- ISSUES RELATING TO VOC REGULATION 

CUTPOINTS, DEFICIENCIES, AND DE VIA TlONS 

, Clarification to Appendix D 

of November 24, 1987 FEDERAL REGISTER 

May 25, 1988 

Ozone/Carbon Monoxide Program Branch 

Air Quality Management Division 

Office of Air Quality Planning and Standards 

Revised 1/11/90 
I NTKODUCT ION 

On November 24, 1987, EPA proposed its post-1987 ozone and carbon 

monoxide pol icy statement. In that proposal the Agency described a 

process to make SIP deficiency 'callsY pursuant to Section 110(a) (2) (H) 

of the Clean Air Act. Appendix 0 of the emposed policy statement 

contained a 1 isting of SIP deficiencies and inconsistencies that 

should be addressed and corrected when States respond to such SIP calls. 

The purpose of this docunent is to provide additional clarification of 

those areas descrf bed in Appendix D i n which existing Reasonably Avai 1 able 

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 

requi rements , but merely enhances Appendix D by providi ng more specific 

information in cases 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. 

In the April 1987 letter from the EPA Administrator to the Governors 

of 42 States, EPA announced its intention to undertake a three-part 

process in its post-1987 SIP revisions. First, EPA was to review all 

federal ly-approved control comnitments in the State implementation plan 

to determine 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 to determine whether adopted measures are being effectively 

implemented. This document addresses many of the "Appendix D" problems 

uncovered during the second part of this process. Corrections of the 

deficiencies described herein provide for a greater degree of equity 

and national consistency among all States and localities that receive 

post-1987 ozone SIP calls. 

NOTE: This update includes revisions to pages 1-2, 2-5, and 2-6 of 

this document. The revisions are technical corrections to 

reflect the addition of four~compounds to the list of those 

that are exempt from EPA's definition of "volatile organic 

compounds." This change was made in the Federal Register of 

January 18, 1989 (54 FR 1987). 

. . 

Revised 1/11/90 
ISSUES KtLATlNti TO VDC HEGULATIUN CUTPOINTS, 

DEFICIENCIES AND DEVIATIONS 

lxecut ive Summary 

3ased on ¥dix D of Federal Register of November 24, 1987 

1. dACT Keyu lation Exemptions-- = Wnere EPW has previously speci fiea 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 speci tied 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 to make enforceable any regulations specified on an "actual" 

emissions basis. 

Cutotf total determined from the sun of individual emission sources 

witni n - same CT(; category. (Exception: Petrol em market1 nj -- 

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 wul d 

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 federal ly 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" sol vents). "Exempt" sol vents are those 

detemi nea by EPA to ndve ney liyible pnotochmical reactivity. 

See VOC definition, page 1-2. 

If "equivalent" add-on controls, transfer efficiency,' or emission 

trading (cross 1 i 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 

in exchange for a relaxation of RACT. 
5. Exempt Sol vents-- * Treat as water in Wlb VOC/gal coating less water" calc 

Cannot take credit in emissions inventory and attainment 

demonstration or new source review for control of exem 

Exempt only those solvents determined to have negligib 

chemical reactivity listed in the five Federal Regi 

notices (see RECO~~ll~1EtIDAT10t~ FOR EXEFlPT SOLVENTS, pa 

5. VOC. Defini tion-- 

Cannot use 0.1 mm Hg v istent with EPA 

reac ti vi ty policy . Su 

low volatility, which, 

and, therefore, partic 

Hodel definition: 

"Volati'le organic comp compound which 

participates in atmosp ctions. This includes 

any organic compound o 

methane, ethane, wthy 

(trichlorotri fluoroeth 

(trichl orof 1 uorowthan 

(chl orodi fl uorome thane 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 w tal coating opera ti ons; however, 

bove 60% default baseline is needed to 

lly acceptable for certain auto coatings: 

waterborne equivalence (i.e., 2.8 lb 

at 30% TE) . See page 2-22. 

ernative means of control unless baseline 

d is approved as part of the SIP. 

n is required unless use of TE is approved 

visi on (see discussion, page 2-14). 

o NSPS TE table values allowed -for final 

RACT compliance. 
4. Exempt Sol vents-- - Treat as water in "lb VOC/gal coating less water" calculations. 

Cannot take credit in emissions inventory and attainment 

demonstration or new source review for control of exempt solvents. 

