UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

01 DEC 1988 

MEMORANDUM 

SUBJECT: RACT Requirements in Ozone Nonattainment Areas 

FROM: Gerald A. Emison, Director Office of Air Quality Planning and 

Standards (MD-l0) 

TO: William A. Spratlin, Director Air and Toxics Division, Region VII 

This is in response to your memorandum of October 12, 1988 concerning reasonably 

available control technology (RACT) requirements for automobile assembly plants in ozone 

nonattainment areas. 

We agree that automobile assembly plants in ozone nonattainment areas should have 

volatile organic compound emission requirements that are at least as stringent as RACT. As 

described below, the requirements for new source performance standards (NSPS) or lowest 

available emission rate (LAER) (as determined at the time of permit issuance) for two plants in 

the St. Louis area may not be as stringent as RACT. Therefore, the St. Louis State 

implementation plan should contain RACT requirements for these plants. 

There are important differences in the format and compliance demonstration methodology 

for automobile coating RACT and NSPS. Topcoat and surfacer RACT require daily averaging 

and actual transfer efficiency, while the NSPS allows monthly averaging and table transfer 

efficiency values. These differences may result in RACT being more stringent than NSPS. The 

OAQPS recommends that the June 1988 protocol be used as the basis for determining 

compliance with the RACT limit. 

The Ford Hazelwood plant is subject to NSPS and RACT. The State has proposed to 

delete the RACT requirements for Ford Hazelwood on the basis that the NSPS is more stringent. 

This claim is not correct. Therefore, the RACT requirements for Ford Hazelwood should not be 

deleted, rather they should be maintained and the June 1988 protocol adopted as 

________________ 

(footnote-1)-For this discussion, RACT for topcoat means an appropriate emission limit 

for which compliance is demonstrated on a daily basis using the June 1988 protocol. For 

surfacer, the RACT requirements should also specify daily compliance and actual transfer 

efficiency. 
2 

the compliance determination procedure. 

The GM Wentzville plant was permitted as a new source in the early 1980's. This source is 

subject to NSPS and LAER, which was set equal to NSPS for topcoat and surfacer. Since the St. 

Louis RACT requirements for automobile coating were source specific and the GM Wentzville 

plant did not exist when the RACT requirements were first adopted, there are currently no RACT 

requirements for this plant. The NSPS and LAER requirements for this plant may not be as 

stringent as RACT. Therefore, RACT requirements should be adopted for GM Wentzville. 

Thank you for bringing this situation to our attention. Questions concerning this matter 

should be addressed to Bill Polglase (629-5246) or Dave Salman (629-5417). 

cc: J. Calcagni 

A. Campbell 

T. Helms 

J. Berry 

D. Salman 

G. McCutchen 

D. Crumpler 

B. Polglase 

J. Silvasi 

Director, Air Management Div., Regions I, III, V, IX 

Director, Air and Waste Management Division, Region II 

Director, Air, Pesticides, and Toxics Division, Regions IV, VI 

Director, Air and Toxics Division, Regions VII, VIII, X 

Chief, Air Branch, Regions IX 

Chief, Air Compliance Branch, Regions IV, V 

Chief, Air Enforcement Branch, Region III 

Chief, Air Operations Branch, Region IX