Final Se ction 6
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**SECTION 6 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)**  **6.1 Purpose of Section**  This Section addresses the requirements for 8
- hour ozone standard nonattainment areas with respect to Reasonabl y Available Control Technology (RACT). MassDEP certifies that all RACT measures adopted and in effect in Massachusetts pursuant to the 1
- hour ozone standard continue to constitute RACT under the 8
- hour ozone standard for all large point sources subject to RACT and for all source categories subject to RACT, except the fo llowing categories: solvent metal degreasing; gasoline dispensing vapor control; and asphalt paving. For these three categories, MassDEP has concluded that RACT measures previously adopted no longer constitute RACT and either has promulgated, or is committ ing to promulgate, revised regulations that will further reduce emissions from these three source categories. For the category of Municipal Waste Combustors, MassDEP intends to conduct additional anal ys is as to whether existing NOx controls on this category still constitute RACT. Massachusetts RACT source categories and large point sources are listed in Tables 1
- 3 at the end of this Section. **6.2 Overview of 1**  **- Hour Ozone Standard RACT**  **6.2.1 Pre**  **- 1990 VOC RACT Requirements**  Prior to the 1990 CAA Amendments, RACT requirements were governed by CAA Section 172(c), which provides that non
- attainment areas must implement ... “all reasonabl y available control measures [RACM]...including such reductions in emissions from existing sources in the area as m ay

be obtained through the adoption ... of reasonabl y available control technology [RACT].” EPA has defined RACT as the lowest emission limit that a polluting source is capable of meeting if it uses pollution control equipment and/or material or process c hanges that are reasonabl y available considering costs and current technology . (44 FR 53762, September 17, 1979) To assist states with implementation of RACT, EPA issued Control Technique Guidelines (CTGs) for various source categories of VOC emissions. 1 CTGs establish a ``presumptive norm'' for RACT for the VOC source category addressed. Some CTGs cover onl y major2 sources of VOC emissions. Other CTGs apply at thresholds below the major source level. In addition, states were required to adopt RACT controls for all major sources of VOCs, whether or not within a CTG source category
. **6.2.2 1990 CAA Amendments** 

1 . Prior to the 1990 CAA Amendments, EPA issued three sets of CTG documents: Group 1: 15 CTGs issued before January 1978; Group 2: 9 CTGs issued i n 1978; and Group III: 5 CTGs issued in the early 1980s. (A list of all CTGs, as compiled by EPA, is in Table RACT
- 1.) 2 . The emission threshold for a major source varies. P rior to the 1990 CAA Amendments, major VOC sources were those with a potential to emit > 100 tons of VOCs per year. After the 1990 Clear Air Act amendments, major source thresholds for VOC and NOx were tied to a non
- attainment areas classification and whether the state is located within an ozone transport region.Final Se ction 6
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The 1990 CAA Amendments made the general Section 172 RACT requirements more specific. Amendments to section 182(a)(2)(A) required that ozone non
- attainment areas classified as marginal or above “fix” any deficient VOC RACT rules by May 1991. A new provision, Section 182(f), required states to adopt RACT for all major stationary NOx sources. Amendments to Section 184, which addresses control of ozon e in an Ozone Transport Region, 3 lowered the major source applicability threshold of RACT for states within the OTR from sources with a potential to emit 100 tons of VOC per ye ar to sources with a potential to emit 50 tons per y ear. To assist states with NOx RACT implementation, EPA issued Alternative Control Technology Documents (ACTs), which provide analy ses of the reductions that can be achieved with various controls at various levels of stringency , and the costs per ton to achieve those levels of contr ol. Unlike CTGs, ACTs do not establish a presumptive RACT level of control. **6.2.3 Massachusetts 1**  **- Hour RACT**  **Compliance** During the late 1970s and the 1980s, MassDEP adopted and from time
- to - time amended 310 CMR 7.18
- Volatile and Halogenated Organic Compounds and 310 CMR 7.24
- Organic Material Storage and Distribution . These regulations established emissions controls on VOC sources consistent with EPA’s pre
- 1990 CTGs. EPA approved these regulations as meeting RACT and incorporated them into the Mass achusetts ozone SIP. 4 The CTGs issued by

