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                   Air  Act

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    for Solvent
  Regulatory Strategies for Manufacturers Affected by the Clean

  Air Act Amendments NESHAP for Haiogenated Solvent Cleaners
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                  April 1995
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    The University of Tennessee Center for Industrial Services

     Tennessee Department of Environment and Conservation
                   	.,.' '. ''... .'" "'""•,.,. ... ', '


-------
About the Sponsors
EPA's Education and Outreach Group of the Office of Air Quality Planning and
Standards manages the programs such as the Air Pollution Training Institute (APTI),
the Distance Learning Network (satellite broadcasts), and international training. Through
APTI, courses in permitting, engineering, ambient and source monitoring, compliance,
and dispersion modeling are offered using various formats including television, class-
room, and self-instructional delivery methods. In late 1994, the EOG also became
responsible for the Environmental Education Program and an evolving outreach pro-
gram because of the recognized need to build new and strengthen existing partner-
ships.

EPA's federal Small Business Assistance Program was established to provide tech-
nical support to the state small business stationery source technical and environmental
compliance assistance programs. The federal SBAP is located within the Office of Air
Quality Planning & Standards Control Technology Center (CTC), a leader in providing
technical assistance to state and local agencies. The federal SBAP is run in cooperation
with several EPA assistance centers including the Pollution Prevention Information
Center, the Chemical Emergency Preparedness and Prevention Office (CEPP), and the
Emission Measurement Technical Information Center.

EPA's Office of the Small Business Ombudsman provides a convenient way for
small business to access EPA, facilitates communication between the small business
community and EPA, investigates and resolves  disputes with EPA, and works with EPA
personnel to increase their understanding of small businesses in development of en-
forcement and environmental regulations.

Tennessee's Small Business Assistance Program is located with the Tennessee
Department of Environment and Conservation's Division of Pollution Prevention  and
Environmental Awareness. Its role of employer assistance to those regulated under the
Clean Air Act Amendments is guided by the State  Ombudsman.

Tennessee Valley Authority is a resource development arm of the federal government
committed to environmental leadership supporting creative solutions to environmental
problems. Through public and private partnerships, TVA promotes sustainable eco-
nomic developments by educating corporate America on the value of waste reduction.

The University of Tennessee Center for Industrial Services has been Tennessee's
industrial statewide extension program for more than 30 years. CIS provides technical
and managerial assistance to Tennessee manufacturers to help them prosper. CIS
helps manufacturers with a wide range of industrial issues from the environment to
electronic data interchange. This manual was prepared by Todd Thomas, M.S., UT CIS
waste reduction consultant.

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Foreword
          Modern American society has grown dependent on small business
          which provide services that make life easier. From the dry
          cleaner to the corner print shop to metal finishing employers,
small businesses have seen increasing demands placed on them to operate
without detriment to the environment.

Air pollution control regulations are very complex to small businesses,
which may not be able to afford lawyers or environmental specialists to
help them comply with all the requirements they may be responsible for in
the new act. Many may be hard pressed to interpret the most basic
requirements and deadlines of the control programs that will affect them,
let alone the more complicated control issues.

Varying efforts by government are being required to meet the needs of
small business. Satellite teleconferencing, accompanied by workbooks such
as this, is believed to be one of the most cost-effective delivery techniques.
By this means, we can distribute understandable compliance information
which is uniform among the states as new federal regulations impact other
heretofore unregulated small business sources.

This workbook and accompanying satellite teleconference were produced
by the University of Tennessee Center for Industrial Services and Center for
Telecommunications and Video in partnership with those concerned about
helping small business.

Indeed, we are appreciative of all our federal, state, and private sector
partners who make training events such as this possible.

Karen Brown                                  Deborah Elmore
Small Business Ombudsman                         Federal SBAP Coordinator
US EPA                                     US EPA
Washington, DC                                Research Triangle Park, NC
Ernie Blankenship                                Cam Metcalf
Small Business Advocate                            Training Manager
The State of Tennessee                             UT Center for Industrial Services
Nashville, TN                                  Nashville, TN

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Table of Contents
ABOUT THIS BOOK	3

   How this book is arranged	4

CHAPTER 1 INTRODUCTION	5

   What is this regulation?	5
   Who is covered?	5
   When are the deadlines	6

CHAPTER 2 NAVIGATING THE REGS	7

CHAPTER 3 COMPLIANCE STRATEGIES	12

   Administrative Duties	12
   Compliance Alternatives	12
   Details of Control Combinations	14
   Details of the Idling Emissions Method	25
   Details of the Alternative Standards Method	27
CHAPTER 4 RECORDKEEPING & REPORTING	35

   Recordkeeping	12
   Reporting	36
GLOSSARY	42

APPENDICES

 A Cold Batch Cleaning	44
 B Reduce Methyl Chloroform Emissions for Environmentally Sound
   Vapor Degreasing	45
 C Percent by Weight Solvent Determination	46
 D Title V Overview	47
 E Operator Test	48
 F Sample Recordkeeping Forms	49
 G Alternative Standards: Monthly Emissions Worksheet	50
 H Cleaning Capacity	51
 / Sample Reporting Forms	52
 J Resources (EPA numbers and equipment suppliers info.)	53

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Table of Contents
TABLES

  1. Important Dates for Compliance	6
  2. Required Elements for Each Compliance Method...	 4
  3. Small Batch Vapor	18
  4. Large Batch Vapor	19
  5. Existing In-Line	19
  6. New In-Line	 19
  7. Temperature Requirements for Freeboard Refrigeration Devices
   	20
  8. Idling Emission Rates for Each Degreaser Type	25
  9. Emission Limits for Batch Vapor and In-Line Solvent Cleaning
   Machines with a Solvent/Air Interface	33
  10. Emission Limits for Machines without Solvent/Air Interface ... 34

FIGURES

  1. How the Book is Arranged	4
  2. Offset Condenser Vapor-Spray-Vapor Degreaser.........	8
  3. Degreaser with Lip Exhaust	8
  4. Liquid-Liquid Vapor Degreaser, 2 Compartment	9
  5. Liquid-Liquid Vapor Degreaser, 3 Compartment	9
  6. Vapor-Spray-Vapor Monorail Degreaser	10
  7. Compliance Steps	15
  8. Idling Emissions Method	..26
  9. Alternative Standards	„	10

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About  this book
This manual will help you understand the National Emission Standards for
Hazardous Air Pollutants (NESHAPS) for halogenated solvent cleaners.
After you gain a clear understanding of the law and its requirements, you
can make a better decision on how to comply with it. Thus, this book
focuses on explaining the regulation.  After finishing, you should be able to
answer these questions:

   • What is the law's intent?

   • What are the details of each option?

   • What is required with each option?

   • What records must I keep?

   • What reports must I submit?

   • How often must I submit reports?

Please note that this book applies only to batch vapor or in-line
degreasers using halogenated solvents (either pure or blended). Please
refer to Appendix A for regulatory information if you use a batch cold
degreaser.

US EPA has also prepared a publication, "Guidance Document for the
Halogenated Solvent Cleaner NESHAP," to aid small business in
determining if the NESHAP rule applies to them and their options for
compliance. For a copy of the guidance document, contact the EPA Office
of Air Quality Planning and Standards at (919) 541-2777 or contact your
state SBAP office. For on-line/electronic copies, call the Technology
Transfer Network Bulletin Board helpline at (919) 541-5384. Appendix B
contains an article by DOW Chemical on reducing solvent use and
minimizing emissions.

Unfamiliar terms appear in the glossary at the end of this book. Words
which you see bold faced in italics are glossary terms.

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4
About this Book
                 How this book is arranged
                 This book explains the compliance techniques mandated by the NESHAP
                 vapor degreasing regulations. Use whichever technique best fits your
                 operation. However, familiarize yourself with each method before making
                 a decision.

                 Figure 1  shows an overview of the book. Chapter 1 introduces the law,
                 who must comply, and important deadlines. Chapter 2 gives an overview
                 of the regulation's structure to help you understand the law. Chapter 3
                 describes the administrative, monitoring, and performance details
                 associated with each compliance technique. The final chapter discusses
                 recordkeeping and reporting. Here is where you'll find items that you  must
                 track for each method and information required for each report.
                                                 Chapter 1

                                                Introduction
                                                 Chapter 2

                                             Regulatory Structure
                                                 Chapter 3

                                             Compliance Methods

                                        • Overview
                                        • Administrative Requirements
                                        • Compliance Alternatives
                                                 Chapter 4

                                               Recordkeeping

                                        • Control Options
                                        • Idling Emissions
                                        • Alternative Standards

                                            Reporting (all methods)

                                        • Initial Notification
                                        - Initial Stmt. of Compliance
                                        - Annual Reports
                                        - Exceedance reports
                 FIGURE 1 HOW THE BOOK IS ARRANGED

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Chapter 1     Introduction
What is this regulation?
On December 2, 1994, the Environmental Protection Agency (EPA)
published the National Emission Standards for Hazardous Air Pollutants
for Halogenated Solvent Cleaning (59 CFR 61801). The law falls under the
authority of Section 112 of the 1990 Clean Air Act Amendments. You can
find the regulation in 40 Code of Federal Regulations Part 63, Subpart T.
The regulation focuses on reducing the emissions of selected halogenated
solvents used in parts cleaning. The compliance methods center around
best operating practices and pollution prevention techniques.


Who is covered?
Owners and operators of degreasers using the following solvents:

            • methylene chloride      • perchloroethylene

            • 1,1,1-trichloroethane     • trichloroethylene

            • chloroform             • carbon tetrachloride

Note:  Blended cleaning solvents must contain a total regulated solvent
content below 5 percent by weight to be exempted from regulation. To
determine the solvent content, contact your vendor, use your Material
Safety Data Sheets, or use EPA Test Method 181. Appendix C contains
worksheets to help you determine the regulated solvent content of your
cleaning solution.


When  are the deadlines?
Table 1 on the next page summarizes key deadlines for compliance. Other
important deadlines appear in Chapter 4 Reporting and Recordkeeping.
1 Test methods are available from EPA's Office of Air Quality Planning & Standards or their bulletin board
 system (BBS) at (919) 541-5742.

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Chapter One  Introduction
                TABLE 1 IMPORTANT DATES FOR COMPLIANCE
Machine
Type
Existing
New
Initial
Notification
August 29, 1995
January 31, 1995"
Compliance
Deadline
December 2, 1 997
Immediate
Initial Statement
of Comoliance
May 1, 1998
150 days after start-up
*You must operate your machines within the provisions of this regulation
"or as soon as practicable before construction or reconstruction if after December 2,
1994.
                Existing sources are degreasers for which construction or reconstruction
                began on or before November 29, 1993.

                New sources are degreasers for which construction or reconstruction
                began after November 29, 1993.

                Title V applicability: Users of halogenated solvent cleaners must obtain a
                Title V permit under 40 CFR Part 70. However, some states may waive the
                permit requirement. Check with EPA to determine your responsibilities.
                This manual does not cover Title V.  For further information on the CAAA
                and Title V, please see Appendix D.

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Chapter!  Navigating the Regs

The regulation seeks to reduce emissions of the six halogenated cleaners
listed on page five through better operating practices and pollution           lfi
prevention techniques. As a result, the law offers several compliance
techniques.

Your responsibilities for each technique vary depending on your
degreaser. The regulation categorizes degreasers in two classes based on
machine type: batch vapor and in-line cleaners. See Figures 2 through 6
for examples of each machine.

EPA classifies batch vapor degreasers in two sizes, small and large,
based on the machine's solvent/air interface area. Small batch
degreasers have a solvent/air  interface area less than or equal to 13 ft2
(1.21 m2). Large degreasers have an interface area greater than 13 ft2.

In-line degreasers are either existing or new. They can use either a cold
or vapor process to clean parts. Existing in-line degreasers are those for
which construction, or reconstruction, began on or before November 29,
1993.  EPA classifies all others degreasers as new.

Three primary methods exist for regulatory compliance:

      • Control combinations;

      • Idling emissions;

      • Alternative standards.

The specifics of each method depend on your machine type. Carefully
consider your operation before making a decision; then choose the
method that best fits your situation. Here's a brief overview of each
method.

Control combinations: You may choose combinations of control
technologies to reduce solvent releases. Your type of degreaser
determines which group of control combinations you use. A set of
minimum equipment design standards and operation practices accompany
this method. Your reporting and monitoring requirements also depend on
which group you choose.

