MAY 18, 2006 

NOTE

SUBJECT: RACT Qs & As – Reasonably Available Control Technology (RACT): 

Questions and Answers 

FROM: William T. Harnett 

 Director, Air Quality Policy Division (C539-01) 

TO: Regional Air Division Directors 

The attached Reasonably Available Control Technology (RACT) Questions and 

Answers (Q&A) document addresses issues we have received from the Regional Offices and 

States. The document provides additional clarification that will be helpful for the RACT 

State implementation plans (SIPs) which are due September 15, 2006. Please distribute this 

document to your States, local control agencies, and tribal governments. Regional Office 

staff may contact William Johnson at (919) 541-5246 or Johnson.WilliamL@epa.gov, with 

any questions. 
May 18, 2006 

Questions Related to RACT in 8-hour ozone implementation 

A. What is RACT? 

1. Q: Is the facility expected to perform the RACT analysis? Is this similar to a BACT 

analysis? 

A: The State is responsible for the RACT determination but is likely to have considerable 

interaction with the affected facilities. States may rely on past EPA guidance, such as 

CTGs, for help and should also review other available information regarding the 

appropriate controls. BACT requires that new or modified sources adopt the best 

available controls and, as such, the analysis is a “top-down” analysis that first looks at the 

most stringent level of control available for a source. Industries applying for a 

construction permit list in their application what are the currently most stringent levels of 

control. The State verifies this by checking the application against other data sources 

including EPA’s RACT/BACT Clearinghouse. RACT requires that sources adopt 

controls that are reasonably available and thus they may not be the most stringent 

controls that have been adopted for other similar sources. 

2. Q: If a State in or near the Ozone Transport Region failed to adopt one of the model 

rules which the Ozone Transport Commission developed to help meet the ozone standard 

in that region, would this mean that a rule the State may have for that source is no longer 

considered to be RACT? 

A: No, not necessarily. The model rules developed for the Ozone Transport Region 

were for the purpose of bringing areas in the OTR into attainment with the 1-hour 

NAAQS and thus may be more stringent than what would be considered RACT. In 

performing a RACT analysis, States should look at available controls, such as those that 

were the basis for the model rules developed by the OTR, to conclude whether they are 

reasonably available for a specific source or source category. However, the fact that 

another similar source has such controls in place does not mean that such a control is 

reasonably available for all other similar sources across the country. 

3. Q: Some moderate 8-hour areas were severe 1-hour nonattainment areas. As such, 

the “major source” threshold for 1-hour RACT rules was 25 TPY potential emissions. 

For the purposes of certifying 1-hour RACT determinations, must the State address only 

down to the applicable 8-hour threshold [which is 100 TPY or in the Ozone Transport 

Region 50 TPY for VOC non-CTG major sources and the 100 TPY for all NOx sources] 

or down to the 1-hour threshold of 25 TPY? 

A: For purposes of meeting the 8-hour RACT requirement, the State’s RACT analysis 

only needs to include an evaluation of RACT for CTG sources and for non-CTG major 

sources based on the area’s 8-hour classification. 
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We note however, that under the anti-backsliding requirements, the State may not remove 

RACT requirements for sources that were subject to RACT for the 1-hour standard (but 

that would not be subject to RACT based on the area’s 8-hour classification). Similarly, 

if the State has never met the RACT requirement for one or more sources for the 1-hour 

standard, the anti-backsliding requirements require the State to meet that obligation. The 

anti-backsliding provisions may be found at 40 CFR 51.905 and apply to all former 1-

hour non-attainment areas. 

4. Q: Where a State determines that sources subject to Federal rules, such as NESHAPs, 

the municipal waste incinerator rules under CAA section 111(d), and NSR/PSD 

settlement agreements, meet RACT by compliance with those requirements, how should 

those requirements be addressed as part of the SIP? 

A: To rely on federal rules to meet the RACT requirement, the State must incorporate 

these requirements into the SIP. For example, a State could incorporate by reference the 

Federal requirement or could submit a permit that includes this provision as a SIP 

revision. 

5. Q: Can a State rely for RACT determinations on control obligations in Federally 

enforceable permits issues under a State approved nonattainment new source review 

program (or a PSD program)? 

A: Yes, a State may rely on control obligations required by federally enforceable 

permits. The State would need to submit the relevant portions of these permits (i.e., the 

portions establishing the VOC and NOx obligations) as SIP revisions along with a 

demonstration that such controls are RACT. 

