EL DORADO COUNTY 

AIR QUALITY MANAGEMENT DISTRICT

REASONABLY AVAILABLE CONTROL 

TECHNOLOGY (RACT) STATE 

IMPLEMENTATION PLAN (SIP) UPDATE 

ANALYSIS STAFF REPORT 

NOVEMBER 17, 2006
This Page Intentionally Left Blank 
TABLE OF CONTENTS 

TITLE PAGE

 

INTRODUCTION 5 

 

REASON FOR THIS ANALYSIS 5 

ACTION REQUESTED BY U.S. EPA 5 

ANALYSIS 

 DISTRICT PLANNING HISTORY 6 

 

PART 1 – RACT STANDARDS 6 

PART 2 – NEGATIVE DECLARATIONS 8 

 

PART 3 – SIP APPROVAL STATUS 9 

 

PART 4 – SUMMARY AND CONCLUSIONS 12 

APPENDIX: 

Table A - Rule Categories As Listed in U.S. EPA 13 

Letter to CARB, 4/4/06 

 
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2006 RACT SIP Update Analysis 

November 7, 2006 

Page 5 

INTRODUCTION 

El Dorado County is located in northern California, bordering Sacramento County to the west and 

the State of Nevada on the east. Air quality attainment planning is under the jurisdiction of the El 

Dorado County Air Quality Management District (District). Elevations range from 1,000 feet in the 

western portion of the County to 9,000 feet in the mountains of the Sierras. El Dorado County is 

divided into two different air basins: the Mountain Counties Air Basin (MCAB); and the Lake 

Tahoe Air Basin (LTAB). Each air basin has its own meteorological and geographic conditions. 

Generally, the Mediterranean climate in the adjacent Sacramento Valley Air Basin (SVAB) and 

the lower elevations of the MCAB have summers that are hot and dry with temperatures usually 

in the 90s, which are conducive to ozone formation. Prevailing winds from the west transport 

ozone from the San Franciso Bay Area and the Sacramento Valley into the foothill and mountain 

areas. 

 

The portions of El Dorado County in the MCAB are included in the Sacramento Federal Ozone 

Non-Attainment Area (SFNA), which has been designated as “serious” non-attainment for the 8-

hour ozone National Ambient Air Quality Standard (NAAQS). Before the U.S. Environmental 

Protection Agency (U.S. EPA) posted new 8-hour ozone designations and non-attainment 

classifications in June 2004, the SFNA was a “severe” non-attainment area for the 1-hour ozone 

NAAQS. Although the U.S. EPA revoked the 1-hour ozone NAAQS, the SFNA still remains 

subject to control measure commitments that applied under the 1-hour ozone NAAQS. 

Therefore, the District is responsible for implementing emission standards and other 

requirements mandated by the Federal Clean Air Act. 

REASON FOR THIS ANALYSIS

Sections 182(b)(2) and 182(f) of the Federal Clean Air Act require ozone non-attainment areas 

to implement Reasonably Available Control Technology (RACT) for sources that are subject to 

Control Techniques Guideline (CTG) documents issued by U.S. EPA and for “Major Sources” of 

Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx), which are ozone 

precursors. RACT requirements are included in the Clean Air Act to assure that significant 

source categories at Major Sources are controlled to a “reasonable” extent, but not necessarily 

to Best Available Control Technology (BACT) or Maximum Achievable Control Technology” 

(MACT) levels which are expected of new sources. 

U.S. EPA defines RACT as the lowest emission limitation that a particular source is capable of 

meeting by the application of technology (i.e., devices, systems, process modification, or other 

apparatus or techniques that reduce air pollution) that is reasonably available considering 

technological and economic feasibility. 

According to the U.S. EPA’s Final Rule to Implement the 8-Hour Ozone NAAQS (70 

FR 71612, November 29, 2005) areas classified as moderate non-attainment or higher must 

submit a demonstration that their current rules fulfill 8-hour ozone RACT for all CTG categories 

and all Major, non-CTG Sources as a revision to their State Implementation Plan (SIP). States 

can demonstrate that RACT is being met with either a new RACT determination or a certification 

that previously required RACT controls represent RACT for 8-hour ozone. Areas may rely on 

previous analyses written for 1-hour ozone plans and U.S. EPA guidance documents. The RACT 

SIP submittal is in addition to the area’s 8-hour Ozone Attainment Demonstration Plan, which 

will also be a SIP submittal. 

ACTION REQUESTED BY U.S. EPA

On March 9, 2006 and April 4, 2006, Andrew Steckel, U.S. EPA Office Rulemaking Chief, sent 

request letters to the California Air Resources Board (CARB). The letters concern District 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 6 

requirements and outlined a possible RACT SIP submittal strategy to determine whether RACT 

requirements have been met. District activities performed as a part of this analysis are as 

follows: 

 

Part 1 Identify all District rules subject to the U.S. EPA Control Techniques Guidelines 

(CTG) source categories within the District and determine if they meet RACT standards. 

Part 2 Identify all CTG categories for which there are no facilities in the District, and 

submit Negative Declarations stating that there are no such facilities. 

 

Part 3 List District rules and their SIP approval status for all applicable RACT 

categories. 

Part 4 Summarize the above processes that the District used to: (1) determine that the 

District regulations fulfill RACT, (2) determine Negative Declarations needed for certain 

CTG categories, and (3) determine which District rules need to be submitted to U.S. EPA 

as revision to the SIP. 

The District was requested to prepare a complete RACT SIP update analysis, covering Major 

Sources, non-Major CTG Sources, and non-CTG Major Sources. In addition, the District is 

required to implement an 8-hour Ozone Demonstration Plan no later than the beginning of the 

first ozone season or portion thereof that occurs 30 months after the above submittal date. This 

would be March 15, 2009. Since El Dorado County has a full year ozone season, the required 

implementation date for the District will be January 1, 2009. Note that the implementation date for 

any source operating under a Title V permit, pursuant to 40 CFR Part 70, would be governed by 

the requirements of that permit. This staff report relates to the RACT SIP update analysis 

submittal. 

