# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

## COMAR 26.11.19.09-1 Control of VOC Emissions

from Industrial Solvent Cl eaning Operations other than Cold and Vapor Degreasing

Purpose of Regulation

The purpose of this action is to adopt the requirements of the Environmental Protection Agency (EPA) Control Techniques Guidelines (CTG) fo r industrial cleaning solvents. EPA develops CTGs as guidance on control requirements for sour ce categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes to adopt the CTG standards for industrial cleaning solvents.

Background

Industrial cleaning solvents are us ed in many different industries. These solvents are used to remove contaminants such as adhesives, inks, pain t, dirt, soil, oil, and grease. Contaminants are removed from parts, products, tools, machiner y, equipment, vessels, floors, walls, and other production related work areas fo r a variety of reasons includ ing safety, operability, and protection. The cleaning solvents us ed in these operations are, in many cases, generally available

bulk solvents that are used fo r a variety of applications not limited to cleaning. Petroleum distillates may be used as a cleani ng solvent, as a paint thinner, or as an ingredient used in the manufacture of a coating, such as paint. All solvents evaporate during use and solvent-based cleaning materials result in large emissions of VOC.

In 1994, EPA completed a study of industrial clean ing solvents that ch aracterized cleaning operations carried out within six focus industrie s (automotive, electrical equipment, magnetic tape, furniture, packaging, and photographic supp lies) to evaluate s ources of evaporative emissions from VOC solvents used as cleaning materials.

The industrial cleaning solvent product category includes products with differing VOC contents. There are several basic approach es to achieve VOC emission reduc tions from industrial cleaning solvents. First, emissions can be controlled thro ugh work practices targeted at the activities and sources of emissions specific to the industry (e .g., minimization of eva poration losses). Second,

users can also reduce overall VOC emissions through solvent substitu tion (e.g., use of low - VOC, no -VOC, or low -vapor pressure solvents). Industries can also reduce VOC emissions by using add-on controls, modifying equipment, or upgrading to using a lower emitting cleaning technology.

1Sources Affected

This proposed regulation affects users of industrial cleaning solvents. The regulation applies to facilities that emit 15 pounds or more per day (6.8 kg/day) of VOC.

Requirements of Regulation

COMAR 26.11.19.09-1 sets the following VOC standa rd and requirements for mixing vessels (tanks), spray booths, and parts cleaners (exc luding cold or vapor degreasing covered under COMAR 26.11.19.09), where VOC emissions from cl eaning operations at a premises are 15 pounds or more per day (6.8 kg/day):

1. A person subject to the regulation may not us e any VOC industrial solvent cleaning material that exceeds the vapor pressure 8 mm Hg at 20 deg. C (~ 0.152 psia) or 50 gram per liter VOC limit; and

2. Exemptions of industrial categories that have specific requirements for cleaning solvents are also included in the regulation.

Basis for Emission Standards

The CTG standards are applicable to emissions of VOC from the use, storage, and disposal of industrial cleaning solvents including work practices and cleaning materials, where VOC emissions from cleaning operations at a premises are 15 pounds or more per day (6.8 kg/day).

CTG Work Practice Standards

• Cover open containers a nd used applicators;

• Minimize air circulation around cleaning operations;

• Proper disposal of used solvent and shop towels; and

• Implement equipment practices that minimize emissions.

CTG VOC Content Standard

VOC content limit of 50 grams VOC per lite r (0.42 1b/gal) of cleaning material.

CTG Exemptions

The CTG specifically exempts cat egories listed under section 183( e) as well as categories of cleaning operations that are specifically excluded from existing rules. A brief list of the categories is given below:

• Aerospace coatings

• Wood furniture coatings

• Shipbuilding and repair coatings

• Flexible packaging printing materials

DRAFT 12/15/2009 1:10 PM 2• Lithographic printing materials

• Letterpress printing materials

• Flat wood paneling coatings

• Large appliance coatings

• Metal furniture coatings

• Paper film and foil coating

• Plastic parts coatings

• Miscellaneous metals parts coatings

• Fiberglass boat manufacturing materials

• Miscellaneous industrial adhesives

• Auto and light-duty truck assembly coatings

Expected Emissions Reductions

VOC emissions on a national level are expected to be reduced by 10-20 percent.

Health Effects and Ground-Level Ozone

The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

Since Maryland sources have already been contro lled by an existing regulation, there is minimal to no economic impact from this regulation. EPA has estimated the economic impact on a

national level and has determined it to be low. Costs for the controls are offset by the savings associated with low evaporative losses. The impact on the Department will be minimal as affected sources are already regulated. The Depa rtment will need to review additional records and ensure new standards are being met.

Revision to Maryland's SIP

This action will be submitted to the U.S. EPA fo r approval as a revision to Maryland's State Implementation Plan.

Other State or Federal Requirements

There are no other state or fede ral reasonably available control technology standards for this category. Multiple facilities are covered under this CTG and each may be subject to additional federal requirements.

Comparison to Federal Standards

There is a corresponding federal standard to this proposed acti on, but the proposed action is not more restrictive or stringent.

DRAFT 12/15/2009 1:10 PM 3DRAFT 12/15/2009 1:10 PM 4 References

Control Techniques Guidelines: Industrial Cleaning Solvents EPA 453/R-06-001 September

2006