Testimony

of

Lori Leffler 

PPG Industries 

on

National Emission Standards for Hazardous Air Pollutants: Areas Source
Standards for Paints and Allied Products Manufacturing

Public Hearing

Environmental Protection Agency – Research Triangle Park

July 16, 2009

Good morning, I am Lori Leffler, and I am the Plant Manager of the PPG
Greensboro Powder Facility. 

The first concern I have with this rule is that we are trying to figure
out how our powder plant is going to comply with this rule, especially
since the rule seems to be written more from a liquid coating
perspective. While we do have premix/assembly operations which may
include pigment additions, powder plants do not really have process
vessels. In addition we utilize particulate baghouses as part of the
process to collect powders, however these do not vent to the atmosphere
so we anticipate that these particulate filters are not applicable. 

We are concerned about the provision in the proposed rule where if the
proposed standards are applicable to a facility then the proposed
standards apply to all organic and particulate HAP emissions – not
just the Urban HAPs of concern. This is problematic especially for a
powder plant – will covers be required on our operations even though
we don’t have organic volatile emissions. We recommend this provision
be dropped or limited to only equipment that is in Urban HAP service. 

It is important to note that our Greensboro plant has been operating
under a state permit so this rule will not reduce any additional HAP
emissions but will increase recordkeeping burden.  Most paint facilities
that have particulate controls don’t have opacity limits. They
especially don’t have limits as stringent as the proposed 5% opacity
limit. NPCA reviewed the operating permits in the proposed rule docket
and out of the 44 facility permits, only three facilities had a 5%
opacity requirement. The remaining 41 facilities either had no
requirement at all or were 20% opacity or greater. Given this, I believe
that EPA’s proposal of 5% is arbitrary and not in line with the
reality on the ground. We believe that a 30% opacity is much more
reasonable (Lori what is your facility’s opacity limit?) 

Also, give the burden associated with Method 9, we suggest that EPA
allow for an alternative or modification to Method 9 that has been
widely implemented across the country. This alternate method uses
observation and reporting techniques very similar to Method 9 except
that an uncertified observer would be permitted to make an initial
determination of any visible emission. If a visible emission is
identified, then corrective measures must be taken. If more than a trace
of visible emissions persists after maintenance has been completed, the
facility must either determine whether the emission limit is being
exceed using a certified observer - or shut the process shut down. We
have a similar method in place at our facility and suggest that EPA
include this in the final rulemaking (Lori please elaborate on the
method if you could, benefits, etc.). 

Finally, as I mentioned earlier, we already have been complying with a
state permit for years, this rule will not result in any further
emission reductions but will require my personal to complete additional
burdensome recordkeeping, EPA should somehow limit the burden on
facilities that already have controls and state permits – we suggest
EPA allow these facilities to just continue with their current state
permit conditions without additional recordkeeping and reporting
requirements.      

