1. Table of Contents

1. Introduction

2. RACT Evaluation Approach

2.1. General Discussion

2.2. Identification of CTG and Non-CTG Emission Sources

2.3. Determining if State Regulations Fulfill RACT Requirements

3. RACT Determination and Discussion

3.1. General Discussion

3.2. NOX RACT Determination

3.2.1. Chapter 117 NOX Rules

3.3. VOC RACT Determination

3.3.1. Existing Chapter 115 VOC RACT Rules

3.3.2. Flexible Package Printing Materials

3.3.3. Industrial Cleaning Solvents

3.3.4. Large Appliance Coatings

3.3.5. Metal Furniture Coatings

3.3.6. Paper, Film, and Foil Coatings

3.3.7. Miscellaneous Industrial Adhesives

3.3.8. Miscellaneous Metal and Plastic Parts Coatings

3.3.9. Automobile and Light-Duty Truck Assembly Coatings
APPENDIX F: REASONABLY AVAILABLE CONTROL 

TECHNOLOGY ANALYSIS

1. INTRODUCTION

The Dallas-Fort Worth eight-hour ozone nonattainment area (DFW area) is currently classified 

as serious under the 1997 eight-hour ozone National Ambient Air Quality Standards (NAAQS) 

(75 FR 79302, December 20, 2010). Under the 1997 eight-hour ozone standard, the DFW area is 

required to meet the mandates of the Federal Clean Air Act (FCAA) under §172(c)(1) and

§182(b)(2) and (f). According to the United States Environmental Protection Agency’s (EPA)

Final Rule to Implement the Eight-Hour Ozone NAAQS (40 Code of Federal Regulations (CFR) 

§51.912, November 29, 2005), a state containing areas classified as moderate nonattainment 

and above must submit a state implementation plan (SIP) revision demonstrating that its 

current rules fulfill the reasonably available control technology (RACT) requirements for all 

control techniques guidelines (CTG) emission source categories and all non-CTG major sources 

of nitrogen oxides (NOX) and volatile organic compounds (VOC). The major source threshold for 

serious nonattainment areas is a potential to emit 50 tons per year (tpy) or more of either NOX

or VOC. This appendix provides the TCEQ's analysis of the sources and the applicable rules to 

demonstrate that the state is fulfilling the RACT requirements for the DFW area.

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). RACT requirements for moderate 

and above classification nonattainment areas are included in the FCAA to assure that significant 

source categories at major sources of ozone precursor emissions are controlled to a reasonable 

extent, but not necessarily to best available control technology (BACT) levels expected of new 

sources or to maximum achievable control technology (MACT) levels required for major sources 

of hazardous air pollutants.

While RACT and reasonably available control measures (RACM) have similar consideration 

factors like technological and economic feasibility, there is a significant distinction between 

RACT and RACM. A control measure must advance attainment of the area towards the meeting 

the NAAQS for that measure to be considered RACM. Advancing attainment of the area is not a 

factor of consideration when evaluating RACT because the benefit of implementing RACT is 

presumed under the FCAA.

The EPA issued 11 CTG documents from 2006 through 2008 with recommendations for VOC 

controls on a variety of consumer and commercial products. Some of the new CTG 

recommendations are updates to previously issued CTG documents and some are 

recommendations for new categories. 

The RACT analysis included in the DFW RACT Update, 30 Texas Administrative Code Chapter 

117 Rule Revision Noninterference Demonstration, and Modified Failure-to-Attain Contingency 

Plan SIP revision adopted March 10, 2010, addressed the following CTG documents:

• Flat Wood Paneling Coatings, Group II issued in 2006;

• Offset Lithographic and Letterpress Printing, Group II issued in 2006; and

• Fiberglass Boat Manufacturing Materials, Group IV issued in 2008.

The RACT analysis included in this SIP revision addresses following CTG documents:
• Flexible Packaging Printing Materials, Group II issued in 2006;

• Industrial Cleaning Solvents, Group II issued in 2006;

• Large Appliance Coatings, Group III issued in 2007;

• Metal Furniture Coatings, Group III issued in 2007;

• Paper, Film, and Foil Coatings, Group III issued in 2007;

• Miscellaneous Industrial Adhesives, Group IV issued in 2008;

• Miscellaneous Metal and Plastic Parts Coatings, Group IV issued in 2008; and

• Auto and Light-Duty Truck Assembly Coatings, Group IV issued in 2008.

2. RACT EVALUATION APPROACH

2.1. General Discussion

The TCEQ demonstrates that the RACT requirements are being fulfilled in the DFW area by: (1) 

identifying all CTG source categories of NOX and VOC emissions and submitting negative 

declarations for categories where there are no emission sources within the DFW area; (2) 

identifying all non-CTG major sources of NOX and VOC emissions; (3) identifying the state 

regulation that implements or exceeds RACT for each applicable CTG source category or nonCTG major emission source; and (4) describing the basis for concluding that these regulations 

fulfill RACT.

2.2. Identification of CTG and Non-CTG Emission Sources

The EPA has issued CTG documents defining RACT for existing facilities. The EPA has also 

issued Alternative Control Technology (ACT) documents that describe available control 

technologies but do not define presumptive RACT levels. The TCEQ reviewed the EPA's CTG 

and ACT documents to identify all source categories of NOX and VOC emissions that require 

RACT. RACT determinations are not required if there are no facilities in the DFW area that are 

subject to a CTG or ACT document. A negative declaration is provided for source categories 

described within the EPA guidance documents that do not exist in the DFW area.

Under the EPA’s 1997 eight-hour ozone regulations for serious ozone nonattainment areas, the 

threshold for major stationary sources is a potential to emit of 50 tpy of either NOX or VOC 

emissions. The TCEQ reviewed the point source emissions inventory and Title V databases to 

identify all major sources of NOX or VOC emissions. All sources in the Title V database that were 

listed as a major source for NOX or VOC emissions are included in the RACT analysis. Since the 

point source emissions inventory database reports actual emissions rather than potential to 

emit, the TCEQ reviewed sources that reported actual emissions as low as 25 tpy of NOX or VOC 

to account for the difference between actual and potential emissions. Sites from the emissions 

inventory database with emissions of 25 tpy or more of NOX or VOC that were not identified in 

the Title V database and could not be verified as minor sources by other means are also included 

in the RACT analysis.

2.3. Determining if State Regulations Fulfill RACT Requirements

The EPA previously approved the DFW VOC rules in 30 Texas Administrative Code (TAC) 

Chapter 115 and NOX rules in 30 TAC Chapter 117 as meeting the FCAA RACT requirements (74 

FR 1903; January 14, 2009). State regulations in Chapters 115 and 117 that implement the 

controls recommended in CTG or ACT documents or that implement equivalent or superior 

emission control strategies were determined to fulfill RACT requirements for any CTG or ACT 

documents issued prior to 2006. For CTG documents issued in 2006 and later, RACT was 

evaluated by comparing CTG recommendations to TCEQ rules to determine if the existing rules 

satisfied RACT requirements. RACT determinations for three of the CTG documents issued from 

2006 to 2008 were submitted to the EPA on April 6, 2010 (SIP Project Number 2009-021-SIP-
NR). Additional discussion regarding CTG documents issued in 2006 and later is provided in 

Section 3.3: VOC RACT Determination of this appendix. State rules that are consistent with or 

more stringent than controls implemented in other nonattainment areas were also determined 

to fulfill RACT requirements. Federally approved state rules and rule approval dates can be 

found in 40 CFR §52.2270(c), EPA Approved Regulations in the Texas SIP.

BACT is an emission standard that is based on the maximum degree of emission reduction 

achievable and is at least as stringent as the emission standards set by any applicable FCAA 

provisions. MACT is an emission standard that requires the maximum reduction of hazardous 

emissions and is at least as stringent as the average emission level achieved by controls on the 

top 12% of existing sources in the applicable source category. Therefore, emission sources 

subject to the more stringent BACT or MACT requirements were determined to also fulfill RACT 

requirements.

The TCEQ reviewed the emission sources in the DFW area and the applicable state rules to 

verify that all CTG or ACT emission source categories and non-CTG and ACT major emission 

sources in the DFW area were subject to requirements that meet or exceed the applicable RACT 

requirements, or that further emission controls on the sources were either not economically 

feasible or not technologically feasible.

3. RACT DETERMINATION AND DISCUSSION

3.1. General Discussion

Under the current state rules, the DFW area is subject to some of the most stringent NOX and 

VOC emission control requirements in the country and for many source categories the existing 

rules are more stringent than recommended RACT standards for those categories. The EPA 

previously approved the VOC RACT analysis as submitted in the May 2007 DFW Eight-Hour 

Ozone Attainment Demonstration SIP Revision (74 FR 1903, January 14, 2009). The analysis 

demonstrated all CTG emission source categories addressed by CTG documents issued prior to 

2006 and all major VOC emission sources in the DFW area were subject to rules in 30 TAC 

Chapter 115, or other federally enforceable measures, that meet or exceed the applicable RACT 

requirements, or that further emission controls on the sources were either not technologically or 

economically feasible.

Table F-1: State Rules Addressing NOX RACT Requirements in CTG and ACT Reference 

Documents provides the emission source categories, the CTG and ACT reference documents, 

and the state rules addressing the RACT requirements for sources in the CTG and ACT 

documents. A negative declaration is provided in the table for emission source categories that 

based on information available to the TCEQ either do not exist in the DFW area or exist but do 

not meet the applicability criteria recommended for controls, e.g., sources less than the 

recommended exemption thresholds. Table F-2: State Rules Addressing VOC RACT 

Requirements in CTG and ACT Reference Documents provides the emission source categories, 

the CTG and ACT reference documents, and the state rules addressing the RACT requirements 

for sources in the CTG and ACT documents. A negative declaration is provided in the table for 

emission source categories that based on information available to the TCEQ either do not exist 

in the DFW area or exist but do not meet the applicability criteria recommended for controls, 

e.g., sources less than the recommended exemption thresholds.

Table F-3: State Rules Addressing NOX RACT Requirements for Major Emission Sources in the 

DFW Area and Table F-4: State Rules Addressing VOC RACT Requirements for Major 

Emission Sources in the DFW Area list the major stationary emission sources with actual or 

potential emissions exceeding the 50 tpy major source threshold in the DFW area. Some sources 
listed may actually be less than the major source threshold but were included in the tables. The 

tables provide the emission source regulated entity number (RN), account number, company 

name, standard industrial classification (SIC) code, a brief description of the source, and the 

reported annual emissions (in tpy). The tables also include either the state rules satisfying the 

RACT requirements, the permit requirements that limit emissions, or the reasoned justification 

for why controlling the emissions is not considered RACT. Additionally, in order to facilitate 

review of the major source RACT determination, Tables F-3 and F-4 identify those sites that 

were included in the major source RACT analysis for the 2007 attainment demonstration SIP 

revision for the 1997 eight-hour ozone NAAQS.

3.2. NOX RACT Determination

3.2.1. Chapter 117 NOX Rules

The Chapter 117 rules represent one of the most comprehensive NOX control strategies in the 

nation. The NOX controls and reductions implemented through Chapter 117 for the DFW ozone 

nonattainment area encompass both RACT and beyond-RACT levels of control. The current 

EPA-approved Chapter 117 rules fulfill RACT requirements for all CTG and ACT NOX source 

categories. Table F-1 provides additional details on the CTG and ACT source categories.

For non-CTG and ACT major NOX emission source categories, RACT is fulfilled by separate 

existing source-specific rules in Chapter 117 for sources that NOX controls are technologically 

and economically feasible. Further NOX controls on certain major sources were determined to be 

either not economically feasible or not technologically feasible. Table F-3 provides additional 

detail on the non-CTG and ACT major emission source categories.

3.3. VOC RACT Determination

3.3.1. Existing Chapter 115 VOC RACT Rules

All VOC emission source categories addressed by CTG and ACT documents that VOC controls 

are technologically and economically feasible are controlled by existing rules in Chapter 115,

other EPA-approved regulations that fulfill RACT requirements, and by revisions to Chapter 115

VOC rules that are being adopted concurrently with this SIP revision (Rule Project Numbers 

2010-016-115-EN and 2010-025-115-EN). Sections 3.3.2 through 3.3.9 of this appendix discuss 

the RACT determination for eight CTG documents issued by the EPA between 2006 and 2008. 

