537
Rhoads
Rhoads
Hawkins
45 FR 78121
Helms
Barber
-------
6CGI
103. 12/02/80
104. 12/02/80
105. 12/02/80
106. 12/03/80
107. 12/03/80
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
L20.
L21.
122.
L23.
12/24/80
12/30/80
1/16/81
1/22/81
1/28/81
1/28/81
2/03/81
2/06/81
3/13/81
3/24/81
4/03/81
4/06/81
4/17/81
4/23/81
4/24/81
4/29/81
Role c£ Impra/ed Transfer Efficiency in Helms
Demonstrating Compliance with the CIG Reccn*-
mendations for Surface Coating
Cost Effectiveness for RACT - Application to Helms
Leaks fran Petroleum Refinery Equipment
RACT for Specialty Rrinting Operations Rhoads
Set II \OC Regulations Approval Rhoads
Canpliance with UXZ Bnission Limitations for Hawkins
Can Coating Operations
RACT/LAER Efeterminations for Casket Coaters Helms
New Nonattaiment Designations Rhoads
Model Index for Ozone SIPs Calcagni
SIPs, Approval of 82 Ozone Plan for Extension 46 FR 7182
Areas Final Policy
Letter to Denmkoehler Concerning Coating Barber
Specifications
Federal Paint Specifications Via-A-Vis CTG Rarber
Part D Conditional Approvals - Prioritizing Helms
Conditions
Storage Tank Vapor Balance Requirements at TV3.e*"
Synthesized Pharmaceutical Products Manufacture
Facilities
Applicability of Fuel Storage Regulations to Tberk
JP-4 Jet Fuel
Test Methods for the Set I and Set II CTG Tuerk
Source Categories
Clarification of VX "Test Method" Requirements TUerk
\CC Test Methods or Procedures for Group I and Tuerk
Group II CTGs
Internal Surface Coating Bubble for Rhode Island Williams
Criteria for Reviewing State WjC ELibhle Tuerk
Regulations
Letter to Massport on Jet Fuel
NSPS, Ftetroleum Liquid Storage \fessel3f -
Equivalency Da termination
Burr
46 FR 23984
-------
7CGI
124.
125.
4/30/81
5/06/81
126. 7/21/81
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
7/24/81
7/24/81
8/07/81
8/11/81
8/14/81
9/11/81
9/22/81
9/22/81
9/24/81
10/20/81
10/26/81
11/04/81
11/06/81
11/09/81
11/30/81
12/11/81
12/14/81
12/14/81
Status of 1982 Ozone SIP E&ta Base Rhoads
Cost Effectiveness cf Gasoline Tank Truck Tyler
Certification Program
State cf Michigan Stage I Service Station 5% Helms
Determination
Tank Truck Certification Workshop Follow-up Nicholson
Results of the Regional Survey of Studies
Related to RACT Beyond the VGC CTGs Helms
Working Group Meeting - Review of 111(d) Guide- Goodwin
lines to Control Itichloroethylene, Iterchloroetty-
lene, 111 Trichloroe thane Methyl Oil or id e and
Trichlorotri-flouroethane fran Existing Organic
Solvent Cleaners
tercsol Can Mounting Cup Sealant Compounds
Applicability of the Miscellaneous Metal Parts
CTG to the Coating of Electromotive F&rts
Review of PA Group II MOC Regulations
Summary of Group I and II VX) RACT Regulations
Review of Final Group II VXT Regulations for
Massachusetts
Summary of Grcup I \UC Regulations
Compliance Schedules for Auto Assembly
ffcint Shops
VJC Hegulations for the 1982 SIP
Status of State Action on Gtaup III and
Beyond Source Categories
Polic/ on the Use of Conditional Approvals
(Draft)
New Procedures for Review of State Implementa-
tion Plans
Review of Plan Revisions by the Office of
Management and Budget
Fblicy on the Use of Conditional Approvals
Summary of Tank Truck Certification Tests
Letter to George Payne on Can Manufacturing
Helms
Helms
Po lg la se A »'i 11 i ami
Nicholson
lb lgla se/Wi 1 li ans
Vvilliams
46 FR 51366
Helms
Fblglase
Bennett
Bennett
Bennett
Bennett
Ftolglase
Barber
-------
8CGI
145.
2/09/82 Acceptability of Oklahoma's Demonstration Con-
cerning the Surface Coating of Miscellaneous
Metal Parts and Products
146. 2/12/82
161. 4/21/83
162.
163.
164.
165.
166
Acceptability of Oklahoma's Demonstration Con-
cerning the Surface Coating of Miscellaneous
Metal Parts and Products
147. 3/19/82 Approval and Promulgation of Implementation
Plans; San Francisco Bay Area Air Basin Non-
attainment Area Plan (Boiler-Plate for "good
cause")
148. 3/19/82 San Francisco Nonattainment Plan
149. 3/25/82 Clean Air Act Restriction Applying to SIP
Revisions Due 7/1/82
150. 4/08/82 EPA Emissions Trading Policy
151. 4/19/82 \t)Cs from Bakeries
152. 6/18/82 Prime Coating at Chrysler Assembly Plant
153. 8/27/82 Equivalency with the Ferchloroethylene Dry
Cleaning CTG PACT Recommendations
154. 9/07/82 Clarification of Memo Dated May 6, 1981 Truck
Certification Program
155. 9/28/82 Policy on Excess Omissions During Start-uj',
Siutdcwn, Maintenance, and Malfunctions
156. 11/01/82 Errata Sheet for Petroleum Dry Cleaners
157. 1/17/83 Allowable Tank Truck terminal Emission Limits
158. 3/04/83 Review of Illinois Group II VJC Rules
159. 4/04/83 Etaft RACT Determinations
160. 4/15/83 Reynolds Metals - WC Bubble with Long-Iteim
Emissions Averaging
Averaging Time - VOC Equivalence
Compliance Calculations
5/10/83 Graphic Arts - 100 TPY Ibtential Exemption
5/17/83 Guidance for Non-CTG RACT Determinations
6/03/83 Bock Cover Coating
6/06/83 Tank Truck Hatch Covers
6/28/83 Letter to Dow Chemical on Exernpt Solvents
Helms
Helms
47 FR 11866
47 FR 11866
Perry-OGC
Spink
Carb
lyier
Helms
Helms
Bennett
Farmer
Etolglase
Williams/Polgiase
Williams
Helms
Itolglase
Iblglase
Helms
Bolglase
Calcagni
Helms
-------
167. 6/29/83 Exclusion of Exempt Solvents Frcn VJC Calcu-
lations
168. 7/05/83 Reynolds Metal Babble
169. 9/14/83 Allowable Tank Truck Terminal Bnission Limits—
Update of 1/17/83 Memo
170. 9/19/83 Ttest Methods for Gasoline Bulk Terminals
171. 10/12/83 Averaging Times for Compliance
172. 10/20/83 Addition of Dilution Solvents to Rrinting Inks
173. 10/24/83 Solvent Reactivities
174. 10/31/83 Averaging Times for Compliance with \UC
emission Limits
175. 12/05/83 Meeting Report on Long-Teem Averairg for VX
Sources
176. 1/20/84 Averaging Times for Compliance with UXZ Emission
Limits—SIP Revision Policy
177. 1/27/84 Violations of Record Keeping Previsions in
Approved SIPs
178. 2/29/84 Draft PEDCo Report for Surface Coating
Calculations
179. 3/06/84 VjC Equivalency Calculations - Clarification
of Requirements
180. 3/08/84 Letter to Lillquist on Flexible Packaging
181. 3/15/84 Reynolds and Vestvaco Plant Proposed
Ozone SIP Revisions
182. 4/16/84 Letter on WC extend canpliance dates
183. 5/7/84 Ibpcoating and Printy of Urethane Fabric
and Sheets
184. 5/7/84 Exclusion of Vinyl Plasti9ol frcm
WC Compliance Calculations
185. 5/21/84 Confirmation that WC regulations
are required for CIG III
186. 6/19/84 Regional survey - \©C Equivalency
Calculations
187. 6/25/84 Confirmation of Definition cf 100 TPY
Source
Helms
Helms
Eblglase
McLaughlin
Tyler
RDlglase
Federal Registez
Tyler
Fblglase
O'Connor
SSCD
Polglase
Tyler
Cannon
Helms
Rothblatt
Helms
Helms
Tyler
Pslglase
Helms
-------
10CGI
188. 6/25/84
189. 7/30/84
190. 8/28/84
191. 8/29/84
192. 9/11/84
193. 9/14/84
194.
195.
196.
197.
199.
200.
201.
202.
204.
205.
206.
207.
208.
11/07/84
12/06/84
12/21/84
1/09/85
198. 2/04/85
2/11/85
4/02/85
4/23/85
4/23/85
203. 5/20/85
7/22/85
8/15/85
8/27/85
8/29/85
12/16/85
Applicability of CTG III Tyler
Federally Enforceable Itemits Helms
far 100 T?Y non CTG sources
VJC data sheet for suppliers Bnison
of paints and coatings
VUC Policy Rasnic
(Frcm 19 VCC Issue Resolution Process)
Methods to establish daily violations fran Berry
annual use data
VJC test methods or procedures for Group I, Tyler
II, and III CTGs
Connecticut TOC issues Mirphy
Ccmments on WC clarification memo Hagg
Connecticut '^JC issues Helms
Clarification of CTG RACT Reconmendation for Tyler
High-Censity Fblyethylene, polypropylene,
and polystyrene
Stack height in facilities using air stripping Cannon
for groundwater cleaning
Response concerning VOC clarification memo Tyler
B-iission limits for coating of shipping pails Helms
and drums
Consideration of Organisols in VJC Canpliance Bnison
Calculations
Printing on Unsupported Vinyl Film Covered Crumpler
fry CTG
Results of May 3 VOC Meeting SSCD
(t^cm 19 VCC Issue Resolution Rrocess)
Graphic Arts - Aid-On Control Systens Ealton
Fabric Coating - Dip and Impregnator Coating Crunpler
Classification of Benzene as a WC Tyler
Paper Coating RACT Determination Johnson
Baseline Time Reriod for VOC Transfer Efficien- Helms
cy Credits
-------
110GI
209. 1/17/86
210. 1/31/86
212. 4/11/86
Issues #3(e) and #5 of the VX Issue
Resolution Process: Establishing Proof of
V*X Missions Violations, and Bubbles in
Consent Etecrees Resolving Civil Actions
Under Section 113(b) of the Clean Air Act
(Fran 19 VCC Issue Resolution Process)
Responses to TVo \*JC Ouestions Raised by
Regional Offices
(Fran 19 \KX Issue Resolution Processj
Price
211. 2/28/86 Responses to Four \UC Issues Raised by
the Regional Offices and Department of
Justice
(Frcm 19 \OC Issue Resolution Process)
Responses to Five VDC Issues Raised fcy the
Regional Offices and Department of Justice
(Fran 19 VDC Issue Resolution Process)
213. 5/01/86 Exemption of Negligibly Photochenically
Reactive Compounds ty the State of South
Carolina
SSG3
Ehiison
Bnison
lyier
214. 5/16/86 Ccmpliance With \OC Bnission Limitations
for Can Coating Operations
(Fran 19 VOC Issue Resolution Process)
215. 5/22/86
216. 8/04/86
217. 8/07/86
218. .8/07/86
Exemption of Negligibly Fhotochemically
Reactive Compounds fcy the State of South
Carolina
Fblicy on SIP Revisions Requesting Compliance
lite Extensions fcr VCC Sources
&nison
lyier
Misuse by industry of Cost and Cost Effec- Berry
tiveness as a Tbol to Avoid Ccmpliance with
Environmental Regulations
Iblicy on the Availability of I^w-Solvent Potter
Technology Schedules in Clean Air Act
Enforcement Actions
Ratter
219. 9/22/86 Reactivity of Acetylene Hathaway
220. 10/07/86 DOD Directive on TOC Compliance Hitte
221. 10/30/86 Inclusion of Clean-uu Solents in Determining Helns
Applicability to tie 100-Tbn Iter Year Non-CTG
Requirements
-------
12CGI
222. 11/21/86
223. 1/20/87
224. 3/16/87
225. 4/17/87
226. 6/25/87
227. 7/21/87
228. 9/09/87
Early Compliance and Stipulated Penalties in
VDC Enforcement Cases
Determination of Economic Feasibility
November 21, 1986 Memorandum Titled "Early
Compliance and Stipulated Penalties in
\*DC Enforcement Cases"
Definition of VOC
Emission Cut-Off for Control Technicjues
Guidelines - Volatile Organic Ccnpcund
Sources
Definition of Volatile Organic Compounds
(VOC's)
Alternative Compliance for Graphic Arts
RA.CT
Rasnic/Alushin
Helms
Hitte
Helms
Helms
HeliTE
Tyler
229. 11/04/87
Additional Information Concerning Emission Helms
Cut-Off — 3 Ibs/hr, 15 lbs/day
-------
CGF
Updated - 1/13/8£
Cross Reference Index by Source Category
Category
1) Surface Coating of Cans
2) Surface Coating of Metal
Coils !
