   



                                       
                                       
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION IX AIR DIVISION





                          Technical Support Document 
                                     for 
                  The EPA's Notice of Proposed Rulemaking 
                                    for the
                       Arizona State Implementation Plan
                                       
                                       
                                       
                                       
                           The EPA's Evaluation of
                                       
                   Maricopa County Air Quality Department, 
Analysis of Reasonably Available Control Technology For The 2008 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) State Implementation Plan (RACT SIP)  -  Adopted May 24, 2017
                                        
                                      And
                                       
                   Maricopa County Air Quality Department, 
                             Negative Declarations
                            -  Adopted May 24, 2017
                                       
                                       
                                       
                                       
                                       




                            Prepared by: Nicole Law
                                   July 2020



DOCUMENT IDENTIFICATION 

Agency:	Maricopa County Air Quality Department (MCAQD or County)

SIP Approved Version:	There is no previous SIP-approved MCAQD RACT SIP for the 2008 8-hour ozone standard, nor for the 1997 8-hour ozone standard.
				
Subject of this TSD:	Analysis of Reasonably Available Control Technology For The 2008 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) State Implementation Plan (RACT SIP)

	Appendix 1A: Negative Declarations 

	Adopted - May 24, 2017 
	Submitted - June 22, 2017

Completeness Finding:   Complete by operation of law - December 22, 2017
								
 BACKGROUND 

Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground-level ozone or "smog" which can result in significant impacts to human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that are classified as Moderate or above for ozone nonattainment to implement reasonably available control technology (RACT) for specific types of sources. 

The Phoenix-Mesa, Arizona ozone nonattainment area is classified as a Moderate ozone nonattainment area for the 2008 8-hour national ambient air quality standard ("NAAQS") for ozone (May 4, 2016, 81 FR 26697 and 40 CFR 81.303). The Phoenix-Mesa, Arizona ozone nonattainment area includes portions of Maricopa and Pinal Counties, and expressly excludes portions of Indian Country. MCAQD regulates those portions of the Phoenix-Mesa, Arizona ozone nonattainment area that lie within Maricopa County.
 
Under CAA § 182(b)(2) and (f), the MCAQD must, at a minimum, adopt RACT-level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any major stationary source of VOC or NOx. The EPA defines RACT as the "lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility."  44 FR 53761 (September 17, 1979). A RACT analysis should, therefore, take into account the technological and economic feasibility of controls, and may differ from source to source and location to location.


 SUBMITTAL SUMMARY  

The MCAQD adopted its RACT SIP certification for the 2008 ozone standard on May 24, 2017, and the Arizona Department of Environmental Quality (ADEQ) submitted it to the EPA on June 22, 2017. The MCAQD performed its RACT SIP analysis based on an ozone non-attainment classification of "Moderate." This classification defines a major source as those facilities that emit or have the potential to emit at least 100 tons per year (tpy) of VOC or NOx. 42 USC §§ 7511a(b), (f), 7602(j).

The MCAQD's submittal includes the following documents:
 "Analysis of Reasonably Available Control Technology For The 2008 8-Hour Ozone National Ambient Air Quality Standard (NAAQS) State Implementation Plan (RACT SIP)," dated December 5, 2016 [hereinafter "2016 RACT SIP"].
      
 Maricopa County Board of Supervisors' Certified Agenda Item and Action Taken on May 24, 2017.
 
The MCAQD's analysis includes the following elements:
       Evaluation of CTG Source Categories
       Evaluation of Non-CTG Source Categories
       Major sources identified 
       Negative declarations
      
Further discussion is provided below.
      
 EPA EVALUATION 

The EPA evaluated the following elements of the MCAQD submission:
 Efforts to identify non-CTG major sources within the MCAQD portion of the nonattainment area 
 The bases for concluding local rules implement RACT
 Negative declarations 
      
The MCAQD submittal contained newly-adopted rules, certifications that existing rules implement RACT, and negative declarations. This TSD addresses the categories for which the County either certified that existing rules implement RACT or provided a negative declaration.  The newly-adopted rules are addressed in separate TSDs and Federal Register notices as described in part IV below. 

The following documents were also used to support our review:

 "Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard  -  Phase 2" (70 FR 71612; November 29, 2005).
 "State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990" (57 FR 13498; April 16, 1992).
 Enforceability - Section 110(a) of the CAA requires enforceable emission limitations and other control measures. Several EPA guidance documents are used to evaluate rule enforceability, including "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," EPA, May 25, 1988 (The Blue Book), and "Guidance Document for Correcting Common VOC & Other Rule Deficiencies," EPA Region 9, August 21, 2001 (the Little Bluebook). 
 "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990" (57 FR 55620, November 25, 1992) ("the NOx Supplement").
 Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), "RACT Qs & As  -  Reasonably Available Control Technology (RACT) Questions and Answers."
 RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX's understanding of what constitutes a minimally acceptable RACT SIP.
 Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing the EPA's current CTGs, Alternative Control Techniques (ACTs), and other documents which may help to establish RACT.
 "Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements'' (80 FR 12264; March 6, 2015).
 EPA's CTGs and ACTs:   https://www.epa.gov/ozone-pollution/control-techniques-guidelines-and-alternative-control-techniques-documents-reducing
 MCAQD and EPA Region IX databases of MCAQD and other state and district rules
 			MCAQD: 	https://www.maricopa.gov/1951/Adopted-Rules
      EPA: 		https://www.epa.gov/air-quality-implementation-plans/approved-air-quality-implementation-plans-region-9   

The following summarizes MCAQD actions to address RACT requirements and the EPA's evaluation of those actions.

As an overview, the Department identified major sources for VOCs and NOx in Maricopa County.  They also identified RACT rules implemented for the Serious Area (1-hour) Ozone SIP dated December 2000.  The 2016 RACT SIP includes an analysis of CTG source categories and the accompanying Maricopa rules.  The Department determined which CTG source categories had no emitting facilities in Maricopa County and submitted a negative declaration for several CTG source categories.  Additionally, the Department determined which CTG source categories only had emitting facilities below the CTG threshold.  A negative declaration was also submitted for these CTG source categories.  The 2016 RACT SIP also includes an analysis of the non-CTG major source categories and the accompanying Maricopa rules.  

