Methods for Reducing TCE 

from Superior Tube Co

and Accellent, In

Collegeville, Pennsylv

MATSON & ASSOCIATES, I

March 7, 2008
MATSON & ASSOCIATES

 Based in State College, Pennsy Environmental Engineering Con Expertise/Services

 Litigation Support and Expert Wi Environmental Engineering Consu
Background

 Jan 2007: DEP Collegeville Area Air M

Report showed excess cancer risk in ETrappe, PA from TCE

 Superior Tube and Accellent: significa

of TCE

 Ranked 6 and 8 nationally in 2005 (69.0 t Ranked 11 and 12 nationally in 2006 (68.

tons)

 May 2007: EPA Final Rule for Halogen

Cleaning exempted narrow tube indusemissions controls
Overview

 Superior Tube’s and Accel

programs are capable of asignificant TCE emissions 

 Effective operation of con

technologies is essential tgoals

 Permits reflecting effective 

should ensure success
Voluntary Actions: Super

 Removed from operation

 5 point sources  Will remove another point source b

 Switched from TCE to nPB

 3 Lubrication Spray Booths  Plan to switch remaining 4 point so

TCE to nPB in April 2008

Source: STCI, Minor Operating Permit Modification Application, 2/13/2008.
Concerns: Superior Tube

 Maintains the option of switchi

 34 tons/yr TCE emissions EPA Final Rule for other halogena

cleaning industries is 15.5 tons/y

 No emissions capture controls on 

 Non-optimal operation of its Ac

(AC) system

Source: STCI, Minor Operating Permit Modification Application, 2/13/2008; EPA Final Rule, M
TCE emitted (0.8

Superior Tube’s Compliance Test, Jan 2002

TCE to AC (100%)

Activated Carbon System O

Activated carbon 

(AC) beds

TCE in (100%)

TCE to AC (90%)

TCE emitted (19

TCE removAC (90%)

Superior Tube’s Plan Approval, Nov 2000

Vapor Degreaser

Permit based on 81% removal efficiency
CONCERNS: Non-optimal operation of 

Year 

2003 2004 2005 2006 

Actual TCE eAC system

Controlled TCE

emissions 

(tons/year)

PrecontrolledTCE Emissionslbs/hour

81%

removal 

efficiency

99.2% 

removal 

efficiency

17.8 (Avg +20%) 14.8 0.614.8 (Avg) 12.3 0.58.0 (hourly 

throughput) 6.7 0.3

Calculated TCE emissions

Based on 24/7 365 days operation

Sources: Plan Approval for Installation of AC system, 2000; DEP Inspection Reports; Complia

Test, 2002; Best Controlled Detail Reports for emissions years: 2006, 2005, 2004, 2003 

Permit lim
Recommendations: Supe

 Conduct new Compliance Test 

system and change permit levethe results

 Use continuous monitoring Install emission controls on un

point sources
Voluntary Actions: Accel

 Installing AC system on its 2 la

degreasers



1st unit installed Oct. 2007



2nd unit install by Mar. 2008

 ~97% of TCE emissions originate 

large vapor degreasers

 Expects 25 – 35% reduction in T

plant wide

Source: Best Controlled Detail Report for emissions year 2006; STCI to DEP, Subj: Carbon Systems Accellent, 4/9/2007.
Concerns: Accellent, Inc

 25 - 35% reduction in TCE emission

of its AC system

 TCE Emissions remaining = 44 – 51 ton EPA Final Rule for other halogenated so

15.5 tons/year TCE

 Should be able to achieve higher re No AC system compliance test perfo No emissions controls on 2 smaller e

Source: EPA Final Rule, May 2007
Recommendations: Acce

 Conduct Compliance Test on n

and change permit levels to re

 Switch to nPB and/or route em

system in 2 remaining point so

 Require continuous monitoring 

emissions
Recommendation: Continuous 

TCE in

Inlet monitor

Stack emissions = outlet monitor Emergencies: Early Detection and Control 

Pump

AC removal efficiency monitored

BENEFITS:
Conclusions

 Superior Tube and Accellent ar

implementing voluntary actions TCE emissions

 Proper operation of control tec

reduce TCE emissions significacurrent permit levels

 Permit levels based on proper 

ensures compliance with volunreductions