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 27711April 1995

Page left blank for productionEPA-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 27711iv 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 4.10Surface Coating of Fabrics

.......... . 4-12 4.11Surface Coating of Large Appliances

..... . 4-14 4.12Surface Coating of Metal Coils

........ . 4-15 4.13Surface Coating of Metal Furniture

...... . 4-16 4.14Surface Coating of Magnet Wire

........ . 4-17 4.15Surface Coating of Paper

........... . 4-18 4.16External Floating Roof Petroleum Tanks

.... . 4-19 4.17Gasoline Tank Truck and Vapor Collection System Leaks

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

................. . 4-20 4.19Leaks from Petroleum Refinery Equipment

... . 4-22 4.20Surface Coating of Miscellaneous Metal Parts and Products

................. . 4-24 4.21Pneumatic Rubber Tire Manufacturing

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

.... . 4-25 4.23Synthesized Pharmaceutical Products

..... . 4-26 4.24Air Oxidation Processes - SOCMI

....... . 4-27 4.25Equipment Leaks from Natural Gas/Gasoline Processing Plants

............ . 4-28 4.26Large Petroleum Dry Cleaners

......... . 4-29 4.27Polymer Manufacturing

............ . 4-30 4.28SOCMI 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-1viii 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-1ix 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-91-1 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 rulesthat 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, 19871-2

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 theBNA Environment Reporter.However, due to time constraints and limited resources, a comprehensive review of all of the State VOC regulations contained in theEnvironment Reporterwas 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 CTG1-4

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: thestringencyof the rule and the applicabilityof the rule. If a rule appeared more attractive from apollution preventionperspective (as discussed in Chapter 3), it was not classified as more stringent than the Federal CTG unless the reductions werequantifiable. 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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 AQMDTABLE 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. aState/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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 TexasTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 AQMDTABLE 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. aState/District rule provides quantifiable additional reduction relative to CTG. bState/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 theEnvironment 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 aquantifiableextra 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 an2-3

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 addition3-2

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

4.1Cutback 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 not4-2

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. 4.2Fixed-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 control4-3

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. 4.3Gasoline 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 averagedailythroughput 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 Texas4-4

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. 4.4Gasoline 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. 4.5Miscellaneous 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 of4-6

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. 4.6Stage 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 reducing4-7

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. 4.7Solvent 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 for4-8

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 mof 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 to4-9

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. 4.8Surface 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 of4-10

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. Theaveraged valueof 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 anhourly basis or on the basis ofhourly 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 an4-11

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. 4.9Surface Coating of Cans The Federal CTG defines RACT limits for four coating categories: sheet base coat and over-varnish and two piece canexterior; 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 anhourly 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 to4-12

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. 4.10Surface 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 volume4-13

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 anhourly basisor thehourly 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. 4.11Surface 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 anhourlybasisor 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 CTG4-15

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.

4.12Surface 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 onan 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.

4.13Surface 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 onan 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 encourages4-17

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. 4.14Surface 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 reductioneach 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 requirements4-18

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. 4.15Surface 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 anhourlyemission reduction or anhourly 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 toallpaper 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 for4-19

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.

4.16External 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 more4-20

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. 4.17Gasoline 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). 4.18Graphic Arts4-21

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 anhourlybasis 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 coatings4-22

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. 4.19Leaks 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 for4-24

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. 4.20Surface 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, and4-25

then the CTG. 4.21Pneumatic 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 ofat least85 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. 4.22Surface 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. 4.23Synthesized 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 regulations4-27

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. 4.24Air 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. Several4-28

State regulations (Texas, Pennsylvania, Rhode Island, and Colorado) were consulted, but no State regulations pertaining to this category were located. 4.25Equipment 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 measurethe 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 beminimizedwithin 24 hours and if the leak persists and exceeds a concentration of 10,000 ppm, the equipment is to be4-29

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. 4.26Large 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 cartridge4-30

filters to be drained in the filter housing for at least12 hours before removal. The CTG is less stringent than the Bay Area or the South Coast regulation since it requires only8 hoursof 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. 4.27Polymer 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 an4-31

