Halogenated solvents NESHAP

The most effective method of isolating solvent vapor from the room draft within the vapor degreaser is to use a cover (Chapter 1.13). There is no alternative. A proper cover should slide easily over the mouth of the freeboard section (see Figure 1.25). A cover which is lifted or hinged should not be used. Each time a hinged or lifted cover is opened, drafts and turbulence carry out vapor. Covers must slide to be a control measure under the 1994 Halogenated Solvents NESHAP (Endnote W). 

The 1994 Halogenated Solvents NESHAP limits air speeds above a degreaser to less than 50 ft/min unless idling covers are used. 

More than two hateful words were expressed to the US EPA about this regulation. Yet more than a decade after its deadline for compliance, it s clear that interest in cleaning dirty parts with solvents has not declined but has increased. Essentially, the Halogenated Solvents NESHAP did not destroy solvent cleaning technology, rather it validated its use. 

Imagine playing a game and someone unexpectedly notes a mle about which you hadn t known, and the new rule affects your play. Confusion Sabotage Tbat s what happened in 2007 with the 1994 Halogenated Solvents NESHAP. 

The second-generation Halogenated Solvents NESHAP used the outcome(s) of the 1994 NESHAP as a baseline. Then, the 1990 CAA required the EPA to review whether or not at that baseline there is residual risk to the US population caused by users of halogenated solvents and required in the event residual risk is found by the EPA, that they take action to reduce that risk to acceptable levels . 

DD. It is also required by the EPA per the 1994 Halogenated Solvents NESHAP (Endnote V). 

The vapor removed, which is mostly air ripe with solvent, is a moving stream of air pollution. Traditionally, the stream was directed to an exhaust vent from the work area. As with many aspects of solvent cleaning, the 1994 NESHAP for halogenated solvents mandated that, under the equipment control options, the exhaust from lip vents be directed to a bed of activated carbon for removal of solvent from the moving stream by adsorption. 

W. For more details, see the ERA S Guidance Document for the 1994 NESHAP for Halogenated Solvents, available at http //www.epa. gov/ttnatw01 /degrea/solv-cl n4-30-04. pdf. 

I. This characteristic of an enclosed vapor degreaser was noted in the 1994 NESHAP for Halogenated Solvents (Chapter 1, Endnote T) as a basis for specifying permissible compliance options. 

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