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TECHNICAL SUPPORT DOCUMENT

Reasonably Available Control Technology (RACT) for Volatile Organic Compounds 

(VOC) and Oxides of Nitrogen (NOx) Sources – Houston Galveston Brazoria (HGB) 1997 

8-Hour Ozone Nonattainment Area

EPA-R06-OAR-2012-0100
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This TSD reviews portions of two different SIP submittals from Texas. Specifically, the first 

submittal is Texas’ State Implementation Plan (SIP) revision dated June 13, 2007, and the second 

one is Texas’ SIP submittal of April 6, 2010. No material in either of these two SIP submittals 

was designated as Confidential Business Information (CBI). In this TSD we are reviewing the 

following components of the June 13, 2007, and April 6, 2010 SIP submittals.

Component #1 concerns the Voluntary Mobile Emissions Program (VMEP) commitment for the 

HGB area. Component #2 concerns review of the June 13, 2007 submittal and the April 6, 2010 

submittal for the HGB area 8-Hour VOC RACT evaluation purposes. In particular, as a part of 

component #2 review, we also utilize Appendix D of the April 6, 2010 submittal in concert with 

the June 13, 2007 submittal to evaluate the 8-Hour VOC RACT for the HGB area.

Table A – SIP submittal of 2007 and its components

Description - June 13, 2007 submittal Information

Voluntary Mobile Emissions Program (VMEP) commitment for the HGB area Component #1

Rule Project No. 2006-036-114-EN 

TxLED for Certain Marine Fuels 

Amendments to: §114.6, §114.319 

Date Adopted: May 23, 2007 

Date Filed with the Secretary of State: May 25, 2007 

Date Published in the Texas Register: June 8, 2007 

Date Effective: June 14, 2007

See October 

24, 2008 (73 

FR 63378)

Rule Project No. 2006-038-115-EN 

Control of VOC Emissions from Storage and Degassing Operations in HGB 

for the 8-Hour Ozone Standard 

Amendments to: §§115.112 - 115.117, 115.119, 115.541 - 115.547, 115.549; 

and New: §115.110 

Date Adopted: May 23, 2007 

Date Filed with the Secretary of State: May 25, 2007 

Date Published in the Texas Register: June 8, 2007 

Date Effective: June 14, 2007

See March 29, 

2010 (75 FR 

15348)

Component #1 (this component was evaluated by S. Rennie): 

What is EPA’s Voluntary Mobile Emission reduction Program (VMEP)?
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Voluntary mobile source strategies that attempt to complement existing regulatory programs 

through voluntary, non-regulatory changes in local transportation activities or changes in in-use 

vehicle and engine composition constitute the VMEP. EPA supports innovative methods in 

achieving air quality goals and the creation of viable voluntary mobile source air quality 

programs. The increasing cost of technological improvements to produce incrementally smaller 

reductions in grams per mile or grams per kilowatt-hour emission in the entire fleet of vehicles 

and engines suggests that supplemental or alternative approaches for reducing mobile source air 

pollution are necessary. 

The CAA allows SIP credit for new approaches to reducing mobile source emissions. This 

flexible approach is set forth in section 110 of the Act, and economic incentive provisions are in 

sections 182(g)(4)(A) and 108 of the Act. The credits generated through VMEP can be counted 

toward attainment and maintenance of the NAAQS. Up to 3% of the total future year emissions 

reductions of each pollutant required to attain the appropriate NAAQS may be claimed under the 

VMEP. Some voluntary mobile measures may also be implemented under authority of the 

Economic Incentives Program

What are the guidelines for creditability of emission reductions achieved under a VMEP?

The basic framework for ensuring SIP credit for VMEPs is spelled out in guidance issued under 

a memorandum from Richard D. Wilson, Acting Assistant Administrator for Air and Radiation, 

dated October 24, 1997, entitled “Guidance on Incorporating Voluntary Mobile Source Emission 

Reduction Programs in State Implementation Plans (SIPs).” While this guidance was later 

incorporated into another EPA guidance, “Implementing Bundled Measure into a State 

implementation Plan (SIP),” 1 the VMEP demonstration is based on the former and the mobile 

source portion of the latter. Generally, to obtain credit for a VMEP, a State submits a SIP that: 

1) identifies and describes a VMEP; 2) contains projections of emission reductions attributable to 

the program, along with any relevant technical support documentation; 3) commits to evaluation 

and reporting on program implementation and results; and 4) commits to the timely remedy of 

any credit shortfall should the VMEP not achieve the anticipated emission reductions. More 

 

1 Office of Air and Radiation, August 2005.
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specifically, the guidance suggests the following key points are considered for approval of 

credits. The credits should be:

1. Quantifiable - VMEP emission reductions must be quantifiable. The level of uncertainty in 

achieving emission reductions must be quantified, and this uncertainty must be reflected in the 

projected emission reductions claimed by the VMEP. VMEPs must also contain procedures 

designed to both evaluate program implementation and to report program results as described in 

the “Technical Support for VMEPs” portion of the guidance.

2. Surplus - VMEP emission reductions may not be substituted for mandatory, required 

emission reductions. States may submit to EPA for approval any program that will result in 

emission reductions in addition to those already credited in a relevant attainment or maintenance 

plan, or used for purposes of SIP demonstrations such as conformity, rate of progress, or 

emission credit trading programs.

3. Enforceable - VMEPs must be enforceable at the State and Federal levels. A State can adopt 

a measure into the SIP such that the State is obligated only to track, assess and report on the 

implementation of voluntary actions and the emission reductions achieved from the voluntary 

actions. The State is not responsible, necessarily, for implementing a program depending on 

voluntary actions. The State must commit to conducting program evaluations and reporting the 

results to EPA within an appropriate time-frame.

4. Permanent - VMEP emission reductions must continue at least for as long as the time period 

in which they are used by the applicable SIP demonstration.

5. Adequately Supported - VMEPs must demonstrate adequate personnel and program 

resources to implement the program. 

6. Consistent - VMEPs must be consistent with attainment of the standard and with and Rate of 

Progress requirements. Further, VMEPs cannot interfere with the other requirements of the 

Clean Air Act. 

What is the Background for the HGB VMEP Program?
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The State first established the VMEP program in the December 2000 1-hour ozone attainment 

demonstration for the HGB nonattainment area approved by EPA on November 14, 2001, 66 FR 

57160. In that initial action we approved VMEP emission reductions of 23 tpd of NOx (up to 

3% of the total needed for attainment) because the state was able to demonstrate that the HGB 

area’s ozone SIP VMEP met the criteria for credit in the SIP. The State showed that the credits 

were quantifiable, surplus, enforceable, permanent, adequately supported, and consistent with the 

SIP and the Act. The Houston-Galveston Area Council (H-GAC) implemented the VMEP 

programs in the HGB area, committing to evaluate each program to validate estimated credits, 

and reporting the emission reductions to the TCEQ. The State is responsible for verifying the 

reported emissions and timely remedy of any shortfall. The VMEP program can be revised by 

submitting substitute measures or additional measures as a SIP revision, which has been done 

with subsequent submittals.

In the mid-course review submitted December 1, 2004, it was noted that the VMEP program 

was not getting the projected 23 tpd in NOx reductions. Subsequently, we approved that revision 

and a supplemented VMEP program on September 6, 2006, 71 FR 52656, which revised credit 

taken for this program to 7 tpd. In that revision, certain mobile emission credits were 

recalculated using MOBILE6. In the earlier SIP submittal these credits were calculated using 

MOBILE5a.

What did the State submit?

In the June 13, 2007, submittal adopted May 23, 2007, the State includes seven program 

descriptions (Table B) that project emission reductions attributable to each voluntary 

commitment as part of the Houston-Galveston-Brazoria State Implementation Plan. This 

submittal builds upon the VMEP program established in previous SIP revisions as noted above. 

The additional commitment to reduce NOx by an estimated 2.82 tons per day, and are referred to 

as the Houston-Galveston Area Council (H-GAC) reductions. 

Table B. Voluntary Mobile Emission Reduction Programs and Credits Claimed 

Program Type 2009 NOx Benefits in Tons per Day

Public and Private Sector Clean Fuel Fleet 2.0
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Commute Solutions 

 - Compressed Work Week

 - Telecommuting Incentives or Mandates

 - Expanding Vanpooling

 - Internet Ridematching Service and 

Incentives

 - Personalized Rapid Transit and 

Subscription Service

0.77

Pooled Ownership of Vehicles 0.05

Total Benefits 2.82

All VMEP commitment emission reductions were calculated for 2009 and were not to be 

forecasted to estimate emission reductions for any other year. The measures will be in place for 

the life of the SIP, however, which makes them permanent. 

What did EPA’s analysis show?

Overall the VMEP projects are consistent with the SIP and fall within the 3% allowed by the 

guidance for voluntary mobile measures. None of the programs interferes with or are mandated 

by other Act requirements. Employee trip reduction is no longer required by the Act, so the 

Commute Solutions measures are allowed. Therefore all programs are surplus. 

Since the State committed in the December 2000 SIP to assure that any shortfall in VMEP 

credits would be made up with other measures not already in the SIP, the measures are 

enforceable. And since all measures will be in place by 2009 for a 2010 attainment date, and 

they will remain in place for the life of the SIP, the measures are considered permanent. 

Our analysis below further shows that each program is also quantifiable and adequately 

supported. Therefore all criteria for the VMEP have been met. 

Public and Private Sector Clean Fuel Fleet:

A description of this measure is found in Appendix A of the submittal, Voluntary Mobile Source 

Emission Reduction Programs for the Houston-Galveston-Brazoria Eight-Hour Ozone State 

Implementation Plan. This measure seeks to reduce on-road vehicle emissions through rapid 

turnover to newer, lower emitting engines, retrofit of existing engines with approved devices, or 

new, lower emission technologies. The target for this program will be heavy duty vehicles, 
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although other fleets can compete for the funds. Funding heavy duty vehicles is more cost 

effective than lighter vehicles. Funding for the program comes from CMAQ and TERP. 

Quantifying the emission reductions from this program is done by calculating the differences in 

emission standards for vehicles that are replaced by new, lower emission vehicles, or by using 

EPA’s diesel emission quantifier for calculating benefits of retrofits and other new technologies. 

Therefore, the state has demonstrated that this program measure is quantifiable and adequately 

supported. The emission reductions for this program are projected to be 2.0 tpd of NOx.

Commute Solutions

Summary descriptions of the Commute Solutions program Detailed descriptions of the five 

programs that make up Commute Solutions are found in Appendix A cited above. Detailed 

descriptions are found in Appendix C, Evaluation of Mobile Source Control Strategies for the 

Houston-Galveston-Brazoria State Implementation Plan (Drafted by Environ for the HoustonGalveston Area Council), of the submittal. The combined emission reduction for all Commute 

Solutions programs is projected to be 0.77 tpd of NOx.

Compressed Work Week:

A compressed work week program is already in place in the HGB nonattainment area, but this 

measure would aim to specifically increase the amount of compressed work weeks through a 

mandatory program that is not currently in place. This program would target 20% of Houston 

area employees for a 4/40 program (four 10 hour days per week). Emission reductions are 

calculated using the MOSERs2 method that takes into account variables for number of 

employees potentially affected, average round trip VMT, average light duty vehicle composite 

emission factors for NOx and VOC. Although costs for this hypothetical program are unknown, 

the cost to employers is considered minimal with offsetting benefits including decreased 

turnover, reduced parking demand, and possibly fewer sick days. The cost effectiveness of the 

program is approximately $4,200/ ton of NOx reduced. The analysis shows that this measure is 

quantifiable and could be adequately supported.

