Surface Coating of Miscellaneous Metal Parts and Products

Summary of the Stakeholders Kickoff Meeting

June 18, 1997

The following meeting summary presents the major issues associated with the Surface Coating of Miscellaneous Metal Parts and Products (MMPP) source category which were discussed in the group of stakeholders gathered. 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.

The PMACT Process - Linda Herring, EPA's Leader for the Coatings and Consumer Products Group, began the meeting by addressing recent industry concerns about the PMACT process. Ms. Herring assured the industry representatives that the EPA will work with all stakeholders, and is willing to make adjustments to the schedule if the need arises. PMACT should be considered the first phase of MACT development and the main focus is on information gathering and not solely development of a preliminary MACT determination. Data that is obtained during this stage will be utilized in the MACT development process. Attachment A is a copy of a paper by Ms. Herring clarifying the objectives of the PMACT process.

Participants expressed concern over the use of the word "presumptive" in PMACT, and that development of a PMACT emission limitation prematurely could be misused by state and local agencies. They suggest using the word "preliminary" instead.

A related issue is the time frame allotted to the development of PMACT. Industry representatives do not view four months as a reasonable amount of time for establishing a scientifically sound PMACT. It was stated that if the PMACT will establish presumptive emission limitations it must have a substantial basis. Ms. Herring responded that although the PMACT process is required, setting a PMACT emission limitation is not. The EPA will not issue a PMACT in October if there is not sufficient data to do so. The PMACT process, however, will end in October as scheduled.

Concern was raised regarding the use of case-by-case MACT versus the provisions of 112(j) of the Clean Air Act Amendment of 1990 (CAAA). EPA responded that case-by-case MACT and 112(j) would apply to new sources only and would not be used for existing sources.

Development of a CTG versus A National Rule for VOC - Participants voiced concerns about how state regulations may be based upon a Control Technique Guideline (CTG) developed by EPA in conjunction with the MACT versus the establishment of a national rule. Many companies have facilities in several states, and have concerns regarding the different requirements each facility has to meet; competing companies are not always on a level playing field. EPA explained that states enact their own regulations in addition to the Federal standards. A national rule does not preempt state or local regulatory agencies from enacting stricter standards.

Potential Overlaps - Concerns have been raised in previous meetings about the overlap of the MMPP category with other categories (e.g., plastic parts) which may result in differing requirements from processes coating different products but using identical coating materials. The EPA believes that by developing the various surface coating categories concurrently this overlap will be addressed more directly. It was also noted that the existing CTG for MMPP covered things not specifically covered by other rules. The EPA stated that it does not want to burden industry, and is working to avoid the problem of overlapping standards.

Terminology - Bruce Moore, EPA Team Leader for the Miscellaneous Metal Parts and Products project, clarified some of the commonly used terminology for stakeholders. "Work group" is defined as the regulatory team of EPA office representatives involved in the Miscellaneous Metal Parts and Products source category, and those regulatory agency representatives that actively develop the proposed standards. The term "subgroup" will apply to subsets of the stakeholder's group with common interests or organized to more effectively explore specific issues. Subgroups will not necessarily become subcategories to the source category.

MACT Floor Issues - George Woodall, of Pacific Environmental Services, Inc. (PES), discussed some of the issues that will be faced in determining the MACT floor. Participants were concerned as to how the top 12% of facilities will be established. The definition of "major source" is different for HAPs and VOCs and questions as to how this would affect a MACT floor determination were raised. There were also questions as to which data will be used in MACT floor determinations, the actual emission rates or the permitted emission limitations. There was further concern about facilities which have low emissions due to pollution prevention or use of costly add-on controls and may not be considered as major sources under Title V and would thereby be missed in an analysis of strictly major sources.

Progress to Date - Dr. Woodall presented a synopsis of the progress to date on the MMPP project. Several meetings with subgroups have taken place to discuss coating operations in certain industries and to voice other concerns. Meetings with the Truck Manufacturers Association, the Aluminum Extruders Council, magnet wire coaters, an automotive association, and regulatory and small business stakeholders took place. The summaries from those meetings were provided with the kickoff meeting materials.

