Control Techniques Guidelines:

Industrial Cleaning Solvents 

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EPA 453/R-06-001 

September 2006 

Control Techniques Guidelines: 

Industrial Cleaning Solvents

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

RTP, NC

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TABLE OF CONTENTS 

Section Title Page No.

I. Introduction..........................................................................................................................1

II. Background and Overview ..................................................................................................2 

III. Applicability ........................................................................................................................5

IV. State and Local Regulatory Approaches..............................................................................6 

V. Recommended Control Options...........................................................................................7 

A. Recommended Control Measures............................................................................7 

1 Work Practices.............................................................................................7 

2 VOC Content Limit......................................................................................8 

3 Alternative Composite Vapor Pressure Limit..............................................8 

B. Suggested Exclusions...............................................................................................8 

1 Categories Listed for Regulation under CAA Section 183(e) .....................8 

2 Categories with Specific Exemptions under Bay Area 8-4-116 ..................9 

3 Categories with Specific Exemptions under Bay Area 8-4-117 ..................9 

4 Categories with Special Limits in South Coast AQMD Rule 

1171(c) and exemptions in 1171(h) .............................................................9 

VI. Impacts of Recommended Controls...................................................................................10 

VII. References..........................................................................................................................12

Appendix A. 1994 Control Techniques Guidelines: Industrial Cleaning Solvents ................. A-1 

Appendix B. Summary of Regulations in California Reviewed for Industrial Solvent 

Cleaning CTG ..................................................................................................................B-1

Appendix C. Summary of NAICS Codes for nonattainment facilities estimated to meet 

the applicability criteria recommended in the CTG.....................................................C-1 

Appendix D. Number of nonattainment facilities organized by State that are estimated to 

meet the applicability criteria recommended in the CTG........................................... D-1 

Appendix E. Costs and Emission Reductions for the Recommendation Concerning 

Solvent Substitution ....................................................................................................E-1 

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NOTICE

This report is issued by the Sector Policies and Programs Division of the Office of Air 

Quality Planning and Standards, U.S. Environmental Protection Agency to provide 

information to State and local air pollution control agencies. Mention of trade names and 

commercial products is not intended to constitute endorsement or recommendation for 

use. Copies of this report are available as supplies permit-from the Library Services 

Office (at 541-2777 or library.rtp@epa.gov ) of the U S. Environmental Protection 

Agency, Research Triangle Park, North Carolina 27711 They can also be downloaded 

from the FDMS e-docket websited (www.fdms.gov) by searching under Docket No. 

EPA-HQ-OAR-0535 or, for a nominal fee, from the National Technical Information 

Service, 5285 Port Royal Road, springfield VA 22161 (800) 553-NTIS) 

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I. Introduction

Clean Air Act (CAA) section 172(c)(1) provides that state implementation plans 

(SIPs) for nonattainment areas must include “reasonably available control measures” 

(RACM), including “reasonably available control techniques” (RACT), for sources of 

emissions. Section 182(b)(2) provides that for certain nonattainment areas, States must 

revise their SIPs to include RACT for sources of VOC emissions covered by a control 

techniques guidelines document (CTG) issued after November 15, 1990 and prior to the 

area’s date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the 

lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility.” 44 FR 53761 (Sept. 17, 1979). In subsequent Federal 

Register notices, EPA has addressed how states can meet the RACT requirements of the 

Act. Significantly, RACT for a particular industry is determined on a case-by-case basis, 

considering issues of technological and economic feasibility. 

CAA section 183(e) directs EPA to list for regulation those categories of products 

that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, 

from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., 

ozone nonattainment areas). EPA issued such a list on March 23, 1995, and has revised 

the list periodically. See March 23, 1995 (60 FR 15264); see also 71 FR 28320 (May 16, 

2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Industrial cleaning 

solvents are included on the current section 183(e) list. 

This CTG is intended to provide state and local air pollution control authorities 

information that should assist them in determining RACT for industrial cleaning solvents. 

In developing this CTG, EPA, among other things, evaluated the sources of VOC 

emissions from the use of industrial cleaning solvents and the available control 

approaches for addressing these emissions, including the costs of such approaches.

Based on available information and data, EPA provides recommendations for 

determining RACT for the categories at issue in this document. 

States can use the recommendations in this CTG to inform their own 

determination as to what constitutes RACT in their particular areas. The information 

contained in this document is provided only as guidance. This guidance does not change, 

or substitute for, applicable sections of the CAA or EPA’s regulations; nor is it a 

regulation itself. This document does not impose any legally binding requirements on 

any entity. It provides only recommendations for state and local air pollution control 

agencies to consider in determining RACT. State and local pollution control agencies are 

free to implement other technically-sound approaches that are consistent with the CAA 

and EPA’s implementing regulations 

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 The recommendations contained in this CTG are based on data and information 

currently available to EPA. These general recommendations may not apply to a 

particular situation based upon the circumstances of a specific source. Regardless of 

whether a State chooses to implement the recommendations contained herein through 

State rules, or to issue State rules that adopt different approaches for RACT for VOCs for 

offset lithographic printing and letterpress printing, States must submit their RACT rules 

to EPA for review and approval as part of the SIP process. EPA will evaluate the rules 

and determine, through notice and comment rulemaking in the SIP process, whether they 

meet the RACT requirements of the Act and EPA’s regulations. To the extent a State 

adopts any of the recommendations in this guidance into its State RACT rules, interested 

parties can raise questions and objections about the substance of this guidance and the 

appropriateness of the application of this guidance to a particular situation during the 

development of the State rules and EPA’s SIP approval process. 

 CAA section 182(b)(2) provides that a CTG issued after November 15, 1990 and 

before the date of attainment must include the date by which States must submit SIP 

revisions in response to the CTG. States subject to section 182(b) should submit their 

SIP revisions within one year of the date of issuance of this final CTG. States subject to 

CAA section 172(c)(1) may take action in response to this guidance, as necessary to 

attain.

The remainder of this document is divided into five (5) sections. Section II 

Provides Background and Overview, which lists the cleaning (unit) operations associated 

with industrial cleaning solvents and identifies the sources of VOC emissions from those 

cleaning operations. Section III describes the emissions threshold that applies to this 

CTG. Section IV summarizes state and local regulatory approaches for addressing such 

emissions. Section V describes the available control options for addressing VOC 

emissions and. lists categories of industries we are recommending for exclusion from this 

CTG. This information supplements the survey of state CTG summarized in Appendix B 

of the 1994 ACT. Section VI provides our proposed recommendations for RACT for 

industrial cleaning solvents.), and discusses the cost-effectiveness of the recommended 

controls. Section VII provides references. 

II. Background and Overview

This category of consumer and commercial products includes the industrial 

cleaning solvents used by many industries. It includes a variety of products that are used 

to remove contaminants such as adhesives, inks, paint, dirt, soil, oil, and grease.

Contaminants are removed from parts, products, tools, machinery, equipment, vessels, 

floors, walls, and other work production related work areas for a variety of reasons 

including safety, operability, and to avoid product contamination. The cleaning solvents 

used in these (unit) operations are, in many cases, generally available bulk solvents that 

are used for a multitude of applications not limited to cleaning. For example, petroleum 

distillates may be used as a cleaning solvent, as a paint thinner, or as an ingredient used 

in the manufacture of a coating, such as paint. Because a portion of all solvents 

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evaporate during use, such solvent-based cleaning materials result in large amounts of 

emissions of VOC. 

In 1994, EPA completed a study of industrial cleaning solvents that characterized 

cleaning operations carried out within six focus industries (automotive, electrical 

equipment, magnetic tape, furniture, packaging, and photographic supplies) to evaluate 

sources of evaporative emissions from VOC solvents used as cleaning materials. (See 

Reference 1 in the reference section for the full citation to these documents.) 

We believe that the range of cleaning activities performed in these focus 

industries provided a good variety of cleaning operations for the study, and that the 

information obtained relevant to VOC emission sources and possible control techniques 

can be applied to virtually any industry. 

Data collected by EPA during the development of the 1994 Alternative Control 

Techniques (ACT) (to be referred to as 1994 ACT or ACT) document for industrial 

cleaning solvents show nationwide usage of VOC solvent from six industries studied is 

more than 360,000 Mg/yr (400,000 tpy).1

 We also reported in the ACT document that 

the estimated total VOC solvent usage for cleaning by all U.S. industry was more than 

910,000 Mg/yr (1 million tpy). This number was estimated using multiple sources, and 

not based on data from the facilities we surveyed. In general, VOC emissions occur from 

industrial cleaning solvents through evaporation during cleaning activities such as 

wiping, flushing, and brushing, as well as from storage and disposal of used shop towels 

and solvent. 

The 1994 ACT included as Appendix A to this CTG. The document provides a 

thorough discussion of cleaning activities and types of cleaning operations in a wide and 

diverse assortment of industrial facilities, frequently used cleaning solvents, and the 

practices (or lack of) for managing solvents. It, also, identifies a methodology for 

estimating VOC emissions by cleaning operation, discusses control techniques for 

addressing such emissions, the costs-benefit of setting up a solvent accounting and 

management system, and other items. 

EPA surveyed 34 facilities in the six focus industries and collected approximately 

300 individual cleaning data sets or unit operation systems (UOS) representing emissions 

from the nine types of cleaning unit operations (UO) in the focus industries for the ACT 

document. These nine UO are identified below together with the VOC emission 

distribution based on the UOS material balance data: 

1 Spray Gun Cleaning (50 percent); 

2 Spray Booth Cleaning (14 percent); 

3 Large Manufactured Components Cleaning (14 percent); 

4 Parts Cleaning (7.0 percent); 

5 Equipment Cleaning (6.9 percent); 

6 Line Cleaning (3.6 percent); 

7 Floor Cleaning (2.9 percent); 

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8 Tank Cleaning (0.82 percent); and 

9 Small Manufactured Components Cleaning (0.44 percent). 

Because spray gun cleaning (one of the UO) accounted for 50 percent of the 

emissions from cleaning operations, the ACT dedicated appendix G of the document to 

describe procedures for determining, in a consistent way, VOC emissions from a number 

of subcategories of spray gun cleaning. The subcategories represented the range of gun 

cleaning practices in the focus industries in 1994. However, due to the availability of 

enclosed gun cleaners today, states have disallowed gun cleaning methods that result in 

high solvent emissions. 

