APPENDIX J 

REASONABLY AVAILABLE CONTROL TECHNOLOGY ANALYSIS
J-2

REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS

Introduction

Under the one-hour ozone National Ambient Air Quality Standard (NAAQS), the four-county 

DFW area, consisting of Collin, Dallas, Denton, and Tarrant Counties, was classified as a serious 

nonattainment area. The eight-hour ozone NAAQS classifies the nine-county DFW area, 

consisting of Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant 

Counties, as a moderate nonattainment area. Under the eight-hour ozone standard, the ninecounty DFW area is required to meet the RACT mandates of the Federal Clean Air Act (FCAA) 

under §172(c)(1), §182(b)(2) and §182(f). According to the United States Environmental 

Protection Agency’s (EPA’s) Final Rule to Implement the Eight-Hour Ozone NAAQS – Phase 2 

(40 Code of Federal Regulations (CFR) §51.912, November 29, 2005), areas classified as 

moderate nonattainment or higher must demonstrate, by revision to their SIP, that their current 

rules fulfill eight-hour RACT for all Control Technique Guidelines (CTG) categories and all nonCTG major sources of NOX and VOC emissions. 

RACT is defined as the lowest emissions limitation that a particular source is capable of meeting 

by the application of control technology that is reasonably available considering technological 

and economic feasibility (44 Federal Register (FR) 53762; September 17, 1979). RACT 

requirements for moderate nonattainment areas are included in the FCAA to assure that 

significant source categories at major sources of ozone precursor emissions are controlled to a 

reasonable extent, but not necessarily to best available control technology (BACT) levels 

expected of new sources or maximum achievable control technology (MACT) required for major 

sources of hazardous air pollutants. 

RACT Demonstration 

The TCEQ demonstrates that the RACT requirements are being fulfilled in the DFW eight-hour 

ozone nonattainment area by (1) identifying all CTG source categories of VOC and NOX

emissions and submitting negative declarations for categories where there are no major emission 

sources within the DFW area; (2) identifying all non-CTG major sources of VOC and NOX

emissions; (3) identifying the state regulation that implements or exceeds RACT for each 

applicable CTG source category or non-CTG major emission source; and (4) describing the basis 

for concluding that these regulations fulfill RACT. 

Identification of CTG and Non-CTG Emission Sources 

The EPA has issued CTG documents defining RACT for existing facilities that emit large 

amounts of air pollutants and Alternative Control Technology (ACT) documents that describe 

available control technologies but do not define presumptive RACT levels. The TCEQ reviewed 

EPA CTG and ACT documents to identify all source categories of NOX and VOC emissions that 

require RACT. RACT determinations are not required if there are no facilities in the DFW eighthour ozone nonattainment area that are subject to a CTG or ACT document. A negative 

declaration is provided for source categories described within the EPA guidance documents that 

do not exist in the DFW area. 

To identify all non-CTG major source categories, the TCEQ reviewed its emission inventory 

database for all major sources of NOX or VOC emissions not covered by a CTG. Under the 

EPA’s eight-hour ozone regulations for moderate ozone nonattainment areas, the threshold for 

major stationary sources is 100 tons per year (tpy) of either VOC or NOX emissions. Since the 

emission inventory database reports actual emissions rather than potential to emit, the TCEQ 

looked at sources that reported as few as 50 tpy or more of actual emissions to identify all nonCTG major source categories of NOX and VOC emissions. 

Determining if State Regulations Fulfill RACT Requirements 

The TCEQ examined the rules in Title 30 of the Texas Administrative Code (TAC) Chapters 115 

and 117 to verify that the current state rules satisfy the corresponding RACT requirements for all 
J-3

applicable CTG source categories and non-CTG major emission sources. To determine if the 

control technologies associated with the existing state emission specifications fulfill RACT 

requirements for the relevant unit types, the TCEQ compared the existing state regulations to the 

controls contained in the CTG and ACT guidance documents. State regulations that implement 

the controls suggested in CTG and ACT documents or that implement equivalent emission 

control strategies were determined to fulfill RACT requirements. 

The TCEQ also reviewed new technologies that are now considered RACT by the EPA and 

current control technologies and methodologies implemented as RACT in other moderate 

nonattainment areas. Current technologies and methodologies were examined to identify nonCTG emission source categories that are regulated by other moderate nonattainment areas, to 

ensure there are no new economically or technologically feasible controls that could be 

implemented in the DFW area, and to verify that the state rules fulfill RACT requirements. The 

TCEQ also evaluated control technologies suggested during the public comment period for recent 

rule projects. State rules that were consistent with or more stringent than the current control 

technologies and methodologies implemented in other moderate nonattainment areas were also 

determined to fulfill RACT requirements. 

The EPA must evaluate SIP-related rules prior to approval to determine if those rules fulfill all 

applicable EPA guidelines and policies and therefore, any EPA SIP-approved rules were 

determined to meet RACT requirements at the time of federal approval. Federally approved state 

rules, especially those rules that were approved many years ago, were evaluated to determine if 

the existing rules still fulfill RACT requirements. Federally approved state rules and rule 

approval dates can be found in 40 CFR §52.2270(c) EPA Approved Regulations in the Texas SIP. 

