UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	September 18, 2012

SUBJECT:	Technical Support Document for Maryland’s Adoption of
Amendments to Reasonably Available Control Technology Requirements for
Volatile Organic Compounds

				/s/

FROM:	Jacqueline Lewis, Environmental Engineer 

Office of Air Program Planning 

TO:		File

				/s/

THRU: 	Donna Mastro, Acting Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

	The Clean Air Act (CAA) section 172(c)(1) provides that state
implementation plans (SIPs) for nonattainment areas must include
“reasonably available control measures” (RACM), including
“reasonably available control technology ” (RACT), for sources of
emissions.  Section 182(b)(2)(A) provides that for certain nonattainment
areas, states must revise their SIPs to include RACT for sources of 
volatile organic compounds (VOC) emissions covered by a control
techniques guidelines (CTGs) document issued after November 15, 1990 and
prior to the area’s date of attainment. 

	The United States Environmental Protection Agency (EPA) defines RACT as
“the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably
available considering technological and economic feasibility.” See 44
FR 53761 (Sept. 17, 1979).  In subsequent Federal Register notices, EPA
has addressed how states can meet the RACT requirements of the CAA. 

	CAA section 183(e) directs EPA to list for regulation those categories
of products that account for at least 80 percent of the VOC emissions,
on a reactivity-adjusted basis, from consumer and commercial products in
areas that violate the national ambient air quality standards (NAAQS)
for ozone (i.e., ozone nonattainment areas).  EPA issued the list on
March 23, 1995, and has revised the list periodically. See 60 FR 15264
(March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov.
17, 2005), and 64 FR 13422 (Mar. 18, 1999).  

EPA develops CTGs as guidance on control requirements for specific
source categories.  The CTGs are intended to provide state and local air
pollution control authorities information that should assist them in
determining RACT for VOC.  Maryland has submitted revisions to the SIP
to address the following source categories: (1) paper, film, and foil
coatings; (2) industrial cleaning solvents; (3) miscellaneous metal and
plastic parts coatings; (4) large appliance coatings; (5) offset
lithographic printing and letterpress printing; (6) flat wood paneling
coatings; and (7) flexible package printing.  

In 1977, 1978, 1993 and 1994, EPA developed CTGs for all the source
categories listed above, and in 2006, 2007 and 2008 EPA developed new
CTGs for these source categories after conducting a review of existing
state and local VOC emission reduction approaches for these industries,
reviewing the original CTGs, Alternative Control Techniques (ACTs), and
New Source Performance Standards (NSPS) and taking into account the
information that has become available since then.  EPA’s new CTGs are
entitled Control Techniques Guidelines for Paper, Film, and Foil
Coatings (EPA 453/R-07-003, September 2007), Control Techniques
Guidelines: Industrial Cleaning Solvents (EPA 453/R-06-001, September
2006), Control Techniques Guidelines for Miscellaneous Metal and Plastic
Parts Coatings (EPA-453/R-08-003, September 2008), Control Techniques
Guidelines for Large Appliance Coatings (EPA 453/R-07-004, September
2007), Control Techniques Guidelines for Offset Lithographic Printing
and Letterpress Printing (EPA-453/R-06-002, September 2006), Control
Techniques Guidelines for Flat Wood Paneling Coatings (EPA 453/R-06-004,
September 2006), and Control Techniques Guidelines for Flexible Package
Printing (EPA 453/R-06-003, September 2006).  These new CTGs include new
general requirements along with testing, work practice, and
recordkeeping requirements.

B.  STATE SUBMITTAL

On April 5, 2012, EPA received a SIP revision from the Maryland
Department of the Environment (MDE) to address sources of VOC emissions
covered by EPA’s CTGs for seven source categories.  These categories
are (1) paper, film, and foil coatings; (2) industrial cleaning
solvents; (3) miscellaneous metal and plastic parts coatings; (4) large
appliance coatings; (5) offset lithographic printing and letterpress
printing; (6) flat wood paneling coatings; and (7) flexible package
printing.  This SIP revision amends Regulation .04 Testing and
Monitoring under COMAR 26.11.01 General Administrative Provisions and
Regulation .02 Applicability, Determining Compliance, Reporting, and
General Requirements under COMAR 26.11.19 for subsections (D) Test
Methods, (E) Computations, (G) Control of Major Stationary Sources of
Volatile Organic Compounds, and (I) Good Operating Practices, Equipment
Cleanup, and VOC Storage.

