DEPARTMENT OF ENVIRONMENTAL QUALITY 

Chapter 340 

Proposed Rulemaking 

Adoption of Air Quality Permit Program Streamlining and Updates 

Additional Information on Proposed Rule Changes: Proposed Rule Summary 

Summary of Proposed Rule Changes

1. General Definitions 

Proposed changes would relocate several definitions to the General Air Quality Definitions 

section to make it clear that they apply to all air quality rules. Revisions to the definition of 

“particulate matter” would improve the cross reference to DEQ’s Air Quality Source 

Sampling Manual and specify test methods. 

2. Delisting HFE-7300 as a VOC

The proposed changes would add HFE-7300 to the list of compounds exempt from the 

definition of volatile organic compounds (VOC). According to EPA research, this substance 

has negligible reactivity and very low potential to form ground-level ozone or smog. HFE7300 has a variety of potential uses including as a heat-transfer fluid and in coating, cleaning, 

and lubricating applications. This change should benefit air quality in Oregon, because 

exempting HFE-7300 will allow the Department to focus VOC reduction strategies on 

compounds that are more responsible for forming ground-level ozone or smog. Delisting 

will likely have an additional environmental benefit because HFE-7300 can be used in place 

of substances that deplete the earth’s protective ozone layer and substances with high global 

warming potentials. 

 

3. Revisions to Standards for Clackamas, Columbia, Multnomah, and Washington Counties 

The proposed changes would repeal outdated and redundant requirements. The Storage and 

Handling of Petroleum Products section in OAR 340-208-0560 is redundant with existing 

New Source Performance Standards (NSPS) and vapor control requirements in OAR 340-

242-0520. The Sulfur Dioxide Emission Standard in OAR 340-208-0630 is redundant with 

existing fuel oil sulfur content limits and Kraft Pulp Mill regulations. These changes would 

result in the removal of unnecessary permit conditions and are not expected to affect air 

quality or rule stringency. 

4. Revisions to make Title V procedural rules consistent with federal Part 70 requirements, and 

improve administration

In 2004, EPA began a comprehensive review of DEQ’s Title V Operating Permitting 

Program. In June 2006, EPA identified several areas where DEQ needed to change its rules 

for better alignment with federal requirements. Aligning DEQ regulations with federal Part 

70 requirements would maintain clarity, enforceability, and continued federal approval of the 

Title V Program. The revisions would improve administration of the Title V Program by 

ensuring a full description of the comment procedures in public notices, and clarifying the 

process for responding to comments prior to issuance or denial of a permit. The proposed 

revisions would also clarify that for facilities with Title V or Air Contaminant Discharge 

Attachment B, p. 1 
Permits (ACDPs), requirements established in preceding permits remain in effect unless 

specifically modified or terminated. The proposed revisions would satisfy federal 

requirements by updating the description of which facilities are exempted from the 

requirement to obtain a Title V Permit. Additional rule revisions in response to federal 

requirements would allow reporting or source testing dates to be changed by administrative 

permit amendment if a facility or parts of a facility are not operating, and disallow treatment 

of baseline and Plant Site Emission Limit (PSEL) corrections as administrative permit 

amendments. 

DEQ also identified several streamlining improvements for Title V Permitting. These 

proposed revisions would eliminate redundancy by limiting the information needed in 

renewal applications to new or changed information only, decreasing the number of required 

application copies from four to three, and directing applicants to submit a copy of monitoring 

reports to DEQ regional offices. The Department does not expect these changes to affect air 

quality or rule stringency, but they may result in minor efficiencies for permitted facilities. 

5. Revisions to make Excess Emissions rules consistent with federal Part 70 requirements

In its 2006 Title V Program Review, EPA identified several deficiencies in DEQ’s Excess 

Emissions rules. Revisions to these rules would achieve two main objectives. First, they 

would clarify that the affirmative defense of emergency does not take away DEQ’s 

enforcement discretion, but is relevant when evaluating a violation to determine the level of 

penalty. Second, the revisions would consolidate the notification and reporting requirements 

and the criteria for demonstrating emergency as an affirmative defense. These changes 

would improve enforceability and ensure continued Title V Program and State 

Implementation Plan (SIP) approval. The proposed revisions would make DEQ’s rules 

consistent with 40 CFR part 70 requirements and also EPA SIP guidance. The EPA SIP 

guidance is contained in a September 20, 1999 memorandum titled “State Implementation 

Plans: Policy Regarding Excess Emissions During Malfunctions, Startup, and Shutdown” 

from Steven A. Herman, Assistant for Enforcement and Compliance Assurance, and Robert 

Perciasepe, Assistant Administrator for Air and Radiation. 

