GUIDANCE DOCUMENT FOR CORRECTING
COMMON VOC & OTHER RULE DEFICIENCIES
(A.K.A., The Little Bluebook)
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IX
Originally Issued, April 1991
Revised, August 21, 2001

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Table of Contents
Guidance Document for Correcting
Common VOC & Other Rule Deficiencies
Introduction 	1
Definitions & Applicability
VOC Definition	2
Rule Applicability and Exemptions	3
Control Requirements
Coating and Ink VOC Content Units	5
Compliance Periods and Averaging Times	7
Alternative Controls and Alternative Methods of Compliance	9
Monitoring, Recordkeeping & Reporting
Recordkeeping 	11
Test Methods	13
Transfer Efficiency 	14
Capture Efficiency	16
Other
Director's Discretion 	17

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Introduction
This document, sometimes referred to as the Little Bluebook, is intended to help state and
local air agencies develop rules that meet federal criteria for incorporation into State
Implementation Plans (SIPs). It was originally developed for stationary source VOC
rules, but much of the discussion also applies to other rules. It does not impose new
requirements but provides examples and additional explanation of issues highlighted in
EPA's guidance document, Issues Relating to VOC Regulation Cutpoints, Deficiencies,
and Deviations - Clarification to Appendix D of November 24, 1987 Federal Register
(OAQPS, May 25, 1988, referred to as the Bluebook). The Bluebook can be found at
http://www.epa.gov/oar/oaqps/ozonetech/voc bluebook.pdf.
Please note, neither the Bluebook nor the Little Bluebook represent exhaustive
listings of all potentially applicable requirements for SIP rules. The lists of national
guidance, for example, do not include all potentially relevant information.
For questions or comments on this document, please contact:
Rulemaking Office (AIR-4)
Air Division
U.S. EPA, Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1185
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VOC Definition
EPA regulates emissions of all volatile organic compounds (VOC) except those with
negligible photochemical reactivity.
National Regulation/Policy/Guidance
EPA defines VOC at 40 CFR 51.100(s) and lists those negligibly reactive compounds
which are exempt from VOC requirements. EPA occasionally updates this list based on
new information.
Suggestions for Developing Approvable Provisions
1.	Most SIPs either reference 40 CFR 51.100(s) orreprintitin its entirety.
2.	SIP rules cannot use vapor pressure to define VOC.
3.	SIP rules cannot exclude compounds that are not exempted by 40 CFR 51.100(s).
4.	SIP rules can control compounds that are exempted by 40 CFR 51.100(s) as long as states
do not claim control of these compounds as emission reductions in ozone SIPs, as credits
for New Source Review or Economic Incentive Programs, or for determining compliance
with emission limits.
Example Approvable Provision
40 CFR 51.100(s) exempts ethane, but California considers ethane reactive. Consistent
with item #4 above, EPA has approved California VOC definitions which do not exempt
ethane.

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Rule Applicability and Exemptions
National Regulation/Policy/Guidance
1.	Rule applicability must be clear to meet the general enforceability requirement of
§110(a)(2)(A).
2.	§§182(a)(2) and (f) require RACT in nonattainment areas for all major sources of VOC
and NOx and all sources that meet the applicability requirements of a CTG.
3.	The Bluebook describes a 5% equivalency rule that allows rule applicability that varies
slightly from the presumptive RACT.
http://www.epa.gov/oar/oaqps/ozonetech/voc_bluebook.pdf.
4.	CTGs and other EPA policy documents have further guidance on specific source
categories. For example, Exemption for Low-Use Coatings, signed by G.T. Helms on
August 10, 1990, allows exemption of up to 55 gallons/year of high-VOC coatings.
http://www.epa.gov/oar/oaqps/ozonetech/luc memo.pdf.
5.	State Implementation Plans: Policy Regarding Excess Emissions During Malfunctions,
Startup, and Shutdown, memo from Steven Herman (OECA) and Robert Perciasepe
(OAR), EPA, September 20, 1999. http://www.epa.a3v/ttncaaal/tl/meta/ml2554.html.
Suggestions for Developing Approvable Provisions
1.	Rules affecting major sources in nonattainment areas generally cannot exempt activities
subject to relevant CTGs or other presumptive RACT without demonstrating compliance
with the 5% equivalency rule.
