June 19, 1997 Meeting Summary--Plastic Parts Stakeholder Meeting 1.0 PURPOSE This meeting was the initial stakeholders meeting in the beginning stages of the MACT development process for the surface coating of plastic parts. The agenda for the meeting is included as attachment A. 2.0 PLACE AND DATE US EPA Environmental Research Center Alexander Drive Research Triangle Park, NC June 19, 1997 9:00 a.m. 3.0 ATTENDEES The attendees, along with those who participated through a conference call, are listed in table 1. Although a show of hands indicated a majority of participants were involved in the Automobile/Heavy Truck sector, a few representatives of Business Machines and Miscellaneous Plastic Parts sectors also attended. 4.0 DISCUSSION The Environmental Protection Agency (EPA) representative opened the meeting with introductions. The EPA summarized the goals for the first few months of the MACT development process, as shown in attachment B, and listed the long term schedule for the development of the MACT rule: MACT Long Term Schedule Complete data gathering 12/98 Determine MACT floor & select options 2/99 Prepare draft proposal 6/99 Proposal in Federal Register 12/99 Final Rule in Federal Register 11/2000 Attendees in the Miscellaneous Metal Parts stakeholder meeting on June 18, 1997 had raised concerns over the P-MACT process and the October 1997 time frame for reaching decisions. As shown in attachment B and the long term schedule above, EPA restated that P-MACT is the earliest stage of rule development and is a vehicle to identify issues and to start the data collection phase of rule development. The EPA asked if industry participants who had not attended the Miscellaneous Metal Parts meeting had questions or comments about the P-MACT process. There were none at this time. Sections 4.1 to 4.5 of this memorandum summarize the discussion under each agenda topic (attachment A). Section 5 summarizes the issues noted for further data collection or discussion. 4.1 Meeting Objectives The EPA stated the meeting objectives as follows: review EPA preliminary data collection efforts, identify sources to help fill remaining data gaps, present options for questionnaires, and discuss the formation of issue work groups in the future. 4.2 Understanding of Industry Sectors The EPA described the four major sectors covered the plastic parts surface coating source category: (1) Automobile, Light Duty Truck, and Other Automotive; (2) Heavy Duty Truck; (3) Business Machines; and (4) Miscellaneous Plastic Parts. The EPA's characterizations of the automobile and light duty truck sector, business machines sector, and miscellaneous plastic parts sector are taken from the Alternative Control Techniques Document: Surface Coating of Automotive/Transportation and Business Machine Plastic Parts (ACT). Information gathered on EPA's recent site visits to three heavy duty truck manufacturing facilities was used to describe the heavy duty truck sector. Miscellaneous plastic parts is currently the least well characterized sector. Although EPA has contacted several toy and other miscellaneous part manufacturers, these contacts have explained that their operations consist of importing finished products or using plastics with molded-in colors. The EPA asked the meeting participants for assistance in identifying coating operations or trade associations in the miscellaneous sector. Industry participants agreed that it is a difficult task to characterize the miscellaneous sector. No one was aware of any relevant trade associations. One industry representative voiced concern over the inclusion in this regulation of the application of inks for logos on plastic containers. The EPA responded that the Plastic Parts surface coating rule will not cover the use of inks. This issue might require coordination and discussion with other MACT standard projects. Attendees indicated that EPA's list of suggested coating categories is incomplete. Automobile, Light Duty Truck, and Other Automotive should include a no bake category for interior and exterior coatings and a radiation curing category for headlights and wheel covers. Heavy Duty Truck should include categories for stripe coatings for "wet on wet" and "wet on dry" applications, pretreatment coatings, UV coatings, and repair coats. Business Machines should include categories for reconditioning and repair operations. Miscellaneous Plastic Parts should differentiate between inks and coatings. The EPA stressed the need to identify more representatives from the business machine and miscellaneous sectors to contribute to their understanding of these coating categories and their respective technologies. 