EPA-340/1-79-008
      INSPECTION SOURCE TEST MANUAL

                    FOR

          SOLVENT METAL CLEANING

                (DEGREASERS)
         EPA CONTRACT 68-01-4146

              TASK ORDER 42
  U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
           401 M Street, S.W.
         Washington, D.C.  20460

     EPA Project Officer:  John R. Busik
     EPA Task Manager:     Robert C. Marshall
                June 1979

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This report was prepared for the U.S. Environmental Protection Agency
by Engineering-Science of Durham, North Carolina in partial fulfillment
of Contract No. 68-01-4146.  The contents of this report are reproduced
herein as received from the contractor.  The opinions, findings and
conclusions expressed are those of the author and not necessarily those
of the U.S. Environmental Protection Agency.
                                   ii

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                             ACKNOWLEDGEMENTS

     This report was prepared under the direction of Roger D. Allen,
Manager of Air Quality, Engineering-Science.  The principal investigators
were Mr. Allen, John T. Chehaske, Terranee A. Li Puma and Joseph Van Gieson.
     Task Manager for the U.S. Environmental Protection Agency was
Mr. Robert C. Marshall.  The authors appreciate the contributions made to
this study by Mr. Marshall and other members of the Office of Enforcement,
Division of Stationary Source Enforcement including Mr. Howard Wright,
Mr. Mark Antell, and Mr. Robert L. King.  The authors also appreciate the
assistance provided by the staff of the Office of Air Quality Planning and
Standards, Emission Standards and Engineering Division, especially
Mr. Jeffrey L. Shumaker and Mr. K. W. Grimley.
     We also wish to acknowledge the invaluable assistance by the following
organizations in taking the time to lend their expertise to the content of
this report:
                        Barren - Blakslee, Inc.
                        Chicago, Illinois
                        Delta Industries
                        Santa Fe Springs, California
                        Detrex Corp.
                        Detroit, Michigan
                        Graymills Corp.
                        Chicago, Illinois
                        Kleer-Flo Company
                        Eden Prairie, Minnesota
                        Naval Facilities Engineering Command
                        Atlantic Division
                        Norfolk, Virginia
                        Safety-Kleen
                        New Berlin, Wisconsin
                                iii

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         CONVERSION FACTORS

1 KPa        =   7.5 mm Hg (at 100°F) =7.5 Torr
             -   0.15 psi (at 100°F)
                 1.03 bars
1m3         =   3.785 x 10~3 gallons
                 1.337 x lO"1 ft3
1m          =   3.281 ft
1 cm         =   3.937 x 10'1 in
1 in Hg      =  13.60 in H20
1 liter      =   2.642 x 1Q-1 gallons
1 ml         =   2.642 x 10~^ gallons
1 yl         =  10~6 liter
1 rag         =  10~° gram
°K               °C + 273
                iv

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               LIST OF ABBREVIATIONS
ASTM - American Society for Testing and Materials
Btu  - British thermal unit
cfm  - Cubic feet per minute
cm   - Centimeters
°C   - Degrees centigrade
CTG  - Control Technology Guideline
dm   - decimeter
EPA  - Environmental Protection Agency
Ft   - Feet
°F   - Degrees farenheit
gal  - Gallons
GC   - Gas chromatography
Hg   - Mercury
in   - Inches
kPa  - Kilograms per square centimeter (absolute pressure)
m    - Meter
min  - Minutes
mm   - Millimeter
OSHA - Occupational Safety and Health Administration
ppm  - Parts per million by volume
psi  - Pounds per square inch
RACT - Reasonably available control technology
SIP  - State Implementation Plan
TLV  - Threshold limit value in ppm
VOC  - Volatile organic compound

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                               TABLE OF CONTENTS


Chapter                                                                      Page

  1         INTRODUCTION	      1.1-1
            1.1  Scope and Objective of Manual	      1.1-1
            1.2  EPA's Policy on RACT Regulations  for Degreasers	      1.2-1
                 1.2.1  Application of Control Systems A and  B	      1.2-1
                 1.2.2  EPA's Policy on Exemptions 	      1.2-1
            1.3  Degreasing Solvents 	      1.3-1
            1.4  Inspection Equipment	      1.4-1
            1.5  Safety Considerations 	      1.5-1

  2         COLD CLEANERS	      2.1-1
            2.1  Process Description	      2.1-1
                 2.1.1  Unit Operation	      2.1-1
                 2.1.2  Types of Cold Cleaner Degreasers	      2.1-1
                 2.1.3  Operation of Degreaser Components	      2.1-2
            2.2  Atmospheric Emissions	      2.2-1
                 2.2.1  Emission Points	      2.2-1
                 2.2.2  Parameters Affecting Rate  of  VOC Emissions	      2.2-1
            2.3  Emission Control Methods	      2.3-1
                 2.3.1  Other Controls	      2.3-3
            2.4  Inspection Procedures	      2.4-1
                 2.4.1  Field Inspections	      2.4-1
                 2.4.2  Record Review	      2.4-4
                        2.4.2.1  Review of Design, Operation, and
                                   Maintenance Data	      2.4-6
                        2.4.2.2  Review Waste Solvent Disposal  Procedures    2.4-8

  3         OPEN TOP VAPOR DEGREASERS	      3.1-1
            3.1  Process Description	      3.1-1
                 3.1.1  Unit Operation	      3.1-1
                 3.1.2  Types of Open Top Vapor Degreasers	      3.1-1
                 3.1.3  Operation of Degreaser Components	      3.1-10
            3.2  Atmospheric Emissions	      3.2-1
                 3.2.1  Emission Points	      3.2-1
                 3.2.2  Parameters Affecting Rate  of  VOC Emissions	      3.2-3
            3.3  Emission Control Methods	      3.3-1
            3.4  Inspection Procedures	      3.4-1
                 3.4.1  Field Inspections	      3.4-1
                 3.4.2  Record Review	      3.4-6
                        3.4.2.1  Review of Design, Operation, and
                                   Maintenance Data	      3.4-6
                        3.4.2.2  Review Waste Solvent Disposal  Procedures    3.4-8

  4         CONVEYORIZED DEGREASERS	      4.1-1
            4.1  Process Description	      4.1-1
                 4.1.1  Unit Operation	      4.1-1
                 4.1.2  Types of Conveyorized Degreasers	      4.1-1
                 4.1.3  Operation of Degreaser Components	      4.1-6
                                      vi

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                            TABLE OF CONTENTS  (cont)


Chapter                                                                     Page

            4.2  Atmospheric Emissions ----------------------------------      4.2-1
                 4.2.1  Emission Points ---------------------------------      4.2-1
                 4.2.2  Parameters Affecting Rate of VOC Emissions ------      4.2-2
            4.3  Emission Control Methods ------------------------------      4.3-1
                 4.3.1  RACT Controls ----------------------------------      4.3-1
                 4.3.2  Other Controls- ---------------------------------      4.3-3
            4.4  Inspection Procedures ----------------------------------      4.4-1
                 4.4.1  Field Inspections -------------------------------      4.4-1
                 4.4.2  Record Review -----------------------------------      4.4-8
                        4.4.2.1  Review of Design, Operation, and
                                   Maintenance Data ---------------------      4.4-8
                        4.4.2.2  Review Waste Solvent Disposal Procedures     4.4-10

  5         EMISSION TESTING OF CARBON ADSORPTION SYSTEMS ---------------      5.1-1
            5 . 1  Introduction -------------------------------------------      5.1-1
            5.2  Source Testing Screening Method ------------------------      5.2-1
                 5.2.1  Applicability -----------------------------------      5.2-1
                 5.2.2  Principle ---------------------------------------      5.2-1
                 5.2.3  Range and Sensitivity ---------------------------      5.2-2
                 5.2.4  Calibration Apparatus ---------------- • -----------      5.2-2
                        5.2.4.1  Calibration Apparatus for Use With
                                   Commercially Prepared Calibration
                                     Gas Mixtures ----------------------      5.2-2
                        5.2.4.2  Calibration Apparatus for Use With
                                   Standard Gas Mixtures Prepared from
                                     Pure Solvent Liquid ---------------      5.2-3
                 5.2.5  Sampling and Analysis Apparatus -----------------      5.2-4
                 5.2.6  Laboratory Calibration Procedures ---------------      5.2-4
                        5.2.6.1  Preparation of Standard Gas Mixture ----      5.2-4
                        5.2.6.2  Determination of Analyzer Calibration
                 5.2.7  Sampling Procedures ----------------------------      5.2-14
            5.3  Draft Source Testing Compliance Verification Method ----      5.3-1
                 5.3.1  Principle and Applicability ---------------------      5.3-2
                        5.3.1.1  Principle -----------------------------      5.3-2
                        5.3.1.2  Applicability -------------------------      5.3-2
                 5.3.2  Range and Sensitivity ---------------------------      5.3-2
                 5.3.3  Interferences ---------------------------------      5.3-2
                 5.3.4  Apparatus ---------------------------------------      5 . 3-2
                        5.3.4.1  Sampling ------------------------------      5.3-2
                        5.3.4.2  Sample Recovery ------------------------      5.3-5
                        5.3.4.3  Analysis -------------------------------      5.3-5
                        5.3.4.4  Calibration ----------------------------      5.3-6
                 J • j • 5  ^gQgQ0tS"~""—™""~""™'""""~"""~*~""p~~~~— "~~"""~™"— ™"~"""~~"™"""~™"~">"""""™"      3 * J~ /
                        5.3.5.1  Analysis ------------------------------      5.3-7
                        5.3.5.2  Calibration ----------------------------      5.3-7
                 5.3.6  Procedure --------------------------------------      5.3-9
                        5.3.6.1  Sampling ------------------------------      5 . 3-9
                        5.3.6.2  Sample Storage -------------------------      5.3-9
                        5.3.6.3  Sample Recovery ------------------------      5.3-9
                        5.3.6.4  Analysis -------------------------------      5.3-10
                        5.3.6.5  Determine Ambient Conditions ----------      5.3-10
                                       vii

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                           TABLE OF CONTENTS  (cont)

Chapter

                 5.3.7  Standards,  Calibration,  and Quality Assurance	      5.3-10
                        5.3.7.1  Standards	      5.3-10
                        5.3.7.2  Calibration	      5.3-11
                        5.3.7.3  Quality Assurance	      5.3-14
                 5.3.8  Calculations	      5.3-15
                        5.3.8.1  Optional Standards Concentrations	      5.3-15
                        5.3.8.2  Sample Concentrations	      5.3-15
                 5.3.9  References	      5.3-16
            5.4  Material Balance	      5.4-1
APPENDIX A. LIST OF REFERENCES
APPENDIX B  CTG GUIDELINES
APPENDIX C  SUPPLEMENT A:  DETERMINATION OF ADEQUATE
                           CHROMATOGRAPHIC PEAK RESOLUTION

            SUPPLEMENT B:  PROCEDURE FOR FIELD AUDITING
                           GC ANALYSIS
                                      viii

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                           LIST OF ILLUSTRATIONS

Figure                           Title                                       Page

1-1         Solvent Vapor Pressure vs Temperature	    1.3-4
1-2         Vapor Pressure vs Temperature for Chlorinated Solvents	    1.3-5

2-1         Cold Cleaner	    2.1-3
2-2         Spray Sink	    2.1-4
2-3         Cold Cleaner Emission Points	     2.2-3
2-4         Example Worksheet for Field Inspection of Cold Cleaners	     2.4-2
2-5         Maintenance Cold Cleaner	     2.4-5
2-6         Drainage Rack	     2.4-5
2-7         Example Questionnaire for Office Review of Cold Cleaning
                 Degreasers	     2.4-7

3-1         Single Compartment Vapor Degreaser	     3.1-3
3-2         Liquid-Vapor Degreaser	     3.1-4
3-3         Liquid-Liquid-Vapor Degreaser 2 Compartment	     3.1-5
3-4         Liquid-Liquid-Vapor Degreaser 3 Compartment	     3.1-5
3-5         Offset Condenser Vapor-Spray-Vapor Degreaser	     3.1-6
3-6         Degreaser with Lip Exhaust	•	     3.1-6
3-7         Perimeter Condensing Vapor-Spray-Vapor Degreaser	     3.1-7
3-8         Liquid-Liquid-Vapor Degreaser 2 Compartment	     3.1-8
3-9         Liquid-Liquid-Vapor Degreaser 3 Compartment with Dip	     3.1-9
3-10        Open Top Degreaser Emission Points	     3.2-2
3-11        Refrigerated Freeboard Chiller	     3.3-4
3-12        Example Worksheet for Field Inspection of Open Top Vapor
                 Degreasers	     3.4-2
3-13        U.S. Environmental Protection Agency Open Top Va'por Degreaser
                 Summary	     3.4-7
4-la        Gyro Degreaser	     4.1-2
4-lb        Vibra Degreaser	     4.1-2
4-2         Monorail Degreaser	     4.1-3
4-3         Cross-Rod Degreaser	     4.1-4
4-4         Mesh Belt Conveyorized Degreaser	     4.1-5
4-5         Liquid-Liquid-Vapor Cross-Rod Degreaser	     4.1-7
4-6         Typical Emission Points	•	'	     4.1-9
4-7         Example Worksheet for Field Inspection of Conveyorized
                 Degreasers	     4.4-2
4-8         Cross Rod with Rotating Baskets	     4.4-6
4-9         Cross Rod with Rotating Baskets (sketch)	     4.4-7
4-10        Questionnaire for Conveyorized Degreasers	     4.4-9
5-1         Example Calibration Curve Data Sheet	     5.2-6
5-2         Apparatus for the Preparation of Calibration Gas Mixtures
                 from Liquid Solvent	     5.2-7
5-3         Example Span Gas Preparation Data Sheet	     5.2-9
5-4         Example Calibration Curve	     5.2-13
5-5         Solvent Vapor Field Data Sheet for Screening of Carbon
                 Adsorption Systems on Vapor Degreasers	     5.2-15
5-6         Integrated Bag Sampling Apparatus Assembly	     5.3-3
5-7         Apparatus for the Preparation of Calibration Gas Mixtures from
                 Liquid Solvent	     5.3-12
5-8         Material Balance Data Sheet	—•	     5.4-3
                                      ix

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                                 LIST OF TABLES

Table                                Title                                  Page

1-1         Common Metal Cleaning Solvents	    1.3-2
2-1         Control Systems For Cold Cleaning	    2.3-2
3-1         Complete Control Systems For Open Top  Vapor Degreasers	    3.3-2
5-1         Injection Values For Preparation of  Standards	    5.2-10
5-2         Injection Values For Preparation of  Standards	    5.3-13
                (Optional,  See Section 5.3.7.1.1)
                                       x

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                                 CHAPTER 1
                               INTRODUCTION

1.1  SCOPE AND OBJECTIVE OF MANUAL
     This document was prepared to assist U.S. Environmental Protection
Agency Regional Offices and state/local air quality control agencies in
implementing Reasonably Available Control Technology (RACT)l for volatile
organic compound (VOC) emissions from solvent metal cleaning processes
(more commonly referred to as degreasers) .  Specifically, this manual
provides guidance in performing source inspections and compliance tests.
     There are three basic types of solvent metal cleaning equipment;
manual cold cleaners, open top vapor degreasers, and conveyorized degreasers.
Chapters 2 through 4 discuss these operations, respectively.  Each chapter
contains a description of the process, identification of the emission points
and the parameters that effect emissions, emission control methods, and a
suggested inspection procedure.  For those degreasers equipped with carbon
adsorption control devices, it is necessary to perform emissions tests.
Chapter 5 contains EPA's draft procedure for testing solvent emissions and
also contains suggestions for performing screening tests and material
balances.
     Additional topics in this introductory chapter include EPA's policy
regarding the implementation of RACT, identification of the solvents most
commonly used in degreasers, a listing of field equipment needed for
inspecting degreasers, and a discussion of the safety aspects of inspecting
degreasers.
     Chapters  and  sections  of  this  document have been  arranged  in a format  that
 permits  easy  and  convenient replacement  of material as  information reflecting
 more accurate and refined  inspection and testing procedures are developed.   To
 speed dissemination of  information,  chapters  or sections that  contain  new
 procedures will be issued  separate from  the parent report whenever they are
 revised.  To  facilitate the addition of  future  materials,  the  punched,  loose-
 leaf format was selected.  This  approach permits the  document  to be placed
 in a three-ring binder  or  to  be  secured  by rings, rivets,  or other fasteners;
 future supplements or revisions  can then be easily inserted.
     solvent metal  cleaning operations, RACT is defined  in  the EPA Document
 "Control of Volatile Organic Emissions from Solvent Metal  Cleaning"
 (EPA 450/2-77-022).  This series of publications is also referred to  as
 the  Control Technology Guideline (CTG) documents.
                                    1.1-1

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1.2  EPA's POLICY ON RACT REGULATIONS FOR DEGREASERS
     EPA's guidelines for RACT as applied to degreasers are contained  in
Appendix B to this manual.  Separate guidelines were issued for cold cleaners,
open top vapor degreasers, and conveyorized degreasers.  Each guideline is
divided into two levels of control.  Control System A consists of operating
practices and simple, inexpensive control equipment.  Control System B con-
sists of System A plus additional requirements to improve the effectiveness
of control.
1.2.1  Application of Control Systems A and B
     An approvable State Implementation Plan (SIP) must require the
application of Control System B throughout urban nonattainment areas
(>200,000 population) seeking an extension and to all facilities emitting
VOC's in excess of 100 tons per year in other nonattainment areas.  Facil-
ities emitting 100 tons per year or less of VOC's in other nonattainment
areas must apply Control System A as a minimum.  However, EPA encourages
states to control all degreasers in nonattainment areas to the Control
System B level.
1.2.2  EPA's Policy on Exemptions
     The CTG recommends two exemptions for solvent metal cleaning processes.
First, conveyorized degreasers with an air/vapor interface of less than
2.0 square meters should be exempted from the requirement for a major
control device.  Requirements for controlling these smaller units would
not be cost effective and would tend to move the small conveyorized degreaser
users to open top vapor degreasers which emit more solvent per unit of work.
Second, open top vapor degreasers with an open area of less than 1.0 square
meter of open area should be exempt from the application of refrigerated
chillers and carbon adsorbers since these controls would not be cost effec-
tive.  These two exemptions are the only ones EPA will approve in urban
nonattainment areas.   Blanket exemptions such as a 3 pound per day cutoff
or exemptions for cold cleaners will not be approved.
     In rural nonattainment areas EPA will approve exemptions for sources
emitting less than 100 tons per year of VOC's.   This would allow a blanket
exemption for cold cleaners since a typical cold cleaner emits approximately
0.3 tons per year.   However,  SIP's will not be approved that exempt all
open top vapor degreasers and conveyorized degreasers that individually emit
                                      1.2-1

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less than 100 tons per year in rural nonattainment areas because large scale
users may have over 100 separate degreasing operations at one plant location.
If a State chooses to exempt open top or conveyorized degreasing operations
in rural nonattainment areas, the limitation should be 100 tons or less on
a facility-wide basis based on annual solvent purchase records.  Further,
any exemption which distinguishes between open top vapor degreasers and con-
veyorized degreasers will not be approved because of the potential of switching
between equipment types.  Although conveyorized degreasers are larger emitters,
they emit significantly less solvent than do open top vapor degreasers for an
equivalent workload.  Thus, it would not be advantageous to encourage
degreaser operators to choose open top vapor degreasers in order to avoid
regulations on conveyorized degreasers.
                                       1.2-2

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1.3  DECREASING SOLVENTS
     Degreasing solvents are organic chemicals derived principally from
petroleum.  They commonly include (i) petroleum distillates such as Stoddard,
kerosene, heptane and cyclohexane, (ii) halogenated hydrocarbons such as
methylene chloride, perchloroethylene, 1,1,1-trichloroethane, trichloroethy-
lene and trichlorotrifluoroethane (FC-113), (iv) oxygenated organics such as
acetone, methyl ethyl ketone, isopropyl alcohol and ethers, and (v) aromatics
such as toluene, turpentine and xylene.  Table 1-1 summarizes some of the
important properties of common metal cleaning solvents.
     Selection of a solvent for a particular application depends on the
type of cleaning to be done (cold or vapor), the nature of the grease and
other soil to be removed, and the level of cleanliness required.  The pur-
pose of the solvent is to dissolve oils, grease, waxes, tars, and in some
cases, water.  When these materials have been removed from the work,
insoluble material such as sand, metal chips, buffing abrasives and so
forth are flushed away at the same time.  Consideration must be given to
nonmetallic portions of the work to be cleaned.  For example plastic may
be dissolved or otherwise deteriorated by certain solvents.  Other materials
may not be able to stand the heat necessary to boil high boiling solvents
in vapor degreasers.
     Halogenated hydrocarbons are used universally in vapor degreasers
for two reasons.  A very important consideration in solvent selection is
its flammability especially if the solvent must be heated to create a
vapor zone.  The halogenated hydrocarbons used commonly in vapor degreasers
are nonflammable.  Second, the vapors of halogenated hydrocarbons are
approximately four times more dense than air.  This property enhances the
stability of the solvent vapor zone and thus reduces diffusion and convection
losses.  Petroleum solvents are among the most widely used in cold cleaners,
especially in maintenance cleaners.  If petroleum solvents are not adequate
for a particular cleaning application, the operator may turn to any of the
various alcohols, ketones, aromatics or halogenated hydrocarbons that are
capable of doing the job.
                                   1.3-1

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                                                                              TABLE  1-1
ho
COMMON METAL CLEANING SOLVENTS****
Solvency for
Type of Solvent/ Metal Working

Alcohols


Solvent
Ethanol (95Z)
Isopropanol
Methanol
Aliphatic Hydrocarbons
Heptane



Kerosene
Stoddard
Mineral Spirits 66
Aromatic Hydrocarbons
Benzene***




Chlorinated





Fluorinated


Ke tones


SC 150
Toluene
Turpentine
Xylene
Solvents
Carbon Tetrachloride***
Methylene Chloride
Perchloroethylene
1 , 1, 1-Tr ichloroe thane
Trichloroethylene
Solvents
Trichlorotrifluoro-
ethane (FC-113)

Acetone
Methyl ethyl ketone
Soils
poor
poor
poor
good
good
good
good
good
good
good
good
good

excellent
excellent
excellent
excellent
excellent


good

good
good
TLV
(ppm)
1000*
400*
200*
500*
500
200
200
10*
200
200*
100*
100*

10*
500*
100*
350*
100*


1000*

1000*
200*
Flash
Point
60°F
55°F
58°F
<20°F
149°F
105°F
107°F
10°F
151°F
45°F
91°F
81°F

none
none
none
none
none


none

<0°F
28°F
Evaporation
Rate**
24.7
19
45
26
0.63
2.2
1.5
132
0.48
17
2.9
4.7

111
363
16
103
62.4


439

122
45
Water
Solubility Boiling Point
(Z wt.) (Range)
oo 165-176°F
oo 179-181°F
oo 147-149°F
<0.1 201-207°F
<0.1 354-525°F
<0.1 313-380°F
<0. 1 318-382°F
<0.1 176-177°F
<0.1 370-410°F
<0.1 230-232°F
<0.1 314-327°F
<0.1 281-284°F

<0.1 170-172°F
0.2 104-105. 5°F
<0.1 250-254°F
<0.1 165-194°F
<0.1 188-190°F


<0.1 117°F

oo 132-134°F
27 174-176°F

Pounds
Per Gal.
6.76
6.55
6.60
5.79
6.74
6.38
6.40
7.36
7.42
7.26
7.17
7.23

13.22
10.98
13.47
10.97
12.14


13.16

6.59
6.71

Price
Per Gal.
$ 1.59
$ 1.26
$ 1.11
$ 0.86
$ 0.66
$ 0.62
$ 06.2

$ 1.06
$ 0.90
$ 2.40
$ 0.96

$ 3.70
$ 2.83
$ 3.33
$ 2.78
$ 3.13


$ 7.84

$ 1.45
$ 1.74
                                                                                                                  (ml/dm/min) (Dow Chemical Co., method).
   •Federal Register, June 27, 1974, Vol.  39, No.  125.
  **Evaporation Rate determined by weight  loss of  50 mis in a 125 ml beaker on an analytical balance
 ***Not recommended or sold for metal cleaning (formerly standards in industry).
****prlmary source from The Solvents and Chemicals Companies "Physical Properties of Common Organic Solvents" and Price List
    (July 1, 1975).