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. 4.28SOCMI 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 Booksuggests 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-37A-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 CTGA-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 loadedA-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 vaporA-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 settingof 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 nothave 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-59A-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 theefficiency 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 requiredunder 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 CTGA-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-74A-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 poundsper 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 (2.8lb/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 dailyweightedaverage 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 hourfrom 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 interiorbody 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 sealingA-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 interiorbody 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-128A-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 appliedeach hourfrom 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-135A-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 thepurpose 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 ofsolids 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, appliedeach hourfrom 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 moreaccurate 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 beingdischarged directly or indirectly into the outdoor atmosphere; or b) the operations result in an hourly VOC emission rate nogreater 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 performingresearch, 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 VOCemission 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, andhot 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 awater 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 formulationscontaining 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 performingresearch, 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 thesurface 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 gallonof 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 CATEGORIES1B-2 EXTERNAL FLOATING ROOF PETROLEUM TANKS FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTGB-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; andB-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 ofwelded 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 PETROLEUMTANKS

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, cmper meter of tank inch), so the Federal R307-1- diameter (1.0 inchper 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 ppm.]

vB-11 GRAPHIC ARTS FEDERAL RACT EMISSION LIMIT AS DEFINED BY THE CTGB-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 BookB-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 applicabilityB-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.AB-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 immediatelymonitor 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, orfirst 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 iffewer 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

nPNEUMATIC 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, AirQuality 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 theminimum 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

mor 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 mor 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). bB-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 AirQuality 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 mof 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 mof coated 2 surface (12.0 lb/1,000 ft) natural finish 2 hardwood plywood panels.

- 4.8 kg/100 mof 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 remainclosed 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

- 25EC 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-76This 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 CATEGORIES2C-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. Theprovisions 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 necessaryafter 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 CTGC-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-9C-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. aC-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 theC-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 Booksuggests 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.

Xa 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. aC-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)

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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

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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)

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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)

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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)

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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)

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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, orC-34 BULK PLANTS CA DISTRICT RACT RULES (Concluded)

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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

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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.
X Regulation A person shall not allow 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)

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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)

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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 onlytrucks, 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)

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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

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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)

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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)

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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)

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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.

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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)

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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

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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)

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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)

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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 mof air/vapor interface should be 2 exempted from the requirement for a major control device. 2. Open top parts cleaners with less than 1 mof 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

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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)

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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)

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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.
X Section Cold cleaners shall not 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)

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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)

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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)

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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.
X Section d.3 Batch-loaded cold cleaners 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)

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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)

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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 mof 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 4.4EC (40EF); or

- a carbon adsorption system. 2

* This is an issue of applicability.C-66 SOLVENT METAL CLEANING CA DISTRICT RACT RULES (Continued)

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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 CTGC-67 SOLVENT METAL CLEANING CA DISTRICT RACT RULES (Concluded)

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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 mand 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

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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)

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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

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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.
X Section a The District specifies 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

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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 topcoatapplications, 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

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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)

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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.
X End Sealing Compound for 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)

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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

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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)

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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)

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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)

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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.
X Section d A person may comply with the 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

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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

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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.
X Section b.3 An approved air 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)

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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 FURNITUREC-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

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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. aC-90 SURFACE COATING FOR INSULATION OF MAGNET WIRE

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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

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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)

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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.
X Section d A person may comply with the 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 CTGC-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 ofwelded 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 cmper 0.3 m of tank diameter (1.0 inper foot of 2 2 tank diameter). tank tankC-98 EXTERNAL FLOATING ROOF PETROLEUM TANKS

CA DISTRICT RACT RULES

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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)

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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)

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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)

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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 ARTSC-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.

X Section b.2 Effective January 1, 1991, a 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.

X Section b.5 Owners and operators may 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)

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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

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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)

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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)

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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 aas water according to EPA guidance (Blue Book).C-115 SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS CA DISTRICT RACT RULES

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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.
X Section b.3 A person shall not use 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)

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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.
X Section b.10 A person may apply to 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; andC-118 SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS CA DISTRICT RACT RULES (Continued)

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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)

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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

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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. bSURFACE 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

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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. areD-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. Theregulation 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.
X Section

- Cartridge filters are The Federal CTG 301.4 drained in the filter ho- requires that carusing for at least12 tridge filters be hoursor 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.
X Section A solvent recovery dryer 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 ALLOWEDM. 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 coatingormass 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) = V(Liter) + V (Liter) E.1 NV VOC

where Vstands for volume of nonvolatile matter and V for volume

NV VOC 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:

