Enclosure 1A

ALTERNATIVE LIST OF QUESTIONS

A. Instructions

This information request is designed for the paper and other web coating source category, including any facility engaged in the coating of paper, plastic film, metallic foil, and other web surfaces. This alternative list of questions is particularly geared toward facilities that produce industrial or decorative overlays and/or laminates. However, the questions should be completed for all paper and other web coating operations at your facility. Because fabric coating will be covered under another standard, Section G includes questions that are specific to fabric coating. This information request includes questions related to coating mixing, coating application and drying, coating and solvent storage, and cleaning operations.

This survey does not consider information concerning web surface coating operations which are dedicated primarily to research or laboratory purposes. A research or laboratory operation is one whose primary purpose is to conduct research and development into new processes and products and is operated under the close supervision of technically trained personnel and is not engaged in the manufacture of products for commercial sale in commerce, except in a de minimis manner.

We have provided example responses to most questions to aid you in completing the survey. Attachment 1 includes a list of hazardous air pollutants that you should refer to as you are completing the survey. Attachment 2 includes a list of definitions that may be helpful when responding to the questions.

All data and responses should be based on calendar year 1996 emissions, usage, and emission control equipment, or the most recent 12 months available. Please be sure to keep a copy of the completed survey for your records. You should also keep copies of any notes or calculations you perform in completing the survey. In answering the questions requiring a numerical response, the nearest percentage (for example, 5 percent not 5.1 percent) and the nearest ton are sufficient in most cases. If additional significant figures are required, this will be noted in the instructions/example for that question. In general, please provide the same number of significant figures that are included in the examples for each response.

If the space provided for your response is not adequate, please include the information clearly labeled with your response. If you believe there is additional information that is not requested on the survey that would be helpful to the EPA in developing standards for this industry, please include this information with your response also.

Return the completed survey and any additional information to:

U.S. Mail:

Bruce C. Jordan, Director

Emission Standards Division (MD-13)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards	Research Triangle Park, NC 27711

Attention: Daniel Brown

Express Mail:

Bruce C. Jordan, Director

Emission Standards Division (MD-13)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards	North Carolina Mutual Life Building

411 W. Chapel Hill Road

Durham, NC 27702

Attention: Daniel Brown, Room 1125

B.	General Information

B.1	General Corporate Information

1.	Name of legal owner (parent company)

2.	Address of legal owner:

3.	Size of company

Please indicate below the approximate number of employees in the business enterprise that owns this facility including, where applicable, the parent company and all subsidiaries, branches, and unrelated establishments owned by the parent company.

<99	500 - 999

100-249	1,000 - 1,499

250-499	>1,500

B.2 Facility Information

1.	Name of facility:

2.	Address of facility (mailing address and physical address if different):

3.	Name of person(s) completing the survey:

4.	Title(s):

5.	Telephone number:

6.	SIC code(s) covering facility operations:

7.	Please indicate below the total number of employees at this facility.

<99	500 - 999

100-249	1,000 - 1,499

250-499	>1,500

8.	Please indicate below the approximate percentage of employees attached to paper, film, foil, and other web coating operations (and other operations associated with the coated product) at this facility. If the only products produced at the facility are made of coated paper, film, foil, or other webs, the percentage will be 100.

____ 100% ____75% ____50% ____25% ____0%

9.	If, at any of the coating lines at the facility, controls or process changes have been implemented that are the result of new source review requirements pursuant to 40 CFR 51.160, Subpart I, Review of New Sources and Modifications, provide below: the date at which the latest Lowest Achievable Emission Rate (LAER) requirement came into effect, and, where applicable, the ID number of the affected line.

LAER date	Line ID

10.	Are the coating lines at this facility subject to any Federal new source performance standards (NSPS), State reasonably available control techniques (RACT) rules, or State air toxic rules? Please circle those that apply and specify which NSPS.

NSPS

RACT

Air Toxics

None
(specify)

C.	Facility Operations

The information requested in this section will provide EPA with an overview of your facility. This information will be used to characterize the paper, film, foil, and other web coating industry.

