STATE OF RHODE ISLAND'S 

APPLICATION TO THE 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 DELEGATION 
PART 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 from the 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) 

Date : 312A ~ v`~ 

s Signature: Date: 0 

(State Agen4y e6tor i~b~ 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)] . Interim or 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 from the US Environmental Protection Agency . The final 

approval was published on Oct 1, 2001, at 40CFR Part 70 Volume 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 minimum thickness of 1 

inch ; Section 36 .5 .3(b) of RI rule requires a minimum thickness of 4 inches . 
" Section 63.463(a)(3) of the NESHAP requires automated parts handling systems to be 

capable of moving parts at a maximum speed of 11 ft/min . Section 36.6.3 of the RI rule 

allows a maximum speed 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 allow exemption from controls if facilities 

comply with idling emissions limits . 

" Since the reduction of room drafts, 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 Title 

6 
V 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 maximum compliance with the cover replacement requirement 

are training and periodic unannounced inspections, and that the best mechanism for 

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, each 
part 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 system or parts do not remain within 

the superheated vapor for at least the minimum proper 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 item above, 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 below each 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 minimum dwell 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 system the 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 system or 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 stream while 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 maximum speed of 10 ft/min 

whereas the NESHAP allows a maximum speed 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 

confirm that 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 maximum averaging 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 from the carbon adsorber exhaust and monthly checks of the automated parts 

handling system speed, 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 compliance 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 room draft, and 

solvent/air interface area . 

Additionally, the federal regulation 
defines 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 room drafts for compliance 

Machine Standards with this regulation . RI requires the 

automated parts handling system to 

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 allow idling 

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 allow reduced 

12) 36.7.1 (2) room drafts 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 

§ 63.463 (e) (1) Compliance 1) 36.9.1, Rhode Island regulations do not allow I !

-(4) Specifications and 36.9.3, the reduction of room drafts, 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 allow the 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 allow alternative 

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 capacity. 

§ 63.465(a) Idling standard test N/A RI does not allow idling 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 perheated 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 room draft N/A RI regulations do not allow reduced 

room drafts for compliance with this 

regulation . 

63.466 e Carbon Adsorber 36.9 .5 

§ 63.466 (f) Idling limit N/A RI regulations do not allow idling 

limits as control options. 

§ 63 .466 (g) Alternate § 36 .9 .8 Requires both EPA and DEM to 

monitorin g methods approve 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 

startup 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 averag 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 

system or 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 .8 
Part 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 degreasers 

63.1 ( a)( 5) Not a licable to Subpart T 

63.1 . (a)(6) -- ( 8) RI is substitutin g their rule for the NESHAP 

63.1 ( a)( 7 Not applicable to Subpart T 

63.1 a 9 Not applicable to Subpart 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 Subpart T 

63.1(a)(12 The RI rule does not allow for extension of 

compliance dates 

63.1 b 1 Not applicable to Subpart T 

63.1 b 2 reserved 

63.1 c 1 36.3 Compliance Schedule New sources must comply 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 Subpart 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 

Law Title 23-Chapter 23 

63.4(a)2 36.11 .3 Exceedances and 

Exceedance Reports 

63.4 (a)3 reserved 

63.4 (a)4 Not applicable to Subpart T 

63.4 (a)5 reserved 

63.4(b Rhode Island Clean Air Act, General 

Law Title 23-Cha pter 23 

63.5 Preconstruction review and 

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 days before startu p 

63.5 ( b)5 reserved 

63 .5(c) reserved 

63.5 (d)-(f Not applicable to Subpart T 

Regulation 36 Comparison to General Provisions 
63 .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 Subpart 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 . 

Operations 

63.6( e) 2 reserved 

63.6 e Not applicable to Subpart 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 Subpart T 

63.6(i) 1-14,1 The RI rule does not allow for extension of 

compliance dates 

63 .6 i 15 reserved 

63.7 Performance testing Not applicable to Subpart T. The RI rules do not 

re quirements allow an 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 re g ulation 
63.11 b Not a licalbe to Sub

part T 

63 .12 State authority and RI is submitting this 1121 application and 

delegations 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 

regional 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