NSC Technical Subcommittee Call Minutes – October 18, 2016
Participation [by regions]:
1: Sara Johnson – NH
2: Harry Ching - NY
3: Jeremy Hancher – PA
4: Tony Pendola – NC and Mary Talukder – GA
5: Bob Taylor, Annette Fulgenzi, Erin Conley & Ed Bakowski – IL; Jenifer Dixon – MI; Lisa Ashenbrenner - WI; Todd Nein, Brent Goetz – OH and Mark Stoddard - IN
7: Barb Goode & Larey Sadiq – KS
9: Mark Hubbard – AZ and Jenna Latt – CA
August minutes: approved as is
Open forum
(Current or upcoming topics of interest, issues we need more information on, what states are currently working on, etc.)Air Pollution Control Cost Manual Updates – basis for EPA’s economic analysis
Impacts refrigeration condensation, incineration and oxidation
Manual is being revised, comment accepted through December 21
Larry Sorrel, EPA will tentatively present on this topic during November call
40 CFR 63, Subpart M – National Perchloroethylene (Perc) Air Emission Standards for Dry Cleaning Facilities – last updated in 2008
December 21, 2020 – eliminating Perc from co-residential dry cleaning facilities
Relocate/replace with a drop off location
Replace solvent – Green Earth is an example, still generates hazardous waste
Petroleum solvents are subject to state or city fire codes/NFPA standards; some states or cities may be more restrictive
Hazardous waste generator improvements regulatory changes – anticipated to be final soon
Watch for publication in Federal Register
Response to comments received, including those submitted by subcommittee, should be published in the Federal Register or in preamble of final rule
Auto body/collision repair – 40 CFR 63, Subpart HHHHHH (6H)
Vendor products lists containing 6H metals - https://nationalsbeap.org/content/vendor-resources-6h-petition-exemption
Petition for exemption - https://www.epa.gov/sites/production/files/2016-01/documents/petitionforexemption.pdf
Burden/difficult to complete paperwork
Fear of being inspected if they petition
Not a priority/inertia – no one is asking about it, shops used to required training
Electronic reporting?
Workgroup developing template (paint manufacturers, trade associations, shops, insurance companies), Tony asked to be involved
Manufacturers have their own systems, don’t want a standard – shops can pay to use their supplier’s system
Not all states require reporting
Recordkeeping is a big issue for shops, one system might be helpful
Region 5 complaint driven form letters – provided SBEAP contact info
Illinois outreach – 6H refresher training
Networking opportunities
Identifying industry groups at the national and state levels – state level groups will be more tuned in to local events creating a contact list over time – Promotional Subcommittee has national trade association list
Next Call:
November 15, 2016
2-3pm EST (3rd Tuesday of month)
Future topics for consideration:
· ~ tentative for November ~ Air Pollution Control Cost Manual updates, comments must be received on or before December 21, 2016 - https://www.gpo.gov/fdsys/pkg/FR-2016-09-22/html/2016-22846.htm
· Promoting/conducting confidential compliance assistance visits
· Coating manufacturers: sharing information to help users with environmental determinations
· How different states handle potential to emit
· User fees for electronic hazardous waste manifests and amendments to manifest regulations
· RCRA hazardous waste generator rule coming out in Oct 2016 – suggested by Jim O’Leary
· Start-up/shutdown final rule – Tony (NC) and Melissa (MS) how their states are handling
· Metal fabrication resources / 6W – what it is, what resources are out there (states could share what they have), Region 5 project – could gather resources to be added to the website (some people have indicated that is it difficult to find resources)
· ~tentative for January~ Multimedia assistance – (Barb and Dan)
Minutes prepared by Lisa Ashenbrenner Hunt – WI () and Mark Stoddard – IN (), Technical Subcommittee Co-Chairs.