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Vapor Degreasing Process Uses Trichloroethylene (TCE) Replacement to Eliminate Hazardous Waste

Electro-Spec Inc. (Franklin, Indiana) had been using a trichloroethylene (TCE) solvent, one of these hazardous materials, in its Tiyoda vacuum vapor degreasing unit for years. When the solvent came up on the EPA list, environmental health and safety director Ben McKnight led a research project to find an alternative to this hazardous chemical. As members of an environmental stewardship program and members of a program sponsored by the Indiana Department of Environmental Management, Partners for Pollution Prevention, Electro-Spec needed to live up to its drive for environmental excellence, and therefore minimize or eliminate hazardous waste. The Production Machining magazine has a full article in the May 2019 issue detailing how good chemistry has helped this vapor degreasing process become greener.

Annual Compliance Certifications

In Indiana, regulated entities with Part 70 (Title 5) or federally enforceable state operating permits (FESOP) issued by IDEM’s Office of Air Quality (OAQ) are required to certify compliance through the submittal of Annual Compliance Certifications (ACC).

ACC submittal dates:

  • FESOP and Part 70 (Title 5): for Clark, Elkhart, Floyd, Lake, Marion, Porter, St. Joseph, and Vanderburgh Counties, the ACC - due no later than April 15
  • FESOP and Part 70 (Title 5): for all other counties - due no later than July 1

Much of the required information for the ACC comes from the permitted source’s quarterly deviation and compliance monitoring reports, permit conditions, inspection reports, and internal review practices. OAQ’s air inspectors are required to review all of the 1,100 plus certifications that are received or should have been received, and they must request resubmittals if errors are found within the reports. Common errors can include:

  • Recording only one permit number when during the calendar year, another permit was issued which may have included new permit conditions
  • Forgetting to include the reporting year which is typically January 1 or when the permit was issued to December 31 or the expiration of the permit
  • Forgetting to submit the ACC after the sale of their business (previous owners have an ongoing obligation for reporting until the reporting cycle is completed and the new owners take over reporting responsibilities)
  • Confusion over terminology (e.g. “intermittent”), which may result in reporting inaccurate data, or not reporting deficiencies and corrective actions taken
  • Descriptions of a deviation and the related permit condition can be written vaguely or ambiguously, making it difficult for the inspector assigned to review the certification to understand the content, which causes delays in processing and may result in a resubmittal request
  • Forgetting to obtain the signature of the responsible official in a timely fashion, as they could be located in another state, which results in a late submittal

Sources can reduce errors to the required ACC by taking these steps to be proactive and prepared to submit accurate and timely reports:

  • Develop a long term strategy for reporting - Delegating responsibility and establishing a system of reminders can increase the likelihood that monitoring data that needs to be collected will be
  • Collect records throughout the year
  • Organize records for easy retrieval
  • Consider contingencies – backup person to collect and submit reports
  • Incorporate a reminder system to prompt the process of reviewing records, completing & reviewing the certification and submitting it via certified mail to the IDEM Compliance and Enforcement Branch, Office of Air Quality at least one week prior to the due date

Environmental Impacts of Power Washing Activities

Power washing is a type of industrial activity that is typically mobile, short-term and generates a relatively small volume of wastewater and debris. Wastewater generated from power washing can contain contaminants like detergents, oils, inert solids, metals, paint, solvents or other chemicals.

If the wastewater that is generated from power washing isn’t properly managed, the discharge can be conveyed by streets, curbs, gutters, inlets, ditches, open channels, etc. to Waters of the State, in violation of state law and rules. These various types of conveyances may be connected to storm sewers or storm drains that can lead directly to Waters of the State. Discharging to these conveyances may violate state water quality standards by causing floating debris, oil or scum, color, odor or other nuisance conditions. More about power washing chemical additives, regulatory oversight, disposal options, and other considerations can be found in CTAP’s newest power washing Fact Sheet (available on the IDEM Fact Sheets page).

Reminder to all regulated entities in Indiana that have federal air permits - Title 5 (Part 70) and Federally Enforceable State Operating Permits (FESOP) – that the Annual Compliance Certification is due on July 1. These Air Annual Compliance Certifications are due for all companies except those required to submit on April 15 (sources located in Clark, Elkhart, Floyd, Lake, Marion, Porter, St. Joseph, and Vanderburgh Counties). The IDEM Office of Air Quality (OAQ) has guidelines for submittal and review of ACCs and sample forms available for reference. Contact CTAP if your business needs help getting your ACC completed properly and submitted on time.

Solvents in the Workplace

The U.S. EPA has released an updated guidance document, entitled, Solvents in the Workplace – How to Determine If They Are Hazardous Waste [PDF].

Solvents are used in the workplace for many different purposes and once they are spent or left unused and destined to be disposed, making hazardous waste determinations can sometimes be a challenging task. This e-enterprise user-friendly guidance walks through a series of questions and answers that will help a facility determine if it may have generated a hazardous waste solvent. The guidance provides information to assist a facility in recycling or reusing its solvents which could reduce its waste management costs and the nation’s need for virgin materials. Also, at the end of the document, there are a number of questions the U.S. EPA has answered through the years involving hazardous waste solvents.

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