Economic Impact Analysis for the Proposed 

Notice of Reconsideration of the Final 

Halogenated Solvent Cleaners Residual Risk 

Standard and Request for Public Comment 
EPA-452/R-08-005 

October 2008 

Economic Impact Analysis for the Proposed Notice of Reconsideration for the Final 

Halogenated Solvent Cleaners Residual Risk Standard and Request for Public Comment

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Health and Environmental Impacts Division 

Air Benefits and Costs Group 

Research Triangle Park, NC

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Executive Summary 

 The EPA has proposed to reduce the amount of risk associated with exposure to 

hazardous air pollutants (HAPs) such as methylene chlorine (MC), perchloroethylene (PCE), and 

trichloroethylene (TCE) from existing and new halogenated solvent cleaning machines. This 

standard is proposed in response to petitions to reconsider a final rule regulating HAPs from 

existing and new halogenated solvent cleaning machines published in May, 2007. The 

proposed standard offers three options to revise these limits based on a finding that sufficient 

residual risk exists to warrant a tighter standard, and these options cover several industries not 

affected under the final rule published last year. These industries are aerospace manufacturing, 

narrow tube manufacturing, and industries with continuous web cleaners. 

This report provides the economic impacts as well as other impacts – costs, emission 

reductions, and risk reductions - associated with the three options offered in this proposal. The 

impacts in this report are estimated based on comparisons of annualized compliance costs to the 

revenues for affected firms. We find that the impacts of these options are generally minimal to 

small businesses, and that most large businesses will likely experience cost savings for the most 

part. All economic impact estimates are based on incorporation of the scale-up factor of 1.74 

applied to affected source populations and costs. Option 1 is expected to affect 120 ultimate 

parent entities, and forty of these parent entities (or one-third of the total number of the ultimate 

parent entities affected) are small as defined by Small Business Administration (SBA) small 

business size standards. Of these 40 small entities, none have an annualized cost of greater than 

1 percent of their sales. Option 2 is expected to affect 148 ultimate parent entities, and fifty-two 

(or thirty-five percent) of these are small as defined by SBA small business size standards. Of 

these 52 small entities, three have an annualized cost of greater than 1 percent of sales. Option 3 

is expected to affect 181 ultimate parent entities, and fifty-six (or thirty-one percent) of these are 

small. Of these 56 small entities, three have an annualized cost of greater than 1 percent of sales. 

There is no significant economic impact on a substantial number of small entities (or SISNOSE) 

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associated with this final standard. This certification is based on the economic impact of today’s 

action to all affected small entities in the entire halogenated solvent cleaning source category 

regardless of the option in this proposed rulemaking. 

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Introduction 

 

On December 2, 1994, we promulgated national emission standards for halogenated 

solvent cleaning machines1 (59 FR 61801, December 2, 1994)(1994 NESHAP), to control 

emissions of the halogenated solvents methylene chloride (MC), perchloroethylene (PCE), 

trichloroethylene (TCE), 1,1,1,-trichloroethane (TCA), carbon tetrachloride, or chloroform and 

halogenated solvent blends or their vapors from halogenated solvent cleaning machines, pursuant 

to Section 112(d) of the CAA. The standards, which can be found in 40 CFR Subpart T, include 

multiple alternatives that allow maximum compliance flexibility. The 1994 NESHAP is 

available in the docket for this rulemaking. 

Carbon tetrachloride and chloroform are no longer used in this source category. The 

Montreal Protocol, a treaty signed on September 16, 1987, phased-out the production and 

consumption of these chlorofluorocarbons by January 1, 1996. The Protocol also phased out 

TCA. Although production and use of TCA has been phased-out since 1998, an exemption to 

the phase-out allows facilities with essential products or activities to continue their use of TCA, 

and facilities with non-essential activities or products to continue their use of remaining TCA 

stockpiles until depleted. A declining quantity of TCA continued to be used until 2002, when all 

production of TCA ceased, and eventually, facilities used TCA stockpiles until depleted. Since 

January 1, 2002, TCA has not been manufactured for domestic use in the United States. 

Halogenated solvent cleaning machines use MC, PCE, TCE and TCA to remove soils 

such as grease, oils, waxes, carbon deposits, fluxes, and tars from metal, plastic, fiberglass, 

printed circuit boards, and other surfaces. Halogenated solvent cleaning is typically performed 

prior to processes such as painting, plating, inspection, repair, assembly, heat treatment, and 

 

1 Halogenated solvent cleaning does not constitute a distinct industrial category, but is an integral part of 

many major industries. The five 3-digit NAICS Codes that use the largest quantities of halogenated 

solvents for cleaning are NAICS 337 (furniture and related products manufacturing), NAICS 332 

(fabricated metal manufacturing), NAICS 335 (electrical equipment, appliance, and component 

manufacturing), NAICS 336 (transportation equipment manufacturing), and NAICS 339 (miscellaneous 

manufacturing). Additional industries that use halogenated solvents for cleaning include NAICS 331 

(primary metals), NAICS 333 (machinery), and NAICS 334 (electronic equipment manufacturing). Nonmanufacturing industries such as railroad (NAICS 482), bus (NAICS 485), aircraft (NAICS 481), and 

truck (NAICS 484) maintenance facilities; automotive and electric tool repair shops (NAICS 811); and 

automobile dealers (NAICS 411) also use halogenated solvent cleaning machines. 

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machining. Types of halogenated solvent cleaning machines include, but are not limited to, 

batch vapor, in-line vapor, in-line cold, and batch cold solvent cleaning machines. Buckets, 

pails, and beakers with capacities of 7.6 liters (2 gallons) or less are not considered halogenated 

solvent cleaning machines. 

 In May 2007, we promulgated the Halogenated Solvent Cleaning Rule (72 FR 25138), 

which established revised standards that further limit emissions of MC, TCE and PCE from 

facilities engaged in halogenated solvent cleaning, pursuant to CAA section 112(f). Specifically, 

we promulgated a facility-wide emission limit of 60,000 kilograms per year (kg/yr) MC 

equivalent2 that applied to all halogenated solvent cleaning machines with the exception of 

halogenated solvent cleaning machines used by the following industries: facilities that 

manufacture narrow tubing, facilities that manufacture specialized products that require 

continuous web cleaning, aerospace manufacturing and maintenance facilities, and military 

maintenance and depot maintenance facilities. We also promulgated a facility-wide emission 

limit of 100,000 kg/yr MC equivalent for halogenated solvent cleaning machines used at military 

maintenance and depot facilities. We required facilities to comply with the revised standards 

within 3 years after the effective date of the Halogenated Solvent Cleaning Rule, which is May 3, 

2010. Further, with regard to halogenated solvent cleaning machines used by facilities that 

manufacture narrow tubing, facilities that manufacture specialized products that require 

continuous web cleaning, and aerospace manufacturing and maintenance facilities we found, 

after considering risks, associated compliance costs and the availability of control measures, that 

the 1994 NESHAP reduces risk to acceptable levels, provides an ample margin of safety to 

protect public health, and prevents adverse environmental effects. We concluded that the actions 

taken in the final rule satisfied our obligations under CAA section 112(d)(6) and (f)(2). 

C. What are the petitions for reconsideration? 

 Following promulgation of the Halogenated Solvent Cleaning rule, the Administrator 

received several petitions3

 for reconsideration (Petitions), under CAA section 307(d)(7)(B). 

 

2

 All emission limits and emission rates in the assessments were converted to MC-equivalents based on the relative 

cancer potency of the HAPs emitted. The cancer potency-weighted MC-equivalent emission rate was calculated as 

the estimated emissions for the HAP in kg/yr or lb/yr times the unit risk estimate (URE) for the HAP divided by the 

URE for MC.

3 These petitions for reconsideration were filed by the Commonwealth of Pennsylvania Department of 

Environmental Protection, Natural Resources Defense Council v. EPA, Citizens for Pennsylvania’s Future and 

Sierra Club, several state and federal legislators and the Governor for the Commonwealth of Pennsylvania. 

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Generally, petitioners claimed that the Halogenated Solvent Cleaning Rule contained legal 

interpretations and information that are of central relevance to the final rule that were not 

sufficiently reflected at proposal, and that they, therefore, did not have an adequate opportunity 

to provide input on during the designated public comment period. Further, petitioners claimed 

that additional information on compliance measures had become available since the close of the 

public comment period for the Halogenated Solvent Cleaning rule, and that this new information 

is also of central relevance to the Halogenated Solvent Cleaning rule. 

 On August 15, 2007, EPA informed petitioners of its intent to initiate notice and 

comment rulemaking to address the Petitions. We also informed petitioners that the particular 

issues for reconsideration and the specifics of the reconsideration process would be addressed in 

a forthcoming Federal Register notice. Additionally, we denied the request to stay the 

effectiveness of the Halogenated Solvent Cleaning rule pending completion of the 

reconsideration proceedings. (These letters are in the docket for this rulemaking.). 

Finally, petitioners challenged the Halogenated Solvent Cleaning rule in the Court of 

Appeals for the District of Columbia Circuit.4

 Because we intended to initiate notice and 

comment rulemaking to address the Petitions, we requested and the Court has granted our 

request, to hold the challenge in abeyance until November 3, 2008. 

I. Proposed Response to the Petitions for Reconsideration 

A. What is our proposed action? 

 In our August 17, 2007, letter we informed petitioners that the particular issues for 

reconsideration and the specifics of the reconsideration process would be addressed in a forth 

coming Federal Register notice. The purpose of this notice is to initiate the process for 

responding to certain issues raised in these petitions. 

 In this action, we are proposing that the risk associated with the 1994 NESHAP for the 

halogenated solvent cleaning source category is acceptable. We are also proposing 

various regulatory options that would provide an ample margin of safety to protect public 

health and prevent adverse environmental effects. These proposed requirements would 

apply to owners and operators of halogenated solvent cleaning machines that are subject 

 

4 Commonwealth of Pennsylvania Department of Environmental Protection v. EPA, No. 07-1129 (D.C. Cir.); 

Citizens for Pennsylvania’s Future and Sierra Club v. EPA, No. 07-1255 (D.C. Cir.); Natural Resources Defense 

Council v. EPA, No. 07-1256 (D.C. Cir.). These cases have since been consolidated. 

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to the 1994 NESHAP. Additionally, we are proposing that such standards would satisfy 

our obligations under both CAA sections 112(d)(6) and 112(f)(2). In this action we are 

proposing a 2-year compliance deadline from the date that this action becomes final for 

existing sources not covered by the Halogenated Solvent Cleaning rule. Additionally, for 

sources covered by the Halogenated Solvent Cleaning rule, we are also proposing a 2-

year compliance deadline from the date that this action becomes final because we are 

allowed to reset the compliance period when we make substantial changes and 

amendments to the existing standards in a subsequent rulemaking. We are seeking public 

comment on the particular issues identified below for which we are granting 

reconsideration, on our response to those issues, and on proposed regulatory options that 

are discussed below. 

 We are not reopening any other portions of the Halogenated Solvent Cleaning Rule for 

either public comment or reconsideration and we will not respond to any comments addressing 

other aspects of the Halogenated Solvent Cleaning Rule beyond those discussed in this notice. 

Further, our final decision on certain issues that we are not granting reconsideration will be 

issued no later than the date by which we take final action on the issues discussed in this action. 

II. Profile of Affected Industries Under This Proposal 

Halogenated solvent cleaners are found primarily in manufacturing industries found in 

NAICS codes 332999, 337124, 335999, 336999, 332116, and 336 and 339. A description of 

each of these NAICS codes is contained below. 

 

NAICS 332999: All Other Miscellaneous Fabricated Metal Product Manufacturing. This U.S. 

industry comprises establishments primarily engaged in manufacturing fabricated metal products 

(except forgings and stampings, cutlery and handtools, architectural and structural metals, 

boilers, tanks, shipping containers, hardware, spring and wire products, machine shop products, 

turned products, screws, nuts and bolts, metal valves, ball and roller bearings, ammunition, small 

arms and other ordnances, fabricated pipes and pipe fittings, industrial patterns, and enameled 

iron and metal sanitary ware). 

NAICS 331210: Iron and Steel Pipe and Tube Manufacturing Industry. The iron and steel pipe 

and tube manufacturing industry is defined as all establishments primarily engaged in 

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manufacturing welded, riveted, or seamless pipe and tube from purchased iron or steel. 

NAICS 337124: Metal Household Furniture Manufacturing. This U.S. industry comprises 

establishments primarily engaged in manufacturing metal household-type furniture and 

freestanding cabinets. The furniture may be made on a stock or custom basis and may be 

assembled or unassembled (i.e., knockdown). 

NAICS 335999: All Other Miscellaneous Electrical Equipment and Component Manufacturing. 

This U.S. industry comprises establishments primarily engaged in manufacturing industrial and 

commercial electric apparatus and other equipment (except lighting equipment, household 

appliances, transformers, motors, generators, switchgear, relays, industrial controls, batteries, 

communication and energy wire and cable, wiring devices, and carbon and graphite products). 

This industry includes power converters (i.e., AC to DC and DC to AC), power supplies, surge 

suppressors, and similar equipment for industrial-type and consumer-type equipment. 

NAICS 336999: All Other Transportation Equipment Manufacturing. This U.S. industry 

comprises establishments primarily engaged in manufacturing transportation equipment (except 

motor vehicles, motor vehicle parts, boats, ships, railroad rolling stock, aerospace products, 

motorcycles, bicycles, armored vehicles and tanks). 

