MEMORANDUM

DATE:	July 10, 1998

SUBJECT:	Meeting Minutes from the Paper and Other Web Coating Stakeholders Roundtable Meeting on June 4, 1998

FROM:	Trish Koman, USEPA/OAQPS/ESD/CCPG

TO:	Stakeholders and Meeting Attendees

A roundtable meeting was held to discuss the Environmental Protection Agency's (EPA's) integrated rule development for paper and other web coatings. Integrated rule development refers to the concurrent development process of two separate rules: 1) National Emissions Standard for Hazardous Air Pollutants (NESHAP) for the paper and other web coatings (POWC) hazardous air pollutant (HAP) source category pursuant to Section 112(d) of the Clean Air Act (CAA), and 2) regulatory action for the Paper, Film, and Foil volatile organic compounds (VOC) category pursuant to Section 183(e) of the CAA. Section I of these minutes includes an overview of the presentations, and Section II includes comments expressed and questions raised during the meeting and EPA's responses. A list of meeting attendees, including those attending via teleconference, can be found as Attachment 1. The meeting handouts are compiled in Attachment 2.

The following information was made available to stakeholders for the meeting: 1) the meeting agenda; 2) a summary handout of EPA's presentation overheads; and, a detailed handout packet, including 3)speaker notes and 4) tables, charts, and graphs. Items 1, 2, and 4 are included in Attachment 2.

I.	OVERVIEW OF PRESENTATIONS

Trish Koman, the EPA project leader, began the meeting by introducing the POWC project team, consisting of herself and contractor staff, headed by Dr. Donna Lee Jones of EC/R Incorporated (EC/R). Ms. Koman proceeded with introductions of meeting attendees. She presented the objectives of the

meeting by reviewing the meeting agenda, which included discussions of the POWC industry profile, survey data and analysis, printing versus coating issues, issues related to Section 112(c)(6) of the CAA, and future site visits. An open discussion period, in which attendees could ask questions, was also scheduled.

Ms. Koman reviewed a timeline with benchmarks for the integrated rule development. The project is on schedule for proposal of a maximum achievable control technology (MACT) standard in November 1999. Presently, the POWC team is working in the latter part of the data gathering and analysis phase. Ms. Koman emphasized the importance of industry involvement in helping to close data gaps and provide on-going review of data analyses results. Model plants are expected to be developed later this summer, after current data gaps have been filled.

The current schedule for the POWC NESHAP is as follows:

POWC NESHAP
Presumptive MACT	May 1997
Data gathering, analysis, and model plants	mid-1998
Regulatory options	late 1998
Economic impacts	early 1999
Proposal	November 1999
Promulgation	November 2000

Industry Profile

Status of Background Information Document Chapters

Lisa Sutton of EC/R discussed the status of the Background Information Document (BID) for the POWC project. Three of the four chapters of the BID are currently in draft format. These are Chapters 1, 2, and 3, respectively titled as Introduction, Industry Profile, and Emissions Control Techniques. The fourth chapter, Model Plants, will be drafted by September 1998. Ms. Sutton noted the sources of information used in BID development, including survey data (discussed later in the presentation), site visits, trade organizations, other industry organizations, Toxic Release Inventory (TRI) data, 1992 Census information, and additional literature. Additional data sources include the 1994 Gravure Association of America (GAA) survey, 1991 EPA Control Techniques Handbook, 1990 Office of Air Quality Planning and Standards (OAQPS) Cost Manual, 1984 EPA report on the Paper, Film, and Foil source category, and the 1980 Pressure Sensitive Tape BID.

Ms. Sutton described the structure of the BID. Chapter 1 is generic to all MACT standards. This chapter describes the source category, primary products and substrates, and defines coating. Chapter 2 is more specific to the industry and describes coating processes, materials, and eight industry sectors to be regulated under the POWC rule. Chapter 3 describes emission control techniques used in the industry, such as thermal oxidizers, carbon adsorbers, and solvent recovery. It also discusses capture systems, and pollution prevention (P2 ) measures. The model plant chapter at this point may include model plants or model plant groups of the three surveyed industry sectors, and at least one model plant group to represent the remaining sectors. If specific information is received for other sectors, more model plant groups may be developed. Dr. Jones noted that the EPA develops a model plant group for each unique set of economic data (i.e., sales revenues and costs).

Tom Godonis inquired whether the POWC team would like industry input in model plant development. Ms. Koman responded that this would be welcomed. EPA will seek industry input on the draft BID chapters, some of which may be available for review later this summer.

Estimated Number of POWC Facilities

Dr. Jones conveyed that it is a very challenging endeavor to develop an accurate facility count for the POWC source category because it is a "catch-all" source category rather than a discretely-defined one. The POWC team is currently trying to estimate the number of affected facilities. This information will be used to estimate the regulatory impacts of MACT, as well as to point out currently unidentified industry sectors which will fall under POWC. Estimates are being gathered from a number of sources of information. The team is aspiring to converge on a good estimate for POWC using information from all the sources, taking into account the limitations of each data source. To more accurately reflect the number of POWC facilities, the team will need stakeholder input to evaluate data for specific sectors.

Despite all efforts to develop an accurate count of POWC facilities, the final estimate for a POWC facility count will likely be a range of values. This is due to the uncertainties in estimation previously described, the most prominent of which is that POWC is a "catch-all" category.

Trade Organizations

Ms. Sutton indicated that, based on direct counts from trade organizations, it is estimated that there are 2,300 POWC facilities included in 38 trade organizations. However, this value has questionable accuracy. It is expected that there is overlap of facilities between the organizations. It is also likely that not all of these facilities actually perform coating. However, it is also likely that there are trade organizations that should be listed but are not included.

