Proposed Industrial Cleaning Solvents RACT Rule is Out

Does your facility use industrial cleaning solvents?  If so, you should be aware that the Pennsylvania Department of Environmental Protection (PADEP) has proposed a new rule, 25 Pa. Code 129.63a – Control of Volatile Organic Compound (VOC) Emissions from Industrial Cleaning Solvents, to adopt reasonably available control technology (RACT) requirements and RACT emissions limitations for sources of VOC from industrial cleaning solvents which are not regulated elsewhere is 25 Pa. Code 129 or 130.  An industrial cleaning solvent is any solvent used or applied in a cleaning activity that is formulated with one or more regulated VOCs.  Per 25 Pa. Code §129.63a, 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, spraying or a similar effort.  PADEP has proposed the rule in response to the 2006 Control Technique Guideline (CTG) document for industrial cleaning solvents.  States are required to implement RACT requirements for affected sources located in nonattainment areas within two years of publication of a final CTG.

Specifically, the proposed 25 Pa. Code §129.63a would implement control measures to reduce VOC emissions from industrial cleaning solvents used or applied during 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 proposed 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 that are subject to one or more of the current Pennsylvania RACT rules affecting surface coating operations should review the language of such rules to determine if the use of clean up solvents is specifically addressed by the rule.  If not, then the proposed rule could impact your operations.  Also, as the rule is currently written, facilities that recently completed a RACT proposal for industrial cleaning solvent operations may need to comply with the emissions limitations of 25 Pa. Code §129.63a(e), regardless of the alternative RACT proposal that was submitted to PADEP.  The proposed rule, published in the Pennsylvania Bulletin (Volume 47 Number 24, 47 Pa.B. 3356) on Saturday, June 17, 2017, can be reviewed here.  Comments on the proposed rule are due to PADEP by August 21, 2017.  If you would like assistance in developing comments in response to the proposed rule, please contact me at 610.933.5246 ext. 135 or cgiannascoli@all4inc.com.