Section 3.3.10 of this appendix discusses the RACT determination for the petroleum liquid 

storage CTG emission source category. Table F-2 provides additional details on the CTG and 

ACT source categories.

For all non-CTG and ACT major VOC emission source categories that VOC controls are 

technologically and economically feasible, RACT is fulfilled by existing Chapter 115 rules, other 

federally enforceable measures, and by revisions to Chapter 115 VOC rules that are being 

adopted concurrently with this SIP revision (Rule Project Number 2010-025-115-EN). Section 

3.3.10 of this appendix discusses the RACT determination for crude oil and condensate storage 

tanks with the potential to emit at least 50 tpy of VOC. Additional VOC controls on certain major

sources were determined to be either not economically feasible or not technologically feasible. 

Table F-4 provides additional detail on the non- CTG and ACT major emission source 

categories.

3.3.2. Flexible Package Printing Materials

Concurrent with this SIP revision, the commission is adopting revisions to the flexographic and 

rotogravure printing rules in 30 TAC Chapter 115, Subchapter E: Solvent-Using Processes, 

Division 3: Flexographic and Rotogravure Printing to implement the EPA’s 2006 Flexible 
Package Printing CTG recommendations that the TCEQ has determined are RACT in the DFW 

area (Rule Project Number 2010-016-115-EN). The Chapter 115 rulemaking reduces the VOC 

content limits of coatings, increases the overall control efficiency of add-on controls used in

flexible package printing processes, establishes work practice procedures for materials used 

during associated cleaning activities, and expands rule applicability to include smaller flexible 

package printing lines that were previously exempt from these rules.

The TCEQ is not implementing the EPA’s 2006 CTG recommendation to exempt flexible 

package printing operations from all VOC coating content limits if the operations have total 

actual VOC emissions less than 15 pounds per day from inks, coatings, and adhesives. For the 

DFW area, the existing Chapter 115 rules provide an exemption for combined flexographic and 

rotogravure printing operations with the potential to emit less than 50 tpy of VOC from inks. 

Calculating only the VOC emissions resulting from flexible package printing operations to 

determine exemption from the required controls may create backsliding issues for properties 

already complying with the current Chapter 115 rules because sources currently subject to the 

Chapter 115 rules could potentially become exempt. The existing Chapter 115 exemption limit is 

equal to or potentially more stringent than the 2006 CTG-recommended exemption threshold 

for properties conducting multiple flexographic and rotogravure printing operations, and is 

retained in the rules.

Additionally, the TCEQ is not implementing the EPA’s 2006 CTG recommendation to exempt a

flexible package printing line from complying with VOC coating content limits if the line has the 

potential to emit less than 50 tpy of uncontrolled VOC emissions from the dryer, from inks, 

coatings, and adhesives. As previously stated, the current Chapter 115 rules require combining 

the VOC emissions from all flexographic and rotogravure printing lines to determine exemption 

from the VOC coating content limits. Implementing the 2006 CTG recommendation may 

exempt flexible package printing lines co-located on a property with other flexographic and 

rotogravure printing lines that are currently required to comply with the VOC control limits. The 

Chapter 115 rules retain the existing VOC content limits for a flexible package printing line with 

VOC emissions below the 2006 CTG-recommended exemption threshold.

The EPA's 2006 CTG recommends requiring control equipment to have an overall control 

efficiency ranging from 65% to 80% depending on the first installation date of the press and 

control equipment. The TCEQ disagrees with the 2006 CTG recommendation to correlate 

control device efficiency requirements with the first installation date of the printing press or 

control device regardless of where the equipment was first installed. Imposing this policy may 

encourage the installation of older, less efficient equipment and may create potential backsliding 

issues. The policy may also create significant practical enforceability issues for TCEQ 

investigators with regard to verifying the first installation date of the control equipment. 

Instead, the TCEQ is requiring the CTG-recommended 80% overall control efficiency, regardless 

of the first installation date.

3.3.3. Industrial Cleaning Solvents

Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115, 

Subchapter E, to create new Division 6: Industrial Cleaning Solvents to implement the EPA's 

2006 Industrial Cleaning Solvents CTG recommendations that the TCEQ has determined are

RACT in the DFW area (Rule Project Number 2010-016-115-EN). The Chapter 115 rulemaking 

establishes VOC content limits for cleaning solvents used in specific cleaning activities, provides

exemptions for certain cleaning activities from all or portions of the rule, and requires certain 

work practice procedures for the use, storage, and disposal of cleaning solvents. In response to 

comments on the proposed industrial cleaning solvents rules, the commission is adopting new 
§115.461(c) to exempt a solvent cleaning operation from the requirements in this division if the 

VOC emissions from that solvent cleaning operation are controlled by the control requirements 

or emission specifications in another division in Chapter 115. The adopted new exemption 

provides flexibility and reduces the compliance burden for affected sources. Additionally, the 

commission expects that complying with requirements in other Chapter 115 rules is at least as 

effective as meeting the industrial cleaning solvents rule requirements. The adopted exemption 

is consistent with the EPA's 2006 CTG recommendation to ensure that a particular cleaning 

activity is not subject to duplicative requirements.

3.3.4. Large Appliance Coatings

Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115, 

Subchapter E, to create new Division 5: Control Requirements for Surface Coating Processes to 

implement the EPA's 2007 Large Appliance Coatings CTG recommendations that the TCEQ has 

determined are RACT in the DFW area (Rule Project Number 2010-016-115-EN). The Chapter 

115 rulemaking reduces VOC content limits of coatings, increases the overall control efficiency 

for add-on controls used in large appliance coating operations, and establishes minimum 

transfer efficiency for coating application methods. The rules also require certain work practice 

procedures for coating-related activities and materials used during associated cleaning 

operations.

The EPA’s 2007 CTG recommends exempting large appliance coating operations from the 

coating VOC content limits and work practice standards if total uncontrolled VOC emissions 

from coatings and associated cleaning solvents are less than 15 pounds per day. The current 

TCEQ rules provide an exemption from the coating VOC content limits for large appliance 

coating operations if total uncontrolled VOC emissions from all applicable coating processes on 

a property subject to Chapter 115, Subchapter E, Division 2: Surface Coating Processes are less 

than 3.0 pounds per hour and 15 pounds per day. The existing exemption from the required 

VOC controls may be more stringent for properties conducting multiple coating operations 

specified in Division 2 because the exemption is not based on VOC emissions from a single 

coating category. To prevent potential backsliding for properties already required to comply 

with the state’s regulations, the Chapter 115 rules retain the existing exemption criteria.

The existing TCEQ large appliance coating limits are based on the original CTG 

recommendations issued by the EPA in 1977. Several of the recommended VOC content limits 

for specific coating categories listed in the 2007 CTG document are less stringent than the limits 

specified in the EPA’s original CTG recommendations for this coating category. The 2007 CTG 

also recommends minimum solids transfer efficiency for coating application equipment. Despite 

the higher VOC content limits for the specialty coatings, the EPA’s 2007 CTG claims that 

implementing the limits as recommended would result in an overall emissions reduction and 

provides documentation containing the methodology used to estimate the reduction. The TCEQ 

also conducted a comprehensive comparison of the 2007 CTG recommendations to the existing 

VOC coating content limit and determined that implementing the 2007 CTG-recommended 

coating VOC content limits will not negatively impact the status of the state’s attainment with 

the 1997 eight-hour ozone NAAQS, will not interfere with control measures, and will not prevent 

reasonable further progress toward attainment of the ozone NAAQS. Despite the full 

demonstration of noninterference provided in the proposed rule preamble (Rule Project 

Number 2010-016-115-EN), the EPA commented that in order for the proposed rules to be 

approved as RACT, the state must also demonstrate that the existing Chapter 115 VOC content 

limits for large appliance coatings, which were based on the EPA’s original CTG 

recommendations, are no longer technologically or economically feasible. The commission 

contends that by promulgating higher CTG-recommended RACT limits for large appliance 
coatings, the EPA has established that the original CTG-recommended limits, and thus the 

existing Chapter 115 limits, are not technologically or economically feasible. However, the EPA’s 

CTG did not specifically explain why the lower limits included in the original CTG 

recommendations were no longer technologically or economically feasible. In absence of any 

specific information indicating that the TCEQ’s existing large appliance coating limits are no 

longer technologically or economically feasible, the adopted Chapter 115 rules only include the 

CTG-recommended limits that are equivalent to or lower than the existing limit.

3.3.5. Metal Furniture Coatings

Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115, 

Subchapter E, to create new Division 5 to implement the EPA's 2007 Metal Furniture Coatings 

CTG recommendations that the TCEQ has determined are RACT in the DFW area (Rule Project 

Number 2010-016-115-EN). The Chapter 115 rulemaking reduces VOC content limits of 

coatings, increases the overall control efficiency for add-on controls used in metal furniture 

coating operations, and establishes minimum transfer efficiency of coating application methods. 

The rules also require certain work practice procedures for coating-related activities and 

materials used during associated cleaning operations.

The EPA’s 2007 CTG recommends exempting metal furniture coating operations from the 

coating VOC content limits and work practice standards if total uncontrolled VOC emissions 

from coatings and associated cleaning solvents are less than 15 pounds per day. The current 

TCEQ rules provide an exemption from the coating VOC content limits for metal furniture 

coating operations if total uncontrolled VOC emissions from coatings in all applicable coating 

processes located on a property subject to Chapter 115, Subchapter E, Division 2 are less than 

3.0 pounds per hour and 15 pounds per day. The existing exemption from the required VOC 

controls may be more stringent for properties conducting multiple coating processes specified in 

Division 2 because the exemption is not based on VOC emissions from a single coating category. 

To prevent potential backsliding for properties already required to comply with the state’s 

regulations, the Chapter 115 rules retain the existing exemption criteria. 

The existing TCEQ metal furniture coating limits are based on the original CTG 

recommendations issued by the EPA in 1977. Several of the recommended VOC content limits 

for specific coating categories listed in the 2007 CTG document are less stringent than the limits 

specified in the EPA’s original CTG recommendations for this coating category. The 2007 CTG 

also recommends minimum solids transfer efficiency for coating application equipment. Despite 

the higher VOC content limits for the specialty coatings, the EPA’s 2007 CTG claims that 

implementing the limits as recommended would result in an overall emissions reduction and 

provides documentation containing the methodology used to estimate the reduction. The TCEQ 

also conducted a comprehensive comparison of the 2007 CTG recommendations to the existing 

VOC coating content limits and determined that implementing the 2007 CTG-recommended 

coating VOC content limits will not negatively impact the status of the state’s attainment with 

the 1997 eight-hour ozone NAAQS, will not interfere with control measures, and will not prevent 

reasonable further progress toward attainment of the ozone NAAQS. Despite the full 

demonstration of noninterference provided in the proposed rule preamble (Rule Project 

Number 2010-016-115-EN), the EPA commented that in order for the proposed rules to be 

approved as RACT, the state must also demonstrate that the existing Chapter 115 VOC content 

limits for metal furniture coatings, which were based on EPA’s original CTG recommendations, 

were no longer technologically or economically feasible. The commission contends that by 

promulgating higher CTG-recommended RACT limits for metal furniture coatings, the EPA has 

established that the original CTG-recommended limits, and thus the existing Chapter 115 limits, 

are not technologically or economically feasible. However, the EPA’s CTG did not specifically 
explain why the lower limits included in the original CTG recommendations were no longer 

technologically or economically feasible. In absence of any specific information indicating that 

the TCEQ’s existing metal furniture coating limits are no longer technologically or economically 

feasible, the adopted Chapter 115 rules only include the CTG-recommended limits that are 

equivalent to or lower than the existing limit.

3.3.6. Paper, Film, and Foil Coatings

Concurrent with this SIP revision, the TCEQ is adopting revisions to Chapter 115, Subchapter E, 

to create new Division 5 to implement the EPA's 2007 Paper, Film, and Foil Coatings CTG 

recommendations that the TCEQ has determined are RACT in the DFW area (Rule Project 

Number 2010-016-115-EN). The Chapter 115 rulemaking reduces the VOC content limits of 

coatings; increases the overall control efficiency for add-on controls used in paper, film, and foil 

coating operations; and establishes work practice procedures for materials used during cleaning 

operations associated with paper, film, and foil coating.

