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Need your help providing specific P2 info. on multiple sectors to EPA Office of Air



P2ers,

I hope this message finds you well.

Please help us provide answers to the P2 questions in the table below.
Please send your responses to:

Karl Bremer
USEPA/ESD  C43902
109 TW Alexander Dr.
Research Triangle Park, N.C. 27709
Phone: (919) 541-3003
E-mail:  bremer.karl@epa.gov

Background: In the 1990 Clean Air Act, EPA was given discretion as to
how to implement air standards for smaller, area sources. The EPA Office
of Pollution Prevention and Toxic Substances (OPPTS) is now working with
the Office of Air Quality Planning and Standards (OAQPS) to develop
rules for the specific area sources below that incorporate P2 in them.
HQ is also working with NPPR, FOSTAA and STAPPA/ALAPCO on this, but they
would like specific P2 information, as described below.

Please send studies/data to Karl at the email address above. This is a
very worthwhile effort: a chance to get P2 integrated into Air rules and
demonstrate the effectiveness of a combined P2/regulatory approach.
Thanks in advance for your assistance.

|------------------+----------------+---------------------------------------------|
|                  |                |                                             |
|    Area Source   |      Rule      |                 P2 Questions                |
|     Category     |   Development  |                                             |
|                  |      Stage     |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
|                  |                | <      Is there a universal replacement for |
| Paint Strippers  | economic       | Methylene Chloride other than mechanical    |
|                  | analysis       | removers using abrasives or Normal Methyl   |
|                  |                | Pyrrolidone (NMP)?                          |
|                  |                | <      Are there any economic studies on    |
|                  |                | replacement of Methylene Chloride as a paint|
|                  |                | stripper?                                   |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
|                  | <    proposal  | <      Do you have emissions data           |
| <    Industrial  |                | demonstrating before and after data relative|
| Boilers          |                | to tuning up a boiler (reduction in HAP     |
|                  |                | emissions)?                                 |
|                  |                | <      Do you have any P2 studies           |
|                  |                | demonstrating an improvement in HAP by      |
|                  |                | emissions by switching from coal to oil or  |
|                  |                | gas?                                        |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
| < Plating and    |                | <      Are there any P2 studies             |
| Polishing        | data gathering | demonstrating that controls or changes in   |
|                  |                | process reduced or eliminated HAP emissions |
|                  |                | at plating and polishing facilities?        |
|                  |                |                                             |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
| < Iron and Steel | < data         | <      Are there any studies at iron and    |
| Foundries        | collection     | steel foundries where binder                |
|                  |                | systems(facilitates mold release) had been  |
|                  |                | reviewed and replaced with lower HAP        |
|                  |                | emitting systems?                           |
|                  |                | <      Are there any studies where the      |
|                  |                | process was changed resulting in lower HAP  |
|                  |                | emissions during pouring/cooling/shake-out  |
|                  |                | at iron or steel foundries?                 |
|                  |                | <      Are there any studies where          |
|                  |                | naphthalene-containing solvents used in a   |
|                  |                | binder system have been reduced by use of   |
|                  |                | naphthalene-depleted solvents to reduce     |
|                  |                | emissions?                                  |
|                  |                | <      Are there any studies demonstrating  |
|                  |                | emission reductions from replacement of     |
|                  |                | Cupola wet scrubbers with fabric filters?   |
|                  |                | <      Are there studies or data            |
|                  |                | demonstrating lower emissions from lined    |
|                  |                | furnaces vs. unlined furnaces?              |
|                  |                | <      Are there studies of cupolas         |
|                  |                | demonstrating reductions in emissions       |
|                  |                | (40-60% reduction) due to screening of      |
|                  |                | charged materials limiting the amount of    |
|                  |                | sand, rust and coke fines?                  |
|                  |                | <      For electric induction furnaces, are |
|                  |                | there studies where metal scrap is preheated|
|                  |                | prior to charging the furnace?  In addition,|
|                  |                | are there studies indicating that scrap     |
|                  |                | selection reduces emissions?                |
|                  |                | <      For electric arc furnaces (EAFs), are|
|                  |                | there studies demonstrating reduced         |
|                  |                | emissions from elimination of oil,          |
|                  |                | oxidation, and sand from casting returns or |
|                  |                | scrap?  In addition, are there studies      |
|                  |                | showing  elimination of back- charging of   |
|                  |                | EAFs reduces emissions?                     |
|                  |                | <      For mold and core coatings, are there|
|                  |                | studies showing the substitution of methanol|
|                  |                | based coatings with non-HAP coating         |
|                  |                | materials (such as isopropanol) has reduced |
|                  |                | emissions?                                  |
|                  |                | <      Are there studies of cupolas where   |
|                  |                | use of briquettes and oily scrap has been   |
|                  |                | reduced or eliminated?                      |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
|                  |                | <      For pesticides and agricultural      |
| Agricultural     | data collection| chemical production, are there examples of  |
| Chemicals and    |                | reformulation to eliminate ingredients?     |
| Pesticides       |                | <      Are there examples for these         |
| Manufacturing and|                | industries where better engineering of the  |
| Cyclic Crude and |                | process including control devices, leak     |
| Intermediate     |                | detection and equipment repair have reduced |
| Production       |                | use of original constituents used in the    |
|                  |                | process?                                    |
|                  |                | <      Are there examples of reuse of       |
|                  |                | off-spec materials created in the           |
|                  |                | manufacturing process?                      |
|                  |                | <      Are there examples of quality        |
|                  |                | assurance processes to prevent production of|
|                  |                | off-spec products?                          |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
| < Chemical       | < data         | <      Are there data or studies where      |
| Preparations and | collection     | metals (eg. chromium, cadmium, lead often in|
| Paint and Allied |                | pigments) have been removed or substituted  |
| Products         |                | in the manufacture of paint, inks, adhesives|
|                  |                | or sealants?                                |
|                  |                | <      Have HAPS been reduced by this       |
|                  |                | practice?                                   |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
| < Auto Body      | < data         | <      Are there data or studies where      |
| Refinishing      | collection     | metals including chromium, lead, and cadmium|
|                  |                | have been removed from automotive paints and|
|                  |                | primers?                                    |
|                  |                | <      Have the final product paints and    |
|                  |                | primers proved to be effective in the auto  |
|                  |                | body refinishing process?                   |
|                  |                |                                             |
|------------------+----------------+---------------------------------------------|



|------------------+----------------+---------------------------------------------|
|                  | <data          | <      Are there data or studies where      |
| < Blown Glass and| collection     | metals used to impart color to the process  |
| Glassware        |                | have been replaced with substitutes or      |
| Manufacture      |                | removed from the glass manufacturing        |
|                  |                | process?                                    |
|                  |                | <      Has this replacement or substitution |
|                  |                | been successful?                            |
|------------------+----------------+---------------------------------------------|



Best...

Leif Magnuson
Pollution Prevention Coordinator
U.S. EPA Region IX, WST-7
75 Hawthorne St.
San Francisco, CA  94105
(415) 972-3286
magnuson.leif@epa.gov
www.epa.gov/region09/p2

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