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8

Chapter Two  Navigating the Regs
             FREE
            BOARD
             WATER
             JACKET
      HEAT SOURCE
       FLEXIBLE HOSE

    SPRAY LANCE

VAPOR LEVEL
                                                               CONDENSING
                                                               COIL
                                                                CONDENSATE
                                                                TROUGH
                                                                WATER
                                                                SEPARATOR
                                       CONDENSATE
                                       RESERVOIR
                                         SPRAY
                                         PUMP
                                             BOILING SUMP
               FIGURE 2  OFFSET CONDENSER VAPOR-SPRAY-VAPOR
               DEGREASER
                                                   EXHAUST INLET
                                                               EXHAUST DUCT
                                                 • CONDENSING UNIT


              FIGURE 3 DEGREASER WITH LIP EXHAUST

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                                              Chapter Two  Navigating the Regs
FREE
BOILING SUI\
BOARD
r
L
/IP


c
-c
•••*






CONDENSATE TROUGH\
VAPOR LEVEL — . \ t
> \ \ 9
>\ \ A


















O













f
APOR





P


















ZONE i-^^^V^v



-

CONDENSING COILS
xWATER JACKET
-* i 	 1 /WATER SEPARATOR
=| 9 Y
___-CONDENSATE RESERVOIR
                HEAT SOURCE
FIGURE 4  LIQUID-LIQUID-VAPOR DEGREASER, 2 COMPARTMENT
                  WORK FLOW
    FREE
BOARD
                                  CONDENSING COILS
             ^  VAPOR LEVEL	\  CONDENSATE TROUGH    \
             9             \               \    9
               ^^•^/•^ VAPOR ZONE;
HOT SOLVENT
RESERVOIR
                                                   /WATER JACKET
                                                        WATER
                                                        SEPARATOR
                                                      CONDENSATE
                                                      RETURN


                                                      BOILING SUMP
             HEAT SOURCE
                       WARM RINSE
                                    HEAT SOURCE
 FIGURE 5  LIQUID-LIQUID-VAPOR DEGREASER, 3 COMPARTMENT

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10
Chapter Two  Navigating the Regs
        PART TRAVEL
                         TO ADSORPTION DEVICE
                         OR ATMOSPHERE
                  C^D
                   BOILING SUMP

                        HEAT SOURCE
SOLVENT SPRAY
RESERVOIR
                                                                      CONDENSATE
                                                                      TROUGH
                FIGURE 6 VAPOR-SPRAY-VAPOR MONORAIL DEGREASER

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                                                                              11
                                                Chapter Two  Navigating the Regs
Idling emission standards: This technique combines the minimum
equipment design and operating practices with emission limits. You may
use additional controls and techniques to meet the limits.

Alternative standards: You reach compliance with this method by
meeting halogenated solvent emission limits from each machine as
calculated on a three-month rolling average basis. You can use any
means necessary to meet the emission limits. However, you might need to
adopt several pollution prevention techniques to obtain compliance.
      NOTE: EPA allows another route to compliance—the
      equivalent methods of control. Under it, you can develop your
      own techniques, using either equipment or workplace
      practices, to meet compliance. However, EPA or your local air
      authority must approve your procedures. Your application
      must include a complete description of the equipment or
      procedure; the proposed equivalency testing procedure; and
      the date, time, and location for the equivalency demonstration.
      Because every situation is unique, this method is not covered
      in this manual. Submit the application to your regional office,
      or contact your local air authority for more information. The
      Small Business Assistance Program in your state can assist
      you in submitting your application.

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12
                Chapter 3    Compliance Methods

                This chapter provides the details needed to comply with this regulation.
                First you will find an overview of the administrative duties and compliance
                techniques. The next sections describe the details of each method.

                ADMINISTRATIVE DUTIES
                Administrative duties such as monitoring, recordkeeping, and reporting
                are included with this regulation. Some of the reporting information is the
                same (for example, initial notifications) regardless of your compliance
                method. However, the overall reporting content varies greatly with each
                method. The four types of reports are:

                     • Initial notification

                     • Initial statement of compliance

                     • Annual report

                     • Exceedance report

                COMPLIANCE ALTERNATIVES
                As mentioned earlier, three primary methods of compliance exist:

                     • Control combinations

                     • Idling emissions

                     • Alternative standards

                Each method differs in its techniques to reduce emissions. Table 2
                outlines the required techniques used with each method.

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                                                                                13
                                               Chapter Three  Compliance Methods
TABLE 2 REQUIRED ELEMENTS FOR EACH COMPLIANCE METHOD

Control Comb.
Idling Emissions
Alternative Standards
Equip.
Design
X
X
n/a
Control
Comb.
X
n/a
n/a
Operating
Practices
X
X
n/a
Emission
Limits

X
X
Control Combinations Method
This method requires three items to meet compliance: using a degreaser
that meets a minimum equipment design, adopting mandated operating
practices, and using a group of control technologies. Equipment design
and operating practices lay the groundwork for reducing emissions. Using
a combination of controls helps further minimize your solvent emissions.
One appealing characteristic of this method is that it has no emission
limits. You are only responsible for  using a control group and meeting
performance and administrative requirements.

EPA uses seven technologies to make up the control combinations. The
combinations consist of either two or three control technologies depending
on your degreaser. The technologies range from simple and inexpensive
to complex and costly. The seven controls EPA used to create the
combinations include:
            • Working mode cover;

            • Dwell time;

            • Freeboard refrigeration;

            • Reduced room draft;
Carbon adsorber;

Freeboard ratio of 1.0;

Superheated vapor.
Some machine types have more control combinations available. The
different combinations give you flexibility in picking a compliance method.
Idling Emissions
Emission limits are the basis of this method. The emission rate depends
on the machine, and as with the control combinations method, you must

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14
Chapter Three   Compliance Methods
                 use the minimum equipment designs and operational practices prescribed
                 by EPA. However, you can use any additional techniques (controls or
                 operating procedures) to meet the limits. But, you must inform EPA of
                 your method and a procedure to monitor its performance.

                 Alternative Standards
                 Like idling emissions, this method is emissions based. However, this
                 method has no equipment or operational requirements. The only
                 requirement is that solvent emissions, based on a three-month rolling
                 average, be kept below certain  limits. The machine type determines these
                 limits. Meeting the emission limits may prove challenging to owners and
                 operators of large degreasers.

                 DETAILS OF CONTROL COMBINATIONS
                 As mentioned, the control combination method consists of three items to
                 meet compliance:

                       • Installing controls to meet a minimum design requirement;

                       • Adopting certain operating practices;

                       • Using a predefined group of control technologies.

                 Figure 7 is a flowchart you can follow to meet compliance. First, you
                 should meet the required equipment design. Next, train your workers to
                 use the prescribed workplace practices. After implementing workplace
                 practices, choose a control combination and establish a monitoring
                 program to ensure their proper operation. Next, develop a recordkeeping
                 system to track the control's performance. Finally, report the required
                 information to EPA on time.

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                                                                             15
                                             Chapter Three  Compliance Methods
                           Equipment
                             Design
                           Workplace
                            Practices
                              I
                            Choose a
                            Control
                          Combination
                              I
                            Establish
                           Monitoring
                            Programs
                              I
                          Recordkeeping
                           Reporting
FIGURE 7 COMPLIANCE STEPS

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16
Chapter Three  Compliance Methods
                Minimum Equipment Design
                This section describes the minimum design features your degreaser must
                have. These requirements apply to both classes of batch vapor and in-line
                degreasers. New machines may have the equipment in place, while older
                models may need retrofitting. If your machine already has the equipment,
                ensure that it can meet performance requirements. These are EPA's
                requirements:

                     • An idling and downtime mode cover OR reduced room draft;

                     • A freeboard ratio of at least 0.75;

                     • An automated parts handling system that moves parts slower
                      than 11 feet per minute (3.4 meters per minute) during the entire
                      cleaning cycle (for example, parts loading through removal);

                     • An automatic shut-off for the sump heater when the solvent level
                      drops to the sump heater coils;

                     • A vapor level control device that shuts off sump heat if the vapor
                      level rises above the primary condenser;

                     • A primary condenser above the vapor zone;

                     • A carbon adsorber if a lip exhaust is used to collect solvent
                      vapors.

                NOTE: There are monitoring and  recordkeeping  requirements if you use a
                       hoist.
                Required Workplace Practices
                In addition to the minimum equipment design, EPA requires that users
                choosing this compliance route adopt certain workplace practices which
                center around pollution prevention. This list suggests ways to reduce
                solvent loss, regardless of your compliance method:

                     • Minimize air flow across the opening of the degreaser by covering
                      the it during idling and downtime OR reducing room draft;

                     • Operate open-top batch vapor cleaning machines so the size of
                      parts or part baskets to less than 50 percent of the machine's
                      solvent/air interface OR reduce the entry speed of the parts or
                      part baskets into the degreaser to less than 3 feet per minute (0.9
                      meters per minute);

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                                                                                   17
                                                Chapter Three  Compliance Methods
     • Conduct spraying operations within the degreaser—ideally, spray
      within the vapor zone or in a baffled or enclosed area within the
      machine;

     1 Place parts so they do not capture or trap solvent—for example,
      orient parts with cavities down to prevent solvent accumulation. Tip
      or rotate parts to remove excess solvent trapped in recessed
      cavities or in blind holes;

     1 Allow parts baskets or parts  to stop dripping before removing from
      the degreaser;

     1 Turn on the primary condenser before starting the sump heater;

     1 Turn off the primary condenser after turning off the sump heater
      and the solvent vapor layer has collapsed;

     1 Use threaded or other leakproof couplings while  adding or removing
      solvent from any degreaser. Also, place inlets to the solvent sump
      below the liquid solvent level;

     1 Follow manufacturers' recommendations for maintaining each
      degreaser and its controls. The EPA must approve any alternative
      maintenance practice;

     1 Ensure that all degreaser operators can pass the appropriate
      sections of EPA's written test (see Appendix E). An inspector may
      request that degreaser operators take the test during an inspection;

      Collect and store all waste solvent, still bottoms,  and sump bottoms
      in closed containers. The containers may allow for pressure relief,
      but liquid solvent should not drain from the container;

     • Avoid cleaning sponges, fabric, wood, and paper products in a
      degreaser.
Available Control Combinations
This section presents the control combinations you may use. As
mentioned, no emission limit exists with this compliance method.
However, properly using each control group will reduce halogenated
solvent emissions.

You must know two characteristics of your degreaser to ensure that you
pick from the correct pool of control groups. First, know whether you have
a batch vapor or in-line degreaser. Second, if you use a batch degreaser,

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18
Chapter Three  Compliance Methods
                 you should know its solvent/air interface area. This is the surface area where
                 the solvent condensate meets the air. If you use an in-line machine, you need
                 to know whether EPA considers it new or existing.

                 Tables 3 through 6 provide a matrix of the control options available for each
                 degreaser classification. The tables should help you identify the technologies
                 contained in each control group. Following the tables, you will find details of
                 each control technology, including operating and monitoring requirements.

                 Appendix F contains forms to help you track the parameters that require
                 monitoring. The forms provide guidance only and may not apply to your
                 specific situation.
   TABLE 3 SMALL BATCH VAPOR (SOLVENT/AIR INTERFACE AREA OF 13 FT2 OR LESS.)
Control Groups
Control Technology
1 23456 78 9 10
Working-mode cover
Freeboard ratio of 1 .0
Freeboard refrig. device
Superheated vapor
Reduced room draft
Dwell time
Carbon adsorber
X
X

X





X
X



X

X





X

X
X




X

X



X
X






X


X


X


X
X



X



X

X

X


X

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                                                                        19
                                          Chapter Three   Compliance Methods
TABLE 4 LARGE BJCH VAPOR (SOLVENT/AIR INTERIACE AREAOF > 13 FT2.)
Control Groups
Control Technology
Working-mode cover
Freeboard ratio of 1 .0
Freeboard refrig. device
Superheated vapor
Reduced room draft
Dwell time
Carbon adsorber
1

X
X
X



2


X

X
X

3
X

X
X



4

X

X
X


5


X
X
X


6

X
X

X


7


X
X


X
TABLE 5 EXISTING IN-LINE
Control Groups
Control Technology
1234
Freeboard ratio of 1 .0
Freeboard refrigeration device
Superheated vapor
Dwell time
Carbon adsorber
X

X


X
X




X

X




X
X
TABLE 6 NEW IN-LINE
Control Groups
Control Technology
1 2 3
Freeboard refrigeration device
Superheated vapor
Carbon adsorber
X
X

X

X

X
X

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20
Chapter Three   Compliance Methods
                 Freeboard refrigeration devices
                 A freeboard refrigeration device (also called a chiller) is a set of
                 condenser coils in the freeboard region that creates a chilled air blanket
                 to condense the solvent vapor and prevents its escape.

                 The freeboard refrigeration device must create a cool air zone which is 30
                 percent or less of the solvent's boiling point. For example, if your solvent
                 boils at 100° F, your freeboard refrigeration device must cool the air
                 blanket to 30° F or less. Table 7 lists the minimum temperatures needed
                 for pure solvents.

                 TABLE 7 TEMPERATURE REQUIREMENTS FOR FREEBOARD
                 REFRIGERATION DEVICES FOR REGULATED SOLVENTS
Solvent Boiling Temperature (F) Req. Blanket Air Temp. (F)
Methylene chloride
1,1,1 trichloroethane
Trichloroethylene
Perchloroethylene
Carbon tetrachloride
Chloroform
104
165
189
250
168
143
31.2
49.5
56.7
75.0
50.0
43.0
                 If you use a blended cleaning solution of regulated halogenated solvents
                 and other chemicals, use the boiling point provided by the manufacturer
                 on the material safety data sheets.

                 Check and record the temperature of the chilled region weekly using a
                 thermometer or thermocouple. Measure the temperature in the center of
                 the air blanket while the machine is idling.

                 Freeboard ratio of 1.0
                 The freeboard ratio is the freeboard height divided by the smaller interior
                 dimension (length, width, or diameter) of the degreaser. For batch
                 cleaners, the freeboard height is the distance from the solvent/air
                 interface to the top of the idling degreaser. Freeboard height on in-line
                 machines is the distance from the solvent/air interface to the bottom of
                 either the entrance or exit,  whichever is lower. Figures 2 through 6 show
                 the freeboard region for both batch vapor and in-line degreasers respectively.

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                                                                                 21
                                                Chapter Three  Compliance Methods
Superheated Vapor
Superheated vapor degreasers heat the solvent vapor above its boiling
point to facilitate parts drying and minimize solvent drag-out.

Degreasers equipped with superheated vapor devices must:

    • Maintain the solvent vapor at least 10° F above the solvent's boiling
      point;

    • Use the manufacturer's method for determining the dwell time in the
      superheated vapor zone;

    • Ensure the parts remain in the superheated vapor zone for the
      entire dwell time;

    • Measure  and record the temperature at the center of the
      superheated vapor zone weekly using a thermometer or
      thermocouple.

