EPA-453/R-95-010

BEYOND VOC RACT CTG REQUIREMENTS

CONTROL TECHNOLOGY CENTER

SPONSORED BY:

Information Transfer and Program Integration Division

Office of Air Quality Planning and Standards

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

Air and Energy Engineering Research Laboratory

Office of Research and Development

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711
April 1995

Page left blank for production
EPA-453/R-010

 April 1995

BEYOND VOC RACT CTG REQUIREMENTS

Prepared by:

Ming Tedijanto and Greg LaFlam

Pacific Environmental Services, Inc.

5001 S. Miami Boulevard

P.O. Box 12077

Research Triangle Park, NC 27709

EPA Contract Number: 68-D1-0116

Work Assignment No. III-06

Task Officer: Mohamed Serageldin, Ph.D.

Emission Standards Division

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

Prepared for:

Control Technology Center

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711 
iv

NOTICE

This report has been reviewed by the Emission Standard Division of the Office of Air Quality Planning and

Standards, EPA, and approved for publication. Mention of trade names or commercial products is not

intended to constitute endorsement or recommendation for use. Copies of this report are available through

U. S. EPA's Office of Air Quality Planning and Standards (OAQPS), Technology Transfer Network (TTN)

under the clean Air Act Ammendments Main Menu, Title 1, Policy and Guidance or from the Control

Technology Center (MD-13) in OAQPS. Copies may also be obtained from the National Technical

Information Services (NTIS), 5285 Port Royal Road, Springfield, Virginia 22161 [800] 553-NTIS.
v

PREFACE

The Control Technology Center (CTC) was established by EPA's

Office of Research and Development (ORD) and Office of Air

Quality Planning and Standards (OAQPS) to provide technical

assistance to State and local air pollution control agencies. 

Several levels of assistance are provided by the CTC. First, a

CTC Hotline is available to provide telephone assistance on

matters related to air pollution control technologies. Second, 

more in-depth engineering assistance is provided when

appropriate. Third, the CTC can provide technical guidance by

designing technical guidance documents, developing personal

computer software, and presenting workshops on control technology

matters. The CTC is also the focal point for the Federal Small

Business Assistance Program (SBAP), and maintains the Reasonably

Available Control Technology/Best Available Control

Technology/Lowest Achievable Emission Rate (RACT/BACT/LAER)

Clearinghouse and International Technology Transfer Center for

Global Greenhouse Gases (ITTCGGG). Information concerning all

CTC products and services can be accessed through the CTC

Bulletin Board System (BBS), which is part of the OAQPS

Technology Transfer Network (TTN) bulletin board system.

Technical guidance projects such as this one focus on topics

of national or regional interest that are identified through

contact with State and local agencies. This study was requested

by the Lake Michigan Air Directors Consortium. It provides

technical information that will help agencies develop strategies

for achieving additional reductions in VOC emissions for CTG

Groups I, II, and III, and for enhancing pollution prevention

aspects of State rules. 
vi

ACKNOWLEDGEMENT

This report was prepared by Ms. Ming Tedijanto and Mr. Greg

LaFlam both in Pacific Environmental Services, Inc.'s

Environmental Engineering Department located in Research Triangle

Park. The U.S. Environmental Protection Agency (EPA) project

manager was Dr. Mohamed Serageldin of the Office of Air Quality

Planning and Standards. 

The cooperation of numerous members of the work group is

greatly appreciated. Special thanks are due to the work group

members Ms. Anne E. Arnold in Region I, Mr. William Denman in

Region IV for providing detailed and timely comments and Bill

Johnson of the Ozone Policy and Strategies group at OAQPS.
vii

TABLE OF CONTENTS

Chapter No. Page

1.0 EXECUTIVE SUMMARY .................. . 1-1

2.0 INTRODUCTION ..................... . 2-1

3.0 COMPARISON CRITERIA ................. . 3-1

4.0 DISCUSSION OF FINDINGS BY SOURCE CATEGORY ...... . 4-1

4.1 Cutback Asphalt ................ . 4-1

4.2 Fixed-Roof Petroleum Tanks ........... . 4-2

4.3 Gasoline Bulk Plants .............. . 4-3

4.4 Gasoline Loading Terminals ........... . 4-4

4.5 Miscellaneous Refinery Sources ......... . 4-5

4.6 Stage I Vapor Recovery ............. . 4-6

4.7 Solvent Metal Cleaning (Degreasing) ...... . 4-7

4.8 Surface Coating of Automobiles and Light-Duty 

 Trucks ..................... . 4-9

4.9 Surface Coating of Cans ........... . 4-11

4.10 Surface Coating of Fabrics .......... . 4-12

4.11 Surface Coating of Large Appliances ..... . 4-14

4.12 Surface Coating of Metal Coils ........ . 4-15

4.13 Surface Coating of Metal Furniture ...... . 4-16

4.14 Surface Coating of Magnet Wire ........ . 4-17

4.15 Surface Coating of Paper ........... . 4-18

4.16 External Floating Roof Petroleum Tanks .... . 4-19

4.17 Gasoline Tank Truck and Vapor Collection System 

 Leaks .................... . 4-20

4.18 Graphic Arts ................. . 4-20

4.19 Leaks from Petroleum Refinery Equipment ... . 4-22

4.20 Surface Coating of Miscellaneous Metal Parts

 and Products ................. . 4-24

4.21 Pneumatic Rubber Tire Manufacturing ..... . 4-25

4.22 Surface Coating of Flat Wood Paneling .... . 4-25

4.23 Synthesized Pharmaceutical Products ..... . 4-26

4.24 Air Oxidation Processes - SOCMI ....... . 4-27

4.25 Equipment Leaks from Natural Gas/Gasoline 

 Processing Plants ............ . 4-28

4.26 Large Petroleum Dry Cleaners ......... . 4-29

4.27 Polymer Manufacturing ............ . 4-30

4.28 SOCMI and Polymer Manufacturing Equipment Leaks 4-31

Appendices

APPENDIX A: COMPARISON OF STATE/LOCAL VOC RULES TO 

FEDERAL RACT FOR GROUP I CTG CATEGORIES . . . A-1

APPENDIX B: COMPARISON OF STATE/LOCAL VOC RULES TO 

FEDERAL RACT FOR GROUP II CTG CATEGORIES . . . B-1
viii

TABLE OF CONTENTS (Concluded)

APPENDIX C: COMPARISON OF STATE/LOCAL VOC RULES TO 

FEDERAL RACT FOR GROUP III CTG CATEGORIES . . C-1

APPENDIX D: COMPARISON OF BAAQMD AND SCAQMD VOC RULES

TO FEDERAL RACT FOR GROUPS I, II, AND III 

CTG CATEGORIES ............... . D-1

APPENDIX E: DETERMINING THE AMOUNT OF THINNING SOLVENT 

ALLOWED .................. . E-1

APPENDIX F: CONVERTING EMISSION LIMIT UNITS FROM MASS

VOC/VOL COATING TO MASS VOC/MASS SOLIDS

(NONVOLATILES) IN COATING ......... . F-1

APPENDIX G: EPA VOC POLICY WORK GROUP ......... . G-1

APPENDIX H: LIST OF GROUPS I, II, AND III CTGs ..... . H-1
ix

LIST OF TABLES

Table No. Page

TABLE 1.1 SUMMARY OVERVIEW OF STATE REGULATION 

FINDINGS .................. . 1-5

LIST OF FIGURES

Figure No. Page

FIGURE E.1 ESTIMATING MAXIMUM THINNING ALLOWANCE ... . E-9
1-1

1.0 EXECUTIVE SUMMARY

Air pollution control agencies that have ozone nonattainment

areas within their jurisdiction are required under the Clean Air

Act (CAA) to develop State implementation plans (SIPs) that will

lead to attainment of the national ambient air quality standards

(NAAQS) for ozone. This effort includes the development and

implementation of rules that require Reasonably Available Control

Technology (RACT) for sources of volatile organic compounds (VOC)

located within the designated ozone nonattainment areas. In

order to obtain the required VOC emission reductions, these

agencies are required to establish RACT for source categories not

already covered by EPA's Control Technique Guidelines (CTGs) in

addition to tightening RACT for source categories for which RACT

has already been defined. 

This study was performed at the request of the Lake Michigan

Air Directors Consortium (LADCO). It identifies and compares, by

CTG source category, examples of State and local agency rules

that exceed or may exceed the RACT requirements that are specified in the Federal CTGs. This study is limited to CTG Groups I,

II, and III only, which cover 28 source categories. Tables

summarizing these comparisons are provided in Appendices A

through D. There is no summary table for Air Oxidation Processes

- SOCMI (Group III CTG, Appendix C), because no State or

California District rules were reviewed for this source category. 

Existing Federal CTGs for each source category that define RACT

were thoroughly reviewed and evaluated. Also, EPA's "Blue Book"

("Issues Relating to VOC Regulation Cutpoints, Deficiencies, and

Deviations - Clarification to Appendix D of November 24, 1987
1-2

Federal Register," May 25, 1988, revised 1/11/90) was used to

clarify CTG related issues. Comparison and analysis of EPA's

Model VOC Rules for RACT were not included in the scope of the

project. This study also does not include CTGs that are

currently under development.

In this report, regulations from eight states (Colorado,

Connecticut, Maine, New Jersey, New York, Rhode Island, Texas,

and Utah) and two California control districts were examined for

as many of the source categories as time allowed (see Table 1.1). 

The two California Districts evaluated were the Bay Area Air

Quality Management District (AQMD) and the South Coast AQMD. 

Information for each source category was obtained primarily from

EPA's VOC Policy Work Group members (listed in Appendix G);

additional information was obtained from the BNA Environment

Reporter. However, due to time constraints and limited

resources, a comprehensive review of all of the State VOC

regulations contained in the Environment Reporter was not

accomplished. 

 State and local regulations received for each source

category were reviewed and compared for stringency with the

guidelines in the applicable Federal CTG. Stringency evaluations

were based on, but were not limited to, VOC content limits of

coatings, emission limitations, percent emission reduction

(capture and control), and transfer efficiency requirements. 

Other differences between the regulations and the Federal CTGs

(such as equipment specifications, recordkeeping, and work

practice requirements) were categorized as having the potential

to "enhance" the pollution prevention aspects of a rule, but not

necessarily as being more stringent in and of themselves, unless

quantifiable emission reductions could be attributed to the

measure. If, for example, a State or District rule has more

stringent recordkeeping requirements, it is noted in the

stringency column in the summary tables (Appendices A through D)

through a footnote. This 'qualifying' statement indicates that

the more stringent recordkeeping requirements may result in 

pollution prevention. 
1-3

A discussion of the rule identification methodology is

presented in Chapter 2, Introduction. Chapter 3 addresses the

criteria description and ranking criteria used for evaluating the

State and District regulations reviewed in each CTG source

category. The rules reviewed are summarized and compared to the

Federal CTG and against each other when appropriate. A maximum

of six State rules were considered for each source category. 

Chapter 4 discusses the findings of this study by source

category. The report contains several appendices. Appendices A

through C provide summary tables of the State/local rules by CTG

group, whereas Appendix D provides a summary of the California

District rules. Appendices E and F focus on computational

aspects of the study. Appendix G lists the members of EPA's VOC

Policy Work Group. Appendix H contains a listing of the 28 Group

I, II, and III CTGs. 

Table 1.1 summarizes the State regulations that were found

to be more stringent than the Federal CTGs. The study found that

at least one State (or District) regulation was more stringent

than Federal RACT in 24 of the 28 CTG categories considered. 

State regulations were as stringent as Federal RACT in only four

CTG categories. As mentioned above, one CTG category, Air

Oxidation Processes - SOCMI, was not covered by any of the State

or District rules reviewed.

The Bay Area and South Coast regulations are generally more

stringent than Federal RACT and the State regulations. 

Regulations for these two Districts are as stringent as the

Federal CTG requirements in two CTG categories: Stage I Vapor

Recovery and Surface Coating of Magnet Wire. Four CTG categories

were not found in the District rules. These include: Gasoline

Tank Truck and Vapor Collection System Leaks, Air Oxidation

Processes - SOCMI, Polymer Manufacturing, and SOCMI and Polymer

Manufacturing Equipment Leaks.

Of the eight States and two California Districts, the Bay

Area District has the most rules that exceed Federal RACT (20 of

the 28 CTG categories). The South Coast AQMD is second with 17

rules, and Connecticut is third with 4 rules that exceed CTG
1-4

RACT. 

Overall, the State and California District rules reviewed

exceed CTG RACT in about 50 instances. Table 1.1 provides a

convenient way of identifying more stringent regulations and

those that have pollution prevention provisions. The "X" under

the column labelled "Stringency" identifies those rules found to

be more stringent than the CTG. The X under the column labelled

"Applicability" is used to identify those rules that provide

specific exemptions or affect different source populations than

indicated in the CTG. There were some cases where the State or

District rules were applicable to a smaller population of sources

than recommended in the Federal CTG. However, these State or

District rules were not termed less stringent. Instead, the term

applicability was used to highlight the possibility that the rule

may result in lower reductions. Therefore, in this study a

distinction is made between two aspects of a rule that affect the

emission reduction achievable: the stringency of the rule and the

applicability of the rule. If a rule appeared more attractive

from a pollution prevention perspective (as discussed in Chapter

3), it was not classified as more stringent than the Federal CTG

unless the reductions were quantifiable. As an example, work

practices that lead to quantifiable emission reductions are

considered more stringent. Such regulations were marked with an

X under the "Pollution Prevention" columns. Other work or

operating practices may enhance the rule but do not necessarily

lead to quantifiable emission reductions. Such additional

requirements ("additions") to the State rules were not considered

to make the rule more stringent. They are entered in Table 1.1

under the column entitled "Potential Emission Reduction."

 
TABLE 1.1

SUMMARY OVERVIEW OF STATE REGULATION FINDINGS

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

GROUP I

Cutback Asphalt Rhode Island X

Colorado

Bay Area X X

AQMD

South Coast X

AQMD

Fixed-Roof Utah X

Petroleum Tanks

Colorado X X

Bay Area X X

AQMD

South Coast X X

AQMD

Bulk Plants Colorado

Texas X

Bay Area X X

AQMD

South Coast X X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-6

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-7

Gasoline Loading Colorado X

Terminals

Utah X

Texas X

Bay Area X X

AQMD

South Coast X

AQMD

Miscellaneous Colorado X X

Refinery Sources

Utah X

Bay Area X

AQMD

South Coast X X X

AQMD

Stage I Vapor Colorado X

Recovery

Texas X X

Bay Area X

AQMD

South Coast X X X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-8

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-9

Solvent Metal Colorado X

Cleaning

Rhode Island X

Connecticut X X X

Maine

Bay Area X

AQMD

South Coast X X X X

AQMD

Surface Coating of Colorado

Automobiles and

Light-Duty Trucks New Jersey X X X

Bay Area X

AQMD

South Coast X X

AQMD

Surface Coating of Colorado X

Cans

New Jersey X X

Maine

Bay Area X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-10

South Coast X X

AQMD

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-11

Surface Coating of Colorado

Fabrics

New Jersey X X

Rhode Island X

Utah

Maine

Bay Area X X

AQMD

South Coast X X

AQMD

Surface Coating of Colorado

Large Appliances

Utah

New Jersey X X

Maine

Bay Area X

AQMD

Surface Coating of Colorado

Metal Coils

New Jersey X X

Bay Area X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-12

South Coast X

AWMD

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-13

Surface Coating of Colorado

Metal Furniture

New Jersey X X

Utah

Maine

Bay Area X

AQMD

Surface Coating of Colorado

Magnet Wire

New Jersey X X

Utah

South Coast X

AQMD

Surface Coating of Colorado

Paper

Maine

New Jersey X

Rhode Island

Utah

Bay Area X X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-14

South Coast X X

AQMD

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to b

CTG.

 State/District rule affects additional sources and may provide additional c

reductions relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-15

GROUP II

External Floating Colorado

Roof Petroleum

Tanks Utah

Bay Area X

AQMD

South Coast X

AQMD

Gasoline Tank Colorado X

Truck and Vapor

Collection System

Leaks

Texas

Graphic Arts Colorado

Connecticut X

Maine X

New Jersey X X

New York X

Utah X

Bay Area X

AQMD

South Coast X

AQMD
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-16

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-17

Leaks from Colorado X

Petroleum Refinery

Equipment Utah X

Bay Area X X

AQMD

Surface Coating of Colorado X

Miscellaneous

Metal Parts and

Products

Connecticut X

Maine

New Jersey

Utah

Bay Area X

AQMD

South Coast X X

AQMD

Pneumatic Rubber Colorado

Tire Manufacturing

Connecticut X

Bay Area X

AQMD

Surface Coating of New Jersey

Flat Wood Paneling

Texas
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-18

Maine

Utah

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
TABLE 1.1 (Continued)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-19

Surface Coating of Bay Area X

Flat Wood Paneling AQMD

South Coast X

AQMD

Synthesized Colorado X X

Pharmaceutical

Products Connecticut X

Bay Area X

AQMD

South Coast X

AQMD

GROUP III

Air Oxidation None

Processes-SOCMI

d

Equipment Leaks Texas X

from Natural

Gas/Gasoline

Processing Plants

Bay Area X

AQMD

South Coast X X X

AQMD

Large Petroleum Bay Area X X X

Dry Cleaners AQMD
TABLE 1.1 (Concluded)

CTG CATEGORY CT POTENTI

STATE/DISTRI

EMISSION REDUCTION COMPARISONa

AL

EMISSIO

N 

REDUCTI

ON

STRINGENC APPLICABIL POLLUTION

Y ITY PREVENTION b c

WORK OTHER

PRACTICES

1-20

South Coast X X

AQMD

Polymer Connecticut X

Manufacturing

SOCMI and Polymer Connecticut X

Manufacturing

Equipment Leaks

 Federal CTG and "Blue Book" used as the basis. a

 State/District rule provides quantifiable additional reduction relative to CTG. b

 State/District rule affects additional sources and may provide additional reductions c

relative to CTG.
2-1

2.0 INTRODUCTION

Reasonably Available Control Technology (RACT) is defined as

the lowest emission limit that a particular source is capable of

meeting through the application of control technology that is

reasonably available considering technological and economic

feasibility. For surface coating source categories generally,

the Federal CTGs define RACT in terms of the VOC content limits

of a coating; i.e., mass of VOC per unit volume of coating (minus

water) as applied (ready for application). In some cases,

however, RACT is defined in terms of the percentage emission

reduction achieved with add-on control devices, equipment

specifications and recordkeeping, reporting requirements, and

exemption levels.

For the purposes of this study, 28 CTG documents addressing

28 source categories were reviewed. Information related to State

rules that may go beyond RACT recommendations as specified in the

CTGs and the "Blue Book" was solicited from members of EPA's VOC

Policy Work Group. This report is based on the Work Group's

responses to these information requests. The Work Group did not

identify any State or District regulations as exceeding Federal

RACT for the Air Oxidation Processes - SOCMI and Large Petroleum

Dry Cleaner source categories.

State rules reviewed for this project were those sent by

members of the Work Group following a request by the Office of

Air Quality Planning and Standards. The California District

rules were provided by the EPA Work Assignment Manager. 

Additional information with regard to State regulations came from

the Environment Reporter. The Federal CTG for each source

category was reviewed and summarized; the State and the District

rules pertaining to each source category were compared to the

Federal CTG. 
 Issues Relating to VOC Regulation Cutpoints, Deficiencies, 1

and Deviations - Clarification to Appendix D of November 24, 1987

Federal Register - May 25, 1988 (Revised 1/11/90); U.S. EPA

(AQMD); Research Triangle Park, N C. 

2-2

Although the RACT limits in the Federal CTG's developed in

the late 1970's and early 1980's do not mention "exempt"

compounds in the coating limit expressions, it is assumed that

exempt compounds are treated as water in mass of VOC per gallon

of coating (less water) calculations as called for in the "Blue

Book." "Exempt" compounds are those compounds classified by EPA 1

as having negligible photochemical reactivity as listed in 40 CFR

51.100(s). For the purposes of this study, baseline RACT

consists of guidance in the CTG documents plus subsequent

clarifying policy guidance included in the "Blue Book." This

point clarifies why State coating VOC limits were sometimes not

considered to be more stringent than the Federal CTG coating

limits when the numerical limits were equal. Some States added

requirements to their rules that enhance pollution prevention

aspects of the rules. For example, a State may have specified

how soon a leak must be repaired from the time it is detected,

whereas the applicable CTG may not have such a provision. When

additional requirements in a State regulation did not appear to

result in a quantifiable extra reduction in pollution, the rule

was not termed more stringent than the CTG RACT level. Hence,

when a rule required or modified work practices in general terms

it was not considered more stringent unless the emission

reduction benefit could be quantified. However, when the

requirement enhanced the rule, that fact was acknowledged in the

summary table for that State rule. 

When a rule increased (or decreased) the population of

emission unit operations (or items of equipment) covered with

respect to the applicable Federal CTG, this was noted by an "X"

in the column headed "Applicability." Comparisons of stringency

were reserved for rules that affected the same population of

units or processes. Several States converted limits from mass of

VOC per volume of coating (less water and exempt solvents) to an
2-3

equivalent solids (nonvolatiles) basis. The States, however, did

not explicitly state the assumptions or indicate the volume of

solids (nonvolatiles) used for the conversion. Appendix F

discusses a procedure for performing this conversion.
3-1

3.0 COMPARISON CRITERIA

Several criteria were used to compare State regulations to

the Federal RACT guidance in the CTGs in order to determine

relative stringency. The following criteria were used:

(1) more stringent VOC emission limits (e.g., mass of VOC

per unit of production);

(2) more stringent limits on the VOC content of a coating

(e.g., paint, inks, or other);

(3) a requirement for a greater "percent reduction" than

recommended as RACT;

(4) an improved transfer efficiency requirement;

(5) a requirement for more efficient capture of emissions;

(6) inclusion of work practice requirements not present in

the CTG; and

(7) any other pollution prevention method. 

In most cases, evaluation of criteria 1 through 3 for

relative stringency was straightforward. In some cases, however,

it could not be determined whether an emission limit was

equivalent to a suggested overall control efficiency for a

control device because the emission rate from the process was

unknown. 

Criteria 4 through 7 proved to be the most difficult to

evaluate for stringency. For example, based on the information

available, equivalency for design criteria, equipment

specifications, or work practices is difficult to rank. However,

in evaluating the source categories, more equipment and design

specifications delineated by the State regulations were presumed

to indicate greater stringency. This is especially true where

such changes appear to result in quantifiable reductions. The

design criteria and equipment specifications noted in the tables

shown in Appendices A through D are, in most cases, in addition
3-2

to the Federal CTG specifications. An example of this type of

additional requirement would be for all openings in floating roof

tanks to provide a projection below the liquid surface, or for an

emergency roof drain to be provided with a slotted membrane

fabric cover or equivalent cover that covers at least 90 percent

of the opening.
4-1

4.0 DISCUSSION OF FINDINGS BY SOURCE CATEGORY 

4.1 Cutback Asphalt

Cutback asphalts are mixtures of solvent and a base asphalt

of selected hardness or viscosity. There are rapid curing,

medium curing, and slow curing cutback asphalts. Emulsified

asphalts consist of asphalt suspended in water (98 percent)

containing an emulsifier (2 percent). Water in emulsified

asphalt evaporates during curing while the emulsifier is retained

in the asphalt. Federal RACT for cutback asphalt is defined in

terms of substitution of emulsified asphalt for cutback, rather

than in terms of an emission limit. The CTG provides no

exemptions for this source category. In general, the State

regulations that were reviewed had stipulations for substitution

of emulsified for cutback asphalt with some variation.

State and District regulations were ranked according to

stringency of State/District requirements versus Federal RACT. 

The criteria used to rank these regulations involved the

requirements of substitution and the allowable solvent content. 

In other words, the State regulations reviewed define RACT in

terms of how and when the cutback would be substituted, in

addition to including added specifications for emulsified

asphalt. Although the CTG does not discuss any exemptions, the

"Blue Book" suggests seasonal exemptions. In general, the State

regulations echo the Federal CTG for the substitution of

emulsified asphalt. 

The Rhode Island regulation allows the use of cutback

asphalt during certain periods of the year. Rhode Island also

places several restrictions on the type of cutback asphalt that

may be used during the ozone season. These restrictions will not
4-2

result in quantifiable reductions, but will enhance the quality

of the rules.

The Bay Area AQMD regulations, however, prohibit the use of

any rapid-cure liquid asphalt and liquid asphalt or emulsified

asphalt in paving material or in paving and maintenance

operations. These prohibitions are not specified in the CTG or

the South Coast regulation and have not been used to determine

stringency; this is an issue of applicability. The Bay Area and

the South Coast specify lower VOC content for any slow-cure

liquid asphalt and emulsified asphalt than the CTG. Therefore,

the Bay Area and South Coast regulations are similar and more

stringent than the Rhode Island or Colorado rules, or the CTG.

4.2 Fixed-Roof Petroleum Tanks

 The Federal CTG does not provide an emission limit, but 

recommends equipment specifications. These specifications

include internal floating roofs equipped with a closure seal or

seals, or alternative equivalent controls. The CTG, however,

does not specify the exact types of controls that can be used to

achieve this.

Stringency for this source category is determined by the

storage tank capacity cutoff level, control efficiency, and

additional equipment specifications where the benefits are

readily quantifiable. Additional requirements are defined as

conditions beyond what the CTG specifies.

Two State regulations and the two California District

regulations were reviewed. In general, the Utah and Colorado

regulations are as stringent as the CTG. In addition, these

rules provide additional operating practices that are not found

in the CTG. These practices enhance the pollution prevention

aspects of the rule and may result in potential emission

reductions. The State of Colorado also specifies exemptions that

result in fewer sources subject to the rule. 

The Bay Area and South Coast regulations specify a lower

product vapor pressure cutoff than Utah, Colorado, or the Federal

CTG. Therefore, more operations will be required to comply with

the rule. These regulations also require the same control
4-3

efficiency for an approved emission control system, but higher

than that specified in the CTG. The effect of these requirements

is more emission reduction. The Bay Area and South Coast

regulations also have more detailed operating requirements than

the CTG. These requirements, however, were not used for

determining stringency. 

4.3 Gasoline Bulk Plants

The Federal CTG defines a bulk plant as having a throughput

of less than 76,000 liters of gasoline per day, averaged over the

work days in 1 year. In addition, the CTG specifies types of

bulk plant facilities, control techniques used in bulk plants,

and type of operations and maintenance required to prevent leaks. 

No emission limit or exemptions are specified for this source

category.

Two State and the two California District regulations were

reviewed for stringency and compared to the corresponding CTG

RACT. The criteria used to rank these regulations are the bulk

plant definition (capacity), recovery system efficiency, and the

required VOC emission limit (if available) during gasoline

transfer.

Both the Colorado and Texas regulations define a bulk plant

as having an average daily throughput of less than 76,000 liters

calculated over a period of 30 days, instead of over the work

days in 1 year as stated in the CTG. The shorter the timeframe

(30-day period) for calculating the average throughput to meet a

set limit, the better should be the compliance with the rule.

The Bay area regulation defines a bulk plant as having an

annual throughput of not more than 23,000 cubic meters (6,000,000

gallons). Assuming 360 work days in 1 year (30 work days per

month for 12 months), the calculated daily throughput is 17,000

gallons. The Bay Area defines a bulk plant with a lower

throughput cutoff than other States or the Federal CTG;

therefore, it is considered the most stringent.

The Texas and Bay Area regulations specify a maximum VOC

emission limit associated with product transfer. The Bay Area

emission limit is less than half that required by the Texas
4-4

regulation. No emission limit is specified in the Federal CTG or

the Colorado or South Coast regulations. In addition to the bulk

plant definition and emission limit, the Bay Area requires a

higher vapor recovery system efficiency than the South Coast or

the Federal CTG. The Bay Area and South Coast regulations also

provide work practices and a shorter timeframe for repairing

leaks that are not specified by the other States or the Federal

CTG. For example, both regulations place a limit on the gauge

pressure developed in a delivery tank during transfers, which

should result in quantifiable reductions. 

The Bay Area has the most stringent regulation on the basis

of the VOC emission limit, lower capacity cutoff, and higher

recovery efficiency. These criteria should result in a

substantial reduction in emissions. On the same scale, the Texas

regulation is more stringent than the South Coast, followed by

Colorado and then the CTG.

4.4 Gasoline Loading Terminals

The Federal CTG describes sources and type of emissions,

control techniques, compliance test methods (test conditions and

test procedures) and monitoring techniques, and emission test

procedures. The recommended RACT VOC emission limit for this

category is 80 milligrams per liter (0.67 lb/1,000 gal) of

gasoline loaded. 

The State and District regulations were ranked according to

their stringency versus Federal RACT. The criteria used to rank

these regulations involved emission limit requirements. 

Three State regulations (Colorado, Utah, and Texas) and the

two Districts were reviewed for this category. The Utah emission

limit is slightly lower than Colorado's, which is identical to

the emission limit stated in the Federal CTG. Although the

Colorado regulation specifies loading procedures, it is less

stringent than the Utah regulation. 

Certain areas in Texas (Beaumont/Port Arthur, Dallas/Fort

Worth, El Paso, and Houston/Galveston) have a lower emission

limit (40 mg VOC/l (0.33 lb VOC/1,000 gal) of gasoline

transferred), except for Gregg, Nueces, and Victoria counties. 
4-5

The Texas regulation, in general, is more stringent than the Utah

and Colorado rules.

The Bay Area sets the lowest emission limit and requires

work practices to be followed and a maximum control efficiency

for vapor control systems. Such requirements would result in

quantifiable emission reductions. The South Coast emission limit

is slightly lower than Texas. The South Coast also requires a

shorter repair period than the Federal CTG. Therefore, the Bay

Area regulation is ranked as the most stringent, followed by the

South Coast, Texas, Utah, and Colorado. The Colorado regulation

is as stringent as the Federal CTG.

4.5 Miscellaneous Refinery Sources

Miscellaneous refinery sources include vacuum producing

systems (VPSs), wastewater separators (WSs), and process unit

turnarounds (PUTs). The Federal CTG defines RACT for VPSs and

WSs in terms of equipment specifications, and specifies that

regulations for PUTs should be written in terms of operating

procedures. In general, the State regulations define RACT in

terms of equipment specifications and operating procedures.

State, Bay Area, and South Coast regulations were ranked

according to stringency of the State requirements versus Federal

RACT. The criteria used to rank these regulations involved

comparing add-on equipment control efficiency and operating

procedures. In general, State regulations that were reviewed are

as specified in the CTG, with several "additions." The additions

include the covering of forebays and separator sections, use of

EPA approved test methods to determine compliance with the

emission limitations, the use of a vapor recovery system that has

at least 90 percent control efficiency, additional vapor control

options, as well as specifications for the use of safety pressure

relief valves. 

The Colorado regulation specifies a minimum control

efficiency for control equipment and contains more "additional"

stipulations than Utah or the CTG. These additional provisions

involve covering forebay and separator sections, the use of EPA

Reference Test Methods to determine compliance, and control of
4-6

depressurization venting and process blowdowns. These additional

requirements cannot be used to determine stringency since they

will not result in quantifiable emission reductions. The Utah

regulation, in this case, is considered as stringent as the

Federal CTG.

The Bay Area and South Coast regulations require a greater

combined collection and control efficiency than the Colorado

rule. The CTG does not specify an add-on control efficiency. 

The South Coast regulation also specifies a VOC emission limit at

a fixed distance (1 cm) from the drain opening and requires a

shorter timeframe for repair than the CTG. Therefore, the South

Coast regulation is considered more stringent than the Bay Area

regulation, followed by Colorado, then the CTG. 

4.6 Stage I Vapor Recovery

The Federal CTG defines RACT for this source category in a

number of ways, suggesting several methods by which to conduct

displaced vapors from underground storage tanks to tank trucks.

It also suggests that system "design criteria" be developed to

accomplish efficient control of emissions.

Stringency for this category is determined by the VOC

emission limit and by any "additional" requirements or

specifications beyond what the Federal CTG requires. Only those 

additional requirements including work practices that result in

quantifiable emission reductions are considered to determine the

stringency of a regulation. 

The Colorado, Texas, Bay Area, and South Coast regulations

were reviewed for this source category. All regulations except

Colorado's contain standards that exceed the requirements

specified in the CTG. 

The State of Texas requires control equipment to be operated

during the transfer of gasoline, and VOC emissions to be reduced

to a certain limit. The CTG document does not specify a VOC

emission limit for this category and the "Blue Book" only

specifies control efficiency for Stage I emission control

equipment. Providing an emission limit (mg/l of gasoline

transferred) is more significant for the purpose of reducing
4-7

emissions than only requiring a control system efficiency. In

addition to the emission limit, Texas also specifies a tank size

exemption and required gauge pressure and vacuum pressure relief

limits for the tank of the fuel delivery truck. Pressure relief

settings are not specified in the Federal CTG. 

In general, the Bay Area and South Coast regulations have

adopted the guidelines in the CTG. The Bay Area regulation,

however, exempts gasoline storage tanks with a capacity less than

260 gallons in this source category. The CTG exempts several

tank sizes that are not found in the Bay Area. For example, if

the gasoline is used for agricultural purposes, the storage tank

capacity cutoff is over twice the capacity cutoff specified in

the Bay Area. The Bay Area also has additional exemptions that

are not specified in the CTG, but these were not used to

determine stringency of the rule. These exemptions will result

in fewer sources being required to comply with the rule.

The South Coast rule exempts gasoline storage tanks with

capacities less than 250 gallons. In addition, the rule also

exempts tanks used primarily for the fueling of implements of

husbandry and agricultural wind machines. These exemptions will

result in fewer affected sources. The South Coast regulation

also includes work practices that would result in quantifiable

emission reductions.

In conclusion, the Texas regulation is the most stringent,

followed by the South Coast. The Bay Area and Colorado rules are

as stringent as the CTG.

4.7 Solvent Metal Cleaning (Degreasing)

The Federal CTG divides this source category into three

separate types of parts cleaning (degreasing) operations: cold

cleaning, open top "vapor parts cleaners (degreasers)," and

"conveyorized parts cleaners." It further specifies the control

device options for each type. Stringency for this source

category is defined through the efficiency of control equipment

and the freeboard ratio value. 

Four State and the two California District regulations were

reviewed for this category. All State regulations, except for
4-8

Rhode Island, mirror the Federal CTG and include several

additional work practice requirements. The Rhode Island

regulation specifies a slightly higher freeboard ratio (0.75 vs.

0.70) for all cold cleaning units than the CTG. Freeboard

primarily serves to reduce drafts near the air/solvent interface. 

A freeboard ratio is determined by the freeboard height divided

by the width of the parts cleaner's air/solvent area. The higher

the ratio, the less emissions are released. The CTG also

indicates that an increase in ratio from 0.5 to 1.0 may yield

about a 50 percent reduction in emissions. 

The Bay Area and South Coast regulations specify the same

control equipment for open top vapor parts cleaners, cold

cleaners, and conveyorized parts cleaners, but require a greater

control efficiency than the CTG. The Bay Area specifically

indicates that solvent agitation must be accomplished only by

pump recirculation or by means of a mixer; air agitation may not

be used. The CTG states that agitation is generally accomplished

through the use of pumping, compressed air, vertical motion, or

ultrasonic. The CTG allows the use of air agitation involving

dispersing compressed air from the bottom of the "soaking;" the

air bubbles provide a scrubbing action. This type of agitation

is prohibited by the Bay Area because air bubbles may create more

emissions. 

For facilities using the freeboard ratio as a control

option, the Bay Area and South Coast regulations specify a

slightly higher freeboard ratio than the CTG (0.75 vs. 0.70). 

The South Coast regulation provides additional operating

requirements not specified in the Bay Area regulation or the CTG

that may have potential in reducing emissions. The CTG exempts

conveyorized parts cleaners with less than 2.0 m of air/vapor 2

interface from the requirement for a control device. 

One of the general requirements specified in the Bay Area

regulation prohibits waste solvent residues that are treated

prior to final disposal at an appropriate waste disposal facility

to contain more than 10 percent solvent by volume. The CTG does

not allow waste solvent to be disposed of or transferred to
4-9

another party such that greater than 20 percent of the waste (by

mass) can evaporate into the atmosphere. Both rules were

developed to restrict the amount of solvent in the waste, but

they are not specified in the same manner (units). The effect of

each requirement can be clarified by the following example. 

Assume 1 gallon of waste solvent residue will be treated prior to

final disposal and that it contains 10 percent by volume of

solvent. Using an average solvent density of 6.7 lb/gal and a

residue density of 9.2 lb/gal, the mass of solvent and of residue

in the waste are 0.67 lb and 8.28 lb, respectively. The

concentration of solvent by mass in the waste is 7.5 percent. 

When the concentration of solvent is increased to 15 percent by

volume, the concentration of solvent in the waste increases 12.9

percent by mass. Note: This is in violation of the Bay Area

rule, but not the Federal CTG.

In conclusion, the Bay Area regulation is as stringent as

the South Coast regulation, but more stringent than Rhode

Island's rule, since it has additional requirements that will

result in extra, quantifiable emission reductions.

 4.8 Surface Coating of Automobiles and Light-Duty Trucks

The Federal CTG recommends different emission limits for

prime application, topcoat application, and final repair

application coatings. The State and District regulations were

ranked according to criteria including VOC emission limitations,

additional emission limit for coating operations, transfer

efficiencies, and control efficiencies.

Colorado, New Jersey, and the two District regulations were

reviewed and ranked for this source category. The Colorado

regulation echoes the emission limits specified in the CTG. The 

Colorado regulation also provides an alternative method to meet

the emission limit for topcoat application in terms of mass of

VOC per unit volume of solids (nonvolatiles) deposited on the

coated part. This emission limit is not specified in the Federal

CTG. However, the alternative emission limit can be calculated

using the guideline given in Appendix E or F. The calculated

emission limit for topcoat application is 4.5 lbs VOC/gal of
4-10

solids, not 15.1 lbs VOC/gal of solids. 

