MEMORANDUM

DATE:		October 2, 2008

SUBJECT:	National Impacts for Proposed Reconsideration  

FROM: 	Chris Sarsony

		engineering-environmental Management (e2M), Inc.

THROUGH:	John Crenshaw

		Eastern Research Group, Inc.

TO:		Lynn Dail

		U.S. Environmental Protection Agency

1.0	INTRODUCTION

On December 2, 1994, EPA promulgated technology-based emission standards
to control hazardous air pollutant (HAP) emissions of halogenated
solvents from halogenated solvent cleaning.  Pursuant to the Clean Air
Act (CAA) section 112(f), EPA evaluated the remaining risk to public
health and the environment following implementation of the
technology-based rule and determined that more stringent standards are
necessary in order to provide an ample margin of safety to protect
public health.  

On August 17, 2006, EPA published proposed standards that provided
further reductions of methylene chloride (MC), perchloroethylene (PCE),
and trichloroethylene (TCE) beyond the 1994 national emission standards
for hazardous air pollutants (NESHAP), through application of a
facility-wide total MC, PCE, and TCE emission standard.  The EPA
received comments on the proposed rule from industry, states, solvent
manufacturers, industry associations and district air associations. 
Industry’s comments were primarily submitted by four specific sectors:
narrow tubing manufacturing facilities (tube), facilities that
manufacture specialized products requiring continuous web cleaning
(web), aerospace manufacturing and maintenance facilities (aerospace),
and military depot maintenance facilities.  Comments and data submitted
by the four industry sectors focused on the unique nature and size of
the halogenated solvent cleaning machines used in the cleaning
operations.  

A Notice of Data Availability (NODA) was issued on December 14, 2006 (71
FR 75184) to collect additional information from these four industry
sectors.  As a result of the NODA, EPA received significant comments
from responders associated with the above-noted industries, industry
associations, and commenters that were not associated with the
above-noted industries.  They provided additional data and information
on control costs and the technical feasibility of additional controls
that were directly relevant to the promulgation of the proposed
facility-wide emission limits.  

On May 3, 2007, EPA promulgated the final rule titled:  National
Emission Standards for Hazardous Air Pollutants (NESHAP):  Halogenated
Solvent Cleaning (the Halogenated Solvent Cleaning rule)
(72 FR 25138), pursuant to sections 112(d)(6) and 112(f) of the Clean
Air Act (CAA).  The Halogenated Solvent Cleaning rule set facility-wide
emission limits for certain halogenated solvent cleaning machines and a
May 3, 2010, compliance deadline.

	Following promulgation of the Halogenated Solvent Cleaning rule, the
EPA Administrator received several petitions for reconsideration,
pursuant to CAA section 307(d)(7)(B).  On August 15, 2007, EPA informed
petitioners of its intent to initiate notice and comment rulemaking to
address the Petitions.  

The purpose of this memorandum is to summarize the nationwide cost and
emission impacts associated with the control options presented in the
proposed notice of reconsideration of the final rule.  In Section 2.0
the changes to the impacts analyses are summarized.  Section 3.0
contains a discussion of the levels and format of the control options. 
Section 4.0 summarizes the development of costs and percent emission
reduction estimates for individual control techniques.  Section 5.0
summarizes the results of the cost and emission reduction analysis for
all of the control options.



CHANGES TO IMPACTS METHODOLOGY RESULTING FROM PETITIONS FOR
RECONSIDERATION

Petitions for reconsideration filed in response to the May 3, 2007 final
Halogenated Solvent Cleaning rule (72 FR 25138) were received from the
Commonwealth of Pennsylvania Department of Environmental Protection,
Natural Resources Defense Council, Citizens for Pennsylvania’s Future,
Sierra Club, several state and federal legislators, and the Governor of
the Commonwealth of Pennsylvania.  The EPA has evaluated the information
provided in these letters along with additional information obtained
from publically available sources and contacts with manufacturers of
solvents and control equipment.  Based on the information collected, 
EPA determined that the changes summarized in Table 1 would be
incorporated into the impacts analysis for the proposed reconsideration
of the final rule.