3) Surface Coating of Fabrics
4) Surface Coating of Paper
Products
5) Surface Coating of Auto-
mobiles
6) Surface Coating of Metal
Furniture
7) Surface Coating of Magnet
Wire
8) Surface Coating of Large
Appliances
9) Gasoline Terminals
10) Gasoline Bulk Plants
11) Stage I Vapor Recovery
Roof Tanks
Date of
Memo
11/21/78
12/20/78
11/20/80
12/03/80
8/11/81
12/14/81
5/16/86
4/13/79
8/04/80
8/25/80
12/02/80
8/05/85
11/09/78
5/13/79
8/04/80
8/29/85
10/06/78
11/16/78
5/24/79
4/18/80
7/18/80
7/31/80
10/20/81
6/18/82
11/20/80
11/28/80
11/20/80
11/28/80
8/08/80
8/22/80
9/14/83
9/14/83
7/21/81
Originator
Rhoads
Helms
Hawk ins
Hawkins
Helms
Barber
Emison (19 VOC Issue
Helms
Helms
Berry
Rhoads
Crumpler
Rhoads
Helms
Helms
Johnson
Rhoads
Barber
Rhoads
Giaccone
Giaccone
Rhoads
46 FR 51386
Tyler
Rhoads
Helms
Rhoads
Helms
Helms
Rhoads
Polglase
Polglase
Helms
-------
CGF
Cross Reference Index by Source Category (pq. 2)
Category
12) Gasoline Storage in Fixed
Roof Tanks
13) Petroleum Refinery Process
14) Cutback Asphalt
15) Solvent Metal Degreasing
16) Surface Coating of Miscel-
laneous Metal Parts and
Products
17) Flatwood Paneling
18) Pharmaceutical
19) Pneumatic Rubber Tire
20) Vegetable Oil
21) Graphic *Arts
22) Dry Cleaning
Date of
Memo
8/08/80
3/20/80
12/19/78
3/06/79
10/04/79
9/07/78
12/12/79
7/02/80
8/04/80
9/03/80
1/28/81
8/14/81
2/09/82
2/12/82
4/02/85
4/30/80
8/04/80
2/06/81
3/13/81
4/25/80
8/04/80
10/28/80
5/10/83
7/22/85
9/09/87
8/04/80
8/07/81
8/27/82
11/01/82
10/24/83
Originator
Helms
Rhoads
Rhoads
Rhoads
Rhoads
Rhoads
Rhoads
Rhoads
Helms
Helms
Barber
Helms
Helms
Helms
Helms
Giaccone
Helms
Tyler
Tuerk
Rhoads
Helms
Federal Register
Polglase
Dalton
Tyler
Helms
Helms
Helms
Farmer
Federal Register
23) Leaks at Petroleum
Refineries
12/02/80
Helms
-------
CGF
Cross Reference Index by Source Category (dq. 3)
Category
24) External Floating Roof
Tanks
25) Gasoline Tank Trucks
Date of
26) Bubbling
27) Solids Applied/Transfer
Efficiency
Memo
Oriai nator
8/08/80
Helms
3/13/81
Tuerk
4/29/81
Federal Register
6/16/80
Rhoads
7/18/80
Rhoads
7/21/80
Williams
7/30/80
Helms
5/06/81
Tyler
7/24/81
Nicholson
12/14/81
Polglase
9/07/82
Helms
6/06/83
Calcagni
9/19/83
McLaughlin
5/01/79
Rhoads
7/15/79
Walsh
4/17/81
Williams
4/29/81
Tuerk
4/08/82
Spink
4/15/83
Helms
7/05/83
Helms
10/12/83
Tyler
10/31/83
Tyler
12/05/83
Polglase
1/20/84
0•Connor
3/09/84
Tyler
1/22/8 6
Price (19 VOC Issue;
2/28/86
Emison (19 VOC Issu-
6/15/79
Walsh
7/03/79
Rhoads
1/28/80
Salman
5/05/80
Rhoads
8/04/80
Helms
10/17/80
Rhoads
11/20/80
Rhoads
12/02/80
Helms
2/26/81
Salman
3/04/83
Williams/Polglase
6/2 9/83
Helms
2/29/84
Polglase
3/06/84
Tyler
12/16/85
Helms
4/11/86
Emison (19 VOC Issue
-------
CGF
Cross Reference Index bv Source Category (po. 4)
Cateqorv
Date of
Memo
Oriqinator
28) Exempt Solvents
7/08/77
8/24/78
3/06/79
6/04/79
7/22/80
2/26/81
6/28/83
6/29/83
10/24/83
5/01/86
5/22/86
9/22/86
Federal Register
Barber
Barber
Federal Register
Federal Register
Salman
Helms
Helms
Federal Register
Tyler
Tyler
Hathaway
29) Capture Efficiency
7/07/83
Berry
30) Test Methods
31) Beyond Set I and II CTG
11/15/79
3/24/81
4/03/81
4/06/81
(V11/86
7/24/81
11/04/81
12/30/81
8/29/84
1/31/8 6
6/25/87
11/4/87
Rhoads
Tuerk
Tuerk
Tuerk
Emison (19 VOC Isslis
7>/er
Helms
Polglase
Helms
Rasnic (19 VOC Issue
SSCD (19 VOC Issues;
Helms
Helms
32) 111(d)
8/07/81
Goodwin
33) Definition of VOC
10/26/78
8/27/85
4/17/87
7/21/87
Helms
Tyler
Helms
Helms
34) RFP
12/21/78
James
35) 5% Rule
8/17/79
Rhoads
36) Long Ter^i Averaging
10/31/83
12/05/83
1/20/84
3/06/84
Tyler
Polglase
0'Connor
Tyler
37) Jet Fuel
3/13/81
4/21/81
4/24/81
Tuerk
Polglase
Burr
38) Dilution Solvents
10/20/8 3
10/30/86
Berry
Helms
-------
CGF
Cross Reference Index by Source Category (pq. 5)
Category
39) Definition of 100
Ton-Pe r-Year
40) CTG III
41) Afterburners
42) Non-CTG Bakeries
43) High Density Polyethylene,
Polypropylene, and Poly-
styrene
44) Surface Coating of Vinyl-
coated Fabric or Vinyl
Sheets
45) Criteria for Plan Revisions 5/19/78
for Nonattainment Areas
Date of
Memo
9/07/79
8/08/80
8/22/80
5/10/83
6/2 5/84
2/28/86
4/11/86
5/21/84
12/01/80
2/28/86
4/19/82
1/09/86
4/23/86
46) Low Solvent Technology
47) Compliance Date Extension
48) General VOC Issues
49) Recordkeeping/
Reporting
50) Class Al, A2, and
B VOC sources
51) Baseline Year for VOC
Percent Emission Reductions
as per State SIP Regulations
8/07/86
11/21/86
3/16/87
8/07/86
5/20/8 5
1/17/86
4/11/86
1/31/86
2/28/86
Origi nator
Rhoads
Helms
Rhoads
Polglase
He lms
Emison (19 VOC Issue
Emison (19 VOC Issue
Tyler
Barber
Emison (19 VOC Issue
Carb
Tyler
Crumpler
43 FR 21673
Potter
Rasnic/Alushin
Hitte
Potter
SSCD (19 VOC Issues'.
Price (19 VOC Issues
Emison (19 VOC Issue
SSCD (19 VOC Issues)
Emison (19 VOC Issue
-------
CGF
Cross Reference Index by Source Category (dq. 6)
52) Type of Compliance Monitor- 4/11/86
ing When Incineration Is
Used Sporadically
Emison (19 VOC issuer
53) Cost Effectiveness of
controlling voc's
8/04/86
Berry
54) Clean up Solvents
10/30/86
Helms
-------
ATTACHMENT 6
SUMMARIES OF CONTROL TECHNIQUES GUIDELINES (CTG'S)
-------
SUMMARY OF CTG DOCUMENT FOR TANK TRUCK GASOLINE lOAOING TERMINALS
AFFECTED
FACILITIES
Any tank truck loading operations at the primary wholesale outlet
for gasoline which delivers at least 76,000 liter/day (20.000 gal/day).
A facility which delivers under 20,000 gal/day Is covered by the
CTG for bulk plants.
NUMBER OF
AFFECTED
FACILITIES
According to the Bureau of Census, there were 1,325 terminals in
1972. Current estimates are about 1,600 terminals nationwide.
voc
EMISSIONS
NATIONWIDE
Estimated annual emissions are 250,000 Mg/yr (275,000 ron/yr)^14,1^
-nich represent about 0.9 percent of estimated VOC emissions nationwide. I
voc
EMISSION
RANGE ?E3
FACILITY
Without vapor recovery systems, VOC emissions can range from 0.5 to.
1.4 g/1,000 liters of throughout (5 to 12 lb/1,000 gal). For a typicai '
size facility having a througnput of 950,000 liter/day (250,000 gal/day).
VOC emissions are estimated to be 200 Mg/yr (220 ton/yr).
100 TON/YR
SOURCE
SIZE
For an uncontrolled facility with fixed roof tanks, a 133,000 literi
/day (35,000 gal/day) plant would result in VOC emission of 100 ton/yr.
For an uncontrolled facility with floating roof tanks, a 454,000 liter/ <
day (120,000 gal/day) facility would result in VOC emissions of |
100 ton/yr. |
EMISSION
LIMIT
The reconmended emission limit 1s 80 mg/liter (0.67 lb/1,000 gal) 1
of gasoline loaded. This limit Is based on submerged fill and vapor
recovery/control systems. No leaks 1n the vapor collection system
during operation is a requirement.
voc
REDUCTION
PER
FACILITY
|
A minimum control of 87 percent 1s expected for the loading !
facility. !
COSTS
BASIS: 250,000 gal/day facility with active vapor control systems.;
Capital cost: $140,000 - $195,000 j
Annualized cost: $ 20,000 - $ 30,000 1
Cost effectiveness: $120 - $180 per ton VOC |
1
-------
SUMMARY OF CTG DOCUMENT FOR BULK GASOLINE PLANTS
AFFECTED
FACILITIES
A wnolesale gasoline distribution facility which has a maximum
daily througnput of 76,000 liters (20,000 gal) of gasoline.
Facilities which deliver over 20,000 gal/day are covered under
the CTG for terminals. Potentially severe economic harasmo may be
encountered by bulk plants whicn deliver less than 4,000 gal/day.
NUMBER OF
AFrECTED
FACILITIES
There were 23,367 bulk plants in 1972 according to the
Bureau of Census. Current estimates are about 18,000 bulk
gasoline plants nationwide.
VOC
EMISSIONS
NATIONWIDE
Estimated annual emissions are 150,000 Mg/yr (165,000 ton/yr)
[14,151 which represent about 0.6 percent of estimated VOC
emissions nationwide.
voc
EMISSION
RANGE
PER
FACILITY
A facility with three storage tanks would have VOC emissions
aooraximatmg 4.4 kg/day (20 lb/day) plus a range of 0.2 to 3.0 ;/
1,000 liters througnput (2.3 to 25.0 lb/1,000 gal). For a tyoical
size facility having a througnout of 18,900 liter/day (5,000 gal/
day) average VOC emissions are estimated to be 15 Mg/yr (17 ton/yr).
100 TON/YR
SOURCE
SIZE
None.
CTG
EMISSION
LIMIT
Emission limits recommended in terms of equipment specification
alternatives:
1. Submerged fill of outgoing tank trucks.
2. Alternative 1 * vapor balance for incoming transfer.
3. Alternative 2 ~ vaoor balance for outgoing transfer.
VOC
REDUCTION
PER
FACILITY
Emission Reductions
Total Plant
All Transfers
Alternative 1
Alternative 2
Alternative 3
22 percent
54 percent
77 percent
27 percent
64 percent
92 percent
COSTS
3ASIS: 4,000 gal/day throughput using submerged fill
and vapor balance for both incoming and outgoing transfers:.
Capital cost: $4,000 • $10,000
Annualized cost: J 100 - $ 1,200
Cist effectiveness: $9 - $90 per ton VOC
2
-------
SUMMARY OF DOCUMENT FOR GASOLINE SERVICE STATIONS - STAGE I
AFFECTED
FACILITIES
Transfer of gasoline from delivery trucks to service station
storage tanks.
No exemotions were noted in the "Design Criteria for Stage I
Vapor Control Systems."
NUM6S3 >5?
AFFECTED
FACILITIES
Estimated to be 180,000 retail gasoline service stations
nationwide. There are 240,000 other gasoline dispensing outlets.
VOC
EMISSIONS
NATIONWIDE
For transfer of gasoline to service station storage tanks, VOC
emissions estimated to be 400,000 Mg/yr (440,000 ton/yr)^14
wmcn represents about 1.5 percent of estimated VOC emissions
nationwide.
VOC
EMISSION
RANGE PER
FACILITY
Without vapor controls, VOC emissions are estimated to be
1.4 kg/1,000 liters (11.5 lb/1,000 gal) of throughput. For a typical
facility having a throughput Of 151,000 11ter/mo (40,000 gal/mo) VOC
emissions would be 2.5 Mg/yr (2.3 ton/yr) for Stage I.
TOO TON/YR
SOURCE
SIZE
For an uncontrolled facility, a 2,800,000 liter/mo (750,000
gal/mo) throughput results in VOC emissions of 100 ton/yr. Very
few service stations will have this size throughput. The emissions
include both Stage I and Stage II losses.
CTG
EMISSION
LIMIT
Emission limits reccmnended 1n terms of equipment specifications.
Reconmended controls are submerged fill of storage tanks, vaoor balance
between truck and tank, and a leak free truck and vapor transfer system.
VOC
REDUCTION
PER
FACILITY
Stage I control can reduce transfer losses by 95* percent and
total facility losses by 50 percent.