2.	Exemptions for activities subject to other federal requirements (e.g., RACM) should be
accompanied by a demonstration that the federal requirement has been met.
3.	Waivers or exemptions from requirements during startup, shutdown, malfunction and
related conditions must comply with EPA s September 1999 policy on excess emissions.
Example Provisions Needing Support Demonstration
1. For purposes of this rule, organic liquid loading facilities are those facilities which load
more than 20,000 gallons/day of organic liquids with a true vapor pressure of at least 1.5
psia at loading conditions.
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EPA's CTG for Bulk Gasoline Plants exempts facilities which load less than 4,000
gallons/day. The example exemption level of 20,000 is not approvable in nonattainment
areas without demonstrating compliance with the 5% equivalency rule.
2. Paragraph (b)(1) shall not apply to coatings with separate formulations that are used in
volumes of less than 20 gallons per year provided that the total usage by a facility is less
than 200 gallons of such formulations applied annually.
EPA recognizes exemptions of 55 gallons/year total of high VOC coating (e.g., G.T.
Helms August 10, 1990 memo). The above provision, in contrast, exempts up to 200
gallons/year and is not approvable in nonattainment areas without demonstrating
compliance with the 5% equivalency rule.
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Coating and Ink VOC Content Units
The units for limits on VOC content of coatings and inks must be clear and enforceable.
National Regulation/Policy/Guidance
1.	The Bluebook. http://www.epa.gov/oar/oaqps/ozonetech/voc bluebook.pdf.
2.	A Guideline to Surface Coating Calculations, EPA-340/1-86-016, July 1986.
http://www.epa.gov/oar/oaqps/ozonetech/guide sco.pdf.
3.	A Guideline for Graphic Arts Calculations, EPA-340/1-88-004, June 1988.
http: //www. epa. gov/cl ariton/clhtml/ pubtitl e. html.
4.	Model VOC Rules for RACT (staff working document), EPA/OAQPS, June 1992.
http://www.epa.gov/oar/oaqps/ozonetech/voc modelrules.pdf.
Suggestions for Developing Approvable Provisions
1.	Coating VOC content limits are generally expressed in units of weight of VOC per
volume of coating, less water and exempt compounds, as applied. Many ink and
adhesive VOC limits are also expressed this way.
2.	Solids-based units (e.g., weight VOC per volume solids) are also often appropriate (e.g.,
when add-on control is a compliance option), and generally must be used when allowing
compliance with VOC limits by averaging. Weight VOC per weight solids units may
also be appropriate for some coatings and graphic arts operations. (See reference 3.)
3.	Weight VOC per volume material, without subtracting water and exempts, can be used
for limits on materials without solids, like clean-up solvents and lithographic fountain
solutions. Alternative units for low-solids coatings (e.g., less than 10% by weight of the
material is solids), however, should be evaluated on a case-by-case basis.
Example Approvable Equations
1. VOC content of coatings less water and exempt compounds, as applied, shall be
determined using the test methods in paragraph X and calculated as follows:
VOC Content =	where:
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Dc	= density of coating.
Wv	= weight fraction volatile content of coating.
Ww	= weight fraction water.
Wei	= weight fraction exempt solvent i.
Dw	= density of water.
Dei	= density of exempt solvent i.
2.	VOC content of coatings less water and exempt compounds, as applied, shall be
determined using the test methods in paragraph X and calculated as follows:
VOC Content = (Ws - Ww - Wec)/(Vm - Vw - Vec), where
Ws	= grams of all volatile compounds evolved during analysis.
Ww	= grams of water evolved during analysis.
Wee	= grams of exempt compounds evolved during analysis.
Vm	= liters of coating and/or ink, including any thinners and diluents applied.
Vw	= liters of water evolved during analysis.
Vec	= liters of exempt compounds evolved during analysis.
3.	Other equations must be used for determining compliance with VOC content limits by
averaging or with limits using other units (e.g., solids-based limits).
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Compliance Periods and Averaging Times
All SIP requirements are associated with one or more compliance time frames. For
example:
1.	Some facilities are limited in the pounds of pollutant they may emit per hour and the
hours they may operate per year.
