## - 

# ISSUESRELATING TO VOCREGULATION 

# CUTPOINTS, DEFICIENCIES,

# ANDDEVIATlONS

, 

# Clarificationto

# AppendixD ofNovember24, 

# 1987

# FEDERALREGISTER



# May25,1988

Ozone/CarbonMonoxideProgram Branch Air Quality ManagementDivision Officeof

# Air QualityPlanningandStandards

Revised 1/11/90I NTKODUCTION

On November 24, 1987, EPA proposed its post-1987 ozone and carbon monoxide policy statement. Inthat proposal the Agency described a process to make SIP deficiency 'callsY pursuant to Section 110(a)(2)

### (H) of the Clean AirAct. Appendix 0 of the emposed policy statement contained a 1 istingof SIPdeficiencies and inconsistencies that should be addressed and corrected when States respond to such SIP calls. The purpose of this docunent istoprovide additional clarification of those areas descrfbed inAppendix 

### D i n which existing Reasonably Avai

### 1able 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 incases where past €PA guidance or approved rulemaking was vague or ambiguous. This docunent does not address issues covered in Agpendix 

### 0 related to new source review regulations. Inthe April 1987 letter 

### from the EPA Administrator tothe Governors of 42 States, EPA announced its intentionto undertake a three-part process in its post-1987 SIP revisions. First, EPA was to review all federally-approved control comnitments inthe State implementation plan todetermine whether they have been adopted. Second, EPA was to review whether these adopted measures are technically adequat-e and meet minimum national standards for consistency. Third, EPA was to initiate a comprehensive program todetermine 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~compoundsto 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

### ISSUES KtLATlNti TO VDC 

### HEGULATIUN CUTPOINTS, 

### DEFICIENCIES AND DEVIATIONS lxecutive Summary

3ased on ¥dix 

### D of Federal Register of November 

### 24, 1987 1. dACT Keyulation Exemptions-- 

### = Wnere EPW has previously specifiea a regulation size cutoff (in 

### CTG or other guidance docunents--e.g., model regulation documents, sucn as €PA-45UI2-79-UUJ ana EPA-3U3/2-78-UUl), State must incorporate tnese cutoffs if 

### their existing regulations ire less str.inyent. j

### See At 

### tacrment 1) Wnere EPA 

### has previously specitied 3 ID VOC/hr 

### or 13 10 VOClday cutoff, State may use it 

### on actual emissions basis or use 10 tpy tneoratical potential emissions (design capacity Lor 

# -maximum proauctionJ and 87bU hrlyr) before ada-on control. Care should be taken tomake enforceable any regulations specified on an "actual" emissions basis. Cutotf total determined from the sun of individual emission sources witnin

# - same CT(; category. (Exception: Petrolemmarket1nj

# -- storaye tanks, terminals, and Loadiny rdCkS must be combined.) 

## " Stares may only use higher cutoffs if 

### supported By 5%analysis on an emissions basis (snowiny tnat no siynificant emissions ditferential occurs between EPA guidance and State choice). (See Attachment 2) 2. 

### Uetinition of 1U0 tpy non-CTG source-- 

## ' Aggregate a1 l 

### unregulated sources (including sources which wuld nave bean covered Dy a CTG if

### they had been above the EPA-dcceptea size cutoff--e.g. 

## , <10U tpy graphic drts sources). Base on theoretical potential emissions (design capacity [or 

# - maximum production] and 876U hrlyr) before add-on control. O 

### Cannot merely apply less-than-RACT controls to avoid applicability. O 

### Can restrict nours of operation by legally and federally enforceable permit conditions to limit emissions below 100 tpy. O 

### "Once-i n-a lways-i n" concept must a~ply (i

### .e., if

### emissions are found above cutoff, then State must apply RACT thereafter). 

### 3. Form 

### of Surfdce Coatiny Emission Limit Units-- 

### = 2eyulatiOnS ~nould be expressed as 10 VOC/yal of codtiny (less water and "exempt" solvents). "Exempt" solvents are those deteminea by EPA 

### to ndve neyliyible pnotochmical reactivity. See VOC 

### definition, page 1-2. If 

### "equivalent" add-on controls, transfer efficiency,' or emission trading (cross 

### 1i 

### ne averaging) are contemplated, tnen regulation snould slso be expressed as lb VUC/gal of solids (or Ib VOC/~~ 

### solids forpraphic arts). O 

### Alternatively, the reyulation cdn contain a calculation conversion procedure to determine compliance. Procedure nust be clearly defined, reylicdole, ana consider tne above factors. (See Attdcnment 3) O 