6. Q: For NOx RACT for stationary source categories, other than wall and tangentially 

fired electric utility boilers, EPA guidelines in 1994 indicate States should consider in 

their RACT determinations technologies that achieve 30-50 percent reduction within a 

cost range of $160-1300 per ton of NOx removed. Do EPA VOC guidance documents, 

CTGs and ACTs, give percentage reductions and cost per ton removed guidelines for 

VOC? 

A. The VOC CTGs and ACTs usually do not give percent reductions. The emission 

levels are typically expressed as weight of VOC emitted per some unit of production. For 

example, for coatings the units are often pounds of VOC emitted per gallon of coating. 

However in calculating the emission limits, EPA made an assumption of 90% capture of 

emissions and 90% control of these captured emission for an 81% overall control in many 

cases. Some of the CTGs, such as for degreasers and storage tanks, define RACT as 

certain types of equipment, rather than an emission limit. 

EPA has never issued a general cost of control guideline for VOC, but costs of control in 

the CTGs generally ranged around $2000/ton in 1980s dollars. However, EPA never 

published this figure as a cut-point that had should not be exceeded. 
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7. Q: What is the primary difference between an ACT and a CTG? 

A: The ACTs give percent reductions that can be achieved with various controls at 

various levels of stringency and the costs per ton to achieve those levels of control. The 

ACTs do not recommend a particular level as being RACT. The CTGs do specify a 

particular level of control as being presumptive RACT. 

8. Q: Does EPA maintain a website containing all the RACT Control Techniques 

Guidelines and Alternative Control Techniques documents for both NOx and VOC? 

A: The EPA web site http://www.epa.gov/ttn/atw/ctg_act.html contains a list of all 

published CTGs. This web site also contains a partial list of ACTs, although this ACT 

list is missing the ACTs for bakeries, organic waste process vents and polyester foam 

manufacture. The following website includes two updates to NOx ACTs (see items J.3-

4): http://www.epa.gov/ttn/naaqs/ozone/ozonetech/#nox . A list of CTGs and ACTs is 

also attached to this list of Qs & As. 

9. Q: Does a RACT analysis need to be done for source categories for which an 

Alternative Control Techniques (ACT) document has been published? 

A: Yes. A RACT analysis needs to be done for all CTG sources and all major non-CTG 

sources. While the CTGs and ACTs provide a starting point for such an analysis, RACT 

can change over time as new technology becomes available or the cost of existing 

technology adjusts. States are encouraged to use the latest information available in 

making RACT determinations, whether that information is in CTGs, ACTs, other 

guidance that is available or through information submitted during the public review 

process. 

10. Q: Would EPA's “Beyond VOC RACT CTG Requirements” guidance (EPA-53/R010. April 1995) found at http://www.epa.gov/ttn/catc/dir1/byndract.pdf be of help in 

determining RACT? How about documents such as “Control Techniques for Volatile 

Organic Emissions from Stationary Sources,” EPA-450/2-78-022, May 1978, or 

“Fugitive Emission Sources of Organic Compounds –Additional information on 

Emission, Emissions Reductions, and Costs,” EPA-450/3-82-010, April 1982? 

A: The “Beyond RACT” document could be a source to evaluate in performing a RACT 

analysis. We note that this document was originally written primarily for States that 

needed to get reductions beyond RACT in order to attain and maintain the ozone 

NAAQS. However, in the ten years since that document was issued these controls may 

have become more economically feasible and thus it is possible that controls considered 

beyond RACT in that document could be considered RACT for certain sources. The 

second two documents are somewhat analogous to ACT documents which describe 

various control techniques that can be applied to various industry sectors but do not 

identify a presumptive RACT-level of control. Some of the industry sectors addressed in 

these documents are also covered by a CTG, while others are not. 
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11. Q: For source categories for which an NSPS has been adopted, would a statement 

that there are no sources that preexisted the NSPS be an acceptable RACT analysis? In 

other words, does the fact that all existing sources meet the NSPS mean that they also 

meet RACT? 

A: The NSPS and RACT requirements are separate obligations under the Act and both 

must be met. So the fact that a source meets a NSPS does not necessarily mean that it 

also meets RACT. A State should evaluate the control obligation required through NSPS 

to determine whether the source is currently meeting the RACT obligation or whether 

additional control is necessary for RACT. 

