Surface Coating of Miscellaneous Metal Parts

Summary of the Meeting of TMA and EPA MACT Development Teams for Miscellaneous Metal Parts and Products and Plastic Parts

May 7, 1997

The following summary presents the major issues associated with the surface coating of the miscellaneous metal parts and products and plastic parts source categories as discussed in a meeting with the Truck Manufacturers' Association (TMA). 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 was imposed.

Introduction to Heavy Truck Manufacturing

Chairman of the TMA-Environmental Management Committee, Bob Whelen , gave a brief overview of TMA and the categories which it represents. TMA, in conjunction with its consultant TRC, works to serve the trade by coordinating constructive dialog, cooperative research, and technical information exchange between industry and government agencies.

TRC Project Manager Jim Serne discussed the role that TRC will play as consultant.

Mr. Serne offered tasks such as: liaison to government agencies, coordinating information gathering, data gathering through site visits, and submitting a white paper to summarize the industry opinion of an appropriate MACT floor.

Tim McDaniel, who serves as MACT Study Chairman for TMA, described the variety of coating systems used throughout the industry. There are 15 assembly plants located in approximately 11 states, in addition to numerous parts plants. Virtually all heavy duty trucks are custom designed. Most heavy duty truck coatings have been reformulated to hi-solids rather than water-borne, and coatings' performance requirements include a one million mile warranty. The main focus of concern for facilities associated with TMA is recordkeeping due to the unique substrates and color complexity associated with assembly.

A description of coatings and coating procedures used by TMA facilities was provided by Rick Hartnedy, who serves as the representative for coating vendors. Each truck manufacturer draws from only one coating supplier. Coating considerations the industry must evaluate include:

Highly specified colors

High durability

Large surface areas with highly variable sizes and shapes

Large color selection (an average of 600-900 colors used per year in a typical plant)

Batch-type operations and mixing machines

Multiple substrates and primers

Low-bake requirements for touch-ups

Military and government specifications

Questions/Concerns/Comments - A list of questions for the EPA MACT Development Team was provided by TMA, responses to some of those questions are included below. The following topics were addressed by participants during the meeting:

•	TMA representatives emphasized that they want to be considered a subcategory.
Participants conceded that the process of heavy duty truck coating is very different than	the coating of other products in the category.

Participants were concerned with the process of determining the MACT floor. Possible
calculation of the baseline included: use of the top five facilities, averaging, or taking a	mean of plant emissions. Further questions arose as to whether the baseline would be	based on tons/year or lbs/product, and what would be the baseline year. Participants	were assured that the	baseline would be set using data in the most practical and
appropriate ways, and cost effectiveness would be considered.

With regard to the coordination between metal parts and plastic parts, participants
inquired as to the potential to link the two MACTs. The plastic coating that is conducted	by truck manufacturers is entirely exterior pieces, which do not accommodate water-	borne coatings as well as interior parts. Concern was raised over the different work	practices and recordkeeping which would be required of each MACT. EPA
representatives responded that the Project Managers would be attending PMACT
meetings for both categories. Participants also asked about the inclusion of
adhesives/sealants under this rule.

TRC discussed coordinating the mailing of questionnaires between TMA and EPA.
Questionnaires are being developed and will be mailed after the first PMACT meeting,	which is scheduled for mid-June. The proposed questionnaires will use an approved	generic form and an optional specific form.

EPA discussed plans for site visits which are tentatively scheduled for June 3 (Dublin,
VA) and June 4 (Cleveland, NC and Mount Holly, NC). These facilities were chosen	based on TMA input and their proximity to the EPA office. It was determined that a	reasonable time frame for evaluation was approximately five hours per facility.
Suggestions for other potential site visits were made to provide an adequate cross-section	of facility types. It was suggested that coating suppliers be notified of the finalized	schedule of visits to provide them with the opportunity to attend and provide input.

Participants inquired as to the inclusion of body builders, RVs, and large military vehicles	into their potential subcategory. The ramifications of incorporating these types of	facilities into the category was discussed. Questions were raised as to the potential	effects their operations and emissions would have on the MACT floor.

Participants discussed HAP emissions averaging. The industry would prefer averaging
for the facility as a single source rather than for each individual line. It was stated that	recordkeeping would be easier if the MACT applied to the facility as a whole.

Roll Call - A list of the meeting attendees and their associated organizations and companies is enclosed with this summary. Please review the list of attendees enclosed with this summary and if there are any additions or modifications notify George Woodall at (919) 941-0333 or via

e-mail at gwoodall @ rtp.pes.com.

NAME	AFFILIATION	PHONE/FAX	E-MAIL
Bouslog, Lyle	Peterbilt Motors Co. (Paccar)	615-860-1617

615-868-0117F
Bryant, Michael	ERG (Plastics)	919-461-1215

919-461-1418F	mbryant@erg.com
Ducey, Ellen	EPA (Plastics)	919-541-5408

919-541-5689F	ducey.ellen@epamail.epa.gov
Hartnedy, Rick	DuPont	610-347-0930

610-347-1036F	rhartnedy@aol
Hill, Rob	TRC Environmental Corp.	919-419-7500

919-419-7501F	HillRD@sprynet.com
Kruzer, Marc	Sherwin Williams	216-566-6546

216-566-2508F	mskruzer@sherwin.com
Mazzocco, Dave	PPG Industries, Inc.	412-492-5476

412-492-5377F	mazzocco@ppg.com
McDaniel, Tim	Navistar	937-390-4024

937-390-4501F	twm3@navistar.com
McLean, Joan S.	ERG (Plastics)	919-461-1218

919-461-1418F	jmclean@erg.com
Moore, Bruce	EPA (MMP)	919-541-5460

919-541-5689F	moore.bruce@epamail.epa.gov
Nelson, Bob	National Paint & Coatings Assoc.	202-462-6272

202-462-8549F
Salinas, Julie	Mack	610-709-2766

610-709-2543F
Schultz, Karl	DuPont Automotive	302-992-2372

302-892-1143F
Serne, Jim	TRC Environmental Corp.	919-419-7591

919-419-7501F
Synak, Milan	Frieghtliner	503-735-8940

503-735-7569F
Szorik, Julius	Akzo Nobel	810-637-8535

810-649-7367F
Teal, Kim	EPA (MMP)	919-541-5580

919-541-5689F	teal.kim@epamail.epa.gov
Thompson, Tom	PPG Industries, Inc.	412-274-3030

412-274-3016F	tjthompson@ppg.com
Whelen, Bob	Volvo	910-393-2644

910-393-2099F	vght.vgh200rw@memo.volvo.se
Williams, Lori	PES (MMP)	919-941-0333

919-941-0234F	lwilliam@rtp.pes.com
Woodall, George	PES (MMP)	919-941-0333

919-941-0234F	gwoodall@rtp.pes.com