Exempt only those solvents determined to have negl igible 

photochemical reactivity 1 isted in the five federal 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 pol icy. Such a definition would exempt compounds of low 

vol at il fty, which, under certain processes, would vol atil ize and, 

therefore, participate in photochenical react ions. 

- Model definition: 

"Volatile organic compound (V0C)--Any organic compound which 

part ic ipates in atmospheric photochemical react ions. 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 orofl uoromethane) , CFC-12 (dichl orodifl uoroaethane) , CFC-22 

(chl orodifl uoromethane), FC-23 (trifl uoromethane), 

CFC-114(dichlorotetrafl uoroethane), CFC-I 15 

(chl oropentafl uoroethane) , HCFC-123 (dichlorotrifluoroethane) , HFC134a (tetrafluoroethane), HCFC-14lb (dichlorofluoroethane), and 

HCFC- 142b (chl orodifl uoroethane) . These compounds have been 

determined to have negl ig 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 negl ig ibl e photochemical 

reactivity, an owner or operator may exclude these negl igibly 

reactive compounds when determining compliance with an emissions 

standard. " 

6. Corrections for Other VOC Rule Definitions-- 

* List from Appendix 0: (coating, coating 1 ine, 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 

appl irabl e base1 ine, emission 1 imit, and test procedure. A 

rep1 icable base1 ine should be no less stringent than standard 

industry practice. 

60 percent default base1 ine acceptable for most large appliances, 

metal furniture, and miscell aneous metal coat ing operat ions ; 

however, testing for actual TE above 60 percent default baseline is 

needed to determine final compl iance. 

Rev i 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 lb VOC/gal coating, less water at 30 percent TE). See 

page 2-22. 

- TE cannot be used as an alternative means of control unless base1 ine 

is specified and test method is approved as part of the SIP. 

- Source-specificSIPrevision isrequiredunless useof TE is 

approved pursuant to generic SIP provision (see discussion, page 2- 

14). 

Actual TE'smustbeused;noNSPSTEtablevaluesallowedforfinal 

RACT compl iance. 

Revised 1/11/90 
6. Cross-Line Averaging (Bubble )-- 

In cases 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 

If approved under generic bubble rule, generic rule must also meet 

provisions of ET policy 

The following ri tuations are examples of cross-1 ine 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 in the SIP. (See Attachment 4) For auto topcoating 

operations, see page 2-22. 

12. Capture Efficiency-- * Specify capture efficiency test method where capture efficiency is 

discussed or implied in limit (e.g., web-coating operations with 

add-on control 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 is already 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 a1 terna tive 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 determi nations 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 

in accordance with guidance issued by EPA; AND 

" require that any source seeking approval of exemption, variance, 

or a1 terna ti ve 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 (1.e.. not requiring caseby-case EPA approval for the alternative means to be federally effective) 

must met the general principle of replicabi li ty descri bed in EPA's 

emissions trading policy statement (51FR 43850, December 4, 1986). 

Federal Reoi ster notices that approve SIP revisions containing general 

provi si ons that may be cons trued as generic procedures s houl d include 

EPA's "warning" about residual authori ty 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 if it meets EPA's redesignation policy. 
WHAT DOES SIP CALL MEAN? 

(Regarding VOC RACT Rules) 

Sesponse to SIP calls will be made in two phases as described below: 

FIRST PHASE--LIMITED RESPONSE 

(512 revision due 1 year after work plan is submitted under SIP call) 

No additional regulatory requirements added 

Meet all previously applicable requirements for 1987 extension 

areas and 1982 SIP call areas ("Level Playing Fleld") (e.g., 

consistent cutoffs, test methods). All such areas must meet 

requirements of Groups 1, 11, and I1 I CTG source categories. 

:do additional RACT requirement <lo0 tpy for contiguous rural county 

SECOCD PHASE--FULL RESPONSE 

(After EPA Pub1 i shes Final Ozone/CO Pol icy) 

fiew additional requirements possible for additional MSA and new 

contiguous (rural ) SIP call areas. (May be mandatory or discretionaryodepends upon fi na 1 pol icy 1. 

Groups I and 11 

Group 11 I 

- > 100 tpy non CTG 

!!ew requirements possible for new isolated rural SIP call areas. Again, 

depends upon final policy. 

