Economic
Impact
Analysis
of
the
Plastic
Parts
and
Products
NESHAP
Final
Report
EPA­
452/
R­
03­
019
August
2003
Economic
Impact
Analysis
of
the
Plastic
Parts
and
Products
NESHAP
By:

Katherine
B.
Heller
Jui­
Chen
Yang
Brooks
M.
Depro
RTI
International*
Health,
Social,
and
Economics
Research
Research
Triangle
Park,
NC
27709
Prepared
for:

John
L.
Sorrels
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Innovative
Strategies
and
Economics
Group
(
ISEG),
(
C339­
01)
Research
Triangle
Park,
NC
27711
*
RTI
International
is
a
trade
name
of
Research
Triangle
Institute.
iii
CONTENTS
Section
Page
1
Regulatory
Background
and
Impacts
(
Costs
and
Emission
Reductions)
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1­
1
1.1
Background
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1­
1
1.1.1
Authority
for
Development
of
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
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1­
1
1.1.2
Criteria
for
Development
of
NESHAP
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1­
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1.2
Summary
of
the
Rule
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1­
2
1.2.1
Affected
Source
Categories
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1­
2
1.2.2
Characterization
of
Emissions
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1­
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1.3
Definition
of
Affected
Source
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1­
6
1.4
Emission
Limits
and
Operating
Limits
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1­
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1.4.1
Emission
Limits
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1­
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1.4.2
Compliance
Options
for
Meeting
Emission
Limits
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1­
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1.4.2.1
Option
1:
Compliant
Materials
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1­
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1.4.2.2
Option
2:
Compliance
Based
on
the
Emission
Rate
without
Add­
on
Controls
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1­
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1.4.2.3
Option
3:
Emission
rate
with
Add­
on
Controls
Option
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1­
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1.4.3
Operating
Limits
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1­
10
1.5
Continuous
Compliance
Provisions
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1­
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1.5.1
Emission
Limits
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1­
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1.5.2
Operating
Limits
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1­
12
1.6
Notification
Requirements
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1­
12
1.7
Rationale
for
Selecting
the
Standards
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1­
13
1.7.1
Selection
of
Source
Category
and
Subcategories
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1­
13
1.8
Selection
of
Affected
Source
within
Selected
Source
Category
and
Subcategories
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1­
15
iv
1.9
Beyond
the
Floor
Alternatives
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1­
17
1.10
Format
of
the
Standards
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1­
18
1.11
Testing
and
Initial
Compliance
Requirements
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1­
19
1.12
Costs
and
Emission
Reductions
of
the
Standards
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1­
20
1.12.1
Cost
Estimates
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1­
20
1.12.2
Emissions
and
Emission
Reductions
Estimates
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1­
21
1.13
Health
Effects
from
Exposure
to
HAP
Emissions
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1­
21
2
Industry
Profile
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2­
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2.1
Introduction
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2­
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2.2
Production,
Costs,
and
Producers
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2­
4
2.2.1
Surface
Coating
of
Plastic
Parts
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2­
4
2.2.1.1
Surface­
Coated
Plastic
Parts
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2­
5
2.2.1.2
Inputs
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2­
6
2.2.1.3
The
Surface
Coating
Process
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2­
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2.2.1.4
Emissions
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2­
12
2.2.2
Costs
of
Surface
Coating
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2­
13
2.2.3
Suppliers
of
Plastics
Parts
Coating
Services
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2­
14
2.3
Consumption,
Value,
and
Consumers
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2­
19
2.3.1
Characteristics
of
Plastic
Parts
and
Products
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2­
20
2.3.2
Uses
of
Plastic
Parts
and
Products
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2­
21
2.3.2.1
Automotive
and
Truck
Parts
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2­
21
2.3.2.2
Computers
and
Business
Equipment
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2­
22
2.3.2.3
Miscellaneous
Products
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2­
22
2.3.3
Substitutes
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2­
23
2.3.4
Elasticity
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2­
23
2.4
Firm
Characteristics
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2­
23
2.4.1
Market
Power
of
Firms
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2­
25
2.4.2
Firm
Size
by
Employment
and
Revenue
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2­
26
2.4.3
Vertical
and
Horizontal
Integration
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2­
26
2.4.4
Small
Businesses
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2­
31
2.5
Markets
and
Trends
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2­
32
2.5.1
Production
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2­
32
2.5.2
Consumption
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2­
32
2.5.3
Pricing
Trends
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2­
32
v
3
Economic
Impact
Analysis
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3­
1
3.1
Results
in
Brief
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3­
1
3.2
Baseline
Data
Set
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3­
2
3.2.1
Sales
Data
Summary
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3­
2
3.2.2
Profit
Data
Summary
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3­
2
3.2.3
Employment
Data
and
Identification
of
Small
Firms
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3­
4
3.3
Methods
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3­
4
3.4
Results
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3­
5
3.5
Estimated
Impacts
on
Small
Business
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3­
7
References
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R­
1
vi
LIST
OF
FIGURES
Number
Page
2­
1
The
Firm's
Production
Diagram
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2­
4
2­
2
Powder
Coating
Booth
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2­
10
2­
3
A
Conveyorized
Paint
Finishing
Booth
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.
.
.
2­
11
2­
4
Example
Coating
Line
for
Three­
Coat
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
13
2­
5
Short­
Run
Unit
Cost
Function
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
15
3­
1
Distribution
of
Firm
Sales
(
n=
121)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
3
3­
2
Distribution
of
Profit
Rates
(
n=
31)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
3
3­
3
Distribution
of
Firm
Employment
(
n=
121)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
5
3­
4
Distribution
of
Cost­
to­
Sales
Ratios
(
CSRs):
Small
and
Large
Firms
(
n=
121)
.
3­
7
vii
LIST
OF
TABLES
Number
Page
1­
1
Emission
Limits
for
Existing
Affected
Sources
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
7
1­
2
Emission
Limits
for
New
or
Reconstructed
Affected
Sources
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
7
2­
1
Industries
Manufacturing
Surface­
Coated
Plastic
Parts
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
2­
2
Types
of
Common
Thermoplastic
and
Thermoplastic
Elastomer
Resins
.
.
.
.
.
2­
7
2­
3
Types
of
Thermoset
Resins
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
8
2­
4
Production
Costs
of
Industries
Producing
Coated
Plastic
Parts:
1997
.
.
.
.
.
2­
17
2­
5
Surface
Coaters
of
Plastic
Parts
and
Products,
by
State
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
20
2­
6
Auto
Parts
Made
of
Plastic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
26
2­
7
Measurements
of
Concentration
of
Industries
Manufacturing
Coated
Plastic
Parts:
1997
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
30
2­
8
Distribution
of
Potentially
Affected
Firms
by
Employment:
2000
.
.
.
.
.
.
.
.
.
2­
33
2­
9
Distribution
of
Potentially
Affected
Firms
by
2000
Sales
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
34
2­
10
Value
of
Domestic
Producta
Shipments
in
Some
Industries
Using
Surface
Coated
Plastic
Parts
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
37
2­
11a
Production
and
Apparent
Consumption
of
Automotive
Parts
and
Accessories
(
NAICS
336370,
336311,
336321,
335911,
336322,
336312,
336330,
336340,
336350,
336399
[
SICs
3465,
3592,
3647,
3691,
3694,
3714])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
38
2­
11b
Production
and
Apparent
Consumption
of
Motor
Vehicles
and
Bodies
(
NAICS
336111,
336112,
336120,
336211,
336992
[
SICs
3711,
3713])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
38
2­
11c
Production
and
Apparent
Consumption
of
Motorcycles
and
Parts
(
NAICS
334111
[
SIC
37512])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
39
2­
12
Production
and
Apparent
Consumption
of
Computers
and
Peripheral
Equipment
(
NAICS
334111,
334112,
334113,
334119
[
SICs
3571,
3572,
3575,
3577])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
39
2­
13a
Production
and
Apparent
Consumption
of
Dolls,
Toys,
and
Games
(
NAICS
339931,
336991,
339932
[
SICs
3942,
3944])
(
106
$
1997)
.
.
.
.
.
.
.
2­
40
2­
13b
Production
and
Apparent
Consumption
of
Sporting
and
Athletic
Goods
(
NAICS
339920
[
SIC
3949])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
40
2­
13c
Production
and
Apparent
Consumption
of
Bicycles
and
Bicycle
Parts
viii
(
NAICS
334111
[
SIC
37511])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
41
2­
13d
Production
and
Apparent
Consumption
of
Costume
Jewelry
and
Novelties
(
NAICS
339914
[
SIC
3961])
(
106
$
1997)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
41
2­
14
Price
Indices
in
Industries
that
Produce
Surface­
Coated
Plastic
Parts
.
.
.
.
.
.
2­
42
3­
1
Summary
Statistics
for
SBREFA
Screening
Analysis:
2000
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
6
1­
1
SECTION
1
REGULATORY
BACKGROUND
AND
IMPACTS
(
COSTS
AND
EMISSION
REDUCTIONS)

1.1
Background
1.1.1
Authority
for
Development
of
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)

Section
112
of
the
Clean
Air
Act
(
CAA)
requires
us
to
list
categories
and
subcategories
of
major
sources
and
area
sources
of
hazardous
air
pollutant
(
HAP)
and
to
establish
NESHAP
for
the
listed
source
categories
and
subcategories.
The
Plastic
Parts
and
Products
(
Surface
Coating)
category
of
major
sources
was
listed
on
July
16,
1992
(
57
FR
31576)
under
the
Surface
Coating
Processes
industry
group.
Major
sources
of
HAP
are
those
that
emit
or
have
the
potential
to
emit
equal
to,
or
greater
than,
9.1
megagrams
per
year
(
Mg/
yr)
(
10
tons
per
year
[
tpy])
of
any
one
HAP
or
22.7
Mg/
yr
(
25
tpy)
of
any
combination
of
HAP.

1.1.2
Criteria
for
Development
of
NESHAP
Section
112
of
the
CAA
requires
that
we
establish
NESHAP
for
the
control
of
HAP
from
both
new
and
existing
major
sources.
The
CAA
requires
the
NESHAP
to
reflect
the
maximum
degree
of
reduction
in
emissions
of
HAP
that
is
achievable.
This
level
of
control
is
commonly
referred
to
as
the
MACT
(
Maximum
Achievable
Control
Technology).

The
MACT
floor
is
the
minimum
control
level
allowed
for
NESHAP
and
is
defined
under
section
112(
d)(
3)
of
the
CAA.
In
essence,
the
MACT
floor
ensures
that
the
standard
is
set
at
a
level
that
assures
that
all
major
sources
achieve
the
level
of
control
at
least
as
stringent
as
that
already
achieved
by
the
better­
controlled
and
lower­
emitting
sources
in
each
source
category
or
subcategory.
For
new
sources,
the
MACT
floor
cannot
be
less
stringent
than
the
emission
control
that
is
achieved
in
practice
by
the
best­
controlled
similar
source.
The
MACT
standards
for
existing
sources
can
be
less
stringent
than
standards
for
new
sources,
but
they
cannot
be
less
stringent
than
the
average
emission
limitation
achieved
by
the
best­
performing
12
percent
of
existing
sources
in
the
category
or
subcategory
(
or
the
best­
performing
five
sources
for
categories
or
subcategories
with
fewer
than
30
sources).
1­
2
In
developing
MACT,
we
also
consider
control
options
that
are
more
stringent
than
the
floor.
We
may
establish
standards
more
stringent
than
the
floor
based
on
the
consideration
of
the
cost
of
achieving
the
emission
reductions,
any
non­
air
quality
health
and
environmental
impacts,
and
energy
requirements.

1.2
Summary
of
the
Final
Rule
1.2.1
Affected
Source
Categories
The
final
rule
will
apply
to
you
if
you
own
or
operate
a
plastic
parts
and
products
surface
coating
facility
that
is
a
major
source,
or
is
located
at
a
major
source,
or
is
part
of
a
major
source
of
HAP
emissions.
We
have
defined
a
plastic
parts
and
products
surface
coating
facility
as
any
facility
engaged
in
the
surface
coating
of
any
plastic
part
or
product.

You
will
not
be
subject
to
the
rule
if
your
plastic
parts
and
products
surface
coating
facility
is
located
at
an
area
source.
An
area
source
of
HAP
is
any
facility
that
has
the
potential
to
emit
HAP
but
is
not
a
major
source.
You
may
establish
area
source
status
by
limiting
the
source's
potential
to
emit
HAP
through
appropriate
mechanisms
available
through
your
permitting
authority.

The
source
category
does
not
include
research
or
laboratory
facilities
or
janitorial,

building,
and
facility
maintenance
operations,
or
hobby
shops
that
are
operated
for
personal
rather
than
commercial
purposes.
The
source
category
also
does
not
include
coating
of
magnet
wire,
coating
of
plastics
to
produce
fiberglass
boats
(
except
post­
mold
coating
of
personal
watercraft
or
their
parts),
or
the
extrusion
of
plastic
onto
a
part
or
product
to
form
a
coating.
Post­
mold
coating
of
personal
watercraft
and
their
parts
is
included
in
the
source
category.

This
source
category
also
does
not
include
surface
coating
of
plastic
parts
and
products
that
would
be
subject
to
certain
other
subparts
of
40
CFR
part
63.
In
particular,
it
does
not
include
the
following
coating
operations:

(
1)
Coating
operations
that
are
subject
to
the
aerospace
manufacturing
and
rework
facilities
NESHAP
(
40
CFR
part
63,
subpart
GG).

(
2)
Operations
coating
plastic
and
wood
that
are
subject
to
the
wood
furniture
NESHAP
(
40
CFR
part
63,
subpart
JJ).
1­
3
(
3)
Operations
coating
plastic
and
metal
parts
of
large
appliances
that
are
subject
to
the
large
appliance
surface
coating
NESHAP
(
40
CFR
part
63,
subpart
NNNN,
67
FR
48254,
July
23,
2002).

(
4)
Operations
coating
plastic
and
metal
parts
of
metal
furniture
that
would
be
subject
to
a
proposed
metal
furniture
surface
coating
NESHAP
(
67
FR
20206,
April
24,
2002).

