On April 1, 2011, a wide range of industrial facilities first became subject to 35 IAC 218.187 and 35 IAC 219.187, which regulated many types of cleaning operations that use organic materials.  A certification statement was required to be submitted to the IEPA for sources subject to control requirements under this regulation and those exempt. On July 27, 2011, the Illinois Pollution Control Board (IPCB) issued a Final Order to adopt revisions to the VOM RACT rules, including updates to these industrial solvent cleaning provisions for the Chicago Area and Metro-East Area sources. 

The updated rules include a new compliance deadline of January 1, 2012.  Additionally, the applicability threshold was revised to 500 lb/month of VOM from cleaning operations (formerly 15 lb/day).  A clarification was also added that emissions from exempt cleaning operations identified in 218/219.187(a)(2) are not to be included in the calculation to determine applicability when compared with the 500 lb/month threshold.  Other notable updates include the addition of multiple compliance options for cleaning of equipment used in the manufacture of coatings, inks, adhesives, or resins including a new VOM content limitation. 

Given the number of changes from the previous version of the rule, IEPA has indicated that most sources will need to submit a second certification to the IEPA by January 1, 2012.