Ms. Sutton further discussed the role of trade organizations in developing a facility count estimate. She noted the counts in the INDUST.WK4 table in the detailed handout packet. This includes facility estimates for each trade organization and contains documentation on the information sources for each trade organization estimate. A table, INDUSTRYNO.WK4 , portrays the type of information that is needed by the POWC team to further develop the facility count estimate. Ms. Sutton requested that the attendees use this table to submit information directly to EC/R.

Dr. Jones moved on to discuss Standard Industrial Classification (SIC) codes that are included in the POWC source category at this point. It was necessary to identify the applicable SIC codes, since some data sources use them to classify facilities. Currently, 22 SIC codes have been identified as potentially defining the POWC category. Dr. Jones relayed that these SIC codes are listed in the SICONLY.WK4 table in the detailed handout packet.

Dr. Jones emphasized that only a percentage of the facilities in each SIC code conduct web coating operations; some SICs have higher percentages of web coating facilities than others. Additionally, she indicated that survey data for the first four SIC codes (2295, 2297, 2396, and 2591) will be collected under the Fabric Coating, Printing, and Dyeing NESHAP (Fabric MACT) effort.

Alex Ross proposed obtaining facility count and overlap information from the trade associations present at the meeting, particularly the Flexible Packaging Association (FPA). Mark Wygonik of the FPA responded that the organization has not gathered that type of information about its membership. Mr. Ross also suggested contacting the Flexographic Technical Association, a member of the POWC stakeholder group, to clarify some of the overlap areas.

Mr. Ross stated that the EPA should refine the SIC code classification scheme, as SIC codes were not designed to correspond to operations. Ms. Koman responded that the EPA does have source classification codes (SCCs) for obtaining operations- specific data, as in EPA's Aerometric Information Retrieval System (AIRS). However, SCCs have not proved useful in obtaining facility count information for this project. Hank Naour added that SIC codes are being revamped with subdivision in some cases. Larry Sorrels noted that a new classification system is replacing the SIC system. This system, called the North American Industry Classification System (NAICS), will be available next year.

Toxic Release Inventory (TRI) Data

Kavita Bhatia of EC/R discussed a search of the Toxic Release Inventory (TRI) database that was conducted to uncover potential POWC facilities. The database was searched using 20 of the 22 POWC SIC codes as the primary SIC code. This search revealed 620 potential POWC facilities in the TRI database. Ms. Bhatia explained that more facilities are expected to be uncovered when nonprimary SICs are also included in the search. The POWC team will be pursuing the use of the 22 POWC SIC codes as nonprimary SIC codes in the TRI database in the near future.

Ms. Bhatia noted that the TRI database is expected to reflect the larger sources in the POWC category, since only large sources are included (i.e., ≥ 12.5 tons per year manufactured or ≥ 5 tons per year used of TRI pollutants). Ms. Bhatia pointed out that the TRIPOWC.WK4 table in the detailed handout packet contains the TRI data.

Census Data

Dr. Jones described the results of searching census data. The census data indicated an estimated 12,000 facilities for 21 of the 22 aforementioned SIC codes. Dr. Jones indicated that this is expected to be a high estimate for the POWC category. Dr. Jones asked that the relevant stakeholder groups reconcile the census numbers found in the CBP95SIC.WK4 table (in the detailed handout packet) with their trade organization lists.

Kevin Barnett asked if the number of employees reported in the census data represent all employees in the facilities or companies, or those employees performing POWC activities only. Dr. Jones responded that this is unclear; however, the number of employees is most likely the total number in the collective facilities under the SIC code.

NSPS Estimate and Projection based on NPCA Growth Factors

Dr. Jones stated that the 1984 NSPS value for the number of POWC facilities is 1,700. Applying NPCA growth factors to the 1984 estimate, the number of facilities in the year 2000 will be approximately 2,400. The NPCA growth factors range from 0 (1991) to 5.9% (1993), for an average (mean) of 1.5% and a median of 1.8%.

Other Approaches

Dr. Jones explained that two additional sources of information will be examined to determine their usefulness in estimating the number of POWC facilities. The Dun & Bradstreet database is currently under review by the POWC team. A count of facilities from this database is formed in manner similar to the facility count from the census data. In addition, these data are expected to produce one of the higher estimates. In the near future, data from A. F. Lewis will be reviewed as well. The A.F. Lewis data will focus primarily on SIC 27.

Cheryl Kasunich mentioned that A.F. Lewis mainly tracks supplier data and may be neither useful nor cost-effective for collecting facility count information. Ms. Kasunich suggested that the Lockwood's Directory may be a better resource for information on coating facilities.

Mr. Naour asked whether the POWC team has accessed Title V permits in developing the POWC industry profile. Ms. Koman responded that EPA's Coatings and Consumer Products Group (CCPG) rule development teams have jointly requested this type of data from 22 states; data from several states are being analyzed by designated coating rule teams.

Data Gathering from Additional Sectors

Dr. Jones discussed several additional potential data sources and the current status of efforts related to those sources. The POWC team is currently in the process of gathering data from the Coated Abrasives Manufacturers Institute (CAMI). Preliminary discussions have revealed that because of the widespread use of catalytic incinerators that achieve 95 to 99 percent control, the average controlled HAP emissions per facility are expected to be as low as 1 ton per year from CAMI facilities. The POWC team is awaiting additional data from CAMI to determine whether any of these facilities are synthetic minor sources. Susan Young indicated that CAMI is near completion in its review of the blank survey form of one POWC industry segment, with the intent of providing similar information.

Paul Narog asked whether CAMI was being surveyed. Dr. Jones responded that CAMI had not been and probably would not be surveyed. Instead, CAMI will respond to a set of questions.

Dr. Jones mentioned that several additional data sources included data from the Fabric MACT survey and American Forestry and Paper Association (AF&PA) site visits. She concluded by noting that tires and most rubber products (hoses and gaskets) will be covered by other rules.

