RACTSIP 2016-12.PDF

Maricopa County — Formal (2017-04-12)

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Analysis Of Reasonably Available Control Technology For
The 2008 8-Hour Ozone National Ambient Air Quality
Standard (NAAQS) State Implementation Plan
(RACT SIP)
December 5, 2016
___________________________________
Prepared By:
Maricopa County Air Quality Department
Planning & Analysis Division
1001 North Central Avenue, Suite #125
Phoenix, Arizona 85004
(602) 506-6010
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___________________________________________________________________________________
The Clean Air Act Amendments (CAAA) of 1990 gives States primary responsibility for achieving the
national ambient air quality standards (NAAQS). The NAAQS are established by the U.S. Environmental
Protection Agency (EPA) as the maximum concentrations of specific air contaminants allowed in the
atmosphere above which public health and welfare would not be protected.
The CAAA requires that States attain the NAAQS by specified dates based on the severity of an area’s
air quality problem. Maricopa County is designated as “moderate” nonattainment for the 2008 eight-hour
ozone NAAQS (86 FR 26697, May 4, 2016). As a “moderate” nonattainment area, Maricopa County is
required by the CAAA to attain the 2008 eight-hour ozone NAAQS by July 20, 2018.
The Maricopa Association of Governments (MAG) has prepared the MAG 2017 Eight-Hour Ozone
Moderate Area Plan to meet the requirements of Section 182(b) of the Clean Air Act. Per the MAG 2017
Eight-Hour Ozone Moderate Area Plan, “The new MAG 2017 Eight-Hour Ozone Moderate Area Plan
includes 93 existing and approved ozone control measures in the Maricopa nonattainment area from the
EPA approved regional air quality plans and separate EPA actions. The overall approach taken in the
plan is to demonstrate attainment with existing federal, state, and local ozone control measures. The
implementation of existing ozone control measures in the Maricopa eight-hour ozone nonattainment area
has already been effective in reducing ozone. These measures have allowed the area to attain and
maintain both the one-hour ozone standard and the 1997 eight-hour ozone standard of 0.08 parts per
million. The existing ozone control measures continue to have emission reduction benefits that provide for
the attainment of the 2008 ozone standard in the 2017 ozone season prior to the July 20, 2018 attainment
date. The emission reduction benefits of the existing measures also continue beyond the attainment year
of 2017, providing the emissions reductions needed in 2018 to satisfy the contingency measure
requirements of the Clean Air Act Section 172(c)(9).”
Within the Maricopa nonattainment area, the Maricopa County Air Quality Department (department) must
implement reasonably available control technology (RACT) for (1) sources that are subject to Control
Techniques Guidelines (CTGs) issued by the EPA, (2) major sources of volatile organic compounds
(VOCs) (ozone precursors), and (3) all major stationary sources of nitrogen oxides (NOx) (ozone
precursors) that are located in the area.
RACT is 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).
Control Techniques Guidelines (CTGs), issued by the EPA, are intended to provide States information
that should assist them in determining RACT for source categories. In developing CTGs, the EPA
evaluates sources of VOC emissions from source categories and the available control approaches for
addressing those emissions, including the costs of such approaches. Based on available information and
data, the EPA provides recommendations for determining RACT for the source categories. States can
use the recommendations in the CTGs to inform their own determination as to what constitutes RACT in
their particular areas. The guidance does not change or substitute for applicable sections of the CAAA or
the EPA’s regulation nor is it regulation. CTGs provide only recommendations for States to consider in
determining RACT. States are free to implement other technically-sound approaches that are consistent
with the CAAA and the EPA’s implementing regulations.
Source categories for VOCs for which the EPA has issued CTGs include: solvent metal cleaning,
perchloroethlene dry cleaning, large petroleum dry cleaning, metal furniture, magnet wire, large
appliances, paper, can coating, metal coils, fabrics, miscellaneous metal parts, industrial adhesives,
graphic arts, flexible package printing, cutback asphalt, wood furniture manufacturing, automobile and
light-duty trucks, flatwood paneling, aerospace Most Achievable Control Technology (MACT), aerospace
CTG & MACT, synthesized pharmaceutical products, gasoline bulk plants, fixed roof petroleum tanks,
external floating roof petroleum tanks, gasoline loading terminals, gasoline tank trucks and vapor
collection system leaks, service stations (Stage I vapor control systems), polymer manufacturing,
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synthetic organic chemical manufacturing industry (SOCMI) and polymer manufacturing equipment leaks,
miscellaneous refinery sources, leaks from petroleum refineries, rubber tire manufacturing, air oxidation
processes (SOCMI), equipment leaks from natural gas/gasoline processing plants, reactor processes and
distillation operations in SOCMI, surface coating at shipbuilding facilities, operations at shipbuilding
facilities, and fiberglass boat manufacturing.
Major sources of VOCs (ozone precursors) in Maricopa County are listed below. “Major sources” are
sources that emit or have the potential to emit 100 tons per year of VOC. The department requires such
sources to implement RACT via the VOC rules that implement RACT.
 Arlington Valley LLC
 Gila River Power Station
 Luke Air Force Base
 Mesquite Power Operations LLC
 New Harquahala Generating Company
 New Wincup Holdings Inc
 Oak Canyon Manufacturing Inc
 Redhawk Generating Facility
 Rexam Beverage Can Company
 SFPP PL Phoenix Terminal
 Trendwood Inc
Major stationary sources of NOx (ozone precursors) in Maricopa County are listed below. Major
stationary sources are sources that emit or have the potential to emit 100 tons per year of NOx. The
department requires such sources to implement RACT via the NOx rules that implement RACT.
 Arlington Valley LLC
 Gila River Power Station
 Luke Air Force Base
 Mesquite Power Operations LLC
 New Harquahala Generating Company
 Ocotillo Power Plant
 Redhawk Generating Facility
 Santan Generating Station
 SRP Kyrene Generating Station
As part of the Final Serious Area (1-Hour) Ozone State Implementation Plan For Maricopa County,
December 2000, Maricopa County implemented RACT in the following Maricopa County Air
Pollution Control Regulations:
 Rule 331: Solvent Cleaning
 Rule 333: Petroleum Solvent Dry Cleaning
 Rule 334: Rubber Sports Ball Manufacturing
 Rule 335: Architectural Coatings
 Rule 336: Surface Coating Operations
 Rule 337: Graphic Arts
 Rule 338: Semiconductor Manufacturing
 Rule 339: Vegetable Oil Extraction Processes
 Rule 340: Cutback & Emulsified Asphalt
 Rule 341: Metal Casting
 Rule 342: Coating Wood Furniture And Fixtures
 Rule 343: Commercial Bread Bakeries
 Rule 344: Automotive Windshield Washer Fluid
 Rule 346: Coating Wood Millwork
 Rule 347: Ferrous Sand Casting
 Rule 348: Aerospace Manufacturing And Rework Operations
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 Rule 349: Pharmaceutical, Cosmetic, And Vitamin Manufacturing Operations
 Rule 350: Storage Of Organic Liquids At Bulk Plants And Bulk Terminals
 Rule 351: Loading Of Organic Liquids
 Rule 352: Gasoline Delivery Vessel Testing And Use
 Rule 353: Gasoline In Stationary Dispensing Tanks
 Rule 358: Polystyrene Foam Operations
The rules implemented RACT to reduce VOC emissions (ozone precursors) but did not implement RACT
to reduce NOx emissions (ozone precursors). Maricopa County had determined that NOx reductions
would not contribute to attainment of the 1-hour ozone NAAQS. The EPA granted a waiver (NOx waiver)
from the Clean Air Act Section 182(f) requirements for NOx (60 FR 19510, April 19, 1995).
Because of the Maricopa nonattainment area, Maricopa County must ensure that the rules that
implemented RACT in 2000 continue to implement RACT and that the NOx rules implement RACT to
reduce NOx emissions (ozone precursors); the NOx waiver granted by the EPA no longer applies. In
addition, Maricopa County must ensure that the rules implement RACT for all major sources of VOC and
NOx.
In coordination with the EPA Region 9, the department conducted an analysis of CTG source
categories with the Maricopa County Air Pollution Control Regulations that implemented RACT in
2000. The analysis compared CTGs’ applicability thresholds and emissions limits with emissions limits in
the VOC rules listed above. If the rules were not consistent with the CTGs, the department determined
that the rule was not implementing RACT and therefore needed revision. See Appendices A and C. For
non-CTG source categories, the department compared the rule requirements applicable to such source
categories with relevant RACT guidance documents. See Appendix B.
Negative Declarations: In instances where either there were no sources in Maricopa County meeting a
CTG source category or where the number of sources or the amount of emissions were de minimis, the
department made a negative declaration regarding such CTG source category. See Appendix A.
The analysis showed that six (6) of the rules that implemented RACT in 2000 to reduce VOC
emissions (ozone precursors) were not consistent with the CTGs. The department revised the
following six (6) rules to implement RACT for VOCs:
 Rule 336: Surface Coating Operations
 Rule 342: Coating Wood Furniture And Fixtures
 Rule 350: Storage Of Organic Liquids At Bulk Plants And Bulk Terminals
 Rule 351: Loading Of Organic Liquids
 Rule 352: Gasoline Delivery Vessel Testing And Use
 Rule 353: Gasoline In Stationary Dispensing Tanks
The analysis also showed that three (3) rules needed to be revised to implement RACT to reduce
NOx emissions (ozone precursors). The department revised the following three (3) rules to implement
RACT to NOx:
 Rule 322: Power Plant Operations
 Rule 323: Fuel Burning Equipment From Industrial/Commercial/Institutional Sources
 Rule 324: Stationary Internal Combustion (IC) Engines
These rulemakings included twenty-one (21) stakeholder workshops and a 30-day comment period,
which began on May 13, 2016 with the publication of the Notices of Proposed Rulemaking in the Arizona
Administrative Register. A public hearing before the Maricopa County Board of Supervisors was
conducted on November 2, 2016, at which the Maricopa County Board of Supervisors approved the
revisions to the nine (9) rules.
This document (RACT SIP) will be submitted to the EPA (through the Arizona Department of
Environmental Quality (ADEQ)).
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__________________________________________________________________________________
CONCLUSION
Based on the analysis performed (described in this RACT SIP and in Appendices A, B, and C), the
department finds that it has fulfilled the requirements of RACT, as applicable to the 2008 eight-hour
ozone NAAQS for all CTG source categories and for all major sources of VOC and NOx.
____________________________________________________________________________________
APPENDICES
Appendix A: RACT Analysis Of CTG Source Categories
Appendix B: RACT Analysis Of Non-CTG Source Categories
Appendix C: CTG-RACT Spreadsheet
___________________________________________________________________________________
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Appendix A: RACT Analysis Of CTG Source Categories
Solvent Metal Cleaning
Rule 331 (Solvent Cleaning) limits VOC emissions from various cleaning operations.
There are two relevant CTG documents for Solvent Cleaning. The first document is “Control of Volatile
Organic Emissions from Solvent Metal Cleaning” (EPA-450/2-77-022) (“1977 CTG document”); the
second document is “Control Techniques Guidelines: Industrial Cleaning Solvents” (EPA-453/R-06-001)
(“2006 CTG document”).
Rule 331 was most recently revised on September 25, 2013 (to delete the definitions of “non-precursor
organic compounds” and “volatile organic compounds”) and the department determined that the rule
implements RACT; this was confirmed through the comparison of Rule 331 with the 1977 and the 2006
CTG documents. The work practices required in Rule 331, e.g., minimizing air circulation around cleaning
operations and properly disposing of VOC materials, correspond with the work practices discussed in the
1977 CTG document. The solvent handling requirements of the rule (Section 301) correspond with the
work practices discussed in Section V.A.1 of the 2006 CTG document. The solvent specification
requirement included in the rule (Section 304.1) exceeds the alternative composite vapor pressure limit
from Section V.A.3 of the 2006 CTG document. Finally, the minimum control efficiencies of the emission
control system included in the rule (Section 304.2 and Appendix IV.1) meet the control efficiencies
discussed in Section V.A.2 of the 2006 CTG document.
Can Coating, Fabrics, And Miscellaneous Metal Parts
Rule 336 (Surface Coating Operations) was revised on November 2, 2016. The purpose of Rule 336 is to
limit VOC emissions from various types of surface coating operations. Specific types of surface coating
operations addressed under Rule 336 include: Metal Parts and Products; Can and Coil Coating; Plastic
Parts and Products; Business Machine Coatings; Metal Furniture and Large Appliance Coatings; Paper,
Film, and Foil Surface Coating; and Pleasure Craft Surface Coating.
The department revised Rule 336 to incorporate five (5) CTGs:
 “Control Techniques Guidelines For Metal Furniture Coatings” (EPA-453/R-07-005)
 “Control Techniques Guidelines For Large Appliance Coatings” (EPA-453/R-07-004)
 “Control Techniques Guidelines For Miscellaneous Metal And Plastic Parts Coatings” (EPA-453/R-08-
003) (“2008 CTG document”)
 “Control Techniques Guidelines For Paper, Film, And Foil Coatings” (EPA-453/R-07-003)
 “Control Techniques Guidelines: Industrial Cleaning Solvents” (EPA-453/R-06-001)
The revisions in Rule 336 also include raising the required emission control system (ECS) control
efficiency to 90 percent (see Section 305.1); this revision meets the control efficiencies discussed in
Section VI.C of the 2008 CTG document. The revisions in Rule 336 also include required work practices
for handling, disposal, and storage of VOC-containing material (see Section 304) which are discussed in
Section VI.D of the 2008 CTG document.
Other revisions include amending the VOC emission limits for surface coatings consistent with the above
listed CTGs, deleting an exemption for the military, deleting the sprayless equipment exemption for vapor
pressure limits, adding new work practices, clarifying existing work practices, streamlining recordkeeping
provisions, and updating test methods. Review of the CTG requirements indicate that the revisions meet
(or exceed) the federal CTG requirements and can be considered RACT for control of VOCs from surface
coating operations.
Regarding pleasure craft surface coating, stakeholders commented that three pleasure craft VOC surface
coating limits: Extreme High Gloss Coatings, Finish Primer/Surfacer; and Other Substrate Anti-Foulant
Coating should be higher than the limits proposed in the CTG (Miscellaneous Metal and Plastic Parts
Coatings, September, 2008). Stakeholders challenged these CTG recommended limits to EPA in 2010.
EPA responded in a June 1, 2010 decision that clarified these suggested pleasure craft VOC surface
coating thresholds were RACT recommendations provided in the CTG and should be “used by the states
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to determine what constitutes RACT for VOC operations in their particular ozone nonattainment areas.”
The department reviewed both the stakeholders’ recommendation and the EPA’s decision and included
the following VOC limits in Rule 336, Table 336-7:
Extreme High Gloss Topcoat 600 g VOC/l
Finish Primer Surfacer; 600 g VOC/l
Other Substrate Anti-Foulant Coating 400 g VOC/l
Graphic Arts
The purpose of Rule 337 (Graphic Arts) is to limit VOC emissions from the use of inks, coatings,
adhesives, fountain solutions, and cleaning materials from graphic arts operations, including any digital,
screen, gravure, letterpress, flexographic, and lithographic printing process.
There are three relevant CTG documents for Graphic Arts. The first document is “Control of Volatile
Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts – Rotogravure and
Flexography” (EPA-450/2-78-033) (“1978 CTG document”); the second document is “Offset Lithography
Printing” (EPA-453/R-94-054) (“1994 CTG document”); the third document is “Offset Lithographic Printing
and Letterpress Printing” (EPA-453/R-06-002) (“2006 CTG document”).
Rule 337 was most recently revised on August 17, 2011 and the department has determined that the rule
implements RACT. This was confirmed through comparison of Rule 337 with the 2006 CTG document.
The maximum fountain solution VOC contents included in the rule (Section 302.2) correspond with the
fountain solution limits discussed in Section VI.B of the 2006 CTG document. The cleaning solution
requirements included in the rule (Section 302.3) correspond with the cleaning material recommendations
from Section VI.C of the 2006 CTG document. Finally, the minimum control efficiencies of the emission
control system included in the rule (Section 302.4) meet the control efficiencies discussed in Section VI.A
of the 2006 CTG document.
Wood Furniture Manufacturing
Rule 342 (Coating Wood Furniture and Fixtures) was revised on November 2, 2016. The purpose of Rule