1.	Type of product(s) manufactured (e.g., decorative foil overlays, low basis weight paper overlays, decorative laminates, industrial laminates, etc.):

2a.	Are both printing and coating done at the facility? Please circle.

Yes	No

2b.	If yes, approximately what percentage of the total materials used for coating and printing at the facility are used for coating?	Please circle.

0-5%	5-25% >25%

3.	Please list the substrates coated at your facility. Be specific. For example, if you coat on film, indicate type of film, such as polyvinyl chloride).

4.	Number of coating lines:

5.	Please complete Table 1 for each coating line at your facility using the example provided. Attachment 3 includes a list of coating application methods that you can refer to in completing the Table.

6.	If you produce high pressure laminates, please describe the pressing process (include the number of press openings, the average temperature and pressure used, and the venting of any emissions).

7.	Typical hours of coating operation (run plus make-ready), on the average:

Hours per day:

Days per week:

Weeks per year:

8.	Total Annual Coating Use (lb):

9.	Total Annual Coating Solids Applied (lb):

10.	Please provide a detailed diagram(s) showing typical coating process flow through the facility. The diagram should identify each emission point (for example coating stations on each coating line) and the control device(s), if any, that the emissions are directed to. Multiple diagrams are acceptable if necessary. If you prepared a
similar diagram for your Title V permit application, you may submit that diagram rather than preparing a new diagram.

D.	VOC and HAP Emissions

The information requested in this section will be used to determine baseline VOC and HAP emissions, to identify the current level of control being achieved by the industry and the methods
used to reduce emissions, and to identify the type of HAP emitted by the industry.

PLEASE NOTE: "Before Control" as used below means total VOC emitted from all operations, assuming no controls are present (often equal to the VOC used). It includes emissions from sources that are not controlled, fugitive emissions, and the emissions from controlled sources BEFORE the emissions are sent

to the control device. Similarly, "After Control" includes emissions from all uncontrolled sources, including fugitives and emissions occurring at the outlet of any control devices (e.g. stack).

1.	Annual VOC Emissions (tons/year)

a.	Annual Coating Operation VOC Emissions

1) Before control:

2) After control:

3) Method(s) used to determine controlled emissions (emission test results, engineering estimate, mass balance, AP-42):

b.	Annual Cleaning Operation VOC Emissions (directly associated with web coating)

1) Before control:

2) After control:

3) Method(s) used to determine controlled emissions (emission test results, engineering estimate, mass balance, AP-42):

c.	Annual VOC Emissions from Other Facility Operations Directly Associated with Web Coating (e.g., do not include emissions from boilers).	Please specify source.

1) Source of emissions:

2) Before control:

3) After control:

4) Method(s) used to determine controlled emissions (emission test results, engineering estimate, mass balance, AP-42):

2a.	What is the overall annual average weight (pounds) of HAP emitted per weight (pounds) of coating solids used?

2b.	Complete Table 2 for each source of hazardous air pollutant (HAP), and each HAP known to be emitted from operations related to web coating at the facility. Include HAP emissions from coating mixing; coating lines; coating and solvent storage; coating-related cleaning operations; resin manufacturing; printing; transfer, handling, and processing of materials; and wastewater and solid waste handling. Also, if known, include any nonvolatile HAP and any HAP that are emitted as reaction by-products during coating curing.

Report emissions from calendar year 1996 or more recent 12-month period, unless you can justify selection of an alternative base year. Please indicate below the time period to which the information in Table 2 applies.

Table 2 data applies to the following 12-month period:

Begin End

Example entries to Table 2 are also provided. A list of HAP is provided in Attachment 1.

EXAMPLE TABLE 2. HAP EMISSIONS - BEFORE AND AFTER CONTROL

Source

of HAP

Name

of HAP

Total Annual HAP Emissions

Before Control (ton/yr)a,b

Basis for

Before-

Control

Estimate

Capture Method; Original

or

Retrofit?

