# Economic Impact Analysis for the Proposed Notice of Reconsideration of the Final Halogenated Solvent Cleaners Residual Risk Standard and Request for Public CommentEPA-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

23Executive Summary

The EPA has proposed to reduce the amount of risk associated with exposure to hazardous air pollutants (HAPs) such as methylen e chlorine (MC), perchloroethylene (PCE), and trichloroethylene (TCE) from existing and new ha logenated 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 opti ons cover several industries not affected under the final rule publ ished last year. These industr ies are aerospace manufacturing, narrow tube manufacturing, and industries with con tinuous web cleaners.

This report provides the economic impacts as well as other impacts – costs, emission reductions, and risk reductions - a ssociated with the three options offered in this proposal. The impacts in this report are estimated based on co mparisons of annualized compliance costs to the
revenues for affected firms. We find that the im pacts 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 ba sed on incorporation of th e 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 defi ned by Small Business Administration (SBA) small
business size standards. Of these 40 small entitie s, none have an annualized cost of greater than 1 percent of their sales. Option 2 is expected to affect 148 ultimat e parent entities, and fifty-two (or thirty-five percent) of these are small as de fined 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 a nnualized cost of greater th an 1 percent of sales. There is no significant economic impact on a substa ntial number of small entities (or SISNOSE)

4associated with this final standard. This certif ication is based on the ec onomic impact of today’s
action to all affected small en tities in the entire halogenate d solvent cleaning source category regardless of the option in this proposed rulemaking.

5Introduction
On December 2, 1994, we promulgated nati onal emission standards for halogenated solvent cleaning machines 1 (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 co mpliance flexibility. The 1994 NESHAP is available in the docket for this rulemaking.
Carbon tetrachloride and chloroform are no l onger 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 Ja nuary 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 cont inue 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, faciliti es 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. Haloge nated solvent cleaning is typically performed prior to processes such as painting, plating, in spection, repair, assembl y, 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 (elect rical equipment, appliance, and component manufacturing), NAICS 336 (transportation equipmen t manufacturing), and NAICS 339 (miscellaneous manufacturing). Additional industries that use ha logenated 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; automotiv e and electric tool repair shops (NAICS 811); and automobile dealers (NAICS 411) also use halogenated solvent cleaning machines.

6machining. Types of halogenated solvent clean ing machines include, but are not limited to, batch vapor, in-line vapor, in- line cold, and batch cold solven t 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 Halogena ted Solvent Cleaning Rule (72 FR 25138),
which established revised standards that furt her limit emissions of MC, TCE and PCE from facilities engaged in ha logenated solvent cleanin g, pursuant to CAA section 112(f). Specifically, we promulgated a facility-wide emission lim it of 60,000 kilograms pe r year (kg/yr) MC equivalent 2 that applied to all halogenated solvent cleaning machin es with the exception of halogenated solvent cleaning machines used by the following industrie s: facilities that manufacture narrow tubing, facilities that manuf acture specialized pr oducts 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 fa cilities 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 solv ent cleaning machines us ed by facilities that manufacture narrow tubing, facilities that manuf acture specialized pr oducts that require continuous web cleaning, and aerospace manufac turing and maintenance facilities we found, after considering risks, associated compliance cost s and the availability of control measures, that the 1994 NESHAP reduces risk to acceptable levels , provides an ample ma rgin of safety to protect public health, and prevents adverse environm ental effects. We concluded that the actions taken in the final rule satisfied our obliga tions 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 petitions 3 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-equivale nt 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 Reso urces Defense Council v. EPA, Citi zens for Pennsylvania’s Future and Sierra Club, several state and federal legislators and the Governor for the Commonwealth of Pennsylvania.

7Generally, petitioners claimed that the Haloge nated Solvent Cleaning Rule contained legal interpretations and information that are of centr al 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 rele vance 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 th e reconsideration process would be addressed in a forthcoming Federal Register notice. Additionally, we deni ed 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 Halogenate d 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 pe titioners that the particular issues for reconsideration and the specifics of the reconsid eration process would be addressed in a forth coming Federal Register notice. The purpose of this noti ce is to initiate the process for responding to certain issues raised in these petitions. In this action, we are proposing that the ri sk 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 e ffects. These proposed requirements would apply to owners and operators of halogenate d 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. EP A, No. 07-1255 (D.C. Cir.); Natural Resources Defense Council v. EPA, No. 07-1256 (D.C. Cir.). These cases have since been consolidated.

8to the 1994 NESHAP. Additionally, we are pro posing 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 th e date that this ac tion becomes final for existing sources not covered by the Halogenated Solvent Clea ning rule. Additionally, for sources covered by the Halogenated Solvent Cleaning rule, we ar e also proposing a 2- year compliance deadline from the date that this action becomes final because we are allowed to reset the compliance period wh en 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 issu es, 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 a ny comments addressing other aspects of the Halogenated Solvent Cleaning Rule beyond thos e discussed in this notice. Further, our final decision on cer tain issues that we are not gr anting reconsideration will be issued no later than the date by which we take fi nal action on the issues di scussed in this action.

II. Profile of Affected I ndustries Under This Proposal
Halogenated solvent cleaners are found prim arily in manufacturi ng 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 Miscella neous Fabricated Metal Produc t Manufacturing. This U.S. industry comprises establishments primarily enga ged in manufacturing fabricated metal products (except forgings and stampings, cutlery and hand tools, architectural a nd structural metals, boilers, tanks, shipping contai ners, 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, fabricat ed pipes and pipe fittings, i ndustrial patterns, and enameled iron and metal sanitary ware).

