STATE OF RHODE ISLAND'S

APPLICATION TOTHE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY FOR THE DELEGATION OF AUTHORITY TO REGULATE HALOGENATED SOLVENT

CLEANING EQUIPMENT OPERATIONS

March 2005

Rhode Island Department of Environmental Management

Office of Air Resources
APPLICATION FOR SUBPART E DELEGATIONPART 1 . GENERAL INFORMATION 1 .1 Agency Information Date : Januarv 2005 Official Agency Name : Rhode Island Department of Environmental Management Office of Air Resources Mailing Address : 235 Promenade Street Providence, Rhode Island, 02908-5737 Phone : 401-222-2808 Fax: 401-222-2017 Agency Contact : Mr
. Stephen Maikut Contact Information : Chief, Office of Air Resources 1 .2 Title V Information Please give date and Federal Register citation for the final approval of the State's Title V Operating Permits Program (if applicable)
. The Rhode Island Department of Environmental Management's Title V Program has received approval fromthe US Environmental Protection Agency. The final approval was published on Oct 1, 2001, at 40CFR Part 70 Volume 66, No 190 page 49839
. 1 .3 Other 112(I) delegations Please cite Federal Register notices and dates for any previous 112(I) delegations
. The Department has no other 112(I) delegations and no other applications pending
. This application is the Department's first 112(I) delegation request . 1 .4 Delegation option: XXXXX Rule Substitution (Section 63.93) 1 .5 Agency Certification We, the undersigned, do hereby certify that the information contained in this application is correct to the>best of Wr knowledge. Signature : (4/-
_ (State Agency Cory~act) ~ v`~ Date : 312A
s

0 Signature: Date: (State Agen4y i~b~

e6tor or other highest official) APPLICATION FOR SUBPART E DELEGATION

COMMON CRITERIA .( 63 .91)PART 2
. CRITERIA FOR APPROVAL

2.1 Once a State has satisfied the § 63 .91(d) up front approval requirements, it only needs to reference the previous demonstration and reaffirm that it still meets the criteria for any subsequent equivalency submittals
. [§ 63 .91(d)(2)]
. Interimor final title V program approval will satisfy the criteria set forth in § 63 .91(d), up front approval criteria
. [ § 63.91(d)(3)] The Rhode Island Department of Environmental Management's Title V Program has received approval fromthe US Environmental Protection Agency
. The final approval was published on Oct 1, 2001, at 40CFR Part 70Volume 66, No 190 page 49839
.APPLICATION FOR SUBPART E DELEGATION RULE SUBSTITUTION (§ 63.93) PART 3
. APPROVAL OF A STATE RULE OR STATE AUTHORITIES THAT SUBSTITUTE FOR A SECTION 112 RULE 3 .1 Provide a demonstration that the State authorities contain or demonstrate applicability criteria that are no less stringent than those in the respective Federal rule [§ 63.93(b)(1)] . As part of this demonstration, cite the State's applicability provisions: Citation(s) : RI Section 36.2 & Federal Section 63 .460(a) The RI regulations contain more stringent applicability provisions than the NESHAP
. Section 63 .460(a) of the NESHAP applies to any solvent cleaning machine using methylene chloride, perch loroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5%by weight
. Section 36.2 of the RI regulation covers all organic solvent cleaning machines using Volatile Organic Compounds and/or Hazardous Organic Compounds, which include all of the solvents listed in the Federal applicability criteria
. Additional requirements in the RI Regulation apply to solvent cleaning machines using the above listed halogenated solvents
.3.2 Provide a demonstration that the State authorities contain or demonstrate levels of

control and compliance and enforcement measures that result in emissions reductions from each affected source (or accidental release prevention program requirements for each affected source) which are no less stringent than those that would result from the otherwise applicable Federal rule [§63 .93(b)(2)]

