Halogenated Solvent Question and Answers (Q&As) 12/98 (updated 11/7/02)

Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

Halogenated Solvent Question and Answers (Q&As)

12/98 (updated 11/7/02)

Applicability

QUESTION: In the definition of a solvent cleaning machine, it says that "buckets, pails, and beakers
with capacities of 7.6 liters (2 gallons) or less are not considered solvent cleaning
machines." Are there specific definitions for 'buckets, pails, and beakers'? We have a
source that has a cold batch cleaning unit that is approximately 10" x 10" x 6"...therefore,
they do not meet the appropriate freeboard, but the total capacity of the unit is definitely
less than 2 gallons. Are they subject?

ANSWER: You are correct we did not define buckets, pails or beakers. EPA excluded buckets,

pails and beakers with less than 2 gallons capacity to make sure we were not requiring
small operations (such as a lab or someone cleaning by dipping it a small bucket) to
comply with the rule. Nevertheless, if the equipment is designed for carrying out solvent
cleaning operations and is less than 2 gallons capacity (as some bench top models are) it
is subject to the rule.

QUESTION: Does the Halogenated Solvent NESHAP apply to paint stripping operations?

ANSWER: No. The rule states that the provisions apply to each solvent cleaning machine using

methylene chloride, etc. Solvent cleaning machine is defined as "any device or piece of
equipment that uses halogenated HAP solvent liquid or vapor to remove soils from the
surfaces of materials." Also, "Soils means contaminants that are removed from the parts
being cleaned. Soils include, but are not limited to grease, oils, waxes, metal chips, carbon
deposits, fluxes, and tars." Stripping operations will be covered under a separate rule to be
developed by 2000. EPA's Applicability Determination Index (ADI) at
httn://www.ena.gov/Comnliance/nlanning/data/air/adi.html. Control Number M960059
(7/17/1996) pertains to paint stripping operations and their applicability under Subpart T.

QUESTION: Does the Halogenated Solvent NESHAP apply only to metal cleaning?

ANSWER: No, the rule applies to all types of cleaning operations including metal, plastic, composite,
etc. The rule regulates the removal of soils and does not specifically exempt non-metal
cleaning.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

QUESTION: What is the status on Web & Wire cleaning?

ANSWER: EPA published an compliance extension for web & wire cleaning machines in the

12/11/98 Federal Register (63 FR 68398). The Federal Register notices are available for
download on the Unified Air Toxics Website
(www. ep a. gov/ttn/uatw/deagrea/halopg .html).

QUESTION: Are R&D facilities exempt from the rule?

ANSWER: No, all facilities/plants who have solvent cleaning machines as defined by the rule are
required to comply with the rule. The issue of exempting R&D facilities was raised in
the BID to the final rule, Page 2-18, commenter IV-D-21. The EPA response was:

"The EPA is required by the Act to establish a separate category covering research or
laboratory facilities, as necessary to assure the equitable treatment of such facilities.
There is nothing inherently different about research and laboratory facilities that would
justify a separate category or exemption. The proposed and final regulation for
halogenated solvent cleaning machines provide for equitable treatment of all halogenated
HAP solvent cleaning machine sources, by not exempting sources, such as the ones
described by the commenter."

Definitions

QUESTION: I've talked to several people about lip exhausts and one particular woman said that

many facilities out there are having a tough time understanding what a lip exhaust is,
that is, it isn't defined very specifically and a lot of issues have arisen from this
particular piece of equipment. Local agencies have been telling these companies that
it is in the process of being defined - do you know if that is true and if not, is there
someway to get a more specific definition or at least more criteria for what is or isn't
a lip exhaust?

ANSWER: EPA, at this time, is not planning on clarifying the definition in rulemaking. Lip exhaust is
an integral part of the machine (meaning that it is actually attached to the perimeter of
the opening of the solvent cleaning machine in the case of an open top; and for an in-line
machine, it is a stack attached to the machine that is drawing air/solvent from the inside
of the solvent cleaning machine). Ventilation systems which are not part of the solvent
cleaning machine itself and are located around or above the solvent cleaning machine
would not be considered lip exhaust. These ventilation systems could affect the work
practice requirement of windspeed of less than 50 fpm across the degreaser.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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Batch Vapor/In-Line Machines

QUESTION: A facility has two 22 square feet solvent sumps. From the two sumps the sides of

the machine extend to form a funnel like area where the vapor cleaning takes place
(the primary condensers are also located in this funnel like area). This area
measures 60 feet long and is 5 feet wide. The 1995 EPA guidance document and the
definition of solvent/air interface area in the rule says that "...for an in-line cleaning
machine, it is the total surface area of all the sumps...". But EPA also states that
"solvent/air interface means, for a vapor cleaning machine, the location of contact
between the concentrated solvent vapor layer and the air. This location of contact is
defined as the mid-line height of the primary condenser coils....".

