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General
Reporting requirements for the National Emission Standards for Perch lorethylene have been finalized. While the deadline for reporting has been extended to June 18,1994, the record keeping requirements have been in effect since December 20,1993. As with most regulations originating from a government, there are a number of grey areas involved. We do not profess to be experts in the interpretation of these regulations. What we have tried to do is to provide an outline of forms that might be used to record the required data. These are generic and not all spaces will be required data for all plants. These are only suggested forms but hopefully will serve as a guide for you to develop a form that fits your situation.
Log of Solvent Purchases
This is a yearly form to record gallons of perc purchased, the vendor and invoice number. A column is provided to keep a running total of perc purchases for the previous 12 months. The $ columns are for your own information and are not required by the government.
Log of Information
The information required here depends on the annual perc Purchases for each plant, the type of equipment involved and the date on which each cleaning machine was installed in its present location. This form is monthly and the total perc purchases for the previous 12 months may be transferred from the Log of Solvent Purchases.
The first six lines, up to R/C Condenser Temp out, are presently required for most plants. If a leak is detected, the detail as shown is required. The form provides documentation for 3 leaks per month. The weekly inspection involves leaks you can see, feel or smell; no instruments are required.
Some or all of the remaining data may apply to you now, in 1996, or not at all. Read the regulations carefully and determine your situation.
If you are required to measure vapor concentration you will have to invest in a colorometric monitoring system. A device made by Sensidyne is available from the IFI (1-800-638-2627) or Lab Safety Supply (1-800-356-2501). Another unit, made by Drager is called the Accuro Gas Metering System and is available from Lab Safety Supply and Fisher Scientific (1-800-766-7000). Both devices are undoubtedly available from other sources and range from $300.00 to $400-00 depending on accessories. Tubes are available for both units for perc in the range 10-500 ppm. Each tube is good for only one test and costs around $4.50.
Electronic halogen gas leak detectors, while not currently required under this regulation, are valuable in controlling solvent losses and to maintain a legal TWA of vapor exposure to employees. The only meters we know of are made by TIF and come in three models, 5050, 5550 and 5650, each similar but with various features. They may be purchased from W.W. Grainger (locations nationwide) or from most refrigeration equipment supply houses.
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