BACT is an emission limitation based on the maximum degree of emission reduction 

(considering energy, environmental, and economic impacts) achievable through application of 

production processes and available methods, systems, and techniques. BACT does not permit 

emissions in excess of those allowed under any applicable FCAA provisions. MACT is the 

emission standard for sources of air pollution requiring the maximum reduction of hazardous 

emissions, taking cost and feasibility into account. Under the FCAA Amendments of 1990, the 

MACT must not be less than the average emission level achieved by controls on the best 

performing 12 percent of existing sources, by category of industrial and utility sources. 

Therefore, emission sources subject to the more stringent BACT or MACT requirements were 

determined to also fulfill RACT requirements. 

Conclusion 

Table J-1: State Rules Addressing RACT Requirements in CTG and ACT Reference Documents

provides the emission source categories, the CTG and ACT reference documents, and the state 

rules addressing the RACT requirements for sources in the CTG and ACT documents. Table J-1 

also includes non-CTG NOX emission source categories, identified during the current technology 

and methodology evaluation, for which other nonattainment areas have adopted RACT 

regulations. A negative declaration is provided in the table for emission source categories that are 

described within the EPA guidance documents which, based on information available to the 

TCEQ, either do not exist in the DFW eight-hour area or exist but are not considered major 

sources and are therefore not required to demonstrate RACT compliance. All CTG source 

categories and non-CTG major emission sources in the DFW eight-hour ozone nonattainment 

area are controlled by source specific state rules that fulfill RACT requirements or are controlled 

by standards that meet or exceed what would otherwise be considered RACT. 

Table J-2: State Rules Addressing RACT Requirements for Major Emission Sources in the DFW 

Eight-Hour Ozone Nonattainment Area lists the major stationary emission sources in the DFW 

area with actual emissions, as reported in the TCEQ emissions inventory, equal to or greater than 

50 tpy. Table J-2 provides the emission source account number, company name, standard 

industrial classification (SIC) code, a brief description of the source, and the reported annual 
J-4

emissions (in tpy). Table J-2 also includes either the state rules satisfying the RACT 

requirements, the permit requirements that limit emissions, or the reasoned justification for why 

controlling the emissions is not considered RACT. Most major stationary emission sources in the 

DFW eight-hour ozone nonattainment area are controlled by source specific state rules that fulfill 

RACT requirements or are controlled by standards that meet or exceed what would otherwise be 

considered RACT. In some instances however the TCEQ has determined that controlling 

emissions from some sources is not economically feasible and thus is not considered RACT for 

the state. 

Basis for Concluding State Regulations Fulfill RACT Requirements 

The EPA proposed to approve RACT for all major sources of VOC emissions in the four-county 

DFW one-hour ozone nonattainment area on November 18, 2001, and received no comments (66 

FR 4756). On August 22, 2006, the EPA proposed to approve the DFW 5 percent Increment of 

Progress (IOP) SIP and stated their intention to finalize approval of the DFW 5 percent IOP SIP 

and the one-hour RACT in the same rulemaking (71 FR 48870). The DFW 5 percent IOP SIP 

extended the applicability of certain RACT requirements to include all nine counties in the DFW 

eight-hour ozone nonattainment area. On November 15, 2006, the TCEQ adopted rules extending 

the applicability of the remaining control, monitoring, testing, recordkeeping, and reporting 

requirements in 30 TAC Chapter 115 to include all nine counties in the DFW eight-hour ozone 

nonattainment area. With the adoption of these rules the new five counties are subject to the 

same rules that EPA has proposed to approve as RACT for the original four-county DFW area. 

The only comment the TCEQ received regarding additional controls was a suggestion that 

thermal oxidizers be used to control VOC emissions from cement kilns. As discussed in the 

preamble to the adopted rule (rule project number 2006-011-115-EN) the use of thermal oxidizers 

does not represent RACT for control of VOC emissions from cement kilns because it is not 

economically reasonable. In addition, since modeling discussed in Chapter 2 of this SIP revision 

indicates the reduction of VOC emissions has less benefit in reducing ozone levels than reduction 

in NOX emissions, the level of control required by the rules in 30 TAC Chapter 115 represents 

RACT for the nine-county DFW area. 

The emission specifications for attainment demonstration in 30 TAC §117.400 – §117.456 

regulate all major sources of NOX emissions in the DFW eight-hour ozone nonattainment area. 

Due to the significant NOX emissions reductions necessary to demonstrate ozone attainment in 

DFW, these emissions specifications are equal to or more stringent than the emission limits 

associated with the controls contained in the CTG and ACT guidance documents and current 

control technologies and methodologies implemented as RACT in other moderate nonattainment 

areas. Additional discussion on the basis for determining these NOX emission specifications for 

attainment demonstration can be found in the preamble to the Chapter 117 rulemaking (rule 

project number 2006-034-117-EN). 