Survey Data and Analysis

Dr. Jones proceeded to discuss survey data and analysis. Survey data were collected from three segments of the POWC industry: the Pressure Sensitive Tapes and Labels (PST), Flexible Vinyl and Film (Film), and Industrial and Decorative Laminates (IDL) segments. These segments were identified as the highest HAP emitters based on TRI data. The POWC team analyzed the survey data from these three segments separately as well as together in the combined data set. The combined data set is a simple combination of the data, where each individual survey has the same weight as any other survey.

Dr. Jones noted that two separate sets of analyses were to be performed on these data. These were: 1) analyses on the entire set of surveys, and 2) analyses on major sources only. The total number of surveys collected that contained useful data is 174. Of these 174 surveys, 89 are from the PST segment, 58 from the Film segment, and 27 from the IDL segment. Dr. Jones noted that the "All Survey" analyses are complete, and will be discussed in this presentation. Only some of the "Major Source" analyses have been completed, so they were discussed in a limited fashion.

"All Survey" Analyses

Dr. Jones explained that the "All Survey" analyses consist of 1) analyses related only to coating lines; 2) analyses only for "other HAP sources" (excluding coating lines); and, 3) analyses of data for both coating lines and other HAP sources together (i.e., all HAP sources). The category "other HAP sources" includes laminating, hot melt, extrusion and calendering, storage and mixing/formulation, cleaning, material transfer, wastewater, printing, and other miscellaneous sources. Dr Jones noted that hot melt, extrusion, and calendering were included with the PST coating line analysis, although these sources were included with the other HAP sources for Film and IDL analyses.

Dr. Jones then described several terms to allow easier understanding of the statistical analyses in the presentation. The "overall control efficiency" (%OCE) is the product of the capture efficiency and the control device control/destruction efficiency. The "mean" is the average of a list of values.

She defined the use of the "median" value in the POWC analyses. In the case of an even number of values, the median is the value next higher than the true middle, when the numbers are ranked from the highest efficiency to the lowest. For example, in the series 1,2,3,4,5,6,7,8,9,10 the true middle is between 5 and 6; therefore, the median would be 6.

Dr. Jones continued the discussion of statistical terms by describing the use of the term "percentile," defining the 100th percentile as the best controlled source and the 0th percentile as the least controlled source. She then defined the "top 12%," as used in the analyses. An illustration of the top 12% concept is provided for an example data set in the FLOOR.WK4 sheet in the detailed handout packet. The top 12% value is significant because the CAA states that the MACT floor should not be less stringent than "the average emission limitation achieved by the best performing 12 percent of the existing sources (for which the Administrator has emissions information)."

Dr. Jones described several statistical analyses that were performed on the dataset. These included finding the highest values, the lowest values, the average value (i.e., the mean), the 88th percentile value and top 12%, and the median of the top 12%. Other noteworthy analyses were performed, such as calculation of the 80th percentile and the percentile/rank where %OCE falls to zero, but were not extensively discussed in the presentation.

Data Groupings

Dr. Jones described the delineation of data within the "All Survey" analyses. The coating line data is divided into two groupings, one by line, and the other by facility. The non- coating line data is also separated into two groups, one by source, and the other by facility. These groups are further divided into subgroups. The total HAP emissions by facility were estimated by %OCE, and by pound of HAP emitted per pound of coating solid used at the facility. The last analysis, which only includes facilities where %OCE is equal to zero, is intended to target those facilities that may be using pollution prevention (i.e., "compliant" coatings or other low-HAP coatings).

Results

Dr. Jones then moved on to describe the data analyses results. Analysis 1a describes coating line %OCE by coating line. The results are summarized in the ALL1AOH.WK4 spreadsheet in the detailed handout packet. Analysis 1b describes coating line %OCE by facility, and its results are summarized in the ALL1BOH.WK4 spreadsheet in the detailed handout packet. Dr. Jones presented the numbers from this first set of analyses, which elicited a number of responses from the group. The general opinion was that the numbers were quite high.

Bob Nelson inquired about the magnitude of the actual emissions corresponding to the 99.1 percent HAP control value, the median %OCE of the top 12% of the combined data set in Analysis 1a . Dr. Jones responded that although this value is unavailable at present, it could be found in the database and would be interesting to examine.

Following discussion of the coating line analyses, the second set of analyses were described. These two analyses cover non-coating line sources. Analysis 2a describes other HAP sources %OCE by source, while Analysis 2b covers other HAP sources %OCE by facility. These two analyses are included in the detailed handout packet in the ALL2AOH.WK4 spreadsheet and ALL2BOH.WK4 spreadsheet, respectively. Again, Dr. Jones' presentation of these numbers led to a number of comments and questions from the group.

Katie Hornbarger questioned why the POWC team collected and analyzed HAP emissions data from sources other than coating lines at a given facility. Ms. Koman replied that the EPA is required to gather data on all facility HAP sources to ensure that the important ones have been identified.

Jennifer Griffith asked how HAP emissions from coating lines compared to HAP emissions from other HAP sources. Ms. Koman replied that coating line HAP emissions far exceed HAP emissions from other sources. However, lamination operations may be an exception, perhaps contributing significantly to HAP emissions.

Emil Studinka inquired about the working definition of lamination, one of the non-coating HAP sources. Ms. Koman responded that as with many other terms (such as "coating" and "printing"), lamination is not clearly defined. The POWC team relied on the facility's identification of its operations as including lamination.

Larry Hicks wondered if another regulation would oversee HAP emissions from wastewaters at a POWC facility. Ms. Koman stated that liquid effluent guidelines are emerging in a rule that applies to publicly owned treatment works, but that this would not influence POWC facilities. Dr. Jones stated that Mr. Hicks may have been recalling the wastewater component of the Hazardous Organic NESHAP (HON) rule, which also would not impact POWC facilities.