New Jersey emission limits for topcoat application and final

repair application are identical to the emission limits stated in

the Federal CTG. The State of New Jersey divides prime

application into two operations (electrophoretic dip prime and

spray prime) with two emission limits. The averaged value of

these limits is identical to the emission limit for prime

application stated in the Federal CTG. This shows that New

Jersey regulation is more process-specific than the Federal CTG,

but not necessarily more stringent. In addition, the New Jersey

regulation specifies two additional VOC emission limits for

custom topcoating and refinishing operations. These emission

limits are higher than the Federal CTG and Colorado limits for

all three operations. These limits provide additional reduction

of emissions and are therefore more stringent.

The New Jersey regulation requires that the emission

reduction of the control apparatus be demonstrated on an hourly

basis or on the basis of hourly emission rate calculated on a

solids (nonvolatiles) applied basis. The CTG does not require

the efficiency of a control apparatus to be demonstrated on an

hourly basis. Although New Jersey's requirement may not result

in quantifiable emission reductions, it will allow compliance to

be evaluated more accurately.

The Bay Area specifies a lower VOC emission limit for primer

application than the CTG. It also provides four additional VOC

emission limits for flexible primer, color topcoat,

basecoat/clearcoat, and off-line coating. The emission limit for

basecoat/clearcoat is lower than that for basecoat specified in

the New Jersey regulation.

The South Coast regulation provides VOC emission limits for

several coating (primer, topcoat, and final) and application

methods (electrophoretic dip, manual electrostatic spray, and air

atomized spray). The emission limits for the topcoat and final

repair coating categories are higher than those specified in the

CTG and, therefore, are less stringent. The CTG specifies an

emission limit for primer application based on use of an
4-11

electrophoretic system. The South Coast regulation specifies a

lower VOC emission limit for electrophoretic applied primer than

that in the CTG. In addition, the South Coast regulation

provides emission limits for primer surfacer, spray primer,

basecoat, and clearcoat that are not found in the CTG. The South

Coast regulation also requires higher transfer efficiencies than

the Bay Area. The Bay Area regulation follows the "Blue Book"

guidelines for transfer efficiencies.

Due to a lower VOC emission limit for primer application and

additional emission limits, the Bay Area regulation is ranked

first, followed by the South Coast's, New Jersey's, and the CTG. 

Colorado's rule is considered as stringent as the CTG. 

4.9 Surface Coating of Cans

The Federal CTG defines RACT limits for four coating

categories: sheet base coat and over-varnish and two piece can

exterior; two and three-piece can exterior body spray and twopiece can exterior end; three-piece can side-seam spray; and end

sealing compounds. ( Three State and the two District

regulations were reviewed and ranked according to stringency of

the State and District requirements versus CTG RACT. The

criteria used to rank these regulations were based on the

required VOC emission limits for several coating applications,

additional emission limit, and the required control efficiency of

a control device. 

The Colorado, Maine, and New Jersey regulations specify the

same VOC emission limits as the CTG. Colorado also sets an

additional emission limit for "any other coating," which is not

provided in the CTG or the New Jersey regulation. The New Jersey

regulation also requires that the efficiency of a control

apparatus be achieved on an hourly basis or on the basis of

hourly emission rate calculated on a solids applied basis. This

requirement will evaluate more accurately the compliance

performance than having an initial or one emission test in a

year. The New Jersey regulation requires the same control

efficiency as the CTG and provides exemptions that are not found

in the CTG. With regard to the smaller population of sources to
4-12

which the rule is applicable, the rule is not considered more

stringent than the CTG. The Maine regulation contains a

provision that will enhance the pollution prevention aspects of

the rule.

The Bay Area regulation specifies separate emission limits

for sheet basecoat and two-piece can exterior basecoat. These

emission limits are lower than the limit specified in the CTG and

thus are more stringent. The South Coast regulation has lower

emission limits for three-piece base, two-piece exterior

basecoat, and two-piece interior body spray than the CTG. In

addition, the South Coast regulation specifies two emission

limits for end sealing compound applicable to food and non-food

cans. The Federal CTG specifies the same emission limits 

applicable to both food and non-food cans. The South Coast

emission limit for non-food cans is lower than the CTG. The

South Coast regulation also provides two additional emission

limits and higher control efficiency than the Bay Area and New

Jersey rules, and the CTG. 

In conclusion, the South Coast regulation is the most

stringent, followed by that of the Bay Area. The Colorado

regulation is more stringent than New Jersey's. This is because

of an additional emission limit that will apply to a greater

population of sources. The New Jersey and Maine regulations are

as stringent as the CTG in terms of coating emission limits and

control efficiency. However, the regulations require compliance

to be based on hourly emission reduction or hourly emission rate

calculated on a solids applied basis.

4.10 Surface Coating of Fabrics

This category is divided into two coating operations: fabric

and vinyl coating lines. The CTG defines RACT emission limits in

terms of mass of VOC per unit volume of coating applied (minus

water and exempt solvents). These emission limits are based on

the use of an add-on control device that recovers or destroys at

least 81 percent of the VOC introduced in the coating. In the

CTG, the limitation for fabric coating can also be achieved by

the use of a high solids coating containing about 60 volume
4-13

percent solids (nonvolatiles) or a waterborne coating with a

solids content of about 24 volume percent.

Five State regulations (Colorado, New Jersey, Utah, Rhode

Island, and Maine) and the two California District regulations

were reviewed for this category. These regulations were ranked

according to stringency of the State requirements versus the

Federal RACT guidance. Ranking was accomplished by comparing the

VOC emission limits and the required control efficiency. 

The emission limits stated in all of the State regulations

reviewed are identical to the emission limits stated in the

Federal CTG. Only the Utah and Rhode Island regulations provide

equivalent emission limits for fabric and vinyl operations in

terms of mass of VOC per unit volume of solids (nonvolatiles). 

These limits were calculated using the guideline specified in

Appendix F. The New Jersey regulation also requires the control

device to achieve the emission reduction on an hourly basis or

the hourly VOC emission rate should not be greater than the

hourly emission rate calculated on a solids applied basis. The

hourly requirement is not specified in the CTG. This aspect of

the New Jersey regulation will evaluate more accurately

compliance performance than on the basis of the requirements in

the Colorado regulation or the CTG. Such a requirement also

enhances the pollution prevention aspects of the rule, but may

not necessarily result in a quantifiable reduction in emissions. 

The Rhode Island regulation requires a higher number for the

overall control efficiency and, therefore, is are more stringent

than the New Jersey or Colorado rule, or the CTG. Although the

Maine regulation has an attractive provision, this rule is not

considered more stringent than the CTG.

The Bay Area and South Coast regulations specify a lower

emission limit for fabric coating processes than the CTG. The

South Coast regulation requires a higher control efficiency and

transfer efficiencies than the Bay Area rule or the CTG. In

addition to emission limits for fabric and vinyl coating, the

South Coast regulation has separate and lower emission limits for

the plastisol and wash primer used in these coating operations. 
4-14

Additional work practices are also found in the South Coast

regulation that are not found in the Bay Area or other State

regulations, or the CTG. In conclusion, the South Coast

regulation is ranked the most stringent, followed by the Bay Area

rule, the Rhode Island rule, and then the Federal CTG. The

Colorado, Maine, and New Jersey regulations are as stringent as

the CTG.

4.11 Surface Coating of Large Appliances

The Federal CTG recommends a single emission limit for a

large appliance coating line in terms of mass of solvent per unit

of coating applied (minus water and exempt solvents). This

emission limit is derived based on the use of low organic solvent

coatings containing at least 62 volume percent solids

(nonvolatiles) or any waterborne equivalent. An equivalent

method for achieving the desired reduction would be the use of an

add-on control device such as an incinerator or a carbon adsorber

that can achieve approximately an 81 percent overall emission

reduction.

Four States (Colorado, Utah, Maine, and New Jersey) and the

Bay Area regulation were reviewed and ranked according to the

stringency of State requirements versus Federal RACT

requirements. All State regulations have the same emission limit

as specified in the Federal CTG. The Maine regulation provides

an incentive (by allowing monthly rather than daily

recordkeeping) for facilities that demonstrate that only low-VOC

coatings are used. Although this provision was not factored into

determining the stringency of the rule, the provision enhances

the pollution prevention aspects of the rule. The New Jersey

regulation has an additional requirement for a control device to

achieve an efficiency on an hourly basis or an hourly VOC

emission rate shall not be greater than the allowable hourly

emission rate calculated on a solids applied basis. This hourly

requirement is not specified in the Federal CTG. This

requirement is not used to determine stringency since it may not

result in quantifiable emission reductions, but it does provide

for more accurate compliance performance than the CTG
4-15

recommendation. These State regulations are, therefore, as

stringent as the CTG. 

The Bay Area regulation has a lower emission limit and a

higher overall control efficiency requirement than the CTG or the

other regulations reviewed. As a result, the Bay Area regulation

has been ranked the most stringent.

4.12 Surface Coating of Metal Coils

The Federal CTG specifies only a single emission limit for

surface coating of metal coil operations. This emission limit is

expressed as mass of VOC per unit volume of coating as applied

(minus water). 

Two State (Colorado and New Jersey) and the two California

District regulations were reviewed and ranked according to

stringency of the requirements in comparison to RACT. Stringency

is based on the required emission limit, control efficiency, and

other additional requirements. The Colorado and New Jersey

regulations specify a VOC emission limit identical to the

emission limit stated in the Federal CTG.

An alternate means of complying with the emission limit is

through the use of control technologies such as add-on control

devices or low-solvent coatings. The CTG states that the use of

thermal or catalytic incinerators can achieve over 90 percent

emission reduction. The New Jersey regulation specifies the same

emission control efficiency as the CTG, but requires the VOC

control device to reduce the emissions on an hourly basis or to

achieve the maximum allowable hourly emission rate calculated on

a solids applied basis. Although this requirement may not result

in quantifiable reductions, it will, however, provide for more

accurate evaluation of the compliance performance than the

specifications in the CTG. The New Jersey regulation also

specifies an exemption for daily coating usage. This exemption

will result in a smaller population of sources being subject to

the rule, but it is an issue of applicability and not the

stringency of the rule. Thus, although the New Jersey regulation

is more attractive, it is considered equivalent to the CTG.
4-16

The Bay Area and South Coast regulations specify the same

emission limit for this category, but the limit is lower than the

one specified in the CTG. In addition to the emission limit, the

South Coast regulation requires greater emission control and

transfer efficiency than the CTG. Therefore, the South Coast

regulation is considered the most stringent, followed by the Bay

Area regulation, and then the CTG.

4.13 Surface Coating of Metal Furniture

The Federal RACT emission limit for a metal furniture

coating line is expressed as mass of VOC per unit volume of

coating as applied (minus water). This emission limit is based

on the use of low organic solvent coatings. The limit can also

be achieved by the use of waterborne coatings or an add-on

control device. The control device must have at least an 80

percent overall control efficiency.

Rules for four States (Colorado, New Jersey, Maine, and

Utah) and one of the California Districts (Bay Area) were

reviewed and ranked according to stringency of these requirements

versus Federal RACT. The criteria used in determining stringency

include the emission limitation, required control efficiency, and

alternative emission reduction.

All of the regulations reviewed have the same emission limit

as the Federal CTG. For the surface coating operation served by

a control device, the New Jersey regulation requires that

emission reductions be achieved on an hourly basis or an hourly

VOC emission rate no greater than the maximum allowable hourly

emission rate calculated on a solids applied basis. The CTG does

not require the control efficiency to be demonstrated on an

hourly basis. New Jersey's requirement, however, will result in

more accurate compliance performance evaluation than the CTG. 

Maine provides an incentive for facilities that demonstrate that

only low-VOC (compliant) coatings are used, by allowing them to

keep monthly rather than daily records as indicated in the "Blue

Book." This provision was not factored into determining the

stringency of the rule. However, the provision encourages
4-17

pollution prevention actions. In general, the State regulations

are as stringent as the CTG.

The Bay Area regulation specifies two VOC emission limits

for this operation based on the drying techniques employed. Both

emission limits are lower than those recommended in the CTG. The

Bay Area also requires a slightly higher control efficiency and

transfer efficiency. Therefore, the Bay Area regulation is

considered to be the most stringent.

4.14 Surface Coating of Magnet Wire

The Federal CTG recommends a single emission limit for

magnet wire coating operations. This limit is given in terms of

mass of VOC per unit volume of coating as applied (minus water). 

This emission limit may also be achieved using an add-on control

device such as an incinerator, provided 90 percent control

efficiency is achieved.

Three State (Colorado, New Jersey, and Utah) regulations and

the South Coast regulation were reviewed and ranked according to

the stringency of these requirements versus Federal RACT. The

criteria used in determining stringency include the VOC emission

limitation and the required control efficiency.

The State and South Coast regulations specify the same 

emission limit as the Federal CTG. Utah specifies an equivalent

emission limit in units of mass of VOC per unit mass of solids. 

Guidelines for equivalency calculations are given in Appendices E

and F. 

For surface coating operations with a control device, the

New Jersey regulation requires the device to have at least 90

percent emission reduction each hour or an hourly VOC emission

rate no greater than the maximum allowable hourly emission rate

calculated on a solids applied basis. The CTG specifies the same

control efficiency as the New Jersey regulation, but it does not

require the efficiency of a control device to be demonstrated on

an hourly basis. The New Jersey provision should result in more

accurate evaluation of the compliance performance. The rule is

not, however, necessarily more stringent than the CTG.

The South Coast regulation does not have any requirements
4-18

that will affect the relative stringency of the rule. However,

they have provided several exemptions that are not specified in

the CTG, which reduces the number of sources to which the rule is

applicable.

4.15 Surface Coating of Paper

The Federal RACT emission limit for a paper coating line is

defined in terms of mass of VOC per unit volume of coating

applied (minus water). The Federal CTG also states that the

emission limit can be achieved using alternative means such as

incinerators, carbon adsorbers, or coatings that contain low

fractions of organic solvents.

Five State (Colorado, New Jersey, Utah, Rhode Island, and

Maine) and the two California District regulations were reviewed

and ranked for this category. The State regulations specify the

same emission limit for paper coating lines as the CTG. In

addition to the emission limit, New Jersey specifies coating

cutoff exemptions and requirements for an hourly emission

reduction or an hourly emission rate calculated on a solids

applied basis. This requirement may not result in quantifiable

reductions, but it will allow the compliance performance to be

more accurately evaluated. The Maine and Rhode Island

regulations provide equivalent emission limits for paper coating

operations in terms of mass of VOC per unit volume of solids

(nonvolatiles). These limits were calculated using the

guidelines specified in Appendix F. The Maine regulation

contains a provision that provides an incentive (monthly rather

than daily recordkeeping) for facilities which demonstrate that

only low-VOC coatings are used. The provision enhances the

pollution prevention aspects of the rule, but it was not used to

determine relative stringency. Maine's regulation also applies

to all paper coating lines (rather than only those above the

CTG's emission cutoffs), which is an applicability rather than a

stringency issue.

The Bay Area and South Coast regulations specify the same

emission limit, which is lower than that specified in the CTG. 

The South Coast regulation also specifies an emission limit for
4-19

plastisol, the required capture efficiency, and operating

requirements. Such information is not found in the Bay area

regulation or the CTG. These operating requirements are provided

to reduce or prevent emissions, but the reduction is not

quantifiable. In conclusion, the South Coast regulation is the

most stringent, followed by the Bay Area, then the CTG. The five

State regulations are considered as stringent as the CTG.

4.16 External Floating Roof Petroleum Tanks

The Federal CTG defines RACT in terms of an applicability

cutoff related to the storage capacity of a tank and the type of

seals or closure devices that must be installed on the tank. 

Stringency for this category is defined through additional

equipment requirements which result in quantifiable emission

reductions. The exemption levels required by the State

regulations for this category were also evaluated. However,

exemption levels for this category are not appropriate for

evaluation of stringency, since the exemptions are more related

to the capacity cutoff levels. Although one of the regulations

reviewed for this source category was numerically less stringent

than the CTG, the difference in the allowable seal gap

specifications is not believed to be significant. 

Two States (Colorado and Utah) and the two District

regulations were reviewed for this category. The State of

Colorado exemption levels mirror those found in the CTG, with one

addition. Colorado exempts external floating roof (EFR) tanks

that store any material whose true vapor pressure as stored

"never exceeds" 1.3 psia (8.96 kPa), while the CTG exempts EFR

tanks with a higher vapor pressure cutoff level (1.5 psia). 

Therefore, more tanks are likely to be subject to the Colorado

rule. The Utah regulation cited in the summary table allows

greater gap space between the seal and tank wall than the CTG. 

The impact on emissions is unlikely to be quantifiable.

The Bay Area and South Coast regulations have similar tank

capacity cutoff requirements to the CTG, but they have a lower

vapor pressure cutoff. Therefore, these regulations are more
4-20

stringent than the CTG and the other States evaluated. The Bay

Area regulation also requires a greater overall control

efficiency as well as a smaller gap between the tank shell and

the secondary seal than the South Coast regulation or the CTG. 

The South Coast regulation also specifies additional operating

requirements that are not found in the CTG. These additional

requirements include specifications for all openings in the roof

and any emergency roof, and the type of tank used for storing

crude oil containing hydrogen sulfide. These requirements may

not result in a quantifiable reduction in emissions, but they

enhance the pollution prevention aspects of the regulation. In

conclusion, the Bay Area provisions are considered the most

comprehensive relative to the CTG, followed by the South Coast

regulation.

4.17 Gasoline Tank Truck and Vapor Collection System Leaks

The RACT level for this source category is delineated in

terms of control approaches. The control approach is a

combination of testing, monitoring, and equipment design to

ensure that good maintenance practices are employed to prevent

leaks from truck tanks or tank compartments and vapor collection

systems during gasoline transfer at bulk plants, bulk terminals,

and service stations. The CTG recommends that a reading should

be less than or equal to 100 percent of the lower explosive limit

(LEL) at 2.5 centimeters around the perimeter of a potential

leaking source as detected by a combustible gas detector. The

CTG further specifies how vapor collection and vapor processing

equipment should be designed and operated so as to prevent leaks.

Both the Colorado and Texas regulations mirror the Federal

CTG requirements. In addition, the Colorado regulation requires

periodic visual inspections. This requirement provides a

desirable feature, but it does not result in a quantifiable

reduction. Therefore, in general, the Colorado and Texas

regulations are as stringent as the Federal CTG. (Information

regarding this source category was not found in the Bay Area or

South Coast regulation).

4.18 Graphic Arts
4-21

The Federal CTG defines RACT in terms of percentage of

emission reduction through the application of add-on control

technology or product substitution. The "Blue Book" provides a

RACT emission limit for this category in terms of mass of VOC per

unit mass of solids applied [0.5 kg VOC/kg (0.5 lbs VOC/lbs)

solids on a per-line basis]. The percentage of solids

(nonvolatiles) required in the coating is not specified. This

emission limit is applicable to both flexographic and rotogravure

printing processes, and to both publication and packaging

printing in which maximum theoretical VOC emissions (including

solvents used to clean each of these printing presses) without

control devices from all printing presses are greater than or

equal to 90.7 megagrams (100 tons) per year with 8,760 operating

hours or maximum production. The CTG RACT does not apply to

offset lithography or letterpress printing.

Six State regulations (Colorado, Connecticut, Maine, New

Jersey, New York, and Utah) were reviewed and ranked according to

the stringency of State requirements versus the CTG RACT

requirements. The criteria used to rank these regulations depend

upon how the specific concentration of nonvolatile (solid)

material in inks or the volatile portion of waterborne inks was

calculated. The percentage emission reduction and the

requirements for an alternative control technology also affect

the stringency.

The Colorado and Utah regulations basically mirror the

Federal CTG. However, the Connecticut regulation requires a

control system to achieve the emission limit on an hourly basis

or every adsorption cycle. Due to these requirements, the

Connecticut regulation will result in more accurate compliance

performance evaluations than the CTG and may thus help to

identify areas having potential emission reduction. 

The Maine and New York regulations specify a lower VOC

emission cutoff (50 tons per year or less for some New York

areas) than the CTG, and thus, more facilities are subject to the

rules. The New Jersey regulation exempts surface coating

operations (commercial and research operations) that use coatings
4-22

containing VOC below the cutoff hourly or daily rate. The New

Jersey regulation also specifies the emission limit in terms of

mass of VOC per unit volume of coating. To compare stringency

between the Federal RACT and the New Jersey regulation, the units

of the emission limit were converted to mass of VOC per unit mass

of solids using the procedure specified in Appendix F. The

calculated emission limit is 0.3 lb VOC/lb of solids and is lower

than the limit specified in the CTG (0.5 lb VOC/lb of solids). 

Therefore, the New Jersey regulation is considered more stringent

than the CTG and the other State regulations. The Utah

regulation is applicable to "special printing operations," which

results in more printing operations subject to the rule. 

Overall, the State regulations other than New Jersey's are as

stringent as the CTG. 

The Bay Area and South Coast regulations specify the same

emission limits in terms of mass of VOC per unit volume of

coating. The calculated emission limit in terms of mass of VOC

per unit mass of solids (nonvolatiles) is 0.24, which is lower

than the limit specified in the "Blue Book" or the New Jersey

regulation. Therefore, the Bay Area and South Coast regulations

are more stringent than the New Jersey regulation or the CTG. 

The Bay Area, however, requires a higher overall control

efficiency than the South Coast (85 vs 70 percent). The Bay Area

also specifies emission limits for two additional coatings that

are not specified in the South Coast regulation or the CTG. In

conclusion, the Bay Area regulation is considered more stringent

than the South Coast rule, followed by New Jersey, and then the

CTG.

4.19 Leaks from Petroleum Refinery Equipment

The Federal CTG defines RACT in terms of operating

procedures, monitoring program, and timeframe for repairing

leaks. Stringency for this category is defined by a shorter

timeframe for repairing leaks, additional monitoring, and

operating requirements. The Utah, Colorado, and Bay Area

regulations contain some requirements that are considered more

stringent than the Federal CTG.
4-23

Stringency for this source category was difficult to

quantify since all of the listed requirements consist of specific

recordkeeping procedures, specific monitoring requirements, and

additional specifications for equipment. These requirements,

although necessary for determining compliance, are difficult to

rank and their benefits are not readily quantifiable. Also, some

of the additional equipment specifications that are now required

may not have existed at the time the Federal CTG was published. 

Therefore, no clear distinction between "additional" requirements

beyond RACT can be made.

The Utah, Colorado, and Bay Area regulations were reviewed

for this category. Utah and Colorado include additional

"administrative" requirements, such as specification of a timeframe for a proposed monitoring program, as well as documentation

and notification of the proper authorities when inspecting a

leak. Each State regulation reviewed lists the same EPA

Reference test methods, calibration procedures, and similar VOC

monitoring procedures. The Utah regulation exempts some

equipment from monitoring requirements, thereby making them

applicable to a smaller population of sources than the Federal

CTG and the Colorado rule. As shown in the table in Appendix B,

the exemptions are specifically related to the vapor pressure of

stored product, location of pressure relief valves, and the

contents of the stream composition. The "unsafe to monitor"

requirements found in the Utah regulation are not specifically

found in the Federal CTG, the Colorado regulation, or the "Blue

Book." However, the "Blue Book" recommends consistency with the

SOCMI guidance in relation to "unsafe to monitor" requirements,

which mirrors the requirements advised by the State (Utah)

regulation. As described above, there are very minor differences

in the State regulations and they are considered generally

comparable. Therefore, both the Utah and Colorado regulations

are determined to be as stringent as the CTG.

The Bay Area regulation defines a leak with lower VOC

concentration (500 ppm from any valve or connector and 1,000 ppm

from any pump or compressor) and provides a shorter timeframe for
4-24

repairing leaks (7 days vs 15 days) than the CTG, Utah, or

Colorado. Both requirements will result in substantial and

quantifiable emission reductions. Therefore, the Bay Area

regulation is considered the most stringent.

4.20 Surface Coating of Miscellaneous Metal Parts and Products

The Federal CTG defines RACT in terms of emission limits for

several types of coating categories. The recommended limits are

given in terms of mass of VOC per unit volume of coating as

applied (minus water). The CTG gives "case examples" of how to

calculate emission limits and emission factors. It lists a

typical solids (nonvolatiles) content for a conventional coating,

but does not indicate to which of the five coating categories the

example applies. Thus, the CTG does not give "typical" coating

compositions for the coating of miscellaneous metal parts.

Stringency for this category is defined by comparing the

emission limit, control efficiency, additional emission limits,

and other requirements which may result in quantifiable

reductions. Four State regulations and the two District

regulations were reviewed for this category. 

The State regulations (Utah, Colorado, Maine, and New

Jersey) specify the same emission limits as the CTG. In addition

to the emission limits, the Maine regulation provides an

incentive for facilities which demonstrate that only low-VOC

coatings are used by allowing them to keep monthly rather than

daily records. The CTG specifies daily recordkeeping. 

The Bay Area and South Coast regulations specify a lower

emission limit than the CTG for air dried items. The South Coast

regulation provides two emission limits for various coatings

depending upon how the coatings are dried (air dried or baked). 

The emission limits for coatings that are baked are usually lower

than for air dried. In addition to the emission limits, the

South Coast regulation also requires a greater control efficiency

for control systems and provides emission limits for "additional

coatings" that were not specified in the CTG (including limits

for cleaning materials). Therefore, the South Coast regulation

is considered the most stringent, followed by the Bay Area, and
4-25

then the CTG.

4.21 Pneumatic Rubber Tire Manufacturing

The Federal CTG defines RACT under four main operations

involved in the manufacture of rubber tires, listing control

options for each of these operations and giving the expected

capture and destruction efficiencies. Stringency for this source

category is determined by comparing the control options and their

respective efficiencies. 

Two State regulations (Colorado and Connecticut) and the Bay

Area regulation were reviewed for this source category. Both the

Colorado and Connecticut regulations generally mirror the Federal

CTG in almost all requirements. However, the Connecticut

regulation could be considered more stringent since it requires

the use of control equipment able to achieve higher control

efficiencies than required by the CTG. The CTG states that the

expected capture and control efficiency is between 65 and 85

percent. However, the State of Connecticut requires a control

efficiency of at least 85 percent; therefore, its rule is

considered to be more stringent. In addition, the Connecticut

regulation requires the efficiency of a control system to be

maintained on an hourly basis (for incinerators) or on each

adsorption cycle (for carbon adsorption systems). This latter

requirement will result in a more accurate compliance performance

evaluation, but does not affect the stringency of the rule.

The Bay Area regulation specifies a higher overall control

efficiency for emission reduction systems for this category than

the Connecticut regulation or the CTG.

4.22 Surface Coating of Flat Wood Paneling

The Federal CTG defines RACT in several ways. The emission

limits are expressed as mass of VOC per unit area coated, mass of

VOC per unit volume of coating, and mass of VOC per unit volume

of solids (nonvolatiles). 

The relative stringency of rules for this category is

determined by comparing the emission limits and the required

control efficiency of a control device, and by examining

additional emission limits. Four State regulations (New Jersey,
4-26

Maine, Texas, and Utah) and the two California District

regulations were reviewed for this category. The State

regulations specify the same emission limits as the CTG. In

addition to these limits, the Maine regulation provides an

incentive for facilities that demonstrate that only low-VOC

(compliant) coatings are used (monthly rather than daily

records). This incentive was not factored into determining the

relative stringency; however, this provision does encourage

pollution prevention activities.

The Bay Area and South Coast regulations specify only one

emission limit for wood flat stock coatings. Wood flat stock is

defined as panels containing wood including but not limited to

redwood stocks, plywood panels, particle boards, composition

hardboards, and any other panels containing solid wood or wood

product. To compare stringency between the CTG and the District

rules, the emission limits specified in the CTG were averaged. 

The averaged emission limit is 0.3 kg/l (2.53 lb/gal) of coating

and is higher than the limit specified in the Bay Area or South

Coast regulation. In addition to the limit, the South Coast

regulation requires higher destruction and capture efficiencies

than the CTG. Therefore, The South Coast regulation is

considered the most stringent, followed by the Bay Area

regulation, and then the CTG.

4.23 Synthesized Pharmaceutical Products

The Federal CTG defines RACT in several ways for this source

category. It specifies that vents that emit at least a certain

amount per day of VOC must install surface condensers or

equivalent controls. The CTG gives temperature and vapor

pressure specifications for surface condensers. Production

equipment emitting over a certain mass per day of VOC must

control to a specified percentage emission reduction. The CTG

also specifies a cutoff for VOC-containing storage tanks, and

contains additional work practice provisions.

Stringency for this category is defined by additional

equipment and operation requirements that are not found in the

Federal CTG. Both the Colorado and Connecticut regulations
4-27

generally mirror the Federal CTG. They also provide additional

requirements to those specified in the CTG. These requirements

include covers for all in-process tanks and making repairs 

immediately, rather than within 15 days as allowed by the CTG. 

However, the benefit of these requirements is not readily

quantifiable, and therefore they are not factored into

determining the stringency. For these reasons, the Colorado and

Connecticut rules are ranked as stringent as the CTG.

The relative ranking of Colorado, Connecticut, and the

Federal CTG is very close. As stated earlier, the differences

between the three are minor with the segregating factor related

to how many "additions" there are.

In addition to requirements specified in the CTG, the Bay

Area and South Coast regulations specify requirements for

centrifuges, rotary or vacuum filters, or any other filters. The

Bay Area also requires the use of chemical sterilizers, which is

not contained in the South Coast regulation or the CTG.

4.24 Air Oxidation Processes - SOCMI

Federal RACT is applicable to any air oxidation facility in

the synthetic organic chemical manufacturing industry (SOCMI) in

which air is used as an oxidizing agent to produce an organic

chemical. Any equipment used to collect VOC for sale or reuse

from a product recovery system of an oxidation facility is

subject to RACT. 

The CTG specifies that each air oxidation process vent

stream must use a control device that reduces total organic

compound emissions by 98 percent by mass or to 20 ppmv. However,

this is not required for facilities that have a total resource

effectiveness (TRE) index value greater than unity. The TRE

index is a measure of the supplemental total resource requirement

per unit VOC reduction, associated with VOC control by thermal

oxidation. All resources that are expected to be used in VOC

control by thermal oxidation are taken into account in

determining the TRE index.

No State or District regulations concerning air oxidation

processes - SOCMI were provided through the Work Group. Several
4-28

State regulations (Texas, Pennsylvania, Rhode Island, and

Colorado) were consulted, but no State regulations pertaining to

this category were located.

4.25 Equipment Leaks from Natural Gas/Gasoline Processing 

 Plants

The Federal CTG for this source category defines equipment

specifications and suggests a leak detection and repair (LDAR)

program. The CTG also recommends the appropriate test methods to

be used to determine compliance with any standards set forth, and

provides an inspection schedule.

Relative stringency for this source category depends on a

shorter timeframe for leak repair and by additional inspection

requirements not set forth in the CTG. The Texas regulation and

the two California District regulations were reviewed for this

category.

The Texas regulation specifies monitoring and repair

requirements for relief valves that have vented to the atmosphere

within 24 hours at manned facilities or within 30 days at

unmanned facilities. The CTG does not provide any timeframe for

repairing leaks from relief valves. This provision, however, is

not used to determine stringency since the benefit is not readily

quantifiable.

The Bay Area regulation specifies the distance to measure

the concentration of VOCs from the source of a leak and the timeframe for repairing any leak. The regulation provides two timeframes for repairing leaking equipment, which depend upon whether

or not the equipment is essential. The Bay Area rule defines the

term "essential" as applying to any equipment that cannot be

taken out of service without shutting down the process which it

serves. The Bay Area regulation specifies that if the leaking

equipment is not essential or the equipment can be repaired

without interrupting the process, the leak must be repaired

within 24 hours. This part of the rule is more stringent than

the CTG. For essential equipment, the Bay Area requires the leak

to be minimized within 24 hours and if the leak persists and

exceeds a concentration of 10,000 ppm, the equipment is to be
4-29

repaired at the next scheduled maintenance. Stringency could

have been determined based on the length of time required to

minimize the losses from leaks but, in this case, the requirement

may not result in a quantifiable reduction in emissions. It

does, however, enhance the pollution prevention aspects of the

rule. 

The South Coast regulation specifies several timeframes for

different concentrations of leaks. The rule requires repair of a

minor gas leak (in excess of 1,000 ppm but less than 10,000 ppm)

within 14 calendar days. This range of concentration is not 

considered a leak in the CTG or the Bay Area rule, and no repair

is needed. The South Coast regulation requires a leak with a VOC

concentration of greater than 10,000 ppm to be repaired within 5

days (not 15 days as specified in the CTG). The timeframe is

further reduced to 1 day for repairing a gas leak with VOC

concentration over 50,000 ppm or any liquid leak. These

requirements should result in a significant reduction in

emissions.

The Bay Area and South Coast regulations also provide

additional operating requirements pertaining to uncovered

vessels, liquid pools, and operator inspection that will enhance

the pollution aspects of the rules. 

4.26 Large Petroleum Dry Cleaners

The Federal CTG for large petroleum dry cleaners sets an

emission limit in terms of mass of VOC per unit mass of articles

cleaned. It specifies the control equipment and a timeframe for

repairing leaks.

The relative stringency for this category is determined on

the basis of lower VOC emission limits or alternative emission

limits, longer draining time, and additional requirements that

may result in reducing emissions.

No State regulations for controlling large petroleum dry

cleaners were provided through the Work Group. New York,

Pennsylvania, and Texas rules were consulted, but they addressed

only percholoroethylene dry cleaners.

The Bay Area and South Coast regulations require cartridge
4-30

filters to be drained in the filter housing for at least 12 hours

before removal. The CTG is less stringent than the Bay Area or

the South Coast regulation since it requires only 8 hours of

draining time. The Bay Area and South Coast regulations also

provide specific operating requirements for transferring articles

to the dryer within a specified time limit, which will result in

quantifiable emission reductions. The South Coast regulation

specifies the same emission limit as the CTG for a dry cleaning

facility with a solvent filtration system. The South Coast

regulation also provides an alternative method to meet the

emission limit in terms of mass of VOC per mass of solvent still. 

This means that if the first emission limit is not applicable,

the alternative method must be used to comply with the rule. The

Bay Area, on the other hand, specifies a lower VOC emission limit

and a lower solvent flow rate from a solvent recovery dryer than

the South Coast regulation or the CTG. These provisions would

likely result in significant emission reductions. Therefore, the

Bay Area regulation is considered more stringent than the South

Coast rule or the CTG.

4.27 Polymer Manufacturing

The Federal CTG divides this source category into three

types of polymer manufacturing plants: polystyrene,

polypropylene, and high-density polyethylene. RACT for this

category is defined in terms of emission limits and percentage

emission reductions or emission rates. An emission limit in

terms of mass of VOC per unit volume is specified only for

polystyrene plants using continuous processes. Recommended

limitations for both polypropylene and high-density polyethylene

plants are given in terms of percent of emission reduction or

emission rates. The Federal CTG states that the RACT

recommendations were made on the basis of a single control device

controlling all vents of VOC emissions.

Only one State regulation (Connecticut) was received from

the Work Group members and reviewed for this source category. No

RACT rule for this category was located in the Bay Area or South

Coast regulation. The Connecticut regulation specifies only an
4-31

emission limit (in terms of mass of VOC per unit volume) for

polystyrene plants. No information is available for

polypropylene or high-density polyethylene plants. The State

emission limit for polystyrene plants is the same as in the

Federal CTG (0.12 kg of VOC/1,000 kg of product). However,

Connecticut's emission limit for polystyrene plants must be

achieved over a 1-hour period. In order to meet the limit, it is

necessary to monitor or document the performance of the control

equipment every hour. The Connecticut regulation also requires

the owner or operator of a facility to maintain monitoring

records for a period of 2 years, while the Federal CTG does not

specify a timeframe over which these records must be kept. For

these reasons, the Connecticut regulation is considered to be

more stringent than the Federal CTG.

4.28 SOCMI and Polymer Manufacturing Equipment Leaks

RACT is applicable to components that appear to be leaking. 

These components include pumps, compressors, valves, open-ended

lines, safety relief valves, etc. The CTG also specifies

inspection and maintenance requirements.

Only one State regulation (Connecticut) was reviewed for

this category, since information was not located for this

catgegory for the Bay Area or the South Coast. The criteria used

to determine relative stringency are based on compliance and

reporting requirements.

The Connecticut regulation requires leaking equipment found

during monitoring or on the basis of sight, smell, or sound to be

repaired within 15 days after detection. Providing a specific

timeframe to repair equipment leaks should help reduce VOC

emissions significantly. The State regulation also requires 10-

day notification prior to the scheduled quarterly monitoring. 

This requirement is part of the monitoring procedures to be in

compliance, but it does not have any impact in reducing 

emissions. In general, the Connecticut regulation is more

stringent than the Federal CTG. 
 This appendix describes Federal RACT for source categories 2

covered in the Group I CTGs, as well as regulatory requirements

for the same categories as contained in selected State/local VOC

rules.

A-32

APPENDIX A.

COMPARISON OF STATE/LOCAL VOC RULES TO FEDERAL RACT 

FOR GROUP I CTG CATEGORIES2
 "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," 3

Clarification to Appendix D of November 24, 1987 Federal Register - May 25, 1988

(revised 1/11/90), U.S. Environmental Protection Agency, Office of Air Planning

and Standards, Research Triangle Park, North Carolina.

A-33

CUTBACK ASPHALT 

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Substitute emulsified asphalt for cutback asphalt.

The Blue Book suggests seasonal exemptions (i.e., outside of ozone season) as opposed to 3

temperature forecasting (e.g., <50EF), specifies (1) no higher than 7% oil distillate as

maximum allowable solvent content in emulsified asphalt, as determined by ASTM

distillation test D-244 or (2) allow use of certain grades or applications of emulsified

asphalt with the following maximum solvent contents as determined by ASTM D-244: (a) 3%

limit for seal coats used in early spring or late fall; (b) 3% limit when chip seals used

with aggregate is dusty or dirty; (c) 8% limit when mixing with open graded aggregate

that is not well washed; and (d) 12% limit when mixing with dense graded aggregate. 