342 is to limit the emissions of VOC from the surface preparation and coating of wood furniture and
fixtures. The provisions of Rule 342 apply to any facility in Maricopa County that applies a VOC
containing finishing material to furniture or fixtures made of wood or wood derived material. These wood
products fall into the Standard Industrial Classification (SIC) code of 2434, 2511, 2512, 2515, 2517, 2519,
2521, 2531, or 2541. Rule 342 provides simplified provisions for facilities which agree to a permit limit of
less than 10 tons (9.1 megagrams (Mg)) of VOC emissions per year and for sources emitting less than 2
tons (1.8 Mg) of VOC per year.
The relevant CTG for Rule 342 is “Control of Volatile Organic Compound Emissions from Wood Furniture
Manufacturing Operations” (EPA-453/R-96-007).
The rule revisions include adding leak detection and repair requirements, annual operator training
requirements, and associated recordkeeping requirements. The VOC content limits in Rule 342 met the
VOC content limits in the CTG; therefore, they were not changed.
Currently, there are 82 permits issued by Maricopa County Air Quality Department that include Rule 342
requirements. Three permits are Title V permits but not necessarily Title V for VOC emissions from wood
finishing only. Fifteen permits are general woodworking permits. Sixty-four permits are Non-Title V
permits; some may be “synthetic minor permits” meaning the facility has accepted an emissions limit
below the Title V threshold. Wood finishing may not be the primary process for the Non-Title V permits.
The wood furniture industry in Maricopa County is composed of a diverse mix of cabinet shops and
furniture companies, e.g., soft goods (sofas), case goods, spraying flatline, and knockdown or non-
knockdown.
During stakeholder workshops held in August 2015, December 2015, and February 2016, it was noted
that the climatic conditions in Maricopa County are different from other areas and product reformulations
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developed in these other locations may not be workable in Maricopa County. A particular example cited
was that South Coast Air Quality Management District (SCAQMD) Rule 1136 (Wood Products Coatings)
has more stringent VOC limits than the CTG; however, use of coatings compliant with these lower VOC
limits will adversely impact the final finish quality. The shops and manufacturers in Maricopa County do
not operate in temperature and humidity controlled environments. In the hot, dry climate of Maricopa
County, the shops and manufacturers use products that have a higher solids content, which slows-down
the evaporation rate of coatings and finishes. In addition, EPA Staff (Stanley Tong e-mail dated
November 19, 2015) have indicated that “…[the EPA] understands that high temperatures can cause the
solvent to flash off too fast before the resin can form a proper film. [The EPA] is open to evaluate this as a
reason for an alternative to the wood furniture CTG VOC limits, if [the department] can provide written
documentation from a few coating manufacturers that their wood furniture coatings will not work at the
temperatures typically found in the coating areas of [Maricopa County’s] wood furniture manufacturing
plant.”
A review was conducted by Eastern Research Group, Inc. (ERG) to compare industry stakeholders’
comments on what constitutes RACT for wood furniture coating operations as it relates to Rule 342. The
industry stakeholders provided substantial analysis and comments on the achievability of the current VOC
limits in Rule 342 and on the achievability of more stringent limits. The industry stakeholders’ comments
are summarized and addressed below. The effects of SCAQMD Rule 1136 on the wood furniture industry
in that District were frequently cited by the stakeholders as an example of what could happen in Maricopa
County under more stringent regulations.
The following table summarizes the VOC content limits from the CTG and Rule 342. Units are in kg
VOC/kg solids (grams VOC/liter*).
Coating Category CTG Rule 342
Low VOC topcoats that are part of a sealer/topcoat
0.8 0.8 (360)
system in which the sealer are not subject to a VOC limit
Clear Topcoats N/A N/A
Pigmented Topcoats N/A N/A
Sealers that are part of a sealer/topcoat system 1.9 1.9 (645)
Clear Sealers N/A N/A
Pigmented Primers, Sealers, & Undercoats N/A N/A
Topcoats that are part of a sealer/topcoat system 1.8 1.8 (635)
Strippable Booth Coating N/A 0.8 (360)
Affected sources using acid-cured alkyd amino vinyl sealers or acid-cured alkyd amino conversion
varnish topcoats:
Acid-cured alkyd amino vinyl sealers 2.3 2.3 (680)
Acid-cured alkyd amino conversion varnish topcoats 2.0 2.0 (655)
* Less water and less non-precursor/exempt solvents
The stakeholders recommended that the VOC limits in Rule 342 for woodworking finishing materials
should remain unchanged from the 1996 CTG.1 In addition, stakeholders offered information on the
current state of the wood furniture manufacturing industry in the United States in general, and the effect of
different factors on the health of their industry, including the effects of foreign competition and the effects
of regulation, in support of their recommendation.
The following sections summarize and offer an analysis of the issues raised by the stakeholders in the
materials they provided to the department.
The following table lists the industry stakeholders and their affiliation, who provided comments:
1 Support Documentation for the Maricopa County RACT Technical Feasibility Analysis. Prepared by Oak
Canyon Manufacturing, Inc. June 23, 2016.
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Commenter and Title Affiliation
Ty Lorts, President AF Lorts Manufacturing company, Inc.
David Darling, Senior Director, Environmental Affairs American Coatings Association
Tim Dombrowski, Owner/President Copperstate Cabinet Company, Inc.
Rick Schmidgall, President Legends Furniture, Inc.
Butch Beinborn, Environmental Manager Oak Canyon Manufacturing, Inc.
Leroy Zachek, President, and Windy Zachek, CEO OakCraft Elegant Cabinetry, Inc.
Laurel Jamison, President/CEI Rudd Company, Inc.
Brad Baldridge The Sherwin-Williams Company
Barry Cupp, Director of Product Compliance The Sherwin-Williams Company
Environmental, Health, Safety & Regulatory Affairs
Dana L. Scarlatta, Senior Chemist RPM Wood Finishes Group
Jason Rovig, General Manager Trendwood, Inc.
Climate Differences Between Maricopa County And South Coast
The stakeholders commented that standards that have been adopted in the SCAQMD have had an
adverse effect on the volume furniture industry in SCAQMD and are not applicable in Maricopa County,
because Maricopa County is substantially hotter and drier than South Coast particularly in the summer
time, and these climate differences exacerbate performance problems with low VOC coatings, especially
as they relate to drying and curing of the coatings.
The following tables summarize the yearly mean and the summer (June and July 2016) mean NOAA
meteorological data for Los Angeles, CA, and Phoenix, AZ (http://www.ncdc.noaa.gov/IPS/lcd/lcd.html).
Yearly Mean Los Angeles, CA Phoenix, AZ
Data Element
Mean Daily Maximum Temperature (°F) 70.1 85.9
Normal Relative Humidity (%) 72 36
Normal Annual Precipitation (Inches) 12.82 8.03
Summer (June and July 2016) Mean Los Angeles, CA Phoenix, AZ
Data Element
Mean Daily Maximum Temperature (°F) 75.3 107.9
Normal Relative Humidity (%) 58 13
Maricopa County summers are, on average, about 33°F warmer than South Coast during the warmest
part of the day and has only about one-fourth the humidity of South Coast.
The Hot Dry Climate Of Maricopa County Complicates Low VOC Coating Formulation And Use
The stakeholders described that surface coatings contain a blend of solvents that are characterized as
fast, medium, and slow evaporating solvents. The solvents are selected to control the flow of the coating
during application and drying, to dissolve the resin in the coating being applied, and to promote adhesion
between the different stages of the coating system (e.g., sealer, stain, and topcoat). (See letter from Dana
Scarlata, Senior Chemist, RPM Wood Finishes Group, to Butch Beinborn, Oak Canyon Manufacturing,
Inc. June 21, 2016.)
The stakeholders noted that the largest fraction of the solvent is the medium solvents, and these are often
targeted for reduction in low VOC coatings, increasing the fractions of fast and slow solvents. This is
particularly true if acetone is used as a non-VOC solvent in sealers and lacquers in place of MAK (methyl
n-amyl ketone, CAS No. 110-43-0) and EEP (ethyl 3-ethoxypropionate, CAS No. 763-69-9). The increase
in the fraction of fast solvents leads to application problems (e.g., dry spray and orange peel) that must be
countered through an increase in the amount of slow solvents. However, the increase in the amount of
slow solvents creates problems with the final curing of the finish such that it is not fully cured by the time
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the product must be packaged for shipping. The result, even after days of drying, is the products are
susceptible to “printing,” which is the deformation of the cured finish from contact with the packaging
when the product is wrapped and stacked for storage and shipping.
Oak Canyon Manufacturing has experienced this problem using coatings that are compliant with the
current VOC limits (see letter from Ryan Heard, Quality Assurance Manager, Aspenhome Furniture
Company, to Robert McMillan, President, Oak Canyon Manufacturing, Inc. August 20, 2015; and letter
from Brad Baldbridge, The Sherwin-Williams Company, to Butch Beinborn, Environmental Manager, Oak
Canyon Manufacturing, Inc., July 14, 2016).
Another problem with low-VOC coatings raised by stakeholders is “blushing”, in which fast evaporating
solvents cause the coated surface to cool, promoting the condensation of moisture and causing a white
appearance in what should be a clear finish. (See letter from Dana Scarlata, Senior Chemist, RPM Wood
Finishes Group, to Butch Beinborn, Oak Canyon Manufacturing, Inc. June 21, 2016.)
Other problems with low-VOC finishes in hot dry climates raised by stakeholders include “bubbling” of the
finish as solvents are trapped in the rapidly drying finish and cannot escape. (See letter and photos from
Tim Dombrowski, Copper State Cabinet Company, to Hether Krause, MCAQD, June 22, 2015).
Repair or replacement of products with defective finishes can represent a significant cost to facilities in
terms of direct costs and in damage to their reputation and loss of future business, as documented by the
stakeholders. One stakeholder reported that they invested significant resources (about $100,000) in
equipment and materials to investigate water-based products, but the results were “disastrous” when
used in the hot dry climate of the County. (See letter from Richard Schmidgall, Legends Furniture, to
Phillip McNeely, MCAQD, June 20, 2016.) Brad Baldbridge, a Sherwin Williams technical representative
who was assigned to Oak Canyon for 9 years, experienced these same types of problems during his time
at Oak Canyon. He reported that in some cases, the temperature inside the factory can exceed 100 °F.
He explained that periods of high temperature and high humidity combined with low VOC coatings
caused problems with bubbling, orange peel, blushing, lack of film build, and printing. He also reported
that these problems were compounded by the small footprint of the facility and the short dry time between
coating steps, and the need to box and ship products as they come off the manufacturing line. He also
noted that manufacturers of fully-assembled case good furniture like Oak Canyon cannot use the same
flat-line automated conveyor coating machines and UV-cured coatings that can be used by manufacturers
of kitchen cabinets and ready to assemble (RTA) furniture to comply with lower VOC emission limits.
It is likely that the problems stakeholders have observed so far will increase if coatings with even lower
VOC contents are used in Maricopa County. The defects described by the stakeholders are consistent
with defects described in standard texts on coatings technology.2 The mechanisms that cause the defects
observed by the stakeholders, such as rapid increases in surface tension in spray droplets and rapid
increases in the viscosity of applied surface films, could be exacerbated through the use of lower-
VOC/higher-solids coatings, or through the use of waterborne coatings. The use of water as a solvent in
coatings is complicated by the fact that water evaporates quickly from thin films, relative to many organic
solvents, and this characteristic is exacerbated in hot dry climates.
The stakeholders also stated that case good manufacturers cannot use UV-cured coatings used by
kitchen cabinet manufacturers because the pieces that are coated have to be able to lay flat on a
conveyor belt as they go through the coating process and the UV-curing oven. (See for example, R.C.
Peters, Selecting the best finishing system; getting started with the right products and materials. FDM
[Furniture Design and Manufacturing], December 2001. http://www.raymondnet.com/AGRCo-
Articles/Articles/FDM%201201B.pdf)
Impacts On The Wood Furniture Industry From Past Regulations
2 See, for example, Organic Coatings: Science and Technology, 2d Ed. Zeno W. Hicks, Jr., Frank N.
Jones, and S. Peter Pappas. 1999. Chapter 24, Film Defects.
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Stakeholders assert that past regulations, especially in the SCAQMD, have contributed to the dramatic
decline in the domestic wood furniture industry and a shift to production in lower-cost countries with fewer
regulations, particularly in China and Southeast Asia.
The stakeholders, particularly Oak Canyon Manufacturing, provides various California furniture company
testimonial information (See Support Documentation for the Maricopa County RACT Technical Feasibility
Analysis. Prepared by Oak Canyon Manufacturing, Inc. June 23, 2016. Table labeled “Furniture
Companies which left California or went Out of Business” following page # 6) that regulations have
caused a decline in domestic manufacturing and the loss of factories and jobs in the SCAQMD. They note
that the domestic share of the wood household furniture market (separate from the kitchen cabinet
market) has declined from 74 percent in 1997 to 18 percent in 2014.
The kitchen cabinet market, although subject to the same VOC limits as the wood household furniture
market, has not been affected as drastically as the household furniture market by the effect of imports.
The stakeholders stated that this is because cabinets are more often “custom” and “made to order” for
individual retail customers, rather than the “made to stock” or “made to inventory” approach used by wood
furniture manufacturers to meet orders from wholesalers, distributors, and retailers.
Wood Furniture Manufacturing Is A Small Percent Of The VOC Inventory
The stakeholders stated that wood furniture manufacturing is a tiny fraction (less than 0.3 percent) of the
total VOC inventory for Maricopa County, and thus further regulation of VOC content limits on wood
furniture coatings would have no measurable effect on ozone levels and the attainment status of the
County.
Wood manufacturing is not indicated as a source of NOx or CO emissions in either the point or area
source emission inventories of ozone precursors. The stakeholders also note that the County has made
considerable progress toward attainment of the ozone standard in the past decade under the current
regulations, with a steady reduction in the number of exceedance days under both the previous and
current ozone NAAQS.
The inventory of area sources lists wood furniture coatings as emitting 416.56 tpy of VOC (see Table 1.6-
8 of the 2011 Ozone Precursor Emissions Inventory). The point sources of VOC are listed in Table 2.4-1
of the 2011 Inventory, and include Oak Canyon Manufacturing Inc. (62.86 tpy of VOC) and Trendwood,
Inc. (128.59 tpy). The point and area sources together account for 608.01 tpy of VOC, which is still less
than 0.4 percent of all VOC sources, and about 0.8 percent of just the anthropogenic (non-biogenic) VOC
sources.
RACT Should Take Into Account Facility Specific Factors
The stakeholders, especially Oak Canyon Manufacturing, stated that the RACT determination should take
into account facility-specific factors. The stakeholders note, as mentioned earlier, the differences in
climate between Maricopa County, and other locations, which need to be taken into account in RACT
determinations. (See Support Documentation for the Maricopa County RACT Technical Feasibility
Analysis. Prepared by Oak Canyon Manufacturing, Inc. June 23, 2016. Relevant pages defining RACT as
“the lowest emission limitation that a Particular Source is capable of meeting” in a document named:
Federal Register Vol. 80 No. 44 following Page # 8)
The stakeholders also noted that differences among facilities should be taken into account in the RACT
determination, such as differences in operating practices that may affect the feasibility of certain
measures to reduce emissions. Oak Canyon Manufacturing, for example, cites the fact that they are a
“just in time” manufacturing facility with a small facility footprint. Therefore, they do not have the time nor
the space to allow for the extended drying and curing times that may be required for certain low-VOC
coatings.
The stakeholders also stated that more stringent limits that are being applied in SCAQMD are
considerably stricter than RACT and have therefore significantly reduced the number of volume wood
furniture manufacturing facilities in SCAQMD. That is, the stakeholders stated that remaining facilities in
11

