P2 Interim Report by Abbydoc

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									                                            SBAP

                 TECHNICAL ASSISTANCE
                       REPORT
                   Indiana Clean Manufacturing Technology and Safe Materials Institute
                    2655 Yeager Road, Suite 103, West Lafayette, Indiana 47906-1337


                                      Company ID SB 640

                                           December 2002
____________________________________________________________________________________________

Introduction                                            Environmental Issues

An      Indiana      Clean     Manufacturing            Coating operations have the potential to
Technology and Safe Materials Institute                 release particulate matter (PM), volatile
(CMTI) process engineer, as part of the                 organic compounds (VOCs) and hazardous
Small Business Assistance Program (SBAP)                air pollutants (HAPs) into the atmosphere.
outreach, contacted company SB640.          A           VOCs are chemicals categorized as ozone
site visit was conducted and technical                  precursors, and can contribute to the
assistance provided. This included a review             development of ground-level ozone in the
of the facility’s air emissions inventory, air          atmosphere. HAPs are those pollutants that
permit status determination, solvent                    are known or suspected to cause cancer or
substitution opportunities, and an ISO 14001            other serious health effects. PM, which
environmental management systems gap                    includes dust, dirt, soot, and smoke, can
analysis.                                               have damaging effects on the respiratory
                                                        system.
Company Background
                                                        Companies that perform these operations
The Company is located in the central
                                                        may be required to obtain an air construction
region of the state and employs
                                                        and/or operating permit for their emission
approximately 35 employees in the
                                                        sources. Companies that operate under air
manufacturing of paints and the re-finishing
                                                        permits must ensure that emissions from
of metal office furniture, both on and off-
                                                        their operations do not exceed limits
site. The company has a primary SIC of
                                                        specified in their permit. They must also
3479, Coating and Engraving.
                                                        ensure that they comply with the operating,
                                                        monitoring, and reporting requirements
                                                        outlined in their permit. Failure to comply



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with these requirements       would    be   a        Permit-by-Rule (PBR) option, provided that
violation of the permit                              they can demonstrate compliance for a
                                                     rolling 12 month time period using material
There is a hierarchy of permits regulating           usage and/or production records.
increasingly higher levels of the potential to
emit (PTE) pollutants. PTE assumes that              The company was in the process of
the company is operating 24 hours per day,           evaluating alternative solvents for their
seven days per week. The hierarchy is:               operations prior to the site visit. The CMTI
Exemption --> Registration --> Minor                 representative explained the Indiana
Source Operating Permit (MSOP) -->                   Relative Chemical Hazard Score (IRCHS)
Federally Enforceable State Operating                measurement method developed by CMTI to
Permit (FESOP) --> Title V (Part 70)                 rank chemicals by their environmental and
Operating Permit. There are two alternative          workplace hazards.       The IRCHS uses a
operating programs that are not based upon           mathematical algorithm to assign the
the PTE. A company may use the Permit-               chemical a value based upon impact upon
by-Rule option if their actual emissions are         the aquatic ecosystems, air quality, soil &
less than 20% of the Part 70 thresholds. The         groundwater, stratospheric ozone depletion,
Source Specific Operating Agreements                 and worker safety. CMTI evaluated 6
(SSOAs) are sector based, allowing limited           solvents for the company.
levels of pollutants to be emitted by sources
undertaking specific activities within a             CMTI also conducted a gap analysis of the
certain scale of operations.        Company          company’s environmental management
SB640 did not have an air permit at the time         system to determine how they compared
of the site visit.                                   with the ISO 14001 standard.

Description of Technical Assistance                  Potential Environmental & Cost Benefits

At the time of the site visit, copies of             Based upon information provided by
IDEM’s Self-Disclosure and Environmental             company SB640, the facility is currently
Audit Policy brochure and the SBAP                   operating under the PBR criteria.
brochure were distributed to the company
representative.   The various levels and             CMTI’s IRCHS evaluation of              the
hierarchies of air permitting were also              alternative solvents company SB640 is
discussed with the company representative.           currently considering will help them choose
                                                     safer solvents for the workplace and will
CMTI determined the company’s air                    help to reduce xylene emissions. CMTI will
permitting status by calculating the actual          prepare a follow-up technical assistance
emissions of PM, VOCs and HAPs from the              report that will describe the environmental
paint production and coating operations,             and cost benefits of using the alternative
based upon information provided by the               solvents.
company representative. Paint production
and surface coating of metal furniture on-           The ISO 14001 gap analysis will help the
site resulted in actual annual emissions that        company determine if they wish to pursue
were less than 20% of the Part 70                    certification to the standard.         Past
thresholds. Therefore, according to 326              experience with ISO 14001 certification has
IAC 2-10, the company is able to use the             indicated that some companies will go


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beyond compliance with the regulations and
switch to a new paradigm of continuous
improvement with respect to pollution
prevention, regulatory compliance and
byproducts management.

This is an ongoing technical assistance
project.

TFG




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