MEMORANDUM

DATE:	July 17, 2009

SUBJECT:	Summary of June 23, 2009 Teleconference with the Technical
Subcommittee for the Small Business Ombudsman/Small Business
Environmental Assistance Programs (SBO/SBEAP)

FROM:	Bradley Nelson, EC/R Inc.

TO:	Melissa Payne, EPA/OAQPS/RDPAG

I.  Purpose of Meeting

The purpose of this teleconference was to discuss the proposed Paints
and Allied Products Manufacturing Area Source NESHAP.  

II.  Attendees

Melissa Payne, EPA	Todd Nein, OH

Jan King, EPA	Barbara Johnson, KS

Paula Zampieri, EPA	Jeremy Duis, KS

Bradley Nelson, EC/R 	Linda Sadler, TN

Renee Bashel, WI	Sarah Walls, NCAP

Leslie Churilla, GA	Tony Pendola, NC

Jackie Sims, IL	Charlie Adams, TX

Kim Grosenheider, MN	Joni Canterbury, CO

Joan Meitl, ID	Deanna Moultrie-Jackson

Rick Carleski, OH	Lester Facey



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.

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 refill
ink cartridges for printers.  Again, Melissa responded by saying that
was not the intention of the proposed rule, but if the reseller produces
the ink from raw materials then they may be covered.  

A member of the small business group asked what would sources within the
source category need to do if they do not use any of the listed HAP
(cadmium, chromium, lead, nickel, benzene, methylene chloride).  Melissa
responded that these sources would be required to submit a one time
notification that they are not affected by the rule.  Another group
member stated that the proposed monitoring, reporting, and recordkeeping
requirements appear to be similar to Title V requirements and are
onerous and time consuming.  Another group member believes that the
requirement to do Method 9 testing for compliance is expensive and may
have a high margin of error due to the low visible emission from the
particulate control device.  In addition, Method 9 requires the visible
emission reader to be certified, which also increases expenses to the
facility.  A different group member suggested that Method 22 could be
used as a substitute for Method 9. 

Melissa stated that EPA was still hoping to obtain additional
information on the paint and allied products manufacturing category
through the request for information as written in the proposal.

ATTACHMENT A

Paint and Allied Products Manufacturing Area Source NESHAP Presentation



 

 

 

 

 

 

 

 

 

 

 

 

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