### GUIDANCE DOCUMENT F OR CORRECTING

COMMON VOC & OTHER RULE DEFICIENCIES

(A.K.A., The Litt

le Bluebook)

U.S. ENVIRONMENT

AL PROTECTION AGE NCY REGION IX

Originally Issued, April 1991 Revised, August 21, 2001

### Table of Contents Guidance Document for Correcting Common VOC & Other Rule Deficiencies

Introduction
.................................................................. 1 Definitions & Applicability VOC Definition
............................................................... 2 Rule Applicability and Exemptions
................................................ 3 Control Requirements Coating and Ink VOC

Content Units
............................................... 5 Compliance Periods and Averaging Times
.......................................... 7 Alternative Controls and Alternative Methods of Compliance
........................... 9 Monitoring, Reco

rdkeeping & Report

ing Recordkeeping
.............................................................. 11 Test Methods
................................................................ 13 Transfer Efficiency
........................................................... 14 Capture Efficiency
............................................................ 16
Other Director's Discretion
.......................................................... 17- 1 -



### Introduction This document, sometimes referred to as the Little Bluebook, is intended to help state and local air agenc

ies develop rules

that meet federa

l criteria for in

corporation into St

ate Implementation Plans (SIPs). It was originally developed for stationary source VOC rules, but much of the discussion also applies to other rules. It does not impose new requirements but

provides example

s and additional ex

planation of issue

s highlighted in EPA's guidance document, Issues Relating to V OC Regulation Cutpoin

ts, Deficiencies

, and Deviations - Clarification to Appendix D of November 24, 1987 Federal Register (OAQPS, May 25, 1988, referred to as the Bluebook). The Bluebook can be found at http://www.epa.gov/oar/oaqps/ozonetech/voc_bluebook.pdf
. Please note, neither the Bluebook nor the Little Bluebook represent exhaustive listings of all potent

ially applicable requir

ements for SIP rul

es.The lists of national guidance, for example, do not include all potentially relevant information. For questions or co

mments on this docume

nt, please contac

t: Rulemaking Office (AIR-4) Air Division U.S. EPA, Region IX 75 Hawthorne Street San Francisco, CA 94105 (415) 744-1185- 2 -



### VOC Definition EPA regulates e

missions of all volat

ile organic com

pounds (VOC) excep

t those with negligible photochemical reactivity. National Regulation/Policy/Guidance EPA defines VOC at 40 CFR 51.100(s) and lists those negligibly reactive compounds which are exempt from VOC requirements. EPA occasionally updates this list based on new information. Suggestions for Deve

loping Approvable Pr

ovisions 1. Mos t SIP s ei the r referen ce 40 CFR 51. 100 (s) or r epri nt i t in its ent ire ty. 2. SIP rules cann

ot use vapor pressure to define VO C. 3. SIP rules cannot exclude compounds that are not exempted by 40 CFR 51.100(s). 4. SIP rules can control compounds that are exempted by 40 CFR 51.100(s) as long as states do not claim control of these compounds as emission reduc tions in ozone SIPs, a

s credits for New Source Review or Economic Incentive Programs, or for determining compliance with emission limits. Example Approvable Provision 40 CFR 51.100(s) exempts ethane, but California considers ethane reactive. Consistent with item #4 above, EPA has approved California VOC definitions which do not exempt ethane.- 3 -



### Rule Applicabil

ity and Exempti

ons National Regulation/Policy/Guidance 1. Rule applicability must be clear to meet the general enforce ability requirement of §110(a)(2)(A). 2. §§182(a)(2) and (f) require RACT in nonattainment areas for all major sources of VOC and NOx and all sources that meet the applicability requirements of a CTG. 3. The Bluebook describes a  5% equivalency rule  that allows rule applicability that varies slightly from the presumptive RACT. http://www.epa.gov/oar/oaqps/ozonetech/voc_bluebook.pdf
. 4. CTGs and other EPA policy documents have further guidance on spec ific source categories. For example, Exemption for Low-Use Coatings , signed by G.T. Helms on August 10, 1990, allows exemption of up to 55 gallons/year of high-VOC coatings. http://www.epa.gov/oar/oaqps/ozonetech/luc_memo.pdf. 5. State Implementa

tion Plans: Policy R

egarding Excess E

missions During Malfu

nctions, Startup, and Shutdown, memo from Steven Herman (OECA) and Robert Perciasepe (OAR), EPA, September 20, 1999. http://www.epa.g ov/ttncaaa1/t1/me