	

	

 COMAR 26.11.01 General Administrative Provisions

Regulation .04 Testing and Monitoring under COMAR 26.11.01 General
Administrative Provisions provides updated provisions for the test
methods that are referenced under COMAR 26.11.19.02.  These amendments
are incorporated by reference under Section C. Emissions Test Methods
and now read as follows.  

C. Emission Test Methods. The following test methods are incorporated by
reference: 

(1) 40 CFR Part 60, Appendix A, as amended;                             
                                                                        
                                                                        
                                                         (2) The
Department's Technical Memorandum 91-01, "Test Methods and Equipment
Specifications for Stationary Sources," January 1991, as amended through
Supplement 3 (October 1, 1997); and 

(3) For PM10 stack tests, the following EPA approved test methods shall
be used: 

(a) Test Methods 201 A and 202 in 40 CFR Part 51, Appendix M, as
amended; 

(b) Test Method 5 (40 CFR Part 60, Appendix A, as amended) and Test
Method 202 in 40 CFR Part 51, Appendix M, as amended; 

(c) Test Method 5 (40 CFR Part 60, Appendix A, as amended) using front
half and back half procedure; 

(d) EPA Conditional Test Method 39 may be substituted for Test Method
202 in 40 CFR Part 51, Appendix M, as amended; or 

(e) Alternative test methods may be used for PM10 if they are approved
by the Department and the EPA.

COMAR  26.11.19 Volatile Organic Compounds from Specific Processes

	Top of Form

 B			

The amendments to COMAR 26.11.19.02 (D), (E), and (I) apply to sources
covered by the CTG categories and other regulations and processes
involving testing, cleaning solutions, solvents, or degreasing materials
covered under COMAR 26.11.19.  These amendments make the requirements
more consistent with EPA’s CTGs guidance for alternative test methods,
calculation methods, and work practice standards.

COMAR 26.11.19.02(D) (Test Methods) establishes methods, procedures and
requirements for the alternative testing of control devices.  The
revision amends COMAR 26.11.19.02(D)(2) by requiring sources that use
air pollution control equipment to comply with the requirements of this
chapter make the determination in accordance with COMAR 26.11.01.04(C). 
The revision also adds COMAR 26.11.19.02(D)(3) requiring MDE and U.S.
EPA approval if a source chooses to determine compliance using
alternative test methods.  

COMAR 26.11.19.02(E) (Computations) establishes the method required to
determine composite vapor pressure of solvent cleaning material.  This
revision adds sections (3), (4), and (5) to COMAR 26.11.19.02 (E)
entitled Computations which read as follows.

 (3) The composite vapor pressure of organic compounds for any cleaning
solution, solvent, or degreasing material shall be determined as
follows: 

(a) The composite vapor pressure of organic compounds shall be
determined by quantifying the amount of each compound in the blend using
gas chromatographic analysis (ASTM E 260-91) for organics and ASTM
D3792-79 for water content, as applicable, and the following equation: 

∑(Wi)(VPi)/Mwi] / [Ww/Mww + ∑We/Mwe + ∑Wi/Mwi]

Where: 

Ppc = VOC composite partial pressure at 200 C, in mm Hg                 
                    

Wi = Weight of the “I”th VOC compound, in grams, as determined by
ASTM E 260-91 

Ww = Weight of water, in grams as determined by ASTM D 3792-86 

We = Weight of the “I”th exempt compound, in grams, as determined by
ASTM E 260-91 

Mwi = Molecular weight of the “I”th VOC compound, in grams per
g-mole, as given in chemical reference literature 

Mww = Molecular weight of water, 18 grams per g-mole 

Mwe =Molecular weight of the “I”th exempt compound, in grams per
g-mole, as given in chemical reference literature 

Vpi = Vapor pressure of the “I”th VOC compound at 20 C, in mm Hg, as
determined by §E(4)(b) of this regulation. 