Capture

Efficiency

(%)

Basis for

Reported

Capture

Efficiency

Control

Device/

Method

Control

Device

D/C

Efficiency

(%) c

Basis for

Reported

D/C

Efficiency

Overall

Control

Efficiency

(%) c,d

Total

Annual

HAP

Emissions

After

Control

(ton/yr)e

Coating Line A	Methanol

Phenol

Formaldehyde

233

120

7	Mass

balance	Coater hood and dryer;

original	95	Method 204	Thermal

oxidizer	99	Method 25	94	39 .2
Line cleaning

Methanol	5	Usage

records	N/A	N/A	N/A	N/A	N/A	N/A	N/A	5
Printing line Z

MEK	2	Mass

balance	Hood; original	80	Engineering calculation	N/A	N/A	N/A	N/A	2
Coating Line B

Methanol

Formaldehyde	0 .5

25	Mass

balance	Permanent total enclosure (PTE)

retrofit	100	Meets

EPA

criteria	Thermal oxidizer	98

(permit

95)	Method 25	98

(permit 95 )	0 .5
Wastewater

Aeration

Basin

Methanol	2	Engineering

calculation	N/A	N/A	N/A	N/A	N/A	N/A	N/A	2

------SEE NOTES a - e ON PAGE 10 THAT EXPLAIN COLUMN HEADINGS----

a	Before-control emissions represent the sum of all HAP emissions that would occur in the absence of all control devices. Therefore, it includes emissions from the source that are never controlled plus emissions from the source BEFORE the emissions are sent to the control device.

b	In addition to those volatile HAPs that are emitted into the air, identify (to the extent possible) and footnote 1) volatile HAPs that are present but not emitted (e.g., react to form coating), and 2) inorganic HAPs or nonvolatile HAPs that are present but not emitted into the air.

c	If permitted destruction/collection (D/C) and/or overall control efficiencies are different than those shown in the table, please also provide the permitted efficiencies.

d	Overall control efficiency (OCE) is the product of the destruction/collection efficiency (DCE) times the capture efficiency (CE): OCE = (DCE x CE)÷ 10,000

e	After-control emissions represent all emissions from the source, including emissions from the control device(s) as well as emissions that are totally uncontrolled.

TABLE 2. HAP EMISSIONS - BEFORE AND AFTER CONTROL

Source

of HAP

Name

of HAP

Total Annual

HAP

Emissions

Before

Control

(ton/yr) a,b

Basis

for

Before-

Control

Estimate

Capture Method:

Capture: Original

or

Retrofit?

Capture

Efficiency

(%)

Basis

for

Reported

Capture

Efficiency

Control

Device/

Method

Control

Device

D/C

Efficiency

(%)c

Basis

for

Reported

D/C

Efficiency

Overall

Control

Efficiency

(%)c,d

Total

Annual

HAP Emissions After

Control

(ton/yr)e

--SEE EXAMPLE TABLE ON PAGE 9 AND NOTES A - E ON PAGE 10 THAT EXPLAIN COLUMN HEADINGS--
3.	Test Data for Residual HAP and Emissions

3a.	Are you aware of any available test or engineering data regarding the amount of residual HAP from the coating that is estimated to remain in the product after curing? Please circle.

Yes	No

3b.	Do you have any emissions tests or engineering data for emissions that occur during layup, buildup, pressing or postforming operations, or for emissions that occur along the line, after the ovens, before the pressing operations for high pressure laminates? Please circle.

Yes	No

3c.	If any of the data described in 3a and 3b are available, please provide a summary of the information with your response.

E.	VOC and HAP Information for Coatings

The information requested in this section will be used to identify the types of coatings used by the industry, the VOC and HAP contents of those coatings, and the types of low VOC/HAP coatings being used by the industry. This information will be used in developing model plants and evaluating the impacts of control alternatives.

1.	In Table 3, provide the total usage (as applied) for each type of coating used at the facility, as well as the corresponding range of HAP and VOC and solids contents for the coatings used. Please be as specific as possible in providing ranges.

