NESHAP II: You should have said something
Barbara Kanegsberg, BFK Solutions

In the final “National Air Emission Standards for Hazardous Air Halogenated Solvent Cleaning,” there are facility-wide emissions limits. Are you subject to these limits? Read on for more information, but I’ll give you a hint: those who spoke up were more likely to be exempt.

The new rule took effect on May 3, 2007. There are facility-wide emissions limits for Perchloroethylene (PCE), trichloroethylene (TCE), and Methylene chloride (MC). I have converted from kg/year to gallons/year, because most of you purchase solvent in 55-gallon drums.

What applications have emissions limits?
General cleaning (gal/year)
783 PCE
2550 TCE
12000 MC
Military
1300 PCE
4250 TCE
20000 MC

What applications are exempt from the emissions limits?
Narrow tube manufacturing
Continuous web cleaning
Aerospace

The new rule builds on the 1994 NESHAP, but some groups have more process monitoring and recordkeeping requirements. We did tell you about the proposed NESHAP in the Fall, 2006 issue of “Clean Source;” and we indicated an additional opportunity for input to the EPA in the January, 2007 issue of “Green Files,” the newsletter for SQRC, our non-profit organization. You can check out the articles in our BFK Solutions archives and in the “Green Files” archives.
http://bfksolutions.com/Newsletter%20Archives/V3-Issue%204/Chlorinated%20Solvents.html

http://www.sqrc.org/Newsletter%20Archive/Volume%202,%201/Update%20Neshap.html

Will this rule impact your business?
Maybe, especially if you fall under the ubiquitous “general” category. For example, assuming a 22 day work-month (5 days per week), the limits for PCE would be just under 3 gallons per day ( 2.97 gallons ). This means your lovable old degreaser might not be so lovable any more. It may be time to get to that deferred maintenance, or maybe even to upgrade.

It helped to speak up
Some groups that provided comment to the EPA effectively received regulatory relief. In the final rule, there is an indication that many comments were received from narrow tube manufacturing, continuous web cleaning, and aerospace. Apparently only a single military installation commented.

Of course, in an earlier proposal, the EPA had indicated that they were restricting their requests for comments only to the areas that ultimately received exemption. It is understandable that very large facilities might have problems with staying under ca. 3 gal/day of PCE. However, such groups also have greater resources for process control; and several control options and emissions options were put forth.

In such situations, if I were a manufacturer, my inclination would be to comment to the EPA even if the EPA request for comments excluded my application. This is especially true if it appeared that my manufacturing facility had pressing process requirements and if my manufacturing facility would be adversely impacted relative to other groups.

The new NESHAP regulation can be found at http://www.epa.gov/fedrgstr/EPA-AIR/2007/May/Day-03/a7668.htm