Industrial Cleaning Solvents Rule – Finalized within Pennsylvania
Posted: September 11th, 2018Authors: Christina L.
On August 11, 2018, the Pennsylvania Department of Environmental Protection (PADEP) finalized the proposed Control of Volatile Organic Compounds (VOC) from Industrial Cleaning Solvents Rule as 25 Pa. Code 129.63a. This rule is in response to the Environmental Protection Agency’s (U.S. EPA’s) 2006 Control Technique Guideline (CTG): Industrial Cleaning Solvents document. States are required to implement reasonably available control technology (RACT) requirements for affected sources located in nonattainment areas within two years of publication of a final CTG.
The industrial cleaning solvent rule applies when an industrial cleaning solvent is used or applied in a cleaning activity at a cleaning unit operation, a work production-related work area or a part, product, tool, machinery, equipment, vessel, floor or wall. Per 25 Pa. Code §129.63a, an industrial cleaning solvent is a product formulated with one or more regulated VOCs that is used in a cleaning activity for a cleaning unit operation. A cleaning activity is defined as the use or application of an industrial cleaning solvent to remove a contaminant, such as an adhesive, ink, paint, dirt, soil, oil or grease, by wiping, flushing, brushing, soaking, dipping, spraying or a similar effort.
Per 25 Pa. Code §129.63a(e), facilities with total combined actual VOC emissions from applicable cleaning unit operations equal to or greater than 2.7 tons per 12-month rolling period, before consideration of controls, shall either (1) utilize compliant solvents (i.e., a VOC content less than or equal to 0.42 lb VOC/gal or a VOC composite vapor pressure less than or equal to 8 mm mercury at 68°F) or (2) install a VOC emissions capture system and add-on air pollution control device. Facilities with actual VOC emissions greater than 2.7 tons per 12-month rolling period will also be subject to additional work practice standards per 25 Pa. Code §129.63a(f). Facilities with actual VOC emissions less than 2.7 tons per 12-month rolling period will only be subject to the recordkeeping and reporting requirements of 25 Pa. Code §129.63a(h)(4).
PADEP anticipates that approximately 576 facilities within the Commonwealth of Pennsylvania will be subject to 25 Pa. Code §129.63a. 25 Pa. Code §129.63a(c) includes a list of exceptions and exemptions to 25 Pa. Code §129.63a. The list of exemptions includes various manufacturing operations as well as industrial cleaning solvent operations subject to a standard or specification required by the United States Department of Defense, Federal Aviation Administration or other Federal government entity (25 Pa. Code 129.63a(c)(2)(i).
If you are a major source of VOC or nitrogen oxides (NOX) you may be wondering how 25 Pa. Code §129.63a correlates to your new RACT requirements per 25 Pa. Code 129.96. A facility’s compliance with 25 Pa. Code §129.63a is completely separate compared to a facility’s compliance with 25 Pa. Code 129.96. Therefore, you may have performed a case-by-case RACT analysis in accordance with 25 Pa. Code 129.99. Since the industrial solvent rule was published subsequently, it will be interesting to see how this affects previously completed RACT case-by-case analyses.
I recommend taking a comprehensive look into cleaning solvents used at your Facility as soon as possible. Since there was no compliance deadline established within 25 Pa. Code §129.63a, your Facility is expected to be in compliance with the rule today. ALL4 is here to help you develop a strategy to comply with Pennsylvania’s Industrial Solvent Cleaning Rule. If you have questions about how 25 Pa. Code §129.63a affects your Facility or what your next steps should be, please reach out to me at (610) 933-5246, extension 135, or at firstname.lastname@example.org.