(
5)
Operations
coating
plastic
and
wood
parts
of
wood
building
products
that
would
be
subject
to
a
proposed
wood
building
products
surface
coating
NESHAP
(
67
FR
42400,
June
21,
2002).

(
6)
In­
mold
and
gel
coating
operations
in
manufacturing
of
reinforced
plastic
composites
that
are
subject
to
the
proposed
reinforced
plastics
composites
production
NESHAP
(
66
FR
40324,
August
2,
2001).

(
7)
Surface
coating
of
parts
that
are
pre­
assembled
from
plastic
and
metal
components,
where
greater
than
50
percent
of
the
coatings
(
by
volume,
determined
on
a
rolling
12­
month
basis)
are
applied
to
the
metal
surfaces,
that
would
be
subject
to
a
proposed
NESHAP
for
miscellaneous
metal
parts
surface
coating.
If
you
can
demonstrate
that
more
than
50
percent
of
coatings
are
applied
to
metal
surfaces,
then
compliance
with
a
proposed
NESHAP
for
miscellaneous
metal
parts
surface
coating
would
constitute
compliance
with
proposed
subpart
PPPP.
You
must
maintain
records
(
such
as
coating
usage
or
part
surface
area)
to
document
that
more
than
50
percent
of
coatings
are
applied
to
metal
surfaces.

(
8)
A
coating
operation
conducted
at
a
source
where
the
source
uses
only
coatings,

thinners
and/
or
other
additives,
and
cleaning
materials
that
contain
no
organic
HAP,
as
determined
according
to
the
procedures
in
the
final
rule.

(
9)
Surface
coating
that
occurs
at
research
or
laboratory
facilities,
or
is
part
of
janitorial,
building,
and
facility
maintenance
operations,
or
that
occurs
at
hobby
shops
operated
for
noncommercial
purposes.

(
10)
Surface
coating
of
plastic
performed
on­
site
at
installations
owned
or
operated
by
the
Armed
Forces
of
the
United
States
(
including
the
Coast
Guard
and
the
National
Guard
of
any
such
State)
or
the
National
Aeronautics
and
Space
Administration
(
NASA),
or
the
surface
coating
of
military
munitions
manufactured
by
or
for
the
Armed
Forces
of
the
United
States
(
including
the
Coast
Guard
and
the
National
Guard
of
any
such
State).
1­
4
(
11)
Surface
coating
where
plastic
is
extruded
onto
plastic
parts
or
products
to
form
a
coating,
and
surface
coating
of
magnet
wire.

If
you
perform
surface
coating
of
plastic
parts
or
products
that
meet
the
applicability
criteria
for
both
the
Automobiles
and
Light­
Duty
Trucks
NESHAP
(
40
CFR
part
63,
subpart
IIII
(
under
development))
and
these
NESHAP,
then
you
may
comply
with
the
requirements
of
the
Automobiles
and
Light­
Duty
Trucks
NESHAP
for
the
surface
coating
of
all
your
plastic
parts
used
in
automobile
or
light­
duty
truck
manufacturing
in
lieu
of
complying
with
each
subpart
separately.

We
have
established
four
subcategories
in
the
plastic
parts
and
products
surface
coating
source
category:
(
1)
general
use
coating,
(
2)
thermoplastic
olefin
(
TPO)
coating,

(
3)
automobile
headlamp
coating,
and
(
4)
assembled
on­
road
vehicle
coating.
The
general
use
coating
subcategory
includes
all
plastic
parts
and
products
coating
operations
except
TPO,

headlamp,
and
assembled
on­
road
vehicle
coating.
This
includes
operations
that
coat
a
wide
variety
of
substrates,
surfaces,
and
types
of
plastic
parts,
as
well
as
more
specialized
coating
scenarios.
The
TPO
subcategory
encompasses
all
materials
used
in
the
surface
coating
of
TPO
substrates
for
automotive
applications.
The
TPO
subcategory
requires
the
use
of
solvents
to
facilitate
proper
adhesion
of
coatings.
The
automotive
lamp
subcategory
addresses
the
unique
requirements
for
surface
coating
of
exterior
automotive
lamps
(
e.
g.,

headlamps,
tail
lamps,
etc.).
Automotive
lamps
are
subject
to
regulatory
requirements
established
by
the
National
Highway
Traffic
Safety
Administration
resulting
in
the
use
of
specific
coatings
to
achieve
required
performance
specifications.
The
assembled
on­
road
vehicle
subcategory
addresses
surface
coating
of
fully­
assembled
vehicles
that
are
physically
larger
than
the
other
plastic
parts
and
products
coated
in
this
source
category
and
that
may
contain
heat­
sensitive
parts.
The
large
size
and
presence
of
heat­
sensitive
parts
make
certain
lower­
HAP
technologies,
such
as
heat­
cured
waterborne
coatings,
infeasible
for
assembled
on­
road
vehicles.
The
assembled
on­
road
vehicle
subcategory
will
affect
primarily
recreational
vehicle
manufacture
and
automobile
body
refinishing.
Each
subcategory
consists
of
all
coating
operations,
including
associated
surface
preparation,
equipment
cleaning,

mixing,
storage,
and
waste
handling.

1.2.2
Characterization
of
Emissions
The
NESHAP
will
regulate
emissions
of
organic
HAP.
Available
emission
data
collected
during
the
development
of
the
NESHAP
show
that
the
primary
organic
HAP
emitted
from
plastic
parts
and
products
surface
coating
operations
include
methyl
ethyl
ketone
1­
5
(
MEK),
methyl
isobutyl
ketone
(
MIBK),
toluene,
and
xylenes.
These
compounds
account
for
over
85
percent
of
this
source
category's
nationwide
organic
HAP
emissions.
Other
organic
HAP
emissions
identified
include
ethylene
glycol
butadiene
(
EGBE)
and
glycol
ethers.
The
majority
of
organic
HAP
emissions
from
a
facility
engaged
in
plastic
parts
and
products
surface
coating
operations
can
be
attributed
to
the
application,
drying,
and
curing
of
coatings.

The
remaining
emissions
are
primarily
from
cleaning
operations.
In
most
cases,
organic
HAP
emissions
from
mixing,
storage,
and
waste
handling
are
relatively
small.

The
organic
HAP
emissions
associated
with
coatings
(
the
term
"
coatings"
includes
protective
and
decorative
coatings
as
well
as
adhesives)
occur
due
to
volatilization
of
solvents
and
carriers.
Coatings
are
most
often
applied
either
by
using
a
spray
gun
in
a
spray
booth
or
by
dipping
the
substrate
in
a
tank
containing
the
coating.
In
a
spray
booth,
volatile
components
evaporate
from
the
coating
as
it
is
applied
to
the
part
and
from
the
overspray.

The
coated
part
then
passes
through
a
flash­
off
area
where
additional
volatiles
evaporate
from
the
coating.
Finally,
the
coated
part
passes
through
a
drying/
curing
oven,
or
is
allowed
to
air
dry,
where
the
remaining
volatiles
are
evaporated.

Organic
HAP
emissions
also
occur
from
the
activities
undertaken
during
cleaning
operations
where
solvent
is
used
to
remove
coating
residue
or
other
unwanted
materials.

Cleaning
in
this
industry
includes
cleaning
of
spray
guns
and
transfer
lines
(
e.
g.,
tubing
or
piping),
tanks,
and
the
interior
of
spray
booths.
Cleaning
also
includes
applying
solvents
to
manufactured
parts
prior
to
coating
application
and
to
equipment
(
e.
g.,
cleaning
rollers,

pumps,
conveyors,
etc.).

Mixing
and
storage
are
other
sources
of
emissions.
Organic
HAP
emissions
can
occur
from
displacement
of
organic
vapor­
laden
air
in
containers
used
to
store
organic
HAP
solvents
or
to
mix
coatings
containing
organic
HAP
solvents.
The
displacement
of
vapor­
laden
air
can
occur
during
the
filling
of
containers
and
can
be
caused
by
changes
in
temperature
or
barometric
pressure,
or
by
agitation
during
mixing.
Volatilization
of
organic
HAP
can
also
occur
during
waste
handling.

Although
most
of
the
coatings
used
in
this
source
category
do
not
contain
inorganic
HAP,
a
few
special
purpose
coatings
used
by
a
few
facilities
in
this
source
category
contain
inorganic
HAP
such
as
chromium
and
lead.
Although
these
emissions
have
not
been
quantified,
we
believe
that
the
inorganic
HAP
emission
levels
are
very
low.
Furthermore,

emissions
of
these
materials
to
the
atmosphere
are
minimal
because
very
few
of
the
facilities
in
this
source
category
use
spray
application
techniques
to
apply
coatings
that
contain
inorganic
1­
6
HAP
compounds.
At
this
time,
it
does
not
appear
that
emissions
of
inorganic
HAP
from
this
source
category
warrant
Federal
regulation.

1.3
Definition
of
Affected
Source
We
define
an
affected
source
as
a
stationary
source,
a
group
of
stationary
sources,
or
part
of
a
stationary
source
to
which
a
specific
emission
standard
applies.
The
proposed
standards
define
the
affected
source
as
the
collection
of
all
operations
associated
with
the
surface
coating
of
plastic
parts
and
products
within
each
of
the
four
subcategories
(
TPO,

headlamps,
assembled
on­
road
vehicle
and
general
use).
These
operations
include
preparation
of
a
coating
for
application
(
e.
g.,
mixing
with
thinners
or
other
additives);
surface
preparation
of
the
plastic
parts
and
products;
coating
application
and
flash­
off;
drying
and/
or
curing
of
applied
coatings;
cleaning
of
equipment
used
in
surface
coating;
storage
of
coatings,
thinners,

and
cleaning
materials;
and
handling
and
conveyance
of
waste
materials
from
the
surface
coating
operations.
The
coating
operation
does
not
include
the
application
of
coatings
using
hand­
held
aerosol
containers.

A
few
facilities
have
coating
operations
in
more
than
one
subcategory.
For
example,
a
few
facilities
have
TPO
coating
operations
that
are
in
the
TPO
coating
subcategory
and
also
have
other
plastic
parts
and
products
coating
operations
that
are
in
the
general
use
coating
subcategory.
In
such
a
case,
the
facility
would
have
two
separate
affected
sources:
(
1)
the
collection
of
all
operations
associated
with
the
surface
coating
of
TPO,
and
(
2)
the
collection
of
all
operations
associated
with
general
use
coating.
Each
of
these
affected
sources
would
be
required
to
meet
the
emission
limits
that
apply
to
its
subcategory.

Another
example
of
a
facility
with
coating
operations
in
more
than
one
subcategory
would
be
a
facility
that
assembles
and
paints
motor
homes.
The
use
of
adhesives,
caulks,

sealants,
and
associated
materials
in
assembling
the
motor
home
would
be
in
the
general
use
coating
subcategory
and
would
constitute
one
affected
source.
The
use
of
coatings
and
associated
materials
in
painting
the
assembled
motor
home
would
be
in
the
assembled
on­
road
vehicle
subcategory
and
would
constitute
a
second
affected
source.

1.4
Emission
Limits
and
Operating
Limits
1.4.1
Emission
Limits
1­
7
The
rule
will
limit
organic
HAP
emissions
from
each
existing
affected
source
using
the
emission
limits
in
Table
1­
1.
The
emission
limits
for
each
new
or
reconstructed
affected
source
are
given
in
Table
1­
2.

Table
1­
1.
Emission
Limits
for
Existing
Affected
Sources
For
any
affected
source
applying
coating
to
...
The
organic
HAP
emission
limit
you
must
meet,
in
kg
organic
HAP
emitted/
kg
coating
solids
used
(
lb
organic
HAP
emitted/
lb
coating
solids
used),
is:

TPO
substrates
0.26
Automotive
headlamps
0.45
Assembled
on­
road
vehicles
1.34
Other
(
general
use)
plastic
parts
and
products
0.16
Table
1­
2.
Emission
Limits
for
New
or
Reconstructed
Affected
Sources
For
any
affected
source
applying
coating
to
...
The
organic
HAP
emission
limit
you
must
meet,
in
kg
organic
HAP
emitted/
kg
coating
solids
used
(
lb
organic
HAP
emitted/
lb
coating
solids
used),
is:

TPO
substrates
0.22
Automotive
Headlamps
0.26
Assorted
on­
road
vehicles
1.34
Other
(
general
use)
plastic
parts
and
products
0.16
1­
8
You
can
choose
from
several
compliance
options
in
the
rule
to
achieve
the
emission
limits.
You
could
comply
by
applying
materials
(
coatings,
thinners
and
other
additives,
and
cleaning
materials)
that
meet
the
emission
limits,
either
individually
or
collectively,
during
each
compliance
period.
You
could
also
use
a
capture
system
and
add­
on
control
device
to
meet
the
emission
limits.
You
could
also
comply
by
using
a
combination
of
both
approaches.

Existing
affected
sources
would
have
to
be
in
compliance
with
the
final
rule
no
later
than
3
years
after
the
effective
date
of
the
final
rule.
The
effective
date
is
the
date
on
which
the
final
rule
is
published
in
the
Federal
Register.
This
the
maximum
allowed
by
the
CAA.

Most
plastic
parts
and
products
sources
would
need
this
3
year
maximum
period
of
time
to
develop
and
test
reformulated
coatings,
particularly
those
that
may
opt
to
comply
using
a
different
lower­
emitting
coating
technology.
In
addition,
time
would
be
needed
to
establish
records
management
systems
required
for
enforcement
purposes.

For
new
sources,
the
CAA
requires
compliance
with
standards
immediately
upon
startup
or
the
effective
date
of
the
final
rule,
whichever
is
later.

1.4.2
Compliance
Options
for
Meeting
Emission
Limits
There
are
three
options
for
complying
with
the
emission
limits,
and
the
testing
and
initial
compliance
requirements
vary
accordingly.
You
may
choose
to
use
one
compliance
option
for
the
entire
affected
source,
or
you
may
use
different
compliance
options
for
different
coating
operations
within
the
affected
source.
You
may
also
use
different
compliance
options
for
the
same
coating
operation
at
different
times.

