UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029



DATE:

	February 6, 2009



SUBJECT:

	Technical Support Document for the District of Columbia, Reasonably
Available Control Technology Under the 8-hour Ozone National Ambient Air
Quality Standard	 	 

 FROM:

	Patrick J. Egan, Environmental Protection Specialist  

Air Quality Planning Branch (3AP21)

TO:

REVIEWED BY:	SIP Docket File

            /s/                           

Cristina Fernandez, Branch Chief

Air Quality Planning Branch (3AP21)



I.	Affected Regulation

The revision to the District of Columbia State Implementation Plan
(SIP), received by EPA on September 22, 2008, applies to the
demonstration that the District of Columbia has implemented all the
necessary requirements of Reasonably Available Control Technology (RACT)
set forth by the federal Clean Air Act (CAA).  This determination is
necessary because section 184 of the CAA requires that areas within the
Ozone Transport Region (OTR) perform certain moderate nonattainment
requirements, regardless of the ozone designation or classification of
the particular area.

II.	 Background

Ozone is formed in the atmosphere by photochemical reactions between
volatile organic compounds (VOC), oxides of nitrogen (NOx) and carbon
monoxide (CO) in the presence of sunlight.  In order to reduce ozone
concentrations in the ambient air, the CAA requires all nonattainment
areas to apply control on VOC/NOx emission sources to achieve emission
reductions.  Among effective control measures, RACT controls are a major
group for reducing VOC and NOx emissions from stationary sources.

The District of Columbia is part of the OTR.  The OTR is established by
section 184 of the CAA.  Areas under the OTR are subject to OTR-specific
RACT requirements. Under the 1-hour ozone NAAQS, the District of
Columbia was originally classified as part of the Metropolitan
Washington serious 1-hour ozone nonattainment area located in OTR (56 FR
56694 at 56844, November 6, 1991).  As part of the planning process,
section 182(b)(2) of the CAA required the District of Columbia to
implement RACT on all sources and source categories covered by a CTG
issued by EPA.  Point sources with the potential to emit 50 tons per
year or more of VOCs or 100 tons per year or more of NOx that were not
covered by a CTG were also required to implement RACT.  As a result of
failure to meet the attainment date of November 15, 1999, the
Metropolitan Washington area was reclassified as a severe nonattainment
area for the 1-hour standard (68 FR 3410 at 3425, January 24, 2003).  As
a result of the reclassification, the District of Columbia was required
to perform RACT evaluations on point sources with the potential to emit
25 tons per year for either VOC (62 FR 11334, March 12, 1997) or NOx (69
FR 48150, August 9, 2004).

On July 18, 1997, EPA promulgated the new 8-hour NAAQS for ozone (62 FR
38856, July 18, 1997).  Under the 8-hour ozone NAAQS, the Metropolitan
Washington Area was designated nonattainment for the 8-hour ozone
standard and classified as a moderate nonattainment area.  

On March 7, 2007, the District of Columbia Department of Environment
(DDOE) submitted a SIP revision for the District of Columbia in order to
recertify RACT as part of the 8-hour ozone NAAQS planning process for
the Metropolitan Washington Area and the requirements of section 184 of
the CAA must be satisfied.  

At that time DDOE was requesting EPA approval of the SIP revision. 
However the SIP Revision submitted on March 7, 2007, contained the word
“proposal” on the first page and thus could not be approved by EPA. 
Therefore, on August 11, 2008, DDOE requested a withdrawal of the March
7, 2007 submittal.  DDOE also requested return of the SIP submittal
package at that time.  On August 28, 2008, DDOE received the SIP
revision package.  The word “proposal” was replaced with the word
“final” and the SIP package was received on September 22, 2008. 

 

The first requirement, contained in section 184(b)(1)(B), requires the
implementation of RACT with respect to all sources of VOC covered by a
CTG.  The second requirement, set forth in section 184(b)(2), requires
the implementation of major stationary source requirements as if the
area were a moderate nonattainment area on any stationary source with a
potential to emit of at least 25 tons per year of VOC or 100 tons per
year of NOx.

Since the District of Columbia is part of the OTR, DDOE submitted this
SIP revision to demonstrate that all requirements for RACT are met,
either through certification that previously required RACT controls
represent RACT for 8-hour implementation purposes, through new or
amended RACT determinations, or by demonstrating that no facilities
exist in the District of Columbia that are applicable to CTG categories.

Since the 1970's, EPA has consistently interpreted RACT to mean the
lowest emission limit that a particular source is capable of meeting by
the application of the control technology that is reasonably available
considering technological and economic feasibility.  See, e.g., 72 FR
20586 at 20610 (April 25, 2007).  Section 182 of the CAA sets forth two
separate RACT requirements for ozone nonattainment area.  The first
requirement, contained in section 182(a)(2)(A) of the CAA, and referred
to as RACT fix-up, requires the correction of RACT rules for which the
EPA identified deficiencies before the CAA was amended in 1990.  The
second requirement, set forth in section 182(b)(2) of the CAA, requires
that moderate (or worse) ozone nonattainment areas, as well as marginal
and attainment areas the OTR established pursuant to section 184 of the
CAA, implement RACT controls on all major VOC and NOx emission sources
and on all sources and source categories covered by a CTG issued by EPA.

