7397-79-03
National Emission Standards for Halogenated Solvent Cleaning:
Summary of Requirements for Implementating the
NESHAP
September 1997
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DISCLAIMER
This report is not a legally binding document and is not meant to replace the published regulation
titled "National Emission Standard for Hazardous Air Pollutants (NESHAP): Halogenated
Solvent Cleaning" (59 FR 61801). This document discusses specific aspects of the regulation
and may not cover all parts of the regulation. It is intended solely as guidance, does not represent
final Agency action, and is not ripe for judicial review. It is not intended, nor can it be relied
upon, to create any rights enforceable by any party in litigation with the United States. The EPA
may change this document at any time without public notice.
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TABLE OF CONTENTS
Section
1.0 INTRODUCTION 1-1
2.0 SUMMARY OF THE RULE 2-1
2.1 Which Sources are Affected? 2-1
2.2 When Must Sources Comply? 2-5
'9 3.0 DETERMINE MACHINE TYPE AND SIZE 3-1
^ 3.1 Cleaning Machine Type 3-1
•£ 3.1.1 Batch vs. In-Line 3-1
5| 3.1.2 Vaporvs. Cold 3-1
'$ 3.1.3 Batch Cold Machines 3-4
3.2 Cleaning Machine Size 3-4
3.2.1 Batch Cold Machines 3-4
3.2.2 Batch Vapor Machines 3-4
3.2.3 In-line (cold & vapor) Machines 3-8
3.2.4 Calculating Solvent-Air Interface Area 3-8
3.2.5 Calculating Cleaning Capacity 3-8
4.0 DETERMINING COMPLIANCE OPTIONS 4-1
4.1 Batch Vapor Machines 4-1
4.1.1 Equipment Compliance Options 4-1
4.1.2 Overall Emission Limit 4-5
4.1.3 Machines Without a Solvent-Air Interface 4-5
4.2 In-line Machines 4-7
4.2.1 Machines Without a Solvent-Air Interface 4-7
4.3 Batch Cold-cleaning Machines 4-7
5.0 INSPECTION PROCEDURES 5-1
5.1 Preparing for the Inspection 5-1
5.2 On-site Inspection 5-2
5.2.1 General Protocol 5-2
5.2.2 Specific Requirements 5-3
5.3 Post-inspection Follow-up 5-5
6.0 QUESTIONS AND ANSWERS 6-1
7.0 OTHER IMPLEMENTATION MATERIALS 7-1
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TABLE OF CONTENTS (Continued)
Section Page
APPENDIX A - Glossary
APPENDIX B - Checklist
B. 1 Applicability Checklist
B.2 Batch Vapor Machines or In-Line (Vapor or Cold) Checklist
B.3 Batch Cold-Cleaning Machines Checklist
APPENDIX C - Conversion Chart
APPENDIX D - Emission Limits for Machines Without a Solvent-Air Interface
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LIST OF FIGURES
Figure Page
2-1 Applicability Flow Chart 2-2
2-2 Example Weight-Average Calculation 2-4
3-1 Batch Vapor Cleaning Machine 3-2
3-2 In-Line Cleaning Machine 3-3
3-3 Remote Reservoir Cleaning Machine 3-5
3-4 Immersion Cleaning Machine 3-6
3-5 Calculation of the Solvent-Air Interface 3-8
3-6 Solvent Cleaning Machine Cleaning Capacity = IW x IL x D 3-10
4-1 Batch Vapor Solvent Cleaning Machines Compliance Options 4-2
4-2 In-Line Solvent Cleaning machine Compliance Options 4-8
4-3 Batch Cold Cleaning Machines Compliance Options 4-9
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LIST OF TABLES
Table Page
4-1 Control Combinations for Batch Vapor Cleaning Machines 4-5
4-2 Control Combinations for In-Line Cleaning Machines 4-7
7-1 Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP ... 7-3
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1.0 INTRODUCTION
On December 2,1994, the U.S. Environmental Protection Agency promulgated
the final rule for the national emission standards for hazardous air pollutants (NESHAP) for
halogenated solvent cleaning (59 FR 61801). These standards implement Section 112 of the
Clean Air Act (CAA), and can be found in 40 Code of Federal Regulations (CFR) Part 63,
Subpart T. Subsequent amendments and corrections to the rule can also be found in Subpart T.
Subpart T is located on the EPA Technology Transfer Network (TTN) at
http:/www.epa.gov/docs/epacfr40/chapt-I.info/subch-c/40P0063/.
The halogenated solvent cleaning NESHAP was enacted to reduce emissions of
certain halogenated solvents that have been identified as hazardous air pollutants (HAPs). As
promulgated, the standard includes multiple alternatives to allow owners or operators maximum
compliance flexibility. These alternatives which are summarized in Section 4.0, include an
equipment standard with work practice requirements and an overall emission standard.
This document focuses on inspection of affected halogenated solvent cleaning
machines and provides tools for ensuring compliance with the standard. The use of this
document is not a requirement of the rule. Instead, it is intended to educate and provide guidance
to EPA regional, state, and local agency personnel, who will be responsible for implementing
and enforcing many of the provisions of this standard through inspections. Other materials have
been developed that provide background information on the halogenated solvent cleaning
NESHAP and instruct owners and operators on how to comply. Therefore, this document will
not exhaustively dissect and discuss the rule, but will refer the reader to places where background
information is already available. It is recommended that this document be used in conjunction
with the EPA publication "Guidance document for Halogenated Solvent Cleaner NESHAP",
EPA-453/R-94-081, April 1995. The publication is located on the EPA TTN at
http://www.epa.gov/tm/sbap/access.html. The file name is haloguid.zip, dated November 12,
1996.
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A set of applicability and compliance checklists are appended to this document.
These checklists provide the detail needed by an inspector to assess compliance with the standard
for each type of halogenated solvent cleaning machine affected. The information presented in
the body of this document is intended to equip those who will be using the checklists and to
provide a framework for applying them in the field. The implementing authority is encouraged
to use the checklists or modify them to meet state and local needs.
Section 2.0 briefly summarizes the sources to which this NESHAP applies.
Section 3.0 illustrates the general types and sizes of solvent cleaning machines that an inspector
could encounter in the field. Compliance options are outlined in Section 4.0, which presents
flow charts that will help determine the provisions that apply to different solvent cleaning
machines. Section 5.0 suggests procedures to follow before, during, and after a field inspection
of a solvent cleaning machine, and lists the tools and methods an inspector will need to use.
Commonly asked questions about implementing the standard, along with suggested answers, are
presented in Section 6.0. Other materials that might be helpful on the halogenated solvent
cleaning NESHAP are listed in Section 7.0. A glossary of terms associated with the standard can
be found in Appendix A. A set of applicability and compliance checklists appears in
Appendix B. Appendix C presents a unit conversion chart, and Appendix D contains a table of
emission limits for machines with no solvent-air interface area.
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2.0 SUMMARY OF THE RULE
2.1 Which Sources are Affected?
The halogenated solvent cleaning NESHAP rale applies to solvent cleaning
machines. Unlike some rales, this NESHAP does not apply to the facility, but to each individual
machine. Therefore, compliance is determined machine by machine and affects both major and
non-major (ie., area) sources of Hazardous Air Pollutants (HAPs). This NESHAP applies to
solvent cleaning machines that use a solvent containing 5 percent or more by weight of any one
or any combination of the following halogenated solvents:
Carbon tetrachloride (CAS No. 56-23-5)
Chloroform (CAS No. 67-66-3)
Perchloroethylene (CAS No. 127-18-4)
1,1,1-Trichloroethane (CAS No. 71-55-6)
Trichloroethylene (CAS No. 79-01 -6)
Methylene chloride (CAS No. 75-09-2)
In the rale, the definition of solvent cleaning machine excludes the following:
• Small buckets, pails, or beakers with capacities less than 7.6 liters
(2 gallons)
• Wipe cleaning activities, such as cleaning using a rag containing '
halogenated solvent or a spray cleaner containing halogent solvent.
Therefore, these uses of halogenated solvents are not covered by the requirements
of this rale. Figure 2-1 presents the above applicability criteria in the form of a flow chart.
'Found in the corrections to final regulations published on June 5,1995 60 FR 29485
2-1
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Do you own or operate a solvent
cleaning machine? (This excludes
small buckets, pails, and beakers
with capacities less than 7.6 liters
[2 gallons])
NO
NOT SUBJECT TO
THE RULE
YES
Does the solvent cleaning machine
use a solvent that contains 5 percent
or more by weight of any one or any
combination of the following
halogenated solvents?
• Carbon tetrachloride
• Chloroform
• Perchloroethylene
• 1,1,1 -Trichloroethane
• Trichloroethylene
• Methylene chloride
NO
NOT SUBJECT TO
THE RULE
YES
SUBJECT TO THE RULE
Figure 2-1. Applicability Flow Chart
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Generally, the listed solvents (when used in cleaning operations) are used in
amounts much greater than 5 percent by weight. If the halogenated solvent content is greater
than 5 percent by weight, no documentation of solvent content is required.
A solvent may be used that has a solvent content below the 5-percent cut-off
level. In these cases, documentation is required to demonstrate that the solvent falls below this
cut-off. For solvents that are used as supplied (i.e., without further mixing on site), the material
safety data sheets (MSDS) should provide sufficient documentation of solvent content. This
information (or equivalent as determined by the implementing agency) should be available from
the source upon request.
If the facility to be inspected blends solvent on site (i.e., mixes solvents together),
and the blend contains less than 5 percent by weight of the solvents listed above, the source must
document that the resulting solvent content is below the 5-percent cut-off level. The solvent
content of the blend can be calculated using a weighted average of the solvent contents of the
individual constituents based on their respective MSDS. An example weight-average calculation
is shown in Figure 2-2.2
Alternatively, the solvent content can be demonstrated using EPA Method 18,
which is based on the use of a flame ionization detector. A test report from a Method 18 test
showing a solvent content less than 5 percent is adequate to document that the rule does not
apply to the solvent cleaning machine in question.
Demonstration of applicability should be determined each time there is a
reformulation of an existing solvent or when a new solvent is used in a solvent cleaning machine.
2Blank forms are available in EPA Publication "Guidance Document for the Halogenated
Solvent Cleaner NESHAP", EPA-453/R-94-081, April 1995
2-3
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Example Calculation.
A facility blends solvent mixture X using three components. Knowing the mass of each
component and its respective solvent content in the batch, calculate the total solvent
content.
Step 1: Solvent Mixture X
Solvent Mixture Component
1 =PCE
2 = MC
3 =TCE
TW
Total Weight of Component
20g
30g
10g
s%
% of Listed Solvent
0.3
0
1.0
Total Weight of Solvent Mixture = 60g
(M)
Step 2:
TW
20g
30g
10g
X
X
X
S%
0.3
0
1.0
=
=
=
ws
6g
0
10g
TB = 16g
Step 3:
Sept 4:
WS, + WS2 + WS3 = TB
6g + Og + lOg = 16g
[Where, WS = weight of solvent in component
TB = Total WS per batch]
(TB -5- M) x 100 = TW%
(16g -5- 60g) x 100 = 27%
Solvent mixture X contains 27 percent by weight of the listed solvents. Solvent mixture X is
therefore considered to be a halogenated solvent, and solvent cleaning machines using solvent
mixture X are subject to rule.
Figure 2-2. Example Weight-Average Calculation
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2.2 When Must Sources Comply?
Compliance dates depend on whether the machine is an "existing" or "new"
machine. An existing machine is one that was installed or reconstructed on or before
November 29, 1993. A machine is defined as new if it was installed or reconstructed after
November 29,1993. Existing machines must comply by December 2,1997. New machines
must comply at startup or by December 2,1994, whichever is later. If a source commences
construction or reconstruction on a solvent cleaning machine on or before November 29, 1993,
but does not use halogenated solvents until after December 2,1994, the source has until
December 2, 1997 or 60 days after commencing the use of the halogenated solvent to comply,
whichever is later. A solvent cleaning machine moved within a contiguous facility or to another
facility under the same ownership constitutes an existing machine. Specific reporting
requirements are discussed in Section 4.0.
9
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3.0 DETERMINE MACHINE TYPE AND SIZE
Once you have determined that the rule applies to the machine to be inspected,
you will need to identify which type of machine it is. The type of machine determines the
available compliance options. The three basic types of machines covered by this regulation are:
batch vapor, batch cold, and in-line machines. In-line machines can be either vapor or cold.
3.1 Cleaning Machine Type
The rule has different requirements for different types of machines. Cleaning
machine types are classified by how parts are processed through the machine (batch vs. in-line),
and by whether or not solvent vapor is created in the cleaning process (vapor vs. cold).
3.1.1 Batch vs. In-Line
Batch: New parts or baskets of parts are introduced into a batch machine after the
previous parts or baskets of parts have been cleaned. Examples of batch machines
include "open top vapor" cleaning machines, which clean multiple batch loads
simultaneously and are manually loaded, such as a "Ferris wheel" machines, and
"cross-rod" machines that move parts semi-continuously through the cleaning
process. Figure 3-1 is an example of a batch vapor machine with a cutaway to
show internal features.
In-line: A cleaner is an in-line machine if the movement of the conveyor that carries parts
is continuous. Figure 3-2 illustrates an in-line vapor machine.
3.1.2 Vapor vs. Cold
Vapor: A vapor machine heats the solvent enough to create vapor (the batch and in-line
machines illustrated here are vapor machines).
Cold: A cold machine does not heat the solvent enough to create vapor. A carburetor
cleaning machine is an example of a cold cleaning machine.
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Solvent-air Interface
(top of solvent vapor zone)
Freeboard Height
Primary
Condenser Coils
Temperature
Indicator
CleanoutDoor
Level Indicator
Freeboard
Condensate Trough
Water Separator
Work Rest and
Protective Grate
Heating Elements
Figure 3-1. Batch Vapor Cleaning Machine
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Conveyor
Path"
Boiling
Chamber
Mesh
Belt
Figure 3-2. In-Line Vapor Cleaning Machine
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3.1.3 Batch Cold Machines
The two different types of batch cold machines covered by the rule are immersion
and remote reservoir.