### Daily emission caps are desirable but not mandatory unless establ

### ished as part of the SIP 

### control,strategy. They cannot be used inexchange for a relaxation of RACT.5. 

### Exempt Solvents-- * 

### Treat as water inWlb VOC/gal coating less water" calc Cannot take credit inemissions inventory and attainment demonstration or new source review for control of exem Exempt only those solvents determined to have negligib chemical reactivity listed inthe five Federal Regi notices (see RECO~~ll~1EtIDAT10t~ FOR EXEFlPT SOLVENTS,pa 

### 5. VOC.

### Definition-- Cannot use 0.1 

### mm Hg 

### v istent with EPA reacti

### vi ty policy

# . Su low volatility, which, and, therefore, partic Hodel definition: "Volati'le organic comp compound which participates inatmosp ctions. This includes any organic compound o methane, ethane, wthy (trichlorotri fluoroeth (trichl orof1 uorowthan (chlorodi

### fl uoromethane uoromethane

### 1, CFC-114 (dichlorotetrafluoroet (chloropentafluoroethane

### 1. These compounds have b chemical reactivity. emission limits, VOC w 

### blhere such a method a1 negligible photochemic exclude these negligib compliance with an emi 6. 

### Corrections for Other VO 

### Rule Definitions-- * List from Appendix D 

### (coating, coating line, refinishing, paper coating, fabric co ing, vinyl coating) EPA 

### Regions to 

### na* SIP 

### calls on State-specific definitional problems to ensure consis ncy with CTG's and to avoid vague and ambiguous

. 

### wording. 

# /

for TE, SIP must clearly state the ission limit, 

### and test procedure. A 

### uld be no less stringent than standard ceptable for most large appliances, metal neous 

### wtal coating operati 

### ons; however, bove 60%default baseline isneeded to llyacceptable for certain auto coatings:

waterborne equivalence (i.e., 2.8 

### lb at30%TE)

# . See page 2-22. 

### ernative means of control unless baseline d isapproved as part of the SIP. n is required unless use of TE isapproved visi on (see discussion, page 2-14). o NSPS TE table values allowed -for final RACT 

### compliance.

### 4. 

### Exempt Solvents-- 

# - Treat as water in "lb VOC/gal coating less water" calculations. Cannot take credit inemissions inventory and attainment demonstration or new source review for control of exempt solvents. Exempt only those solvents determined to have negligible photochemical reactivity 1isted inthe fivefederal Reaister notices (see RECOHMENDATION FOR EXEMPT SOLVENTS, Page 

### 2-5.) 5. VOC Definition-- 

# - Cannot use 

### 0.1 

### mn 

### Hg vapor pressure cutoff

# -- Inconsistent with EPA reactivity policy. Such a definitionwould exempt compounds of low volat

### ilfty, which, under certain processes, would volatilize and, therefore, participate inphotochenical reactions. 

# - Model definition: "Volatile organic compound (V0C)--Any organic compound which partic ipates inatmospheric photochemical reactions. This includes any organic compound other than the following compounds: methane, ethane, methyl chloroform 

## (l,l,l-trichloroethane), CFC-113 

### (trichlorotrifluoroethane), methylene chloride, CFC-11 (tr ichl orofluoromethane)

# , CFC-12 (dichlorodifluoroaethane) 

## ,CFC-22 (chlorodifluoromethane), FC-23 

### (trifl uoromethane), CFC-114(dichlorotetrafl uoroethane), CFC-I15 (chloropentafluoroethane)

## , HCFC-123 

### (dichlorotrifluoroethane)

# , HFC134a (tetrafluoroethane), HCFC-14lb (dichlorofluoroethane), and HCFC-142b (chlorodifluoroethane)

# . These compounds have been determined to have neglig

### i bl e 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 neglig ibl e 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 0: (coating, coating 1ine, 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 applirable base1ine, emission 1

### imit, and test procedure. A rep1icable base1ine should be no less stringent than standard industry practice. 60 percent default base1ine 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 compl iance. Revi 

### sed 1/11/90

# - 30 

### percent default baseline generally acceptable for certain auto coatings: i.e. surfacer and top coat waterborne equivalence (i-e., 2.8 lbVOC/gal coating, less water at 30 

### percent TE). See page 2-22. 

# - TE cannot be used as an alternative means of control unless base1ine isspecified and test method is approved as part of the 

## SIP. 

# - Source-specificSIPrevision 

### isrequiredunless useof 

### TE is approved pursuant togeneric 

## SIP provision (see discussion, page 

### 2- 14). Actual 

### TE'smustbeused;noNSPSTEtablevaluesallowedforfinal 

### RACT compliance. Revised 1/11/906. Cross-Line Averaging (Bubble)-- Incases where a State, prior to the post-1987 SIP call, has previously granted (without EPA approval) cross-1 i ne 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 'Ib~control requirement. Source-specific revision must 

### meet ET policy on daily weighted average basis



### Ifapproved under generic bubble rule, generic rule must also meet provisions of ET policy The following 

### ri tuations are examples of cross-1ine 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 1 

### imi ts; and (2) The source averages emissions between two or more similar processes (e.g., separate conveyor lines of similar machines