4.3 Data Collection Status Report The EPA's contractor for the development of plastic parts regulations, Eastern Research Group (ERG) described data collection activities to date for plastic parts regulation development. ERG had performed searches of the following databases: the Aerometric Information Retrieval System (AIRS), the Toxic Release Inventory (TRI), and the Source Test Information Retrieval System (STIRS). In addition, ERG presented a summary of plastic parts surface coating rules in 13 states. The meeting handouts included examples of TRI data, AIRS data, and a draft summary of the State rules. Some industry representatives raised serious concerns about the TRI database, describing a search of TRI as "not a worthwhile activity." Some attendees raised the concern that Material Safety Data Sheets (MSDS) are used to develop databases such as TRI. The participants noted that the MSDS are only "modestly accurate," and hazardous air pollutants (HAPs) are not necessarily speciated. A representative from the automotive sector pointed out that the standard industrial classification (SIC) 3714-Motor Vehicle Parts and Accessories was missing from EPA's SIC list. Attendees asked for clarification on the inclusion of source category codes (SCC) regarding combustion in the plastic parts MACT rule. The EPA responded that Dave Salman is currently investigating the overlap with the Industrial Combustion Coordinated Rulemaking (ICCR) Committee. He will report his findings to the eight P-MACT groups. Industry representatives suggested several universities that have excellent polymer programs that may provide EPA with more information about coating technology: (1) University of Akron, (2) University of Cincinnati, (3) Case Western, and (4) University of Massachusetts. In conclusion, the attendees indicated that these data bases are incomplete and of limited use for characterizing emissions from the plastic parts coating industry. The EPA agreed that these data bases are not intended to provide a complete emissions profile of the plastic parts industry. Rather, they provide initial indications of some of the species emitted and their magnitudes, and names and locations of plastic parts coating facilities. 4.4 Questionnaires The EPA briefly discussed the regulatory requirements, the general structure, and the options for sending out questionnaires to industry. The EPA briefly explained their procedures for handling data that are classified as confidential. The EPA informed the group about the requirement for Office of Management and Budget (OMB) approval of questionnaires that go to more than nine respondents and the possibility of using the generic MACT questionnaire that has already been approved by OMB.. The EPA's draft site-visit questionnaire was presented as an example of the types of information likely to be regulated. Discussion of the draft questionnaire raised several issues. These issues are summarized as follows. The participants see a clear need to coordinate the development of the eight MACT standards, particularly where there is a potential for overlap in standards applicability. The EPA stated that the eight project leads meet on a regular basis and that they are tracking overlapping issues. In addition, efforts are being made to reduce the participation and information collection burden on the industries by coordinating site visits and requests for data. For example, the miscellaneous metal parts and plastic parts, an groups are coordinating their site visits and development of their questionnaires. An industry representative asked about the expected response time for questionnaires. The EPA stated that six weeks to two months is generally allowed for completion. Some industry representatives noted that six weeks is not enough time for extensive questionnaires. Particular concern was expressed for small businesses. Attendees raised concerns that response to a questionnaire would be used by the enforcement branch at EPA. The EPA responded that, although the Emissions Standards Division (ESD) and the Office of Enforcement and Compliance Assurance (OECA) both gather information under the authority of section 114 of the Clean Air Act, regulatory development information is not routinely shared with OECA. The EPA participants noted that they were not aware of any instances of information gathered for regulation development being used for enforcement purposes. A few industry representatives stated that Title V applications are the best source for data as well as for questionnaire format ideas. The EPA agreed and noted that the Heavy Duty Truck sites that were visited in early June have provided their Title V permit applications. It was noted that Title V permits have not been issued in some states, and therefore only the applications may be available. In addition, many Title V applications are hundreds of pages long. Ideally, EPA would like to collect only the information in the applications that is relevant to coating operations (e.g., flow diagrams, process descriptions, emissions data, and control technology information regarding coating operations in particular.) One industry representative suggested tailoring questionnaires to each State to reflect the permit application format in that State. The draft site visit questionnaire includes questions about the facilities waste handling practices. Some participants questioned EPA's need for this information in regulating HAP emissions. The participants stated that facilities do not monitor HAP contents of waste streams, and requests for such data would be very burdensome. The EPA responded that the MACT standards are intended to address all sources of HAP emissions from regulated sources. However, EPA's site visit questionnaires