1.4.2.1
Option
1:
Compliant
Materials
This
option
is
a
pollution
prevention
option
that
allows
you
to
easily
demonstrate
compliance
by
using
low­
HAP
or
non­
HAP
coatings
and
other
materials.
If
you
use
coatings
that,
based
on
their
organic
HAP
content,
individually
meet
the
kg
(
pound
(
lb))
organic
HAP
emitted
per
kg
(
lb)
coating
solids
used
levels
in
the
applicable
emission
limits
and
you
use
non­
HAP
thinners
and
other
additives
and
cleaning
materials,
this
compliance
option
is
available
to
you.
For
this
option,
we
have
minimized
recordkeeping
and
reporting
requirements.
You
can
demonstrate
compliance
by
using
readily
available
purchase
records,

the
amount
of
each
material
(
if
needed)
and
material
safety
data
sheets
(
MSDS)
or
other
manufacturer's
reformulation
data
to
determine
the
organic
HAP
content.
You
would
not
1­
9
need
to
perform
any
detailed
emission
rate
calculations.
For
more
information
on
the
compliance
limits
and
the
methods
to
demonstrate
compliance
with
these
limits,
refer
to
the
preamble
or
the
rule.

1.4.2.2
Option
2:
Compliance
Based
on
the
Emission
Rate
without
Add­
on
Controls
This
option
is,
like
Option
1,
a
pollution
prevention
option.
Option
2
allows
you
to
demonstrate
compliance
based
on
the
organic
HAP
contained
in
the
mix
of
coatings,
thinners
and
other
additives,
and
cleaning
materials
you
use.
This
option
allows
you
the
flexibility
to
use
some
individual
coatings
that
do
not,
by
themselves,
meet
the
kg
(
lb)
organic
HAP
emitted
per
kg
(
lb)
coating
solids
used
levels
in
the
applicable
emission
limits
if
you
use
other
low­
HAP
or
non­
HAP
coatings
such
that
overall
emissions
from
the
affected
source
over
a
12­
month
period
meet
the
emission
limits.
You
must
use
this
option
if
you
use
HAP­
containing
thinners,
other
additives,
and
cleaning
materials
and
do
not
have
add­
on
controls.
You
would
keep
track
of
the
mass
of
organic
HAP
in
each
coating,
thinner
or
other
additive,
and
cleaning
material,
and
the
amount
of
each
material
you
use
in
your
affected
source
each
month
of
the
compliance
period.
You
would
use
this
information
to
determine
the
total
mass
of
organic
HAP
in
all
coatings,
thinners
and
other
additives,
and
cleaning
materials
divided
by
the
total
mass
of
coating
solids
used
during
the
compliance
period.
You
would
demonstrate
that
your
emission
rate(
in
kg
(
lb)
organic
HAP
emitted
per
kg
(
lb)
coating
solids
used)
meets
the
applicable
emission
limit.
You
can
use
readily
available
purchase
records,
including
manufacturer's
formulation
data,
to
determine
the
amount
of
each
coating
or
other
material
you
used
and
the
organic
HAP
in
each
material.
The
rule
contains
equations
that
show
you
how
to
perform
the
calculations
to
demonstrate
compliance.
For
more
information
on
the
compliance
limits
and
the
methods
to
demonstrate
compliance
with
these
limits,
refer
to
the
preamble
or
the
rule.

1.4.2.3
Option
3:
Emission
Rate
with
Add­
on
Controls
Option
This
option
allows
sources
to
use
a
capture
system
and
an
add­
on
pollution
control
device,
such
as
a
combustion
device
or
a
recovery
device,
to
meet
the
emission
limits.
While
we
believe
that,
based
on
typical
emission
characteristics,
most
sources
will
not
use
control
devices,
we
are
providing
this
option
for
sources
that
can
use
control
devices.
Fewer
than
10
percent
of
the
existing
sources
for
which
we
have
data
use
control
devices
and
may
continue
using
the
control
devices
for
compliance
with
the
standards.
Under
this
option,
testing
is
required
to
demonstrate
the
capture
system
and
control
device
efficiency.
Alternatively,
you
may
conduct
a
liquid­
liquid
material
balance
to
demonstrate
the
amount
of
organic
HAP
1­
10
collected
by
your
recovery
device.
The
rule
provides
equations
showing
you
how
to
use
records
of
materials
usage,
organic
HAP
contents
of
each
material,
capture
and
control
efficiencies,
and
coating
solids
content
to
calculate
your
emission
rate
during
the
compliance
period.

If
you
demonstrate
compliance
based
on
this
option,
you
would
demonstrate
that
your
emission
rate
considering
controls
(
in
kg
(
lb)
organic
HAP
emitted
per
kg
(
lb)
of
coating
solids
used)
is
less
than
the
applicable
emission
limit.
For
more
information
on
the
compliance
limits
and
the
test
methods
to
demonstrate
compliance
with
these
limits,
refer
to
the
preamble
or
the
rule.

1.4.3
Operating
Limits
As
mentioned
above,
you
would
establish
operating
limits
as
part
of
the
initial
performance
test
of
a
capture
system
and
control
device
other
than
a
solvent
recovery
system
for
which
you
conduct
liquid­
liquid
material
balances.
The
operating
limits
are
the
minimum
or
maximum
(
as
applicable)
values
achieved
for
capture
systems
and
control
devices
during
the
most
recent
performance
test,
conducted
under
representative
conditions,
that
demonstrated
compliance
with
the
emission
limits.

The
rule
specifies
the
parameters
to
monitor
for
the
types
of
emission
control
systems
commonly
used
in
the
industry.
You
would
be
required
to
install,
calibrate,
maintain,
and
continuously
operate
all
monitoring
equipment
according
to
manufacturer's
specifications
and
ensure
that
the
continuous
parameter
monitoring
systems
(
CPMS)
meet
the
requirements
in
§
63.4568
of
the
proposed
rule.
If
you
use
control
devices
other
than
those
identified
in
the
proposed
rule,
you
would
submit
the
operating
parameters
to
be
monitored
to
the
Administrator
for
approval.
The
authority
to
approve
the
parameters
to
be
monitored
is
retained
by
EPA
and
is
not
delegated
to
States.
For
more
information
on
the
operating
limits
and
the
procedures
to
demonstrate
compliance
with
these
limits,
refer
to
the
preamble
or
the
rule.

If
you
use
a
capture
system
and
control
device
for
compliance,
you
would
be
required
to
develop
and
implement
on
an
ongoing
basis
a
work
practice
plan
for
minimizing
organic
HAP
emissions
from
storage,
mixing,
material
handling,
and
waste
handling
operations.
This
plan
would
include
a
description
of
all
steps
taken
to
minimize
emissions
from
these
sources
(
e.
g.,
using
closed
storage
containers,
practices
to
minimize
emissions
during
filling
and
transfer
of
contents
from
containers,
using
spill
minimization
techniques,
placing
solvent­
laden
1­
11
cloths
in
closed
containers
immediately
after
use,
etc.).
You
would
have
to
make
the
plan
available
for
inspection
if
the
Administrator
requests
to
see
it.

If
you
use
a
capture
system
and
control
device
for
compliance,
you
would
be
required
to
develop
and
operate
according
to
a
designed
plan
during
periods
of
startup,
shutdown,
or
malfunction
of
the
capture
system
and
control
device.

1.5
Continuous
Compliance
Provisions
1.5.1
Emission
Limits
If
you
use
the
compliant
materials
option
(
Option
1),
you
would
demonstrate
continuous
compliance
if
each
coating
meets
the
applicable
emission
limit
and
you
use
no
organic
HAP­
containing
thinners,
other
additives,
or
cleaning
materials.
If
you
use
the
emission
rate
without
add­
on
controls
option
(
Option
2),
you
would
demonstrate
continuous
compliance
if,
for
each
12­
month
compliance
period,
the
ratio
of
kg
(
lb)
organic
HAP
emitted
to
kg
(
lb)
coating
solids
used
is
less
than
or
equal
to
the
applicable
emission
limit.
You
would
follow
the
same
procedures
for
calculating
the
organic
HAP
emitted
to
coating
solids
ratio
that
you
used
for
the
initial
compliance
period.

For
each
coating
operation
on
which
you
use
a
capture
system
and
control
device
(
Option
3)
other
than
a
solvent
recovery
system
for
which
you
conduct
a
liquid­
liquid
material
balance,
you
would
use
the
continuous
parameter
monitoring
results
for
the
month
as
part
of
the
determination
of
the
mass
of
organic
HAP
emissions.
If
the
monitoring
results
indicate
no
deviations
from
the
operating
limits
and
there
were
no
bypasses
of
the
control
device,
you
would
assume
the
capture
system
and
control
device
are
achieving
the
same
percent
emission
reduction
efficiency
as
they
did
during
the
most
recent
performance
test
in
which
compliance
was
demonstrated.
You
would
then
apply
this
percent
reduction
to
the
total
mass
of
organic
HAP
in
materials
used
in
the
controlled
coating
operations
to
determine
the
emissions
from
those
operations
during
the
month.
If
there
were
any
deviations
from
the
operating
limits
during
the
month
or
any
bypasses
of
the
control
device,
you
would
account
for
them
in
the
calculation
of
the
monthly
emissions
by
assuming
the
capture
system
and
control
device
were
achieving
zero
emission
reduction
during
the
periods
of
deviation.
Then
you
would
determine
the
organic
HAP
emission
rate
by
dividing
the
total
mass
of
organic
HAP
emissions
for
the
12­
month
compliance
period
by
the
total
mass
of
coating
solids
used
during
the
12­
month
compliance
period.
Every
month,
you
would
calculate
the
emission
rate
for
the
previous
12­
month
period.
1­
12
1.5.2
Operating
Limits
If
you
use
a
capture
system
and
control
device,
the
rule
would
require
you
to
achieve
on
a
continuous
basis
the
operating
limits
you
establish
during
the
performance
test.
If
the
continuous
monitoring
shows
that
the
capture
system
and
control
device
are
operating
outside
the
range
of
values
established
during
the
performance
test,
you
have
deviated
from
the
established
operating
limits.

If
you
operate
a
capture
system
and
control
device
with
bypass
lines
that
could
allow
emissions
to
bypass
the
control
device,
you
would
have
to
demonstrate
that
captured
organic
HAP
emissions
within
the
affected
source
are
being
routed
to
the
control
device
by
monitoring
for
potential
bypass
of
the
control
device.

If
you
use
an
emission
capture
system
and
control
device
for
compliance,
you
would
be
required
to
implement,
on
an
ongoing
basis,
the
work
practice
plan
you
developed
during
the
initial
compliance
period.
If
you
did
not
develop
a
plan
for
reducing
organic
HAP
emissions
or
you
do
not
implement
the
plan,
this
would
be
a
deviation
from
the
work
practice
standard.

If
you
use
a
capture
system
and
control
device
for
compliance,
you
would
be
required
to
operate
according
to
your
designed
plan
during
periods
of
startup,
shutdown,
or
malfunction
of
the
capture
system
and
control
device.

For
more
information
on
continuous
operating
limits
and
the
compliance
procedures
necessary
to
meet
them,
please
refer
to
the
preamble
or
the
rule.

1.6
Notification
Requirements
Notification
requirements
for
this
rule
are
taken
from
the
General
Provisions
notification
requirements
in
subpart
A
of
40
CFR
63
for
NESHAPs.
They
include:
initial
notifications,
notification
of
performance
test
if
you
are
complying
using
a
capture
system
and
control
device,
notification
of
compliance
status,
and
additional
notifications
required
for
affected
sources
with
continuous
monitoring
systems.
The
General
Provisions
also
require
certain
records
and
periodic
reports.
For
more
information
on
the
recordkeeping
requirements,
notifications,
periodic
reporting,
and
for
startups,
shutdowns,
and
malfunctions,

please
refer
to
the
preamble
or
the
ICR
supporting
statement
in
the
public
docket.
1­
13
1.7
Rationale
for
Selecting
the
Standards
1.7.1
Selection
of
Source
Category
and
Subcategories
The
surface
coating
of
plastic
parts
and
products
is
a
source
category
that
is
on
the
list
of
source
categories
to
be
regulated
because
it
contains
major
sources
which
emit
or
have
the
potential
to
emit
at
least
9.07
Mg
(
10
tons)
of
any
one
HAP
or
at
least
22.7
Mg
(
25
tons)
of
any
combination
of
HAP
annually.
The
rule
would
control
organic
HAP
emissions
from
both
new
and
existing
major
sources.
Area
sources
are
not
being
regulated
under
this
rule.

The
plastic
parts
and
products
surface
coating
category
consists
of
facilities
that
apply
protective
or
decorative
coatings
and
adhesive
coatings
to
plastic
parts
and
products
through
a
post­
mold
coating
process.
The
surface
coating
of
plastic
parts
and
products
includes
any
facility
engaged
in
the
surface
coating
of
plastic
parts
or
products,
including
panels,
housings,

bases,
covers,
and
other
components
formed
of
synthetic
polymers.
We
use
the
plastic
parts
and
products
lists
contained
in
the
Standard
Industrial
Classification
(
SIC)
and
North
American
Industry
Classification
System
(
NAICS)
code
descriptions
to
describe
the
vast
array
of
plastic
parts
and
products.

Due
to
the
broad
scope
of
the
plastic
parts
and
products
surface
coating
source
category,
the
source
category
definition
likewise
needs
to
be
broad
in
order
to
include
the
varieties
of
operations
and
activities
that
might
occur
at
these
facilities.
However,
a
broad
description
has
the
potential
to
unintentionally
include
surface
coating
operations
that
we
would
not
consider
to
be
part
of
the
source
category.
We
intend
the
source
category
to
include
facilities
for
which
the
surface
coating
of
plastic
parts
and
products
is
either
their
principal
activity
or
an
integral
part
of
a
production
process
that
is
the
principal
activity.
Most
coating
operations
are
located
at
plant
sites
that
are
dedicated
to
these
activities.
However,

some
may
be
located
at
sites
for
which
some
other
activity
is
principal,
such
as
automobile
assembly
plants
that
coat
plastic
automobile
parts
or
accessories
off
the
assembly
line.

Co­
located
surface
coating
operations
comparable
to
the
types
and
sizes
of
the
dedicated
plastic
parts
surface
coating
facilities,
in
terms
of
the
coating
operation
and
applicable
emission
control
techniques,
are
included
in
the
source
category.