### 1 with the same or different regulatory 1 

### imi ts. 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

### 1, 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 

### 76. Recordkeeping Requirements-- * Must keep records consistent with compliance time frames--daily compliance requires daily records Employ most recent EPA recordkeeping guidance (guidance forthcoming). 1 Test Hethods--Use most current EPA acceptable methods. A1 1 methods must be specified inthe 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 inlimit (e.g., web-coating operations with add-on control

### 1. 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-tomonitor valves are required to be monitored when conditions would allow these valves to be monitored ~afcly, e.g., during shutdown. 14. Exemptions, Variances, and Alternative Means of Control-- * Generic approval of emission trades isalready covered by EPA's emission trading policy statement (51 FR 43814, December 4, 1986).

### A1 1 SIP'S 

### must specify whether approval of source-speci fic exemptions, variances, and/or a1ternative means of control shall be accomplished as a source-speci fic SIP 

### revision or by a determination of approval by the State Director (a "generic" provision

### 1. A1 1 such generic determina

### tions and supporting documentation shall be submitted to the appropriate aegional Office. To be approvable, a provision for generic approval of source-specific exemptions, variances, and/or alternative mans of control must

# -- " specify appropriate test methods and other replicable criteria inaccordance with guidance issued by EPA; AND 

### " require that any source seeking approval of exemption, variance, or a1ternati

### ve means of control demonstrates that itscontrol method achieves emissions reductions equal to or greater than the emission reductions required by the SIP. 

### Provisions that are intended to be generic (1.e.. not requiring caseby-case EPA approval for the alternative means to be federally effective) must met the general principle of replicability 

### described inEPA's emissions trading policy statement (51FR 43850, December 4, 1986). Federal Reoister 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 redesfgnation under .40 CFR Part 81 only ifit

### meets EPA's redesignation policy.WHAT DOES SIP CALL MEAN? (Regarding VOC RACT Rules)
Sesponse to SIP calls will be made intwo phases as described below: FIRST PHASE--LIMITED RESPONSE (512 revision due 1year after work plan issubmitted under SIP call)

No additional regulatory requirements added

Meet all previously applicable requirements for 1987 extension areas and 1982 SIP call areas ("Level Playing Fleld") (e.g., consistent cutoffs, test methods). All such areas must meet requirements of Groups 

### 1, 11, and 

### I1ICTG source categories. :do additional RACT requirement <lo0 tpy for contiguous rural county

SECOCD PHASE--FULL RESPONSE (After EPA Pub1i shes Final Ozone/CO Policy) fiew additional requirements possible for additional MSA and new contiguous (rural) SIP call areas. (May be mandatory or discretionaryodepends upon fi na

### 1 policy

### 1. Groups 

### Iand 11 Group 11

### I

> 100 tpy non CTG 

# - !!ew requirements possible for new isolated rural SIP call areas. Again, depends upon final policy. Groups 

### Iand 11: 100 tpy coverage onlyCTG RACT REGULATION CUTOFFS/EXEMPTIOtlS

Recommended cutoffs contained inCTG's, model regulations, or EPA policy memorandums (See Attachment 

### 1) For additional CTG categories size cutoffs, see SELECTED COATINGS CTG CATEGORY RECOl4GEt4DED EXEMPTION LEVEL, page 16. Calcolating regulation size cutoffs for CTG sources 

### " Base tpy cutoff on theoretical potential to emf t (design capacity 

# [ormaximum production] and 8760 hr/yr) before add-on conttol 

### s. 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 ifplantwide emis.sions 

### > cutoff lfmit 

## " Ifcaught with emissions 

### > cutoff limitinthe future, then State must apply RACT ("once in, always inm) 

## " 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 inEPA 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 sm11 exemption level

### s to prepare for additional emission reductions under full response to SIP callDEFINITIOtl OF 100 TPY NON-CTG SOURCE

Based on theoretical potential toemit (design capacity [or 

# -maximum production

## 1and 8760 hr/yr) before add-on controls To determine if 

### > 100 tpy: 

# - " apgregate emissions of a11 nonregulated sources --include sources which would have been covered by a CTG if they had been above the €PA-accepted size cutoff--e.g., (100 tpy graphic arts sources --exclude regulated CTG sources



### If> 100 tpy, evaluate RACT on all unregulated source types inplant

Even "status quo" (RACT-level) emissions must be put inregulation or federally enforceable permit form toavoid 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 ina federally enforceable permit (cannot just apply minimal controls to go below 100 tpy) ~mploy "once-in-always-in" concept for applicabilityFORH OF SURFACE COATING EMISSION LIMIT UNITS

Recommended form of emission limi t--pounds VOC per gallon coating (less water and "exempt" solvents*)
However, ifrule or SIP allows:

" determination of compliance from 'equivalent' add-on controls, 

### " credit for transfer efficiency, or 

### " emissions trades and cross-1ine averaging

Then rule must have VOC limits expressed as both: 

### " pounds VOC per gallon coating (less water and exempt solvents) to aid inconpliance determination and 

# -

" pounds VOC per gal10n solids (or pounds VOC per pound of solids for graphic arts)

or 

# -

" provide clearly defined, rep1icable 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 inexchange for a relaxation of RACT.