 

ANALYSIS

District Planning History

 

To improve the air quality in El Dorado County and move the region towards attainment of the 

NAAQS, the District has prepared and adopted several air quality attainment plans since 1991. 

The following table summarizes the District’s attainment plans. The District has also adopted 

over 100 new rules and amendments to meet the commitments in these attainment plans. The 

air quality in El Dorado County has improved over the past several years as the District has 

adopted air quality plans and regulations. In a continuation of the District’s strategy for achieving 

the NAAQS, the District is working with other air districts in SFNA to submit an 8-hour ozone 

attainment demonstration plan to U.S. EPA by June 15, 2007, as specified by federal 

requirements. 

Part 1 – Identify all District rules subject to the U.S. EPA CTG source categories within the District 

and determine if they meet RACT standards.

This District analysis compared the current Prohibitory Rules (Regulation 2 in the District Rule 

Book) to current U.S. EPA guidance standards for emission control measure. The purpose of 

this work was to: (1) determine if the District had an adopted rule for the source category, (2) 

determine if the rule’s control measures satisfied the requirements of the U.S. EPA’s control 

measure standard, and (3) determine if a new rule will need to be adopted for existing emission 

sources. The standards compared were Control Techniques Guidelines (CTG) and Alternate 

Control Techniques (ACT) Guidance. CARB’s The ultimate purpose of this study is the 

determination by the District of whether the District has existing adopted rules that meet or 

exceed the standards in the current CTGs and ACTs. 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 7 

To determine if District rules fulfill RACT requirements, Staff used the following guidelines: 

• District rules that have been SIP-approved by U.S. EPA are considered to meet RACT 

requirements because U.S. EPA evaluated the rules to determine if they fulfill RACT 

established by CTGs, (ACTs) and U.S. EPA guidelines and policies. Therefore, any EPA 

SIP-approved District rules are said to have met RACT requirements. 

• As a non-attainment area for the California ozone standard, the District is required by 

California Health and Safety Code (CH&SC) Sections 40914(a)(2) and 40920.6(a) to 

implement “All Feasible Control Measures” (AFCM) and “Best Available Retrofit Control 

Technology” (BARCT). In general, AFCM and BARCT requirements are more stringent 

than those previously established by CTGs and ACTs. Therefore, District rules that 

implemented AFCM and BARCT are said to fulfill RACT requirements. 

• All CTG emission source categories were compared against existing adopted District 

rules and a finding was made regarding whether the adopted rule met or exceeded the 

applicable CTG RACT requirements. All ACTs were evaluated to determine whether 

Major Sources exist in the source category and if so, whether or not a District rule 

satisfying ACT guidelines has been adopted. 

Table A, provided as an Appendix to this report lists all U.S. EPA source categories requested, 

both Major and non-Major, and the corresponding CTGs and ACTs, with details of each category. 

All the adopted rules have been found to satisfactorily meet RACT requirements. 

Table B contains the major source in the District and that the source meets RACT for all emission 

units. 

Table C shows that there are rule categories listed in the April 4, 2006 U.S. EPA letter for which 

no sources currently exist in the District. The absence of sources of these categories was 

determined by Staff, based on a study of the District permit base, public notices, and personal 

knowledge (See Part 2, below which discusses Negative Declarations) Staff also noted that the 

District has new non-Major Sources in one CTG category (Metal Parts and Products) that has no 

rule at this time. The District RACT SIP submittal process will include the requirement that the 

appropriate rule be written, adopted and approved subsequent to this RACT SIP study, but no 

later than the El Dorado County RACT implementation date of January 1, 2009. 

 

Table D provides an overview of adopted District Rules and amendments, and Applicable SIP 

Approval dates. 

Major Sources: 

The following Table B lists the Major Source that is currently in the District. 

 

Table B - Major Sources – El Dorado Air Quality Management District 

Source Source Category Pollutant Rule No. Rule Title Location / 

Comments 

Sierra 

Pacific 

Industries 

(Title V) 

Boilers, Steam 

Generators and 

Process Heaters 

NOX 232 Biomass Boilers Camino 

Sierra 

Pacific 

Industries 

Boilers, Steam 

Generators and 

Process Heaters 

VOC 234 

VOC RACT RuleSierra Pacific 

Industries 

Camino 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 8 

Table B - Major Sources – El Dorado Air Quality Management District 

Source Source Category Pollutant Rule No. Rule Title Location / 

Comments 

(Title V) 

 

The Major Stationary Source, including Major non-CTG Sources have adopted District rules that 

satisfy RACT requirements. 

Part 2 - Negative Declaration (Negative Declaration) for use with 8-hour Ozone Reasonably 

Available Control Technology (RACT) State Implementation Plan Certification

Background 

Due to the designation of portions of El Dorado County as “moderate” or above non-attainment 

for ozone, Sections 182(b)(2) and 182(f) of the Federal CAA require the District to submit a 

revision to the State Implementation Plan (SIP) to implement RACT for each category of Volatile 

Organic Compound (VOC) or Nitrogen Oxide (NOx) sources covered by a CTG document and for 

any Major Stationary Source not covered by a CTG document. The Mountain Counties Air Basin 

portions of the District are part of the Sacramento Federal Ozone Non-Attainment Area (SFNA) 

which is designated as “serious” non-attainment for ozone. 

RACT requires that all non-attainment areas classified as “moderate” or above have RACT in 

place for source categories covered by a Control Techniques Guideline (CTG) document and for 

Major Sources that are not subject to a CTG (i.e. a “Major non-CTG Source”). A “Major Source” 

of VOCs or NOx in El Dorado County is defined as an emission source having a potential to emit 

of 25 tons of the pollutant per year. The District must adopt the control measures for a source 

category if it has a source of emissions located within the non-attainment area that is subject to a 

CTG. Alternatively, if the finding is made that there are no existing sources that emit the 

designated pollutants in its area subject to a RACT requirement, the District may make a 

negative declaration to this effect and consequently the requirement to adopt a rule for those 

sources is not applicable. This process is called “Negative Declaration” . 