The purpose of identifying these UO is to assist State and local agencies in 

identifying the sources of VOC emissions from cleaning activities and to provide a 

structure for developing and applying control techniques to mitigate VOC emissions from 

industrial cleaning solvents used in these UO. This CTG is intended to cover all 

industrial cleaning operations. EPA believes that all categories of industrial cleaning 

operations are represented or can be classified under one of the nine cleaning categories 

listed in this CTG. See also ACT (describing nine UO in further detail). EPA has not, to 

date, identified any industrial cleaning activity that would not fall within one of the nine 

UO, but even if such a situation occurred, this CTG is intended to cover all industrial 

cleaning operations irrespective of whether they can be properly categorized as one of the 

nine UO. That said, we recognize that there are several cleaning operations that may 

already be the subject of regulatory requirements, and we urge States to consider the 

specific industries and operations in their jurisdictions and any existing regulatory 

requirements applicable to those operations and tailor their RACT rules in response to 

this CTG accordingly. Finally, janitorial supplies used for cleaning offices, bathrooms 

or other similar areas are not covered by this CTG. 

The ACT document provided a quantitative overview of cleaning solvents used 

and a model for accounting and tracking solvent usage--a solvent management system. It 

also provided a methodology for calculating emissions in a consistent way. A brief 

outline on how to manage emissions from cleaning operations is presented in Fig 4-1 of 

the ACT (see Appendix A). 

Although the industrial cleaning solvent product category includes a variety of 

different products with differing VOC contents, and although these products are used in 

different ways by a wide range of industries, we believe that there are several basic 

approaches to achieve VOC emission reductions. First, the users of the products can 

control emissions through work practices targeted at the activities and sources of 

emissions specific to the user’s industry (e.g., keeping solvent containers covered, 

properly storing and disposing of used shop towels and solvent, etc.). Second, users can 

also reduce overall VOC emissions through solvent substitution (e.g., use of low - VOC, 

no -VOC, or low -vapor pressure solvents). They can also reduce VOC emissions by 

using add-on controls, modifying equipment, or upgrading to using a lower emitting 

cleaning technology. 

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Theoretically, solvent substitution could be achieved at the point of manufacture 

or at the point of use, but in practice it is usually the user who selects the solvent or 

mixture of solvents to use in the various industrial cleaning operations throughout a 

facility. These general approaches are effective strategies to achieve significant emission 

reductions from this product category, notwithstanding the variation in the products, their 

users, and their specific uses. 

III. Applicability (Scope of Sources)

This CTG applies to industries that have to use organic solvent for cleaning unit 

operations such as mixing vessels (tanks), spray booths, and parts cleaners, where a 

facility emits at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls in 

an ozone nonattainment area. The cleaning activities for removal of foreign material 

from substrate being cleaned include actions (activities) such as wiping, flushing, or 

spraying.

The applicability threshold of 6.8 kg/day (15 lb/day) of VOC is consistent with 

the threshold level contained in many previous final CTGs. It is also consistent with the 

purpose of the section 183(e) program. In section 183(e), Congress directed EPA to 

assist States in achieving VOC emission reductions from consumer and commercial 

products. These products individually may result in relatively small amounts of VOC 

emissions, but, in the aggregate, they contribute significantly to ozone formation in 

nonattainment areas. Given the nature of the products and sources at issue here, we 

believe that the 6.8 kg/day (15 lb/day) of VOC per day applicability threshold is 

appropriate. For purposes of determining whether this threshold is met at a given facility 

performing industrial cleaning operations, the facility should consider the VOC emissions 

from the use of organic solvent cleaning prior to controls. 

 Some industries with solvent cleaning operations are presently covered by an 

existing CTG (e.g., aerospace). Other industries with solvent cleaning operations may be 

the subject of a CTG that is presently being developed (e.g., printing) or may be the 

subject of a future CTG (e.g., automobiles and light trucks coatings). CTGs often 

recommend control approaches for a particular industry, like printing, and those 

approaches achieve important VOC emission reductions. We recommend that States 

consider excluding from the applicability of their State rules promulgated in response to 

this CTG, those industries relevant to the product categories listed for regulation under 

CAA section 183(e). See 71 FR 44540. We list below the section 183(e) industries that 

the States may wish to consider excluding from the applicability of their State rules. 

States should also consider the structure of the Bay Area cleaning solvent rule, which 

ensures that particular cleaning activities are only subject to one set of requirements, as 

opposed to duplicative requirements. For example, under the Bay area structure, there is 

a cleaning exemption that is common to all Bay Area AQMD rules. There are cleaning 

standards found in each individual rule, such as metal parts and products, plastic parts, 

etc. The exemption exempts cleaning that is subject to Regulation 8, Rule 16, which 

governs cleaning in vats, containers, cold cleaners, vapor degreasers, etc, in which there 

is some standing liquid, either in the cleaning area or a remote reservoir. “The only intent 

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here is to make it clear that only one rule applies to a type of cleaning operation.” For 

example, cleaning a metal part by dipping in liquid solvent is subject to a 50 g/l standard 

in Reg. 8, Rule 16. Wipe cleaning that same part is subject to a 50 g/l standard in Reg. 8, 

Rule 19. Cleaning of spray booths by solvent wiping, a stationary structure would be 

subject to the architectural coating rule, Regulation 8, Rule 3. Consequently, a State may 

wish to exclude industrial categories to parallel the Bay Area rule overall structure or 

may wish to follow a structure where all the wipe cleaning and cleaning in a container are 

kept together and then address the specific needs of various types of substrates all within 

the wipe cleaning standards. The South Coast AQMD is one example of a California 

district that uses this format (e.g., AQMD Rule 1171(c)). 

We estimate that there are approximately 7360 facilities in nonattainment areas 

for 8-hour ozone standards of which 2520 would be potentially affected because they 

meet the 6.8 kg/day (15 lb/day) of VOC applicability threshold for this CTG. Of these 

facilities, we estimate that approximately 1290 are located in areas for which RACT is 

required under section 182(b) of the CAA. We derived these number based on available 

information concerning the use of industrial cleaning solvents from the 2002 EPA 

National Emissions Inventory. The cost aspects are presented in greater detail in 

Appendix E. 

IV. State and Local Regulatory Approaches

We reviewed regulations issued by three different local air pollution control 

authorities in California. These regulations are aimed at reducing VOC emissions from 

industrial cleaning solvents by combining work practice standards and placing limits on 

the VOC content of the solvent used. They also provided as an additional option the use 

of add-on controls. The work practice standards are similar for the air pollution control 

authorities. However, the VOC content limits required for certain applications and the 

add-on control overall efficiency level that would need to be met, vary by district. 

Appendix B presents a summary of the industrial solvent cleaning regulations in the three 

California air pollution control districts. 

EPA also reviewed various State rules including: 

1 Michigan; 

2 Florida;

3 New Jersey; and 

4 Indiana.

The above State rules do not require VOC content limits. Instead, equipment 

standards, work practices, and recordkeeping are required by sources. Regulations in 

these States on parts cleaners have an overall similar structure. However, there are 

specific differences. For example, the New Jersey rule applies to cold cleaning machines 

that use 2 gallons or more of solvents with greater than 5 percent (by mass) VOC. This is 

similar to a VOC limit of approximately 50 g VOC/liter. Both New Jersey and Illinois do 

not allow the use of solvents with a vapor pressure greater than 1 mm Hg (at 68 degrees 

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F) in parts cleaners --“cold cleaning machines.” The other States listed do not have 

similar provisions. 

V. Recommended Control Options

The recommended measures for controlling emissions of VOC from the use, 

storage, and disposal of industrial cleaning solvents includes work practice standards, 

limitations on VOC content of the cleaning materials, and an optional alternative limit on 

composite vapor pressure of the cleaning materials. They also include the use of add-on 

controls with an overall emission reduction of at least 85 percent by mass. The first two 

recommendations and the last one are based on the Bay Area AQMD rule. Following the 

section discussing recommended control measures is a discussion of the industrial 

categories that we are recommending that States and local agencies consider excluding 

from applicability of these recommended control measure. 

States can adopt these recommendations and include them in their SIP revisions 

or adopt RACT rules that provide for different approaches. For example, for a given 

industrial sector or cleaning operation, where appropriate, a State may offer the flexibility 

of requiring only work practices. Regardless of the approach a State pursues in its RACT 

rule, EPA will review the State RACT rule as part of the SIP approval process and will 

make the final determination as to whether the State rule comports with the RACT 

requirements of the Act. 

When developing RACT measures for industrial cleaning operations, we suggest 

specific category exclusions, similar to the ones provided for the Bay Area and South 

Coast rules and that State and local agencies consider the specific industries and 

operations in their jurisdictions and the individual requirements of those operations and 

tailor their rules to those specific scenarios accordingly. 

Furthermore, in considering existing cleaning requirements as bases for specific 

exemptions from their general industrial cleaning solvents rules, State and local agencies 

should take into account how current those measures are. EPA believes that more recent 

rules are likely to be more effective than older, possibly outdated, rules. We remind the 

States that the ultimate determination of whether any specific State or local measures 

meet any applicable RACT requirement will occur during the notice and comment 

rulemaking process associated with EPA action on SIP submissions. For ease of 

reference, in discussing the control recommendations below, we refer to the nine unit 

operations that we believe are representative of all industrial cleaning operations.

