February 2, 2009

Air and Radiation Docket

Environmental Protection Agency

Mailcode: 6102T

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Subject: Docket ID No. EPA-HQ-OAR-2002-0009

> National Emission Standards for Halogenated Solvent Cleaning
>
> Proposed Notice of Reconsideration and Request for Public Comment
> Published in Federal Register (October 20, 2008)

Dear Sirs:

Eastman Kodak Company (Kodak) is a manufacturer of imaging and related
products with manufacturing facilities located in the United States.
Kodak owns and operates **three** halogenated solvent cleaning machines
at the Eastman Business Park facility located in Rochester, New York.
These units are subject to the requirements of 40 CFR 63 Subpart T
(National Emission Standards for Halogenated Solvent Cleaning).
Emissions from two of these batch cold cleaning units are currently
directed to a carbon adsorption system.

In mid-2003, while performing compliance verifications for Kodak's Title
V permit, Kodak concluded that the two batch cold cleaning units which
were equipped with control *could not* comply with the provision of the
Subpart T rule. Specifically, Kodak was unable to certify that the
exhaust mechanism constitutes compliance with the requirement of 40 CFR
63.462(a)(2) to "employ a tightly fitting cover that shall be closed at
all times except during parts entry and removal..." On April 11, 2005,
Kodak submitted a Request for Equivalent Method of Control Determination
to the Air program at USEPA Region 2 (copy enclosed). Region 2 has not
acted upon Kodak's application. Since that time, Kodak has submitted
comments and reiterated our concerns regarding these units on (1)
October 2, 2006 (re. the Subpart T regulation which was proposed on
August 17, 2006) and (2) January 29, 2007 (re. the Notice of Data
Availability issued on December 14, 2006).

On January 14, 2009, I spoke with Ms. Winifred Okoye (USEPA) and Mr.
Lynn Dail (USEPA) regarding the revised Subpart T rule which was
promulgated on May 3, 2007. We discussed the two batch cold cleaning
devices which are equipped with emission control, the application for an
equivalency determination as well as the above-referenced comments which
were previously submitted by Kodak. Upon the recommendation of these
USEPA personnel, Kodak requests that the Agency consider the following
information and comments as they review information submitted under the
Proposed Notice of Reconsideration and Request for Public Comment, which
was published in the Federal Register (October 20, 2008).

If you have any questions, please contact me at (585) 477-5992.

> Sincerely,
>
> Tracey A. Karatas, P.E.
>
> Health, Safety and Environment
>
> Eastman Kodak Company

TAK:

Enclosure

cc: Mr. H. Lynn Dail (USEPA)

> Mr. Kenneth Eng (Chief -- Air Compliance Branch, USEPA Region II)
>
> Mr. Tom Marriott (NYSDEC, Region 8)
>
> Ms. Bernette Schilling (NYSDEC, Region 8)

Bcc: Central File

> D. Schoch (electronic copy)
>
> T. Smithgall (electronic copy)

**ATTACHMENT I : INFORMATION & COMMENTS REGARDING 40 CFR 63 SUBPART T
APPLICABILITY AND COMPLIANCE - EASTMAN KODAK COMPANY, EASTMAN BUSINESS
PARK (Rochester, NY)**

