 |
 |
 |
 |
|
|
|
|
|
|
|
R&D Stakeholders'
Task Force Conference Call
R&D Stakeholders' Task Force Conference Call
March 26, 1998
The Research and Development (R&D) Stakeholders' Task Force held a conference call on March 26, 1998 to discuss progress since the previous conference call (January 30, 1998) and the following agenda items:
1. Discussion of what additional data (if any) the Task Force will be providing.
2. Discussion of what are planned as the next steps in the data gathering effort.
II. PARTICIPANTS
A list of attendees is provided in Attachment A.
III. ACTION ITEMS
1. Stakeholders will provide Keith Barnett with additional information, including:
- PhRMA will send the information
they previously offered.
- Roy Hardiman, Genentech,
will send additional industry structure information for biotechnology
- Shannon Broome, General
Electric, is still compiling some facility information
- Ann Gross, NACUBO, will
supply any additional data available from research universities
- John Vanderwersf, DuPont,
will try to send additional information about DuPont R&D operations
2. Shannon Broome, General Electric, offered to draft a short list of questions that would assist in determining if we could exclude any industry sector, and the EPA will review it for potential use in limiting the number of industry sectors where we will be collecting additional information.
3. Stakeholders agreed to identify whether there are other trade organizations that may be interested in participating in information collection.
4. Keith Barnett will contact the EPA staff working on each National Emissions Standard for Hazardous Air Pollutants (NESHAP) source category to determine whether there is R&D associated with each, what information may be available on the R&D, and the trade organizations associated with each source category. He will also check on NESHAP projects that have used voluntary information collection and how successful this approach has been.
5. Keith Barnett will provide the schedule for data collection to the stakeholders when it has been approved by EPA managers.
6. The next conference call was set for 10:30 am to Noon (EST) on Thursday, April 16, 1998.
IV. MEETING SUMMARY
1. Discussion of what additional data (if any) the Task Force will be providing.
Keith Barnett asked if anyone else is planning to provide information (emissions data, industry structure, etc.). Several more pieces of information are expected from PhRMA, Genentech, General Electric, NACUBO, and DuPont, as described in the action items section (above).
2. Discussion of the next steps in the data gathering effort.
Keith explained that the issue of whether R&D should be listed as a category of major sources of hazardous air pollutants (HAP) has not been resolved. There is not enough information available from what has been submitted thus far to make an informed decision. The approach the EPA is going to take to obtain information for an informed listing decision is as follows:
- Look at each of the currently
listed HAP major source categories to identify the information that
may be available on R&D and trade associations of each. (This
will help identify industries that have not been involved thus far,
and will prevent those industries from being overlooked.) The associations
of research and development universities, medical laboratories, institutional
laboratories, government/military laboratories, etc., which are not
currently listed source categories, will also be identified.
- Contact each of the trade
organizations regarding whether their members do R&D, and if so
what can they tell us about it, in hopes of narrowing the source categories
and organizations in which R&D occur.
- The next step is to identify
major R&D facilities that are a part of each source category.
This may be done by surveying the information available from the rulemaking
of each listed source category, review of comment letters, or through
cooperation with trade associations.
- Voluntary or Clean Air
Act (CAA) Section 114 letters requesting information will be sent
to some facilities in each R&D category identified. This does
not necessarily mean that each source category will be listed separately,
but is just a mechanism of information collection.
Mr. Barnett asked for comments on this plan for information collection. Some stakeholders believed that the EPA has enough information to make the decision that the emissions are insignificant, either through utilizing the emissions data collected or the fact that R&D emissions have been deemed insignificant for other MACT rules. Mr. Barnett stated that the EPA believes that emissions data collected this far is not complete and warrants further collection. Also, the R&D emissions were not necessarily deemed insignificant for other MACT rules. Instead, the Agency deferred making a decision on regulating R&D, as allowed under Section 112(c)(7).