2.	Certain information must be recorded once an hour and maintained for five years.
3.	Some compliance tests must be performed at least once every year.
National Regulation/Policy/Guidance
1.	Averaging Times for Compliance with VOC Emission Limits - SIP Revision Policy, memo
from John R. O'Connor, EPA/OAQPS, January 20, 1984, published as Appendix D of
EPA s Emissions Trading Policy Statement, 51 FR 43857, December 4, 1986.
2.	40 CFR 51, Subpart U - Economic Incentive Programs, 59 FR 16690, April 7, 1994.
3.	Improving Air Quality with Economic Incentive Programs, EPA-452/R-01-001, January
2001. http://www.epa.a3v/ttncaaal/tl/meta/ml201.html.
4.	Compliance periods and averaging times should not interfere with the enforceability of
emission limits as required in §110(a)(2)(A).
Suggestions for Developing Approvable Provisions
1.	Compliance time frames should be clearly specified. Where they are not, such as many
emission rate limits (e.g., ppmv) and VOC content limits (e.g., lb/gal), EPA assumes
instantaneous and continuous compliance is required.
2.	Rule compliance periods generally must be consistent with the applicable NAAQS time
frame. Since the ozone NAAQS is based on one-hour levels recorded over 24-hours, for
example, VOC requirements should have daily or shorter compliance periods.
3.	Provisions that allow compliance demonstration by averaging a series of measurements
overtime should clearly specify:
a.	The frequency of measurements.
b.	Whether averages are arithmetic or weighted.
c.	Whether averages are calculated on a calender (e.g., daily average examines each
day, midnight to midnight) or rolling (e.g., midnight to midnight, lam to lam,
2am to 2am, etc.) basis.
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4.	As described in the 1984 O Connor memo, VOC emission limitations with averaging
longer than 24-hours may be permitted under the following conditions:
a.	Daily limits are infeasible.
b.	Actual emissions (based on historical data) are consistent with relevant
RACT/BACT control levels.
c.	Averaging is no longer than 30 days.
d.	Averaging will not jeopardize attainment or RFP requirements. Agencies must
demonstrate that 1he maximum daily emission increase caused by the averaging is
consistent with the area s approved ozone SIP. Nonattainment areas without
approved SIPs cannot be considered for long term averages.
5.	Longer than 24-hour averaging in economic incentive programs generally must comply
with 40 CFR 51 Subpart U, including:
a.	10% or other environmental benefit (51.493(a)(1)).
b.	A statistical showing that the averaging is consistent with the NAAQS and RFP
(51.493(d)(2)(ii)).
c.	A statistical showing that the averaging is equivalent on a daily basis to source-
specific RACT requirements (51.493(d)(2)(ii)).
d.	A demonstration that the enforcement mechanisms for averaging provide
equivalent incentives for compliance (51.493(i)(l)(i)).
e.	Other EIP requirements.

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Alternative Controls and Alternative Methods of Compliance
Some regulations allow alternative methods for meeting emission limits including -
equivalency provisions, alternative emission control plans (AECPs) and cross-line
averaging. Variances are another alternative method of compliance that must meet
additional administrative requirements.
National Regulation/Policy/Guidance
1.	40 CFR 51 Subpart U describes Economic Incentive Program (EIP) requirements.
2.	Improving Air Quality with Economic Incentive Programs, EPA-452/R-01 -001, January
2001. http://www.epa.gov/ttncaaal/tl/meta/ml201.html.
3.	Industry-specific national guidance that describes averaging provisions, such as
Compliance with VOC Emission Limitation for Can Coating Operations (45 FR 80824,
December 8, 1980) and several CTGs, generally takes precedence over the generic EIP
guidance in items 1 & 2 above. Such industry-specific guidance should not, however, be
used to develop averaging provisions in SIP rules for other industries.
Suggestions for Developing Approvable Provisions
1.	Provisions that allow alternative compliance with emission limits by providing equivalent
or greater emission reductions through control equipment or other methods must clearly
and completely specify the test methods, calculations and any other methodology needed
to demonstrate equivalence, including capture efficiency where appropriate.