The third analysis covers total facility HAP emissions. Analysis 3 contains %OCE for all HAP sources combined (i.e., both coating line and other HAP sources) and is summarized in the ALL3OH.WK4 spreadsheet in the detailed handout packet.

The last set of analyses focuses on pound of HAP per pound of coating solids (lb/lb) data. Analysis 4 covers lb/lb for total facility HAP emissions for all facilities in the database. The analysis is summarized in the ALL4OH.WK4 spreadsheet, found in the detailed handout packet.

Analysis 5 also covers lb/lb but only contains the data for facilities whose %OCE is equal to zero. The data for this analysis is contained in the ALL5OH.WK4 spreadsheet in the detailed handout packet.

In response to the low lb/lb median of top 12% value in Analysis 5, Nelson Lawson suggested checking the results against similar analyses performed for existing coating rules. Ms. Koman responded that the POWC team may compare data with information from the Aerospace, Wood Furniture, Shipbuilding, and Magnetic Tape rules. Mr. Barnett mentioned that the Coil Coating MACT project team will be performing a similar analysis in the near future.

Ms. Griffith commented that Analysis 4 does not seem very useful, as it includes data from any facility reporting a lb/lb value. Thus, such facilities could be using a combination of compliant coatings and add-on control, which complicates the assessment of emissions control. Ms. Koman agreed that Analysis 5 is more clearly significant, and explained that Analysis 4 was computed to obtain an idea of the top 12 % of facilities selecting multiple strategies for emissions control.

Following the discussion of the analyses presented by Dr. Jones, the group broke for lunch.

Vinyl Coating Analyses

Following the lunch break, the group continued the survey data and analysis discussion. Dr. Jones proceeded to discuss vinyl coating (i.e., the coating of a vinyl substrate). She noted that the survey data showed very little difference between HAP control efficiency for vinyl coating compared to other substrates. She then indicated the underlying reason for performing separate analyses on vinyl sources. EPA's Control Technique Guidelines (CTG) vinyl VOC limit was 3.8 lb/gal, compared to 2.9 lb/gal for paper and fabric. The POWC team wanted to determine the cause for this difference, as well as determine if this difference exists in the POWC database. Dr. Jones determined that this higher CTG value is likely based on a higher baseline level of VOC in vinyl coatings than paper and fabric coatings. Dr. Jones noted that the VINYL-1. WK4 spreadsheet in the detailed handout packet displays all of the vinyl analyses. The VINYL-2. WK4 spreadsheet (in the detailed handout packet) compares the vinyl data to the combined "All Survey" data. Dr. Jones noted that the vinyl HAP %OCE ranges from 0 to 99 percent, with the median of the top 12% being 98 percent. In addition, the 88th percentile value is also 98 percent.

Dr. Jones continued by discussing some of the other results from the vinyl analyses. She indicated that the lb/lb level for vinyl was higher than for the combined database. However, the median lb/lb of the top 12% was still much lower than the presumptive MACT (p-MACT) 0.2 lb/lb level. Dr. Jones then discussed the lb/lb level for facilities coating vinyl whose %OCE equals zero. She indicated that the median of the top 12% for these facilities is at the same level as the combined database. In addition, the top 12% lb/lb for vinyl is much lower than the

p-MACT lb/lb level. She then noted that for both the "All Vinyl" and the "%OCE equals zero Vinyl" analyses, the percentage of vinyl facilities with lb/lb less than or equal to the p-MACT level is actually higher than in the combined database.

Ms. Kasunich asked for clarification on whether the vinyl coating analyses consider vinyl as a substrate to be coated or as a component in a coating formulation. Ms. Koman responded that the analyses were concerned with the coating of a vinyl web substrate. Mr. Ross indicated that vinyl coatings are classified either as organisols or plastisols and can be applied to many substrates, such as paper and vinyl itself.

Ms. Griffith requested confirmation that vinyl coating is not a special case, warranting subcategorization. Ms. Koman corroborated her statement but indicated that other analyses would be performed to uncover any cases in which overall control efficiencies differed significantly from the survey database average and top 12% %OCE.

Mr. Ross asked if data from vinyl flooring manufacturers were collected, since he believed that vinyl flooring production involves web processes. Dr. Jones stated that these manufacturers may not have been surveyed for the POWC project, but that data concerning the web coating of vinyl as a substrate for other products was collected. Jeff Rezin revealed that many vinyl flooring manufacturers purchase precoated vinyl; thus, they would not have had to complete a survey, as long as original vinyl coaters were contacted. Ms. Kasunich added that there are only six companies in the business of vinyl flooring manufacture. Matthew Waite commented that information on vinyl flooring manufacturers would have likely been provided by the Gravure Association of America.

Major Source Analyses

Dr. Jones began the discussion of major source analyses by defining the term "major source." According to Section 112(a) of the CAA, "the term major source means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any HAP or 25 tons per year or more of any combination of HAPs." See Attachment 3 for a copy of the citation. These HAP emissions are based on controlled, or actual, emissions. However, for the analyses, synthetic minor sources, or facilities whose controlled emissions are less than the major source thresholds but whose uncontrolled emissions exceed these values, were included. Dr. Jones then noted that there are a total of 85 major sources, and 42 synthetic minor sources in the POWC database. Together, these 127 sources represent 73% of the database. Dr. Jones mentioned that the number of major sources listed in the handouts is inaccurate, and the numbers presented in this text are the actual values.

Charlie Carter questioned the validity of using data from synthetic minor sources, together with true major source data, in performing the MACT floor analysis. He cited the CAA specification that only major sources, defined as exceeding the thresholds considering controls, are to be subject to MACT standards. Ms. Koman explained that there is a distinction between inclusion in the MACT floor analysis and being subject to the regulation; thus, it is valid to include synthetic minor sources in computing the MACT floor. Ms. Koman then confirmed Mr. Narog's statement that area sources, constituting the other 27 percent of the survey database, are not used in calculating the MACT floor. Mr. Narog further questioned whether the POWC rule would include major sources only. Ms. Koman replied that the EPA has the discretion to develop requirements for area sources; if these were developed, they would be contained in the POWC NESHAP.

