MEMORANDUM

DATE:	July 17, 2009

SUBJECT:	Summary of July 14, 2009 Teleconference Briefing with
State/Local Representatives

FROM:	Bradley Nelson, EC/R Inc.

TO:	Melissa Payne, EPA/OAQPS/RDPAG

I.  Purpose of Meeting

The purpose of this teleconference was to brief State/Local
representatives on the proposed Paints and Allied Products Manufacturing
Area Source NESHAP.  

II.  Attendees

The attendees to the webinar are presented in the accompanying sound
recording.

III. Summary of Meeting

Melissa Payne began the meeting by presenting a brief summary of the
proposed area source Paints and Allied Products Manufacturing NESHAP. 
The summary included a brief introduction of the source category, a
description of the manufacturing process and emission points, and a
discussion of the proposed rule requirements.  A copy of the
presentation is provided in Attachment 1.  It was noted that a public
hearing was held on June 16, 2009, which meant that the comment period
had been extended until July, 16, 2009.  In addition, Melissa told the
group that the court ordered promulgation date for the Bin 6 rules had
been extended until October 15, 2009.

Melissa then opened the floor to questions from the group.  A member of
the group asked if the rule applied to home improvement stores like Home
Depot or Lowes, where small amounts of pigments are added to the paint
to obtain the proper paint color.  Melissa responded by saying that was
not the intention of the proposed rule.  The rule is intended to
regulate the larger companies that manufacture the paint or allied
products.  Another member asked if the rule was intended to cover
manufacturers of polymers used in paint manufacturing.  Again, Melissa
responded that the proposed rule was intended to only cover paints and
allied products manufacturing and is not intended to regulate the
manufacturers of raw materials used in paints and allied products
manufacturing.   

A representative asked if there was a specific form to complete for
initial notification and when did the form need to be submitted. 
Melissa responded that the instruction and due dates were provided in
the proposed rule.  Melissa added that only affected sources were
required to submit the initial notification form.  Another
representative believes that requiring EPA Method 9 test every six
months is excessive and costly, and believes there are alternative
methods that could be used, such as EPA Method 22.  

One representative asked whether a source that already was using a
thermal oxidizer to become a synthetic minor source would still need to
use lids or covers.  Melissa responded that they should submit this
question to the docket so that EPA could provide a formal response. 
Another representative asked how a source monitored a cartridge filter
particulate control system that does not vent to the outside.  Melissa
asked the representative to provide this comment to the docket so that
EPA can prepare a formal response to the comment.  A representative
asked if the listed HAP chromium was total chromium or hexavalent
chromium.  Melissa responded that chromium was total chromium.

Melissa ended the meeting by asking if any of the representatives had
any questions or comments that they should submit them to the docket. 

ATTACHMENT A

Paint and Allied Products Manufacturing Area Source NESHAP Presentation



 

 

 

 

 

 

 

 

 

 

 

 

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