6. Changes to Basic Permit Categories

The proposed changes streamline the ACDP permitting program by eliminating basic permit 

categories with limited potential for environmental harm. In 2001, DEQ instituted 19 Basic 

Permit categories to track small air emission sources. DEQ intended that basic permits 

function as a registration, or means to track sources with potential to grow or require a 

different type of permit and to trigger control requirements. The purpose was to anticipate 

emission increases and reduce potential for source violations. DEQ has determined that there 

is little to no environmental benefit from tracking the 12 basic permit categories proposed for 

deletion. 

The existence of unused basic permit categories results in lack of clarity about whether 

various small facilities must obtain basic ACDPs. Deleting the unused permit categories will 

eliminate confusion and align the rules with current program implementation. To date, DEQ 

has only issued basic permits to source categories that required ACDPs before the 2001 

rulemaking. Because no basic permits have been issued in the 12 categories proposed for 

Attachment B, p. 2 
repeal, this action would not result in termination of any existing permits. A general 

provision in the ACDP rules ensures that any facility with significant emissions is regulated 

through a permit. OAR 340-216-0020 Table 1 (B)(75) requires permits for all sources not 

otherwise listed with emissions of five or more tons a year of PM10 in a PM10 nonattainment or maintenance area, or 10 or more tons of any single criteria pollutant in any part 

of the state. 

7. Update and Renewal of General Permits for Rock Crushers, Ready Mix Concrete Plants, 

Asphalt Plants, Sawmills/Plywood/Veneer Plants, Boilers and Crematories

DEQ proposes to adopt by reference updates and corrections to six categories of general 

permits. Since these permits were originally issued in 2001, the Department has identified 

various errors in need of correction. These changes will clarify monitoring, reporting and 

compliance procedures, and are not expected to affect air quality or rule stringency. 

8. SO2 Averaging

To align with federal standards, DEQ proposes to change the averaging time in the sulfur 

dioxide standards for fuel-burning equipment from two to three hours. The averaging time is 

the period during which measurements are taken to determine compliance with a standard. 

Measurements of a pollutant are averaged for comparison to the standard. Currently, some 

facilities must demonstrate compliance with both two and three hour averaging periods. 

DEQ does not expect this change to affect air quality or rule stringency. It will simplify 

compliance determinations by eliminating duplicative standards. 

9. Salt Laden Wood Exception

This proposal would add a requirement that the existing salt laden wood waste exemption is 

applicable only upon prior notice to DEQ. When burned, salt laden wood has higher 

emissions than “standard” wood. High salt content is caused by floating logs in salt water as 

a means of transportation. While this was a common practice 30 years ago, it is now a rare 

event. This proposal would allow the Department to have knowledge of this exemption so it 

can assure compliance with the appropriate standard. 

10. Utility Mercury Rule Corrections

 On December 15, 2006, the Environmental Quality Commission adopted the Utility Mercury 

Rule which opts Oregon into the national mercury cap-and-trade program through 2017, 

requires coal-fired power plants in Oregon to install mercury controls in 2012, and opts 

Oregon out of the national cap-and-trade program starting in 2018. As a result of opting out 

of the national cap-and-trade program, mercury emissions from coal-fired power plants in 

Oregon are capped at 60 pounds per year in 2018 and thereafter. The rule distributes the 60 

pound cap among the existing Boardman plant and new plants, with the Boardman plant 

capped at 35 pounds of mercury per year and all new plants capped at a combined 25 pounds 

of mercury per year. 

Since the adoption of the Utility Mercury Rule, DEQ has discovered that the method of 

distribution of the 25 pound mercury emission cap for new plants is flawed. Currently the 

Utility Mercury Rule distributes Oregon’s mercury emissions cap for new plants based on 

relative plant size. Under this distribution system, as new plants come on line, they could 

Attachment B, p. 3 
potentially take a portion of the mercury allocation away from an existing plant putting the 

existing plant into non-compliance due to no fault of their own. This allocation method used 

by the federal Clean Air Mercury Rule makes sense when associated with a trading program 

because a plant could just purchase extra credits, but it creates problems in the absence of 

trading. It could also create unexpected and unavoidable non-compliance for the existing 

plant. 