. As part of this demonstration, cite relevant State compliance and enforcement provisions: Citation(s) : RI Sections : 36.1, 36.2
. 36.3 36.5 & 36.10 Federal Sections : 63 460(a (c)(d) 63 .462(a) &63 .463(a)(b)(d)(e) A table comparing the requirements in the Federal regulation with those in the State regulation is attached
. In order to enhance the level of control for solvent cleaning machines and control devices, RI made provisions throughout the RI regulation
. As of result of these provisions, the RI standard is more stringent than the Federal in several areas . " Section 63 .460(a) of the NESHAP applies to any solvent cleaning machine using methylene chloride, perch loroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5%by weight
. Section 36.2 of the RI regulation covers all organic solvent cleaning machines using Volatile Organic Compounds and/or Hazardous Organic Compounds, which include all of the solvents listed in the Federal applicability criteria
. Additional requirements in the RI Regulation apply to solvent cleaning machines using the above listed halogenated solvents
. " Section 63 .460(c) & (d) of the NESHAP designates new sources as those constructed after 11/29/93
. Section 36.3 of the State regulation defines new sources as those constructed on and after 11/29/93
. Section 63.461 of the NESHAP defines "vapor cleaning machine" as a batch or in-line solvent cleaning machine that boils liquid solvent generating solvent vapor that is used as part of the cleaning or drying cycle
. The RI definition of "vapor cleaning" in Section 36.1 .30,of the RI rule, definition of Vapor Cleaning, does refers to hot solvent vapor, but does not specify that the solvent must be heated to boiling
. Section 63 .462(a)(1) of the NESHAP requires a water layer at a minimumthickness of 1 inch ; Section 36.5 .3(b) of RI rule requires a minimumthickness of 4 inches
." Section 63.463(a)(3) of the NESHAP requires automated parts handling systems to be

capable of moving parts at a maximumspeed of 11 ft/min
. Section 36.6.3 of the RI rule allows a maximumspeed of 10 ft/min
. Section 63 .463(e)(2)(vii) of the NESHAP requires that the solvent concentration in the carbon adsorber exhaust not exceed 100 ppm . Section 36.9 .5 of RI regulation requires that the solvent concentration not exceed 25 ppm . " Section 63 .463(e)(3)(ii) of the NESHAP requires that certain exceedances be corrected within 15 days of detection
. Section 36.11 .3(a)(2) of the RI regulation requires they be corrected within 10 days
. Section 63 .467 of the NESHAP does not require records of training to be maintained whereas section 36.10(e) of the RI regulation requires records of training to be kept for the lifetime of the machine
. " Section 63 .463 of the NESHAP specifies control requirements for batch and in-line vapor cleaners
. Sections 36.6. and 36.7 contain similar requirements, but further restrict the allowable control options available and do not allowexemption fromcontrols if facilities comply with idling emissions limits
. " Since the reduction of roomdrafts, use of working-mode covers, and adherence to an idling emission rate limit are not allowed as a compliance option in the RI regulation, all reporting, monitoring, and recordkeeping provisions in the NESHAP relevant to these compliance options are not included in the RI regulation
. " The federal General Provisions require initial notifications to include an identification of the relevant standard
. The RI regulation does not include this requirement
. However, the OAR printed the citation of the NESHAP on the forms used for Initial Notifications in the State
. Since these forms have already been distributed and returned, the OAR believes that the RI program is consistent with the NESHAP requirement
. " Section 63 .468 of the NESHAP requires sources to calculate potential to emit (PTE) using an identified procedure, and the General Provisions require each facility to state on its Initial Notification that it is a major or an area source. The RI regulation does not include either of these requirements, but did collect the information required to calculate PTE using the NESHAP procedure, type of cleaner and solvent/vapor interface area, on the Initial Notification form

. This information has been crosschecked with other records, including inspection reports . " Since the NESHAP itself applies to both major and area sources, this distinction is important only for determining whether or not facilities must apply now for operating permits
. The OAR's operating permit program calculates PTE for facilities in the State and, based on those calculations, notifies appropriate sources that they are required to file Title6V permit applications
. There is no reason not to use the same procedure with degreasers ;