 Efforts to identify non-CTG major sources within the MCAQD portion of the nonattainment area
      
      RACT is required for source categories covered by an EPA Control Techniques Guidelines document ("CTG sources") and all sources that are not covered by a CTG document but are "major sources" (i.e., for MCAQD, non-CTG sources that emit or have the potential to emit at least 100 tpy of VOCs or NOx).
      
      
      MCAQD action
      
      Non-CTG major sources - MCAQD's 2016 RACT SIP identifies the major sources of VOCs and NOx by facility name, and Appendix B of the 2016 RACT SIP provides a RACT analysis of non-CTG source categories.  MCAQD also provided supplementary information including a table listing the facility names, type of pollutants, source type, and applicable SIP rules.      
      
      The table below reflects the information in MCAQD's 2016 RACT SIP and the "Supplemental Table 1  -  Major Sources of NOx and VOC in Maricopa County," showing all the major sources identified by the MCAQD with at least 100 tpy potential to emit VOC or NOx in the Maricopa County nonattainment area, and the applicable rules for these sources.  The bolded rule numbers represent rules which cover a primary emission source. 
      
      Table 1  -  Major Sources of NOx and VOC in Maricopa County, within the nonattainment area, identified by the County
Source
Pollutants
Source Type
Applicable Rules
APS West Phoenix Power Plant
NOX
Power Plant*
100, 130, 140, 200, 210, 240, 241, 270, 280, 300, 310, 312, 314, 315, 320, 322, 323, 330, 331, 335, 336, 340, 353, 360, 370, 371, 500, 510, 600
Arlington Valley LLC
VOC & NOX
Power Plant*
100, 130, 140, 200, 210, 240, 241, 270, 300, 310, 312, 320, 322, 324, 331, 335, 340, 360, 370, 371, 600
Gila River Power Station
VOC & NOX
Power Plant*
100, 130, 140, 200, 210, 270, 300, 310, 312, 320, 322, 331, 335, 340, 360, 370, 371, 600
Luke Air Force Base
VOC & NOX
Military Installation
100, 200, 210, 270, 280, 300, 310, 311, 312, 314, 315, 320, 323, 324, 330, 331, 335, 336, 345, 348, 350, 351, 352, 353, 370, 600
Mesquite Power Operations LLC
VOC & NOX
Power Plant*
100, 130, 140, 200, 210, 270, 300, 310, 312, 315, 320, 322, 324, 331, 335, 360, 370, 371, 600
New Harquahala Generating Company
VOC & NOX
Power Plant*
100, 130, 140, 200, 210, 241, 270, 300, 310, 312, 320, 322, 331, 335, 340, 360, 370, 600 
New Wincup Holdings Inc
VOC
Polystyrene Expansion and Molding
Plastic and Foam*
100, 130, 140, 200, 210, 270, 300, 310, 314, 320, 323, 331, 337, 358, 360, 370, 371, 600
Oak Canyon Manufacturing Inc
VOC
Wood Furniture Finishing and Manufacturing
100, 130, 140, 200, 201, 204, 210, 241, 270, 280, 300, 310, 311, 315, 320, 331, 342, 370, 371, 600
Ocotillo Power Plant
NOX
Power Plant*
100, 200, 210, 270, 280, 300, 310, 312, 314, 320, 322, 330, 331, 335, 336, 340, 353, 370, 371
Redhawk Generating Facility
VOC & NOX
Power Plant*
100, 130, 140, 200, 210, 270, 300, 310, 312, 315, 320, 322, 331, 335, 336, 340, 360, 370, 371, 600
Rexam Beverage Can Company
VOC
Can Manufacturing

100, 130, 140, 200, 210, 241, 270, 300, 310, 314, 320, 336, 360, 370, 371, 600
Santan Generating Station
NOX
Power Plant*
100, 130, 140, 200, 210, 240, 241, 242, 270, 300, 310, 312, 314, 315, 320, 322, 324, 330, 331, 335, 336, 353, 360, 370, 371, 600
SFPP PL Phoenix Terminal
VOC
Petroleum Products Bulk Storage
100, 130, 140, 200, 210, 270, 300, 310, 311, 312, 314, 320, 330, 331, 335, 336, 350, 351, 360, 370, 600
SRP Agua Fria
NOX
Power Plant*
100, 200, 210, 270, 280, 300, 310, 312, 314, 320, 322, 335, 340, 370, 371
SRP Kyrene Generating Station
NOX
Power Plant*
100, 130, 140, 200, 210, 241, 270, 300, 310, 312, 314, 315, 320, 322, 331, 335, 336, 340, 353, 360, 370, 371, 600
Trendwood Inc
VOC
Wood Furniture Finishing and Manufacturing
	
100, 130, 140, 200, 210, 241, 270, 300, 310, 311, 314, 335, 342, 370, 371
*This table contains all major sources in Maricopa County, within the nonattainment area.  However, the asterisked sources are the non-CTG major sources.
   
      EPA evaluation
      For major non-CTG stationary sources of VOCs or NOx, we reviewed Maricopa's list of Title V Permit sources and EPA's 2011 and 2014 National Emissions Inventory to determine if there were any major sources potentially missing from MCAQD's 2016 RACT SIP analysis and supplemental tables. We identified sources listed in the Title V Permit source list that were not included in the County's list of major sources and supplemental tables. However, we were able to determine that these sources were not, in fact, major sources for VOC or NOx. 
      