The TCEQ received comments suggesting emission control strategies for cement kilns in Ellis 

County. Based on review of the 2006 cement kiln study and all other available information, the 

TCEQ has determined that all technologically or economically feasible controls are being 

implemented in the DFW eight-hour ozone nonattainment area. The 2006 cement kiln study can 

be found in Appendix I: Assessment of NOX Reduction Strategies for Cement Kiln - Ellis County, 

Final Report (July 14, 2006). Additional discussion on the basis for this conclusion can be found 

in the response to comments sections of both the preamble to the Chapter 117 rules and the DFW 

Attainment Demonstration SIP (rule project numbers 2006-034-117-EN and 2006-013-SIP-EN 

respectively). 

The TCEQ has compared the existing state rules in 30 TAC Chapters 115 and 117 to the current 

RACT standards and determined that these rules fulfill the RACT requirements for the eight-hour 

ozone NAAQS. The emission source categories in the DFW eight-hour ozone nonattainment area 

have been reviewed and evaluated to determine appropriate emission specifications, control 
J-5

requirements, and associated control technologies for those source categories. The TCEQ has 

determined that the controls adopted with this rulemaking are available, reasonable, and 

necessary to help the DFW eight-hour ozone nonattainment area achieve the eight-hour ozone 

NAAQS. All CTG source categories and non-CTG major emission sources in the DFW eighthour ozone nonattainment area, for which RACT is technologically and economically feasible, 

are controlled by source specific state rules that fulfill RACT requirements or are controlled by 

standards that meet or exceed what would otherwise be considered RACT. 
J-6

Table J-1: State Rules Addressing RACT Requirements in CTG and ACT Reference Documents

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

VOC Emissions 

Aerospace Guideline Series: Control of Volatile 

Organic Compound Emissions from 

Coating Operations at Aerospace 

Manufacturing and Rework Operations 

(EPA-453/R-97-004, EPA-68/D1-

00115, EPA-453/D-96-016, December 

1997) 

(see 59 FR 29216, June 6, 1994) 

§115.420 – §115.429 

Agricultural 

Pesticides 

Control of Volatile Organic Compound 

Emissions from the Application of 

Agricultural Pesticides 

(EPA-450/R-92-011, March 1993) 

The TCEQ does not regulate the 

use of agricultural pesticides and 

this ACT document does not give 

presumptive control therefore, no 

RACT determination is required 

for this source category. 

Architectural and 

Industrial 

Maintenance 

Coatings 

Reduction of Volatile Organic 

Compound Emissions from Application 

of Traffic Markings 

(EPA-450/3-88-007, August 1988) 

Emissions from this source 

category are regulated by the 

AIM National Rule. 

Automobile 

Coating 

The Reduction of Volatile Organic 

Compound Emissions from Automobile 

Refinishing 

(EPA-450/3-88-009, October 1988) 

§115.420 – §115.429 

Automobile 

Refinishing 

Alternative Control Techniques 

Document: Automobile Body 

Refinishing 

(EPA-453/R-94-031, April 1994) 

§115.420 – §115.429 

Batch Processes Alternative Control Techniques 

Document: Control of Volatile Organic 

Compound Emissions from Batch 

Processes 

(EPA-453/R-93-017 or EPA 453/R-93-

020, February 1994) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

2821, 2833, 2834, 2861, 2865, 

2869, and 2879). 

Bulk Gasoline 

Plants 

Control of Volatile Organic Emissions 

from Bulk Gasoline Plants 

(EPA-450/2-77-035, December 1977) 

§115.211 – §115.219 

Cleaning Solvents Alternative Control Techniques 

Document: Industrial Cleaning 

Solvents 

(EPA-453/R-94-015, February 1994) 

§115.412 – §115.419 

§115.420 – §115.429 

Commercial 

Bakeries 

Alternative Control Techniques 

Document: Bakery Ovens 

(EPA-453/R-92-017, December 1992) 

§115.120 – §115.129 

Cutback Asphalt Control of Volatile Organic 

Compounds from Use of Cutback 

Asphalt 

(EPA-450/2-77-037, December 1977) 

§115.510 – §115.519 

Ethylene Oxide 

Sterilization/ 

Fumigation 

Operations 

Alternative Control Technology 

Document: Ethylene Oxide 

Sterilization/Fumigation Operations 

(EPA-450/3-89-007, March 1989) 

Emissions from this source 

category are regulated by MACT 

per §113.200. 
J-7

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

Fugitive 

Emissions 

Fugitive Emission Sources of Organic 

Compounds – Additional Information 

on Emissions, Emission Reductions, 

and Costs 

(EPA-450/3-82-010, April 1982) 

§115.352 – §115.359 

Gasoline Service 

Stations 

Design Criteria for Stage I Vapor 

Control Systems - Gasoline Service 

Stations 

(November 1975) 

§115.221 – §115.229 

Graphic Arts Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume VIII: Graphic Arts - 

Rotogravure and Flexography (EPA450/2-78-033, December 1978) 

§115.430 – §115.439 

Graphic Arts Control of Volatile Organic Compound 

Emissions from Offset Lithographic 

Printing (September 1993) 

§115.440 – §115.449 

Graphic Arts Alternative Control Technology 

Document: Offset Lithographic 

Printing 

(EPA-453/R-94-054, June 1994) 

§115.440 – §115.449 

Industrial 

Wastewater 

Control Techniques for Industrial 

Wastewater 

(EPA-453/D-93-056, September 1992) 

(ACT: April 1994, consists of cover 

memo with option tables and CTG) 

§115.140 – §115.149 

Ink and Paint 

Manufacturing 

Alternative Control Technology 

Document: Control of Volatile Organic 

Compounds from Ink and Paint 

Manufacturing 

(EPA-453/3-92-013) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

2842 and 2851). 