NAICS 331210: Iron and Steel Pi pe and Tube Manufacturing Indus try. The iron and steel pipe and tube manufacturing industry is defined as all establishm ents primarily engaged in

9manufacturing 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 enga ged in manufacturing metal ho usehold-type furniture and freestanding cabinets. The furniture may be ma de 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 pr imarily engaged in manufacturing industrial and commercial electric apparatus and other equi pment (except lighting equipment, household appliances, transformers, motors, generators, sw itchgear, relays, industr ial controls, batteries, communication and energy wire and cable, wiring devices, and carbon a nd 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 Equi pment Manufacturing. This U.S. industry comprises establishments primarily engaged in manufacturing transportation equipment (except motor vehicles, motor vehicle parts, boats, ship s, railroad rolling st ock, aerospace products, motorcycles, bicycles, armo red vehicles and tanks).

NAICS 332116: Metal Stamping. This U.S. indus try comprises establishments primarily engaged in manufacturing unfinished metal st ampings and spinning unf inished metal products (except crowns, cans, closures, automotive, and coins). Establishments making metal stampings and metal spun products and further manufact uring (e.g., machining, assembling) a specific product are classified in the i ndustry of the finished product. Metal stamping and metal spun products establishments may perform surface finishing operations, su ch as cleaning and deburring, on the products they manufacture.
NAICS 336: Transportation Equipment Manufac turing. Industries in the Transportation Equipment Manufacturing subsector produce eq uipment 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.

10NAICS 339: Miscellaneous Manufacturing. Indust ries 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 manufact uring 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 be nding, forming, and assembly used in making medical products.
NAICS 5121: Motion Picture and Video Industries. This industry group comprises establishments primarily engaged in the produc tion and/or distribution of motion pictures, videos, television programs, or co mmercials; in the exhibition of motion pictures; or in the provision of postproduction a nd 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%

11335999 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 industri es are largely dominated by small businesses and establishments (or facilities). We also note that certain non-manufacu ring industries such as railroad (NAICS 482), bus (NAI CS 485), aircraft (NAICS 4 81), 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

12Economic 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 expect ed 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 industr ies over the next several years.

III. Background for This Proposed Action

A. Statutory authority for regulatin g hazardous air pollutants (HAP) Section 112 of the Clean Air Act (CAA) establ ishes a two-stage regu latory process to
address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, after EPA has identified categories of sources em itting 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 fo r certain “area sources” emitting less than those amounts. These technology-based standards must reflect the maximum reductions of HAP achievable (after considering cost, energy requ irements, and non-air health and environmental impacts) and are commonly referred to as maximum achievable cont rol technology (MACT)
standards. For area sources, CAA section 112(d)(5) pr ovides that the standards may reflect generally available control technology or mana gement practices in lieu of MACT, and are commonly referred to as generally available control technology (GAC T) standards. EPA is then required to review these technol ogy-based standards and to revise them “as necessary, taking into account de velopments in practices, proce sses and control technologies,” no less frequently than every eight years. CAA section 112(f)(2) requires us to dete rmine for each section 112(d) source category whether the MACT standards protec t 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.

13standards for HAP “classified as a known, probabl e, or possible human carcinogen do not reduce
lifetime excess cancer risks to th e individual most exposed to em issions 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 pr event an adverse environmental effect (defined in CAA section 112(a)(7) as “any significant and widespread adverse effect * * * to wildlife, aquatic life, or natu ral 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 thei r 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 solv ent cleaning is typically performe d 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 ca pacities of 7.6 liters (2 gallons) or less are not consider ed solvent cleaning machines. Halogenated solvent cleaning doe s not constitute a distinct in dustrial category, but is an integral part of many major indus tries. Based on data in our la test National Emissions Inventory (NEI), the five 3-digit NAICS C ode that use the largest quantiti es 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 (tra nsportation equipment manu facturing), 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.). N on-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.

14We estimated that there were approx imately 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 informati on shows that the curre nt number of cleaning machines is much lower than these pre-MACT es timates. 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 informa tion 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 MA CT control technologies and work practice
standards. More recent eviden ce on solvent usage sugge sts that the number of sources in the source category may have declined further in th e post-MACT implementation years. An analysis of market data for halogenated so lvents showed that the demand for degreasing solvents declined substantially in the five year s following the implementation of the MACT standard. From 1998 to 2003, the demand for tetrachloroethylene, tr ichloroethylene, methylene chloride, and 1,1,1- trichloroethane for use in degreasing decreased by 39 percent, 35 percen t, 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 mo st common type of batch cleaner that uses halogenated solvent is the open-t op vapor cleaner (OTVC). Batch cleaning machines, which are the mo st common type, are defined as a solvent cleaning machine in which individual parts or se ts of parts move through the entire cleaning cycle before new parts are introduced. Batc h 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 temperatur e. Most batch cold cleaners
are small maintenance cleaners (e.g., carburetor cleaners) or pa rts 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 ab ove its boiling point.

15Solvent 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 cond enses on the cooler workload surface. The workload or a parts basket is lowered into th e 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 defi ned 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/a ir 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 vacu um 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) cleani ng 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., work load size, shape, and producti on 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 poi nts for in-line cleaners are different from

16those for batch cleaners because of differences in machine configurations. In-line cleaning
machines are semi-enclosed above the solvent/air interface to control so lvent 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 cleane r. 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 mach ine but increase solvent consumption.
Continuous web cleaners are a subset of in-l ine 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 con tinuous cleaners are similar to emission points
from other inline cleaners. Continuous cleaner s 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 worklo ad. Some continuous machines have exhaust systems similar to those used with some other in-line cleaners.
C. Health effects from exposu re to halogenated solvents
Methylene chloride, perchloroethylene, tr ichloroethylene, and 1,1,1,-trichlorothane are the primary halogenated solvents used for solvent cleaning. Alt hough 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 ar e 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 eff ects including decreased visual, auditory, and motor functions, but these e ffects 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. Huma n data are inconclusive regarding methylene
chloride and cancer. Animal studies have show n increases in liver a nd 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