A. Recommended Control Measures

1. Work Practices 

Recommended work practices that will help reduce VOC emissions from the use, 

handling, storage, and disposal of cleaning solvents and shop towels include:

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1 Covering open containers and used applicators;

2 Minimizing air circulation around cleaning operations; 

3 Properly disposing of used solvent and shop towels; and 

4. Implementing equipment practices that minimize emissions (e.g., keeping arts 

cleaners covered, maintaining cleaning equipment to repair solvent leaks, 

etc.).

2. VOC Content Limit 

We recommend a generally applicable VOC content limit of 50 grams VOC per 

liter (0.42 1b/gal) of cleaning material for each of the nine cleaning UO identified in the 

Background and Overview section, unless emissions are controlled by an emission 

control system with an overall control efficiency of at least 85 percent. This limit is 

modeled on the “general use” category of the Bay Area AQMD solvent cleaning 

regulations, taking into account the specific exclusions provided for in the Bay Area 

AQMD rule and described below. 

3. Alternative Composite Vapor Pressure Limit 

In addition to the recommended VOC content limit, EPA is recommending 

inclusion of a composite vapor pressure limit of 8 millimeters of mercury (mmHg) at 20 

degrees Celsius, as (1) a replacement for the 50 g/l VOC content limit entirely; or (2) an 

alternative limit that may be used in lieu of the 50 g/l VOC content limit for specific 

operations as determined by the State or local agency. 

B. Suggested Exclusions

This section includes product categories that EPA has listed for regulation under 

section 183(e) as well as categories of cleaning operations that are specifically excluded 

from applicability in Bay Area Regulation 8 rule 4. The Bay Area exclusions are 

provided as examples for consideration by the State and local agencies.

1. Categories Listed for Regulation under CAA Section 183(e) 

We recommend that the States exclude from applicability those cleaning 

operations in the following categories listed for regulation under CAA section 183(e):

1 Aerospace coatings; 

2 Wood furniture coatings;

3 Shipbuilding and repair coatings; 

4 Flexible packaging printing materials; 

5 Lithographic printing materials;

6 Letterpress printing materials; 

7 Flat wood paneling coatings;

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8 Large appliance coatings; 

9 Metal furniture coatings; 

10 Paper film and foil coating; 

11 Plastic parts coatings; 

12 Miscellaneous metals parts coatings; 

13 Fiberglass boat manufacturing materials; 

14 Miscellaneous industrial adhesives; and 

15 Auto and light-duty truck assembly coatings. 

2. Categories with Specific Exemptions under Bay Area 8-4-116 

1 Electrical and electronic components; 

2 Precision optics; 

3 Numismatic dies; 

4 Stripping of cured inks, coatings, and adhesives; 

5. Cleaning of resin, coating, ink, and adhesive mixing, molding, and 

application equipment; 

5 Research and development laboratories; 

6 Medical device or pharmaceutical manufacturing; and 

7 Performance or quality assurance testing of coatings, inks, or adhesives. 

3. Categories Subject to Specific Rules and Exemptions under Bay Area 8-4-

117

1 Architectural coating; 

2 Metal container, closure, and coil coating; 

3 Paper, fabric, and film coating; 

4 Light and medium duty motor vehicle assembly plants; 

5 Surface coating of metal furniture and large appliances; 

6 Surface coating of miscellaneous metal parts and products; 

7 Graphic arts printing and coating operations; 

8 Coating of flat wood paneling and wood flat stock; 

9 Magnet wire coating operations; 

10 Aerospace assembly and component coating operations; 

11 Semiconductor wafer fabrication operations; 

12 Surface coating of plastic parts and products; 

13 Wood products coating; 

14 Coating, ink, and adhesive manufacturing; 

15 Flexible and rigid disc manufacturing; 

16 Marine vessel coating; 

17 Motor vehicle and mobile equipment coating operations; and 

18 Polyester resin operations. 

Appendix C provides a summary of NAICS Codes for nonattainment facilities estimated 

to meet the applicability criteria recommended in this CTG. 

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4. Categories with special limits in South Coast AQMD Rule 1171(c) 

In addition to the Bay Area exclusions, and as discussed earlier, the more 

stringent South Coast AQMD “general use” limit of 25 g/l (0.21 lb/gal) is accompanied 

by higher limits for several individual operations. Although we are not recommending 

higher limits for these categories beyond the 50 g/l limit in this CTG, State and local 

agencies should be aware of the individual performance requirements in these categories 

when developing individual State or local cleaning solvent rules based on the specific 

industries within their jurisdictions. We suggest that State and local agencies refer to the 

South Coast rule for more details on subcategories and specific limits. The broad 

categories are: 

1. Product cleaning during manufacturing process or surface preparation for 

coating; 

 2. Repair and maintenance cleaning; 

3. Cleaning of coatings or adhesives application equipment; 

4. Cleaning of ink application equipment; and 

5. Cleaning of polyester resin application equipment. 

VI. Impacts of Recommended Controls 

EPA estimates that there are approximately 2,524 facilities in ozone 

nonattainment areas that would be affected by this CTG. These facilities had emissions 

that exceed the emission threshold of 6.8 kg (15 lb) of VOC per day. Total aggregate 

VOC emissions from solvent cleaning operations from these nonattainment sources are 

approximately 64,000 Mg/yr (71,000 tpy). Appendix D summarizes the potential number 

of facilities and their emissions that may be subject to this CTG by State. 

EPA used studies published by the Bay Area AQMD to estimate the cost of 

compliance for the measures recommended in this CTG. According to these estimates, 

EPA believes that affected sources may either incur minimal additional costs or realize a 

savings on a case - by - case basis, depending primarily on facts such as how much they 

currently spend to operate high-VOC content solvent - based parts cleaners, and the cost 

of organic solvent disposal. The Bay Area AQMD studies indicate that there is a cost 

savings associated with replacing high-VOC cleaning materials with low-VOC, 

waterbased cleaning materials. 

The total VOC emissions from solvent cleaning operations (64,000 Mg/yr (71,000 

tpy) were determined by first assigning the VOC emissions from solvent cleaning 

operations at each facility using the 2002 National Emissions Inventory (NEI) database to 

one of two general groups: parts cleaners, and other solvent cleaning operations. The 

parts cleaner subgroup included emissions from all SCC codes with a “degreasing” or 

cold solvent cleaning/stripping classification in SCC_L3. VOC emissions from this 

subcategory are approximately 4,000 Mg/yr (4,400 tpy). The other solvent cleaning 

operations included all other SCCs that were identified as solvent cleaning operations.

The VOC emissions from the other subgroup are approximately 60,000 Mg/yr (66,000 

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tpy). These emissions do not include emissions from halogenated parts cleaners. 

Consistent with our recommendations to the States, we did not include in these emissions 

those from facilities represented by the 183(e) source categories listed in section V. They 

also do not include remissions from research and development facilities, or emissions 

from manufacturing and assembly of electrical and electronic components. 

Costs associated with switchover to aqueous parts cleaners (cleaning systems or 

washers) include the initial cost of equipment, solvent costs, filters, electricity, and waste 

disposal costs. Many of these costs are also incurred when operating higher VOC solvent 

cleaners. A study on parts cleaners, for example, has shown typical annual costs for 

mineral spirits parts cleaners as $1,453. Estimates on annual costs for aqueous parts 

cleaners, in comparison, range from $1,171 to $1,480, thus showing that facilities could 

either face a slight increase in cleaning costs or realize a cost savings as a result of the 

switchover.6

Facilities may either incur minimal additional costs or realize a savings on a caseby-case basis, depending primarily on how much they currently spend to operate the high 

VOC content solvent-based parts cleaners, the cost of organic solvent disposal, and air 

emission fees levied for VOC emissions. A study provided by the California Bay Area 

AQMD shows that the cost-effectiveness for meeting the 50 grams of VOC per liter of 

cleaning material limit for a parts cleaner is estimated at $1,832/Mg (1,664/ton).6,7 This 

represents the annual cost of compliance (industry wide) for parts cleaners (Table 4 of the 

Bay Area Regulation 8, Rule 16). We determined that replacing high VOC content 

cleaning materials with low VOC water-based cleaning materials for the other cleaning 

(unit) operations (e.g., cleaning of large manufactured surfaces, tank cleaning, and gun 

cleaning, etc.) would result in an estimated cost savings of $1,460/Mg. For this 

calculation we only considered the cost-difference in cleaning material cost and costdifference in waste disposal cost. The savings is a result of lower cost of aqueous 

cleaners which offset the increase in waste disposal cost for aqueous cleaners. Appendix 

E explains how we calculated the cost of applying the solvent substitution option for 

reducing VOC emissions from the use of organic cleaning solvents. 

As explained above, this CTG is guidance for the States to use in determining 

RACT for VOC from industrial cleaning solvents. State and local pollution control 

agencies are free to implement other technically-sound approaches for RACT that are 

consistent with the CAA and EPA’s implementing regulations. Accordingly, there is 

necessarily some uncertainty in any prediction of costs and emission impacts associated 

with the recommendations in this document. Nevertheless, assuming that States adopt 

the recommendations in this CTG or comparable approaches, EPA anticipates a net cost 

savings. We based this prediction on an assumption that substitution of low-VOC 

materials for high-VOC materials is possible for all uses. Because this assumption is not 

true for some applications, this prediction may not be valid in all cases. 

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12

VII. References

1. U.S. Environmental Protection Agency, Alternative Control Techniques 

Document—Industrial Cleaning Solvents, February 1994. EPA-453/R-94-015.

(NTIS PB 94-181-694). 

2. Bay Area Air Quality Management District, Regulation 8, Rule 16: Solvent 

Cleaning Operations. http:// www.arb.ca.gov/DRDB/BA/CURHTML/R8-

16.PDF, (Accessed June 27, 2006). 

