BeVf)rly 

Governor 

Stan Meiburg 

Perdue 

Acting Regional Supervisor 

Director 

April 6, 2010 

U.S. Environmental Protection Agency, Region 4 

Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 30303-8909 

Dee Freeman 

Secretary 

Subject: Group I Control Technology Guidelines and Nitrogen Oxide and Volatile Organic 

Compounds Reasonably Available Control Technology for Major Sources 

Dear Mr. Meiburg: 

The North Carolina Division of Air Quality (NCDAQ) has determined that there are four (4) 

Group I Control Technology Guidelines (CTGs) categories for which there are no major sources in 

the Charlotte-Gastonia-Rock Hill, NC-SC (referred to as the Metrolina area) 1997 8-hour ozone 

moderate nonattainment area. This determination was based upon review of emissions inventory 

data and through consultation with the NCDAQ and Mecklenburg County Air Quality permitting 

staff. Therefore, North Carolina is making a negative declaration for the following categories: 

• Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment 

(EPA-450/2-78-036, 1978/06), 

• Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit 

Turnarounds (EPA-450/2-77 -026, 1977/1 0), 

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

Processing Plants (EPA -450/3-83-007, 1983/ 12), and 

• Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface 

Coating) (61 FR-44050 8/27/96, 1996/08). 

Additionally, please find attached the clarifying information your staff requested concerning 

how the NCDAQ has addressed the remaining Group I CTGs, as well as the Nitrogen Oxides 

(NOx) and Volatile Organic Compounds (VOC) Reasonably Available Control Technology 

(RACT) for major sources not covered by CTGs for the Metrolina area with respect to the 1997 

8-hour ozone national ambient air quality standard (NAAQS). Some of the RACT rules to address 

the 1997 8-hour ozone NAAQS have been submitted to your agency and are still waiting for 

federal approval into the SIP. These include 15A North Carolina Administrative Code (NCAC) 

2D .1402 and .1403, submitted on April6, 2007, January 31,2008 and February 3, 2010, arid 

15A NCAC 2D .0902 and .0909, submitted on April 6, 2007 and January 31, 2008. 

1641 Mail Service Center, Raleigh, North Carolina 27699-1641 

2728 Capital Blvd., Raleigh, NC 27604 

Phone: 919-733-3340 I FAX 91 9-"715·7175 I Internet: www.ncair.org 

An Equal OpportunityiAffirrnative Action Employer 

NOnehC 1' ort aro 1na 

!Vaturall!l 
Meiburg 

April 6, 2010 

Page 2 of2 

With the negative declarations in this letter, the NCDAQ believes that North Carolina has met 

the requirements for Group I CTGs and NOx and VOC RACT for major sources not covered by 

CTGs for the Metrolina area with respect to the 1997 8-hour ozone standard. 

This letter and the attached information was noticed for public comment. The opportunity to 

request a public hearing, in accordance with the Code of Federal Regulations (CFR), 40 CFR 

51.102, and the public comment period were noticed in the local newspaper on Friday, 

February 12, 2010. The public comment period was open from Friday, February 12, 2010, through 

Monday, March 22, 2010. There were no requests for a public hearing; therefore the hearing 

scheduled for March 22, 2010 was cancelled. The cancellation was communicated to the public on 

March 16, 2010, through the North Carolina Division of Air Quality's website. There were no 

comments received on this letter or the attached information. An electronic copy identical to the 

attachment to this letter is enclosed. If you have any questions regarding this submittal, please 

contact Laura Boothe at or (919) 733-1488 or Michael Abraczinskas at 

l!-!'.~1.!:~:_!2:':!~~_!'-1,'1£l~ -~,~~!-'"~-'~"-"- or (919) 715-3743. Thank you for your assistance with this 

matter. 

BKO/lab 

Attachment 

cc: Carol Kemker, USEPA 

Dick Schutt, USEP A 

Michael Abraczinskas, NCDAQ 

Laura Boothe, NCDAQ 

Don Willard, LUESA 

Sincer~Jy ... 

