Louisiana SIP: LAC 33:III Ch 21 Subchap L, 2151--Limiting Volatile Organic Compound Emissions from Cleanup Solvent Processing; SIP effective 1998-02-02 (LAc74) to 2011-08-03 (LAc34 - Revised)
Louisiana Administrative Code, Title 33 ENVIRONMENTAL QUALITY, Part III Air (LAC 33:III)
Chapter 21. Control of Emission of Organic Compounds
Subchapter L. Limiting Volatile Organic Compound (VOC) Emissions from Cleanup Solvent Processing
Section 2151. Limiting Volatile Organic Compound Emissions from Cleanup Solvent Processing. LAc74 to LAd34 - Revised
(Approved by EPA 12/02/97 (62 FR 63658) at 52.970(c)(74) effective 02/02/98.)
A. Applicability and Designation of Affected Operations. The provisions of this Subchapter apply to the ensuing stationary sources that emit, or have the potential to emit, 50 tons per year or more of volatile organic compounds and conduct one or more of the following affected cleaning operations in the ozone nonattainment area consisting of Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee and West Baton Rouge. Once an operation is considered to be covered by this Subchapter, it shall be so considered ad infinitum. The affected cleaning operations are ones that use solvents in the following operations:
1. spray gun cleaning, which includes spray guns, attached paint lines, and any other gun equipment used in applying a coating;
2. spray booth cleaning, which includes all interior surfaces of booths and all equipment within the booth such as conveyors, robots, etc.;
3. large manufactured components cleaning (i.e., the cleaning of large parts as a step in the manufacturing process), which includes large manufactured products, such as automobile bodies, furniture sheet metal, etc.;
4. equipment cleaning, which includes all production equipment that may be cleaned in place (not moved to a cleaning area) to prevent cross-contamination or merely for maintenance purposes. Examples are punch presses, electrical contacts on a major piece of equipment, pump parts, packaging equipment, rollers, ink pans, carts, press frames, and table tops;
5. floor cleaning, which includes floors in all production areas of a facility;
6. line cleaning, which includes lines that transport raw material (e.g., paint, resin, etc.) and that are cleaned separately from tanks, spray guns, and other process equipment. In some cases a small tank may be part of the system;
7. parts cleaning, which includes miscellaneous items that might be moved to dip into a container of solvent. Examples of parts include applicator tips, brushes, machine parts, pumps, circuit boards, truck parts, engine blocks, gauges, cutoff steel/machined parts, tool dies, motors and assemblies, screws, oil guns, welded parts, bearings, and filters;
8. tank cleaning, which includes mixing pots, process vessels, and tanks. In some instances, tank lines are cleaned in conjunction with the tanks and would be considered part of the system; and
9. small manufactured components cleaning (i.e., the cleaning of small parts as a step in the manufacturing process), which includes small manufactured products such as glass windows, engine components, subassemblies, sheet metal panels, molded parts, electrical contacts, steel and copper components, tin/silver-plated terminals, plastic parts, upholstered parts, circuit breaker cases, switch covers, and threads and bolts.
B. Definitions. Unless specifically defined in LAC 33:III.111, the terms in this Subchapter shall have the meanings commonly used in the field of air pollution control. Additionally, the following meanings apply, unless the context clearly indicates otherwise.
Cleaning Activity -- physical removal of foreign material from a substrate being cleaned. It includes such actions as wiping, brushing, flushing, or spraying.
Cleaning Classification -- cleaning is considered to have three main classifications:
a. cleaning of external surfaces;
b. cleaning of interior surfaces (i.e., containers); and
c. cleaning of removable parts.
Cleaning of External Surfaces -- solvent is applied to the external surface being cleaned (as contrasted to the interior of tanks or pipes). Surfaces that fall within this classification include rollers in printing machines, wings of airplanes, floors, tables, and walls. The cleaning activities applied to the external surface may include wiping, brushing, mopping, or spraying.
