## EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT



# REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) STATE
IMPLEMENTATION PLAN (SIP) UPDATE ANALYSIS STAFF REPORT

NOVEMBER 17, 2006This 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, 4/4/06This Page Intentionally Left Blank2006 RACT SIP Update Analysis November 7, 2006 Page 5

INTRODUCTION

El Dorado County is located in northern Califor nia, bordering Sacramento County to the west and the State of Nevada on the east. Air quality attain ment planning is under the jurisdiction of the El Dorado County Air Quality Management District (Distr ict). 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 M ountain 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 adj acent Sacramento Valley Air Basin (SVAB) and the lower elevations of the MCAB have summers t hat are hot and dry with temperatures usually in the 90s, which are conducive to ozone formati on. Prevailing winds from the west transport ozone from the San Franciso Bay Area and the Sa cramento Valley into the foothill and mountain

areas.

The portions of El Dorado County in the MC AB are included in the Sacramento Federal Ozone Non-Attainment Area (SFNA), which has been desi gnated 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 “s evere” 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 t hat 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 Cl ean Air Act require ozone non-attainment areas to implement Reasonably Available Control Technol ogy (RACT) for sources that are subject to Control Techniques Guideline (CTG) documents i ssued by U.S. EPA and for “Major Sources” of Volatile Organic Compounds (VOCs) and Oxi des 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 controll ed 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 lim itation that a particular source is capable of meeting by the application of technology (i.e., dev ices, systems, process modification, or other apparatus or techniques that reduce air polluti on) 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 thei r 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 eit her a new RACT determinat ion 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 pl ans 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 Ste ckel, U.S. EPA Office Rulemaking Chief, sent request letters to the California Air Resources Board (CARB). The letters concern District2006 RACT SIP Update Analysis November 7, 2006 Page 6

requirements and outlined a possible RACT SIP subm ittal 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 t here are no facilities in the District, and submit Negative Declarations stati ng 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 t he District used to: (1) determine that the District regulations fulfill RACT, (2) det ermine Negative Declarations needed for certain CTG categories, and (3) determine which Distri ct rules need to be submitted to U.S. EPA as revision to the SIP.

The District was requested to prepare a comp lete RACT SIP update analysis, covering Major Sources, non-Major CTG Sources, and non-CTG Majo r Sources. In addition, the District is required to implement an 8-hour Ozone Demonstr ation 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 Dor ado County has a full year ozone season, the required implementation date for the Di strict 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 severa l air quality attainment plans since 1991. The following table summarizes the District’s a ttainment plans. The District has also adopted over 100 new rules and amendments to meet the co mmitments 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 continuat ion 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 Prohibi tory 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 satisf ied the requirements of the U.S. EPA’s control measure standard, and (3) determine if a new ru le will need to be adopted for existing emission sources. The standards compared were Contro l 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 exis ting 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 ru les to determine if they fulfill RACT established by CTGs, (ACTs) and U.S. EPA gui delines 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 Distri ct is required by California Health and Safety Code (CH &SC) Sections 40914(a)(2) and 40920.6(a) to implement “All Feasible Control Measures” (A FCM) and “Best Available Retrofit Control Technology” (BARCT). In general, AFCM and BARCT requirements are more stringent than those previously estab lished 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 whet her the adopted rule met or exceeded the applicable CTG RACT requirements. All AC Ts 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 satisf actorily 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 lis ted in the April 4, 2006 U.S. EPA letter for which no sources currently exist in the District. T he 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 Negat ive Declarations) Sta ff 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 subm ittal 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 Dist rict 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 NO X 232 Biomass Boilers Camino

Sierra Pacific
Industries Boilers, Steam Generators and
Process Heaters VOC 234 VOC RACT RuleSierra Pacific
Industries Camino2006 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 Di strict rules that satisfy RACT requirements.

Part 2 - Negative Declaration (Negative Declarati on) for use with 8-hour Ozone Reasonably Available Control Technology (RACT) St ate 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 F ederal 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 “seri ous” non-attainment for ozone.

RACT requires that all non-attainment areas cl assified as “moderate” or above have RACT in place for source categories covered by a Cont rol 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 wi thin the non-attainment area that is subject to a CTG. Alternatively, if the finding is made t hat 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 proc ess is called “Negative Declaration” .