2a.	What coatings do you manufacture for use on-site? Please circle. Please remember to include any associated emissions in Table 2 of Section D.

Resin Adhesive Other Coating None

2b.	If you manufacture coatings on-site, are they also available for sale off-site? Please circle.

Yes	No

2c.	If you manufacture coatings on-site, are these processes currently covered by any regulation? If yes, please specify the regulation.

Yes	No

3a.	If you purchase your coatings, do you thin them prior to application? Please circle.

Yes	No

3b.	If coatings are thinned, how much thinner is added (as a ratio or percentage)?

F.	Cleaning Operations, and Solvent and Coating Storage

The information requested in this section will be used to identify the level of emissions from operations other than coating and to identify control measures and work practice standards the industry has already implemented to reduce emissions from these sources. Typically, EPA develops work practice standards for these miscellaneous emission sources rather than setting emission limits or control efficiency requirements. Identifying work practice standards already being used by some facilities in the industry is usually a good starting point for identifying work practice standards that could be implemented by the entire industry.

1.	Please provide a brief description of your cleaning operations and cleaning solvent usage.

2.	Describe any work practices or pollution prevention/ source reduction measures that have been implemented at the facility (within the last 10 years) to reduce cleaning or other facility solvent usage, or emissions from solvent-use operations. For example: The facility has implemented a cleaning solvent accounting system to track cleaning solvent usage.

3.	If you have previously estimated storage tank VOC or HAP emissions (for Title V permit or other regulatory requirements), please provide the storage tank emissions data below (by storage tank or total emissions from all storage tanks, whichever is available).

If you provided similar information in your Title V permit application or any other applications/inventories, you may attach that section of your permit application rather than provide the information below.

If storage tank emissions data are not available, please indicate below.

4.	Provide information on the types of emission controls used on coating storage tanks at the facility. State the types of controls used overall, and indicate if certain types of controls are used with certain types of coatings or types of storage tanks (e.g., solvent storage tanks are vented to a thermal incinerator, remaining tanks are uncontrolled).

TABLE 3. TOTAL COATING USAGE AND RANGE OF

HAP, VOC, AND SOLIDS CONTENTS

Coating Type

Range of

HAP and VOC

Contents

(% by weight)

Range of Solids Contents

(% by weight)

Total

Usage

(lb/year)
EXAMPLES:

Solventborne Top Coat

Waterborne Top Coat

Phenolic Coating

(as applied)

Melamine Coating

(as applied)

60-65 HAP

90-95 VOC

10-15 HAP

10-15 VOC

25 - 30

0 - 0.5

5-10

50-60

65 - 70

30 - 35

900,000

400,000

2.0 x 107

2.5 x 107

G. Fabric Coating

The information collected through this survey will be used to develop standards for the paper and other web coating source category. Fabric coating is scheduled to be regulated under separate standard. However, because some facilities that manufacture laminates may also coat fabric, such as fiberglass, we may consider an option for these facilities to cover the fabric coating under this regulation. In order to consider this option, we need to collect information on the extent of fabric coating within the industrial and decorative overlays and laminates industry, and the types of coatings used for fabric coating.

1.	What percentage of the coatings used at the facility is used for coating fabric?

0	25-50

1-10	50 - 75

10-25	>75

2a.	Are the coatings used for overlays and laminates the same coatings used on fabric? Please circle.

Yes	No

2b.	If no, what types of coating formulations do you use for fabric coating and how are these different from the coatings used for overlays and laminates?

H. Pollution Reduction/Source Reduction Measures

Please answer the questions below, where applicable. You do not need to answer all of these questions, however, the information will be helpful in identifying source reduction (pollution prevention) measures currently being used by the industry.

