On April 17, 2013, DEP posted to public comment proposed changes to its Chapter 130, Solvent Cleaning Regulation. The proposed changes would expand the applicability of the regulation from covering "solvent cleaning machines" to covering "solvent cleaning operations." The proposed rule can be found here.
Under the proposal, industrial solvent cleaning activities with pre-control VOC emissions in excess of 5,400 lbs. during any consecutive 12-month period would be subject to new emissions and work practice requirements. Industrial solvent cleaning activities with pre-control emissions less than 5,400 lbs. would be subject to new recordkeeping requirements. The proposed regulation defines "industrial solvent cleaning" to include "the use of cleaning solvent to remove uncured adhesives, uncured inks, uncured coatings or contaminants...from parts, products, tools, machinery, equipment and work areas...incorporated into or used exclusively in manufacturing a product," including but not limited to "spray booth cleaning, cleaning of manufactured components, parts cleaning, [and] cleaning of production equipment for maintenance...."
Note that the existing 5% VOC exemption for cold cleaning machines would not apply to many industrial solvent cleaning operations covered by the new proposal.
The proposed regulatory changes would exempt certain activities subject to Chapters 123, 129, 154, 159, 161, 162, laboratory testing, and R&D activities.
DEP is accepting public comments on its proposal until May 17, 2013. If you would like assistance determining whether the DEP's proposed changes will affect your operations and, if so, developing comments for submission to DEP to express any concerns you may have regarding such impacts, please contact Dixon Pike or Brian Rayback.
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