Bryan W. Shaw, Ph.D., Chairman 

Buddy Garcia, Commissioner 

Carlos Rubinstein, Commissioner 

Mark R. Vickery, P.G., Executive Director 10 APR 12'" PH 4: 08 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution 

April6, 2010 

Dr. Alfredo "Al" Armendariz, Regional Administrator 

U.S. Environmental Protection Agency- Region 6 

1445 Ross Avenue ' 

Dallas, Texas 75202-2733 

Dear Dr. Armendariz: 

Docket No. 2009-1127-SIP 

On March I 0, 20 I 0, the Texas Commission on Environmental Quality (Commission) adopted a revision to the 

State Implementation Plan (SIP) for the Dallas-Fort Worth 1997 eight-hour ozone nonattainment area. · 

The Commission adopted the SIP revision to provide a Reasonably Available Control Technology (RACn 

..update, a 30 Texas Administrative Code Chapter 117 rule revision noninterference demonstration, and a 

modified failure-to-attain contingency plan. 

Enclosed are the proposed revision to the SIP, a public hearing certification~ a complete record of the public 

hearings, and the accompanying order. I look forward to your expeditious approval of this SIP revision. 

Sincerely, 

~:~~~ Chairman 

BWS/mac 

Enclosures 

cc: The Honorable Rick Perry, Governor of Texas 

Mr. Toby Baker, Office of Budget, Planning and Policy, Office of the Governor 

MJ:. Mark R. Vickery, P.G., Executive Director, Texas Commission on Environmental Quality 

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

printed on recydeJ paper using soy-based ink 
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

THE STATE OF 1EXAS 

COUNTY OF TRAVIS 

Docket No. 2009-1127-SIP 

This is to certify that the attached are true and correct copies of documents for a 

revision to the Texas State Implementation Plan, adopted on March 10, 2010, pursuant to 40 

Code of Federal Regulations (C.P.R.) § 51.104. I am the records administrator for the Air 

Quality Division of the Texas Commission on Environmental Quality (Commission). 

~D~~ \1 ~ Texas Commission on Environmental Quality 
Texas Commission on Environmental Quality 

Public Hearings 

October 29, 2009 and November 2, 2009 

Concerning Revisions to the 

DFW Eight-Hour Ozone Attainment Demonstration SIP 

Project No. 2009-021-SIP-NR 
INTRODUCTION 

The Texas Commission on Environmental Quality (commission) held public hearings in Austin on 

October 29, 2009; and Fort Worth on November 2, 2009, to receive testimony regarding revisions to 

the state implementation plan (SIP) concerning the Dallas-Fort Worth (DFW) Eight-Hour Ozone 

Attainment Demonstration. 

This SIP revision contains elements and actions required by the Federal Clean Air Act (FCAA), 

including a DFW Volatile Organic Compounds (VOC) Reasonably Achievable Control Technology 

(RACT) to 30 TAC Chapters 115 and 117 into the Texas SIP, a demonstration of noninterference 

with the SIP for the Chapter 117 rule revision, and a modified failure-to-attain contingency plan. 

The comment period closed on November 9, 2009. All testimony and comments have been 

reviewed and seriously considered. This hearing record contains a complete record of the public 

hearing and is divided into the following four sections: 

o Public Notification and Proposal 

o Written and Oral Testimony 

o Evaluation of Testimony 

o Staff Recommendations/Order 

Additional copies of this hearing record are maintained in the TCEQ central office at 12100 Park 35 

Circle, Austin, Texas 78753. For further information, please contact Mary Ann Cook at (512) 239-

6739. 
PUBLIC 

NOTIFICATION AND 

PROPOSAL 
PUBLIC NOTIFICATION 

Notification to the public of the proposed revisions was conducted by the following procedures: 

1. Publication of notice of public hearings in the following newspapers on the date listed: 

Austin American-Statesman, September 28, 2009 

Fort Worth Star-Telegram, September 25, 2009 

2. Publication of the Notice of Public Hearings in the October 9, 2009, issue of the Texas Register 

(34 TexReg 7133). 

3. Correspondence forwarding the notice of public hearings to the following officials and agencies: 

Speaker of the House 

Lieutenant Governor 

Alamo Area Council of Governments 

Capital Area Planning Council 

City of Austin, Mayor's Office 

City of Dallas, Department of Environmental and Health Services 

City of Dallas, Department of Aviation 

City of El Paso, Environmental Services 

City of Fort Worth, Environmental Management Department 

City of Fort Worth, Mayor's Office 

City of Houston, Department of Health and Human Services 

City of Houston, Mayor's Office 

East Texas Council of Governments 

El Paso Metropolitan Planning Organization 
Federal Highway Administration 

Galveston County Health District 

Harris County Public Health and Environmental Services 

North Central Texas Council of Governments 

Houston-Galveston Area Council 

South East Texas Regional Planning Commission 

Tarrant County Judge 

Texas Department of Transportation 

Travis County Judge 

Victoria Metropolitan Planning Organization 

Arkansas Department of Pollution Control and Ecology 

Louisiana Department of Environmental Quality 

New Mexico Environmental Department 

Oklahoma Department of Environmental Quality 

United States Environmental Protection Agency 
Example of Newspacer Classified A,g 

Fort Walth Star-Telegram, September 25, 2009 
Compounds and corresponding revis ons to the state implementation 

plan (SIP) under the requirements o Texas Health and Safety Code, 

§382.017; Texas Government Code, hapter 2001, Subchapter B; and 

40 Code of Federal Regulations §51. 02, and the United States Environmental Protection Agency (EPA) concerning SIPs. Additionally, 

the commission will also receive te · ony regarding the proposed 

eight-hour ozone attainment demo stration and reasonable further 

progress (RFP) demonstration for e Houston-Galveston-Brazoria 

(HGB) area. 

The proposed amendment to Chapte 101, Subchapter H. Division 3, 

Mass Emissions Cap and Trade CT) Program, would revise the 

definition of"Uncontrolled design ca acity" to provide additional flexibility for certain stationary diesel en ines and clarify both site and facility applicability. In addition, the p posed amendment would maintain the integrity of the nitrogen oxi es (NO.) cap in the HGB ozone 

nonattainment area and minimize in reases in the NO. cap by discontinuing the acceptance of late ECT- forms, Level of Activity Certification, from major sources ofNO submitted after March 30, 2010. 

(Rule Project No. 2009-019-101-E 

The proposed amendment to Cha r 101, Subchapter H. Division 

6, Highly-Reactive Volatile Organi Compound Emissions Cap and 

Trade Program, would reduce the cap amount of allowances and 

revise the allocation methodology o allowances for participants in the 

Highly-Reactive Volatile Organic ompound (HRVOC) Emissions 

Cap and Trade Program. A propose amendment to §I 0 1.1 would also 

update the definition of volatile org ·c compound (VOC) to link the 

30 TAC definition with the current definition in 40 Code of Federal 

Regulations and correct the repo le quantity for 1,1,1,2,3,3,3-heptaftuoropropane. (Rule Project No 2009-006-101-EN) 

The proposed amendments to Chap r 115, Subchapter E, Division 4, 

Offset Lithographic Printing, woul reduce the VOC content limits on 

fountain solutions used by sources tare subject to the existing Chapter 115 rules. The proposed rule aking would also limit the VOC 

content of fountain and cleaning so tions used by certain sources that 

are exempt from the existing Cha 115 rules. (Rule Project No. 

2008-019-115-EN) 

The proposed HGB Attainment D 

Federal Clean Air Act-required S elements, including a photochemical modeling analysis, a weight f evidence analysis, a reasonable 

available control technology (RA analysis, a reasonably available 

control measures (RACM) analys' , a motor vehicle emissions budget (MVEB) for 2018, and a con· gency plan. In addition, the Houston-Galveston Area Council has mmitted to emissions reductions 

through the Voluntary Mobile Em ssion Reduction Program and implementation oftransportation co I measures. The proposed revision also describes the concurren proposed rule revisions in Chapters 101 and 115. The commiss' n is also soliciting comments on 

whether it is appropriate to perfo a 1997 eight-hour ozone standard 

mid-course review analysis, and, · so, what elements should be contained in the analysis. The co ission is also seeking input on the 

appropriate date to submit the mi course review. (Rule Project No. 

2009-017-SIP-NR) 

The proposed HGB Eight-Hour ne Nonattainment Area RFP SIP 

revision demonstrates that the 18 rcent ozone precursor emissions reduction requirement will be met fo the analysis period of2002 to 2008, 

9 percent between 2009 and 2011 9 percent between 2012 and 2014, 

9 percent between 2015 and 201 , 3 percent in 2018, and 3 percent 

for contingency purposes. This re ision also includes a revised MVEB 

for the milestone years 2008, 20 I, 2014, 2017, and 2018. No new 

on-road mobile source controls ve been adopted as part of the plan. 

However, on-road mobile source missions inventories have been updated using the latest available da and the EPA's MOBILE6 inventory 

development tool. As a result of the quired mobile source emission 

inventory updates, the MVEBs are u ted as part of this SIP revision. 

(Rule Project No. 2009-018-SIP-N ) 

Public hearings on these proposals ll be held at the following times 

and locations: October 28, 2009, 2:0 p.m. and 6:00 p.m., in Conference Room A at the Houston-Galve n Area Council. 3555 TIIIlinons 

Lane, Houston; and in Austin on 0 ober 29, 2009, 3:00p.m., at the 

Texas Commission on Environmen Quality complex, Building E, 

Room 201S, 12100 Park 35 Circle. e hearings will be structured for 

the receipt of oral or written comm nts by interested persons. Registration will begin 30 minutes prior o each hearing. Individuals may 

present oral statements when called u n in order of registration. There 

will be no open discussion during e hearing; however, commission 

staff members will be available to di uss the proposals 30 minutes before each hearing and will answer q stions before and after the hearing. 

Persons planning to attend the he' g, who have special communication or other accommodation nee , should contact Charlotte Horn, 

Texas Register Team (512) 239-077 . Requests should be made as far 

in advance as possible. 

Comments may be submitted to J ssica Rawlings, Texas Register 

Team, Office of Legal Services, Te Commission on Environmental 

Quality, MC 205, P.O. Box 1308 , Austin, Texas 78711-3087, or 

faxed to (512) 239-4808. Electro comments may be submitted at 

www5.tceq.state.tx.uslruleslecomm ts/. File size restrictions may 

apply to comments being submitte via the eComments system. All 

comments should reference the le or SIP project number that 

the comment pertains to: Rule Project No. 2009-019-101-EN 

for the proposed MECT rule mendments, Rule Project No. 

2009-006-101-EN for the propo ed HRVOC rule amendments, 

Rule Project No. 2008-019-115- N for the proposed VOC rule 

amendments, SIP Project No. 2 9-017-SIP-NR for the proposed 

HGB Attainment Demonstratio SIP revision and SIP Project 

No. 2009-018-SIP-NR for the p posed HGB RFP SIP revision. 

Comments must be received by November 9, 2009. Copies of 

the proposed rules can be obtaine from the commission's Web site 

at http://www.tceq.state.tx.uslnav!J eslpropose _ adopt.html. Copies 

of the proposed SIP revisions an all appendices can be obtained 

from the commission's Web site http:llwww.tceq.state.tx.uslimplementationlairlsip/Hottop.html. Fo further information regarding the 

proposed rules and SIP revisions, please contact Ray Schubert, Air 

Quality Planning Section, at (512) 39-6615. 

TRD-200904267 

Robert Martinez 

Director, Environmental Law Divisi n 

Texas Commission on Environmen I Quality 

Filed: September 25, 2009 

• • 

Notice of Public Hearings on Proposed Revisions to 30 TAC 

Chapter 115 and to the State Implementation Plan 

The Texas Commission on Environmental Quality (commission) will 

conduct public hearings to receive testimony regarding proposed 

revisions to 30 TAC Chapter 101, General Air Quality Rules, and 

30 TAC Chapter 115, Control of Air Pollution from Volatile Organic 

Compounds and corresponding revisions to the state implementation 

plan (SIP) under the requirements of Texas Health and Safety Code, 

§382.017; Texas Government Code, Chapter 2001, Subchapter B; 

and 40 Code of Federal Regulations §51.1 02, and the United States 

Environmental Protection Agency (EPA) concerning SIPs. Additionally, the commission will also receive testimony regarding the 

IN ADDITION October 9, 2009 34 TexReg 7133 
proposed eight-hour ozone volatile organic compound (VOC) reasonably available control technology (RAC1) update, demonstration of 

noninterference, and modified failure-to-attain contingency plan for 

the Dallas-Fort-Worth (DFW) area. 

The proposed amendments to Chapter 115, Subchapter E, Division 4, 

Offset Lithographic Printing, would reduce the VOC content limits on 

fountain solutions used by sources that are subject to the existing Chapter 115 rules. The proposed rulemaking would also limit the VOC 

content of fountain and cleaning solutions used by certain sources that 

are exempt from the existing Chapter 115 rules. (Rule Project No. 

2008-4J19-11S-EN) 

The proposed DFW SIP revision contains Federal Clean Air Act-required SIP elements including an update to the VOC RACT element of 

the DFW 1997 Eight-Hour Ozone Attainment Demonstration SIP Revision. The proposed DFW SIP revision also includes a demonstration 

of noninterference to attainment of the 1997 eight-hour ozone standard 

from a Chapter 117 rule revision proposed by the commission on August 12, 2009, and a modified failure-to-attain contingency plan. The 

proposed revision also incorporates the concurrently proposed rule revision in Chapter 115 regarding the offset lithographic printing contingency measure. (Rule Project No. 2009-4)21-SIP-NR) 

Public hearings on these proposals will be held at the following times 

and locations: in Austin on October 29,2009, 1:00 p.m., at the Texas 

Commission on Environmental Quality complex, Building E, Room 

201S, 12100 Park 35 Circle; and in Fort Worth on November 2, 2009, 

2:00p.m., at the Texas Commission on Environmental Quality, Region 

4 Office, DFW Public Meeting Room, 2309 Gravel Road, Fort Worth. 

The hearings will be structured for the receipt of oral or written comments by interested persons. Registration will begin 30 minutes prior 

to each hearing. Individuals may present oral statements when called 

upon in order of registration. There will be no open discussion during the hearing; however, commission staff members will be available 

to discuss the proposals 30 minutes before each hearing and will answer questions before and after the hearing. Persons planning to attend 

the hearing, who have special communication or other accommodation needs, should contact Charlotte Hom, Texas Register Team (512) 

239-0779. Requests should be made as far in advance as possible. 

Comments may be submitted to Jessica Rawlings, Texas Register 

Team, Office of Legal Services, Texas Commission on Environmental 

Quality, MC 205, P.O. Box 13087, Austin, Texas 78711-3087, or 

faxed to (512) 239-4808. Electronic comments may be submitted at 

www5.tceq.state.tx.us/ru/es/ecomments!. File size restrictions may 

apply to comments being submitted via the eComments system. All 

commeots should refereoce the rule or SIP project oumber that 

the commeot pertaiDs to: Rule Project No. 2008-4J19-11S-EN 

for the proposed VOC rule ameodmeots aod SIP Project No. 

2009-4J21-SIP-NR for the proposed DFW SIP revisioo. Commeats must be received by November 9, 2009. Copies of the 

proposed rules can be obtained from the commission's Web site at 

http://www.tceq.state. tx. uslnavlru/es/propose _ adopt.html. Copies of 

the proposed SIP revision and the appendix can be obtained from 

the commission's Web site at http:llwww.tceq.state.tx.uslimplementation!airlsip/Hottop.html. For further information regarding the 

proposed rule and SIP revision, please contact Ray Schubert, Air 

Quality Planning Section, at (512) 239-6615. 

TRD-200904265 

Robert Martinez 

Director, Environmental Law Division 

Texas Commission on Environmental QuaiHy 

Filed: September 25, 2009 

• • • 

34 TexReg 7134 October 9, 2009 Texas Register 

Notice of Water Quality Applic tions 

The following notices were issue on September I 0, 2009 through 

September 17, 2009. 

The following require the applican to publish notice in a newspaper. 

Public comments, requests for pub c meetings, or requests for a contested case hearing may be submit! d to the Office ofthe Chief Clerk, 

Mail Code 105, P.O. Box 13087, A . Texas 787ll-3087, WITiflN 

30 DAYS OF THE DATE OF NEW PAPER PUBLICATION OF THE 

NOTICE. 

INFORMATION SECTION 

LAS VENTANAS LAND PAR RS LTD has applied for a renewal 

ofTCEQ Permit No. WQ0014534 01, which authorizes the disposal 

of treated domestic wastewater at daily average flow not to exceed 

630,000 gallons per day via surface· 'gation of262 acres of non-public access land. This permit will no authorize a discharge of pollutants 

into waters in the State. The waste ater treatment facility and disposal 

site will be located approximately .6 miles west-southwest of the intersection of Ranch-to-Market Ro 620 and Lakeway Boulevard in 

Travis County, Texas 78734. 

KINDER MORGAN PETCOKE P which operates Kinder Morgan 

Deepwater Bulk Terminal, a pe leum coke storage and handling 

facility, has applied for a m~Yor endment to TPDES Permit No. 

WQ000430 I 000 to authorize an ad itional impoundment for retaining 

storm water associated with the troleum coke operation and an 

increase in the storage area for pe leum coke. The current permit 

authorizes the discharge of process wastewater and storm water on an 

intermittent and flow variable bas via Outfall 001. The facility is 

located just south of the Houston S "p Channel, and approximately 1.0 

mile northeast of the intersection o East Beltway and State Highway 

225, in the City of Pasadena, ·s County, Texas. The TCEQ 

Executive Director has reviewed is action for consistency with the 

Texas Coastal Management Pro goals and policies in accordance 

with the regulations of the Co Coordination Council, and has 

determined that the action is consis ent with the applicable CMP goals 

and policies. 

FORTHANCOCKWATERCON OLANDIMPROVEMENTDIS- · 

TRICT which proposes to operate ort Hancock WCID Plant, has applied for a new permit, proposed rmit No. WQ0004869000, to authorize the discharge of microfilter ackwash water and reverse osmosis reject water at an average flow t to exceed 36,000 gallons per day 

via evaporation. This permit will n authorize a discharge of pollutants 

into water in the State. The facility d the disposal site will be located 

approximately 2.5 miles northwest fthe intersection ofState Highway 

180 (Knox Avenue) and Interstate 0, Hudspeth County, Texas. 

CITY OF COLEMAN has applied or a renewal ofTPDES Permit No. 

WQ0010150001 which authorizes the discharge of treated domestic 

wastewater at a daily average flo not to exceed 800,000 gallons per 

day. The current permit also autho · s the disposal of treated domestic wastewater via irrigation of S acres of City owned pastureland. 

The facility is located east of the ity of Coleman on the south side 

ofHords Creeks and approximate! 3/4 mile northwest of the intersection of Farm-to-Market Road 568 and U.S. Highway 84 in Coleman 

County, Texas 76834. 

CITY OF RUNAWAY BAY has a plied fora renewal ofJ'PDESPermit No. WQ0010862001 which au orizes the discharge of treated domestic wastewater at a daily ave e flow not to exceed 400,000 gallons per day. The facility is locate approximately 2,000 feet north of 

U.S. Highway 380 and approxim ly 7,000 feet southwest of the point 

where U.S. Highway 380 crosses Lake Bridgeport in Wise County, 

Texas 76426. 
Bryan W. Shaw, Ph.D., Chairman 

Buddy Garcia, Commissioner 

Carlos Rubinstein, Commissioner 

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

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution 

NOTICE OF PUBLIC HEARINGS BY THE 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

ON PROPOSED REVISIONS TO 30 TAC CHAPTER 115 AND TO THE STATE 

IMPLEMENTATION PLAN 

The Texas Commission on Environmental Quality (commission) will conduct public hearings to receive 

testimony regarding proposed revisions to 30 TAC Chapter 101, General Air Quality Rules, and 30 TAC 

Chapter 11 5, Control of Air Pollution from Volatile Organic Compounds and corresponding revisions to 

the state implementation plan (SIP) under the requirements of Texas Health and Safety Code, §382.017; 

Texas Government Code, Chapter 2001, Subchapter B; and 40 Code of Federal Regulations §51.102, and 

the United States Environmental Protection Agency (EPA) concerning SIPs. Additionally, the 

commission will also receive testimony regarding the proposed eight-hour ozone volatile organic 

compound (VOC) reasonably available control technology (RACT) update, demonstration of 

noninterference, and modified failure-to-attain contingency plan for the Dallas-Fort-Worth (DFW) area. 

The proposed amendments to Chapter 115, Subchapter E, Division 4, Offset Lithographic Printing, would 

reduce the VOC content limits on fountain solutions used by sources that are subject to the existing 

Chapter 115 rules. The proposed rulemaking would also limit the VOC content of fountain and cleaning 

solutions used by certain sources that are exemPt from the existing Chapter 115 rules. (Rule Project No. 

1008-019-115-EN) 

The proposed DFW SIP revision contains Federal Clean Air Act-required SIP elements including an 

update to the VOC RACT element of the DFW 1997 Eight-Hour Ozone Attainment Demonstration SIP 

Revision. The proposed DFW SIP revision also includes a demonstration of noninterference to 

attainment of the 1997 eight-hour ozone standard from a Chapter 117 rule revision proposed by the 

commission on August 12, 2009, and a modified failure-to-attain contingency plan. The proposed 

revision also incmporates the concurrently proposed rule revision in Chapter 11 S regarding the offset 

lithographic printing contingency measure. (Rule Project No.1009-0ll-SIP-NR) 

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

prinlec..l on rnycled pi!per u~in~ .soy-based jnh" 
Public hearings on these proposals will be held at the following times and locations: in Austin on 

October 29, 2009, 1:00 p.m., at the Texas Commission on Environmental Quality complex, Building E, 

Room 201S, 12100 Park 35 Circle; and in Fort Worth on November 2, 2009, 2:00 p.m., at the Texas 

Commission on Environmental Quality, Region 4 Office, DFW Public Meeting Room, 2309 Gravel 

Road, Fort Worth. The hearings will be structured for the receipt of oral or written comments by 

interested persons. Registration will begin 30 minutes prior to each hearing. Individuals may present oral 

statements when called upon in order of registration. There will be no open discussion during the 

hearing; however, commission staff members will be available to discuss the proposals 30 minutes before 

each hearing and will answer questions before and after the hearing. Persons planning to attend the 

hearing, who have special communication or other accommodation needs, should contact Charlotte Horn, 

Texas Register Team (512) 239-0779. Requests should be made as far in advance as possible. 

Comments may be submitted to Jessica Rawlings, Texas Register Team, Office of Legal Services, Texas 

Commission on Environmental Quality, MC 205, P.O. Box 13087, Austin, Texas 78711:3087, or faxed to 

(512) 239-4808. Electroiric comments may be submitted at www5.tceq.state.tx. us/rules/ecommentsl. File 

size restrictions may apply to comments being submitted via the eComments system. All comments 

should reference the rule or SIP project number that the comment pertains to: Rule Project No • 

.2008-019-115-EN for the proposed VOC rule amendments and SIP Project No. 2009-021-SIP-NR 

for the proposed DFW SIP revision. Comments must be received by November 9, 2009. Copies of 

the proposed rules can be obtained from the commission's Web site at 

http:llwww.tceq.state.tx.uslnavlruleslpropose_adopt.html. Copies of the proposed SIP revision and the 

appendix can be obtained from the commission's Web site at 

http:llwww.tceq.state.tx.uslimplementation/air/sip/Hottop.html. For further information regarding the 

proposed rule and SIP revision, please contact Ray Schubert, Air Quality Planning Section, at (512) 239-

6615. 

Issued in Austin, Texas, on September 23, 2009. 
STATE OF TEXAS AIR QUALITY IMPLEMENTATION PLAN 

FOR THE CONTROL OF OZONE AIR POLLUTION 

DALLAS/FORT WORTH 1997 EIGHT -HOUR OZONE NONA TTAINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

Dallas-Fort Worth Reasonably Available Control Technology Update, 

30 Texas Administrative Code Chapter 117 Rule Revision Noninterference Demonstration, 

and Attainment Demonstration Contingency Plan State Implementation Plan Revision 

TCEQ PROJECT NO. 2009-021-SIP-NR 

Proposed September 23, 2009 
This page intentionally left blank. 
DFW RACT, Rule, and Contingency SIP Revision 

EXECUTIVE SUMMARY 

This Dallas-Fort Worth (DFW) Reasonably Available Control Technology (RACT) Update, 30 

Texas Administrative Code (T A C) Chapter 117 Rule Revision Noninterference Demonstration, 

and Attainment Demonstration Contingency Plan State Implementation Plan (SIP) Revision 

(DFW RACT, Rule, and Contingency SIP Revision) proposes changes to the State of Texas Air 

Quality Implementation Plan for the Control of Ozone Air Pollution. This SIP revision proposes 

to integrate several actions applicable to the DFW 1997 eight-hour ozone standard nonattainment 

area (Dallas, Denton, Tarrant, Collin, Parker, Johnson, Ellis, Kaufman, and Rockwall Counties) 

into the DFW 1997 eight-hour ozone attainment demonstration and the Texas SIP upon adoption 

by the Texas Commission on Environmental Quality (TCEQ). 

This DFW RACT, Rule, and Contingency SIP Revision proposes several revisions to the DFW 

1997 eight-hour ozone attainment demonstration. As required by the 1990 Federal Clean Air Act 

(FCAA) Amendments under§§ 172(c)(l), l82(b)(2) and I82(t), an updated RACT determination 

for the DFW area that documents the state's RACT analysis of I l control technique guidelines 

(CTG) documents issued between 2006 and 2008 by the EPA is proposed. In addition to the 

RACT update, this SIP revision proposes to incorporate the associated 30 T AC Chapter I I 5 and 

30 T AC Chapter 117 rule revision proposals into the Texas SIP. The Chapter I IS rulemaking 

proposed concurrently with this SIP revision would revise rules governing offset lithographic 

printing emission sources. That rulemaking resulted from the state's RACT determination 

regarding offset lithographic printing sources upon its analysis of the CTG document for that 

emission source category. The Chapter I I7 rulemaking proposed August I3, 2009, addresses a 

petition filed by the Elk Corporation of Texas and approved by the commission in February 2009. 

That rulemaking proposes to expand a specific and limited exemption from Chapter 117 

stationary source rules. Finally, this DFW RACT, Rule, and Contingency SIP Revision proposes 

modifications to the DFW attainment demonstration contingency plan. This revision proposes 

removal and replacement of a Chapter 115 rule contingency measure because the rule is being 

revised for RACT purposes. 

This DFW RACT, Rule, and Contingency SIP Revision demonstrates that the Chapter I 17 rule 

revision will not interfere with the DFW 1997 eight-hour ozone attainment demonstration. 

Nitrogen oxides (NOx) emission reductions are identified to replace reductions that would no 

longer be available for the area's ozone control strategy upon adoption of the Chapter I I 7 rule 

rev1s1on. Replacement reductions from fleet turnover (occurring 2009 through 2010) are 

allocated for use in the attainment demonstration to replace the NOx reduction that would not 

materialize if the exemption is expanded as proposed in the Chapter 1 I 7 rulemaking. Because 

replacing the NOx reduction in the control strategy will maintain the integrity of the attainment 

demonstration, the adoption of the Chapter 117 rule revision will not interfere with the DFW 

1997 eight-hour ozone attainment demonstration. 

As required by the FCAA, the measures identified in the proposed contingency plan will continue 

to meet the three percent emissions reduction requirement from the 1999 adjusted base year 

emissions inventory used to develop the May 2007 DFW AD SIP Revision. This revision 

removes the offset lithographic printing rule contingency measure, because the RACT update 

analysis revealed the need for a proposed rule revision applicable to those sources. This revision 

proposes a reallocation to the contingency plan of reductions predicted to result from the 2009 

through 20IO mobile source fleet turnover. The proposed contingency plan contains an increased 

portion of the fleet turnover reductions to make up the difference for reductions lost to the area's 

contingency plan upon removal of the offset lithographic printing contingency measure. The 

Proposed September 23, 2009 
DFW RACT, Rule, and Contingency SIP Revision 

removal of the offset lithographic printing rule contingency measure would not adversely affect 

the DFW area's demonstration of attainment, since replacement reductions are identified. In 

addition to the fleet turnover, two previously identified contingency measures will remain in the 

plan. Those two measures are the state VOC rules, applicable in Collin, Dallas, Denton, and 

Tarrant Counties, to the degassing or cleaning processes of stationary, marine, and transport 

vessels, and to petroleum-based dry cleaning businesses. 

Proposed September 23, 2009 ii 
DFW RACT, Rule, and Contingency SIP Revision 

SECTION V: LEGAL AUTHORITY 

A. General 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state's air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon's 

Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 

1989, 1991, 1993, 1995, 1997, 1999,2001,2003,2005,2007, and 2009. In 1989, the TCAA was 

codified as Chapter 382 of the Texas Health & Safety Code. 

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September I, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the 

general provisions, organization, and general powers and duties of the TNRCC, and the 

responsibilities and authority of the executive director. This chapter also authorizes the TNRCC 

to implement action when emergency conditions arise, and to conduct hearings. Chapter 7 gives 

the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence 

of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Environmental Quality (TCEQ). In 2009, the 81 sr Texas Legislature, during a 

special session, amended section 5.014 ofthe Texas Water Code, changing the expiration date of 

the TCEQ to September 1, 201 I, unless continued in existence by the Texas Sunset Act. 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state's air and to control the quality of the state's air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring requirements; 

to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate 

rules; to issue orders taking into consideration factors bearing upon health, welfare, social and 

economic factors, and practicability and reasonableness; to conduct hearings; to establish air 

quality control regions; to encourage cooperation with citizens' groups and other agencies and 

political subdivisions of the state as well as with industries and the federal government; and to 

establish and operate a system of permits for construction or modification of facilities. 

Local government authority is found in Subchapter E of the TCAA. Local governments have the 

same power as the TCEQ to enter property and make inspections. They also may make 

recommendations to the commission concerning any action of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission. 

Proposed September 23, 2009 iii 
DFW RACT, Rule, and Contingency SIP Revision 

Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and maintain 

the NAAQS; establish gasoline volatility and low emission diesel standards; and fund and 

authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated 

vehicle retirement programs. 

B. Applicable Law 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes 

All sections of each subchapter are included, unless otherwise noted. 

TEXAS HEALTH & SAFETY CODE, Chapter 382 

TEXAS WATER CODE 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A: General Provisions 

Subchapter 8: Organization of the Texas Natural Resource 

Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the Commission 

Subchapter E: Administrative Provisions for Commission 

Subchapter F: Executive Director (except§§ 5.225, 5.226, 5.227, 

5.2275, 5.231, 5.232, and 5.236) 

Subchapter H: Delegation of Hearings 

Subchapter 1: Judicial Review 

Subchapter J: Consolidated Permit Processing 

Subchapter L: Emergency and Temporary Orders(§§ 5.514, 5.5145, 

and 5.515 only) 

Subchapter M: Environmental Permitting Procedures(§ 5.558 only) 

Chapter 7: Enforcement 

Subchapter A: General Provisions(§§ 7.001, 7.002, 7.0025, 7.004, 

and 7.005 only) 

Subchapter 8: Corrective Action and Injunctive Relief(§ 7.032 only) 

Subchapter C: Administrative Penalties 

Subchapter D: Ci vii Penalties (except § 7 .109) 

Subchapter E: Criminal Offenses and Penalties: §§ 7.177, 7.179-7.183 

Rules 

All of the following rules are found in 30, Texas Administrative Code, 

as of the following effective dates: 

Chapter 7: Memoranda of Understanding,§§ 7.110 and 7.119 

Chapter 19: Electronic Reporting 

Proposed September 23, 2009 iv 

September I, 2009 

September 1, 2009 

May 2, 2002 

March I, 2007 
DFW RACT, Rule, and Contingency SIP Revision 

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amen9ment of Permit Conditions July 20, 2006 

Chapter 39: Public Notice, §§ 39.201; 39.401; 39.403(a) and (b)(8)-(l0); 

39.405(f)(l) and (g); 39.409; 39.411 (a), (b)(l)-(6), and (8)-(10) and 

(c)(l)-(6) and (d); 39.413(9), (11), (12), and (14); 39.418(a) and (b)(3) 

and (4); 39.419(a), (b), (d), and (e); 39.420(a), (b) and (c)(3) and (4); 

39.423 (a) and (b); 39.601-39.605 March 29,2006 

Chapter 55: Requests for Reconsideration and Contested Case Hearings; 

Public Comment, §§ 55.1; 55.21(a)- (d), (e)(2), (3), and (12), (f) and 

(g); 55.101(a), (b), and (c)(6)- (8); 55.103; 55.150; 55.152(a)(l), (2), 

and (6) and (b); 55.154; 55.156; 55.200; 55.201(a)- (h); 55.203; 

55.205; 55.209, and 55.211 March 29, 2006 

Chapter 101: General Air Quality Rules January 1, 2009 

Chapter 106: Permits by Rule, Subchapter A June 30, 2004 

Chapter 111: Control of Air Pollution from Visible Emissions and 

Particulate Matter July 19, 2006 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants 

and for Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles June 26, 2008 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007 

Chapter 116: Permits for New Construction or Modification May 29, 2008 

Chapter 117: Control of Air Pollution by Control of Air Pollution from 

Nitrogen Compounds March 4, 2009 

Chapter 118: Control of Air Pollution Episodes March 5, 2000 

Chapter 122: § 122.122: Potential to Emit December 11,2002 

Chapter 122: § 122.215: Minor Permit Revisions June 3, 2001 

Chapter 122: § 122.216: Applications for Minor Permit Revisions June 3, 2001 

Chapter 122: § 122.217: Procedures for Minor Permit Revisions December 11, 2002 

Chapter 122: § 122.218 Minor Permit Revision Procedures for Permit 

Revisions Involving the Use of Economic Incentives, Marketable 

Permits, and Emissions Trading June 3, 2001 

Proposed September 23, 2009 v 
DFW RACT, Rule, and Contingency SIP Revision 

SECTION VI. CONTROL STRATEGY 

A. Introduction (No revision) 

B. Ozone (Revision) 

1. Dallas-Fort Worth (Revision) 

2. Houston-Galveston-Brazoria (No revision) 

3. Beaumont-Port Arthur (No revision) 

4. El Paso (No revision) 

5. Regional Strategies (No revision) 

6. Northeast Texas (No revision) 

7. Austin Area (No revision) 

8. San Antonio Area (No revision) 

C. Particulate Matter (No revision) 

D. Carbon Monoxide (No revision) 

E. Lead (No revision) 

F. Oxides ofNitrogen (No revision) 

G. Sulfur Dioxide (No revision) 

H. Conformity with the National Ambient Air Quality Standards (No revision) 

I. Site Specific (No revision) 

J. Mobile Sources Strategies (No revision) 

K. Clean Air Interstate Rule (No revision) 

L. Transport (No revision) 

M. Regional Haze (No revision) 

Proposed September 23, 2009 vi 
DFW RACT, Rule, and Contingency SIP Revision 

LIST OF ACRONYMS 

ACT-- Alternative Control Techniques 

AD -- Attainment Demonstration 

AF -- Air-to-Fuel 

APU -- Auxiliary Power Units 

ARPDB -- Acid Rain Program Data Base 

A TCM- Airborne Toxic Control Measure 

auto-GC --Automated Gas Chromatograph 

BACT -- Best Available Control Technology 

BCCA-AG -- Business Coalition for Clean Air-Appeal Group 

BMP -- Best Management Practices 

BPA --Beaumont-Port Arthur 

Btulhr -- British Thermal Units per Hour 

Btu/scf -- British Thermal Units per Standard Cubic Feet 

CAE -- Cetane Additive Enhanced Diesel Fuel 

CAIR -- Clean Air Interstate Rule 

CAMx -- Comprehensive Air Model with Extensions 

CARB -- California Air Resources Board 

CBD -- Houston's Central Business District 

CFR -- Code of Federal Regulations 

CMAQ -- Congestion Mitigation and Air Quality 

CO -- Carbon Monoxide 

CTG -- Control Technique Guidelines 

DECS -- Diesel Emission Control Strategy 

DERC -- Discrete Emission Reduction Credits 

DFW -- Dallas-Fort Worth 

DFW AD SIP - DFW Attainment Demonstration SIP revision 

DPM -- Diesel Particulate Matter 

DRRP -- Diesel Risk Reduction Program 

DV -- Design Value 

DYe-- Current Design Value 

DVf -- Future Design Value 

EAC -- Early Action Compact 

EDMS -- Emissions and Dispersion Modeling System 

E-GRID-2007 -- Emissions and Generation Resource Integrated Database 

EEIRE -- Energy Efficiency/Renewable Energy 

EGAS -- Economic Growth Analysis System 

EGF -- Electric Generating Facilities 

EGU -- Electric Generating Units 

EI -- Emissions Inventory 

EPA -- United States Environmental Protection Agency 

EPS3 -- Emissions Processing System, version 3 

ERC -- Emission Reduction Credits 

ERCOT -- Electric Reliability Council of Texas 

ESAD -- Emission Specification for Attainment Demonstration 

ESL --Energy Systems Laboratory, the Texas A&M University System 

F -- Fahrenheit 

FAA-- Federal Aviation Administration 

FCAA --Federal Clean Air Act 

Proposed September 23, 2009 vii 
DFW RACT, Rule, and Contingency SIP Revision 

FCV --Fuel Cell Vehicle 

FGR -- Flue Gas Recirculation 

FHWA --Federal Highway Administration 

FR -- Federal Register 

FT -- Fischer-Tropsch Diesel Fuel 

GIS -- Geographic Information System 

GloBEIS --Global Biosphere Emissions and Interactions System 

gpm -- Gallons per Minute 

GTM --Gross Ton Mile 

HAP -- Hazardous Air Pollutant 

HARC -- Houston Advanced Research Center 

HOT-- Heavy-Duty Truck 

ijECT --Highly Reactive Volatile Organic Compound Emissions Cap and Trade Program 

