From: 	Chris Sarsony, HDR|e2M

To: 	Amy Hambrick, U.S. Environmental Protection Agency

Re:  	August 6, 2009 Meeting Between the U.S. EPA and the Pennsylvania
Department of Environmental Protection, Penn Future, and Earth Justice
regarding the Halogenated Solvent Cleaning Reconsideration

Date: 	August 12, 2009

On August 6, 2009, a teleconference meeting was held between the U.S.
Environmental Protection Agency (EPA) and representatives from the
Pennsylvania Department of Environmental Protection (PA DEP), Penn
Future, and Earth Justice to discuss PA DEP’s comments on the October
20, 2008, Proposed Notice of Reconsideration and Request for Public
Comment for Halogenated Solvent Cleaning (73 FR 62384).  The meeting
participants are listed below.

Name	Organization

Tim Benner	EPA/ORD

Francine Carlini	PA DEP

Ron Davis	PA DEP

Susmita Dubey	EPA/OGC

Robin Dunkins	EPA/OAQPS

John Guth	PA DEP

Amy Hambrick	EPA/OAQPS

Ann Johnson	EPA/OPEI

Elaine Manning	EPA/OAQPS

Charley McPhedran	Penn Future

Dennis Pagano	EPA/OAQPS

Jim Pew	Earth Justice

Krish Ramamurthy	PA DEP

Bo Reiley	PA DEP

Chris Sarsony	HDR|e2M Inc.

Kim Teal	EPA/OAQPS



Meeting Agenda (see attachment for detailed agenda):

1.	Introductions and Meeting Purpose

2.	Issues for Discussion

3.	PA DEP Questions/Concerns

4.	Open Discussion

Meeting Summary:

 Introduction and Meeting Purpose

Ms. Hambrick of the U.S. EPA began the meeting with introductions and by
stating the following purpose for the meeting: “To discuss new
information that the PA-DEP and other commenters provided on the
Halogenated Solvent Proposed Rule regarding technologies used by certain
narrow tube solvent cleaning machines located at facilities within
Pennsylvania.”

Ms. Hambrick indicated a meeting summary would be developed for the
meeting and this summary would be made available to the public in the
docket.  

Issues for Discussion

Clarification of PA-DEP position on the proposed reconsideration options
for narrow tube manufacturers, including achievability of proposed
limits as well as PA-DEP recommended limit.

PA DEP stated that in their public comment they were basically
commenting on the three regulatory options that were proposed by EPA in
the October 20, 2008 proposal.  Of the three Options presented, PA DEP
prefers Options 2 and 3, which would both require a 60,000 kg Methylene
Chloride Equivalents (MC EQ) limit for tube manufacturers.  PA DEP does
not support Option 1, which would not require any additional control for
narrow tube manufacturers beyond what is required in the original
NESHAP.  

PA DEP stated that they recognize some tube manufacturing facilities,
such as Accellent, may have difficulty in achieving a 60,000 kg MC EQ
limit.  Therefore, they proposed in their comments that EPA add a
provision that would require tube manufacturing facilities that exceed
the 60,000 kg MC EQ limit to achieve an 80 percent overall control
efficiency and conduct a site-specific risk assessment.   

PA DEP clarified that the 80 percent control number was based on Option
3 for web cleaning machines and was not based on any new analysis
specific to tube manufacturing facilities.  

PA DEP stated that when it asked tube manufacturing facilities to
achieve voluntary halogenated solvent emission reductions, not all
facilities chose the same approach.  Some facilities, such as Superior
Tube and Tube Methods, chose to switch from TCE to n-Propyl Bromide
(nPB).  Other facilities, such as Accellent (new carbon adsorption
system) and Salem Tube (new vacuum-to-vacuum machine), chose to install
new equipment.  



Compliance time frame.

EPA asked PA-DEP if and how quickly the narrow tube industry technology
was changing and improving such that companies like Accellent could have
additional controls available to them if given more time.  PA-DEP
responded that they were unsure of how quickly the technology was
changing and for a facility like Accellent they have retrofitted
controls to existing machines.    

Technical differences between facilities manufacturing the smallest
tubes, those used in medical devices, and larger tubes.

The majority of the tubing made by Accellent is for medical devices
(intra-body use), and therefore, is subject to high standards of
cleanliness.  The products they manufacture are subject to strict FDA
and client specifications for quality.  Therefore, any change they make
in the manufacturing process must go through the FDA approval process,
which can take years.  Accellent determined through their own bench
scale tests that nPB would not achieve to necessary level of cleanliness
for their products.  

A noted difference between Accellent and Superior Tube is that Accellent
produces end products, whereas Superior Tube produces tubing that
typically undergoes additional manufacturing at their client’s
facility.     

EPA asked PA-DEP if it might make sense to subcategorize narrow tubing
manufactured for medical uses.  PA-DEP responded that it may make sense
to subcategorize medical tubing, but did not know what basis should be
used to define this subcategory.

Information on Salem Tube’s (Greenville, PA) new vacuum cleaning
system.