The EPA’s 2007 CTG recommends exempting all paper, film, and foil coating operations on a 

property from the coating VOC content limits and work practice standards if total uncontrolled 

VOC emissions from paper, film, and foil coatings and associated cleaning solvents are less than 

15 pounds per day. The current TCEQ rules provide an exemption from the coating VOC content 

limits for paper, film, and foil coating operations if total uncontrolled VOC emissions from all 

applicable surface coating processes on a property subject to Chapter 115, Subchapter E, 

Division 2 are less than 3.0 pounds per hour and 15 pounds per day. The existing exemption 

from the required VOC controls may be more stringent for properties conducting multiple 

coating processes specified in Division 2 because the exemption is not based on VOC emissions 

from a single coating category. To prevent potential backsliding for properties conducting paper, 

film, and foil coating operations already required to comply with the state’s regulations, the 

Chapter 115 rules retain the existing exemption criteria.

Additionally, the TCEQ is not implementing the EPA’s 2007 CTG recommendation to exempt a

paper, film, and foil coating line from complying with VOC coating content limits if the line has

the potential to emit less than 25 tpy of uncontrolled VOC emissions from coatings. As 

previously stated, the current Chapter 115 rules require combining the VOC emissions from all 

applicable surface coating processes located on a property subject to Subchapter E, Division 2 to 

determine exemption from the VOC coating content limits. Implementing the 2007 CTG 

recommendation may exempt paper, film, and foil coating lines co-located on a property with 

other coating lines subject to Division 2 that are currently complying the VOC coating content 

limits. To prevent backsliding, the Chapter 115 rules retain the existing VOC content limits for a 

paper, film, and foil coating line with VOC emissions below the 2007 CTG-recommended 

exemption threshold.

3.3.7. Miscellaneous Industrial Adhesives

Concurrent with this SIP revision, the TCEQ is adopting revisions to Chapter 115, Subchapter E, 

to create new Division 7: Miscellaneous Industrial Adhesives to implement the EPA's 2008 

Miscellaneous Industrial Adhesives CTG recommendations that the TCEQ has determined are

RACT in the DFW area (Rule Project Number 2010-016-115-EN). The Chapter 115 rulemaking 

implements VOC content limits for general adhesive application processes, specialty adhesive 

application processes, and adhesive primer application processes; provides exemptions for 

certain cleaning activities from all or portions of the rule; incorporates test methods and 

recordkeeping requirements; and establishes minimum transfer efficiency of adhesive 

application methods. The rules also require certain work practice procedures for adhesiverelated activities and materials used during associated cleaning operations. In response to 
comments, the commission is revising §115.470(a) to clarify the rules in Division 7 apply to 

manufacturing operations that use adhesives for any of the adhesive application processes 

specified in the control requirements in §115.473(a); adhesives applied in the field (e.g., 

adhesives applied at construction jobs in the field) are not subject to this division. The revised 

rule applicability in §115.470(a) more accurately reflects the sources affected by the CTG

recommendations as described by the EPA in the final rule for the 2008 Miscellaneous 

Industrial Adhesives CTG (73 FR 58489).

3.3.8. Miscellaneous Metal and Plastic Parts Coatings

Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115, 

Subchapter E, to create new Division 5 to implement the EPA's 2008 Miscellaneous Metal and 

Plastic Parts Coatings CTG recommendations that the TCEQ has determined are RACT in the 

DFW area (Rule Project Number 2010-016-115-EN). The miscellaneous plastic parts category of 

the CTG represents a new RACT CTG category for the DFW area, and the current coatings rules 

in Chapter 115, Subchapter E, Division 2 do not apply to miscellaneous plastic parts. The 

Chapter 115 rulemaking expands the scope of the existing rule applicability to include the new 

coating categories recommended in the 2008 CTG. The Chapter 115 rulemaking reduces VOC 

content limits of coatings, increases the overall control efficiency of add-on controls, and 

establishes minimum transfer efficiency of coating application methods. The rules also require 

certain work practice procedures for coating-related activities and materials used during 

associated cleaning operations.

The EPA’s 2008 CTG recommends exempting miscellaneous metal and plastic parts coating 

operations from the VOC control requirements if total uncontrolled VOC emissions from 

coatings and cleaning solvents are less than 15 pounds per day. The current TCEQ rules exempt 

miscellaneous metal parts and products coating operations from the required VOC coating 

limits if located on a property where total uncontrolled VOC emissions from all applicable 

surface coating processes subject to Chapter 115, Subchapter E, Division 2 are less than 3.0 

pounds per hour and 15 pounds per day. The existing exemption from the required controls may 

be more stringent for properties conducting multiple coating processes specified in Division 2 

because the exemption is not based on VOC emissions from a single coating category. To 

prevent potential backsliding for sources already subject to the Chapter 115 rules, the rule 

revisions integrate the new 2008 CTG coating categories into the existing exemption from the 

VOC control requirements. The Chapter 115 rules retain the state’s approach to maintain 

consistency with the current exemption criteria.

The miscellaneous metal part and product coating limits in Chapter 115, Subchapter E, Division 

2 are based on the original CTG recommendations issued by the EPA in 1978. Several of the 

recommended VOC content limits for specific coating categories listed in the 2008 CTG 

document are less stringent than the limits specified in the EPA’s original CTG 

recommendations for this coating category. The 2008 CTG also recommends minimum solids 

transfer efficiency for coating application equipment. Although the 2008 CTG does not quantify 

the estimated VOC emissions reduced as a result of implementing the recommended VOC 

content limits, the TCEQ applied an approach consistent with the methodology the EPA used to 

estimate VOC emission reductions associated with implementing the Large Appliance Coating 

and Metal Furniture Coating CTG recommendations. The TCEQ determined that implementing

the 2008 CTG-recommended coating VOC content limits will not negatively impact the status of 

the state’s attainment with the 1997 eight-hour ozone NAAQS, will not interfere with control 

measures, and will not prevent reasonable further progress toward attainment of the 1997 eighthour ozone NAAQS. Despite the full demonstration of noninterference provided in the proposed 

rule preamble (Rule Project Number 2010-016-115-EN), the EPA commented that in order for 
the proposed rules to be approved as RACT, the state must also demonstrate that the existing 

Chapter 115 VOC content limits for miscellaneous metal part and product coatings, which were 

based on EPA’s original CTG recommendations, were no longer technologically or economically 

feasible. The commission contends that by promulgating higher CTG-recommended RACT 

limits for miscellaneous metal part and product coatings, the EPA has established that the 

original CTG-recommended limits, and thus the existing Chapter 115 limits, are not 

technologically or economically feasible. However, the EPA’s CTG did not specifically explain 

why the lower limits included in the original CTG recommendations were no longer 

technologically or economically feasible. In absence of any specific information indicating that 

the TCEQ’s existing miscellaneous metal part and product coating limits are no longer 

technologically or economically feasible, the adopted Chapter 115 rules only include the CTGrecommended limits that are equivalent to or lower than the existing limits. In light of the 

technological and economic feasibility issues detailed in the EPA's 2008 CTG that are associated 

with high performance architectural coatings containing less than 6.2 pounds of VOC per gallon 

of coating (lb VOC/gal coating), the commission is adopting to retain the EPA’s 2008 CTGrecommended 6.2 lb VOC/gal coating limit for high performance architectural coatings in the 

adopted Chapter 115 miscellaneous metal parts and products rules.

In response to comments, the commission has revised §115.427 to limit the rule applicability to 

only those designated on-site maintenance shops that re-coat used parts or products that were 

required to comply with the rules in Division 2 prior to January 1,2012, which is the beginning 

of the calendar year shortly after the expected effective date of this rule revision. Additionally, in 

response to this comment, the commission has revised §115.450(a) to exclude designated on-site 

maintenance shops from the miscellaneous metal parts and products coatings rule applicability 

in Division 5. The adopted revisions prevent any potential backsliding concerns by requiring 

sources that are currently complying with these rules in Division 2 to continue to meet these 

VOC limits. The adopted revisions are consistent with the intent of EPA’s 1977 and 2008 CTG 

RACT recommendations for miscellaneous metal parts and products coatings and the 

commission maintains the rules continue to satisfy RACT requirements in FCAA, §172(c)(1) and 

§182(b)(2) for this CTG emission source category.

In response to comments, the commission added new §115.451(2)(D) to exempt all other coating 

categories regulated in Divisions 2 and 5 from the miscellaneous metal and plastic parts 

coatings rules. Incorporating this new exemption into §115.451 clarifies that the miscellaneous 

metal parts and products coatings rules do not apply to the coating operations characterized by 

another rule specified in Division 2 and Division 5.

Based on information provided during the public comment period, the commission determined 

that some of the pleasure craft coating VOC limits included in the EPA’s CTG recommendations 

are not technologically feasible at this time and therefore do not represent RACT. In response to 

comments, the commission is increasing the VOC limit for extreme high-gloss coatings to 5.0 

pounds of VOC per gallon of coating (lb VOC/gal coating) and revising the definition include any 

coating that achieves greater than 90% reflectance on a 60 degree meter. In response to 

comments, the commission is increasing the VOC limit for finish primer/surfacer coatings to 

5.0 lb VOC/gal coating. In response to comments, the commission is increasing the VOC limit 

for other substrate antifoulant coatings to 3.34 lb VOC/gal coating. In response to comments, 

the commission is introducing a new specialty coating category for antifoulant sealer/tie 

coatings, which are coatings applied over biocidal antifoulant coating for the purpose of 

preventing release of biocides into the environment, or to promote adhesion between an 

antifoulant and a primer or other antifoulants, and is establishing a VOC limit of 3.5 lb VOC/gal 

coating for this new category. In response to comments, the commission is revising the 
definition of pretreatment wash primer coatings to include any coating that contains no more 

than 25% solids, by weight, and at least 0.10% acids, by weight; is used to provide surface 

etching; and is applied directly to fiberglass and metal surface to provide corrosion resistance 

and adhesion of subsequent coatings.

3.3.9. Automobile and Light-Duty Truck Assembly Coatings

Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115, 

Subchapter E, to create new Division 5 to implement the EPA's 2008 Auto and Light-Duty Truck 

Assembly Coatings CTG recommendations that the TCEQ has determined are RACT in the DFW 

area (Rule Project Number 2010-016-115-EN). The Chapter 115 rulemaking reduces the VOC 

content limits of coatings and establishes work practice procedures for materials used during 

cleaning operations associated with automobile and light-duty truck assembly coating 

operations.

The EPA’s 2008 CTG recommends exempting automobile and light-duty truck assembly coating 

operations from the VOC control requirements if total uncontrolled VOC emissions from 

coatings and cleaning solvents are less than 15 pounds per day. The current TCEQ rules exempt 

automobile and light-duty truck assembly coating operations from the required VOC coating 

limits if located on a property where total uncontrolled VOC emissions from all applicable 

surface coating processes subject to Chapter 115, Subchapter E, Division 2 are less than 3.0 

pounds per hour and 15 pounds per day. The existing exemption from the required controls may 

be more stringent for properties conducting multiple coating processes specified in Division 2 

because the exemption is not based on VOC emissions from a single coating category. To 

prevent potential backsliding for properties already required to comply with the state’s 

regulations, the Chapter 115 rules retain the existing exemption criteria.

3.3.10. VOC Storage

Concurrent with this SIP revision, the commission is adopting rules in Chapter 115, Subchapter 

B, Division 1 to implement RACT for the storage of VOC (Rule Project Number 2010-025-115-

EN). The Chapter 115 rulemaking revises existing rules to include additional requirements for

low-leaking storage tank fittings and to limit situations when a floating roof storage tank is

allowed to emit VOC because the roof is not floating on the liquid. Although the revised 

requirements implement RACT for the petroleum liquid storage CTG emission source category,

these rules are more stringent than the EPA’s RACT recommendations for these sources (EPA 

Document Numbers EPA-450/2-77-036, EPA-450/2-78-047, and EPA-453/R-94-001). This

Chapter 115 rulemaking also requires 95% control of flash emissions from crude oil and 

condensate storage tanks with uncontrolled VOC emissions that equal or exceed 50 tpy. The 

commission is adopting this requirement to implement RACT for major stationary sources in 

serious nonattainment areas. The TCEQ has determined that these new and revised control 

requirements are technologically and economically feasible and therefore represent RACT for 

the storage of VOC.