The project teams for both MMPP and the plastic parts source categories have also visited the Volvo facility in Dublin, Virginia and the Freightliner facilities in Cleveland and Mount Holly, North Carolina. Additional site visits are being planned for other types of facilities, including a magnet wire coating line and a rail car facility.

Participants discussed the process of identifying facilities that will be subject to the MACT standards. The EPA is using the AIRS and TRI databases to obtain information about facilities. Facilities will be tentatively identified through AIRS, then cross referenced with TRI to obtain HAP emissions information (the AIRS database does not store HAP emissions data). This approach will provide a rough sketch of the industry. Concern was raised over the AIRS information being outdated. The State of Florida has developed its own database which is more up to date, and these findings were offered for analysis. The EPA will also be sending a letter to the states requesting information on applicable facilities.

A regulatory review has been rendered to provide comparison of the surface coating regulations between states and a summary table from that review was also included in the meeting materials. The EPA is also working on a comprehensive set of definitions that would apply to all eight surface coating categories. These definitions are being drafted from state regulations, CTG documents, and other sources.

Two sets of questionnaires are currently being developed: one for use with site visits, and another that will be sent under Section 114 authority as an alternative to the generic ICR already approved by OMB. This second questionnaire will be developed in later stakeholder meetings for dispersal sometime after the end of October.

Participants initiated a discussion about the subcategorization issue. The EPA has not recognized any groups as subcategories to date, the subgroups that have been identified are stakeholders and associations that have approached the EPA with their special concerns. Participants stated that there are numerous other groups that could have an interest and should be contacted. EPA stated that any inquiries regarding additional subgroups are welcome.

Activities through the Next Meeting - In addition to the generic Information Collection Request (ICR) that will be sent out under Section 114, the EPA will also be developing an alternative questionnaire that is tailored to specific industry categories. Facilities will have the option of choosing which questionnaire to answer. Copies of the generic ICR were included in the April Workshop notebook. Rough drafts of the alternative questionnaire will be sent out for review by industry before the next meeting. Fin Johnson, of the NC Small Business Ombudsman Office, stated that many states have conducted inventories of HAPs and suggested the possibility that facilities may submit these instead of completing the questionnaire, thereby reducing reporting burdens on smaller facilities.

Participants discussed the target dates for subsequent meetings. The next meeting will be held during the first week in August in conjunction with the Plastic Parts Stakeholders group at the EPA Environmental Research Center Building in Research Triangle Park, NC. Additional meetings were tentatively scheduled for mid-September and the end of October. Further details will be announced in a few weeks.

Issues Subgroups - During the discussions that took place during the morning session of the meeting, issues were noted for further discussion. At the end of the morning session, these issues were consolidated into a list of six main issues that served as the agenda for the afternoon session. Participants were asked to identify issues in which they were interested and form issues subgroups that would report back at the next stakeholders meeting.

A synopsis of the discussions on each issue is presented below.

Scope/Definition - Participants examined both the diversity and commonality among the
industries included in the MMPP source category. In order to begin discussing these	issues, the method for defining the source category and what is included in it was
examined. Several approaches were presented for categorizing the various industries:

-	By coating application method or process;

-	By Materials/Technologies; and

-	By coating types.

Attachment B presents a tabular summary of the subdivisions mentioned in these
discussions.

Source Size - This Issue Subgroup will look at major source facilities versus major source	processes; minor source facilities versus major processes; other agency area source	programs and strategies; and the inclusion of small business.

Data Collection - One of the main issues of data collection is determination of the
baseline year. Participants questioned whether the baseline would be set for the
whole category, by subcategory, or by facility. There was discussion regarding the	inclusion of prior emission reductions when choosing the baseline. It was stated
that the Aerospace MACT allowed for some facility-based regulation. The issue
of actual versus permitted emission rates will be analyzed during the review of
Title V/Installation permits, permits by rule, emission limitations, and others.
Although all states do not currently have Title V permit programs in place,
they should before this rule is promulgated. However, it was stated that many
facilities have permitted emissions that are well above their actual emission
rates. It was recommended that there should be distinguishment between actual
emission rates and permitted emissions limitations when this data is analyzed.
The issue raised earlier as to how the top 12% of the industry will be defined was
also discussed further.