Printing vs. Coating Issues

Ms. Koman discussed the attempts that have been made to differentiate between printing and coating. She noted that the EPA is currently working with the printing industry to attempt to classify their emissions and stated that the goal is to avoid requirements that conflict with the Printing and Publishing NESHAP (P&P rule).

Attendees asked to review distinctions between printing and coating to clarify rule coverage for the POWC rule and P&P rule. Ms. Koman elaborated that EPA's definitions for "printing" and "coating," specified in the P&P rule, are working definitions and do not account for all existing scenarios. Printing operations can be described as the application of images (i.e., words, designs, and pictures) to a substrate, often for mostly decorative purposes; coating operations can be defined as the application of a coating across the entire length or width of a substrate to provide a covering, finish, or protective layer, or to provide adhesion between two substrates (as in lamination). However, spot coating, adhesive coating for envelopes, and instances in which the entire web is not coated because of trims are examples of coating in which the present coating definition does not hold.

Ms. Kasunich commented that in the gravure printing industry segment, printing and coating activities are generally conducted on the same process line and are configured to a common control device. It is likely that these facilities will choose to control HAP emissions from both printing and coating under the P&P rule, where this is allowed under the NESHAP (Note: not all printers are able to meet the requirements). Asking State agencies for the number of facilities submitting notification of intent to comply with the P&P rule may provide an approximate idea of the maximum number of printers for the POWC source category.

CAA Section 112(c)(6) Issues

Ms. Koman briefly discussed Section 112(c)(6) of the CAA (see EPA's Unified Air Toxics website web page printout in Attachment 2) as it relates to the POWC project. She explained that Section 112(c)(6) focuses regulatory attention on facilities that account for 90 percent of total emissions of seven specific chemicals or families of chemicals. These facilities are grouped in source categories pursuant to Section 112(c)(6). Data collection for the "paper coating and laminate packaging" category may utilize data from the POWC project. One HAP chemical family that falls under Section 112(c)(6) is polycyclic organic matter (POM). Since naphthalene (also a VOC) can be considered a POM, this chemical is of interest to the POWC project due to its presence in POWC facility TRI reports (albeit in small amounts). The POWC team has performed a search of the survey database to determine if naphthalene was used or generated in any facility; very few occurrences of naphthalene were found.

Mr. Ross expressed that he would not expect naphthalene to be widely used in coating formulations. Ms. Koman stated that the National Paint and Coatings Association (NPCA) indicated to the EPA that naphthalene could be a component in some coatings. She further explained that the EPA had relied on TRI data, which is facility-wide (not operation-specific), in generating the Section 112(c)(6) listing. The TRI database showed some POM emissions for POWC facilities, but it was not clear if emissions were due to the coatings or were emitted from other operations. Ms. Griffith stated that the TRI POM emissions could be from facility operations that are completely unrelated to coating, such as boilers.

Mr. Barnett inquired about human exposure modeling in approaching regulation under Section 112(c)(6). Ms. Koman responded that it is unclear whether a risk assessment will have to be conducted. Ms. Koman summarized that it is generally unclear, for the time being, how exactly to proceed with Section 112(c)(6) work.

Future Site Visits

Ms. Koman provided a brief update on plans for site visits. She noted that such visits may be necessary to investigate specific coating technologies and coating types. These visits will help define regulation applicability and will be used to gather data on additional industry segments. Potential sites that may be visited include paper manufacturing specialty coaters, printing and coating facilities that perform narrow web coating or bindering, and possibly others.

Ms. Kasunich asked which sites have already been visited for the project. Dr. Jones directed her to the October 1997 stakeholder update, available by accessing the POWC project on the CCPG web page on EPA's Unified Air Toxics website (UATW). Ms. Koman concluded the presentations by displaying web addresses of interest to POWC stakeholders. For future reference, she noted that the site contains maps and directions to EPA's facilities, as well as information on local lodging and restaurants.

II.	COMMENTS

The comments of stakeholders and meeting attendees are presented in this section, grouped somewhat by topic, but not necessarily in order of their presentation. Where applicable, the EPA response is included following the comment.

Representativeness of Data

Mr. Ross inquired about the percentage of all POWC facilities represented in the survey database. Ms. Koman replied that a percentage is difficult to estimate, as the facility count effort is ongoing. The POWC team is confident that facility data collected is a good representation of the three segments surveyed; information is being gathered from other sectors, as discussed earlier.

Mr. Hicks inquired about the data gathering "cutoff point" in terms of the percentage of affected facilities from which data is required to complete rule development. Ms. Koman replied that the cutoff point is not so much a number of facilities but an amount of data that can be compiled and analyzed before the proposal deadline. Graham Fitzsimons added that the foremost goal of the data gathering phase is to obtain data for a representative segment of the industry.

Mr. Narog asked if any additional surveys were planned for gathering data for the project. Ms. Koman responded that Section 114 surveys are time consuming; thus, further gathering of facility information would most likely proceed via other correspondence.

Tim Owens stated that if there are approximately 11,000 facilities that may be subject to the POWC rule, it does not seem reasonable that EPA would survey so few of them. Ms. Koman responded that realistically there may be on the order of 1,000 to 2,000 facilities that will be subject to the rule that were not included in the 174 facilities that have been surveyed. Ms. Koman said that the EPA is trying to characterize the overall industry, and that contacting each facility would not be reasonable. The EPA works with readily available information in developing a MACT standard. In the case of the printing industry, the POWC team is examining the information recently acquired through a survey of printing facilities that was performed as part of P&P rule development.

