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Air Quality Regulations Affecting Dry Cleaners,
Metal Finishers, and Printers



Summary of Regulations Controlling Perchloroethylene Emissions From Dry Cleaners


The Clean Air Act Amendments of 1990 direct the US Environmental Protection Agency (EPA) to regulate emissions of 189 toxic chemicals, including perchloroethylene (also known as perc, PCE, or tetrachloroethene). In response, the EPA issued national regulations to control air emissions of perc from dry cleaners. These regulations appeared in the 22 September 1993 edition of the Federal Register [volume 58, beginning on page 49354].

The regulations require that each owner or operator of a dry cleaning facility that uses perc as a cleaning solvent submit two reports to the USEPA: an Initial Report and a Compliance Report. The initial reporting information was due to the EPA 18 June 1994. The compliance certifications were due to the USEPA by 18 June 1994 for pollution prevention requirements and by 22 October 1996 if control equipment is required.

Required Pollution Prevention
The aformentioned pollution prevention steps involve:
  • Inspecting all dry ceaning equipment at least every other week for leaks that are obvious from sight, smell, or touch. All leaks must be repaired.
  • Keeping a log of the leak detection and repair program results.
  • Following good house keeping practices inclusive of: keeping all perc and wastes containing perc in covered containers with no leaks; draining cartridge filters in closed containers; and keeping the machine doors shut when clothing is not being transferred.
  • Operating and maintaining all dry cleaning equipment according to the manufacturers' instructions.
  • Keeping a log of the amount of perc purchased for the past 12 months.
Control Requirements
To better understand the control requirements set forth in the National Emission Standards for Hazardous Air Pollutants (NESHAP) for PCE, it is important to understand the following definitions:

Existing Dry Cleaning Machine: a machine installed before 9 December 1991
New Dry Cleaning Machine: machine installed on or after 9 December 1991

For "Existing" machines, the following control requirements apply:
Type of Machine Purchase Amounts of PCE (Perc) (gallons per year) "Small" or "Large" Facility Required Control
Transfer machines
only
200 or more
Large
Refrigerated condensers or existing carbon adsorber if in place before 9/22/93
Transfer machines
only
over 1,800
Large
Must install a room enclosure around each transfer machine and vent room enclosure to a carbon adsorber
Dry-to-dry
machines
only
140 or more
Large
Refrigerated condensers or existing carbon adsorber if in place before 9/22/93
Combination of
dry-to-dry
and transfer machines
140 or more
Large
Refrigerated condensers or existing carbon adsorber if in place before 9/22/93
Transfer machines
only
Less than 200
Small
Do not need to install perc vapor recovery systems
Dry-to-dry machines
only
Less than 140
Small
Do not need to install perc vapor recovery systems

For "New" dry cleaning machines, the following control criteria apply:
Any dry cleaning facility that installs a "new" machine must install a dry-to-dry machine with a refrigerated condenser. In addition, facilities that purchase over 1800 gallons of perc annually are required to use a carbon adsorber with a refrigerated condenser on the new dry-to-dry machine. "New" transfer machines that use perc cannot be installed.

Additional Reporting and Compliance Requirements
For existing machines, perc vapor recovery systems (refrigerated condensers and carbon adsorbers) are not required until 22 September 1996. All new machines must be equipped with these systems upon start-up. Refrigerated condensers must cool the perc vapor in the machine down to 45 degrees Fahrenheit or less at the end of the dry cleaning cycle. Any carbon adsorber must not release more than 100 parts per million of perc out of the stack. Facilities must submit a report to the EPA stating how it is complying with the regulations.

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Summary of NJ Air Quality Regulations Affecting Surface Coating (Spray Painting) and Graphic Arts Operations


* These regulations can be found at NJAC 7:27-16 and are downloadable from the New Jersey Department of Environmental Protection's BBS which can be "modemed" into at (609)-292-2006. The BBS is a DOS-based, menu-driven service which provides electronic access to a variety of NJDEP documents including regulations.

If your facility incorporates a surface coating or graphic arts operation and if the total surface coating formulations containing VOC are applied at rates in excess of one half gallon per hour and two and one half gallons per day then:
  • You should check to make sure that the VOC content of any surface coating formulation as applied does not exceed the applicable VOC content specified in tables 7A, 7B, 7C, or 7D of NJAC 7:27-16.7.
  • In addition, you may have to concern yourself with the following control requirements:
    a) the apparatus should prevent no less than 90% by weight of the VOC content in the surface coating formulation as applied each hour from being discharged directly or indirectly into the outdoor atosphere, or
    b) if a graphic arts operation cannot meet the control criteria set forth in table 7D of NJAC 7:27-16.7, then they should meet the following collection and control requirements:
Type of Printing Operation
Control
Volumetric Collection Efficiency (Hourly Basis)
Volumetric VOC Removal/Destruction Efficiency (Hourly Basis)
Rotogravure and gravure Thermal oxidizer
75
95
Carbon adsorption system
75
90
Flexographic Thermal oxidizer
70
95
Carbon adsorption system
70
90
FabricThermal oxidizer
70
95
Carbon adsorption system
70
90
Screen Thermal oxidizer
70
95
Carbon adsorption system
70
90


In addition, if your operation is subject to these operations, you should maintain:
  • records of the VOC content of each surface coating formulation (minus water) as applied, in pounds of VOC per gallon of coating or kg of VOC per liter of coating;
  • the percent weight of additional organic substances;
  • and the daily volume of each surface coating formulation applied.

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Metal Finishers: EPA's Chromium Emissions MACT Standard

Summary
The EPA's Office of Air Quality Planning and Standards established chromium emission limits in the National Emission Standards for Chromium Emissions from Hard and Decorative Electroplating and Anodizing Tanks, promulgated in 1995. The Standard includes two designations for hard chromium electroplating facilities, based on the maximum cumulative potential rectifier capacity and when the electroplating tanks were installed. A facility is desgnated as "large" if the rectifier capacity for all hard chromium electroplating tanks equals or is greater than 60 million ampere-hours per year. A "small" facility is one where the rectifier capacity is less than 60 million ampere-hours per year. The electroplating tanks in a facility can be "new" or "existing" . A "new" tank is one installed or reconstructed after December 16, 1993. An "existing" tank is one installed on or before December 16, 1993. The deadline for meeting the Standard is January 1997. Hard chrome electroplating shops must report their source outlet chromum emissions either on a total (hexavallent + trivalent) or hexavalent basis. The emission limits are:

"Small" Facility"Large" Facility
All existing tanks:0.03 milligrams/dry standard cubic meter 0.015 milligrams/dry standard cubic meter
All new tanks: 0.015 milligrams/dry standard cubic meter 0.015 milligrams/dry standard cubic meter

For more detailed information on EPA's MACT Standard, check the Wednesday, 25 January 1995 Federal Register for the National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. You can view the Federal Register on-line at the US EPA's web site.

In addition there is a document entitled "Hard Chrome Pollution Prevention Demonstration Project, Interim Report," prepared by the U.S. Environmental Protection Agency in cooperation with The National Institute of Standards and Technology available at the National Metal Finishing Resource Center's Web Site. The purpose of this document is to assist hard chrome metal finishing operators cost-efficiently comply with, or do better than, EPA's Chromium Emission MACT Standard. Of particular interest is the fact that it provides information regarding the efficiencies of pollution control/pollution prevention technologies including:
  • Blade-type mist eliminators
  • Packed-bed scrubbers
  • Mesh-pad mist eliminators
  • Polyballs
  • Chemical mist suppressants
It also compares the effectiveness of EPA Sampling Methods 306 and 306A. These sampling methods are described in detail in the Wednesday, 25 January 1995 Federal Register on pages 4979-4993.

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New Jersey Technical Assistance Program for Industrial Pollution Prevention ·
138 Warren Street · Newark, NJ 07102-1982 ·
Phone: 973-596-5864 · Fax: 973-596-6367 · Email: njtap@megahertz.njit.edu