may request only qualitative information regarding waste handling procedures. Some attendees raised the concern that some facilities could have hundreds of coatings to report on for table 2 of the draft site visit questionnaire. The EPA defined the reporting scope to include the top 10 to 15 coatings used at a facility that account for at least 90 percent of the total usage. Questions were raised regarding what source to use for reporting coating contents. It was pointed out that Material Safety Data Sheets (MSDS) do not necessarily provide complete data on HAPs and VOC. This issue is relevant to all of the coating projects and is further discussed in section 5.0 below. Attendees also stated that the process of responding to questionnaires would be greatly enhanced if the following suggestions were followed: (1) The language, terms, and format are modeled after Title V applications, (2) data are reported in English units instead of metric (EPA to make the conversions), and (3) The Small Business Assistance office be involved to help small businesses with the completion of these questionnaires. Industry representatives stressed the necessity of considering individual coatings as part of a coating system. They pointed out that, for example, the lowest VOC primer, colorcoat, and clear coat cannot necessarily be used in conjunction. Consideration must be given to compatibility between the substrate and the coatings as well as between the different coatings. Performance requirements must also be considered. Industry representatives noted that the plastic parts ACT document's automotive coating categories are a good example of a coatings systems approach (e.g., high bake and low bake systems, and flexible and non-flexible systems). Attendees asked if the definitions used in the site visit questionnaire would be common for all MACT questionnaires. The EPA explained that the definitions attached to the draft site visit questionnaire are intended only as an aid to responding to the questionnaire. Definitions that will be included in the regulations will be developed at a later date. The definitions contained in the plastic parts ACT document will be the starting point, and definitions will be coordinated with the other coating MACT standards to the extent possible. 4.5 Discussion and Formation of Issue Work Groups The EPA introduced the idea of issues work groups to contribute to the information gathering process. Participants agreed that the next stakeholders meeting will be an appropriate time for the formation of issue work groups. The Issue Work Groups formed during the Miscellaneous Metal Parts meeting are the models for future development: (1) Scope and definition, (2) Source/source sizes, (3) Information collection, (4) Flexibility/overlap issues, (5) Consistency of MACT rules, and (6) Recordkeeping. Participants suggested that the issues work groups for automotive plastic parts work with their counter parts for automotive miscellaneous metal parts. 5.0 ONGOING ISSUES During discussion of some of the Agenda topics, additional questions and issues were raised but could not be resolved within the scope of the stakeholder meeting. These issues are noted below and will be addressed during the MACT development process. Cleaning operations -- Emissions from solvent cleaning activities associated with coating operations will be considered in the standards development process. The EPA will be collecting information on HAP and VOC emissions from clean-up operations. Control of VOC emissions from clean-up operations is addressed in EPA's Alternative Control Techniques Document: Solvent Cleaning. Reporting coating contents -- The EPA's questionnaires and other data gathering efforts will focus on the HAP and VOC contents of coatings. As noted in the questionnaire discussion in section 4.3, the VOC and HAP content of coatings are not always readily available, and industry participants expressed concern as to how to respond to requests for this information. This question has been raised for other MACT projects as well. MSDS often list contents as a range of percentage by weight or volume, or list minor constituents as "less than" some de minimis (e.g., less than 0.1 percent). HAP and VOC contents are not always speciated. Some coaters receive confidential MSDS from their coating suppliers. While these MSDS may list more complete contents, the coaters have signed agreements not to share the information with third parties. Spray design information, or formulations, are also sometimes distributed to some coaters but are apparently not available for all coatings. A cooperative effort between EPA and the Chemical Manufacturer's Association (CMA) is under way to develop Certified Product Data Sheets that would satisfy EPA's need for solvent content information and would also be acceptable to solvent manufacturers and users. However, these data sheets are under development and are not expected to be available within the time frame of P-MACT. The EPA needs to determine the most appropriate available source and format for coating content data. Any requests for coating content data will include specific instructions on acceptable sources. Requests will