Metal Finishing Guide Book

2012 Organic Finishing Guidebook Issue

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Program (SBAP) in each state. State SBAPs provide a Small Business Ombudsman and a Technical Assistance Director to facilitate communications between the EPA and small businesses and to provide information on new and existing environ- mental regulations and policies. To qualify as a small business, a company must have fewer than 100 employees and must not be "dominant in its field." The federal Small Business Ombudsman provides literature and a toll-free hot-line to answer questions. Primary assistance for a business comes from the state SBAP office, and a small business can find out who to contact on a state level by calling the federal Small Business Ombudsman's hotline: 1-800/368-5888. The Halogenated Solvents Industry Alliance (HSIA), a trade association of producers of chlorinated solvents, provides legislative and regulatory news for the solvent industry, sponsors research on chlorinated solvents, and presents infor- mation from research to the EPA and other solvent regulators. Users of chlori- nated solvents can obtain information from this organization, as well as litera- ture on the use of the solvents and how to comply with regulations, by calling HSIA at 202/775-0232. Help is also available from the producers of chlorinated solvents. Producers and distributors are required by law to provide a MSDS, containing complete in- formation on safety and handling, to all customers. In addition many produc- ers also supply other forms of assistance. PROCEDURES FOR REDUCING EMISSIONS Emission standards for chlorinated solvent degreasing operations are now governed by EPA's NESHAP for new and existing halogenated solvent clean- ing operations. These standards cover both vapor degreasing and cold clean- ing with TCE, PCE, and MEC, as well as with chloroform. The goal of the NE- SHAP regulation is an overall reduction in solvent emissions of 50 to 70% of current nationwide emissions. The NESHAP provides a number of control procedures for reducing solvent emissions from equipment. Operators of batch vapor degreasers and in-line cleaning machines may choose from a series of combinations of two or three of the procedures, which include: • Freeboard ratio of 1.0: The height of the freeboard above vapor level must be equal to the width (shorter dimension) of the degreaser. • Freeboard refrigeration device: This is a refrigerated system that sup- plements or replaces the traditional water cooling system and creates a cold air blanket above the vapor zone. • Reduced room draft: Wind speed above the freeboard must not ex- ceed 50feet per minute (15.2 m/min). • Working-mode cover: This is defined as any cover or machine design that shields the cleaning machine from outside air disturbances dur- ing the parts cleaning cycle. • Dwell: This refers to the time in which cleaned parts remain in the freeboard area above the vapor zone after cleaning. The EPA defines proper dwell time as 35% of the time required for the parts to cease dripping in the vapor zone. • Superheated vapor (vapor temperature maintained 10°F above the 21

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