Joint Stakeholder Meeting for

Surface Coating of Miscellaneous Metal Parts and Products

and Surface Coating of Plastic Parts

Meeting Summary - August 13, 1997

1.0	PURPOSE

The following is a summary of the second stakeholders meeting in the MACT and VOC regulation development process for both the surface coating of miscellaneous metal parts and products, and plastic parts. The meeting was conducted jointly due to several overlapping issues between the two source categories and an interest by many stakeholders in both projects. An agenda from the meeting is included as Attachment A.

2.0	PLACE AND DATE

US EPA Environmental Research Center

Alexander Drive

Research Triangle Park, NC

August 13, 1997

9:00 a.m.

3.0	ATTENDEES

The attendees, along with those who participated through a conference call, are listed in Attachment B. Introductions made by attendees indicated that approximately half were interested in both metal and plastic parts surface coating, with the remainder primarily interested in metals, and a few participating for plastics only.

4.0	DISCUSSION

The topics summarized below are presented roughly in the order in which they were discussed and for the most part, follow the agenda established prior to the meeting.

4.1	Status of Projects

4.1.1	Plastic Parts

Ellen Ducey, EPA's team leader for the plastic parts surface coating source category, identified the four sectors that have been developed for this category: automotive, heavy duty truck, business machines, and miscellaneous, listing some examples of the industries and businesses that would fall under each. A suggestion was made that the aerospace industry be listed under the miscellaneous sector, as various plastic parts (luggage racks, trays, etc.) may be coated for installation within aircraft and would not be covered under the aerospace MACT. Ms. Ducey explained that the identification of facilities in these sectors is being conducted through contact with state agencies and trade associations, as well as searches of Internet sites and EPA databases. Data collection is currently being conducted through site visits, reviews of technical literature, state regulations, and Title V permits and applications, in addition to Internet site searches. She also stated that site visits in the heavy duty truck category have been completed, while visits to business machine, automotive, and miscellaneous industries will be conducted in the future.

Ms. Ducey then listed the states in which an initial Title V application collection has been conducted. A question arose as to how these states were picked. Joan McLean of the Eastern Research Group, Inc. (ERG), explained that several were identified as having a large number of coating industries by performing searches within EPA databases using SIC codes and source category codes (SCC). Others were chosen due to their proximity to North Carolina which will facilitate permit retrieval and review, as well as future site visits.

4.1.2	Miscellaneous Metals

Bruce Moore, EPA's team leader for the miscellaneous metal parts and products surface coating source category, explained the role of subgroups within this category and described the focus of each of the established subgroups. Six issue subgroups were formed during the first stakeholders meeting: Scope and Definition, Source Size, Data Collection, Alternate Questionnaire, Flexibility, and Consistency. Following the initial conference call meetings, reorganization of these issue subgroups left four: Scope, Coatings Technology, Source Size, and Data Collection. The issue subgroups for flexibility and consistency were dropped since these are issues that will be given consideration throughout the process. Two other subgroups, Regulatory and Small Business, are to convene at a later date.

Concern was raised by industry participants about the Flexibility subgroup having been eliminated. This is an important issue because there are many varying technologies currently used in the coatings industry, as well additional technologies that may be developed in the future. It was agreed that the need to allow for innovative technologies must be continually recognized in the regulatory process. Mr. Moore noted that, although the Flexibility and Consistency subgroups have been eliminated, these topics will be continuously addressed throughout the MACT development process due to their importance. In addition, one of the participants in the discussion of these issues during the conference calls volunteered to draft a list of "guiding principles" to consider for the entire project. Mr. Moore also added that technological flexibility and differences between coating lines are topics which should be covered by the Coatings Technology subgroup.

Mr. Moore then presented a summary of both past and planned site visits. Concern was raised by a participant that small businesses may not be receiving equal representation in the process because so many large companies are involved. In addition, a question was raised as to how site visit locations are chosen, and whether selection is based on processes and technology. It was noted that the Small Business issue subgroup should be very instrumental in ensuring that the needs of smaller businesses and industries are met during this process. There was also a concern as to whether different technologies have been observed to date or would be during future site visits. It was agreed that a representative mix of technologies should be covered by the visits. Mr. Moore indicated that spray, low bake, and high bake have been seen so far. He further stated that if there is not a complete sampling of all the different types of coating technologies during the visits, it will not hinder the MACT development process, because regulations are not solely based on these site visits. Significant data and information are also gathered from Section 114 questionnaires. Also, the data collection process runs through December 1998, so the end of the PMACT process does not signal an end to data gathering. A suggestion was then made that trade associations be notified prior to site visits within a particular industry sector so that they may be involved as well.