Alternative Questionnaire & ICR - The EPA stated that a generic ICR approved by
the OMB will be sent out with a Section 114 letter. In addition, there will be an
alternative questionnaire which will be more industry specific. These materials are	scheduled to be sent out after the October end of the PMACT process. Participants in this	issues subgroup were asked to look at alternatives to the questionnaire (such as emissions	or permits) the ICR schedule, and the scope of requested information. Discussion	digressed to a recent ICR that allowed for only three weeks response time. Participants	were concerned that facilities need to be given ample time to gather the requested	information.

Flexibility of Regulations - Participants would like to see some flexibility in regulations
to allow for innovation in technology.

Consistency - A resounding concern of industry is the consistency among rules,
specifically in the areas of record keeping and reporting. The EPA stated that the eight	surface coating source categories are working closely together to ensure compatibility.

Roll Call - A list of the meeting attendees and their associated organizations/companies is enclosed with this summary as Attachment C. This list also indicates which issues subgroups the attendees have agreed to participate in. Please review the list of attendees and if there are any additions or modifications notify George Woodall at (919) 941-0333 or via e-mail at gwoodall@rtp.pes.com.

Attachment A

July 1997

DEVELOPMENT OF INDUSTRIAL SURFACE COATING REGULATIONS

The Coatings and Consumer Products Group (CCPG) of the Environmental Protection Agency (EPA) is currently engaged in development of regulations for a number of categories of industrial surface coating operations. Work on eight of those categories1 began with a Coating Regulations Workshop for representatives from EPA and interested stakeholders in April 1997 and continues as a coordinated effort to help promote consistency and joint resolution of issues common across these categories. The regulations under development are national emission standards for hazardous air pollutants (HAP) under Section 112 of the Clean Air Act (commonly called MACT standards) for each of the eight categories, and national volatile organic compound (VOC) rules or control techniques guidelines under Section 183(e) of the Act for five of the eight categories2.

The first phase of the regulatory development effort is one in which readily available information and data about the industry are collected by EPA with the help of representatives from State and local air pollution control agencies, the regulated industry, and environmental groups. There are two primary objectives for this first phase: (1) to learn as much as possible about the industry in a short time frame and engage stakeholders in identification of issues and data needed for regulatory development, and (2) to identify a "rough draft" of MACT, if possible, for sources and States to use as needed for case-by-case MACT determinations. "Presumptive MACT" or "PMACT" was the term coined for this "rough draft" of MACT by EPA when this phase of regulatory development was adopted as part of the process to be followed for MACT standards. For sources and States faced with making case-by-case determinations of MACT for new and reconstructed major sources due to the requirements of Section 112(g) of the Clean Air Act, PMACTs could serve as useful starting points.

For the industrial surface coating categories, the first phase of the regulatory development process is scheduled to end in late 1997 after several months of collecting data and information through meetings; site visits; telephone contacts; limited surveys; review of State records, regulations, and permits; review of various databases and publications; and other means. At the end of this phase, we hope to have achieved a number of goals, including the following, either fully or partially:

- Understand the coating processes

- Identify typical emission points and the relative emissions from each

- Identify the range of emission reduction techniques and their effectiveness

- Make an initial determination on the scope of each category

- Determine the relationships and overlaps of categories

- Locate as many facilities as possible, particularly major sources

- Identify and involve representatives for each industry segment

- Complete informational site visits

- Identify issues and data needs and develop plan for addressing

- Develop questionnaire(s) for additional data gathering

- Document results of first phase of regulatory development for each category, including PMACT, as appropriate

The documentation of the results of the first phase of regulatory development will include summaries of the data and information obtained as well as the plan to be followed for the remainder of the regulatory development process. The first phase documentation will serve as a type of status report of where we are in the process and where we need to go. It will be helpful in focusing efforts appropriately to resolve issues and obtain additional data. Finally, it will provide useful information on the industry, emissions and emission control techniques, and the differences and similarities among processes that may affect the choice of control requirements for anyone who must make a case-by-case MACT determination.