Dwell Time
Dwell time is the time parts are held  in the freeboard area so that some
residual solvent may drain back into  the degreaser. This technique
reduces solvent drag-out and evaporative losses. Each part will require
different dwell times due to its shape and material. As a result, you must
determine the dwell time for every unique part you clean if you use this
control method.

EPA has developed a procedure to determine the proper dwell time:

      1. Use parts or parts baskets that are at room temperature.

      2. Clean parts in the degreaser per standard operating procedures.

      3. Determine the time for the part(s) or parts basket to cease
        dripping once placed in the freeboard region.

      4. The proper dwell time for parts to remain in the freeboard area is
        no less than 35 percent of the time determined in step 3.

Example
   Plant XYZ separately cleans two  parts, A and B, in an open-top batch
   vapor degreaser using methylene chloride. To obtain compliance, XYZ
   chooses a control combination that uses dwell time. Thus, the
   company must determine the proper dwell time for each part type or
   parts basket.

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22
Chapter Three
Compliance Methods
                    First, XYZ must clean parts A, which are at room temperature, in the vapor
                    degreaser. After the cleaning cycle, an operator places the wet parts into
                    the freeboard area and starts a timer. When the parts stop dripping, the
                    operator stops the timer. The elapsed time (for example, 10 minutes) is
                    multiplied by 35 percent to determine the proper dwell time.

                             proper dwell time = 10 minutes x 35 percent
                                              =  3.5 minutes

                    Thus, the proper dwell time for A parts is 3.5 minutes. This is the
                    minimum time the parts must remain in "dwell." The same procedure
                    is repeated for B parts. If XYZ decides to clean both parts A and B
                    together, they must use the longer dwell time.

                 Important information about dwell time:

                      • Document the test used to determine dwell time;

                      • Measure dwell time monthly to assure you're using the proper time.

                 Reduced Room Draft
                 "Reduced room draft" is a method to decrease the air flow across the
                 freeboard area. This minimizes turbulence inside the degreaser. Two
                 methods for reducing room draft are controlling room parameters (i.e.,
                 redirecting fans,  closing doors and windows, etc.), or either fully or
                 partially enclosing the degreaser. Whatever technique you choose,  you
                 must keep the air flow across the freeboard area or inside the machine to
                 less than 50 ft/min (15.2 m/min). EPA developed the following procedures
                 for each method to determine the air velocity:
                 Controlling room parameters
                     • Determine maximum wind speed with an air velocity meter on each
                       of the four corners of the degreaser. Measure the windspeed within
                       6 inches above the freeboard area;

                     • Record the maximum reading for each corner;

                     • Average the values obtained at each corner to determine the
                       average wind speed;

                     • Lower the velocity if the average wind speed is greater than 50 ft/
                       min. (for example, redirecting fans);

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                                                                                  23
                                                 Chapter Three  Compliance Methods
      Monitor weekly the room parameters established during the initial
      compliance test to achieve the reduced room draft of less than 50
      ft/min.
Enclosures
     • Determine the maximum windspeed inside the enclosure with an air
      velocity meter;

     • On a monthly basis:

       0 Monitor the air flow inside the enclosure;

       0 Inspect the enclosure for cracks, holes, and/or other defects.

Carbon Adsorbers
Carbon adsorption is a method of controlling solvent emissions by
passing the exhaust from  a degreaser through activated carbon. EPA
discourages this method because it is a treatment technology. In addition,
carbon adsorption can produce other potentially hazardous waste
streams,  like spent carbon beds saturated with halogenated solvent. As a
result, additional waste management costs can occur. You should consider
all factors and options  before using this control technology.

The allowable limit for the solvent concentration in the carbon adsorber
exhaust is 100 parts per million (ppm) by volume. If the concentration
exceeds 100 ppm, adjust the desorption schedule, or replace the carbon
bed if it is not a regenerative system. Additional operating requirements
include:

     • Ensuring that the carbon adsorber bed is not bypassed during
      desorption;

     • Locating the lip exhaust so the degreaser's cover closes below the
      lip exhaust level.

With this control you must measure and record the solvent concentration
in the exhaust of the carbon adsorber weekly. Test the concentration with
a colorimetric detector tube. The measurement procedure should meet the
following  criteria:

      • Sample gas at the exhaust vent of the solvent cleaning machine;

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24
Chapter Three  Compliance Methods
                       • Ensure that the vapor degreaser is in working mode and venting
                         to the carbon adsorber;

                       • Be sure the colorimetric detector tube is accurate to +/- 25 parts
                         per million by volume;

                       • Follow the manufacturer's instructions when using the
                         colorimetric detector tube;

                       • Provide a sampling port for monitoring within the exhaust outlet of
                         the carbon  adsorber. The port should be at least 8 stack or duct
                         diameters downstream from any flow disturbance such as a
                         bend, expansion, contraction, or outlet; downstream from no
                         other inlet;  and 2 stack or duct diameters upstream from any flow
                         disturbance such as a bend, expansion, contraction, inlet or
                         outlet.

                 Covers
                 Covers keep the solvent vapors inside the degreaser by protecting its
                 openings from air movements. Many different covers exist for use
                 including rolltop, sliding, and biparting. Covering a degreaser is one of the
                 cheapest and easiest ways to reduce solvent losses.

                 Covers for a degreaser can be independent or part of its  design. Any
                 cover must seal the cleaner and prevent solvent vapors from escaping.
                 When using a cover, you must inspect it monthly for  cracks and to ensure
                 proper operation. EPA recognizes  three types of cover: idle, working, and
                 downtime-mode:

                       Idling-mode cover: any cover that shields the  degreaser openings
                       during the idling mode. You can use an idling-mode cover as a
                       working-mode cover if that definition is also met.

                       Working-mode cover: any cover that protects  the degreaser
                       openings from outside air disturbances during parts cleaning.
                       Working mode covers are opened only during parts entry and
                       removal. You  can also use a cover that meets this definition as an
                       idling-mode cover if that definition is also met.

                       Downtime-mode cover: a cover used when the degreaser is off. It
                       must completely cover the openings of the degreaser

                 Hoists
                 A hoist is no? an available control method in a control combination. It's
                 required per the mandatory equipment design. The following monitoring

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                                                                                25
                                               Chapter Three   Compliance Methods
and reporting requirements are associated with hoist use:

     • Calculate hoist speed by measuring the time it takes for the hoist to
      travel a measured distance and report it in meters per minute. To
      convert from feet to meters, multiply the distance in feet by 0.305;

     • Check the hoist speed monthly unless:

         0 hoist speed does not exceed 11 feet/minute for one year—If
         so, you may measure hoist speed quarterly;

         0 you can demonstrate that hoist speed cannot exceed 11 feet/
         minute. Then you can measure the speed quarterly.

DETAILS OF THE IDLING EMISSIONS METHOD
This method has a limit on the quantity of regulated solvents emitted from
the degreaser while the machine is idling. Figure 7 shows the steps
required to meet compliance with this method. Table 8 lists the emission
limits for each regulated degreaser.

TABLE 8 IDLING EMISSION RATES FOR EACH DEGREASER TYPE
Degreaser type
Small and large batch
Existing and new in-line
Idling emission rate
(Ibs/hr/ft2)
0.045
0.021
Although this regulatory method is emissions oriented, it still requires the
minimum equipment design and operational methods used in the control
combinations method. If these techniques do not lower your emissions,
you may use any additional controls or procedures necessary to meet the
limit.

Your emission limit depends on the area of the degreaser's solvent/air
interface. Once you determine the area,  multiplying it by the appropriate
emission factor gives the maximum hourly emission  rate of solvent that
the degreaser may emit.

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26
Chapter Three  Compliance Methods
                                          Equipment
                                           Design
                                          Workplace
                                           Practices
                                          Calculate
                                          Emission
                                            Rate
                                        Recordkeepin^
                                             1
                                          Reporting
                 FIGURE 8 IDLING EMISSIONS METHOD

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                                                                                27
                                               Chapter Three   Compliance Methods
In addition to determining your idling emissions rate you must:

 • Prove you can meet the emission limits using EPA's Reference Method
   307;

 • Identify and monitor the operating parameters used to meet
   compliance. If you use a control from the Control Combination section,
   you must adhere to that control's monitoring requirements. If not, you
   must supply EPA with equivalent information on your parameter(s);

 • Operate the degreaser within the parameter limits. When a parameter
   is not met, an exceedance has occurred. Follow the exceedance
   guidelines listed in Chapter 4, Reporting.

Remember, with this compliance method you must:

      • Monitor the controls used to meet emission limits;

      • Use the equipment design and operating practice guidelines.

DETAILS OF THE ALTERNATIVE STANDARDS METHOD
The alternative standard method limits the solvent emissions from your
degreaser without requiring a minimum equipment design or workplace
practices. You obtain compliance by using any technology or workplace
practices you wish to meet the limits. You must also monitor and report the
halogenated solvent emissions from your degreaser.

As mentioned, no mandatory equipment standards or workplace practices
apply to this method. EPA developed this method to allow owners/
operators a route to compliance if they have trouble using the other
methods. Figure 8 is a flowchart of the steps required to use the
alternative standards. Appendix G contains a worksheet to help you
calculate your emissions.

The method for determining your emissions is based on a solvent material
balance. In other words:
                    solvent in = solvent oui

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28
Chapter Three   Compliance Methods
                                                  Initial Reporting
                                                    Requirements
                                                 Determine Cleaner
                                                       Type
                          Batch Vapor
                               or
                             In-line
  Batch Without a
    Solvent/Air
      Interface
                             1
                        Calculate 3-month
                        Rolling Average for
                           Emissions
      I
    Determine
 Cleaning Capacity
                       Compare Calculated
                     Emissions With Table 9 to
                      Determine Compliance
                             Status
                                                                                 I
Calculate 3-month
Rolling Average for
    Emissions
                                                                           Compare Calculated
                                                                        Emissions With Table 10 or
                                                                         Equation 3 to Determine
                                                                            Compliance Status
                                                  Initial Statement Of
                                                     Compliance
                                                       i
                                                  Recordkeeping &
                                                     Reporting
                   FIGURE 9 ALTERNATIVE STANDARDS

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                                                                                    29
                                                  Chapter Three   Compliance Methods
"Solvent in" can be virgin, reclaimed, or filtered cleaning solution. "Solvent
out" is the amount evaporated during use plus the quantity contained in
the solid waste produced during clean-outs.

The emission limit is based on a three-month rolling average. To calculate
this value, determine your machine's solvent losses every month; then
average it with the previous two months.  This requires detailed records on
solvent  additions, deletions, and clean-out waste during each month.

Like the other methods, your equipment determines your regulatory
obligation. This compliance method divides all degreasers into two
categories:

      • Batch or in-line vapor (BIV) degreasers with a solvent/air
        interface;

      • Batch vapor degreasers without a solvent/air interface.

Older BIV have solvent/air interfaces. This is the area where the
concentrated solvent vapor meets the air. Newer batch cleaners may use
a vacuum to create a solvent vapor during the cleaning cycle. These batch
units are completely enclosed and require a different calculation method to
determine emission rates.

Basics  for Determining Degreaser Emissions
The alternative standards require certain  procedures regardless of your
degreaser type. You must do the following before calculating your
emissions:

       • Place clean solvent in the degreaser on the first operating day of
        each  month. Clean solvent may be either virgin, recycled, or
        filtered;

       • Determine a fill line that you will always bring the solvent level to
        when replenishing the degreaser. On the first operating day of
        the month, bring the solvent level to the fill line with clean
        solvent.

BIV with a solvent/air interface
The emission limits center around your degreaser type (batch, existing, or
new in-line). Table 9 provides the three-month rolling average for emission

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30
Chapter Three  Compliance Methods
                  limits. Using the material balance described above, EPA suggests you use
                  the following methods for determining your emission rates:

                      • Maintain a log of all solvent additions or removals for each solvent
                       cleaning machine;

                      • Use the information from the solvent log to calculate the solvent
                       emissions (E) for one month. EPA provides the following formula for
                       this calculation:
                        Equation One

                                     E=  SA - LSR -SSR
                                               S/A
                        where: E =  wei§   = solvent emissions for one month
                                   area
                              SA = "clean" solvent added into to degreaser during month (weight)

                              LSR = liquid solvent removed during month (weight)

                              SSR - solvent contained in solid waste from equipment cleaning during
                              month (weight)

                              S/A area = solvent/air interface area (area)
                 Of these variables, SSR warrants further discussion. EPA allows two
                 methods for determining solvent content in the solid waste from the
                 degreaser clean-outs. First, you can use EPA Reference Method 25d. You,
                 or an analytical lab, may perform the test. EPA also lets you use
                 engineering calculations (for example, estimations) to determine solvent
                 content. If you use your method, be sure to document the procedure.
                 Whatever technique you choose, you must include it in the initial
                 compliance report.

                 Once you've determined your monthly emission rate for three
                 consecutive months, calculate the rolling average (EA). If this value is
                 below the emission limit for your machine, you are in compliance.

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                                                                                  31
                                                Chapter Three  Compliance Methods
The formula for the rolling average is:
      Equation 2
                  EA =
            where: EA = the three-month rolling average taken over the preceding
            three months.

      E1 = halogenated HAP solvent emissions for month one from Eqn 1.

      E2 = halogenated HAP solvent emissions for month two from Eqn 1.