Other exemptions are listed for use solely as penetrating prime coat and when stockpiled

for extended periods.
A-34

 CUTBACK ASPHALT 

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Rhode Rhode Island Rhode Island's restrictions Rhode Island has

Island Air Pollution on the use of cutback limit on application

Control Regu- asphalt between May 1 and of cutback asphalt

lation No. 25 October 14 are consistent from May through

with Federal guidance on the October which is

use of cutback asphalt consistent with the

during the ozone season. CTG and other EPA

**

guidance. 
A-35

In addition, the use of These prohibitions

cutback asphalt between are not specified in

October 15 and April 30 is the Federal CTG.

limited to:

a) the use of medium curing

cutback asphalt solely as

a penetrating prime coat,

or

b) manufacture and use of

patching mixtures for

pavement repairs when

long life stockpile

storage is necessary, or

c) medium curing cutback

asphalt is used where

less than 5% of the total

solvent evaporates at up

to temperatures of 500EF.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-36

CUTBACK ASPHALT 

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Cutback asphalt may be used The State regulation

Colorado for any paving purpose is the same as the

Regulation October 1 through February Federal CTG, which

Title 5, 28 (29). No person shall allows some use of

Chapter 1001, use cutback asphalt or any cutback as a

Regulation emulsified asphalt March 1 penetrating prime

No. 7, Part through September 30 except coat.

XI. as provided below:

a. If used solely as a

penetrating prime coat,

or

b. If the user can

demonstrate to the

Division that under the

conditions of its

intended use, there will

be no emissions of VOCs

to the ambient air.
A-37
A-38

FIXED-ROOF PETROLEUM TANKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Emission limits are recommended in terms of equipment specifications. These

specifications include internal floating roofs equipped with a closure seal or seals, or

alternative equivalent control. The CTG, however, does not specify the exact types of

controls acceptable as alternative equivalent. 

The cutoffs for fixed-roof petroleum tanks, as described in the "Blue Book," are as

follows:

(a) < 150,000 liters (40,000 gallons) storage capacity of volatile petroleum liquids

(greater than 10.5 kPa TVP), and 

(b) < 1,600,000 liters (420,000 gallons) storage capacity of crude oil and condensate

prior to lease custody transfer.
A-39

FIXED-ROOF PETROLEUM TANKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air All openings in floating ** There are no

Conservation roof tanks except for specifications in

Regulation, automatic bleeder vents, the Federal CTG

Emission rim space vents, and leg requiring a

Standard sleeves, shall provide a projection below

Regulation, projection below the the liquid surface

R307-1- liquid surface. of any opening.

4.4.9.1

B.(1)(b) 

B.(1)(f) An emergency roof drain ** The State

shall be provided with a requirement

slotted membrane fabric specifies

cover or equivalent cover additional

which covers at least 90% requirements which

of the opening. were in the

Federal CTG.
A-40

 B.(5) The Executive Secretary ** The Federal CTG

must be notified 7 days does not require

prior to the refilling of this notification. 

a tank which has been

emptied, or degassed for

any other similar purpose. 

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-41

FIXED-ROOF PETROLEUM TANKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of A storage vessel must be ** The Federal CTG

Colorado removed from service does not give a

Regulation, within 45 days of an specified

Title 5, inspection if it is not timeframe in which

Chapter 1001, repaired within that leaks must be

Regulation timeframe. repaired. The CTG

No. 7, Part indicates that the

VI. Maintenance or inspection State guideline

records must be kept for 2 should be followed

years. for recordkeeping. 
A-42

I.B.2.a. During a routine ** There are no

(iii)(A)(1) inspection, the operator specifications in

shall measure for the Federal CTG. 

detectable vapor loss This requirement

inside the hatch. has the potential

Detectable vapor loss to reduce emission

means a VOC concentration losses.

exceeding 10,000 ppm,

using a portable

hydrocarbon analyzer.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-43

FIXED-ROOF PETROLEUM TANKS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado VI.B.1 Tanks or other containers * The State rule

(Concluded) used to store the provides more

following liquids are exemptions than

exempt: the Federal CTG. 

1) diesel fuels 1-D, 2-D, Stringency between

and 4-D as defined in ASTM the two cannot be

D975-78; determined since

2) fuel oils #1, #2, #3, the additional

#4, and #5, as defined in exemptions make

ASTM D396-78; and fewer sources

subject to the

3) gas turbine fuels 1-GT standard, rather

through 4-GT as defined in than the rule more

ASTMD 2880-78. stringent.
A-44

Exemption for underground * This exemption is

storage tanks whose annual not specified in

volume total of liquid the Federal CTG. 

removed from the tank plus

the sum of the volume of

liquid added to it does

not exceed twice the

operational volume of the

tank (i.e., a maximum of

one turnover per year is

allowed). Subsurface

caverns or porous rock

reservoirs are also

exempt.

* This is an issue of applicability.

BULK PLANTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG
A-45

The EPA defines a gasoline bulk plant as having a throughput of less than 76,000 liters of

gasoline per day averaged over the work days in one year. A summary of the CTG RACT

requirements is as follows.

- Bulk plant facilities include: 1) tanks for gasoline storage; 2) loading racks; and 3)

incoming and outgoing tank trucks. 

- Three control techniques employed at the bulk plants are submerged loading, vapor

balance system, and leak prevention. 

- Other control alternatives considered are: a) submerged filling, b) submerged filling

account trucks with vapor balancing of transport trucks and storage tanks, and c)

submerged filling account trucks with vapor balancing of storage tanks, account and

transport trucks. 

- A vapor balance system can control vapor emissions during loading and unloading of tank

trucks with an efficiency greater than 90 percent.

- Proper maintenance, proper operation, and good housekeeping are required to prevent

leaks and assure effective collection of VOC emissions when balance systems are

installed.

- To maintain high emission reduction efficiencies, tank trucks, storage tanks, and all

piping must be vapor-tight.

- No specific emission limits for bulk plants are provided. 
A-46

BULK PLANTS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Colorado The State defines a Although the State

Regulation, Title bulk plant as having an requires a shorter

5, Chapter 1001, average daily through- period of time in

Regulation No. 7, put of 76,000 liters of calculating the average

Part VI, Section gasoline (20,000 gal) throughput, this does

C.(3)(a). or less over a period not necessarily signify

of 30 days. that the State

regulation is more

stringent than the

Federal CTG.

C.3.d The owner or operator The Federal CTG lists

of a bulk plant that submerged filling as

serves only storage one of the possible

tanks may use submerged control options.

filling instead of

vapor recovery.
A-47

Texas Texas Adminis- In Harris County, and X The Federal CTG does

trative Code, after January 31, 1994 not specify a maximum

Title 31, Natural in counties other than emission loss of VOC

resources and Harris, the maximum due to product

Conservation, allowed loss of VOC due transfer. Therefore,

Part III, Air to product transfer is the State requirement

Control Board, 1.2 lb VOC/1,000 gal is presumed to result

Chapter 115, (140 mg VOC/l) of gaso- in lower emissions than

Subchapter C. line transferred. following the CTG's

§115.211(a)(2) control technique and

a

operational specifications.

The "X" indicates that the State/local requirement is considered more stringent than a

the specifications in the applicable Federal CTG.

GASOLINE LOADING TERMINALS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Tank truck gasoline loading terminal 80 mg VOC/l (0.67 lb VOC/1,000

gal) of gasoline loaded
A-48

This limit is based on submerged fill and vapor recovery/control systems. a

The "Blue Book" defines a tank truck gasoline loading terminal as any tank truck loading

operations at the primary wholesale outlet for gasoline that delivers at least 76,000

l/day (20,000 gal/day).
A-49

GASOLINE LOADING TERMINALS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-50

Colorado Code of As stated in the CTG with ** These loading

Colorado additional operating procedures are work

Regulation, requirements listed practices and are

Title 5, below. The owner or not specified in the 

Chapter 1001, operator of a gasoline Federal CTG. 

Regulation No. terminal shall equip the Although these

7, terminal with proper requirements enhance

Part VI, loading equipment and the pollution

Section C.2. shall follow the follow- prevention aspects

ing loading procedures: of the rule, they

(a) Install dry-break may not result in

loading couplings to quantifiable

prevent petroleum reductions. The

liquid loss during State emission limit

uncoupling from is the same as the

vehicles. CTG.

(b) Install a vapor

collection and

disposal system that

gathers vapor

transferred from

vehicles being

loaded. The system

shall include

devices to prevent

the release of vapor
A-51

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

GASOLINE LOADING TERMINALS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado (c) Use operating

(Continued) procedures to ensure

that petroleum

liquid cannot be

transferred unless

the vapor collection

equipment is in use.

(d) Provide for the

prevention of

overfilling of

transport vehicles

with loading pump

shutoffs, set stop

meters, or

comparable

equipment.
A-52

(e) Operate all recovery

and disposal

equipment at a

backpressure less

than the pressure

relief valve setting

of transport vehicles.
A-53

GASOLINE LOADING TERMINALS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado (f) Prevent the release

(Continued) of petroleum liquid

on the ground from

transport vehicles. 

Provision shall be

made to remove any

undelivered

petroleum liquid

with closed drainage

devices.
A-54

(g) Maintain and operate

final recovery and

disposal equipment

or devices in the

vapor control system

(i.e., control

devices) so as to

emit no more than 80

milligrams of

volatile organic

compounds per liter

of gasoline being

loaded. Such

disposal devices

shall be approved by

the Division.
A-55

GASOLINE LOADING TERMINALS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado (h) Prevent loading of

(Concluded) petroleum liquid

into transport

vehicles that do not

have valid leaktight certification

as required in

Section VI.D. No

truck shall be

loaded unless a

certification

sticker is

displayed, or a 

certification letter

is carried in the

truck.

(i) Follow all control

procedures to

prevent leaks.
A-56

Utah Utah Air The State emission limit X The State requires a

Conservation is 0.64 lb VOC/1,000 gal slightly lower

Regulation, of gasoline transferred. emission limit than

Emission the CTG and provides

Standard work practices and

Regulation, R- vapor collection

307-1-4.9.2 procedures that are

Section A. not included in the

CTG.
A-57

GASOLINE LOADING TERMINALS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-58

Texas Texas The emission limit for X As of January 31,

Administrative Beaumont/Port Arthur, 1994, the Texas

Code, Title Dallas/Fort Worth, El emission limit for

31, Natural Paso, and Hous- these areas is lower

resources and ton/Galveston areas until than the Federal CTG

Conservation, January 31, 1994 is 80 mg and therefore is

Part III, Air VOC/l (0.67 lb VOC/1,000 more stringent. 

Control Board, gal) of gasoline

Chapter 115, transferred. After

Subchapter C. January 31, 1994, the

115.211 emission limit will be

reduced to 40 mg VOC from

vapor recovery system

vent per liter (0.33 lb

VOC/1,000 gal) of

gasoline transferred. 

However, for Gregg, Nueces, and Victoria

counties, the emission

limit is the same as in

the CTG.
A-59
A-60

MISCELLANEOUS REFINERY SOURCES

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG states that regulations for vacuum producing systems (VPSs) and wastewater

separators (WSs) should be written in terms of equipment specifications, and regulations

for process unit turnarounds (PUTs) should be written in terms of operating procedures. 

It is suggested that non-condensables from VPSs should be piped to an appropriate firebox,

incinerator, or (if spare compressor capability is available) compressing the vapors and

adding them to refinery fuel gas. The hot wells that are associated with contact

condensers can be covered and the vapors incinerated. Reasonable control of VOC emissions

from WS consists of covering the forebays and separator sections.
A-61

Commercially operating wastewater separators include (1) a solid cover with all openings

sealed totally enclosing the compartment liquid contents and (2) a floating pontoon or

double-deck type cover, equipped with closure seals to enclose any space between the

cover's edge and compartment wall. Also, any gauging and sampling device in the

compartment cover can be designed to provide a projection (such as a probe) into the

liquid surface to prevent VOC from escaping. The sampling device can also be equipped

with a cover or lid that is in a closed position at all times except when the device is in

actual use. 

When a process unit is shut down for a turnaround the agency should require that the

vessel be depressurized to vapor recovery, flare, or a firebox. The agency and the

operator should agree on a timetable for compliance. Included in this timeframe should be

dates for ordering, recovery installation, and start-up of necessary equipment. Each

fractioner, reactor, stabilizer, etc. should be addressed. The vapors can either be

added to the fuel gas system, flared, or directly vented to atmosphere. No VOC should be

directly discharged to the atmosphere until the vessel pressure is less than 5 psig. The

refinery operator should keep a record of each PUT listing as a minimum the date the unit

was shut down, the approximate vessel hydrocarbon concentration when the hydrocarbons were

first discharged to the atmosphere, and the approximate total quantity of hydrocarbons

emitted to the atmosphere. These records should be kept for at least 2 years and be made

available to the air pollution control agency inspector during any compliance inspection

of the refinery.
A-62

MISCELLANEOUS REFINERY SOURCES

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of The forebays and sep- ** The Federal CTG only sugColorado arator sections of WSs gests covering of the

Regulation, must have a vapor forebays and separator

Title 5, recovery system con- sections while the State

Chapter sisting of a vapor gath- regulation includes the

1001, ering device capable of option of sending the vaRegulation collecting the VOC va- pors to a control device

No. 7 Part pors discharged and a or as in VIII.A.2.a(i),

VIII vapor disposal device using a solid cover. 

VIII.A.2.a. capable of processing

(iii) such volatile organic

vapors so as to prevent

their emission into the

atmosphere. 

**
A-63

VIII.B.7 Control devices must The Federal CTG does not

meet applicable re- define the test methods

quirements including that are to be utilized

recordkeeping and the for determining compliapplicable EPA Reference ance.

Methods 1-4 and 25 of 40

CFR Part 60 shall be

used to determine the

efficiency of the control devices. The above

stated requirements also

apply to VPSs.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-64

MISCELLANEOUS REFINERY SOURCES

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado VIII.B.2.a. For PUTs, depressur- X The Federal CTG does not

(Concluded) and b., and ization venting of the specify a vapor control

VIII.B.3 process unit or vessel system combustion efto a vapor recovery ficiency for any of the

system, or to a flare or mentioned refinery

firebox must have at sources.

least 90% combustion

efficiency. Also, no

process unit or vessel

can emit VOCs until the

internal pressure is 2.5

psig or less.
A-65

All blowdown systems,

process equipment vents,

and pressure relief

valves shall be vented

to a vapor recovery

system, or to a flare or

firebox which assures at

least 90% combustion

efficiency.
A-66

MISCELLANEOUS REFINERY SOURCES

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air Catalytic cracking Catalytic cracking units

Conservation units. Flue gas pro- are not specifically adRegulation, duced by catalytic dressed in the Federal

Emission cracker catalyst regen- CTG, but are indirectly

Standard eration units shall be referred to when it is

Regulation vented to a waste heat suggested that vapors may

R-307-1- boiler, a process heater be added to the refinery

4.9.3 Sec- firebox, incinerated, or fuel gas system for burntions D and controlled by other ing. 

E methods provided the

design and effectiveness

of such methods are

documented and submitted

to and approved by the

Executive Secretary.
A-67

MISCELLANEOUS REFINERY SOURCES

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah All safety pressure ** This requirement is not

(Concluded) relief valves handling specified in the Federal

organic material shall CTG.

be vented to a flare,

firebox, or vapor 

recovery, or controlled

according to the

stipulations required

under Leaks from Petroleum Refinery Equipment.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects 

of the rule.
A-68

STAGE I VAPOR RECOVERY

RACT EMISSION LIMIT AS DEFINED BY THE CTG
A-69

The CTG suggests several methods to conduct displaced vapors from the underground

tank to the trucks as follows: 1) two-point system, 2) coaxial systems, 3)

manifolded vent lines, and 4) prescribed design criteria. Under design criteria,

several distinctions have been made; they are 1) drop tube specifications, 2) gauge

well, 3) vapor line connections, 4) vapor hose return, 5) type of liquid fill

connection, 6) tank truck inspection, 7) closures and interlocks on underground tank

vapor hose connectors, 8) vapor hose connection to the tank trucks, and 9) vent line

restrictions.

The design criteria were developed to accomplish the following:

(a) assure submerged fill, i.e., discharge liquid below the gasoline surface in

the storage tank;

(b) assure that the vapor return line and connections are of sufficient size and

sufficiently free of restrictions to allow transfer of vapor to the truck

tank and achieve the desired recovery;

(c) assure that there are no significant leaks in the system or in the tank truck

that reduce vacuum in the truck or otherwise inhibit vapor transfer; and 

(d) assure that the vapor return line will be connected during tank filling.

Suitable restrictive orifices or pressure relief valves are required wherever the

systems would otherwise be incapable of achieving 90 percent control or would

otherwise not assure that the vapor return line is connected. Either of the

following restrictive devices is acceptable:

(a) Orifice of 1/2 to 3/4 inch ID.
A-70

STAGE I VAPOR RECOVERY

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-71

Colorado Appendix D The State rule lists test Test

procedures for annual pres- procedures

sure/vacuum testing of include visual

gasoline transport tanks inspection,

(Stage I). A specific equipment

emission limit for Stage I was requirements,

not located in the rule. pressure test

specification,

vacuum test

specification,

and leak

checks of

vapor return

valves. The

Federal CTG

also requires

tank truck

visual

inspection and

leak testing

at least twice

per year.
A-72

STAGE I VAPOR RECOVERY

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-73

Texas Texas The State rule limits appli- X The State

Regulation cability to sources according regulation

V, to location. Those who are provides

Subchapter subject must not transfer, or specific vapor

C 115.221 allow the transfer of, gaso- control

line from any delivery vessel options that

into a stationary storage are only

container located at a motor briefly

vehicle fuel dispensing mentioned in

facility, unless displaced the Federal

vapors from the gasoline CTG. It

storage container are con- requires

trolled by one of the control

following: equipment to

(1) a vapor recovery system meet a certain

that reduces VOC emissions to emission limit

no more than 93 mg/liter (0.8 based on the

lb/1,000 gal) of gasoline feed rate of

transferred; or gasoline. 

This limit is

not specified

in the CTG. 

The CTG

recommends

only equipment

specifica-
A-74
A-75

STAGE I VAPOR RECOVERY

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas (2) a vapor balance system

(Continued) operated and maintained in

accordance with the State

control requirements.

§115.222(4) The vapor return line's cross- The State

sectional area is at least requirement is

one-half of the product drop the same as

line's cross-sectional area. stated in the

Federal CTG.
A-76

§115.222(5) The only atmospheric emission The State

during gasoline transfer into requirements

the storage container is are the same

through a storage container as stated in

vent line equipped with either the Federal

an orifice no greater than CTG.

3/4-inch internal diameter or

a pressure-vacuum relief valve

set to open at a pressure of

no less than 8 ounces per

square inch.
A-77

STAGE I VAPOR RECOVERY

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas §115.222(8) The gauge pressure in the tank ** The State

(Continued) of the fuel delivery truck requires gauge

does not exceed 4.5 kPa (18 settings in

inches of water) and vacuum tank trucks

does not exceed 1.5 kPa (6 that the

inches of water). Federal CTG

 does not in-

 clude. These

 

*

settings are

set for safety

(pressure

relief)

purposes.
A-78

§115.227(1) The State exempts stationary The Federal

and (2) gasoline storage containers CTG does not

with a nominal capacity less list any

than or equal to 1,000 gallons exemptions. 

(3,875 liters); containers The Blue Book,

used exclusively for the however, has

fueling of implements of identified

agriculture; storage tanks cutoff levels

equipped with external float- for Stage I. 

ing roof, internal floating The throughput

roofs,or their equivalent; and cutoff level

stationary storage tanks for the State

located at a facility which is the same as

dispenses less than 120,000 in the Blue

gallons (454,248 liters) of Book. 

gasoline per year.
A-79

STAGE I VAPOR RECOVERY

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas However, the

(Concluded) State storage

tank capacity

cutoff

exemption is

higher than

the CTG. 

Although this

results in

fewer sources

subject to the

rule, this

cannot be used

to determine

stringency. 

This is an

issue of

applicability.
A-80

** This provision of the State's regulation does not reduce emissions, but is

required for safety purposes.

* This is an applicability issue.
A-81

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

1) CONTROL SYSTEMS FOR COLD CLEANING

Control System A

Control Equipment:

1. Cover.

2. Facility for draining cleaned parts.

3. Permanent, conspicuous label, summarizing the operating requirements.

Operating Requirements:

1. Do not dispose of waste solvent or transfer it to another party, such that greater

than 20 percent of the waste (by mass) can evaporate into the atmosphere. Store *

waste solvent only in covered containers.

2. Close parts cleaner (degreaser) cover whenever not handling parts.

3. Drain cleaned parts for at least 15 seconds or until dripping ceases.

Control System B

Control Equipment:
A-82

1. Cover: Same as in System A, except if (a) solvent volatility is greater than 2

kPa (15 mm Hg or 0.3 psi) measured at 38EC (100EF), (b) solvent is agitated, or **

(c) solvent is heated, the cover must be designed so that it can be easily

operated with one hand. (Covers for larger parts cleaners (degreasers) may

require mechanical assistance, by spring loading, counter weighting, or powered

systems.)

2. Drainage facility: Same as in System A, except that if solvent volatility is

greater than about 4.3 kPa (32 mm Hg or 0.6 psi) measured at 38EC (100EF), the

drainage facility must be internal, so that parts are enclosed under the cover

while draining. The drainage facility may be external for applications where an

internal type cannot fit into the cleaning system.
A-83

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

3. Label: Same as in System A.

4. If used, the solvent spray must be a solid, fluid stream (not a fine atomized or

shower type spray) and at a pressure that does not cause excessive splashing.

5. Major control device for highly volatile solvents: If the solvent volatility is 

> 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38EC (100EF), or if solvent is heated

above 50EC (120EF), then one of the following control devices must be used:

a. Freeboard that gives a freeboard ratio > 0.7 ***

 b. Water cover (solvent must be insoluble in and heavier than water)

c. Other systems of equivalent control, such as a refrigerated chiller or carbon

adsorption. 
A-84

Operating Requirements:

Same as in System A.

2) COMPLETE CONTROL SYSTEMS FOR OPEN TOP VAPOR PARTS CLEANERS (DEGREASERS)

Control System A

Control Equipment:

1. Cover that can be opened and closed easily without disturbing the vapor zone.

Operating Requirements: 

1. Keep cover closed at all times except when processing work loads through the parts 

cleaner.

 

*Water and solid waste regulations must also be complied with.

**Generally, solvents consisting primarily of mineral spirits (Stoddard) have volatilities 

 < 2 kPa.

***Freeboard ratio is defined as the freeboard height divided by the width of the parts 

 cleaner.

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)
A-85

2. Minimize solvent carry-out by the following measures:

a. Rack parts to allow full drainage

b. Move parts in and out of the parts cleaner at less than 3.3 m/sec (11 ft/min).

c. Clean the work load in the vapor zone at least 30 sec. or until condensation

ceases.

d. Tip out any pools of solvent on the cleaned parts before removal.

e. Allow parts to dry within the parts cleaner for at least 15 sec. or until

visually dry.

3. Do not clean porous or absorbent materials, such as cloth, leather, wood, or rope.

4. Work loads should not occupy more than half of the parts cleaner's open top area.

5. The vapor level should not drop more than 10 cm (4 in) when the work load enters

the vapor zone.

6. Never spray above the vapor level.

7. Repair solvent leaks immediately, or shut down the parts cleaner.

8. Do not dispose of waste solvent or transfer it to another party such that greater

than 20 percent of the waste (by mass) will evaporate into the atmosphere. Store

waste solvent only in closed containers.

9. Exhaust ventilation should not exceed 20 m /min per m (65 cfm per ft ) of parts 3 2 2

cleaner's open area, unless necessary to meet OSHA requirements. Ventilation fans

should not be used near the parts cleaner's opening.

10. Water should not be visually detectable in solvent exiting the water separator.
A-86

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

Control System B

Control Equipment:

1. Cover (same as in system A).

2. Safety switches

a. Condenser flow switch and thermostat - (shuts off sump heat if condenser

coolant is either not circulating or too warm).

b. Spray safety switch - (shuts off spray pump if the vapor level drops

excessively, about 10 cm (4 in).
A-87

3. Major Control Device:

Either: a. Freeboard ratio greater than or equal to 0.75, and if the parts cleaner's

opening is > 1 m (10 ft ), the cover must be powered; 2 2

b. Refrigerated chiller;

c. Enclosed design (cover or door opens only when the dry part is actually

entering or exiting the parts cleaner);

d. Carbon adsorption system, with ventilation > 15 m /min per m (50 cfm/ft ) of 3 2 2

air/vapor are (when cover is open), and exhausting <25 ppm solvent averaged

over one complete adsorption cycle; or

e. Control system, demonstrated to have control efficiency equivalent to or

better than any of the above.

4. Permanent, conspicuous label, summarizing operating procedures #1 to #6.

Operating Requirements:

Same as in System A.
A-88

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

3) CONTROL SYSTEMS FOR CONVEYORIZED PARTS CLEANERS (DEGREASERS)

Control System A

Control Equipment: None

Operating Requirements:

1. Exhaust ventilation should not exceed 20 m /min per m (65 cfm per ft ) of parts 3 2 2

cleaner's opening, unless necessary to meet OSHA requirements. Work place fans

should not be used near the parts cleaner's opening.

2. Minimize carry-out emissions by:

a. Racking parts for best drainage.

b. Maintaining vertical speed at < 3.3 m/min (11 ft/min).

3. Do not dispose of waste solvent or transfer it to another party such that greater

than 20 percent of the waste (by mass) can evaporate into the atmosphere. Store

waste solvent only in covered containers.

4. Repair solvent leaks immediately, or shut down the parts cleaner.

5. Water should not be visibly detectable in the solvent exiting the water separator.
A-89

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

Control System B

Control Equipment:

1. Major control devices; the parts cleaner must be controlled by either:

a. Refrigerated chiller;

b. Carbon adsorption system, with ventilation > 15 m /min per m (50 cfm/ft ) of 2 2 2

air/vapor area (when down-time covers are open), and exhausting <25 ppm of

solvent by volume averaged over a complete adsorption cycle; or

c. System demonstrated to have control efficiency equivalent to or better than

either of the above.

2. Either a drying tunnel or another means such as rotating (tumbling) basket,

sufficient to prevent cleaned parts from carrying out solvent liquid or vapor.

3. Safety switches

a. Condenser flow switch and thermostat - (shuts off sump heat if coolant is

either not circulating or too warm).

b. Spray safety switch - (shuts off spray pump or conveyor if the vapor level

drops excessively, e.g. > 10 cm (4 in.)).

c. Vapor level control thermostat - (shuts off sump heat when vapor level rises

too high).
A-90

4. Minimized openings: Entrances and exits should silhouette work loads so that the

average clearance (between parts and the edge of the parts cleaner's opening) is

either <10 cm (4 in.) or <10 percent of the width of the opening.

5. Down-time covers: Covers should be provided for closing off the entrance and exit

during shutdown hours.
A-91

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

Operating Requirements: 

1. to 5. Same as for System A.

6. Down-time cover must be placed over entrances and exits of conveyorized parts

cleaners immediately after the conveyor and exhaust are shut down and removed just

before they are started up.
A-92

SOLVENT METAL CLEANING

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Colorado Each control device shall ** The Federal CTG does not

X.A.5 meet the applicable list any additional

requirements of subsec- control device requiretions IX.A.3.a, b, c, e, ments for demonstrating

and IX.A.8.a and b. compliance. 

Those sections specify

test methods and

recordkeeping

requirements.

X.B.1.d Similar to the Federal

Solvent CTG.

Cold

Cleaners

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-93

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-94

Colorado X.C.2 Operating Requirements The State regulation

(Continued) does not include

stipulations in the

Federal CTG for open top

parts cleaners that

restrict the vapor level

from being allowed to

drop more than 10 cm (4

in) when the workload

enters the vapor zone,

and the restriction

regarding disposing of

waste solvent or

transferring it to

another party such that

greater than 20 percent

of waste (by mass) will

not evaporate into the

atmosphere. The State

regulation is considered

less specific than the

CTG.
A-95

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado X.D.2.a. Exhaust flow shall be ** The Federal CTG does not

(Concluded) measured by EPA Reference specify how the exhaust

Methods 1 and 2 of 40 CFR flow for conveyorized

part 60. parts cleaners should be

measured. Providing a

test method will result

in data with a higher

confidence level. By

using the EPA test

method for exhaust flow

determination, the

result will be more

reliable.
A-96

X.D.f A permanent, clearly ** The Federal CTG does not

visible sign shall be mention the requirement

mounted on or next to the to place signs for

parts cleaner. The sign conveyorized parts

shall list the operating cleaners. Following

requirements. proper operating

practices can minimize

solvent loss to the

atmosphere.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-97

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut Title 22a, The State regulation * Sources built after June

Chapter applies to all sources 1, 1990 have additional

174, that were constructed control and work

Section 20 before June 1, 1990. All practices to ensure

subject sources must compliance.

comply with specified

operating requirements. 

If a source became

operational after June 1,

1990, it must comply with

the earlier specified

operating requirements in

addition to several

additional operational

requirements.
A-98

(1)(3)(D) Covers must be closed ** In addition to the

whenever parts are not requirement for covers

being handled in the to be closed when parts

cleaner for 2 minutes or are not being handled in

more, or when the device the cleaner, the State

is not in use. rule specifies a

timeframe of 2 minutes

or more when not in use.

That is not mentioned in

the Federal CTG.

* This is an applicability issue.

** This provision of the State's regulation involves work practices that will result in

quantifiable emission reductions.
A-99

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut (1)(3)(F) If used, supply a Similar to the CTG.

(Continued) cleaning (degreasing)

solvent spray that is a

solid (geometrical) fluid

stream at a pressure that

does not exceed 10 pounds

per square inch as measured at the pump outlet

and perform such spraying

within the confines of

the cold cleaning unit.
A-100

(1)(H) and Minimize the drafts ** This requirement is not

(1)(5)(H) across the top of each specified in the Federal

cold cleaning unit such CTG. However, this

that whenever the cover requirement may have the

is open the unit is not result of reducing

exposed to drafts greater emissions.

than 40 meters per

minute, as measured

between 1 and 2 meters

upwind and at the same

elevation as the tank

lip.

** This provision of the State's regulation involves work practices that will result in

quantifiable emission reductions.
A-101

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut (1)(G) Do not operate the unit ** The Federal CTG does not

(Continued) upon the occurrence of specify restricting the

any visible solvent leak operation of a unit

until such leak is (cold cleaner only) when

repaired. any visible solvent

leaks occur. It only

indicates that leaks are

to be repaired properly

and promptly.

(1)(K),(1)( Maintain a monthly record This requirement is not

4)(K), and of the amount of solvent specified in the Federal

(1)(5)(M) added to each unit and CTG. 

keep such a record for a

minimum of 2 years. 
A-102

(1)(3)(C) Metal cleaning equipment The Federal CTG does not

that uses 1,1,1 discuss these three

trichloroethane, compounds. However,

methylene chloride, or these chlorinated

trichloro-triflouroethane compounds are not

are exempted from this considered

rule. photochemically reactive

by EPA. They are,

therefore, exempt from

the VOC definition.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-103

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut If the open top vapor ** A lip exhaust is not

(Concluded) parts cleaner is equipped specified in the Federal

with a lip exhaust, the CTG. 

required cover shall be

located below the lip

exhaust.

Maine Air Quality The parts cleaner must be This requirement is

Control equipped with a identical to the Federal

Regulation thermostat to shut off CTG. 

Title 38 the sump heat if the

 Chapter condenser coolant is

130 either not circulating or

if the vapor level rises

above the height of

primary condenser.
A-104

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-105

SOLVENT METAL CLEANING

 STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Maine Chapter 130 The vapor parts cleaner This requirement is

(Concluded) (Concluded) shall be equipped with a specified in the Federal

switch that shuts off the CTG.

spray pump if the vapor

level drops more than 10

cm below the lowest

condensing coil. The

operator shall not allow

this drop in vapor level

to occur.

Monthly records of the

amount of solvent added

to each unit must be

maintained and kept for a

period of 2 years.
A-106

SOLVENT METAL CLEANING

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Rhode Title 3, All cold cleaning units X Unlike the Federal CTG,

Island Chapter 10, must have covers, all cold cleaning units

18.3.1 regardless of solvent must have covers

vapor pressure. regardless of solvent

Freeboard ratio is vapor pressure. A

required to be at least recommended freeboard

0.75. Four inches of ratio of at least 0.75

water cover are required. instead of 0.70 is more

stringent than the

conditions in the CTG. 

The State requires a

larger amount of water

cover which provides

some reduction in

emissions.
A-107

18.4.1 Drain cleaned parts for ** The Federal CTG does not

at least 15 seconds or include the statement,

until dripping ceases, "whichever is longer,"

whichever is longer. an important

"additional"

requirement.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

SOLVENT METAL CLEANING

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-108

Rhode 18.3.2 Owners of open top vapor ** Both the Federal CTG and

Island parts cleaners are the State rule require

(Concluded) required to install a the installation of a

refrigerated chiller refrigerated chiller as

having a minimum cooling one of the control

capacity, based on the devices, but the State

size of the cleaner unit. rule is more specific. 

Also, install vapor level The State defines the

safety switches that shut chiller cooling capacity

the unit off if the vapor as based on the size of

rises above the cooling the parts cleaner. This

coils, and a low solvent definition is not found

level safety switch to in the Federal CTG. The

shut off the heating Federal CTG does specify

element if it becomes that a spray safety

exposed to solvent vapor. switch should be

installed, but it does

not specifically state

that a low solvent

safety switch must also

be installed. These

additional requirements

may have an impact on

emission reduction.
A-109

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-110

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime application, flashoff area, and oven 0.23 kg VOC/l of coating (1.9 lb b

VOC/gal of coating) [minus water]

Topcoat application, flashoff area, and oven 0.34 kg VOC/l of coating (2.8 lb

VOC/ gal of coating) [minus water]

Final repair application, flashoff area, and oven 0.58 kg VOC/l of coating (4.8 lb c

VOC/gal of coating) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).

The recommended emission limit is based on use of an electrophoretic system followed by a b

25 percent solids waterborne "surfacer."

The recommended emission limit is based on use of organic-borne enamel with 35 percent c

solids.

The Federal CTG provides another alternative for complying with RACT by the installation

of add-on control devices. Incinerators and carbon adsorbers are the most applicable and

preferred devices to reduce VOC emissions. Incineration systems can achieve over 90

percent reduction efficiency and carbon adsorption systems can achieve over 85 percent.
A-111

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-112

Colorado Code of State emission limits: The State emission

Colorado a) prime application, limits are not more

Regulation, flashoff area, and stringent than the

Title 5, oven: 0.23 kg/l (1.9 Federal CTG for reasons

Chapter 1001, lb/gal) of coating explained under (a)

Regulation No. (minus water and exempt recommended

7, Part IX, solvents); limitations.

Section B.3. b) topcoat application,

flashoff area, and

oven: 0.34 kg/l (2.8

lb/gal) of coating (minus water and exempt

solvents);

c) final repair

application, flashoff

area, and oven: 0.58

kg/l (4.8 lb/gal) of

coating (minus water

and exempt solvents).
A-113

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-114

Colorado Section B.5 For topcoat In addition to the

(Concluded) application, if a emission limits, the

compliant coating is State provides an

not used to meet the alternative method for

emission limit, then: topcoat application in

a. an alternative order to achieve

method shall compliance. The

meet an emis- alternative emission

sion limit of limit given in terms of

15.1 lb mass VOC/gal solids is

VOC/gal solids 4.5 lb/gal of solids

deposited on (see the calculation

the coated procedure in Appendix

part; and F).

b. compliance

shall be

determined on

a daily

weightedaverage basis.
A-115

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey New State emission limits: The State emission

Administrative a) topcoat application, limits are identical to

Code, Title 7, flashoff area, and the emission limits

Chapter 27, oven: 0.34 kg/l (2.8 specified in the CTG.

Bureau of Air lb/gal) of coating (miPollution nus water);

Control, Sub- b) final repair

chapter 16, application, flashoff

7:27- area, and oven: 0.58

16.5(a)(1) kg/l (4.8 lb/gal) of

coating (minus water).
A-116

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey State of New Jersey * The State splits prime

(Continued) divides prime application into two

application into two separate operations

operations: with two different

electrophoretic dip emission limits. The

prime and spray prime. averaged emission limit

The maximum allowable for these two

VOC content per volume operations is the same

of coating (minus as the emission limit

water) for for "prime application"

* electrophoretic dip stated in the Federal

prime: 0.14 kg/l CTG. Therefore, the

(1.2 lb/gal); and State rules are more

* spray prime: 0.34 specific than the

kg/l (2.8 lb/gal). Federal CTG, but not

necessarily more

stringent. 

* Relative stringency cannot be determined.
A-117

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey The State also adds two X The State provides

(Continued) additional operations: additional emission

custom topcoating and limits for coatings

refinishing (basecoat, that are not specified

clear coat, and all in the CTG, so more

others). The emission coating operations will

limit for custom coat- be regulated.

ing is 0.6 kg VOC/l (5

lb/gal) of coating

(minus water). The

maximum allowable VOC

content per volume of

coating (minus water)

for refinishing is: 
A-118

*base coat: 0.75 kg/l

(6.0 lb/gal);

*clear coat: 0.54 kg/l

(4.4 lb/gal); and

*all others: 0.6 kg/l

(5.0 lb/gal).
A-119

 

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27- As of June 15, 1990, * No VOC applicability

(Continued) 16.5(c)(2) and the State provisions threshold is provided

(3) shall not apply to any in the Federal CTG.

individual coating

operation in which the

total surface coating

formulations containing

VOC are applied at

rates not in excess of

0.5 gal per hour and

2.5 gal per day; or for

the purpose of

developing new coatings

or performing research,

such formulations are

applied at rates not in

excess of 2 gal per

hour and 3 gal per day.