COSTS*
3ASIS: Application of submerged fill and vapor balance to a
service station with three tanks.
Capital cost: $600
Annualized cost: ($200) r,-.
Cost effectiveness: (S110) per ton VOC1- J
* (J—) indicates savings
3
-------
SUMMARY OF CTG DOCUMENT FOR PETROLEUM
LIQUID STORAGE IN FIXED-ROOF TANKS
AFFECTED
FACILITIES
Fixed-roof storage tanks having a capacity greater than 150,000 liters (4C.30C
gal or 950 bbl) and storing petroleum liquids whicn have a true vapor pressure
greater than 10.5 kPa (1.5 psia). Fixed-roof tanks which have capacities less thar.
1,600,000 liters (420,000 gal or 10,000 bbl) used to store produced crude oil arc
condensate prior to lease custody transfer are exempt.
NUMBER OF
AFFECTED
FACILITIES
Estimated for the year 1976 to be 7,300 tanks nationwide.
voc
EMISSIONS
NATIONWIDE
Estimated annual emissions are 560,000 Mg/yr (616,000 ton/yr) wnich reorosert
aoout 2.1 percent of the estimated VOC emissions nationwide. Emissions of VGC fror
fixed-'-oof tanks are 4.7 times that from existing floating roof tantcs, altiougn :ne
total caoacity of fixed-roof tank storage is less.
VOC
EMISSION
RANGE
PER
FACILITY
VOC emission ranges for gasoline or crude oil storage assuming 5 to 20 turn-
overs per year and a true vapor pressure of 13.8 to 69 kPa (2.0 to 10 psia).
5 i z e ^ j Small
M e d i u m
Large
Caoacity (gal)
Dimensions
diam. x ht. (ft)
VOC Emissions
Gasoline (Mg/yr)
(ton/yr)
Crude Oil (Mg/yr)
(ton/yr)
420 x 103
SO x 30
12 - 113
13 - 125
7 - 65
8-72
2.3 x 106
100 x 40
52 - 535
57 - 590
28-311
30 - 340
6.3 x 10s
150 x 48
123 - 1,353
135 - 1,490
68 - 796
75 - 875
100 TON/YR
SOURCE
SIZE
Variable depending on many parameters Including the type and vapor pressure of
the petroleum liquid stored, schedule of tank filling and emotying, and the
geograpnic location of tank* As shown above a medium size tank can easily exceed
100 ton/yr emissions of VOC.
CTG
EMISSION
LIMIT
Emission limits reconmended in terms of equipment specifications: Installation
of internal floating roofs or alternative equivalent control. Types of alternative
controls are not specified in the CTG document.
VOC
REDUCTION
PER
FACILITY
VOC emission reduction of 90+ percent can be achieved by installation of
internal floating roofs.
COSTS'
3ASIS: 55,000 bbl (2,310,000 gal) medium size tank with gasoline or crude oil
with true vaoor pressure range of 14 to 69 kPa (2 to 10 psia). and 5 to 20 turnovers
per year.
Caoital cost: $31,000
Annualized cost: J(70,000) to 2,100
Cost effectiveness: (S123) - S73 per ton VOC
* (S-) indicates savings
4
-------
SUMMARY OF CTG DOCUMENT FOR PROCESSES AT PETROLEUM REFINERIES
AFFECTED
FACILITIES
The affected facilities and operations are:
a. Vacuum producing systems (VPS).
b. Wastewater separators (US).
c. Process unit turnarounds (PUT) - (i.e., shutdown, repair or
inspection, and start up of a process unit).
The CTG provides no exemptions.
NUMBER OF
AFFECTED
FACILITIES
No estimates of the number of individual facilities are available.
There are approximately 235 refineries nationwide.
VOC
EMISSIONS
NATIONWIDE
Estimated annual nationwide emissions from vacuum producing systems
(VPS), wastewater separators (KS), and process unit turnarounds (PUT)
are 730,000 Mq/yr (80C.000 ton/yr) wmcn represent about 2.7 percent of
estimated VOC emissions nationwide. [14]
VOC
EMISSION
RANGE
PER
FACILITY
The estimated average annual VOC emissions from affected facilities
at a oetroleum refinery are 2,560 Mg (2,320 ton). Emission factors usee
for estimating uncontrolled, reactive VOC emissions are:
a. VPS - 145 ( 50 1b/1o3 bbl) refinery througnout.
b. US - 570 kg/10Tiu (200 lb/10. bbl) refinery througnout.
c. PUT - 860 kg/10 m (301 lb/10 bbl) refinery througnput.
100 TON/YR
SOURCE
SIZE
The following annual refinery throughputs will result in 100 ton/yr
uncontrolled VOC emissions from each affected facility type:
a. VPS - 24.6 x lof.ir3 (3.9 x 10® bbl).
b. US - 6.3 x 10?m3 (l.Q x 10° bbl).
c. PUT - 4.2 x 106m3 (0.67x 10° bbl).
CTG
EMISSION
LIMIT
Emission limits recommended in terms of equipment specifications:
a. VPS - incineration of VOC emissions from condensers.
b. WS - covering separator forebays.
c. PUT - combustion of vapor vented from vessels.
voc
REDUCTION
3E?.
FACILITY
Implementing the recontnended controls can reduce VOC emissions by:
a. VPS - 100 percent.
b. US - 95 percent.
c. PUT - 98 percent.
COSTS*
3ASIS: A 15,900 m^/day (2,500 bbl/day) refinery using the
recomnended control equipment.
VPS U S PUT - 10 units
Capital cost -$1,000.' 24 - 52 63 98
Annualized cost SI .000: ( 95) - (89) (310) 26
Cost effectiveness S/ton ; (104) - (96) ( 90) 5
• {%-) indicates savings
5
-------
SUMMARY OF CTG' DOCUMENT FOR CUTBACK ASPHALT
AFFECTED toa'lway construction and maintenance operations using asnhalt liauefier
FACILITIES jwitn petroleum distillates.
NUKoES OF
AFFECTED
FACILITIES
No estimates were obtained.
Yqj. | Estimated annual emissions are 655,000 Mg/yr (720,000 ton/yr). This
MISSIONS j re?resants ADOut 2.4 percent of estimated VOC emissions nationwide.
NAT I ON * I l»E 1
|
VOC EMISSIOf,
RANGE PER
FACILITY
Estimated VOC emissions from cutback aspnalt production are:
a. 0.073 kg/kg (ton/ton) of slow cure aspnalt.
S. Q.209 kg/kg (ton/ton) of medium cure aspnalt.
c. 0.204 kg/kg (ton/ton) of raoid cure aspnalt.
100 TON/YR
SOURCE SIZE
Not generally applicable to this source category since tne main sources
of emissions are the road surfaces where the asphalt is applied.
CTG
EMISSION
LIMIT
Substitute water and nonvolatile esnulsifier for petroleum distillate
blending stock.
VOC
REDUCTION
PER
FACILITY
VOC emission reductions are approximately 100 percent.
COSTS*
3ASIS: The major cost associated with control of VOC is the price
difference between cutback and emulsified asphalt. A price differential
of 5 cent/gallon savings to 1 cent/gallon penalty results in a cost ef-
fectiveness range of ($73) - J15 per ton VOC.
* (S—) indicates savings
6
-------
SUMMARY OF CTG OOCUMENT FOR SOLVENT METAL CLEANING
AFFECTED
FACILITIES
Tnree types bf solvent degreasers are affected:
a. Cold cleaner: batch loaded, nonboiling solvent decrease*.
b. Open top vapor degreaser: batch load, boiling solvent
degreaser.
c. Conveyorized degreaser: continuously loaded, conveyorized
solvent degreaser, either boiling or nonboiling.
2
Open top vapor degreasers smaller than \ m of open area are exempt
from the aoDlication of refrigerated chillers or carbon adsorbers.
Conveyorized degreasers smaller than 2.0 r of air/vapor interface
are exempt from a requirement for a major control device.
Estimates of the number of solvent degreasers nationwide for the
NUMBER OF | year 1974 are:
AFFECTED 1 a. Cola cleaners (CC) - 1 ,220,000.
FACILITIES b. Open toe vapor degreasers (OT) - 21,000.
| c. Conveyorized degreasers (CO) - 3,700.
•
VOC
EMISSIONS
NATIONWIDE
Estimates of annual nationwide emissions are:
a. CC - 380,000 Mg/yr (419,000 ton/yr).
b. OT - 200,000 Mg/yr (221,000 ton/yr)
c. CO • 100.000 Mg/yr (110,000 ton/yr) [14]
which represent about 2.5 percent of estimated VOC emissions nationwide.
VOC
EMISSION
RANGE PER
¦ FACILITY
Averaged emission rates per degreaser:
a. CC - 0.3 Mg/yr (0.3 ton/yr).
b. OT - 10 Mg/yr (11 ton/yr).
c. CO - 27 Mg/yr (30 ton/yr).
100 TON/YR
SOURCE
SIZE
Oata indicate that on an average 10 open top degreasers or 4 con-
veyorized degreasers may emit 100 ton/yr. j
I
CTG
EMISSION
LIMIT
The VOC emission limit Is reconmended in terms of equipment soeci-
fications and operation procedures. Required control equipment can be
as simole as a manually operated rank cover or as complex as a carbon
adsorption system depending on ths type, size, and design of the
degreaser.
VOC
REDUCTION
PER
FACILITY
The actual percent VOC reduction will vary depending on the control
equipment installed and the operational procedures followed. Reconmend-
ed control methods can reduce VOC emissions by;
a. CC - 50 to 53 percent {~ 20 percent).
b. OT - 45 to 60 percent (£ 15 percent). i
c. CD - 25 to 60 percent (+ 10 percent). j
COSTS *
• n
3ASIS.
and low vol a
3.5 work
CC-a
St""
CD
CC of 0.5 m work
ti1ity solvent (b]
area.
Caoital Cost
51.000
area using high vol
; OT of 1.67 m* work
Annualized Cost
SI. 000
atility solvent (a)
area; and CO of
Cost Effectiveness
S/ton VOC
0.025
0.065
0.3 - 10.3
7.5 - 18
,0.001,
(0.026)
(0.3) - 0.8
3.7 - 1.5
(3^0)°' 220
(260) - 260
7
-------
SUMMARY OF C7G OOCUMtKT FOR COATING OF CA.NS
^AF.-iCiLu 1 Two-and three-oiece can surface coatina lines including tne
FACILITIES .application areas and the drying ovens.
NUME-n Gr 1
AFFECTED Estimated to be 46C affected facilities nationwide.
facilities;
VOC I Estimated annual emissions from can coating facilities are up,CD?
EKISSIOfiS iMa/yr (150,000 ton/yr) wnicn reoresent aDOut 0.5 oercen*. of *.ne esnmats.i
NATION-IDE; nationwide VOC ens:ions. n4.15]
VOC j
EKIS5I0.'. i Typical annual emissions from can coatinq lines can vi=ry f*orr 'j
RA'.CE j(U tons) for end sealing to 240 Mg (260 ton) for two-piece can coat-
?E* line for a plant average of 310 (340 ton;.
FACILITY i
ICC TOK/YR
SOURCE
SIZE
Typical can coating facilities as represented in the CTG would ail
approacn or exceed 100 TPY VOC emissions if uncontrolled.
CTG
EMISSION
LIMIT
The recommended VOC emission limits are:
a. Sheet coating, two-piece exterior 0.34 kg/1 (2.8 lb/gal)*
b. Two- and three-piece Interior 0.S1 ltg/1 (4.2 lb/gal)*
c. Two-p1ece end exterior 0.51 kg/1 (4.2 lb/gal)*
d. Three-piece side seam 0.66 kg/1 (5.5 lb/gal)*
e. End seal compound 0.44 kg/1 (3.7 lb/gal)"
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary depending on tne solvent
content of the existing coatings and the control method selected. j
Implementation of the recommended control methods can reduce VOC emis- !
sions by 60 to 100 percent. !
COSTS
3ASIS: 5,000 scfm facility using thermal or catalytic inc:nera-
tion with primary heat recovery, or adsorption with recove-ed solvent
credited at fuel value. . i
CAPITAL COST: $125,000 - 5162,000 i
ANNUALIZED COST: $42,000 - $71 .000
COST EFFECTIVENESS: $135 - $706 Jer ton VOC |
* Coating minus water
8
-------
SUMMARY OF CTG OOCUMENT FOR COATING OF METAL COILS
AFFECTED
FACILITIES
Coil surface coating lines including the application areas, the dry-:
inc ovens, and the quench areas. ;
' NUMSE? OF j
AFrECTEO
FACILITIES
Estimated to be 180 facilities nationwide.
VOC | Estimated annual emissions from coil coating facilities are 30,0CC
EMISSIONS ! Mc/yr (33,000 toryyr), which represent about 0.1 oercent of tf1® es:i-
NATIONWIDE (mated nationwide VOC emissions. L14,153
VOC
Ef: £ 110'."
RANGL PES
facility
Average annual VOC emission for a typical facility is estimated
to be 180 Ma (200 ton).
ioo ton/yr
SOURCE
SIZE
6 2 9 2
It is estimated that 2 x 10 m (2 x 10 ft ) of coil coatei couic
result in a potential emission of 100 tons of VOC.
CTG
EMISSION
LIMIT
The reconmended VOC emission limit is 0.31 kg per liter of coating
minus water (2.6 lb/gal).