3. South Coast Air Quality Management District, Rule 1171: Solvent Cleaning 

 Operations. 

4. Sacramento Metropolitan Air Quality Management District, Rule 466: Solvent 

 Cleaning. 

5. U.S. Environmental Protection Agency, Control of Volatile Organic Emissions 

from Solvent Metal Cleaning, November 1977. EPA-450/2-77-022. 

6. Bay Area Air Quality Management District, Staff Report: Proposed Amendments 

to BAAQMD Regulation 8, Rule 16: Solvent Cleaning Operations, September 

2002.

7. South Coast Air Quality Management District, Staff Report for Proposed 

Amendment to Rule 1171 - Solvent Cleaning Operations, August 15, 1996. 

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CTG: Ind. Clng. Solv. pg18 of 290 
A-1

Appendix A 

1994 Control Techniques Guidelines: Industrial Cleaning Solvents 

.

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B-1

Appendix B 

Summary of Regulations in California Reviewed for Industrial 

Cleaning Solvents CTG 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg255 of 290 
B-3

Appendix B. Summary of Regulations in California Reviewed for Industrial Solvent 

Cleaning CTG 

Regulation Exemptions Standards 

BAAQMD

Regulation 8, 

Rule 16 

x Semiconductor Solvent 

Cleaners

x Aerospace Stripping 

Operations

x Vapor Phase Solder 

Reflow Operations 

x Dry Cleaning Operations 

x Stripping Operations 

x Aerospace components 

x Electrical and electronic 

components 

x Precision optics 

x Medical devices 

xCleaning of resin, coating, 

ink, and adhesive mixing, 

molding and application 

equipment 

xCleaning associated with 

research and development 

operations.

xPerformance testing to 

determine coating, 

adhesive or ink 

performance 

xTesting for QA/QC 

purposes

xWork practices to minimize 

emissions, and 

xUse solvent with VOC 

content of 50 g/l or less, or 

xVent emissions to an 

emission control device 

achieving 90% reduction 

SMAQMD

Rule 466 

x Cleaning of solar cells, 

laser hardware, scientific 

instruments, and high 

precision optics, 

x Cleaning of cotton swabs 

to remove cottonseed oil 

before cleaning of high 

precision optics 

x Cleaning of paper-based 

gaskets and clutch 

assemblies where rubber is 

bonded to metal by means 

of an adhesive 

x Cleaning of application 

xWork practices to minimize 

emissions, and 

xVent emissions to an 

emission control device 

achieving 95% reduction 

through a collection system 

with a collection efficiency 

of 90%, or 

xUse solvent with VOC 

content of 50 g/l or less, 

except for the following 

activities: 

o 500 g/l for product 

cleaning during 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg256 of 290 
B-4

equipment used to apply 

coatings on satellites and 

radiation effect coatings, 

x Cleaning of electrostatic 

coating application 

equipment 

x Janitorial cleaning 

x Cleaning of sterilization 

ink indicating equipment if 

solvent usage is less than 

1.5 gpd. 

x Cleaning with aerosol 

provided that 160 fluid oz 

or less of aerosol is used 

per day 

manufacture of 

electrical apparatus 

components and 

electronic

components 

o 800 g/l for product 

cleaning during 

manufacture of 

medical devices and 

pharmaceuticals, 

platelets,

o 900 g/l for repair 

and maintenance of 

electrical apparatus 

components and 

electrical

components 

o 800 g/l for repair 

and maintenance of 

medical devices and 

pharmaceuticals 

tools, equipment, 

and machinery, and 

platelets

o 600 g/l for repair 

and maintenance of 

medical devices and 

pharmaceuticals 

general work 

surfaces

o 300 g/l for solvent 

based architectural 

coating application 

equipment 

SCAQMD 

Rule 1171 

x Cleaning carried out in 

batch loaded cold cleaners, 

vapor degreasers, 

converyorized degreasers,

x Motion picture film 

cleaning equipment 

x Dry cleaning subject to 

Rule 1102 or 1422 

x Semiconductor 

manufacturing subject to 

Rule 1164 

xWork practices to minimize 

emissions, and 

xVent emissions to an 

emission control device 

achieving 95% reduction 

through a collection system 

with a collection efficiency 

of 90%, or 

xUse solvent with VOC 

content of 25 g/l or less, 

except for the following 

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CTG: Ind. Clng. Solv. pg257 of 290 
B-5

x Aerospace assembly and 

component manufacturing 

operations (except coating 

application equipment 

cleaning, and storage and 

disposal of VOC 

containing materials used 

in solvent cleaning 

operations) subject to Rule 

1124

x Resin manufacturing 

subject to Rule 1141 

x Coatings and ink 

manufacturing subject to 

Rule 1141.1 

x Janitorial cleaning 

x Stripping of cured 

coatings, cured ink, or 

cured adhesives 

The following do not have to 

comply with VOC content limits 

in the rule: 

xCleaning solar cells, laser 

hardware, scientific 

instruments, and high 

precision optics 

xMedical and 

pharmaceutical facilities 

using up to 1.5 gpd 

solvents

xCleaning motor vehicles 

on application lines 

subject to Rule 1115 

xCleaning of photocurable 

resins from 

stereolithography

equipment and models 

xCleaning of adhesive 

application equipment for 

thin metal laminating if 

VOC content is no more 

than 950 g/L 

xCleaning of electronic 

cables if VOC content is 

no more than 400 g/l 

xCircuit board touch up if 

activities: 

o 100 g/l for product 

cleaning during 

manufacture of 

electrical apparatus 

components and 

electronic

components 

o 800 g/l for product 

cleaning during 

manufacture of 

medical devices and 

pharmaceuticals, 

o 100 g/l for repair 

and maintenance of 

electrical apparatus 

components and 

electrical

components 

o 800 g/l for repair 

and maintenance of 

medical devices and 

pharmaceuticals 

tools, equipment, 

and machinery, 

o 600 g/l for repair 

and maintenance of 

medical devices and 

pharmaceuticals 

general work 

surfaces

o 100 g/l for gravure 

printing on 

publications

o 100 g/l for 

lithographic or 

letterpress printing 

(roller wash-step 1, 

and step 2) 

o 100 g/l for screen 

printing

o 100 g/l for 

ultraviolet 

ink/electron beam 

ink application 

equipment 

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CTG: Ind. Clng. Solv. pg258 of 290 
B-6

VOC content is nor more 

than 800 g/l 

xTransdermal drug delivery 

product manufacturing 

using less than 3 gpd ethyl 

acetate

xCleaning of application 

equipment used for 

solvent-borne

fluropolymer coatings if 

VOC content is no more 

than 900 g/l 

xFacilities cleaning 

sterilization indicating ink 

using less than 1.5 gpd 

solvent

xCleaning operations in 

printing pre-press or 

graphic arts pre-press 

areas, including the 

cleaning of film 

processors, color scanners, 

plate processors, film 

cleaning, and plate 

cleaning 

x Cleaning of cotton swabs 

to remove cottonseed oil 

before cleaning of high 

precision optics 

xCleaning of paper-based 

gaskets and clutch 

assemblies where rubber is 

bonded to metal by means 

of an adhesive 

xCleaning of application 

equipment used to apply 

coatings on satellites and 

radiation effect coatings, 

xCleaning with aerosol 

provided that 160 fluid oz 

or less of aerosol is used 

per day 

xCleaning associated with 

research and development 

operations.

xTesting for QA/QC 

o 100 g/l specialty 

flexographic

printing

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CTG: Ind. Clng. Solv. pg259 of 290 
B-7

purposes

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CTG: Ind. Clng. Solv. pg260 of 290 
C-1

Appendix C

Summary of NAICS Codes for nonattainment facilities 

Estimated to meet the applicability criteria 

recommended in this CTG

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C-2

Appendix C: Summary of NAICS Codes for nonattainment estimated to meet the 

applicability criteria recommended in the CTG 

NAICS NAICS DESCRIPTION 

42 Wholesale Trade 

321 Wood Product Manufacturing 

325 Chemical Manufacturing 

327 Nonmetallic Mineral Product Manufacturing 

331 Primary Metal Manufacturing 

332 Fabricated Metal Product Manufacturing 

333 Machinery Manufacturing 

334 Computer and Electronic Product Manufacturing 

337 Furniture and Related Product Manufacturing 

339 Miscellaneous Manufacturing 

3336 

Engine, Turbine, and Power Transmission Equipment 

Manufacturing 

3399 Other Miscellaneous Manufacturing 

11112 Oilseed (except Soybean) Farming 

23511 Plumbing, Heating, and Air-Conditioning Contractors 

23521 Painting and Wall Covering Contractors 

31212 Breweries 

31321 Broadwoven Fabric Mills 

31323 Nonwoven Fabric Mills 

31331 Textile and Fabric Finishing Mills 

31332 Fabric Coating Mills 

31611 Leather and Hide Tanning and Finishing 

32191 Millwork 

32199 All Other Wood Product Manufacturing 

32213 Paperboard Mills 

32311 Printing 

32551 Paint and Coating Manufacturing 

32552 Adhesive Manufacturing 

32591 Printing Ink Manufacturing 

32613 

Laminated Plastics Plate, Sheet (except Packaging), and 

Shape Manufacturing 

32614 Polystyrene Foam Product Manufacturing 

32615 

Urethane and Other Foam Product (except Polystyrene) 

Manufacturing 

32721 Glass and Glass Product Manufacturing 

32739 Other Concrete Product Manufacturing 

32791 Abrasive Product Manufacturing 

33121 Iron and Steel Pipe and Tube Manufacturing from Purchased 

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CTG: Ind. Clng. Solv. pg264 of 290 
C-3

