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Air Quality Regulations Affecting Dry Cleaners, Metal Finishers, and Printers
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Summary of Regulations Controlling Perchloroethylene Emissions From Dry
Cleaners
The Clean Air Act Amendments of 1990 direct the US Environmental
Protection Agency (EPA) to regulate emissions of 189 toxic chemicals,
including perchloroethylene (also known as perc, PCE, or tetrachloroethene).
In response, the EPA issued
national regulations to control air emissions of perc from dry cleaners.
These regulations appeared in the 22 September 1993 edition of the
Federal Register [volume 58, beginning on page 49354].
The regulations require that each owner or operator of a dry cleaning
facility that uses perc as a cleaning solvent submit two reports to the
USEPA: an Initial Report and a Compliance Report. The initial reporting
information was due to the EPA 18 June 1994. The compliance
certifications were due to the USEPA by 18 June 1994 for pollution
prevention requirements and by 22 October 1996 if control equipment is
required.
Required Pollution Prevention
The aformentioned pollution prevention steps involve:
- Inspecting all dry ceaning equipment at least every other week for
leaks that are obvious from sight, smell, or touch. All leaks must be
repaired.
- Keeping a log of the leak detection and repair program results.
- Following good house keeping practices inclusive of: keeping all perc
and wastes containing perc in covered containers with no leaks; draining
cartridge filters in closed containers; and keeping the machine doors
shut when clothing is not being transferred.
- Operating and maintaining all dry cleaning equipment according to the
manufacturers' instructions.
- Keeping a log of the amount of perc purchased for the past 12 months.
Control Requirements
To better understand the control requirements set forth in the National
Emission Standards for Hazardous Air Pollutants (NESHAP) for PCE, it is
important to understand the following definitions:
Existing Dry Cleaning Machine: a machine installed
before 9 December 1991
New Dry Cleaning Machine: machine installed on or after
9 December 1991
For "Existing" machines, the following control
requirements apply:
| Type of Machine |
Purchase Amounts
of PCE (Perc) (gallons per year) |
"Small" or
"Large" Facility |
Required Control |
Transfer machines only |
200 or more |
Large |
Refrigerated
condensers or existing carbon adsorber if in place before 9/22/93 |
Transfer machines only |
over 1,800 |
Large |
Must install a room enclosure
around each transfer machine and vent room
enclosure to a carbon
adsorber |
Dry-to-dry machines only |
140 or
more |
Large |
Refrigerated
condensers or existing carbon adsorber if in place before 9/22/93 |
Combination of dry-to-dry and transfer
machines |
140 or
more |
Large |
Refrigerated
condensers or existing carbon adsorber if in place before 9/22/93 |
Transfer machines only |
Less than
200 |
Small |
Do not need to
install perc vapor recovery systems |
Dry-to-dry machines only |
Less than
140 |
Small |
Do not need to
install perc vapor recovery systems |
For "New" dry cleaning machines, the following control criteria
apply:
Any dry cleaning facility that installs a "new" machine must install a
dry-to-dry machine with a refrigerated condenser. In addition, facilities
that purchase over 1800 gallons of perc annually are required to use a
carbon adsorber with a refrigerated condenser on the new dry-to-dry
machine. "New" transfer machines that use perc cannot be installed.
Additional Reporting and Compliance Requirements
For existing machines, perc vapor recovery systems (refrigerated
condensers and carbon adsorbers) are not required until 22 September
1996. All new machines must be equipped with these systems upon start-up.
Refrigerated condensers must cool the perc vapor in the machine down to
45 degrees Fahrenheit or less at the end of the dry cleaning cycle. Any
carbon adsorber must not release more than 100 parts per million of perc
out of the stack. Facilities must submit a report to the EPA stating how
it is complying with the regulations.
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Summary of NJ Air Quality Regulations Affecting Surface Coating (Spray Painting) and Graphic Arts Operations
* These regulations can be found at NJAC 7:27-16 and are downloadable from
the New Jersey Department of Environmental Protection's BBS which can be
"modemed" into at (609)-292-2006. The BBS is a DOS-based, menu-driven
service which provides electronic access to a variety of NJDEP documents
including regulations.