Leather Tanning 

and Finishing 

Operations 

Alternative Control Technology 

Document: Leather Tanning and 

Finishing Operations 

(EPA-453/R-93-025) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

3111). 

Metal Furniture Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume III: Surface Coating of Metal 

Furniture 

(EPA-450/2-77-032, December 1977) 

§115.420 – §115.429 

Natural 

Gas/Gasoline 

Processing 

Control of Volatile Organic Compound 

Equipment Leaks from Natural 

Gas/Gasoline Processing Plants 

(EPA-450/2-83-007, December 1983) 

§115.352 – §115.359 

Petroleum Dry 

Cleaners 

Control of Volatile Organic Compound 

Emissions from Large Petroleum Dry 

Cleaners 

(EPA-450/3-82-009, September 1982) 

Contingency Measures: 

§115.552 – §115.553 

§115.555 – §115.557 

§115.559 

Petroleum Liquid 

Storage 

Control of Volatile Organic Emissions 

from Storage of Petroleum Liquids in 

Fixed Roof Tanks 

(EPA-450/2-77-036, December 1977) 

§115.112 – §115.119 

Petroleum Liquid Control of Volatile Organic Emissions §115.112 – §115.119 
J-8

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

Storage from Petroleum Liquid Storage in 

External Floating Roof Tanks 

(EPA-450/2-78-047, December 1978) 

Petroleum Liquid 

Storage 

Alternative Control Techniques 

Document: Volatile Organic Liquid 

Storage in Floating and Fixed Roof 

Tanks 

(EPA-453/R-94-001, January 1994) 

§115.112 – §115.119 

Plywood Veneer 

Dryers 

Control Techniques for Organic 

Emissions from Plywood Veneer 

Dryers 

(EPA-450/3-83-012, May 1983) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

2435 and 2436). 

Process Vents Alternative Control Technology 

Document: Organic Waste Process 

Vents 

(EPA-450/3-91-007, December 1990) 

§115.120 – §115.129 

Refineries Control of Refinery Vacuum Producing 

Systems, Wastewater Separators, and 

Process Unit Turnarounds 

(EPA-450/2-77-025, October 1977) 

§115.311 – §115.319 

§115.131 – §115.139 

Refineries Control of Volatile Organic Compound 

Leaks from Petroleum Refinery 

Equipment 

(EPA-450/2-78-036, June 1978) 

§115.352 – §115.359 

Rubber Tires Control of Volatile Organic Emissions 

from Manufacture of Pneumatic 

Rubber Tires 

(EPA-450/2-78-030, December 1978) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

3011). 

Shipbuilding and 

Ship Repair 

Control Technique Guidelines for 

Shipbuilding and Ship Repair 

Operations 

(EPA-453/R-94-032, April 1994 ) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

3731). 

Shipbuilding and 

Ship Repair 

Control Technique Guidelines for 

Shipbuilding and Ship Repair Surface 

Coating Operations 

(61 FR 44050, August 27, 1996) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

3731). 

Solvent Cleaning Control of Volatile Organic Emissions 

from Solvent Metal Cleaning 

(EPA-450/2-77-022, November 1977) 

§115.412 – §115.419 

§115.420 – §115.429 

Solvent Cleaning Alternative Control Technology 

Document: Halogenated Solvent 

Cleaners 

(EPA-450/3-89-030, August 1989) 

§115.412 – §115.419 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume I: Control Methods for Surface 

Coating Operations 

(EPA-450/2-76-028, November 1976) 

§115.420 – §115.429 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume II: Surface Coating of Cans, 

Coils, Paper, Fabrics, Automobiles, and 

Light-Duty Trucks 

§115.420 – §115.429 
J-9

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

(EPA-450/2-77-008, May 1977) 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume IV: Surface Coating for 

Insulation of Magnet Wire 

(EPA-450/2-77-033, December 1977) 

§115.420 – §115.429 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume V: Surface Coating of Large 

Appliances 

(EPA-450/2-77-034, December 1977) 

§115.420 – §115.429 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume VI: Surface Coating of 

Miscellaneous Metal Parts and 

Products 

(EPA-450/2-78-015, June 1978) 

§115.420 – §115.429 

Surface Coating Control of Volatile Organic Emissions 

from Existing Stationary Sources, 

Volume VII: Factory Surface Coating 

of Flat Wood Paneling 

(EPA-450/2-78-032, June 1978) 

§115.420 – §115.429 

Surface Coating Alternative Control Techniques 

Document: Surface Coating of 

Automotive/Transportation and 

Business Machine Plastic Parts 

(EPA-453/R-94-017, February 1994) 

§115.420 – §115.429 

Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Emissions 

from Manufacture of Synthesized 

Pharmaceutical Products 

(EPA-450/2-78-029, December 1978) 

§115.531 – §115.539 

Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Compound 

Emissions from Manufacture of HighDensity Polyethylene, Polypropylene, 

and Polystyrene Resins 

(EPA-450/3-83-008, November 1983) 