 

2 Mobile Source Emission Reduction Strategies. http://moser.tamu.edu/
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Telecommuting Incentives or Mandates:

A telecommuting program is already in place in the HGB nonattainment area with varying 

frequency, but this measure would aim to specifically increase the amount of telecommuting 

through a program that is not currently in place in which an employee would commit to teleworking once per week. The program would target 10% of the total employment in the HGB 

nonattainment area. Emission reductions are calculated using the MOSERs method that 

considers the average round trip VMT per participant, one day per week participation, and 

average light duty vehicle composite emission factors for NOx and VOC. The current program 

costs attributed to employer outreach and marketing by H-GAC and consultants is $2.5 

million/year. Although this program aims to be 100 times larger than the current program, an 

accurate cost cannot be calculated, and it is assumed that an addition $2.5 million would be 

allocated for the new program. Net benefits are not quantified, but may be as much as three 

times the program cost based on a JALA International example. Cost-effectiveness is about 

$6,400/ton of NOx reduced. The analysis shows that this measure is quantifiable and could be 

adequately supported.

Expanding Vanpooling:

The ongoing vanpooling program is anchored by METRO (the local transit agency), and consists 

of standard vanpools and a newer effort called “miniPOOL” to recruit participants. The aim of 

this measure would be to aggressively encourage vanpooling through improved coordination and 

implementation of the program, additional funding and improved marketing outreach. The goal 

is to increase ridership by three times the current number. The net decrease in VMT would be 

over 1million miles per day. Emission reductions are calculated using MOSERs methodology. 

Reductions are reduced by an additional 0.4 tpd from reductions already accounted for in the 

baseline modeling. Some of the additional cost of the program may be offset by “the application 

of revenue positive features such as limited in-van advertising.” The cost-effectiveness is 

estimated at about $36,700/ton of NOx reduced. The analysis shows that this measure is 

quantifiable and could be adequately supported.

Internet Ridematching Service and Incentives:
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This program is described as an H-GAC ridesharing program that uses computer-based methods 

to match riders for carpooling. It was started in August 2005. This program offers incentives to 

participate by offering gift cards and other similar benefits to participants based on the number of 

times they sign up for a carpool. The aim of this measure is to increase participation in the 

program from its infancy of 2,500 riders to 100,000 regular riders who would use this service on 

average two times per week. This program is available seven days a week, and so can provide 

additional reductions that other commuter programs would not ordinarily do. The VMT 

reductions are calculated with MOSERs methodology using the number of ridesharers, miles of 

carpooling, miles driven by the carpool driver, and frequency of ridesharing. A budget of $1.5 

million is expected to be sufficient to accommodate the larger ridership. Sign up for the program 

is free to the riders, so the program cost must be borne by H-GAC. The cost-effectiveness is 

about $15,200/ton of NOx reduced. The analysis shows that this measure is quantifiable and 

could be adequately supported.

Personalized Rapid Transit and Subscription Service:

This innovative program would be designed to remove obstacles to transit use by providing more 

personalized services between residential areas and employment areas. This might include online transit planning, subscription bus service, and feeder shuttles from major transit stops to 

work centers. Buses and vans may be equipped with wireless Internet connections and 

accommodate working in transit with fold-down tables. The analysis envisions 100 business 

buses and 100 shuttle buses. The program area would include underserved residential areas too 

far from transit center or park and ride and employment areas in downtown Houston which do 

not have sufficient transit access. 

Calculation of emission reductions is by MOSERs methodology that relied on the following key 

variables:

•100 buses seating 35 people operating four round trips (per person) per day; at 80% capacity 

this is equivalent to 11,200 people per work day;

•100 shuttle buses seating 15 people operating 6 round trips (per person) per day; at 80% 

capacity this is equivalent to 7,200 people per work day.
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•100% of shuttle use is due to new transit users who did not previously use transit because it did 

not provide a viable way to their place of employment or their home.

•average work trip distance is 40 miles round trip business buses travel 40 miles for each round 

trip, or 160 miles each day per bus; new emissions due to these buses is therefore based upon an 

average weekday mileage of 16,000 miles.

•shuttle buses are assumed to travel 10 miles per round trip, or 60 miles per day per shuttle; new 

emissions due to the shuttles is therefore based upon an average weekday shuttle mileage of 

6,000 miles.

•Average light duty vehicle composite emission factor for NOx for same day is 0.471 grams per 

mile

•Average light duty vehicle composite emission factor for VOC for same day is 0.489 grams per 

mile.

•Average shuttle bus emissions are represented by the MOBILE6 category LDDT12 and are 

2.68 grams per mile of NOx and 2.56 grams per mile of VOC.

•Average transit bus emissions are represented by the MOBILE6 HDDBS category and are 9.83 

grams per mile NOx and 0.57 grams per mile VOC.

The cost of the program is estimated at over $45.6 million/year (in 2005-2006 $) not including 

marketing and administration. Riders will pay $2 to $5 per round trip. Selling ad space inside 

the vehicles will also be considered as a way to help pay for the service. Annual NOx reduction 

benefits are 54.6 tons, with cost effectiveness at $500,000/ton. The analysis shows that this

measure is quantifiable and could be adequately supported.

Pooled Ownership of Vehicles

A detailed description of this program is found in Appendix C, Evaluation of Mobile Source 

Control Strategies for the Houston-Galveston-Brazoria State Implementation Plan (Drafted by 

Environ for the Houston-Galveston Area Council), of the submittal. This is a car-sharing 

program with vehicles based at transit stations for use by employees to dispersed work locations. 

These vehicles are referred to as station cars. The analysis assumes 10,000 station cars used by 

10 people per car. Calculation of the emission reduction from VMT by this program was done 

using the basic process suggested by the MOSERs methodology. Depending on how the 

program is structured, the cost per ton of NOx could range from $0 to $14,000. The cost would 

be borne by the station car users, and some other entity (presumably H-GAC) for marketing and 
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administration. This measure was estimated to provide 0.05 tpd of NOx reductions. The 

analysis shows that this measure is quantifiable and could be adequately supported.

Conclusion for Component #1: The HGB 8-Hour SIP revision of the VMEP meets the criteria 

for credit in the SIP. The State has shown that the credits are quantifiable, surplus, enforceable, 

permanent, adequately supported, and consistent with the SIP and the Act. We recommend 

proposing approval of the VMEP portion of the HGB 8-hour SIP.
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Component #2: This part of the TSD concerns our review of the RACT-related provisions of 

the 30 TAC Chapter115 (for VOCs), and the 30 TAC Chapter117 (for NOx). RACT for major 

NOx sources is discussed following the major Non-CTG VOC sources in this document.

The EPA had previously approved RACT for VOC and NOx into Texas’ SIP under the 1-Hour

ozone standard. In this document we are addressing those portions of the SIP submittals 

concerning the following CTG categories for RACT purposes in the HGB 8-Hour ozone 

nonattainment area here. See Table C below for a listing of relevant portions of SIP submittal 

requiring action.

Table C – Entry Numbers, Relevant Portions of the SIP, and Their Corresponding Agreed Upon 

Deadline for the HGB Area.

Entry 

#

Area Portion of SIP Submittal Requiring Action

1 HGB RACT VOC CTG Bulk Gasoline Plants

2 HGB RACT VOC CTG Equipment Leaks from Natural Gas/Gasoline Processing 

Plants

3 HGB RACT VOC CTG Fugitive Emissions from Synthetic Organic Chemical 

Polymer and Resin Manufacturing Equipment

4 HGB RACT VOC CTG leaks from Gasoline Tank Trucks and Vapor Collection 

Systems

5 HGB RACT VOC CTG Leaks from Petroleum Refinery Equipment

6 HGB RACT VOC CTG Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins

7 HGB RACT VOC CTG Manufacture of Pneumatic Rubber Tires

8 HGB RACT VOC CTG Manufacture of Synthesized Pharmaceutical Products

9 HGB RACT VOC CTG Petroleum Liquid Storage in External Floating Roof 

Tanks

10 HGB RACT VOC CTG Refinery Vacuum Producing Systems, Wastewater 

Separators, and Process Unit Turnarounds

11 HGB RACT VOC CTG SOCMI Air Oxidation Processes

12 HGB RACT VOC CTG SOCMI Distillation and Reactor Processes

13 HGB RACT VOC CTG Shipbuilding/Repair
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Entry 

#

Area Portion of SIP Submittal Requiring Action

14 HGB RACT VOC CTG Solvent Metal Cleaning

15 HGB RACT VOC CTG Stage I Vapor Control Systems – Gasoline Service 

Stations

16 HGB RACT VOC CTG Storage of Petroleum Liquids in Fixed Roof Tanks

17 HGB RACT VOC CTG Tank Truck Gasoline Loading Terminals

18 HGB RACT Non-CTG VOC for Major Sources

Table D below summarizes the affected source categories in the HGB area, CTG documents 

issued by EPA, and the corresponding Texas rules which address these CTG control 

requirements.

Table D: Listing of CTG Categories, EPA Reference Document, and Corresponding Texas rules

Entry # Source Category 

in HGB Area

CTG Reference Document Chapter 115, 

Fulfilling 

RACT

1 Bulk Gasoline 

Plants 

Control of Volatile Organic Emissions from 

Bulk Gasoline Plants, EPA-450/2-77-035

§115.211 – 219 

2 Natural 

Gas/Gasoline 

Processing 

Control of Volatile Organic Compound 

Equipment Leaks from Natural Gas/Gasoline 

Processing Plants, EPA-450/2-83-007

§115.352 – 359 

3 Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Compound 

Fugitive Emissions from Synthetic Organic 

Chemical Polymer and Resin Manufacturing 

Equipment, EPA-450/3-83-006.

§115.352 – 359 

4 Tank Trucks Control of Volatile Organic Compound Leaks 

from Gasoline Tank Trucks and Vapor 

Collection Systems, EPA-450/2-78-051.

§115.211 – 219 

and 

§115.234 – 239 

5 Refineries Control of Volatile Organic Compound Leaks 

from Petroleum Refinery Equipment, EPA450/2-78-036.

§115.352 – 359 

6 Synthetic Organic 

Chemical 

Control of Volatile Organic Compound 

Emissions from Manufacture of High-Density 

§115.120 – 129 
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Entry # Source Category 

in HGB Area

CTG Reference Document Chapter 115, 

Fulfilling 

RACT

Manufacturing 

Industry 

Polyethylene, Polypropylene, and Polystyrene 

Resins, EPA-450/3-83-008.

7 Rubber Tires Control of Volatile Organic Emissions from 

Manufacture of Pneumatic Rubber Tires, EPA450/2-78-030.

No existing 

major sources 

in HGB eighthour ozone area 

(SIC 3011)

8 Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Emissions from 

Manufacture of Synthesized Pharmaceutical 

Products, 450/2-78-029.

§115.531 – 539 

9 Petroleum Liquid 

Storage 

Control of Volatile Organic Emissions from 

Petroleum Liquid Storage in External Floating 

Roof Tanks, EPA-450/2-78-047.

§115.112 – 119 

10 Refineries Control of Refinery Vacuum Producing 

Systems, Wastewater Separators, and Process 

Unit Turnarounds, EPA-450/2-77-025.

§115.311 – 319 

and 

§115.131 – 139 

11 Synthetic Organic 

Chemical 

Manufacturing 

Industry 

Control of Volatile Organic Compound 

Emissions from Air Oxidation Processes in 

Synthetic Organic Chemical Manufacturing 

Industry, EPA-450/3-84-015.