The District is required to submit Negative Declarations for all CTG categories for which there are 

no sources above the CTG recommended threshold, even if such negative declarations were 

made for an earlier SIP. This is necessary since there may be sources in the non-attainment 

area that previously did not exist. Also, if the boundaries of the non-attainment area have 

expanded, there may be sources in the new portion of the non-attainment area which should not 

be overlooked. 

The District must also submit a Negative Declaration to certify that there are no Major non-CTG 

Sources in the non-attainment area. 

The Negative Declaration must go through the same public review requirements as any other SIP 

submittal. 

Negative Declaration Findings and Staff Recommendations 

The District Staff reviewed permit databases, SIC codes, other source data and the emission 

inventory for its Federal Clean Air Plan, and has determined that there are no sources for the 

CTG categories listed below in Table C. 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 9 

Staff has determined that there are no existing sources of emissions in these fifteen (15) CTG 

categories and the Negative Declarations should be submitted to U.S. EPA for approval. Staff 

will submit these fifteen (15) Negative Declarations for public comment, and District Board 

consideration and approval. If approved by the District Board the Negative Declarations will be 

submitted to CARB for forwarding to U.S. EPA as requested revisions to the State 

Implementation Plan.

Table C District Negative Declaration Submittal Requirements 

 Rule Title Pollutant 

1 Aerospace Coating VOC 

2 Large Appliance Coating VOC 

3 Magnet Wire Coating VOC 

4 Metal Coil, Container and Closure Coating VOC 

5 Metal Furniture Coating VOC 

6 Paper and Fabric Coating VOC 

7 Ship Coating VOC 

8 Wood Coating (Flat Wood Paneling) VOC 

9 Natural Gas/Gasoline Plants VOC 

10 Refineries VOC 

11 Synthetic Organic Chemical Manufacturing VOC 

12 Petroleum Dry Cleaning VOC 

13 Pharmaceutical Products VOC 

14 Polyester Resin Manufacturing VOC 

15 Rubber Tires VOC 

Part 3 - SIP Status - Identify all District rules subject to the U.S. EPA CTG source categories 

within the District and determine if they meet RACT standards.

The current status of each of the District prohibitory rules that previously were adopted for 

CTG/ACT source categories was reviewed and is displayed in the following tables. This SIP 

status study was necessary in order to determine which rules, if any, needed to be submitted or 

re-submitted for SIP approval by U.S. EPA. The following lists the SIP status categories that 

were examined: 

a. Rules that were submitted and approved for SIP. 

b. Rules that were submitted and approved for SIP and that must be re-submitted 

for approval because of amendments that post-dated the SIP approval. 

c. Rules that have not yet been submitted for SIP approval. 

d. Rules that were submitted for SIP approval and which are awaiting approval. 

(None were in this category). 

Staff examined the adoption dates of the above rules, and the dates of the latest amendments, if 

any. Then the date of SIP approval was compared with the rule adoption histories. 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 10 

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status:

Table D-1 lists the adoption history of ten (10) District rules for CTG categories and ACT 

categories at major sources, and their SIP approval status. They are listed by rule number. The 

right hand column indicates if the District must re-submit any existing rule that was amended after

the latest date of SIP approval, in order to ensure that the review will be based upon the most 

current amendment of that rule. Staff recommends that these SIP submittals be found exempt 

from the California Environmental Quality Act (CEQA). The proposed submittals are exempt from 

CEQA as per Title 14, Calfornia Code of Regulations, Chapter 3, Article 19, Section 15308, 

Actions by Regulatory Agencies for the Protection of the Environment. 

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status

Rule 

No. Rule Title 

Pollutant 

Controlled 

CTG 

Source

? 

Date 

Adopted 

Date Last 

Amended 

SIP 

Approval - 

FR Citation 

New SIP 

Approva

l 

Require

d? 

216 Organic Solvents VOC Yes 1979 1/24/85 1/24/85 - 50 

FR 3338 N 

224 

Cutback and 

Emulsified Asphalt 

Paving Materials 

VOC Yes 9/16/91 6/6/94 8/21/95 - 60 

FR 43383 N 

225 

Organic Solvent 

Cleaning and 

Degreasing 

Operations 

VOC Yes 9/27/94 Not 

Amended 

8/21/95 - 60 

FR 43383 N 

230 

Automotive 

Refinishing 

Operations 

VOC Yes 9/27/94 Not 

Amended 

4/30/96 - 61 

FR 18962 N 

231 Graphic Arts 

Operations VOC Yes 9/27/94 Not Amended 

7/11/97 62 FR 

37136 N 

232 Biomass Boilers NOx No 10/18/94 9/25/01 10/14/03 - 68 

FR 59121 N 

234 

VOC RACT RuleSierra Pacific 

Industries 

VOC No 4/25/95 Not 

Amended 

9/12/95 - 60 

FR 47273 N 

237 

Wood Products 

Coating 

Operations 

VOC Yes 6/27/95 Not 

Amended 

4/30/96 - 61 

FR 18962 N 

238 Gasoline Transfer 

and Dispensing VOC Yes 3/27/01 Not Amended 

8/27/01 - 66 

FR 44974 N 

244 

Organic Liquid 

Loading and 

Transport Vessels 

VOC Yes 3/27/01 9/25/01 7/8/02 - 67 FR 

45067 Y 

District Rules Which Were SIP- Approved and Do Not Require Re-Submittal: 

Table D-2 lists rules that were submitted for SIP after their latest amendment date and approved. 