§115.120 – §115.129 

Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Compound 

Fugitive Emissions from Synthetic 

Organic Chemical Polymer and Resin 

Manufacturing Equipment 

(EPA-450/3-83-006, March 1984) 

§115.352 – §115.359 

Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Compound 

Emissions from Air Oxidation 

Processes in Synthetic Organic 

Chemical Manufacturing Industry 

(EPA-450/3-84-015, December 1984) 

§115.120 – §115.129 

Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Polystyrene Foam Manufacturing 

(EPA-450/3-90-020, 1990) 

§115.120 – §115.129 

Synthetic Organic 

Chemical 

Manufacturing 

Control of Volatile Organic Compound 

Emissions from Reactor Processes and 

Distillation Operations in Synthetic 

§115.120 – §115.129 
J-10

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

Industry Organic Chemical Manufacturing 

Industry 

(EPA-450/4-91-031, August 1993) 

Tank Trucks Control of Hydrocarbons from Tank 

Truck Gasoline Loading Terminals 

(EPA-450/2-77-026, December 1977) 

§115.211 – §115.219 

§115.221 – §115.229 

Tank Trucks Control of Volatile Organic Compound 

Leaks from Gasoline Tank Trucks and 

Vapor Collection Systems 

(EPA-450/2-78-051, December 1978) 

§115.211 – §115.219 

§115.234 – §115.239 

Vegetable Oil 

Manufacturing 

Control of Volatile Organic Emissions 

from Manufacture of Vegetable Oils 

(EPA-450/2-78-035, June 1978) 

No existing major sources in the 

DFW eight-hour ozone area (SIC 

2046 and 2076). 

Wood Furniture 

Manufacturing 

Guideline Series: Control of Volatile 

Organic Compound Emissions from 

Wood Furniture Manufacturing 

Operations 

(EPA-453/D-95-002) 

§115.420 – §115.429 

Wood Furniture 

Manufacturing 

Guidelines Series: Control of Volatile 

Organic Compound Emissions from 

Wood Furniture Manufacturing 

Operations 

(EPA-453/R-96-007, April 1996) 

(see also 61 FR 25223, and, 61 FR 

50823, September 27, 1996) 

§115.420 – §115.429 

NOX Emissions 

Brick & Ceramic 

Manufacturing 

Non-CTG Major NOX Source §117.410(b)(7)(B) 

Cement 

Manufacturing 

NOX Emissions from Cement 

Manufacturing 

(EPA-453/R-94-004, March 1994) 

(Updated September 2000) 

§117.3110(a) – (f) & §117.3123 

Coke, Wood, Rice, 

and Other 

Biomass-Fired 

Boilers 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Fiberglass 

Manufacturing 

Non-CTG Major NOX Source §117.410(b)(10) & (11) 

Fuel Switching Fuel Switching to Meet NOX RACT for 

NOX 

(EPA Memorandum, July 30, 1993) 

§117.400 – §117.456 

§117.1300 – §117.1356 

Glass 

Manufacturing 

NOX Emissions from Glass 

Manufacturing 

(EPA-453/R-94-037, June 1994) 

§117.410(b)(10) & (11) 

Hot Mix Asphalt 

Plants 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Incinerators Non-CTG Major NOX Source §117.410(b)(9) 

Industrial, 

Commercial, and 

Institutional 

Boilers 

NOx Emissions from Industrial, 

Commercial & Institutional Boilers 

(EPA-453/R-94-022, March 1994) 

§117.410(b)(1) & (2) 

Iron and Steel NOX Emissions from Iron and Steel 

Mills 

§117.410(b)(8) 
J-11

Emission Source 

Category 

CTG or ACT Reference Document State Regulations Fulfilling 

RACT Requirements 

(EPA-453/R-94-065, September 1994) 

Lead Smelting Non-CTG Major NOX Source §117.410(b)(8) 

Lightweight 

Aggregate Kilns 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Lime 

Manufacturing 

Non-CTG Major NOX Source §117.410(b)(7)(A) 

Magnesium 

Chloride Fluidized 

Bed Dryers 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Natural Gas-Fired 

Dryers, Heaters, 

and Ovens at 

Major Sources 

Non-CTG Major NOX Source §117.410(b)(12) & (13) 

Nitric and Adipic 

Acid 

Manufacturing 

NOX Emissions from Nitric and Adipic 

Acid Manufacturing Plants 

(EPA-453/3-91-026, December 1991) 

§117.4000 – §117.4050 

§117.4100 – §117.4150 

§117.4200 – §117.4210 

Oilfield Drilling 

Operations 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Other Minerals 

Processing Kilns 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Petroleum 

Refining 

Operations 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Process Heaters NOX Emissions from Process Heaters 

(EPA-453/R-93-034, revised 

September 1993) 

§117.410(b)(3) 

Pulping Liquor 

Recovery 

Furnaces 

Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Pyrolysis Reactors Non-CTG Major NOX Source No existing major sources in 

DFW eight-hour ozone area. 