      E3 = haiogenated HAP solvent emissions for month three from Eqn 1.
Example:
You choose to use the alternative standards to meet compliance. You
have a small open-top vapor degreaser which has a solvent/air interface
area of 12 square feet. In June, you begin recording solvent additions
and deletions. During June you:

    • Removed 150 Ibs of solid waste containing an estimated 75 Ibs of
      solvent (SSR);

    •Added 400 Ibs of clean solvent (SA);

    • Removed 100 Ibs of spent solvent (LSR);

    • Added  125 Ibs on July 3 (the first working day of the month) to
      bring the solvent level to the fill line (SA).

Using equation 1, you may calculate the solvent emissions for June as:
          (400 Ibs + 125 Ibs) - 100 Ibs   75 Ibs
                        12ft5
ft2

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32
Chapter Three  Compliance Methods
                 During the months of July and August, you calculate your monthly
                 emissions as 25.7 Ibs/ft2 and 27.6 Ibs/ft2' respectively. Now you can
                 determine your three-month rolling average with Equation 2:
                                                                     Ibs
                                       3 month
                                                                 fr • month
                 You are under the emission limit of 30.67 Ibs/ft2/month, so you are in
                 compliance. At the end of September, you calculate the three-month
                 rolling average using emissions from July, August, and September. This
                 method is used for the entire year.

                 Batch without solvent air/interface
                 These machines use a vacuum in the cleaning chamber to process the
                 parts. Therefore, instead of basing emissions on the solvent/air interface
                 area, it revolves around the cleaning capacity. See Appendix H for help
                 on determining your cleaning capacity. This value is the maximum volume
                 of parts the machine can clean at one time.

                 If your machine has a cleaning capacity less than or equal to 104 ft3,
                 then you may use either the values in Table 10 Of? calculate the
                 machine's limit as:
                       Equation 3
                                           0.6
                             ME = 330 *(vol)

                                    where ME - the monthly emissions in kg/month

                                    vol - cleaning capacity of the degreaser (m3)

                 'to convert from kg/month to Ibs/month, multiply kg/month by 2.2046.
                 If your machine capacity is greater than 104 ft3 (2.95 m3), you must
                 calculate your emission limits using Equation 3. The three-month rolling
                 average is calculated with Equation 2 above.

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                                                                  33
                                       Chapter Three  Compliance Methods
TABLE 9 EMISSION LIMITS FOR BATCH VAPOR AND IN-LINE
SOLVENT CLEANING MACHINES WITH A SOLVENT/AIR INTERFACE
Solvent cleaning machine 3-month rolling average
monthly emission limit
(Ibs/square foot/month)
Batch vapor solvent cleaning machines
Existing in-line solvent cleaning machines
New in-line solvent cleaning machines
30.67
31.28
20.24

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TABLE 10 EMISSION LIMITS FOR CLEANING MACHINES WITHOUT SOLVENT/AIR INTERFACE
Cleaning
capacity
(cubic feet)
0.0
1.8
3.5
5.3
7.1
8.8
10.6
12.4
14.1
15.9
17.7
19.4
21 .2
23.0
24.7
26.5
28.2
30.0
31.8
33.5
3-Month rolling
average monthly
emission limit
(Ibs/month)
0.0
121.3
183.0
233.7
277.8
317.5
352.7
388.0
418.9
449.7
480.6
509.3
535.7
562.2
586.4
612.9
637.1
659.2
683.4
705.5
Cleaning
capacity
(cubic feet)
35.3
37.1
38.8
40.6
42.4
44.1
45.9
47.7
49.4
51 .2
53.0
54.7
56.5
58.3
60.0
61.8
63.6
65.3
67.1
68.9
3-Month rolling
average monthly
emission limit
(Ibs/month)
727.5
749.6
769.4
791.5
811.3
831.1
851.0
870.8
890.7
908.3
928.1
945.8
965.6
983.3
1,000.9
1,018.5
1,036.2
1,051.6
1,069.2
1,086.9
Cleaning
capacity
(cubic feet)
70.6
72.4
74.2
75.9
77.7
79.4
81.2
83.0
84.7
86.5
88.3
90.0
91.8
93.6
95.3
97.1
98.9
100.6
102.4
104.2
3-Month rolling
average monthly
emission limit
(Ibs/month)
1,102.3
1,119.9
1,135.4
1,150.8
1,168.4
1,183.9
1,199.3
1,214.7
1 ,230.2
1,245.6
1,261 .0
1,276.5
1,289.7
1 ,305.1
1,320.6
1,333.8
1,349.2
1,364.6
1,377.9
1,393.3
O
o


I

5P
                                                                                       I

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                                                                              35
Chapter 4  Recordkeeping &
Reporting
This chapter discusses the recordkeeping and reporting requirements
associated with this regulation. Remember, the compliance method you
choose determines your responsibilities. Therefore, the requirements for
each compliance method are discussed separately.

RECORDKEEPING

Control Combinations and Idling emission
With the control combination or idling emission method, you must maintain
certain records on equipment performance, control test procedures, and
test results. Either electronic or written records are acceptable. You must
keep some information for as long as you own the machine while you
must keep other information for only five years.

Keep this information for as long as you own the machine:

    • Owners manuals for each degreaser and control device. If
      unavailable, keep written operating and maintenance procedures;

    • The installation date for each degreaser and its respective control
      devices. If unsure of the date, substitute a letter certifying that the
      degreaser and its controls were installed on or before November
      29, 1993, OR a letter certify that the degreaser and its control
      devices were installed after November 29, 1993;

    • If using dwell as a control, keep the test methods and results from
      dwell time tests for each part;

    • If using idling emissions standards, keep the test methods and
      results from the initial emission rate tests;

    • The halogenated solvent content for the cleaner used in each
      degreaser. Your vendor  can supply you with this information.

Maintain these records for five  years.

    • Monitoring results from each control device;

    • Any actions taken to comply with the control options or idling
      emissions standard. This may include written or documented verbal
      orders for replacement parts, repairs, and  monitoring procedures;

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36
Chapter Four   Recordkeeping and Reporting
                       Estimates of the annual solvent consumption for each degreaser;
                       If using a carbon adsorber, the dates and results from the weekly
                       tests to determine solvent concentration in the carbon adsorber
                       exhaust.
                 Alternative Standards
                 Users of the alternative standards must keep these records for five years:
                     • Dates and quantity of solvent added to each degreaser;
                     • Solvent content of wastes removed from each degreaser;
                     • Methods for determining the rolling three-month average emissions,
                       and the emission rate for each degreaser;
                     • Methods used to determine cleaning capacity for each degreaser
                       without a solvent/air interface.
                 REPORTING
                 There are four different reports you must submit regardless of your
                 degreaser type or compliance method. These reports are the initial
                 notification, initial statement of compliance, and annual report. Appendix I
                 contains sample forms which you can use to model your reports.

                 Initial notification
                 This report informs EPA that you use one or more degreasers. The
                 content of the initial notification depends on your machine type and its age
                 (for example, is your machine existing or new).
                 Existing degreaser
                 For existing machines, the report is due by August 29, 1995, and must
                 contain the following information where applicable.
                     • Name and address of each owner and  each degreaser;
                     • Description of the degreaser machine including:
                             0 type (batch, in-line);
                             0 solvent/air interface area or cleaning capacity;
                             0 existing controls;

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                                                                                  37
                                        Chapter Four  Recordkeeping and Reporting
     • The installation date for degreaser and its respective control
      devices. If unsure of the date, substitute a letter certifying that the
      degreaser and its controls were installed on or before November
      29, 1993, OR a letter certify that the degreaser and its control
      devices were installed after November 29, 1993;

     •Anticipated method of compliance (control options, idling emissions,
      or alternative standards);

     • Estimated annual consumption of halogenated solvents.

New degreaser
Deadlines for initial notifications depend on the date your "new" degreaser
went, or goes, into service. If you began constructing  or installing the
degreaser on, or before, December 2,1994, your initial compliance report
was due by January 31,1995. It is due as soon as practicable after
December 2,  1994. Include this information on the initial notifications for
new degreaser:

      • Brief description of each degreaser;

      • Anticipated method of compliance for each degreaser;

      • Estimated annual consumption of halogenated solvent.

Initial statement of compliance
You must submit an initial statement of compliance after submitting your
initial notification. This notice informs EPA of your intended compliance
method. For existing sources, the  due date is May 1,1998. For new
degreasers the due date is 150 days after start-up. The content of this
report varies with the compliance method.

Controls Combinations and Idling  Emissions
You must report different information depending on whether you use
control combinations or idling emissions. You should file a separate
compliance statement for each degreaser even if you use the same
method for both. Regardless of how you reach compliance, provide these
five items:

     1. Name and address of the owner(s);

    2. Physical location of each degreaser;

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38
Chapter Four   Recordkeeping and Reporting
                      3. The control equipment used for each solvent cleaning machine;
                      4. For each control, the parameters that are monitored and the
                        monitoring results for the first month after the compliance date;
                      5. If applicable:
                         • Steps taken to reduce room draft (for example, close doors or
                          windows);
                         • The date and results of the weekly measurement of halogenated
                          solvent concentration in the carbon adsorber exhaust.
                 For idling emissions standard only, include items 1 through 5 and:
                     6. The results from the initial emissions test from Method 307;
                     7. Information on the monitoring method, monitoring frequency, and
                       exceedance limits for any controls used  to meet compliance. If
                       using controls listed in the regulation, you should use the
                       prescribed monitoring methods and frequencies;
                     8. Certify that the initial emissions test was performed on the exact
                       model used in the facility. You, the vendor, or a third party may
                       perform the initial emissions test;
                     9. If the degreaser vendor or a third party performed the emissions
                       test include:
                        • Person(s) or company performing the test;
                        • Name and serial number of the degreaser;
                        • Date of the emissions test;
                        • Diagram of the degreaser;
                        • Justification that the solvent emissions from the in-house
                          degreaser are equal to or less than the unit used in the test.
                 Alternative Standards
                 Supply this data where appropriate on the initial compliance report  when
                 using the alternative standard:
                       •  Name and address of the degreaser owner or operator;
                       •  Physical location of degreaser;
                       • The solvent/air interface area for each  degreaser;

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                                                                                 39
                                        Chapter Four   Recordkeeping and Reporting
      •The cleaning capacity and method for its determination;

      • The first three-month rolling average for emissions.

Annual Reports
These reports contain information on degreaser usage during the calendar
year (for example, January to December). It is due February 1 of the
following year. For example, if you used your degreaser the last nine
months of 1999, the annual report is due February 1, 2000. The report
content varies with the compliance method you choose. However, EPA
allows you to include all methods in one report to reduce paperwork.

Control Combinations and Idling Emissions
If you use the control combinations or idling emissions method to comply,
your annual report must include:

      1. A signed statement from a company official (owner or his
        designee) certifying that degreaser operators have been properly
        trained, and can pass a written exam on its operation and
        respective control devices. Appendix D contains the EPA exam
        used by inspectors;

      2. An estimate of the annual solvent consumption for each
        degreaser during the reporting period.

Alternative Standards
The annual report for each degreaser with which you use the alternative
standard must include:

     • The solvent/air interface OR cleaning capacity of each degreaser
      used with alternative standards;

     • The average monthly solvent consumption during the reporting
      period for each degreaser;

     • The estimated three-month rolling average solvent emissions.

Exceedance Reports
Exceedance reports are periodic statements filed for each machine to the
EPA Administrator stating:

      • Actions taken to maintain compliance;

      • Exceedances and the associated corrective action;

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40
Chapter Four   Recordkeeping and Reporting
                 Exceedance reports are in addition to your annual reports, and are due
                 semiannually. However, if you have a particular type of exceedance, they
                 become due quarterly. EPA may also decide that more frequent reporting
                 is necessary for your operation.

                 An exceedance is different for each compliance method. For the control
                 options and idling emissions method, an exceedance occurs when a
                 control does not meet a certain operating parameter. For alternative
                 standards, an exceedance occurs when the emission limit is surpassed.

                 For the control options and idling emissions method, we have divided
                 Exceedances into two categories—minor and major. Table 11 lists the
                 minor and major exceedances. Different requirements exist for each type
                 of exceedance.

                 Minor
                 You do not have to report minor exceedances if corrected within 15 days
                 of discovery. However, include the corrective action taken on the
                 semiannual exceedance report. If you do  not correct a minor exceedance
                 within the 15-day limit,  it becomes a major exceedance, and you are
                 required to begin filing quarterly exceedance reports.

                 Major
                 If you have a major exceedance, you must correct the problem and report
                 it on the next exceedance report. You must begin reporting  quarterly until
                 you have operated the degreaser for one  calendar year without an
                 exceedance or convinced the Administrator to reduce the reporting
                 frequency.

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                                                                          41
                                     Chapter Four  Recordkeeping and Reporting
Table 11:  Minor and Major Exceedances
MINOR
Temperature in chilled air blanket
exceeds 30% of the solvent's boiling
point
Air flow across the freeboard top or
within the solvent cleaning machine
exceeds 50 ft/sec
Working- and/or idling-mode covers
become defective (e.g. cracks or
holes)
Superheated vapor zone is less than
10°f above the solvent's boiling point.
Concentration or organic solvent
exceeds 100 ppm in the carbon
adsorber exhaust

MAJOR
Operating parameters allow a room
draft to exceed 50 ft/sec
Working mode cover does not com-
pletely cover the degreaser openings
when in a cleaning cycle
Idle mode cover does not completely
cover the degreaser when idling
Parts are not held in dwell long enough
Manufacturers dwell time exceed while
using superheated vapor
Carbon adsorber bed is bypassed
during desorption
Lip exhaust located below the cover

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42
                 Glossary
                 Air blanket: the layer of air inside the solvent cleaning machine freeboard
                 located above the solvent/air interface. The center line of the air blanket is
                 equidistant between the sides of the machine.