* This is an applicability issue.
A-120

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27- If the surface coating ** The State requirements

(Concluded) 16.5(a)(3) operation is served by will result in more

VOC control equipment, accurate compliance

the State requires: performance evaluation

a) the control

equipment to prevent no

less than 90 percent by

mass of the VOC content

in the surface coating

formulation as applied

each hour from being

discharged directly or

indirectly into the

outdoor atmosphere; or

than the CTG.
A-121

b) the operations

result in an hourly VOC

emission rate no

greater than the

maximum allowable

hourly emission rate

calculated on a solids

applied basis.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-122

SURFACE COATING OF CANS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Sheet basecoat and over-varnish; two-piece can 0.34 kg VOC/l of coating (2.8 lb

exterior VOC/gal of coating) [minus water]

Two and three-piece can interior body spray, two- 0.51 kg VOC/l of coating (4.2 lb 

piece can exterior end VOC/gal of coating) [minus water]

Three-piece can side-seam spray 0.66 kg VOC/l of coating (5.5 lb

VOC/gal of coating) [minus water]

End sealing compound 0.44 kg VOC/l of coating (3.7 lb

VOC/gal of coating) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).

For the industries where stack gas treatment is a more feasible option, it may be

appropriate to state emission limits in terms of control efficiency across control devices

such as incinerators or carbon adsorbers. Catalytic and non-catalytic incinerators and

carbon adsorbers are expected to achieve 90% reduction.
A-123

SURFACE COATING OF CANS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-124

Colorado Code of Colo- Can Coating The State emission

rado Regula- - Sheet basecoat: limits are not more

tion, Title 5, 0.34 kg VOC/l (2.8 stringent than the

Chapter 1001, lb VOC/gal) of Federal CTG for

Regulation No. coating (minus reasons explained

7, Part IX, water and exempt under (a) recommended

Section C. solvents). limitations. 

- Two and threepiece can interior

body spray, twopiece can exterior

end (spray or roll

coat): 0.51 kg

VOC/l (4.2 lb

VOC/gal) of

coating (minus

water and exempt

solvents).

- Three-piece can

side- seam spray: 

0.66 kg VOC/1 (5.5

lb VOC/gal) of

coating (minus

water and exempt

solvents).

- End sealing
A-125

SURFACE COATING OF CANS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado In addition to emission X The State rule

(Concluded) limitations as stated specifies an emission

in the CTG, Colorado limit for "any

has an emission limit additional coat." 

for "any additional Therefore, more

(other) coat" [emission coatings may be

limit: 0.51 kg VOC/l of subject to the rule.

coating or 4.2 lb VOC-

/gal of coating (minus

water)].

Maine Air Quality Facilities which demon- * This is a means of

Control strate that only low- encouraging pollution

Regulation VOC coatings are used prevention, but does

Chapter 129. at that facility are not have a direct

allowed to keep impact on stringency.

monthly, rather than

daily, records.

* Although this provision may not result in quantifiable emission reductions, it

encourages pollution prevention.
A-126

SURFACE COATING OF CANS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-127

New Jersey New Jersey Can Coating The emission limits

Administrative - Sheet basecoat and for coating

Code, Title 7, two-piece can application in the

Chapter 27, exterior:0.34 kg State regulation are

Bureau of Air VOC/l (2.8 lb the same as those

Pollution Con- VOC/gal) of stated in the Federal

trol, Subchap- coating (minus CTG. 

ter 16, 7:27- water).

16.5 - Two- and threepiece can interior

body spray, twopiece can exterior

end: 0.51 kg VOC/l

(4.2 lb VOC/gal)

(minus water).

- Side-seam spray:

0.66 kg VOC/l (5.5

lb VOC/gal) of

coating (minus

water).

- End sealing

compound: 0.44 kg

VOC/l (3.7 lb

VOC/gal) of

coating (minus

water).
A-128
A-129

SURFACE COATING OF CANS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-130

New Jersey 7:27-16.5 As of June 15, 1990, * No VOC cutoff point is

(Continued) (c)(2) and the State provisions given in the Federal

(3). shall not apply to any CTG.

individual surface

coating operation in

which the total surface

coating formulations

containing VOC are

applied at rates not in

excess of 0.5 gal per

hour or 2.5 gal per

day; or for the purpose

of developing new

coatings or performing

research, such

formulations are

applied at rates not in

excess of 2 gal per

hour and 3 gal per day.

* This is an applicability issue.
A-131

SURFACE COATING OF CANS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27-16.5 If the surface coating ** The State requirements

(Concluded) (a)(3) operation is served by will evaluate

VOC control equipment, compliance performance

the State requires: more accurately than

a) the control

equipment to prevent

no less than 90% by

mass of the VOC

content in the surface

coating formulation as

applied each hour from

being discharged

directly or indirectly

into the outdoor

atmosphere; or

the CTG.
A-132

b) the operations

result in an hourly

VOC emission rate no

greater than the

maximum allowable

hourly emission rate

calculated on a solids

applied basis.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

 

SURFACE COATING OF FABRICS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Fabric Coating Line 0.35 kg VOC/1 of coating (2.9 lb

 VOC/gal of coating) (minus water)

Vinyl Coating Line 0.45 kg VOC/1 of coating (3.8 lbs

VOC/gal of coating) (minus water)
A-133

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book). These limitations are based on use of

an add-on control system that has an overall control efficiency of 81% 

(90 percent capture/90 percent control).
A-134

SURFACE COATING OF FABRICS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Fabric coating line: 0.35 The emission limit is

Colorado kg VOC/l (2.9 lb VOC/gal) identical to the CTG.

Regulation, of coating.

Title 5,

Chapter 1001,

Regulation No.

7, Part IX,

Section E

Section K Vinyl coating line: 0.45 The emission limit is

kg VOC/l (3.8 lb/gal) of identical to the CTG.

coating.

New Jersey New Jersey Maximum allowable VOC The emission limits

Administrative content per volume of are identical to the

Code, Title 7, coating (minus water) for CTG.

Chapter 27, fabric coating lines: 

Bureau of Air 0.35 kg/l (2.9 lb/gal)

Pollution and for vinyl coating

Control, line: 0.45 kg/l (3.8

Subchapter 16, lb/gal).

27-16.5(a)(1) 
A-135
A-136

SURFACE COATING OF FABRICS

STATE RACT RULES

(Continued) 

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27-16.5 As of June 15, 1990, the * No VOC cutoff point

(Continued) (c)(2) State provisions shall is given in the

 and (3) not apply to any individ- Federal CTG. 

ual surface coating

operation in which the

total surface coating

formulations containing

VOC are applied at rates

not in excess of 0.5 gal

per hour or 2.5 gal per

day; or for the purpose

of developing new

coatings or for the

purpose of performing research, such formulations

are applied at rates not

in excess of 2 gal per

hour and 3 gal per day.

* This is an applicability issue.
A-137

SURFACE COATING OF FABRICS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-138

New Jersey 7:27-16.5 If the surface coating ** The State

(Concluded) (a)(3) operation is served by requirements evaluate

VOC control equipment, compliance

the State requires: performance more

a) the control accurately than the

equipment to prevent Federal CTG and may

no less than 90% by result in more

mass of the VOC emission reductions.

content in the

surface coating

formulation as

applied each hour

from being

discharged directly

or indirectly into

the outdoor

atmosphere; or 

b) the operations

result in an hourly

VOC emission rate no

greater than the

maximum allowable

hourly emission rate

calculated on a

solids applied

basis.
A-139

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-140

SURFACE COATING OF FABRICS

STATE RACT RULES

(Continued) 

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air Fabric coating line: 0.35 The EPA "Blue Book"

Conservation kg VOC/l (2.9 lb VOC/gal) clarifies that exempt

Regulation, of coating, excluding solvents are treated

Emission water and exempt as water in the "lb

Standard solvents. Vinyl coating VOC/gal of coating

Regulation, R- line: 0.45 kg VOC/l (3.8 less water"

307-1-4.9.6 lb/gal) of coating. calculation.

Section C (1)
A-141

Section C (2) The State indicates that The emission limit in

in determining compli- terms of mass VOC per

ance, equivalency mass of solids (noncalculations for coatings volatiles) can be

shall be performed in calculated using the

units of lb VOC/gal of guidelines provided

solids rather than lb in Appendix F.

VOC/gal of coating. The

equivalent emission limit

is 4.8 lb VOC/gal of

solids for fabric coating, and 7.9 lb VOC/gal

of solids for vinyl

coating.
A-142

SURFACE COATING OF FABRICS

STATE RACT RULES

(Continued) 

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Rhode Rhode Island VOC emission limit for: The guidelines

Island Air Pollution a) Fabric coating line: provided in Appendix

Regulation No. 2.9 lb VOC/gal of F to calculate can be

19.3.1 coating (minus used the emission

water) and 4.79 lb limit in terms of

VOC/gal of solids. mass of VOC per unit

b) Vinyl coating line: volume of solids

3.8 lb VOC/gal of (non-volatiles). 

coating (minus

water) and 7.86 lb

VOC/gal of solids.

X

19.3.2 The State requires an The State requires

approved control system higher overall

to have a total emission reduction efficiency

reduction of 85% or than the Federal CTG

greater. (85% vs 81%). 
A-143

SURFACE COATING OF FABRICS

STATE RACT RULES

(Concluded) 

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Maine Air Quality Facilities which demon- * This is a means of

Control strate that only low-VOC encouraging pollution

Regulation coatings are used at that prevention, but does

Chapter 129. facility are allowed to not have a direct

keep monthly, rather than impact on stringency. 

daily, records.

* Although this provision does not necessarily result in quantifiable emission reductions,

it encourages pollution prevention.
A-144

SURFACE COATING OF LARGE APPLIANCES

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime, single, or topcoat application area, flashoff 0.34 kg VOC/1 of coating (2.8 lb

area, and oven VOC/gal of coating) [minus water]

The Federal CTG states that the emission limit is based on use of low organic solvent

coatings containing at least 62 volume percent solids or any other waterborne equivalent. 

An equivalent reduction can also be achieved by use of add-on control devices such as

incinerators or carbon adsorbers which would result in approximately 81% reduction in VOC

emissions over conventional organic-borne coatings which contain about 25 volume percent

solids.

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).
A-145

SURFACE COATING OF LARGE APPLIANCES

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Colorado For prime, single, or The State emission

Regulation, topcoat application limit is the same as

Title 5, Chapter area, flashoff area, the Federal CTG.

1001, Regulation and oven the emission

No. 7, Part IX, limit is 0.34 kg VOC/1

Section F. of coating (2.8 lb

VOC/gal of coating).

Utah Utah Air For prime, single, or The State emission

Conservation topcoat application limit is the same as

Regulation, area, fashoff area, the Federal CTG.

Emission and oven the limit is

Standard 0.34 kg VOC/1 of

Regulation, R- coating (2.8 lb

307-1-1-4.9.6, VOC/gal of coating).

Section E.
A-146

SURFACE COATING OF LARGE APPLIANCES

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey New Jersey As of June 15, 1990, * The Federal CTG does

Administrative the State provisions not provide any

Code, Title 7, shall not apply to any cutoff point.

Chapter 27, individual surface

Bureau of Air coating operation in

Pollution which the total

Control, surface coating formuSubchapter 16, lations containing VOC

7:27-16.5 are applied at rates

not in excess of 0.5

gal per hour or 2.5

gal per day.

* This is an issue of applicability.
A-147

SURFACE COATING OF LARGE APPLIANCES

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey New Jersey The State also re- ** The Federal CTG does

(Concluded) Administrative quires the control not specify this

Code, Title 7, equipment to achieve requirement. The

Chapter 27, no less than 90% by State requirement

Bureau of Air mass of the VOC will result in more

Pollution content in the surface accurate compliance

Control, coating formulation as performance

Subchapter 16, applied each hour from evaluation.

7:27-16.5 being discharged directly or indirectly

into the outdoor

atmosphere; or an

hourly VOC emission

rate no greater than

the maximum allowable

hourly emission rate

calculated on a solids

applied basis.
A-148

 ** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-149

SURFACE COATING OF METAL COILS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime and topcoat or single coat operation 0.31 kg VOC/l of coating (2.6

lb VOC/gal of coating) [minus

water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).

Three control options are specified: thermal incineration, catalytic incineration, and

waterborne & high solids coatings. Thermal incineration is estimated to achieve 90 to 98

percent VOC emission reduction, 90 percent using catalytic incineration, and 70 to 95

percent using product substitution.
A-150

SURFACE COATING OF METAL COILS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Colorado The emission limit for prime The State

Regulation, and topcoat or single coat emission limit is

Title 5, Chapter operation is 0.31 kg VOC/l the same as the

1001, Regulation (2.6 lb VOC/gal) of coating Federal CTG.

No. 7, Part IX, (minus water and exempt

Section D(3). solvents).

New Jersey New Jersey The maximum allowable VOC The State

Administrative content per volume of emission limit is

Code, Title 7, coating for coil coating the same as the

Chapter 27, operations is 0.31 kg/l (2.6 Federal CTG.

Bureau of Air lb/gal) (minus water).

Pollution Control, Subchapter

16, 7:27-16.5

(a)(1)
A-151

SURFACE COATING OF METAL COILS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27-16.5(c)(2) As of June 15, 1990, the * No VOC cutoff

(Continued) and (3) State provisions shall not point is given in

apply to any individual sur- the Federal CTG.

face coating operation in

which the total surface

coating formulations

containing VOC are applied

at rates not in excess of

0.5 gal per hour or 2.5 gal

per day; or for the purpose

of developing new coatings

or performing research, such

formulations are applied at

rates not in excess of 2 gal

per hour and 3 gal per day.

**
A-152

7:27-16.5(a)(3) If the surface coating The Federal CTG

operation is served by VOC does not specify

control equipment, the State this requirement. 

requires: The State

a) the control equipment to requirement will

prevent no less than result in more

accurate compliance performance

evaluation than

the CTG.

* This is an applicability issue.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-153

SURFACE COATING OF METAL COILS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 90% by mass of the VOC

(Concluded) content in the surface

coating formulation as

applied each hour from being

discharged directly or indirectly into the outdoor

atmosphere; or b) the

operations result in an

hourly VOC emission rate no

greater than the maximum allowable hourly emission rate

calculated on a solids 

applied basis. 
A-154

SURFACE COATING OF METAL FURNITURE

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended limitationa

Metal Furniture Coating Line 0.36 kg VOC/l of coating (3 lb

VOC/gal coating) (minus water)

 The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book). This emission limit is based on the use

of low organic solvent coatings.

This emission limit can also be achieved by using waterborne coatings and is

approximately equivalent (on a solids applied basis) to use of an add-on control device

which collects or destroys about 80% of the solvent from a conventional high organic

solvent coating.
A-155

SURFACE COATING OF METAL FURNITURE

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Metal furniture coating 

Colorado line: 0.36 kg VOC/l

Regulation, (3.0 lb VOC/gal) of

Title 5, coating (minus water

Chapter 1001, and exempt solvents).

Regulation No.

7, Part IX,

Section H.

New Jersey New Jersey Maximum allowable VOC

Administrative content per volume of

Code, Title 7, coating (minus water)

Chapter 27, for metal furniture

Bureau of Air coating line is 0.36 kg

Pollution VOC/l (3.0 lb VOC/gal)

control, of coating (minus waSubchapter 16, ter).

7:27-

16.5(a)(1)
A-156

SURFACE COATING OF METAL FURNITURE

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27-16.5- As of June 15, 1990, * No VOC cutoff point

(Continued) (c)(2) and (3) the State provisions is provided in the

shall not apply to any Federal CTG.

individual surface

coating operation in

which the total surface

coating formulations

containing VOC are

applied at rates not in

excess of 0.5 gal per

hour or 2.5 gal per

day; or for the purpose

of developing new

coatings or performing

research, such formulations are applied at

rates not in excess of

2 gal per hour and 3

gal per day.
A-157

* This is an applicability issue.
A-158

SURFACE COATING OF METAL FURNITURE

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-159

New Jersey 7:27-16.5 If the surface coating ** The Federal CTG

(Concluded) (a)(3) operation is served by does not specify

VOC control equipment, that the control

the State requires: efficiency is to be

a) the control met every hour. 

equipment to prevent no The State

less than 90% by mass requirement will

of the VOC content in evaluate more

the surface coating accurately the

formulation as applied compliance

each hour from being performance than

discharged directly or the CTG.

indirectly into the

outdoor atmosphere; or

b) the operations to

result in an hourly VOC

emission rate no greater than the maximum allowable hourly emission

rate calculated on a

solids applied basis.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
A-160

SURFACE COATING OF METAL FURNITURE

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air Metal furniture coating 

Conservation line: 0.3 kg VOC/l (3

Regulation, lb VOC/gal) of coating

Emission (excluding water and

Standard exempt solvents).

Regulation, R307-1-4.9.6,

Section D(1).

Maine Air Quality Facilities which demon- * This is a means of

Control strate that only low- encouraging

Regulation VOC coatings are used pollution

Chapter 129. at that facility are prevention, but

allowed to keep does not have a

monthly, rather than impact on

daily, records. stringency.

* Although this provision may not result in quantifiable emission reductions, it encourages 

pollution prevention.
A-161

SURFACE COATING FOR INSULATION OF MAGNET WIRE

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Wire Coating Oven 0.2 kg VOC/l of coating (1.7 lb

VOC/gal of coating) (minus water)

The Federal CTG states that the recommended emission limit can be met with application of

high solids coatings having greater than 77 volume percent of solids, powder coatings, and

hot melt coatings. The emission limit can also be met with a waterborne coating that contains 29 volume percent solids, 8 volume percent organic solvent, and 63 volume percent

water. The limit can also be met by a conventional coating provided 90 percent emission

reduction by incineration is achieved.

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book).
A-162

SURFACE COATING FOR INSULATION OF MAGNET WIRE

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Colo- Wire coating operation: The State emission

rado Regula- 0.20 kg VOC/l (1.7 limit is identical to

tion, Title 5, lb/gal) of coating the Federal CTG.

Chapter 1001, (minus water and exempt

Regulation No. solvents).

7, Part IX,

Section G(3).

New Jersey New Jersey The maximum allowable The State emission

Administrative VOC content per volume limit is the same as

Code, Title 7, of coating (minus the Federal CTG.

Chapter 27, water) is 0.20 kg/l

Bureau of Air (1.7 lb/gal).

Pollution Control, Subchapter 16,

7:27-16.5

(a)(1)
A-163

 

SURFACE COATING FOR INSULATION OF MAGNET WIRE

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey 7:27-16.5 As of June 15, 1990, * No VOC cutoff point is

(Continued) (c)(2) and (3) the State provisions given in the Federal

shall not apply to any CTG.

individual surface

coating operation in

which the total surface

coating formulations

containing VOC are applied at rates not in

excess of 0.5 gal per

hour or 2.5 gal per

day; or for the purpose

of developing new

coatings or performing

research, such formulations are applied

at rates not in excess

of 2 gal per hour and 3

gal per day.
A-164

* This is an applicability issue.
A-165

 

SURFACE COATING FOR INSULATION OF MAGNET WIRE

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
A-166

New Jersey 7:27- If the surface coating ** The Federal CTG does

(Concluded) 16.5(a)(3) operation is served by not specify this

VOC control equipment, requirement. The

the State requires: State requirement will

a) the control evaluate more

equipment accurately the

to prevent no less than compliance performance

90 percent by mass of than the CTG.

the VOC content in the

surface coating formulation as applied

each hour from being

discharged directly or

indirectly into the

outdoor atmosphere; or

b) the operations to

result in an hourly VOC

emission rate no

greater than the

maximum allowable

hourly emission rate

calculated on a solids

applied basis.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-167

SURFACE COATING FOR INSULATION OF MAGNET WIRE

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air Con- Magnet wire coating: The State emission

servation 0.20 kg VOC/l (1.7 lb limit is identical to

Regulation, VOC/gal) of coating. the CTG.

Emission

Standard 

Regulation, 

R-307-1-4.9.6,

Section F(1)
A-168

Section F(2) The State rule requires The emission limit in

equivalent calculations terms of mass VOC/mass

for coatings to be per- solids (non-volatiles)

formed in units of was calculated using

pounds VOC per gallon the procedure given in

of solids rather than Appendix F.

pounds VOC per gallon

of coating when determining compliance. The

calculated emission

limit is 2.2 lb VOC per

gallon of solids.

 
A-169

SURFACE COATING OF PAPER

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Coating Line 0.35 kg VOC/l of coating (2.9 lb

VOC/gal of coating) (minus water)

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book).

This limit can be achieved in all cases using incinerators and in many cases with coatings

that contain low fractions of organic solvents. The estimated emission reduction using

incinerators is 95 percent, and 80 to 99 percent using low solvent coatings.
A-170

SURFACE COATING OF PAPER

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Code of Colo- Coating line emission limit The emission limit

rado is 0.35 kg VOC/l (2.9 lb is the same as

Regulation, VOC/gal) of coating (less stated in the

Title 5, water and exempt solvents) Federal CTG.

Chapter 1001,

Regulation

No. 7, Part

IX, Section

I.

New Jersey New Jersey The maximum allowable VOC The emission limit

Adminis- content per volume of is identical to the

trative Code, coating (minus water) for a limit stated in the

Title 7, paper coating line is 0.35 Federal CTG.

Chapter 27, kg/l (2.9 lb/gal).

Subchapter

16, 7:27-

16.5.a.1.
A-171

SURFACE COATING OF PAPER

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL REQUIREMENTS MORE COMMENTS

NUMBER STRINGENT?

New Jersey a.4.(c)2 As of June 15, 1990, the * No VOC cutoff point

(Continued) State provisions shall not is provided in the

apply to any individual Federal CTG.

surface coating operation

in which the total surface

coating formulations

containing VOC are applied

at rates not in excess of

0.5 gal per hour or 2 and

0.5 gal per day; or for the

purpose of developing new

coatings or performing

research, such formulations

are applied at rates not in

excess of 2 gal per hour

and 3 gal per day.
A-172

7:27- If the surface coating

16.5(a)3i operation is controlled by

VOC control equipment, the

State requires: 

(i) the control equipment 

* This is an issue of applicability.
A-173

SURFACE COATING OF PAPER

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey Achieve no less than 90% by ** The Federal CTG does

(Concluded) mass of the VOC content in not require the

the surface coating efficiency of 

formulation as applied each control equipment to

hour from being discharged be met on an hourly

directly or indirectly into basis. The State

the outdoor atmosphere; or requirement will

(ii) an hourly VOC emission result in more

rate no greater than the accurate compliance

maximum allowable hourly performance 

emission rate calculated on evaluation than the

a solids applied basis. CTG.
A-174

Utah Utah Air VOC emission limit is 0.35

Conservation kg/l (2.9 lb/gal) of

Regulation, coating applied. The

Emission equivalent emission limit

Standard is 4.8 lb VOC/gal of

Regulation, solids.

R-307-1-

4.9.6, Section B.1 and

2.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
A-175

 

SURFACE COATING OF PAPER

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Section B.2 The State indicates that The Federal CTG

(Concluded) the emission limit can be states that add-on

achieved by (a) application control devices can

of low solvent coating; or achieve over 90%

(b) incineration, provided reduction.

that a minimum of 90%

reduction of nonmethane VOC

which enter the incinerator

is achieved.

Rhode Rhode Island Coating line emission limit The emission limit

Island Air Pollution of 0.35 kg VOC/l of coating in terms of mass VOC

Control (2.9 lb VOC/gal (minus per volume of solids

Regulation water) and 4.79 lb VOC/gal was calculated using

No. 19.3.1 of solids. the guidelines

provided in Appendix

F.
A-176

SURFACE COATING OF PAPER

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Rhode State rule applies to all * Federal CTG applies

Island paper coating lines. to lines with 15

(Concluded) lb/day actual

emissions or

theoretical

emissions of at

least 10 tpy.

Maine Air Quality The owner/operator of a The equivalent

Control paper coating line subject emission limit on a

Regulation to this regulation which is pounds VOC per

Chapter 123 controlled by an add-on volume solids basis

control device at all times is calculated using

the paper coating line is the guidelines

operating must reduce the provided in Appendix

VOC emissions to a rate F. 

equal to 4.8 lb VOC/gal of

solids applied to the

substrate on a continuous

basis.
 This appendix describes Federal RACT for source categories covered in the Group II 1

CTGs, as well as regulatory requirements for the same categories as contained in selected

State/local VOC rules.

Facilities which demon- ** This is a means of

strate that only low-VOC encouraging polcoatings are used at that lution prevention,

facility are allowed to but does not have a

keep monthly, rather than direct impact on

daily, records. stringency.

* This is an issue of applicability.

** Although this provision may not result in quantifiable emission reductions, it

enhances the pollution prevention aspects of the rule.

APPENDIX B.

COMPARISON OF STATE/LOCAL VOC RULES TO FEDERAL RACT 

FOR GROUP II CTG CATEGORIES1
B-2

EXTERNAL FLOATING ROOF PETROLEUM TANKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG
B-3

This category is defined as external floating roof tanks (EFRTs) larger than 150,000

liters (40,000 gal) storing petroleum liquids with a true vapor pressure (TVP) greater

than 10.5 kPa (1.5 psi). 

A continuous (rim mounted) secondary seal or equivalent closure must be installed on all

affected storage tanks, plus certain inspection and recordkeeping requirements, if the

tank is:

a) a welded EFRT, equipped with a primary metallic shoe or liquid-mounted seal, or any

other closure device that can be demonstrated equivalent to the above primary

seals, and the TVP of the stored liquid is 27.6 kPa (4 psi) or greater;

b) a riveted EFRT, equipped with a primary metallic shoe or liquid-mounted seal, or

any other closure device that can be demonstrated equivalent to the above primary

seals, and the TVP of the stored liquid is 10.5 kPa (1.5 psi) or greater; or

c) a welded or riveted EFRT, equipped with primary vapor-mounted seal, or any other

closure device that can be demonstrated equivalent to the above primary seals, and

the TVP of the stored liquid is 10.5 kPa (1.5 psi) or greater.

When such primary closure device can be demonstrated equivalent to the primary seals

described above, the seal closure devices must meet the following requirements:

a) there shall be no visible holes, tears, or other openings in the seal(s) or seal

fabric;

b) the seal(s) must be intact and uniformly in place around the circumference of the

floating roof between the floating roof and the tank wall; and
B-4

EXTERNAL FLOATING ROOF PETROLEUM TANKS 

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

Exemptions: 

1) EFRTs with storage capacities less than 1,600,000 liters (420,000 gallons) used to

store produced crude oil and condensate prior to custody transfer;

2) fixed-roof tanks with or without internal floating roofs, or small production tanks;

3) welded tanks with a primary metallic-type shoe seal and a secondary seal from the top

of the shoe seal to the tank wall;

4) external floating roof tanks storing waxy, heavy pour crudes;

5) petroleum liquid storage vessels:

a) containing petroleum liquid with a TVP less than 10.5 kPa (1.5 psia), and

b) containing petroleum liquid with a TVP less than 27.6 kPa (4.0 psia) that are of

welded construction and presently possess a metallic-type shoe seal, a liquidmounted or liquid-filled type seal, or other approved closure device of

demonstrated equivalence; and

6) horizontal underground storage tanks storing JP-4 jet fuel. 
B-5

 EXTERNAL FLOATING ROOF PETROLEUM TANKS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT? 

Color Code of Exemptions: * The State sets a

ado Colorado EFRTs that store any lower vapor pressure

Regulation, material whose true vapor limit for storage

Title 5, pressure as stored never tanks than the

Regulation exceeds 1.3 psia. Federal CTG. 

No. 7, Part Therefore, more tanks

VI. are subject to the

State rule.
B-6

Utah Utah Air For vapor-mounted primary The State gap space

Conservation seals, the accumulated area limit of 1.27 cm (0.5

Regulation, of gaps between the in) exceeds the

Emission secondary seal and the tank Federal CTG gap space

Standard wall shall not exceed 21.2 limit of 0.32 cm (1/8

Regulation, cm per meter of tank inch), so the Federal

R307-1- diameter (1.0 inch per ft. CTG specification is

4.9.1.C of tank diameter) and the more stringent than

(2)(c). width of any gap shall not the State rule. All

2

2

exceed 1.27 cm (0.5 inch). other State

requirements mirror

the recommendations

in the CTG.

* This is an issue of applicability.
B-7

LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

During loading or unloading operations at service stations, bulk plants, and bulk

terminals, there shall be no reading greater than or equal to 100% of the lower

explosive limit (LEL) at 2.5 centimeters around the perimeter of a potential leak source

as detected by a combustible gas detector. There shall be no avoidable visible liquid

leaks. The vapor collection and vapor processing equipment shall be designed and

operated to prevent the gauge pressure in the tank truck from exceeding 4,500 Pascals

(18 inches of water) and to prevent vacuum from exceeding 1,500 Pascals (6 inches of

water). Vapor collection systems should be monitored by regulatory agencies as needed. 

Bulk terminal, bulk plant, and service station owners or operators must keep records for

2 years indicating the last time the vapor collection system passed a leakage test and

identifying points at which VOC leakage exceeded 100% of the LEL. 

Gasoline tank trucks and their vapor collection systems shall not sustain a pressure

change of more than 750 Pascals (3 inches of water) in 5 minutes when pressurized to

4,500 Pascals (18 inches of water) or evacuated to 1,500 Pascals (6 inches of water). 

There shall be no avoidable visible liquid leaks. Trucks shall be certified leak tight

annually, and shall have a sticker displayed on each tank indicating the identification

number of the tank and the date the tank last passed the pressure/vacuum test. Tank

trucks should be monitored by regulatory agencies as needed. Trucks with leaks greater

than or equal to 100% of the LEL are to be repaired within 15 days and must take and

pass a pressure/vacuum test as described in the CTG. 
B-8

LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colo- Code of The operator shall, within 15 The Federal CTG specifies

rado Colorado days, repair and retest a the same timeframe for

Regulations, vapor collection or control repairing leaking

Title 5 - system that exceeds the equipment.

Chapter 1001 pressure limits.

-

Regulation

No. 7 - Part

XV.
B-9

Tank trucks are specifically ** The Federal CTG does not

required to be vapor-tight specify a periodic visual

and to have valid leak-tight inspection of the tank

certification. The visual truck equipment.

inspection procedure must be

conducted at least once every

6 months. [The specified

procedure involves inspection

of domes, dome vents, cargo

tank, piping, hose

connections, hoses and

delivery elbows for wear,

damage, or misadjustment that

could be a potential leak

source.]

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-10

LEAKS FROM GASOLINE TANK TRUCKS AND VAPOR COLLECTION SYSTEMS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas Texas Vapor recovery systems . . . The Federal CTG

Administra- must be designed and operated specifications are the

tive [such that] no VOC leaks . . same as the State

Code, Title . shall be allowed from any requirements.

31, potential leak source when

Subchapter measured with a portable

C, combustible gas detector. 

§115.212 [VOC leak is defined as

10,000 ppmv.]
B-11

GRAPHIC ARTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG
B-12

The Federal CTG RACT specifications are applicable to packaging rotogravure, publication

rotogravure, and flexographic printing. The CTG does not address letterpress printing or

offset lithography. The recommendations apply to any packaging rotogravure, publication

rotogravure, or flexographic printing facility whose maximum theoretical emissions of VOC

(including solvents used to clean each printing press) without control devices from all

printing presses are greater than or equal to 90.7 Megagrams (100 tons) per year with design

capacity and 8,760 operating hours or maximum production (this cutoff is stated in the EPA

"Blue Book"). The Federal CTG does not specify an emission limit for this category. RACT is

defined in terms of emission reduction efficiencies by application of control technology. 

The specifications stated in the Federal CTG are as follows:

1. RACT requires installation of the best practicable capture systems to assure that VOC is

directed to the control device.

2. Publication rotogravure operations controlled by carbon adsorption systems can achieve

an overall reduction efficiency of 75 percent.

3. Packaging rotogravure printing operations controlled by incineration systems can achieve

an overall reduction efficiency of 65 percent.

4. Flexographic printing operations controlled by incineration systems can achieve an

overall reduction efficiency of 60 percent.

5. Waterborne inks achieving 70 percent overall VOC reduction is equivalent to the exhaust

treatment systems described above.

6. A waterborne ink whose volatile portion consists of 75 volume percent water and 25

volume percent organic solvent (or a lower VOC content) is considered equivalent to the

exhaust treatment systems.
B-13

GRAPHIC ARTS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Colorado Flexographic and packaging The State

Department of rotogravure printing emission limit

Health, Air facilities shall limit is the same as

Quality emissions to 0.5 kg VOC/kg the one stated

Control (0.5 lb VOC/lb) solids in in the Federal

Commission, the inks. CTG.

Title 5,

Chapter 1001,

Part XIII

(B)(1)(e)
B-14

(B)(1)(b) The owner or operator of a If the

facility subject to this Colorado

section and employing VOC regulation

containing ink shall not excludes water

cause, allow, or permit the in determining

operation of the facility compliance

unless the ink (minus with the

water) as it is applied to emission

the substrate, contains 60 limit, they

volume percent or more non- allow a higher

volatile (solid) material. percentage of 

solvent

material and

still meet the

emission limit

exemption.
B-15

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut Regulation of The State regulation * Connecticut

Connecticut applies to any packaging has a lower

State rotogravure, publication threshold

Agencies, rotogravure, or requirement

Title 22a, flexographic printing (as an ozone

Environmental facility whose maximum control

Protection theoretical VOC emissions strategy) than

Chapter 174, (including solvents used the Federal

Section 22a- to clean each printing CTG and

174- press) from all printing therefore its

20(v)(2)(A) presses are greater than rule may apply

or equal to 50 tons per to more

year (25 tpy for sources facilities.

in one section of the

State).

* This is an applicability issue.
B-16

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-17

Connecticut 20(v)(2)(A) The owner or operator of a The State

(Continued) packaging rotogravure, requirements

20(v)(2)(B) (B) Each ink as it is

publication rotogravure, or are identical

flexographic printing to the Federal

facility subject to the CTG.

regulation and employing

solvent-containing ink

shall not cause or permit

the discharge into the

atmosphere of any VOC

unless:

(A) The volatile fraction

of each ink, as it is

applied to the

substrate, contains 25

percent by volume or

less VOC and 75

percent by volume or

more of water and any

exempt VOC; or

applied to the Same as

substrate, less water Federal CTG.
B-18

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-19

Connecticut and exempt compounds,

(Continued) contains 60 volume percent

20(v)(2)(C) (C) The owner or operator ** The CTG does

or more nonvolatile

material (solids); or

installs and operates: not specify

 (i) A carbon adsorption that the

system which reduces efficiency of

volatile organic control

emissions from the equipment be

capture system by at verified on an

least 90% by mass over hourly basis

the adsorption cycle, or every

or 24 hours, whichever adsorption

is shorter; or cycle. The

(ii) An incineration system State

provided that 90% of requirements

the nonmethane will result in

volatile organic more accurate

compounds (measured as compliance

total combustible performance

carbon) which enter evaluation

the incinerator per than the CTG. 

hour are oxidized to

carbon dioxide and

water; or,
B-20

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
B-21

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut 20(v)(2)(C) (iii) A system

(Concluded) demonstrated to

have control

efficiency

equivalent to or

greater than the

above required 90%

and approved by the

Commissioner by

permit or order.
B-22

Maine Department of The State regulation * Maine has a

Environmental applies to any packaging lower

Protection, rotogravure, publication threshold

Bureau of Air rotogravure, or requirement

Quality flexographic printing (as an ozone

Control, Air facility whose maximum control

Quality theoretical VOC emissions strategy) than

Control (including solvents used to the Federal

Regulation, clean each printing press) CTG and

Chapter 132 from all printing presses therefore its

(1) are greater than or equal rule may apply

to 50 tons per year. to more

facilities. 

* This is an issue of applicability.
B-23

GRAPHIC ARTS

STATE RACT RULES

(Continued) 

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Maine Facilities which demostrate * This is a

(Concluded) that only low-VOC inks are means of

used at that facility are encouraging

allowed to keep monthly, pollution

rather than daily, records. prevention,

and does not

have a direct

impact on

stringency.
B-24

New Jersey New Jersey As of June 15, 1990, the * The Federal

Administrative State provisions shall not CTG does not

Code, Title 7, apply to any individual set any VOC

Chapter 27 coating operation in which cutoff point.

Bureau of Air the total surface coating

Pollution formulations containing VOC

Control, are applied at rates not in

Subchapter 16, excess of 0.5 gal per hour

7:27-16.5 f(c) and 2.5 gal per day; or for

(2) and (3) the purpose of developing

new coatings or performing

research, such formulations

are applied at rates not in

excess of 2 gal per hour

and 3 gal per day.

* This is an issue of applicability. (The EPA "Blue Book" specifies daily

recordkeeping.)
B-25

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-26

New Jersey 7:27-16.5 The State requires that for X The "Blue

(Concluded) (a)(1) formulations that do not Book" provides

Table 3D contain water, the maximum an alternative

allowable VOC content per emission limit

volume of formulation in terms of

(minus water) is 0.35 g/l mass of VOC

(2.9 lb/gal). per mass of

a

solids. The

State emission 

limit was

converted to

these units

using the

procedure

specified in

Appendix F. 

The calculated

limit is 0.3

lb VOC/lb

solids, and is

lower than the

emission limit

specified in

the Blue Book
B-27

a The "X" indicates that the State/local requirement is considered more stringent

than the specification in the applicable Federal CTG.
B-28

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-29

New York Title 6, Any packaging rotogravure, The State

Chapter III- publication rotogravure, regulation

Air Resources, flexographic, offset applies to a

Subchapter A- lithographic process, or larger

Prevention and screen printing process at population of

Control of Air any facility located in the printers than

Contamination New York City metropolitan the CTG, and

and Pollution, area, regardless of its it also

Part 234.1.b.4 potential to emit VOC and applies to

which was constructed after offset

September 1, 1988, must lithographic

have demonstrated and screen

compliance with this part printing

upon startup. facilities. 