EPA and the MassDEP regulation that was adopted to meet the presumptive level of RACT established in the CTG for RACT is listed in Table RACT
- 1. If there were no facilities within a CTG source category in the State, MassDEP submitted a “negative declaration” to EPA. The negative declarations are also listed in Table RACT 1. For major sources not within a CTG category , 3 10 CMR 7.18(17) provided for imposition of RACT controls through single
- source RACT SIPs. Pursuant to this provision MassDEP determined what constituted RACT on a facilit y - by
- facilit y basis for non
- CTG major sources. EPA approved these single
- source RACT determinations as part of the Massachusetts SIP; the facilities subject to single
- source RACT are listed in Table RACT
- 2. To meet the 1990 CAA Amendment requirements, in 1991 MassDEP submitted SIP revisions to 310 CMR 7.18 to correct RACT SIP deficiencies concerning automobile and metal parts coating and other minor deficiencies id entified b y EPA. In 1992, MassDEP amended its regulations to incorporate the lower RACT major source threshold of =>50 tons of VOC per year (vs. 100 tons). To address the 1990 CAA NOx RACT requirement, MassDEP adopted 310 CMR 7.19, Reasonably Available Control Technology (RACT) for Sources of Oxides of Nitrogen (NOx), which established RACT for large, medium and small boilers; stationary combustion turbines;
3 The Northeast Ozone Transport Region (OTR) c om prises Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey , New York, Pennsylvania, Rhode Island, Vermont, and northern Virginia. The OTC w as created under the CAA to ad dress ozone transport issues within the OTR. 4 See 40 CFR 52.1167 for a complete list of the EPA
- approved Massachusetts SIP revisions, including those related to RACT regulations and determinations.Final Se ction 6
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stationary reciprocating internal combustion engines; and glass melting furnaces. 310 CMR 7.19(1 2) provided for single source NOx RACT determinations for major “miscellaneous” NOx source **s** with a potential to emit 50 tons or more per y ear of NOx. EPA approved the Massachusetts NOx RACT controls requirements, although Massachusetts NOx RACT regulation s were in some cases adopted prior to issuance of EPA’s ACTs and therefore were not based on EPA’s ACT analy sis. Massachusetts has no outstanding 1
- hour requirements to revise an y existing RACT rules nor are there unresolved issues with respect to an y Mas sachusetts 1
- hour RACT determinations and SI P submittals. It has fully

complied with all 1
- hour RACT requirements. **6.2.4 Results of 1**  **- Hour RACT Implementation in Massachusetts**  Pursuant to MassDEP RACT regulations, Massachusetts sources subject to RACT substantially reduced their emissions of VOCs and NOx. These reductions are dramatic in the stationary point source sector 5 , as illustrated in Figure RACT
- 1 below. As a result of the significant emissions reductions that have already been achieved in Massachuse tts by large industrial sources, there are few, if an y, cost - effective opportunities for sources to adopt an y RACT controls that will further reduce VOC and NOx emissions. Between 1980 and 1987, VOC emissions from Massachusetts major VOC sources decrease d from an estimated 192 tons per summer day in 1980 to 80 tons per summer day in 1987. (See Massachusetts Demonstration of Reasonable Further Progress, Ozone SIP, 1987 , submitted September 1988, page 14, Table III
- 5; numbers have been converted from kilogr ams per y ear as reported in that SIP to tons per summer day .) VOC emissions from point sources continued to decrease during the 1990s. The 2002 MA Base Year Inventory

(Section 2) includes the following trends data for stationary point source 6 VOC emission s: **Figure RACT -**  **1 Massachusetts Stationary Point Source VOC Emissions Trends** 

Tons per summer day Tons per year 1990 64 17,324 1993 61 19,165 1996 43 11,580 1999 28 9,831 2002 16 5,647

5 . “Stationary point sources” is a term used for emiss ions inventory purposes; it refers to all facilities that report actual emissions of 10 tons per year or more of VOC. 6 . The universe of sources subject to VOC RACT is not identical to the universe of sources included in the stationary point source secto r of the 2002 inventory because some CTG/RACT categories also cover smaller area source.Final Se ction 6
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Massachusetts stationary

point sources thus emit 48 TPSD f ewer of VOCs (75% less) in 2002 than in 1990 based on these estimates. As a result of the significant emission reductions that have taken place due to RACT regulations, as well as due to plant closures, point sources account for just 2% of total in
- state anthropogenic VOC emissions, as shown in the following Figure RACT
- 2 taken from the 2002 MA Base Year Inventory
.

