Surface Coating of Miscellaneous Metal Parts

Summary of the Break-Out Session from the Coatings Workshop

April 9, 1997

The following summary presents the major issues associated with the surface coating of miscellaneous metal parts source category and discussed in the large group of representatives from industry, industry associations, and State and local agencies. 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.

Treatment of Area Sources - The issue is should all sources be covered under this category regardless of size; this would treat area sources the same way as major sources.

Sealers and Adhesives - Should these be included as a coating of a miscellaneous metal part? These materials are covered under Section 183(e) but further investigation will be needed to determine applicability to this source category.

Scope of the Category - The original issue raised was the distinction between miscellaneous metal parts and plastic parts; often a coating operation may coat a part composed of both materials. The determination of which category a process may fall is especially difficult in a category as diverse as miscellaneous metal parts. Another concern was that overlap into other categories (e.g., automotive coatings) may result in differing requirements from processes coating different products but using identical coating materials. In response, it was pointed out that by developing the various surface coating categories concurrently this overlap could be addressed more directly with minimal duplication of effort. It was also noted that the basis of the CTG for miscellaneous metal parts was to cover things not specifically covered by other rules. It was asked whether the rule would apply to refurbishers as well as manufacturers. In response, it was noted that a rule would apply to both if they were major sources. In later discussions, it was noted that wire coating was far different from all other processes in this category and it was suggested that perhaps it should be separated into a separate category.

National Rule vs. CTG - The industry concern is that certain facilities may institute a control technology that is based on using a particular type of material, and if during the process of developing a National Rule that material was banned, the facility would not be able to acquire that material and their investment in that technology would have been wasted. If a CTG approach was used, however, the economic effect would not be an issue, as long as the technology worked at reducing emissions. In response, it was noted that the current thinking is towards developing a CTG, which is less complicate and less resource intensive. The state agency concern on this topic is that CTGs are not enforceable, whereas a national rule would be.

Coordination of Regulations Under Two Mandates - EPA has been given the mandate to develop regulations to control VOC under 183(e) and hazardous air pollutants under 112(d); the issue is that the regulations covering these two mandates not be in conflict with one another. Secondly, the question was raised of how EPA plans to balance those needs. Under the Code of Federal Regulations, the regulations pertaining to 183(e) would be codified under 40 CFR Part 59, whereas the regulations derived from 112(d) would appear under NESHAPs. There was a general question as to whether two rules would be written. In response, it was pointed out that there will be a Section 112 rule and either a CTG or a 183(e) rule.

Certification and Record-Keeping Requirements - Industry representatives were concerned that flexibility be used in applying the rules to coating processes done in small batches. The concern is the inordinate record-keeping burden for documenting numerous small batches would be unfair and cost-prohibitive for certain facilities, effectively discriminating against their operations. Another concern is the record-keeping burden for sources with low VOC/HAP emissions co-located with a major source. In response, it was noted that EPA has already begun thinking about that issue.

Timetable for PMACT Process - In response to a question on schedule for PMACT, it was noted that the present timetable calls for the development of a PMACT for this category by October. The first major milestone is the identification of stakeholders and coordination of a conference call (or set of conference calls) by the end of April. It was suggested that by identifying subcategories early on, EPA may be able to better focus on putting together more manageable stakeholder teams.

Stakeholder Identification - In order to facilitate identifying stakeholders, or representatives for stakeholder groups, a sheet of paper was circulated for session participants to identify potential trade associations or other groups to represent their interests. A concern of EPA is that the stakeholder group be representative of all interested parties without becoming too large to function efficiently. The attendees noted that this may be difficult to do because the people represent many different processes and a single manageable group may be difficult to identify. Industry representatives voiced some concerns with using the Toxic Release Inventory (TRI) as the sole source for identifying facilities. Some of the state representatives suggested that the state agencies may have a better list of the facilities within each state that fall into this source category, regardless of size cut-offs. One suggestion was to develop two questionnaires; the first would identify the players and their processes, and the second would be the more detailed, process-oriented questionnaire.

Representation by Trade Associations - Some participants were concerned that although they did have some interest in the stakeholder process, the trade associations that represent them may not (e.g., foundries). Conversely, some companies noted that they may not want to be represented by a trade association. Also mentioned were the small business concerns that may not be represented by any trade associations.

