January 1998 Number 34 Acetone Regulations and Pollution Prevention: What You Should Know. Considerations for Use

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1 January 1998 Number 34 Acetone Regulations and Pollution Prevention: Wat You Sould Know Altoug manufacturers in Oio will no longer be required to submit a TRI Form R for acetone, you sould evaluate acetone use closely since it is igly flammable and remains a regulated substance in oter programs. Considerations for Use Te greatest danger regarding acetone use is tat it poses a serious fire azard. Altoug acetone is an excellent solvent and is relatively non- toxic, it is extremely flammable. It as a flas point of -18 o C (0 o F). If andled improperly, acetone may be a dangerous fire risk. Healt 3 Flammability 1 0 Special Reactivity National Fire Protection Association Hazard Rating Regulatory Canges Under te Clean Air Act, te United States Environmental Protection Agency (U.S. EPA) recently determined tat acetone as negligible groundlevel ozone-forming properties and exempted it from some air pollution regulations. Oio EPA is considering similar canges in state air pollution rules. Also, U.S. EPA removed acetone from te Toxics Release Inventory (TRI), te database for reporting toxic cemical uses, releases, and transfers from certain manufacturing facilities. TRI reporting is no longer required for acetone. Due to tese regulatory canges, acetone as emerged as an attractive alternative to oter, more toxic cemicals. Industries are increasingly using or considering te use of acetone as a substitute for azardous air pollutants and ozone-depleting substances listed in te Clean Air Act Amendments of Acetone is listed in te U.S. EPA s SNAP (Significant New Alternatives Program) as an acceptable substitute to ozone depleting compounds for several uses including metal, electronics and precision cleaning applications. Be aware, owever, tat using acetone requires important safety precautions. It also remains a regulated substance in oter programs. Tis paper contains 100% post-consumer recycled fiber and was printed using soy-based inks Office of Pollution Prevention, Oio Environmental Protection Agency P.O. Box 1049, Columbus, Oio, , (614)

2 Some Regulations and Guidelines Affecting Acetone Use Air Requirements Acetone is not a azardous air pollutant (HAP) under te federal Clean Air Act Amendments of In addition, acetone is not subject to te Risk Management Plan (RMP) requirements under section 112(r) pertaining to te prevention of accidental releases. U.S. EPA as also granted acetone VOC-exempt status. In Oio, te Oio EPA Division of Air Pollution Control (DAPC) plans to exempt acetone from VOC classification. Under ORC (H)(4), acetone remains an organic compound (OC) subject to annual air pollution control fees. For information on air pollution regulations contact te Oio EPA, Division of Air Pollution Control, Engineering Section, at 614/ Toxic Release Inventory (TRI) Under te Emergency Planning and Community Rigtto-Know Act (EPCRA) 313 and capter 3751 of te Oio Revised Code (ORC), acetone is no longer TRI-reportable. For TRI information, contact te Oio EPA, TRI program tecnical staff, at 614/ Clean Water Act (CWA) Acetone is not a priority pollutant under te federal CWA, but its discarge into wastewater would still need to be addressed on a case-by-case basis. Local sewer autorities may also ave regulations affecting discarge. For information on permitting, call te Oio EPA, Division of Surface Water, Industrial Permit Section, at 614/ Spills Under Compreensive Environmental Response, Compensation, and Liability Act (CERCLA), section 103(a), you must report acetone spills of 5,000 pounds or more to U.S. EPA. Under EPCRA (40 CFR, Part 355) and ORC , you must report acetone spills of 5,000 pounds or more to Oio EPA. For more information, contact te Division of Emergency and Remedial Response, at 800/ (Oio only) or 614/ Carcinogenicity Acetone is not regulated as a known or suspect carcinogen based on researc conducted by te Te National Toxicology Program (NTP). Resource Conservation and Recovery Act (RCRA) Facilities must comply wit RCRA regulations. Te spent or unused acetone tat a facility generates or discards may be a azardous waste in Oio. For RCRA information contact te Oio EPA, Division of Hazardous Waste Management, RCRA Tecnical Assistance Unit, at 614/ Occupational Safety and Healt Administration (OSHA) OSHA as set a timeweigted average of 1,000 ppm in workplace air for an 8-our workday over a 40-our workweek. Personal protective equipment may be necessary wen andling. In addition, acetone is subject to OSHA s Hazard Communication Standard (29 CFR ). Requirements of tis standard include tat employers must provide information (including Material Safety Data Seets or MSDS) to teir workers on te azardous cemicals in te workplace. For more information call OSHA, Columbus, at 614/