                 Automated parts handling system: a mechanical device that carries all
                 parts and parts baskets at a controlled speed from the initial loading of
                 soiled or wet parts through the removal of the cleaned or dried parts.
                 Automated parts handling systems include, but are not limited to, hoists
                 and conveyors.

                 Batch cleaning machine: a solvent cleaning machine in which individual
                 parts or a set of parts move through the entire cleaning cycle before new
                 parts are introduced into the solvent cleaning machine. An open-top vapor
                 cleaning machine is a type of batch cleaning machine. A solvent cleaning
                 machine, such as a ferris wheel cleaner, that cleans multiple batch loads
                 simultaneously and is manually loaded is a batch cleaning machine.

                 Carbon adsorber: a bed of activated carbon into which an air-solvent
                 vapor stream is routed and which adsorbs the solvent on the carbon.

                 Cleaning capacity: for a cleaning machine without a solvent/air interface,
                 the maximum volume of parts that can be cleaned at one time. In most
                 cases, the cleaning capacity is equal to the volume (length times width
                 times  height) of the cleaning chamber.

                 Dwell: the technique of holding parts  within the freeboard area but above
                 the vapor zone of the solvent cleaning machine. Dwell occurs after
                 cleaning to allow solvent to drain from the parts or parts baskets back into
                 the solvent cleaning machine.

                 Freeboard ratio: the ratio of the solvent cleaning machine freeboard
                 height to the smaller interior dimension (length, width, or diameter) of the
                 solvent cleaning machine.

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                                                                                   43
Primary condenser: a series of circumferential cooling coils on a vapor
cleaning machine through which a chilled substance is circulated or
recirculated to provide continuous condensation of rising solvent vapors
and, thereby,  create a concentrated solvent vapor zone.

Reduced room draft: decreasing the flow or movement of air across the
top of the freeboard area of the solvent cleaning machine. Methods of
achieving a reduced room draft include, but are not limited to, redirecting
fans and/or air vents to not blow across the cleaning machine, moving the
cleaning machine to a comer where there is less room draft, and
constructing a partial or complete enclosure around the cleaning machine.

Superheated  vapor system: a system that heats the solvent vapor, either
passively or actively, to a temperature above the solvent's boiling point.
Parts  are held in the superheated vapor before exiting the machine to
evaporate the liquid solvent on them. Hot vapor recycle is an example of a
superheated vapor system.

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44
     Appendix A
       COLD HALOGENATED
       SOLVENT CLEANING

-------
OVERVIEW  -   COLD  HALOGENATED  SOLVENT
CLEANING

On December 2, 1994, the EPA published in the Federal Register final National
Emission Standards for Halogenated Solvent Cleaning. The rules apply to cleaning
machines using:

•   methylene chloride,
•   perchloroethane,
•   trichloroethylene,
•   1,1,1-trichloroethane,
•   chloroform
•   carbon tetrachloride,

Owners and operators of vapor or in-line cleaning machines must achieve emission
control standards based on maximum achieveable control technology.They also
must comply with on-going monitoring, recordkeeping, and reporting requisites.
 There will be a state-
 wide teleconference
 on vapor degreasing
 conducted by UT-CIS
 on May 24,  1995.
EPA based the standards for batch cold cleaning machines on generally available
control technology. These standards require readily implemented controls, simple
work and operational practices, minimal reporting and no record keeping.

A cold cleaning machine is a device that uses a nonboiling listed solvent to clean or
dry the surfaces of parts placed therein.

EPA's preferred compliance option requires:

•    use of a tightly fitting cover  kept closed except during part entry or removal,

•    a layer of water at least 1.0  inch thick floating on the solvent surface.

Sources using the water-cap option have no other work or operating practices
requirements. In lieu of a water-cap, sources also can comply by using:

•    an 0.75  freeboard ratio and a cover kept closed except during part entry or
     removal.

•    a remote-reservoir and a cover kept closed except during parts cleaning.

-------
Sources using either of these options must perform specified work practices, these
are:

•    Collect and store all waste solvent in closed containers.
•    Do part flushing only in the machines freeboard area.
•    Drain cleaned parts in the freeboard  area for 1 5 seconds, or drip-free, which-
     ever takes longer.
•    Never exceed the machine's maximum fill line.
•    Wipe up spills immediately. Store wipe rags in a closed container.
•    Do not permit spashing when parts are cleaned using an agitated bath.
•    Assure the machine is not exposed to drafts > 1 32 fpm when the cover is
     open.
•    Do not clean sponge, fabric, wood, or paper parts in the machine.

All cold cleaning sources must submit an  "initial notification report" and a "compli-
ance report" to:

EPA Region  IV
Director, Air Toxics Div. 345  Courtland St., NE
Atlanta, GA 30365

The Initial notification is due August 29, 1995. Information required includes:

•    Name and address of the owner/operator.
•    The address of the  cleaning machine(s).
•    A brief description of each cleaning machine, including the  machine type, and
     existing controls.
•    The date of each machines installation, OR a letter certifying  the machine and
     its control devices were installed  before/after November 29,1993.
•    The anticipated  compliance approach.
•    An estimate of annual solvent consumption for each machine.

The compliance report is due May 1, 1998. This report requires  the following
information:

•    Name and address of the owner/operator.
•    The address of the  cleaning machine(s).
•    A statement, signed by the owner/operator, that the machine(s) for which the
     report is/are being submitted is/are in compliance.
•    The approach used to  secure compliance.

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Appendix B
   REDUCE METHYL
    CHLOROFORM
      EMISSIONS

-------
Reduce Methyl  Chloroform Emissions  for
Environmentally  Sound  Vapor  Degreasing
by James A. Mertens
The Dow Chemical Co., Midland, MI
    The stratospheric ozone protection
    provisions of the US Clean Air Act
Amendments of 1990 regarding methyl
chloroform (MCF or  1,1,1-trichloro-
ethanc) pose a challenge to many com-
panies with metal cleaning operations.
The mandated production scale-down
and eventual phaseout of the widely
used solvent has sent metal finishers
on a long and difficult search for alter-
native solvents and processes. Unfortu-
nately, it appears that there are no com-
mercially available alternatives as ef-
fective,  economical or safe as MCF.
  For those metal cleaners who depend
on  the effectiveness,  safety,  and low
toxicity of MCF and its exemption from
regulations controlling volatile organic
compounds (VOCs), the First step that
should be considered is emission reduc-
 tion.
    Table I. Overview of Methyl
      Chloroform Legislation
 Montreal
 Protocol
   Clean Air Act
Amendments of 1990
                  1991: 100%o< base
                  1992: 100%
 1993: 100% ol base   1993:  90%
                  1994:  85%
 1995: 70% of base   1995:  70%
                  1996:  50%
                  1997:  50%
                  1998:  50%
                  1999:  50%
 2000- 30% of base   2000:  20%
                  2001:  20%
                  2002: 0-10%-
                  2003: 0-10%'
                  2004:0-10%'
 2005.  0% of base   2005:   0%

 All dates are effective "Maximum volume of
 January i of the year  lO%forEPA-
 '•steci. base year is   approved essential
 1989            usesonly
  The fact is, the graduated production
phase-out period mandated by the act—
from January 1991 to January 2005 (see
Table I for  schedule  details)—allows
solvent availability to users for up to
11 years and, for certain essential appli-
cations, possibly 14 years. During this
time, metal cleaners  can adopt tech-
niques that greatly reduce solvent emis-
sions and waste  and eventually  ap-
proach total elimination of emissions.
This practice will help them save sol-
vent and the resulting solvent replace-
ment costs  (plus  excise tax).  It  also
makes sense, considering the increas-
ing  scrutiny that emissions will be re-
ceiving from regulatory agencies.
  In addition, for those metal cleaners
using the related chlorinated  solvent
trichloroethylene (TCE), emission re-
duction is especially important. TCE is
classed by the Environmental  Protec-
tion Agency (EPA) as  a VOC which
contributes  to  smog  generation,  and
consequently its use is restricted under
most state and local environmental reg-
ulations. With successful reduction of
emissions and the corresponding con-
tainment of solvent vapors, many oper-
ations  may consider using trichloro-
ethylene, as well as  the other chlori-
 nated solvents, perchloroethylene or
 methyiene chloride, as alternatives.

 CONTAINMENT OF  SOLVENT
 VAPORS
   Industry's challenge to minimize sol-
 vent vapor emissions will mean, among
 other things, finding ways to contain
 vapors in the degreasing process, cap-
 turing and  reusing fugitive vapors, re-
 cycling as  a means of minimizing sol-
 vent waste, and environmentally safe
 disposal  of solvent sludge. For  many
 companies, this  will require  taking a
good look at the vapor degreasing proc-
ess.
  The  vapor  degreaser has evolved
over the years from a very simple piece
of equipment to a comprehensive proc-
ess  that is  continually improving as
emission reduction is emphasized. The
early  degreasers  were  designed to
maintain a vapor zone, but were not
efficient in controlling  solvent loss
through diffusion to the ambient air.
More recent degreaser designs con-
serve solvent better through several
methods of containment, such as higher
freeboards, improved cooling capabili-
ties, and automatic covers.  Today,
even greater solvent containment can
be achieved through modifications to
these improved  degreasers and  as-
sociated processes .
  The principal factors influencing sol-
vent vapor losses are poor heat balance,
moving air currents, and improper plant
operating procedures. Significant sav-
ing can be achieved by getting any one
of these parameters under control. The
following  operating  guidelines can
serve as a checklist for a metal cleaner
who wants  to reduce emissions.

IMPROVING HEAT BALANCE

REDUCE HEAT:
   High heat does not provide improved
cleaning. Use the least amount of heal
required to keep the solvent at a slow
boil and to give adequate vapor produc-
tion.

 ADJUST COOLING:
   An  adequate  supply of cold water is
 needed to  maintain the vapor zone  ai
 the midpoint of the cooling coils. Water
 cooled systems should be  50°F (10°Q
 at the  inlet and not allowed to go above
 90°F (32°C) at  the discharge.

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                  THE STOP AND GO TECHNIQUE
   This procedure was  developed to reduce solvent loss and lower solvent
 concentrations in the ambient air near a vapor degrcaser.
 1. Lower the work load into the vapor zone slowly. Otherwise an excessive
    vapor wave formation can push vapor out of the degreaser.
 2. The vapors collapse as the work load enters the vapor zone.
 3. Whenever the vapor level drops two to four inches, stop the load until the
    vapors stabilize or start to recover.
 4. Then, lower the load further until the vaporsdropanothertwotofourinches.
 5. Once the work load is covered by the vapors, it need not be lowered any
    further. The further it is from the boiling sump, the better the vapor recovery.
    The work load should never sit on top of the heating elements.
 6. Remove the work load in increments of two to four inches, with pauses to
    allow the vapors to be entrapped in the freeboard area. This decreases vapor
    drag-out.
 7. Once the work load has  cleared the vapor zone, it should remain in the
    freeboard area until all parts are dry and no solvent drips from the work or
    the basket.
   This "stop and go" method prevents solvent vapors from being pushed out
 of the degreaser by the piston effect of  the work load. It allows  maximum
 vapor recovery with shorter cleaning cycles.
CHECK THE WATER JACKET:
  Proper water flow and temperature
on the outside of the degreaser should
be verified. This provides cooling for
the upper surfaces of the degreaser and
keeps hot vapor from migrating up the
side walls from convection currents.

CONSIDER COLD TRAPS:
  This is an upper set of very cold coils
that cool the air above the vapors. Prop-
erly used, cold traps provide a  dense
blanket of cold  air that helps reduce
vapor diffusion. Frequently these  are
below freezing. It is best if a separate
condensation trough is provided, as a
considerable amount of water is con-
densed on these coils. This  should in-
corporate a separate water separator in
series with the main water separator.

PREVENTING AIR CURRENTS

USE COVERS ON OPEN TOP
DEGREASERS:
   Especially during idle times,  this is
possibly the single most important con-
servation step you can take.  Proper use
of covers can reduce solvent loss up to
55%. Sliding covers are particularly
helpful,  since they do not cause  turbu-
lence when  moved,  as  do  hinged
covers.

AVOID DRAFTS OVER THE
DEGREASER:
   Fans, air conditioners, heaters, win-
dows, doors, general plant air  move-
ment  and equipment movement can
blow the vapor-air mixture out of the
degreaser.  Situate  the  degreaser to
minimize natural drafts or use baffles
to prevent the vapors from being upset.
Drafts around an open top degreaser
can increase losses by up to 30%.

EXTEND THE FREEBOARD:
  Units with freeboard heights that are
75 to 100% of the width of the de-
greaser can use up to 40% less solvent
than units with  lower ratios, such as
50%. Many new degreasers are now at
125 to 160% freeboard.

SPRAY IN THE VAPOR ZONE:
  Spraying above the vapor zone not
only generates a vapor-air mixture di-
rectly, which is immediately lost, but
falling droplets of solvent also disrupt
the vapor interface causing more vapor-
air mixing. Spraying below the vapor
zone can achieve up to a 5% reduction
in solvent loss.

REDUCE EXHAUST VELOCITIES:
  If  vapor emissions are controlled
with  lip vent hood exhausts, be sure
the exhaust is not too forceful. Other-
wise  it can cause turbulence in the
vapor. Use the minimum exhaust vel-
ocity that provides proper vapor control
in the work area.