B. Certifications 

12. Q: If a source is subject to a rule that is beyond 1-hour RACT, can a State give a 

certification that this source meets RACT? 

A: Even though a source may have been subject to control that was beyond RACT for 

the 1-hour standard, the State needs to evaluate whether that requirement is, at a 

minimum, RACT based on the current information that is available. 

13. Q: Would a certification need to include a commitment to upgrade rules in the future 

if/when we determine that RACT levels of control have become more stringent? 

A: No. The RACT analysis needs to be performed at the time the RACT SIP is being 

developed and once the RACT SIP is approved there is no additional duty to reconsider 

this control obligation for a source. 

14. Q: By what date does a facility need to have a federally enforceable permit to meet 

requirements for RACT? 

A: A RACT SIP is due by September 15, 2006 for subpart 2 areas and with submission 

of an attainment demonstration request for subpart 1 areas seeking an attainment date 

more than 5 years after designation. RACT must be implemented no later than the 

beginning of the first ozone season or portion thereof that occurs 30 months after the 

required submission date. States should have enforceable measures in place by that date. 

If a source has or is required to have a Title V operating permit, the provisions of Title V 

program would govern when the RACT requirement must be incorporated into the SIP 

and a facility should consult with the permitting authority regarding that issue. 

15. Q: Must RACT based emission limits, and associated monitoring, record keeping 

and reporting be included in a Federally enforceable permit (Title V operating permit)? 

A: For purposes of meeting the requirements of Title I of the Act (i.e., the nonattainment 

area provisions), RACT needs to be adopted and approved into the SIP. This can be 

accomplished in a variety of ways. Typically, States have adopted regulations. 
5

However, the State could first specify the obligation in an enforceable permit and submit 

the permit (or portions of the permit) for inclusion into the SIP. In some cases, States 

have also submitted enforceable consent orders as SIP revisions. In general, the RACT 

requirement for a specific source or source category would include a requirement for a 

specific control measure or for a specific level of reduction and, as appropriate, 

monitoring, recordkeeping and reporting requirements. 

16. Q: Does EPA intend to issue guidance on how States should reassess their rules in 

light of currently available technologies to determine if their rules incorporate RACT? 

A: At this time, EPA is not working on further RACT guidance. States should consult 

with the appropriate EPA Regional office if they have questions regarding how the 

analysis for a specific source or source category should be performed. 

17. Q: What should a State do if it concludes that for a specific source or source 

category no additional controls are necessary beyond what was required by the RACT 

analysis under the 1-hour standard? 

A: Where a State concludes that the no control is required beyond what was required for 

purposes of the 1-hour NAAQS, the State should submit its analysis justifying such a 

conclusion as part of its RACT SIP. 

18. Q: What is required in a RACT analysis in order for a State to give a certification 

that previously required RACT controls or newly applied controls represent RACT for 8-

hour implementation purposes? 

A: A State should evaluate RACT for a source or source category by examining existing 

EPA guidance as well as other available information such as that identified in the 

responses above. To conclude that the existing level of control is RACT for a source or 

source category, the State’s analysis should demonstrate that more effective controls are 

not economically or technically feasible. 

C. Relationship between RACT and the Clean Air Interstate Rule (CAIR) and the NOx 

SIP Call 

19. Q: Can a State rely on its participation in the CAIR trading programs to demonstrate 

that certain source categories meet RACT? 

A: EPA has received a petition for reconsideration asking it to reconsider and reopen for 

public comment its determination that certain sources in States participating in the EPAadministered CAIR NOx trading program meet ozone NOx RACT requirements. EPA 

intends to grant the petition for reconsideration on this issue. If necessary, EPA will 

provide further guidance on this subject after the reconsideration process is complete. 

20. Q: Do all sources subject to a State’s NOx SIP call trading program presumptively 

meet RACT even if the trading program covers non-EGU sources? 
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A: Yes, EPA believes that the NOx SIP Call constitutes RACT for those sources covered 

by the NOx SIP Call. However, whether our judgment that non-EGU sources subject to 

the NOx SIP Call trading system meet RACT will continue to apply in the future depends 

upon how the State chooses to make the transition from the NOx SIP Call trading system 

to the CAIR trading system. This issue is discussed in greater detail in the preamble to 

the November 29, 2005 8-hour implementation rule at 70 Fed. Reg. 71657. 