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     Evaporative losses in cold cleaners increase as the volatility of
the solvent increases.  In addition, cold cleaning solvents are sometimes
heated or agitated to improve cleaning, further increasing evaporative
losses.  EPA has included more stringent control requirements under Control
System B for the more volatile solvents.  Figures 1-1 and 1-2 provide the
vapor pressures of a number of solvents as a function of temperature.
                                   1.3-3

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                                  FIGURE 1-1
Ul
ee.
CO
oo
            SOLVENT  VAPOR PRESSURE VS. TEMPERATURE
     1000
     900
     800
     700

     600

     500

     400


     300



     200
100
 90
 80
 70

 60
      50
      40
      30
      20
                             1.   Heptane
                             2.   1,1,1-Trichlorotrifluoroethane
                             3.   Acetone
                             4.   Methanol
                             5.   Benzene
                             6.   Methyl Ethyl  Ketone
                             7.   Ethane
                             8.   Isopropyl  Alchohol
                             9.   Toluena
                10
                   20
30
  I 40

38°C
50
60
80
                                 TEMPERATURE  (°C)
                                1.3-4

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                            FIGURE 1-2


VAPOR PRESSURE VS TEMPERATURE FOR  CHLORINATED  SOLVENTS
   E
   oo
   oo
   LU
   o:
   a.


   o:
   o
   D.
IUUU
900
800
700
600
500
400
300
200
100
90
80
70
60
50
40
30
20
1






•

X














/
/
//
^

/









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/
/
2
//
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1. Hethylene Chloride 6. Ethylene Dichloride
2. 1 ,1-Dichloroethane 7. Trichloroethylene
3. Chloroform 8. 1 ,1 ,2-Trichloroethane
4. 1 ,1 ,1-Trichloroethane 9. Perchloroethylene
5. Carbon Tetrachloride 10. Stoddard Solvent*
i i
20 30 40 50 60 70 81
                              38°C

                               TEMPERATURE  (°C)

           *Stoddard is not a chlorinated  solvent
                                1.3-5

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1.4  INSPECTION EQUIPMENT
     The inspector should arrive at the plant with all the necessary per-
sonal safety and testing equipment.  The requisite personal safety equipment
will depend on the nature of the activities at the plant; the inspector
should be prepared with the minimal routine items, that is, a hard hat,
steel-toed shoes and safety glasses.
     Field equipment specific to degreaser inspections should include the
following:
     o  Tape measure for measuring degreaser area and stack dimensions
     o  Thermometer (dial type) for measuring condensor coil water
        temperature
     o  Stop watch for timing operational procedures
     o  Small plastic bottle for collecting sample of condensor coil
        water
     o  Swinging vane velocity meter (velometer)  for measuring exhaust
        stack velocity
     o  Refer to Chapter 5 for a list of stack testing equipment
     A thorough discussion of inspection equipment, general field enforce-
ment activities and inspection techniques may be  found in ""Field Operations
and Enforcement Manual for Air Pollution Control, Volume I:  Organization
and Basic Procedures".  EPA Publication Number APTD-1100 (NTIS Publication
No. PB 213008,  $10.75).
                                    1.4-1

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1.5  SAFETY CONSIDERATIONS
     All of the solvents used in degreasers have toxic characteristics
if inhaled at sufficient concentration levels (see Table 1-1).  It should
never be necessary for the air pollution inspector to enter a drained
degreaser sump.  Several safety precautions are necessary (ventilation,
safety harnesses, respirators, tests for flammability of vapors, etc.)
that are best left to the operators that are properly trained in the safety
requirements.
     Most solvents are flammable, and even those that are not may develop
flammable or even explosive mixtures in the sump,  depending on the nature
of the contaminants.   Do not smoke near a degreaser.
     Transfer of solvent into the degreaser or into waste storage con-
tainers can cause splashing.  The inspector should stand clear of these
operations.
     Heat is another  potential hazard.   Vapor degreaser walls may be hot
enough to burn hands.  Never put hands  below the vapor level inside a vapor
degreaser.  These vapors can exceed 200°F and are extremely powerful solvents.
                                    1.5-1

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                             CHAPTER 2
                           COLD CLEANERS
 2.1     PROCESS DESCRIPTION
 2.1.1   Unit Operation
         Manually operated  cold cleaners provide  solvent  degreasing for low
 volume workloads of  small,  variably shaped  automotive  and  general plant
 maintenance parts, and for fabricated metal products.  The basic  steps
 involved in degreasing with a  cold  cleaner  include  soaking with solvent
 in the dip  tank,  and drying the work of solvent  after  cleaning.
         The solvent  dissolves  the dirt/grease  on the part  to  be cleaned
 as it is immersed.   The part is usually lowered  into the solvent  bath
 in a metal  basket.   The cleaning action is  often enhanced  by  agitation
 of the solvent  and by spraying solvent  on the  part.  After cleaning
 the part is dried by allowing  evaporation and  drainage of  the solvent
 on drying racks which are  located inside the cleaner or  on external racks
 which route the drainage back  into  the  cleaner.
         Many cold cleaners  which are equipped  with  sprayers or  pump agitation
 utilize  filters in the pump piping  system to remove sludge and  dirt thus
 extending the useful life  of the solvent.
 2.1.2    Types of  Cold Cleaner  Degreasers
         Cold cleaners can be generally  classified as maintenance  and manu-
 facturing degreasers.   Maintenance  cold  cleaners are by  far more  common
 and  are  used for  automotive and plant maintenance cleaning.   Maintenance
 cold  cleaners are usually smaller,  simpler  and less expensive than  manu-
 facturing cleaners.   A typical  size  of maintenance cold  cleaners  is
 approximately 0.4 m2  (4 ft2) of opening  and 0.1 m3  (30 gallon)  solvent
 capacity.
         Manufacturing  cold  cleaners  are  employed in applications where  a
 larger volume workload, a higher degree  of cleaning and  larger parts to
 be cleaned dictate the use  of  larger more specialized degreasers.    Manu-
 facturing cold  cleaners are usually  found in metal fabrication facilities.
 The larger size, greater workload and higher solvency needed  to achieve
 the degree of cleaning required of manufacturing cold cleaners result in
more solvent emissions than is usually released by maintenance cold cleaners.
                                     2.1-1

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        The variety of specific applications for cold cleaners offers a
method for more accurately classifying cold cleaners by agitation techni-
que and tank design.
        The two basic designs are the dip tank and the spray sink, although
many cold cleaners employ both cleaning methods.  Dip tank cleaners  (Figure
2-1) allow for more thorough cleaning by providing for soaking dirty parts
in the liquid solvent bath.  The spray sink (Figure 2-2) is simple, inexpen-
sive and used when a relatively low degree of cleanliness is required.  As
can be seen from Figure 2-2, the liquid solvent tank is not accessible
for soaking parts; however, solvent losses due to bath evaporation are
insignificant with this arrangement.
2.1.3   Operation of Degreaser Components
        Agitation of the liquid solvent in dip tanks further improves clean-
ing efficiency and can be provided by pumping, compressed air, vertical
motion or ultrasonic vibration.  Pump agitation rapidly circulates solvent
through the tank.   Compressed air is dispersed from the bottom of the tank
in air agitation.   The rising bubbles scrub the surface of the work.  Ver-
tically agitated cold cleaners vibrate the dirty parts up and down in the
tank with a motor driven, cam actuated device usually operated at 60-70
cycles per minute.  Ultrasonic agitation vibrates the solvent with high
frequency sound waves.  This vibration causes cavitation, the implosion
of bubbles of vaporized solvent on the surface of the parts, which breaks
down the dirt film.   To optimize cavitation, the solvent is usually heated
to a specific temperature.
        Other degreaser components that are discussed in this chapter
include the cover, spray pump and hose, internal and external drain
boards and the parts basket.
                                    2.1-2

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2-1
           Cleaner

-------
                      Figure 2-2
                   SPRAY   SINK
(Safety-Kleen, New Berlin, Wisconsin)

                            2.1-4

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 2.2     ATMOSPHERIC EMISSIONS
 2.2.1   Emission Points
        Solvent evaporation is the basic emission mechanism for cold  cleaners
 and the emission rates vary with size, frequency of use, and manner of their
 operation.  Based on national consumption data, cold cleaners each emit an
 average of 0.3 metric tons of solvent vapor per year.  Maintenance cold
 cleaners emit an average of 0.25 metric tons per year and manufacturing cold
 cleaners emit an average of 0.5 metric tons per year.  Emissions from manu-
 facturing cleaners are larger primarily because their units are used more
 steadily in the course of a work day than maintenance clraners.
        There are several means by which organic solvent vapors can be
 emitted to the atmosphere from a cold cleaner.  These are illustrated
 in Figure 2-3.  Cold cleaners are very rarely hooded or vented to the
 outside.  Thus, an obvious emission point is the direct evaporation of
 solvent from the tank to the atmosphere (Location 1).  Carry out emissions
 (Location 2) result from liquid solvent that is physically carried out
 of the degreaser on the cleaned parts and subsequently evaporates.  Mechan-
 ical agitation of the solvent bath (Location 3) increases evaporative losses.
 Turbulence from spraying (Location 4) increases emissions as does overspray-
 ing (spraying outside the tank), and excessive spray velocity.  Finally,
 the emissions from the disposal of waste solvent (Location 5) can vary
 significantly, depending on the techniques employed.
 2.2.2   Parameters Affecting Rate of VOC Emissions
        Bath evaporation occurs whenever the degreaserfs hood is open but
 is increased by air movement such as drafts or ventilation and is directly
 related to the evaporation rate of the solvent used.  The solvents most
 commonly used by cold cleaners are Stoddard solvents, safety solvents
 (blends of chlorinated hydrocarbons and petroleum solvents), ketones and
 fluorinated solvents.
        Bath evaporation can be minimized during operation when adequate
 freeboard height (distance from solvent level to top of the cold cleaner)
 is employed.   Freeboard height requirements are often expressed as free-
board ratio,  which is the ratio of freeboard height to the width of the
degreaser.
                                  2.2-1

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        Bath evaporation emissions can be further reduced by keeping the
degreaser cover closed during degreasing operations except when parts are
removed from or added to the degreaser.  Various types of covers are
available.  Sliding plastic covers which roll up on a rotating shaft at
one end of the degreaser when not in use are the most simple and easy to
use.  Some large degreaser covers use counterweights.  Electrically or
pneumatically powered covers are also used.  Guillotine covers are another
easily operated type found on many degreasers.  Generally, the amount of
effort required will dictate the frequency of use of the cover and therefore
dictate the amount of bath evaporation.  Hatch type covers such as the one
shown in Figure 2-3 usually have a fusible link support arm so that they
will slam shut in the event that a fire breaks out.  Local fire and  safety
codes often require such devices.
         Air flow into the tank also influences solvent evaporation.  The
degreaser should be located to minimize evaporative losses due to work
fans and ventilation ducts.  Partitions, curtains or baffles help create
a still air zone around the degreaser and can reduce bath evaporation
emissions.
     Control devices are required for cold cleaners with heated (>50°C)
or highly volatile (volatility >4.3 Kpa measured at 38°C)  solvent.   (The
term "cold cleaner" applies even if the solvent is heated,  as  long as the
objective is not to create a vapor zone.)   The control devices which comply
with the RACT guidelines are refrigerated chillers, freeboard  ratios >0.7,
carbon adsorption and water blankets.  If properly applied,  maintained and
operated, these control devices can significantly reduce solvent emissions.
         Refrigerated chillers are condensing coils  located peripherally
along the freeboard, which condense  the solvent vapor before escaping
from the degreaser.  Carbon adsorption is a device which reclaims solvent
from the air/vapor mixture escaping  the cleaner.  These are rarely used
on  cold cleaners.
         A water blanket is a layer  of water  in the  dip tank on top  of  the
solvent which provides a vapor barrier between the solvent and the atmos-
phere.  The solvent must be heavier  than and  insoluble in water.
         Carry-out emissions occur when wet parts are removed from the
degreaser and are  influenced by:  drying procedure,  location and type of
drying racks, s±ze of the parts being cleaned, and the volume of the work-
load.
                                   2.2-2

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                                           I) CARRY-OUT




                                         COMPRESSED  AIR
             5)  WASTE SOLVENT
Figure 2-3.  Cold Cleaner Emission Points
                2.2-3

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         Drainage of any solvent entrained in crevices or depressions in
the parts prior to moving them to external drying racks, and closing the
hood during drying if internal racks are used, minimizes carry-out emissions.
If external racks are employed, drains which return the carried-out solvent
to the degreaser tank reduce solvent loss.  As recommended from ASTM D-26,
cleaned parts should be drained for 15 seconds.
          The surface area of  the parts workload affects carry-out since the
mass-transfer of solvent by evaporation is directly proportional to the
amount of solvent-laden surface area.
         Agitation  increases emissions.   Agitation intensity, amount of heat
input, if any,  and  solvent volatility all affect VOC  emissions  from cold
cleaners.  Proper operating procedures can minimize emission during agita-
tion.  Emissions are insignificant  if the cover  is closed during agitation
and  the  bath should be agitated only during  cleaning.   If air or pump
agitation is used, the flow rate should be adjusted to  the minimum amount
required to achieve the desired degree of cleaning.  Air flow rate should
                         o
not  exceed 0.01 to 0.03 m  per minute per square meter  of opening.
         Evaporation from spraying will vary with spray pressure, spray
droplet  size and distribution, amount of  overspray which splashes from
the  sink, solvent volatility and amount of time the spray is in use.
         Spray  operating techniques can lower emissions.  Care to eliminate
overspray, adjusting spray to  a solid fluid stream and  limiting spray fluid
pressure to a maximum of 10 psig will reduce solvent  losses by evaporation.
         Waste  solvent evaporation is the single largest mechanism for solvent
emissions from  cold cleaning.  The amount of solvent  disposed by a single
degreaser is dependent upon the degreaser size, frequency of operation,
degree of cleanliness required and amount of oil and  dirt to be removed.
If a cold cleaner spray system is equipped with a filter, the frequency of
disposal is reduced.
         Leaks  in spray lines  and agitation pump discharge  lines which are
under pressure  can cause significant solvent emissions.  Pipe flanges,
drain valves, corroded tanks (especially  when using an  acidic solvent or
if water is present in the solvent) can also leak if  not properly maintained.
                                     2.2-4

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         Acceptable methods of disposal include recycling by distillation,
proper incineration, distillation (recovery of solvent for re-use) and
chemical landfilling if waste is enclosed in sealed containers and surrounded
by impermeable soil.
         Disposal by flushing solvent into sewers, spreading solvent for dust
control and landfilling without proper containers or prevention of leaching
all result in complete evaporative emissions of waste solvent to the atmos-
phere.
         Solvent emissions are greatly influenced by the type of solvent.
Obviously volatility and operating temperatures are significant parameters
affecting emissions.  Highly toxic solvents are more conscientiously
controlled to protect workers and comply with OSHA regulations.  Solvent
costs often determine the care with which degreasers are operated.  More
expensive solvents are usually conserved by the same procedures which
reduce emissions and are more likely to be recycled.
                                     2.2-5

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 2.3      EMISSION CONTROL METHODS
         The  EPA Control  Technology Guideline  (CTG)  document  for solvent metal
 cleaning identifies  a  number  of control strategies  for  reducing volatile
 organic  emissions from cold cleaning  degreaser  operations.   These  form the
 basis  of defining RACT for the cold cleaning  degreasers and  should therefore
 be the focal point of  a  field inspection.   The  CTG  suggests  two levels of
 control.   (See  Table 2-1).  Level  A could  reduce  cold cleaning  emissions by
 50%  (+20%) and  Level B may achieve a  reduction  of 53% (+20%).   The range
 represents the  limits  of reduction for  poor operating procedure (-20%)  and
 good operating  procedure (+20%).   The estimated benefit from Level B  only
 slightly exceeds  that  from Level A, assuming  low  volatility  solvents.   This
 is because the  additional devices  required in Level B generally control only
 bath evaporation  which represents  only  20% to 30% of the total  emissions
 from an  average cold cleaner.  For cold cleaners  using  highly volatile
 solvents, bath  evaporation may constitute  50% of  the total emissions,  and
 it is  estimated that Level B  would then achieve an  emissions reduction of
 69%  (+20%) and  a  55% (+20%) reduction for  Level A.
         The  preceding  discussion on the parameters  affecting the rate  of
 VOC emissions (Section 2.2.2) explicitly identifies the equipment  and
 operating procedures necessary to  implement the RACT control strategies
 except for the  disposal  of waste solvent.   Dirt,  grease,  oil, metal chips
 and the  like  slowly  build up  in the liquid solvent  over a period of time
 and eventually  severely  affects its ability as  a  cleaning agent.   This
 usually  occurs  when  the  solvent contamination level reaches about  10
 percent  by volume.   It is fairly common for the small operator  to  secure
 a service contract that  provides for reclaiming the spent solvent.  The
 contractor distills  the  spent solvent and  returns it to users for  a fee.
 One organization  rents the cold cleaner  and provides the  solvent reclama-
 tion service as a package deal.   Large  operations that  use scores  of
manufacturing cold cleaners sometimes operate stills on-site to reclaim the
 solvent.   Distillation,  proper landfilling, and incineration (which is
not commonly used) will meet the RACT operating requirements ("not  greater
 than 20 percent can evaporate into  the  atmosphere").  Disposal of  the
waste solvent (and still bottoms)  at landfills may be subject to hazardous
waste disposal regulations.   EPA has proposed regulations governing the
disposal of such material in the Federal Register at 43FR58946  (December  18,
1978).
                                    2.3-1

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                                 TABLE  2-1

                  CONTROL  SYSTEMS FOR COLD  CLEANING
  Control System A

  Control Equipment

       1.  Cover

       2.  Facility  for  draining  cleaned parts

       3.  Permanent,  conspicuous  label, summarizing the operating requirements

  Operating Requirements:

       1.  Do not dispose  of waste solvent or transfer it to another party,
  such that greater  than 20 percent of the waste (by weight) can evaporate
  into the atmosphere.11'  Store waste solvent only in covered containers.

       2.  Close degreaser cover whenever not handling parts in the cleaner.

       3.  Drain cleaned parts for at least 15 seconds or until dripping ceases.

  Control System B

  Control Equipment:

       1.  Cover: Same  as in System A, except if (a) solvent volatility is
  greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38°C (100°F),**
  (b)  solvent is agitated, or (c)  solvent is heated, then the cover must
  be designed so that  it can be easily operated with one hand.  (Covers for
  larger degreasers  may  require mechanical assistance, by spring loading,
  counterweighting or  powered systems.)

       2.  Drainage  facility:  Same as in System A, except that if solvent
  volatility is greater  than about 4.3 kPa (32 mm Hg or 0.6 psi) measured at
  38°C (100°F), then the drainage facility must be internal, so that parts are
  enclosed under the cover while  draining.  The drainage facility may be
  external for applications where an Internal type cannot fit into the cleaning
  system.

       3.  Label: Same  as in System A

       4.  If used,  the  solvent spray must be a solid, fluid stream (not a
  fine, atomized or  shower type spray) and at a pressure which does not cause
  excessive splashing.

       5.  Major control device for highly volatile solvents:  If the solvent
  volatility is > 4.3  kPa  (33 mm Hg or 0.6 psi) measured at 38°C (100°F), or
  if solvent is heated above 50°C  (120°F), then one of the following control
  devices must be used:

       a.  Freeboard that  gives a  freeboard ratio*** ^0.7

       b.  Water cover (solvent must be insoluble in and heavier than water)

       c.  Other systems of equivalent control, such as a refrigerated chiller
  or carbon adsorption.

  Operating Requirements:

       Same as in System A
  *Water and solid waste  regulations must also be complied with.
 **Generally solvents consisting primarily of mineral spirits (Stoddard) have
   volatilities - 2 kPa.
***Freeboard ratio is defined  as the freeboard height divided by the width
   of the degreaser.
                              2.3-2

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2.3.1  Other Controls
     Where work being degreased contains acid cutting oils  or other
acidic products, acid acceptance and PH determination should be made to
ascertain the quality of the solvent.
     Absorbent materials such as wood or fabric materials should not be
degreased or used in basket construction.
     The cold cleaner should be inspected for solvent leaks and repairs
should be made as necessary.
                                   2.3-3

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 2.4      INSPECTION PROCEDURES
         This section will discuss two  types  of inspections:   (1)  field
 review and  (2) office reviews.  Source sampling, still another  form  of
 inspection, is only feasible for measuring the stack  gases from carbon
 adsorbtion  systems which are rarely used  for cold cleaning degreasers.
         Field inspections range from plant visits to  thorough inspections
 that produce a complete data base for  enforcement proceedings.  Office
 reviews  rely on the source to furnish  the information.  This approach may
 require  less time and manpower but the resulting data base is generally
 less complete.  Office reviews, however, provide a useful screening
 mechanism where the number of potential violators is  large.
 2.4.1    Field Inspections
        After becoming familiar with the plant and its facilities the
 inspector should request that the appropriate company official  provide
 information from company records that  will allow the  inspector  to complete
 the worksheets shown in Figure 2-4.  The data may also be available  from
 permit applications.  The worksheet divides the required data into two
 categories:  operating requirements and control equipment.  It  also
 provides the RACT requirements for each category with suggested inspec-
 tion procedures and guidelines.  With  such information, comparisons  can
 be made with past conditions, and with  operations at  the time of the
 inspection.
        Generally, the inspector would next request the company's assistance
 in conducting a full inspection of the  facility in order to verify actual
 operating conditions.   This inspection may take several hours depending on
 the number and types of degreasers.
        All field data such as solvent temperature and type should be
measured or observed first hand.   Auxiliary degreaser components (sprayer,
agitator, etc.),  and waste solvent,  recovery, disposal or storage facilities
 should be seen and verified.   Operating procedures should be observed and
noted.   Degreasers should be inspected for condition  of hoses, connections,
drains and for leaks^   The inspector should check for ventilation ducts,
location of work fans and air flow baffles near the degreaser which may
affect solvent evaporation rate.   The inspection should include evaluation
of those parameters which influence emissions as discussed earlier in this
chapter.

                                 2.4-1

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                                             FIGURE 2-4
                            EXAMPLE  WORKSHEET FOR FIELD INSPECTION OF
                                            COLD  CLEANERS
1.  BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY:
2a.
3.
It.
5.
6.
7.
MAILING ADDRESS: 2b. PLANT ADDRESS WHERE THIS DEGREASER IS LOCATED:
SOURCE NO. (PERMIT NUMBER, NEDS ID, ETC.):
NAME AND TITLE OF COMPANY REPRESENTATIVE:
TELEPHONE NO.:
NAME OF OFFICIAL CONDUCTING INSPECTION:
DEGREASER
MANUFACTURER: MODEL NO. SERIAL NO.
INSIDE DIMENSIONS OF TANK (FT.): WIDE X LONG X DEEP
TYPE OF DEGREASER: SPRAY SINK [~~| DIP TANK [~~|
8.
9.
TITLE AND CODE NUMBERS OF DRAWINGS, SPECIFICATIONS, STANDARDS, CODES, PROCEDURES AND DOCUMENTS USED WITH THE
INSPECTION


TYPE OF SOLVENT IN USE (SPECIFIC NAME AND MANUFACTURER) :


INSPECTION OBSERVATIONS
RACT REQUIREMENT
1.
2.
3.
4.
CONTROL EQUIPMENT
Cover
Cover must be easily
operated with one hand
if:
- Solvent volatility
>2 kPa (measured at
38°C)
- Solvent is agitated
- Solvent is heated
Drainage Facility
Internal drainage
facility is required
if:
- Solvent volatility
> 4.6 kPa (measured
at 38°C)
SUGGESTED INSPECTION
PROCEDURE
o Observe if a cover is Installed
and if it is closed when parts
are not being handled in the
degreaser.
o Observe if cover can be operated
with one hand. Observe if solvent
is heated or agitated. If degreaser
cover is large, check for mechani-
cal assistance for operation. Deter-
mine the solvent type and its vola-
tility. Vapor pressures for common
solvents can be found in Chapter 1
of this manual.
o Observe if drainage racks are
provided. If drainage racks are
external to the degreaser, observe
if drainage is routed to the solvent
bath.
o Observe if drainage racks are
internal. Determine solvent
volatility.
FIELD
OBSERVATION




                                                2.4-2

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FIGURE 2-4
(Continued)
RACT REQUIREMENT
5. Solvent spray must be
a solid fluid stream
and at a pressure that
does not cause splash-
ing.
6. Permanent conspicuous
label summarizing
operating require-
ments.
7. If solvent volatility
>4.3 kPa measured at
38°C, or solvent temp-
erature is > 50°C then
one of the following
control measures must
be used.
a. Freeboard Ratio
>_ 0.7
b. Water Cover
c. Other systems of
equivalent control
such as chiller
or carbon adsorb-
tion
OPERATING REQUIREMENTS
1. Do not dispose of
waste solvent or trans-
fer it to another party
such that greater than
20% (by weight) can
evaporate to the atmos-
phere. Store waste
solvent only in covered
containers.
2. Close degreaser cover
whenever not handling
parts in the cleaner.
3. Drain parts for at
least 15 seconds or
until parts are dry.
SUGGESTED INSPECTION
PROCEDURE
o Observe If spray forms a mist
or shower type consistency. Check
for splashing above degreaser free-
board
o Observe if label is clearly displayed,
complete and permanently fastened to
degreaser
o Determine if requirement is appli-
cable
o Measure solvent temperature
(if heated) with thermometer
o Calculate from degreaser
dimensions. Freeboard ratio -
Freeboard
Width
o Observe if the solvent
is covered with water.
o Determine if appropriate device is
installed and operational
o Determine if source has inhouse
reclamation facility (i.e. still)
or a service contract with a
solvent reclamation firm.
o Confirm that storage is done
with covered containers. Note
whether containers leak.
o Observe the operation
o Observe this operation. Time if
necessary, or determine if parts
are dry when removed from drying
rack.
FIELD
OBSERVATION






     2.4-3

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        If the degreaser is not in use then only design data and records
review can be performed during the field inspection.  Maintenance degreasers
are used intermittantly and may not be operating during the inspections.
Manufacturing cold cleaners are generally an integral part of a manufacturing
process and normally will be operating.  It is important to note that
operating procedures (use of cover, drain and drying time, spray technique)
can have a significant impact on solvent emissions regardless of equipment
design.
        The information gathered during the field inspection will be compared
to the data given by the company official, and the total data base will be
compared to the RACT requirements for design, operating and control require-
ments to determine if a violation exists.  At that time, a reinspection date
should be established if it is determined that the source is not in compliance.
        Figures 2-5 and 2-6 are photographs of a maintenance cold cleaner
of a design that would typically be encountered by an inspector.  In
Figure 2-5 the rectangular box in the corner of the tank contains the
spray pump, the cylindrical housing contains pump filter.  Figure 2-6 shows
that this cleaner has been equipped with two spray hoses; the flexible metal
hose is the original equipment, the garden hose and nozzle was retrofitted
by the operator in order to increase the spray velocity.  This arrangement
potentially violates the RACT requirement that the solvent spray must be
"...a solid, fluid stream (not a fine, atomized or shower type spray) and
at a pressure that does not cause excessive splashing".  Also, note the pan
located underneath the drainage rack.  Drippings from drying parts are
accumulated on the pan, rather than returned to the tank.  This increases
the surface area of solvent, thus increasing evaporative losses.
2.4.2    Record Review
         Determining compliance of cold cleaning degreasers through field
inspections and monitoring is expensive and time consuming.  It requires
a great deal of manpower and tends to limit the number of sources that can
be reviewed in a given year.  The review of company-furnished records
through questionnaires or letter requests may provide a viable alternative
to field inspections and source monitoring activities for compliance deter-
mination.  At minimum, this approach should be considered as a screening
tool to identify candidate sources for comprehensive field inspections,
thereby increasing the effectiveness of the available resources.
                                  2.4-4

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                          Figure 2-5
                          MAINTENANCE
                          COLD
                          CLEANER
Figure 2-6

DRAINAGE
RACK
                      2.4-5

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         This discussion outlines several procedures which may be used when
implementing a record review.  Information will be required from the plant
concerning the design, operation and maintenance of the equipment.
         When screening sources for setting inspection priorities by office
review of questionnaires, the estimated average emission rates of 0.25
metric tons per year for maintenance cold cleaners and 0.50 metric tons
per year for manufacturing cold cleaners can be applied to individual
degreasers to estimate the total cold cleaning solvent emissions for a
specific source.  Comparison of the total emissions for each source can
aid in allocating manpower for inspections to achieve effective use of
an enforcement agencies resources.
2.4.2.1  Review of Design, Operation, and Maintenance Data
         The first requirement of this procedure is the development of
standard questionnaires that can be sent out as part of a Section 114
request to the applicable sources.  The type of information required is
similar to what is identified on the inspection forms illustrated in
Figure 2-4.  It is important that the source understand what is being
requested and that the request be realistic because the entire process of
making compliance judgments using this procedure is highly dependent on
the reliability of the information furnished.
         An example questionnaire is provided as Figure 2-7 and should
be used as a guide only.  It is suggested that the agency develop its
own form which would be specific to the program.  For example, a screening
program may only require key data, while a more extensive request is
necessary  if compliance determinations are to be attempted.  Three types
of data are suggested for review:  design information, operational infor-
mation, and maintenance records.  The design data should be readily avail-
able, while operational and maintenance may require the source to create
a special  logging system in order to comply with the agency's request.
        Design data should be compared to the RACT requirements and review
should include such items as degreaser dimensions, solvent bath volume,
solvent type, auxiliary components (agitation, spray, etc.) and type of
cover and drainage facility.  Operational information such as solvent
makeup schedule (if any) and rate, disposal schedule and procedure, and
frequency  of degreaser operation should be reviewed.  Maintenance records
should report repair or replacement records and comment on the general
condition  of the equipment.