NAICS 332116: Metal Stamping. This U.S. industry comprises establishments primarily 

engaged in manufacturing unfinished metal stampings and spinning unfinished metal products 

(except crowns, cans, closures, automotive, and coins). Establishments making metal stampings 

and metal spun products and further manufacturing (e.g., machining, assembling) a specific 

product are classified in the industry of the finished product. Metal stamping and metal spun 

products establishments may perform surface finishing operations, such as cleaning and 

deburring, on the products they manufacture. 

NAICS 336: Transportation Equipment Manufacturing. Industries in the Transportation 

Equipment Manufacturing subsector produce equipment for transporting people and goods. 

Transportation equipment is a type of machinery. An entire subsector is devoted to this activity 

because of the significance of its economic size in all three North American countries. 

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NAICS 339: Miscellaneous Manufacturing. Industries in the Miscellaneous Manufacturing 

subsector make a wide range of products that cannot readily be classified in specific NAICS 

subsectors in manufacturing. Processes used by these establishments vary significantly, both 

among and within industries. For example, a variety of manufacturing processes are used in 

manufacturing sporting and athletic goods that include products, such as tennis racquets and golf 

balls. The processes for these products differ from each other, and the processes differ 

significantly from the fabrication processes used in making dolls or toys, the melting and shaping 

of precious metals to make jewelry, and the bending, forming, and assembly used in making 

medical products. 

NAICS 5121: Motion Picture and Video Industries. This industry group comprises 

establishments primarily engaged in the production and/or distribution of motion pictures, 

videos, television programs, or commercials; in the exhibition of motion pictures; or in the 

provision of postproduction and related services. 

Table 1 provides percentages of the number of firms and establishments (or facilities) for 

many of the industries in the NAICS codes listed above. 

Table 1. Percentage of Firms and Establishments with Less than 500 Employees for 

Selected Industries by NAICS Code 

NAICS Code Firms (%) Establishments (%) 

332999 97.38% 96.39% 

337124 95.87% 90.45% 

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335999 92.14% 90.40% 

336999 94.52% 90.98% 

332116 95.11% 92.51% 

336 94.39% 80.95% 

339 98.59% 96.07% 

(Information obtained from Statistics of U.S. Businesses, 2001, U.S. Census Bureau.) 

 We see from this table that these industries are largely dominated by small businesses and 

establishments (or facilities). We also note that certain non-manufacuring industries such as 

railroad (NAICS 482), bus (NAICS 485), aircraft (NAICS 481), and truck (NAICS 484) 

maintenance facilities; automotive and electric tool repair shops (NAICS 811); and automobile 

dealers (NAICS 411) also use halogenated solvent cleaning machines. Detailed information on 

the industries affected by this proposed rule can be found in the industry profile for this 

rulemaking.5

 

5

 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. “Industry Profile for Some 

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Economic Growth For These Industries:

 A projection of the average annual rate of change in output from 2002 to 2012 for 4-digit 

NAICS codes for these industries shows expected output increases ranging from 1.2 to 5.2 % 

(Monthly Labor Review, Bureau of Labor Statistics, February 2004). Thus, moderate economic 

growth is expected in these industries over the next several years. 

 

III. Background for This Proposed Action

A. Statutory authority for regulating hazardous air pollutants (HAP)

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to 

address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, 

after EPA has identified categories of sources emitting one or more of the HAP listed in the 

CAA section 112(d) calls for us to promulgate national technology-based emission standards for 

sources within those categories that emit or have the potential to emit any single HAP at a rate of 

10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year 

(known as “major sources”), as well as for certain “area sources” emitting less than those 

amounts. These technology-based standards must reflect the maximum reductions of HAP 

achievable (after considering cost, energy requirements, and non-air health and environmental 

impacts) and are commonly referred to as maximum achievable control technology (MACT) 

standards. 

For area sources, CAA section 112(d)(5) provides that the standards may reflect 

generally available control technology or management practices in lieu of MACT, and are 

commonly referred to as generally available control technology (GACT) standards. 

 EPA is then required to review these technology-based standards and to revise them “as 

necessary, taking into account developments in practices, processes and control technologies,” 

no less frequently than every eight years. 

 CAA section 112(f)(2) requires us to determine for each section 112(d) source category 

whether the MACT standards protect public health with an ample margin of safety. If the MACT 

 

Industries Affected by the Halogenated Solvent Cleaning Reconsideration Proposal.” Draft Report. July 2008. 

Prepared by the Research Triangle Institute. 

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standards for HAP “classified as a known, probable, or possible human carcinogen do not reduce 

lifetime excess cancer risks to the individual most exposed to emissions from a source in the 

category or subcategory to less than 1-in-1 million,” EPA must promulgate residual risk 

standards for the source category (or subcategory) as necessary to provide an ample margin of 

safety. The EPA must also adopt more stringent standards to prevent an adverse environmental 

effect (defined in CAA section 112(a)(7) as “any significant and widespread adverse effect * * * 

to wildlife, aquatic life, or natural resources * * *.”), but must consider cost, energy, safety, and 

other relevant factors in doing so. 

B. Halogenated solvent cleaning – background on processes

 Halogenated solvent cleaning machines use halogenated solvents (methylene chloride, 

perchloroethylene, trichloroethylene, 1,1,1,-trichloroethane, carbon tetrachloride, and 

chloroform), halogenated solvent blends, or their vapors to remove soils such as grease, oils, 

waxes, carbon deposits, fluxes, and tars from metal, plastic, fiberglass, printed circuit boards, and 

other surfaces. Halogenated solvent cleaning is typically performed prior to processes such as 

painting, plating, inspection, repair, assembly, heat treatment, and machining. Types of solvent 

cleaning machines include, but are not limited to, batch vapor, in-line vapor, in-line cold, and 

batch cold solvent cleaning machines. Buckets, pails, and beakers with capacities of 7.6 liters (2 

gallons) or less are not considered solvent cleaning machines. 

 Halogenated solvent cleaning does not constitute a distinct industrial category, but is an 

integral part of many major industries. Based on data in our latest National Emissions Inventory 

(NEI), the five 3-digit NAICS Code that use the largest quantities of halogenated solvents for 

cleaning are NAICS 337 (furniture and related products manufacturing), NAICS 332 (fabricated 

metal manufacturing), NAICS 335 (electrical equipment, appliance, and component 

manufacturing), NAICS 336 (transportation equipment manufacturing), and NAICS 339 

(miscellaneous manufacturing). Additional industries that use halogenated solvents for cleaning 

include NAICS 331 (primary metals), NAICS 333 (machinery), and NAICS 334 (computer and 

electronic equipment man.). Non-manufacturing industries such as railroad (NAICS 482), bus 

(NAICS 485), aircraft (NAICS 481), and truck (NAICS 484) maintenance facilities; automotive 

and electric tool repair shops (NAICS 811); and automobile dealers (NAICS 411) also use 

halogenated solvent cleaning machines. 

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 We estimated that there were approximately 16,400 batch vapor, 8,100 in-line, and 

perhaps as many as 100,000 batch cold cleaning machines in the U.S. prior to promulgation of 

the MACT standards. More recent information shows that the current number of cleaning 

machines is much lower than these pre-MACT estimates. We currently estimate the number of 

sources in this source category to be about 3,800 cleaning machines located at 1,900 facilities in 

the U.S. This estimate is based on information we collected in 1998, a year after compliance 

with the MACT occurred and should reflect the decreases in HAP emissions and demand that 

were expected due to implementation of MACT control technologies and work practice 

standards. More recent evidence on solvent usage suggests that the number of sources in the 

source category may have declined further in the post-MACT implementation years. An analysis 

of market data for halogenated solvents showed that the demand for degreasing solvents declined 

substantially in the five years following the implementation of the MACT standard. From 1998 

to 2003, the demand for tetrachloroethylene, trichloroethylene, methylene chloride, and 1,1,1-

trichloroethane for use in degreasing decreased by 39 percent, 35 percent, 23 percent, and 15 

percent, respectively. 

There are two basic types of solvent cleaning machines: batch cleaners and in-line 

cleaners. Both cleaner types can be designed to use either solvent at room temperature (cold 

cleaners) or solvent vapor (vapor cleaners). The vast majority of halogenated solvent use is in 

vapor cleaning, both batch and in-line. The most common type of batch cleaner that uses 

halogenated solvent is the open-top vapor cleaner (OTVC). 

 Batch cleaning machines, which are the most common type, are defined as a solvent 

cleaning machine in which individual parts or sets of parts move through the entire cleaning 

cycle before new parts are introduced. Batch cleaning machines include cold and vapor 

machines. In batch cold cleaning machines, the material being cleaned (i.e., the workload) is 

immersed, flushed, or sprayed with liquid solvent at room temperature. Most batch cold cleaners 

are small maintenance cleaners (e.g., carburetor cleaners) or parts washers that often use nonHAP solvent mixtures for cleaning. Batch cold cleaning equipment sometimes includes agitation 

to improve cleaning efficiency. 

 In batch vapor cleaning machines, parts are lowered into an area of dense vapor solvent 

for cleaning. The most common type of batch vapor cleaner is the open-top vapor cleaner. 

Heating elements at the bottom of the cleaner heat the liquid solvent to above its boiling point. 

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Solvent vapor rises in the machine to the height of chilled condensing coils on the inside walls of 

the cleaner. The condensing coils cool the vapor causing it to condense and return to the bottom 

of the cleaner. Cleaning occurs in the vapor zone above the liquid solvent and below the 

condensing coils, as the hot vapor solvent condenses on the cooler workload surface. The 

workload or a parts basket is lowered into the heated vapor zone with a mechanical hoist. 

 Batch vapor cleaning machines vary greatly in size and design to suit applications in 

many industries. Batch vapor cleaner sizes are defined by the area of the solvent/air interface. 

Emissions from batch cold cleaning machines result from evaporation of solvent from the 

solvent/air interface, "carry out" of excess solvent on cleaned parts, and other evaporative losses 

such as those that occur during filling and draining. Evaporative emissions from the solvent/air 

interface are continual whether or not the machine is in use. These evaporative losses can be 

reduced by limiting air movement over the solvent/air interface (e.g., with a machine cover or by 

reducing external drafts) or by limiting the area of solvent air interface (e.g., with a floating 

water layer). Emissions related to solvent carry out occur only when the cleaning machine is in 

use. 

 The closed-loop cleaning system is a type of batch cleaner with a closed system capable 

of reusing solvent. Parts are placed inside a vacuum chamber. Vapor or liquid solvent is pumped 

in the chamber to clean the parts. Once cleaned, the parts are dried under vacuum and removed; 

the solvent is removed and recycled. Because these systems are constructed to maintain a 

vacuum, they have the potential to reduce emissions up to 95 percent. 

 Cold and vapor in-line (i.e., conveyorized) cleaning machines, which include continuous 

web cleaners, employ automated parts loading and are used in applications where there is a 

constant stream of parts to be cleaned. In-line cleaners usually are used in large-scale industrial 

operations (e.g., auto manufacturing) and are custom-designed for specific workload and 

production characteristics (e.g., workload size, shape, and production rate). In-line cleaners 

clean parts using the same general techniques used in batch cleaners: cold in-line cleaners spray 

or immerse parts in solvent, and vapor in-line cleaners clean parts in a zone of dense vapor 

solvent. 

 Emissions from cold and vapor in-line cleaning machines result from the same 

mechanisms (e.g., evaporation, diffusion, carryout) that cause emissions from cold and vapor 

batch cleaning machines. However, the emission points for in-line cleaners are different from 

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those for batch cleaners because of differences in machine configurations. In-line cleaning 

machines are semi-enclosed above the solvent/air interface to control solvent losses. In most 

cases, the only openings are the parts entry and exit ports. These openings are the only emissions 

points for downtime and idling modes. Carryout emissions add to emissions during the working 

mode. Idling and working mode emissions from the in-line cleaner are significantly less than 

emissions from an equally-sized batch vapor cleaner. However, in-line cleaners tend to be much 

larger than batch vapor cleaners. Some in-line cleaners have exhaust systems that pump air from 

inside the cleaning machine to an outside vent. Exhaust systems for in-line cleaners reduce 

indoor emissions from the cleaning machine but increase solvent consumption. 

Continuous web cleaners are a subset of in-line cleaners and are used to clean products 

such as films, sheet metal, and wire in rolls or coils. The workload is uncoiled and conveyorized 

throughout the cleaning machine at speeds in excess of 11 feet per minute and recoiled or cut as 

it exits the machine. Emission points from continuous cleaners are similar to emission points 

from other inline cleaners. Continuous cleaners are semi-enclosed, with emission points where 

the workload enters and exits the machine. Squeegee rollers reduce carry out emissions by 

removing excess solvent from the exiting workload. Some continuous machines have exhaust 

systems similar to those used with some other in-line cleaners. 

C. Health effects from exposure to halogenated solvents

 Methylene chloride, perchloroethylene, trichloroethylene, and 1,1,1,-trichlorothane are 

the primary halogenated solvents used for solvent cleaning. Although production of 1,1,1,-

trichlorothane has ceased in the United States, a declining quantity of stockpiled TCA continues 

to be used. Carbon tetrachloride and chloroform are no longer used as degreasing solvents. 

Therefore, their health effects are not of a concern in this action. 

