# 1 Approval and Promulgation of Air Qualit y Implementation Plans; Louisiana;

Control of Air Pollution from Volatile Organic Compounds

Technical Support Document

Docket ID EPA-R06-OAR-2010-0775

March 2011

Table of Contents:

I. Background

II. State Submittal

III. Review and Evaluation of Revisions to VOC Control Regulations for RACT

IV. Related Rulemaking

V. Conclusions and Recommendations

VI. Reference

Appendix A: Detailed Comments to LDEQ fr om EPA regarding these Rule Revisions

(including attachments to lett er dated September 24, 2009)



# Appendix B: Detailed Review for RACT

Control Technology Guidelines (LAC 33:III.111, §2123, and §2143) (AQ296 and

AQ307)

I. Background

The Clean Air Act (CAA) Amendments of 1990 re quire the Environmental Protection Agency

(EPA) to establish air quality criteria and national ambient air quality standards for pollutants

that cause or contribute to air po llution that is reasonably anticipa ted to endanger public health or

welfare (CAA § 108 - 109). National ambient air quality standards (NAAQS) define levels of

air quality which the Administrato r judges are necessary, with an adequate margin of safety, to

protect the public health, and ar e identified in 40 CFR § 50.

States are responsible for deve loping State Implementation Plans (SIPs) for the NAAQS which

identify how these standards will be attained and maintained. This plan must provide for

implementation, maintenance, and enforcement of primary air quality standards in each air

quality control region with the State (CAA § 110).

The NAAQS for ozone identify standards for bot h 1-hour (§50.9) and 8-hr ozone (§50.10). The

1-hour standard is 0.12 parts per million (ppm) ground-level ozone. The 1-hour standard is

attained when the expected number of days per calendar year with maximum hourly average

concentrations above 0.12 ppm is equal to or less than 1, as determined by appendix H to part 50.

The 1997 8-hour standard is 0.08 ppm and the 2008 8-hr standard is 0.075 ppm. Eight-hour

ozone values are calculated as a daily maximum 8-hour average. The 8-hour standard is met at

an ambient air quality monitoring site when the average of the fourth-highest daily maximum 8-

# 2 hour average ozone concentration is less than or equal to th e standard, as determined by

appendix I to part 50.

Ozone is a pollutant that forms photochemically (i.e. a reaction caused by sunlight) in the

troposphere (lowest portion of the at mosphere) due to the presence of nitrogen oxides (NOx),

volatile organic compounds (VOCs), and carbon mo noxide (CO). The emission rates of these

precursor compounds are regulated in order to minimize the formation rate of ozone and the

other photochemical reaction products.

The general nature of the photoche mical reactions is il lustrated by the pollutant profiles shown in

Figure 1. Nitric oxide (NO) emitted from fossil-fu el-fired boilers, automobiles, trucks, and other

fuel burning emission sources is converted to nitrogen dioxide (NO 2 

# ) due to photochemical

reactions. The formation of nitrogen dioxide fu rther stimulates the photochemical smog-forming

reactions because nitrogen dioxide is very efficient at absorbing sunlight.

As the reactions proceed, nitrogen dioxide reacts to form particulate and vapor phase nitrates. As

the nitric oxide concentration drops, the levels of ozone rise rapidly. The formation of ambient

levels of ozone is highest during the summer months since the intensity of sunlight necessary for

the photochemically initiated reactions is highest during this time period.

The current rulemaking addresses control of VOC concentrations. A variety of techniques can

be used to reduce VOC emissions. For any ope ration or process involving materials which

contain VOCs, using materials containing an in herently low quantity of VOC compounds will

reduce the release of VOCs. Also, processes can be redesigned to reduce the quantities that are

lost as fugitive emissions. When these techniques are inapplicable or insufficient, add-on control

systems can be used:

Under the 1-hr ozone standard, Louisiana had deve loped a number of VOC controls for the 1-hr

ozone nonattainment areas. On April 30, 2004, EPA issued Part I of a Final Rule to implement

the 1997 8-hour ozone National Ambient Air Qu ality Standard. In this action, EPA

• Designated some parishes as nonattai nment for the 1997 8-hour ozone standard,

# 3 • Classified some parishes in Louisiana as moderate

On November 29, 2005, EPA issued Part II of the Final Rule to implement the 1997 8-hour

ozone National Ambient Ai r Quality Standard.

On March 27, 2008 (73 FR 16436), EPA promulgate d a revised 8-hour ozone standard of 0.075

ppm. On January 6, 2010, EPA proposed to set th e level of the primary 8-hour ozone standard

within the range of 0.060 to 0.070 ppm, rather than at 0.075 ppm. EPA anticipates that by the

end of July 2011 it will have completed reconsid eration of the standard and thereafter will

proceed with designations. The actions addresse d in today’s rulemaking related to control of

VOC emissions. EPA’s actions with respect to this new standard do not affect EPA’s action

here.

II. State Submittal

A. Regulatory Chronology

In June 2009 and August 2010, Louisi ana adopted revisions to the Louisiana SIP for control of

VOC emissions which were submitted to EPA on August 31, 2010: AQ296 was adopted on June

20, 2009, and AQ307 was adopted on August 31, 2010. These VOC control revisions were

included in LDEQ’s submittal en titled, “VOC RACT Control Technique Guidelines” dated

August 2010 as Appendices A (AQ 296) and B ( AQ 310). Also, in January 2011, Louisiana

proposed a related revision to the Louisiana SIP (AQ320), which is a small wording change to

the VOC rules that EPA is proposing to approve by parallel processing. In a letter to EPA dated

February 7, 2011, signed by Secretary Hatch on behalf of the Governor, the State of Louisiana

requested parallel processing of this revision, and provided a sche dule for final adoption of this

VOC rule revision.