A powder coating technologies show was also announced. This show will be held in Charlotte, NC on October 7-9, 1997. Two facilities which use powder coating methods will be toured as a part of this event. The show will provide an excellent opportunity to learn more about this method of surface coating and to visit sites where it is utilized.

4.2	Establishing the MACT Floor

During Mr. Moore's status update, questions were raised concerning how EPA establishes a MACT floor and what type of information is utilized to do so. Mr. Moore stated that this topic had been discussed previously within the metal parts stakeholders group, and that EPA has no predetermined policy on exactly how to set a MACT floor. EPA does follow internal policy guidance compiled within the Emissions Standards Division (ESD). This policy guidance helps in the development process, but the compilation itself is not shared outside of the ESD. Linda Herring, EPA leader for the coating and consumer products group, added that this policy is a means by which the different MACT projects update each other on the status of regulatory development and not a set of rules on how to conduct the process. Someone also raised a concern about data collection leading the MACT floor development process, saying that often how and what type of data are collected can influence the standards that are set. It was agreed that at this point focus should be placed on data collection, so that a good evaluation can be made as to what information needs to be gathered to support MACT floor determination.

4.3	Scope and Definition of Categories

4.3.1	Plastic Parts

Joan McLean briefly summarized the status of the information gathering process for each of the four sectors within the plastic parts category. At this point in the process, the automotive sector is well represented and characterized, but further information may be needed for other types of mobile equipment. Both interior and exterior plastic parts are coated. The heavy duty truck sector is also well represented and characterized. Ms. McLean stated that this sector is basically concerned with exterior parts. A point was made that it should not be listed as exclusively exterior, because there is likely some interior coating included, and if not now, possibly in the future. Ms. McLean went on to say that there exists a moderate representation for business machines, with additional contacts currently being made. The sector is well characterized through the Alternative Control Techniques (ACT) document and the New Source Performance Standard (NSPS). Miscellaneous parts is lightly represented in the process, while more contacts are needed for a thorough representation. A problem arises because the sector is so diverse and includes many small businesses, toll coaters, specialty coaters, and job shops. As such, this sector is not well characterized. A point was raised that there are probably many large industry groups within the miscellaneous sector, that in combination, will comprise a large portion of the emissions. Thus, miscellaneous should be recognized as a significant sector and an effort should be made to break it down so that it may be better characterized, rather than referring to it as "miscellaneous". Another suggestion was made that plastic building products, such as windows, moldings, and doors should be included as a significant group within the miscellaneous sector.

Another question was asked as to whether these sectors will eventually become subgroups for source categorization later in the process. Ms. McLean stated that this was not necessarily the case and that these were chosen to initially facilitate the data collection process. A second question was raised concerning the final rules and whether or not they will apply only to major sources, or area sources as well, and how this would effect the questionnaire process. Ms. McLean pointed out that the information gathering process is for both the MACT standard and regulatory development under Section 183(e). VOC data collection must cover all sources, because they will all be affected under 183(e). A suggestion was then made that the questionnaires have separate sections for HAP and VOC information, easing the burden for sources having to complete information for VOC only.

4.3.2	Miscellaneous Metals

George Woodall of Pacific Environmental Services, Inc. (PES), presented an initial list of industry sectors to be considered under the miscellaneous metal parts and products category. He stated that the list was not all-inclusive, but simply an attempt to begin breaking down the various segments. Questions were raised as to why magnet wire was the only wire category represented on the list of industry sectors for miscellaneous metal parts and products. The explanation was that magnet wire is the only wire not covered with plastic extrusion, and therefore is the only wire not covered by another source category. A suggestion was made that limiting terms, specifically "magnet" describing wire, not be used in defining source category industry sectors so as not to exclude similar industries. It was agreed that the term "magnet" would be dropped. Another question was brought up concerning the difference between large and small appliances and the cutoff between the two. Bruce Moore explained that large appliances will be regulated as a distinct source category but it has not yet been determined what the exact cutoff is.

Someone else then asked if a coating is defined as just paint or if it also includes adhesives. Ms. Ducey responded that adhesives are included, because we are dealing with any type of coating and the EPA considers adhesives to be coatings. There is confusion around this issue, because some MACT standards define adhesives as coatings, whereas others treat them separately. In addition, it was pointed out that adhesives suppliers should be included in the process, since facilities do not have much information about VOC and HAP emissions from adhesives nor the ability to reformulate.