Use of a Web Site as a Method of Disseminating Information - This would allow for open dialogue and all interested parties could access information in a time-effective manner. In response, it was noted that EPA would try to use it as much as possible.

Rule Flexibility - One representative of a local agency noted that they are currently revising their surface coating rule and that the revisions being made will be very flexible because of the numerous differences in the processes being covered. This representative stated that the EPA needs to keep the MACT standard very flexible to allow local agencies to implement what is good for their area. For example, the prescriptive use of a certain type of application method may be counter-productive for certain types of coatings; such as using an airless spray gun for asphaltic coatings, thereby increasing solvent use to allow the coating to be applied by this method.

Sub-categorization - Various methods were suggested for how this category could be broken down into smaller sub-groups: 1) Size of product; 2) Method of application; 3) Time of use (hourly versus continuous lines); 4) Volume of use; 5) Process lines versus field repair; 6) Type of paint/coating used (asphaltic, high-solids, low VOC, etc.); 7) End-use of the final product (Performance requirements and specialty applications); 8) SIC; and 9) Curing method. It was also noted that wire coating is very much different from all other coating processes within this source category, and should stand alone as a sub-category, if not broken-out as a separate source category. It was also suggested that a final sub-categorization scheme may be a hybrid of more than one method.

State Rules - A poll of the state and local agency representatives and industry representatives with operations in various states was taken to assess the basis for state rules: SC, NC and WA use fence line concentrations determined by dispersion modeling to determine compliance; CA uses VOC content and transfer efficiency; NJ recently added new operations to their rule; and TN uses the pounds/gallon recommendations from the current CTG. It was also noted that many states have a list of toxic pollutants that varies from the list of 189 pollutants specified in 112(b), and that these need to be considered in the PMACT process.

Potential Conflicts with OSHA Regulations - EPA asked the attendees to comment on this area of concern. Some emission control techniques, such as air recirculation, may increase the concentration of toxic pollutants above the PEL , thereby triggering noncompliance with OSHA regulations or increasing the regulatory burden on the facility. It was suggested that the American Conference of Governmental Industrial Hygienists ( ACGIH ) recommendations for spray paint booths and the rules from the South Coast Air Quality Management District in California be referenced. It was also noted that Chuck Darvin ( ORD /EPA) is working on a project at a Marine base in California where they are investigating the potential for using recirculation/partition systems to reduce exhaust of toxic pollutants.

Facilities with Early Reductions - A special concern was raised for facilities that apply the most innovative technology prior to the development of the MACT, and that they not be subject to the same reduction levels as facilities without the costly additional controls.

Pollution Prevention - Pollution prevention was brought forward as an alternative to expensive add-on controls. It was noted that if the demand for low-HAP coatings increases, the market demand for the production of HAPs will also be decline, reducing emissions from solvent production facilities as well.

Facility Bubbles and Other Averaging Methods - The application of a bubble-type of averaging for entire facilities was discussed, possibly across source categories. Investigation of alternative averaging methods was also suggested. It was noted that averaging across source categories and across subcategories is allowable.

PMACT Process - Concern was raised on the definition of the top 12% under the six-month time frame for the current PMACT process; the method of subcategorization will also affect this determination. It was suggested that a longer time frame be used for this source category since it is so diverse and ubiquitous. One attendee believed that the PMACT would be picked-up by the State/local agencies for their SIPs, but that six months is insufficient time to develop a high quality PMACT, and it would be better to either spend more time developing the PMACT or drop PMACT and go directly to MACT development for this source category. It was also speculated that a PMACT may not be necessary for this source category because few facilities would be constructed or reconstructed and the need for case-by-case MACT determination would be minimal.

Changing Solvents - This concern was raised after the session. By reducing the amounts of certain solvents declared as HAPs, the market forces may increase the use of other solvents not currently classified as HAPs due to their volume of use, yet triggering their later redesignation as HAPs due to increases in use. Other concerns were raised as to product quality and nuisance problems (odor) associated with some potential replacement solvents.

Small-Use Exemption - It was noted that the aerospace NESHAP includes a small use exemption and a similar type exclusion was encouraged to be considered for miscellaneous metal parts.

Format of the Standard - A concern was raised about whether standards based on technologies other than add-on controls would be considered. In response, it was noted that all options will be considered.