With the adoption of NOx RACT re gulations and the promulgation, in 1999, of MassDEP regulation 310 CMR 7.28, NOx Allowance Trading Program (NOx Budget Program
- see discussion in Section 3, Control Measures ), major NOx sources have significantly reduced emissions. The following data from the 2002 MA Base Year Inventory illustrates the amount of reductions. **Figure RACT -**  **3 Massachusetts Stationary Point Source NOx Emissions Trends** 

Tons per summer day Tons per year 1990 318.1 115,752 1993 297.7 92,876 1996 171 56,883 1999 180 60,27 2 2002 129.6 45,590 Massachusetts stationary

point sources 7 emit 188 TPSD fewer (60% less) NOx in 2002 than in 1990 based on these estimates. As a result of the significant emission reductions that have taken
7 As noted in footnote 5, this sector includes facilities with actual emissions over 10 tons per year NOx as reported annually by the facilities. **Figure RACT -**  **2 Massachusetts 2002 VOC Emissions by Source Sector**  **2002 VOCs** Tons per year

(TPY) TPY % of

total VOC inventory Tons per

summer day (TPSD) TPSD % of

total VOC inventory **Stationary Point**  **5,647 2%**  **16 2%**  Stationary Area 159,753 57% 328 46% On
- Road Mobile 57,186 21% 152 21% Off
- Road Mobile 56,577 20% 224 31% Total 279,163 100% 719 100%Final Se ction 6
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place due RACT regulations as well as plant closures, point sources now account for onl y 17.1% of total in
- state NOx emissions on an annual basis and 16.9 % on a tons per summer day basis as shown in Figure RACT
- 4. **Figure RACT -**  **4 Massachusetts 2002 NOx Emissions by Source Sector**  **2002 NOx** Tons per year

(TPY) TPY % of

Inventory Tons per

summer day (TPSD) TPSD % of

Inventory **Stationary Point**  45,590 17.1% 129.6 16.9% Stationary area 34,371 12.9% 39.1 5.1% On
- Road Mobile 143,368 53.9% 453.1 59.1% Off
- Road Mobile 42,906 16.1% 144.5 18.9% TOTA L 266,235 100% 766.3 100%

**6.3 8**  **- Hour Ozone Standard RACT Requirements**  **6.3.1 Required Analysis**  With respect to RACT, EPA’s Phase 2 Rule provides: Where a State has adopted, and EPA has approved, a control measure as RACT for a specific major st ationary

source or source category for the 1
- hour ozone NAAQS and absent data indicating that the previous RACT determination is no longer appropriate, the State may submit a certification that the source is subject to a SIP
- approved RACT requirement (70 F R 71652). Subsequent to the issuance of the Phase 2 Rule, EPA developed questions and answers (Q&A) to further explain 8
- hour ozone standard RACT SI P requirements. The Q&A document states that in order for a state to certify that previously

required RACT controls or newly applied controls represent RACT for 8
- hour ozone standard purposes, a state should evaluate RACT for a source or source category

by examining EPA guidance and other information. When a state concludes that the existing level of control i s RACT and that no control is required bey ond what was required for the 1
- hour standard, it must submit its conclusions in its RACT SI P. The state may

