1 Control Techniques Guidelines Joel Leon September 16, 2011

2 Control Techniques Guidelines (CTG) Under the Clean Air Act (CAA), states with nonattainment areas must revise their State Implementation Plans (SIP) to include reasonably available control technology (RACT) In addition to RACT, the CAA specifically requires states with moderate and above ozone nonattainment areas implement ozone related CTG, which address VOC emissions. –Minimum VOC control efficiencies –Maximum VOC content levels –Thresholds to exempt lower emitting facilities The USEPA issues CTGs to provide states with guidance regarding controls that constitute RACT

3 Control Techniques Guidelines (CTG) Guidelines – States can adopt different standards if justified On May 9, 2009, the CTG for the following categories were adopted in N.J.A.C 7: –flat wood paneling coatings –flexible packaging printing materials –offset lithographic printing and letterpress printing

4 Control Techniques Guidelines (CTG) States do not have to adopt CTG if: –The current RACT limits are already equivalent to or more stringent than the CTG –If a state does not have sources in a particular category that are subject to the CTG –All existing sources are already in compliance with CTG States must file “Negative Declaration” with EPA for all CTG that it proposes not to adopt

5 Control Techniques Guidelines (CTG) Negative Declaration to be filed by NJ for the following CTG since no facilities located in state –Auto and Light-Duty Truck Assembly Coatings –Metal Furniture Coatings –Large Appliance Coatings

6 CTG Source Categories which may be adopted into NJAC Fiberglass Boat Manufacturing Materials CTG –Based on 2001 NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) –Two facilities comply with MACT (in compliance with CTG) –Three other facilities being contacted

7 CTG Source Categories which may be adopted into NJAC Paper, Film, and Foil Coatings and Miscellaneous Metal and Plastic Part Coatings CTGs –Reviewing APC Permits of applicable facilities –Will determine if a negative declaration will be proposed Industrial Cleaning Solvent CTG –Solvents containing VOC used to clean –Includes spray booth cleaning, equipment cleaning, line cleaning, and floor cleaning –Cleaning that generally does not require an APC Permit –Reviewing APC regulation to determine which regulations already apply