ta/m12554.html
. Suggestions for Deve

loping Approvable Pr

ovisions 1. Rules affecting major sources in nonattainment areas generally cannot exempt activities subject to relevant CTGs or other presumptive RACT without demonstrating compliance with the 5% equivalency rule. 2. Exemptions for activities subject to other federal requirements (e.g., RACM) should be accompanied by a demonstration that the federal requireme nt has been met. 3. Waivers or exemptions from requirements during startup, shutdown, malfunction and related conditio

ns must comply

with EPA  s September 1999 po licy on excess emissions. Example Provisions Needing Support Demonstration 1. For purposes of this rule, organic liquid loading facilities are those facilities which load more than 20,000 gallons/day of organic liquids with a true vapor pressure of at least 1.5 psia at loading condit

ions.- 4 -

EPA's CTG for Bulk Gasoline Plants exempts facilities which load less than 4,000 gallons/day. The example exemption level of 20,000 is not approvable in nonattainment areas without demonstrating compliance with the 5% equivalency rule. 2. Paragraph (b) (1) shall not ap ply to coatings with se

parate formulations t

hat are used in volumes of less than

20 gallons per year

provided that the to

tal usage by a facili

ty is less than 200 gallons of such formulations applied annually. EPA recognizes exemptions of 55 gallons/year total of high VOC coating ( e.g., G.T. Helms  August 10, 1990 memo). The above provision, in contrast, exempts up to 200 gallons/year and is not approvable in nonattainment areas without demonstrating compliance with the 5% equivalency rule.- 5 -



### Coating and Ink VOC C ontent Units The units for limits on VOC content of coatings and inks must be clear and enforceable. National Regulation/Policy/Guidance 1. The Bluebook. http://www.epa.gov/oar/oaqps/ozonetech/voc_bluebook.pdf
. 2. A Guideline to Surface Coating Calculations , EPA-340/1-86-016, July 1986. http://www.epa.gov/oar/oaqps/ozonetech/guide_sco.pdf
. 3. A Guideline for Graphic Arts Calculations , EPA-340/1-88-004, June 1988. http://www.epa.g

ov/clariton/clhtm

l/pubtitle.html
. 4. Model VOC Rules for RACT (staff working document), EPA/OAQPS, June 1992. http://www.epa.gov/oar/oaqps/ozonetech/voc_modelrules.pdf
. Suggestions for De

veloping Approvable P

rovisions 1. Coating VOC content limits are generally expressed in units of weight of VOC per volume of coating, less water and exempt compounds, as applied. Many ink and adhesive VOC limits are also expressed this way. 2. Solids-based units (e.g., weight VOC per volume solids) are also often appropriate (e.g., when add-on control is a compliance option), and generally must be used when allowing compliance with VOC limits by averaging. Weight VOC per weight solids units may also be appropriate for some coatings and graphic arts operations. (See referenc e 3.) 3. Weight VOC per volume material, without subtracting water and exempts, can be used for limits on materi

als without solids, lik

e clean-up solve

nts and lithographi

c fountain solutions. Alternative units for low-solids coatings (e.g., less than 10% by weight of the material is solids), however, should be evaluated on a case-by-case basis. Example Approvable Equa tions 1. VOC content of coatings less water and exempt compounds, as applied, shall be determined using the test methods in paragraph X and calculated as follows:

VOC Content = where:- 6 -

Dc = density of coating. Wv = weight fraction volatile content of coating. Ww = weight fraction water
. Wei = weight fraction exe mpt solvent i. Dw = density of water. Dei = density of exemp t solvent i.
2. VOC content of coatings less water and exempt compounds, as applied, shall be determined using the test methods in paragraph X and calculated as follows: VOC Content = (Ws - Ww - Wec)/(Vm - Vw -

Vec), where Ws = grams of all volatile compounds evolv

ed during analysis. Ww = grams of water evolv ed during analysis. Wec = grams of exempt c ompounds evolve

d during analysis. Vm = liters of coating and/or ink, including any thinners and diluents applied. Vw = liters of water evolv ed during analysis. Vec = liters of exempt c ompounds evolve

d during analysis.
3. Other equations must be used for determining compliance with VOC content limits by averaging or with limits using other units (e.g., solids-based limits).- 7 -



