Chlorinated Solvents: Nation-wide EPA NESHAP Change to Appear
by December 15, 2006
Barbara Kanegsberg
BFK Solutions LLC
If you use certain chlorinated solvents for cleaning parts in liquid/vapor
degreasers, wherever you are in the United States, you may be impacted
by an impending Federal regulation.
This is not a solvent ban; this is not a chlorinated solvent ban. However,
if you use chlorinated solvents that are covered by the Halogenated Solvents
NESHAP it may mean that you will have to modify process equipment and/or
add process controls.
A final rule amending the current EPA Halogenated Solvents NESHAP (National Emission Standard for Hazardous Air Pollutants) is due no later than December 15, 2006. The goal of the rule is to minimize residual air emissions risks to the surrounding community.
The original NESHAP includes air emissions from certain chlorinated solvents
that are used in vapor degreasers, notably Perchloroethylene, trichloroethylene,
and Methylene chloride. The new proposed regulation, while keeping
the original 1994 NESHAP in place, assumes that all manufacturers
are in
compliance with
the 1994 NESHAP and then addresses residual risks to surrounding neighborhoods.
While this will be a nation-wide regulation, California EPA risk analysis
is included in the assessment. The proposed rule has been published
in the Federal Register. The public was invited to comment; and the
comment
period
has already ended. There is a Federal court order requiring that the
regulation be signed by December 15, 2006.
If you use chlorinated NESHAP solvents, the potential impact on your
manufacturing operations is related to the amount of solvent emitted
and to the identity
of the solvent (i.e. the specific toxicological issues). This is
new in that previously HAPS (Hazardous Air Pollutants) used in vapor
degreasing
were
treated equivalently under the NESHAP. However, all HAPS are not
created equal. The proposed regulation considers risks associated
with each
specific chemical. Those of us familiar with California regulations
are familiar
with the concept.
The proposed rule calls out emissions caps for facilities exceeding
certain levels of air emissions. Two options were proposed: one
is more stringent.
While the final rule has not yet been published, it is likely to
impel process modifications and controls for some manufacturers.
The proposed
rule does
not call out specifics of controls to be used. The proposed rule
does not distinguish allowable emissions levels based on proximity
to “sensitive
receptors” (eg. schools). However, the final rule may change, based
on EPA assessment of comments that were received.
Whether you do industrial cleaning or critical cleaning, this scheduled
NESHAP change may signal a really good point to reassess cleaning
process performance
and to schedule capital outlays for equipment modification, replacement,
and automation. It may be a good opportunity to take a dispassionate
look at the entire cleaning and manufacturing process. With careful
planning, you can minimize solvent emissions, save money, and
end up with a high-performance
cleaning process.
EPA contact:
H. Lynn Dail
U.S. EPA
(919) 541-2363
dail.lynn@epa.gov
Federal Register Notice:
71 FR 38147 (July 5, 2006)
http://www.epa.gov/fedrgstr/EPA-AIR/2006/August/Day-17/a6927.htm
EPA website:
www.epa.gov/epahome/dockets.htm
Compliance Tools for Halogenated Solvent Cleaning NESHAP
http://www.afcee.brooks.af.mil/products/air/federal/toolsindex/tools/category_tools.asp?sg_id=43
