1

From: Amy

Hambrick, U.S. Environmental Protection Agency To: Docket EPA
- HQ
- OAR
- 2002
- 0009 Re: October 28, 2009 Meeting Between the U.S. EPA and Hy perflo, LL C Regarding the Halogenated Solvent Cleaning Reconsideration Date: November 6, 2009
On Oct ober 28, 2009 , a teleconference meeting was held between the U.S. Environmental Protection Agency

(EPA) and representatives from Hy perflo
- a vacuum to vacuum manufacturer. The meeting participants are listed below: Name Organization Kim Teal EPA/OAQPS Amy Hambrick EPA/OAQPS Dennis Pagano EPA/OAQPS Chris Sarsony HDR|e 2 M Inc. Dr. Donald Gray University of Rhode Island Joe Schuttert Hy perflo Meeting Agenda: 1. Introductions and Meeting Purpose 2. Issues for Discussion 3. Open Discussion Meeting Summary: 1. 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 an informational meeting for EPA to obtain clarification and additional details reg arding Hy perflo vacuum to vacuum (VTV) Halogenated Solvent cleaning machines. 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. 2. Issues for Discussion
a. Vacuum to vacuum overview. Hy perflo provided a basic overview to EPA of how the VTV cleaners work. Hy perflo stated that a machine would be designed to meet a customer’s needs (i.e. size of chamber, cycle time, etc.). Hy

perflo described the process of ho w an item is placed into the machine, air is removed from the chamber, the parts are cleaned, the solvent is flushed2

from the machine, and, finally , how the pressure is dropped to then remove the solvent, and the item dried ending the cycle. b. Are VTV mach ines top or end loading? Hy perflo responded that ty

picall y the VTV machines used for tube cleaning are end loading. For items such as narrow tubes greater than 30 feet, the VTV can have a side chamber for loading purposes. Smaller tubes or parts can hav e a top loading machine. Hy perflo explained that the VTV used for longer tubes can be top loading but it is ty picall y more expensive. A top loading machine can have a sliding lid opposed to a clam shell lid. The 30’top loading sliding lid option would c ost an estimated $8,000 more. The sliding top lid does not have increased fugitive emissions. If the lid does not seal properl y, it would most likely be the result of a manufacturing defect.
c. What kind of maintenance do VTV machines require? The gask et must be replaced every 4
- 5 y ears, however if the unit is very long, a double seal can be installed. d. How much solvent is used? Solvent is applied as needed. For man y applications, using vaporized solvent is adequate. An industry

like narrow tube may

require tube immersion in the solvent. A sequence d vapor spray

application can be applied for narrow tubes that don’t require immersion . A ty pical cycle time is 20 minutes. The solvent is intended to last indefinitely . When the machine removes the air, atmospheric moisture is also removed increasing the longevity of the solvent. A conservative solvent usage rate is 0.00253 pounds per cubic foot of machine cleaning area. However, if a rate is 0.00506 pounds per cubic foot, it is an indication that there is a malfunction.
e. What types of parts cleaned represent the greatest emissions? Aluminum honeycomb aerospace parts (e.g. fuselage) represent the highest emissions with present degreasing machines (not VTV). Hy perflo provided an example of a fa cility that installed a VTV to clean honeycomb parts. The annual emissions dropped from 175,000 lbs to 500 lbs. Hyperflo indicated that the drying time for these parts is longer, about 30 minutes. In this example, the VTV machine was a 300 square foot end loading machine. To convey

a visual imagine, Hy

perflo described it as a large bakery rake on wheels. Hy

perflo described the business pay back to be approximately one y ear. A second example provided discussed a facility that cleans aerospace landing ge ars. This VTV set up is a dual s ys tem that can handle six tons of product per hour. Hy perflo stated that they

have ongoing conversations with the aerospace industry
. Hy perflo believes that three
- quarters of a million dollars capitol investment present s a hurdle for the aerospace industry
.3

Hy perflo referenced an independent study done by Texas Instruments (Attachment 1). f. What size narrow tubes can a VTV machine clean? VTV machines can adequately clean narrow tubes of a variet y of sizes including s uch as capillary tubes for the refrigeration industry . Hy perflo has conducted testing in TCE for stainless steal narrow tubes that were 1/16 and 1/8 of an inch in inner diameter and 1,500 feet long in coils. g. How long would it take to get a VTV designed and installed? 18 weeks to 6 months. The machines are built at Hy perflo. Installation could take about one week. This t ypically happens during the summer or the holiday s when production has slowed. h. Do VTV machines take up more floor or building spac e than a traditional vapor degreaser? The same square footage is required for VTV as for traditional vapor degreasers. The VTV machine is installed around existing structures. i. Can Hyperflo facilitate an EPA site visit to an aerospace industry that hous es a VTV ma chine? Hy perflo will attempt to facilitate an EPA site visit to an aerospace industry. j. Does Hyperflo have a VTV fact sheet that they can share with EPA? Yes, they can put something together. Hy perflo also committed to sending EPA a cost co mparison presentation (Attachment 2 & 3 ).