### Compliance Periods and Averaging Times All SIP requirements are associated with one or more compliance time frames. For example: 1. Some facilities ar

e limited in the pound

s of pollutant they ma

y emit per hour

and the hours they may operate per year . 2. Certain information must be recorded once an hour and maintained for five years
. 3. Some compliance te sts must be perform

ed at least once every year . National Regulation/Policy/Guidance 1. Averaging Times for Compliance with VOC Emission Limits - SIP Revision Policy , memo from John R. O'Connor, EPA/OAQPS, January 20, 1984, published as Appendix D of EPA s Emissions Trading Policy Statement, 51 FR 43857, December 4, 1986. 2. 40 CFR 51, Subpart U - Economic Incentive Programs, 59 FR 16690, April 7, 1994. 3. Improving Air Quality with Economic Incentive Programs , EPA-452/R-01-001, January 2001. http://www.epa.g

ov/ttncaaa1/t1/me

ta/m1201.html
. 4. Compliance periods and averaging times should not interfere with the enforceability of emission limits as required in §110(a)(2)(A). Suggestions for De

veloping Approvable P

rovisions 1. Compliance time frames should be clearly specified. Where they are not, such as many emission rate limits (e.g., ppmv) and VOC content limits (e.g., lb/gal), EPA assumes instantaneous and continuous compliance is required. 2. Rule compliance p eriods generall

y must be consistent

with the applicabl

e NAAQS time frame. Since the ozone NAAQS is based on one-hour levels recorded over 24-hours, for example, VOC req

uirements should ha

ve daily or shorte

r compliance per

iods. 3. Provisions that allow compliance demon

stration by avera

ging a series of me

asurements over time should clearly specify: a. The frequency o

f measurements. b. Whether averages are arithmetic or weighted. c. Whether averages are calculated on a calender (e.g., daily average examines each day, midnight to midnig

ht) or rolling (e.g., midnight to midnight, 1am to 1am, 2am to 2am, etc.) basis.- 8 -

4. As described in the 1984 O Connor memo, VOC emission limitations with averaging longer than 24-ho

urs may be permitte

d under the follow

ing conditions: a. Daily limits are infeasible. b. Actual emissions (based on historical data) are consistent with relevant RACT/BACT control levels. c. Averaging is no lon ger than 30 days. d. Averaging will not jeopardize atta

inment or RFP require

ments. Agencies mu

st demonstrate that t

he maximum daily emi

ssion increase c

aused by the aver

aging is consistent with the area s approved ozone SIP. Nonattainment areas without approved SIPs can

not be considere

d for long term ave

rages. 5. Longer than 24-ho ur averaging in e

conomic incentive

programs genera

lly must comply with 40 CFR 51 Subpart U , including: a. 10% or other environmental benefit (51.493(a)(1)). b. A statistical showi ng that the avera

ging is consistent wi

th the NAAQS and RFP (51.493(d)(2)(ii)). c. A statistical showing that the averaging is equivalent on a daily basis to sourcespecific RACT requirements (51.493(d)(2)(ii)). d. A demonstration that the enforcement mechanisms for averaging provide equivalent incentives for compliance (51.493(i)(1)(i)). e. Other EIP requir

ements.- 9 -



### Alternative Controls and Alternative Methods of Co mpliance Some regulat ions allow alternativ e methods for meeting em ission li mits incl uding - equivalency provisions, alternative emission control plans (AECPs) and cross-line averaging. Variances are another alternative me thod of compliance that must meet additional administ

rative require

ments. National Regulation/Policy/Guidance 1. 40 CFR 51 Subpart U de scribes Economic

Incentive Pr

ogram (EIP)

requirements. 2. Improving Air Quality with Economic Incentive Programs , EPA-452/R-01-001, January 2001. http://www.epa.g

ov/ttncaaa1/t1/me

ta/m1201.html
. 3. Industry-specific national guidanc e that describes averaging provisions, such as Compliance with VOC Emission Limitation for Can Coating Operations (45 FR 80824, Decem ber 8, 1980) and se veral CTGs, genera lly tak es pre ceden ce ove r the g eneri c EIP guidance in items 1 & 2 above. Such industry-specific guida nce should not, however, be used to develop averaging provisions in SIP rules for other industries. Suggestions for Deve

loping Approvable Pr

ovisions 1. Provisions that allow alternative compliance with emission limits by providing equivalent or greater em

ission reductions th

rough control e

quipment or other m

ethods must clear

ly and completely specify the test methods, ca lculations and any other methodology ne eded to demonstrate equivalence, including capture efficiency where appropriate. 2. AECPs (a.k.a., equivalency, compensating reduction or bubble) and e conomic incentive (e.g., emission trading) programs allow over-compliance at one operation to offset undercompliance at another. These provisions generally should comply with 40 CFR 51 Subpart U. Common deficiencies include director  s discretion, averaging beyond 24- hours, incomplete methodology for determining equivalency (e.g., no emission quantification pr

