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. NO X RACT Determination
3.2.1. Chapter 117 NO X 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 M etal and Plastic Parts Coatings
3.3.9. Automobile and Light

- Duty Truck Assembly CoatingsAPPENDIX F : REASONABLY AVAILAB LE 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 standar d, the DFW area is required to meet the mandates of the Feder al 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 (NO X

) 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 NO X 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 requ irements 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 availa ble 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 consider ation 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 attai nment 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 consum er 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 R ACT Update, 30 Texas Administrative Code Chapter 117 Rul e 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 i ssued in 2006 ;

**•** Offset Lithographic and Letterpress Printing, Group II i ssued in 2006 ; and

**•** Fiberglass Boat Manufacturing Materials, Group IV i ssued in 2008

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

**•** Industrial Cleaning Solvents, Group II i ssued in 2006 ;

**•** Large Appliance Coatings, Group III i ssued in 2007 ;

**•** Metal Furniture Coatings, Group III i ssued in 2007 ;

**•** Paper, Film, and Foil Coatings, Group III i ssued in 2007 ;

**•** Miscellaneous Industrial Adhesives, Gro up IV i ssued in 2008 ;

**•** Miscellaneous Metal and Plastic Parts Coatings, Group IV i ssued in 2008 ; and

**•** Auto and Light

- Duty Truck Assembly Coatings, Group IV i ssued in 2008

. 2. RACT EVALUATION APPR OACH 2.1. General Discussion The TCEQ demonstrates that the RACT require ments are being fulfilled in the DFW area by: (1) identifying all CTG source categories of NO X 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 NO X and VOC emissions; (3) identifying the state regulation that implements or exceeds RACT for each applicable CTG source category or non

CTG 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 defi ne presumptive RACT levels. The TCEQ reviewed the EPA's CTG and ACT documents to identify all source categories of NO X 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 thre shold for major stationary sources is a potential to emit of 50 tpy of either NO X or VOC emissions. The TCEQ reviewed the point source emissions inventory and Title V databases to identify all major sources of NO X or VOC emissions. All sources in the Title V database that were listed as a major source for NO X 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 a ctual emissions as low as 25 tpy of NO X 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 NO X 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 T he EPA previously approved the DFW VOC rules in 30 Texas Administrative Code (TAC) Chapter 115 and NO X 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 AC T 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 o n April 6, 2010 (SIP Project Number 2009

- 021

- SIP

-NR). Addi tional 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 red uction 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 lev el achieved b y 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 emiss ion 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 A ND DISCUSSION 3.1. General Discussion Under the current state rules, the DFW area is subject to some of the most string ent NO X 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 Ma y 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 are a 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 NO X 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 applicab ility criteria recommended for controls, e.g., sources less than the recommended exemption thresholds.

Table F

- 3: State Rules Addressing NO X RACT Requirements for Major Emission Sources in the DFW Area and Table F

- 4: State Rules Addressing VOC RACT Require ments 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 sourceslisted may actually be less than the major source thres hold 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 ozo ne NAAQS.

3.2. NO X RACT Determination 3.2.1. Chapter 117 NO X Rules The Chapter 117 rules represent one of the most comprehensive NO X control strategies in the nation. The NO X 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 NO X source categories. Table F

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

For non

- CTG a nd ACT major NO X emission source categories, RACT is fulfilled by separate existing source

- specific rules in Chapter 117 for sources that NO X controls are technologically and economically feasible. Further NO X controls on certain major sources were determi ned 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 cat egories 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 r ules 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 rev ision, 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 FlexiblePackag e Prin ting CTG recommendations that the TCEQ has determined are RACT in the DFW area (Rule Project Number 2010

- 016

- 115

- EN). The Chapter 115 rulemaking reduce s the VOC content limits of coatings, increase s the overall control efficiency of add

- on controls used in flexible package printing processes , establish es work practice procedures for materials used during associated cleaning activities, and expand s rule applicability to include smaller flexible package printing lines that were previously exempt from these ru les. The TCEQ is not implement ing 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 ad hesives. 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 fle xible 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 potential ly 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 t he rules. Additionally, the TCEQ is not implement ing 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 cont ent 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 1 15 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 rang ing 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 e nforceability 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. Industr ial Cleaning Solvents Concurrent with this SIP revision, the commission is adopting revisions to Chapter 115

, Su b chapter 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 establish es VOC content limits for cleaning solvents used in specific cleaning activities, provide s exemptions for certain cleaning acti vities from all or portions of the rule, and require s 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 ado pted 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 sol vents 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 th e DFW area (Rule Project Number 2010