17potential 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 ef fects of PCE are neurol ogical, liver, and kidney damage following acute (short-term) and chr onic (long-term) inhalati on exposure. Animal studies have reported an incr eased 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 carcinoge nicity. All activities related to this reassessment are expected to be complete by late 2008. The acute inhalation exposure effects fr om 1,1,1-trichloroethane include hypotension, mild hepatic effects, and central nervous system depression. Card iac 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 human s. After chronic inhalation exposure to 1,1,1-trichloroethane, some liver damage was observed in mice and vent ricular 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 Un ited States is released into the atmosphere from industrial degreasing operations. Ac ute 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 b een 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, li ver, cervix, and lymphatic system. Animal studies have reported increases in lung, liver, ki dney, and testicular tumo rs and lymphoma. EPA has classified trichloroethyl ene as a Group B2/C, an interm ediate between a probable and possible human carcinogen. EPA should complete its reassessment of the can cer 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

18the benchmarks for the four HAPs used in the risk assessment. Specific information underlying the values used may be found at the followi ng 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 an d 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 reas sessments, (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 ri sk associated with the 1994 NESHAP for the halogenated solvent cleaning source category is acceptable. We are also proposing various regulatory options that would provi de an ample margin of safety to protect public health and prevent adverse environmental effects. These pr oposed requirements would apply to owners and operators of halogenated solv ent cleaning machines that ar e subject to the 1994 NESHAP. Additionally, we are proposing that such sta ndards would satisfy our obligations under both CAA sections 112(d)(6) and 112(f)(2). In this action we are proposi ng a 2-year compliance
deadline from the date that this action become s final for existing sources not covered by the Halogenated Solvent Cleaning rule. Additiona lly, for sources covered by the Halogenated Solvent Cleaning rule, we are also proposing a 2-year compliance dead line from the date that this
action becomes final because we are allowed to reset the compliance period when we make substantial changes and amendmen ts to the existing standards in a subsequent rulemaking. We are seeking public comment on the particular issu es identified below for which we are granting reconsideration, on our response to those issues , and on proposed regulat ory 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 a ny comments addressing other aspects of the Halogenated Solvent Cleaning Rule beyond thos e discussed in this notice.

19Further, our final decision on cer tain issues that we are not gr anting reconsideration will be issued no later than the date by which we take fi nal action on the issues di scussed 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 fr om facilities engaged in halogenated solvent cleaning, pursuant to CAA secti on 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 develope d six options to limit emissions to evaluate reductions in residual risk if pos t-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 en tire source category in addition to the 1994 NESHAP requirements. We also proposed a complian ce deadline of 2 years
after the effective date of the final rule. Industry, states, solvent manu facturers, industry trade asso ciations 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, f acilities 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, technica l 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 informa tion 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 invent ory 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 solv ent cleaning facilities in the finalized 2002 NEI, and conducted separate assessments of four sp ecific industry sectors —aerospace manufacture

20our 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 so lvent cleaning machines used by facilities that manufacture narrow tubing, facilities that manufacture specialized products re quiring continuous web cleaning, aerospace manufacturing and maintenan ce facilities, and military maintenance and depot facilities. We concluded that this emissi on limit would provide an ample margin of safety to protect health and prevent adverse environmenta l 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 Halogenate d Solvent Cleaning rule. Finally, with regard to continuous web cleaning machines and halogena ted solvent cleaning machines used by narrow tubing and aerospace manufacturing and maintenan ce facilities, we found that the current level of control required by the 1994 NESHAP reduces hazar dous air pollutant emissions to levels that provide an ample margin of safety to pr otect 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 curr ent level of controls for aerospace manufacturing and maintenance facilities, narrow tubing manufact uring facilities, and continuous web cleaning machines prescribed by the 1994 NESHAP both redu ce risk to acceptable levels and provide an ample margin of safety to protec t 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 provide d for public comment. Petitione rs further contend that we re-evaluated the proposed risk assessment, ample ma rgin of safety decisio n, technical feasibility and associated compliance costs without pr oviding notice and opportunity for comment. Specifically,

- Several petitioners stated that the Agency’s decision to use ava ilable data from the 2002 National Emission Inventory (NEI), in stead of data from the 1999 NEI as

and maintenance facilities, narrow tube manufact uring facilities, facili ties 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.

21proposed, appeared for the first time in the Halogenated Solvent Cleaning rule, making it impracticable to raise objecti ons during the period provided for public

comment.

- Petitioners contend that EPA co-pr oposed only two standards-25,000 kg/yr MC and 40,000 kg/yr MC equivalent limits-tha t 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 hal ogenated solvent clean ing 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 fr om halogenated solvent cleaning machines used at military depot and maintenance faci lities 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 conclusi on that the current level of controls prescribed by the 1994 NESHAP both re duces risk to acceptable levels and provides an ample margin of safety fo r 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-evaluat ed the August 17, 2006 proposed technical feasibility with respect to the narrow tube manufacturing facilities; aerospace manufacturing and maintenance facil ities; military depot and maintenance facilities; and manufacturer s that use continuous web cleaners, without providing notice and an opportunity for public comment.

- Some petitioners believe that subseque nt to the August 17, 2006 proposal and December 15, 2006 NODA, EPA re-evaluat ed the compliance costs for the

22Halogenated Solvent Cleaning Rule without providing additional public

comment.