SCAQMD are not representative of wood furniture manufacturing companies in the rest of the country
because all of the large production manufacturing facilities have left the SCAQMD. The stakeholders also
note that the EPA has not revised the wood furniture manufacturing CTG in response to more stringent
VOC limits in SCAQMD, and has previously declared that Rule 342 has no RACT deficiencies related to
the VOC limits.
The stakeholders stated that, given the problems that facilities in Maricopa County have already
experienced in complying with the VOC limits currently based on the CTG, the department should also
consider limits that are less stringent than the CTG as RACT. The stakeholders stated that this would be
consistent with the EPA’s statements that the CTG is guidance and that RACT should be determined on a
case-by-case basis. However, the stakeholders did not propose any specific limits that should be
considered as alternatives to those in effect or presented in the CTG.
Given the documentation provided by the stakeholders and coatings manufacturers (American Coatings
Association, RPM Wood Finishes Group, Rudd Company, Inc., Sherwin-Williams Co.), the EPA Staff
comments dated November 19, 2015, and the revisions made to Rule 342, which include additional work
practice standards for training and leak detection, the department has determined that the rule
implements RACT.
Gasoline Bulk Plants, Fixed Roof Petroleum Tanks, External Floating Roof Petroleum Tanks, And
Gasoline Loading Terminals
Rule 350 (Storage and Transfer of Organic Liquids (Non-Gasoline) at an Organic Liquid Distribution
Facility) was revised on November 2, 2016. The purpose of Rule 350 is to limit emissions of VOCs from
organic liquids (non-gasoline) under actual storage and transfer conditions at an organic liquid distribution
facility.
There are two relevant CTG documents for Rule 350. The first CTG document is “Control of Volatile
Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks” (EPA-450/2-77-036). The
second CTG document is “Control of Volatile Organic Emissions from Petroleum Liquid Storage in
External Floating Roof Tanks” (EPA-450/2-78-047).
Rule 351 (Storage and Loading of Gasoline at Bulk Gasoline Plants and Bulk Gasoline Terminals) was
revised on November 2, 2016. The purpose of Rule 351 is to limit emissions of VOCs emitted during the
storage and loading of gasoline at bulk gasoline plants and bulk gasoline terminals under actual storage
and loading conditions.
There are two relevant CTG documents for Rule 351. The first CTG document is “Control of
Hydrocarbons from Tank Truck Gasoline Loading Terminals” (EPA-450/2-77-026). The second CTG
document is “Control of Volatile Organic Emissions from Bulk Gasoline Plants” (EPA-450/2-77-035).
Rule revisions for Rule 350 and Rule 351 include the distinct separation of gasoline from the organic
liquids (non-gasoline) storage requirements. The rule revisions combine the gasoline storage
requirements from Rule 350 and the gasoline loading requirements from Rule 351 into Rule 351. The
department renamed both Rules 350 and 351 to reflect this structural revision.
The revisions also include addition of definitions and terms specific to the gasoline industry, deletion of
definitions and terms specific to the organic liquid (non-gasoline) industry, specification of regulatory
requirements for transferring organic liquid, addition of a monthly equipment leak inspection requirement,
and addition of optical gas imaging as an alternative work practice to monitor and identify leaking
equipment.
In order to meet current RACT, Rule 350 was revised to lower the rule applicability from organic liquids
with a true vapor pressure of 1.5 psia to organic liquids with a true vapor pressure of 0.5 psia. The rule
revisions also include additional definitions and terms specific to the organic liquid industry, delete
definitions and terms specific to the gasoline industry, specify regulatory requirements for transferring
12

