Date:
September
5,
2002
From:
Brenda
Shine,
North
State
Engineering,
Inc.

To:
David
Randall
RTI
Project
Leader
Miscellaneous
Organic
Chemicals
MACT
Standard
Subject:
Meeting
Minutes
Teleconference
with
Kodak
Corporation
June
13,
2002
I.
Introduction
On
June
13,
2002,
representatives
of
Kodak
held
a
teleconference
with
Randy
McDonald
and
Brenda
Shine
to
discuss
provisions
in
the
proposed
Miscellaneous
Organic
Chemicals
NESHAP.
The
attached
Powerpoint
presentation
was
forwarded
by
Kodak
prior
to
the
teleconference
as
background.
The
following
issues
were
discussed:
1)
the
intent
of
the
family
of
materials
definition
and
preamble
discussion,
2)
the
definition
of
process
vent
and
how
it
should
be
applied
to
sources
such
as
equipment
exhaust
capture
systems
(
elephant
trunk
systems),
3)
the
format
of
the
proposed
process
vent
requirements,
and
4)
the
proposed
pollution
prevention
alternative.

The
paragraphs
below
summarize
the
discussion.

II.
Participants
Kodak
Deb
Chapin
Bill
Lorry
Walter
Toot
USEPA
Randy
McDonald
NSE
Brenda
Shine
2
III.
Discussion
A.
Family
of
Materials
Kodak
is
concerned
about
the
MON's
definition
and
discussion
relating
to
family
of
materials.
Their
facility
manufactures
proprietary
imaging
chemicals,
but
these
chemicals
serve
various
functions,
as
presented
in
the
attached
presentation.
Kodak
manufactures
on
the
order
of
1,000
chemicals
at
their
site;
all
these
products
are
considered
imaging
chemicals
but
Kodak
did
not
have
a
clear
idea
of
how
the
definition
of
family
of
materials
in
the
proposed
MON
would
require
that
products
be
grouped
into
families
of
materials.
Products
grouped
according
to
end
use
include
photographic
couplers,
dies,
stabilizers,
emulsions,
polymers
for
toners,
suspension
polymers,
and
other
miscellaneous
products.
Among
these
products,
there
are
different
classes
of
couplers,
for
example,
and
different
chemicals
based
on
chemical
structure
and
end
use
characteristics.
Kodak
representatives
stressed
that
the
definition
needed
to
be
clear.

B.
Definition
of
Process
Vent
and
Format
of
Process
Vent
Standards
Kodak
briefly
described
elephant
trunk
systems
that
are
used
to
reduce
operator
exposure
during
periods
in
which
a
manway
or
hatch
in
a
process
vessel
must
be
open
or
closed.
They
want
EPA
to
consider
some
language
that
would
clearly
describe
requirements
for
these
systems
and
suggested
that
the
rule
differentiate
between
personal
hygiene
or
personal
safety
and
process
requirements.
They
also
suggested
a
maximum
limit
for
an
emissions
episode
below
which
an
emission
event
could
be
considered
deminimis.
Kodak
representatives
indicated
that
they
would
like
EPA
to
consider
another
format
to
accommodate
insignificant
emissions.

C.
Pollution
Prevention
Alternative
Without
going
into
details,
Kodak
representatives
indicated
that
they
would
like
to
see
the
pollution
prevention
alternative
be
extended
to
beyond
a
single
process
basis.
Their
written
comments
will
contain
details
of
how
this
alternative
could
be
implemented.
Attachment
Family
of
Materials
Compliance
Strategy
Issues