                                     ^-. 4-6

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                                                     FIGURE 2-7
                                EXAMPLE QUESTIONNAIRE FOR OFFICE  REVIEW

                                        OF  COLD CLEANING DEGREASERS
 GENERAL
 1.   BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY:
 2a.  MAILING ADDRESS:
      2b.  PLANT ADDRESS WHERE THIS DEGREASER IS LOCATED:
 3.   SOURCE NO. (PERMIT NUMBER,  NEDS  ID, ETC.):
 it.  NAME  AND TITLE OF AUTHORIZED COMPANY REPRESENTATIVE FURNISHING DATA:
                                                                                   SIGNATURE:
 5.   TELEPHONE NO.:
 6.   DEGREASER:
         MANUFACTURER:	
         INSIDE DIMENSIONS OF TANK (FT) :_
         DIP TANK |—-i     SPRAY SINK |	1
_MODEL NO.
 WIDE X
                       LONG X
_SERIAL NO.	
          DEEP
 7.   TYPE  OF SOLVENT IN USE (SPECIFIC  NAME AND MANUFACTURER):
 8.   EQUIPMENT DESIGN
         TANK COVER:  YES j   |  NO |   [

         DRAINAGE BOARD  YES |   | NO |   |

              INTERNAL   ||

              EXTERNAL   ||

         DRAINAGE RETURN (IF EXTERNAL)  j   |

         SOLVENT SPRAY:  YES [^] NO |   I

                SPRAY PRESSURE     PSI
AGITATION:   YES |   |  NO |   |

   PUMPED |    |    MECHANICAL |   |

   AIR   |    |    ULTRASONIC |   [

   HEATED:   YES Q]]  NO |   j

   IF HEATED, GIVE TEMPERATURE 	°F
                                                         FREEBOARD HEIGHT
                                                                             FT
 9.  OPERATING PROCEDURE

         CAN DEGREASER COVER BE CLOSED  DURING DEGREASER OPERATION?   YES |   [  NO I   I

         IS DEGREASER COVER CLOSED WHEN DEGREASER IS NOT IN USE?    YES |   |  NO |   |

         ARE PARTS DRY BEFORE REMOVAL FROM DRYING RACK?.             YES £^[  N0 d

         HOW IS WASTE SOLVENT DISPOSED  OF:
         FREQUENCY OF MAKEUP
10.   CONTROL DEVICES:

         REFRIGERATION CHILLERS   YES |   I  NO |   [

         CARBON ADSORBTION        YES |   [  NO |   [

         WATER COVER              YES |   |  NO |   |

         FREEBOARD RATIO >_ 0.7    YES |   [  NO |   |
11.   DESCRIPTION OF MAINTENANCE PROGRAM:
                                                        2.4-7

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2.4.2.2 Review Waste Solvent Disposal Procedures
        A description of waste solvent disposal methods used by the source
must be requested in the questionnaire initiated by the agency (example
shown in Figure 2-7) .  A comparison should be made with the RACT operating
requirements ("not greater than 20 percent can evaporate into the atmosphere"),
and data on other acceptable practices which are readily available.
        Several acceptable methods for disposing of waste solvent were briefly
discussed in Section 2.3.  Common disposal methods that do not meet the
RACT guidelines include flushing waste solvent into sewer lines and spreading
waste solvent on parking lots and roadways for dust control purposes.
                                   2.4-8

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                             CHAPTER 3

                     OPEN TOP VAPOR DEGREASERS

3.1     PROCESS DESCRIPTION
3.1.1   Unit Operation
     Open top vapor degreasers provide an efficient and economical method for
preparing clean, dry articles for subsequent finishing or fabricating.  There
are several configurations in use for open top degreasers; all are similar in
basic design.  In the simple vapor method, cleaning results from the condensa-
tion of solvent vapors on the cool surface of the article; the dissolving and
flushing action of the condensate removes the soil.  When the article reaches
the temperature of the solvent vapor, no more condensation (or cleansing)
occurs and the article is removed from the vapor zone.  Other cleaning methods
involve various combinations of the simple vapor method with immersion and spray-
ind with liquid solvent.
     Open top vapor degreasers utilize nonflammable solvent contained in the
lower area of the degreaser, referred to as the boiling sump.  The solvent is
boiled to produce a vapor zone, the height of which is controlled by cooling
coils installed above the vapor zone.  The "cold work" introduced into the
vapor space of the degreaser must be at a temperature lower than the vapor zone
in order to cause the solvent vapors to condense on the work surfaces and flush
the oil and other foreign matter off with the liquid condensate.  The removed
material accumulates in the boiling sump and only the pure vapor comes in con-
tact with the work load.  In either case, flushing is often followed by pure
solvent spray and/or liquid immersion.  The cool, pure liquid solvent reduces
the temperature of the work surface below the vapor temperature, producing a
second vapor condensation flushing action on the work surfaces.  When the work
pieces are removed from the degreaser, they should be clean, dry, and ready for
further processing.
3.1.2  Types of Open Top Vapor Degreasers
     Open top vapor degreasers are most suitable in situations where the
work flow is variable or intermittent.  Otherwise, a conveyorized degreaser
might be the equipment preferred.  Essentially, there are three variations of
vapor degreasing:  (1) straight vapor, (2) liquid immersion-vapor, and
(3) vapor-spray-vapor degreasing.

                                    3.1-1

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        o  Straight Vapor:  In this unit, the article to be cleaned is lowered
           into the vapor zone and held there until it reaches the vapor temp-
           erature, at which point vapors cease condensing on the article.  It
           is gently agitated to enhance drainage of trapped liquid solvent.
           Then, it is brought into the freeboard area and allowed to dry for
           a moment before being removed from the degreaser.  Figure 3-1 is
           a cut away sketch of a straight vapor degreaser.  As with any open
           top arrangement, the work to be cleaned may be lowered manually
           or with an overhead hoist with hooks or long handle baskets.  Hands
           should never be placed below the vapor line.

        o  Liquid Immersion - Vapor:  Immersion of the work in the hot or
           boiling solvent is preferred;  (i) for closely nested work, (ii) for
           excessive soil levels (iii) for light gauge work, (iv) when ultra-
           sonics is necessary, and (v) for parts with intricate patterns.
           Figures 3-2 to 3-4 show various equipment configurations for this
           technique.  Typically, the work is lowered into the vapor zone for
           a straight vapor rinse, then lowered into the liquid immersion
           chamber to be rinsed.  This will cool the work slightly.  Then,
           the work is raised into the vapor zone for a second vapor rinse.
           The 2-compartment unit shown in Figure 3-3 may be operated in this
           fashion or, if necessary for proper cleaning, the work may be
           lowered directly into the boiling sump, then rinsed in the con-
           densate reservoir.  (Care should be taken not to drag dirty solvent
           from the boiling liquid tank to the rinse tank).  After the liquid
           rinse the work is given a vapor rinse above the condensate reser-
           voir.  The reservoir is often heated to ensure that the liquid
           rinse is warm.  Similarly, the 3-compartment unit depicted in
           Figure 3-4 may be outfitted to operate with two or three liquid
           immersions.

        o  Vapor - Spray - Vapor:  This is similar to straight vapor degreasing
           except that as soon as the work is below the vapor level, it is
           sprayed with cool condensate.  After spraying is complete the work
           should remain in the vapor zone until it reaches the vapor tempera-
           ture and condensation has stopped.  Figure 3-5 is a schematic of
           a spray unit with an offset condenser.  Spraying should be done
           as far below the top of the vapor line as possible so that evapora-
           tive losses due to spraying are minimized.

    Some units, especially larger ones, are equipped with a lip exhaust.  A

lip exhaust draws air laterally across the top of the degreaser and vents the
air directly to the roof or to a carbon adsorption unit.  Figure 3-6 is a

schematic of one of these units.  The primary purpose of a lip exhaust is to

limit worker exposure to solvent vapors.

    Figures 3-7 through 3-9 are photographs of three variations of open top

vapor degreasers.  The unit in Figure 3-8 relates directly to the schematic

in Figure 3-3.  The physical dimensions of these units varies widely.  For
example, the vapor-spray unit in Figure 3-7 commonly is purchased in several

sizes ranging from 2 feet wide by 4 feet long by 4 1/2 feet high to 4 feet

wide by 12 feet long by 9 1/2 feet high.  Larger sizes are available on

special order.
                                     3.1-2

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             CONDENSING  COILS
WATER SEPARATOR
 DISTILLATE
 HEAT  EXCHANGER
    CLEANOUT
    DOOR
           SOLVENT LEVEL
           SIGHT GLASS
                          SAFETY
                          THERMOSTAT
                                                                      FREEBOARD
                                                                         WATER
                                                                         JACKET
                                                                H CONDENSATE
                                                                   TROUGH
                          HEATING
                          ELEMENTS
                                                      WORK REST AND
                                                      PROTECTIVE GRATE
\TEMPERATURE
 INDICATOR
                 Figure 3-1.  Single Compartment Vapor Degreaser
                                      3.1-3

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                                                          WATER JACKET
                  CONDENSING COILS

           CONDENSATE TROUGH
                                                                  WATER
                                                                  SEPARATOR
                                                           CONDENSATE RETURN
                                                           LIQUID IMMERSION
                                                           CHAMBER
STEAM/
-BOILING  SUMP
           Figure 3-2.   Liquid-Vapor  Degreaser
                           3.1-4

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           FREE BOARD
       BOILING SUMP-
                                                             CONDENSING COILS
                                                                  WATER  JACKET
                             CONDENSATE TROUGH
                                                                       WATER SEPARATOR
                                                                CONDENSATE RESERVOIR
                           STEAM
                Figure 3-3.  Liquid-Liquid-Vapor Degreaser 2 Compartment
                            WORK FLOW
                                                 CONDENSING  COILS

                                           CONDENSATE TROUGH
HOT SOLVENT
RESERVOIR
         WATER JACKET
                                                                             •WATER
                                                                             SEPARATOR
                                                                      CONDENSATE RETURN
          BOILING SUMP
                   STEAM
STEAM
                             WARM RINSE7    ^-OVERFLOW

                Figure 3-4, Liquid-Liquid-Vapor Degreaser 3 Compartment
                                      3.1-5

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  FREE
 BOARD
 WATER
 JACKET
            FLEXIBLE HOSE

        SPRAY  LANCE

VAPOR LEVEL -.
STEAM

CONDENSING
COIL

^CONDENSATE
  TROUGH
                                                                     WATER
                                                                     SEPARATOR
                                                      CONDENSATE
                                                      RESERVOIR

                                                      SPRAY
                                                      PUMP
                                                BOILING SUMP
          Figure 3-5.  Offset Condenser Vapor-Spray-Vapor  Degreaser
TO ATMOSPHERE
OR ADSORBER BLOWER
                                                EXHAUST  INLET
                                                                 EXHAUST DUCT
                                             CONDENSING UNIT
                    Figure  3-6.  Degreaser with Lip Exhaust

                                 3.1-6

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OJ

I-1
I
                            Figure 3-7.  Perimeter Condensing  Vapor-Spray-Vapor  Degreaser

                                         ( Baron Blakeslee, Chicago, Illinois)

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Figure 3-3.   Liquid-Liquid-Vapor Degreaser  2  Compartment
             (Baron  Blakeslee.  Chicago,  Illinois)
                           3.1-i

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Figure 3- 9.
Uquid-Liquid-Vapor Degreaser 3 CompartmentWith Automatic Dip
(Delta Industries,  Santa  Fe  Springs,  California.  )
                                      3.1-9

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        The unit in Figure 3-9  is a 3 compartment degreaser that is outfitted

with an automatic hoist system.  The work is loaded into a basket that is auto-

matically carried through the cleaning cycle.  As pictured, the work is in

compartment #1.  Note that as the mechanism moves the work from left to right

and back a horizontal cover is automatically opened and closed.

3.1.3   Operation of Degreaser Components

        Open top vapor degreasers are relatively simple in design.  Although

there are several different common configurations and optional features, they

share common design characteristics.  Typical units, as shown in Figures 3-1

through 3-6, consist of a boiling sump, cooling coils, a work delivery system, a

vapor space above the boiling sump, a freeboard, safety thermostats, and a water

separator.  Most units are equipped with a downtime cover to minimize solvent

loss when the degreaser is not in operation.  Some units are equipped with a

liquid spray, ultrasonic cleaning mechanism, water jacket, or lip exhaust.

Brief descriptions of the primary components follow:

        o  Boiling Sump - The boiling (solvent) sump is located in the
           bottom section of the degreaser and includes the heating coils
           for vaporizing the liquid solvents.  Steam, electricity, and gas
           are the mediums normally used to heat the chamber.  Steam is often
           the most economical.  Steam is usually supplied by use of a pipe
           coil in the boiling sump although a steam jacket or panel may be
           preferable in certain designs.

           In those cases where electricity is the heating method of choice,
           immersion type heaters should be installed on a sturdy support
           within the boiling sump.  Degreasers which are not expected to
           accumulate metal fines or precipitate other insoluble solids may be
           adequately heated by strip heaters fastened in close contact with
           the underside of the sump.

           If gas is used for heating, the burner is enclosed in an immersion
           tube in the boiling sump.  The combustion chamber must be of tight
           construction and the gas flame's air supply should be designed so
           that fresh air only is fed to the burner.  Being a combustion
           process an exhaust flue is required to vent the exhaust gases out
           of the work area.

           The boiling sump and heating elements (regardless of heating method)
           should be accessible for cleaning and maintenance.  The heating
           elements usually are removable and access doors are often provided
           for the sump, especially on larger units.

        o  Vapor Zone - The vapor zone is the volume of vapors above the boiling
           liquid solvent up to the vapor/ambient air interface that occurs at
           the cooling coils.  This area in the degreaser is pure solvent vapor;
           the solvent vapors are about 4 1/2 times as heavy as ambient air so
           they are contained quite efficiently within the degreaser to form a
           vapor zone in which the vapor degreasing actually occurs.

                                   3.1-10

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o  Freeboard - The upper body of the degreaser is extended above
   the cooling coils to .provide a "seal" of stagnant air over  the
   vapor zone.  This area is referred to as the freeboard and  it
   serves to reduce distrubances at the vapor/air interface thus
   reducing solvent vapor emissions.  It also serves as a dis-
   engaging space for the traces of solvent which evaporate from
   the work as it is withdrawn after cleaning.

o  Cooling Coils - Cooling  (condensing) coils are installed along
   the inside surfaces of the degreaser; their location defines
   the upper limit of the vapor space and the lower limit of the
   freeboard.  The coils consist of four or more pipe coils stacked
   one above the other and  located directly above a vapor condensate
   trough.  The cooling medium is normally tap or process water.
   Usually, the water enters the bottom coil and exits at the top.
   If the arrangement should be reversed, the bottom exit should
   be connected to a standpipe at least as high as the condenser
   so that the condenser will always stay full of water.  Sometimes
   the coils are set along  only one side of the degreaser, as shown
   in Figure 3-5.

o  Water Separator - Water  enters a degreaser from several sources;
   i.e., condensation of atmospheric moisture oh condenser coils,
   moisture on work pieces being processed, and steam or cooling
   water leaks.  Water forms a low boiling azeotrope with the sol-
   vent and is vaporized.  Most degreasers are equipped with a
   water separator because uncontrolled water causes corrosion,
   shortens solvent life, and increases the vaporization rate of
   solvent.  The condensed  solvent-water mixture drops into the
   condensate trough below  the condenser coils and flows by gravity
   to the separator.

o  Piping and Sprays - There is a minimum amount of piping included
   in the degreaser.   Leaks should not  be tolerated because they
   represent a source of emission and a loss of valuable material.
   Drain valves are generally found at the lowest point in the
   tank.  Piping that is under pressure, such as the spray line,
   is a potential source of leaks.   Sprays should be operated
   within the vapor zone so as to not disturb the air/vapor inter-
   face.  Some designs spray the material in a contained chamber
   within the degreaser.   A spray safety switch is generally pro-
   vided to shut off the spray pump when the vapor level drops
   below the design level.

o  Water Jacket - A water jacket,  where applicable,  is installed on
   the exterior of the degreaser and consists of a box section to
   contain cooling water circulating around the degreaser in the same
   approximate area of the  cooling coils.   This jacket is sometimes
   referred to as the freeboard cooler.   Its function is to prevent
   convection of solvent vapors up  hot degreaser walls.   In addition,
   water jackets may reduce "sidewall radiation" from hot freeboard
   walls.   This heat  radiation can  increase air turbulence and thus
   disturb the cold air blanket in  the freeboard area.   Water jackets
   are sometimes used in lieu of cooling coils in smaller units.

   Water jackets and  cooling coils  should not  be confused with refri-
   gerated chillers.   Chillers are  sometimes used in addition to these
   units in order to  increase vapor control efficiency.
                          3.1-11

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o  Covers - An automatic or manual cover should be installed on open
   top vapor degreasers.  The use of such covers reduces solvent losses
   during idling and downtime.  A simple lid type cover is effective
   if utilized by operating personnel.   Newer units often are equipped
   with mechanisms that are more easy to use, and hence more frequently
   used.  The more popular manual designs open and close in a horizontal
   motion, so that the air/vapor interface disturbance is minimized.
   These types of covers include roll type plastic covers, canvas curtains
   and quillotine covers.  It is usually advantageous on larger open top
   vapor degreasers to power the cover.   This may be done pneumatically
   or electrically, usually by manual control with an automatic cutoff.
   The most advanced covering systems are automated in coordination with
   the hoist or conveyor.  The cover can be designed so it will close
   while the parts are being cleaned and dried.  Thus, the cover is
   open for only a short period of time  when the parts are actually
   entering or exiting the degreaser.

o  Safety Switches - A variety of safety switches are available to
   prevent emissions or damage to the equipment during a malfunction.
   (1) The most important safety switch  is the vapor level control
   thermostat.  This device turns off the sump heat if the vapor zone
   rises above the design level.  When hot vapors are sensed above the
   cooling coils the sump heater is turned off, thus minimizing solvent
   vapor losses.  (2) The condenser water flow switch and thermostat
   turns off the sump heat when either the condenser water stops circu-
   lating or the condenser water becomes warmer than specified.  (3) The
   boiling point in the sump increases as the solvent becomes contami-
   nated with oils, grease and other materials.  To prevent the sump
   from becoming too hot, thus causing solvent decomposition, the sump
   thermostat cuts off the heat when the sump temperature rises signi-
   ficantly above the solvent's boiling  point.  (4) The sump can be-
   come too hot also if the liquid level drops and exposes the heating
   elements.  Thus, some units are equipped with a solvent level control
   that cuts off the heat if the liquid  level in the boiling sump drops
   down to the level of the sump heater  coils.  (5) Spraying above the
   vapor line can cause excessive emissions, so a few units are equipped
   with a spray safety switch that turns off the spray pump if the vapor
   level drops below a specified level.

   As a minimum, the vapor level control thermostat should be of the
   manual reset type.  Some manufacturers install manual reset switches
   for all of the safety switches they install on a unit.

o  Water Regulating Valve - To minimize  water consumption, some units
   are equipped with a water regulating  valve installed at the water
   outlet of the cooling coils.  A constant temperature is automatically
   maintained at the outlet of the coils by the valve's temperature bulb.
   The valve opens on temperature rise,  closes on temperature drop.

o  Ultrasonics - If parts are immersed in the liquid solvent, cleaning
   may be enhanced by vibrating the solvent with high frequency sound
   waves.  To optimize cavitation at the surface of the work the solvents
   need to be heated to specific temperatures.  Cavitation is the implo-
   sion of microscopic vapor cavities within the liquid solvent.
                          3.1-12

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 3.2    ATMOSPHERIC  EMISSIONS
 3.2.1  Emission  Points
     There  are several means  by which  organic  solvent  vapors  can be emitted
 to the atmosphere in  an  open  top  vapor degreaser.   These  are  identified  in
 Figure 3-10.  In general,  open top units  are not hooded or  vented to the out-
 side.  Thus,  an  obvious  emission  point is the  direct diffusion  and convection
 of vapors from the  vapor zone to  the atmosphere  (Location 1).   If a lip
 exhaust  is  installed  some  of  these vapors can  be directed to  a  roof vent
 (Location 2).  If not properly designed,  these systems can  actually increase
 solvent  evaporation,  especially if the exhaust rate is excessive,  causing
 disruption  of the air/vapor interface.  The use of  lip (or  lateral)  exhausts
 is usually  limited  to larger  than average degreasers where  the  primary objec-
 tive is  to  limit worker  exposure  to solvent vapors.  A rule of  thumb used by
 degreaser and control systems manufacturers is to set  the exhaust  rate at 50
 cubic feet  per minute per  square  foot  of  degreaser  opening.   If this exhaust
 rate is  not adequate  to  protect the workers, higher rates may be  encountered.
     Carry-out emissions result from solvent that has  condensed on the work
 and has  not fully evaporated  before being removed from the  degreaser (Loca-
 tion 3).  Also,  solvent  vapors may be  entrained by  the motion of  removing
 the work from the vapor  zone  or by convection  due to the  hot work  heating
 the solvent laden air as it is removed  from the vapor  zone.  Porous  or
 adsorbant materials such as cloth, leather, wood or rope  will adsorb and
 trap condensed solvent and thus such materials should  never enter  a  degreaser.
     As  the solvent material  is spent  and itself becomes  contaminated with
 impurities  its usefulness decreases.  To  reduce the volume  of waste  material
 some degreasers  are used as a simple still during downtime where the solvent
 in the sump is boiled off as much as feasible  and the  pure  condensed vapors
 are piped off to a storage tank,  rather than back to the  sump.  Other
 degreasers,  especially the larger ones, may be used with  an external still
 that may run on a continuous or batch basis.  Nevertheless,  a significant
 volume of waste material will remain to be disposed of and depending on the
 method of disposal,  waste solvents may enter the atmosphere (Location 4).
     Fugitive emissions can occur at any  of the piping connection  or pump
 seals that may have loosened,  or  become worn or corroded  (Location 5).
 These emission points are usually eliminated fairly quickly because  they are
detectable by visual observation  and represent a correctable loss  of valuable
material, and create a potentially unhealthy work environment.
                                   3.2-1

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POTENTIAL
ADSORBER
u>
N3
I
LIP TOP
EXHAUST
                        RETRACTABLE
                        COVER
                                                               DIFFUSION AND
                                                                CONVECTION
                                                                                      CONDENSER
                                                                                      COILS
                                     Figure 3-10.  Open Top  Degreaser  Emission  Points

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3.2.2   Parameters Affecting Rate of VOC Emissions

        The rate of vapor emissions emanating from the various points pre-

viously discussed is dependent on a variety of operating and design para-

meters.  Emissions can be minimized by attempting to achieve certain optimum

conditions; however, it is important to understand the cause and effect

relationsiip.   The following parameters significantly affect VOC emissions

from open top vapor degreasers:

        o  Freeboard Ratio - The freeboard ratio is the ratio of the freeboard
           height to the width (not the length)  of the degreaser.   Manufacturers
           of degreasers generally size the equipment so that this ratio is at
           least 0.5 for the higher boiling solvents.  For solvents with lower
           boiling points, such as methylene chloride and trichlorotrifluoroe-
           thane, this ratio should be at least 0.75.

        o  Drafts - A fan or other air moving devices located in the work area
           near the degreaser can cause a draft to enter the freeboard area of
           the degreaser housing, thereby upsetting the interface and drawing
           vapors into the ambient air.

        o  Type of Work Load - Atmospheric emissions increase when the parts
           being processed in the degreaser contain numerous pockets or liquid
           traps that allow liquids to be carried from the degreaser chamber.

        o  Size of Work Load - If the cross-sectional area of the work is sub-
           stantial compared to the cross-sectional area of the vapor chamber,
           moving the work in and out of the degreaser will have a piston
           effect on the surrounding vapors; the resulting turbulence will
           cause excessive emissions.

        °  Mass of Work Load - If the work load is especially massive the heat
           required to bring the work to vapor temperature will be excessive.
           This will cause the vapor zone to collapse resulting in turbulence
           that will increase emissions.

        o  Solvent Heat Input - Once the solvent's boiling temperature has been
           achieved, increasing the heat input to the solvent will increase
           the rate of solvent vaporization.  If continued, the cool air
           blanket generated by the condenser coils may not be sufficient to
           retain the increased vapors and breakthrough could occur, resulting
           in greater emissions.

        o  Temperature and Flow Rate of the Cooling Water - The function of a
           condensing coil is to limit the upper level of the vapor zone.  A
           condenser consisting of a coil of pipe through which cooling water
           flows, creates a blanket of cool air.   The flow rate and temperature
           of  the water affect the efficiency of a given set of coils with a
           given heat input rate.   Increasing flow increases efficiency.
           Decreasing the temperature of the water will also increase the
           efficiency of the coils in supporting the vapor layer.
                                  3.2-3

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Work Rate - Moving the work into and out of the degreaser creates
turbulence that will result in the emission of vapors.   Turbulence
and the resulting emissions increase as the speed of the work in-
creases .

Location of Spraying - If spraying is conducted in a manner that
disrupts the vapor/air interface, emissions will increase.  Spray-
ing should be done below the vapor line; the spray should never
be pointed to allow liquid to be sprayed above the vapor line.

Water in the Solvent - If water is allowed to accumulate in the boil-
ing sump emissions may be increased in three ways:  (i) the water/
solvent vapor mixture has a lower density than pure solvent vapor and
thus has a greater tendency to be lost by diffusion, (ii) water com-
bines with the solvent to form a low boiling azeotrope that results
in a higher vaporization rate, and (iii) water is corrosive to de-
greaser surfaces and piping, thus making leaks a serious problem.
Water has a tendency to form acidic by-products with certain solvents,
especially 1,1,1 - trichloroethane and methylene chloride, further
exacerbating the corrosion problem.

Covers - The use of a cover during idle and down time virtually
eliminates diffusion losses during these periods.

Drying Time - After the work has been removed from the vapor zone
it may carry some condensed solvent out of the degreaser.  To
minimize these emissions the work should be allowed to dry for a
brief time (about 15 seconds) in the freeboard area.  Note, however,
that when the hot part rests just above the vapor level, it will
cause solvent laden air to heat up and rise, so the drying time
should not become excessive.

Lip Exhaust - If the degreaser is equipped with a lip exhaust, the
ventilation rate should not be excessive; otherwise, the exhaust
system may disrupt the air/vapor interface and actually  increase
emissions.
                        3.2-4

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  3.3     EMISSION  CONTROL METHODS
       The  EPA Control  Technology  Guideline  document  for  solvent  metal cleaning
  identifies  a number of control strategies  for  reducing  volatile organic emis-
  sions from  open  top vapor  degreasers.   These form the basis  for defining RACT
  for  these degreasers  and should  therefore  be the  focal  point of a field inves-
  tigation.   The CTG document  suggests two alternative control schemes.   Level  A
  represents  a relatively low  efficiency  system  consisting  primarily of  operating
  procedures  and has an estimated  efficiency of  45  (+15)  percent.   Level B
  consists  of Level A plus additional control and has a control efficiency es-
  timated at  60 (+15) percent.  These control methods are presented in Table  3-1.
  EPA's policy regarding the application  of  these control levels  is discussed in
  Chapter 1.   EPA  suggests that open top  vapor degreasers with an open area
  of less than one square meter be exempt from the  application of refrigerated
  chillers  or carbon adsorbers because these devices would  not be cost effective
  on such snail units.
      The safety switches  and  thermostat  recommended  in Control System B are
 the spray safety switch,  the  condenser flow switch and  thermostat.  The vapor
 level thermostat is not  included because it is  already required  by OSHA on
 "open surface vapor degreasing tanks".   The sump thermostat and  solvent level
 control discussed in Section  3.1.3 are used primarily to prevent solvent degra-
 dation and protection  of  the  equipment rather  than to prevent solvent emissions.
      Refrigerated chillers  should not  be confused with the condenser coils
 or water jacket;  rather,  the  chillers  are  an optional,  additional control device
 designed to minimize solvent  losses.   The  refrigerated  chiller consists of a
 second set of condenser  coils located  slightly  above the primary coils.
 Figure 3-11 depicts a  unit  with finned chiller  coils.   The function of the
 primary coils remains  as  in units without  freeboard  chillers, i.e. to control
 the upper limit of  the vapor  zone.  The  refrigerated freeboard chiller creates
 a sharper temperature  gradient than would  otherwise  exist.  The  resulting cold
 air blanket  reduces diffusion losses and the stable  inversion layer created
 by the increased temperature  gradient  decreases upward  convection of solvent
 laden air.
      Two types of chiller designs are  commercially available; one that operates
 below 0°C  and one that operates above  that  temperature.   Most manufacturers of
 degreasing equipment offer  both types, although there  is a patent* on the sub-
 zero  design.

