Facility Contact with Xerox in Webster NY - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
November 10, 2021
Subject
Data collection
Stakeholder
Ms. Danelle Giannini
(585) 422-0770
Danelle.Giannini@xerox.com
EPA in attendance
-
ERG in attendance
Bryan Lange
ERG Mission:
The Clean Air Act requires the EPA to periodically review and revise its federal rules. We are asking for your help with this requirement for the NSPS Subpart TTT (Surface Coating of Plastic Parts for Business Machines). Xerox, out of Webster NY was identified in an EPA database as subject to Subpart TTT. We collected your NY air permit and have confirmed the NSPS applicability. 
We have prepared a short telephone survey for facilities that are subject to this rule. We hope to learn more about the impact of the 1988 rule, ways it might be improved for future facilities, and to look for innovation in the control of air pollution (e.g., new add-on control technologies, new work practices or operational procedure).  After the call we can share with you a copy of the minutes and discuss any necessary changes.
 Describe your business and surface coating process and approximately what fraction of your operation is used to coat plastic parts for business machines:

Ms. Giannini:  Xerox applies spray coatings to plastic parts in operations at the Joseph C. Wilson Center for Technology in Webster, NY, that are subject to 40 CFR Part 60 Subpart TTT (Standards of Performance for Industrial Surface Coating: Coating of Plastic Parts for Business Machines).  We manufacture and remanufacture Xerox products, which involves making exterior panels look new again by re-painting them. One of the products we remanufacture is the multifunction machine Nuvera. A print-shop might use this large machine to produce a magazines or mailers.  [Upon hearing that Xerox is the only manufacturer in the US with Subpart TTT applicability:]  I'm surprised that our peers aren't also on your call list (e.g., HP, IBM, Lexmark) because what we are doing isn't unusual. Although our peers might be using job-shops to do this remanufacturing.
These remanufactured products are high-value, we typically take the product back from a customer. If the configuration is up-to-date then we do cosmetic repairs sell it as used equipment or the "wear-parts" can be replaced and it is sold as new. If the configuration is out of date, then we might salvage components like the door panel. It is recycling, but the business phrase we use is the circular economy. 
We also paint metal parts, though these do not fall under Subpart TTT applicability. It's hard to estimate the plastic fraction of our total operations because I don't know the typical product weights, but the square footage dedicated to the surface coating of plastic, relative to our permitted space, is less than one percent.
I can't quantify the annual (or weekly) remanufacture throughput. 
[Response to interviewer question regarding whether we have a video of the remanufacturing operation.]  We don't have promotional videos that explains our process, but perhaps we should make one. Our customers are often interested in the remanufacturing. 
 We found your facility in a database indicating it is subject to NSPS subpart TTT (i.e., Surface Coating of Plastic Parts for Business Machines). Have you implemented any procedures or VOC control technologies to comply with that rule?

Ms. Giannini: We are not using VOC controls for the VOC emissions that result from the VOC content in the surface coating of plastic parts. Our business operations are able to maintain compliance by using compliant coatings.  We have procedures to ensure we use only compliant coatings to comply with the NSPS subpart TTT VOC limits of 1.5 kg VOC/liter of coating solids or 2.3 kg VOCs/liter of coating solids, depending on the appropriate coating type. The area where we coat plastics is separate and dedicated. Other than recordkeeping of the quantities of paints used (and the use of complaint coatings), there are no other activities required to comply with subpart TTT.  Control device infrastructure is not required to meet Subpart TTT requirements as they are currently written.
We don't use specialty coating to impart special properties like anti-static. 
In the past 5-years, we have not significantly expanded our remanufacturing products and have not had to reformulate a custom color. We use a single supplier to supply our compliant coatings, and have not experienced any issues with being about to obtain the needed compliant coatings.  VOC content is included in our design specifications.
What happens next?
Mr. Lange: EPA is looking for innovation in the control of VOC. We identified three states that have VOC emission limits more stringently than the NSPS (i.e., Michigan, Indiana, New York). Matching these State limits is a regulatory option. An important part of any rule change is estimating the cost to industry. The information I'm collecting today will improve the accuracy of our model plant costs. Our conversation will be part of public record and I'll let you know when the draft rule change is published in the federal register. Comments from the public are welcome at that time.
Ms. Giannini: Given that we operate in the state of New York, we would already be meeting those lower New York limits. Given our low volume of coating that falls under Subpart TTT applicability, any changes resulting in additional VOC control requirements may be unduly burdensome on the company.

 If you were building a new plant in a different location to address a growing demand applying surface coating to plastic parts for business machines, how would it be different?

Ms. Giannini: If we were unable to meet our production volume targets in our existing footprint then we would largely duplicate our existing operations and processes. 
I should note that the remanufacturing of small machines does not occur at the Webster, NY location. If we were to remanufacture small machines (including the painting of plastic parts), it might be more suited for a job shop rather than an on-site operation.