These nine (9) rules have been incorporated into the SIP and will not require resubmittal for SIP 

at this time. 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 11 

 Table D-2 - District Rules Which Were SIP- Approved and Do Not Require ReSubmittal 

Rule 

No. Rule Title Pollutant Controlled 

CTG 

Source

? 

Date 

Adopted 

Date Last 

Amended 

SIP 

Approval 

- FR 

Citation 

New SIP 

Approval 

Required

? 

216 Organic Solvents VOC Yes 1979 1/24/85 

1/24/85 - 

50 FR 

3338 

N 

224 

Cutback and 

Emulsified Asphalt 

Paving Materials 

VOC Yes 9/16/91 6/6/94 

8/21/95 - 

60 FR 

43383 

N 

225 

Organic Solvent 

Cleaning and 

Degreasing 

Operations 

VOC Yes 9/27/94 Not 

Amended 

8/21/95 - 

60 FR 

43383 

N 

230 

Automotive 

Refinishing 

Operations 

VOC Yes 9/27/94 Not 

Amended 

4/30/96 - 

61 FR 

18962 

N 

231 Graphic Arts 

Operations VOC Yes 9/27/94 Not Amended 

7/11/97 

62 FR 

37136 

N 

232 Biomass Boilers NOx No 10/18/94 9/25/01 

10/14/03 - 

68 FR 

59121 

N 

234 

VOC RACT RuleSierra Pacific 

Industries 

VOC No 4/25/95 Not 

Amended 

9/12/95 - 

60 FR 

47273 

N 

237 

Wood Products 

Coating 

Operations 

VOC Yes 6/27/95 Not 

Amended 

4/30/96 - 

61 FR 

18962 

N 

238 Gasoline Transfer 

and Dispensing VOC Yes 3/27/01 Not Amended 

8/27/01 - 

66 FR 

44974 

N 

District Rules Which Were SIP-Approved and Now Require Re-Submittal Because 

of Amendments:

Table D-3 lists the one (1) adopted District rule that was approved for SIP previously, and that 

must now be re-submitted for SIP because of amendments that post-dated the U.S. EPA’s SIP 

approval. 

 

Table D-3 - District Rules Which Were SIP-Approved and Require Re-Submittal 

Because of Recent Amendments

Rule 

No. Rule Title 

Pollutant 

Controlled 

CTG 

Source? 

Date 

Adopted 

Date Last 

Amended 

SIP 

Approval - 

FR 

Citation 

New SIP 

Approval 

Required

? 

244 

Organic Liquid 

Loading and 

Transport Vessels 

VOC Yes 3/27/01 9/25/01 7/8/02 - 67 

FR 45067 Y 
2006 RACT SIP Update Analysis 

November 7, 2006 

Page 12 

Part 4 – Summary and Conclusions 

New RACT Rules to Be Adopted - Details of the process Staff used to evaluate the Applicable 

SIP status of the District’s rules that satisfy Major Source RACT requirements are described in 

Part 1, above. The Staff comparison of all current District rules to the standards of applicable 

CTG’s and ACT’s found that the District has adopted rules corresponding to RACT source 

categories and that satisfy RACT requirements. One CTG category, Metal Parts and Products, 

have non-Major emission source(s), but no District Rule has been adopted. Staff recommends 

that the Board direct the development and adoption of the rule to limit VOC emissions from the 

coating of metal parts and products. Although there are no Major Sources in this source 

category, there are non-Major Sources of VOC that would be subject to the new rule establishing 

RACT requirements. The rules should be implemented by January 1, 2009, and should be 

adopted as a revision to the SIP and submitted to U.S. EPA. 

Negative Declarations - (Part 2) Based on Staff review of District sources, the Negative 

Declaration of no existing Major Stationary VOC Sources may be made for fifteen (15) additional 

VOC RACT source categories. In addition, the Staff analysis found that there were no Major 

Stationary Sources, including Major non-CTG Sources, for which District rules satisfying RACT 

had not been adopted. Staff recommends that the District Board make the declaration that no 

existing Stationary Sources exist for VOC in El Dorado County in the fifteen (15) specified CTG 

source categories and that no Major non-CTG Sources exist for which RACT measures have not 

been adopted.. Staff further recommends that these SIP submittals be found exempt from the 

California Environmental Quality Act (CEQA) per Title 14, California Code of Regulations, 

Chapter 3, Article 19, Section 15308, Actions by Regulatory Agencies for the Protection of the 

Environment. 

SIP Status – (Part 3) Rule adoption, amendment, and SIP approval history for District prohibitory 

rules was reviewed and analyzed. Nine (9) SIP-approved rules do not require re-submittal for 

SIP status. One (1) previously SIP approved rule must be re-submitted because of amendments 

that post-dated the original approval. Staff recommends that the District Board direct and 

approve the submittal of the specified rules, previously adopted, to the U.S. EPA as revisions to 

the SIP. 
APPENDIX 

Table A - 

Rule Categories as Listed in U.S. EPA Letter to CARB, 4/4/06 
 -3-

List of EPA Documents Which Help Establish RACT 

Category EPA Documents

General CTGs ACTs / other documents to help establish 

RACT at Major sources

Batch Processes (A12) ACT Document Control of VOC Emissions from 

Batch Processes (EPA-453/R-93-017 or EPA-453/R-93-020 

2/94). 

http://www.epa.gov/ttn/oarpg/t1/memoranda/batctg1.zip

http://www.epa.gov/ttn/oarpg/t1/memoranda/batctg2.zip

http://www.epa.gov/ttn/oarpg/t1/memoranda/batctg3.zip

http://www.epa.gov/ttn/oarpg/t1/memoranda/batctg4.zip

http://www.epa.gov/ttn/oarpg/t1/memoranda/batctg5.zip

NOx Sources 1. Guideline for Determining the Appicability of Nitrogen 

Oxides Requirements Under Section 182(f), EPA, 12/93. 