Stationary Internal 

Combustion 

Engines 

NOX Emissions from Stationary 

Internal Combustion Engines 

(EPA-453/R-93-032, July 1993) 

(Updated September 2000) 

§117.410(a) & (b)(4) 

Stationary 

Turbines 

NOX Emissions from Stationary 

Combustion Turbines 

(EPA-453/R-93-007, January 1993) 

§117.410(b)(5) 

Utility Auxiliary 

Steam Boilers 

Non-CTG Major NOX Source §117.1310(a)(2) 

Utility Boilers NOX Emissions from Utility Boilers 

(EPA-453/R-94-023, March 1994) 

§117.1310(a)(1) 

Utility Stationary 

Gas Turbines 

Non-CTG Major NOX Source §117.1310(a)(3) 
J-12

Table J-2: State Rules Addressing RACT Requirements for Major Emission Sources in the DFW 

Eight-Hour Ozone Nonattainment Area 

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

Major Sources of VOC Emissions (from the 2002 TCEQ Emissions Inventory)

ED0099J Holcim Texas 

LP 

3241 Cement kilns 626.67 Control of VOC 

emissions is not 

economically feasible. 

ED0168P Dartco of TX 

LP 

3089 Foam containers 539.65 VOC emissions are 

controlled per BACT in 

NSR Permit No. 18505. 

Additional control for 

RACT is not 

economically feasible. 

ED0011D Chaparral Steel 

Midlothian LP 

3312 Iron and Steel 

foundry electric 

arc furnaces 

339.59 VOC emissions are 

controlled per BACT in 

NSR Permit No. 1635, 

3026, 5983, 8097, 8099. 

Further control may be 

required by MACT. 

Additional control for 

RACT is not 

economically feasible. 

JH0025O Johns Manville 

International 

Inc. 

3296 Fiberglass 

curing 

219.30 VOC emissions are 

controlled per BACT in 

NSR Permit No. 946A, 

1218. Additional 

control for RACT is not 

economically feasible. 

ED0051O Owens-Corning 

Waxahachie 

Plant 

3296 Fiberglass 

forming and 

curing 

137.50 VOC emissions are 

controlled per BACT in 

NSR Permit No. 6093. 

Additional control for 

RACT is not 

economically feasible. 

KB0015U Vistawall 

Architectural 

Products 

3354 Aluminum 

coating 

112.37 Surface coating 

operations are covered 

by RACT in §115.420 – 

§115.429. 

PC0001E ACME Brick 

Bennett Plant 

3251 Brick kiln 90.59 VOC emissions are 

controlled per BACT in 

NSR Permit No. 25937. 

Additional control for 

RACT is not 

economically feasible. 

PC0013U Enbridge 

Gathering 

Springtown 

Gas Plant 

1321 Gas plant, 

fugitives, storage 

tanks covered 

91.90 VOC emissions from 

equipment leak fugitives 

are covered in §115.352 

– §115.359 and from 

storage tanks by 

§115.112 – §115.119. 
J-13

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

ED0332D Midlothian 

Energy LP 

4911 Gas-fired 

combustion 

turbines 

77.39 VOC emissions arise 

from natural gas 

combustion; control is 

not economically 

feasible. 

KB0073G Madix Inc 

Skyline 

Manufacturing 

Facility 

2542 Surface coating 

misc. metal parts 

63.49 Surface coating 

operations are covered 

by RACT in §115.420 – 

§115.429. 

ED0018M Elk Corp. of 

TX 

2952 Asphalt Roofing 59.66 VOC emissions are 

controlled per BACT in 

NSR Permits. 

Additional control for 

RACT is not 

economically feasible. 

ED0032S G.S. Roofing 

Products 

2952 Asphalt Roofing 51.27 VOC emissions are 

controlled per BACT in 

NSR Permits. 

Additional control for 

RACT is not 

economically feasible. 

TA0157I General Motors 

Corporation 

3711 Motor vehicle 

manufacture 

555.77 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DF0051J Peterbilt 

Motors Co. 

3711 Motor vehicle 

manufacture 

181.76 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DB0802D Quebecor 

World 

2754 Printing 159.24 Printing operations are 

covered by rules 

satisfying RACT in 

§115.430 – §115.439. 

TA0235N Miller Brewing 

Co. 

2082 Beverage 

alcohol 

production 

149.65 VOC emissions are 

controlled per BACT in 

NSR Permit No. 3113. 

Additional control for 

RACT is not 

economically feasible. 

CP0004W General Cable 

Texas 

Operations 

3366 Copper 

foundries 

121.49 Plant was shut down in 

2004. 

DB1172K Western 

Extrusions 

Corp 

3354 Aluminum 

coating 

106.63 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 
J-14

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

TA0133W Styrochem US 

Ltd 

2821 Plastics and 

resins 

98.4 Vent emissions are 

covered by rules 

satisfying RACT in 

§115.120 – §115.129. 

Fugitive emissions are 

covered under §115.352 

– §115.359. 

DB0838F Texwood 

Industries LP 

2434 Wood kitchen 

cabinets 

91.31 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DB0482W Datron Inc. 3443 Metal coating 86.58 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DB0179D Rock-Tenn Co. 2621 Paper mill 82.87 VOC emissions are 

controlled per BACT in 

NSR Permit No. 49039. 

Additional control for 

RACT is not 

economically feasible. 

