Surface Coating of Miscellaneous Metal Parts and Products

Summary of the Issue Subgroup Conference Calls

August 7, 1997

The following summary presents the major issues associated with the Consistency, Data Collection, and Alternative Questionnaire 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.

Consistency & Overlap

The EPA and participants agreed to disband this Issue Subgroup and incorporate any potential consistency issues in the Data Collection Subgroup.

Participants were concerned with how sources that fall into more than one source category would be treated. They would like to see a way to integrate multiple categories through inter-source category averaging or creating links between categories. Requirements under existing rules as well as those currently undergoing development will need to be considered.

There was further concern over the consistency of applicability between categories. Possible solutions offered were a rule of engagement or the potential to opt out of one category and be included in another.

Data Collection

As part of the data collection process, EPA would like to obtain coating information directly from coating manufacturers. Requested information would include HAP content, VOC content, and the range of industries each manufacturer supplies.

EPA has been discussing sending representatives to the states to obtain information about facilities applicable to the Miscellaneous Metal Parts and Products Source Category. The data would be used to define the scope, determine source sizes, identify small businesses, etc.

Participants readdressed the question of actual versus permitted versus potential emissions in the MACT floor determination. This is an unresolved issue which will be discussed further in subsequent meetings.

With regard to determination of the baseline year participants would like to establish a default baseline period based on relevant factors and have alternative baseline years offered due to cyclical changes in industry. There was also concern as to an across-the- board baseline applicable to potential subcategories. EPA responded that there may need to be different baseline periods for subcategories or industry sectors based on the dynamics of the industry. Participants also expressed concern over some facilities having already incorporated voluntary reductions and this putting other companies or other facilities owned by the same company at a disadvantage. Determination of the baseline year is currently an unresolved issue.

Participants wanted to know by what process the standard would be set and if there is an EPA Policy Guide on such issues. Bruce Moore, EPA Project Lead, will be researching this matter in the EPA Regulatory Policy Notebook and reporting his findings to stakeholders. Participants were concerned that the reference is not open as public record.

AAMA volunteered to nominate a chairperson for the subgroup. It was recommended that there be another industry co-chair due to the breadth of the data collection issue.

Alternative Questionnaire

The Alternative Questionnaire Issue Subgroup has been incorporated into the Data Collection Subgroup.

Roll Call

A list of the conference call participants and their affiliations is enclosed with this summary. Please review this 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
Cardounel, Carlos	Reynolds Metal Company

6601 W Broad St

Richmond, VA 23230	804-281-4387

804-281 -3745F	cacardou@lanmail.rmc.com
Detweiler , Dennis	DuPont	302-892-6702

302-892 -1143F
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 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
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 (NEMA)

1300 North 17th Street, Suite 1847

Rosslyn, VA 22200	703-841-3237

703-841-3337F	ric_lalumondier@nema.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, Elizabeth	Georgia Air Protection Division	Elisabeth_Munsey@mail.dnr.state.ga.us
Nelson, Bob	National Paint & Coatings Assoc.

1500 Rhode Island Ave. N.W.

Washington, DC 20005	202-462-6272

202-462-8549F
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
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	rlr@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
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