DATE & TIME: 	November 1, 2006, 11:00 a.m.

SUBJECT:   	Ex-Parte Communications on Halogenated Solvent Cleaning rule

FROM:		H. Lynn Dail

TO:		Docket EPA-HA-OAR-2002-0009

Meeting with Bill Wehrum

November 21, 2006

1:00 p.m. til 1:40 p.m.

Washington, DC

Attendees in person:

Bill Wehrum, EPA/OAQPS

Wendy Blake, EPA/OGC

Winifred Okoye, EPA/OGC

Ann Johnson, EPA/OPEI

Carl Mazza, EPA/OAR

Steve Risotto, HSIA

W. Caffey Norman, Patton & Boggs (representing HSIA)

Hoai Hyunh, Aerospace Industries Association

Edward Ferguson. Boeing

Greg Sanks, Spirit AeroSystems

John Stedge, Superior Tube

Mark Hammond, Drinker Biddle & Reath (representing Superior Tube)

Dwayne Davis, Plymouth Tube

Steven Lemon, Jones Lemon Graham & Norman (representing Plymouth Tube)

Robert Fensterheim, American Safety Razor

Attendees via conference call:

Steven Page, OAQPS

Peter Tsirigotis, OAQPS

Robin Dunkins, OAQPS

Ken Hustvedt, OAQPS

Dennis Pagano, OAPOS

Dave Guinnup, OAQPS

Fred Thompson, OAQPS

Lynn Dail, OAQPS

	Various industries that use halogenated solvent cleaning techniques to
degrease met with Bill Wehrum to discuss their salient comments on the
August 17, 2006 proposal of Halogenated solvents cleaning MACT
amendments.  The industries commented on EPA’s dependence on the NEI
database. The attendees represented narrow tube manufacturing, aerospace
manufacture and maintenance and continuous web cleaning facilities or
industry associations.  They provided their issues dealing with EPA’s
dependence on NEI database, EPA’s risk analysis and economic analysis,
small business impacts and compliance schedule.  The participants also
indicated eagerness to discuss alternative approaches to reducing
emissions.  

	The participants presented their MS Power Point display that will be
embedded in this document and installed in the docket.  Their primary
concerns centered around the proposed emission limits and these
industry’s ability to comply with the limits, the fact that EPA
underestimated the costs associated with reducing emissions, the fact
that there are many technical issues and infeasibilities in methods
available to reduce emissions and the time limitations of the proposal
to attempt to comply with the standards.

	The main message from these industries is that the proposed regulation
may generally be suitable to control emissions from a large segment of
affected facilities, yet because of these industries size and
specialized processes, they are quite divergent from the normal
degreasing operation and EPA should consider them as special cases apart
from the proposed MACT amendments.

	EPA provided information to the attendees that EPA intends to issue a
Notice of Data Availability to the public that would allow these
industries to provide specific data and information that may compel EPA
to consider differing standards for these industries.  

	All parties agreed to have meeting ASAP, around the first or second
week of December   

OAQPS agrees to meet with the industry prior to publishing the Notice of
Data Availability.

 

 