in fact, since solvent cleaning sources in RI tend to be small and not technically proficient, the OAR's PTE calculations would be more accurate than the sources'
. " Section 64.468 of the NESHAP requires that initial compliance reports for facilities complying with the alternative emission limits include the first 3 -month average emissions calculation and that those reports be submitted by 150 days after the compliance date
. The RI regulation requires a calculation of emissions for the first month but, since the RI report is due 60 days after the compliance date, the 3-month average is not required and cannot be required
. However, facilities are required to keep records of each 3-month average calculation, which would be verified by inspection, and to submit that information as part of the annual compliance report . The Office of Air Resources believes that this approach adequately assures compliance, and is preferable to an extensive delay in the submittal of the initial compliance report . " Section 63 .468 of the NESHAP requires that annual compliance reports for facilities complying with the alternative emission limits list the size and type (solvent/air interface area or cleaning capacity) of each unit
. The RI regulation does not require this information as part of the annual report ; however, information on type of cleaning unit and solvent/air interface area is required as part of RI's Initial Notification and information on cleaning capacity as part of the RI's initial compliance report . Since this information would not change from year to year, requiring that information on the annual report would not yield additional information
. " Section 63 .468 of the NESHAP requires exceedance reports to be filed semiannually or more frequently
. The RI regulation allows OAR to determine on a case-by-case basis that more or less frequent reporting is necessary. The OAR would like to maintain this flexibility in the event that it is determined that ; for instance, a facility has an excellent record of inspecting and maintaining equipment and is being inspected frequently enough by the OAR to assure compliance with only annual exceedance reports. Section 63.468 of the NESHAP states that an exceedance has occurred, and must be listed on an exceedance report, if an idling mode cover is not in place when parts are not in the solvent cleaning machine or does not completely cover the cleaning machine openings when in place
. The RI regulation does not include a similar requirement
. OAR believes that facilities cannot reasonably be expected to record and report each time an operator temporarily fails to replace a cover and that, therefore, such reporting would be spotty at best and of no practical enforcement use. Further, OAR believes that the best mechanisms for achieving maximumcompliance with the cover replacement requirement are training and periodic unannounced inspections, and that the best mechanismfor determining that the cover is adequately sized is through an initial compliance inspection
. The NESHAP states that an exceedance has occurred, and must be listed on an exceedance report, if the appropriate dwell time is not determined or if, after cleaning, eachpart is not held in the freeboard area for the appropriate dwell time
. The RI regulation does

not include a similar requirement, but does require facilities to determine appropriate dwell times in a manner consistent with the NESHAP requirements, to maintain records of that determination for the lifetime of the machine, to supply that information to the OAR in the initial compliance reports, to measure and record actual dwell times monthly, to keep records of monthly dwell measurements for 5 years, and to report those measurements on the compliance reports . OAR believes that these measures are sufficient to assure compliance, to the extent possible, with dwell specifications, and that exceedance reports for dwell infractions would not provide useful information
. " The NESHAP states that an exceedance has occurred, and must be listed on an exceedance report, if manufacturer's specifications are not followed for determining the minimum proper dwell time for a superheated vapor systemor parts do not remain within the superheated vapor for at least the minimumproper dwell time
. OAR believes that the monitoring, recordkeeping and reporting requirements for superheated vapor systems in the RI regulation, which are similar to those discussed in the itemabove, are sufficient to assure compliance and that including this information in an exceedance report would not yield useful information
. " The NESHAP states that an exceedance has occurred, and must be listed on an exceedance report, if a lip exhaust is located below the solvent cleaning machine cover so that the cover closes above the lip exhaust level
. OAR believes that the placement of a lip exhaust can be easily verified in an initial compliance inspection, and is not appropriately the subject of an exceedance report .3.3 Provide a demonstration that the State authorities contain or demonstrate a compliance