For instance, a 500 megawatt plant might be given a 25 pound mercury cap when it starts up. 

Then if a new 200 megawatt plant was built the credits would be redistributed based on plant 

size: the 500 megawatt plant would get 18 pounds and the 200 megawatt plant would get 7 

pounds. The 500 megawatt plant would be seven pounds short of what it needs to operate. 

The proposed corrections to the Utility Mercury Rule would require DEQ to distribute 

Oregon’s mercury emissions cap for new plants on a first-come-first-served basis. This 

would ensure more equitable distribution of the mercury emissions cap for new plants and 

would not affect air quality or rule stringency. 

Additional revisions to the Utility Mercury Rule correct cross references. 

 

11. Revisions to Incinerator Rules

Proposed revisions to the incinerator rules would clarify and consolidate definitions and 

clarify the requirements for operating crematory incinerators. These revisions would be 

consistent with current implementation and rule interpretation. There will be no increase in 

workload for permitted sources or the Department and the changes are not expected to affect 

air quality or rule stringency. 

12. Wigwam Prohibition

Because wigwam waste burners cannot be operated in compliance with other air quality 

regulations, DEQ proposes to repeal outdated regulations governing wigwam burners 

and prohibit their use statewide. The proposed revisions would specify that wigwam waste 

burner emissions not be subtracted from the netting basis in rare cases where wigwam 

burners were actually operated at facilities during the baseline period. These changes are not 

expected to affect workload, air quality or rule stringency. 

13. Revisions to Kraft Pulp Mill Rules

The Department adopted the Kraft Pulp Mill Rules in 1973. Since then, EPA has 

promulgated New Source Performance Standards (NSPS) for kraft pulp mills. Process units 

at some mills were modified after the NSPS applicability date, making those units subject to 

the NSPS. Several sections of the Kraft Pulp Mill Rules are redundant for mills with process 

units that are subject to the NSPS. As a result of these redundancies, Title V permits now 

include multiple permit conditions that set similar requirements the same emission sources 

and pollutants. Revisions would streamline the Kraft Pulp Mill Rules by eliminating 

redundancies. The revisions would also simplify permitting and compliance determinations 

and eliminate unnecessary reporting. There could be a minimal decrease in workload for 

DEQ and permitted sources. These changes are not expected to affect workload, air quality 

or rule stringency. 

Attachment B, p. 4 
 

14. Simplified Emission Standards for Plywood, Particleboard and Hardboard Manufacturing 

Operations

The current board product standards are confusing. In one section the standards are based on 

square foot of product, but in another section the standards are hourly emission limits based 

on maximum production rates. As a result, these standards have been interpreted 

inconsistently for many years. Proposed revisions to these standards would clarify emission 

requirements for plywood, particleboard and hardboard manufacturing facilities by 

specifying uniform measurements and compliance methods. These revisions would facilitate 

permitting and are not expected to affect air quality or rule stringency. 

15. Changes to Emission Standards for Specific Industries

Proposed changes to these rules would consolidate definitions and clarify them for 

consistency with other divisions. These changes are not expected to affect air quality or rule 

stringency. 

Table 1: Description of Proposed Changes 

Topic Rule Citation Description of Proposed Change 

General Definitions 340-200-0020 

(11) 

(78) 

(83) 

(130) 

- “Ambient Air” 

Relocates definition and clarifies exclusion for 

areas to which the general public has no access. 

 - “Opacity” 

Relocates definitions to the general section to 

apply to all air quality rules in divisions 200 

through 268. Deletes reference to Director’s 

discretion to allow alternatives to emission 

limits, testing or monitoring methods in federal 

rules or the State Implementation Plan without 

prior EPA approval. 

- “Particulate Matter” 

Clarifies cross reference to Source Sampling 

Manual, clarifies test methods. Redundant 

definitions of “Particulate Matter” in other 

sections are deleted (340-228-0020). 

- “Source Test” 

Deletes reference to Director’s discretion to 

allow alternatives to emission limits, testing or 

monitoring methods in federal rules or the State 

Implementation Plan without prior EPA 

approval. 