Table F-1: State Rules Addressing NOX RACT Requirements in CTG and ACT 

Reference Documents

Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Cement Manufacturing NOX Emissions from Cement Manufacturing 

(EPA-453/R-94-004, March 1994, Updated 

September 2000)

§117.3100 – §117.3145

Glass Manufacturing NOX Emissions from Glass Manufacturing (EPA453/R-94-037, June 1994)§117.400 – §117.456

Industrial, Commercial, 

and Institutional Boilers 

NOX Emissions from Industrial, Commercial and 

Institutional Boilers (EPA-453/R-94-022, March 

1994)

§117.400 – §117.456

Iron and Steel NOX Emissions from Iron and Steel (EPA-453/R94-065, September 1994)§117.400 – §117.456

Nitric and Adipic Acid 

Manufacturing

NOX Emissions from Nitric and Adipic Acid 

Manufacturing Plants (EPA-453/3-91-026, 

December 1991)

No Nitric or Adipic Acid 

Manufacturing Plants 

in DFW.

Process Heaters NOX Emissions from Process Heaters (EPA-453/R93-034, revised September 1993)§117.400 – §117.456

Stationary Internal 

Combustion Engines

NOX Emissions from Stationary Internal 

Combustion Engines (EPA-453/R-93-032, July 

1993) (Updated September 2000)

§117.400 – §117.456

§117.2100 – §117.2145

Stationary Turbines NOX Emissions from Stationary Combustion 

Turbines (EPA-453/R-93-007, January 1993)

§117.400 – §117.456

Utility Boilers NOX Emissions from Utility Boilers (EPA-453/R94-023, March 1994)§117.1100 – §117.1156

Table F-2: State Rules Addressing VOC RACT Requirements in CTG and ACT 

Reference Documents

Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Aerospace Guideline Series: Control of Volatile Organic 

Compound Emissions from Coating Operations 

at Aerospace Manufacturing and Rework 

Operations (EPA-453/R-97-004, EPA-68/D1-

00115, EPA-453/D-96-016, December 1997) (see 

59 FR 29216, June 6, 1994)

§115.420 – §115.429
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Agricultural Pesticides Control of Volatile Organic Compound Emissions 

from the Application of Agricultural Pesticides 

(EPA-450/R-92-011, March 1993)

The TCEQ does not 

regulate the use of 

agricultural pesticides 

and this ACT document 

does not give 

presumptive controls; 

therefore, no RACT 

determination is 

required for this source 

category.

Architectural and 

Industrial Maintenance 

Coatings

Reduction of Volatile Organic Compound 

Emissions from Application of Traffic Markings 

(EPA-450/3-88-007, August 1988). The 

Architectural and Industrial Maintenance 

coatings national rule issued in 1998 includes 

limits for traffic coatings and superseded the 

ACT.

Emissions from this 

source category are 

regulated by the 

Architectural and 

Industrial Maintenance 

National Rule.

Automobile Coating The Reduction of Volatile Organic Compound 

Emissions from Automobile Refinishing (EPA450/3-88-009, October 1988, NTIS No PB-89-

148-282)

§115.420 – §115.429

Automobile Refinishing Alternative Control Techniques Document: 

Automobile Body Refinishing (EPA-453/R-94-

031, April 1994) (Note: a national rule for autobody refinishing was issued in 1998 after the 

ACT)

§115.420 – §115.429

Batch Processes Alternative Control Techniques Document: 

Control of Volatile Organic Compound Emissions 

from Batch Processes (EPA-453/R-93-017 or EPA453/R-93-020, February 1994)

No existing major 

sources in the DFW 

area (SIC 2821, 2833, 

2834, 2861, 2865, 

2869, and 2879).

Bulk Gasoline Plants Control of Volatile Organic Emissions from Bulk 

Gasoline Plants (EPA-450/2-77-035, December 

1977)

§115.211 – §115.219

Cleaning Solvents Alternative Control Techniques Document: 

Industrial Cleaning Solvents (EPA-453/R-94-015, 

February 1994)

§115.412 – §115.419

§115.420 – §115.429

Cleaning Solvents Control Techniques Guidelines for Industrial 

Cleaning Solvents (EPA-453/R-06-001, 

September 2006)

§115.460 - §115.469

See Section 3.3.3 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Commercial Bakeries Alternative Control Techniques Document: 

Bakery Ovens (EPA-453/R-92-017, December 

1992)

§115.120 – §115.129

Cutback Asphalt Control of Volatile Organic Compounds from Use 

of Cutback Asphalt (EPA-450/2-77-037, 

December 1977)

§115.510 – §115.519

Ethylene Oxide 

Sterilization/Fumigation 

Operations

Alternative Control Technology Document: 

Ethylene Oxide Sterilization/Fumigation 

Operations (EPA-450/3-89-007, March 1989)

Emissions from this 

source category are 

regulated by MACT per 

§113.200.

Fiberglass Boat 

Manufacturing Materials

Control Techniques Guidelines for Fiberglass 

Boat Manufacturing Materials (EPA 453/R-08-

004, September 2008)

No sources meeting 

the specific category 

description in the CTG.

Fugitive Emissions Fugitive Emission Sources of Organic Compounds 

– Additional Information on Emissions, Emission 

Reductions, and Costs (EPA-450/3-82-010, April 

1982)

§115.352 – §115.359

Gasoline Service Stations Design Criteria for Stage I Vapor Control Systems 

- Gasoline Service Stations (November 1975)

§115.221 – §115.229

Graphic Arts Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume VIII: Graphic 

Arts - Rotogravure and Flexography (EPA-450/2-

78-033, December 1978)

§115.430 – §115.439

Graphic Arts Control of Volatile Organic Compound Emissions 

from Offset Lithographic Printing (September 

1993)

§115.440 – §115.449

Graphic Arts Alternative Control Technology Document: 

Offset Lithographic Printing (EPA-453/R-94-054, 

June 1994)

§115.440 – §115.449

Graphic Arts Control Techniques Guidelines for Flexible 

Package Printing (EPA-453/R-06-003, September 

2006)

§115.430 - §115.439

See Section 3.3.2 of 

RACT Discussion and

Rule Project No. 2010-

016-115-EN.

Graphic Arts Control Techniques Guidelines for Offset 

Lithographic Printing and Letterpress Printing 

(EPA-453/R-06-002, September 2006)

§115.440 – §115.449
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Industrial Adhesives Control Techniques Guidelines for Miscellaneous 

Industrial Adhesives (EPA 453/R-08-005, 

September 2008)

§115.470 - §115.479

See Section 3.3.7 of 

RACT Discussion and

Rule Project No. 2010-

016-115-EN.

Industrial Wastewater Control Techniques for Industrial Wastewater 

(EPA-453/D-93-056, September 1992) (ACT: April 

1994, consists of cover memo with option tables 

and CTG)

§115.140 – §115.149

Ink and Paint 

Manufacturing

Alternative Control Technology Document: 

Control of Volatile Organic Compounds from Ink 

and Paint Manufacturing (EPA-453/3-92-013)

§115.120 – §115.129

Leather Tanning and 

Finishing Operations

Alternative Control Technology Document: 

Leather Tanning and Finishing Operations (EPA453/R-93-025)

No existing major 

sources in DFW area 

(SIC 3111).

Metal Furniture Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume III: Surface 

Coating of Metal Furniture (EPA-450/2-77-032, 

December 1977)

§115.420 – §115.429

Natural Gas/Gasoline 

Processing

Control of Volatile Organic Compound 

Equipment Leaks from Natural Gas/Gasoline 

Processing Plants (EPA-450/2-83-007, December 

1983)

§115.352 – §115.359

Petroleum Dry Cleaners Control of Volatile Organic Compound Emissions 

from Large Petroleum Dry Cleaners (EPA-450/3-

82-009, September 1982)

§115.552 – §115.559

Petroleum Liquid Storage Control of Volatile Organic Emissions from 

Storage of Petroleum Liquids in Fixed Roof Tanks 

(EPA-450/2-77-036, December 1977)

§115.110 – §115.119

See Section 3.3.10 of 

RACT Discussion and 

Rule Project No. 2010-

025-115-EN.

Petroleum Liquid Storage Control of Volatile Organic Emissions from 

Petroleum Liquid Storage in External Floating 

Roof Tanks (EPA-450/2-78-047, December 1978)

§115.110 – §115.119

See Section 3.3.10 of 

RACT Discussion and 

Rule Project No. 2010-

025-115-EN.

Petroleum Liquid Storage Alternative Control Techniques Document: 

Volatile Organic Liquid Storage in Floating and 

Fixed Roof Tanks (EPA-453/R-94-001, January 

1994)

§115.110 – §115.119

See Section 3.3.10 of 

RACT Discussion and 

Rule Project No. 2010-

025-115-EN.
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Plywood Veneer Dryers Control Techniques for Organic Emissions from 

Plywood Veneer Dryers (EPA-450/3-83-012, May 

1983)

No existing major 

sources in the DFW 

area (SIC 2435 and 

2436).

Process Vents Alternative Control Technology Document: 

Organic Waste Process Vents (EPA-450/3-91-

007, December 1990)

§115.120 – §115.129

Refineries Control of Refinery Vacuum Producing Systems, 

Wastewater Separators, and Process Unit 

Turnarounds (EPA-450/2-77-025, October 1977)

§115.120 – §115.129

§115.131 – §115.139

§115.311 – §115.319

Refineries Control of Volatile Organic Compound Leaks 

from Petroleum Refinery Equipment (EPA-450/2-

78-036, June 1978)

§115.352 – §115.359

Rubber Tires Control of Volatile Organic Emissions from 

Manufacture of Pneumatic Rubber Tires (EPA450/2-78-030, December 1978)

No existing major 

sources in DFW area 

(SIC 3011).

Shipbuilding and Ship 

Repair

Control Technique Guidelines for Shipbuilding 

and Ship Repair Operations (EPA-453/R-94-032, 

April 1994)

No existing major 

sources in the DFW 

area (SIC 3731).

Shipbuilding and Ship 

Repair

Control Technique Guidelines for Shipbuilding 

and Ship Repair Surface Coating Operations (61 

FR 44050, August 27, 1996)

No existing major 

sources in the DFW 

area (SIC 3731).

Solvent Cleaning Control of Volatile Organic Emissions from 

Solvent Metal Cleaning (EPA-450/2-77-022, 

November 1977)

§115.412 – §115.419

§115.420 – §115.429

Solvent Cleaning Alternative Control Technology Document: 

Halogenated Solvent Cleaners (EPA-450/3-89-

030, August 1989)

§115.412 – §115.419

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume I: Control 

Methods for Surface Coating Operations (EPA450/2-76-028, November 1976)

§115.420 – §115.429

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume II: Surface 

Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks (EPA-450/2-

77-008, May 1977)

§115.420 – §115.429

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume IV: Surface 

Coating for Insulation of Magnet Wire (EPA450/2-77-033, December 1977)

§115.420 – §115.429
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume V: Surface 

Coating of Large Appliances (EPA-450/2-77-034, 

December 1977)

§115.420 – §115.429

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume VI: Surface 

Coating of Miscellaneous Metal Parts and 

Products (EPA-450/2-78-015, June 1978)

§115.420 – §115.429

Surface Coating Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume VII: Factory 

Surface Coating of Flat Wood Paneling (EPA450/2-78-032, June 1978)

§115.420 – §115.429

Surface Coating Alternative Control Techniques Document: 

Surface Coating of Automotive/Transportation 

and Business Machine Plastic Parts (EPA-453/R94-017, February 1994)

§115.420 – §115.429

Surface Coating Control Techniques Guidelines for Flat Wood 

Paneling Coatings (EPA-453/R-06-004, 

September 2006)

No sources meeting 

the specific category of 

the CTG.

Surface Coating Control Techniques Guidelines for Paper, Film, 

and Foil Coatings (EPA 453/R-07-003, September 

2007)

§115.450 - §115.459

See Section 3.3.6 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN.