schedule that assures that each affected source is in compliance no later than would be required by the otherwise applicable Federal rule [§ 63.93(b)(3)]
. If applicable to this demonstration, cite State provisions containing compliance schedules: Citation (S) : RI Section 36.3 & Federal Section 63 .460(c)(d) Section 36.3 of the RI regulation considers solvent cleaning machines constructed before November 29, 1993 to be existing sources and requires compliance for those sources to be achieved by January 1, 1997
. Section 63.460(c) of the NESHAP defines a solvent cleaning machine constructed on or before November 29, 1993 as existing sources and requires compliance by December 2, 1997
. Therefore, the RI regulation is more stringent than the NESHAP because it has an earlier compliance date for existing sources . Section 36.3 of the RI regulation considers solvent cleaning machines constructed on or after November 29,1993 to be new sources and requires compliance for those sources to be achieved by April 8, 1996, or upon startup, whichever is later
. Section 63 .460(c) of the NESHAP requires compliance for new sources by December 2, 1994
. The RI regulation could not require an earlier date because it was not effective until April 8, 1996 and could not require compliance before it was effective
. The RI regulation and the NESHAP have the same submittal dates for Initial Notification
. Submittal of Compliance Notifications are linked to the compliance dated discussed above
.3.4 Provide a demonstration that the State authorities contain each of the following

compliance and enforcement measures [§ 63 .93(b (4)]
. Cite State provisions for each: 3.4.1 A method for determining compliance
. Citation(s) See beloweach category (a) Refrigerated freeboard chiller : Both the RI regulation and NESHAP require that either a thermometer or thermocouple be used to measure the temperature at the centroid of the air blanket on a weekly basis while the machine is operating in the idling mode
. In order to be considered in compliance the temperature reading at the coldest point of the centroid of the chilled air blanket is no greater than 30%of the solvent's boiling point
. Citation(s) : RI Section 36.9.3 & NESHAP Section 63.463(e)(2)(i) and 63.466(a)(1) (b) Superheated vapor system : Both the RI regulation and the NESHAP require that either a thermometer or a thermocouple be used to measure the temperature of the solvent vapor on a weekly basis while the machine is operating in the idling mode
. In order for the temperature to be in compliance of both regulations, the temperature reading at the centroid of the superheated vapor zone must be at least 10°F above the solvent's boiling point
. Citation(s) : RI Section 36.9.4 & NESHAP Section 63.463(e)(2)(vi) and 63.466(a)(2) (c) Dwell time: Both the RI regulation and the NESHAP require that the actual dwell time be measured on a monthly basis and the result of the measured actual dwell time be no less than the minimum dwell time
. For units without superheated vapor systems, the minimumdwell time is determined by taking 35%of the time necessary for the part or parts basket to cease dripping once placed in the vapor zone . For a superheated vapor systemthe dwell time is determined according to the specifications of the manufacturer of the control equipment
. If the actual dwell time is less than the minimum dwell time, the automatic parts handling systemor other transporting means shall be adjusted accordingly
. Citation(s) : RI Section 36.9 .6 & Federal Section 63.463(e)(2)(v), 63.463(e)(2)(vi)(c), and 63 .466(b)(2)
10(d) Carbon Adsorber :

Both the RI regulation and the NESHAP require monitoring of the concentration of the solvent in the carbon adsorber's exhaust streamwhile the cleaning machine is operating on a weekly basis using a colorimeter detector tube
. The colorimeter detector tubes must have an accuracy of +/- 25%or better and must be in used according to the manufacturer's instructions
. To meet RI's specification, the solvent concentration shall be measured while the cleaning machine is in the working mode and is exhausting to the carbon adsorber and the measured concentration must not exceed 25 ppm . The NESHAP allows the solvent concentration to be 100 ppm . If the exhaust exceeds the standard the desorption cycle must be adjusted or the carbon canister replaced
. Therefore the RI regulation is more stringent in this area . Citation(s) : RI Section 36.9 .5 & Federal Section 63 .463(e)(2)(vii)(a)-(c) and 63 .66(2)(e)(1)-(3) (e) Automated parts handling system : Both the RI regulation and the NESHAP require the speed of the automated parts handling systems to be measured monthly
. The RI regulation allows a maximumspeed of 10 ft/min whereas the NESHAP allows a maximumspeed of 11 ft/min
. If a facility does not exceed this standard for one year the facility may monitor the speed on a quarterly basis rather than on a monthly basis
. The RI regulation is more stringent in this area. Citation(s) : RI Section 36.9 .2 & Federal Section 63.463(e)(2)(ii)(a) and 63 .466(c)(2) (f) Cover : Both the RI regulation and the NESHAP require that the cover be visually inspected monthly to confirmthat it is opening and closing properly, that it completely covers the cleaning machines opening when closed and that it is free of cracks, holes and other defects
. Citation(s) : RI Section 36.9 .1 & Federal Section 63.463(e)(2)(iii)(a)&(b) and 63.466(d)(2)3.4.2 A maximumaveraging time for any standard in the authorities which is not an