Groups I and 11: 100 tpy coverage only 
CTG RACT REGULATION CUTOFFS/EXEMPTIOtlS 

Recommended cutoffs contained in CTG's, model regulations, or EPA 

pol icy memorandums (See Attachment 1) 

For additional CTG categories size cutoffs, see SELECTED COATINGS 

CTG CATEGORY RECOl4GEt4DED EXEMPTION LEVEL, page 16. 

Cal cola ti ng regulation size cutoffs for CTG sources 

" Base tpy cutoff on theoretical potential to emf t (design capacity [or maximum production] and 8760 hr/yr ) before add-on con ttol 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 if plantwide emis.sions > cutoff lfmi t 

" If caught with emissions > cutoff limit in the 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 in EPA guidance. Exemptions can be granted only by 

way of the 5% rule (see Attachment 2) 

In cases where past guidance recommends high cutoff (e.g., 100 tpy), 

SIP call should also recommend that State investigate sm11 exemption 

level s to prepare for addi tional emission reductions under full response 

to SIP call 
DEFINITIOtl OF 100 TPY NON-CTG SOURCE 

Based on theoretical potential to emit (design capacity [or - maximum 

production 1 and 8760 hr/yr) before add-on controls 

To determine if - > 100 tpy: 

" apgrega te emi ssions of a1 1 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 in plant 

Even "status quo" (RACT-level) emissions must be put in regulation or 

federally enforceable permit form to avoid increases (e.g., emission 

levels without any additional controls) 

To achieve "below 100 tpy" (and avoid RACT), a State may limit production 

or capacity and specify this limitation in a federally enforceable 

permit (cannot just apply minimal controls to go below 100 tpy) 

~mploy "once-in-always-in" concept for applicability 
FORH OF SURFACE COATING EMISSION LIMIT UNITS 

Recommended form of emission limi t--pounds VOC per gallon coating 

(less water and "exempt" solvents*) 

However, if rule or SIP allows: 

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

" credit for transfer efficiency, or 

" emissions trades and cross-1 ine averaging 

Then rule must have VOC limits expressed as both: 

" pounds VOC per gallon coating (less water and exempt solvents) 

to aid in conpl iance determination 

- and 

" pounds VOC per gal 10n sol ids (or pounds VOC per pound of sol ids for 

graphic arts) 

- or 

" provide clearly defined, rep1 icable conversion calculation procedure 

to obtain equivalent limit (See Attachment 3) 

Daily emission caps are desirable, but not mandatory unless they are 

established as part of the SIP control strategy. Daily emission caps 

cannot be used in exchange for a relaxation of RACT. 

*"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 pol icy 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 in the 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 1/11/90 
VOC OEFINITION 

Cannot use 0.1 mar Hg vapor pressure cutoff to define VOC--inconsistent 

with EPA reacti vi ty policy. Such a definl tion would exempt compounds 

of low volati 1 i ty, which, under certain processes, would volatilize 

and, therefore, would participate in photochemical reactions. A State 

must eliminate this loophole from the SIP. . . Node1 definition: 

Any organic conpound which participates in atnospheric 

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 

(trichlorotri fluoroe thane), methyl ent chlorf de, CFC-11 

(tri chl orof 1 uoromethane) , CFC-12 (dl chlorodi f l uoroarthane 1, 

CFC-22 (chlorodifluoromethant), FC-23 (tri fluorolncthane) , CFC-114 (dichlorotetrafluorocthane), CFC-115 .(chloroptntaf 1 uoroe thane ) . * These compounds have been de tcmi ned to have 

negl igi bl photochemical reactivity . For purposes of determining 

compliance wf th emf ssi on If mi ts, YOC wi 11 be measured by the 

approved test methods. Uhere such a method also inadvertently 

measures compounds wi th ntgl igi ble photochcari cal nactivi ty , an owner or operator may exclude these ne'gl i.gi b1 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) Tetraf luoroethane (HFC-134a) 

f 3) Dichlorofluoroethane (HCFC-14lb) 

(5) Chlorodifluoroetilanc? (HCFC-142b) 

Revised 1/5/90 
CORRECTIONS FOR OTHER VOC RULE DEFINIT IOtJS 

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: in most cases, can accept use of 605 transfer 

efficiency as baseline for: 

--iarge appliances 

--:!eta1 furniture 

--Mi scel laneous metal parts 

Testing for actual TE above the 60: default baseline is needed 

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 lb VOC/gal coating less watcr 

at 30: TE (see page 2-22) 

TE cannot be used as an a1 ternative means of control unless baseline is 

specified and test method is approved as part of the SIP 

Source-specific SIP revision is required unless use of TE is approved 

pursuant to generic SIP provision (see discussion on EXEMPTIONS, 

VARIANCES, AND ALTERNATIVE MEANS OF CONTROL, page 2-14) 

Actual TE's nust be used; TE table values (e.g., from NSPS) are 

unacceptable for final RACT compl iance. 