**INFORMATION REGARDING SOLVENT CLEANERS OPERATED BY KODAK AT EASTMAN
BUSINESS PARK**

> **Overview of All Solvent Cleaners at Eastman Business Park**
>
> Kodak operations at the Eastman Business Park facility (located in
> Rochester, New York) are a "major source" of HAP emissions. At this
> facility, Kodak owns and operates **three** halogenated solvent
> cleaning machines which qualify as "batch cold cleaning machines". One
> cleaning machine is a small drum (diameter = 13.75") used to soak
> small equipment, while the other two machines are specially-engineered
> units which are designed to clean large equipment used in the
> manufacture of photographic film base. All three units are subject to
> the requirements of 40 CFR 63 Subpart T (National Emission Standards
> for Halogenated Solvent Cleaning).
>
> Using the calculation methodology prescribed by §63.465(e), the
> potential to emit for all three solvent cleaning units at the facility
> is calculated as follows:
>
> **PTE ~i~ = H~i~ x W~i~ x SAI~i~ (Equation 6) \*\***
>
> where H~i~ = 8760 hrs/yr
>
> W~i~ = 1.95 kg/m^2^-hr (for batch cold cleaners)
>
> SAI~i~ = Solvent/air interface area of the cleaning machine
>
> SAI ~Drum~ = π (13.75 in/ 2) ^2^ \[m^2^ / 1550 in^2^ \] = 0.0958 m^2^
>
> SAI ~Sink\ 1~ = (22 in) (103.5 in) \[m^2^ / 1550 in^2^ \] = 1.47 m^2^
>
> SAI ~Sink\ 2~ = (22 in) (103.5 in) \[m^2^ / 1550 in^2^ \] = 1.47 m^2^
>
> PTE ~drum~ = (8760 hrs/yr)(1.95 kg/m^2^-hr)(0.0958 m^2^) = 1640 kg/yr
>
> PTE ~Sink\ 1~ = (8760 hrs/yr)(1.95 kg/m^2^-hr)(1.47 m^2^) = 25,100
> kg/yr \*\*
>
> PTE ~Sink\ 2~ = (8760 hrs/yr)(1.95 kg/m^2^-hr)(1.47 m^2^) = 25,100
> kg/yr \*\*
>
> PTE ~total\ cleaners~ = PTE ~drum~ **+** PTE ~Sink\ 1~ **+** PTE
> ~Sink\ 2~
>
> = (1640 kg/yr) + (25,100 kg/yr) + (25,100 kg/yr)
>
> = 51,800 kg/yr \*\*
>
> *\*\*NOTE: The calculation methodology prescribed by Equation 6 of
> §63.465(e) does not account for the presence of control equipment.
> (Sinks 1 & 2 are actually directed to a Carbon Adsorption
> System).Under the CAA, the determination of PTE generally reflects the
> emissions controls which are associated with the emission source, if
> the control is identified and made federally-enforceable in the air
> permit.*
>
> The focus of the remaining discussion is focused upon the two "DH
> Cleaning Sinks".
>
> **Design & Operation of \"DH Cleaning Sinks"**
>
> Kodak operates two "DH Cleaning Sinks" which qualify as "batch cold
> cleaning machines". The sinks are used to flush and clean coating
> hoppers (as well as other equipment) associated with the manufacture
> of acetate photographic film base. These custom-engineered units are
> constructed of stainless steel, and are approximately 104" (L) x 23"
> (W) x 26" (D). Each sink is equipped with a hinged lid which is
> latched onto the base of the unit. A "tightly-fitting cover" is
> achieved via an air-inflated bladder which is seated between the cover
> and the body of the cleaner.
>
> To clean a coating hopper (or other piece of equipment), the equipment
> is loaded into the *empty* sink (i.e., *with no solvent present*).
> Solvent flush lines are connected to the equipment and the cover is
> closed and secured. The cleaning cycle is initiated and controlled by
> a programmable logic controller (PLC). The PLC activates a pump
> (located outside the sink) to fill the cleaner to a programmed solvent
> height (NOTE: Depending upon the type/style of equipment being
> cleaned, the solvent height in the cleaner may vary. This solvent
> height, however, is limited to comply with the freeboard requirements
> of Subpart T). A level sensor within the sink is used to monitor the
> liquid level within the sink.
>
> After the sink is filled, a centrifugal pump draws solvent from the
> bottom of the cleaner to multiple connection points on the equipment.
> A heat exchanger (equipped with chilled water) is used to maintain the
> solvent temperature between 68^o^F and 78^o^F as it is re-circulated
> back into the sink. At the end of a cleaning "cycle", the solvent is
> drained. It typically requires *nine* cleaning "cycles" (i.e., *nine*
> fill -- drain cycles) in order to satisfactorily clean a piece of
> equipment. Through the entire cleaning process, the "tight-fitting"
> cover remains closed until all solvent is drained from the sink after
> the final cleaning cycle.
>
> On an occasional basis (approximately one of ten cleaning events), the
> sink may need to be opened in order to inspect the equipment for
> cleanliness. When this is necessary, the operator places the sink into
> "Inspection Mode". The cover is opened, and the equipment is partially
> retracted from the sink for inspection. During the inspection process,
> the operator may continue flushing the equipment with solvent in order
> to look for irregular solvent flow patterns as evidence of plugged or