- 016

- 115

- EN). The Chapter 115 rulemaking reduce s VOC content limits of coatings, increase s the overall control efficiency for add

- on controls used in large appliance coating operations, and establish es minimum transfer e fficiency 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 oper ations 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 cont ent 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 p ounds 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 recommendatio ns 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. Th e 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 over all 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 progres s 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 promul gating higher CTG

- recommended RACT limits for large appliancecoatings, 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 a re 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

, Subch a pter 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 reduce s VOC content limits of coatings, increase s the overall control efficiency for add

- on controls used in metal furniture coating operations, and establish es minimum transfer efficiency of coating application methods. The rules also requi re 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 st andards 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 unco ntrolled 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 m ay 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 l imits 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 coat ing 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 meth odology 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 limit s 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, t he 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 specificallyexplain why the lower limits included in the original C TG 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 Chapte r 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 Divisi on 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 reduce s the VOC content limits of coatings; increase s the overall control efficiency for add

- on controls used in paper, film, and foil coating operations; and establish es 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 cleani ng 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 i n 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, th e Chapter 115 rules retain the existing exemption criteria

. Additionally, the TCEQ is not implement ing the EPA’s 200 7 CTG recommendation to exempt a paper, film, and foil coating line from complying with VOC coating content limits if the line has the poten tial to emit less than 25 tpy of uncontrolled VOC emissions from coatings . As previously sta ted, 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 comply ing 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 200 7 CTG

- recommended exemption threshold.

3.3.7. Miscellaneous Industria l 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 implement s VOC content limits for general adhesive application processes, specialty adhesive application processes, and adhesive primer appl ication processes; provide s exemptions for certain cleaning activities from all or portions of the rule; incorporate s test methods and recordkeeping requirements; and establish es minimum transfer efficiency of adhesive application methods. The rules also r equire certain work practice procedures for adhesive

related activities and materials used during associated cleaning operations. I n response tocomment s , the commission is revising §115.470(a) to clarify the rules in Division 7 apply to manufacturing oper ations 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 r evised 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 P arts 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 de termined 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 expand s the scope of the existing rule applicability to include the new coating categories recommended in the 2008 CTG. The Chapter 115 rulemaking reduce s VOC content limits of coatings, inc rease s the overall control efficiency of add

- on controls

, and establish es minimum transfer efficiency of coating application methods. The rules also r equire certain work practice procedures for coating

- related activities and materials used during associate d 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 rul es 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, Div ision 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 i ssued 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 20 08 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 app roach 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 eight

hour 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 forthe 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 promulgati ng 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 m etal part and product 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 limits. In light of the technological and e conomic 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 200 8 CTG

recommended 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 RAC T 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 commi ssion 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 cra ft 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 po unds 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/su rfacer 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 coati ng 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 antifo ulants, 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 thedefinition of pretreatment wash primer coatings to include any coating that contains no more than 25 % solids, b y weight, and at least 0.1 0 % 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. Auto mobile and Light

- Duty Truck Assembly Coating s 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 reduce s the VOC content limits of coatings and establish es work practice procedures for materials used during cleaning operations associated with automobile and light

- d uty 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 th an 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 process es 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, Di vision 1 to implement RACT for the storage of VOC (Rule Project Number 2010

- 025

- 115

- EN)

. The Chapter 115 rulemaking revises existing rules to inclu de additional require ments 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 t he revised requirements implement RACT for the petroleum liquid stora ge CTG emission source category

, these rules are more stringent than the EPA’s RACT recommendations for th e s e source s (EPA Document Numbers EPA

- 450/2

- 77

- 036, EPA

- 450/2

- 78

- 047, and EPA

- 453/R

- 94

- 001)

. T his Chapte r 115 rulemaking also require s 95% control of flash emissions from crude o il 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 source s 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 NO X RACT Require ments in CTG and ACT Reference Documents

Emission Source Category CTG or ACT Reference Document State Regulations Fulfilling RACT RequirementsEmission Source Category CTG or ACT Reference Document State Regulations Fulfilling RACT Requirements Cement Manufacturing NO X Emissions from Cement Manufacturing (EPA

- 453/R

- 94

- 004, March 1994, Updated September 2000) §117.3100

– §117.3145

Glass Manufacturing NO X Emissions from Glass Manufacturin g (EPA

453/R

- 94

- 037, June 1994) §117.400

– §117.456

Industrial, Commer cial, and Ins titutional Boilers NO X Emissions from Industrial, Commercial and Institutional Boilers (EPA