organic liquid, add a monthly equipment leak inspection requirement, and add optical gas imaging as an
alternative work practice to monitor and identify leaking equipment.
In addition, in Rule 351 the department moved Section 403 (Performance Testing) to new Section 501.4
(Determining Vapor Tight Status-Gasoline Cargo Tank Loading Pressure) and changed the requirement
for recording pressure every one (1) minute while a gasoline cargo tank is being loaded during
performance testing to every five (5) minutes. The five (5) minute requirement is consistent with 40 CFR
Subpart XX, Section 60.503(d)(2). The department discussed the comment with stakeholders, Kinder
Morgan/SFPP, and the EPA and reviewed the federal requirements. Kinder Morgan/SFPP stated that the
back pressure is continuously monitored by the source test contractor while a gasoline truck is being
loaded during performance testing and that the instantaneous reading at the five (5)-minute mark and the
maximum instantaneous reading during the last five (5) minutes are recorded. The federal requirements
(40 CFR Subpart XX Section 60.503(d)(2)) state that during the performance test, the pressure shall be
recorded every five (5) minutes while a gasoline truck is being loaded and the highest instantaneous
pressure that occurs during each loading shall be recorded. After considering the comments, reviewing
the federal requirements, and reviewing the text in Rule 351, the department changed the requirement for
recording pressure every one (1) minute while a gasoline cargo tank is being loaded during performance
testing to every five (5) minutes to be consistent with the federal requirement in 40 CFR Subpart XX,
Section 60.503(d)(2). With this change, the department has determined that Rule 351 is no less stringent
than the SIP-approved rule.
Rules 350 and 351 are not new rules but include revisions that improve the clarity and enforceability of
the existing regulatory requirements for the organic liquid (non-gasoline) and gasoline industry. Review of
the CTG requirements indicate that the revisions meet (or exceed) the federal CTG requirements and can
be considered RACT for control of VOCs from storage and loading of gasoline at bulk gasoline and bulk
gasoline terminals.
Gasoline Tank Trucks And Vapor Collection System Leaks
Rule 352 (Gasoline Cargo Tank Testing and Use) was revised on November 2, 2016. The purpose of
Rule 352 is to limit the emission of VOCs from gasoline delivery vessels and applies to any gasoline
delivery vessel used to receive or deliver gasoline within Maricopa County. Rule 352 also applies to all
persons who own, operate, maintain, repair or test the delivery vessel.
The relevant CTG for Rule 352 is “Control of Volatile Organic Compound Leaks from Gasoline Tank
Trucks and Vapor Collection Systems” (EPA-450-2-78-051).
The rule revisions update the rule to use current industry language; update test methods; clarify the
loading requirements for bulk terminals, bulk plants and gasoline dispensing facilities; increase the
amount of notification time in advance of cargo tank testing; and add optical gas imaging as an alternative
work practice to monitor and identify leaking equipment.
The department previously found that Rule 352 met the RACT requirements. Since that time, RACT
requirements for gasoline cargo tank testing and use have not changed. Rule 352 continues to meet the
RACT requirements as applied to the gasoline tank trucks for vapor/leak tightness testing, monitoring,
local agency certification and decal requirements.
Gasoline Service Stations – Stage I
Rule 353 (Storage and Loading of Gasoline at Gasoline Dispensing Facilities) was revised on November
2, 2016. The purpose of Rule 353 is to limit VOC emissions from gasoline during storage and loading of
gasoline at gasoline dispensing facilities.
The relevant CTG for Rule 353 is “Design Criteria for Stage I Vapor Control Systems – Gasoline Service
Stations” (EPA-450/R-75-102).
The rule revisions make Rule 353 consistent with current gasoline industry terms and definitions; clarify
the storage and loading requirements of an underground storage tank and an above ground storage tank;
13

update test methods to be consistent with state and federal test methods; and clarify the inspection
requirement for gasoline dispensing facilities that receive gasoline less than once per week.
The department previously found that Rule 353 met the RACT requirements. Since that time, RACT
requirements for Stage I gasoline dispensing at service stations have not changed. The current revisions
included limited changes for consistency, clarifications, and updating of test methods. Rule 353 continues
to meet the RACT requirements for control of VOCs associated with Stage I loading of gasoline at
gasoline dispensing facilities.
For stationary gasoline dispensing tanks for farm operations, the department retained the exemption.
Based upon information provided by the Arizona Farm Bureau, annual gasoline throughput has been
estimated to be approximately 180,000 gallons per year (i.e., 150 250-gallon tanks with 100 gallons per
month throughput). A loading loss emission factor of 0.909 lbs VOC/1000 gallons was calculated using
the equation provided in Section 5.2.2.1.1 of AP-42. In addition, a breathing and emptying emission factor
of 1.0 lbs VOC/1000 gallons was obtained from Table 5.2-7 of AP-42. Combining these two emission
factors with the annual gasoline throughput of the agricultural tanks results in annual VOC emissions of
344 lbs/year (or 0.172 tons/year). These data are included in a spreadsheet dated July 3, 2016 named
“AST fuel estimates.xlsx”. The spreadsheet also includes emissions for displacement and spillage; these
are Stage II emission sources which are not covered under Rule 353. Also, the 2014 National Emissions
Inventory (NEI) emissions used for comparison only included Stage I emission sources. Therefore, the
displacement and spillage emissions were excluded from this analysis. For comparison purposes, the
Maricopa County gasoline station VOC emissions (i.e., total Stage I and tank breathing and emptying) are
1,781.6 tons in the 2014 National Emissions Inventory (NEI). Thus, the VOC emissions from the
agricultural gasoline tanks are less than 0.01 percent of the VOC emissions from gasoline stations.
Compared to the gasoline station (and overall inventory) VOC emissions, VOC emissions from the
agricultural gasoline tanks are negligible. The VOC emissions from the agricultural gasoline tanks are
0.0005% of the annual VOC emissions for all area sources in Maricopa County per the draft 2014
Periodic Emissions Inventory For Ozone Precursors.
Negative Declarations
The department has determined that there are no emitting facilities in the county for the following
CTG source categories. Thus, there is a negative declaration for these CTG source categories.
Source Category CTG Document Title Document
Number and Date
Automobiles and Light- Control of Volatile Organic Emissions from EPA-450/2-77-008
Duty Trucksa Existing Stationary Sources – Volume II: Surface (May 1977)
Coating of Cans, Coils, Paper, Fabrics,
Automobiles, and Light-Duty Trucks
Control Techniques Guidelines for Automobile and EPA-453/R-08-006
Light-Duty Truck Assembly Coatings (September 2008)
Cutback Asphalt Control of Volatile Organic Compounds from Use EPA-450/2-77-037
of Cutback Asphalt (December 1977)
Flat Wood Paneling Control of Volatile Organic Emissions from EPA-450/2-78-032
Existing Stationary Sources – Volume VII: Factory (June 1978)
Surface Coating of Flat Wood Paneling
Control Techniques Guidelines for Flat Wood EPA-453/R-06-004
Paneling Coatings (September 2006)
Flexible Packaging Printing Control Techniques Guidelines for Flexible EPA-453/R-06-003
Package Printing (September 2006)
Magnet Wire Insulation Control of Volatile Organic Emissions from EPA-450/2-77-033
Existing Stationary Sources – Volume IV: Surface (December 1977)
Coating of Insulation of Magnetic Wire
Natural Gas/Gasoline Control of Volatile Organic Compound Equipment EPA-450/3-83-007
14