HGB --Houston-Galveston-Brazoria 

H-GAC -- Houston-Galveston Area Council 

· HOV --High Occupancy Vehicle 

hp -- Horsepower 

HPMS -- Highway Performance Monitoring System 

HRVOC- Highly Reactive Volatile Organic Compound 

HSC -- Houston Ship Channel 

IC -- Internal Combustion 

ICI -- Industrial, Commercial, and Institutional 

IECC -- International Energy Conservation Code 

1/M -- Inspection and Maintenance 

km -- Kilometer 

Kvs -- Vertical Exchange Coefficient 

LAER -- Lowest Achievable Emission Rate 

lb/MMBtu -- Pound per Million British Thermal Units 

LDAR -- Leak Detection and Repair 

LIDIR -- Light Detection and Ranging 

LDEQ -- Louisiana Department of Environmental Quality 

LDGV --Light-Duty Gasoline Vehicle 

LOT-- Light-Duty Truck 

LDV --Light-Duty Vehicle 

LED -- Low Emission Diesel 

LEV-- Low Emission Vehicle 

LEV II-- California's Low Emission Vehicle II Program 

LIRAP -- Low Income Repair and Assistance Program 

LNB --Low Nitrogen Oxides (NOx) Burners 

LNC -- Low Nitrogen Oxides (NOx) Combustors 

LNG -- Liquefied Natural Gas 

L TO -- Landing and Take-Off 

MACT --Maximum Achievable Control Technology 

Mcf --Thousand Cubic Feet 

MCR -- Mid-Course Review 

MDPV --Medium-Duty Passenger Vehicle 

MECT -- Mass Emissions Cap and Trade Program 

MM5 -- Fifth Generation Meteorological Model 

MMBtulhr -- Million British Thermal Units per Hour 

MMcf --Million Cubic Feet 

MMS -- Minerals Management Service 

Proposed September 23, 2009 viii 
DFW RACT, Rule, and Contingency SIP Revision 

MOA -- Memorandum of Agreement 

MON -- Miscellaneous Organic National Emission Standards for Hazardous Air Pollutants 

(NESHAP) 

mph -- miles per hour 

MVEB --Motor Vehicle Emissions Budget 

MW --Megawatts 

MY-- Model Year 

NAAQS -- National Ambient Air Quality Standard 

NCTCOG - North Central Texas Council of Governments 

NEGF --Non-Electric Generating Facility 

NEI -- National Emissions Inventory 

NESHAP -- National Emission Standards for Hazardous Air Pollutants 

ng!J --Nanogram per Joule 

NMIM -- National Mobile Inventory Model 

NOAA -- National Oceanic and Atmospheric Administration 

Non-EGU --non-Electric Generating Unit 

NOx -- Nitrogen Oxides 

NOy -- Nitrogen Species 

NSCR -- Non-Selective Catalytic Reduction 

NTRD -- New Technology Research and Development Program 

0 3 -- Ozone 

OGV -- Ocean-Going Vessel 

PAYD --Pay As You Drive 

PBL --Planetary Boundary Layer 

PEl -- Periodic Emissions Inventory 

PERP -- Portable Engine Registration Program 

PiG -- Plume-in-Grid 

PM -- Particulate Matter 

PM2.s -- Particulate Matter 2.5 microns and less 

ppb --Parts Per Billion 

ppbC -- Parts Per Billion Carbon 

ppbv -- Parts Per Billion by Volume 

ppm -- Parts Per Million 

PSCF --Potential Source Contribution Factors 

PSDB -- Point Source Database 

psia -- Pounds per Square Inch Absolute 

PUC -- Public Utility Commission 

RACT -- Reasonably Available Control Technology 

RACM --Reasonably Available Control Measure 

RFP --Reasonable Further Progress 

RMSE -- Root Mean Square Error 

ROP -- Rate-of-Progress 

RRF -- Relative Reduction Factor 

SB --Senate Bill 

SCAQMD -- South Coast Air Quality Management District 

scfm -- Standard Cubic Feet per Minute 

SCR -- Selective Catalytic Reduction 

SEP -- Supplemental Environmental Programs 

SETPMTC -- Southeast Texas Photochemical Modeling Technical Committee 

SIC -- Standard Industrial Classification 

SIP-- State Implementation Plan 

Proposed September 23, 2009 ix 
DFW RACT, Rule, and Contingency SIP Revision 

SNCR -- Selective Non-Catalytic Reduction 

SOY-- Single Occupancy Vehicle 

STP -- Surface Transportation Program 

SWCV --Solid Waste Collection Vehicle 

T AC -- Texas Administrative Code 

T ACB -- Texas Air Control Board 

TCAA -- Texas Clean Air Act 

TCEQ --Texas Commission on Environmental Quality (commission) 

TCM -- Transportation Control Measure 

TOM -- Travel Demand Model 

TERP -- Texas Emission Reduction Plan 

TexAQS 2000 -- Texas Air Quality Study 2000 

TexAQS II-- Texas Air Quality Study 2006 

TKE -- Turbulent Kinetic Energy 

TNMHC -- Total Non-methane Hydrocarbon 

TNRCC -- Texas Natural Resource Conservation Commission 

tpd --tons per day 

tpy -- tons per year 

TSE -- Truck Stop Electrification 

TTl-- Texas Transportation Institute 

TUC --Texas Utility Code 

TxDOT --Texas Department of Transportation 

TxLED -- Texas Low Emission Diesel 

USC-- United States Code 

VMEP --Voluntary Mobile Source Emissions Reduction Program 

VMT --Vehicle Miles Traveled 

VOC -- Volatile Organic Compound 

VRU --Vapor Recovery Unit 

ZEB -- Zero Emission Bus 

ZEV -- Zero Emissions Vehicle 

Proposed September 23, 2009 X 
DFW RACT, Rule, and Contingency SIP Revision 

IDENTIFICATION OF REFERENCED DOCUMENTS 

Throughout this document, references are made to this SIP revision, to other SIP revisions, and to 

composites of SIP revisions and SIP-related documents. In order to clarify and more clearly 

define the references contained in this document, the list below identifies and provides additional 

information for each. The referenced documents may be directly accessed from the links 

provided. 

May 2007 DFW AD SIP Revision, and DFW 1997 Eight-Hour Ozone AD SIP Revision, both 

refer to: 

The Dallas-Fort Worth (DFW) Ozone Nonattainment Area Attainment Demonstration (AD) 

State Implementation Plan (SIP) Revision for the 1997 Eight-Hour Ozone Standard 

(TCEQ Project No. 2006-013-SIP-NR, adopted May 2007) 

April 2008 supplement to the DFW 1997 Eight-Hour Ozone AD SIP Revision refers to: 

A TCEQ Jetter to the EPA of April 23, 2008, that provides clarification and supplemental 

information regarding the May 2007 DFW AD SIP Revision 

Related document: A March 7. 2008, Jetter from the EPA to the TCEQ requesting 

supplemental information for clarification of the May 2007 DFW AD SIP Revision 

DFW AD SIP Contingency Plan Revision refers to: 

The DFW AD SIP Revision for the 1997 Eight-Hour Ozone Standard (Contingency Measures 

Plan) 

(TCEQ Project No. 2008-016-SIP-NR, adopted November 2008) 

DFW AD SIP DERC Program Revision refers to: 

The DFW AD SIP Revision for the 1997 Eight-Hour Ozone Standard (Discrete Emission 

Reduction Credits (DERC) Program) 

(TCEQ Project No. 2008-016-SIP-NR, adopted December 2008) 

DFW RACT, Rule, and Contingency SIP Revision refers to this SIP revision document: 

The DFW Reasonably Available Control Technology (RACT) Update, 30 Texas 

Administrative Code (T A C) Chapter 117 Rule Revision Noninterference Demonstration, and 

Attainment Demonstration Contingency Plan SIP Revision 

(TCEQ Project No. 2009-021-SIP-NR, proposed September 23, 2009) 

DFW 1997 eigbt-bour ozone attainment demonstration refers to: 

The Texas SIP revisions relative to the DFW nine-county nonattainment area (Dallas, 

Denton, Tarrant, Collin, Ellis, Kaufman, Rockwall, Parker, and Johnson Counties) 

demonstration of attainment for the 1997 eight-hour ozone NAAQS, comprised of the 

following documents: the May 2007 DFW AD SIP Revision (also called the DFW 1997 

Eight-Hour Ozone AD SIP Revision), the April 2008 supplement to the DFW 1997 EightHour Ozone AD SIP Revision, the DFW AD SIP Contingency Plan Revision, the DFW AD 

SIP DERC Program Revision, and (pending adoption) this DFW RACT, Rule, and 

Contingency SIP Revision. 

Tbe Texas SIP refers ·to: 

The SIP revisions that make up the State of Texas Air Quality Implementation Plan for the 

Control of Ozone Air Pollution 

Proposed September 23, 2009 xi 
DFW RACT, Rule, and Contingency SIP Revision 

TABLE OF CONTENTS 

Executive Summary 

List of Acronyms 

Identification of Referenced Documents 

Table of Contents 

List of Tables 

Chapter I. Background and Introduction 

1.1. General (Revision) 

1.2. Health Effects (No revision) 

1.3. Public/Stakeholder Participation (Revision) 

1.4. Social and Economic Considerations (Revision) 

1.5. Fiscal and Manpower Resources (No revision) 

Chapter 2. · Photochemical Modeling (No revision) 

Chapter 3. Corroborative Analysis (No revision) 

Chapter 4. Required Control Strategy Elements 

4.1. Overview of Existing Control Strategies (No revision) 

4.2. Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC) Control Measures 

4.2.1. VOC Control Measures (Revision) 

4.2.1.1. Background (Addition) 

4.2.1.2. Proposed 30 Texas Administrative Code (T A C) Chapter 115 VOC Rule 

Revision (Addition) 

4.2.2. NOx Control Measures 

4.2.2.1. Major Source NOx Reductions 

4.2.2.1.1. Industrial, Commercial, and Institutional (ICI) Sources (Revision) 

4.2.2.1.1.1. Background (Addition) 

4.2.2.1.1.2. Proposed 30 T AC Chapter 117 Rule Revision (Addition) 

4.2.2.1.1.3. Demonstration ofNoninterfereance (Addition) 

4.2.2.2. - 4.2.2.4. (No revision) 

4.2.3. -4.2.7. (No revision) 

4.3. Reasonably Available Control Technology (RACT) Analysis (Revision) 

4.3.1. DFW VOC RACT Analysis Update (Addition) 

4.3.1. I. CTG Document Recommendations Not Applicable to the DFW Area (Addition) 

4.3.1.2. CTG Document Recommendations that Do Not Represent RACT for the DFW 

Area (Addition) 

4.3.1.3. CTG Document Recommendations for which RACT Determinations are Not 

Being Made (Addition) 

4.3.1.4. CTG Document Recommendations that Represent RACT for the DFW Area 

(Addition) 

4.4. Reasonably Available Control Measures (RACM) Analysis (No revision) 

4.5. Motor Vehicle Emissions Budget (MVEB) (No revision) 

4.6. Contingency Measures (Revision) 

4.6.1. Background 

4.6.2. Revised DFW 1997 Eight-Hour Ozone Failure-to-Attain Contingency Plan 

(Addition) 

4.6.3. Allocation of the June 2009 through 2010 fleet turnover reductions (Addition) 

Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update 

Proposed September 23, 2009 xii 
Number 

Table 4.1 

Table 4.2 

Table 4.3 

DFW RACT, Rule, and Contingency SIP Revision 

LIST OFT ABLES 

Table Name 

Emission Reductions Provided by Proposed Contingency Plan 

Calculations Showing Three Percent Required Reductions 

Allocation of Emission Reductions from the 2009 through 2010 Fleet Turnover 

Proposed September 23, 2009 xiii 
DFW RACT, Rule, and Contingency SIP Revision 

CHAPTER1. BACKGROUNDANDINTRODUCTION 

1.1. GENERAL (Revision) 

The "History of the Texas State Implementation Plan (SIP)," a comprehensive overview of SIP 

revisions submitted to the United States Environmental Protection Agency (EPA) by the State of 

Texas is viewable on the Texas Commission on Environmental Quality's (TCEQ) Web Site, at; 

http://www.tceq.state.tx.us/assets/public/implt;imentation/air/sip/miscdocs/SIPHistory updated.pdf 

The Dallas-Fort Worth (DFW) Ozone Nonattainment Area Attainment Demonstration (AD) SIP 

Revision for the 1997 Eight-Hour Ozone Standard, also called the DFW 1997 Eight,.Hour Ozone 

AD SIP Revision or May 2007 DFW AD SIP Revision, was adopted by the TCEQ in May 2007 

and subsequently submitted to the EPA. The DFW nonattainment counties include Dallas, 

Denton, Tarrant, Collin, Parker, Johnson, Ellis, Kaufman, and Rockwall. During the EPA's 

review of that SIP submittal, a March 7, 2008, letter from the EPA to the TCEQ requested 

clarification and additional information applicable to the DFW 1997 Eight-Hour Ozone AD SIP 

Revision. A TCEQ letter to the EPA of April 23. 2008, (referred to as the April 2008 Supplement 

to the DFW 1997 Eight-Hour Ozone AD SIP Revision) provided additional information to clarify 

and support the DFW 1997 Eight-Hour Ozone AD SIP Revision to the EPA. 

Upon review of the April 2008 Supplement to the DFW 1997 Eight-Hour Ozone AD SIP 

Revision, the EPA requested that the TCEQ implement an enforceable mechanism to limit the use 

of Discrete Emission Reduction Credits (DERCs) in the nine-county DFW eight-hour ozone 

nonattainment area, consistent with attainment and maintenance of the 1997 eight-hour ozone 

National Ambient Air Quality Standard (NAAQS). The EPA asked the state to revise the DFW 

1997 Eight-Hour Ozone AD SIP Revision to provide additional emissions reductions sufficient to 

meet contingency plan mandates of the Federal Clean Air Act (FCAA), and to implement a rule 

limiting DERC use in the DFW area. In June 2008, the TCEQ informed the EPA of its intention 

to propose a revised contingency plan as well as DERC SIP and rule revisions to satisfy the EPA 

requests. 

In July 2008, the EPA proposed a conditional approval of the DFW 1997 Eight-Hour Ozone AD 

SIP Revision. The DFW AD SIP Contingency Plan Revision, adopted by the commission and 

submitted to the EPA in November 2008, revised the attainment demonstration contingency plan. 

That revised plan identified four measures to provide reductions in the event the DFW area fails 

to meet its June IS, 2010, deadline for attainment of the 1997 eight-hour ozone standard. Three 

previously identified volatile organic compounds (VOC) rule contingency measures (applicable 

to offset lithographic printing, petroleum-based dry cleaning, and degassing or cleaning processes 

of stationary, marine, and transport vessels) and the 2009 through 20 I 0 fleet turnover completed 

the DFW attainment demonstration contingency plan. 

Effective February 13, 2009, the EPA published a final conditional approval of the DFW 

nonattainment area's 1997 eight-hour ozone attainment demonstration, as submitted in the May 

2007 DFW AD SIP Revision and April 2008 Supplement, and as revised in the DFW AD SIP 

Contingency Plan Revision. Both the contingency plan and the VOC reasonably available control 

technology (RACT) analysis elements of the attainment demonstration were deemed adequate, 

and both were given final approval by the EPA. Final full approval of the attainment 

demonstration was withheld, pending the EPA's approval of the SIP and rule revisions to provide 

the enforceable mechanism to limit DERC use in the DFW area consistent with the 1997 eighthour ozone attainment demonstration. 

Proposed September 23, 2009 1-1 
DFW RACT, Rule, and Contingency SIP Revision 

The commission adopted the DFW AD SIP DERC Program Revision and submitted it to the EPA 

in December 2008. That SIP revision and the corresponding DERC rule revision together 

addressed the EPA condition for final approval of the attainment demonstration, limiting DERC 

use in 2009 and subsequent calendar years consistent with the area's attainment of the 1997 eighthour ozone standard. Accordingly, the DFW AD SIP DERC Program Revision incorporated the 

adopted revised DERC rule in 30 Texas Administrative Code (TAC) Chapter 101, and 

implemented a required annual review by the TCEQ executive director. The annual review of 

banked credits and requests to use DERCs will be evaluated in light of the attainment 

demonstration to determine annual DERC use limitations and subsequently apportion DERC 

allowables for use within the nine-county DFW area. The DFW AD SIP DERC Program 

Revision and the DERC rule revision are both currently under review by the EPA. 

This DFW RACT Update, 30 TAC Chapter 117 Rule Revision Noninterference Demonstration, 

and Attainment Demonstration Contingency Plan SIP Revision (DFW RACT, Rule, and 

Contingency SIP Revision) proposes revisions to the DFW 1997 eight-hour ozone attainment 

demonstration, and as a result, the Texas Air Quality Implementation Plan for the Control of 

Ozone Air Pollution. Also called the DFW RACT, Rule, and Contingency SIP Revision, this 

revision proposes several actions. First, it updates the EPA-approved VOC RACT analysis 

determination element of the attainment demonstration to include the state's analysis of control 

technique guidelines (CTG) documents issued by the EPA in 2006, 2007, and 2008. Those CTGs 

were not addressed in the May 2007 DFW AD SIP Revision; however, the Federal Clean Air Act 

(FCAA) requires states to address these. Documentation of a DFW VOC RACT update analysis 

and the TCEQ determinations regarding the CTG recommendations is provided in Chapter 4, 

Required Control Strategy Elements, of this SIP revision and in Appendix A: Dallas-Fort Worth 

Reasonably Available Control Technology Analysis Update. 

In addition to the RACT update, the DFW RACT, Rule, and Contingency SIP Revision proposes 

inclusion of associated 30 T AC Chapter 115 and 30 T AC Chapter 117 rule revisions into the 

Texas SIP. The Chapter 115 rulemaking proposal is based on the RACT analysis update 

contained in this SIP revision. In its review, staff determined that some of the recommendations 

made in the EPA's Offset Lithographic and Letterpress Printing CTG represent RACT for the 

DFW area. Concurrent with this SIP revision, the TCEQ is proposing the Chapter 115 

rulemaking (TCEQ Rule Project 2008-019-115-EN) to limit the VOC content of solvents used by 

offset lithographic printing facilities in the DFW area. The rulemaking proposes to implement 

the EPA's recommendation to reduce fountain solution and cleaning material VOC contents, and 

further expands applicability to smaller sources not already subject to the rule. Discussion 

concerning RACT determinations regarding heatset press and letterpress printing sources is 

provided in Chapter 4, Required Control Strategy Elements, of this SIP revision and in Appendix 

A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update. 

In addition to the VOC RACT update and Chapter 115 rulemaking, this proposed DFW RACT, 

Rule, and Contingency SIP Revision proposes inclusion of an associated Chapter 117 rule 

revision, proposed by the commission on August 12, 2009, into the Texas SIP. The Chapter 117 

rule proposal responds to a petition for rulemaking filed by the Elk Corporation of Texas and 

approved by the commission on January 28, 2009. The rulemaking proposes to exempt, from 

Chapter 117 rules, low temperature drying and curing ovens used in mineral wool-type fiberglass 

manufacturing and wet-laid, non-woven fiber mat manufacturing where nitrogen-containing 

resins or other additives are used. 

The proposed expansion of a Chapter 117 rule exemption could reduce the predicted nitrogen 

oxides (NOx) reductions from Chapter 117 rules for the DFW area by up to 0.1 tons per day 

Proposed September 23, 2009 1-2 
DFW RACT, Rule, and Contingency SIP Revision 

(tpd). This SIP revision proposes that 0.1 tpd NOx portion of uncommitted surplus emission 

reductions from the 2009 through 20 I 0 vehicle fleet turnover be used as the replacement 

reduction. The reduction replacement serves to maintain integrity of the DFW 1997 eight-hour 

ozone attainment demonstration, providing the required demonstration of noninterference 

proposed in this SIP revision. 

As a final action, this DFW RACT, Rule, and Contingency SIP Revision proposes a modified 

contingency plan for the area's 1997 eight-hour ozone attainment demonstration. Removal ofthe 

offset lithographic printing rule contingency measure from the contingency plan is proposed 

because a revision of that Chapter I 15 rule for RACT purposes is also being proposed. This SIP 

revision proposes to replace the measure with a portion of the emission reductions predicted from 

vehicle fleet turnover for the one-year period beginning June 15, 2009. The fleet turnover 

contingency measure would provide VOC reductions sufficient to replace reductions removed 

from the contingency plan along with the offset lithographic printing measure. The proposed 

contingency plan retains two state VOC rule contingency measures previously identified for the 

DFW area applicable to petroleum-based dry cleaning, and degassing or cleaning processes of 

stationary, marine, and transport vessels. Additional information about these measures and the 

proposed contingency plan is contained in Chapter 4, Required Control Strategy Elements, of this 

SIP revision. As proposed in this SIP revision, emission reductions to result from the two 

remaining state VOC rule contingency measures together with the allotment for contingency of 

emission reductions from the 2009 through 20 I 0 fleet turnover will provide a total three percent 

emissions reduction to the DFW attainment demonstration's 1999 adjusted base year emissions 

inventory. 

The 0.1 tpd NOx reduction replacement in the control strategy will not interfere with the DFW 

area's attainment demonstration. The 2009 through 2010 vehicle fleet turnover will provide 

sufficient reductions to offset the possible 0.1 tpd NOx emission increase from Chapter I I 7 rule 

exemption expansion. The reductions from fleet turnover will also provide the emission 

reductions needed to replace the offset lithographic printing rule contingency measure. After the 

reduction replacements are complete, 7.42 tpd NOx emission reductions from the 2009 through 

2010 vehicle fleet turnover will remain surplus and available for other future SIP purposes. The 

proposed allocation of the fleet turnover reductions is provided in Table 4.3: Allocation of 

Emission Reductions from the 2009 through 2010 Fleet Turnover, and further described in 

Chapter 4, Required Control Strategy Elements, of this SIP revision. 

Commission adoption of this DFW RACT, Rule, and Contingency SIP Revision would further 

supplement the DFW I 997 eight-hour ozone attainment demonstration by incorporating the VOC 

RACT update, the associated Chapter 115 and Chapter I I 7 rule revisions, and the contingency 

plan. Additional information about each of the actions proposed in this DFW RACT, Rule, and 

Contingency SIP Revision is contained in Chapter 4, Required Control Strategy Elements, of this 

document. 

There are no outstanding SIP requirements for the DFW area under the one-hour ozone NAAQS. 

A final rule published in the Federal Register by the EPA on October 16, 2008, (73 FR 6I357) 

describes the EPA determination that, effective November I7, 2008, the DFW one-hour ozone 

nonattainment area (consisting of Dallas, Denton, Collin, and Tarrant Counties) has attained the 

one-hour ozone standard. This determination was based on the EPA's review of certified ambient 

air monitoring data showing attainment of the one-hour ozone NAAQS for the 2004 through 2006 

period. The one-hour ozone standard attainment determination was further supported by EPA's 

review of quality-controlled, quality-assured ozone data for 2007 and 2008. Due to the area's 

one-hour ozone standard attainment, the EPA determined that all requirements to submit any 

Proposed September 23, 2009 1-3 
DFW RACT, Rule, and Contingency SIP Revision 

demonstration of attainment, Five Percent Increment of Progress (lOP) plan, reasonable further 

progress (RFP) plan, contingency plan, or other planning SIP revisions related to attainment of 

the one-hour ozone NAAQS, are suspended for as long as the area continues to attain that 

standard. 

1.2. HEALTH EFFECTS (No revision) 

1.3. PUBLICIST AKEHOLDER PARTICIPATION (Revision) 

The commission will hold two public hearings for this proposed SIP revision at the following 

times and locations: 

p:;J;;: ·,'; .. ' .·.TIME : ·.· .. z.' ... . CITY ' ·DA:TE \'. • .. · . LOCATION ;. 

Austin October 29,2009 l :00 P.M. (CST) TCEQ Headquarters 

12100 Park 35 Circle 

Austin, TX 78753 

Building E. Room 201S 

Fort Worth November 2, 2009 2:00 P.M. (CST) TCEQ Region 4 Offices 

2309 Gravel Road 

Fort Worth, TX 76118 

Public Meeting Room 

The comment period will open on October 9, 2009, and close on November 9, 2009. Written 

comments will be accepted via mail, fax, or through the eComments system. All comments 

should reference the "DFW RACT, Rule, and Contingency SIP Revision" and Project 

Number 2009-021-SIP-NR. Comments may be submitted to Mary Ann P. Cook, MC 206, State 

Implementation Plan Team, Chief Engineer's Office, Texas Commission on Environmental 

Quality, P.O. Box 13087, Austin, Texas 78711-3087 or faxed to (512) 239-5687 (Attn. Mary Ann 

P. Cook). Electronic comments may be submitted via the eComments Form for Proposed TCEO 

Rulemakings, at http://www5.tceg.state.tx.us/rules/ecomments. File size restrictions may apply 

to comments being submitted via the eComments system. Comments must be received by 

November 9, 2009. 

Copies of the proposed SIP revision and all appendices can be obtained from the TCEQ's Web 

site at http://www.tceg.state.tx.us/implementation/air/sip/dfw.html. 

Prior to opening each of the public hearings, TCEQ staff will hold a short discussion session 

where interested persons may direct questions to staff and obtain information. For the hearing to 

be held in Austin on October 29, 2009, the preceding discussion session will begin at 12:30 p.m. 

CST and end at I :00 p.m. CST. For the hearing to be held in Fort Worth, the preceding 

discussion period will begin at I :30 p.m. CST and end at 2:00p.m. CST. Also prior to opening 

each hearing, sign-up lists will be made available for interested persons to indicate a desire to 

provide oral comment. In the event no party signs up to speak at a hearing, the hearing will not 

be officially opened. If interested parties sign up to provide comment, a hearing will be officially 

opened and those who signed up to speak will be called upon to provide oral comments. TCEQ 

staff is unable to hold discussions with or answer questions from speakers during public hearings. 

Proposed September 23, 2009 1-4 
DFW RACT, Rule, and Contingency SIP Revision 

Comments on the 30 T AC Chapter 115 and Chapter 117 rule proposals associated with this SIP 

revision will not be addressed by the comments responses for this SIP revision. Only comments 

clearly identified as applicable to this DFW RACT, Rule, and Contingency SIP Revision will be 

addressed in the Response to Comments document for this SIP revision. Instructions for 

submitting comments on the 30 TAC Chapter 115 and Chapter 117 rule proposals are contained 

in the preamble applicable to each ofthose rule proposal packages. 

1.4. SOCIAL AND ECONOMIC CONSIDERATIONS (Revision) 

There are no social or economic issues of concern attributable to this DFW RACT, Rule, and 

Contingency SIP Revision. For a detailed explanation of any social and economic issues 

involved with the associated Chapter 115 and 117 rulemaking, please refer to the preamble in 

each of those proposals. Proposed rulemaking documents may be accessed from the TCEQ 

public Web site rule project information search address, at http://www5.tceg.state.tx.us/rules/. 

TCEQ proposed and adopted rules may be accessed from the Texas Register index on the Texas 

Secretary of State's Web site, located at http://www.sos.state.tx.us/texreg/index.shtml. 

1.5. FISCAL AND MANPOWER RESOURCES (No revision) 

Proposed September 23, 2009 1-5 
DFW RACT, Rule, and Contingency SIP Revision 

CHAPTER 2. PHOTOCHEMICAL MODELING 

(No revision) 

Proposed September 23, 2009 2-1 
DFW RACT, Rule, and Contingency SIP Revision 

CHAPTER3. CORROBORATIVEANALYSIS 

(No revision) 

Proposed September 23, 2009 3-1 
DFW RACT, Rule, and Contingency SIP Revision 

CHAPTER 4. REQUIRED CONTROL STRATEGY ELEMENTS 

4.1. OVERVIEW OF EXISTING CONTROL STRATEGY (No revision) 

4.2. NITROGEN OXIDES (NOx) AND VOLATILE ORGANIC COMPOUNDS (VOC) 

CONTROL MEASURES 

4.2.1. VOC Control Measures (Revision) 

4.2.1.1. Background (Addition) 

Under 42 United States Code (USC), § 7511(b), the United States Environmental Protection 

Agency (EPA) is required to issue Control Techniques Guidelines (CTG) to assist states in 

developing RACT for major sources of volatile organic compounds (VOC) emissions. States can 

adopt and implement the CTG recommendations, or they can adopt alternative approaches, but in 

either event, a RACT demonstration and any rule revisions must be submitted to the EPA for 

review and approval as part of the State Implementation Plan (SIP). The Federal Clean Air Act 

(FCAA) provides that states with ozone nonattainment areas classified as moderate and above 

must revise their ozone SIPs to include requirements for RACT for VOC sources covered by any 

EPA CTG document issued after November 15, 1990, and prior to the date of attainment. The 

Dallas-Fort Worth (DFW) 1997 eight-hour ozone nonattainment area's attainment date is June 

15, 2010. The nine county area includes Dallas, Denton, Tarrant, Collin, Parker, Johnson, Ellis, 

Kaufman, and Rockwall Counties. 

The EPA provided final approval of the volatile organic compounds (VOC) Reasonably 

Available Control Technology (RACT) analysis element ofthe DFW attainment demonstration in 

the conditional approval for the DFW 1997 Eight-Hour Ozone AD SIP Revision (74 FR 1903; 

January 14, 2009). During and shortly after development of that SIP revision, the EPA issued II 

new CTG documents. Texas Commission on Environmental Quality (TCEQ) staff has evaluated 

the new CTG documents to make RACT determinations for the State of Texas and to determine if 

additional VOC controls are necessary to fulfill RACT requirements. Section 4.6, Contingency 

Measures, of this SIP revision further describes the RACT update analysis proposed in this SIP 

revision, and Appendix A: DFW Reasonably Available Control Technology Analysis Update 

provides additional details regarding evaluation of the II CTG recommendation documents. 

The TCEQ has determined that some emission control recommendations in the Offset 

Lithographic and Letterpress Printing CTG document (71 FR 58745, October 5, 2006) represent 

RACT for the DFW area. In offset lithographic printing, VOC emissions result from the 

evaporation of components of the ink, fountain solutions, and cleaning solutions. Fountain 

solutions can account for up to 25 percent of the total VOC emissions from offset lithographic 

printing operations. Cleaning solutions containing organic solvents, used to remove excess 

printing ink oils or unwanted debris from the offset lithographic printing, also contribute to VOC 

emissions. 

4.2.1.2. Proposed 30 Texas Administrative Code (T AC) Chapter 115 VOC Rule Revision 

(TCEQ Rule project 2008-0 19-115-EN) (Addition) 

Concurrent with this SIP revision, the TCEQ is proposing a Chapter 115 rule revision to 

implement new RACT requirements for offset lithographic printing sources in the DFW area, as 

required by the Federal Clean Air Act (FCAA), § 172(c)(l) and § 182(b)(2). The proposed 

Proposed September 23, 2009 4-1 
DFW RACT, Rule, and Contingency SIP Revision 

rulemak.ing implements the 2006 CTG recommendations to limit the VOC content of solvents 

used by offset lithographic printing facilities in the DFW nine-county 1997 eight-hour ozone 

nonattainment area. The proposed rulemak.ing is scheduled for the commission's consideration 

for adoption at the March I 0, 20 I 0, TCEQ agenda. 

The proposed rule revision would amend Chapter 115, Subchapter E, Division 4, to reduce VOC 

content limits of fountain solutions used by offset lithographic printing operations currently 

subject to these rules. The proposed rules would also limit the VOC content of fountain and 

cleaning solutions used in offset lithographic printing operations that are exempt under current 

rules. Existing Chapter 115 rules limit the VOC content of fountain and cleaning solutions used 

by offset lithographic printing lines in the DFW area with combined uncontrolled VOC emissions 

of at least 50 tpy. The proposed rules would expand requirements in the DFW area beginning 

March I, 20 II, to limit the VOC content of fountain and cleaning solutions used by offset 

lithographic printing lines located on a property with combined uncontrolled VOC emissions of at 

least three tpy. 

Because the commission is proposing a revised Chapter I I 5 to include RACT requirements for 

offset lithographic printing sources, the state VOC rule for those sources will no longer be 

available for use as a measure in the DFW attainment demonstration contingency plan. In order 

to maintain integrity of the DFW 1997 eight-hour ozone attainment demonstration, this DFW 

RACT, Rule, and Contingency SIP Revision proposes to modify the contingency plan, to remove 

and replace the state VOC rule offset lithographic contingency measure as more specifically 

described in Section 4.6, Contingency Measures, of this SIP revision. 

Additional information on the proposed rulemak.ing is contained in the preamble for TCEQ Rule 

project 2008-0 19-115-EN. Additional information on the RACT analysis of the Offset 

Lithographic and Letterpress Printing CTG can be found in Appendix A: DFW Reasonably 

Available Control Technology Analysis Update. 

4.2.2. NOx Control Measures 

4.2.2.1. Major Source NOx Reductions 

4.2.2.1.1. Industrial, Commercial, and Institutional (IC/) Sources (Revision) 

4.2.2.1.1.1. Background (Addition) 

Concurrent with adoption of the May 2007 DFW AD SIP Revision, the commission adopted a 

revised 30 TAC Chapter 117, Subchapter B, Division 4 rule for major emission sources on May 

23, 2007. The rule established new emission control requirements, beginning in March I, 2009, 

and March I, 20 I 0, for major industrial, commercial, or institutional (ICI) sources of NOx in the 

DFW 1997 eight-hour ozone nonattainment area Subchapter B, Division 4, requires owners or 

operators of major ICI sources ofNOx in the DFW I997 eight-hour ozone nonattainment area to 

reduce NOx emissions from a wide variety of stationary sources, providing emissions reductions 

to help bring the DFW ozone nonattainment area into compliance with the I 997 eight-hour ozone 

National Ambient Air Quality Standards (NAAQS). 

On December I I, 2008, a petition for rulemak.ing requesting an amendment to Chapter 1 I 7, 

Subchapter B, Division 4, for certain DFW area sources, was filed with the commission. The 

petition (TCEQ Rule Project No. 2009-012-PET-NR), submitted by Brown McCarroll, L.L.P., on 

behalf of Elk Corporation of Texas, requested that the agency initiate rulemak.ing to revise 30 

Proposed September 23, 2009 4-2 
DFW RACT, Rule, and Contingency SIP Revision 

TAC Chapter 117, Subchapter B, § 117.403(a)(l2). The request related to owners and operators 

of low-temperature drying and curing ovens used in mineral wool-type fiberglass manufacturing 

and wet-laid, non-woven fiber mat manufacturing located at major sources in the DFW 1997 

eight-hour ozone nonattainment area. Source categories affected by the petitioners request are 

currently required to comply with Chapter 117 rule requirements by March I, 2010. 

Elk Corporation of Texas operates an asphalt shingle manufacturing plant in Ennis, Texas. In the 

petitioner's manufacturing process, a urea-formaldehyde resin binder is used with other nitrogencontaining compounds on a fiberglass substrate that is then passed through a drying and curing 

oven. This operation results in nitrogen-containing off-gas that is vented through incinerators and 

reacts with oxygen to form NOx. The petitioner asserts that emissions associated with the 

manufacturing process alone makes compliance with the applicable NOx emission specification 

in § 117.41 O(b) of 0.036 pounds per million British thermal unit (lb/MMBtu) infeasible. On 

January 28, 2009, the commission considered and approved the petition for rulemaking. The 

commission issued an order on February 2, 2009, directing the executive director to examine the 

issues in the petition and to initiate rulemaking. 

4.2.2.1.1.2. Proposed 30 TAC Chapter I I 7 Rule revision (TCEQ Rule Project 2009-023-117-

EN) (Addition) 

On August 12, 2009, the TCEQ proposed an amendment to § 117.403 to implement the rule 

changes requested by Elk Corporation of Texas. The proposed rulemaking would amend Chapter 

I I 7, Subchapter B, Division 4, § 117.403 for the DFW eight-hour ozone nonattainment area. It 

would expand the exemption in § 117 .403( a)(l2) to include low-temperature drying ovens and 

curing ovens used in wet-laid, non-woven fiber mat manufacturing as well as in low-temperature 

drying ovens used in mineral wool-type fiberglass manufacturing where nitrogen-containing 

resins or other additives are used. The current§ ll7.403(a)(l2) only exempts curing ovens used 

in mineral wool-type fiberglass manufacturing in which nitrogen-bound chemical additives are 

used. If adopted, the Chapter 117 rule revision would become effective on February 4, 2010. 

This DFW RACT, Rule, and Contingency SIP Revision proposes to incorporate a revised § 

117.403 into the SIP .. 

In 2006, during Chapter 117 rulemaking development for the DFW 1997 ~ight-hour ozone 

nonattainment area. comments were received from Owens Corning pointing out technical 

feasibility issues with controlling NOx emission from curing ovens of this specific operation. In 

response to those comments, a provision was added under § 117.403(a)(l2) to exempt curing 

ovens used in mineral wool-type fiberglass manufacturing in which nitrogen-bound chemical 

additives are used. While the type of manufacturing covered by the proposed rulemaking is 

different from that specified in the current rule exemption, the technical feasibility issue for Elk 

Corporation of Texas is similar to the Owens Corning issue, and is the basis of the current 

exemption in§ 117.403(a)(l2). The addition of nitrogen-bound chemical additives contributes to 

the creation of non-combustion related thermal NOx that cannot be controlled using control 

methodologies identified by the commission as appropriate for curing ovens used in mineral 

wool-type fiberglass manufacturing. 

NOx emissions from curing ovens of this type are small contributors to the total NOx emissions. 