Mr. Waite wondered whether the survey database might contain disproportionately more data from facilities with better HAP emission control or less data from facilities with lower HAP control, which would indicate skew in the existing survey database, because only those facilities chose to respond. Ms. Koman clarified that facilities that received Section 114 surveys were required to submit responses; thus, the representativeness of the survey database would not be in question.

Survey Data

Mr. Godonis inquired whether facility survey data were weighted on facility size. Ms. Koman replied that the calculations were independent of facility production volume or material throughput. Mr. Owens inquired whether survey data for new facilities were separately assessed. Dr. Jones replied that this was not done but that only 7 facilities surveyed indicated that they are subject to New Source Performance Standards (NSPS). Mr. Owens and other attendees expressed that this number of NSPS facilities seemed rather low.

Mr. Hicks implied that consideration may need to be given to coating application density (amount of coating applied per square unit of web), as this quantity varies significantly among POWC operations. Industrial and decorative lamination operations tend to have higher coating application densities. In response to a question about the amount of coating (or solvent) retained in web materials, Mr. Hicks replied that this is generally thought to be less than one percent of the coating applied.

Howard Hofmeister asked whether capture efficiency data were requested separately from destruction efficiency data in the Section 114 surveys. Dr. Jones confirmed that these values were requested separately and that the POWC team used them to calculate overall control efficiencies, in case reported values did not seem reasonable.

Mr. Barnett asked whether capture efficiencies for controlled HAP streams in the survey data were verified, specifically to check whether the efficiency values were supported by tests. Ms. Koman stated that the POWC team relied on facilities to provide accurate information. Also, the facilities responded as to the basis of their estimates for both capture and control device efficiency.

Mr. Godonis stressed that a ventilator hood may be reported to achieve 100 percent efficiency (i.e., to capture the HAP- containing stream in its entirety), but that this efficiency cannot be achieved in practice. He urged the EPA to utilize those capture efficiency values that can be substantiated by reliable tests. Ms. Koman responded that questionable values were either confirmed or excluded from the analysis; however, facilities should submit revised survey responses, as necessary to alleviate lingering concerns. Moreover, any requirement for verifying capture efficiencies would amount to requiring testing activities even before regulation development is completed. Ms. Koman emphasized that the EPA is limited to the quality and quantity of data provided by industry.

Mr. Ross suggested interfacing with capture equipment manufacturers to get an idea of reasonable capture efficiencies. Ms. Koman stated that various EPA personnel have done so and have documented this information in numerous publications.

Mr. Hofmeister asserted that aside from concerns regarding the validity of reported capture efficiency values, destruction efficiency values reported may have large variabilities, some of which result from whether Method 25 or 25A was used. Mr. Hicks stated that facilities typically base their knowledge of the destruction efficiency achieved by a control device on results from 3 1-hour tests conducted when the device is first installed. When the device is newly acquired, high destruction efficiencies are achieved, and facilities mistakenly report these as representative of device performance on a regular basis over time. Mr. Hofmeister said a facility may not always report the results of all tests and recommended that the POWC team consider revisiting the destruction efficiency values.

Mark Hawes echoed collective concerns about the integrity of device control efficiency values, particularly since most are based on 3 1-hour tests depicting a positively-biased snapshot of device performance. However, solvent recovery efficiency values are achievable on an ongoing basis. In fact, recovery rates are often calculated on a monthly basis. Ms. Koman pointed out that the EPA is interested in an accurate picture of facility emissions over time, which was why the POWC team is interested in investigating the feasibility of continuous emission monitoring ( CEM).

Mr. Hicks questioned whether any of the overall control efficiencies discussed have been found to vary by individual HAP chemicals, since some HAPs are easier to control than others. Dr. Jones responded that survey data has not been analyzed on a chemical basis at this point in time.

Mr. Godonis inquired whether water-based compliant coatings were reported to contain 0 percent VOC, noting that EPA's Method 24 test results may differ from manufacturers' data (Materials Safety Data Sheet, or MSDS, and Certified Product Data Sheet, or CPDS). Dr. Jones spoke to his concerns about data integrity by revealing that when formulations were reported to have, for example, between 0 and 30 percent of a component, the POWC team used 15 percent in their analyses. Ms. Koman added that survey responses reflect whatever information was available to responding individuals.

Mr. Godonis emphasized overall concerns with the quality of data for the facilities in the top 12 percent. He stated that during a performance test, process conditions and control device parameters are carefully controlled. Because normal operating conditions are quite different, data may not be representative of reality. Any overall control efficiency values used to determine the MACT floor should be demonstrable under normal operating conditions.

Data Collection Priorities

Attendees made many comments regarding a pie chart and a horizontal bar graph (in Attachment 2) displayed by Ms. Koman. The pie chart, obtained from an EPA report published in the 1980s , depicts the contribution of various types of coating operations to the overall solvent usage by POWC industry; solvent usage was used as a surrogate for potential HAP emissions for the purposes of setting priorities for data collection. Ms. Koman stressed that solvent usage does not necessarily imply emissions because the use of add-on controls are not factored in.

The bar graph was recently compiled by Ms. Koman to depict the maximum number of facilities potentially in the POWC source category. Ms. Koman stated that the largest group of facilities are printing facilities. Thus, the POWC team is working with the flexographic, gravure, lithographic, and screen printing segments to fill data gaps. Ms. Kasunich noted that the number of facilities for the gravure printers category (the longest bar on the graph) also includes wide web flexographers.

Mr. Godonis noted that the pie chart gives an unduly negative impression when it shows the pressure sensitive products segment as the largest consumer of solvents within the POWC industry. The basis for examining solvent use is "shaky" because facility emissions depend more on the extent of solvent recovery activities and other control techniques than the volume of solvents used. The pressure sensitive tape segment uses a great deal of solvent recovery and achieves high overall control efficiencies for its add-on control devices. In actuality, the TRI emissions from SIC 2672 are less than 15 percent of total TRI emissions found, as reported in the TRIPOWC.WK4 table. Moreover, the solvent use values are from the 1980s and do not reflect the results of source reduction measures implemented in the industry segment since then. Ms. Koman reiterated that the pie chart was only used as a starting point in the project to determine where to begin data gathering.

