Surface Coating of Miscellaneous Metal Parts and Products

Summary of Second Regulatory Subgroup Conference Call

August 11, 1997

The following meeting summary presents the major issues associated with the Surface Coating of Miscellaneous Metals and Parts (MMPP) source category which were discussed by the state and local agencies represented during the Regulatory Subgroup conference call. The issues listed below are presented in the order in which they were discussed and no presumption of the importance of one issue over another has been imposed.

Preliminary Concerns - The meeting began with a request that state and local agency representatives voice any issues of concern at that time. No concerns were expressed.

Issues Subgroups - There was a discussion on the scope and definition, source size, flexibility, consistency, data collection and alternative questionnaire issue subgroups. A brief description of each subgroup was given. Georgia made a request to be included in one of the issue subgroups at a later date.

Data Collection/Permit File Review - EPA has requested assistance from state agencies in identifying facilities performing surface coating of miscellaneous metal parts and products in their jurisdiction. EPA would like to send contractor staff representatives to the agencies to assist in data collection as opposed to sending a letter to agencies requesting data. A list of states and agencies to be visited has not been formulated.

Definition of MMPP by State - State representatives in attendance were asked how MMPP surface coating is regulated in their perspective states. In Florida , MMPP is regulated as a subcategory of a general surface coating regulation and includes the RACT rule. New York uses a general surface coating rule with a MMPP subcategory. Oklahoma regulates MMPP surface coating based on the amount of VOC in the solvent in a general rule. In Alabama, a general rule also regulates the VOC content of the surface coating and is enforced in 3 counties. Nebraska regulates MMPP surface coating using VOC and HAP rules. Other state representative in attendance gave no response to this question.

Overlap Between MMPP and Cans - Participants discussed the overlap of miscellaneous metal parts with metal cans. Metal crowns and closures are considered miscellaneous metal parts in some states and cans in other states. In Oklahoma, bottle closures are considered miscellaneous metal parts. However, metal drums are not considered cans and therefore, fall under the MMPP category.

Designation of Regulatory Subgroup Chair - Venkata Panchakarla, a representative of the Florida DEP, agreed to chair the Regulatory Subgroup.

Questions /Comments/Concerns - Concerns were expressed on the use of SIC and SCC numbers to obtain information from state agencies. It was suggested that applicable SICs be sent to state agencies ahead of time so that these agencies can search for information in preparation of the data collection trip. Oklahoma has an archive of facilities with active permits and can use a key word database search to access the information. Florida also has a database of facilities than can cross-check SIC and SCC codes.

Representatives wanted to know if railcars and tanker trucks had been included in the MMPP category. Railcars have been included in this category and a site visit to a railcar manufacturing facility in Missouri has been scheduled for September. Tanker trucks would fit in this category but they have not been investigated thus far. Louisiana has a pipeline coating facility that may be of interest as a potential site visit.

Bruce Moore asked state representatives how many HAPs their perspective state has identified. Oklahoma has identified 1,000 different air toxins, including the 187 HAPs listed by the EPA. New York has also identified approximately 1,000 HAPs. West Virginia, Georgia, Alabama, and Florida all recognize only the 187 EPA listed HAPs. Louisiana has identified the EPA listed HAPs and has a supplemental list of additional HAPs. Nebraska recognizes the 187 EPA listed HAPs plus one additional HAP, hydrogen sulfide.

Activities Through Next Meeting - The summaries for the issues subgroup meeting will be sent out with summaries for the Second Stakeholders meeting and the Second Regulatory Subgroup conference call. The definition and purpose of each issue subgroup will be formalized for presentation at the Second Stakeholders meeting. A recap of the issues subgroup meetings will also be presented at this meeting.

Roll Call - A list of the meeting attendees and their associated state/local agencies is enclosed with this summary as Attachment A. Please review this list. If there are any additions or modifications, please notify George Woodall by telephone at (919) 941-0333 or via e-mail at gwoodall @ rtp.pes.com .