21. Q: If electrical generating units (EGU) in a State are covered by the NOx SIP Call 

trading program, would any EGU be presumed to have met the requirements of NOx 8-

hour ozone RACT even though the source just buys additional needed allocations to 

comply? Or does the State need to look to see if combustion modifications (e.g. adding 

low NOx burners or over fire air) are RACT? 

A: As stated in the preamble to the November 29, 2005 8-hour implementation rule, the 

NOx SIP Call is estimated to achieve a beyond-RACT degree of control regionally, and 

sources were required to install any controls needed for compliance no later than May 

2004. Under these circumstances, EPA believes that the NOx SIP call constitutes RACT 

for those sources covered by the NOx SIP Call, regardless of the manner of compliance 

of individual sources (e.g., control equipment installation or purchase of allowances from 

other sources). 

22. Q: Does a source that came into existence after the State’s NOx SIP call rule was 

adopted meet RACT if it is subject to the State’s SIP call rule? 

A: Yes, if that source is covered by the NOx SIP Call trading program. A large EGU 

will automatically become part of the NOx SIP Call trading program and thus will be 

considered to meet ozone NOx RACT requirements. If the source is a cement kiln or 

stationary internal combustion engine, a control level of at least a 30 percent or 82 

percent reduction respectively from uncontrolled levels would be considered RACT. 

23. Q: May a State rely on its compliance with the NOx SIP Call to show that cement 

kilns and stationary internal combustion engines are meeting the RACT requirements? 

A: Yes, if the cement kilns and stationary internal combustion engines are subject to a 

SIP approved as meeting the NOx SIP Call obligation to install and operate controls that 

are expected to achieve at least a 30 percent and 82 percent reduction, respectively, from 

uncontrolled levels. 

24. Q: The November 29, 2005 preamble to the 8-hour ozone implementation rule says, 

at page 71656, that: “....a State need not perform a NOx RACT analysis for non-EGU 

sources that after 2008 continue to be subject to a SIP that regulates those non-EGU 

sources equally or more stringently than the State’s current rules meeting the NOx SIP 

call.” Does this apply to the whole facility or just to the unit that is subject to the NOx 

SIP call? 
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A: The State need not perform such an analysis (and may instead rely on the analysis 

performed by EPA) only for the unit covered by the NOx SIP call. 

D. Negative Declarations 

25. Q: Are negative declarations required? That is, must a State certify that it has no 

sources in a particular CTG category if the State does not adopt a RACT rule for this 

category? 

A: A negative declaration that there are no sources in a specific CTG category or no 

major non-CTG sources would need to be included as part of the RACT SIP submittal. 

As part of the RACT submission, the negative declaration and the information supporting 

the declaration would be subject to the SIP public hearing at the State level. 

26. Q: If the State area believes that there are no major non-CTG sources located in the 

nonattainment area, would the area need to submit a negative declaration? 

A: Yes, the negative declaration would need to assert that there are no major non-CTG 

sources in the area, and the accompanying analysis would need to support that 

conclusion. 

E. Other Issues 

27. Q: Can the State calculate the potential to emit (PTE) for an emission unit based on 

emissions after a control device if the operation and installation of the control device are 

federally enforceable, e.g., a NSPS or MACT standard requires the control device to be 

installed and operated? 

A: Yes. Where a source has a federally enforceable limit on emissions or a federally 

enforceable restriction on the hours of operation, then the analysis of whether the source 

is subject to RACT would be based on emissions considering those restrictions. 

28. Q: What must a State do for sources in a subpart 2 area not subject to 1-hour RACT 

SIP regulation? 

A: The State must perform a RACT analysis for all CTG and major non-CTG sources in 

the nonattainment area. Where a source is currently not regulated, the State could start its 

analysis by considering EPA guidance documents (e.g., CTGs and ACTs). After 

considering these documents as well other available information, the State would need to 

submit a SIP revision providing for RACT for all CTG and major non-CTG sources in 

the area, and a negative declaration where no sources within a category are located in the 

area. Additionally, section §182(f) provides for an exemption from NOx RACT if certain 

criteria are met. 
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29. Q: What must a State do for sources which were subject solely to 1-hour RACT 

rules in their SIP (excluding sources covered by certain NOx SIP call/CAIR trading 

programs)? 