The State rule

also contains

a lower

applicability

cutoff than

the Federal

CTG. 
B-30

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-31

New York Part Each owner or operator of a * The Federal

(Continued) 234.1.c.3 packaging rotogravure, CTG applies to

publication rotogravure, facilities

flexographic, or offset that have the

lithographic printing potential to

process, or screen printing emit 100 tons

process at any facility or more per

located in the Lower Orange year. 

County metropolitan area, Therefore, the

for which the annual State

potential to emit VOC from regulation may

all sources regardless of apply to more

process type, but excluding facilities.

combustion installations,

is equal to or exceeds 25

tons, must submit a

compliance plan to the

Department of Environmental

Conservation by November

15, 1993. 

* This is an applicability issue.
B-32

GRAPHIC ARTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-33

New York Part 234.1.c.4 Each owner or operator of a * The Federal

(Concluded) packaging rotogravure, CTG

publication rotogravure, requirement

flexographic, offset applies to

lithographic printing facilities

process, or screen printing that have the

process at any facility potential to

located outside the New emit 100

York City and Lower Orange tons/yr or

County metropolitan areas more. 

and for which the annual Therefore, the

potential to emit VOC from State

all sources regardless of regulation may

process type, but excluding apply to more

combustion installations, facilities. 

is equal to or exceeds 50

tons, must submit a

compliance plan by November

15, 1993. The plan is to

contain a schedule of the

steps necessary to achieve

compliance or to limit 

annual potential to emit

below the applicability
B-34

* This is an applicability issue.
B-35

GRAPHIC ARTS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah Air The State regulation for * The Federal

Conservation this section also applies CTG does not

Regulation, to specialty printing apply to

Emission operations. The State also specialty

Standard indicates that machines printing and,

Regulation, R- which have both "coating" therefore, is

307-1-4.9.6, units (application of a less inclusive

Section I uniform layer of material than the State

across the entire width of regulation.

a web) and "printing" units

(formation of words,

designs, and pictures)

shall be considered as

performing a printing

operation. 

* This requirement affects the applicability of the rule.
LEAKS FROM PETROLEUM REFINERY EQUIPMENT 

 RACT EMISSION LIMIT AS DEFINED BY THE CTG

The owner or operator of a petroleum refinery complex shall develop and conduct a VOC

monitoring program as defined in the CTG appendix. The recommended monitoring intervals

are: annual (pump seals, pipeline valves in liquid service, and process drains);

quarterly (compressor seals, pipeline valves in gas service, and pressure relief valves

in gas service); weekly (visual inspection of pump seals), and no individual monitoring

(pipeline flanges and other connections, and pressure relief valves in liquid service).

Whenever a liquid leak from a pump seal is observed during visual inspection or when a

relief valve vents to the atmosphere, the operator must immediately monitor the VOC

concentration of that component. If a leak (greater than 10,000 ppm) is detected, the

leak should be repaired within 15 days. The refinery operator should report quarterly

leaks that cannot be repaired in 15 days, and arrange for repairs to be made during the

next scheduled turnaround or, if unable to bring a component into compliance, apply for

a variance on an individual basis.

Three types of monitoring are mentioned; they include individual source monitoring, unit

walk-through monitoring, and multiple fixed-point monitoring. The CTG details only

individual source monitoring.
B-37

LEAKS FROM PETROLEUM REFINERY EQUIPMENT 

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Utah The owner or operator of ** The requirement to

Conservation a petroleum refinery develop and conduct a

Regulation, complex shall develop monitoring program is

Emission and conduct a VOC exactly the same as the

Standard monitoring program. Federal CTG

Regulation, This program must be specification. However,

R-307-1- submitted 30 days prior the State has added a

4.9.3.F(1) to startup of the timeframe in which this

complex or as determined plan must be submitted. 

necessary.

**

4.9.3.F(3)(d) The refinery owner or The CTG specifies the

operator must monitor same monitoring in order

within 24 hours (with a to determine the

portable VOC detection concentration of a leak. 

device) or repair within However, the Federal CTG

15 days any pump seal does not require 

from which liquids are monitoring within 24

observed dripping. hours.
B-38

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-39

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-40

Utah 4.9.3.F(3) Specifies that any ** There are no specific

(Continued) (g) relief valve that is "unsafe to monitor"

vented to the atmosphere provisions in the

must be monitored within Federal CTG or the EPA

24 hours. "Unsafe to "Blue Book." However,

monitor" valves must be the "Blue Book"

monitored when recommends consistency

conditions allow them to with the SOCMI leak CTG

be monitored safely guidance. The State

(e.g., at unit requirement is the same

turnaround). as the one recommended

For all other valves in the SOCMI guidance.

considered inaccessible

during an annual

inspection, the

owner/operator shall

document to the

Executive Secretary the

number of valves

considered inaccessible,

the reasons for

inaccessibility, and the

location of the valves. 
B-41

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-42

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah This documentation shall ** The timeframe is an

(Continued) be submitted for app- additional requirement.

roval to the Executive

Secretary 15 days after

the last day of each

calendar year.

*
B-43

4.9.3.F(4) The State rule exempts The Federal CTG does not

the following from the provide any exemptions.

monitoring requirement: 

- Pressure relief

devices connected to

an operating flare

header, firebox, or

vapor recovery

device, storage tank

valves, and valves

that are not

externally regulated;

- Refinery components

containing a stream

composition less than

10% by mass VOC; and

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

* This is an applicability issue.
B-44

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah 4.9.3.F(4) - Refinery equipment

(Concluded) (Concluded) containing natural

gas supplied by a

public utility as

defined by the Utah

Public Service

Commission.

Colorado Colorado The State requires These requirements are

Regulation annual monitoring recommended by the CTG.

Title 5, inspections for heatChapter 1001, exchanger body flanges

Regulation and other accessible

No. 7, Part flanges in VOC service.

VIII C.4.A
B-45

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado C.4.D The owner or operator of ** The CTG states that

(Concluded) a petroleum refinery whenever a liquid leak

subject to this is observed during

regulation shall monitor visual inspection, the

using a VOC detector operator must

within 24 hours and make immediately monitor the

a record of any VOC concentration of

component from which VOC that component. The

liquids are observed term "immediately" is

leaking. not defined. The State

regulation provides a

more specific timeframe.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-46

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Coating Category Recommended Limitationa

Air or forced air dried items 0.42 kg VOC/l of coating (3.5 lb/gal)

 [minus water]

Clear Coat 0.52 kg VOC/l of coating (4.3 lb/gal)

[minus water]

No or infrequent color change or small number of

colors applied

1. Powder Coatings 0.05 kg VOC/l of coating (0.4 lb/gal)

2. Other 0.36 kg VOC/l of coating (3.0 lb/gal)

[minus water]

[minus water]

Outdoor, harsh exposure, or extreme performance 0.42 kg VOC/l of coating (3.5 lb/gal)

characteristics [minus water]

Frequent color changes, large number of colors ap- 0.36 kg VOC/l of coating (3.0 lb/gal)

plied, or first coat on untreated ferrous sub- [minus water]

strate

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book). 
B-47

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah Air Air or forced air The limits given here are

conservation dried items: 0.42 kg assumed to apply for

Regulation, VOC/l coating (3.5 coatings that contain only 

Emission lb/gal) VOCs and nonvolatiles

Standards (solids).

Regulation R307-1-4.9.H(b)

307-1-4.9.H(a) Clear coat coatings: 

0.52 kg VOC/l coating

(4.3 lb/gal)

307-1-4.9.H(c) Outdoor, harsh The units given here are

exposure, or extreme assumed to apply for

performance coatings that contain only

characteristic VOCs and nonvolatiles

coatings: 0.42 kg (solids).

VOC/l coating (3.5

lb/gal)
B-48

307-1-4.9.H(d) Frequent color

changes, large number

of colors applied, or

first coat on untreated ferrous

substrate: 0.36 kg

VOC/l coating (3.0

lb/gal) 
B-49

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah 307-1- Any incineration sys- The State requirement is

(Concluded) 4.9.H(5)(b) tem used to control similar to that specified

VOC emissions from in the CTG.

this process must

oxidize a minimum of

90% of the nonmethane

VOCs to carbon

dioxide and water.
B-50

Colorado Code of The State emission * This State requirement is

Colorado limits are exactly an issue of applicability.

Regulation, the same as the The Federal CTG does not

Title 5, Federal CTG. The exclude high performance

Chapter 1001, State provides coatings while the State

Regulation No. exemptions for high requirements do. Thus, the

7, Part IX, performance coatings Federal CTG may apply to

Section L. on a case-by-case more sources.

basis, and full exterior repainting of

automobiles and

light-duty trucks if

fewer than 18 vehicles are painted per

day.

* This is an issue of applicability.

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-51

Maine Maine Facilities which * This recordkeeping

Department of demonstrate that only requirement has been

Environmental low-VOC coatings are adopted as a means of

Protection, used at that facility encouraging pollution

Bureau of Air are allowed to keep prevention.

Quality Con- monthly, rather than

trol daily, records.

Regulation

Chapter 129.

New Jersey New Jersey Clear coating is 0.52 The State emission limits

Administrative kg VOC/l (4.3 lb/gal) expressed as mass of

Code, Title 7, VOC/volume of coating as

Chapter 27 Air dried coating is applied (minus water) is

Bureau of Air 0.42 kg VOC/l (3.5 exactly the same as the

Pollution lb/gal) Federal CTG, for clear

Control, coatings, air dried, exSubchapter 16, Extreme performance treme performance coatings,

7:27-16.5. coating is 0.42 kg and other coatings. The

VOC/l (3.5 lb/gal) State rule does not give a

All other coating is listed under color change

0.36 kg VOC/l (3.0 coatings.

lb/gal)

limit for "other coatings"

* Although this provision may not result in quantifiable emission reductions, it

encourages pollution prevention.
B-52

PNEUMATIC RUBBER TIRE MANUFACTURING 

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG addresses four major operations (undertread cementing, tread-end cementing, bead

preparation, and green tire spraying) within the tire manufacturing process. The following

is a summary of control technology used in the four operations.

Affected Control System Expected Control 

Unit Capture Efficiency(%) Efficiency (%)

Undertread Carbon 65 - 85 95

cementing

adsorption 65 - 85 90

Incineratio

n

Tread-end Carbon 65 - 85 95

cementing

adsorption 65 - 85 90

Incineratio

n
PNEUMATIC RUBBER TIRE MANUFACTURING 

RACT EMISSION LIMIT AS DEFINED BY THE CTG (Continued)

B-53

Bead dipping Carbon 75 - 85 95

adsorption 75 - 85 90

Incineratio

n

Green tire Water-based NA NA

spraying coating

Carbon 80 - 90 95

adsorption 80 - 90 90

Incineratio

n

Exemptions:

Production of specialty tires for "antique or other vehicles" when produced on an irregular

basis or with short production runs, only if these tires are produced on equipment separate

from normal production lines for passenger type tires. (This exemption is not specified in

the CTG, but is stated in the EPA "Blue Book.")
B-54

PNEUMATIC RUBBER TIRE MANUFACTURING

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Colorado Same as above. The State adopted the

Department of CTG recommendations.

Health, Air

Quality Control

Commission,

Regulation No.

7, Section IX

(N).
B-55

Connecticut Regulation of The owner or operator X The high control and

Connecticut of any undertread capture efficiencies

State Agen- cementing, tread-end stated in the Federal

cies, Title cementing, or bead CTG are the minimum

22a, Chapter dipping operation efficiencies required

174, Section shall install and by the State. 

22a-174-20 operate a capture Therefore, the State

(u)(2)(A). system, designed to regulation is

achieve maximum considered more

reasonable capture of stringent than the CTG.

at least 85% by mass

of VOC.
B-56

PNEUMATIC RUBBER TIRE MANUFACTURING

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut 22a-174- The State requires (i) ** The CTG specifies a

(Concluded) 20(u)(B)(i) a carbon adsorption higher reduction

and (ii). system to achieve 90% efficiency of an

VOC removal by mass adsorption system than

for each adsorption the State. However, it

cycle or 24 hours, does not specify the

whichever is shorter; timeframe.

or (ii) an

incineration system

that oxidizes at least

90% of the nonmethane

VOC that enters the

incinerator to carbon

dioxide and water.
B-57

22a-174- The State permits the The State provides more

20(u)(2)(B)- use of alternative flexibility to a

(iii). control techniques facility as long as the

that achieve at least same emission reduction

90% VOC reduction is achieved. This,

efficiency. however, does not

result in a more

stringent regulation.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects of

the rule.
B-58

SURFACE COATING OF FLAT WOOD PANELING

FEDERAL RACT EMISSION LIMITS AS DEFINED BY THE CTG

1) Printed hardwood, 2.9 kg VOC/100 Minus Water Solids Basis

plywood, and m or 6.0 lb and Exempt 0.51 kg VOC/l (4.25

particleboard VOC/1,000 ft Solvents lb VOC/gal solids)

2 

2

(equivalent to 0.66 kg (assume 40% solids)

an average VOC/l (5.7

coating with a lb VOC/gal)

VOC content of (assume 23%

0.20 kg/l [1.7 organic

lb VOC/gal]) solvent and

b

33% water)

b

2) Natural finished hardwood plywood 5.8 kg VOC/100 0.72 kg 0.73 kg VOC/l (6 lb

m or 12.0 lb VOC/l (6 lb VOC/gal solids) 2

VOC/1,000 ft VOC/ gal) (assume 55% solids) 2

(equivalent to (assume 45%

an average organic

coating with a solvent,

VOC content of and no

0.40 kg/l [3.3 waterborne

lb VOC/gal]) coatings

are used)
B-59

SURFACE COATING OF FLAT WOOD PANELING

FEDERAL RACT EMISSION LIMITS AS DEFINED BY THE CTG

(Concluded)

 3) Class II finishes for hardboard 4.8 kg VOC/100 0.85 kg 0.85 kg VOC/l (7 lb

paneling m or 10.0 lb VOC/l (7 lb VOC/gal) (assume 40% 2

VOC/1,000 ft VOC/gal) solids) 2

(equivalent to (assume 38%

an average organic

coating with a solvent and

VOC content of 22% water)

0.34 kg/l [2.8

lb VOC/gal]) 

 The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).

 All assumptions based on the values provided in the CTG (EPA-450/2-78-032, Appendix B). b
B-60

SURFACE COATING OF FLAT WOOD PANELING 

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

New Jersey New Jersey Emission limit for: The State VOC

Administra- - printed hardwood, plywood emission limit for

tive Code, panels, and particleboard printed hardwood,

Title 7, panels: 0.32 kg VOC/l plywood panels, and

Chapter 27, (2.7 lb/gal). particleboard

Bureau of Air - natural finish hardwood panels is higher

Pollution plywood: 0.40 kg VOC/l than the Federal

Control, (3.3 lb/gal). CTG; the emission

Subchapter - hardboard panels: 0.34 kg limits for natural

16, 7:27- VOC/l (3.6 lb/gal). finish hardwood

16.5. plywood and

hardboard panels

are the same as the

CTG. 
B-61

SURFACE COATING OF FLAT WOOD PANELING 

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Maine Maine Facilities demonstrating **

Department of that only low-VOC coatings

Environmental are used at that facility

Protection, are allowed to keep monthly,

Bureau of Air rather than daily, records.

Quality Control Air

Quality Control

Regulation

Chapter 129.

** Although this provision does not result in quantifiable emission reductions, it

encourages pollution prevention.
B-62

SURFACE COATING OF FLAT WOOD PANELING 

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas Texas State emission limit: The State emission

Regulations - 2.9 kg/100 m of coated limits for each

Subchapter E: surface (6.0 lb/1,000 type of panel

115.421(10) ft ) printed interior coating are the

2

2

wall panels made of same as the limits

hardwood plywood and thin in the Federal CTG.

particleboard. 

- 5.8 kg/100 m of coated 2

surface (12.0 lb/1,000

ft ) natural finish 2

hardwood plywood panels.

- 4.8 kg/100 m of coated 2

surface (10.0 lb/1,000

ft ) hardboard paneling 2

with Class II finish.
B-63

Utah Utah Air Emission limit for: The emission limit

Conservation 1) Printed hardwood, ply- in terms of mass of

Regulation, wood, and particleboard: VOC per volume of

Emission 0.20 kg VOC/l (1.7 lb solids was

Standard Reg- VOC/gal]) coating (minus calculated using

ulation, R- water and exempt the procedure given

307-1-4.9- solvents) or 2.2 lb in Appendix F.

.6.G. VOC/gal solids.
B-64

SURFACE COATING OF FLAT WOOD PANELING 

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Utah 2) Natural finished hardwood The State's

(Concluded) plywood: 0.40 kg VOC/l emission limits and

coating (3.3 lb VOC/gal) those in the

coating (minus water and Federal CTG are the

exempt solvents) or 6.0 same.

lb VOC/gal solids.

3) Class II finishes for The emission limit

hardboard paneling: 0.34 in terms of mass of

kg VOC/l coating (2.8 lb VOC/mass of solids

VOC/gal) (minus water and was calculated

exempt solvents) or 4.5 using the

lb VOC/gal solids. guidelines

specified in

Appendix F.
B-65

SYNTHESIZED PHARMACEUTICAL PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

 1. (a) For each vent from reactors, distillation operations, crystallizers, centrifuges, and vacuum dryers that emit 6.8 kg/day (15 lb/day) or more of VOC,

require surface condensers or equivalent controls.

 

(b) If surface condensers are used, the condenser outlet gas temperature should not

exceed:

(i) -25EC when condensing VOC of vapor pressure greater than 40 kPa (5.8

psi),*

(ii) -15EC when condensing VOC of vapor pressure greater than 20 kPa (2.9

psi),*

(iii) 0EC when condensing VOC of vapor pressure greater than 10 kPa (1.5

psi),*

(iv) 10EC when condensing VOC of vapor pressure greater than 7 kPa (1.0 psi),

* and

(v) 25EC when condensing VOC of vapor pressure greater tan 3.5 kPa (0.5

psi).*

(c) Equivalent control results when emissions are reduced at least as much as when

using a surface condenser according to 1(b).

 

*Vapor pressures as measured at 20EC.
B-66

2. (a) For air dryers and production equipment exhaust systems that emit 150 kg/day

(330 lb/day) or more of VOC, require 90 percent emission reduction.

(b) For air dryers and production equipment exhaust systems that emit less than 150

kg/day (330 lb/day), require emission reduction to 15 kg/day (33 lb/day).
B-67

SYNTHESIZED PHARMACEUTICAL PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

3. (a) For storage tanks storing VOC with a vapor pressure greater than 28 kPa (4.1

psi) at 20EC, allow 1 liter of displaced vapor to be released to atmosphere for

every 10 liters transferred (i.e., a 90% effective vapor balance or

equivalent), on truck/rail car delivery to all tanks greater than 7,500 liters

(2,000 gallons) capacity except where tanks are equipped with floating roofs,

vapor recovery, or equivalent. This guideline does not apply to transfer of

VOC from one in-plant location to another.

(b) For tanks storing VOC with a vapor pressure greater than 10 kPa (1.5 psi) at

20EC, require pressure/vacuum conservation vents set at + 0.2 kPa, except where

more effective air pollution control is used.

4. Enclose all centrifuges containing VOC, rotary vacuum filters processing liquid

containing VOC, and any other filters having an exposed liquid surface where the

liquid contains VOC. This applies to liquids exerting a total VOC vapor pressure of

3.5 kPa (0.5 psi) or more at 20EC.

5. All in-process tanks must have covers. Covers should be closed whenever possible.

6. For liquids containing VOC, all leaks in which liquid can be observed to be running

or dripping from vessels and equipment (for example: pumps, valves, flanges) should

be repaired as soon as practicable. 
B-68

SYNTHESIZED PHARMACEUTICAL PRODUCTS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado Colorado The covers required for ** The Federal CTG specifies

Air all in-process tanks that all in-process tanks

Pollution shall remain closed be covered when possible. 

Regulation unless sampling, The State rule is more

No. 7, maintenance, short dura- specific as to what this

Title 5, tion production proce- entails.

Chapter dures, or inspection

1001, procedures require acSection cess.

XIV.B.6

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-69

SYNTHESIZED PHARMACEUTICAL PRODUCTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Colorado XIV.B.7 All leaks from which a ** The State requirement is

(Concluded) liquid, containing VOC, more specific than the

can be observed running Federal CTG in reference

or dripping shall be to repairs and the

repaired and completed timeframe for those

the first time the repairs. The Federal CTG

equipment is off-line. states that repairs

No leaks shall go should be made as soon as

unrepaired for more than practicable.

14 days after initial

detection unless the

Division issues written

approval.

**
B-70

XIV.B.8 Each surface condenser The Federal CTG is not

must have at least one specific about the

temperature indicator temperature indicator

with its sensor located (safety requirement).

in the outlet gas

stream.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-71

SYNTHESIZED PHARMACEUTICAL PRODUCTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut Section Visible leaks that are ** The Federal CTG states

22a-174- detected must be that repairs should be

20(t) repaired immediately. made as soon as is

practical, whereas the

State specifies a 

timeframe for repairs. 

This is considered more

specific and, thus, may

have the potential to

further reduce emissions.
B-72

The owner or operator of The State requirements

a synthetic are the same as specified

pharmaceutical in the Federal CTG.

manufacturing facility

shall control VOC

emissions from all

operations. Surface

condensers or equivalent

controls shall be used

provided that:

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-73

SYNTHESIZED PHARMACEUTICAL PRODUCTS

STATE RACT RULES

(Continued)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
B-74

Connecticut Section (A) If surface The State requirements

(Continued) 22a-174- condensers are used, the are the same as specified

20(t) outlet gas temperature in the Federal CTG.

from the condenser must

not exceed:

- -25EC when condensing

VOCs having a vapor

pressure of 40 kPa

(5.8 psi) or greater

at 20EC,

- -15EC when condensing

VOCs having a vapor

pressure of 20 kPa

(2.9 psi) or greater

at 20EC,

- 0EC when condensing

VOCs having a vapor

pressure of 10 kPa

(1.5 psi) or greater

at 20EC,

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
B-75

SYNTHESIZED PHARMACEUTICAL PRODUCTS

STATE RACT RULES

(Concluded)

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut - 10EC when condensing The State requirements

(Concluded) VOCs having a vapor are the same as specified

pressure of 7 kPa (1.0 in the Federal CTG.

psi) or greater at

20EC, or

- 25 EC when condensing VOCs having a

vapor pressure of 3.5

kPa (0.5 psi) or 

greater at 20EC, or

(B) If equivalent

controls are used, the

VOC emissions must be

reduced by at least as

much as when using a

surface condenser that

meets the requirements

of subparagraph (A).
B-76
 This appendix describes Federal RACT for source categories covered in 2

the Group III CTGs, as well as regulatory requirements for the same

categories as contained in selected State/local VOC rules.

C-1

APPENDIX C.

COMPARISON OF STATE/LOCAL VOC RULES TO FEDERAL RACT 

FOR GROUP III CTG CATEGORIES2
C-2

AIR OXIDATION PROCESSES - SOCMI 

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Federal RACT is applicable to any air oxidation facility under the synthetic organic chemical

manufacturing industry (SOCMI) in which air is used as an oxidizing agent to produce an

organic chemical. Any product recovery equipment used to collect VOC for sale or reuse from

a product recovery system of an air oxidation facility is subject to RACT.

RACT would require, for each air oxidation process vent stream, either use of a combustion

device which reduces total organic compound emissions (minus methane and ethane) 98 percent

by mass or to 20 ppm by volume (ppmv), whichever is less stringent, or maintenance of a total

resource effectiveness (TRE) index value greater than 1.0.

Thermal oxidation is the only demonstrated VOC control technology universally applicable to

all SOCMI air oxidation processes. Other control devices (flares, boilers, process heaters,

and catalytic oxidizers) have also demonstrated the ability to achieve 98% destruction or the

20 ppmv emission limit.

It is recommended that air oxidation process VOC emissions not be required to meet the 98%

reduction standard until the combustion device is replaced for other reasons.

For facilities having a TRE index value that exceeds the cutoff level (1.0), a VOC emission

reduction of 98% or the 20 ppmv limit would not be required.
C-3

No State or District regulations concerning air oxidation processes - SOCMI were provided

through the Work Group. However, the Texas, Pennsylvania, Rhode Island, and Colorado rules

were consulted, and no State rules pertaining to air oxidation processes were found.
C-4

VOC EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS 

RACT AS DEFINED BY THE CTG

This category applies to equipment in VOC service within a process unit in on-shore natural

gas processing plants. Natural gas processing plants are defined as facilities engaged in

the separation of natural gas liquids from field gas and/or fractionation of the liquids

into natural gas products, such as ethane, propane, butane, and natural gasoline. The

provisions affect only those pumps, compressors, valves, pressure relief devices, openended lines, flanges, and connections containing or contacting process streams with a VOC

concentration of 1.0 percent by mass or more.

A leak is defined as a VOC concentration greater than 10,000 ppm. Any leaking component

that has a VOC concentration over 10,000 ppm must be tagged and repaired within 15 days or

at next shutdown.
C-5

RACT procedures include weekly visual inspection of pumps and quarterly monitoring of

pumps, valves, compressors, and relief valves. Relief valves should be monitored and

repaired if necessary after they have vented to the atmosphere. Affected facilities must

implement a leak detection and repair (LDAR) program. This program involves the use of a

portable hydrocarbon detection device meeting the specifications and performance criteria

set forth in EPA Reference Test Method 21 (40 CFR 60, appendix A). Affected pumps, valves,

compressors, and pressure relief devices must be monitored at a frequency interval of no

more than quarterly. Difficult-to-monitor components (the monitoring of which requires the

use of scaffolding or requires monitoring personnel to be elevated higher than 2 meters

above permanent support) may be monitored with a frequency of no less than annually. Any

component that appears to be leaking on the basis of sight, smell, or sound, including

flanges and connections that need not be monitored regularly, should be tagged for repair. 

Leaking components must be repaired within 15 days of leak detection; however, if repair is

not technically feasible without shutting down the process unit, repair may be delayed

until the equipment can be isolated for repair or during the next scheduled process unit

turnaround.

Open-ended lines must be controlled by installation of a cap, plug, flange, or second valve

on the open end of the line. 

Exempted:

1. Facilities that do not fractionate the mixed natural gas liquids and that have design

throughput less than 10 million standard cubic feet per day. 

2. Components operating under vacuum service and equipment at underground storage

facilities.
EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Texas Texas The owner or operator of ** The CTG states that

Administrative a natural gas/gasoline relief valves should be

Code, Title processing operation monitored and repaired

31, Chapter shall measure emissions if necessary after they

115, from any relief valve have vented to the

Subchapter D, that has vented to the atmosphere. Therefore,

§115.344 atmosphere within 24 the State regulation is

hours at manned more attractive in that

facilities or within 30 it encourages pollution

days at unmanned prevention activities.

facilities.

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-7

LARGE PETROLEUM DRY CLEANERS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG
C-8

Each owner or operator of a petroleum solvent dry cleaning facility that consumes 123,000

liters or more of petroleum solvent annually shall either:

(1) limit VOC emissions to the atmosphere to an average of 3.5 kg of VOC per 100 kg dry

mass of articles dry cleaned, or

(2) install and operate a solvent recovery dryer in a manner such that the dryer remains

closed and the recovery phase continues until a final recovered solvent flow rate of

50 milliliters per minute is attained.

Each owner or operator of a petroleum solvent dry cleaning facility with a solvent

filtration system shall either:

(1) reduce the VOC content in all filtration wastes to 1.0 kg or less per 100 kg dry mass

of articles dry cleaned, before disposal, and exposure to the atmosphere; or 

(2) install and operate a cartridge filtration system, and drain the filter cartridges in

their sealed housings for 8 hours or more before removal.

Each owner or operator shall repair petroleum solvent vapor or liquid leaks within 3

working days after identifying the source of the leak. If necessary repair parts are not

on hand, the owner or operator shall order these parts within 3 working days, and repair

the leaks no later than 3 working days following the arrival of the parts.

No State or District regulations concerning large petroleum dry cleaners were provided

through the Work Group. The New York State, Pennsylvania, and Texas regulations address

only perchloroethylene dry cleaners.
C-9
C-10

POLYMER MANUFACTURING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Polystyrene plants (using continuous processes) 0.12 kg VOC/1,000 kg of product (0.24

Material recovery section lb VOC/2,000 lb of product) 

Polypropylene plants (using liquid phase processes) 98 mass percent reduction, or

reduction to 20 ppm of continuous VOC

emissions from the polymerization

reaction section, the material

recovery section, and the product

finishing section.

High-density polyethylene plants 98 mass percent reduction, or

(using liquid phase slurry processes) reduction to 20 ppm of continuous VOC

emissions from the material recovery

section and the product finishing

section.

 Emission limits are based on the use of condensers. a
C-11

POLYMER MANUFACTURING

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut Regulations For polystyrene plants ** The State requirement

of using continuous pro- will result in more

Connecticut cesses: 0.12 kg VOC/ accurate compliance

State 1,000 kg product from performance evaluation

Agencies, the material recovery than the CTG.

Title 22a, section on an hourly

Environmental basis. 

Protection,

Chapter 174,

Sec. 22a-174-

20(y).

** Although this provision of the State's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-12

SOCMI AND POLYMER MANUFACTURING EQUIPMENT LEAKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG RACT procedures are described by the following requirements:

1) RACT is applicable only to components in VOC service (containing 10% or greater VOC by

mass).

2) VOC equipment leaks from SOCMI and polymer manufacturing include capping of open-ended

lines and quarterly leak detection and repair of pumps, valves, compressors, and

safety/relief valves.

3) Any component that appears to be leaking, on the basis of sight, smell, or sound,

should be repaired.

4) Light liquid is defined as a fluid with a vapor pressure greater than 0.3 kPa at 20EC.

5) A component is considered in light liquid service if it contacts a fluid containing

greater than 10% by mass light liquid.
C-13

6) A component is considered in gas service if it contains process fluid that is in the

gaseous state at operating conditions.

7) Leak detection should consist of quarterly monitoring of the following components in

VOC service with an organic detection instrument: pumps in light liquid service,

valves in light liquid service, valves in gas service, compressors, and safety/relief

valves in gas service. However, States may choose monthly monitoring for pumps

instead of quarterly monitoring, for cost effectiveness purposes.

8) Pumps in light liquid service should be visually inspected weekly for indication of

leaks.

9) Safety/relief valves should be monitored after each overpressure relief to ensure the

valve has properly reseated.

10) Compressor seal quarterly monitoring will be determined on a case-by-case basis.

SOCMI AND POLYMER MANUFACTURING EQUIPMENT LEAKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

11) EPA Reference Method 21 or an equivalent State method should be employed to detect and

monitor VOC.

12) A source is considered leaking if monitoring results in an instrument reading of

10,000 ppmv or greater.
C-14

Exemptions:

• Small process units (e.g., units processing small quantities of light liquid (fluid with

vapor pressure >0.3 kPa at 20EC) and gaseous VOC) may be exempted from implementing

routine leak detection and repair (LDAR) programs on the basis of cost effectiveness.

• Process units processing only heavy liquid (fluid with vapor pressure <0.3 kPa at 20EC)

VOC or processing only non-VOC and equipment operating under a vacuum.

• Less frequent monitoring may be required for difficult-to-monitor valves than the

quarterly plan considered as RACT for valves in gas or light liquid service.
C-15

SOCMI AND POLYMER MANUFACTURING EQUIPMENT LEAKS

STATE RACT RULES

STATE REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Connecticut Regulation of As stated in the CTG X The State regulation is

Connecticut with additional more stringent than the

State Agencies, requirements. The Federal CTG, because the

Title 22a- State requires leaking State requires leaking

Environmental equipment (found equipment to be repaired

Protection, during monitoring or within a specified time

Chapter 174, on the basis of sight, period.

Section 22a- smell, or sound) to be

174-20(x)(4) repaired within 15

days after detection.

a

22a-174- The State requires the This additional

20(x)(5) owner or operator to reporting requirement

notify the does not result in

Department's air increased emission

compliance unit at reductions.

least 10 days prior to

the scheduled

quarterly monitoring.

a The "X" indicates that the State/local requirement is considered more stringent than the
C-16

specification in the applicable Federal CTG.
 This appendix describes Federal RACT for source categories covered in the Groups I, 3

II, and III CTGs, and presents regulatory requirements for the same categories as

contained in the two California District (local) VOC rules. Since this appendix was

developed several months after Appendices A, B, and C, and time did not allow combining

with these other appendices, Appendix D is included as a separate appendix.

C-17

APPENDIX D.

COMPARISON OF BAAQMD AND SCAQMD VOC RULES 

TO FEDERAL RACT FOR GROUPS I, II, AND III CTGs3
 "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,"

Clarification to Appendix D of November 24, 1987 Federal Register - May 25, 1988 (revised

1/11/90), U.S. Environmental Protection Agency, Office of Air Quality Planning and

Standards, Research Triangle Park, NC.

C-18

CUTBACK ASPHALT

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Substitute emulsified asphalt for cutback asphalt.

The Blue Book suggests seasonal exemptions (i.e., outside of ozone season) as opposed to temperature forecasting (e.g., <50EF), 4

specifies (1) no higher than 7% oil distillate as maximum allowable solvent content (by volume) in emulsified asphalt, as determined

by ASTM distillation test D-244 or (2) allow use of certain grades or applications of emulsified asphalt with the following maximum

solvent contents as determined by ASTM D-244: (a) 3% limit for seal coats used in early spring or late fall; (b) 3% limit when chip

seals used with aggregate is dusty or dirty; (c) 8% limit when mixing with open graded aggregate that is not well washed; and (d) 12%

limit when mixing with dense graded aggregate. Other exemptions are listed for use solely as penetrating prime coat and when

stockpiled for extended periods.
C-19

CUTBACK ASPHALT 

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Air Regulation 8, Rule The District sets the following ** The District places some

Quality 15, standards: prohibitions on the use of rapidManagement Section 301 - A person shall not use any rapid- cure asphalt in paving material

District cure liquid asphalt in paving or in paving and maintenance

material or in paving and operations which are not

maintenance operations. specified in the Federal CTG.

X

a

Section 304 - A person shall not use any slow- The Federal CTG specifies that

cure liquid asphalt which slow- cure may contain 20 to 30

contains more than 0.5 percent percent (by volume) of diluent

by volume of petroleum solvents (petroleum distillate), average

which boil at less than 260EC 25%.

(500EF) in paving material or in

paving and maintenance

operations.

** Although this provision of the District's regulation may not necessarily result in a quantifiable reduction in emissions, it does

enhance the pollution prevention aspects of the rule.

The "X" indicates that the District requirement is considered more stringent than the applicable Federal CTG. a
C-20

CUTBACK ASPHALT 

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, Rule A person shall not use any emulsified X The District requires a lower

AQMD 15, Section 305 asphalt containing petroleum solvents VOC content than the CTG.

(Concluded) in excess of 3% by volume in paving

material or in paving and

maintenance operations.

South Coast Air Rule 1108 A person shall not sell or offer for X The CTG specifies a higher

Quality Section b sale for use in the District, or use any VOC content than the District.

Management cutback asphalt containing more than

District 0.5% by volume organic compounds

that evaporate at 260EC (500EF) or

lower.

X

Rule 1108.1 A person shall not sell or offer for The Federal CTG allows 7% as

sale for use in the District, or use any the maximum solvent content

emulsified asphalt containing organic (by volume) in emulsified

compounds that evaporate at 260EC asphalt, as determined by

(500EF) or lower, in excess of 3% by ASTM distillation test D-244.

volume for slow and rapid setting

type; and 3% by volume for medium

setting type for use with any

aggregate.
C-21

FIXED-ROOF PETROLEUM TANKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Emission limits are recommended in terms of equipment specifications. These specifications

include internal floating roofs equipped with a closure seal or seals, or alternative

equivalent control. The CTG, however, does not specify the exact types of controls that

can be used to achieve this. 

The cutoffs for fixed-roof petroleum tanks provided in the CTG are as follows:

(a) greater than 150,000 liters (40,000 gallons) storage capacity containing volatile

petroleum liquids (greater than 10.5 kPa or 1.5 psi TVP) are covered, and 

(b) less than 1,600,000 liters (420,000 gallons) storage capacity of crude oil and

condensate prior to lease custody transfer are exempted.
C-22

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, A person shall not store X The Bay Area 

Air Quality Rule 5, organic liquid in any regulation has a

Management Section 304 storage tank with a capacity lower cutoff level

District greater than 75,000 l than the Federal

(19,813 gal) unless such CTG. Therefore,

tank meets the following more tanks may be

conditions: subject to the

1. Storage tanks with a rule.

capacity greater than

75,000 l (19,813 gal)

but less than 150,000 l

(39,600 gal) storing an

organic liquid with a

true vapor pressure

greater than 1.5 psia

must meet the

requirements of Section

311.

2. Storage tanks with a

capacity of 150,000 l

(39,600 gal) or greater

storing an organic

liquid with a true

vapor pressure greater

than 0.5 psia must meet

the requirements of

Section 311.
C-23

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 311.2 An internal floating roof The Federal CTG

AQMD shall be equipped with seals only specifies that

(Continued) that satisfy one of the internal floating

following requirements: roofs should be

a. A liquid primary seal, equipped with a

mounted in full contact closure seal or

with the liquid in the seals. The Bay

annular space between Area, on the other

the tank shell and hand, provides

floating roof; detailed

b. A vapor-mounted primary specifications for

and a secondary seal; each type of seal.

or

c. A liquid-mounted

primary and a secondary

seal that satisfy the

requirements in

Sections 321 and 322 if

the seals were

installed after

February 1, 1993.
C-24

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 311.3 An approved emission control ** The Federal CTG

AQMD system that collects and indicates that an

(Concluded) processes all organic vapors internal floating

and gases and has an roof can achieve

abatement efficiency of at VOC emission

least 95% by mass. reduction of 90% or

**

greater. 