> dirty equipment. Some hand cleaning (e.g., with a brush) may be
> performed. When this is complete, the equipment is lowered back into
> position within the sink, and the cover is closed and secured.
>
> **Emissions from \"DH Cleaning Sinks"**
>
> As described above, solvent is not pumped into the sink until the
> dirty equipment is positioned in the empty sink, and the sink lid is
> closed and secured. When solvent is added to the unit, the rising
> liquid level will increase the pressure of the vapor headspace,
> resulting in vapor leaks via the bladder seal. To prevent these vapor
> leaks and minimize employee exposure to solvent vapors, the PLC turns
> on a lip exhaust (located approximately 2.5" from the upper edge of
> the cleaning unit) to exhaust vapors from the unit (1) while the
> cleaner is being filled with solvent, (2) while the unit is open
> during "Inspection Mode", and (3) after solvent is *finally* drained
> completely (i.e., after nine cleaning cycles) from the machine, but
> before the lid is opened.
>
> Emissions which are captured via the lip exhaust are directed to a
> carbon adsorber system, which is operated to meet various emission
> control requirements at this film manufacturing operation. The Carbon
> Adsorber System (Control ID 05302) is comprised of three 12-ton beds
> of carbon, and has been shown to achieve 99.6% control\*\*control of
> methylene chloride. Process exhaust gases for treatment are directed
> to a single bed at a time, where air contaminants are adsorbed onto
> the carbon. When the concentration of the outlet gas indicates that
> bed "breakthrough" has occurred, the process control system diverts
> the uncontrolled stream to the next-available carbon bed, and
> initiates the regeneration cycle of the "spent" carbon bed. To
> regenerate the carbon, the "spent" bed is (1) steamed to remove
> adsorbed solvents, (2) dried using heated air, and (3) cooled.
>
> *NOTE: Based upon a review of data from a performance test conducted
> in 6/03, the carbon adsorber alone (which exhausts to Emission Point
> 053L6) demonstrated an average control efficiency of 99.6%. (The
> minimum value seen during this test was 95.8%).*
>
> *Under the Title V Permit, the outlet of the carbon adsorber is
> required to be monitored at a minimum of once per hour for methylene
> chloride concentration, as well as to continuously monitor the total
> hydrocarbon breakthrough on the carbon adsorber.*
>
> Based upon engineering calculations, the *total* 2008 actual emissions
> (after control) from both sinks was calculated to be \< 15 lb/yr of
> methylene chloride.
>
> **Addition & Removal of Solvents from \"DH Cleaning Sinks"**
>
> To demonstrate compliance with recently-promulgated facility-wide
> standards of Subpart T, §63.471(b)(1) requires that a log of solvent
> additions and deletions be maintained for each cleaning machine. As
> previously noted, each sink is equipped with a level sensor. However,
> because solvent is added to the unit after the equipment is in the
> sink, the actual quantity of solvent added cannot be calculated by
> liquid level only. (I.e., the volumetric displacement characteristics
> of each piece of equipment as it is placed in the sink must be
> understood).
>
> The "cleaning solution" used in the sinks is prepared in a solution
> making vessel which is connected to the sinks via several hundred feet
> of hard piping. The preparation of cleaning solution is completely
> automated. When the vessel level becomes "low" (as monitored by a
> continuous level sensor within the making vessel), the PLC initiates
> the preparation of additional cleaning solution; specifically, the PLC
> initiates the addition of specific quantity of two pipeline solvents
> to the vessel. A data historian records the amount of solution
> added/prepared in the making vessel, however, the vessel also supplies
> the "cleaning solution" to other operations (besides the DH cleaning
> sinks). The amount supplied to the DH cleaning sinks or other
> operations is not monitored or measured.
>
> Spent solvent in the sinks is pumped/drained to a lugger or process
> tank via several hundred feet of hard piping. (The lugger and process
> tank are used to accumulate recoverable solvents from various parts of
> the film manufacturing process). The amount of solvent pumped/drained
> from to the DH is not monitored or measured.
>
> In order to monitor the amount of solvent additions and removals from
> each sink, Kodak will be forced to install four mass flow monitors (as
> well as the associated sensing elements & data historian) to record
> the information. This installation is estimated to cost approximately
> \$50 K. Given the fact that methylene chloride is being used to
> [dissolve]{.underline} solid materials, there is a possibility of a
> higher mass quantity leaving the sink than entering the sink.