If the Chapter 117 rule revision is adopted, approximately 0.1 tons per day (tpd) of anticipated 

NOx emission reduction will be no longer available to support the DFW 1997 eight-hour ozone 

attainment demonstration. Therefore, a demonstration of noninterference submittal to the EPA is 

required under the FCAA Section II 0(1). 

Proposed September 23,2009 4-3 
DFW RACT, Rule, and Contingency SIP Revision 

4.2.2.1.1.3 Demonstration of Noninterference under FCAA Section 11 0(1) (Addition) 

The estimated 0.1 tpd NOx emission increase and resulting loss to the DFW control strategy that 

would result from the Chapter 117 rule exemption expansion would be insignificant and not 

expected to interfere with the DFW area's attainment of the 1997 ozone standard. However, the 

TCEQ provides this demonstration of noninterference to support the state's assertion that 

expansion of the exemption in§ 117.403(a)(12) as proposed would not negatively impact the 

status of the area's attainment ofthe NAAQS. 

The EPA issued draft guidance on June 8, 2005, titled "Demonstrating Noninterference under 

Section 110(1) of the Clean Air Act When Revising a State Implementation Plan." The guidance 

provides options available for states to demonstrate noninterference in nonattainment areas for 

affected pollutants. One option for demonstrating noninterference is through the substitution of 

measures that provide equivalent or greater emissions reduction/air quality benefits than the 

measure(s) being removed from the SIP. 

The commission proposes to replace the 0.1 tpd NOx reduction from the § 117.403 exemption 

with 0. 1 tpd NOx allotment of vehicle fleet turnover surplus emission reductions predicted to 

occur in the one-year period beginning June 15, 2009. Allocating 0.1 tpd NOx reduction from 

fleet turnover surplus emissions ensures that adoption of the Chapter 117 rulemaking associated 

with this DFW RACT, Rule, and Contingency SIP Revision will not interfere with the DFW 1997 

eight-hour ozone attainment demonstration. 

4.2.2.2.- 4.2.2.4 (No revision) 

4.2.3. - 4.2. 7 (No revision) 

4.3. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS 

(Revision) 

4.3.1 DFW VOC RACT Analysis Update (Addition) 

The DFW nine-county ozone nonattainment area is classified as a moderate nonattainment area 

for the 1997 eight-hour ozone standard, and thus required to meet RACT mandates of the 1990 

FCAA Amendments under§§ 172(c)(1), 182(b)(2) and 182(f). States containing nonattainment 

areas classified as moderate or higher must demonstrate that current rules fulfill 1997 eight-hour 

ozone RACT requirements for all control technique guidelines (CTG) categories, and for all nonCTG major sources ofNOx and VOC. 

Section 183(e) of the FCAA directs the EPA to regulate categories that account for at least 80 

percent of the VOC emissions from consumer and commercial products in ozone nonattainment 

areas. FCAA § 183(e)(3) requires the EPA to regulate VOC emissions from consumer arid 

commercial products by issuing national regulations applicable to manufacturers, processors, 

wholesale distributors, or importers, or by issuing CTG documents. 

Under 42 United States Code (USC),§ 75ll(b), the EPA is required to issue CTG documents to 

assist states in developing RACT for major sources of VOC emissions. States can adopt and 

implement the CTG recommendations, or they can adopt alternative approaches, but in either 

event, a RACT demonstration and any rule revisions must be submitted to the EPA for review 

and approval as part of the SIP. The FCAA provides that states with ozone nonattainment areas 

classified as moderate and above must revise their ozone SIPs to include requirements for RACT 

Proposed September 23, 2009 4-4 
DFW RACT, Rule, and Contingency SIP Revision 

for VOC sources covered by any EPA CTG document issued after November 15, 1990, and prior 

to the date of attainment. 

The DFW 1997 Eight-Hour Ozone AD SIP Revision submitted to the EPA in May 2007 

demonstrated fulfilled VOC RACT requirements for the nine-county DFW 1997 eight-hour 

ozone nonattainment area. The RACT element of that SIP revision: (I) identified VOC emission 

CTG source categories for the area and provided negative declarations for the categories where 

no major emission sources exist; (2) identified the state regulation(s) that implement or exceed 

RACT for each applicable CTG source category; and (3) described the basis for concluding that 

the regulations fulfill RACT. That RACT analysis demonstrated that current VOC rules and 

controls for the DFW area satisfy the FCAA requirements for RACT for all CTG or alternative 

control technology (ACT) VOC source categories specific to any CTG or ACT documents issued 

prior to 2006. RACT for all non-CTG/ACT major VOC emission source categories for which 

controls are technologically and economically feasible is met by the EPA-approved Chapter 115 

rules or other federally enforceable measures. 

The EPA provided final approval of the VOC RACT analysis element of the DFW attainment 

demonstration in the conditional approval document for the DFW 1997 Eight-Hour Ozone AD 

SIP Revision (74 FR 1903; January 14, 2009). However, during and shortly after development of 

that SIP revision, the EPA issued II new Consumer and Commercial Products CTG documents. 

Some of the recommendations made in the new CTGs were updates to previously issued 

guidelines, and some were recommendations for new categories. The RACT analysis did not 

include the 2006 through 2008 CTG documents. The EPA requires SIP revision submittals 

within one year after final Consumer and Commercial Products CTG documents publish in the 

Federal Register; however, there was not sufficient time to address those in the May 2007 DFW 

AD SIP Revision before the submittal deadline. During development of that SIP revision, the 

commission had requested extension of the deadline to allow sufficient time to review, evaluate 

and act upon the CTGs. In its final rule, the EPA did not extend that deadline, but did indicate an 

intention to work with states to ensure timely submittals of the required SIP revisions. 

The II CTG documents published in the Federal Register in lieu of national regulations each 

contain recommendations for VOC controls on various consumer and commercial products. On 

October 5, 2006, final CTGs for Group II product categories were published (71 FR 58745). On 

October 9, 2007, final CTGs were published for Group III product categories (72 FR 57215). 

Final.CTGs for Group IV product categories were published on October 7, 2008 (73 FR 58481). 

The following is a list of the CTG documents: 

• Flat Wood Paneling Coatings, Group II Issued in 2006 

• Flexible Packaging Printing Materials, Group II Issued in 2006 

• Industrial Cleaning Solvents, Group II Issued in 2006 

• Offset Lithographic and Letterpress Printing, Group II Issued in 2006 

• Large Appliance Coatings, Group III Issued in 2007 

• Metal Furniture Coatings, Group III Issued in 2007 

• Paper, Film, and Foil Coatings, Group III Issued in 2007 

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

• Fiberglass Boat Manufacturing Materials, Group IV Issued in 2008 

• Miscellaneous Industrial Adhesives, Group IV Issued in 2008 

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

Proposed September 23, 2009 4-5 
DFW RACT, Rule, and Contingency SIP Revision 

TCEQ staff evaluated the new CTG documents to make RACT determinations for the State of 

Texas and to determine if additional VOC controls are necessary to fulfill RACT requirements. 

The following provides a brief summary of the state's RACT determinations regarding the II 

CTG documents. This DFW RACT, Rule and Contingency SIP Revision proposes an update to 

the VOC RACT element of the DFW area's 1997 eight-hour ozone attainment demonstration. 

Details regarding the state's evaluation of the CTG documents and RACT determinations for the 

source categories addressed are provided in the VOC RACT analysis update for the DFW area 

contained in Appendix A: DFW Reasonably Available Control Technology Analysis Update. 

Through this SIP revision, the TCEQ demonstrates a continued VOC RACT fulfillment in the 

DFW 1997 eight-hour ozone nonattainment area. The RACT update provided in this SIP revision 

identifies state regulation(s) that implement or exceed RACT for each applicable CTG source 

category, and describe the TCEQ's basis for concluding that the regulations fulfill RACT for the 

DFW area. Although the FCAA requires states to implement RACT for new or revised CTGs, 

the recommendations made do not always constitute RACT for an affected area. As indicated by 

the EPA in the introduction of each of the CTG documents, the purpose of the CTG is to assist 

states in determining what represents RACT for specific nonattainment areas. 

4.3.1.1. CTG Document Recommendations Not Applicable to the DFW Area 

The TCEQ provides a negative declaration for the Flat Wood Paneling Coatings CTG source 

category. The TCEQ determined that no sources meeting the applicability criteria recommended 

in the CTG document are located in the DFW area. Additional information is provided in 

Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update. 

4.3.1.2. CTG Document Recommendations that Do Not Represent RACT for the DFW Area 

The TCEQ has determined that (I) the recommendations do not represent RACT due to economic 

or technological feasibility concerns, or that (2) the TCEQ has equivalent or superior controls in 

place for the following four CTG source categories: Fiberglass Boat Manufacturing Materials; 

Flexible Packaging Printing Materials; Auto and Light-Duty Truck Assembly Coatings; and 

Paper, Film, and Foil Coatings. Therefore, the TCEQ is not proposing to implement any rule 

amendments or new rules associated with these CTG categories. Additional information is 

provided in Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis 

Update. 

4.3.1.3. CTG Document Recommendations for which RACT Determinations are Not Being 

The TCEQ is not making a determination at this time whether the CTG recommendations for the 

Industrial Cleaning Solvents or the Miscellaneous Industrial Adhesives categories represent 

RACT for Texas. The TCEQ's initial assessment indicates that the EPA substantially 

underestimated the scope and potential impact of the CTGs, and that the implementation of the 

recommendations would have widespread and potentially adverse impacts to small businesses 

and micro-businesses. The TCEQ will continue to evaluate the CTGs, and intends to provide 

small business outreach in order to more clearly gauge adverse impact potential. A RACT 

determination regarding the recommendations for this CTG source category will be made after 

these outstanding issues are addressed. Once adequate stakeholder input is received and the 

TCEQ determines potential impact to small businesses, economic and technological feasibility, 

and practical enforceability of the recommendations, a RACT determination can be made. 

Additional information is provided in Appendix A: Dallas-Fort Worth Reasonably Available 

Control Technology Analysis Update. · 

Proposed September 23, 2009 4-6 
DFW RACT, Rule, and Contingency SIP Revision 

In a letter to the EPA dated December 8, 2008, the TCEQ requested clarification from the EPA 

regarding several issues related to recommendations made in the CTG documents for the 

following source categories: Large Appliance Coatings; Metal Furniture Coatings; and 

Miscellaneous Metal and Plastic Parts Coatings. A number of the CTG recommendations 

regarding VOC content limits for specific coatings categories are less stringent than the more 

general VOC content limits specified in the EPA's original CTG recommendations. The TCEQ 

requested clarification to determine if implementing the CTG recommendations would be 

backsliding. Staff has requested this clarification to ensure that the TCEQ has all the appropriate 

infonnation needed to detennine whether the recommendations represent RACT for Texas. As of 

September 4, 2009, the EPA had not yet responded to the request for clarification. Therefore, the 

TCEQ cannot yet detennine whether these CTGs represent RACT for Texas. A RACT 

detennination will be made after the EPA provides clarification to the issues identified and the 

TCEQ evaluates the CTG recommendations in context with the EPA's response. 

4.3.1.4. CTG Document Recommendations that Represent RACT for the DFW Area 

The TCEQ has detennined that some recommendations in the Offset Lithographic and Letterpress 

Printing CTG represent RACT for the DFW area. Concurrent with this SIP revision, the TCEQ is 

proposing rulemaking to limit the VOC content of solvents used by offset lithographic printing 

facilities in certain areas of Texas, including the DFW area (Rule Project 2008-0 19-115-EN). 

The proposed rulemaking would implement CTG recommendations to reduce the VOC content of 

fountain solutions and cleaning materials, and would expand applicability of the current rule to 

include smaller sources not currently subject to the rule. The TCEQ is not proposing to 

implement any rulemaking associated with the control requirements for heatset presses or 

letterpress printing recommendations. Additional discussion concerning the state's detennination 

regarding the CTG recommendations for heatset press and letterpress printing is provided in 

Appendix A: DFW Reasonably Available Control Technology Analysis Update. The Chapter 

115 rulemaking (TCEQ Rule Project No. 2008-0 19-115-EN) associated with this SIP revision, 

proposed to implement RACT for offset lithographic printing sources, is described in Section 

4.2.1., VOC Control Measures, of this SIP revision. 

4.4. - 4.5. (No revision) 

4.6. CONTINGENCY MEASURES (Revision) 

4.6.1. Background (Addition) 

FCAA (42 USC§§ 7502(c)(9) and 7511a(c)(9)) and the EPA final Phase 2 1997 eight-hour ozone 

implementation rule require that the SIPs for all 1997 eight-hour ozone nonattainment areas 

include contingency measures as additional controls needed to further reduce emissions in the 

event an area fails to attain by its attainment date. The Act requires that states with ozone 

nonattainment areas classified as moderate and above include contingency measures in their SIPs 

(sections 172(c)(9) and 182(c)(9)). Per the FCAA, the failure-to-attain contingency plan must 

identifY control measures sufficient to secure an additional three percent reduction (from the 1999 

adjusted base year emissions inventory used in the attainment demonstration) in ozone precursor 

emissions should a moderate nonattainment area fail to attain the 1997 eight-hour ozone NAAQS 

by the June 15,2010, required attainment date. The May 2007 DFW AD SIP Revision, Appendix 

B: Emissions Inventory Development identifies 520.08 tpd ofVOC and 754.56 tpd ofNOx in the 

1999 adjusted base year emissions inventory from all anthropogenic sources in the DFW ninecounty nonattainment area. 

Proposed September 23, 2009 4-7 
DFW RACT, Rule, and Contingency SIP Revision 

As part of its January 14 2009, final conditional approval of the DFW 1997 Eight-Hour Ozone 

AD SIP Revision, as supplemented and revised (74 FR 1903), the EPA deemed the failure-toattain contingency plan (as submitted in the May 2007 DFW AD SIP Revision, supplemented in 

April 2008, and revised in the November 2008 DFW AD SIP Contingency Plan Revision) to be 

complete and fully approved. That contingency plan identified emissions reductions from three 

state VOC rules along with emission reductions from the 2009 through 20 I 0 mobile source fleet 

turnover as the contingency measures. At the time these VOC rules were identified for the DFW 

eight-hour ozone failure-to-attain contingency plan, they were not required to meet VOC RACT 

requirements. The three rules, applicable to (I) Offset Lithographic Printing, as in 30 T AC § 

l15.449(c); (2) Degassing or Cleaning of Stationary, Marine, and Transport Vessels, as in 30 

TAC § 115.549(b); and (3) Petroleum Dry Cleaning, as in 30 TAC § 115.559(a), were determined 

to provide a cumulative 1.80 tpd VOC emission reduction from sources in Collin, Dallas, Denton, 

and Tarrant Counties. Surplus emission reductions predicted to result from the fleet turnover to 

occur over a one-year period beginning June 15, 2010, were identified to provide the remainder 

of emission reductions needed for the three percent contingency requirement. 

The turnover of the on-road fleet of cars and trucks will result in additional VOC and NOx 

emission benefits in 2009 and beyond because newer vehicles have significantly lower emission 

standards than vehicles they are replacing. New vehicle emission standards are lower primarily 

due to a number of federal rules such as the Tier 2 standards for automobiles and light trucks, and 

the 2007 Heavy-Duty Diesel standards for large diesel highway trucks. Emission reductions 

predicted to occur from the fleet turnover during the one-year period beginning June 15, 2009, are 

estimated to total4.86 tpd VOC and 20.78 tpd NOx. 

4.6.2. Revised DFW 1997 Eigbt-Hour Ozone Failure-to-Attain Contingency Plan (Addition) 

This DFW RACT, Rule and Contingency SIP Revision proposes a revised contingency plan for 

the DFW 1997 eight-hour ozone attainment demonstration. Removal of one measure from the 

contingency plan - the offset lithographic measure - and a modified allotment of fleet turnover 

reductions dedicated to the failure-to-attain contingency plan are both proposed in this SIP 

revision. Upon adoption of this DFW RACT, Rule, and Contingency SIP Revision, 13.36 tpd of 

the NOx emission reductions, and 4.86 tpd of the VOC emission reductions predicted from the 

June 2009 through 2010 fleet turnover will be dedicated to provide reductions for the contingency 

plan. 

Due to the associated Chapter 115 rule proposal applicable to the same sources, the offset 

lithograph printing rule contingency measure (and the associated 0.24 tpd predicted VOC 

reduction) is being removed as a contingency measure. However, the two other state VOC rules 

identified in the SIP revision will remain in the SIP. Those two VOC rule contingency measures 

provide controls applicable to the degassing or cleaning process of stationary, marine, and 

transport vessels, and to petroleum-based dry cleaning. 

The three contingency measures identified in Table 4.1: Emission Reductions Provided by 

Proposed Contingency Plan, and further described below, are measures identified for the 

proposed DFW 1997 eight-hour ozone attainment demonstration contingency plan, for 

implementation in the event the contingency plan is triggered. 

1. A VOC reduction of0.18 tpd will be made through controls on the degassing or cleaning 

process of stationary, marine, and transport vessels. All affected persons in Collin, 

Dallas, Denton, and Tarrant Counties must be in compliance with 30 T AC. Chapter 115. 

Subchapter F. Division 3 (relating to Degassing or Cleaning of Stationary, Marine. and 

Transport Vessels) as soon as practicable, but no later than one year, after notification is 

Proposed September 23, 2009 4-8 
DFW RACT, Rule, and Contingency SIP Revision 

published in the Texas Register of the commission's detennination that this contingency 

rule is necessary as a result of failure to attain the 1997 NAAQS for ozone by the 

attainment deadline as set forth in the 1990 Amendments to the FCAA, § 172( c )(9). The 

commission will submit notification to the Texas Register for publication within 60 days 

after the EPA notifies the state of its failure through publication of a final action in the 

Federal Register. 

2. A VOC reduction of 1.38 tpd will be made through controls on petroleum-based dry 

cleaning businesses. All affected petroleum solvent dry cleaning facilities in Collin, 

Dallas, Denton, and Tarrant Counties must be in compliance with 30 T AC. Chapter 115, 

Subchapter F. Division 4 (relating to Petroleum Dry Cleaning Systems) as soon as 

practicable, but no later than one year, after notification is published in the Texas Register 

of the commission's detennination that this contingency rule is necessary as a result of 

failure to attain the 1997 NAAQS for ozone by the attainment deadline as set forth in the 

1990 Amendments to FCAA, § 172( c )(9). The commission will submit notification to 

the Texas Register for publication within 60 days after the EPA notifies the state of its 

failure through publication of a final action in the Federal Register. 

3. Emission reductions to provide 4.86 tpd VOC and 13.36 tpd NOx, allotted to the DFW 

contingency plan from and out of surplus emission reductions that will result from the 

motor vehicle fleet turnover to occur during a one-year period beginning June 15, 2009. 

T a bl e . : 41 E . . MISSIOn Red uct1ons p rov1 'd e db )l'_ p rol!_ose dC on f me:ency PI an 

Contine;ency Measure Emission Reductions (tpd) 

State VOC rule contingency measure applicable to the Degassing or 

Cleaning of Stationary, Marine, and Transport Vessels* 

State VOC rule contingency measure applicable to Petroleum Dry 

Cleaning* 

Mobile source fleet turnover emission reductions** 

(portion allocated for contingency) 

Total Contingency Plan Reductions 

*applicable m Collm, Dallas, Denton, and Tarrant Counties only 

**attributable to DFW nine-county area 

voc NOx 

0.18 00.00 

1.38 00.00 

4.86 13.36 

6.42 13.36 

The method used to calculate the DFW three percent contingency emission reduction requirement 

is represented in the following equation: 

RvNOCBASE + RN/NOxBASE >= 0.03 where; 

Rv =typical summer day VOC reductions in mass units 

R.N = typical summer day NOx reductions in mass units 

VOCBASE = the mass of anthropogenic VOC emissions in the 1999 adjusted base year 

inventory, and 

NOxBASE =the mass of anthropogenic NOx emissions in the 1999 adjusted base year inventory, 

and was calculated as follows: 

[(6.42/520.08) + (13.361754.56)] = 3% 

Table 4.2: Calculations Showing Three Percent Required Reductions shows that the proposed 

DFW contingency plan will provide a 1.23 percent reduction from the DFW area 1999 adjusted 

Proposed September 23, 2009 4-9 
DFW RACT, Rule, and Contingency SIP Revision 

base year VOC emissions inventory, and a 1.77 percent reduction from the corresponding NOx 

emissions inventory. Following the EPA's NOx substitution guidance to calculate the 

contingency plan reductions, the 1.23 (percent VOC reduction) is added to the l. 77 (percent NOx 

reduction) to equal the required 3.00 (percent total VOC and/or NOx emissions reductions). This 

modified contingency plan identifies measures to provide the required reductions, totaling 6.42 

tpd VOC and 13.36 tpd NOx. 

Table 4. 2 C : a I culations Showin2 Three p ercent R . equ1re dR e d uct10ns 

Modified DFW Conting_ency_ Plan Calculations voc NOx 

1999 adjusted base year El, DFW 9-county area {tQ_d weekdayl 520.08 754.56 

tpd emissions reductions from the two state VOC rule measures 1.56 0.00 

tpd emissions reductions from the surplus fleet turnover emissions 

reductions allotted for the contingency Qlan 4.86 13.36 

(Total t/!_d reductions to be /!_rovided by the modified contin~ncyplanl_ (6.42) 03.36) 

Percentag_e of inventory_ reduction for each Q_recursor 1.23% 1.77% 

Total percentage o.f_reductionsprovided by the plan 3.00% total 

4.6.3. Allocation of the June 2009 through 2010 fleet turnover reductions (Addition) 

Table 4.3: Allocation of Emissions Reductions from the 2009 through 2010 Fleet Turnover 

consolidates emissions reductions allocations proposed in this DFW RACT, Rule, and 

Contingency SIP Revision. Out of the total 4.86 tpd VOC and 20.78 NOx emission reductions 

predicted to occur from the fleet turnover expected to occur during the one-year period beginning 

June 15, 2009, all of the 4.86 tpd VOC and 13.36 tpd of the NOx reductions are allotted to 

provide reductions for the proposed DFW contingency plan. The remaining 7.42 tpd surplus 

NOx emissions reduction from fleet-turnover is surplus and usable for other future SIP purposes. 

T a bl e . 4 3 : All ocatlon o fE .. IDISSIODS Rd e uctlons ti rom th e 2009 th rougt h 2010 Fl eet T urn over 

Vehicle Fleet Turnover Emission Reductions• (tpd) voc NOx 

Total emissions reductions from June 2009 through 2010 fleet turnover 4.86 20.78 

Allocation to replace NOx reduction lost from control strategy upon 

adoption of Chap. I I 7 rulemaking (_see section 4.2.2.11 -0.00 -0.10 

Allocation to the proposed DFW contingency plan -4.86 - 13.36 

Remaining surplus emission reductions available for future SIP use 0.00 7.42 

• from the mne-county DFW etght-hour ozone nonattamment area 

Proposed September 23, 2009 4-10 
DFW RACT, Rule, and Contingency SIP Revision 

APPENDIX A: 

Dallas-Fort Worth Reasonably Available Control Technology Analysis Update 

Proposed September 23, 2009 
DFW RACT, Rule, and Contingency SIP Revision 

Description 

Section 1.0. Introduction 

Section 2.0. RACT Evaluation Approach 

2.1. General Discussion 

INDEX: 

2.2. Identification of CTG Emission Source Categories 

2.3. Determining if State Regulations Fulfill RACT Requirements 

Section 3.0. RACT Determination and Discussion 

3.1. EPA Consumer and Commercial Products CTG Documents, 

Group II, Issued in 2006 

3.2. EPA Consumer and Commercial Products CTG Documents, 

Group III, Issued in 2007 

3.3. EPA Consumer and Commercial Products CTG Documents, 

Group IV, Issued in 2008 

Attachment I 

December 8, 2008, Letter to Mr. William T. Harnett, Director, 

Air Quality Policy Division, United States Environmental Protection 

Agency on Issues related to Control Technique Guidelines documents 

Proposed September 23, 2009 A-1 

A-2 

A-3 

A-3 

A-3 

A-3 

A-4 

A-4 

A-6 

A-7 

A-10 
DFW RACT, Rule, and Contingency SIP Revision 

DALLAS-FORT WORTH REASONABLY AVAILABLE CONTROL TECHNOLOGY 

ANALYSIS UPDATE 

1.0. Introduction 

The Dallas-Fort Worth (DFW) eight-hour ozone nonattainment area (Dallas, Denton, Collin, 

Tarrant, Parker, Johnson, Ellis, Kaufman, and Rockwall Counties) is currently classified 

moderate nonattainment for the United States Environmental Protection Agency (EPA) 1997 

eight-hour ozone National Ambient Air Quality Standards (NAAQS). Under the 1997 eight-hour 

ozone standard, the area is required to meet the mandates of the Federal Clean Air Act (FCAA) 

under§§ 172(c)(l), 182(b)(2) and 182(f). According to the EPA's Final Rule to Implement the 

Eight-Hour Ozone NAAQS (40 Code of Federal Regulations (CFR) § 51.912, November 29, 

2005), the area must submit as a revision to the state implementation plan (SIP) a demonstration 

that current rules fulfill the eight-hour reasonably available control technology (RACT) 

requirements for all Control Techniques Guidelines (CTG) categories. The EPA previously 

approved the volatile organic compounds (VOC) RACT analysis, as submitted in the May 2007 

DFW Eight-Hour Ozone Attainment Demonstration SIP Revision (74 FR 1903; January 14, 

2009). However, in 2006 through 2008, the EPA issued II new CTG documents containing 

recommendations for VOC controls on a variety of consumer and commercial products. Some of 

the new CTG recommendations update previously issued CTG documents and some of them 

apply to new source categories. The Texas Commission on Environmental Quality (TCEQ) has 

evaluated the CTG documents to determine if additional VOC controls are necessary to fulfill 

RACT requirements. The following is a list of the 11 CTG documents evaluated for this DFW 

VOC RACT analysis update: 

• Flat Wood Paneling Coatings, Group II issued in 2006 

• Flexible Packaging Printing Materials, Group II issued in 2006 

• Industrial Cleaning Solvents, Group II issued in 2006 

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

• Large Appliance Coatings, Group III issued in 2007 

• Metal Furniture Coatings, Group III issued in 2007 

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

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

• Fiberglass Boat Manufacturing Materials, Group IV issued in 2008 

• Miscellaneous Industrial Adhesives, Group IV issued in 2008 

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

Because the Group II CTG documents published just shortly before the May 2007 DFW AD SIP 

Revision was proposed, and because the EPA issued the remaining seven after the TCEQ 

submitted that SIP revision to the EPA, RACT analysis determinations for the new CTGs have 

not yet been submitted to the EPA. This document addresses the II CTG documents, and 

provides a VOC RACT analysis update for the DFW area. 

RACT represents 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 Federal Register 53762; September 17, 1979). RACT requirements for 

moderate nonattainment areas are included in the FCAA to ensure the control, to a reasonable 

extent, of ozone precursor emissions at major sources are controlled. However, RACT control 

levels are not necessarily equal to the best available control technology (BACT) levels expected 

Proposed September 23, 2009 A-2 
DFW RACT, Rule, and Contingency SIP Revision 

of new sources or to the maximum achievable control technology (MACT) levels required for 

major sources of hazardous air pollutants. 

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

such as technological and economic feasibility; however, there is significant distinction between 

RACT and RACM. In order for a control measure to be determined RACM, the measure must 

advance the area's NAAQS attainment. However, a measure need not advance NAAQS 

attainment to be determined RACT, as benefits resulting from RACT implementation are 

presumed under the FCAA. 

2.0. RACT Evaluation Approach 

2.1. General Discussion 

The TCEQ demonstrates that RACT requirements are fulfilled by: (1) identifying all CTG source 

categories of VOC and NOx emissions and submitting negative declarations for categories where 

no major emission sources exist; (2) identifying all non-CTG major sources of VOC and NOx 

emissions; (3) identifying the state regulation implementing or exceeding RACT for each 

applicable CTG source category or non-CTG major emission source; and (4) describing the basis 

for conclusion that the regulations fulfill RACT. Because this SIP revision focu~es specifically 

on the 11 CTG documents issued by the EPA from 2006 through 2008, this RACT analysis 

provides only an update to the DFW VOC RACT demonstration. 

2.2. Identification of CTG Emission Source Categories 

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

the 11 Consumer and Commercial Products CTG documents issued from 2006 through 2008 to 

identify all source categories of VOC emissions that require RACT. RACT determinations are 

not required if there are no facilities in the DFW area that are subject to the CTG document. 

Negative declarations for source categories described in the EPA guidance documents that do not 

exist in the DFW area are included. 

2.3. Determining if State Regulations Fulfill RACT Requirements 

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

115 as meeting RACT requirements for the DFW area for CTG documents issued prior to 2006. 

RACT determinations regarding the CTG documents issued in 2006 and later were made by 

comparing the CTG recommendations to TCEQ rules to determine if the existing rules satisfied 

RACT. Specific discussion regarding the CTG recommendations evaluated is provided in 

Sections 3.3.2. through 3.3.4. 

BACT is an emission standard based upon a maximum achievable degree of emission reduction, 

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

MACT is an emission standard that requires the maximum reduction of hazardous emissions, and 

is at least as stringent as the average emission level achieved by controls on the top 12 percent of 

existing sources in the applicable source category. Emission sources that are subject to the more 

stringent BACT or MACT requirements were determined to fulfill RACT requirements. The 

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

all CTG emission source categories in the DFW area are subject to requirements that meet or 

exceed applicable RACT requirements or that further emission controls are not economically or 

technologically feasible. 

Proposed September 23, 2009 A-3 
DFW RACT, Rule, and Contingency SIP Revision 

3.0. RACT Determination and Discussion 

3 .1. The EPA Consumer and Commercial Products CTG Documents, Group II Issued in 2006 

3.1.1. Flat Wood Paneling Coatings 

The TCEQ is not proposing to implement any rule amendment or new rule for the DFW area 

associated with the Flat Wood Paneling Coatings CTG. The EPA indicated in Appendix B: State 

and Local Regulations for Flat Wood Paneling of the CTG document that two facilities in Texas 

ozone nonattainment areas are potentially subject to the recommendations. Based on a review of 

the 2005 point source emissions inventory, the TCEQ determined that only one facility in the 

DFW area, Buell Door Company, TCEQ Account Number DB-0128-U, may fit the source 

category description in the Flat Wood Paneling Coatings CTG. However, that facility ceased all 

operations in 2006 and to date has not reported any emissions for the site for subsequent years. 

The TCEQ does not expect that the company will resume business operations at this facility; 

therefore, the TCEQ provides a negative declaration for this CTG category for the DFW area. 

3.1.2. Flexible Packaging Printing Materials 

The TCEQ is not proposing to implement any rule amendments or new rules for the DFW area 

associated with the Flexible Packaging Printing Materials CTG document. Rules for flexographic 

and rotogravure printing in Chapter 115, Subchapter E, Division 3 and the sites' permit provisions 

sufficiently satisfy RACT for the DFW area. The Flexible Packaging Printing Materials CTG 

recommends an add-on air pollution control device requirement on any flexible package printing 

press with the potential to emit 25 tons per year (tpy) or more of VOC. Current TCEQ rules 

control emissions from flexographic and rotogravure printing lines on a property with the 

combined uncontrolled potential to emit 50 tpy or more of VOC when operating at maximum 

production rate. The TCEQ has identified nine facilities in the DFW nonattainment area that 

potentially meet applicability criteria in this CTG document. However, eight facilities have 

enforceable limitations on VOC emissions in place that restrict VOC emissions to less than 25 

tpy, consistent with the recommendation to allow sites to elect the 25 tpy enforceable limitation. 

The remaining facility, Printpack Inc., TCEQ Account Number TA-0282-E, has enforceable 

permit provisions that are more effective overall than the CTG recommendations regarding VOC 

capture and destruction efficiency. The permit requirements specified for these facilities 

sufficiently fulfill RACT requirements for this CTG category. 

The CTG also recommends specific work practice requirements for flexible package printing 

operations with an uncontrolled potential to emit 15 pounds per day (ppd) or more of VOC. The 

EPA's CTG document does not provide a VOC emissions reduction estimate for implementing 

these work practices. Based on the TCEQ's review, the potential benefit from implementing the 

work practices is not reliably quantifiable, and any emission reduction would likely be miniscule. 

Additionally, the TCEQ expects that most facilities already voluntarily follow similar work 

practices for safety reasons or that they have required work practices as part of a permit 

authorization. The TCEQ does not consider it reasonable to impose additional rule requirements 

for general housekeeping requirements when neither need nor quantifiable benefits are apparent. 

3.1.3. Industrial Cleaning Solvents 

The TCEQ is not making a RACT determination at this time regarding the Industrial Cleaning 

Solvents CTG recommendations. The TCEQ's assessment indicates that the EPA substantially 

underestimated the scope and potential impact of the recommendations. In Appendix D of the 

CTG document: Number of nonattainment facilities organized by State that are estimated to meet 

the applicability criteria recommended in the CTG, the EPA estimated 92 facilities in Texas 

nonattainment areas would be subject to the recommendations. However, the North American 

Proposed September 23, 2009 A-4 
DFW RACT, Rule, and Contingency SIP Revision 

Industry Classification System (NAICS) codes provided in Appendix C of the CTG document: 

Summary of NAICS Codes for nonattainment facilities estimated to meet the applicability criteria 

recommended in the CTG suggests a much broader applicability. Based on the EPA's 15 ppd 

VOC suggested exemption threshold and the listed NAICS codes, the TCEQ estimates that 

implementation of this recommendation would have widespread and possibly adverse impact on 

small business and micro-business in Texas. Evaluating technological and economic feasibility 

aspects of a proposed technology or control measure is integral to determining RACT; however, 

identifying potentially impacted businesses and determining applicability of a technology or 

measure are required to conduct those evaluations. Because additional research is needed in 

order to clarify and determine source applicability of this CTG, a RACT analysis cannot be 

completed at this time. The TCEQ will continue to evaluate this CTG, and intends to conduct 

small business outreach to potentially impacted stakeholders in order to obtain the information 

needed to complete a RACT analysis. A RACT determination for this CTG category can be 

made only after the TCEQ has determined impact to small businesses, technological and 

economic feasibility, and practical enforceability of the CTG recommendations. 

3.1.4. Offset Lithographic & Letterpress Printing 

The TCEQ has determined that portions of the Offset Lithographic and Letterpress Printing CTG 

recommendations do represent RACT for the DFW area. Concurrent with this SIP revision, the 

TCEQ is proposing rulemaking to limit the VOC content of solvents used by offset lithographic 

printing facilities in the DFW area. The proposed Chapter 115 rulemaking implements the CTG 

recommendations to reduce the VOC content of the fountain solutions and cleaning solutions, and 

expands rule applicability to include smaller sources not subject to the existing rule. 

The TCEQ is not proposing to implement any rule amendments or new rules for the DFW area 

associated with the recommended control requirements for heatset presses. The CTG 

recommends an add-on air pollution control device requirement for each heatset offset 

lithographic press with an uncontrolled potential to emit 25 tpy of VOC or more from the dryer. 

The EPA recommends different control efficiencies for devices installed before and after the 

effective date of the rule implementing these CTG recommendations; EPA recommends requiring 

a 90 percent overall control efficiency for control devices installed before the rule effective date 

and a 95 percent overall control efficiency for control devices installed after the rule effective 

date. The commission is not proposing any rule amendments or new rules to implement the 

EPA's recommendations for these sources. 

In the DFW area, the existing Chapter 115 rules require control devices with an efficiency of at 

least 90 percent to be installed on heatset offset lithographic presses located on a property with 

combined VOC emissions of at least 50 tpy. The existing Chapter 115 requirement may not be as 

stringent as the EPA's recommendations for control devices installed before the rule effective date 

in all instances, since an individual press with uncontrolled emissions greater than 25 tpy could be 

located on a site with total emissions less than 50 tpy when uncontrolled. However, staff 

reviewed the point source emissions inventory, Title V, and central registry databases to identify 

heatset presses in the DFW area potentially subject to the EPA's CTG recommendations and 

determined that the heatset presses identified have control devices with a minimum efficiency of 

90 percent to comply with either Chapter 115 rules or as part of their permit authorization. Since 

the level of control on heatset presses identified in the DFW area either meets or exceeds the 

EPA's recommendations for control devices installed before the effective date of the rule, the 

commission is not proposing any new rules or rule revisions for control devices on heatset presses 

in the DFW area. 

Proposed September 23, 2009 A-5 
DFW RACT, Rule, and Contingency SIP Revision 

The EPA also recommends requiring a 95 percent overall efficiency for control devices installed 

after the rule effective date on individual heatset web offset lithographic presses with the 

uncontrolled potential to emit at least 25 tpy of VOC. Control devices installed in the future will 

be required to meet best available control technology standards of at least 95 percent control 

efficiency as part of their penn it authorization. Therefore, the commission is not proposing any 

new rules or rule revisions for control devices installed on heatset presses after the effective date 

of the rule. 

The TCEQ is not proposing to implement any new rules associated with the recommendations 

applicable to letterpress printing emission sources in DFW area. Letterpress printing operations 

are not currently regulated under Chapter 115 rules; however, the CTG recommends an add-on 

air pollution control device requirement for each heatset letterpress with an uncontrolled potential 

to emit 25 tpy or more of VOC from the dryer. Reviews of the point source emissions inventory, 

Title V database, and central registry databases indicate there may be some letterpress printing 

operations co-located with offset lithographic printing operations in the DFW area; however, it 

appears that none of the presses have potential to emit over 15 tpy of VOC, so they are not 

subject to the recommended controls. 

The 2006 CTG also recommends limiting the VOC content of cleaning solutions used in offset 

lithographic printing operations to 70.0 percent VOC by weight in conjunction with work practice 

standards. However, the proposed rules retain the more stringent existing Chapter 115 cleaning 

solution content limit of 70 percent VOC by volume in conjunction with work practice standards. 

