Response to comments on 1121 submittal 

Comment 1 : It is unclear if RI used the most current final rule entitles "Hazardous 

Air Pollutants : Amendments to the Approval of State Programs and Delegation of 

Federal Authorities," dated September 14, 2000 in preparing your package . It 

appears that RI used an earlier version of this regulation . Please update the 

citations to reflect the September 2000 regulation . 

Response: The citations in the submittal have been updated to reflect the 

September 2000 version . 

Comment 2 : It is unclear if RI used the most recent version of the Halogenated 

Solvent NESHAP in preparing your package. There was an amendment to this 

NESHAP on December 3, 1999 (64FR67801) that pertained to continuous web 

solvent cleaning machines (see enclosed) . Thus it appears that the following 

sections of the NESHAP were not addressed in RI's equivalency request: 

63 .469(g), 63 .463(e)(2)(ix), (x), (xi), 63 .463 (g)(h), 63.465 (f), (g), (h) and 

63 .467(a)(6)(7) : RI must access these sections for equivalency before EPA can 

make a final decision . 

Response : Currently there are no continuous web-cleaning machines in the 

state. If a continuous web-cleaning machine were to locate in the state they 

would first be required to obtain a preconstruction permit. Since section 

9 .3 .3(a)(5) of RI Air Pollution Control Regulation No . 9, "Air Pollution Control 

Permits," requires sources to be in compliance with all applicable state and 

federal air pollution control regulations, the permit would contain the 

requirements in the NESHAP . 

Comment: Regulation No 36 disallows the use of reduced room draft as a 

control option . Although it does make RI's rule more stringent and less flexible 

from the EPA perspective, we do not agree with your reason for denying this 

option, i .e., the potential for this practice to dramatically increase worker solvent 

exposure . The worker exposure issue was brought up during rule development 

to which EPA responded that installation and proper operation of our control 

combinations would reduce worker exposure . This is especially true for reduced 

room draft since with this technique the solvent vapor layer is less disturbed, 

therefore reducing vapor emissions, hence reducing worker exposure . Please 

provide additional clarification regarding your perspective on this issue. 

Response : While it is possible that, in some cases, reduced room draft may 

reduce worker exposure, there is also the potential for increased worker 

exposure under some conditions . Since many of the Rhode Island sources 

covered by this regulation are small and do not have sophisticated technical staff, 

RI DEM judged that the potential for problems was sufficient that it was 

preferable to not include this control option . Note that the RI regulation does not 
disallow the use of reduced room drafts -- it only disallows the use of reduced 

room drafts as a control option for compliance with this regulation . 

Comment: Please clarify the following on page 18 of the General Information 

document; it is not clear whether RI regulations require sources to determine a 

dwell time or whether the regulations defer to the degreaser NESHAP. 

Response : Sections 36.9, 36 .10 and 36.11 of the RI regulation include the 

requirements for dwell as follows : 

36.9.6 1f dwell or a superheated vapor system is used, the. actual dtivell time shall 

not exceed the rrrirtimurrt dwell time. Minimum and actual dwell time shall be 

determined using the following procedztres : 

(a) For units without cr superheated vapor systerrl, the rrrirtimurn dwell time 

shall he determined ,for each part type or parts basket or for' the most 

conrpleti part ty pe or parts basket using the following procedure: 

(1) 

(h) 

rc) 

Determine the amount of time necessar7~ for the part or- parts 

basket to cease dripping once placed in the vapor zone. The part 

or parts basket itsed f r this determination must be at, roora7 

temperature when placed in the vapor zone; and 

(2) The n7irriruurrr dwell time required./bi-parts to remain in the 

fi-eeboard zone above the vapor zone is calculated as 35 percent of 

the tirne determined in Paragraph (a)(1) of this subsection.. 

The minimum dwell time, for a cleaning machine equipped with a 

superheated vapor stistern shall he detennined according to the 

specifications of~the rncrnufiwturer of the control equipment; and 

On. a monthly hczsis, the actual dtivell time that parts are held in the 

fi-eehoarcl zone above the vapor zone shall be measured,- and 

(a') If the actual dwell time is less than the rninimurn dwell time determined 

Using the applicable procedure in Paragraph (a) or- (h) qf this subsection 

, fbr~ a particular part. or parts basket., the automatic parts handlings~vstem 

must he ucljtcstecl so~ that this specification is met. 