Surface Coating Control Techniques Guidelines for Large 

Appliance Coatings (EPA 453/R-07-004, 

September 2007)

§115.450 - §115.459

See Section 3.3.4 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN.

Surface Coating Control Techniques Guidelines for Metal 

Furniture Coatings (EPA 453/R-07-005, 

September 2007)

§115.450 - §115.459

See Section 3.3.5 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN.

Surface Coating Control Techniques Guidelines for Miscellaneous 

Metal and Plastic Parts Coatings (EPA 453/R-08-

003, September 2008)

§115.450 - §115.459

See Section 3.3.8 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN.

Surface Coating Control Techniques Guidelines for Automobile 

and Light-Duty Truck Assembly Coatings (EPA 

453/R-08-006, September 2008)

§115.450 - §115.459

See Section 3.3.9 of 

RACT Discussion and 

Rule Project No. 2010-

016-115-EN.
Emission Source 

Category CTG or ACT Reference Document

State Regulations 

Fulfilling RACT 

Requirements

Synthetic Organic 

Chemical Manufacturing 

Industry

Control of Volatile Organic Emissions from 

Manufacture of Synthesized Pharmaceutical 

Products (EPA-450/2-78-029, December 1978)

§115.531 – §115.539

Synthetic Organic 

Chemical Manufacturing 

Industry

Control of Volatile Organic Compound Emissions 

from Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins (EPA450/3-83-008, November 1983)

§115.120 – §115.129

Synthetic Organic 

Chemical Manufacturing 

Industry

Control of Volatile Organic Compound Fugitive 

Emissions from Synthetic Organic Chemical 

Polymer and Resin Manufacturing Equipment 

(EPA-450/3-83-006, March 1984)

§115.352 – §115.359

Synthetic Organic 

Chemical Manufacturing 

Industry

Control of Volatile Organic Compound Emissions 

from Air Oxidation Processes in Synthetic 

Organic Chemical Manufacturing Industry (EPA450/3-84-015, December 1984)

§115.120 – §115.129

Synthetic Organic 

Chemical Manufacturing 

Industry

Polystyrene Foam Manufacturing (EPA-450/3-90-

020, 1990)

§115.120 – §115.129

Synthetic Organic 

Chemical Manufacturing 

Industry

Control of Volatile Organic Compound Emissions 

from Reactor Processes and Distillation 

Operations in Synthetic Organic Chemical 

Manufacturing Industry (EPA-450/4-91-031, 

August 1993)

§115.120 – §115.129

Tank Trucks Control of Hydrocarbons from Tank Truck 

Gasoline Loading Terminals (EPA-450/2-77-026, 

December 1977)

§115.211 – §115.219

§115.221 – §115.229

Tank Trucks Control of Volatile Organic Compound Leaks 

from Gasoline Tank Trucks and Vapor Collection 

Systems (EPA-450/2-78-051, December 1978)

§115.211 – §115.219

§115.234 – §115.239

Vegetable Oil 

Manufacturing

Control of Volatile Organic Emissions from 

Manufacture of Vegetable Oils (EPA-450/2-78-

035, June 1978)

No existing major 

sources in DFW area 

(SIC 2046 and 2076).

Wood Furniture 

Manufacturing

Guideline Series: Control of Volatile Organic 

Compound Emissions from Wood Furniture 

Manufacturing Operations (EPA-453/D-95/002)

§115.420 – §115.429

Wood Furniture 

Manufacturing

Guidelines Series: Control of Volatile Organic 

Compound Emissions from Wood Furniture 

Manufacturing Operations (EPA-453/R-96-007, 

April 1996) (see also 61 FR 25223, and, 61 FR 

50823, September 27, 1996)

§115.420 – §115.429
Table F-3: State Rules Addressing NOX RACT Requirements for Major Emission Sources in the DFW Area

RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100219286 ED0099J Holcim Texas LP 3241 Cement, Hydraulic 3184.3 §117.3100 -

§117.3145

Yes

RN100217199 ED0066B TXI Operations LP 3241 Cement, Hydraulic 2877.1 §117.3100 -

§117.3145

Yes

RN100225978 ED0034O Ash Grove Texas 

LP

3241 Cement, Hydraulic 1385.3 §117.3100 -

§117.3145

Yes

RN100213420 KB0176S FPLE Forney LP 4911 Electric Services 1148.4 §117.1300 -

§117.1356

No

RN100210889 JH0045I Texas Lime 

Company

3274 Lime 1075.3 §117.400 -

§117.456

Yes

RN100216472 ED0011D Chaparral Steel 

Midlothian LP

3312 Blast Furnaces and 

Steel Mills

437.9 §117.400 -

§117.456

Yes

RN100223585 ED0051O Owens-Corning 3296 Mineral Wool 364.6 §117.400 -

§117.456

Yes

RN100585918 ED0044L Saint Gobain 

Containers LLC

3221 Glass Containers 294.7 §117.400 -

§117.456

Yes

RN102596400 ED0332D Midlothian 

Energy LP

4911 Electric Services 258.5 §117.1300 -

§117.1356

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN101559854 DB0251U Luminant 

Generation Co 

LLC

4911 Electric Services 206.5 §117.1300 -

§117.1356

Yes

RN100673490 DB0249H Luminant 

Generation Co 

LLC

4911 Electric Services 199.1 §117.1300 -

§117.1356

Yes

RN100223312 JH0230L Brazos Electric 

Power 

Cooperative Inc.

4911 Electric Services 177.7 §117.1300 -

§117.1356

Yes

RN100212430 ED0347N Ennis Tractebel 

Power Company 

LP

4911 Electric Services 155.5 §117.1300 -

§117.1356

No

RN100242510 PC0300O Acacia Natural 

Gas Corp.

1311 Crude Petroleum 

and Natural Gas

142.1 §117.400 -

§117.456

No

RN100216225 DF0558Q Texas Aero 

Engine Service 

LLC

4581 Airports, Flying 

Fields, Service

123.3 NA Engine testing, aircraft. 

Additional control of NOX

emissions not technologically 

feasible. FCAA prohibition 

regarding jet engine test cells. 

Yes

RN100216399 TA4004G Tyson Foods Inc. 2099 Food Preparations 

NEC

114.1 §117.400 -

§117.456

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100542588 ED0238T Atmos Energy 

Corporation MidTex Division

4922 Natural Gas 

Transmission

107.0 §117.400 -

§117.456

No

RN104377692 JHA004D Energy Transfer 

Fuel LP

4922 Natural Gas 

Transmission

93.0 §117.400 -

§117.456

No

RN100213719 JH0025O Johns Manville 

Corporation

3296 Mineral Wool 91.1 §117.400 -

§117.456

Yes

RN105010714 TAA021U Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

86.3 §117.400 -

§117.456

No

RN100218080 DB1073N American 

Marazzi Tile, Inc.

3253 Ceramic Wall and 

Floor Tile

81.6 §117.400 -

§117.456

Yes

RN105171029 JHA024X Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

80.2 §117.400 -

§117.456

No

RN104283635 JHA001A Chesapeake 

Energy Marketing 

Inc.

1311 Crude Petroleum 

and Natural Gas

79.2 §117.400 -

§117.456

No

RN102903432 EDA001A Energy Transfer 

Fuel LP

4922 Natural Gas 

Transmission

78.8 §117.400 -

§117.456

No

RN104891825 PCA006F Crosstex ccng 

Processing Ltd.

4922 Natural Gas 

Transmission

78.6 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104763370 JHA014N Crosstex North 

Texas Gathering 

LP

1311 Crude Petroleum 

and Natural Gas

77.7 §117.400 -

§117.456

No

RN100213479 ED0018M Elk Corporation 

of Texas

2952 Asphalt Felts and 

Coatings

75.9 §117.400 -

§117.456

No

RN105068001 JHA020T Peregrine 

Pipeline Co. LP

1311 Crude Petroleum 

and Natural Gas

74.6 §117.400 -

§117.456 

No

RN104488358 DFA087I Crosstex North 

Texas Gathering 

LP

1311 Crude Petroleum 

and Natural Gas

73.7 §117.400 -

§117.456

No

RN102505195 DB0820B Texas 

Instruments Inc.

3674 Semiconductors 

and Related 

Devices

72.0 §117.400 -

§117.456

Yes

RN104962634 JHA028B Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

71.9 §117.400 -

§117.456

No

RN104787478 TAA014N Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

70.4 §117.400 -

§117.456

No

RN104260096 JHA003C Chesapeake 

Energy Marketing 

Inc.

1311 Crude Petroleum 

and Natural Gas

69.9 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100685213 DB3357F Tyson Foods Inc. 2013 Sausages and 

Other Prepared 

Meat

64.5 §117.400 -

§117.456

Yes

RN104927876 JHA018R Devon Gas 

Services LP

1311 Crude Petroleum 

and Natural Gas

64.1 §117.400 -

§117.456

No

RN100218569 DB4707Q Mccommas LFG 

Processing 

Partners LP

4925 Gas Production 

and Distribution

63.5 §117.400 -

§117.456

No

RN100219963 DB1494I Solar Turbines, 

Inc.

3511 Turbines and 

Turbine Generator

63.1 NA Engine testing, turbine. 

Additional control of NOX

emissions not technologically 

feasible.

No

RN105010797 PCA008H Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

60.7 §117.400 -

§117.456

No

RN105132609 JHA022V Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

60.7 §117.400 -

§117.456

No

RN104475157 TAA013M Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

60.0 §117.400 -

§117.456

No

RN104370259 JHA023W Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

59.6 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100689934 DB0447B Hensley 

Industries, Inc.

3325 Steel Foundries, 

NEC

57.4 §117.400 -

§117.456

No

RN102939626 TAA008H Crosstex North 

Texas Gathering 

LP

1311 Crude Petroleum 

and Natural Gas

56.5 §117.400 -

§117.456

No

RN100225291 DB0632E Owens Corning 2952 Asphalt Felts and 

Coatings

54.8 §117.400 -

§117.456

No

RN100218643 CP0029G Exide 

Corporation

3341 Secondary 

Nonferrous Metals

53.0 §117.400 -

§117.456

Yes

RN105225692 TAA020T Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

48.9 §117.400 -

§117.456

No

RN100542257 DF0223E DFW Recycling 

and Disposal 

Facility

4953 Refuse Systems 48.6 §117.400 -

§117.456

No

RN105247126 JHA029C EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

48.6 §117.400 -

§117.456

No

RN100215581 DB0476R Atlas Copco 

Drilling Solutions 

Inc.

3531 Construction 

Machinery

48.0 §117.400 -

§117.456

No

RN102505963 TA0157I General Motors 

Corporation

3711 Motor Vehicles 

and Car Bodies

47.2 §117.400 -

§117.456

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN105137475 JHA034H EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

45.4 §117.400 -

§117.456

No

RN104995089 JHA032F EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

44.1 §117.400 -

§117.456

No

RN100226414 PC0013U Enbridge 

Gathering North 

Texas LP

1321 Natural Gas 

Liquids

43.2 §117.400 -

§117.456

Yes

RN100542232 ED0240J Waste 

Management of 

Texas, Inc.

4953 Refuse Systems 42.9 §117.400 -

§117.456

No

RN104700711 PCA010J Energy Transfer 

Fuel LP

1311 Crude Petroleum 

and Natural Gas

40.8 §117.400 -

§117.456

No

RN105302186 JHA036J EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

40.8 §117.400 -

§117.456

No

RN105302152 JHA035I EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

40.6 §117.400 -

§117.456

No

RN104023353 JHA010J Devon Gas 

Services LP

1311 Crude Petroleum 

and Natural Gas

40.5 §117.400 -

§117.456

No

RN104776661 TAA016P Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

40.1 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100219203 CP0026M City of Garland 4911 Electric Services 38.4 §117.1300 -

§117.1356

Yes

RN104948005 JHA016P EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

36.9 §117.400 -

§117.456

No

RN100942259 TA0512K Village Creek 

Wastewater 

Treatment

4952 Sewerage Systems 34.9 §117.400 -

§117.456

Yes

RN105011290 JHA017Q EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

34.9 §117.400 -

§117.456

No

RN105225924 TAA018R Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

34.8 §117.400 -

§117.456

No

RN101559235 DB0252S Extex Laporte LP 4911 Electric Services 34.3 §117.1300 -

§117.1356

Yes

RN104311741 JHA026Z Etc Texas Pipeline 

Ltd.