instantaneous standard
. Citation(s) : RI section 36.8 .2 & Federal Section 63 .464(2)(B) Both the RI regulation and the NESHAP require batch vapor cleaning operations without solvent/air interfaces to comply with a monthly emission limit for a 3-month rolling average period
. The emission limits and averaging times are the same in both regulations, after unit conversion
.3.4 Provide a demonstration that the State authorities contain each of the following

compliance and enforcement measures [§ 63.93(b (4)]
. Cite State provisions for each : 3.4.3 An obligation to periodically monitor or test compliance using the method shown in question 4.4 .1 which is sufficient to yield reliable data that are representative of the source's compliance status. Citation(s) : RI section 36.9 & NESHAP section 63 .466 Both the RI regulation and the NESHAP require weekly temperature check for refrigerated chillers and superheated vapor systems. In addition both require weekly solvent concentration checks fromthe carbon adsorber exhaust and monthly checks of the automated parts handling systemspeed, covers, and dwell time
.Federal vs. State Halogenated Solvent Cleaning Rules

Federal Cite Section State Cite Comments 63.460 (a) Applicability § 36.2 RI regulations cover all organic solvent cleaning machines using volatile organic compounds and/or hazardous organic compounds
. The federal regulation only applies to solvent cleaning machines using methylene chloride, perch loroethylene, trichloroethylene, 1,1,1 trichloroethane, carbon tetrachloride or chloroform, or any combination or these halogenated HAP solvents, in a total concentration greater than 5%by weight
. Overall the RI rule is more stringent . § 63 .460 (b) General Provisions RI regulations do include all applicable General Provisions
. § 63 .460 ( c) Compliance § 36.3 (b) Rhode Island requires compliance for

Schedule New new sources upon start up or by Sources 4/8/96, whichever is later
. The Federal Regulation requires compliance by 12/2/94, however the RI regulation was not effective until 4/8/96 and could not require an earlier com

pliance date
. § 63 .460 (d) Compliance § 36.3 (a) RI requires compliance for existing

Schedule Existing sources by 1/1/1997
. The federal Sources regulation requires compliance by 12/2/97
. 63 .460(g) RI rules do not contain provisions for continuous web solvent cleaning machines, however RI does not have an continuos web cleaners
. § 63.461 Definitions 36.1 RI did not define the following : consumption, cover, HAP solvent I, (but did define HAP), hoist, I immersion cold cleaning machine, ' monthly reporting, open top vapor mode, part, soils, contaminant, sump heater coils, water layer, and the following general provision definitions : administrator, existing, new, reduced roomdraft, and solvent/air interface area . Additionally, the federal regulationdefines vapor cleaning machine as a batch or inline solvent cleaning machine that boils liquid solvent generating vapor that is used as part of the cleaning or drying cycle whereas the RI regulation does not specify that the hot liquid must be boiling . § 63.462 Requirements for 36.5 Rhode Island requires a 4" water

Batch Cold layer whereas the Federal regulation Cleaning Machines only requires a 1" water layer
. All other requirements are the same. The RI rule is more stringent . § 63.463 (a) (1) Batch Vapor and In § 36.6 RI regulations do not allow the use of - (a) (7) Line Cleaning reduced roomdrafts for compliance

Machine Standards with this regulation
. RI requires the automated parts handling systemto operate at 10ft/min whereas the federal regulation allows 11ft/min
. The RI rule is more stringent . § 63.463 (b) Requirements for § 36.6 .6 or RI regulations do not allowidling

Batch Vapor 7 limits and less control options are Cleaning allowed, but those allowed are at Operations with least as stringent
. Solvent/Air Interface § 63.463 (c ) Requirements for § 36.7 .7 No idling limit allowed (more