A: For sources subject to 1-hour RACT, the State should review available EPA guidance 

and other available information to determine whether additional control is needed to meet 

8-hour RACT. If no additional control is needed, the State may submit a certification 

with an accompanying analysis demonstrating that the current level of control is RACT. 

The State need not resubmit the existing SIP-approved 1-hour RACT rules. If additional 

control is needed, the State would need to make that obligation federally enforceable 

through a SIP revision. 

30. Q: What must a State do for sources (excluding sources covered by certain NOx SIP 

call/CAIR trading programs) subject to 1-hour RACT rule in the SIP, but subsequently 

subject to a more stringent regulation (“beyond 1-hour RACT rule”) in State rule which is 

already in the approved SIP where such rule was adopted as necessary for 

ROP/attainment? 

A: See previous answer to question 29. 

31. Q: Would the units covered by EPA’s January 1, 1995 memorandum “De Minimis 

Values for NOx RACT” also fall into the category where the State used this 

guidance/policy to set cut-offs for small emissions units? 

A: The purpose of the January 1, 1995 memorandum is to provide technical data that 

may be used to evaluate de minimis NOx for various categories of sources. EPA does 

not recommend specific de minimis values, but presents factors as a guide in the 

development and review of State de minimis rules. Similar to other RACT guidance 

issued for the 1-hour ozone standard, a State may continue to use this guidance--along 

with any other relevant infomation--for purposes of the 8-hour ozone RACT SIP. 

32. Q: Subpart 1 areas must demonstrate they will attain the 8-hour standard within 5 

years of designation, or submit RACT rules with their attainment date extension request. 

A State/Air District in a subpart 1 nonattainment area plans to submit an extension 

request and will need to adopt RACT rules for EGUs. In the meantime, a facility has 

shutdown an old EGU. They submitted a package to bank the shutdown emissions as 

emission reduction credits (ERCs). Do the calculated ERCs in the facility's submittal 

need to be reduced to account for the future RACT rule the State/Air District needs to 

adopt? 

A: If the State plans to ask for an attainment date extension for a subpart 1 area beyond 5 

years, RACT rules must be submitted. The ERCs must be discounted to the extent that 

emissions must be reduced to meet the new RACT rule. That is, the ERCs only continue 

to exist to the extent that the emissions reductions in the ERC represent lower emissions 

than those which would have been allowed under the new RACT rule if the rule had 

existed when the ERCs were generated. 
9

Additional guidance on the issue of ERCs and RACT may be found in the 1994 memo, 

“Response to Request for Guidance on Use of Pre-1990 ERC’s and Adjusting for RACT 

at Time of Use,” dated August 26, 1994 from John S. Seitz, Director Office of Air 

Quality Planning and Standards to David Howekamp, Director Region IX Air and Toxics 

Division. This memo may be found at this web site: 

http://www.epa.gov/Region7/programs/artd/air/nsr/nsrmemos/pre-1990.pdf 

33. Q: Is there any option for using Title V permits as the means of complying with the 

non-CTG major stationary source obligation – either submitting the permits for SIP 

approval or pulling the salient pieces from them and submitting these components, rather 

than going to the trouble of adopting a prohibitory rule for the source category? 

A: Because Title V permits must be renewed every 5 years, the permits themselves 

should not be submitted as RACT rules because they are not permanent. However, if 

State law allows, the State may submit components of the permit as requirements that 

would remain enforceable until such time as the SIP is revised. 

34. Q: May a State’s RACT submission include commitments to adopt one or more 

RACT rules in the future? 

A: A RACT submission that does not address RACT for all CTG and non-CTG sources 

would not be a complete official submission as required by the RACT provisions of the 

CAA. The State may address RACT through adoption of rules or submission of permits 

or consent orders; through one or more negative declarations; or through a request for a 

NOx RACT exemption. In addition, for non-CTG sources, some states have taken the 

approach of submitting a RACT rule that provides a process for the source-specific 

adoption of RACT through a future process. However, such a rule must also provide a 

backstop control obligation that would apply no later than the RACT compliance date if a 

source-specific rule had not been adopted, approved and implemented by that date. 