1311 Crude Petroleum 

and Natural Gas

33.9 §117.400 -

§117.456

No

RN100754779 KB0156B Corrugated 

Services, LP

2631 Paperboard Mills 33.4 §117.400 -

§117.456

No

RN100213537 ED0168P Dartco of Texas 

LP

3089 Plastics Products, 

NEC

33.3 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104920160 TAA017Q Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

33.0 §117.400 -

§117.456

No

RN105337554 DFA151U Williams Barnett 

Gathering 

Systems LP

1311 Crude Petroleum 

and Natural Gas

32.2 §117.400 -

§117.456

No

RN105354062 DFA173Q Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

31.8 §117.400 -

§117.456

No

RN104890355 JHA030D Williams Barnett 

Gathering 

Systems LP

1311 Crude Petroleum 

and Natural Gas

31.3 §117.400 -

§117.456

No

RN105093512 PCA007G Enbridge G&P 

North Texas LP

1321 Natural Gas 

Liquids

30.9 §117.400 -

§117.456

No

RN100218007 TA0009B Alcon 

Laboratories Inc.

2834 Pharmaceutical 

Preparations

30.5 §117.400 -

§117.456

No

RN102336906 TA0353G Extex Laporte LP 4911 Electric Services 30.0 §117.1300 -

§117.1356

Yes

RN104807680 JHA005E EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

28.9 §117.400 -

§117.456

No

RN104807755 JHA006F EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

28.7 §117.400 -

§117.456

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104457114 JHA007G EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

28.2 §117.400 -

§117.456

No

RN104488416 DFA086H Crow Creek 

Energy II LLC

1311 Crude Petroleum 

and Natural Gas

27.4 §117.400 -

§117.456

No

RN105234728 TAA025Y Texas Midstream 

Gas Services LLC

1311 Crude Petroleum 

and Natural Gas

26.8 §117.400 -

§117.456

No

RN105011092 PCA005E Empire Pipeline 

Corp.

4922 Natural Gas 

Transmission

26.6 §117.400 -

§117.456

No

RN105227763 TAA024X Cowtown 

Pipeline LP

1311 Crude Petroleum 

and Natural Gas

26.2 §117.400 -

§117.456

No

RN104876263 PCA009I Energy Transfer 

Fuel LP

4922 Natural Gas 

Transmission

25.7 §117.400 -

§117.456

No

RN105224224 JHA041O Williams Barnett 

Gathering 

Systems LP

1311 Crude Petroleum 

and Natural Gas

25.7 §117.400 -

§117.456

No

RN105171649 JHA031E EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

25.6 §117.400 -

§117.456 

No

RN100693308 TA0352I Luminant

Generation 

Company LLC

4911 Electric Services -- §117.1300 -

§117.1356

No reported emissions for 2008 Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100754779 KB1056B Orange County 

Container Group 

LLC

2631 Paperboard Mills -- §117.400 -

§117.456

No reported emissions for 2008 No

RN100784735 CP0065C Luminant 

Generation 

Company LLC

4911 Electric Services -- §117.1300 -

§117.1356

No reported emissions for 2008 Yes

RN105304521 Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

-- §117.400 -

§117.456

No reported emissions for 2008 No
Table F-4: State Rules Addressing VOC RACT Requirements for Major Emission Sources in the DFW Area

RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100213537 ED0168P Dartco of Texas 

LP

3089 Plastics Products, 

NEC

865.1 §115.110 -

§115.119

§115.211 -

§115.219

VOC emissions from storage, 

loading, and unloading addressed 

through Chapter 115 rules. Other 

VOC emissions are controlled per 

BACT in NSR Permit No. 18505. 90% 

of VOC emissions are building 

fugitives. Additional control for 

RACT is not economically feasible.

Yes

RN100219286 ED0099J Holcim Texas LP 3241 Cement, 

Hydraulic

582.0 NA Additional control for RACT is not 

economically feasible.

Yes

RN102505963 TA0157I General Motors 

Corporation

3711 Motor Vehicles 

and Car Bodies

381.8 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.9 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

Yes

RN100216472 ED0011D Chaparral Steel 

Midlothian LP

3312 Blast Furnaces 

and Steel Mills

320.9 §115.211 -

§115.219

VOC emissions from other 

operations are controlled per BACT 

in NSR Permit Nos. 1635, 3026, 

5983, 8097, and 8099. Further 

control may also be required by 

MACT. Additional control for RACT 

is not economically feasible.

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100211762 DF0051J Peterbilt Motors 

Company

3711 Motor Vehicles 

and Car Bodies

184.3 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

Yes

RN105171649 JHA031E EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

135.9 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN102649399 TA0235N Miller Brewing 

Company

2082 Malt Beverages 131.6 §115.120 -

§115.129

§115.211 -

§115.219

Vent gas streams meet applicable 

exemptions in §115.127. 75% of 

VOC emissions are fugitive 

emissions from product loss. 

Additional control for RACT is not 

technologically or economically 

feasible.

Yes

RN105132609 JHA022V Texas 

Midstream Gas 

Services LLC

1311 Crude Petroleum 

and Natural Gas

97.9 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100212885 DB0802D Quebecor World 

Dallas

2754 Commercial 

Printing, Gravure

94.4 §115.430 -

§115.439

§115.440 -

§115.449

Publication printing. Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100223585 ED0051O Owens-Corning 3296 Mineral Wool 89.2 §113.710

and 

§113.930

VOC controls from organic HAP

MACT controls in 40 CFR 63 

Subparts NNN and JJJJ, 

incorporated via §113.710 and 

§113.930. Additional control for 

RACT is not economically feasible.

Yes

RN100213719 JH0025O Johns Manville 

Corporation

3296 Mineral Wool 88.5 §113.710 

and 

§113.930

§115.120 -

§115.129

§115.420 -

§115.429

VOC controls from organic HAP 

MACT controls in 40 CFR 63 

Subparts NNN and JJJJ, 

incorporated via §113.710 and 

§113.930.

Vent gas streams meet applicable 

exemptions in §115.127. VOC 

emissions meet exemption in 

§115.427. Additional control for 

RACT is not economically feasible.

Yes

RN104380811 JHA015O American Film 

and Printing Ltd

2759 Commercial 

Printing, NEC

86.1 §115.430 -

§115.439

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

No

RN104459078 JHA008H EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

81.8 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100689934 DB0447B Hensley 

Industries, Inc.

3325 Steel Foundries, 

NEC

79.3 §115.120 -

§115.129

§115.420 -

§115.429

§115.450 -

§115.459

Vent gas streams meet applicable 

exemptions in §115.127.

See Section 3.3.8 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

Yes

RN100218783 KB0015U Oldcastle 

Windows Inc. 

dba Vistawall

3354 Aluminum 

Extruded 

Products

73.6 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.8 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

Yes

RN100217199 ED0066B TXI Operations 

LP

3241 Cement, 

Hydraulic

71.6 NA Additional control for RACT is not 

economically feasible.

No

RN100225804 TA0499A Trinity Industries 

Inc.

3743 Railroad 

Equipment

69.4 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.8 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN102505195 DB0820B Texas 

Instruments Inc.

3674 Semiconductors 

and Related 

Devices

67.6 §115.110 -

§115.119

§115.120 -

§115.129

§115.211 -

§115.219

No

RN100218023 DB0374D Fritz Industries 

Inc.

3272 Concrete 

Products, NEC

66.8 §115.120 -

§115.129

No

RN102418563 TA0285V Trinity Industries 

Inc.

4789 Transportation 

Services, NEC

64.4 §115.412 -

§115.419

§115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.8 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

No

RN104962634 JHA028B Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

57.8 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines with 

lean burn technology. Additional 

VOC control not technologically or 

economically feasible.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN105010714 TAA021U Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

57.0 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines with 

lean burn technology. Additional 

VOC control not technologically or 

economically feasible.

No

RN104377692 JHA004D Energy Transfer 

Fuel LP

4922 Natural Gas 

Transmission

55.6 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN100218643 CP0029G Exide 

Corporation

3341 Secondary 

Nonferrous 

Metals

53.7 §115.120 -

§115.129

Vent gas streams meet applicable 

exemptions in §115.127. VOC 

emissions are controlled per BACT 

in NSR Permit No. 1147A. 

Additional control for RACT is not 

economically feasible

Yes

RN100218320 DB0914O Vought Aircraft 

Industries Inc.

3721 Aircraft 53.0 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3.8 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104787478 TAA014N Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

52.0 NA VOC emissions mostly from 

stationary internal combustion

engines with lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN102593894 DB0838F Texwood 

Industries, LP

2434 Wood Kitchen 

Cabinets

50.8 §115.420 -

§115.429

Yes

RN100221779 TA0142V Citgo Petroleum 

Corp.

5171 Petroleum Bulk 

Stations and 

Terminals

48.0 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100213479 ED0018M Elk Corporation 

of Texas

2952 Asphalt Felts and 

Coatings

47.7 NA VOC emissions are controlled per 

BACT in NSR Permits. Additional 

control for RACT is not 

economically feasible.

Yes

RN105775779 DFA172P Burlington 

Resources Oil 

and Gas Co. LP

1311 Crude Petroleum 

and Natural Gas

47.5 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100519651 DB0795V Motiva 

Enterprises, LLC

5171 Petroleum Bulk 

Stations and 

Terminals

47.2 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104700711 PCA010J Energy Transfer 

Fuel LP

1311 Crude Petroleum 

and Natural Gas

46.7 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100542257 DF0223E DFW Recycling 

and Disposal 

Facility

4953 Refuse Systems 44.4 §115.152 -

§115.159

No

RN102903432 EDA001A Energy Transfer 

Fuel LP

4922 Natural Gas 

Transmission

42.5 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN100242015 DB0588F Magellan 

Terminals 

Holdings LP

4226 Special 

Warehousing and 

Storage

42.3 §115.112 –

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN105068001 JHA020T Peregrine 

Pipeline Co. LP

1311 Crude Petroleum 

and Natural Gas

41.1 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN105010797 PCA008H Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

40.7 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN100222231 DF0261T American 

Airlines Inc.

4581 Airports, Flying 

Fields, Service

40.5 §115.131 -

§115.139

§115.412 -

§115.419

§115.420 -

§115.429

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100219419 CP0396W Encore Wire 

Limited

3351 Copper Rolling 

and Drawing

40.4 §115.110 -

§115.119

§115.120 -

§115.129

§115.412 -

§115.419

§115.420 -

§115.429

Vent gas streams meet applicable 

exemptions in §115.127. VOC 

emissions meet exemption in 

§115.427.

No

RN102572682 TA0685B Film Pak Inc. 3089 Plastics Products, 

NEC

39.5 §115.430 -

§115.439

See Section 3.3.2 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

No

RN102096377 TA0175G Chevron USA 

Inc.

5171 Petroleum Bulk 

Stations and 

Terminals

38.4 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100664853 DB0155R Tamko Roofing 

Products, Inc.

2952 Asphalt Felts and 

Coatings

37.4 §115.120 -

§115.129

No

RN100225440 TA0236L Ball Metal 

Beverage 

Container Corp.

3411 Metal Cans 37.4 §115.420 -

§115.429

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN105590228 DFA157A Burlington 

Resources Oil 

and Gas Co. LP

1311 Crude Petroleum 

and Natural Gas

37.0 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN102595816 DB1690G Dallas 

Semiconductor

3674 Semiconductors 

and Related 

Devices

36.0 §115.120 -

§115.129

No

RN102560067 TA0508B Nustar Logistics 

LP

5171 Petroleum Bulk 

Stations and 

Terminals

35.7 §115.110 -

§115.119

§115.131 -

§115.139

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN102939626 TAA008H Crosstex North 

Texas Gathering 

LP

1311 Crude Petroleum 

and Natural Gas

34.8 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100211291 TA0282E Printpack 

Incorporated

2671 Paper Coated 

and Laminated 

Pkg.