We
reviewed
the
available
data
and
information
to
identify
a
descriptor
common
to
sources
we
intended
to
include
in
the
category
that
would
further
help
to
describe
the
category.
Based
on
our
review,
we
believe
the
quantity
of
coating
used
is
the
most
equitable
descriptor
for
purposes
of
defining
the
scope
of
the
category.
This
source
category
only
1­
14
includes
facilities
that
use
at
least
100
gallons
of
coatings.
Other
descriptors
that
could
have
been
used
but
were
rejected
because
they
would
either
be
too
difficult
to
implement
or
they
are
not
as
equitable
as
coating
usage
include
production
rate,
quantity
of
emissions,
and
solvent
usage.

The
source
category
does
not
include
research
or
laboratory
facilities
or
janitorial,

building,
and
facility
maintenance
operations,
or
hobby
shops
that
are
operated
for
personal
rather
than
commercial
purposes.
The
source
category
also
does
not
include
coating
of
magnet
wire,
coating
of
plastics
to
produce
fiberglass
boats
(
except
the
post­
mold
coating
of
personal
watercraft
or
their
parts),
or
the
extrusion
of
plastic
onto
a
plastic
part
or
product
to
form
a
coating.
These
activities
and
operations
are
not
comparable
to
the
types
and
sizes
of
the
dedicated
facilities
in
terms
of
coating
operations
and
applicable
control
techniques
and
are
regulated
or
are
being
considered
for
regulation
as
part
of
other
source
categories.
Thus,

they
are
not
considered
to
be
within
the
scope
of
the
source
category.
The
post­
mold
coating
of
personal
watercraft
and
their
parts
is
considered
within
the
scope
of
the
source
category.

The
source
category
also
does
not
include
certain
other
coatings
of
plastic
parts
and
products
that
are
already
being,
or
would
be,
regulated
by
another
NESHAP
as
part
of
a
different
source
category.

The
statute
gives
us
discretion
to
determine
if
and
how
to
subcategorize.
Once
the
floor
has
been
determined
for
new
or
reconstructed
and
existing
affected
sources
for
a
source
category
or
subcategory,
we
must
set
MACT
standards
that
are
no
less
stringent
than
the
MACT
floor.
Such
standards
must
then
be
met
by
all
sources
within
the
source
category
or
subcategory.
A
subcategory
is
a
group
of
similar
sources
within
a
given
source
category.
As
part
of
the
regulatory
development
process,
we
evaluate
the
similarities
and
differences
between
industry
segments
or
groups
of
facilities
comprising
a
source
category.
In
establishing
subcategories,
we
consider
factors
such
as
process
operations
(
type
of
process,

raw
materials,
chemistry/
formulation
data,
associated
equipment,
and
final
products);
emission
characteristics
(
amount
and
type
of
HAP);
control
device
applicability;
and
opportunities
for
pollution
prevention.
We
may
also
consider
existing
regulations
or
guidance
from
States
and
other
regulatory
agencies
in
determining
subcategories.

After
reviewing
survey
responses
from
the
industry,
facility
site
visit
reports,
and
information
received
from
stakeholders
meetings,
we
found
that
the
plastic
parts
and
products
surface
coating
industry
could
be
grouped
into
four
subcategories:
(
1)
general
use
coating,

(
2)
TPO
coating,
(
3)
headlamp
coating,
and
(
4)
assembled
on­
road
vehicle
coating.
The
1­
15
general
use
coating
subcategory
includes
all
plastic
parts
and
products
coating
operations
except
TPO,
headlamp,
and
assembled
on­
road
vehicle
coating.
This
includes
operations
that
coat
a
wide
variety
of
substrates,
surfaces,
and
types
of
plastic
parts,
as
well
as
more
specialized
coating
scenarios.
Each
of
the
subcategories
includes
coating
operations,

including
associated
surface
preparation,
equipment
cleaning,
mixing
and
storage,
and
waste
handling.

The
TPO
coating
is
considered
a
separate
subcategory
from
other
plastic
parts
and
products
coating
operations
because
the
surface
coating
of
TPO
substrates
requires
the
use
of
an
adhesion
promoter
in
order
to
apply
subsequent
coatings
to
the
substrate.
Automotive
headlamp
coating
is
considered
as
a
separate
subcategory
because
these
coating
operations
require
specialized
reflective
argent
coatings
and
hard
clear
coatings
to
meet
U.
S.
Department
of
Transportation
Motor
Vehicle
Safety
Standards
for
reflectivity,
brightness,
color,
and
other
performance
criteria.
Assembled
on­
road
vehicle
coating
is
considered
a
separate
subcategory
because
these
coating
operations
are
performed
on
fully­
assembled
vehicles
that
may
contain
heat
sensitive
parts.
In
addition,
fully
assembled
on­
road
vehicles
are
physically
larger
than
the
other
parts
and
products
coated
in
this
source
category.
The
large
size
and
presence
of
heat
sensitive
parts
make
certain
lower­
HAP
technologies,
such
as
heat­
cured
waterborne
coatings,
not
feasible
for
use
on
fully
assembled
on­
road
vehicles
and
make
it
technically
difficult
for
these
sources
to
achieve
the
same
emission
level
as
sources
that
do
not
coat
assembled
on­
road
vehicles.
An
assembled
on­
road
vehicle
coating
operation
is
considered
part
of
this
subcategory
if
greater
than
50
percent
of
the
surface
being
coated
on
a
vehicle
is
plastic.

1.8
Selection
of
Affected
Source
within
Selected
Source
Category
and
Subcategories
When
emission
standards
are
based
on
a
collection
of
emissions
sources
or
total
facility
emissions,
we
select
an
affected
source
based
on
that
same
collection
of
emission
sources
or
the
total
facility
as
well.
This
approach
for
defining
the
affected
source
broadly
is
particularly
appropriate
for
industries
where
a
single
emission
standard
encompassing
multiple
emission
points
within
the
plant
provides
the
opportunity
and
incentive
for
owners
and
operators
to
utilize
control
strategies
that
are
more
cost
effective
than
if
separate
standards
were
established
for
each
emission
point
within
a
facility.

The
affected
source
for
these
standards
is
broadly
defined
to
include
all
operations
associated
with
the
coating
of
plastic
parts
and
products
and
the
cleaning
of
products,

substrates
or
coating
operation
equipment
in
a
subcategory
(
i.
e.,
TPO
coating,
headlamp
1­
16
coating,
assembled
on­
road
vehicle
coating,
or
general
use
coating).
These
operations
include
storage
and
mixing
of
coatings
and
other
materials;
surface
preparation
of
the
plastic
parts
and
products
prior
to
coating
application;
coating
application
and
flash­
off,
drying
and
curing
of
applied
coatings;
cleaning
operations;
and
waste
handling
operations.

Because
we
are
assuming
that
all
the
organic
HAP
in
the
materials
entering
the
affected
source
are
volatilized
(
emitted),
emissions
from
operations
occurring
within
the
affected
source
(
e.
g.,
mixing
operations
and
storage)
are
accounted
for
in
the
estimate
of
total
materials
usage
at
the
affected
source.
A
broad
definition
of
the
affected
source
was
selected
to
provide
maximum
flexibility
in
complying
with
the
emission
limits
for
organic
HAP.
In
planning
its
compliance,
each
facility
can
select
among
available
coatings,
thinners
and
other
additives,
and
cleaning
materials,
as
well
as
the
use
of
emissions
capture
and
add­
on
control
systems,
to
comply
with
the
emission
limits
for
each
subcategory
in
the
most
cost­
effective
manner.
Additional
information
on
the
plastic
parts
and
products
surface
coating
operations
selected
for
regulation,
and
other
operations,
are
included
in
the
docket
for
the
standards.

The
MACT
floor
analysis
was
performed
using
a
sourcewide
emission
rate
approach
for
each
of
the
four
subcategories
mentioned
above.
Because
organic
HAP
emissions
are
directly
related
to
the
materials
used
by
these
sources,
and
since
it
is
very
difficult
to
estimate
the
emissions
that
occur
in
any
one
area
within
the
affected
source,
an
emission
rate
approach
for
affected
sources
in
each
subcategory
is
the
most
feasible
way
to
determine
emission
limits.

The
emission
rate
approach
covers
the
emissions
from
all
areas
within
the
affected
source
for
each
subcategory.

To
determine
the
existing
and
new
source
MACT
floor
for
each
subcategory,
we
determined
the
organic
HAP
emission
rate
for
each
facility
in
units
of
kg
(
lb)
organic
HAP
emitted
per
kg
(
lb)
of
coating
solids
used
for
each
subcategory.
We
then
ranked
the
sources
in
each
subcategory
from
lowest
to
highest
emission
rate
to
identify
the
best­
performing
sources.
We
then
used
information
obtained
from
industry
survey
responses
and
subsequent
changes
and
clarifications
received
from
facilities
to
estimate
the
sourcewide
organic
HAP
emission
rate
from
each
survey
respondent.
If
add­
on
controls
were
reported,
their
capture
and
control
efficiencies
were
taken
into
account.
Both
major
and
"
synthetic
minor"
sources
were
included
in
the
population
for
determining
MACT
floor
emission
limits.

Table
1­
1
above
provides
the
MACT
floor
emission
limits
for
existing
sources
by
subcategory.
These
limits
were
reviewed
to
assess
the
achievability
of
the
emissions
levels
by
affected
sources,
and
it
was
determined
that
all
sources
could
achieve
the
existing
source
1­
17
MACT
floor
emission
rate
for
their
subcategory.
For
more
information,
please
refer
to
the
public
docket.

Table
1­
2
above
provides
the
MACT
floor
emission
limits
for
new
sources
by
subcategory.
As
one
can
see
by
comparison
of
Tables
1
and
2,
the
new
source
MACT
floor
emission
limits
are
the
same
as
the
existing
source
limits
for
the
general
use
coating
and
the
assembled
on­
road
vehicle
coating
subcategories.
The
new
source
MACT
levels
are
more
stringent
for
the
other
two
subcategories.

For
the
general
use
coating
subcategory,
the
existing
and
new
source
MACT
floors
are
the
same
because
none
of
the
sources
with
emissions
rates
lower
than
the
existing
source
MACT
floor
emission
rates
represent
a
similar
source
that
could
establish
a
new
source
level
for
the
range
of
new
sources
in
the
subcategory.
For
the
assembled
on­
road
vehicle
coating
subcategory,
the
existing
and
new
source
MACT
floors
are
the
same
because
the
diversity
of
sources
is
such
that
those
sources
emission
rates
lower
than
the
existing
source
MACT
level
are
not
representative
of
the
possible
range
of
new
sources
in
the
subcategory.
This
determination
is
based
on
review
of
coating
operations
observed
by
EPA
during
site
visits
and
among
facilities
in
the
MACT
database.

For
the
TPO
subcategory,
the
new
source
MACT
floor
is
more
stringent
than
the
existing
source
MACT
level
because
the
best­
performing
single
source
uses
a
coating
process
that
can
be
feasibly
employed
on
TPO
substrates
at
other
facilities.
For
the
headlamp
coating
subcategory,
the
new
source
MACT
floor
is
more
stringent
than
the
existing
source
MACT
level
because
the
best­
performing
single
source
uses
coating
processes
that
the
Agency
believes
are
feasible
for
new
coating
processes.
These
processes
coat
automotive
headlamps
utilizing
low­
HAP,
ultraviolet
(
UV)­
cure
clearcoat
technology
and
vacuum
metallizing
technology
on
the
reflective
lamp
bodies.

1.9
Beyond
the
Floor
Alternatives
The
Agency
is
required
to
establish
MACT
floors
for
NESHAPs
established
under
Title
III
of
the
Clean
Air
Act
Amendments
of
1990.
The
Agency
can,
however,
set
these
standards
beyond
the
MACT
floor.
We
do
this
by
identifying
and
considering
any
reasonable
regulatory
alternatives
that
are
beyond
the
floor,
taking
into
account
emission
reductions,

cost,
non­
air
quality
health
and
environmental
impacts,
and
energy
requirements.
These
alternatives
may
be
different
for
new
and
existing
sources,
and
separate
standards
may
be
established
for
new
and
existing
sources.
1­
18
No
options
beyond
the
MACT
floor
could
be
identified
for
the
general
use
coating
subcategory
and
the
assembled
on­
road
vehicle
subcategory
that
were
technically
feasible
for
all
new
or
existing
facilities.

For
the
TPO
coating
subcategory,
we
are
not
requiring
beyond
the
floor
emission
reductions.
The
use
of
a
waterborne
coating
technology
was
identified
as
a
beyond
the
floor
option,
but
was
not
recommended
as
such
since
the
Agency
determined
that
the
additional
cost
of
going
beyond
the
floor
is
not
warranted
at
this
time
without
a
further
evaluation
of
health
and
environmental
risks.
This
is
due
to
the
high
cost
of
retrofitting
an
existing
TPO
source
with
the
waterborne
coating
technology
and
the
small
additional
emission
reduction
beyond
the
MACT
floor
level.

For
the
headlamp
coating
subcategory,
we
are
not
requiring
beyond
the
floor
emission
reductions.
The
use
of
low­
HAP
UV­
cure
clearcoat
and
vacuum
metallizing
were
considered
but
not
recommended
as
beyond
the
floor
options
because
requiring
existing
sources
to
switch
to
these
technologies
could
require
costly
retrofits
to
an
existing
headlamp
coating
operation.

The
Agency
then
determined
that
the
additional
cost
of
going
beyond
the
floor
is
not
warranted
at
this
time
without
a
further
evaluation
of
health
and
environmental
risks.

Add­
on
controls
were
also
reviewed
to
identify
beyond
the
floor
options,
but
no
controls
of
this
type
were
found
to
be
technically
feasible
generally
for
any
of
the
four
subcategories.
Therefore,
add­
on
controls
were
not
considered
as
a
beyond­
the­
floor
option.

Therefore,
we
base
the
standards
for
existing
sources
on
the
existing
source
MACT
floors
for
the
subcategories,
and
the
same
is
true
for
new
sources.

For
more
information,
please
refer
to
the
MACT
floor
memorandum
in
the
public
docket
(
Burlew,
2002).