1.	Source reduction measures reduce the amount of any HAP prior to recycling, treatment, or disposal. Source reduction measures include equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control. For each unit operation for which source reduction measures have (in the last 10 years) resulted in a decrease in HAP emissions, provide the following information.

a.	Name of unit operation (e.g., resin formation):

b.	Description of process change (e.g., Reduced content of free formaldehyde):

2.	If recovery or recycling of feedstocks is used, quantify the effect of the program (e.g., what would the annual purchase of feedstocks be in the absence of the recovery/recycling program, as a factor of the actual purchases).

3.	Are you aware of any alternative processes (feedstock substitution or eliminations) or control devices that could result in fewer impacts between environmental media (water, air, and land) or reduced total release to all environmental media (e.g., reduced wastewater or solid waste)? If you can, discuss whether these processes could be adapted to the industrial and decorative overlay and/or laminating industries and any experience you have with this.

4.	If your facility has switched to low-VOC/low-HAP coatings and/or adhesives, why did you switch? If you have not switched, have you considered doing so?

5.	Please describe any overall differences in the coatings that can be used on the various substrates coated and/or for the various end products produced. For instance, perhaps waterborne coatings cannot be used successfully on one particular substrate, or for one particular end use, such as kitchen cabinet laminates.

6.	If your facility has switched to low-HAP coatings, how have your production costs changed (%), and what caused the production costs to change (e.g., increased cost of coatings)?

7a.	Was additional capital investment required? Please circle one.

Yes	No

7b.	If yes, how much was required, and what were the major cost items?

8a.	Was the additional investment more than expected?

Yes	No

8b.	If yes, which costs were unexpected?

9a.	Did your product quality change with the low-HAP coatings?

Yes	No

9b.	If yes, how?

10.	Did your facility find it more difficult to meet your customers' requirements with the low-HAP coatings?

Yes	No

Comment

I. Miscellaneous

Please answer the questions below, where applicable. You do not need to answer all of these questions, however, the information will be useful to the EPA in performing the economic impact analysis for the industry.

1.	How extensive is the competition your firm faces for the products you produce, whether they be intermediate or for final end-use? Are you typically competing with one firm or several firms in the market you service?

2.	What is the share of production cost for your products that is due to applying and formulating coatings (e.g., more than 25 percent, less than 1 percent)?

3.	Describe any factors not addressed in the above questions that might serve to distinguish your operation from others in the industry:

3 attachments

Attachment 1

List of Hazardous Air Pollutants

CAS No.	Chemical name

CAS No.	Chemical name

75070	Acetaldehyde

60355	Acetamide

75058	Acetonitrile

98862	Acetophenone

53963	2-Acetylaminofluorine

107028	Acrolein

79061	Acrylamide

79107	Acrylic acid

107131	Acrylonitrile

107051	Allyl chloride

92671	4-Aminobiphenyl

62533	Aniline

90040	o-Anisidine

1332214	Asbestos

71432	Benzene (including benzene from gasoline)

92875	Benzidine

98077	Benzotrichloride (isomers and mixture)

100447	Benzyl chloride

92524	Biphenyl

117817	Bis(2-ethylhexyl)phthalate(DEHP)

542881	Bis(chloromethyl)ether

75252	Bromoform

106990	1,3-Butadiene

156627	Calcium cyanamide

133062	Captan

63252	Carbaryl

75150	Carbon disulfide

56235	Carbon tetrachloride

43581	Carbonyl sulfide

120809	Catechol

133904	Chloramben

57749	Chlordane

7782505	Chlorine

79118	Chloroacetic acid

532274	2-Chloroacetophenone

108907	Chlorobenzene

510156	Chlorobenzilate

67663	Chloroform

107302	Chloromethyl methyl ether

126998	Chloroprene

1319773	Cresols/Cresylic acid

95487	o-Cresol

108394	m-Cresol

106445	p-Cresol

98828	Cumene

94757	2,4-D, salts and esters

3547044	DDE

57147	1,1-Dimethyl hydrazine

334883	Diazomethane

132649	Dibenzofurans

96128	1,2-Dibromo-3-chloropropane

84742	Dibutylphthalate

106467	1,4-Dichlorobenzene(p)