Together, these revisions includ e updates to the following Louisi ana rules: Chapter 1 “General

Provisions” amendments to §§111 Definitions; Ch apter 21 Control of Emission of Organic

Compounds, amendments to Subchapter B: Organic Solvents §2123 Or ganic Solvents, and

amendments to Subchapter H: Graphic Arts §2143 Graphic Arts (Printing) by Rotogravure,

Flexographic, Offset Lithographic, Letterpress, and Flexible Package Printing Processes.

Additional detail is provided for each Louisiana revision below:

For AQ296:

Notices were published in the following newspapers:

December 13, 2008, The Times, Parish of Caddo;

December 16, 2008, Lake Charles American Press, Parish of Calcasieu;

December 18, 2008, the Town Talk, Alex andria, Parish of Rapides; and

December 13, 2008, The Advocate, the official J ournal of the State of the Louisiana, the

City of Baton Rouge, and the Parish of East Baton Rouge.

“Advanced Notice of Potential Rulemaking and Solicitation of Comments on Control

# 4 Technology Guidelines” (AQ296) was published in the August 20, 2008 issue of the Louisiana

Register (Vol. 34, No. 08). Proposed Rule AQ296 was published December 20, 2008 in the

Louisiana Register (Vol. 34, No. 12). Notice of public hearing was included December 13, 2008

in The Times and The Advocate; December 16, 2008 in The Lake Charles American Press; and

December 18, 2008 in The Town Talk. On January 27, 2009, a public hearing was held in Baton

Rouge, Louisiana.

For AQ307:

Notices were published in the following newspapers:

August 20, 2009, The Times – Picayune, Parish of Orleans, City of New Orleans;

August 13, 2009, The Advertiser, Acadiana, Parish of Lafayette;

August 12, 2009, the Town Talk, Alexandria, Parish of Rapides; and

August 13, 2009, The Advocate, the official Jour nal of the State of the Louisiana, the

City of Baton Rouge, and the Parish of East Baton Rouge.

August 19, 2009, Lake Charles American Press, Parish of Calcasieu;

August 14, 2009, The Times, Parish of Caddo; and

August 18, 2009, The News-Star, Monroe, Parish of Ouachita.

“Advanced Notice of Potential Rulemaking and Solicitation of Comment s on Organic Solvents

and Solvent Degreasers” (AQ307) was published in the August 20, 2009 i ssue of the Louisiana

Register (Vol. 35, No. 8). Proposed Rule AQ307 was published March 20, 2010 in the

Louisiana Register (Vol 36, No. 3). Notice of public hearing was included March 13, 2010 in

The Town Talk; March 15, 2010 in The Advertiser , The Times, and the Lake Charles American

Press; March 16, 2010 in The Advocate and the News Star; and March 20, 2010 in The Times

Picayune. On April 28, 2010, a public hearing was held in Baton Rouge, Louisiana.

AQ320:

As mentioned earlier in this se ction, in January 2011, Louisiana proposed a SIP revision related

to AQ296 and AQ307, numbered AQ320, which is a sm all wording change to the VOC rules that

EPA is proposing to approve by parallel proc essing. This proposed revision updates §2123

Organic Solvents, paragraph A., to read as follo ws: “Except as provided in Subsections B and C

of this Section, any emissions source us ing organic solvents having an emission of volatile

organic compounds resulting from the application of surface coatings equal to or more than 15

pounds (6.8 kilograms) per day, or an equivalent level of 2.7 t ons per 12-month rolling period,

shall control emissions of volatil e organic compounds through the use of low solvent coatings, as

provided in subsection C of this Section, or where feasible, by inco rporating one or more of the

following control methods: . . . ”

In a letter to EPA dated February 7, 2011, the Stat e of Louisiana requested parallel processing of

this revision, and provided a schedule for final adoption of this VOC rule revision. A copy of the

letter including the rule, the rule changes, a nd the promulgation schedule, is available in the

docket for this action and is referenced in Section VI of this TSD.

B. Revision of VOC Control Regulations

# 5 This rule will affect VOC-emitting facilities affected by the rules in Chapter 1 General

Provisions §111 Definitions, Chapter 21 Subc hapter B. Organic Solvents §2123 Organic

Solvents, or Subchapter H. Graphic Arts §2143 Graphic Arts (Printing) by Rotogravure,

Flexographic, Offset Lithographic, Letterpress, and Flexible Package Printing Processes.

Louisiana’s Chapter 1 definitions, and Chapte r 21 controls for VOC emissions, cover many

categories of sources in many parishes. In part icular, this rulemaking af fects sources covered by

the LAC Chapters and Subcha pters listed in Table 1:

Table 1

Louisiana Administrative Code (LAC) 33: III.111, 2123, and 2143

Chapters and Subchapters Affected by this Rulemaking

Chapter 1 General Provisions

111. Definitions

Chapter 21 Control of Emission of Organic Compounds

Subchapter B Organic Solvents

§2123 Organic Solvents

Subchapter H Graphic Arts

§2143 Graphic Arts (Printing) by Rotogravur e, Flexographic, Offset Lithographic,

Letterpress, and Flexible Package Printing Processes

Applicability for these rules includes requirements that vary by parish. To determine whether a

specific facility in a Louisiana parish will be a ffected by one or more of the above revisions,

please see Louisiana’s associated rule revisions included in the docket.

These rules require compliance with the specif ied VOC control requirements by the effective

date of this rulemaking.

