Update to Halogenated Solvents NESHAP
Barbara Kanegsberg, SQRC
Impending changes to the 1994 Halogenated Solvents NESHAP (National Emission
Standard for Hazardous Air Pollutants) will limit the amount of releases
of certain chlorinated solvents that are still used in cleaning processes.
The
solvents of interest are Perchloroethylene (PCE), Methylene chloride (MC),
and trichloroethylene (TCE). The changes are likely to favorably impact
air quality in communities near manufacturing processes. The changes are
also likely to affect the way
manufacturers do critical cleaning and other manufacturing processes.
These nation-wide changes have a California flair. The Federal assessments
include California EPA risk analysis so that rather than treating all
the hazardous air pollutants (HAPS) uniformally, the impact of PCE,
MC, and
TCE are considered
individually relative to the specific risks to communities. Some groups
commented to the EPA that airless (vacuum) degreasing systems would have
to be used to
achieve the lower emission levels; especially in Southern California,
such systems are a must for manufacturers using chlorinated solvents.
The original public comment period passed, but there is an unexpected
additional narrow window of opportunity to comment to the EPA, ending
January 29,
2007.
We discussed the impending NESHAP in the Fall, 2006, “Clean Source
Newsletter:
http://www.bfksolutions.com/Newsletter/Chlorinated%20Solvents.html
The proposed revised standards had originally appeared in the August
17, 2006 Federal Register;
http://www.epa.gov/fedrgstr/EPA-AIR/2006/August/Day-17/
The public
comments period had come and gone; and, based on information available
in October,
the final rule was certain to have appeared in December 15, 2006.
However, on December
14th instead of a rule, the EPA published a second notice. You can
view this more recent Federal Register notice online:
http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-14/a21296.htm
“ National Air Emission standards for Hazardous Air Pollutants, Halogenated
Solvent Cleaning: Notice of Data Availability”
Despite the title, the notification is actually an additional limited
public comments period, ending January 29, 2007.
The EPA wants comments in certain specified areas only:
• narrow tube processing
• continuous web cleaning
• aerospace manufacturing and maintenance
• large scale military vehicle maintenance facilities
• facilities requiring multiple vapor degreasers
The EPA wants to hear only about issues involving:
• meeting the new emissions limits
• cost impacts
• time frame required
Despite these restrictions, we would suggest that if you have any relevant
and urgent comments germane to any of these areas, and
if you would like the EPA know about, this is your opportunity.
It can be difficult to keep tabs
on impending regulatory changes. However, there is a convenient link to “Federal
Register Environmental Documents”
http://www.epa.gov/fedrgstr/EPA-AIR/index.html
We have bookmarked the link and check it on a regular basis.
You might want to do the same.