Steel

33231 Plate Work and Fabricated Structural Product Manufacturing 

33251 Hardware Manufacturing 

33281 Coating, Engraving, Heat Treating, and Allied Activities 

33291 Metal Valve Manufacturing 

33299 All Other Fabricated Metal Product Manufacturing 

33312 Construction Machinery Manufacturing 

33322 Plastics and Rubber Industry Machinery Manufacturing 

33329 Other Industrial Machinery Manufacturing 

33341 

Ventilation, Heating, Air-Conditioning, and Commercial 

Refrigeration Equipment Manufacturing 

33392 Material Handling Equipment Manufacturing 

33511 Electric Lamp Bulb and Part Manufacturing 

33611 Automobile and Light Duty Motor Vehicle Manufacturing 

33612 Heavy Duty Truck Manufacturing 

33621 Motor Vehicle Body and Trailer Manufacturing 

33632 

Motor Vehicle Electrical and Electronic Equipment 

Manufacturing 

33634 Motor Vehicle Brake System Manufacturing 

33635 

Motor Vehicle Transmission and Power Train Parts 

Manufacturing 

33636 Motor Vehicle Seating and Interior Trim Manufacturing 

33651 Railroad Rolling Stock Manufacturing 

33699 Other Transportation Equipment Manufacturing 

33711 Wood Kitchen Cabinet and Countertop Manufacturing 

33712 Household and Institutional Furniture Manufacturing 

33721 Office Furniture (including Fixtures) Manufacturing 

33995 Sign Manufacturing 

42131 Lumber, Plywood, Millwork, and Wood Panel Wholesalers 

42183 Industrial Machinery and Equipment Wholesalers 

42213 Industrial and Personal Service Paper Wholesalers 

44211 Furniture Stores 

45431 Fuel Dealers 

48821 Support Activities for Rail Transportation 

49211 Couriers 

51223 Music Publishers 

53112 Lessors of Nonresidential Buildings (except Miniwarehouses) 

54138 Testing Laboratories 

54171 

Research and Development in the Physical, Engineering, and 

Life Sciences 

61131 Colleges, Universities, and Professional Schools 

81121 Electronic and Precision Equipment Repair and Maintenance 

81131 

Commercial and Industrial Machinery and Equipment (except 

Automotive and Electronic) Repair and Maintenance 

81149 

Other Personal and Household Goods Repair and 

Maintenance 

92214 Correctional Institutions 

92612 Regulation and Administration of Transportation Programs 

211111 Crude Petroleum and Natural Gas Extraction 

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CTG: Ind. Clng. Solv. pg265 of 290 
C-4

211112 Natural Gas Liquid Extraction 

221111 Hydroelectric Power Generation 

221112 Fossil Fuel Electric Power Generation 

221113 Nuclear Electric Power Generation 

221310 Water Supply and Irrigation Systems 

236118 Residential Remodelers 

236220 Commercial and Institutional Building Construction 

237120 Oil and Gas Pipeline and Related Structures Construction 

237310 Highway, Street, and Bridge Construction 

238170 Siding Contractors 

238290 Other Building Equipment Contractors 

38320 Painting and Wall Covering Contractors 

238350 Finish Carpentry Contractors 

238910 Site Preparation Contractors 

311111 Dog and Cat Food Manufacturing 

311320 

Chocolate and Confectionery Manufacturing from Cacao 

Beans

311340 Nonchocolate Confectionery Manufacturing 

311812 Commercial Bakeries 

311919 Other Snack Food Manufacturing 

311942 Spice and Extract Manufacturing 

311991 Perishable Prepared Food Manufacturing 

312111 Soft Drink Manufacturing 

312112 Bottled Water Manufacturing 

312120 Breweries 

312221 Cigarette Manufacturing 

313112 Yarn Texturizing, Throwing, and Twisting Mills 

313113 Thread Mills 

313221 Narrow Fabric Mills 

313230 Nonwoven Fabric Mills 

313311 Broadwoven Fabric Finishing Mills 

313312 

Textile and Fabric Finishing (except Broadwoven Fabric) 

Mills

313320 Fabric Coating Mills 

314110 Carpet and Rug Mills 

314912 Canvas and Related Product Mills 

314991 Rope, Cordage, and Twine Mills 

314992 Tire Cord and Tire Fabric Mills 

314999 All Other Miscellaneous Textile Product Mills 

315111 Sheer Hosiery Mills 

315991 Hat, Cap, and Millinery Manufacturing 

315999 Other Apparel Accessories and Other Apparel Manufacturing 

316110 Leather and Hide Tanning and Finishing 

316213 Men's Footwear (except Athletic) Manufacturing 

316999 All Other Leather Good Manufacturing 

321114 Wood Preservation 

321219 Reconstituted Wood Product Manufacturing 

321911 Wood Window and Door Manufacturing 

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CTG: Ind. Clng. Solv. pg266 of 290 
C-5

321918 Other Millwork (including Flooring) 

321920 Wood Container and Pallet Manufacturing 

321991 Manufactured Home (Mobile Home) Manufacturing 

321992 Prefabricated Wood Building Manufacturing 

321999 All Other Miscellaneous Wood Product Manufacturing 

322110 Pulp Mills 

322121 Paper (except Newsprint) Mills 

322122 Newsprint Mills 

322130 Paperboard Mills 

322211 Corrugated and Solid Fiber Box Manufacturing 

322212 Folding Paperboard Box Manufacturing 

322214 Fiber Can, Tube, Drum, and Similar Products Manufacturing 

322221 

Coated and Laminated Packaging Paper and Plastics Film 

Manufacturing 

322222 Coated and Laminated Paper Manufacturing 

322231 Die-Cut Paper and Paperboard Office Supplies Manufacturing 

322232 Envelope Manufacturing 

322299 All Other Converted Paper Product Manufacturing 

323110 Commercial Lithographic Printing 

323111 Commercial Gravure Printing 

323112 Commercial Flexographic Printing 

323113 Commercial Screen Printing 

323116 Manifold Business Forms Printing 

323117 Books Printing 

323122 Prepress Services 

324110 Petroleum Refineries 

324122 Asphalt Shingle and Coating Materials Manufacturing 

324191 Petroleum Lubricating Oil and Grease Manufacturing 

324199 All Other Petroleum and Coal Products Manufacturing 

325110 Petrochemical Manufacturing 

325131 Inorganic Dye and Pigment Manufacturing 

325132 Synthetic Organic Dye and Pigment Manufacturing 

325188 All Other Basic Inorganic Chemical Manufacturing 

325199 All Other Basic Organic Chemical Manufacturing 

325211 Plastics Material and Resin Manufacturing 

325212 Synthetic Rubber Manufacturing 

325222 Noncellulosic Organic Fiber Manufacturing 

325411 Medicinal and Botanical Manufacturing 

325412 Pharmaceutical Preparation Manufacturing 

325413 In-Vitro Diagnostic Substance Manufacturing 

325510 Paint and Coating Manufacturing 

325520 Adhesive Manufacturing 

325611 Soap and Other Detergent Manufacturing 

325612 Polish and Other Sanitation Good Manufacturing 

325613 Surface Active Agent Manufacturing 

325620 Toilet Preparation Manufacturing 

325910 Printing Ink Manufacturing 

325991 Custom Compounding of Purchased Resins 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg267 of 290 
C-6

325992 Photographic Film, Paper, Plate, and Chemical Manufacturing 

325998 

All Other Miscellaneous Chemical Product and Preparation 

Manufacturing 

326112 

Plastics Packaging Film and Sheet (including Laminated) 

Manufacturing 

326113 

Unlaminated Plastics Film and Sheet (except Packaging) 

Manufacturing 

326121 Unlaminated Plastics Profile Shape Manufacturing 

326130 

Laminated Plastics Plate, Sheet (except Packaging), and 

Shape Manufacturing 

326140 Polystyrene Foam Product Manufacturing 

326150 

Urethane and Other Foam Product (except Polystyrene) 