NOx RACT Controls

District of Columbia Municipal Regulations (DCMR) Chapter 8 Section 805
contains District of Columbia’s NOx RACT controls that were
implemented and approved into the District of Columbia’s SIP under the
1-hour ozone SIP.  Table 1 lists District of Columbia’s NOx RACT
controls:

Table 1	District of Columbia’s NOx RACT Controls

Regulation 20 DCMR - 	Title of Regulation	State Effective Date	Federal
Effective Date	Federal Register Notice

805.1	Fuel-burning equipment with an input capacity of 100 MM Btu/hr or
greater	4/16/04	12/28/04	69 FR 77645

805.5 & 805.8	Fuel-burning equipment with an input capacity equal to or
greater than 20MM/Btu/hr, but less than 50 MM Btu/hr	4/16/04	12/29/04	69
FR 77645

805.1 & 805.8	Fuel-burning equipment with an input capacity equal to or
greater than 50 MM/Btu/hr, but less than 100 MM Btu	4/16/04	12/28/04	69
FR 77645

805.4	Combustion turbine with an input capacity equal to or greater than
100 MM	4/16/04	12/28/04	69 FR 77645

805.1 & 709.1	Asphalt concrete plant with a pPTE 25 tons per year or
greater	4/16/04	12/28/04	69 FR 77645

805.1	All other fuel burning equipment with a PTE of 25 tons per year of
NOx or greater	4/16/04	12/28/04	69 FR 77645

805.1	Stationary Internal Combustion Engines	4/16/04	12/28/04	69 FR
77645



VOC RACT Controls

The District of Columbia’s Regulations and Statues, under 20 DCMR
Chapter 7, contain the District’s VOC RACT controls that were
implemented and approved in the District SIP under the 1-hour ozone
NAAQS.  Table 2 lists District of Columbia’s VOC RACT controls.

Table 2	District of Columbia’s VOC RACT Controls

Regulation

20-DCMR-	Existing Stationary Sources

	Title of Regulation	State Effective Date	Federal Register Date	Citation

715 and 716	Offset Lithography	10/2/98	10/27/99	64 FR 57777

704	Stage I Vapor Recovery	3/15/85	10/27/99 	64 FR 57777

708 and 742 	Solvent Cleaning Degreasing	3/15/85 	10/27/99

	64 FR 57777

718	Paint – Spray Booth	11/26/04	12/23/04	69 FR 76855

706	Petroleum Dry Cleaners	3/15/85	10/27/99	64 FR 57777

709.1	Cutback Asphalt	3/15/85	10/27/99	64 FR 57777

704.4	Leaks from Gasoline Tank Trucks and Vapor Collection Systems
3/15/85	10/27/99	64 FR 5777

710	Engraving and Plate Printing	3/15/85	8/4/92	57 FR 34249

705.4 – 705.14	Stage II Gasoline Vapor Recovery 	3/15/85	10/27/99	64
FR 57777



Although Alternate Control Techniques (ACTs) are not regulatory
documents and have no legal effect on state regulations, EPA requires
that states verify that ACTs have been considered in the RACT program
development process.  Therefore, DDOE included ACTs in their review of
applicable RACT requirements in this submittal.

 DDOE also submitted a negative declaration that the following VOC CTG
major sources do not exist in the District of Columbia.  The
determination was made after review of the existing registration
database for the counties comprising the 8-hour ozone nonattainment area
in the Metropolitan Washington, D.C. area.  Table 3 lists the District
of Columbia’s negative declaration for VOC CTG major sources.

Table 3 – Documents for which no Applicable Sources Exist in the
District of Columbia



Document Title

Automobile and light-duty truck manufacturing

Coating of cans, coils, paper, fabric and vinyl, metal furniture, large
applicances, magnet wire, miscellaneous metal parts and products and
flatwood paneling

Storage of petroleum liquids in fixed-roof tanks

Bulk gasoline plants

Petroleum refinery sources

Manufacture of synthesized pharmaceutical products, pneumatic rubber
tires, vegetable oil, synthetic organic chemicals (fugitive VOCs and air
oxidation) and high density polyethylene, polypropylene and polystyrene
resins

Graphic Arts Systems

Storage, transportation and marketing of VOCs (fugitive VOCs from oil
and gas production and natural gas and gasoline processing)

Aerospace

Shipbuilding and repair

Distillation or reactor or batch processees in the synthetic organic
chemical manufacturing industry

Wood furniture coatings

Storage of petroleum liquids in external floating-roof tanks

Bulk gasoline terminals

Petroleum refinery equipment leaks



III.       Evaluation

The District of Columbia’s SIP revision contains the requirements of
RACT set forth by the CAA under the 8-hour ozone NAAQS.  This SIP
revision for the District of Columbia satisfies the 8-hour RACT
requirements through (1) certification that previously adopted RACT
controls in the District of Columbia’s SIP that were approved by EPA
under the 1-hour ozone NAAQS are based on the currently available
technically and economically feasible controls, and that they continue
to represent RACT for the 8-hour implementation purposes; (2) the
negative declaration that there are no CTG or non-CTG major sources of
VOC and NOx emissions within the District of Columbia; and (3) no
revised or new, more stringent regulations that represent RACT control
levels, were adopted.  Therefore, approval of the District of
Columbia’s 8-hour RACT SIP is recommended.

IV.       Conclusion

This SIP revision request satisfies all requirements for an acceptable
SIP revision.

V.    Recommended Agency Action

The SIP revision request should be approved.

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