Federal vs. State Halogenated Solvent Cleaning Rules Revised October 2009 

Federal Cite Section State Cite Comments 

63.460 (a) Applicability § 36.2 RI regulations cover all organic 

solvent cleaning machines using 

volatile organic compounds and/or 

hazardous organic compounds. The 

federal regulation only applies to 

solvent cleaning machines using 

methylene chloride, 

perchloroethylene, trichloroethylene, 

1,1,1 trichloroethane, carbon 

tetrachloride or chloroform, or any 

combination or these halogenated 

HAP solvents, in a total concentration 

greater than 5% by weight. Overall 

the RI rule is more stringent. 

§ 63.460 (b) General Provisions RI regulations do include all 

applicable General Provisions. 

§ 63.460 ( c) Compliance § 36 .3 (b) Rhode Island requires compliance for 

Schedule New new sources upon start up or by 

Sources 4/8/96, whichever is later . The 

Federal Regulation requires 

compliance by 12/2/94; however the 

RI regulation was not effective until 

4/8/96 and could not require an 

earlier compliance date. 

§ 63.460 (d) Compliance § 36.3 (a) RI requires compliance for existing 

Schedule Existing sources by 1/1/1997. The federal 

Sources regulation requires compliance by 

12/2/97.The RI Rule is more 

Stri ngent. 

63.460(g) RI rules do not contain provisions for 

continuous web solvent cleaning 

machines; however RI does not have 

any continuous web cleaners. Any 

new continuous web cleaning 

machine would be subject to a preconstruction permit under RIAPC 

Regulation 9 and therefore subject to 

all NESHAP provisions. 

Compliance Date 36.4.17 The Federal Regulation requires 

63.460( i ) for Facility Wide compliance with the facility wide 

emission limit emission limits on May 3, 2010 . RI 

Facility Wide Emission limit became 

effective on October 9, 2008 
§ 63.461 Definitions 36 .1 RI did not define the following: 

consumption, cover, HAP solvent 

(but did define HAP), hoist, 

immersion cold cleaning machine, 

monthly reporting, open top vapor 

mode, part, soils, contaminant, sump 

heater coils, water layer, and the 

following general provision 

definitions:, existing, new, and 

reduced room draft. 

Additionally, the federal regulation 

defines vapor cleaning machine as a 

batch or inline solvent cleaning 

machine that boils liquid solvent 

generating vapor that is used as part 

of the cleaning or drying cycle 

whereas the RI regulation does not 

specify that the hot liquid must be 

boiling . 

Although solvent/air interface area, 

and open top mode are not defined, 

solvent /air interface and open top 

area are defined . 

The definition for administrator is 

included in the RIAPC General 

Definitions Regulation. 

§ 63 .462 Requirements for 36.5 RI does not require a water layer of 

Batch Cold 1" for batch cold vapor machines, but 

Cleaning Machines does require a cover and freeboard 

ration of 0 .75. All other requirements 

are the same. This is equivalent to 

the NESHAP. 

§ 63 .463 (a) (1) Batch Vapor and In § 36.6 RI regulations do not allow the use of 

- (a) (7) Line Cleaning reduced room drafts for compliance 

Machine Standards with this regulation . RI requires the 

automated parts handling system to 

operate at 10ft/min whereas the 

federal regulation allows 11ft/min . 

The RI rule is more strin gent. ' 

§ 63.463 (b) Requirements for § 36 .6 .6 or RI regulations do not allow idling 

Batch Vapor 7 limits more strin gent) and less 
Cleaning control options are allowed, but those 

Operations with allowed are at least as stringent. 

Solvent/Air 

Interface 

§ 63.463 (c ) Requirements for § 36 .7 .7 No idling limit allowed (more 

In-Line Cleaning and § stringent) ; less control options 

Operations 36.7.8 allowed, but those allowed are at 

least as strin gent. 

§ 63.463 (d) (1- Work practice (1)36.6.1- RI regulations do not allow reduced 12) 36 .7.1 (2) room drafts for compliance with this 

(ii) N/A (3) regulation. RI regulations contain 

36 .6 .4(c), some additional language regarding 

36.6.11, treatment of waste solvent. 

