DATE & TIME: 	December 11, 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 OAQPS, HSIA and Representatives from the Narrow Tubing
Industry

December 11, 2006

11:00 a.m. til 2:00 p.m.

Washington, DC

Attendees in person:

Steve Risotto, HSIA

Jon McChesney, Parts Cleaning Technologies

David R. Crandell, Parts Cleaning Technologies

Jeff Farina, Accellent Endoscopy

Wendy Cooper, Accellent Endoscopy

Carol McCabe, Manko, Gold, Katcher & Fox

John Coates, Hardy and Harman

Gary Johnson, Tube Methods

Matt Courtney, Salem Tube Inc.

Charles Downs, Greenville Tubes

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)

Lynn Dail, OAQPS

Robin Dunkins, OAQPS

Dennis Pagano, OAQPS

Larry Sorrels, OAQPS	

Attendees via conference call:

Winifred Okoye, EPA/OGC

Ann Johnson, EPA/OPEI

Tim Benner, EPA/ORD

Keith Holman, SBA

Joe Johnson, SBA

	The narrow tubing industry and their legal representation came to the
Environmental Protection Agency’s Research Triangle Park Campus to
discuss their comments on the August 17, 2006 proposal of Halogenated
solvents cleaning MACT amendments.  

	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 the narrow tube industry is that the proposed
regulation may generally be suitable to control emissions from a large
segment of affected facilities, yet because of this industry’s
technical specifications, 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.  The
narrow tubing industry provided information of the technical
infeasibility of applying most available emission control technologies
from solvent switching, retrofitting and vacuum to vacuum technology. 
Most methods are infeasible to adapt to the performance, size and
operational requirements of the narrow tube industry.

		EPA provided the recently signed and approved Notice of Data
Availability to the participants that EPA intends to issue public and
would allow these industries to provide specific data and information
that may compel EPA to consider differing standards for these
industries.  The industry is going to provide EPA with additional data
and information on the uniqueness of this industry and what the industry
is capable of doing in regards to reducing total emissions.