 The MCAQD Title V Permit source list includes Butterfield Station Facility (Permit # V98003), Glendale Mun Sanitary Landfill (Permit # V97015), Northwest Regional Landfill (Permit # V97016), Skunk Creek Landfill (Permit # V97019), Southwest Regional Landfill (Permit # V97023), and SR 85 Landfill Public Works Dept (Permit # V03002). These landfills are required to have a Title V permit, but are not major sources for VOC or NOx.   Therefore, RACT is not required for these sources.
 The MCAQD Title V Permit source list shows CMC Steel Fabricators Inc (Permit # V07001) as a major source.  Upon review of the permit, this is a major source for carbon monoxide (CO), but not for VOCs or NOx. Therefore, RACT is not required for this source (CAA § 182(b)(2)).
 The current MCAQD Title V Permit source list shows Intel Corp-Ocotillo Campus (Permit # V15002) as a major source.  Upon review of the most recent permit, this has only recently become a major source for VOC and NOx.  However, the initial permit issued limited the facility-wide emissions to below the major source threshold, as did the revision of the operating permit just prior to the finalizing date of the 2016 RACT SIP adoption in December 2016. Accordingly, the facility was not a major source at the time the 2016 RACT SIP was submitted. Additionally, EPA's 2014 NEI shows emissions of 40.6 tpy VOC and 38.6 tpy NOx.  Because the facility was not a major source at the time the 2016 RACT SIP was submitted, we do not consider Intel Corp-Ocotillo Campus a major source for the purpose of the present RACT SIP. However, future RACT SIP submittals may be required to demonstrate RACT for this source. 
 The MCAQD Title V Permit source list shows Marlam Industries (Permit # V97022) as a major source.  Upon review of the permit, this is a synthetic minor source of VOC (that is, the source has taken an enforceable permit limit to emit less than the major source threshold). Therefore, this is not a major source for RACT.
      
      There are four other sources listed in the Title V Permit Sources list which are also addressed in a supplemental table provided by MCAQD, but not identified in the 2016 RACT SIP:
      
 Goodrich Corporation (Permit # V97007) and Honeywell International (Permit # V97008) facilities are Title V Permitted sources operating as aerospace manufacturing sources.  However, Goodrich Corporation is a Title V Permitted sources due to HAP emissions and Honeywell International is a major source for NOx. Goodrich Corporation is not major for VOC or NOx, but is a CTG source for the Aerospace manufacturing CTG.
 Maax Spas Industries Corp (Permit # V97005) and Mesa Fully Formed LLC (Permit # V97027) are Title V Permitted sources operating as industrial adhesive sources, which is a CTG RACT category.  
      
      Based on MCAQD's major sources list in the RACT analysis and supplemental tables, we conclude that MCAQD properly identified all major non-CTG sources requiring RACT.  These sources are listed in Table 1 of this TSD. The four sources identified from the Title V Permit Sources list that are not identified in the 2016 RACT SIP are CTG sources.
      
 The bases for concluding local rules implement RACT 
      
      In 2000, the MCAQD analyzed CTG source categories to ensure that County rules covering these sources implemented RACT for the purpose of the 1-hour ozone NAAQS.  For the purpose of the 2016 RACT SIP, MCAQD analyzed these rules again to ensure that they meet current RACT. Based on this analysis, MCAQD determined that 6 VOC RACT rules and 3 NOx RACT rules needed to be revised to meet current RACT. Accordingly, MCAQD decided to revise these 6 VOC RACT rules and 3 NOx RACT rules. 
      
      MCAQD's Appendices A and B contain analysis of the RACT source categories and the associated rules.  Appendix A describes the 15 VOC CTG categories for which the County found it had applicable sources. Appendix B describes the NOx RACT sources.  In Appendix A, the MCAQD identified the following two existing SIP-approved rules as meeting RACT:
      
 Rule 331 Solvent Cleaning (amended 4/21/04): MCAQD concluded that Rule 331 meets current RACT based on comparisons to the two solvent cleaning CTGs, "Control of Volatile Organic Emissions from Solvent Metal Cleaning" (EPA-450/2-77-022) and "Control Techniques Guidelines: Industrial Cleaning Solvents" (EPA-453/R-06-001).
       Complete  -  the EPA concurs that Rule 331 as approved into the SIP on December 21, 2004, meets RACT.  
      
 Rule 337 Graphic Arts (amended 8/17/11): MCAQD concluded Rule 337 meets RACT as determined by a comparison with the relevant CTGs: "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VIII: Graphic Arts- Rotogravure and Flexography" (EPA-430/2-78-033) and "Offset Lithographic Printing and Letterpress Printing" (EPA-453/R06-002).   The most recent revision of the rule incorporated changes such as expanding the standards section of the rule to include additional categories and requirements.    
       Complete  -  the EPA approved Rule 337 into the SIP on August 27, 2019 (84 FR 44701), finding that the rule met current RACT. Accordingly, the EPA concurs that Rule 337 meets RACT.  
      
      The County also identified in Appendices A and B the following nine rules, which it recently updated and submitted along with its 2016 RACT SIP to satisfy the RACT requirement for the listed CTG source categories:
       
 Rule 336 Surface Coating Operations (amended 9/2/16): MCAQD revised this rule to meet additional CTGs.  The CTGs met are: "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks" (EPA-450/2-77-008), "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume III: Surface Coating of Metal Furniture" (EPA-450/2-77-032),  "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume V: Surface Coating of Large Appliances (EPA-450/2-77-034), "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VI: Surface Coating of Miscellaneous Metal Parts and Products" (EPA-450/2-78-15), "Control Techniques Guidelines for Metal Furniture Coatings" (EPA-453/R-07-005), "Control Techniques Guidelines for Large Appliance Coatings" (EPA-453/R07-004), "Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings" (EPA-453/R-08-003), and "Control Techniques Guidelines For Paper, Film, and Foil Coatings" (EPA-453/R-07-003).  MCAQD concluded Rule 336 meets RACT as determined by comparisons with the CTGs. 
       Addressed in separate proposal  -  the EPA believes that Rule 336 needs to be amended.  The EPA proposed a conditional approval of Rule 336 and the County's RACT demonstration for associated CTGs on January 28, 2020 (85 FR 4928), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval of the rule. If the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and the associated CTGs. Because we have already proposed action on this rule and the associated CTG source categories, we are not proposing action on this rule in this proposal.
      
