Stakeholder Meeting with American Coatings Association for Industrial Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
February 23, 2022
Subject
New Source Performance Standards (NSPS) Review for the "Surface Coating of Plastic Parts for Business Machines" Source Category
Stakeholder
FM Corp. (Ivonne Salinas); Affinity Consultants (Keith Gaydosh); Xerox (Danelle Giannini, Benjamin Sperr, Marcus Lathrop, Jean VanEpps); American Coatings Association (Heidi McAuliffe), Sherwin Williams (Steve Kerr).
EPA in attendance
Lisa Sutton, Keith Barnett, Elineth Torres
ERG in attendance
Bryan Lange

Presentation:
EPA's Lisa Sutton presented a 20 slide PowerPoint presentation that outlined the purpose of the meeting, regulatory schedule, and discussion topics. That presentation in attached to this PDF file. 
EPA is soliciting information on how a new product line would be designed. Presumably owner operators would consider a concentration that of explosive and occupational exposure limit before it is designed and constructed. EPA will prove a separate file documenting the design parameters used to create a model plant used to estimate the cost of each regulatory options. 
Stakeholder Insights and Questions:
1. FM Corp. had the following question about applicability: 
      FM Corp. has a single customer whose coated items seem to be subject to Subpart TTT. Specifically, we mold and paint the parts that are shipped to a manufacture of 3D printers. The printer manufacturer assembles the parts.  Does that fit into the scope of this rule? 
      Further, the 60.721 definition of business machine "such as" list include photographic equipment and a 3D printer is clearly not a photocopier. The 3D printer uses a liquid polymer base that is stacked to form an item. 
EPA Response: This is not the forum for an applicability determination. If you submit a public comment on this proposed rule, then EPA will respond. EPA appreciates your situation given that the Standard Industrial Classification (SIC) codes are no longer used by the U.S. Department of Labor. 

EPA is targeting June 1, 2022, for publication of the proposed rule. Typically, there is 45-day comment period. We would appreciate your comment on how the definition might need to change. 
2.  FM Corp. will have to look at the regulatory option #1 which reduces the coating VOC limit from 1.5 kg of VOC per liter of coating solids applied to 0.95 (slide 16) to see if we can comply with that option. 
EPA Response: Understand that the proposed revision would apply to facilities that are new, modified, or reconstructed after the date that the final rule is published (EPA is targeting June 1, 2022). A source that is currently subject to the NSPS will continue to be subject unless it adds a new product line, or the existing product line is modified or reconstructed. 
3. The facility emission totals (slide 12) how were those calculated? 
EPA Response: The emission totals are from recent operating permits. EPA acknowledges these limits (e.g., FM Corp.'s 95 tons of VOC per year) could be designed to avoid becoming a major Title V source. EPA also acknowledges that VOC surface coating content limits do not translate into an annual emission rate. If EPA misrepresented any facilities VOC limits, then let us know and EPA will consider revising the emission rate for the model plant.
4. Will there be a provision in the proposed rule will allows the regulated entity to demonstrate that add on-controls are cost prohibitive? 
EPA Response: The EPA is considering a range of options. One option is coatings with a VOC content lower than they current rule. A second option is add-on controls. EPA will consider costs and environmental impacts to determine the best system of emission reduction (BSER). Facilities would have to meet that BSER emission limit. How a facility meets that BSER limit is up to them i.e., compliant coating. Helping EPA to accurately estimate cost helps EPA make well informed decisions. Further, it is better to make revision to costs before the rule proposal.
