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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: September 18, 2012

SUBJECT: Technical Support Document for Maryland’s Adoption of Amendments to 

Reasonably Available Control Technology Requirements for Volatile Organic 

Compounds

/s/

FROM: Jacqueline Lewis, Environmental Engineer

Office of Air Program Planning 

TO: File

/s/

THRU: Donna Mastro, Acting Associate Director 

Office of Air Program Planning

A. BACKGROUND 

The Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans 

(SIPs) 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, states must revise their SIPs to 

include RACT for sources of volatile organic compounds (VOC) emissions covered by a control 

techniques guidelines (CTGs) document issued after November 15, 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 reasonably available considering technological and economic feasibility.” See 

44 FR 53761 (Sept. 17, 1979). In subsequent 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).
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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 submitted revisions to the 

SIP 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. 

In 1977, 1978, 1993 and 1994, EPA developed CTGs for all the source categories listed 

above, and in 2006, 2007 and 2008 EPA developed new CTGs for these source categories after 

conducting a review of existing state and local VOC emission reduction approaches for these 

industries, reviewing the original CTGs, 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 Guidelines for Offset Lithographic Printing and 

Letterpress Printing (EPA-453/R-06-002, September 2006), Control Techniques Guidelines for 

Flat Wood 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 Department of the 

Environment (MDE) to address sources of VOC emissions covered by EPA’s CTGs for seven 

source categories. These categories are (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. This SIP revision amends Regulation .04 Testing and Monitoring 

under COMAR 26.11.01 General Administrative 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.
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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 reference: 

(1) 40 CFR Part 60, Appendix A, as amended; 

 

(2) The Department's Technical Memorandum 91-01, "Test Methods and Equipment 

Specifications 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 by 

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 use 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 source chooses to determine compliance using alternative test methods. 
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COMAR 26.11.19.02(E) (Computations) establishes the method required to determine 

composite vapor pressure of solvent cleaning material. This revision adds sections (3), (4), and 

(5) to COMAR 26.11.19.02 (E) entitled Computations which read as 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 analysis (ASTM E 260-91) 

for organics and ASTM D3792-79 for water content, as applicable, and the following equation: 

Ppc = [∑(Wi)(VPi)/Mwi] / [Ww/Mww + ∑We/Mwe + ∑Wi/Mwi]

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 = Wv – Ww – Wex/ Wn
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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 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: 

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 

Wn = 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 good operating practice requirements under COMAR 

26.11.19.02(I) (2)(b). They include minimizing spills of VOC-containing cleaning materials, 

minimizing VOC emissions from cleaning of storage, mixing, and conveying equipment and also 

require that closed containers or pipelines be used to convey equipment and convey VOCcontaining 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. This amendment makes references to specific VOC RACT regulations and 

reads as follows: 
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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

The State of Maryland has adopted these amendments 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 comments were 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 SIP. EPA approval of the SIP revision is recommended.