35. Q: If a state includes its RACT SIP with its 8-hr ozone attainment demonstration as 

a submittal sometime after September 15, 2006, would that State's compliance date 

remain the same, or be adjusted to correspond with the actual submittal date? 

A: The RACT compliance date would not change where a State chooses to delay 

submission of its RACT SIP beyond the required submission date. 

36. Q: When are RACT SIPs due? 

A: Subpart 2 moderate and above areas must submit RACT SIPs no later than September 

15, 2006. Subpart 1 areas that seek an attainment date later than five years following 

designation are required to submit their RACT SIP at the time they request the attainment 

date extension, which can be no later than the time required for submission of the 

attainment demonstration – i.e., June 15, 2007. Subpart 1 areas that do not request an 

extension of the attainment date would meet RACT through submission of an attainment 

demonstration that demonstrates attainment as expeditiously as practicable. Thus, the 
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area’s attainment demonstration, which is due June 15, 2007, would also be the RACT 

submission for such area. 

37. Q: For an area with a year-long ozone season, such as California, when does the 

implementation date for RACT begin? 

A: Areas are required to implement RACT no later than the first ozone season or part 

thereof that occurs 30 months after the RACT SIP is due. Thus areas with a year-long 

ozone season would be required to implement RACT 30 months after the SIP submission 

is required – i.e., March 15, 2009. 

38. Q: The maximum attainment date for a moderate 8-hour nonattainment area is June 

15, 2010. All reductions needed for attainment are supposed to be achieved by the 

beginning of the ozone season prior to the attainment date. For areas with full year 

ozone seasons (such as California), the final full ozone season prior to the required 

attainment date would be the ozone season beginning January 1, 2009. RACT 

requirements must be implemented by 30 months after SIP submittal, which would be 

March 15, 2009. When must the RACT requirements be implemented – by January 1, 

2009 or by March 15, 2009? 

 

A: Where a State is relying on RACT reductions as part of its attainment demonstration, 

then those reductions would need to be achieved by the beginning of the final full ozone 

season prior to the area’s attainment date. For some areas, that may mean that RACT 

requirements will need to be implemented earlier than required under the RACT 

provisions of the Act and our regulations. 

39. Q: What is the reference size cut-offs for major non-CTG source categories? 

A: RACT applies to CTG sources and to major non-CTG stationary sources of VOC 

and/or NOx. The major-source threshold is based on the classification of the 

nonattainment area and are specified in Clean Air Act section 182(d) for VOC and 

182(f)(1) for NOx. For example, for a severe 8-hour ozone non-attainment area, such as 

South Coast, ‘‘major source’’ means 25 tpy or more of VOCs or NOx. 

40. Q: Does a VOC or NOx stationary source cut-off (e.g. 25 tpy for NOx or 25 tpy for 

VOC in any severe nonattainment area) represent an uncontrolled or controlled level? 

A: In general, RACT applicability is based on the source’s potential to emit – i.e., 

uncontrolled emissions. However, if the source has a federally enforceable restriction on 

the emission level or on the hours of operation, those restrictions would be considered in 

determining whether the source is a major source (see, e.g., Blue Book pages 2-3 at 

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf). The emissions 

restriction cannot be solely on the emissions, but must be on the operation of the source 

so that the potential to emit is below the applicability threshold. 
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41. Q: Does "major source" in the context of a RACT determination represent 

"equipment" or "facility." 

A: EPA guidance provides that when assessing whether a source is “major” for purposes 

of non-CTG RACT, the State should consider the building, structure, facility or 

installation. See the Blue Book at: 

(http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf ). As provided in the 

guidance, the State should consider the emissions from all sources that were not required 

to install RACT (e.g., the source emissions are below those that would be subject to 

RACT under the applicable CTG) as well as any other sources at the facility. For 

purposes of determining whether a facility is subject to RACT pursuant to a CTG, the 

State should examine the aggregate of all emissions from sources in that particular CTG 

category at the facility. 

42. Q. May States adopt generic RACT provisions in their 8-hour RACT SIP rules for 

VOC and/or NOx? 

 

A. On November 7, 1996, EPA issued a policy memorandum providing additional 

guidance for approving regulations that contains these generic provisions (Sally Shaver, 

Director, Air Quality Strategies and Standards Division, memorandum to EPA Division 

Directors, “Approval Options for Generic RACT Rules Submitted to Meet the non-CTG 

VOC RACT Requirement and Certain NOx RACT Requirements”). A State may adopt 

generic RACT rules as part of its SIP. EPA encourages States to follow the provisions of 

the November 7, 1996 memorandum.

