In April 2011, a wide range of industrial facilities became subject to 35 IAC 218.187 and 35 IAC 219.187, which regulate many types of cleaning operations that use organic materials. On July 21, 2011, the IPCB issued a Final Order to adopt revisions to the VOM RACT rules, including updates to these industrial solvent cleaning provisions for Chicago Area and Metro-East Area sources.
Highlights of the updated rules include extension of the compliance deadline from April 1, 2011 to January 1, 2012, and revising the applicability threshold from 15 lb/day to 500 lb/month of VOM from cleaning operations. A clarification was also added that emissions from exempt cleaning operations identified in 218/219.187(a)(2) are not included in the calculation to determine applicability with this threshold. Therefore, IEPA has stated that most sources will need to submit a second certification to IEPA by January 1, 2012.
Multiple compliance options were added for cleaning of equipment used in the manufacture of coatings, inks, adhesives, or resins including a new VOM content limitation. Additionally, a work practice compliance option was established. Another compliance option was added for sources manufacturing coatings, inks, adhesives, or resins, for solvents that do not meet VOM content or composite vapor pressure limitations, provided the use of such solvents is restricted and the source complies with specified work practice and recordkeeping provisions.
Other notable items are changes to categorically exempt sources, an added clarification on threshold applicability calculations, additional recordkeeping requirements for exempt sources, specific recordkeeping requirements for manufacturers of coatings, inks, adhesives, or resins, and recordkeeping and certification requirements for some categorically exempt sources.
Full details of the changes are redlined in the final order of the rule.