*U.S.  Patent  3,375,177  issued  to Autosonics, Inc.,  March 26, 1968
                                     3.3-1

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                                      TABLE  3-1


        COMPLETE  CONTROL  SYSTEMS FOR OPEN  TOP VAPOR DEGREASERS


Control System A

Control Equipment:

     1.  Cover that can be  opened and closed easily without disturbing the vapor zone.

Operating Requirements:

     1.  Keep cover closed  at  all times except  when processing work loads through
         the degreaser.

     2.  Minimize solvent carry-out by the following measures:

         a.  Rack parts to  allow full drainage.
         b.  Move parts in  and out of the degreaser at less than 3.3 m/sec.(ll ft/min).
         c.  Degrease the work load in the vapor zone at least 30 sec. or until
             condensation ceases.
         d.  Tip out any pools of solvent on the cleaned parts before removal.
         e.  Allow parts to dry within the degreaser for at least 15 sec. or until
             visually dry.
     3.  Do not degrease porous or absorbent materials, such as cloth, leather, wood
         or rope.

     4.  Work loads should  not occupy more than half of the degreaser's open top area.

     5.  The vapor level should not drop more  than 10 cm (4 in.) when the work load
         enters the vapor  zone.

     6.  Never spray above  the vapor  level.

     7.  Repair solvent leaks  immediately, or  shutdown  the degreaser.

     8.  Do not dispose of  waste solvent  or  transfer it to another party such that
         greater than 20 percent of  the waste  (by weight) will evaporate into the
         atmosphere.  Store waste  solvent only in closed containers.

     9.  Exhaust ventilation should not  exceed 20 m /min. per m   (65 cfm per ft )
         of degreaser open area, unless necessary to meet OSHA requirements.  Ventilation
         fans should not be used near the degreaser opening.

    10.  Water should not  be visually detectable in solvent exiting the water separator.

Control System B

Control Equipment:

     1.  Cover  (same as in system A).

     2.  Safety switches.

         a.   Condenser flow switch and thermostat -  (shuts  off sump neat  if condenser
              coolant is either not circulating or too warm).
         b.   Spray safety switch - (shuts off spray pump  if  the vapor  level drops
              excessively,  about 10 cm (4 in).

     3.  Major  Control Device:

         Either:  a.  Freeboard ratio greater than  or  equal to 0.75,  and  if the degreaser
                      opening  is >lm  (10 ft ), the  cover  must be powered,
                  b.  Refrigerated chiller,
                  c.  Enclosed design (cover or door  opens only when  the  dry  part  is
                      actually entering or exiting  the degreaser),                2
                  d.  Carbon adsorption system, with  ventilation  >15  nrVmin per m
                       (50 cfm/ft2) of air/vapor area (when cover  is open), and exhausting
                      <25 ppm  solvent averaged over one complete  adsorption cycle, or
                   e.  Control  system, demonstrated  to have control efficiency,  equiva-
                      lent  to  or better than any of  the above.

     4.  Permanent,  conspicuous label, summarizing operating procedures #1 to #6.

 Operating  Requirements:

     Same  as  in System A

                                      3.3-2

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     The recommended operating temperature for below freezing chillers is
-30 to -25°C.  The cold coils attract moisture as does a dehumidifier.  There-
fore, the designs include a defrost cycle to remove frost from the coils and
restore heat exchange efficiency.  The defrost cycle operates approximately
hourly, requiring only a few minutes to melt the accumulated ice and slush,
which is collected in the condensate trough and poured through the water
separator.  Water contamination of the solvent can have an adverse affect on
water soluable stabilizer systems and can contribute to equipment corrosion.
Therefore, on some units, the material condensed from the chiller coils may
be diverted to a different water separater.
     The operating temperature of above freezing chillers should not exceed
5°C.  These units are normally designed to achieve a minimum of 500 Btu/hr
cooling capacity per foot of air/vapor interface perimeter.   The sub-freezing
units are normally designed in the range of 200-600 Btu/hr per foot of peri-
meter,  depending on the width of the degreaser.
                                  3.3-3

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                                          CHILLER
PRIMARY COILS
                                                              FREEBOARD
                                                              WATER JACKET
                   Figure 3-11.  Refrigerated  Freeboard  Chiller
                                      3.3-4

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 3.4    INSPECTION PROCEDURES
     The following paragraphs discuss two types of inspections:   (1)  field
 review and  (2) office review.  Source sampling, still another form of inspec-
 tion, will  be discussed in Chapter 5.
     Field  investigations range from brief plant visits to thorough inspections
 and testing programs that produce a complete data base for enforcement proceed-
 ings.  Office reviews rely on the source to furnish information through written
 material such as permit applications and responses to Section 114 inquiries.
 This approach may require less time and manpower but the resulting data base
 is generally less complete.  Office reviews, however, provide a useful screen-
 ing tool in those cases where there is a large number of potential violators.
 3.4.1  Field Inspections
     After  becoming familiar with the plant and its facilities, the inspector
 should request that the appropriate company official give him information from
 company records that will allow the inspector to begin completing the worksheets
 shown in Figure 3-12. The data may also be available from permit applications.
 The worksheet divides the required data into two categories:  control equip-
 ment and operating requirements.  It also provides the RACT requirements for
 each category with a suggested inspection procedure.   With such information,
 direct comparisons can be made between the RACT requirements and observed
 practices.
     Generally, the inspector would next request the company's assistance in
 conducting  a full inspection of the facility in order to verify the actual
 operating conditions.  This inspection may take several hours depending on the
number and  types of open top vapor degreasers.   The inspector must collect
 information that will allow him to complete the inspection worksheet.   All
 field data, such as temperature of the coolant, exhaust flow rate, etc.,  should
be observed and verified by the air pollution inspector.   For equipment that
is operating,  the inspector must be prepared to collect this data with his own
resources.
     This information will be compared to the data given by the company official,
and the total  data base will be compared to the RACT  requirements for  control
equipment and  operating conditions to determine if a  violation exists.  At that
time,  a reinspection date should be established if it is  determined that  the
source is not  in compliance.
                                   3.4-1

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                                              FIGURE  3-12
                          EXAMPLE  WORKSHEET FOR  FIELD  INSPECTION  OF
                                      OPEN  TOP VAPOR DEGREASERS
1.  BUSINESS  LICENSE NAME OF CORPORATION,  COMPANY,  OR  INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY:
 2a. MAILING ADDRESS:
                                                     2b.   PLANT ADDRESS WHERE THIS DEGREASER IS LOCATED:
3.  SOURCE NO.   (PERMIT NUMBER, NEDS ID, ETC.)
4.  NAME AND  TITLE OF COMPANY REPRESENTATIVE:
5.   TELEPHONE NO.:
6.   NAME OF OFFICIAL CONDUCTING INSPECTION:
7.   DEGREASER
         MANUFACTURER:
                                               MODEL NO.
         INSIDE DIMENSIONS OF TANK (FT.):_
            WIDE X
                         _SERIAL N0._
                          LONG X
                                           DEEP
8.   TITLE AND  CODE NUMBERS OF DRAWINGS, SPECIFICATIONS,  STANDARDS, CODES, PROCEDURES AND  DOCUMENTS USED WITH
    THE INSPECTION
9.  TYPE OF SOLVENTS IN USE (SPECIFIC NAME AND MANUFACTURER):
                                       INSPECTION OBSERVATIONS
    RACT REQUIREMENTS
SUGGESTED INSPECTION
     PROCEDURE
                                                                                   FIELD
                                                                                OBSERVATIONS
    CONTROL EQUIPMENT

1.  Lid
                                         Observe if  a  lid is in-
                                         stalled and if  it is used
                                         during idling and downtime.
                                         Observe if  opening and
                                         closing the lid disturbs
                                         the vapor zone.
2.  Safety Switches
      a.   Condenser flow
          switch  & thermo-
          stat
Confirm that the switch
and thermostat have been
installed.

If available, check read-
ings of flow and tempera-
ture indicators.  For high
boiling solvents,  the temp-
erature should be about 8°
to 11°C (15° to 20°F) above
dewpoint of surrounding
atmosphere or 32° to A6°C
(90° to 115°F).  For low
boiling solvents (methy-
lene chloride and fluoro-
carbon 113) the exit temp-
erature should be less than
29°C (85°F).  Many installa-
tions may not have a temper-
ature indicator at the cool-
ing coil exit.  A rough es-
timate of the temperature
may be made if a bleed valve
is available at the exit end
of the coils.  Bleed a sample
of coolant into a small vessel
and measure the temperature
with a portable thermometer.

If plant is agreeable,
interrupt flow of coolant
and determine if switch is
tripped.
                                                3.4-2

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                                               FIGURE  3-12

                                               (Continued)
     RACT REQUIREMENTS
                                           SUGGESTED INSPECTION
                                               PROCEDURE
                                                      FIELD
                                                  OBSERVATIONS
      b.
          Spray safety
          switch
 Confirm that the switch
 has been installed.
3.   Major Control  Devices
      a.   Freeboard  ratio
          greater  than  0.75.
      b.   If  the  degreaser
          area  is greater
          than  1.0m2  the
          cover must  be
          powered.
     c.  Refrigerated
         Chiller
     d.  Enclosed Design
 Measure the height of the
 freeboard and the width of
 the tank; calculate the
 ratio.

 (Measurements usually can
 be made externally to
 avoid creating emissions
 and breathing solvent
 vapors.  Otherwise, obtain
 the measurements from
 shop drawings).   Measure
 the length of the tank and
 calculate the degreaser
 area.   Observe if the
 cover is powered.

 Unless observed  during
 the defrost cycle, sub-
 zero chillers should be
 coated with frost or
 slush.  The indicated
 temperature of the coolant
 should not exceed -25°C
 (-13°F).   Do not attempt
 to extract a sample of
 coolant from a refrigerated
 chiller.

 For above freezing chillers
 the coolant temperature
 should not  exceed 5°C
 (40°F).

Determine the cooling capacity
from the design specifications.

oo  For subzero
    chillers the
    minimum cooling
    capacity should be
    as follows for each
    degreaser width:
    (The cooling  units
    are Btu's per hour
    per foot of perimeter.)
    <3.5 ft - 200
    >3.5 ft - 300
    >6   ft - 400
    >8   ft - 500
   >10   ft - 600
oo  For above freezing
    chillers the  cooling
    capacity should be
    at least 500  Btu/hr
    per foot of perimeter.

 Observe that the cover or
 doors  are open only when
 the dry part is  entering
 or exiting the degreaser.
                                                    3.4-3

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                                                FIGURE  3-12
    RACT REQUIREMENTS
                                                (Continued)
    SUGGESTED INSPECTION
         PROCEDURE
   FIELD
OBSERVATIONS
      e.   Carbon Adsorber
                                      o   If the degreaser is equipped
                                          with an adsorber solvent odors
                                          should not be detectable on
                                          the roof downwind from the
                                          stack.

                                      o   See the source testing
                                          section in this manual.
OPERATING REQUIREMENTS

1.  Keep cover closed
    except while process-
    ing work loads.
 o  Observe the operation.
2.  Minimize solvent carry-
    out by the following
    measures:
      a.  Rack parts to
          allow full drain-
          age.
      b.  Move parts in
          and out of de-
          greaser at less
          than 3.3 m/sec
          (11 ft/min).
      c.  Degrease parts for
          at least 30
          seconds or until
          condensation stops.
      d.  Tip out pools of
          solvent on the
          cleaned parts be-
          fore removal.
      e.  Allow parts to
          dry within the
          degreaser for at
          least IS seconds
          or until visually
          dry.
 o  Observe how the parts are
    racked.

 o  Using a stopwatch, time
    the vertical movement of
    parts over a measured
    distance.

 o  Observe this operation
    and time  it if necessary.
 o   Observe this operation.
 o   Observe this operation,
    time it if necessary.
3.
    Do not degrease porous
    or absorbant materials.
    Note the nature of the
    materials being cleaned.
    Baskets should not have
    rope or leather handles.
4.  Work loads should not
    occupy more than half
    of the degreasers open
    top area.
0   Observe the size of the
    work load.   Measure it if
    necessary and compare it
    to the open top area.
    The vapor level should
    not drop more than 10 cm
    (4 inches) when the
    work load enters the
    vapor zone.
    Observe this operation and
    estimate the drop in the
    vapor level.
6.
    Never spray above the
    vapor line.
°   Observe this operation.
7.  Repair solvent leaks
    immediately or shut
    down the operation.
0   Look for leaks around  the
    degreaser.   Note especially
    the solvent spray pump and
    line,  piping,  the external
    sump drain  valve (if so
    equipped) and  the water
    separator.
                                                   3.4-4

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FIGURE 3-12
(Continued)
RACT REQUIREMENTS

8. Do not dispose of
waste solvent or
transfer it to
another party such
that greater than
20 percent of the
waste (by weight)
can evaporate
into atmosphere.
Store waste solvent
only in covered con-
tainers.
9. a. Exhaust ventilation
should not exceed
20m3 /min per m2
(65 cfm per ft2) of
degreaser open area
unless necessary to
meet OSHA requirements.











b. Ventilation fans
should not be
used near degreaser
opening.
10. Water should not be
visually detectable
in solvent exiting
the water separator.

11. Permanent, conspicuous
label, summarizing
operating procedures
#1 to #6 above.
SUGGESTED INSPECTION
PROCEDURE
° Determine if source has
inhouse reclamation
facilities (i.e. still)
or a service contract
with a solvent reclamation
firm.

o Confirm that storage is
done with covered con-
tainers by visual inspec-
tion. Note whether con-
tainers leak.
° Determine the air handling
capacity of the fan,
-or-
If sampling ports are
available, the velocity of
the exhaust gases may be
measured with a swinging
vane velocity meter. Also
determine the cross-sectional
area of the duct, then cal-
culate the cfm.
o After the air volume is
determined from either of
the above methods, obtain
the area of the degreaser
opening and calculate the
cfm per square foot of
degreaser opening.
o Note the location of ven-
tilation fans near the
degreaser .

o This solvent Is normally
returned to the degreaser
sump, or if so equipped,
to the warm rinse tank.
This solvent should be clear.
o Confirm the presence of
this label.


FIELD
OBSERVATIONS











































  3.4-5

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3.4.2  Record .Review
       Determining compliance of open top vapor degreasers through field inspec-
tions and monitoring is expensive and time consuming due to the large number of
degreasers in use.  It requires a great deal of manpower and tends to limit the
number of sources that can be reviewed in a given year.   The review of company-
furnished records through questionnaires or letter requests may provide a
viable alternative to field inspections and source monitoring activities for
compliance determination.  At minimum, this approach should be considered as
a screening tool to identify candidate sources for comprehensive field inspec-
tions, thereby increasing the effectiveness of the available resources.
       This discussion outlines several procedures that may be used when imple-
menting a record review.  Information will be required from the plant concerning
the design and operation and maintenance of the equipment.
3.4.2.1  Review of Design, Operation, and Maintenance Data
       The first requirement of this procedure is the development of standard
questionnaires that can be sent out as part of a Section 114 request to the
applicable sources.  The type of information required is similar to what is
identified on the inspection forms illustrated in Figure 3-12. It is important
that the source understand what is being requested because the entire process
of making compliance judgments using this procedure is highly dependent on
the reliability of the information being furnished.
       An example questionnaire is provided as Figure 3-13 and should be used
as a guide only.  It is  suggested that the agency develop its own form which
is specific to their program.  For example, a screening program designed to
identify major emitters  may only require key data, while a more extensive
request is necessary if  compliance determinations are to be attempted.  Three
types of data are suggested for review:  control equipment information, opera-
tional information, and  maintenance records.  The design data should be readily
available, while  operational and maintenance may require the  source to create
a special logging system in order to  comply with the agency's request.
       Criteria  for review of  the data should be established  prior to  finalizing
the questionnaire.  Obviously  the criteria will address the overall objectives
of the review program  (e.g., screening program or compliance  determination).
In general, however, the design data  should be compared to  the  original construc-
tion  permit and  design  specifications and be at least as  stringent as  RACT.
                                    3.4-6

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                                                 FIGURE  3-13
                                      U.S. ENVIRONMENTAL PROTECTION AGENCY

                                                OPEN TOP VAPOR
                                               DEGREASER SUMMARY

                          ONE COPY OF THIS FORM MUST BE FILLED OUT FOR EACH DEGREASER
 1.  BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY:
 2a. MAILING ADDRESS:
              2b.  PLANT ADDRESS WHERE THIS DEGREASER IS LOCATED:
 3.  SOURCE NO.  (PERMIT NUMBER, NEDS ID, ETC.):
 4.  DEGREASER

        MANUFACTURER:
                                                               MODEL NO.
                                                                                        SERIAL NO.
        INSIDE DIMENSIONS OF TANK (FT.):
       WIDE X
                      LONG X
                                      DEEP
        CONVEYORIZED:   YES [   |   NO \   \   IF YES,  GIVE CONVEYOR SPEED: 	fps

        TYPE OF DECREASING:  COLD SOLVENT CLEANING  |   [    VAPOR DECREASING |    |
 5.  TYPE OF VAPOR LEVEL CONTROLS:

        THERMOSTAT |   |    CONDENSING COIL  |   I  CHILLED WATER OR REFRIGERANT |    [    NONE
 6.  METHOD OF HEATING DEGREASER:

        GAS  |   t  ELECTRIC |   |  STEAM |   |  Btu/hr._
                                OR  KW
 7.  CLEANING ACTION:

        SONIC |   [     IMMERSION IN LIQUID 1   |     MECHANICAL MIXING |   f     VAPOR CONDENSATION I   )

        SPRAY |   |     SPRAY PUMP H.P.  	     OTHER]  [
 8.  TANK COVER:

        AUTOMATIC COVER |   |        MANUAL COVER |    I     NO COVER(  |

        TANK COVERED WHEN NOT IN USE:        YES |    |     NO |   [
 9.  QUANTITY OF SOLVENTS USED:
     (Do not include quantities  of used solvent sent  back to supplier.)
     a.  CARBON TETRACHLORIDE
     b.  PERCHLOROETHYLENE
     c.  METHYLENE CHLORIDE
     d.  1,1,1 -TRICHLOROETHANE
     e.  TRICHLOROETHYLENE
     f.  OTHER (IDENTIFY)
       _55-GALLON DRUMS PER MONTH
       _55-GALLON DRUMS PER MONTH
       _55-GALLON DRUMS PBR MONTH
       J5-GALLON DRUMS PER MONTH
       _55-GALLON DRUMS PER MONTH
        55-GALLON DRUMS PER MONTH
10.  OPERATING SCHEDULE:

        HOURS /DAY	
DAYS/WEEK
WEEKS/YEAR
11.  DESCRIBE METHOD FOR DISPOSING OF SPENT SOLVENT:
                                                    3.4-7

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This would include such items as exhaust ventilation rates, types of safety
switches, and cover design.  Operational information should be compared to
operating permits and operational specifications defined as RACT in the CTG.
These parameters would include the use of powered or unpowered covers, the
quantity and type of parts being cleaned, the method of waste solvent disposal,
and the actual ventilation rates.  Maintenance records should include repair
or replacement records, recalibration schedule of temperature sensors, and
some statement as to the general condition of the equipment.
3.4.2.2  Review Waste Solvent Disposal Procedures
       A description of waste solvent disposal methods used by the source must
be requested in the questionnaire initiated by the agency (example shown in
Figure 3-13).  A comparison should be made with the RACT operating requirements
("not greater than 20 percent can evaporate into the atmosphere"), and other
acceptable practices which are readily available.
       On larger open top vapor degreasers where greater quantities of solvent
are used, it becomes economical to install a solvent distillation still for
solvent reclamation.  On installations of this type, both the sludge and sol-
vent are pumped to the solvent still where the solvent is reclaimed.  The
liquid is heated to its vaporization temperature and the resulting vapors flow
into a chilled condensing chamber where the vapors condense back to liquid.
The liquid is then circulated back to the degreaser for further use.  In this
type of operation, only make-up liquid solvent is added, as needed.  If
properly designed and operated, the still should produce a sludge that contains
less than 20% solvent by weight.  Disposal of the sludge may be subject to
hazardous waste disposal regulations.  EPA has proposed regulations governing
the disposal of such material in the Federal Register at 43FR58946 (December 18,
1978).
   There are alternative approaches to an inhouse still, such as service con-
tracts with outside agents which may be more attractive to the source and
will also meet the RACT requirements.
                                   3.4-8

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                               CHAPTER 4
                          CONVEYORIZED DEGREASERS
 4.1       PROCESS DESCRIPTION
 4.1.1     Unit Operation
          Conveyor operated solvent degreasers provide an efficient and econo-
 mical method for preparing clean, dry articles for subsequent finishing or
 fabricating.  There are several types of conveyorized degreasers and each can
 operate with either cold  or vaporized solvents.  The basic steps found in the
 typical conveyorized vapor degreaser include a vapor rinse upon entry to the
 degreaser vapor space section, liquid immersion, liquid spray, vapor rinse,
 and, finally, a slow withdrawal through a cold air space drying area.
          A nonflammable  solvent contained in the lower area of the de-
 greaser, referred to as the boiling sump, is boiled to produce a vapor zone,
 the height of which is controlled by cooling coils installed above the vapor
 zone.  The "cold work" introduced into the vapor space of the degreaser must
 be at a temperature lower than the vapor zone, in order to cause the solvent
 vapors to condense on the work surfaces and flush the oil and other foreign
 matter off with the liquid condensate.  The removed material accumulates in
 the boiling sump and only the pure vapor comes in contact with the work load.
 Vapor flushing is followed by pure solvent spray and/or liquid immersion.
 The cool, pure solvent reduces the temperature of the work surface below the
 vapor temperature, producing a second vapor condensation flushing action on
 the work surfaces.  When the work pieces are removed from the vapor zone,
 they should be clean, dry, and ready for further processing.
          A well-operated conveyorized vapor degreaser should provide the re-
 quired cleansing action and confine the solvent and solvent vapors, thereby
maintaining a healthful working environment.
 4.1.2     Types of Conveyorized Degreasers
          Conveyorized degreasers are generally large, automatic units de-
 signed to handle a high volume of work in either a straight-through process
or a return type process in which the work pieces enter and leave the
degreaser unit from the same end.   Their use minimizes the human element and
produces consistently high quality cleaning with minimum solvent losses.   As
indicated earlier,  there are several basic designs which are  termed conveyor-
ized degreasers:   gyro,  vibra,  monorail,  cross-rod,  mesh belt and strip
cleaners.   Figures 4-1 to 4-4 present a sketch of each design (with the excep-
                                  4.1-1

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WORK BASKET
   B°N-ING  CHAMBER
                                                         GEAR TO

                                                         TUMBLE  BASKETS
                 Figure 4-]a.
                                   Degreaser
       ASCENDING
       VIBRATING
       TROUGH   '

     WORKLOAD
     ENTRY CHUTE


     STEAM COILS
  WORKLOAD

  CHUTE  RGI

iAj-^-wga
CONDENSERS
                                        COUNTERROW WASH
                          4.1-2

-------
                   CONVEYOR
                   PATH
-p-
l->
                                     SPRAY
                                     PUMP
                                                     BOILING
                                                     CHAMBER  J
                                                                    WATER
                                                                    JACKET
                                              Figure  4-2.  Monorail Degreaser

-------
                                                                               CROSS-RODS
4>
h-1
                     CONVEYOR
                     PATH
                    CHAIN
                    SUPPORTS
                      WORK
                      BASKET
                                WATER
                                JACKET
BOILING CHAMBER
                                         Figure  4-3. Cross-Rod Degreaser

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                 CONVEYOR
                 PATH
H-
I
                                    BOILING
                                    CHAMBER
                                                                                                MESH
                                                                                                BELT
                                        Figure 4-4.  Mesh Belt Conveyorized Degreaser

-------
tion of the strip cleaner type).  A brief discussion of the rationale for
each system follows:

          °  Gyro (ferris wheel) type degreasers permit the operator to load
             and unload the baskets from one work station.  The design is simi-
             lar to the cross-rod degreaser.  It is one of the smallest con-
             veyorized degreasers available.

          o  Vibra type degreasers are used for high production rate applica-
             tions where the work pieces are small.  The work piece is dipped
             into solvent, and rises on a spiral vibrating elevator through a
             counter-flow rinsing action of clean solvent vapor.  Cleaning
             action is accomplished by the combination of vibration, solvent
             dip, and solvent vapor condensation.

          o  Monorail conveyor systems are used for high production of stan-
             dardized work pieces and are generally found in facilities that
             use monorail systems to transport materials within the plant.
             The monorail can be a straight through type, carrying parts in
             one side and out the other, or can turn 180° and exit the material
             through a duct that is parallel and adjacent to the entrance.

          o  Cross-rod conveyorized units are generally used for processing
             small or irregular parts.  A rod placed between two power-driven
             chains carries parts within suspended pendant baskets or per-
             forated cylinders.  The cylinders are rotated to provide the
             tumbling action required to clean and drain the crevices in
             the work pieces.  The pendant baskets do not rotate and are
             used to carry small parts that do not require this action for
             cleaning and draining.

          o  Mesh belt and strip cleaner degreasers are similar in design;
             however, the mesh belt degreaser carries the material to be
             cleaned while the other draws the material through.  The latter
             design is used for sheet metal products.  A continuous strip of
             material is drawn through tha unit for cleaning prior to coating
             or fabrication processes.  Mesh belt degreasers are used for
             smaller parts and allow for rapid loading and unloading of
             material.

4.1.3     Operation of Degreaser Components

          Continuous conveyorized degreaser systems are straight forward in
design.  Although there are several types of conveyorized degreasers, they

share common design characteristics.  A typical unit, shown in Figure 4-5,

consists of several components;  a conveyor work piece transfer system to

carry the work pieces through the degreaser, a bottom sludge sump, a solvent

boiling sump with heating coils, and a vapor space above the boiling sump.

Over the solvent vapor space and around the inner-periphery of the degreaser

housing are cooling  coils designed to maintain a temperature that will con-

dense the vapors.  Upon return to a liquid btate, the solvent flows down to

the boiling sump.  The freeboard area above the primary condensing coils is

designed to be of sufficient height to retard convection and diffusion losses

                                    '4.1-6

-------
                                                        HOOD
                                                        PARIS
                                                        BASKET
                                                       CROSSBAR
                                                       CONVEYOR
                                                   	CONDENSING
                                                   fT~ COILS
                                                     /WATER
                                                        SEPARATOR
                                                        CONDENSATE
                                                        RETURN


                                                         BOILING
                                                         SUMP
     Z
        STEAM
L
  OVERFLOW
Z
  STEAM
Figure 4-5.  Liquid-Liquid-Vapor Cross-Rod Degreaser
                          .1-7

-------
to the atmosphere.   Brief descriptions of  the  primary components  are provided

to familiarize the  inspector with their operation.

          o  Hood and Exhaust System - Unlike  cold  cleaners  or  open top
             cleaners, conveyorized degreasers do not require access to  the
             product for manual handling.   Therefore, they are  generally
             enclosed units with a hood and exhaust system.  The  ventilation
             rate is established at a level sufficient to remove  vapors  from
             the enclosures; however, excessive rates may induce  greater
             emissions.

          o  Solvent Sump and Sludge Sump  - The solvent sump is in the bottom
             section of  the conveyorized degreaser  and includes heating  coils
             for vaporizing the liquid solvents.  The solvent sump is also
             referred to as the solvent boiling area or chamber.   The solvent
             sump includes solvent storage, a  liquid level sight  glass,  heat-
             ing coils and elements, sump  safety thermostat  controls, and
             an automatic shut-down switch. The primary adjustment affecting
             the bath evaporation rate is  the  heating and cooling balance.
             The heating rate must be sufficient to maintain the  desired vapor
             level  as cold parts enter the vapor zone.   The  vapor level  control
             thermostat  will sense hot vapors  rising above the  design opera-
             ting level  and turn off the sump  heater.

