1 **UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III**  **1650 Arch Street Philadelphia, Pennsylvania 19103** 

**DATE:** September 1 8 , 201 2 **SUBJECT:** Technical Support Document for Maryland’s Adoption of Amendments to

Reasonably Available Control Technology R equirements for Volatile Organic Compounds /s/ **FROM:** Jacqueline L ewis, Environmental Engineer

Office of Air Program Planning **TO:** File /s/ **THRU:** Donna Mastro , Acting Associate Director

Office of Air Program Planning

**A. BACKGROUND** The Cl ean Air Act (CAA) section 172(c)(1) provides that state implementation plans (SI Ps) for nonattainment areas must include “reasonably available control measures” (RACM), including “reasonably

available control technology ” (RACT), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, s tates must revise their SIPs to include RACT for sources of volatile organic compounds (VOC) emissions covered by a control techniques guidelines (CTG s ) document issued after November 1 5, 1990 and prior to the area’s date of attainment. The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology

that is r easonably

available considering technological and economic feasibility

. ” See 44 FR 53761 (Sept. 17, 1979). Insubsequent Federal Register notices, EPA has addressed how states can meet the RACT requirements of the CAA

. CAA section 183(e) directs EPA to list for regulation those categories of products that account for at least 80 percent of the VOC emissions, on a reactivity

- adjusted basis, from consumer and commercial products in areas that violate the national ambient air quality standards (NAAQS ) for ozone (i.e., ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list periodically

. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov. 17, 2005) , and 64 FR 13422 (Mar. 18, 1999).2

EPA develops CTGs as guidance on control requirements for specific source categories. The CTGs are intended to provide state and local air pollution control authorities information that should assist them in determining RACT for VOC. Maryland has submitt ed revisions to the SI P to address the following source categories: (1) paper, film, and foil coatings; (2) industrial cleaning solvents; (3) miscellaneous metal and plastic parts coatings; (4) large appliance coatings; (5) offset lithographic printing and letterpress printing; (6) flat wood paneling coatings; and (7) flexible package printing. In1977, 1978, 1993 and 1994 , EPA developed CTGs for all the source categories listed above , and in 2006 , 2007 and 200 8 EPA developed new CTGs for these source categories a fter conducting a review of existing state and local VOC emission reduction approaches for these industries, reviewing the original CTG s, Alternative Control Techniques (ACTs), and New Source Performance Standards (NSPS) and taking into account the information that has become available since then

. EPA ’s new CTGs are entitled Control Techniques Guidelines for Paper, Film, and Foil Coatings (EPA 453/R

- 07

- 003 , September 2007), Control Techniques Guidelines: Industrial Cleaning Solvents ( EPA 453/R

- 06

- 001, September 2006) , Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings ( EPA

- 453/R

- 08

- 003, September 2008), Control Techniques Guidelines for Large Appliance Coatings (EPA 453/R

- 07

- 004, September 2007), Control Techniques Gu idelines for Offset Lithographic Printing and Letterpress Printing (EPA

- 453/R

- 06

- 002, September 2006), Control Techniques Guidelines for Flat W ood Paneling Coatings (EPA 453/R

- 06

- 004 , September 2006), and Control Techniques Guidelines for Flexible Package Printing (EPA 453/R

- 06

- 003, September 2006). These new CTGs include new general requirements along with testing, work practice, and recordkeeping requirements.

**B. STATE SUBMITTAL** On April 5, 2012, EPA received a SIP revision from the Maryland Departme nt of the Environment (MDE) to address sources of VOC emissions covered by EPA’s CTG s for seven source categories. These categories are (1) paper, film, and foil coatings; (2) industrial cleaning solvents; (3) miscellaneous metal and plastic parts coating s; (4) large appliance coatings; (5) offset lithographic printing and letterpress printing; (6) flat wood paneling coatings; and (7) flexible package printing

. This SI P revision amends Regulation .04 Testing and Monitoring under COMAR 26.11.01 General Adm inistrative Provisions and Regulation .02 Applicability , Determining Compliance, Reporting, and General Requirements under COMAR 26.11.19 for subsections (D) Test Methods, (E) Computations, (G) Control of Major Stationary Sources of Volatile Organic Compounds, and (I ) Good Operating Practices, Equipment Cleanup, and VOC Storage.3

**COMAR 26.11.01 General Administrative Provisions** Regulation .04 Testing and Monitoring under COMAR 26.11.01 General Administrative Provisions provides updated provisions for the test methods that are referenced under COMAR 26.11.19.02. These amendments are incorporated by reference under Section C. Emissions Test Methods and now read as follows. C. Emission Test Methods. The following test methods are incorporated by refere nce: (1) 40 CFR Part 60, Appendix A, as amended; ( 2) The Department's Technical Memorandum 91

- 01, "Test Methods and Equipment Specifi cations for Stationary Sources," January 1991, as amended through Supplement 3 (October 1, 1997); and (3) For PM10 stack tests, the following EPA approved test methods shall be used: (a) Test Methods 201 A and 202 in 40 CFR Part 51, Appendix M, as amended; (b) Test Method 5 (40 CFR Part 60, Appendix A, as amended) and Test Method 202 in 40 CFR Part 51, Appendix M, as amended; (c) Test Method 5 ( 40 CFR Part 60, Appendix A, as amended) using front half and back half procedure; (d) EPA Conditional Test Method 39 may be substituted for Test Method 202 in 40 CFR Part 51, Appendix M, as amended; or (e) Alternative test methods may be used for PM10 if they are approved by

the Department and the EPA.
**COMAR 26.11.19 Volatile Organic Compounds from Specific Processes**  The amendments to COMAR 26.11.19.02 (D), (E), and (I ) apply to sources covered b y the CTG categories and other regulations and processes involving testing, cleaning solutions, solvents, or degreasing materials covered under COMAR 26.11.19. These amendments make the requirements more consistent with EPA’s CTGs guidance for alternative test methods, calculation methods, and work practice standards.
COMAR 26.11.19.02 ( D ) (Test Methods) establishes methods, procedures and requirements for the alternative testing of control devices. The revision amends COMAR 26.11.19.02(D)(2) by requiring sources that us e air pollution control equipment to comply with the requirements of this chapter make the determination in accordance with COMAR 26.11.01.04 ( C )

