MEMORANDUM

DATE:	July 2, 2007

SUBJECT:	Summary of the March 8, 2007 Conference Call with the Flexible
Packaging Association  SEQ CHAPTER \h \r 1 

FROM:	Heather P. Brown, P.E.

TO:		  SEQ CHAPTER \h \r 1 Kim Teal,   SEQ CHAPTER \h \r 1
EPA/OAQPS/SPPD/CCG

	The purpose of this memorandum is to summarize the discussion that took
place during a conference call with the Flexible Packaging Association
(FPA).  The FPA requested this conference call to get a good
understanding and the context of why EPA was interested in the   HAP to
VOC ratio, and to discuss whether reducing HAP had led to an increase in
VOC.

MEETING PARTICIPANTS

U.S. Environmental Protection Agency (EPA)

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

Mr. Dave Salman, Office of Air Quality Planning and Standards, Sector
Policies and Programs Division, Coatings and Chemicals Group

 

EC/R Inc.

Ms. Heather Brown

Industry Representatives

Flexible Packaging Association (FPA)

Mr. Howard Hofmeister, Bemis 

Mr. Ram Singhal, FPA 

Mr. Mark Pederson, Rollprint 

SUMMARY OF DISCUSSION

	The FPA and EPA discussed the HAP to VOC ratio.  EPA indicated that it
might be possible to subcategorize the FPA and recommend a separate
limit.  The FPA indicated that there is a wide range in HAP to VOC
ratios across the industry and that it is facility specific.  

	The FPA also clarified that the VOC in coatings did not increase as a
result of complying with the NESHAP, but instead, the HAP content was
replaced with non-HAP VOC.

  SEQ CHAPTER \h \r 1 	The FPA was concerned that using the HAP limits
in the paper and other web coating NESHAP as VOC limits would result in
limits that are too stringent.  EPA indicated that limits in California
were being considered rather than the NESHAP limits.  The FPA stated
that the California numerical limits were back-calculated to achieve air
quality needs and that FPA facilities have moved from California rather
than operate at these limits.

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