In addition, the proposed rules retain the existing Chapter 115 option to limit the cleaning 

solution content to 50 percent VOC by volume. The TCEQ is proposing to include this option to 

retain the flexibility afforded to owners and operators subject to the current rules. The CTG also 

recommends requiring specific work practices for cleaning operations for offset lithographic and 

letterpress printing facilities with the uncontrolled potential to emit of 15 ppd or more of VOC. 

The TCEQ expects that most facilities are already voluntarily following similar practices for 

safety reasons or have required work practices as part of the sites' pennit authorization. The 

TCEQ does not consider it reasonable to implement additional rule requirements for general 

housekeeping requirements on sites when there is no apparent need nor any quantifiable benefit. 

3.2. EPA Consumer and Commercial Products CTG Documents, Group III Issued in 2007 

3.2.1. Large Appliance Coating 

By letter dated December 8, 2008, the TCEQ requested clarification from the EPA regarding 

several issues related to the Large Appliance Coatings CTG recommendations. Current TCEQ 

rules in Chapter 115 for large appliance coating operations are based on the Large Appliance 

Coatings CTG issued by the EPA in 1977. A number of the recommended VOC content limits 

for specific coatings categories listed in the 2007 CTG document are less stringent than the more 

general VOC content limits specified in the EPA's 1977 CTG recommendations for the Large 

Appliance Coatings category. Since the 2007 Large Appliance Coatings CTG document does not 

specifically address this issue, the TCEQ has requested clarification to verify that implementation 

of the new recommendations would not be backsliding, and to ensure that the TCEQ has all 

infonnation needed to detennine whether the 2007 CTG recommendations represent RACT for 

Texas. See Attachment 1 for the TCEQ letter to the EPA requesting clarification on these issues. 

As of September 4, 2009, the EPA has not responded to the TCEQ request for clarification on the 

Large Appliance Coatings CTG recommendations. Therefore, the TCEQ is not making a RACT 

detennination until the EPA provides clarification to the issues identified, and the TCEQ 

evaluates the CTG recommendations in context with the EPA's response. 

Proposed September 23, 2009 A-6 
DFW RACT, Rule, and Contingency SIP Revision 

3.2.2. Metal Furniture Coatings 

In the previously mentioned letter to the EPA of December 8, 2008, the TCEQ requested 

clarification from the EPA regarding several issues related to the Metal Furniture Coatings CTGs. 

Current TCEQ rules in Chapter 115 for metal furniture coating operations are based directly on 

the 1977 Metal Furniture Coatings CTG document issued by the EPA. A number of the VOC 

content limits for specific coatings categories recommended in the 2007 CTGs are less stringent 

than the more general VOC content limits specified in the EPA's 1977 recommendations for the 

Metal Furniture Coatings category. Since the 2007 Metal Furniture Coatings CTG document 

does not specifically address this issue, the TCEQ has requested clarification from the EPA to 

ensure that implementing the 2007 CTGs would not be backsliding, and to be certain that the 

TCEQ has the appropriate information to determine whether the 2007 CTGs represent RACT for 

Texas. See Attachment 1 for the TCEQ letter to the EPA requesting clarification on these issues. 

As of September 4, 2009, the EPA has not responded to the TCEQ request for clarification on the 

CTG recommendations. Therefore, the TCEQ is not making a RACT determination until the 

EPA provides clarification to the issues identified, and the TCEQ evaluates the CTG 

recommendations in context with the EPA's response. · 

3.2.3. Paper, Film, and Foil Coatings 

The TCEQ is not proposing to implement any rule amendment or new rule associated with the 

Paper, Film, and Foil Coatings CTG for the DFW area. The EPA recommendation for the 

installation of controls to achieve 90 percent reduction or compliance with the more stringent 

coating content limits would only apply to individual presses with a potential to emit 25 tpy or 

more of VOC prior to the consideration of controls. The TCEQ has identified two facilities in the 

DFW area that fit the applicability description in this CTG document. However, the rules in 

Chapter 115, Subchapter E, Division 2, and the sites' permit provisions are sufficient to satisfy 

RACT for the DFW area for this category of sources. One facility, Rock Tenn Converting 

Company, TCEQ Account Number DB-0 179-D, has an enforceable permit limitation of less than 

25 tpy VOC emissions from the coating line operations. This is consistent with the CTG 

recommendation to allow sites to elect enforceable limitations to keep VOC emissions less than 

25 tpy. The other facility, Printpack Inc., TCEQ Account Number TA-0282-E, has enforceable 

permit previsions regarding VOC capture and destruction efficiency that are overall more 

effective than the CTG recommendations. The specified permits requirements for these facilities 

sufficiently fulfill RACT for this CTG category. 

The CTG also recommends specific work practice requirements for cleaning operations at paper, 

film, and foil coating facilities with uncontrolled emission potential of 15 ppd or more of VOC. 

The two facilities identified in the DFW area each have work practices incorporated into the site' 

permit conditions. These enforceable work practices provide a reasonable level of control for 

these activities and are sufficient to fulfill RACT. The estimated VOC emissions reduction from 

work practice implementation was not provided by the EPA in the CTG document. Therefore, 

the TCEQ cannot ascertain whether any quantifiable environmental benefit would result from 

regulatory work practice requirements at the facility. The TCEQ does not consider it reasonable 

to implement additional rule requirements for general housekeeping requirements when there is 

no apparent need nor any quantifiable benefit. 

3.3. EPA Consumer and Commercial Products CTG Documents, Group IV Issued in 2008 

3.3.1. Auto and Light-Duty Truck Assembly Coatings 

Proposed September 23, 2009 A-7 
DFW RACT, Rule, and Contingency SIP Revision 

The TCEQ is not proposing to implement for the DFW area any rule amendments or new rules 

associated with the Auto and Light-Duty Truck Assembly Coatings CTG. One site identified in 

the DFW area is subject to the Auto and Light-Duty Truck Assembly Coatings CTG document: 

General Motors Corporation's Arlington Assembly Plant, TCEQ Account Number T A-0 157-1. 

However, the EPA indicates on page 23 of the CTG document that VOC emission reductions will 

not result from implementing the CTGs for coatings. Because auto and light-duty truck coating 

facilities have previously reduced coating operation VOC emissions in compliance with 40 Code 

of Federal Regulations (CFR) Part 60, New Source Performance Standards (NSPS), Subpart MM, 

Automobile and Light-Duty Truck Surface Coating Operations; 40 CFR Part 63, National 

Emission Standards for Hazardous Air Pollutants (NESHAPS), Subpart IIII, Surface Coating of 

Automobiles and Light-Duty Trucks; and existing state rules, the TCEQ agrees that the CTGs for 

coatings would not result in any actual VOC emission reductions. 

Permit requirements (TCEQ Permit Number 19156) for the General Motors Corporation 

Arlington Assembly Plant provide overall VOC emission controls superior to the CTG 

recommendations. Permit Number 19156 requires thermal or regenerative oxidizer controls at 

the many coating operations (clear coat operation line, prime electrodeposition coating oven, 

automatic zones of primer surfacer booth, primer surfacer oven, base basecoat spray booths) at 

the facility. In addition, coatings used must comply with the most recent VOC content 

requirements for coatings in the 30 TAC Chapter 115, NSPS Subpart MM, and NESHAP Subpart 

1111. While the CTG document recommends coating VOC content limits slightly lower than those 

currently required at the facility, the control device efficiency requirement recommendations for 

these operations range from 75 to 91 percent. The overall level of VOC control for coating 

operations at the Arlington Assembly Plant is equivalent or superior to that recommended by the 

EPA in the CTG and sufficiently meets RACT for this category. Therefore, there is no 

environment benefit or other practical value in implementing rules to incorporate the 

recommended coating controls into Chapter 115. 

Regarding the recommended work practices for coating-related activities and cleaning materials, 

TCEQ Permit Number 19156 specifies good industrial housekeeping and painting operation 

cleanup requirements. Additionally, as pointed out by the EPA in the CTG document, the 

NESHAP regulations require facilities to develop and implement work practice plans to reduce 

organic hazardous air pollutant emissions. These enforceable work practices provide reasonable 

control levels for these activities and are sufficient to fulfill RACT. An estimate of any VOC 

reduction benefit for implementing recommended work practices is not provided in the CTG 

document. Therefore, the TCEQ is unable to determine whether any real environmental benefit 

would result from imposing further regulatory work practices on the facility. 

3.3.2. Fiberglass Boat Manufacturing Materials 

The TCEQ has determined that the Fiberglass Boat Manufacturing Materials CTG 

recommendations do not represent RACT for Texas. The CTG document identified no facilities 

subject to the Fiberglass Boat Manufacturing Materials CTG document in the DFW area; 

however, the TCEQ cannot make a definitive negative declaration for this source category. 

Based on information provided by the EPA in the CTG document, the TCEQ has determined that 

implementing the recommended controls would not result in substantive VOC reductions, nor 

would it be economically feasible. The EPA stated in the CTG document that 67 facilities 

located in ozone nonattainment areas nationwide are expected to meet the applicability of the 

CTG. However, the EPA expects that additional VOC reductions will not result from any 

applicable major source because these emission control requirements of the 2001 Boat 

Manufacturing NESHAP already apply to these sources. Per the EPA, the CTG may affect only 

23 minor sources nationwide in ozone nonattainment areas. A potential estimated net emission 

Proposed September 23, 2009 A-8 
DFW RACT, Rule, and Contingency SIP Revision 

reduction of approximately 40 tpy VOC is predicted by the EPA, and the total estimated emission 

reductions from all 67 facilities is estimated at 1601 tpy VOC. The EPA's suggested controls 

would result in only a 2.5 percent reduction to the nationwide total VOC emissions from this 

category. In prior EPA guidance ("Issues Relating to VOC Regulation Cutpoints, Deficiencies, 

and Deviations, Clarification to Appendix D of November 24, 1987 Federal Register" Issued 

May 25, 1988), alternative threshold applicability is allowed, provided the overall controlled level 

for the alternative ranges within 5 percent of the EPA's recommended controlled level. Based on 

the same criterion, because the Fiberglass Boat Manufacturing Materials CTG would not result in 

reductions exceeding a de minimis threshold previously established by the EPA, the CTG does 

not represent RACT. 

Furthermore, the TCEQ disagrees with the cost analysis and determination that the controls are 

economically feasible. The EPA appears to have calculated the total $168,000 cost based on 

multiplying the estimated 40 tpy reduction by the approximately cost effectiveness in dollars per 

ton from the 200 I NESHAP. This total cost estimate represents an additional average annual cost 

of approximately $7,300 per facility. However, the EPA economic report referenced in the CTG 

document, Economic Impact Analysis of the Boat Manufacturing NESHAP (EPA-452/R-01-

0ll), indicates substantially higher costs. The EPA economic report shows that Boat 

Manufacturing NESHAP compliance costs per facility average over $100,000 in total variable 

costs and over $4,000 in total fixed costs. While many of the facilities are likely to be larger 

businesses than would be targeted by the controls proposed in the Fiberglass Boat Manufacturing 

Materials CTG, over 95 percent of the 125 facilities evaluated in the economic report exceeded 

total costs of$25,000, and 99 percent exceeded total costs of$10,000. The TCEQ concludes that 

the EPA's economic assessment in the CTG document underestimates true cost impact, and no 

effective environmental benefit in the ozone nonattainment area would result. The controls 

recommended in the Fiberglass Boat Manufacturing Materials CTG specifically target small 

businesses, and cost impact to small businesses must be weighed more heavily than the cost 

impact to larger businesses. Based on this analysis, the TCEQ has determined that the potential 

cost impact to small businesses is not reasonable or feasible considering the lack of 

environmental benefit. 

3.3.3. Miscellaneous Industrial Adhesives 

The TCEQ is not making a RACT determination at this time regarding the Miscellaneous 

Industrial Adhesives CTG recommendations. As similar to the TCEQ's assessment regarding the 

Industrial Cleaning Solvents CTG, the TCEQ's initial assessment of this CTG again indicates that 

the EPA substantially underestimated the scope and potential impact of CTGs for these sources. 

An evaluation of the technological and economic feasibility is integral to determining whether a 

control technology or measure represents RACT, but making the determination is impossible 

when applicability of the measure is ambiguous. The TCEQ will continue to evaluate this CTG 

and intends to provide small business outreach to engage stakeholders and others potentially 

impacted by the suggested control measures. A RACT determination for this source category 

will be made after adequate stakeholder input has been received and upon TCEQ determination of 

impact to small businesses, technological and economical feasibility of the recommendations, and 

practical enforceability of the CTG. 

3.3.4. Miscellaneous Metal and Plastic Parts Coatings 

In the previously mentioned letter dated December 8, 2008, the TCEQ requested clarification 

from the EPA regarding several issues related to the Miscellaneous Metal and Plastic Parts 

Coatings CTG. The current TCEQ rules in Chapter 115 for these coating operations are based 

directly on original CTG recommendations issued by the EPA in 1978. Several of the 

recommended VOC content limits for specific coatings categories listed in the 2008 CTG are less 

Proposed September 23, 2009 A-9 
DFW RACT, Rule, and Contingency SIP Revision 

stringent than the more general VOC content limits specified in the EPA's original 

recommendations for these categories. Since the 2008 CTG document does not specifically 

address this issue, the TCEQ requested clarification to ensure that that implementing the 2008 

CTG would not be backsliding and to be certain that the TCEQ has all information needed to 

appropriately determine whether the 2008 recommendations represent RACT for Texas. See 

Attachment I for the TCEQ letter to the EPA requesting clarification on these issues. 

As of September 4, 2009, the EPA has not responded to the TCEQ request for clarification on the 

CTG recommendations. Therefore, the TCEQ is not making a determination until the EPA 

provides clarification to the issues identified by the TCEQ and the TCEQ evaluates the CTG 

recommendations in context with the EPA's response. 

Proposed September 23, 2009 A-10 
DFW RACT, Rule, and Contingency SIP Revision 

APPENDIX A 

Dallas-Fort Worth Reasonably Available Control Technology Analysis Update 

Attachment 1 

December 8, 2008, Letter to Mr. William T. Harnett, Director, Air Quality Policy Division, 

United States Environmental Protection Agency on issues related to 

Control Technique Guidelines documents 

Proposed September 23, 2009 
• 

Buddy Garcia, Chaimuzn 

Larry R. Soward, Commissioner 

Bryan W. Shaw, Ph.D., Commissioner 

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

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas bg 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 C504-0 1 

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 ill, 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 arc detailed beiow. 

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

compound (VOC) emissions from the surface coating of large appliances1

, metal fumiturc2

, and 

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

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

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

coating ~es; however, the 2007 erG documents for Large Appliance Coatings5 and Metal Furniture 

Coatings 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' 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 CTO 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 OS reco~endations, TCEQ's Air Quality Division has. 

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

printed (ttl m:yclal f'Dpcr usinlt stl)'--biw:od ink 
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 detennine if actual VOC 

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

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

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

recommendations with regard to the following issues. 

I. Specific clarification is needed that implementing the recommendations in the new erG would 

not be considered backsliding. 

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

were umegulated 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 detennine the overall reduction benefit? Additional infonnation, 

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

implementing th~ erG 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 erG 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, 

~eeL .f=-susana M. Hildebrand, P.E. 

Director, Air Quality Division 

Texas Commission on Environmental Quality 

SMHILNsy 

Enclosures: References 

Emission Limit Comparison Table 

cc: Mr. Guy Donaldson, BP A R~gion 6 

Ms. Ellen Belk, EPA Region 6 

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

Mr. Bili Johnson, EPA, Office of Air Quality Planning and Standards 
Enclosure: References 

1: Title 30 TAC §115.42l{a)(l), Emission Specifications for Large Appliance Coating (Amended 

January 17, 2003). 

2: Title 30 TAC §115.42l(a)(2), Emission Specifications for Metal Furniture Coating (Amen~ed 

January 17, 2003). 

3: Title 30 TAC §115.42I(a)(9)(A), Emission Specifications for Miscellaneous Metal Parts and 

Products Coating (Amended January 17, 2003). 

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

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

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

III: Surface Coating of Metal Furniture, Publication number EPA-45012-77-032. 

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

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

015. 

S: 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 Docl,<et Number EPA-HQ-OAR-2007-0329-0009 and EPA Docket Number EPA-HQ-OAR2007-0334-0010. 
Enclosure: Emission Limi,t Comparison Table 

Comparison of30 TAC Chapter 115 Emission Limits and 2006-2008 CTG Recommended Emission 

Limits 

Chapter 115 CI'G Recommended 

Coating Type* Emission Limit** Emission Limit** · Baked Coating_ · Air-Dried Coatine 

Laree Appliance Coatlnt 

General, One Component 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 

Meta'llic 2.8 3.5 3.5 

Preu·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 CoatinK 

General One Component 3.0 2.3 2.8 

General Multi Coml?_onent . 3.0 2.3 2.8 

Camouflag~ 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 Perfonnance 3.5 3.0 3.5 

Heat-Resistant 3.5 3.0 3.5 

High Performance Architectural 3.0 6.2 6.2 

High Tem~erature 3.0 3.5 3.5 

Metallic 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 

ComQ_onent 

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 Cbapter 115 Emissio~ Limits and %006-2008 CTG Recommended Emission 

Limits 

Chapter 115 CTG Recommended 

Coating Type* Emission Limit** Emission Limit** Baked Coatlna Air-Dried Coating 

Vacuum-Metal izing 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 11 5 limits. 

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

application system. 

. . 
0 

Mr. William T. Harnett 

Page3 

December 8, 2008 

bee: Theresa Pella 

Ashley Forbes 

Vincent Meiller 

Lindley Anderson 

Amy Browning 
WRITTEN AND 

ORAL TESTIMONY 
Reference Number 

W-1 

W-2 

W-3 

INDEX OF WRITTEN TESTIMONY 

Submitted By 

Patricia Eldridge, Printing Industries 

of the Gulf Coast 

Guy Donaldson, Unites States 

Environmental Protection Agency 

Guy Donaldson, Unites States 

Environmental Protection Ag.ency 
.L ., 

-::.· ...... 

Docket No. 2009-0843-RUL 

TCEQ Public Hearing 

October 28,2009 

RECEIVED 

OCT !~ LUU!;j 

AlR Q_UAL.ITY 

9l'flliON 

Item: Chapter 115, Control of Air Pollution from Volatile Organic Compounds 

Volatile Organic Compounds {VOC) Control Techniques Guidelines (CTG) Update 

Rule Project No. 2008-019-115-EN 

My name is Patricia Eldridge. I am a Director with Printing Industries of the Gulf Coast (PIGC). 

PIGC is an affiliate of Printing Industries of America, which is the largest trade association for 

the printing and graphics industries with over 11,000 member companies worldwide. · 

PIGC's purpose is to serve as the official representative of the graphic communications industry 

in the Texas gulf coast region and further the cause ofthe industry in the areas of business, 

government, and to the general public. 

I would like to thank the Texas Commission on Environmental Quality for allowing me to speak 

with you today and offer our comments on this proposed rule. The association will be 

submitting formal written comments as well. 

While our written comments will focus on several specific sections of the rule, today I would 

like to focus my comments and concerns on two main areas: 

- 1. The economic impact on the businesses by the adoption and implementation of the 

proposed rule; and 

2. The overall benefit to public health given the number of business affected by the 

rule. 

First, I would like to provide a brief overview of the industry. The printing industry covers 

multiple processes, of which lithographic is just one. Most print operations utilize more than 

one process in their businesses with lithography being the most common. In fact, 75% of all 

print businesses have lithographic operations. 

It is also an industry of small business. By the government definition of small business, firms 

with less than 100 employees, the general commercial printing industry is 95% small business 

of which approximately 65% of those have ten or fewer employees. There are less than 20 

print facilities in the Texas gulf coast region that have more than 100 employees. 

W-1 
. , 

These small businesses have limited financial and technological resources available to them. As 

a result, more flexibility and options must be offered to them. 

And then there is the current economic situation. Printing has traditionally been one of the first 

industries impacted by economic downturns and one of the last to recover. As businesses scale 

back on their advertising, marketing, and promotions, the printing industry is hit hard by greatly 

reduced print sales and volume. Profit margins in the graphic communications industry are 

historically low compared to many other industries; but have really dropped since 2007. From 

2008-2009, margins have gone from 3.1% down to 1.6%. 

All of these factors are placing a tremendous burden o.n companies making it difficult to absorb . 

higher costs and cost-related activities. 

· Specifically, the ~'mandated" low VOC requirements for fountain solutions and cleaning solvents 

in the proposed rule will add undue hardship on these firms. The rule summary published 

indicated a "conservative 6% price increase" for these products. The actual price increase is 

more in the 40% range. 

' That means, if we use the 768 gallon per year threshold with the current average cost of $15.00 

per gallon for solvent, a company would see an increase in over $4,600 a year for that same 

amount of low VOC product. 

Another aspect is the overall effectiveness of low VOC solvents as cleaning agents. In general, 

low VOC cleaners have not had the same "cleaning ability" as a traditional higher VOC product. 

This means, in order to achieve the same result,. a clean blanket or roller, a larger volume of the 

·cleaner will be needed as well as an increase in the amount of time needed to adequately clean 

the rollers and blankets. So now a wash-up that would take 10-15 minutes could now take 

easily 20-30 minutes. At the current average press operator rate of $21.64 per hour, it could 

add $4 -$5 per wash-up to labor costs. Given the number of jobs run every day (on average) 

and the number of presses most companies have (again on average), they will increase their 

labor costs $60- $80 per day; $300-$400 per week; $1,200- $1,600 per month; or $14,400-

$19,200 annually. 

The $4,600 a year cost increase in product is for the equivalent amount of high VOC cleaner. 

That number does not take into account the increased amount of. low VOC solvent needed to 

clean the same amount of presses. Just adding the $4,600 product cost increase to the $14,400 

- $19,200 labor cost increase~ adds $19,000- $23,800 to a company's expenses. 
.. 

In discussing the use of low VOC solvents and cleaning products with printers, the feedback has 

been negative. Those who have tried them have mentioned that they do not work as well as 

the higher VOC material. To quote one printer, "our guys have said they (the more expensive 

washes) don't do as good a job." 

Lower vapor pressure solvents, although higher in cost than traditional cleaning solvents, is a 

more effective alternative. The product cost increase is not as high as low VOC products and 

most press operators do not see the greatly increased wash-up time that they experience with 

the low VOC materials. · 

Reducing the amount of alcohol substitute to 3% by weight with no alcohol in the fountain 

solution will be a tremendous change in production for most operations. It's not simply a 

matter of changing one product out for another- you are changing a process. Printing is not 

just a mechanical process; it is a chemical process as well. Equipment must be modified in order 

to accommodate the chemistry change and press operators must be trained in new procedures. 

In any case, all of these increased expenses will need to be passed on to the consumer. In 

addition, given the economic climate and the projection of its duration, these requirements 

could drive more printers out of business. No business, no jobs, no sales tax revenue, no 

property tax revenue. 

Incorporating best management practices such as towel handling procedures could be a viable 

low-cost alternative while reducing emissions. 

The 1990 Federal Clean Air Act states that air quality standards will be established. These 

standards must be attained and maintained to protect public health. 

When looking at the impact of the printing industry on the overall air emissions in the DallasFort Worth and especially Houston-Galveston areas, it is not a significant contributor. The 

Houston-Galveston area has perhaps five to seven lithographic facilities that are permitted and 

already using BACT. We estimate that 80 companies in the Houston-Galveston region have 

greater than 3 tons per year emissions. Approximately 70% of these firms, or 56 of them, are 

below ten tons of emissions. Given the intensive industrial nature of the Houston-Galveston 

area in the petrochemical and energy industries, the printing industry is a minor source of 

emissions. 
~ I ,\• 

Although there are several portions ofthe rule we can support since they follow the EPA's 2006 

Offset lithographic and Letterpress Printing CTG, there are a few noted exceptions TCEQ would 

like to adopt that are a concern to the printing industry. 

The items, such as the lower VOC cleaning solvents, due to their higher cost and reduced 

effectiveness will significantly increase production cost. Given the relatively low numbers of 

firms that would be affected in the Houston-Galveston area, the overall health benefit to the 

general public is negligible. The minor environmental benefit does not outweigh the high cost 

to small businesses. 

Printing Industries of the Gulf Coast is ready to continue to work with the TCEQ in finding 

solutions that are responsible, fair and equitable for all parties concerned. 

We thank you for the opportunity to review and comment on this vital piece of proposed 

legislation. 

Respectfully Submitted, 

Patricia Eldridge 

Director, Printing Industries of the Gulf Coast 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGtoN6 

1445 ROSS "VENU£, SUITE 1200 

DALLAS, TX 75202-2733 

Michael Parrish 

State Implementation Plan Team 

Office of Legal Services, MC 205 

NOV 0 9 2009 

Texas Commission on Environmental Quality 

PO Box 13087 

Austin, TX 78711-3087 

Dear Mr. Panish: 

Thank you for the opportunity to submit comments on the September 4, 2009 proposed 

revisions to the Texas Commission on Environmental Quality State Implementation Plan (SIP) 

revision titled.,"Chapter 115, Control of Air Pollution from Volatile Organic Compounds; 

Volatile Organic Compounds (VOC) Control Techniques Gtiidelines.(CTG) Update"; Rule 

ProjectNo. 2008-0 19-115-EN. This VOC RACT SIP is an important element of Texas' plan to 

address ozone air quality problems in the state. 

The Clean Air Act and subsequent federal regulations require Texas to submit a SIP 

revision to the· Environmental Protection Agency (EPA) that incorporates recent Control 

Techniques Guidelines (CTGs). These rule revisions include provisions related to The Offset 

Lithographic and Printing Press CTG issued by EPA in 2006. We appreciate the. efforts of the 

State in developing these SIP revisions. 

Our detailed comments on the proposed rules are included as ail attachment to this letter. 

Please contact me or Ms. Ellen Belkofmy staff at 214-665~2164 ifyou have any questions. 

SillCerely yours; 

,.., . J·j\ /f4 "-----· 

Guy Donaldson 

Chief 

Air Planning Section (6PD~) 

Enclosure 

Cc: Lindley Anderson 

Air Quality Planning Section 

W-2 
Detailed Comments 

Comments on Chapter 115, Control of Air Pollution from Volatile Organic Compounds; 

Volatile Organic Compounds (VOC) Control Techniques Guideliat4 (CTG) Update"; Rule 

Project No . .2008-019-US-EN, Proposed September 23, 2009. 

We have reviewed this ,action with respect to the Lithographic Printing Materials and Letterpress 

Printing Materials Control Techniques Guideline (CTG) issued by EPA in 2006 (7lFR 58745, 

October 5, 2006), and have the.following comments. 

Heatset Offset Lithographic Presses (TCEQ propo.sal, pp. S-7). 

1. Heatset Offset Lithographic Presses: DFW Area 

TCEQ is not proposing to implement any rule amendments or new rules for the DFW area 

associated with the recommended control reqUirements for heatset presses. However, the 

existing Chapter 115 requirements may not be as stringent as EPA's recommendations for 

control devices installed before the rule effective date in all instances, since an individual press 

with uncontrolied enrissions greater. than 25 tpy 'could be located on a site with total emissions 

less than 50 tpy when uncontrolled. V arlo~ databases were reviewed to identify heatset presses 

potentially subject to the CTG reco1111Ilendations.and it was determined that the heatset presses 

identified in the DFW area either meet or exceed the :reconunendations. 

RACT should be federally enforceable. Please explain why TCEQ believes it is appropriate to 

use permit conditions to implement RACT rather than adopting RACT thr()uglrthe rulemaking 

process and revising the affected provisions of Chapter ll 5 for an existing major VOC sourte. 

Please provide the facility-specific information used in this analysis. This should include 

infor.mation for each heatset press identified with uncontrolled emissions greater than 25 tpy 

located on a site with total emissions less than 50 tpy when uncontrolled, and provide all 

documentation relied on for the analysis, including permit information.and other documentation 

as applicable. 

2. Heatset Offset Lithographic Presses: Control Requirements for ·Future Equipment 

Installations 

"The commission does not agree thatapplying RACT standards to future equipment installations 

is necessary to meet1he mandates ofthe FCAA under §§172(c)(l), l82(b)(2), and 182(t)" 

(TCEQ proposal, p. 7). 

EPA disagrees with this statement. Please remove this language as well as any similar 

statements included elsewhere in the revisions. Such statements may have implications for 

approvability for RACT, RACT should apply to both existing and new sources. 

2 
Cleaning Solution (TCEQ proposal, pp. 7 -8). 

EPA continues to believe work practice requirements provide reasonable, cost effective ways to 

reduce emissions and that these control requirements should be met. In order to meet RACT 

requirements, the state should either adopt rules implementing the work practice requirements, or 

provide analysis demonstrating that the requirements are satisfied by existing federally 

enforceable rules. 

3 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGIONS 

1445 ROSS AVENUE, SUITE 1200 

DALLAS, TX 75202-2733 

Mary Ann P. Cook 

State Implementation Plan Team 

Chief Engineer's Office, MC 206 

NOV ·0 9 2009 

Texas Commission on Environmental Quality 

PO Box: 13087 

Austin, TX 78711-3087 

Re: TCEQ Project No. 2009-021-SIP-NR 

·Ms. Cook: 

We appreciate the opportunity to comment on the proposed revisions to the Dallas-Fort 

Worth (DFW) State Implementation Plan (SIP). These revisions address three issues: an 

updated Reasonably Available Control Technology (RACT) determination that incorporates 11 

control technique guidelines (CTGs) issued through 2008; incorporation of the revisions to 30 

Texas Administrative Code (T AC) Chapters 115 and 117 into the SIP; and removal and 

replacement of a 30 T AC Chapter 115 rule contingency measure. Our comments follow. 

RACT Deteffii.ination 

This revision updates the Volatile Organic Compound (VOC) RACT analysis component 

of the DFW 1997 8-hour ozone attainment demonstration to include the state's analysis of the 

CTG documents issued by EPA in 2006, 2007, and 2008. However, EPA will be able to 

consider approval of the VOC RACT update only for those CTGs that have been thoroughly 

addressed. Our detailed comments are attached to this letter. 

30 TAC Chapter 115 Contingency Measure 

The offset lithograph printing.rule and the associated 0.24 tpd predicted in emissions 

reductions for VOCs is removed as a contingency measure. The estimated surplus of emissions 

reductions from fleet turnover in the DFW area, should the area fail to meet the 1997 8-hour 

ozone standard by June 15, 2010, would substitute for the shortfall left by the removal of the 

offset lithograph printing rule as a contingency measure, as well as the revision to 30 T AC 117 

described above. We agree with the state's calculations. 

Table 4.2 (Calculations Showing Three Percent Required Reductions) on page 4-l 0 of 

W-3 

the proposed revision includes a 1999 adjusted base year·emissions inventory (EI). The numbers 

for the adjusted EI however, are the same as those used in the Federally-approved SIP, which 

does not characterize the 1999 base year EI as an adjusted inventory. In addition, Appendix: B of 

the state submittal for tJ?,e 1997 8-hour ozone attainment demonstration does not characterize the · 

1999 EI as an adjusted inventory. For clarity and consistency, please confirin whether or not the 

1999 inventory has been adjusted. 

RecyclediRecyclsble • Pmted with Vegetable 01 Based Inks on 100% Recycled Paper (40% Poslconsumer) 
· We appreciate the opportunity to comment on these proposed SIP revisions. Should you 

have questions on. our RACT comments, please contact me or Ms. Ellen Belk of my staff at 214~ 

665-2164. Should you have questions on our other comments, please contact me or Ms. Carrie 

·Paige of my staff at 214-665-6521. 

Sincerely yours, . 

~~·· Guy Donaldson 

Chief 

. Air Planning Section(6PD-L) 

·Enclosure: Detailed Comments (4 pages) 
Detailed Comments 

We have reviewed this action with respect to the Clean Air Act (CAA) and the Control. 

Techniques Guidelines (CTGs) issued by EPA in 2006,2007, and 2008, and have the 

following comments. 

Work Practice Requirements: For a number of CTG categories,TCEQ bas chosen not to 

adopt the rec~mmended work practices. For all applicable CTGs, EPA continues to 

believe work practice requirements provide reasonable, cost effective controls and that 

these requirements should be met. EPA continues to believe that work practice 

requirements are an important way to reduce emissions. In order to meet RACT 

requirements, the state should either adopt rules implementing the work practice 

requirements, or provide analysis demonstrating that the requirements are satisfied by 

existing rules. · 

CTG categories: Industrial Cleaning Solvents, Miscellaneous Industrial Adhesives, Large 

Appliance Coatings, Metal Furniture Coatings and Miscellaneous Metal and Plastic 

Parts Coatings (section 4.3.1.3, and Appendix A). For these five CTGs, Texas has 

neither adopted rules nor provided a negative declaration. In order for the DFW area to 

meet the requirements for RACT (40 CFR 51.912), the state will need to complete RACT 

determinations and take appropriate action for the CTG categories of Ind~trial Cleaning 

Solvents, Miscellaneous Industrial Adhesives, Large Appliance Coatings, Metal 

Furniture Coatings and Miscellaneous Metal and Plastic Parts Coatings. EPA will be 

able to consider approval of the VOC RACT update only for those CTGs that have been 

thoroughly addressed. - · 

We recognize that EPA has not yet responded to the TCEQ letter of December 8, 2008 

· concerning the CTG documents for Large Appliance Coatings, Metal FurnitUre Coatings; 

and Miscellaneous Metal and Plastic Parts Coatings (section 4A.l.3, and Appendix D). 

While the new CTG documents for these source categories recommend more stringent 

limits for general use coatings, there are some specialty categories for which the new · 

CTGs recommend limits that are less stringent than the general use limits established in 

the guidance from the 1970s. For some of the subcategories within these CTGs; the 

limits in the new CTGs are less stringent than the approved Texas SIP, so it is possible 

the new limits will result in·increased emissions. In general, EPA expects the limits in 

the CTG to result in reductions in VOCs, but it is unclear for specific states or areas 

whether overall reductions will occur. 

We believe that Texas has at least two options for moving forward with the specialty 

coating types discussed above. The state could leave the limits in place for the specialty 

categories where the existing limits are more stringent than the limits. in the CTGs or the 

state could relax the limits consistent with the new CTG, in which case Texas would have 

to provide additional analysis to show compliance with 110(1) of the CAA. We note that 

Texas is not required to adopt the less stringent limits in the CTG. The CTG provides 

recommendations, but does not bind states to adopt specific limits or requirements to 

1 
meet RACT. If the existing Texas rules as they apply to specialty categories are more 

stringent than the limits recommended in the CTG, the state could choose to submit them 

as meeting the RACT requirement, and, assuming all other requirements are met, we 

anticipate that we would be able to approve them as meeting RACT for the source 

categories. addressed by the CTGs. The state would still need to evaluate the more 

stringent recommendations for general use categories and adopt them as appropriate. If 

Texas chooses to relax limits for specialty coatings that are in the approved SIP 

consistent with the recommended limits .in the CfGs, the state would need to demonstrate 

under section 11 0(1) that the SIP as revised ·would not interfere With attainment of or 

reasonable further progress toward attainment of the National Ambient Air Quality 

. Standard (NAAQS) or interfere with any other applicable requirement ofthe CAA. In 

general, if a submitted revision .achieves the same or greater emission reductions as the 

approved SIP within the same tirneframe as provided under the existing plan, we have 

been able to approve the revision as meeting section 11 O(l) . • 

Flat Wood Paneling Coatings (section 4.3.1.1 and Appendix A). No comments. 

Fiberglass Boat Manufacturing Materials (section 4.3.1.2 and Appendix A): For the 

Fiberglass Boat Manufacturing Materials source category, TCEQ has identified no 

facilities in DFW subject to this CTG (pages 4-8, D8 and D-9). However TCEQ is not 

making a definitive negative declaration for this source category. Instead, the TCEQ 

"has determined that implementing the recommended controls in the Fiberglass Boat 

Manufacturing Materials CTG document would neither result in substantive VOC 

reductions nor be economically feasible." 

The proposal relies in part on EPA's prior guidance, "Issues Relatirig to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, Clarification to Appendix .b of November 24, 

1987 Federal Register", issued May 25, 1988; In particular, please see Attachment 2 of 

the guidance, for an Example 5% Rule Calculation. This calculation should be based · 

specifically on sources in the Dallas-Fort Worth area. We do not believe the TCEQ's 

interpretation ofthis 1988 guidance is.correct. EPA continues to believe that these are 

cost effective controls. To meet VOC RACT requirements this category needs to be 

addressed. 

Automobile and Light-Duty Truckhsembly Coatings (section 3.3.1,·and Appendix A). 

RACT should be federally enforceable. Please explain why TCEQ believes it is 

appropriate to use a pennit condition for a facility in the affected area to implement 

RACT. Please provide a copy of the fmal permit(s) used in this analysis, including 

permit information for General Motors Corporation Arlington Assembly Plant 

Regarding work practice requirements, please see the comment above. 

Flexible Packaging Printing Maierials (section 4.3.1.2 and Appendix A). 

RACT should be federally enforceable. Please explain why TCEQ believes it is 

appropriate to use a permit condition for a facility in the affected area to implement 

2 
RACT. Please provide a copy of the fmal permit(s) used in this analysis, including 

permit information for Printpak Inc. 

Regarding work practice requirements, please see the comment above. 

Paper, Film, and Foil Coatings (section 4.3.1.2 and Appendix A). RACT should be 

federally enforceable. Please explain why TCEQ believes it is appropriate to use a 

permit condition for a facility in the affected area to implement RACT. Please provide a 

copy of the final permit(s) used in this analysis, including permit information for Rock 

Tenn Converting Company and Printpak. Inc. 

Regarding work practice requirements, please see the comment above. 