 Rule 342 Coating Wood Furniture and Fixtures (amended 9/2/16): MCAQD concluded Rule 342 meets RACT as determined by a comparison with the EPA's CTG, "Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations" (EPA-453/R-96-007).  The latest amendment of the rule includes an updated table of VOC limits and the addition of a VOC leak detection and repair section.
       Complete  -  the EPA approved Rule 342 into the SIP on August 27, 2019 (84 FR 44701), finding that the rule met current RACT. Accordingly, the EPA concurs that Rule 342 meets RACT.
      
 Rule 350 Storage and Transfer of Organic Liquids (Non-Gasoline) at an Organic Liquid Distribution Facility (amended 9/2/16): MCAQD concluded Rule 350 meets RACT as determined by comparison with the EPA's two CTGs, "Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks" (EPA-450/2-77-036) and "Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks" (EPA-450/2-78-047).  
       Addressed in separate action  - The EPA conditionally approved Rule 350 and the County's RACT demonstration for associated CTGs on February 26, 2020 (85 FR 10986), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. As noted in our final action, if the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and the associated CTGs. Accordingly, we are not acting on this rule, or the associated CTG source categories in this action. 
      
 Rule 351 Storage and Loading of Gasoline at Bulk Gasoline Plants and Bulk Gasoline Terminals (amended 9/2/16): MCAQD concluded Rule 351 meets RACT as determined by comparison with EPA's two CTGs, "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals" (EPA-450/2-77-026) and "Control of Volatile Organic Emissions from Bulk Gasoline Plans" (EPA-450/2-77-035).
       Addressed in separate action  - The EPA conditionally approved Rule 351 and the County's RACT demonstration for associated CTGs on February 26, 2020 (85 FR 10986), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. As noted in our final action, if the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and the associated CTGs. Accordingly, we are not acting on this rule, or the associated CTG source categories in this action.
        
 Rule 352 Gasoline Cargo Tank Testing and Use (amended 9/2/16): MCAQD concluded Rule 352 meets RACT as determined by comparison to EPA's CTG, "Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems" (EPA-450-2-78-051). 
       Addressed in separate action  - The EPA conditionally approved Rule 352 and the County's RACT demonstration for associated CTGs on February 26, 2020 (85 FR 10986), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. As noted in our final action, if the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and the associated CTGs. Accordingly, we are not acting on this rule, or the associated CTG source categories in this action.
      
 Rule 353 Storage and Loading of Gasoline at Gasoline Dispensing Facilities (amended 9/2/16): MCAQD concluded Rule 353 meets RACT as determined by comparison to EPA's CTG, "Design Criteria for Stage I Vapor Control Systems- Gasoline Service Stations" (EPA-450/R-75-102).
       Addressed in separate action  - The EPA conditionally approved Rule 353 and the County's RACT demonstration for associated CTGs on February 26, 2020 (85 FR 10986), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. As noted in our final action, if the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and the associated CTGs. Accordingly, we are not acting on this rule, or the associated CTG source categories in this action.
      
 Rule 322 Power Plant Operations (amended 9/2/16): MCAQD concluded Rule 322 meets RACT as determined by comparing NOx limits to Imperial County Rule 400.1 as well as documentation provided by stakeholders.  The rule was revised to capture more equipment and to lower NOx limits.  
       Addressed in separate action  -  The EPA disapproved Rule 322 on July 20, 2020 (85 FR 43692), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. We are not acting on this rule in this action. However, because the EPA has disapproved Rule 322, there does not exist a SIP-approved rule establishing RACT level controls for sources covered by this rule. As described above, there are major sources of NOx that are covered by this rule. Accordingly, we must propose to disapprove the Maricopa County 2016 RACT SIP with respect to major sources of NOx.  
      
 Rule 323 Fuel Burning Equipment From Industrial/Commercial/Institutional (ICI) Sources (amended 9/2/16): MCAQD concluded Rule 323 meets RACT as determined by comparing NOx limits to Imperial County Rule 400.1.  The rule was revised to lower NOx limits. 
       Addressed in separate action  - The EPA conditionally approved Rule 323 on July 20, 2020 (85 FR 43692), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. If the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and its RACT obligation for major sources of NOx covered by this rule. Accordingly, we are not acting on this rule in this action.
      
 Rule 324 Stationary Internal Combustion (IC) Engines (amended 9/2/16): MCAQD concluded Rule 324 meets RACT as determined by comparing emissions limits in NSPS Subparts III, JJJJ, and various California SIP rules from Placer County, Sacramento, and Ventura County.  
       Addressed in separate action  - The EPA conditionally approved Rule 324 on July 20, 2020 (85 FR 43692), finding that the rule mostly implemented RACT, but identifying a limited number of deficiencies. The County has committed to correct these deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. If the County corrects the identified deficiencies and the EPA approves the updated rule, the County will have met its RACT obligation for this rule, and its RACT obligation for major sources of NOx covered by this rule. Accordingly, we are not acting on this rule in this action.
      
      In appendix C, the County also concluded that the following rule satisfies current RACT and does not require amending for RACT. We agree with the County's assessment that no changes to this rule are needed to demonstrate RACT for the 2008 ozone standard. 
      
 Rule 358 Polystyrene Foam Operations (amended 8/25/97): This rule is listed in the CTG RACT Spreadsheet in Appendix C. It covers operations from at least one major VOC source in the County. Additionally, MCAQD correctly submitted a negative declaration for the CTG category of Polymer Manufacturing because the two CTGs, "Control of Volatile Organic Compound Emissions from Manufacture of High Density Polyethylene, Polypropylene, and Polystyrene Resins" (EPA-450/3-83-008 (November 1983)) and "Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical and Polymer Manufacturing Equipment" (EPA-450/3-83-006 (March 1984)), do not cover the same operations that are performed at the major source and are covered by Rule 358.  Since there is no CTG for the emission sources in this category, MCAQD has determined that the SIP-approved rule does meet RACT based on a RACT analysis prepared by the Eastern Research Group (ERG) on the major source, New Wincup Holding, Inc. The EPA agrees that Rule 358 as approved into the SIP on May 26, 2005 meets RACT.
      