*"Exemptu solvents are those determined by EPA to have negligible

photochemical reactivity. See VOC DEFINITION, page 

### 2-6.

### 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 de~ranstrations or new source review Exempt solvents are only those identified inthe following 

## federal Reaister notices:
** 

### 42 FR 35314, 7/8/77 (Table 

### 1) 42 FR 38931, 8/1/77 (corrects 7/8/77 FR)

4.5 

### FR 32424, 5/16/80 (clarifies 6/4/79 

### FR!

a 

### 45 

### FR 48941, 7/22/80

Revised 1/11/90VOC 

### OEFINITION

Cannot use 0.1 mar Hg 

### vapor pressure cutoff to define VOC--inconsistent with EPA 

### reacti vi ty policy. Such a definltion would exempt compounds of low volati1i 

### ty, which, under certain processes, would volatilize and, therefore, would participate inphotochemical reactions. A 

### State must eliminate this loophole from the SIP.



### . 

# . Node1 definition: 

### Any organic conpound which participates inatnospheric photoche~ical reactions. Th!s includes gny organic compound other than the following compounds: methane, ethane, methyl chloroform (

### 1.1.1-tri chloroethane)

# ,.CFC-113 (trichlorotrifluoroethane), methylent chlorfde, CFC-11 (tri 

### chlorof1uoromethane) 

## ,CFC-12 (dl chlorodi

### f 

### l uoroarthane

### 1, CFC-22 

### (chlorodifluoromethant), FC-23 (tri fluorolncthane) 

# , CFC-114 

### (dichlorotetrafluorocthane), CFC-115 .(chloroptnta

### f1uoroethane)

# . * These compounds have been de

### tcmined to have negligi bl photochemical reactivity

# . For purposes of determining compliance wfthemfssion If 

### mits, 

### YOC wi

### 11 be measured by the approved test methods. Uhere such a method also inadvertently measures compounds wi 

### th ntgl igi ble photochcarical nactivi ty

## , an owner or operator may exclude thesene'gli.gib1 y 

### reactive compounds when determining coql iance .with an emissions standard.

Also includes the following compounds exempted by EPA 

### on Jan 18, 1989 

### (54 FR 1987): (

### 1) Dichlorotrifluoroethane (HCFC-123) (2) 

### Tetrafluoroethane (HFC-134a) 

### f3) 

### Dichlorofluoroethane (HCFC-14lb) (5) 

### Chlorodifluoroetilanc? (HCFC-142b)

Revised 1/5/90CORRECTIONS FOR OTHER VOC RULE DEFINITIOtJS

List from proposed ozone policy-- Appendix 3 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

# .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: inmost cases, can accept use of 605 transfer efficiency as baseline for: --iarge appliances --:!eta1 furniture
--Mi scellaneous metal parts Testing for actual TE above the 

### 60: default baseline isneeded to deter-mine final compliance In most cases accept use of 302 TE as baseline for auto surfacer and topcoat waterborne equivalence (i .e., 2.8 lbVOC/gal coating less watcr at30: TE (see page 2-22) TE cannot be used as an a1ternative means of control unless baseline is specified and test method isapproved as part of the SIP Source-specific SIP revision isrequired unless use of TE isapproved pursuant to generic SIP provision (see discussion 

### on EXEMPTIONS, VARIANCES, AND ALTERNATIVE MEANS OF CONTROL, page 2-14) Actual TE's nust be used; TE table values (e.g., from NSPS) are unacceptable for final RACT compliance.

For a discussion of replicability, see 51 FR 43650, 12/4/86CROSS-LINE AVERAGING (BUBBLE

## I 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-speci fic SIP revision under the emissions trading (ET) policy (see 51 FR 43814, 12/4/86). Treat this as a de facto pending bubble, 5ut only for purposes of the additional 20%c~t~equirement. Sased on daily weighted average :Jo credit for downtime ; however, credit a1lowed when there are enforceable production limits. F:ust be submitted as source-specific SIP revision, unless processed by the State under an EPA-approved bubble rule. Clust be consistent with 

### ?revisions of EPA ET policy If allowed under EPA-approved generic bubble rule, generic rule must meet EPA ET policy* Fix deficiencies incalculation procedures or compliance techniques associated with generic regulations The following situations are examples of cross-1ine avercging:

0-0 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 1 ines of similar machines