otocols), and lac

k of 10% or other e

nvironmental bene

fit. 3. To protect sources from potential federal enforcement for violating the SI P, variances (a.k. a., va rianc e orde r, wai ver, o r cond itio nal pe rmit) tempo raril y suspe nding SIP requirements can be submitted for action by EPA as source specific SI P revisions. Such submittals must demonstrate that the variance meets all relevant CAA requirements. State/local agencies should contact EPA before submitting variances or variance rules f or inclusion into the SIP.- 10 -

Example Approvable

Provisions 1. A person shall not app ly any coating with a

VOC content in exc

ess of the specifie

d limits unless emissions to the atmosphere are controlled to an equivalent level by air pollution abatement equipment with a combined capture and control efficiency of 80 percent or greater. Calculations, test methods and recordkeeping shall be performed as prescribed in Section X. 2. The requirements of Section Y shall not apply to any coating line which complies with the following requireme

nts: a. Emissions of VOCs, determined using a daily weighted average, shall not exceed the amount which would result if the coating line complied with all VOC content limits of this rule. b. In order for two or more coatings to qualify for inclusion in a daily weighted average calculation, the coatings must be used on the same coating line and/or operation, and the coatings must be regulated under the same emission limit (e.g., both adhesive prim

ers subject to 3.5 lb

s VOC/gal material)

, and the coatings mu

st be applied on the same day. c. Calculations, test me thods and recordke

eping shall be perfo

rmed as prescribe

d in Section X.- 11 -



### Recordkeeping Recordkeeping requirements must be sufficient to assure continual compliance with VOC content limits, fuel specifications, rule applicability, exemption levels, emission caps, and other operating and emission requirements. National Regulation/Policy/Guidance 1. The Bluebook. http://www.epa.gov/oar/oaqps/ozonetech/voc_bluebook.pdf
. 2. Recordkeeping Guidance Document for Surface Coating Operations and the Graphics Arts Industry, EPA 340/1-88-003, July 1989. http://www.epa.gov/oar/oaqps/ozonetech/sco_ga.pdf
. 3. Exemption for Low-Use Coatings , memo from G.T. Helms, EPA, August 10, 1990. http://www.epa.gov/oar/oaqps/ozonetech/luc_memo.pdf
. 4. 40 CFR 70.6(a)(3) a nd (c)(1) requi

re periodic monito

ring in Title V perm

its. Suggestions for De

veloping Approvable P

rovisions 1. Recordkeeping requirements should be clear, explicit and independently enforceable. Where a daily log is needed, for example, rules both should explicitly require the log and should specify the frequency and units of each parameter to be recorded. 2. Recordkeeping time frames and units should be consistent with operating and emission requirements. Ho

urly BTU limits, for e

xample, genera

lly must be supporte

d by hourly BTU records. 3. While continuous recordkeeping is required of some activities (e.g., power plant emissions), no less frequent than daily records are generally needed to support the Clean Air Act provision f

or daily violations.

In the few case

s where EPA has al

lowed less frequent (e.g. , weekly) recor dkeeping, rules s

hould specify that

violations of the we

ekly requirement are presumed to be separate violations for each day within the week. 4. Rules that establish VOC content limits on

materials (e.g.,

coatings), but do n

ot establish emission or use caps, can allow monthly recordkeeping for sources using only compliant materials. Complia

nce with VOC conte

nt limits by averagi

ng or trading, howe

ver, must be supported by daily or more frequent recordkeeping. Compliance by add-on control equipment must be su

pported by recor

dkeeping appropr

iate to the specif

ic equipment, which generally includes hourly or daily records of key operating parameters. VOC content records should be required to include all thinners, solvents and other additives as applied.- 12 -

5. EPA has approved s ome coating rules

that do not specify

recordkeeping

associated with the general CTG size cutoff that applies CTG requirements only to sources with total VOC emissions greater than 10 ton/year potential or 15 lb/day and 3 lb/hr actual. In general, however, small sources should maintain records sufficient to demonstrate that they have not exceeded this applicability threshold. 6. Daily or as-used (recording use each day material is used) records are r equired for sources that are larger than the general CTG size cutoff, but that comply with a 55 gal/year or other non-compliant material exemption. 7. SIP rules should req uire that all rec

ords be maintaine

d for at least 2 ye

ars. Note that Titl

e V permits and MACT standards require 5 year record maintenance.- 13 -



### Test Methods SIP rules must specify all sampling and analy sis methods needed to determine compliance with the rule. National Regulation/Policy/Guidance Rules must specify test methods to meet the general enforceability requirement of §110(a)(2)(A). Suggestions for Deve

loping Approvable Pr

ovisions 1. As appropriate, SIP rules can reference or repr int EPA air test methods located in:

