MEMORANDUM

TO:		Martha Smith, OAQPS/SPPD/NRCG

FROM:	David Hendricks, EC/R Inc.

DATE:		February 22, 2007

SUBJECT:	Summary of the February 5, 2007 Metal Furniture Coating CTG
Stakeholder Meeting

	The purpose of this memorandum is to summarize the discussion that took
place during the stakeholder meeting for the metal furniture coating CTG
project held on February 5, 2007 at the EPA campus in Research Triangle
Park, NC.  The meeting objectives were to inform the stakeholders of the
current project status, provide a summary of why EPA is developing this
CTG, and present possible regulatory options.  The meeting presentation
slides for the meeting, including the agenda, are provided in Attachment
1.

MEETING PARTICIPANTS

U.S. Environmental Protection Agency (EPA)

Mr. Bruce Moore, Office of Air Quality Planning and Standards

Ms. Martha Smith, Office of Air Quality Planning and Standards, Sector
Policies and Programs Division, Natural Resource and Commerce Group

Ms. Amy Branning, Office of General Counsel

EC/R Inc.

Mr. David Hendricks

Industry Representatives

Mr. Bill Bulkowski, Steelcase Inc.

Mr. Scott Lesnet, HNI Corp.

Mr. Brad Miller, Business and Institutional Furniture Manufacturer’s
Association

Mr. Bill Perdue, American Home Furnishings Alliance

SUMMARY OF DISCUSSION

	Ms. Smith opened the meeting by welcoming all of the participants and
allowing each participant to provide a brief introduction.  She then
reviewed the meeting objectives and the agenda.

	Mr. Moore then provided an overview of why EPA is developing control
techniques guidelines (CTG).  He began by reviewing the requirements of
section 183(e) of the Clean Air Act (CAA).  Under section 183(e), EPA
conducted a study of volatile organic compound (VOC) emissions from the
use of consumer and commercial products to assess their potential to
contribute to levels of ozone that violate the national ambient air
quality standards (NAAQS) for ozone, and to establish criteria for
regulating VOC emissions from these products.  The EPA then listed for
regulation those categories of products that account for at least 80
percent of the VOC emissions, on a reactivity-adjusted basis, from
consumer and commercial products in areas that violate the NAAQS for
ozone.

	From that exercise, the Metal Furniture Coatings category was
identified for regulation, which requires the EPA to promulgate best
available controls (BAC) for this category of consumer products. 
However, section 183(e)(C) provides that EPA may issue CTG based on
reasonable available control technology (RACT) in lieu of regulations if
EPA determines that such guidance will be substantially as effective as
regulations in reducing emissions of VOC.

	Mr. Moore pointed out the CTG currently under development is not a
Federal regulation.  Rather, it is a guidance document to be used by
States to develop their own regulations based on the CTG to meet state
implementation plan (SIP) requirements for nonattainment areas.

	Ms. Smith then summarized the work EPA has completed on this project. 
First, EPA examined regulations that currently affect the metal
furniture coating industry.  Federal regulations include the national
emission standards for hazardous air pollutants (NESHAP) for metal
furniture surface coating, the new source performance standard (NSPS)
for surface coating of metal furniture, and a previous CTG for surface
coating of metal furniture.  Both the NSPS and CTG are directed at VOC
emissions, while the NESHAP is directed at emissions of hazardous air
pollutants (HAP).  However, the NESHAP will have a co-benefit of
reducing VOC emissions as well.

	The VOC rules for all 50 States were also examined.  The EPA found that
the majority of State rules followed the existing CTG limits, and two
states had limits more strict than the existing CTG limits.

	Ms. Smith explained that the CTG under development must be based on
RACT.  The EPA has defined RACT as “the lowest emission limitation
that a particular source is capable of meeting by the application of
control technology that is reasonably available considering
technological and economic feasibility.”  Because of these factors,
RACT will tend to change over time.  Therefore, EPA is assessing the
current level of control imposed by Federal and State regulations as
part of the RACT determination and is developing regulatory options
based on these regulations.

	Ms. Smith provided the stakeholders with the project schedule.  The EPA
plans to finalize the CTG document and publish a final Federal Register
notice on the determination that the CTG is at least as effective as a
national rule no later than September 30, 2007.  Mr. Moore clarified
that EPA is not proposing or promulgating a CTG.  The Federal Register
notice will be for the determination.  However, the notice for the
proposed determination will also request comment on the draft CTG.

	Mr. Bulkowski asked if the rules that the States develop based on the
CTG will apply only in ozone nonattainment areas.  Mr. Moore responded
that States are required to apply RACT to nonattainment areas regardless
of whether there is an applicable CTG.  The CTG provides guidance to the
States for developing these RACT rules, but the States are free to apply
their rules to any part of the State they deem appropriate.

	Mr. Bulkowski then asked if EPA will publish a finding, based on
economic and technical feasibility, that the draft CTG represents RACT. 
Mr. Moore said that EPA will publish a finding of what we have defined
as RACT, but this will not include an economic or technical analysis. 
Because of the short time frame imposed on EPA to complete this CTG, an
in-depth study of cost and technical feasibility is not practical.  Mr.
Lesnet asked if this means that EPA is basing their decisions on a
literature review.  Mr. Moore replied that to a large extent that is
true, but we are also trying to involve stakeholders as early in the
process as possible to provide relevant information.

	Mr. Lesnet asked if the scope of the CTG will be limited to just
coatings, or will other operations be included such as how affected
source is defined in the NESHAP.  Mr. Moore responded that since the
industry has been looking at tracking and controlling emissions on a
facility-wide basis in response to the NESHAP, then it would make sense
to continue that basis in the CTG to maintain consistency.  Mr.
Hendricks pointed out that in the development of the NESHAP, EPA
developed a VOC emission limit that was equivalent to a facility
complying with the HAP emission limit of the NESHAP.  Mr. Moore
suggested that it would be helpful if the industry would comment on
whether the VOC limit developed during the NESHAP project is valid based
on coatings and solvents currently used by the industry.  Mr. Lesnet
expressed concern about whether a VOC limit developed using data from
large sources is transferable to smaller sources that are not subject to
the NESHAP.

	Mr. Perdue stated that the amount of coatings used in the production of
home furniture is much smaller than used for office equipment.  Thus,
the CTG is less critical to the home furniture segment of the industry. 
Additionally, much of the metal coating performed for the home furniture
segment falls under the miscellaneous metal parts and products source
category.  Mr. Perdue believed that despite the lower coating usage, the
VOC and HAP content data of the coatings used should be readily
available.

	Mr. Moore asked the industry representatives whether the VOC content of
metal furniture coatings has increased in response to the NESHAP HAP
limits.  Mr. Bulkowski replied that in certain situations the VOC
content has gone up, but in general VOC emissions have decreased because
of increased use of high solids and powder coatings.  Mr. Lesnet added
that there has been a switch to exempt VOC solvents in extreme ozone
nonattainment areas, but overall solvent content is generally the same.



ATTACHMENT  1

MEETING PRESENTATION SLIDES

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