ELIMINATE WIND TUNNELS:
   Some semi-enclosed  machine de-
signs tend  to channel and reinforce air
                                     currents through the  machine,  espe-
                                     cially if power exhausted. Rearranging
                                     the air movement in. the room can help
                                     to eliminate this wind tunnel effect.
                                     Baffles  can  also  be   installed  to
                                     minimize or eliminate wind tunnel ef-
                                     fects.
MODIFYING THE PROCEDURE

MOVE THE WORK SLOWLY.
  Rapid part or basket movement dis-
rupts the vapor zone and causes mixing
with air. Control the hoist speed to less
than 11 feet per minute of vertical travel
and ensure the proper conveyor speed.
The lower the speed  the better, with
three feet per minute  being optimum.
(See box for instructions  in die "stop-
and-go" technique.)

AVOID SOLVENT CARRY-OUT:
  Solvent that does not drain properly
from parts is lost immediately to evap-
oration outside the degreaser.  Adjust
the positioning in the  baskets or racks
to allow easy and complete drainage.
Part rotation or movement as the parts
are removed from the liquid helps to
reduce drag-out.

BRING PARTS UP TO
TEMPERATURE BEFORE
REMOVAL:
  The cleaning cycle isn't complete
until parts have reached the temperature
of the vapor, so that condensation has
ceased. If condensation is  still forming,
solvent drag-out will increase.

USE PROPERLY SIZED BASKETS:
   Large baskets that fill the area of the
degreaser opening create a piston action
when entering and exiting. This forces
vapor out, which creates more vapor-
air mixing. The basket should have an
area of 50% or less  of the degreaser
opening.

USE ONLY CLEAN OR
NONPOROUS MATERIALS:
   Avoid  introducing fabrics  (shop
rags, gloves, etc.) and wood into the
degreaser.  Do not use items such as
ropes or wooden spacers  or  covers.
These can  collect solvent and release
the vapors into the air as they dry out.

REPAIR LEAKS:
   Leaks are difficult  to detect because
of the rapid evaporation  of liquid sol-
 vent   seepage.   Careful  inspection
SEP
                                                                                                          51

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should be performed routinely, espe-
cially in hidden spots.

UPGRADE YOUR DECREASING
EQUIPMENT:
  To improve the efficiency of your
vapor degreaser, the following devices
can be useful:
• Automatic slide covers
• Higher freeboards
• Refrigerated freeboard chillers
• Carbon absorption lip exhaust
• Programmable transport systems

COLD CLEANING
IMPROVEMENTS
  It is more difficult to reduce emis-
sions from cold cleaning operations be-
cause of the nature of the  process.
Where possible,  metal finishers should
consider converting these operations to
vapor degreasing. Emissions can be
minimized in cold cleaning, however,
through certain  economical improve-
ments. Here are some suggestions:
   1. Use covers over the cold cleaning
tank to minimize evaporation.
  2. Use a coarse spray or solid stream
of solv-nt instead of a fine spray. A
fine spray can vaporize too easily.
  3. Control ventilation. Rapid air cur-
rents can carry vapors  away from the
tank.
  4. Place wipe rags in a closed con-
tainer and use them again  whenever
possible. Evaporation from drying rags
can cause solvent loss.
  5. Minimize open  surface area. The
less interface between solvent surface
and air, the less evaporation.
   6.  Use a  deep tank with a  high
freeboard to  keep  vapors  inside  the
tank.
   7. Use specially designed containers
with automatic lids and drains.
   8. Drain parts over the tank to cap-
ture as much of the solvent as possible.
Parts should  remain in the unit  until
dry so that there is no drag-out  of sol-
vent.
   9.  Don't use  compressed air sprays
to blow  dry parts or to mix cleaning
baths. These will just propel vapors into
the surrounding air.
   Many  companies  are now offering
completely enclosed  cold cleaning ma-
chines that provide little or no  loss of
vapor

 EMISSIONLESS DEGREASING
   As far fetched as it mav sound todav.
the chief alternative to MCF solvent
degreasing  processes may eventually
be emissionless surface cleaning with
solvents. An ideal process in which no
solvent  vapors are lost through emis-
sions, all solvent is recycled, and sol-
vent residues are either reused or used
as a fuel on site, should eventually be
available.
  This  is not an  impossible dream.
There is an excellent chance that emis-
sionless cleaning will begin to be avail-
able on the US market in the next year
or two. To  begin with, new totally en-
closed equipment designs  that elimi-
nate the solvent to  air interface are
being utilized in Europe and should be
available in North America in the near
future. These cleaning systems can re-
duce emissions beyond 95% compared
with  today's  open  top  degreasers.
Methods are in the development stage
for  trapping the  remaining  solvent
emissions before they leave the plant.
  Even today,  virtually emissionless
operation is theoretically possible. Car-
bon adsorption equipment, for exam-
ple, when properly designed promises
near zero emission. It is costly to oper-
ate, however, and few users have been
able to  approach full solvent loading.
One major problem lies in the steam
stripping process generally used to re-
move solvents from the spent carbon.
  When used with methyl chloroform,
steam  can  cause  removal of the  in-
hibitors from the MCF, which leads to
excessive equipment corrosion. Using
titanium or Hastalloy metals can reduce
the  corrosion and extend equipment
life. Stripping with super heated steam
can avoid these problems, but this must
be done carefully because high temper-
atures can  break down methyl chloro-
form and other chlorinated solvents.
   Molecular sieves provide  an im-
provement in the technology of solvent
capture, since they are able to separate
water from solvent. They  are still not
 100% efficient,  however, when used
with chlorinated solvents.
   The Dow Chemical Company is cur-
rently studying improved means of sol-
vent capture, including the use of ad-
 vanced adsorbent  materials and proc-
esses. It is possible that adsorption sys-
tems with  definite advantages  over
those currently on  the market will be
commercially available in a few years.
   The  probability  that  emissionless
 metal cleaning will soon  be  a reality
 sheds a new  li°ht on the criteria  for
selecting cleaning solvents. At present,
manufacturers are searching  for sys-
tems that will meet OSHA guidelines
for worker exposure and Clean Air Act
requirements for emissions; however,
these considerations may no longer be
relevant  once processes are available
that provide almost no emissions to the
workplace  or environment.   Metal
cleaning specifiers will then be able to
concentrate  exclusively on the perfor-
mance of the solvent.           MF
             Biography
                    Jim  Mertens is
                 project leader for
                 chlorinated    sol-
                 vents    technical
                 service  and  de-
                 velopment (TS&D)
                 in  the  chemicals
                 and metals depart-
                 ment, Dow Chemi-
                 cal USA. Mertens
joined Dow in 1972 in Allyn's Point,
CT,  as operations supervisor for the
eastern division latex product plant. In
1981,  he transferred to Midland as a
chemist  for  products/industrial de-
velopment. The following year he was
named a research chemist for new ap-
plications development. He moved to
formulated  products TS&D in  1983,
and  was  named  senior development
chemist  in  1985. Mertens moved to
field operations in 1988. He assumed
his current position  in 1989.
   BASKETS
      BY C<
        5025 N. RIVER RD.
     SCHILLER PARK. IL 60176
    708-678-8585 • Fax:708-678-8612
                                                                                  Circle 040 on reader Information cart

-------
James A. Mertens






      James A. Mertens is a Development Leader with Advanced Cleaning Systems, a




business unit of Dow Environmental (Midland, Mich.), and a member of the Technical




Service and Development. Group (TS&D).  His responsibilities include working with




customers to  develop, design and implement alternative cleaning systems to 1,1,1-




trichloroethane and CFC 113.




      Mertens earned an M.B.A. at the University of New Haven, Conn., and a




Bachelor of Science from St. Bonaventure University in Allegany, N.Y..  He is a member




of The United Nations Environment Programme, Solvents, Coatings and Adhesives




Technical Options Committee which participates in the technical assessment for The




Montreal Protocol.  He is also a member of the Technical Advisory Group for the




University of Tennessee's Cleaning and Testing Evaluation Project.




      He has been with Dow for 23 years, seven years in latex production at  the Allyns




Point Plant in Connecticut, and 11 years in Chlorinated Solvents TS&D in Midland. He




has been involved with Advanced Cleaning Systems since its inception at Dow four and a




half years ago.  His  assignments in TS&D have involved industrial hygiene,  coatings, new




applications and surface  cleaning.




                                    #   #  #

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46
     Appendix C
       PERCENT BY WEIGHT
            SOLVENT
         DETERMINATION

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If you own a solvent cleaning machine in which you use less than 5 percent by weight of
the solvents listed above, you need to keep records of that determination on-site (e.g.,
Material Safety Data Sheets [MSDSs], EPA Test Method 18 results, and/or calculations).
Solvent MSDS's are  typically available from your solvent supplier.

Stoddard solvents/naphthas generally contain less than 5 percent by weight halogenated
solvent and will not typically be subject to  this rule. The MSDSs for these solvents
should provide sufficient documentation of solvent content.

If you create your own solvent blend, for which the listed solvents are a part, but
comprise less than 5 percent by weight of the solvent, you need to show through
calculations or MSDSs the weight percent  that the listed solvents make up.  This is
required to demonstrate that the rule does not apply to you. One way you can do this is
to do the following calculation:
  Step 1:  §  Gather the following information for each blend you make.
                   S% = The weight percent of the listed solvents for each solvent
                   added to your blend (in decimal form);

                   TW = The total weight of each solvent added to your blend; and

                   M = total solvent mass.
             Multiply the TW by the S% for each of your solvents.  The result of this
             calculation equals WS, the weight of the listed solvents added to the blend
             for each of the solvents.

                                  WS = S% * TW
  Step 3:  §  Add the WS for each of the solvents added to your blend. The result of
             the calculation in Step 3 is TB, the total weight of the listed solvents in
             your blend.

                           TB =  WSi +  WS2  +  WS3 +	

-------
             Divide TB by M.  Then multiply by 100.  The result of this calculation is
             the TW% of the listed solvents in your solvent blend.

                                TW% = TB  -r M
The other method you can use to determine the weight percent contained in your solvent
is by using EPA test method number 18.  This test method should be performed by a
person qualified in the operation of a flame ionization detector.
J
<
(
<
1
Example Calculation
Step 1: Solvent Mixture X
Solvent Mixture
Component
i * PCE
2 = MC
3 = TCE
Total Weight of Solvent Mixture
(M)
Step 2:
TW
20g x
30e x
lOe x

TW
Total Weight of
Component
20g
30K
10g
«>g

s%
0.3
0
1.0

s%
% of Listed Solvent
0.3
0
1.0
13

WS
6s:
0
10g


Step 3:
WS:+ WS2+ WS3= TB
6g + Og + lOg = 16g
Sept 4:
(TB + M) x 100 = TW%
(16g -60g)x 100 = 27%
Solvent mixture X contains 27 percent by weight of the listed solvents. Solvent mixture X is
therefore considered to be a halogenated solvent and solvent cleaning machines using solvent
mixture X are subject to thk rule.

-------
Page A-5 of this Appendix provides a blank calculation sheet for your convenience.  This
blank calculation sheet is not required; any calculation sheet recordkeeping format
incorporating the required documentation would be acceptable.

-------
HALOGENATED SOLVENT CONTENT RECORDKEEPING  FORM
Cleaner Identification Number:
Machine Type (circle one):     Batch Vapor     Batch Cold




Step 1: Solvent Mixture	
                         In-line
Solvent Mixture
Component
1
2
3
4
4
6
Total Weight of Solvent
Mixture (M)
TW
Total Weight of
Component







S%
% of Listed Solvent







Step 2:
       TW
S%
ws

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HALOGENATED SOLVENT CONTENT RECORDKEEPING FORM
                      (Continued)
Step 3:


              j + WS2 + WS3  + WS4 + WS5 + WS6 = TB
Step 4:


                   (TB 4- M) x 100 = TW%

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Appendix D
   TITLE V OVERVIEW

-------
                   CLEAN AIR ACT AMENDMENTS OF 1990

                        TITLE V PERMITS OVERVIEW
Title V is a section of the  amendments made in 1990 to the Federal Clean Air Act
(CAAA). This section of the amendments will have a significant impact on all 50 states,
in that it:

<     Requires all states to have a FEDERALLY ENFORCEABLE air pollution permit
      system.
            Presently, operating permit programs are run strictly by the states and are
            not subject to  direct Federal intervention.  Under Title V, a state may not
            issue air operating permits without EPA approval,  and must not issue a
            permit if EPA objects.

<     Requires that the program be  paid for by emission fees  assessed to permit
      holders.
            Fees are to be set at a presumptive minimum of $25 per ton of pollutant
            emitted, up to 4000 tons for each pollutant covered by the permit.  Fees are
            tied to the consumer price index and are based on 1990 dollars, so they will
            presumably increase with time.

One intent of the program is to consolidate the multiple permits  that  industrial sources
hold into a single permit covering an entire facility. The permit application must address
all current applicable regulatory requirements as well as all known and  anticipated
requirements during the length of the  permit, which will probably be five years.   In
addition to identifying applicable requirements, the applicant must identify those that are
not  applicable and ustify that decision to the satisfaction of the regulators.

                         TO WHOM DOES IT APPLY?

Title V permits are presently required for major sources. A ma  or source is one which
is capable of emitting at least  10 tons per year of any single hazardous air pollutant
(HAP), or 25 tons per year of  any combination of HAPs, or 100 tons per year of any
other regulated air pollutant. These figures may be  set at lower levels in some so-
called non-attainment areas.

What makes  a facility sub ect  to regulation  under Title V is  not actual emissions, but
rather the potential  to emit  (PTE).   PTE  is defined as the maximum potential
emissions from a source calculated as if it were operated at full  design capacity for
8760 hours  per year.
                                                    UT CENTER for INDUSTRIAL SERVICES

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The pollutants covered under Title V include the criteria pollutants (SOX, NOX, VOCs,
CO, lead and particulates), plus a list of 189 HAPs which are specified in CAAA's Title
III. Because each state is constructing its own enforcement plan, even more pollutants
may be included in some states.