http://www.epa.gov/ttn/oarpg/t1/memoranda/sec182f.pdf 

2. Summary of NOx Control Technologies and their 

Availability and Extent of Application (EPA-450/3-92-004), 

2/92. 

http://www.epa.gov/clariton/clhtml/pubtitle.html OR 

http://nepis.epa.gov/pubtitle.htm

3. Control Techniques for Nitrogen Oxides Emissions from 

Stationary Sources - Second Edition (EPA-450-1-78-001), 

1/78 

http://www.epa.gov/ttn/chief/old/ap42/ch01/s01/reference/re

f_10c01s01_1995.pdf 

RACM & RACT Beyond VOC RACT CTG Requirements (EPA-453/R-95-

010, 4/95, NTIS PB-95-239-497), CTG 

http://www.epa.gov/ttn/catc/dir1/byndract.pdf 

Stationary VOC 

Sources 

(#13) 1. Control Techniques for Volatile Organic Emissions 

from Stationary Sources (EPA-450/2-78-022, 5/78, Group 

II, NTIS PB-284-804), CTG. Does not define RACT for any 

particular source. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s091/reference/r

ef_13c04s091_1995.pdf 

(A8) 2. Control Techniques for VOC Emissions from 

Stationary Sources (EPA-453/R-92-018, 12/92, NTIS PB93-150-258) 

VOC Model 

Rules 

 Model VOC Rules for RACT (EPA, OAQPS, 6/92) 

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_modelru

les.pdf

Fugitive (#23) Fugitive Emission Sources of Organic Compounds - 

Additional Information on Emissions, Emission Reductions, 

and Costs (EPA 450/3-82-010, 4/82, NTIS PB-82-217 126) 

Does not define RACT for any particular source. 

EPA R9 has an electronic copy 

Coating & 

Solvents
 -4-

Coating (#2) Control of Volatile Organic Emissions from Existing 

Stationary Sources, Volume I: Control Methods for Surface 

Coating Operations (EPA-450/2-76-028, 11/76, NTIS PB260-386), 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s0227/reference/

ref_04c04s0227_1995.pdf 

Adhesives & 

Sealants 

Aerospace (P4) Control of VOC Emissions from Coating 

Operations at Aerospace Manufacturing and 

Rework Operations CTG & MACT (See 59 

FR 29216, 6/6/1994); CTG (Final), EPA453/R-97-004, 12/97). 

http://www.epa.gov/ttn/oarpg/t1/memoranda/c

tg.pdf

Architectural 

Coatings 

 National VOC Emission Standards for Architectural 

Coatings (40 CFR 59 Subpart D, 9/11/98). 

http://epa.gov/ttn/atw/183e/aim/aimpg.html

Automobile 

Coating 

(#3) 1. 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, 5/77, NTIS PB-272-

445), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0227/reference/ref_02c04s0227_Jan1995.pdf 

2. Reduction of VOC Emissions from Automobile 

Refinishing (EPA-450/3-88-009, 10/88, NTIS PB-89-148-

282), ACT. http://www.p2pays.org/ref/12/11336.pdf 

(A14) 3. ACT Document: Surface Coating of 

Automotive/Transportation and Business Machine Plastic 

Parts (EPA-453/R-94-017, 2/94, NTIS PB-94-158-086). 

(A15) 4. ACT Document: Auto. Refinishing (EPA-453/R94-031, 4/94, NTIS PB-94-191-699). Note a national rule 

was issued in 1998 after the ACT. See 40 CFR 59.100. 

www.epa.gov/clariton/clhtml/pubtitle.html

5. National VOC Emission Standards for Automobile 

Refinish Coatings (40 CFR 59 Subpart B, 9/11/98). 

http://epa.gov/ttn/atw/183e/arc/arcpg.html

Graphic Arts (#19) 1. Control of Volatile Organic 

Emissions from Existing Stationary Sources, 

Volume VIII: Graphic Arts - Rotogravure and 

Flexography (EPA-450/2-78-033, 12/78, 

NTIS PB 292-490), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

091/reference/ref_03c04s091_1995.pdf 

(A17) 3. ACT Document: Offset Lithographic Printing 

(EPA-453/R-94-054, 6/94, NTIS PB-95-201-018). 

http://www.epa.gov/ttn/oarpg/t1/memoranda/lact.zip

Large 

Appliances 

(#9) Control of Volatile Organic Emissions 

from Existing Stationary Sources, Volume V: 

Surface Coating of Large Appliances, EPA450/2-77-034, NTIS PB-278-259), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0224/reference/ref_02c04s0224_1995.pdf 
 -5-

Magnet Wire (#8) Control of Volatile Organic Emissions 

from Existing Stationary Sources, Volume IV: 

Surface Coating of Insulation of Magnet 

Wire, (EPA-450/2-77-033, 12/77, NTIS PB278-258), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0223/reference/ref_01c04s0223_1995.pdf 

Metal Coil, 

Container, & 

Closure 

See automobile coating. 

Metal Furniture (#7) Control of Volatile Organic Emissions 

from Existing Stationary Sources, Volume III: 

Surface Coating of Metal Furniture (EPA450/2-77-032, 12/77, NTIS PB-278-257), 

CTG 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0224/reference/ref_01c04s0224_1995.pdf . 

Metal Parts & 

Products 

(#14) Control of Volatile Organic Emissions 

from Existing Stationary Sources, Volume VI: 

Surface Coating of Miscellaneous Metal Parts 

and Products (EPA-450/2-78-015, 6/78, NTIS 

PB-286-157), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0224/reference/ref_03c04s0224_1995.pdf 

Paper & Fabric See automobile coating. 

Plastic Parts 1. ACT Document: Surface Coating of 

Automotive/Transportation and Business Machine Plastic 

Parts (EPA 453/R-94-017, 2/94). 