 Negative declarations where there are no facilities subject to a CTG
      
      In lieu of adopting RACT rules, districts may adopt negative declarations for CTG source categories if there are no sources in the district covered by the CTG. Negative declarations are not required for ACTs. 
      
      MCAQD Action
      The County reviewed its permit files and emission inventory and used standard industrial classification (SIC) codes and standard classification codes (SCC) to identify businesses subject to the various EPA CTGs. MCAQD used permitting information to also determine if facility emissions exceeded CTG thresholds.  Lastly, MCAQD staff (from Compliance and Permitting divisions) were asked about potential sources subject to CTGs. MCAQD adopted negative declarations for the CTG source categories shown in the tables in Appendix A of the 2016 RACT SIP Analysis and Appendix 1A of the submittal.  MCAQD adopted these negative declarations on May 24, 2017, and they were submitted for SIP approval on June 22, 2017. Supplemental information to MCAQD's 2016 RACT SIP states that additional research indicates there are sources subject to the aerospace and industrial adhesive CTGs.  The supplemental information also claims Rule 336 covers the CTG categories: Large Appliance Coating, Metal Furniture Coating, Cans, Coils, Paper, and Fabric Coating, and Paper, Film, and Foil Coating. 
      

 Table 2 - MCAQD Negative Declarations

 CTG Source Category
CTG Reference Document Title
Document Number and Date



Automobiles and Light-Duty Trucks
Control of Volatile Organic Emissions from Existing Stationary Sources- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks

Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings
EPA-450/2-77-008 (May 1977)




EPA-453/R-08-006 (September 2008)
Cutback Asphalt
Control of Volatile Organic Compounds from Use of Cutback Asphalt
EPA-450/2-77-037 (December 1977)
Flat Wood Paneling
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume VII:  Factory Surface Coating of Flat Wood Paneling

Control Techniques Guidelines for Flat Wood Paneling Coatings
EPA-450/2-78-032 (June 1978)



EPA-453/R-06-004 (September 2006)
Flexible Packaging Printing
Control Techniques Guidelines for Flexible Package Printing
EPA-453/R-06-003 (September 2006)
Magnet Wire Insulation
Control of Volatile Organic Emissions from Existing Stationary Sources- Volume IV: Surface Coating of Insulation of Magnet Wire
EPA-450/2-77-033 (December 1977)
Natural Gas/Gasoline Processing Plants
Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants

Control Techniques Guidelines for the Oil and Natural Gas Industry
EPA-450/3-83-007 (December 1983)



EPA 453/B-16-001 (October 2016)
Fiberglass Boat Manufacturing
Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials
EP-453/R-08-004 (September 2008)
Petroleum Refineries
Control of Refinery Vacuum Producing Systems, Wastewater Separators and Process Unit Turnarounds

Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment
EPA-450/2-77-025 (October 1977)



EPA-450/2-78-036 (June 1978)
Polymer Manufacturing
Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins

Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment
EPA-450/3-83-008 (November 1983)




EPA-450/3-83-006 (March 1984)
Rubber Tire Manufacturing
Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires
EPA-450/2-78-030 (December 1978)
Shipbuilding
Alternative Control Techniques Document: Surface Coating Operations at Shipbuilding and Ship Repair Facilities

Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating)
EPA-453/R-94-032 (April 1994)



61 FR 44050 (August 27, 1996)
Synthetic Organic Chemical Manufacturing
Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry

Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations Processes in the Synthetic Organic Chemical Manufacturing Industry
EPA-450/3-84-015 (December 1984)




EPA-450/4-91-031 (August 1993)
Aerospace*
Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations

National Emission Standards for Hazardous Air Pollutants for Sources Categories: Aerospace Manufacturing and Rework
EPA-453/R-97-004 (December 1997)




59 FR 29216 (June 6, 1994)
Industrial Adhesives*
Control Techniques Guidelines for Miscellaneous Industrial Adhesives
EPA-453/R-08-005 (September 2008)
Large Appliances
Control of Volatile Organic Emissions from Existing Stationary Sources- Volume V: Surface Coating of Large Appliances

Control Techniques Guidelines for Large Appliance Coatings
EPA-450/2-77-034 (December 1977)



EPA-450/R-07-004 (September 2007)
Large Petroleum Dry Cleaners
Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners
EPA-450/3-82-009 (September 1982)
Metal Coils
Control of Volatile Organic Emissions from Existing Stationary Sources- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks
EPA-450/2-77-008 (May 1977)
Metal Furniture
Control of Volatile Organic Emissions from Existing Stationary Sources - Volume III: Surface Coating of Metal Furniture

Control Techniques Guidelines for Metal Furniture Coatings
EPA-450/2-77-032 (December 1977)



EPA-453/R-07-005 (September 2007)
Paper
Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks

Control Techniques Guidelines for Paper, Film, and Foil Coatings
EPA-450/2-77-008 (May 1977)




EPA-453/R-07-003 (September 2007)
Synthesized Pharmaceutical Products
Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products
EPA-450/2-78-029 (December 1978)
 
   *The EPA is proposing to disapprove the negative declaration for the Aerospace and Industrial Adhesives as described below in the conclusion section.
      
      EPA Evaluation
      The County certified that it examined its permit files, emissions inventory and other documentation and determined that there are either no sources or only sources below the CTG threshold in the CTG source categories listed in their negative declaration and included in Table 2. The County adopted the negative declarations on May 24, 2017, after reasonable notice and public comment. Subsequent to submission, the County conducted additional research and determined that they did in fact have applicable sources in two source categories, aerospace and industrial adhesives, making these categories inappropriate for negative declarations. 
      
      The EPA searched the National Emissions Inventory for Maricopa County and verified that there did not appear to be facilities in the MCAQD subject to the remaining CTG categories. Accordingly, we conclude that with the exception of the aerospace and industrial adhesives categories, the submitted negative declarations are consistent with the relevant policy and guidance. However, the negative declarations for the aerospace and industrial adhesives CTGs are not approvable.  



