UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
          Office of Air Quality Planning and Standards
          Research Triangle Park, North Carolina 27711

                           OCT 15 1993


MEMORANDUM

SUBJECT:  Guidance for State Rules for Optional
          Enforceable Emissions Limits Based on
          Organic Compound (VOC) Use

FROM:     D. Kent Berry, Acting Director
          Air Quality Management Division, OAQP (MD-15)

TO:       Air Division Director, Regions I-X


The 1990 Amendments to the Clean Air Act (Act), including the title
V operating permits program, have made source status as a "major"
stationary source of considerably greater relevance to air quality
programs.  The lower major source thresholds now included in the
Act have made an unprecedented number of sources limajor." Many of
these sources are actually emitting air pollutants in amounts less
than the major thresholds but are major on the basis of their
potential to emit.  Certain categories of these sources are
comprised of sources that are in fact rather small and, in some
cases, are not addressed in detail by State air quality programs. 
Examples include auto body shops, dry cleaners, printers, and
surface coaters.

Many of these sources will seek federally-enforceable limits in
their potential to emit so as to avoid the obligation to obtain a
title V operating permit.  The Environmental Protection Agency
(EPA), State air agencies, and industry are all interested in
creating these emissions limits in the most efficient manner
consistent with having reasonable assurance that these are in fact
enforceable and being complied with.  There are a variety of
approaches available for creating federally-enforceable emissions
limits.  While the creation of federally-enforceable emissions
limits generally requires a source-specific evaluation created
through an approved State permitting program, EPA recognizes that,
for certain types of sources or emissions, the limits can be
created through more streamlined processes that do not involve
detailed review or public process for each individual source.









                                2
Probably the greatest need for such limits involves those sources,
such as auto body shops and surface coaters, that would be major on
the basis of use of raw materials containing VoclsTo aid States in
developing generic enforceable emissions limits for such sources,
we have developed technical guidance materials that States can use
in creating such requirements.  States seeking to use these
approaches may submit appropriate regulations as State
implementation plan revisions or, in the case of toxics, as section
112(1) plan provisions.  The technical guidance materials, along
with draft forms that States may use in implementing this process
are attached to this memorandum.  States may, of course, opt to
develop their own approaches for creating such documents.  The
attached language and forms are provided as technical support to
States and to provide an indication of what sorts of practices EPA
considers approvable.  Alternate approaches will be considered on
their individual merits.

For further information about this guidance, please contact Kirt
Cox at (919) 541-5399 or Eric Noble at (919) 541-5362.  To discuss
individual State regulatory provisions and issues, please contact
your Regional Office title V permits program contact.  Any
questions on practical enforceability should be brought to the
attention of Sally Mitoff at (703) 308-8692 or Clara Poffenburger
at (703) 308-8709.  The EPA is considering further options for use
of these streamlined procedures with other pollutants and is
interested in working with States in developing such approaches. 
Suggestions are invited and may by made by calling Mr. Cox or Mr.
Noble.

Attachments

cc:  Air Branch Chief, Regions I-X
     Operating Permits Program Contact, Regions I-X 
     Regional Counsel, Regions I-X
     Division Directors, OAQPS
     A.   Schwartz, OGC
     E.   Hoerath, OE
















Attachment 1


                 CRITERIA FOR A DRAFT MODEL RULE
             FOR VOLATILE ORGANIC COMPOUNDS (VOCIS)
            AND HAZARDOUS AIR POLLUTANT (HAP) SOURCES


PURPOSE: To provide a federally-enforceable mechanism by which
certain sources emitting VOC's may certify that they are not major
sources of those pollutants in a manner that can be recognized as
federally enforceable.  For the purpose of this guidance, I'VOCII
also encompasses HAP's as defined pursuant to section 112 of the
Clean Air Act (Act) that are VOC's (including those that are not
photochemically reactive).

APPLICABILITY: This approach is available to sources which opt to
assume limitations on the quantities of materials used in their
production processes which contain VOC'S.  It does not apply to
VOC's that are produced as part of the manufacturing processes. 
That is, this approach applies limits on emissions resulting from
the use of VOC-containing materials.  To that end, all the VOC's
and HAP's present in the source materials, such as paints and
solvents, are assumed to be emitted to the atmosphere (VOC in
equals VOC out).  Because this rule relies on simple calculation
procedures based on recordkeeping, sources seeking recognition of
emissions limits based on the use of emissions control devices,
which require more complex determinations, would not be able to
take advantage of this approach.  This approach would not be
available to sources which are subject to title V requirements for
other reasons (e.g., that have the potential to emit other
pollutants in major amounts).

     To be approvable, a State rule must require that the source
owner or operator specifically apply for coverage.  Such
applications could take the form of a relatively simple
certification of compliance with the applicability criteria and the
requirements of the rule.  An example of such a certification that
EPA would find acceptable is attached as Attachment 2.