III. Review and Evaluation of Revisions to VOC Control Regulations for RACT

What is RACT? Sections 172(c)(1) and 182 of the Clean Ai r Act require areas th at are classified

as moderate or above for ozone nonattainmen t to adopt Reasonably Available Control

Technology (RACT) requirements for sources that are subject to Control Techniques Guidelines

(CTGs) issued by EPA and for “major sources” of VOCs and NOx, which are ozone precursors.

See 42 U.S.C. sections 7502 (c)(1) and 7511a (b) a nd (f). RACT is defined as the lowest

emissions limitation that a particular source is capable of meeting by the application of control

technology that is reasonably av ailable considering technological and economic feasibility (44

FR 53762; September 17, 1979). A CTG provides in formation on the available controls for a

# 6 source category and provides a “presumptive norm” RACT.

The following provides a brief disc ussion of RACT and how it differs from other types of control

levels such as those for new sources. RACT level controls are defined by 40 CFR 51.100(o) as

devices, systems, process modifica tions, or other appara tus or techniques that are reasonably

available. RACT is required to take into account the social, envir onmental, and economic

impact of controls.

RACT level controls apply to existing sources in non-attainment areas and differ from the more

stringent lowest achievable emi ssion rate (LAER) controls required for new sources in nonattainment areas. LAER is defined in CAA S ection 171(3) and 40 CFR 51.165(a)(1)(xiii) as “the

most stringent emissions limitation which is cont ained in the implementation plan of any State

for such class or category of source, unless the owner or operator of the proposed source

demonstrate that such limitations are not achie vable; or ... the most stringent emissions limit

which is achieved in practice by such cla ss or category of st ationary sources.”

Best available control technology (BACT) is a pollu tion control standard th at applies to sources

in areas that have attained the national ambi ent air quality standard. BACT applies to all

polluting sources that fall under new and modifi ed sources covered by the New Source Review

guidelines and is determined on a case-by-case ba sis. When BACT is determined, factors such

as total source emissions, energy consumption, regional environmental impact, and economic

costs are taken into account. Because BACT is a pplied to new and modified sources, it can often

be a more stringent control level than can be achieved reasonably by retrofit of an existing

source.

One important distinction between RACT and LAER is that RACT is required to take into

account the economic impact of the c ontrols. Therefore, if a certai n type of emission control or

emission limitation is determined to be too cost ly compared to the amount of emission reduction

it achieves, that control might not be consider ed RACT. Also, as economic factors may vary

within a State and between different States , a control technology or emission limitation

designated as meeting RACT in one location doe s not necessarily define RACT for another

location. In contrast, LAER leve l controls are more heavily focu sed towards applying the most

stringent emission limitations achievable.

As mentioned above, and as required by the C AA, EPA has issued a number of CTGs and

Alternative Control Technique (ACT) Guidelines to assist States in implementing RACT

requirements. These documents have been i ssued over a period dating from the mid-1970’s to

the present. The documents provide informati on on the available contro l technology for various

source categories and new guidelines exist for the vast majority of VOC so urces. CTG’s provide

control information that provides a “presump tive norm” for RACT for particular source

categories. States’ rules that conform to the “presumptive norm” established in the CTG have

generally been approved as RACT. It is important to note that for source categories covered by a

CTG, EPA has often found it is reas onable to control sources that ar e not major in size (the term

“major source” is defined in section 182 of the CAA, and varies depending upon the location of

# 7 the source and the classification of that area). In those cases, Stat es must adopt rules that cover

these smaller sources.

States and other interested part ies are encouraged to use the la test information available in

making RACT determinations, whether that information is in CTGs, ACTs, other guidance, or

material submitted during the public review proce ss. In cases where additional information is

presented, for example, as part of notice-and-comment rulemaking on a RACT SIP submittal,

States and EPA would necessarily consider th e additional data in reviewing what control

obligation is consistent with RACT. (For additional informa tion, see Reference 1: RACT

Questions & Answers, dated May 18, 2006.)

EPA issued Control Techniques Guidelines (CTGs) in 2006, 2007 and 2008: Consumer and

Commercial Products Group II: Control Techniques Guidelines in Lieu of Regulations for

Flexible Packaging Printing Materials, Lithogr aphic Printing Material s, Letterpress printing

Materials, Industrial Cleaning Solvents, a nd Flat Wood Paneling Coatings (71 FR 58745,

October 5, 2006); Consumer and Commercial Products : Control Techniques Guidelines in Lieu

of Regulations for Paper, Film, and Foil Co atings; Metal Furniture Coatings; and Large

Appliance Coatings (72 FR 57215, October 9, 2007); Consumer and Commercial Products,

Group IV: Control Techniques guide lines in Lieu of Regulati ons for Miscellaneous Metal

Products Coatings, Plastic Parts Coatings, Au to and Light-Duty Truck Assembly coatings,

Fiberglass Boat Manufacturing Materials, and Miscellaneous Industria l Adhesives (73 FR 58481,

October 7, 2008). Under 182(b)(2)(A) of the Act, States are required to implement RACT for

each category of sources covered by any CTG issu ed by the administrator between the dated of

enactment of the Clean Air Act Amendments of 1990 and the date of attainment. This

requirement was carried forward for the 1997 8 hour standard under 40 CFR 51.912(a). The

rule revisions being reviewed in this docum ent were in response to these new CTGs.

Baton Rouge was reclassified to moderate under the 1997 8 hour ozone standard on March 21,

2008 (73 FR 15087). As such, Louisiana is obligated to provide a SIP revi sion that insures RACT

for the new CTGs is implemented. These revision s to the SIP provided by Louisiana are intended

to meet this requirement.

Do Louisiana’s New Regulati ons Meet RACT Requirements? EPA has evaluated Louisiana’s

Chapter 1 and 21 revisions. Appendix B of this TSD includes a table showing the recommended

limits for the categories which were adopted by Louisiana. In a ll cases, Louisiana’s new limits

are equivalent to the limits recommended in the CTG or Louisiana left in place the existing limit

because it was more stringent than the recomm endation in the CTG. Where appropriate, a

comparison is made between the previous Louisiana limits, and the new limits.

As part of this evaluation, EPA reviewed LDEQ ’s response to comments. The State’s new VOC

regulations were available for public comment prior to adoption by the State. EPA had provided

three comment letters related to these rules to LDEQ: one da ted April 9, 2009 regarding AQ296,

another on September 24, 2009 for Advanced Notice of Potential Rulemaking and Solicitation of

Comments on Organic Solvents and Solvent De greasers AQ307, and then a letter dated May 5,

# 8 2010 in response to Proposed Rule AQ307. The mo st recent of these letters (May 5, 2010) was

formally addressed by LDEQ in Appendix B of the August 31, 2010 submittal in the “Comment

Summary and Responses for Proposed Rule AQ307”. A copy of the letter dated September 24,

2009 which includes the April 9, 2009 information as well, is provided at the end of this TSD

together with information about how these comments were addressed by LDEQ.

RACT Applicability. The recommendation in the CTG is that sources that emit more than 15

lbs/day vs. 2.7 tons per 12-month rolling peri od be subject to the re gulation. Louisiana’s

applicability language, including AQ320, reads as fo llows: “Except as provided in Subsections B

and C of this Section, any emissions source using organic solvents having an emission of volatile

organic compounds resulting from the applications of surface coatings of more than 15 pounds

(6.8 kilograms) per day, or an equivalent leve l of 2.7 tons per 12-month rolling period, shall

control emissions of volatile organic compounds through the use of low solvent coatings, as

provided in Subsection C of this Section, or, where feasible, by inco rporating one or more of the

following control methods:”. Facilities meeting these applicability requirements based on either

the 15 lbs/day or the 2.7 tons pe r 12-month rolling period specifi cation will be subject to the

updated VOC controls. Therefore, Louisiana’ s rules ensure the recommended sources are

covered by the new requirements.

Industrial Cleaning Solvent Requirements . This category, which is addressed by §2123 D. 10

and 11, includes requirements and also exempti ons suggested in the CTG (CTG: Industrial

Cleaning Solvents, Sept. 2006). Work practices for coating-related activities and cleaning

materials are included in §2123 G. 1 – 4. Therefor e, Louisiana’s rules insure RACT is being met

for this source category.

Additional Information . For additional information, please see Louisiana’s Chapter 1 and 21

revisions which are included in the docket.

Summary. Based on this analysis, we find that these VOC rule revisions enhance the SIP by

providing clarification and additi onal control requirements for reducing emissions from volatile

organic compounds, and that these revisions meet RACT requirements. Therefore, EPA is

proposing to find that for the CTG categories incl uded in this rule-making, Louisiana has RACTlevel controls.

IV. Related Rulemaking

On June 20, 2009 and August 31, 2010, LDEQ adopted revisions to their rules for control of

VOCs. These were submitted to EPA on August 31, 2010. Also, in January 2011, Louisiana

proposed a related revision to the Louisiana SIP (AQ320), which is a small wording change to

the VOC rules that EPA is proposing to approve in this action by parallel processing. In a letter

to EPA dated February 7, 2011, the State of L ouisiana requested parallel processing of this

revision, and provided a schedule for final a doption of this VOC rule revision. These

requirements for control of VOC emissions meet Reasonably Available Control Technology

(RACT) requirements and will help to attain and maintain the 8-hour ozone standard in affected

# 9 parishes in Louisiana. Our approval of the revised Louisiana regulations will make them

federally enforceable.

EPA is evaluating Louisiana’s analysis fo r RACT for NOx and for other VOC emission

categories in actions which are separate from this one.

V. Conclusions and Recommendations

Based on the above discussion, EPA recommends proposed approval of revisions to the

Louisiana State Implementation Plan (SIP) for control of VOC emissions which were submitted

to EPA on August 31, 2010 as follows: AQ296 adopted on June 20, 2009, and AQ307 adopted

on August 31, 2010. These VOC control revisions we re included in LDEQ’s submittal entitled,

“VOC RACT Control Technique Guidelines” dated August 2010 as Appendices A (AQ 296) and

B (AQ 310). Also, EPA recommends proposed approval, by parallel processing, of a SIP

revision proposed by Louisiana on January 20, 2011, AQ320. This revision to the Louisiana SIP

is a small wording change to the VOC rules. In a letter to EPA dated February 7, 2011, the State

of Louisiana requested parallel processing of this revision, an d provided a schedule for final

adoption of this VOC rule revision.

Together, these revisions includ e updates to following Louisian a rules: Chapter 1 “General

Provisions” amendments to §§111 Definitions; Ch apter 21 Control of Emission of Organic

Compounds, amendments to Subchapter B: Organic Solvents §2123 Or ganic Solvents, and

amendments to Subchapter H: Graphic Arts §2143 Graphic Arts (Printing) by Rotogravure,

Flexographic, Offset Lithographic, Letterpress, and Flexible Package Printing Processes.