             The sludge  sump is usually located in  the lower section of  the
             solvent sump.  It generally contains either a cleanout drain valve
             or a cleanout door.

          o  Work Opening - Work openings  include the entry  and discharge
             points.  The work entry must  be adequate for the work being pro-
             cessed but  should be kept to  a minimum to control  vapor loss.
             Drying tunnels as shown in Figure 4-6  are used  at  the exit  of the
             conveyorized degreaser, and are designed to provide  additional
             time for parts to dry.  A drying  tunnel is an extension of  the
             hood,  enclosing the exiting conveyor for some distance (i.e. 2
             to 10+ feet) from the degreaser.   Its  length and physical dimen-
             sions  are dependent on the size of the part to  be  cleaned,  the
             type of solvent and the required  residence time to fully dry the
             individual  parts.  Even when  the  unit  is controlled  and no  work
             passes through the entry and  discharge ports, every  square  foot
             of opening presents a potential for vapor losses.  In some  in-
             stances, additional covers are employed during  shut-down hours
             to prevent  unnecessary emissions.

          o  Conveyor System - Although the conveyor configuration varies for
             each type degreaser included  in this group, the design concept
             is similar.  Conveyors are designed to carry the cold part  into
             the vapor chamber and out the other end.  The product is generally
             suspended by hooks or carried in  baskets which  are attached to
             the conveyor.  The mechanism  for  transporting material in the
             vibra  type conveyor is slightly different; a vibrating tray is
             employed to move the material. The rate of movement is critical
             for sufficient contact and drying time; however,  it  also impacts
             on the degree of vapor loss to the surrounding  area.  In addition
             to the rate, the quantity of  material  being processed is another
             consideration.  Too large a load  may cool down  and collapse the


                                   4.1-8

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         TO  ADSORPTION  DEVICE
         OR  ATMOSPHERE
                                         SOLVENT
                                         SPRAY PUMP
BOILING SUMP-/

            STEAM
SOLVENT SPRAY
RESERVOIR
                                                                      I

                                                                     k
                                                            DECREASED! \
                                                            PART      y
                                                            CONDENSING
                                                            COIL
                                                             WATER JACKET
                            CONDENSATE
                            TROUGH
                  Figure 4-6.  Typical  Emission Points

-------
   vapor zone.

   The load size is also dependent on the geometry of pieces being
   cleaned because greater quantities of crevices and surface areas
   will require more time for drying.  (Rotating baskets would
   normally be used to turn the product around and dislodge some
   of the trapped liquid solvent.)

o  Condensing Coils - Condensing (cooling) coils are installed on the
   inside edges of the conveyorized degreaser.  The coils define the
   vapor/air interface.   They are usually coils consisting of four or
   more pipe coils stacked one above the other and located directly
   over a condensate trough.   The condensing coils include a temper-
   ature gauge, a temperature control thermostat, and a high temper-
   ature shut-down switch.

o  Water Jacket- A water jacket, where applicable, is installed on
   the exterior of the degreaser and consists of a box section to
   contain cooling water circulating around the degreaser in the
   same approximate area as the cooling coils.  The water jacket
   is also referred to as the freeboard cooler.  Its function is to
   prevent convection of solvent vapors up hot degreaser walls.  In
   addition, it reduces "sidewall radiation", which can increase
   air turbulence and thus disturb the cold air blanket in the free-
   board area.  Water jackets and condensing coils should not be
   confused with each other or with refrigerated chillers.  Chillers
   are sometimes used in addition to these units in order to increase
   vapor control efficiency.

o  Freeboard - Freeboard is that area above the cooling coils extend-
   ing to the top of the conveyorized degreaser.  The freeboard zone
   permits drainage and drying of the work pieces, thereby minimizing
   solvent loss and air pollution.  The freeboard zone reduces vapor
   disturbances caused by air motion in the work area.

o  Piping and Sprays - There is a minimum amount of piping included
   in the degreaser.  Leaks should not be tolerated because they
   represent a source of emission and a loss of valuable material.
   Drain valves are generally found at the lowest point in the tank.
   Piping that is under pressure, such as the spray line, is a
   potential source of leaks.  Sprays should be operated within
   the vapor zone so as to not disturb the air/vapor interface.
   Some designs spray the material in a contained chamber within
   the degreaser.  A spray safety switch is generally provided to
   shut off the spray pump when the vapor level drops below the
   design level.

o  Water Separator - Water enters a degreaser from several sources,
   i.e., condensation of atmospheric moisture on condenser coils,
   moisture on work pieces being processed, and steam or cooling
   water leaks.  Water forms a low boiling azeotrope with the sol-
   vent and is vaporized.  Most degreasers are equipped with a water
   separator because uncontrolled water causes corrosion, shortens
   solvent life, and increases the vaporization rate of solvent.
   The condensed solvent-water mixture drops into the condensate
   trough below the condenser coils and flows by gravity to the
   separator.

                         4.1-10

-------
Waste Solvent Disposal - Although there are several methods for
disposing of waste solvent, most current practices of dumping are
unacceptable.  The preferred treatment would be the use of recla-
mation services to be accomplished internally or by outside vendors.
Where applicable, direct incineration and chemical landfills are
also viable alternatives.  Reclamation using solvent recovery
stills has the greatest appeal for large users because it repre-
sents a savings of valuable material.
                     4.1-11

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4.2       ATMOSPHERIC EMISSIONS

4.2.1     Emission Points
          There are several locations in a conveyorized degreaser that may
allow organic liquid or vapor to escape to the atmosphere.  These are iden-
tified in Figure 4-6.  In general, conveyorized degreasers are hooded and
vented to the outside.  Therefore, an emission point is the vent line and
subsequent exhaust.  In most instances, a control device such as a carbon
adsorption system is placed in the line to remove organic vapors.  Although
constant ventilation of the hood should create a negative pressure and pre-
vent vapors from escaping from the work openings, ventilation rates are kept
                                   2
to a minimum level (< 65 cfm per ft  of degreaser opening) to prevent dis-
ruption of the vapor-level boundary and corresponding increased emissions.
However, in minimizing the ventilation rate, the opportunity for vapors to
escape from the work openings increases at the inlet (Location 2) and exit
(Location 3) of the degreaser.  In addition, at the exit of the unit the cleaned
material may be carrying out liquid organic material which condensed on its
surface but did not totally dry or drip off while in the degreaser.
          As the solvent material is spent and itself becomes contaminated with
impurities, its usefullness decreases.  Most conveyorized degreasers are designed
to distill and recycle this material on a continuous basis through the use of
external stills.  However, these stills will eventually accumulate wastes and,
depending on the method of disposal, waste solvents may enter the atmosphere
at this point.
          Fugitive emissions can occur at any of the piping connections or sump
seals that may have loosened or become worn because of continuous operation.
Where good housekeeping practices are followed, these emission points are elimi-
nated fairly quickly because they are detectable by visual observation, repre-
sent a correctable loss of valuable material, and create a potentially unhealth-
ful work environment.
                                 4.2-1

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4.2.2      Parameters Affecting Rate of VOC Emissions

           The rate of vapor emissions emanating from the various points pre-

viously discussed is dependent on a variety of operating and design para-

meters.  Emissions can be minimized by attempting to achieve certain optimum

conditions; however, it is important to understand the cause and effect

relationship.   The following parameters significantly affect VOC emissions
from conveyorized degreasers:

           o  Drafts .- A fan or other air-moving devices located in the work
              area near the degreaser can cause a draft to enter the freeboard
              area of the degreaser housing, thereby upsetting the balance of
              the air/vapor interface.

           o  Size of Work Opening - Although conveyorized degreasers are
              generally covered, the size of the opening allowing work loads
              to enter and exit should be kept to a minimum to reduce the
              opportunity for vapors to escape.  The term "average silhouette
              clearance" is used to define the distance from the edge of the
              degreaser opening to the part or the basket or cage conveying
              the part.  Where hoods are exhausted, the smaller the opening
              the greater the capture velocity of the room air traveling
              through the area and the greater the control of vapors escaping
              at this point.

           o  Exhaust Rate - The greater the exhaust rate, the greater the
              control of vapor escaping from the work openings; however, an
              excessive exhaust rate also produces greater emissions because
              it disturbs the vapor and air interface within the degreaser,
              thereby exhausting high concentrations of organic vapors into
              the exhaust gas stream.  To achieve both goals the exhaust rate
              should not exceed 20 m-Vmin per m^ (65 cfm per ft ) of degreaser
              opening.

           o  Conveyor Speed - As the conveyor speed increases, emissions in-
              crease.  Increased speeds represent less time for the material
              to dry.  Therefore, evaporation of the liquid droplets that ori-
              ginally condensed on the cold material will take place outside
              the hooded portion of the degreaser and will increase emissions.
              Too rapid a conveyor speed may also induce drafts that will
              create vapor loss at the outlet work opening.  Conveyor speeds
              must be maintained below 3.3 m/min (11 ft/min) to minimize
              losses.

           o  Type and Magnitude of Load - Atmospheric emissions increase when
              the parts being processed in the conveyorized degreaser contain
              numerous pockets or liquid traps that allow liquids to be carried
              from the degreaser chamber.  Liquid trapped in pockets can be re-
              moved by placing the working pieces in baskets which are rotated
              and tumbled as they move through the degreaser so that they drain
              liquid solvent back to the sump.  Increases in the magnitude of
              the work load will cool the vapor area.  A massive load may cause
              a collapse of the vapor space and increase emissions.  When the
              vapor space collapses two situations arise, (1) the vapor/air
                                     4.2-2

-------
layers mix and organic vapors escape and (2) the working pieces
spend less time within the collapsed vapor space and therefore
have less time to evaporate the condensed solvent, resulting
in greater carry out and subsequent emissions.

Solvent Heat Input - Once the solvent's boiling temperature
has been achieved, increasing the heat input to the solvent
will increase the rate of solvent vaporization.  If continued,
the cool air blanket generated by the condenser coils may not
be sufficient to retain the increased vapors and breakthrough
could occur, resulting in greater emissions.

Temperature and Flow Rate of the Condensing Coils - The function
of a condensing coil is to limit the upper level of the vapor
zone.  A condenser consisting of a coil of pipe through which
cooling water flows, creates a blanket of cool air.  The flow
rate and temperature of the water affect the efficiency of a
given set of coils with a given heat input rate.  Increasing
flow increases efficiency.  Decreasing the temperature of the
water will also increase the efficiency of the coils in support-
ing the vapor layer.
                          4.2-3

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 4.3        EMISSION CONTROL METHODS
            The EPA Control Technology Guideline (CTG) document for solvent
 metal cleaning identifies a number of control strategies for reducing volatile
 organic emissions from conveyorized degreasing operation.  These form the
 basis of defining RACT for the conveyorized degreaser and should therefore
 be the focal point of a field inspection.  The CTG document suggests two
 levels of control.  EPA's policy regarding the application of these control
 levels is discussed in Chapter 1.  Level A represents a relatively low effi-
 ciency system, estimated at 25 + 5 percent.  Level B, consisting of Level A
 plus additional requirements represents a higher efficiency system, estimated
 at 60 + 10 percent.  The following discussion will address these and other
 control measures found in the CTG document.  However, the organization is
 slightly different.  It is divided into three areas:  process equipment de-
 sign, operating requirements, and control equipment requirements.  In addi-
 tion, a second series of suggested controls is offered which do not appear in
 the CTG document.  These controls should be considered by the inspector as
 additional means of reducing emissions.
            It should be noted that a given control strategy will not provide
 equal results for similar degreasers or degreasers used in different appli-
 cations.  Therefore, each degreaser should be evaluated individually.
4.3.1      RACT Controls

           o  Process Equipment Design
              oo  Minimum entrance and exit openings should be pro-
                  vided by silhouetting the work load.   The average
                  silhouette clearance (distance between the edge
                  of the openings and the part)  should be < 10
                  percent of the opening width.
              oo  Safety switches should be included in the design
                  to prevent emissions during malfunctions and ab-
                  normal operation.
                  a.  Condenser flow switch and thermostat shut
                      off sump heat if coolant is either not
                      circulating or becomes too hot.
                  b.  Spray safety switch shuts off spray pump
                      or conveyor if vapor level drops excessively.
                  c.  Vapor level control thermostat shuts off sump
                      heat when vapor level rises too high.
                                   4.3-1

-------
o  Operating Requirements

   oo  Conveyor speed should be < 3.3 m/min (11 ft/min)
       to minimize solvent carry-out emissions.

   oo  Exhaust ventilation should not exceed 20 m^/min
       per m  (65 cfm per ft ) of degreaser opening
       unless necessary to meet Occupational Safety and
       Health Administration (OSHA)  requirements or the
       degreaser is vented to a carbon adsorber.

   oo  Work place fans should not be used near the
       degreaser opening because they will induce
       mixing of the air/vapor layer, thereby in-
       creasing emissions.

   oo  Solvent leaks should be repaired immediately,
       or the degreaser should be shut down, until
       repairs can be made.

   oo  Water should not be visibly detected in the
       solvent exiting the water separator.  For
       chlorinated solvents, water contributes to
       vapor loss because the mixture of water and
       solvent has a lower density than that of dry
       solvent.   In addition, water  contributes to
       corrosion and creates a low boiling azeotrope
       with the solvent in the boiling sump.

   oo  Down-time covers must be placed over entrances
       and exits of conveyorized degreasers immediately
       after the conveyor and exhaust are shut down and
       removed just before they are  started.

   oo  Disposal or transfer of waste solvents should be
       performed in a manner that will not allow greater
       than 20 percent of the waste (by weight) to evapor-
       ate to the atmosphere.  Waste solvents should be
       stored in covered containers.

   oo  Racking parts to allow maximum drainage should
       be implemented to minimize carry-out emissions.

o  Control Equipment Requirements

   oo  Rotating baskets, trays, etc., and/or a
       drying tunnel should be provided to
       prevent solvent drag-out.  Such carry-
       out is most likely to occur from solvent
       hold up in recesses or pockets in the work
       being degreased.

   oo  Covers must be provided for the entrance and
       exit in order to close these  openings immediately
       after shutting down the degreaser.   These covers
       should close off at least 80  to 90 percent of
       the opening to effectively prevent solvent emissions.


                         4.3-2

-------
              oo  Refrigerated chillers can be used to control
                  the upper limit of the vapor zone;  or
                  carbon adsorption systems should be used to
                  control emissions in the exhaust line of the
                  degreaser.   The ventilation rate (when down-
                  time covers are open) should be >^ 15 m /min
                  per m  (50 cfm/ft )  of air /vapor area for adsorbers.

              oo  The exhaust gas from the adsorption system
                  must contain < 25 ppm solvent by volume
                  averaged over a complete adsorption cycle.

              oo  Alternate control systems may be used if they
                  demonstrate control  efficiencies equal to or
                  greater than the refrigerated chiller or carbon
                  adsorption units.

4.3.2      Other Controls

           Several control techniques  are discussed in the literature that

deserve mention although they are not  recommended by EPA as RACT requirements.

           o  The unit is capable of being hooded or  covered without
              affecting its operation.   The enclosure of a degreaser
              diminishes solvent losses from the system that result
              from the movement of air within the plant.

           o  Sprays should be designed or adjusted so they do not
              cause turbulence at the  air/vapor interface; spraying
              must be conducted below  the vapor line.   Spray pressure
              should be the minimum necessary for adequate cleansing.
           o  Overloading work baskets may reduce the vapor temperature
              and collapse the vapor zone, thereby increasing the air/
              vapor mixing and subsequent emissions.   This situation
              can be avoided  by following equipment specifications for
              the allowable work load  as determined by a system heat
              balance.

           o  A solvent reclaimer-still to recycle and return a purified
              solvent to the  solvent sump.  This will tend to stabilize
              vaporization rates and eliminate emission due to improper
              waste disposal  methods.

           o  Where work being degreased contains acidic cutting oils or
              other acidic products, acid acceptance  and pH determination
              should be made  to determine the quality of the  solvent.

           o  Absorbent materials such as wood and fabric materials should
              not be degreased or used  in the basket  construction.

           o  A "good housekeeping" and maintenance program should be in
              effect.   Clean  out doors,  line  connections,  pumps,  water
              separator,  etc.,  should  be checked frequently.

           o  For large users  of solvent,  bulk storage may prove more
              economical than  purchases by individual  drums.   Where bulk
              storage is used,  a submerged fill pipe  from the top of the
              tank should be  included  in the  design of the storage  tank.
              Alternate controls such as a return  vent line to a recovery
              still  should  be  investigated.

                                   4.3-3

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4.4        INSPECTION PROCEDURES
           This section will discuss two types of inspections:   (1)  field
review and (2) office reviews.   Source sampling,  still another  form  of  in-
spection, will be discussed in the next chapter.
           Field investigations range from brief  plant visits to thorough in-
spections that produce a complete data base for enforcement  proceedings.
Office reviews rely on the source to furnish information.  This approach may
require less time and manpower but the resulting  data base is generally less
complete.  Office reviews, however, provide a useful  screening  tool  where
the number of potential violators is large.
4.4.1      Field Inspections
           After becoming familiar with the plant and its  facilities the
inspector should request that the appropriate company official  provide  in-
formation from company records that will allow the inspector to complete the
worksheets shown in Figure 4-7.   The data may also be available from permit
applications.  The worksheet divides the required data into  two categories:
operating requirements,  and control equipment.  It also provide^ the RACT
requirements for each category with suggested inspection procedures  and
guidelines.  With such information, comparisons can be made with past  con-
ditions, and with operations at the time of the inspection.
           Generally, the inspector would next request the company's assistance
in conducting a full inspection of the facility in order to verify actual
operating conditions.  This inspection may take several hours depending on
the number and types of conveyorized degreasers.   Figures 4-8 and 4-9  pre-
sent a photo and a schematic of a crossroad degreaser with a rotating  basket
which identify general components of a conveyorized degreaser.
           All field data, such as temperature of the solvent,   conveyor speed,
exhaust flow rate, silhouette clearance, etc., should be seen and verified.
For equipment that is operating, the inspector must be prepared to collect
this data with his own resources.  The inspector should concentrate  on those
parameters affecting emission rates and control procedures identified  earlier
in this chapter.
           This information will be compared to the data given  by the  company
official, and the total data base will be compared to the RACT  requirements
for design and operating conditions to determine if a violation exists.  At
that time, a reinspection date should be established if it is determined
that the source is not in compliance.

                                   4.4-1

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Figure 4-7.   Example Worksheet for Field Inspection of




               Conveyorized Degreasers
1.
2a.
3.
4.
5.
6.
7.
BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL
AGENCY;
MAILING ADDRESS: 2b. PLANT ADDRESS WHERE THIS DEGREASER IS
LOCATED:
SOURCE NO. (PERMIT NUMBER, NEDS ID, ETC.)
NAME AND TITLE OF COMPANY REPRESENTATIVE:
TELEPHONE NO. :
NAME OF OFFICIAL CONDUCTING INSPECTION:
DEGREASER
MANUFACTURER: MODEL NO. SERIAL NO.
INSIDE DIMENSIONS OF TANK (FT.): WIDE X LONG X DEEP

8.
9.
TYPE OF DECREASING:
TYPE OF CONVEYOR
COLD SOLVENT CLEANING t 	 , VAPOR DECREASING i 	 j


TITLE AND CODE NUMBERS OF DRAWINGS, SPECIFICATIONS, STANDARDS, CODES, PROCEDURES AND
DOCUMENTS USED WITH THE INSPECTION



TYPE OF SOLVENT IN USE (SPECIFIC NAME AND MANUFACTURER) :


INSPECTION OBSERVATIONS
RACT REQUIREMENTS
CONTROL EQUIPMENT
1.
Safety Switches
a. Condenser flow
switch & thermo-
stat
SUGGESTED INSPECTION
PROCEDURE
o Confirm that the switch
and thermostat have been
installed.
o If available, check read-
ings of flow and tempera-
ture indicators. For high
boiling solvents, the temp-
erature should be about 8°
to 11°C (15° to 20°F) above
dewpoint of surrounding
atmosphere or 32° to 46°C
(90° to 115°F). For low
boiling solvents (methy-
lene chloride and fluoro-
carbon 113) the exit temp-
erature should be less than
29°C (85°F). Many installa-
tions may not have a temper-
ature indicator at the cool-
ing coil exit. A rough es-
timate of the temperature
may be made if a bleed valve
is available at the exit end
of the coils. Bleed a sample
of coolant into a small vessel
and measure the temperature
with a portable thermometer.
FIELD
OBSERVATIONS

                      4.4-2

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                                    FIGURE  4-7
                                     (Continued)
    RACT REQUIREMENTS
  SUGGESTED INSPECTION
       PROCEDURE
    FIELD
OBSERVATIONS
1. (continued)
       b.  Spray Safety
           Switch

       c.  Vapor level
           control thermo-
           stats
o  If plant is agreeable,
   interrupt flow of coolant
   and determine if switch is
   tripped.

o  Confirm that the switch
   has been installed.

o  Confirm that vapor
   level control thermostat
   is located just above
   cooling coil or jacket.

o  Suggested thermostat
   settings for four types
   of solvents:
  -Perchlorethylene
       82°C (180°F)
  -Trichlorethylene -
       68°C (155°F)
  -1,1,1-Trichloroethane
       60°C (UO°F)
  -Methylene Chloride
       32°C (90°F) or
   about 6°C (10°F) lower
   than boiling point of
   solvent-water azeotrope

o  Read temp,  on indicators
2.  Minimized openings at
    entrance and exit of
    conveyor
   Determine with a tape
   measure that the average
   silhouette is less than
   10 cm (4 In.) or less than
   10 percent of the width
   of the opening.
3.  Drying tunnel or
    rotating baskets
   Observe whether the degreaser
   is equipped with either of
   these devices.   Observe
   whether parts are wet  or
   have liquid in crevices
   when exiting the degreaser.
4.   Refrigerated chiller
   Observe indicated coolant
   temperature.

   oo  For subzero chillers
       the temperature
       should  not  exceed
       -25°C  (-1
                                oo  For above freezing
                                    chillers the temperature
                                    should not exceed 5°C
                                    (40°F) .

                                oo  Do not attempt to extract
                                    a sample of coolant from
                                    a refrigerated chiller.

                                Determine the cooling capacity
                                from the design specifications,
                                       4.4-3

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                                     FIGURE 4-7
                                     (Continued)
    RACT REQUIREMENTS
  SUGGESTED INSPECTION
       PROCEDURE
                                                                                FIELD
                                                                            OBSERVATIONS
                                    For subzero
                                    chillers the
                                    minimum cooling
                                    capacity should be
                                    as follows for each
                                    degreaser width:
                                    (The cooling units
                                    are Btu's per hour
                                    per foot of perimeter.)

                                    <3.5 ft - 200
                                    >3.5 ft - 300
                                    >6   ft - 400
                                    >8   ft - 500
                                   >10   ft - 600

                                    For above freezing
                                    chillers the cooling
                                    capacity should be
                                    at least 500 Btu/hr
                                    per foot of perimeter.
5.  Carbon adsorption
    system with ventilation
    >1S m^/min per m
    (50 cfm/ft2) of air/
    vapor area.
   Solvent odors should not be
   detectable on the roof  down-
   wind from the stack.
                              o   Determine  the air handling
                                 capacity of the fan,
                                        -or-
                                 If  sampling ports are available,
                                 the velocity of the exhaust
                                 gases may  be measured with a
                                 swinging vane velocity meter.
                                 Also determine the cross-
                                 sectional  area of the duct,
                                 then calculate the cfm.

                              o   After the  air volume is
                                 determined from either of the
                                 above methods, obtain the
                                 area of the air/vapor opening
                                 and calculate the cfm per
                                 square foot of opening.
                              o   See the source testing chapter
                                 of  this manual.
OPERATING REQUIREMENTS
1.  a.  Exhaust ventila-
        tion should not
        exceed 20m /min
        per m  (65 cfm
        per ft2) of de-
        greaser open
        area unless
        necessary to
        meet OSHA re-
        quirements.
        (This ventila-
        tion rate is app-
        licable if a
        carbon adsorber
        is not installed.)
    b.  Work place fans
        should not be
        used near degreaser
        opening.
o  Determine the air handling
   capacity of the fan,
           -or-
   If sampling ports are available,
   the velocity of the exhaust  gases
   may be measured with a swinging
   vane velocity meter.   Also
   determine the cross-sectional
   area of the duct, then calculate
   the cfm.

o  After the air volume is
   determined from either of
   the above methods, obtain
   the area of the degreaser
   opening and calculate the
   cfm per square foot of
   degreaser opening.

o  Note the location of ventilation
   fans near the degreaser.
                                        4.4-4

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FIGURE 4-7
(Continued)
RACT REQUIREMENTS SUGGESTED INSPECTION FIELD
PROCEDURE OBSERVATIONS
2. Water should not
be visually detectable
in solvent exiting
the water separator.
3. Conveyor speed should
not exceed 3.3 m/min.
(11 ft/min).
4. Rack parts for best
drainage.
5. Repair solvent leaks
Immediately.
6. Downtime covers
7. a. Do not dispose of
waste solvent or
transfer it to
another party such
that greater than
20 percent of the
waste (by weight)
can evaporate
into atmosphere.
b. Store water sol-
vent only in
covered containers.
o Observe any water present
in the sight glass on the
separator .
o Check conveyor speed
with stop watch.
o Observe whether parts
are racked in a manner
that allows liquid solvent
to collect in pockets and
crevices.
o Inspect for wetted areas
around pump seals, sight
glass, pipes, etc.
o If the unit is not in
operation, observe whether
they are in place.
o Determine if source has
inhouse reclamation
facilities (i.e. still)
or a service contract
with a solvent reclama-
tion firm.
o Confirm that storage is
done with covered con-
tainers by visual inspec-
tion.
o Check for container leakage.






 4.4-5

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-CONTROL  BOX  FOR
 SAFETY SWITCHES
HOOD
    ROTATING  BASKET.


