From:	Norman, Caffey [CNorman@PattonBoggs.com]
Sent:	Tuesday, September 27, 2011 5:29 PM
To:	Alex Ryan-Bond
Cc:	Faye Graul
Subject:	Model Rule for Degreasing

Follow Up Flag:	Follow up
Flag Status:	Flagged

Dear Mr. Bond,
 
On behalf of the Halogenated Solvents Industry Alliance, Inc. ( HSIA), I write in support 
of the revised model rule for solvent degreasing as it relates to vapor degreasing.  HSIA 
represents manufacturers and users of chlorinated solvents, including 
trichloroethylene (TCE), perchloroethylene, and methylene chloride, and 
manufacturers of solvent cleaning equipment.  In this regard, the most recent revision 
provides:
 
In addition, the new VOC content limit requirements only have been applied cold 
cleaners. The requirements for vapor degreasing remains the same as in the 2001 
model rule, with the exception that all types of parts or substrates are regulated, not just 
metal parts.
 
The decision to leave the vapor degreasing requirements unchanged is absolutely 
warranted given that vapor degreasing using halogenated solvents, includingTCE, is 
already adequately regulated under the National Emissions Standard for Hazardous 
Air Pollutants (NESHAP) for solvent degreasing.   It is important that the small 
businesses in the Northeast that depend on TCE to deliver high-quality parts that meet 
buyer specifications will be able to continue to do so.

W. Caffey Norman  
Patton Boggs LLP  
2550 M Street, NW  
Washington, DC 20037  
202-457-5270 (phone)  
202-457-6315 (fax)