iO S, UNITEDSTATESENVIRONMENTALPROTECTIONAGENCY W-i OfficeofAirQualityPlanningandStandards ResearchTrianglePark,NorthCarolina27711 4, “j

4 Lmo 

### 11 APR

### 1986 MEMORANDUM SUBJECT: Responses to Five VOC Issues Raised by the Regional Offices and Departpe ofJustice FROM: GeraldA. Emison Office of Air u ity Plann ng and Standards TO: AirManagement Division Directors Regions I, III, V and IX Air andWasteManagement Division Director Region II Air, Pesticides, and Toxics Management Division Directors Regions IV and VI Air and Toxics Divisions Directors Regions VII, VIII and X

Attached are responses to five VOC issues Identified by the Regional Offices and DOJ through the VOC Compliance Workgroup. These five Issues are:

0 Recordkeeping o EconomIc Feasihility for Non CTG Sources Type ofCompliance Monitoring When Incineration Is Only Used Sporadically o Transfer Efficiency o TestMethods forAssessing VOC Compliance This is the second group of responses that I have issued and brings the total number of responses issued by Headquarters to thirteen. (For more information on the background ofthe VOC issues, please see my February 28memorandumtoyou with a similar title.l We are workingwith the appropriate Headquarters offices to expedite issuance of the remaining fe’ VOC issues. I apprciateyour staffs’ efforts In comenting on the various drafts of these issues and hope that you fint themhelpful in resolving some of the issues concerning 

### VOC enforcement. Attachment

cc: VOC Compliance Workgroup Regional Counsel, Regions I—X NOTE: Attachments not included in the Policy and Guidance Notebook. DATE: 04/11/ AUTHOR: 

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Issue: What criteria should be usedto determine economic feasibility for non-CTG VOC sources? For CTG sources wherp recommended RACT is technically infeasible? Response: EPA’s definition ofVOC RACTfor ozone plans is the lowest emission limitation that a particular source is capable fmeeting by the application of control technology that Is reasonably available considering technological and economic feasibility. This is explained in greater depth in the September 17, 1979 supplement to the general preamble on the criteria for approval of Part 0 SIP revisions (44 FR 53761). Where EPA cannot rely on presumptive norms, RACT for a parti cular source is determined on a case—by—case basis considering the technological and economic circumstances 

### ofthe individual source. Hence, whether or not a source Is addressed by a 

### CTG, no universally applicable decision rule can supplant case—by-casejudgment 

### onwhat constitutes RACT. In evaluating economic feasibility forRACT, the Agency gives significant weight to cost-effectiveness. However, no specific cost effectiveness threshold exists to determine RACT. Numerous other factors (i.e., age of facility, quantity of emissions, nature of emissions, severity of existing air quality problem, extent of controls present, comparability to standard Industry practice in related industries, cross media impacts, economic impacts, etc.) must be considered in establishing RACT. It is conceivable, given differing local circumstances, that a control option 

### could be reasonably available In one location and unreasonable In another.

Planning and Standards



### Late Signed