BASIS FOR THE CRITERIA: This approach applies to sources which
agree to limit their annual emissions.  The basis for determining
compliance is the maintenance of records with respect to the use of
VOC-containing materials and the periodic submittal of this
information to the permitting authority.  States may elect to
streamline this process further by reducing the frequency and level
of detail of this reporting for those sources accepting limits on
emissions that are very substantially below the threshold for major
source status.  As described below, EPA suqqests three different
levels of reporting requirements fnr sources, depending on the
degree of limitation that the source opts to take. individual State
rules developed pursuant to this approach sliotild, of course,
replace the threshold percentages

                                2

listed herein with actual quantities in tons per year appropriate
to the areas subject to those rules.  For example, the threshold
for major source status for VOC's in ozone nonattainment-areas
designated as "serious" is 50 tons per year.

     1. Sources which commit only to limiting their VOC emissions
to less than the major source threshold.

     These sources would be required to do more comprehensive
recordkeeping and reporting than those smaller sources that accept
more limited emissions caps.  The EPA suggests that these
requirements include:

     a. Preparation of monthly consumption records of all materials
used containing VOC'S.  Sources would make a separate. record for
each such material.  These records would include the VOC and/or
individual HAP content of each such material on the same form. 
Table 2 of Attachment 3 provides an example of such a form that
States might find useful.

     b. Summation of VOC and individual HAP emissions on a monthly
or more frequent basis.  Table 1 of Attachment 3 is offered as an
example form.  Such reports would be submitted to the State agency
on a monthly basis.

     c. Submittal of an annual inventory to the reviewing agency
listing monthly VOC totals and total VOC emissions for the previous
year.

     d. Maintenance of purchase orders and invoices of
VOCcontaining materials which must be made available to the State
agency upon request for use in confirming the general accuracy of
the reports submitted pursuant to item b, above, regarding
materials usage.

     e. Retention of purchase orders and invoices for a period
sufficient to support enforcement efforts.

     f. Reporting of any exceedance of a requirement of this rule
within 1 week of occurrence.

     g. Certification of all submittals as to the truth
completeness, and accuracy of all information recorded and
reported.









                                3

     2. Sources which commit to limiting their VOC emissions to 25
percent of the major source threshold.

     These sources would also be required to meet all the above
requirements, except that annual reports would need to be submitted
annually, rather than monthly, for compliance with item b.

     3. Truly small sources which commit to limiting their VOC
emissions to 5 percent of the major source threshold.

     These sources could dramatically limit their recordkeeping and
reporting obligations.  Such sources need only report total gallons
of paints or solvents used on an annual basis.  Table 3 of
Attachment 3 could serve as a standard means for sources to
maintain this tabulation and could be submitted to satisfy the
annual reporting requirement of item c above.  Such sources would
be required to meet the same general obligations regarding purchase
records and general compliance reporting obligations as sources in
the other categories (items d-g).

ADDITIONAL CRITERIA:

     A source cannot rely on these emissions caps to justify
violation of rate-based emissions limits or other applicable
requirements of the Act.

     A State may require additional restrictions, e.g., limitations
on monthly VOC use in the peak ozone formation season.

     The State must make a list of the sources which are subject to
these requirements publicly available.

     All records shall be maintained at the site and available for
inspection on demand.

     A violation of these requirements is a violation of the SIP or
of the State's section 112 program, or both, depending on the
particular EPA approval mechanism used.  A violation also subjects
the source to enforcement action for failure to meet requirements
applicable to a major stationary source.

     There are, of course, a variety of ways in which States may
elect to implement this concept based on their particular air
quality program needs and policy inclinations.  The above is
offered as one suggestion that states might find useful.  States
wishing to develop alternative approaches should contact their EPA
Regional office to discuss their approvability.






Attachment 2

                       OPERATING AGREEMENT
                              FOR A
                    SURFACE COATING OPERATION

Source Name:
Address:
Source Description:

Emission Units: - re.g., Paint Spray Boothsl Number re.g.. 31

Material Used Over Past 12 Months:
Product                   Actual Usage
#VOC/gal*
    Maker       Type    Number    (MSDS) gal/day gal/mo  gal/year
1)
2)
3)
4)
5)
6)

Maximum Annual Material Usage in Future:
                    Product              Maximum Predicted Usage
                            #VOC/gal*
Maker Type Number (MSDS) gal/day gal/mo gal/year
1)
2)
3)
4)
5)
6)

*Sources may require this input to be in #VOC/gallon solids (paint
or solvent less water).


CERTIFICATION:

I certify that this source will not emit volatile organic compounds
or volatile hazardous air pollutants (as defined pursuant to
section 112 of the Clean Air Act) in excess of the amounts
specified in [indicate which of the 3 size classes].  I further
certify that all information submitted pursuant to this agreement
is true, accurate, and complete.

Plant Owner/Operator
Name (print)
Signature
Date