- One petitioner stated that the 3-year co mpliance period appeared for the first time in the Halogenated Solvent Cleaning rule, making it impracticable to raise objections during the period provi ded for public comment. Petitioners also provided information on tec hnical feasibility that was otherwise not
available to EPA at the time of promulgation of the Halogenate d Solvent Cleaning rule showing certain narrow tubing manufacturers either taking steps or planning to take steps at emissions reductions subsequent to promulgation of th e Halogenated Solvent Cleaning rule. This information is discussed in greater detail below. In response to the petitions, we are reconsid ering our conclusions on technical feasibility, the compliance deadline, health risks, and co mpliance costs presented in the Halogenated Solvent Cleaning Rule. What are the Proposed Options for Ha logenated 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 reducti ons that could be achieved if post-MACT HAP emissions were controlled further. These op tions 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 subjec t of today’s reconsideration) may provide an opportunity for additional risk reduction. These options were de rived from information on the availability and feasibility of specific emission c ontrol technologies or practices, but are expressed as maximum facility-wide emissions limits and requirements th at would apply to the total emissions from all of a facility’s solvent cleaning machines that ar e subject to the 1994 MACT standards. We have produced additional risk and cost analyses to su pport the evaluation of these proposed regulatory options. This proposal also reflects our inves tigations 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 achie ved through both solvent switching and traditional technologies and practices for some sectors of th e 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 aff ected sources will be one of the regulatory options

23discussed below, or an option that falls within the range of the options discussed below. Specifically, comments on these proposed options ma y lead us to conclude that emissions limits and requirements are called for that do not fit within th e bounds of one of the presented options. To that extent this proposal recognizes the likelihood of such a resu lt, 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 on ly two co-proposed options, although we had also developed
six emissions levels to evaluate reductions in residual risk if po st-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 leve ls. We recognize that some commenters may either endorse aspects of one or more regul atory options or advocat e 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 opti ons identified in this proposal. Our decision on the final regulatory approach will reflect the co mments 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 app licable to sources as sociated with the general population of halogenated so lvent cleaning machines. A 100,000 kg/yr MC equivalent limit would be applicable to halogenated so lvent cleaning machines located at military maintenance and depot facilities. With respect to continuous web cleaning machines, halogenated solvent cleaning machines used by na rrow tubing facilities, and halogenated solvent cleaning machines used by aerospace manufact uring 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 cont rol called for by the 1994 NESHAP re duces 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 e ffects. (This option represents all standards promulgated in the Halogenated So lvent Cleaning rule last May.) ii. Proposed Option 2
A 60,000 kg/yr MC equivalent limit would be app licable to sources as sociated with the general population of halogenate d solvent cleaning machines a nd halogenated solvent cleaning

24machines used by narrow tube facilities. A 100,000 kg/yr MC equivalent limit would be applicable to halogenated solvent cleaning mach ines located at military maintenance and depot facilities. With respect to c ontinuous web cleaning machines, and halogenated solvent cleaning machines used by aerospace manufacturing and mainte nance 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 NE SHAP reduces HAP emissions to levels that present an acceptable level of ri sk, 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 app licable to sources as sociated with the general population of halogenate d solvent cleaning machines a nd halogenated solvent cleaning machines used by narrow tube facilities. A 100,000 kg/yr MC equivalent limit would be applicable to halogenated solvent cleaning m achines 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 pe rcent control efficiency for those units. This proposal notice of reconsideration is ba sed on data and information used to support the Halogenated Solvent Cleaning Rule (and contai ned 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 Clea ning 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 (nPB 7 ), 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 othe r substitutes that are available. See CAA section 612(c), 40 CFR Part 82, subpart G. Specifically, based on eviden ce that in those solvent clea ning end users nPB could be

25programs. Further, as in our Halogenated Solv ent 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 th an straight emissions limits are a preferable approach for expressing emissions limitations for continuous web cleaning machines because continuous web cleaning machines must cont rol 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 cont rol efficiency as compared to their current emissions levels. In today’s action, we ar e also soliciting comments on whether emission capture systems operating at high efficiency woul d 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 despit e 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 reduc tions through installation of CAD and a capture and control system. Petitioners ci te responses by various narrow tubing facilities indicating an ability to achieve emissions redu ctions ranging from eith er 25-35 percent or 50-95 percent through installation of emissions control devices and ch anges 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 resp onse of one narrow tubing manufacturer indicating the ability to meet this level within 5 years of pr omulgation. EPA did not develop this option for two reasons: first, Congress limits EP A’s ability to impose compliance periods that exceed three years, and; second, the industrial se ctor commented that they simply could not implement the necessary technology within that tim e 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 foun d 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.

26Solvent 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 indicati ng 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 planni ng 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 th e Halogenated Solvent Cleaning rule, one narrow tubing manufacturer has installed vacuum-to-vacu um 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 reducti on, while still another narrow tubing manufacturer had i ndicated an ability to achieve 8 percent and 22 percent TCE emissions reductions through reconf iguration of two flush degreasers and use of reformulated materials, respectively. This information and su pporting documentation have been placed in the docket for this rulemaking. As explained earlier, our August 17, 2006, proposal would have requi red all owners and operators of all halogenated so lvent cleaning machines to comp ly with either 25,000 kg/yr or 40,000 kg/yr MC equivalent facility-wide emissi on limit. We assumed compliance with these limits could be achieved by insta llation 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 retr ofit technologies such as freeboard ratios, working mode covers and free board 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-p roposed standards would likel y be achieved only through installation of expensive technol ogy, and that such technologies had yet to be proven either effective or reliable for their manufacturing proc esses. They also expressed concerns over the proposed compliance period. Additionally, severa l narrow tubing manufac turers that use PCE indicated that solvent switching was an unsui table compliance option because they were bound to their customers’ procedural requirements fo r the higher vapor temperature of PCE and thus, that both TCE and MC, which have lower vapor pr essure temperature, would be inadequate for