Unless a change is noted specifically in this document, the cost and
environmental impacts were determined using the same approach presented
in the April 13, 2007 memorandum titled “National Impacts for Final
Rule.”  Where analyses remain unchanged, the reader should refer to
the April 13, 2007 memorandum for a more complete discussion of the
analysis.  Specifically, the April 13, 2007 memorandum describes the
development of the 2002 degreasing database; the identification of
facilities within the web, tube, aerospace, and military depot
populations; the calculation of methylene chloride equivalent factors
based on the unit cancer risk; the development of the costs and emission
reduction estimates for the controls used for the main population and
the aerospace, military depot, and web populations; and the approach
used to apply costs for the individual controls to determine costs for
specific facilities. 

Table 1 - Changes to Cost and Emissions Impacts Methodology Since 

Publication of the Final Rule

Change	Effect	Notes

A web cleaning control option was added that requires 80% control only
for those facilities with a methylene chloride equivalent (MC EQ) above
60,000 kg/yr.	Two facilities (Somers Thin Strip and Arcos Alloys) have
MC EQ below 60,000 kg/yr.  Therefore, there are no additional cost
impacts for these two facilities.  Costs and emission reduction impacts
were calculated for the other 6 web facilities at 60,000 kg/yr MC EQ.  
This option was added to focus emission reductions on the highest
emitting web cleaning facilities.

For tube manufacturers the following additional controls were added:

Vacuum Machine

CAD System

Switching from TCE to n-propyl bromide (nPB)	Previously, the only known
viable control for tube manufacturers was the addition of a side
chamber.  The addition of  vacuum machines, CAD systems, and switching
to nPB means that tube manufacturers can significantly or even totally
eliminate their halogenated HAP emissions.  	Controls added as a result
of information obtained from tube manufacturers after publication of the
final rule that indicated these controls were being used at tube
manufacturing facilities.   

For facilities with web cleaning machines the following additional
controls were added:

CAD System

Switching from TCE to n-propyl bromide (nPB)	Previously, the only known
viable control for web facilities was the addition of automated gates,
lengthening the cleaning process area, providing an additional enclosure
around all distillation units, and modifying the capacity and process
structure of existing CADs.  

The addition of  new CAD systems and switching to nPB means that tube
manufacturers can significantly or even totally eliminate their
halogenated HAP emissions.  	Controls added as a result of information
obtained after publication of the final rule that indicated that CAD was
being used at web facilities.  Information also indicated that nPB is an
acceptable substitute for TCE and is compatible with aluminum and steel.
 

CONTROL OPTIONS

Table 2 shows the control options that were evaluated for the proposed
notice of reconsideration of the final rule.  Table 3 shows the control
levels by solvent and for facilities using multiple solvents.  All of
the options evaluated are beyond the 1994 MACT levels.  The control
options for the main population, aerospace facilities, military depots,
and tube are in the form of facility-wide solvent cleaning emission
limits that apply to all PCE, TCE, and MC emissions from solvent
cleaning operations at a facility.  The control option evaluated for
facilities with web cleaning machines applies only to facilities with a
methylene chloride equivalent of greater than 60,000 kg/year.  If the
web facility’s MC EQ exceeds 60,000 kg/yr, the facility is required to
achieve an overall control efficiency of 80% for solvent cleaning
operations.  