3 Some Regulations and Guidelines Affecting Acetone Use Storage Under EPCRA (40 CFR, Part 370) and ORC , if you are storing, on any day of te year, 10,000 pounds or more of acetone, you must report tis information to your local fire department, local emergency planning committee (LEPC), and state emergency response commission (SERC in Oio, c/o Oio EPA). For more information, contact te Division of Emergency and Remedial Response, Cemical Emergency Prevention Unit at 614/ National Fire Protection Association (NFPA) NFPA as rated acetone as an NFPA 704 level 3 flammability azard. State building codes and fire codes are based on NFPA guidelines. Since tese codes vary according to location, it is important to contact your local governing bodies for information relevant to your area. For more information call te NFPA, Quincy, MA, at 800/ Wat Are Your Options? Public Utilities Commission of Oio (PUCO) In Oio, te PUCO regulates sipments of acetone as a azard level 3 (flammable) substance, and transport of te cemical requires sipping papers. For more information call te PUCO Transportation Department, Columbus, at 614/ Alternative solvents Oio EPA s Office of Pollution Prevention (OPP) encourages facilities to first consider canges tat will eliminate te need for cleaning, suc as process canges, equipment modifications, material substitutions, or product redesigns or reformulations. Once cleaning requirements ave been minimized, facilities sould consider using a less toxic material or cleaning metod for eac specific cleaning application. Before converting to an alternative solvent, study te product s Material Safety Data Seet (MSDS) wic provides information about pysical proper- ties, safety precautions, and waste disposal. Carefully evaluate te product to ensure tat its use complies wit environmental and oter regulations. Just as acetone as emerged as an attractive alternative to oter more toxic cemicals, vendors are formulating new products tat may prove more effective tan acetone and safer to use. Source reduction and recycling Te most cost-effective and environmentally acceptable metod of addressing te azards of acetone is source reduction avoiding use and generation from te outset. Source reduction tecniques sould be investigated before examining te feasibility of recycling spent acetone. As a second coice, recycling acetone can reduce disposal and air emission fees, reduce te amount of purcased virgin acetone, and save money. Oio EPA encourages tose interested in acetone recycling to focus on te ability of te solvent recycling process to meet regulatory compliance and to prevent pollution. 3

4 Case Studies Lantz Lenses A manufacturer of eyeglass lenses in St. Cloud, Minnesota, Lantz Lenses used acetone to remove abrasive pads from lens-grinding tools. In 1993, Lantz Lenses purcased 1,050 pounds of acetone and generated approximately 2,300 pounds of acetone contaminated waste and 920 pounds of acetone emissions. After examining teir process, Lantz Lenses determined tat te abrasive pads could be removed by manual scraping alone (at no increased labor cost), eliminating te need for acetone altogeter and saving undreds of dollars per year. Cem-Pruf Door A manufacturer of fiberglassreinforced plastic doors and windows located in Brownsville, Texas Cem-Pruf Door implemented an acetone management program to better use acetone. Te program includes good operating practices suc as ensuring lids on acetone containers are kept closed to limit evaporative losses. In addition, te facility as canged to purcasing acetone in tote bins to eliminate drums and reduce te risk of spills. Spent acetone is also collected at workstations daily and distilled for reuse. Still bottoms remaining from distillation are reused as fillers in new products. Troug te acetone management program, Cem- Pruf Door as reduced acetone emissions by 13,000 pounds a year and saved on te purcase of new acetone by 2,000 gallons a year. Acetone Facts Cemical formula: CH 3 COCH 3 Organic solvent classified as a ketone Often used for cleaning and degreasing Evaporates quickly Soluble in water Colorless liquid wit a sweetis smell and distinctive taste Used in te manufacture of plastics, fibers, drugs, and oter cemicals Also known as dimetyl ketone, 2-propanone, beta-ketopropanone c o c c 4

5 Case Studies More information Picken s Plastics Located in Astabula, Pickens Plastics is a manufacturer of fiberglass products, regularly used acetone to clean tools. Tis worked well, but led to several fires. To reverse tis trend, in 1993 Picken s Plastics switced to a solvent blend and igly concentrated detergent (a water-based cleaner) as alternatives to acetone. Te alternative solvents cost more tan acetone, but Picken s as determined tat tese costs are justifiable. Bot te detergent and te solvent blend are muc less flammable tan acetone because of teir iger flas points. Te facility s insurance costs ave decreased, and employee safety as significantly improved. Since te switc, Picken s Plastics as experienced no fires, and no production time as been lost. Picken s Plastics as a permit to discarge te detergent wastewater to te municipal sewage treatment plant, and te solvent vendor disposes of te spent solvent blend in accordance wit local, state, and federal requirements. Hickory Springs A manufacturer and fabricator of flexible slabstock polyuretane foam (FPF), Hickory Springs developed and patented a process tat uses acetone as te auxillary blowing agent (ABA) in place of te ozone depleting subtances CFC -111 and metyl cloroform and te azardous air pollutant (HAP) metylene cloride. ABAs soften, reduce density and, most importantly, remove te potentially dangerous eat of reaction in te foaming process. Acetone is listed as an acceptable ABA substitute in te U.S. EPA s Significant New Alternatives Program (SNAP). By making te engineering modifications tat allow te use of te flammable acteone, Hickory Spring s foam plant in Ft. Smit, Arkansas now uses and emits only 150 tons of acetone annually as te ABA, compared to 260 tons emitted in 1990 using te HAP metylene cloride. As a result, Hickory Springs converted all six of its foam production facilities to using acetone as te only ABA and as multiple licensees of te process. Te Office of Pollution Prevention (OPP) as several publications available tat address topics regarding acetone, and is available to searc various sources for answers to your questions. Contact te OPP Tecnical Assistance Unit at 614/ for furter information or visit OPP s ome page on te World Wide Web at ttp:// In addition, a good way to start learning about existing solvent alternatives is to connect to Enviro$en$e on te World Wide Web at ttp://es.epa.gov/ Anoter source of information is te Solvent Alternatives Guide (SAGE), wic is also found via te Internet under Enviro$en$e. Set your WWW pointer to ttp://es.epa.gov/ssds/ sage.tml for more information. SAGE is also available from te U.S. EPA Tecnology Transfer Network (TTN), wic can be reaced by means of modem at 919/

6 References and Resources Agency for Toxic Substances and Disease Registry. ToxFAQs: Acetone. September ttp://atsdr1.atsdr.cdc.gov: 8080/tfacts21.tml (23 August 1996). Allen, Linda. Solvent substitution were are we today? Arizona Pollution Prevention Newsletter 1 (6). ttp://es.epa.gov/new/contacts/ newsltrs/arizona/arizv6.tml (20 August 1996). Cemical Manufacturers Association (CMA) Acetone Panel 1300 Wilson Boulevard Arlington, VA Federal Register, June 16, 1995, 60 (116): Rules and Regulations, pp Florida Department of Environmental Protection. Fact Seet: New cleaning solvents for industrial cleaning. ttp://es.epa.gov/tecinfo/facts/ florida/newslvfs.tml (18 August 1996) Indiana Department of Environmental Management, Compliance and Tecnical Assistance Program. February Acetone delisting: making te coice. Minnesota Tecnical Assistance Program. Eyeglass manufacturer eliminates azardous cemicals and canges from LQG to VSQG status. MnTAP SOURCE, v. 11, number 2. Spring Minnesota Tecnical Assistance Program. Fact Seet: Reducing volatile emissions in te fiber reinforced plastics industry. ttp://es.epa.gov/tecinfo/ facts/mpca/emision.tml (21 August 1996). Office of Waste Reduction Services, State of Micigan. Fact Seet: Considerations in selecting a commercial (offsite) solvent recycling service. ttp://es.epa.gov/ tecinfo/facts/micigan/ micfs14.tml (26 August 1996). Texas Natural Resources Conservation Commission.Pollution Prevention Ideas From Texas Industries -A Case Study Compendium. November Tis is one in a series of documents Oio EPA as prepared on pollution prevention. For more information, call te Office of Pollution Prevention at (614) Te Office of Pollution Prevention was created to encourage multi-media pollution prevention activities witin te state of Oio, including source reduction and environmentally sound recycling practices. Te Office analyzes, develops, and publicizes information and data related to pollution prevention. Additionally, te Office increases awareness of pollution prevention opportunities troug education, outreac, and tecnical assistance programs directed toward business, government, and te public. Office of Pollution Prevention WWW address: 6