- 453/R

- 94

- 022, March 1994) §117.400

– §117.456

Iron and Steel NO X Emissions from Iron and Steel (EP A

- 453/R

94

- 065, September 1994) §117.400

– §117.456

Nitri c and Adipic Acid Manufacturing NO X 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 NO X Emissions from Process Heaters (EPA

- 453/R

9 3

- 034, revised September 1993) §117.400

– §117.456

Stationary Internal Combustion Engines NO X 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 NO X Emissions from Stationary Combustion Turbines ( EPA

- 453/R

- 93

- 007, January 1993) §117.400

– §117.456

Utility Boilers NO X Emissions from Utility Boilers (EPA

- 453/R

94

- 023, March 1994) §117.1100

– §117.1156

Table F

- 2: State Rules Addressing VOC RACT Requir ements 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

– §115.4 29Emission 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 Nationa l Rule.

Automobile Coating The Reduction of Volatile Organic Compound Emissions from Automobile Refinishing (EPA

450/3

- 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 auto

body refinishing was issued in 1998 after the ACT) §115.420

– §115.429

Batch Processes Alternative Control Techniques Document: Control of Volatile Organic Compoun d Emissions from Batch Processes (EPA

- 453/R

- 93

- 017 or EPA

453/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 Gaso line 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

- ENEmission 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 Alterna tive 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 Guidelin es 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 (E PA

- 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

– §115.449Emission 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 (EPA

453/R

- 9 3

- 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 Storag e 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 (EPA

450/2

- 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 existin g 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 (EPA

450/2

- 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 (EPA

450/2

- 77

- 033, December 1977) §115.420

– §115.429Emission 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 Coat ing 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 (EPA

450/2

- 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/R

94

- 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 (EPA

450/3

- 83

- 008, November 1983) §115.120

– §115.129

Synthetic Organic Chemical Manufacturing Industry Control of Volatile Organic Compound Fu gitive 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 Oxidati on Processes in Synthetic Organic Chemical Manufacturing Industry (EPA

450/3

- 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

Ta nk 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

– §115.429Table F

- 3: State Rules Addressing NO X 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 NoRN 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 E ngine testing, aircraft

. Additional control of NO X 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 YesRN Account Company SIC SIC Description Annual tpy Rules Addressing RACT Notes 2007 RACT

RN100542588 ED0238T Atmos Energy Corporation Mid

Tex 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 NoRN 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 NoRN 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 E ngine testing, turbine

. Additional control of NO X 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 NoRN 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 YesRN 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 NoRN 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 NoRN 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 NoRN 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 YesRN 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 NoTable 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

§115.4 50

- §115.45 9 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 No s . 1635, 3026, 5983, 8097, and 8099. Further control may also be required by MACT. Additional control for RACT is not economical ly feasible. YesRN 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

§115.4 50

- §115.45 9 See Section 3.3.1 0 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 3.3.1 0 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 Se rvices LLC 1311 Crude Petroleum and Natural Gas 97.9 §115.110

- §115.119 See Section 3.3.1 0 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. YesRN 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 Subpart s 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 Printi ng Ltd 2759 Commercial Printing, NEC 86.1 §115.430

- §115.439 See Section 3.3.1 0 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 3.3.1 0 of RACT Discussion and Rule Project No. 2010

- 025

- 115

- EN

. NoRN 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

§115.4 50

- §115.45 9 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

§115.4 50

- §115.45 9 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

§115.4 50

- §115.45 9 See Section 3.3.8 of RACT Discussion and Rule Project No. 2010

- 016

- 115

- EN

. NoRN 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

- §115.41 9

§115.420

- §115.429

§115.4 50

- §115.45 9 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. NoRN 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

RN10 0218320 DB0914O Vought Aircraft Industries Inc. 3721 Aircraft 53.0 §115.420

- §115.429

§115.4 50

- §115.45 9 See Section 3.3.8 of RACT Discussion and Rule Project No. 2010

- 016

- 115

- EN

. YesRN 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 3.3.1 0 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. YesRN 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 3.3.1 0 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. NoRN 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

- §115.41 9

§115.420

- §115.429 NoRN 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

- §115.11 9

§115.120

- §115.129

§115.412

- §115.41 9

§115.420

- §115.4 29 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 NoRN 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 3.3.1 0 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. NoRN 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

- §115.41 9

§115.420

- §115.4 29

§115.430

- §115.439

§115.4 50

- §115.45 9 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. YesRN 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. NoRN Account Company SIC SIC Description Annual tpy Rules Addressing RACT Notes 2007 RACT

