MEMORANDUM

DATE:	September 17, 2007

SUBJECT:	Summary of September 12, 2007 Meeting with the Industry
Representatives

Related to the Paint and Allied Products Area Source NESHAP

FROM:	Bradley Nelson, EC/R Inc.

TO:		Dr. Mohamed Serageldin, EPA/OAQPS/SPPD/NRCG

I.  Purpose of Meeting

The purpose of this meeting with the Paint and Allied Products industry
representatives was to discuss the current status of the Urban Area
Source NESHAP for the Paint and Allied

Products manufacturing sector.  Contact information for the invited
industry groups are provided

in Attachment A.  The meeting was also used to discuss the NPCA
responses to the questions provided by EPA in preparation for this
meeting.  The NPCA responses are included in Attachment B of this
document.

II.  Attendees

Mohamed Serageldin, EPA	David Darling, NPCA            Jeff Whitlow, EPA
 Alison Keane, NPCA Bob Schell, EPA	John Hopewell, NPCA Sharon Nizich,
EPA	 George Fuchs - NAPIM

Randy McDonald, EPA	Creg Browne, Akzo-Nobel

Bradley Nelson, EC/R	George Patterson - DuPont Performance Coatings

John Kinast, Henry Company	Allen Stegman, Valspar Corporation

Karen Bond, Lord Corporation	Desi Chari, Rohm & Haas

H. Charles Cooper, Ashland Distribution	Jordan Dern, Delta Laboratories

Mark Lutterbach, Red Spot Paint	Deborah Moilanen, BASF Corporation

Robert Stetson, Kelley-Moore Paint Co.	Todd Wirdzek, Kelley-Moore Paint
Company

R. Scott Thomas, Sherwin-Williams	Jennifer Wolfenden, Benjamin Moore

Barry Elman, EPA

III. Summary of Meeting

David Darling started the meeting by asking what the current timeline
was for the Paint and Allied Products Area Source NESHAP.  Dr. Mohamed
Serageldin indicated that the projected date for proposing the rule was
12/31/07 and the promulgation date of the final rule was set for
6/15/08.  

The industry group responded that they thought the rule was supposed to
be promulgated on 6/15/09.  Bob Schell stated he believed that the rule
was in the 6/15/09 bin.  EPA indicated that they will inform the
industry of the expected promulgation date.

Following the meeting EPA revised the schedule for the project so that
the rule will be proposed in the summer of 2008 and promulgated by June
15, 2009.

Dr. Serageldin presented an overview of the Urban Area Source Strategy,
a list of the significant Urban Air Toxic pollutants, a summary of the
Paint and Allied products manufacturing operations, and the proposed
schedule for the rule.  A copy of the presentation is provided in
Attachment C.

The industry group stated that the NEI database does not provide an
accurate representation of the HAP emissions from the Paint and Allied
Products industry as compared to TRI.  NPCA documented numerous problems
with the NEI in our past letters to EPA, including the fact that the NEI
process is not transparent to industry and that in many cases the NEI
data is based on worst case emission estimates from State Agencies. 
NPCA therefore recommends that EPA instead use TRI emissions data to
calculate emissions from the industry. Dr. Serageldin asked the NPCA if
they could provide 2002 TRI data for 10-15facilities so that EPA could
compare that set of data to the 2002 NEI data.  In response, NPCA
suggested that OAQPS staff sit down with the Sector Strategies staff to
go over the TRI analysis the Sector’s program has completed on the
paint manufacturing industry.  The NPCA asked EPA why 2002 data was used
to compare with the 1990 baseline emissions.  EPA responded that 2002
NEI is the most recent inventory data, and provides the best emission
estimate of the Paint and Allied Products industry. In addition, the
2002 Census of Manufacturing provided information on the number of
facilities and annual production that was used to estimate HAP
emissions.

EPA asked the industry group about particulate emissions from addition
of pigments to the paint mixture.  The industry responded that generally
facilities that use dry pigments utilize bag filters to capture
particulate emissions from process tanks in which pigments are added,
however some facilities use pigments that are in a paste or slurry
medium.  The industry stated that once pigments are in a paste or slurry
there are no PM HAP emissions from the mixing associated with these
pastes or slurries.  In response to a question from EPA about the
solvent nature of a slurry, the industry indicated that water based
pigment “carriers” are used for water-based coatings and solvent
pigment “carriers” are used for oil based coatings.  EPA asked about
the types and % effectiveness of baghouses. Industry noted that in
general bag house particulate control technologies achieve approximately
98% PM reduction.

EPA asked the industry about the size of mixing tanks at their
facilities.  The industry group responded that generally there are two
types of mixing or process tanks – portable and stationary tanks.  In
general, portable tanks are small (350 gallon tanks), and stationary
tanks are larger (the average large size tank is approximately 2,500
gallons).  The industry group also responded that survey data indicated
that 95% of the major sources have covers, but they did not have an
estimate of the percentage of area sources that use covers. Industry did
say that EPA needs to be careful with the term “cover” since a cover
could be a simple plastic cover, or a loose fitting metal lid – there
is no definition of the term cover or lid. 

Industry also mentioned that there are general differences in venting of
portable and stationary process tanks in which pigments are added. In
general, dedicated vents are installed on stationary tanks, whereas
portable tanks are placed under ventilation “stations.”    

Industry mentioned that some QA/QC and adjustment occurs in process
tanks that do not have particulate controls. The quantity added is very
small and as such industry believes that these adjustments do not need
to be controlled. Industry asked EPA to allow pigment additions for
QA/QC and adjustment without requiring particulate controls in the Paint
and Allied products standard.

IV. Action Items

The Sector Strategy and OAQPS will meet to discuss the problems
associated with the NEI database, TRI Industry trends and how the TRI
data could be used instead of NEI. 

Industry was to provide additional information on the
Stationary/Portable tanks - what are the differences in operation and
controls (baghouses – type and % effectiveness) for portable and
stationary tanks. 

Industry is to identify any “33 Area source chemicals” used solely
for cleaning and not formulation.

EPA to provide NPCA the NEI analysis that was described on the
conference call, specifically EPA’s emission extrapolation estimates. 
  



Attachment A

Industry Group Contact Information

National Paint and Coating Association (NCPA)

1500 Rhode Island Ave., NW

Washington, DC 20005

David F. Darling, P.E., Director, Environmental Affairs

202-462-6272

David Darling

  HYPERLINK "mailto:ddarling@paint.org"  ddarling@paint.org 

National Association of Printing Ink Manufacturers (NAPIM)

581 Main Street

Woodbridge, NJ 07095

George Fuchs, Manager, Environmental Affairs & Information Systems

732-855-1525

  HYPERLINK "mailto:gfuchs@napim.org"  gfuchs@napim.org 

Adhesive and Sealant Council (ASC)

7979 Old Georgetown Road

Suite 500

Bethesda, MD 20814

Mark Collatz, Director, Government Relations

301-986-9700 ext. 112

  HYPERLINK "mailto:mark.collatz@ascouncil.org" 
mark.collatz@ascouncil.org 



Attachment B

Paint and Allied Products Area Source Rulemaking;

NPCA Response to EPA Questions



 

Attachment C

EPA Paint and Allied Products Presentation

 

 

 

 

 

 

 

 

 

 

 