In a remote reservoir batch cold cleaning machine, solvent is sprayed onto
the parts in a sink-like work area and drains back into an enclosed
container through a small drain (see Figure 3-3).
An immersion batch cold cleaning machine cleans parts by immersing
them in the solvent (see Figure 3-4). Note that an immersion machine
may store solvent in a remote reservoir, but is still considered an
immersion machine if parts are immersed in the solvent.
3.2 Cleaning Machine Size
The rule has different requirements for different sizes of machines. Machine size
is particularly important for determining compliance options for batch vapor machines.
3.2.1 Batch Cold Machines
The size of an affected batch cold cleaning machine does not determine
requirements or compliance options, so size does not have to be determined or verified for this
machine type.
3.2.2 Batch Vapor Machines
The size of a batch vapor machine is important, because the available compliance
options depend on machine size. Additionally, machine size is needed to determine compliance
with an overall emission limit (i.e., alternative standard, discussed in Section 4) if the alternative
compliance option has been selected. Machine size is determined by calculating the solvent-air
interface area of the machine. For machines that do not have a solvent-air interface (i.e., closed
loop systems), the cleaning capacity will need to be determined.
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j Cover
Spray
Hose
Cleaning \
Sink \ /
Solvent
Figure 3-3. Remote Reservoir Cleaning Machine (Batch Cold Cleaning)
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Basket
Solvent
Cover
Cleaning
Tank
Figure 3-4. Immersion Cleaning Machine (Batch Cold Cleaning)
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3.2.3 In-line (cold & vapor) Machines
Machine size is needed to determine compliance with an overall emission limit if
the alternative compliance option has been selected (see Section 4.0).
3.2.4 Calculating Solvent-Air Interface Area
The solvent-air interface area for a vapor machine is the location of contact
between the concentrated solvent vapor layer and the air. In a vapor machine, the vapor layer is
formed when the primary cooling coils condense the rising solvent vapor. This typically occurs
at the midline of the primary condenser coils (see Figure 3-1). For a cold machine, it is the
location of contact between the liquid solvent and the air.
The solvent-air interface area can be determined in any of the following ways:
• The information can be provided by the manufacturer via literature on the
machine; or
• The solvent-air interface area (SA) can be calculated by multiplying the
width (W) (in meters [or feet]) by the length (L) (in meters [or feet]) of
each sump and totaling the areas of all sumps (see Figure 3-5).
Dimensions can be either measured or obtained from literature.
The solvent-air interface area is equal to the surface area of all of the cleaning
tanks in the machine. For an in-line machine, it may not be possible to directly measure the
solvent-air interface area. In such cases, you will need to rely on the manufacturer or literature
supplied by the manufacturer for the appropriate information.
3.2.5 Calculating Cleaning Capacity
Some cleaning machines do not have a solvent-air interface area, because they do
not expose the cleaning solvent to the ambient air during or between the cleaning of parts. An
^ 7
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Immersion
Sump
Boiling
Sump
, = L1 x W1
SA2 = L2x W2
Solvent-air Interface Area = SA,, + SA
Figure 3-5. Example Calculation of the Solvent-Air Interface
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example of this type of cleaner is a vacuum-to-vacuum machine, which uses a processing
chamber capable of withstanding both full vacuum and pressure. These machines operate in a
closed loop, so solvent is not exposed to the air outside of the machine at any time.
For a machine that does not have a solvent-air interface area, the cleaning capacity
must be determined or verified. Cleaning capacity may be available from the vendor or in the
literature provided by the manufacturer. If the cleaning capacity is not directly available, it can
be calculated from measurements of the internal width (IW), internal length (IL), and depth of
the cleaner tank. These measurements can be taken from manufacturer literature or measured
directly as shown in Figure 3-6.
The cleaning capacity is then calculated by multiplying the dimensions
[CAPACITY = IW x IL x D]. The units of measurement can be meters or feet, resulting in a
cleaning capacity in m3 or ft3. As discussed in Section 4, cleaning capacity will determine the
required emission limit for the machine.
3-9
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IW
Figure 3-6. Solvent Cleaning Machine Cleaning Capacity = IW x IL x D
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4.0 DETERMINING COMPLIANCE OPTIONS
To accurately assess compliance, the inspector should first be familiar with the
options available to an owner or operator under the standard. In this section, the compliance
options available for each type and size of machine are summarized. A more detailed listing and
discussion of these options, along with their respective recordkeeping and reporting
requirements, can be found in 40 CFR 63 Subpart T and in the "Guidance Document for the
Halogenated Solvent Cleaner NESHAP" published by the U.S. Environmental Protection
Agency (EPA-453/R/94-081). In addition, the compliance checklists in Appendix B delineate
the compliance requirements for each option in sufficient detail to assess whether the machine
being inspected is in compliance. The implementing agency will find it useful to review the
source's initial notification report prior to conducting an inspection. The initial notification
report should provide the compliance option selected by the source.
4.1 Batch Vapor Machines
Figure 4-1 summarizes in a flow chart the compliance options available for
owners and operators of batch vapor machines under this NESHAP. For machines that have a
solvent-air interface, the owner or operator can choose to comply with equipment compliance
options (§63.463) or the overall emission limit (i.e., the alternative standard in §63.464).
4.1.1 Equipment Compliance Options
If equipment compliance options are chosen, the owner or operator must comply
with the base design and work practice requirements listed below.
Base Design:
• Cover or reduced room draft
• 0.75 or greater freeboard ratio
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Does the cleaning machine
have a solvent/air interface''
NO
Yes
PICK ONE
PICK ONE
V v
CONTROL COMBINATIONS
Comply withaJ! of the following
• Meet base design requirements
• Follow work practice requirements
• Install one of the listed control
combinations (Control options
depend on size; see Table 4-1 )
IDLING EMISSION LIMIT
Comply withal! of the following
• Meet base design requirements
• Follow work practice requirements
• Meet an idling emission limit of
0.22 kg/mj-hr (0.45 Ibs/ft2-hr)
OVERALL EMISSION LIMIT
Comply with the overall emission
limit based on cleaning capacity
(see Section 4 1.3)
OVERALL EMISSION LIMIT
Comply with the overall emission limit
of 150 kg/mj-month (30.7 Ibs/ft'-month)
Figure 4-1. Batch Vapor Solvent Cleaning Machines Compliance Options
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• Maximum parts handling speed of 3.4 m/min (11 ft/min)
• Liquid and vapor level indicators that shut off sump heat
• Primary condenser
• Carbon adsorber if using a lip exhaust
Work Practice:
• Control air disturbances in the cleaning machine and in the room.
• Do not introduce parts or baskets that occupy more than 50% of the solvent-air
interface area unless the speed is 0.9 m/min (3 ft/min) or less (for open-top
machines).
• Conduct spraying operations only in the vapor zone or areas not exposed to
ambient air.
• Orient parts so that solvent drains freely.
• Remove parts only after solvent dripping stops.
• During startup, turn primary condenser on before sump heater.
• During shutdown, turn sump heater off before primary condenser.
• Maintain equipment as recommended by the manufacturer or using alternate
maintenance practices approved by the EPA Administrator.
• Store solvent waste in closed containers.
• Do not clean absorbent materials.
• Take and pass an operator test, if requested.
• Transfer solvent using leakproof couplings.
Control Options:
If the control combinations option is chosen, the owner or operator is required to
select one of the control combinations listed for that particular cleaning machine size (based on
solvent-air interface area) and ensure that all of the controls marked for that control combination
are installed on the machine. The control options available, which are summarized in Table 4-1,
depend on the solvent-air interface area of the machine.
4-3
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Idling Emission Limit:
The idling emission rate may be provided by the manufacturer or can be
determined using Reference Method 307, which was finalized with the NESHAP. Control
combinations and the idling emission limit, including Method 307, are discussed in detail in the
"Guidance Document for the Halogenated Solvent Cleaner NESHAP."
4.1.2 Overall Emission Limit
If the owner or operator chooses instead to comply with the overall emission
limit, the base design and working practice requirements do not apply. The machine only has to
achieve an emission limit of 150 kg/m2-month, identified in Figure 4-1, based on a 3-month
rolling average. The methodology that must be used by the owner or operator to calculate
monthly and 3-month rolling average emissions is discussed in the "Guidance Document for the
Halogenated Solvent Cleaner NESHAP."
4.1.3 Machines Without a Solvent-Air Interface
Machines with no solvent-air interface must select the overall emission limit
option. The applicable emission limit depends on the cleaning capacity of the machine. For
machines with a cleaning capacity less than or equal to 2.95 m3 (104 ft3), determine the emission
limit using either Table 6 of §63.464 (see Appendix D) or the equation:
EL = 330(Vol)06 (1)
where:
EL = 3-month rolling average emission limit (kg/month)
Vol = cleaning capacity of the machine (m3).
4-4
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Table 4-1. Control Combinations for Batch Vapor Cleaning Machines
(with solvent-air interface)
Batch Vapor
Cleaning
Machine Size
Solvent-air
Interface Area
Less than or
equal to 1.21 m2
(13 ft2)
Solvent-air
Interface Area
Greater than
1.21 m2(13ft2)
Control
Combination
Option
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
Controls
Working
Mode Cover
v7
v7
v/
1.0 Freeboard
Ratio
v7
y
v/
v7
v-
v7
v/
V
Super
Heated Vapor
v7
•J
v7
v7
v/
v/
v/
v/
V
Freeboard
Refrigeration
v'
y
v/
v/
V
v/
v/
v7
v/
v/
v/
y
Reduced
Room Draft
v7
V7
v7
v/
V7
v/
v/
Carbon
Adsorber
y
v/
v7
1
v7
v/
v7
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For machines with a cleaning capacity greater than 2.95 m3 (104 ft3), Equation 1
must be used to determine the applicable emission limit.
4.2 In-line Machines
Compliance options for in-line machines are illustrated in Figure 4-2. The options
available depend on whether the machine is new or existing. Owners or operators choosing
equipment compliance options for in-line machines must meet the same base design and work
practice requirements listed above for batch vapor machines. The control combinations available
for in-line machines are shown in Table 4-2.
If the owner or operator chooses the alternative standard, the owner or operator
must achieve an emission limit, identified in Figure 4-2, based on a 3-month rolling average.
4.2.1 Machines Without a Solvent-Air Interface
An in-line machine with no solvent-air interface is subject to the same procedure
for determining an emission limit (based on cleaning capacity) that is discussed above for batch
vapor machines.
4.3 Batch Cold-cleaning Machines
The compliance options available to owners or operators of batch cold-cleaning
machines depend on whether the type of machine is immersion or remote reservoir. Figure 4-3
illustrates the differences in the compliance options. Work practices for remote reservoir
machines are as follows.
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Table 4-2. Control Combinations for In-Line Cleaning Machines
(with solvent-air interface)
In-Line
Cleaning
Machine Type
Existing
ividcinncs
New Machines
Control
Combination
Option
1
2
3
4
1
2
3
Controls
v/
v/
I
n
o>
X
o> o
a a
v/
v/
v/
o
11
5 j?
II
v/
v/
v/
v/
e
0 f
oS
v/
v/
v/
_
I
,
v/
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4-7
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EXISTING IN-LINE
Was the machine installed or
reconstructed on or before
November 29,19937
YES
NO
NEW IN-LINE
PICK ONE
OVERALL EMISSION LIMIT
Comply with the overall emission
limit of 153 kg/nf-month
(31 4 Ibs/ft2-month)
OVERALL EMISSION LIMIT
Comply with the overall
emission limit of 99 kg/rrf-month
(20 IbsTfP-montri)
PICK ONE
CONTROL COMBINATIONS
IDLING EMISSION LIMIT
CONTROL COMBINATIONS
IDLING EMISSION LIMIT
Comply withal! of the following:
• Meet base design requirements
• Follow work practice requirements
• Install one of the listed control
combinations for existing in-line
machines (see Table 4-2)
Comply withajl of the following
• Meet base design requirements
• Follow work practice requirements
• Meet an idling emission limit of
0 10 kg/mMir (0 021 Ibsffi2-hr)
Comply withaJ! of the following.
• Meet base design requirements
• Follow work practice requirements
• Install one of the listed control
combinations for new in-line
machines (see Table 4-2)
Comply withajl of the following.
• Meet base design requirements
• Follow work practice requirements
• Meet an idling emission limit of
0.10 kg/mMir (0.021 Ibs/fP-hr)
Figure 4-2. In-Line Solvent Cleaning machine Compliance Options
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4-8
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PICK ONE
Comply withal] of the following.
• Install a cover
• Provide a 2.5 cm water layer
Comply wlthajl of the following
• Install a cover
• Provide a 0.75 freeboard ratio or greater
• Follow work practice requirements
Remote Reservoir Cold
Cleaning Machines
Comply wtthaJ! of the following-
• Install a cover
• Follow work practice requirements
Figure 4-3. Batch Cold Cleaning Machines Compliance Options
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Work Practices:
Store solvent waste in closed containers.
Flush parts in freeboard area.
Minimize the pooling of solvent on and in parts.
Do not fill machine above fill line.
Clean up spills immediately.
Store wiperags in closed containers.
Do not agitate solvent to the point of causing splashing.
When cover is open, control room drafts.
Do not clean absorbent materials.
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5.0 INSPECTION PROCEDURES
This section suggests guidelines for conducting an on-site compliance inspection
of a halogenated solvent cleaning machine. Pre-inspection preparation, on-site procedures, and
inspection follow-up are outlined. The applicability and compliance checklists appended to this
document will be useful tools in directing both file review and equipment inspection.
5.1 Preparing for the Inspection
The first step in preparing to inspect a halogenated solvent cleaning machine
should be to review records available for the cleaner and facility in the regulating authority's
files, including any required reports related to the cleaning machine and general facility
information from permit files. The agency file review should provide background information
on the cleaning machine, allow determination of compliance with reporting requirements, and
indicate which compliance options will need to be assessed on site. The inspector should
complete as much of the applicability and appropriate compliance checklist as possible based on
the file review before making the site inspection to reduce the amount of paperwork and time
required at the facility. Information gleaned from agency files can then be checked and revised
as needed during the inspection.