2. See automobile coating. 
 -6-

Ships (P3) (A16) 1. ACT Document: Surface 

Coating Operations at Shipbuilding and Ship 

Repair Facilities (EPA-453/R-94-032, 4/94, 

NTIS PB-94-181-864). The ACT was 

superseded by the Shipbuilding CTG which 

was issued in 1996 

http://www.epa.gov/ttn/oarpg/t1/memoranda/s

hip-1.zip 

http://www.epa.gov/ttn/oarpg/t1/memoranda/s

hip-2.zip

and

(P3) 2. CTG, see 61 FR 44050, 8/27/96. FR 

notice: 

http://www.epa.gov/ttn/oarpg/t1/memoranda/s

hipctg.zip

Solvent 

Cleaning 

(#4) 1. Control of Volatile Organic Emissions 

from Solvent Metal Cleaning, (EPA-450/2-77-

022, 11/77, NTIS PB-274-557), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

06/reference/ref_02c04s06_1995.pdf 

(A4) 2. ACT Document - Halogenated Solvent Cleaners 

(EPA-450/3-89-030, 8/89, NTIS PB-90-103-268). 

(A13) 3. ACT Document: Industrial Cleaning Solvents 

(EPA-453/R-94-015, 2/94, NTIS PB-94-156-79). 

http://www.epa.gov/ttn/oarpg/t1/memoranda/indsol-1.zip

http://www.epa.gov/ttn/oarpg/t1/memoranda/indsol-2.zip

Traffic Markings (A2) Reduction of VOC Emissions from the Application of 

Traffic Markings (EPA-450/3-88-007, 8/88, NTIS PB-89-

148-274, ACT). The Architectural and Industrial 

Maintenance Coatings rule included limits for traffic 

markings and superseded the ACT. See 40 CFR 59.400. 

EPA R9 has an electronic copy. 

Wood Coating (#15) Control of Volatile Organic Emissions 

from Existing Stationary Sources, Volume 

VII: Factory Surface of Flat Wood Paneling 

(EPA-450/2-78-032, 6/78, NTIS PB 286-199), 

CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

0225/reference/ref_01c04s0225_1995.pdf 

Wood Furniture (P2) Control of VOC Emissions from Wood 

Furniture Manufacturing Operations CTGMACT draft MACT our 5-94; Final CTG, 

EPA-453/R-96-007, 4/96, NTIS PB-96-178-

769), Also see 61 FR 25223 and 61 FR 50823, 

9/27/96.

http://www.epa.gov/ttn/oarpg/t1/memoranda/

woodctg.ziphttp://www.epa.gov/ttn/atw/wood/

finalctg.pdf 

http://www.epa.gov/ttn/oarpg/t1/memoranda/c

tgadden.pdf

(A1) Control Techniques for Organic Emissions from 

Plywood Veneer Dryers, EPA-450/3-83-012. May 1983. 

This document is labeled as a control technique document 

(CTD) rather than an ACT. However, the information is 

similar to that in an ACT. 

Petroleum

Gasoline Plants (#10) Control of Volatile Organic Emissions 

from Bulk Gasoline Plants (EPA-450/2-77-

035, 12/77, NTIS PB-276-722), CTG. EPA 

R9 has an electronic copy. 
 -7-

Natural 

Gas/Gasoline 

(#26) Control of VOC Equipment Leaks from 

Natural Gas/Gasoline Processing Plants 

(EPA-450/2-83-007, 12/83, NTIS PB-84-161-

520), CTG. EPA R9 has an electronic copy. 

Refineries (#5) 1. Control of Refinery Vacuum 

Producing Systems, Wastewater Separators, 

and Process Unit Turnarounds, (EPA-450/2-

77-025, 10/77, NTIS PB-275-662), CTG. 

EPA R9 has an electronic copy. 

(#16) 2. Control of VOC Leaks from 

Petroleum Refinery Equipment (EPA-450/2-

78-036, 6/78, NTIS PB-286-158), CTG. EPA 

R9 has an electronic copy. 

3. Petroleum Refinery Tier 2 BACT Analysis Report 

(Eastern Research Group for EPA, 1/16/01 

http://www.epa.gov/ttn/oarpg/t1/memoranda/bactrpt.pdf

(A5) 4. ACT Document - Organic Waste Process Vents 

(EPA-450/3-91-007, 12/90 NTIS PB91-148270) 

5. Control Technology Center Document - Industrial 

Wastewater Volatile Organic Compound Emissions - 

Background Information for BACT/LAER Determinations 

(EPA-40/3-90-004, NTIS PB90-194754) 

Service Stations (#1) 1. Design Criteria for Stage I Vapor 

Control Systems - Gasoline Service Stations, 

(11/75), CTG. - EPA R9 has an electronic 

copy 

2. Technical Guidance -- Stage II Vapor Recovery Systems 

for Control of Vehicle Refueling Emissions at Gasoline 

Dispensing Facilities (EPA-450/3-91-022a & b, 11/91). 

3. Guidelines - Gasoline Vapor Recovery - Minimum SIP 

Requirements for EPA Region IX to Approve a Phase I or 

Phase II Gasoline Transfer Rule for Ozone Nonattainment 

Areas, (EPA Region 9, 4/00). EPA R9 has an electronic 

copy. 

Synthetic 

Organic 

Chemical 

(#28) 1. Control of VOC Emissions from Air 

Oxidation Processes in Synthetic Organic 

Chemical Manufacturing Industry (EPA450/3-84-015, 12/84, NTIS PB-85-164-275), 

CTG. 

EPA R9 has an electronic copy 

(P1) 2. Control of VOC Emissions from 

Reactor Processes and Distillation Operations 

in SOCMI (EPA-450/4-91-031, 11/15/93, 

NTIS PB-92-180-009), CTG. EPA R9 has an 

electronic copy 

Tanks (#11) 1. Control of Volatile Organic 

Emissions from Storage of Petroleum Liquids 

in Fixed Roof Tanks (EPA-450/2-77-036, 

12/77, NTIS PB-276-749), CTG. 

