MEMORANDUM

DATE:	January 30, 2008

SUBJECT:	Summary of January 28, 2008 Meeting with the National Paint and
Coatings Association Environmental Management Committee

FROM:	Bradley Nelson, EC/R Inc.

TO:	Melissa Payne, EPA/OAQPS/RDPAG

I.  Purpose of Meeting

The purpose of this meeting was to discuss the concerns and suggestions
by the National Paint and Coatings Association (NPCA) to the Area Source
NESHAP for the Paint and Allied Products manufacturing sector.  

II.  Attendees

Melissa Payne, EPA	David Darling, NPCA            Chebryll Edwards, EPA	
Alison Keane, NPCA 

Laura Bunting, EPA	John Hopewell, NPCA 

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

John Kinast, Henry Company	Allen Stegman, Valspar Corporation

H. Charles Cooper, Ashland Distribution	Marcela Nichols, True Value
Manufacturing Co.

Prouopis Christou, Benjamin Moore	Deborah Moilanen, BASF Corporation

Rajesh Thotakuva, Akzo-Nobel	Meghan Roe, PPG

Jule Wojtanowski, DuPont	Creg Browne, Akzo-Nobel

Barry Elman, EPA

III. Summary of Meeting

David Darling started the meeting by asking for an update from EPA on
the status of the Paint and Allied Products Area Source NESHAP.  Melissa
Payne responded that she is the new Work Assignment Manager for the
project and she is currently reviewing the documents created for this
project.  Mr. Darling stated that they wanted to provide the comments
and concerns that the NPCA and their members have with the NESHAP.  

Melissa Payne asked the group what rules (i.e., MACT, OSHA, NESHAP) are
already on place for the Paint and Allied Products industry.  Dave
Darling responded that the NPCA has provided to EPA a chronological
history of the rules that have been put in place for the paint and
coatings industry.  He stated that he would send a copy of the history
to EPA.  Ms. Payne asked about the use of Toxic Release Inventory (TRI)
data for estimating emissions from the paint and coatings industry.  The
industry believes that the TRI data provides the best data available
that represents the current emissions from the industry, because the
emissions are provided by the individual facilities.  EPA noted that the
2002 TRI database only provided emissions information from 220
facilities of the 1,409 facilities listed in the U.S. Census and asked
why so few facilities are reporting emissions in the TRI.  The industry
group responded that many facilities have less than 10 employees and
therefore do not have to report TRI emissions.  They felt that the Prado
Principle could be used to estimate emissions for the facilities that
did not report emissions in the TRI.  In addition, the TRI database only
requires facilities with toxic emissions greater than 10,000 to 25,000
lbs/yr depending on the pollutant to report.  The industry also noted
the TRI data is collected annually therefore it can be used to show
trends in the industry, whereas the National Emissions Inventory (NEI)
is only published every 4 years.

The NPCA provided a presentation summary of the concerns/suggestions of
the area source NESHAP by the paint industry.  A copy of the
presentation is provided in Attachment A.  The main concerns of the
paint and coatings industry are;

The NPCA does not believe that the Paint and Allied Products industry
should have been included in the 112(k) area source rulemaking.

EPA should consider the urban air toxic reductions that have already
been done by the industry.

Many of these facilities are small businesses and the NCPA does not
believe using data from the Miscellaneous Coatings MACT is appropriate.

The NCPA believes that EPA should limit the scope of the area source
rule to only the 30 urban air pollutants and the rule should apply only
to those facilities that use those chemicals.

The NPCA discussed the reductions in the 6 urban air pollutants of
concern and presented tables using data from both the NEI and TRI
databases.  

The NPCA stated that most of the area source facilities are small
businesses and they have concerns with using data from the MCM for this
rule.  They believe the cost per ton for the pollution control equipment
from the larger MACT facilities does not transpose to the smaller
facilities.  EPA stated that equipment costs will be obtained for the
smaller facilities, and the cost effectiveness will be calculated using
the emissions from the area source facilities.  

EPA asked about the size of portable tanks for these facilities.  The
industry responded that these smaller tanks range from 100 to 250
gallons each, but can be up to 500 gallons.  Additionally the industry
responded that much of the coatings they produce are custom ordered. 
They believe that regulations from the end users have required the paint
manufacturing industry to reduce HAPs and volatiles in the coatings that
they produce.  

The NPCA mentioned that not every process tank needs a cover, and after
some discussion about the definition between a “lid” and a
“cover,” agreed that they were content with the definition as listed
in the MCM.

EPA asked about the cost of switching from dry pigments to wetted
pigments.  The NPCA stated that they could provide the EPA with some
cost information.

IV. Action Items

1. EPA will continue to look at the TRI data and compare to the previous
data from the NEI database.

2. The NPCA will send to EPA the chronological timeline of regulations
that currently in place for the paint industry.  

3. The NPCA will provide cost information for switching from dry
pigments to wetted pigments.



Appendix A

NPCA Presentation

 

 

 

 

 

 

 