PA-DEP indicated that Salem Tube installed a new vacuum-to-vacuum
cleaning machine in late 2007 or early 2008.  The new cleaning machine,
which can clean tubes up to 45 feet in length, dramatically decreased
their TCE emissions.  For example, Salem Tube’s total emissions for
June 2009 were 0.5 lbs, whereas in 2002 their emissions were over 5 tons
per month.  

EPA asked PA-DEP if vacuum-to-vacuum technology could be used at
Accellent’s facility to reduce their emissions.  PA-DEP indicated that
Accellent cleans tubing that is narrower (some narrower than a human
hair) and longer (coils of up to 3,000 feet of tubing).  Accellent has
determined that it is not technically feasible to use vacuum-to-vacuum
technology.  Additionally, it is not economically feasible for Accellent
to use vacuum-to-vacuum technology.  Based on Accellent’s analysis
they would have to install multiple vacuum-to-vacuum machines to meet
their production rates.  Furthermore, Accellent would have to construct
a new building to accommodate the extra equipment and the end loading
design of large vacuum-to-vacuum machines.  

PA-DEP stated that they will send EPA a spreadsheet summarizing solvent
cleaning equipment cost data that they have collected from Superior
Tube, Accellent, and Salem Tube.   

Recent data capture and control efficiency data from Accellent.

In 2007 and 2008, Accellent installed carbon adsorption systems (CAS) on
their two halogenated solvent cleaning machines.  Accellent has tried to
optimize both systems as much as possible by improving their capture
efficiency.  Currently, the CAS on Unit One is achieving an overall
control efficiency of  approximately 75% and the CAS on Unit Two is
achieving an overall control efficiency of approximately 35%.  The
overall control efficiency takes into account both the capture
efficiency and the control efficiency of the CAS.  The percent
efficiencies were determined based on a material balance calculation. 
Accellent continues to look for ways to optimize the performance of both
units, and may even evaluate changes to the roof of their building to
improve the capture efficiency for the CAS on Unit Two.  

Information on production levels, e.g., in permits.  

PA DEP indicated that there are no specific production limits in the
tube manufacturer permits; however, there are limits to the amount of
TCE they can emit.  In a sense, these TCE emission limits could be
viewed as restricting production.  Accellent has voluntarily accepted a
reduction in their TCE emissions from 94 tons/year to 45 tons/year.  

PA-DEP air monitoring program.

PA DEP has air monitors in Collegeville, PA in the vicinity and downwind
of the Accellent and Superior Tube facilities.  The most recent ambient
air data for TCE is much lower than previous levels and is more
consistent with levels in other areas of the state.  PA DEP has seen a
strong cause and effect relationship between the voluntary TCE
reductions at Accellent and Superior Tube and the ambient levels of TCE
in Collegeville, PA.  

Title V permits for Summerville Tube (Scottdale, PA) and Accellent
(Collegeville, PA).

PA DEP agreed to send EPA copies of the most current Title V permits for
Salem Tube, Tube Methods, Summerill Tube, and Accellent. 

EPA indicated that very little is known about Summerill Tube (Scottdale,
PA) and asked PA DEP what they know about this facility.  PA DEP
indicated that Summerill Tube makes an intermediate tubing product, not
a finished product.  Summerill Tube does not make any medical tubing. 
The Summerill facility is older, had housekeeping issues, and may be
shut down.  PA-DEP will send EPA a copy of Summerill Tube’s permit,
which was modified recently. 

Closing Statements

EPA indicted that if additional options for the narrow tub industry
(i.e., options not proposed in the October 20, 2008 proposal) are
considered, then a supplemental proposal will have to be published.  The
publication of a supplemental proposal will delay the publication of the
final rule.  



AttachmentsAgenda

EPA Halogenated Solvent Reconsideration Proposal Workgroup

Meeting with the State of Pennsylvania Department of Environmental
Protection

August 6, 2009

9:00 am to 10:00 am

Conference Line: 919-541-4332/ Room: E141B

Introductions & Meeting Purpose

Introduce meeting participants

To discuss new information that the PA-DEP and other commenters provided
on the Halogenated Solvent Proposed Rule regarding technologies used by
certain narrow tube solvent cleaning machines located at facilities
within Pennsylvania.  

Issues for Discussion. 

Clarification of PA-DEP position on the proposed reconsideration options
for narrow tube, including achievability of proposed limits as well as
PA-DEP recommended limit

Compliance time frame.

Technical differences between facilities manufacturing the smallest
tubes, those used in medical devices and larger tubes.

Information on Salem Tube’s (Greenville, PA) new vacuum cleaning
system.

Recent data capture and control efficiency data.

Information on production levels, e.g., in permits.  

PA-DEP air monitoring program.

Title V permits for Summerville Tube (Scottdale, PA) and Accellent
(Collegeville, PA).

PA-DEP any questions/concerns to communicate with EPA? 

Please share by noon Wednesday August 5, 2009.  PA-DEP did not add any
items. 

Open discussion for any additional questions or discussion points

Meeting adjourned.  Thank you! 

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