§115.120 – 129 

12 Synthetic Organic 

Chemical 

Manufacturing 

Industry

Control of Volatile Organic Compound 

Emissions from Reactor Processes and 

Distillation Operations in Synthetic Organic 

Chemical Manufacturing Industry, EPA-450/4-

91-031.

§115.120 – 129 

13 Shipbuilding and 

Ship Repair 

Control Technique Guidelines for Shipbuilding 

and Ship Repair Operations, EPA-453/R-94-

032, April 1994 

§115.420 – 429 

14 Solvent Metal 

Cleaning

Control of Volatile Organic Emissions from 

Solvent Metal Cleaning, EPA-450/2-77-022.

§115.412 – 419 

and 

§115.420 – 429 

15 Gasoline Service 

Stations 

Design Criteria for Stage I Vapor Control 

Systems - Gasoline Service Stations.

§115.221 – 229 

16 Petroleum Liquid Control of Volatile Organic Emissions from §115.112 – 119 
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Entry # Source Category 

in HGB Area

CTG Reference Document Chapter 115, 

Fulfilling 

RACT

Storage Storage of Petroleum Liquids in Fixed Roof 

Tanks, EPA-450/2-77-036.

17 Tank trucks Control of Hydrocarbons from Tank Truck 

Gasoline Loading Terminals, EPA-450/2-77-

026.

§115.211 – 219 

or 

§115.221 – 229 

18 Non-CTG Major 

Sources

Not Applicable

What EPA document contains a list of questions and answers concerning relationship of 

the 1-Hour RACT and the 1997 8-Hour RACT?

The May 18, 2006 Memorandum from William T. Harnett, Director, Air Quality Policy Division 

to Regional Air Division Directors titled “RACT Qs & As – Reasonably Available Control 

Technology (RACT): Questions and Answers” (EPA’s May 18, 2006 RACT Q and A document) 

explains the relationship of the 1-Hour RACT and the 1997 8-Hour RACT in the form of a series 

of questions and answers. This document is available at 

http://www.epa.gov/ttn/oarpg/t1/memoranda/ractqanda.pdf (URL dating June 12, 2012).

What Framework did Texas use to conduct its RACT analysis? 

Texas submitted a RACT assessment in its SIP revisions of June 13, 2007 and April 6, 2010. In 

those submittals, Texas evaluated its existing RACT regulations which were federally approved 

and adopted to meet the 1-hour ozone standard to ascertain whether these regulations constitute 

RACT for the new 8-hour ozone NAAQS. Texas’ 8-Hour ozone RACT SIP submittals are based 

on the determination that RACT has been met either through a certification that previously 

required RACT controls for the 1-hour ozone standard represent RACT for 8-hour ozone 

implementation purposes or, where necessary, through a new RACT evaluation for certain 

regulations or sources. See section 3.3.2 of Appendix D, April 6, 2010 submittal. In making its 

8-Hour ozone RACT determination, Texas also relied on EPA’s May 18, 2006 RACT Q and A

document. See section 3.3 of Appendix D, April 6, 2010 submittal. Accordingly, the framework 

for Texas’ RACT SIP determination is to:
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• Identify all source categories covered by Control Technique Guidelines (CTG) and 

Alternative Control Technique (ACT) documents.

• Identify applicable regulations that implement RACT.

• Certify that the existing level of controls for the 1-hour ozone standard equals RACT 

under the 8-hour ozone standard, or

• Declare that sources covered by a CTG and ACT do not exist within the state and/or 

that RACT is not applicable in certain cases, or

• Identify potential RACT revisions necessary to implement RACT.

What is our review of Texas’ RACT analysis?

By approving RACT under the 1-Hour ozone standard (70 FR 58136, October 5, 2005; and 71 

FR 52676, September 6, 2006) we found that control measures in 30 TAC Chapter 115 meet the 

lowest emissions limitation that a particular source is capable of meeting by the application of 

control technology that is reasonably available, considering technological and economic 

feasibility. EPA’s May 18, 2006 RACT Q and A document recommends a State certify after 

review that its regulations continue to represent RACT for the 1997 8-Hour ozone NAAQS. The

certification approach is in agreement with the 70 FR 71612, November 29, 2008 (Final Rule to 

Implement the 8-Hour Ozone NAAQS). Also, see sections 3.1 and 3.3, Appendix D, April 6, 

2010 submittal.

The most recent revisions to Chapter 115 regulations corresponding to the newly-EPA-issued 

CTGs are not part of this rulemaking and are not discussed in this TSD. 

Each individual entry from the above Table D is discussed below for RACT purposes:

1 Bulk Gasoline Plants Control of Volatile Organic Emissions 

from Bulk Gasoline Plants, EPA-450/2-

77-035, December 1977 

§115.211 – 219 

Section 115.211 affects the Houston/Galveston areas requiring a VOC limit of 0.09 pound per 

1,000 gallons (10.8 mg/liter) of gasoline loaded into transport vessels.
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Section 115.212 concerns control requirements for nonattainment areas including the HGB area 

and the vapors from the transport vessel caused by the loading of VOC with a true vapor 

pressure greater than or equal to 0.5 psia under actual storage conditions must be controlled by at 

least a control efficiency of 90%, a vapor balance system, or a pressurized loading system. 

Section 115.213 provides for an alternative means control for VOCs and facilitates operational; 

flexibility for operations.

Section 115.214 provides for inspection requirements of the affected VOC loading and 

unloading sources in the HGB area ranging from visible liquid leaks, visible fumes to significant 

odors and prescribes what action to take.

Section 115.215 establishes what Test Methods are to be used to determine compliance. Some of 

these Test methods are: Flow rate. Test Methods 1-4 (40 Code of Federal Regulations (CFR) Part 

60, Appendix for determining flow rates, as necessary; Test Method 18 (40 CFR Part 60, 

Appendix A) for determining gaseous organic compound emissions by gas chromatography; Test 

Method 25 (40 CFR Part 60, Appendix A) for determining total gaseous non-methane organic 

emissions as carbon; Test Methods 25A or 25B (40 CFR Part 60, Appendix A) for determining 

total gaseous organic concentrations using flame ionization or non-dispersive infrared analysis. 

Adoption of these approved Test Methods will provide for federally enforceable mechanism for 

Chapter 115. 

Section 115.216 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of each volatile organic compound (VOC) loading or unloading operation in the HGB 

area is to maintain such records for 2 years. Implementing these measures facilitate lowering of 

VOC emissions.

Section 115.217 states what sources will not be subject to these requirements. This section will 

facilitate inspection and enforcement of the rule.

Section 115.219 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to. This section will assist with implementation of the rule. 

Sections 115.211-219 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Emissions from Bulk Gasoline Plants, EPA-450/2-77-035, 
18

December 1977. Based on EPA’s May 18, 2006 RACT Q and A document, the framework 

described above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 

29, 2008, that its level of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) 

we are proposing that the requirements established in sections 115.211-219 for Bulk Gasoline 

Plants represent RACT for this sector under the 8-Hour ozone NAAQS.

2 Natural Gas/Gasoline 

Processing 

Control of Volatile Organic Compound 

Equipment Leaks from Natural 

Gas/Gasoline Processing Plants, EPA450/2-83-007, December 1983 

§115.352 – 359 

Section 115.352 prohibits a component to be allowed to have a VOC leak for more than 15 

calendar days after the leak is found, establishes a general screening of 500 parts per million by 

volume (ppmv) above background levels, or the dripping or exuding of process fluid based on 

sight, smell, or sound; among other things. States that the first attempt at repair must be made no 

later than five calendar days after the leak is found and the component must be repaired no later 

than 15 calendar days after the leak is found; and requires using EPA Test method 21 for 

monitoring a component to show there is no longer a leak after adjustments or alterations to the 

component. This provision set forth what control requirements a source will be subject to.

Section 115.353 provides for the affected sources in the HGB area with an alternate method of 

control to document and demonstrate continuous compliance. This provision provides for 

operational flexibility to a source.

Section 115.354 establishes the Monitoring and Inspection Requirements identifying or taking 

into consideration the frequency, space and accessibility, safety factors, and test method as 

factors to determine compliance. Establishing these factors will assist with compliance.

Section 115.355 Sets forth Test Methods are to determine compliance. Among these methods are 

EPA Test Method 21 (40 CFR 60 appendix A), and American Society for Testing and Materials 

Test Methods D323, D2879, D4953, D5190, or D5191 for the measurement of Reid vapor 

pressure, adjusted for 68 degrees Fahrenheit (20 degrees Celsius) in accordance with American 

Petroleum Institute Publication 2517, Third Edition, 1989.

Section 115.356 establishes a mechanism and states what type of information an affected source 

in the HGB area is required to keep to demonstrate compliance. This section will facilitate 

inspection and enforcement of the rule.
19

Section 115.357 states when a natural gas/gasoline processing plant is not subject to an emission 

specification. This section will facilitate inspection and enforcement of the rule.

Section 115.358 provides for use of an alternative work practice as an optional alternative for 

compliance purposes. This section will promote operational flexibility.

Section 115.359 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the emission specifications; control requirements; and recordkeeping 

provisions of this sector. See 115.930 for compliance dates.

Sections 115.352-359 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing 

Plants, EPA-450/2-83-007, December 1983. Based on EPA’s May 18, 2006 RACT Q and A 

document, the framework described above, and TCEQ’s certification, a permissible approach per

70 FR 71612, November 29, 2008, that its level of control meets RACT (Appendix B of the June 

13, 2007 SIP submittal) we are proposing that the requirements established in sections 115.532-

539 for Vent Gas Control from Natural Gas/Gasoline Processing Plants represent RACT for the 

HGB area under the 8-Hour ozone NAAQS. 

3 Synthetic Organic 

Chemical 

Manufacturing Industry 

Control of Volatile Organic Compound 

Fugitive Emissions from Synthetic 

Organic Chemical Polymer and Resin 

Manufacturing Equipment, EPA-450/3-

83-006, March 1984 

§115.352 – 359 

Section 115.352 prohibits a component to be allowed to have a VOC leak for more than 15 

calendar days after the leak is found, establishes a general screening of 500 parts per million by 

volume (ppmv) above background levels, or the dripping or exuding of process fluid based on 

sight, smell, or sound; among other things. States that the first attempt at repair must be made no 

later than five calendar days after the leak is found and the component must be repaired no later 

than 15 calendar days after the leak is found; and requires using EPA Test method 21 for 
20

monitoring a component to show there is no longer a leak after adjustments or alterations to the 

component. This provision set forth what control requirements a source will be subject to.

Section 115.353 provides for the affected sources in the HGB area with an alternate method of 

control to document and demonstrate continuous compliance. This provision provides for 

operational flexibility to a source.

Section 115.354 establishes the Monitoring and Inspection Requirements identifying or taking 

into consideration the frequency, space and accessibility, safety factors, and test method as 

factors to determine compliance. Establishing these factors will assist with compliance.

Section 115.355 Sets forth Test Methods are to determine compliance. Among these methods are 

EPA Test Method 21 (40 CFR 60 appendix A), and American Society for Testing and Materials 

Test Methods D323, D2879, D4953, D5190, or D5191 for the measurement of Reid vapor 

pressure, adjusted for 68 degrees Fahrenheit (20 degrees Celsius) in accordance with the 

American Petroleum Institute Publication 2517, Third Edition, 1989.

Section 115.356 establishes a mechanism and states what type of information an affected source 

in the HGB area is required to keep to demonstrate compliance. This section will facilitate 

inspection and enforcement of the rule.

Section 115.357 states when a natural gas/gasoline processing plant is not subject to an emission 

specification. This section will facilitate inspection and enforcement of the rule.

