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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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BOARD
April 1995
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The University of Tennessee Center for Industrial Services
Tennessee Department of Environment and Conservation
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-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
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 compliancethe
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 degreaserideally, 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 solventfor 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 yearIf
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 categoriesminor 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.
-------
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.
-------
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
-------
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.
# # #
-------
46
Appendix C
PERCENT BY WEIGHT
SOLVENT
DETERMINATION
-------
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
-------
HALOGENATED SOLVENT CONTENT RECORDKEEPING FORM
(Continued)
Step 3:
j + WS2 + WS3 + WS4 + WS5 + WS6 = TB
Step 4:
(TB 4- M) x 100 = TW%
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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.
-------
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.
-------
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
-------
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]).
-------
Appendix H
CLEANING CAPACITY
-------
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
-------
52
Appendix I
SAMPLE REPORTING
FORMS
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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).
-------
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
-------
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
-------
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
-------
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.
-------
Appendix J
RESOURCES
- EPA CONTACTS
- EQUIPMENT SUPPLIER LIST
-------
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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