 EPA ACTIONS ON OTHER MARICOPA COUNTY RACT SIP ELEMENTS

Due to its size and complexity, the EPA is acting on the MCAQD 2016 RACT SIP submittal in five separate actions. These actions are as follows:

 On August 27, 2019 (84 FR 44701), the EPA approved Rule 342 into the SIP, finding that the rule met current RACT. This rulemaking also approved Rule 337, which had been submitted earlier and was not part of the 2016 RACT SIP submittal. Although we approved Rules 337 and 342, and found that they established RACT level controls, we did not in that action approve the 2016 RACT SIP for the associated CTG source categories. We now propose to do so in this action. 
 On January 28, 2020 (85 FR 4928), the EPA proposed conditional approval of Rule 336 into the SIP, as well as conditional approval of the associated CTG source categories for the County's 2016 RACT SIP: "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks" (EPA-450/2-77-008), "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume III: Surface Coating of Metal Furniture" (EPA-450/2-77-032),  "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume V: Surface Coating of Large Appliances (EPA-450/2-77-034), "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VI: Surface Coating of Miscellaneous Metal Parts and Products" (EPA-450/2-78-15), "Control Techniques Guidelines for Metal Furniture Coatings" (EPA-453/R-07-005), "Control Techniques Guidelines for Large Appliance Coatings" (EPA-453/R07-004), "Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings" (EPA-453/R-08-003), and "Control Techniques Guidelines For Paper, Film, and Foil Coatings" (EPA-453/R-07-003). The County has committed to correct the EPA's identified deficiencies, and ADEQ has committed to submit the updated rule within one year of the EPA's final conditional approval. If the District corrects the identified deficiencies and the EPA approves the updated rule, the District will have met its RACT obligation for this rule, and the associated CTGs. We do not propose to act on Rule 336 in this action. 
 On February 26, 2020 (85 FR 10986), the EPA conditionally approved Rules 350, 351, 352, and 353 into the SIP, and also conditionally approved the associated CTG source categories for the County's 2016 RACT SIP: Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks (EPA - 450/ 2 - 77 - 036), Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks (EPA - 450/2 - 78 - 047), Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals (EPA - 450/2 - 77 - 026), Control of Volatile Organic Emissions from Bulk Gasoline Plants (EPA - 450/2 - 77 - 035), Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems (EPA - 450/2 - 78 - 051), and Design Criteria for Stage I Vapor Control Systems -- Gasoline Service Stations (EPA - 450/R - 75 - 102).  The County has committed to correct the EPA's identified deficiencies, and ADEQ has committed to submit the updated rules within one year of the EPA's final conditional approval. If the County corrects the identified deficiencies and the EPA approves the updated rules, the County will have met its RACT obligation for these rules, and the associated CTGs. We do not propose to act on rules 350, 351, 352, and 353, or the associated CTGs in the County's 2016 RACT SIP in this action.
 On July 20, 2020 (85 FR 43692), the EPA conditionally approved Rules 323 and 324 into the SIP and disapproved Rule 322. The EPA did not act on the major NOx portion of the County's 2016 RACT SIP in this action. The County has committed to correct the EPA's identified deficiencies in rules 323 and 324, and ADEQ has committed to submit the updated rules within one year of the EPA's final conditional approval. If the County corrects the identified deficiencies and the EPA approves the updated rules, the County will have met its RACT obligation for the sources covered by rules 323 and 324. However, because Rule 322 has been disapproved, the County has not established RACT level controls for the major sources covered by this rule. Therefore, in the present action, the EPA is proposing to disapprove the County's RACT obligation for major sources of NOx.
 The present action  -  which is acting on the remaining elements of the 2016 RACT SIP. 



 CONCLUSION
      
Based on our evaluation, the EPA staff recommends proposing partial approval and partial disapproval of the 2016 RACT SIP for the RACT demonstration for all source categories except those identified in section IV.2 and IV.3, above.  

We recommend a disapproval on the negative declaration for the CTG categories of Industrial Adhesives and Aerospace, and an approval of the other submitted negative declarations. 

In addition, we recommend an approval of the 2016 RACT SIP for sources associated with the following CTGs, because MCAQD has demonstrated that SIP-approved rules regulating these sources implement RACT levels of control: "Control of Volatile Organic Emissions from Solvent Metal Cleaning" (EPA-450/2-77-022), "Control Techniques Guidelines: Industrial Cleaning Solvents" (EPA-453/R-06-001), "Control of Volatile Organic Emissions from Existing Stationary Sources- Volume VIII: Graphic Arts- Rotogravure and Flexography" (EPA-430/2-78-033), "Offset Lithographic Printing and Letterpress Printing" (EPA-453/R06-002), and "Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations" (EPA-453/R-96-007). 

Finally, we recommend proposing approval for the RACT requirement for major non-CTG VOC sources, and a disapproval for major NOx sources. The MCAQD has identified all major sources of NOx and VOCs in the county, within the nonattainment area.  For VOCs, MCAQD has demonstrated that each of these sources is regulated by a SIP-approved rule that implements RACT-level controls, with the exception of one major source, which is a CTG source that is regulated by rules 350 and 351. Because all non-CTG major sources of VOC are regulated by RACT-level rules, we recommend approval for the major non-CTG VOC category. 

For major NOx sources, although MCAQD has identified the appropriate universe of sources, it has not demonstrated that all of these sources are regulated by SIP-approved rules implementing RACT-level controls. On July 20, 2020, the EPA disapproved MCAQD Rule 322 and conditionally approved Rules 323 and 324 based on a limited number of deficiencies.  MCAQD has committed to address the deficiencies in rules 323 and 324, and submit rule amendments to ADEQ to submit to the EPA within one year of the EPA's final conditional approval. However, because Rule 322 was disapproved, the County has not established RACT level controls for the major sources covered by this rule.  Because there are not SIP-approved RACT level controls for all the identified major NOx sources, the RACT requirement for major NOx sources is not fulfilled and we are proposing disapproval for major NOx sources. 
Table 4 below lists the CTGs, how MCAQD addressed this category in their 2016 RACT SIP submittal- with the rule or negative declaration corresponding to the CTG, and the EPA's proposed action for the source category, for those categories included within this rulemaking. Table 5 indicates whether major non-CTG VOC and NOx sources in the MCAQD are regulated by RACT rules.

