Metal Finishing Guide Book

2013

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111 No Yes <100 tpy marginal1 <50 tpy serious <25 tpy severe <10 tpy extreme Yes 10 tpy or combination of 25 tons HAP Yes Yes Yes 50 ppm5 Worker right to know Training Record keeping Reporting Yes <100 kg: Cond. exempt 100-1,000 kg: Small quantity generator >1,000 kg: Large quantity generator Yes 100 lb Reportable quantity spill Trichloroethylene Yes 10 tpy or combination of 25 tons HAP Yes Yes Yes 25 ppm6 Worker right to know Training Record keeping Reporting Yes <100 kg: Cond. exempt 100-1,000 kg: Small quantity generator >1,000 kg: Large quantity generator Yes 100 lb Reportable quantity spill No No2 Perchloroethylene Yes 10 tpy or combination of 25 tons HAP Yes Yes Yes 25 ppm7 Worker right to know Training Record keeping Reporting Yes <100 kg: Cond. exempt 100-1,000 kg: Small quantity generator >1,000 kg: Large quantity generator Yes 100 lb Reportable quantity spill No No3 Methylene Chloride Yes 10 tpy or combination of 25 tons HAP Yes Yes Yes 350 ppm Worker right to know Training Record keeping Reporting Yes <100 kg: Cond. exempt 100-1,000 kg: Small quantity generator >1,000 kg: Large quantity generator Yes 100 lb Reportable quantity spill Yes No4 1,1,1-Trichloroethanea 2Perchloroethylene 1In included for comparison. areas of the country classed as having marginal smog problem up to 100 tpy emissions are allowed to a facility. Allowable emissions are lower in areas with more serious problems. listed as exempt February 7, 1996, Federal Register, 4588. 3Methylene chloride listed as exempt July 8, 1977, Federal Register, 35314 41,1,1-trichloroethane listed as exempt July 8, 1977, Federal Register 35314 5This limit in OSHA's 1989 rule has been overturned. dow continues to use these 1989 PELs in MSDS and labels. 6This limit in OSHA's 1989 rule has been overturned. dow continues to use these 1989 PELs in MSDS and labels. 7Currently challenged by industry ACGIH recommends 50 ppm, and Dow supports this limit. a1,1,1-Trichlorothane CERCLA (Superfund reportable quantities) RCRA (Resource Conservation and Recovery Act Hazardous Waste) HAP (Hazardous Air Pollutants NESHAP Clean Water Act OSHA PEL (Permissible Exposure Limit) Permits CAA Title V Ozone depletion (CAAA, Montreal Protocol) VOC (Votatile Organic Compounds) state-to-state differences Regulation

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