36.111.1 The owner or operator of'a batch vapor or in-line organic cleaning machine 

shall maintain the f'ollowing recor{ls f r the lifE:tirrre of the cleaning unit : 

(a') lf clivell or superheated vapor is used, the rnirrinrurn dwell times determined i1sing 

the procedures specified in Paragraph (a) or (b) c?f Subsection 36. 9.6: and 
3G.1 tJ .37hc owner or operator of cr batch vapor or in-line orgpnic cleaning machine shall 

maintain t.he,follotiving records, fir ci period, of five Years : 

(h) Resulls of~monitoring required under Section 36.9 ; and 

Comment: On page 7 of the General Information document there is a list of de 

minimis levels for apparent applicability to the RI regulations . The list includes 

1,1,1 trichloroethane with a permit threshold of 10 Ib/hour. Ten Ibs./hour could 

potentially be 43 plus tons per year of emissions . This is well over the HAP 

major source threshold and this provisions seems to allow sources emitting less 

than the 10 Ibs/hour threshold to be exempt from the degreaser regulations. 

Potentially some sources could get out of the RI rules that should not. However 

the next paragraph appears to close the exemption . Which provision applies or 

do they supercede each other. 

Response : Under the revised "Hazardous Air Pollutants : Amendments to the 

Approval of State Programs and Delegation of Federal Authorities," dated 

September 14, 2000 this section is no longer included and is not included in this 

submittal . However in response to the comment the de minimis levels pertain to 

permitting of sources, not to applicability to the degreaser regulation . Further, 

the permitting threshold for 1,1,1-trichloroethane (methyl chloroform) in APC 

Regulation No. 9, the permitting regulation, was altered effective April 2004 to be 

4,000 pounds per year. Since there is no small source exemption in Regulation 

No. 36, the degreasing regulation ,all degreasing sources are subject to that 

regulation . 

Comment: On page 1 of the side by side comparison table, RI says that 

Regulation No . 36 does not include all of the part 63 general provisions. Many of 

the general provisions apply to the federal degreaser rule. As a result we cannot 

make a determination until we know whether RI's regulations and requirements 

address the general provisions that apply to the degreaser rule . 

Response: Please see the attached table for a comparison of the RI rule to the 

General Provisions . 

Comment: Please provide the definition of new source. Also please clarify 

whether there are any differences in the control requirements between new and 

existing sources in the RI rule. 

Response : The term "new source" is not used in the regulation . The regulation 

will not be modified to include a definition for new source. The regulation contains 

compliance schedules for sources that commenced construction or 

reconstruction prior to November 29, 1993 and sources that commenced 

construction or reconstruction on or after November 29, 1993 . 
Options for control combinations for in-line cleaning operations differ for new and 

existing sources . Specifically Sections 36.7 .7 and 36.7.8 below contain 

requirements for in line machines installed prior to November 29, 1993 and 

requirements for in line machines installed on or after November 29, 1993 . 

36. 7.7 Any in-line cleaning machine installed before November 29, 9993 

must be equipped with one of the following control combinations: 

(a) Refrigerated freeboard chiller and freeboard ratio of at least 1 .0; or 

(b) Refrigerated freeboard chiller and dwell; or 

(c) Carbon adsorber and dwell; or 

(d) Another system of equivalent control system that is approved by 

the Director and the EPA. Requests for equivalency determinations 

must be submitted no later than June 3, 9996. Requests shall 

include the following information: 

(1) A complete description of process and control equipment; 

(2) Testing procedures that will be used to demonstrate 

equivalency; and 

(3) The date, time and location of the equivalency test. 

36.7.8 Any in-line cleaning machine installed on or after November 29, 

9993 must be equipped with and operate one of the following control 

combinations: 

(a) Refrigerated freeboard chiller and a superheated vapor system; or 

(b) Refrigerated freeboard chiller and carbon adsorber; or 

(c) Another system of equivalent control that is approved by the 

Director and the EPA. Requests for equivalency determinations for 

control of cleaning machines installed on or after November 29, 

1993 must be submitted and approved prior to startup of the 

cleaning machine. Requests shall include the following information : 

(1) A complete description of process and control equipment; 

(2) Testing procedures that will be used to demonstrate 

equivalency; and 

(3) The date, time and location of the equivalency test.