                             THE PERMIT SHIELD

Title V incorporates a feature called the "permit shield" which is intended to protect the
applicant from enforcement actions during  the period an application may be pending.
Once  an application is received by the state agency,  and the agency  deems it
complete, the application is eligible to be covered by the "permit shield".  What this
means is that the applicant must request the permit shield in his application -
granting it is not automatic.  The permit shield will ensure that the applicant can keep
operating under existing permits without fear of enforcement actions  based on permit
expiration while the application is being processed, which can easily be a perlo'd of two
years.

                           TIMING AND DEADLINES

The CAAA requires permits to be submitted within a specific time frame.

<    The  clock starts when  EPA approves the state's Title  V  program. As of
      December, 1994, the Tennessee program had not been approved by the EPA.

<    Within  one year of  the  date of EPA approval of Tennessee's plan,  all  new
      applications must be submitted to the state.

<    Within  that same one  year period, the state must issue one-third of the  permits.

<    Another third of the permits must be issued during the second year and  the final
      third, during the  third year.

The following is how the Tennessee plan anticipates this will  be accomplished:

<    The state has asked for volunteers to commit to filing applications within 120 days
      so that their applications can be processed and permits issued  during the first
      year.  Enough volunteers responded to fill the first group.

<    A drawing will determine which companies are in the second group and  the third
      group.

<    Although the act places a limit of five years on the length of permits, the state will
      attempt to stagger the flow of future permit applications by assigning varying terms
      to initial permits during the round of initial applications.  It is anticipated that all

		      Page 2           UT CENTER for INDUSTRIAL SERVICES

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      renewals will be for five-year terms.

                     COMPLIANCE AND RESPONSIBILITY

Under  the  new permits, a  permit may  be  re-opened during its term, so that new
requirements can be imposed to reflect changes in Federal regulations or changes in the
source being regulated. A renewal application will be more like a new permit than under
the present system.

Compliance demonstrations will  be required,  and the  permit will contain detailed
procedures for monitoring and/or recordkeeping to demonstrate compliance.

CAAA  requires that the  application,  including the emissions  inventory, testing plans,
monitoring procedures must be certified by a responsible official of the company, which
is  defined as a company officer or the highest  ranking operating manager at a
specific site.

The responsible official is subject to personal civil or criminal penalties, along with
the company, forfiling false or misleading information, even if unintentional. In addition,
EPA can prosecute employees at any level if they are  party to a violation.

Monetary penalties for non-compliance are increased, and the  possibility of violations is
multiplied by the increased monitoring, testing and certification  requirements. Penalties
can involve civil and criminal prosecutions; EPA can impose administrative penalties up
to  $100,000 without going to court;  inspectors can issue spot penalties up to $5000 on
field citations.

                          OPERATIONAL FLEXIBILITY

One facet of Title V  is that it allows a facility to define alternate operating scenarios for
processes and include them in their  permit so long as compliance can be maintained.
However, it will be necessary to include all alternate operating schemes in the  permit,
which will greatly complicate the application procedure.

                     SUMMARY - WHAT CAN I DO NOW?

The CAAA makes it clear that^eongress1 intent was to give EPA  an enforcement tool.
Title V is written on the premise that operations under current permitting procedures are
not in  compliance.   The permit will  detail all emissions sources, establish limits  and
prescribe methods by which you will  demonstrate that you are in  compliance.  Several
members of the regulatory community have recently said that the procedure that will be
used in processing applications is that "the permitee will propose, the regulatory  agency
will respond"   Under this procedure,  the burden is on the  permit applicant to determine
what restrictions are applicable,  what restrictions  are not, how  emissions are to be

	Page  3           UT CENTER for INDUSTRIAL  SERVICES

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controlled, and how the permitee will  demonstrate that he  is in compliance with
applicable restrictions.

Until the Tennessee program has been approved by the EPA, the proposed program is
sub ect to change.  However, any facility which currently has air permits will eventually
have to file for a  new one. Because Tennessee will pattern all future permits after the
Title V permits, it is definite that the starting point will be a complete inventory of all
emissions to the atmosphere from the facility.  Because this can be a long, arduous
process, it is recommended that this step be commenced as soon as time and personnel
can be made available.

For up-to-date information on  the status of state and  local  programs, EPA has an
electronic bulletin board, updated monthly, which is accessible from a computer with a
modem by dialing 919-541-5742 (Technical Assistance Hotline, 919-541-5384).
                                     Page 4           UT CENTER for INDUSTRIAL SERVICES

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48
     Appendix E
         OPERATOR TEST

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             Test  of  Solvent  Cleaning  Procedures

General Questions

	 1.   What is the maximum allowable speed for parts
          entry and removal?

          A.   8.5 meters per minute  (28 feet per minute).
          B.   3.4 meters per minute  (11 feet per minute).
          C.   11 meters per minute (36 feet per minute) .
          D.   No limit.

	 2.   How do you ensure that parts enter and exit the
          solvent cleaning machine at the speed required  in
          the regulation?

          A.   Program on computerized hoist monitors speed.
          B.   Can judge the speed by looking at it.
          C.   Measure the time it takes the parts to travel
               a measured distance.

	 3.   Identify the sources of air disturbances.

          A.   Fans
          B.   Open doors
          C.   Open windows
          D.   Ventilation vents
          E.   All of the above

	 4.   What are the three operating modes?

          A.   Idling, working and downtime
          B.   Precleaning, cleaning, and drying
          C.   Startup, shutdown, off
          D.   None of the above

	 5.   When can parts or parts baskets be removed  from
          the solvent cleaning machine?

          A.   When they are clean
          B.   At any time
          C.   When dripping stops
          D.   Either A or C is correct

	 6.   How must parts be  oriented  during cleaning?

          A.   It does not matter  as  long as they  fit in the
               parts basket.
          B.   So that the solvent pools in the  cavities
               where the dirt  is concentrated.

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     C.   So that solvent drains from them freely.

7.    During startup, what must be turned on first, the
     primary condenser or the sump heater?

     A.   Primary condenser
     B.   Sump heater
     C.   Turn both on at same time
     D.   Either A or B is correct

8.    During shutdown, what must be turned off first,
     the primary condenser or the sump heater?

     A.   Primary condenser
     B.   Sump heater
     C.   Turn both off at same time
     D.   Either A or B is correct

9.    In what manner must solvent be added to and
     removed from the solvent cleaning machine?

     A.   With leak proof couplings
     B.   With the end of the pipe in the solvent sump
          below the liquid solvent surface.
     C.   So long as the solvent does not spill, the
          method does not matter.
     D.   A and B

10.  What must be done with waste solvent and still and
     sump bottoms?

     A-   Pour down the drain
     B.   Store in closed container
     C.   Store in a bucket
     D.   A or B

11.  What types of materials are prohibited from being
     cleaned in solvent cleaning machines using
     halogenated HAP solvents?

     A.   Sponges
     B.   Fabrics
     C.   Paper
     D.   All of the above

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Control Device Specific Questions

[ ]  Freeboard Refrigeration Device

	 1.   What temperature must the FRD achieve?

          A.   Below room temperature
          B.   50°F
          C.   Below the solvent boiling point
          D.   30 percent below the solvent boiling point

[ ]  Working-Mode Cover

	 2.   When can a cover be open?

          A.   While parts are in the cleaning machine
          B.   During parts entry and removal
          C.   During maintenance
          D.   During measurements for compliance purposes
          E.   A and C
          F.   B, C, and D

     3.   Covers must be maintained in what condition?
           A.    Free of  holes
           B.    Free of  cracks
           C.    So that  they completely  seal  cleaner opening
           D.    All of the above
 [  ]   Dwell
      4.    Where must the parts be held for the appropriate
           dwell time?

           A.    In the vapor zone
           B.    In the freeboard area above the vapor zone
           C.    Above the cleaning machine
           D.    In the immersion sump

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                           ANSWERS




General Questions
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
B
A or C
E
A
C
C
A
B
D
B
D
Control Device Specific Questions
1.   D




2.   F




3.   D




4.   B

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Appendix F
       SAMPLE
RECORDKEEPING FORMS

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         HALOGENATED SOLVENT CLEANER NESHAP:
                  FRDa RECORDKEEP1NG  FORM
Cleaning Machine Identification Number:	

Machine Type (circle one):      Batch Vapor

FRD Temperature Requirement:
                            In-Une
             Solvent:
  Date/
 Initials6
Temperature (°F)
Date/
Initials6
Temperature (°F1
a FRD = Freeboard refrigeration device.
5 Date of inspection and initials of employee conducting inspection.

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          HALOGENATED SOLVENT CLEANER NESHAP:

                   SHV8 RECORDKEEPING  FORM
 Cleaning Machine Identification Number:	

 Machine Type (circle one):      Batch Vapor

 SHV Temperature Requirement:
                            In-Une
  Date/
  Initials'3
Temperature (°F)
Date/
Initialsb
Temperature (°F)
a SHV = super-heated vapor.
b Date of inspection and initials of employee conducting inspection.

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        HALOGENATED SOLVENT CLEANER NESHAP:
   DWELL DETERMINATION TEST RECORDKEEPING FORM
Cleaning Machine Identification Number:

Parts Description:
Date/Initials3




Run 1
Run 2
Run 3
Time for Parts to
Stop Dripping in
Vapor Zone
(seconds)

Individual Dwell
Times (second)
x 0.35 =
x 0.35 =
x 0.35 =
                                         Total
Cleaning Machine Identification Number:

Parts Description:
/3 =   seconds

= Proper Dwell
    Time

Date/Initials3


i


Run 1
Run 2
Run 3
Time for Parts to
Stop Dripping in
Vapor Zone
(seconds)



Individual Dwell
Times (second)
x035 =
x035 =
x035 =
                                         Total
" Date of test and initials of employee conducting test.
/3 =  seconds

= Proper Dwell
    Time

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         HALOGENATED SOLVENT CLEANER NESHAP:

    DWELL MEASUREMENT TEST RECORDKEEPING FORM
Cleaning Machine Identification Number:

Parts Description:	

Proper Dwell Time:	
  Date/
 Initials3
Actual Dwell (seconds')
 Date/
Initials3
Actual Dwell (seconds)
 Date of inspection and initials of employee conducting inspection.

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         HALOGENATED SOLVENT CLEANER NESHAP:

      REDUCED ROOM DRAFT INITIAL WINDSPEED  TEST
                     RECORDKEEPING FORM
Cleaning Machine Identification Number:	

Machine Type (circle one):      Batch Vapor
La-Line
Reduced Room Draft Requirement: Less than or equal to 15.2 meters per minute
                            (50 feet per minute). Complete A or B, and C
A_ For Controlling Room Parameters:

Corner Q
Corner Q
Corner C3
Corner C4
Average Windspeed
= Q + Cj + Q + C,^
WINDSPEED (meters or feet per minute)
Test 1





Test 2





TestS





B.  For An Enclosure:
Maximum enclosure windspeed
(meters or feet per minute).
C.  Description of Room Parameters or Enclosure:

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         HALOGENATED SOLVENT CLEANER NESHAP:

    REDUCED ROOM DRAFT WINDSPEED MEASUREMENTS
                     RECORDKEEPING FORM
Cleaning Machine Identification Number:	

Machine Type (circle one):     Batch Vapor
                            In-line
If using room parameters, measure windspeed quarterly and check room parameters weekly.
If using an enclosure, measure windspeed and check enclosure monthly.
  Date/
 Initials3
   Windspeed
(meters or feet per
    minute)
               Windspeed
 Date/       (meters or feet per
Initials3           minute)
 Date of inspection and initials of employee conducting inspection.

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         HALOGENATED SOLVENT CLEANER NESHAP:
         CARBON ADSORBER RECORDKEEPING  FORM


Cleaning Machine Identification Number:	

Machine Type (circle one):      Batch Vapor      In-Line

Maximum Allowable Outlet Concentration of the Covered Solvents:  100 ppm
  Date/        Outlet Concentration
 Initials3        	(ppm)
 Date/
Initials3
Outlet Concentration
     (ppm)	
 Date of inspection and initials of employee conducting inspection.

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          HALOGENATED SOLVENT CLEANER NESHAP:
                 COVER RECORDKEEPING FORM
Cleaning Machine Identification Number:	

Machine Type (circle one):      Batch Cold
Batch Vapor
In-Line
Date/Initials3

















Opening & Closing
Properly*
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Completely Covers
Openings"
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Free of Cracks,
Holes and Other
Defects6
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
- N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
" Date of inspection and initials of employee conducting inspection.
b Circle appropriate answer: Y = Yes, N = No.

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         HALOGENATED SOLVENT CLEANER NESHAP:

               AUTOMATED PARTS HANDLING -
             HOIST SPEED RECORDKEEPING FORM
Cleaning Machine Identification Number:	

Machine Type (circle one):      Batch Vapor      In-Line

Maximum Allowable Hoist Speed: 3.4 meters per minute (11 feet per minute)
Date/
Initials*















(1)
Distance Moved
(meters or feet)6















(2)
Time Elapsed
(minutes)















Hoist Speed
(1) ' (2)
(meters or feet
per minute)















Distance Description0
(Starting Point/Ending Point)















a Date of inspection and initials of employee conducting inspection.
b Circle appropriate unit.
c e.g., Left Rim /Right Rim

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Appendix G
     ALTERNATIVE
 STANDARDS: MONTHLY
 EMISSIONS WORKSHEET

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         HALOGENATED SOLVENT CLEANER NESHAP:

                    OVERALL EMISSIONS LIMIT
         MONTHLY EMISSIONS RECORDKEEPING FORM

             (For Machines That Have a Solvent-Air Interface Area)

Cleaner Identification Number: 	
Month/Year











SA
(1)











LSR
(2)











SSR
(3)











AREA
(4)











Monthly
Emissions
m- rc2) +rs)i
_3











SA    =    Amount of halogenated solvent added (kilograms of solvent added [or pounds
           of solvent added]) that month.
LSR  =    Amount of halogenated solvent removed (kilograms of solvent removed [or
           pounds of solvent removed]) that month.
SSR  =    Amount of halogenated solvent removed from the cleaning machine in solid
           waste (kilograms of solvent removed  [pounds of  solvent removed] that
           month).
AREA  =    Amount of halogenated  solvent removed from the  machine in solid waste
           (kilograms of solvent removed [or pounds of solvent removed]).

