Stakeholder Meeting with The Sherwin-Williams Company, for Industrial Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
December 7, 2021
Subject
Data collection
Stakeholder
Steve Kerr, of The Sherwin-Williams Company. 
EPA in attendance
Lisa Sutton
ERG in attendance
Bryan Lange

Mission:
The Clean Air Act (CAA) section 111(b)(1)(B) requires the EPA to "at least every 8 years review and, if appropriate, revise" New Source Performance Standards (NSPS). We are asking for your help as we comply with this CAA requirement for the NSPS Subpart TTT (Surface Coating of Plastic Parts for Business Machines). Our goal is to improve the 1988 rule and look for information on developments in VOC pollution control (e.g., new add-on control technologies, new work practices or operational procedure). Just as important is understanding the business trends, specifically is a population of facilities in the U.S. that are actively painting plastic parts for business machines or has molding improved such that it rarely done. 
First note, is that the reg. text defines a business machine in 40 CFR 60.721 as a device that uses electronic or mechanical methods to process information, perform calculations, print or copy information, or convert sound into electrical impulses for transmission and six (6) SIC codes are listed. It is an open question what equipment should be included in today's definition of business machines (e.g., grocery store scanners, ATM machines).
3572  -  Typewriters
3573  -  Electronic computing devices
3574  -  Calculating and accounting machines
3661  -  Telephone and telegraph equipment
3579  -  Office machines, not elsewhere classified
3861  -  Photocopy machines, a subcategory of products classified as photographic equipment

The original NSPS Subpart TTT evaluated what controls were available and then did an environmental benefit analysis to determine if control costs were reasonable. Those costs did not represent a particular plant but were based on models. 
This NSPS Subpart TTT review will address business machine coating lines that come on-line after June 1, 2022 (i.e., the target proposal date specified in the consent decree). EPA will identify the best performer among the existing facilities that are currently subject to the NSPS (promulgated in 1988). EPA will also look at other available controls and costs to determine if tighter standards are appropriate. Cost calculations will likely be based on new business machine coating lines at model facilities.
NSPSs apply to all sources regardless of size. Conversely, NESHAPs (e.g., Part 63 Subpart PPPP for plastic parts) apply only to major HAP sources. Preliminary research shows the Subpart TTT source category mainly includes facilities that are area (non-major) sources of HAP.
The schedule is set by the consent decree. Specifically, the proposal must be signed by June 1, 2022. EPA hopes to identify the population of existing facilities by the end of 2021.
Data collection, to date:
EPA got your name and number from Frank Bumgarner with Mack Molding in Statesville, NC--a job shop with NSPS subpart TTT included in their air permit. 
Legitimacy:
Steve Kerr has been with Sherwin-Williams (by way of Valspar) for 22 years, starting in a health safety & environmental role and then in a product stewardship role for the performance coating group (e.g., general industrial coating, electronic). 
Sherwin-Williams staff were largely unaware of this NSPS Subpart TTT regulation. 
EPA Questions:
 Frank Bumgarner said that in the 1980s, all plastic parts of business machines were painted. It's our understanding that today, there is more sophistication with colored and textured materials (e.g., plastic molding) so that paint is not needed. 
 Does Sherwin-Williams have firsthand knowledge of business machine manufacturing surface coating trends?
   b.	Can you confirm that trend or transition and provide any insights?
   c.	Is surface coating still a necessary process for business machine manufacturing?
Over the past 30-years, much of manufacturing has gone outside of the US. There is still a market for the plastic parts (e.g., medical equipment, game consoles, consumer electronics, appliances), and the coatings sold for plastic parts represent an important market for Sherwin-Williams. Most of this coating application is done at job-shops (i.e., not the original equipment manufacturer). These job shops are not specialized to businesses equipment coatings, they may be specialized to plastic parts, but likely coating multiple materials (e.g., metal, plastic). Overall, the market has declined.
    
 Does Sherwin-Williams sell pigments or dyes or provide other support for colored plastic molding?
Sherwin-Williams does not sell pigments or dyes that would be an input in plastic molding. Sherwin-Williams can corroborate your findings. First, in the 1980's, the quality of extruded parts was lower, and coatings were used to cover up imperfections and surface defects. Second, plastic parts are now commonly molded in the end color.
 Does Sherwin-Williams sell powder or electrostatic surface coating materials?
   a.	What is the current state of the technology for powder coating plastic parts, such as the use of UV cured powder coating?
   b.	Besides electrodeposition coating, are there other similar ways to improve transfer efficiency for coated plastic? Are there no spray application methods feasible, e.g., dip or curtain coating?
    