Mr. Narog commented that a chart based on emissions may be more useful. Ms. Koman responded that emissions broken out by operations are not easily available: the TRI data does not suffice because the TRI-reported emissions are facility-wide, and SIC codes do not readily match up to the POWC source category's "catch-all" nature. Mr. Godonis then expressed that it would be very useful to know what part of the database, or more specifically what percentage of total HAP emissions from the surveyed facilities, is due to the pressure sensitive tapes and labels segment. Other attendees concurred that it would also be useful to know emissions contributions of other segments in the survey database. Gordon Miller stated that this may help disclose any segments that are over-represented or under- represented in EPA's database.

Mr. Ross asserted that the majority of emissions from POWC operations are probably from a small number of solvents. Thus, regulation effort could proceed from a chemical viewpoint by focusing on solvent substitution, rather than best performance by add-on controls. David Yount disagreed by stating that the legislation should not dictate which coating products are to be used by industry. Attendees indicated that a compliance program such as that of the P&P rule offers industry ample flexibility.

Method of Emissions Control

Several attendees urged the EPA to offer facilities the option to use low-solvent coatings, rather than "end-of-pipe" controls only, in complying with the POWC standard. Dr. Jones responded that, in following the P&P rule construction, it is likely that the POWC MACT will have compliance options that allow for P2. Dr. Jones also noted that P2 options were also included in the POWC p-MACT, and that compliance options for the p-MACT coating HAP content limit were based on monthly averages of the HAP contents of the coating formulations used.

Mr. Ross stated that, in his opinion, requiring a high HAP control efficiency, such as 99 percent, virtually amounts to requiring the use of zero-HAP coatings. Mr. Barnett expressed that whereas "captive" coating operations may be able to incorporate such coatings, the use of compliant, or even zero- HAP, coatings may not be feasible for toll coating operations, which alter coating formulations for each customized application. Toll coating operations would be able to comply through control efficiencies achieved through the use of add-on control devices. Mr. Barnett suggested that it may be worthwhile for the POWC team to quantify the number of POWC toll coating operations, since pollution prevention options probably would not work for them. Ms. Koman responded that this would be a difficult endeavor, especially since this information was not requested in the Section 114 survey.

Mr. Hawes expressed interest in the distribution of the types of HAP emission controls in the data below the 88th percentile. Mr. Hawes also stated that it was his belief that solvent recovery is the predominant form of HAP emissions control in the publication rotogravure printing industry segment, regulated in the first part of the P&P rule. Ms. Kasunich confirmed this to be true. She elaborated that solvent recovery methods were implemented in these facilities in the 1960s, much earlier than the CAA, and proved profitable, as recovered solvents were sold and continue to be sold to ink suppliers. Thus, if the P&P rule had imposed requirements rendering solvent recovery infeasible, the publication rotogravure segment would have suffered significant revenue losses.

Mr. Godonis expressed that solvent recovery has several advantages over combustion. One advantage is that solvent recovery does not involve fuel expenditure, which is especially critical during shortages. Moreover, unlike combustion, solvent recovery does not generate secondary emissions, such as nitrogen oxides and other combustion byproducts. Mr. Godonis stated that the MACT program holds too narrow a view of air pollution control, and that the POWC regulation should allow the use of solvent recovery as a compliance option. Mr. Ross cited secondary emissions from add-on control techniques as another reason to instead require solvent substitution involving switching to zero-HAP coatings. Mr. Narog stated that compliant coatings may not lend themselves to viable solvent recovery.

Mr. Godonis stated that if a high overall control efficiency for HAP emissions was required, averaging control efficiencies or values over various process areas (the "bubble concept") would be difficult due to an array of new and old equipment at a facility. Ms. Koman replied that facilities would most likely have the option of taking any combination of add-on control and reformulation to comply with the standard, as is offered in the P&P rule. Greg Moeller commented that flexibility in compliance options for POWC standards would be advantageous for large facilities but not for small facilities.

Mr. Moeller suggested although the exact coating lb/lb value cannot be established at this stage in rule development, a method could be developed to convert from percent control (based on add- on control devices) to an equivalent coating limit. That way, once the percent control is established, obtaining an equivalent pound HAP per pound solids value would be straightforward.

Accordingly, a suggestion was made to form a subcommittee that would explore methods for arriving at "equivalencies" that will enable specification of the MACT floor for the POWC rule. Ms. Koman indicated that stakeholders should contact Dan Brown, the returning EPA project lead, for participation in such a subcommittee.

Definition of Source and Other Applicability Issues

Mr. Barnett asked whether the POWC standard will have subcategories for each of the types of operations affected. Ms. Koman stated that the POWC team is finding more similarities than differences among the types of operations currently falling in the source category. Thus, the preference is not to subcategorize for the sake of simplicity in the standard, which promotes ease in implementation. She emphasized that the P&P rule, a model for the POWC project, accommodates different operations through a variety of compliance methods.

Mr. Moeller asked which of the other HAP sources in the survey database, if any, produce low HAP emissions. Dr. Jones responded that wastewater treatment and storage activities at the surveyed POWC facilities appear to emit little HAP to the air. Ms. Koman indicated that work practice standards, rather than control efficiency requirements, may be considered for the other HAP sources.

Mr. Hofmeister questioned whether the POWC standard will regulate all HAP or organic HAP only, as in the P&P rule. Ms. Koman replied that the P&P rule may possibly be followed, since the POWC team is finding that volatile HAPs constitute the large majority of HAPs emitted by surveyed facilities (metal HAPs constitute a small fraction). However, a final decision has not yet been reached.