Participants also raised concerns about creating "catch-all" categories, generally called miscellaneous, which imply that those industries not covered by other rules are to be included. The use of "catch-all" categories can lead to applicability questions and uncertainties. It was suggested that a better method might be to specifically list and define all the processes included under miscellaneous metal parts regulations. If some are excluded in the listing process, they could be added later. Bruce Moore did not believe that it would be feasible to identify all the processes that are covered in source categories that include a "miscellaneous" component.

Dr. Woodall then discussed the data collection process, permit reviews, and questionnaire development. State agencies will be contacted to determine which permits will be most useful to the data gathering process. A point was raised that EPA should not limit the collection of information from state agencies to those that are located in close proximity to North Carolina. It was agreed that the permit data collection will occur in state agencies all across the country, and from the site visits as well. It was mentioned that SIC codes will probably not be useful in determining which permits should be reviewed, since facilities often operate under numerous SIC codes. The most efficient method will be to work with state agencies to obtain the permits needed. EPA will be sending contractor staff representatives to the state agencies to gather this information.

Concerns were again raised about the type of data that will be collected, how it will be used to set standards, and how innovative technologies will be treated. A comment was also made about the handling of data from synthetic minor sources. Participants pointed out that these sources have deliberately taken permit limits so as not be considered major sources. However, if these sources are included in the MACT floor determination, they may in fact be penalized for taking proactive steps to reduce emissions. Therefore, participants want to know whether emissions data from these sites will or will not be included in the floor determination. EPA agreed that the treatment of synthetic minor sources is an important issue and noted that it is being evaluated for all of the coating MACT standards.

4.4	Coatings and Application Technology

Dr. Woodall conducted a discussion of the CAGE (Coating Alternatives Guide) website. The Internet address for this site is included on the agenda, Attachment A. He began by saying that the site will be used to facilitate the information gathering process, as it provides an initial framework by which the various types of coatings technologies and processes may be organized, but will certainly not be used as the sole source of such information. A point was raised that much of the information within CAGE is outdated or inaccurate. Again, Dr. Woodall stated that this is just one of many sources of information to be considered and asked that participants inform him of gaps in technology or inaccuracies within CAGE. Another participant suggested that a multi-component category be added to the CAGE list of solvent-borne systems, which only included one and two component coatings. Dr. Woodall also spoke of an additional source which may be used to facilitate the information gathering process concerning coating technologies, entitled Corrosion Prevention by Protective Coatings authored by Charles G. Munger for the National Association of Corrosion Engineers (see Attachment C for reference information and a table of contents). A participant then mentioned another document which may be useful as well, entitled Pollution Prevention in the Coatings Industry out of EPA's Office of Pollution Prevention and Toxics. Dr. Woodall asked that other resources which discuss coatings technologies be brought to the attention of the group at any time. All interested parties should contact Dave Salman by telephone at (919) 541-0589 or via e-mail at

salman.dave@epamail.epa.gov.

4.5	New Surface Coating Source Category - Auto and Light Duty Truck

Dave Salman, EPA's team leader for the auto and light duty truck source category, explained that this is the ninth coating category for which MACT and/or Section 183(e) standards are currently being developed at EPA. The category covers coating operations at auto and light duty truck assembly plants, such as surface priming and topcoating of body panels. EPA's contractor for the project is the Research Triangle Institute (RTI). An initial stakeholder meeting is scheduled for September 16, 1997 at the US EPA Administrative Building in Research Triangle Park. Organizational and substantive issues are to be discussed. One of the most important issues to be covered is how this category will relate to or overlap with the plastic parts and miscellaneous metals categories. The American Automobile Manufacturers Association (AAMA), the Association of International Automobile Manufacturers (AIAM), the National Paint and Coatings Association (NPCA), and the Chemical Manufacturers Association (CMA) have been notified.

4.6	A Coatings System Approach to Data Collection

Ellen Ducey described how data would be collected using a coatings system approach, which considers all the coatings applied to a particular part as a system, thus addressing coating compatibility issues. A suggestion was made that when discussing compatibility issues, energy consumption, productivity considerations (such as drying time), and equipment costs should also be included, because they too drive the types of coating technologies used. It was also discussed that questionnaires may be sent to both coating users and coating manufacturers to obtain a more complete picture of compatibility issues, performance requirements, and coating formulations.

4.7	Questionnaire Development

George Woodall discussed the types of information that will be collected with questionnaires. Dr. Woodall noted that the questionnaire will collect information on a variety of control strategies, primarily coating contents and add-on controls. It was pointed out that permits and other information from state agencies will not give information on all types of control strategies, and that the questionnaire is an essential data gathering tool. It was also stated that the stakeholders will be able to review a draft questionnaire when it is prepared, possibly in early October.