Delisting HFE-7300 as a 340-200-0020 (143) - Adds HFE-7300 to the list of volatile organic 

Attachment B, p. 5 
VOC compounds that are not subject to regulation as 

ozone forming compounds because of a very 

low tendency to react with sunlight to form 

ozone. 

Revision to definition of 

“fuel burning equipment” 

340-208-0010(4) - Revises the definition of “fuel burning 

equipment” to ensure that the particulate 

standards in OAR 340-208-0610 and Divisions 

226 and 228 are applied correctly. The 

standards in 340-208-0610 and Division 228 

should not apply to equipment such as veneer 

dryers and particle dryers that may burn fuel 

but use dilution to control the temperature of 

the gas. These types of equipment are subject 

to the general particulate standards in Division 

226. The same is true for internal combustion 

engines. Gas turbines, for example, cannot be 

subject to the standards in 340-208-0610 and 

Division 228 because the exhaust gas stream is 

diluted by excess air. Divisions 208 and 228 

have a correction to 12 percent CO2 or 50 

percent excess air and are intended to apply 

only to boilers and process heaters with 

controlled, near stochiometric combustion. 

Revisions to Standards for 

Clackamas, Columbia, 

Multnomah, and 

Washington Counties 

340-208-0560 

340-208-0630 

- Deletes Storage and Handling of Petroleum 

Products section which is redundant with 

existing New Source Performance Standards 

(NSPS) and vapor control requirements in 340-

242-0520. 

- Deletes Sulfur Dioxide Emission Standard 

because of redundancy with existing fuel oil 

sulfur content limits and Kraft Pulp Mill 

regulations. 

Making Title V 

procedural rules consistent 

with federal Part 70 

requirements, and 

improving administration. 

340-209-0040 

340-209-0080 

340-216-0020 and 

0082 

 - Adds that public notices of proposed Title V 

Permit actions will include a description of 

procedures for making comments and 

requesting hearings. 

- For added clarity, moves procedures for 

responding to comments and taking action on 

Title V Permits into the rule section on 

Issuance or Denial of a Permit. 

- Clarifies that facilities with Air Contaminant 

Discharge Pemits (ACDPs) may not be 

Attachment B, p. 6 
340-216-0082 and 

340-218-0010 

340-218-0020 (4) 

340-218-0040 

340-218-0050 (3) 

340-218-0150 

operated if the permit expires or is terminated, 

unless a timely renewal application has been 

submitted or another type of permit has been 

issued. 

- Clarifies that for facilities with Title V or 

ACDPs, requirements established in preceding 

permits remain in effect unless specifically 

modified or terminated. Previous source 

specific emission reduction requirements must 

be incorporated into Title V Permits. 

- For consistency with federal regulations, 

updates description of which facilities are 

exempted from the requirement to obtain a 

Title V Permit. 

- Eliminates redundancy by limiting 

information needed on renewal applications to 

new or changed information. Decreases 

number of required application copies from 4 

to 3. 

- Directs applicants to submit a copy of 

monitoring reports to DEQ regional offices. 

Deletes requirement to submit the excess 

emissions log with the annual report because 

revisions to the Excess Emissions rule require 

submission within 15 days of an excess 

emissions event. Changes the definition of 

“prompt” to 15 days after a deviation. 

- Clarifies that reporting or source testing dates 

may be changed by administrative permit 

amendment if a facility or parts of a facility are 

not operating. Deletes baseline or Plant Site 

Emission Limit correction as an administrative 

permit amendment. 

Making Excess Emissions 

rules consistent with 

federal Part 70 

requirements 

340-214-0010 

340-214-0300 

- Clarifies that a “Large Source” is a facility 

required to maintain a Title V Permit, and a 

“Small Source” is a facility required to 

maintain an ACDP. 

- Broadens applicability of the Excess 

Emissions rule to include excess emissions 

caused by reasons other than those enumerated 

Attachment B, p. 7 
340-214-300(3) and 

(4) 

340-214-0310(3) 

340-214-0320(2) 

340-214-0330(4) 

340-214-0350 

340-214-360 

340-214-0330 

340-214-0340 

340-214-0360 

in the rule. 

- Aligns language with federal requirements by 

clarifying that the affirmative defense of 

emergency does not take away DEQ’s 

enforcement discretion, but is relevant when 

evaluating a violation to determine the level of 

penalty. 