 Methylene chloride is predominantly used as a solvent. The acute effects of methylene 

chloride inhalation in humans consist mainly of nervous system effects including decreased 

visual, auditory, and motor functions, but these effects are reversible once exposure ceases. The 

effects of chronic exposure to methylene chloride suggest that the central nervous system is a 

potential target in humans and animals. Human data are inconclusive regarding methylene 

chloride and cancer. Animal studies have shown increases in liver and lung cancer and benign 

mammary gland tumors following the inhalation of methylene chloride. EPA has classified 

methylene chloride as a Group B2, probable human carcinogen. EPA is currently reassessing its 

17
potential toxicity/carcinogenicity. All activities related to this reassessment are expected to be 

complete by the middle of 2009. 

Perchloroethylene (or Tetrachloroethylene) is widely used for dry-cleaning fabrics and 

metal degreasing operations. The main health effects of PCE are neurological, liver, and kidney 

damage following acute (short-term) and chronic (long-term) inhalation exposure. Animal 

studies have reported an increased incidence of liver cancer in mice via inhalation, kidney 

cancer, and mononuclear cell leukemia in rats. PCE was considered to be a “probable 

carcinogen” (Group B) when assessed under the previous 1986 Guidelines by the EPA Science 

Advisory Board. EPA is currently reassessing its potential carcinogenicity. All activities related 

to this reassessment are expected to be complete by late 2008. 

 The acute inhalation exposure effects from 1,1,1-trichloroethane include hypotension, 

mild hepatic effects, and central nervous system depression. Cardiac arrhythmia and respiratory 

arrest may result from the depression of the central nervous system. Symptoms of acute 

inhalation exposure include dizziness, nausea, vomiting, diarrhea, loss of consciousness, and 

decreased blood pressure in humans. After chronic inhalation exposure to 1,1,1-trichloroethane, 

some liver damage was observed in mice and ventricular arrhythmias were observed in humans. 

EPA has classified 1,1,1-trichloroethane as a Group D, not classifiable as to human 

carcinogenicity. 

Most of the trichloroethylene used in the United States is released into the atmosphere 

from industrial degreasing operations. Acute and chronic inhalation exposure to 

trichloroethylene can affect the human central nervous system, with symptoms such as dizziness, 

headaches, confusion, euphoria, facial numbness, and weakness. Liver, kidney, immunological, 

endocrine, and developmental effects have also been reported in humans. A recent analysis of 

available epidemiological studies reports trichloroethylene exposure to be associated with several 

types of cancers in humans, especially kidney, liver, cervix, and lymphatic system. Animal 

studies have reported increases in lung, liver, kidney, and testicular tumors and lymphoma. EPA 

has classified trichloroethylene as a Group B2/C, an intermediate between a probable and 

possible human carcinogen. EPA should complete its reassessment of the cancer classification of 

trichloroethylene by late 2010. 

 Toxicity or status information for the four HAPs may be obtained from the following 

websites: EPA’s Toxicity database at http://www.epa.gov/ttn/atw/toxsource/table1.pdf shows 

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the benchmarks for the four HAPs used in the risk assessment. Specific information underlying 

the values used may be found at the following locations: California EPA’s website at 

http://www.oehha.ca.gov/air/hot_spots/index.html has the background information on PCE and 

TCE used to develop the cancer potency values. 

The Agency for Toxic Substances and Disease Registry’s website at 

http://www.atsdr.cdc.gov/toxpro2.html has the background information used to develop the noncancer values for MC and PCE. 

EPA’s IRIS website at http://www.epa.gov/iris/index.html provides the information supporting 

the cancer potency value for MC. 

Status reports for IRIS chemical reassessments, (i.e., TCA) are available at 

http://cfpub.epa.gov/iristrac/index.cfm. 

IV. Summary of the Proposed Action 

A. Requirements for major and area sources

 In this action, we are proposing that the risk associated with the 1994 NESHAP for the 

halogenated solvent cleaning source category is acceptable. We are also proposing various 

regulatory options that would provide an ample margin of safety to protect public health and 

prevent adverse environmental effects. These proposed requirements would apply to owners and 

operators of halogenated solvent cleaning machines that are subject to the 1994 NESHAP. 

Additionally, we are proposing that such standards would satisfy our obligations under both 

CAA sections 112(d)(6) and 112(f)(2). In this action we are proposing a 2-year compliance 

deadline from the date that this action becomes final for existing sources not covered by the 

Halogenated Solvent Cleaning rule. Additionally, for sources covered by the Halogenated 

Solvent Cleaning rule, we are also proposing a 2-year compliance deadline from the date that this 

action becomes final because we are allowed to reset the compliance period when we make 

substantial changes and amendments to the existing standards in a subsequent rulemaking. We 

are seeking public comment on the particular issues identified below for which we are granting 

reconsideration, on our response to those issues, and on proposed regulatory options that are 

discussed below. 

 We are not reopening any other portions of the Halogenated Solvent Cleaning Rule for 

either public comment or reconsideration and we will not respond to any comments addressing 

other aspects of the Halogenated Solvent Cleaning Rule beyond those discussed in this notice. 

19
Further, our final decision on certain issues that we are not granting reconsideration will be 

issued no later than the date by which we take final action on the issues discussed in this action. 

B. What is the reason for our proposed action? 

 On August 17, 2006, we proposed revised standards (71 FR 47670, August 17, 2006) to 

further limit emissions of MC, TCE and PCE from facilities engaged in halogenated solvent 

cleaning, pursuant to CAA section 112(f). We co-proposed emissions limits of 25,000 kg/yr MC 

and 40,000 kg/yr MC equivalent to provide an ample margin of safety to protect public health 

and prevent adverse environmental effects. We had also developed six options to limit emissions 

to evaluate reductions in residual risk if post-MACT emissions (i.e., baseline emissions) were 

controlled further from this source category. These emissions levels included the 60,000 and 

100,000 kg/yr MC-equivalent levels. 71 FR 47680-81. We indicated that we expected to finalize 

one of the co-proposed options, and that it would be applicable to the entire source category in 

addition to the 1994 NESHAP requirements. We also proposed a compliance deadline of 2 years 

after the effective date of the final rule. 

 Industry, states, solvent manufacturers, industry trade associations and district air 

associations submitted comments in response to our proposal. Industry’s comments were 

primarily submitted by the aerospace manufacturing and maintenance industry, the narrow 

tubing manufacturing industry, facilities that use continuous web cleaning machines, and 

military maintenance and depot facilities. Responses focused on associated compliance costs, 

technical feasibility, and the proposed compliance deadline. In response to these comments, we 

issued a Notice of Data Availability (NODA), on December 14, 2006 (71 FR 75182), requesting 

specific information on compliance costs, technical feasibility, and compliance deadlines as they 

relate to halogenated solvent machines used by the above referenced industries. Responses to 

the NODA provided significant data and information that led EPA to re-evaluate data and 

assumptions used to estimate risks, costs and technical feasibility of compliance with the coproposed emissions limits. 

 In the Halogenated Solvent Cleaning rule, we presented our re-evaluation of risks, costs 

and technical feasibility of compliance with the co-proposed emissions limits.6

 As a result of 

 

6 We re-evaluated risks using more recent inventory data and modified our cost estimates in 

response to public comment. The most important change we made is that we re-analyzed the 

risk metrics and costs using the halogenated solvent cleaning facilities in the finalized 2002 NEI, 

and conducted separate assessments of four specific industry sectors —aerospace manufacture 

20
our re-evaluation, in the Halogenated Solvent Cleaning rule, we promulgated a facility-wide 

emission limit of 60,000 kg/yr MC equivalent for all halogenated solvent cleaning machines with 

the exception of halogenated solvent cleaning machines used by facilities that manufacture 

narrow tubing, facilities that manufacture specialized products requiring continuous web 

cleaning, aerospace manufacturing and maintenance facilities, and military maintenance and 

depot facilities. We concluded that this emission limit would provide an ample margin of safety 

to protect health and prevent adverse environmental effects. For all halogenated solvent cleaning 

machines used at military depot and maintenance facilities we promulgated a facility-wide 

emission limit of 100,000 kg/yr MC equivalent that would provide an ample margin of safety to 

protect health and prevent adverse environmental effects. We also set a compliance deadline of 

3 years from the effective date of the Halogenated Solvent Cleaning rule. Finally, with regard to 

continuous web cleaning machines and halogenated solvent cleaning machines used by narrow 

tubing and aerospace manufacturing and maintenance facilities, we found that the current level 

of control required by the 1994 NESHAP reduces hazardous air pollutant emissions to levels that 

provide an ample margin of safety to protect public health and prevent any adverse 

environmental effects. 

In general, petitioners allege that the 60,000 kg/yr and 100,000 kg/yr MC equivalent 

limits, our conclusion that the current level of controls for aerospace manufacturing and 

maintenance facilities, narrow tubing manufacturing facilities, and continuous web cleaning 

machines prescribed by the 1994 NESHAP both reduce risk to acceptable levels and provide an 

ample margin of safety to protect public health, and the 3-year compliance deadline, appeared for 

the first time in the Halogenated Solvent Cleaning rule making it impracticable to raise 

objections during the period provided for public comment. Petitioners further contend that we 

re-evaluated the proposed risk assessment, ample margin of safety decision, technical feasibility 

and associated compliance costs without providing notice and opportunity for comment. 

Specifically, 

- Several petitioners stated that the Agency’s decision to use available data from the 

2002 National Emission Inventory (NEI), instead of data from the 1999 NEI as 

 

and maintenance facilities, narrow tube manufacturing facilities, facilities using continuous web 

cleaning machines, and military equipment maintenance facilities— as well as for the set of 

remaining facilities that are not in one of these four sectors. 

21
proposed, appeared for the first time in the Halogenated Solvent Cleaning rule, 

making it impracticable to raise objections during the period provided for public 

comment. 

- Petitioners contend that EPA co-proposed only two standards-25,000 kg/yr MC 

and 40,000 kg/yr MC equivalent limits-that would be applicable to the entire 

source category but that the final 60,000 kg/yr MC equivalent limit that is 

applicable to all new and existing halogenated solvent cleaning machines, with 

the exception of halogenated solvent cleaning machines used by military depot 

and maintenance facilities, aerospace manufacturing and maintenance, narrow 

tubing manufacturing and continuous web cleaning machines, appeared for the 

first time in the Halogenated Solvent Cleaning rule, making it impracticable to 

raise objections during the period provided for public comment. 

- Petitioners state that the final facility-wide limit of 100,000 kg/yr MC equivalent 

limit that is applicable to emissions from halogenated solvent cleaning machines 

used at military depot and maintenance facilities appeared for the first time in the 

Halogenated Solvent Cleaning rule, making it impracticable to raise objections 

during the period provided for public comment. 

- Petitioners contend that our conclusion that the current level of controls 

prescribed by the 1994 NESHAP both reduces risk to acceptable levels and 

provides an ample margin of safety for halogenated solvent cleaning machines 

used by the aerospace manufacturing and maintenance, narrow tubing 

manufacturing and continuous web cleaning machines, also appeared for the first 

time in the Halogenated Solvent Cleaning rule, also making it impracticable to 

raise objections during the period provided for public comment. 

- Petitioners believe that EPA re-evaluated the August 17, 2006 proposed technical 

feasibility with respect to the narrow tube manufacturing facilities; aerospace 

manufacturing and maintenance facilities; military depot and maintenance 

facilities; and manufacturers that use continuous web cleaners, without providing 

notice and an opportunity for public comment. 

- Some petitioners believe that subsequent to the August 17, 2006 proposal and 

December 15, 2006 NODA, EPA re-evaluated the compliance costs for the 

22
Halogenated Solvent Cleaning Rule without providing additional public 

comment. 

- One petitioner stated that the 3-year compliance period appeared for the first time 

in the Halogenated Solvent Cleaning rule, making it impracticable to raise 

objections during the period provided for public comment. 

Petitioners also provided information on technical feasibility that was otherwise not 

available to EPA at the time of promulgation of the Halogenated Solvent Cleaning rule showing 

certain narrow tubing manufacturers either taking steps or planning to take steps at emissions 

reductions subsequent to promulgation of the Halogenated Solvent Cleaning rule. This 

information is discussed in greater detail below. 

In response to the petitions, we are reconsidering our conclusions on technical feasibility, 

the compliance deadline, health risks, and compliance costs presented in the Halogenated 

Solvent Cleaning Rule. 

What are the Proposed Options for Halogenated Solvent Cleaning Machines? 

Similar to the approach taken in our August 17, 2006, proposal and discussed in the 

Halogenated Solvent Cleaning rule, we have evaluated a range of regulatory options and have 

assessed the residual risk reductions that could be achieved if post-MACT HAP emissions were 

controlled further. These options incorporate MC-equivalent based emission limits as we 

continue to believe that such emission limits (e.g., as promulgated in the Halogenated Solvent 

Cleaning rule that is the subject of today’s reconsideration) may provide an opportunity for 

additional risk reduction. These options were derived from information on the availability and 

feasibility of specific emission control technologies or practices, but are expressed as maximum 

facility-wide emissions limits and requirements that would apply to the total emissions from all 

of a facility’s solvent cleaning machines that are subject to the 1994 MACT standards. We have 

produced additional risk and cost analyses to support the evaluation of these proposed regulatory 

options. This proposal also reflects our investigations of information received subsequent to 

promulgation of the Halogenated Solvent Cleaning rule and our belief based on that information 

that certain emissions limits could be achieved through both solvent switching and traditional 

technologies and practices for some sectors of the category. We will take final action that will 

provide an ample margin of safety to protect public health and prevent adverse environmental 

effects. We expect our final action for the affected sources will be one of the regulatory options 

23
discussed below, or an option that falls within the range of the options discussed below. 

Specifically, comments on these proposed options may lead us to conclude that emissions limits 

and requirements are called for that do not fit within the bounds of one of the presented options. 