## I with the same or different regulatory limits

*t:OTE: SIP call needed for currently approved generic bubble rules that are inconsistent with EPA ET policy

### 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 

### inaccordance wi 

### th established EPA policy (O'Connor memo--1/20/84) Averaging periods inexcess of 24 

### hours are not allowed generically. Must receive EPA approval as SIP revision Reexamine pre-0'Connor memo approvals of 

### > daiiy averaging to ensure that RACT levels of control are apFlied Compliance date extensions allowed only inaccordance with Potter memo 

### (8/7/86)RECORDKEEPING REQUIREMENTS
iieep records consistent with compliance time frames--daily compliance requires daily records

Record or calculate coating solids use and VOC emftted consistent with compliance time frames
EXAi,iPLES: gallons of solids per day pounds of VOC per day (This allows, for instance, one tocalculate compliance with a VOC

limitintermsofIbVOC/gal ofsolids)



## .

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 codtings Separately enforceable provisions must clearly require recordkeeping imp1oy most recent EPA recordkeeping guidanceTEST FalETHODS AND CAPTURE EFFICIENCY

Use most current VOC test methods (See Attachment 4). For auto topcoating operations, see page 

### 2-22.

A1 1 nethods must be specified inthe SIP.

Procedures should allow verification of accuracy. of test data.
Prescribe capture efficiency test method where capture efficiency isdiscussed or imp1ied in limit (e.g., web-coating operations with add-on control

### 1.
Employ most recent EPA guidance on capture efficiency testing.

### EQUIPMENT LEAK COMPONENTS

Sources previously exempt from mni toring (e.g, plug and ball valves) subgect to 

### SIP requiremn ts

Inaccessible valves are required to be monitored at least annually.

unsafe-to-monitor valves are required to be nonitored when conditions would allow these valves to be monitored safely, e.g., during shutdown.EXE!IPTIONS, VARIANCES, AND ALTERNATIVE MEANS OF CONTROL Generic approval of emission trades isalready covered by EPA's emission trading policy statement (51 FR 43814, December 4, 1986). For information on emissions trading, see page 2-9. A1 1 SIP'S must specify whether approval of source-specific exemptions, variances, and/or a1 ternative means of control shall be accofipl i shed as a source-specific 

### SIP revision or by a determination of approval by the State Director (a "genericn provision

### 1. A11 such generic determinations and supporting documentation shall. be submitted to the appropriate aegional Office. To be approvable, a provision for generic approval of source-specific exemptions, variances, and/or a1ternative means of control must

# -- " specify appropriate test methods and other replicable criteria inaccordance with guidance issued by EPA; 

# - AND



# ..require that any source seeking approval of an exemption, variance, or a1ternative 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 caseby-case EPA approval for the alternative means to be federally effective) must meet the general principle of replicability described inEPA'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), ifa State-approved action under a generic rule does not meet all the requiremnts for replicability, it cannot be considered part of the SIP and by definition cannot replace prior valid emission limits inthe SIP. Should EPA determine, as a result of its oversight activ i t i e s that a State-approved action isinconsistent with the above requirements, itwi11 notify the State and source inwriting and specify any necessary remedial measures. In such circumstances, EPA may take appropriate remedial action toassure 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 itmeets EPA's redesignation policy.ADD1TIOI.IAL CLARIFICATIOtl BY CTG SOURCE CATEGORY (For Selected Categories

## lSELECTED COATINGS CTG CATEGORY RECOt.lMEt4DEC EXEt.1PTION LEVEL
Applicable Source Categories: Can !leial Coil Netal Furni ture %a gnet Uire Large Appliance 5liscellaneous !-!eta1 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 IbVOC/hr or 

### 15 Ib/day actual emissions before add-on control To show that there isno 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-rith 

### " emissions after control under higher cutoff 

### "

# - NOTE: 

### 5: rule applies toentire source category, not individual sources. RACT isthe test for individual sources.

A1 low coatings usage rate (gal/day) as basis for exemption if shown equivalent to emission rate exemption (see EPA guidance memo from Tom kelrns, EPA/OAOPS, to Air Branch Chiefs, Regions I-X, Additional Information Concerning Emission Cut-off--3 Ibs/hr, 15 lbs/day. Kovember 4, 1987).