~~·~ 
Attachment 

 Page 1 

Clarifying Information for Group I Control Techniques Guidelines 

and Nitrogen Oxide and Volatile Organic Compounds 

Reasonably Available Control Technology for Major Sources 

Background 

On April 15, 2004, the USEPA designated areas as nonattainment for the 1997 8-hour ozone 

National Ambient Air Quality Standard (NAAQS). The Charlotte-Gastonia-Rock Hill, North CarolinaSouth Carolina area (referred to as the Metrolina area) was designated as a moderate nonattainment area 

and includes the entire counties of Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan and Union, Coddle 

Creek and Davidson Townships in Iredell County in North Carolina and the Rock Hill Metropolitan 

Planning Organization boundary in York County, South Carolina. 

Under Section 182(b)(2) and 182(f) of the Clean Air Act (CAA), states are required to revise their 

state implementation plans (SIP) to require that Reasonably Available Control Technology (RACT) apply 

to both Control Technique Guideline (CTG) sources and major non-CTG sources of volatile organic 

compounds (VOC) and nitrogen oxides (NOx). CTGs sources are those emissions sources for which the 

United States Environmental Protection Agency (USEPA) issues control techniques guidelines. 

Non-CTG sources are those major sources which are not subject to CTGs, but for which RACT is 

required. Using a phased approach, the USEPA has issued CTGs defining RACT for those 

categories of sources that emit the greatest amounts of VOC emissions in four groups. This 

document summarizes how the North Carolina Division of Air Quality (NCDAQ) has addressed the 

CTG categories included through Group I for which a negative declaration is not being made, as well 

as the NOx and VOC RACT for non-CTG major sources. 

For moderate nonattainment areas, major sources subject to RACT are those sources with the 

potential to emit (PTE) 100 tons per year or greater of VOC or NOx. The USEPA defines RACT as “the 

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

control technology that is reasonably available considering technological and economic feasibility.” 

North Carolina RACT Rules 

North Carolina RACT requirements consist of a combination of CTG category specific rules and 

case by case RACT rule provisions. North Carolina’s VOC RACT rules are found in 15A North Carolina 

Administrative Code (NCAC) 02D .0900, which initially became effective July 1, 1979. The NOx RACT 

rules are found in 15A NCAC 2D .1400, which initially became effective April 1, 1995. These original 

sets of rules have been amended and new rules adopted numerous times since their initial adoption. 

These rules have already been submitted to the USEPA for approval into the SIP for each of these 

amendments as they occurred over time. 

Most recently RACT related rule submissions for SIP approval have dealt with extending 

applicability to the areas designated nonattainment under the 1997 8-hour ozone standard and 

incorporation of contingency measures. As described in the June 15, 2007 attainment demonstration 

submittal (resubmitted November 12, 2009), the State’s RACT rules were amended effective March 1, 
Attachment 

 Page 2 

2007 for purposes of the 1997 8-hour ozone standard and required major sources of VOC and NOx in the 

North Carolina portion of the Metrolina nonattainment area to apply RACT and to establish the associated 

compliance schedule. 

The State rules have previously gone through North Carolina’s standard Administrative 

Procedures Act (APA) process including a 60 day public comment period prior to adoption and approval 

by the State’s Environmental Management Commission (EMC) and Rules Review Commission (RRC). 

These rules have already been submitted to the USEPA for approval as part of the SIP as detailed in this 

supplement. 

NOx RACT for Major Sources 

North Carolina’s NOx RACT rules consist of a combination of category specific rules and case 

by case RACT provisions which have been adopted, amended, and submitted to the USEPA over time for 

approval. On April 6, 2007 and January 31, 2008, the NCDAQ submitted to USEPA for approval rule 

amendments addressing NOx RACT requirements for major sources. The April 6, 2007 revisions 

consisted of amendments to 2D .1402, Applicability, to require major sources in the moderate 

nonattainment area to apply RACT and to 2D .1403, Compliance Schedules, to establish the RACT 

compliance deadline of April 1, 2009. The January 31, 2008 submittal consisted of amendments to 

2D .1402 to establish as a contingency measure major source applicability of RACT requirements to 

sources from 50 to 100 tons per year potential to emit PTE of NOx and to .1403 to establish a compliance 

schedule for such sources should the area become a serious nonattainment area. 