      
Table 4  -  List of CTG Categories  -  2008 ozone NAAQS

EPA document #
CTG Source Category
                            Rule # claimed as RACT
                        Negative Declaration Submitted
                              New Rule submitted
                              EPA proposed action
EPA-450/R-75-102

Design Criteria for Stage I Vapor Control Systems  -  Gasoline Service Stations
                                   Rule 353
                                       
                                   Rule 353
                                      N/A
EPA-450/2-77-008
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume II: Surface Coating of Cans 
                                    Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-450/2-77-008
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume II: Surface Coating of Coils
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-450/2-77-008
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume II: Surface Coating of Paper 
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-450/2-77-008
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume II: Surface Coating of Fabrics 
                                   Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-450/2-77-008
Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume II: Surface Coating of Automobiles, and Light-Duty Trucks 
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-450/2-77-022

Control of Volatile Organic Emissions from Solvent Metal Cleaning 
                                   Rule 331
                                       
                                       
                                       
                                   Approval
EPA-450/2-77-025

Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds 
                                       
                                       X
                                       
                                   Approval
EPA-450/2-77-026

Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals
                                    Rule 351
                                       
                                   Rule 351
                                      N/A
EPA-450/2-77-032

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume III: Surface Coating of Metal Furniture 
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-450/2-77-033

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume IV: Surface Coating of Insulation of Magnet Wire 
                                       
                                       X
                                       
                                   Approval
EPA-450/2-77-034

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume V: Surface Coating of Large Appliances 
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-450/2-77-035

Control of Volatile Organic Emissions from Bulk Gasoline Plants
                                    Rule 351
                                       
                                   Rule 351
                                      N/A
EPA-450/2-77-036

Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks
                                Rule 350 and 351
                                       
                               Rule 350 and 351
                                      N/A
EPA-450/2-77-037

Control of Volatile Organic Emissions from Use of Cutback Asphalt 
                                       
                                       X
                                       
                                   Approval
EPA-450/2-78-015

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume VI: Surface Coating of Miscellaneous Metal Parts and Products 
                                    Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-450/2-78-029

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products
                                       
                                       X
                                       
                                   Approval
EPA-450/2-78-030

Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires
                                       
                                       X
                                       
                                   Approval
EPA-450/2-78-032

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume VII: Factory Surface Coating of Flat Wood Paneling 
                                       
                                       X
                                       
                                   Approval
EPA-450/2-78-033

Control of Volatile Organic Emissions from Existing Stationary Sources  -  Volume VIII: Graphic Arts-Rotogravure and Flexography
                                   Rule 337
                                       
                                       
                                   Approval
EPA-450/2-78-036

Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment
                                       
                                       X
                                       
                                   Approval
EPA-450/2-78-047

Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks
                                Rule 350 and 351
                                       
                               Rule 350 and 351
                                      N/A
EPA-450/2-78-051

Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems
                                    Rule 352
                                       
                                   Rule 352
                                      N/A
EPA-450/3-82-009

Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners
                                       
                                       X
                                       
                                   Approval
EPA-450/3-83-006

Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment
                                       
                                       X
                                       
                                   Approval
EPA-450/3-83-007

Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants 
                                       
                                       X
                                       
                                   Approval
EPA-450/3-83-008

Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins 
                                       
                                       X
                                       
                                   Approval
EPA-450/3-84-015

Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry
                                       
                                       X
                                       
                                   Approval
EPA-450/4-91-031

Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry
                                       
                                       X
                                       
                                   Approval
EPA-453/R-06-001
Control Techniques Guidelines for Industrial Cleaning Solvents
                                   Rule 331
                                       
                                       
                                   Approval
EPA-453/R-06-002
Control Technology Guidelines for Offset Lithographic Printing and Letterpress Printing
                                   Rule 337
                                       
                                       
                                   Approval
EPA-453/R-06-003
Control Techniques Guidelines for Flexible Package Printing
                                       
                                       X
                                       
                                   Approval
EPA-453/R-06-004
Control Technique Guidelines for Flat Wood Paneling Coatings
                                       
                                       X
                                       
                                   Approval
EPA-453/R-07-003
Control Techniques Guidelines for Paper Coatings
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-453/R-07-003
Control Techniques Guidelines for Film Coatings
                                   Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-453/R-07-003
Control Techniques Guidelines for Foil Coatings
                                   Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-453/R-07-004
Control Techniques Guidelines for Large Appliance Coatings
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-453/R-07-005
Control Techniques Guidelines for Metal Furniture Coatings
                                   Rule 336
                                       X
                                   Rule 336
                       Approval of negative declaration
EPA-453/R-08-003
Control Technique Guidelines for Miscellaneous Metal and Plastic Parts Coatings
                                    Rule 336
                                       
                                   Rule 336
                                      N/A
EPA-453/R-08-004
Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials
                                       
                                       X
                                       
                                   Approval
EPA-453/R-08-005
Control Techniques Guidelines for Miscellaneous Industrial Adhesives 
                                       
                                       X
                                       
                                  Disapproval
EPA-453/R-08-006
Control Techniques Guidelines for Automobile and Light-duty Truck Assembly Coatings
                                       
                                       X
                                       
                                   Approval
EPA-453/R-96-007

Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations
                                    Rule 342
                                       
                                   Rule 342
                                   Approval
EPA-453/R-94-032


Alternative Control Technology Document  -  Surface Coating Operations at Shipbuilding and Ship Repair Facilities CTG, see 61 FR-44050, 8/27/96

                                       
                                       X
                                       
                                   Approval
61 FR-44050 -8/27/96
Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating)
                                       
                                       X
                                       
                                   Approval
EPA-453/R-97-004


Aerospace (CTG & MACT) See also 59 FR-29216, 6/6/94.