Section 320 Floating roofs must meet These requirements

certain fitting are not specified

requirements. in the Federal CTG.

 Sections 321 The Bay Area provides ** These requirements

and 322 specific operating are not specified

requirements for tanks in the Federal CTG.

equipped with both primary

and secondary seals.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-25

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Regulation No person shall place, X The South Coast

Air Quality IV, Rule 463, store, or hold in any regulation has a 

Management Section b.1 stationary tank, reservoir, lower vapor

District or other container of pressure cutoff

150,000 l (39,630 gal) or level than the

greater capacity, any Federal CTG (0.5

organic liquid having a true psi vs 1.5 psi).

vapor pressure of 0.5 psi

absolute or greater under

actual storage conditions,

and in any above ground

stationary tank or other

above ground container of

more than 75,000 l (19,815

gal) but less than 150,000 l

(39,630 gal) capacity, and

organic liquid having a true

vapor pressure of 1.5 psi

absolute or greater under

actual storage conditions,

unless such tank is designed

and equipped with vapor loss

control devices, properly

installed, properly

maintained, and in good

operating order.
C-26

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.2.D Compliance shall be verified ** This compliance

AQMD by measuring with a requirement is not

(Continued) combustible gas detector the specified in the

concentration of organic Federal CTG.

compounds in the vapor space

above the internal floating

roof in terms of the lower

explosive limit (LEL). Such

reading for an internal

floating roof shall not

exceed 50% of the LEL for

those installed prior to

June 1, 1984, or 30% for

those installed after June

1, 1984.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-27

FIXED-ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.3 A vapor recovery system ** The Federal CTG

AQMD capable of collecting all indicates that an

(Concluded) organic vapors and a vapor internal floating

return or disposal system roof can achieve

capable of processing such VOC emission

vapors so as to reduce their reduction of 90% or

emission to the atmosphere greater.

at an efficiency of at least

95% by mass.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-28

BULK PLANTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The EPA defines a gasoline bulk plant as having a throughput of less than 76,000 liters

(20,000 gallons) of gasoline per day averaged over the work days in 1 year. A summary of

the CTG RACT requirements is given below.

- Bulk plant facilities include: 1) tanks for gasoline storage; 2) loading racks; and 3)

incoming and outgoing tank trucks. 

- Three control techniques employed at bulk plants are submerged loading, balance system,

and leak prevention. 

- Other control alternatives considered are: a) submerged filling; b) submerged filling

account trucks with vapor balancing of transport trucks and storage tanks; and c)

submerged filling account trucks with vapor balancing of storage tanks, and account and

transport trucks. 

- A vapor balance system controls vapor emissions during loading and unloading of tank

trucks with an efficiency greater than 90%.

- Proper maintenance, operation, and good housekeeping are required to prevent leaks and

assure effective collection of VOC emissions when balance systems are installed.

- To maintain high reduction efficiencies, tank trucks, storage tanks, and all piping

must be vapor-tight.

- No specific emission limit for bulk plant controls is provided. 
C-29

BULK PLANTS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Air Regulation 8, A person shall not load X The Federal CTG does

Quality Rule 39, or permit the loading of not specify a VOC

Management Section 302 gasoline into or out of a emission limit, but

District gasoline bulk plant only provides

unless a CARB certified equipment

vapor recovery system is specifications.

properly connected and

used. Such system shall

not emit into the

atmosphere more than 60 g

of precursor organic

compounds/m (0.5 3

lb/1,000 gal) of organic

liquid loaded.

Regulation 8, The system shall be * The gauge pressure

Rule 39, maintained and operated requirement during

Section 308 in a manner that prevents product loading is

the gauge pressure in the not specified in the

delivery tank from Federal CTG. 

exceeding 46 cm (18 in)

of water column during

product loading.

* This provision of the District's regulation involves work practices that will result in

emission reductions.
C-30

BULK PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Rule 6, A person shall not allow X The Federal CTG

AQMD Section 304 the delivery of any requires a vapor

(Continued) organic liquid to any recovery system to

bulk plant storage tank achieve at least 90%

having a capacity between efficiency. 

7.6 and 150 m (2,000 and Therefore, the 3

40,000 gallons) District requirement

inclusive, unless a vapor is more stringent

recovery system of at than the Federal CTG.

least 95% efficiency, or

an equivalent vapor loss

control system, has been

properly installed on the

storage tank and is

properly connected during

delivery.
C-31

BULK PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Rule 6, Standard for operating * These operating 

AQMD Section 307 practices: any organic practices are not

(Concluded) liquid having a true specified in the

Rule 6, A bulk plant is defined * The Bay Area daily

Section 201 as having an annual gasoline throughput

vapor pressure greater Federal CTG.

than 0.1 bar (1.5 psia)

shall not be spilled,

discarded in sewers,

stored in open

containers, or handled in

any other manner that

would result in

evaporation to the

atmosphere.

throughput of not more cutoff of 17,000

than 23,000 cubic meters gallons is lower than

(6,000,000 gallons). the daily cutoff of

Assuming 360 workdays in 20,000 gallons

one year, the maximum specified in the

daily throughput is Federal CTG.

17,000 gallons.

* This provision of the District's regulation involves work practices that will result in

emission reductions.
C-32

BULK PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Regulation IV, South Coast regulation X The Federal CTG

Air Quality Rule 462, defines a bulk plant as a provides several

Management Section b.1.B Class B facility, which options including the

District shall be equipped with a vapor balance

vapor recovery system technique to reduce

capable of returning the emissions during

displaced vapors from the transfer operations.

delivery vessel being This technique

filled back to the provides a higher

stationary storage control efficiency

container (vapor balance than submerged fill

technique). (90% vs 58%).

The backpressure in the ** These additional

vapor recovery system requirements are not

shall not exceed 18 specified in the

inches of water. The Federal CTG. They

transfer equipment shall have a potential for

be operated so that there reducing emissions

are no overfills, resulting from

fugitive vapor leaks, filling operations.

fugitive liquid leaks, or

excess organic liquid

leaks.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule. 
C-33

BULK PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.1.E Any source of a fugitive X This requirement is

AQMD vapor or liquid leak not found in the

(Continued) shall be corrected to Federal CTG. It is

comply with the fugitive more stringent than

vapor or liquid leak the timeframe of 15

limit of this rule within days set in the CTG

2 days after notification for repairing leaks

in writing of detection. from petroleum

The Executive Officer refinery equipment.

shall be notified within

2 days after the work is

completed. A fugitive

vapor leak is defined as

an escape of organic

vapors from a source

other than the tank

truck, trailer, or

railroad tank car,

measured in excess of

3,000 ppm above

background at a distance

of 2 cm (0.8 inch) from

the source for more than

10 seconds duration, or
C-34

BULK PLANTS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast equivalent test method as

AQMD determined by the

(Concluded) Executive Officer. A

fugitive liquid leak is a

dripping of liquid

organic compounds at a

rate in excess of three

drops per minute from any

single leak source other

than the disconnect

operations, liquid fill

line(s), and vapor

line(s).
C-35

GASOLINE LOADING TERMINALS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Tank truck gasoline loading terminal 80 mg VOC/l (0.67 lb VOC/1,000 gal)

of gasoline loaded

This limit is based on submerged fill and vapor recovery/control systems. a

The "Blue Book" defines the affected facility as any tank truck loading operations at the

primary wholesale outlet for gasoline which delivers at least 76,000 liters/day (20,000

gallons/day).
C-36

GASOLINE LOADING TERMINALS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation A person shall not load X The District VOC

Air Quality 8, Rule 33, or permit the loading of emission limit is much

Management Section 301 gasoline into or out of lower than the one

District a gasoline bulk terminal specified in the

unless a CARB certified Federal CTG.

vapor recovery system is

properly connected and

used. Such system shall

not emit into the

atmosphere more than 9.6

mg of precursor organic

compounds/l (0.08

lb/1,000 gal) of organic

liquid loaded.

Regulation A person shall not allow X The Federal CTG does

8, Rule 6, the delivery of any not specify a control

Section 304 organic liquid to any efficiency requirement

storage tank having a for a vapor control 

capacity between 7.6 and system.

150 m (2,000 and 40,000 3

gallons) inclusive,

unless a vapor recovery

system of at least 95%

efficiency, or an

equivalent vapor loss

control system, has been

properly installed on

the storage tank and is

properly connected

during delivery.
C-37

GASOLINE LOADING TERMINALS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 307 Any organic liquid * These work practices

AQMD having a true vapor are not specified in

(Concluded) pressure greater than the Federal CTG.

0.1 bar (1.5 psia) shall

not be spilled,

discarded in sewers,

stored in open containers, or handled in any

other manner that would

result in evaporation to

the atmosphere.

South Coast Regulation South Coast defines a ** The Federal CTG does

Air Quality IV, Rule loading terminal as a not specify any

Management 462, Section Class A facility. The continuous monitoring. 

District b.1.A Class A facility shall

be equipped with an

approved vapor recovery

and/or disposal system

which has continuous

monitoring and a

recording system to

measure emissions to the

atmosphere.

* This provision of the District's regulation involves work practices that will result

in quantifiable emission reductions.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
C-38

GASOLINE LOADING TERMINALS

CA DISTRICT RACT RULES

(Continued)

STATE REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast The emission limit for X The South Coast regula-

 AQMD this facility is 35 mg/l tion specifies less

(Continued) (0.29 lb non-methane than half of the

organic vapors/1,000 emission limit specgal) of liquid tran- ified in the Federal

sferred. CTG.

The backpressure in the * The pressure 

vapor recovery system requirement is not

shall not exceed 18 specified in the

inches of water. Federal CTG.

The transfer equipment ** The EPA "Blue Book"

shall be operated so clarifies that trucks

that there are no used in the loading

overfills, fugitive terminal should pass a

vapor leaks, fugitive leak-tight test. The

liquid leaks, or excess South Coast regulation

organic liquid leaks. requires all transfer

equipment, not only

trucks, to be leakfree.

* This provision of the District's regulation involves work practices that will result

in quantifiable emission reductions.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-39

GASOLINE LOADING TERMINALS

CA DISTRICT RACT RULES

(Concluded)

STATE REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section Any source of a fugitive X The CTG does specify

AQMD b.1.E vapor or liquid leak written notification. 

(Concluded) shall be corrected to The District regulation

comply with the limits requires shorter time

of this rule within 2 to repair leak than the

days after notification CTG and, therefore, is

in writing of detection. more stringent. 

The Executive Officer

shall be notified within

2 days after the work is

completed.
C-40

MISCELLANEOUS REFINERY SOURCES

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG states that regulations for vacuum producing systems (VPSs) and wastewater

separators (WSs) should be written in terms of equipment specifications, and regulations

for process unit turnarounds (PUTs) should be written in terms of operating procedures. 

It is suggested that non-condensables from VPSs be piped to an appropriate firebox,

incinerator, or (if spare compressor capability is available) compressing the vapors and

adding them to refinery fuel gas. The hot wells associated with contact condensers can be

covered and the vapors incinerated. Reasonable control of VOC emissions from a WS

consists of covering the forebays and separator sections.

Commercially operating wastewater separators include (1) a solid cover with all openings

sealed, totally enclosing the compartment liquid contents; and (2) a floating pontoon or

double-deck type cover, equipped with closure seals to enclose any space between the

cover's edge and compartment wall. Also, any gauging and sampling device in the

compartment cover should be designed to provide a projection (such as a probe) into the

liquid surface to prevent VOC from escaping. The sampling device can also be equipped

with a cover or lid that is in a closed position at all times except when the device is in

actual use. 

When a process unit is shut down for a turnaround, the agency should require that the

vessel be depressurized to vapor recovery, a flare, or a firebox. The agency and the

operator should agree on a timetable for compliance. Included in this timeframe should be

dates for ordering, recovery installation, and startup of necessary equipment. Each

fractioner, reactor, stabilizer, etc. should be addressed. The vapors can either be added

to the fuel gas system, flared, or directly vented to atmosphere. No VOC should be

directly discharged to the atmosphere until the vessel pressure is less than 5 psig. The

refinery operator should keep a record of each PUT, listing as a minimum the date the unit

was shut down, the approximate vessel hydrocarbon concentration when the hydrocarbons were

first discharged to the atmosphere, and the approximate total quantity of hydrocarbons

emitted to the atmosphere. These records should be kept for at least 2 years and be made

available to the air pollution control agency inspector during any compliance inspection

of the refinery. 
C-41

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation Any wastewater separator X The Federal CTG does not

Air Quality 8, Rule 8, and/or forebay shall not be specify a required

Management Sections operated unless such system collection and

District 301, 302 is equipped with an organic destruction efficiency.

compound (OC) vapor

recovery system with a

combined collection and

destruction efficiency of

at least 95%, by mass.

South Coast Regulation For every refinery that ** This is an additional

Air Quality XI, uses inert gas displacement requirement that is not

Management Rule 1123, or vacuum eduction for specified in the Federal

District Section process turnaround, a CTG.

b.2 person operating the

refinery shall submit to

the Executive Officer a

plan that describes at

least the following:

- the procedure used for

gas displacement or

eduction;

- the disposition of the

displaced or educed

organic gases;

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-42

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast - the stage in the

AQMD displacement or eduction

(Continued) procedure at which the

disposition is changed

from a control facility

to atmospheric venting,

and

- the criteria by which

said stage is

identifiable.

**

Section The Executive Officer shall This requirement is

b.3 approve the plan upon his applied when the 

determination that it owner/operator of the

provides for the maximum plant is subject to

feasible control of Section b.2. 

emissions of displaced or

educed organic gases

without causing damage to

equipment, malfunction of

pollution control or safety

devices, or violations of

safety regulations and

without installation or

structural modification of

equipment that is not

needed to comply with this

rule.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-43

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section After approval of a plan, ** This requirement is not

AQMD b.4 all displacement operations specified in the Federal

(Continued) shall be conducted CTG. 

according to said plan

unless another specifically

approved plan is used.

Section d Any vessel that has been * No exemption is

depressurized to less than specified in the Federal

5 psi shall be exempted CTG. 

from the provision of

Section b.2 by the

Executive Officer upon

determination by the

Executive Officer that the

use of existing control

facilities to comply with

Section b.2 is likely to

damage equipment, cause the

malfunction of pollution

control or safety devices,

or cause violations of

safety regulations.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

* This is an applicability issue. 
C-44

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1176, Wastewater separators shall X The Federal CTG

AQMD Section be replaced by covered specifies a fixed cover

(Continued) c.2.B tanks that are approved by and a floating cover,

the Executive Officer; or equipped with closure

provided with any one of seals. The CTG,

the following: however, does not

a) a floating cover specify that a fixed

equipped with seals; cover must be equipped

b) a fixed cover, equipped with a control device.

with a closed vent

system that directs

vapors to a control

device with a control

efficiency of 95% by

mass or greater. The

closed vent system

shall not produce

detectable VOC

emissions in excess of

500 ppm measured at a

distance of 1 cm or

less from the source;

or

c) any measure that is

equivalent to, or

better than, the above

requirements.

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?
C-45

South Coast Rule 1176, The following shall not be X The Federal CTG only

AQMD Section used unless equipped and says to cover the

(Continued) c.3 operated as specified forebays and separator

below: sections. The South

a. Separator forebays and Coast regulation, on the

sewer lines: other hand, indicates

All interconnections with specifically how each

the receiving wastewater item of equipment should

separators shall be be covered. No emission

enclosed by fixed covers limit is given in the

such that no liquid surface CTG.

is exposed to the

atmosphere.

b. Process drains:

At any drain opening to the

atmosphere, VOC emissions

shall not exceed 500 ppm

measured at a distance of 1

cm or less from the source.

c. Junction boxes:

Junction boxes shall be

totally enclosed with a

solid, gasketed, or manhole

cover.

Requirement for covers. ** The Federal CTG does not

discuss requirements for

covers.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-46

MISCELLANEOUS REFINERY SOURCES

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section e Operator inspection and X The Federal CTG

AQMD maintenance requirements indicates pollution

(Concluded) 1. Air pollution control control equipment should

device(s) required be checked by an air

shall be subjected to a pollution control agency

performance test inspector, at least once

semiannually, for a year.

verification of control

efficiency.

2. Closed vent systems and ** The Federal CTG does not

process drains shall be specify monthly

inspected monthly for inspections.

VOC emissions.

3. Defect(s) or leak(s) X The Federal CTG

detected through either specifies leaks from

operator or District petroleum refinery

inspection shall be equipment are to be

repaired within 3 repaired within 15 days.

calendar days of

detection. The

repaired or replaced

component shall be

reinspected within 15

days of the repair or

replacement.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects of

the rule.
C-47

STAGE I VAPOR RECOVERY

RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG suggests several methods to conduct displaced vapors from the underground tank

to the trucks as follows: 1) two-point system, 2) coaxial systems, 3) manifolded vent

lines, and 4) prescribed design criteria. Under design criteria several distinctions

have been made; they are 1) drop tube specifications, 2) gauge well, 3) vapor line

connections, 4) vapor hose return, 5) type of liquid fill connection, 6) tank truck

inspection, 7) closures and interlocks on underground tank vapor hose connectors, 8)

vapor hose connection to the tank trucks, and 9) vent line restrictions.

The design criteria were developed to accomplish the following:

(a) assure submerged fill, i.e., discharge liquid below the gasoline surface in the

storage tank; 

(b) assure that the vapor return line and connections are of sufficient size and

sufficiently free of restrictions to allow transfer of vapor to the truck tank

and achieve the desired recovery;

(c) assure that there are no significant leaks in the system or the tank truck

which reduce vacuum in the truck or otherwise inhibit vapor transfer; and 

(d) assure that the vapor return line will be connected during tank filling.

Suitable restrictive orifices or pressure-relief valves are required whenever the

systems would otherwise be incapable of achieving 90% control or would otherwise not

assure that the vapor return line is connected. Either of the following restrictive

devices is acceptable:

(a) Orifice of 1/2 to 3/4 inch ID.

(b) Pressure-vacuum relief valve set to open at 8 oz. per square inch or greater

pressure and 4 oz. per square inch or greater vacuum. The vacuum relief

feature of a P-V valve is not required for Stage I recovery purposes but may be

required by safety authorities.

Exemptions (See Blue Book):

- Storage tanks < 550 gallons capacity for agricultural use.

- Storage tanks < 2,000 gallons capacity in place before 1/1/79.

- Storage tanks < 250 gallons capacity in place after 12/31/78.

- Service stations with < 10,000 gal/month (120,000 gal/year) throughput.
C-48

STAGE I VAPOR RECOVERY

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, The rule exempts storage * Although the Federal

Air Quality Rule 7, tanks with a capacity of CTG provides

Management Section 111 less than 1 cubic meter exemptions for

District (260 gallons). different tank sizes

*

depending upon the

purpose and age of

the tanks, more

facilities are

subject to this

rule.

Section 111 Other exemptions: These exemptions are

1. Storage tanks not specified in the

installed before Federal CTG. This

October 1, 1974 at is an issue of

facilities with an applicability.

annual throughput of

less than 60,000

gallons which were

not equipped with

Phase I vapor

recovery as of July

1, 1983.

* This is an applicability issue.
C-49

STAGE I VAPOR RECOVERY

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 111 2. Storage tanks used

AQMD (Concluded) primarily for the

(Concluded) fueling of

implements of

husbandry, provided

such tanks are

equipped with a

submerged fill pipe.

South Coast Regulation IV The rule applies to any * The South Coast

Air Quality Rule 461 storage tank with a regulation has a

Management Section c.1 capacity of 950 liters lower cutoff level

District (251 gallons) or more. than the Federal

**

CTG.

Section c.1.D The hatch on any tank These additional

truck, trailer, or requirements are not

railroad tank car shall specified in the

not be opened for more Federal CTG.

than 3 minutes for each

visual inspection,

provided that:

a. transfer or pumping

has been stopped for

at least 3 minutes

prior to opening;

and

b. the hatch is closed

before transfer or

pumping is resumed.

* This is an applicability issue.

** This provision of the District's regulation involves work practices that will

result in emission reductions.
C-50

STAGE I VAPOR RECOVERY

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section c.1.F The South Coast ** These requirements

AQMD regulation contains are not specified in

(Concluded) specific requirements the Federal CTG.

for operating and

maintaining equipment

subject to the rule.

Section d The provisions of this * These exemptions are

rule shall not apply to not provided in the

the transfer of Federal CTG.

gasoline:

1. into or from any

stationary tank if

75% of its monthly

throughput is used

for the fueling of

implements of

husbandry, provided

such a tank is

equipped with a

submerged fill tube.

2. into or from any

stationary tank used

exclusively for

fueling agricultural

wind machines.

* This is an issue of applicability.

** Although this provision of the District's regulation may not necessarily result in

a quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
C-51

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

1) CONTROL SYSTEMS FOR COLD CLEANING

Control System A

Control Equipment:

1. Cover.

2. Facility for draining cleaned parts.

3. Permanent, conspicuous label, summarizing the operating requirements.

Operating Requirements:

1. Do not dispose of waste solvent or transfer it to another party, such that

greater than 20 percent of the waste (by mass) can evaporate into the

atmosphere. Store waste solvent only in covered containers. *

2. Close parts cleaner (degreaser) cover whenever not handling parts in the cleaner.

3. Drain cleaned parts for at least 15 seconds or until dripping ceases.

Control System B

Control Equipment:

1. Cover: Same as in System A, except if (a) solvent volatility is greater than 2

kPa (15 mm Hg or 0.3 psi) measured at 38EC (100EF), (b) solvent is agitated, or **

(c) solvent is heated, then the cover must be designed so that it can be easily

operated with one hand. (Covers for larger parts cleaners (degreasers) may

require mechanical assistance, by spring loading, counterweighting, or powered

systems.)

2. Drainage facility: Same as in System A, except that if solvent volatility is

greater than about 4.3 kPa (32 mm Hg or 0.6 psi) measured at 38EC (100EF), then

the drainage facility must be internal, so that parts are enclosed under the

cover while draining. The drainage facility may be external for applications

where an internal type cannot fit into the cleaning system.
C-52

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

3. Label: Same as in System A.

4. If used, the solvent spray must be a solid, fluid stream (not a fine, atomized,

or shower type spray) at a pressure that does not cause excessive splashing.

5. Major control device for highly volatile solvents: If the solvent volatility is

> 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38EC (100EF), or if solvent is heated

above 50EC (120EF), then one of the following control devices must be used:

a. Freeboard that gives a freeboard ratio > 0.7, ***

b. Water cover (solvent must be insoluble in and heavier than water), or

c. Other systems of equivalent control, such as a refrigerated chiller or carbon

adsorber. 

Operating Requirements:

Same as in System A.

 

Water and solid waste regulations must also be complied with. *

Generally, solvents consisting primarily of mineral spirits (Stoddard) have **

volatilities < 2 kPa.

Freeboard ratio is defined as the freeboard height divided by the width of the parts ***

cleaner (degreaser).

2) COMPLETE CONTROL SYSTEMS FOR OPEN TOP VAPOR PARTS CLEANERS (DEGREASERS)

Control System A

Control Equipment:

1. Cover that can be opened and closed easily without disturbing the vapor zone.

Operating Requirements: 

1. Keep cover closed at all times except when processing work loads through the

parts cleaner (degreaser).
C-53

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

2. Minimize solvent carry-out by the following measures:

a. Rack parts to allow full drainage

b. Move parts in and out of the parts cleaner (degreaser) at less than 3.3 m/sec

(11 ft/min).

c. Degrease the work load in the vapor zone at least 30 sec. or until

condensation ceases.

d. Tip out any pools of solvent on the cleaned parts before removal.

e. Allow parts to dry within the parts cleaner (degreaser) for at least 15 sec.

or until visually dry.

3. Do not degrease porous or absorbent materials, such as cloth, leather, wood, or

rope.

4. Work loads should not occupy more than half of the parts cleaner's open top area.

5. The vapor level should not drop more than 10 cm (4 in) when the work load enters

the vapor zone.

6. Never spray above the vapor level.

7. Repair solvent leaks immediately, or shut down the parts cleaner.

8. Do not dispose of waste solvent or transfer it to another party such that greater

than 20% of the waste (by mass) will evaporate into the atmosphere. Store waste

solvent only in closed containers.

9. Exhaust ventilation should not exceed 20 m /min per m (65 cfm per ft ) of parts 3 2 2

cleaner's open area, unless necessary to meet OSHA requirements. Ventilation

fans should not be used near the parts cleaner opening.

10. Water should not be visually detectable in solvent exiting the water separator.
C-54

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

Control System B

Control Equipment:

1. Cover (same as for system A).

2. Safety switches

a. Condenser flow switch and thermostat - (shuts off sump heat if condenser

coolant is either not circulating or too warm).

b. Spray safety switch - (shuts off spray pump if the vapor level drops

excessively, about 10 cm (4 in).

3. Major Control Device:

Either: a. Freeboard ratio greater than or equal to 0.75, and if the parts cleaner's

opening is > 1 m (10 ft ), the cover must be powered; 2 2

b. Refrigerated chiller;

c. Enclosed design (cover or door opens only when the dry part is actually

entering or exiting the parts cleaner);

d. Carbon adsorption system, with ventilation > 15 m /min per m (50 cfm/ft )

3 2 2

of air/vapor are (when cover is open), and exhausting <25 ppm solvent

averaged over one complete adsorption cycle; or

e. Control system, demonstrated to have control efficiency equivalent to or

better than any of the above.

4. Permanent, conspicuous label summarizing operating procedure nos. 1 to 6.

Operating Requirements:

Same as for System A.
C-55

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

3) CONTROL SYSTEMS FOR CONVEYORIZED PARTS CLEANERS (DEGREASERS)

Control System A

Control Equipment: None

Operating Requirements:

1. Exhaust ventilation should not exceed 20 m /min per m (65 cfm per ft ) of parts 3 2 2

cleaner's opening, unless necessary to meet OSHA requirements. Work place fans

should not be used near the parts cleaner's opening.

2. Minimize carry-out emissions by:

a. Racking parts for best drainage.

b. Maintaining vertical speed at < 3.3 m/min (11 ft/min).

3. Do not dispose of waste solvent or transfer it to another party such that greater

than 20% of the waste (by mass) can evaporate into the atmosphere. Store waste

solvent only in covered containers.

4. Repair solvent leaks immediately, or shut down the parts cleaner.

5. Water should not be visually detectable in the solvent exiting the water

separator.
C-56

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Continued)

Control System B

Control Equipment:

1. Major control devices; the parts cleaner must be controlled by either:

a. Refrigerated chiller;

b. Carbon adsorption system, with ventilation > 15 m /min per m (50 cfm/ft ) of 2 2 2

air/vapor area (when down-time covers are open), and exhausting <25 ppm of

solvent by volume averaged over a complete adsorption cycle; or

c. System demonstrated to have control efficiency equivalent to or better than

either of the above.

2. Either a drying tunnel, or another means such as rotating (tumbling) basket,

sufficient to prevent cleaned parts from carrying out solvent liquid or vapor.

3. Safety switches

a. Condenser flow switch and thermostat - (shuts off sump heat if coolant is

either not circulating or too warm).

b. Spray safety switch - (shuts off spray pump or conveyor if the vapor level

drops excessively, e.g. > 10 cm (4 in.)).

c. Vapor level control thermostat - (shuts off sump heat when vapor level rises

too high).

4. Minimized openings: Entrances and exits should silhouette work loads so that the

average clearance (between parts and the edge of the parts cleaner's opening) is

either <10 cm (4 in.) or <10% of the width of the opening.

5. Down-time covers: Covers should be provided for closing off the entrance and

exit during shutdown hours.
C-57

SOLVENT METAL CLEANING

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

Operating Requirements: 

1. to 5. Same as for System A.

6. Down-time cover must be placed over entrances and exits of conveyorized parts

cleaners immediately after the conveyor and exhaust are shut down and removed

just before they are started up.

Exemptions:

1. Conveyorized parts cleaners with less than 2.0 m of air/vapor interface should be 2

exempted from the requirement for a major control device.

2. Open top parts cleaners with less than 1 m of open area should be exempted from 2

having to operate with either a refrigerated chiller or a carbon adsorber.
C-58

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Air Regulation Vapor solvent cleaners shall X The Federal CTG

Quality 8, Rule 16, not operate without one of states that the

Management Section the following control recommended control

District 301.4 devices: methods can reduce

- A freeboard chiller VOC emissions by 25

where the chilled air to 60%, depending

blanket temperature on the type of

measured at the coldest cleaner and

point on the vertical controls installed. 

axis in the center of The Bay Area, on

the solvent cleaner is the other hand,

no greater than 30% of requires a much

the initial boiling higher control

point of the solvent efficiency than

used or 40EF; those stated in the

- An approved emission CTG. The Bay Area

control device with a also gives detailed

control efficiency of specifications for

90% or more on a mass the freeboard

basis. chiller that are

not provided in the

CTG.
C-59

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

 Bay Area 302.5 Conveyorized solvent X See comments above

AQMD cleaners shall not operate under Section

(Continued) without one of the following 301.4.

control devices:

- A freeboard chiller

where the chilled air

blanket temperature

measured at the coldest

point on the vertical

axis in the center of

the solvent cleaner is

no greater than 30% of

the initial boiling

point of the solvent

used or 40EF;

- An approved emission

control device with a

control efficiency of

90% or more on a mass

basis.
C-60

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section Cold cleaner operating X The Federal CTG

AQMD 303.2 requirements: allows agitation

(Continued) - solvent agitation shall with compressed

be accomplished only by air. The Bay Area

pump recirculation or specifically

by means of a mixer. prohibits air

Air agitation shall not agitation.

be used.

Section Cold cleaners shall not X Freeboard ratio is

303.4 operate without one of the defined as the

following control devices: ratio of freeboard

- A freeboard ratio height to cleaner

greater than or equal width. Freeboard

to 0.75 where the height is the

maximum solvent distance from the

reservoir capacity is solvent to the top

clearly marked by a edge of the cold

suitable mechanical or cleaner. 

physical means. Therefore, the

- A water cover, provided larger the ratio,

the solvent is the less the

insoluble in and emissions. The

heavier than water. Federal CTG

specification for

freeboard ratio is

lower than in the

Bay Area

regulation. 
C-61

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section - A freeboard chiller X In addition, the

AQMD 303.4 where the chilled air Federal CTG does

(Continued) (Concluded) blanket temperature not provide

measured at the coldest detailed

point on the vertical specifications for

axis in the center of a freeboard chiller

the solvent cleaner is and requires a

no greater than 30% of lower control

the initial boiling efficiency than the

point of the solvent Bay Area. Overall,

used or 40EF; the Bay Area

- An approved emission regulation is more

control device with a stringent than the

control efficiency of CTG.

90% or more on a mass

basis.
C-62

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section General operating X The CTG does not

AQMD 301.1, requirements for vapor allow waste solvent

(Concluded) subsection solvent cleaners, to be disposed of

1.4 conveyorized solvent or transferred to

cleaners, and cold cleaners: another party, such

Waste solvent residues that greater than

treated prior to final 20% of the waste

disposal at an appropriate (by mass) can

waste disposal facility evaporate into the

shall not contain more than atmosphere. 

10% solvent by volume and

shall be stored in covered

containers.
C-63

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1122, Solvent agitation, where ** Although the South

Air Quality Section necessary, shall be carried Coast regulation

Management c.2.I out only by pump allows the same

District recirculation, ultrasonics, agitation equipment

a mixer, or by air as the Federal CTG,

agitation. Air agitation it has several

shall be carried out under restrictions on the

the following conditions: use of air

- The air agitation unit agitation. These

shall be equipped with restrictions are

a gauge and a device not specified in

that limits air the CTG.

pressure into the

cleaner to less than 2

psig; and

- the cover must remain

closed while the air

agitation system is in

operation.

Section d.3 Batch-loaded cold cleaners X The South Coast

with a high volatility regulation requires

solvent shall be fitted with a higher freeboard

a drainage facility inside ratio than the

the cleaner and have a Federal CTG (0.7).

freeboard ratio of at least

0.75.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
C-64

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section e.6 Specific operating ** These operating

AQMD requirements for open top requirements are

(Continued) vapor cleaners: not stated in the

- when equipped with a Federal CTG.

lip exhaust system, the

exhaust fan shall be

off whenever the

cleaner is covered;

- if the inside length or

width of the cleaner is

equal to or greater

than 10 ft, the

workload area may

exceed half of the 

cleaner's open top area

provided the hoist

speed, while lowering

and raising parts, does

not exceed 1.7 m/min

(5.5 ft/min);

- at startup, the

refrigerated condenser

and freeboard chiller

shall be turned on

either simultaneously

or before the sump

heater is turned on. 

At shutdown, the pump

heater shall be turned

off, either heater 

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention

aspects of the rule.
C-65

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast simultaneously or

AQMD before the condenser

(Continued) water and refrigerated

chiller are turned off. 

The (hot) cleaner must

be covered whenever the

primary condenser is

turned off;

- the workload shall be

degreased in the vapor

zone until condensation

ceases.

 *

Section f.6 Conveyorized cleaners that The Federal CTG

have air-vapor or air- exempts any

solvent interface surface conveyorized (hot)

areas of more than 1 m , but cleaner with less 2

less than or equal to 2 m , than 2 m of air- 2

shall have either: vapor interface

- refrigerated freeboard from the

chillers, designed such requirement for a

that the refrigerant control device.

temperature at the

cleaner outlet does not

exceed 4.4 EC (40EF); or

- a carbon adsorption

system.

2

* This is an issue of applicability.
C-66

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section h Any person owning or X The South Coast

AQMD operating a carbon regulation provides

(Continued) adsorption system, in specific

association with any cleaner instructions on how

covered under this rule, the enclosure

shall meet the following should be

requirements: installed. The

- the system shall have a indicates that

hood or enclosure with carbon adsorption

a delivery system or systems controlling

ductwork designed to open top vapor

collect parts cleaner cleaners and 

emissions and to vent conveyorized nonthem to a carbon boiling cleaners

adsorption system with can achieve 60 and

a control efficiency of 65% emission

at least 90% in terms reduction,

of organic input to the respectively. In

bed; general, the South

- the output of the Coast regulation is

carbon adsorption more stringent than

system shall not be the CTG.

more than 25 ppm,

calculated as carbon.

Federal CTG
C-67

SOLVENT METAL CLEANING

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section l The provisions of this rule * These exemptions

AQMD shall not apply to: are not specified

(Concluded) in the Federal CTG.

- Cleaning solvents that

have a VOC content of

2% or less by volume,

based on the total

volume of the material

as used;

- Solvent cleaning

activities carried out

in batch-loaded cold

cleaners with open top

surface areas less than

0.1 m and solvent usage 2

less than 1 gal per

day; or

- Solvent blends that

contain less than 10%

VOC by volume.

* This is an applicability issue.
C-68

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime application, flashoff area, and oven 0.23 kg VOC/l of coating (1.9 lb b

VOC/gal of coating) [minus water]

Topcoat application, flashoff area, and oven 0.34 kg VOC/l of coating (2.8 lb

VOC/gal of coating) [minus water]

Final repair application, flashoff area, and oven 0.58 kg VOC/l of coating (4.8 lb c

VOC/gal of coating) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book).

The recommended emission limit is based on use of an electrophoretic system followed by b

a 25% solids waterborne "surfacer."

The recommended emission limit is based on use of organic-borne enamel with 35% solids. c

The Federal CTG provides another alternative to comply with RACT by installation of add-on

control devices. Incinerators and carbon adsorbers are the most applicable and preferred

devices for reducing VOC emissions. Incineration systems can achieve over 90% reduction

efficiency and carbon adsorption system can achieve over 85%.
C-69

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, A person shall not apply X This additional

Air Quality Rule 13, to any flexible part or requirement is not

Management Section 302 product subject to this specified in the

District rule any coating that has Federal CTG and

the following VOC content, should reduce the

unless emissions are emissions resulting

controlled by use of an from these

abatement device with processes.

control efficiency of at

least 90%. 

VOC emission limit for:

a) flexible primer is 0.49

kg/l (4.1 lb/gal),

excluding water;

b) color topcoat is 0.45

kg/l (3.8 lb/gal),

excluding water;

c) basecoat/clearcoat

(combined system) is 0.54

kg/l (4.5 lb/gal),

excluding water.
C-70

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, The VOC emission limit for X This additional

AQMD Rule 13, off-line coatings is 0.34 requirement is not

(Concluded) Section 308 kg/l (2.8 lb/gal) of specified in the

coating as applied, Federal CTG and will

excluding water, unless reduce air pollution

the emissions are resulting from such

controlled by use of an processes.

air pollution abatement

device with a control

efficiency of at least

90%.

South Coast Rule 1115, The VOC content of X The District

Air Quality Section b.1.A electrophoretic applied emission limit is

Management primer must meet a lower than that for

District standard of 0.145 kg/l primers stated in

(1.2 lb/gal), excluding the Federal CTG

water. (0.23 kg VOC/l or

1.9 lb VOC/gal

coating).
C-71

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1115, The District specifies X This requirement is

AQMD Section b.1.A emission standards for not specified in the

(Continued) primer surfacer (air Federal CTG. 

atomized and manual

spray), spray primer (air

atomized and automatic

spray), basecoat (air

atomized spray), and

clearcoat rigid coating by

manual electrostatic

method.

Section a The District specifies X The EPA "Blue Book"

certain transfer sets a baseline of

efficiencies for different 60% to determine

methods of coating final compliance. 

application. The guidance also

indicates that, in

most cases, use of

30% transfer

efficiency (TE) as

baseline for auto

surfacer and topcoat

waterborne

equivalence should

be accepted. The

District specified

TEs are higher than

the CTG.
C-72

SURFACE COATING OF AUTOMOBILES AND LIGHT-DUTY TRUCKS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section d Exemptions: * These exemptions are

AQMD a. Other coating not provided in the

(Concluded) operations not Federal CTG.

associated with

applying body primer

and topcoats to

exterior sheet metal

and body are exempt

from the requirements

of this regulation.

b. Wheel topcoat

applications, antirust coatings, trunk

coatings, interior

coatings, flexible

coatings, sealers and

deadeners, plastic

parts, and accent and

stripe coatings are

exempt from the

requirements of this

regulation.

c. Any house car

assembly line shall

not be required to

comply with this

rule.