1.10
Format
of
the
Standards
The
format
of
the
standards
is
an
emission
rate
expressed
as
the
mass
of
organic
HAP
emitted
per
mass
of
coating
solids
used.
This
format
would
allow
coating
operators
flexibility
in
choosing
any
combination
of
means
(
e.
g.,
coating
reformulation,
use
of
lower­
HAP
or
non­
HAP
materials)
that
is
workable
to
comply
with
the
emission
limits.

We
selected
mass
of
coating
solids
used
as
a
component
of
the
proposed
format
to
normalize
the
rate
of
organic
HAP
emissions
across
all
sizes
and
types
of
facilities.
We
also
selected
kg
(
lb)
organic
HAP
emitting
per
kg
(
lb)
coating
solids
used
because
this
is
consistent
1­
19
with
the
data
available
though
Material
Safety
Data
Sheets
and
other
manufacturer's
formulation
data.
Considering
the
primary
means
of
compliance
will
likely
be
low­
and
no­
HAP
coatings
and
other
materials,
this
format
best
ensures
comparable
control
levels
being
achieved
by
all
affected
sources.
Also,
this
format
allows
sources
flexibility
to
use
a
combination
of
emission
capture
and
control
systems,
as
well
as
low­
HAP
content
coatings
and
materials.

In
lieu
of
emissions
standards,
section
112(
h)
of
the
CAA
allows
work
practice
standards
or
other
requirements
to
be
established
when
a
pollutant
cannot
be
emitted
through
a
conveyance
or
capture
system,
or
when
measurement
is
not
practicable
because
of
technological
and
economic
limitations.
Many
plastic
parts
and
products
facilities
use
some
type
of
work
practice
measure
to
reduce
HAP
emissions
from
mixing,
cleaning,
storage,
and
waste
handling
areas
as
part
of
their
standard
operations.
However,
we
do
not
have
data
to
quantify
accurately
the
emission
reductions
achievable
by
such
measures.

1.11
Testing
and
Initial
Compliance
Requirements
The
standards
allow
you
to
choose
among
several
options
to
demonstrate
compliance
with
the
organic
HAP
limits:
compliant
materials
(
i.
e.,
coatings
and
other
materials
with
low
or
no
organic
HAPs);
emission
rate
without
add­
on
controls,
or
emission
rate
with
add­
on
controls.

For
the
compliant
materials
option,
the
source
must
document
the
organic
HAP
content
of
all
coatings
on
an
as­
received
basis
and
show
that
each
is
less
than
the
applicable
emissions
limit.
Manufacturer's
formulation
data
can
be
used
to
demonstrate
the
HAP
content
of
each
material
and
solids
content
of
each
coating.
For
more
information
on
this
option
and
test
methods
used
to
identify
organic
HAP
and
solids
content,
refer
to
the
preamble
or
the
monitoring
rationale
memo
in
the
public
docket
(
Burlew,
2002).

For
the
emission
rate
with
add­
on
controls
option,
you
would
be
required
to
conduct
an
initial
performance
test
of
the
system
to
determine
its
overall
control
efficiency
using
EPA
Method
25
or
25A
depending
on
the
type
of
control
device
and
outlet
concentration.

Capture
efficiency
would
also
have
to
be
determined
using
various
EPA
Methods
(
204
and
204A
 
204F).
For
a
solvent
recovery
system
for
which
you
conduct
a
liquid­
liquid
material
balance,
you
would
determine
the
quantity
of
volatile
matter
applied
and
the
quantity
recovered
during
the
initial
compliance
period
to
determine
its
overall
control
efficiency.
For
1­
20
both
cases,
the
overall
control
efficiency
would
be
combined
with
the
monthly
mass
of
organic
HAP
in
the
coatings
and
other
materials
used
to
calculate
the
monthly
organic
HAP
emissions
in
kg
(
lb)
HAP
emitted.
The
monthly
amount
of
coating
solids
in
kg
(
lb)
would
also
be
determined.
For
more
information
on
this
option
and
test
methods,
refer
to
the
preamble
or
memos
in
the
public
docket
(
Burlew,
2002).

1.12
Costs
and
Emission
Reductions
of
the
Standards
1.12.1
Cost
Estimates
The
total
capital
cost
for
existing
sources
is
estimated
to
be
$
804,000.
These
costs
include
monitoring
costs.
These
capital
costs
are
primarily
based
on
all
existing
source
facilities
to
purchase
stainless
steel
application
equipment
in
order
to
meet
the
emission
limits.

The
nationwide
annualized
costs
include
the
costs
for
facilities
to
purchase
reformulating
coatings
along
with
the
administrative,
insurance,
capital
recovery,
and
taxes
and
overhead
associated
with
the
capital
investment.
The
annualized
costs,
including
monitoring,

recordkeeping,
and
reporting,
for
existing
sources
is
estimated
to
be
about
$
10.7
million
(
1997$).
The
total
capital
cost
for
new
sources
is
estimated
to
be
$
28,000.
These
costs
include
monitoring
costs.
The
nationwide
annual
costs,
including
monitoring,
recordkeeping,

and
reporting,
for
existing
sources
is
estimated
to
be
about
$
194,000
(
1997$).
New
sources
are
assumed
to
incur
a
capital
cost
associated
with
using
application
equipment
made
of
stainless
steel
to
resist
corrosion
that
might
occur
if
using
low­
HAP,
waterborne
coatings.

New
sources
will
also
incur
an
annual
cost
increase
associated
with
purchasing
reformulated
lower­
HAP
coatings.
The
costs
for
new
sources
are
also
based
on
an
estimate
of
six
new
sources
being
constructed
within
5
years
after
issuance
of
the
final
standards.
This
estimate
comes
from
a
growth
projection
for
new
sources
in
this
industry
of
4
percent
over
a
5
year
period.
This
estimate
was
based
on
reviewing
Census
data
for
the
major
SIC/
NAICS
codes
represented
in
the
plastic
parts
existing
source
database.

This
4
percent
growth
projection
was
applied
to
the
number
of
existing
sources
mapped
to
each
model
plant
to
determine
how
many
new
facilities
are
expected
for
each
model
over
the
5
year
period.
After
rounding
to
discount
any
fractional
results,
this
calculation
estimates
six
new
facilities
over
the
5
year
period.
For
more
information
on
the
methodology
used
to
estimate
the
number
of
affected
new
sources,
please
refer
to
the
growth
methodology
memo
in
the
public
docket.
1­
21
These
costs,
as
well
as
the
emissions
reductions,
are
calculated
assuming
the
majority
of
source
would
comply
by
using
lower­
HAP
or
non­
HAP
containing
coatings
and
cleaning
materials
because
such
materials
are
generally
available,
and
add­
on
controls
would
not,
as
mentioned
above,
be
technically
feasible
for
typical
facilities.
We
also
assumed
that
facilities
currently
equipped
with
add­
on
controls
would
continue
to
operate
these
systems
and
would
perform
the
required
performance
tests
and
parameter
monitoring.

1.12.2
Emissions
and
Emission
Reductions
Estimates
The
1997
nationwide
baseline
organic
HAP
emissions
for
the
202
existing
major
source
plastic
parts
and
products
surface
coatings
facilities
of
which
EPA
is
aware
are
estimated
to
be
9,820
tons
per
year.
Implementation
of
the
emissions
standards
as
proposed
would
reduce
these
emissions
by
7,560
tons
per
year,
or
about
80
percent.
As
mentioned
earlier
in
Section
1.2.2,
the
major
HAP
emitted
from
the
plastic
parts
and
products
surface
coating
industry
include
MEK,
MIBK,
toluene,
and
xylenes.
These
compounds
account
for
over
85
percent
of
the
nationwide
HAP
emissions
from
this
source
category.
Other
HAP
identified
in
emissions
include
ethylene
glycol
monobutyl
ether
(
EGBE)
and
glycol
ethers.

For
new
sources,
nationwide
baseline
organic
HAP
emissions
are
estimated
at
520
tons
per
year.
Implementation
of
the
emissions
standards
would
reduce
these
emissions
by
440
tons
per
year,
or
about
85
percent.

1.13
Health
Effects
from
Exposure
to
HAP
Emissions
The
major
HAP
emitted
from
the
plastic
parts
and
products
surface
coating
industry
include
MEK,
MIBK,
toluene,
and
xylenes.
Other
HAP
identified
in
emissions
include
ethylene
glycol
monobutyl
ether
and
glycol
ethers.
The
HAP
that
would
be
controlled
with
this
proposed
rule
are
associated
with
a
variety
of
adverse
health
effects.
These
adverse
health
effects
include
chronic
health
disorders
(
e.
g.,
birth
defects
and
effects
on
the
central
nervous
system,
liver,
and
heart),
and
acute
health
disorders
(
e.
g.,
irritation
of
the
lung,
skin,

and
mucous
membranes,
and
effects
on
the
central
nervous
system).

We
do
not
have
the
type
of
current
detailed
data
on
each
of
the
facilities
covered
by
the
proposed
emission
standards
for
this
source
category,
and
the
people
living
around
the
facilities,
that
would
be
necessary
to
conduct
an
analysis
to
determine
the
actual
population
exposures
to
the
HAP
emitted
from
these
facilities
and
potential
for
resultant
health
effects.

Therefore,
we
do
not
know
the
extent
to
which
the
adverse
health
effects
described
above
occur
in
the
populations
surrounding
these
facilities.
However,
to
the
extent
the
adverse
1­
22
effects
do
occur,
the
rule
would
reduce
emissions,
subsequent
exposures,
and
associated
health
effects.
2­
1
SECTION
2
INDUSTRY
PROFILE
2.1
Introduction
The
U.
S.
Environmental
Protection
Agency's
(
EPA's)
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
will
regulate
organic
hazardous
air
pollutant
(
HAP)

emissions
released
during
surface
coating
operations
of
plastic
parts
and
products.
The
plastic
parts
and
products
surface
coating
category
consists
of
facilities
that
apply
protective,

decorative,
or
functional
coatings
and
adhesives
to
plastic
substrates
through
a
post­
mold
coating
process
only.
These
goods
fall
into
two
major
product
groups:

automotive/
transportation
and
business
machines/
electronics.
In
addition
to
these
groups,

surface­
coated
plastic
parts
are
incorporated
in
a
wide
range
of
miscellaneous
products,

ranging
from
toys
to
signs,
that
are
also
covered
by
the
NESHAP.
Table
2­
1
provides
a
listing
of
the
products
produced
by
affected
entities,
and
the
respective
six­
digit
North
American
Industry
Classification
System
(
NAICS)
codes
of
the
industries
to
which
those
entities
belong.
This
table
is
not
intended
to
be
exhaustive,
but
rather
provides
a
guide
for
readers
regarding
entities
likely
to
be
covered
by
this
NESHAP.

Plastic
parts
surface
coating
may
be
performed
by
°
captive
operators
in
the
same
organization
as
the
product
manufacturer,

°
commercial
suppliers
that
fabricate
and
coat
plastic
parts
and
sell
them
to
the
product
manufacturer,

°
commercial
suppliers
that
surface­
coat
plastic
parts
on
a
toll
basis
for
the
product
manufacturer,
or
°
commercial
suppliers
that
coat
plastic
parts
and
products
as
part
of
refurbishment
(
EPA,
1994).

The
economic
effects
of
the
rule
are
conditional
on
the
technology
for
producing
the
plastic
parts
and
their
costs
of
production;
the
value
of
the
parts
to
users;
and
the
organization
of
the
industries
engaged
in
plastic
parts
production,
coating,
and
use.
This
2­
2
Table
2­
1.
Industries
Manufacturing
Surface­
Coated
Plastic
Parts
Includes
Manufacturing
of:
NAICS
Code
Automobile
and
Truck
Parts
Automobile
manufacturing
336111
Light
truck
and
utility
vehicle
manufacturing
336112
Heavy
duty
truck
manufaturing
336120
Motor
vehicle
body
manufacturing
336211
Motor
home
manufacturing
336213
Travel
trailer
and
camper
manufacturing
336214
Vehicular
lighting
equipment
manufacturing
336321
Other
motor
vehicle
electrical
and
electronic
equipment
manufaturing
336322
Motor
vehicle
steering
and
suspension
component
(
except
spring)
manufacturing
336330
Motor
vehicle
brake
system
manufacturing
336340
All
other
motor
vehicle
parts
manufacturing
336399
Motorcycles,
bicycles,
and
parts
manufacturing
336991
Military
armored
vehicle,
tank,
and
tank
component
manufacturing
336992
All
other
transportation
equipment
manufacturing
336999
Business
Machine
and
Computer
Equipment
Parts
Office
machinery
manufacturing
333313
Electronic
computer
manufacturing
334111
Computer
terminal
manufacturing
334113
Other
computer
peripheral
equipment
manufacturing
334119
Watch,
clock,
and
part
manufacturing
334518
Lead
pencil
and
art
good
manufacturing
339942
Miscellaneous
Products
Plastics
pipe
and
pipe
fitting
manufacturing
326122
Polystyrene
foam
product
maufacturing
326140
Urethane
and
other
foam
product
(
except
polystyrene)
manufacturing
326150
All
other
plastics
product
manufacturing
326199
Residential
electric
lighting
fixture
manufacturing
335121
Laboratory
apparatus
and
furniture
manufacturing
339111
(
continued)
2­
3
profile
provides
background
information
on
these
topics
organized
within
a
conventional
economic
framework.

°
Section
2.2
includes
a
description
of
surface
coating
processes
for
plastic
parts,
with
discussions
of
the
processes
and
inputs,
types
of
coated
plastic
parts,
the
costs
of
coating,
and
the
characteristics
of
coating
facilities.

°
Section
2.3
describes
the
characteristics,
uses,
and
consumers
of
surface­
coated
plastic
parts
and
substitution
possibilities
in
consumption.

°
Section
2.4
discusses
the
industry's
organization
and
provides
information
on
market
structure,
and
companies
that
own
potentially
affected
plants.
Special
attention
is
given
to
data
on
small
businesses
for
future
use
in
evaluating
the
impact
on
these
entities
as
required
by
the
Small
Business
Regulatory
Enforcement
and
Fairness
Act
(
SBREFA)
and
the
Regulatory
Flexibility
Act
(
RFA).