Manufacturing 

326160 Plastics Bottle Manufacturing 

326191 Plastics Plumbing Fixture Manufacturing 

326192 Resilient Floor Covering Manufacturing 

326199 All Other Plastics Product Manufacturing 

326211 Tire Manufacturing (except Retreading) 

326212 Tire Retreading 

326220 Rubber and Plastics Hoses and Belting Manufacturing 

326291 Rubber Product Manufacturing for Mechanical Use 

326299 All Other Rubber Product Manufacturing 

327112 

Vitreous China, Fine Earthenware, and Other Pottery Product 

Manufacturing 

327121 Brick and Structural Clay Tile Manufacturing 

327123 Other Structural Clay Product Manufacturing 

327124 Clay Refractory Manufacturing 

327125 Nonclay Refractory Manufacturing 

327211 Flat Glass Manufacturing 

327212 Other Pressed and Blown Glass and Glassware Manufacturing 

327213 Glass Container Manufacturing 

327215 Glass Product Manufacturing Made of Purchased Glass 

327310 Cement Manufacturing 

327331 Concrete Block and Brick Manufacturing 

327332 Concrete Pipe Manufacturing 

327390 Other Concrete Product Manufacturing 

327910 Abrasive Product Manufacturing 

327991 Cut Stone and Stone Product Manufacturing 

327993 Mineral Wool Manufacturing 

327999 

All Other Miscellaneous Nonmetallic Mineral Product 

Manufacturing 

331111 Iron and Steel Mills 

331112 Electrometallurgical Ferroalloy Product Manufacturing 

331210 

Iron and Steel Pipe and Tube Manufacturing from Purchased 

Steel

331221 Rolled Steel Shape Manufacturing 

331222 Steel Wire Drawing 

331312 Primary Aluminum Production 

331314 Secondary Smelting and Alloying of Aluminum 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg268 of 290 
C-7

331315 Aluminum Sheet, Plate, and Foil Manufacturing 

331316 Aluminum Extruded Product Manufacturing 

331319 Other Aluminum Rolling and Drawing 

331421 Copper Rolling, Drawing, and Extruding 

331422 Copper Wire (except Mechanical) Drawing 

331423 Secondary Smelting, Refining, and Alloying of Copper 

331491 

Nonferrous Metal (except Copper and Aluminum) Rolling, 

Drawing, and Extruding 

331511 Iron Foundries 

331512 Steel Investment Foundries 

331513 Steel Foundries (except Investment) 

331524 Aluminum Foundries (except Die-Casting) 

331525 Copper Foundries (except Die-Casting) 

331528 Other Nonferrous Foundries (except Die-Casting) 

332112 Nonferrous Forging 

332114 Custom Roll Forming 

332115 Crown and Closure Manufacturing 

332116 Metal Stamping 

332117 Powder Metallurgy Part Manufacturing 

332211 Cutlery and Flatware (except Precious) Manufacturing 

332212 Hand and Edge Tool Manufacturing 

332213 Saw Blade and Handsaw Manufacturing 

332214 Kitchen Utensil, Pot, and Pan Manufacturing 

332311 Prefabricated Metal Building and Component Manufacturing 

332312 Fabricated Structural Metal Manufacturing 

332313 Plate Work Manufacturing 

332321 Metal Window and Door Manufacturing 

332322 Sheet Metal Work Manufacturing 

332323 Ornamental and Architectural Metal Work Manufacturing 

332410 Power Boiler and Heat Exchanger Manufacturing 

332420 Metal Tank (Heavy Gauge) Manufacturing 

332431 Metal Can Manufacturing 

332439 Other Metal Container Manufacturing 

332510 Hardware Manufacturing 

332611 Spring (Heavy Gauge) Manufacturing 

332612 Spring (Light Gauge) Manufacturing 

332618 Other Fabricated Wire Product Manufacturing 

332721 Precision Turned Product Manufacturing 

332722 Bolt, Nut, Screw, Rivet, and Washer Manufacturing 

332811 Metal Heat Treating 

332812 

Metal Coating, Engraving (except Jewelry and Silverware), 

and Allied Services to Manufacturers 

332813 Electroplating, Plating, Polishing, Anodizing, and Coloring 

332911 Industrial Valve Manufacturing 

332919 Other Metal Valve and Pipe Fitting Manufacturing 

332991 Ball and Roller Bearing Manufacturing 

332993 Ammunition (except Small Arms) Manufacturing 

332994 Small Arms Manufacturing 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg269 of 290 
C-8

332996 Fabricated Pipe and Pipe Fitting Manufacturing 

332998 Enameled Iron and Metal Sanitary Ware Manufacturing 

332999 

All Other Miscellaneous Fabricated Metal Product 

Manufacturing 

333111 Farm Machinery and Equipment Manufacturing 

333120 Construction Machinery Manufacturing 

333131 Mining Machinery and Equipment Manufacturing 

333132 Oil and Gas Field Machinery and Equipment Manufacturing 

333210 Sawmill and Woodworking Machinery Manufacturing 

333291 Paper Industry Machinery Manufacturing 

333292 Textile Machinery Manufacturing 

333293 Printing Machinery and Equipment Manufacturing 

333295 Semiconductor Machinery Manufacturing 

333298 All Other Industrial Machinery Manufacturing 

333314 Optical Instrument and Lens Manufacturing 

333315 Photographic and Photocopying Equipment Manufacturing 

333319 

Other Commercial and Service Industry Machinery 

Manufacturing 

333412 Industrial and Commercial Fan and Blower Manufacturing 

333414 

Heating Equipment (except Warm Air Furnaces) 

Manufacturing 

333415 

Air-Conditioning and Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration Equipment 

Manufacturing 

333512 Machine Tool (Metal Cutting Types) Manufacturing 

333515 Cutting Tool and Machine Tool Accessory Manufacturing 

333516 Rolling Mill Machinery and Equipment Manufacturing 

333611 Turbine and Turbine Generator Set Units Manufacturing 

333612 

Speed Changer, Industrial High-Speed Drive, and Gear 

Manufacturing 

333613 Mechanical Power Transmission Equipment Manufacturing 

333618 Other Engine Equipment Manufacturing 

333911 Pump and Pumping Equipment Manufacturing 

333912 Air and Gas Compressor Manufacturing 

333921 Elevator and Moving Stairway Manufacturing 

333922 Conveyor and Conveying Equipment Manufacturing 

333923 

Overhead Traveling Crane, Hoist, and Monorail System 

Manufacturing 

333924 

Industrial Truck, Tractor, Trailer, and Stacker Machinery 

Manufacturing 

333991 Power-Driven Handtool Manufacturing 

333994 Industrial Process Furnace and Oven Manufacturing 

333999 

All Other Miscellaneous General Purpose Machinery 

Manufacturing 

334111 Electronic Computer Manufacturing 

334112 Computer Storage Device Manufacturing 

334113 Computer Terminal Manufacturing 

334119 Other Computer Peripheral Equipment Manufacturing 

334220 

Radio and Television Broadcasting and Wireless 

Communications Equipment Manufacturing 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg270 of 290 
C-9

334290 Other Communications Equipment Manufacturing 

334310 Audio and Video Equipment Manufacturing 

334411 Electron Tube Manufacturing 

334412 Bare Printed Circuit Board Manufacturing 

334413 Semiconductor and Related Device Manufacturing 

334414 Electronic Capacitor Manufacturing 

334415 Electronic Resistor Manufacturing 

334416 

Electronic Coil, Transformer, and Other Inductor 

Manufacturing 

334417 Electronic Connector Manufacturing 

334418 

Printed Circuit Assembly (Electronic Assembly) 

Manufacturing 

334419 Other Electronic Component Manufacturing 

334510 

Electromedical and Electrotherapeutic Apparatus 

Manufacturing 

334511 

Search, Detection, Navigation, Guidance, Aeronautical, and 

Nautical System and Instrument Manufacturing 

334512 

Automatic Environmental Control Manufacturing for 

Residential, Commercial, and Appliance Use 

334513 

Instruments and Related Products Manufacturing for 

Measuring, Displaying, and Controlling Industrial Process 

Variables 

334516 Analytical Laboratory Instrument Manufacturing 

334517 Irradiation Apparatus Manufacturing 

334518 Watch, Clock, and Part Manufacturing 

334519 Other Measuring and Controlling Device Manufacturing 

334613 Magnetic and Optical Recording Media Manufacturing 

335110 Electric Lamp Bulb and Part Manufacturing 

335121 Residential Electric Lighting Fixture Manufacturing 

335122 

Commercial, Industrial, and Institutional Electric Lighting 

Fixture Manufacturing 

335129 Other Lighting Equipment Manufacturing 

335211 Electric Housewares and Household Fan Manufacturing 

335221 Household Cooking Appliance Manufacturing 

335222 Household Refrigerator and Home Freezer Manufacturing 

335228 Other Major Household Appliance Manufacturing 

335311 

Power, Distribution, and Specialty Transformer 

Manufacturing 

335312 Motor and Generator Manufacturing 

335313 Switchgear and Switchboard Apparatus Manufacturing 

335314 Relay and Industrial Control Manufacturing 

335911 Storage Battery Manufacturing 

335921 Fiber Optic Cable Manufacturing 

335929 Other Communication and Energy Wire Manufacturing 

335932 Noncurrent-Carrying Wiring Device Manufacturing 

335999 

All Other Miscellaneous Electrical Equipment and 

Component Manufacturing 

336111 Automobile Manufacturing 

336112 Light Truck and Utility Vehicle Manufacturing 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg271 of 290 
C-10