The documentation for each category might, or might not, contain a preliminary emission limitation/control strategy for PMACT. PMACT will be included if there is general agreement among the EPA and stakeholder representatives that it is an appropriate resource to make available for case-by-case MACT determinations and that there is adequate technical support for it. However, as the name implies ("presumptive" MACT), PMACT is not necessarily MACT and is not expected to have the same level of supporting data and information as MACT.

For the coating categories, PMACT determinations will not be attempted for existing sources or for segments of the industry that may require more extensive study and investigation than others to establish PMACT, such as those that traditionally have not been included in the source categories. The first phase documentation will summarize the knowledge gained about these industry segments and the additional information that will be needed before any recommendations concerning emission control requirements can be made. It will also summarize information on existing sources and discuss unique challenges they may have in controlling emissions that may not apply to new sources (i.e., retrofit considerations).

Once this first phase of the regulatory development process is completed, EPA will continue to build on the knowledge gained and proceed with more focused investigation and data analysis. We hope that most of the data gathering will be completed by the end of 1998 so that MACT floors and regulatory options can be determined and analysis of impacts conducted in early 1999. At that point, decisions will be made on the form and content of the proposed regulations, and the regulatory packages will be prepared for management reviews and approvals. The projected date for proposal of the rules is by the end of 1999 with promulgation by the end of 2000.

Throughout the entire regulatory development process for the proposed rules, coordination with stakeholders will be a high priority. Also, emphasis will be placed on maintaining consistency among the rules and coordinating activities to address cross- cutting issues and concerns (those that apply to more than one category). The first phase of the process has already proven useful in identifying some of these issues and concerns, and more are expected to surface before it ends. As they are identified, the EPA and stakeholder representatives need to work together to appropriately characterize and prioritize them and develop plans for addressing them. Some may be resolved during the first phase while others may require more long-term efforts. We hope that the participatory process we are engaged in with the stakeholders will produce rules that maximize environmental benefits while minimizing regulatory burdens on all concerned.

Attachment B. Approach to Scope of the MMPP Source Category

Approach	Subdivisions
Application process	Supercritical fluid

Electro deposition

Conventional Spray

Electrostatic

Airless

Air-assisted Airless

HVLP

Dip

Roll

Brush

Flow Coat

Curtain

Fluidized Bed

Aerosol
Material/Technologies	Powder

Solvent-borne

Water-borne

Radiation-cured

Multi-component

Solvent-free
Coating Type	Surface Preparation

-pretreatment

-conversion coating

-precleaning

Undercoating

-primers

-primer sealers

Top Coats

-single stage/mono coat

-multi coats

-direct-to-metal

-base/clear coat

Attachment C. List of Attendees

NAME	AFFILIATION AND ADDRESS	PHONE/FAX	E-MAIL	ISSUES SUBGROUPS
Allerton, Dave	Reichhold Chemicals

PO Box 13582

RTP, NC 27709	919-990-8066

919-990-8218F	dave.allerton@reichhold.com
Berry, Jim	Berry Environmental

(Representing ASTM)

PO Box 20634

Raleigh, NC 27619	919-785-9631

919-785-9631F	jimberryec@aol.com
Bracey, Alan	Vulcraft

PO Box 100520

Florence, SC 29501	803-662-0381

803-679-3097F	F
Bradley, Cheryl	Oklahoma DEQ
Broome, Shannon	GE, Corporate

Environmental Programs

3135 Easton Turnpike W1B

Fairfield, CT 06431	203-373-3575

203-373-3389F	shannon.broome@corporate.ge.com	AQ, DC
Bryant, Chris	Air Pollution Control

District of Jefferson County

(STAPPA - ALAPCO Rep)