Table 2 - Emissions Control Options Evaluated for the Proposed Notice of
Reconsideration in kg/yr MC Equivalents

Degreasing Population	

Option 1	

Option 2	

Option 3

Main Degreasing Population, (excludes those below)	60,000	60,000	60,000

Military Depot	100,000	100,000	100,000

Web	No Additional Control	No Additional Control	For facilities >60,000,
must achieve an 80% control efficiency 

Tube	No Additional Control	60,000	60,000

Aerospace	No Additional Control	No Additional Control	100,000



Table 3 - Specific Control Level Components of Options 1, 2, and 3
Evaluated for the Proposed Notice of Reconsideration 

Solvents Emitted	

Control Levels in kg (lbs)

	Main Population	Military Depot	

Web	

Tube	

Aerospace

PCE only	4,781 (10,540)	7,968 (17,567)	For Facilities with MC EQ above
60,000, must achieve an 80% overall control efficiency	4,781 (10,540)
7,968 (17,567)

TCE only	14,085 (31,051)	23,474 (51,751)

14,085 (31,051)	23,474 (51,751)

MC only	60,000 (132,276)	100,000 (220,460)

60,000 (132,276)	100,000 (220,460)

Multiple Solvents - MC Equivalent 	60,000 (132,276)	100,000 (220,460)

60,000 (132,276)	100,000 (220,460)



DETERMINATION OF COSTS FOR INDIVIDUAL CONTROLS

	Table 4 shows the individual controls, percent emission reductions, and
associated costs that were used for evaluating the cost impacts on the
main population of cleaning machines.  The percent emission reduction
values and costs shown in Table 4 have not changed as a result of the
reconsideration.  

Table 4 - Controls Beyond MACT Applied to Main Population 

Control Type	Description	% Emission Reduction (a) 	Total Capital Costs
Annualized Capital Costs	O&M Costs	Total Annual Emission Control Costs
(b)

Control Equipment Retrofits	1.5 Freeboard Ratio (1.5FBR), Working Mode
Cover (WC), Freeboard Refrigeration Device (FRD)	50	$25,645	$2,821
$2,015	$4,836

	1.5 Freeboard Ratio (1.5FBR)	30	$20,380	$2,242	$0	$2,242

	Carbon Adsorption System (CAD)	30	$162,687	$17,896	$8,948	$26,844

Solvent Switching	PCE to MC	11	$15,677	$1,725	$928	$2,653

	PCE to TCE	31	$0	$0	($2,022)c	($2,022)

	TCE to MC	(29)	$15,677	$1,725	$2,950	$4,675

Machine Replacement	Vacuum to Vacuum Cleaning Machine	95	$399,000
$37,663	$18,832	$56,495



a -  For the solvent switching options the percent emission reduction
reflects the amount of new solvent emitted relative to the amount of old
solvent emitted.  For the TCE to MC option it is estimated that
emissions of MC would be 29% more than the original TCE emissions.  The
primary benefit for the solvent switching options results from the lower
MIR cancer risk for the new solvents.  If the MIR values are taken into
account along with the change in emission reduction, the resulting
decrease in cancer risk are as follows:

	PCE to MC = 93%

	PCE to TCE = 77%

	TCE to MC = 70%

b – Does not include cost savings due to reduced solvent purchases. 
The solvent savings were calculated for each specific unit based on the
volume of solvent emissions reduced and the cost of the specific solvent
in $/gal. 

c – Values in ( ) indicate a cost savings.

	Table 5 shows the individual controls that were applied when evaluating
the cost impacts on the web, tube, aerospace, and military depot
cleaning machine populations.  The percent emission reduction estimates
and costs have not changed for the controls applied to the aerospace,
and military depot populations.  For the tube population, three new
controls were added as a result of information obtained since the
publication of the final rule.  These controls are the replacement of
existing cleaning equipment with a new vacuum-to-vacuum cleaning
machine, the addition of carbon adsorption, and switching from TCE to
n-propyl bromide (nPB).  For facilities with web cleaning machines, two
new controls were added as a result of information obtained since the
publication of the final rule.  These controls are the addition of
carbon adsorption and switching from TCE to n-propyl bromide (nPB).  

