The HSC rule assistant is a tool that you can use to select and display the pertinent parts of the HSC emissions standards rule that apply to a particular type of solvent cleaning machine. The NESHAP emissions standard for Halogenated Solvent Cleaning (HSC) Machines was used as the first example of this type of a "smart system". The system will prompt you for answers to questions about the equipment and types of existing control devices in use at the operation and will guide you to the requirements for compliance with the rule. Because the HSC NESHAP has multiple compliance options the HSC rule assistant can be used to show you multiple options for compliance.
EPA is continually looking for opportunities to facilitate compliance with and enforcement of the air emissions standards. This is particularly true for NESHAP and MACT standards that are being prepared in response to Section 112 of the Clean Air Act (CAA). The CAA requires that standards be developed to regulate air emissions of 189 specific chemical substances that were identified as Hazardous Air Pollutants (HAP). EPA has promulgated a large number of these rules, and continues to work on many more. Many of the rules include a significant amount of flexibility, in the form of multiple compliance options, in an attempt to lessen the regulatory and cost burdens for industry and small business to comply with these rules. Often the advantage offered by this flexibility comes with a disadvantage in terms of complexity in the rule language. The rules often have multiple options with associated requirements for monitoring, reporting, and record keeping that are located intermittently through the rule. Many of the rules refer to the general requirements, the requirements of other NESHAP rules, and sometimes to requirements of rules that have been developed under other environmental legislation.
Historically, EPA has published guidance documents, enabling documents and other materials to help both the regulated community and the regulatory implementing agencies to understand the rules and how they are to be implemented. Computer systems in general, and Internet systems in particular, offer another forum for this type of assistance. HSC Rule Assistant was prepared as a Pilot Demonstration System to serve as an example of the possibilities for this kind of tool and to measure the response of the user community to determine if additional computer based guidance materials would be useful.
The rule assistant is constructed to be self-guiding. You do not need to have any special computer skills. All of the instructions necessary to use the system are presented to you. The program has links to definitions for key words and phrases, so you do not need to be an expert in the construction, operation or inspection of cleaning machines to use the system. The program does require specific information about the operation of the machine, such as dimensions, age, and some operating parameters. You will find most of the information you need in manuals and other materials provided by the manufacturer. This guidance presents explanations of important features of the program. You can reference it to find specific features and to prepare you for what to expect when you use the program.
Critical questions will be displayed and you will be prompted to supply information about the machine to make applicability determinations and to establish whether the operation is subject to requirements for new or existing operations. You will also be asked to select the appropriate machine and design type and to supply additional information on critical dimensions, existing control features, and/or operational practices. Finally, the program will list all of the requirements that apply to the particular piece of equipment that you described. The program will give you several output options including: a) requirements in each of the four major categories; standards, monitoring, reporting and record keeping, b) all requirements listed together and, c) a summary table of the citation numbers of the relevant paragraphs.
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