Section 115.358 provides for use of an alternative work practice as an optional alternative for 

compliance purposes. This section will promote operational flexibility.

Section 115.359 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the emission specifications; control requirements; and recordkeeping 

provisions of this sector. See 115.930 for compliance dates.

Sections 115.352-359 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s

Control of Volatile Organic Compound Fugitive Emissions from Synthetic Organic Chemical 

Polymer and Resin Manufacturing Equipment, EPA-450/3-83-006, March 1984. Based on 

EPA’s May 18, 2006 RACT Q and A document, the framework described above, and TCEQ’s 

certification, a permissible approach per 70 FR 71612, November 29, 2008, that its level of 
21

control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are proposing that the 

requirements established in sections 115.532-539 for Synthetic Organic Chemical Manufacturing 

Industry represent RACT for the HGB area under the 8-Hour ozone NAAQS. 

4 Tank Trucks Control of Volatile Organic Compound 

Leaks from Gasoline Tank Trucks and 

Vapor Collection Systems, EPA-450/2-

78-051, December 1978

§115.211 – 219 

and 

§115.234 – 239 

Section 115.234 sets forth the inspection requirements to control VOC emissions leaks from 

transport vessels in the HGB area and prescribes what action to take. 

Section 115.235 establishes what Test Methods are to be used to determine compliance. 

Adoption of these approved Test Methods will provide for federally enforceable mechanism for 

Chapter 115. 

Section 115 .236 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of each transport vessel operating in the HGB area is to maintain such records for 2 

years. Implementing these measures facilitate lowering of VOC emissions.

Section 115.237 states what sources will not be subject to these requirements. This section will 

facilitate inspection and enforcement of the rule.

Section 115.239 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to. This section will assist with implementation of the rule. 

Sections 115.211 – 219 concern Loading and Unloading of Volatile Organic Compounds. 

Section 115.211 affects the Houston/Galveston areas requiring a VOC limit of 0.09 pound per 

1,000 gallons (10.8 mg/liter) of gasoline loaded into transport vessels. 

Section 115.212 concerns control requirements for nonattainment areas including the HGB area 

and the vapors from the transport vessel caused by the loading of VOC with a true vapor 

pressure greater than or equal to 0.5 psia under actual storage conditions must be controlled by at 

least a control efficiency of 90%, a vapor balance system, or a pressurized loading system. 

Section 115.213 provides for an alternative means control for VOCs and facilitates operational; 

flexibility for operations.
22

Section 115.214 provides for inspection requirements of the affected VOC loading and 

unloading sources in the HGB area ranging from visible liquid leaks, visible fumes to significant 

odors and prescribes what action to take.

Section 115.215 establishes what Test Methods are to be used to determine compliance. Some of 

these Test methods are: Flow rate. Test Methods 1-4 (40 Code of Federal Regulations (CFR) Part 

60, Appendix for determining flow rates, as necessary; Test Method 18 (40 CFR Part 60, 

Appendix A) for determining gaseous organic compound emissions by gas chromatography; Test 

Method 25 (40 CFR Part 60, Appendix A) for determining total gaseous non-methane organic 

emissions as carbon; Test Methods 25A or 25B (40 CFR Part 60, Appendix A) for determining 

total gaseous organic concentrations using flame ionization or non-dispersive infrared analysis. 

Adoption of these approved Test Methods will provide for federally enforceable mechanism for 

Chapter 115. 

Section 115.216 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of each volatile organic compound (VOC) loading or unloading operation in the HGB 

area is to maintain such records for 2 years. Implementing these measures facilitate lowering of 

VOC emissions.

Section 115.217 states what sources will not be subject to these requirements. This section will 

facilitate inspection and enforcement of the rule.

Section 115.219 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to. This section will assist with implementation of the rule. 

Sections 115.211-219 combined with sections 115.234 -239 will provide for lowering of VOC 

emissions from this sector. We have previously stated that VOC and NOx RACT requirements 

under the Act are in place for the HGB area for the 1-Hour ozone NAAQS (70 FR 58136, 

October 5, 2005; and 71 FR 52676, September 6, 2006), thus finding that these control measures 

meet those described in EPA’s Control of Volatile Organic Compound Leaks from Gasoline 

Tank Trucks and Vapor Collection Systems, EPA-450/2-78-051, December 1978. Based on 

EPA’s May 18, 2006 RACT Q and A document, the framework described above, and TCEQ’s 

certification, a permissible approach per 70 FR 71612, November 29, 2008, that its level of 

control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are proposing that the 

requirements established in sections 115.211-219 combined with sections 115.234 -239 for tank 

trucks represent RACT for this sector under the 8-Hour ozone NAAQS.
23

5 Refineries Control of Volatile Organic Compound 

Leaks from Petroleum Refinery 

Equipment, EPA-450/2-78-036, June 

1978 

§115.352 – 359 

Section 115.352 prohibits a component to be allowed to have a VOC leak for more than 15 

calendar days after the leak is found, establishes a general screening of 500 parts per million by 

volume (ppmv) above background levels, or the dripping or exuding of process fluid based on 

sight, smell, or sound; among other things. States that the first attempt at repair must be made no 

later than five calendar days after the leak is found and the component must be repaired no later 

than 15 calendar days after the leak is found; and requires using EPA Test method 21 for 

monitoring a component to show there is no longer a leak after adjustments or alterations to the 

component. This provision set forth what control requirements a source will be subject to.

Section 115.353 provides for the affected sources in the HGB area with an alternate method of 

control to document and demonstrate continuous compliance. This provision provides for 

operational flexibility to a source.

Section 115.354 establishes the Monitoring and Inspection Requirements identifying or taking 

into consideration the frequency, space and accessibility, safety factors, and test method as 

factors to determine compliance. Establishing these factors will assist with compliance.

Section 115.355 Sets forth Test Methods are to determine compliance. Among these methods are 

EPA Test Method 21 (40 CFR 60 appendix A), and American Society for Testing and Materials 

Test Methods D323, D2879, D4953, D5190, or D5191 for the measurement of Reid vapor 

pressure, adjusted for 68 degrees Fahrenheit (20 degrees Celsius) in accordance with American 

Petroleum Institute Publication 2517, Third Edition, 1989.

Section 115.356 establishes a mechanism and states what type of information an affected source 

in the HGB area is required to keep to demonstrate compliance. This section will facilitate 

inspection and enforcement of the rule.

Section 115.357 states what a polymer and resin manufacturing equipment in a SOCMI plant is 

not subject to an emission specification. This section will facilitate inspection and enforcement 

of the rule.

Section 115.358 provides for use of an alternative work practice as an optional alternative for 

compliance purposes. This section will promote operational flexibility.
24

Section 115.359 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the emission specifications; control requirements; and recordkeeping 

provisions of this sector. See 115.930 for compliance dates.

Sections 115.352-359 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment, EPA-450/2-

78-036, June 1978. Based on EPA’s May 18, 2006 RACT Q and A document, the framework 

described above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 

29, 2008, that its level of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) 

we are proposing that the requirements established in sections 115.532-539 for this sector 

represent RACT for the HGB area under the 8-Hour ozone NAAQS.

6 Synthetic Organic 

Chemical 

Manufacturing Industry 

Control of Volatile Organic Compound 

Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene 

Resins, EPA-450/3-83-008, November 1983 

§115.120 – 129 

Section 115.120 establishes definitions for terms relevant to Synthetic Organic Chemical 

Manufacturing Industry operation (from batch operation to reactor processes). Identifying these 

terms will assist with the applicability and compliance determination of the rule. 

Section 115.121 sets forth emission specifications requiring the affected sources to meet the 

respective control requirements established in 115.122.

Section 115.122 sets forth a control requirement of “a control efficiency of at least 90% or to a 

volatile organic compound (VOC) concentration of no more than 20 parts per million by volume 

(ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices” or use of a “controlled 

properly with a control efficiency of at least 98% or to a VOC concentration of no more than 20 

ppmv (on a dry basis corrected to 3.0% oxygen for combustion devices) for a smokeless flare. 

These conditions should assist in determining if control device is properly employed.

Section 115.123 requires an affected source in the HGB are when that a source seeking an 

alternate method of control to document and demonstrate continuous compliance.
25

Section 115.125 establishes what Test Methods are to be used to determine compliance. 

Adoption of these approved Test Methods will provide for federally enforceable mechanism for 

Chapter 115. Among these test methods are: US EPA Test Methods 1-4 for flow rate; Test 

Method 18, 25, 25A, 25 B, and 22.

Section 115.126 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of affected facility in the HGB area is to maintain, on site, such records for 5 years after 

December 31, 2000. Test results, exhaust gas temperature, exhaust gas VOC concentration, 

maximum flow rate of VOC are among information to be maintained. Implementing these 

measures facilitate lowering of VOC emissions.

Section 115.127 states what vent gas stream is not subject to an emission specification. This 

section will facilitate inspection and enforcement of the rule.

Section 115.129 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the Emission Specifications; Control Requirements; and Monitoring and 

Recordkeeping Requirements as soon as practicable, but no later than December 2007.

Sections 115.120-129 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Compound Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene Resins, EPA-450/3-83-008, November 1983. 

Based on EPA’s May 18, 2006 RACT Q and A document, the framework described above, and 

TCEQ’s certification that its level of control meets RACT (Appendix B of the June 13, 2007 SIP 

submittal) we are proposing that the requirements established in sections 115.532-539 

corresponding to Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene 

Resins represent RACT for the HGB area under the 8-Hour ozone NAAQS.

7 Rubber Tires Control of Volatile Organic Emissions from 

Manufacture of Pneumatic Rubber Tires, EPA450/2-78-030, December 1978 

No existing major 

sources in HGB 8-

hour ozone area 

(SIC 3011)
26

In the June 13, 2007, submittal Texas makes a negative declaration to the effect that there are no 

applicable sources of VOC located or operating in the HGB 1997 8-Hour ozone nonattainment,

area for the rubber tire manufacturing with the Standard Industrial Classification (SIC) 3011 that 

we have issued a reference CTG document for. As a result of this declaration we are not 

required to conduct a VOC RACT evaluation for the rubber tire manufacturing sector, at this

time. This approach is permissible within the above identified frame work and is in agreement 

with the 70 FR 71612, November 29, 2008 (Final Rule to Implement the 8-Hour Ozone 

NAAQS).

8 HGB Control of Volatile Organic Emissions from Manufacture of 

Synthesized Pharmaceutical Products, 450/2-78-029, 

December 1978

February 1, 2013

Section 115.531 establishes the vapor pressure and a corresponding maximum exhaust gas 

temperature requirement for the reactors, distillation units, crystallizers, centrifuges, vacuum 

dryers, loading facilities, and railcar deliveries to storage tanks.

Section 115.532 establishes control requirements for tanks (in-process and storage), centrifuges 

and filters. Also states that sources affected under 115.531 in the HGB area must be controlled 

by a system with a reduction efficiency of at least 90% of the uncontrolled emissions.

Section 115.533 provides for the affected sources in the HGB area to adopt an alternate method 

of control pending demonstration of continuous compliance or exemption criteria as the case 

might be. This provision provides for operational flexibility to a source.

Section 115.534 establishes that inspection for visible liquid leaks, visible fumes, or significant 

odors resulting from the transfer of VOC from trucks or railcars to storage tanks at loading 

facilities must be conducted by the owner or operator of any pharmaceutical manufacturing 

facility in the HGB area. Additionally, this provision states that VOC loading or unloading 

through the affected transfer lines shall be discontinued immediately when a leak is observed and 

shall not be resumed until the observed leak is repaired. This provision promotes a compliant and 

safe operation of the facility.