The next step should be to contact the facility being inspected (unless the
inspection is to be purposefully unannounced). By contacting the facility in advance, the
inspector can arrange to have all the owner's or operator's files on the cleaning machine(s)
collected and available for review upon arrival. In addition, the inspector can ask that facility
personnel most familiar with the machine(s) be available for interviews, and appropriate contacts
can be established.
Finally, the inspectors should ensure that they have all the materials needed to
conduct an inspection. Inspection tools could include:
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• appropriate checklists
• a copy of the standard
• copies of the operator required tests
• a tape measure to check machine dimensions
• a stop watch to determine hoist speed
• a thermometer or thermocouple for temperature readings
• a velometer to check room-draft air speeds
• a colorimetric detector tube to measure exhaust concentrations from a carbon adsorber
• a calculator and calculation pad to check calculations required of the owner or operator
• a camera or video camera and film to record machine and facility conditions
• safety equipment, such as a hard hat, safety shoes, chemical resistant gloves, hearing and
vision protection, etc.
5.2 On-site Inspection
5.2.1 General Protocol
Upon arrival at the facility, an inspection kick-off meeting is useful and
appropriate. During the kick-off meeting, the inspector explains the purpose of the inspection
and outlines the schedule for the inspection, meets important facility contacts, answers questions,
and determines the location of records for the machine(s). The facility contact should be made
aware that all cold halogenated solvent cleaners are covered by the standard so that none of the
small, batch cold cleaners are overlooked during the visit. Also, the contact should be informed
that wipe cleaning, spray cleaning, and solvent cleaning machines not using halogenated solvent,
etc., are not covered by the standard to avoid spending time viewing these operations.
5-2
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After the kick-off meeting the inspector can inspect the halogenated solvent
cleaning machine(s). The applicability and appropriate compliance checklists serve to guide the
inspector through the inspection. Completing the applicability checklist will help determine the
machine type and size and whether it is new or existing. The inspector will then be directed to
the appropriate compliance checklist for the machine. The compliance checklists walk the
inspector through the requirements for the compliance option chosen for the machine. Where
there is compliance, the inspector can simply check the "Yes" box. If the machine is out of
compliance, the "No" box should be checked and an explanation logged on the checklist or a
separate record.
After inspecting the machines, the inspector will want to review owner or operator
files to verify information obtained from agency files and to check compliance with
recordkeeping requirements. Material safety data sheets (MSDS) on solvents could also be
collected at this time.
When on-site inspection and file review are complete, the inspector should have a
wrap-up meeting with appropriate facility personnel. The purpose of the meeting is to
summarize findings, explain any compliance violations noted, and inform the owner or operator
of the next step.
5.2.2 Specific Requirements
The following list describes how compliance with certain requirements of the
standard must be monitored, if it is assessed by the inspector. It is not the purpose of this
document to provide instructions on how field equipment works, for which the manufacturer's
manuals should be reviewed, but to direct its use according to the NESHAP.
• Wind speed measurements for establishing reduced room draft: (1) Determine the
direction of the wind by rotating a velometer (or similar wind speed measuring device)
withing six inches above the freeboard area of the machine until the maximum speed is
located; (2) Orient the velometer in the direction of the wind at each of the four corners of
the machine and record the reading for each corner; and (3) Total the values obtained at
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each corner and divide by four to obtain the average wind speed. Average room wind
speed should not exceed 15.2 meters/minute (50 feet/minute).
• Hoist speed of automated parts handling: Measure the time (in minutes) that it takes
the hoist to move parts or a parts basket a measured vertical distance (in meters). The
hoists speed can then be calculated by dividing the distance measured by the time
recorded. For example, if the time measured for the hoist to travel from a point above
the freeboard to a point at the fill line is 45 seconds (0.75 min.), and the distance between
these two points is 2 meters, the hoist speed is: 2 rn/0.75 min = 2.7 m/min. Parts
handling speed should not exceed 3.4 meters/minute (11 feet/minute).
• Exhaust concentration from a carbon adsorber: Measure and record the exhaust
concentration using a colorimetric detector tube while the machine is in working mode.
The colorimetric detector must be designed to measure a concentration of 100 ppmv of
solvent in air with an accuracy of ±25 ppmv. The samples must be taken at a point where
the air flow is unobstructed, at least 8 stack or duct diameters downstream and 2 stack or
duct diameters upstream of any flow disturbance such as a bend, contraction, expansion,
or outlet. Exhaust concentrations should not exceed 100 ppm. Colormetric tubes are
designed to detect specific chemicals. The regulatory agency may wish to carry tubes for
each type of halogenated solvent regulated under the rule, then sample based on the
halogenated content of the solvent used for a specific cleaning tank.
• Freeboard ratio: Determine freeboard ratio by measuring the freeboard height and the
smallest interior freeboard width and dividing the height by the width. A freeboard ratio
of 0.75 or greater is required when base design requirements apply. When using control
options available in the rule, follow the freeboard ratio identified in the control options
tables.
• Super-heated vapor (SHV) temperature: Measure the temperature of the super-heated
vapor at the center of the SHV zone. The solvent vapor at the center of the super-heated
vapor zone must be heated to at least 10°F above the solvent's boiling point.
• Freeboard refrigeration temperature: Measure the temperature of the freeboard
refrigeration device at the center of the air blanket above the vapor zone while the
machine is in idling mode. Freeboard refrigeration temperature must be no greater than
30% of the solvent's boiling point (°F).
• Dwell time: Measure the primary cleaning time, which is the amount of time required for
parts or parts baskets to cease dripping after being placed in the vapor zone (parts must be
at room temperature before being placed in the vapor zone). The allowable dwell time is
no less than 35 percent of the primary cleaning time.
• Solvent-air Interface area: See the discussion in Section 3.2.4.
• Cleaning Capacity: See the discussion in Section 3.2.5.
5-4
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5.3 Post-inspection Follow-up
Procedures to follow once the inspection is completed will be specific to the
responsible regulating authority. A written report of the inspection should be forwarded to the
owner or operator. The report describes the findings from the inspection, clearly delineates any
compliance violation discovered, and educates the owner or operator about what is required to
correct the violations and achieve compliance. If responsibility for enforcement will be
transferred to another person or agency, the inspector should provide this information.
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6.0 QUESTIONS AND ANSWERS
Below is a compilation of questions that an inspector may be asked about
implementation of the standard. An answer approved by the U.S. Environmental Protection
Agency follows each question. Most of the questions listed came from two sources: (1) inquiries
made at a satellite downlink seminar for small business owners in May 1995 on compliance with
the rule for vapor degreasers and (2) the Applicability Determination Index found on the TTN.
Section 7.0 describes and references both of these sources.
Applicability
Ql. Does the standard have a lower cut-off level for solvent use?
Al. No. The standard has no de minimis or solvent use cut-off level to determine
applicability. Except for buckets, pails, or beakers with capacities of 2 gallons or
less, the standard applies to all solvent cleaning machines that use the listed
solvents in concentrations of at least 5 percent.
Q2. Are solvent spray cans containing greater than 5 percent of a listed solvent
covered under the standard?
A2. No. Spray cans and hand wipes are not covered under this standard.
Q3. Does this standard apply to both major and area sources?
A3. Some NESHAP do differentiate between major and area sources and regulate only
major sources. However, this standard regulates both major and area sources.
Q4. Are paint strippers used to remove paint from wood furniture subject to
40 CFR 63, Subpart T?
A4. No. The finish on furniture is not a soil.
Q5. Is a bucket with a capacity of 2.4 gallons subject to 40 CFR 63, Subpart T?
A5. No. It is not subject if the following conditions are met: (1) a solvent capacity of
2 gallons or less is established with the container by clearly marking a fill line on
the container below the 2-gallon mark, (2) written facility standard operating
kam\K:Y7397\79\03\SOLV-CLN.ALL
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procedures prohibit filling the container with a regulated solvent above the fill
line, and (3) the facility follows the standard operating procedures.
Q6. Does the halogenated solvent NESHAP apply to ordinary 5-gallon buckets or
pails?
A6. Depending on site-specific circumstances, pails or buckets may be required to
comply with the batch cold cleaning machine standards in Section 63.462 of the
halogenated solvent cleaner NESHAP. (Also, see Q&A #5 above.)
Q7. An ultrasonic cleaning machine is not specified by name in the definition for
solvent cleaning machines, but it still uses the halogenated HAP liquid
solvent to remove soils from the surfaces of materials. Is it considered to be a
solvent cleaning machine?
A7. Yes. Even though it is not specifically stated by name, it is not excluded from the
requirements of 40 CFR Part 63, Subpart T.
Q8. A batch vapor coating extractor separates polyethylene from paper using
trichloroethylene. Is this extractor subject to Subpart T?
A8. No. Section 63.461 says a solvent cleaning machine is one that removes soils
from surfaces. The described activity is not a cleaning operation.
Q9. Is an enclosed tank system that sprays PCE onto dirty masks to clean them
classified as a batch cold cleaning tank without a solvent interface?
A9. Yes. This arrangement would be subject to Subpart T.
Q10. Does Subpart T apply to a chemical stripping operation using solvents
containing PCE?
A10. Yes. Although this process differs from cleaning of parts, the use of a solution
containing 5% or more of regulated solvents triggers the application of Subpart T.
Qll. Are vapor degreasers used to restore the surface of molded plastic devices
subject to the degreasing NESHAP rule?
All. Yes.
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Compliance Options and Requirements
Q12. For an in-line machine with a carbon adsorber, can the dwell area be outside
the freeboard if solvent from the dwell goes back into the machine and the
area is vented to the carbon adsorber?
A12. Yes, if the solvent is recovered from the dwell area and returned to the machine,
and vapors from the dwell area are vented through a carbon adsorber, the dwell
area can be located outside the freeboard.
Q13. If the alternative standard is chosen, do machines with lip exhausts have to
have carbon adsorbers?
A13. No specific control is required if the source chooses to comply with the alternative
standard. A carbon adsorber would only be required under the equipment control
options.
Q14. Does a machine have to be cleaned out on a monthly basis?
A14. The standard does not require that solvent cleaning machine be cleaned out on a
monthly basis. However, if the alternative standard is chosen for compliance, the
owner or operator might want to clean the machine monthly. Solvent contained in
the solid waste from the machine does not have to be counted toward monthly
emissions. If the machine is not cleaned and the solvent content of the waste is not
determined, the waste solvent will be not be accounted for in the mass balance
and will be included in the monthly emissions estimate.
Q15. Does the 11-ft/min parts handling requirement refer to the conveyor speed,
the vertical hoist speed, or both?
Al5. The automated parts handling speed of 3.4 m/min (11 ft/min) in the base design
requirements refers to both the vertical and horizontal speeds of the system.
Q16. To meet the freeboard requirements in the halogenated solvent cleaner
NESHAP, would the following design be allowed: Mount a by-parting cover
on top of an existing degreaser lip, then add the freeboard extension
immediately on top of the by-parting cover structure?
Al 6. The halogenated solvent cleaner NESHAP rule defines freeboard height.
However, the rule does not require specific design parameters regarding freeboard
construction. The objective of the NESHAP is to reduce emissions of selected
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halogenated solvents used in parts cleaning. In developing the rule, EPA has
provided the regulated community some flexibility on how best to meet this
objective.
Q17. If room parameters are used and a door is closed during the test, can that
door ever be opened or does the test need to be done with the door both
opened and closed to ever be able to use a door?
Al 7. If a door is closed when measurements are taken to establish room conditions, it
may still be used for entry and exit, but the door must remain closed at all other
times to demonstrate compliance.
Definitions
Q18. What is meant by the "location" of the degreaser mentioned in the reporting
requirements?
Al 8. The location required in reports that must be submitted under the standard refers
to the physical address of the facility where the machine is located (as opposed to
the mailing address). It does not refer to the location of the machine within the
facility.
Measurements and Calculation Methods
Q19. Where can you get the test apparatus for Method 307?
A19. Reference Method 307 is described in Appendix A of 40 CFR 63 Subpairt T. The
Method involves reading level indicators that are required design components
under the standard. Therefore, the only "equipment" needed will be incorporated
as a component of the cleaning machine. No additional apparatus is required.
Q20. How do you determine the solvent content of the solid waste resulting from
cleaning out a machine?
A20. Either engineering calculations or Method 25d are acceptable under the standard.
Q21. How often do values of idling emissions have to be verified?
A21 . The idling emission rate must be initially established based on information from
the manufacturer or a Reference Method 307 test. The conditions and parameters
used to establish initial compliance must then be monitored periodically, but the
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actual idling emission rate does not. However, if any of the conditions or
parameters change, the idling emission rate will have to be reestablished using
Method 307 under the new conditions.
Q22. Where is the interior dimension measured for calculating the freeboard ratio
of a halogenated solvent cleaning machine?
A22. The measurements of the interior dimension should be made at the opening of the
degreaser.
Q23. If a freeboard refrigeration device is used and the air blanket temperature
has to be measured at the center of the air blanket, where is the center of the
air blanket? Is the center in the middle of the length and width of the
machine at some point above the condensers or is it at the middle of the
length, width and height (distance from middle of primary condensing coils
to top of freeboard)?
A23. As defined in the rule, the "centerline of the air blanket is equidistant between the
sides of the machine." (§ 63.461)
Q24. When measuring wind speed with the velometer, is the velometer rotated in
only the horizontal plane or rotated in all directions (horizontal and
verticle)?
A24. The velometer should be rotated in a horizontal plane within six inches of the top
of the freeboard area to determine the direction of maximum wind speed. The
wind speed is then measured at the four comers of the top of the machine.
Because individual velometers are different, check the owners manual for the
correct method of operation for your velometer.
Operator Testing
Q25. How will the operator test be administered if the operator is unable to read
or write in English?
A25. The test could be administered verbally or translated into a language understood
by the operator. The specifics of administration in this type of situation will be up
to the regulatory authority implementing the standard.
Q26. What if an operator misses questions on the test (i.e., what is considered
passing), and what are the consequences?
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A26. The test and the answers are supplied in 40 CFR 63 Subpart T, Appendix B, so
operators should be able to thoroughly familiarize themselves with it in case it is
given by an inspector. Whether an operator passes, and thus compliance is
demonstrated, will be determined by the regulatory authority implementing the
standard.