TA0353G Ex-Tex 

LaPorte LP 

4911 Electricity 

generation 

77.46 Control of VOC 

emissions is not 

economically feasible. 

DB0976P Lasco 

Bathware Inc. 

3088 Plastic plumbing 

fixtures 

70.84 Installed control 

equipment; emissions 

reported in 2005 less 

than 50 tpy with a 

presumed PTE less than 

100 tpy. 

TA0508B Valero 

Logistics 

Southlake 

Terminal 

5171 Gasoline 

terminal 

68.14 Gasoline terminal 

operations are covered 

by rules satisfying 

RACT for storage tanks 

in §115.112 – §115.119 

and for loading in 

§115.211 – §115.219. 

DB0447B Hensley 

Industries Inc. 

3325 Steel production 65.01 VOC emissions are 

controlled per BACT in 

NSR Permit No. 2489A. 

Additional control for 

RACT is not 

economically feasible. 

DB1040F Williamson 

Printing Corp. 

2752 Lithographic 

printing 

64.17 Printing operations are 

covered by rules 

satisfying RACT in 

§115.430 – §115.439. 
J-15

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

DB0566P SST Truck Co. 3711 Motor vehicle 

manufacture 

59.71 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 –

§115.429. 

DB0386T General 

Aluminum 

Company of 

TX 

3442 Aluminum 

windows 

57.04 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

TA0102K Conoco 

Phillips 

5171 Gasoline 

terminal 

56.25 Gasoline terminal 

operations are covered 

by rules satisfying 

RACT for storage tanks 

in §115.112 – §115.119 

and for loading in 

§115.211 – §115.219. 

DB0259E Dallas 

Woodcraft 

Company LP 

2499 Wooden picture 

frames 

56.19 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DB0914O Vought 

Aircraft 

Industries 

3721 Aircraft 54.76 Surface coating 

operations are covered 

by rules satisfying 

RACT in §115.420 – 

§115.429. 

DB0249H TXU 

Generation Co. 

4911 Electricity 

generation 

54.69 Control of VOC 

emissions is not 

economically feasible. 

CP0029G Exide Corp. 3341 Battery 

recycling 

53.11 VOC emissions are 

controlled per BACT in 

NSR Permit No. 1147A. 

Additional control for 

RACT is not 

economically feasible 

DB0344M ExxonMobil 

Corp. 

5171 Gasoline 

terminal 

52.51 Gasoline terminal 

operations are covered 

by rules satisfying 

RACT for storage tanks 

in §115.112 – §115.119 

and for loading in 

§115.211 – §115.219. 

DB0795V Motiva 

Enterprises 

LLP 

5171 Gasoline 

terminal 

52.37 Gasoline terminal 

operations are covered 

by rules satisfying 

RACT for storage tanks 

in §115.112 – §115.119 

and for loading in 

§115.211 – §115.219. 

Major Sources of NOX Emissions (from the 2000 TCEQ Emissions Inventory)
J-16

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

ED0066B TXI Operations 

LP 

3241 Cement 

Manufacturing 

4515.42 NOX emissions from 

cement kilns are 

covered by rules 

satisfying RACT in 

§117.3100 – §117.3145. 

TA0353G ExTex LaPorte 

LP 

4911 Industrial Dist. 

Oil/Diesel 

Reciprocating 

3690.54 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

ED0099J Holcim Texas 

LP 

3241 Cement 

Manufacturing 

3474.71 NOX emissions from 

cement kilns are 

covered by rules 

satisfying RACT in 

§117.3100 – §117.3145. 

DB0252S ExTex LaPorte 

LP 

4911 Electric 

Generation, 

Natural Gas 

>100 MMBtu/hr 

2905.36 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 

ED0034O Ash Grove 

Texas LP 

3241 Cement 

Manufacturing 

2904.90 NOX emissions from 

cement kilns are 

covered by rules 

satisfying RACT in 

§117.3100 – §117.3145. 

DB0251U TXU Electric 

Company 

4911 Electric 

Generation Dist. 

Oil/Diesel 

Turbine 

2676.48 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 

DB0249H TXU 

Generation 

Company LP 

4911 Electric 

Generation Dist. 

Oil/Diesel 

Reciprocating 

2339.15 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 

TA0352I TXU 

Generation 

Company LP 

4911 Electric 

Generation Dist. 

Oil/Diesel 

Reciprocating 

1336.45 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 

CP0026M Garland 

Municipal 

Power and 

Light 

4911 Electric 

Generation, 

Natural Gas, Tan 

Fired Boilers 

1092.85 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 
J-17

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

JH0045I Texas Lime 

Company 

3274 Lime 

Manufacturing, 

Calcining, 

Rotary Kiln 

1028.60 NOX emissions from 

lime kilns are covered 

by rules satisfying 

RACT in §117.400 – 

§117.456. 

DB0253Q TXU 

Generation 

Company LP 

4911 Electric 

Generation Dist. 

Oil/Diesel 

Reciprocating 

1012.93 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1300 – 

§117.1356. 

ED0051O Owens-Corning 3296 Industrial 

Natural Gas <10 

MMBtu/hr 

586.36 NOX emissions from 

fiberglass are covered 

by rules satisfying 

RACT in 

§117.410(b)(10). 