* This is an applicability issue.
C-73

SURFACE COATING OF CANS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Sheet basecoat and over-varnish; two-piece can exterior 0.34 kg VOC/l of coating (2.8 lb

VOC/gal of coating) [minus water]

Two and three-piece can interior body spray, two-piece 0.51 kg VOC/l of coating (4.2 lb

can exterior end VOC/gal of coating) [minus water]

Three-piece can side-seam spray 0.66 kg VOC/l of coating (5.5 lb

VOC/gal of coating) [minus water]

End sealing compound 0.44 kg VOC/l of coating (3.7 lb

VOC/gal of coating) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as water a

according to EPA guidance (Blue Book).

For the few industries where stack gas treatment is a more feasible option, it may be

appropriate to state emission limits in terms of control efficiency across control devices,

such as incinerators or carbon adsorbers. Catalytic and non-catalytic incinerators and

carbon adsorbers are expected to achieve 90% reduction.
C-74

SURFACE COATING OF CANS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, Can Coating X The District emission

Air Quality Rule 11, - Sheet basecoat: 0.225 limits are lower than

Management Section 301 kg VOC/l (1.9 lb the limits stated in

District VOC/gal) of coating, the Federal CTG. 

excluding water.

- Two-piece can X The District emission

exterior basecoat and limits are lower than

overvarnish: 0.25 kg the limits stated in

VOC/l (2.1 lb the Federal CTG. 

VOC/gal) of coating,

excluding water.

South Coast Regulation XI, Can Coating 

Air Quality Rule 1125, - Three-piece base- X The District emission

Management Section b.1 coat: 0.225 kg VOC/l limit for three-piece

District (1.9 lb VOC/gal) of basecoat is lower than

coating, excluding the limit stated in

water. the Federal CTG.

- Two-piece exterior X The District emission

basecoat and limit for two-piece

overvarnish: 0.25 kg exterior basecoat and

VOC/l (2.1 lb overvarnish is lower

VOC/gal) of coating, than the limit stated

excluding water. in the Federal CTG. 
C-75

SURFACE COATING OF CANS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1125, Can Coating X The District emission

AQMD Section b.1 -Two-piece interior body limit is lower than

(Continued) spray: 0.44 kg VOC/l the limit stated in

(3.7 lb VOC/gal) of the Federal CTG. 

coating, excluding water. 

End Sealing Compound for X The Federal CTG sets

Non-Food Cans: 0 kg an emission limit for

VOC/l, excluding water end sealing compounds. 

(after March 1, 1991). However, it does not

distinguish between

food and non-food cans

as the District does. 

Therefore, the CTG

emission limit is

applicable to both

food and non-food

cans.

The District gives The Federal CTG does

emission limits for a) not specify these

drums, pails, and lids; limits.

and b) necker lubricants.

Section b.3 An approved air pollution X The Federal CTG

control device may be used specifies that control

to comply with the VOC devices are expected

emission limit for cans by to achieve 90%

reduction.
C-76

SURFACE COATING OF CANS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast reducing emissions by 95% X However, it does not

AQMD by mass and collecting at specify the required

(Concluded) least 90% by mass of capture efficiency. 

Section h.1 The provisions of this * The Federal CTG does

emissions generated by can The capture efficiency

coating operations. can be lower than that

 required by the South

rule shall not apply to not specify any

the spray coating of 1 gal exemptions. 

per day or less of

coatings at a single

facility.

Coast. Therefore, the

South Coast regulation

is considered more

stringent than the

Federal CTG.

* This is an issue of applicability. 
C-77

SURFACE COATING OF FABRICS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Fabric Coating Line 0.35 kg VOC/1 of coating (2.9

 lb VOC/gal of coating) [minus

water]

Vinyl Coating Line 0.45 kg VOC/1 of coating (3.8

lb VOC/gal of coating) [minus

water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book). 

The above limitations reflect use of an add-on control device where 90% of the VOC is

captured and delivered to the control device, which also must have a reduction efficiency

of 90%.
C-78

SURFACE COATING OF FABRICS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation Emission limit for a fabric X The District

Air Quality 8, Rule 12, coating line: 0.265 kg VOC/l emission limit

Management Section 301 (2.2 lb VOC/gal) of coating as for a fabric

District applied, excluding water. coating line is

Section 110 The rule exempts any fabric * The Federal CTG

coating line that emits less does not specify

than 6.5 kg (14.3 lb) of VOC any cutoff

per day. points.

lower than the

Federal CTG.

South Coast Regulation Emission limit for a fabric X The South Coast

Air Quality XI, coating process; 0.265 kg regulation has a

Management Rule 1128, VOC/l of coating, less water more stringent

District Section and exempt compounds, as emission limit

c.2.A applied, and applied with a and requires a

minimum transfer efficiency of higher transfer

95%. efficiency than

the Federal CTG. 

(The Blue Book

sets the

baseline

transfer

efficiency at

60%.)

* Relative stringency cannot be determined.
C-79

SURFACE COATING OF FABRICS

CA DISTRICT RACT RULES

(Continued) 

STATE REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section c.3 Plastisols applied to a fabric X The Federal CTG

AQMD must contain less than 0.20 kg does not set a

(Continued) of VOC/l of coating, less specific

water and exempt compounds, as emission limit. 

applied. The limit for

X

plastisol would

therefore be

0.35 kg VOC/l of

coating, less

water and exempt

compounds.

Section c.5 Wash primer applied to a Since a wash

fabric must contain less than primer is used

0.265 kg VOC/l of material in fabric

used. coating

operations, the

emission limit

would also be

0.35 kg VOC/l of

coating, less

water and exempt

compounds. 
C-80

SURFACE COATING OF FABRICS

CA DISTRICT RACT RULES

(Continued) 

STATE REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section c.8 A person shall not: ** These operating

AQMD a) use VOC-containing requirements are

(Continued) materials for the cleaning of not specified in

application equipment used in the Federal CTG. 

fabric coating operations,

excluding hand wiping, unless

85% of the VOCs are collected

and properly disposed of, or

the cleaning materials contain

15% or less by mass of VOC;

b) use other than closed

containers for disposal of

cloth or paper used for

surface preparation, cleaning,

or the removal of uncured

coatings that are impregnated

with solvent containing VOC;

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-81

SURFACE COATING OF FABRICS

CA DISTRICT RACT RULES

(Concluded)

STATE REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast c) use other than closed

AQMD containers for disposal of

(Concluded) cloth or paper used in

stripping cured coating, that

are impregnated with solvent

containing VOC.

Section d A person may comply with the X The Federal CTG

provisions by using an requires lower

emission control system for emission

reducing emissions consisting reduction (90%)

of collection and control than the South

devices that are approved, in Coast. 

writing, by the Executive Therefore, the

Officer and operated subject South Coast

to the following provisions: regulation is

a) collect at least 90%, by considered more

mass. stringent than

b) reduce emissions from an the CTG.

emission collection system by

at least 95%, by mass, or the

output of the control device

is 50 ppm, by volume,

calculated as carbon.
C-82

SURFACE COATING OF LARGE APPLIANCES

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime, single, or topcoat application area, flashoff 0.34 kg VOC/1 of coating (2.8 lb

area, and oven VOC/gal of coating) [minus water]

The Federal CTG states that the emission limit is based on use of low organic solvent

coatings containing at least 62 volume percent solids or any other waterborne equivalent. 

An equivalent reduction can also be achieved by use of add-on control devices such as

incinerators or carbon adsorbers which would result in approximately 80% (by mass)

reduction in VOC emissions over conventional organic-borne coatings which contain about

25 volume percent solids.

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book).
C-83

SURFACE COATING OF LARGE APPLIANCES

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation Emission limit for X The District

Air 8, Rule 14, baked coatings: 0.275 kg regulation requires a

Quality Section 302 VOC/l (2.3 lb VOC/gal) of lower emission limit

Management coating as applied, for baked coatings

District excluding water. An and requires a higher

equivalent reduction can abatement control

also be achieved using air efficiency than

pollution abatement specified in the

equipment with an Federal CTG.

efficiency of at least 85

percent.
C-84

SURFACE COATING OF METAL COILS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Prime and topcoat or single coat operation 0.31 kg VOC/l of coating (2.6 lb

VOC/gal of coating) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book).

Incinerators (thermal and catalytic), and waterborne and high-solids coatings are

feasible control options that reduce organic vapor emissions from coil coating lines. A

reduction of over 90% in organic emissions from a coil coating line is achievable using

either catalytic or thermal incineration. A reduction of 70 to 95% in organic emissions

is achievable using product substitution.
C-85

SURFACE COATING OF METAL COILS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation The emission limit for X The District

Air Quality 8, Rule 11, any coil coating regulation is more

Management Section 303 operation is 0.20 kg stringent than the

District VOC/l (1.7 lb VOC/gal) Federal CTG since

of coating, excluding its emission limit

water. is lower than the

one in the CTG.

South Coast Regulation The District emission X The District

Air Quality XI, limit for coil coating emission limit is

Area Rule 1125, is .20 kg VOC/l (1.7 lb lower than the

Management Section b.2 VOC/gal) of coating, limit stated in the

District less water and exempt Federal CTG.

compounds.

Section b.3 An approved air X The Federal CTG

pollution control device specifies that 90

may be used that reduces to 98% VOC emission

VOC emissions by 95% by reduction can be

mass and collects at achieved using

least 90% by mass of thermal

emissions generated by incineration, 90%

coil coating operations. using catalytic

incineration, and

70 to 95% using

product

substitution. The

CTG recommends

these devices for 

achieving emission

reductions,
C-86

SURFACE COATING OF METAL COILS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast but does not

AQMD specify a required

(Concluded) collection

efficiency. 

Therefore, the

District limits,

considering both

collection and

reduction

efficiency, are

considered more

stringent.

Section b.5 A person or facility The EPA "Blue Book"

shall not coat unless clarifies that a 

the coating is applied 60% default

with properly operating baseline TE is

equipment of one of the acceptable. The

following types: South Coast

electrostatic regulation requires

application, flow coat, a higher transfer

roll coat, dip coat, efficiency than

high-volume, low specified in EPA

pressure (HVLP) spray, guidance.

or hand application

methods or other coating

application methods

demonstrated to the

Executive Officer to be

capable of achieving at

least 65% transfer

efficiency.

SURFACE COATING OF METAL FURNITURE
C-87

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended limitationa

Metal Furniture Coating Line 0.36 kg VOC/l of coating (3 lb VOC/gal

coating) [minus water]

 The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

 water according to EPA guidance (Blue Book).

This emission limit can also be achieved by using waterborne coatings and is

approximately equivalent (on a solids applied basis) to use of an add-on control device

that collects or destroys about 80% of the solvent from a conventional high organic

solvent coating.
C-88

SURFACE COATING OF METAL FURNITURE

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, VOC emission limit for: X The District's

Air Rule 14, a) Baked coatings is 0.275 VOC emission

Quality Section 302 kg/l (2.3 lb/gal) of limit is lower

Management coating as applied, than the Federal

District excluding water. CTG.

b) Air-dried coatings is 0.34

kg/l (2.8 lb/gal) of

coating as applied,

excluding water.

Equivalent emission reduction

can also be achieved by X The Bay Area

abatement equipment with a requires a

control efficiency of at least slightly higher

85%. control

efficiency than

the Federal CTG

(85% vs 81%). 

Section 304 The District requires that the X The EPA "Blue

method used to apply a coating Book" clarifies

have a transfer efficiency (TE) that a 60%

of 65% or greater. default baseline

TE is

acceptable.
C-89

SURFACE COATING FOR INSULATION OF MAGNET WIRE

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Wire Coating Oven 0.2 kg VOC/l of coating (1.7 lb

VOC/gal of coating) [minus

water]

The Federal CTG states that the emission limit can be met with application of highsolids coatings having greater than 77 volume percent of solids, powder coatings, and

hot melt coatings. The emission limit can also be met with a waterborne coating that

contains 29 volume percent solids, 8 volume percent organic solvent, and 63 volume

percent water. The limit can also be met by a use of conventional coating, provided

that 90% emission reduction by incineration is achieved.

The CTG does not mention "exempt" solvents. a
C-90

SURFACE COATING FOR INSULATION OF MAGNET WIRE

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Regulation Exemptions: * The Federal CTG

Coast XI, 1. Magnet wire coating does not provide

Air Rule 1126, operations (not using any exemptions.

Quality Section aerosol containers)

Management that emit less than 1

District kg (2.2 lb) per hour,

but not more than 5

kg (11 lb) per day of

VOCs.

2. Coating of electrical

machinery and

equipment

subassemblies, such

as motor housings, is

exempt from the

standard.

3. Aerosol container

applications.

* This is an applicability issue.

 
C-91

SURFACE COATING OF PAPER

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Affected Units Recommended Limitationa

Paper Coating Line 0.35 kg VOC/1 of coating (2.9 lb

 VOC/gal of coating) [minus

water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated as a

water according to EPA guidance (Blue Book). 

This limit can be achieved in all cases using incinerators and in many cases with coatings

that contain low fractions of organic solvents. Both catalytic and thermal incinerators

can destroy 95% of the organic emissions introduced to them. Since the effectiveness of

the capture and containment system varies from plant to plant, the overall reduction in

the coating plant emissions may be less than 90%. 
C-92

SURFACE COATING OF PAPER

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation Emission limit for a paper X The District

Air Quality 8, Rule 12, coating line: 0.265 kg VOC/l emission limit for

Management Section 301 (2.2 lb VOC/gallon) of a paper coating

District coating as applied, line is lower than

Section 110 The rule exempts any paper * The Federal CTG

excluding water. the Federal CTG.

coating line that emits less does not specify

than 6.5 kg (14.3 lb) of VOC any exemptions.

per day.

South Coast Regulation Emission limit for a paper X The South Coast

Air Quality XI, coating process: 0.265 kg regulation has a

Management Rule 1128, VOC/l of coating, less water more stringent

District Section and exempt compounds, as emission limit and

c.2.A applied, and applied with a requires a higher

minimum transfer efficiency transfer efficiency

of 95%. than the Federal

CTG. (The EPA

"Blue Book" sets

the baseline

transfer efficiency

at 60%.)

* This is an applicability issue.
C-93

SURFACE COATING OF PAPER

CA DISTRICT RACT RULES

(Continued) 

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section c.3 Plastisols applied to paper X The Federal CTG

AQMD must contain less than 20 does not set an

(Continued) grams of VOC/l of coating, emission limit for

less water and exempt plastisol. 

compounds, as applied. However, since it

X

is used in paper

coating, the CTG

emission limit of

0.35 kg/l of

coating (minus

water) would apply.

Section c.5 Wash primer applied to paper The CTG emission

must contain less than 0.265 limit of 0.35 kg/l

kg VOC/l of material used. of coating (minus

water) would apply

for wash primers.
C-94

SURFACE COATING OF PAPER

CA DISTRICT RACT RULES

(Continued) 

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section c.8 A person shall not: ** These operating

AQMD a) use VOC-containing requirements are

(Continued) materials for the cleaning not provided in the

of application equipment Federal CTG. These

used in paper coating requirements will

operations, excluding hand result in reducing

wiping, unless 85% of the VOC emissions.

VOCs are collected and

properly disposed of; or the

materials used for cleaning

contains 15% or less by mass

of VOC.

b) use other than closed

containers for disposal of

cloth or paper used for

surface preparation,

cleaning, and the removal of

uncured coatings that are

impregnated with solvent

containing VOC.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-95

SURFACE COATING OF PAPER

CA DISTRICT RACT RULES

(Concluded) 

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast c)use other than closed

AQMD containers for disposal of

(Concluded) cloth or paper used in

stripping cured coatings 

impregnated with solvent

containing VOC.

Section d A person may comply with the X The Federal CTG

provisions by using an specifies a lower

emission control system for emission reduction

reducing emissions (90%) than the

consisting of collection and South Coast. 

control devices which are Therefore, the

approved, in writing, by the South Coast

Executive Officer and regulation is more

operated subject to the stringent than the

following provisions: CTG.

a) collect at least 90%, by

mass.

b) reduce emissions from

emission collection system

by at least 95%, by mass, or

the output of the control

device is 50 ppm, by volume,

calculated as carbon.

EXTERNAL FLOATING ROOF PETROLEUM TANKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG
C-96

This CTG is applicable to external floating roof tanks (EFRTs) larger than 150,000 liters

(40,000 gal) storing petroleum liquids with a true vapor pressure (TVP) greater than 10.5

kPa (1.5 psi). 

A continuous (rim mounted) secondary seal or equivalent closure must be installed on all

affected storage tanks, plus certain inspection and recordkeeping requirements, if the

tank is:

a) a welded EFRT, equipped with a primary metallic shoe or liquid-mounted seals, and the

TVP of the stored liquid is 27.6 kPa (4 psi) or greater;

b) a riveted EFRT, equipped with a primary metallic shoe or liquid-mounted seal and the

TVP of the stored liquid is 10.5 kPa (1.5 psi) or greater; or

c) a welded or riveted EFRT, equipped with primary vapor-mounted seal and the TVP of the

stored liquid is 10.5 kPa (1.5 psi) or greater.

Exemptions: 

1) EFRT with storage capacities less than 1,600,000 liters (420,000 gal) used to store

produced crude oil and condensate prior to custody transfer;

2) fixed-roof tanks with or without internal floating roofs, or small production tanks;

3) welded tanks with a primary metallic-type shoe seal which has a secondary seal from the

top of the shoe seal to the tank wall;

4) external floating roof tanks storing waxy, heavy pour crudes;
C-97

EXTERNAL FLOATING ROOF PETROLEUM TANKS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

________________________________________________________________________________________

Exemptions: (Concluded)

5) petroleum liquid storage vessels:

a) containing petroleum liquid with a TVP less than 10.5 kPa (1.5 psia), and

b) containing petroleum liquid with a TVP less than 27.6 kPa (4.0 psia) that are of

welded construction and presently possess a metallic-type shoe seal, a liquidmounted or liquid-filled type seal, or other approved closure device of

demonstrated equivalence; and

6) horizontal underground storage tanks storing JP-4 jet fuel. 

The seal closure devices shall meet the following requirements:

a. there shall be no visible holes, tears, or other openings in the seals or seal fabric.

b. the seal(s) must be intact and uniformly in place around the circumference of the

floating roof between the floating roof and the tank wall.

c. the area of gaps exceeding 0.32 cm (1/8 inch) in width between the secondary seal and

the tank wall shall not exceed 6.5 cm per 0.3 m of tank diameter (1.0 in per foot of 2 2

tank diameter). tank tank 
C-98

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, A person shall not store X The Bay Area

Air Quality Rule 5, organic liquid in any regulation has a

Management Section 304 storage tank with a lower cutoff level

District capacity greater than than the Federal

75,000 l (19,813 gal) CTG. Therefore,

unless such tank meets the more tanks will be

following conditions: subject to the rule.

1. Storage tanks with a

capacity greater than

75,000 l (19,813 gal)

but less than 150,000 l

(39,626 gal) storing an

organic liquid with a

true vapor pressure

(TVP) greater than 1.5

psia must meet the

requirement in Section

311.

2. Storage tanks with a

capacity of 150,000 l

(39,626 gal) or greater

storing an organic

liquid with a TVP

greater than 0.5 psia

must meet the

requirements of Section

311.

*

* More sources are subject to the rule.
C-99

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 311.3 An approved emission X The Federal CTG does

AQMD control system that not specify a

(Continued) collects and processes all required control

organic vapors and gases efficiency. 

and has an abatement However, it is

efficiency of at least 95% assumed that this

by mass. CTG would have been

worded in a similar

way to the CTG for

fixed-roof tanks. 

 Section 320 Floating roofs must meet ** These requirements

certain fitting are not specified in

requirements. the Federal CTG.

Section 321 The Bay Area provides ** The Federal CTG does

additional operating not specify any

conditions for tanks operating

equipped with primary seals conditions.

(metallic shoe type and

resilient-toroid seals).

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-100

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 322.5 For welded external X The Federal CTG

AQMD floating roofs with seals allows a larger seal

(Concluded) installed after September gap (0.125 in) than

4, 1985, no gap between the the Bay Area rule.

tank shell and the

secondary seal shall exceed

1.5 mm (0.06 in). The

cumulative length of all

secondary seal gaps

exceeding 0.5 mm (0.02 in)

shall not be more than 5%

of the circumference of the

tank, excluding gaps less

than 5 cm from vertical

weld seams.
C-101

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Regulation No person shall place, X The Federal CTG

Air Quality IV, store, or hold in any applies to external

Management Rule 463, stationary tank, reservoir, floating roof tanks

District Section b.1 or other container of larger than 150,000

150,000 l (39,630 gal) or liters storing

greater capacity, any petroleum liquids. 

organic liquid having true The South Coast

vapor pressure of 0.5 psi regulation has a

absolute or greater under lower vapor pressure

actual storage conditions, cutoff level for the

and in any above ground same size of tank

stationary tank or other than the CTG. 

above ground container of Therefore, the South

more than 75,000 l (19,815 Coast regulation is

gal) but less than 150,000 more stringent and

l (39,630 gal) capacity, it will apply to

any organic liquid having a more tanks than the

true vapor pressure of 1.5 CTG.

psi absolute or greater

under actual storage

conditions, unless such

tank is a pressure tank

maintaining working

pressures sufficient at all

times to prevent organic 

*

* The rule applies to more sources.
C-102

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast vapor loss, or is designed

AQMD and equipped with one of

(Continued) the following control

devices: 

Section For a closure device on a ** The Federal CTG does

b.1.B.i welded tank shell that uses not specify any gap

a metallic shoe-type seal requirement for the

as its primary seal: primary seal.

Gaps between the tank shell

and the primary seal shall

not exceed 3.8 cm for a

cumulative length of 10%,

1.3 cm for another 30%, and

0.32 cm for the remaining

60% of the circumference of

the tank. No continuous

gap greater than 0.32 cm

shall exceed 10% of the

circumference of the tank.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-103

EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.1.G Additional requirements: ** These additional

AQMD 1. All openings in the roof requirements are not

(Concluded) except pressure-vacuum specified in the

Section b.1.H 2. Any emergency roof shall ** This requirement is

valves, which shall be set Federal CTG.

to within 10% of the 

maximum allowable working 

pressure of the roof, shall 

provide a projection below 

the liquid surface to 

prevent belching of liquid 

and to prevent entrained or 

formed organic vapor from 

escaping. 

be provided with a slotted not found in the

membrane fabric cover, or Federal CTG.

equivalent, that covers at

least 90% of the area of

the opening.

Section b.4.e No crude oil containing in This prohibition is

excess of 70 ppm(m) of not found in the

hydrogen sulfide shall be Federal CTG.

stored in a floating roof

tank.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

GRAPHIC ARTS
C-104

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The Federal CTG RACT is applicable to packaging rotogravure, publication rotogravure, or

flexographic printing. The CTG does not address letterpress printing or offset

lithography. The rules apply to any packaging rotogravure, publication rotogravure, or

flexographic printing facility whose maximum theoretical emissions of VOC (including

solvents used to clean each of these printing presses) without control devices from all

printing presses are greater than or equal to 90.7 megagrams (100 tons) per year with

design capacity and 8,760 operating hours or maximum production (this cutoff is stated

in the "Blue Book"). The Federal CTG does not specify an emission limit for this

category. RACT is defined in terms of emission reduction efficiencies by application of

add-on control devices or by product substitution. The following are the specifications

stated in the Federal CTG:

1. RACT requires installation of the best practicable capture systems to assure that 

VOC is directed to the control device.

2. Publication rotogravure operations controlled by carbon adsorption systems can

achieve an overall reduction efficiency of 75%.

3. Packaging rotogravure presses operations controlled by either adsorption or

incineration systems can achieve an overall reduction efficiency of 65%.

4. Flexographic printing operations controlled by incineration systems can achieve an

overall reduction efficiency of 60%.

5. Waterborne inks achieving 70 volume percent overall reduction of solvent usage can be

considered equivalent to the exhaust treatment systems described above.

6. A waterborne ink whose volatile portion consists of 75 volume percent water and 25

volume percent organic solvent (or a lower VOC content) is considered equivalent to

the exhaust treatment systems.

7. It is recommended that inks containing 60% or more non-volatile material be exempt

from emission limitations.

8. The "Blue Book" adds an alternative emission limit 0.5 kg VOC/kg solids (0.5 lb

VOC/lb solids) on a per-line basis.
C-105

GRAPHIC ARTS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation A person shall not operate a X The District reAir Quality 8, Rule 20, publication gravure process quires higher

Management Section unless one or more of the overall control

District 301.1 following conditions is efficiency than

Section 2) emissions of VOC from the VOC/mass solids

301.2 printing and drying operation is 0.24 lb VOC/lb

satisfied: the Federal CTG. 

1) the process uses inks and The Bay Area

coatings that contain less equivalent

than 0.3 kg VOC/l of product, emission limit in

less water; or terms of mass

are controlled by an emission solids (see

control system that meets the discussion). 

requirements of Regulation 2, Therefore, the

Rule 1, and which has an Bay Area emission

overall collection and limit is more

control efficiency of at stringent than

least 85% on a mass basis. the one in the

CTG.
C-106

GRAPHIC ARTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation A person shall not operate a X The Federal CTG

AQMD 8, Rule 20, flexographic, gravure, does not provide

(Concluded) Section 302 letterpress, or lithographic emission limits

related printing or coating for coating

operation unless the adhesive and web

following conditions are met: splicing

1) content limit in terms of adhesive.

VOC per unit of product as

applied, less water for ink,

coating, adhesives, and web

splicing adhesive is 0.3 kg/l

(2.5 lb/gal). Effective

1/1/95, the limit for

adhesive will be reduced to

1.5 kg/l (1.25 lb/gal). 

2) content limit for fountain

solution is 15% VOC by mass

(effective 4/19/89), 10% VOC

by mass (effective 1/1/95),

and 8% VOC by mass (effective

1/1/97).
C-107

GRAPHIC ARTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1130, Effective January 1, 1991, a X Using the

Air Quality Section b.1 person shall not apply to procedure in

Management graphic arts substrates any Appendix F, the

District printing ink, including VOC- calculated

containing materials added to emission limit is

the original ink supplied by 0.2 lb VOC/lb

the manufacturer, that solids. 

contains total VOC in excess Therefore, it is

of 0.3 kg/l (2.5 lb/gal) of more stringent

coating, less water and than the Federal

exempt compounds. CTG. 

 

Section b.2 Effective January 1, 1991, a X This prohibition

person shall not use in any is not specified

graphic arts operation any in the Federal

fountain solution, including CTG.

VOC-containing materials

added to the original

fountain solution supplied by

the manufacturer, that

contains total VOC in excess

of 100 g/l (0.8 lb/gal) of

material.
C-108

GRAPHIC ARTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.3 A person shall not use VOC- X No solvent

AQMD containing materials for requirement is

(Continued) cleaning purposes unless such specified in the

material contains 0.2 kg or Federal CTG.

less of VOC per liter of

material or has a composite

vapor pressure of 45 mm Hg or

less at 20EC.

Section b.5 Owners and operators may X The Federal CTG

comply with the provisions by requires overall

using an approved VOC reduction effiemission control system ciencies for

consisting of collection and packaging

control devices approved by rotogravure and

the Executive Officer or his flexographic

printing of 65

and 60%,
C-109

GRAPHIC ARTS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast designee and which satisfy respectively. 

AQMD the following conditions: The South Coast

(Concluded) - the control device shall regulation

reduce emissions from an requires an

emission collection system overall reduction

by at least 95%, by mass; efficiency of

- the owner/operator shall 67%. Therefore,

demonstrate that the the South Coast

emission collection system regulation is

achieves at least 70%, by more stringent

mass, collection of the than the Federal

generated emissions; and CTG for these two

- the VOC content of the graphic arts

inks, adhesives, and/or operations.

coatings does not exceed

0.5 kg/l, less water and

exempt compounds.
C-110

LEAKS FROM PETROLEUM REFINERY EQUIPMENT 

 RACT EMISSION LIMIT AS DEFINED BY THE CTG

The owner or operator of a petroleum refinery complex shall develop and conduct a VOC

monitoring program as defined in the CTG. The recommended monitoring intervals are: 

annual (pump seals, pipeline valves in liquid service, and process drains); quarterly

(compressor seals, pipeline valves in gas service, and pressure relief valves in gas

service); weekly (visual inspection of pump seals), and no individual monitoring

(pipeline flanges and other connections, and pressure relief valves in liquid service).

Whenever a liquid leak from a pump seal is observed during the visual inspection and

whenever a relief valve vents to atmosphere, the operator must immediately monitor the

measured VOC concentration. If a leak (greater than 10,000 ppm) is detected, the leak

should be repaired within 15 days. The refinery operator should report quarterly leaks

that cannot be repaired in 15 days, and arrange for repairs to be made during the next

scheduled turnaround or, if unable to bring a component into compliance, apply for a

variance on an individual basis.

Three types of monitoring are mentioned; they include individual source monitoring, unit

walk-through monitoring, and multiple fixed-point monitoring. The CTG only details

individual source monitoring.
C-111

LEAKS FROM PETROLEUM REFINERY EQUIPMENT 

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, Effective January 1, 1993, X The Bay Area 

Air Quality Rule 18, any valve or connector definition of a leak

Management Section 302 that leaks in excess of is more stringent

District 500 ppm is in violation of than the Federal CTG

this rule unless a leak (500 ppm vs 10,000

discovered by the operator ppm). The Bay Area

has been minimized within also requires a

24 hours and repaired shorter timeframe for

within 7 days, or a leak repair of leaks.

discovered by the APCO has

been repaired within 24

hours. Effective January

1, 1997, the standard will

be reduced to 100 ppm.
C-112

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, Effective January 1, 1993, X The Bay Area

AQMD Rule 25, any pump or compressor definition of a leak

(Continued) Section 302 that leaks in excess of is more stringent

1,000 ppm is in violation than the Federal CTG

of this rule unless a leak (500 ppm vs 10,000

discovered by the operator ppm). The Bay Area

has been minimized within also requires leaks

24 hours and repaired to be repaired in a

within 7 days, or a leak shorter timeframe. 

discovered by the APCO has

been repaired within 24

hours. Effective January

1, 1997, the standard will

be reduced to 500 ppm. 
C-113

LEAKS FROM PETROLEUM REFINERY EQUIPMENT

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Rule 28, A person shall not use a ** The Federal CTG does

AQMD Section 301 pressure relief valve on not specify these

(Concluded) any equipment if the requirements.

concentration of organic

compounds, measured 1 cm

or less from any such

valve exceeds 10,000 ppm

(expressed as methane),

unless:

- the emission is vented

to a vapor recovery or

disposal system that is at

least 95% efficient, or

- the pressure relief

valve is protected by a

rupture disc, or

- the static upstream

pressure exceeds the

setpoint of the pressure

relief valve, or

- the pressure relief

valve leak has been

identified by the operator

and is minimized within 15

days and repaired at the

next scheduled turnaround.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
C-114

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Coating Category Recommended Limitationa

Air or forced air-dried items 0.42 kg VOC/l coating (3.5

 lb/gal) [minus water]

Clear Coat 0.52 kg VOC/l coating (4.3

lb/gal) [minus water]

No or infrequent color changes or small number of colors applied

1. Powder Coatings 0.05 kg VOC/l of coating

2. Other 0.36 kg VOC/l of coating

(0.4 lb/gal) [minus water]

(3.0 lb/gal) [minus water]

Outdoor, harsh exposure, or extreme performance char- 0.42 kg VOC/l of coating

acteristics (3.5 lb/gal) [minus water]

Frequent color changes, large number of colors app- 0.36 kg VOC/l of coating

lied, or first coat on untreated ferrous substrate (3.0 lb/gal) [minus water]

The CTG does not mention "exempt" solvents. However, exempt solvents are treated a

as water according to EPA guidance (Blue Book).
C-115

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Air Regulation Emission limit for air- X The District

Quality 8, Rule 19, dried coating: 0.34 kg emission limit

Management Section VOC/l (2.8 lb VOC/gal) of is lower than

District 302.2 coating as applied, the Federal

excluding water. CTG; therefore,

it is more

stringent.

South Coast Regulation The South Coast requires X The EPA "Blue

Air Quality XI, coating application Book" indicates

Management Rule 1107, methods (such as HVLP that a default

District Section b.1 spray) to be capable of baseline of 60% 

achieving at least transfer

65% transfer efficiency. efficiency is

X

acceptable for

miscellaneous

metal coating

operations.

Section b.2 Emission limit for air- The District's

dried items: 0.34 kg emission limit

VOC/l (2.8 lb/gal) of is lower than

coating, less water and the Federal

exempt solvents. CTG; therefore,

it is more

stringent.
C-116

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.2 In addition to this X The South Coast

AQMD emission limit, the South has more

(Continued) Coast has additional specific

emission limits for requirements

coatings that are not than the

specified in the Federal Federal CTG. 

CTG, such as: metallic, Also, more

extreme high-gloss, heat facilities are

resistant, solar subject to the

absorbent, etc. standards.

Section b.3 A person shall not use X This

VOC-containing materials requirement is

that have a VOC content not specified

of more than 200 grams/l in the Federal

of material for surface CTG.

preparation or cleanup,

excluding cleaning of

coating application

equipment.
C-117

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.4 VOC-containing materials X This

AQMD used for stripping any requirement is

(Continued) coating governed by this not specified

rule shall not contain in the Federal

more than 0.2 kg VOC/l of CTG.

material.

Section b.10 A person may apply to X These

metal parts and products additional

any coating used to match coating

the existing coating of requirements

motor vehicles (including are not

any VOC-containing specified in

materials added to the the Federal

original coating as CTG.

supplied by the

manufacturer) if such

coating does not contain

in excess of:

- 0.52 kg VOC/l of

coating, less water

and exempt solvents,

for general coatings;

or

- 0.6 kg VOC/l of

coating, less water

and exempt solvents,

for metallic coatings;

and 
C-118

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES 

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast provided that 

AQMD the person submits a

(Continued) written request to the

Executive Officer

demonstrating to the

Executive Officer's

satisfaction the need to

apply such coating and

the person receives from

the Executive Officer

written approval to use

the coating.
C-119

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.11 Owners and operators may X The "Blue Book"

AQMD comply with the emission indicates that

(Continued) limits stated in b.2 by the exhaust gas

using approved air treatment

pollution control should achieve

equipment, provided that at least 90%

the VOC emissions from reduction. No

such operations and capture

materials are reduced as efficiency is

follows: specified in

- the control device the Federal

shall reduce emissions CTG.

from an emission

collection system by

at least 95% by mass

or the output of the

air pollution control

device is 50 ppm by

volume, calculated as

carbon with no

dilution.

- the owner/operator

demonstrates that the

system collects at

least 90% by mass of

the generated

emissions.
C-120

SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section The provisions exempt a X The "Blue Book"

AQMD f.l.b facility that uses a clarifies that

(Concluded) total of less than 1 the Federal CTG

gallon of coating, exempts 3 lb

including any VOC- VOC/hr or 15

containing materials lb/day actual

added to the original emissions

coating as supplied by before add-on

the manufacturer, subject control. Using

to this rule, in any one an average VOC 

day, excluding aerosol density of 7.36

coatings from the gallon lb/gal, the

usage determination after calculated

1/1/92. cutoff point

*

specified in

the South Coast

regulation is

lower than the

CTG.

f.1.d and e Exempts pretreatment These

coatings and safety- exemptions are

indicating coatings. not specified

in the Federal

CTG. 

* This is an applicability issue.
C-121

PNEUMATIC RUBBER TIRE MANUFACTURING 

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

The CTG addresses four major operations (undertread cementing, tread end cementing, bead

preparation, and green tire spraying) within tire manufacturing. The following is a

summary of control technology for the four operations.

Affected Control Expected Control 

Unit System Capture Efficiency (%) Efficiency (%)

Undertread Carbon 65 - 85 95

cementing adsorption

Incineration 65 - 85 90

Tread-end Carbon 65 - 85 95

cementing adsorption

Incineration 65 - 85 90

Bead Carbon 75 - 85 95

dipping adsorption

Incineration 75 - 85 90

Green tire Water-based NA NA

spraying coating

Carbon 80 - 90 95

 adsorption 90

Incineration 80 - 90

Exemptions:

Production of specialty tires for "antique or other vehicles" when produced on an

irregular basis or with short production runs only if these tires are produced on

equipment separate from normal production lines for passenger type tires. (This exemption

is not specified in the CTG, but is described in the Blue Book.)
C-122

PNEUMATIC RUBBER TIRE MANUFACTURING

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation 8, A person shall not operate any X The Bay Area

Air Rule 21, undertread cementing, tread- requires higher

Quality Section 301 end cementing, or bead dipping collection and

Management operation unless they: 1) control

District install and operate an efficiencies than

Section 302 A person shall use only water- X The Bay Area

approved emission collection the Federal CTG. 

system (collects at least

85%); and 2) install and

operate a control device that

reduces emissions from the

collection system by at least

95% on a mass basis.

based coatings in green tire requires higher

coating operations unless collection and

they: 1) install and operate control

an emission collection system efficiencies than

that collects and transports the Federal CTG. 

to the control device at least

90% (on a mass basis) of the

VOC emitted; and 2) install

and operate a control device

which reduces emissions from

the collection system by at

least 95% on a mass basis.
D-123

SURFACE COATING OF FLAT WOOD PANELING

FEDERAL RACT EMISSION LIMITS AS DEFINED BY THE CTGa

1) Printed hardwood, plywood, and particleboard 2.9 kg SOLIDS BASIS

VOC/100 m 0.51 kg VOC/l 2 

or 6.0 lb (4.25 lb

VOC/1,000 VOC/gal solft (equi- ids) (assume 2

valent to 40% solids)

an average

coating

with a VOC

content of

0.20 kg/l

[1.7 lb

VOC/gal] -

[minus water])

b

2) Natural finished hardwood plywood 5.8 kg 0.73 kg VOC/l

VOC/100 m (6.0 lb 2

or 12.0 lb VOC/gal solVOC/1,000 ids) (assume

ft (equi- 55% solids) 2

valent to

an average

coating

with a VOC

content of

0.38 kg/l

[3.2 lb

VOC/gal]

[minus water])
SURFACE COATING OF FLAT WOOD PANELING

FEDERAL RACT EMISSION LIMITS AS DEFINED BY THE CTGa

(Concluded)

D-124

3) Class II finishes for hardboard paneling 4.8 kg 0.84 kg VOC/l

VOC/100 m (7.0 lb 2

or 10.0 lb VOC/gal solVOC/1,000 ids) (assume

ft (equi- 40% solids) 2

valent to

an average

coating

with a VOC

content of

0.32 kg/l

[2.7 lb

VOC/gal] 

[minus

water]) 

The CTG emission limit does not mention "exempt" solvents. However, exempt a

solvents are treated as water according to EPA guidance (Blue Book).