°
Section
2.5
presents
data
on
trends
in
the
markets
for
goods
for
which
surfacecoated
plastic
parts
are
an
input.
The
section
includes
data
on
production,
consumption,
net
exports,
and
prices
in
industries
affected
by
this
NESHAP.
Table
2­
1.
Industries
Manufacturing
Surface­
Coated
Plastic
Parts
(
continued)

Includes
Manufacturing
of:
NAICS
Code
Miscellaneous
Products
(
continued)

Costume
jewelry
and
novelty
manufacturing
339914
Sporting
and
athletic
goods
manufacturing
339920
Doll
and
stuffed
toy
manufacturing
339931
Game,
toy,
children's
vehicle
manufacturing
339932
Sign
manufacturing
339950
Musical
instrument
manufacturing
339992
Note:
The
above
list
is
not
meant
to
be
an
exhaustive
list
of
affected
industries,
but
rather
a
list
to
illustrate
the
types
of
industries
likely
to
be
affected
by
this
rule.

Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1997
Economic
Census:
The
Bridge
Between
NAICS
and
SIC.
<
http://
www.
census.
gov/
epcd/
ec97brdg/>.
Last
updated
on
June
27,
2000.
2­
4
Productive
noncapital
inputs
(
labor,
materials,
energy)
Emissions
Surface­
coated
part
Abatement
inputs
(
labor,
materials,
energy,
capital)
Pollutant
Productive
capital
Surface
coating
process
Abatement
activity
Figure
2­
1.
The
Firm's
Production
Diagram
2.2
Production,
Costs,
and
Producers
The
production
of
surface­
coated
plastic
parts
releases
organic
HAP
emissions.
This
section
describes
the
types
of
coated
plastic
parts
and
products,
the
inputs
needed
for
production
of
those
parts,
the
production
process,
and
the
points
at
which
the
process
generates
these
emissions.
It
describes
some
of
the
costs
associated
with
producing
surfacecoated
plastic
parts.
Finally,
it
characterizes
the
producers
of
plastic
parts
that
will
be
affected
by
the
NESHAP.

2.2.1
Surface
Coating
of
Plastic
Parts
The
production
process
characterizes
the
relationship
between
the
inputs
to
a
productive
activity
and
its
output(
s).
Figure
2­
1
illustrates
the
productive
activity
of
surface
coating
plastic
parts.
The
appropriate
quantities
of
labor
services,
materials,
energy,
and
capital
services
are
combined
according
to
the
relevant
rules
of
production
to
produce
a
given
quantity
of
surface­
coated
parts,
where
pollutants
(
organic
HAPs)
are
a
by­
product
of
that
activity.
The
quantity
of
pollutants
that
result
from
the
surface
coating
process
is
a
direct
result
of
the
combination
of
inputs
used
in
that
process.
The
pollutants
may
or
may
not
be
emitted
into
the
atmosphere
depending
on
the
efficiency
of
pollution
abatement
activities.

This
section
describes
the
surface
coating
process
in
terms
of
the
products
that
result
from
the
surface
coating
process,
the
characteristics
of
production
inputs,
and
the
characteristics
of
the
coating
process
itself.
2­
5
2.2.1.1
Surface­
Coated
Plastic
Parts
Surface­
coated
plastic
parts
include
automobile
and
light
duty
truck
parts
(
including
other
small
passenger
motor
vehicles
like
motorcycles
and
golf
carts),
business
machine
and
computer
equipment
parts,
and
some
miscellaneous
plastic
parts
ranging
from
laboratory
apparatus
to
toys.

Automobile
and
Light
Duty
Truck
Parts.
Surface­
coated
plastic
parts
are
standard
components
of
all
passenger
vehicles
such
as
cars,
light
duty
trucks,
and
motorcycles.
In
1994,
about
8
percent
of
the
average
weight
of
a
new
passenger
car
was
made
of
plastic
parts
(
EPA,
1995).
The
wide
variety
of
automobile
and
light
duty
trucks
made
of
plastic
or
plastic
composites
includes
coated
plastic
interior
parts,
exterior
body
parts,
and
lighting
equipment
as
well
as
more
functional
parts
such
as
gas
tanks.
In
addition,
some
motorcycle,
golf
cart,

and
motor
home
parts
are
coated
plastic.

Interior
Parts.
Instrument
board
assemblies,
handles,
seat
belt
parts,
air
bag
covers,

dashboards,
and
door
linings
are
often
coated
plastic
parts.

Exterior
Body
Parts/
Lighting
Equipment.
Coated
plastic
parts
used
on
the
exterior
of
automobile
bodies
include
°
body
panels,
bumpers,
grills,
fenders,
hoods,
and
wheel
covers;

°
headlamp
and
taillight
bezels
and
lamp
covers,
mirror
housings,
and
windshield
frames;

°
truck
cabs,
beds,
bodies,
and
tops;
and
°
plastic
handles,
seats
and
saddles
for
motorcycles.

Functional
Parts.
Functional
coated
plastic
vehicle
parts
include
gas
tanks,
steering
assemblies,
and
suspension
parts.

Business
Machine
and
Computer
Equipment
Parts.
Computers,
calculating
and
accounting
machines,
and
other
office
machines
are
often
encased
in
plastic
housings.

Handles,
buttons,
and
other
external
machine
parts
are
also
made
of
plastic.

Miscellaneous
Parts.
There
is
a
wide
variety
of
miscellaneous
coated
plastic
parts
and
products:

°
coated
plastic
wires
and
plastic
housings
for
electrical
outlets;
2­
6
°
laboratory
apparatus
and
furniture;

°
musical
keyboard
housings,
piano
and
keyboard
keys
and
buttons,
and
entire
musical
instruments
like
recorders;

°
dolls
and
stuffed
toys,
game
parts,
toys,
and
children's
vehicles;

°
sporting
and
athletic
goods,
such
as
helmets,
backboards,
balls,
bicycles,
and
kayaks;

°
aquarium
accessories,
boxes,
brush
handles,
drums,
siding,
hardware,
lamp
bases,
tool
handles,
life
jackets,
and
shutters;

°
costume
jewelry;
and
°
signs
and
advertising
display
cases.

2.2.1.2
Inputs
The
surface
coating
process
requires
material
inputs
as
well
as
labor,
capital
services,

and
energy.
The
primary
material
inputs
into
the
coating
process
are
plastic
parts
and
coatings.
Necessary
capital
equipment
most
often
includes
spray
guns,
spray
booths,

conveyor
lines,
filtration
systems,
and
curing
ovens.

Material
Inputs.

Plastic
Parts.
As
an
input
into
the
coating
process,
the
important
characteristics
of
plastic
parts
are
the
type
of
resin
they
are
made
from
and
their
shape
and
size.
The
shape
and
size
of
the
part
affect
the
coating
process
in
that
large
parts
require
larger
facilities,
spray
booths,
and
curing
ovens,
and
parts
with
complex
shaping
may
require
special
handling
for
complete
and
even
coating
coverage.
The
resins
used
to
form
plastic
parts
have
certain
properties
that
are
critical
in
determining
how
to
prepare
the
surface
for
coating,
how
well
the
various
coatings
will
adhere
to
the
surface,
and
what
type
of
curing
methods
are
appropriate.

Plastic
parts
that
are
to
be
coated
are
first
manufactured
out
of
one
of
two
types
of
resins:
thermoplastic
or
thermoset.
Properties
important
to
surface
coaters
include
solvent
resistance
and
the
temperature
at
which
the
material
can
be
baked.
Tables
2­
2
and
2­
3
list
common
thermoplastic
resins,
thermoset
resins,
and
the
abbreviations
generally
used
to
describe
the
different
resins.
2­
7
Table
2­
2.
Types
of
Common
Thermoplastic
and
Thermoplastic
Elastomer
Resins
Resin
or
Composite
Abbreviation
Acetal
Acrylic
Cellulosics
Ketone­
based
resins
Nylon
Polyarylate
Polybutylene
terephthalate
PBT
Polycarbonate
Polycarbonate
and
polybutylene
terephthalate
(
PBT)
blend
XENOY
Polyimide
Polyolefins
(
blends
of
polypropylene,
polyethylene
and
its
copolymers)
TPO
Polyethylene
terephthalate
PET
Polypropylene
PP
Polyphenylene
oxide
(
modified)
PPO
Polyurethane
TPU
Polyvinyl
chloride
PVC
Styrenic
resins
Acrylic­
styrene­
acrylonitrite
ASA
Acrylonitrile
butadiene
styrene
ABS
Polystyrene
Styrenic
resins
(
continued)

Styrene­
maleic
anhydride
S­
Ma
Styrene
block
copolymer
SBC
Styrene
butadiene­
styrene
SBS
Styrene­
isoprene­
styrene
SIS
Styrene­
ethylene­
butylene­
styrene
SEBS
Thermoplastic
polyester
TPEa
a
TPE
is
also
used
as
the
abbreviation
for
the
group
of
resins
known
as
thermoplastic
elastomers
 
a
group
of
specialty
rubbers
with
the
processing
characteristics
of
thermoplastics
and
the
elasticity
of
rubber.

Sources:
U.
S.
Environmental
Protection
Agency.
1994.
Alternative
Control
Techniques
Document:
Surface
Coating
of
Automotive/
Transportation
and
Business
Machine
Plastic
Parts.
EPA
435/
R­
94­
017.
Research
Triangle
Park,
NC:
U.
S.
Environmental
Protection
Agency.

Howlett,
Elizabeth.
1998.
"
Thermoplastic
Elastomers
in
the
Auto
Industry:
Increasing
Use
and
the
Potential
Implications."
Industry,
Trade,
and
Technology
Review
January:
28
 
41.
2­
8
Table
2­
3.
Types
of
Thermoset
Resins
Resin
or
Composite
Abbreviation
Epoxy
Melamines
Phenolic
Polyurathanes
PU
Thermoset
polyester
2­
9
Coatings.
Coatings
provide
a
protective,
decorative,
or
functional
film
to
plastic
parts
and
products.
Coatings
typically
include
resins
or
binders,
pigments,
carriers,
and
additives.

The
resins
or
binders,
pigments,
and
additives
are
dissolved
in
the
carrier
(
i.
e.,
water
or
solvent)
and
form
the
film
following
evaporation
of
the
carrier.

Resins
or
binders
form
the
coating
film,
which
adheres
flexibly
to
the
surface
of
the
plastic
part.
Resins
or
binders
are
most
often
polymers
 
the
same
types
of
organic
molecules
that
make
up
the
resins
used
to
form
plastic
parts.

Pigments
are
insoluble
solids
that
provide
opacity
to
obscure
the
surface
of
a
plastic
part
and
add
color.

Carriers
are
organic
solvents,
liquid
carbon
dioxide,
or
water,
which
facilitate
the
transference
of
the
other,
often
solid,
coating
components
to
the
plastic
part.

Additives
improve
properties
such
as
coalescence,
flow,
and
other
properties
(
University
of
Missouri­
Rolla,
1999).
Additives
may
°
affect
the
rheological
properties
of
coatings
(
i.
e.,
their
ability
to
flow),

°
speed
the
curing
process,

°
ensure
pigment
dispersion,

°
reduce
the
surface
tension
of
the
coating
to
ensure
complete
coverage
of
the
part,

°
serve
as
defoamers
so
that
the
dried
coating
surface
is
free
of
bubbles,
and
°
serve
as
fungicides
or
bactericides
("
Surface
Coating,"
Encyclopedia
Britannica).

Capital
Inputs.
The
coating
process
involves
capital
inputs
including
coating
equipment
such
as
spray
booths,
filtration
systems,
spray
guns,
conveyor
lines,
and
curing
ovens
and
investment
in
pollution­
abatement
equipment.

Coating
Equipment.
Parts
to
be
coated
may
enter
a
partially
or
totally
enclosed
spray
booth
either
manually
or
by
way
of
a
conveyor.
Application
of
the
coating
may
be
accomplished
through
manual
or
robotic
methods.
Figure
2­
2
shows
powder
coating
being
applied
manually
in
a
partially
enclosed
spray
booth.
Figure
2­
3
shows
a
spray
booth
to
which
parts
are
delivered
by
way
of
a
conveyor.
2­
10
Figure
2­
2.
Powder
Coating
Booth
Source:
<
www.
spraytech.
com/
powder.
html>.

Pollution­
Abatement
Equipment.
To
manage
organic
HAP
emissions
resulting
from
the
coating
process,
additional
equipment
may
be
used
at
some
plastic
parts
surface
coating
sources.
Spray
booth
filtration
systems
may
be
connected
to
scrubbing
towers
or
carbon
absorption
filters
to
extract
the
emissions
from
the
filtered
air.
The
extracted
solvents
then
are
incinerated
to
keep
them
from
escaping
into
the
atmosphere.
The
capital
equipment
associated
with
managing
the
solvents
released
in
the
coating
process
requires
other
inputs
such
as
fuel,
energy,
and
chemicals.
2­
11
Figure
2­
3.
A
Conveyorized
Paint
Finishing
Booth
Source:
OBI
Spray
Booths
and
Systems
Catalog
#
201­
2.
Inside
Cover.
2­
12
2.2.1.3
The
Surface
Coating
Process
The
surface
coating
of
plastic
parts
includes
the
following
steps:

°
preparation
of
the
coating
(
i.
e.,
mixing
with
thinners
or
other
additives),

°
surface
preparation,

°
coating
application
and
flash­
off,

°
drying
and/
or
curing,
and
°
cleaning
of
equipment
used
in
surface
coating.

Surface
Preparation.
Once
a
part
is
formed,
it
may
require
surface
preparation
to
correct
flaws,
clean
residue
from
the
surface,
and/
or
to
prepare
the
surface
to
receive
the
coating.
Correcting
surface
flaws
is
necessary
to
provide
an
even
surface
for
the
coating,
to
achieve
an
aesthetically
pleasing
final
product,
and,
in
some
cases,
to
improve
the
eventual
performance
of
functioning
parts.
Correcting
surface
flaws
may
involve
sanding,
puttying,

and
gassing
out
plastic
parts.
Cleaning
may
include
wipe­
down
(
dry
or
solvent),
multistage
washing
cycles,
or
deionized
water
rinses.
Finally,
masking
may
be
used
to
prevent
unwanted
surface
coating
on
specific
areas
of
the
part
or
product.