Concerns were raised about the time needed to complete a survey. If the questionnaire contains multiple sections, some facilities may need a longer time than others to complete it. There is also the problem of mailroom delays, however, the use of certified mail was recommended to curtail this hindrance. In addition, it was mentioned that some of the information requested through a Section 114 questionnaire may not be immediately available at a facility, thus taking more time for completion. There was also some discussion on submitting questionnaires to facilities electronically. It was mentioned that this method has proven to be extremely cumbersome and ineffective in the past, as it is not feasible to select an electronic format that will be compatible with all systems and familiar to every individual who receives it.

It was then mentioned that it will be important to define the source category thoroughly in order to ensure that a complete, representative sample is being obtained. Bruce Moore agreed, but noted that this is difficult to do for the same reasons that miscellaneous categories cannot be fully described. Some small or unique industry sectors may be difficult or impossible to identify. Further, Dr. Woodall explained that all nine coating groups will be working together to create the questionnaire, with the intent that any individual facility will receive only one questionnaire.

Joan McLean then discussed the pros and cons of using Title V permit applications to design and/or respond to the questionnaire. She commented that stakeholders at the first plastic parts meeting thought this method of response would present less of a burden to respondents. But due to the variation in permit applications from state to state, they will be of limited use. Certain portions of a Title V application may be useful, such as process descriptions or drawings, but as a whole it would be an incomplete source of data in comparison to a questionnaire. A question was raised as to what type of information may be requested beyond that which is usually included in a Title V permit application. EPA responded that coatings content and detailed coating process information are primary examples.

A point was raised that speciated coating content will be difficult to pin down with the use of various coatings within a facility, because contents will often vary greatly from line to line, or from season to season. It is believed that it may be hard to speciate HAP emissions, because so many different types of coatings are utilized. There is concern that requests about speciation will require a high level of detailed information for the questionnaire to be completed. A suggestion was made that EPA ask for ranges of speciated content to ease the response burden. Ms. McLean pointed out that when a draft is made available, stakeholders will be able to comment on the reasonableness of data requests.

4.8	Overlapping Issues

Bruce Moore lead a discussion about overlapping issues between the plastic parts and miscellaneous metal parts source categories. He introduced Trish Koman with EPA, who will be working to address and track overlapping issues among all nine coating source categories. Ms. Koman will be creating a whitepaper which explores options to avoid an entanglement of regulations by overlapping MACT standards. A suggestion was made that a meeting of all stakeholders from the nine source category groups be conducted at the conclusion of the PMACT efforts, because so many companies will be subject to numerous MACT coating regulations. In addition, there is a need to address overlaps that may develop between the MACT regulations and the 183(e) rules. Another suggestion was made that attention should be paid to other (i.e. EPA and non-EPA) agency regulations as well, because the use of specific coatings can be mandated by other federal requirements. For example, the Safe Drinking Water Act defines what coatings can be applied to products used with drinking water.

It was then mentioned that plastics can often drive the system when metal and plastic are coated together, because plastic usually has more stringent primer requirements. In some cases, the two substrates need to be treated separately, because they require different coatings. It was also noted that there may be cases where it is more economical to coat plastic and metal separately, because coatings which can be applied to both plastic and metal are generally more expensive. It was also pointed out that there is currently a move towards the development of stronger plastics, so that many coatings for plastics often have metal in them.

4.9	Next Steps in the PMACT Process

4.9.1	Plastic Parts

Ellen Ducey stated that the next plastic parts stakeholder meeting will likely be conducted via conference call. A summary of the data collection process is expected to be available in early October prior to the call, so that these efforts may be discussed.

4.9.2	Miscellaneous Metals

Bruce Moore explained that the next miscellaneous metal parts meeting will probably occur via telephone, as well. Several site visits are scheduled to be conducted in the next two months, and issue subgroup meetings will continue.

4.10	Open Forum

Several issues had been noted throughout the day as needing further discussion or clarification. These are listed as follows, with a summary of the corresponding discussions.

Small business involvement - There is a need to involve more small businesses at this stage in the process. The plastic parts source category is trying to find more of these sources, particularly in the miscellaneous sector. Trade associations and the Internet may be good sources. The miscellaneous metals category is in the process of organizing a small business subgroup which will be meeting to discuss issues in the near future.

Applicability by exclusion for miscellaneous categories - It may be difficult to set a MACT standard based on quantitative and technical information, if the category is not fully defined, creating gaps in who to survey for information. If applicability is defined by exclusion, how can data collection be thoroughly implemented? Also, it is difficult for sources to determine which standards they are subject to when miscellaneous categories are defined by exclusion. An industry representative suggested that, since the Clean Air Act (the Act) requires technology-based MACT standards, each subject process must be fully described and understood in order to set its respective MACT standard. The EPA responded that, historically, standards for miscellaneous sectors have been set based on relevant representative information, and not necessarily on identification of all process variations.