also be coordinated across coating projects to the extent practical. Measurable HAP contents -- Participants pointed out that a particular HAP may be present in a coating in such small quantities that it is not reported in MSDS or formulations, but measurable quantities of the HAP may be detectable in stack tests due to the quantity of coating used. Such potential discrepancies should be considered in the determination of P-MACT as well as the MACT floor. Reports of emissions data -- The miscellaneous metal parts stakeholder meeting (June 18, 1997) included discussion of how to report sources' VOC and HAP emissions in questionnaire responses. Industry participants suggested reporting their permitted limits rather than their actual emissions. In some cases permit limits may be useful, but actual emissions are likely to be needed as well, for example to identify the best performing sources. The EPA will specify in its requests for emissions data whether actual, potential, or permitted levels are to be reported. Table 1. Plastic Parts Coating P-MACT Meeting Participants Organization Participant Phone # Fax # EPA/ESD Linda Herring (919) 541-5358 541-5689 EPA/ESD Ellen Ducey (919) 541-5408 541-5689 EPA/ESD Dave Salman (919) 541-0859 541-5689 EPA Region IV Karen Borel (404) none 562-9019 Michigan DEQ Bob Irvine (517) 373-7023 335-6993 Jefferson Co. Air Board (STAPPA/ALAPCO) Bruce Gaylord (502) 574-6000 574-5306 Eastern Research Group Joan McLean (919) 461-1218 461-1418 Eastern Research Group Greg D'Angelo (919) 461-1522 461-1418 Eastern Research Group Michael Bryant (919) 461-1215 461-1418 TRC (TMA Contractor) Jim Serne (919) 419-7591 419-7501 Ford Motor Company Cathie Jo Seamon (313) 390-3799 248-5030 General Motor Corporation Bob Fedorko (313) 556-7620 556-7629 Nissan Motor Manufacturing Gary Ewing (615) 459-1633 355-2303 AAMA1 Gene Prachan (919) 547-7100 547-7102 AIAM2 Tara Vizzi (703) 525-7788 525-8817 BASF Sharon Finn (810) 948-2000 Dupont Karl Schultz (302) 992-2372 892-1143 Dupont Stan Horvath (248) 583-8037 583-4555 Lilly Industries Sherry Stookey (910) 802-4305 889-6005 PPG Dave Mazzocco (412) 492-5476 492-5377 Red Spot Paint/Varnish Mark Lutterback (812) 428-9131 428-9167 Sherwin Williams Company Madelyn Harding (216) 566-2630 566-2730 Sherwin Williams Company Marc Kruzer (216) 566-6546 566-2508 Fusion UV Systems Chris Brandl (810) 231-5700 231-3688 Rad Tech International Alexander Ross (703) 534-9313 533-1910 NPCA3 Bob Nelson (202) 462-6272 462-8549 Worthington Industries Matthew Johnston (614) 438-7960 438-3171 EIA/CEMA4 Brooke Robel (703) 907-7600 907-7501 Berry Environmental (ASTM) 6 Jim Berry (919) 785-9631 785-9631 Van Ness Feldman (AIAM) 2 Dick Penna (202) 298-1870 338-2416 1AMMA = American Automobile Manufacturers Association 2AIAM = Association of International Automobile Manufacturers, Inc. 3NPCA = National Paint and Coatings Association 4EIA/CEMA = Electronic Industry Association/Computer Equipment Manufacturers Association Attachment A AGENDA FOR PLASTIC PARTS P-MACT STAKEHOLDER MEETING JUNE 19, 1997 1. Meeting objectives: - Obtain stakeholder response to EPA preliminary data collection and industry sector characterizations. - Obtain recommendations for filling data gaps - Introduce EPA's options for industry questionnaires - Formation of issues work groups 2. EPA presentation on current understanding of industry sectors - Heavy duty truck manufacturers - Other automotive - Business machines - Miscellaneous parts: toys; sporting goods; flexible flooring; windows, doors, and shutters; plastic bottles/containers and caps. Further characterization of the miscellaneous sector is needed. Discussion of industry sector divisions and characterizations 3. Data collection status report (See Attachment A) - Explanation of need and intended use for different types of data; - Air emissions: Aerometric Information Retrieval System (AIRS), Toxic Release Inventory (TRI); - Test data: Source Test Information Retrieval System (STIRS); - Site visits; - State regulations; - Literature search. Discussion of data sources, current data gaps, and site visit opportunities. 4. EPA presentation on available options for questionnaires - What is an Information Collection Request (ICR) - Review and approval by the Office of Management and Budget (OMB) - The generic ICR for MACT development - Options for developing a coating-specific questionnaire - Industry administered survey possibilities - Schedule/timing for the plastic parts questionnaire Discussion of questionnaire options and opportunities for stakeholder input. 5. Discussion and formation of issues work groups: (See Attachment B) 6. Next steps - Schedule for collection of data from stakeholders - Coordination of issues work groups - Availability of meeting summary - Tentative dates for next stakeholder meeting Attachment B Goals by October 1997 Understand industry coating processes Identify typical emission points Identify/involve representatives for each industry segment Coordinate/develop plan to address overlap among MACT sources Determine Scope Locate major sources Identify existing controls Develop questionnaire Complete informational site visits Identify issues/develop plan for resolving