34.4 §115.412 -

§115.419

§115.420 -

§115.429

§115.430 -

§115.439

§115.450 -

§115.459

See Section 3.3 of RACT Discussion 

and Rule Project No. 2010-016-115-

EN.

No

RN101649317 TA0102K ConocoPhillips 

Co.

5171 Petroleum Bulk 

Stations and 

Terminals

33.5 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

Yes

RN100212984 DB0344M ExxonMobil 

Corp.

5171 Petroleum Bulk 

Stations and 

Terminals

33.4 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104891825 PCA006F Crosstex Ccng 

Processing Ltd

4922 Natural Gas 

Transmission

33.2 §115.352 -

§115.359

Natural gas processing facility 

fugitive emissions addressed 

through §115.352 - §115.359. VOC 

emissions from stationary internal 

combustion engines – engines 

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN102615747 DF0089H Tetra Pak 

Materials LP

2752 Commercial 

Printing

Lithograph

32.9 §115.440 -

§115.449

No

RN100242510 PC0300O Acacia Natural 

Gas Corp.

1311 Crude Petroleum 

and Natural Gas

32.8 §115.110 -

§115.119

Condensate Tanks - See Section 

3.3.10 of RACT Discussion and Rule 

Project No. 2010-025-115-EN.

Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN104475157 TAA013M Barnett 

Gathering LP

1311 Crude Petroleum 

and Natural Gas

32.8 NA Compressor station - VOC 

emissions mostly from stationary 

internal combustion engines

already equipped with oxidative 

catalyst or lean burn technology. 

Additional VOC control not 

technologically or economically 

feasible.

No

RN100218197 DB0728N The Sherwin 

Williams 

Company

2851 Paints and Allied 

Products

32.7 §115.110 -

§115.119

§115.120 -

§115.129

No

RN104807680 JHA005E EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

32.4 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100746007 DB4914J Trend Offset 

Printing Services 

Inc.

2752 Commercial 

Printing 

Lithograph

31.4 §115.440 -

§115.449

No

RN100223312 JH0230L Brazos Electric 

Power 

Cooperative Inc.

4911 Electric Services 31.4 NA VOC emissions arise from natural 

gas combustion. Additional control 

for RACT is not economically 

feasible.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN102496684 TA1222P Flint Hills 

Resources LP

5171 Petroleum Bulk 

Stations and 

Terminals

31.2 §115.110 -

§115.119

§115.211 -

§115.219

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100226414 PC0013U Enbridge 

Gathering North 

Texas LP

1321 Natural Gas 

Liquids

30.8 §115.110 -

§115.119

§115.211 -

§115.219

§115.352 -

§115.359

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

Yes

RN100219344 TA0172M Fort Dearborn 

Co.

2752 Commercial 

Printing 

Lithograph

30.3 §115.440 -

§115.449

No

RN100747435 TA4073K Pro Line Printing 

Inc.

2752 Commercial 

Printing 

Lithograph

30.3 §115.440 -

§115.449

No

RN101964849 DB2035O Surepak LP 3086 Plastics, Foam 

Products

29.8 §115.120 -

§115.129

No

RN104025556 DBA003C Western 

Cabinets Inc.

2434 Wood Kitchen 

Cabinets

29.6 §115.420 -

§115.429

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100215995 DB0286B Valspar Coatings 2851 Paints and Allied 

Products

29.4 §115.110 -

§115.119

§115.120 -

§115.129

No

RN100225291 DB0632E Owens Corning 2952 Asphalt Felts and 

Coatings

29.2 §115.120 -

§115.129

§115.211 -

§115.219

§115.412 -

§115.419

No

RN102566890 TA0106C Styrochem US 

Ltd

2821 Plastics Materials 

and Synthetic 

Resins

29.0 §115.120 -

§115.129

§115.352 -

§115.359

No

RN100773381 JH0376F Technical 

Chemical Co

2899 Chemical 

Preparations, 

NEC

28.5 NA VOC emissions are controlled per 

BACT in NSR permit. Additional 

control for RACT is not 

economically feasible.

No

RN100673490 DB0249H Luminant 

Generation Co 

LLC

4911 Electric Services 28.4 NA VOC emissions arise from natural 

gas combustion. Additional control 

for RACT is not economically 

feasible.

Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100215508 DB1276U Tekni-Plex, Inc. 5169 Chemicals and 

Allied Products 

NEC

28.0 §115.412 -

§115.419

§115.430 -

§115.439

No

RN102338027 DB2321K Tube Forming 

Inc.

3463 Nonferrous 

Forgings

28.0 §115.412 -

§115.419

No

RN100225184 PC0001E Acme Brick Co. 3251 Brick and 

Structural Clay 

Tile

28.0 NA VOC emissions are controlled per 

BACT in NSR permit. Additional 

control for RACT is not 

economically feasible.

Yes

RN102302007 DB3613K Western 

Cabinets Inc.

2434 Wood Kitchen 

Cabinets

27.8 §115.420 -

§115.429

No

RN103184545 TAA004D Marco Display 

Specialists Gp LC

2449 Wood 

Containers, NEC

27.4 §115.420 -

§115.429

No

RN104808472 PCA018R Etc Texas 

Pipeline Ltd.

1311 Crude Petroleum 

and Natural Gas

27.3 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN100212356 TA0156K Lockheed Martin 

Aeronautics 

Company

3721 Aircraft 27.3 §115.412 -

§115.419

§115.420 -

§115.429

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100220417 TA2193N Bimbo Bakeries 

USA Inc.

2051 Bread, Cake and 

Related Products

27.3 §115.120 -

§115.129

No

RN100215581 DB0476R Atlas Copco 

Drilling Solutions 

Inc.

3531 Construction 

Machinery

27.1 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3 of RACT Discussion 

and Rule Project No. 2010-016-115-

EN.

No

RN102324142 KB0073G Madix Inc. 2542 Partition and 

Fixtures Except 

Wood

26.7 §115.420 -

§115.429

§115.450 -

§115.459

See Section 3.3 of RACT Discussion 

and Rule Project No. 2010-016-115-

EN.

Yes

RN100559988 DB0969M Rmax Inc. 3086 Plastics, Foam 

Products

26.4 NA VOC emissions are controlled per 

BACT in NSR permit. Additional 

control for RACT is not 

economically feasible.

No

RN100210210 DB1182H Texwood 

Industries, Inc.

2434 Wood Kitchen 

Cabinets

26.0 §115.420 -

§115.429

No

RN104927876 JHA018R Devon Gas 

Services LP

1311 Crude Petroleum 

and Natural Gas

26.0 NA VOC emissions mostly from 

stationary internal combustion

engines already equipped with 

oxidative catalyst or lean burn 

technology. Additional VOC control 

not technologically or economically 

feasible.

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN102764792 PC0003A Antelope Oil 

Tool and Mfg. 

Co.

3499 Fabricated Metal 

Products, NEC

25.9 §115.420 -

§115.429

§115.450 -

§115.459

Metal furniture coating

See Section 3.3.5 of RACT 

Discussion and Rule Project No. 

2010-016-115-EN.

No

RN102216819 TA0051C Bell Helicopter 

Textron Inc.

3721 Aircraft 25.7 §115.110 -

§115.119

§115.120 -

§115.129

§115.412 -

§115.419

§115.420 -

§115.429

No

RN105592026 DFA113I Burlington 

Resources Oil 

and Gas Co LP

1311 Crude Petroleum 

and Natural Gas

25.6 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN104807755 JHA006F EOG Resources 

Inc.

1311 Crude Petroleum 

and Natural Gas

25.5 §115.110 -

§115.119

See Section 3.3.10 of RACT 

Discussion and Rule Project No. 

2010-025-115-EN.

No

RN102198868 DB1068G Littelfuse LP 3674 Semiconductors 

and Related 

Devices

25.4 §115.120 -

§115.129

No
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100661073 DB1573L Vertis Inc. 2752 Commercial 

Printing 

Lithograph

25.4 §115.440 -

§115.449

No

RN102660909 DB0482W General 

Dynamics Ots 

(Garland) LP

3483 Ammunition, 

Except for Small 

Arm

25.3 §115.420 -

§115.429

No

RN100216043 DB0259E Dallas 

Woodcraft 

Company LP

2499 Wood Products, 

NEC

§115.420 -

§115.429

No reported emissions in 2008 Yes

RN102000924 DB4237J City of Irving 4953 Refuse Systems §115.152 -

§115.159

No reported emissions in 2008 No

RN100747104 TA0133W New Styrochem 

US Ltd.

2821 Plastics Materials 

and Synthetic 

Resins

§115.110 -

§115.119 

§115.120 -

§115.129 

§115.131 -

§115.139 

§115.140 -

§115.149 

§115.352 -

§115.359

No reported emissions in 2008 Yes
RN Account Company SIC SIC Description Annual 

tpy

Rules 

Addressing 

RACT

Notes 2007 

RACT

RN100693308 TA0352I Luminant 

Generation 

Company LLC

4911 Electric Services NA No reported emissions in 2008

VOC emissions arise from natural 

gas combustion. Additional control 

for RACT is not economically 

feasible.

No
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

MAR I 7 2011 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

MEMORANDUM 

SUBJECT: 	 Approving SIP Revisions Addressing VOC RACT Requirements for Certain 

Coatings Categories 

FROM: 	 Scott Mathias, Interim Direct ;j J~~ Air Quality Policy Division \/C14 

TO: 	 Regional Air Division Directors 

The Office ofAir Quality Planning and Standards has received requests from 

Regional Offices for guidance on approving State Implementation Plan (SIP) revisions 

resulting from newly-issued Control Techniques Guidelines (CTGs) documents. These 

CTGs provide recommendations to inform state determinations as to what constitutes 

reasonably available control technology (RACT). In some cases, the newly-issued CTGs 

contain recommended emission limits that are less stringent than limits recommended in 

older CTGs covering the same industry, and may be less stringent than limits already adopted 

into SIPs based on the older CTGs. This is the case for industries covered by CTGs 

pertaining to Large Appliance Coatings, Metal Furniture Coatings, and Miscellaneous Metal 

and Plastic Parts Coatings. 

The U. S. Environmental Protection Agency (EPA) issued new CTGs for these 

categories in 2007 and 2008, under authority ofClean Air Act (CAA) section 183( e), to 

address volatile organic compound (VOC) emissions from categories of consumer and 

commercial products. They replace similar CTGs issued by EPA in 1977 and 1978. The 

new CTGs recommend more stringent limits for general use coatings, but also include new 

recommendations for several "specialty use" categories that are less stringent than the 

general use limits established in the 1970s guidelines. 

States are required to submit a SIP revision in response to any newly-issued CTGs. 1 

If an existing SIP contains requirements that are not less stringent than the applicability 

thresholds and/or coating operations limits recommended in new CTGs, the state may choose 

to submit as a SIP revision a certification that the existing SIP meets RACT requirements. 

CAA section 182(b)(2) requires Moderate and above ozone nonattainment areas to revise SIPs when a new 

CTG is issued by EPA after 1990. EPA is required to set a SIP submission deadline with the issuance of each 

CTG. For CTGs we have issued in the past several years, we have specified a submission deadline ofone year 

after the CTG was issued (See 72 FR 572 15 Oct 9, 2007 and 73 FR 5848 Oct 7, 2008). 

Internet Address (UAL) • http://www.epa.gov 

Recycled/Recyc lable • Printed w~ h Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer} 

1 
We anticipate that EPA Regional Offices would be able to approve the RACT determinations 

in these circumstances. We note that EPA's recommendations in CTGs are generally treated 

as "presumptive" RACT and states may demonstrate that other limits are RACT for one or 

more sources within the source category addressed by the CTG. Where a state has 

previously determined that more stringent applicability thresholds and/or control levels are 

RACT for one or more sources in a source category and the sources have complied with 

those requirements, then those existing controls should be considered RACT for such 

sources. 