In the first case the sources solvent/air interface area would be 44 square feet, and in the
other it would be 300 square feet. The source is looking for an EPA interpretation on
which is the right way of calculating so he can determine his potential to emit, which is
tied to the machine's solvent/air interface area, and also to determine what would be his
allowable emissions under the alternative standard (§63.464).

ANSWER: The solvent air interface area is the area where the solvent vapor are mixing with air ~
300 sq. ft.

QUESTION: My company is operating a batch vapor degreaser >1.21 m3. Our only real choice of

compliance options is Option #2 in Table 2. We can met dwell and reduced room
draft with no problem, but we have a problem meeting the freeboard refrigeration
device part. Superheated vapor is not an alternative since we do not have a closed
system. We just tested this machine and found that in the midpoint of the blanket
(said something about having a cooling jacket 8") is reading 82 F. Under
63.463(e)(2)(i), we must ensure that the chilled air blanket temperature measured at
the center of the air blanket is no greater than 30 % of the solvents boiling point. The
boiling point of the solvent is 250 F, 30% of that would be 75 F.

We would like to increase the cooling zone of the machine by using 6-9" "ropes" of
copper tubing. These secondary coils would be above the cooling jacket and would
decrease the diameter of the machine by about 1". This would still be large enough to set
his basket into the machine in accordance with the rule. This is much less expensive for
him than his other option of (I think he said) increasing the size of the machine? Does
the rule allow us to do this?

ANSWER: The rule does not stipulate how many or the configuration of the cooling coils as long as

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

the requirements in 63.463(1) through (7) are met. If modifications to the machine are
made, you must ensure that the machine still complies with all applicable requirements,
including 63.463(d)(2) (i.e., the basket or parts being cleaned do not occupy more than
50% of the solvent/air interface area or ensure that the basket/parts are introduced at a
speed of 3 fpm or less).

QUESTION:	My facility/plant uses an existing batch vapor machine which has chosen the

following options: The idling and downtime cover in 63.463(a)(l)(i), the base design
requirements in 63.463(a)(2) through (a)(7), and the idling emission limit in
63.463(b)(2)(ii). Under 63.466, do I have to monitor only those sections that indicate
compliance with the equipment or idling standards (i.e., 63.466(c) and (f)) or do I
have to monitor everything that I use on that machine even if I use a control (ie.,
superheated vapor) that is not part of this option. The reason I am asking is that in
63.466(f)(1), it refers you back to the requirements in (a)( through (e).

ANSWER: Under 63.466(f)(1), you would have to monitor any controls listed in (a) through (f). This
means that if you are using superheated vapor, comply with 63.466(2), unless you can
show that the superheated vapor does not effect your ability to meet compliance with the
idling emission limit.

Under the idling emission limit, you must meet base design requirements including,
freeboard ratio, automated parts handling, sump heat shutoff, vapor level control device,
and use of primary condenser. If 63.466 lists any of these controls, you must monitor in
accordance with that section. In your original question, the machine you described would
be monitored for (under 63.466(f)) : 63.466(a)(2) - superheated vapor; 63.466(b)(1) -
cover; 63.466(c)(1) to (c)(4) - hoist speed.

QUESTION: Section 63.463(d)(12) states "sponges, fabric, wood and paper products shall not be

cleaned". Our company currently has a metal tag system on the baskets (for production
control purposes). We are looking into a new labeling system where we would use a
paper label. The label would be on the basket when it is lowered into the solvent. Can
we do this under 63.463(d)(12)?.

ANSWER: Section 63.463(d)(12) was added to the rule to prevent the use of a product during the

cleaning process that would adsorb halogenated solvents and then later release the vapors
into the atmosphere. Sponges, paper , fabric and wood are adsorbent materials and
should not be used in the cleaning process. Even if the owner/operator has allowed the
equipment to "cease dripping" in accordance with the regulation, these adsorbent
materials would continue to release halogenated solvents into the atmosphere. A non-
adsorbent material should be used for your labeling system.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

QUESTION: I have a question regarding the monitoring procedures (§63.466) for the Alternative

Standards. Does §63.466(e) apply to the alternative standard (monitoring requirements
for the carbon absorber)?

ANSWER: No, sources complying with the Alternative Standards (§63.464) are not required to
comply with the monitoring procedures provided in §63.466.