                                       
                                       X
                                       
                                  Disapproval
59 FR-29216 6/06/94

Aerospace MACT See also EPA-453/R-97-004.
                                       
                                       X
                                       
                                  Disapproval

Table 5 - RACT for Major non-CTG VOC/NOx Sources in MCAQD  -  2008 ozone NAAQS
     
Category
               Covered by SIP-Approved RACT-Level Maricopa Rules
                              EPA proposed action
Major non-CTG VOC sources
                                      Yes
                                   Approval 
Major non-CTG NOx sources
                                      No
                                  Disapproval
      
             
 REFERENCES 
      
 "Revisions to the State Implementation Plan Revision For the Maricopa County Air Quality Department Ozone Rules Contained in the Arizona SIP, Originally Dated December 5, 2016 Originally Submitted to the EPA on December 19, 2016", June 16, 2017. 

 RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX's understanding of what constituted a minimally acceptable RACT SIP.
      
 RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing EPA's current CTGs, ACTs, and other documents that may help to establish RACT.
      
 RACT Qs & As  -  Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Note from William T. Harnett, Director, Air Quality Policy Division, to Regional Air Division Directors. https://www3.epa.gov/ttn/naaqs/aqmguide/collection/cp2/20060518_harnett_ract_q&a.pdf    
      
 "Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard  -  Phase 2" (70 FR 71612; November 29, 2005).
      
 "Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements'' (80 FR 12264; March 6, 2015).

 "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 	http://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf

 "Guidance Document for Correcting Common VOC & Other Rule Deficiencies," (a.k.a., 	Little Bluebook), EPA Region 9, August 21, 2001 	http://www.arb.ca.gov/drdb/lbb2001.pdf
      
 "State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990" (57 FR 13498; April 16, 1992).

 "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990" (57 FR 55620, November 25, 1992) ("the NOx Supplement").

 EPA's CTGs and ACTs https://www.epa.gov/ozone-pollution/control-techniques-guidelines-and-alternative-control-techniques-documents-reducing 
      
 MCAQD and EPA Region IX databases of MCAQD rules
 			MCAQD: 	https://www.maricopa.gov/1951/Adopted-Rules
      EPA: 		https://www.epa.gov/air-quality-implementation-plans/approved-air-quality-implementation-plans-region-9
      
 Electronic Meeting Invitation from J. Kuspert (MCAQD) to S. Tong and N. Law (EPA R9), "Maricopa County RACT SIP: EPA Conference Call,"  January 3, 2018. Includes three attachments titled, "Maricopa RACT SIP analysis document," "RactSipInformationForEpa 2018-01-11.docx," and "Rule 324 Comment Response Support_8_28_2017.docx."
      
 Email from K. Butler (MCAQD) to D. Lo and N. Law (EPA R9), "Rule 336 Updates," November 1, 2018.  Includes two attachments titled, "Response to EPA Comments on the RACT SIP.docx" and "Follow-up comments from 1/11/18 conference call on Maricopa County RACT SIP."

 Letter from P. McNeely (MCAQD) to M. Cabrera (ADEQ), "RE: Request for Submittal of Letter of Commitment for Conditional Approval of the Maricopa County Reasonably Available Control Technology (RACT) State Implementation Plan (SIP)," January 28, 2019.

  Letter from T. Franquist (ADEQ) to M. Stoker (EPA R9), "Re: Submittal of the Maricopa County Air Quality Department's Letter of Commitment for Conditional Approval of the Maricopa County Reasonably Available Control Technology (RACT) State Implementation Plan (SIP), February 25, 2019.

 Title V Air Quality Operating Permit for Butterfield Station Facility as Issued on October 27, 2003 and Renewed on August 31, 2016. Permit # V98003

 Title V Air Quality Operating Permit Renewal for Glendale Mun Sanitary Landfill as dated December 20, 2013. Permit #V97015.

 Title V Air Quality Operating Permit for Northwest Regional Landfill as Issued on October 27, 2003 and renewed on April 25, 2017.  Permit # V97016.
      
 Title V Air Quality Operating Permit for city of Phoenix Public Works as Issued on February 28, 2003 and renewed on May 1, 2015 for the business named Skunk Creek Landfill.  Permit # V97019.
      
 Title V Air Quality Operating Permit for Southwest Regional Landfill as Issued on September 10, 1999 and renewed on March 9, 2016.  Permit # V97023.
      
 Title V Air Quality Operating Permit for the City of Phoenix as Issued on April 4, 2005 and renewed on September 29, 2006.  Permit # V03002.
      
 Title V Air Quality Operating Permit for CMC Steel Fabricators Inc as Issued on August 8, 2008 and renewed on June 14, 2018.  Permit # V07001.
      
 Title V Air Quality Operation Permit for Intel Corp- Ocotillo Campus as Issued on January 11, 2016 and revised on December 17, 2018. Permit # V15002.
      
 Title V Air Quality Operation Permit for Intel Corp- Ocotillo Campus as Issued on January 11, 2 016 and revised on September 27, 2016. Permit # V15002.
      
 Title V Air Quality Operation Permit for Marlam Industries as Issued on May 14, 2013 and renewed on May 17, 2016. Permit # V97022
      
 Title V Air Quality Operation Permit for Goodrich Corporation as Issued on August 26, 2004 and revised on September 12, 2018. Permit # V97007
      
 Title V Air Quality Operating Permit for Honeywell Engines as Issued on January 27, 2006 and revised on November DD, 2016. Permit # V97008
      
  Title V Air Quality Operating Permit for Honeywell Engines as Issued on January 27, 2006 and revised on December 6, 2018. Permit # V97008

 Title V Air Quality Operating Permit for Maax Spas Industries Corp as issued on April 23, 2003 and revised on August 18, 2015. Permit # V97005
      
 Title V Air Quality Operating Permit for Mesa Fully Formed LLC as Issued on November 30, 2002 and renewed on February 29, 2016. Permit # V 97027