                WORK OPENING.
  Figure 4-8.  Cross Rod with Rotating Baskets
                        4.4-6

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 LOCATION OF "V-BELT
 CONVEYOR DRIVE
  REMOVABLE PANEL &
  SERVICE DOOR
  ROTATING
  BASKET RACK
  COOLING COILS AROUND
  INSIDE OF MACHINE-
                                                  EXHAUST & DUCT
  WATER  	
  SEPARATOR

STEAM COILS
MOUNTED ON
CLEAN-OUT  "
  DOORS

THIS
SECTION
TOTALLY
ENCLOSED
                LOCKING DEVICE
                FOR  ROTATING
                BASKETS
                                                                 LOOR LINE
             VAPO_R   LIQUID SOLVENT LIQUID SOLVENT
          GENtRATrNG RINSE SUMP
             SU MP
                                  WASH SUMP
        Figure  4-9.    Cross  Rod with Rotating  Baskets
                        (Sketch)
                                  4.4-7

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4.4.2      Record Review
           Determining compliance of conveyorized degreasers through field
inspections and monitoring is expensive and time consuming.  It requires a
great deal of manpower and tends to limit the number of sources that can be
reviewed in a given year.  The review of company-furnished records through
questionnaires or letter requests may provide a viable alternative to field
inspections and source monitoring activities for compliance determination.
At minimum, this approach should be considered as a screening tool to identify
candidate sources for comprehensive field inspections, thereby increasing the
effectiveness of the available resources.
            This  discussion  outlines  several procedures which may  be  used  when
 implementing a record  review.   Information  will  be  required  from  the plant
 concerning the design,  operation and maintenance of the equipment.
 4.4.2.1     Review of Design, Operation,  and Maintenance Data
            The first requirement of this procedure  is the  development of
 standard questionnaires  that can be sent out as  part of a  Section 114 request
 to the applicable sources.  The type of  information required is similar to
what  is identified on  the inspection forms  illustrated in  Figure 4-7.  It
 is important  that the  source understand what is  being requested and  that
 the request be realistic because the entire process of making compliance
judgments  using  this procedure is highly dependent  on the  reliability of  the
 information  furnished.
           An example questionnaire is provided  as  Figure  4-10 and should be
used  as a  guide  only.  It is suggested that the  agency develop its own form
which would be specific  to the program.  For example, a screening program
may only require key data, while a more extensive request  is necessary if
compliance determinations are to be attempted.   Three types of data  are
suggested  for review:  design information,  operational information,  and main-
tenance records.  The design data should be readily available, while opera-
tional and maintenance may require the source to create a  special logging
system in  order  to comply with the agency's request.
                                    4.4-8

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                Figure 4-10.  Questionnaire for Conveyorized Degreasers
 1.  BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL
     AGENCY:
 2.  a. MAILING ADDRESS:
      2.  b. PLANT ADDRESS WHERE THIS DEGREASER
             IS LOCATED:
 3.  SOURCE NO.  (PERMIT NUMBER, NEDS ID, ETC.)
 4.  NAME AND TITLE OF AUTHORIZED COMPANY REPRESENTATIVE FURNISHING DATA:

                                          SIGNATURE:
 5.  TELEPHONE NO.:
 6.  DEGREASER
       MANUFACTURER:
MODEL NO.
       INSIDE DIMENSIONS OF TANK (FT.):
   WIDE X
	SERIAL N0._

 LONG X      DEEP
       CONVEYORIZED:  YES i	1  NO i	1  IF YES, GIVE TYPE	

       TYPE OF DECREASING:  COLD SOLVENT CLEANING i	\  VAPOR DECREASING

       WORK LOAD DESIGN SPECS
 7.  CONTROL EQUIPMENT:  NAME
                         CFM
    _TYPE
     EFF.
         MODEL NO.
 8.  DRYING TUNNEL:  YES nzZ!  NO \	1
     TUMBLING OR ROTATING BASKETS:  YES

     TANK COVERED WHEN NOT IS USE:  YES
    NO

    NO
 9.  SAFETY SWITCHES:
                        [-—]  CONDENSER FLOW SWITCH AND THERMOSTAT

                        r—I  SPRAY SAFETY SWITCH

                             VAPOR LEVEL SAFETY SWITCH
10.  REFRIGERATED CHILLERS

       DESIGN TEMPERATURE FOR REFRIGERANT
               °C or
11.  DISPOSITION OF

       SPENT SOLVENT FROM DEGREASER_
       SLUDGE FROM STILL
       SOLVENT FROM ADSORBER
12.  OPERATING PARAMETERS

       ACTUAL CONVEYOR SPEED
       FLOW RATE OF EXHAUST GAS	
       TEMPERATURE OF SOLVENT BATH_
       CHEMICAL NAME OF SOLVENT
   JT/MEN
   _CFM
    °C
                  or
                                             4.4-9

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           Criteria for review of the data should be established prior to fi-
nalizing the questionnaire.  Obviously the criteria will address the overall
objectives of the review program (e.g., screening program or compliance
determination).  In general, however, the design data should be compared to
the original construction permit and the design specifications and be at
least as stringent as RACT.  This review would include such items as exhaust
ventilation rates, types of safety switches, design conveyor speed, and the
availability of control equipment.   Operational information should be com-
pared to operating permits and operational specifications defined as RACT.
These parameters would include the silhouette distance,  the use of down-time
covers, the quantity and type of parts being cleaned, the method of waste
solvent disposal, and actual ventilation rates.  Maintenance records should
include repair or replacement records and some statement as to the general
condition of the equipment.
 4.A.2.2    Review Waste Solvent  Disposal  Procedures
            A description of waste  solvent disposal methods  used by the  source
 must be requested in the questionnaire initiated  by  the agency (example shown
 in Figure  4-10).  A comparison should be  made with the  RACT operating  require-
 ments ("not greater than 20 percent  can evaporate into  the atmosphere"),  and
 data on other acceptable practices which are readily available.
            On conveyorized vapor degreasers where large quantities of
 solvent are used, it becomes economical to install a solvent  distillation
 still for  solvent reclamation.   On installations  of  this type, both the
 sludge and solvent  are pumped to the solvent still where the solvent is
 reclaimed.  The liquid is heated to  its vaporization temperature and the
 resulting  vapors flow into a chilled condensing  chamber where the vapors
 condense back to liquid.   The liquid is then circulated back to the con-
 veyorized  vapor degreaser for further use.  In this  type of operation,  only
 make-up liquid solvent is added, as  needed.  There are  alternate approaches
 to an inhouse still, such as service contracts with  outside agents which
 may be more attractive to the source and will also meet the RACT require-
 ments.
            The sludge remaining in the still along with water and spent un-
 reclaimable solvent should be disposed of in accordance with the Resource
 Conservation and Recovery Act.  Pursuant to this legislation EPA has pro-
 posed regulations for the disposal of hazardous wastes  at 43FR58946 (December
 18, 1975).
                                   4.4-10

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                                  CHAPTER 5
                EMISSION TESTING OF CARBON ADSORPTION SYSTEMS

5.1  INTRODUCTION
     The compliance status of a carbon adsorption system cannot always be
determined by a routine source inspection or by an engineering evaluation
conducted in the office.  For those cases where the compliance status is
uncertain or where violations are anticipated, measurement of the solvent
concentration in the effluent gases will be necessary to establish the com-
pliance status.  It would be ideal if there were an accurate, quick, easy,
inexpensive compliance test method available for inspectors.  Unfortunately,
the present methods that are sufficiently accurate (+ 10% or better) for
compliance concentration measurements of halogenated organics are not parti-
cularly quick, easy, and inexpensive; and the methods that meet these latter
requirements are not sufficiently accurate for exact compliance determinations•
Because no single method currently exists that satisfies all the requirements
of an ideal compliance test method, two methods have been selected.  The first
method  is a screening method that is quick, easy, and relatively inexpensive.
The second method is designed to provide the accuracy necessary for full fledg-
ed enforcement compliance actions.  The screening method and the recommended
reference method are presented in Section 5.2 and Section 5.3, respectively.
In addition, a method is described in Section 5.4 for conducting a material
balance so that emissions can be determined on a pounds per hour or pounds
per day basis.
     The screening procedure is designed to be quick, easy, and inexpensive.
The primary objective is to provide an inspector with a method that can iden-
tify those sources that are well below the emission concentration limitation
as well as those sources that are well above the limitation, while not adding
significantly to the inspectors work load nor requiring a substantial invest-
ment in either personnel training or equipment.  The screening method can be
                                    5.1-1

-------
used by an inspector during a routine source inspection, and will add only
15 to 30 minutes to the field inspection time.  Personnel can be trained  to
use the method in 1 to 2 hours.  Equipment for the screening method will
cost from $2,000 to $4,000.
     The screening method provides an instantaneous reading of apparent sol-
vent concentration in the gases emitted from solvent adsorption systems.
The instruments used cannot identify specific compounds, nor can they select-
ively measure individual compounds in a mixture of solvent vapors.  They
respond to practically all volatile organic compounds, although the magnitude
of the response varies from compound to compound.  For these reasons, the
screening method cannot provide the quality of data necessary for an enforce-
ment action.   What the screening method can do, however, is indicate the
apparent compliance status of sources, thereby significantly limiting the
number of full compliance tests that  must be conducted.
     The EPA guideline document for solvent metal cleaning does not specify a
test method  for measurement of solvent emission concentrations.  However,
EPA has prepared  a draft test procedure specifically designed to provide
accurate concentration measurements  of halogenated solvent vapors emitted
from  sources such as the subject degreaser carbon adsorption systems.  The
draft procedure is entitled, "Determination of Halogenated Organics from
Stationary Sources"!.   The method provides accurate concentration measurements
of individual solvent compounds even if a mixture of solvents is present.  It
is recommended that this procedure be adopted as the compliance verification
method for determination of VOC emission concentrations from degreaser carbon
adsorption systems  that are subject to regulations which incorporate the
EPA guideline document.   The CTG recommends limiting the solvent content in
the exhaust gases to 25 parts per million (ppm) by volume of solvent.
     As with most source testing procedures, the recommended compliance
verification method requires special equipment and trained personnel.  The
method requires integrated bag sampling equipment for sample collection and
a gas chromatograph (GC) with a flame ionization detector (FID) for sample
  "Determination of Halogenated Organics from Stationary Sources", Emission
  Measurements Branch, ESED, EPA, Research Triangle Park, North Carolina,
  January 1979.
                                    5.1-2

-------
analysis.  A single source test, using the recommended reference method,
will require approximately 30 to 40 labor hours, assuming the personnel are
previously trained and the equipment is already set up for this purpose.
The total cost of the necessary equipment will range from $8,000 to $15,000.
It is apparent that conducting source tests is expensive in both labor and
equipment requirements.  Furthermore, source testing should not be attempted
by persons unfamiliar with source sampling, nor by those who are unfamiliar
with the analyzers.  In light of these facts, the importance of screening
tests is quite obvious.  Reference method compliance testing should be reser-
ved for those cases where screening tests have indicated potential violations
and further proof is needed.
     The purpose of testing is to determine if the emission standards will be
met when degreasers are operated under conditions that create the maximum
solvent vapor emissions.    Therefore, the plant operating conditions during
a test should be as follows:
     o  The production rate should be the maximum rate for satisfactory
        operation of the work material being processed and for the type of
        vapor degreaser being used.
     o  The testing should be conducted during operating cycles which pro-
        duce the maximum emissions.
     o  Work parts which produce maximum emissions (i.e., parts with porous
        surfaces, crevices, large mass, etc.) should be processed during
        testing.  The conveyor speed (mpm) should be the maximum  allowable.
        The solvent boiling  rate and the vapor space barrier chilling coil
        temperature should be at normal operating conditions.  No special
        work material or conditions should be used that would cause opera-
        tions to be other than normal for that particular conveyorized de-
        greaser application, except as specifically mentioned above.
     When conducting a screening test the inspector should first determine
if the process is operating normally.  Although it is desirable to perform
the screening test under conditions of maximum emissions, it is not mandatory
as it would be for reference method compliance testing.
                                    5.1-3

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5.2      SOURCE TESTING SCREENING METHOD
         This procedure contains seven major sections.  The title of each major
section and the page number where each is found is as follows:
         5.2.1  Applicability                        5.2-1
         5.2.2  Principle                            5.2-1
         5.2.3  Range and Sensitivity                5.2-2
         5.2.4  Calibration Apparatus                5.2-2
         5.2.5  Sampling and Analysis Apparatus      5.2-4
         5.2.6  Calibration Procedures               5.2-12
         5.2.7  Sampling Procedures                  5.2-14
5.2.1    Applicability
         This suggested procedure is applicable to the measurement of single-
component solvent concentrations in the effluent gases from carbon adsorption
systems installed on degreasers using organic solvents. It assumes that quan-
tities of other organic compounds which are present as oils or stabilizers
are insignificant in comparison to the solvent emissions.  The procedure is
intended to provide a quick and relatively inexpensive approach that can be
used by field inspectors to estimate solvent concentrations.  It is not
intended to be a compliance testing method.
5.2.2    Principle
         Commercially available portable organic vapor analyzers are used to
measure solvent concentration directly in the stack gases from carbon adsorp-
tion systems.  The units are battery powered and are safe for use in explo-
sion hazard areas, provided they are certified intrinsically safe by the
Factory Mutual Laboratories or are designed for use in Class I, Division 1
or 2 hazardous areas as designated by the National Electrical Code.l  Detec-
tion principles available include flame ionization, catalytic oxidation/
thermal conductivity, and photoionization.  The photoionization unit is an
in-situ analyzer, while the flame ionization and catalytic oxidant/thermal
conductivity units are extractive analyzers.  The units are completely self
contained requiring no ancillary sample handling equipment.
1 "National Electric Code 1968", National Fire Protection Association,
  Publication NFPA No. 70-1968, Boston, 1968
                                    5.2-1

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5.2.3    Range and Sensitivity
         The range and sensitivity varies among the different types of instru-
ments that are available.
5.2.4    Calibration Apparatus
         Calibration is most easily accomplished by obtaining commercially
prepared and certified calibration gas mixtures.  If this is done, then
only a minimum of equipment is required.  The calibration gas mixtures must
contain the same solvent that is used in the degreaser to be tested.  Inclu-
sion of any other organic materials must be limited to less than 0.1 ppm as
methane.  The diluent gas should be pure air containing less than 0.1 ppm
organics (as methane).  The gas manufacturer should recommend a maximum
shelf life for each cylinder, based on a maximum concentration change of + 5
percent from the certified value.  The date of gas cylinder preparation,
certified concentration, and recommended shelf life should be provided by
the gas manufacturer.
         If commercially prepared calibration gas mixtures are not available,
or if the decision is made to prepare the mixtures in-house, then more equip-
ment is required.  Suitable calibration gas mixtures can be prepared from
pure solvent liquid and zero air.  Such mixtures, however, should be prepared
fresh each day, unless their stability for a longer period has been demon-
strated.
         The two following sections list the appraratus required for calibra-
tion using either commercially prepared or in-house prepared calibration gas
mixtures.
5.2.4.1  Calibration Apparatus for Use With Commercially Prepared Calibration
         Gas Mixtures
         o  Air—zero grade, certified by the manufacturer to contain less
            than 0.1 ppm organics (as methane).
         o  Calibration Gas Mixtures—approximately 5,  25, and 50 ppm of the
            specific solvent in zero air, with less than 0.1 ppm of other
            organic material (as methane).   Concentration of solvent and or-
            ganic impurities to be certified by the manufacturer.
         o  Gas pressure regulators—for zero air and solvent gas cylinders.
                                    5.2-2

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         o  Tedlar bags—30 liter capacity with an integral stainless steel
            valve.  A separate bag is reserved for each calibration gas con-
            centration.  Other bag materials may be used if it is proven that
            they do not affect the sample integrity.
5.2.4.2  Calibration Apparatus for Use With Standard Gas Mixtures Prepared from
         Pure Solvent Liquid
         o  Air—zero grade, certified by the manufacturer to contain less
            than 0.1 ppm organics (as methane), for zero gas and dilution of
            solvent calibration gases.
         o  Solvent—99.9+ percent pure,  must be the same as the solvent used
            in the degreaser being tested.
         o  Gas pressure regulator—for cylinder of zero air.
         o  Tedlar bags—50 liter capacity with integral stainless steel valve.
            Other bag materials may be used if it is  proven that they do not
            affect the sample integrity.
         o  Midget impinger—30 ml capacity,  with septum.
         o  Hot plate—small laboratory size.
         o  Beaker—500 to 1,000 ml size.
         o  Syringe—1.0 microliter (yl)  capacity.
         o  Syringe—5.0 microliter (yl)  capacity.
         o  Syringe--25.0 microliter (ul)  capacity.
         o  Dry gas meter—1 liter per revolution,  smallest scale divisions no
            greater than 0.01 liters,  +_ 1% accuracy.   Meter must be calibrated
            with a wet test meter or a spirometer at  least every 12 months.
            Alternatively a calilbrated flowmeter may be used instead of a dry
            gas meter,  provided it is  accurate to + 1.0 percent.
         o  Vacuum pump—-to evacuate the  bags.
         o  Connecting tubing and fittings—Teflon tubing,  6.4 mm outside
            diameter.   Stainless  steel or  Teflon fittings  as required.
                                    5.2-3

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 5.2.5     Sampling and Analysis Apparatus
          The  following  instruments are  listed as  examples  of  the  types  of
 portable  analyzers applicable to this procedure.  Other units may also  be
 available which will perform satisfactorily.
          o  FID - OVA Model 108 or 128, Century Systems Corporation
          o  Catalytic Oxidation/Thermal Conductivity - TLV Sniffer, Bacharach
            Instruments Company
          Accessory hand-held probes which are available for all of the  above
 instruments should be used.
 5.2.6     Laboratory Calibration Procedures
          These procedures are designed to determine if an  analyzer is respon-
 ding properly and to determine the analyzer response curve for each different
 solvent.  Analyzer response will normally be linear over the narrow range of
 concentrations (zero to 50 pppm) used for calibration.  The slope of the
 response  curve will be different for each solvent, however.  The calibration
 curves allow the operator to convert analyzer response (instrument reading)
 to actual concentration.
 5.2.6.1   Preparation of Standard Gas Mixtures
          The gases used for calibration can come from several sources.  If
 they are  available, commercially certified span gas mixtures are preferable
 for analyzer calibration.   The span gas mixtures should contain zero air as
 the diluent.  The solvent vapor in the span gas mixture must be the same as
 the solvent used in the subject degreaser.  At lease three different span
 gas concentrations should be used in order to cover the range of concentra-
 tions expected in the field.  For most carbon adsorption systems, span  gas
 concentrations of 5,  25, and 50 ppm of solvent should be adequate.  In  addi-
 tion to the span gases, a zero gas (certified by the manufacturer to contain
 less than 0.1 ppm organics, as methane) is required.
          If certified solvent span gas mixtures can be obtained, they are
 used directly to calibrate the analyzer.  If such mixtures are not commer-
 cially available, then suitable calibration gas mixtures can be prepared by
 diluting pure solvent liquid.  Prior to use, each bag must be numbered  and
must be leak checked using one of the following procedures.
                                    5.2-4

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         o  Pressurize the bag to 5 to 10 cm H20 (2 to 4 in. 1^0) using a water
            manometer to measure the bag pressure.   Allow to stand for 10
            minutes.  Any displacement of the water manometer indicates a
            leak.
         o  Pressurize the bag to 5 to 10 cm 1^0 (2 to 4 in. H20) and allow
            to stand overnight.  A deflated bag indicates a leak.
            Note:  Bag pressurization can easily be accomplished by placing
            a book or other suitable weight on a partially inflated bag.
         If commercially prepared calilbration gas mixtures are used, transfer
20 to 25 liters from each cylinder into individual Tedlar bags.  Before each
use the bags must be numbered, leak tested as discussed above, and evacuated.
Connect each bag to the appropriate gas cylinder regulator with a short piece
of Teflon tubing.  Flush the tubing with the calibration gas just prior to
connecting the bag.  Slowly fill each bag with calibration gas.  Fill a bag
with zero air in the same manner.  Record the appropriate data on the Cali-
bration Curve Data Sheet (Figure 5-1).  (Caution: To eliminate contamination
if bags are reused, a bag should only be refilled with the solvent it origin-
ally contained.  Furthermore, the new gas mixture standard should never be
a lower concentration than the previous gas mixture standard.)
         If the calibration gas mixtures are to be prepared from solvent
liquid, assemble the apparatus as shown in Figure 5-2.  Slip a short piece
of 4.8 mm inside diameter rubber tubing over the Teflon tubing that attaches
to the bag valve.  Tighten a pinch clamp on the rubber tubing to seal the
tubing.  Back off the pressure control knob on the zero air cylinder regula-
tor so that no gas will flow when the cylinder is opened.  Close the outlet
valve on the zero air cylinder regulator and open the zero air cylinder value.
The outlet pressure gauge on the regulator should indicate zero pressure.
Open the regulator outlet valve slightly.  Slowly turn the regulator pressure
control knob (normally in a clockwise direction) until gas just begins to
flow through the regulator.  Allow the pressure in the system to reach 5 to
10 cm H20 (2 to 4 in. H20) and close the regulator outlet valve.  Observe
the manometer water level for a 1 minute period.  Any change in the manometer
water level indicates there is a leak in the system that must be corrected
before proceeding.  After a successful leak check is obtained, remove the
                                    5.2-5

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            Figure 5-1.  Example Calibration Curve Data Sheet
Calibration Run Number
Date
Location
Analyst
Resultant Calibration Curve Number
Analyzer Type 	
Analyzer I.D. Number
Solvent Gas (name)
                                               Zero   Mixture   Mixture   Mixture
                                               Air       1          2         3
Bag I.D. Number
Bag Size (liters)
Source of Calibration Gas
Calibration Gas Cylinder Number
Calibration Gas Bag Number
Calibration Gas Concentration (opm)
Analyzer Range Setting
Analyzer Span Potentiometer Setting
Analyzer Zero Check Response
Analyzer Internal Span Check Response
Analyzer Response to Zero Air
Response to Gas Mixture
                                    5.2-6

-------
                               TEFLON
                               TUBING
                WATER
                MANOMETER
ro
I
•-j
MIDGET    /"
IMPINGER
                                       THERMOMETER
               SYRINGE

                J
                SEPTUM
                                                                           BOILING WATER
                                                                           BATH
                                                                                                   INTEGRAL
                                                                                                   VALVE
                                                                HOT  PLATE
                                                                                    -TEDLAR BAG
                                                                                     CAPACITY 50 LITERS
                                         ZERO AIR
                                         CYLINDER
                Figure 5-2.   Apparatus  for  the  Preparation  of Calibration  Gas Mixtures  from Liquid Solvent

-------
rubber tubing and pinch clamp from the Teflon tubing.  Using the regulator
outlet valve and the pressure control knob, obtain a flow through the system
of approximately 3 liters/minute.  Flush the system for 5 minutes, then
close the regulator outlet valve.  Turn on the hot plate and allow the water
bath to reach boiling.  Evacuate a 50 liter Tedlar bag that has passed a
leak test , and connect it to the impinger outlet tubing with the bag valve
closed.  Record the initial meter readings (M^) on an appropriate data sheet,
such as the one shown in Figure 5-3.  Open the bag valve and the zero air
cylinder valve.  Adjust the filling rate to approximately 3 liters/minute.
Record the meter pressure (Pm), the meter temperature (Tm), and the baromet-
ric pressure (P^).  Determine the proper amount of solvent from Table 5-1.
Select the smallest syringe that will accommodate the solvent volume, and
fill the syringe with the desired amount of pure liquid solvent (Vg).  Push
the syringe needle through the impinger septum and inject the solvent into
the impinger.  Use a needle of sufficient length to permit injection of the
liquid below the air inlet branch of the tee.  Remove the syringe.
         Complete filling of the bag, recording the meter temperature and
pressure at 5 minute intervals.  When the desired amount of air (preferably
40 liters) has been metered into the bag close the zero air cylinder and the
bag valve.  Record the final meter reading (Mf).  Disconnect the bag from
the impinger outlet.  Transfer the bag to a protected area out of direct
sunlight and allow it to equilibrate for approximately 1 hour.  Gentle mani-
pulation of the bag will speed the equilibration process.
         Calculate the average meter meter temperature (T^) and pressure
(pma) from the readings taken while filling the bag.  Calculate the actual
resultant concentration using the following equation:
            (Vs)(Qs)(103)(24.04)(760)(Tma + 273)(106ppm)   Equation  5-1
     Cppm = — — — - — • — - — — • • ' • -- — — — • — - • — ~ -
               (MWg)(Vn)(106)  (Pb + P^ )  (293)
                                    13.6
where:
                 = solvent concentration, ppm by volume
         V       = volume of liquid solvent, /u,l (1 microliter = 10~  liter)
         Qs      = density of liquid solvent at temperature used, g/ml  = mg//iAl
                                    5.2-8

-------
           Figure  5-3 .  Example Span Gas Preparation Data Sheet
 Run  Number
 Analyst
 Dry  Gas Meter Number
 Dilution Gas (name)
 Dilution Gas Cyl. Number
 Bag Material 	
 Bag Capacity 	
Nominal Dilution Gas Flow Rate
Barometric Pres., P., (mm Hg)
             Bag  I.D.  Number
             Date
             Solvent  (name) 	
             Solvent  Liquid Lot  Number 	
             Solvent  Density,  Q  ,  g/ml 	
             Volume of  Solvent Used, V ,  (yl)
             Ambient  Temperature 	
             Data  for Calib.  Curve Number
Time
(24-Hour Clock)









Gas Meter
Reading
(liters)








NET, Vn -
Gas Meter
Temperature,
V <°c>








AVS- Tma '
Gas Meter
Pressure,
Pm' (mm H20)








AVG, P =
ma
For Liquid Solvent:    C
                       ppm
_ (VsHQs)(103)(24.04)(760)(Tma  + 273)
                       ppm
                       ppm
                                    ^V  (Pb +T
                             (     )(     )(24,040)(760)(    + 273)
                                        ppm
                                     5.2-9

-------
                                                           TABLE  5-1
ro
INJECTION VALUES FOR PREPARATION OF STANDARDS


Perchloroethylene C2C14
Trichloroethylene C2HC13
1,1, 1-Tr ichloroethane C2H3Cl3
Methylene Chloride CH2Cl2
Trichlorotrifluoroethane C2C13F3
Carbon Tetrachloride CC14
Ethylene Dichloride C?HAC1

MOLECULAR WT
(MWS)
165.85
131.40
133.42
84.94
187.38
153.84
98.96

DENSITY AT 293° K
(Qs>
1.6230
1.4649
1.4384
1.3255
1.5790
1.5940
1.2569



Vs, pi LIQUID REQUIRED IN 40 1 AIR
FOR APPROXIMATE CONCENTRATION OF:
5 PPM 25 PPM 50 PPM
0.85
0.75
0.77
0.53
0.99
0.80
0.66
4.25
3.73
3.86
2.67
4.94
4.01
3.28
8.5
7.5
7.7
5.3
9.9
8.0
6.6

-------
                 = conversion factor: mg to fig
         24.04   • volume occupied by one /u,g-mole of pure solvent at 20°C
                   (293°K) and 760 mm Hg,
         Pb      - barometric pressure, mm Hg
         pma     * average meter pressure (gauge), mm H20
         293     - standard temperature (20 + 273), °K
         13.6    = conversion factor, mm l^O/mm Hg
         MWS     = molecular weight of solvent, /ig//Ag-mole = g/g-mole
         Vn      - net metered volume, liters.  Vn = final meter reading (Mf)
                   minus initial meter reading
                 » conversion factor: liters to /u.1
         760     = standard pressure, mm Hg
         Tma     = average meter temperature, °C
         273     - constant added to °C to obtain °K
         10^ ppm - conversion factor: volume fraction to ppm
         If the laboratory conditions are close to standard conditions the
above equation can be simplified by eliminating the temperature and pressure
correction terms.  As long as the meter temperature is within the range of
6° to 34°C (43° to 93°F), eliminating the temperature correction will intro-
duce a maximum error of 5% in the calculated concentration.  Similarly, if
the meter pressure is within the range of 722 to 792 mm Hg (28.43 to 31.42
in. Hg), eliminating the pressure correction will introduce a maximum error
of 5% in the calculated concentration.  Therefore, if both temperature and
pressure corrections are eliminated, the maximum error that could result
would be 10%, and for most laboratory conditions the error  would be much
less.  Removing the temperature and pressure corrections and combining con-
stants yields the following simplified equation:
                                  (VS)(QX)(24,040)               Equation 5-2
                                      (MWs)(Vn)
                                    5.2-11

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5.2.6.2  Determination of Analyzer Calibration Curve
         Assemble the sampling probe to the analyzer and leak check the sys-
tem in accordance with the manufacturer's instructions.  Set the range switch
to the lowest range that will allow analysis of the 50 ppm solvent gas mixture
without an off-scale response.  This setting will vary, depending on the type
of analyzer used and the analyzer gain setting.  In some cases it may be
necessary to adjust the analyzer gain to obtain the desired response.  Always
refer to the manufacturer's instructions before performing any adjustments
inside the instrument case.  Adjust the analyzer zero and span following the
manufacturer's instructions.  (Use the internal electronic span check or manu-
facturer's span gas as appropriate for the specific analyzer being used.)  Re-
cord the final analyzer settings and the other required data on the Calibra-
tion Curve Data Sheet (Figure 5-1).
         Assemble bags of calibration gases prepared as discussed in Section
5.2.6.1.  Tedlar bag gas mixture standards of methylene chloride, ethylene
dichloride, and trichlorotrifluoroethane should be prepared fresh each day.
Trichloroethylene and 1,1,1-trichloroethane can be kept for 2 days, while
perchloroethylene and carbon tetrachloride can be kept for 10 days from the
date of preparation.  Connect the analyzer probe to the bag containing zero
air.  Allow the analyzer to stabilize and record the analyzer response on the
Calibration Curve Data Sheet.  Similarly determine the analyzer response for
each of the gas mixture bags, starting with the most dilute concentration and
proceeding to the next higher concentration.  After completing the gas mix-
tures, recheck the analyzer response to the zero air.  If the zero air re-
sponse has drifted more than 5 percent the run should be repeated.
         Plot the analyzer response for each of the calibration gases (in-
cluding the zero air) versus the actual concentration of each gas.  Figure
5-4 is a typical calibration curve developed in this manner.  The points
should fall along a straight line.  If any of the plotted points fall farther
than 10% from the average line, those points should be checked to determine
if an error has been made.  The resulting curve is then used to convert
source measured analyzer response to solvent ppm concentrations.
                                    5.2-12