Section 115.535 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, Test methods 18, 25, 25A, and 25 B for determining 
27

concentrations, and ASTM Test Method D323-82 for the measurement of Reid vapor pressure, 

adjusted for actual storage temperature in accordance with API Publication 2517, Third Edition, 

1989. Use of approved test methods will facilitate compliance determination.

Section 115.536 sets forth what parameters are to be monitored and what records are to be 

maintained. Among the monitored parameters are the daily VOC emission rates, exhaust gas 

temperature, vapor pressure of materials transferred, and VOC concentrations of exhaust 

streams. Monitoring and recordings of this information will assist with compliance determination 

efforts.

Section 115.537 states what process or vents are not subject to emission specification or other 

provisions of this sector. This section will facilitate inspection and enforcement of the rule.

Section 115.539 set forth the pharmaceutical manufacturing facilities sources in which counties 

are subject to these control requirements. For compliance date see 115.930. 

Sections 115.531-539 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical 

Products, 450/2-78-029, December 1978. Based on EPA’s May 18, 2006 RACT Q and A 

document, the framework described above, and TCEQ’s certification, a permissible approach per 

70 FR 71612, November 29, 2008, that its level of control meets RACT (Appendix B of the June 

13, 2007 SIP submittal) we are proposing that the requirements established in sections 115.531-

539 for this sector represent RACT for the HGB area under the 8-Hour ozone NAAQS.

9 Petroleum Liquid 

Storage 

Control of Volatile Organic Emissions 

from Petroleum Liquid Storage in 

External Floating Roof Tanks, EPA450/2-78-047, December 1978 

§115.112 – 119 

Section 115.112 establishes the control requirements based on the true vapor pressure and tank 

capacity of the storage tank when VOCs Other than Crude Oil and Condensate are stored. See 

Table 1(a) of this section. Also establishes the control requirements based on the true vapor 

pressure and tank capacity of the storage tank when crude oil and condensate are stored in a tank. 

See Table II(a) of this section. This section also states that when a vapor control systems is used 
28

as a control device on any storage tank must maintain a minimum control efficiency of 90%. If a 

flare is used, it must be designed and operated in accordance with 40 Code of Federal 

Regulations §60.18(b) - (f) (as amended through December 22, 2008 (73 FR 78209)) and be lit at 

all times when VOC vapors are routed to the flare.

Section 115.113 provides for an alternate methods control condition upon demonstrating and 

documenting continuous compliance with the applicable control requirements or exemption 

criteria as the case might be. This provision provides for operational flexibility to a source.

Section 115.114 establishes what the inspection requirements for each affected tank are. This 

provision should facilitate compliance determination.

Section 115.115 set forth the parameters an affected source in the HGB area will need to 

monitor. For example, for a direct-flame incinerator, the owner or operator shall continuously 

monitor the exhaust gas temperature immediately downstream of the device; for a condensation 

system, the owner or operator shall continuously monitor the outlet gas temperature to ensure the 

temperature is below the manufacturer's recommended operating temperature for controlling the 

volatile organic compounds (VOC) vapors routed to the device; and for a carbon adsorption 

system or carbon adsorber the owner or operator shall continuously monitor the exhaust gas 

VOC concentration of a carbon adsorption system that regenerates the carbon bed directly to 

determine breakthrough (using EPA Test Method 21). These monitoring requirements will 

facilitate compliance determination.

Section 115.116 establishes the testing requirements for an affected facility in the HGB area. For 

example; for a vapor control system, other than a vapor recovery unit or a flare, an initial control 

efficiency test must be conducted in accordance with the approved test methods; and when A 

flare used to comply with the control requirements it must meet the design verification test 

requirements in 40 CFR §60.18(f) (as amended through December 22, 2008 (73 FR 78209)). In 

addition, if the vapor control system is modified in any way that could decrease the control 

efficiency of the system, then the device must be retested within 60 days of the modification.

Section 115.117 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, Test methods 18, 21, 22, 25, 25A, and 25 B. In 

addition, true vapor pressure must be determined using standard reference texts or American 

Society for Testing and Materials Test Method D323, D2879, D4953, D5190, or D5191 for the 
29

measurement of Reid vapor pressure, adjusted for actual storage temperature in accordance with 

American Petroleum Institute Publication 2517. Use of approved test methods will facilitate 

compliance determination.

Section 115.118 establishes specific equations to determine reportable emissions, and states that 

all records must be maintained for two years and be made available for review upon request by 

authorized representatives (including any local air pollution control agency with jurisdiction).

Section 115.119 establishes the date by which an affected source in the HGB area is to meet the 

applicable recordkeeping, monitoring, testing, and emission specifications requirements of this 

sector. The compliance schedule will make this particular provision of Chapter 115 federally 

enforceable.

Sections 115.112-119 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof 

Tanks, EPA-450/2-78-047, December 1978. Based on EPA’s May 18, 2006 RACT Q and A 

document, the framework described above, and TCEQ’s certification, a permissible approach per 

70 FR 71612, November 29, 2008, that its level of control meets RACT (Appendix B of the June 

13, 2007 SIP submittal) we are proposing that the requirements established in sections 115.112-

119 for this sector represent RACT for the HGB area under the 8-Hour ozone NAAQS.

10 Refineries Control of Refinery Vacuum Producing 

Systems, Wastewater Separators, and 

Process Unit Turnarounds, EPA-450/2-

77-025, October 1977 

§115.311 – 319 

and 

§115.131 – 139 

Section 115.311 states that no person maybe allowed to emit VOC from a steam ejector or 

mechanical vacuum pump in a petroleum refinery unless the vent stream is controlled properly in 

accordance with the prescribed control requirements of this sector, and also states that no person 

may be allowed to emit any VOC from a hotwell with a contact condenser unless the hotwell is 

covered and the vapors from the hotwell are controlled properly in accordance with prescribed 

control requirements of this sector.
30

Section 115.312 states that the Vent gas streams affected source in the HGB area must be 

controlled properly with a control efficiency of at least 90% or to a VOC concentration of no 

more than 20 ppmv on a dry basis corrected to 3.0% oxygen for combustion devices. For a 

direct-flame incinerator the conditions are at a temperature equal to or greater than 1,300 degrees 

Fahrenheit (704 degrees Celsius); a smokeless flare; or any other vapor control system are to be 

used. Establishing a minimum control requirement should assist in lowering the VOC in the 

affected area.

Section 115.313 provides for an alternate methods control condition upon demonstrating and 

documenting continuous compliance with the applicable control requirements or exemption 

criteria as the case might be. This provision provides for operational flexibility to a source.

Section 115.315 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, Test methods 18, 25, 25A, and 25 B for determining 

concentrations. Use of approved test methods will facilitate compliance determination.

Section 115.316 sets forth what parameters are to be monitored and what records are to be 

maintained. All records shall be maintained for two years and be made available for review upon 

request. Among such records are: continuous monitoring of the exhaust gas temperature 

immediately downstream of a direct-flame incinerator; continuous monitoring of temperatures 

upstream and downstream of a catalytic incinerator or chiller; continuous monitoring of the 

exhaust gas VOC concentration of any carbon adsorption system; and the results of any 

applicable testing conducted. Maintaining records and making them available for review or 

examination will assist with compliance determination.

Section 115.317 states what source may be exempt from these requirements. The only exemption 

is listed is for the vacuum-producing system emitting a combined weight of volatile organic 

compounds equal to or less than 100 pounds (45.4 kg) in Gregg, Nueces, and Victoria Counties. 

No exemption is listed in this source category within the HGB area.

Section 115.319 establishes what counties are subject to these requirements and by what date an 

affected source should comply with the applicable control requirements of the process unit 

turnaround and vacuum-producing systems in petroleum refineries. For compliance date see 

115.930.
31

Section 115.131 establishes an emission specification that any water separator equipped with a 

vapor recovery system shall reduce emissions such that the true partial pressure of the VOC in 

vent gases to the atmosphere will not exceed a level of 0.5 psia (3.4 kPa) in the HGB area.

Section 115.132 requires that any water separator which separates materials containing VOC 

obtained from any equipment which is processing, refining, treating, storing, or handling VOC, 

unless each compartment be controlled in one of the following ways: 1) the compartment totally 

encloses the liquid contents and has all openings (such as roof seals and access doors) sealed; 2) 

the compartment is equipped with a floating roof or internal floating cover which will rest on the 

surface of the contents and must be equipped with a closure seal or seals to close the space 

between the roof edge and tank wall; 3) the compartment is equipped with a vapor recovery 

system which satisfies the established emission specifications; and 4) once any water separator 

becomes subject to these emission specifications it will always be subject to them (the once in 

always in will apply even if the throughput or emissions later fall below the exemption limits). 

Establishing these requirements will assist in lowering the VOC levels for this sector in the HGB 

area.

Section 115.133 provides for an alternate methods control condition upon demonstrating and 

documenting continuous compliance with the applicable control requirements or exemption 

criteria as the case might be. This provision provides for operational flexibility to a source.

Section 115.135 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, Test methods 18, 25, 25A, and 25 B for determining 

concentrations. Also for determination of true vapor pressure at actual storage temperature this 

section requires using American Society for Testing Materials (ASTM) Test Methods D323, 

D2879, D4953, D5190, or D5191; using API Publication 2517, Third Edition, 1989 or standard 

reference texts to convert from Reid vapor pressure to true vapor pressure, where applicable are 

required. Use of approved test methods will facilitate compliance determination.

Section 115.136 sets forth what parameters are to be monitored and what records are to be 

maintained. Among such records are: the exhaust gas temperature immediately downstream of 

any direct-flame incinerator; the gas temperature immediately upstream and downstream of any 

catalytic incinerator or chiller; and the VOC concentration of any carbon adsorption system 

exhaust gas to determine if breakthrough has occurred. Affected owner or operator shall install 
32

and maintain monitors to continuously measure and record operational parameters of any 

emission control device installed to meet applicable control requirements. Such records must be 

sufficient to demonstrate proper functioning of those devices to design specifications. All records 

shall be maintained for two years and be made available for review upon request. Monitoring and 

keeping of these record will assist in compliance determination of the affected source in the 

HGB area. 

Section 115.137 states what source may be exempt from these requirements. Among exempted 

units are water separator used exclusively in conjunction with the production of crude oil or 

condensate is exempt from 115.132(a) of this title (relating to Control Requirements) if the 

emissions from the separator have a combined weight of VOC equal to or less than 100 pounds 

(45.4 kg) in any continuous 24-hour period. To ensure this provision is not abused this section 

states that “it is unacceptable to disconnect any of the multiple sources routed through a common 

vent for purposes of complying with this exemption.”

Section 115.139 establishes what counties are subject to these requirements and states that owner 

or operator of each VOC water separator shall continue to comply with the applicable VOC 

requirements of wastewater separators in the HGB area. For compliance date see 115.930. 

Sections 115.311-319 combined with sections 115.131-139 will provide for lowering of VOC 

emissions from this sector. We have previously stated that VOC and NOx RACT requirements 

under the Act are in place for the HGB area for the 1-Hour ozone NAAQS (70 FR 58136, 

October 5, 2005; and 71 FR 52676, September 6, 2006), thus finding that these control measures 

meet those described in EPA’s Control of Refinery Vacuum Producing Systems, Wastewater 

Separators, and Process Unit Turnarounds, EPA-450/2-77-025, October 1977. Based on EPA’s 

May 18, 2006 RACT Q and A document, the framework described above, and TCEQ’s 

certification, a permissible approach per 70 FR 71612, November 29, 2008, that its level of 

control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are proposing that the 

requirements established in sections 115.311-319 combined with sections 115.131-139 for this 

sector represent RACT for the HGB area under the 8-Hour ozone NAAQS.