PC0013U Enbridge 

Gathering 

(North Texas) 

LP 

1321 Industrial, 

Natural Gas, 4-

Cycle Rich-Burn 

551.20 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

ED0011D Chaparral Steel 

Midlothian LP 

3312 Steel Foundries 507.17 NOX emissions from 

furnaces used in steel 

production are covered 

by rules satisfying 

RACT in 

§117.410(b)(8). 

DF0012T Garland 

Municipal 

Power and 

Light 

4911 Electric 

Generation, 

Natural Gas, 

>100 MMBtu/hr 

485.58 NOX emissions from 

electric generation are 

covered by rules 

satisfying RACT in 

§117.1310. 

TA0512K Village Creek 

Wastewater 

Treatment 

4952 Industrial, Large 

Bore Engine, 

Dual-Fuel 

(Oil/Gas) 

450.90 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

ED0044L Saint Gobain 

Containers 

3221 Glass 

Manufacturing, 

Container Glass 

Melting Furnace 

310.10 NOX emissions from 

glass melting furnaces 

are covered by rules 

satisfying RACT in 

§117.410(b)(10). 

TA0354E TXU 

Generation 

Company LP 

4911 Electric 

Generation, 

Natural Gas, 

>100 MMBtu/hr 

305.72 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1310. 

DB2459D The University 

of Texas 

Southwestern 

8221 Industrial, Large 

Bore Engine, 

Dual-Fuel 

(Oil/Gas) 

267.64 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

TA4004G Tyson Foods 

Inc 

2099 Industrial, 

Natural Gas, 4-

Cycle LeanBurn 

242.27 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 
J-18

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

JH0230L Ponderosa Pine 

Energy 

Partners Ltd 

4911 Electric 

Generation, 

Natural Gas, 

>100 MMBtu/hr 

169.00 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1310. 

DB3357F Tyson Foods 

Inc 

2013 Industrial, 

Natural Gas, 4-

Cycle LeanBurn 

155.73 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

CP0065C TXU 

Generation 

Company LP 

4911 Electric 

Generation Dist. 

Oil/Diesel 

Reciprocating 

148.39 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1310. 

KB0050S Energy 

Transfer Fuel 

LP 

1311 Industrial, 

Natural Gas, 2-

Cycle LeanBurn 

137.82 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

DB0179D Rock-Tenn 

Company 

2621 Fuel Fired 

Equipment 

Process Heaters 

Natural Gas 

136.68 NOX emissions from 

process heaters are 

covered by rules 

satisfying RACT in 

§117.410(b)(4). 

PC0140M Cantera 

Resources Inc 

1321 Industrial, 

Natural Gas 

Reciprocating 

127.35 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

JH0025O Johns Manville 

International 

Inc 

3296 Fiberglass 

Wool-Type 

Fiber, 

Regenerative 

Furnace 

122.23 NOX emissions from 

fiberglass furnaces are 

covered by rules 

satisfying RACT in 

§117.410(b)(10). 

DB0820B Texas 

Instruments Inc 

3674 CommercialInstitutional 

Natural Gas 10-

100 MMBtu/hr 

79.17 NOX emissions from ICI 

boilers are covered by 

rules satisfying RACT 

in §117.410(b)(1). 

DB1073N American 

Marazzi Tile 

Inc 

3253 CommercialInstitutional 

Natural Gas <10 

MMBtu/hr 

68.13 NOX emissions from 

brick and ceramic kilns 

are covered by rules 

satisfying RACT in 

§117.410(b)(7). 

DB0384A Garland 

Municipal 

Power and 

Light 

4911 Electric 

Generation, 

Natural Gas, 

>100 MMBtu/hr 

67.87 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1310. 

PC0005T Brazos Electric 

Power 

Cooperative 

Inc 

4911 Electric 

Generation, 

Natural Gas, 

>100 MMBtu/hr 

60.82 NOX emissions from 

utility electric 

generation are covered 

by rules satisfying 

RACT in §117.1310. 
J-19

Source 

Account # 

Company 

Name 

SIC 

Code 

Source 

Description 

Emissions 

(tpy) 

RACT Determination 

DF0001B ACME Brick 

Company 

3251 Brick 

Manufacturing 

57.69 NOX emissions from 

brick kilns are covered 

by rules satisfying 

RACT in 

§117.410(b)(7). 

CP0029G Exide 

Corporation 

3341 CommercialInstitutional 

Natural Gas <10 

MMBtu/hr 

57.35 NOX emissions from 

boilers are covered by 

rules satisfying RACT 

in §117.410(b)(1). 

TA0115B DFW 

International 

Airport 

4581 Industrial Dist. 

Oil/Diesel 

Reciprocating 

55.99 NOX emissions from 

engines are covered by 

rules satisfying RACT 

in §117.410(b)(4). 

TA0157I General Motors 

Corporation 

3711 Engine Testing 

Reciprocating 

Gasoline 

53.77 Control of NOX

emissions is not 

economically feasible. 

DF0558Q Texas Aero 

Engine Service 

LLC 

4581 Engine Testing, 

Aircraft, Jet A 

Fuel 

53.44 Control of NOX

emissions is not 

economically feasible.