For a discussion of replicability, see 51 FR 43650, 12/4/86 
CROSS-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) pol icy 

(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 credi t for downtime ; however, credi t a1 lowed 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 in calculation procedures or compl iance techniques 

associated with generic regulations 

The fol lowing situations are examples of cross-1 ine 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 in accordance 

wi th established EPA pol icy (O'Connor memo--1/20/84) 

Averaging periods in excess of 24 hours are not allowed generically. 

Must receive EPA approval as SIP revision 

Reexamine pre-0'Connor memo approvals of > daiiy averaging to 

ensure that RACT levels of control are apFlied 

Compliance date extensions allowed only in accordance 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 emf tted consistent 

with compliance time frames 

EXAi,iPLES: gallons of solids per day 

pounds of VOC per day 

(This allows, for instance, one to calculate compliance with a VOC 

limitin termsofIbVOC/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 

cod ti ngs 

Separately enforceable provisions must clearly require recordkeepi ng 

imp 1 oy most recent EPA recordkeepi ng gui dance 
TEST 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 in the SIP. 

Procedures should allow verification of accuracy. of test data. 

Prescribe capture efficiency test method where capture efficiency 

is discussed or imp1 ied 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) 

sub gect to SIP requi remn ts 

Inaccessible valves are required to be monitored at least annually. 

unsafe-to-moni tor valves are required to be noni tored 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 is already 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. A1 1 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 a1 ternative means of control must -- 

" specify appropriate test methods and other replicable criteria 

in accordance with guidance issued by EPA; - AND 

. . require that any source seeking approval of an exemption, variance, 

or a1 ternative 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 in EPA's 

emissions trading policy statement (51 FR 43850, December 4, 1986). 

Federal Register notices that approve SIP revisions containing general 

provisions that may be construed as generic procedures should include 

the following statement: 

It should be noted that, similar to EPA's treatment of 

generic bubble rules (51 FR 43853,'column 3, 12-4-86), 

if a State-approved action under a generic rule does 

not meet all the requiremnts for replicability, it 

cannot be considered part of the SIP and by definition 

cannot replace prior valid emission limits in the SIP. 

Should EPA determine, as a result of its oversight 

acti v i t i e s that a Sta te-approved action is inconsistent 

wi th the above requirements, it wi 11 notify the State 

and source in writing and specify any necessary remedial 

measures. In such circumstances, EPA may take appropriate 

remedial action to assure attainment and maintenance, 

including direct enforcement of the original SIP limits. 

Seasonal controls (other than shutdown of natural gas afterburners 

or use of emulsified asphalt) are not allowed. 

State redesignation to attainment classification must not affect 

applicability of regulations. The EPA will approve a redesigna tion 

under 40 CFR Part 81 only if it meets EPA's redesignation policy. 
ADD1TIOI.IAL CLARIFICATIOtl BY CTG SOURCE CATEGORY 

(For Selected Categories l 
SELECTED COATINGS CTG CATEGORY RECOt.lMEt4DEC EXEt.1PTION LEVEL 

Applicable Source Categories: 

Can 

!leial Coil 

Netal Furni ture 

%a gne t Ui re 

Large Appliance 

5li scel laneous !-!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 Ib VOC/hr or 15 Ib/day actual emissions before add-on control 

To show that there is no significant difference between "State-derived 

cutoffs" and EPA guidance, States must apply '5% rule" (See Attachment 

2) to allow higher cutoff. Analysis must be based on comparison of: 

" emi ssions after control under presumptive cutoff-ri th 

" emissions after control under higher cutoff 

" - NOTE: 5: rule applies to entire source category, not individual 

sources. RACT is the 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 1 ow roll ing 30-day average to determine appl icabi 1 i ty--but not 

for determining compliance with emission limit 

Employ "once-in-always-in" concept for applicability 

CTG 1 imi t recommends tion--80 mgll 

Ensure that trucks using terminals pass leak-tight test 
GASOLINE BULK PLANTS 

Cefined as - < 20,000 gal/day throughput 

Allowed exemption--< 4.000 gal/day throughput 

Recommend CTG control alternative 13 (Submerged fill + vapor 

balance4 n and out) 

A1 1 ow to1 1 i ng 30-day average for determining appl icabi 1 i ty--but 

- not for determining compliance 

Employ "once-i n-always-i n" concept for appl icabi 1 i 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 a1 1 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 is recommended. 