Table 5 - Controls Beyond MACT Applied to the Web, Tube, Aerospace, and
Military Depot Cleaning Machine Populations

Industry Segment	Description	% Emission Reduction	Total Capital Costs
Annualized Capital Costs	O&M Costs	Total Annual Emission Control Costs
(a)

Aerospace	Vacuum Machine - Small - Baskets	95	$150,000	$14,159	$7,080c
$21,239

	Vacuum Machine - Small - Hanging	95	$242,000	$22,867	$11,434c	$34,301

	Vacuum Machine - Large - Baskets	95	$584,000	$55,125	$27,563c	$82,688

	Vacuum Machine - Large - Hanging	95	$788,800	$74,457	$37,229c	$111,686

	Enclosure, parts transporter, CAD, and distillation	50	$237,500	$26,076
$13,038c	$39,114

	Dual-Split Working-Mode Cover and Dual-Bank Freeboard Chillers	25
$44,000	$4,831	$2,416c	$7,247

	Enclosure	15	$108,000	$11,858	$5,929c	$17,787

Military Depot	RETRO - 1.5FBR, WC, FRD (b) 	50	$102,581	$11,284	$8,059
$19,343

Tube	Vacuum-to-Vacuum Cleaning Machine	99	$1,700,000	$160,468	$80,234c
$240,702

	Carbon Adsorption System	90	$1,000,000	$109,795	$54,897c	$164,692

	Switch from TCE to nPB	100	$0	$0	$0	$0

Web	Automated gates 	25	$50,000	$5,490	$2,745c	$8,235

	Carbon Adsorption System	50	$237,500	$26,076	$13,038 c	$39,114

	Switch from TCE to nPB	100	$0	$0	$0	$0

a – Does not include cost savings due to reduced solvent purchases or
cost increases due to the higher cost of solvent.  The solvent cost
savings or increases were calculated for each specific unit based on the
volume of solvent and the cost of the specific solvent in $/gal. 

b – To account for the large size of the cleaning machine the costs
are 4 times those used for the main population).

c – O&M costs were assumed to be equal to half the annualized capital
costs.

	The basis of the percent emission reductions and costs for controls
that have not changed as a result of the reconsideration are explained
in detail in the April 13, 2007 memorandum titled “National Impacts
for Final Rule.”  The basis of the percent emission reductions and
costs for the controls added for the tube population are explained in
the following paragraphs.  As was done previously, all capital costs for
new systems were annualized based on a 20-year equipment lifetime and a
7% interest rate and retrofit equipment was annualized based on a
15-year equipment lifetime and a 7% interest rate.  The equipment
lifetimes were determined based on information from equipment
manufacturers. 

Vacuum-to-Vacuum Cleaning Machine for Tube Manufacturers

	The percent emission reduction and costs for vacuum-to-vacuum cleaning
machines applied to the narrow tube manufacturer population were based
on information obtained from Salem Tube, Inc. for their Greenville, PA
tube manufacturing plant.  Salem Tube, Inc. submitted an application for
an Air Quality Plan Approval to Pymatuning Township on April 13, 2007. 
A revision to the application was submitted by Salem Tube, Inc. to the
Pennsylvania Department of Environmental Protection (PA DEP) on July 24,
2007.  In the application, Salem Tube, Inc. indicates that they will be
installing a vacuum cleaning and degreasing system manufactured by EMO. 
The system includes the following components:

A vacuum tight degreasing tank with lifting/lowering equipment for
vertical inclination of the tank;

Heated flood tank;

Supply unit with solvent evaporator, main distillation, additional
vacuum distillation, filtration, and activated carbon air filter system;

Control system with programmable logic control (PLC) and graphics
display with process visualization; and an

Extraction tank/water separator.