V(L) = 1 (L coating) - V (L) E.2 NV VOC Divide by total liters of coating:VNV( by vol.) ' 1

& VOC content of coating (g VOC/L coating) averagedensityof solvents (g VOC/L VOC)

VNV( vol.) ' 1

& 340 g VOC

L coatingx 1 L VOC

839 g VOC

VNV( vol.) ' 1

&.405 '0.595( 59.5 percent)

340g VOC/L coating 0.595L 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:

V= 1 - [V + V+ V] E.4 NV VOC ex w

where: V = VOC volume (fraction) in the coating as supplied VOC (L VOC/L of coating); V= 'exempt' solvent volume (fraction) in the coating as ex supplied (L exempt solvents/L of coating); V= water volume (fraction) in the coating as supplied w (L water/L of coating). NOTE: Cure volatiles (those released due to chemical reactions inE-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:

V= 1 - [0.250 + 0.100 + 0.150] = 0.500 L (50.0 percent) NV
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 V NV1 ' M

VOC2%aDthVth V NV2

Vth' 1 a D M

VOC1 V NV1 V

NV2&M

VOC2

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 V , th where: V = maximum volume of thinner permitted, L/L of th coating;

a = the volume fraction of VOCs in the thinner, equal

to 1 if 100% VOC; D = average density of thinning solvent (thinner), th g/L solvent;

m = mass of VOCs in the coating, g/L coating; VOC = volatile organic compound; V = volume of nonvolatiles (solids), L/L coating; NV VOC1/V = mass of VOC in limiting coating over NV1 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 Vdetermined thE-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 V using NV2 equation E.3.

V = 1 - (VOC) NV2 = 1 - 0.353 = 0.647 L/L coating.

4. Record the density of thinning solvent D and the fraction th of VOC in the thinner: D = 900 g/L and a = 0.8. th

5. Determine Vusing equation E.6. th

### Vth

### ' 1

(0.8)(900) (571 g VOC

1 L NV1 )( 0.647 L NV2)

&(300 g VOC2)

Vth'0.096L thinner/L of coating

.

Vth' 1 a Dth mVOC1 1LNV1V

NV2&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 D = 900 g/L is around 0.08 L of thinner/L coating. th
General Equation:

where, as given before Vis the maximum volume of thinner th permitted, L/L coating; a is the volume fraction of VOCs in the thinner, equal to 1 if 100% VOC; D is the average density of th thinning solvent (thinner), g/L solvent; m is the mass of VOCs in the coating, g/L coating; VOC = volatile organic compound; Vis NV the volume of nonvolatiles (solids), L/L coating; and VOC1/V is NV1 the mass of VOC in limiting coating over volume of 2nonvolatiles, g/L. The term mstands for mass of cure volatiles that are VOCs c (e.g., formaldehyde). When a coating does not release cure volatiles, mshould be deleted from equation E.7. The maximum c amount of thinner added should be less than Vdetermined above for th 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 gE-10

solvent/L solvent.F-1 APPENDIX F.

CONVERTING EMISSION LIMIT UNITS FROM MASS VOC/VOL COATING TO MASS VOC/MASS SOLIDS (NONVOLATILES) IN COATING0.3kg VOC

L coating ( 2.20lb

1kg ( 3.78L

1gal 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 unitmassof solids (nonvolatiles), whereas the VOC limits in these CTGs were presented in terms of coatingvolume. 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.0.660lb VOC

1gal coating( 1gal VOC

7.36lb VOC' 0.339gal VOC

1gal 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 - V = V VOC NV1gal coating 0.661gal solids ( 1gal solids 16lb solids ( 2.49lb VOC

1gal coating

' 0.236lb VOC 1lb solids

F-4 V= 1 - 0.339 = 0.661 gal solids/gal coating NV

Step 4: Calculate lb VOC/lb solids.G-1 APPENDIX G.
EPA VOC POLICY WORK GROUPG-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) 744-1076G-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) 553-0110H-1 APPENDIX H. LIST OF GROUPS I, II, AND III CTGsH-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 OxidationProcesses 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 SyntheticOrganic 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 UnclassifiedH-6 EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE