1 

Approval and Promulgation of Air Quality 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 from EPA regarding these Rule Revisions 

(including attachments to letter 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 require the Environmental Protection Agency 

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

that cause or contribute to air pollution that is reasonably anticipated to endanger public health or 

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

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

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

States are responsible for developing 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 both 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 the 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 atmosphere) due to the presence of nitrogen oxides (NOx), 

volatile organic compounds (VOCs), and carbon monoxide (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 photochemical reactions is illustrated by the pollutant profiles shown in 

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

fuel burning emission sources is converted to nitrogen dioxide (NO2) due to photochemical 

reactions. The formation of nitrogen dioxide further 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 operation or process involving materials which 

contain VOCs, using materials containing an inherently 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 developed 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 Quality Standard. In this action, EPA 

• Designated some parishes as nonattainment for the 1997 8-hour ozone standard, 
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• 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 Air Quality Standard. 

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

ppm. On January 6, 2010, EPA proposed to set the 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 reconsideration of the standard and thereafter will 

proceed with designations. The actions addressed 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, Louisiana 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 entitled, “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 schedule for final adoption of this 

VOC rule revision. 

Together, these revisions include updates to the following Louisiana rules: Chapter 1 “General 

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

Compounds, amendments to Subchapter B: Organic Solvents §2123 Organic 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, Alexandria, Parish of Rapides; and 

December 13, 2008, The Advocate, the official Journal 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 
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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 Journal 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 Comments on Organic Solvents 

and Solvent Degreasers” (AQ307) was published in the August 20, 2009 issue 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 section, in January 2011, Louisiana proposed a SIP revision related 

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

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

Organic Solvents, paragraph A., to read as follows: “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 application of surface coatings equal to or more than 15 

pounds (6.8 kilograms) per day, or an equivalent level 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 incorporating one or more of the 

following control methods: . . . ” 

In a letter to EPA dated February 7, 2011, the State 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, and 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 
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This rule will affect VOC-emitting facilities affected by the rules in Chapter 1 General 

Provisions §111 Definitions, Chapter 21 Subchapter 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 Chapter 21 controls for VOC emissions, cover many 

categories of sources in many parishes. In particular, this rulemaking affects sources covered by 

the LAC Chapters and Subchapters 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 Rotogravure, 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 affected 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 specified 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 Air Act require areas that are classified 

as moderate or above for ozone nonattainment 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) and (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 available considering technological and economic feasibility (44 

FR 53762; September 17, 1979). A CTG provides information on the available controls for a 
6 

source category and provides a “presumptive norm” RACT. 

The following provides a brief discussion 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 modifications, or other apparatus or techniques that are reasonably 

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

impact of controls. 

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

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

most stringent emissions limitation which is contained 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 achievable; or ... the most stringent emissions limit 

which is achieved in practice by such class or category of stationary sources.” 

Best available control technology (BACT) is a pollution control standard that applies to sources 

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

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

guidelines and is determined on a case-by-case basis. 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 applied 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 controls. Therefore, if a certain type of emission control or 

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

it achieves, that control might not be considered 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 does not necessarily define RACT for another 

location. In contrast, LAER level controls are more heavily focused towards applying the most 

stringent emission limitations achievable. 

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

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

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

the present. The documents provide information on the available control technology for various 

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

control information that provides a “presumptive 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 reasonable to control sources that are not major in size (the term 

“major source” is defined in section 182 of the CAA, and varies depending upon the location of 
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the source and the classification of that area). In those cases, States must adopt rules that cover 

these smaller sources. 

States and other interested parties are encouraged to use the latest information available in 

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

material submitted during the public review process. 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 the additional data in reviewing what control 

obligation is consistent with RACT. (For additional information, 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, Lithographic Printing Materials, Letterpress printing 

Materials, Industrial Cleaning Solvents, and 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 Coatings; Metal Furniture Coatings; and Large 

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

Group IV: Control Techniques guidelines in Lieu of Regulations for Miscellaneous Metal 

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

Fiberglass Boat Manufacturing Materials, and Miscellaneous Industrial 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 issued 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 document 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 revision that insures RACT 

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

to meet this requirement. 

Do Louisiana’s New Regulations 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 all 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 recommendation 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 dated 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 Degreasers AQ307, and then a letter dated May 5, 
8 

2010 in response to Proposed Rule AQ307. The most 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 period be subject to the regulation. Louisiana’s 

applicability language, including AQ320, reads as follows: “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 level 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 incorporating 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 per 12-month rolling period specification 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 exemptions 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. Therefore, 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 additional 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 included 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 Louisiana requested parallel processing of this 

revision, and provided a schedule for final adoption 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 for 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 were 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, and provided a schedule for final 

adoption of this VOC rule revision. 

Together, these revisions include updates to following Louisiana rules: Chapter 1 “General 

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

Compounds, amendments to Subchapter B: Organic Solvents §2123 Organic 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 February 7, 2011, requesting parallel 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: miscellaneous metal and plastic parts coatings; auto 

and light-duty truck assembly coatings; fiberglass boat manufacturing materials; and 

miscellaneous industrial adhesives. 

We have reviewed this action with respect to Control Techniques Guidelines (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 Parts 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 Coating 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-surfacer and topcoat operations should be 

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

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

Duty Trucks. 

3. Fiberglass Boat Manufacturing Materials (EPA CTG 2008) (LA §2123) 

The following recommended VOC Content and Vapor Pressure Limits for Cleaning 

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

a. From the CTG: “ . . . low-VOC and low vapor pressure cleaning materials that 
Page 2 of 4 

can be used for cleaning boat manufacturing application equipment are readily 

available. . . . we are recommending that 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 Adhesives (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 Application Operations. This third option is 

included in the rule. 

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

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

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

General and Specialty Adhesive Application Processes” on page 19. 

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

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

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

Addressed in §2123 Table 1 section 17. General 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 appliance coatings; metal 

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

flexible package printing; and 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 and 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 the above list of CTGs. 

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

 No comments. 

2. Lithographic printing materials and letterpress 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 addressed 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 revised (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 recommended 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 recommendations for coatings is at least 25 

tons per year. (“We recommend applying 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 Cleaning Materials should be added. 

c. Efficiency requirements should be revised (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 Coating-Related Activities should be added. 

b. Recommended Work Practices for Cleaning Materials should be added. 

c. Efficiency requirement should be revised (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 Coating Operations and Cleaning Materials 

should be added. 

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

(instead of 80 percent). 

Addressed in §2123 G., and D. 1. 
Page 1 of 27

Appendix B 

Detailed Review for RACT 

Control Technology Guidelines (LAC 33:III.111, §2123, and §2143) (AQ296 and AQ307) 

We have reviewed this action for Reasonably Available Control Technology (RACT) with respect to eleven Con

Guidelines (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 Parts Coatings (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 which were updated to address the above CTGs are high
Page 2 of 27

Surface Coating Industries

Affected Facility

LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ296 and 

Daily Weighted Aver

VOC Emission Limita

Lbs. per Gal. of Coating 

as applied (minus water 

and exempt solvent) 

Kg

Coat

(min

exe

1. Large Appliance Coating Industry 

Large Appliance Coating 

Industry 

2.8 lbs per gal and 

0.34 kgs per liter 

General, One Component 2.3 General, Multi-Component (Baked/Air Dried) 

2.3 / 2.8 0

Extreme High Gloss 2.8 
Page 3 of 27

Extreme Performance 2.8 Heat Resistant 2.8 Metallic 2.8 Pretreatment Coatings 2.8 Solar Absorbent 2.8 2. Surface Coating of Cans Sheet Basecoat (Exterior and Interior) and Over-Varnish: Two-Piece Can Exterior 

(Basecoat and Over-Varnish) 

2.8 

Two and Three-Piece Can Interior Body Spray, Two-Piece 

Can Exterior End (Spray or Roll 

Coat) 

4.2 
Page 4 of 27

Three-Piece Can Side-Seam Spray 

5.5 

End Sealing Compound 3.7 3. Surface Coating of Coils Prime and Topcoat or Single Coat Operation 

2.6 

4. Surface Coating of Fabrics Fabric Facility 2.9 Vinyl Coating Line (Except 

Plasticol Coatings) 

3.8 

5. Surface Coating–Magnet Wire Coating Coating Line 1.7 6. Surface Coating of Metal Furniture 

3.0 lbs / gal and 

0.36 kg / liter 
Page 5 of 27

General, One Component (Baked/Air Dried) 

2.3 / 2.3 0

General, Multi-Component (Baked/Air Dried) 

2.3 / 2.8 0

Extreme High Gloss (Baked/Air Dried) 

3.0 / 2.8 0

Extreme Performance 3.0 Heat Resistant 3.0 Metallic 3.0 Pretreatment Coatings 3.0 Solar Absorbent 3.0 
Page 6 of 27

Table 1. Surface Coating Industries

Affected Facility LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ 296 an

Daily Weighted Aver

VOC Emission Limita

Lbs. per 

Gal. of 

Coating as 

applied 

(minus 

water and 

exempt 

solvent) 

Lbs. per Gal. of Solids

Kgs. p

Liter 

Coati

as app

(minu

water 

exem

solve
Page 7 of 27

7. Surface Coating of Miscellaneous Metal Parts and Products 

Previous limits for this category were the same as or higher than the revised limits (in other words, the revised limits are the same or more stringent).

General, One Component or MultiComponent (Baked/Air Dried) 2.3 / 2.8 3.35 / 4.52 0.28 / 0Camouflage 3.5 6.67 0.42 Electric Insulating Varnish 3.5 6.67 0.42 Etching Filler 3.5 6.67 0.42 Extreme High Gloss (Baked/Air Dried) 3.0 / 3.5 5.06 / 6.67 0.36 / 0Extreme Performance (Baked/Air Dried) 3.0 / 3.5 5.06 / 6.67 0.36 / 0
Page 8 of 27

Heat Resistant (Baked/Air Dried) 3.0 / 3.5 5.06 / 6.67 0.36 / 0

Outdoor or 

harsh exposure or 

extreme performance 

characteristics

3.5 / 0.42

High Performance Architectural 3.5 6.67 0.42 High Temperature 3.5 6.67 0.42 Metallic 3.5 6.67 0.42 Military Specification (Baked/Air Dried)

2.3 / 2.8 3.35 / 4.52 0.28 / 0

Mold Seal 3.5 6.67 0.42 Pan Baking 3.5 6.67 0.42 Prefabricated Architectural, One Component or Multi-Component (Baked/Air Dried)

2.3 / 3.5 3.35 / 6.67 0.28 / 0

Pretreatment Coatings 3.5 6.67 0.42 
Page 9 of 27

Repair and Touch Up (Baked/Air Dried)

3.0 / 3.5

Does not 

apply

0.36 / 0

Silicone Release 3.5 6.67 0.42 Solar Absorbent (Baked/Air Dried) 3.0 / 3.5 5.06 / 6.67 0.36 / 0Vacuum Metalizing 3.5 6.67 0.42 Drum Coating, New, Exterior 2.8 4.52 0.34 Drum Coating, New, Interior 3.5 6.67 0.42 Drum Coating, Reconditioned, Exterior

3.5 6.67 0.42 

Drum Coating, Reconditioned, Interior 4.2 9.78 0.50 Powder Coating 

0.4 

Does not 

apply

0.05 

8. Surface Coating of Miscellaneous Plastic Parts and ProductsGeneral, One Component 2.3 3.35 0.28 General, Multi-Component 3.5 6.67 0.42 
Page 10 of 27

Electric Dissipating Coatings and Shock-Free Coatings

6.7 74.7 0.80 

Extreme Performance 3.5

(2-pack 

coatings)

6.67 

(2-pack 

coatings)

0.42

(2-pa

coatin

Metallic 3.5 6.67 0.42 Military Specification

2.8 (1 pack)3.5 (2 pack)

4.52 (1 

pack)

6.67 (2 

pack)

0.34

(1pac

0.42

(2pac

Mold Seal 6.3 43.7 0.76 Multi-Colored Coatings 5.7 25.3 0.68 Optical Coatings 6.7 74.7 0.80 Vacuum Metalizing 6.7 74.7 0.80 
Page 11 of 27

9. Surface Coating of Automotive/Transportation Plastic Partsa. High Bake Coatings–Interior and Exterior PartsFlexible Primer 4.5 11.58 0.54 Non-Flexible Primer 3.5 6.67 0.42 Base Coat 4.3 10.34 0.52 Clear Coat 4.0 8.76 0.48 Non-Base Coat/Clear Coat 4.3 10.34 0.52 b. Low Bake/Air Dried Coatings–Exterior PartsPrimer 4.8 13.80 0.58 Base Coat 5.0 15.59 0.60 Clear Coat 4.5 11.58 0.54 Non-Base Coat/Clear Coat 5.0 15.59 0.60 c. Low Bake/Air Dried Coatings–Interior Parts

5.0 15.59 0.60 

d. Touch Up and Repair Coatings 5.2 17.72 0.62 
Page 12 of 27

For red, yellow, and black auto coatings, except touch up and repair coatings, the limit is determined the appropriate limit in Item 9 of this Table by 1.15.10. Surface Coating of Business Machine Plastic PartsPrimer 2.9 4.80 0.35 Topcoat 2.9 4.80 0.35 Texture Coat 2.9 4.80 0.35 Fog Coat 2.2 3.14 0.26 Touch Up and Repair 2.9 4.80 0.35 11. Surface Coating of Pleasure CraftExtreme High Gloss Topcoat 4.1 9.2 0.49 High Gloss Topcoat 3.5 6.7 0.42 Pretreatment Wash Primer 6.5 55.6 0.78 Finish Primer/Surfacer 3.5 6.7 0.42 High Build Primer Surfacer 2.8 4.6 0.34 
Page 13 of 27

Aluminum Substrate Antifoulant Coating

4.7 12.8 0.56 

Other Substrate Antifoulant Coating 2.8 4.4 0.33 All Other Pleasure Craft Surface Coatings (for Metal or Plastic)

3.5 6.7 0.42 

Table 1. Surface Coating Industries

Affected Facility LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ 296 an

Daily Weighted Aver

VOC Emission Limita

Lbs. per Gal. of Coating 

as applied (minus water 

and exempt solvent) 

Kg

Coat

(min

exe
Page 14 of 27

12. Surface Coating of Motor Vehicle MaterialsMotor Vehicle Cavity Wax 5.4 Motor Vehicle Sealer 5.4 Motor Vehicle Deadener 5.4 Motor Vehicle Gaskets/GasketSealing Material 1.7 Motor Vehicle Underbody Coating

5.4 

Motor Vehicle Trunk Interior Coating

5.4 

Motor Vehicle Bedliner 1.7 Motor Vehicle Lubricating Wax/Compound

5.8 

The limits in Items 7-12 of this Table do not apply to operations covered in Items 1-6 or 13-17 hereincoatings, architectural coatings, or automobile refinish coatings.
Page 15 of 27

13. Factory Surface Coatings of Flat Wood Paneling with VOC Emissions Greater Than 15 Pounds PControls 

Limits for this category 

were previously given in 

lbs per 1000 sq. ft. of 

coated surface (ranging 

from 6.0 to 12.0 for three 

categories). 

All Inks, Coatings, and Adhesives 

2.1 

14. Surface Coatings for Marine Vessels and Oilfield Tubulars and Ancillary Oilfield Equipment a. Except as otherwise provided in this Section, a person shall not apply a marine coating with a VO

excess of the following limits: 

Baked Coatings 3.5 Air-Dried, Single-Component Alkyd or Vinyl Flat or SemiGloss Finish Coatings 3.5 Two Component Coatings 3.5 
Page 16 of 27

b. Except for the parishes of Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe C

Baton Rouge, in which the VOC limitations in Item 14.a of this Table may not be exceeded, specialty 

and coatings on oilfield tubulars and ancillary oilfield equipment with a VOC content not in excess of limits may be applied: 

Heat Resistant 3.5 Metallic Heat Resistant 4.42 High Temperature (Fed. Spec. TT-P-28) 

5.41 

Pre-Treatment Wash Primer 6.5 Underwater Weapon 3.5 Elastomeric Adhesives With 15 Percent by Weight Natural or Synthetic Rubber 

6.08 

Solvent-Based Inorganic Zinc Primer 

5.41 
Page 17 of 27

Pre-Construction and Interior Primer 

3.5 

Exterior Epoxy Primer 3.5 Navigational Aids 3.5 Sealant for Wire-Sprayed Aluminum 

5.4 

Special Marking 4.08 Tack Coat (Epoxies) 5.08 Low Activation Interior Coating 4.08 Repair and Maintenance Thermoplastic 

5.41 

Extreme High Gloss Coating 4.08 Antenna Coating 4.42 Antifoulant 3.66 High Gloss Alkyd 3.5 
Page 18 of 27

Anchor Chain Asphalt Varnish (Fed. Spec. TT-V-51) 

5.2 

Wood Spar Varnish (Fed. Spec. TT-V-119) 

4.1 

Dull Black Finish Coating (DOD-P-15146) 