11 Synthetic Organic 

Chemical 

Manufacturing Industry 

Control of Volatile Organic Compound 

Emissions from Air Oxidation Processes 

in Synthetic Organic Chemical 

§115.120 – 129 
33

Manufacturing Industry, EPA-450/3-84-

015, December 1984 

Section 115.120 establishes definitions for terms relevant to Synthetic Organic Chemical 

Manufacturing Industry operation (from batch operation to reactor processes). Identifying these 

terms will assist with the applicability and compliance determination of the rule. 

Section 115.121 sets forth emission specifications requiring the affected sources to meet the 

respective control requirements established in 115.122.

Section 115.122 sets forth a control requirement of “a control efficiency of at least 90% or to a 

volatile organic compound (VOC) concentration of no more than 20 parts per million by volume 

(ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices” or use of a “controlled 

properly with a control efficiency of at least 98% or to a VOC concentration of no more than 20 

ppmv (on a dry basis corrected to 3.0% oxygen for combustion devices) for a smokeless flare. 

These conditions should assist in determining if control device is properly employed.

Section 115.123 requires an affected source in the HGB are when that a source seeking an 

alternate method of control to document and demonstrate continuous compliance.

Section 115.125 establishes what Test Methods are to be used to determine compliance. 

Adoption of these approved Test methods will provide for federally enforceable mechanism for 

Chapter 115. Among these test methods are: US EPA Test Methods 1-4 for flow rate; Test 

Method 18, 25, 25A, 25 B, and 22.

Section 115.126 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of affected facility in the HGB area is to maintain, on site, such records for 5 years after 

December 31, 2000. Test results, exhaust gas temperature, exhaust gas VOC concentration, 

maximum flow rate of VOC are among information to be maintained. Implementing these 

measures facilitate lowering of VOC emissions.

Section 115.127 states what vent gas stream is not subject to an emission specification. This 

section will facilitate inspection and enforcement of the rule.

Section 115.129 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the Emission Specifications; Control Requirements; and Monitoring and 

Recordkeeping Requirements as soon as practicable, but no later than December 2007.

Sections 115.120-129 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 
34

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic 

Organic Chemical Manufacturing Industry, EPA-450/3-84-015, December 1984. Based on 

EPA’s May 18, 2006 RACT Q and A document, the framework described above, and TCEQ’s 

certification, a permissible approach per 70 FR 71612, November 29, 2008, that its level of 

control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are proposing that the 

requirements established in sections 115.120-129 for Vent Gas Control from Natural 

Gas/Gasoline Processing Plants represent RACT for this sector under the 8-Hour ozone NAAQS. 

12 Synthetic Organic 

Chemical 

Manufacturing Industry

Control of Volatile Organic Compound 

Emissions from Reactor Processes and 

Distillation Operations in Synthetic 

Organic Chemical Manufacturing 

Industry, EPA-450/4-91-031, August 

1993 

§115.120 – 129 

Section 115.120 establishes definitions for terms relevant to Synthetic Organic Chemical 

Manufacturing Industry operation (from batch operation to reactor processes). Identifying these 

terms will assist with the applicability and compliance determination of the rule. 

Section 115.121 sets forth emission specifications requiring the affected sources to meet the 

respective control requirements established in 115.122.

Section 115.122 sets forth a control requirement of “a control efficiency of at least 90% or to a 

volatile organic compound (VOC) concentration of no more than 20 parts per million by volume 

(ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices” or use of a “controlled 

properly with a control efficiency of at least 98% or to a VOC concentration of no more than 20 

ppmv (on a dry basis corrected to 3.0% oxygen for combustion devices) for a smokeless flare. 

These conditions should assist in determining if control device is properly employed.

Section 115.123 requires an affected source in the HGB are when that a source seeking an 

alternate method of control to document and demonstrate continuous compliance.

Section 115.125 establishes what Test Methods are to be used to determine compliance. 

Adoption of these approved Test methods will provide for federally enforceable mechanism for 
35

Chapter 115. Among these test methods are: US EPA Test Methods 1-4 for flow rate; Test 

Method 18, 25, 25A, 25 B, and 22.

Section 115.126 provides for Monitoring and Recordkeeping Requirements each owner or 

operator of affected facility in the HGB area is to maintain, on site, such records for 5 years after 

December 31, 2000. Test results, exhaust gas temperature, exhaust gas VOC concentration, 

maximum flow rate of VOC are among information to be maintained. Implementing these 

measures facilitate lowering of VOC emissions.

Section 115.127 states what vent gas stream is not subject to an emission specification. This 

section will facilitate inspection and enforcement of the rule.

Section 115.129 sets forth the compliance schedule for the HGB area that affected sources will 

need to adhere to the Emission Specifications; Control Requirements; and Monitoring and 

Recordkeeping Requirements as soon as practicable, but no later than December 2007.

Sections 115.120-129 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation 

Operations in Synthetic Organic Chemical Manufacturing Industry, EPA-450/4-91-031, August 

1993. Based on EPA’s May 18, 2006 RACT Q and A document, the framework described 

above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 29, 2008, 

that its level of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are 

proposing that the requirements established in sections 115.532-539 corresponding to Reactor 

Processes and Distillation Operations represent RACT for the HGB area under the 8-Hour ozone 

NAAQS.

13 Shipbuilding and Ship 

Repair 

Control Technique Guidelines for 

Shipbuilding and Ship Repair Operations, 

EPA-453/R-94-032, April 1994 

§115.420 – 429 

Section 115.420 sets forth relevant definitions used in relation with this sector. For example; 

ship, navigational aids specialty coating, shipbuilding and ship repair operations are among the 
36

ship building and ship repair-related definitions. The definitions facilitate with the applicability 

and implementation of the rule.

Section 115.421states that no person may cause, suffer, allow, or permit VOC emissions from 

the surface coating processes affected by paragraph 15 (specifically numerated paragraph) of this 

subsection to exceed the specified emission limits. Establishing the emission limits for marine 

coatings will assist with enforcement of the rule.

Section 115.422 for shipbuilding related operations requires that all handling and transfer of 

VOC-containing materials to and from containers, tanks, vats, drums, and piping systems must 

be conducted in a manner that minimizes spills; all containers, tanks, vats, drums, and piping 

systems must be free of cracks, holes, and other defects and remain closed unless materials are 

being added to or removed from them; and all organic solvent used for line cleaning or to clean 

spray guns must be pumped or drained into a normally closed container. Such control 

requirements will lead to lower VOC emissions while using organic solvents. 

Section 115.423 provides for an alternate methods control condition for surface coating 

processes. It also states that if a vapor control system is used to control emissions from coating 

operations the capture and abatement system shall be capable of achieving and maintaining 

emission reductions equivalent to the applicable emission limitations (section 115.421) and an 

overall control efficiency of at least 80% of the VOC emissions from those coatings. This section 

provides for operational flexibility to a source.

Section 115.424 states that the owner or operator of each surface coating process must provide 

samples, without charge, upon request by representatives of the executive director, EPA, or local 

air pollution control agency; and that the representative or inspector requesting the sample will 

determine the amount of coating needed to test the sample to determine compliance. This section 

will assist the field inspectors with obtaining necessary information to conduct their field duties 

and determine compliance.

Section 115.425 set forth the testing methods an affected source in the HGB area will need to 

conduct. The test methods are EPA Test Methods 1-4 for determining flow rate, and Test 

Methods 25, 25A, 25 B for determining VOC concentration, Method 24 (one hour bake), and 

ASTM Test Methods D 1186-06.01, D 1200-06.01, D 3794-06.01, D 2832-69, D 1644-75, and D 

3960-81. In addition, it requires conformance with the EPA guidelines series document 

"Procedures for Certifying Quantity of Volatile Organic Compounds (VOC) Emitted by Paint, 
37

Ink, and Other Coatings," EPA-450/3-84-019, as in effect December, 1984. Adoption of 

prescribed Test Methods will make the control requirements federally enforceable.

Section 115.426 sets forth what parameters an owner or operator will need to monitor and keep. 

A material data sheet shall be maintained which documents the VOC content, composition, 

solids content, solvent density, and other relevant information regarding each coating and solvent 

available for use in the affected surface coating processes sufficient to determine continuous 

compliance with applicable control limits; and records shall be maintained of the quantity and 

type of each coating and solvent consumed during the specified averaging period if any of the 

coatings, as delivered to the coating application system, exceed the applicable control limits. 

Such records shall be sufficient to calculate the applicable weighted average of VOC for all

coatings. Records will need to be maintained for two year and shall be made available upon 

request by representatives of the executive director, EPA, or any local air pollution control 

agency. These requirements will facilitate with compliance determination. 

Section 115.427 states that certain processes are exempt from the requirements this sector. This 

section will assist the field personnel with the applicability determination.

Section 115.429 states that owner or operator of each affected source in the HGB area is required 

to comply with the applicable recordkeeping, monitoring, testing, and emission specifications 

requirements of this sector. For compliance date see 115.930.

Sections 115.420-429 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control Technique Guidelines for Shipbuilding and Ship Repair Operations, EPA-453/R-94-032, 

April 1994. Based on EPA’s May 18, 2006 RACT Q and A document, the framework described 

above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 29, 2008, 

that its level of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are 

proposing that the requirements established in sections 115.420-429 for this sector represent 

RACT for the HGB area under the 8-Hour ozone NAAQS. 
38

14 Solvent Metal Cleaning Control of Volatile Organic Emissions 

from Solvent Metal Cleaning, EPA450/2-77-022, November 1977 

§115.412 – 419 

and 

§115.420 – 429 

Section 115.412 states that for degreasing processes (solvent cleaning) the affected source must 

adhere to specific control requirements when engaged in cold solvent cleaning; open-top vapor 

degreasing; and conveyorized degreasing activities. These prescribed restrictions should assist 

with lowering of VOC emissions.

Section 115.413 provides for an alternate methods control condition for solvent cleaning 

processes. For example; cold solvent cleaners must demonstrate an overall VOC emission 

reduction efficiency of 65% or greater; and open-top vapor or conveyorized degreasers must 

demonstrate an overall VOC emission reduction efficiency of 85% or greater to be considered as 

an acceptable alternative method of control. This section provides for operational flexibility to a 

source.

Section 115.415 establishes specific test methods for compliance purposes. Among these 

methods are EPA Test Methods 1-4 for determining flow rate, and Test Methods 25, 25A, 25 B 

for determining VOC concentration, and ASTM Test Method D323-89, ASTM Test Method 

D2879, ASTM Test Method D4953, ASTM Test Method D5190, or ASTM Test Method D5191 

for the measurement of Reid vapor pressure (RVP), adjusted for actual storage temperature 

according to American Petroleum Institute (API) Publication 2517, Third Edition, 1989. 

Adoption of prescribed Test Methods will make the control requirements federally enforceable.

Section 115.416 sets forth what parameters an owner or operator will need to monitor and keep. 

Among these are a record of control equipment maintenance, such as replacement of the carbon 

in a carbon adsorption unit; and the results of all tests conducted at the facility in accordance 

with the requirements described in 115.415(2). Records will need to be maintained for two year 

and shall be made available upon request by representatives of the executive director, EPA, or 

any local air pollution control agency. These requirements will facilitate with compliance 

determination.

Section 115.417 states that certain processes are exempt from the requirements this sector. This 

section will assist the field personnel with the applicability determination.

Section 115.419 states that owner or operator of each solvent using-processes (degreasing 

processes) in the HGB area are required to comply with the applicable recordkeeping, 
39

monitoring, testing, and emission specifications requirements of this sector. For compliance date 

see 115.930.