Lithographic Printing Materials and Letterpress Printing Materials (section 4.3.1.4 and 

Appendix A). Detailed comments regarding this are included in a separate letter 

addressing these rule revisions. (Rule Project No. 2008-019-115-EN). Since this 

rulemaking is specifically discussed in section 4.3 .1.4 and Appendix A of the proposal, 

our comments are also included here. 

Heatset Offiet Lithographic Presses (Appendix A, pp. AS and A6). 

1. Heatset Offset Lithographic Presses: DFW Area 

TCEQ is not proposing to implement any rule amendments or new rules for the 

DFW area associated with the recommended control requirements for heatset 

presses. However, the existing Chapter 115 requirements may not be as stringent 

as EPA's recommendations for control devices installed before the rule effective 

date in all instances, since an individual press with uncontrolled emissions greater 

than 25 tpy could be located on a site with total emissions less than 50 tpy when 

uncontrolled. Various databases were reviewed to identify heatset presses 

potentially subject to the CTG recommendations and it was determined that the 

heatset presses identified in the DFW area either meet or exceed the 

recommendations. 

Please provide the facility-specific information used in this analysis. This should 

include information for each heatset press identified with uncontrolled emissions 

greater than 25 tpy located on a site with total emissions less than 50 tpy when 

uncontrolled, and provide all documentation relied on for the analysis, including 

permit information and other documentation as applicable. · 

RACT should be federally enforceable. Please explain why TCEQ believe~ it is 

appropriate to use permit conditions to implement RACT rather than adopting 

RACT through the rulemaking process and revising the affected provisions of 

Chapter 115 for an existing major VOC source. 

3 
2. Heatset Offset Lithographic Presses: Control Requirements for Future 

Equipment Installations · 

"The conunission does not .agree that applying RACT standards to future 

. equipment installations is necessary to meet the mandates ·of the FCAA under 

§§172(c)(l), 182(b)(2), and 182(f)" (TCEQ proposal,"p. 7). 

EPA disagrees with this statement. Please remove this language as well as any 

similar statements included elsewhere in the revisions. Such statements may have 

implications for approvability for RACT. RACT sh~uld apply to both existing 

and new sources. ·· 

~. Cleaning Solution 

EPA continues to believe work practice requirements provide reasonable, cost · 

· effective ways to rectuce emissions and that these control requirements should be 

met. In order to meet RACT requirements, the state should either adopt rules 

implementing the work practice requirements, or provide analysis demonstrating 

that ~e requirements are satisfied by existing federally enforceable rules. 

4 
INDEX OF ORAL TESTIMONY 

Reference Number Submitted by 

0-1 Joe Polanco, Printing & 

Imaging Association of MidAmerica 
Page 1 

.TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

PUBLIC HEARING REGISTRATION 

October 29, 2009, 1 :00 p.m~ 

Location: Austin, 12100 Pari< 35 Circle, Building E, Room 2018 

Rule Project Nos.: 2009-021-BIP-NR, DFW RACT, Rule, Contingency SIP Revision, 

2008-019-115-EN, Chapter 115 Offset Lithographic Rule Revision 

Presenting If Yes, check all NAME Oral 

(Please Print) REPRESENTING Testimony? projects 

(Circle One) to comment on 

Offset 

{! lt,J ·J- Cbev 1r/ £-rL ~u t)1'T" ~>~u- ('b~otr~ Vas~ f'"D~ Litho .t. s Rule 

I 

w~.\:S~~ li?\C_ fi...~ y Tr~u- ~r_ Yes ~ i)~\N 

Yes No 

Yes . No 

Yes No 

Yes No 

Yes No 

Yes No 
BEARING OFFICER REPORT 

I am the hearing officer assigned to conduct the public hearing regarding proposed 

reVisions to 30 TAC Chapters 101 and 115 rules and corresponding revisions to the state 

implementation plan for the control of ozone air pollution. (Rule Project Nos. 2008-019-

115-EN, 2009-006-101-EN, and 2009-021:.SIP-NR) 

A public hearing was scheduled for October 29,2009 at 1:00 p.m. in the Texas Commission 

on Environmental Quality complex, Building E, Room 201S, 12100 Park 35 Circle in Austin, 

TX. 

At 1:00 p.m., the room was open, TCEQ staff and a court reporter were present and ready 

to open the hearing for public comment. After waiting for 15 minutes, no one had 

arrived to make comments on the record. Therefore, the public hearing was not formally 

opened for comment and ·no transcript was prepared. 

~·' 12 ' ' ' . 

, ... 

Date signed· 
PUBLIC HEARING 

BY THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

ON PROPOSED REVISIONS TO 30 TAC CHAPTER 115, AND TO THE 

STATE IMPLEMENTATION PLAN 

******************************************************* 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

PUBLIC HEARING 

NOVEMBER 2, 2009 

****************************************************** 

BE IT REMEMBERED that the above-entitled 

meeting came on the 2nd day of November, 2009, from 

2:02 p.m. to 2:11p.m. at the Texas Commission on 

Environmental Quality, Region 4 Office, DFW Public 

Meeting Room, 2309 Gravel Road, Fort Worth, Texas, and 

the following proceedings were reported by me, Lauren M. 

Morrison, Certified Shorthand Reporter in and for the 

State of Texas. 

l"\'1~ 1\Tl\l1~ 1l '{ . ---~-~---

l:t 1~PO lt'I'Il\!.G· 

8l~It\71C1~ 

a record of excellence 

1801 Lavaca • Suite 1Ui • Austin, Texas 78701 • 512-474-2233 

I 
1 P R 0 C E E D I N G S 

2 MONDAY, NOVEMBER 2, 2009 

3 (2:02p.m.) 

4 MS. COOK: Good afternoon. Today is 

5 November 2, 2009. I would like to welcome everyone to 

6 this public hearing conducted by the Texas Commission 

7 on Environmental Quality. My name is Mary Ann Cook. 

8 I'm with the Air Quality Division of the Chief 

9 Engineer's Office. Additional TCEQ staff here today 

10 are Teresa Pellae and Kathy Singleton. 

11 We are here to receive oral and written 

12 comments on proposed revisions to 30 TAC Chapter 115 

13 rules and corresponding revisions to the State 

14 Implementation Plan for the control of ozone air 

15 pollution under the requirements of Texas Health and 

16 Safety Code, §382.017; Texas Government Code, Chapter 

17 2001, Subchapter B; and 40 Code of Federal Regulations, 

18 §51.102 of the United States Environmental Protection 

19 Agency concerning State Implementation Plans. 

20 The proposed rule revisions apply to 30 

21 TAC Chapter 115, Subchapter E, Division 4, for offset 

22 lithographic printing, the proposed Dallas-Fort Worth 

23 reasonably available control technology update, 30 TAC 

24 Administrative Code Chapter 117 rule revision, 

25 noninterference demonstration and attainment 

2 
1 demonstration contingency plan supervisio~, revises and 

2 supplements the DFW area's demonstration of attainment 

3 for the 1997 eight-hour ozone standard. 

4 This proposed SIP action updates the DFW 

5 reasonably available· control technology, or RACT, 

6 demonstration for volatile organic compounds, or VOCs. 

7 It incorporates the proposed 30 TAC Chapter 115 Rule, 

8 Subchapter E, Division 4, regarding offset lithographic 

9 printing rule revisions. It incorporates revisions to 

10 30 TAC Chapter ~1 7, which was proposed on August 12, 

3 

11 2009, and demonstrates noninterference of that rule with 

12 attainment of the 1997 eight-hour ozone standard. And 

13 further, it revises the failure-to-attain contingency 

14 plan. 

15 If you intend to present oral comments on 

16 either of these proposals and have not yet signed in~ 

17 please sign in now at the registration table. We have 

18 copies of the rule, of the SIP, hearing notice, and a 

19 key in the back. We have plenty copies, so take them. 

20 We will also be continuing to accept --

21 TCEQ will continue to accept written comments on this 

22 proposal -- these proposals until Monday, November 9, 

23 2009. This hearing is strictly for receiving oral or 

24 written comments. Open discussion may not occur during 

25 the hearing; however, if you have any additional 
1 questions regarding the proposals, there should be 

2 additional opportunity to speak with staff after the 

3 hearing. 

4 We will now begin receiving comments in 

5 the order in which you are registered. Once I call your 

6 name, please come to the -- we don't have a podium 

7 front, state your name and whom you represent, and 

8 provide your comments. 

9 I believe we only have one person signed 

10 in, and that would be Mr. Joe -- Polanco? 

11 

12 

13 

MR. POLANCO: Polanco. 

MS. COOK: with PIA MidAmerica? 

MR. POLANCO: Correct. Do you want me 

14 from here to stand? What's the best way to do it? 

15 MS. COOK: I think if you got up here 

16 and faced that way maybe. Is that okay? 

17 MR. POLANCO: Face the camera or back 

18 MS. COOK: I think here. 

19 MR. POLANCO: Okay. 

. 20 MS. COOK: Don't you guys think? 

21 COMMENTS ON BEHALF OF 

22 PRINTING & IMAGING ASSOCIATION OF MIDAMERICA 

--

23 

24 Polanco. 

MR. POLANCO: Good afternoon. I'm Joe 

I'm the president of the Printing & Imaging 

25 Association of MidAmerica. We're the trade 

4 
1 association that rep~esents commercial and advertising 

2 printers in Texas as well as Dallas-Fort Worth, of 

3 course, being impacted by Chapter 115. I'm going to 

4 skim through this very quickly. I've made written 

5 comments to the state in this format as well as what 

6 I'm going to say today, so I want to highlight this. 

7 We've already prepared comments already to 

8 the state, submitted last week, predominantly on a 

9 variety of suggestions on the language, which would make 

10 the proposed regulations more consistent with the EPA's 

11 Control Technique Guidelines as well as simplif~ing the 

12 process of compliance. 

13 This afternoon I really want to focus on 

14 the size of the impacted community and explore the 

15 concept that the proposed regulations may not have a 

16 significant impact on reducing emissions in the 

17 Dallas/Fort Worth area. 

18 Per our internal records as well as data 

19 from the Comptroller's office, we estimate there are 

20 approximately 900-1000 printing companies in the DFW 

21 area. Because of major shifts in technology affecting 

22 the industry and today•s present economic conditions, we 

23 anticipate that this number will decrease by 15 to 20 

24 percent over the next two to three years. 

25 We also estimate that about 15 percent of 

5 
1 those so-called printers are really virtual. They are 

2 really manufacturers' reps that do not have any printing 

3 facilities at all. Along those same lines, 15 to 20 

4 percent of the remaining -- excuse me. Let me rephrase 

5 that. 

6 We estimate about 15 percent of all the 

7 printers that are less than three tons of VOCs, that are 

8 presently going to be exempt under this new proposed 

9 regulation, are migrating away from offset technology. 

10 Within three to five years, they will not be using 

11 offset technology but digital technology, whic~·does not 

12 emit any kind of VOCs. 

13 Yet, a portion of the industry will 

14 continue to use lithographic technologies, which are 

15 predominantly the larger printers, because of mass 

16 marketing. It's very economical to produce that way. 

17 And those companies will continue to operate. We 

18 estimate there are about 140 companies in the DFW area 

19 which fall in that greater than three tons of VOCs. 

20 We also want to bring it up to TCEQ that a 

21 significant number of these companies no longer use 

22 isopropyl alcohol on a daily basis. They have gone 

23 alcohol-free, so to speak. We also estimate, based on 

24 conversation with suppliers, that -- and this is an 

25 estimate -- that probably the entire industry consumes 

6 
1 no more than 80 tons of alcohol a year. Of those 140 

2 companies, which are considered major printers, 

3 approximately 30 of those companies emit more than 10 

4 tons. That's based on the 2007 emissions inventory that 

5 was submitted to the TCEQ. And only a handful of those 

6 emit more than 50 tons. 

7 Based on discussions with suppliers, 

8 printers, we estimate the total emissions from the 

9 impact of companies are about 1,400 tons per year. 

10 Companies who are permitted and following RACT 

11 guidelines probably -- excuse me. Let me rephra~e that. 

12 Companies who are permitted are following RACT 

13 guidelines; thus, it's the remaining companies who will 

14 be the target of these proposed rules. We 

15 conservatively estimate that that group, if you will, 

16 emits about 600 tons of emissions. 

17 If we do the math, we're talking reducing 

18 VOCs through clean solids. Predominantly you'll be 

19 reducing the amount of VOCs we have there. Many of 

20 those companies are already alcohol-free, so there's 

21 going to be very little gain by going alcohol-free. 

22 We would assume, in our calculations, 

23 we're talking about 180 tons reduction of VOCs in a 

24 year. That's less than one ton per day. The question 

2 5 we ask as an industry: Is this a significant amount, 

7 
1 especially as we calculate a cost of $10,000 per ton of 

2 vocs. 

3 Consequently, we would like to recommend 

4 to the TCEQ they would further study and analyze the 

5 actual size of the inventory of commercial lithographic 

6 printers in the DFW area and determine if implementing 

7 the proposed rules, Ch. 115, will truly provide a 

s significant reduction in emissions. 

9 We feel that the data we've been operating 

10 from over the years has changed dramatically, that the 

11 industry has made a lot of impact as far as pro.cess 

12 controls to reduce the emissions. And because the 

13 industry has shifted from a very large and very 

14 segmented industry to a much smaller industry, that the 

15 actual impact is much smaller than anticipated. 

16 So again, those are my comments. Thank 

17 you. 

18 MS. COOK: Thank you. Is that the same 

19 as this? 

20 MR. POLANCO: Same thing. 

21 MS. COOK: Okay. 

22 Are there any other comments? 

23 Okay. Once again, the deadline for 

24 comment receipt is November 9, 2009. All comments 

25 should reference the applicable rule or SIP project 

8 
9 

1 number. Copies of the proposed rule and SIP provisions 

2 are also available from the Commission•s website. 

3 Please feel free to pick up a handout that 

4 has those web addresses, on the back table. If you 

5 would like to sign up to receive e-mail updates when new 

6 information is added to our SIP hot topics web page, 

7 sign-up instructions are also provided on that handout. 

B We thank you for your interest in DFW air 

9 quality and for attending this hearing. We appreciate 

1 0 your comments . 

11 If there are no further comments,! then 

12 this hearing is now closed. 

13 {Hearing adjourned: 2:11p.m.) 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 
1 

1 C E R T I F I C A T E 

2 STATE OF TEXAS 

3 COUNTY OF TRAVIS 

4 I, Lauren M. Morrison, a Certified 

5 Shorthand Reporter in and for the State of Texas, do 

6 hereby certify that the above-mentioned matter occurred 

7 as hereinbefore set out. 

8 I FURTHER CERTIFY THAT the proceedings of 

9 such were reported by me or under my supervision, later 

l.O reduced to typewritten form under my supervision and 

11 control and that the foregoing pages are a full, true 

12 and correct transcription of the original notes. 

13 IN WITNESS WHEREOF, I have hereunto set my 

14 hand and seal this 5th day of November 2009. 

15 

16 

17 

18 

19 

20 

2.1 

22 

23 

24 

25 

Lauren M. Morrison 

Certified Shorthand Reporter 

CSR No. 8909 - Expires 12/31/11 

Firm Registration No. 276 

Kennedy Reporting Service, Inc. 

Cambridge Tower 

1801 Lavaca Street, Suite 115 

Austin, Texas 78701 

512.474.2233 
ragt: 1 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

PUBLIC HEARING REGISTRATION 

November 2, 2009, 2:00p.m. 

Location: TCEQ Regional Office, 2309 Gravel Drive, Fort Worth 

Rule Project Nos.: 2009-021-SIP-NR, DFW RACT, Rule, Contingency SIP Revision, 

2008-019-115-EN, Chapter 115 Offset Lithographic Rule Revision 

Presenting If Yes, check all NAME Oral 

(Please Print) REPRESENTING Testimony? projects 

(Circle One) to comment on 

® DFW Offset 

0LLvv\'B ?a_t'~-G Yes SIP Litho lAS ~PA ·'R(, Rule 

... d 

C!xl/s~l La LlJ.$' G'Y\ ['i_,. L1__0_Wa.ut flssot)q_ ./Ps Yes (3 

l ~ j 

Yes@ k: +~ fv1c /G.'-~ ,, ,, 

jj/qcZ. ac ~ 1-v' a fr/(,(_ (;1/c,l'J t{~scc . tf( .> Yes~ r:> 

~···· ~ .:::t () ~ OLA-Nl CO en~ IV\~~ J ~r C/J. 

€}No ?( 

cl/xl~ (/ftvr jU{·-{c;eJ() Yes ~ 

R,·fa- l£hl 'CI.f) l!:>e111\ttvVL Yes @> 

G-"7 0 0 '""'0- \) 3 ·~""" HPA Yes G) 

I 
t'age L. 

. 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

PUBLIC HEARING REGISTRATION 

November 2, 2009, 2:00 p.m. 

Location: TCEQ Regional Office, 2309 Gravel Drive, Fort Worth 

Rule Project Nos.: 2009-021-SIP-NR, DFW RACT, Rule, Contingency SIP Revision, 

2008-019-115-EN, Chapter 115 Offset Lithographic Rule Revision 

Presenting If Yes, check all NAME Oral 

(Please Print) REPRESENTING Testimony? projects 

(Circle One) to comment on 

@ DFW Offset 

e-- /Zep ,]&e /3 "/ ,fo 11..- Yes Litho .Ji·i .~~ k~~/ / f.l7fctr SIP Rule 

Yes No 

Yes No 

Yes No 

Yes No 

Yes No 

Yes No 

Yes No 
EVALUATION OF 

TESTIMONY 
To: 

Prom: 

Docket No.: · 

. Subject: 

Commissioners Date: Februmy 19, 2010 

LaDonna Castduela, Chief Clerk 

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

Suaa..aM. Bildobraud. P.E., Cllief~ 

2009-1127.SIP 

·Commission Approval .foi Adoption .of RoviSions to the State of Texas Air Quality 

Iinplementation Plan for the Control of O.mne Air Pollution: · 

The :o.Ilas-Fort Worth (DFW) Reasonably Available Control T~logy (RAC'l) 

Update, 30 Texas AdmiDistrative Code (I'AC) Chaptar 117 Rule bvision Nonin.terfarence 

Demonstraticm, BDd Modified Failm.to-Attain Contm.gengy Plan State Implementation 

·Plan (SIP) Revision (DFWRACT, RDle, and Cnntinpncy SIP Revision) . . . 

Rule Project No. 2009-021-SJP .. NR, . 

Baclcground ud reasoia(s) for t.·SJP J."eWision: · ··. · · · · . · : . 

Ibis DFW RACT, Rule, and Contingency. S1P ReViSion integrates sevoral actions required by the United 

States Environmental Protection Agtmr:y (EPA) iDto iJle State of Texas Air Quality ImplemcntatioQ. Plan for 

the Control of Ozone Air Pollution applicable to the DFW 1997 eight-hour ozone standard nonattainment 

arD& (ColliD. Dallas, ~ BUis, Kaufmtrft', 1~ Parkat, RockWall, and Tammt Counties). It . 

supplements and~ the DFW 1997 eight-hour ozone pttainment demonstration. 

The DFW RA.CI', Rule, and Contingency SIP Revision includes RACI' determinations for certain volatile 

organic compounds (VOC) emission sources in the DFW area, as required by the 1990 Federal Clean Air Act . 

(FCAA) Amoodments u.ndcr §172(cXI) and §182(b)(2) and (f). Pevolopment of the voc RACI' update 

was required to address the EP A1s issuance of 11 control teclmiques guideliJias (CTG) ~ ~ 

2006 and 2008. 

Two state rule revisions are incorporated in this SIP revision. One is a 30 TAC Chapter 115 rule rovision 

govmning o:ffsot lithographic printing emission sources to be adopted CODCUr'l'CJ1tly with the SIP revision. 

That rule revision resulted :from the state's analysis of an applicable CTG doCU1Ilei11: d the subsequent 

RACI' determination for offset lithographic .printing emission sources. Also incorporated into the SIP 

revision is a Chapter 117 rule revision adopted by the commission on JanWilY 13, 2010. That rule rmsion 

resulted from the commission's.approval of a rulemaldng petition filed by the Elk Corporation. The reVision 

exempts from Chapter 117 regulation low tm:npemtnre dty:ing and curing ovens used in mineral wool-type 

fiberglass manufacturing and wet-1aid, non-woven fiber mat manufactu.ring where ni1rogen-containing resins 

or other additives are used. Bocause that rule revision leads to a small potciitiai omission reductions loss, this 

SlP revision allocates surplus nitrogen oxides (NOx) emission reductions from vehicle t1=t turnover to occur 

between 2009 and 2010 to substitute for .any control strategy reciuctiOna. that may be lost from the rule 

revision. Replacing the control strategy reductions serves to maintain integrity of the attainment 

domonstration and shows that the revised Chapter 117 rule does not interfere with attainment of the 1997. 

eight-hour omne standard in the DFW area. This demoDstmtion of n~ or § 11 0(1) 

demonstration, is required by the FCAA to address backsliding issues. 
Cnmmissioncrs 

Pap2 

February 19, 2010 

Ra: Docket No. 2009-1127-SIP 

This SIP revision also modifies the DFW 1997 eight-hom ozone attainment demonstration contingoncy plan. 

An eirliat vetmOil of the omet lithographic printing mle ichmtified as a coiltiiigmc)' measure for the DFW 

aroa has become unavailable for use in the contingency plan. That role is no longer available for contingency 

use because it bas bean revised in accordance wi1h the ~ct detarmination made for -those sources. and the rmsad rule is now considered RACI'. ·'Iherefore, the offset lithographic .printing rule can no longer be 

included in the :fBilure-to-attain contingeilcy plan for ~ DFW area. . To replaco ~ emissions reductions 

from offset lithographic printing sources, ·this SIP misimi allocates a portion of Sinplus emission redUdions 

to result from vehicle fleet turnavor to the contingency plan. This action ·serves to majntain a viable failureto-attain contingency plait for 'the DFW area. . The modified contingency pla'il retains two provioliSly 

idontified state 1'l11es {applicable in ColliD. DalW., DentoD, and Tarrant .Colmties) for degassing or cleaning 

_process08 of stationary; ma:ti:ne_ and transport vaisols; BDd for patrol~-haSed dry cleaning. as contingency 

measures as well.as vehicle fleet .turJlCJVor·emission i'eductiOD.il pi'eviously COJDII1itted far contingency, along 

WDh the additional fleet tumovar reductions allotted in this SIP revision. Tho plan provides emission 

reducti011S su:fficient to meet. the FCAA requiramebt for a 3 parcant · conti11gcncy for the attsimnent 

.demonstratiOJl. . 

Scope of the SIP midoa.: . . ' . . 

This DFW RACT. Rule. and Contingency SIP Revision integrates seveml actions required by the BP A into 

the State of Texas Air Quality Implementation Plan fur the Control of Ozone Air Pollution applicable to the 

DFW 1997 eight-hour ozone standard ll0Jll¢hrimnent area {ColliD, Dallas, Dcmton, Ellis, Kaufman, Johnson, 

P~. Rockwall. and Tarrant Counties). . . · . •• ,J .. · ' .• . 

A) summary of what t1ae SIP l'ftiDon will do: 

This SIP ,revision supplements and revisos the DFW 1997 oight-hour ozone attaimncmt demonstration and 

fulfiils·BPA requirel1ieiits for several,acticms· to be Dicmporated into·the Texas Air,Qiiality Plan .for. the 

Con1rol of Ozone Air Pollution. ·The mrision supplomonts .and .revises the DFW 1997. eight-hour .bzolle 

standard attaimneDt demonstration to incmporate recent Chapter 115 and Chapter 117 rule revisions, updated 

VOC RACI'-deteanin&tiODS, a §ilO(l) demonstration of·nonin1mfmm0e; and .a modified ~to-attain 

contingency plan. . '. 

B) Seope required by federal ~tioDI or state Ratlrtes: 

Under the 1997 eight-hour ozone standard, the DFW nine-county nonattaimnent area is required to meet tbt . 

mandates ofthc FCAA under §172{cX1) and §182(b){2) and {f). According 1D the EPA's Final Rule to 

Jmplimlent the Eigbt-Hotlr Ozone Naticmal Ambient Air Qoalit¥ Standards. {NAAQS) { 40 Code of Fcdcmil 

R.eguhmons (CFR) §51.912, November 29, 2005), .the Biea must submit, as a revision to the SIP., a 

demonstration that current rules fulfill the ·1997 eigb,t-hour RACI' requirements for an CI'G 'categories. The 

11 cro ·docmnents addressed in this SIP revision war; issued between 2006 and 2008 by the EPA and have 

not been addressed in a pteV'ious SlP revision. · · 

·'Jb FCAA (42 USC §7502{cX9) and §7Slla(cX9)) and the EPA tinai Phase 2 1997 ·eight-hour ozone 

implomentation m1c (70 FR 71612) require that state SIPs for alll997 eight-hour ozcme nonattainment areas 

include contmgcncy measures as additional controls to further reduce· mnissions in the event an area fails to 

attain by its attainment .date. The contingency measures idantified for implementation must provide for 

emissiOns reductions equiva1elit to 3 percent of the base-year emissions inventory ustld :in development of the 

. applicable f11faimncmt dmnonstration. · The FCAA requires replacement of any reductions .removed from a 

contingency plan to maintain the 3 percent reduction contingency requirement. 

The FCAA requires a § 11 0(1) demonstration of nonintmferonce in :the form of a SIP submittal for potential 

backsliding issues. Because the Chapter 117 rule revision creates a small potential emission reduction loss 1D 
Commissioners 

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February 19, 2010 

Ra: Docbt No. 2009-1127-SJP 

the DFW ozonc control stlatc&Y, emission reductions to offset the potential reduction loss are replaced via. 

this S1P revision, dmnonstrating that the rule revision will not ~ere with the area's attainment status. 

C) Additional atlifr recommendatiou that are Bot required by fecleral rale or state ltatate: N~ . 

Statutory authority: 

The authority to adopt this SJP revision is derived from Texas Health and Safety Code, Texas Clean Air Act 

(TCAA), §382.002, which provides that 1be policy and pmpose of1he TCAA is to safeguard the state's air 

resources from pollution; TCAA, §382.011, which au1:horiZes the commissiop. to control the quality of the 

state's air; and §382.012, which authorizes·tbe coirimission to pmpare and dovelcip a ganeral, comprolumsive 

plan for the control of the state•s air; and Texas Water Code, §5.102, GeumaJ. Powers, and 

§5.013, Gencnl1uri,sdiction of Commission. · · · · 

. The FCAA, 42 United States Code (USC), §§7401, et seq., requires states to submit ·SIP rcMsions tbat 

specify the mannor m which the NAAQS will be attained and maintainod within each air quality contrOl 

rDgicm. of the state. Phase 1 of the BPA•s implementatioil·rule. for the 1997 eight-hour oZODD standard, 

published in the April 30, 2004, issue of 1be Federal Register (69 F.R. 23951), outlines classifications, 

at1ainment dates, and BDti-backsJiding princjples. Phase 2 of the EPA;s implementation rule for 1he 1997 

eight-hour standard, published in the Nowm.ber 29, 2005, issue of ihe Federal Register (70 FR 71612), 

outlines the requirmnentS for state plans. . . 

Effect OB the: 

A) Replated cOmmllllity: 

None. 

B) Public: . . . 

~ are no aoticipated direct impacts on the public, ~ than benefits from emission reductions .from 

revised rules. · 

C) Agency pro1JU18: 

'Ibe.re ·are no anticipated impacts on agency programs ftom this SIP revision. 

Stakeholder meetilap: 

None. 

Public eoiDDlent: 

The commission held .two public hearings to receive oral comments on the proposod version of this SIP · 

revision and 1he Chapter 115 rule revision. The public comment period for the proposed SIP revision and 

Chaptm' 115 rulemalring.opened on October 9, 2009,·and closed on November 9~ 2009. The OctOber 29, 

2009, hearlng m Austin was nat officially opened because no ,party indicated a desire to provide comment. 

Comments wme .received at the November 2, 2009; hearing in Fort Worth. Written comments were accepted 

via mail, fax, and through the eComments system. . 

For the Chap1m 117 rule revision, a public hearing was scheduled on September 17, 2009, in Ennis. The 

hearing was not officially opened because no party indicated a desire to provide comment. The public 

comment period for the proposed rule revision opened August 28, 2009, and closed September 28, 2009. 
Commissioners 

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Febrwuy 19,2010 

Ra: Docket No. 2009-1127-SIP 

The commission received one Wl'i1ten comment, from tlle EPA. which in.dica:ted ~, t1;le EPA would 

cotmnmt on the § 110(1) dem.an.st:tation U1 a: 1c¢ter poitaini.n& to the prpposod DF\\1 SIP ~an. · 

Comments recoived applicable to the ~ 1 ~5 and Chapter · U 7 rule teViaions aro ~ssed in the 

preambles for those rules. No changes were made to 1hia SIP revision in rospoi:L8e to comments :r=ooivecl on 

the Chaptar 115 or Chapter 117 rule :re'Visions~ · 

. The Response to CommantS section of t1rls SU» misicm addroBs~ only commcm~ applicable to this I>.FW 

RACT,. Rule, and ContingeD.oy SIP R.cviaian. · The EPA commcm.ted on tbo DFW VOC :RACf update, the 

-demcmstratim ()! ~ (from th~ CQap1m ll7 rule reviJion); aad ~ modified ~plan 

• elemmit& Of 1hiB SIP.:~iQn. l'hc·SIP revision 'MIS~ in response to cnmm• .received on tile VOC 

RACT. update. Ne changes w~ nw:to. ·to the ;SIP revision in ,response. to comments received on the 

demonstration of noninterference and the modified ·contingeney pla!a, ~ the only oom~ reCeived on 

those wore supportive commcmts from the EPA. 

Significaat changes from proposal: · •· . . . . . . , _ 

Significant changes ftl'O lll8de to the. VOC RACT Update ~lcmmt of tl:rls SIP rerisjon in respOn&e to 

cmmnents, ·Staff proposed that RACT for~ CTG catogori.os was fulfilled througb ·CUll'l'llt aiD m1es -and 

par.mitting ~- Tb.eBe c;ategories inoludc FlexiQlc l'19kaging Printing; Paper, Film. and Fcri,l 

.CoMings; au4 Auto and Light .. ~ Ttllck A.JseQ1bly Co~. Hpweyer, in respcmse to ·comments-from b. 

EPA the RACT determinations for. these three citegoiioa were withtbwn ao tbat std may :reev~ the 

RACT analyses. The RACT dctmmination fm the FibOrglasa ~at Ma.nuf'aduring CTG catagory was 

proposed as not representing RACT for the DFW area due to 1he potrmtia1 economic ~ ,on,~ 

businessoa; 11owever. ~ staff research jndiastea that no sources meeting 1he CTG applicability exist 

in the DFW area. Thetafare, the RACT determination far Fiberglass Boat Man~.~ ·~ W. a 

negative declaration. · · · . , 

No significant changes were made to the other elmnents of this SIP revision as a result ot; comments · · 

ieceiw4. , J:D. respon$0 to · CQJDIP.QJ'lti.. rcx:Qived. ~cable tp the .rples ·associate4 with this. $P ~OJ.l, 

substantive changes were made to the 30 TAC Chapter 115 rule revision, which are ad4J'cssed in the 

preamble for that rule. and no changes were made to the SIP in response to any comment on tho Chapter 117 

rule revision. 

. . . .... , ' ' 

Potential controversial eoneerDS and legislative interest remabdng after proposal and pilbJic comment: 

RACT determinations were· not finalized for eight of the 11 eros issued by :fhe ~A between 2006 and 

2008, pending further infmmation from the EPA. While not stated in formally submitted COIIIJileiltS; the 

EPA has verbally indicated to staff that it may issue notices af failure to submit to states that have not yet 

addressed all of the CTGs. Tho EPA's issuance of nab a notice would start an 18-month sawmons clock. 

·The TCBQ will need to addl'ess the CTGs ttnnaining in a :future SIP revision. 

Doea tbiB request affect. any eur,reat polieie$· or req~ deveiQpmeat ofaew ~Jic:ies? 

No. 

. . 

What are the couequences if this SIP revision does not 10 ·forward? Are there aJtematives to the 

request? 

The VOC RACI' determination ·-qpciate ADd associated Chapter llS rule tmsions would not be incorporated . 

into the Texas Air Qua1itr Plan for the DFW ozpue »~imnent area. This could re$ult in 1he EPA issuing 

a findmg of ixlcompleteness for the DFW 1997 eight-hour omne standard attainment demanstration, wbich 

could further result in sanctions. The Chapter 1.17 role revision$, the assaciatcd § 110(1) demonstration, and 
Commissioners 

PageS 

February 19, 2010 

Re: Docet No. 2009-1127-SIP 

the modified contingency plan wo~ also not be incolporated into the PFW 1997 eigb.t-hour ozone standard 

affainment doinonstration. This could result in BP A disapproval of these elements of the attainment 

demonat:raticm, which could result in sanctions. 

· X., pofata ba adoptioa reque1hchedule: 

Texas liegister proposal publication date: NA 

Anticipated Texas Register publication date: NA 

Anticipated effoctivo dml: NA 

Six-month Texas Register filing deadline! NA · 

Apney contacts: . · . 

Mary A:im P. Cook, SIP Projoct Manager, 239-6739, Air Quality Division Tear Salem, Staff A.ttorney, 239-0469, BilvU.omnentai Law Division 

Attaclmumts 

·CC: Cbie!"Clark, S copies · . 

Executive Director's Office ~ M. Hildebrand, p .E. 

xmnPattDsan 

Curtis Seaton 

Daniel Womack 

Office of Getleral Counsel 

MarY Aml P. Cook 
RESPONSE TO COMMENTS SECTION 

Regarding the 

DALLAS-FORT WORTH (DFW) REASONABLE AVAILABLE CONTROL 

TECHNOLOGY (RACT) UPDATE, 30 TEXAS ADMINISTRATIVE CODE (TAC) 

CHAPTER 117 RULE REVISION NONINTERFERENCE DEMONSTRATION, AND 

MODIFIED FAILURE-TO-ATTAIN CONTINGENCY PLAN 

STATE IMPLEMENTATION PLAN (SIP) REVISION 

The commtsston received comments from the following entities: Printing and Imaging 

Association of Mid-America (PIA MidAmerica); Printing Industries of the Gulf Coast (PIGC); 

and the United States Environmental Protection Agency (EPA). 

Comments received regarding the 30 TAC Chapter 115 Offset Lithographic Printing rule 

revisions (Rule Project no. 2008-0 19-115-EN) or the 30 TAC Chapter 117 Stationary Sources 

rule exemption revision (Rule Project no. 2009-023-117-EN), both of which are incorporated by 

reference into this SIP revision, are addressed in the preambles to those rules. The comments 

received on the Chapter 115 and Chapter 117 rule revisions are included in this SIP revision 

through the adoption of those rules. 

Changes from Proposal 

Substantive changes were made to the Chapter 115 rule revision in response to comments 

received. Changes made to that rule revision are noted in this SIP revision. 

No changes were made to the Chapter 117 rule revision due to comment. 

Significant changes were made to the volatile organic compounds (VOC) RACT update element 

of this SIP revision as a result of comments and guidance received from the EPA. 

No changes were made to the Demonstration of Noninterference from the Chapter 117 rule 

revision as a result of comments received. 

No changes were made to the Modified Failure-to-Attain Contingency Plan element of this SIP 

revision due to comment. 

Incorporation of the Chapter 115 rule revision into the SIP 

PIA MidAmerica commented that the Chapter 115 rule revision applicable to offset lithographic 

printing sources may have no significant impact on reducing emissions in the Dallas-Fort Worth 

(DFW) area. PIGC commented that the printing industry is not a significant contributor to the 

overall air emissions in the DFW area. 

The commission is aware that printing sources do not constitute a large proportion of the 

emissions in the DFW area. However, revisions to the Chapter 115 offset lithographic 

printing rules are necessary to fulfill Federal Clean Air Act (FCAA) RACT requirements. 

1 
In accordance with FCAA, §172(c)(1) and §182(b)(2), the state is required to revise the 

DFW SIP to include RACT determinations for VOC emission sources addressed in a 

control techniques guidelines (CTG) document issued between November 15, 1990, and 

the area's attainment date. On OctoberS, 2006, the EPA published a CTG document in 

lieu of national regulations for VOC emissions from Offset Lithographic Printing and 

Letterpress Printing (71 FR 58745). The purpose of the offset lithographic printing rule 

revision is to implement RACT for this CTG emission source category. 

No changes were made to this SIP revision due to these comments received from PIA 

MidAmerica and PIGC. The preamble to the Chapter 115 rule revision addresses changes 

made to the rule revision as a result of comments received on that rule revision. 

DFW VOC RACT Update 

The EPA commented that the commission did not propose a RACT determination for the 

Industrial Cleaning Solvents CTG and Miscellaneous Industrial Adhesives CTG. The EPA 

further commented that in order for the DFW 1997 eight-hour ozone nonattainment area to meet 

the requirements of 40 Code of Federal Regulations (CFR) §51.912, the commission will need 

to complete RACT determinations and take appropriate action for these CTG categories. The 

EPA indicated that its approval of the VOC RACT update would only be considered for 

thoroughly addressed CTG categories. 

As noted in the EPA's comment, the commission did not make a determination whether 

the Industrial Cleaning Solvents and Miscellaneous Industrial Adhesives CTG 

recommendations represent RACT for Texas. The commission maintains the EPA 

substantially underestimated the scope and potential impact of these CTG 

recommendations, especially the impacts to small businesses. The commission is 

conducting research to determine the quantity of affected sources in the DFW 1997 eighthour ozone nonattainment area and plans to provide small business outreach to engage 

potentially impacted stakeholders. As a result of the comments received by the EPA, the 

Executive Director will proceed with RACT analyses of these CTG documents and will 

initiate a future SIP revision and rulemaking for the commission's consideration, if 

necessary, to submit RACT determinations to the EPA in a timely manner. 

