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lVi' A R ? 7 2011 OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

MEMOR.ANDUM 

SUBJECT: Approving SIP Revisions Addressing VOC RACT Requirements for Certain 

Coatings Categories 

FROM: Scott Mathias, Interim Direct ~ 

Air Quality Policy Division (5 9-01) 

TO: Regional Air Division Directors 

The Office of Air Quality Planning and Standards has received requests from 

Regional Offices for guidance on approving State Implementation Plan (SIP) revisions 

resulting from newly-issued Control Techniques Guidelines (CTGs) documents. These 

CTGs provide recommendations to inform state determinations as to what constitutes 

reasonably available control technology (RACT). In some cases, the newly-issued CTGs 

contain recommended emission limits that are less stringent than limits recommended in 

older CTGs covering the same industry, and may be less stringent than limits already adopted 

into SIPs based on the older CTGs. This is the case for industries covered by CTGs 

pertaining to Large Appliance Coatings, Metal Furniture Coatings, and Miscellaneous Metal 

and Plastic Parts Coatings. 

The U. S. Environmental Protection Agency (EPA) issued new CTGs for these 

categories in 2007 and 2008, under authority of Clean Air Act (CAA) section 183(e), to 

address volatile organic compound (VOC) emissions from categories of consumer and 

commercial products. They replace similar CTGs issued by EPA in 1977 and 1978. The 

new CTGs recommend more stringent limits for general use coatings, but also include new 

recommendations for several "specialty use" categories that are less stringent than the 

general use limits established in the 1970s guidelines. 

States are required to submit a SIP revision in response to any newly-issued CTGs. I 

If an existing SIP contains requirements that are not less stringent than the applicability 

thresholds and/or coating operations limits recommended in new CTGs, the state may choose 

to submit as a SIP revision a certification that the existing SIP meets RACT requirements. 

' CAA section 182(b)(2) requires Moderate and above ozone nonattainment areas to revise SIPs when a new 

CTG is issued by EPA after 1990. EPA is requii-ed to set a SIP submission deadline with the issuance of each 

CTG. For CTGs we have issued in the past several years, we have specified a submission deadline of one year 

aftel-the CTG was issued (See 72 FR 57215 Oct 9, 2007 and 73 FR 5848 Oct 7, 2008). 

Intemet Address (URL) • http://www.epa.gov 

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We anticipate that EPA Regional Offices would be able to approve the RACT determinations 

in these circumstances. We note that EPA's recommendations in CTGs are generally treated 

as "presumptive" RACT and states may demonstrate that other limits are RACT for one or 

more sources with'rn the source category addressed by the CTG. Where a state has 

previously determined that more stringent applicability thresholds and/or control levels are 

RACT for one or more sources in a source category and the sources liave complied with 

those requirements, then those existing controls should be considered RACT for such 

sources. 

If a state chooses to revise rnore stringent rules that are already in the approved SIP, 

so that those rules reflect the less-stringent recommended limits in the new CTGs, there are 

additional considerations that must be factored into any EPA decision to approve the SIP 

revision. The state would need to first deinonstrate that the SIP-approved control 

requirements are not reasonably available considering technological and economic 

feasibility, consistent with EPA's definition of RACT. See 44 FR 53762 (September 17, 

1979). In addition, in order to comply with the SIP approval conditions of CAA section 

110(1), the state would need to demonstrate that the revision to the SIP would not interfere 

with attaimnent of, or reasonable further progress toward attainment of, the National 

Ambient Air Quality Standards, nor interfere with any other applicable requirement of the 

CAA. "fhis would be demonstrated if the stricter limits on general use coatings provide 

sufficient emission reductions to entirely offset any emission inerease caused by adopting the 

less stringent liinits for specialty coatings. Alternatively, the state could adopt supplemental 

measures that achieve additional emission reductions from another source category in 

another industry to offset the increased emissions from the specialty coatings. In general, if a 

proposed SIP revision achieves the same or greater emission reductions as the approved SIP 

within the same timeframe as provided under the existing plan, the Regional Office should be 

able to deternnine that the SIP revision is consistent with the approval conditions of CAA 

section 110(1). 

The public dockets for the Large Appliance Coatings and the Metal Furniture 

Coatings CTGs contain information that states may find helpful in determining the reductions 

that can be achieved by adopting the new general use category CTG limits £or these 

industrics. According to the docketed information, the estiniated reductions from the new 

CTGs are 30 to 35 percent greater than from the older CTGs. See documents EPA-I-IQOAR-2007-0329-0009 and EPA-HQ-OAR-2007-0334-0010 in dockets EPA-I-IQ-OAR2007-0329 and EPA-IIQ-OAR-2007-0334, respectively. The increase in emissions 

reductions in any specific nonattainment area may vary depending on the volume usage 

distribution among the general and specialty categories in that area. The dockets for the new 

CTGs do not contain area-specific analyses of potiential emissions reductions. Generally, if a 

state believes the volume usage distribution among the general and specialty categories in the 

docket is representative of the distribution in the nonattainment area, we believe that if a state 

undertakes wholesale adoption of the new categorical limits in a specific CTG, the state may 

rely on the assessments in the docket to demonstrate that the range of new limits will result in 

an overall reduction in emissions from the collection of covered coatings. However, if a state 

adopts some specialty category limits, but not all of the new categorical limits, or deterinines 

that it has a different volume usage distribution among categories, the state may need to do 

an area-specific assessment of whether tighter restrictions for some coatings, ooupled with 

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less stringent restrictions on other coatings would provide overall equal or greater emissions 

reductions than the set of rules based on the recoinmendations in the 1970s guidelines. 

If you have further questions on SIP-related issues you should contact Butch 

Stacl<house at (919) 541-5208. If you have further technical questions on the topics covered 

in this meniorandum you should contact Kaye Whitfield at (919) 541-2509. 

cc: Robin Dunlcins, SPPD 

Kimber Scavo, AQPD 

David Orlin, OGC 

Sara Sehneeberg, OGC