Small Existing Area Source Inspection Checklist
Prior to conducting the site inspection, the inspector MUST determine the installation date and usage rate of perchloroethylene in order to classify the source as a small or large area source.
This checklist is only relevant for SmallExistingArea source facilities.
[Perchloroethylene consumption is less than 140 gallons per year
for area sources installed after 12/9/91 use the Large Area Source Inspection checklist]
INSPECTOR ON-SITE CHECKLIST
Small Existing Area Sources
The Inspector must complete one checklist for each “source” or machine inspected.
This source has a yearly perchloroethylene usage rate of ______
(Yearly perchloroethylene usage rate is calculated as the sum of the volume of all perchloroethylene purchases made in each of the previous 12 months. [40 CFR 63.323(d)])
This source had an initial startup date of ______
This is a ______source (new, or existing)
[New – constructed or reconstructed with initial startup after 12/9/91
Existing – constructed prior to 12/9/91]
This is a Residential Area Source? ______(yes, or no) (no new residential sources after July 27, 2006)
If yes, installed prior to December 21, 2005? ______(must eliminate perc use by December 21, 2020)[40CFR 63.320(o)(5)(i)]
If yes, installed between December 21, 2005 and July 12, 2006? ______(must eliminate perc use by July 27, 2009)[40CFR 63.320(b)(2)(ii)]. If installed between 12/21/05 and 7/12/06, additional requirements apply as of 7/26/06 per 40CFR 63.322(o)(5)(ii) these are not included on this checklist, please refer to the regulation for compliance requirements.
This source must be in compliance as of ______(date)
This Perchloroethylene dry cleaner was in compliance on ______(date)
OR this source is not in compliance because ______
______
______
Page 1 of 4
Small Existing Area Source Inspection Checklist
Transfer Dry Cleaning Machines
Existing Small and Large Area Sources must discontinue the use of transfer machines by
July 28, 2008. New sources are prohibited from using new or relocated transfer machines.)
Existing Dry to Dry Machine (Installed prior to 12/9/91)
____The door should remain closed at all times except when the operator is adding or removing clothes. [40CFR 63.322(a)]
____The operator must run the machine based on the manufacturer specifications and recommendations. [40CFR 63.322(c)]
____Before removing any filters from the dry cleaning machine, the operator must drain the filters in their housing or in a sealed container for a 24 hour period. [40CFR 63.322(i)]
____The operator must store all perchloroethylene and perchloroethylene wastes in sealed containers that do not leak. [40CFR 63.322(j)]
____Perceptible Leak Inspection - The operator must check for leaks in and around the machine biweekly. The leak check must be done when the machine is running. The leak check is documented in the operator’s record keeping practices. [40 CFR 63.322(k) and 40 CFR 63.322(l)]
Page 1 of 4
Small Existing Area Source Inspection Checklist
____The operator must repair any leaks found within 24 hours. If new parts are needed they should be ordered within two days of finding the leak and new parts should be installed within 5 days of receiving the part. [40CFR 63.322(m)]
____Enhanced LDAR Inspection - The operator must inspect for vapor leaks using a halogenated hydrocarbon detector or PCE gas analyzer on a monthly basis by placing the probe inlet at the surface of each component interface where leakage could occur and moving it slowly along the interface periphery. The leak check must be done when the machine is running. This enhanced LDAR inspection can satisfy a requirement for a perceptible leak inspection. [40 CFR 63.322(o)(1)].
New Dry to Dry (installed on or after 12/9/1991)
[for small area sources installed after 12/9/91 use the Large Area Source Inspection checklist]
All Sources:
TYPE OF AIR POLLUTANT CONTROL DEVICE: (mark applicable devices) theowner or operator should have documentation available about the machine and the control device being used. [40CFR 63.324(e)] Note: A pollution control device is not required for small existing area sources.
Add-on air pollution control devices:
_____Refrigerated condenser
____ Freon
____ Water
____ Other
_____Carbon Adsorber (Sniffer)
RECORDKEEPING:
____Usage logs are up to date and receipts for perchloroethylene purchases are available. [40CFR 63.324(d)(1)]
____The sum of all the perchloroethylene purchases made in each of the previous twelve months is calculated. [40 CFR 63.324(d)(2)]
____Log showing the dates of leak inspections kept? [40CFR 63.322(k), 40CFR 63.322(o)(1), and 40CFR 63.324(d)(3)]
____Existing small sources (installed prior to 12/9/91) require biweekly leak inspections.
____New sources (installed on or after 12/9/91) must conduct weekly inspections.
____All sources must conduct monthly Enhanced LDAR inspections with a hydrocarbon detector or PCE gas analyzer (the Enhanced LDAR inspection can satisfy a requirement for a perceptible leak inspection). [Enhanced LDAR leak detection must commence by 7/28/08 for sources installed on or before 12/21/05 and by 7/26/06 for sources installed after 12/21/05].
____ If any leaks were found, the name or location of the components involved are listed. [40CFR 63.324(d)(3)]
____The dates of repair and records of written or verbal orders for repair parts are available. [40CFR 63.324(d)(4), 63.322(k)]
Refrigerated Condenser
____If a refrigerated condenser is used, the logs of the temperature monitoring results are available. [40CFR 63.324(d)(5)]
____As of 7/28/08 sources should include weekly documentation of the high and low pressure during the drying phase (if equipped with a pressure gauge, if not record temperature), rather than the exit temperature as previously required.[40CFR 63.323(a)(1)(i)]
Carbon Adsorber
____If a carbon adsorber is used the logs of the colorimetric detector monitoring results are available. [40CFR 63.324(d)(6)]
____Weekly leak testing date and perc concentration shall be recorded.[40CFR 63.322(k)]
REPORTING:
____Initial report has been sent to EPA and the Division. [40CFR 63.324(a)]
____A compliance report for control requirements has been submitted to the Division. [40CFR 63.324(b)]
NOTIFICATION
____On or before July 28, 2008, a Notification of Compliance Status form must be submitted to EPA and KDHE-BAR.(40CFR 63.324(f))
Page 1 of 4