MEMORANDUM

TO:	Large Appliances Integrated Rule Development Project

Docket Number: A-97-41

SUBMITTED

BY:	Dr. Mohamed Serageldin

U.S. EPA/CCPG

DATE:	February 9, 1998

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SUBJECT:	Large Appliances Integrated Rule - Summary of Meeting between U.S. EPA and Stakeholders regarding Section 114 Questionnaires sent out June 10, 1997 - Presumptive Maximum Achievable Control Technology/Presumptive Best Achievable Controls (P-MACT/P-BAC) Phase

I.	Purpose

The purpose of this conference call was to clarify or explain to Section 114 Questionnaire recipients what EPA was anticipating in response to each question. The EPA also wanted recipients to have a chance to address any comments regarding Section 114 Questionnaires sent out on June 10, 1997.

II.	Location of Meeting and Participants

Place:	NC Mutual Life Building, U. S. EPA

11th Floor Conference Room

Durham, North Carolina

Date:	June 16, 1997, 2:00 p. m. - 4:00 p. m.

Participants:	See attendee list (Attachment 1)

III.	Discussion

After allowing everyone to call in, Dr. Mohamed Serageldin, U. S. EPA, began the meeting by asking if everyone had received the Section 114 Questionnaire. Mr. Tim Hooker, General Electric, responded that he had not yet received the questionnaire. Dr. Serageldin replied that it was the same questions and format as the draft questionnaire sent out earlier.

Mr. Robert (Bob) Karwowski, Whirlpool Corporation, said that he would like to make comments from the Large Appliance Industry that were based on joint agreement between industry representatives and work team members. Mr. Karwowski had faxed a summary of large appliance manufacturers comments to Dr. Serageldin on June 6, 1997 (see Attachment 2).

Dr. Serageldin responded that would be fine and asked if we could go through the questionnaire and address each question (listed numerically below) as comments warranted discussion.

Comment 1 - General

As a follow up to the May 19th roundtable meeting, the EPA was to send the DRAFT questionnaires to work team members. Work team members were to review the questionnaire and comment on the structure and format and the time requirements needed to complete the questionnaire. Due to time restrictions, the EPA was unable to send the questionnaire out for review by work team members.

Dr. Serageldin went over the general questionnaire structure and explained that responses will be specific to each facility depending on the operations at the individual facility. The intent was to provide less structure to questionnaires in an effort to allow facilities more flexibility in responding, due to the different way facilities are organized and how data is kept.

Mr. Karwowski responded that he was concerned that EPA would be getting questionnaire responses in "apples and oranges" format that would not be valuable. Dr. Serageldin replied that certain information was required in a particular manner (i.e., industry level emissions, type of paints used at the facility, etc.). He explained further that an additional questionnaire will be sent out in 1998, which will be more structured. This future questionnaire will be sent to as many companies as possible in order to obtain more specific data from facilities that fall under the Large Appliance SIC codes.

Mr. Jim Sell, National Paint and Coatings Association (NPCA), asked if EPA was going to keep the original four SIC code determinations that the NSPS rule defines for Large Appliances or add the two new SIC codes. Dr. Serageldin responded that the present definition includes all six SIC codes.

Mr. Sell asked if this would create a problem matching affected facilities with the MACT standard. He also asked if EPA had to go through the rulemaking process prior to expanding the rule since the source category was previously defined by EPA. Dr. Serageldin stated that he would rather leave this as a separate conversation. He also indicated that the work team members would be receiving a copy of the P-MACT/P-BAC draft and industry representatives would be encouraged to respond with any written comments.

Mr. Sell also commented that because the category had been expanded to include heating and air conditioning products, a large appliance is defined differently than in the original NSPS definition. Thus, the source category will be different for NSPS and NESHAP.

Ms. Linda Herring, US EPA, stated that the Federal Register Notice discussion about developing rules, states that the scope of the category could be expanded, and that the EPA is not bound by the NSPS definition. If there is a need to define a new source category, the EPA has the authority to do so. There also may be HAP emitting sources that need to be added to this category.

Mr. Sell asked for the date of this Federal Register Notice. Dr. Serageldin stated that he would have to look that information up and let him know. [Note: The reference is "Initial List of Categories of Sources Under Section 112(c)(1) of the Clean Air Act Amendments of 1990,"

(V. Descriptions of Listed Categories). Federal Register, 57 FR 31590, July 16, 1992.]

Comment 2 - Section A. General Facility Information - Number 4

The questionnaire recipients wanted to know why it was important to give detailed employment information other than total facility employment.

Dr. Serageldin explained that in some cases total number of employees per facility is not sufficient. It is especially important in determining the impact on small businesses.

