Document wgGmGGXaXMLkoQb2VqZaDNaQB

AmericanCoatings ASSOCIATION" July 27, 2017 Ms. Kaye Whitfield U.S. Environmental Protection Agency (EPA) Office of Air Quality Planning and Standards 109 T.W. Alexander Drive Research Triangle Park, NC 27707 RE: ACA Petition to EPA to Add Compounds to Table 2A of the National Volatile Organic Compound Emission Standards for Aerosol Coatings The American Coatings Association (ACA)1, whose members consist of entities that are regulated under 40 CFR Part 59, Subpart E, hereby petitions US EPA to add several compounds to Table 2A of the National Volatile Organic Compound Emission Standards for Aerosol Coatings. Under 40 CFR 59.511(j), a regulated entity may petition the Administrator to add to EPA's Aerosol Coatings Tables any compounds needed for an aerosol formulation that are not listed in those tables. Petitions must include the "chemical name, CAS number, a statement certifying the intent to use the compound in an aerosol coatings product, and adequate information for the Administrator to evaluate the reactivity of the compound and assign a RF value consistent with the values for the other compounds listed in Table 2k."1 After reviewing EPA's Tables, various aerosol coatings manufacturers subject to EPA's regulations concluded that several compounds are being used by formulators that are not yet on EPA's Tables 2k, 2B, or 2C. It is the intent of industry members and the regulated community to use these compounds in aerosol coatings products moving forward. Furthermore, the reactivity factors of each of the compounds have undergone significant scientific study under the direction of Dr. William P.L. Carter and have been peer reviewed by the scientific community.3 Dr. Carter's reports reflect the most up-to-date scientific research available and are widely accepted. His research is also the basis for California Air Resources Board's (CARB) Aerosol Coatings Regulations, which has also assigned Maximum Incremental Reactivity (MIR) Values to these compounds.4 1The American Coatings Association (ACA) is a voluntary, nonprofit trade association working to advance the needs of the paint and coatings industry and the professionals who work in it. The organization represents paint and coatings manufacturers, raw materials suppliers, distributors, and technical professionals. ACA serves as an advocate and ally for members on legislative, regulatory, and judicial issues, and provides forums for the advancement and promotion of the industry through educational and professional development services. 240 CFR 59.511(j). https://www.ecfr.gov/cgi-bin/textidx?SID=dcbfa03c404c58a04e4ca497cl2dl3a0&mc=true&node=se40.6.59 1511&rgn=div8. 3 Dr. William P.L. Carter's 2009a Report: https://www.arb.ca.gov/research/reactivity/mir09.pdf. Dr. Carter's Investigation of Atmospheric Ozone Impacts of Trans-l-Chloro-3,3,3-Trifluoropropene: lrtt[)^/www;cert;uaTedu/21carte!^|3ubs/ZDErej3y)df. 4Title 17, California Code of Regulations, Division 3, Chapter 1, Subchapter 8.6, Article 1, 94700, et seq. MiP.s://goyLwst!aw.com/^ DDE29EDlDC0A&originationContext=documenttoc&transitionType=Default&contextData=(sc. Default). 901 Mew York Avenue, MW Siete 300 West j Washington, DC 20001 j 202-462-6272 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00082572-00001 Since the reactivity factors of the following compounds have been studied, peer reviewed, and accepted, and these compounds are intended to be used by the regulated community moving forward, ACA petitions US EPA to add them to Table 2A: # Chemical Name CAS No. MIR Value 1 Dipropylene Glycol Monomethyl Ether 34590-94-8 2.70 2 2-Nitropropane 79-46-9 0.11* 3 Dibutyl Phthalate 84-74-2 1.25* 4 Dipropylene Glycol Methyl Ether Acetate Isomers 88917-22-0 1.49 5 n-Pentyl Propionate 624-54-4 0.79 6 Dimethoxy Methane 109-87-5 1.04 7 trans-l,2-Dichloroethene 156-60-5 0.81 8 2-Methyl-l-Butyl Acetate 624-41-9 1.17 9 3-Methyl-Butyl Acetate 123-92-2 1.18 10 Benzyl Alcohol 100-51-6 5.11* 11 trans-l,3,3,3,-tetrafluoropropene (HFO-1234ze) 1645-83-6 0.10** 12 trans-l-chloro-3,3,3-trifluoropropene (HFO-1233zd) 102687-65-0 0.04** 13 2,2,4-trimethyl-l,3-pentanediol diisobutyrate 6846-50-0 0.38* 14 Diethyl Phthalate 84-66-2 1.62* 15 Tert-butyl benzene 98-06-6 1.89 16 2-Ethyl-l,3-hexanediol 94-96-2 2.62 * These five new compounds did not have an MIR Value assigned to them at the time that EPA promulgated its aerosol coatings regulation. Thus, the MIR values listed above derive from Dr. Carter's most recent scientific research. ** Please note that both trans-l,3,3,3,-tetrafluoropropene (HFO-1234ze) and trans-l-chloro-3,3,3-trifluoropropene (HFO-1233zd) are both considered "exempt" from the definition of "volatile organic compound" by EPA because of their negligible photochemical reactivity.5 However, paragraph (s){7) makes it clear that there are no "exempt" compounds in the aerosol coatings regulation. Thank you for your consideration of ACA's petition. Please do not hesitate to contact us if you have any questions or concerns. Sincerely, Rhett Cash Counsel, Government Affairs Raleigh Davis Assistant Director, Environmental Health and Safety 540 CFR 51,100(s)(l). https://www.ecfr.gov/cgi-bin/textidx?SID=4b2f372b38103583387646807020fcl8&mc=true&node=se40.2.51 1100&rgn=div8. 2 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00082572-00002