Coating
Application.
Coating
application
methods
for
plastic
parts
include
brush,
dip,

flow,
spray,
vacuum
metallizing,
and
others.
Immediately
following
application
plastic
parts
are
usually
introduced
to
a
flash­
off
zone.
The
flash­
off
zone
is
an
area
where
the
coating
completes
its
flowing
or
leveling
prior
to
curing.
Figure
2­
4
shows
an
example
coating
line
for
a
three­
coat
system.

Drying
and/
or
curing.
The
drying
and/
or
curing
processes
for
plastic
parts
includes
ambient,
elevated
temperature,
forced­
air,
radiation­
cure,
and
ultraviolet
light.
The
proper
curing
conditions
for
each
coating,
including
temperature,
residence
time
in
an
oven
or
under
a
lamp,
and
humidity
depend
on
the
type
of
coating
used
and
the
characteristics
of
the
substrate
coated.
After
curing
at
elevated
temperatures,
coated
parts
enter
a
cool­
down
zone
where
they
remain
until
cool
enough
for
further
handling
(
EPA,
1998).

Equipment
Cleaning.
Cleaning
is
performed
on
the
equipment
for
a
variety
of
reasons
to
include
flushing
of
the
paint
lines
and
application
equipment
for
color
changes,

housekeeping,
etc.
The
specific
solvent
used
to
clean
the
equipment
will
vary
depending
on
the
type
of
material
(
i.
e.,
waterborne,
solventborne,
etc.)
being
applied
with
the
equipment.
2­
13
Prime
Booth
Oven
Oven
Flash­
Off
Area
Flash­
Off
Area
Coated
Part
Flash­
Off
Area
Color
Booth
Charcoal/
Texture
Booth
Figure
2­
4.
Example
Coating
Line
for
Three­
Coat
System
Source:
U.
S.
Environmental
Protection
Agency.
1994.
Alternative
Control
Techniques
Document:
Surface
Coating
of
Automotive/
Transportation
and
Business
Machine
Plastic
Parts.
EPA
435/
R­
94­
017.
Research
Triangle
Park,
NC:
U.
S.
Environmental
Protection
Agency.

Commonly
used
cleaning
materials
include
water,
butyl
acetate,
acetone,
xylene,
and
water­
based
peel­
off
cleaner.

2.2.1.4
Emissions
Solvents
used
in
the
surface
coating
of
plastic
parts
and
products
contain
organic
HAP
that
may
evaporate
into
the
atmosphere.
Generally,
100
percent
of
the
organic
HAP
in
the
materials
used
for
surface
coating
of
plastic
parts
and
products
are
emitted.
However,
in
2­
14
some
adhesives
a
portion
of
the
organic
HAP
may
become
part
of
the
film
through
a
chemical
reaction
and
are
not
emitted.
Finally,
some
of
the
affected
entities
may
capture
and
incinerate
the
organic
HAP
emissions.

2.2.2
Costs
of
Surface
Coating
The
(
opportunity)
costs
of
production
depend
on
whether
the
productive
activity
is
characterized
by
the
existence
of
a
fixed
factor
such
as
plant
and
equipment
whose
quantity
cannot
be
varied
over
the
time
frame
of
analysis
or
whether
the
activity
is
in
the
planning
stage.
In
the
former
short­
run
case,
there
is
no
cost
to
using
the
fixed
input
and
for
any
output
rate,
the
(
minimum)
total
costs
of
production
are
simply
C
x
=
P
n
Q
nx
*
+
P
m
Q
mx
*
+
P
g
Q
gx
*,
(
2.1)

assuming
that
the
fixed
factor
is
capital.
However,
although
the
cost
of
the
fixed
factor
is
not
included
in
the
costs
of
production,
the
cost
is
conditional
on
the
quantity
of
the
fixed
input
available
since
it
influences
the
productivity
of
the
other
inputs.
The
*
denotes
that
these
are
the
minimum
cost
quantities
of
the
inputs
for
a
given
output
rate.
The
abatement
costs
for
existing
controls
are
similarly
calculated.

In
the
planning
long­
run
case,
all
costs
are
variable
and
the
cost
of
the
fixed
factor
(
e.
g.,
capital
services)
must
be
included:
PkQkx*.
In
the
intermediate­
run
case
when
there
is
the
opportunity
to
use
the
fixed
input
in
another
application,
this
foregone
opportunity
is
also
part
of
the
cost
of
production.

The
cost
function
describes
the
relationship
between
the
minimum
costs
of
production
and
alternative
output
rates.
Figure
2­
5
shows
a
typical
textbook
characterization
of
a
shortrun
unit
cost
function.

For
existing
suppliers
of
surface
coating
services,
the
primary
fixed
input
is
the
capital
equipment
used.
This
includes
washing
systems,
spray
booths
and/
or
plating
vats,
conveyor
lines
and
hoists,
spray
guns
and
pumping
systems,
filtration
systems,
reclaim
systems,
curing
ovens
and
incinerators,
and
other
pollution
abatement
equipment.

Variable
inputs
include
labor
used
for
both
production
and
pollution
abatement,

coatings
and
other
chemical
solutions,
uncoated
plastic
parts
and
products,
fuels,
and
purchased
electricity.
Total
costs
of
the
variable
inputs
used
by
industries
that
produce,
coat,

and
use
plastic
parts
and
products
are
provided
in
Table
2­
4.
Plastic
parts
and
products
prices
2­
15
Average
Costs
($)

0
Average
Total
Cost
Average
Variable
Cost
Average
Fixed
Cost
Quantity
Figure
2­
5.
Short­
Run
Unit
Cost
Function
are
not
included
because
they
are
usually
produced
in­
house
or
delivered
to
the
coater
for
coating
on
a
toll
basis,
so
the
price
for
the
parts
is
not
readily
available.
Note
that
the
table
provides
industry
data
on
costs
rather
than
costs
only
for
firms
that
coat
plastic
parts
and
products.
The
costs
reported
are
much
larger
than
the
actual
costs
of
surface
coating.

For
any
existing
supplier
of
plastic
parts
surface
coating
services,
the
costs
of
production
depend
on
the
supplier's
purchase
of
variable
inputs
and
the
opportunity
cost
of
owning
capital
equipment.
EPA
regulations
result
in
changing
a
facility's
minimum
cost
quantities
of
some
inputs,
often
both
variable
inputs
and
capital
equipment.

2.2.3
Suppliers
of
Plastics
Parts
Coating
Services
EPA
has
identified
202
existing
facilities
that
coat
plastic
parts
and
products,
which
would
be
directly
affected
by
the
rule.
Of
these
202
facilities,
EPA
had
sufficient
data
to
allow
costs
to
be
estimated
for
185
facilities.
These
185
facilities
are
the
facilities
covered
by
this
study.
Table
2­
5
shows
the
location
of
the
facilities
by
state.

These
suppliers
of
plastic
parts
coating
services
are
as
varied
as
the
parts
themselves.

They
range
from
small
single­
facility
firms
with
annual
revenues
in
the
hundreds
of
thousands
of
dollars
to
facilities
owned
by
large
automobile
manufacturers
with
total
revenues
in
the
hundreds
of
billions
of
dollars.
2­
16
2­
17
Table
2­
4.
Production
Costs
of
Industries
Producing
Coated
Plastic
Parts:
1997
Labor
Cost
of
Materials
($
103)
Total
Capital
Expenditures
($
103)

Industry
NAICS
Code
Total
Employment
Total
Payroll
($
103)

Automobile
and
Truck
Parts
Automobile
manufacturing
336111
114,060
6,411,952
66,546,225
3,355,800
Light
truck
and
utility
vehicle
manufacturing
336112
94,033
5,361,980
70,927,268
1,769,649
Heavy
duty
truck
manufacturing
336120
28,214
1,190,164
10,306,435
120,735
Motor
vehicle
body
manufacturinga
336211
1,722
54,000
200,324
8,086
Motor
home
manufacturing
336213
17,936
503,294
2,679,768
49,753
Travel
trailer
and
camper
manufacturing
336214
32,036
770,504
2,724,961
62,502
Gasoline
engine
and
engine
parts
manufacturing
336312
81,160
3,550,770
17,847,864
1,750,675
Vehicular
lighting
equipment
manufacturing
336321
16,506
628,534
1,686,309
169,235
Other
motor
vehicle
electrical
and
electronic
equipment
manufacturingb
336322
30,489
1,048,438
4,096,932
239,147
Motor
vehicle
steering
and
suspension
component
(
except
spring)
manufacturing
336330
48,625
2,323,579
5,473,746
552,144
Motor
vehicle
brake
system
manufacturing
336340
43,147
1,486,119
6,407,923
473,867
Motor
vehicle
transmission
and
power
train
parts
manufacturing
336350
111,955
5,516,801
19,567,915
1,902,483
All
other
motor
vehicle
parts
manufacturingc
336399
173,229
5,442,190
18,656,740
1,600,988
Motorcycles,
bicycles,
and
parts
manufacturing
336991
17,074
567,520
1,797,470
103,730
Military
armored
vehicle,
tank,
and
tank
component
manufacturingd
336992
5,982
238,241
495,679
17,819
All
other
transportation
equipment
manufacturing
336999
19,290
504,886
2,875,923
98,858
(
continued)
2­
18
Table
2­
4.
Production
Costs
of
Industries
Producing
Coated
Plastic
Parts:
1997
(
continued)

Labor
Cost
of
Materials
($
103)
Total
Capital
Expenditures
($
103)

Industry
NAICS
Code
Total
Employment
Total
Payroll
($
103)

Business
Machine
and
Computer
Equipment
Parts
Office
machinery
manufacturing
333313
10,492
327,913
1,180,516
97,724
Electronic
computer
manufacturing
334111
105,383
4,251,722
40,239,744
1,053,379
Computer
terminal
manufacturing
334113
5,764
253,087
941,879
34,716
Other
computer
peripheral
equipment
manufacturing
334119
93,130
4,563,858
16,981,173
980,417
Watch,
clock,
and
part
manufacturinge
334518
6,332
178,481
380,468
26,214
Lead
pencil
and
art
good
manufacturingf
339942
1,210
29,408
82,640
8,821
Miscellaneous
Products
Plastics
pipe
and
pipe
fitting
manufacturingg
326122
4,058
100,969
261,268
39,467
Polystyrene
foam
product
manufacturing
326140
26,983
756,131
2,447,473
318,445
Urethane
and
other
foam
product
(
except
polystyrene)

manufacturing
326150
37,129
1,002,055
3,851,626
216,477
All
other
plastics
product
manufacturingh
326199
523,192
13,989,931
30,344,499
3,449,409
Residential
electric
lighting
fixture
manufacturingi
335121
74
1,973
2,405
173
Current
carrying
wiring
device
manufacturing
335931
44,907
1,293,583
2,326,114
219,293
Laboratory
apparatus
and
furniture
manufacturing
339111
16,833
616,819
909,818
58,880
Costume
jewelry
and
novelty
manufacturing
j
339914
13,975
314,581
448,479
19,325
Sporting
and
athletic
goods
manufacturing
339920
68,920
1,799,871
4,679,110
345,602
(
continued)
2­
19
Table
2­
4.
Production
Costs
of
Industries
Producing
Coated
Plastic
Parts:
1997
(
continued)

Labor
Cost
of
Materials
($
103)
Total
Capital
Expenditures
($
103)

Industry
NAICS
Code
Total
Employment
Total
Payroll
($
103)

Miscellaneous
Products
(
continued)

Doll
and
stuffed
toy
manufacturing
339931
3,392
63,722
104,698
3,939
Game,
toy,
children's
vehicle
manufacturing
339932
29,375
767,211
1,870,746
136,243
Sign
manufacturing
339950
82,246
2,367,259
3,314,770
234,572
Musical
instrument
manufacturing
339992
13,286
359,101
493,019
36,262
a
Excludes
707
firms
classified
under
truck
and
bus
bodies
(
NAICS
336211).

b
Excludes
252
firms
classified
under
electronic
components,
n.
e.
c.
(
NAICS
34418,
34419),
and
570
firms
classified
under
engine
electrical
equipment
(
NAICS
336322).

c
Excludes
6
firms
classified
under
internal
combustion
engines,
n.
e.
c.
(
NAICS
333618)
and
1
firm
under
all
other
manufacturing
industries
(
NAICS
339999).

d
Includes
38
firms
classified
under
the
tanks
and
tank
components
(
NAICS
336992).

e
Includes
2
firms
classified
under
wire
springs
(
NAICS
332612),
and
128
firms
under
watches,
clocks,
and
watch
cases
(
NAICS
334518).

f
Excludes
17
firms
classified
under
public
building
and
related
furniture
(
NAICS
337127),
and
143
firms
under
lead
pencils
and
art
goods
(
NAICS
339942).

g
Excludes
349
firms
classified
under
plastics
pipe
(
NAICS
326122).

h
Excludes
140
firms
classified
under
all
other
manufacturing
industries,
n.
e.
c.
(
NAICS
339999).

i
Excludes
497
firms
classified
under
residential
lighting
fixtures
(
NAICS
335121),
and
53
firms
under
all
other
manufacturing
industries,
n.
e.
c.

(
339999).

j
Excludes
17
firms
classified
under
metal
coating
and
allied
services
(
NAICS
332812)
and
80
firms
under
fabricated
metal
products,
n.
e.
c.

(
NAICS
332999).

Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999aa­
1999nn.
Manufacturing
 
Industry
Series,
1997
Economic
Census.