There was discussion of the variability in pilot plants. Some pilot plants vary in size and amount of controlled/uncontrolled emissions. This lead to a discussion of whether there will be a broad listing. Keith Barnett stated the information collection was not intended to be the basis of a broad listing, but rather was intended to limit the industry sectors and types of operations that may need to be considered. Shannon Broome said that she had been working on a short list of initial information that would be necessary to decide not to list a segment or type of operation. She will provide this list to the EPA for consideration.
The issue of whether to use a voluntary collection for industry information, versus an official Section 114 letter, was discussed. Multiple stakeholders (Mike Dunn, Rasma Zvanders, Ann Gross, Jim Vanderwerff, Ellen Siegler, Shannon Broome, Bill Wehrum, and Chuck Knauss) favored the voluntary collection. Umesh Dholakia supported the use of Section 114 because it may be more defensible. Some stakeholders thought that voluntary information collection had been used successfully in previous NESHAP projects. Rasma Zvanders reported the successful use of both Section 114 and voluntary survey letters on the Miscellaneous Organics NESHAP. Keith was asked to find examples of other projects where voluntary information collection had been used, and whether they were successful. One stakeholder felt that Section 114 letters may actually limit the information that could be collected. There was a discussion of what will be enough information, and the time schedule for the data collection. Keith Barnett has drafted a preliminary schedule, and will provide it to the stakeholders when it has been approved by EPA management.
ATTACHMENT A: PARTICIPATION IN THE R&D STAKEHOLDERS' TASK FORCE CONFERENCE CALLS Name
Organization
Meeting Date
12/4/97
1-7-98
1-30-98
3-26-98
Keith Barnett
EPA/OAQPS
x
x
x
x
Larry Bernson
Lucent Technologies
x
x
x
Shannon Broome
General Electric/NEDA/EIA
x
x
x
x
Russ Cerchiaro
Schering Corporation
x
x
x
John Dege
DuPont/American Crop Assoc.
x
x
x
Steve DeSantis
NY DEC
x
x
x
Umesh Dholakia
EPA Region 2
x
x
x
x
Sandra Dudley
Eastman Chemical Company
x
x
x
Alexander Dunn
CMA
x
Mike Dunn
Department of the Navy
x
x
x
x
Max Eslambolchi
State of New Jersey
x
Mark Feathers
Radian; US Army
x
Steve Flaniken
Hazen Research, Inc.
x
x
x
Marlae Fry
Society of Plastics Industry
x
Tom Gentile
State of New York
x
Allen Goldhammer
BIO
x
x
x
Paul Goozh
NASA
x
x
x
x
Dennis Griesing
Soap and Detergent Association.
x
x
Ann Gross
NACUBO
x
x
x
x
Roy Hardiman
Genentech, Inc.
x
x
Katherine Hoenke
Chevron/Laboratory Safety Alliance
x
x
x
x
Martha Jordan
API
x
Chuck Knauss
Swidler/Berlin; AAMA
x
Thomas Kovacic
Dow Corning Corporation/CMA
x
x
Amy Kreiger
Swidler/Berlin; AAMA
x
x
Janet McDonald
EC/R, Inc. (EPA Contractor Support)
x
x
x
x
Lou Mikolajczyk
State of New Jersey
x
Gail Murphree
USBI Company
x
x
x
x
Brenda Perkovich
EC/R, Inc. (EPA Contractor Support)
x
x
x
Karna Peters
3M
x
x
Jim Pinto
Department of the Navy
x
Karen Ritter
API
x
Jeneene Sams-Smiley
NASA
x
x
Jim Sell
National Paint & Coatings Association
x
Ellen Siegler
API
x
x
x
Jim Vanderwersf
DuPont
x
Christine Visnic
Pfizer
x
William Wehrum
Latham & Watkins; PhRMA
x
x
x
Rasma Zvanders
CMA
x
x
x
Copyright © 2002 The Campus Consortium for Environmental Excellence | contact_webmaster@c2e2.org