-------
Calibration Curve Number — r/?V-
Analyzer  O iss -/2&   -syV  / S.
Range
                 O  TV;
       Internal  Calibration  Point
                                    Date
    50
    40
Q.
CL
Q_
00
    30
    20
    10
         CALIBRATION GAS
         INSTRUMENT INTERNAL ELECTRONIC
         CALIBRATION OR MANUFACTURER'S
         SPAN GAS
                  10
                       20
30
40
                      CALIBRATION GAS  CONCENTRATION
                      (ppm  1,1,1-trichloroethylene)


                 Figure  5-4.   Example  Calibration  Curve
50
                               5.2-13

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         Once a calibration curve is developed for each solvent encountered
in the field, analyzer calibrations utilizing the instrument internal elec-
tronic span check or manufacturer's span gas are sufficient for routine
operation.  Analyzers should initially be recalibrated as outlined in this
section every 3 to 6 months to verify the accuracy of the internal electronic
span check or manufacturer's span gas.  If the periodic recalibrations repeat-
edly show a zero or span drift of more than 10 percent, more frequent recali-
brations, as outlined in this section, should be performed.  If the periodic
recalibrations show that the instrument and the electronic span check or
manufacturer's span gas are stable, a longer interval between recalibration
can be instituted.
5.2.7    Sampling Procedures
         Prepare the analyzer for field use in accordance with the manufactur-
er's instructions.  Connect the sampling probe (where applicable) to the ana-
lyzer and leak check the system in accordance with the manufacturer's instruc-
tions.   Make sure the batteries are fully charged and the instrument is
operating properly before leaving the office.
         When ready to perform the sampling again leak check the system.
Zero the analyzer as directed by the manufacturer and check the span calibra-
tion using the internal electronic calibration check.  Adjust the analyzer
gain as necessary so that the analyzer response is equal to the value used
during the last laboratory calibration.   For those instruments that do not
have an internal electronic calibration check, use calibration gas available
from the manufacturer and adjust the analyzer gain so that the analyzer
response is equal to the value obtained with the same concentration span gas
during the last laboratory calibration.   With the analyzer operating, place
the end of the probe at the centroid of the stack.  Seal off the sampling
port so that no dilution air enters the stack around the probe.   Allow suffi-
cient time for the analyzer response to stabililze (normally from 5 to 90
seconds is sufficient) and record the instrument reading on an appropriate
field data sheet,  such as shown in Figure 5-5.  Be sure to fill in all the
blanks  on the data sheet.
         Avoid sampling during  the first five minutes after an adsorption
bed is  placed on-line as the solvent concentration will tend to be high for
                                    5.2-14

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             Figure 5-5.  Solvent Vapor Field Data Sheet for
                Screening of Carbon Adsorption Systems on
                           Vapor Degreasers
Plant Name
Address
                       Sketch  of
                    Sampling  Location
Analyzer Operator
Date
Run Number
Unit Sampled 	
Sampling Location 	
Adsorber Bed I.D. Number
Adsorber Bed On-Line At
Length of Normal  On-Line Cycle
Analyzer Type 	
Analyzer I.D Number  	
Analyzer Calibration Curve Number
Leak Check Results; Beginning 	
Analyzer Sampling Rate 	
  End
Analyzer Zero Response;  Beginning
Analyzer Span Response;  Beginning
Span Source 	
_,  End
 ,  End
                       Top  View
                       Side View
Time
(24-Hr. Clock)











Analyzer
Range
Setting











Analyzer
Span
Setting










Average
Analyzer
Response
( )











Actual
Concentration
(ppm )











                                  5.2-15

-------
a short time after a bed is switched.  If possible try to obtain measurements
during the last portion of a bed cycle to determine if breakthrough is occur-
ring.  If low concentrations (<25 ppm) are found at the end of a cycle it is
a strong indication that the system is operating in compliance.   If break-
through is found and the measured concentrations exceed the 25 ppm limitation,
then multiple samples should be taken at regular intervals throughout an
entire cycle.  This will allow the calculation of the average emission con-
centration during the cycle.
         At the completion of the sampling run, perform a final  leak check
and check the analyzer zero and span response.  If the system has developed
a leak or if the analyzer has drifted more than 5% for either zero or span,
the run should be repeated.
         Using the calibration curve prepared according to Section 5.2.6.2,
determine the actual solvent concentration that corresponds to the observed
analyzer response.  Record these corresponding solvent concentrations on the
field data sheet.  If multiple samples have been obtained, calculate the
average solvent concentration and enter it on the field data sheet.
                                    5.2-16

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5.3      DRAFT SOURCE TESTING COMPLIANCE VERIFICATION METHOD
         The methodology required for compliance testing requires the use of
accurate instruments, operated by experienced personnel, in a careful and
thorough manner.   The following testing procedure is designed to accurately
determine the average solvent concentration in the exhaust gases of a carbon
adsorption system during a complete adsorption cycle, regardless of whether
the solvent is a single compound or a mixture of compounds.  The procedure
utilizes a gas chromatograph with a flame ionization detector that can be
used to separate a mixture of solvent vapors and determine the concentration
of each component.
         Samples are collected by the integrated bag technique.  A bag is
filled continuously over an entire cycle, yeilding a single sample that repre-
sents an average of the emissions during that cycle.  Three such cycles
should be sampled and the results of the three runs should be averaged to
determine the average emission concentration for the source.  The samples
need not be analyzed in the field, provided the bag samples are properly
protected as outlined in the method.
         The method has not been promulgated as an EPA Reference Method, so
no method number has been assigned at this time.  The method was written in
anticipation that either an NSPS or NESHAP regulation would be promulgated
for drycleaning and degreasing, so it is quite appropriate for testing de-
greaser carbon adsorption systems.  The draft method is reprinted in its
entirety in the sections below.

                                 INTRODUCTION
         Performance of this method should not be attempted by persons un-
         familiar with the operation of a gas chromatograph, nor by those
         who are unfamiliar with source sampling, as there are many details
         that are beyond the scope of this presentation.  Care must be
         exercised to prevent exposure of sampling personnel to hazardous
         emissions.
                                    5.3-1

-------
5.3.1    Principle and Applicability
5.3.1.1  Principle
         An integrated bag sample of stack gas containing one or more halo-
genated organics is subjected to gas chromatographic (GC) analysis, using a
flame ionization detector (FID).
5.3.1.2  Applicability
         The method is applicable to the measurement of halogenated organics
such as carbon tetrachloride, ethylene dichloride, perchloroethylene, tri-
chloroethylene, methylene chloride, 1-1-1 trichloroethane, and trichlorotri-
fluoroethane in stack gases only from specified processes.  It is not appli-
cable where the gases are contained in particulate matter.
5.3.2    Range and Sensitivity
         The procedure described herein is applicable to the measurement of
halogenated organics in the 0.1 to 200 ppm range.  The upper limit may be
extended by further calibration or by dilution of the sample.
5.3.3    Interferences
         The chromatograph column with the corresponding operating parameters
herein described has been represented as being useful for producing adequate
resolution of halogenated organics.  However, resolution interferences may be
encountered on some sources.   Also, the chromatograph operator may know of a
column that will produce a superior resolution of the particular compound of
interest without reducing the response to that compound, as specified in Sec-
tion 5.3.4.3.1.
         In any event, the chromatograph operator shall select a column which
is best suited to his particular analysis problem, subject to the approval of
the Administrator.  Such approval shall be considered automatic provided that
confirming data produced through a demonstrably adequate supplemental analytical
technique, such as analysis with a different column or GC/mass spectoscopy, is
available for review by the Administrator.
5.3.4    Apparatus
5.3.4.1  Sampling
         See Figure 5-6.
                                    5.3-2

-------
Ul
•
OJ

(-0
          FILTER
          (GLASS  WOOL)
                    STACK WALL
                           M
PROBE
TEFLON
SAMPLE LINE
        QUICK
        CONNECTS
        MALE
                                        QUICK
                                        CONNECTS
                                        FEMALE
                                                                                                    FLOW METER
                                        TEDLAR BAG
                                                1X1
                                                                                        CHARCOAL TUBE
                                                    RIGID LEAK-PROOF
                                                    CONTAINER
                                            PUMP
                                   Figure 5-6.  Integrated Bag Sampling  Apparatus  Assembly

-------
         5.3.4.1.1   Probe
         Stainless steel, Pyrex glass, or Teflon tubing according to stack
temperature, each equipped with a glass wool plug to remove particulate
matter if particulate matter is present.
         5.3.4.1.2   Sample Line
         Teflon, 6.4 mm outside diameter, of sufficient length to connect
probe to bag.  A new unused piece is employed for each series of bag samples
that constitutes an emission test.
         5.3.4.1.3   Connections
         Male (2) and female (2) stainless steel quick connects, with ball
checks (one pair without) located as shown in Figure 5-6.
         5.3.4.1.4   Sample Bags
         Tedlar or aluminized Mylar bags, 100 liter capacity.  To contain
sample.
         5.3.4.1.5   Sample Bag Containers
         Rigid leakproof containers for 5.3.4.1.4, with covering to protect
contents from sunlight.
         5.3.4.1.6   Needle Valve
         To adjust sample flow rate.
         5.3.4.1.7   Pump—Leak—Free
         Minimum capacity 2 liters per minute.
         5.3.4.1.8   Charcoal Tube
         To prevent admission of halogenated organics to the atmosphere in
the vicinity of samplers.
         5.3.4.1.9   Flow Meter
         For observing sample flow rate; capable of measuring a flow range
from 0.10 to 1.00 liters per minute.
         5.3.4.1.10  Connecting Tubing
         Teflon, 6.4 mm outside diameter, to assemble sample train (Figure
5-6).
                                    5.3-4

-------
5.3.4.2  Sample Recovery
         5.3.4.2.1   Tubing
         Teflon, 6.4 mm outside diameter, to connect bag to gas chromatograph
sample loop.  A new unused piece is employed for each series of bag samples
that constitutes an emission test, and is to be discarded upon conclusion of
analysis of those bags.
5.3.4.3  Analysis
         5.3.4.3.1   Gas Chromatograph
         With FID, potentiometric strip chart recorder and 1.0 to 2.0 ml
sampling loop in automatic sample valve.  The chromatographic system shall
be capable of producing a response to 0.1 ppm of the halogenated organic
compound that is at least as great as the average noise level.  (Response is
measured from the average value of the baseliine to the maximum of the wave-
form, while standard operating conditions are in use.)
         5.3.4.3.2   Chromatographic Column
         Stainless steel, 3.04 m x 3.2 mm, containing 20 percent SP-2100/0.1
percent Carbowax 1500 to 100/120 Supelcoport.  Other columns can be used,
provided that the precision and accuracy of the analysis of standards are
not impaired.  Information confirming that adequate resolutin of the halogen-
ated organic compound peak is accomplished should be available.  Adequate
resolution is defined as an area overlap of not more than 10 percent of the
halogenated organic compound peak by an interferent peak.  Calculation of
area overlap is explained in Appendix C, Supplement A: "Determination of
Adequate Chromotographic Peak Resolution."
         5.3.4.3.3   Flow Meters (2)
         Rotameter type, 0 to 100 ml/min capacity.
         5.3.4.3.4   Gas Regulators
         For required gas cylinders.
         5.3.4.3.5   Thermometer
         Accurate to one degree centigrade,  to measure temperature of heated
sample loop at time of  sample injection.
                                    5.3-5

-------
         5.3.4.3.6   Barometer
         Accurate to 5 mm Hg, to measure atmospheric pressure around gas
chromatograph during sample analysis.
         5.3.4.3.7    Pump—Leak-free
         Minimum capacity 100 ml/min.
         5.3.4.3.8   Recorder
         Strip chart type, optionally equipped with disc integrator or elec-
tronic integrator.
         5.3.4.3.9   Planimeter
         Optional, in place of disc or electronic integrator, for Section
5.3.4.3.8 to measure chromatograph peak areas.
5.3.4.4     Calibration
            Sections 5.3.4.4.2 through 5.3.4.4.6 are for Section 5.3.7.1
which is optional.
         5.3.4.4.1   Tubing
         Teflon, 6.4 mm outside diameter, separate pieces marked for each
calibration concentration.
         5.3.4.4.2   Tedlar or Aluminized Mylar Bags
         50-liter capacity, with valve; separate bag marked for each calibra-
tion concentration.
         5.3.4.4.3   Syringe
         25//,l, gas tight, individually calibrated, to dispense liquid halo-
genated organic solvent.
         5.3.4.4.4   Syringe
         50/il, gas tight, individually calibrated, to dispense liquid halo-
genated organic solvent.
         5.3.4.4.5   Dry Gas Meter, With Temperature and Pressure Gauges
         Accurate to +_ 2 percent, to aeter nitrogen in preparation of stan-
dard gas mixtures, calibrated at the flowrate used to prepare standards.
                                    5.3-6

-------
         5.3.4.4.6   Midget Impinger/Hot Plate Assembly
         To vaporize solvent.
5.3.5    Reagents
         It is necessary that all reagents be of chromatographic grade.
5.3.5.1  Analysis
         5.3.5.1.1   Helium Gas or Nitrogen Gas
         Zero grade, for chromatographic carrier gas.
         5.3.5.1.2   Hydrogen Gas
         Zero grade.
         5.3.5.1.3   Oxygen Gas or Air as Required by the Detector
         Zero grade.
5.3.5.2  Calibration
         Use one of the following options: either 5.3.5.2.1 or 5.3.5.2.2, or
5.3.5.2.3.
         5.3.5.2.1   Halogenated organic compound
         99 mol percent pure, certified by the manufacturer to contain a
minimum of 99 mol percent of the particular halogenated organic compounds;
for use in the preparation of standard gas mixtures as described in Section
5.3.7.1.
         5.3.5.2.2   Nitrogen Gas
         Zero grade, for preparation of standard gas mixtures as described
in Section 5.3.7.1.
         5.3.5.2.3   Cylinder Standards (3)
         Gas mixture standards (200,  100, and 50 ppm of the halogenated or-
ganic compound of interest,  in nitrogen) for which the gas composition has
been certified with an accuracy of + 3 percent or better by the manufacturer.
The manufacturer must have recommended a maximum shelf life for each cylinder
so that the concentration does not change by greater than +_ 5 percent from
the certified value.  The date of gas cylinder preparation, certified concen-
tration of  the halogenated organic compound and recommended maximum shelf
                                    5.3-7

-------
life must have been affixed to the cylinder before shipment from the gas
manufacturer to the buyer.   These gas mixture standards may be directly used
to prepare a chromatograph calibration curve as described in Section 5.3.7.2.2.
         5.3.5.2.3.1 Cylinder Standards Certification
         The concentration of the halogenated organic compound in nitrogen
in each cylinder must have been certified by the manufacturer by a direct
analysis of each cylinder using an analytical procedure that the manufacturer
had calibrated on the day of cylinder analysis.  The calibration of the analy-
tical procedure shall, as a minimum, have utilized a three-point calibration
curve.  It is recommended that the manufacturer maintain two calibration
standards and use these standards in the following way: (1) a high concentra-
tion standard (between 200 and 400 ppm) for preparation of a calibration
curve by an appropriate dilution technique; (2) a low concentration standard
(between 50 and  100 ppm) for verification of the dilution technique used.
If the difference between the apparent concentration read from the cali-
bration curve and the true concentration assigned to the low concentration
standard exceeds 5 percent of the true concentration, determine the source
of error and correct it, then repeat the three-point calibration.
         5.3.5.2.3.2 Establishment and Verification of Calibration Standards
         The concentration of each calibration standard must have been esta-
blished by the manufacturer using reliable procedures.  Additionally, each
calibration standard must have been verified by the manufacturer by one of
the following procedures, and the agreement between the initially determined
concentration value and the verification concentration value must be within
+ 5 percent: (1) verification value determined by comparison with a gas mix-
ture prepared in accordance with the procedure described in Section 5.3.7.1.1
and using 99 mol percent of the halogenated organic compounds, or (2) verifi-
cation value obtained by having the calibration standard analyzed by the
National Bureau of Standards, if such analysis is available.  All calibration
standards must be reverfied on a time interval consistent with the shelf
life of the cylinder standards sold.
         5.3.5.2.4   Audit Cylinder Standards (2)
         Gas mixture standards identical in preparation to those in Section
5.3.5.2.3 (the halogenated organic compounds of interest, in nitrogen),
                                    5.3-8

-------
 except  the  concentrations  are  only  known to  the  person  supervising  the  analy-
 sis  of  samples.   The  concentrations of  the audit cylinders  should be: one
 low  concentration cylinder in  the range of 25  to 50  ppm, and  one high concen-
 tration cylinder  in the range  of 200 to 300  ppm.  When  available, audit
 cylinders may be  obtained  by contacting:  EPA,  Environmental Monitoring  and
 Support Laboratory, Quality Assurance Branch (MD-77), Research  Triangle
 Park, North Carolina  27711.  If audit cylinders  are  not available at EPA, an
 alternate source  must be secured.
 5.3.6.       Procedure
5.3.6.1      Sampling
             Assemble the sample train as in Figure 5-6.  Perform a bag leak
check according to Section  5.3.7.3.2.  Join the quick connects as illustrated,
and determine that all connections between the bag and the probe are tight.
Place the end of the probe  at the centroid of the stack and start the pump
with the needle valve adjusted to yield a flow of 0.5 1pm.  After a period
of time sufficient to purge the line several times has elapsed, connect the
vacuum line to the bag and  evacuate the bag until the rotameter indicates no
flow.  At all times, direct the gas exiting the rotameter away from sampling
personnel.  Then reposition the sample and vacuum lines and begin the actual
sampling, keeping the rate constant.  At the end of the sample period, shut
off the pump, disconnect the sample line from the bag, and disconnect the
vacuum line from the bag container.  Protect the bag container from sunlight.
5.3.6.2      Sample Storage
             Sample bags must be kept out of direct sunlight and must be
protected from heat.   Analysis must be performed within 1 day of sample
collection for methylene chloride, ethylene dichloride and trichlorotrifluor-
oethane.   Analysis of perchloroethylene, trichloroethylene, 1,1,1-trichloroe-
thane and carbon tetrachloride must be performed within 2 days.
5.3.6.3      Sample Recovery
             With a new piece of Teflon tubing identified for that bag,
connect a bag inlet valve to the gas chromatograph sample valve.   Switch the
valve to receive gas  from the bag through the sample loop.  Arrange the
equipment so the sample gas passes from the sample valve to a 0-100 ml/min
rotameter with flow control valve followed by a charcoal tube and a 0-1 inch
                                    5.3-9

-------
w.g. pressure gauge.  Sample flow may be maintained either by a vacuum pump
or container pressurization if the collection bag remains in the rigid con-
tainer.  After sample loop purging is ceased, allow the pressure gauge to
return to zero before activating the gas sampling valve.
5.3.6.4      Analysis
             Set the column temperature to 100°C, and the detector tempera-
ture to 225°C.  When optimum hydrogen and oxygen flow rates have been deter-
mined, verify and maintain these flow rates during all chromatograph opera-
tions.  Using zero helium or nitrogen as the carrier gas, establish a flow
rate in the range consistent with the manufacturer's requirements for satis-
factory detector operation.  A flow rate of approximately 20 ml/min should
produce adequate separations.  Observe the base line periodically and deter-
mine that the noise level has stabilized and that base line drift has ceased.
Purge the sample loop for thirty seconds at a rate of 100 ml/min, then acti-
vate the sample valve.  Record the injection time (the position of the pen
on the chart at the time of sample injection), the sample number, the sample
loop temperature, the column temperature, carrier gas flow rate, chart
speed and the attenuator setting.  Record the laboratory pressure.  From the
chart, note the peak having the retention time corresponding to the halogen-
ated organic compound peak as determined in Section 5.3.7.2.1.  Measure the
halogenated organic compound peak area, Am, by use of a disc integrator,
electronic integrator, or a planimeter.  Record Am and the retention time.
Repeat the injection at least two times or until two consecutive values for
the total area of the peak do not vary more than 5 percent.  The average
value for these two total areas will be used to compute the bag concentration.
5.3.6.5      Determine Ambient Conditions
             Measure the ambient temperature and barometric pressure near
the bag.  From a water saturation vapor pressure table, determine and record
the water vapor content of the bag as a decimal figure.  (Assume the relative
humidity to be 100 percent unless a lesser value is known.)
5.3.7       Standards, Calibration, and Quality Assurance
5.3.7.1     Standards
                                    5.3-10

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             5.3.7.1.1   Preparation of  Standard Gas Mixtures
             (Optional-delete  if  cylinder  standards are used.)   Assemble the
 apparatus  shown in Figure  5-7.   Check  that  all fittings are  tight.   Evacuate
 a 50-liter Tedlar  or aluminized  Mylar  bag that has passed a  leak check (de-
 scribed  in Section 5.3.7.3.2) and  meter in  about  50  liters of  nitrogen.
 Measure  the barometric  pressure, the relative  pressure at the  dry gas  meter,
 and  the  temperature at  the dry gas meter.   Refer  to  Table 5-2.   While  the
 bag  is filling,  use the 50 yu,l syringe  to  inject through the  septum on  top  of
 the  impinger,  the  quantity required to yield a concentration of 200 ppm.   In
 a like manner,  use the  25  ju,l  syringe to prepare bags having  approximately
 100  and  50 ppm concentrations.   To calculate the  specific concentrations,
 refer to Section 5.3.8.1.   Tedlar  bag  gas mixture standards  of  methylene
 chloride,  ethylene dichloride, and trichlorotrifluoroethane  may be  used  for
 1 day; trichloroethylene and  1,1,1-trichloroethane for 2  days;  perchloroethy-
 lene and carbon tetrachloride for  10 days from the date of preparation.
 (Caution:  Contamination may be a problem  when  a bag  is reused  if  the gas
 mixture  standard is a lower concentration than the previous  gas mixture
 standard.)
 5.3.7.2      Calibration
            5.3.7.2.1  Determination of Halogenated Organic Compound Retention
                       Time
            This section can be performed simultaneously with Section 5.3.7.2.2.
Establish chromatograph conditions identical with those in Section 5.3.6.3
above.  Determine proper attenuator position.  Flush the sampling loop with
zero helium or nitrogen and activate the sample valve.  Record the injection
time, the sample loop temperature, the column temperature, the carrier gas
flow rate, the chart speed and the attenuator setting.  Record peaks and
detector responses that occur in the absence of the halogenated organic.
Maintain conditions (with the equipment plumbing arranged identically to
Section 5.3.6.3), flush the sample loop for 30 seconds at the rate of 100 ml/
min with one of the halogenated organic compound calibration mixtures, and
activate the sample valve.  Record the injection time.  Select the peak that
corresponds to the halogenated organic compound.   Measure the distance on
                                    5.3-11

-------
                              TEFLON	7
                              TUBING   /
                WATER
                MANOMETER
I
M
S3
MIDGET
IMPINGER
                                        THERMOMETER
               SYRINGE
                 l
                SEPTUM
                                                                          BOILING WATER
                                                                          BATH
                                                                                                   INTEGRAL
                                                                                                   VALVE
                                                               HOT PLATE
                                                                                    -TEDLAR BAG
                                                                                    CAPACITY 50 LITERS
                                        ZERO AIR
                                        CYLINDER
                Mgure 5-7.  Apparatus for the Preparation of Calibration Gas Mixtures from Liquid Solvent

-------
                                                             TABLE 5-2
OJ
INJECTION VALUES FOR PREPARATION OF STANDARDS
(Optional, See Section 5.3.7.1.1)
Compound
Perchloroethylene C2C14
Trichloroethylene C2HC13
1,1,1-Trichloroethane C2H3C13
Methylene Chloride CH2C12
Trichlorotrifluoroethane C2C13F3
Carbon Tetrachloride CC14
Ethylene Dichloride CoHAClo
Molecular Wt.
(M)
165.85
131.40
133.42
84.94
187.38
153.84
98.96
fil. Liquid Required in 50 1 N2
Density at 293° K for Approximate Concentration of:
(D) 200 ppm 100 ppm 50 ppm
1.6230
1.4649
1.4384
1.3255
1.5790
1.5940
1.2569
42.5
37.3
38.6
26.6
49.3
40.1
32.7
21.2
18.6
19.3
13.3
24.7
20.1
16.4
10.6
9.3
9.6
6.7
12.3
10.0
8.2

-------
the chart from the injection time to the time at which the peak maximum oc-
curs.  This distance divided by the chart speed is defined as the halogenated
organic compound peak retention time.  Since it is possible that there will
be other organics present in the sample, it is very important that positive
identification of  the halogenated organic compound peak be made*
         5.3.7.2.2  Preparation of Chromatograph Calibration Curve
         Make a gas chromatographic measurement of each standard gas mixture
(described in Section 5.3.5.2.3 or 5.3.7.1.1) using conditions identical
with those listed in Sections 5.3.6.3 and 5.3.6.4.  Flush the sampling loop
for 30 seconds at the rate of 100 ml/min with one of the standard gas mixtures
and activate the sample valve.  Record Cc, the concentration of halogenated
organic injected, the attenuator setting, chart speed, peak area, sample
loop temperature, column temperature, carrier gas flow rate, and retention
time.  Record the laboratory pressure.  Calculate Ac, the peak area multiplied
by the attenuator setting.  Repeat until two consecutive injection areas are
within 5 percent, then plot the average of those two values versus Cc.  When
the other standard gas mixtures have been similarly analyzed and plotted,
draw a straight line through the points.  Perform calibration daily, or be-
fore and after each set of bag samples, whichever is more frequent.
5.3.7.3  Quality Assurance
         5.3.7.3.1  Analysis Audit
         Immediately after the preparation of the calibration curve and
prior to the sample analyses, perform the analysis audit described in Appen-
dix C, Supplement B: "Procedure for Field Auditing GC Analysis."
         5.3.7.3.2  Bag Leak Checks
         While performance of this section is required subsequent to bag
use, it is also advised that it be performed prior to bag use.  After each
use, make sure a bag did not develop leaks as follows: to leak check, connect
a water manometer and pressurize the bag to 5-10  cm 1^0 (2-4 in. 1^0).
Allow to stand for 10 minutes.  Any displacement  in the water manometer
indicates a leak.  Also, check the rigid container for .leaks in  this manner.
(Note: an alternative leak check method is to pressurize the bag to 5-10 cm
H20  or 2-4 in. 1^0 and allow to stand overnight.  A deflated bag indicates
a leak.)  For each sample bag in its rigid container, place a rotameter in

                                     5.3-14

-------
line between the bag and the pump  inlet.   Evacuate  the  bag*   Failure of the
rotameter to register zero  flow when  the  bag  appears  to be empty indicates a
leak.
5.3.8.   Calculations
5.3.8.1  Optional Standards Concentrations
         Calculate each halogenated organic  standard concentration prepared
in accordance with Section 5.3.7.1.1 as follows:
                    (B/ul)  /D//g\ /103Atg\ /Ag-mole\ /24.055A<1\(106)
                    	I /*!''  mg   ; I M  jag  / l/Ag-mole '
                                             m
                  J*P_  (24.055 x 103)
                  M	                          Equation 5-3
                            293   P
                  V      v        -=Jn-
                  vm     Y   Tm   760
Where:
         Cc     - Standard concentration  in  ppm.
         B      - Number of /il injected.
         Vm     " Gas volume measured by  dry gas meter  in  liters.
         Y      = Dry gas meter calibration  factor.
         Pm     • Absolute pressure of the dry  gas meter,  mm Hg.
         Tm     = Absolute temperature of the dry gas meter,  °K.
         D      = Density of compound at  293° K.
         M      - Molecular weight of compound.
         24.055 = Ideal gas constant at 293° K, 760 mm  Hg.
         10"    » Conversion factor, ppm.
5.3.8.2  Sample Concentrations
         From the calibration curve described in Section 5.3.7.2.2  above,
select the value of Cc that corresponds to Ac.  Calculate  Cg  as  follows:
                                      5.3-15

-------
                 CcPrTl
         C  -     c r i
          s   PiTj. (l-Swb)                              Equation 5-4
Where:   Sw^) = The water vapor content of the bag sample, as analyzed.
         Cs  = The concentration of the halogenated organic in the sample  in ppm.
         Cc  = The concentration of the halogenated organic indicated by the gas
               chromatograph, in ppm.
         Pr  = The reference pressure, the laboratory pressure recorded during
               calibration, mm Hg.
         T^  = The sample loop temperature on the absolute scale at the time of
               analysis, °K.
         P£  = The laboratory pressure at time of analysis, mm Hg.
         Tr  = The reference temperature, the sample loop temperature recorded
               during calibration, °K.
5.3.9.   References
         1.  Feairheller, W. R., Kemmer, A. M., Warner, B. J., and   D.  Q.  Doug-
las.   "Measurement of Gaseous  Organic Compound Emissions by  Gas Chromato-
graphy," EPA Contract No. 68-02-1404, Task 33  and 68-02-2818, Work Assignment
3.  January 1978.  Revised August, 1978, by EPA.
         2.  Bulletin 747.  "Separation of Hydrocarbons" 1974.  Supelco, Inc.
Bellefonte, Pennsylvania 16823.
         3.  Communication from Joseph E. Knoll.  Perchloroethylene  Analysis
by Gas Chromatography.  March 8, 1978.
         4.  Communication from Joseph E. Knoll.  Test Method for Halogenated
Hydrocarbons.  December 20, 1978.
                                       5.3-16

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5.4      MATERIAL BALANCE
         A material balance test provides data to quantify the amount of
solvent input into a degreaser over a sufficiently long time period  so that
an average emission rate can be calculated.  This technique is useful where
pounds per hour or pounds per day emission limitations are applicable, such
as with "Rule 66" type regulations.  It may also be useful when an accurate
plant site emissions inventory is required.
         In order to perform a material balance test, the following  general
procedure should be used:
         1.  Fill the solvent sump (or bath) to a marked level.
         2.  Begin normal operation of the degreaser, recording the  quantity
             of make-up solvent and hours of operation.
         3.  Conduct the test for about four weeks, or until the solvent
             loss is great enough to minimize the error in measurement.
         4.  Refill the solvent sump to the original, marked level,  record-
             ing the volume of solvent added.  The total volume of solvent
             added during the test period approximately equals the solvent
             emitted.
         Degreasers that are used in manufacturing operations are in service
often enough such that it is necessary to drain the contaminated solvent
from the sump and recharge it with clean solvent.  Under these circumstances
this cycle (often approximately one week) is long enough to minimize measure-
ment errors.
         Marking the sump liquid level is generally impractical in open top
and conveyorized degreasers due to safety problems (exposure to high solvent
concentrations and heat) and accessability.  An alternative for open top
vapor degreasers is to use a dip stick to record the solvent level.  The
stick should be made of a nonabsorbent material such as metal and care should
be taken not to disturb the air/vapor interface if the sump heat is on.   Also,
precautions should be taken in handling the hot dip stick.  For conveyorized
                                    5.4-1

-------
degreasers the manufacturer's instruction manual should be consulted for

topping off the sump.  This may also be necessary for very large open top

vapor degreasers.