To that extent this proposal recognizes the likelihood of such a result, we are presenting 

estimated risk reductions and the associated costs for specific emissions limits and requirements 

discussed in this preamble. This approach differs from our August 17, 2006, proposal where we 

explicitly solicited comments on only two co-proposed options, although we had also developed 

six emissions levels to evaluate reductions in residual risk if post-MACT emissions (i.e., baseline 

emissions) were controlled further from this source category. These emissions levels included 

the 60,000 kg/yr and 100,000 kg/yr emission cap levels. We recognize that some commenters 

may either endorse aspects of one or more regulatory options or advocate for a combination of 

the options in ways other than presented in this proposal. We are also soliciting comments on 

any combination or variation of the proposed options identified in this proposal. Our decision on 

the final regulatory approach will reflect the comments we receive. The options, presented in 

terms of increasing stringency of control, are summarized below: 

i. Proposed Option 1 

A 60,000 kg/yr MC equivalent limit would be applicable to sources associated with the 

general population of halogenated solvent cleaning machines. A 100,000 kg/yr MC equivalent 

limit would be applicable to halogenated solvent cleaning machines located at military 

maintenance and depot facilities. With respect to continuous web cleaning machines, 

halogenated solvent cleaning machines used by narrow tubing facilities, and halogenated solvent 

cleaning machines used by aerospace manufacturing and maintenance facilities, we are 

proposing to re-adopt the 1994 NESHAP under CAA section 112(f)(2) because we are proposing 

that the current level of control called for by the 1994 NESHAP reduces HAP emissions to levels 

that present an acceptable level of risk, provide an ample margin of safety to protect public 

health, and prevent any adverse environmental effects. (This option represents all standards 

promulgated in the Halogenated Solvent Cleaning rule last May.) 

ii. Proposed Option 2 

A 60,000 kg/yr MC equivalent limit would be applicable to sources associated with the 

general population of halogenated solvent cleaning machines and halogenated solvent cleaning 

24
machines used by narrow tube facilities. A 100,000 kg/yr MC equivalent limit would be 

applicable to halogenated solvent cleaning machines located at military maintenance and depot 

facilities. With respect to continuous web cleaning machines, and halogenated solvent cleaning 

machines used by aerospace manufacturing and maintenance facilities, we also are proposing to 

re-adopt the 1994 NESHAP under CAA section 112(f)(2) because we are proposing that the 

current level of control called for by the 1994 NESHAP reduces HAP emissions to levels that 

present an acceptable level of risk, provide an ample margin of safety to protect public health, 

and prevent any adverse environmental effects. 

iii. Proposed Option 3 

A 60,000 kg/yr MC equivalent limit would be applicable to sources associated with the 

general population of halogenated solvent cleaning machines and halogenated solvent cleaning 

machines used by narrow tube facilities. A 100,000 kg/yr MC equivalent limit would be 

applicable to halogenated solvent cleaning machines used by aerospace manufacturing facilities 

and halogenated solvent cleaning machines located at maintenance and military maintenance and 

depot facilities. Facilities whose continuous web machines exceed 60,000 kg/yr MC equivalent 

HAP emissions would have to achieve 80 percent control efficiency for those units. 

This proposal notice of reconsideration is based on data and information used to support 

the Halogenated Solvent Cleaning Rule (and contained in the docket for that rule) and data and 

information received since promulgation of the Halogenated Solvent Cleaning rule. Data and 

information received since promulgation of the Halogenated Solvent Cleaning rule indicates the 

availability of control measures that would enable certain facilities to achieve HAP emissions 

reductions that we did not believe feasible when we finalized the Halogenated Solvent Cleaning 

rule. 

 All this information leads us to believe that certain facilities might be able to use control 

measures that include retrofit technologies, such as carbon adsorption device (CAD), and 

vacuum-to-vacuum machines, switching from HAP to non-HAP solvents, such as n-propyl 

bromide (nPB7), changes to manufacturing process, and instituting emissions reductions 

 

7 The Agency has addressed the use of nPB as a solvent in industrial equipment for metals cleaning, electronics 

cleaning and precision cleaning under the Significant New Alternative Policy Program (“SNAP”). Under SNAP, 

EPA reviews substitutes for ozone depleting substances and to determine if a substitute would pose a substantially 

greater risk to human health of the environment than other substitutes that are available. See CAA section 612(c), 

40 CFR Part 82, subpart G. Specifically, based on evidence that in those solvent cleaning end users nPB could be 

25
programs. Further, as in our Halogenated Solvent Cleaning rule, this proposal recognizes and 

reflects the differences between continuous web cleaners and batch cleaning machines 

acknowledging comments on the August 17, 2006 proposal and subsequent NODA indicating 

that control efficiency requirements rather than straight emissions limits are a preferable 

approach for expressing emissions limitations for continuous web cleaning machines because 

continuous web cleaning machines must control emissions at both entry and exit points. In the 

Halogenated Solvent Cleaning rule, we noted that some facilities that use continuous web 

cleaning machines suggested that their emission capture systems could be modified within a 

three-year period to achieve 80 percent overall control efficiency as compared to their current 

emissions levels. In today’s action, we are also soliciting comments on whether emission 

capture systems operating at high efficiency would provide an opportunity for facilities using 

these machines to control up to 80 percent of their emissions.

 i. Narrow Tube Manufacturing Facilities 

 Petitioners contend that we failed to consider and evaluate various compliance options for 

the narrow tubing manufacturing industry despite responses and comments we received on both 

our August 17, 2006 proposal and NODA. Petitioners cite comments and responses to both the 

August 17, 2006 proposal and the subsequent NODA from several narrow tubing manufacturers 

indicating the likelihood of 35 percent TCE emissions reductions through installation of CAD 

and a capture and control system. Petitioners cite responses by various narrow tubing facilities 

indicating an ability to achieve emissions reductions ranging from either 25-35 percent or 50-95 

percent through installation of emissions control devices and changes in production processes. 

Petitioners further argue that we should have investigated the feasibility of establishing a 

100,000 kg/yr MC emission limit given the response of one narrow tubing manufacturer 

indicating the ability to meet this level within 5 years of promulgation. EPA did not develop this 

option for two reasons: first, Congress limits EPA’s ability to impose compliance periods that 

exceed three years, and; second, the industrial sector commented that they simply could not 

implement the necessary technology within that time period and within the cost parameters EPA 

assumed in the August 17, 2006 proposal. Subsequent to promulgation of the Halogenated 

 

used as safely as other available substitutes, EPA found nPB acceptable as a substitute for methyl chloroform and 

CFC-113, (72 FR 30142 (May 30, 2007). While under SNAP no restrictions were placed on the use of nPB in the 

solvent cleaning end uses addressed in the rule, it does not relieve users from the obligation to comply with any 

other regulatory obligations, such as those that might apply under the 1994 NESHAP. 

26
Solvent Cleaning rule, information was provided to EPA that this industrial sector may, in fact, 

be capable of complying with the 60,000 kg/yr MC equivalent level within the compliance 

period. 

 Petitioners also provide information indicating that subsequent to close of the comment 

period of the Halogenated Solvent Cleaning rule various narrow tubing manufacturers either 

installed control devices or were in advanced planning stages to install control devices that 

would enable them achieve either of our August 17, 2006 co-proposed emissions limits. 

Specifically, subsequent to promulgation of the Halogenated Solvent Cleaning rule, one narrow 

tubing manufacturer has installed vacuum-to-vacuum machines, and another has switched from 

solvent HAP to non-HAP, such as nPB. Petitioners also provided information indicating that yet 

another narrow tubing manufacturer was in advanced installation stages for CAD and a capture 

and control system that would likely achieve 30 percent TCE reduction, while still another 

narrow tubing manufacturer had indicated an ability to achieve 8 percent and 22 percent TCE 

emissions reductions through reconfiguration of two flush degreasers and use of reformulated 

materials, respectively. This information and supporting documentation have been placed in the 

docket for this rulemaking. 

As explained earlier, our August 17, 2006, proposal would have required all owners and 

operators of all halogenated solvent cleaning machines to comply with either 25,000 kg/yr or 

40,000 kg/yr MC equivalent facility-wide emission limit. We assumed compliance with these 

limits could be achieved by installation of control technologies, such as vacuum-to-vacuum 

machines and CAD, and switching solvents, either from PCE to TCE or TCE to MC. We also 

assumed compliance would be achieved through retrofit technologies such as freeboard ratios, 

working mode covers and freeboard refrigeration devices. In commenting on our August 17, 

2006 proposal, various narrow tubing manufacturers indicated that further HAP control that 

would be required by the co-proposed standards would likely be achieved only through 

installation of expensive technology, and that such technologies had yet to be proven either 

effective or reliable for their manufacturing processes. They also expressed concerns over the 

proposed compliance period. Additionally, several narrow tubing manufacturers that use PCE 

indicated that solvent switching was an unsuitable compliance option because they were bound 

to their customers’ procedural requirements for the higher vapor temperature of PCE and thus, 

that both TCE and MC, which have lower vapor pressure temperature, would be inadequate for 

27
proper cleaning. Although some narrow tubing manufacturers indicated the possibility of 

switching solvents from TCE to nPB, they also stated that it had yet to be proven as a degreaser 

and thus, had yet to be approved as an alternative solvent by many original equipment 

manufacturers. They further indicated that such approval processes would likely be beyond the 

proposed 2-year compliance period. Some narrow tube manufacturers also described their 

halogenated cleaning machines as unique due to their large sizes and capacity and indicated the 

non-availability of vacuum-to-vacuum machines as a result of this uniqueness. 

As explained above, subsequent to our evaluation of these comments, we issued a NODA 

that requested additional information on costs, compliance deadlines and technical feasibility for 

halogenated solvent cleaning at narrow tube manufacturers. In submitted responses, most 

narrow tubing manufacturers again reiterated their inability to comply with the co-proposed 

limits due to technological, costs and compliance deadline constraints. 

In the Halogenated Solvent Cleaning rule, because we were persuaded by these 

assertions, we found, after re-evaluating risks, associated compliance costs and availability of 

control measures, that the 1994 NESHAP both reduces risk to acceptable levels and provides an 

ample margin of safety to protect public health for halogenated solvent cleaning machines used 

by facilities that manufacture narrow tubing.

We are now aware, however, that since promulgation of the Halogenated Solvent 

Cleaning rule, four out of seventeen narrow tubing facilities have either implemented or 

instituted plans to install control measures and HAP reduction techniques that would likely 

achieve either of the August 17, 2006 co-proposed limits, i.e., 25,000 kg/yr and 40,000 k/yr MC 

equivalent limits. These control measures and HAP emission reduction techniques that have 

been implemented within the compliance period include installing CAD, and vacuum-to-vacuum 

machines, (installed by the narrow tubing manufacturer that indicated uniqueness of its 

halogenated solvent cleaning machines due to size, in its comments on the August 17, 2006 

proposal), switching to n-propyl bromide (a non-HAP solvent), and manufacturing process 

changes such as either cleaning smaller bundles of tubes and/or allowing product to remain in the 

machine for a longer duration and allowing complete condensation of the solvent vapors before 

removal. These accomplishments are applauded by EPA, yet appear to be in direct contrast with 

the responses to the August 17, 2006 proposal and subsequent NODA. 

 The remaining thirteen facilities continue to use HAP solvents and operate in accordance 

28
with the 1994 MACT standard. Four of these will already meet the 60,000 kg/yr MC equivalent 

limit, the most stringent emissions limit for narrow tube facilities considered in this proposal. 

We assume that these facilities employ certain techniques or technologies to reduce emissions, 

however, we believe the techniques and technologies employed by the three narrow tube 

manufacturing facilities may be used by the remaining facilities to achieve emissions limits of 

60,000 kg/yr MC equivalent. 

In light of the information that was otherwise not available to EPA at the time of 

promulgation of the Halogenated Solvent Cleaning rule, we have reviewed and revised our 

conclusion on technical feasibility, compliance deadline and compliance costs associated with 

meeting the August 17, 2006 co-proposed limits. With the activities completed by these narrow 

tube facilities, we believe that the remaining narrow tube facilities nationwide, most with smaller 

emission totals than the facilities mentioned above, could limit emissions quickly and with 

reasonable costs to comply with EPA’s emission limit. We believe that with the implementation 

of these control measures, narrow tubing manufacturers might achieve the 60,000 kg/yr MC 

equivalent emissions limits. Therefore, we are proposing a range of regulatory options that 

would be applicable to halogenated solvent cleaning machines in use at narrow tubing 

manufacturing facilities. We are soliciting comments on the proposed emission limits for 

narrow tube manufacturing facilities. 

2. What are the Requirements for Aerospace Manufacturing and Maintenance 

Facilities? 

Petitioners contend that the Halogenated Solvent Cleaning rule does not provide any 

explanation as to why vacuum-to-vacuum technology and retrofit technologies such as freeboard 

ratios, working mode covers and freeboard refrigeration devices cannot be used by aerospace 

manufacturing and maintenance facilities. One petitioner stated that there was no explanation for 

the rejection of vacuum-to-vacuum technology as a control option for aerospace manufacturing 

and maintenance facilities even though the Halogenated Solvent Cleaning rule indicated that it 

was in use by “similar” aerospace facilities.