address RACT through adoption of rules, submission of permits or through negative declarations stating that there are no sources subject to RACT. If the state determines that additional controls are needed to meet 8
- hour ozone standard RACT requirements, the controls must be made federall y enforceable through a SIP revision. Any new RACTFinal Se ction 6
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requirements mus t be implemented no later than May 1, 2009. Pursuant to EPA’s Phase 2 Rule, Massachusetts was required to submit a SI P addressing 8
- hour ozone RACT requirements within 29 months of EPA’s April 15, 2004 non
- attainment areas designation. **6.3.2 Applicable**  **Thresholds** As noted previousl y, after the 1990 CAA Amendments, the applicable EPA major source thresholds for RACT in Massachusetts as a “serious” 1
- hour non
- attainment area were 50 tons per year for both VOCs and NOx. 8 As a “moderate” 8
- hour non
- attai nment area the applicable EPA RACT thresholds for Massachusetts are 50 tons per year for VOC and 100 tons per year for NOx. EPA revoked the 1
- hour standard as of June 15, 2005; therefore, the 1
- hour classification scheme and corresponding EPA RACT thre sholds no longer appl y. However, under EPA’s anti
backsliding requirements (40 CFR 51.905) a state may not remove RACT requirements for sources that were subject to 1
- hour standard RACT, even if they would not be subject to RACT under the non
- attainment area’s 8
- hour classification and applicable RACT threshold. Thus, any source subject to NOx RACT because of the 50
- ton per y ear threshold will continue to be subject to applicable regulations and existing permit conditions based on this threshold. Howeve r, pursuant to EPA’s Phase 2 Implementation Rule, a state is only required to certify

that RACT under the 8
- hour ozone standard is met for those non
- CTG sources that EPA defines as major under the 8
- hour ozone standard “moderate” classification (100 tons p er year of NOx and 50 tons per y ear of VOCs). Table RACT
- 2 indicates which Massachusetts sources are major under these EPA thresholds. As required b y the Phase 2 Rule, MassDEP has reviewed its current RACT requirements. It has determined that VOC contr ols previously adopted as RACT for CTG source categories and non
CTG major sources still constitute RACT for 8
- hour ozone standard purposes, except for four categories
- solvent metal degreasing, gasoline dispensing vapor control, asphalt paving and Munici pal Waste Combustor (MWCs). For the first three categories, MassDEP is adopting tighter regulations; for MWCs it will conduct additional analy sis to determine if existing NOx controls on this category

still constitute RACT. It has also determined that RACT controls adopted for major sources of NOx (100 tons per y ear) continue to constitute RACT. MassDEP has, therefore, certified in Tables RACT
- 1 and RACT
- 2 that its current RACT controls meet 8
- hour RACT requirements, except for the categories of solv ent metal degreasing, gasoline dispensing vapor control and asphalt paving. MassDEP is committing to revise its regulations for these three categories. **6.4 VOC RACT Analysis** 

8 . In general, RACT applicability is based on a source’s potential to emit

– i.e., uncontrolled emissions. However, under certain circumstances a source may not be subject to RACT if it has a federally enforceable restriction on the emission level or on its hours of oper ation, emission rate and throughput, that limit its potential to emit to below the RACT applicability threshold.Final Se ction 6
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**6.4.1 CTGs**  As noted under the 1
- hour RACT discussion, a state regulation impos ing VOC controls that met EPA’s presumptive CTG control levels met 1
- hour RACT requirements. Table RACT
- 1 lists the VOC source categories for which EPA issued CTGs and the existing MassDEP RACT regulation for each of these categories. MassDEP regulations that imposed VOC RACT requirements are 310 CMR 7.18
- Volatile and Halogenated Organic Compounds and 310 CMR 7.24
- Organic Material Storage and Distribution. For all CTG categories, these MassDEP regulations either incorporated the CTG recommended contr ols or achieved reductions equivalent to the CTG controls and were approved by EPA for 1
- hour RACT purposes. MassDEP has reviewed 310 CMR 7.18 and 310 CMR 7.24 to determine if the levels of control required b y these regulations continue to constitute VOC RACT under the 8
- hour ozone standard for sources covered b y C TGs. It has determined that the current regulations governing emissions from CTG source categories constitute RACT, except for the three categories noted above and discussed below under “RACT R evisions for 8
- Hour Ozone Standard.” Pursuant to the requirement of the Phase 2 Rule, MassDEP certifies in Table RACT
- 1 for each category that current RACT control meets 8
- hour RACT. The CTG categories for which MassDEP submitted negative declaratio ns stating that it did not have sources within a CTG category are also listed in Table RACT
- 1. MassDEP has reviewed its 2002 stationary