2.	AECPs (a.k.a., equivalency, compensating reduction or bubble) and economic incentive
(e.g., emission trading) programs allow over-compliance at one operation to offset under-
compliance at another. These provisions generally should comply with 40 CFR 51
Subpart U. Common deficiencies include director s discretion, averaging beyond 24-
hours, incomplete methodology for determining equivalency (e.g., no emission
quantification protocols), and lack of 10% or other environmental benefit.
3.	To protect sources from potential federal enforcement for violating the SIP, variances
(a.k.a., variance order, waiver, or conditional permit) temporarily suspending SIP
requirements can be submitted for action by EPA as source specific SP revisions. Such
submittals must demonstrate that the variance meets all relevant CAA requirements.
State/local agencies should contact EPA before submitting variances or variance rules for
inclusion into the SIP.
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Example Approvable Provisions
1.	A person shall not apply any coating with a VOC content in excess of the specified limits
unless emissions to the atmosphere are controlled to an equivalent level by air pollution
abatement equipment with a combined capture and control efficiency of 80 percent or
greater. Calculations, test methods and recordkeeping shall be performed as prescribed
in Section X.
2.	The requirements of Section Y shall not apply to any coating line which complies with the
following requirements:
a.	Emissions ofVOCs, determined using a daily weighted average, shall not exceed
the amount which would result if the coating line complied with all VOC content
limits of this rule.
b.	In order for two or more coatings to qualify for inclusion in a daily weighted
average calculation, the coatings must be used on the same coating line and/or
operation, and the coatings must be regulated under the same emission limit (e.g.,
both adhesive primers subject to 3.5 lbs VOC/gal material), and the coatings must
be applied on the same day.
c.	Calculations, test methods and recordkeeping shall be performed as prescribed in
Section X.
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Recordkeeping
Recordkeeping requirements must be sufficient to assure continual compliance with VOC
content limits, fuel specifications, rule applicability, exemption levels, emission caps, and
other operating and emission requirements.
National Regulation/Policy/Guidance
1.	The Bluebook. http://www.epa.gov/oar/oaqps/ozonetech/voc bluebook.pdf.
2.	Recordkeeping Guidance Document for Surface Coating Operations and the Graphics
Arts Industry, EPA 340/1-88-003, July 1989.
http://www.epa.gov/oar/oaqps/ozonetech/sco ga.pdf.
3.	Exemption for Low-Use Coatings, memo from G.T. Helms, EPA, August 10, 1990.
http://www.epa.gov/oar/oaqps/ozonetech/luc memo.pdf.
4.	40 CFR 70.6(a)(3) and (c)(1) require periodic monitoring in Title V permits.
Suggestions for Developing Approvable Provisions
1.	Recordkeeping requirements should be clear, explicit and independently enforceable.
Where a daily log is needed, for example, rules both should explicitly require the log and
should specify the frequency and units of each parameter to be recorded.
2.	Recordkeeping time frames and units should be consistent with operating and emission
requirements. Hourly BTU limits, for example, generally must be supported by hourly
BTU records.
3.	While continuous recordkeeping is required of some activities (e.g., power plant
emissions), no less frequent than daily records are generally needed to support the Clean
Air Act provision for daily violations. In the few cases where EPA has allowed less
frequent (e.g., weekly) recordkeeping, rules should specify that violations of the weekly
requirement are presumed to be separate violations for each day within the week.
4.	Rules that establish VOC content limits on materials (e.g., coatings), but do not establish
emission or use caps, can allow monthly recordkeeping for sources using only compliant
materials. Compliance with VOC content limits by averaging or trading, however, must
be supported by daily or more frequent recordkeeping. Compliance by add-on control
equipment must be supported by recordkeeping appropriate to the specific equipment,
which generally includes hourly or daily records of key operating parameters. VOC
content records should be required to include all thinners, solvents and other additives as
applied.
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5.	EPA has approved some coating rules that do not specify recordkeeping associated with
the general CTG size cutoff that applies CTG requirements only to sources with total
VOC emissions greater than 10 ton/year potential or 15 lb/day and 3 lb/hr actual. In
general, however, small sources should maintain records sufficient to demonstrate that
they have not exceeded this applicability threshold.
6.	Daily or as-used (recording use each day material is used) records are required for sources
that are larger than the general CTG size cutoff, but that comply with a 55 gal/year or
other non-compliant material exemption.