Regulatory Deadlines
Q27. Why is a machine defined as new or existing based on a date of
November 29,1993?
A27. November 29,1993 was the date that EPA proposed the emission standard for
halogenated solvent cleaning.
Q28. Can the compliance method selected for existing machines be changed before
the December 2,1997 compliance date?
A28. Yes, the method of compliance chosen by an owner or operator may be changed
before the compliance date. A revision to the initial notification should be
submitted to the regulating authority.
Q29. A solvent cleaning machine was built prior to 11/29/93, but has not used any
regulated halogenated solvent since prior to 12/2/94. There are no plans to
use it again. Is the machine considered an existing source and, therefore,
subject to the 12/2/97 compliance date?
A29. Yes. It is an existing source, because it was built prior to the cutoff date.
Reporting
Q30. What are the consequences of late submittal or failure to submit the initial
notification report?
A30. A late submittal or failure to submit the initial notification would be violation of
the reporting requirements of the standard and, therefore, a violation of the
standard itself. The appropriate regulatory or enforcement authority would deal
with specific penalties associated with such violations.
Q31. Is an exceedance report required even if there is no exceedance?
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A31. Yes, an exceedance report is required at least semiannually for all affected batch
vapor and in-line cleaners. If no exceedance has occurred during the reporting
period, the report should state so.
Q32. Do batch cold-cleaning machines require an initial notification report?
A32. Yes, an initial notification report must be submitted for affected batch cold
cleaners.
Q33. If an existing machine will be shut down by December 2,1997, is an initial
notification report required?
A3 3. Yes, an initial notification report was due by August 29,1995. The report, or any
revision to the report, should clearly state that the machine will be shut down
before the compliance date to avoid inquiries about the initial compliance report.
Q34. When are compliance notifications due?
A34. Initial compliance reports for existing machines are due by May 1,1998. For new
machines, initial compliance reports are due no later than 150 days after startup.
Annual compliance reports are due before February 1 of the year following the
year covered by the initial compliance report.
Solvents
Q35. Are there plans to eliminate or ban the use of any of the solvents covered by
the rule?
A3 5. The Montreal Protocol on substances that deplete the ozone layer will phase out
production and consumption of carbon tetrachloride and 1,1,1-trichloroethane,
because they are ozone depleting substances. The EPA considers each of the
other listed solvents to be well regulated, and there are currently no plans to ban
their use.
Title V
Q36. What are the Title V permitting requirements for this NESHAP?
A36. If the solvent cleaning machine is located at a major source, it must be included in
the Title V permit. For machines covered by this standard that are not located at a
major Title V source, EPA is allowing the States flexibility to defer requirement
of a permit for up to five years.
f\ 7
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7.0 OTHER IMPLEMENTATION MATERIALS
Other materials are currently available that might be helpful to those responsible for
implementing this NESHAP. Table 7-1 lists a number of these materials, ranging from
published documents to videotapes to information on the Internet. The table presents the
following information for each item:
Title
• Publishing or producing organization
• Intended purpose
• Summary of contents
• Where it is available
Many of the documents listed can be down-loaded via the Internet from EPA's Office
of Air Quality Planning and Standards (OAQPS) Technology Transfer Network (TTNWeb)
[ttnwww.rtpnc.epa.gov/html/sscd/compli.htm]. If assistance is needed, the TTNWeb has a
helpline at (919) 541-5384 to provide help to users.
As referenced in previous sections, some of the information in this implementation
document was taken from the first item mentioned in the table, the "Guidance Document for the
Halogenated Solvent Cleaner NESHAP", which was developed under the Small Business
Assistance Program. The guidance document discusses the rule and compliance with the rule in
detail and presents examples of forms that sources may use to comply with monitoring and
recordkeeping requirements.
Another item that may be of particular interest to those who conduct field inspections
but do not have extensive experience with vapor degreasers is the videotape "Clean Air Act
Compliance for Solvent Degreasers: Regulatory Strategies for Manufacturers Affected by the
Clean Air Act Amendment NESHAP for Halogenated Solvent Cleaners" (Satellite
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Teleconference). The video captures the 4-hour satellite downlink session sponsored by EPA's
Air Pollution Training Institute (APTI) that was produced to assist small businesses in
complying with the standard. Segments of the video present case studies of compliance issues,
with footage of batch vapor and in-line degreasers and their components. The instruction manual
for this video, "Clean Air Act Compliance for Solvent Degreasers," published by the University
of Tennessee Center for Industrial Studies, includes drawings of various types of halogenated
solvent cleaners. Further information in the manual is listed in Table 7-1.
Finally, EPA's Office of Enforcement and Compliance Assurances (OECA)
maintains a database called the Applicability Determination Index (ADI), which contains
memoranda issued by EPA on applicability and compliance issues associated with the New
Source Performance Standards (NSPS), NESHAP (Part 61, and MACT, Part 63), and
chlorofluorocarbons (CFC). Recently issued determinations are added to the database on a
quarterly basis. Determinations for Subpart T can be accessed on the TTNWeb.
7-2
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Table 7-1
Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP
t>j
&
o
n
5
r
Title
Published/Produced by:
Purpose
Contents
Where Available?
Guidance Document for the
Halogenated Solvent Cleaner
NESHAP
EPA-453/R-94-081
U. S. EPA (OAQPS/ESD)
Research Triangle Park, NC
April 1995
Assist owners and
operators of solvent
cleaning machines,
particularly in small
business, to determine
whether the NESHAP
applies to them and
compliance options
available
Applicability criteria
Descriptions and diagrams of
different types of machines with
corresponding compliance
options and requirements
Alternatives to halogenated
solvent cleaning
Appendices with calculation and
monitoring instructions,
recordkeeping forms, EPA
Regional office contacts
TTNWeb
[www.epa.gov/ttn/]
Clean Air Act Compliance for
Solvent Degreasers
The University of
Tennessee Center for
Industrial Services
April 1995
Help small business
understand the
NESHAP for
halogenated solvent
cleaners
Applicability criteria and
deadlines
Cleaner types (diagrams and
descriptions)
Compliance strategies
Recordkeeping and reporting
Appendices with worksheets,
reporting and recordkeeping
forms, Title V overview
UT Center for Industrial
Studies
423-974-2249
www.cis.utk.edu
(In print only)
Permitting Guide for Solvent
Degreasers to Comply with the
Federal National Emission
Standard for Hazardous Air
Pollutant (NESHAP) for
Solvent Cleaning and the
Significant New Alternative
Policy Requirements-Version
1.1 (DRAFT)
South Coast Air Quality
Management District
Los Angeles, CA
August 20, 1996
Permitting guidance for
SCAQMD relative to
NESHAP for solvent
cleaning machines and
Title VI Significant
New Alternatives
Policy
Permit application checklist
SNAP Program summary
Permit conditions for each
solvent cleaner type and
compliance option
South Coast AQMD
21865 E.Copley Dr.
Diamond Bar, CA
91765-4182
909-396-2000
(In print only)
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sr
I
Table 7-1
Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP (Continued)
O
O
Title
Published/Produced by:
Purpose
Contents
Where Available?
National Emission Standard for
Hazardous Air Pollutants
Halogenated Solvent Cleaning
- Background Information for
Final Standards
EPA-453/R-94-071
U. S. EPA (OAQPS/ESD)
Research Triangle Park, NC
Novembers, 1994
Provide information on
final NESHAP
Summary of public comments on the
proposed rule, EPA responses to the
comments, and changes from the
proposed rule
TTNWeb
[www.epa.gov/ttn/]
Fact Sheet - Halogenated
Solvent Cleaning Machine
NESHAP
U. S. EPA
Research Triangle Park, NC
November 1994
Summary of NESHAP
Highlights of background, standards
and impacts
TTNWeb
[www.epa.gov/ttn/]
New Regulation Controlling
Air Emissions from Solvent
Cleaning Machines
(Degreasers)
EPA-453/F-94-083
U. S. EPA
Research Triangle Park, NC
March 1995
Brochure on
compliance options and
requirements of
NESHAP
Summary of compliance options and
requirements for each type of
cleaning machine
TTNWeb
[www.epa.gov/ttn/]
Understanding Regulations on
Solvent Cleaning Equipment:
What You Need to Know to
Comply
Pacific Northwest Pollution
Prevention Center
(Northwest Business
Assistance Network)
November 1996
Provide compliance
information to small
businesses in
Northwest with cold
cleaners
Summary of provisions for batch
cold cleaning machines and pollution
prevention opportunities
[www.pprc.org/pprc]
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Table 7-1
Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP (Continued)
I
UJ
65
O
>
t-
Title
Published/Produced by:
Purpose
Contents
Where Available?
Clean Air Act Compliance for
Solvent Degreasers: Regulatory
Strategies for Manufacturers
Affected by the Clean Air Act
Amendment NESHAP for
Halogenated Solvent Cleaners.
Satellite Teleconference.
University of Tennessee
Center for Industrial
Services
and
Center for
Telecommunications and
Video
April 1995
Information to small
business on compliance
for vapor degreasers
Explanation of Subpart T
Compliance case studies
Instruction on cleaner parts
Solvent substitution
Sources of assistance for small
business
Question and answer sessions
(VHS video; 2 tapes)
Uniform Air Quality Training
Program Course #233: Solvent
Cleaning and Degreasing
California Air Resources
Board
Slides from a training
course for California
inspectors of solvent
cleaners and degreasers
Descriptions of various solvent
cleaners
Emissions and control devices
CA rule discussion
Inspection procedures
California Air Resources
Board
Compliance Division
Contact: Randy Opfer
916-445-0961
[ropfer@arb.ca.gov]
Solvents: Cleaning,
Degreasing, Recycling, and
Disposing
California Air Resources
Board
December 1995
Manual to assist
inspectors and
operators conduct
inspections of solvent
operations
Overview of California ARB
Overview of common solvents
and their applications
Descriptions of various solvent
operations and emissions control
Inspection procedures
California legal requirements
Discussion of toxics and
halogenated solvents
California Air Resources
Board/
Compliance Division/
Attn: Manager,
Compliance Assistance
Program/
P.O.Box 2815/
Sacramento, CA 95812
(In print only)
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sr
I
Table 7-1
Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP (Continued)
VO
I
O
f
O
>
f
Title
Published/Produced by:
Purpose
Contents
Where Available?
Halogenated Solvent
Degreasers Air General Permit
Notification Form
Florida Department of
Environmental Protection
(Division of Air Resources
Management)
June 25, 1996
Instruct sources on
application for general
Title V permit for
halogenated solvent
cleaners
Procedures for use of general
permit
Permit terms and conditions
Notification forms and
instructions
Fact sheets
Division of Air
Management Resources,
MS-5510
2600 Blair Stone Rd.
Tallahassee, FL
32399-2400
904-488-6140
[www.dep.state.fl.us/air/
regulation/permitting/
forms]
Ohio EPA Inspection Form,
Fact Sheet, and Standard
Terms & Conditions
Ohio EPA
Information for permit
writers and inspectors
of halogenated solvent
cleaners
Standard permit terms and
conditions
Inspection forms
Fact sheet
[www.epa.ohio.gov/
dapc/mact/
degrease.html]
Sage 2.1, Solvent Alternatives
Guide: User's Guide
EPA-600/SR-95-049
U.S. EPA
May 1995
Assist users in
identifying alternatives
to halogenated solvents
Interactive database that provides a
list of potential alternative solvents
based on user inputs
TTNWeb
[www.epa.gov/ttn/]
Contact: Charles Darvin
919-541-7633
Notification of Compliance
Deadline
Lincoln-Lancaster County
Health Department
Initial notification and
statement of
compliance form for
cold cleaners
Form for sources using cold cleaning
buckets subject to the rule
Lincoln-Lancaster
County Health Dept.
3140 "N" Street
Lincoln, NE 68510
Contact: Jim Fobben
402-441-8040
(in print only)
-------
Table 7-1
Other Implementation Materials for the Halogenated Solvent Cleaning NESHAP (Continued)
1
o
o
z
Title
Project Summary,
Demonstration of Alternative
Cleaning Systems
EPA-600/SR-95/120
Published/Produced by:
U.S. EPA
Office of Research and
Development
August 1995
Purpose
Summarize evaluation
of substitutes for
halogenated solvents as
part of the
33/50 program
Contents
• Objective
• Methodology
• Technical, environmental, and
economic evaluations
• Conclusions
Where Available?
TTNWeb
[www.epa.gov/ordntrnt/
ORD/Webpubs/projsum/
index.html]
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APPENDIX A
Glossary
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GLOSSARY
Air blanket means the layer of air inside the solvent cleaning machine freeboard located above
the solvent-air interface. The center of the air blanket is equidistant between the sides of the
cleaning machine.
Automated parts handling system means a mechanical device that carries all parts and parts
baskets at a controlled speed from the initial loading of soiled parts through the removal of the
cleaned parts. Automated parts handling systems include, but are not limited to, hoists and
conveyors.
Carbon Adsorber means a bed of activated carbon into which an air-solvent gas-vapor stream is
routed and that adsorbs the solvent on the carbon.
Clean liquid solvent means fresh unused solvent, recycled solvent, or used solvent that has been
cleaned of soils (e.g., skimmed of oils or sludge and strained of metal chips). The rule did not
intend that usable solvent should be disposed. It intended that all metal and dirt soils be removed
from the machine so that solvent emissions are not underestimated.
Construction means the on-site fabrication, erection, or installation of an affected source.
Cover means a lid, top, or portal cover that shields the solvent cleaning machine openings from
air disturbances when it is in place and is designed to be easily opened and closed without
disturbing the vapor zone. Air disturbances include, but are not limited to, lip exhausts,
ventilation fans, and general room drafts. Types of covers include, but are not limited to, sliding,
biparting, and roll-top covers.
Downtime mode means the time period when a solvent cleaning machine is not cleaning parts
and the sump heating coils, if present, are turned off.
A 1
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Dwell means the technique of holding parts within the freeboard area but above the vapor zone of
the solvent cleaning machine. Dwell occurs after cleaning to allow solvent to drain from the
parts or parts baskets back into the solvent cleaning machine.
