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AQUEOUS VCN CLEANING SYSTEMS > SOLVENT TUBE CLEANING > STUDY

RESULT STUDY - VACUUM TO VACUUM SYSTEMS COMPLIANCE WITH NESHAP SOLVENT CLEANING MACHINES

Federal Register / Vol. 71, No. 159 / Thursday, August 17, 2006 / Proposed Rules Page 47682.

“It was determined that a 97 percent reduction in emissions would result from switching from an existing solvent cleaning machine to a Vacuum-to-Vacuum cleaning machine.” This determination came from data taken from Vacuum to Vacuum systems operating in the field for over 10 years. Units have now been in the field over 15 years.

Federal Register / Vol. 71, No. 159 / Thursday, August 17, 2006 / Proposed Rules Page 47684

“To achieve the emission limit of 40,000 kg/yr MC-equivalent, nearly 31 percent of the affected facilities may need to select vacuum to vacuum cleaning machines to achieve necessary emission reductions. We estimate the annualized capital costs plus the operation and maintenance (O&M) costs at nearly $4.4 million for these machines, yet with a solvent savings of nearly $8.9 million, the total annualized control costs would ultimately save the industry nearly $4.5 million for this emission control.”

The EPA rated the Vacuum to Vacuum systems as the most efficient way to meet requirements with a near zero emissions resulting in substantial solvent savings cost.

For example, for vapor cleaning units using PCE, there are two control options available when the required reduction is between 78 percent to 99 percent—PCE to MC and a vacuum cleaning machine. In this case, we initially assumed that approximately 25 percent of the units would choose the PCE to MC option and that approximately 75 percent of the units would choose the vacuum cleaning machine option. We assumed that more would choose the vacuum cleaning machine option because it is more universally applicable. The solvent switching option will be limited relative to the other options because TCE and MC will not meet the cleaning requirements for all cleaning applications. The costs and emission


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