Data requests requiring calculations - There is a concern among participants that some questionnaire elements may require new data generation. Ellen Ducey suggested that discussion about data collection request burdens be postponed until a draft questionnaire is completed and distributed to the stakeholders for comment. At that point, discussion of the reasonableness of information requests would be appropriate.

Permitted vs. actual emissions for MACT floor determination - Bruce Moore pointed out that historically, MACT standards have been based on state regulations, technology-based information, and emissions levels. An industry participant commented that actual emissions may not be suitable for setting standards, because production rates can vary significantly year to year or even season to season, and that permitted rates are often higher, but provide stable numbers. Another participant commented that Section 112 of the Act states that "emissions limitations" must be the basis for setting the MACT floor. Therefore, it was reasoned, actual emissions cannot be used. Linda Herring stated that the Office of General Counsel (OGC) has determined that EPA is not restricted in the Act to using only emissions limitations, in a narrow sense, to set a MACT floor. She suggested that OGC would not object to the use of emissions limitations, but they would not likely limit MACT floor data to emissions limitations only. Ms. Herring continued that if it is determined that permitted emissions levels are representative of the various industries, then it certainly would present a smaller data collection burden and could be used.

Baseline year for data collection - Discussion about a baseline year was initially brought up in the first miscellaneous metals meeting. They discussed the possibility of allowing facilities to either use a default year or choose their own baseline year that is representative of their normal production. It was suggested that respondents could then pick their most representative year and explain why it was used in place of the default baseline. Within the auto industry, there is speculation that they may be penalized for reductions achieved at some of their facilities by having a standard set which is based on those lower emissions. Some industry representatives expressed concern that they may be getting penalized for their earlier good faith efforts.

Coatings formulation confidentiality - It may be difficult for coating users to provide complete coating contents. Much of this information may be confidential. It was suggested that coating manufacturers could, rather than the coaters, provide EPA with formulation information. A representative from the paint industry was concerned that this would be a burdensome information request if it covered all of their products. EPA responded that an effort could be made to require only formulation information on specific coatings, after questioning the users about which coatings are used.

5.0	FURTHER CONTACT INFORMATION

Comments and suggestions concerning future site visits, additional coatings technology resources, industry sectors to be included for better definition of the miscellaneous sectors, or corrections to the attached attendee list should be made via e-mail to George Woodall, gwoodall@rtp.pes.com, or Joan McLean, jmclean@erg.com.

Attachment A

Agenda

Joint Second Stakeholders Meeting

Miscellaneous Metal Parts and Products

and

Plastic Parts Surface Coating

Wednesday, August 13, 1997 from 9 a.m - 4 p.m. (EDT)

Class Room No. 1 at the Environmental Research Center

Research Triangle Park, NC

9:00	Introduction and Meeting Objectives

9:15	Project Status (Progress to date)

•	Subgroup Activities

•	Scope/Definition of Categories

•	Identification of Facilities (Development of a census of facilities)

•	Coatings/Application Technologies

•	Data Collection and Review

•	Site Visits (Completed, Planned, Proposed)

10:15	Break

10:30	Scope/Definition of Categories

•	Industry Sectors to Consider

•	Methods for Developing a Census of Facilities for each Category

10:45	Coatings/Application Technologies

•	The CAGE Web Site (http://cage.rti.org/)

•	Use of the CAGE Hierarchy in Discussing Technologies

11:30	Lunch break

12:30	Data Collection Issues

•	Coating System Approach to Gathering Data

•	Alternate Questionnaire Elements

-	Coatings Content (Issue of questionnaires to coatings manufacturers)

-	Coating line add-on controls, and other control strategies

-	Use of Permits

1:30	Overlap Issues

•	Are Coating Systems Different for Metal and Plastic? How? When?

•	Trends in Industry (Are Some Parts/Products Going from Metal to Plastic; Plastic to Metal)

2:00	Break (if necessary)

2:15	Open Forum (Opportunity to continue discussion of specific issues)

3:45	Next Steps

4:00	Adjourn

NAME	AFFILIATION AND ADDRESS	PHONE/FAX	E-MAIL
Bernheim, Ed	Exxene Corporation

PO Box 8997

Corpus Christi, TX 78468-8997	512-991-8391

512-991-9057F
Berry, Jim	Berry Environmental (Representing ASTM)

PO Box 20634

Raleigh, NC 27619	919-785-9631

919-785-9631F	jimberryec@aol.com
Berry, Kent	Environmental Quality Mgt. Inc.