Sherwin-Williams is heavy into powder coatings, but we don't sell powder coatings for the plastic parts end use.
For plastic parts, our products are mostly spray applied. Dip coating may be used by OEMs, for large runs. Dip coating by our customers, is uncommon because although it has a high transfer efficiency, it's color specific and the customer (i.e., job shop) couldn't easily switch colors. Steve was not aware of a job shop trade group.
 We met with David Darling (Vice President of Health, Safety and Environmental Affairs for American Coatings Association) to learn more about business trends related to business machines. He conducted an informal survey of his members and said that the manufacturing of cell phones and computers now occurs overseas, and the only domestic computer manufacturing activity is assembly.
   a.	Can you corroborate this observation?
   b.	Are you aware of any U.S. companies that are coating plastic parts for business machines?
    
 Are there specialty coatings that have an application specific to business machines? E.g., conductive lacquers and "Teflon" finishes, chemical and stain resistance coatings, or coatings designed to shield from electromagnetic interference (EMI) and radio frequency interference (RFI). 
 Do these specialty coatings have distinct composition (e.g., high solids, high VOCs, metals)?
The products Sherwin-Williams is selling to the business machine market are formulated for broad application to plastic parts. Some of those plastic parts happen to be business machines. Sherwin-Williams does not sell coatings that are uniquely formulated for business machines.
Sherwin-Williams does not sell specialty coatings with the attributes you listed; our competitors might. Further, coatings for business machines do not require unique qualities such as anti-fingerprint or anti-conductive coatings.
Sherwin-Williams has both waterborne and solvent borne coatings for this end use.
 The NSPS limit restricts VOC content to 1.5 and 2.3 kg of VOC per liter of coating solids applied. Our data collection shows states with VOC limits lower than the NSPS (e.g., NY limits are 0.26 and 0.35 kg of VOC per liter of "coating (minus water and excluded compounds) at application," or approximately 25% of the NSPS limits--but likely lower, depending on assumption of volume solids content). Attached. Do you sell coatings (intended for use on plastic parts for business machines) that exceed the NSPS (or NY) VOC limits?
In Steve's opinion, the TTT unit of measure is difficult for the regulated community because it's based on volume of coating solids applied. The vernacular of our industry is, e.g., 2.8 pounds of VOC per gallon of coating (applied, less water and exempts). To convert from that and the NSPS format, one must know (or assume) the coating's volume solids content. For example, Sherwin-Williams had to apply an assumption of 60% solids by volume to calculate that the NSPS limit of 1.5 kg VOC per liter of coating solids applied (for prime coat or color coat) is comparable to 7.5 pounds of VOC per gallon of coating applied. 
The products we sell to this market are generally at or below 2.8 pounds of VOC per gallon of coating applied. Our customers follow the limits that are in their jurisdiction (e.g., NY) when those are more stringent. Sherwin-Williams says there is no application (end use) that required a higher VOC coating.
Lisa: Well, we realize it is hard to compare the TTT emission limits (in mass of VOC per volume of coating solids applied) with the those of the plastic parts NESHAP (in mass of VOC per mass of coating solids used), because doing so requires knowing (or assuming) solids density as well as transfer efficiency. The intent of the original TTT was to encourage more efficient transfer of coatings. Do you know of any subset of customers that has some specific need we should consider? For example, are there certain applications that require a higher solvent content? Is there a price premium on a coating that meets the NY requirements vs. the NSPS standards? Could you give us a range of VOC content that is offered?
Steve: Our staff didn't identify any applications that require a high solvent content. There may be competitors that provide specialized coatings with high solvent requirements. From a manufacturer's standpoint, the larger the batch the lower the costs (i.e., we try to minimize the number of product options we offer). Therefore, we would prefer a national not regional product line. 
To see the "menu" of VOC coatings, go to the Sherwin-Williams general industrial website: https://industrial.sherwin-williams.com/na/us/en/general-industrial/catalog/category/products-by-industry/electronics/business-machines.10656533.html. When you apply a product filter for "Plastic Substrate," you'll find four liquid products and they are in the range of 2.3  -  2.8 pounds of VOC per gallon of coating (as applied). Having the flexibility to manufacture coatings with a higher VOC content is better and our customers might say the same. Some applications, such as for use as an adhesion promoter (primer), might justify a coating with a higher VOC content like 3.5 pounds per gallon of coating applied (which is an option for one of the four products).
One of the key attributes to our products is color matching, the color on the other components (e.g., metal case for a computer) needs to be the same color on the coated plastic face. 
   
 If EPA does not modify the NSPS VOC limits, then sources can continue to meet the "old" limits and incur zero "new" costs. EPA is also considering VOC limits that are consistent with NY. Do you have any information that would help us quantify the new costs to a facility (e.g., dollar per gallon, dollars per year with any assumptions on coating consumption)?
Follow-up:
EPA requested information on cost and transfer efficiency. 