Cleaning of Internal Surfaces/Containers -- solvent is applied to an interior surface for cleaning. Surfaces may include the inside of tanks/vessels, batch reactors, columns, heat exchangers, paint spray booths, and fuel tanks. The cleaning activities applied may include flushing, agitation, spraying, mopping, or brushing. Any combination of activities may be used, depending upon the shape and size of the unit operation and upon the type of residue that is being removed.
Cleaning of Parts -- solvent engulfs the entire surface of the part as it is dipped into a container of solvent or the part is cleaned above the container by a cleaning activity such as spraying or wiping. Equipment or the unit operation where this might take place includes part washers, batch-loaded cold cleaners, ultrasonic cleaners, and spray gun washers.
Cleaning Practice -- a repeated or customary action that is specific to an industry. An example is nightly maintenance of a spray booth in an automobile assembly plant.
Cleaning Tool -- an item used to aid cleaning, such as a wiping rag, a brush, a scraper, or a water jet.
Closed-loop Recycling (In-process Recycling) -- reuse or recirculation of a chemical material within the boundaries used to develop a material balance around a unit operation system. A recovery or regeneration (R and R) unit operation may be within the boundaries selected for the primary unit operation system if it is:
a. solely dedicated. The chemical is reused only for cleaning the primary unit operation;
b. physically integrated. The R and R unit operation is connected to the primary unit operation by means of piping, so that it is not possible to perform the material balance around the primary unit operation system without including it.
Hazardous Air Pollutant (HAP) -- any of the substances identified in LAC 33:III.5115.
In-process Recycling -- see Closed-loop Recycling.
Line Flushing -- the procedure of completely cleaning out a large paint circulating system such as those found at auto assembly plants. The system includes the paint mix tanks and perhaps hundreds of feet of piping. This procedure is only necessary when a system is inadvertently contaminated or for a routine color change. (Although the system is essentially a closed loop, some losses can occur during the flushing; i.e., through various vents, from transfer operations, and from the paint mix tanks.)
Material Balance -- the sum of all materials entering a system equated to the sum of all materials leaving the same system. Emissions from storage vessels shall be included.
Net Usage -- the net usage (U) of solvent, in appropriate weight units, shall be calculated on a monthly basis as follows: opening solvent inventory (A), plus any estimated opening in-process solvent inventory (B), minus the closing solvent inventory (C), minus any closing in-process solvent inventory (D), minus the corrected waste solvent collected during the month, corrected by subtracting the amount of water and solid contaminants (W), i.e., U = A + B - C - D - W.
On-site Recycling -- an R and R unit operation located within the plant boundaries from which waste solvent is returned to a process other than that which generated the waste solvent. A material balance for the R and R unit operation (distillation, filtration, etc.) shall be developed independently. (See Storage Container.)
Off-site Recycling -- an R and R unit operation system located outside of the plant boundaries.
Pollution Prevention -- practices or process changes that decrease or eliminate emissions (or wastes) at the source. Such prevention techniques include the use of new materials, modification of equipment, and changes in work practices.
Product Substitution -- replacement of any product or raw material intended for an intermediate or final use, with another. This substitution is a source reduction activity if either the VOC emission or the quantity of waste generated is reduced.
Purging -- the process wherein individual paint applicators and portions of paint delivery lines are emptied of one color paint, cleaned, and filled with another.
Reclaim -- process or regenerate a material to recover a usable product. (See Recycled.)
Recovery or Regeneration (R and R) Unit Operation -- a device for purifying solvent that may use any of a variety of techniques, including extraction, distillation, filtration, adsorption, or absorption.
Recycled -- used, reused, or reclaimed. A material is used or reused if it is employed as an ingredient (including its use as an intermediate) to make a product; i.e, when solvent, recovered by distillation, is reused in the plant.
Reused -- see Used or Reused.
Solvent -- a substance that has the potential to emit VOCs and the sum of the partial pressures of the VOCs exceeds 1.5 psia at operating conditions.