Louisville, KY 40204	502-574-6000

502-574-5306F
Cannon, Dick	Jones Blair Company

2527 Empire Central

PO Box 35286

Dallas, TX 75235	214-353-1686

214-353-1684F or

214-350-7624F	CACardou@lanmail.rmc.com	S/D
Cardounel, Carlos	Reynolds Metal Company

6601 W Broad St

Richmond, VA 23230	804-281-4387

804-281-3745F	AQ, DC
Cash, Douglas	Nebraska DEQ

Suite 400, The Atrium

1200 N Street

PO Box 98922

Lincoln, NE 68509	402-471-8414

402-471 -2909F
Clark, Lorraine	Dept. of Environmental Protection

2600 Blair Stone Rd.

Tallahassee, FL 32399	904-488-1344

904-922-6979F
Drucker, Kirk
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 485

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	DC, SS
Gans, Alan	U.S. Can Company

1125 Gasket Dr.

Elgin, IL 60120	847-888-5538

847-888-5649F
Harding, Madelyn	Sherwin Williams

101 Prospect Ave. NW

Cleveland, OH 44115	216-566-2630

216-566-2730F	mkharding@sherwin.com	F, S/D
Herring, Linda	EPA/CCPG	919-541-5358

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

1450 G Street, NW

Washington, DC 20005	202-879-7644

202-737-2832F	kwholman@jonesday.com
Hopkins, Peg	Geomatrix Consultants

7233 Mast Rd.

Dexter, MI 48130	313-426-0999

313-426-0214F	DC
Horton, Mike	US Pipe & Foundry

PO Box 10406

Birmingham, AL 35173	205-254-7964

205-254-7967F	S/D
Horvath, Stanley	DuPont

950 Stephenson Hwy.

Box 7013

Troy, MI 48007	248-583-8037

248-583-4555F	horvatsk@a1.spoc.umc.dupont.com	AQ, C, F, DC, S/D, SS
Johnson, Fin	NC Small Business (NSBO/SBAP)

PO Box 29583

Raleigh, NC 27626	919-733-0824

919-715-6794F	Fin_Johnson@owr.ehnr.state.nc.us
Karwowski, Robert J.	Whirlpool Corp.

2000 M-63

Benton Harbor, MI 49022	616-923-3614

616-923-5486F	Robert_J_Karwowski@email.whirlpool.com
Kent, Chris	EPA Pollution Prevention Div.
Kinsley, Timothy	Alumax Extrusions Inc.

2700 International Dr., Suite 200

West Chicago, IL 60185	630-584-1000

630-584-1243F
Koman, Patricia	EPA/CCPG	919-541-5170

919-541-5689F	koman.patricia@epamail.epa.gov
Koppenhaver, Randy	Pennsylvania DEP	717-787-9257	KOPPENHAVER.RANDY@a1.pader.gov
Kruzer, Marc	Sherwin Williams

101 Prospect Ave. NW

Cleveland, OH 44115	216-566-6546

216-566-2508F	mskruzer@sherwin.com	DC, S/D
Landeis, Kelvin	Valspar Corp. (CDOA)

1647 English Road

PO Box 2170

High Point, NC 27262	910-887-4666

910-887-4688F
Lasher, Leigh	PES	910-941-0333

919-941-0234F	llasher@rtp.pes.com
Lilly, Michele	Reichhold Chemicals

2400 Ellis Rd.

Durham, NC 27709	919-990-7823

919-990-7703F	michelle.lilly@reichhold.com
Mazzocco, Dave	PPG Industries, Inc.

4325 Rosanna Dr.

PO Box 2009

Allison Park, PA 15101	412-492-5476

412-492-5377F	mazzocco@ppg.com	AQ, C, DC, S/D, SS
McDaniel, Tim	Navistar (TMA)

6125 Urbana Road

Springfield, OH 45502	937-390-4024

937-390-4501F	twm3@navistar.com
Medberry, Arnold	EPA Off. of Small Business

OMBUDSMAN
Moore, Bruce	EPA/CCPG	919-541-5460

919-541-5689F	moore.bruce@epamail.epa.gov
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-Phillippe_Monfet@canammanac.com
Munsey, Elizabeth	Georgia Air Protection Division	404-363-7100

404-363-7113F
Nelson, Bob	National Paint & Coatings Assoc.