The EPA commented that the commission did not propose any RACT determination for Large 

Appliance Coatings, Metal Furniture Coatings, and Miscellaneous Metal and Plastic Parts 

Coatings CTG. The EPA further commented that the commission needs to complete RACT 

determinations and take appropriate action for these three CTG categories in order for the DFW 

area to meet the requirements for RACT (40 CFR §51.912). The EPA indicated that approval 

for any RACT determinations contained in the VOC RACT update would only be considered 

for CTG categories thoroughly addressed. The EPA recognized that it had not yet responded to 

the commission's request for clarification on potential backsliding issues regarding the CTG. 

The commission had previously requested clarification on implementing CTG 

recommendations for these specialty coatings that are less stringent than general-use coating 

RACT recommendations from the 1970s. The EPA comments identified options for moving 

forward with RACT analyses for these CTG categories, to: (1) implement only CTGrecommended specialty coating content limits more stringent than existing state Jimits; or (2) 

relax existing coating content limits consistent with the later CTG recommendations and 

2 
provide additional analyses demonstrating compliance with non-interference provisions under 

the Federal Clean Air Act, §II 0(1). 

As noted, the commission did not make RACT determinations for the Large Appliance 

Coatings, Metal Furniture Coatings, and Miscellaneous Metal and Plastic Parts Coatings 

CTG recommendations. As discussed in Appendix A: Dallas-Fort Worth Reasonably 

Available Control Technology Analysis Update, the CTG documents for these emission 

source categories did not contain sufficient information for the commission to determine 

RACT for Texas. On December 8, 2008, the commission asked the EPA to clarify why the 

VOC content limits recommended for these categories are less stringent than previous 

EPA recommendations. While the EPA has not formally responded to the December 2008 

letter, the commission appreciates the EPA's suggestions regarding the issues raised by the 

commission. The commission intends to proceed with a RACT analysis of this CTG 

recommendation based on the guidance provided in the EPA's comments. As a result of 

the comments received by the EPA, the Executive Director will proceed with RACT 

analyses of these three CTG documents based on the guidance provided in the EPA's 

comments and initiate a future SIP revision and rulemaking for the commission's 

consideration, if necessary, in order to submit RACT determinations to the EPA in a 

timely manner. 

The EPA commented that the commission needs to address the VOC RACT requirements for 

the Fiberglass Boat Manufacturing Materials CTG source category. The EPA disagreed with 

the commission's interpretation of its 1988 guidance for determining alternative applicability 

thresholds for RACT ("Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations, Clarification to Appendix D of November 24, 1987 Federal Register" issued May 

25, 1988) since the calculation was not specifically based on emission sources in the DFW area. 

The EPA further commented that the Fiberglass Boat Manufacturing Materials CTGrecommended controls that are cost-effective, and RACT for this emission source category 

should be addressed. 

The 2008 Fiberglass Boat Manufacturing Materials CTG document did not identify any 

sources in Texas that would be subject to the CTG-recommended controls. However, as of 

the September 23, 2009, agenda for proposal of this SIP revision, the commission could 

not make a definitive negative declaration for this source category. Since that time the 

commission has conducted extensive additional review of sources identified in the point 

source emissions inventory, Title V permits, and central registry databases. No sources 

meeting the applicability criteria recommended in the CTG document were identified in 

the DFW area. Therefore, the commission provides a negative declaration for this 

emission source category with regard to RACT for the DFW area. 

The EPA commented that RACT for Automobile and Light-Duty Truck Assembly Coatings 

should be federally enforceable. The EPA requested additional information to explain how the 

use of permit conditions is reasonable to implement RACT and requested a copy of the final 

permit(s) used in this analysis, including permit information for General Motors Corporation 

Arlington Assembly Plant. The EPA further commented that work practice requirements for 

Automobile and Light-Duty Truck Assembly Coatings provide reasonable, cost-effective 

controls and are an important way to reduce emissions. The EPA stated that in order to meet 

RACT requirements, the commission should either adopt rules implementing the work practice 

requirements or provide analyses demonstrating that the requirements are satisfied by existing ru~ . 

3 
Because of tbe comments received by the EPA, the commission has decided to reevaluate 

the RACT determination for the Automobile and Light-Duty Truck Assembly Coatings 

CTG recommendations. Tbe Executive Director will proceed with the RACT analysis of 

this CTG document and initiate a future SIP revision and rulemaking for the 

commission's consideration as appropriate, if necessary, in order to submit a RACT 

determination to tbe EPA in a timely manner. As a result, the commission has not 

included copies of tbe requested permit information at this time. 

The EPA commented that RACT for Flexible Packaging Printing Materials should be federally 

enforceable. The EPA also requested additional explanation as to why it is reasonable to use 

permit conditions to implement RACT and requested a copy of the final permit(s) used in this 

analysis, including permit information for Printpak Incorporated. The EPA further commented 

that work practice requirements for Flexible Packaging Printing Materials provide reasonable, 

cost-effective controls and are an important way to reduce emissions. The EPA stated that in 

order to meet RACT requirements, the commission should either adopt rules implementing the 

work practice requirements or provide an analysis demonstrating that the requirements are 

satisfied by existing rules. 

Because of tbe comments received by the EPA, tbe commission has decided to reevaluate 

the RACT determination for the Flexible Packaging Printing Materials CTG 

recommendations. Tbe Executive Director will proceed witb the RACT analysis of tbis 

CTG document and initiate a future SIP revision and rulemaking for the commission's 

consideration as appropriate, if necessary, in order to submit a RACT determination to 

the EPA in a timely manner. As a result, tbe commission has not included copies of the 

requested permit information at this time. 

The EPA commented that RACT for Paper, Film, and Foil Coatings should be federally 

enforceable. The EPA requested additional explanation as to why it is reasonable to use permit 

conditions to implement RACT and requested a copy of the final permit(s) used in this analysis, 

including permit information for Rock Tenn Converting Company and Printpak Incorporated. 

The EPA commented that work practice requirements for Paper, Film, and Foil Coatings 

provide reasonable, cost effective controls and are an important way to reduce emissions. The 

EPA stated that in order to meet RACT requirements, the commission should either adopt rules 

implementing the work practice requirements or provide analyses demonstrating that the 

requirements are satisfied by existing rules. 

Because of the comments received by the EPA, the commission has decided to reevaluate 

the RACT determination for tbe Paper, Film, and Foil Coatings CTG recommendations. 

The Executive Director will proceed with the RACT analysis of tbis CTG document and 

initiate a future SIP revision and rulemaking for the commission's consideration, if 

necessary, in order to submit a RACT determination to the EPA in a timely manner. As a 

result, the commission has not included copies of the requested permit information at this 

time. 

The EPA commented that RACT for heatset offset lithographic printing presses should be 

federally enforceable. The EPA requested additional explanation as to why it is reasonable to 

use permit conditions to implement RACT and requested a copy of the final permit(s) used in 

this RACT analysis. The EPA requested copies of the documentation used to determine that all 

heatset offset lithographic presses in the DFW area meet RACT including copies of facilityspecific information for each heatset press identified with uncontrolled emissions greater than 

25 tons per year (tpy) located on a site with total emissions less than 50 tpy when uncontrolled, 

4 
copies of the final permit(s) used in this analysis, and copies of any other applicable 

documentation. 

The overall VOC control level in the adopted Chapter 115, Subchapter E, Division 4 rules 

is equivalent to or more stringent than the EPA's 2006 Offset Lithographic and 

Letterpress Printing CTG recommendations and sufficient to fulfill RACT for offset 

lithographic printing operations in the DFW area. The commission must balance 

implementing the 2006 CTG recommendations with the potential for backsliding, 

enforceability considerations, and the possible impacts to sources that have already 

complied with the existing rules. 

The commission notes that in several instances the adopted Chapter 115 content limits are 

more stringent than EPA's 2006 CTG recommendations. The 2006 CTG 

recommendations include limiting the VOC content of cleaning solutions used in offset 

lithographic printing operations to 70 percent VOC by weight in conjunction with work 

practice standards. The adopted Chapter 115 rules retain the more stringent cleaning 

solution content limit of 70 percent VOC by volume in conjunction with work practice 

standards. Assuming the VOC in the cleaning solvent used is kerosene, which is the VOC 

referenced in the 2006 CTG, the adopted Chapter 115 content limit of 70 percent VOC by 

volume for cleaning solutions is equivalent to 66 percent VOC by weight. The EPA's 2006 

CTG also recommends limiting the fountain solution content to 5 percent alcohol 

substitutes or less by weight and no alcohol in the fountain solution. To prevent potential 

backsliding for sources already required to comply with these state regulations, the 

adopted Chapter 115 rules retain the more stringent fountain solution content limit of 3 

percent alcohol substitutes or less by weight and no alcohol in the fountain solution. 

The adopted Chapter 115 rules for heatset offset lithographic presses are at least as 

stringent as the EPA's 2006 CTG-recommended controls. The EPA's CTG recommends 

an add-on air pollution control device be required on each individual heatset offset 

lithographic press with the uncontrolled potential to emit 25 tpy ofVOC or more from the 

dryer. The rules in Chapter 115, Subchapter E, Division 4, require control devices, with a 

control efficiency of at least 90 percent, to be installed on heatset offset lithographic 

presses on a property in the DFW area with total uncontrolled VOC emissions of at least 

50 tpy, which includes VOC emissions from ink oils evaporated by the press dryer and 

VOC in fountain and cleaning solutions. In Table 5-1: Model Plant Product Use and 

Baseline (Uncontrolled) Volatile Organic Compounds (Average Tons Per Year), of the 1993 

draft Offset Lithographic Printing CTG, the EPA estimates that 26 percent of the total 

uncontrolled VOC emissions from heatset offset lithographic printing operations are 

emitted from the press dryer. Based on the EPA's assumption, an individual heatset press 

located on a property with total uncontrolled VOC emissions of 50 tpy would emit less 

than 13 tpy of VOC from the press dryer. Therefore, the Chapter 115 rules are effectively 

more stringent than the EPA's 2006 CTG RACT recommendations with regard to the 

applicability threshold for this control requirement. Additionally, the EPA's 2006 CTG 

recommended exempting heatset presses used for book printing and heatset presses with a 

maximum web width of 22 inches or Jess from the add-on control device requirements. 

The existing Chapter 115 regulations do not exempt these sources from the control 

requirements, and the commission has not adopted these exemptions into the revised rule. 

The EPA's CTG recommends requiring control equipment first installed before the 

effective date of rules implementing the CTG to have an overall control efficiency of 90 

percent and control equipment first installed after the effective date of rules implementing 

5 
the CTG to have an overall control efficiency of 95 percent. The commission disagrees 

with the EPA's CTG recommendation to tie control device efficiency requirements with 

the first installation date of the control device regardless of where the equipment is 

installed. The commission contends imposing this policy may encourage the installation of 

older, less efficient equipment because facilities purchasing used equipment would be held 

to a less stringent standard. The policy could also create significant practical 

enforceability issues for commission investigators with regard to verifying the first 

installation date of the control equipment. 

Regardless of the first installation date of the device, the EPA recommends providing the 

alternative option to reduce the control device outlet concentration to 20 parts per million 

by volume (ppmv) as hexane on a dry basis to accommodate situations where the inlet 

VOC concentration is too low to demonstrate the 90 or 95 percent control efficiency. The 

Chapter 115 rules provide affected owners or operators of a heatset offset lithographic 

printing press the option to operate a control device to reduce VOC emissions from the 

press dryer exhaust vent by 90 percent by weight or maintain a maximum dryer exhaust 

outlet VOC concentration of 20 ppmv. The Chapter 115 alternative concentration limit is 

substantially preferable because it encourages VOC emission reductions without requiring 

add-on controls and implementing the EPA's recommended approach would penalize 

operations that were able to achieve the 20 ppmv limit without the installation of 

expensive add-on control devices. 

Based on this analysis, the commission determined that the adopted Chapter 115 rules for 

offset lithographic printing operations provide an overall VOC control level that is at least 

equivalent to the 2006 CTG recommendations and are more effective and enforceable. 

Therefore, the revised Chapter 115, Subchapter E, Division 4 rules are sufficient to fulfill 

RACT for offset lithographic printing operations in the DFW area. 

The EPA disagreed with the statement in the preamble to the offset lithographic printing rule 

revision that the commission does not agree that applying RACT standards to future equipment 

installations is necessary to meet the mandates of the Federal Clean Air Act (FCAA) under 

§172(c)(l) and §182(bX2) and (f). The EPA stated that RACT should apply to both existing 

and new sources. The EPA added that such statements may have implications for RACT 

approvability and requested the commission remove this language as well as any similar 

statements included elsewhere in the revisions. 

The commission bas removed this statement from the preamble to the offset lithographic 

printing rule revision (2008-019-115-EN). 

The EPA commented that work practice requirements for cleaning solutions used in offset 

lithographic printing operations provide reasonable, cost-effective controls and are an important 

way to reduce emissions. The EPA stated that in order to meet· RACT requirements, the 

commission should either adopt rules implementing the work practice requirements or provide 

analyses demonstrating that the requirements are satisfied by existing rules. 

The EPA's 2006 Offset Lithographic and Letterpress Printing CTG recommends 

mandating a towel handling program in conjunction with reduced VOC cleaning solution 

limits. Existing Chapter 115 rules include these work practice requirements for facilities 

choosing the 70 percent VOC cleaning solution limit; however, these work practice 

requirements were not proposed with cleaning solutions containing VOC vapor pressure 

less than 10 millimeters of mercury, because the commission expected most facilities were 

6 
voluntarily following -similar practices for safety reasons or have required work practices 

as part of their permit authorization. 

However, in response to comments received regarding the offset lithographic printing rule 

revisions, the commission is revising the rule to include the CTG-recommended work 

practice requirements for offset lithographic printing operations using cleaning solutions 

with VOC vapor pressure less than 10 millimeters of mercury. 

Demonstration of Noninterference (§1100> demonstration) 

The EPA commented that to be able to approve expansion of an existing exemption clause in a 

SIP revision, it must be shown that the rule revision will comply with §110(1) ofthe FCAA and 

has properly accounted for the corresponding SIP credit changes. The EPA agreed with the 

state's calculations showing that estimated surplus emission reductions from fleet turnover 

sufficiently substitute for the shortfall left by the Chapter 117 rule revision and adequately 

demonstrate noninterference with attainment of the 1997 eight-hour ozone standard. 

The commission appreciates the EPA's agreement with the state's calculations showing 

the substitution of the vehicle fleet turnover reductions to replace the shortfall caused by 

the Chapter 117 rule revision and the § 110(1) demonstration of noninterference. 

Modified Failure-to-Attain Contingency Plan 

The EPA commented that Table 4.2: Calculations Showing 3 Percent Required Reductions, of 

the proposed DFW RACT, Rule and Contingency SIP revision includes reference to a 1999 

adjusted base-year emissions inventory (EQ; however, the numbers shown are the same as those 

used in the federally approved 2007 DFW Attainment Demonstration SIP Revision (Appendix 

B), which does not characterize the 1999 emissions inventory as being an adjusted inventory. 

The EPA requested clarification of whether the EI used to calculate the contingency reductions 

is adjusted or not. 

The proposed SIP revision incorrectly identified the base-year emissions inventory used to 

calculate contingency reductions as an adjusted base-year inventory. All references in this 

SIP revision to the inventory used for contingency plan reduction requirement 

calculations have been corrected to more accurately reflect the unadjusted emission 

inventory used, and tbe word "adjusted" have been removed in those instances. The 

commission appreciates the EPA pointing out this needed correction. Tbe modified 

failure-to-attain contingency plan provides the required 3 percent contingency reduction. 

Comments from the EPA noted that the offset lithographic printing rule and the associated 0.24 

tons per day predicted in emission reductions for VOC are removed as a contingency measure. 

The EPA agreed with the state's calculations that estimated surplus emission reductions from 

fleet turnover sufficiently substitute for the shortfall left by removal of the offset lithographic 

printing measure. 

Tbe commission appreciates tbe EPA's agreement with the state's calculations and the 

substitution of the vehicle fleet turnover reductions for the removal of the offset 

lithographic printing measure in the modified failure-to-attain contingency plan. 

7 
STAFF 

RECOMMENDATIONS
STATE OF TEXAS AIR QUALITY IMPLEMENTATION PLAN 

FOR THE CONTROL OF OZONE AIR POLLUTION 

DALLAS/FORT WORTH 

1997 EIGHT-HOUR OZONE STANDARD NONATTAINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

Dallas-Fort Worth Reasonably Available Control Technology Update, 

30 Texas Administrative Code Chapter 117 Rule Revision Noninterference Demonstration, 

and Modified Failure-to-Attain Contingency Plan State Implementation Plan Revision 

TCEQ PROJECT NO. 2009-021-SIP-NR 

Adopted March 10, 2010 
This page is intentionally left blank. 
DFW RACT, Rule, and Contingency SIP Revision

EXECUTIVE SUMMARY 

The Dallas-Fort Worth (DFW) Reasonably Available Control Technology (RACT) Update, 30 

Texas Administrative Code (TAC) Chapter 117 Rule Revision Noninterference Demonstration, 

and Modified Failure-to-Attain Contingency Plan State Implementation Plan (SIP) Revision 

(DFW RACT, Rule, and Contingency SIP Revision) revises the State of Texas Air Quality 

Implementation Plan for the Control of Ozone Air Pollution. The SIP revision incorporates 

several actions adopted by the Texas Commission on Environmental Quality (TCEQ), and 

supplements the attainment demonstration for the 1997 eight-hour ozone standard for the DFW 

1997 eight-hour ozone standard nonattainment area (Dallas, Denton, Tarrant, Collin, Parker, 

Johnson, Ellis, Kaufman, and Rockwall Counties). 

The DFW RACT, Rule, and Contingency SIP Revision includes RACT determinations for certain 

volatile organic compounds (VOC) emission sources in the DFW area, as required by the 1990 

Federal Clean Air Act (FCAA) Amendments under §172(c)(1) and §182(b)(2) and (f). The VOC 

RACT update was developed to address the United States Environmental Protection Agency 

(EPA) issuance of 11 control techniques guidelines (CTG) documents between 2006 and 2008. 

Two adopted state rule revisions are incorporated into the SIP, one of which is a 30 TAC Chapter 

115 rule revision for offset lithographic printing emission sources that was adopted concurrently 

with the SIP revision. The revised Chapter 115 rule resulted from the state’s analysis of the CTG 

document for that emission source category and a subsequent RACT determination for offset 

lithographic printing emission sources. Also incorporated into the SIP revision is a 30 TAC 

Chapter 117 rule revision adopted by the commission on January 13, 2010. That rule revision, 

which resulted from the commission’s approval of a rulemaking petition filed by the Elk 

Corporation, exempts from Chapter 117 regulation low temperature drying and curing ovens used 

in mineral wool-type fiberglass manufacturing and wet-laid, non-woven fiber mat manufacturing 

where nitrogen-containing resins or other similar additives are used. 

The DFW RACT, Rule, and Contingency SIP Revision demonstrates that the revised Chapter 117 

rule does not interfere with the DFW area’s attainment demonstration for the 1997 eight-hour 

ozone standard. This demonstration is accomplished by offsetting a small potential emission 

reduction loss to the Chapter 117 control strategy that could result from the rule revision. This 

SIP revision allocates surplus nitrogen oxides (NOX) emission reductions from vehicle fleet 

turnover to occur between 2009 and 2010 to the control strategy to replace any loss of reductions 

resulting from the Chapter 117 rule revision. Replacing the control strategy emission reductions 

serves to maintain the integrity of the attainment demonstration and demonstrates that the revised 

Chapter 117 rule does not interfere with attainment of the 1997 eight-hour ozone standard in the 

DFW area. 

As a final action, the DFW RACT, Rule, and Contingency SIP Revision modifies the contingency 

plan for the DFW 1997 eight-hour ozone standard attainment demonstration. An earlier version 

of the Chapter 115 rule for offset lithographic printing sources was identified as a measure in 

previous failure-to-attain contingency plans for the DFW area. However, the measure is not 

contained in the modified plan because the Chapter 115 offset lithographic printing source rule as 

revised is no longer eligible for contingency use. The modified plan allocates a portion of surplus 

emission reductions that will result from vehicle fleet turnover to offset removal of the offset 

lithographic measure from the contingency plan. The modified plan provides emission reductions 

sufficient to meet the Federal Clean Air Act (FCAA) contingency requirement for a 3 percent 

reduction to the 1999 base year emissions inventory used for development of the attainment 

Adopted March 10, 2010 iii
DFW RACT, Rule, and Contingency SIP Revision

demonstration. A portion of surplus fleet turnover emissions reductions were previously 

allocated to the contingency plan; however, this revision allocates a greater portion of those 

reductions for contingency, to offset contingency reductions lost with removal of the offset 

lithographic printing rule measure. Because replacement reductions are identified, the 

contingency plan modification does not adversely affect the DFW area’s demonstration of 

attainment for the 1997 eight-hour ozone standard. The modified contingency plan retains two 

previously identified state Chapter 115 VOC rules applicable in Collin, Dallas, Denton, and 

Tarrant Counties for degassing or cleaning processes of stationary, marine, and transport vessels, 

and petroleum-based dry cleaning as contingency measures in addition to the vehicle fleet 

turnover emission reductions committed for contingency. 

Adopted March 10, 2010 iv
DFW RACT, Rule, and Contingency SIP Revision

SECTION V: LEGAL AUTHORITY

A. General

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state’s air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s 

Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 

1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009. In 1989, the TCAA was 

codified as Chapter 382 of the Texas Health & Safety Code. 

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the 

general provisions, organization, and general powers and duties of the TNRCC, and the 

responsibilities and authority of the executive director. This chapter also authorizes the TNRCC 

to implement action when emergency conditions arise, and to conduct hearings. Chapter 7 gives 

the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence 

of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Environmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a 

special session, amended section 5.014 of the Texas Water Code, changing the expiration date of 

the TCEQ to September 1, 2011, unless continued in existence by the Texas Sunset Act.

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state’s air and to control the quality of the state’s air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring requirements; 

to institute enforcement proceedings; to enter into contracts and execute instruments; to formulate 

rules; to issue orders taking into consideration factors bearing upon health, welfare, social and 

economic factors, and practicability and reasonableness; to conduct hearings; to establish air 

quality control regions; to encourage cooperation with citizens’ groups and other agencies and 

political subdivisions of the state as well as with industries and the federal government; and to 

establish and operate a system of permits for construction or modification of facilities. 

Local government authority is found in Subchapter E of the TCAA. Local governments have the 

same power as the TCEQ to enter property and make inspections. They also may make 

recommendations to the commission concerning any action of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission. 

Adopted March 10, 2010 v
DFW RACT, Rule, and Contingency SIP Revision

Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and maintain 

the NAAQS; establish gasoline volatility and low emission diesel standards; and fund and 

authorize participating counties to implement vehicle repair assistance, retrofit, and accelerated 

vehicle retirement programs. 

B. Applicable Law

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes

All sections of each subchapter are included, unless otherwise noted. 

 TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2009 

 TEXAS WATER CODE September 1, 2009 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A: General Provisions 

Subchapter B: Organization of the Texas Natural Resource 

 Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the Commission 

Subchapter E: Administrative Provisions for Commission 

Subchapter F: Executive Director (except §§ 5.225, 5.226, 5.227, 

 5.2275, 5.231, 5.232, and 5.236) 

Subchapter H: Delegation of Hearings 

Subchapter I: Judicial Review 

Subchapter J: Consolidated Permit Processing 

Subchapter L: Emergency and Temporary Orders (§§ 5.514, 5.5145, 

 and 5.515 only) 

Subchapter M: Environmental Permitting Procedures (§ 5.558 only) 

Chapter 7: Enforcement 

Subchapter A: General Provisions (§§ 7.001, 7.002, 7.0025, 7.004, 

 and 7.005 only) 

Subchapter B: Corrective Action and Injunctive Relief (§ 7.032 only) 

Subchapter C: Administrative Penalties 

Subchapter D: Civil Penalties (except § 7.109) 

Subchapter E: Criminal Offenses and Penalties: §§ 7.177, 7.179-7.183 

Rules

All of the following rules are found in 30, Texas Administrative Code, 

 as of the following effective dates: 

Chapter 7: Memoranda of Understanding, §§ 7.110 and 7.119 May 2, 2002 

Chapter 19: Electronic Reporting March 1, 2007 

Adopted March 10, 2010 vi
DFW RACT, Rule, and Contingency SIP Revision

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

 Permits; Temporary Suspension or Amendment of Permit Conditions July 20, 2006 

Chapter 39: Public Notice, §§ 39.201; 39.401; 39.403(a) and (b)(8)-(10); 

39.405(f)(1) and (g); 39.409; 39.411 (a), (b)(1)-(6), and (8)-(10) and 

(c)(1)-(6) and (d); 39.413(9), (11), (12), and (14); 39.418(a) and (b)(3) 

and (4); 39.419(a), (b), (d), and (e); 39.420(a), (b) and (c)(3) and (4); 

 39.423 (a) and (b); 39.601-39.605 March 29, 2006 

Chapter 55: Requests for Reconsideration and Contested Case Hearings; 

Public Comment, §§ 55.1; 55.21(a) - (d), (e)(2), (3), and (12), (f) and 

(g); 55.101(a), (b), and (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2), 

and (6) and (b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 

55.205; 55.209, and 55.211 March 29, 2006 

Chapter 101: General Air Quality Rules January 1, 2009 

Chapter 106: Permits by Rule, Subchapter A June 30, 2004 

Chapter 111: Control of Air Pollution from Visible Emissions and 

 Particulate Matter July 19, 2006 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants 

 and for Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles June 26, 2008 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007 

Chapter 116: Permits for New Construction or Modification May 29, 2008 

Chapter 117: Control of Air Pollution by Control of Air Pollution from 

 Nitrogen Compounds March 4, 2009 

Chapter 118: Control of Air Pollution Episodes March 5, 2000 

Chapter 122: § 122.122: Potential to Emit December 11, 2002 

Chapter 122: § 122.215: Minor Permit Revisions June 3, 2001 

Chapter 122: § 122.216: Applications for Minor Permit Revisions June 3, 2001 

Chapter 122: § 122.217: Procedures for Minor Permit Revisions December 11, 2002 

Chapter 122: § 122.218 Minor Permit Revision Procedures for Permit 

Revisions Involving the Use of Economic Incentives, Marketable 

Permits, and Emissions Trading June 3, 2001 

Adopted March 10, 2010 vii
DFW RACT, Rule, and Contingency SIP Revision

SECTION VI. CONTROL STRATEGY 

A. Introduction (No revision) 

B. Ozone 

 1. Dallas-Fort Worth 

 2. Houston-Galveston-Brazoria (No revision) 

 3. Beaumont-Port Arthur (No revision) 

 4. El Paso (No revision) 

 5. Regional Strategies (No revision) 

 6. Northeast Texas (No revision) 

 7. Austin Area (No revision) 

 8. San Antonio Area (No revision) 

 9. Victoria Area (No revision) 

C. Particulate Matter (No revision) 

D. Carbon Monoxide (No revision) 

E. Lead (No revision) 

F. Oxides of Nitrogen (No revision) 

G. Sulfur Dioxide (No revision) 

H. Conformity with the National Ambient Air Quality Standards (No revision) 

I. Site Specific (No revision) 

J. Mobile Sources Strategies (No revision) 

K. Clean Air Interstate Rule (No revision) 

L. Transport (No revision) 

M. Regional Haze (No revision) 

Adopted March 10, 2010 viii
DFW RACT, Rule, and Contingency SIP Revision

LIST OF ACRONYMS 

ACT -- Alternative Control Techniques 

AD -- Attainment Demonstration 

AF -- Air-to-Fuel 

APU -- Auxiliary Power Units 

ARPDB -- Acid Rain Program Data Base 

ATCM -- Airborne Toxic Control Measure 

auto-GC -- Automated Gas Chromatograph 

BACT -- Best Available Control Technology 

BCCA-AG -- Business Coalition for Clean Air-Appeal Group 

BMP -- Best Management Practices 

BPA -- Beaumont-Port Arthur 

Btu/hr -- British Thermal Units per Hour 

Btu/scf -- British Thermal Units per Standard Cubic Feet 

CAE -- Cetane Additive Enhanced Diesel Fuel 

CAIR -- Clean Air Interstate Rule 

CAMx -- Comprehensive Air Model with Extensions 

CARB -- California Air Resources Board 

CBD -- Houston's Central Business District 

CFR -- Code of Federal Regulations 

CMAQ -- Congestion Mitigation and Air Quality 

CO -- Carbon Monoxide 

CTG -- Control Techniques Guidelines 

DECS -- Diesel Emission Control Strategy 

DERC -- Discrete Emission Reduction Credits 

DFW -- Dallas-Fort Worth 

DFW AD SIP – DFW Attainment Demonstration SIP revision 

DPM -- Diesel Particulate Matter 

DRRP -- Diesel Risk Reduction Program 

DV -- Design Value 

DVc -- Current Design Value 

DVf -- Future Design Value 

EAC -- Early Action Compact 

EDMS -- Emissions and Dispersion Modeling System 

E-GRID-2007 -- Emissions and Generation Resource Integrated Database 

EE/RE -- Energy Efficiency/Renewable Energy 

EGAS -- Economic Growth Analysis System 

EGF -- Electric Generating Facilities 

EGU -- Electric Generating Units 

EI -- Emissions Inventory 

EPA -- United States Environmental Protection Agency 

EPS3 -- Emissions Processing System, version 3 

ERC -- Emission Reduction Credits 

ERCOT -- Electric Reliability Council of Texas 

ESAD -- Emission Specification for Attainment Demonstration 

ESL -- Energy Systems Laboratory, the Texas A&M University System 

F -- Fahrenheit 

FAA -- Federal Aviation Administration 

FCAA -- Federal Clean Air Act 

Adopted March 10, 2010 ix
DFW RACT, Rule, and Contingency SIP Revision

FCV -- Fuel Cell Vehicle 

FGR -- Flue Gas Recirculation 

FHWA -- Federal Highway Administration 

FR -- Federal Register 

FT -- Fischer-Tropsch Diesel Fuel 

GIS -- Geographic Information System 

GloBEIS -- Global Biosphere Emissions and Interactions System 

gpm -- Gallons per Minute 

GTM -- Gross Ton Mile 

HAP -- Hazardous Air Pollutant 

HARC -- Houston Advanced Research Center 

HDT -- Heavy-Duty Truck 

HECT -- Highly Reactive Volatile Organic Compound Emissions Cap and Trade Program 

HGB -- Houston-Galveston-Brazoria 

H-GAC -- Houston-Galveston Area Council 

HOV -- High Occupancy Vehicle 

hp -- Horsepower 

HPMS -- Highway Performance Monitoring System 

HRVOC – Highly Reactive Volatile Organic Compound 

HSC -- Houston Ship Channel 

IC -- Internal Combustion 

ICI -- Industrial, Commercial, and Institutional 

IECC -- International Energy Conservation Code 

I/M -- Inspection and Maintenance 

km -- Kilometer 

KVs -- Vertical Exchange Coefficient 

LAER -- Lowest Achievable Emission Rate 

lb/MMBtu -- Pound per Million British Thermal Units 

LDAR -- Leak Detection and Repair 

LIDIR -- Light Detection and Ranging 

LDEQ -- Louisiana Department of Environmental Quality 

LDGV -- Light-Duty Gasoline Vehicle 

LDT -- Light-Duty Truck 

LDV -- Light-Duty Vehicle 

LED -- Low Emission Diesel 

LEV -- Low Emission Vehicle 

LEV II -- California's Low Emission Vehicle II Program 

LIRAP -- Low Income Repair and Assistance Program 

LNB -- Low Nitrogen Oxides (NOX) Burners 

LNC -- Low Nitrogen Oxides (NOX) Combustors 

LNG -- Liquefied Natural Gas 

LTO -- Landing and Take-Off 

MACT -- Maximum Achievable Control Technology 

Mcf -- Thousand Cubic Feet 

MCR -- Mid-Course Review 

MDPV -- Medium-Duty Passenger Vehicle 

MECT -- Mass Emissions Cap and Trade Program 

MM5 -- Fifth Generation Meteorological Model 

MMBtu/hr -- Million British Thermal Units per Hour 

MMcf -- Million Cubic Feet 

MMS -- Minerals Management Service 

Adopted March 10, 2010 x
DFW RACT, Rule, and Contingency SIP Revision

MOA -- Memorandum of Agreement 

MON -- Miscellaneous Organic National Emission Standards for Hazardous Air Pollutants 

(NESHAP) 

mph -- miles per hour 

MVEB -- Motor Vehicle Emissions Budget 

MW -- Megawatts 

MY -- Model Year 

NAAQS -- National Ambient Air Quality Standard 

NCTCOG – North Central Texas Council of Governments 

NEGF -- Non-Electric Generating Facility 

NEI -- National Emissions Inventory 

NESHAP -- National Emission Standards for Hazardous Air Pollutants 

ng/J -- Nanogram per Joule 

NMIM -- National Mobile Inventory Model 

NOAA -- National Oceanic and Atmospheric Administration 

Non-EGU -- non-Electric Generating Unit 

NOX -- Nitrogen Oxides 

NOy -- Nitrogen Species 

NSCR -- Non-Selective Catalytic Reduction 

NTRD -- New Technology Research and Development Program 

O3 -- Ozone 

OGV -- Ocean-Going Vessel 

PAYD -- Pay As You Drive 

PBL -- Planetary Boundary Layer 

PEI -- Periodic Emissions Inventory 

PERP -- Portable Engine Registration Program 

PiG -- Plume-in-Grid 

PM -- Particulate Matter 

PM2.5 -- Particulate Matter 2.5 microns and less 

ppb -- Parts Per Billion 

ppbC -- Parts Per Billion Carbon 

ppbv -- Parts Per Billion by Volume 

ppm -- Parts Per Million 

PSCF -- Potential Source Contribution Factors 

PSDB -- Point Source Database 

psia -- Pounds per Square Inch Absolute 

PUC -- Public Utility Commission 

RACT -- Reasonably Available Control Technology 

RACM -- Reasonably Available Control Measure 

RFP -- Reasonable Further Progress 

RMSE -- Root Mean Square Error 

ROP -- Rate-of-Progress 

RRF -- Relative Reduction Factor 

SB -- Senate Bill 

SCAQMD -- South Coast Air Quality Management District 

scfm -- Standard Cubic Feet per Minute 

SCR -- Selective Catalytic Reduction 

SEP -- Supplemental Environmental Programs 

SETPMTC -- Southeast Texas Photochemical Modeling Technical Committee 

SIC -- Standard Industrial Classification 

SIP -- State Implementation Plan 

Adopted March 10, 2010 xi
DFW RACT, Rule, and Contingency SIP Revision

Adopted March 10, 2010 xii

SNCR -- Selective Non-Catalytic Reduction 

SOV -- Single Occupancy Vehicle 

STP -- Surface Transportation Program 

SWCV -- Solid Waste Collection Vehicle 

TAC -- Texas Administrative Code 

TACB -- Texas Air Control Board 

TCAA -- Texas Clean Air Act 

TCEQ -- Texas Commission on Environmental Quality (commission) 

TCM -- Transportation Control Measure 

TDM -- Travel Demand Model 

TERP -- Texas Emission Reduction Plan 

TexAQS 2000 -- Texas Air Quality Study 2000 

TexAQS II -- Texas Air Quality Study 2006 

TKE -- Turbulent Kinetic Energy 

TNMHC -- Total Non-methane Hydrocarbon 

TNRCC -- Texas Natural Resource Conservation Commission 

tpd -- tons per day 

tpy -- tons per year 

TSE -- Truck Stop Electrification 

TTI -- Texas Transportation Institute 

TUC -- Texas Utility Code 

TxDOT -- Texas Department of Transportation 

TxLED -- Texas Low Emission Diesel 

USC -- United States Code 

VMEP -- Voluntary Mobile Source Emissions Reduction Program 

VMT -- Vehicle Miles Traveled 

VOC -- Volatile Organic Compound 

VRU -- Vapor Recovery Unit 

ZEB -- Zero Emission Bus 

ZEV -- Zero Emissions Vehicle 
DFW RACT, Rule, and Contingency SIP Revision

IDENTIFICATION OF REFERENCED DOCUMENTS 

This document references SIP revisions and SIP-related documents. The following list provides 

clarification and additional information for those references. Direct access links to the documents 

are also provided. 

May 2007 DFW AD SIP Revision, and DFW 1997 Eight-Hour Ozone AD SIP Revision, both 

refer to the Dallas-Fort Worth (DFW) Ozone Nonattainment Area Attainment Demonstration 

(AD) State Implementation Plan (SIP) Revision for the 1997 Eight-Hour Ozone Standard, 

(TCEQ Project No. 2006-013-SIP-NR, adopted May 2007). 

April 2008 supplement to the DFW 1997 Eight-Hour Ozone AD SIP Revision refers to a TCEQ 

letter to the EPA of April 23, 2008, that provides clarification and supplemental information 

regarding the May 2007 DFW AD SIP Revision. 

 Related document: A March 7, 2008, letter from the EPA to the TCEQ requesting 

supplemental information for clarification of the May 2007 DFW AD SIP Revision. 

 

DFW AD SIP Contingency Plan Revision refers to the DFW AD SIP Revision for the 1997 

Eight-Hour Ozone Standard (Contingency Measures Plan), (TCEQ Project No. 2008-016-

SIP-NR, adopted November 2008). 

 

DFW AD SIP DERC Program Revision refers to the DFW AD SIP Revision for the 1997 

Eight-Hour Ozone Standard (Discrete Emission Reduction Credits (DERC) Program), 

 (TCEQ Project No. 2008-016-SIP-NR, adopted December 2008). 

 

DFW RACT, Rule, and Contingency SIP Revision refers to this DFW Reasonably Available 

Control Technology (RACT) Update, 30 Texas Administrative Code (TAC) Chapter 117 

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

Plan SIP Revision, (TCEQ Project No. 2009-021-SIP-NR, adopted March 10, 2010). 