27proper 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 a lternative solvent by many original equipment manufacturers. They further indicated that such approval pr ocesses would likely be beyond the proposed 2-year compliance period. Some na rrow tube manufacturers also described their halogenated cleaning machines as unique due to their large sizes and cap acity and indicated the non-availability of vacuum-to- vacuum machines as a result of this uniqueness. As explained above, subsequent to our eval uation of these comments, we issued a NODA that requested additional informa tion 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 an d compliance deadline constraints. In the Halogenated Solvent Cleaning rule , because we were persuaded by these assertions, we found, after re-evaluating risks, as sociated 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 prot ect public health for halogenate d 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 techniqu es 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 a nd 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 manuf acturer 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 pr oduct 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

28with the 1994 MACT standard. Four of these wi ll already meet the 60,00 0 kg/yr MC equivalent limit, the most stringent emissions limit for narro w tube facilities consider ed in this proposal. We assume that these facilities employ certain techniques or technologies to reduce emissions, however, we believe the techniques and tec hnologies employed by the three narrow tube manufacturing facilities may be used by the rema ining facilities to achieve emissions limits of 60,000 kg/yr MC equivalent. In light of the information that was otherw ise not available to EPA at the time of promulgation of the Halogenated Solvent Cleani ng 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 lim its. With the activities completed by these narrow tube facilities, we believe that the remaining narrow tube facilitie s 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 li mit. We believe that with the implementation of these control measures, narrow tubing ma nufacturers might achieve the 60,000 kg/yr MC equivalent emissions limits. Therefore, we ar e 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 manufactur ing 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 technol ogy and retrofit technologi es such as freeboard ratios, working mode covers and freeboard refr igeration devices cannot be used by aerospace manufacturing and maintenance facilities. One pe titioner 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 Haloge nated 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 faci lities indicated an inability to comply with our co-proposed
limits due to technical infeasibility, associ ated compliance costs and the limited proposed compliance deadline. Some facilities indicate d a 5-year minimum comp liance period would be

29required because they would need to investigat e 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 opera tions 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 uns uitable compliance option due to incompatibility and lower vapor pressure. They also stated thatchanging solvents involved a rigorous approval process by the original equipment manufacturer s 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 Clea ning Rule, after our re-e valuation of compliance costs, technical feasibility and ri sks, we concluded that the curre nt 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 ri sk and provides an ample margin of safety to protect public health. Since receiving the petitions, we have re-evalu ated our treatment of the responses to the NODA. Specifically, we have re-evaluated re sponses we received from various aerospace facilities indicating the availabil ity of compliance options that in clude various work practices and installing larger or additional carbon adsorpti on 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 industr y. However, the industr y 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 in cremental costs were disproportiona te given the emissions reductions
involved. Although we have not developed any additiona l information on control technologies

30applicable to the aerospace indus try since promulgating the final rule, today we are re-proposing the outcome of the Halogenated Solvent Cleaning rule, re-proposing the a lternative we rejected in the Halogenated Solvent Cleaning rule, and al so 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 a pplicable on a facilitywide basis for all halogenated Solvent cleaning machines in use at aerospace maintenance and manufacturing facilities. We are soliciting comments on this asp ect 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 machin es or solvent switching are not available control options for continuous web cleaners. As explained earlier, in re sponse 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 complian ce 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 stringe nt 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 c ontinuous 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

31requirements that would be based on overall contro l 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 ra ther than meeting an emission limit was a more appropriate measure of their emi ssions reduction capability. They also indicated that they had installed carbon absorption devices, which can oper ate at about 99 percent control efficiency, and that they could possibly achieve an overall effectivenes s of between 75 percent and 80 percent control efficiency (the 1994 NESHAP re quires 70 percent control efficiency). They
reiterated that most emissions could not be captured by these devices becaus e of the nature of continuous web cleaning machines.
Similar to our treatment of comparable assert ions by both narrow tubing manufacturing and aerospace maintenance and manufacturing f acilities, we were also persuaded by these assertions, and in the Halogenated Solvent Cleaning rule we acknowledged that continuous web machines are designed differently from gene ral halogenated solvent cleaning machines, i.e ., batch cleaning machines, and that it would be both technologically infeasible and cost prohibitive for continuous web cl eaning 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 th e final promulgated emissions limits. Since promulgation of the Halogenated So lvent Cleaning rule, and receipt of the petitions, we have also re-e valuated our assumptions on compliance options, and costs for
additional emission reductions as it relates to continuous web cleaner s. In doing so, we have reexamined responses to our August 17, 2006, proposal and NODA, where some facilities that use
continuous web cleaners indicated th eir preference for tighter control efficiency as compared to a straight emission limit and more specifically their ability to further contro l emissions to between 75 percent and 80 percent overall efficiency. (T hese responses are in the docket for this rulemaking). This proposal reflect s this re-evaluation. Specifically, we assumed that facilities
could switch their HAP so lvent to n-propyl bromide or install CAD to comp ly with the proposed options. Thus, we are including as one of the proposed options an overall c ontrol efficiency of 80 percent for continuous web cleaning m achines. This requirement would be applicable to
facilities that use contin uous web cleaners and that exceed the various proposed emissions limits

32for the general population of haloge nated solvent cleaning machines i.e. , 40,000 kg/yr and 60,000 kg/yr MC equivalent limits. Our decisi on 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 ove rall 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 fi nal 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 mainte nance 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 indicate d an inability to comply with either co-proposed limits due to both technological and compliance deadline constraints. They i ndicated, 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 ha logenated solvent clean ing machines used by military depot and maintenance facilities would provide an ample margin of safety in the Halogenated Solvent Cleaning rule. As e xplained earlier, however, our August 17, 2006 proposal would have required all owners and operators of all haloge nated solvent cleaning machines to comply with either 25,000 kg/ yr or 40,000 kg/yr MC equivalent limits. Since promulgation of the Halogenated So lvent Cleaning rule, and receipt of the petitions, we have also re-e valuated 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 vacu um-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 vari ous regulatory options for

