MEMORANDUM UNITED STAT ES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711



### MAR I 7 2011 OFF I CE OF A I R QUALITY PLANN I NG AND STANDARDS

SUBJECT: Approving SIP Revi sion s Addressing VOC RACT Require ments for Certain Coatings Categories 

### FROM: Scott Mathias, Interim Direct 

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# ~~ Air Qualit y Policy Divi si on

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TO: Reg ional Air Di v ision Dir ecto rs The Office of Air Qualit y Planning and Standards ha s received reque sts from Regional Offices for guidance on approving State Implementation Plan (SIP) revi s ion s resulting from newly-issued Co ntrol Techniques Guidelines (CTGs) document s . These CTGs pro vide recommendations to inform state d etermin ation s as to w hat constitutes rea s onably avail ab le control tec hnolo gy (RACT). In so me cases, the newly-i ss ued CTGs contain recommended emi ss ion limit s that are less st rin ge nt than limit s re co mmended in o lde r CTGs coverin g th e sam e indu stry, and may be less stringent th an limit s already adopted into S IP s based on the older CTGs

. Thi s i s the case for industrie s covered by CTGs pertaining to Large Appliance Coat in gs, Metal Furniture Coatin gs, and Miscellaneous Metal and Plastic Parts Coatin gs. The U. S. Environme nta l Protection Agency (EPA ) i ss u ed n e w CTGs for th ese categorie s in 2 00 7 an d 2 008 , under authority of Clean A ir Ac t (CAA) se ction 183(e), to address vo l ati le organic compound (VOC) em i ss i o n s from categories of con s um er and commercial product s. They replace s imil ar CTGs i ss u e d by EPA in 1 977 a nd 19 78. The n ew CTGs recommend more s trin ge nt limit s for g eneral u se coating s, but al s o include new recommendations for several "specialty u se" categories that are l ess strin ge nt than the ge neral u se limit s es tabli sh ed in the 1970 s guid e line s . State s are required to submit a SIP revi s i o n in re spon se to any new ly- i ss u e d CTGs. 1 If an ex i sting SIP co nt ains requirement s that are not le ss strin ge nt than th e app li cabilit y threshold s and/ or coat in g operations limit s recommended in n ew CTGs, the state m ay choo se to s ubmit as a SIP revision a certification that th e exis tin g SIP m eet s RACT requirement s.

1 CAA sec tion 18 2( b )(2) requ ires Mod erate a nd abo ve ozone no nattai nm ent areas to rev ise SIPs when a new CTG is i ss ued by E PA after 1 990. E PA i s r e quire d to se t a S IP s ubmi ss ion d eadlin e with th e iss u a nce of eac h CTG. For CTGs we h ave iss u e d in the p ast sever al years, we h ave s p ec ifi e d a s ubmi ss ion deadlin e of o n e yea r after th e CTG was i ss u e d (See 72 FR 572 1 5 Oct 9, 2 00 7 a nd 73 FR 5848 Oct 7, 2 008)

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Inte rn e t Address ( UA L) • http :// www .e p a
. gov Rec y c l ed/R ec y c l ab l e • P ri nte d**w~ h**  Vege tab l e Oil Ba sed Ink s o n Recyc l e d Paper ( Mi n imum 2 5% P o s tco n s u m e r}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 within 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 have complied with those requirements, then those existing controls should be considered RACT for such sources. If a state chooses to revise more 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 demonstrate that the SIP-approved control requirements are not reasonably available considering technological and economic feasibility, consistent with EPA's definition ofRACT. 

### See 44 FR 53762 (September 17, 1979). In addition, in order to comply with the SIP approval conditions of CAA section II 0(1), the state would need to demonstrate that the revision to the SIP would not interfere with attainment of, or reasonable further progress toward attainment of, the National Ambient Air Quality Standards, nor interfere with any other applicable requirement of the CAA. This would be demonstrated if the stricter limits on general use coatings provide sufficient emission reductions to entirely offset any emission increase caused by adopting the less stringent limits 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 determine that the SIP revision is consistent with the approval conditions of CAA section 11 0(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 for these industries. According to the docketed information, the estimated reductions from the new CTGs are 30 to 35 percent greater than from the older CTGs. 

### See documents EPA-HQOAR-2007-0329-0009 and EPA-HQ-OAR-2007-0334-0010 in dockets EPA-HQ-OAR2007-0329 and EPA-HQ-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 potential 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 determines 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, coupled with 2less stringent restrictions on other coatings would provide overall equal or greater emissions reductions than the set of rules based on the recommendations in the 1970s guidelines. If you have further questions on SIP-related issues you should contact Butch Stackhouse at (919) 541-5208. If you have further technical questions on the topics covered in this memorandum you should contact Kaye Whitfield at (919) 541-2509.

cc: Robin Dunkins, SPPD Kimber Scavo, AQPD David Orlin, OGC Sara Schneeberg, OGC



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