36.7.4(c), 

36.7.15 (4) 

36.4.9- 

36 .4 .10(5) 

36 .4 .8 (6) 

36 .6 .15- 

36.7 .13(7) 

36.6.16- 

36.7.14(8) 

36.4.11 (9) 

36.4.13 (10) 

36 .4.14 (11) 

36 .4.12 (12) 

36 .4 .7 

§ 63.463 (e) (1) Compliance 1) 36.9.1, Rhode Island regulations do not allow -(4) Specifications and 36 .9.3, the reduction of room drafts, use of 

Monitoring 36 .9 .4, working mode covers or adherence 

Requirements 36.9 .5, to an idling emission rate limits as 

36.9.6(c) control options. RI regulations 

2) 36.9.3, require that the solvent concentration 

36.9.4, in the carbon adsorber exhaust not 

36.9.6, exceed 25 ppm whereas the federal 

36 .9.5, regulation allows 100ppm . 

36 .5 .1, The RI rule is more stringent. 

36.6 .1 

(3)36.11 .3(a 

)(1), 

36.11 .3 a 2 
) 

(4) 

_ 36.11 .3(b) 

63.464(e)(2)(ix) RI rules do not contain provisions for 

,(x),(xi) continuous web solvent cleaning 

machines ; however RI does not have 

any continuous web cleaners . 

§ 63.463 (f) Idling Standards N/A RI does not allow the idling limit 

standard option. 

63.463(g),(h) RI rules do not contain provisions for 

continuous web solvent cleaning 

machines; however RI does not have 

any continuous web cleaning 

machines. 

§ 63.464 Alternate Standards § 36.8 RI does not allow alternative 

standards for machines with solvent 

air interface. RI does require 

alternative standards for machines 

without solvent air interface. RI 

regulations have no provisions for 

cleaning capacity. 

§ 63.465(a) Idling standard test N/A RI does not allow idling limits 

method 

§ 63.465 (b) Test method for § 36 .8.3 (a 

alternative standard & b 

§ 63.465 ( c) Calculation for § 36 .8.3 ( 

alternative standard c,d,e & f 

63.465 d Dwell time 36.9.6 a 

§ 63.465 (e) PTE for solvent RI General RI added the NESHAP definition of 

cleaning operations Definitions PTE for organic solvent cleaning to 

its general definitions regulation . 

63 .465(f),(g),(h) RI rules do not contain provisions for 

continuous web solvent cleaning 

machines ; however RI does not have 

any continuous web cleaning 

machines. 

§ 63.466 (a) Weekly monitoring § 36 .9 .3 

freeboard and § 

refrigeration device 36 .9 .4 

superheated vapor 

§ 63.466 (b) Monthly monitoring § 36.9.1 

of Cover and dwell and 36 .9 .6 

c 

$ 63.466 (c) Hoist speed § 36.9.2 

4 
a,b and d 

§ 63.466 (d) Reduced room draft N/A RI regulations do not allow reduced 'I 

room drafts for compliance with this 

regulation . ' 

63.466 e Carbon Adsorber 36 .9 .5 

- 

§ 63.466 (f) Idling limit N/A RI regulations do not allow idling 

limits as control options. 

§ 63.466 (g) Alternate § 36.9 .8 Requires both EPA and DEM to 

monitoring methods a pprove alternative method 

§ 63 .467 (a) Recordkeeping § 36.10.1 Additionally, RI requires records of 

Requirements (to training and superheated vapor dwell 

be kept for the be maintained . 

lifetime of the 

machine 

§ 63 .467 (b) Recordkeeping § 36 .10.2 Rhode Island does not explicitly 

Requirements (to require records of CA weekly 

be kept for the five measurements, but does require 

years) results of all monitoring required 

which includes CA weekly 

measurements. 

§ 63.467 (c & Recordkeeping § 36.10 .3 

d) Requirements 

(sources complying 

with alternative 

standards 

63.467 RI rules do not contain provisions for 

(a)(6),(7) continuous web solvent cleaning 

machines; however RI does not have 

any continuos web cleaning 

_ machines. 