7.	SIP rules should require that all records be maintained for at least 2 years. Note that Title
V permits and MACT standards require 5 year record maintenance.
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Test Methods
SIP rules must specify all sampling and analysis methods needed to determine
compliance with the rule.
National Regulation/Policy/Guidance
Rules must specify test methods to meet the general enforceability requirement of
§110(a)(2)(A).
Suggestions for Developing Approvable Provisions
1.	As appropriate, SIP rules can reference or reprint EPA air test methods located in:
40 CFR Part 51, Appendix M (SIP methods).
40 CFR Part 60, Appendix A (EPA Reference Methods).
40 CFR Part 60, Material Approved for Incorporation by Reference (ASTM
methods). Only those specific ASTM methods which appear in 40 CFR 60 are
approved for use in SIPs.
40 CFR Part 61, Appendix B (HAP methods).
40 CFR Part 63, Appendix A (MACT methods).
2.	EPA methods used in other media, such as SW-846 for solid waste, are not automatically
approved for air pollution applications.
3.	All other test methods must be evaluated and approved by EPA before a rule containing
the test method can be approved into the SIP. Region IX maintains a list of California
methods that have been approved for SIPs. Submittal of test methods for EPA approval
should include the information and follow the procedure described in Region IX's "Test
Method Review & Evaluation Process. EPA has approved SIP rules that refer to
specific ASTM methods that are not directly tied to criteria pollutant emissions (e.g.,
gloss of paints) without full method evaluation.
4.	References to EPA-approved ASTM methods should include the full title and date of the
version being specified.
5.	References to EPA-approved state or local methods should include the full title but may
or may not specify the date of the version.
6.	If a SIP rule lists more than one EPA-approved test method for determining compliance,
the rule must also state that a violation determined by either test method shall constitute a
violation of the rule.
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Transfer Efficiency (TE)
Transfer efficiency requirements are included in some coating regulations and can be defined as
the following ratio:
Generally, total coating use and VOC emissions decrease as TE increases.
National Regulation/Policy/Guidance
1.	A Guideline for Surface Coating Calculations (EPA-340/1-86-016, July 1986) contains
sample TE calculations, http://www.epa.gov/oar/oaqps/ozonetech/guide sco.pdf.
2.	Past efforts such as TE tables in several NSPS (e.g., 40 CFR 60 Subpart EE) attempted to
assign generic TE values to coating application methods. Changes in operating
parameters significantly affect TE, however, and the generic values were rarely
meaningful because of the variety of substrate shape, size and other real-world operating
conditions. As a result, TE test protocols generally must be custom designed and
consider all parameters of specific operations.
3.	Http://www.epa.gov/etv/04/04 main.htm summarizes TE research on some specific
coating equipment. This information should not be used to show compliance with
specific TE requirements, but may help determine relative efficiency of different
equipment.
Suggestions for Developing Approvable Provisions
1.	Many rules specify acceptable coating methods rather than a TE requirement.
2.	SIP rules can specify TE values for alternative coating methods if test protocols to verify
TE are approved by EPA. Two generic EPA-approved TE protocols are Spray
Equipment Transfer Efficiency Test Procedure for Equipment Users (South Coast Air
Quality Management District, 5/24/89), and a protocol described in the Automobile
Topcoat Protocol Document (EPA-450/3-88-018). EPA was able to develop the latter
protocol because TE is relatively stable at automobile assembly plants where identical
items are continuously coated with automated equipment and few kinds of coatings.
3.	ASTM methods which address TE and may be useful in developing source-specific TE
protocols include:
a. D5286-95 Standard Test Methods for Determination of Transfer Efficiency Under
General Production Conditions for Spray Application of Paints.
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b.	D5327-97 Standard Practice for Evaluating and Comparing Transfer Efficiency
Under General Laboratory Conditions.
c.	D5066-91(1996) Standard Test Method for Determination of the Transfer
Efficiency Under Production Conditions for Spray Application of Automotive
Paints-Weight Basis.
d.	D5009-96 Standard Test Method for Evaluating and Comparing Transfer
Efficiency of Spray Applied Coatings Under Laboratoiy Conditions.