In response to both our August 17, 2006 proposal, and subsequent NODA, aerospace 

manufacturing and maintenance facilities indicated an inability to comply with our co-proposed 

limits due to technical infeasibility, associated compliance costs and the limited proposed 

compliance deadline. Some facilities indicated a 5-year minimum compliance period would be 

29
required because they would need to investigate technology and protocol changes called for by 

the proposed 40,000 kg/yr limit. With regard to vacuum-to-vacuum technology, aerospace 

manufacturers indicated that vacuum-to-vacuum technology was extremely expensive and had 

not been proven effective or reliable for the operations at aerospace facilities. With regard to 

solvent switching, those aerospace manufacturing and maintenance facilities that use PCE stated 

that switching to TCE or MC would be an unsuitable compliance option due to incompatibility 

and lower vapor pressure. They also stated that changing solvents involved a rigorous approval 

process by the original equipment manufacturers and the Federal Aviation Administration in 

order to ensure that safety and quality criteria continue to be met and that such process would 

likely be beyond the 2-year proposed compliance deadline. 

 Similar to the narrow tubing manufacturers, we were persuaded by these responses and 

information and in the Halogenated Solvent Cleaning Rule, after our re-evaluation of compliance 

costs, technical feasibility and risks, we concluded that the current level of control provided by 

the 1994 NESHAP for the aerospace manufacturing and maintenance industry both reduces HAP 

emissions to levels that present an acceptable risk and provides an ample margin of safety to 

protect public health. 

Since receiving the petitions, we have re-evaluated our treatment of the responses to the 

NODA. Specifically, we have re-evaluated responses we received from various aerospace 

facilities indicating the availability of compliance options that include various work practices and 

installing larger or additional carbon adsorption systems, and vacuum-to-vacuum machines. 

Aerospace industries indicated that there may be opportunities for their facilities to implement 

vacuum-to-vacuum technology and other retrofitted technology. They also stated that for some 

facilities there were opportunities to switch from a HAP solvent to a non-HAP solvent such as 

nPB, yet this solvent is untested in their industry. However, the industry contended they could 

not implement these opportunities within the three-year compliance period EPA originally 

proposed and remain within the cost parameters EPA presented in the proposal. We discussed 

two options for aerospace facilities in our final rule, which are the 100,000 kg/yr and 

250,000kg/yr levels, but rejected both options based on our conclusion that they were either not 

cost-effective or the incremental costs were disproportionate given the emissions reductions 

involved. 

Although we have not developed any additional information on control technologies 

30
applicable to the aerospace industry since promulgating the final rule, today we are re-proposing 

the outcome of the Halogenated Solvent Cleaning rule, re-proposing the alternative we rejected 

in the Halogenated Solvent Cleaning rule, and also are proposing an additional more stringent 

option for aerospace manufacturing and maintenance facilities. Although since promulgating the 

Halogenated Solvent Cleaning rule we have learned that certain aerospace facilities are testing 

nPB as a compliance approach to reducing HAP, we currently do not have sufficient information 

that would allow us to conclude definitively that nPB switching is viable for this industry and we 

have thus calculated costs for the emission limits using the same set of controls and assigned 

costs used in the Halogenated Solvent Cleaning rule, which were based on costs provided in 

public comments. Specifically, we believe that aerospace manufacturing and maintenance 

facilities may be able to meet emissions limits that range down to 100,000 kg/yr MC equivalent 

limits. We are proposing the ranges of regulatory options that would be applicable on a facilitywide basis for all halogenated Solvent cleaning machines in use at aerospace maintenance and 

manufacturing facilities. We are soliciting comments on this aspect of this proposal. As also 

discussed earlier, our decision on the applicable option will be based on comments we receive on 

this action. 

iii. Continuous Web Cleaning Facilities 

Petitioners also allege that EPA failed to provide any explanation as to why several 

alternative reduction measures, such as either vacuum-to-vacuum machines or solvent switching 

are not available control options for continuous web cleaners. 

As explained earlier, in response to both our August 17, 2006 proposal, and subsequent 

NODA, EPA received significant comments from some facilities that use continuous web 

cleaning machines identifying numerous compliance issues presented by the co-proposed limits. 

Responses included that switching from either PCE or TCE to MC was not an available 

compliance option due to the fact that MC is incompatible with certain metals, and production 

processes, has a lower boiling point, and stringent worker safety OSHA requirements. Some 

facilities also indicated that installation of vacuum-to-vacuum machines was not a compliance 

option due to the differences between the continuous web cleaning process and other batch 

cleaning operations. They stated that the 1994 NESHAP, in recognition of these differences, 

prescribed compliance options for continuous web cleaners that were different from other 

halogenated solvent cleaning machines. They requested that we set different compliance 

31
requirements that would be based on overall control efficiency rather than an emissions limit, in 

light of the fact that they could not comply with either of the co-proposed emission limits. They 

maintained that attaining a degree of control rather than meeting an emission limit was a more 

appropriate measure of their emissions reduction capability. They also indicated that they had 

installed carbon absorption devices, which can operate at about 99 percent control efficiency, 

and that they could possibly achieve an overall effectiveness of between 75 percent and 80 

percent control efficiency (the 1994 NESHAP requires 70 percent control efficiency). They 

reiterated that most emissions could not be captured by these devices because of the nature of 

continuous web cleaning machines. 

Similar to our treatment of comparable assertions by both narrow tubing manufacturing 

and aerospace maintenance and manufacturing facilities, we were also persuaded by these 

assertions, and in the Halogenated Solvent Cleaning rule we acknowledged that continuous web 

machines are designed differently from general halogenated solvent cleaning machines, i.e., 

batch cleaning machines, and that it would be both technologically infeasible and cost 

prohibitive for continuous web cleaning machines to comply with our final promulgated 

emissions limit. Further, in the Halogenated Solvent Cleaning rule we concluded that control 

choices for continuous web cleaners were limited to CADs, that CADs may only achieve a 10 to 

30 percent overall emissions reductions in facility-wide emissions, and thus, that CADs would be 

insufficient for purposes of complying with the final promulgated emissions limits. 

Since promulgation of the Halogenated Solvent Cleaning rule, and receipt of the 

petitions, we have also re-evaluated our assumptions on compliance options, and costs for 

additional emission reductions as it relates to continuous web cleaners. In doing so, we have reexamined responses to our August 17, 2006, proposal and NODA, where some facilities that use 

continuous web cleaners indicated their preference for tighter control efficiency as compared to a 

straight emission limit and more specifically their ability to further control emissions to between 

75 percent and 80 percent overall efficiency. (These responses are in the docket for this 

rulemaking). This proposal reflects this re-evaluation. Specifically, we assumed that facilities 

could switch their HAP solvent to n-propyl bromide or install CAD to comply with the proposed 

options. Thus, we are including as one of the proposed options an overall control efficiency of 

80 percent for continuous web cleaning machines. This requirement would be applicable to 

facilities that use continuous web cleaners and that exceed the various proposed emissions limits 

32
for the general population of halogenated solvent cleaning machines i.e., 40,000 kg/yr and 

60,000 kg/yr MC equivalent limits. Our decision on the emissions limits will be based on 

comments we receive on this proposal. Comments from facilities that use these machines 

suggested they could achieve an 80 percent overall control efficiency within a three-year 

compliance period. The current NESHAP limit requires a 70 percent overall control efficiency. 

To achieve the 80 percent overall efficiency, facilities would be required to reduce emissions by 

33 percent ((1-70%)-(1-80%)/(1-70%) = 33%). Due to the nature of these cleaning machines, a 

relative reduction limit is more suitable than an emission cap, due to the fact that certain 

technologies are not available. 

iv. Military Depot and Maintenance Facilities 

Petitioners also contend that EPA announced a final rule that dramatically departed from 

the proposed rule by imposing a 100,000 kg/yr MC equivalent limit for halogenated solvent 

cleaning machines used by military depot and maintenance facilities. Petitioners contend that the 

public was deprived of the opportunity to comment on this standard and on the technical, legal 

and policy rationale EPA proffered in the Halogenated Solvent Cleaning rule. 

 In response to both our August 17, 2006 proposal and NODA, military depot and 

maintenance facilities also indicated an inability to comply with either co-proposed limits due to 

both technological and compliance deadline constraints. They indicated, however, an ability to 

comply with a 100,000 kg/yr MC equivalent limit. Persuaded by these responses, we concluded 

that the 100,000 kg/yr MC equivalent limit for halogenated solvent cleaning machines used by 

military depot and maintenance facilities would provide an ample margin of safety in the 

Halogenated Solvent Cleaning rule. As explained earlier, however, our August 17, 2006 

proposal would have required all owners and operators of all halogenated solvent cleaning 

machines to comply with either 25,000 kg/yr or 40,000 kg/yr MC equivalent limits. 

Since promulgation of the Halogenated Solvent Cleaning rule, and receipt of the 

petitions, we have also re-evaluated our assumptions on compliance options, and costs for 

additional emission reductions as they relate to military depot and maintenance facilities. 

Additionally, we have taken into consideration the large vacuum-to-vacuum machine technology 

that is now in use by some narrow tubing facilities. All the information leads us to believe that 

military depot and maintenance facilities can achieve emissions limits down to 100,000 kg/yr 

MC equivalent limits. In this action, we are proposing a range of various regulatory options for 

33
halogenated solvent cleaning machines used by military maintenance and depot facilities. We 

expect to select one of the emissions limits that will be applicable to halogenated solvent 

cleaning machines in use at military maintenance and depot facilities. We are soliciting 

comments on this aspect of this proposal and our final decision will be based on comments we 

receive on this proposal. 

General Degreasing Population 

Petitioners stated that the 60,000 kg/yr level we promulgated was not proposed and was not 

made available for public comment. In reconsideration of the final rule, we re-examined the 

proposed 40,000 kg/yr and promulgated 60,000 kg/yr levels of control for the subset of the 

category that excludes the four specific industry sectors identified above (which we call “general 

degreasing units”), retaining the cost assumptions used in the final rule. As in the final rule, our 

evaluation is based on the 2002 NEI data. 

For this subset of the category that excludes the four specific industry sectors mentioned 

above, we have no further new information that would change the facts we presented in the final 

rule for the 40,000 kg/yr level (which we rejected in the final rule) or the 60,000 kg/yr level. 

However, in this action we are proposing a 60,000 kg/yr emission limit as part of the regulatory 

options for the general degreasing units. We are soliciting comments on this aspect of this 

proposal and our final decision will be based on comments we receive on this proposal. 

C. What is the Compliance Schedule?

 One petitioner stated that the 3-year compliance period appeared for the first time in the 

Halogenated Solvent Cleaning rule, making it impracticable to raise objections during the period 

provided for public comment. One petitioner argued that our assumption that narrow tube 

manufacturers could only achieve a ten percent emissions reduction within a 3-year compliance 

period was unsupported by the record and unexplained. Another petitioner argued that CAA 

section 112(f)(4) is the controlling provision that addresses compliance deadlines for existing 

sources with regard to standards promulgated under CAA sections 112(d)(6) and (f)(2). 

 At proposal, we determined that CAA section 112(i) was the controlling provision that 

addressed compliance deadlines for existing sources with regard to standards promulgated under 

CAA sections 112(d)(6) and (f)(2). We also proposed a 2-year compliance deadline from the 

effective date of the rule. We were persuaded, however, by comments on our August 17, 2006 

34
proposal and subsequent NODA, indicating that additional time beyond the proposed 2-year 

compliance deadline would be needed, and in the Halogenated Solvent Cleaning rule, we set a 3-

year compliance period reasoning that this period was more rational and realistic. Thus, we 

promulgated a 3-year compliance deadline from the effective date of the Halogenated Solvent 

Cleaning rule. 

 In this action, we are proposing a 2-year compliance deadline from the date that this 

action becomes final for existing sources not covered by the Halogenated Solvent Cleaning rule. 

Additionally, for all sources covered by the Halogenated Solvent Cleaning Rule, we are also 

proposing a 2-year compliance deadline from the date that this action becomes final, because we 

are allowed to reset the compliance period for sources otherwise covered by an existing rule 

when we make substantial changes or amendments to an existing standard in a subsequent 

rulemaking. 

 In the Halogenated Solvent Cleaning rule, we identified a conflict between section 112(i) 

and section 112(f)(4) of the Act. To avoid a conflict in these provisions addressing compliance 

deadlines, we interpreted the more specific and comprehensive set of provisions in section 112(i) 

as governing both CAA section 112(d) and (f) standards. We maintain this interpretation in this 

rule. We note, however, that the 2-year compliance deadline proposed in this action is consistent 

with an alternative interpretation of the Act, which petitioners endorse, that the provisions of 

CAA section 112(f)(4) controls. CAA section 112(f)(4) would allow us to grant a 2-year 

extension of the compliance deadline for existing sources, in addition to the 90-day compliance 

date otherwise applicable. We believe that the proposed 2-year compliance deadline is necessary 

for the installation of controls at existing sources, and section 112(f)(4) would allow us to grant 

such an extension for the installation of controls. The proposed 2-year compliance deadline 

takes into consideration that some sources may have already completed installation of control 

options in the period between our August 17, 2006 proposal and this action, which is a period of 

about 2 years. Thus, we believe that this proposal falls within the 2-year plus 90-day period that 

would be allowed under CAA section 112(f)(4)(A) – (B) and is therefore within the permissible 

range of CAA section 112(f)(4), if it applies. We are also soliciting comments on this aspect of 

this proposal. 

 

35
V. Control Technologies Available to Affected Industries

 As explained earlier above, in response to the August 17, 2006 proposal, and subsequent 

NODA, we received significant comments on the associated compliance costs of our proposed 

limits from the aerospace and maintenance industry, narrow tubing manufacturing industry, 

facilities that use continuous web cleaning machines and military maintenance depot facilities. 