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary depending on the solvent
content of the existing coatings and the control method selected. Imole-
mentation of tfie recommended control methods can reduce VOC emissions by
70 to 98 percent.
COSTS
BASIS: 15,000 scfm facility using incineration with primary heat
recovery.
Capital cost: % $170,000
Annualized cost: * S 70,000
Cost effectiveness: S51 - $94 oer ton VOC
9
-------
SUMMARY OF CTG DOCUMENT FOR COATING OF FABRIC ANO VINYL
affected
FACILITIES
fsoric and vinyl surface coating lines including the aoplication
areas and trie drying ovens. Fabric coating includes all types of
coatings aoplied to fabric. Vinyl coating refers to any printing,
| decorative, or protective topcoat applied over vinyl coateo faonc or
v i n_, 1 sneets.
NUMBER OF
AFFECTED
FACILITIES
Estimated to be 130 facilities nationwide.
VOC
EMISSIONS
NATIONWIDE
Estimated annual emission froir fabric coating operations are 10C.D-
Mc.'vr (110,000 ton/yr). [15] The vinyl seonent of the fabric industry
ents aoou: 36.02C Kg,'yr (iO.OOO ton/yr). vOC fror fabric coatinc1 rec-
resents aoo'jt 0.4 osrcent of the estimated VOC emssions nationwiae.
VOC
EMISSION
RANGE PER
facility
Average annual VOC emissions are estimated to be 350 Mo (9^0 ton
100 TON/YR
SOUPCE
SIZE
Any but the smallest fabric coating facilities should exceed emis-
sions ot" 100 ton/yr of VOC.
CTG
EMISSiON
LIMIT
The recontnended VOC emission limits are:
a. Fabric coating 0.35 kg per liter of coating minus water
(2.9 lb/gal).
b. Vinyl coating 0.45 kg per liter of coating minus water
(3.8 lb/gal).
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary deoending on the solvent
content of the existing coatings and the control method selected.
Imo 1ementation of the recomnended control methods can reduce VOC emis-
sions ay 30 to 100 percent.
COSTS
BASIS: 15,000 scfm facility using incineration with primary heat
recovery or adsorption with recovered solvent credited at fuel value.
Capital cost: SI50.000 - S320.000
Annualized cost: S 50,000 - J 75,000
Cost effectiveness: S34 - S39 oer ton vnc
10
-------
SUMMARY OF CTG OOCUMENT FOR SURFACE COATING OF PAPER PRODUCTS
AFFECTED
FACILITIES
Pacer surface coating lines including the aoplication areas and the)
drying ovens. The CTG document applies to manufacturing of adhesive
taDes, adhesive labels, decorated paper, -book covers, office coder 1
pacer, carbon paper, typewriter ribbons, and photographic films. j
NUMBER OF
AFFECTED
FACILITIES
SIC 2641, Paper Coating and Glazing, had 397 plants in 1967.
Current estimates for this category are 290 plants nationwide.
VOC
emission:
NATIONWIDE
Estimated annual emissions are 320,000 Mg/yr (350,000 ton/yr). Of j
this amount, the manufacture of pressure sensitive tapes and labels is
estimated to emit 263,000 M;/yr (290,000 ton/yr). Emissions frorr :ne '
coatmc of caper products represent about 1.2 percent of nationwide VOC !
[14]
em:ssions.L J ;
voc
EMISSION
RANGE PER
FACILITY
Emissions from typical paper coating lines can vary from 23 to 1
•150 tg/hr (50 to 1,000 lb/hr). A plant may have 1 to 20 coating lines. |
It is estimated that the annual average VOC emission from paper coating j
plants is 1,480 Mg (1 ,630 ton). j
1QO TON/YR
SOURCE
SIZE
Based on the data given, a plant with one large line or two 1
small lines can exceed 100 ton/yr of VOC emissions. i
CTG
EMISSION
LIMIT
The recomnended VOC emission limit Is 0.3S kg per liter
of coating minus water (2.9 lb/gal). j
1
VOC
REDUCTION
PCT
FACILITY
The actual percent reduction will vary depending on the solvent j
content of the existing coatings and the control method selected. '
ImDlementation of the recomnended control methods can reduce VOC !
emissions by 80 to 99 percent. j
COSTS
BASIS: 15,000 scfm facility using incineration with primary heat
recovery or adsorption with recovered solvent credited at fuel falue. j
Caoital cost: $150,000 - S320.000 |
Annualized cost: S 60,000 - S 75,000
Cost effectiveness: $34 - $40 per ton VOC j
11
-------
SUMMARY OF CTG DOCUMENT FOR COATING IN AUTOMOBILE ANO LIGJ- T- DUTY TRUCK ASSEMBLY DL4NT!
AFFECTED
FACILITIES
AutomoDile and light-duty truck surface coating lines including tne-
application areas, the flashoff areas, and the drying ovens.
The CTG provides no exemotions but notes that it may not oe
reasonable to convert an existing water-borne dio prime coatmc syster
N'JMSE?. OF j
AF'IZ'IZ Identified for the year 1977 to be 47 plants nationwide.
FACILITIES j
I
VOC I Estimated annual emissions from auto and lignt duty true' oiants
EKISSIO'.'S ! are 90,000 Mq/yr (IOC,000 ton'yr). This is aoout 0.3 oerce.it o*
NATIONWIDE j estimated VOC enssions nation».i
j Emissions from tyoical coating lines can vary from 270 to 1,300
ic,' 1 kg/hr (600 to 4,000 lb/hr). Average annual emissions are estimated to be
FACILITY j2,^ao (2,620 ton) oer Sucject plant.
^SOUR*^ i ;11 jncontr°'1ed coating lines at the assemoly plants are exoectec
SIZ*~ *° OTi1: ln excess ^ tons af per year-
CTG
EMISSION
LIMIT
The recomnended VOC emission limits are:
a. Prime coating 0.23 kg/1 (1.9 lb/gal) minus water
b. Top coating 0.34 kg/1 (2.3 lb/gal) minus water
c. Final reoair coating 0.58 kg/1 (4.3 lb/gal) minus water
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary depending on the solvent
content of the existing coatings and the control metnod selected.
Imoiementation of the recomnended methods can reduce VOC emissions for-
a. Prime coating - 80 to 93 percent.
b. Top coating - 75 to 92 percent.
c. Final repair coating - not available
COSTS
3ASIS: 30 - 65 units per hour facility with substantial variability
in both existing operations and potentially applicaole control systems.
Capital cost: $6,500,000 - S50,000,000 i
Annualized cost: . $2,000,000 - S25.000.000 i
Cost effectiveness: SI ,000 - S4.000 per ton VOC
12
-------
SUMMARY OF CTG OOCUMENT FOR COATING OF METAL FURNITl.RE
AFFECTED
FACILITIES
Metal furniture surface coating lines including the
application and flashoff areas, and the drying ovens.
Nl)M.S£R OF
AFFECTED
FACILITIES
Aoproximately 1,400 facilities would be affected nationally
voc
EMISSIONS
NAT I ON.IDE
Estimated annual emissions are 90,000 Mg/yr (100,000 ton/
no
yr). This represents about 0.3 percent of estimated VOC
emissions nationwide.
VOC
EMISSION
RANGE PER
FACILITY
Estimated average annual VOC emissions are 70 Mg
(30 ton) per facility.
TOO TON/YR
SOURCE
SIZE
For a model dip coating line, a plant coating (with no primer),
2 2
1,500,000 m (16,200v000 ft ) of shelving per year would emit .
aoout 100 ton/yr.
CTG
EMISSION
LIMIT
The recommended VOC emission limit is 0.36 kg per liter
of coating minus water (3.0 lb/gal).
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary depending on the solvent !
content of the existing coatings and the control method selected. {
Implementation of the recomnended control methods can reduce VOC
emissions by 50 to 99 percent. j
COSTS
8ASIS: A dip coating facility coating 7,000,000 ft2 of shelving 1
per year converting to water-borne or electrodeoosition: j
l
Capital cost: S 3,000 - SI24,000 I
Annualized cost: $11,000 - S 25,000 j
Cost effectiveness: $440 - $657 per ton VOC
13
-------
SUWARY OF CTG DOCUMENT FOR COATING OF MAGNET WIRE
AFFECTED
FACILITIES
Wire coating oven.
NUMSES OF
AFFECTED
FACILITIES
Estimated to be 30 plants nationwide. It is not unusual for a wire
coating plant to have SO coating ovens.
VOC
EMISSIONS
NATIONWIDE
CTG states that there Is no way to know how much solvent is actually
emit tea. About 29,500 metric tons (32,500 ton) of solvent are used eacr.
year out much of this is controlled.
VOC
EMISSION
RANGE PES
FACILITY
Emissions from a typical uncontrolled oven will be approximately 12
'
-------
SUMMARY OF CTG DOCUMENT FOR COATING OF LARGE APPLIANCES
AFFECTED
FACILITIES
Large appliance surface coating Including the prime, single, or
topcoat application areas, the flashoff areas, and the oven.
NUK:-^ OF
AFFECTED
FACILITIES
Estimated to be about 270 plants nationwide. !
voc
EMISSIONS
NATIONWIDE
Estimated annual emissions are 42,000 Mg/yr (46,000 ton/yr)^11-'
whicn represent about 0.2 percent of estimated nationwide VOC
emissions.
VOC
EVISSIO:.
RANGE PEP
FACILITY
'
The average annual VOC emissions are estimated to be
170 Mg (135 ton).
100 TON/YR
SOURCE
SIZE
Extrapolating the model facility data, a plant coating 221,000
clothes washer cabinets per year would exceed 100 ton/yr emissions of
uncontrolled VOC.
CTG
. EMISSION
LIMIT
The recomcnded VOC emission limit is 0.34 kg per liter
of coating minus water (2.8 lb/gal).
VOC
REDUCTION
PER
FACILITY
The actual percent reduction will vary depending on the solvent
content of the existing coatings and the control method selected.
Implementation of the recomnended control methods can reduce VOC
emissions by 79 to 95 percent.
COSTS*
BASIS: 768,000 clothes washer cabinets coated per year using
various combinations of control techniques.
Capital cost: $70,000 - $1,250,000
Annualized cost: (1300.000) - $350,000
Cost effectiveness: ($1,050) - $1,180 per ton VOC
• {$—) indicate* savings
15
-------
SUMMARY OF CTG DOCUMENT FOR LEAKS FROM PETROLEUM REFINERY EQUIPMENT
Affected
facilities
(p. 6-l)o
Petroleum refinery equipment Including pump seals, compressor
seals, seal oil degassing vents, pipeline valves, flanges and
other connections, pressure relief devices, process drains,
and open ended pipes.
Number of
affacted
facilities
There were 311 petroleum refineries in the nation as of
January 1, 1979.12
VOC
emissions
nationwide
(p. 5-1)*
The estimated VOC emissions nationwide are 170,000 Mg/year,
or about 1 percent of the total VOC emissions from stationary
sources.
VOC
emissions
range per
facility
(p. 3-2)*
The potential VOC emissions per leaking source range from 1.0 to
10 kg/day.
100 ton/year
source size
(p. 1-3, 2-3)*
A 3lngle Leaking source has the potential to emit 0.4 to 3.7 Mg
VOC/year (0.5 to 4.1 ton/yr). A refinery with between 25 and
227 leaking components would emit 100 tons/year of VOC. A
modeL medium size refinery may have 90,000 leaking components.
CTG
emlss ton
limita
(p. 1-3) •
If a leakLng component has a VOC concentration of over 10,000 ppm
at the potential leak source, it should be scheduled for main-
tenance and repaired within 15 days.
VOC
reduction per
facility
(calculated)
Estimated to prevent the release of 1821.1 Mg/year (2007.4 ton/
year) of VOC at a model medium size refinery (15,900 m3/day) by
reducing emissions from 2933.6 Mg (3233.5 ton) to 1112.5 Mg
(1226.1 can) per year.1''
Costs
(p. 4-8)*
Basis: A monitoring and maintenance program for a 15,900 m3/day
(100,000 bbl/day) refinery (Fourth quarter 1977 dollars).
Instrumentation Capital Cost 8,800
Total Annualized Costs 115,000
Cost Effectiveness $/Mg (86,85)Tl3
S/ton (78.31)+13
The source of die summary Information is the indicated page number(s) in "Control
of Volacile Organic Compound Leaks from Petroleum Refinery Equipment,"
EPA-450/2-78-03h.
Numbers in parentheses ,ire savings.
16
-------
SUMMARY OF CTG DOCUMENT FOR SURFACE COATING OF MISCELLANEOUS METAL
PARTS AND PRODUCTS
Affected
facilities
(p. l-2>-
PUafeer of
ifffctid
facilities
Co*clna application areas, flashoff areas, Jry«rs, and ovens fur
monufacttirera of:
a. Urge farm machinery
b. . Small farm machinery
c. Small appliances
d. conwercial machinery
«. Industrial machinery
f. Fabricated metal produces
g. Any ochcr Industriel category, which coaca mrtale,
under SIC major groups 3^*39. Inclusive.
Except those fscllltiee which are covered by previous CTCe.
96,000'
voc
eslsalons
nationwide
9.0 « 10'' Kg/yr (I * L0* tons/yr) estimated for 1977, which
represents abouc 3.0 percent of stationary source entlmated
eitlfta 1 onn . '*
voc
emission
range per
facility
(pp. 1-10,
2-3)e
An emission factor of 0.66 kg VOC/I coating lese water
(5.3 lb voc/nal coating lees water) can be expected fro®
• facility udllting a costing composed of 73 percent organic
solvent, 23 percent solids by volume.