In-Line Cleaning and § stringent) ; less control options Operations 36.7.8 allowed, but those allowed are at least as strin gent .§ 63 .463 (d) (1- Work practice (1) 36.6.1 - RI regulations do not allowreduced

12) 36.7.1 (2) roomdrafts for compliance with this , (ii) N/A (3) regulation
. RI regulations contain !, 36.6.4(c), some additional language regarding ' 36.6.11, treatment of waste solvent, but do not 36.7.4(c), include that the container must allow 36.7.15 (4) pressure relief
. 36.4.9- 36.4.10(5) 36.4.8 (6) , 36.6.15- 36.7.13(7) 36.6.16- 36.7.14(8) 36.4.11 (9) 36.4.13 (10) 36.4.14 (11) 36.4.12 (12) 36.4.7

I § 63.463 (e) (1) Compliance 1) 36.9.1, Rhode Island regulations do not allow ! -(4) Specifications and 36.9.3, the reduction of roomdrafts, use of

Monitoring 36.9.4, working mode covers or adherence , Requirements 36.9.5, to an idling emission rate limits as ',

36.9.6(c) control options
. RI regulations 2) 36.9.3, require that the solvent concentration , 36.9.4, in the carbon adsorber exhaust not ' 36.9.6, exceed 25 ppm whereas the federal 36.9.5, regulation allows 100ppm
. RI ' 36.5.1, regulations require that certain 36.6.1 exceedances be corrected within 10 (3)36.11 .3(a days whereas the federal regulation )(1), allows 15 days
. The RI rule is more 36.11 .3(a)(2 ) stringent
. (4) 36.11 .3( b ) 63 .464(e)(2)(ix) RI rules do not contain provisions for ' ,(x),(xi) continuous web solvent cleaning machines, however RI does not have any continuous web cleaners
. 3§ 63.463 (f) Idling Standards N/A RI does not allowthe idling limit I standard option
. 63.463(g),(h) RI rules do not contain provisions for I continuous web solvent cleaning ' machines, however RI does not have I any continuous web cleaning machines
. § 63.464 Alternate Standards § 36.8 RI does not allowalternative standards for machines with solvent air interface
. RI does require alternative standards for machines without solvent air interface
. RI regulations have no provisions for ' cleaning ca pacity. § 63.465(a) Idling standard test N/A RI does not allowidling limits

method § 63.465 (b) Test method for § 36.8.3 (a I alternative standard & b § 63.465 ( c) Calculation for § 36.8.3 (

alternative standard c,d,e & f 63.465 d Dwell time 36.9.6 a § 63.465 (e) PTE for solvent Not found '

cleaning o perations I 63.465(f),(g),(h) RI rules do not contain provisions for I continuous web solvent cleaning ' machines, however RI does not have any continuous web cleaning machines
. ' § 63.466 (a) Weekly monitoring § 36.9 .3 !

freeboard and § refrigeration device 36.9.4 su p erheated va por § 63.466 (b) Monthly monitoring § 36.9.1

of Cover and dwell and 36.9 .6



### c § 63.466 (c ) Hoist speed § 36.9 .2 a,b and d § 63.466 (d) Reduced roomdraft N/A RI regulations do not allowreduced roomdrafts for compliance with this regulation
. 63.466 e Carbon Adsorber 36.9 .5 § 63.466 (f) Idling limit N/A RI regulations do not allowidling limits as control options
. § 63 .466 (g) Alternate § 36.9 .8 Requires both EPA and DEM to monitoring methods a pprove alternative method§ 63 .467 (a) Recordkeeping § 36.10.1 Additionally, RI requires records of Requirements (to training and superheated vapor dwell be kept for the be maintained
. lifetime of the machine § 63 .467 (b) Recordkeeping § 36.10.2 Rhode Island does not explicitly

Requirements (to require records of CA weekly be kept for the five measurements, but it is covered years) under the results of control device monitorin g. § 63.467 (c & Recordkeeping § 36.10.3 d) Requirements

(sources complying with alternative standards 63 .467 RI rules do not contain provisions for (a)(6),(7) continuous web solvent cleaning machines, however RI does not have any continuos web cleaning machines
. § 63.468 (a) Initial notification § 36.11 .1



