TECHNICAL SUPPORT DOCUMENT

Clean Air Act Approval of Revisions to the Texas State Implementation
Plan Regarding a Negative Declaration for the Synthetic Organic Chemical
Manufacturing Industry Batch Processing Source Category in El Paso
Subject to Reasonably Available Control Technology

                        

Carl Young

EPA Region 6, Dallas, Texas

May 2007

I.  BACKGROUND

The Clean Air Act (CAA) requires the Environmental Protection Agency
(EPA) to establish national ambient air quality standards (NAAQS) for
pollutants that cause or contribute to air pollution that is reasonably
anticipated to endanger public health or welfare.  States have developed
a State Implementation Plan (SIP) which identifies how these standards
will be attained and maintained.  The State must submit revisions to the
SIP to EPA.  EPA reviews the revision and approves it if it conforms
with the Clean Air Act.  Approval makes the revisions federally
enforceable.  If the revision does not conform with the Clean Air Act,
EPA disapproves it.  Disapproval may lead to further revisions by the
State, sanctions or development of a Federal Implementation Plan by EPA.

CAA section 172(c)(1) requires State Implementation Plans (SIPs) for
areas that are not attaining a National Ambient Air Quality Standard
(NAAQS) to provide, at a minimum, for such reductions in emissions from
existing sources in the areas as may be obtained through the adoption of
reasonably available control measures including Reasonably Available
Control Technology (RACT).  In a September 17, 1979 Federal Register
notice (44 FR 53761) RACT is defined 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 economical feasibility.”  State SIPs for
ozone nonattainment area classified as moderate or higher must require
RACT for major stationary sources of volatile organic compound (VOC)
emissions (CAA Section 182(b)(3)).  VOC emissions can react with
sunlight and nitrogen oxides to form ground-level ozone.  If no major
stationary sources of VOC emissions exist in a particular source
category in a nonattainment area, the State may submit a negative
declaration for that category.

EPA established source categories for which RACT must be implemented and
issued associated Control Technique Guidelines or Alternative Control
Techniques (ACT) documents.  Synthetic organic chemical manufacturing
industry (SOCMI) batch processing sources is one of the source
categories for which RACT must be implemented.  In 1994 EPA issued an
ACT document for this source category.

The El Paso area, consisting of El Paso County, Texas, was classified as
a moderate nonattainment area for the 1-hour ozone NAAQS by EPA on
November 6, 1991 (56 FR 56694).  On January 10, 1996, the State of Texas
submitted a SIP revision that included a demonstration that RACT was
required for the El Paso area.  The SIP revision that included the
demonstration was the December 1995 Post-1996 Rate of Progress Plan for
the Beaumont/Port Arthur and Houston/Galveston Ozone Nonattainment
Areas.  On October 30, 1996 EPA approved negative declarations for nine
source categories in the El Paso area (61 FR 55894).  These VOC source
categories are: industrial wastewater, clean-up solvents, aerospace
coating, shipbuilding and repair, wood furniture, plastic part coatings
– business machines, plastic part coatings – others, autobody
refinishing, and offset lithography.  On January 16, 1999 EPA approved
the demonstration that RACT was required in the El Paso area for
synthetic organic chemical manufacturing industry (SOCMI) reactor and
distillation sources and storage tank sources (64 FR 3841).

In the October 30, 1996 action approving negative declarations for nine
source categories in the El Paso area, EPA failed to take action on the
negative declaration for SOCMI batch processing sources.  The negative
declarations are found on page 35 of the December 1995 SIP revision.

II.  REVIEW & RECOMMENDATION

Data from the Texas 2004 Point Source Emissions Inventory was obtained
and reviewed.  The data was obtained from the website
www.tceq.state.tx.us/implementation/air/industei/psei/psei.html.  The
data confirmed that there were no major sources of VOC emissions from
SOCMI batch processing facilities in El Paso County.  

It is recommended that the State’s declaration that there no major
sources of VOC emissions from SOCMI batch processing facilities in El
Paso County be approved.  EPA approval of the State(s negative
declaration will correct the earlier failure to take action on the
negative declaration submitted by Texas.

III.  BIBLIOGRAPHY

1.  Control of Volatile Organic Compound Emissions from Batch Processes
– Alternative Control Techniques Information Document, EPA,
EPA-453/R-93-017, February 1994.

2. Post-1996 Rate of Progress Plan for the Beaumont/Port Arthur and
Houston/Galveston Ozone Nonattainment Areas, Texas Natural Resource
Conservation Commission, December 13, 1995.

3.  State of Texas Point Source Emissions Inventory, 2004, Sorted by
County, Texas Commission on Environmental Quality, September 2006