In addition to applicability and compliance schedule rules, 2D .1400 contains category specific 

RACT rules provisions, which include 2D .1407, Boilers and Indirect-Fired Process Heaters, 2D .1408, 

Stationary Combustion Turbines, and 2D .1409, Stationary Internal Combustion Engines, and initially 

became state effective as of July 18, 2002. Additionally, 2D .1413, Sources Not Otherwise Listed In This 

Section, requires major sources of NOx for which there is not a specific RACT rule in Section .1400 to 

apply case by case RACT which initially became state effective April 1, 1995, was amended effective 

July 18, 2002 and was most recently SIP approved December 27, 2002 (67 FR 78987). 

 Under the final Phase 2 8-hour ozone standard implementation rule (70 FR 71652), the USEPA 

determined that NOx RACT requirements have been satisfied for sources subject to the state’s emission 

cap-and-trade program that meets the NOx SIP Call requirements or, in states achieving Clean Air 

Interstate Rule (CAIR) reductions solely from electric generating units, the CAIR NOx requirements. 

The North Carolina EMC adopted NOx SIP Call rules in 2000 which have previously approved by the 

USEPA. Consistent with the USEPA CAIR requirements, the NOx SIP Call rules have been replaced by 

the North Carolina Clean Air Interstate Rules (CAIR), 15A NCAC 02D .2400. The North Carolina CAIR 

rules initially became state effective July 1, 2006 and most recent revisions were SIP approved effective 

November 30, 2009. 

The NCDAQ has submitted amendments to 15A NCAC 2D .1402 and .1403, to meet the NOx 

RACT requirements relative to the 1997 8-hour ozone standard, on the April 6, 2007, January 31, 2008, 

and February 3, 2010. These amendments still require federal approval into the SIP. 
Attachment 

 Page 3 

VOC RACT for Major Sources 

In addition to CTG source category specific rules, North Carolina also has provisions for case by 

case VOC RACT determinations. 15A NCAC 2D .0951, Miscellaneous Volatile Organic Compound 

Emissions, applies to all facilities in the Metrolina nonattainment area that use volatile organic 

compounds as solvents, carriers, material processing media, or industrial chemical reactants, or in other 

similar uses, or that mix, blend, or manufacture volatile organic compounds for which there is no other 

applicable emissions control rule in 2D .0900. It requires that the facility install and operate RACT or 

limit VOC emissions from coating lines not otherwise covered by a specific 2D .0900 rule. This case by 

case RACT rule would apply for any category where North Carolina does not have a category specific 

RACT rule regardless of whether USEPA has a CTG for that category or not. The amendment adding the 

requirement to apply RACT was SIP approved 6-27-2001 (66 FR 34117) and is the latest version of this 

rule. 

For three (3) CTG categories, the NCDAQ applied 2D .0951, Miscellaneous Volatile Organic 

Compound Emissions, and 2D .0958, Work Practice Standards, as listed in Table 1 below. 2D .0958, 

Work Practice Standards, is a statewide rule and applies to all facilities that use volatile organic 

compounds as solvents, carriers, material processing media, or industrial chemical reactants, or in other 

similar uses or that mix, blend or manufacture volatile organic compounds, or emit volatile organic 

compounds as a product of chemical reactions. 2D .0958 was adopted, became state effective July 1, 

2000, and was SIP approved June 27, 2001 effective August 27, 2001 (66 FR 34117). 

Table 1. CTG Categories Covered by Case by Case RACT Rule Provisions 

CTG State Rule Original 

Effective Date 

Effective Date 

of Most Recent 

Change 

SIP Approval 

Date of Most 

Recent Change 

Control of Volatile Organic 

Compound Emissions from 

Air Oxidation Processes in 

Synthetic Organic Chemical 

Manufacturing Industry 

(EPA-450/3-84-015, 1984/12) 

No category specific rule; 2D .0951 

case by case RACT provision 

applies. 

02D .0958 Work Practice Standards 

also applicable. 

7/1/1994 7/1/2000 

6/27/2001 

66 FR 34117 

Control of Volatile Organic 

Compound Emissions from 

Wood Furniture 

Manufacturing Operations 

(EPA-453/R-96-007, 1996/04) 

No category specific rule; 2D .0951 

case by case RACT provision 

applies. 