336211 Motor Vehicle Body Manufacturing 

336212 Truck Trailer Manufacturing 

336213 Motor Home Manufacturing 

336214 Travel Trailer and Camper Manufacturing 

336311 Carburetor, Piston, Piston Ring, and Valve Manufacturing 

336312 Gasoline Engine and Engine Parts Manufacturing 

336321 Vehicular Lighting Equipment Manufacturing 

336322 

Other Motor Vehicle Electrical and Electronic Equipment 

Manufacturing 

336340 Motor Vehicle Brake System Manufacturing 

336350 

Motor Vehicle Transmission and Power Train Parts 

Manufacturing 

336360 Motor Vehicle Seating and Interior Trim Manufacturing 

336370 Motor Vehicle Metal Stamping 

336399 All Other Motor Vehicle Parts Manufacturing 

336412 Aircraft Engine and Engine Parts Manufacturing 

336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing 

336414 Guided Missile and Space Vehicle Manufacturing 

336510 Railroad Rolling Stock Manufacturing 

336611 Ship Building and Repairing 

336612 Boat Building 

336999 All Other Transportation Equipment Manufacturing 

337110 Wood Kitchen Cabinet and Countertop Manufacturing 

337121 Upholstered Household Furniture Manufacturing 

337122 Nonupholstered Wood Household Furniture Manufacturing 

337124 Metal Household Furniture Manufacturing 

337125 Household Furniture (except Wood and Metal) Manufacturing 

337127 Institutional Furniture Manufacturing 

337129 

Wood Television, Radio, and Sewing Machine Cabinet 

Manufacturing 

337211 Wood Office Furniture Manufacturing 

337212 

Custom Architectural Woodwork and Millwork 

Manufacturing 

337214 Office Furniture (except Wood) Manufacturing 

337215 Showcase, Partition, Shelving, and Locker Manufacturing 

337920 Blind and Shade Manufacturing 

339111 Laboratory Apparatus and Furniture Manufacturing 

339112 Surgical and Medical Instrument Manufacturing 

339113 Surgical Appliance and Supplies Manufacturing 

339115 Ophthalmic Goods Manufacturing 

339911 Jewelry (except Costume) Manufacturing 

339912 Silverware and Hollowware Manufacturing 

339914 Costume Jewelry and Novelty Manufacturing 

339920 Sporting and Athletic Goods Manufacturing 

339932 Game, Toy, and Children's Vehicle Manufacturing 

339941 Pen and Mechanical Pencil Manufacturing 

339942 Lead Pencil and Art Good Manufacturing 

339950 Sign Manufacturing 

Docket No. EPA-HQ-OAR-2006-0535

CTG: Ind. Clng. Solv. pg272 of 290 
C-11

339991 Gasket, Packing, and Sealing Device Manufacturing 

339992 Musical Instrument Manufacturing 

339993 Fastener, Button, Needle, and Pin Manufacturing 

339995 Burial Casket Manufacturing 

339999 All Other Miscellaneous Manufacturing 

423110 Automobile and Other Motor Vehicle Merchant Wholesalers 

423310 

Lumber, Plywood, Millwork, and Wood Panel Merchant 

Wholesalers

423510 Metal Service Centers and Other Metal Merchant Wholesalers 

423810 

Construction and Mining (except Oil Well) Machinery and 

Equipment Merchant Wholesalers 

423990 Other Miscellaneous Durable Goods Merchant Wholesalers 

424690 Other Chemical and Allied Products Merchant Wholesalers 

424950 Paint, Varnish, and Supplies Merchant Wholesalers 

425110 Business to Business Electronic Markets 

425120 Wholesale Trade Agents and Brokers 

441110 New Car Dealers 

441120 Used Car Dealers 

442110 Furniture Stores 

442210 Floor Covering Stores 

443111 Household Appliance Stores 

444120 Paint and Wallpaper Stores 

444190 Other Building Material Dealers 

446199 All Other Health and Personal Care Stores 

451110 Sporting Goods Stores 

453998 

All Other Miscellaneous Store Retailers (except Tobacco 

Stores) 

454312 Liquefied Petroleum Gas (Bottled Gas) Dealers 

481219 Other Nonscheduled Air Transportation 

482111 Line-Haul Railroads 

485111 Mixed Mode Transit Systems 

485113 Bus and Other Motor Vehicle Transit Systems 

485410 School and Employee Bus Transportation 

485999 All Other Transit and Ground Passenger Transportation 

488190 Other Support Activities for Air Transportation 

488210 Support Activities for Rail Transportation 

488490 Other Support Activities for Road Transportation 

488999 All Other Support Activities for Transportation 

491110 Postal Service 

493110 General Warehousing and Storage 

511110 Newspaper Publishers 

511120 Periodical Publishers 

512110 Motion Picture and Video Production 

512220 Integrated Record Production/Distribution 

515120 Television Broadcasting 

523930 Investment Advice 

531120 Lessors of Nonresidential Buildings (except Miniwarehouses) 

532299 All Other Consumer Goods Rental 

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532411 

Commercial Air, Rail, and Water Transportation Equipment 

Rental and Leasing 

541330 Engineering Services 

541360 Geophysical Surveying and Mapping Services 

541380 Testing Laboratories 

541710 

Research and Development in the Physical, Engineering, and 

Life Sciences 

541720 

Research and Development in the Social Sciences and 

Humanities 

541850 Display Advertising 

541940 Veterinary Services 

561499 All Other Business Support Services 

562212 Solid Waste Landfill 

562910 Remediation Services 

562998 All Other Miscellaneous Waste Management Services 

611110 Elementary and Secondary Schools 

611210 Junior Colleges 

611310 Colleges, Universities, and Professional Schools 

611513 Apprenticeship Training 

621511 Medical Laboratories 

621512 Diagnostic Imaging Centers 

622110 General Medical and Surgical Hospitals 

622210 Psychiatric and Substance Abuse Hospitals 

622310 Specialty (except Psychiatric and Substance Abuse) Hospitals 

711310 

Promoters of Performing Arts, Sports, and Similar Events 

with Facilities 

711510 Independent Artists, Writers, and Performers 

713110 Amusement and Theme Parks 

722310 Food Service Contractors 

811111 General Automotive Repair 

811118 

Other Automotive Mechanical and Electrical Repair and 

Maintenance 

811121 Automotive Body, Paint, and Interior Repair and Maintenance 

811122 Automotive Glass Replacement Shops 

811211 Consumer Electronics Repair and Maintenance 

811310 

Commercial and Industrial Machinery and Equipment (except 

Automotive and Electronic) Repair and Maintenance 

811412 Appliance Repair and Maintenance 

811420 Reupholstery and Furniture Repair 

811490 

Other Personal and Household Goods Repair and 

Maintenance 

812320 Drycleaning and Laundry Services (except Coin-Operated) 

812921 Photofinishing Laboratories (except One-Hour) 

812922 One-Hour Photofinishing 

812990 All Other Personal Services 

921190 Other General Government Support 

922140 Correctional Institutions 

923130 

Administration of Human Resource Programs (except 

Education, Public Health, and Veterans' Affairs Programs) 

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923140 Administration of Veterans' Affairs 

926120 Regulation and Administration of Transportation Programs 

927110 Space Research and Technology 

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D-1

Appendix D 

Number of Nonattainment Facilities organized by State that are 

Estimated to Meet the Applicability Criteria Recommended in the 

CTG,

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D-2

Appendix D. Number of nonattainment facilities organized by State that are 

estimated to meet the applicability criteria recommended in the CTG 

State

Number of 

Facilities

Baseline

VOC

Emissions 

from Solvent 

Utilization 

(Mg/yr)

Alabama 17 665

Arkansas 1 23

Arizona 51 1,567

California 619 5,730

Colorado 203 2,191

Connecticut 21 349

Delaware 3 18

Georgia 9 639

Illinois 130 2,293

Indiana 162 5,825

Kentucky 23 1,329

Louisiana 5 111

Massachusetts 268 2,960

Maryland 19 442

Maine 4 24

Michigan 157 3,469

Missouri 60 1,583

North Carolina 154 12,013

New Hampshire 11 447

New Jersey 32 657

New York 11 381

Ohio 17 1,823

Pennsylvania 166 3,660

Rhode Island 27 465

South Carolina 36 2,538

Tennessee 82 4,307

Texas 92 2,558

Virginia 36 2,762

Wisconsin 97 1,625

West Virginia 11 807

Totals: 2,524 63,261

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1

Appendix E 

Costs and Emission Reductions for the Recommendations 

Concerning Solvent Substitution 

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Appendix E 

Costs and Emission Reductions for the Recommendation Concerning 

Solvent Substitution 

I. Introduction 

This memorandum addresses how we calculated the costs and VOC emission 

reductions for the recommended option involving substituting a high VOC solvent with a 

cleaning solution with 50gram per liter VOC. 

According to the 2002 National Emissions Inventory (NEI), there are 2,524 

facilities conducting solvent cleaning operations in the United States that are located in 

ozone nonattainment areas (based on April 2004 designations). These facilities had 

emissions that exceed the emission threshold of 6.8 kg (15 lb) of VOC per day before 

control. Total aggregate VOC emissions from solvent cleaning operations from these 

nonattainment sources are approximately 64,000 Mg/yr (71,000 tpy). We identified the 

facilities above the recommended daily VOC emission limit threshold from all SCC 

codes at the facility with source category classifications of interest. 

The total VOC emissions from solvent cleaning operations were first determined 

by identifying SCCs that corresponded to solvent evaporation or solvent utilization at a 

facility. In this analysis, the SCCs that fit this category included SCC codes with an SCC 

level 1 description of “Petroleum and Solvent Evaporation” or “Solvent Utilization.”

Next, this list of applicable SCC codes was narrowed to codes where the SCC level 2 

code included "surface coating", "degreasing","dry cleaning”,” graphic arts", 

"rubber/plastics”, “All Solvent User Categories", or "organic solvent evaporation" it was 

included in the population of total VOC emissions from solvent cleaning operations. 

This list of applicable SCC codes was further divided into one of three general 

groups: halogenated solvents, parts cleaners, and other solvent cleaning operations.

Halogenated solvents were identified by reviewing the name of the solvent listed in the 

SCC level 4 description for halogenated compounds. As a result, all SCC codes 

representing halogenated solvents were removed from our estimate of total VOC 

emissions from solvent cleaning operations. SCC codes with “degreasing” or “cold 

solvent cleaning/stripping” in the SCC level 3 description were identified as parts 

cleaners. The final subgroup covers “other solvent cleaning operations,” and this group 

includes all of the applicable SCC codes that were not classified as halogenated solvents 

or parts cleaners. 

Several industries with solvent cleaning operations are covered under either 

section 183(e) of the Clean Air Act or are part of a category with a specific exemption to 

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E-2

a Bay Area Rule. These are listed in the CTG, and were removed from the total VOC 

calculation.

This list of applicable SCC codes was further divided into one of three general 

groups: halogenated solvents, parts cleaners, and other solvent cleaning operations.

Halogenated solvents were identified by reviewing the name of the solvent listed in the 

SCC level 4 description for halogenated compounds. As a result, all SCC codes 

representing halogenated solvents were removed from our estimate of total VOC 

emissions from solvent cleaning operations. SCC codes with “degreasing” or “cold 

solvent cleaning/stripping” in the SCC level 3 description were classified as part cleaners. 

The final subgroup covers “other solvent cleaning operations,” and this group includes all 

of the applicable SCC codes that were not classified as halogenated solvents or parts 

cleaners.

As a result of this analysis, we determined that there were approximately 64,000 

Mg/yr (71,000) tpy) VOC from solvent cleaning operations. Of this total, 4,000 Mg/yr 

(4,400 tpy) were identified as parts cleaners and the remaining 60,000 Mg/yr (66,000 tpy) 

were classified as other solvent cleaning operations. We did not include in this analysis 

cleaning solvent emissions from 183(e) category of sources. Nor did we include 

emissions from research and development facilities, or emissions from manufacturing 

and assembly of electrical and electronic components. 