3325 Durham-Chapel Hill Blvd., Suite 250

Durham, NC 27707-2646	919-489-5299
Blankenship, Bob	Environmental Quality Mgt. Inc.

3959 Electric Rd., SW, Suite 290

Roanoke, VA 24018	540-772-3130

540-772-3142F
Bocchi, Greg	The Powder Coating Institute

2121 Eisenhower Ave., Suite 401

Alexandria, VA 22314	703-684-1770

703-684-1771F	gbocchi@powdercoating.org
Bradley, Cheryl	Oklahoma DEQ - Air Quality Division

4545 N. Lincoln Blvd., Suite 250

Oklahoma City, OK 73105-3483	405-290-8247

405-962-2200F	cheryl.bradley@oklaosf.state.ok.us
Bryant, Chris	Air Pollution Control District of Jefferson County

850 Barret Ave.

Louisville, KY 40204-1745	502-574-6000

502-574-5306F
Bryant, Mike	Eastern Research Group (ERG)

PO Box 2010

Morrisville, NC 27560	919-461-1215

919-461-1418F	mbryant@erg.com
Butt, Kevin	Toyota Motor Mfg. of North America

Mail Code: ENV-NA

25 Atlantic Ave.

Erlanger, KY 41018	606-746-4099

606-746-4002F	kbutt@mail.TMMNA.com
Cannon, Dick	Jones Blair Company

2527 Empire Central

PO Box 35286

Dallas, TX 75235	214-353-1686

214-353-1684F or

214-350-7624F
Cardounel, Carlos	Reynolds Metal Company

6601 W. Broad St.

Richmond, VA 23230	804-281-4387

804-281-3745F	cacardou@lanmail.rmc.com
Cohoon, Barry	William L. Bonnell Company, Inc.

Hwy. 53, Bonnell Rd.

PO Box 279

Carthage, TN 37030	615-683-2267

615-683-2212F
Craner, Francis	NY State DEC - Division of Air Resources

50 Wolf Rd., Room 108

Albany, NY 12233	518-457-7688

518-485-8427F	fxcraner@gw.dec.state.ny.us
Detweiler, Dennis	DuPont

Barley Mill Plaza, Bldg. 21, Rm. 1128

Wilmington, DE 19880	302-892-5702

302-892-1143F
Ducey, Ellen	EPA - Plastic Parts Lead	919-541-5408

919-541-5689F	ducey.ellen@epamail.epa.gov
Ewing, Gary

Nissan Manufacturing Corp.

983 Nissan Dr.

Smyrna, TN 37167	615-459-1633

615-355-2303F	gewing@edge.net
Fedorko, Robert	General Motors Corp.

Argonaut A-205H, 705 W. Milwaukee Ave.

Detroit, MI 48202	313-556-7620

313-556-7629F
Finn, Sharon	BASF

26701 Telegraph Rd.

Southfield, MI 48034	248-948-2000

248-827-2727F	finn@basf.com
Gaylord, Bruce	Air Pollution Control District of Jefferson County

850 Barret Ave.

Louisville, KY 40204-1745	502-574-6000

502-574-5306F
Gemgnani, Greg	New Columbia Joist

Steel Joist Inst.

Prior Coated Metals, Inc.

2233 26th St., SW

Allentown, PA 18103	610-797-5200

610-791-7799F	ggemgnani@enter.net
Godbole, Rani	Phelps Dodge

2600 N. Central Ave.

Phoenix, AZ 85004-3014	602-234-8286

602-234-4846F	rgodbole@phelpd.com
Gross, Neil	Pennsylvania DEP Bureau of Air Quality

PO Box 8468

Harrisburg, PA 17105-8468	717-787-9702	gross.neil@al.dep.state.pa.us
Harding, Madelyn	Sherwin Williams

101 Prospect Ave., NW

Cleveland, OH 44115	216-566-2630

216-566-2730F	mkharding@sherwin.com
Harris, Lynne	The Society of the Plastics Industry

1801 K St., NW, Suite 600K

Washington, DC 20006-1301	202-974-5217

202-296-7006F	lharris@socplas.org
Herring, Linda	EPA - Coating and Consumer Products Group Lead	919-541-7946

919-541-5689F	herring.linda@epamail.epa.go v
Holman, Keith	JDRP Law Firm

1450 G St., NW

Washington, DC 20005	202-879-7644

202-737-2832F	kwholman@jonesday.com
Horton, Mike	US Pipe & Foundry

PO Box 10406

Birmingham, AL 35173	205-254-7964

205-254-7967F
Isaacs, David	Electronic Industries Association

2500 Wilson Blvd.

Arlington, VA 22201	703-907-7576

703-907-7501F	Dissacs@ETA.ORG

Johnson, Fin	NC Small Business (NSBO/SBAP)

PO Box 29583

Raleigh, NC 27626	919-733-0824

919-715-6794F	Fin_Johnson@owr.ehnr.state.n
c.us
Johnston, Matt	Worthington Industries

1205 Dearborn Dr.

Columbus, OH 43085	614-438-7960

614-438-3171F	mfjohnst@wthg.com
Jones, Tim	Vulcraft

PO Box 1000

Saint Joe, IN 46785	219-337-3884

219-337-1801F
Jones, Thomas	Mitsubishi Motor Mfg.