Section 115.420 sets forth relevant definitions used in relation with this sector. For example; 

ship, navigational aids specialty coating, shipbuilding and ship repair operations are among the 

ship building and ship repair-related definitions. The definitions facilitate with the applicability 

and implementation of the rule.

Section 115.421states that no person may cause, suffer, allow, or permit VOC emissions from 

the surface coating processes affected by paragraph 15 (specifically numerated paragraphs) of 

this subsection to exceed the specified emission limits. Establishing the emission limits for 

marine coatings will assist with enforcement of the rule.

Section 115.422 for shipbuilding related operations requires that all handling and transfer of 

VOC-containing materials to and from containers, tanks, vats, drums, and piping systems must 

be conducted in a manner that minimizes spills; all containers, tanks, vats, drums, and piping

systems must be free of cracks, holes, and other defects and remain closed unless materials are 

being added to or removed from them; and all organic solvent used for line cleaning or to clean 

spray guns must be pumped or drained into a normally closed container. Such control 

requirements will lead to lower VOC emissions while using organic solvents. 

Section 115.423 provides for an alternate methods control condition for surface coating 

processes. It also states that if a vapor control system is used to control emissions from coating 

operations the capture and abatement system shall be capable of achieving and maintaining 

emission reductions equivalent to the applicable emission limitations (section 115.421) and an 

overall control efficiency of at least 80% of the VOC emissions from those coatings. This section 

provides for operational flexibility to a source.

Section 115.424 states that the owner or operator of each surface coating process must provide 

samples, without charge, upon request by representatives of the executive director, EPA, or local 

air pollution control agency; and that the representative or inspector requesting the sample will 

determine the amount of coating needed to test the sample to determine compliance. This section 

will assist the field inspectors with obtaining necessary information to conduct their field duties 

and determine compliance.

Section 115.425 set forth the testing methods an affected source in the HGB area will need to 

conduct. The test methods are EPA Test Methods 1-4 for determining flow rate, and Test 
40

Methods 25, 25A, 25 B for determining VOC concentration, Method 24 (one hour bake), and 

ASTM Test Methods D 1186-06.01, D 1200-06.01, D 3794-06.01, D 2832-69, D 1644-75, and D 

3960-81. In addition, it requires conformance with the EPA guidelines series document 

"Procedures for Certifying Quantity of Volatile Organic Compounds (VOC) Emitted by Paint, 

Ink, and Other Coatings," EPA-450/3-84-019, as in effect December, 1984. Adoption of 

prescribed Test Methods will make the control requirements federally enforceable.

Section 115.426 sets forth what parameters an owner or operator will need to monitor and keep. 

A material data sheet shall be maintained which documents the VOC content, composition, 

solids content, solvent density, and other relevant information regarding each coating and solvent 

available for use in the affected surface coating processes sufficient to determine continuous 

compliance with applicable control limits; and records shall be maintained of the quantity and 

type of each coating and solvent consumed during the specified averaging period if any of the 

coatings, as delivered to the coating application system, exceed the applicable control limits. 

Such records shall be sufficient to calculate the applicable weighted average of VOC for all 

coatings. Records will need to be maintained for two year and shall be made available upon 

request by representatives of the executive director, EPA, or any local air pollution control 

agency. These requirements will facilitate with compliance determination. 

Section 115.427 states that certain processes are exempt from the requirements this sector. This 

section will assist the field personnel with the applicability determination.

Section 115.429 states that owner or operator of each affected process in the HGB area is 

required to comply with the applicable recordkeeping, monitoring, testing, and emission 

specifications requirements of this sector. For compliance date see 115.930.

Sections 115.420-429 combined with section 115.412-419 will provide for lowering of VOC 

emissions from this sector. We have previously stated that VOC and NOx RACT requirements 

under the Act are in place for the HGB area for the 1-Hour ozone NAAQS (70 FR 58136, 

October 5, 2005; and 71 FR 52676, September 6, 2006), thus finding that these control measures 

meet those described in EPA’s Control of Volatile Organic Emissions from Solvent Metal 

Cleaning, EPA-450/2-77-022, November 1977. Based on EPA’s May 18, 2006 RACT Q and A 

document, the framework described above, and TCEQ’s certification, a permissible approach per 

70 FR 71612, November 29, 2008, that its level of control meets RACT (Appendix B of the June 

13, 2007 SIP submittal) we are proposing that the requirements established in sections 115.420-
41

429 combined with sections 115.412-419 for this sector represent RACT for the HGB area under 

the 8-Hour ozone NAAQS. 

15 Gasoline Service 

Stations 

Design Criteria for Stage I Vapor Control 

Systems - Gasoline Service Stations, 

November 1975 

§115.221 – 229 

Section 115.221 sets forth emission specifications by stating that no person shall transfer, or 

allow the transfer of, gasoline from any tank-truck tank into a stationary storage container which 

is located at a motor vehicle fuel dispensing facility, unless the displaced vapors from the 

gasoline storage container are controlled of a vapor control system which reduces the emissions 

of VOC to the atmosphere to not more than 0.8 pound per 1,000 gallons (93 mg/liter) of gasoline 

transferred; or a vapor balance system which is operated and maintained in accordance with the 

provisions of 115.222.

Section 115.222 states that vapor balance system will be assumed to comply with the specified 

emission limitation of if: the container is equipped with a submerged fill pipe and the path 

through the submerged fill pipe to the bottom of the tank must not be obstructed by a screen, 

grate, or similar device whose presence would preclude the determination of the submerged fill 

pipe's proximity to the tank bottom while the submerged fill tube is properly installed; a vaportight return line is connected before gasoline can be transferred into the storage container; the 

vapor return line's cross-sectional area is at least one-half of the product drop line's crosssectional area; and no avoidable gasoline leaks, as detected by sight, sound, or smell, exist 

anywhere in the liquid transfer or vapor balance systems. In addition, the only atmospheric 

emission during gasoline transfer into the storage container is through a storage container vent 

line equipped with a pressure-vacuum relief valve set to open at a pressure of no more than eight 

ounces per square inch (3.4 kPa).

Section 115.223 provides for an alternate methods control condition while vapor recovery 

system is capable of meeting the applicable performance requirements for Motor Vehicle Fuel 

Dispensing Facilities, as certified by third-party evaluation conducted by a qualified independent 

testing organization using a code or standard of practice and has been developed by a nationally 

recognized agency, association, or independent testing laboratory. This provision provides for 

operational flexibility to a source.
42

Section 115.224 establishes inspection requirements so that inspections for liquid leaks, visible 

vapors, or significant odors resulting from gasoline transfer shall be conducted at motor vehicle 

fuel dispensing facilities. Gasoline transfer shall be discontinued immediately when a leak is 

observed and shall not be resumed until the observed leak is repaired; and the gasoline tank-truck 

tank must have been inspected for leaks within one year as evidenced by a prominently displayed 

certification affixed near the United States Department of Transportation certification plate. The 

inspection requirement will assist with compliance determination of the source in the HGB area.

Section 115.225 set forth the testing methods an affected source in the HGB area will need to 

conduct. The test methods are EPA Test Methods 1-4 for determining flow rate, and Test 

Methods 18, 25, 25A, 25 B for determining VOC concentration, and Test Method 21for 

determining volatile organic compound leaks. Adoption of approved Test methods will make the 

control requirements federally enforceable.

Section 115.226 sets forth the type of records an affected source in the HGB area should 

maintain and make them available for review or inspection upon request. Some of these records 

include: dates on which gasoline was delivered to the dispensing facility and the identification 

number and date of the last leak testing; a record of the results of any testing conducted at the 

motor vehicle fuel dispensing facility. The records must contain the calendar month and year, 

and the total facility gasoline throughput for each calendar month. Maintaining records and 

keeping them on site for two years will assist with compliance determination of the affected site. 

Section 115.227 states that the motor vehicle fuel dispensing facility which has dispensed no 

more than 10,000 gallons of gasoline in any calendar month after January 1, 1991, and for which 

construction began prior to November 15, 1992, are exempt from the requirements this sector. 

This section will assist the field personnel with the rule applicability determination.

Section 115.229 states that owner or operator of each motor vehicle fuel dispensing facility in the 

HGB area are required to comply with the applicable recordkeeping, monitoring, testing, and 

emission specifications requirements of this sector. For compliance date see 115.930.

Sections 115.221-229 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Design Criteria for Stage I Vapor Control Systems - Gasoline Service Stations, November 1975. 
43

Based on EPA’s May 18, 2006 RACT Q and A document, the framework described above, and 

TCEQ’s certification, a permissible approach per 70 FR 71612, November 29, 2008, that its level 

of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) we are proposing that 

the requirements established in sections 115.221-229 for this sector represent RACT for the 

HGB area under the 8-Hour ozone NAAQS.

16 Petroleum Liquid 

Storage 

Control of Volatile Organic Emissions 

from Storage of Petroleum Liquids in 

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

December 1977 

§115.112 – 119 

Section 115.112 establishes the control requirements based on the true vapor pressure and tank 

capacity of the storage tank when VOCs Other than Crude Oil and Condensate are stored. See 

Table 1(a) of this section. Also establishes the control requirements based on the true vapor 

pressure and tank capacity of the storage tank when crude oil and condensate are stored in a tank. 

See Table II(a) of this section. This section also states that when a vapor control systems is used 

as a control device on any storage tank must maintain a minimum control efficiency of 90%. If a 

flare is used, it must be designed and operated in accordance with 40 Code of Federal 

Regulations §60.18(b) - (f) (as amended through December 22, 2008 (73 FR 78209)) and be lit at 

all times when VOC vapors are routed to the flare.

Section 115.113 provides for an alternate methods control condition upon demonstrating and 

documenting continuous compliance with the applicable control requirements or exemption 

criteria as the case might be. This provision provides for operational flexibility to a source.

Section 115.114 establishes what the inspection requirements for each affected tank are. This 

provision should facilitate compliance determination.

Section 115.115 set forth the parameters an affected source in the HGB area will need to 

monitor. For example, for a direct-flame incinerator, the owner or operator shall continuously 

monitor the exhaust gas temperature immediately downstream of the device; for a condensation 

system, the owner or operator shall continuously monitor the outlet gas temperature to ensure the 

temperature is below the manufacturer's recommended operating temperature for controlling the 

volatile organic compounds (VOC) vapors routed to the device; and for a carbon adsorption 

system or carbon adsorber the owner or operator shall continuously monitor the exhaust gas 
44

VOC concentration of a carbon adsorption system that regenerates the carbon bed directly to 

determine breakthrough (using EPA Test Method 21). These monitoring requirements will 

facilitate compliance determination.

Section 115.116 establishes the testing requirements for an affected facility in the HGB area. For 

example; for a vapor control system, other than a vapor recovery unit or a flare, an initial control 

efficiency test must be conducted in accordance with the approved test methods; and when A 

flare used to comply with the control requirements it must meet the design verification test 

requirements in 40 CFR §60.18(f) (as amended through December 22, 2008 (73 FR 78209)). In 

addition, if the vapor control system is modified in any way that could decrease the control 

efficiency of the system, then the device must be retested within 60 days of the modification.

Section 115.117 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, Test methods 18, 21, 22, 25, 25A, and 25 B. In 

addition, true vapor pressure must be determined using standard reference texts or American 

Society for Testing and Materials Test Method D323, D2879, D4953, D5190, or D5191 for the 

measurement of Reid vapor pressure, adjusted for actual storage temperature in accordance with 

American Petroleum Institute Publication 2517. Use of approved test methods will facilitate 

compliance determination.