Cold Cleaning Machines

QUESTION:	A plant uses a batch cold cleaning machine which has a tightly fitted lid that is kept

closed except when introducing or removing parts or when adding perchloroetheylene
into the tank. The plant can not meet the requirements for the 2.5 cm water layer as
described in 63.462(a)(1) and proposes to use the (a)(2) compliance option
(freeboard ratio >=0.75). The machine in question has a ventilation system present
which was installed primarily for Safety and Health reasons. The ventilation system
is kept on except when the machine is idle. Does running the ventilation system
cause me to be out of compliance with the rule?

ANSWER: Section 63.462 requires that batch cold cleaning machines meet the following options. (1)
for immersion batch cold cleaning machines, comply with either 63.462(a)(1) or (a)(2); or
(2) for a remote reservoir machine, meet 63.462(b). In your case, you have a immersion
batch cold cleaning machine and have chosen to meet (a)(2) which requires you to
employ a tightly fitting cover that is closed at all times except during parts entry and
removal and has a freeboard ratio of >= 0.75.

The rule requires that those complying with (a)(2) or (b), to also comply with work and
operational practice requirements in 63.462(c)(1) through (8). Section 63.462 does not
require, nor prohibit, the use of a ventilation system. However, under 63.462(c)(7), the
owner/operator needs to ensure that when the cover is open, the cold cleaning machine is
not exposed to drafts greater than 132 feet per minute. If your facility/plant were
operating a batch vapor or in-line cleaning machine and used a lip exhaust ventilation
system, you would be required to collect vapors thought a carbon absorber or meet an
alternative standard. Since your cleaning machine is a batch cold, however, such a
requirement does not exist.

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Test Methods

QUESTION: I have a question about the requirement to use an inclined liquid gauge in accordance with
test method 307 (idling emission standard) I have contracted various gauge
manufacturers and they do not know what this is. We are currently using a sight glass to
check the liquid level. Is there another name for this liquid gauge? Who manufacturers
it? Is this a manometer we are talking about?

ANSWER: With regard to Test Method 307, it was brought to our attention that the "inclined liquid
level indicator" referenced in the test methodology is not readily available for purchase.
EPA/state inspectors and compliance assistance providers should be aware that owners
and operators implementing Test Method 307 may be using alternative apparatus capable
of measuring the solvent level in solvent cleaning machines. (See Memorandum of
12/11/97, Reporting Dates and Test Method 207, which can be downloaded at
www.epa.gov/ttn/uatw/degrea/halopg.html).

QUESTION: How many idling emission tests must be performed to comply with §63.463(b)(l)(ii) or
§63.463(b)(2)(ii)?

ANSWER: Subpart T specifies what is required to demonstrate idling emission standard compliance
through the use of the EPA test method 307 and control device monitoring.

Reporting

QUESTION: I have a question regarding the Exceedance Report that is required by the

Halogenated Solvent NESHAP regulations. I have a client that has both existing
(pre-11/29/93) and new (post-11/29/93) cleaning machines, covered by the
NESHAP. We are presently submitting quarterly exceedance reports for the new
machines and we are trying to determine when we need to start including the existing
machines in these reports. For existing machines, 40 CFR 63.468(d) states that the
initial statement of compliance must be submitted within 150 days of Dec. 2, 1997 (by
5/2/98), but it doesn't really state when these units need to be included in exceedance
reporting. We will be submitting an exceedance report for the new machines,
covering the first three months of 1998. Do the existing machines need to be
included on this first quarter report or do we wait until after the initial statement of
compliance has been submitted?

ANSWER: See time line and OECA policy memo Dec 11, 1997 "Compliance Issues for the
Halogenated Solvent Cleaner MACT." Both are available for download at

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations.

State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

www.epa.gov/ttn/uatw/degrea/halopg. html.

QUESTION: If the compliance date is in December and the Initial Statement of Compliance is due in
May 98, do we have to submit the first annual report in Feb 98 or can we wait until 99?

ANSWER: See time line and OECA policy memo Dec 11, 1997 "Compliance Issues for the
Halogenated Solvent Cleaner MACT"

QUESTION: Section 63.468(d) requires o/o's to submit their initial statement of compliance w/in 150
days after the compliance date. Pursuant to 63.468(6), o/o's complying with the idling
emission limit standards must append a test report to their initial statement of compliance.
However (there is always a "however"), the General Provisions, 63.7(a)(iii) provides o/o's
with 180 days after the compliance date to perform the a performance test. Note,
Appendix B to Subpart T includes 63.7(a) as applicable to batch vapor and in-line
machines

ANSWER: Sources must submit their initial statement of compliance within 150 days after the
compliance date pursuant to §63.468(d).

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