### existing sources (a § 63.468 (b) Initial notifications - § 36.11 .1 RI is more stringent requiring that

new sources (b) initial notification reports be submitted 120 days before the startu p of the cleaning machine
. § 63.468 (c,d Compliance § 36.11 .2 The RI regulation requires a & e) Notification Reports calculation of emissions for the first month but, since the RI report is due 60 days after the compliance date, the 3-month average calculation (as in the federal regulation) in not required and cannot be required
. However, the RI regulation does require sources to keep record s of each 3-month avera g e calculation
. § 63 .468 (f) Annual Reporting 36.11 .4 The RI regulation does not require sources complying with an alternative emission limit to list the size and type or each unit on the annual report . This information is part of the initial notification and is not likely to change and would therefor yield no additional information
.§ 63.468 (g) Annual Report for 36.11 .4 sources complying with Alternative Standards § 63 .468 (h) Exceedance § 36.11 .3 The RI regulation allows DEM to reports (b,c,d & e) determine, on a case by case basis, the exceedance reporting frequency
. The RI regulation does not require Exceedance reports to be filed for the following : 1) an idling mode cover is left off, 2) if the appropriate dwell time is not determined or if, after cleaning the part is not held in the freeboard area for the appropriate dwell time, 3) if manufacturers specifications are not followed for determining the proper dwell for a superheated vapor systemor parts do not remain in the superheated vapor for at least the minimum proper dwell time, and 4) if a lip exhaust is located below the solvent cleaning machine cover so that the cover closes above the lip exhaust level
. § 63 .468 (I) Reduction in § 36.11 .3 (f)

Exceedance Reports § 63 .468 (J) Permit N/A Rule applies to all solvent cleaners

req uirements regardless of size
. § 63 .468 (k) Equivalency N/A

timeframe for submittal § 63 .469 Equivalent Methods § 36.5.3(c ) RI's rule requires both EPA and DEM

of Control , § approval
.

36.6 .6(e), § 36.6 .7 (c ), 36.9 .8Part 63 section RI rule Comments

63.1 Applicability of General Provisions RI is substituting their rule for the NESHAP
. .

63.1 (a)1-3 General 36 .1 Definitions, 36.2 applicability Terms applicable to the rule are defined in the RI rule
. Appendix C of the NESHAP provides a table of General Provisions Applicability to the rule
. 63.1(a)4 Appendix C of the NESHAP identifies applicability of the General Provisions to each section of the NESHAP for deg

reasers 63.1 ( a)( 5

) Not a licable to Subp art T 63.1 . (a )( 6 )

-- ( 8 ) RI is substituting their rule for the NESHAP 63.1 ( a)( 7 Not applicable to Subp art T 63.1 a 9 Not applicable to Subp art T 63.(a)(10 Not applicable - compliance dates are specified in the regulation
. The word day is self explanatory in sections used
. 63.1 WO 1 Not applicable to Subp art T 63.1(a)(12 The RI rule does not allow for extension of com p liance dates 63.1 b 1 Not applicable to Subp art T 63.1 b 2 reserved

63 .1 c 1 36.3 Com

p liance Schedule New sources must com

ply upon startu p. 63.1 (c)2 RI Regulation 29 contains requirements for operating permits
. 63.1 c 3 4 reserved

63 .1 c 36.2 A licablit Rule applies to all solvent cleaning machines 63.1 d reserved

63.1 e Not a licable to Sub p art T 63.2 Definitions 36.1 Definitions Definitions applicable to the rule are contained in the RI rule 63.3 Abbreviations/Unit Not applicable 63.4 Prohibited activities and circumvention Rhode Island Clean Air Act, General LawTitle 23-Chapter 23 63.4(a)2 36.11 .3 Exceedances and

