From: 	Chris Sarsony, HDR|e2M

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

Re:  	September 1, 2009 Meeting Between the U.S. EPA and Plymouth Tube
Inc. Regarding the Halogenated Solvent Cleaning Reconsideration

Date: 	September 9, 2009

On September 1, 2009, a teleconference meeting was held between the U.S.
Environmental Protection Agency (EPA) and representatives from Plymouth
Tube, Inc. - a narrow tube manufacturer.  The meeting participants are
listed below 

Name	Organization

Tim Benner	EPA/ORD

Susmita Dubey	EPA/OGC

Amy Hambrick	EPA/OAQPS

Ann Johnson	EPA/OPEI

Elaine Manning	EPA/OAQPS

Dennis Pagano	EPA/OAQPS

Jim Robellard	Plymouth Tube, Inc.

Chris Sarsony	HDR|e2M Inc.

Kim Teal	EPA/OAQPS



Meeting Agenda:

1.	Introductions and Meeting Purpose

2.	Issues for Discussion

3.	Open Discussion	

Meeting Summary:

Introductions and Meeting Purpose

Ms. Hambrick of the U.S. EPA began the meeting with introductions and by
stating the purpose for the meeting.  The meeting was as a follow up to
Plymouth Tube’s February 4, 2009 public comments on the October 20,
2008, Proposed Notice of Reconsideration and Request for Public Comment
for Halogenated Solvent Cleaning (73 FR 62384).  Specifically, EPA
wanted to obtain clarification and additional details regarding Plymouth
Tube’s products, manufacturing process, halogenated solvent cleaning
machines, and trichloroethylene (TCE) emission controls.  

Ms. Hambrick indicated that 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

Background on Plymouth Tube’s operations at the Salisbury, Maryland
facility.

The Plymouth Tube Salisbury Division began operations in 1982.  At the
Salisbury facility Plymouth Tube manufactures stainless steel tubing for
the following markets:

Aerospace (jet engines, etc) – 30% of their sales

Commercial, including satellite components – 30% of their sales

Medical (stents, etc.) – 10% of their sales

Nuclear (submarines, power generation, etc.) – 30% of their sales.

They only make stainless steel tubing.  The tubing is made in lengths
from 10 feet to 148 feet.  The outer diameter (O.D.) of the tubing
ranges from 1/8 inch to 1 inch.  There can be a multitude of lengths and
O.D. combinations within the above ranges.  

Their starting stock tube has an O.D. of 1 ¾ inch and a ¼ inch wall
thickness.  All their tubing is drawn from this starting stock.  Every
time the tube is drawn it gets longer.  They buy the starting stock by
the pound but sell the tubing they manufacture by the foot.  Drawing the
tubing from a 1 ¾ inch O.D. to a 1 inch O.D. may increase the tubing
length from about 40 feet to about 60 feet.  Drawing the tubing from a 1
¾ inch O.D. to a 1/8 inch O.D. may increase the tubing length to about
4,000 feet.  

Plymouth’s non-nuclear tubing is sold in 20 foot lengths; however, the
process non-nuclear tubing is being degreased and cleaned at 60 foot
lengths.  The nuclear tubing which also has a small OD and small ID,
reaches lengths within a range of 120 to 148 feet.  This nuclear tubing
is coiled in 11 foot diameter coils, so that it can be transported
effectively and shipped all over the United States and abroad. No tube
bending is performed at their facility.  

Their medical tubing is typically ¼ inch O.D. and smaller and has the
smallest O.D. and the thickest wall.  Therefore, their medical tubing
has a very small inner diameter (I.D.).  Some of their nuclear tubing
also has a very small O.D.

Was the reduction in TCE emissions from CY2003 to CY2004 the result of
installing new cooling coils on VD-1, or was this due to some other
effect?

The addition of the cooling coils on VD-1 played a big part in the
reduction of emissions in CY2004.  They had noticed that the cooling
zone temperature was steadily increasing over time.  The addition of the
cooling coils reduced the cooling zone temperature from around 55-56
degrees F to less than 50 degrees F.  Another factor affecting emissions
during CY2004 was the fact that they were manufacturing larger tubing
sizes that year.  This would have the effect of reducing TCE emissions. 


If the cooling coils were effective in reducing emissions on VD-1, why
weren’t new cooling coils installed on the large cleaning machine
VD-2?

The larger cleaning machine (VD-2) has not been used in about 7 years
(since 2002).  

Description of the solvent cleaning machines at Plymouth Tube’s
Salisbury, MD facility.

Cleaning Machine	

Size

(L x W x D)	

Solvent Capacity	Approximate Cost to Fill with TCE

VD-1	60ft  x 3ft x 15ft	6,600 gallons	$62,000

VD-2	62ft x 5ft x 15ft	12,125 gallons	$120,000

   

What caused TCE emissions to increase from CY2004 to CY2005?