point source inventory

by reviewing its point source database for facilities with North American Industrial Classificat ion Sy stem (NAICS) codes that correspond to the CTG categories for which Massachusetts submitted negative declarations. The 2002 inventory data does not reflect the existence of an y sources with NAI CS codes that correspond to these categories. Therefore, M assDEP certifies in Table RACT
- 1 to the continued applicability of these negative declarations. **6.4.2 New CTGs**  In October 2006, EPA adopted five new CTGs for the following source categories: three categories of printing: Lithographic Printing Mat erials, Letterpress Printing Materials, and Flexible Packaging Printing Materials; Flat Wood Paneling Coatings; and Industrial Cleaning Solvents. (71 FR 58745, October 5, 2006) States must submit SIP revisions incorporating these new CTGs within one ye ar o f EPA’s promulgation of the final CTG. SIP revisions for these CTGs are due b y October 4, 2007. MassDEP has determined that there are no Massachusetts facilities that are subject to the Flat Wood Paneling CTG. The CTG for Industrial Cleaning Solvents c ontains VOC content, operations and equipment requirements for all industrial cleaning categories and operations 9 that have VOC emissions of at least 15 lb/day . However, the CTG recommends that states exclude from regulation under this CTG, cleaning operations that are covered b y other CTGs that have 9 EPA states that all operations evaluated to date by EPA can be categorized under one of the nine “Unit Operations” (UO) identified in the CT G: Spray Gun Cleaning; Spray Booth Cleaning; Large Manufactured Com ponents Cleaning; Parts Cleaning; Equipment Cleaning; Line Cleaning; Floor Cleaning; Tank Cleaning; and Sm all Manufactured Components Cleaning .Final Se ction 6
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been, or may

be developed for other categories, such as wood furniture coating, shipbuilding and repair coatings, metal furniture coatings, and plastic parts coatings. MassDEP has adopted VOC regulations addr essing numerous other coating operations pursuant to previously
- issue CTGs that include requirements related to cleaning solvents specific to these categories.(See Table RACT 1.) MassDEP’s current Solvent Metal Degreasing regulations, 310 CMR 7.18(8), regulates solvent content within the Metal Degreasing category . MassDEP intends to adopt an amendment to that regulation to limit solvent vapor pressure. (See discussion of this proposed amendment under Section 6.6, RACT Revisions .) With the adoption of that amendment in 2008, MassDEP believes it will meet the requirements of this new CTG. With respect to the three CTGs for printing, MassDEP believes that its existing regulations for these categories may

include controls that are equivalent to the CTG. Itintends to anal yz e the CTG and Massachusetts sources that are covered by it and determine, in consultation with EPA, if that is the case. If additional regulations are required to meet the CTG for this category , MassDEP will adopt regulations and fil e a subsequent RACT SI P incorporating an y regulations necessary to meet the presumptive RACT limits established in these new CTGs. On October 9, 2007, EPA issued new CTGs for the following source categories: 1. paper, film, and foil coatings; 2.metal furniture coatings, and; 3. large appliance coatings. States are required to submit SIP revisions addressing the new CTGs within one y ear of the date that they were issued. MassDEP has made a preliminary determination that there are no facilities in the st ate that are subject to the Large Appliance Coating CTG, as it has been proposed. It has made a preliminary

determination that there are seven facilities that are subject to the proposed Paper, Film and Foil coating CTG and two facilities that are subject to the proposed Metal Furniture coating CTG. Once these CTGs are finalized, MassDEP will analy ze them and, if necessary , adopt regulations and file a subsequent RACT SI P incorporating any regulations it determines are necessary

to meet the presumptive RAC T limits established in these new CTGs. 6.4.3 Non
- CTG Major VOC Sources As previously