DFW 1997 eight-hour ozone standard attainment demonstration and attainment 

demonstration both refer to Texas SIP revisions applicable to the DFW nine-county 

nonattainment area (Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, and 

Tarrant Counties) demonstration of attainment for the 1997 eight-hour ozone NAAQS, 

comprised (to date) of the following documents: the DFW 1997 Eight-Hour Ozone AD SIP 

Revision; the April 2008 supplement to the DFW 1997 Eight-Hour Ozone AD SIP Revision; 

the DFW AD SIP Contingency Plan Revision; the DFW AD SIP DERC Program Revision; 

and this DFW RACT, Rule, and Contingency SIP. 

The Texas SIP (in this document) refers to SIP revisions that make up the State of Texas Air 

Quality Implementation Plan for the Control of Ozone Air Pollution. 

Adopted March 10, 2010 xiii
DFW RACT, Rule, and Contingency SIP Revision

TABLE OF CONTENTS

Executive Summary 

List of Acronyms 

Identification of Referenced Documents 

Table of Contents 

List of Tables 

Chapter 1. Background and Introduction

1.1.General 

1.1.1. Background 

1.1.2. Current SIP Action 

 1.2. Health Effects 

 1.3. Public/Stakeholder Participation 

 1.4. Social and Economic Considerations 

 1.5. Fiscal and Manpower Resources (No revision) 

Chapter 2. Photochemical Modeling (No revision) 

Chapter 3. Corroborative Analysis (No revision) 

Chapter 4. Required Control Strategy Elements

4.1. Overview of Existing Control Strategies (No revision) 

4.2. Nitrogen Oxides (NOX) and Volatile Organic Compounds (VOC) Control Measures 

 4.2.1. VOC Control Measures 

 4.2.1.1. Background 

 4.2.1.2. 30 TAC Chapter 115 VOC Rule Revision (Rule Project 2008-019-115-EN) 

 4.2.2. NOX Control Measures 

 4.2.2.1. Major Source NOX Reductions 

 Industrial, Commercial, and Institutional (ICI) Sources 

 30 TAC Chapter 117 Rule Revision (Rule Project 2009-023-117-EN) 

 Demonstration of Noninterference under FCAA §110(l) 

 4.2.2.2. - 4.2.2.4. (No revision) 

 4.2.3. - 4.2.7. (No revision) 

4.3. Reasonably Available Control Technology (RACT) Analysis 

 4.3.1. DFW VOC RACT Analysis Update 

 4.3.1.1. CTG Documents Not Applicable to the DFW Area 

 4.3.1.2. CTG Documents for which RACT Determinations are Not Being Made 

 4.3.1.3. CTG Documents that Represent RACT for the DFW Area 

4.4. - 4.5. (No revision) 

4.6. Contingency Measures 

 4.6.1. Background 

 4.6.2. Modified DFW 1997 Eight-Hour Ozone Failure-to-Attain Contingency Plan 

 4.6.3. Allocations from Surplus 2009 through 2010 Fleet Turnover Reductions 

Response to Comments Section 

Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update 

Adopted March 10, 2010 xiv
DFW RACT, Rule, and Contingency SIP Revision

Adopted March 10, 2010 xv

LIST OF TABLES

Number Table Name 

Table 4.1 Emission Reductions Provided by Modified Failure-to-Attain Contingency Plan 

Table 4.2 Calculations Showing Required 3 Percent Contingency Reductions 

Table 4.3 Allocation of Surplus Emissions Reductions from 2009 through 2010 Fleet Turnover 
DFW RACT, Rule, and Contingency SIP Revision

CHAPTER 1. BACKGROUND AND INTRODUCTION 

1.1. GENERAL 

The “History of the Texas State Implementation Plan (SIP),” a comprehensive overview of SIP 

revisions submitted to the United States Environmental Protection Agency (EPA) by the State of 

Texas, is accessible from the Texas Commission on Environmental Quality’s (TCEQ) Web Site, 

at http://www.tceq.state.tx.us/assets/public/implementation/air/sip/miscdocs/SIPHistory_updated.pdf. 

The Dallas-Fort Worth (DFW) Ozone Nonattainment Area Attainment Demonstration (AD) SIP 

Revision for the 1997 Eight-Hour Ozone Standard, also called the DFW 1997 Eight-Hour Ozone 

AD SIP or May 2007 DFW AD SIP, was adopted by the TCEQ and submitted to the EPA in May 

2007. The DFW 1997 eight-hour ozone nonattainment area includes Collin, Dallas, Denton, 

Ellis, Johnson, Kaufman, Parker, Rockwall, and Tarrant Counties. 

1.1.1. Background 

During the EPA’s review of the DFW 1997 Eight-Hour Ozone AD SIP Revision submittal, a 

March 7, 2008, letter from the EPA to the TCEQ requested clarification and additional 

information applicable to the DFW 1997 Eight-Hour Ozone AD SIP Revision. A TCEQ letter to 

the EPA of April 23, 2008, (referred to as the April 2008 Supplement to the DFW 1997 EightHour Ozone AD SIP Revision) provided the EPA with additional information to clarify and 

support the submittal. 

Upon review of the April 2008 Supplement to the DFW 1997 Eight-Hour Ozone AD SIP

Revision, the EPA requested that the TCEQ implement an enforceable mechanism to limit the use 

of Discrete Emission Reduction Credits (DERCs) in the nine-county DFW eight-hour ozone 

nonattainment area, consistent with attainment and maintenance of the 1997 eight-hour ozone 

National Ambient Air Quality Standard (NAAQS). The EPA asked the state to revise the DFW 

1997 Eight-Hour Ozone AD SIP Revision to provide additional emissions reductions sufficient to 

meet contingency plan mandates of the Federal Clean Air Act (FCAA) and to implement a rule 

limiting DERC use in the DFW area. 

In June 2008, the TCEQ informed the EPA of its intention to propose a revised contingency plan 

as well as DERC SIP and rule revisions to satisfy the EPA requests. The following month (July 

2008) the EPA proposed a conditional approval of the DFW 1997 Eight-Hour Ozone AD SIP 

Revision. The DFW AD SIP Contingency Plan Revision, adopted by the commission and 

submitted to the EPA in November 2008, revised the contingency plan for the DFW 1997 eighthour ozone standard attainment demonstration. The revised plan identified four measures to 

provide reductions in the event of failure to meet the June 15, 2010, deadline for attainment of the 

1997 eight-hour ozone standard for the DFW area. Three previously identified volatile organic 

compounds (VOC) rule contingency measures (applicable to offset lithographic printing, 

petroleum-based dry cleaning, and degassing or cleaning processes of stationary, marine, and 

transport vessels), along with an allocation of a portion of the surplus emission reductions to 

result from 2009 through 2010 vehicle fleet turnover, completed the revised failure-to-attain 

contingency plan. 

Effective February 13, 2009, the EPA published a final conditional approval of the DFW 

nonattainment area’s 1997 eight-hour ozone attainment demonstration, as submitted in the May 

2007 DFW AD SIP Revision and April 2008 Supplement, and as revised in the DFW AD SIP 

Contingency Plan Revision. The published notice deemed the failure-to-attain contingency plan 

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DFW RACT, Rule, and Contingency SIP Revision

and the VOC reasonably available control technology (RACT) analysis elements of the 

attainment demonstration to be adequate and both were given final approval by the EPA. A final 

full approval of the attainment demonstration was withheld by the EPA, pending approval of SIP 

and rule revisions needed to provide an enforceable mechanism to limit DERC use in the DFW 

area consistent with the 1997 eight-hour ozone attainment demonstration. 

The DFW AD SIP DERC Program Revision was adopted by the commission and submitted to the 

EPA in December 2008. That SIP revision and the corresponding DERC rule revision addressed 

the EPA’s requirement for final approval of the DFW attainment demonstration by limiting 

DERC use in the DFW area consistent with attainment of the 1997 eight-hour ozone standard. 

The DERC rule in 30 Texas Administrative Code (TAC) Chapter 101 was revised to include 

requirements for the review and determination of annual DERC use limitations and 

apportionments for DERC use within the nine-county DFW area. At the time of the 

commission’s adoption of this DFW RACT, Rule, and Contingency SIP Revision, the DFW AD 

SIP DERC Program Revision and the Chapter 101 DERC rule revision had not yet been acted 

upon by the EPA. 

1.1.2. Current SIP Action 

This DFW RACT Update, 30 Texas Administrative Code (TAC) Chapter 117 Rule Revision 

Noninterference Demonstration, and Modified Failure-to-Attain Contingency Plan SIP Revision 

(DFW RACT, Rule, and Contingency SIP Revision) revises the DFW 1997 eight-hour ozone 

attainment demonstration, and as a result, the Texas Air Quality Implementation Plan for the 

Control of Ozone Air Pollution. Several actions required by the FCAA are finalized in this SIP 

revision, including: (1) an update to DFW VOC RACT analysis determinations; (2) incorporation 

of adopted 30 TAC Chapter 115 and 30 TAC Chapter 117 rule revisions into the Texas SIP; (3) 

demonstration that the Chapter 117 rule revision will not interfere with attainment of the 1997 

eight-hour ozone standard in the DFW area; and (4) modification of the contingency plan for the 

DFW 1997 eight-hour ozone attainment demonstration. Additional information about each of 

these SIP actions is provided in Chapter 4: Required Control Strategy Elements of this document. 

This SIP revision updates the VOC RACT determination element of the DFW attainment 

demonstration by including analyses of control techniques guidelines (CTG) documents issued by 

the EPA in 2006, 2007, and 2008, as required by the FCAA. Documentation of the state’s 

determinations regarding those CTG recommendations is provided in Chapter 4, Required 

Control Strategy Elements, of this SIP revision and in Appendix A: Dallas-Fort Worth 

Reasonably Available Control Technology Analysis Update. 

A concurrently adopted 30 TAC Chapter 115 rule revision is incorporated into the Texas SIP via 

this DFW RACT, Rule, and Contingency SIP Revision. The Chapter 115 rule was revised based 

on new VOC RACT determinations made for the DFW area for offset lithographic and letterpress 

printing sources, based on CTG recommendations issued by the EPA in 2006 for those sources. 

The adopted rule revision (TCEQ Rule Project 2008-019-115-EN) implements the CTG 

recommendation to reduce the VOC content in fountain and cleaning solutions used by offset 

lithographic printing operations. Applicability of the rule to smaller sources previously exempt is 

also expanded by the rule revision. Additional information concerning RACT determinations for 

heatset press and letterpress printing sources is provided in Chapter 4: Required Control Strategy 

Elements and in Appendix A: Dallas-Fort Worth Reasonably Available Control Technology 

Analysis Update. 

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DFW RACT, Rule, and Contingency SIP Revision

This SIP revision also incorporates a 30 TAC Chapter 117 rule revision that was adopted by the 

commission on January 13, 2010. The Chapter 117 rule was revised in response to a rulemaking 

petition filed by the Elk Corporation of Texas that was approved by the commission on January 

28, 2009. The rule revision exempts from Chapter 117 regulation low temperature drying and 

curing ovens used in mineral wool-type fiberglass manufacturing and wet-laid, non-woven fiber 

mat manufacturing where nitrogen-containing resins or other additives are used. 

The Chapter 117 rule exemption creates a potential nitrogen oxides (NOX) emission reduction 

loss to the DFW area ozone control strategy of up to 0.1 tons per day (tpd) from Chapter 117 

control measures included in the DFW 1997 Eight-Hour Ozone AD SIP Revision. To offset the 

potential loss of this NOX reduction that could result from the new exemption, this DFW RACT, 

Rule, and Contingency SIP Revision allocates to the DFW control strategy a replacement 0.1 tpd 

NOX reduction out of surplus emission reductions to result from turnover of the vehicle fleet from 

2009 to 2010 in the DFW area. This action maintains integrity of the DFW 1997 eight-hour 

ozone attainment demonstration, and provides the required demonstration of noninterference 

from Chapter 117 rule revisions. 

Prior to this SIP revision, the DFW failure-to-attain contingency plan identified three state VOC 

rule contingency measures along with an allocation from surplus fleet turnover emission 

reductions. The VOC rule measures were Chapter 115 rules applicable to (1) offset lithographic 

printing, (2) petroleum-based dry cleaning, and (3) degassing or cleaning processes of stationary, 

marine, and transport vessels. Because the offset lithographic printing rule was revised for RACT 

purposes in this SIP revision, it may no longer be used as a contingency measure. This DFW 

RACT, Rule, and Contingency SIP Revision modifies the DFW 1997 eight-hour ozone standard 

failure-to-attain contingency plan to no longer contain the offset lithographic printing measure. 

The modified plan retains the two state VOC rules applicable to petroleum-based dry cleaning 

and degassing or cleaning processes of stationary, marine, and transport vessels, along with the 

fleet turnover emission reductions previously allocated for contingency purposes. The modified 

plan also contains an additional allocation of the surplus emission reductions predicted to result 

from vehicle fleet turnover for the one-year period beginning June 15, 2009. The additional 

reductions are allocated for contingency purposes to offset and replace reductions removed from 

the plan with removal of the offset lithographic printing rule measure. The modified failure-toattain contingency plan provides the required 3 percent reduction to the attainment 

demonstration’s 1999 base year emissions inventory with the reductions from the two remaining 

state VOC rule contingency measures together with the revised fleet turnover reduction 

allocations for contingency. 

Surplus fleet turnover emission reduction allocations are provided in Table 4.3: Allocation of 

Surplus Emissions Reductions from 2009 through 2010 Fleet Turnover. After surplus fleet 

turnover emission reductions are allocated to offset the possible 0.1 tpd NOX emission increase 

from Chapter 117 rule exemption expansion as well as the offset lithographic printing rule 

contingency measure reductions, a 7.42 tpd NOX emission reduction from 2009 through 2010 

vehicle fleet turnover remains surplus and available for future SIP purposes. Additional 

information is provided in Chapter 4: Required Control Strategy Elements. 

There are no outstanding SIP requirements for the DFW area under the one-hour ozone NAAQS. 

A final rule published in the Federal Register by the EPA on October 16, 2008, (73 FR 61357) 

describes an EPA determination, effective November 17, 2008, that the DFW one-hour ozone 

nonattainment area (Collin, Dallas, Denton, and Tarrant Counties) has attained the one-hour 

ozone standard. The EPA based this determination upon its review of certified ambient air 

monitoring data showing attainment of the one-hour ozone NAAQS for the 2004 through 2006 

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DFW RACT, Rule, and Contingency SIP Revision

period. The one-hour ozone standard attainment determination was further supported by EPA 

review of quality-controlled, quality-assured ozone data for 2007 and 2008. The EPA 

determination also provided that due to the area’s one-hour ozone standard attainment, all 

requirements to submit any demonstration of attainment, 5 Percent Increment of Progress (IOP) 

plan, reasonable further progress (RFP) plan, contingency plan, or other planning SIP revisions 

related to attainment of the one-hour ozone NAAQS, are suspended for as long as the area 

continues to attain that standard. 

1.2. HEALTH EFFECTS 

In 1997, the EPA revised the NAAQS for ozone from a one-hour to an eight-hour standard. To 

support the 1997 eight-hour ozone standard, the EPA provided information indicating that health 

effects can occur at levels lower than the previous standard and at exposure times longer than one 

hour. Exposure to ambient ozone can aggravate asthma in some people. Repeated exposures to 

ozone can make people more susceptible to respiratory infection and lung inflammation and can 

aggravate preexisting respiratory diseases, such as bronchitis and emphysema. 

Children are at a relatively higher risk from exposure to ozone when compared to adults, since 

they breathe more air per pound of body weight than adults and because children's respiratory 

systems are still developing. Children also spend a considerable amount of time outdoors during 

summer and during the start of the school year (August - October) when high ozone levels are 

typically recorded. Adults most at risk to ozone exposure are people working or exercising 

outdoors and individuals with preexisting respiratory diseases. 

1.3. PUBLIC/STAKEHOLDER PARTICIPATION 

The commission held two public hearings to receive oral comments on the proposal of this SIP 

revision, as follows. 

CITY DATE TIME LOCATION 

Austin October 29, 2009 1:00 P.M. (CST) TCEQ Headquarters 

12100 Park 35 Circle 

Austin, TX 78753 

Building E, Room 201S 

Fort Worth November 2, 2009 2:00 P.M. (CST) TCEQ Region 4 Offices 

2309 Gravel Road 

Fort Worth, TX 76118 

Public Meeting Room 

The comment period opened on October 9, 2009, and closed on November 9, 2009. Written 

comments were accepted via mail, fax, and through the eComments system. Prior to and 

following each of the public hearings, TCEQ staff answered questions and provided information 

to interested persons. The October 29, 2009, hearing in Austin was not officially opened because 

no party indicated a desire to provide comment. Comments were received at the November 2, 

2009, hearing in Fort Worth. Comments were received via the eComments system that are 

applicable to the 30 TAC Chapter 115 and Chapter 117 rule revisions associated with this SIP 

revision, which are addressed in the preambles applicable to each of those rules. Only comments 

applicable to this DFW RACT, Rule, and Contingency SIP Revision are addressed in the 

Response to Comments Section of this SIP revision. 

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DFW RACT, Rule, and Contingency SIP Revision

Adopted March 10, 2010 1-5

1.4. SOCIAL AND ECONOMIC CONSIDERATIONS 

There are no social or economic issues of concern attributable to this DFW RACT, Rule, and 

Contingency SIP Revision. For a detailed explanation of any social and economic issues 

involved with the associated Chapter 115 and 117 rulemaking, please refer to the preamble of 

each of those rules, accessed from the TCEQ public Web site at 

http://www5.tceq.state.tx.us/rules/. TCEQ rules may also be accessed from the Texas Register

index located on the Secretary of the State of Texas Web site, at 

http://www.sos.state.tx.us/texreg/index.shtml. 

1.5. FISCAL AND MANPOWER RESOURCES (No revision)
DFW RACT, Rule, and Contingency SIP Revision

CHAPTER 2. PHOTOCHEMICAL MODELING 

(No revision) 

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DFW RACT, Rule, and Contingency SIP Revision

CHAPTER 3. CORROBORATIVE ANALYSIS 

(No revision) 

 

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DFW RACT, Rule, and Contingency SIP Revision

CHAPTER 4. REQUIRED CONTROL STRATEGY ELEMENTS 

4.1. OVERVIEW OF EXISTING CONTROL STRATEGIES (No revision) 

4.2. NITROGEN OXIDES (NOX) AND VOLATILE ORGANIC COMPOUNDS (VOC) 

CONTROL MEASURES 

4.2.1. VOC Control Measures

4.2.1.1. Background

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

moderate nonattainment for the 1997 eight-hour ozone National Ambient Air Quality Standard 

(NAAQS). Under the standard, the DFW area is required to meet the mandates of the Federal 

Clean Air Act (FCAA) under §172(c)(1) and §182(b)(2) and (f). According to the United States 

Environmental Protection Agency (EPA) Final Rule to Implement the 1997 eight-hour ozone 

NAAQS (40 CFR §51.912), states containing areas classified as moderate nonattainment or 

higher must submit state implementation plan (SIP) revisions demonstrating that their current 

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

techniques guidelines (CTG) categories and all non-CTG major sources of nitrogen oxides (NOX) 

and volatile organic compounds (VOC). 

The EPA previously approved the VOC RACT analysis submitted in the DFW 1997 Eight-Hour 

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

analysis demonstrated that all CTG emission source categories addressed by CTG documents 

issued prior to 2006 and all major VOC emission sources in the DFW area were subject to rules 

in 30 Texas Administrative Code (TAC) Chapter 115 or other federally enforceable measures that 

meet or exceed applicable RACT requirements, or that further emission controls were not 

technologically or economically feasible. However, the EPA-approved 2007 VOC RACT 

analysis did not address 11 CTG documents issued between 2006 and 2008 containing 

recommendations for VOC controls on a variety of consumer and commercial products. 

Information regarding TCEQ's RACT determinations for these 11 CTG documents is provided in 

Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update. 

Concurrent with this SIP revision, the Texas Commission on Environmental Quality (TCEQ) 

adopted revisions to 30 TAC Chapter 115, Subchapter E, Division 4 to implement the EPA's 2006 

Offset Lithographic and Letterpress Printing CTG recommendations that represent RACT in the 

DFW area (TCEQ Rule Project 2008-019-115-EN). 

4.2.1.2. 30 TAC Chapter 115 VOC Rule Revision (Rule project 2008-019-115-EN)

The TCEQ has adopted revisions to 30 TAC Chapter 115, Subchapter E, Division 4 to implement 

the EPA's 2006 Offset Lithographic and Letterpress Printing CTG recommendations that 

represent RACT in the DFW area concurrent with this SIP revision. The adopted Chapter 115 

rulemaking reduces the VOC content of the fountain solutions and cleaning solutions used by 

offset lithographic printing operations and expands rule applicability to include smaller offset 

lithographic printing sources that were previously exempt from these rules. 

Additional information on the offset lithographic printing rule revision is contained in the 

preamble for TCEQ Rule project 2008-019-115-EN. Additional information on the RACT 

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DFW RACT, Rule, and Contingency SIP Revision

analysis of the 2006 Offset Lithographic and Letterpress Printing CTG can be found in Appendix 

A: DFW Reasonably Available Control Technology Analysis Update. 

Because the commission revised Chapter 115 rules to include RACT requirements for offset 

lithographic printing sources, the state VOC rule for those sources is no longer available for use 

as a measure in the contingency plan for the DFW 1997 eight-hour ozone attainment 

demonstration. Therefore, the offset lithographic printing rule is no longer identified as a 

measure in the modified failure-to-attain contingency plan adopted within this DFW RACT, Rule, 

and Contingency SIP Revision. To maintain integrity of the attainment demonstration, this SIP 

revision allocates emission reductions from fleet turnover to replace the contingency reduction 

removed with the offset lithographic printing rule measure, as more specifically described in 

Section 4.6: Contingency Measures, of this SIP revision. 

4.2.2. NOX Control Measures 

4.2.2.1. Major Source NOX Reductions 

Industrial, Commercial, and Institutional (ICI) Sources

On December 11, 2008, a petition for rulemaking requesting an amendment to Chapter 117, 

Subchapter B, Division 4, for certain DFW area sources, was filed with the commission. The 

petition (TCEQ Rule Project No. 2009-012-PET-NR), submitted by Brown McCarroll, L.L.P., on 

behalf of Elk Corporation of Texas, requested that the agency initiate rulemaking to revise 30 

TAC Chapter 117, Subchapter B, §117.403(a)(12). The request related to owners and operators 

of low-temperature drying and curing ovens used in mineral wool-type fiberglass manufacturing 

and wet-laid, non-woven fiber mat manufacturing located at major sources in the DFW 1997 

eight-hour ozone nonattainment area. Source categories affected by the petitioners request are 

currently required to comply with Chapter 117 rule requirements by March 1, 2010. 

Elk Corporation of Texas operates an asphalt shingle manufacturing plant in Ennis, Texas. In the 

petitioner’s manufacturing process, a urea-formaldehyde resin binder is used with other nitrogencontaining compounds on a fiberglass substrate that is then passed through a drying and curing 

oven. This operation results in nitrogen-containing off-gas that is vented through incinerators and 

reacts with oxygen to form NOX. The petitioner asserts that emissions associated with the 

manufacturing process alone makes compliance with the applicable NOX emission specification 

in §117.410(b) of 0.036 pounds per million British thermal unit (lb/MMBtu) infeasible. On 

January 28, 2009, the commission considered and approved the petition for rulemaking. The 

commission issued an order on February 2, 2009, directing the executive director to examine the 

issues in the petition and to initiate rulemaking. 

30 TAC Chapter 117 Rule revision (Rule Project 2009-023-117-EN) 

On January 13, 2010, the TCEQ adopted an amendment to Chapter 117, Subchapter B, Division 

4, §117.403 to implement the stationary source rule changes requested by Elk Corporation of 

Texas for the DFW 1997 eight-hour ozone nonattainment area. The rule revision expands an 

exemption to §117.403(a)(12) to include low-temperature drying ovens and curing ovens used in 

wet-laid, non-woven fiber mat manufacturing, as well as in low-temperature drying ovens used in 

mineral wool-type fiberglass manufacturing where nitrogen-containing resins or other additives 

are used. The rule revision became effective on February 4, 2010. This DFW RACT, Rule, and 

Contingency SIP Revision incorporates a revised §117.403 into the Texas SIP. 

In 2006, during Chapter 117 rulemaking development for the DFW 1997 eight-hour ozone 

nonattainment area, comments were received from Owens Corning pointing out technical 

Adopted March 10, 2010 4-2
DFW RACT, Rule, and Contingency SIP Revision

feasibility issues with controlling NOX emissions from curing ovens of this specific operation. In 

response to those comments, a provision was added under §117.403(a)(12) to exempt curing 

ovens used in mineral wool-type fiberglass manufacturing in which nitrogen-bound chemical 

additives are used. While the type of manufacturing covered by the rule is different from that 

specified in the current rule exemption, the technical feasibility issue for Elk Corporation of 

Texas is similar to the Owens Corning issue and is the basis of the current exemption in 

§117.403(a)(12). The addition of nitrogen-bound chemical additives contributes to the creation 

of non-combustion related thermal NOX that cannot be controlled using control methodologies 

identified by the commission as appropriate for curing ovens used in mineral wool-type fiberglass 

manufacturing. 

NOX emissions from curing ovens of this type are small contributors to the total NOX emissions. 

Due to the expanded exemption from the Chapter 117 rule revision, up to 0.1 tons per day (tpd) of 

anticipated NOX emission reduction previously anticipated to support the DFW 1997 eight-hour 

ozone attainment demonstration will no longer be available. Therefore, a demonstration of 

noninterference submittal to the EPA is required under the FCAA §110(l). 

Demonstration of Noninterference under FCAA §110(l) 

The estimated 0.1 tpd NOX emission increase and potential loss to the DFW control strategy that 

could result from the Chapter 117 rule exemption expansion is insignificant and does not interfere 

with the DFW 1997 ozone attainment demonstration. However, the TCEQ provides this 

demonstration of noninterference to support the state’s assertion that expansion of the exemption 

in §117.403(a)(12) does not negatively impact the status of the area’s attainment of the NAAQS. 

The EPA issued draft guidance on June 8, 2005, titled “Demonstrating Noninterference under 

Section 110(l) of the Clean Air Act When Revising a State Implementation Plan.” The guidance 

provides options available for states to demonstrate noninterference in nonattainment areas for 

affected pollutants. One option for demonstrating noninterference is through the substitution of 

measures that provide equivalent or greater emissions reduction/air quality benefits than the 

measure(s) being removed from the SIP. 

This SIP revision replaces the potential 0.1 tpd NOX control strategy reduction loss from the 

expanded §117.403 exemption with an equal 0.1 tpd NOX allotment from surplus vehicle fleet 

turnover emission reductions predicted to occur in the one-year period beginning June 15, 2009. 

Allocating 0.1 tpd NOX reduction from fleet turnover surplus emissions ensures that adoption of 

the Chapter 117 rulemaking associated with this DFW RACT, Rule, and Contingency SIP 

Revision will not interfere with the DFW 1997 eight-hour ozone attainment demonstration. 

4.2.2.2. – 4.2.2.4. (No revision) 

4.2.3. – 4.2.7. (No revision)

4.3. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS 

4.3.1. DFW VOC RACT Analysis Update

The DFW eight-hour ozone nonattainment area is currently classified moderate nonattainment for 

the 1997 eight-hour ozone NAAQS. Under the 1997 eight-hour ozone standard, the DFW area is 

required to meet the mandates of the FCAA under §172(c)(1) and §182(b)(2) and (f). According 

to the EPA’s Final Rule to Implement the 1997 eight-hour ozone NAAQS (40 CFR §51.912), 

states containing areas classified as moderate nonattainment or higher must submit a SIP revision 

Adopted March 10, 2010 4-3
DFW RACT, Rule, and Contingency SIP Revision

demonstrating that their current rules fulfill the RACT requirements for all CTG categories and 

all non-CTG major sources of NOX and VOC. 

In the September 17, 1979, issue of the Federal Register (44 FR 53762) 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. RACT requirements for nonattainment areas classified as moderate and higher are 

included in the FCAA to assure that significant source categories at major sources of ozone 

precursor emissions are controlled to a reasonable extent, but not necessarily to best available 

control technology levels expected of new sources or to maximum achievable control technology 

levels required for major sources of hazardous air pollutants. Advancing attainment of the area is 

not a factor of consideration when evaluating RACT because the benefit of implementing RACT 

is presumed under the FCAA. 

The EPA previously approved the VOC RACT analysis as submitted in the May 2007 DFW 

Eight-Hour Ozone Attainment Demonstration SIP Revision (74 FR 1903; January 14, 2009). The 

analysis demonstrated all CTG emission source categories addressed by CTG documents issued 

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

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

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

technologically or economically feasible. 

However, the EPA-approved 2007 VOC RACT analysis did not address 11 CTG documents 

issued between 2006 and 2008 with recommendations for VOC controls on a variety of consumer 

and commercial products. Some of the new CTG recommendations are updates to previously 

issued CTG documents and some are recommendations for new emission source categories. This 

RACT analysis update addresses the evaluation of these 11 new CTG documents to determine if 

additional VOC controls are necessary to fulfill RACT requirements for the DFW area. 

The following is a list of the CTG documents: 

 Flat Wood Paneling Coatings, Group II Issued in 2006

 Flexible Packaging Printing Materials, Group II Issued in 2006

 Industrial Cleaning Solvents, Group II Issued in 2006

 Offset Lithographic and Letterpress Printing, Group II Issued in 2006

 Large Appliance Coatings, Group III Issued in 2007

 Metal Furniture Coatings, Group III Issued in 2007

 Paper, Film, and Foil Coatings, Group III Issued in 2007

 Auto and Light-Duty Truck Assembly Coatings, Group IV Issued in 2008

 Fiberglass Boat Manufacturing Materials, Group IV Issued in 2008

 Miscellaneous Industrial Adhesives, Group IV Issued in 2008

 Miscellaneous Metal and Plastic Parts Coatings, Group IV Issued in 2008

A brief summary of the TCEQ's RACT determinations regarding these 11 CTG documents 

follows. Additional details regarding the evaluation of the 11 CTG documents are provided in 

Appendix A: Dallas-Fort Worth Reasonably Available Control Technology Analysis Update. 

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DFW RACT, Rule, and Contingency SIP Revision

4.3.1.1. CTG Documents Not Applicable to the DFW Area

The TCEQ provides a negative declaration for the Flat Wood Paneling Coatings CTG and the 

Fiberglass Boat Manufacturing CTG. The TCEQ determined that no sources meeting the 

applicability criteria recommended in these CTG documents are located in the DFW area. 

4.3.1.2. CTG Documents for which RACT Determinations are Not Being Made

The TCEQ is not making a determination at this time of whether the recommendations in the 

following eight CTG documents represent RACT for Texas: Industrial Cleaning Solvents, 

Miscellaneous Industrial Adhesives, Large Appliance Coatings, Metal Furniture Coatings, 

Miscellaneous Metal and Plastic Parts Coatings, Flexible Packaging Printing Materials, 

Automobile and Light-Duty Truck Assembly Coatings, and Paper, Film, and Foil Coatings. 

The TCEQ's initial assessment of Industrial Cleaning Solvents and the Miscellaneous Industrial 

Adhesives CTG documents indicates that the EPA substantially underestimated the scope and 

potential impact of implementing the CTG recommendations, as they would have widespread and 

potentially adverse impacts to small businesses and micro-businesses. The TCEQ will continue 

to evaluate these CTG documents and will provide small business outreach to engage potentially 

impacted stakeholders. Research to determine the quantity of sources affected by the 

recommendations has been initiated. The Executive Director will proceed with RACT analyses 

of these CTGs and will initiate a future SIP revision and rulemaking for the commission's 

consideration, if necessary, in order to submit RACT determinations to the EPA in a timely 

manner. 

By letter dated December 8, 2008, the TCEQ requested clarification from the EPA regarding 

several issues related to recommendations in the CTG documents for Large Appliance Coatings, 

Metal Furniture Coatings, and Miscellaneous Metal and Plastic Parts Coatings. A number of the 

VOC content limits recommended for specific coatings categories are less stringent than the more 

general VOC content limits specified in the EPA's original CTG recommendations. The TCEQ 

requested clarification to assure that implementation of the new recommendations would not be 

backsliding and to be certain that the TCEQ has appropriate information to determine if the CTG 

recommendations actually represent RACT for Texas. As of the September 23, 2009, TCEQ's 

agenda for proposal of this SIP revision, the EPA had not formally responded to the request for 

clarification; therefore, the TCEQ did not propose RACT determinations for these CTG 

document categories. However, in comments submitted for this SIP revision, the EPA provided 

suggestions and guidance regarding the issues raised by the TCEQ in the December 2008 letter. 

The Executive Director will proceed with RACT analyses of these three CTG documents based 

on guidance provided in the EPA's comments and will initiate a future SIP revision and 

rulemaking for the commission's consideration, if necessary, in order to submit RACT 

determinations to the EPA in a timely manner. 

At the September 23, 2009, agenda for proposal of this SIP revision, the TCEQ determined that 

emission sources affected by recommendations in the Flexible Packaging Printing Materials, 

Automobile and Light-Duty Truck Assembly Coatings, and Paper, Film, and Foil CTG 

documents have enforceable permit limitations in place that restrict VOC emissions to levels 

consistent with the recommendations and that additional controls were not necessary. However, 

in response to the EPA's comments on this SIP revision, the TCEQ has decided to reevaluate 

these CTGs for RACT determination. The Executive Director will proceed with these analyses 

and will initiate a future SIP revision and rulemaking for the commission's consideration, if 

necessary, in order to submit RACT determinations to the EPA in a timely manner. 

Adopted March 10, 2010 4-5
DFW RACT, Rule, and Contingency SIP Revision

4.3.1.3. CTG Documents that Represent RACT for the DFW Area

Concurrent with this SIP revision, the TCEQ adopted revisions to 30 TAC Chapter 115, 

Subchapter E, Division 4 to implement the EPA's 2006 Offset Lithographic and Letterpress 

Printing CTG recommendations that represent RACT in the DFW area (TCEQ Rule Project 

2008-019-115-EN). The adopted Chapter 115 rulemaking reduces the VOC content of the 

fountain solutions and cleaning solutions used by offset lithographic printing operations and 

expands the rule applicability to include smaller offset lithographic printing sources that were 

previously exempt from these rules. The overall VOC control level in the adopted Chapter 115 

rules is equivalent to or more stringent than the EPA's 2006 CTG recommendations and sufficient 

to fulfill RACT for offset lithographic printing operations in the DFW area. 

4.4. - 4.5. (No revision)

4.6. CONTINGENCY MEASURES 

4.6.1. Background

FCAA (42 USC §7502(c)(9) and §7511a(c)(9)) and the EPA’s final Phase 2 1997 eight-hour 

ozone implementation rule require that the SIPs for all 1997 eight-hour ozone nonattainment 

areas include contingency measures as additional controls needed to further reduce emissions in 

the event an area fails to attain by its attainment date. The FCAA requires that states with ozone 

nonattainment areas classified as moderate and above include contingency measures in their SIP 

(sections 172(c)(9) and 182(c)(9)). Per the FCAA, the failure-to-attain contingency plan must 

identify control measures sufficient to secure an additional 3 percent reduction (from the base 

year emissions inventory used for development of the attainment demonstration) in ozone 

precursor emissions should a moderate nonattainment area fail to attain the 1997 eight-hour 

ozone NAAQS by the June 15, 2010, required attainment date. The May 2007 DFW AD SIP 

Revision, Appendix B: Emissions Inventory Development identifies 520.08 tpd of VOC and 

754.56 tpd of NOX in the 1999 base year emissions inventory from all anthropogenic sources in 

the DFW nine-county nonattainment area. 

As part of its January 14 2009, final conditional approval of the DFW 1997 Eight-Hour Ozone 

AD SIP Revision, as supplemented and revised (74 FR 1903), the EPA deemed the failure-toattain contingency plan (as submitted in the May 2007 DFW AD SIP Revision, supplemented in 

April 2008, and revised in the November 2008 DFW AD SIP Contingency Plan Revision) to be 

complete and fully approved. That contingency plan identified emissions reductions from three 

state VOC rules along with emission reductions from the 2009 through 2010 mobile source fleet 

turnover as the contingency measures. At the time these VOC rules were identified for the DFW 

1997 eight-hour ozone failure-to-attain contingency plan, they were not required to meet VOC 

RACT requirements. The three rules, applicable to (1) Offset Lithographic Printing, as in 30 

TAC § 115.449(c); (2) Degassing or Cleaning of Stationary, Marine, and Transport Vessels, as in 

30 TAC §115.549(b); and (3) Petroleum Dry Cleaning, as in 30 TAC §115.559(a), were 

determined to provide a cumulative 1.80 tpd VOC emission reduction from sources in Collin, 

Dallas, Denton, and Tarrant Counties. Surplus emission reductions predicted to result from the 

fleet turnover to occur over a one-year period beginning June 15, 2009, were identified to provide 

the remainder of emission reductions needed for the 3 percent contingency requirement. 

The turnover of the on-road fleet of cars and trucks will result in additional VOC and NOX

emission benefits in 2009 and beyond because newer vehicles have significantly lower emission 

standards than vehicles they are replacing. New vehicle emission standards are lower primarily 

Adopted March 10, 2010 4-6
DFW RACT, Rule, and Contingency SIP Revision

due to a number of federal rules such as the Tier 2 standards for automobiles and light trucks, and 

the 2007 heavy-duty diesel standards for large diesel highway trucks. Emission reductions 

predicted to occur from the fleet turnover during the one-year period beginning June 15, 2009, are 

estimated to total 4.86 tpd VOC and 20.78 tpd NOX. 