Mr. Ray Rusek, Maytag, stated that the people which received the questionnaire were not small businesses. Dr. Serageldin responded that at the present they are not small businesses, but later EPA may need this information, for model plant development. EPA will need to know how many employees are required in cleaning and other areas in order to produce a model plant.

Comment 3 - Section B. Unit Operations - Number 3

The industry representatives commented that it would be impossible to list every coating used at a facility.

Dr. Serageldin explained that a list of major coatings used would be fine with possibly a sample representation of the small usage coatings or specialty coatings. This would allow the EPA to determine the magnitude of emissions from various paint types and an overview of products currently being used by industry. In the past, EPA has had to subcategorize sources based on the different types of coatings used. For example, if a facility uses 100 different coatings and only 5 are used in large amounts (represent more than 80 percent of the facility usage), these 5 coatings need to be identified in detail. The other coatings should be listed only.

Mr. Tim Hooker, General Electric, stated that some of their facilities use a multitude of touch up coatings. Dr. Serageldin asked how many. Mr. Hooker replied that some are applied with brushes like fingernail polish brushes, some are applied with aerosol cans, etc. Dr. Serageldin asked what quantity. Mr. Hooker said that approximately one gallon (3.785 liters) a year for some.

Dr. Serageldin stated that EPA needs to understand product usage per year as well as emissions per year from each source. He explained that EPA will need an idea of how much each facility uses and emissions produced because touch up operations may not be exempt. He commented that it would be very helpful if each facility could give a representative total and provide an explanation if total usage was less than 5 liters.

Mr. Hooker asked for clarification as to whether touch up will be exempt or not. Dr. Serageldin replied that there may be a limitation, since it is not known if there will be a separate limit for touch up. He stated that it will be beneficial if industry could give EPA examples and total amounts of different types of coatings used.

Comment 4 - Section B. Unit Operations - Number 6

The industry representatives were not sure what EPA wanted for this section.

Dr. Serageldin explained that EPA needed to know how waste is handled throughout the coating process. Are recycling efforts implemented? How much waste is eliminated by recycling? Are emission reduction strategies being used/achieved? Where and how is wastewater disposed of? Are there other control measures in operation at facilities? He stated that industry can give EPA what is available, no matter what format it is in (i.e., if data is available in permit format, then submit it in that format).

Comment 5. Section C. Control Measures - Number 2

The industry representatives asked if EPA realized how much effort this would entail.

Dr. Serageldin commented that this was not a rigorous and detailed request. He explained that he generated Unit Operation System ( UOS ) drawings while visiting facilities. The UOS should be a simple diagram to illustrate where emissions are being emitted. The intent is to obtain an emission estimate from each facility because the facility should know where emissions exit the system. Emission distribution is different for each facility, therefore, if a facility needs to reduce emissions, development of UOSs merely identify where emissions originate.

Mr. Rusek explained that he did not have the UOS textbook, so how will he be able to determine what makes up a UOS? He also expressed concern that the format of the data request allowed for a wide variety of responses. Dr. Serageldin replied that the text book was not required, because each company was provided with the information needed through the questionnaire instructions. Examples are provided and EPA is expecting companies to modify the UOS diagrams based on the way each facility is designed.

Mr. Karwowski commented that industry could handle stick figures, but providing UOS diagrams for each tank would be impractical. Some cleaning operations have as many as fourteen stages, not just one stage cleaning. Dr. Serageldin responded that the request was not to break up stages. For example, all cleaning stages should be presented as one diagram. EPA is not interested in each stage, just the material balance for the cleaning operation. The main idea is to provide a boundary around a cleaning unit operation1 in order to perform a material balance. He continued to explain that a manufacturing process can be naturally broken up into blocks that can stand alone thus generating the UOSs.

Mr. Dan Elliot, Trane, asked if EPA had any idea of how many man hours this questionnaire will take with the UOS diagrams or any estimated level of the effort required. Dr. Serageldin stated the effort depends on the company and how many operations they perform. This is supposed to be a short, simplified questionnaire to assist EPA in learning more about the Large Appliance Surface Coating Industry. Dr. Serageldin stated that it will depend on each facility's level of organization. Typically, ISO 14000 and ISO 9000 certified facility's information is more organized due to the reporting requirements.

Mr. Hooker commented that at GE they do not monitor production on hourly basis. Dr. Serageldin responded that if you monitor weekly, respond with a weekly estimate.

Mr. Hooker remarked that some monitoring is done on an hourly, weekly, monthly or annual basis. Dr. Serageldin asked if Mr. Hooker could explain why monitoring is weekly or monthly, and whether or not a computerized system is used.