?or facilities utilising en eJectrodepoeltion proceae che VOC
•aiswion factor Is 0.36 kg VOC/1 coating leea water (3.0 lb/gel).
100 tonM/yr
source else
(calculated)
An amlaelon factor of 3.5 lb VOC/gal Implies that a minimum proceae
rate of 3.64 ¦ 10" gal coating aaterlal/yr would be required for a
facility Co be a potential 100 eon*/yr source.
CTG
emission
Halt
(p. V) e
Coat Inn nethod
a. Air or forced air dried
1 terns
b. Clear coat
c. Mo or Infrequent color
change or amall nuoeer
of colore applied
1. Powder coetlnga
2. Other
d. Outdoor, harsh exposure
or extreme performance
characteristics
«. Frequent color change*
large nuauer of colore
applied, or flrat coat
on uncreated ferrous
eubetrate
Recomended limitation
wt. VOC
vol. coating
0.42 kg/1 (3.3 lb/gal)
0.32 kg/1 (4.3 lb/gal)
*¦>
o
o
kg/1
(0.4
lb/gal)
0.36
kg/1
(3.0
lb/gal)
0./.2
k«/l
(l-l
Ib/xni)
0.34
kg a
(3.0
lb /gal)
VOC
reduction
per facility
(p. 2-l)«
Proceae radlflcatlon
Zxhauet ^aa treatment
Percent reduction In VOC eralselone
(coating/equipment change)
50-98
90+
Coeta
(pp. }-S to
J-U)*
10* ft2/yr)
Baele: A medium else coating line ("» 743,000 o*/yr, - 8
wtth single or tvo coat operation using flow-coat, dip-coat,
or spray-coat applications. The rangee cover the cot* of
several different VOC control optlone.
20-1,817
Capital cost
'S1C00)
Annualized cost
( 51000)
Cost offcctlveneee
($/**)
(S/tcn)
(27)t-602
(290)t.fjta4l
(261)^-6,206
•The eource of the tusnary Information Is the indicated pege nuatoer In "Control of
Volatile Organic Sralseiona from £xLetlng Stationary Sourcee, Volume VI: Surface
Coating of Nlecellaneoua Metal Parte and Products," EPA-450/2-78-01S.
fNua6ere In parentheeee are tavlnga.
17
-------
SUMMARY OF CTG DOCUMENT FOR FACTORY SURFACE COATING OF
FLAT WOOD PANELING
Affected
facilities
(p. l-2)»
Number of
affected
facilities
(p. t-2)*
VOC
emissions
nationwide
VOC
etalna Ion
ranRe per
facility
(Tabic 2-2
p. 2-5)*
The ,if fort i'il i.ullltlcs are factories that surface coat Che
folluwlne lvpom in* flat wood panela:
a. Hardwood plyvood
b. PartlcIeboard
c. Hardboard
Affecced Facilities Nationwide Total
a. Hardwood plywood 247
b. Parclcleooard 80
c. Hardboard 67
8.4 « 10" Hg/yr (9-3 « 101* tons/yr) estimated for 1977 which
represents .ioouc 0.5 percent of stationary source estimated
pmlaK tons.!1
Pntenclul Vuc i-miHHlons per coated surface area are:
0.4 ci. 8.0 fc«/l()0 m7 (0.8 to 16.5 lb/1000 ft2)
depend Inn on ttie coating/curing process as well as the coating
macerlnlH uNeil.
100 tons/yr
source size
(calculated)
U.ined on che VOC emission range above, a 100 tpy source would
coat n minimum annual throughput of:
3.8 « I0-' to 1.7 ' 10" standard panels/yr
Whore -i scandard panel Is 2.97 m2 (32 ft2).
CTG
•mission
limit
(p. v)«
Printed hardwood plyvood
and part LcIeboard
Natural finish hardwood plyvood
CIarr M finishes for hard-
bonrd pnne i Int*
tecorgnended limitation
2.9 kg VOC/100 m'
(6.0 lb VOC/1000 ft2)
5.8 kg VOC/100 m2)
(12.0 lb V0C/1000 ft2)
4.8 kg VOC/100 m2)
(10.0 lb VOC/1000 ft2)
VOC
reduction
per facility
(Table 2-1
p. 2-4)«
Cos Cm
(Table 3-2
p. 1-9)*
70 co 90 percent VOC emission reduction, depending on coating
material and coverage, through uss of water-borne coatings,
Inclnerac 1 on , ailaurpc Ion, ultraviolet curing or electron beam
curing.
3au1s:
Shlfcs: I
2
Panels/yr: 2,000,
000
4,000,000
Waterborne
UV/Watcrborne
Waterbome
UV/Warerbome
Caplcal rose
(S1000)
52
135
52
155
Annua 11 zed ense
(Sinnoi
101
124.6
200.3
2 34. 4
Cose i.M'fl'1'Llvi'ni'IH
(5/Ma)
I 5/con)
269
244
292
264
256
232
264
240
•The source of Che nummary Information ta Che Indicated page number In "Control of
Volatile Organic Emissions frcm Existing Stationary Sources, Volume VII: Factory
Surface Coating of 7lac v.'oon Paneling," EPA-450/2-78-032.
''Definition on p. vt: of KPA-4 50/2-78-032.
18
-------
SUMMARY OF CTG DOCUMENT FOR MANUFACTURE OF SYNTHESIZED
PHARMACEUTICAL PRODUCTS
Af facted
{acillties
(p. 1-4)*
Synthesized pharmaceutical manufacturing facilities. Specific
sources include:
L. Dryers 5. Filters
2. Reactors Extraction equipment
3. Distillation Units 7. Centrifuges
4. Storage and transfer 8. Crystallizers.
of VOC
Number of
affected
facilities
(p. 1-2)*
Estimated 800 plants nationwide
VOC
emissions
nationwide
30,000 Mg/yr (55,000 tons/yr) estimated for 1977 which represents
about 0.3 percent of stationary source estimated VOC emissions.11
VOC
amlaalon
range per
facility
Not available
100 ton/yr
¦ourca size
Not aval table
CTC
amission
limit
(P. 1-5) •
1. a. Surface condensers or equivalent control on vents fro®
reactors, distillation operations, crystallizers, cen-
trifuges, and vacuum dryers that emit 6.8 kg/day (15 lb/day)
or more VOC.
b. Surface condensers must meet certain temperature versus VOC
vapor pressure criteria.
2. Additional specific emission reductions are required for air
dryers, production equipment exhaust systems, and storage and
transfer of VOC.
3. Enclosures or covers are recommended for rotary vacuum fiLters,
processing liquid containing VOC and in-process tanks.
4. Repair of components leaking liquids containing VOC.
VOC
reduction
par facility
Not available
Coaca
(pp. 5-14
to 5-42)*
Capital and Annualized Coat graphs are provided for the following types
of control equipment: conservation vents, floating roofs, pressure
vessels, carbon adsorption systems, thermal and catalytic incineration
systems, water cooled condensers, chilled water and brine cooled con-
densers, :*raon cooled condensers, packed bed scrubbers and venturi
flcruhnera.
Cost effectiveness daca is not calculated for typical plants.
The source of the summary Information 13 the Indicated page(s) in "Control of Volatile
Organic Emissions from Manufacture of Synthesized Pharmaceutical Products "
EPA-450/2-78-029.
19
-------
SUMMARY OF CTG DOCUMENT FOR MANUFACTURE OF PNEUMATIC RUBBER TIRES
Af fueted
facilities
(pp. 1-1,
1-3)*
Rubber tlri- manufacturing plants, producing passenger car, and light
and medium duty truck, tires. Operations affected arc: undertread
cementing, bead dipping, tread end cementing, and green tire spraying.
Number of
affected
facilities
(p. 2-2)*
Maximum of 62 rubber tire plants nationwide
VOC
emissions
nationwide
(p. 1-2)*
1976 VOC emissions ostimate from rubber tire manufacturing totalled
88,200 Mg/yr (97,200 tons/yr). This quantity represents 0.6 percent
of total national VOC emissions from stationary sources.
VOC
emission
range per
facility
(p. 1-2) *
The average tire plant la estimated to release 4,000 kg per day
(8,820 lb/day) of emissions or 1,000 Mg VOC per year (1,100 tons/yr).
100 tons/yr
source size
(p. 2-8) *
rhe model plant, producing 16,000 tires/day, has potential to emit
1,460 Mg/yr (1,600 tons VOC/yr). Therefore a plant producing approxi-
mately 1,000 Llres/day would be a potential 100 tons/yr source.
CTC
emission
limit
(p. 4-2) *
VOC emissions reduction from the affected operations is recommended
through use of carbon adsorption or incineration. Water-based coat-
ings may be used for green tire spraying.
VOC
reduction
per facility
(p. 1-4) *
a. Carbon adsorption gives an overall efficiency of 62-86 percent in
reducing VOC emissions, when applied to the affected operations.
b. Incineration gives an overall efficiency of 59-81 percent when
applied to the affected operations.
c. Water-based coatings, applied to green tire spraying, provide an
overall emission reduction efficiency of 97 percent.
Costs
(pp. 4-11,
4-15) *
Basis: A model 16,000 tires/dav nlant usina the various ronrrnl
technologies recommended on the following affected operations.
All costs are based on January 1978 dollars.
Undertread
cementing
Bead dipping
Tread end
cementing
Green tire
spraying
Capital cost
($1000)
Annualized coic
(51000)
Cost effectiveness
(S/Mn)
($/ton)
130-340
92-280
166-505
150-458
115-250
70-985
l,4«0-20,800
1,340-18,800
135-375
100-340
1,1^0-3,880
1,000-3,500
15-450
118-490
202-839
184-763
*The Mource of the summary Information is tlie indicated paBt>(s) In "Control
of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires "
EPA-450/2-78-0 3U. '
20
-------
SUMMARY OF CTG DOCUMENT FOR EXTERNAL FLOATING ROOF TANKS
Affected
facilities
(p. 1-2)*
External floating roof tanks larger thaw 150,000 liters (40,000 gal)
storing petroleum liquids. See exceptions noted in text.
Number of
affected
facilities
(p. 2-1)*
There Is an estimated 13,800 internal and external floating roof tanks
that are larger than 150,000 liters (40,000 gal). The number of ex-
ternal floating roof tanks is not available.
voc
emissions
nationwide
(p. 1-2) *
An estimated 65,000 Mg (71,630 tons) of VOC was emitted in 1978 which
represents about 4.0 percent of stationary source estimated emissions.
VOC
emission
range per
facility
(pp. 3-3,
3-9)*
The emission range for a 30.5 m (100 ft) diameter tank storing 41.4 kPa
(6 psi) vapor pressure gasoline i3 212 Mg/yr (233 tons/yr) for a slightly
gapped primary seal Co 2.2 Mg/yr (2.4 tons/yr) for a tight rim-mounted
•secondary seal over a tight primary seal.
100 tons/yr
source size
No single float inn roof tank Is expected to emit more than 100
tonw/yr.1^
CTG
emission
Halt
(pp. 5-1,
5-4) *
.... —
A continuous secondary seal or equivalent closure on all affected
storage tanks, plus certain inspection and recordkeeping requirements.
VOC
reduce 1 on
per facility
(pp. 3-3,
>9) *
Ranges from about 200 to 2 Mg/yr (220 to 2.2 tons/yr).
i
[
i
Costs
(pp. 4-9,
4-12) *
Basis: External floating roof tank 30.5 m (100 ft) in diameter with a
capacity of 8.91 * 106 liters (55,000 bbl) controlled by a rim
mounted serondury seal. ,
Capital cost 16.9
($1000) j
Annualized cost 3.3 |
($1000) . j
Cost effectiveness
(S/Mg) (66)^-3,655
(S/con) (59)T-3,316
*The source of the summary Information is Che Indicated page(s) in "Concrol of Volatile
Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks "
EPA-450/2-78-047.
Numbera in parenthesis indicate credits.
21
-------
SUMMARY OF CTG DOCUMENT FOR GRAPHIC ARTS - ROTOGRAVURE
AND FLEXOGRAPHY
Affected
Facilities
(p. 1-D*
Nunfcer of
affected
facilities
(p. 2-5)*
VOC
emisB1onn
nat lonwldc
(p. 2-8)*
FlcxoRrnph U' .-iml rotogravure processes appLled Co publication .nul
packaglnR printing.
Publication printing Is done In Large printing plants,
less than 50 In totsl.
nmnhe r i m-
There are approximately 13 to 14 thousand gravure prlntln,- units
and 30 thousand flexographlc printing units.
a. Cravure 100,000 Mg/yr 1976 (110,000 tons/yr)
b. Flexopraphv 30,000 Mg/yr 1976 (33,000 tons/yr)
This represents about 0.8 percent of stationary source estimated
i-ml in Ions.
1 1
VOC
cnlsnion
range per
faclllcy
(calculated)
a. Cravure
b. FlcxoRrapliy
7.4 Mg/prlnting unit per year
(8.2 tons/unit)
1 Mg/printing unit per year
(1.1 tons/printing unit per year)
100 tons/yr
source size
A plant will he .i potential 100 tons/yr VOC source if it uses
110-L80 Mg (120-200 cons) of Ink per year, where the solvent
concentration Is 50-85 percent.