### " 40 CFR Part 51, Appendix M (SIP methods).

### " 40 CFR Part 60, Appendix A (EPA Reference Methods).

### " 40 CFR Part 60, Material Approved for Incorporation by

Reference (ASTM methods). Only those specific ASTM methods which appear in 40 CFR 60 are approved for use

in SIPs.

### " 40 CFR Part 61, Appendix B (HAP methods).

### " 40 CFR Part 63, Appendix A (MACT methods). 2. EPA methods used in o ther media, such a

s SW-846 for solid wa

ste, are not autom

atically approved for air pollution applications. 3. All other test methods must be evaluated and approved by EPA before a rule conta ining the test method ca

n be approved into

the SIP. Regio

n IX maintains

a list of California methods that have been approved for SIPs. Submittal of test methods for EPA approval should include the i

nformation and fo

llow the procedur

e described in Re

gion IX's "Test Method Review & Evaluation Process.  EPA has approved SIP rules that refe r to specific ASTM methods that are not directly tied to criteria pollutant emissions (e.g., gloss of paints) without full method evaluation. 4. References to EPA-approved ASTM methods should include the full title and date of the version being specified. 5. References to EPA-approved state or local methods should include the full title but may or may not specify the date of the version. 6. If a SIP rule lists more than one EPA-approved test method for determining compliance, the rule must also state that a violation determined by either test method shall constitute a violation of the rule.- 14 -



### Transfer Efficiency (TE) Transfer efficiency requirements are included in some coating regulations and can be defined as the following ratio:

Generally , total coating us

e and VOC emissions

decrease as TE

increases. National Regulation/Policy/Guidance 1. A Guideline for Surface Coating Calculations(EPA-340/1-86-016, July 1986) contains sample TE calcula

tions. http://www.epa.gov/oar/oaqps/ozonetech/guide_sco.pdf
. 2. Past efforts such

as TE tables in sev

eral NSPS (e.g.,

40 CFR 60 Subpart EE)

attempted to assign generic TE values to coating application methods. Changes in operating parameters sig

nificantly a

ffect TE, howev

er, and the gen

eric values wer

e rarely meaningful because of the variety of substrate shape , size and other real-world operating conditions. As a result, TE test protocols generally must be custom designed and consider all par

ameters of spec

ific operations. 3. Http://www.epa.g ov/etv/04/04_main.

htm summarizes TE rese

arch on some spec

ific coating equipme

nt. This information

should not be used to

show compliance w

ith specific TE requirements, but may help determine relative effic iency of different equipment. Suggestions for Deve

loping Approvable Pr

ovisions 1. Many rules specify acc eptable coating methods rather than a TE requirement. 2. SIP rules can specify TE values for alter native coating methods if test protocols to verify TE are approved by EPA. Two generic EPA-a pproved TE protocols are  Spray Equipment Transf

er Efficiency

Test Procedure f

or Equipment User

s  (South Coast Air Quality Mana

gement District

, 5/24/89), and a pr

otocol described

in the  Automobile Topcoat Protocol Document  (EPA-450/3-88-018). EPA was able to develop the latter protocol because TE is relatively stable at automobile assembly plants where identical items are continuously coated with automated equipment and few kinds of coatings. 3. ASTM methods which address TE and may be useful in developing source-spe cific TE protocols include:
a. D5286-95 Standard Test Methods for Determination of Transfer Efficiency Under General Product

ion Conditions for Spr

ay Applica

tion of Paints.- 15 -

b. D5327-97 Standard Practice for Evaluating and Comparing Transfer Efficienc y Under General