The cleaning tank can hold tubes 4 feet to 44 feet in length.  The tubes
are placed in the degreasing tank in baskets using an overhead crane,
the top cover of the degreasing tank is closed, and air is evacuated
from the chamber.  For immersion cleaning, the tank is flooded with hot
solvent and the tank can be inclined vertically.  When immersion
cleaning is finished the solvent is fed back into the flood tank through
a filter unit.  For vapor cleaning, solvent vapor is fed into the tank
from the solvent evaporator.  When solvent cleaning is complete the
solvent vapor is fed through a condenser and the pure solvent condensate
is fed back into the flood tank.  The tank is then rinsed with fresh air
which is fed to the integrated activated carbon air filter system to
ensure that any remaining solvent vapor is removed from the tank.  The
cleaning chamber is equipped with an infrared spectral photometer to
measure the solvent content at the end of each cycle and will only allow
the chamber to be opened when TCE levels are below 1 gram per cubic
meter. 

	Salem Tube, Inc. estimated that this system will reduce their TCE
emissions to 262 lbs/year.  In the 2002 National Emissions Inventory,
emissions of TCE from this facility were reported at 104,000 lbs/year. 
Therefore, this new system will reduce Salem Tube, Inc.’s TCE
emissions at the Greenville, PA facility by 103,738 lbs/year or over 99%
 [(103,738 lbs/year)/(104,000 lbs/year) = 99.7%].  A 99% reduction was
assumed for the purposes of the impact analysis.  

	Salem Tube reports that the cost for this system will be $1.7 million. 
As with other controls, the annual operating and maintenance costs were
assumed to be equal to half of the annualized capital costs.  

Carbon Adsorption System for Tube Manufacturers

	Superior Tube in Collegeville, PA, and Accellent, Inc., also in
Collegeville, PA, have installed carbon adsorptions (CAD) systems to
control emissions of TCE from their solvent cleaning machines.  

	Superior Tube installed their CAD system in 2001 to control emissions
of TCE from their 661 Vapor Degreaser.  Compliance tests conducted on
Superior Tube’s system showed that it had an average TCE removal
efficiency of 99.2%.  No cost estimate was provided for the installation
of the carbon adsorption unit at Superior Tube.

	In 2007 and early 2008, Accellent, Inc. installed a carbon adsorption
system comprised of four beds.  These beds serve only two of the four
TCE emissions sources – Plant #1 and Plant #2 Vapor Degreasers. 
However, these two sources account for approximately 95% of 2006 TCE
emissions.  In their permit documents Accellent has proposed only a
25-35% reduction in TCE emissions from the installation of this CAD
system.  However, PA DEP believes “this is very conservative, as
emission reductions of 90% or greater usually result from this type of
installation.”  In their January 29, 2007 comment letter, Accellent
provided an estimated cost of $1.8 million dollars for the CAD system on
their two large degreasers.  

	Based on the control efficiency of 99.2% for Superior Tube’s CAD
system and the expectation that Accellent’s CAD system will achieve a
90% control efficiency, a 90% control efficiency was used for the
impacts analysis.  The installed capital cost of a CAD system installed
on a tube manufacturing degreaser was estimated to be approximately $1
million/per unit.  This is a conservatively high estimate based on
Accellent’s costs of $1.8 million for a system serving 2 units.  

Carbon Adsorption System for Web Cleaning Facilities

	Several web cleaning facilities, such as Alcoa (IA), American Safety
Razor (VA), and American Safety Razor (TN) already have CAD systems
installed.  Therefore, CAD is a demonstrated technology for this
population of solvent cleaning machines.  Cost for the purchase of the
CAD systems was not available for these facilities.  Therefore, costs
provided by Delta Airlines were used to estimate the costs for
installing CAD for web cleaning facilities.  The CAD system costs
provided by Delta Airlines include the CAD, an enclosure, distillation
unit, and parts transporter.  The cost estimate provided was for a
“large” solvent cleaning machine with a solvent-air-interface area
of 40ft2.  The percent reduction that Delta Airlines provided for this
system was 50%.  