The cooling coils added to VD-1 were efficient the first couple of
years, but then their efficiency dropped off.  Out of 8 cooling coil
passes only 6 of the cooling coil passes were working.  The cooling
coils were being damaged by the tubing loads going in and out of the
cleaning machine.  Also, starting in CY2005 the size of the tubing that
they manufactured got smaller, and thus, TCE emissions increased.   

  

What were the TCE emissions from the Salisbury, MD facility in CY2008?

The TCE emissions from the Salisbury, MD facility in CY2008 were 37.3
tons.  All of these emissions were from VD-1.

Has Plymouth Tube explored the use of alternative solvents, such as nPB?

Plymouth Tube indicated that they conducted bench scale tests with nPB. 
They use chlorinated paraffin based drawing lubricants that are cleaned
best at temperatures greater than 160 degrees F.  They found that nPB
left behind some lubricant residue that required a second cleaning. 
Plymouth believes that this is a result of nPB’s boiling point at 140
degrees F as compared to TCE, which boils at 188 degrees F.  The higher
boiling temperature of the TCE helps to melt the chlorinated paraffin. 
Plymouth explained that the combination of the long length and small
ID’s of their tubes will inhibit the effectiveness of nPB for removal
of the chlorinated paraffin from the middle of the tube ID’s. 
Plymouth discussed that a solvent switch to nPB must require NRC
approval.    

Plymouth stated that the nuclear tubes must pass several cleanliness
tests and inspections prior to shipment.  Other types of tubing also has
similar product-specific requirements regarding the type of cleaning and
product used, many of which specify TCE vapor degreasing.  Any solvent
switching would require Plymouth to conduct product tests and customer
approval.   

Plymouth Tube reports their research has shown nPB also costs about
twice as much as TCE (TCE costs about $0.75/lb, whereas nPB is about
$1.42/lb).  Though cost is factor, Plymouth Tube stated the technical
feasibility issues and client requirements for TCE have been foremost in
their consideration of using nPB.

Can Plymouth Tube describe the carbon adsorption system (CAS) and its
control efficiency?

The CAS has three carbon beds containing a total of 10,800 lbs of
carbon.  When they talked about expanding their CAS system in their
comment letter, they were referring to adding a lip exhaust that would
go to the CAS.  However, the benefits of the lip exhaust would be
marginal because it would increase the flow of air across the solvent
cleaning machine.  Plymouth Tube’s support equipment supplier reported
that the addition of a lip exhaust on their degreaser would cause a
draft across the edge of the tank thus drawing the vapors up above the
cooling coils limiting their effectiveness. 

Plymouth Tube will email the control efficiency data for their CAS to
EPA.  This is the estimated capture efficiency of 90% and removal
efficiency 98% of Plymouth’s carbon units

Please describe the cleaning process at Plymouth Tube’s Salisbury, MD
facility?

They load approximately 2,000 lbs of product into the machine at one
time.  The cover to the cleaning machine closes when the product is in
the machine.  The product is tipped into the vapor, then into the
liquid, and then into the vapor again.  At the end of the cleaning cycle
the product is held in the freeboard area of the cleaning machine to
allow solvent to drain back into the tank.  The cover to the cleaning
machine is then opened and the product is removed from the cleaning
machine.  The product is then placed into the draft tanks for 30
minutes.  The draft tanks pull a vacuum and route the captured air to
the CAS.  The air from the room is also routed to the CAS.

Has Plymouth Tube looked at replacing their open top vapor cleaning
machines with vacuum-to-vacuum (VTV) cleaning machines?

Plymouth Tube explored VTV technology which included requesting
estimates and proposals for installing the technology.  During this time
only one company, Tiyoda-Serec would entertain the prospect of building
a unit of the size that Plymouth would need. Tiyoda-Serec proposed
building an end loading machine with an interior space 60 feet long and
three feet in diameter.  Plymouth stated that neither this vendor, nor
any other VTV supplier ever had built a machine of this size and scale.

Plymouth Tube is challenged by the size and loading requirements of VTV
machines which would require significant modifications to the facility,
including construction of a new addition to handle the lateral movement
of the product for loading and unloading VTV machines.

Plymouth Tube further found, in consultation with Tiyoda-Serec that the
combination of machine length and diameter would expand the current
cleaning time from 45 minutes per cycle to 1 hour and 30 minutes per
cycle.  Because of the 1.5 hour cleaning cycle of the VTV machines,
Plymouth Tube would need two of these hypothetical machines to maintain
their current production levels.  Each machine was found to cost more
than one million dollars.  Plymouth feels that large scale VTV
technology is not proven.

Plymouth felt that installation of VTV machines and the redesign of
their building was economically and technically unfeasible.  

Does Plymouth Tube have any pictures of the cleaning machines at their
Salisbury, MD facility that they could send to EPA?  

Plymouth Tube will send photographs of their cleaning machines.   

 

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