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

To: 	Docket EPA-HQ-OAR-2002-0009

Re:  	September 15, 2009 Meeting Between the U.S. EPA and Parts Cleaning
Technology Regarding the Halogenated Solvent Cleaning Reconsideration

Date: 	September 15, 2009

On September 15, 2009, a teleconference meeting was held between the
U.S. Environmental Protection Agency (EPA) and representatives from
Parts Cleaning Technology (PCT) - a narrow tube cleaner and solvent
distributor.  The meeting participants are listed below: 

Name	Organization

Tim Benner	EPA/ORD

Susmita Dubey	EPA/OGC

Winifred Okoye 	EPA/OGC

Amy Hambrick	EPA/OAQPS

Dennis Pagano	EPA/OAQPS

Dave Crandell	Parts Cleaning Technology

Farrell Costello	Parts Cleaning Technology



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
PCT’s January 26, 2009 and 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 PCT’s products, 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 PCT’s operations at the Bowling Green, Kentucky
facility.

PCT’s corporate headquarters are located in Michigan.  At the Bowling
Green, Kentucky facility PCT builds and designs cleaning units for the
metal cleaning industry, and contract cleans for other narrow tube
manufacturers..  PCT cleans narrow tubes that are then inspected and
shipped to customers.  This is usually the final cleaning step before
shipping to PCT’s customers who may use the narrow tubes for medical,
oxygen, and refrigeration applications. PCT returns the cleaned tubes to
the original manufacture for shipping to the end user.  All tubes are
cleaned to the same specifications.

The narrow tubes range in size from 1/16th of an inch to 2 and 1/8 of an
inch inner diameter (I.D.).  The tubes cleaned are up to 21.5 feet long,
the shortest tube cleaned is 3 inches long. PCT has one cleaning unit
(EP01).  The unit is 22 feet long by 3 feet wide by 4 feet of vapor
space.  The unit is 10 feet tall and can hold up to 1,200 gallons of
solvent.      

What were the TCE emissions from EP01 in CY 2008?

The net emissions were 17,985 pounds (18.44 tons).  EP01 is a top
loading unit with a CAS.  The CAS removes 95% of the solvent in the air
that reaches it.  However, not all the solvent makes it into the air
that reaches the CAS.  Thus the CAS achieves about 50% overall reduction
in emissions in the cleaning process.  The cleaning cycle for a bundle
of tubes can range from 30 to 45 minutes.  Before the bundle is unloaded
from the unit, it is held for about 1.5 minutes.  The unit is only
covered during down time.  The unit is uncovered during the cleaning
process.  The majority of the emissions result from solvent carried out
with bundles of tubing as they are removed from the cleaning unit.  PCT
currently only has EP01 in operation.      

 

Has PCT explored the use of alternative solvents, such as nPB or
vacuum-to-vacuum (VTV) technology for the narrow tube industry?

Yes, PCT has explored using aqueous cleaning solvents, nPB, and VTV
technology.  PCT determined that aqueous solvents do not clean as
thoroughly, and the tubes do not dry as rapidly after cleaning. 
Residual moisture can damage the annealing furnaces used for narrow
tubing.  Some facilities have switched from aqueous cleaners back to
chlorinated solvents, and some states with water shortages have
disapproved permits for aqueous cleaning systems.  PCT determined that
although nPB cleans adequately, it is not as stable as TCE, and its use
would require additional monitoring equipment.  PCT determined that VTV
is not a practical option for them and that the technology is not yet
cost effective.  VTV has limited options for top-loading units, leading
to a need for additional building space to accommodate end-loading
units.  The cleaning cycle time frame in a VTV system is doubled, and
PCT feels that the tubes used in medical devices would not be able to
meet stringent cleaning specifications in a VTV system.  PCT felt that
VTV systems were OK for shorter tube lengths, but they had no real
advantage over regular vapor systems for such tubes.  PCT explained that
the cost of nPB ranges from $2.25 to $3.00 per gallon, and the cost of
TCE ranges from 85 cents to $1.00 per gallon. 

Does PCT see the industry technology changing in the next 3 years?

PCT does not see any anticipated major breakthroughs on solvent or VTV
technology.  An appropriate tube size to switch solvents is about ½
inch I.D. and greater than 20 feet long.  PCT described that new
facilities should have an easier time of designing improved buildings
and units to accommodate to newer technologies like VTV, but that for
existing entities the economic cost is very challenging.

What is a reasonable emissions limit for narrow tube manufacturing
operations? 

PCT stated that the narrow tube industry has significantly reduced
emissions in the past decade.  PCT has seen in some applications that
annual emissions have been reduced fifty per cent by installing CAS
systems and improving material handling.  PCT feels that if a facility
has already made these improvements and still has emissions in excess of
30 tons per year, reducing emissions to fewer than 20 tons per year is
not achievable.  PCT feels that a reasonable emission limit for a narrow
tube manufacture is not a static limit but one that ensures facilities
have installed best available technology for their production capacity.

Does PCT have any pictures of their cleaning machines that they could
send to EPA?  

PCT will send photographs of their cleaning machine.

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