1500 Rhode Island Ave. N.W.

Washington, DC 20005	202-462-6272

202-462-8549F	AQ, C, F, DC, S/D, SS
Patton, John	State of TN/APC

9th FI, L&C Annex

401 Church St.

Nashville, TN 37243	615-532-0604

615-532-0614F
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	C, DC
Praschan, Gene	AAMA

1000 Park Forty Plaza Suite 300

Durham, NC 27713	919-547-7100

919-547-7102F	praschea+adet01%7332724@moimail.com	AQ, C, F, DC, S/D, SS
Randle, Margaret	Amoco

One Prudential Plaza

30 E. Randolph Dr.

Chicago, IL 60601	312-856-5265

312-616-0529F	mhrandle@amoco
Ross, Alex	Rad Tech

400 N. Cherry St.

Falls Church, VA 22046	703-534-9313

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

25 Atlantic Ave.

Erlanger, KY 41018	606-746-4121

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

1400 N. Woodward Ave.

Bloomfield Hills, MI 48304	248-645-1483

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

1250 Eye St., NW

Washington, DC 20005	202-371-8401

202-371-8471F	glynn@aia-aerospace.org
Schultz, Karl	DuPont Automotive

Barley Mill Plaza 21-1108

PO Box 80021

Wilmington, DE 19880	302-992-2373

302-892-1143F	AQ, C, F, DC, S/D, SS
Serne, Jim	TRC Environmental Corp. (TMA)

6340 Quadrangle Dr., Suite 200

Chapel Hill, NC 27514	919-419-7591

919-419-7501F	AQ, DC
Snell, Terry D.	The William L. Bonnell Company, Inc.

25 Bonnell St., PO Box 428

Newnan, GA 30264	770-254-7690

770-254-7717F	tdsnell@mindspring.com	C
Sonntag, William	AESF/NAMF/MFSA

2600 Virginia Ave. NW #408

Washington, DC 20037	202-965-5190

202-965-4037F	wasdc@erols.com	S/D, SS
Strabbing, Patty	Chrysler

800 Chrysler Dr. East

Auburn Hills, MI 48326	248-576-5494

248-576-7928F	pas2@chrysler.com
Takas, Tim	Reichhold Chemicals

2400 Ellis Rd.

Durham, NC 27709	919-990-7977

919-990-8218F	tim.takas@reichhold.com	S/D
Teal, Kim	EPA/CCPG	919-541-5580

919-541-5689F	teal.kim@epamail.epa.gov
Thompson, Tamara	Virginia DEP	804-698-4502
Vizzi, Tara	AIAM

1001 N. 19th St., Suite 1200

Arlington, VA 22209	703-525-7788

703-525-8817F	tvizzi@aiam.org	AQ, C, F, DC, S/D, SS
Wehrum, Bill	Swidler & Berlin (AAMA)

3000 K St., NW, Suite 300

Washington, DC 20007	202-424-7773

202-424-7643F
Willets, William	ENSR/GATX

2700 Wycliff Rd., Suite 300

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

919-571-0688F	wwillets@ensr.com
Williams, Lori	PES	919-941-0333

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

1601 Destruchan Ave. PO Box 816

Harvey, LA 70058	504-347-4321

504-340-1147F	sigmax@compuserve.com	S/D
Woodall, George	PES	919-941-0333

919-941-0234F	gwoodall@rtp.pes.com
Worcester, Dana	Assoc. of Container Reconditioners

8401 Corporate Dr., Suite 140

Landover, MD 20785	301-577-3786

301-577-6476F
Wright, Hal	Oklahoma Permit

Engineer/Environmental Specialist	405-290-8247

405-962-2200F

Key for Issues Subgroups

AQ = Alternative Questionnaire

C = Consistency

F = Flexibility

DC = Data Collection

S/D = Scope/Definition

SS = Source Size