43. Q: Can you provide a complete list of CTGs and ACTs? 

A: Here is as complete a listing as we have been able to compile. The CTG list is 

complete. We believe the ACT list is complete: 

Pre 1990 CTGs 

1. Design Criteria for Stage I Vapor Control Systems - Gasoline Service Stations, 

November 1975. [Note – this document is regarded as a CTG although it was never 

published with an EPA document number.] 

2. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I: 

Control Methods for Surface Coating Operations, EPA-450/2-76-028, November 

1976 [Note – although often listed with the CTGs for historical reasons, this 

document does not define RACT for any source. It is a compilation of control 

techniques.] 

3. 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, May 1977. 
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4. Control of Volatile Organic Emissions from Solvent Metal Cleaning, EPA-450/2-77-

022, November 1977. 

 

5. Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process 

Unit Turnarounds, EPA-450/2-77-025, October 1977. 

 6. Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals, EPA-450/2-

77-026, December 1977. 

7. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume III: 

Surface Coating of Metal Furniture, EPA-450/2-77-032, December 1977 

8. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume IV: 

Surface Coating for Insulation of Magnet Wire, EPA-450/2-77-033, December 1977 

9. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: 

Surface Coating of Large Appliances, EPA-450/2-77-034, December 1977. 

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

035, December 1977 

11. Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed 

Roof Tanks, EPA-450/2-77-036, December 1977. 

 

12. Control of Volatile Organic Compounds from Use of Cutback Asphalt, EPA-450/2-

77-037, December 1977 

13. Control Techniques for Volatile Organic Emissions from Stationary 

Sources, EPA-450/2-78-022, May 1978. [Note – This document is often listed 

with CTGs, but it does not define RACT for any particular source.] 

14. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume 

VI: Surface Coating of Miscellaneous Metal Parts and Products, EPA-450/2-78-

015, June 1978 

15. Control of Volatile Organic Emissions from Existing Stationary Sources, Volume 

VII: Factory Surface Coating of Flat Wood Paneling, EPA-450/2-78-032, June 

1978. 

16. Control of Volatile Organic Compound Leaks from Petroleum Refinery 

Equipment, EPA-450/2-78-036, June 1978. 

17. Control of Volatile Organic Emissions from Manufacture of Synthesized 

Pharmaceutical Products, 450/2-78-029, December 1978. 
13

18. Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber 

Tires, EPA-450/2-78-030, December 1978. 

19. Control of Volatile Organic Emissions from Existing Stationary 

Sources, Volume VIII: Graphic Arts - Rotogravure and Flexography, 

EPA-450/2-78-033, December 1978. 

20. Control of Volatile Organic Emissions from Petroleum Liquid Storage in External 

Floating Roof Tanks, EPA-450/2-78-047, December 1978. 

21. Control of Volatile Organic Emissions from Perchloroethylene Dry 

Cleaning Systems, EPA-450/2-78-050, December 1978. [Note – Perchloroethylene 

has been exempted as a VOC, so this CTG is no longer relevant. However, there is 

a MACT standard for perchloroethylene dry cleaners.] 

22. Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor 

Collection Systems, EPA-450/2-78-051, December 1978. 

23. Fugitive Emission Sources of Organic Compounds – Additional 

Information on Emissions, Emission Reductions, and Costs, 

EPA-450/3-82-010, April 1982. [Note – This document does not define RACT for 

any particular source.] 

24. Control of Volatile Organic Compound Emissions from Large Petroleum Dry 

Cleaners, EPA-450/3-82-009, September 1982 

25. Control of Volatile Organic Compound Emissions from Manufacture of HighDensity Polyethylene, Polypropylene, and Polystyrene Resins, EPA-450/3-83-008, 

November 1983 

26. Control of Volatile Organic Compound Equipment Leaks from Natural 

Gas/Gasoline Processing Plants, EPA-450/2-83-007, December 1983. 

27. Control of Volatile Organic Compound Fugitive Emissions from Synthetic Organic 

Chemical Polymer and Resin Manufacturing Equipment, EPA-450/3-83-006, 

March 1984 

28. Control of Volatile Organic Compound Emissions from Air Oxidation 

Processes in Synthetic Organic Chemical Manufacturing Industry, 

EPA-450/3-84-015, December 1984. 