100 N. Mitsubishi Motor Way

Normal, IL 61761-8099	309-888-8780
Jurczyszyn, Robert	Akzo Nobel Coatings Inc.

1845 Maxwell St.

PO Box 7062

Troy, MI 48007-7062	248-637-5203

248-649-3584F	akzobob@aol.com
Kanagy, David L.	Aluminum Extruders Council (AEC)

1000 N. Rand Rd., Suite 214

Wauconda, IL 60084	847-526-2010

847-526-3993F	aec@mc.net
Kersey, Ed	Commercial Metal Company

PO Box 991

Seguin, TX 78516	210-372-8487

210-372-8502F	ekersey@connecti.com
Kosusko, Mike	EPA	919-541-2734

919-541-0359F	mkosusko@engineer.aeerl.epa.gov
Koman, Trish	EPA	919-571-0669

919-571-0688F	koman.trish@epamail.epa.gov
Lacy, Gail	EPA	919-541-5261

919-541-5689F	lacy.gail@epamail.epa.gov
LaLumondier, Richard	National Electrical Manufacturers Assoc. (NEMA)

1300 N. 17th St., Suite 1847

Rosslyn, VA 22200	703-841-3237

703-841-3337F	ric_lalumondier@nema.org
Landeis, Kelvin	Valspar Corp. (CDOA)

1647 English Rd.

PO Box 2170

High Point, NC 27262	910-887-4666

910-887-4688F
Lasher, Leigh	Pacific Environmental Services, Inc.

5001 South Miami Blvd.

PO Box 12077

Research Triangle Park, NC 27709	919-941-0333

919-941-0234F	llasher@rtp.pes.com
Lilly, Amy	Association of International Auto Mfg.

1001 N. 19th St., Suite 1200

Arlington, VA 22209	703-525-7788

703-525-8817F	alilly@aiam.org
Lovelace, John	Indiana Office of Pollution Prevention and Technical Assistance

100 N. Senate Ave.

Indianapolis, IN 46206	317-232-8172
Lutterbach, Mark	Red Spot Paint

PO Box 418

Evansville, IN 47703	812-428-9181

812-428-9167F
McLean, Joan	Eastern Research Group (ERG)

PO Box 2010

Morrisville, NC 27560	919-461-1218

919-461-1418F	jmclean@erg.com
Monfet, Jean-Philippe	The Canam Manac Group

(Representing Steel Joist Institute)

270, chemin du Tremblay

Boucherville (Quebec), Canada J4B 5X9	514-641-4000 (x3573)

514-641-4001F	Jean-Philippe_Monfet@canammanac.com
Moore, Bruce	EPA - Miscellaneous Metal Parts and Products Lead	919-541-5460

919-541-5689F	moore.bruce@epamail.epa.gov
Munsey, Elisabeth	Georgia Air Protection Division

4244 International Parkway, Suite 120

Atlanta, GA 30354	404-363-7000	Elisabeth_Munsey@mail.dnr.state.ga.us
Nelson, Bob	National Paint & Coatings Assoc.

1500 Rhode Island Ave., NW

Washington, DC 20005	202-462-6272

202-462-8549F	bnelson@paint.org
Oppenhiemer, Peter	Bryan Cave

700 13th St., NW, Suite 600

Washington, DC 20005	202-508-6067

202-508-6200F	pho@bryancavellp.com
Panchakarla, Venkata	Florida Dept. Of Environmental Protection

2600 Blair Stone Rd., MS 5500

Tallahasse, FL 32399-2400	904-488-0114

904-922-6979F

Panchakarl_V@dep.state.fl.us
Penna, Dick	VanNess Feldman, Attorneys at Law

1050 Thomas Jefferson St., NW, Suite 700

Washington, DC 20007	202-298-1870

202-338-2416F	rap@vnf.com
Praschan, Gene	AAMA

1000 Park Forty Plaza, Suite 300

Durham, NC 27713	919-547-7100

919-547-7102F
Pugh, Carl	John W. Hancock Jr. Inc.