Existing cleaning machine means a cleaning machine constructed or reconstructed on or before
November 29, 1993. An existing machine is also a machine in which construction or
reconstruction was commenced on or before November 29,1993, but that did not meet the
definition of a solvent cleaning machine on December 2,1994, because it did not use a listed
halogenated solvent liquid or vapor. A machines in this category shall become an existing source
when the machine begins to use such liquid or vapor. A solvent cleaning machine moved within
a contiguous facility or to another facility under the same ownership constitutes an existing
machine.3
Freeboard height means for a batch vapor cleaning machine, the distance from the solvent-air
interface, as measured during the idling mode, to the top of the cleaning machine. For an in-line
cleaning machine, it is the distance from the solvent-air interface to the bottom of the entrance or
exit opening, whichever is lower as measured during the idling mode. The freeboard height for a
batch cold cleaning machine is the distance from the solvent fill line (the line that the sump is
filled to) to the lip of the cleaning machine.
Freeboard ratio means the ratio of the solvent cleaning machine freeboard height to the smaller
interior dimension (length, width, or diameter) of the solvent cleaning machine. For example, if
the height of the freeboard is 2 meters and the smaller interior dimension is 1.8 meters, the
freeboard ratio would be 2 meters/1.8 meters or 0.9.
Freeboard refrigeration device (FRD, also called a chiller) means a set of secondary coils
mounted in the freeboard area that carries a refrigerant or other chilled substance to provide a
3Found in the corrections to final regulations published on June 5, 1995 60 FR 29485
A-2
kam\K:\7397\79\03\SOLV-CLN.ALL
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chilled air blanket above the solvent vapor. The rule requires that a FRD have enough cooling
capacity to cool the air in the freeboard area of the machine to a temperature no greater than
30 percent of the boiling point of the solvent being used. The following lists the temperature that
a FRD must achieve for each of the solvents covered under the rule.
Solvent
Methylene Chloride
Trichloroethylene
1,1,1,-Trichloroethane
Chloroform
Carbon Tetrachloride
Perchloroethylene
Boiling Point
(°F)
104
189
165
143
168
250
Maximum Allowed Air
Blanket Temperature
°F
31
57
50
43
50
75
°C
0
14
10
6
10
24
Freeboard zone for a batch vapor cleaning machine, means the area from the solvent-air
interface, as measured during the idling mode, to the top of the cleaning machine. For an in-line
cleaning machine, it is the area within the solvent cleaning machine that extends from the
solvent-air interface to the bottom of the entrance or exit opening, whichever is lower. The
freeboard zone for a batch cold cleaning machine is the area from the solvent fill line (the line
that the sump is filled to) to the lip of the cleaning machine.
Hoist means a mechanical device that carries the parts and parts baskets from the loading area
into the solvent cleaning machine and to the unloading area at a controlled speed. A hoist may
be operated by controls or may be programmed to cycle parts through the cleaning cycle
automatically.
kam\K:\7397\79\03\SOLV-CLN.ALL
A-3
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Idling mode means the time period when a solvent cleaning machine is turned on but is not
actively cleaning parts.
Idling-mode cover means any cover or solvent cleaning machine design that allows the cover to
shield the cleaning machine openings during the idling mode. A cover that meets this definition
can also be used as a working-mode cover if that definition is also met.
Lip exhaust means a device installed at the top of the opening of a solvent cleaning machine that
draws in air and solvent vapor emissions from the freeboard area and ducts the air and vapor
away from the solvent cleaning area.
New cleaning machine means a solvent cleaning machine for which the construction or
reconstruction is commenced after November 29, 1993.
Potential to emit, as defined in 40 CFR Part 63, Subpart A, means the maximum capacity of a
stationary source to emit a pollutant under its physical and operational design. Any physical or
operational limitation on the capacity of the stationary source to emit a pollutant, including air
pollution equipment and restrictions on hours of operation or on the type or amount of material
combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect
it would have on emissions is federally enforceable.
For solvent cleaning machines, potential to emit is determined on the basis of the yearly hours of
operation, the working-mode uncontrolled emission rate, and the solvent/air interface area.
Unless otherwise restricted by a federally enforceable requirement, the hours of operation must
be based on the total number of hours in a year (8,760 hours). A facility's total potential to emit
is the sum of the HAP emissions from all solvent cleaning operations, plus all HAP emissions
from other sources within the facility.
A-4
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Primary cleaning time means the amount of time it takes a part to reach the vapor zone
temperature.
Primary condenser means a series of circumferential cooling coils on a vapor cleaning machine
through which chilled liquid or gas is circulated or recirculated to provide continuous
condensation of rising solvent vapors and, thereby, create a controlled vapor zone.
Reconstruction, as defined in 40 CFR Part 63, Subpart A, means the replacement of components
of an affected or a previously unaffected stationary source to such an extent that:
(1) The fixed capital cost of the new components exceeds 50 percent of the
fixed capital cost that would be required to construct a comparable new
source; and
(2) It is technologically and economically feasible for the reconstructed source
to meet the relevant standard(s) established by the Administrator (or a
State) pursuant to Section 112 of the Act. Upon reconstruction, an
affected source, or a stationary source that becomes an affected source, is
subject to relevant standards for new sources, including compliance dates,
irrespective of any change in emissions of hazardous air pollutants from
that source.
Reduced room draft means decreasing the flow or movement of air across the top of the
freeboard area of the solvent cleaning machine to less than or equal to 15.2 meters per minute (50
feet per minute). Methods of achieving a reduced room draft include, but are not limited to,
redirecting fans and/or air vents so that they do not blow across the cleaning machine, moving
the cleaning machine to a corner where there is less room draft, and constructing a partial or
complete enclosure around the cleaning machine.
Solvent fill line means the line, typically on the interior of a solvent cleaning machine sump, that
indicates the level to which the cleaning machine should be filled with solvent (established
before parts are added).
A S
kam\K:V7397Y79\03\SOLV-CLN.ALL
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Solvent-air interface means for a vapor cleaning machine, the location of contact between tiae
concentrated solvent vapor layer and the air. This location of contact is defined as the midline
height of the primary condenser coils. For a cold cleaning machine, it is the location of contact
between the liquid solvent and the air.
Solvent-air interface area for a vapor cleaning machine, means the surface area of the solvent
vapor zone that is exposed to the air. For an in-line cleaning machine, it is the total surface area
of all the sumps; for a cold cleaning machine, it is the surface area of the liquid solvent that is
exposed to the air.
Solvent vapor zone for a vapor cleaning machine, means the area that extends from the liquid
solvent surface to the level at which the solvent vapor is condensed. This level is defined as the
midline height of the primary condenser coils.
Sump means the part of a solvent cleaning machine where the liquid solvent is located.
Super-heated vapor system (SHV) means a system that heats the solvent vapor, either passively
or actively, to at least 10°F (5°C) above the solvent's boiling point. Parts are held in the super-
heated vapor before exiting the machine to evaporate the liquid solvent on them. Hot vapor
recycle is an example of a SHV system. The following is the minimum temperature thsit a SHV
system much achieve in the super-heated vapro zone for the solvents covered by the rule.
Solvent
Methylene Chloride
Trichloroethylene
1,1,1,-Trichloroethane
Chloroform
Carbon Tetrachloride
Perchloroethylene
Boiling Point
(°F)
104
189
165
143
168
250
Maximum Allowed Air
Blanket Temperature
op
114
199
175
153
178
260
°C
46
93
79
67
81
127
kam\K:Y7397\79\03\SOLV-CLN.ALL
A-6
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Water cover for a cold cleaning machine, means a layer of water that floats above denser solvent
and provides control of solvent emissions. If the solvent used is not denser than water, a water
layer (water cover) will not float above your cleaning solvent and will not control solvent
emissions. In many cases the solvent used in batch cold cleaning machines is sold containing the
appropriate amount of water to create a water cover. The water cover must be 2.5 cm (1 in) thick
to comply with this option of the rule.
Working-mode means the time period when the solvent cleaning machine is actively cleaning
parts.
Working-mode cover means any cover or solvent cleaning machine design that allows the cover
to shield the cleaning machine openings from outside air disturbances during the working mode
(i.e., while parts are in the cleaning machine) and during the idling and downtime modes. A
working-mode cover is opened only during parts entry and removal. A cover that meets this
definition can also be used as an idling-mode cover if that definition is also met.
A 7
kam\KA7397Y79\03\SOLV-CLN.ALL ^ '
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APPENDIX B
Checklist
B.I Applicability Checklist
B.2 Batch Vapor or In-Line (Vapor or Cold)
Machines Checklist
B.3 Batch Cold-Cleaning Machines Checklist
kam\K:\7397Y79\03\SOLV-CLN.ALL
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B.I Applicability Checklist
kam\K:\7397\79\03\SOLV-CLN.ALL
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APPLICABILITY CHECKLIST
Halogenated Solvent Cleaning NESHAP
NOTE: This checklist will help determine whether a solvent cleaning machine/degreaser is subject to the
Halogenated Solvent cleaning NESHAP.
1. GENERAL INFORMATION
A. Date of Inspection:
B. Facility Name:
C. Facility Address:
D. Facility Contact:
(Name, Title, and Phone)_
E. Is the facility a major or area source? Major n Area n
F. Inspector(s):
Name Title/Affiliation Phone Number
2. MACHINE AND SOLVENT IDENTIFICATION
A. Solvent Cleaning Machine Identification Number
B. Solvent Cleaning Machine Location (within facility)
C. Is the machine a solvent cleaning machine as defined by the rule?
(see below) Yes n No n
(If no, do not proceed, this rule does not apply to this machine.)
• A solvent cleaning machine is anything that holds solvent (greater than 2
gallons or 7.6 liters) into which parts are placed to be cleaned. If the unit is less
than 2 gallons, it is only subject to this rule if it is specifically designed to clean
parts (i.e., an open bucket that has a capacity of less than 2 gallons is not a
solvent cleaning machine.).
• Almost anything can be considered a "part." If things are put into the unit to be
to be cleaned, it is likely a solvent cleaning machine.
• Wipe cleaning activities (e.g., using a rag) or a spray cleaner containing
halogenated solvents are not subject to the rule.
R1 1
kam\K:\7397\79\03\SOLV-CLN.ALL ~
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D. Does the machine use one of the following halogenated solvents (the solvent must
contain at least 5 percent, in total, of the following HAP solvents)?
Yes No
perchlorethylene (CAS No. 127-18-4) n D
1,1,1-trichloroethane (CAS No. 71-55-6) n n
trichlorethylene (CAS No. 79-01-6) n D
methylene chloride (CAS No. 75-09-2) n n
carbon tetrachloride (CAS No. 56-23-5) n n
chloroform (CAS No. 67-66-3) n a
(If you answered no to all, do not proceed, this rule does not apply to this machine.)
E. Is the machine a new source or existing source?
Installed or constructed after 11/29/93 New n
Installed or constructed on or before 11/29/93 Existing n
[Note: Moving a machine from one location to another within the facility does not make
it a new source.]
F. What is the type of the cleaning machine?
Batch Vapor n
In-line Vapor D
In-line Cold n
Batch Cold n
(Go to the appropriate compliance checklist for this machine type.)
3. INSPECTOR COMMENTS:
END OF FORM
R1 2
kam\K:Y7397Y79\03\SOLV-CLN.ALL DL-A
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B.2 Batch Vapor or In-Line (Vapor or Cold)
Machines Checklist
kam\K:\7397\79\03\SOLV-CLN.ALL
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COMPLIANCE CHECKLIST FOR
BATCH VAPOR OR IN-LINE MACHINES
Halogenated Solvent Cleaning NESHAP
NOTE: This checklist will help determine whether a batch vapor or in-line (cold or vapor) machine is in
compliance with the Halogenated Solvent Cleaning NESHAP.
1. GENERAL INFORMATION
A. Cleaning machine ID No.:
B. Installation Date: . ——
C. Machine is: New a Existing a
2. MACHINE SIZE
Indicate the machine size based on whether the machine has a solvent-air interface.
A. Solvent-air interface area: m2 or ft2
(Equal to the surface area of all cleaning sumps. E (L, x W,) = solvent-air interface)
OR if no solvent-air interface area
B. Cleaning Capacity: m3 or ft3
(Equal to the product of internal width, length and depth of the tank. IW x IL x D = cleaning capacity)
3. COMPLIANCE OPTION
Mark the compliance option chosen by owner/operator, and complete the checklist sections
indicated for this option.
A. Base design + work practices + control combination Q
Complete sections 4, 5, 8 and 9
B. Base design + work practices + idling emission limit n
Complete Sections 4, 6, 8 and 9
C. Alternate standard (i.e., overall emission limit) D
[Note: This is the only option available for machines with no solvent-air interface.]
Complete Sections 7, 8 and 9
4. BASE DESIGN AND WORK PRACTICE REQUIREMENTS
Complete the tables below by filling in any required measurements, calculations, or observations, and
check either "Yes" or "No" to document compliance.
DO 1
kam\K:\7397\79\03\SOLV-CLN.ALL DZ.-1
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A. Base Design Requirements:
The solvent cleaning machine must meet all criteria in the table to be in compliance.
Citation
Compliance
§63.463(a)(l)(i)
§63.463(d)(l)(i)
§63.463(e)(2)(iv)
Monitoring
§63.466(b)(l)
QR
Compliance
§63.463(a)(l)(ii),
§63.463(e)(2)(ii)(A)
Monitoring
§63.466(d)
Compliance
§63.463(e)(2)(ii)(B)
Compliance
§63.463(a)(2)
Base Design
Parameter
Machine idling and downtime
cover is tightly fitting; free of
holes cracks, or other defects;
and is in place when parts are
not in the machine.4
Cover is inspected monthly to
ensure it is free of holes,
cracks, or other defects.5
Room draft not exceeding
15.2m/min(50ft/min)2.
Room draft is monitored
according to §63.466(d).
Owner/operator established and
maintains the operating
conditions of testing.1
Machine has a freeboard ratio
of 0.75 or greater.
Calculate by dividing freeboard height
by the smallest interior freeboard
width.
Measurement,
Calculation, or
Observation
Monitoring
frequency:
Average wind speed:
Room parameters or
enclosure used?:
Monitoring
frequency:
Freeboard ratio:
Freeboard height:
Interior width:
In
Compliance?
