From: 	Chris Sarsony, HDR|e2M

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

Re:  	September 3, 2009 Meeting Between the U.S. EPA and Summerill Tube
Inc. Regarding the Halogenated Solvent Cleaning Reconsideration

Date: 	September 10, 2009

On September 3, 2009, a teleconference meeting was held between the U.S.
Environmental Protection Agency (EPA) and representatives from Summerill
Tube, Inc. - a narrow tube manufacturer.  The meeting participants are
listed below.

Name	Organization

Amy Hambrick	EPA/OAQPS

Robin Dunkins	EPA/OAQPS

Ann Johnson	EPA/OPEI

Toni Jones	EPA OAQPS

Elaine Manning	EPA/OAQPS

Dennis Pagano	EPA/OAQPS

Chris Sarsony	HDR|e2M Inc.

Matt Grandinette	Summerill Tube, Inc.

Ernie Stricsek	Summerill Tube, Inc.

Steve Slavonic	Summerill Tube, Inc.

Dawn Noorlag	Summerill Tube, Inc.

Joe Handrahan	Summerill Tube, Inc.

Duane Maietta	Summerill Tube, Inc.

Jim Schroyer	Summerill Tube, Inc.



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 purpose of the meeting was to
obtain information from Summerill Tube for 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 additional details regarding Summerill 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

What were the TCE emissions in CY2008 for Summerill Tube’s Scottdale,
PA facility?

The TCE emissions in CY2008 for Summerill Tube’s Scottdale, PA
facility were 30.83 tons.  There is only one solvent cleaning machine at
the facility.  

Has Summerill Tube explored the use of Carbon Adsorption Systems (CAS)
to reduce their TCE emissions?

No, they have not looked at CAS recently.  They did investigate
vacuum-to-vacuum (VTV) technology, but determined that it was too
expensive.  In addition, at the time they investigated it VTV technology
was not readily available in very large sizes.  A custom designed unit
that was big enough for their products would have cost $1.5 to $2
million.  There also was not enough room for the end-loading VTV design.
 In order to accommodate this design they would have had to enlarge the
building, which would increase the costs further.  

What is the size and design of their cleaning machine?

They have one cleaning machine that is 36.6 ft long by 3 feet wide by
7.8 feet tall.  They comply with the Halogenated Solvent Cleaning NESHAP
using the control equipment combination option.  The cleaning machine
incorporates the following emission controls: freeboard ratio of 1.0,
working-mode cover, superheated vapor, freeboard refrigeration device,
and hoist.  

The cleaning cycle begins when the cover is opened and the load to be
cleaned is introduced to the machine.  Once the load is in the machine
the cover is closed.  The load remains in the cleaning machine for a ½
hour.  The cover is opened and the load is raised to the freeboard area
and solvent is allowed to drain back into the cleaning tank.  Once the
load is drained of all visible solvent it is removed from the cleaning
machine.  The cleaning machine is in a large open room with other
manufacturing processes, it is not in a room by itself.  

What size tubes do they manufacture and clean?

Summerill Tube manufactures tubes from 1/8 inch to 2.5 inches outer
diameter (O.D.).  Their smallest tube has an inner diameter (I.D.) of
0.059 inches.  Their longest tubes are 35 feet in length.  They clean
all their tubes in straight lengths and not in coils.  Summerill will
send EPA information showing the tube sizes they manufacture and the
percentage of sales for each.  

They estimate that 15-20% of their sales are to the nuclear sector, 40%
to the aerospace sector, and 40% to the energy sector.  They will send a
more accurate estimate to EPA.   

Please provide an overview of the tube manufacturing operations at
Summerill Tube’s Scottdale, PA facility.

Summerill Tube’s Scottdale, PA facility began operations in 1954. 
Teledyne Corporation was the original owner.  They specialize in making
high end tubing products for the aerospace, nuclear, and energy markets.
 They do not sell directly to the medical market, but some of their
tubing is used in the manufacture of some medical products.  They make
primarily stainless steel and nickel alloy tubing using a cold drawing
process.  The cold drawing process utilizes special solvent-based
plasticized lubricants that must be cleaned off the final product.  

  

Has Summerill Tube explored switching to alternative solvents such as
nPB?

Summerill Tube has done some bench scale tests with nPB.  They found
that the plasticized lubricants that they use cannot be adequately
cleaned using nPB.  In addition to the technical considerations, the use
of nPB would increase solvent costs by 3 to 4 times.  Many of the
products they make must meet manufacturing specifications that specify
that TCE be used as the cleaning solvent.  Therefore, if they were to
switch solvents, they would need prior approval from their customers. 

Does Summerill Tube have any photographs of their cleaning machine that
they could send to EPA?

They currently do not have any photographs, but they will take some and
send them to EPA.  

Timeline considerations.

Summerill Tube asked EPA to consider the fact that manufacturers will
need adequate time to implement any additional requirements EPA may
impose.  Summerill Tube is a small business and thus capital for
upgrades is hard to obtain, particularly in these hard economic times.

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