Mr. Hicks inquired whether laminate presses and reactors (for coating formulation) not covered under NSPS would be covered by the POWC rule. Ms. Koman responded that both sources are potentially covered; she noted that reactors would fit under the "Storage and Mixing/Formulation" category of other HAP sources.

Mr. Narog inquired about operations covered under the Fabric MACT. Ms. Koman replied that to date the Fabric rule is concerned with traditional textiles (clothing), carpets, and rubber coating of fabric. She clarified that rubberized pressure sensitive tape and label products would remain under the POWC rule. In general the POWC rule will serve as a "catch-all" for web coating operations not covered by other rules.

Mr. Ross expressed concerns that due to the diversity of operations in the source category, facilities subject to the standard may not recognize, at the time of proposal, that the POWC standard will apply to them. He mentioned that a notable number of printing facilities have had a difficult time understanding that they are subject to the P&P rule, whose source category is not as diverse. Ms. Griffith agreed that this problem may be encountered. Ms. Koman responded that State agencies are generally proactive and make efforts to inform facilities about federal standards applicability, as much as possible. Mr. Naour noted that States perform outreach activities, as early as the p-MACT phase. For example, in Illinois, agency personnel conduct "dry runs," or simulations, of standards implementation by visiting participating facilities and discussing the effects on facility operations. Furthermore, the Illinois agency attempts standards consolidation, especially to align monitoring, recordkeeping, and reporting requirements for the standards that apply to a given facility, in the facility permits issued. Ms. Koman added that this latter idea also supports the use of the P&P rule as a model, since State agencies will have had experience in dealing with its requirements.

Other Comments

Mr. Lawson inquired whether wax coatings will be covered by the POWC rule, since applying a wax coating via a hot-melt process is quite different from applying a hot-melt adhesive to form a pressure sensitive tape product. Ms. Hornbarger indicated that the AF&PA may have some information on HAP emissions from wax coating activities.

Mr. Waite inquired about details on the Section 183(e) component of the POWC regulation. Ms. Koman responded that the POWC team has been focusing on MACT and will work on the VOC issues later in the year. However, the data gathered during the MACT study will aid in the development of the VOC requirements.

Several attendees expressed interest in seeing a copy of a Section 114 survey through which data has been gathered for the POWC project. Ms. Koman agreed to post a revised version of one survey on CCPG's webpage on EPA's UATW site in the near future.

Mr. Narog inquired about plans for the next stakeholder meeting. Ms. Koman responded that the time frame for the next meeting would depend on the returning EPA project lead, Dan Brown; tentatively, a meeting in September or October could be expected.

Attachment 1:

Attendee List for POWC Stakeholder Meeting

on June 4, 1998

Attendee List for POWC Stakeholder Meeting on June 4, 1998

Name	Company/Affiliation	Telephone Number
Kevin Barnett	ALCOA	412-553-2094
Kavita Bhatia	EC/R Inc.	919-484-0222
Jason Bowker	Quad/Graphics, Incorporated	920-269-5236
Dan Bowman	EC/R Inc.	919-484-0222
Joelle Burleson	NCDEHNR - DAQ	919-733-1474
Mary Jo Caldwell	Caldwell Environmental, Inc.	919-781-1936
Charlie Carter	Womble Carlyle, for Tarkett Incorporated	919-755-2167
Ted Cartwright	Flexible Packaging Association	202-842-3880
Dennis Coil	Lawson Mardon Packaging USA Incorporated	708-649-3872
Graham Fitzsimons	EC/R Inc.	919-484-0222
Tom Godonis	American Biltrite Incorporated	609-778-0700
Jennifer Griffith	North East Waste Management Officials Association ( NEWMOA )/ NESCAUM	617-367-8558 X303
Mark Hawes	Shurtape Technologies	704-322-2700
Howard Hofmeister	Curwood - Bemis	920-303-7417
Katie Hornbarger	American Forest & Paper Association	202-463-2780
Donna Lee Jones	EC/R Inc.	919-484-0222
Cheryl Kasunich	Gravure Association of America	716-436-2150
Trish Koman	EPA/OAQPS/ ESD /CCPG	919-541-4120
Nelson Lawson	Union Camp Corporation	912-238-7752
Tom Loredo	Reynolds Metals Company	804-743-6636
Gordon Miller	Rexam Incorporated	704-551-1549
Greg Moeller	Eastman Kodak Co., and the Photographic and Imaging Manufacturers Association	716-477-9881
Paul Narog	The 3M Corporation	612-778-5380
Tim Owens	MACtac	330-688-1111
Mark Pederson	Rollprint Packaging Products Incorporated	630-628-1700
Steve Rach	MEGTEC Systems	920-339-2789
Jeff Rezin	O'Sullivan Corporation, and Chemical Fabrics & Film Association	540-665-2511
Alexander Ross	Radtech , International	703-534-9313
Larry Sorrels	EPA/OAQPS	919-541-5041
Lisa Sutton	EC/R Inc.	919-484-0222
Shannon Vogel	NCDEHNR - DAQ	919-733-1472
Matthew Waite	Resilient Floor Covering Institute ( RFCI )	610-266-5656
Mark Wygonik	Flexible Packaging Association	202-842-3880
David Yount	RJR Packaging	910-741-6309

The following individuals attended the meeting via teleconference:

Name	Company/Affiliation
Steve Byrne	Cytec
David Darling	National Paint and Coatings Association
Larry Hicks	General Electric
Scott Levin	Norplex
Hank Naour	Illinois EPA
Bob Nelson	National Paint and Coatings Association
Carol Niemi	Chemical Manufacturers Association - Solvents Council
Carrie Reese	Alpha-Gamma Technologies, Incorporated
Emil Studinka	Wilsonart International Incorporated
Susan Young	Chemical Fabrics & Film Association

Attachment 2:

Meeting Handouts

Attachment 3:

Definition of Major Source