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Capture Efficiency
Capture efficiency is the fraction of emissions generated by a process that is directed to a
control device.
National Regulation/Policy/Guidance
1.	Guidelines for Determining Capture Efficiency (January 9, 1995), incorporated in an EPA
memo signed by John Seitz titled, Revised Capture Efficiency Guidance for Control of
Volatile Organic Compound Emissions (February 7, 1995).
http://www.epa.gov/ttncaaal/tl/meta/m28508.html.
2.	Rules that reference older capture efficiency guidance (e.g., 40 CFR 52.741 or 55 FR
26865 of June 29, 1990) should be updated. The 1995 guidance corrects errors in earlier
guidance and provides greater flexibility in meeting test requirements.
Suggestions for Developing Approvable Provisions
1.	Both capture efficiency and control device efficiency (or emission limit) must be
specified when regulating emissions with add-on control equipment.
2.	Rules must specify both the test methods and the calculation procedures to be used to
determine capture efficiency. Reference to 40 CFR 51 Appendix M, which contains
relevant EPA test methods, is not sufficient without also describing calculation
procedures or referencing EPA s 1995 guidance.
3.	Rules may specify a single combined capture and destruction efficiency if the methods for
determining it are clear.
4.	SIP submittals should describe how capture and control requirements were established.
Example Approvable Provision
Sources must install and operate an emissions control system designed and operated to
capture at least 90% of all VOC emissions from affected units and to direct them to a
control device designed and operated at 90% destruction efficiency or greater.
Capture efficiency shall be determined according to US EPA s Guidelines for
Determining Capture Efficiency, (January 9, 1995) and 40 CFR 51, Appendix
M, Methods 204-204F as applicable.
Destruction efficiency shall be determined by 40 CFR 60, Appendix A, Methods
18, 25 or 25A.
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Director's Discretion
Director's Discretion allows the state to approve alternatives to the applicable SIP without
following the SIP-revision process described in §110. Inappropriate Director s
Discretion has appeared in a wide variety of state rule provisions including those
regarding applicability, emission limits, operating requirements, recordkeeping,
monitoring, test methods and alternative compliance.
National Regulation/Policy/Guidance
1.	§ 110(a)(2)(A) requires that SIP regulations are enforceable.
2.	52 FR 45109 (November 24, 1987) states EPA s gen eral policy regarding director s
discretion.
Suggestions for Developing Approvable Provisions
1.	Director s Discretion may be appropriate if explicit and replicable procedures within the
rule tightly define how the discretion will be exercised to assure equivalent emission
reductions.
2.	Director s Discretion may be appropriate for provisions that do not fulfill or support any
federal SIP requirement.
3.	Director s Discretion may be appropriate if each exercise of discretion is approved by
EPA.
Example Approvable Provisions
1. Inclusion of replicable procedures. In many cases, such provisions do not need to require
the Director s approval, particularly those such as example (b) below where the rule
provides clear discrete compliance choices.
a. A person shall not use any coating with a VOC content in excess of the limits in Section E
unless all coating emissions from the facility are controlled by air pollution abatement
equipment which has been approved inwriting by the APCO and which has an overall
control efficiency of at least 85%. Overall control efficiency shall be determined
according to Section F.
Test methods and the 85% standard provide the replicable procedure. Note that the SIP
submittal to EPA must demonstrate that 85% is equivalent to the emission limits.
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b. For cold cleaning, one of the these devices approved by the APCO must be used:
(i)	a freeboard with a freeboard ratio equal to or greater than 0.75, or
(ii)	a water cover if the solvent is insoluble and heavier than water.
2.	Discretion for provisions that do not fulfill or support any federal SIP requirement.
Some dry cleaning rules regulate both perchloroethylene and petroleum solvent
processes. Directors Discretion for perchloroethylene provisions could be approved into
the SIP since EPA considers perchloroethylene an exempt VOC and does not require its
control in the SIP. Note that such discretion may cause other problems, if the
perchloroethylene provisions are intended to implement §112 MACT standards.
3.	Discretion approved by EPA.
This Section shall not apply to any person who complies with an alternate recordkeeping
plan that provides for an enforceable daily record which has been submitted to and
approved by the APCO, ARB and EPA.
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