Reasonably Available Control Technology (RACT) Analysis

What is RACT?

Reasonably Available Control Technology (RACT) refers to the minimum level of emissions control that existing facilities in ozone nonattainment areas must implement to reduce air pollution. RACT standards are developed by the US Environmental Protection Agency (EPA) and guides the selection of emissions control technologies for specific pollutants, mainly volatile organic compounds (VOCs) and nitrogen oxides (NOx). The core principles of RACT include:

1. 1. Emission reduction – Minimize pollutant output contributing to ozone formation.
   2. Technological feasibility – Apply proven and available control methods.
   3. Economic reasonableness – Cost-effective control method for existing sources.
   4. Regulatory compliance – Integrate into State Implementation Plan (SIP) as part of the Clean Air Act framework.

When is RACT Required?

RACT is mandatory for existing and new sources located in ozone nonattainment areas, which are regions that do not meet the National Ambient Air Quality Standards (NAAQS) for ozone. This includes:

• • All volatile organic compounds (VOCs) covered by EPA’s Control Techniques Guidelines (VOC)
  • All major sources of VOCs and Nitrogen Oxides (NOx) are not covered by CTGs (i.e. non-CTGs)
  • All major sources of VOCs and Nitrogen Oxides (NOx) located in areas classified as moderate or more severe under current 8-hour ozone NAAQS
  • As attainment status is evaluated for newly promulgated NAAQS, such as PM2.5, these requirements will be expanded.

Types of RACT Determinations

RACT determinations vary based upon whether source falls under EPA-issued guidance or requires a case-specific approach:

1. 1. Control Techniques Guidelines (CTGs) – Presumptive RACT
      1. Issued by the US EPA
      2. Provides presumed level of control that states adopt directly into SIP
      3. Applies to specific volatile organic compounds (VOC) source categories (e.g. coatings, degreasers, etc.)
   2. Alternative Control Techniques (ACTs) – Informed RACT
      1. When no CTG exists, states refer to ACT documents
      2. Applies to non-CTG major sources (e.g. cement kilns, turbines, or internal combustion engines)
   3. Source-specific– Case-by-case RACT
      1. Conducted when facility doesn’t fit into defined CTG category
      2. Requires full top-down analysis, which follows the process:
         1. Identify all Reasonably Available Control Technologies (RACT)
         2. Eliminate Technically Infeasible Control Technologies
         3. Rank Remaining Control Technologies Based on Capture and Control Efficiencies
         4. Evaluate Remaining Control Technologies on Economic, Energy, and Environmental Feasibility