If a state chooses to revise more stringent rules that are already in the approved SIP, 

so that those rules reflect the less-stringent recommended limits in the new CTGs, there are 

additional considerations that must be factored into any EPA decision to approve the SIP 

revision. The state would need to first demonstrate that the SIP-approved control 

requirements are not reasonably available considering technological and economic 

feasibility, consistent with EPA's definition ofRACT. See 44 FR 53762 (September 17, 

1979). In addition, in order to comply with the SIP approval conditions of CAA section 

II 0(1), the state would need to demonstrate that the revision to the SIP would not interfere 

with attainment of, or reasonable further progress toward attainment of, the National 

Ambient Air Quality Standards, nor interfere with any other applicable requirement of the 

CAA. This would be demonstrated if the stricter limits on general use coatings provide 

sufficient emission reductions to entirely offset any emission increase caused by adopting the 

less stringent limits for specialty coatings. Alternatively, the state could adopt supplemental 

measures that achieve additional emission reductions from another source category in 

another industry to offset the increased emissions from the specialty coatings. In general, if a 

proposed SIP revision achieves the same or greater emission reductions as the approved SIP 

within the same timeframe as provided under the existing plan, the Regional Office should be 

able to determine that the SIP revision is consistent with the approval conditions of CAA 

section 11 0(1). 

The public dockets for the Large Appliance Coatings and the Metal Furniture 

Coatings CTGs contain information that states may find helpful in determining the reductions 

that can be achieved by adopting the new general use category CTG limits for these 

industries. According to the docketed information, the estimated reductions from the new 

CTGs are 30 to 35 percent greater than from the older CTGs. See documents EPA-HQOAR-2007-0329-0009 and EPA-HQ-OAR-2007-0334-0010 in dockets EPA-HQ-OAR2007-0329 and EPA-HQ-OAR-2007-0334, respectively. The increase in emissions 

reductions in any specific nonattainment area may vary depending on the volume usage 

distribution among the general and specialty categories in that area. The dockets for the new 

CTGs do not contain area-specific analyses of potential emissions reductions. Generally, if a 

state believes the volume usage distribution among the general and specialty categories in the 

docket is representative of the distribution in the nonattainment area, we believe that if a state 

undertakes wholesale adoption of the new categorical limits in a specific CTG, the state may 

rely on the assessments in the docket to demonstrate that the range of new limits will result in 

an overall reduction in emissions from the collection of covered coatings. However, if a state 

adopts some specialty category limits, but not all of the new categorical limits, or determines 

that it has a different volume usage distribution among categories, the state may need to do 

an area-specific assessment of whether tighter restrictions for some coatings, coupled with 

2 

less stringent restrictions on other coatings would provide overall equal or greater emissions 

reductions than the set of rules based on the recommendations in the 1970s guidelines. 

If you have further questions on SIP-related issues you should contact Butch 

Stackhouse at (919) 541-5208. If you have further technical questions on the topics covered 

in this memorandum you should contact Kaye Whitfield at (919) 541-2509. 

cc: 	 Robin Dunkins, SPPD 

Kimber Scavo, AQPD 

David Orlin, OGC 

Sara Schnee berg, OGC 

3 

Buddy Garcia, Chairman 

Larry R. Soward, Commissioner 

Bryan W. Shaw, Ph.D., Commissioner 

Mark R. Vickery, P.G., Executive Director 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution . 

December 8, 2008 

Mr. William T. Harnett, Director, Air Quality Policy Division 

Office of Air Quality Planning and Standards Organization 

United States Environmental Protection Agency 

Mail Drop C504-01 

Research Triangle Park, North Carolina 27711 

Dear Director Harnett: 

The Texas Commission on Environmental Quality (TCEQ), Air Quality Division is currently reviewing 

the Consumer and Commercial Products Group II, Group III, and Group IV Control Techniques 

Guidelines (CTG) documents released by the United States Environmental Protection Agency (EPA) 

from 2006 through 2008. Our evaluation of these CTG documents has prompted several questions 

regarding the CTG documents for Large Appliance Coatings, Metal Furniture Coatings, and 

Miscellaneous Metal and Plastic Parts Coatings. The issues and questions related to these CTG 

documents are detailed below. 

Texas' existing rules in 30 Texas Administrative Code (TAC) Chapter 115 for controlling volatile organic 

compound (VOC) emissions from the surface coating of large appliances', metal furniture2

, and 

miscellaneous metal parts and products3 were based on the EPA's Office of Air Quality Planning and 

Standards (OAQPS) corresponding 1977 and 1978 Guideline Series4 (OS) recommendations. The 

existing emission standards for surface coating of large appliances and metal furniture are not specific to 

coating types; however, the 2007 CTG documents for Large Appliance Coatings5 and Metal Furniture 

Coatings6 recommend setting coating type specific emission standards. Some of the recommended 

emissions standards are equivalent or more stringent than the existing generic standards while some 

recommended emission standards are less stringent than the existing standards. Similarly, the 2008 CTG 

for Miscellaneous Metal and Plastic Parts Coatings 7 also recommends emission standards for certain 

coating types that are less stringent than the existing 30 TAC Chapter 115 emission standards. Please see 

the enclosed table for a more detailed comparison of the existing VOC emission standards based on the 

1977 and 1978 OS recommendations (and TCEQ rules) versus the 2007 and 2008 CTG documents for 

these categories. 

Since some of the limits recommended for these specific coating types are less stringent than the existing 

emission standards based on the EPA's original GS recommendations, TCEQ's Air Quality Division has. 

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • Internet address: www.tceq.state.tx.us 

pnnlcd on recycled paj)Cr u!iin~ soy-based inlo: 
Mr. William T. Harnett 

Page2 

December 8, 2008 

concerns that implementing the new CTG recommendations could be perceived as backsliding. In 

addition, these discrepancies may make it impossible for TCEQ staff to determine if actual VOC 

reduction benefit would occur from implementing the CTG recommendations. Given the limited 

explanation8 of how these differences should be considered in light of the original GS standards, the 

TCEQ Air Quality Division is requesting written guidance to clarify the intent of the EPA's new CTG 

recommendations with regard to the following issues. 

1. Specific clarification is needed that implementing the recommendations in the new CTG would 

not be considered backsliding. 

2. Are the coating type categories in the new CTG considered by the EPA to be coating types that 

were unregulated by the original GS recommendations or is this a situation where these specific 

coatings were covered under the original guidance, but the EPA has re-evaluated what is 

technically feasible for these specialty coating types? What data was used to make this 

determination? 

3. In light of the varying stringency of the recommended coating standards in these new CTG 

documents, how did the EPA determine the overall reduction benefit? Additional information, 

beyond what ·is provided in the docket, is necessary for the state to determine whether 

implementing th~ CTG recommendations will result in a net VOC reduction in the specific 

nonattainment areas where these CTG recommendations would be. implemented. 

The EPA's clarification regarding these issues is critical for the Air Quality Division to complete our 

evaluation of the CTG recommendations and proceed with any recommendation to TCEQ 's executive 

management and the commission regarding the potential implementation of the EPA's CTG 

recommendations. Therefore, your expeditious response regarding these issues is greatly appreciated. 

You may contact me at 512-239-4696. 

Sincerely, 

?JJCcL 

psusana M. Hildebrand, P .E. 

Director, Air Quality Division 

Texas Commission on Environmental Quality 

SMH/LA/sy 

Enclosures: References 

Emission Limit Comparison Table 

cc: Mr. Guy Donaldson, EPA Region 6 

Ms. Ellen Belk, EPA Region 6 

Mr. Bruce Moore, EPA, Office of Air Quality Planning and Standards 

Mr. Bill Johnson, EPA, Office of Air Quality Planning and Standards 

~--~~~~~~~~~-. 
Enclosure: References 

1: Title 30 TAC §115.421(a)(1), Emission Specifications for Large Appliance Coating (Amended 

January 17, 2003). 

2: Title 30 TAC §115.421(a)(2), Emission Specifications for Metal Furniture Coating (Amended 

January 17, 2003). 

3: Title 30 TAC §115.421(a)(9)(A), Emission Specifications for Miscellaneous Metal Parts and 

Products Coating (Amended January 17, 2003). 

4: Guideline Series. Control ofVolatile Organic Emissions from Existing Stationary Sources- Volume 

V: Surface Coating ofLarge Appliances, Publication number EPA-450/2-77-0.34. 

Guideline Series. Control ofVolatile Organic Emissions from Existing Stationary Sources- Volume 

III: Surface Coating ofMetal Furniture, Publication number EPA-450/2-77-032. 

Guideline Series. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume · 

VI: Surface Coating of Miscellaneous Metal Parts and Products, Publication number EP A-450/2-78-

015 .. 

5: Control Techniques Guidelines for Large Appliance Coatings. Publication number EPA 453/R-07-

004. 

6: Control Techniques Guidelines for Metal Furniture. Coatings. Publication number EPA 453/R-07-

005. 

7: Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings. Publication 

number EPA 453/R-08-003. 

8: EPA Docket Number EPA-HQ-OAR-2007-0329-0009 and EPA Docket Number EPA-HQ-OAR2007 -03 34-0010. 
Enclosure: Emission Limit Comparison Table 

Comparison of 30 TAC Chapter 115 Emission Limits and 2006-2008 CTG Recommended Emission 

Limits 

CTG Recommended Chapter 115 Coating Type* Emission Limit** Emission Limit** · Baked Coatinf:! · Air-Dried Coatinf:! 

Large Appliance Coating 

General, One Com_Q_onent 2.8 2.3 2.3 

General, Multi-Component 2.8 2.3 2.8 

Extreme High Gloss 2.8 3.0 2.8 

Ext1:eme Performance 2.8 3.0 3.5 

Heat Resistant 2.8 3.0 3.5 

Metallic 2.8 3.5 3.5 

Preti·eatment Coatings 2.8 3.5 3.5 

Solar Absorbent 2.8 3.0 3.5 

Metal Furniture Coating 

General, One Component 3.0 2.3 2.3· 

General, Multi-Component 3.0 2.3 2.8 

Extreme High Gloss 3.0 3.0 2.8 

Extreme Performance 3.0 3.0 3.5 

Heat Resistant 3.0 3.0 3.5 

·Metallic 3.0 3.5 3.5 

Pretreatment Coatings 3.0 3.5 3.5 

Solar Absorbent 3.0 3.0 3.5 

Miscellaneous Metal Parts and Products Coating 

General One Component 3.0 2.3 2.8 

General Multi Com:R_onent 3.0 2.3 2.8 

Camouflage 3.0 3.5 3.5 

Electric-lnsulating Varnish 3.0 3.5 3.5 

Etching Fillei· 3.0 3.5 3.5 

Extreme High-Gloss 3.0 3.0 3.5 

Extreme Performance 3.5 3.0 3.5 

Heat-Resistant 3.5 3.0 3.5 

High Performance Architectural 3.0 6.2 6.2 

High Temperature 3.0 3.5 3.5 

Metal.lic 3.0 3.5 3.5 

Military Specification 3.0 2.3 2.8 

Mold-Seal 3.0 3.5 3.5 

Pan Backing 3.0 3.5 3.5 

Prefabricated Architectural 3.0 2.3 3.5 

Multi-Component 

Prefabricated Architectural One- 3.0 2.3 3.5 

Component 

Pretreatment Coatings 3.0 3.5 3.5 

Repair and Touchup 3.0 3.0 3.5 

Silicone Release ' 3.0 3.5 3.5 

Solar-Absorbent 3.0 3.0 3.5 

·~-- -~---------~~-----------
Comparison of 30 TAC Chapter 115 Emissio~ Limits and 2006-2008 CTG Recommended Emission 

Limits 

Coating Type* Chapter 115 

Emission Limit** 

CTG Recommended 

Emission Limit** 

Baked Coating Air-Dried Coating 

Vacuum-Metalizing 3.0 3.5 3.5 

Drum Coating, New, Exterior 3.0 2.8 2.8 

Drum Coating~ New, Interior 4.3 3.5 3.5 

Drum Coating, Reconditioned, 3.0 3.5 3.5 

Exterior 

Drum Coating, Reconditioned, 4.3 4.2 4.2 

Interior 

* The CTG recommended emission limits for coating types listed in red font are less stringent than 

existing Chapter 115 limits. 

** Limit expressed in pounds per gallon of coating (minus water and exempt solvent) delivered to the 

application system. 
Mr. William T. Harnett 

Page 3 

December 8, 2008 

bee: Theresa Pella 

Ashley Forbes 

Vincent Meiller 

Lindley Anderson 

Amy Browning