The responses indicated, among other issues, that compliance with the co-proposed standards 

would be achievable only through installation of expensive technologies, due to high capital and 

operating costs, and that such technologies had yet to be proven effective or reliable for the 

operations of subject facilities. Based on these responses, we re-analyzed our cost data and 

assumptions at proposal focusing especially on the above-referenced four industry sectors. As a 

result of our re-analyses, we concluded in the Halogenated Solvent Cleaning rule that the 

installation of any further emission controls, including switching to either a low-HAP solvent 

cleaner or non-HAP solvent cleaner as assumed in our August 17, 2006 proposal would be cost 

prohibitive for the above-referenced industries. 

 Since promulgation of the Halogenated Solvent Cleaning rule, however, we have become 

aware of certain narrow tubing manufacturing facilities that have voluntarily investigated and 

instituted HAP emissions reductions by installing CAD, vacuum-to-vacuum machines, switching 

from HAP solvents to a non-HAP solvent and reconfiguration and changing production 

processes. 

 Consequently, we have re-evaluated our conclusions on costs, availability of technology 

and the compliance deadline for the facility-wide limits in the Halogenated Solvent Cleaning 

rule. Existing information now leads us to conclude, in a change from the Halogenated Solvent 

Cleaning rule, that certain affected sources in the narrow tubing industry can comply with the 

proposed limits and requirements through installation of CAD, vacuum-to-vacuum machines, 

switching from HAP to non-HAP and improved work practices and manufacturing process 

changes. In addition, we extrapolated information we obtained about the narrow tubing industry 

sector to continuous web cleaners and to military depot and maintenance facilities. Specifically, 

we assumed that continuous web cleaners could substitute TCE for n-propyl bromide (nPB) and 

that military depot and maintenance facilities could install large vacuum-to-vacuum machines. 

Today’s proposed cost estimates do not reflect any new information we have been provided or 
have obtained on available HAP emission reduction options for general (non-specific) 

degreasing units or degreasing units in the aerospace industry. 

 To estimate the costs of reducing emissions for individual facilities, EPA first calculated 

the percent emission reduction necessary for each facility to comply with the levels being 

investigated. Then, control technologies were applied on a per unit basis to achieve the percent 

reduction necessary to achieve the level. The control technologies applied varied depending on 

the cleaning machine type, the solvent used, and the percent control required. Control 

technologies included the replacement of existing units with vacuum-to-vacuum machines, 

solvent switching, and add-on controls. The costs for an individual facility were then determined 

based on the costs associated with the controls needed to meet the level and taking into account 

any increase or decrease in solvent costs. 

 When estimating costs for the narrow tube manufacturers, EPA used cost information 

provided by narrow tube manufacturers that had already implemented control technologies, such 

as CAD, vacuum-to-vacuum machines, and switching to nPB. Costs and risk estimates were 

developed for the narrow tube manufacturing industry at various percent emission reduction 

levels and MC equivalent levels. 

 To more fully analyze the implications of the various emission limits, we re-calculated 

the overall and incremental annualized cost per cancer case avoided for each option. 

 We have determined facilities in each sector of industries engaging in halogenated 

solvent cleaning that would have to add technology measures to control emissions at the various 

emissions limits discussed in this preamble. With regard to the narrow tubing manufacturing 

industry, we have applied costs that were incurred by specific facilities in Pennsylvania for 

purposes of meeting various proposed emissions limits. We have also extrapolated some of 

these costs to continuous web machines (e.g., use of n-propyl bromide as a substitute for TCE) 

and military maintenance and depot facilities (e.g., availability of large vacuum-to-vacuum 

machines). We also assumed that the necessary controls were all high efficiency and costlier 

controls. We did not apply any mid-level controls and their associated costs for instances where 

we had direct compliance costs to use as examples. We have then applied these associated direct 

costs to military maintenance depots and continuous web cleaning machines because we have

assumed that these associated direct costs would be a primary example of costs for any facility 

with similar cleaning machines, similar solvent usage and similar HAP emissions reductions for 

37
compliance with the various proposed emissions limits. These applied assumptions are similar to 

our cost assumptions in the August 17, 2006 proposal. In general, we expect that facilities that 

use halogenated solvents with a higher URE, and as a result have higher emission limits, would 

likely incur higher costs to reduce emissions to the necessary limit. We are soliciting comments 

on these aspects of this proposal. 

A. Information on Individual Controls 

A suite of controls was developed that achieve emission reductions beyond the level of 

the MACT and that reduce the level of cancer risk associated with the emissions as shown in 

Table 2. Two of the controls are retrofit controls that can be added to existing cleaning 

machines, three controls are solvent switching options that reduce cancer risk, and one control 

requires the replacement of existing equipment with a new vacuum to vacuum cleaning machine. 

Table 2. Emission Controls Beyond the MACT Standard and Controls That Reduce 

Cancer Risk And Costs for Each 

Control 

Type Description 

% 

Control 

(a) 

Total 

Capital 

Costs 

Annualized 

Capital 

Costs 

O&M 

Costs 

Total 

Annual 

Emission 

Control 

Costs (b) 

1.5 Freeboard Ratio (1.0FBR), 

Working Mode Cover (WC), 

Freeboard Refrigeration 

Device (FRD) 

50 $25,645 $2,821 $2,015 $4,836 Control 

Equipment 

Retrofits 

1.5 Freeboard Ratio (1.5FBR) 30 $20,380 $2,242 $0 $2,242 

CAD 30 $162,687 17,896 8,948 $26,844 

PCE to MC 11 $15,677 $1,725 $928 $2,653 

PCE to TCE 30 $0 $0 ($2,022)c Solvent ($2,022) 

Switching 

TCE to MC 29 

(increase) $15,677 $1,725 $2,950 $4,675 

Machine 

Replacement 

Vacuum to Vacuum Cleaning 

Machine 95 $399,000 $37,663 $18,832 $56,495 

a - For the solvent switching options the percent emission reduction reflects the amount of new solvent emitted 

relative to the amount of old solvent emitted. For the TCE to MC option it is estimated that emissions of MC would 

be 29% more than the original TCE emissions. The primary benefit for the solvent switching options results from 

the lower MIR cancer risk for the new solvents. If the MIR values are taken into account along with the change in 

emission reduction, the resulting decrease in cancer risk are as follows: 

 PCE to MC = 93% 

 PCE to TCE = 77% 

 TCE to MC = 70% 

b – Does not include cost savings due to reduced solvent purchases. The solvent savings were calculated for each 

specific unit based on the volume of solvent emissions reduced and the cost of the specific solvent in $/gal. 

c – Values in ( ) indicate a cost savings. Costs are in 2007 dollars. 

The costs for the retrofit controls were based on vendor estimates obtained in 2005 and 

38
then revised based on comments received on the 2006 proposed rule and NODA. The capital 

costs were based on equipment for a solvent cleaning machine with a solvent-air interface area of 

2.5 m2

, which is the average size of the solvent cleaning machines in the database for which size 

data are available. A 50% emission reduction is expected to result from the addition of the 

1.0FBR, WC, and FRD control combination. A 30% emission reduction is expected to result 

from the addition of a 1.5FBR. These emission reduction percentages were calculated using 

percent reduction values and procedures that were developed for the 1994 NESHAP. 

 The development of the costs for the solvent switching options included considerations of 

changes in the cost of the solvent, changes in solvent consumption rates, changes in energy 

requirements, costs for equipment modifications, and changes in productivity. Capital costs 

were annualized assuming a 15-year equipment lifetime (retrofit application) or a 20 year 

equipment lifetime (new control application) and a 7% interest rate. The solvent switching 

scenarios, their costs, and impacts are fully discussed in a separate memorandum titled 

“Evaluation of the Feasibility, Costs, and Impacts of Switching from a Halogenated Solvent with 

a High Cancer Unit Risk Value to a Halogenated Solvent with a Lower Cancer Unit Risk Value” 

that is available in the public docket for the rulemaking. 

 Costs for the vacuum-to-vacuum cleaning machines are based on vendor estimates 

obtained in 2005 and then revised based on comments on the proposed rule and NODA. The 

vacuum-to-vacuum cleaning machine capital costs were based on the replacement of a solvent 

cleaning machine with a solvent-air interface area of 2.5 m2

, which is the average size of the 

solvent cleaning machines in the database for which size data are available. 

 The equipment lifetimes were determined based on information from equipment 

manufacturers. It was determined that a 95% reduction in emissions would result from switching 

from an existing solvent cleaning machine to a vacuum-to-vacuum cleaning machine. The 

emission reduction estimate was based on case study results as reported in "Pollution Prevention 

Technology Profile Closed Loop Vapor Degreasing" by the Northeast Waste Management 

Officials' Association (NEWMOA) dated December 28, 2001. In the study, two cleaning 

machines saw a reduction in solvent use of 97% and a third saw a reduction in solvent use of 

83%. The third machine had a smaller reduction in solvent use due to the heavy soils cleaned by 

the machine. Therefore, more solvent was being lost to the solid waste stream. 

Finally, we added a carbon adsorption device (CAD) to our set of available control 

39
measures based on a number of comments who mentioned that this control measure was 

available for use in most of the industries affected. The level of HAP control associated with 

this device is 30%. 

Table 5 shows the individual controls that were applied when evaluating the cost impacts 

on the web, tube, aerospace, and military depot cleaning machine populations. For the tube 

population, three new controls were added as a result of information obtained since the 

publication of the final rule. These controls are the replacement of existing cleaning equipment 

with a new vacuum-to-vacuum cleaning machine, the addition of carbon adsorption, and 

switching from TCE to n-propyl bromide (nPB). All costs are in 2007 dollars. 

Table 5 - Controls Beyond Degreasing MACT Applied to the Web, Tube, Aerospace, and Military Depot 

Cleaning Machine Populations 

Industry 

Segment Description 

% 

Emission 

Reduction 

Total 

Capital 

Costs 

Annualized 

Capital 

Costs 

O&M 

Costs 

Total 

Annual 

Emission 

Control 

Costs (a) 

Vacuum Machine - Small - 

Baskets 95 $150,000 $14,159 $7,080c $21,239 

Vacuum Machine - Small - 

Hanging 95 $242,000 $22,867 $11,434c $34,301 

Vacuum Machine - Large - 

Baskets 95 $584,000 $55,125 $27,563c $82,688 

Vacuum Machine - Large - 

Hanging 95 $788,800 $74,457 $37,229c $111,686 

Enclosure, parts transporter, 

CAD, and distillation 50 $237,500 $26,076 $13,038c $39,114 

Dual-Split Working-Mode 

Cover and Dual-Bank 

Freeboard Chillers 

25 $44,000 $4,831 $2,416c $7,247 

Aerospace 

Enclosure 15 $108,000 $11,858 $5,929c $17,787 

Military 

Depot 

RETRO - 1.5FBR, WC, FRD 

(b) 50 $102,581 $11,284 $8,059 $19,343 

Vacuum-to-Vacuum 

Cleaning Machine 99 $1,700,000 $160,468 $80,234c $240,702 

Carbon Adsorption System 90 $1,000,000 $109,795 $54,897c $164,692 Tube 

Switch from TCE to nPB 100 $0 $0 $0 $0 

Web 

Automated gates and 

lengthening the cleaning 

process area, providing an 

additional enclosure around 

all distillation units, and 

modifying the capacity and 

process structure of the CADs 

40 $850,000 $93,500 $46,750c $123,003 

a – Does not include cost savings due to reduced solvent purchases or cost increases due to the higher cost of 

solvent. The solvent cost savings or increases were calculated for each specific unit based on the volume of solvent 

40
and the cost of the specific solvent in $/gal. 

b – To account for the large size of the cleaning machine the costs are 4 times those used for the main population). 

c – O&M costs were assumed to be equal to half the annualized capital costs. 

The basis of the percent emission reductions and costs for controls that have not changed 

as a result of the reconsideration are explained in detail in the April 13, 2007 memorandum titled 

“National Impacts for Final Rule.” The basis of the percent emission reductions and costs for the 

controls added for the tube population are explained in the following paragraphs. As was done 

previously, all capital costs for new systems were annualized based on a 20-year equipment 

lifetime and a 7% interest rate and retrofit equipment was annualized based on a 15-year 

equipment lifetime and a 7% interest rate. The equipment lifetimes were determined based on 

information from equipment manufacturers. 

Vacuum-to-Vacuum Cleaning Machine for Tube Manufacturers

 The percent emission reduction and costs for vacuum-to-vacuum cleaning machines 

applied to the narrow tube manufacturer population were based on information obtained from 

Salem Tube, Inc. for their Greenville, PA tube manufacturing plant. Salem Tube, Inc. submitted 

an application for an Air Quality Plan Approval to Pymatuning Township on April 13, 2007.8 A 

revision to the application was submitted by Salem Tube, Inc. to the Pennsylvania Department of 

Environmental Protection (PA DEP) on July 24, 2007.9 In the application, Salem Tube, Inc. 

indicates that they will be installing a vacuum cleaning and degreasing system manufactured by 

EMO. The system includes the following components: 

• A vacuum tight degreasing tank with lifting/lowering equipment for vertical inclination 

of the tank; 

• Heated flood tank; 

• Supply unit with solvent evaporator, main distillation, additional vacuum distillation, 

filtration, and activated carbon air filter system; 

• Control system with programmable logic control (PLC) and graphics display with 

process visualization; and an 

• Extraction tank/water separator. 