Comment 6 - Section D Other Information - Second Paragraph

The industry representatives commented that they were not sure what defined a UOS.

Dr. Serageldin explained that EPA is requesting data in this format to allow for the eventual aggregation of emissions by UOS. This is why a UOS was defined and definitions provided, so that unit operations which are linked such as a coating unit operation2 and a drying unit operation, can be identified. He stated that a unit operation system (one or more unit operations) will be used as the organizational tool.

Mr. Karwowski replied that he was still struggling to determine what EPA wanted. Why not look at a unit as a permitted unit? Mr. Karwowski expressed concern with the level of detail involved to try and determine what EPA wants. Dr. Serageldin responded that the intent was to have industry look at a plant as a big block, then conceptually break it into departments. Each department has different activities with different work areas. Each work area performs a different activity. Therefore, you have a plant that is divided into a department, which is divided into a work area. The work area is then divided into one or more UOSs.

Mr. Karwowski wanted to know why a process flow diagram would not work. Dr. Serageldin stated that, as in Figure 1 of the questionnaire, the paint area may be separate from the incinerator, and that a UOS would consider this distinction. In addition, he stated that this data collection is the first step in a flexible learning process to help EPA understand how each facility operates and how much change maybe required. He also commented that EPA needs to learn of differences among the facilities.

Dr. Serageldin asked if he had covered everything. Mr. Karwowski replied that he had a new issue if there were no comments about the questionnaire. He stated that he had a letter from a legal firm which indicated that P-MACT carried more weight than the final MACT, and he wanted to know if this were true.

Dr. Serageldin stated that he was not sure he understood the question. Mr. Sell replied that

P-MACT has certain legal requirements, such as if the State has to implement P-MACT. He explained that a concern was that if we gather data for P-MACT on just the typical "white goods" industry, what effect would this have on the final MACT.

Dr. Serageldin responded that EPA would like to focus on the P-MACT effort as a project for MACT. He explained that the data gathering will not cover everything and that EPA is not required through the P-MACT process to send out a questionnaire. P-MACT is supposed to be based on the best available data. Dr. Serageldin also stated that this group will not develop something that is not unreasonable and that the work team will have a chance to look at the

P-MACT draft. The P-MACT draft will be EPA's best recommendation given the limited time frame for data collection and analysis.

Dr. Serageldin then asked if there were any other issues or comments. The industry representatives had no other comments, so the call was concluded.

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Attachment 1

Attendee List

Conference Call

June 16, 1997 Attendee

June 16, 1997 - Conference Call

Attendee List

Attendee	Affiliation	Address/Telephone
Dave Hendricks

Karen Holmes	Environmental Consulting and Research, Incorporated (EC/R)	2327 Englert Drive, Suite 100

Durham, NC 27713

(919) 484-0222
Joe Mattingly	Gas Appliance Manufacturers Associations (GAMA)	1901 North Moore Street

Suite 1100

Arlington, VA 22209

(703) 525-9565
Tim Hooker	General Electric	GE Appliance Park

AP65 -100

Louisville, KY 40225

(502) 452-4797
Ray Rusek

Doug Wilson	Maytag Appliances	403 West Fourth Street North

Newton, IA 50208

(515) 791-5749
Bob Nelson

Jim Sell	National Paint & Coatings Association (NPCA)	1500 Rhode Island Ave., NW

Washington, DC 20005-5597

(202) 462-6272
Judy Lee

Greg Pagett	Pacific Environmental Services, Inc.	Post Office Box 12077

5001 S. Miami Blvd., Suite 300

Research Triangle Park, NC 27709

(919) 941-0333
Kenneth Gabele

Madeleine Harding

Dwight Kohapen	The Sherwin Williams Company	101 Prospect Avenue

Cleveland, OH 44115

(216) 566-3316
Dan Elliott

Bob Mulliener	Trane Company American Standard	1 Centeninnel Avenue

Piscataway , NJ 08855-6820

(732) 980-6304

3600 Pammel Creek Road, Bldg 17-1

La Crosse, WI 54601-7599

(608) 787-4467
Linda Herring

Mohamed Serageldin	USEPA	OAQPS / ESD / CCPG (MD-13)

Research Triangle Park, NC 27711

(919) 541-2379
Robert Karwowski

Whirlpool Corporation	2000 M-63

Benton Harbor, MI 49022

(616) 923-3614

Attachment 2

Memorandum to Dr. Serageldin from Mr. Karwowski

Large Appliance Manufacturers

Comments on the U. S. EPA Questionnaire

June 6, 1997