Federal Air Pollution Standards

Transcription

1 Solvent State and national air pollution rules may affect you andyour business. Some of these rules are new, some have been around for awhile. and some have recently been revised. These new and revised regulations will change the way you clean parts. The location ofyour business, the size ofyour operation, and the types of solvents used will determine how this law affects you. Smaller businesses never before regulated by state and federal agencies, will need to comply with these laws. The Small Business Clean Air Assistance Program exists to help smaller companies undertand and comply with Clean Air Act rules and regulations. This program, a joint effort between the Wisconsin Departments of Development and Natural Resources. provides businesses with a general understanding of what the laws require through publications such as this "Overview'! Federal Air Pollution Standards On December 2,1994, the U.S. safety data sheet (MSDS) or ask Notification Environmental Protection Agency your supplier. Mineral spirits Reports. Existing (EPA) issued a MCT (Maximum and stoddard solvent, two sources (affected Achievable Control Technology) commonly used cleaning facilities with solvent cleaning standard, regulating hazardous solvents, are not affected by this machines constructed or air pollutant emissions generated standard. reconstructed before or on from the use of halogenated November 29,1993), must file solvent cleaning machines. The How Does MY Business this report by August 29, goal of the standard is to reduce comply with ni Standard? New sources (affected facilities the amount of harmful pollutants The federal standard offers with solvent cleaning machines emitted into the atmosphere several compliance options. constructed or reconstructed when solvents evaporate. after November 29,1993), Your business may choose to: should have filed this by January Does This Federal Standard 31,1995, or before the. Switch to a non-chlorinated, Affect My Business? water-based or semi-water based construction or reconstruction Businesses that use any of the solvent. This option will exempt begins. following halogenated your facility from this federal compounds, or a combination of standard. So it's in your best Given the limited information that has been available about the them, in concentrations greater interest to investigate this option. federal standard, a new source than 5% by weight as a cleaning or drying agent are affected by. Comply with one ofthe that missed the January deadline the federal standard: equipment standards; will not be penalized if it files the Initial Notification Report in early -~ Methylene Chloride, Trichloro-. Show that your cleaning Further details about this ethylene, Carbon Tetrachloride, machine meets the appropriate MACT standard and the Initial 1,1,1 Trichioroethane, Chloro- idling emission limit; or Notification Report are available - form or Perchloroethylene by checking the appropriate. Meet the appropriate boxes and returning the order To determine if the solvent you use contains any of these chemicals, refer to the material alternative emission limit. Affected facilities must file Initial form on page seven to the Small Business Clean Air Assistance Program. 1

2 %ah'business Uean Airhsitance hgnm Wisconsin's regulation to control air pollution from solvent metal cleaning operations (ch. NR 423, Adm Code), was established in This regulation was recently revised. Does This State Standard Affect My Business? Throughout the state, this rule applies to the following types of solvent metal cleaning operations:. Cold Cleaners (parts cleaners). Open Top (batch) Vapor Cleaners. Conveyorized Vapor Cleaners. Conveyorized Non-Vapor Cleaners In the nine-county ozone nonattainment area, Process tine Wipe Cleaning Operations are also addressed. This nonattainment area includes the nine counties of: Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington and Waukesha. Wsconsh Air Pollution Standards...*****e ****~~***** Solvent metal cleaning operations throughout the state are affected by this standard. However, those using only cleaning solvents with a VOC (volatile organic compound) content of 2.0 % or less by volume are exempt. lf you use photochemically unreactive solvents (Le. methylene chloride or 1,1,1 trichloroethane) this rule does not apply to you. Whether you are exempt or not, you must still comply with the general reporting and recordkeeping requirements. How Does My Business Comply With This Standard? lf your facility is not in the ozone nonattainment area, then your cleaner may be exempt from NR 423 if it is: a cold cleaner with a throughput less than 1.5 gallons of solvent per day, or an open top vapor cleaner or conveyorized cleaner emitting less than 15 pounds of VOC per day. lf you do not meet these emission-based exemptions, you may be exempt from the pollution control device requirements of ch. NR 423 if your: cold cleaner has an open area less than 1.I sq. ft., open top vapor cleaner has an open area less than 10.8 sq. ft. or conveyorized cleaner has an open area less than 21.6 sq. ft. 2 If your facility is located in the ozone nonattainment area, your cleaner may be exempt from the control device requirements if it is: a cold cleaner with a throughput less than 1.5 gallons of solvent per day and an open area less than 1.I sq. ft.; an open top vapor cleaner emitting less than 15 pounds of VOC per day and having an open area less than 10.8 sq. ft.; a conveyorized cleaner emitting less than 15 pounds of VOC per day and having an open area less than 21.6 sq. ft ; or a wipe-cleaning operation emitting less than 15 Ibs of VOC per day. The state air pollution regulation for solvent metal cleaning affects businesses throughout Wisconsin. However, the revisions to the law apply onj to operations in the ozone nonattainment area. Depending on how the original NR 423 regulations affected you, businesses in the ozone nonattainment area must comply with revisions to the regulation by one of the following dates: May 15,1995, Sep tember 15,1995 or May 15, If your degreasing operation is located outside of the ozone nonattainment area, then the requirements of this rule have not changed for you and you should already be in compliance with the regulation. (continued on page three)

