The Pennsylvania Environmental Quality Board has finalized amended regulations under 25 Pa. Code §129.63a to establish reasonably available control technology (RACT) requirements and emissions limitations for stationary sources of volatile organic compound (VOC) emissions from industrial cleaning solvents. The rule applies to facilities where industrial cleaning solvents are used or applied in a cleaning activity at a cleaning unit operation (a work production-related area or a part, product, tool machinery, equipment, vessel, floor or wall). The rule provides the following key definitions:
- “Industrial cleaning solvent” is defined as a product formulated with one or more regulated VOCs used in a cleaning activity for a cleaning unit operation; and
- “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.
Facilities at which the total combined actual VOC emissions from all subject cleaning unit operations are equal to or greater than 2.7 tons per 12-month period before the consideration of controls are required to use compliant solvents. Such solvents are required to have a VOC content less than or equal to 0.42 pounds per gallon (lb/gal), as applied, or a VOC composite vapor pressure less than or equal to 8 mmHg at 68◦F, as applied. As an alternative to the use of compliant solvents, the facility may use a capture system and add-on air pollution control device which reduces emissions by no less than 85% or no less than an equivalent efficiency calculated in accordance with the regulation.
In addition to the use of compliant solvents, subject industrial cleaning activities must also implement the following work practices and associated recordkeeping and reporting:
- Store all VOC-containing industrial cleaning solvents, used shop towels and related waste materials in closed containers.
- Ensure that mixing and storage containers used for VOC-containing industrial cleaning solvents and related waste materials are kept closed at all times except when depositing or removing these materials.
- Minimize spills of VOC-containing industrial cleaning solvents and related waste materials and clean up spills immediately.
- Convey VOC-containing industrial cleaning solvents and related waste materials from one location to another in closed containers or pipes.
- Minimize VOC emissions from cleaning of storage, mixing and conveying equipment.
- Minimize air circulation around cleaning unit operations.
The new regulations may affect a variety of facilities, however, several exceptions and exemptions are specified in §129.63a(c), including:
- Operations emitting VOCs from the use or application of consumer products subject to §130.201 - §130.471 for cleaning offices, bathrooms, or other areas that are not part of a cleaning unit operation or production-related work area;
- The use or application of solvents subject to a standard or specification required by the U.S. Department of Defense, Federal Aviation Administration or other Federal government entity;
- Industrial cleaning unit operations subject to: degreasing operations requirements under §129.63, halogenated solvent cleaning requirements under 40 CFR 63 Subpart T, or another standard under 25 Pa. Code Chapter 129 or Chapter 130;
- The use of solvents associated with the cleaning of screen printing equipment, as long as the industrial cleaning solvent used or applied has an as applied VOC content that does not exceed 4.2 pounds of VOC per gallon (lb VOC/gal); and
- Finally, facilities with total combined actual VOC emissions from all subject cleaning unit operations at the facility less than 2.7 tons per 12-month rolling period (before consideration of controls) are exempt from §129.63a.
The rule has been published in the Pennsylvania Bulletin with an effective date of August 11, 2018. Facilities should evaluate any industrial cleaning solvent usage/activity for potential applicability under this new rule. Affected facilities will need to immediately implement work practice and emission standards. Facilities with operations that meet one or more of the exceptions outlined in the rule should prepare records to document how exemption criteria is being met. For more information on the new rules, or for assistance with determining your facility's potential applicability, please contact Trinity staff members Christie Heath in the greater Philadelphia area at (610) 280-3902 or Christi Wilson in the greater Pittsburgh area at (724) 935-2611.