If your facility incorporates a surface coating or graphic arts operation
and if the total surface coating formulations containing VOC are applied
at rates in excess of one half gallon per hour and two and one half
gallons per day then:
- You should check to make sure that the VOC content of any surface coating
formulation as applied does not exceed the applicable VOC content
specified in tables 7A, 7B, 7C, or 7D of NJAC 7:27-16.7.
- In addition, you may have to concern yourself with the following
control requirements:
a) the apparatus should prevent no less than 90% by weight of the VOC
content in the surface coating formulation as applied each hour from
being discharged directly or indirectly into the outdoor atosphere, or
b) if a graphic arts operation cannot meet the control criteria set forth
in table 7D of NJAC 7:27-16.7, then they should meet the following
collection and control requirements:
| Type of Printing
Operation |
Control
|
Volumetric Collection Efficiency (Hourly Basis)
|
Volumetric VOC Removal/Destruction Efficiency
(Hourly Basis) |
| Rotogravure and gravure |
Thermal oxidizer |
75 |
95 |
| Carbon adsorption
system |
75 |
90 |
| Flexographic |
Thermal
oxidizer |
70 |
95 |
| Carbon adsorption
system |
70 |
90 |
| Fabric | Thermal
oxidizer |
70 |
95 |
| Carbon adsorption
system |
70 |
90 |
| Screen |
Thermal
oxidizer |
70 |
95 |
| Carbon adsorption
system |
70 |
90 |
In addition, if your operation is subject to these operations, you should
maintain:
- records of the VOC content of each surface coating formulation (minus
water) as applied, in pounds of VOC per gallon of coating or kg of VOC
per liter of coating;
- the percent weight of additional organic substances;
- and the daily volume of each surface coating formulation applied.
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Metal Finishers: EPA's Chromium Emissions MACT Standard
Summary
The EPA's Office of Air Quality Planning and Standards established
chromium emission limits in the National Emission Standards for Chromium
Emissions from Hard and Decorative Electroplating and Anodizing Tanks,
promulgated in 1995. The Standard includes two designations for hard
chromium electroplating facilities, based on the maximum cumulative
potential rectifier capacity and when the electroplating tanks were
installed. A facility is desgnated as "large" if the rectifier capacity
for all hard chromium electroplating tanks equals or is greater than 60
million ampere-hours per year. A "small" facility is one where the
rectifier capacity is less than 60 million ampere-hours per year. The
electroplating tanks in a facility can be "new" or "existing" . A "new"
tank is one installed or reconstructed after December 16, 1993. An
"existing" tank is one installed on or before December 16, 1993. The
deadline for meeting the Standard is January 1997. Hard chrome
electroplating shops must report their source outlet chromum emissions
either on a total (hexavallent + trivalent) or hexavalent basis. The
emission limits are:
| "Small"
Facility | "Large" Facility |
| All existing tanks: | 0.03 milligrams/dry
standard cubic meter |
0.015 milligrams/dry standard cubic
meter |
| All new tanks: |
0.015 milligrams/dry
standard cubic meter |
0.015 milligrams/dry standard cubic
meter |
For more detailed information on EPA's MACT Standard, check the
Wednesday, 25 January 1995 Federal Register for the National Emission
Standards for Chromium Emissions From Hard and Decorative Chromium
Electroplating and Chromium Anodizing Tanks. You can view the Federal
Register on-line at the
US
EPA's web site.
In addition there is a document entitled "Hard Chrome Pollution
Prevention Demonstration Project, Interim Report," prepared by the U.S.
Environmental Protection Agency in cooperation with The National
Institute of Standards and Technology available at the
National Metal
Finishing Resource Center's Web Site. The purpose of this
document is to assist hard chrome metal finishing operators
cost-efficiently comply with, or do better than, EPA's Chromium Emission
MACT Standard. Of particular interest is the fact that it provides
information regarding the efficiencies of pollution control/pollution
prevention technologies including:
- Blade-type mist eliminators
- Packed-bed scrubbers
- Mesh-pad mist eliminators
- Polyballs
- Chemical mist suppressants
It also compares the effectiveness of EPA Sampling Methods 306 and 306A.
These sampling methods are described in detail in the Wednesday, 25
January 1995 Federal Register on pages 4979-4993.
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