3.7 

Tank Coatings (DOD-P-23236) 3.5 Potable Water Tank Coating (DOD-P-23236) 

3.7 

Flight Deck Markings (DOD-C24667) 4.2 Vinyl Acrylic Top Coats 5.4 Antifoulant Applied to Aluminum Hulls 

4.5 
Page 19 of 27

Table 1. Surface Coating Industries

Affected Facility LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ 296 an

Daily Weighted Aver

VOC Emission Limita

Kgs. VOC/Kgs. Solids 

(Lbs. VOC/Lbs. Solids) 

Kgs. V

(Lb

15. Surface Coating of Paper, Film, Foil, Pressure-Sensitive Tape, and Labels

Paper 

Coating Line 2.9 / 0.35 

Paper, Film, and Foil 0.40 Pressure-Sensitive Tape and 

Labels

0.20 
Page 20 of 27

Table 1. Surface Coating Industries

Affected Facility LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ 296 an

Daily Weighted Aver

VOC Emission Limita

Lbs. per Gal. of 

Deposited

Solids

Kg

Dep

16. Surface Coating of Assembly Line Automobiles and Light Duty TrucksPrimer-Surfacer Operations (Including Application Area, Flashoff Area, and Oven)

12.0 

Topcoat Operations (Including Application Area, Flashoff Area and Oven)

12.0 
Page 21 of 27

Final Repair Operations(Including Flashoff Area and Oven)

4.8 

Combined Primer-Surfacer and Topcoat Operations

12.0 

Electrodeposition Primer Operations (Including Application Area, Spray/Rinse Stations, and Curing Oven)

When 

Solids 

Turnover

Ratio is

RT ≥ 0.16

When

0.040 ≤ RT < 0.160
Page 22 of 27

0.084 

kgs./liter 

(0.7 

lbs./gal.) 

coating 

solids 

applied

0.084 x 3500.160-RT

kgs./liter (0.084 x 

3500.160-RT x 8.34 

lbs./gal.) coating solids 

applied
Page 23 of 27

Table 1. Surface Coating Industries

Affected Facility LA Rules prior to 

AQ 296 and AQ307 

LA Rules after AQ 296 an

Daily Weighted Aver

VOC Emission Limita

17. General and Specialty Adhesive Application Processes

Lbs. VOC per Gal. of 

Adhesive or Adhesive 

Primer (minus water 

and exempt 

compounds)

Grams 

Adhes

Prime

a

c

a. General Adhesive Application ProcessReinforced Plastic Composite 1.7 Flexible Vinyl 2.1 Metal 0.3 Porous Material (Except Wood) 1.0 
Page 24 of 27

Rubber 2.1 Wood 0.3 Other Subtrates 2.1 b. Specialty Adhesive Application ProcessesCeramic Tile Installation 1.1 Contact Adhesive 2.1 Cove Base Installation 1.3 Floor Covering Installation (Indoor)

1.3 

Floor Covering Installation (Outdoor)

2.1 

Floor Covering Installation (Perimeter Bonded Sheet Vinyl)

5.5 

Metal to Urethane/Rubber Molding or Casting

7.1 
Page 25 of 27

Motor Vehicle Adhesive 2.1 Motor Vehicle Weather Strip Adhesive

6.3 

Multipurpose Construction 1.7 Plastic Solvent Welding (ABS) 3.3 Plastic Solvent Welding (Except

ABS)

4.2 

Sheet Rubber Lining Installation 7.1 Single-Ply-Roof Membrane Installation/Repair (Except EPDM)

2.1 

Structural Glazing 0.8 Thin Metal Laminating 6.5 Tire Repair 0.8 
Page 26 of 27

Waterproof Resorcinol Glue

Application

1.4 

c. Adhesive Primer Application ProcessesMotor Vehicle Glass Bonding Primer

7.5 

Plastic Solvent Welding Adhesive Primer

5.4 

Single-Ply Roof Membrane Adhesive Primer

2.1 

Other Adhesive Primer 2.1 
Page 27 of 27

Table 1. Surface Coating Industries

18. Fiberglass Boat Manufacturing MaterialsFor this material — And this application method 

—

This weighted average monomer VOC content (weight percent) limit is —

Production resin Atomized (spray) 28Production resin Nonatomized 35Pigmented gel coat Any method 33Clear gel coat Any method 48Tooling resin Atomized 30Tooling resin Nonatomized 39Tooling gel coat Any method 40