Source Category CTG Document Title Document
Number and Date
Processing Plants Leaks from Natural Gas/Gasoline Processing (December 1983)
Plants
Control Techniques Guidelines for the Oil and EPA 453/B-16-001
Natural Gas Industry (October 2016)
Fiberglass Boat Control Techniques Guidelines for Fiberglass Boat EPA-453/R-08-004
Manufacturing Manufacturing Materials (September 2008)
Petroleum Refineries Control of Refinery Vacuum Producing Systems, EPA-450/2-77-025
Wastewater Separators and Process Unit (October 1977)
Turnarounds
Control of Volatile Organic Compound Leaks from EPA-450/2-78-036
Petroleum Refinery Equipment (June 1978)
Polymer Manufacturingb Control of Volatile Organic Compound Emissions EPA-450/3-83-008
from Manufacture of High-Density Polyethylene, (November 1983)
Polypropylene, and Polystyrene Resins
Control of Volatile Organic Compound Leaks from EPA-450/3-83-006
Synthetic Organic Chemical and Polymer (March 1984)
Manufacturing Equipment
Rubber Tire Manufacturing Control of Volatile Organic Emissions from EPA-450/2-78-030
Manufacture of Pneumatic Rubber Tires (December 1978)
Shipbuilding Alternative Control Techniques Document: EPA-453/R-94-032
Surface Coating Operations at Shipbuilding and (April 1994)
Ship Repair Facilities
Control Techniques Guidelines for Shipbuilding 61 FR-44050
and Ship Repair Operations (Surface Coating) (August 27, 1996)
Synthetic Organic Control of Volatile Organic Compound Emissions EPA-450/3-84-015
Chemical Manufacturing from Air Oxidation Processes in Synthetic Organic (December 1984)
Chemical Manufacturing Industry
Control of Volatile Organic Compound Emissions EPA-450/4-91-031
from Reactor Processes and Distillation (August 1993)
Operations Processes in the Synthetic Organic
Chemical Manufacturing Industry
aThe CTG documents for Automobile and Light-Duty Trucks only cover new automobiles/trucks and parts
on assembly lines; auto refinishing (i.e., body shops and collision repair) are not covered by a CTG. Rule
345 (Vehicle and Mobile Equipment Coating) applies to refinishing only.
bThe CTG documents for Polymer Manufacturing only cover the manufacture of the polymer resins;
product fabrication and formation are not covered by a CTG. Rule 358 (Polystyrene Foam Operations)
applies only to facilities that expand, age, or mold expandable polystyrene.
The department has also determined that there are no emitting facilities that exceed the CTG
applicability threshold in the county for the following CTG source categories. Thus, there is a
negative declaration for these CTG source categories.
Source Applicability CTG Document Title Document
Category Threshold Number and Date
Aerospace 25 tons/year National Emission Standards for 59 FR-29216
Hazardous Air Pollutants for (June 6, 1994)
Sources Categories: Aerospace
Manufacturing and Rework
25 tons/year Control of Volatile Organic EPA-453/R-97-004
Compound Emissions from Coating (December 1997)
Operations at Aerospace
Manufacturing and Rework
15

Source Applicability CTG Document Title Document
Category Threshold Number and Date
Operations
Industrial 15 lb/day or 3 Control Techniques Guidelines for EPA-453/R-08-005
Adhesives tons/rolling 12 month Miscellaneous Industrial Adhesives (September 2008)
Large None Control of Volatile Organic EPA-450/2-77-034
Appliancesa Emissions from Existing Stationary (December 1977)
Sources – Volume V: Surface
Coating of Large Appliances
15 lbs/day OR 3 Control Techniques Guidelines for EPA-453/R-07-004
tons/rolling 12 months Large Appliance Coatings (September 2007)
Large 123,000 liters (32,500 Control of Volatile Organic EPA-450/3-82-009
Petroleum Dry gallons) petroleum Compound Emissions from Large (September 1982)
Cleaners solvent/ year Petroleum Dry Cleaners
Metal Coilsa 15 lbs/day Control of Volatile Organic EPA-450/2-77-008
Emissions from Existing Stationary (May 1977)
Sources – Volume II: Surface
Coating of Cans, Coils, Paper,
Fabrics, Automobiles, and Light-
Duty Trucks
Metal Furniturea None Control of Volatile Organic EPA-450/2-77-032
Emissions from Existing Stationary (December 1977)
Sources – Volume III: Surface
Coating of Metal Furniture
15 lbs/day OR 3 Control Techniques Guidelines for EPA-453/R-07-005
tons/rolling 12 months Metal Furniture Coatings (September 2007)
Papera None Control of Volatile Organic EPA-450/2-77-008
Emissions from Existing Stationary (May 1977)
Sources – Volume II: Surface
Coating of Cans, Coils, Paper,
Fabrics, Automobiles, and Light-
Duty Trucks
15 lbs/day OR 3 Control Techniques Guidelines for EPA-453/R-07-003
tons/rolling 12 months Paper, Film, and Foil Coatings (September 2007)
actual; 25 tons/year
potential to emit per
coating line
Synthesized 15 lbs/day for each Control of Volatile Organic EPA-450/2-78-029
Pharmaceutical vent from reactors, Emissions from Manufacture of (December 1978)
Products distillation operations, Synthesized Pharmaceutical
crystallizers, Products
centrifuges, and
vacuum dryers
aAlthough there are no stationary sources or emitting facilities that exceed the CTG applicability threshold
for these CTG categories, the department revised Rule 336 (Surface Coating Operations), which is the
applicable rule for these categories.
In addition, the CTG for perchloroethylene dry cleaning systems is also not relevant due to the delisting of
perchloroethylene as a VOC effective March 8, 1996 (61 FR 4588; February 7, 1996).
16

Appendix B: RACT Analysis Of Non-CTG Source Categories
Electric Utility Boilers
Rule 322 (Power Plant Operations) was revised on November 2, 2016. The purpose of Rule 322 is to limit
the discharge of nitrogen oxides (NOx), sulfur oxides (SOx), particulate matter (PM) and carbon monoxide
(CO) emissions into the atmosphere from stationary fossil-fuel-fired equipment at electric utility stationary
gas turbines, electric utility steam generating units or cogeneration steam generating units.
The NOx limitation when burning gaseous fossil was changed from “155 ppm” to “42 ppmdv”. The EPA
advised the department that this limitation is considered RACT for NOx; this limitation is similar to limits in
Imperial County’s (CA) RACT SIP for the 1997 ozone standard for turbines (Rule 400.1 adopted 2010).
The NOx limitation when burning liquid fossil fuel was changed from “230 ppm” to “65 ppmdv”. The EPA
advised the department that this limitation is considered RACT for NOx; this limitation is similar to limits in
Imperial County’s (CA) RACT SIP for the 1997 ozone standard for turbines (Rule 400.1 adopted 2010).
In addition, the revisions to Rule 322 remove the exemption of equipment for which construction
commenced after May 10, 1996. Rule 322 applies to all equipment listed in Section 102, regardless of
when it was constructed. Moreover, Rule 322 includes new Section 102.4, a provision that states that
facilities subject to Rule 322 may be subject to New Source Performance Standards (NSPS) and/or
National Emission Standards for Hazardous Air Pollutants (NESHAP).
Understanding that this rule applies to many different types of units, operated differently, the department
revised the rule to allow affected sources to submit a case-by-case RACT analysis for NOx.
At the department’s request, a review was conducted by Eastern Research Group, Inc. (ERG) of the RTP
Environmental Associates, Inc. document entitled “Reasonably Available Control Technology Evaluation
For Natural Gas Fired Power Plants for Proposed Revisions to Rule 322” (the “RTP Report”), which was
submitted to the Maricopa County Air Quality Department (department) by Arizona Public Service (APS)
and Salt River Project (SRP) in March of 2016.
The RTP Report was a preliminary assessment and RACT analysis related to five power plants. It was
intended to inform the department on the potential options available for regulated equipment to meet the
new RACT standards and on the RACT process including cost effectiveness of various control options.
The RTP Report used the best information available to characterize actual NOx emissions for the
equipment subject to Rule 322. Most of these units were first put in service duirng the 1970s, and for
some of them no site specific performance test data or manufacturers guarantee is available. The table
below lists the emission/emission factor source cited by the RTP Report for the baseline actual emissions
estimates for each unit.
Owner/Operator Facility Subject Units Emission Permit NOx Limit
Data Source
APS West Phoenix 2 CC Turbines August 2015 NOx 155 ppmv
Power Plant 85 MW each Stack Test
2 SC Turbines AP-42 Chapter 3.1 155 ppmv
55 MW each Stationary Gas
Turbinesa
APS Ocotillo Power 2 SC Turbines AP-42 Chapter 3.1 
Plant 55 MW each Stationary Gas
Turbinesa
2 Gas Fired 2014 CEMS Data 
Boilers Reported To
110 MW each CAMD
SRP Santan Generating 4 CC Turbines Annual Average 155 ppmv
Station 90 MW each CEMS Data
17

Owner/Operator Facility Subject Units Emission Permit NOx Limit
Data Source
SRP Agua Fria 3 SC Turbines AP-42 Chapter 3.1 
Generating Station 90 MW each Stationary Gas
Turbinesa
2 Gas Fired 2014 CEMS Data 
Boilers Reported To
114 MW each CAMD
1 Gas Fired Boiler Annual Average 
163 MW CEMS Data
SRP Kyrene Generating 3 SC Turbines AP-42 Chapter 3.1 b
Station 53.1, 60, 60 MW Stationary Gas
Turbinesa
2 Gas Fired No CEMS Data 
Boilers Used The Same
34.5 And 73.5 MW Emission Rate As
Agua Fria
Footnotes:
(a) AP-42, Chapter 3.1, Stationary Gas Turbines, Table 3.1-1 (Uncontrolled NOx For Natural Gas Fired
Turbine)
(b) The air permit includes a NOx emission factor for each of these three (3) turbines of 336 lb/MMscf.
The permit also limits plant-wide annual NOx emissions to 158 tons.
ERG’s review included the consideration of the available technologies, technical feasibility, and
control effectiveness presented in the RACT analysis. The review has been conducted in accordance with
state and federal rules and the conventional “Top-Down” process. The steps required for conducting a
top-down analysis are: (1) identify all potentially available control options, (2) eliminate technically
infeasible control options, (3) rank remaining control technologies by control effectiveness, (4) evaluate
the most effective controls and document the results as necessary, and (5) select RACT.
The RTP Report is a preliminary assessment setting forth potential options available for select regulated
equipment to meet the new RACT standards. Submittal of the RTP Report does not require the affected
source to utilize the conclusions or case-by-case RACT determination set forth in the RTP Report. ERG
substantiated the conclusions in the RTP Report.
Cost Effective Technologies Discussion
In a 1994 memorandum to Regional Directors, the EPA provides guidance on determining NOx RACT,
noting specifically that cost effectiveness of NOx technologies should cost less than $1,300 per ton of NOx
removed. Escalated to 2015, using the Consumer Price Index (CPI) data from the U.S. Bureau of Labor
Statistics, the cost effectiveness threshold will be $2,067 per ton of NOx removed. For this analysis a
rounded-up threshold of $2,100 per ton of NOx removed was used. Costs above the $2,100 per ton were
considered in the RTP Report to be cost prohibitive. ERG reviewed the methodology that resulted in this
threshold and agreed that $2,100 per ton is an appropriate threshold.
The RTP Report calculated all control costs using the methodology described in Section 6, Chapter 1 of
the “EPA Air Pollution Control Cost Manual, Sixth Edition” (EPA 452-02-001). Direct capital costs were
based on the:
1. EPA’s Alternative Control Techniques (ATC) Document - NOx Emissions from Stationary Gas
Turbines (EPA-453/R-93-007);
2. Cost Analysis of NOx Control Alternatives for Stationary Gas Turbines which was prepared for the
U.S. Department of Energy;
3. 2011 Sargent & Lundy LLC – Santan Emissions Assessment Report;
4. EPA’s ATC document NOx Emissions from Utility Boilers (EPA-453/R-94-023);
5. EPA’s ATC document NOx Emissions from Industrial/Commercial/Institutional Boilers (ICI) (EPA-
453/R-94-022); and
6. EPA’s OAQPS Control Cost Manual (EPA-452/B-02-001).
18