- Consolidates notification requirements for 

excess emissions not addressed by planned 

startup and shutdown, scheduled maintenance 

or emergencies, in the All Other Excess 

Emissions section. 

- For clarity and ease of use, consolidates 

reporting requirements in one section. Many of 

the reporting requirements were located in the 

section on Enforcement Action Criteria. 

Clarifies that excess emission report must 

include whether a source followed approved 

procedures for startup, shutdown or 

maintenance activity when applicable. 

- Consolidates and further describes criteria for 

demonstrating emergency as an affirmative 

defense. 

Changes to Basic Permit 

Categories 

340-216-0020 Table 1 - To streamline permitting procedures, clarifies 

which facilities must obtain basic permits and 

update rules to current practices, deletes twelve 

unused Basic Permit categories: 

- Wood Furniture and Fixtures more 

than 5,000 but less than 25,000 board 

feet/maximum 8 hour input 

- Flour, Blended and/or Prepared and 

Associated Grain Elevators more than 

2,000 but less than 10,000 tons per year 

throughput. 

- Grain Elevators used for intermediate 

storage more than 1,000 but less than 

10,000 tons/yr. throughput. 

- Gray iron and steel foundries, 

malleable iron foundries, steel 

investment foundries, steel foundries 

more than one ton/yr. but less than 100 

Attachment B, p. 8 
tons/yr. metal charged (not elsewhere 

identified). 

- Millwork (including kitchen cabinets 

and structural wood members) more 

than 5,000 but less than 25,000 bd. 

ft./maximum 8 hour input. 

- Non-Ferrous Metal Foundries more 

than one ton/yr. but less than 100 

tons/yr. of metal charged. 

- Pesticide Manufacturing more than 

1,000 tons/yr. but less than 5,000 

tons/yr. 

- Sawmills and/or Planing Mills more 

than 5,000 but less than 25,000 board 

feet/maximum 8 hour finished product. 

- Seed Cleaning and Associated Grain 

Elevators more than 1,000 but less than 

5000 tons per year throughput. 

- Bakeries, Commercial baking more 

than 500 tons of dough per year. 

- Cereal Preparations and Associated 

Grain Elevators more than 2,000 but 

less than 10,000 tons per year 

throughput. 

- Coffee Roasters roasting more than 6 

tons coffee beans in a year, but less than 

30 tons/yr. 

Update and Renewal of 

General Permits for Rock 

Crushers, Ready Mix 

Concrete Plants, Asphalt 

Plants, 

Sawmills/Plywood/Veneer 

Plants, Boilers and 

Crematories 

340-216-0060(5)(g), 

(h), (i), (j), (k), and (l) 

- Adopts by reference updates and corrections 

to six categories of general permits. 

SO2 Averaging 340-228-0200 - To match federal standards, changes the 

averaging time for sulfur dioxide standards for 

fuel-burning equipment from two hours to 

three hours. 

Salt Laden Wood 

Exception 

340-228-0210 - Adds requirement for notice to the 

Department prior to using an existing 

exemption allowing a higher emission rate for 

burning salt laden wood waste. 

Utility Mercury Rule 

Corrections 

340-228-0672 - Fixes Oregon’s Utility Mercury Rule to direct 

the Department to distribute the 25 pound 

mercury emissions cap to new plants on a firstAttachment B, p. 9 
340-228-0673 

340-228-0674 

340-228-0676 

340-228-0678 

come-first-served basis. 

- Corrects cross references. 

Revisions to Incinerator 

Rules 

340-230-0030(13) (36) 

340-230-0030(32) 

340-230-0030(16), 

(37) and (38) 

340-230-0030(38) 

340-230-0200 

340-230-0210 

340-230-0220(2) 

340-230-0230 

- Deletes confusing “new” and “existing” 

definitions, places dates relating to 

requirements in regulations. 

- Deletes construction date in “Municipal waste 

combustor plant” definition, places dates 

relating to requirements in regulations. 

- Deletes “fugitive emissions”, “opacity” and 

“particulate matter” definitions because they 

are addressed in the General Definitions, 

Division 200. 

- Clarifies the “pyrolysis” definition by 

deleting references to hospital or medical 

waste. 

- Simplifies the opacity standard for crematory 

incinerators by changing it from an aggregate 

measurement of 6 minutes in 60 minutes to a 6 

minute period. 