### 2-17

GASOLINE LOADING TERMINALS



### > i0,OCO gal/day--considered terminal



# - < 20,000 gal/day

# - bulk plant

A1 1ow roll ing 30-day average to determine applicabi1i ty--but 

## not for determining compliance with emission limit
Employ "once-in-always-in" concept for applicability

CTG 1imi t recommendstion--80 mgll

Ensure that trucks using terminals pass leak-tight testGASOLINE BULK PLANTS

Cefined as

# - < 20,000 gal/day throughput

Allowed exemption--< 4.000 gal/day throughput

Recommend CTG control alternative 13 (Submerged 

### fill + vapor balance4n and out)

A11ow to1 1i ng 30-day average for determining applicabi1i ty--but not for determining compliance 

# - Employ "once-i n-always-i n" concept for applicabi1i ty

Recommend tank truck must be certified leak tight at bulk plant

### LEAKS FROtl 

### PET ROLEUPI 

### REFINERIES

Peiine "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 a11 refineries

Reconmend 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.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 0.5 pounds or greater are covered. Affected sources are not covered if throughput of these recovered petroleum products is < 200 gal/day.
Flay also wish to consider NSPS where no cutoff isrecommended. Segregated storm water runoff drain systems and non-con tact cooli ng water systems are exempt.2-21 SERVICE STATIOtiS--STAGE 

### I
Regulation can be written two ways: --tank size. or --gasoline tkroughput

Tank size: --exempt storage tanks 

### < 550 gal capacity for agricultural use --exempt < 2.000 gal capacity storage tanks inplace before 1/1/79 --exempt 

### < 250 gal capacity storage tanks inplace after 12/31/78
Gasoline throughput: --exempt 

### < 10,000 gal/mo (120,000 gallyr

### 1 throughput for service stations --allow rolling 30-day average for applicability level--but 

# - not for compl i ance Employ "once-i n-always-i n" concept for applicability
Apply 5: rule for other than 10.000 gal/mo (120,000 gallyr) exemption 

### (5%rule applies to the entire source category and not individual faci1i ties

### 1.EPA 

### autocoating protocol isthe 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 inunits of lbVOC/gal of solids deposited 

### (2.8 lbVOC/gal coating, less water at 30 percent TE translates to 15.1 lbVOC/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 inwhich topcoat isapplied, dried and cured (excludes final off-line repair). Emission limit

### for surfacer (guidecoat) should be expressed inpounds of VOC 

### per gallon of solids deposited with compliance calculated on a daily weighted average basis if

### transfer efficiency isto be considered in determining compliance. Inthese cases, the EPA 

### protocol may be applicable for calculating daily surfacer emission rate. The SIP 

### should specify whether anti-chip materials applied tomain 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 isto be considered incompliance demonstrations. Underbody anti.-chi p (e.9.. 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 r.laterials Division, Regions I-X, 

### Applicability of VOC 

### Control Techniques Guidelines (CTG's 

### 1 to the Automobile Manufacturing Industry. July 31, 1980. ) 

### Co CTG cutoffs Should define exemption level on plantwide basis CTG applies only to manufacture of new vehicles Hew and modified sources must also meet new source review requirements, which may include BACT and LAER.CUTBACK OR fMULSIFIED ASPHALT

tlo CTG cutoffs

Recommend seasonal exemptions (i.e., outside of ozone season) as opposed to temperature forecasting (e.g., 

### < SO'F). (See memorandum from Richard 2hoads. EPA/OAQPS, toAir

### L Hazardous Haterials Division Directors, 2ecions I-X. cutback Asphalt-acceptable RACT Regulation. ~ecember19, 

### ia7s1. Specify (1) no higher than 

### 7%oil distillate as naximun allowable solvent content inemulsified asphalt, as determined by ASTM distil lation test D-244, 

# or (2) allow use of certain grades or applications of emulsified asphalt with the following maximum solvent contents as determined by ASTy.1 D-244: (a) 35 limitfor seal coats used inearly spring or late fa11; (b) 

### 3% 1 imi t when chip seals used when aggregate isdusty or dirty; (c) 8'0 limitwhen mixing with open graded aggregate that isnot well washed; and (dl 12%

### limitwhen mixing with dense graded aggregate (See memorandum from, Richard Rhoads to Director, Air

### L Hazardous Materials 3ivision, 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 

### 1month) (See memorandum from Richard Rhoads to Director, Air

### L Hazardous Materials Division, Reqions I-X, Cutback Asphalt-Acceptable RACT Regulation. December 19, i97e

# I.SOLVENT METAL CLEANING
Exemptions: See CTG for appropriate cutoffs

Ro S lb/hr, 15 lb/day exemption for smll cold cleaner degreasers (area source). (See memorandum from Richard Rhoads, EPA/OAQPS, to Director, Air 

### L Hazardous Materials Division, Regions I-X, Clarification of Degreasing Regulation Requirements, September 

### 7, 1978).2-25 GRAPHIC ARTS

ST6 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 1b VOC/lb solids on a per line basis. (See memorandum from Darryl Tyler, EPA/OACPS, to Zirector, Air Division, Regions I-X, A1ternative Compliance for Graphic Arts RACT, September 9, 1987.)

