                  Equivalency By Permit Process
                                     ( 63.94 )

Ellison Technologies in Tennessee is proposing to install and operate 2 thermal spray coating operations that will be subject to 40 CFR Part 63, Subpart 6W (MACT for Plating and Polishing).  Subpart 6W requires sources to install fabric filters to control HAP emissions.  Ellison plans to use a cyclone to control HAPs rather than a fabric filter.  The Equivalency by Permit process in 40 CFR 63.94 will provide EPA a mechanism to approve the use of the alternative control device (standard), provided that Ellison can demonstrate compliance through testing.


Step 1:  Upfront approval of TN program

  TN submits letter to R4 requesting approval of EBP

	Must identify the Part 63 standard
	Must identify source or sources wanting to use EBP
	Must demonstrate that TN has an approved Title V program

 R4 drafts Federal Register to approve TN's EBP program

Proposal and Direct Final FR notices written
FR amends 63.99 (Delegated Federal Authorities)
63.90  -  99 implements Section 112(l) of the CAA (Part 63, Subpart E)
Gives TN the authority to implement EBP for Ellison's alternative standard


Step 2:  Approval of Title V permit terms and conditions to implement EBP

 TN drafts permit terms and conditions for EPA approval

Permit terms and conditions must be no less stringent than what Subpart 6W requires

 EPA approves permit terms and conditions by formal letter to TN

Ellison must comply with 6W as written until T5 permit is issued


Step 3:  Title V permit issuance

	Terms and conditions in T5 permit must be exactly as approved
	Gives Ellison the authority to presume normal operation using the cyclone
	Must complete successful performance test within 90 days 