VI. References

1. Louisiana’s SIP revision, AQ296, adopted on June 20, 2009.

2. Louisiana’s SIP revision, AQ307, adopted October 31, 2010.

3. Louisiana’s SIP revision, AQ320, proposed January 20, 2011.

4. Letter from State of Louisiana, dated Febr uary 7, 2011, requesting pa rallel processing of

AQ320. Included with this letter are a copy of the rule, the rule changes, and the

promulgation schedule.

# Page 1 of 4 Appendix A

Detailed Comments

(Attachments to Letter Dated September 24, 2009)



# Comments on AQ307 Organic Solvents and Solvent Degreasers (LAC 33:III.111 and 2123)

. These rules address the following CTGs: miscella neous metal and plastic parts coatings; auto

and light-duty truck assembly coatings; fi berglass boat manufacturing materials; and

miscellaneous industrial adhesives.

We have reviewed this action with respect to Control Techniques Guidel ines (CTGs) issued by

EPA in 2008:

Group IV (73 FR 58481, October 7, 2008)

Miscellaneous Metal and Plastic Parts Coatings

Auto and Light-Duty Truck Assembly Coatings

Fiberglass Boat Manufacturing Materials

Miscellaneous Industrial Adhesives

Our comments are organized by the above list of CTGs.

1. Miscellaneous Metal and Plastic Part s Coatings (EPA CTG 2008) (LA §2123)

Recommended Option 2 for reducing coating VOC emissions, should be added. This

option expresses emissions limits in mass of VOC per volume of coating solids. (CTG,

pp. 35 – 38).

Addressed in §2123 Table 1, 7. Surface Coatin g of Miscellaneous Metal Parts and Products.



# 2. Auto and Light-Duty Truck Assembly Coatings (EPA CTG 2008) (LA §2123)

VOC emission limits for “Combined Primer-s urfacer and topcoat operations should be

added to Table 3. se ction 16 (CTG, p. 20).

Addressed in §2123 Table 1, 16. Surface Coatin g of Assembly Line Authomobiles ad light

Duty Trucks.



# 3. Fiberglass Boat Manufacturing Ma terials (EPA CTG 2008) (LA §2123)

The following recommended VOC Content a nd Vapor Pressure Limits for Cleaning

Materials should be adde d (CTG, pp. 32 -33).

a. From the CTG: “ . . . low-VOC and low va por pressure cleaning materials that

# Page 2 of 4 can be used for cleaning boat manufactu ring application equipment are readily

available. . . . we are recommending th at VOC cleaning solvents for routine

application equipment cleaning contain no more than 5 percent VOC by weight,

or have a composite vapor pressure of no more than 0.50 mm Hg at 68 degrees F”

(68 degrees F / 20 degrees Celcius). This is much lower than the vapor pressure

of 8 mm Hg in LAC 33:III.2123.D.10.e.

b. Also from this CTG: “We recommend that only non-VOC solvents be used to

remove curing resin and gel coat from application equipment.”

Addressed in §2123 D.12 a. and b.



# 4. Miscellaneous Industrial Adhe sives (EPA CTG 2008) (LA §2123)

The CTG recommends three options, the third of which is an efficiency requirement of

85% for Add-on Controls for Adhesive Applic ation Operations. This third option is

included in the rule.

The other two options recommended in th e CTG should be added to the rule:

a. VOC Emission Limits “Adhesive and A dhesive Primer” should be added to the

rule. The CTG includes a table of “Recommended VOC Emission Limits for

General and Specialty Adhesive Ap plication Processes” on page 19.

b. Adhesive Application Methods requiremen ts should be added to the rule. VOC

emission limits for “Combined Primer-sur facer and topcoat operations should be

added to Table 3. se ction 16 (CTG, p. 20).

Addressed in §2123 Table 1 section 17. Ge neral and Specialty Adhesive Application

Processes, and D. 13. a - h.

# Page 3 of 4 The following comments were submitted on April 9, 2009. We are submitting them

again so they may become part of the public record.

Comments on AQ296 Control Technique Guidelines (LAC 33:III.111, 2123, and 2143)

. These rules address the following CTGs: flat wood paneling; large appl iance coatings; metal

furniture coatings; lithographic printing and letterpress printing; paper, film and foil coatings;

flexible package printing; a nd industrial cleaning solvents.

We have reviewed this action with respect to eleven Control Techniques Guidelines (CTGs)

issued by EPA in 2006 and 2007:

Group II (71 FR 58745, October 5, 2006)

Flexible Packaging Printing Materials

Lithographic Printing Materials a nd Letterpress Printing Materials

Industrial Cleaning Solvents

Flat Wood Paneling Coatings

Group III (72 FR 57215, October 9, 2007)

Paper, Film, and Foil Coatings

Metal Furniture Coatings

Large Appliance Coatings

Our comments are organized by th e above list of CTGs.

1. Flexible Packaging Printing Materials (EPA CTG 2006) (LA §2143)

No comments.

2. Lithographic printing materials and letterp ress printing materials (EPA CTG 2006) (LA

§2143)

No comments.

3. Industrial Cleaning Solvents (EPA CTG 2006)

a. It is not clear whether this CTG is a ddressed by this rulemaking. If applicable,

please add material to address this CTG. Alternatively, please provide

information explaining how this CTG is addressed in documents accompanying

rule.

b. The efficiency requirement should be re vised (increased) to at least 85 percent

(instead of 80 percent) in LA §2123 D. 1. [See also comments V.c. Paper, Film

and Foil Coatings, VI.c. Metal Furniture Coatings, and VII. b. Large Appliance

Coatings, where the recommende d efficiency is 90 percent.]

Addressed in §2123 D. 10 and 11, and D. 1.