33halogenated solvent cleaning machines used by m ilitary 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 maintena nce 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 reconsid eration of the final rule, we re-examined the proposed 40,000 kg/yr and promulgated 60,000 kg/yr le vels of control for the subset of the category that excludes the four specific industry s ectors identified above (w hich we call “general degreasing units”), retaining the cost assumptions used in the final ru le. As in the final rule, our
evaluation is based on the 2002 NEI data. For this subset of the category that exclude s the four specific industry sectors mentioned above, we have no further new info rmation that would change the f acts 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 ar e soliciting comments on this aspect of this proposal and our final decision will be base d on comments we receive on this proposal.

C. What is the Compliance Schedule?
One petitioner stated that the 3-year complia nce period appeared for the first time in the Halogenated Solvent Cleaning rule, making it impract icable to raise objec tions during the period provided for public comment. One petitioner ar gued that our assumption that narrow tube manufacturers could only achieve a ten percent emissions reducti on within a 3-year compliance period was unsupported by the record and unexplai ned. Another petitioner argued that CAA section 112(f)(4) is the control ling provision that addresses co mpliance deadlines for existing sources with regard to standards promulga ted under CAA sections 112(d)(6) and (f)(2). At proposal, we determined that CAA sec tion 112(i) was the controlling provision that addressed compliance deadlines for existing sources with regard to stan dards promulgated under CAA sections 112(d)(6) and (f)(2). We also pr oposed a 2-year compliance deadline from the effective date of the rule. We were pers uaded, however, by comments on our August 17, 2006

34proposal 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 th at this period was more rati onal and realistic. Thus, we promulgated a 3-year compliance deadline from th e effective date of the Halogenated Solvent Cleaning rule. In this action, we are proposing a 2-year co mpliance deadline from the date that this action becomes final for existing sources not cove red by the Halogenated Solvent Cleaning rule. Additionally, for all sources c overed by the Halogenated Solven t 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 amendmen ts 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 provisi ons addressing compliance deadlines, we interpreted the more specific and co mprehensive 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 complian ce deadline proposed in this action is consistent
with an alternative inte rpretation of the Act, which petitione rs 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 existi ng 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 ex isting sources, and section 112(f )(4) would allow us to grant
such an extension for the installation of cont rols. 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 proposa l 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 solic iting comments on this aspect of this proposal.

35V. 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 t echnologies had yet to be proven effective or reliable for the operations of subject facilities. Base d 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 emi ssion controls, including switching to either a low-HAP solvent
cleaner or non-HAP solvent cleaner as assume d in our August 17, 2006 proposal would be cost prohibitive for the above -referenced industries. Since promulgation of the Halogenated Solv ent Cleaning rule, howev er, we have become aware of certain narrow tubing ma nufacturing facilities that have voluntarily investigated and
instituted HAP emissions reducti ons by installing CAD, vacuum -to-vacuum machines, switching
from HAP solvents to a non-HAP solvent a nd reconfiguration a nd changing production

processes. Consequently, we have re-evaluated our conc lusions on costs, availability of technology and the compliance deadline for the facility-wid e limits in the Halogenated Solvent Cleaning rule. Existing information now leads us to conc lude, 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 installa tion of CAD, vacuum-to-vacuum machines, switching from HAP to non-HAP and improved wo rk practices and manufacturing process changes. In addition, we extrapolated inform ation 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 coul d substitute TCE for n-propyl bromide (nPB) and that military depot and maintenance facilities co uld install large vacuum-to-vacuum machines. Today’s proposed cost estimates do not reflect a ny new information we have been provided orhave 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 fo r 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 contro l required. Control technologies included the replacement of existi ng units with vacuum-to-vacuum machines, solvent switching, and add-on controls. The costs fo r 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 manufactur ers that had already implemente d control technologies, such as CAD, vacuum-to-vacuum mach ines, 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 co st per cancer case avoided for each option

. We have determined facilities in each s ector of industries engaging in halogenated solvent cleaning that would have to add technology measures to c ontrol 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 lim its. We have also ex trapolated 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 con tinuous 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

37compliance 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, a nd as a result have highe r 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 achie ve emission reductions beyond the level of
the MACT and that reduce the leve l of cancer risk associated w ith the emissions as shown in
Table 2. Two of the controls are retrofit cont rols that can be added to existing cleaning machines, three controls are solvent switching op tions that reduce cancer risk, and one control requires the replacement of exis ting equipment with a new vacuum to vacuum cleaning machine. Table 2. Emission Controls Beyond the M ACT 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 ($2,022) Solvent 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 prim ary benefit for the solvent switching options results from the lower MIR cancer risk for the new solv ents. If the MIR values are taken in to 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 sa vings. Costs are in 2007 dollars.
The costs for the retrofit controls were ba sed on vendor estimates obtained in 2005 and

38then revised based on comments received on th e 2006 proposed rule and NODA. The capital costs were based on equipment for a solvent cleani ng machine with a solvent-air interface area of
2.5 m 2 , which is the average size of the solvent cl eaning machines in the database for which size
data are available. A 50% emission reduction is expected to result fr om 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 emissi on 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 appli cation) or a 20 year equipment lifetime (new control application) a nd a 7% interest rate. The solvent switching scenarios, their costs, and impacts are fully discussed in a separate memorandum titled “Evaluation of the Feasibility, Co sts, and Impacts of Switching fr om 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 cleani ng machines are based on vendor estimates
obtained in 2005 and then revi sed based on comments on the proposed rule and NODA. The vacuum-to-vacuum cleaning machine capital cost s were based on the replacement of a solvent cleaning machine with a solvent-air interface area of 2.5 m 2 , which is the average size of the solvent cleaning machines in the databa se for which size data are available. The equipment lifetimes were determined based on information from equipment
manufacturers. It was determined that a 95% re duction in emissions woul d 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 Degreas ing" 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 devi ce (CAD) to our set of available control