Total capital investment costs for each affected unit were annualized based on an interest rate of 7
percent and an equipment life of 20 years.
RACT Findings
The table below presents the RACT findings, which are estimates only and are not to be used to establish
regulatory thresholds or permitting limits. For purposes of RACT, no additional controls would be required
for the affected units if they operate less than the hours of operation indicated in the table from the RTP
Report. All calculations were verified by ERG.
The cost effectiveness for all of the affected units at all of the facilities, when operated below the hours
per year indicated in the table below, exceed the EPA guidance for RACT cost effectiveness of
$2,100/ton. It should be noted that APS and SRP have indicated that recordkeeping associated with the
limited use restrictions would not increase costs for the units subject to Rule 322, because their current
Title V permits already include similar requirements.
Owner/Operator Facility Affected Operation Good Estimated
Units Hrs/Yr Combustion Emissions
Practices In Tons/Yr
The Permit If Affected
Source
Accepts
Hrs/Yr
Restrictions
APS West Phoenix 2 CC Turbines 3,500 Yes 401b
Power Plant 85 MW each
2 SC Turbines 2,000 Yes 293b
55 MW each
APS Ocotillo Power 2 SC Turbines 2,000 Yes 293b
Plant 55 MW each
2 Gas Fired 8,000 Yes 702b
Boilers
110 MW each
SRP Santan 4 CC Turbines 8,000 Yes 262b
Generating 90 MW each
Station
SRP Agua Fria 3 SC Turbines 2,400 Yes 434b
Generating 90 MW eachc
Stationa 2 Gas Fired 8,000 Yes 1,253b
Boilers
114 MW each
1 Gas Fired 6,000 Yes 1,995
Boiler
163 MW
SRP Kyrene 1 SC Turbine 2,000 No 283
Generating 53.1 MW
Station 2 SC Turbines 3,000 No 331b
60 MW each
1 Gas Fired 8,000 No 379
Boiler
34.5 MW
1 Gas Fired 8,000 No 808
Boiler
73.5 MW
Total 6 CC 1,852
19

Owner/Operator Facility Affected Operation Good Estimated
Units Hrs/Yr Combustion Emissions
Practices In Tons/Yr
The Permit If Affected
Source
Accepts
Hrs/Yr
Restrictions
Turbines 
10 SC 3,377
Turbines
7 Gas Fired 7,092
Boilers
Footnotes:
(a) During normal operations, these units combust natural gas only with some having the capacity to burn
fuel oil as back-up. NOx emissions from only natural gas combustion is evaluated for purposes of
establishing RACT.
(b) Emission totals are for each RACT unit.
(c) Two of the turbines are 85 MW. The applicant conservatively assumed all three to be the same size.
Given the documentation provided by the stakeholders and the revisions made to Rule 322, which include
changing the NOx limitations, changing the applicability to apply to all equipment listed in Section 102
regardless of when the equipment was constructed, clarifying the good combustion practices for turbines
and the operation and maintenance plan requirements, the department has determined that the rule
implements RACT.
Boilers Used In Industrial Facilities, Process Heaters, And Stationary Gas Turbines
Rule 323 (Fuel Burning Equipment From Industrial/Commercial/Institutional (ICI) Sources) was revised on
November 2, 2016. The purpose of Rule 323 is to limit the discharge of nitrogen oxides (NOx), sulfur
oxides (SOx), particulate matter (PM), and carbon monoxide (CO) emissions into the atmosphere from
fuel burning combustion equipment at industrial, commercial, and institutional (ICI) sources.
The NOx limitation when burning gaseous fossil fuel was changed from “155 ppm” to “42 ppmdv”. The
EPA advised the department that this limitation is considered RACT for NOx; this limitation is similar to
limits in Imperial County’s (CA) RACT SIP for the 1997 ozone standard for turbines (Rule 400.1 adopted
2010).
The NOx limitation when burning liquid fossil fuel was changed from “230 ppm” to “65 ppmdv”. The EPA
advised the department that this limitation is considered RACT for NOx; this limitation is similar to limits in
Imperial County’s (CA) RACT SIP for the 1997 ozone standard for turbines (Rule 400.1 adopted 2010).
The revisions also include clarifications regarding exemptions and limitations, e.g., add the definition of
“steady state” and revise the definition of “waste derived fuel gas”. In addition, the revisions also include
changes associated with various administrative requirements and compliance determinations. Given the
revisions made to Rule 323, the department has determined that the rule implements RACT.
Stationary Reciprocating Internal Combustion (IC) Engines
Rule 324 (Stationary Internal Combustion (IC) Engines) was revised on November 2, 2016. The purpose
of Rule 324 is to limit the discharge of carbon monoxide (CO), nitrogen oxides (NOx), sulfur oxides (SOx),
volatile organic compounds (VOCs), and particulate matter (PM) emissions from stationary reciprocating
internal combustion engines (RICE).
The requirements in Rule 324 harmonize with New Source Performance Standards (NSPS) IIII, and JJJJ,
and Most Achievable Control Technology (MACT) ZZZZ. The definitions of “existing engine” and “new
engine” were deleted from Rule 324; the terms are not used in the rule. Rule 324 refers to the dates
before and after which NSPS were promulgated. Rule 324 applies to spark-ignition engines and
20

compression-ignition engines with a rated brake horsepower of greater than 250 and to any stationary
reciprocating internal combustion engine subject to the federal standards of performance set forth in 40
CFR 60, Subpart IIII for compression-ignition engines or 40 CFR 60, Subpart JJJJ for spark-ignition
engines.
Rule 324 clarifies the two options that non-emergency engines have for complying with Rule 324. A
source can comply with the current emission limitations or the federal standards of performance for non-
emergency engines. The current emission limits in Rule 324 have been retained; such limits apply to:
 Engines manufactured prior to October 22, 2003 (the date when Rule 324 was adopted)
 Engines manufactured on or after October 22, 2003 but prior to July 11, 2005 (the date the New
Source Performance Standards were adopted for compression-ignition engines)
 Engines manufactured on or after October 22, 2003 but prior to June 12, 2006 (the date the New
Source Performance Standards were adopted for spark-ignition engines).
Rule revisions include a requirement that spark-ignition engines manufactured after June 12, 2006 and
compression-ignition engines manufactured after July 11, 2005 comply with federal standards of
performance. Rule revisions also include clarifications regarding applicability, limitations, exemptions,
definitions, and changes associated with various administrative requirements and compliance
determinations.
A review was conducted by Eastern Research Group, Inc. (ERG) to compare the emissions limits in Rule
324 to other similar rules in other similar jurisdictions, as well as national standards and data sources.
ERG reviewed and compared State Implementation Plan (SIP) rules for IC engines in several areas of
California to the NSPS Subparts IIII and JJJJ limits incorporated under revised Rule 324. Specifically, IC
engine rules for these areas were reviewed: Placer County Air Pollution Control District, Sacramento
Metropolitan Air Quality Management District, Ventura County Air Pollution Control District, and South
Coast Air Quality Management District. In addition, ERG searched the RACT/BACT/LAER Clearinghouse
(RBLC) to locate applicable control technologies. ERG’s search of the RBLC specified processes in the
Internal Combustion Engines categories, including Large Internal Combustion Engines greater than 500
horsepower (hp) (all fuel types) and Small Internal Combustion Engines less than 500 hp (all fuel types),
with permits dating back to 2000. The search results included the following data fields: RBLC ID, facility
name and state, permit date, process name, throughput, pollutant, control technology, and percent
efficiency of control. Based on searches conducted for facilities in the IC engine category, ERG found 283
recent RACT, BACT, and LAER decisions for CO, NOx, and VOC emissions that had sufficient
information to be included in this analysis. While the initial RBLC query returned thousands of records,
RBLC records were only used if the engine size could be determined and if the emission limits were in
units of (g/HP-hr). The majority of the RBLC determinations represent PSD-BACT determinations and
some represent LAER determinations.
The engine rules in NSPS Subparts IIII and JJJJ are complex and provide numerous subcategories of
engines subject to different emission limits. However, the NSPS rules are generally consistent with both
the California SIP rules and recent RBLC determinations, with the exception of the SIP rules for the Los
Angeles nonattainment area. The Los Angeles area of California has been classified as being in serious,
severe, and extreme nonattainment with the 2008 8-hour ozone standard. Therefore, because these
areas have worse nonattainment classifications as compared to Maricopa County, it is expected that their
IC engine limits would be more restrictive than for a moderate nonattainment area such as Maricopa
County.
The RBLC results represent 283 records that had sufficient information to be useful for comparison. Of
the 283 records evaluated, 10 were for smaller compression-ignition engines (less than 250 hp). The NOx
and CO limits for these smaller engines are lower than the corresponding NSPS Subpart IIII limits for
larger engines (greater than 250 hp), while the VOC limits are higher. For the larger engines, the NSPS
limits fell within the range of the RBLC limits for most pollutants and engine types, the only exception
being VOC limits for spark-ignition engines manufactured between July 1, 2008 and January 1, 2011. A
comparison of the emission limits in revised Rule 324 and NSPS Subparts IIII and JJJJ with the range of
limits found in RBLC and the California SIP rules shows that the emission limits in revised Rule 324 are
21

within the range of values found in the RBLC and as required under the California SIP rules. Given the
revisions made to Rule 324, the department has determined that the rule implements RACT.
22

Appendix C: CTG RACT Spreadsheet
#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
Rule 200
requires a
permit if
unheated,
non-
(a) In
conveyori
urban
zed
nonattain
solvent
ment
cleaning
areas,
or coating
open top
equipment
vapor
, without
degrease
control
rs with an
enclosure,
open 1. Work
has: (a)
area of Practices:
An open
less than closed
surface
1 m2 containers
area of >1
from , Rule 331
Control m2 (10.8
equipme minimizing meets
of ft2),
nt air the
Volatile internal
8 standard No size circulation requirem
EP Organic volume of
Co s (Ref. cutoffs around ents in
A- Emission >350 l
des 080101, 12,p. 7-4) from cleaning CTG
450 s from (92.5 gal),
: 080102, and operati operations EPA-
/2- Solvent and uses 122
25, 080103 conveyori onal , proper 453/R-
77- Metal more than Minor,
33- zed standar disposal 06-001.
022 Cleaning 3 gal/day 56
39 degrease ds of VOC Rule 200 2006
Solvent (PDF of organic Gener Rule
rs with materials, 04/21 3 lbs of CTG, so
Metal 229 pp, solvent. al, 13 331
less than implement 331 / 266 VOC/day Rule 331
Cleanin 7.0MB) (b) Uses Title V meets
2.0 m2 of ing 2004 permit meets
g organic (all RACT
air/vapor practices requirem RACT
solvents minor
Interface that ents
with for
from minimize exceeds
boiling VOC)
requirem emissions the
point
ent of a CTG's
<302°F
major cutoff of
(150°C)
control 15 lb/day
with
device of VOC
solvent
(e.g., emission
loss >3
carbon s
gal/day.
adsorber)
(c) Uses
(Ref. 12,
materials
p.3-34).
with VOC
content
>2% by
volume
(20 cc/l).
(b) In Volatilit Control 2. VOC Rule 200
rural y of Techniqu Content in general
nonattain solvent EP es Limit: 50 also
ment is used A- Guidelin g/l (0.42 requires a
areas, all to 453 es for lb/gal) of permit for
cold require /R- Industrial VOC any
cleaners greater 06- Cleaning content in source
can be control 001 Solvents cleaning emitting
exempte in cold (PDF material, more than
d and cleaner 290 pp, unless 3 lbs
23