**COMMENTS REGARDING SUBPART T REGULATION**

> **1. Kodak requests/recommends that the regulation be modified to
> provide an *option* for the owners of batch cold cleaners to comply
> with the NESHAP through the use of control technology (rather than by
> work practice standards only).**
>
> The two batch cold cleaning machines which are previously described
> ("DH Cleaning Sinks") were designed in a manner to minimize emissions
> as well as employee exposure to methylene chloride. A lip exhaust is
> utilized (1) while the cleaner is being filled with solvent, (2) while
> the unit is open during "Inspection Mode", and (3) after solvent is
> *finally* drained completely (i.e., after nine cleaning cycles) from
> the machine, but before the lid is opened. The lip exhaust is not used
> during the other portions of the cleaning cycle.
>
> *Before* any solvent is added to the sink, the dirty equipment is
> placed into the sink and the lid is closed/locked in place. Thus, the
> "cleaning" process begins while the sink is being filled. Without a
> means to exhaust emissions during filling, the addition of solvent to
> the sink would cause the vapor headspace within the sink to increase
> in pressure (due to a reduction in the volume of the vapor headspace)
> and subsequently leak vapor via the bladder seal) from the closed
> sink. To reduce the internal pressure, a lip exhaust *must* be used
> while the cleaner is being filled. However, unless the EPA provides an
> interpretation, or an equivalency determination, Kodak is not able to
> certify that this exhaust mechanism constitutes compliance with the
> requirement of 40 CFR 63.462(a)(2) to "employ a *tightly fitting*
> cover that shall be closed at all times except during parts entry and
> removal..."
>
> For batch vapor and in-line cleaning machines, Subpart T does address
> the existence of lip exhausts and directly provides for the use of
> carbon adsorption as a compliance method. However, there are no
> similar provisions for batch cold cleaning machines. In the Subpart T
> preamble (59 FR 61803, 12/2/94), EPA stated that
>
> *"there are multiple control options for meeting the rule, many of
> which are pollution prevention measures. Many of these options also
> reduce worker exposure. However, some sources may rely on lip exhausts
> instead in order to meet OSHA requirements. Use of a lip exhaust
> without any controls, while reducing worker exposure on the one hand,
> would dramatically increase overall emissions to the air. Thus, if lip
> exhausts are used on solvent cleaning machines, the rule requires
> carbon adsorption controls (which have been added explicitly as a
> control option in the final rule)."*
>
> The only compliance method which is currently available for batch cold
> cleaning machines is the work practice standards of §63.462. Kodak
> requests that the USEPA either (1) grant Kodak's Request for
> Equivalent Method of Control Determination dated April 11, 2005 (copy
> enclosed), or (2) modify the regulations to provide an option for the
> use of capture and control devices to control emissions from batch
> cold cleaning machines. *\[NOTE: Kodak's issues with §63.462(a)(2)
> could be simply resolved by the modifying the requirement to read
> "Employ a tightly fitting cover that shall be closed at all times
> except during [filling of the unit or]{.underline} parts entry and
> removal[,]{.underline} and a freeboard ratio of 0.75 or greater". \]*
>
> **2. Batch cold cleaning units which utilize carbon adsorption
> technology should be specifically excluded from the facility-wide
> standards of §63.471.**
>
> Under §63.471(a), batch cold cleaning machines which qualify as an
> *area source* are excluded from the facility-wide standards of
> §63.471. The section also excludes other specific cleaning machines
> which are located at major sources. Kodak requests that the Agency
> also exclude Kodak's batch cold cleaning units which utilize carbon
> adsorption technology. Kodak's issues regarding the facility-wide
> standards are as follows:

(a) **Cleaning units which are interconnected via hard piping with
    solvent feed or waste storage tanks may be forced to install flow
    monitoring systems.**

> The recently-promulgated facility-wide standards of §63.471(b)(1)
> requires that a log of solvent additions and deletions be maintained
> for each cleaning machine. For the two batch cold cleaning machines
> which are previously described ("DH Cleaning Sinks"), a capital
> investment of approximately \$50 K will be required in order to
> install flow monitoring equipment and data recording capabilities.
> Given the design and use of these machines, Kodak believes that the
> addition of flow meters provides no environmental benefit and could
> possibly generate negative emission values.