 

8

 Joseph P. Pezze, Hillcrest Group Environmental Consultants to Pymatuning Township Supervisors. Re: Plan 

Approval Application, New Vacuum Degreaser, Existing Title V Permit #43-000142. April 13, 2007. 

9

 Joseph P. Pezze, Hillcrest Group Environmental Consultants to Ms. Carrie Cooper, P.E., PA DEP NW Regional 

Office. Re: Salem Tube, Inc, New Degreasing System (revisions). July 24,2007. 

41
 Salem Tube, Inc. estimated that this system will reduce their TCE emissions to 262 

lbs/year.10 In the 2002 National Emissions Inventory, emissions of TCE from this facility were 

reported at 104,000 lbs/year. Therefore, this new system will reduce Salem Tube, Inc.’s TCE 

emissions at the Greenville, PA facility by 103,738 lbs/year or over 99% [(103,738 

lbs/year)/(104,000 lbs/year) = 99.7%]. A 99% reduction was assumed for the purposes of the 

impact analysis. 

 Salem Tube reports that the cost for this system will be $1.7 million.11 As with other 

controls, the annual O&M costs were assumed to be equal to half of the annualized capital costs. 

Carbon Adsorption System for Web Cleaning Facilities

Several web cleaning facilities, such as Alcoa (IA), American Safety Razor (VA), and 

American Safety Razor (TN) already have CAD systems installed. Therefore, CAD is a 

demonstrated technology for this population of solvent cleaning machines. Cost for the purchase 

of the CAD systems was not available for these facilities. Therefore, costs provided by Delta 

Airlines were used to estimate the costs for installing CAD for web cleaning facilities. The CAD 

system costs provided by Delta Airlines include the CAD, an enclosure, distillation unit, and 

parts transporter. The cost estimate provided was for a “large” solvent cleaning machine with a 

solvent-air-interface area of 40ft2. The percent reduction that Delta Airlines provided for this 

system was 50%.12 

Carbon Adsorption Systems for Tube Manufacturers

 Following publication of the final rule, EPA became aware that Superior Tube in 

Collegeville, PA, and Accellent, Inc., also in Collegeville, PA, have installed carbon adsorptions 

(CAD) systems to control emissions of TCE from their solvent cleaning machines. 

 Superior Tube installed their CAD system in 2001 to control emissions of TCE from their 

661 Vapor Degreaser.13 Compliance tests conducted on Superior Tube’s system showed that it 

 

10 Reference 3, Cover page. 

11 Reference 2, Section C, Page 16. 

12 Docket item EPA-HQ-OAR-2002-0009-0121. 

13 Minor Operating Permit Modification Application, Summary of Requested Permit Modifications. February 13, 

2008. 

42
had an average TCE removal efficiency of 99.2%.14 No cost estimate was provided for the 

installation of the carbon adsorption unit at Superior Tube. 

 In 2007 and early 2008, Accellent, Inc. installed a carbon adsorption system comprised of 

four beds. These beds serve only two of the four TCE emissions sources – Plant #1 and Plant #2 

Vapor Degreasers. However, these two sources account for approximately 95% of 2006 TCE 

emissions. In their permit documents Accellent has proposed only a 25-35% reduction in TCE 

emissions from the installation of this CAD system. However, PA DEP believes “this is very 

conservative, as emission reductions of 90% or greater usually result from this type of 

installation.”15 In their January 29, 2007 comment letter, Accellent provided an estimated cost 

of $1.8 million dollars for the CAD system on their two large degreasers.16 

 Based on the control efficiency of 99.2% for Superior Tube’s CAD system and the 

expectation that Accellent’s CAD system will achieve a 90% control efficiency, a 90% control 

efficiency was used for the impacts analysis. The installed capital cost of a CAD system 

installed on a tube manufacturing degreaser was estimated to be approximately $1 million/per 

unit. This is a conservatively high estimate based on Accellent’s costs of $1.8 million for a 

system serving 2 units. 

Switching from TCE to nPB for Tube Manufacturers and Web Cleaning Facilities

 Following publication of the final rule in 2007, EPA became aware that Superior Tube, 

Inc. in Collegeville, PA, and Tube Methods, Inc. in Bridgeport, PA, were switching from TCE to 

nPB for their solvent cleaning operations. Contacts with manufacturers of nPB and information 

from other sources also indicated that nPB is an acceptable replacement for TCE in solvent 

cleaning applications.17,18

 Since nPB is not a halogenated HAP, a switch from TCE to nPB will result in a 100% 

reduction in halogenated HAP emissions. According to nPB manufacturers, other than adjusting 

certain equipment settings, no equipment purchases or changes are necessary to switch to nPB.19 

Therefore, capital equipment costs for switching from TCE to nPB were estimated to be zero for 

 

14 “Preliminary Report - Methods for Reducing TCE Emissions at Accellent, Inc. and Superior Tube Co., Inc., 

Collegeville, Pennsylvania,” prepared by Matson & Associates, Inc. January 2008. Page 4. 15 “Progress of Emission Reduction Efforts” from PA DEP. February 13, 2008. 

16 Docket item EPA-HQ-OAR-2002-0009-0126. 

17Reference 7, Page 7. 

18 Telecommunication. Jason Goldsmith, e2M with Jason Ridenour, Parts Cleaning Technologies, February 18, 

2008. Re: Solvent Switching from TCE to nPB. 

19 Ibid. 

43
the cost analysis. However, nPB does cost considerably more than TCE - $2.25/lb for nPB 

versus $1.04/lb for TCE.20 This additional cost was factored into the cost analysis by calculating 

an increased solvent cost based on the amount of TCE previously used and assuming that an 

equal amount of nPB is used at the higher price. Manufacturers of nPB support the assumption 

that 1 lb of TCE will be replaced with 1 lb of nPB.21,22 

 

20 Ibid. 

21 Ibid. 

22 Reference 7, Page 7. 

44
VI. Cost and Emission Reductions for the Proposed Options 

More than 60 percent of the facilities implementing a control technology would recognize 

a cost savings primarily from solvent savings under the options being examined for this proposal. 

Capturing and controlling HAP emissions is a pollution prevention approach where emissions 

reduction translate into less PCE, TCE and MC consumption and reduced operating costs 

primarily because facilities would need to purchase less solvents. Using the 2002 NEI database, 

the maximum individual cancer risk is estimated to be reduced from 100-in-1 million to between 

50 and 20-in-a-million, depending on the control option selected. The options outlined here are 

expected to reduce cancer incidence from a source category wide baseline of 0.55 cases annually 

to 0.36 for option 1, with reductions to 0.32 when continuing to Option 3, resulting in a range of 

reduction in cancer incidence from between 0.19 to 0.23 cases annually, depending upon the 

option selected. 

Under Option 1, the total HAP emissions would be reduced by 1,681 tons per year (tpy). 

We anticipate that about 82 facilities and 98 halogenated solvent cleaning machines would be 

affected by this proposed option. Facilities would reduce their emissions to meet this proposed 

regulatory option by selecting control options that might include one or more of the following: 

(1) Solvent switching from a HAP solvent with a higher URE to a HAP solvent with a lower 

URE, such as switching from PCE or TCE to MC; (2) Solvent switching from a HAP solvent to 

a non-HAP solvent; (3) Retrofitting additional freeboard; (4) installing CAD or (5) installing 

vacuum-to-vacuum machines. 

For the general population degreasing sources required to comply with the 60,000 kg/yr 

MC equivalent emission limit as part of Option 1, the national capital costs to reach compliance 

are estimated to be $15,000,000 with annualized cost savings of $1.38 million (2007 dollars). 

The capital costs for individual facilities would range from $15,000 to $800,000 with an average 

cost of about $190,000. EPA also estimates that to comply with the 100,000 kg/yr MC 

equivalent emission limit which is part of Option 1, military depot maintenance facilities are 

expected to incur $535,000 in capital costs with annualized savings of about $56,000. Using the 

2002 NEI database, the maximum individual cancer risk is estimated to be reduced from six-ina-million to three-in-a-million. The emission limit for military depot maintenance facilities is 

expected to reduce cancer incidence by 0.002 cases annually. EPA estimates that to comply with 

the 60,000 kg/yr MC equivalent emission limit, military depot maintenance facilities are 
expected to incur $3 million in capital costs with annualized costs of $256,000 per ton. The 

emission limit for military depot maintenance facilities is expected to reduce cancer incidence by 

0.002 cases annually. 

 When Option 1 is applied to the facilities in the 2002 NEI database we estimate that the 

MIR decreases to about 50-in-a-million with an estimated reduction in cancer incidence of about 

0.22 cases annually, with capital costs at $15.6 million and an annualized cost savings of $1.38 

million, or a cost savings of about $832 per ton. 

For Option 2, we anticipate that about 105 facilities and 150 halogenated solvent cleaning 

machines would be subject to this proposed option. Facilities would reduce their emissions by 

selecting control options that might include one or more of the following: (1) from a HAP 

solvent with a higher URE to a HAP solvent with a lower URE, such as switching from PCE or 

TCE to MC; (2) solvent switching from a HAP solvent to a non-HAP solvent; (3) retrofitting 

additional freeboard; (4) installing CAD or; (5) installing vacuum-to-vacuum machines. 

The difference between Option 2 and Option 1 is that halogenated solvent cleaning 

machines used by narrow tube facilities would be subject to a 60,000 kg/yr MC equivalent limit 

just as the general degreaser population is. EPA also estimates that to comply with the 60,000 

kg/yr MC equivalent emission limit, narrow tube manufacturing facilities are expected to incur 

$22 million in capital costs with annualized costs of about $3 million. Using the 2002 NEI 

database, this emission limit for narrow tube manufacturing facilities is expected to reduce 

cancer incidence by 0.005 cases annually. 

 When Option 2 is applied to the facilities in the 2002 NEI database, the MIR decreases to 

about 30 in-a-million with an estimated reduction in cancer incidence of about 0.20 cases 

annually, and annualized costs of $1.6 million, or annual costs of about $616 per ton. 

For Option 3, we anticipate that about 130 facilities and 260 halogenated solvent cleaning 

machines would be subject to this proposed option. Facilities would reduce their emissions by 

selecting control options that might include one or more of the following: (1) solvent switching 

from a HAP solvent with a higher URE to a HAP solvent with a lower URE, such as switching 

from PCE or TCE to MC; (2) solvent switching from a HAP solvent to a non-HAP solvent; (3) 

retrofitting additional freeboard; (4) installing; or (5) installing vacuum-to-vacuum machines. 

The differences between Option 3 and Option 2 is that a 100,000 kg/yr MC equivalent 

limit would be applicable to halogenated solvent cleaning machines used by aerospace 

46
manufacturing facilities as well as military maintenance and depot facilities, and facilities with 

continuous web machines exceeding 60,000 kg/yr MC equivalent HAP emissions would have to 

achieve 80 percent control efficiency for those units. EPA estimates that to comply with the 

100,000 kg/yr MC equivalent emission limit, aerospace manufacturing and maintenance facilities 

are expected to incur $9 million in capital costs with annualized costs of about $626,000. Using 

the 2002 NEI database, this emission limit for aerospace manufacturing and maintenance 

facilities is expected to reduce cancer incidence by 0.03 cases annually. EPA further estimates 

that to comply with the 80 percent overall control efficiency, facilities using continuous web 

cleaning machines with total emissions over the 60,000 kg/yr thresholds are expected to incur $1 

million in capital costs with annualized costs of about $807,000. Using the 2002 NEI database, 

this emission limit for facilities using continuous web cleaning machines is expected to reduce 

cancer incidence by 0.003 cases annually. 

 When Option 3 is applied to facilities in the 2002 NEI database the MIR decreases to 

about 30-in-a-million with an estimated reduction in cancer incidence of about 0.23 cases 

annually, and these facilities are expected to incur $47.7 million in capital costs and annualized 

costs of $3.0 million, or annualized costs of about $944 per ton. 

Table 4 provides the costs for the proposed options broken down by capital and annual 

components, including estimates of the cost savings from solvent recovery, and also emission 

reductions and the reduction in annual cancer incidence. Solvent savings represent the cost 

savings that result from reduced solvent purchases. All of the cost estimates listed above and 

shown in Table 4 are scaled up by a factor of 1.74 to adjust the results for the number of 

potentially affected sources within the 2002 NEI. 

47
Table 4. Summary Table of Costs and Emission Reductions for the Proposed Options 

DESCRIPTION 

Option 1 Option 2 Option 3 

Total Capital Costs 

(millions) $15.66 $37.58 $47.68 

Annualized Capital Costs 

(millions) $1.51 $3.73 $4.72 

Total Annual Operation and 

Maintenance Costs 

(millions) 

$0.76 $1.88 $2.37 

Emission Reduction 

(tons/yr) 1,680 2,601 3,216 

Cancer Cases Avoided/Year 0.19 0.20 0.23 

Solvent Savings (millions) $3.65 $4.0 $4.05 

Net Annualized Cost of 

Control ($/yr) 

(Annualized Capital Costs + 

Solvent Credit) 

($1.38) $1.60 $3.03 

Cost Effectiveness ($/ton) 

(Net Annualized Cost of 

Control/Emission 

Reduction) 

($821) $616 $944 

* Represents the facility-wide emissions limit in the final rule. All costs are in 2007 dollars. Cost estimates reflect 

application of the scale-up factor (1.74) to put these estimates on a comparative basis with the number of potentially 

affected solvent cleaners in the 2002 NEI. 

48
We are also presenting in Table 5 the associated costs and emissions reductions for 

various options that we have considered in light of the fact that we are soliciting comments on 

alternative limits that fall within the range of the options we have presented earlier in this 

preamble. 

