TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

COMAR 26.11.19.09-1 Control of VOC Emissions 

from Industrial Solvent Cleaning 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) for industrial cleaning solvents. EPA develops 

CTGs as guidance on control requirements for source 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 used in many different industries. These solvents 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 

production related work areas for a variety of reasons including safety, operability, and 

protection. The cleaning solvents used in these operations are, in many cases, generally available 

bulk solvents that are used for a variety of applications not limited to cleaning. 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. All solvents evaporate during use and solvent-based 

cleaning materials result in large 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. 

The industrial cleaning solvent product category includes products with differing VOC contents. 

There are several basic approaches to achieve VOC emission reductions from industrial cleaning 

solvents. First, emissions can be controlled through work practices targeted at the activities and 

sources of emissions specific to the industry (e.g., minimization of evaporation losses). Second, 

users can also reduce overall VOC emissions through solvent substitution (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. 

1 
Sources 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 standard and requirements for mixing vessels 

(tanks), spray booths, and parts cleaners (excluding cold or vapor degreasing covered under 

COMAR 26.11.19.09), where VOC emissions from cleaning operations at a premises are 15 

pounds or more per day (6.8 kg/day): 

1. A person subject to the regulation may not use 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 and 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 liter (0.42 1b/gal) of cleaning material. 

CTG Exemptions 

The CTG specifically exempts categories 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 

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• 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 controlled 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 Department 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 for approval as a revision to Maryland's State 

Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal 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 action, but the proposed action is not 

more restrictive or stringent. 

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References

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

2006