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 strin gent

. § 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 com

p liance 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 p rovisions

. 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 roomdraft

. 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 allowthe use of

- (a) (7) Line Cleaning reduced roomdrafts for compliance

Machine Standards with this regulation

. RI requires the automated parts handling systemto operate at 10ft/min whereas the federal regulation allows 11ft/min

. The RI rule is more strin g ent

. ' § 63.463 (b) Requirements for § 36 .6 .6 or RI regulations do not allowidling

Batch Va p

or 7 limits more strin gent ) and lessCleaning 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 g ent

. § 63.463 (d) (1- Work practice (1)36.6.1- RI regulations do not allowreduced 12) 36 .7 .1 (2) roomdrafts 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 roomdrafts, 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 allowthe 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 cleanin g ca paci ty

. § 63.465(a) Idling standard test N/A RI does not allowidling 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 g eneral definitions reg ulation

. 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 su perheated va p

or § 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 4a,b and d

§ 63.466 (d) Reduced roomdraft N/A RI regulations do not allow reduced 'I roomdrafts for compliance with this re g ulation

. ' 63.466 e Carbon Adsorber 36 .9 .5 - § 63.466 (f) Idling limit N/A RI regulations do not allowidling limits as control options

. § 63.466 (g) Alternate § 36.9 .8 Requires both EPA and DEM to monitorin g methods a pp rove 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 kee p record s ofeach 3-month avera g e 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 Re ports 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 re q uired the informationin the May 3, 2010 report to be submitted previously (date of installation of machine and controls used RI 36.11 .1 a and ( b))

.