02D .0958 Work Practice Standards 

also applies for sources not subject 

to MACT. 

7/1/1994 7/1/2000 

6/27/2001 

66 FR 34117 

Aerospace (CTG & MACT) 

(EPA-453/R-97-004, 1997/12) 

No category specific rule; 2D .0951 

case by case RACT provision 

applies. 

02D .0958 Work Practice Standards 

also applies. 

7/1/1994 7/1/2000 

6/27/2001 

66 FR 34117 
Attachment 

 Page 4 

Table 2 below lists the applicable pre-1990 through post 1990 Group I USEPA CTGs, 

corresponding North Carolina rules, original effective date, most recent amendment date, and SIP 

approval date relevant to the 1997 8-hour ozone standard. 

Table 2. CTG Documents and Corresponding North Carolina Rules 

CTG State Rule Original 

Effective Date 

Effective Date 

of Most Recent 

Change 

SIP Approval 

Date of Most 

Recent Change 

Design Criteria for Stage I 

Vapor Control Systems –

Gasoline Service Stations 

(EPA-450/R-75-102, 1975/11) 

15A NCAC 02D .0928 Gasoline 

Service Stations Stage I 07/01/79 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

II: Surface Coating of Cans, 

Coils, Paper, Fabrics, 

Automobiles, and Light-Duty 

Trucks 

(EPA -450/2-77-008, 1977/05) 

15A NCAC 02D .0917 Automobile 

and Light-duty Truck Manufacturing 

15A NCAC 02D .0918 Can Coating 

15A NCAC 02D .0919 Coil Coating 

15A NCAC 02D .0920 Paper Coating 

15A NCAC 02D .0921 Fabric and 

Vinyl Coating 

07/01/79 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Solvent Metal 

Cleaning 

(EPA-450/2-77-022, 1977/11) 

15A NCAC 02D .0930 07/01/79 03/01/91 

06/23/94 

59 FR 32362 

Control of Hydrocarbons from 

Tank Truck Gasoline Loading 

Terminals 

(EPA- 450/2-77-026, 1977/12) 

15A NCAC 02D .0927 Bulk Gasoline 

Terminals 

07/01/79 01/01/07 10/31/07 

72 FR 61531 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

III: Surface Coating of Metal 

Furniture 

(EPA-450/2-77-032, 1977/12) 

15A NCAC 02D .0922 Metal Furniture 

Coating 07/01/79 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

IV: Surface Coating of 

Insulation of Magnet Wire 

(EPA -450/2-77-033, 197/12) 

15A NCAC 02D .0924 Magnet Wire 

Coating 07/01/79 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

V: Surface Coating of Large 

Appliances 

(EPA-450/2-77-034, 1977/12) 

15A NCAC 02D .0923 Surface 

Coating of Large Appliances 07/01/79 07/01/96 

08/01/97 

62 FR 41277 
Attachment 

 Page 5 

Table 2. CTG Documents and Corresponding North Carolina Rules (Continued)

CTG State Rule Original 

Effective Date 

Effective Date 

of Most Recent 

Change 

SIP Approval 

Date of Most 

Recent Change 

Control of Volatile Organic 

Emissions from Bulk Gasoline 

Plants 

(EPA-450/2-78-035, 1977/12) 

15A NCAC 02D .0926 Bulk Gasoline 

Plants 07/01/79 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Storage of 

Petroleum Liquids in FixedRoof Tanks 

(EPA-450/2-77-036, 1977/12) 

15A NCAC 02D .0925 Petroleum 

Liquid Storage in Fixed Roof Tanks 07/01/79 03/01/91 

06/23/94 

59 FR 32362 

Control of volatile Organic 

Emissions from Use of Cutback 

Asphalt 

(EPA-450/2-77-037) 

15A NCAC 02D .0931 Cutback 

Asphalt 07/01/79 12/01/89 

06/23/94 

59 FR 32362 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

VI: Surface Coating of 

Miscellaneous Metal Parts and 

Products 

(EPA -450/2-78-015, 1978/06) 

15A NCAC 02D .0934 Coating of 

Miscellaneous Metal Parts and 

Products 

07/01/80 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Existing 

Stationary Sources – Volume 

VII: Factory Surface Coating 

of Flat Wood Paneling 

(EPA-450/2-78-032, 1978/06) 

