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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:
The proposed revised standards had originally appeared in the August 17, 2006 Federal Register;

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:
“ 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”
We have bookmarked the link and check it on a regular basis. You might want to do the same.

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