CTC
emission
limit
(PP. 1-2,
1-3) *
VOC
rcduct Inn
per facl1 Ity
Costs
(pp. 4-8
4-13) *
Use of water-borne or high solids Inks meeting certain composition
criteria or the use of capture and control equipment which provides:
a. 75 percent overall VOC reduction where a publication
rotogravure process is employed;
b. 6 5 porci-nt overall VOC reduction where a packaging roto-
rotoeravure process Is employed; or,
c. 60 percent overall VOC reduction where a flexographlc
printing process is employed.
Same as (.TH I Imic above.
VOC rontrol opt Ion
[nk usage,
Mg/yr
(tons/yr)
VOC conccntration ppm
Capital cost
Annual Lzci jost
Cost effectiveness
¦"> / Me.
S / ton
Incinerator
7
(7.7)
500
94,000
24,900
8,360
7 .570
! Cj rh on
Incinerator adsorption
2,500
(2,750)
500
1.110,000
1,665.500
1,650
I, 480
3,500
(3,360)
1,200
701.000
72.300
51
46
Carbon
adsorption
7 ,000
(7 , 720)
2 ,4110
701 ,000
(41 .700) r
( lr>)'
I I IV
•The Hource of the summary Information Is the indicated paRe number in "Control of
Volatile Organic Emissions from Existing Stationary Sources, Volume VIII: Graphic
Arts - RotORravure and K lexnuraphy," f'.P A-4 50/2-78-033.
'"Numbers In parentheses are savinns.
22
-------
SUMMARY OF CTG DOCUMENT FOR PERCHLOROETHYLENE DRY CLEANING SYSTEMS
Af fected
facilities
(p. 2-1)*
Affected facilities arc coin-operated, commercial, and industrial, dry
denning systems wli 1 cli utilize perchloroethy 1 ene as solvent.
Number of
affected
facilities
(calculated)
a. Coin-op 14,900
I). Commercial 44,600
c. Industrial 230
VOC
emlssIons
nationwide
(pp. 1-2,
2-1) *
a. Coin-op 21,400 Mg/yr (23,500 tons/yr)
b. Commercial 123,000 Mp/yr (135,000 tons/yr)
c. Industrial 13,600 Mg/yr (15,000 tons/yr)
The estimated 158,000 Mg VOC/yr is 0.9 percent of total stationary
source estimated emissions.
VOC
emission
range per
facility
(p. 5-2)*
Uncontrolled VOC emissions
Type of plant ^g/yr (lb/yr)
a. Coln-op 1,460 (3,200)
1). Commercial 3,240 (7,200)
c.. Industrial 32,400 (72,000)
100 tons/yr
source nize
(extrapolated)
A larso industrial dry cleaning plant, processing 750 Mg (825 tons) of
clothes per -/ear, would be a potential 100 tons VOC per year source.
CTG
emlnnIon
limit
(pp. 6-1 -
6-4)*
a. Reduction of dryer outlet concentration to less than 100 ppm VOC,
hy means of carbon adsorption. (Facilities with inadequate space
or steam capacity for adsorbers are excluded.)
b. Reduction of VOC emissions from filter and distillation wastes.
c. Eliminate liquid and vapor leaks.
VOC
reduction
per facility
(pp. 2-5,
2-7)*
Carbon adsorption applied to commercial and industrial plants will
reduce overall VOC emissions by 40-75 percent.
Costs
(p. 4-5)*
Basis: Carbon adsorbers for a commercial [slant cleaning 46.000
(100,000 lb) of clothes per year.
Capital cost $4,500
Annualized cost $300
Cost offectivcness $90 credit/Mg
S80 credit/ton
*The source of the .nummary information Is Che Indicated page number In "Control of
Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems," EPA-450/2-78-050.
23
-------
SUMMARY OF CTC DOCUMENT FOR LEAKS FROM GASOLINE TANK TRUCKS AND
VAPOR COLLECTION SYSTEM
Affected
fad lities
(p. 2)*
a. Casoline tank trucks that are equipped for vapor collection.
b. Vapor collection systems at bulk cerminals, bulk plants, and service
stations chat are equipped with vapor balance and/or vapor processing
systems.
Number of
affected
facilities
Not available
VOC
emissions
nationwide
Not available
VOC
emission
range per
facility
Not available
CTC
emiaa ion
limit
(pp. 1
and 2)
The control approach Is a combination of testing, monitoring, and equip-
ment design co ensure that good maintenance practices are employed to
prevent leaks from truck tanks or tank compartments and vapor collection
systems during gasoline transfer at bulk plants, bulk terminals, and
service stations. A leak is a reading greater than or equal to 100
percent of the LEL at 2.5 co from a potential leak source as detected by
a combustible gas detector.
VOC
reduction
per facility
Noc available
Costa
Not available
*The source of Che summary Informal: Ion Is the indicated page number in "Control of Volatile
Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems,"
EPA-450/2-78-051.
24
-------
Summary of CTG Document for Manufacture of High-Density
Polyethylene, Polypropylene, and Polystyrene Resins
AFFECTED FACILITIES: This CTG applies to emissions from certain processes
in the manufacture of high-density polyethylene,
polypropylene, and polystyrene.
The manufacture of these three polymers are estimated
to account for 53,000 ton/yr of VOC emissions or 56%
of emissions from all types of polymer manufacturing.
Typical size uncontrolled plants could emit:
high density polyethylene 3,100 tons/yr
polypropylene 5,700 tons/yr
polystyrene 260 tons/yr
CTG EMISSION LIMIT: The following emission reductions or limitations are
considered representative of RACT:
(1) For polypropylene plants using liquid phase
processes: a 98 weight percent reduction or reduction
to 20 ppm of continuous VOC emissions from the
polymerization reaction section (i.e., reactor vents),
the material recovery section (i.e., decanter vents,
neutralizer vents, by-product and diluent recovery
operations vents), and the product finishing section
(i.e., dryer vents and extrusion and pelletizing vents).
(2) For high-density polyethylene plants using liquid
phase slurry processes: a 98 weight percent reduction
or reduction to 20 ppm of continuous VOC emissions from
the material recovery section (i.e., ethylene recycle
treater vents) and the product finishing section (i.e.,
dryer vents and continuous mixer vents).
(3) For polystyrene plants using continuous processes:
an emission limit of 0.12 kg V0C/1,000 kg product from
the material recovery section (i.e., product devolati1izer
system).
CONTROL TECHNIQUES: Flares or thermal incinerators are the most commonly
used control devices. They can destroy 98% of the
streams ducted to them.
Condensers are often used on polystyrene vents. These
can control 952 of the VOC emissions passing through them.
25
-------
2
CONTROL COSTS: Cost per ton of VOC controlled is a function of
the uncontrolled emission rates. The CTG gives
emission rates (in Kg VOC/Mg product and Mg/yr)
above which the control cost is $1000/Mg or less
Similar cutoffs are given for $2000/Kg and
$3000/Mg. A State may choose to use any cutoff
which gives an appropriate level of stringency.
26
-------
Summary of CTG Document for VOC Leaks
from SUCMI/Polymer Manufacturing
AFFECTED FACILITIES/
APPLICABILITY:
CTG EMISSION LIMIT:
Equipment in VOC service in process units producing
synthetic organic chemicals listed in SOCMI NSPS and
manufacturing polymers and resins;
Applies to VOC leaks from process equipment:
pumps, compressors, valves, open-ended lines,
sampling connections, safety relief devices.
Equipment specifications and inspections/maintenance
requi rements:
1. Capping of open-ended lines (except when
in use)
2. Quarterly leak detection and repair of pumps,
valves, compressors, safety relief devices
3. Repair components appearing to leak on basis
of sight, stnel 1, sound
4. Less frequent monitoring than quarterly for valves
in gas or light liquid service
5. Weekly visual inspections for indications of leaks
from pumps in light liquid service
6. Monitor safety relief devices after each overpressure
relief for proper reseating
27
-------
Summary of CTG Document for VOC Emissions
From Large Petroleum Dry Cleaners
AFFECTED FACILITIES/
APPLICABILITY: Petroleum solvent washers, dryers, solvent niters,
settling tanks, vacuum stills, and other containers
and conveyors of petroleum solvent used in petroleum
solvent dry cleaning facilities.
Applies to all petroleum solvent dry cleaning
facilities consuming 123,000 liters (32,500 gallons)
or more of" petroleum solvent annually.
CTG EMISSION LIMIT: 1. Petroleum solvent dry cleaning dryer:
Either
° VOC limit of 3.b lb of VOC per 1U0 lb dry
weight of articles dry cleaned
Or
° Install solvent recovery dryer
2. Petroleum solvent filtration system:
Either
0 Limit VOC content in filtration wastes
to 1 lb per 100 lb dry weight of articles
dry cleaned
Or
° Install cartridge filtration system; drain
filter cartridges in their sealed housings
for 8 hours or more before their removal
3. Repair petroleum solvent vapor and liquid
leaks within 3 working days after identifying
the leaks
28
-------
Summary of CTG Document tor VOC Emissions from Air Oxidation Processes
In Synthetic Organic Chemical Manufacturing Industry
AFFECTED FACILITIES/ .
APPLICABILITY: Air oxidation facilities within SOCMI, including
all reactors using air as oxidizing agent to produce
an organic chemical.
Includes any equipment (absorbers, adsorbers, condensers,
ammonia/HCl recovery units) used to collect VOC for
beneficial use or reuse (for sale or recycling)
CTG EMISSION LIMIT: For eacn air oxidation process vent stream, either:
I
1. Use combustion device (e.g., thermal oxidation,
flares, boilers) to reduce VOC emissions by 98 weight
percent or to 20 ppmv, whichever is less stringent;
OR:
t. Maintenance of total resource effectiveness (TRE)
index value greater than 1.0 (TRE is a measure of cost
effectiveness of controlling air oxidation streams witn
a 98% combustion device (thermal oxidation). A TRE index
of 1.0 is equivalent to a cost effectiveness of
51600/Mg (198U dollars) of VOC emission reduction)
29
-------
Summary of CTG Document for VOC Equipment Leaks
From Natural Gas/Gasoline Processing Plants
AFFECTED FACILITIES/
APPLICABILITY:
CTG EMISSIUN LIMIT:
Equipment in VOC service within a process unit in
onshore natural gas processing plants.
Equipment leaks rrom gas plants are VUC emissions
that result when process fluid (either gas or liquid)
leaks from plant equipment: pumps, compressors, valves,
pressure relief devices, open-ended valves or lines,
flanges and connections, gas-operated control valves.
RACT applies only to equipment containing or contacting
a process stream with VOC cbncentration of 1.0 percent
by weight or more
Equipment specifications and inspections/maintenance
requi rements:
1. Quarterly monitoring of pumps, valves, compressors,
and relief valves
2. Weekly visual inspection of pumps
3. Repair any component that appears to be leaking
on the basis of sight, smell, or sound
4. Less frequent monitoring than quarterly for
difficult-to-monitor valves
5. Capping of open-ended lines (except when open
end is in use)
6. Leaking components should be tagged and repaired
within 15 days or at next shutdown.
30
-------
ATTACHMENT 7
EPA PROTOCOL FOR CALCULATING DAILY EMISSION RATE
FOR AUTOMOBILE AND LIGHT-DUTY TRUCK TOPCOAT OPERATIONS
(TO BE PROVIDED)
-------
ATTACHMENT 8
APPENDIX D, NOVEMBER 24, 1987, FEDERAL REGISTER
-------
Federal Register / Vol. 52. No. 226 / Tuesday. November 24. 1987 / Notices
45105
Information for Proposed Stanctei-da.
eta moi't *"-maa- December 198S-
a phatocfaeoncally Reactive Organic
Conpooad Emissions From Consumer
and Commerttal Products. EPA 902/4-
88-001. prepared by EPA Region H.
November 1986.
9. Evaluation of a Paint Spray Booth
Utilizing-Air Recirculation. EPA-600/2-
H-143.
10. Benefits of Microprocessor Control
a£ Ovens for Solvent Based
Coatings. EPA-625/2-84-031. September
1984.
The EPA Region IV has prepared, with
contractor assistance, a number of
reports on specific non-CTG sources in
specific cities. These reports describe
control technology which is available.
The reports listed below were prepared
by EPA Region IV.
11. Volatile Organic Compound
Control at Specific Sources in Louisville,
Kentucky and Nashville. Tennessee.
EPA-904/9-81-087, December 1981.
This report discusses control
technology for these industries:
Wood Furniture
Aluminum Rolling Mill Lubricant
Control
Fiberglas* Reinforced Polyester Boat
Building (Styrene Emissions)
12. Technical Support ia the
Development of a Revised Ozone State
Implementation Plan for Atlanta.
Georgia, prepared .for EPA Region IV by
Pacific Environmental Services, EPA
Contract No. 68-02-3887, August 1985.
This report includes:
Architectural Surface Coating
Automobile Refinishing
Commercial/Consumer Solvent Use
Fuel Combustion
Gasoline Volatility
Aircraft Emissions
Degreasing
Lawn and Garden Equipment
13. Summary Report for Technical
Support in Development of a Revised
Ozone State Implementation Plan for
Memphis. Tennessee, prepared for EPA
Region IV bv Pacific Environmental
Services. EPA Contract No. 53-02-3887.
June 1985.
