iO S,

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

W-i Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711 4, “j

4L mo

1 1 APR 1986

MEMORANDUM

SUBJECT: Responses to Five VOC Issues Raised by the Regional

Offices and Departpe of Justice

FROM: Gerald A. Emi son

Office of Air u ity Plann ng and Standards

TO: Air Management Division Directors

Regions I, III, V and IX

Air and Waste Management 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 of Compliance Monitoring When Incineration Is Only

Used Sporadically o Transfer Efficiency o Test Methods for Assessing 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 of the VOC issues, please see my

February 28 memorandum to you with a similar title.l We are working with

the appropriate Headquarters offices to expedite issuance of the remaining

fe’ VOC issues.

I apprciate your staffs’ efforts In comenting on the various drafts

of these issues and hope that you fint them helpful 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: mis
9

Issue:

What criteria should be used to determine economic

feasibility for non-CTG VOC sources? For CTG sources wherp

recommended RACT is technically infeasible?

Response:

EPA’s definition of VOC RACT for ozone plans is the

lowest emission limitation that a particular source is capable f meeting 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 of the individual

source. Hence, whether or not a source Is addressed by a

CTG, no universally applicable decision rule can supplant

case—by-case judgment on what constitutes RACT.

In evaluating economic feasibility for RACT, 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