39measures based on a number of comments w ho mentioned that this control measure was
available for use in most of the industries affect ed. The level of HAP control associated with
this device is 30%.
Table 5 shows the individual controls that we re 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 informati on obtained since the publication of the final rule. These controls are the replacement of ex isting cleaning equipment with a new vacuum-to-vacuum cleaning mach ine, the addition of carbon adsorption, and switching from TCE to n-propyl bromide (n PB). All costs ar e in 2007 dollars.

Table 5 - Controls Beyond Degreasing MACT Applie d to the Web, Tube, Aero space, 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 $7,080 c $21,239
Vacuum Machine - Small - Hanging 95 $242,000 $22,867 $11,434 c $34,301 Vacuum Machine - Large - Baskets 95 $584,000 $55,125 $27,563 c $82,688 Vacuum Machine - Large - Hanging 95 $788,800 $74,457 $37,229 c $111,686 Enclosure, parts transporter, CAD, and distillation 50 $237,500 $26,076 $13,038 c $39,114 Dual-Split Working-Mode

Cover and Dual-Bank

Freeboard Chillers 25 $44,000 $4,831 $2,416 c $7,247 Aerospace

Enclosure 15 $108,000 $11,858 $5,929 c $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 $80,234 c $240,702 Carbon Adsorption System 90 $1,000,000 $109,795 $54,897 c $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 $46,750 c $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 calcu lated for each specific unit base d on the volume of solvent

40and the cost of the specific solvent in $/gal. b – To account for the large size of the cleaning machine th e 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 a nd costs for controls that have not changed as a result of the reconsideration are explaine d 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 explai ned 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. Th e 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 popula tion 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 A pproval 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 En vironmental Consultants to Ms. Carrie Cooper, P.E., PA DEP NW Regional Office. Re: Salem Tube, Inc, New Degreas ing System (revisions). July 24,2007.

41Salem Tube, Inc. estimated that this sy stem will reduce their TCE emissions to 262 lbs/year. 10 In the 2002 National Emissions Inventory, em issions 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 e qual to half of the annua lized capital costs.

Carbon Adsorption System fo r Web Cleaning Facilities Several web cleaning facilities, such as Alcoa (IA), American Safety Razor (VA), and American Safety Razor (TN) already have CA D systems installed. Therefore, CAD is a demonstrated technology for this population of so lvent cleaning machines. Cost for the purchase of the CAD systems was not available for these f acilities. Therefore, costs provided by Delta
Airlines were used to estimate the costs for in stalling 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 40ft 2 . The percent reduction that De lta 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 Superi or 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.

42had an average TCE removal efficiency of 99.2%. 14 No cost estimate was provided for the
installation of the car bon adsorption unit at Superior Tube. In 2007 and early 2008, Accellent, Inc. instal led a carbon adsorption system comprised of four beds. These beds serve only two of the f our TCE emissions sources – Plant #1 and Plant #2 Vapor Degreasers. However, these two sour ces account for approximately 95% of 2006 TCE emissions. In their permit documents Accelle nt has proposed only a 25-35% reduction in TCE emissions from the installation of this CAD syst em. 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 sy stem 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 Ma nufacturers 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, we re switching from TCE to nPB for their solvent cleaning operations. Contac ts 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 emi ssions. According to nPB manuf acturers, other than adjusting certain equipment settings, no equipment purchases or changes are necessary to switch to nPB. 19 Therefore, capital equipment costs for switching fr om 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. 17 Reference 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.

43the 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 base d on the amount of TCE previously used and assuming that an equal amount of nPB is used at the higher pri ce. Manufacturers of nP B 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.

44VI. Cost and Emission Reductions for the Proposed Options
More than 60 percent of the facilities im plementing 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 purch ase 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 opti on selected. The options outlined here are expected to reduce cancer incidence from a s ource 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 ha logenated solvent cleani ng machines would be affected by this proposed option. Facilities would reduce their em issions 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) Retrofitt ing additional freeboard; (4) in stalling 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 w ould 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 Op tion 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 indi vidual 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 areexpected to incur $3 million in capital costs with annualized costs of $256,000 per ton. The emission limit for military depot maintenance facili ties 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 estim ated reduction in cancer incidence of about 0.22 cases annually, with capital costs at $15.6 m illion 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 faci lities and 150 halogenated solvent cleaning machines would be subject to this proposed opt ion. 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 so lvent 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. EP A 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 ma nufacturing 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 reduc tion 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 faci lities and 260 halogenated solvent cleaning machines would be subject to this proposed opt ion. 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 so lvent cleaning machines used by aerospace

46manufacturing facilities as well as military main tenance and depot facilitie s, 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, aerosp ace manufacturing and maintenance facilities are expected to incur $9 million in capital costs with annualiz ed costs of about $626,000. Using the 2002 NEI database, this emission limit for aerospace manufacturing and maintenance facilities is expected to reduce cancer incide nce by 0.03 cases annually. EPA further estimates that to comply with the 80 pe rcent 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 reduc tion 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 fo r the proposed options broken down by capital and annual components, including estimates of the cost sa vings from solvent recovery, and also emission
reductions and the reduction in a nnual cancer incidence. Solv ent 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 resu lts for the number of potentially affected sources within the 2002 NEI.

