EPA’s New Ozone Rule: Part 21

As we continue to look at the costs and benefits of lowering the standard on ground-level ozone, let’s get an idea what industry would need to do to comply. As we mentioned before, ozone is rarely emitted directly by industry. Rather, industry emits volatile organic compounds (VOCs), and atmospheric chemistry and sunlight act on these VOCs to produce ozone1. To reduce ground-level ozone, industry must reduce the VOCs that it emits.

This is not an easy thing to do, considering the vast array of applications that VOCs arise from. To give an idea of how many industries are affected, I copied EPA’s list of documents recommending how different industries can cut down their VOC emissions, called control techniques guidelines (CTGs) and alternative control techniques (ACTs)2. The methods they describe are called reasonably available control technologies (RACTs), because they are not difficult to obtain at reasonable cost. Many of these documents are from the 1970’s, 80’s, and 90’s and may be seriously out of date. Nevertheless, the extent of industrial processes described by these documents give us an appreciation for the breadth of effort and the depth of commitment required from the business community to reduce ozone.

Some of technologies may not be hard to implement. One of the shorter documents addresses the technology of cutback asphalt, which is asphalt dissolved in an organic solvent3. This allows the asphalt to be sprayed as a liquid on a road bed. The solvent evaporates into fumes that can generate ozone, and the asphalt is left behind to harden into road surface. To eliminate these fumes, the EPA recommends switching to emulsion asphalt, which is asphalt finely ground and mixed with water. Like cutback asphalt, emulsion asphalt can also be sprayed onto road beds where it will harden, but the evaporated water will not generate ozone. Emulsion asphalt can be manufactured with the same equipment, so road construction companies can switch to emulsion asphalt at little additional cost.

Other technologies are no longer needed over time. A federal regulation required that gasoline stations put hoods on their pump nozzles to prevent the escape of gasoline fumes. In May 2012, the EPA rescinded that regulation when it was advised that current car construction already prevent gasoline fumes from escaping during refueling without need of a hood4.

Here is a list of CTGs and ACTs taken from the EPA website SIP Planning Information Toolkit: Control Techniques Guidelines and Alternative Control Techniques Documents, which you can view by clicking here. As you can see, the list of industries that need to adapt to new ozone rules is long, which helps to explain the large-scale economic impact of new ozone regulations:

Control Technology Guidelines (CTGs)

  • Gasoline service stations
  • Surface coating operations
  • Surface coatings of cans, coils, paper, fabrics, automobiles, and light-duty trucks.
  • Solvent metal cleaning
  • Refinery vacuum producing systems, wastewater separators, and process unit turnarounds
  • Tank truck gasoline loading terminals
  • Surface coating of metal furniture
  • Surface coating of insulation of magnetic wire
  • Surface coating of large appliances
  • Bulk gasoline plants
  • Storage of petroleum liquids in fixed-roof tanks
  • Cutback asphalt
  • Surface coating of miscellaneous metal parts and products
  • Factory surface coating of flat wood paneling
  • Petroleum refinery equipment
  • Manufacture of synthesized pharmaceutical products
  • Manufacture of pneumatic rubber tires
  • Graphic arts: Rotogravure and Flexography
  • Petroleum Liquid Storage in External Floating roof tanks
  • Gasoline tank trucks and vapor collection systems
  • Large petroleum dry cleaners
  • Manufacture of high-density polyxxx resins
  • Natural gas/gasoline processing plants
  • Leaks from synthetic organic chemical polymer and resin manufacturing equipment
  • Air oxidation processes in synthetic organic chemical manufacturing industry
  • Wood furniture manufacturing operations
  • Ship building and ship repair operations
  • Aerospace
  • Industrial cleaning solvents
  • Offset lithographic and letterpress printing
  • Flexible package printing
  • Flat wood paneling coatings
  • Paper, film, and foil coatings
  • Large appliance coating
  • Metal furniture coatings
  • Miscellaneous metal and plastic pants coatings
  • Fiberglass boat manufacturing materials
  • Miscellaneous industrial adhesive
  • Automobile and light-duty truck assembly coatings

Alternate Control Technologies (ACTs)

  • Surface coating operations at shipbuilding and ship repair facilities
  • Plywood veneer dryers
  • Applications of traffic markings
  • Ethylene oxide sterilization of fumigation operation
  • Halogenated solvent cleaners
  • Organic wast process vents
  • Polystyrene foam manufacturing
  • Bakery ovens
  • Industrial wastewater
  • Agricultural pesticides
  • Volatile organic liquid storage in floating and fixed-roof tanks
  • Batch processes
  • Industrial cleaning solvents
  • Surface coating of automotive/transportation and business machine plastic parts
  • Automotive refinishing
  • NOx emissions from nitric and adipic acid manufacturing plants
  • NOx emissions from stationary combustion turbines
  • NOx emissions from process heaters
  • NOx emissions from stationary internal combustion engines
  • NOx emissions from cement manufacturers
  • NOx emissions from industrial, commercial, and institutional boilers
  • NOx emissions from utility boilers
  • NOx emissions from glass manufacturers
  • NOx emissions from iron and steel mills
  • Automobile refinishing



  1. To review the chemistry of ozone generation, see my post in this blog EPA’s New Ozone Rule: Part 4.
  2. EPA website, SIP Planning Information Toolkit: Control Techniques Guidelines and Alternative Control Techniques Documents. To view, click here.
  3. U.S. Environmental Protection Agency, Control of Volatile Organic Compounds from Use in Cutback Asphalt, December 1977. To view, click here.
  4. CNN website, EPA to remove vapor-capturing rubber boot from gas pump handles by Todd Sperry, May 10, 2012. To view, click here. See also the television program The Rachel Maddow Show, MSNBC; click here for the video.

One response to “EPA’s New Ozone Rule: Part 21

  1. Pingback: EPA’s New Ozone Rule: Part 24 | Michael Klein's Environmental Essays

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