Switching from TCE to nPB for Tube Manufacturers and Web Cleaning
Facilities

 	Following publication of the final rule, EPA became aware that
Superior Tube, Inc. in Collegeville, PA, and Tube Methods, Inc. in
Bridgeport, PA, were switching from TCE to nPB for their solvent
cleaning operations.  Contacts with manufacturers of nPB 

and information from other sources also indicated that nPB is an
acceptable replacement for TCE in solvent cleaning applications.,

	Since nPB is not a halogenated HAP, a switch from TCE to nPB will
result in a 100% reduction in halogenated HAP emissions.  According to
nPB manufacturers, other than adjusting certain equipment settings, no
equipment purchases or changes are necessary to switch to nPB. 
Therefore, capital equipment costs for switching from TCE to nPB were
estimated to be zero for the cost analysis.  However, nPB does cost
considerably more than TCE - $2.25/lb for nPB versus $1.04/lb for TCE. 
This additional cost was factored into the cost analysis by calculating
an increased solvent cost based on the amount of TCE previously used and
assuming that an equal amount of nPB is used at the higher price. 
Manufacturers of nPB support the assumption that 1 lb of TCE will be
replaced with 1 lb of nPB.,  

Automated Gates for Web Cleaning Facilities

	The costs and emission reduction estimates (25%) for automated gates
were obtained from American Safety Razor. 

	

SUMMARY OF COSTS AND EMISSION REDUCTION RESULTS

	The costs and emission reductions for all units at all facilities were
totaled to yield the total national costs and emission reductions. 
Table 6 summarizes the national capital costs, national annualized
capital costs, national O&M Costs, national solvent savings, and the
total national annual emission control costs for each control level
component.  

	Table 6 shows that the capital costs and O&M costs are the greatest for
the main population at 60,000 kg/yr MC EQ and the tube population at
60,000 kg/yr MC EQ.  However, the main population and tube levels also
have the greatest emission reductions.  The significant solvent savings
for the main population at 60,000 MC EQ offset the capital and O&M costs
to yield a negative net annualized cost of control.  Therefore, for
every ton of emissions reduced, the facilities in the main population
will on average realize savings of $832.  However, for tube the cost
savings do not fully offset the capital costs, and therefore, a cost
effectiveness of $3,238/ton results.  

	The 100,000 kg/yr MC EQ control level for the aerospace and 80% control
efficiency for web result in cost effectiveness values of $1,933/ton and
$2,774/ton, respectively.  These values reflect the fact that the
emission reductions, and thus the solvent savings, do not significantly
offset the capital costs.  The control level of 100,000 kg/yr MC EQ for
military depots shows a savings of $625/ton.  

	Table 7 summarizes the national capital costs, national annualized
capital costs, national O&M Costs, national solvent savings, and the
total national annual emission control costs for each of the three
control options.  The control levels that make up each control option
are shown in Table 2.  The costs for the options are, therefore,
determined by combining the appropriate control level costs in Table 6. 
For example, as shown in Table 2, Option 1 includes the main population
at 60,000 kg/yr MC EQ and the military depot population at 100,000 kg/yr
MC EQ.  All other populations have no additional control under option 1.
 Therefore, to determine the capital costs for option 1, the capital
costs of the main population of $15,117,235 (as shown in Table 6) are
added to the capital costs for military depots of $535,471 (as shown in
Table 6) to yield $15,652,706.  This same process was followed to
determine the costs for all three options as shown in Table 7.

	Table 7 shows that the capital costs, O&M costs, emission reductions,
and the size of the solvent credit increase from Option 1 to Option 2,
and from Option 2 to Option 3.  The lowest cost effectiveness value is
for Option 1 at -$821/ton.  The highest cost effectiveness value is for
Option 3 at $944/ton.    

 	For additional details regarding the development of the costs and
emission reduction impacts for the proposed notice of reconsideration
refer to the cost spreadsheet in the rulemaking docket.  