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
liters Cleaners Negative
(32,500 (PDF Declarati
gallons) 174 pp, on
of 5.0MB)
petroleu
m solvent
annually
(Ref. 31
p. 4-2).
Rule 200
Control
requires a
of
permit if
Volatile
sources
Organic
25 uses more
Emission Rule 336
14, than one
s from exceeds
25 gallon per
Existing the
22, day of
EP Stationar requirem
25 coating
A- y ents in
31, material.
450 Sources EPA- CTG Negative
25 080410 Rule 200
/2- – 453/R-07- EPA- Declarati
42, in general No
77- Volume 005 453/R- on,
25 also source
15 lb/day 032 III: regulates 007-005. though
99, requires a s
or 3 Surface air-dried 2 Rule 200 Rule 336
34 permit for exceed
Metal tons/rollin Coating metal 04/07 Minor, - 3 lbs of should
29, any the
Furnitur g 12 of Metal furniture 336 / 164 2 VOC/day be
34 source CTG
e month - Furniture coatings 1999 Gener permit updated
69, emitting applica
2007 (PDF 66 to al requirem to latest
34 more than bility
CTG pp, between ents CTG
95, 3 lbs thresho
1.9MB) 3.3 and exceeds RACT.
36 VOC/day. ld
6.7 gal of the No
45, Control
solids. CTG's Sources
36 Techniqu Rule 336
cutoff of
46, es regulates
EP 15 lb/day
38 Guidelin metal
A of VOC
21, es for furniture
453 emission
38 Metal coatings
/R- s.
43 Furniture to 3.0
07-
Coatings lbs/gal of
005
(PDF VOC
100 pp, content.
293KB)
Control Rule 336
of does not
Volatile mention
Organic magnet Negative
Emission wire. The Declarati
CTG
s from other on,
recommen Rule 336
Existing metal though
EP ds either does not
Stationar parts Rule 336
15 A- 90% meet the
y 04/07 section No should
Magnet lb/day; 450 efficient CTG for
080405 Sources 336 / gives 164 0 source be
Wire no yearly /2- ECS or magnet
– 1999 limits of s updated
threshold 77- coating of wire;
Volume 3.5 lbs/gal to latest
033 1.7 lbs/gal update
IV: of air dried CTG
of VOC Rule 336
Surface and 3.0 RACT.
content
Coating lbs/gal for No
of baked Sources
Insulatio VOC
n of content.
Magnet ECS are
26

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
Wire required
(PDF 44 to meet
pp, 85%
1.1MB) efficiency.
Rule 200
Control
requires a
of
permit if
Volatile
sources
Organic
uses more
Emission
Quick than one
s from
drying gallon per
Existing
lacquer day of
EP Stationar
s used coating
A- y
to material.
36 450 Sources 1
080404 repair EPA- Rule 200 Negative
31, /2- – minor
scratch 453/R-07- in general Declarati
36 77- Volume Rule 336 No
es and 004 also on,
32, 034 V: does not source
15 lb/day nicks regulates requires a though
36 Surface meet the s
or 3 that air-dried permit for Rule 336
33, Coating CTG for exceed
Large tons/rollin occur metal 04/07 any should
36 of Large large the
Applian g 12 during furniture 336 / source 164 be
39, Applianc applianc CTG
ces month - assem coatings 1999 emitting updated
35 es (PDF e applica
2007 bly are to more than to latest
82, 70 pp, coating; bility
CTG exempt between 3 lbs CTG
35 2.1MB) update thresho
from 2.3 and VOC/day. RACT.
85, Rule 336 ld
meetin Control 3.5 lbs/gal No
35
g any Techniqu of VOC. Sources
89 Rule 336
emissio es
regulates
n limits EP Guidelin
metal
(Ref. A es for
furniture
18, p. 453 Large
coatings
1-2). /R- Applianc
to 2.8
07- e
lbs/gal of
004 Coatings
VOC
(PDF 44
content.
pp,
374KB)
Control 1. Provide Rule 200
of a 90% requires a
15 lb/day Volatile control of permit if
or 3 Organic VOC sources
Negative
tons/rollin Emission emissions uses more
Declarati
g 12 s from or than one No
on,
month - Existing 2. 0.20 kg gallon per source
though
2007 EP Stationar VOC/kg day of s
2 Different Rule 336
CTG A- y (0.20 lb coating exceed
04/07 Minor, system should
actual 450 Sources VOC/lb) material. the
Paper 080403 336 / 164 1 of VOC be
emission /2- – solids for Rule 200 CTG
1999 Gener calculati updated
s or 25 77- Volume pressure in general applica
al on. to latest
tpy 008 II: sensitive also bility
CTG
potential Surface tape and requires a thresho
RACT.
to emit Coating label permit for ld
No
per of Cans, printing any
Sources
coating Coils, and 0.067 source
line Paper, kg emitting
Fabrics, VOC/kg more than
Automob (0.40 lb 3 lbs
27

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
iles, and VOC/lb) VOC/day.
Light- solids for
Duty paper,
Trucks film, and
(PDF foil.
232 pp,
2.7MB)
Control
Techniqu Rule 336
es regulates
EP Guidelin paper
A es for coating,
453 Paper, including
/R- Film, and adhesives
07- Foil , to 2.9
003 Coatings lbs/gal of
(PDF VOC
102 pp, content.
488KB)
Control
of
Volatile
Organic
Emission
s from CTG is
Existing from
Stationar 1977 so
EPA-
y cannot
450/2-77- Rule 336
Sources 1 Major be
008 limits limits VOC
– Minor, source assumed
EP VOC content of
Volume 1 exceed to meet
15 A- content of can
II: 04/07 Gener Rule 336 s the RACT.
Can lb/day; 450 can coating to
080407 Surface 336 / 164 al, 1 matches CTG Also,
Coating no yearly /2- coating to between
Coating 1999 Title V the CTG applica there is a
threshold 77- between 2.5 and
of Cans, (Major bility major
008 2.5 and 5.5 lbs/gal
Coils, for thresho VOC
5.5 lbs/gal (2.8 for
Paper, VOC) ld souce in
(2.8 for basecoat)
Fabrics, this
basecoat)
Automob category.
iles, and Update
Light- Rule 336.
Duty
Trucks
(PDF
232 pp,
2.7MB)
Control EPA-
Negative
of 450/2-77-
Declarati
Volatile 008 limits No
on,
Organic VOC source
Rule 336 though
EP Emission content of s
limits VOC Rule 336
15 A- s from can exceed
04/07 content of Rule 336 should
Metal lb/day; 450 Existing coating to 2 the
080408 336 / coil 164 matches be
Coils no yearly /2- Stationar 2.6 lbs/gal Minor CTG
1999 coating to the CTG updated
threshold 77- y for prime applica
2.6 lbs/gal to latest
008 Sources and bility
(any coat). CTG
– topcoat or thresho
RACT.
Volume single ld
No
II: coat
Sources
Surface operation.
28

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
Coating
of Cans,
Coils,
Paper,
Fabrics,
Automob
iles, and
Light-
Duty
Trucks
(PDF
232 pp,
2.7MB)
Control
of
Volatile
Organic
Emission
s from CTG is
Existing from
EPA-
Stationar 1977 so
450/2-77-
y cannot
008 limits 2 minor
Sources be
VOC source
– Rule 336 assumed
EP content of s
Volume limits VOC to meet
15 A- fabric exceed
II: 04/07 content of Rule 336 RACT.
lb/day; 450 coating to 4 the
Fabrics 080402 Surface 336 / fabric 164 matches Also,
no yearly /2- 2.9 Minor CTG
Coating 1999 coating to the CTG there is a
threshold 77- lbs/gal. applica
of Cans, 2.9 major
008 Vinyl bility
Coils, lbs/gal. VOC
coating is thresho
Paper, souce in
limited to ld
Fabrics, this
3.8
Automob category.
lbs/gal.
iles, and Update
Light- Rule 336.
Duty
Trucks
(PDF
232 pp,
2.7MB)
· This Control
regulati of There
35
on is Volatile are 12
72,
not Organic minor
35
intende Emission source
73,
d to s from Rule 336 s and 4
35
cover Existing does not general
74, 15 lb/day
surface EP Stationar meet the source
36 or 2.7 64
Miscell coating A- y CTG for s that
61, tons/rollin 04/07 minor,
aneous of the 450 Sources miscella exceed Update
35 080415 g 12 336 / 164 36
Metal followin /2- – neous the Rule 336
79, month - 1999 gener
Parts g metal 78- Volume metal annual
38 2007 al
parts 015 VI: parts; emissio
61, CTG
and Surface update ns
am
product Coating Rule 336 CTG
on
s: (1) of applica
g
automo Miscella bility
oth
bile neous thresho
ers
and Metal ld
light- Parts
29

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
Rule 342
limits VOC
Control content to
EPA- 2
of between
453/R-96- minor,
Volatile 1.8 and
007 limits 50 1
Organic 2.3 lbs
VOX Minor, general
Compou VOC/lbs
content to 3 , and 2 CTG and
EP nd solids.
Wood between Gener major Rule 342
A- Emission There are
Furnitur 25 tpy; 1.9 and 11/20 al, 2 Rule 342 source are both
453 s from options for
e 080409 no daily 2.0 lb 342 / 68 Title V matches s from
/R- Wood lower
Manufa threshold VOC/lb 1996 (4 of CTG exceed 1996;
96- Furniture VOC
cturing solids. these the update
007 Manufact topcoat
Has major CTG Rule 342
uring and
option for for applica
Operatio unlimited
lower VOC) bility
ns (PDF sealer and
VOC thresho
288 pp, some
topcoat. ld
13.8MB) coatings
have no
limits.
Control
of
Volatile
Organic
15 Emission
lb/day; s from
no yearly Existing
threshold Stationar
. y
Sources
The 2006 –
EP
CTG Volume
A-
covers II:
450
new Surface
/2-
automobi Coating 6 minor
77-
les/trucks of Cans, and 56
008
and parts Coils, general
on Paper, Rule is source
Automo 13
assembly Fabrics, not in the s
bile and 04/21 Not Minor,
lines; Automob ozone exceed Update
Light- 080421 345 / Anal 122
auto iles, and plan but the Rule 345
Duty 1999 yzed Gener
refinishin Light- is being CTG
Trucks al
g, i.e., Duty revised applica
body Trucks bility
shops (PDF thresho
and 232 pp, ld
collision 2.7MB)
repair, Control
are not Techniqu
covered es
by the Guidelin
EP
CTG. es for
A
Rule 345 Automob
453
applies to ile and
/R-
refinishin Light-
08-
g only Duty
006
Truck
Assembl
y
Coatings
35