Segregated storm water runoff drain sys tems and non-con tact 

cool i ng wa ter sys tems are exempt. 
2-21 

SERVICE ST AT IOtiS--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 in place before 1/1/79 

--exempt < 250 gal capacity storage tanks in place after 12/31/78 

Gasoline throughput: 

--exempt < 10,000 gal/mo (120,000 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 

faci 1 i ties 1. 
EPA autocoating protocol is the preferred method for calculating daily 

topcoat emission rate (protocol forthcoming ) 

Topcoat regulation must be amenable to use of EPA autocoating protocol : 

" Emission limit must be in units of lb VOC/gal of solids 

deposited (2.8 lb VOC/gal coating, less water at 

30 percent TE translates to 15.1 lb VOC/gal solids deposited) 

" Compliance must be calculated on a daily weighted average basis 

" Topcoat operation must include all spray booths, 

flash-off areas and ovens in which topcoat is applied, dried 

and cured (excludes final off-line repair). 

Emission limit for surfacer (guidecoat) should be expressed in pounds of 

VOC per gallon of solids deposited with compliance calculated on a daily 

weighted average basis if transfer efficiency is to be considered in 

determining compliance. In these cases, the EPA protocol may be applicable 

for calculating daily surfacer emission rate. 

The SIP should specify whether anti-chip materials applied to main body 

parts (e.g., rocker panels, -bottom of doors and fenders; and leading edge 

of roof ) are treated as surfacer or miscellaneoous metal coating. 

These anti-chip materials should generally be treated as surfacer, 

especially if transfer efficiency is to be considered in compliance 

demonstrations. Underbody anti.-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.la terial s 

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, to Air L Hazardous Haterials Division Directors, 

2ecions I-X. cutback Asphalt-acceptable RACT Regulation. ~ecember 19, 

ia7s1. 

Specify (1) no higher than 7% oil distillate as naximun allowable solvent 

con tent in emulsified 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 limit for seal coats used in early spring or late 

fa1 1 ; (b) 3% 1 imi t when chip seals used when aggregate is dusty or 

dirty; (c) 8'0 limit when mixing with open graded aggregate that is not 

well washed; and (dl 12% limit when 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 1 month) (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, A1 ternative Compliance for 

Graphic Arts RACT, September 9, 1987.) 

If a source wishes to average emissions across lines, it must meet 

the general provisions of the EPA emissions trading policy. 

Exploy "once-i n-always-in" concept for applicabi 1 i ty 
ATTACHMENT 1 

CTG APPLICABILITY: 

CUTOFFS, EXLWTIONS, AND GENERAL 

APPLICABILITY 
CTG 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 provf ded in the 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 is sunarfzed 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 guf dance f ssued 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 I and I1 for 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: 5/16/58 
TAI\I E I . CIITOI I:S IIM (;RC)III' I (:T(; CAI ET,(JRI KS 

I . Casol i ne Loading 

Terminal s .... --- ------.-.---- 

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 capaci ty (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 gas01 i ne 

storage containers of 

less than 2,085 1 i ten 

(550 gal lons) capac i ty 

used exc 1 us i vel y for the 

fuel lng 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 

gal 1016) capacity 

storage tanks In place 

before 1/1/79 (Ref. 4, 

p. 29). 

(c)<948 1 i ters (250 gal - 

1016) capacity storage 

tanks in place after 

12/31/78 (Ref. 4, p.29). 

*Terminals are defined as >76.0(10 1 i ters (2fl,O(lf 

.--- gaJ lons)/W -.--- 

throu~hj~ut ---------.----- . -- -----.- ----- 

*Bulk plants are defined as <76,000 1i ters 

(20,000 yal lons )/day throug%put. 
4. Fl xed Roof Yetrol etrrn Tanks 

..................... Source 

Catec~cbry 

(d)Exenybt lons Tor service 

stat ion tanks wl tlr 

ttrrotrc~Ir(bth s of rru more ' 

than IU,OOU yal s/mopt h 

or 1211,000 gal slyear 

(Ref. 5, 1. 2). .--------- - 

(a) - <151),U00 I1 ters (40,000 

gal lons) storage 

capacity of .volatile 

petrolella llqulds (greater tllan 10.5kPa TVP) 

(Ref. 6, p. 6-1). 