This multi-volume report includes:
Wood Furniture Coating
Barge Loading Facilities
Sheet Fed Paperboard Coating
Chemical Processing Plants
Solvent Extraction
Offset Lithography
Bulk Plants
14. Technical Information Document
for Technical Support in Development of
a Revised Orone State Implementation
Plan for Birmingham. Alabama,
prepared for EPA Region IV by Pacific
Environmental Services. EPA Contract
No. 66-02-3887. This consists of a series
of reports published in October and
November 1984 and February 1985.
Industrie s covered include:
Surface Coating at Large Aircraft
Paint Manufacturing
Coke frocesses
Lamination of Vinyl Coontertaps
Mineral Wood Production Industry
Brick Manufacturing Industry
Explosives Manufacturing Industry
A number of control technology
documents have been widely circulated
as draft documents for review. Some of
these documents have never been issued
as final documents such as CTG's for
various reasons, but they still contain
much helpful technical information.
Copies of some of these may be still
available from EPA. especially from the
Emissions Standards and Engineering
Division of the Office of Air Quality
Planning and Standards. Among these
are:
15. Draft "Control of Volatile Organic
Compound Emissions From Full-Web
Process-Color Heatset Web Offset
Lithographic Printing," August 1981.
16. Draft "Control Technique
Guidelines for the Control of Volatile
Organic Emissions From Wood
Furniture Coating," April 1979.
17. Draft "Fabric Printing Industry-
Background Information for Proposed
Standards", April 21,1981.
18. Draft "Eoniomic Impact Analysis
of Catalytic Incineration and Carbon
Adsorption on the Fabric Printing
Industry," November 1981.
19. Draft "Control of Volatile Organic
Emissions From Existing Stationary
Sources: Paint Manufacturing Industry,"
U.S. EPA. OAQPS. In addition. EPA's
Air Toxics Control Technology Center
has issued the following report:
20. Air Stripping of Contaminated
Water Sources. Air Emissions and
Control. July 20, 1987, Prepared for Air
Toxics Control Technology Center, U.S.
Environmental Protection Agency.
Research Triangle Park. North Carolina
27711.
Potential New Source Review (.VSR}
Measures
The primary approach a State could
follow to mitigate the effects of growth
by reductions through its NSR program
would be to subject more sources to
new source review.
The following measures are being
suggested for States to consider in their
control strategies as appropriate
techniques to deal with growth. Under
current rules, new sources and
modifications may be exempted from
the Part D major NSR requirements by:
(1^ Having a potential to emit below
certain thresholds [100 tons per year
(tpy) for new sources and 40 tpy of VOC
for modifications to existing major
sources]; (2) not being located in an area
designated as nonattainment under
section 107 of the Clean Air Act (Act):
and {3) qualifying for one of the specific
exemptions contained in the NSR
regulations (e.g.. conversion to
municipal wastes for power generation,
production increases not limited by a
permit increased operating hours).
Each of these situations has a
separate set of possible solutions or
revisions.
(1) Thresholds—The thresholds
contained in the NSR program could be
lowered to. say, 25 tpy for major sources
and major modifications. A significant
portion of the total VOC emissions
generally come from small sources, so
lowering en toffs would bring
significantly more of the VOC emissions
into the major NSR program Even 25 tpy
threshold may not cover a majority of
the emissions resulting from new
sources. One study has shown that for
VOCs. modifications and new sources
emitting less than 5 tpy compose 55
percent of total new VOC emissions.
(2) Location Outside Nonattainment
Area—States may wish to apply the
nonattainment area NSR requirements
of section 173 of the Clean Air Act (and
State programs under that section) to
sources located outside but near
designated nonattainment areas.
(3) Specific Exemptions—The
definitions currently contained in the
NSR program exempt certain increases
in emissions from being considered as a
modification. These exemptions allow
sources capable of accommodating
alternative fuels or raw materials to
switch fuels or raw materials (e.g., from
oil to coal) without being sub)ect to
major NSR requirements. Also, sources
may increase their operating hours (e g„
from 8 hours per day to 24 hours per
day) and throughput (e.g . from 60
percent of capacity) to the maximum
possible while meeting Federal NSR
requirements (unless the changes are
specifically limited by Federal
enforceable conditions). States could
remove these exemptions from the NSR
regulations.
Appendix D—Discrepancies and
Inconsistencies Found in Current SIP's
The EPA has reviewed a number of
SIP's and found inconsistencies and
discrepancies from established EPA
policy and guidance. The following
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45106 Federal Register / Vol. 52. No. 226 / Tuesday, November 24. 1987 / Notices
discussion lists the most prominent
problems and suggests corrections to
these problems. While no State or local
agencies are specifically identified. EPA
intends to discuss individual State and
local deficiencies with the appropriate
agencies at the time the SIP call is made.
a. Achieve Consistent Implementation
of New Source Review Programs
During its audits of State and local
NSR programs. EPA has found
considerable differences in how
agencies implement their NSR
regulations. EPA has found, for example,
that many major modifications of
sources escape preconstruction review
and that lowest achievable emission
reduction (LAER) determinations for
sources subject to NSR are often
inconsistent and insufficiently stringent.
In many cases, these problems may
result from improper interpretation of
the applicable rules. To minimize the
likelihood that this will occur in the
future, EPA intends to develop guidance
on such issues as how emissions
increases and decreases should be
calculated for netting purposes, when
and how implementing agencies may
use growth allowances as a substitute
for offsets, and how to ensure that best
available control technology and LA£R
determinations reflect the be3t
technology for the source in question
rather than simply the new source
performance standards control level.
The EPA also intends to increase its
auditing and enforcement of State
programs.
New Source Review Regulations
The primary focus of the new source
review regulations is to evaluate the
emissions impact of new or modified
source projects before construction
commences on the projects. The basic
requirement for a new source of air
pollution is to ensure that its emissions
do not cause any new nonattainment
situations or exacerbate any existing
nonattainment problems. All sources
must "prove." generally by modeling air
quality impacts before and after ;he
proposed change, that they do not cause
or contribute to any nonattainment
problem. For major new sources and
maior modifications wishing to locate in
designated nonattainment areas, the
applicant must also show that the most
stringent pollution control equipment
(LAER) is being installed, that ail other
sources owned by the applicant within
the State are in compliance (Statewide
compliance), and that the emission
increases are either offset or taken into
account with an approved growth
allowance (emission offsets). These
requirements are listed in the Clean Air
Act in sections 172 and 173.
The wording in some State NSR
regulations allows or has the potential
to allow certain sources to avoid some
or all of the intended requirements of
new source review. This is in conflict
with the Federal provisions, since State
rules can be more stringent than the
Federal provisions, but in no case can
they be less stringent. The EPA believes
that appropriate guidance and technical
support can help ensure that States
implement the new source review
regulations in conformance with EPA
policy: however. States may need to
correct or cianfy some of their
regulations to avoid possible
applicability or enforcement problems
that may arise under new source review
due to less stringent provisions. The
following areas are the focus of efforts
to achieve conformity with EPA policy.
Exemptions
Permit Conditions: Federal
requirements state that only federally
enforceable permit conditions may be
used to exempt a source from the
requirements for major sources. State
operating permits and State consent
decrees are not federally enforceable
unless incorporated into the SIP either
through EPA approved case-by-case
rulemaking or through a generic
mechanism. State preconstruction
permits issued by States under EPA-
approved SIP regulations pursuant to 40
CFR 51.18.51.24, or 51.30, as well as
construction permits issued by EPA or
by delegated States under 52.21 are
federally enforceable.
State Nonattainment Designations:
The EPA will not permit a State to
exempt sources located in
nonattainment areas that the State has
designated "attainment" without EPA
approval. Similarly, States will not be
permitted to use attainment
demonstrations that have not received
EPA approval to determine whether an
offset or netting transaction is consistent
with RFP.
General: States should revise their
regulations to remove any regulatory
provisions '.hat could be used to exempt
6ny source from any major NSR
requirements. The only exclusions
those contained in the Federal
definitions of major stationary souices
[40 CFR 51.165(a)(l)(iv)) or major
modifications [40 CFR 51.165(a)(l](v)|.
No source type (e.g., cotton gins,
resource recovery facility) or source
class (e.g. reactivated sources) may
have a blanket exemption from any new
source review requirement. This is a
problem under the major source and
major modification thresholds, since the
NSR provisions require that all emission
increases be accumulated for
applicability purposes. For example, a
single cotton gin may be a minor source,
while four cotton gins (under common
ownership) locating on one piece of land
would constitute a major source or
major modification. States may retain
exemptions from minor source
permitting requirements if (1) there
exists a federally approved growth
allowance to mitigate resulting
increases in emissions and (2) State
regulations expressly prohibit the use of
the exemptions to exempt any major
source or major modification from major
NSR requirements.
Clean Spot Exemption: As a result of
the August 1980 rulemaking which was
conducted as part of the Alabama
Power decision. State regulations cannot
contain provisions that exempt a source
from major new source review
requirements where the source does not
"significantly cause or contribute to a
violation of a National Ambient Air
Quality Standard." The August 1980
requirements subject any major source
or ma|or modification located in an EPA
designated nonattainment area to the
major NSR requirements regardless of
the ambient impact of the source. Some
SIP's, however, still retain this
exemption and should be revised.
Offset/Netting Requirements 112
Offsets: The EPA requires State
regulations to contain enforceable and
specific criteria on the credibility of
emission reductions as offsets. These
provisions must include a specific, well-
defined baseline for emission increases
and decreases, a requirement that all
emission reductions used for offsets be
federally enforceable (see section on
permit conditions above), certain
restrictions on the use of emission
reductions caused by prior shutdowns
and curtailments as offsets, and the
prohibition of the use of any emission
reductions already included m a State
.ittainment demonstration. The last
requirement listed is to ensure thdt a
Strife does rot use a reduction twice, i.e..
n . ,)T ? "'..-p If 2 , ,on. or r:t
r ;i ». '. ts!.»ny itnal r^oinii.in of
.,.-Ktna from the sntl.i-jJry
¦ .-"rtiir..®® to r.'.y \ i l"*u) promuU.jfion of :p\ •
\SR r ili»S I' " 'ft' ~ ' it furors 4y.v< r:; m \ >
EP \. No *>« 1\2. 0 C. C.r Ff»»r«Mry I'Jh:; ,y
.ilt*»r rPijtiirpmrn's S»** 48 KR JHT4J ;
25. '.MR')| i )ri>po5»*U re\ _uinn) Powpvnr unless
until FliAk ur..»»W :k.e rf'yvjnt r-yvjiuinuia
;he current requirements *pm«un in If j Sure'
chunqps :ts regulations to rr.ee: iVse requirement
and EPA then relaxes these requirements pursujnl
to this CMA settlement agreement. EPA wiil dllow
the States to change their applicable regulations as
appropriate.
-------
Federal Register ,j Vol. 52. No. 228 / Tuesday, November 24. 1987" / Notices
45107
once for attainment purposes and orrce
for .mitigation «f new scarce growth.
Netting: The EPA requires State
regulations to contain specific and
enforceable criteria if a Slate wishes to
allow a source to "net out" ai major
NSR review. A source "nets out" of
majocnew source review by securing
emission decreases within the source to
mitigate increases from the same source,
resulting in an "insignificant" emissions
increaae on a sourcewide basis. The
Federal regulations require the following
criteria for netting: (1) An "actual"
baseline: [2) health and welfare
equivalence between the emission
increases and decreases; (3) Federal
enforceability of emissions decreases
(see section on permit conditions
above); (4) a specific contemporaneous
time frame [up to 10 years); and (5) the
prohibition on the use of any reductions
already incorporated in a State's
attainment demonstration (see
discussion on offsetting above). The
health and welfare equivalence
generally focuses on the concept of air
quality; the air quality effects of the
proposed netting action must result in
equivalent or improved air quality. For
"stable" pollutants, this places an
emphasis on dispersion. For an ozone
nonattainment area, the relative
reactivities of the VOC species also
plays an important role in air quality
determinations. The State should not
allow a netting transaction that causes
an increase in a reactive VOC and a
decrease in a negligibly reactive VOC
even if the absolute amount of VOC
emitted does not increase significandy.
The contemporaneous timeframe is
needed to ensure that increases are
accumulated over a reasonable period of
time, to discourage construction projects
exempting themselves from NSR. and
ensure that decreases are not so old as
to already be taken into account in
attainment demonstrations. Also, if a
reduction occurred a very long time ago.
that reduction should go towards
assisting an area to show attainment
rather than assisting a source to avoid
major NSR requirements.
Definitions
VOC: NSR regulations 3'nould use a
VOC definition that defines VOC as ail
organic compounds except those '.hat
EPA has listed in its Federal Register
notices as nonphotochemically reactive.
(See VOC definition m RACT
regulations discussion.)
Other NSR regulations should contain
clear definitions, consistent with Federal
requirements, for the following terms:
Stationary source; actual emissions:
allowable emissions: fugitive emissions:
commence or begin construction;
building, structure, or facility; and major
stationary source. State regulations that
do not contain good, concise definitions
that meet the Federal requirements risk
treating sources inequitably because of
varying interpretations of the
definitions. For example, minor
variations in a State rule regarding the
LAER definition which appear
unimportant could allow a source to
avoid installing proven technology by
arguing that it costs too much, a result
that is unacceptable using the EPA
definition. The definitions must provide
a framework to make decisions
replicable among sources.