(#20) 2. Control of Volatile Organic 

Emissions from Petroleum Liquid Storage in 

External Floating Roof Tanks (EPA-450-2/78-

047, 12/78, NTIS PB-290-579), CTG. 

www.epa.gov/clariton/clhtml/pubtitle.html

(A11) 3. Volatile Organic Liquids Storage in Floating and 

Fixed Roof Tanks (EPA-453/R-94-001, 2/94, NTIS PB-94-

152-741), ACT. 

http://www.epa.gov/clariton/clhtml/pubtitle.html

Tank Trucks (#6) 1. Control of Hydrocarbons from Tank 

Truck Gasoline Loading Terminals (EPA450/2-77-026, 12/77, NTIS PB-275-060), 

CTG. EPA R9 has an electronic copy. 

(#22) 2. Control of VOC Leaks from Gasoline 

Tank Trucks and Vapor Collection Systems 

(EPA-450/2-78-051, 12/78, NTIS PB-290-

568), CTG. EPA R9 has an electronic copy. 

Combustion
 -8-

Boilers, Steam 

Generators, 

Process Heaters 

(N3) 1. ACT Document -- NOx Emissions from Process 

Heaters (Revised) (EPA-453/R-93-034, 9/93). 

http://www.epa.gov/ttn/catc/dir1/procheat.pdf

(N5) 2. ACT Document -- NOx Emissions from Utility 

Boilers (EPA-453/R-94-023, 3/94). 

http://www.epa.gov/ttn/chief/old/ap42/ch01/s01/reference/re

f27_c01s01_1998.pdf 

(N7) 3. ACT Document -- NOx Emissions from 

Industrial/Commercial/Institutional (ICI) Boilers (EPA453/R-94-022, 3/94). 

http://www.epa.gov/ttn/catc/dir1/icboiler.pdf

Cement Kilns (N6) ACT Document -- NOx Emissions from Cement 

Manufacturing (EPA-453/R-94-004, 3/94). Updated 

September 2000. Electronic copy of 1994 doc: 

http://www.epa.gov/ttn/catc/dir1/cement.pdf

Gas Turbines (N2) ACT Document -- NOx Emissions from Stationary Gas 

Turbines (EPA-453/R-93-007, 1/93). 

http://www.epa.gov/ttn/catc/dir1/gasturb.pdf

Glass Furnaces (N8) ACT Document -- NOx Emissions from Glass 

Manufacturing (EPA-453/R-94-037, 6/94). 

http://www.epa.gov/ttn/catc/dir1/glassact.pdf

Internal 

Combustion 

Engines 

 (N4) ACT Document -- NOx Emissions from Stationary IC 

Engines, (EPA-453/R-93-032, 7/93. Updated 9/2000. 

http://www.epa.gov/ttn/chief/old/ap42/roystuff/sect0302/rel_

c03s02_jul1993.pdf 

Iron and Steel (N9) NOx emissions from Iron and Steel Mills, EPA 453/R94-065, 9/94. EPA R9 has a copy. 

Municipal Waste 

Combustion 

 

 1. 40 CFR 60 subpart Cb - Emission Guidelines and 

Compliance Schedules for Municipal Waste Combustors. 

http://www.access.gpo.gov/cgibin/cfrassemble.cgi?title=200540

2. 40 CFR 62 subpart FFF, Federal Plan for existing large 

MWC units. 

http://www.access.gpo.gov/cgibin/cfrassemble.cgi?title=200540
 -9-

NOx Rules 1. Summary of State NOx RACT rules 9/29/95 

http://www.epa.gov/ttn/oarpg/t1/memoranda/noxregsm.pdf

2. Cost effective NOx RACT 3/16/94 

http://www.epa.gov/ttn/oarpg/t1/memoranda/noxregsm.pdf

3. De Minimis values for NOx RACT 1/1/95 

http://www.epa.gov/ttn/oarpg/t1/memoranda/demin.pdf

4. Scope of NOx Exemptions RACT 1/12/95 

http://www.epa.gov/ttn/oarpg/t1/memoranda/exempnox.pdf

5. Fuel switching to NOx RACT 7/30/93 

http://www.epa.gov/ttn/oarpg/t1/memoranda/fuelsw.pdf

6. Section 182(f) NOx Exemptions Revised Process and 

Criteria 2/8/95 

http://www.epa.gov/ttn/oarpg/t1/memoranda/noxexmp.pdf

7. NOx questions from Ohio EPA 1993 

http://www.epa.gov/ttn/oarpg/t1/memoranda/ohio.pdf

8. NOx RACT for Repowering of Utility Boilers 3/9/94 

http://www.epa.gov/ttn/oarpg/t1/memoranda/repower.pdf

9. NOx Exemptions Revised Process and Criteria 5/27/94 

http://www.epa.gov/ttn/oarpg/t1/memoranda/reproc.pdf

10. NOx Policy Documents for the CAA of 1990 

http://www.epa.gov/ttn/oarpg/t1/memoranda/ttnsum.pdf

PM 

 

Generic PM PM-10 Guideline Document (EPA-452/R-93-008, 4/93) 

Open Burning Guidelines - Open Burning Rule Exemption (EPA Region 

IX, 10/18/02). EPA R9 has an electronic copy. 

Residential 

Wood 

Combustion 

 1. Technical Information Document for Residential Wood 

Combustion (EPA-450/2-92-002, 9/92) 

www.epa.gov/clariton/clhtml/pubtitle.html

2. Guidelines - Minimum BACM/RACM for Residential 

Wood Combustion (EPA Region IX, 10/25/02). 

EPA R9 has an electronic copy. 

3. Available Residential Wood Combustion Control 

Measures (57 FR 18072, 4/28/92), RACT. 

Prescribed 

Burning 

 Prescribed Burning Control Measures (57 FR 18072, 

4/28/92), RACT. 

Fugitive Dust Available Fugitive Dust Control Measures (57 FR 18072, 

4/28/92), RACT. 