3 If you re not, talk with your DNR inspector to arrange a compliance schedule or call the Small Business Clean Air Assistance Program at (608) or 14WO-HELP-BUSiness. which coordinates pollution prevention activities. Case studies highlighting companies using pollution prevention alternatives are available from the office by calling (608) A detailed summary of the rule is available in the document Facts About: Wisconsin Air Pollution Regulations Affecting Solvent Metal Cleaning. To order that document, please see page seven. Pollution Prevention ~ a a ~ ~ m ~ ~ o o o o o o o e o o m m m o ~ e ~ m ~ e o o The University of Wisconsin-Extension s Solid and Hazardous Waste Education Center offers technical experts, free of charge, to help you choose an appropriate pollution prevention option. To contact a pollution prevention specialist, call (608) or (414) Pollution Prevention reduces the amount of pollutants entering the environment by using alternative materials; changing processes; or increasing the efficiency of current processes. By using pollution prevention alternatives, you may save your business money and avoid environmental regulations. Ways Pollution Prevention Benefits Your Business:. Reduces costs of waste disposal, raw materials and insurance premiums;. Reduces costs of complying with environmental regulations;. Increases efficiency and competitiveness;. Improves product quality and workplace conditions;. Reduces regulatory burdens such as record keeping and reporting and * Decreases long-term liability. Solvent Degreasing Pollution Prevention Altematives. Control emissions from solvent parts cleaning.. Use less toxic or less volatile cleaning solvents.. Switch to citrus-based, water-based or semiwater-based cleaning solvents.. Change to a blastcleaning or absorbentcleaning method. The Department of Natural Resources houses a non-regulatory office of Pollution Prevention, Waste water ReLuhtions ~ O O b b b O ~ O ~ O O...OO...OO. O ~ ~ ~ O Facilities that substitute water-based cleaners for degreasing solvents will need to properly dispose of the spent cleaning baths and rinses. If you discharge to a municipal sewer system, the discharge must comply with the wastewater pretreatment requirements found in NR 211, WI Adm. Code, local Sewer Use Ordinances and any applicable categorical standards. Contact your DNR District Pretreatment Coordinator and your local sewage treatment plant for specific requirements. To find the DNR district office nearest you, see page seven. If a facility is not connected to a municipal sewer system, another disposal method is required. Wastewater may not be discharged to a soil absorption (septic) system, storm sewer, drainage ditch or surface water unless you have obtained a Wisconsin Pollutant Discharge Elimination Permit (WPDES). It may not be practical to obtain a permit for small volumes of water, so contact a DNR Area Wastewater Engineer for further information. For more information on wastewater regulations, contact the DNR s Bureau of Wastewater Management at (608) ~ - 3

4 If you re involved in cleaning parts with solvent material, you may be creating some form of hazardous waste regulated by the DNR and the EPA. Examples of hazardous wastes can indude: contaminated or spent (used-up) solvents from process applications; industrial refuse such as rags or filter cartridges; and diluted wastewater containing low concentrations of solvent and residues. When determining if your business generates hazardous waste, you should become familiar with the terms listed hazardous waste and characteristic hazardous waste. Many of the materials used in solvent degreasing operations are considered listed hazardous wastes because they are listed in the state regulations, Ch. NR , WI Adm. Code. (he specific tables listing hazardous waste are located in NR ) Other wastes may be characteristic hazardous waste because the material exhibits characteristics of ignitabilii, corrosmty, reactivity or toxic i (See NR ). To determine if your waste is hazardous, check information from suppliers, look at container labels, read your Material Safety Data Sheets (MSDS) or have a sample of your waste analyzed. - The Once you ve figured out if your waste is hazardous, you need to figure out what kind of hazardous waste generator you are. There are three kinds of generator classifications in Wisconsin: Very Small Quantity Generators (VSQC) Small Quantity Large Quantity Generators (LQG) Under federal and state laws, all hazardous waste generators will have to comply with some regulations, depending on classification. To make a hazardous waste determination or generator classification, see the checklist order form on page seven of this publication. DNR offers a free handbook, Managing Your Hazardous Wastes: A Guidebook for Wsconsin Small Quantip Generators. The handbook is also available on the checklist order form. If you are interested in minimizing your hazardous waste, take advantage of the over 150 publications offered through DNR s Pollution Prevention Clearinghouse. The clearinghouse has factsheets, case studies, equipment supplier lists and handbooks to help you identify cleaning alternatives. To request the clearinghouse order form, check theappropriate box on page seven. For hazardous waste management information, call your DNR district hazardous waste specialist. For hazardous waste minimization information call (608)

