Surface Coating of Miscellaneous Metal Parts and Products

Summary of the Issue Subgroup Conference Calls

August 6, 1997

The following summary presents the major issues associated with the Scope and Definition, Source Size, and Flexibility Issue Subgroups of the Miscellaneous Metal Parts and Products Surface Coating category. The issues listed below are presented in the order in which they were discussed; no presumption of the importance of one issue over another was imposed.

Scope & Definition

Bruce Moore, EPA Project Lead, began the conference call by addressing the need to divide the Scope and Definition Issue Subgroup into two separate categories. The new categories will be: 1) Scope and 2) Coating Materials and Processes. The purpose of the Scope Subgroup is to assist in the process of defining the industry sectors that compose this source category and in the compilation of a census of facilities that fall within that scope. The purpose of the Coating Technologies Subgroup is to help define the coating processes and materials currently in use with Miscellaneous Metal Parts and Products, and to help EPA understand how coating systems (combinations of application methods and materials) are developed. The members of the automotive trade association offered to nominate a Chairperson for the Scope Subgroup. NPCA offered to nominate a Subgroup Chairperson for the Coating Technologies Subgroup.

Participants were asked to submit ideas for methods of identifying sources applicable to the category. Recommendations were to look at SIC Codes or to define sources by the types of parts/products they coat. John Sparks, of the US EPA OPPT, volunteered to develop a matrix of segments of the category. It was further suggested that the EPA should look at what each state has permitted as Miscellaneous Metal Parts and Products. EPA responded that it has been looking into sending representatives to the states to gather this type of information.

EPA discussed the use of the CAGE website to obtain information on coatings and technology. The site can be accessed at http:\\cage.rti.org. Participants were concerned with the references used to establish the information on the website. EPA responded that it wants to look at the structure of CAGE only as a framework to look at different technologies. The reference "Coating Technology" by Charles Munger was also recommended as a good handbook for coatings and application techniques.

Source Size

In the Stakeholders Kickoff meeting participants voiced concerns about how source size would be used in the determination of the MACT floor, and to assess the impact on small business. EPA stated that even though a facility is not a major source it should not necessarily be eliminated from being assessed for determination of the MACT floor. A source could have a sizable throughput but not be considered a major source because of the control technology used. Such a source may be considered in the MACT floor determination. It was stated that there should be some practical break points as far as how sources of various sizes should be treated.

Participants were concerned about the inclusion of area sources with regard to this issue and with small sources (small businesses) being drawn in by larger sources with low emission levels. EPA stated that it is too early to decide about extending applicability to area sources.

There were questions raised as to the development of a CTG or a national rule on VOC, and a MACT standard simultaneously. As stated previously, the provisions of Section 112 of the CAA require development of a MACT standard for emissions of HAPs, and that it is still too early to decide whether a CTG or national rule will be developed to control VOC from this source category.

AAMA will appoint a representative to chair the Source Size Issue Subgroup.

Flexibility

The EPA and industry participants agreed that the Flexibility Issue Subgroup would be disbanded

Participants were asked for approaches to the flexibility issue. One suggestion was to set the standard and allow options for the source to decide how it would be met. It was also stated that limits should not be set so low that it becomes impractical to use a given technology. EPA responded that it does not want to exclude any type of coating, process, or control technology or dictate what must be used to meet the yet to be developed standard.

Karl Schultz, of DuPont Automotive, agreed to draft a statement of industry concerns about flexibility of the standard.

Roll Call

A list of the conference call participants and their affiliations is enclosed with this summary. Please review the list and if there are any additions or modifications please notify Leigh Lasher at (919) 941-0333 or via e-mail at llasher@rtp.pes.com.

NAME	AFFILIATION AND ADDRESS	PHONE/FAX	E-MAIL
Detweiler, Dennis	DuPont
Ewing, Gary	Nissan Manufacturing Corp.

983 Nissan Dr.

Smyrna, TN 37167	615-459-1633

615-355-2303F	gewing@edge.net
Farris, Michele	South Dakota DENR	Michelef@denr.state.sd.us
Fedorko, Robert	General Motors Corp.

Argonaut A-205H 485 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
Hill, Rob	TRC Environmental Corp. (TMA)

6340 Quadrangle Dr. Suite 200

Chapel Hill, NC 27514	919-419-7500

919-419-7501F
Horton, Mike	US Pipe & Foundry

PO Box 10406

Birmingham, AL 35173	205-254-7964

205-254-7967F
Horvath, Stanley K.	DuPont

950 Stephenson Hwy. Box 7013

Troy, MI 48007	248-583-8037

248-583-4555F	horvatsk@a1.spoc.umc.dupont.com
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
LaLumondier, Richard	National Electrical Manufacturers Assoc.

1300 North 17th Street, Suite 1847

Rosslyn, VA 22200	703-841-3237

703-841-3337F	ric_lalumondier@nema.org
Lilly, Amy	Assoc. of Intn'l Auto Mfg.

1001 N. 19th St., Suite 1200

Arlington, VA 22209	703-525-7788

703-525-8817F	alilly@aiam.org
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, Elisabeth	Georgia Air Pollution
Nelson, Bob	National Paint & Coatings Assoc.

1500 Rhode Island Ave. N.W.

Washington, DC 20005	202-462-6272

202-462-8549F
Pleasant, John	US Pipe & Foundry

PO Box 10406

Birmingham, AL	205-254-7435

205-254-7405F
Praschan, Gene	AAMA

1000 Park Forty Plaza Suite 300

Durham, NC 27713	919-547-7100

919-547-7102F
Ronner, Jim	Vulcraft

P.O. Box 1000

Saint Joe, IN 46785	219-337-1800

219-337-1988F
Rose, Bob	EPA - OSDBU	703-305-5511

703-305-6462F
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	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
Schultz, Karl	DuPont Automotive

Barley Mill Plaza 21-1108

PO Box 80021

Wilmington, DE 19880	302-992-2373

302-892-1143F
Seamon, Cathie Jo	Ford	313-390-3799

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

6340 Quadrangle Dr., Suite 200

Chapel Hill, NC 27514	919-419-7591

919-419-7501F
Sparks, John	EPA OPPT	202-260-1682

202-260-0981F	sparks.john@epamail.epa.gov
Strabbing, Patty	Chrysler

800 Chrysler Dr. East

Auburn Hills, MI 48326	248-576-5494

248-576-7928F	pas2@chrysler.com
Vizzi, Tara	AIAM

1001 N. 19th St., Suite 1200

Arlington, VA 22209	703-525-7788

703-525-8817F	tvizzi@aiam.org
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