discussed, States were required to adopt RACT controls for any non - CTG major VOC source. Massachusetts regulation 310 CMR 7.18(17) established requirements for major f acilities not covered b y a CTG. Such facilities are required to restrict emissions to a rate that is achievable through the implementation of RACT as required in an emission control plan specific to that facility
. MassDEP issued a number of single
- source RACT determinations pursuant to this provision. The single
- source VOC RACT determinations, which were approved by EPA as part of the Massachusetts SI P, are listed in Table RACT
- 2 along with the date of the approvals and the current status of the facilities . For facilities that are still operating, MassDEP has concluded that these controls constitute RACT under the 8
- hour standard. **6.5 NOx RACT Analysis**  MassDEP has reviewed 310 CMR 7.19, Reasonably Available Control Technology (RACT) for Sources of Oxid

es of Nitrogen (NOx), which established RACT for a number of NOx sourceFinal Se ction 6
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categories and provided for single source RACT determinations for major miscellaneous sources. The source categories covered in this regulation are: large, medium and small boilers; st ationary combustion turbines; stationary reciprocating internal combustion engines; glass melting furnaces; and miscellaneous sources. (Massachusetts adopted this NOx RACT regulation in 1995 prior to EPA’s issuance of some of the ACTs for NOx. As noted ab ove, ACTs do not establish presumptive RACT limits.) Except for MWCs (see below), MassDEP has determined that the NOx controls required by 310 CMR 7.19 regulation continue to constitute NOx RACT under the 8
- hour ozone standard for each of the source cat egories covered b y that rule as well as for major sources of NOx for which single
- source RACT determinations were made pursuant to 310 CMR 7.19(12). It certifies in Table RACT
- 1 that current Massachusetts NOx RACT constitutes 8
- hour NOx RACT for the NOx categories listed and for the facilities for which single
- source RACT determinations were made. 6.5.1 Municipal Waste Combustors (MWCs) Massachusetts regulation, 310 CMR 7.19(9), established NOx RACT for the seven MWCs in Massachusetts, with a total of 16 combustor units, in 1995. The NOx emission limits for five of the facilities, with a total of 11 combustor units, were further restricted b y 310 CMR 7.08(2), effective in 2000. These currentl y applicable limits are more stringent than 310 CMR 7.19(9) and are equivalent to emission limits established under EPA’s emissions guidelines (40 CFR 60 Subpart Cb) for MWCs with a combustor capacity greater than 250 tons per day . One unit is subject to the more stringent emission limit in the New Source Performance Standard (NSPS) (40 CFR 60 Subpart Eb). The other two facilities have a combustor capacity less 250 tons per day , but are subject to the emission limitations contained in 310 CMR 7.08(2) and in the Operating Permit for each facility . The NSPS and emissio n guidelines require compliance with emission limitations for nine pollutants, including NOx, that reflect performance of what EPA has determined in the maximum achievable control technology (MACT) for these units. All of the MWCs in Massachusetts meet the emissions limits set in EPA’s MACT standard. In response to comments submitted by EPA on the proposed Ozone SI P with respect to MWCs, MassDEP w ill re
- examine whether its current MACT regulations for MWCs, 310 CMR 7.08 (2), still constitute RACT. By Ap ril 1, 2008, it commits to do an additional analy sis on whether it is cost effective to further reduce NOx emissions from existing MWCs. MassDEP will include stakeholders (i.e. the MWCs, municipalities, and environmental organizations) as part of this proc ess. MassDEP expects to propose revisions to its MWC regulations by December 31, 2008 to comply with the U.S. EPA’s Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Stationary Sources: Large Municipal Waste Combus tors, 40 CFR 60 subpart Cb. Based on the findings of the additional RACT analy sis, MassDEP will consider whether to include a proposal for more stringent NOx limits when it proposes the revisions to the Massachusetts MWC regulations.Final Se ction 6
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**6.5.2 NOx Cap**  **- and**  **- Tr**  **ade Program Sources** Electric generation units (EGUs) and large industrial boilers in Massachusetts are subject to 310 CMR 7.28, NO