5 Do I Need an Air Operating Permit? 0 ~ ~ 0 0 ~ ~ 0 ~ 0 0 ~ 0 0 ~ ~ 0 ~ ~ ~ ~ ~ Many businesses with solvent cleaning operations are required to obtain an Air Operating Permit. This permit is a legal document containing information about your business air pollution emissions and how those emissions are monitored and controlled. Businesses that are considered major sources must submit a permit application to the DNR between May 1,1994 and October 1,1995 based on h at county the business is located. Major sources are defined as any source that has the potential to emit: 1. More than 10 tons per year of any hazardous air pollutant; or 2. More than 25 tons per year of any combination of hazardous air pollutants; or 3. More than 100 tons per year of any combination of air contaminants; or 4. More than 25 tons per year of volatile organic compounds (VOCs) if your business is located in a severe ozone nonattainment area. (i.e. Kenosha, Milwaukee, Ozaukee, Racine, Washington or Waukesha County.) 5. More than 50 tons per year of VOC s if your business is located in a moderate ozone nonattainment area. (i.e. Kewaunee, Manitowoc or Sheboygan County.) Potential to emit is the total amount of all air pollutants your business would emit if operating at maximum production capacity, 24 hours a day 365 days a year. Businesses that are not major sources, but are affected by the MA0 Standard described on page one will need to file a permit application with the DNR between July 1,1997 and December 1,1998, based on the county in which the business is located. General Operating Permit A General Operating Permit is being developed to ease the permitting process for solvent cleaning operations. To obtain a copy of the general permit application form, please contact either your local district DNR office, or the central office Bureau of Air Management at (608) For more information about Air Operating Permits, request Air Operating Petmits for Small Businesses from the checklist order form on page seven. 5

6 Small Business Clean Air What Does All This Mean to Your Business? The Small Business Clear Air Assistance Program wants to make it as easy as possible for solvent parts cleaning operators to get the technical assistance and compliance information they need. Ozone Depletin- Substances..~mb...m.O me.. *.*.b*. Chlorinated compounds used in some degreasing solvents such as methyl chloroform, carbon tetrachloride and chlorofluorcarbon-i 13, deplete the stratospheric ozone layer (the atmosphere layer about 9-31 miles above earth which filters out harmful ultraviolet rays). Under an international agreement, these substances will not be produced after December 31,1995. This agreement will affect other ozone-depleting substances, such as those used in refrigerants, fire suppressants, foam-blowing agents and propellants. Commonly used solvents that do not deplete the ozone will still be available, including perchloroethylene, methylene chloride and trichloroethylene. If your business is independently owned and operates with fewer than 100 employees, you may qualify for free assistance. Whether you re looking for more information, a clearer explanation or have permitting frustrations, contact one of the Small Business Clean Air Assistance representatives. Give Us a Call. We re Here to Help! Pam Christenson Small Business Clean Air Assistance Program Department of Development or HELP-Business Small Business Liasion Department of Natural Resources The EPA evaluates and approves alternative solvents and degreasing equipment that can be substituted for the ozone-depleting solvents. Lists of these approved chemicals and methods are available through the EPA s Significant New Alternative Policy. Manuals are available from EPA s STRATOSPHERIC OZONE HOTLINE at

7 in this overview, you may order the following materials free of charge. Order documents by checking them on the list below. You can mail, call, or fax your requests to: Small Business Clean Air Assistance Program P.O. Box 7970 Madison, WI, phone (608) or fax (608) Facts About: MACT Standard for Halogentated Solvent Cleaning Machines Lake Michigan Distrie 1125 North Military Ave Green Bay, W (414) Westem District 404 South Barstow Eau Claire, W (715) North Central District 107 Sutliff Avenue Rhinelander, W Initial Notification Report for Halogenated Solvent Cleaning Machines (715) Clean Air Compliance for Solvent Degreasers Guidebook [7 Facts About: Wisconsin Air Pollution Regulations Affecting Solvent Metal Cleaning owhat is Hazardous Waste? (SW-106) Hazardous Waste Determination (SW-204) 0 Managing Your Hazardous Waste: A Guide for W Small Quantity Generators (SW-071) 0 Pollution Prevention Information Clearinghouse Publications Orderform ( ) Southern District 2801 Coho Street Madison, W (608) Northwest District Highway 70 & 1st Street P. 0. Box 309 Spooner,W (715) Southeast District 2300 N. Martin Luther King Jr. Drive Milwaukee, W (414) Air Operating Permits for Small Businesses hisconsin s Small Business Clean Air Assistance Program nthe Cost of Clean Air: Financial Assistance to Small Businesses Your Name: Company Address: Cii/State/Zip: Type of Business:

8 I I Small Business Clean Air Assistance Program P.O. Box 7970 Madison, WI If Your Business Does Any Kind of Cleaning With Solven ts...this Overview is For YOU!!! - What's Inside U L Federal and State Laws May Affect the Way Your Business Cleans Pa rts... Pollution Prevention Techniques for Solvent Parts CI ean in g...wastewater and Hazardous Waste Information... Do You Need an Air Permit?... mere Small Businesses Can Go For Help... and much more!