PO Box 3400

Salem, VA 24153	540-389-0211
Randle, Margaret	Amoco

One Prudential Plaza, 150 E. Randolph Dr.

Chicago, IL 60601	312-856-5265

312-856-0529F	mhrandle@amoco.com
Ronner, Jim	Vulcraft

PO Box 1000

Saint Joe, IN 46785	219-337-1805

219-337-1988F
Ross, Alex	Rad Tech

400 N. Cherry St.

Falls Church, VA 22046	703-534-9313

703-533-1910F	rossradtech@aol.com
Ross, Gary	Toyota Motor Manufacturing

25 Atlantic Ave.

Erlanger, KY 41018	606-746-4121

606-746-4002F	gary_ross@mail.tmmna.com
Ross, Rhonda	Howard & Howard (AAMA)

1400 N. Woodward Ave.

Bloomfield Hills, MI 48304	248-645-1483

248-645-1568F	rlr@howardandhoward.com
Rountree, Glynn	Aerospace Industries Association

1250 Eye St., NW

Washington, DC 20005	202-371-8401

202-371-8471F	glynn@aia-aerospace.org
Salman, Dave	EPA - Auto and Light Duty Truck Lead	919-541-0859

919-541-5689F	salman.dave@epamail.epa.gov
Seamon, Cathie Jo	Ford Motor Company

1 Parkland Blvd., Suite 1400E

Dearborn, MI 48126	313-390-3799

313-248-5030F	cseamon1@ford.com
Serne, Jim	TRC Environmental Corp. (TMA)

6340 Quadrangle Dr., Suite 200

Chapel Hill, NC 27514	919-419-7591

919-419-7501F
Sharma, Moe	Lilly Industries

5400 23rd Ave.

Moline, IL 61265-5040	309-762-7546

309-762-9604F
Shown, Tim	Phelps Dodge

2131 S. Coliseum Blvd.

Ft. Wayne, IN 46803	219-421-5570

219-421-5418F	tshown@phelpsd.com
Sparks, John	EPA OPPT	202-260-1682

202-260-0981F	sparks.john@epamail.epa.gov
Stookey, Sherry	Lilly Industries

PO Box 2358

High Point, NC 27261	910-802-4305

910-899-6007F
Synak, Milan	Freightliner (TMA)

4747 North Channel Ave.

Portland, OR 97217	503-735-8940

503-735-7569F
Takas, Tim	Reichhold Chemicals

2400 Ellis Rd.

Durham, NC 27709	919-990-7500

919-990-8218F	tim.takas@reichhold.com
Teal, Kim	EPA - Miscellaneous Metal Parts and Products	919-541-5580

919-541-5689F	teal.kim@epamail.epa.gov
Tomlinson, Charles	Natural Coating Systems, LLC

970 Conservation Club

Martinsville, IN 46151	812-597-1132

812-597-0312F	ctomlins@scican.net
Torrance, Sharnay	Pacific Environmental Services, Inc.

5001 South Miami Blvd.

PO Box 12077

Research Triangle Park, NC 27709	919-941-0333

919-941-0234F	storranc@rtp.pes.com
Wehrum, Bill	Swidler & Berlin (AAMA)

3000 K St., NW, Suite 300

Washington, DC 20007	202-424-7773

202-424-7643F	wlwehrum@swidlaw.com
Willets, William	ENSR/GATX

2700 Wycliff Rd., Suite 300

Raleigh, NC 27607	919-571-0669 (x224)

919-571-0688F	wwillets@ensr.com
Williams, Lori	Pacific Environmental Services, Inc.

5001 South Miami Blvd.

PO Box 12077

Research Triangle Park, NC 27709	919-941-0333

919-941-0234F	lwilliam@rtp.pes.com
Winkeler, Max	Sigma Coatings (CDOA)

1601 Destruchan Ave.

PO Box 816

Harvey, LA 70058	504-347-4321

504-340-1147F	max.winkeler@fina.com
Woodall, George	Pacific Environmental Services, Inc.

5001 South Miami Blvd.

PO Box 12077

Research Triangle Park, NC 27709	919-941-0333

919-941-0234F	gwoodall@rtp.pes.com
Wright, Hal	Oklahoma DEQ - Air Quality Division

4545 N. Lincoln Blvd., Suite 250

Oklahoma City, OK 73105-3483	405-290-8247

405-962-2200F	hal.wright@oklasof.state.ok.us
Wright, Heather	Eastern Research Group (ERG)

PO Box 2010

Morrisville, NC 27560	919-461-1284

919-461-1418F	hwright@erg.com

Attachment C

Refer to Docket for Handouts