Laboratory

Conditions. c. D5066-91(1996) Standard Test Method for Determination of the Transfer Efficiency Under Production Conditions for Spray A pplication of Automotive Paints-Weight Ba

sis. d. D5009-96 Standard Test Method for Evaluating and Comparing Transfer Efficiency

of Spray App

lied Coatings Unde

r Laborator

y Conditions.- 16 -



### Capture Efficiency Capture efficiency is the fraction of emissions genera ted by a process that is directed to a control device. National Regulation/Policy/Guidance 1. Guidelines for Determining Capture Efficiency (January 9, 1 995), incorpora ted in an EPA memo signed by John Seitz titled,  Revised Capture Efficiency Guidance for Control of Volatile Organic Compound Emissions  (February 7, 1995). http://www.epa.g

ov/ttncaaa1/t1/me

ta/m28508.html. 2. Rules that reference older c apture efficiency guidance (e.g., 40 CFR 5 2.741 or 55 FR 26865 of June 29, 1990) should be updated. The 1995 guidance corrects errors in earlier guidance and provides greater flexibility in meeting test re quirements. Suggestions for Deve

loping Approvable Pr

ovisions 1. Both capture efficiency and control device e fficiency (or emission limit) must be specified when r

egulating emissions with add-on c ontrol equipment. 2. Rules must specify both the test method

s and the calcula

tion procedures t

o be used to determine capture efficiency. Refere nce to 40 CFR 51 Appendix M, which contains relevant EPA test methods, is not sufficient without also describing calculation procedures or referencing EPA  s 1995 guidance. 3. Rules may specify a single c ombined capture and destruction efficiency if the methods for determining it are clear. 4. SIP submittals should describe how capture and control requirements were established. Example Approvable Provision Sources must install

and operate an emi

ssions control syste

m designed and ope

rated to capture at least 90% of all VOC emissions from affected units and to direct them to a control device designed and operated at 90% destruction efficiency or greater.

### " Capture efficiency shall be determined according to US EPA  s  Guidelines for Determining Captur

e Efficiency,  (January 9, 199 5) and 40 CFR 51, Ap

pendix M, Methods 204-204F as applicable.

### " Destruction efficiency shall be determined by 40 CFR 60, Appendix A, Methods 18, 25 or 25A.- 17 -



### Director's Discretio

n Director's Discretion allows the state to approve alternatives to the applicable SIP without follo wing t he SIP -revi sion p roces s desc ribed in §11 0. Ina pprop riate Direc tor s Discretion has ap

peared in a wide

variety of state r

ule provisions incl

uding those regarding applicability, emission limits, operating requirements, recordkeeping, monitoring, test methods and alternative compliance. National Regulation/Policy/Guidance 1. §110(a)(2)(A) requires that SIP regulations are enforceable. 2. 52 FR 45109 (Nove mber 2 4, 198 7) sta tes EP A s gen eral p olicy regar ding d irect or s discretion. Suggestions for De

veloping Approvable P

rovisions 1. Director s Discretion may be appropriate if explicit and replicable proce dures within the rule tightly define how the discretion will be exercised to assure equivalent emission reductions. 2. Director s Discretion may be appropriate for provisions that do not fulfill or support any federal SIP requirement. 3. Director s Discretion may be appropriate if each exerc ise of discretion is approved by EPA. Example Approvable P

rovisions 1. Inclusion of replicable procedures. In many cases, such provisions do not need to require the Director  s approval, parti cularly those suc

h as example (b) b

elow where the r

ule provides clear d

iscrete complian

ce choices.
a. A person shall not use any coating with a VOC content in excess of the limits in Section E unless all coating emissions from the facility are controlled by air pollution abatement equipment which ha

s been approved in

writing by the APCO an

d which has an overa

ll control efficiency of at least 85%. Overall control efficiency shall be determined according to Section F. Test methods and the 85% standard provide the replicable procedure. Note that the SIP submittal to EPA must demonstrate that 85% is equivalent to the emission limits.- 18 -

b. For cold cleaning, one of the these devices approved by the APCO must be used: (i) a freeboard with a freeboard ratio equal to or greater than 0.75, or (ii) a water cover

if the solvent is inso

luble and heavier

than water. 2. Discretion for provisions that do not fulfill or support any federal SIP requirement. Some dry cleaning rules regulate both perchloroethylene and petroleum solvent processes. Dire

ctors Discretion

for perchloroe

thylene provisions

could be approve

d into the SIP since EPA co

nsiders perchlor

oethylene an exe

mpt VOC and does not r

equire its control in the SIP. Note that such discretion may cause other problems, if the perchloroethyle

ne provisions are

intended to impleme

nt §112 MACT standar

ds. 3. Discretion approved by EPA. This Section shall not apply to any person who complies with an alternate recordkeeping plan that provides for an enforceable daily record which has been submitted to and approved by the APCO, ARB and EPA.