Section 115.118 establishes specific equations to determine reportable emissions, and states that 

all records must be maintained for two years and be made available for review upon request by 

authorized representatives (including any local air pollution control agency with jurisdiction).

Section 115.119 establishes the date by which an affected source in the HGB area is to meet the 

applicable recordkeeping, monitoring, testing, and emission specifications requirements of this 

sector. The compliance schedule will make this particular provision of Chapter 115 federally 

enforceable.

Sections 115.112-119 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks, 

EPA-450/2-77-036, December 1977. Based on EPA’s May 18, 2006 RACT Q and A document, 
45

the framework described above, and TCEQ’s certification, a permissible approach per 70 FR 

71612, November 29, 2008, that its level of control meets RACT (Appendix B of the June 13, 

2007 SIP submittal) we are proposing that the requirements established in sections 115.112-119 

for this sector represent RACT for the HGB area under the 8-Hour ozone NAAQS. 

17 Tank trucks Control of Hydrocarbons from Tank Truck Gasoline 

Loading Terminals, EPA-450/2-77-026, December 

1977 

§115.211 – 219 

or 

§115.221 – 229 

Section 115.112 establishes the control requirements based on the true vapor pressure and tank 

capacity of the storage tank when VOCs Other than Crude Oil and Condensate are stored. See 

Table 1(a) of this section. Also establishes the control requirements based on the true vapor 

pressure and tank capacity of the storage tank when crude oil and condensate are stored in a tank. 

See Table II(a) of this section. This section also states that when a vapor control systems is used 

as a control device on any storage tank must maintain a minimum control efficiency of 90%. If a 

flare is used, it must be designed and operated in accordance with 40 Code of Federal 

Regulations §60.18(b) - (f) (as amended through December 22, 2008 (73 FR 78209)) and be lit at 

all times when VOC vapors are routed to the flare.

Section 115.113 provides for an alternate methods control condition upon demonstrating and 

documenting continuous compliance with the applicable control requirements or exemption 

criteria as the case might be. This provision provides for operational flexibility to a source.

Section 115.114 establishes what the inspection requirements for each affected tank are. This 

provision should facilitate compliance determination.

Section 115.115 set forth the parameters an affected source in the HGB area will need to 

monitor. For example, for a direct-flame incinerator, the owner or operator shall continuously 

monitor the exhaust gas temperature immediately downstream of the device; for a condensation 

system, the owner or operator shall continuously monitor the outlet gas temperature to ensure the 

temperature is below the manufacturer's recommended operating temperature for controlling the 

volatile organic compounds (VOC) vapors routed to the device; and for a carbon adsorption 

system or carbon adsorber the owner or operator shall continuously monitor the exhaust gas 

VOC concentration of a carbon adsorption system that regenerates the carbon bed directly to 
46

determine breakthrough (using EPA Test Method 21). These monitoring requirements will 

facilitate compliance determination.

Section 115.116 establishes the testing requirements for an affected facility in the HGB area. For 

example; for a vapor control system, other than a vapor recovery unit or a flare, an initial control 

efficiency test must be conducted in accordance with the approved test methods; and when A 

flare used to comply with the control requirements it must meet the design verification test 

requirements in 40 CFR §60.18(f) (as amended through December 22, 2008 (73 FR 78209)). In 

addition, if the vapor control system is modified in any way that could decrease the control 

efficiency of the system, then the device must be retested within 60 days of the modification.

Section 115.117 set forth what test methods are to be used to determine compliance with 

emission specification or prescribed VOC control level. Among these tests are EPA Test 

Methods 1-4 for determining the flow rate, and Test Methods 18, 21, 22, 25, 25A, and 25 B. In 

addition, true vapor pressure must be determined using standard reference texts or American 

Society for Testing and Materials Test Method D323, D2879, D4953, D5190, or D5191 for the 

measurement of Reid vapor pressure, adjusted for actual storage temperature in accordance with 

American Petroleum Institute Publication 2517. Use of approved test methods will facilitate 

compliance determination.

Section 115.118 establishes specific equations to determine reportable emissions, and states that 

all records must be maintained for two years and be made available for review upon request by 

authorized representatives (including any local air pollution control agency with jurisdiction).

Section 115.119 establishes the date by which an affected source in the HGB area is to meet the 

applicable recordkeeping, monitoring, testing, and emission specifications requirements of this 

sector. The compliance schedule will make this particular provision of Chapter 115 federally 

enforceable.

Sections 115.112-119 will provide for lowering of VOC emissions from this sector. We have 

previously stated that VOC and NOx RACT requirements under the Act are in place for the HGB 

area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; and 71 FR 52676, 

September 6, 2006), thus finding that these control measures meet those described in EPA’s 

Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals, EPA-450/2-77-026, 

December 1977. Based on EPA’s May 18, 2006 RACT Q and A document, the framework 

described above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 
47

29, 2008, that its level of control meets RACT (Appendix B of the June 13, 2007 SIP submittal) 

we are proposing that the requirements established in sections 115.112-119 for this sector 

represent RACT for the HGB area under the 8-Hour ozone NAAQS. 

18 Non-CTG Major 

Sources

April 6, 2010 

Submittal

Emission Inventory, Title V database

VOC:

RACT for major VOC sources that do not fall into one of the above sector categories identified 

in Table C of this TSD, and are located in the HGB area is discussed here. The major source 

definition for the HGB area, classified as severe, is 25 TPY when uncontrolled. See section 

182(e) of the Act. For the list of major VOC sources in the HGB area we are using the Appendix 

D of the April 6, 2010 Submittal. As stated elsewhere in this document, TCEQ reviewed the 

point source emissions inventory and Title V databases to identify all major sources of NOX or 

VOC emissions. All sources in the Title V database that were listed as a major source for NOX

or VOC emissions and included in the RACT analysis. For illustration purposes a sample 

company from the Appendix D list is shown below.

Regulated 

Entity 

Number

Account Company SIC SIC Description Rules 

Addressing 

RACT

Annual 

TPY VOC

Notes

104499579 HGA050X King

Fabrication

3441 Fabricated 

Structural Metal

§115.420 -

§115.429

22.02

Since the point source emissions inventory database reports actual emissions rather than potential 

to emit, the TCEQ reviewed sources that reported actual emissions as low as 10 tpy of NOX or 

VOC to account for the difference between actual and potential emissions. To be conservative, 

sites from the emissions inventory database with emissions of 10 tpy or more of NOX or VOC 

that were not identified in the Title V database and could not be verified as minor sources by 

other means are also included in the RACT analysis. For illustration purposes another sample 

company from Appendix D of the April 6, 2010 Submittal is shown below.

Regulated 

Entity 

Number

Account Company SIC SIC Description Rules 

Addressing 

RACT

Annual 

TPY VOC

Notes

100699230 HG7418U Bimbo 

Bakeries 

USA Inc.

2051 Bread, Cake & 

Related Products

§115.120 –

§115.129

10.21 Either Controlled by 

§115.120 - §115.129, or 

Below Exemption 
48

Threshold for Minor 

Sources

For a complete listing of Non-CTG emission sources in the HGB area see pages D-48 through D81 of the Appendix D, April 6, 2010 SIP submittal. Appendix D was provided in e-format as a 

part of the April 6, 2010 SIP submittal. We have reviewed TCEQ’s approach and RACT 

determination, and agree with their approach to include these sources in the inventory of the 

sources, and their RACT determination. We are proposing to approve TCEQ’s approach and 

RACT determination for the Non-CTG major sources of VOC in the HGB area under the 8-Hour 

ozone NAAQS.

Therefore, by implementing the 30 TAC Chapter 115 control requirements, individually 

described for entries 1-18 above, Texas has the 8-Hour RACT in place for VOC sources in the 

HGB area.

NOx:

Using a similar approach, RACT for major NOx sources that are located in the HGB area is 

discussed here. The major source definition for the HGB area, classified as severe, is 25 TPY 

when uncontrolled. See section 182(e) of the Act. For the list of major NOx sources in the HGB 

area, we are using the Appendix D of the April 6, 2010 Submittal. As stated elsewhere in this 

document, TCEQ reviewed the point source emissions inventory and Title V databases to 

identify all major sources of NOX or VOC emissions. All sources in the Title V database that 

were listed as a major source for NOX or VOC emissions and included in the RACT analysis. 

Since the point source emissions inventory database reports actual emissions rather than potential 

to emit, the TCEQ reviewed sources that reported actual emissions as low as 10 tpy of NOX or 

VOC to account for the difference between actual and potential emissions. To be conservative, 

sites from the emissions inventory database with emissions of 10 tpy or more of NOX or VOC 

that were not identified in the Title V database and could not be verified as minor sources by 

other means are also included in the RACT analysis.

For a complete listing of NOx emission sources in the HGB area, see pages D-18 through D-47, 

Appendix D, April 6, 2010 SIP submittal. Appendix D was provided in e-format as a part of the 

April 6, 2010 SIP submittal. We have previously stated that NOx RACT requirements under the 

Act are in place for the HGB area for the 1-Hour ozone NAAQS (70 FR 58136, October 5, 2005; 
49

and 71 FR 52676, September 6, 2006). HGB Area has some of the most stringent NOx control 

requirements in the country. See http://www.tceq.texas.gov/airquality/airsuccess/airsuccess 

(URL dating June 25, 2012); and 

http://www.tceq.state.tx.us/assets/public/implementation/air/success/2010.01.10-

txOzoneNoxTrends.pdf (URL dating June 25, 2012) for State’s NOx emission trends. 

TCEQ has certified that its level of control meets RACT (Appendix D of the April 6, 2010 SIP 

submittal). We have reviewed TCEQ’s approach and RACT determination, and agree with their 

approach to include these sources in the inventory of the sources, and their RACT determination. 

Therefore, we are proposing that the requirements established in Chapter 117 for major sources 

in the HGB Area represent RACT under the 8-Hour ozone NAAQS. Therefore, by 

implementing the 30 TAC Chapter 117 control requirements Texas has the 8-Hour RACT in 

place for major NOx sources in the HGB area. We recommend proposing their approval into 

Texas SIP.

Conclusion for Component #2: The EPA had previously approved RACT for VOC and NOx 

into Texas’ SIP under the 1-Hour ozone standard, thus finding that these control measures result 

in the lowest emissions limitation that a particular source is capable of meeting through 

application of control technology that is reasonably available, considering technological and 

economic feasibility. Based on EPA’s May 18, 2006 RACT Q and A document, the framework 

identified above, and TCEQ’s certification, a permissible approach per 70 FR 71612, November 

29, 2008 (Final Rule to Implement the 8-Hour Ozone NAAQS), of its RACT we are proposing to 

approve the 30 TAC Chapter 115 control requirements as meeting RACT for VOC sources (both 

the CTG sources identified in Table C and all major Non-CTG sources) in the HGB 1997 8-Hour 

ozone nonattainment area. We are proposing to approve Texas’ negative declaration for the 

rubber tire manufacturing sector for the HGB 1997 8-Hour area. Therefore, by implementing the 

30 TAC Chapter 115 control requirements Texas has the 8-Hour RACT in place for VOC

sources identified in Table D in the HGB area. We recommend proposing their approval into 

Texas SIP. Similarly, we are proposing that the requirements established in Chapter 117 for 

major sources of NOx in the HGB Area represent RACT under the 8-Hour ozone NAAQS. 

Therefore, by implementing the 30 TAC Chapter 117 control requirements Texas has the 8-Hour 
50

RACT in place for major NOx sources in the HGB area. We recommend proposing their 

approval into Texas SIP.