47Table 4. Summary Table of Costs and Emi ssion 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 compara tive basis with the number of potentially affected solvent cleaners in the 2002 NEI.

48We are also presenting in Table 5 the asso ciated costs and emissions reductions for various options that we have c onsidered 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 Opti ons 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 a nd Small Business Analysis
These residual risk standards to control hal ogenated solvents will potentially affect the
economic welfare of owners of th e 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 conduc t 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 transact ions and make business
decisions that affect the facili ty. 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 regul ations like this rule potentially affect all businesses, large and small, but small businesse s may have special probl ems in complying with such regulations. The Regulatory Flexibility Act (RFA) gene rally 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 signifi cant economic impact on a substantial number of
small entities. Small entities include sma ll businesses, small organizations, and small governmental jurisdictions. This analysis identi fied the businesses that will be affected by this rule and provides an analysis to assist in dete rmining 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 th e annualized compliance costs as a share of sales for each company. The “sales test” is th e 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 becau se 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 ear ned by firms due to accounting and tax considerations. Firms and entities often have ways availabl e 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 on e is consistent with guidance offered by EPAon compliance with SBREFA, 23 and is consistent with guida nce published by the US SBA’s Office of Advocacy that suggests th at 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 analys is are found in the Appendix to this report.

A. Identifying and Characterizing Small Entities For purposes of assessing the impacts of toda y'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 governme ntal 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 Busine ss 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 industrie s in which they operate in. The SBA defines a small business in terms of the maximum employm ent, 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 code s, the most conservative SBA definition (i.e., the NAICS code with the highest employ ee or revenue size standard) was used.
As mentioned earlier in this report, facilities across seve ral industries use halogenated solvents to degrease their products , therefore a number of size standards ar e utilized in this analysis. For the industries repr esented in this analysis, the em ployment size standard varies from 500 to 1,500 employees. The annual sales sta ndard is as low as 4 million dollars and as high as 150 million dollars. The specific SBA si ze 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 imp act of this rule on affected businesses, the

23 The SBREFA compliance guidance to EPA rulewriters rega rding 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.

51Agency 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 screeni ng-level analysis, annual complia nce costs are defined as the engineering control costs incurred by these compan ies; thus, they do not reflect the changes in production expected to occur in response to th e 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 thes e 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.

52D. Small Business/Entity Impact Results
After considering the economic impacts of th is final rule on small entities, we have concluded that this action will not have a signif icant 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 imp act estimates are based on incorporation of the scale-up factor of 1.74 applied to affected source populations and cost s. 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 affect ed) are small as defined by SBA small business size
standards. Of these 40 small entit ies, none have an annualized cost of greater than 1 percent of their sales. Option 2 is expected to affect 148 ultimate parent en tities, 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 pare nt entities, and fifty-six (or th irty-one percent) of these are small. Of these 56 small entities, three have an a nnualized cost of greater th an 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 project ions to 2012: concepts and context,” Monthly Labor
Review 127(2): 12, Bureau of Labor Statistics, February 2004.

Memo from Sarsony,Chris, engin eering-environmental Management, Inc. to Dail, Lynn, U.S. EPA. “National Cost Impacts.” April 2007.

Memo from Sarsony,Chris, engin eering-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 Fairne ss Act,” November 2006.

Thomas Manufacturing, www.ThomasNet.com . Accessed in March, 2007.Appendix – Construction of Database for Econ omic Impact and Small Business Analysis
This appendix provides a methodology and deta ils 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 databa se and why it is used.

As mentioned in the body of th e 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 anal ysis of affected small entities also; we identify the small parent entities affected in our analysis as describe d 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 halogena ted solvent cleaning facilities under each regulatory option analyzed. This list of facilities reflects faci lities 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 ma de 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 lis ted. This name, however, does not necessarily identify the parent entity of the affected facility. The economist on this project collected information fr om various data sources identified earlier in this report to determine what parent entity owned each identified affected facility. In most cases, the pare nt entity owning an affected facilities is a privately owned firm, but there ar e a few facilities affected that are government-owned. Once the parent en tity for an affected facility is identified, it was included beside the fac ility 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 enti ty nearly 75 percent of the time.
3) Revenue and employment data for each a ffected parent entity. We collected revenue data for the most recent fiscal y ear for each affected parent entity, and we collected this data from the same data sources identified earlier in this56

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 “sma ll” as defined by SBA size standards. The SBA size standards relevant to this analysis are defined earlier in this report. These size standards are define d by 6-digit North American Industry Classification System (NAICS) code. Part of the data that Engineering Environmental Management (e 2 M), Inc. supplied was the NAICS for each affected facility. We use this NAICS to assign an SBA small business size standard to each aff ected parent entity.
4) Annualized compliance costs for each aff ected facility and parent entity. Engineering Environmental, Inc. prep ared capital and annualized compliance cost estimates for each affected solven t cleaner under each regulatory option. These compliance cost estimates include the annualized cost of capital, operating and maintenance cost, and m onitoring, recordkeeping, and reporting costs. We summed up the solvent cl eaner 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 incorporat ed this data into a spreadsheet. There is therefore a spreadsheet with a tab for annuali zed 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 sma ll or large is included as appropriate in each tab. This spreadsheet is available in the public rule docket with the following file name:

*Small businessEconanalysishalogsolvreconsider ationproposalrule.xls – Sp readsheet with all data used in the economic impact analysis for the proposed action.
Finally, we also submit a spreadsheet w ith estimated impacts shown by sector for
affected small businesses in the narrow tube a nd aerospace industries, and small business with continuous web cleaners expected to be affected by this proposed notice of reconsideration. That spreadsheet is HSCreconsiderationsmallbusinessanalysissummarysectorsfinal.xls.

5657

57United 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