MEMORANDUM

          SUBJECT:  Compliance Issues for the Halogenated Solvent Cleaner MACT

          FROM:     Elliott J. Gilberg, Director
                    Chemical, Commercial Services and Municipal Division

          TO:       Regional Halogenated Solvent Cleaner MACT Contacts


     In response to questions raised by regulated sources, this memorandum was prepared to
clarify when annual compliance reports (§63.468(f)) and annual solvent emission reports
(§63.468(g)) are due for halogenated solvent cleaning machines subject to Subpart T.   In
addition, a brief discussion on implementing Test Method 307 is provided below.

     Section 63.468(f) requires owners or operators of batch vapor or in-line solvent cleaning
machines complying with the batch vapor and in-line cleaning machines standards to submit
annual reports by February 1 of each year for which the report is being made.  Section 63.468(g)
requires owner or operators of batch vapor or in-line solvent cleaning machines complying with
the alternative standards to submit a solvent emission report each year.  Much of the information
contained in these reports will be collected over each reporting year.  Because the compliance
date for existing sources (December 2, 1997) recently passed, it is not expected that the annual
reports or annual solvent emission reports be submitted by owners or operators of existing
machines until February 1, 1999.  In addition, it is not expected that owners or operators of new
sources subject to Subpart T submit annual reports or annual solvent emission reports until the
sources have operated for six months or more.  The attached halogenated solvent cleaning
compliance time line provides additional information on §63.468 reporting requirements.

     With regard to Test Method 307, it was recently brought to our attention that the
"inclined liquid level indicator" referenced in the test methodology is not readily available for
purchase.  EPA/state inspectors and compliance assistance providers should be aware that owners
and operators implementing Test Method 307 may be using alternative apparatus capable of
measuring the solvent level in solvent cleaning machines.  Attached is a schematic of an example
methodology that has been used in lieu of the inclined liquid level indicator.  

     Please refer any question on this memorandum to Tracy Back of my staff at (202) 564-
7076.

     cc:  Bruce Buckheit, ORE
          Paul Almodovar, OAQPS
          John Rasnic, OC
          EPA Regional Halogenated Solvent Cleaner MACT Coordinators
          Gerald Potamis, Region I
          Kenneth Eng, Region II
          Bernard Turlinski, Region III
          Beverly Spagg, Region IV
          David Kee, Region V
          John Hepola, Region VI
          Don Toensing, Region VII
          Mark Hestmark, Region VIII
          David Howekamp, Region IX
          Anita Frankel, Region X