. The revision also adds COMAR 26.11.19.02(D)(3) requiring MDE and U.S. EPA approval if a sourc e chooses to determine compliance using alternative test methods

.4

COMAR 26.11.19.02 ( E ) (Computations) establishes the method required to determine composite vapor pressure of solvent cleaning material. Th is revision adds sections (3), (4), and (5) to CO MAR 26.11.19.02 ( E ) entitled Computations which read a s follows. (3) The composite vapor pressure of organic compounds for any cleaning solution, solvent, or degreasing material shall be determined as follows: (a) The composite vapor pressure of organic compounds shall be determined by quantifying the amount of each compound in the blend using gas chromatographic analy sis (ASTM E 260

- 91) for organics and ASTM D3792

- 79 for water content, as applicable, and the following equation: Pp c = [ ∑ (W i )(VP i )/Mw i ] / [W w/Mw w + ∑W e /Mw e + ∑W i/Mw i ] Where: Ppc = VOC composite partial pressure at 200 C, in mm Hg Wi = Weight of the “I ”th VOC compound, in grams, as determined by ASTM E 260

- 91 Ww = Weight of water, in grams as determined by ASTM D 3792

- 86 We = Weight of the “I ”th exempt compound, in grams, as determined by ASTM E 260

- 91 Mwi = Molecular weight of the “I ”th VOC compound, in grams per g

- mole, as given in chemical reference literature Mww = Molecular weight of water, 18 grams per g

- mole Mwe =Molecular weight of the “I ”th exempt compound, in grams per g

- mole, as given in chemical reference literature Vpi = Vapor pressure of the “I ”th VOC compound at 20 C, in mm Hg, as determined by §E(4)(b) of this regulation. (b) The vapor pressure of each single component compound may be determined from ASTM D2879

- 86, or may

be obtained from a material safety data sheet or another source approved by the Department. (4) The mass VOC to mass solids applied for coatings, adhesives, or inks shall be determined as follows: (a) The VOC content, water content, density , volume solids, and weight solids for any coating, adhesive, or ink used pursuant to the requirements of this chapter shall be determined as specified in COMAR 26.11.01.04C. (b) The weight of coating solids shall be calculated as follows: VOCS = W v – W w – W ex/ W n5

Where: VOCS = VOC content in lb VOC/lb of coating solids or in kg VOC/kg of coating solids Wv = 100%

- Wn Ww = Weight percent of water Wex = Weight percent of exempt solvents Wn = Weight percent of solids of the as applied coating (5) The weight of VOC in units of weight VOC per weight coating applied (in pounds VOC/pounds coating applied or in VOC/kg coating applied) for coatings, adhesives, or i nks shall be determined as follows: (a) The VOC content, water content, density , volume solids, and weight solids for any coating, adhesive, or ink used pursuant to the requirements of this chapter shall be determined as specified in COMAR 26.11.01.04C. (b) The weight of coating solids shall be calculated as follows: VOCM = Wv

- Ww

- Wex Where: VOCM = VOC content in lb VOC/lb of coating or in kg VOC/kg of coating Wv = 100%

- Wn Ww = Weight percent of water Wex = Weight percent of exempt solvents W n = Weight percent of solids of the as applied coating COMAR 26.11.19.02(I ) (Good Operating Practices, Equipment Cleanup, and VOC Storage) establishes requirements for the handling of solvents and cleaning material . This revision adds three additional go od operating practice requirements under COMAR 26.11.19.02(I ) (2) (b) . They include m inimiz ing spills of VOC

- containing cleaning materials , minimizing VOC emissions from cleaning of storage, mixing, and conveying equipment and also require that closed cont ainers or pipelines be used to convey equipment and convey VOC

containing cleaning materials from one location to another

. The amendment to COMAR 26.11.19.02 (G) (Control of Major Stationary Sources of Volatile Organic Compounds) exempts additional VOC RACT regulations that had not been adopted since 1991. Th is amendment makes references to specific VOC RACT regulations and reads as follows :6

G. Control of Major Stationary Sources of Volatile Organic Compounds. (1) This section applies to a person who owns or operates any major stationary

source of VOC that is not subject to any

VOC emission standard in COMAR 26.11.10, 26.11.11, 26.11.13, 26.11.14, or Regulations .03

— .33 of this chapter.

**C. EPA EVALUATION** T he State of Maryland has adopted these ame ndments to address sources of VOC emissions covered by

EPA’s seven CTGs listed above. Maryland already had regulations in place which reduced VOC emissions from these source categories, and these amendments make the requirements more consistent with EPA’s CTG guidance for alternative test methods, calculations methods, and work practice standards. Therefore the VOC emissions reductions are expected to be minimal.

**D. PUBLIC COMMENT** During the State’s public comment period, no comment s w ere received

.
**E. CONCLUSIONS AND RECOMMENDED AGENCY ACTION** The adoption of various test methods, calculations methods, and work practice standards for (1) paper, film, and foil coatings; (2) industrial cleaning solvents; (3) miscellaneous metal and plastic parts coatings; (4) large appliance coatings; (5) offset lithographic printing and letterpress printing; (6) flat wood paneling coatings; and (7) flexible package printing by the State of Maryland will strengthen Maryland SI P . EPA approval of the SI P revision is recommended.