Exceedance Re ports 63.4(a) 3 reserved

63.4(a)4 Not applicable to Subpart T 63.4(a) 5reserved

63.4(b Rhode Island Clean Air Act, General LawTitle 23-Cha p

ter 23 63.5 Preconstruction reviewand notification procedures RI Air Pollution Control Regulation No
. 9 "Permits" New or modified process emitting 10 tons or more of any one Hazardous Air Pollutant (HAP) or 25 tons or more of any combination of HAPs must also receive a preconstruction permit, as must all installations of air pollution control equipment
. Preconstruction permit stipulations are written to be consistent with the rule requirements
. The Permit section also incorporates the rule requirements into Title V operating permits for all 63.5 b 2reserved 63.5(b )( 3 Not applicable to Subpart T 63.5(b) 4, 36.11 .1 Initial Notification Sources must submit an initial notification report 120 da y s before startu p 63.5( b) 5 reserved 63.5(c) reserved 63.5 (d)-(f Not applicable to Subpart T

Regulation 36 Com

parison to General Provisions63.6 Compliance with standards

and maintenance re quirements

63.6 (a) Applicability Section 36.2 Applicability Section 36.2 of the RI rule contains applicability standards that are more stringent than NESHAP
. 63.6 (b) 1-5 and 63.6 (c)1-2, 36.3 Compliance Compliance dates in the RI rule are as follows : sources which commenced construction or reconstruction after 11/29/93 must achieve compliance by 1/1/97 and sources which commenced construction or reconstruction after 11/29/93 must achieve compliance upon startup or 4/8/96 whichever is l ater: 63.6 (b)6, and 63.6 (c) 3-4, 63.6(d reserved 63.6( b ) 7 Not applicable to Sub part T 63.6(e) 1 Sections : 36.6 Requirements for Batch Start up and shut down procedures are contained

Vapor Cleaning Machines with in the RI rule in Sections 36.6.15, 36.6.16, Solvent/Air Interface; 36.7 36.7 .13, and 36.7 .14 of the RI rule contain start up Requirements for In Line Cleaning and shut down requirements
. O p erations 63 .6 ( e) 2 reserved 63.6 e Not applicable to Sub part T 63.6(f)-(g Section 36.9 Compliance Section 36.9 contains applicable monitoring

Specifications and Monitoring requirements consistent with the NESHAP Requirements General Provisions section 63.6 (f) and 63 .6 ( h Not app licable to Sub part T 63.6(i) 1-14,1 The RI rule does not allow for extension of com pliance dates 63 .6 i 15 reserved 63.7 Performance testing Not applicable to Subpart T
. The RI rules do not re quirements allowan idling emissions standard 63.8 Monitoring re quirements 63.8 (a-b), (f Section 36.9 "Compliance Any alternative monitoring procedures must be

Specifications and Monitoring approved by the Director and EPA Re uirements 63.8 c-e Not app licable to Subpart T 63.9 Notification re quirements 63.9 (a-e Section 36.11, Section 36.9.5 Section 36.11 .1 Initial Notifications Report, Section 11 .2 Compliance Notification Report
. Section 36.9.5 contains notification of performance test requirements
. The RI rule does not allow for extension of compliance dates or contain continuous monitoring requirements
. 63.9 b 4, 63.9 f, h Not applicable to Subpart T 63.10 Recordkeeping and reporting re quirements 63.10 (a Sections 36
. .10, 36.11 .3 RI Section 36.10 Recordkeeping, Section 36.11 .3 Exceedances and Exceedance Reports 63 .10 b Not app licable to Subpart T 63.10 ( c) ( 1 )

- ( 15 Not app licable to Subpart T 63.10(d)(1 Section 36.11 Reporting

Requirements 63.10 ( d)( 2 ) , 63 .10 e Not app licable to Subpart T 63.10 (f Section 36.11 .3 Allows for a change in reporting frequency for exceedances with Division approval
. 63.11 Control Device requirements 63.11 (a 36.9 Control device requirements consistent wit the NESHAP are contained in the reg ulation63.11 b Not a licalbe to Subp art T 63.12 State authority and RI is submitting this 1121 application and dele gations complying with the requirements of 63.93 63.13 Addresses of State air Annual reports are collected and available to EPA pollution control Agencies and EPA as requested re gional Offices 63.14 Incorporations by reference Not applicable to Subpart T 63 .15 Availability of information and Information is available under the State Public confidentiality Records Rule