x Allowance Trading Program ( NOx Budget Program

) , which caps emissions of NOx from covered sources for the 2003 through 20 08 ozone seasons. This regulation was adopted in 1999 to meet the requirements of EPA’s NOx SI P Call (63 CFR 61712). EPA’s Phase 2 Rule provides that compliance with the NOx SIP Call, regardless of the manner of compliance b y individual sources (e.g. co ntrol equipment installation or purchase of allowances from other sources), constitutes RACT. States need not submit 8
- hour RACT anal ys es for sources in compliance with a SIP meeting the NOx SI P Call. EPA determined that the Massachusetts NOx Budget Program met the NOx SIP Call and approved it as part of the Massachusetts 1
- hour Ozone SI P. Therefore, MassDEP certifies that all NOx sources regulated by 310 CMR 7.28 meet 8
- hour ozone RACT requirements for 2003
- 2008. (These sources are listed in Table RA CT
- 3.) Following the promulgation of EPA’s CAI R in 2005 (See Section 3, Control Measures for a discussion of CAIR and Massachusetts Clean Air Interstate Rule (Mass CAIR), the NOx SI P Call and MassDEP’s NOx Budget Program will be phased out. The Phase 2 Rule provides that EGU sources subject to CAI R, and non
- EGU sources subject to the NOx SIP Call that are brought into the state’s CAIR program, meet 8
- hour ozone RACT requirements. Mass CAI R, 310 CMR 7.32, was promulgated on May 4, 2007 and approved by EPA on December 3, 2007 (72 FR 67854). It regulates the same sources covered under the NOx Budget Program, but imposes a lower ozone season NOx cap. Accordingl y, MassDEP certifies that, all NOx sources regulated under MassCAIR (Table RACT
- 3) will meet 8
- hour ozone standard RACT requirements, starting with the 2009 ozone season. A significant subset of the largest fossil fuel
- fired EGUs in Massachusetts are also subject to annual NOx emission limitations under 310 CMR 7.29, Emissions Standards for Power Plants, adopted in 2001
. Depending upon the compliance path selected b y the affected facilities, the facilities will comply

with these more stringent than RACT output
- based standards between 2004 and 2008. The NOx provisions of 310 CMR 7.29 will be submitted to EPA as a SI P revision by

March 1, 2008. **6.6 RACT Revisions**  MassDEP has determined that its existing solvent metal degreasing, gasoline dispensing vapor recovery , and asphalt paving regulations do not constitute RACT under the 8
- hour ozone standard **.** It is revising its regulations for these categories to require additional VOC controls, as discussed below. **6.6.1 Solvent Degreasing**  The CTG covering solvent metal degreasing applies to units that clean/degrease metal in three ty pes of s ys tems - cold cleanin g, open top vapor degreasers and conveyorized degreasers. The control measures for this sector generall y cover operating practices rather than establish emissionFinal Se ction 6
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limits. Massachusetts regulation 310 CMR 7.18(8) incorporated the CTG requirement for this s ector and met 1
- hour RACT as noted in Table RACT
- 1. MassDEP believes that its existing regulation for this category does not constitute what is currentl y reasonabl y available technology in light of the adoption in a number of other states in the OTC regi on of a vapor pressure limit for solvents used in cold cleaning. MassDEP will propose an amendment to 310 CMR 7.18 (8) to include the vapor pressure limitation for solvents used in cold cleaning consistent with the OTC Model Rule. Upon completion of this rule amendment process, Massachusetts will meet 8
- hour RACT control requirements for this source category . MassDEP anticipates that the revised control requirements will be effective by January 1, 2009. **6.6.2 Gasoline Dispensing Vapor Control**  The distribution of gasoline results in evaporative VOC emissions from each stage of the distribution process. Control of gasoline vapors during transfer of gasoline from tank trucks to gasoline storage tanks is referred to as “Stage I” control. EPA issu ed a CTG for Stage I controls in 1975. MassDEP regulation 310 CMR 7.24(3), Distribution of Motor Vehicle Fuel , governs Stage 1 controls. Control of gasoline vapors during vehicle refueling is referred to as “Stage II” control and is addressed in 310 CMR 7.24(6), Dispensing of Motor Vehicle Fuel . EPA did not issue a CTG related to Stage II control. Stage II control s ys tems return vapors to gasoline tanks using either “vapor balance” or “vacuum assist” s ys tems. Under the current requirements of 310 CMR 7 .24(6), vapor balance sy stems installed on above ground gasoline storage tanks and all vacuum assist sy stems are required to install pressure/vacuum (P/V) vent caps, to further capture gasoline vapors. However, vapor balance sy stems installed on underground gasoline storage tanks are not required to install P/V vent caps. (MassDEP has, for many ye ars, encouraged facilities to voluntarily