Cutot 1s ....................................................................... 

5. Mlscel laneous Refinery Sources 

(Vacum Producl ng 

Sys teas, Wastewater 

Separators, and 

Process Unl t Turna round s ) 

................................................. .... 

Ctnnrnent s 

* ..................................... 

--- 

-None for vacum producing 

systems and process unit 

turnarounds. 

Ref orenc-es 

(b) <I ,600,000 I 1 ters 

T42U,OOO gal lons) 

storage capacl ty 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 horl zontal , underground 

storage tanks storing JP-4 jet fuel (Ref. 7, 

P. 2). 

-CTG recommends case-by-case addresslng of Instances In whlch control may not be jus'tlf led 

(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 demons tratlon Is developed (Ref. 10, 

P. 6). 
ti. Cutback Asphalt 

(cunt intre(l) 

7. Solvent Metal 

C l eanl ng 

(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 

ai r/vapor Interface 

from requi rent of a 

lna Jor control devl ce 

(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 

conveyori zed degreasing operations at one 

plant location where 

ea~issions are 1110 tons 

*Ilse of ctltback asphalt is approval~le trncler the 

fol lowing cl rctlmstances: (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 in cold cleaners for the same control techniques (Ref. 12, p. 3-31). 

.Operating and equlpmnt requl rement exemptions for cold cleaners with remote solvent 

reservoirs; no other exemptions for cold 

cleaners in urban non-at talnment areas (Ref. 

13, p. 1). 
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leak troln Petroleum Hef ineri es 

2. Hiscel laneous Hetal 

Parts 

-1edks ot corlcentrations 

less Llmn or eqtral to 

10,000 ppm (Hef. 19, 1). 

6-1). 

*No cutnf f for ~~etrolerrm ref l nery sl ze; ayq~li es 

to all retineries. 

=Not intended to affect facll it ies that recycle 

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

3. Fl a tYood Panel I ng *Does not apply to the manufacture of exterior 

siding, tileboard, or particleboard used as a 

- -- -I--- furnl ture co onent (Ref. 20, p.49). 

*This regulation is not intended to cover surface coating of the following metal parts and 

products: (1 ) autombl le 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 furnl ture, (6) lar e appliances, (7) exterior of planes, (8 ! automobile 

ref I nlshing, (9) customized topcoat lng of 

automobi les and trucks, If product ion Is less 

than 35 vehicles per day, and (10) exterior of 

marine vessels (Ref. 20, pp. 28 and 29). 

4. Synt hesi zed Pharmaceut lcal Products 

20, 21 

-- 

*<I5 lbslday; for each 

vent from reactors, 

dl st ll la tlon operat ions, crystal 11 zers , centrifuges, and vacum dryers (Ref. 23, 

p. 1-5). 

*Recormends cutoffs If case-by-case approach 

Is not practical (Ref. 23, p. 1-5). 

*Requl rement for air dryers and product ion 

equipment exhaust systems differ at 330 lb/ 

day (Ref. 23, p. 1-6). 

*Does not cover fermentation, extract ion 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 gal Ions ) of 

storage capacity 

(Ref. 25. p. 5-1). 

(b) <I ,600,000 l l ters 

(420,000 gal Ions) 

storage capacl ty used 

to store produced 

crude oil and condensate prlor to custody 

transfer (Ref. 25, 

p. 5-31. 

11' II CTG CAIEtiOHIES (contlnoetl) 

-Does not apply to the product Ion of ~(~clalty 

tlres for antique or other vehlc les wtlen produced on an Irregular basis or with short 

product ion runs only If these tlres are produced on equipment separate fran normal product ion lines for passenger type tlres (Ref. 

20, p. 74). -- 

*Dues not apply to f lxed roof tanks wl th or 

wl thout Internal float lng roofs, or to smal l 

product lon tanks (Ref. 25, p. 1-2). 

*Does not apply to tanks with a metal llc-type 

shoe seal In a we1 ded 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 f 11 led type seal . or 

other approved closure devlce of demonstrated 

equivalence (Ref. 20, p. 105). 

References 

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