The District is required to subm it 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 si nce 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 certif y 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 s ources 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 Declar ations for public comment, and District Board consideration and approval. If approved by the District Board the Negativ e 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 s ubject 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 di splayed in the following tables. This SIP status study was necessary in order to determi ne 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 approv ed 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 com pared 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 recomm ends that these SIP submittals be found exempt from the California Environmental Quality Act (C EQA). The proposed submittals are exempt from CEQA as per Title 14, Calfornia Code of Regul ations, Chapter 3, Article 19, Section 15308, Actions by Regulatory Agencies for t he Protection of the Environment.



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

Rule
No. Rule Title PollutantControlled 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 NO x 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 t he 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 NO x 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 SI P 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 PollutantControlled 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 Y2006 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 ru les that satisfy Major Source RA CT 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 Dist rict 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 t here 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 Dist rict sources, the Negative Declaration of no existing Major Stationary VO C 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 Source s, for which District rules satisfying RACT had not been adopted. Staff recommends that the Di strict 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 Sour ces exist for which RACT measures have not been adopted.. Staff further recommends that thes e 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 Agencie s 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 Dist rict Board direct and approve the submittal of the specified rules, prev iously 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 S ection 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/clarit on/clhtml/pubtitle.html OR http://nepis.epa.gov/pubtitle.htm 3. Control Techniques for Nitrogen Oxides Emissions from Stationary Sources - Sec ond Edition (EPA-450-1-78-001),
1/78 http://www.epa.gov/ttn/c hief/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/cat c/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/c hief/old/ap42/ch04/ s091/reference/r ef_13c04s091_1995.pdf (A8) 2. Control Techniques for VOC Emissions fromStationary 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/oz one/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 SurfaceCoating Operations (EPA-450/2-76-028, 11/76, NTIS PB260-386), http://www.epa.gov/ttn/chief/o ld/ap42/ch04/s0227/reference/ ref_04c04s0227_1995.pdf

Adhesives &
Sealants

Aerospace (P4) Control of VOC Emissions from Coating Operations at Aero space Manufacturing and Rework Operations CTG & MACT (See 59FR 29216, 6/6/1994); CTG (Final), EPA453/R-97-004, 12/97). http://www.epa.gov/ttn/o arpg/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/c hief/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/c hief/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/c hief/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 MagnetWire, (EPA-450/2-77-033, 12/77, NTIS PB278-258), CTG. http://www.epa.gov/ttn/c hief/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/c hief/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/c hief/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/o arpg/t1/memoranda/s hip-1.zip http://www.epa.gov/ttn/o arpg/t1/memoranda/s hip-2.zip
and (P3) 2. CTG, see 61 FR 44050, 8/27/96. FR
notice: http://www.epa.gov/ttn/o arpg/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/c hief/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/c hief/old/ap42/ch04/s 0225/reference/ref_01c04s0225_1995.pdf

Wood Furniture (P2) Control of VOC Emissions from WoodFurniture 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/o arpg/t1/memoranda/ woodctg.zip http://www.epa.gov/ttn/atw/wood/ finalctg.pdf http://www.epa.gov/ttn/o arpg/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 - Gaso line Service Stations, (11/75), CTG. - EPA R9 has an electronic

copy 2. Technical Guidance -- Stag e 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 Ru le 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 OrganicChemical 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/clarit on/clhtml/pubtitle.html

Tank Trucks (#6) 1. Control of Hydrocarbons from TankTruck 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/cat c/dir1/procheat.pdf (N5) 2. ACT Document -- NOx Emissions from Utility Boilers (EPA-453/R-94-023, 3/94). http://www.epa.gov/ttn/c hief/old/ap42/ch01/ s01/reference/re f27_c01s01_1998.pdf (N7) 3. ACT Document -- NOx Emissions fromIndustrial/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 Emi ssions from Stationary Gas Turbines (EPA-453/R-93-007, 1/93). http://www.epa.gov/ttn/cat c/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/cat c/dir1/glassact.pdf

Internal
Combustion Engines (N4) ACT Document -- NOx Emi ssions from Stationary IC Engines, (EPA-453/R-93-032, 7/93. Updated 9/2000. http://www.epa.gov/ttn/chief/o ld/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 Exemp tions 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 Du st 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/c hief/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/c hief/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 C ontrol 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 ofAgricultural 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/c hief/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/clarit on/clhtml/pubtitle.ht
ml (#27) 2. Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymerand Resin Manufacturing Equipment (EPA450/3-83-006, 3/84,NTIS PB-84-189-372),
CTG. http://www.epa.gov/clarit on/clhtml/pubtitle.ht
ml 3. Control of VOC Emissions from Manufacture of StyreneButadiene Copolymers - Preliminary Draft CTG 4/81 http://www.epa.gov/ttn/c hief/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/c hief/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/clarit on/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/a tw/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 ar e 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