If a source wishes to average emissions across lines, itmust meet the general provisions of the EPA emissions trading policy.
Exploy "once-i n-always-in" concept for applicabi1i ty

### ATTACHMENT 1


### CTG APPLICABILITY: CUTOFFS, EXLWTIONS, AND GENERAL APPLICABILITYCTG APPLICABILITY: CUTOFFS, EXEMPTIONS, AND GENERAL APPLICABILITY

The EPA has 'ssued control technique guideline (CTG) documents for 31) source categories;two regulatory gufdelfne documents covering 25 of t9ese 30 source categot!es, and several ~olf cy and other miscellaneous gu'dance memoranda. Part of the guidance provfded inthe CTG's, the two regulatory documents, and the guidance memoranda concerns cutoffs, exempt'ons, and other sfmf lar guidance on the applicability of the recornmended control technfques. This fnformatfon issunarfzed fn Tables 

### 1, 2, and 3 for 29 of the 30 source categories. The CTG for the 30th source category, Vegetable Ofl, was recommended by EPA not to be implemented by the States unt'l test method uncertainties were resolved, and thus is not included 'n these tables. A complete list of references fs provided at the end of tnese tables. Tnis 'nfonation represents gufdance fssued prior'to May, 1988. For categor'es w'th cutoffs listed as 'None", no specific gufdance on cutoffs has Deen 'ssued for thfs particular category although a 

### 3 1b/hr or 15 Iblday general exemotion has been discussed Sn pre-1988 guidance. For current gu'dance on cutoffs for categories lfsted here as 'None", see 'Issues Relating to VOC 2egulations. Cutpofnts, Deffc!encfes, and Deviatfons

# - ClarSfScation to Appendix D of November 24, 1987. Federal Register,' May 1988. Also, for CTG Groups Iand I1for nonattainment areas that neither rece'ved an attajnment date extensSon beyond 1982 nor received a notice of 517 deffcienc'es ("SIP calls'), States were not required to cover sources with em'ssions less than 100 tons peryear, even Sf the CTG or €PA guidance contafned no applicability size cutoff.

Last Ypdate: 5/16/58TAI\IE I

# . CIITOII:S IIM (;RC)III' I(:T(; CAIET,(JRIKS

I

# . Casol i ne Loading Terminals

.... --- ------.-.---- 2. Gasoline Bulk Plants .......... Source Category



## .....................

3. Service StationsStage 

### I ............. ......... (:tttuf t

### s

._a........................

None
(a)Storage tanks with less than 2,000 gallons storage capacity (Ref. 2, p. 5-1). (b)Exempt ion for bulk plants with throughputs of less than 4,000 gals



## -- per day (Ref 3, p. I). 

### - (a)Statl>r,;ry gas01i ne storage containers of less than 2,085 1i ten (550 gallons) capac i ty used exc1 us i vely for the fuellng of Implements of husbandry, provlded the containers are equlpped with submerged flll pipes (Ref. 4, p. 29). (b)<7,5W 1

### l ters (2,000 gal1016) capacity storage tanks Inplace before 1/1/79 (Ref. 4, p. 29). (c)<948 1i ters (250 gal

# - 1016) capacity storage tanks in place after 12/31/78 (Ref. 4, p.29). *Terminals are defined as >76.0(10 1i ters (2fl,O(lf 

### gaJ lons)/W throu~hj~ut 

# . .--- -.--- ---------.----- 

### -- -----.- 

### ----- *Bulk plants are defined as <76,000 1i ters (20,000 yallons)/day throug%put.4. Fl xed Roof Yetro

### letrrn Tanks ..................... Source Catec~cbry
(d)Exenybtlons Tor service station tanks wl tlr ttrrotrc~Ir(bth s of rru more ' than IU,OOU yals/mopt h or 1211,000 galslyear (Ref. 5, 

### 1. 2). .---------- (a) 

## - <151),U00 I1 ters (40,000 gallons) storage capacity of .volatile petrolella llqulds (greater tllan 10.5kPa TVP) (Ref. 6, p. 6-1). Cutot 1s



# .......................................................................

5. Mlscellaneous Refinery Sources (Vacum Produclng Systeas, Wastewater Separators, and Process Unlt Turnarounds

### ) ................................................. .... Ctnnrnents *

## .....................................

--- -None for vacum producing systems and process unit turnarounds. Reforenc-es

(b)

### <I ,600,000 

### I 1ters T42U,OOO gallons) storage capaclty of crude oil and condensate prlor to lease custody transfer (Ref. 6, p. 6-2).

9~200



## - gallday for wastewater separators (Ref. 4, p. A-68)

6. Cutback Asphalt *None (see camment) *Does not apply to storage vessels equipped wlth external f loatlng roofs before 1/1/79 *Does not apply to horlzontal

## ,underground

storage tanks storing JP-4 jet fuel (Ref. 

### 7, P. 2).

-CTG recommends case-by-case addresslng of Instances Inwhlch control may not be jus'tlfled (Ref. 8, p. 6-1).