15A NCAC 02D .0935 Factory 

Surface Coating of Flat Wood 

Paneling 

07/01/80 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Manufacture of 

Synthesized Pharmaceutical 

Products 

(EPA-450/2-78-029, 1978,12) 

15A NCAC 02D .0947 Manufacture of 

Synthesized Pharmaceutical Products 07/01/94 07/01/94 

05/05/95 

60 FR 22284 

Control of Volatile Organic 

Emissions from Manufacture of 

Pneumatic Rubber Tires 

(EPA-450/2-78-030, 1978/12) 

15A NCAC 02D .0937 Manufacture of 

Pneumatic Rubber Tires 07/01/80 07/01/96 

08/01/97 

62 FR 41277 

Control of Volatile Organic 

Emissions from Existing 

Stationary Source – Volume 

VIII: Graphic ArtsRotogravure and Flexography 

(EPA-450/2-78-033, 1978/12) 

15A NCAC 02D .0936 Graphic Arts 07/01/80 12/01/93 

06/23/94 

59 FR 32362 

Control of Volatile Organic 

Emissions from Petroleum 

Liquid Storage in External 

Floating Roof Tanks 

(EPA-450/2-78-050, 1978/12) 

15A NCAC 02D .0933 Petroleum 

Liquid Storage in External Floating 

Roof Tanks 

07/01/80 06/01/05 

02/01/96 

62 FR 3589 
Attachment 

 Page 6 

Table 2. CTG Documents and Corresponding North Carolina Rules (Continued)

CTG State Rule Original 

Effective Date 

Effective Date 

of Most Recent 

Change 

SIP Approval 

Date of Most 

Recent Change 

Control of Volatile Organic 

Compound Leaks from 

Gasoline Tank Trucks and 

Vapor Collection Systems 

(EPA -450/2-78-051, 1978/12) 

15A NCAC 02D .0932 Gasoline Truck 

Tanks and Vapor Collection Systems 07/01/80 08/01/08 

10/31/07 

72 FR 61531 

Control of Volatile Organic 

Compound Emissions from 

Large Petroleum Dry Cleaners 

(EPA -450/3-82-009, 1982/09) 

15A NCAC 02D .0945 Petroleum Dry 

Cleaning 05/01/85 06/01/08 

11/19/86 

51 FR 41786 

Control of Volatile Organic 

Compound Emissions from 

Manufacture of High-Density 

Polyethylene, Polypropylene, 

and Polystyrene Resins 

(EPA -450/3-83-008, 1983/11) 

15A NCAC 02D .0944 Manufacture of 

Polyethylene, Polypropylene, and 

Polystyrene 

05/01/85 

05/01/85 

3/14/85 

11/19/86 

51 FR 41786 

Control of Volatile Organic 

Compound Leaks from 

Synthetic Organic Chemical 

Polymer and Resin 

Manufacturing Equipment 

(EPA-450/3-83-006, 1984/03) 

15A NCAC 02D .0943 Synthetic 

Organic Chemical and Polymer 

Manufacturing 

05/01/85 

03/01/91 

06/01/08 

03/01/91 

06/23/94 

59 FR 32362 

The NCDAQ submitted amendments to USEPA on April 6, 2007 and January 31, 2008, to 

15A NCAC 2D .0902 and .0909, to meet the VOC RACT requirements relative to the 1997 8-hour ozone 

standard. These amendments still require federal approval into the SIP. 

Conclusion 

Based upon staff review, North Carolina has adopted applicable rules addressing all Group I CTG 

categories adopted by USEPA for which there are existing sources in the North Carolina portion of the 

Charlotte-Gastonia-Rock Hill nonattainment area. In addition, North Carolina has case by case RACT 

rule provisions applicable to both CTG and non-CTG sources for which there is not a category specific 

rule. North Carolina’s RACT obligations relative to the 1997 8-hour ozone standard and Group I CTG 

requirements are satisfied through the combination of the category specific RACT rules, the rules 

requiring case by case RACT determinations, and negative declarations for those categories for which 

there are no applicable sources in the North Carolina portion of the Charlotte-Gastonia-Rock Hill 

nonattainment area.