RN104475157 TAA013M Barnett Ga thering 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 3.3.1 0 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. NoRN 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 NoRN 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

- §115.41 9 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. YesRN 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 p ermit. 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 3.3.1 0 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 NoRN 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

§115.4 50

- §115.45 9 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

§115.4 50

- §115.45 9 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 p ermit. 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. NoRN 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

§115.4 50

- §115.45 9 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 3.3.1 0 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 3.3.1 0 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 NoRN 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 YesRN 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. NoUNITED STAT E S ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711



## MAR I 7 2011 OFF I CE OF A I R QUALITY PLANN I NG AND STANDARDS



### MEMORANDUM

SUBJECT: Approving SIP Revi s ion s Addressing VOC RACT Requir e ment s for Certain Coatings Categories



### FROM: Scott Mathias, Int e rim Direct 

# ;j 

# J

# ~~ Air Qualit y Policy Divi si on

# \/C1**4**



### TO: R eg ional Air Di v ision Dir ecto r s

The Office of Air Qualit y Planning a nd Standards ha s received reque sts from Regional Offices for g uidance on approving State Implementation Plan (SIP) revi s ion s resulting from newly-issued Co ntrol Techniques Guidelines (CTGs) document s

. These CTGs pro vide recommendations to inform state d ete rmin at ion s as to w h at constitutes

rea s onably ava il ab l e control tec hnolo gy (RACT). In so me cases, the newly-i ss ued CTGs contain recommended e mi ss ion limit s that are l ess st rin ge nt than limit s re co mmended in

o ld e r CTGs cove rin g t h e sa m e indu s tr y, and ma y be l ess s tringent th a n limit s already adopted into S IP s based on the older CTGs

. Thi s i s th e case for industrie s covered by CTGs pertaining to Large Appliance Coat in gs, Metal F urnitur e Coat in gs, a nd Miscellaneous Metal

a nd Plastic Parts Coat in gs.

T h e U. 

### S. E n vironme nt a l Protection Agency ( E PA ) i ss u ed n e w CTGs for th ese categorie s in 2 00 7 an d 2 008
, und er a uthorit y of Clean A ir Ac t (CAA) se ction 183( e), to

a ddr ess vo l ati le or ga nic compound (VOC) em i ss i o n s from categories of co n s um e r and commercial product s. They replace s imil a r CTGs i ss u e d by E PA in 1 977 a nd 19 78. Th e
n ew CTGs recomm e nd more s trin ge nt limit s for g eneral u se coating s, but a l s o includ e new recommendations for severa l "s pecialty u se" ca t egor i es t hat a r e l ess str in ge nt than th e ge n era l u se limit s es tabli s h e d in the 1970 s g uid e line s

.
State s are required to s ubmit a SIP revi s i o n in re s pon se to any n ew l y- i ss u e d CTGs. 1 

### I f a n ex i s ting SIP co nt a in s requirement s that a r e not le ss s trin ge nt th an th e app li ca bilit y thr es hold s and/ or coat in g operations limit s recommended in n ew CTGs, the s tate m ay choo se to s ubmit as a SIP revision a certification that t h e exis tin g SIP m ee t s RACT requir e ment s.

CAA sec tion 18 2( b )(2) requ ir es Mod e r ate a nd a bo ve ozone n o n attai nm ent a r eas t o r ev i se SIPs w hen a new CTG i s i ss u ed b y E PA a fter 1 990. E PA i s r e quir e d to se t a S IP s ubmi ss i on d ea dlin e with t h e i ss u a n ce of eac h C TG. For CTGs we h ave i ss u e d in the p ast seve r a l years, we h ave s p ec ifi e d a s ubmi ss i on deadlin e of o n e yea r after th e CTG was i ss u e d (See 72 FR 572 1 5 Oct 9, 2 00 7 a nd 73 FR 5848 Oct 7, 2 008)

.

Int e rn e t Address ( UA L) • http :// www .e p a

. gov Rec y c l ed /R ec y c l ab l e • P ri nte d**w~ h**  V ege t ab l e Oil Ba s ed Ink s o n Recyc l e d Paper ( Mi n imum 2 5% P o s t co n s u m e r} 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



### 3Buddy 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 furniture 2

, and miscellaneous metal parts and products 3 were based on the EPA's Office of Air Quality Planning and Standards (OAQPS) corresponding 1977 and 1978 Guideline Series 4 (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 Coatings 5 and Metal Furniture Coatings 6 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 explanation 8 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

psu sana 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