         Although a highly accurate material balance is not usually neces-

sary, the following modifications will improve the accuracy of the test.

         1.  Clean the degreaser sump before testing.

         2.  Record the amount of solvent added to the tank with a flow meter.

         3.  Record the weight and type of work load degreased each day.

         4.  At the end of the test run, pump out the used solvent and mea-
             sure the amount with a flow meter.  Also, approximate the volume
             of metal chips and other material remaining in the emptied
             sump, if significant.

         5.  Bottle a sample of the used solvent and analyze it to find the
             percent that is oil and other contaminants.  The oil and solvent
             proportions can be estimated by weighing samples of used solvent
             before and after boiling off the solvent.  Calculate the volume
             of oils in the used solvent.  The volume of solvent displaced
             by this oil along with the volume of make-up solvent added
             during operations is equal to the solvent emisison.

         Proper maintenance and adjustment should be performed on the de-

greaser and control system before the test period.

         Figure 5-8 illustrates an example material balance data sheet.

The control official or degreaser operator is encouraged to develop a data
sheet that is specific to the particular test being conducted.
                                     5.4-2

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                         Figure 5-8.   Material  Balance  Data Sheet
 1.   BUSINESS LICENSE NAME OF CORPORATION, COMPANY, OR INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY:
 2a.  MAILING ADDRESS
 3.   SOURCE NO. (PERMIT NUMBER,  NEDS  ID.,  ETC.)
                                                            2b.  PLANT ADDRESS WHERE THIS DECREASER  IS LOCATED
 4.   NAME AND TITLE OF AUTHORIZED COMPANY  REPRESENTATIVE FURNISHING DATA:  SIGNATURE:
 5.   TELEPHONE NO.:
 6.   DEGREASER
       MANUFACTURER:
                                                MODEL NO.
        INSIDE DIMENSIONS OF TANK (FT):
WIDE X
                          _SERIAL NO.
                           LONG  X
                                                                                                       DEEP
                                             MATERIAL BALANCE DATA
 7.   BEFORE BEGINNING OPERATION FILL THE CLEANED SOLVENT SUMP TO A MARKED LEVEL AND NOTE APPROXIMATE  DISTANCE
     FROM TOP EDGE OF TANK.
                           DISTANCE FROM TOP  EDGE OF TANK	'              INCHES
8.   BEGIN NORMAL OPERATION OF DEGREASER AND RECORD HOURS OF OPERATION AND MAKE UP SOLVENT ON CHART
                     OF OPERATION
                                                                              MAKE UP SOLVENT
          DATE   TIME
                            DATE
                                      TIME
           TOTAL HOURS OPERATED
DATE ADDED

NUMBER OF GALLONS

                                                                    TOTAL GALLONS ADDED
     OPERATE  UNIT FOR SEVERAL WEEKS OR UNTIL SOLVENT MUST BE CHANGED DUE TO CONTAMINATION.   HALT OPERATION
     AND REFILL SOLVENT SUMP TO ORIGINAL MARKED LEVEL:   RECORD VOLUME OF SOLVENT ADDED.
                   VOLUME OF SOLVENT ADDED AFTER OPERATION HALTED                      GALLONS
10.  TOTAL VOLUME OF SOLVENT USED (ADD 8 & 9)
     TOTAL TIME OF RUN
              GALLONS
              HOURS
11.  IF SIGNIFICANT, ESTIMATE THE VOLUME OF METAL CHIPS  AND OTHER MATERIAL ACCUMULATED IN THE SUMP:
                                                    5.4-3

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    APPENDIX A
LIST OF REFERENCES

-------
                  SOLVENT METAL CLEANING PROCESSES

                         LIST OF REFERENCES


 1.  ASTM, D-26:   Handbook of Vapor Degreasing,  ASTM Special Technical
     Publication 310A, Philadelphia, Pa., April 1976.

 2.  DOW Chemicals,  USA:   Modern Vapor Degreasing and  DOW Chlorinated
     Solvents.   Form No.  100-5185-77.

 3.  Diamond-Shamrock Corp.,  Electro Chemicals Division:   Vapor Degreasing
     Handbook.   EC-S-512.

 4.  Surprenant,  K.S., Richards, D.W., "Study to Support  New Source Per-
     formance Standards for Solvent Metal Cleaning Operations", Dow Chemi-
     cal Company (EPA Contract 68-02-1329, Task Order  No. 9), June 30, 1979.

 5.  Massoglla, M.F., "Industry Characterization and Required Effort to
     Control VOC Emissions:  Solvent Metal Cleaning Processes", Research
     Triangle Institute (EPA Contract 68-01-4141, Task Order No. 16),
     December 1978.

 6.  Danielson, J.A.  (ed.), "Air Pollution Engineering Manual", EPA Publica-
     tion AP-40,  May 1973.

 7.  "Control of Volatile Organic Emissions from Solvent  Metal Cleaning",
     Emission Standards and Engineering Division, U.S. Environmental Pro-
     tection Agency,  EPA Publication EPA-450/2-77-022, November 1977.

 8.  "Handbook of Organic Industrial Solvents",  National  Association of
     Mutual Casualty Companies, Chicago, Illinois, 1958.

 9.  Rhoades, R.G.,  Memorandum to Directors,  Air & Hazardous Materials
     Division,  Regions I, III-X, and Director, Environmental Programs
     Division,  Region II, Subject:  Clarification of Degreasing Regulation
     Requirements,  September 7, 1978.

10.  "Vapor Degreasing Handbook", Diamond Shamrock Corporation.

11.  "Vapor Degreasing With Chlorinated Solvents" Ethyl Corporation, Indus-
     trial Chemicals Division

12.  "Conveyorized  Degreasers", Bulletin 2172.1
     "Cold Trap", Bulletin 2141.9
     "Heavy-Duty Solvent  Recovery Stills", Bulletin 2112.12
     "Three Dip Degreaser", Bulletin 2114.11
     "Liquid-Liquid-Vapor Type", Bulletin 2171.1
     "Carbon Adsorption Systems", Bulletin 2141.8
     "Immersion/Spray Degreasers with Ultrasonic Option", Bulletin 2113.16
     "Vapor Spray Degreaser,  Bulletin 2114.1
     "Solvent Cleaning Systems", Bulletin 2172.2
     "Liquid Vapor  Degreaser", Bulletin 2114.18
     Baron-Blakeslee, Inc., Chicago, Illinois
                                 A-l

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13.   "Perchlorethylene",  Bulletin 35C
     "Trichlorethylene",  Bulletin 35B
     "Tri-Ethane",  Bulletin 35A
     PPG Industries, Inc.,  Pittsburgh,  PA

14.   Pendleton,  G., Kleer Flo Company,  personal communication,  March 9,  1979

15.   "Vapor Spray Degreaser,  Model DH"
     "Vapor Spray Degreaser,  Model NP"
     "Vapor Spray Degreasers, Model DM"
     Delta Industries,  Santa Fe Springs,  CA
                                 A-2

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  APPENDIX B
CTG GUIDELINES

-------
              CONTROL  SYSTEMS  FOR COLD CLEANING



 Control System A

 Control Equipment

       1.  Cover

       2.  Facility for draining cleaned parts

       3.  Permanent, conspicuous label, summarizing the operating requirements

 Operating Requirements:

       1.  Do not dispose of waste solvent or transfer it to another party,
 such  that greater than 20 percent of the waste (by weight) can evaporate
 into  the atmosphere.*  Store waste solvent only in covered containers.

       2.  Close degreaser cover whenever not handling parts in the cleaner.

       3.  Drain cleaned parts for at least IS seconds or until dripping ceases.

 Control System B

 Control Equipment:

       1.  Cover:  Same as in System A, except if (a) solvent volatility is
 greater than  2 kPa  (15 mm Hg or 0.3 psi) measured at 38°C (100°F),**
  (b) solvent  is agitated, or (c) solvent is heated, then the cover must
 be designed  so that it can be easily operated with one hand.  (Covers for
 larger degreasers may require mechanical assistance, by spring loading,
 counterweighting or powered systems.)

       2.  Drainage facility:  Same as in System A, except that if solvent
 volatility is greater than about 4.3 kPa (32 mm Hg or 0.6 psi) measured at
 38°C  (100°F), then  the drainage facility must be internal, so that parts are
 enclosed under the  cover while draining.  The drainage facility may be
 external for  applications where an internal type cannot fit into the cleaning
 system.

       3.  Label:  Same as in System A

       4.  If  used, the solvent spray must be a solid, fluid stream (not a
 fine, atomized or shower type spray) and at a pressure which does not cause
 excessive splashing.

       5.  Major control device for highly volatile solvents:  If the solvent
 volatility is > 4.3 kPa  (33 mm Hg or 0.6 psi) measured at 38°C  (100°F), or
 if solvent is heated above 50°C (120°F), then one of the following control
 devices must  be used:

       a.  Freeboard  that gives a freeboard ratio*** ^ 0.7

       b.  Water cover  (solvent must be insoluble in and heavier  than water)

       c.  Other systems of equivalent control, such as a refrigerated chiller
 or carbon adsorption.

 Operating Requirements:

       Same .is  in System A
  *Water and .solid  waste regulations  must  also be  complied with.
 **Ceneralty Holvcnts consisting  primarily of mineral spirits  (Stoddard) have
   volatilities  - 2 kPa.
***Freebonrd ratio  is defined  as  the  freeboard height divided  by  the width
   of the dc'itrciiHcr.
                                      B-l

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           COMPLETE  CONTROL  SYSTEMS  FOR OPEN  TOP VAPOR  DEGREASERS


Control System A

Control Equipment:

     1.  Cover that  can be  opened and closed easily without disturbing the vapor zone.

Operating Requirements:

     1.  Keep cover  closed  at  all times except when processing work loads through
         the degreaser.

     2.  Minimize solvent carry-out by the following measures:

         a.  Rack parts to  allow full drainage.
         b.  Move parts in  and out  of the degreaser at less than 3.3 m/sec.(ll ft/min).
         c.  Degrease the work load in the vapor zone at least 30 sec. or until
             condensation ceases.
         d.  Tip out any pools of solvent on the cleaned parts before removal.
         e.  Allow parts to dry within the degreaser for at least 15 sec. or until
             visually dry.
     3.  Do not degrease porous or  absorbent materials, such as cloth, leather, wood
         or rope.

     4.  Work loads  should  not occupy more than half of the degreaser's open top area.

     5.  The vapor level should not drop more  than 10 cm (4 in.) when the work load
         enters the  vapor zone.

     6.  Never spray above  the vapor level.

     7.  Repair solvent leaks  immediately, or  shutdown the degreaser.

     8.  Do not dispose of  waste solvent or  transfer it to another party such that
         greater than 20 percent of the waste  (by weight) will evaporate into the
         atmosphere.  Store waste solvent only in  closed containers.
                                                  1           2           '2
     9.  Exhaust ventilation should not exceed 20 m /min. per m   (65  cfm per  ft )
         of degreaser open area, unless necessary  to meet OSHA requirements.  Ventilation
         fans should not be used near  the degreaser opening.

    10.  Water should not be visually  detectable in solvent exiting the water separator.

Control System B

Control Equipment:

     1.  Cover (same as in system A).

     2.  Safety switches.

         a.  Condenser flow switch  and thermostat  -  (shuts off sump neat  if condenser
             coolant is either not  circulating or  too warm).
         b.  Spray safety switch -  (shuts  off  spray  pump  if  the vapor level drops
             excessively, about 10  cm  (4  in).

     3.  Major Control Device:

         Either:  a.   Freeboard ratio  greater  than or  equal  to 0.75,  and  if the  degreaser
                       opening  is >lm  (10  f t ) ,  the  cover  must be powered,
                  b.   Refrigerated  chiller,
                  c.   Enclosed design  (cover or  door opens only when  the  dry  part  is
                       actually entering or exiting the  degreaser),
                  d.   Carbon adsorption system,  with ventilation  >15  nr/min per  m
                       (50 cfm/ft )  of  air/vapor  area (when cover  is  open),  and exhausting
                       <25 ppm  solvent  averaged over  one complete  adsorption cycle,  or
                  e.   Control  system,  demonstrated to have control efficiency,  equiva-
                       lent  to  or better than any of  the above.

     4.  Permanent,  conspicuous label, summarizing operating procedures 01  to 06.

 Operating  Requirement!):

     Snmc  an  In  System A


                                         B-2

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                     CONTROL SYSTEMS FOR  CONVEYORIZED DEGREASERS


Control Syatem A

Control Equipment:   None

Operating Requirements:

     1.  Exhaust ventilation should not  exceed  20 m'/min per oi2  (65 cfm per ft2) of degreaser opening.
unless necessary to meet OSHA requirements.   Work place fans should not be used near the degreaser opening.

     2.  Minimize carry-out emissions by:

     a.  Racking parts  for best drainage.
     b.  Maintaining verticle conveyor speed  at < 3.3 m/mln  (11  ft/nin).

     3.  Do not dispose  of waste solvent or  transfer it to another party  such that greater than 20 percent
of the waste (by weight) can evaporate into  the atmosphere.  Store waste  solvent only  In covered containers.

     4.  Repair solvent  leaks Immediately, or shutdown the degreaser.

     5.  Water should not be visibly detectable In the solvent exiting the water separator.

Control System B

Control Equipment:

     1.  Major control  devices; the degreaser must be controlled by either:

     a.  Refrigerated chiller,
     b.  Carbon adsorption system, with ventilation _> IS m2/mln  per m2  (50 cfm/ft2) of air/vapor area
(when down-time covers  are open),  and exhausting <25 ppm of  solvent by volume averaged over a complete
adsorption cycle, or
     c.  System demonstrated to have control efficiency equivalent to or  better  than either of  the above.

     2.  Either a drying tunnel, or another  means such as rotating (tumbling) basket,  sufficient to prevent
cleaned parts from carrying out solvent liquid or vapor.

     3.  Safety switches

     a.  Condenser flow switch and thermostat - (shuts off  sump  heat If coolant  Is either  not circulating
or too warm).
     b.  Spray safety switch - (shuts off spray pump or conveyor if the vapor level drops  excessively,
e'.g. > 10 en (4 in)).
     c.  Vapor level control thermostat - (shuts off  sump heat when vapor level  rises  too  high).

     4.  Minimized openings:  Entrances and  exits should silhouette work  loads so  that the average clearance
(between parts and the  edge of the degreaser opening)  Is either  <10 cm  (4 In.) or  <10  percent of the width
of the opening.

     5.  Down-time covers:  Covers should be provided  for closing off the entrance and exit during shutdown
hours.

Operating Requirements:

     1.  to 5.  Same as for System A

     6.  Down-time cover must be placed over entrances and  exits of conveyorized degreasers immediately after
the conveyor and exhaust are shutdown and removed just before  they are  started up.
                                            B-3

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               APPENDIX C
SUPPLEMENT A:  DETERMINATION OF ADEQUATE
               CHROMATOGRAPHIC PEAK RESOLUTION
SUPPLEMENT B;  PROCEDURE FOR FIELD AUDITING
               GC ANALYSIS

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                            SUPPLEMENT A
     DETERMINATION OF ADEQUATE CHROMATOGRAPHIC PEAK RESOLUTION
     In this method of dealing with resolution, the extent to which
one chromatographic peak overlaps another is determined.
     For convenience, consider the range of the elution curve of
each compound as running from -2a  to +2a.   This range is used in
other resolution criteria, and it contains  95.45 percent  of the
area of a normal curve.  If two peaks are separated by a  known
distance, b, one can determine the fraction of the area of one
curve that lies within the range of the other.  The extent to which
the elution curve of a contaminant compounds overlaps the curve
of a compound that is under analysis is found by integrating the
contaminant curve over the limits b-2a  to  b+2a ,  where a  is the
                                      s        s         s
standard deviation of the sample curve.
     There are several ways this calculation can be simplified.
Overlap can be determined for curves of unit area  and then actual
areas can be introduced.  The desired integration  can be  resolved
into two integrals of the normal distribution function for which
there are convenient calculation programs and tables.  An example
would be Program 15 in Texas Instruments Program Manual ST1, 1975,
Texas Instruments Inc., Dallas, Texas 75222.
Jc    dt  =
   b-2o.
                                       x_
                                       2
                                           dx -
x_
2
                                                                       dx.
                                   C-1A

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The following calculation steps are required:*
1.    2ac   = t//2 In 2
        S      S
2.    a,    = t 72/2 In 2
       c       c
3.
            = (b-2as)/ac
4.
              (b+2as)/cc
5.
                            dx
6.    Q(x9) =
7.    I.
                  i
                         _x_

                         2
                            dx
                    - Q(x2).
8'    Ao    = WAs
9.    % overlap = AQ x 100
   (Note:  In most instances, Q(x2) is very small and may be neglected.)
                                      C-2A

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Where:
     A      = The area of the sample peak of interest determined
              by electronic  integration, or by the formula AS • hstg.
     A      = The area of the contaminant peak, determined in the
      c
              same manner as Ag.
     b      = The distance on the chromatographic chart that
              separates  the  maxima  of  the two peaks.
      h      = The peak  height of the sample compound of interest,
              measured  from  the average value of the baseline to
              the maximum of the curve.
      t      = The width of  the  sample  peak of interest at  1/2 of
              peak  height.
      t      = The width of  the  contaminant peak at  1/2 of  peak
       C
              height.
      0      = The  standard  deviation  of the sample  compound  of
               interest elution  curve.
      a      =  The  standard  deviation  of the contaminant elution
               curve.
      Q(xJ  •  The  integral  of the  normal  distribution  function  from
               X-, to infinity.
      Q(x2)  = The integral  of the  normal  distribution  function  from
               x2 to infinity.
      I      = The overlap integral.
      A      = The area overlap fraction
       o
                                       C-3A

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     In judging the suitability of alternate gas chromatographic
columns, or the effects of altering chromatographic conditions,
one can employ the area overlap as the resolution parameter with
a specific maximum permissible value.
     The use of Gaussian functions to  describe chromatographic
elution curves is widespread.   However, some elution curves are
highly asymetric.  In those cases  where the sample peak is
followed by a contaminant that has a leading edge that rises
sharply but the curve then tails off,  it may be possible to
define an effective width for  tc as "twice the distance from the
leading edge to a perpendicular line through the maxim of the
contaminant curve, measured along  a perpendicular bisection of
that line."
                                    C-4A

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                            SUPPLEMENT B
           PROCEDURE FOR FIELD AUDITING GC ANALYSIS
     Responsibilities of audit supervisor and analyst at the
source sampling site include the following:
     A.  Check that audit cylinders are stored in a safe location
both before and after the audit to prevent vandalism of same.
     B.  At the beginning and conclusion  of the audit, record  each
cylinder number and cylinder pressure.  Never analyze an audit
cylinder when the pressure drops below 200 psi.
     C.  During the audit, the analyst is to perform a minimum
of two consecutive analyses of each audit cylinder gas.  The audit
must be conducted to coincide with the analysis of source test
samples.  Normally, it will be conducted immediately after the GC
calibration and prior to the sample analyses.
     D.  At the end of the audit analyses, the audit supervisor
requests the  calculated concentrations from the analyst, and then
compares the  results with the actual audit concentrations.  If each
measured concentration agrees with the respective actual concentra-
tion within +_10  percent, he then directs  the analyst to begin the
analysis of source  samples.  Audit supervisor judgment and/or
supervisory policy  determines course of action when agreement is
not within +_ 10 percent.  Where a consistent bias in excess of
 10 percent  is found,  it may be  possible to proceed with the sample
 analyses, with a  corrective factor to  be  applied to the results
 at a  later  time.   However,  every  attempt  should  be made to locate
 the cause  of  the  discrepancy, as  it may be misleading.  The audit
                                    C-IB

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supervisor is to record each cylinder number, cylinder pressure
(at the end of the audit) and all  calculated concentrations.  The
individual being audited must not under any circumstance be told
the actual audit concentrations until the calculated concentrations
have been submitted to the audit supervisor.
                               C-2B

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                        FIELD AUDIT REPORT
PART A - To be filled out by organization supplying audit
         cylinders
     1.  Organization supplying audit sample(s)  and shipping address

     2.  Audit supervisor, organization, and phone number
     3.  Shipping instructions - Name, Address, Attention
     4.  Guaranteed arrival date for cylinders_
     5.  Planned shipping date for cylinders	
     6.  Details on audit cylinders from last analysis
                                                Low Cone.   High Cone,
         a.  Date of last analysis              	   	
         b.  Cylinder number                    	   	
         c.  Cylinder pressure, PSI             	   	
         d.  Audit gas(es)/balance gas	   	
         e.  Audit gas(es) ppm                  	   	
         f.  Cylinder construction              	   	

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PART B - To be filled out by audit supervisor
     1.  Process sampled	
     2.  Location of audit
     3.  Name of individual  audited
     4.  Audit date
     5.  Audit results
                                             Low Cone.     High  Cone.
                                             Cylinder     Cylinder
         a.  Cylinder number                 	
         b.  Cylinder pressure before        	
             audit, psi
         c.  Cylinder pressure after         	
             audit, psi
         d.  Measured concentration, ppm
             Injection #1*                   	
             Injection #2*                   	
             Average *                       	
         e.  Actual audit concentration, ppm 	     	
             (Part A, 6e)
*  Results of two consecutive injections which meet  the  sample
   analysis criteria of the test method.

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f.   Audit accuracy*
    Low Cone. Cylinder
    High Cone. Cylinder
    *  Percent accuracy = Measured Cone.  - Actual  Cone.  x  10Q
                                  Actual  Cone.
g.  Problems detected (if any)	

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 DEPORT NO.
 EPA-340/1-79-008
                              2.
                                                            3. RECIPIENT'S ACCESSION>NO.
 TITLE AMD SUBTITLE
 Inspection Source Test Manual for
 Solvent Metal  Cleaning (Degreasers)
                                                             . REPORT DATE
              June 1979 fflal-P  nf
            6. PERFORMING ORGANIZATION CODE
 AUTHOR(S)

 Roger D. Allen
                                                             8. PERFORMING ORGANIZATION REPORT NO.
 PERFORMING ORGANIZATION NAME AND ADDRESS
 Engineering-Science
 501 Willard Street
 Durham, North  Carolina 27701
                                                             10. PROGRAM ELEMENT NO.
             11. CONtRACT/GRANT N6.

               68-01-4146
2. SPONSORING AGENCY NAME AND ADDRESS
  U.S. Environmental Protection Agency
  Division  of  Stationary Source Enforcement
  401 M Street SW
  Washington,  D.C.  20460                	
             13. TYPE OF REPORT AND PERIOD COVERED
               Final
             14. SPONSORING AGENCY CODE
5. SUPPLEMENTARY NOTES
                     Chapter authors  are R.  D. Allen, J.  T.  Chehaske,
                     T.  A. Li Puma and  J.  Van Gieson
6. ABSTRACT

  This document  presents guidelines  to enable field enforcement personnel  to determine
  whether solvent metal cleaning  processes (degreasers)  are in compliance  with EPA's
  guidelines  for Reasonably Available Control Technology.   Conveyorized  degreasers,
  open top vapor degreasers and cold cleaners are discussed.   Principles of operation,
  emissions points,  parameters that  effect emissions,  emission control methods and field
  investigation  procedures are described.   Suggested screening and compliance test
  methods are provided.  Inspection  methods and types  of records to be kept are dis-
  cussed  in detail.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                                b.IDENTIFIERS/OPEN ENDED TERMS
                            c. cos AT I Field/Group
  Air Pollution
  Solvent Metal Cleaning (Degreasing)
  Emissions  and Controls
 Air Pollution Controls
 Stationary Sources
 Organic Vapors
 Degreasing
13. DISTRIBUTION STATEMENT
  Available  from the National Technical
  Information  Service, 5285 Port Royal Road,
  Springfield,  Virginia 22161
19. SECURITY CLASS (ThisReport)
 Unclassified
                                                                            21. NO. OF PAGES
20. SECURITY CLASS (This page)

 Unclassified
                            22. PRICE
EPA Form 2220-1 (9-73)
                                                                   «U.S. GOVERNMENT PRINTING OFFICE: 1979 628-90:

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