Margaret Sheppard/DC/USEPA/US

06/18/2007 11:05 AM	To

	"DeWayne Hartsoe" <dhartsoe@midsouthadhesives.com>

	cc

	jgordan@midsouthadhesives.com

	bcc

	

	Subject

	Re: nPB in Adhesives

	

	

Dear Mr. Hartsoe,

Thank you for your questions.  Based on the advice I received from our 

legal counsel, I will state what we have already said in the proposal, 

rather than adding further interpretation or new clarification.

I am not clear if your first question concerns the alternate approach
(pp. 

30190-30195 in the proposal) or if you were asking about making some
sort 

of demonstration about an ability to meet specific exposure levels.  If 

you or your customers intend to provide information as part of public 

comments, our office will welcome the chance to see more exposure data 

from facilities using nPB and other relevant technical information.

The alternate approach would require any user of nPB in the proposed end


uses to meet the use conditions described in the alternate option for 

comment (pp. 30190-30195, summary on p. 30193). 

Note that the proposal also takes comment on the specific issue you
raise 

about specific applications where other adhesive options do not work at
72 

FR 30190:

            During the public comment period on the June 2003 NPRM, one 

commenter representing the adhesives industry stated that there are some


small but critical applications that require nonflammability and high 

solvency (Collatz, 2003).  The commenter did not specify what those 

applications are, and whether there was information showing that other 

types of adhesives, such as those using water, flammable solvents, or 

methylene chloride, are technically infeasible in these applications. 
We 

request comment and data on whether there are any unique applications in


the adhesives end use for which there are no technically feasible 

alternatives other than nPB and thus, for which nPB should be allowed. 
If 

so, and if determined that nPB should be unacceptable except where no 

other substitutes are feasible, we would consider finding nPB acceptable


subject to narrowed use limits, with requirements for each end user to 

perform a demonstration that there are no other technically feasible 

alternatives for their particular site, to install local exhaust 

ventilation equipment designed to reduce exposures to acceptable levels 

and to perform worker exposure monitoring.  Alternatively, if there was 

sufficient information provided during the public comment period showing


that there are applications in which nPB can be safely used, we would 

consider finding nPB acceptable in adhesives, subject to use conditions 

requiring installation of local exhaust ventilation and worker exposure 

monitoring.  This would allow for use of nPB in any applications where
it 

may be used safely if any such applications exist.

You asked if nPB will be an acceptable substitute for methylene chloride


in adhesives.  Our proposal for adhesives is that nPB would be an 

unacceptable substitute for methyl chloroform, CFC-113, and HCFC-141b. 

You asked if our proposal is that methylene chloride is safer for
workers 

than nPB.  Our proposal is that nPB poses significantly greater risk to 

human health as compared to other available alternatives in the
adhesives 

end use (72 FR 30189).

If you believe that the proposal is not sufficiently clear, please
provide 

us with comments to that effect.  You can comment online in docket 

EPA-HQ-OAR-2002-0064 at www.regulations.gov .

Thank you for taking the time to read the proposal and to share 

information with your customers.

Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

"DeWayne Hartsoe" <dhartsoe@midsouthadhesives.com> 

06/07/2007 02:04 PM	

	To

	Margaret Sheppard/DC/USEPA/US@EPA

	cc

	<jgordan@midsouthadhesives.com>

	Subject

	nPB in Adhesives

	

	

	

	

Dear Ms. Sheppard,

I have a few questions that I would like clarification on so that we may

inform our customers of this proposed change in nPB usage.

We have a very samll number of customers in the aircraft industry who
are

now using nPB based adhesives and we have not been able to find a
suitable

replacement that will bond all of the various substrates that they use.
Is

it going to be possible for them to continue using nPB based adhesives
if

they are able to demonstrate that they can keep thier WEL below THE
EPA's

proposed limit of 20 PPM?  10 ppm? Is your alternate proposal going to 

apply

to any user that can by monitoring demonstrate they will be able to meet


the

TWA exposure limits? Will nPB be an acceptable substitute for Methylene

Chloride in adhesives?

Also the way I have understood this proposal is that Methylene Chloride
is

safer for workers than nPB.  Am I understanding this correctly?

Any information that you can provide would be most helpful.

Thanks,

DeWayne Hartsoe

President

Mid South Adhesives, Inc.

5611 Universal Drive

Memphis, TN 38118