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Appendix H
  CLEANING CAPACITY

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APPENDIX B
If your machine does not have a solvent-air interface area, you need to determine the
cleaning capacity (cubic meters [cubic feet]) to determine the appropriate overall
emissions limit that would apply to you. This option is available only to machines that
do not have solvent air interface. A machine's cleaning capacity can be determined in
any of the following ways:

<•>    Check the literature that was provided with >  ir machine at the time of purchase
      to see if it includes a measurement of the cleaning capacity for your cleaning
      machine;
      Ask the manufacturer of your
      machine for the cleaning
      capacity;
<•)    Determine the cleaning
      capacity of your machine from
      the following information:

      •      The internal width (IW)
             (in meters [or in feet])
             of the cleaner tank,

      •      The internal length (IL)
             (in meters [or in feet])
             of the cleaner tank, and

      •      The depth (D) (in
             meters [or in feet]) of
             the cleaner tank.

The cleaning capacity  is obtained by
multiplying the above  numbers
together (i.e., CAPACITY =  IW IL
* D).  The values could be
determined from literature received
with your machine or provided by the
machine manufacturer or by
measuring the machine yourself
Emission limits for machines  th _t do not have a solvent-air interface area are presented
in Table B-l. Note that if the cleaning capacity for your machine falls between those
presented in Table B-l, the limit for your machine is the lower emissions limit.
* IMctt

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52
     Appendix I
       SAMPLE REPORTING
             FORMS

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         HALOGENATED SOLVENT CLEANER NESHAP:

           Compliance Report for Batch Cold Cleaners

PART ONE - General Information
Person Preparing Form:_	Date:_
                     Last Name,  First Name,  Middle Initial

Company Name	
Mailing Address,
                 Number,     Street,      City/Town,      State,    Zip Code
Equipment
Location Address
                Number,     Street,      Ciry/Town,      State,   Zip Code
 Cleaning Machine Summary
         Identification Number                     Description
G-6                                                Guidance Document/als.118

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         HALOGENATED SOLVENT CLEANER NESHAP:

           Compliance Report for Batch Cold Cleaners
PART TWO - Information Required per Machine
              (Make copies for additional machines as necessary)
Cleaner Identification Number:
Cleaning Machine Type (circle one):
           Immersion
 Remote-Reservoir
This batch cold cleaner complies with the rule.
 Signature
                            Date
Method of Compliance (circle one):
   Cover and Water
        Layer
 Cover and a 0.75
Freeboard Ratio or
Greater with Work
    Practices
Cover with Work
   Practices
Guidance Document/sis. ^ 18
                                          G-7

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          HALOGEMATED SOLVENT CLEANER NESHAP
           initial Notification Report for New* Machines
  {Application for Approval of Construction or  Reconstruction)
PART TWO - Information Required per Cleaning Machine
               (Make copies for additional machines as necessary)
1.     Type of machine intended for construction/reconstruction (check one):

      	Batch vapor          	Cold in-line           	Vapor in-line

2.     Solvent/air interface area	square meters (square inches)

3.     Intended controls

      	Freeboard ratio of 1.0                   	Carbon adsorber
      	Freeboard refrigeration device               Reduced room draft
      	Super-heated vapor                     	Dwell
      	Working-mode cover                       Other	
                                                         Control

4.     Proposed construction or reconstruction commencement date	

5.     Expected construction or reconstruction completion date	

6.     Anticipated date of initial startup	
7.     Anticipated compliance approach

      	Basic equipment standard          	Idling emission standard
         Alternative standard
8.  Annual estimate of halogenated HAP solvent consumption

      	kilograms/year (pounds/year)


*New cleaning machines are cleaners installed after November 29, 1993.

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         HAIOGENATED SOLVENT CLEANER NESHAP:


          Initial Statement of Compliance for Machines
            Complying with the Equipment Standard


PART ONE - General Information
Person Preparing Report.
                     Last Name, First Name, Middle Initial
      Date
Company Name_
Mailing Address,
                Number,     Street,      City/Town,      State,    Zip Code
Intended Equipment
Location Address	
                Number,     Street,      City/Town,      State,    Zip Code
 Cleaning Machine Summary
        Identification Number
Description

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          HALOGENATED SOLVENT CLEANER NESHAP:
           Initial Statement of Compliance for Machines
              Complying with the Equipment Standard
PART TWO - Information Required per Cleaning Machine
              (Make copies for additional machines as necessary)
1.     Type of machine (check one):

      	Batch vapor          	In-line


2.     Solvent/air interface area	square meters (square feet)


3.     Equipment Standard Compliance Method chosen

         Control combination
        _Idling emission limit (idling emission limit test report attached)
4.     Control equipment used to comply with the rule

      	Freeboard ratio of 1.0                  	Carbon adsorber
      	Freeboard refrigeration device              Reduced room draft
        _Super-heated vapor                        Dwell
        _Working-mode cover	Other.
        _Other                                                  Control
                                             	Other_	
                                                               Control

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5.     Monitored Parameters and Values:
Control
(check all that
applies)
Freeboard
Refrigeration
Device
Cover (Working
mode and idling-
mode)
	 Dwell
Superheated
Vapor System
Reduced Room
Draft
Measured Parameter
• Temperature at the center
of the air blanket while
idling
• Use, function and integrity
• Period of time parts are
held in the solvent cleaning
freeboard area above the
vapor zone after being
cleaned.
• Temperature at the center
of the super-heated vapor
zone while idling
• Windspeed
- Room parameters
(e^, enclosure*)
L
2.
3.
4.
Compliance Parameter Value
« 5 30 percent of the solvent
hailing point
• Opens and doses properly
• Closed except during parts
entry and removal
• Closes completely
» Free of cracks, holes, or
other defects
• Determined for each of your
parts or parts baskets you
dean, or
« Determined using the most
complex part type or parts
baskets you clean.
• At least 10°F above the
solvent's boiling point
• < 153. meters per minute
(50 feet per minute)
L
2.
3.
4.
*If a full or partial enclosure is used to achieve the reduced room draft for your de-aning machine,
attached the initial monitoring test
Carbon Adsorber
Other
• Working-mode exhaust
halogenated solvent
concentration (weekly
measurement records of
the exhaust halogenated
solvent concentration
attached)

• < 100 ppm


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         HALOGENATED SOLVENT CLEANER NESHAP:


          Initial Statement of Compliance for Machines
            Complying with the Alternative Standard


PART ONE - General Information
Person Preparing Report	Date:_
                      Last Name,  First Name,  Middle Initial
Company Name_
Mailing Address.
                Number,     Street,      City/Town,      State,    Zip Code
Equipment
Location Address
               Number,    Street,      City/Town,      State,   Zip Code
        Machine Summary
         Identification Number                     Description

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          HALOGENATED SOLVENT CLEANER NESHAP
     initial Statement of Compliance for Cleaning Machines
             Complying with the Alternative Standard
PART TWO - Information Required per Cleaning Machine
              (Make copies for additional machines as necessary)
Cleaner Identification Number:
1.    Type of machine (check one):

     	Batch vapor          	In-line


2.    a)    Solvent/air interface area:  	square meters, or
     b)    Cleaning capacity: 	cubic meters, if your cleaning machine
           does not have a solvent/air interface area (calculation method and results for
           this determination attached).
3.    The first 3-month average emissions is	kilograms per month (calculation
     sheets are attached).

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         HALOGENATED SOLVENT CLEANER NESHAP:

                            Annual Report


PART ONE - General Information
Person Preparing Report	 Date_
                     Last Name,  First Name, Middle Initial
Company Name_
Mailing Address_
                 Number,     Street,      City/Town,      State,    Zip Code
Intended Equipment
Location Address
                Number,     Street,      City/Town,      State,   Zip Code
 Cleaning Machine Summary
         Identification Number                      Description

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          HALOGEIMATED SOLVENT  CLEANER NESHAP

                              Annual Report
PART TWO - Information Required per Cleaning Machine
              (Make copies for additional machines as necessary)
Cleaner Identification Number:
Check compliance option chosen and fill out appropriate report requirements.

d    Control Options

      All operators of solvent cleaning machines have received training on the proper
      operation of solvent cleaning machines and their control devices sufficient to pass the
      required operator test
                             Signature                            Date

      Previous Year's Solvent Consumption	Mg/yr.

 D    Alternative Standard

      Cleaning machine size:

           Solvent-air interface area	.    m2
                       or
           Solvent cleaning capacity	m3

      Average monthly solvent consumption	kg


 Three month rolling            1.             kg   From          To
  average emission estimates:
  (calculations attached)                                   Date         Date

                             2. 	 kg   From 	To  	
                                                        Date         Date

                             3. 	kg   From 	To  	
                                                        Date         Date

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         HALOGENATED SOLVENT CLEANER NESHAP:

                        Exceedance Report


PART ONE - General Information
Person Preparing Report	 Date_
                     Last Name, First Name, Middle Initial
Company Name_
Mailing Address,
                 Number,     Street,       City/Town,      State,    Zip Code
Intended Equipment
Location Address
                Number,     Street,      City/Town,      State,    Zip Code
 Cleaning Machine Summary
         Identification Number                      Description

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          HALOGEIMATED SOLVENT CLEANER NESHAP

                         Exceedance Report
PART TWO - Information Required per Cleaning Machine
              (Make copies for additional machines as necessary)
Cleaner Identification Number:
Check appropriate box and answer the requested information.

I	I   Exceedance

Exceedance that occurred:	
Date of occurrence^

Actions taken:
Results of actions:
I	1   No exceedance occurred.

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Appendix J
       RESOURCES



         - EPA CONTACTS



     - EQUIPMENT SUPPLIER LIST

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The contact phone number for the  EPA Regional Office where your state  or  territory
resides is listed in the following table:
Region
1
2
3
4
5
6
7
8
9
10
States
CT, ME, MA, NH, RI, VT
NJ, NY, Puerto Rico, Virgin Islands
DE, MD, PA, VA, WV, District of Columbia
AL, FL, GA, KY, MS, NC, SC, TN
IL, IN, MI, WI, MN, OH
AR, LA NM, OK, TX
IA KS, MO, NE
CO, MT, ND, SD, UT, WY
AZ, CA, HI, NV, American Samoa, Guam
AK, ID, WA, OR
Telephone
(617) 565-2734
(212) 264-6819
(212) 264-6679 (NY only)
(215) 597-3237
(404) 347-2864"
(312) 353-8615 (IL and IN)
(312) 886-503-1 (MI and WI)
(312) 886-7017 (MN and OH)
(214) 656-7547
(913) 551-7960
(303) 293-1886
(415) 744-1143
(206) 553-1949

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               VAPOR DECREASING EQUIPMENT  SUPPLIERS
 Baron-Blakeslee Inc.
 2001  North  Janice Ave.
 Melrose  Park  IL.  60160
 312-450-3900

 Branson  Cleaning  Equipment  Co.
 Parrott  Drive
 Shelton  CT  06484
 203-929-7301

 Casso-Solar Corp.
 P.O.  Box 163
 U.S.  Route  202
 Pomona,  NY  10970
 914-354-2000

 Cinncinnati Industrial Machinery Div.
 Eagle-Picher  Industries  Inc.
 2027  Hageman  St.
 Cincinnati  OH 45241
 513-769-0700

 Cooper Co., D.C.
 1467  So. Michigan  Ave.
 Chicago  IL  60605
 312-427-8046

 Corpane  Industries
 250 Production Ct.
 Louisville, KY 40299
 502-491-4433

 Crest Ultrasonics  Corp.
 One Scotch  Rd.
 Trenton,  NJ 08628
 609-883-4000

 Delta Industries
 8137 Allport
 Santa Fe Springs CA 90670
 213-945-1067

 Detrex Chemical Industries Inc.
 4000 Town Center
 Southfield,  MI 48075
 313-358-5800

Finishing Equipment Inc.
 3640 Kennebec Drive
 St. Paul MN 55122
 612-452-1860

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The University of Tennessee does not discriminate on the basis of race,
sex, color, religion, national origin, age, handicap, or veteran status in
provision of educational opportunities or employment opportunities and
benefits.

The University does not discriminate on the basis of sex or handicap in its
educational programs and activities, pursuant to requirements of Title IX
of the Educational Amendments of 1972, Public Law 92-318, and Section
504 of the Rehabilitation Act of 1973, Public Law 93-112, and the Ameri-
cans With Disabilities Act of 1990, Public Law 101-336, respectively. This
policy extends to both employment by and admission to the University.

Inquiries concerning Title IX, Section 504, and the Americans With Dis-
abilities Act of 1990 should be directed to Mr. Gary W. Baskette, Director
of Business Services,  109 Student Services and Administration  Building,
Knoxville, Tennessee 37996-0212, (615) 974-6622. Charges of violation of
the above policy should also be directed to Mr. Baskette.

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