- Clarifies crematory operating requirements 

for units built before and after March 13, 1993. 

- For continuity of recordkeeping, increases 

from one to two years the requirement to 

maintain crematory temperature monitoring 

records. 

- Clarifies compliance demonstration 

requirements by describing specific source test 

procedures and citations. 

Wigwam Prohibition 340-234-0100 through 

0140 

- Deletes outdated regulations governing the 

use of Wigwam Waste Burners and adds a 

prohibition statewide. Addresses rare historic 

cases in which wigwam emissions have been 

included in a source’s netting basis by 

specifying that these emissions shall not be 

Attachment B, p. 10 
subtracted from the netting basis. 

Revisions to Kraft Pulp 

Mill Rules 

340-234-0010(12) 

340-234-0010 (26)(a) 

340-234-210(1)(c)(B) 

340-234-210(1)(e)(A) 

340-234-220(2) 

340-234-230 

340-234-0240(1) 

340-234-0240(1)(c) 

340-234-0240(2)(c) 

340-234-0240(5) 

- In definition of “Daily Arithmetic Average” 

deletes reference to Director’s discretion to 

allow alternatives to emission limits, testing or 

monitoring methods in federal rules or the State 

Implementation Plan without prior EPA 

approval. 

- Adds additional exemptions to the list of 

“other sources” of Total Reduced Sulfur (TRS). 

Smelt dissolving tanks are covered by separate 

state limits. Sewers, drains and wastewater 

treatment facilities are not measurable sources 

of TRS. Categorically insignificant activities 

are very minor, difficult to evaluate and could 

include non-industrial sources such as 

restrooms. 

- Deletes a section which no longer applies to 

existing Kraft Mills in Oregon. 

- Deletes examples of “other sources” because 

this term is defined in the definitions section. 

- Consistent with current practice, clarifies that 

the Department may require that a Kraft Pulp 

Mill undertake an odor emission reduction 

study program. 

- Deletes section on submission of plans for 

construction and modification because general 

permitting regulations in Division 210 address 

these requirements. 

- Deletes general monitoring section which has 

been superseded by specific Title V monitoring 

requirements. 

- Clarifies that DEQ may require different vent 

sampling methods. 

- Deletes section requiring use of obsolete 

sodium ion probes. Federal NSPS 

requirements address opacity monitoring. 

- For clarity, states the existing requirement 

Attachment B, p. 11 
340-234-0250 

340-234-0260 

that new or modified sources subject to federal 

standards must conduct monitoring and source 

tests in accordance with these standards. 

Clarifies that DEQ may require relevant 

monitoring when it is more stringent than 

federal requirements. 

- Clarifies that mills must follow state-specific 

reporting requirements if required in permit by 

DEQ. 

- Deletes Upset Conditions section because 

these conditions are addressed both in the 

federal National Emission Standards for 

Hazardous Air Pollutants (NESHAPs) and 

Division 214 (Excess Emissions Rules). 

Simplified emission 

standards for plywood, 

particleboard and 

hardboard manufacturing 

operations 

340-234-0510(2) 

340-234-0520(2) 

340-234-0530(2) 

- Clarifies emission requirements for 

Board Products by specifying uniform 

measurements and compliance methods. 

Changes to Emission 

Standards for Specific 

Industries 

340-236-0010(6) 

340-236-0010(15) 

340-236-0010 (21) 

340-236-0010(22) 

340-236-0010(27) 

- Clarification of “collection efficiency” 

definition. 

- In definition of “fluorides” deletes reference 

to Director’s discretion to allow alternatives to 

emission limits, testing or monitoring methods 

in federal rules or the State Implementation 

Plan without prior EPA approval. 

- In definition of “particulate matter” deletes 

reference to Director’s discretion to allow 

alternatives to emission limits, testing or 

monitoring methods in federal rules or the State 

Implementation Plan without prior EPA 

approval. 

- Deletes “opacity” definition because it is 

addressed in the General Definitions, Division 

200. 

- Updates “source test” definition for 

consistency with other rules, adds reference to 

the Department’s Source Sampling Manual. 

Deletes reference to Director’s discretion to 

Attachment B, p. 12 
Attachment B, p. 13 

allow alternatives to emission limits, testing or 

monitoring methods in federal rules or the State 

Implementation Plan without prior EPA 

approval.