91941	3,3-Dichlorobenzidene

111444	Dichloroethyl ether (Bis(2-chloroethyl ether)

542756	1,3-Dichloropropene

62737	Dichlorvos

111422	Diethanolamine

121697	N,N-Diethyl aniline (N,N-Dimethylaniline)

64675	Diethyl sulfate

119904	3,3-Dimethozybenzidine

60117	Dimethyl aminoazobenzene

119937	3,3 -Dimethyl benzidine

79447	Dimethyl carbamoyl chloride

68122	Dimethyl formamide

131113	Dimethyl phthalate

77781	Dimethyl sulfate

534521	4,6-Dinitro-o-cresol, and salts

51285	2,4-Dinitrophenol

121142	2,4-Dinitrotoluene

123911	1,4-Dioxane (1,4-Diethyleneoxide)

122667	1,2-Diphenylhydrazine

106898	Epichlorohydrin (1-Chloro-

2,3-epoxypropane)

106887	1,2-Epoxybutane

140885	Ethyl acrylate

100414	Ethyl benzene

51796	Ethyl carbamate (Urethane)

75003	Ethyl chloride (Chloroethane)

106934	Ethylene dibromide (Dibromoethane)

107062	Ethylene dichloride (1,2-Dichloroethane)

107211	Ethylene glycol

151564	Ethylene imine (Aziridine)

75218	Ethylene oxide

96457	Ethylene thiourea

75343	Ethylidene dichloride (1,1-Dichloroethane)

50000	Formaldehyde

76448	Heptachlor

118741	Hexachlorobenzene

87683	Hexachlorobutadiene

77474	Hexachlorocyclopentadiene

67721	Hexachloroethane

822060	Hexamethylene-1,6-diisocyanate

680319	Hexamethylphosphoramide

110543	Hexane

302012	Hydrazine

7647010	Hydrochloric acid

7664393	Hydrogen fluoride (Hydrofluoric acid)

123319	Hydroquinone

78591	Isophorone

58899	Lindane (all isomers)

108316	Maleic anhydride

67561	Methanol

72435	Methoxychlor

74839	Methyl bromide (Bromomethane)

74873	Methyl chloride (Chloromethane)

71556	Methyl chloroform (1,1,1-Trichloroethane)

78933	Methyl ethyl ketone (2-Butanone)

60344	Methyl hydrazine

74884	Methyl iodide (Iodomethane)

108101	Methyl isobutyl ketone (Hexone)

624839	Methyl isocyanate

80626	Methyl methacrylate

1634044	Methyl tert butyl ether

101144	4,4-Methylene bis(2-chloroaniline)

75092	Methylene chloride (Dichloromethane)

101688	Methylene diphenyl diisocyanate (MDI)

101779	4,4-'Methylenedianiline

91203	Naphthalene

98953	Nitrobenzene

92933	4-Nitrobiphenyl

100027	4-Nitrophenol

79469	2-Nitropropane

684935	N-Nitroso-N-methylurea

62759	N-Nitrosodimethylamine

59892	N-Nitrosomorpholine

56382	Parathion

82688	Pentachloronitrobenzene (Quintobenzene)

87865	Pentachlorophenol

108952	Phenol

106503	p-Phenylenediamine

75445	Phosgene

7803512	Phosphine

7723140	Phosphorus

85449	Phthalic anhydride

1336363	Polychlorinated biphenyls (Aroclors)

1120714	1,3-Propane sultone

57578	beta-Propiolactone

123386	Propionaldehyde

114261	Propoxur (Baygon)

78875	Propylene dichloride (1,2-Dichloropropane)

75569	Propylene oxide

75558	1,2-Propylenimine (2-Methyl aziridine)