(b) The vapor pressure of each single component compound may be
determined from ASTM D2879-86, or may be obtained from a material safety
data sheet or another source approved by the Department. 

(4) The mass VOC to mass solids applied for coatings, adhesives, or inks
shall be determined as follows: 

(a) The VOC content, water content, density, volume solids, and weight
solids for any coating, adhesive, or ink used pursuant to the
requirements of this chapter shall be determined as specified in COMAR
26.11.01.04C. 

(b) The weight of coating solids shall be calculated as follows: 

VOCS = Wv – Ww – Wex/ Wn

Where: 

VOCS = VOC content in lb VOC/lb of coating solids or in kg VOC/kg of
coating solids 

Wv = 100% - Wn 

Ww = Weight percent of water 

Wex = Weight percent of exempt solvents 

Wn = Weight percent of solids of the as applied coating 

(5) The weight of VOC in units of weight VOC per weight coating applied
(in pounds VOC/pounds coating applied or in VOC/kg coating applied) for
coatings, adhesives, or inks shall be determined as follows: 

(a) The VOC content, water content, density, volume solids, and weight
solids for any coating, adhesive, or ink used pursuant to the
requirements of this chapter shall be determined as specified in COMAR
26.11.01.04C. 

 (b) The weight of coating solids shall be calculated as follows: 

VOCM = Wv - Ww - Wex 

Where: 

VOCM = VOC content in lb VOC/lb of coating or in kg VOC/kg of coating 

Wv = 100% - Wn 

Ww = Weight percent of water 

Wex = Weight percent of exempt solvents 

Wn = Weight percent of solids of the as applied coating 

COMAR 26.11.19.02(I) (Good Operating Practices, Equipment Cleanup, and
VOC Storage) establishes requirements for the handling of solvents and
cleaning material.  This revision adds three additional good operating
practice requirements under COMAR 26.11.19.02(I) (2)(b).  They include
minimizing spills of VOC-containing cleaning materials, minimizing VOC
emissions from cleaning of storage, mixing, and conveying equipment and
also require that closed containers or pipelines be used to convey
equipment and convey VOC-containing cleaning materials from one location
to another. 

The amendment to COMAR 26.11.19.02 (G) (Control of Major Stationary
Sources of Volatile Organic Compounds) exempts additional VOC RACT
regulations that had not been adopted since 1991.  This amendment makes
references to specific VOC RACT regulations and reads as follows:  

G. Control of Major Stationary Sources of Volatile Organic Compounds. 

(1) This section applies to a person who owns or operates any major
stationary source of VOC that is not subject to any VOC emission
standard in COMAR 26.11.10, 26.11.11, 26.11.13, 26.11.14, or Regulations
.03—.33 of this chapter. 

C.  EPA EVALUATION

The State of Maryland has adopted these amendments to address sources of
VOC emissions covered by EPA’s seven CTGs listed above.  Maryland
already had regulations in place which reduced VOC emissions from these
source categories, and these amendments make the requirements more
consistent with EPA’s CTG guidance for alternative test methods,
calculations methods, and work practice standards.  Therefore the VOC
emissions reductions are expected to be minimal.  

D.  PUBLIC COMMENT 

	During the State’s public comment period, no comments were received. 

	

E.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of various test methods, calculations methods, and work
practice standards for (1) paper, film, and foil coatings; (2)
industrial cleaning solvents; (3) miscellaneous metal and plastic parts
coatings; (4) large appliance coatings; (5) offset lithographic printing
and letterpress printing; (6) flat wood paneling coatings; and (7)
flexible package printing by the State of Maryland will strengthen
Maryland SIP.  EPA approval of the SIP revision is recommended.

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