Meeting
with
Puget
Sound
Clean
Air
Agency
Date:
June
16,
2003
Attending:
from
Puget
Sound
Clean
Air
Agency
(
PSCAA):
Claude
Williams,
Agata
McIntyre,
Steven
Van
Slyke,
Gerry
Pade
from
US
EPA:
Margaret
Sheppard
from
Garrett
Services,
Inc.:
Andy
Garrett
from
Albemarle
Corporation:
Joe
Miller
Andy
Garrett
opened
the
meeting
with
introductions.
He
said
that
he
had
set
up
a
meeting
because
Margaret
Sheppard
from
EPA
was
in
the
area
and
she
could
talk
about
EPA's
proposed
ruling
on
n­
propyl
bromide
(
nPB).
Ms.
Sheppard
provided
information
on
the
environmental
and
health
effects
of
nPB
(
see
attachment/
Docket
A­
2001­
07,
item
IV­
B­
3).
PSCAA
inquired
about
the
ozone
depletion
potential,
the
toxicological
studies,
and
who
developed
them,
and
whether
nPB
is
considered
a
hazardous
air
pollutant
(
HAP).

Claude
Williams
asked
if
EPA
has
a
policy
of
"
once
in,
always
in"
for
following
the
National
Emission
Standard
for
HAPs
(
NESHAP)
for
halogenated
solvent
cleaning.
For
example,
if
a
company
was
currently
using
a
chlorinated
solvent
and
switched
to
nPB,
would
they
still
be
required
to
meet
all
the
recordkeeping
and
reporting
requirements
of
the
NESHAP?
Mr.
Williams
said
that
people
would
want
to
know
EPA's
official
policy
on
this,
and
that
EPA
should
let
state
and
local
agencies
know.

PSCAA
staff
asked
some
practical
questions
about
the
use
of
nPB,
including
the
odor
threshold
and
the
possibility
of
recycling
spent
solvent
or
using
spent
nPB
as
an
additive
in
construction.
Joe
Miller
of
Albemarle
said
that
in
Japan,
nPB
users
distill
and
recycle
the
solvent.
This
is
not
yet
happening
in
the
U.
S.
because
there
is
not
quite
enough
volume
of
nPB
to
make
recycling
viable.
However,
it
is
possible
that
this
could
happen
in
the
future
if
the
volume
of
nPB
use
increases
slightly.
Currently,
Albemarle
recommends
to
its
customers
that
the
spent
solvent
is
incinerated.
Albemarle
has
even
offered
free
pickup
and
disposal
of
spent
solvent
for
its
customers.

Andy
Garrett
asked
the
PSCAA
about
how
a
company
would
apply
for
a
permit
if
they
are
switching
solvents.
PSCAA
staff
said
that
the
company
must
demonstrate
that
they
have
looked
at
different
options,
including
changing
their
process.
This
would
be
like
an
analysis
of
alternatives
to
the
best
available
control
technology.
The
users
would
need
to
determine
"
How
clean
does
clean
need
to
be?"
The
company
must
provide
an
estimate
of
volatile
organic
compound
(
VOC)
emissions.
Mr.
Garrett
asked
about
the
time
and
cost
involved
for
approval
of
the
permit
application.
PSCAA
responded
that,
once
a
permit
application
is
truly
complete,
they
aim
to
complete
the
review
in
60
days.
They
said
that
it
could
cost
up
to
$
1000
for
an
application
with
a
solvent
regulated
under
New
Source
Performance
Standards
(
NSPS)
Subpart
T
or
a
NESHAP.
For
a
new
application
for
a
Notice
of
Construction
permit,
a
typical
cost
might
be
$
2500
to
$
3000.
If
there
is
an
existing
permit,
there
is
no
change
to
annual
fees
(
on
the
order
of
2
$
800/
year).
PSCAA
commented
that
this
is
relatively
small
compared
to
Title
V
permitting
fees.
In
December
2005,
major
sources
will
need
to
apply
for
a
Title
V
operating
permit
if
they
fall
under
NSPS
Subpart
T
or
a
NESHAP.
This
would
cost
at
least
$
15,000
for
the
application,
and
there
would
be
additional
fees
based
on
emissions.
According
to
PSCAA
staff,
the
application
is
over
60
pages
long.
PSCAA
staff
noted
that
this
cost
might
well
be
more
than
the
cost
of
using
a
more
expensive,
but
less
toxic
chemical
that
is
not
a
HAP.