install P/V vent caps.) MassDEP has concluded that the P/V vent caps should be required on vapor balance s ys tems insta lled on underground storage tanks to further reduce evaporative emissions from vehicle refueling. MassDEP intends to amend 310 CMR 7.24(6) to require that motor vehicle fuel dispensing facilities with vapor balance systems install a PV vent cap on each und erground motor vehicle fuel storage tank vent. I t anticipates that the revisions will be effective by January 1, 2009. **6.6.3 Asphalt Paving**  Asphalt paving is used to pave, seal and repair surfaces such as roads, parking lots, and walkway s. Asphalt pav ing is grouped into three general categories: hotmix, cutback, and emulsified. Hot
- mix asphalt, the most commonly used paving asphalt, produces minimal VOC emissions. Cutback asphalt is prepared b y blending asphalt cement with a diluent, ty picall y from 25 to 45 percent b y volume of petroleum distillates. Emulsified asphalt is a lower emitting alternative to cutback asphalt; emulsified asphalts use a blend of asphalt cement, water and an emulsifying agent, such as soap. Some emulsified asphalts may contain v irtually

no VOCs; others may

contain up to 12% VOC by volume.Final Se ction 6
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The EPA published a CTG for the use of cutback asphalt in December 1977. The CTG recommended replacing cutback asphalt binders with emulsified asphalt during the ozone season. In 1979, EPA adde d a specification for emulsified asphalt to the CTG recommendations to limit the content of oil distillate in emulsified asphalt to no higher than 7 percent oil distillate. Massachusetts regulation 310 CMR 7.18(9) incorporated the CTG requirement for this sector and met 1
- hour RACT as noted in Table 1. It bans the use of cutback asphalt during the ozone season, but with a number of exceptions. It does not address emulsified asphalt. During its review of additional control measures that states should cons ider adopting as part of the OTC regional 8
- hour ozone attainment strategy , the OTC identified asphalt paving as a category where further VOC emission reductions could be achieved. It developed a model rule for the asphalt paving control measure that prohi bits the use of cutback asphalt during the ozone season and limits the use of emulsified asphalt to that which contains not more than 0.5 mL of oil distillate from a 200 mLsample (as determined using American Societ y for Testing and Materials Methods) reg ardless of application. (This is equivalent to a VOC content of 0.25 percent.) MassDEP will propose an amendment to 310 CMR 7.18(9) to eliminate all exceptions to the ozone - season ban on use of cutback. Itwill also propose to limit the VOC content of emulsified asphalt to the level proposed in the OTC model rule, or to such other level as is determined to be feasible in Massachusetts. Upon completion of this rule amendment process, Massachusetts will meet 8
- hour RACT control requirements for this source category . MassDEP anticipates that the revised control requirements will be effective b y April 2009. **6.7 Conclusions**  By full y compl yi ng with all 1
- hour ozone standard RACT requirements, Massachusetts has reduced emissions of VOCs and NOx from stationary point and area sources significantl y over the past 30 y ears. In order to meet the 8
- hour ozone standard RACT requirements, MassDEP is committing to further reduce VOC emissions for the categories of solvent metal degreasing, gasoline dispensing vapor contr ol, and asphalt paving by adopting revised regulations with an anticipated effective date no later than January 1, 2009. For large EGUs and other large NOx sources covered b y the NOx Budget Program and Mass CAIR, those cap
- and
- trade programs meet RACT Ma ssDEP intends to review the three printing CTGs finalized by EPA in October 2006 and will determine in consultation with EPA whether existing Massachusetts regulations covering these source categories may

be equivalent to the CTGs. If not, it will propose new regulations that will meet the CTG requirements. With the exception of MWCs, as discussed in Section 6.5.1,for all other CTG RACT categories and major non
- CTG sources of VOC and NOx emissions, MassDEP has concluded that current RACT controls, as ad opted and approved b y EPA under the 1
- hour ozone standard, constitute RACT under the 8
- hour ozone standard.