The Pennsylvania Department of Environmental Protection has proposed new regulations based on the EPA September 2006 Control Techniques Guidelines (CTG) for Industrial Cleaning Solvents. The CTG is intended to cover all industrial cleaning operations, that are not already regulated elsewhere.
DEP presented a powerpoint overview of the proposed draft regulations and the schedule for promulgation at the April 27, 2016 Small Business Compliance Advisory Committee meeting.
The proposed draft regulations are intended to control VOC emissions from industrial cleaning operations and will potentially impact a large number of small businesses in Pennsylvania.
The ICS category includes a variety of products used to remove contaminants such as adhesives, inks, paint, soil, oil and grease. Types of cleaning activies include operations such as parts cleaning, spray gun cleaning, spray booth cleaning, large and small manufactured components cleaning, eqiupment cleaning, line cleaning, tank cleaning and floor cleaning.
In the proposed regulations, compliant solvents must meet one or both of the following VOC limits:
• A VOC content less than or equal to 0.42 pounds of VOC per gallon (50 grams of VOC per liter of industrial cleaning solvent as applied.
• A VOC composite vapor pressure equal to or less than 8 mm mercury at 68oF (20oC) as applied.
Change to Applicability Threshold
Based on feedback on the 2014 initial draft proposed regulations, DEP made changes to provide greater flexibility to affected owners and operators and small businesses. The previous proposed applicability threshold was 15 pounds (6.8 kg) of VOC emissions per day, before consideration of controls. The current proposed applicability threshold is 2.7 tons (2,455 kg) of VOC emissions per 12-month rolling period, before consideration of controls.
If you generate less than 2.7 tons of VOC emissions per 12-month rolling period from cleaning unit operations you can still use non-compliant solvents as long as you maintain the required records.
Facilities that generate 2.7 tons of VOC emissions per 12-month rolling period or more from cleaning unit operations must either use compliant coatings or install an add-on air pollution control device.
The proposed rulemaking is expected to be reviewed by the Environmental Quality Board in July 2016 followed by publication in the Pennsylvania Bulletin and a public comment period.
The compliance date will be after January 1, 2017.