Opacity Final Disapproval of ADEQ Rule R18-2-702 for 

BACM/RACT analysis (Docket AZ-02-60F). 

(67 FR 59456 9/23/02) EPA R9 has an electronic copy. 

De Minimis 

Analysis 

 1. 59 FR 42011 (8/16/94) 

2. 40 CFR 51.165(b)(1). http://www.access.gpo.gov/cgibin/cfrassemble.cgi?title=200540

Other
 -10-

Cutback Asphalt (#12) Control of VOC from Use of Cutback 

Asphalt (EPA-450/2-77-037, NTIS PB 278-

185), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch04/s

05/reference/ref_03c04s05_1995.pdf 

Bakeries (A8) 1. ACT Document - Bakery Oven Emissions (EPA453/R-92-017,12/92) 

http://epa.gov/ttn/atw/bakery/bakery92.pdf 

2. Issues Concerning Bakery RACT Requirements 2/8/95 

http://www.epa.gov/ttn/oarpg/t1/memoranda/bakery.pdf

Dry Cleaning (#24) Control of VOC Emissions from Large 

Petroleum Dry Cleaners, EPA-450/3-82-009 

9/82, NTIS PB-83-124-875), CTG. EPA R9 

has an electronic copy. 

(#21) 1. Control of Volatile Organic Emissions from 

Perchloroethylene Dry Cleaning Systems (EPA-450/2-78-

050, 12/78, NTIS PB-290-613), (CTG no longer relevant 

as PERC is exempted as a VOC - however there is a 

MACT std for PERC drycleaners)

www.epa.gov/clariton/clhtml/pubtitle.html

Ethylene Oxide (A3) ACT Document - Ethylene Oxide 

Sterilization/Fumigation Operations (EPA-450/3-89-007, 

3/89, NTIS PB-90-131-434). 

Fertilizer Control of Fluoride Emissions From Existing Phosphate 

Fertilizer Plants (EPA-450/2-77-005, 3/77) 

http://www.epa.gov/ttn/chief/old/ap42/ch08/s051/reference/r

ef_06c08s051_1995.pdf 

Ink & Paint 

Manufacture 

 Control of VOC Emissions from Ink and Paint 

Manufacturing Processes (EPA-450/3-92-013, 4/92). 

Leather Tanning Air Emissions and Control Technology for Leather Tanning 

and Finishing Operations (EPA-453/R-93-025, 6/93). 

Nitric & Adipic 

Acid 

(N1) ACT Document -- Nitric and Adipic Acid 

Manufacturing Plants (EPA-450/3-91-026, 12/91). 

http://www.epa.gov/ttn/catc/dir1/nitric.pdf

Pesticides (A10) Control of VOC Emissions from the Application of 

Agricultural Pesticides (EPA-453/R-92-011, 3/93, NTIS PB93-199-131), ACT. 

Pharmaceutical 

Products 

(#17) Control of Volatile Organic Emissions 

from Manufacture of Synthesized 

Pharmaceutical Products (EPA-450/2-78-029, 

1278, NTIS PB-290-580), CTG. 

http://www.epa.gov/ttn/chief/old/ap42/ch06/s

10/reference/ref_01c06s10_1995.pdf (partial)
 -11-

Polyester Resin (#25) 1. Control of VOC Emissions from 

Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins (EPA450/3-83-008, 11/83, NTIS PB-84-134-600), 

CTG. 

http://www.epa.gov/clariton/clhtml/pubtitle.ht

ml

(#27) 2. Control of VOC Fugitive Emissions 

from Synthetic Organic Chemical Polymer 

and Resin Manufacturing Equipment (EPA450/3-83-006, 3/84,NTIS PB-84-189-372), 

CTG. 

http://www.epa.gov/clariton/clhtml/pubtitle.ht

ml

3. Control of VOC Emissions from Manufacture of StyreneButadiene Copolymers - Preliminary Draft CTG 4/81 

http://www.epa.gov/ttn/chief/old/ap42/ch06/s10/reference/re

f_01c06s10_1995.pdf 

(A6) 4. Polystyrene Foam Manufacturing (EPA 450/3-90-

020 NTIS PB91-102111) 

Rubber Tires (#18) Control of Volatile Organic Emissions 

from Manufacture of Pneumatic Rubber Tires 

(EPA-450/2-78-030, 12/78, NTIS PB-290-

557), CTG. 

www.epa.gov/clariton/clhtml/pubtitle.html

Sulfuric Acid Control of Sulfuric Acid Mist Emissions from Existing 

Sulfuric Acid Production Units (EPA-450/2-77-019, 9/77). 

http://www.epa.gov/ttn/chief/old/ap42/ch08/s10/reference/re

f_02c08s10_1995.pdf 

Wastewater (A9) 1. Control of VOC Emissions from Industrial 

Wastewater CTG draft EPA-453/D-93-056 9/92) 

http://www.epa.gov/clariton/clhtml/pubtitle.html

(A9) 2. ACT Document: Air Emissions from Industrial 

Wastewater (4/94), ACT consists of cover memo with option 

tables and CTG draft. 

http://www.epa.gov/ttn/oarpg/t1/memoranda/iwwact.zip

Source for most of EPA information above is: http://www.epa.gov/ttn/atw/ctg_act.html 

ACT Alternative Control Techniques Document 

CTG Control Techniques Guidelines Document 

FR Federal Register documents can be found at: http://www.gpoaccess.gov/fr/index.html

NTIS National Technical Information Service, 1-800-553-6847 

ZIP Compressed files with *.wpf are saved in Word Perfect format 

(XX ) EPA use - Bold coding refers back to OAQPS CTG/ACT listing (may change as OAQPS updates their list) 

 eg 4 = #4 of Pre 1990 CTGs 

 P4 = #4 of Post 1990 CTGs 

 A4 = #4 of the VOC ACTs 

 N4 = #4 of the NOx ACTs