§ 63 .468 (a) Initial notification § 36 .11 .1 

existin g sources a 

§ 63 .468 (b) Initial notifications - § 36 .11 .1 RI is more stringent requiring that 

new sources (b) initial notification reports be 

submitted 120 days before the 

startu p of the cleanin g machine. 

§ 63.468 (c,d Compliance § 36.11 .2 The RI regulation requires a 

& e) Notification Reports calculation of emissions for the first 

month but, since the RI report is due 

60 days after the compliance date, 

the 3-month average calculation (as 

in the federal regulation) in not 

required and cannot be required . 

However, the RI regulation does 

require sources to keep record s of 
each 3-month average calculation . 

§ 63 .468 (f) Annual Reporting 36 .11 .4 The RI regulation does not require 

sources complying with an alternative 

emission limit to list the size and type 

or each unit on the annual report. 

This information is part of the initial 

notification and is not likely to change 

and would therefor yield no additional 

information . 

§ 63.468 (g) Annual Report for 36 .11 .4 

sources complying 

with Alternative 

Standards 

§ 63 .468 (h) Exceedance § 36.11 .3 The RI regulation requires semireports (b,c,d & e) annual exceedance reports and 

unless DEM requires more frequent 

reporting, on a case by case basis. 

RI requires the following to be 

reported as exceedances (the 

NESHAP only requires these to be 

reported as exceedances if not 

corrected within 15 days): 

63 .463(e)(2)(i), (e)(2)(vi)(A), 

e(2)(vii)(A) (RI 36 .9 .3, 36.9.4, 

36 .9 .5) .The RI rule is more stringent. 

RI does not required the following to 

be reported as an exceedance as the 

NESHAP does but requires a record 

to be kept of these incidences : idling 

mode cover in place during parts 

entry and removal 

63.463(e)(2)(iv)(A), (e)(2)(vii)(c), (RI 

36.10.2( h) , 36.6.1, 36.7 .1 ) . 

§ 63.468 (I) Reduction in § 36 .11 .3 (f) 

Exceedance 

Reports 

63.468 J Reserved N/A 

§ 63.468 (k) Equivalency N/A 

timeframe for 

submittal 

§ 63.469 Equivalent Methods § 36.5.3(c ) RI's rule requires both EPA and DEM 

of Control , § approval. 

36.6.6( e) , 
36.6.7 (c ), 

36.9.8 

§ 63.471 Facility Wide § 36.4.17, § RI incorporated a monthly 

Emission Limits 36 .10 .2(b) halogenated HAP solvent emission 

and Associated and limit, calculated on a 12 month rolling 

Reporting 36 .10.4(d), average basis unless RI approves a 

Requirements § greater quantity of HAP emissions in 

36 .11 .4(b), an operating permit. In no case shall 

§ 36.11 .1(a) emissions exceed the facility wide 

and (b) . limit in 63.471 (RI 36.4.17). 

RI does not require all of the 

reporting and recordkeeping in the 

NESHAP under 63.471, so long as 

sources emit less than 50% of the 

facility wide emission limit in the 

63.471 . If a facility emits more than 

50% of the facility wide emission limit 

in 63 .471, it becomes subject to all of 

the reporting and recordkeeping in 

63 .471 ( RI 36.11 .4(b)) . 

Specifically, RI does not require 

sources to maintain a log of additions 

and deletions from the machine, and 

fill the machine on the first day of 

each month to calculate the facility 

wide emission limit (except batch 

vapor machines). But, RI does 

require sources to keep a record of 

the amount of perch loroethylene, 

trichloroethylene, and methylene 

chloride used each month (RI 

36.10.2(b) and 36.10.4(d)). 

RI does not require all of the 

information in the notification of 

compliance status report due to EPA 

by May 3, 2010, but RI does require 

sources so submit an annual report 

by April 15th of each year starting 

April 15, 2009 and report its solvent 

consumption (RI 36 .11 .4(b)). 

Also, RI has req uired the information 
in the May 3, 2010 report to be 

submitted previously (date of 

installation of machine and controls 

used RI 36.11 .1 a and ( b)) .