Yes
No
4 Exceedance has occurred if this requirement has not been met and is not corrected within 15 days of
detection (§63.463(e)(3)(ii)).
5 Exceedance has occurred if this requirement has not been met (§63.463(e)(3)(i)).
R9 ?
kam\K.\7397\79\03\SOLV-CLN.ALL D4.-L
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A. Base Design Requirements (Continued):
Citation
Compliance
§63.463(a)(3)
Monitoring
§63.466(c)
Compliance
§63.463(a)(4)
Compliance
§63.463(a)(5)
Compliance
§63.463(a)(6)
Compliance
§63.463(a)(7)
Monitoring
§63.466(e)(2)(vii)
Base Design
Parameter
Machine has an automated
handling system, and it moves
at a speed of 3.4 m/min
(11 ft/min) or less.
Determine hoist speed monthly
(quarterly if no exceedances for
year or otherwise approved by
Administrator) by taking the
distance and dividing by rate.
Liquid level indicators to shut
off sump heat are present and
functioning for vapor
machines.
Vapor level indicators to shut
off sump heat are present and
functioning for vapor
machines.
Primary condenser present and
functioning.
Lip exhaust carbon adsorber (if
applicable) exhaust must not
exceed lOOppmhalogenated
solvent.
Carbon adsorber bed is not
bypassed during desorption.
Lip exhaust is above the cover.
Measurement,
Calculation, or
Observation
Handling speed:
Distance: (ml
Rate: (mm"*
Monitoring
frequency:
Outlet concentration:
Solvent sampled:
In
Compliance?
Yes
No
kam\K:\7397V79\03\SOLV-CLN.ALL
B2-3
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B. Work Practice Requirements:
The solvent cleaning machine must meet all criteria in the table to be in compliance.
Citation
Compliance
§63.463(d)(l)(i)
§63.463(d)(l)(ii)
Compliance
§63.463(d)(2)
Compliance
§63.463(d)(3)
Compliance
§63.463(d)(4)
Compliance
§63.463(d)(5)
Compliance
§63.463(d)(6)
Compliance
§63.463(d)(7)
Compliance
§63.463(d)(8)
Compliance
§63.463(d)(9)
Work Practice
Requirement
Control air disturbances across
cleaning machine openings by (check
one):
Q Keeping cover(s) in place during
idling and downtime
Qi
Q Room draft reduction
For open-top machines, ensure that
parts or parts baskets do not occupy
more than 50% of the solvent-air
interface area, or introduce the parts
or baskets at a speed of 0.9 m/min
(3 ft/min) or less.
Perform all spraying operations
within the vapor zone or within a
section of the machine that is not
directly exposed to ambient air.
Orient parts so that the solvent drains
from them freely.
Remove parts or baskets only after
dripping has stopped.
When starting up, turn on the primary
condenser before the sump heater.
When shutting down, turn off sump
heater before the primary condenser.
Add or drain solvent using threaded
or other leak-proof couplings, and
ensure that the end of the pipe or
hose introducing solvent is located
beneath the liquid solvent surface.
Maintain equipment as recommended
by manufacturer or using approved
alternate maintenance practices.
Observation
Solvent-air interface
area:
Handling speed:
Distance:
Rate:
In
Compliance?
Yes
No
kam\K:Y7397Y79\03\SOLV-CLN.ALL
B2-4
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B. Work Practice Requirements:
Citation
Compliance
§63.463(d)(10)
Compliance
§63.463(d)(ll)
Compliance
§63.463(d)(12)
Work Practice
Requirement
Operators must complete and pass
applicable sections of the Test of
Solvent Cleaning Procedures
(Appendix B of Part 63, Subpart T) if
asked to do so by the inspector.
Collect and store waste solvent, still
bottoms, and sump bottoms in closed
containers.
Do not clean absorbent materials,
such as sponges, fabric, wood, and
paper, in the machine.
Observation
In
Compliance?
Yes
No
kam\K:\7397\79\03\SOLV-CLN.ALL
B2-5
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5.
CONTROL COMBINATIONS
A. Options for Batch Vapor Machines
Circle the Control Combination number in the table below that applies to this machine
(§63.463(c)(l)-(2)). Then complete the compliance inspection information in the referenced
sections.
Batch Vapor
Cleaning Machine
Size
- i- - >; , ,
:/'"^ t'&&fr,^f«%}
Solvent-air
Interface Area
Less than or equal
to 1.21m2 (13 ft2)
[§63.463(b)(l)(i)]
Solvent-air
Interface Area
Greater than
1.21m2 (13 ft2)
[§63.463(b)(2)(i)]
Control
Combination
(circle the number
that applies)
>>r ,
£.-'••*• -^^^^-^W/' '
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
Control and Checklist Section to Complete:
Working
Mode Cover
C.I
v7
v/
V
1 .0 Freeboard
Ratio
C.2
v/
v/
y
v/
v7
v/
v/
v/
Super
Heated Vapor
C.3
v7
v/
v/
v/
v/
y
y
y
v/
Freeboard
Refrigeration
C.4
v/
v/
v/
v/
v7
v/
v/
v/
y
v/
y
v/
Reduced
Room Draft
C.5
v7
v7
v7
v/
v/
v/
v7
Carbon
C6
v/
v/
v7
1
C.7
v/
v7
v7
kam\K:\7397\79\03\SOLV-CLN.ALL
B2-6
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B.
Options for In-line Machines
Circle the Control Combination number in the table below that applies to this machine
(§63.463(c)(l)-(2)). Then complete the compliance inspection information in the sections for
the applicable controls following this table and check either "Yes" or "No" to document
compliance.
In-Line Cleaning
Machine Type
' - ,-. ^fp^V ,"/ /-V^:
'"J-**"""- ' ' f "*>'
Existing Machines
[§63.463(c)(l)(i)]
New Machines
[§63.463(c)(2)(i)]
Control
Combination
(circle the
number that
applies)
: yf f viMfi. ::: \::y.v. f
1
2
3
4
1
2
3
Control and Checklist Section to Complete:
S
•s
a>
it .2
°K
C.2
^
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kam\K-\7397\79\03\SOLV-CLN.ALL
B2-7
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C. Control Combination Requirements
C.I Working Mode Cover
Citation
Compliance
§63.463(e)(2)(iii)(A)
Compliance
§63.463(e)(2)(iii)(B)
Monitoring
§63.466(b)(l)
Working Mode Cover
Parameter
Cover opens only during parts
entry and removal and
completely covers machine
openings when closed.
Cover is maintained free of
cracks, holes, and other
defects.
Cover is inspected monthly to
ensure it is free of holes,
cracks, or other defects.
Measurement,
Calculation, or
Observation
In
Compliance?
Yes
No
C.2 Freeboard Ratio of 1.0
Citation
Compliance
§63.463(c)(l)(i)
§63.463(c)(2)(i)
Freeboard Ratio
Parameter
Machine has a freeboard ratio
of 1.0 or greater.
Calculate by dividing freeboard height
by the smallest interior freeboard
width.
Measurement,
Calculation, or
Observation
Freeboard ratio:
Freeboard height:
Interior width:
In
Compliance?
Yes
No
kam\K:\7397Y79\03\SOLV-CLN.ALL
B2-8
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C.3. Superheated Vapor
Citation
Compliance
§63.463(e)(2)(vi)(A)
Compliance
§63.463(e)(2)(vi)(B)
Compliance
§63.463(e)(2)(vi)(C)
Monitoring
§63.466(a)(2)
Superheated Vapor
Parameter
Solvent vapor at the center of
the superheated vapor zone
must be heated to at least 10°F
above the solvent boiling point
(BP)6.
Manufacturers specifications
for determining proper dwell
time are followed7.
Parts must remain in the
superheated vapor zone for
minimum proper dwell time4.
The temperature at the center
of the superheated vapor zone
must be measured and recorded
weekly while the machine is
idling (retain the records for 5
years).
Measurement,
Calculation, or
Observation
Temperature:
Solvent BP:
Temp, difference:
Specification:
Dwell time:
In
Compliance?
Yes
No
6Exceedance has occurred if this requirement has not been met and are not corrected within 15 days
of detection (§63.463(e)(3)(ii)).
7Exceedance has occurred if this requirement has not been met (§63.463(e)(3)(i)).
kam\K \7397\79\03\SOLV-CLN.ALL B2-9
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C.4 Freeboard Refrigeration
Citation
Compliance
§63.463(e)(2)(i)
Monitoring
§63.466(a)(i)
Freeboard Refrigeration
Parameter
Air in the freeboard must be at
a temperature no greater than
30 percent of the solvent
boiling point (in °F)3.
The air blanket temperature
above the vapor zone must be
measured and recorded weekly
while the machine is idling
(retain the records for
5 years).
Measurement,
Calculation, or
Observation
Solvent BP (op) :
Temp (°F):
Temp. As%ofBP:
In
Compliance?
Yes
No
C.5 Reduced Room Draft
Citation
Compliance
§63.463(e)(2)(ii)(A)
Compliance
§63.463(e)(2)(ii)(B)
Monitoring (room
parameters)
§63.466(d)(l)
Monitoring
(enclosure)
§63.466(d)(2)
Reduced Room Draft
Parameter
The average windspeed in the
room or enclosure is less than
or equal to 15.2 m/min (50
ft/min).
Owner/operator established and
maintains the operating
conditions of testing.
Windspeed is measured and
recorded quarterly. Room
conditions established during
testing are monitored weekly.
Windspeed is measured and
recorded monthly. Enclosure
conditions is monitored
monthly.
Measurement,
Calculation, or
Observation
Average windspeed:
In
Compliance?
Yes
No
3Exceedance has occurred if this requirement has not been met and are not corrected within 15 days
of detection (§63.463(e)(3)(ii)).
kam\K:\7397\79\03\SOLV-CLN.ALL
B2-10
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C.6 Carbon Adsorber (with Lip Exhaust)
Citation
Compliance
§63.463(e)(2)(vii)(A)
Compliance
§63.463(e)(2)(vii)(B)
Compliance
§63.463(e)(2)(vii)(C)
Monitoring and
Recordkeeping
§63.466(e)
§63.467(b)(4)
Carbon Adsorber
Parameter
Halogenated solvent
concentration in the exhaust
does not exceed 100 ppm using
colorimetric detector tube.5
The carbon bed cannot be
bypassed during desorption.6
The lip exhaust must be located
above the cover.6
The exhaust concentration of
the halogenated solvent must
be measured and recorded
weekly, (retain the records for
5 years).
Measurement,
Calculation, or
Observation
Concentration:
Solvent tested:
In
Compliance?
Yes
No
5Exceedance has occurred if this requirement has not been met and are not corrected within 15 days
of detection (§63.463(e)(3)(ii)).
6Exceedance has occurred if this requirement has not been met (§63.463(e)(3)(i))
R? 11
kam\K:\7397\79\03\SOLV-CLN.ALL DZ-" L l
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C.7 Dwell
Citation
Compliance
§63.463(e)(2)(v)(A)
Compliance
§63.463(e)(2)(v)(B)
Test Methods
§63.465(d)(l)
Test Methods
§63.465(d)(2)
Monitoring
§63.466(b)(2)
Recordkeeping
§63.467(a)(3)
Dwell
Parameters
Determine the proper or
maximum dwell time for each
type of part or parts basket to
be cleaned.6
Ensure that parts are held in the
freeboard area above the vapor
zone for the proper dwell time.6
Determine the amount of time
for the parts to cease dripping
once placed in the vapor zone.
Proper dwell time for parts to
remain in the freeboard area
above the vapor zone is no less
than 35% of the actual dwell
time.
Actual dwell time must be
measured and recorded
monthly.
Retain records of the tests to
determine proper dwell time
for the lifetime of the machine.
Measurement,
Calculation, or
Observation
Proper dwell time
recorded (sec)
Actual measured
dwell time (sec)
% of actual dwell
time:
In
Compliance?
Yes
No
6Exceedance has occurred if this requirement has not been met (§63.463(e)(3)(i))
R2 12
kam\K:\7397Y79\03\SOLV-CLN.ALL
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6.
IDLING EMISSION LIMIT
Complete the tables below by filling in any required measurements, calculations, or observations, and
check either "Yes" or "No" to document compliance.
Citation
Compliance
(batch vapor)
§63.463(f)(l)(i)
§63.463(b)(l)(ii)
§63.463(b)(2)(ii)
Compliance
(in-line)
§63.463(f)(l)(i)
§63.463(c)(l)(ii)
§63.463(c)(2)(ii)
Test Methods
§63.465(a)
Compliance
§63.463(f)(l)(ii)
Compliance
§63.463(f)(2)
Idling
Parameters
Demonstrate that the batch
vapor machine can meet an
emission limit of 0.22 kg/hr-m2
(0.045 lbs/hr-ft2) of solvent-air
interface area when idling.7
Demonstrate that the in-line
machine can meet an emission
limit of 0.10 kg/hr-m2 (0.021
lbs/hr-ft2) of solvent-air
interface area when idling.7
Determine idling emission rate
using Reference Method 307
(in Appendix A of Subpart T).
Establish operating parameters
to demonstrate compliance.
For example, if a control from
the Control Combination
section of the rule was used,
the requirements for that
control must be followed.7
Conduct periodic monitoring to
demonstrate compliance.7
Measurement,
Calculation, or
Observation
Periodic monitoring
of parameters
selected:
Parameters machine is
operated within:
Frequency of
monitoring
performed:
Type of monitoring:
In
Compliance?
Yes
No
7Exceedance has occurred if this requirement has not been met. Determine if exceedance of
parameters are classified as an immediate exceedance or whether a 15-day repair period would be
allowed (§63.463(0(4)(i)-(ii)).
kam\K.\7397\79\03\SOLV-CLN.ALL
B2-13
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6.
IDLING EMISSION LIMIT (Continued)
Citation
Compliance
§63.463(f)(3)
Recordkeeping
§63.467(a)(4)
Monitoring
§63.466(f)
Idling
Parameters
Operate machine within
parameters identified in the
initial performance test.8
Retain the results of the initial
test, including the idling
emission rate and values of
monitoring parameters
measured, for the life of the
machine.
