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MEMORANDUM

Date: May 12, 1998

SUBJECT: Halogenated Solvent Cleaning Machine NESHAP

FROM: Elliott J. Gilberg, Director

Chemical, Commercial Services and Municipal Branch

TO: Regional Halogenated Solvent Cleaner MACT Contacts

 

This letter provides an overview of two recently published Federal Register notices regarding the halogenated solvent cleaning machine NESHAP and clarifies several other issues regarding the implementation of the NESHAP.

On May 5, 1998, two Federal Register notices were published to amend the halogenated solvent cleaning machine NESHAP. These notices: (1) announce an immediate 3-month stay of the effectiveness of the NESHAP for continuous web cleaning machines using HAP solvents; and (2) propose a temporary extension of the applicable compliance date beyond the 3-months stay for up to one year. During the stay, the Office of Air Quality Planning and Standards (OAQPS) will conduct an evaluation of methods of control for all continuous web cleaning machines to determine which emission control measures are equivalent to those provided in the NESHAP. EPA decided to propose a stay on the NESHAP after becoming aware of several sources with continuous web cleaning machines that were experiencing difficulties in determining how to comply with the NESHAP. In each case, the emission control requirements specified by the NESHAP was difficult or impossible to implement due to the unique operating and emission characteristics of continuous web cleaning machines. Unless the Agency receives adverse public comment on the proposed temporary extension of the 3-month stay, the stay will go into effect at the end of the immediate 3-month stay. We will keep you apprised of the regulatory status of continuous web cleaning machines.

In response to several Regions, this letter also provides clarification regarding the applicability of the halogenated solvent cleaning machine NESHAP to stripping operations. The use of a halogenated HAP solvent to remove paint, maskant, or a coating is not subject to this NESHAP. A separate MACT standard for paint stripping operations is under development.

Finally, this letter provides corrections to the April 1995 Guidance Document for the Halogenated Solvent Cleaner NESHAP (EPA-435/R-94-081) and question number 1 of the Control Device Specific Questions provided in Appendix A to Subpart T - Test of Solvent Cleaning Procedures. On page C-14 of the guidance document, AREA is incorrectly defined as "Amount of halogenated solvent removed from the machine in solid waste". The correct definition of AREA is "The solvent-air interface area of the machine in square meters (or square feet" (see page 2-35 definition of AREA). Regarding question number 1 of the Control Device Specific Questions provided in Appendix A, as drafted, none of the answers to this question are correct. Answer D to this question should read: no greater than 30 percent of the solvent boiling point rather than 30 percent of the solvent boiling point.

Please contact Tracy Back of my staff at (202) 564-7076 or E-mail at back.tracy@epamail.epa.gov with any questions on the halogenated solvent cleaning machine NESHAP.

 

 

cc: Paul Almodovar, OAQPS

Ingrid Ward, OAQPS

Charlie Garlow, ORE-Air

Bruce Buckheit, ORE-Air

 

 



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