(b) **The methodology prescribed by §63.471(c)(2) to calculate solvent
    emissions does not include any provision for capture & control of
    emissions.**

> Because emissions from these two sinks are directed to a carbon
> adsorber system, (which has been shown to achieve 99.6% control of
> methylene chloride) the calculation will grossly overestimate the
> actual emissions. Based upon engineering calculations, the *total*
> 2008 actual emissions (after control) from both sinks was calculated
> to be \< 15 lb/yr of methylene chloride.
>
> As an alternative, an owner/operator should be given the option to
> demonstrate that the facility potential to emit (PTE) for halogenated
> solvent cleaning machines is less than the applicable facility-wide
> limit, whereby the owner/operator would be excluded from the ongoing
> compliance recordkeeping. (NOTE: The current PTE calculation
> methodology outlined in §63.465(e) mandates the use of 8760 operating
> hours/yr and does not account for the use of capture/control. If a
> facility wanted to change the prescribed calculation methodology in
> order to keep the facility total below the limit, then the parameters
> used in the calculation would need to be made
> "federally-enforceable").
>
> **3. Mandatory filling of the cleaner to the same level may create
> excessive solvent use or waste.**
>
> §63.471(b)(1) requires that a log of solvent additions and deletions
> be maintained for each cleaning machine. Furthermore, §63.471(c)(1)
> requires that the solvent fill level must be returned to the same fill
> line each month. For units which may be emptied and refilled several
> times a month, Kodak presumes that the Agency intends for the cleaning
> unit to always be filled to the same liquid level.
>
> []{.mark}
>
> Based on 2008 usage records, the DH Cleaning Sinks (previously
> described) were filled and emptied an average of 23 times per month
> per sink. Depending on the type of equipment being cleaned, the liquid
> solvent level will vary. Kodak estimates that the requirement to
> return the solvent fill line to the same level each time would have
> resulted in the additional use of more than 4000 gal/yr of solvent in
> 2008. To minimize solvent use, §63.471(c)(1) should be made
> non-applicable to Kodak's cold cleaning machines or amended as
> follows:
>
> §63.471(c)(1): "Each owner or operator of an affected facility shall,
> on the first operating day of every month, ensure that each solvent
> cleaning machine contains only clean liquid solvent. This includes,
> but is not limited to, fresh unused solvent, recycled solvent, and
> used solvent that has been cleaned of soiled materials. ~~A fill line
> must be indicated during the first month the measurements are made.
> The solvent fill level must be returned to the same fill line each
> month, immediately prior to calculating monthly emissions as specified
> in paragraphs (c)(2) and (3) of this section.~~ [The quantity of clean
> liquid solvent remaining in the cleaning machine at the beginning of
> the first operating day shall be documented.]{.underline} The solvent
> cleaning machine does not have to be emptied and filled with fresh
> unused solvent prior to the calculations".
>
> **4. Compliance Date**
>
> §63.460(i)(1) states that "each affected facility that was constructed
> or reconstructed on or before August 17, 2006, shall be in compliance
> with...\<\< §63.471\>\> no later than May 3, 2010. Under §63.471(g),
> an initial statement of compliance must be submitted on or before May
> 3, 2010. Because the statement is required to include "the results of
> the first 12-month rolling total emissions calculation", sources must
> actually begin maintaining their records of solvent additions and
> deletions no later than May 1, 2009.
>
> For the two batch cold cleaning machines which were previously
> described ("DH Cleaning Sinks"), a capital investment of approximately
> \$50 K will be required to install flow monitoring equipment and data
> recording capabilities. For the reasons outlined herein (as well as
> the current state of the economy), Kodak requests that the Agency
> revise the rule in a manner that excludes these sinks from this
> requirement. If the Agency is unwilling to revise the rule, Kodak
> requests that the Agency grant Kodak's Request for Equivalent Method
> of Control Determination dated April 11, 2005, and in that
> determination, exempt these two cleaning units from the facility-wide
> standards of §63.471.