New regulations intended to control VOC emissions from industrial cleaning operations could potentially impact many small businesses not already regulated elsewhere. The anticipated compliance date is September 1, 2018.
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 proposed regulations are intended to control VOC emissions from industrial cleaning operations. The draft final rulemaking is expected to be reviewed by the Environmental Quality Board on May 16, 2018 with the final rulemaking promulaged in August 2018.
The compliance date for the new regulations is expected to be September 1, 2018
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 draft final rulemaking, Control of VOC Emissions from Industrial Cleaning Solvents; General Provisions; Aerospace Manufacturing and Rework; and Additional RACT Requirements for Major Sources of NOx and VOCs (25 Pa. Code, Chapters 121 and 129), was discussed at the February 8th Air Quality Technical Advisory Committee meeting.
Presentation (PDF of PowerPoint)