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
(PDF 44
pp,
2.64MB)
Protocol
for
Determin
ing the
Daily
Volatile
Organic
Compou
nd
EP Emission
A Rate of
453 Automob
/R- ile and
08- Light-
002 Duty
Truck
Primer-
Surfacer
and
Topcoat
Operatio
ns (PDF
129 pp,
450KB)
Rule 346
limits VOC
content of
coatings
Control
to Rule 346
of
between does not
Volatile
· Does 5.10 and meet the
Organic
not 5.66 requirem There
Emission
apply lbs/gal. ents of are 4
s from
to the There are the latest minor
Existing
manufa VOC CTG. In source
Stationar Per note
1978 cture of tradeoff addition, s and 1
EP y EPA- from
CTG: 15 exterior options the major
A- Sources 453/R-06- Stan, the
lb/day; siding, and some 10 language source
450 – 004 limits flatwood
080411 no yearly tile coatings minor, of the that
Flatwoo /2- Volume VOC paneling
threshold board, 11/20 with no 1 Title newest exceed
d 78- VII: content to CTG
or 346 / VOC 24 V (all CTG the
Panelin 032 Factory 2.1 lbs/gal does not
2006 particle 1996 limits. minor does not annual
g Surface or use a include
CTG: 15 board Must use for include emissio
Coating 90% millwork.
lb/day; used transfer- VOC) millwork, ns limit
of Flat efficient Negative
no yearly as a efficient but uses for the
Wood ECS. Declarati
threshold furnitur spray the term CTG
Paneling on
e equipment flat wood applica
(PDF 66
compo if coating paneling bility
pp,
nent exceeds (old CTG thresho
2.0MB)
(Ref.20 4.29 lb does ld
, p. 49). VOC/gal refer to
or must millwork)
use ECS. .
EP Control Sources
A- Techniqu emitting
453 es <10
/R- Guidelin tons/year
36

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
See Rule
348
Specifics
tab. Rule
348 limits
VOC
content to
350-540
g/l for
primers &
topcoats
and 60-
1030 g/l
for
specialty
See Rule
coatings.
348
An ECS of
Specifics
at least
tab. EPA-
81%
453/R-97-
efficiency
004 limits
can also 18 No No
VOC
be used. Minor, source sources
content to Rule 348
EP Aerospa Applicatio 2 s exceed
60-1030 matches
Aerosp A- ce (CTG n Gener exceed applicabil
g/l for 04/07 the
ace 453 & MACT) equipment al, 3 the ity
080414 25 tpy specialty 348 / 44 NESHAP
CTG & /R- (PDF 62 must have Title V CTG threshold
coatings. 1999 MACT
MACT 97- pp, a transfer (all applica .
Primers and the
004 288KB) efficiency minor bility Negative
and CTG
of at least for thresho Declarati
topcoats
65% (i.e. VOC) ld on
are
HVLP or
regulated
electrostat
for major
ic spray
sources
applicatio
under
n
NESHAP
methods).
Solvent
cleaning
must have
VOC
vapor
pressure <
45 mm
HG.
Rules
apply to
the
cleaning
of spray
guns.
<15 · Control No No
lbs/day; Recom of Rule is in source sources
Synthe for each mends EP Volatile the s exceed
sized vent from cutoffs A- Organic ozone exceed applicabil
04/07
Pharma reactors, if case- 450 Emission Non 4 plan but the ity
040699 349 /
ceutical distillatio by- /2- s from e Minor does not CTG threshold
1999
Product n case 78- Manufact need to applica .
s operation approa 029 ure of be bility Negative
s, ch is Synthesi revised thresho declarati
crystalliz not zed ld on
38

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
(Ref. 2. )/day (PDF 49 recovery 2. Vapor
p. 5-1 ) through pp, with 90- recovery
put 1.3MB) 93% systems
efficiency, on tanks
incineratio between
n of 250-
vapors at 40,000
98% gal., or
efficiency. alternative
4. Leak control
prevention device.
(b)
from Tanks
Exemptio
loading >40,000
n for bulk
operations gal must
plants
. have
with
alternative
throughp
control
uts of
device:
less than
external
4,000
floating
gals per
roof,
day (Ref
internal
3, p. 1)
floating
roof, or
vapor
collection/
processin
g system
with 95%
efficiency.
(a) 1.
· Does
<150,000 Submerge
not
liters d fill pipe
apply
(40,000 and
to
gallons) pressure/v
storage
storage acuum
vessels
capacity valve on
equipp Control
of volatile tanks
ed with of
petroleu >250 gal.
externa Volatile
m liquids 2. Vapor
l Organic
(greater 1. recovery
floating Emission
than I0.5 Installatio systems Rule 350 CTG is
roofs s from
kPa TVP) EP n of an on tanks exceeds from
Fixed before Storage
(Ref. 6, A- internal between the 1977,
Roof 1/1/79 of 04/06 Status
p. 6-1). 450 floating 250- Unkno requirem Rule is
Petrole ? Petroleu 350 / 26 unkno
(b) · Does /2- roof tank 40,000 wn ents of from
um m 1992 wn
<1,600,0 not 77- with 90% gal., or the CTG; 1992;
Tanks Liquids
00 liters apply 036 emission alternative update update
in Fixed-
(420,000 to reductions control Rule 350 Rule 350
Roof
gallons) horizon . device.
Tanks
storage tal, Tanks
(PDF 43
capacity underg >40,000
pp,
of crude round gal must
1.1MB)
oil and storage have
condens tanks alternative
ate prior storing control
to lease JP-4 device:
custody Jet fuel external
transfer (Ref. 7, floating
(Red. 6, p. 2). roof,
40

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
p. 6-2) internal
floating
roof, or
vapor
collection/
processin
g system
with 95%
efficiency.
· Does
not
apply
to fixed
roof
(a)
tanks
<150,000
with or 1.
liters
without Submerge
(40,000
internal d fill pipe
gallons)
floating and
of
roofs, pressure/v
storage
or to acuum
capacity
small valve on
(Ref. 25,
product tanks
p. 5-1).
ion >250 gal.
tanks 2. Vapor
(Ref. recovery
1.
25, p. Control systems
External
1-2). of on tanks
floating
· Does Volatile between
roof tanks
not Organic 250-
are
apply Emission 40,000
recommen Rule 350 CTG is
Externa to s from gal., or
EP ded to exceeds from
l tanks Petroleu alternative
A- have a the 1977,
Floatin with a m Liquid 04/06 control Status
450 primary Unkno requirem Rule is
g Roof ? metallic Storage 350 / device. 26 unkno
(b) /2- foam, wn ents of from
Petrole -type in 1992 Tanks wn
<l,600,00 78- liquid- the CTG; 1992;
um shoe External >40,000
0 liters 047 filled, or update update
Tanks seal in Floating gal must
(420,000 metallic Rule 350 Rule 350
a Roof have
gallons) shoe seal
welded Tanks alternative
storage with a rim-
tank (PDF 66 control
capacity mounted
which pp, device:
used to secondary
has a 2.0MB) external
store seal.
second floating
produced
ary roof,
crude oil
seal internal
and
from floating
condens
the top roof, or
ate prior
of the vapor
to
shoe collection/
custody
seal to processin
transfer
the g system
(Ref. 25,
tank with 95%
p. 5-3).
wall or efficiency.
externa
l
floating
roof
tanks
storing
41

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
include: g system
Refrigerati which
on reduces
Compress VOC
ion, emissions
Refrigerati to 10 g
on per 1000
Absorptio liters. 4.
n, loading
Thermal prevents
Oxidizer. pressure
3. Leak >33.6 mm
prevention Hg and
from tank vacuum
trucks >11.2 mm
requiring Hg.
proper
maintenan
ce and
testing.
· The 1. 1.
affecte Gasoline gasoline
d tank must be
facilitie trucks hall stored or
s are not transporte
(1) change in d in a
gasolin pressure delivery
e tank of more vessel
trucks than 3" designed
that are H2O in 5 and
equipp minutes maintaine
ed for Control when d to be
vapor of pressurize vapor tight
collecti Volatile d to 18" and leak
on and Organic H2O or free. 2.
(2) the Compou evacuated Vapor
Gasolin
vapor nd Leaks to 6" H2O, return Rule 350 CTG is
e Tank
collecti EP from with no hoses exceeds from
Trucks Not
on A- Gasoline visible must be the 1978,
and specified Status
system 450 Tank liquid 05/05 attached Un- requirem Rule is
Vapor ? (15 352 6 unkno
at bulk /2- Trucks leaks. /1999 before known ents of from
Collecti lbs/day wn
termina 78- and 2.During connectin the CTG; 1999;
on VOC?)
ls, bulk 051 Vapor loading or g any update update
System
plants, Collectio unloading onloading Rule 350 Rule 352
Leaks
and n operations hose. 3.
service Systems there shall Spills and
station (PDF 32 be no excess
s that pp, reaing drainage
are 887KB) greater must be
equipp than or prevented
ed with equal to when
vapor 100% of disconnec
balanc the LEL at ting fill
e 2.5 cm hose. 4.
and/or around a Vapor
vapor potential hose is
proces leak required
sing source. 3. for
system Vapor dispensin
s (Ref. collection/ g gasoline
44

#Per #of
Late Do mits Permi
SI CTG Co
Bluebo st County in ts
Source C Applicab Recomm unt
TIER ok CT CTG Rule Rules Mari With Recomm
Catego Co ility ended y Note Status
Code Comm G# Name Revi Meet CTG cop Match endation
ry de Cutoffs Control Rul
ents sion Requirem a ing
s Options e
Date ents? Cou TIER
nty Code
.5" than
the tank
fails for
pressure
instability.
(a) 1. a 1.Tanks
Stationar submerge and
y d fill pipe delivery
gasoline is operations
storage required, shall be
container pipe must vapor
s of less extend to tight.
than 2 within 6" Tanks
,085 of tank may have
liters bottom. 2. pressure/v
(550 if a guage acuum
gallons) well is relief
capacity used it valve that
used must also prevent
exclusive have a vapor
ly for the Design drop tube escape at
62
fueling of Criteria which 1/5 of the
Minor,
impleme for Stage extends to LEL. 2.
825 Rule 350 24 CTG is
nts of I Vapor within 6" Storage
EP Gener exceeds Minor from
husbandr Control of tank and
Service A- al, 2 the permits 1978,
y, Systems bottom. 3. 06/16 delivery
Station 450 Title V requirem exceed Rule is
090213 provided – Vapor 353 / operations 165
s - /R- (4 ents of applic- from
the Gasoline hose 1999 may have
Stage I 75- source the CTG; ability 1999;
container Service returns no more
102 s update thresho update
s are Stations must be 3" than 3
major Rule 350 ld Rule 353
equipped (PDF 15 ID when drops per
for
with pp, used with minute of
VOC)
submerg 766KB) a 4" drop leakage.
ed fill tube, or No more
pipes operator than 2 tsp
(Ref. 4, must use of
p. 29) slower fill gasoline
(b) rates to shall be
<7,580 achieve lost in the
liters required course of
(2,000 vapor a hose
gallons) recovery. disconnec
capacity 4. 3" or t. 3. the
storage larger entire spill
tanks in connectio containme
place ns must nt system
before be used shall be
l/1/79 with 4" kept vapor
46