Table 5—Impact Estimates for Options Applied to Specific Sectors 

Emission Limit 

Total 

Capital 

Costs 

(Millions) 

Total 

Annualized 

Costs 

(Millions) 

Emission 

Reduction 

(tons/yr) 

Cost 

Effectiveness of 

Control 

$/ton 

Cost per Case 

Avoided 

(Millions) 

60,000 kg/yr MC Eq. for 

General Degreaser Population 

(does not include named 

sectors) 

$15.1 ($1.32) 1,591 ($832) ($7.0) 

100,000 kg MC Eq. for 

Aerospace Manufacturing and 

Maintenance $9.02 $0.63 324 $1,933 $31 

60,000 kg/yr MC Eq. for 

Narrow Tubing $21.92 $2.98 921 $3,238 $596 

80 percent Overall Control for 

Continuous Web Cleaning 

machines at facilities emitting 

>60,000 kg/yr 

$1.09 $0.81 291 $2,774 $177 

100,000 kg/yr MC Eq. for 

Military depot and 

maintenance 

$0.54 ($0.06) 89 ($625) ($56) 
VI. Economic Impact and Small Business Analysis 

These residual risk standards to control halogenated solvents will potentially affect the 

economic welfare of owners of the facilities using these hazardous air pollutants. The ownership 

of these facilities ultimately falls on private individuals who may be owner/operators that 

directly conduct the business of the firm (i.e., “mom and pop shops” or partnerships) or, more 

commonly, investors or stockholders that employ others to conduct the business of the firm on 

their behalf (i.e., privately-held or publicly-traded corporations). The individuals or agents that 

manage these facilities have the capacity to conduct business transactions and make business 

decisions that affect the facility. The legal and financial responsibility for compliance with a 

regulatory action ultimately rests with these agents; however the owners must bear the financial 

consequences of the decisions. Environmental regulations like this rule potentially affect all 

businesses, large and small, but small businesses may have special problems in complying with 

such regulations. 

The Regulatory Flexibility Act (RFA) generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice and comment rulemaking 

requirements under the Administrative Procedure Act or any other statute unless the agency 

certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. Small entities include small businesses, small organizations, and small 

governmental jurisdictions. This analysis identified the businesses that will be affected by this 

rule and provides an analysis to assist in determining whether this rule is likely to impose a 

significant economic impact on a substantial number of small businesses. The screening analysis 

employed here is a “sales test” that computes the annualized compliance costs as a share of sales 

for each company. The “sales test” is the impact methodology EPA employs in analyzing 

small entity impacts as opposed to a “profits test”, in which annualized compliance costs are 

calculated as a share of profits). This is because revenues or sales data is commonly available 

data for entities normally impacted by EPA regulations and profits data normally made available 

is often not the true profits earned by firms due to accounting and tax considerations. Firms and 

entities often have ways available in the tax code to reduce their reported profits; thus, using 

reported profits may lead to an overestimate of the economic impact of a regulation to an 

affected firm or entity and their consumers. The use of a “sales test” for estimating small 

business impacts for a rulemaking such as this one is consistent with guidance offered by EPA 
on compliance with SBREFA,23 and is consistent with guidance published by the US SBA’s 

Office of Advocacy that suggests that cost as a percentage of total revenues is a metric for 

evaluating cost increases on small entities in relation to increases on large entities.24 Details on 

the data used in the economic impact analysis are found in the Appendix to this report. 

A. Identifying and Characterizing Small Entities

For purposes of assessing the impacts of today's rule on small entities, small entity is 

defined as: (1) a small as defined by the Small Business Administration’s (SBA) regulations at 

13 CFR 121.201;” (2) a small governmental jurisdiction that is a government of a city, county, 

town, school district or special district with a population of less than 50,000; and (3) a small 

organization that is any not-for-profit enterprise which is independently owned and operated and 

is not dominant in its field. 

 The companies owning the facilities using halogenated solvents can be grouped into 

small and large categories using Small Business Administration (SBA) general size standard 

definitions. Size standards are based on industry classification codes (i.e., NAICS) that each 

company uses to identify the industry or industries in which they operate in. The SBA defines a 

small business in terms of the maximum employment, annual sales, or annual energy-generating 

capacity (for EGUs) of the owning entity. These thresholds vary by industry and are evaluated 

based on the primary industry classification of the affected companies. In cases where 

companies are classified by multiple NAICS codes, the most conservative SBA definition (i.e., 

the NAICS code with the highest employee or revenue size standard) was used. 

As mentioned earlier in this report, facilities across several industries use halogenated 

solvents to degrease their products, therefore a number of size standards are utilized in this 

analysis. For the industries represented in this analysis, the employment size standard varies 

from 500 to 1,500 employees. The annual sales standard is as low as 4 million dollars and as 

high as 150 million dollars. The specific SBA size standard is identified for each affected 

industry within the small entity database created for this economic analysis. 

B. Screening-Level Analysis

 For the purposes of assessing the potential impact of this rule on affected businesses, the 

 

23 The SBREFA compliance guidance to EPA rulewriters regarding the types of small business analysis that should 

be considered can be found at http://www.epa.gov/sbrefa/documents/rfafinalguidance06.pdf , pp. 24-25. 24 U.S. SBA, Office of Advocacy. A Guide for Government Agencies, How to Comply with the Regulatory 

Flexibility Act, Implementing the President’s Small Business Agenda and Executive Order 13272, May 2003. 

51
Agency considers the costs of specific compliance options considered. The share of the facility’s 

annual compliance cost relative to baseline sales for each facility-owning company is calculated 

and this measure is used to determine the economic impact of these options on small businesses. 

When a company owns more than one facility that potentially faces the costs of complying with 

this standard, the costs for each facility it owns are summed to develop the numerator of the sales 

test ratio. For this screening-level analysis, annual compliance costs are defined as the 

engineering control costs incurred by these companies; thus, they do not reflect the changes in 

production expected to occur in response to the imposition of these costs and the resulting 

market adjustments. 

 

C. Excluded Companies

 Annual sales and employment data could not be located for 35 of the companies (again, 

reflecting the scale up factor of 1.74) that use halogenated solvents and, as mentioned above, 

have been excluded from the analysis. Without these data, a size determination cannot be made 

for these companies nor could CSRs be calculated. Since it is more difficult to locate company 

data for small companies, it is possible that these companies are small. However, without sales 

and employment data, this cannot be determined with certainty. It is possible that these 

companies might be considered large, depending on the SBA size standard definition for their 

NAICS codes. It is important to note that only one of the excluded companies is expected to 

experience positive costs as a result of compliance with the final rule. 

52
D. Small Business/Entity Impact Results

After considering the economic impacts of this final rule on small entities, we have 

concluded that this action will not have a significant economic impact on a substantial number of 

small entities. This certification is based on the economic impact of today’s action to all affected 

small entities in the entire halogenated solvent cleaning source category regardless of the option 

in this proposed rulemaking. All economic impact estimates are based on incorporation of the 

scale-up factor of 1.74 applied to affected source populations and costs. Option 1 is expected to 

affect 120 ultimate parent entities, and forty of these parent entities (or one-third of the total 

number of the ultimate parent entities affected) are small as defined by SBA small business size 

standards. Of these 40 small entities, none have an annualized cost of greater than 1 percent of 

their sales. Option 2 is expected to affect 148 ultimate parent entities, and fifty-two (or thirtyfive percent) of these are small as defined by SBA small business size standards. Of these 52 

small entities, three have an annualized cost of greater than 1 percent of sales. Option 3 is 

expected to affect 181 ultimate parent entities, and fifty-six (or thirty-one percent) of these are 

small. Of these 56 small entities, three have an annualized cost of greater than 1 percent of sales. 

These economic impacts are summarized in Table 6. 

Table 6. Summary of Economic Impacts 

Proposed Option Number of 

Businesses 

Affected 

Number of 

Small 

Businesses 

Affected 

Impacts at 1% 

or Greater 

CSR – Small 

Businesses* 

Impacts at 3% 

or Greater 

CSR – Small 

Businesses* 

Option 1 120 40 0 0 

Option 2 148 52 3 0 

Option 3 181 56 3 0 

*Includes those companies for which sales and employment data could be located 

Calculations are based on scale-up factor applied to affected source populations and costs (1.734)
References 

Hoover’s Online, www.hooversonline.com . Accessed in March, 2007. 

 

Memo from Sorrels, Larry, U.S. EPA to Vogel, Ray, U.S. EPA. “Economic Data for Area 

Source Categories – Title V Permit Program Rulemaking,” June 17, 2004. 

Michael W. Horrigan, “Employment projections to 2012: concepts and context,” Monthly Labor 

Review 127(2): 12, Bureau of Labor Statistics, February 2004. 

Memo from Sarsony,Chris, engineering-environmental Management, Inc. to Dail, Lynn, U.S. 

EPA. “National Cost Impacts.” April 2007. 

Memo from Sarsony,Chris, engineering-environmental Management, Inc. to Dail, Lynn, U.S. 

EPA. “National Impacts for Proposed Reconsideration.” October 2, 2008. 

U.S. Environmental Protection Agency, Office of Policy, Economics, and Innovation. “Final 

Guidance for EPA Rulewriters: Regulatory Flexibility Act as Amended by the Small Business 

Regulatory Enforcement Fairness Act,” November 2006. 

Thomas Manufacturing, www.ThomasNet.com . Accessed in March, 2007. 
Appendix – Construction of Database for Economic Impact and Small Business Analysis 

 

This appendix provides a methodology and details of how the database used in the 

economic impact and small business analysis was constructed so that a reader can examine the 

database itself to understand why the particular data exists in that database and why it is used. 

As mentioned in the body of the report, the economic impact analysis (EIA) prepared is a 

comparison of the annualized compliance costs for each parent entity affected under a particular 

regulatory option to the revenues for each parent entity. This comparison is loosely called a 

“cost-to-sales ratio.” This EIA includes an analysis of affected small entities also; we identify 

the small parent entities affected in our analysis as described below. The analysis methodology 

and database construction is identical for all options considered. 

The database used for preparing the EIA is constructed by following these steps: 

1) Identification of affected facilities. The engineering contractor to the Sector 

Policies and Programs Division (SPPD), engineering environmental Inc., 

identified a list of affected halogenated solvent cleaning facilities under each 

regulatory option analyzed. This list of facilities reflects facilities with one or 

more solvent cleaners identified as affected under a particular regulatory 

option. The contractor made this list of facilities available to the economist 

preparing this report. This list of facilities was made available in a Microsoft 

Excel spreadsheet, and this spreadsheet prepared by the engineering contractor 

is available in the rule docket. 

 

2) Identification of affected parent entity. Each facility identified in the list of 

affected facilities had its name listed. This name, however, does not 

necessarily identify the parent entity of the affected facility. The economist 

on this project collected information from various data sources identified 

earlier in this report to determine what parent entity owned each identified 

affected facility. In most cases, the parent entity owning an affected facilities 

is a privately owned firm, but there are a few facilities affected that are 

government-owned. Once the parent entity for an affected facility is 

identified, it was included beside the facility name for the affected facility. 

We were unable to identify the parent entity for each affected facility; 

however, as mentioned earlier in this report, we were able to identify the 

parent entity for each affected entity nearly 75 percent of the time. 

3) Revenue and employment data for each affected parent entity. We collected 

revenue data for the most recent fiscal year for each affected parent entity, and 

we collected this data from the same data sources identified earlier in this 
56

report. We also collected employment data for each affected parent entity from 

most of these same data sources. We collect the employment data in order to 

determine if the affected entity is “small” as defined by SBA size standards. 

The SBA size standards relevant to this analysis are defined earlier in this 

report. These size standards are defined by 6-digit North American Industry 

Classification System (NAICS) code. Part of the data that Engineering 

Environmental Management (e2

M), Inc. supplied was the NAICS for each 

affected facility. We use this NAICS to assign an SBA small business size 

standard to each affected parent entity. 

4) Annualized compliance costs for each affected facility and parent entity. 

Engineering Environmental, Inc. prepared capital and annualized compliance 

cost estimates for each affected solvent cleaner under each regulatory option. 

These compliance cost estimates include the annualized cost of capital, 

operating and maintenance cost, and monitoring, recordkeeping, and reporting 

costs. We summed up the solvent cleaner costs by facility to obtain the 

facility-level cost estimate and then summed up the facility-level cost 

estimates to obtain parent entity-level estimates. Costs are in 2007 dollars to 

match the year dollars for our revenue data (2007 data). 

After completion of these 4 steps, we incorporated this data into a spreadsheet. There is 

therefore a spreadsheet with a tab for annualized cost, revenue, and employment for each 

identified affected parent entity identified as affected by the proposed action according to our 

analysis. Identification of a parent entity as small or large is included as appropriate in each tab. 

This spreadsheet is available in the public rule docket with the following file name: 

*Small businessEconanalysishalogsolvreconsiderationproposalrule.xls – Spreadsheet with all 

data used in the economic impact analysis for the proposed action. 

 Finally, we also submit a spreadsheet with estimated impacts shown by sector for 

affected small businesses in the narrow tube and aerospace industries, and small business with 

continuous web cleaners expected to be affected by this proposed notice of reconsideration. 

That spreadsheet is HSCreconsiderationsmallbusinessanalysissummarysectorsfinal.xls. 

56
57

57
United States 

Environmental Protection 

Agency 

Office of Air Quality Planning and Standards 

Health and Environmental Impacts Division 

Research Triangle Park, NC 

Publication No. EPA 452/R-08-005 

October 2008