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Overview of Control Techniques Guidelines (CTGs)

Overview of Control Techniques Guidelines (CTGs). Air Quality Technical Advisory Committee Meeting Harrisburg, PA October 30, 2008. CTG Background.

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Overview of Control Techniques Guidelines (CTGs)

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  1. Overview of Control Techniques Guidelines (CTGs) Air Quality Technical Advisory Committee Meeting Harrisburg, PA October 30, 2008

  2. CTG Background • Section 183(e) of the Clean Air Act directs the EPA to list for regulation categories that account for at least 80% of the VOC emissions from consumer and commercial products in ozone nonattainment areas • The EPA has determined that for 11 VOC categories, issuing CTGs will be as effective as national rules • Recent CTGs affecting 12 categories have been issued in 3 groups: 4 in 2006, 3 in 2007, and 4 in 2008

  3. CTG Background • CTGs provide guidance to states on what constitutes Reasonably Available Control Technology (RACT) for that type of source • States with ozone nonattainment areas are required to revise their State Implementation Plans (SIPs) to include requirements for RACT for VOC categories covered by a CTG issued after 1990

  4. Previous Post-1990 CTGs and Related PA Regulations • CTG – SOCMI Distillation and Reactor Processes – August 1993 • PA 129.71 Synthetic organic chemical and polymer manufacturing – fugitive sources • PA 129.72 Manufacture of surface active agents • CTG – Wood Furniture – April 1996 • PA 129.101-129.107 Wood furniture manufacturing operations • CTG – Shipbuilding/Repair – August 1996 • CTG – Aerospace – December 1997 • PA 129.73 Aerospace manufacturing and rework

  5. CTGs Issued 9/29/06 and Existing PA Regulations • Flat Wood Paneling Coatings • Industrial Cleaning Solvents • PA 129.63 - covers parts washers only • Flexible Package Printing • PA 129.67 - covers facilities with VOC PTE > 100 tons/year • Lithographic and Letterpress Printing • PA 129.67 covers facilities with VOC PTE > 100 tons/year

  6. CTGs Issued 9/28/07 and Existing PA Regulations • Metal Furniture Coatings • PA 129.52 – Surface coating processes • Large Appliance Surface Coating • PA 129.52 – Surface coating processes • Paper Film and Foil Coatings • PA 129.52 - covers paper coatings

  7. CTGs Issued 9/30/08 and Existing PA Regulations • Miscellaneous Metal and Plastic Parts Coatings • PA 129.52 - covers metal parts coatings • Fiberglass Boat Manufacturing • Auto and Light-duty Truck Assembly Coatings • PA 129.52 – Surface coating processes • Miscellaneous Industrial Adhesives

  8. Impact of the New CTGs • Many of the sources covered by the CTGs are already regulated by one or more of the following: • earlier CTG • Maximum Available Control Technology (MACT) • National Emission Standard for Hazardous Air Pollutants (NESHAP) • Available Control Technology (ACT) • New Source Performance Standard (NSPS) • PA regulation • In those cases, the recently published CTGs update existing requirements relating to allowable VOC content, add-on controls, work practices, etc. to what is currently reasonably available

  9. Cost of Compliance • EPA provides estimates of the cost of compliance with the recommended limits in each CTG (see next slide) • EPA indicates that cost estimates are based on use of low-VOC materials because that will be the widely used compliance method • Work practices are estimated to provide a net savings

  10. EPA Estimated Costs of Complying with Coating Limits

  11. Typical CTG Recommendations • Most CTGs are applicable to facilities emitting at least 15 lb/day (2.7 tons/year) of VOC • Contain emission limits based on low-VOC materials • Generally allow use of add-on controls or combination of low-VOC materials and add-on controls as compliance alternatives • Some CTGs recommend specific application methods • Some CTGs specify VOC content and vapor pressure limits for cleaning materials

  12. Typical CTG Recommendations • Work Practices – Examples of “good housekeeping” requirements include: • Store VOC-containing materials and used shop towels in closed containers • Ensure that mixing and storage containers used for VOC-containing materials are kept closed • Minimize spills • Convey VOC-containing materials from one location to another in closed containers or pipes

  13. Options for Incorporating the CTG Recommendations • For categories covered by an existing PA regulation: • Amend existing PA regulation or add new regulation with more stringent emission limits consistent with the CTG • Add any work practice requirements • For categories not covered by an existing PA regulation • Add new regulations based on the CTG documents

  14. Assessment of CTGs • Identifying potentially affected sources • Evaluating potential for emission reduction • Comparing each CTG to existing requirements for the source category • Current PA regulations • NESHAP/MACT • OTC adhesives model rule

  15. Next Steps • We plan to provide an update at a future committee meeting • Rule development status • Schedule • Questions – Please contact: • Susan Hoyle at (717) 772-2329 • Nancy Herb at (717) 783-9269

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