# Page 4 of 4 4. Flat wood paneling coatings (EPA CTG 2006) (LA §2123)

No comments.

5. Paper, Film, and Foil Coatings (EPA CTG 2007)

a. The applicability threshold for control r ecommendations for coatings is at least 25

tons per year. (“We recommend ap plying the control recommendations for

coatings only to individual paper, film and foil surface coating lines with the

potential to emit at least 25 tons per year (tpy) of VOC from coatings, prior to

controls.”). Please incorporate this applicability requirement.

b. Recommended Work Practices for Cl eaning Materials should be added.

c. Efficiency requirements should be revi sed (increased) to at least 90 percent

(instead of 80 percent).

Addressed in §2123 A., G., and D. 1.



# 6. Metal Furniture Coatings (EPA CTG 2007) (LA §2123)

a. Recommended Work Practices for Coa ting-Related Activities should be added.

b. Recommended Work Practices for Cl eaning Materials should be added.

c. Efficiency requirement should be revi sed (increased) to at least 90 percent

(instead of 80 percent).

Addressed in §2123 G., and D. 1.



# 7. Large Appliance Coatings (EPA CTG 2007) (LA §2123)

a. Recommended Work Practices for Coa ting Operations and Cleaning Materials

should be added.

b. Efficiency requirement should be revi sed (increased) to at least 90 percent

(instead of 80 percent).