Small Sources
Lack of Minor Source and Minor
Modification Review: As required by
the Federal rules, SIP's should require a
review program of all sources of air
pollution regardless of size. This review
must include an assurance that no new
source or modification will interfere
with attainment and maintenance of the
standard as well as a requirement that
all construction projects be subject to
public comment procedure. Many States
only have requirements for major
sources and major modifications. States
may only exempt minor sources from
these requirements if (1) there exists a
federally approved growth allowance to
mitigate resulting increases in emissions
and (2) State regulations expressly
prohibit the use of exemptions to
exempt any major source or major
modifications from NSR requirements.
b. Ensure Conformity of SIP's With
Existing EPA Policy
Although most SIP regulations have
met the terms of EPA's requirements for
Part D plans. EPA may have approved
some SIP's containing rules that do not
meet those requirements.
Some State regulations controlling
VOC emissions are being implemented
in a manner that is not consistent with
EPA requirements and policies and can,
in certain cases, significantly interfere
with the effectiveness of those
regulations. These implementation
problems appear to be caused by
:.-correct or ambiguous definitions,
variable interpretation, the lack of key
provisions (e.g.. compliance times, test
methods, etc.). or specific provisions in
State regulations that are inconsistent
with current EPA policies. In some
cases, these problems can interfere with
the States" ability to (1) secure their
expected emissions reductions from
stationary source RACT regulations or
(2) control emission growth through their
N'SR regulations. EPA plans to work
with States to identify these problem
areas and provide training, guidance.
and other technical support to ensure
that RACT and NSR regulations are
effectively implemented.
Stationary Source RACT Regulations
The existing RACT regulations were
developed as a major component of the
SIP strategies to achieve VOC emissio' 1
reductions. The following describes thi;
areas where RACT regulations have
been adopted and/or implemented on
an inconsistent basis.
RACT Regulation Exemptions
Many of the CTG's that EPA issued in
the late 1970's recommended that States
exempt from their RACT rules only
those sources falling below certain size
or throughput cutoffs. Other CTG's
recommended no such cutoffs. Some of
the RACT regulations now in the SIP's,
however, establish exemptions wider
than those recommended in the CTG's
or provide exemptions so ambiguous as
to be susceptible to abuse. The EPA will
require the States to amend such rules to
ensure that these exemptions conform to
the CTG recommendations in all cases
except those for which the State
provides adequate justification that the
CTG level would impose unreasonable
requirements in that State.
Definition of 100 Tons Per Year Source
The EPA guidance has called on SEP'3
for extension areas to require RACT for
sources with the potential to emit more
than 100 tons per year (tpy), but that do
not fall into a CTG category. Although
EPA intended the definition of source
for this purpose to be the entire plant,
some SIFs are susceptible to an
interpretation requiring RACT only for
individual emissions units emitting more
than 100 tpy. Also, some SIP's are
susceptible to a reading under which the
source must apply RACT only if it has a
potential to emit more than 100 tpy with
controls. EPA intended, however, to
have States apply RACT to non-CTG
sources emitting more than that amount
without controls. Therefore. EPA intends
to require the relevant States to amend
VOC rules that do not clearly reflect
EPA's intent.
Other Issues
Existing VOC ruies contain a variety
of othtr ambiguities and exemptions
thut may impede efforts to achieve full
RACT-ievel reductions. Although some
of the affected State or local agencies
currently interpret these rules
consistently with EPA policy, courts will
frequently turn to the actual words of
the rules to decide the legal obligations
of the affected sources. For that reason.
EPA believes it is essential for States to
-------
45108
Federal Register / Vol. 52. No. 226 / Tuesday, November 24. 1087 / Notices
amend these roles to state clearly what
is required. Until the States change
these rules, the Agency will continue to
interpret them consistent with EPA's
intent when it approved them and will
encourage the relevant State or local
agencies to do the same. Examples of
these deficiencies are described
generally below.
Emission Limit Units: VOC rules
incorporating limits expressed as
pounds of VOC per gallon (lb VOC/gal)
of coating should also list the equivalent
lb VOC/gal of solids emission limit. It
will be acceptable but not mandatory to
totally replace pounds of VOC per
gallon of coating units with units of lbs
VOC per gallon of solids. VOC rule3
should state that units of lbs VOC/gal of
solids be used for all calculations
involving emission trades, cross-line
averaging, and determining compliance
by add-on control equipment such as
incinerators and carbon adsorbers.
Exempt Solvents: Compliance
calculations for coatings expressed as lb
VOC/gallon coating (less water) should
treat exempt solvents such as 1.1,1-
trichloroethane and methylene chloride
as water for purposes of calculating the
"less water" part of the coating
composition.
VOC Definitions: These rules should
define VOC as all organic compounds
except those that EPA has listed as
photochemically nonreactive in its
Federal Register notices. Many rules
incorrectly contain a vapor pressure
cutoff (e.g., 0.1 mmHg) that effectively
exempts some photochemically reactive
compounds (such as butyl dioxitol. a
paint solvent, and certain mineral oils)
from control. The following definition is
a model for use:
Volatile Organic Compound (VOC)—Any
organic compound which participates in
atmospheric photochemical reactions: that is.
any organic compound other than those
which the Administrator designates hs having
negligible photochemical reactivity. VOC
may be measured by a reference method, an
equivalent method, an alternative method or
by procedures specified under 40 CFR Part 60.
A reference method, an equivalent method, or
an alternative methud. however, may aiso
measure nonreactive organic corrmoiinas. !n
such cases, an owner or operator may
exulude the nonreactive organic cumonunds
when determining compliance with a
standard.
Other Definitions: A variety of other
definitions in VOC rules are inconsistent
with EPA's CTG's. EPA proposes to
identify these deficiencies and require
the States to remedy them.113
"* For example, definitions of "coatinq line"
should not exempt from control coaling lines that Jo
not have bake ovens. Also, definition] of
"reflniihing" in miscellaneous melal codling rules
Transfer Efficiency: Transfer
efficiency is a measure of how
efficiently coating solids are applied to
the objects being coated in spray
coating operations. Increasing transfer
efficiency reduces the amount of coating
used for a particular job and may
thereby reduce VOC emissions. Some
States have attempted to provide
sources with credit for transfer
efficiency improvements.
The EPA proposes to require that
sources be allowed to seek credit for
transfer efficiency improvements only if
the SIP specifies a baseline transfer
efficiency and a test method acceptable
to EPA for determining actual transfer
efficiency. (The use of default, assumed
or table transfer efficiency values would
be unacceptable.) This could be done
either with general or source-specific
SIP revisions.
Cross Line A veraging: A source may
use crossiine averaging only upon (1)
EPA approval as a source-specific SIP
revision or (2) State adoption under a
cross-line averaging or equivalency rule
that EPA has approved genencally.
Compliance Periods: VOC rules
should describe explictly the compliance
timeframe associated with each
emission limit (e.g., instantaneous or
daily). However, where the rules are
silent on compliance time. EPA will
interpret it as instantaneous. The rules
could include periods longer than 24
hours only in accordance with the
memorandum from John O'Connor.
Acting Director of the Office of Air
Quality Planning and Standards, dated
January 20.1984. entitled "Averaging
Times for Compliance With VOC
Emission Limits-SIP Revision Policy."
and only as source-specific SIP
revisions.
Recordkeeping: The EPA would
require States to amend their VOC rules
to require explicitly that sources keep
records needed to assess compliance for
the timeframe specified in the rule.
Records must be commensurate with
regulatory requirements and must be
available for examination on request.
The SiP must qive reporting schedules
>non»d ."n.ike uear that ''n-line" or f.na! off-!.n«•
•I'o-ni rcv orumni equipment manufacturers is not
Rptmisiung U« Ot">ne
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Federal Register / Vol- 52. No- 226 / Tuesday, November 24. 1987 / Notices
45109
monitoring requirements. The EPA
believes that inaccessible and unsafe-to-
monitor valves should be monitored as
often as practicable because of the
potential for finding leaks and reducing
emissions. The EPA does not consider
annual monitoring or monitoring at
shutdown to be an unreasonable burden
for inaccessible and unsafe-to-momtor
valves.
For natural gas plants. RACT should
apply to equipment that contains or
contacts a process stream with a VOC
concentration of 1.0 percent by weight
or more. Equipment with process
streams containing relatively low
percentages of VOC (i.e.. between 1.0
and 10.0 percent) contributes a
significant portion of total emissions
from natural gas plants and. therefore, is
subject to RACT requirements.
Exemptions and Variances: Many
SIFs contain provisions giving the State
authority to grant variances,
exemptions, and alternative means of
control strategies. SIP's must clearly
state whether EPA approval of such
variances is required on a case-by-case
basis before such a variance, exemption,
or alternative means becomes federally-
effective. Provisions that are intended to
be generic (i.e., not requiring case-by-
case EPA approval for the alternative
means to be federally-effective) must
meet the general principle of
replicability described in EPA's
Emissions Trading Policy Statement (51
FR 43814, December 4.1986).
Appendix E—-Guidance Document on
Enhanced I/M
/. Introduction
The EPA.has considered the potential
for greater VOC and CO reductions from
vehicle inspection and maintenance
programs, and believes that substantial
enhancement is available.
The EPA is considering a variety of
options relative to enhanced I/M.
including establishing a specific
enhanced I/M performance level for
some nonattainment areas as well as
relying on the 3 percent reduction
requirement to force consideration of
enhanced 1/M in lieu of a mandated
performance requirement. The latter
option would allow States ;o consider
the benefits of enhanced I/M. along with
those of other control measures, in
deciding how to meet the 3 percent
average annual reduction requirement.
The other option toward which EPA is
presently learning would be to establish
a specific enhanced I/M requirement for
areas with relatively serious ozone or
CO nonattainment problems. The
remainder of this appendix describes
aspects of and issues related to a
separate enhanced I/M requirement, if
adopted. .
Possible enhancements fall into four
categories. First operating losses due to
improper inspections, incomplete
enforcement or lenient repair waiver
systems can be reduced. Second,
additional vehicles which are exempt
based on age. or vehicle type can be
made subject to the inspection
requirement Third, the emission test
portion of the periodic inspection can be
made more sophisticated or the pass/
fail limits or cutpoints more stringent.
Fourth, important emission control
components can be checked visually, or
by other means that do not involve
emissions measurement, for evidence of
tampering or misfueling.
The concept of "enhanced I/M."
therefore, covers both increases to the
coverage and stringency of inspection,
and improved management practices to
assure full effectiveness. The
requirements being considered for area3
adopting enhanced I/M are explained in
detail below.
[I. Background
In 1978. EPA first established policy
for the implementation of the I/M
programs required under the Clean Air
Act Amendments of 1977. This policy
addressed the elements to be included
in SIP revisions, minimum emission
reduction requirements, administrative
requirements, and schedules for
implementation. Approvable I/M
programs were to be in place in all
ozone and CO extension areas by the
end of 1982. and were to produce at
least a 25 percent reduction in light-duty
vehicle hydrocarbon exhaust emissions
and at least 3 percent reduction in CO
exhaust emissions as of the end of 1987.
At this time, there are I/M programs
operating in 60 urban areas in 32 States.
There are a variety of program designs
in place, some which just exceed
minimum levels, and some which
contain additional measures to achieve
greater emission reductions. The EPA
audits of I/M programs over the last 3
years have identified both considerable
accomplishments by State and local
agencies in implementing programs
successfully, and a number of operating
problems. These audit findings serve a3
the basis for the increased stringency
ana the additional administrative
requirements associated with enhanced
1/M.
III. New Performance Standard for VOC
and CO Reductions
The EPA has developed a computer
model which it proposes to use to assess
the benefits of various I/M program
designs, expressed as annual tons of
reduction from a typical urban fleet of
one million vehicles. The model is based
on MOBILE3, but performs additional
manipulations of the emission estimates.
The assumptions employed in this
computer model are explained in detail
in the technical report, entitled "Method
for Estimating the Cost-Effectiveness of
Inspect. on/Maintenance Program
Designs."
The LPA is leaning toward a nominal
performance standard to be achieved by
enhanced I/M of 5700 tons of HC and
69.000 tons of CO per year per million
light-duty vehicles over the first 5 years
of operation of the enhanced program.
This level represents the design levei of
the third most stringent of the 27 or so
distinct I/M programs currently in
operation. As discussed in the preamble
of this policy, EPA is also considering
other performance levels which could be
established, if a separate enhanced I/M
requirement is adopted. The level of
performance desenbed above would be
equivalent to the following design:
—Centralized biennial inspections
—20 model years of passenger cars and
light trucks
—20 percent stringency for pre-1981
vehicles
—Idle test
—207(b) cutpoints for 1981 + vehicles
(1.2 percent CO/220 ppm HC)
—Catalyst inlet, and lead deposit
inspections on 1981 + vehicles
—5 percent waiver on the emission
short test
Programs which vary from this design
yet have equivalent emission reductions
would be acceptable. For example,
decentralized biennial inspections and/
or fewer model years of coverage are
also allowed, provided other features of
the program design are strengthened
such that the estimated benefit meets
the new performance standard.
Programs may show equivalency to
this design using either national or local
conditions of tampering/misfueling
rates, vehicle type mix. average speed,
etc. Use of local conditions may result in
a performance standard different than
5700/69.000: in all cases, equivalency :o
the above design would be the
controlling criterion for approval.
l'he new computer model has two
features which were not included in
¦MOBILE3 but which grew out of the past
3 years of evaluating operating
programs. First, for purposes of SIP
approval, decentralized programs will
be credited with identifying and
repairing existing tampering at a rate
which is less than that modeled for
centralized programs. The initial
analysis suggests a reduced
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