All assumptions are based on the values provided in the CTG. b
SURFACE COATING OF FLAT WOOD PANELING

FEDERAL RACT EMISSION LIMITS AS DEFINED BY THE CTGa

(Concluded)

D-125

SURFACE COATING OF FLAT WOOD PANELING 

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation Emission limit for wood flat X The

Air Quality 8, Rule 23, stock coatings: 0.25 kg VOC/l District's

Management Section 301 (2.1 lb/gal) coating used, emission

District excluding water. limit is

lower than

the Federal

CTG. 

South Coast Regulation Emission limit for wood flat X The

Air Quality 1104, stock coatings for wood District's

Management Section panels: 0.25 kg VOC/l (2.1 emission

District c.1.A lb/gal) of coating, less limit is

water and exempt compounds. lower than

X

the Federal

CTG.

Section c.4 Any person owning or The Federal

operating a control system, CTG does not

in association with a wood specify RACT

flat stock coating operation, for control

may comply by using an devices. It

approved system such that the states that

VOC emissions are reduced in afterburners

accordance with the following may achieve

provisions: over 90% 
D-126

SURFACE COATING OF FLAT WOOD PANELING 

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast a) the control device shall control of

AQMD reduce emissions from an the vapor

(Continued) emission collection captured, but

system by at least 95%, it does not

by mass, or the output specify an

of the air pollutant overall

control device is less control

than 50 ppm calculated system

as carbon; efficiency. 

b) the emission collection The South

system shall collect at Coast

least 90%, by mass, of requires a

the generated higher

emissions. minimum

control

efficiency

and an

overall

efficiency of

over 85%.
D-127

SYNTHESIZED PHARMACEUTICAL PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

 1. (a) For each vent from reactors, distillation operations, crystallizers, centrifuges, and vacuum dryers that emit 6.8 kg/day (15 lb/day) or more of VOC,

require surface condensers or equivalent controls.

 

(b) If surface condensers are used, the condenser outlet gas temperature should

not exceed:

(i) -25EC when condensing VOC of vapor pressure greater than 40 kPa (5.8

psi),*

(ii) -15EC when condensing VOC of vapor pressure greater than 20 kPa (2.9

psi),*

(iii) 0EC when condensing VOC of vapor pressure greater than 10 kPa (1.5

psi),*

(iv) 10EC when condensing VOC of vapor pressure greater than 7 kPa (1.0

psi), and *

(v) 25EC when condensing VOC of vapor pressure greater tan 3.5 kPa (0.5

psi).*

(c) Equivalent control results when emissions are reduced at least as much as they

would have been by using a surface condenser according to 1(b).

 

Vapor pressures as measured at 20EC. *

2. (a) For air dryers and production equipment exhaust systems that emit 150 kg/day

(330 lb/day) or more of VOC, require 90% emission reduction.

(b) For air dryers and production equipment exhaust systems that emit less than

150 kg/day (330 lb/day), require emission reduction to 15 kg/day (33 lb/day).
D-128

SYNTHESIZED PHARMACEUTICAL PRODUCTS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

(Concluded)

_______________________________________________________________________________________

3. (a) For storage tanks storing VOC with a vapor pressure greater than 28 kPa (4.1

psi) at 20EC, allow 1 liter of displaced vapor to be released to atmosphere

for every 10 liters transferred (i.e., a 90% effective vapor balance or

equivalent), on truck/rail car delivery to all tanks greater than 7,500 liters

(2,000 gal) capacity except where tanks are equipped with floating roofs,

vapor recovery, or equivalent. This guideline does not apply to transfer of

VOC from one in-plant location to another.

(b) For tanks storing VOC with a vapor pressure greater than 10 kPa (1.5 psi) at

20EC, require pressure/vacuum conservation vents set at + 0.2 kPa, except

where more effective air pollution control is used.

4. Enclose all centrifuges containing VOC, rotary vacuum filters processing liquid

containing VOC, and any other filters having an exposed liquid surface where the

liquid contains VOC. This applies to liquids exerting a total VOC vapor pressure of

3.5 kPa (0.5 psi) or more at 20EC.

5. All in-process tanks must have covers. Covers should be closed when possible.

6. For liquids containing VOC, all leaks in which liquid can be observed to be running

or dripping from vessels and equipment (for example: pumps, valves, flanges) should

be repaired as soon as is practical. 
D-129

SYNTHESIZED PHARMACEUTICAL PRODUCTS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Air Regulation 8, Any chemical X The Federal CTG

Quality Management Rule 24, sterilizer using does not

District Section 303 gaseous organic provide any

Section 302 A rotary vacuum filter X The Federal CTG

compounds shall not be specifications

operated unless for chemical

emissions of organic sterilizers.

compounds do not

exceed 15 kg (33 lb)

per day or such

emissions are reduced

by at least 75% on a

mass basis.

or any other filter or does not

separation device specify a VOC

having an exposed cutoff point.

liquid surface where

the liquid contains

organic compounds with

a combined vapor

pressure of 26 mm Hg

(0.5 psia) or more at

20EC (68EF), shall not

emit more than 15 kg

(33 lb) of organic

compounds per day

unless such emissions

are reduced by 90% on

a mass basis. are 
D-130

SYNTHESIZED PHARMACEUTICAL PRODUCTS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Regulation XI, An operator shall not X The Federal CTG

Air Quality Rule 1103, use centrifuges, requires that

Management District Section c.2 rotary vacuum filters, all centrifuges

or other filters, or and rotary

devices having an vacuum filters

exposed liquid surface processing VOCs

where the liquid be enclosed,

contains VOCs having a but does not

total vapor pressure specify use of

of 0.5 psi or more at a control

20EC unless such system to

devices incorporate a collect VOC

hood or enclosure with emissions.

a delivery system or

ductwork to collect

VOC emissions,

exhausting to a carbon

absorber or equivalent

control method

approved by the

Executive Officer.
D-131

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS 

RACT AS DEFINED BY THE CTG

This CTG applies to equipment in VOC service within a process unit in on-shore natural gas

processing plants. Natural gas processing plants are defined as facilities engaged in the

separation of natural gas liquids from field gas and/or fractionation of the liquids into

natural gas products, such as ethane, propane, butane, and natural gasoline. The

regulation affects only those pumps, compressors, valves, pressure relief devices, openended lines, flanges, and connections containing or contacting process streams with a VOC

concentration of 1.0 percent by mass or more.

A leak is defined as a VOC concentration greater than 10,000 ppm. Any leaking component

that has a VOC concentration over 10,000 ppm shall be tagged and repaired within 15 days

or at the next shutdown.

Affected facilities shall implement a leak detection and repair (LDAR) program. This

program will involve the use of a portable hydrocarbon detection device meeting the

specifications and performance criteria set forth in EPA Method 21 (40 CFR 60, appendix

A). Affected pumps, valves, compressors, and pressure relief devices shall be monitored

with a frequency interval of no less than quarterly. Difficult-to-monitor components (the

monitoring of which require the use of scaffolding or require monitoring personnel to be

elevated higher than 2 meters above permanent support) may be monitored with a frequency

of no less than annually. Any component that appears to be leaking on the basis of sight,

smell, or sound, including flanges and connections that need not be monitored regularly,

should be tagged for repair. Leaking components shall be repaired within 15 days from

detection of the leak; however, if repair is not technically feasible without shutting

down the process unit, repair may be delayed until the equipment can be isolated for

repair or during the next scheduled process unit turnaround.

Open-ended lines shall be controlled by installation of a cap, plug, flange, or second

valve on the open end of the line. 

Exempted:

1. Facilities that do not fractionate the mixed natural gas liquids and that have design

throughput less than 10 million standard cubic feet per day. 

2. Components operating under vacuum service and equipment at underground storage

facilities.
D-132

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay area Regulation A person shall not use any ** The Federal CTG does

Air Quality 8, Rule 37, valve, flange, choke, pump, not explain where the

Management Section 301 compressor, or component concentration should

District handling organic compounds be measured. The

in a natural gas or crude District requirement

oil production facility if is more specific and

the concentration of organic requires the leak

compounds, measured 1 cm detector to be placed

from any leak source in such 1 cm from any leak. 

equipment exceeds 10,000 ppm This, however, cannot

(expressed as methane), be used to compare

unless the following stringency. 

requirements are satisfied: The CTG requires all

a) if the equipment is not leaks greater than

essential, the leak shall be 10,000 ppm to be

repaired within 24 hours; repaired within 15

b) if the equipment is days or at next

essential, the leak shall be shutdown. The Bay

minimized within 24 hours; Area provides two

and timeframes for repair

based on the type of

leaking equipment. 

The Bay Area

regulation is

considered more

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
D-133

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area c) if the equipment leak specific in one case 

AQMD which has been minimized as (for nonessential

(Continued) required still exceeds the equipment) and less

limitations, that equipment specific in the other

shall be repaired at the case (for essential

next scheduled maintenance equipment).

of the well head. Any such

equipment shall not be

operated longer than 3

months before repairs are

conducted.

Section 302 There shall be no open ** This requirement is

liquid pools of crude oil or not specified in the

condensate in the lease Federal CTG.

area.

Section 303 No open or uncovered vessels ** This requirement is

of crude material larger not specified in the

than 250 ml shall be kept in Federal CTG.

the lease area. The well

cellar shall be kept

covered.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
D-134

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION STATE/LOCAL MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section 303 All spills of crude oil and ** This work practice

AQMD condensate that cause a requirement is not

(Concluded) liquid pool shall be cleaned specified in the

up within 24 hours. Federal CTG.

South Coast Regulation Operator inspection ** These additional

Air Quality XI, requirements requirements are not

Management Rule 1173, 1. All accessible pumps, specified in the

District Section e compressors, and Federal CTG.

pressure relief devices

shall be audio-visually

inspected once during

every 8-hour operating

period, except for

unmanned oil and gas

production fields, and

unmanned pipeline

transfer stations.

2. A pressure relief device

shall be inspected

within 14 calendar days

after every functional

pressure relief.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
D-135

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section f.1 A component shall be X The South Coast

AQMD repaired or replaced within regulation sets

(Continued) the following time period different time

after detection of a leak: periods for repairing

- Minor gas leak (in leaks. For any leak

excess of 1,000 ppm but with VOC

no more than 10,000 concentration over

ppm), 14 calendar days. 10,000 ppm, the South

- Major gas leak (in Coast requires the

excess of 10,000 ppm as leak to be repaired

methane), 5 calendar within 5 calendar

days. days instead of 15

- Gas leak >50,000 ppm, 1 days as stated in the

calendar day. Federal CTG. The

- Liquid leak, 1 calendar South Coast

day. regulation also

requires a shorter

time period for

repair for any gas

leak greater than

50,000 ppm or any

liquid leak.
D-136

EQUIPMENT LEAKS FROM NATURAL GAS/GASOLINE PROCESSING PLANTS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section f.2 The repaired or replaced ** This requirement is

AQMD component shall be subjected not specified in the

(Concluded) to operator inspection Federal CTG.

within 30 days of the repair

or replacement.

Section k The South Coast regulation * These exemptions are

states several exemptions not specified in the

from the provisions of the Federal CTG.

rule.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.

* This is an applicability issue.
D-137

LARGE PETROLEUM DRY CLEANERS

FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTG

Each owner or operator of a petroleum solvent dry cleaning facility that consumes 123,000

liters or more of petroleum solvent annually shall either:

(1) limit VOC emissions to the atmosphere to an average of 3.5 kg of VOC per 100 kg dry

mass of articles dry cleaned; or

(2) install and operate a solvent recovery dryer in a manner such that the dryer remains

closed and the recovery phase continues until a final recovered solvent flow rate of

50 milliliters per minute is attained.

Each owner or operator of a petroleum solvent dry cleaning facility with a solvent

filtration system shall either:

(1) reduce the VOC content in all filtration wastes to 1.0 kg or less per 100 kg dry mass

of articles dry cleaned, before disposal, and exposure to the atmosphere; or 

(2) install and operate a cartridge filtration system, and drain the filter cartridges in

their sealed housings for 8 hours or more before their removal.

Each owner or operator shall repair all petroleum solvent vapor and liquid leaks within 3

working days after identifying the sources of the leaks. If necessary repair parts are not

on hand, the owner or operator shall order these parts within 3 working days, and repair

the leaks no later than 3 working days following the arrival of the necessary parts.

No State regulations concerning large petroleum dry cleaners were provided through the Work

Group; however, New York State, Pennsylvania, and Texas laws were consulted and only

addressed perchloroethylene dry cleaners.
D-138

LARGE PETROLEUM DRY CLEANERS

CA DISTRICT RACT RULES

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Regulation A person shall not operate ** The Federal CTG

Air Quality 8, Rule 17, any petroleum dry cleaning indicates that leaks

Management Section 301 facility unless all of the should be repaired

District following requirements are within 3 days after

Section satisfied: identifying the 

301.1 - there is no solvent sources of the leaks. 

liquid or vapor leaking It does not state

from any portion of the that the system

equipment or the leaking should be shut down

equipment shall not be when a leak is deoperated. tected.

Section - Cartridge filters are X The Federal CTG

301.4 drained in the filter ho- requires that carusing for at least 12 tridge filters be

hours or placed in an en- drained in the filter

closed device including a housing for only 8

solvent recovery dryer hours before being

until dry before being discarded. The Disdiscarded. trict requires a

longer draining time;

therefore, the rule

is more stringent

than the CTG.

** Although this provision of the District's regulation may not necessarily result in a

quantifiable reduction in emissions, it does enhance the pollution prevention aspects

of the rule.
D-139

LARGE PETROLEUM DRY CLEANERS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area Section - Articles that have been * This is an additional

AQMD 301.6 cleaned must be transfer- requirement that is

(Continued) red to the dryer within 5 not specified in the

minutes after they are Federal CTG.

removed from the washer,

or shall be stored in

closed transfer carts.

Section A solvent recovery dryer X The Federal CTG does

302.2 that recovers at least 85% not specify the

of petroleum solvent by required control

mass shall be installed. efficiency of a

For the purpose of solvent recovery

determining compliance with dryer. In addition,

the 85% recovery the Federal CTG emisefficiency, 3 kg of sion limit for

petroleum solvent determining comemitted/100 kg dry mass of pliance is higher

articles cleaned shall be than the emission

deemed to be in compliance. limit stated in the

In addition, the petroleum Bay Area regulation. 

solvent flow rate from the Moreover, the rewater separator of the quired solvent flow

recovery dryer shall not rate from the water

exceed 15 separator of such a

milliliters/minute at the

termination of the recovery

cycle.

* This provision of the District's regulation involves work practices that will result in

quantifiable emission reductions.
D-140

LARGE PETROLEUM DRY CLEANERS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

Bay Area recovery dryer is

AQMD three times as much

(Concluded) as the flow rate reX

quired by the Bay

Area. Thus, the Bay

Area regulation is

more stringent than

the Federal CTG.

Section 303 A person shall not operate The Federal CTG

any solvent filtration specifies the same

system unless one of the requirements as the

following requirements is Bay Area. However,

satisfied: it does not provide

a) The total VOC content in an alternative emisall filtration wastes is sion limit in terms

reduced to: of mass of solvent

- 1 kg or less per 100 kg per mass of solvent

dry mass or articles still or filter

cleaned, before disposal waste. 

and exposure to the atmosphere, or

- no more than 0.25 kg of

solvent per kg of solvent

still or filter waste.

b) A cartridge filter

system is installed and

operated.
D-141

LARGE PETROLEUM DRY CLEANERS

CA DISTRICT RACT RULES

(Continued)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Rule 1102, The dry cleaning facility X The Federal CTG

Air Quality Section b.4 equipped with cartridge specifies only 8

Management filters containing paper or hours of draining

District carbon or a combination time.

thereof, are required to be

fully drained in the filter

housing for at least 12

hours before removal.

Section b.5 Articles which have been * This additional

dry cleaned are to be operating requirement

transferred to the dryer is not specified in

within 5 minutes after they the Federal CTG.

are removed from the washer, or are stored in closed

transfer carts.

* This provision of the District's regulation involves work practices that will result in

emission reductions.
D-142

LARGE PETROLEUM DRY CLEANERS

CA DISTRICT RACT RULES

(Concluded)

DISTRICT REGULATION DISTRICT MORE COMMENTS

NUMBER REQUIREMENTS STRINGENT?

South Coast Section b.7 The solvent recovery dryer X The Federal CTG

AQMD shall remain closed and the specifies similar

(Concluded) recovery phase shall requirements for

continue until there is no solvent recovery

visible flow in the sight dryers, but it allows

glass of the condenser for opening of the dryer

at least 1 minute or until when a solvent flow

a final recorded flow rate rate of 50 ml/min is

of 15 ml/min is attained. attained.
E-1

APPENDIX E.

ESTIMATING THE AMOUNT OF

THINNING SOLVENT ALLOWED
 M. Serageldin, EPA, to Project File. Procedure for Determining Nonvolatiles (Solids), Equivalent

Paint VOC or VOHAP Limits, and Allowed Amount of Thinning Solvent - NESHAP for Shipbuilding

and Ship Repair Facilities (Surface Coating), June 30, 1994. (Docket No. A-92-11, Document No. II-B26).

 The terms "nonvolatiles" and "solids" are used 6

interchangeably to refer to the film forming material of a

coating.

 An 'exempt' compound (solvent) is an organic compound that 7

would be considered a VOC if it were not classified by EPA as

having negligible photochemical reactivity. These compounds are

listed in 40 CFR 51.100(s).

E-2

APPENDIX E5

DETERMINING THE AMOUNT OF THINNING SOLVENT ALLOWED

This may be achieved in two steps:

1. Estimating volume of nonvolatile matter (solids) - Part A.

2. Calculating the volume of thinning solvent allowed - Part B. 

 

The allowed amount of thinning solvent is any volume that is less

than the thinner volume calculated based on the given equation. 

The equation can be represented in graphical form and used for

rapidly estimating thinning allowances pertaining to a VOC emission

limitation. The curve in Figure E.1 was generated assuming that

the VOC limit is 571 g/L of nonvolatiles (solids) , the thinning 6

solvent density is 1,200 g/L, and the solvent is 100% VOCs. 

A procedure for converting an emission limit from one set of units

to another is also illustrated: 

from mass of volatiles/unit volume of coating or mass of

volatiles/unit volume of coating (less water and

'exempt' solvents) 7

to mass of volatiles per volume of nonvolatile matter

(solids) in a coating.
VNV (L)

1 L coating

' 1 &

Vvoc (L)

L coating

VNV ( by vol.) ' 1 &

Vvoc (L)

L coating

E-3

E.3

 Part A

ESTIMATING VOLUME OF NONVOLATILE MATTER (SOLIDS)

 The amount of film forming material or nonvolatiles (solids) in

a coating is usually calculated from formulation data. Some paint

companies, however, report the percentage of nonvolatiles using

methods which are based on those developed by ASTM (American

Society for Testing and Materials). Since there is presently no

approved EPA method for measuring the amount of film forming

material, the discussion will focus only on the procedure for

calculating what may be termed the theoretical volume of

nonvolatiles (solids).

CASE 1: Coatings containing no exempt solvents or water

An example calculation (in standard international units) follows

for a coating where the volatiles are all VOCs:

 Coating volume (Liter) = VNV (Liter) + VVOC (Liter) E.1 

where VNV stands for volume of nonvolatile matter and VVOC for volume

of volatile organic compounds, VOCs. In the above representation,

it is assumed that the volumes of the different components in a

coating are additive, which is not necessarily true.

Basis 1 Liter of coating:

VNV (L) = 1 (L coating) - VVOC (L) E.2

Divide by total liters of coating:
VNV ( by vol.) ' 1 &

VOC content of coating (g VOC/L coating)

average density of solvents (g VOC/L VOC)

VNV ( vol.) ' 1 &

340 g VOC

L coating x

1 L VOC

839 g VOC

VNV ( vol.) ' 1 & .405 ' 0.595 ( 59.5 percent)

340 g VOC /L coating

0.595 L NV /L coating

E-4

If the average density of the VOCs in this paint is 839 g/L, and

the VOC content is 340 g VOC/L, then:

The VOC content in terms of nonvolatiles is:

which is equal to 571 g VOC/L of nonvolatiles.

CASE 2. Coatings containing VOC, water, and exempt compounds

To calculate the ratio of VOCs to nonvolatiles (solids) in a

coating, the facility has to account for the volume of water and

'exempt' compounds in determining the volume of nonvolatiles

(solids). We therefore need to rewrite equation E.2 as follows:

VNV = 1 - [VVOC + Vex + Vw] E.4

where:

VVOC = VOC volume (fraction) in the coating as supplied

(L VOC/L of coating);

Vex = 'exempt' solvent volume (fraction) in the coating as

supplied (L exempt solvents/L of coating);

Vw = water volume (fraction) in the coating as supplied 

(L water/L of coating).

NOTE: Cure volatiles (those released due to chemical reactions in
E-5

some coating films) will be dealt with at the end of this document.

Example:

If a coating having a VOC content of 208 g/L is made up of three

volatile components [25% (vol.) VOC solvent, 10% (vol.) 'exempt'

solvent, and 15% (vol.) water], one can determine the nonvolatile

volume to 3 significant figures as follows: 

VNV = 1 - [0.250 + 0.100 + 0.150] = 0.500 L (50.0 percent)

The VOC content of this paint can be expressed in several ways:

o 208 g VOC/L of coating

o (208/0.750) or 277 g VOC/L of coating less water and exempt 

solvents

o (208/0.500) or 416 g VOC/L of nonvolatiles (solids).

 
mVOC1

VNV1

'

MVOC2 % aDth Vth

VNV2

Vth '

1

a D

MVOC1

VNV1

VNV2 & MVOC2

E-6

E.5

E.6

Part B

CALCULATION OF THINNING ALLOWED

Paint manufacturers or users add solvents to modify the flowing

properties of a coating. To determine the amount of thinning

solvent allowed, the user should know how much VOC is already in

the coating and the emission limit for that coating category. To

be in compliance, the total mass of VOCs in a coating must be less

than that set by the appropriate limit as indicated by the first

ratio in equation E.5.

One can rewrite equation E.5 to determine Vth, 

where:

Vth = maximum volume of thinner permitted, L/L of

coating;

a = the volume fraction of VOCs in the thinner, equal

to 1 if 100% VOC; 

Dth = average density of thinning solvent (thinner),

g/L solvent; 

m = mass of VOCs in the coating, g/L coating;

VOC = volatile organic compound; 

VNV = volume of nonvolatiles (solids), L/L coating;

 VOC1/VNV1 = mass of VOC in limiting coating over 

 volume of nonvolatiles, g/L.

The subscript 1 stands for the limits of a compliant coating and 2

for the as-supplied coating (paint received from the paint

manufacturer) that needs to be thinned before application. The

maximum amount of thinner allowed should be less than Vth determined
E-7

above for a given coating limit. 

Scenario: Coating does not contain water, exempt solvents,

or cure volatiles

Problem: The user needs to determine the maximum amount of

solvent thinner that can be added to a coating. The VOC content of

the coating is 300 g/L of coating and the average density of the

VOC portion is 850 g/L of solvent. The thinner has a density of

900 g/L. Assume that the VOC limit for a coating category in a

rule is 340 g VOC/L of coating (minus water and exempt solvents);

this is equivalent to 571 g VOC/L of nonvolatiles (see Part A, CASE

1). 

Solution Steps:

1. Record the applicable limit for the coating category: 571 g

VOC/L of nonvolatiles. 

 

2. Record the mass of VOC in a liter of coating: 300 g VOC/L of 

coating (minus water and exempt solvents). 

3. Calculate the (theoretical) volume of nonvolatiles VNV2 using 

equation E.3. 

 VNV2 = 1 - (VOC) 

 = 1 - 0.353

 = 0.647 L/L coating.

4. Record the density of thinning solvent Dth and the fraction 

 of VOC in the thinner: Dth= 900 g/L and a = 0.8.

5. Determine Vth using equation E.6. 
Vth '

1

(0.8) (900)

(

571 g VOC

1 L NV1

)( 0.647 L NV2) & (300 g VOC2)

Vth '0.096 L thinner/L of coating.

Vth '

1

a Dth

mVOC1

1 LNV1

VNV2 & mVOC2 & mc

E-8

E.7

As a rule, the amount of thinning that is allowed for a

coating decreases with an increase in solvent density. Figure E.1

provides a rapid method for estimating the amount of thinning that

is allowed. For a coating with the same VOC content as in the

previous example (300 g/L of coating), the volume of thinner when

Dth= 900 g/L is around 0.08 L of thinner/L coating. 

General Equation:

where, as given before Vth is the maximum volume of thinner

permitted, L/L coating; a is the volume fraction of VOCs in the

thinner, equal to 1 if 100% VOC; Dth is the average density of

thinning solvent (thinner), g/L solvent; m is the mass of VOCs in

the coating, g/L coating; VOC = volatile organic compound; VNV is

the volume of nonvolatiles (solids), L/L coating; and VOC1/VNV1 is

the mass of VOC in limiting coating over volume of 2nonvolatiles,

g/L. The term mc stands for mass of cure volatiles that are VOCs

(e.g., formaldehyde). When a coating does not release cure

volatiles, mc should be deleted from equation E.7. The maximum

amount of thinner added should be less than Vth determined above for

a given coating limit. 
E-9

 

Figure E.1. Estimating Maximum Thinning Allowance

 (NOTE: This figure applies when all the volatiles in

the coating are VOCs. The av. density of the

volatiles in a coating was assumed equal to 840 g
E-10

solvent/L solvent. 
F-1

APPENDIX F.

CONVERTING EMISSION LIMIT UNITS FROM MASS VOC/VOL COATING 

TO MASS VOC/MASS SOLIDS (NONVOLATILES) IN COATING
0.3 kg VOC

L coating

(

2.20 lb

1 kg

(

3.78 L

1 gal coating '

2.49 1b VOC

l gal coating

F-2

APPENDIX F

CONVERTING EMISSION LIMIT UNITS FROM MASS VOC/VOL COATING

TO MASS VOC/MASS SOLIDS (NONVOLATILES) IN COATING

Some of the rules reviewed presented their emission limits as

VOC per unit mass of solids (nonvolatiles), whereas the VOC limits

in these CTGs were presented in terms of coating volume. To

compare these rules, the CTG limits were converted into these

alternate limits using the steps outlined in the example below. 

Given: 

Emission limit: 0.3 kg VOC/L of coating (minus water and 

exempt solvents), VOC density: 883 g/L (7.36 lb VOC/gal) of

solvent, assuming all volatiles are VOCs. 

 

Solution Steps:

To perform this conversion, one needs to know the density of

the solids (nonvolatiles) in the coating. Assume the density of

nonvolatiles is 16 lb solids/gal solids.

Step 1: Convert the units of the emission limit to

 lb VOC/gal coating.
0.660 lb VOC

1 gal coating

(

1 gal VOC

7.36 lb VOC

'

0.339 gal VOC

1 gal coating

F-3

Step 2: Calculate volume of VOCs in a gallon.

Step 3: Determine the nonvolatiles volume. 

 

The theoretical nonvolatiles volume can be 

 calculated using equation E.3 (Appendix E).

 Basis 1 gallon of coating: 

1 gal coating - VVOC = VNV 
1 gal coating

0.661 gal solids

(

1 gal solids

16 lb solids

(

2.49 lb VOC

1 gal coating

'

0.236 lb VOC

1 lb solids

F-4

VNV = 1 - 0.339 = 0.661 gal solids/gal coating

Step 4: Calculate lb VOC/lb solids.
G-1

APPENDIX G.

EPA VOC POLICY WORK GROUP
G-2

Anne Arnold Paul Truchan

U.S. EPA Region I U.S. EPA Region II

Room 2203 Room 1005

JFK Federal Building 26 Federal Plaza

Boston, MA 02203-2211 New York, NY 10278

Phone: (617) 565-3166 Phone: (212) 264-2518

FAX: (617) 565-4939 FAX: (212) 264-7613

Lisa Wild Cynthia Stahl

U.S. EPA Region III U.S. EPA Region III (3AM10)

Air Enforcement Branch Air Programs Branch

841 Chestnut Building 841 Chestnut Building

Philadelphia, PA 19107 Philadelphia, PA 19107

Phone: (215) 597-9318 Phone: (215) 597-9337

FAX: (215) 597-7906 FAX: (215) 597-7906

Diane Altsman Steve Rosenthal

U.S. EPA Region IV U.S. EPA Region V (5AR-26)

Air Programs Branch Air & Radiation Branch

345 Courtland Street, NE 77 West Jackson Street

Atlanta, GA 30365 Chicago, IL 60604

Phone: (404) 347-2864 Phone: (312) 886-6052

FAX: (404) 347-5246 FAX: (312) 886-5824

Guy Donaldson Joshua Tapp

U.S. EPA Region VI U.S. EPA Region VII

Suite 1200 Air Branch

1445 Ross Avenue 726 Minnesota Avenue

Dallas, TX 75202-2733 Kansas City, KS 66101

Phone: (214) 655-7242 Phone: (913) 551-7606

FAX: (214) 655-2164 FAX: (913) 551-7065

Tim Russ Dave Hodges

U.S. EPA Region VIII (8ART-AP) U.S. EPA Region IX

999 18th Street Air Programs Branch (A-2-3)

Denver Place, Suite 500 75 Hawthorne Street

Denver, CO 80202-2405 San Francisco, CA 94105

Phone: (303) 293-1814 Phone: (415) 744-1197

FAX: (303) 293-1229 FAX: (415) 744-1076
G-3

Chris James Christine Lee

U.S. EPA Region X U.S. EPA Region X (AT-092)

Air & Radiation Branch (AT-092) Air & Radiation Branch

1200 Sixth Avenue 1200 Sixth Avenue

Seattle, WA 98101 Seattle, WA 98101

Phone: (206) 553-1194 Phone: (206) 553-1814

FAX: (206) 553-0110 FAX: (206) 553-0110
H-1

APPENDIX H.

LIST OF GROUPS I, II, AND III CTGs
H-2

Group I CTGs (Pre-1978)

1. Control of Volatile Organic Compounds from Use of Cutback

Asphalt. EPA-450/2-77-037. U.S. EPA, OAQPS. December 1977. 

OAQPS No. 1.2-090.

2. Control of Volatile Organic Emissions from Storage of

Petroleum Liquids in Fixed-Roof Tanks. EPA-450/2-77-036. 

U.S. EPA, OAQPS. December 1977. OAQPS No. 1.2-089.

3. Control of Volatile Organic Emissions from Bulk Gasoline

Plants. EPA-450/2-77-035. U.S. EPA, OAQPS. December 1977. 

OAQPS No. 1.2-085.

4. Control of Hydrocarbons from Tank Truck Gasoline Loading

Terminals. EPA-450/2-77-026. U.S. EPA, OAQPS. October 1977. 

OAQPS No. 1.2-082.

5. Control of Refinery Vacuum Producing Systems, Wastewater

Separators and Process Unit Turnarounds. EPA-450/2-77-025. 

U.S. EPA, OAQPS. October 1977. OAQPS No. 1.2-081.

6. Design Criteria for Stage I Vapor Control Systems--Gasoline

Service Stations. U.S. EPA, OAQPS. November 1975. (Design

Criteria Document.)

7. Control of Volatile Organic Emissions from Solvent Metal

Cleaning. EPA-450/2-77-022. U.S. EPA, OAQPS. November 1977.

8. Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume II: Surface Coating of Cans, Coils, Paper,

Fabrics, Automobiles, and Light-Duty Trucks. EPA-450/2-77-

008. U.S. EPA, OAQPS. May 1977. OAQPS No. 1.2-073.

9. Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume V: Surface Coating of Large Appliances. 

EPA-450/2-77-034. U.S. EPA, OAQPS. December 1977. OAQPS No.

1.2-088.

10. Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume III: Surface Coating of Metal Furniture. 

EPA-450/2-77-032. U.S. EPA, OAQPS. December 1977. OAQPS No.

1.2-086.

11. Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume IV: Surface Coating of Insulation for Magnet

Wire. EPA-450/2-77-033. U.S. EPA, OAQPS. December 1977. 

OAQPS No. 1.2-087.
H-3

Group II CTGs (1978)

1. Control of Volatile Organic Emissions from Petroleum Liquid

Storage in External Floating Roof Tanks. EPA-450/2-78-047. 

U.S. EPA, OAQPS. December 1978. OAQPS No. 1.2-116.

2. Control of Volatile Organic Compound Leaks from Gasoline Tank

Trucks and Vapor Collection Systems. EPA-450/2-78/051. U.S.

EPA, OAQPS. December 1978. OAQPS No. 1.2-119.

3. Control of Volatile Organic Compounds from Existing Stationary

Sources - Volume VIII: Graphic Arts - Rotogravure and

Flexography. EPA-450/2-78-033. U.S. EPA, OAQPS. December

1978. OAQPS No. 1.2-109.

4. Control of Volatile Organic Leaks from Petroleum Refinery

Equipment. EPA-450/2-78-036. U.S. EPA, OAQPS. June 1978. 

OAQPS No. 1.2-111.

5. Control of Volatile Organic Emissions from Existing Stationary

Sources - Volume VI: Surface Coating of Miscellaneous Metal

Parts and Products. EPA-450/2-78-015. U.S. EPA, OAQPS. June

1978. OAQPS No. 1.2-101.

6. Control of Volatile Organic Emissions from Manufacture of

Pneumatic Rubber Tires. EPA-450/2-78-030. U.S. EPA, OAQPS. 

December 1978. OAQPS No. 1.2-106.

7. Control of Organic Emissions from Existing Stationary Sources

- Volume VII: Factory Surface Coating of Flat Wood Paneling. 

EPA-450/2-78-032. U.S. EPA, OAQPS. June 1978. OAQPS No.

1.2-112.

8. Control of Volatile Organic Emissions from Manufacture of

Synthesized Pharmaceutical Products. EPA-450/2-78-029. U.S.

EPA, OAQPS. December 1978. OAQPS No. 1.2-105.

Group III CTGs (Post-1978)

1. Control Volatile Organic Compound Emissions from Air Oxidation

Processes in Synthetic Chemical Manufacturing Industry. EPA450/3-84-015. U.S. EPA, OAQPS. December 1984.

2. Control of Volatile Organic Compound Equipment Leaks from

Natural Gas/Gasoline Processing Plants. EPA-450/3-83-007. 

U.S. EPA, OAQPS. December 1983.
H-4

Group III CTGs (Concluded)

3. Control of Volatile Organic Compound Emissions from Large

Petroleum Dry Cleaners. EPA-450/3-82-009. U.S. EPA, OAQPS. 

September 1982.

4. Control of Volatile Organic Compound Emissions from

Manufacture of High-Density Polyethylene, Polypropylene, and

Polystyrene Resins. EPA-450/3-83-008. U.S. EPA, OAQPS. 

November 1983.

5. Control of Volatile Organic Compound Leaks from Synthetic

Organic Chemical and Polymer Manufacturing Equipment. EPA450/3-83-006. U.S. EPA, OAQPS. March 1984.
H-5

TECHNICAL REPORT DATA

(Please read Instructions on reverse before completing)

1. REPORT NO. 2. 3. RECIPIENT'S ACCESSION NO.

 EPA-453/R-95-

010

4. TITLE AND SUBTITLE 5. REPORT DATE

 BEYOND VOC RACT CTG REQUIREMENTS 

 April 1994

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S) 

8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.

 Pacific Environmental Services, Inc.

 Central Park West

 5001 South Miami Boulevard

 PO Box 12077

 Research Triangle Park, NC 27709-2077

 

11. CONTRACT/GRANT NO.

68-D1-0116

 

12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED

 Director

 Office of Air Quality Planning and

Standards

 Office of Air and Radiation

 U.S. Environmental Protection Agency

 Research Triangle Park, NC 27711

Final

14. SPONSORING AGENCY CODE

EPA/200/04

15. SUPPLEMENTARY NOTES

 EPA Project Manager: Mohamed Serageldin, Ph.D. (919) 541-

2379

16. ABSTRACT

This document contains a comparison of State (and local) and

Distict regulations with control techniques guideline (CTG)

source categories. The purpose was to identify those State

regulations that exceed the reasonably available control

technology (RACT) requirements that are specified in the Federal

CTGs. This study is limited to CTG groups I, II, and III only,

which cover 28 source categories. 

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI

Field/Group

Air Pollution, Summary of VOC, CTG, 

State and District Air RACT Review

Regulations, Comparison of Stringency

State Regulations with Pollution Prevention,

Federal Control Technique Regulations, Rules

Guidelines (CTGs) 

18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (Report) 21. NO. OF PAGES

 Release Unlimited Unclassified 346

20. SECURITY CLASS (Page) 22. PRICE

 Unclassified
H-6

EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE