Save Up to $15,000 in Penalties by Complying with EPA's Vapor Degreaser MACT Standard
Recently, the United States Environmental Protection Agency (EPA) inspected vapor degreasers at six plants, in a variety of industries, and all six were not complying with the EPA's Vapor Degreaser Maximum Available Control Technology (MACT) Standard. The average penalty cost was $10,175 which, because the penalties are not tax deductible, had to be paid out of profits. There were additional costs such as management time, consultant's and attorney's fees and wasted solvent.
Let's look at the types of non-compliance found during the six inspections:
- The chain hoist used to lower and raise a parts container into the vapor
degreaser exceeded the maximum allowable speed 11 feet per minute. The
reason for the specified maximum speed is to assure that the vapor blanket
is not disrupted to the extent that vapor spills out of the degreaser and
into the air. It is not difficult, using a stop watch, to measure a few
feet of chain movement and to figure out if the hoist speed is less than
11 feet per minute. The hoist speed should be checked, and recorded monthly.
If the speed does not exceed 11 feet per minute for one year then it can
be checked quarterly.
- The temperature at the center of the air blanket did not comply with
the requirement that the temperature be 30 percent or less of the solvent's
boiling point. This ensures that the solvent vapors condense and fall back
into the sump rather than evaporating into the plant. Measure and record
the temperature, every week, in the center of the air blanket, while the
machine is idling.
- The freeboard ratio was not measured correctly. Freeboard ratio is the
ratio of the freeboard height to the smaller interior dimension (length,
width or diameter) of the machine. The freeboard height is typically the
distance from the solvent/air interface, as measured during idle mode to
the top of the machine. The distance to the solvent/air interface is typically
at the mid-line height of the primary condenser coils.
- Covers were not in place when the degreaser was not in use. Using a cover is the one of the easiest ways to reduce solvent losses. Covers should only be off/opened during the cleaning of parts.
And the biggest tip-off that there are violations comes when you enter a shop and you can smell the distinct odor of degreaser solvent.
An alternative method of compliance allows facilities to measure solvent consumption rather than measuring hoist speed, temperature, etc. For this option, facilities need to ensure that each degreaser has its own independent measuring device, i.e. flowmeter.
The degreasing regulation was developed with the help of solvent manufacturers, trade associations and equipment manufacturers. Many of these organizations, and their competitors, are invaluable resources for information that can assist you in compliance. Just check their websites or phone their representatives. Also, EPA, Region 3 developed a short tri-fold brochure that summarizes some of the requirements in the regulation. It is available at the Halogenated Solvents Industry Alliance, Inc. web site (PDF, 453KB, 2 pages, info about PDF).
What the inspectors look for is no big secret. Inspector checklists are available in Appendix B2 of EPA document No. EPA-453/R-94-081, "Guidance Document for the Halogenated Solvent Cleaner NESHAP" (PDF, 4.3 MB, 166 pages, info about PDF). The University of Tennessee Center for Industrial Services produced a document that is simpler to read than the regulations named "Clean Air Act Compliance for Vapor Degreasers" (PDF, 1.41 MB, 103 pages, info about PDF). This booklet is logically organized, contains diagrams, sketches, charts and the appendices contain the operator test and sample record keeping and reporting forms. The HSC Rule Assistant is another good resource as is the Halogenated Solvents Industry Alliance Inc. (HSIA) White Papers which contain useful solvent information.
These requirements in the regulation are not all EPA's original ideas. More that 50 years ago, solvent degreaser sales representatives promoted slow hoist speed, racking parts for good drainage and making sure the degreaser is not located in a drafty area. These are good operating practices that reduce costs by reducing solvent usage and they are in the regulation as a compliance option.
Checking a degreaser for compliance requires: a watch that displays seconds, a tape measure, an air velocity meter and a thermometer or thermocouple. None of these are complicated or difficult to use and they are readily available, and relatively inexpensive.
There is the old saying, "if it isn't measured, it isn't managed." Record keeping not only helps manage a degreaser but also provides the person training new employees with an outline covering the important points and it shows the supervisor that the process is in control.
You can also obtain free/low cost technical assistance from state and non-governmental assistance providers. Contact your state small business ombudsman for information about these resources or contact David Byro of the EPA Region III Business Assistance Center at 215-814-5563 or firstname.lastname@example.org.Contributors: David Byro, Bowen Hosford, Dianne McNally and Lew Felleisen all of the EPA Region 3 Mid-Atlantic Regional Office