 

4.6.2. Modified DFW 1997 Eight-Hour Ozone Failure-to-Attain Contingency Plan

This DFW RACT, Rule, and Contingency SIP Revision revises the contingency plan for the 

DFW 1997 eight-hour ozone attainment demonstration. Removal of the contingency measure for 

offset lithographic printing and a modification of the allotment of fleet turnover reductions 

dedicated to the failure-to-attain contingency plan are both included in this SIP revision. This 

DFW RACT, Rule, and Contingency SIP Revision dedicates 13.36 tpd of the NOX emission 

reductions, and 4.86 tpd of the VOC emission reductions predicted from the June 2009 through 

2010 fleet turnover to provide reductions for the contingency plan. 

Due to the associated Chapter 115 rule applicable to the same sources, the offset lithographic 

printing rule contingency measure (and the associated 0.24 tpd predicted VOC reduction) is being 

removed as a contingency measure. However, the two other state VOC rules identified in the SIP 

revision will remain as contingency measures. Those two VOC rule contingency measures 

provide controls applicable to the degassing or cleaning process of stationary, marine, and 

transport vessels, and to petroleum-based dry cleaning. 

The three contingency measures identified in Table 4.1: Emission Reductions Provided by 

Modified Failure-to-Attain Contingency Plan, and further described below, are measures 

identified for the DFW 1997 eight-hour ozone failure-to-attain contingency plan, for 

implementation in the event the contingency plan is triggered. 

1. A VOC reduction of 0.18 tpd will be made through controls on the degassing or cleaning 

process of stationary, marine, and transport vessels. All affected persons in Collin, 

Dallas, Denton, and Tarrant Counties must be in compliance with 30 TAC, Chapter 115, 

Subchapter F, Division 3 (relating to Degassing or Cleaning of Stationary, Marine, and 

Transport Vessels) as soon as practicable, but no later than one year, after notification is 

published in the Texas Register of the commission’s determination that this contingency 

rule is necessary as a result of failure to attain the 1997 NAAQS for ozone by the 

attainment deadline as set forth in the 1990 Amendments to the FCAA, § 172(c)(9). The 

commission will submit notification to the Texas Register for publication within 60 days 

after the EPA notifies the state of its failure through publication of a final action in the 

Federal Register. 

2. A VOC reduction of 1.38 tpd will be made through controls on petroleum-based dry 

cleaning businesses. All affected petroleum solvent dry cleaning facilities in Collin, 

Dallas, Denton, and Tarrant Counties must be in compliance with 30 TAC, Chapter 115, 

Subchapter F, Division 4 (relating to Petroleum Dry Cleaning Systems) as soon as 

practicable, but no later than one year, after notification is published in the Texas Register 

of the commission’s determination that this contingency rule is necessary as a result of 

failure to attain the 1997 NAAQS for ozone by the attainment deadline as set forth in the 

1990 Amendments to FCAA, §172(c)(9). The commission will submit notification to the 

Texas Register for publication within 60 days after the EPA notifies the state of its failure 

through publication of a final action in the Federal Register. 

Adopted March 10, 2010 4-7
DFW RACT, Rule, and Contingency SIP Revision

3. Emission reductions to provide 4.86 tpd VOC and 13.36 tpd NOX, allotted to the DFW 

contingency plan from and out of surplus emission reductions that will result from the 

motor vehicle fleet turnover to occur during a one-year period beginning June 15, 2009. 

Table 4.1: Emission Reductions Provided by Modified Failure-to-Attain Contingency Plan 

Contingency Plan Emission Reductions (tpd) VOC NOX

State VOC rule contingency measure applicable to the Degassing or 

Cleaning of Stationary, Marine, and Transport Vessels* 0.18 00.00

State VOC rule contingency measure applicable to Petroleum Dry 

Cleaning* 1.38 00.00

Mobile source fleet turnover emission reductions** 

(portion allocated for contingency) 4.86 13.36

Total Contingency Plan Reductions 6.42 13.36

 *applicable in Collin, Dallas, Denton, and Tarrant Counties only 

**attributable to DFW nine-county area 

The method used to calculate the DFW 3 percent contingency emission reduction requirement is 

represented in the following equation: 

RV/VOCBASE + RN/NOXBASE >= 0.03 where; 

RV = typical summer day VOC reductions in mass units 

RN = typical summer day NOX reductions in mass units 

VOCBASE = the mass of anthropogenic VOC emissions in the 1999 base year inventory, and 

NOXBASE = the mass of anthropogenic NOX emissions in the 1999 base year inventory, and was 

calculated as follows: [(6.42/520.08) + (13.36/754.56)] = 3% 

Table 4.2: Calculations Showing Required 3 Percent Contingency Reductions, shows that the 

DFW contingency plan will provide a 1.23 percent reduction from the DFW area 1999 base year 

VOC emissions inventory, and a 1.77 percent reduction from the corresponding NOX emissions 

inventory. Following the EPA’s NOX substitution guidance to calculate the contingency plan 

reductions, the 1.23 (percent VOC reduction) is added to the 1.77 (percent NOX reduction) to 

equal the required 3.00 (percent total VOC and/or NOX emissions reductions). This modified 

contingency plan identifies measures to provide the required reductions, totaling 6.42 tpd VOC 

and 13.36 tpd NOX. 

Table 4.2: Calculations Showing Required 3 Percent Contingency Reductions 

Contingency Plan Reduction Calculations VOC NOX

1999 base year EI, DFW 9-county area (tpd weekday) 520.08 754.56

tpd emissions reductions from the two state VOC rule measures 1.56 0.00

tpd emissions reductions from the surplus fleet turnover emissions 

reductions allotted for the contingency plan 4.86 13.36

(Total tpd reductions to be provided by the modified contingency plan) (6.42) (13.36)

Percentage of inventory reduction for each precursor 1.23% 1.77%

Total percentage of reductions provided by the plan 3.00% total 

Adopted March 10, 2010 4-8
DFW RACT, Rule, and Contingency SIP Revision

Adopted March 10, 2010 4-9

4.6.3. Allocations from Surplus 2009 through 2010 Fleet Turnover Reductions

Table 4.3: Allocation of Surplus Emissions Reductions from 2009-2010 Fleet Turnover 

consolidates emissions reductions allocations in this DFW RACT, Rule, and Contingency SIP. 

Out of the total 4.86 tpd VOC and 20.78 tpd NOX emission reductions predicted to occur from the 

fleet turnover expected during the one-year period beginning June 15, 2009, all of the 4.86 tpd 

VOC and 13.36 tpd of the NOX reductions are allotted to provide reductions for the DFW 

contingency plan. The remaining 7.32 tpd surplus NOX emissions reduction from fleet-turnover 

is surplus and usable for other future SIP purposes. 

Table 4.3: Allocation of Surplus Emissions Reductions from 2009 - 2010 Fleet Turnover 

Vehicle Fleet Turnover Emission Reductions* (tpd) VOC NOX

Total emissions reductions from June 2009 through 2010 fleet turnover 4.86 20.78 

Allocation to replace NOX reduction lost from control strategy upon 

adoption of Chap. 117 rulemaking (see section 4.2.2.1) -0.00 - 0.10 

Allocation to the DFW contingency plan -4.86 - 13.36 

Remaining surplus emission reductions available for future SIP use 0.00 7.32 

* from the nine-county DFW eight-hour ozone nonattainment area 

 
DFW RACT, Rule, and Contingency SIP Revision

APPENDIX A: 

DALLAS-FORT WORTH 

REASONABLY AVAILABLE CONTROL TECHNOLOGY 

ANALYSIS UPDATE 

Adopted March 10, 2010 
DFW RACT, Rule, and Contingency SIP Revision

INDEX: 

Description Page

Section 1.0. Introduction A-2 

Section 2.0. RACT Evaluation Approach A-3 

 2.1. General Discussion A-3 

 2.2. Identification of CTG Emission Source Categories A-3 

 2.3. Determining if State Regulations Fulfill RACT Requirements A-3 

Section 3.0. RACT Determination and Discussion A-4 

 3.1. EPA Consumer and Commercial Products CTG Documents, 

 Group II, Issued in 2006 A-4 

3.2. EPA Consumer and Commercial Products CTG Documents, 

Group III, Issued in 2007 A-6 

3.3. EPA Consumer and Commercial Products CTG Documents, 

Group IV, Issued in 2008 A-7 

 

Attachment 1 

 December 8, 2008, Letter to Mr. William T. Harnett, Director, 

 Air Quality Policy Division, United States Environmental Protection 

 Agency on Issues related to Control Techniques Guidelines documents A-10 

Adopted March 10, 2010 A-2
DFW RACT, Rule, and Contingency SIP Revision

DALLAS-FORT WORTH 

REASONABLY AVAILABLE CONTROL TECHNOLOGY ANALYSIS UPDATE 

1.0. Introduction 

The Dallas-Fort Worth (DFW) eight-hour ozone nonattainment area (Dallas, Denton, Collin, 

Tarrant, Parker, Johnson, Ellis, Kaufman, and Rockwall Counties) is currently classified 

moderate nonattainment for the United States Environmental Protection Agency (EPA) 1997 

eight-hour ozone National Ambient Air Quality Standard (NAAQS). Under the 1997 eight-hour 

ozone standard, the area is required to meet the mandates of the Federal Clean Air Act (FCAA) 

under §§172(c)(1), 182(b)(2) and 182(f). According to the EPA’s Final Rule to Implement the 

Eight-Hour Ozone NAAQS (40 Code of Federal Regulations (CFR) §51.912, November 29, 

2005), states containing areas classified as moderate nonattainment or higher must submit a state 

implementation plan (SIP) revision demonstrating that their current rules fulfill the reasonably 

available control technology (RACT) requirements for all control technique guidelines (CTG) 

categories and all non-CTG major sources of nitrogen oxides (NOX) and volatile organic 

compounds (VOC). 

RACT is defined as the lowest emissions limitation that a particular source is capable of meeting 

by the application of control technology that is reasonably available considering technological 

and economic feasibility (44 FR 53762; September 17, 1979). RACT requirements for moderate 

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

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

extent, but not necessarily to best available control technology levels expected of new sources or 

to maximum achievable control technology levels required for major sources of hazardous air 

pollutants. Advancing attainment of the area is not a factor of consideration when evaluating 

RACT because the benefit of implementing RACT is presumed under the FCAA. 

The EPA previously approved the VOC RACT analysis as submitted in the May 2007 DFW 

Eight-Hour Ozone Attainment Demonstration SIP Revision (74 FR 1903; January 14, 2009). The 

analysis demonstrated all CTG emission source categories addressed by CTG documents issued 

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

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

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

technologically or economically feasible. 

However, the EPA-approved 2007 VOC RACT analysis did not address 11 CTG documents 

issued between 2006 and 2008 with recommendations for VOC controls on a variety of consumer 

and commercial products. Some of the new CTG recommendations are updates to previously 

issued CTG documents and some are recommendations for new emission source categories. This 

RACT analysis update addresses the evaluation of these 11 new CTG documents to determine if 

additional VOC controls are necessary to fulfill RACT requirements for the DFW area. 

Adopted March 10, 2010 A-3
DFW RACT, Rule, and Contingency SIP Revision

The following is a list of the CTG documents: 

 Flat Wood Paneling Coatings, Group II Issued in 2006 

 Flexible Packaging Printing Materials, Group II Issued in 2006 

 Industrial Cleaning Solvents, Group II Issued in 2006 

 Offset Lithographic and Letterpress Printing, Group II Issued in 2006 

 Large Appliance Coatings, Group III Issued in 2007 

 Metal Furniture Coatings, Group III Issued in 2007 

 Paper, Film, and Foil Coatings, Group III Issued in 2007 

 Auto and Light-Duty Truck Assembly Coatings, Group IV Issued in 2008 

 Fiberglass Boat Manufacturing Materials, Group IV Issued in 2008 

 Miscellaneous Industrial Adhesives, Group IV Issued in 2008 

 Miscellaneous Metal and Plastic Parts Coatings, Group IV Issued in 2008

2.0. RACT Evaluation Approach 

2.1. General Discussion 

The TCEQ demonstrates that RACT requirements are fulfilled by: (1) identifying all CTG source 

categories of VOC and NOX emissions and submitting negative declarations for categories where 

no major emission sources exist; (2) identifying all non-CTG major sources of VOC and NOX

emissions; (3) identifying the state regulation implementing or exceeding RACT for each 

applicable CTG source category or non-CTG major emission source; and (4) describing the basis 

for conclusion that the regulations fulfill RACT. Specifically, this SIP revision updates the DFW 

VOC RACT analysis to address the 11 consumer and commercial products CTG documents 

issued by the EPA from 2006 through 2008. 

2.2. Identification of CTG Emission Source Categories 

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

Commission on Environmental Quality (TCEQ) reviewed the 11 consumer and commercial 

products CTG documents issued by the EPA from 2006 through 2008 to identify all source 

categories of VOC emissions that require RACT. RACT determinations are not required if there 

are no facilities in the DFW area that are subject to the CTG document. A negative declaration is 

provided for source categories described within the EPA guidance documents that do not exist in 

the DFW area. 

2.3. Determining if State Regulations Fulfill RACT Requirements 

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

Chapter 115 as meeting FCAA RACT requirements for CTG documents issued prior to 2006. 

RACT determinations regarding the 11 CTG documents issued in 2006 and later were made by 

comparing the CTG recommendations to TCEQ rules to determine if the existing rules satisfy 

RACT. Although CTG documents provide the EPA's RACT recommendations for controlling 

emissions from specific sources, EPA guidance on RACT indicates that states can choose to 

implement the CTG recommendations, implement an alternative approach, or demonstrate that 

additional control for the CTG emission source category is not technologically or economically 

feasible in the area. Additional discussion regarding the evaluation of the CTG recommendations 

Adopted March 10, 2010 A-4
DFW RACT, Rule, and Contingency SIP Revision

is provided in Sections 3.3.2: Fiberglass Boat Manufacturing Materials, through 3.3.4: 

Miscellaneous Metal and Plastic Parts Coatings. 

3.0. RACT Determination and Discussion 

3.1. The EPA Consumer and Commercial Products CTG Documents, Group II Issued in 

2006 

3.1.1. Flat Wood Paneling Coatings 

No facilities meeting the applicability of the 2006 Flat Wood Paneling Coatings CTG document 

were identified in the DFW area. Therefore, the TCEQ provides a negative declaration for this 

source category with regard to RACT for the DFW area. 

The EPA indicated in Appendix B: State and Local Regulations for Flat Wood Paneling of the 

Flat Wood Paneling Coatings CTG that two facilities in Texas ozone nonattainment areas are 

potentially subject to the recommendations. Based on a review of the 2005 point source 

emissions inventory, the TCEQ determined that only one facility in the DFW area, Buell Door 

Company, TCEQ Account Number DB-0128-U, may fit the source category description in the 

Flat Wood Paneling Coatings CTG. However, that facility ceased all operations in 2006 and to 

date has not reported any emissions for the site for subsequent years. The TCEQ does not expect 

that the company will resume business operations at this facility. 

3.1.2. Flexible Packaging Printing Materials 

At the September 23, 2009, agenda for proposal of this SIP revision, the TCEQ did not propose to 

revise the flexographic and rotogravure printing rules in 30 TAC Chapter 115, Subchapter E, 

Division 3 to implement the 2006 Flexible Packaging Printing Materials CTG recommendations. 

Flexible package printing sources in the DFW area affected by the CTG recommendations were 

determined to have enforceable permit limitations in place that restrict VOC emissions to levels 

consistent with the CTG recommendations. Therefore, the commission proposed that additional 

controls were not necessary for this CTG category. 

At the September 23, 2009, agenda for proposal of this SIP revision the commission proposed 

that additional controls were not necessary for this CTG category. Because of EPA's comments 

on this SIP revision, the TCEQ has decided to reevaluate the RACT determination for the 

Flexible Packaging Printing Materials CTG recommendations. The Executive Director will 

proceed with the RACT analysis of this CTG document and initiate a future SIP revision and 

rulemaking for the commission's consideration, as appropriate, in order to submit a RACT 

determination to the EPA in a timely manner. 

3.1.3. Industrial Cleaning Solvents

The TCEQ is not making a RACT determination at this time regarding the Industrial Cleaning 

Solvents CTG recommendations. The TCEQ's assessment indicates that the EPA substantially 

underestimated the scope and potential impact of the CTG recommendations. In Appendix D of 

the CTG document: Number of nonattainment facilities organized by State that are estimated to 

meet the applicability criteria recommended in the CTG, the EPA estimated 92 facilities in Texas 

nonattainment areas would be subject to the recommendations. However, the North American 

Industry Classification System (NAICS) codes provided in Appendix C of the CTG document: 

Adopted March 10, 2010 A-5
DFW RACT, Rule, and Contingency SIP Revision

Summary of NAICS Codes for nonattainment facilities estimated to meet the applicability criteria 

recommended in the CTG suggests a much broader applicability. Based on the EPA's suggested 

exemption threshold of 15 pounds per day of VOC and the listed NAICS codes, the TCEQ 

estimates that implementing the CTG would have widespread and potentially adverse impacts to 

small business and micro-business in Texas. An integral part of determining whether a control 

technology or measure represents RACT is evaluating the technological and economic feasibility 

of the proposed controls. Determining technological and economic feasibility is not possible 

when the applicability of the control measure is ambiguous. The TCEQ will continue to evaluate 

this CTG and intends to provide small business outreach to engage stakeholders that could be 

potentially impacted by the EPA's suggested control measures. The Executive Director will 

proceed with the RACT analysis of this CTG document and initiate a future SIP revision and 

rulemaking for the commission's consideration, if necessary, in order to submit a RACT 

determination to the EPA in a timely manner. 

 

3.1.4. Offset Lithographic and Letterpress Printing 

Concurrent with this SIP revision, the TCEQ adopted revisions to 30 TAC Chapter 115, 

Subchapter E, Division 4 to implement the EPA's 2006 Offset Lithographic and Letterpress 

Printing CTG recommendations that represent RACT in the DFW area. The adopted Chapter 115 

rulemaking reduces the VOC content of the fountain solutions and cleaning solutions used by 

offset lithographic printing operations, and expands rule applicability to include smaller offset 

lithographic printing sources that were previously exempt from these rules. The TCEQ 

determined that no letterpress printing operations meeting the applicability criteria recommended 

in the CTG document are located in the DFW area. Therefore, the TCEQ provides a negative 

declaration for the Letterpress Printing CTG source category. 

In its analysis of the EPA's 2006 Offset Lithographic and Letterpress Printing CTG 

recommendations, the TCEQ must balance the VOC control level in the adopted Chapter 115, 

Subchapter E, Division 4 rules and potential for backsliding from implementing the 2006 CTG 

recommendations, along with enforceability considerations, and possible impacts to sources that 

have already complied with the existing rules. 

In several instances the adopted Chapter 115 content limits are more stringent than EPA's 2006 

CTG recommendations. The 2006 CTG recommends include limiting the VOC content of 

cleaning solutions used in offset lithographic printing operations to 70 percent VOC by weight in 

conjunction with work practice standards. The adopted Chapter 115 rules retain the more 

stringent cleaning solution content limit of 70 percent VOC by volume in conjunction with work 

practice standards. Assuming the VOC in the cleaning solvent used is kerosene, the VOC 

referenced in the 2006 CTG, the adopted Chapter 115 content limit of 70 percent VOC by volume 

for cleaning solutions is equivalent to 66 percent VOC by weight. EPA's 2006 CTG also 

recommends limiting the fountain solution content to 5 percent alcohol substitutes or less by 

weight and no alcohol in the fountain solution. To prevent potential backsliding for sources 

already required to comply with these state regulations, the adopted Chapter 115 rules retain the 

more stringent fountain solution content limit of 3 percent alcohol substitutes or less by weight 

and no alcohol in the fountain solution. 

The adopted Chapter 115 rules for heatset offset lithographic presses are at least as stringent as 

the EPA's 2006 CTG recommended controls. The EPA's CTG recommends an add-on air 

pollution control device be required on each individual heatset offset lithographic press with the 

uncontrolled potential to emit 25 tons per year (tpy) of VOC or more from the dryer. The rules in 

Chapter 115, Subchapter E, Division 4, require control devices, with a control efficiency of at 

Adopted March 10, 2010 A-6
DFW RACT, Rule, and Contingency SIP Revision

least 90 percent, to be installed on heatset offset lithographic presses on a property in the DFW 

area with total uncontrolled VOC emissions of at least 50 tpy, which includes VOC emissions 

from ink oils evaporated by the press dryer and VOC in fountain and cleaning solutions. In Table 

Table 5-1: Model Plant Product Use and Baseline (Uncontrolled) Volatile Organic Compounds 

(Average Tons Per Year), of the 1993 draft Offset Lithographic Printing CTG, the EPA estimates 

that 26 percent of the total uncontrolled VOC emissions from heatset offset lithographic printing 

operations are emitted from the press dryer. Based on EPA's assumption, an individual heatset 

press located on a property with total uncontrolled VOC emissions of 50 tpy would emit less than 

13 tpy of VOC from the press dryer. Therefore, the Chapter 115 rules are effectively more 

stringent than the EPA's 2006 CTG RACT recommendations with regard to the applicability 

threshold for this control requirement. Additionally, the EPA's 2006 CTG recommended 

exempting heatset presses used for book printing and heatset presses with a maximum web width 

of 22 inches or less from the add-on control device requirements. The existing Chapter 115 

regulations do not exempt these sources from the control requirements and the TCEQ has not 

adopted these exemptions into the revised rule. 

The EPA's CTG recommends requiring control equipment first installed before the effective date 

of rules implementing the CTG to have an overall control efficiency of 90 percent and control 

equipment first installed after the effective date of rules implementing the CTG to have an overall 

control efficiency of 95 percent. The TCEQ disagrees with the EPA's CTG recommendation to 

correlate control device efficiency requirements with the first installation date of the control 

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

installation of older, less efficient equipment and may create potential backsliding issues. The 

policy may also create significant practical enforceability issues for TCEQ investigators with 

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

 

Regardless of the first installation date of the device, the EPA recommends providing the 

alternative option to reduce the control device outlet concentration to 20 parts per million by 

volume (ppmv) as hexane on a dry basis to accommodate situations where the inlet VOC 

concentration is too low to demonstrate the 90 or 95 percent control efficiency. The Chapter 115 

rules provide affected owners or operators of a heatset offset lithographic printing press the 

option to operate a control device to reduce VOC emissions from the press dryer exhaust vent by 

90 percent by weight or maintain a maximum dryer exhaust outlet VOC concentration of 20 

ppmv. The Chapter 115 alternative concentration limit is substantially preferable because it 

encourages VOC emission reductions without requiring add-on controls and implementing the 

EPA's recommended approach would penalize operations who were able to achieve the 20 ppmv 

limit without the installation of expensive add-on control devices. 

Based on this analysis, the TCEQ determined that the adopted Chapter 115 rules for offset 

lithographic printing operations provide an overall VOC control level that is at least equivalent to 

the 2006 CTG recommendations and are more effective and enforceable. Therefore, the revised 

Chapter 115, Subchapter E, Division 4 rules are sufficient to fulfill RACT for offset lithographic 

printing operations in the DFW area. 

3.2. EPA Consumer and Commercial Products CTG Documents, Group III Issued in 2007 

3.2.1. Large Appliance Coatings 

By letter dated December 8, 2008, the TCEQ requested clarification from the EPA regarding 

several issues related to the Large Appliance Coatings CTG recommendations. Current TCEQ 

Adopted March 10, 2010 A-7
DFW RACT, Rule, and Contingency SIP Revision

rules in Chapter 115 for large appliance coating operations are based on the original Large 

Appliance Coatings CTG issued by the EPA in 1977. A number of the recommended VOC 

content limits for specific coatings categories listed in the 2007 CTG document are less stringent 

than the more general VOC content limits specified in the EPA's original CTG recommendations 

for the Large Appliance Coatings category. Since the 2007 Large Appliance Coatings CTG 

document does not specifically address this issue, the TCEQ requested clarification to ensure that 

implementing the CTG recommendations would not be considered backsliding and to be certain 

that the TCEQ has the appropriate information to determine whether the 2007 CTG 

recommendations actually represent RACT for Texas. See Attachment 1 for the TCEQ letter to 

the EPA requesting clarification on these issues. 

The EPA did not formally respond to the TCEQ's request for clarification on the CTG document. 

Therefore, the TCEQ did not propose a RACT determination for the Large Appliance Coatings 

CTG source category. However, in the comments submitted for this SIP revision, the EPA did 

provide suggestions and guidance regarding the issues raised by the TCEQ in the December 2008 

letter. The Executive Director will proceed with the RACT analysis of this CTG document based 

on the guidance provided in the EPA's comments and initiate a future SIP revision and 

rulemaking for the commission's consideration, if necessary, in order to submit a RACT 

determination to the EPA in a timely manner. 

3.2.2. Metal Furniture Coatings 

In the previously mentioned letter to the EPA of December 8, 2008, the TCEQ requested 

clarification regarding several issues related to the Metal Furniture Coatings CTG 

recommendations. Current TCEQ rules in Chapter 115 for metal furniture coating operations are 

based on the original Metal Furniture Coatings CTG document issued by the EPA in 1977. A 

number of the VOC content limits for specific coatings categories recommended in the 2007 CTG 

document are less stringent than the more general VOC content limits specified in the original 

recommendations for the Metal Furniture Coatings category. Since the 2007 Metal Furniture 

Coatings CTG document does not specifically address this issue, the TCEQ requested 

clarification from the EPA to ensure that implementing the 2007 CTG recommendations would 

not be considered backsliding and to be certain that the TCEQ has the appropriate information to 

determine whether the 2007 CTG recommendations actually represent RACT for Texas. See 

Attachment 1 for the TCEQ letter to the EPA requesting clarification on these issues. 

The EPA did not formally respond to the TCEQ's request for clarification on the CTG document. 

Therefore, the TCEQ did not propose a RACT determination for the Metal Furniture Coatings 

CTG source category. However, in the comments submitted for this SIP revision, the EPA did 

provide suggestions and guidance regarding the issues raised by the TCEQ in the December 2008 

letter. The Executive Director will proceed with the RACT analysis of this CTG document based 

on the guidance provided in the EPA's comments and initiate a future SIP revision and 

rulemaking for the commission's consideration as appropriate, if necessary, in order to submit a 

RACT determination to the EPA in a timely manner. 

3.2.3. Paper, Film, and Foil Coatings 

At the September 23, 2009, agenda for proposal of this SIP revision, the TCEQ did not propose to 

revise the surface coating rules in 30 TAC Chapter 115, Subchapter E, Division 2 to implement 

the 2007 Paper, Film, and Foil Coatings CTG recommendations. Paper, film, and foil coating 

operations in the DFW area affected by the CTG recommendations were determined to have 

Adopted March 10, 2010 A-8
DFW RACT, Rule, and Contingency SIP Revision

enforceable permit limitations in place that restrict VOC emissions to levels consistent with the 

CTG recommendations.. 

Therefore, the commission proposed that additional controls were not necessary for this CTG 

category. However, in response to EPA's comments on this SIP revision, the TCEQ has decided 

to reevaluate the RACT determination for the Paper, Film, and Foil Coatings CTG 

recommendations. The Executive Director will proceed with the RACT analysis of this CTG 

document and initiate a future SIP revision and rulemaking for the commission's consideration as 

appropriate, in order to submit a RACT determination to the EPA in a timely manner. 

3.3. EPA Consumer and Commercial Products CTG Documents, Group IV Issued in 2008 

3.3.1. Auto and Light-Duty Truck Assembly Coatings 

One site identified in the DFW area is subject to the Auto and Light-Duty Truck Assembly 

Coatings CTG document: General Motors Corporation's Arlington Assembly Plant, TCEQ 

Account Number TA-0157-I. On page 23 of the 2008 Automobile and Light-Duty Truck 

Assembly Coatings CTG, the EPA indicates that VOC emission reductions will not result from 

implementing the CTG recommendations because these facilities have previously reduced coating 

operation VOC emissions in compliance with 40 Code of Federal Regulations (CFR) Part 60, 

New Source Performance Standards (NSPS), Subpart MM, Automobile and Light-Duty Truck 

Surface Coating Operations; 40 CFR Part 63, National Emission Standards for Hazardous Air 

Pollutants (NESHAPS), Subpart IIII, Surface Coating of Automobiles and Light-Duty Trucks; 

and existing state rules. 

At the September 23, 2009, agenda for proposal of this SIP revision the commission proposed 

that additional controls were not necessary for this CTG category. However, in response to 

EPA's comments on this SIP revision, the commission has decided to reevaluate the RACT 

determination for the Automobile and Light-Duty Truck Assembly Coatings CTG 

recommendations. The Executive Director will proceed with the RACT analysis of this CTG 

document and initiate a future SIP revision and rulemaking for the commission's consideration, if 

necessary, in order to submit a RACT determination to the EPA in a timely manner. 

3.3.2. Fiberglass Boat Manufacturing Materials 

The 2008 Fiberglass Boat Manufacturing Materials CTG document did not identify any sources 

in Texas that would be subject to the CTG recommended controls. However, as of the September 

23, 2009, TCEQ's agenda for proposal of this SIP revision, the TCEQ could not make a definitive 

negative declaration for this source category. Since that time the TCEQ has conducted extensive 

additional review of sources identified in the point source emissions inventory, Title V permits, 

and central registry databases. No facilities meeting the applicability of the 2008 Fiberglass Boat 

Manufacturing Materials CTG document were identified in the DFW area. Therefore, the TCEQ 

provides a negative declaration for this source category with regard to RACT for the DFW area. 

3.3.3. Miscellaneous Industrial Adhesives 

The TCEQ is not making a RACT determination at this time regarding the Miscellaneous 

Industrial Adhesives CTG recommendations. Similar to the Industrial Cleaning Solvents CTG, 

the TCEQ's initial assessment indicates that the EPA substantially underestimated the scope and 

potential impact of the Miscellaneous Industrial Adhesives CTG recommendations. An integral 

Adopted March 10, 2010 A-9
DFW RACT, Rule, and Contingency SIP Revision

Adopted March 10, 2010 A-10

part of determining whether a control technology or measure represents RACT is evaluating the 

technological and economic feasibility of the proposed controls. Determining technological and 

economic feasibility is not possible when the applicability of the control measure is ambiguous. 

The TCEQ will continue to evaluate this CTG and intends to provide small business outreach to 

engage stakeholders that could be potentially impacted by the EPAs suggested control measures. 

The Executive Director will proceed with the RACT analysis of this CTG document and initiate a 

future SIP revision and rulemaking for the commission's consideration, if necessary, in order to 

submit a RACT determination to the EPA in a timely manner. 

3.3.4. Miscellaneous Metal and Plastic Parts Coatings 

In the previously mentioned letter dated December 8, 2008, the TCEQ requested clarification 

from the EPA regarding several issues related to the Miscellaneous Metal and Plastic Parts 

Coatings CTG recommendations. The TCEQ rules in Chapter 115 for these coating operations 

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

recommended VOC content limits for specific coatings categories listed in the 2008 CTG are less 

stringent than the more general VOC content limits specified in the EPA's original CTG 

recommendations for these categories. Since the 2008 Miscellaneous Metal and Plastic Parts 

Coatings CTG document does not specifically address this issue, the TCEQ requested 

clarification to ensure that that implementing the 2008 CTG would not be considered backsliding 

and to be certain that the TCEQ has the appropriate information to appropriately determine 

whether the 2008 recommendations actually represent RACT for Texas. See Attachment 1 for 

the TCEQ letter to the EPA requesting clarification on these issues. 

The EPA did not formally respond to the TCEQ's request for clarification on these CTG 

documents as of the September 23, 2009, agenda; therefore, the TCEQ did not propose a RACT 

determination for the Miscellaneous Metal and Plastic Parts Coatings CTG source category. 

However, in the comments submitted for this SIP revision, the EPA did provide suggestions and 

guidance regarding the issues raised by the TCEQ in the December 2008 letter. The Executive 

Director will proceed with the RACT analysis of this CTG document based on the guidance 

provided in the EPA's comments and initiate a future SIP revision and rulemaking for the 

commission's consideration, if necessary, in order to submit a RACT determination to the EPA in 

a timely manner. 
DFW RACT, Rule, and Contingency SIP Revision

APPENDIX A 

Dallas-Fort Worth Reasonably Available Control Technology Analysis Update 

Attachment 1 

December 8, 2008, Letter to Mr. William T. Harnett, Director, Air Quality Policy Division, 

United States Environmental Protection Agency on issues related to 

Control Techniques Guidelines documents 

Adopted March 10, 2010 
Buddy Garcia, Chairman 

Larry R. Soward, Commissioner 

Bryan W. Shaw, Ph.D., Commissioner 

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

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by Reducing and Preventing Pollution . 

December 8, 2008 

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

Office of Air Quality Planning and Standards Organization 

United States Environmental Protection Agency 

Mail Drop C504-01 

Research Triangle Park, North Carolina 27711 

Dear Director Harnett: 

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

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

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

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

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

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

documents are detailed below. 

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

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

, and 

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

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

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

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

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

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

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

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

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

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

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

these categories. 

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

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

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

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

Page2 

December 8, 2008 

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

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

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

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

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

recommendations with regard to the following issues. 

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

not be considered backsliding. 

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

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

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

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

determination? 

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

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

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

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

nonattainment areas where these CTG recommendations would be. implemented. 

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

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

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

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

You may contact me at 512-239-4696. 

Sincerely, 

?JJCcL 

psusana M. Hildebrand, P .E. 

Director, Air Quality Division 

Texas Commission on Environmental Quality 

SMH/LA/sy 

Enclosures: References 

Emission Limit Comparison Table 

cc: Mr. Guy Donaldson, EPA Region 6 

Ms. Ellen Belk, EPA Region 6 

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

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

~--~~~~~~~~~-. 
Mr. William T. Harnett 

Page 3 

December 8, 2008 

bee: Theresa Pella 

Ashley Forbes 

Vincent Meiller 

Lindley Anderson 

Amy Browning 
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 

Chapter 115 CTG Recommended 

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 

Chapter 115 CTG Recommended 

Coating Type* Emission Limit** 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. 
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

ORDER ADOPTING 

REVISIONS TO THE STATE IMPLEMENTATION PLAN 

Docket No. 2009-1127-SIP 

On March 10, 2010, the Texas Commission on Environmental Quality (Commission), during a public 

meeting, considered adoption of the Dallas-Fort Worth (DFW) Reasonably Available Control Technology 

(RACT) Update, 30 Texas Administrative Code (TAC) Chapter 117 Rule Revision Noninterference 

Demonstration, and Modified Failure-to-Attain Contingency Plan State Implementation Plan (SIP) Revision 

(DFW RACT, Rule, and Contingency SIP Revision). The Commission adopts this SIP revision demonstrating 

as required by the 1990 Federal Clean Air Act (FCAA) Amendments under§§ 172(c)(l), 182(b)(2) and 182(f), 

an updated RACT determination for the DFW area that documents the state's RACT analysis of 11 control 

technique guidelines (CTG) documents issued between 2006 and 2008 by the EPA. In addition to the RACT 

update, this SIP revision incorporates associated 30 TAC Chapter 115 and 30 TAC Chapter 117 rule revisions 

adopted concurrently into the Texas SIP, demonstrates noninterference of the Chapter 117 rule revision with the 

SIP, and includes a modified failure-to-attain contingency plan. 

Under Tex. Health & Safety Code Ann. §§ 382.011, 382.012, and 382.023 (Vernon 2008), the 

Commission has the authority to control the quality of the state's air and to issue orders consistent with the 

policies and purposes of the Texas Clean Air Act, Chapter 382 of the Tex. Health & Safety Code. Notice of the 

proposed SIP revision was published for comment in the October 9, 2009 issue of the Texas Register (34 

TexReg 7133). 

Pursuant to 40 Code of Federal Regulations § 51.102 and after proper notice, the Commission 

conducted public hearings to consider the revision to the SIP. Proper notice included prominent advertisement 

in the areas affected at least 30 days prior to the dates of the hearings. Public hearings were held in Austin, 

Texas on October 29, 2009 and in Fort Worth, Texas on November 2, 2009. 

The Commission circulated hearing notices of its intended action to the public, including interested 

persons, the Regional Administrator of the EPA, and all applicable local air pollution control agencies. The 

public was invited to submit data, views, and recommendations on the proposed SIP revision, either orally or in 

writing, at the hearings or during the comment period. Prior to the scheduled hearings, copies of the proposed 

SIP revision were available for public inspection at the Commission's central office and on the Commission's 

Web site. 

Data, views, and recommendations of interested persons regarding the proposed SIP revision were 

submitted to the Commission during the comment period, and were considered by the Commission as reflected 

in the analysis of testimony incorporated by reference to this Order. The Commission finds that the analysis of 

testimony includes the names of all interested groups or associations offering comment on the proposed SIP 

revision and their position concerning the same. 
IT IS THEREFORE ORDERED BY THE COMMISSION that the DFW RACT, Rule, and Contingency 

SIP Revision incorporated by reference to this Order is hereby adopted. The adopted revision to the SIP is 

incorporated by reference in this Order as if set forth at length verbatim in this Order. 

IT IS FURTHER ORDERED BY THE COMMISSION that on behalf of the Commission, the Chairman 

should transmit a copy of this Order, together with the adopted revision to the SIP, to the Regional 

Administrator of EPA as a proposed revision to the Texas SIP pursuant to the Federal Clean Air Act, codified at 

42 U.S. Code Ann.§§ 7401- 767lq, as amended. 

If any portion ofthis Order is for any reason held to be invalid by a court of competent jurisdiction, the 

invalidity of any portion shall not affect the validity of the remaining portions. 

Dateissued: MAR 1 5 2010 TEXAS COMMISSION ON 

ENVIRONMENTAL QUALITY