### -If a State chooses a 100 ton per year cutoff,

the State must consider al 

### l State, local, and prlvate use In an area for whlch the control strategy demonstratlon Isdeveloped (Ref. 10, P. 6).ti. Cutback Asphalt (cuntintre(l)

7. Solvent Metal C 

### l eanlng 

### (a) In urban nonattainment areas, open top vapor degreasers with an open area of less than 1

## d from equipment standards (Ref. 12, p. 7-4) and conveyorl zed degreaser wi th less than 2.0 

# 3 of air/vapor Interface from requirentof a lnaJor control devlce (e.g., carbon adsorber) (Ref. 12, p. 3-34). (b) In rural nonattainment areas, all cold cleaners can be exempted and open top vapor or conveyorized degreasing operations at one plant location where ea~issions are 1110 tons *Ilse of ctltback asphalt is approval~le trncler the following clrctlmstances: (1 ) where it can be clemnstrated that long-life stockplllntJ Is necessary, (2) where the asphalt is to he used solely as a penetrating prime coat, (3) months during the year where temperatlrres do not linger above 5U°F for periods of time adequate for emulsified asphalt,application and setting, and (4) where it can be demonstrated that no VOC emissions 

### wlll occur from the use of the cutback (Ref. 11, pp. 2.3).

*No size cutoffs from operational standards 

# I 12a13'14 .Volatility of solvent Is used to require greater control incold cleaners for the same control techniques (Ref. 12, p. 3-31). .Operating and equlpmnt requlrement exemptions for cold cleaners with remote solvent reservoirs; no other exemptions for cold cleaners inurban non-attalnment areas (Ref. 13, p. 1).0 t 7 

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3leak troln Petroleum Hefineries

2. Hiscellaneous Hetal Parts -1edks ot corlcentrations less Llmn or eqtral to 10,000 ppm (Hef. 19, 1). 6-1). *No cutnff for ~~etrolerrm refl nery slze; ayq~li es to all retineries. =Not intended to affect facllit ies that recycle



## -- waste oil (~ef. 20, j). 13). 

### -- -- 

## ----------------

3. Fl atYood Panel 

### I ng *Does not apply to the manufacture of exterior siding, tileboard, or particleboard used as a



### - 

# -- furnlture co onent (Ref. 20, p.49). 

# -I--- *This regulation is not intended to cover surface coating of the following metal parts and products: (1) automblle and 

### I i ght-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 machinery, 

### (5) metal furnlture, (6) lar e appliances, 

### (7) exterior of planes, (8

# ! automobile ref

### I nlshing, (9) customized topcoatlng of automobiles and trucks, Ifproduction Is less than 35 vehicles per day, and (10) exterior of marine vessels (Ref. 20, 

### pp. 28 and 29).

4. Synthesized Pharmaceutlcal Products 20, 21

--

*<I5 lbslday; for each

vent from reactors, dl st

### lllatlon operations, crystal11zers

## , centrifuges, and vacum dryers (Ref. 23, p. 1-5). *Recormends cutoffs Ifcase-by-case approach Is not practical (Ref. 23, p. 1-5). *Requlrement 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).
-.-...-. ..--.-..-.-. Source Cate(~o ry 

# -.

# ......-.. -..*..-



# ....
5. Rubber Tire Hfy.

6. External Floatlng Roof Petroleum Tanks (a) <150,000 

### ll ters 140,000 galIons) of storage capacity (Ref. 25. p. 5-1). (b) 

### <I ,600,000 

### ll ters (420,000 galIons) storage capaclty used to store produced crude oil and condensate prlor to custody transfer (Ref. 25, p. 5-31. 11' IICTG CAIEtiOHIES (contlnoetl)

-Does not apply to the productIon of ~(~clalty

tlres for antique or other vehlcles wtlen produced on an Irregular basis or with short production runs only Ifthese tlres are produced on equipment separate fran normal production lines for passenger type tlres (Ref. 20, p. 74). 

## -- *Dues not apply to flxed roof tanks 

### wl th or wl thout Internal floatlng roofs, or to smal 

### l productlon tanks (Ref. 25, p. 1-2).

*Does not apply to tanks with a metalllc-type

shoe seal Inawe1ded tank whlch has a secondary seal fran the top of the shoe seal to the tank wall or external floating roof tanks storlng waxy, heavy pour crudes (Ref. 25, 

## 1 p. 

### 5-31. -Does not apply to petroleum llquld storage .vessels: 

### (1) that contaln petroleum llquld 

### wl th

### a true vapor pressure of less than 10.5 1 kPa (1.5 psla), and (2) contalnlng petroleum Ilquld wlth a true vapor pressure less than 27.6 kPA (4.0 psla) that are of welded constructlonadpresentlypossessanrtalllctype shoe seal, a llquld-mtmted foam seal. a 

### I lquld-munted Ilquld f11led type seal

# .or other approved closure devlce of demonstrated equivalence (Ref. 20, p. 105). References

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