II. Cost Analysis 

 For this analysis, it was assumed that the total VOC emitted is equal to the total 

VOC used for solvent cleaning. This value was converted to a volume by using an 

average specific gravity (900g/l) for a typical all VOC cleaning solvents found in the 

ACT.

The study provided by the California Bay Area AQMD shows that the costeffectiveness for meeting the 50 grams of VOC per liter of cleaning material limit for a 

parts cleaner is estimated at $1,832/Mg (1,664/ton).1,2 This represents the annual cost of 

compliance (industry wide) for parts cleaners (Table 4 of the Bay Area Regulation 8, 

Rule 16). We determined that replacing high VOC content cleaning materials with low 

VOC water-based cleaning materials for the other cleaning (unit) operations (e.g., 

cleaning of large manufactured surfaces, tank cleaning, and gun cleaning, etc.) would 

result in an estimated cost savings of $1,460/Mg. For this calculation we only considered 

the cost-difference in cleaning material cost and cost-difference in waste disposal cost.

The savings is a result of lower cost of aqueous cleaners which offset the increase in 

waste disposal cost for aqueous cleaners. .1

Therefore, the national annual costs for complying with the 50 grams of VOC per 

liter limit on a cleaning (unit) operation basis are a summation of the costs of operating 

parts cleaners, and the savings realized by the other solvent cleaning operations. The 

annual national cost and emission impacts are a cost savings of $76 million and 61,000 

Mg/yr (67,000 tpy) reduction in VOC emissions. Table 2 summarizes the cost estimates 

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by attainment classification. Attachment 1 presents a sample calculation of cost and 

emission reductions for an individual facility. Lastly, facilities may either incur minimal 

additional costs or realize a savings on a case-by-case basis, depending primarily on how 

much they currently spend to operate the high VOC content solvent-based parts cleaners, 

the cost of organic solvent disposal, and air emission fees levied for VOC emissions. 

Also, the costs and VOC reductions will differ with the option that a facility would be 

required to use by a State for a cleaning operation. 

References

1. Bay Area Air Quality Management District, Staff Report: Proposed Amendments 

to BAAQMD Regulation 8, Rule 16: Solvent Cleaning Operations, September 

2002.

2. South Coast Air Quality Management District, Staff Report for Proposed 

Amendment to Rule 1171 - Solvent Cleaning Operations, August 15, 1996. 

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Table 2. Summary of Costs and Emission Reductions for Nonattainment Facilities 

for the Recommendation Concerning Solvent Substitution 

Solvent Cleaning Operation 

Affected 

facilities with 

VOC emissions 

6.8 kg per day 

2002 NEI* 

Baseline VOC 

emissions 

(Mg/yr) 

Controlled 

VOC for 

facilities in 

NAICS 

(2002 Mg/yr) 

Emission

Reduction 

for

Facilities in 

NAICS 

(tpy) 

Cost Effectiveness 

(2002 $ per Mg) 

Nationwide

Cost

(2002 $) 

Parts Cleaners 613 3,990 221 3,768 1,833 6,905,900 

Other Solvent Cleaning 

Operations 2,408 59,271 3,286 55,986 -1,459 -81,697,307 

Totals (100% of facilities)* 2,524 63,261 3,507 59,754 -74,791,407 

Totals (75% of facilities)** 1893 47,446 2,630 44,816 -56,093,556 

Totals (50% of facilities)** 1262 31,630 1,753 29,877 -37,395,704 

Totals (25% of facilities)** 631 15,815 877 14,939 -18,697,852 

 

* Some facilities have emissions from both parts cleaners and other solvent cleaning operations. The total number of 

 facilities represents the number of facilities considered in this analysis (see Appendix C). 

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Attachment 1. Costs and Emission Reductions Example Calculation for 

the Recommendation Concerning Solvent Substitution 

An example is presented to illustrate the procedure we used to calculate the cost and 

VOC emission reductions resulting when the recommended 50 g/l VOC limit option is 

applied. In this example, we show an overall negative cost, which is representative of 

most of the nonattainment facilities the 2002 NEI database which cleaning solvents above 

the threshold limit. However, the net cost for a facility, that will be using this option, will 

depend on the level of VOC solvent emissions from parts cleaning relative to that for the 

other cleaning operations.

Procedure:

1 Estimated baseline VOC emissions from solvent cleaning operations for the 

facilities in the EPA 2002 NEI database. Only emissions identified as 

originating from “VOC” were included, due time constraints. Individually 

listed compounds were not screened for VOC status. Therefore, total VOC 

from cleaning solvents are somewhat underestimated. 

2 Identified the facilities in nonattainment areas that emitted VOC from the use 

of organic solvents above a 6.8 kg/day (15 lb/day) threshold level.

3 Calculate separately, as identified in the NEI database, the cost of parts 

cleaners and other cleaning operations. 

4 Used an average VOC concentration of 900 g/l, which we determined from 

the 1994 ACT, to convert VOC emissions to volume of solvent used. For this 

analysis we are assuming that the VOC emissions from solvent cleaning 

determined from the NEI database are equal to the volume of solvent used. 

5 Multiplied by the VOC limit (50 g/l) by solvent usage to determine the VOC 

emissions after compliance with the limit. 

6 Subtracted the value determined under 5 above from the NEI baseline 

emissions to estimate emission reductions 

7 Used cost-effectiveness information from the Bay Area AQMD to calculate 

costs of reducing VOC. 

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Table 1A. Emissions from Solvent Cleaning Operations 

(8-hour Ozone Non-Attainment Area based on 2002 NEI) * 

NEI

Unique 

Facility 

ID

County

FIPS SCC

VOC 

emissions

(tpy) Category 

Pollution 

Category NAICS Code SIC Code 

NEI22046 06059 40100308 0 NHPC VOC 713110 7996 

NEI22046 06059 40100398 2.17 NHPC VOC 713110 7996 

NEI22046 06059 40200210 0.08 otherNH VOC 713110 7996 

NEI22046 06059 40200310 0.04 otherNH VOC 713110 7996 

NEI22046 06059 40200410 0 otherNH VOC 713110 7996 

NEI22046 06059 40200510 0.01 otherNH VOC 713110 7996 

NEI22046 06059 40200610 0.19 otherNH VOC 713110 7996 

NEI22046 06059 40200710 0.01 otherNH VOC 713110 7996 

NEI22046 06059 40200901 0.01 otherNH VOC 713110 7996 

NEI22046 06059 40200926 0 otherNH VOC 713110 7996 

NEI22046 06059 40200998 2.02 otherNH VOC 713110 7996 

NEI22046 06059 40201901 0.01 otherNH VOC 713110 7996 

NEI22046 06059 40299995 0.64 otherNH VOC 713110 7996 

NEI22046 06059 49000601 0.47 otherNH VOC 713110 7996 

Step 1: Calculate total facility emissions of VOC from solvent cleaning operations and 

determine if they are above threshold level of 6.8 kg/day (15 lb/day). 

Total Facility Emissions = 0 + 2.17 + 0.08 + 0.04 + 0 + 0.01 + 0.19 + 0.01 + 0.01 + 0 

+ 2.02 + 0.01 + 0.64 + 0.47 = 5.64 tpy

VOC Threshold = 15 lb/day * 1 ton/2000 lb * 365 days/yr = 2.74 tpy 

or 2.17 ton/yr * 907,185 g/ton = 2,485 kg/yr (2.48 Megagrams/yr)

Since the facility emissions are above the VOC threshold limit of 6.8 kg/yr, go to step 2. 

Step 2: Estimate baseline emissions and emission reductions from (1) parts cleaners and 

(2) other solvent cleaning operations. 

2a. Parts Cleaners 

The total VOC Emissions from Parts Cleaners used by this Facility = 2.17 ton/yr * 

907.2kg/ton = 1,967 Kg/yr 

We will assume that the average VOC concentration (density) of the solvents used by this 

facility was 900 g/liter. If we replace the organic solvent with a cleaning solution

with a VOC content (concentration) of 50 g/liter, the controlled emissions would be as 

follows: 

 = 1,967 kg/yr * (50 g/liter/900 g.liter) 

 = 109.2 kg/yr (0.12 ton/yr) 

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2a. Other Cleaning Operations 

The total VOC Emissions from the Other Cleaners Operations in this Facility = 3.48 

ton/yr * 907.2 kg/ton =3,154 kg/yr 

Therefore, the controlled VOC emissions after solvent substitution are 

 = 3,154 kg/yr * (50 g/liter/900 g.liter) 

 = 175.2 kg/yr (0.19 ton/yr) 

Step 3: Estimate the costs of switching to aqueous solvent. 

3a. Parts Cleaners 

Assumption $1,664 per ton of VOC emissions reduced 

Tons VOC reduced due to solvent substitution = 2.17 ton/yr – 0.12 ton/yr = 2.05 ton/yr 

Cost to Facility = $1,664/ton reduced * 2.05 ton/yr = $3,408 

3b. Other Solvent Cleaning Operations 

Assumption -$1,325 (net savings) per ton of VOC reduced. 

Tons VOC reduced to solvent substitution = 3.48 ton/yr – 0.19 ton/yr = 3.29 ton/yr 

Cost to Facility = -$1,325/ton reduced * 3.29 ton/yr = -$4,351 (savings) 

3c. Calculate Total Facility Cost: 

Cost from VOC reduced from Parts Cleaners + Cost from VOC reduced from Other 

Cleaning Operations = $3,408 + -$4,351 = - $943(net savings)

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United States 

Environmental Protection Agency

Office of Air Quality Planning and Standards 

Air Quality Strategies and Standards Division 

Research Triangle Park, NC 

Publication No. EPA 453/R-06-001 

September, 2006

Postal information in this section where appropriate. 

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