Source Reduction -- any activity or treatment that prevents, reduces, or eliminates the generation of VOC emissions (or waste), including product substitution or elimination and pollution prevention.
Treatment -- destruction or degradation of waste using techniques such as combustion or neutralization to produce material that is less toxic and more environmentally benign. (See Recycled.)
Unit Operation -- an industrial operation classified or grouped according to its function in the operating environment. Examples include distillation columns, paint mixing vessels (tanks), spray booths, parts cleaners, and printing machines. A unit operation may consist of one or more items of equipment, e.g., both a reactor and a mixing vessel or several mixing vessels. There may be considerable variation in the type of unit operations from one industry to another. (See Unit Operation System.)
Unit Operation System (UOS) -- the ensemble of equipment around which a material balance is performed. A UOS includes all possible points/sources from which losses could occur to the atmosphere as a result of its being cleaned. This includes losses from solvent storage, during the dispensing of solvent, and from residual solvent on or in cleaning tools (such as rags). An item of equipment used for cleaning parts is, by definition, a unit operation. Therefore, carry-out losses during removal of cleaned parts is to be considered in a material balance.
Used or Reused -- employed as an ingredient (including use as an intermediate) in an industrial process to make a product. (For example, in purifying a waste solvent, distillation bottoms from one column may be used as feedstock to another column.)
Waste Minimization -- the reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated and stored. It includes any source reduction or recycling activity undertaken by a generator that results in either the reduction of total volume or quantity of hazardous waste, or both, so long as such reduction is consistent with the goal of minimizing present and future threats to human health and the environment. In order of preference waste minimization activities are: source reduction, recycling, and treatment.
Work Practice -- specific human activities within industry that lead to a reduction in VOC emissions (or waste). The activities include increased operator training, management directives, segregation of the waste solvent, and practices that lead to a reduction in cleaning frequency. It does not include the use of specialized equipment, such as solvent dispensers.
C. Control Requirements. It is not feasible to mandate specific control techniques in the case of cleanup solvents. Therefore the administrative authority* shall require the affected facilities specified in Subsection A of this Section to implement the following actions, per EPA publication number EPA-453/R-94-015, February 1994:
1. conduct a three month intensive study of solvent types and usage;
2. utilize accounting on a unit operation system;
3. submit plans to the administrative authority*, to reduce VOC emissions from solvent usage, within 12 months after promulgation of these regulations. Any increases in VOC emissions due to the substitution of a nonhazardous air pollutant for a hazardous one shall require approval of the administrative authority*. As an alternative to submitting reduction plans, the owner or operator of affected facilities may report the controls and/or work practices deemed to be MACT that have been adopted to reduce VOC emissions from solvent cleanup operations. These plans or submissions become enforceable upon approval.
D. Testing. ASTM Method D-4828, "Standard Test Method for Practical Washability of Organic Coatings," is a method adaptable for comparing the cleaning effectiveness of solvents and other cleaners. Modifications of this method may be approved by the administrative authority*.
E. Monitoring, Reporting, and Recordkeeping. Reporting and recordkeeping shall be used to monitor VOC emissions from solvent use for cleanup purposes. Affected facilities shall calculate and record the net VOC emissions from usage of solvents monthly and report the net VOC emissions from solvent usage annually. In addition, solvent reduction progress shall be reported annually, based on product output or other suitable basis approved by the administrative authority*. Alternately, the owner or operator of affected facilities may report the controls and/or work practices deemed to be MACT that have been adopted to reduce VOC emissions from solvent cleanup operations. A violation of this Section occurs if the affected facility does not meet the State-approved solvent reduction target.
AUTHORITY NOTE: Promulgated in accordance with R.S. 30:2054.
HISTORICAL NOTE: Promulgated by the Department of Environmental Quality, Office of Air Quality and Radiation Protection, Air Quality Division, LR 21:391 (April 1995).
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