If using a control from the
Control Combinations list,
monitoring requirements for
that control must be followed
or alternative monitoring must
be approved by the
Administrator
Measurement,
Calculation, or
Observation
In
Compliance?
Yes
No
8Exceedance has occurred if this requirement has not been met. Determine if exceedance of
parameters are classified as an immediate exceedance or whether a 15-day repair period would be
allowed (§63.463(f)(4)).
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B2-14
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7.
ALTERNATIVE STANDARD (Overall Emission Limit)
Complete one of the sections below based on whether the machine being inspected has a solvent-air
interface. Check "Yes" or "No" to document compliance.
A. Machines with Solvent-air Interface
NOTE: For machines with solvent-air interface areas, compliance requirements depend
on machine type and whether the machine is existing or new.
Citation
Compliance
§63.464(a)(l)(ii)
Compliance
§63.464(a)(l)(ii)
Compliance
§63.464(a)(l)(ii)
Solvent-air Interface
Alternative Standard
Parameters
For a batch vapor machine, the 3-
month rolling average emissions
of listed solvent from the
machine, calculated monthly,
must not exceed 150 kg/m2-month
(30.7 Ibs/ft2-month).9
For an existing in-line machine,
the 3 -month rolling average
emissions of listed solvent from
the machine, calculated monthly,
must not exceed 153 kg/m2-month
(31.41bs/ft2-month).10
For a new in-line machine, the 3-
month rolling average emissions
of listed solvent from the
machine, calculated monthly,
must not exceed 99 kg/m -month
(20 lbs/ft2 month).11
Measurement,
Calculation, or
Observation
Rolling Average:
Rolling average:
Rolling average:
In
Compliance?
Yes
No
9Exceedance has occurred if this the 3-month rolling average emission limit has not been
met(§63.464(c)).
10Exceedance has occurred if this the 3-month rolling average emission limit has not been
met(§63.464(c)).
HExceedance has occurred if this the 3-month rolling average emission limit has not been
met(§63.464(c)).
kam\K:\7397\79\03\SOLV-CLN.ALL
B2-15
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A. Machines with Solvent-air Interface (Continued)
Citation
Compliance
§63.464(a)(l)(i)
Recordkeeping
§63.467(c)(l)-(2)
Compliance
§63.464(b)
Recordkeeping
§63.467(c)(3)
Test Methods
§63.465(b)
Test Methods
§63.465(b)
Test Methods
§63.465(c)
Solvent-air Interface
Alternative Standard
Parameters
Maintain records (dates and
amounts) of solvent added to the
machine and solvent and waste
removed from the machine (retain
records for 5 years).
Maintain records of calculations
of monthly and 3 -month rolling
average emissions on a monthly
basis (retain records for 5 years).
On the first day of every month,
ensure that the machine contains
only clean solvent.
Return the solvent each month to
the fill line established during the
first month the measurements
were made.
Determine solvent emissions on
the first operating day of each
month.
Measurement,
Calculation, or
Observation
In
Compliance?
Yes
No
kam\K:Y7397Y79\03\SOLV-CLN.ALL
B2-16
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B. Machines without Solvent-air Interface
NOTE: For machines without solvent-air interface areas, compliance requirements
depend on the cleaning capacity of the machine.
Citation
Compliance
§63.464(a)(2)(ii)(A)
Compliance
§63.464(a)(2)(ii)(B)
Compliance
§63.464(a)(l)(i)
Recordkeeping
§63.467(c)(l)-(2)
Compliance
§63.464(b)
Recordkeeping
§63.467(c)(3)
Test Methods
§63.465(b)
Test Methods
§63.465(b)
Test Methods
§63.465(c)
Recordkeeping
§63.467(d).
Alternative Standard
Parameters
(No Solvent-air Interface)
For machines with a cleaning capacity
less than or equal to 2.95 m\ the
monthly emissions must not exceed the
emission limited determined using use
either Table 6 or Equation 1 of 40 CFR
63. 464. 12
For machines with a cleaning capacity
greater than 2.95 m3, the monthly
emissions must not exceed the emission
limit determined using Equation 1 of 40
CFR 63.464."
Maintain records (dates and amounts) of
solvent added to the machine and solvent
and waste removed from the machine
(retain records for 5 years).
Maintain records of calculations of
monthly and 3 -month rolling average
emissions on a monthly basis (retain
records for 5 years).
On the first day of every month, ensure
that the machine contains only clean
solvent.
Return the solvent each month to the fill
line established during the first month the
measurements were made.
Determine solvent emissions the first
operating day of each month.
Maintain records on the method used to
determine cleaning capacity (retain for
5 years).
Measurement,
Calculation, or
Observation
Monthly
emissions:
Emission limit
determined by:
Monthly
emissions:
In Compliance?
Yes
No
12Exceedance has occurred if this the 3-month rolling average emission limit has not been met
(§63.464(c)).
kam\K:\7397\79\03\SOLV-CLN.ALL
B2-17
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8. GENERAL TESTING AND RECORD KEEPING REQUIREMENTS
A. Potential to Emit
Determine the potential to emit from all solvent cleaning operations at the
facility (§63.465(e)).
Potential to emit (kg/yr)
{PTEj = (annual hours of operation), x (working mode emission rate, kg/m2-hr)i x (SAI,
m2)j; SAI = 2.20 x (Vol, m3)06 for machines with no solvent-air interface; SAI = solvent-
air interface area, Vol = cleaning capacity}
Permit limit (kg/yr) (if applicable)
B. Records Retained For Lifetime of Machine
Are the following maintained by the owner/operator?:
• Owner's manual or written maintenance and operating procedures for
the solvent cleaning machine and control equipment (§63.467(a)(l)):
Yes n No D Comment:
• The date of installation for the solvent cleaning machine and all control
devices. (If exact date is unknown, a letter certifying that the machine
and controls were installed prior to, on, or after 11/29/93 can be
substituted) (§63.467(a)(2)):
Yes a No n Comment:
• Halogenated HAP solvent content for each listed solvent used in the
machine (§63.467(a)(5)):
Yes n No n Comment:
C. Records Retained For 5 Years
Does the owner/operators using control combination or idling emission limit, maintain
estimates of annual solvent consumption for the machine (§63.467(b)(3)):
Yes n No D Comment:
R9 1 8
kam\K:Y7397\79\03\SOLV-CLN.ALL °^~ L °
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9.
REPORTING REQUIREMENTS
FOE:
New machines
New machines
Existing machines
Existing machines
Complying with:
Control combination or idling emission limit
Overall emission limit (i.e., alternative standard)
Control combination or idling emission limit
Overall emission limit (i.e., alternative standard)
Complete:
(A) and (C)
(A) and (D)
(B) and (C)
(B) and (D)
A. Initial Notification Requirements for New Machines:
Notification Type/
Citation
Initial Notification
§63.468(b)
Initial Notification
§63.468(b)
New Machine
Reporting
Parameters
If construction or
reconstruction had commenced
but initial startup had not
occurred before 12/2/94, an
initial notification report was
submitted before startup, but
no later than 1/31/95.
If construction or
reconstruction began or will
begin after 12/2/94, an initial
notification report has been
submitted as soon as possible
before starting construction or
reconstruction of the machine.
Observation/
Date
Construction:
Startup:
Notification:
Construction:
Startup:
Notification:
In
Compliance?
Yes
No
Does the initial notification report for the new machine comprise the following
(§63.468(b)(l)-(3)):
• Description of machine, including type, solvent-air interface
area and existing controls: Yes n No D
• Anticipated compliance approach: Yes n No n
• Estimate of annual halogenated solvent consumption for
each cleaning machine: Yes n No D
kam\KA7397\79\03\SOLV-CLN.ALL
B2-19
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B. Initial Notification Requirements for Existing Machines:
Initial notification for existing machines are based on a fixed date. Complete the table below by
checking either "Yes" or "No" to document compliance.
Notification Type/
Citation
Initial Notification
§63.468(a)
Existing Machine
Reporting
Parameter
An initial notification report
was submitted no later than
8/29/95.
Observation/
Date
Notification:
In
Compliance?
Yes
No
Did the initial notification report for existing sources comprise the following (§63.468(a)(l)-
(6)):
Owner/operator name and address:
Address (i.e., physical location of machine):
Description of machine, including type, solvent-air
interface area and existing controls:
Installation date of the machine or letter certifying
installation before or after 11/29/93:
Anticipated compliance approach:
Estimate of annual halogenated solvent consumption:
Yes n
Yes n
No
No
n
a
Yes n No n
Yes D
Yes n
Yes n
No
No
No
n
D
D
C. Reporting Requirements with Control Combinations and Idling Emission Limit
Notification Type/
Citation
Initial Statement of
Compliance (New)
§63.468(d)
Initial Statement of
Compliance
(Existing)
§63.468(d)
Annual Report
§63.468(f)
Exceedance Report
§63.468(h)
Control and Idling Emission
Reporting Parameter
For new sources, an initial statement of
compliance has been submitted no later
than 150 days after startup or 5/1/95,
whichever is later.
For existing sources, an initial
statement of compliance has been
submitted no later than May 1, 1998
(150 days after 12/2/97).
An annual report must be submitted by
February 1 of the year following the one
for which the report is being made.
An exceedance report must be
submitted semiannually unless it is
determined that more frequent reporting
is necessary to accurately assess
compliance status.
Observation/
Date
Notification:
Notification:
Reporting
frequency:
In Compliance?
Yes
No
kam\KA7397\79\03\SOLV-CLN.ALL
B2-20
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Does the initial statement of compliance comprise the following (§63.468(d)(l)-(7)):
• Owner/operator name and address: Yes n No n
• Address (i.e..physical location) of the machine: Yes n No D
• List of parameters monitored for each control and the values
measured on or during the first month after the compliance
date: Yes D No a
• List of control equipment used to achieve compliance: Yes D No n
• Conditions to maintain wind speed requirements, if applicable: Yes a No n
• A test report on tests of idling emissions meeting the
specifications in Reference Method 307 and complying
with the requirements of §63.468(d)(6)(i) through
§63.468(d)(6)(iv), if applicable: Yes n No a
• Date and results of the weekly measurement of the
halogenated HAP solvent concentration in the carbon
adsorber exhaust, if applicable: Yes n No n
Do the annual reports comprise the following (§63.468(f)(l)-(2)):
• A signed statement from the facility owner or the owner's
designee stating that, "All operators of solvent cleaning machines
have received training on the proper operation of solvent
cleaning machines and their control devices sufficient to pass
the test required in §63.643(d)(10).": Yes D No n
• An estimate of solvent consumption for each solvent
cleaning machine during the reporting period: Yes n No n
Do the exceedance reports comprise the following (§63.468(h)(l)-(3)):
• Records of written or verbal orders for replacement parts, a
description of repairs to be made, and additional monitoring
conducted to demonstrate that monitored values have
returned to accepted levels: Yes n No a
• If an exceedance has occurred, the reason for the
exceedance and a description of the actions taken: Yes n No D
• If no exceedance of a parameter has occurred, or a piece
of equipment has not been inoperative, out of control,
repaired or adjusted, a statement to this effect: Yes D No n
R9 91
kam\KA7397\79\03\SOLV-CLN.ALL DZ.-Z, 1
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D. Reporting Requirements with Overall Emission Limit (i.e., Alternative Standard)
Notification Type/
Citation
Initial Statement of
Compliance
§63.468(e)
Initial Statement of
Compliance
§63.468(e)
Solvent Emission
Report
§63.468(g)
Exceedance Report
§63.468(h)
Overall Emission Limit
Reporting
Parameter
For new sources, an initial
statement of compliance has
been submitted no later than
150 days after startup or
5/1/95, whichever is later.
For existing sources, an initial
statement of compliance has
been submitted no later than
May 1, 1998 (150 days after
12/2/97).
A solvent emission report must
be submitted every year.
An exceedance report must be
submitted semiannually unless
it is determined that more
frequent reporting is necessary
to accurately assess compliance
status.
Observation/
Date
Notification:
Notification:
Annual report:
Reporting frequency:
In
Compliance?
Yes
No
Does the initial statement of compliance comprise the following( §63.468(e)(l)-(4)):
• Owner/operator name and address: Yes n No Q
• Address (i.e., physical location) of the machine: Yes d No n
• Solvent-air interface area, or for machines without solvent-
air interface, a description of the method used to determine
cleaning capacity: Yes n No n
• Results of the first 3-month average emission calculations: Yes n No n
Do the solvent emission reports comprise the following (§63.468(g)(l)-(3)):
• Type and size of each unit subject to this NESHAP: Yes n No n
• Average monthly solvent consumption in kilograms/month: Yes n No n
• The 3-month rolling average solvent emission estimates
calculated each month: Yes D No n
[Note: Reporting requirements under §63.468(f) and (g) can be combined into one report.]
kam\K:V7397Y79\03\SOLV-CLN.ALL
B2-22
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Do the exceedance reports comprise the following (§63.468(h)(l)-(3)):
• Records of written or verbal orders for replacement parts, a
description of repairs to be made, and additional monitoring
conducted to demonstrate that monitored values have
returned to accepted levels: Yes n No n
• If an exceedance has occurred, the reason for the
exceedance and a description of the actions taken: Yes n No Q
• If no exceedance of a parameter has occurred, or a piece
of equipment has not been inoperative, out of control,
repaired or adjusted, a statement to this effect: Yes n No n
9. INSPECTOR COMMENTS:
END OF FORM
kam\K:\7397\79\03\SOLV-CLN.ALL
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B3. Batch Cold-Cleaning Machines Checklist
kam\K:\7397Y79\03\SOLV-CLN ALL
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COMPLIANCE CHECKLIST FOR
BATCH COLD-CLEANING MACHINES
Halogenated Solvent Cleaning NESHAP
1. GENERAL INFORMATION:
A. Cleaning machine ID No.
B. Machine is: New n Existing n
C. Machine type is: Immersion n Remote Reservoir D
(go to Section 2.A) (go to Section 2.B)
2. COMPLIANCE REQUIREMENTS BASED ON MACHINE TYPE:
A. Immersion Machine:
The machine employs a tightly fitting cover that is closed at all times except
during parts entry and removal, and a water layer at a thickness of 2.5 cm (1 in.)
on the surface of the solvent within the cleaning machine. [§63.462(a)(l)]
Incompliance?: Yes n No n Not Applicable D
[Note: If the owner/operator has chosen and is in compliance with this option,
complete Section 4 (for new machines) or 5 (for existing machines) only.]