Post 1990 CTGs 

1. SOCMI Distillation and Reactor Processes CTG (EPA 450/4-91-031, August 1993). 
14

2. Wood Furniture (CTG-MACT) - draft MACT out 5-94; Final CTG, EPA-453/R-96-

007, April 1996; see also 61 FR 25223, and, 61 FR 50823, September 27, 1996.

3. Shipbuilding/repair ACT (EPA 453/R-94-032, April 1994) and CTG, see 61 FR 

44050, August 27, 1996. 

4. Aerospace (CTG & MACT) (see 59 FR 29216, June 6, 1994); CTG (Final), EPA453/R-97-004, December 1997.

The VOC Available Control Technology (ACTs) Documents 

1. Control Techniques for Organic Emissions from Plywood Veneer Dryers, EPA-450/3-

83-012. May 1983. [This document is labeled as a control technique document 

(CTD) rather than an ACT. However, the information is similar to that in an ACT.] 

2. Reduction of Volatile Organic Compound Emissions from Application of Traffic 

Markings – EPA-450/3-88-007, August 1988. [Note – the Architectural and 

Industrial Maintenance coatings (AIM) national rule issued in 1998 includes limits 

for traffic coatings and superseded the ACT.] 

3. Ethylene Oxide Sterilization ACT (EPA 450/3-89-007) March 1989. 

4. Alternative Control Technology Document – Halogenated Solvent Cleaners – EPA450/3-89-030. August 1989. 

5. Alternative Control Technology Document – Organic Waste Process Vents – EPA450/3-91-007, December 1990. 

6. Polystyrene Foam Manufacturing – EPA-450/3-90-020, 1990. 

7. Bakery Ovens ACT (EPA 453/R-92-017, December 1992) 

8. Control Techniques for Volatile Organic Compound Emissions from Stationary 

Sources, EPA-453/R-92-018, December 1992 

9. Industrial Wastewater CTG (draft) (EPA-453/D-93-056, September 1992); ACT: 

April 94 ACT consists of cover memo with option tables + CTG (draft). 

10. Control of VOC Emissions from the Application of Agricultural Pesticides, EPA450/R-92-011, March 1993. 

11. Alternative Control Techniques Document: Volatile Organic Liquid Storage In 

Floating and Fixed Roof Tanks, EPA 453/R-94-001, January 1994. 
15

12. Control of Volatile Organic Compound Emissions from Batch Processes ACT (EPA 

453/R-93-017 or EPA 453/R-93-020, February 1994) 

13. Alternative Control Techniques Document – Industrial Cleaning Solvents, EPA453/R-94-015, February 1994 

14. Business Machine Plastic Parts coating/Automobile Plastic Parts coating ACT (EPA 

453/R-94-017, February 1994) 

15. Automobile Body refinishing ACT (EPA 453/R-94-031, April 1994) [Note – a 

national rule for autobody refinishing was issued in 1998 after the ACT.] 

16. Ship building coatings ACT, EPA 453/R-94-032, April 1994. [This was superseded 

by the Ship building CTG which was issued in August 1996.]

17. Offset Lithography ACT (EPA 453/R-94-054, June 1994) 

The NOx ACT documents: 

1. NOx Emissions from Nitric and Adipic Acid Manufacturing Plants (EPA-453/3-91-

026- December 1991. 

2. NOx Emissions from Stationary Combustion Turbines (EPA-453/R-93-007) - January 

1993. 

3. NOx Emissions from Process Heaters (EPA-453/R-93-034) - revised September 1993. 

4. NOx Emissions from Stationary Internal Combustion Engines (EPA-453/R-93-032), 

July 1993 – [Updated September 2000.] 

5. NOx Emissions from Utility Boilers - (EPA 453/R-94-023) March 1994. 

6. NOx Emissions from Cement Manufacturing - (EPA 453/R-94-004) March 1994 – 

[Updated September 2000.] 

7. NOx Emissions from Industrial, Commercial & Institutional Boilers - (EPA 453/R-94-

022) March 1994. 

8. NOx Emissions from Glass Manufacturing - (EPA 453/R-94-037), June 1994. 

9. NOx Emissions from Iron and Steel - (EPA 453/R-94-065) September 1994.