Description	Main Population without Tube, Web, Aerospace, and Military
Depots - 

60,000 kg MC EQ	Aerospace - 

100,000 kg MC EQ 	Military Depots -

100,000 kg MC EQ	Web -

80% Overall Efficiency for Facilities with MC EQ of > 60,000 MC EQ	Tube
-

60,000 kg MC EQ

1.  National Total Capital Costs	$15,117,235	$9,015,636	$535,471
$1,087,500	$21,924,000



 	 



2.  National Annualized Total Capital Costs	$1,446,203	$869,033	$58,902
$119,487	$2,225,190



 	 



3.  National Total Annual Operation and Maintenance Costs	$722,768
$435,516	$42,068	$59,743	$1,112,595



 	 



4.  National Emission Reduction (true tons)	1,591	324	89	291	921



 	 



5.  National Solvent Credit	-$3,492,430	-$677,887	-$156,631	$628,446
-$355,533



 	 



6.  National Net Annualized Cost of Control ($/yr)

[Annualized Total Capital Costs + O&M Costs + Solvent Credit]
-$1,323,459	$625,662	-$55,662	$807,676	$2,982,253



 	 



7.  National Cost Effectiveness ($/ton)

[Net Annualized Cost of Control/Emission Reduction]	-$832	$1,933	-$625
$2,774	$3,238

Table 6 – Summary of National Costs and Emission Reductions for
Specific Control Level Components of 

Options 1, 2, and 3 Evaluated for the Proposed Notice of Reconsideration

	

Table 7 - Summary of National Costs and Emission Reductions for Options
1, 2, and 3 

Evaluated for the Proposed Notice of Reconsideration

Description	Option 1	Option 2	Option 3

1.  National Total Capital Costs	$15,652,706	$37,576,706	$47,679,842





	2.  National Annualized Total Capital Costs	$1,505,105	$3,730,295
$4,718,815





	3.  National Total Annual Operation and Maintenance Costs	$764,836
$1,877,431	$2,372,690





	4.  National Emission Reduction (true tons)	1,680	2,601	3,216





	5.  National Solvent Credit	-$3,649,061	-$4,004,594	-$4,054,035





	6.  National Net Annualized Cost of Control ($/yr)

[Annualized Total Capital Costs + O&M Costs + Solvent Credit]
-$1,379,121	$1,603,132	$3,036,470





	7.  National Cost Effectiveness ($/ton)

[Net Annualized Cost of Control/Emission Reduction]	-$821	$616	$944



 Memorandum.  Chris Sarsony, engineering-environmental Management, Inc.
to Lynn Dail, U.S. EPA.  Re: National Impacts for Final Rule.  April 13,
2007.

 Joseph P. Pezze, Hillcrest Group Environmental Consultants to
Pymatuning Township Supervisors. Re: Plan Approval Application, New
Vacuum Degreaser, Existing Title V Permit #43-000142.  April 13, 2007.

 Joseph P. Pezze, Hillcrest Group Environmental Consultants to Ms.
Carrie Cooper, P.E., PA DEP NW Regional Office.  Re: Salem Tube, Inc,
New Degreasing System (revisions).  July 24,2007.

 Reference 3, Cover page.

 Reference 2, Section C, Page 16.

 Minor Operating Permit Modification Application, Summary of Requested
Permit Modifications. February 13, 2008.

 “Preliminary Report - Methods for Reducing TCE Emissions at
Accellent, Inc. and Superior Tube Co., Inc., Collegeville,
Pennsylvania,” prepared by Matson & Associates, Inc.  January 2008. 
Page 4.

 “Progress of Emission Reduction Efforts” from PA DEP.  February 13,
2008.

 Docket item EPA-HQ-OAR-2002-0009-0126.    

 Docket item EPA-HQ-OAR-2002-0009-0121.    

Reference 7, Page 7.

 Telecommunication.  Jason Goldsmith, e2M with Jason Ridenour, Parts
Cleaning Technologies, February 18, 2008.  Re: Solvent Switching from
TCE to nPB.  

 ID.

 ID.

 ID.

 Reference 7, Page 7.

 Docket item EPA-HQ-OAR-2002-0009-0125.    

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