QR
The machine employs a tightly fitting cover that is closed at all times except
during parts entry and removal, and a freeboard ratio of 0.75 of greater.
[§63.462(a)(2)]
Incompliance?: Yes D No D Not Applicable D
[Note: If the owner/operator has chosen and is in compliance with this option,
complete Section 3 and either Section 4 (for new machines) or 5 (for existing
machines).]
Rl 1
Kam\K:Y7397\79\03\SOLV-CLN.ALL OJ-1
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B. Remote Reservoir Machine:
The machine employs a tightly fitting cover over the solvent sump that is closed
at all times except during the cleaning of parts. [§63.462(b)J
Incompliance?: Yes n
No
[Complete Section 3 and either Section 4 (for new machines) or 5 (for existing
machines) .]
3.
WORK AND OPERATIONAL PRACTICE REQUIREMENTS:
Citation
§63.462(c)(l)
§63.462(c)(2)
§63.462(c)(3)
§63.462(c)(4)
§63.462(c)(5)
§63.462(c)(6)
Work/Operational Practice
All waste solvent is collected and
stored in closed containers.
Flushing is only performed in the
freeboard area.
Parts are drained for 1 5 seconds or
until dripping has stopped, whichever
is longer, and parts with cavities or
blind holes are tipped or rotated while
draining.
The solvent level does not exceed the
fill line.
Spills of solvent during transfer are
wiped up immediately, and the wipe
rags are stored in a covered container.
When an air- or pump-agitated solvent
bath is used, the agitator produces a
rolling motion of the solvent but not
observable splashing against tank
walls or parts being cleaned
Measurement,
Calculation, or
Observation
In
Compliance?
Yes
No
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B3-2
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3. WORK AND OPERATIONAL PRACTICE REQUIREMENTS (Continued):
Citation
§63.462(c)(7)
§63.462(c)(8)
Work/Operational Practice
When the cover is opened, the
machine is not exposed to drafts
greater than 40 m/min (132 ft/min), as
measured between 1-2 m (3.3-6.6 ft)
upwind and at the same elevation as
the tank lip.
Sponges, fabric, wood, and paper
products are not cleaned in the
machine.
Measurement,
Calculation, or
Observation
Wind speed:
In
Compliance?
Yes
No
4. REPORTING REQUIREMENTS FOR NEW MACHINES:
Initial Notification Report
If construction or reconstruction had commenced but initial startup had not occurred
before 12/2/94, an initial notification report was submitted before startup, but no later
than 1/31/95. [§63.468(b)]
In compliance?: Yes n No n Not Applicable n
QR
If construction or reconstruction began or will begin after 12/2/94, an initial notification
report has been submitted as soon as possible before starting construction or
reconstruction of the machine. [§63.468(b)]
Incompliance?: Yes n No n Not Applicable a
Kam\K:\7397Y79\03\SOLV-CLN.ALL
B3-3
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The initial notification report comprises the following:
Citation
§63.468(b)(l)
§63.468(b)(2)
§63.468(b)(3)
Initial Notification Report Component
Description of machine, including type and existing
controls.
Anticipated compliance approach.
Estimate of annual halogenated solvent consumption.
In Compliance?
Yes
No
Compliance Report
A compliance report has been submitted no later than 5/1/98, whichever is later.
[§63.468(c)]
In compliance?: Yes D No n
The compliance report comprises:
Citation
§63.468(c)(l)
§63.468(c)(2)
§63.468(c)(3)
§63.468(c)(4)
Compliance Report Component
Owner/operator name and address.
Address (i.e., physical location) of the machine.
A statement signed by the owner/operator stating that
the machine is in compliance with this NESHAP.
Compliance Approach.
In Compliance?
Yes
No
5. REPORTING REQUIREMENTS FOR EXISTING MACHINES:
Initial Notification Report
An initial notification report was submitted no later than 8/29/95. [§63.468(a)]
Incompliance?: Yes n No n
Kam\K:\7397Y79\03\SOLV-CLN.ALL
B3-4
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The initial notification report comprises the following:
Citation
§63.468(a)(l)
§63.468(a)(2)
§63.468(a)(3)
§63.468(a)(4)
§63.468(a)(5)
§63.468(a)(6)
Initial Notification Report Component
Owner/operator name and address.
Address (i.e., physical location of machine).
Description of machine, including type and existing
controls.
Installation date of the machine or letter certifying
installation before or after 1 1/29/93.
Anticipated compliance approach.
Estimate of annual halogenated solvent consumption.
In Compliance?
Yes
No
Compliance Report
A compliance report has been submitted no later than 5/1/98.
Incompliance?: Yes n No n
The compliance report comprises:
Citation
§63.468(c)(l)
§63.468(c)(2)
§63.468(c)(3)
§63.468(c)(4)
Compliance Report Component
Owner/operator name and address.
Address (i.e., physical location) of the machine.
A statement signed by the owner/operator stating that
the machine is in compliance with this NESHAP.
Compliance approach.
In Compliance?
Yes
No
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B3-5
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Appendix C
Conversion Chart
Kam\K:\7397Y79\03\SOLV-CLN.ALL
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Appendix C
Conversion Chart
Multiply
Centimeters
Cubic centimeters
Cubic centimeters
Cubic centimeters
Cubic feet
Cubic inches
Cubic inches
Cubic meters
Cubic meters
Cubic meters
Cubic yards
Cubic yards
Cubic yards
Feet per minute
Feet per minute
Gallons
Kilograms
Kilograms
Kilograms per cubic meter
Kilograms per cubic meter
Meters
Meters
Meters
Meters per minute
Meters per minute
Meters per minute
By
0.3937
3.531 x IO-5
6.10 xlO-2
io-6
0.02832
5.787 xlO-4
16.39
IO6
35.31
61,023
7.646 x IO5
27
0.7646
0.01829
0.3048
0.1337
2.2046
1.102xlO-3
0.06243
3.61 xlO-5
100
3.2808
39.37
1.667
3.281
0.05468
To Obtain
Inches
Cubic feet
Cubic inches
Cubic meters
Cubic meters
Cubic feet
Cubic centimeters
Cubic centimeters
Cubic feet
Cubic inches
Cubic centimeters
Cubic feet
Cubic meters
Kilometers per hour
Meters per minute
Cubic feet
Pounds
Tons (short)
Pounds per cubic foot
Pounds per cubic inch
Centimeters
Feet
Inches
Centimeters per second
Feet per minute
Feet per second
K.am\K.\7397Y79\(mSOLV-CLN.ALL
C-l
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Appendix C
Conversion Chart (Continued)
Multiply
Meters per second
Meters per second
Pounds
Pounds
Pounds
Pounds per cubic foot
Pounds per cubic foot
Pounds per cubic foot
Pounds per cubic foot
Pounds per foot
Pounds per inch
Pounds per square foot
Pounds per square foot
Pounds per square inch
Pounds per square inch
Square feet
Square feet
Square inches
Square inches
Square meters
Square yards
Yards
Yards
Yards
Yards
By
1968
3.284
453.6
16
0.4536
0.01602
16.02
5.787 x 10-4
1728
1.488
178.6
4.882
6.944 x lO'3
703.1
144
144
0.09290
6.452
6.944 x 10°
10.764
0.8361
91.44
3
36
0.9144
To Obtain
Feet per minute
Feet per second
Grams
Ounces
Kilograms
Grams per cubic centimeter
Kilograms per cubic meter
Pounds per cubic foot
Pounds per cubic foot
Kilograms per meter
Grams per centimeter
Kilograms per square meter
Pounds per square inch
Kilograms per square
Pounds per square foot
Square inches
Square meters
Square centimeters
Square feet
Square feet
Square meters
Centimeters
Feet
Inches
Meters
Kam\K:\7397Y79\03\SOLV-CLN.ALL
C-2
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APPENDIX D
Emission Limits For Machines Without a Solvent-Air Interface
Kam\K:\7397\79\03\SOLV-CLN.ALL
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Emission Limits for Cleaning Machines Without a Solvent-air Interface
Cleaning
capacity
(cubic
meters")
0.00
0.05
0.10
0.15
0.20
0.25
0.30
0.35
0.40
0.45
0.50
0.55
0.60
0.65
0.70
0.75
0.80
0.85
2.70
2.75
2.80
2.85
2.90
2.95
3.00
3-Month rolling
average
monthly
emission limit
(kilograms/
monthb)
0
55
83
106
126
144
160
176
190
204
218
231
243
255
266
278
289
299
599
605
612
619
625
632
638
Cleaning
capacity
(cubic
meters")
0.90
0.95
1.00
1.05
1.10
1.15
1.20
1.25
1.30
1.35
1.40
1.45
1.50
1.55
1.60
1.65
1.70
1.75
3.60
3.65
3.70
3.75
3.80
3.85
3.90
3-Month
rolling
average
monthly
emission limit
(kilograms/
month")
310
320
330
340
349
359
368
377
386
395
404
412
421
429
438
446
454
462
712
718
723
729
735
741
747
Cleaning
capacity
(cubic
meters")
1.80
1.85
1.90
1.95
2.00
2.05
2.10
2.15
2.20
2.25
2.30
2.35
2.40
2.45
2.50
2.55
2.60
2.65
4.50
4.55
4.60
4.65
4.70
4.75
4.80
3-Month rolling
average
monthly
emission limit
(kilograms/
month")
470
477
485
493
500
508
515
522
530
537
544
551
558
565
572
579
585
592
814
819
824
830
835
840
846
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D-l
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Emission Limits for Cleaning Machines Without a Solvent-air Interface (Continued)
Cleaning
capacity
(cubic
meters')
3.05
3.10
3.15
3.20
3.25
3.30
3.35
3.40
3.45
3.50
3.55
5.40
5.45
5.50
5.55
5.60
5.65
5.70
5.75
5.80
5.85
5.90
5.95
6.00
6.05
3-Month rolling
average
monthly
emission limit
(kilograms/
month1*)
644
651
657
663
669
675
682
688
694
700
706
908
913
918
923
928
933
938
943
947
952
957
962
967
972
Cleaning
capacity
(cubic
meters')
3.95
4.00
4.05
4.10
4.15
4.20
4.25
4.30
4.35
4.40
4.45
6.30
6.35
6.40
6.45
6.50
6.55
6.60
6.65
6.70
6.75
6.80
6.85
6.90
6.95
3-Month
rolling
average
monthly
emission limit
(kilograms/
month1*)
752
758
764
769
775
781
786
792
797
803
808
996
1000
1005
1010
1015
1019
1024
1029
1033
1038
1042
1047
1052
1056
Cleaning
capacity
(cubic
meters')
4.85
4.90
4.95
5.00
5.05
5.10
5.15
5.20
5.25
5.30
5.35
7.20
7.25
7.30
7.35
7.40
7.45
7.50
7.55
7.60
7.65
7.70
7.75
7.80
7.85
3-Month rolling
average
monthly
emission limit
(kilograms/
monthb)
851
856
862
867
872
877
882
887
893
898
903
1079
1083
1088
1092
1097
1101
1105
1110
1114
1119
1123
1127
1132
1136
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D-2
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Emission Limits for Cleaning Machines Without a Solvent-air Interface (Continued)
Cleaning
capacity
(cubic
meters")
6.10
6.15
6.20
6.25
8.10
8.15
8.20
8.25
8.30
8.35
8.40
8.45
8.50
8.55
8.60
8.65
8.70
8.75
8.80
8.85
8.90
8.95
10.80
10.85
10.90
3-Month rolling
average
monthly
emission limit
(kilograms/
month1*)
977
981
986
991
1158
1162
1166
1171
1175
1179
1183
1187
1192
1196
1200
1204
1208
1213
1217
1221
1225
1229
1376
1380
1383
Cleaning
capacity
(cubic
meters')
7.00
7.05
7.10
7.15
9.00
9.05
9.10
9.15
9.20
9.25
9.30
9.35
9.40
9.45
9.50
9.55
9.60
9.65
9.70
9.75
9.80
9.85
11.20
11.25
11.30
3-Month
rolling
average
monthly
emission limit
(kilograms/
monthb)
1061
1065
1070
1074
1233
1237
1241
1246
1250
1254
1258
1262
1266
1270
1274
1278
1282
1286
1290
1294
1298
1302
1406
1410
1414
Cleaning
capacity
(cubic
meters")
7.90
7.95
8.00
8.05
9.90
9.95
10.00
10.05
10.10
10.15
10.20
10.25
10.30
10.35
10.40
10.45
10.50
10.55
10.60
10.65
10.70
10.75
11.60
11.65
11 70
3-Month rolling
average
monthly
emission limit
(kilograms/
month")
1140
1145
1149
1153
1306
1310
1314
1318
1322
1326
1329
1333
1337
1341
1345
1349
1353
1357
1360
1364
1368
1372
1436
1440
1444
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D-3
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Emission Limits for Cleaning Machines Without a Solvent-air Interface (Continued)
Cleaning
capacity
(cubic
meters')
10.95
11.00
11.05
11.10
11.15
3-Month rolling
average
monthly
emission limit
(kilograms/
month")
1387
1391
1395
1399
1402
Cleaning
capacity
(cubic
meters")
11.35
11.40
11.45
11.50
11.55
3-Month
rolling
average
monthly
emission limit
(kilograms/
month")
1417
1421
1425
1429
1432
Cleaning
capacity
(cubic
meters')
11.75
11.80
11.85
11.90
11.95
3-Month rolling
average
monthly
emission limit
(kilograms/
month")
1447
1451
1455
1458
1562
a Divide cubic feet by 35.31 to obtain the cleaning capacity in cubic meters.
b Multiply kilograms/month by 2.2046 to obtain the 3-month rolling average monthly emission
limit in pounds/month.
Note: If the cleaning capacity for your machine falls between those presented above, the limit
for your machine is the lower emissions limit.
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