Addressed in §2123 G., and D. 1.Page1of27Appendix BDetailed Review for RACTControl Technology Guidelines (LAC33:III.111, §2123, and §2143) (AQ296 and AQ307)We have reviewed this action for Reasonably Available ControlTechnology (RACT) with respectto eleven Control TechniquesGuidelines (CTGs) issued by EPA in 2006, 2007 and 2008:Group II (71 FR 58745, October 5, 2006)Flexible Packaging Printing Materials (2143)Lithographic Printing Materials and Letterpress Printing Materials (2143)Industrial Cleaning Solvents (2123. 10. and 11.)Flat Wood Paneling Coatings (2123. C. 13)Group III (72 FR 57215, October 9, 2007)Paper, Film, and Foil Coatings (2123. C. 15)Metal Furniture Coatings (2123. C. 6.)Large Appliance Coatings (2123. C. 1.)Group IV (73 FR 58481, October 7, 2008)Miscellaneous Metal and Plastic PartsCoatings (2123. C. 7., 8., 9., 10., 11., and 12.)Auto and Light-Duty Truck Assembly Coatings (2123. C. 16.)Fiberglass Boat Manufacturing Materials (2123. C. 18.)Miscellaneous Industrial Adhesives (2123. C. 17.)Our review is provided below. The sections of the table whichwere updated to address the aboveCTGs are highlighted in yellow.Page2of27Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ296 and AQ307Daily Weighted AverageVOC Emission LimitationLbs. per Gal. of Coatingas applied (minus waterand exempt solvent)Kgs. per Liter ofCoating as applied(minus water andexempt solvent)1. Large ApplianceCoating IndustryLarge Appliance CoatingIndustry2.8 lbs per gal and0.34 kgs per literGeneral, One Component2.30.275General, Multi-Component(Baked/Air Dried)2.3 / 2.80.275 / 0.340Extreme High Gloss2.80.340Page3of27Extreme Performance 2.80.340Heat Resistant2.80.340Metallic2.80.340Pretreatment Coatings2.80.340Solar Absorbent2.80.3402. Surface Coating of CansSheet Basecoat (Exterior andInterior) and Over-Varnish:Two-Piece Can Exterior(Basecoat and Over-Varnish)2.8 0.34Two and Three-Piece CanInterior Body Spray, Two-PieceCan Exterior End (Spray or RollCoat)4.2 0.51Page4of27Three-Piece Can Side-SeamSpray5.5 0.66End Sealing Compound 3.7 0.443. Surface Coating of CoilsPrime and Topcoat or SingleCoat Operation2.6 0.314. Surface Coating of FabricsFabric Facility2.90.35Vinyl Coating Line (ExceptPlasticol Coatings)3.8 0.455. Surface Coating–Magnet Wire CoatingCoating Line1.70.206. Surface Coating of Metal Furniture3.0 lbs / gal and0.36 kg / literPage5of27General, One Component(Baked/Air Dried)2.3 / 2.30.275 / 0.275General, Multi-Component(Baked/Air Dried)2.3 / 2.80.275 / 0.340Extreme High Gloss (Baked/AirDried)3.0 / 2.80.360 / 0.340Extreme Performance3.00.360Heat Resistant3.00.360Metallic3.00.360Pretreatment Coatings3.00.360Solar Absorbent3.00.360Page6of27Table 1. Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ 296 and AQ307Daily Weighted AverageVOC Emission LimitationLbs. perGal. ofCoating asapplied(minuswater andexemptsolvent)Lbs. perGal. ofSolidsKgs. perLiter ofCoatingas applied(minuswater andexemptsolvent)Kgs. perLiter ofSolidsPage7of277. Surface Coating of Miscellaneous Metal Parts and ProductsPrevious limits forthis category werethe same as orhigher than therevised limits (inother words, therevised limits arethe same or morestringent).General, One Component or MultiComponent (Baked/Air Dried)2.3 / 2.83.35 / 4.520.28 / 0.340.40 / 0.54Camouflage3.56.670.420.80Electric Insulating Varnish3.56.670.420.80Etching Filler3.56.670.420.80Extreme High Gloss (Baked/Air Dried)3.0 / 3.55.06 / 6.670.36 / 0.420.61 / 0.80Extreme Performance (Baked/AirDried)3.0 / 3.55.06 / 6.670.36 / 0.420.61 / 0.80Page8of27Heat Resistant (Baked/Air Dried)3.0 / 3.55.06 / 6.670.36 / 0.420.61 / 0.80Outdoor orharsh exposure orextreme performancecharacteristics3.5 / 0.42High Performance Architectural3.56.670.420.80High Temperature3.56.670.420.80Metallic3.56.670.420.80Military Specification (Baked/AirDried)2.3 / 2.83.35 / 4.520.28 / 0.340.40 / 0.54Mold Seal3.56.670.420.80Pan Baking3.56.670.420.80Prefabricated Architectural, OneComponent or Multi-Component(Baked/Air Dried)2.3 / 3.53.35 / 6.670.28 / 0.420.40 / 0.80Pretreatment Coatings3.56.670.420.80Page9of27Repair and Touch Up (Baked/AirDried)3.0 / 3.5Does notapply0.36 / 0.42Does notapplySilicone Release3.56.670.420.80Solar Absorbent (Baked/Air Dried)3.0 / 3.55.06 / 6.670.36 / 0.420.61 / 0.80Vacuum Metalizing3.56.670.420.80Drum Coating, New, Exterior2.84.520.340.54Drum Coating, New, Interior3.56.670.420.80Drum Coating, Reconditioned,Exterior3.56.670.420.80Drum Coating, Reconditioned, Interior4.29.780.501.17Powder Coating0.4Does notapply0.05Does notapply8. Surface Coating of Miscellaneous Plastic Parts and ProductsGeneral, One Component2.33.350.280.40General, Multi-Component3.56.670.420.80Page10of27Electric Dissipating Coatings andShock-Free Coatings6.774.70.808.96Extreme Performance3.5(2-packcoatings)6.67(2-packcoatings)0.42(2-packcoatings)0.80(2-packcoatings)Metallic3.56.670.420.80Military Specification2.8 (1 pack)3.5 (2 pack)4.52 (1pack)6.67 (2pack)0.34(1pack)0.42(2pack)0.54(1pack)0.80(2pack)Mold Seal6.343.70.765.24Multi-Colored Coatings5.725.30.683.04Optical Coatings6.774.70.808.96Vacuum Metalizing6.774.70.808.96Page11of279. Surface Coating of Automotive/Transportation Plastic Partsa. High Bake Coatings–Interior and Exterior PartsFlexible Primer4.511.580.541.39Non-Flexible Primer3.56.670.420.80Base Coat4.310.340.521.24Clear Coat4.08.760.481.05Non-Base Coat/Clear Coat4.310.340.521.24b. Low Bake/Air Dried Coatings–Exterior PartsPrimer4.813.800.581.66Base Coat5.015.590.601.87Clear Coat4.511.580.541.39Non-Base Coat/Clear Coat5.015.590.601.87c. Low Bake/Air Dried Coatings–InteriorParts5.015.590.601.87d. Touch Up and Repair Coatings5.217.720.622.13Page12of27For red, yellow, and black auto coatings, except touch up andrepair coatings, the limit isdetermined by multiplyingthe appropriate limit in Item9 of this Table by 1.15.10. Surface Coating of Business Machine Plastic PartsPrimer2.94.800.350.57Topcoat2.94.800.350.57Texture Coat2.94.800.350.57Fog Coat2.23.140.260.38Touch Up and Repair2.94.800.350.5711. Surface Coating of Pleasure CraftExtreme High Gloss Topcoat4.19.20.491.10High Gloss Topcoat3.56.70.420.80Pretreatment Wash Primer6.555.60.786.67Finish Primer/Surfacer3.56.70.420.80High Build Primer Surfacer2.84.60.340.55Page13of27Aluminum Substrate AntifoulantCoating4.712.80.561.53Other Substrate Antifoulant Coating2.84.40.330.53All Other Pleasure Craft SurfaceCoatings (for Metal or Plastic)3.56.70.420.80Table 1. Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ 296 and AQ307Daily Weighted AverageVOC Emission LimitationLbs. per Gal. of Coatingas applied (minus waterand exempt solvent)Kgs. per Liter ofCoating as applied(minus water andexempt solvent)Page14of2712. Surface Coating of Motor Vehicle MaterialsMotor Vehicle Cavity Wax5.40.65Motor Vehicle Sealer5.40.65Motor Vehicle Deadener5.40.65Motor Vehicle Gaskets/GasketSealing Material1.70.20Motor Vehicle UnderbodyCoating5.40.65Motor Vehicle Trunk InteriorCoating5.40.65Motor Vehicle Bedliner1.70.20Motor Vehicle LubricatingWax/Compound5.80.70The limits in Items 7-12 of this Table do not apply to operations covered in Items 1-6 or13-17 herein, or to aerosolcoatings, architectural coatings, or automobile refinish coatings.Page15of2713. Factory Surface Coatingsof Flat Wood Paneling with VOC EmissionsGreater Than 15 Pounds Per Day BeforeControlsLimits for this categorywere previously given inlbs per 1000 sq. ft. ofcoated surface (rangingfrom 6.0 to 12.0 for threecategories).All Inks, Coatings, andAdhesives2.10.2514. Surface Coatingsfor Marine Vessels and Oilfield Tubulars and Ancillary Oilfield Equipmenta. Except as otherwise provided in this Section, a person shall not apply a marine coating with a VOC content inexcess of the following limits:Baked Coatings3.50.42Air-Dried,Single-ComponentAlkyd or Vinyl Flat or SemiGloss Finish Coatings3.5 0.42Two Component Coatings3.5 0.42Page16of27b. Except for the parishes of Ascension,Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and WestBaton Rouge, in which theVOC limitations in Item 14.a of this Tablemay not be exceeded, specialty marine coatingsand coatings on oilfield tubulars and ancillary oilfield equipment with a VOC content not in excess of the followinglimits may be applied:Heat Resistant3.50.42Metallic Heat Resistant4.420.53High Temperature (Fed. Spec.TT-P-28)5.41 0.65Pre-Treatment WashPrimer 6.5 0.78Underwater Weapon3.50.42Elastomeric Adhesives With 15Percent byWeight Natural orSynthetic Rubber6.08 0.73Solvent-Based Inorganic ZincPrimer5.41 0.65Page17of27Pre-Construction and InteriorPrimer3.5 0.42Exterior Epoxy Primer3.50.42Navigational Aids3.50.42Sealant for Wire-SprayedAluminum5.4 0.648Special Marking4.080.49Tack Coat (Epoxies)5.080.61Low Activation Interior Coating4.080.49Repair and MaintenanceThermoplastic5.41 0.65Extreme High Gloss Coating4.080.49Antenna Coating4.420.53Antifoulant 3.660.44High Gloss Alkyd3.50.42Page18of27Anchor Chain Asphalt Varnish(Fed. Spec. TT-V-51)5.2 0.62Wood Spar Varnish (Fed. Spec.TT-V-119)4.1 0.492Dull Black Finish Coating(DOD-P-15146)3.7 0.444Tank Coatings(DOD-P-23236)3.50.42Potable Water Tank Coating(DOD-P-23236)3.7 0.444Flight Deck Markings (DOD-C24667)4.2 0.504Vinyl Acrylic Top Coats5.4 0.648Antifoulant Applied to AluminumHulls4.5 0.55Page19of27Table 1. Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ 296 and AQ307Daily Weighted AverageVOC Emission LimitationKgs.VOC/Kgs.Solids(Lbs.VOC/Lbs.Solids)Kgs.VOC/Kgs.Coating(Lbs.VOC/bLbs.Coating)15. Surface Coating ofPaper, Film, Foil, Pressure-Sensitive Tape, and LabelsPaperCoating Line2.9 / 0.35Paper, Film, and Foil0.400.08Pressure-Sensitive Tape andLabels0.200.067Page20of27Table 1. Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ 296 and AQ307Daily Weighted AverageVOC Emission LimitationLbs. per Gal. ofDepositedSolidsKgs. per Liter ofDeposited Solids16. Surface Coating of Assembly Line Automobiles and Light Duty TrucksPrimer-Surfacer Operations(Including Application Area,Flashoff Area, and Oven)12.01.44Topcoat Operations (IncludingApplication Area, Flashoff Areaand Oven)12.01.44Page21of27Final Repair Operations(Including Flashoff Area andOven)4.80.58Combined Primer-Surfacer andTopcoat Operations12.01.44Electrodeposition PrimerOperations (IncludingApplication Area, Spray/RinseStations, and Curing Oven)WhenSolidsTurnoverRatio isRT≥0.16When0.040≤RT< 0.160WhenRT< 0.040Page22of270.084kgs./liter(0.7lbs./gal.)coatingsolidsapplied0.084 x 3500.160-RTkgs./liter (0.084 x3500.160-RTx 8.34lbs./gal.) coating solidsappliedNo VOCemission limitPage23of27Table 1. Surface Coating IndustriesAffected FacilityLA Rules prior toAQ 296 and AQ307LA Rules after AQ 296 and AQ307Daily Weighted AverageVOC Emission Limitation17. General and SpecialtyAdhesive Application ProcessesLbs. VOC per Gal. ofAdhesive or AdhesivePrimer (minus waterand exemptcompounds)Grams VOC per Liter ofAdhesive or AdhesivePrimer (minus waterand exemptcompounds)a. General AdhesiveApplication ProcessReinforced Plastic Composite1.7200Flexible Vinyl2.1250Metal0.330Porous Material (Except Wood)1.0120Page24of27Rubber2.1250Wood0.330Other Subtrates2.1250b. Specialty Adhesive Application ProcessesCeramic Tile Installation1.1130Contact Adhesive2.1250Cove Base Installation1.3150Floor Covering Installation(Indoor)1.3150Floor Covering Installation(Outdoor)2.1250Floor Covering Installation(Perimeter Bonded Sheet Vinyl)5.5660Metal to Urethane/RubberMolding or Casting7.1850Page25of27Motor Vehicle Adhesive2.1250Motor Vehicle Weather StripAdhesive6.3750Multipurpose Construction1.7200Plastic Solvent Welding (ABS)3.3400Plastic Solvent Welding (ExceptABS)4.2500Sheet Rubber Lining Installation7.1850Single-Ply-Roof MembraneInstallation/Repair (ExceptEPDM)2.1250Structural Glazing0.8100Thin Metal Laminating6.5780Tire Repair0.8100Page26of27Waterproof Resorcinol GlueApplication1.4170c. Adhesive Primer Application ProcessesMotor Vehicle Glass BondingPrimer7.5900Plastic Solvent WeldingAdhesive Primer5.4650Single-Ply Roof MembraneAdhesive Primer2.1250Other Adhesive Primer2.1250Page27of27Table 1. Surface Coating Industries18. Fiberglass Boat Manufacturing MaterialsFor this material —And this application method—This weighted averagemonomer VOC content(weight percent) limit is —Production resinAtomized(spray)28Production resinNonatomized35Pigmented gel coatAny method33Clear gel coatAnymethod48Tooling resinAtomized30Tooling resinNonatomized39Tooling gel coatAnymethod40