91225	Quinoline

106514	Quinone

100425	Styrene

96093	Styrene oxide

1746016	2,3,7,8-Tetrachlorodi-benzo-p-dioxin

79345	1,1,2,2-Tetrachloro-ethane

127184	Tetrachloroethylene (Perchloroethylene)

7550450	Titanium tetrachloride

108883	Toluene

95807	2,4-Toluene diamine

584849	2,4-Toluene diisocyanate

95534	o-Toluidine

8001352	Toxaphene (chlorinated camphene)

120821	1,2,4-Trichlorobenzene

79005	1,1,2-Trichloroethane

79016	Trichloroethylene

95954	2,4,5-Trichlorophenol

88062	2,4,6-Trichlorophenol

121448	Triethylamine

1582098	Trifluralin

540841	2,2,4-Trimethylpentane

108054	Vinyl acetate

593602	Vinyl bromide

75014	Vinyl chloride

75354	Vinylidene chloride (1,1-Dichloroethylene)

1330207	Xylenes (isomers and mixture)

95476	o-Xylenes

108383	m-Xylenes

106423	p-Xylenes
0	Antimony Compounds

0	Arsenic Compounds (inorganic including arsine)

0	Beryllium Compounds

0	Cadmium Compounds

0	Chromium Compounds

0	Cobalt Compounds

0	Coke Oven Emissions

0	Cyanide Compoundsa

0	Glycol ethersb

0	Lead Compounds

0	Manganese Compounds

0	Mercury Compounds

0	Fine mineral fibersc

0	Nickel Compounds

0	Polycylic Organic Matterd

0	Radionuclides (including radon)e

0	Selenium Compounds

NOTE:	For all listings above which contain the word "compounds" and for glycol ethers, the following applies: Unless otherwise specified, these listings are defined as including any unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part of that chemical's infrastructure.

List of Hazardous Air Pollutants (continued)

a	X'CN where X = H' or any other group where a formal dissociation may occur. For example KCN or Ca(CN)2.

b	Includes mono- and di-ethers of ethylene glycol, diethylene glycol, and triethylene glycol of the form:

R-(OCH2CH2)n-OR'

where:

n	=	1, 2, or 3

R	=	alkyl or aryl groups

R'	=	R, H, or groups which, when removed, yield glycol ethers with the structure:

R-(OCH2CH)n-OH

Note that polymers are excluded from the glycol category.

c	Includes glass microfibers, glass wool fibers, rock wool fibers, and slag wool fibers, each characterized as "respirable" (fiber diameter less than 3.5 micrometers) and possessing an aspect ratio (fiber length divided by fiber diameter) greater than or equal to 3, as emitted from production of fiber and fiber products.

d	Includes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100°C.

e	A type of atom which spontaneously undergoes radioactive decay.

Attachment 2

DEFINITIONS--FOR PURPOSES OF THIS SURVEY

Coating means a material applied onto or impregnated into a substrate for protective, decorative, or functional purposes. Such materials include, but are not limited to, paints, varnishes, sealants, adhesives, inks, maskants, temporary protective coatings, industrial and decorative overlays and laminates, and resins; and are often, but not always, applied across the entire width and/or length of the substrate.

Coating applicator means an apparatus used to apply a surface coating to a continuous web.

Coating line means any number or combination of precoat or coating applicators, flashoff areas, and ovens which coat a continuous web, located between a web unwind station and a web rewind or cutting station.

Coating operation means those activities in which a coating is applied to a substrate and is subsequently air dried, cured in an oven, or cured by radiation.

Coating station means a unit on a coating line which applies a coating to the substrate.

Facility means all contiguous or adjoining property that is under common ownership or control, including properties that are separated only by a road or other public right-of-way.

Flashoff area means the portion of a coating line after the coating applicator and before the oven entrance.

Hood or enclosure means devices used to capture emissions and direct them to a control device.

Oven means a chamber which uses heat or irradiation to bake, cure, polymerize, or dry a surface coating.

Attachment 3

COATING APPLICATION METHODS

Please refer to the following list of coating application methods when completing Table 1.

Air knife

Calender

Dip

Dip/bath

Gravure

Knife-over roll

Mayer rod

Reverse roll

Slot die

Other (please specify):