Washington,
DC.
2­
20
Table
2­
5.
Surface
Coaters
of
Plastic
Parts
and
Products,
by
State
State
Number
of
Facilities
Arkansas
2
California
3
Connecticut
2
Florida
1
Georgia
1
Iowa
2
Illinois
5
Indiana
11
Kansas
3
Kentucky
2
Louisiana
1
Massachusetts
2
Michigan
54
Minnesota
3
Missouri
5
North
Carolina
3
North
Dakota
1
New
Hampshire
1
New
Mexico
1
New
York
1
Ohio
31
Oklahoma
1
Pennsylvania
4
South
Carolina
3
South
Dakota
1
Tennessee
6
Texas
1
Virginia
3
Wisconsin
9
NA
22
Total
185
Source:
U.
S.
Environmental
Protection
Agency
(
EPA).
2001.
ICR
Survey
Responses.
Washington,
DC:
U.
S.
Environmental
Protection
Agency.
1Team
production
occurs
when
several
types
of
resources
are
used
together
to
produce
a
product
which
is
not
a
sum
of
separable
outputs
of
each
cooperating
resource
and
where
resources
do
not
all
belong
to
one
person.
Team
production
is
beneficial
when
a
"
team"
can
produce
goods
and
services
which
an
individual
could
never
produce
alone
or
when
the
marginal
product
of
a
team
is
greater
than
the
sum
of
individual
marginal
products
of
team
members.

2­
21
The
organization
of
a
production
process
varies
according
to
the
benefits
of
team
production1
and
the
costs
of
monitoring
shirking
amongst
team
members.
Firms
that
produce
products
comprising
surface­
coated
plastic
parts
use
team
production
to
perform
the
actual
coating
process.
However,
only
some
of
the
firms
find
it
efficient
to
combine
surface
coating
services
with
the
actual
manufacture
of
plastic
parts
or
with
the
assembly
process
of
coated
parts
and
other
inputs
used
as
components
in
another
downstream
good.
Three
types
of
production
organization
are
used
in
surface
coating:

°
captive
facilities
in
the
same
organization
as
the
product
manufacturer,

°
commercial
suppliers
that
fabricate
and
coat
plastic
parts
and
sell
them
to
the
product
manufacturer,

°
commercial
suppliers
that
surface­
coat
plastic
parts
on
a
toll
basis
for
the
product
manufacturer,
or
°
commercial
suppliers
that
coat
plastic
parts
and
products
as
part
of
refurbishment
(
EPA,
1994).

2.3
Consumption,
Value,
and
Consumers
Surface
coating
is
a
value­
adding
process
demanded
for
its
ability
to
increase
a
plastic
part's
or
product's
aesthetic
value,
conductivity,
and
durability.
Surface­
coated
plastic
parts
and
products
are
most
often
intermediate
goods
incorporated
into
final
products
ranging
from
automobiles
to
toys,
although
they
may
be
final
products
themselves.
The
demand
for
surface­
coated
plastic
parts
and
products
is
based
on
their
value
to
consumers
as
part
of
a
final
good.
The
demand
for
surface
coating
services
is
directly
related
to
the
demand
for
those
parts
and
products.

This
section
characterizes
the
demand
side
of
the
market
for
surface­
coated
plastic
parts.
It
describes
the
characteristics
of
the
various
types
of
coated
plastic
parts
and
the
value
to
consumers
of
each
of
four
different
types
of
final
consumer
goods:
automobiles
and
light
duty
truck
parts,
heavy
duty
truck
parts,
business
machine
and
computer
equipment
parts,
and
2­
22
miscellaneous
parts
and
products.
The
behavioral
response
of
consumers
to
a
change
in
the
price
of
plastic
parts,
quantified
in
economics
as
the
elasticity
of
demand,
is
also
discussed.

2.3.1
Characteristics
of
Plastic
Parts
and
Products
The
demand
for
a
commodity
is
not
simply
for
the
good
itself
but
instead
for
a
set
of
characteristics
and
properties
that
is
satisfied
by
a
particular
commodity.
Commodities
can
thus
be
described
as
bundles
of
attributes
that
provide
services
(
Lancaster,
1966).
The
production
processes
of
surface­
coated
plastic
parts
allow
room
to
vary
the
characteristics
of
the
final
product.
Frequently,
gains
in
one
particular
characteristic
demand
sacrifices
of
another
or
increased
materials
and/
or
processing
costs.
Also,
users
of
different
types
of
plastic
parts
do
not
all
require
the
same
set
of
attributes.
For
example,
electronic
and
office
equipment
manufacturers
coat
plastics
with
metallic
substances
to
make
them
conductive
and
protect
them
from
electromagnetic/
radio
frequency
interference
signals.
However,
children
playing
with
plastic
toys
and
dolls
are
interested
in
the
appearance
of
the
toy;
the
parents
may
value
its
safety
and
durability.
Some
of
the
various
characteristics
of
surface­
coated
plastic
parts
are
°
flammability,

°
recyclability,

°
expected
lifetime
(
i.
e.,
durability,
susceptibility
to
UV
rays),

°
environmental
attributes
(
i.
e.,
safety
of
disposal
and
end
of
life),

°
weight,

°
safety
(
i.
e.,
protection
provided
in
an
automobile
accident),

°
aesthetics,

°
thermal
properties
(
i.
e.,
heat
tolerance),

°
flexibility/
rigidity,
and
°
conductivity.

While
many
of
the
above
characteristics
of
plastic
parts
and
products
will
be
determined
primarily
by
the
composition
of
the
uncoated
part
itself,
coatings
influence
almost
all
of
the
above
characteristics
to
some
degree,
though
mostly
indirectly.
Primary
characteristics
that
can
be
directly
affected
by
the
coating
part
are
2­
23
°
durability
(
scratch
and
chemical
resistance);

°
aesthetics
(
the
color
and
texture
of
the
part);

°
conductivity
(
of
electromagnetic/
radio
frequency
interference
signals);
and
°
the
presence
of
some
functional
capabilities,
such
as
reflective
properties.

2.3.2
Uses
of
Plastic
Parts
and
Products
As
described
in
Section
2.2,
surface­
coated
plastic
parts
are
vital
components
of
a
wide
range
of
products,
including
transportation
equipment,
business
machines
and
computers,
and
a
multitude
of
miscellaneous
products.
The
uses
of
parts
and
characteristics
of
interest
to
their
consumers
vary
across
those
product
groups.
Because
coated
plastic
parts
are
an
intermediate
good
used
in
the
production
of
a
final
good
such
as
a
complete
automobile
or
a
complete
copier
machine,
the
use
of
plastic
parts
is
often
dictated
by
a
manufacturer's
interpretations
of
consumer
preferences
rather
than
directly
by
the
consumer
himself.

2.3.2.1
Automotive
and
Truck
Parts
Plastics
are
used
increasingly
to
produce
transportation
equipment
parts.
By
1993,

manufacturers
were
using
over
250
pounds
of
plastic
in
the
average
vehicle
(
SPI,
1999).
Car
interiors
alone
represent
a
value
of
about
$
1,200
per
vehicle,
of
which
$
500
is
due
to
the
value
of
plastic
components
(
Modern
Plastics
Encyclopedia,
1999a).
Automobile
and
other
transportation
equipment
purchasers
are
concerned
with
the
performance,
safety,
appearance,

and
longevity
of
transportation
products.
Accordingly,
auto
makers
are
especially
concerned
with
the
durability,
corrosion
resistance,
and
resiliency
of
plastic
parts,
which
affect
the
expected
lifetime
of
the
product.
They
often
choose
the
coating
of
a
part
based
on
the
eventual
location
of
the
part
on
the
vehicle.
For
example,
the
lower
a
part
is
on
a
car,
the
more
resistant
it
must
be
to
damage
from
particles
that
might
fly
up
from
the
road.
The
UV
resistance
of
interiors
is
becoming
increasingly
important
to
automakers
as
they
find
consumers
demanding
longer
warranties
on
the
color
retention
and
other
properties
of
auto
interiors
at
the
same
time
that
interior
exposure
to
UV
is
increasing
along
with
an
increase
in
window
areas
(
Modern
Plastics
Encyclopedia,
1999a).
Auto
makers
also
consider
the
aesthetic
properties
of
the
part
 
its
color
and
texture
 
since
the
appearance
of
a
vehicle
affects
its
value
to
consumers.
Plastics
may
be
easily
molded
into
new
and
exciting
aerodynamic
shapes.
The
light
weight
of
plastic
parts
contributes
to
fuel
efficiency
and
is
a
factor
often
considered
in
making
decisions
to
substitute
plastic
parts
for
those
made
of
glass
2­
24
or
metal.
Plastics
have
another
important
advantage
over
metal
parts
 
the
ease
of
processing
them
into
unique
shapes.

2.3.2.2
Computers
and
Business
Equipment
Like
the
consumers
of
automotive
and
truck
parts,
consumers
of
computers
and
business
equipment
value
performance,
safety,
appearance,
and
longevity.
Coatings
affect
the
safety,
appearance,
and
longevity
of
products.
Although
the
range
of
aesthetic
characteristics
seems
narrower
for
products
in
this
segment
than
those
in
the
automotive
segment,
consumers
of
computers
and
business
equipment
do
place
a
value
on
appearance.
Manufacturers
are
aware
of
the
aesthetic
value
consumers
place
on
computer
and
business
machine
housings
and
often
make
their
production
choices
accordingly.
For
example,
Sun
Microsystems
invested
many
resources
in
finding
an
exciting
design
for
the
housing
of
their
Starfire
server.
Sun's
Kathleen
McLaurin
observed:
"
It
was
especially
important
that
the
product
appeal
visually
to
the
design­
sensitive
commercial
users
we
were
targeting"
(
Fox,
1998).
The
same
sentiment
guided
Macintosh
in
its
design
of
the
i­
Mac.
No
matter
how
the
performance
of
the
computer
is
evaluated,
no
one
denies
its
eye­
catching
appearance.
Even
less
innovative
manufacturers
find
it
necessary
to
at
least
color­
match
plastic
parts
to
coated
metal
parts
and
use
molded­
in
texture
to
find
a
market
for
their
product.
In
addition,
coatings
serve
the
purpose
of
hiding
any
flaws
in
a
part's
substrate
(
EPA,
1994).

Business
equipment
users
are
also
interested
in
the
safety
of
the
equipment.

Manufacturers
can
increase
the
safety
of
machines
by
using
selected
resins
that
do
not
easily
ignite
and/
or
that
are
capable
of
self­
extinguishing.
In
some
cases,
fire­
retardant
chemicals
may
be
added
to
the
resins
to
increase
safety,
although
some
European
regulations
preclude
the
use
of
many
of
these
chemicals,
thus
limiting
the
choices
of
exporting
manufacturers
(
Modern
Plastics
Encyclopedia,
1999b).
EMI/
RFI
(
Electromagnetic
Interference/
Radio
Frequency
Interference)
shielding
is
necessary
to
prevent
a
machine
or
computer
from
interfering
with
other
electronic
equipment
and
to
prevent
airwaves
from
outside
the
equipment
from
interfering
with
its
performance.
Shielding
is
best
accomplished
with
grounded,
high­
conductivity
coatings
containing
nickel
or
copper.

2.3.2.3
Miscellaneous
Products
Like
consumers
of
the
other
two
categories
of
products
described
above,
consumers
of
miscellaneous
products
are
concerned
with
the
appearance,
safety,
and
longevity
of
plastic
parts,
all
of
which
can
be
improved
with
the
application
of
coatings.
Consumers
of
construction
materials
desire
plastic
parts
that
can
withstand
the
elements
and
that
be
coated
2­
25
to
match
numerous
architectural
coatings.
Consumers
of
plastic
laboratory
apparatus
and
furniture
desire
durable
products
that
will
not
degenerate
when
cleaned
with
cleaning
solvents.

Consumers
of
sports
equipment
want
durable
plastic
products
that
can
withstand
impacts
and
have
aesthetic
appeal.
Consumers
of
toys
desire
products
that
are
attractive,
safe
(
i.
e.,

nontoxic),
and
durable.

2.3.3
Substitutes
In
most
of
the
products
described
above,
coated
plastic
parts
have
often
replaced
glass
or
metal
parts,
because
they
are
lightweight,
cheaper
to
produce
than
similar
metal
or
glass
parts,
and
sometimes
safer
to
use
than
metal
or
glass
substitutes.
Currently,
depending
on
the
part
in
question,
glass
or
metal
are
the
only
viable
substitutes
for
coated
plastic
automobile
parts.
Table
2­
6
lists
auto
parts
that
may
be
made
out
of
coated
plastic
parts
and
indicates
whether
the
part
could
also
be
made
of
glass
and/
or
metal.
Because
plastic
parts
are
much
cheaper
and
lighter
than
glass
or
metal,
it
is
unlikely
that
vehicle
manufacturers
will
switch
from
plastic
parts
back
to
metal
parts.
As
in
the
automotive
industry,
computer
and
business
machine
parts
and
toys
could
be
constructed
of
metal
rather
than
plastic.
However,

requirements
for
safety,
the
need
to
produce
parts
with
unique
shapes,
and
the
relatively
higher
cost
of
using
metals
limit
the
possibilities
for
substitution.

2.3.4
Elasticity
The
elasticity
of
demand
for
coated
plastic
parts
and
products
is
a
measure
of
the
responsiveness
of
the
quantity
of
coated
products
demanded
to
a
change
in
the
price
of
those
products.
The
responsiveness
of
quantity
demanded
to
price
increases
with
the
availability
of
substitutes,
the
time
frame
of
adjustment,
the
price
proximity
of
substitutes,
and
the
price
of
a
good
in
relation
to
a
consumer's
budget.
The
more
inelastic
the
demand,
the
more
easily
firms
will
be
able
to
pass
the
costs
of
regulation
on
to
consumers.
The
demand
for
coated
plastic
parts
may
be
relatively
inelastic
because
plastic
parts
are
generally
much
cheaper
than
metal
and
glass
substitutes.

2.4
Firm
Characteristics
The
economic
impacts
regulating
surface
coating
facilities
are
related
to
the
ownership
structure
of
those
facilities.
The
market
power,
size,
and
integration
of
firms
affect
their
ability
to
pass
the
costs
of
regulation
on
to
consumers
and/
or
absorb
those
costs
without
significant
harm
to
their
financial
position.
The
185
surface
coating
facilities
2­
26
Table
2­
6.
Auto
Parts
Made
of
Plastic
Type
of
Part
Possible
Materials
for
Use
in
Constructing
Part
Interior
Parts:

Instrument
panel
Plastic,
steel
Console
Plastic
Heater/
AC
controls
Plastic,
steel,
aluminum
Speaker
grille
Plastic,
metal
Dome
light
Plastic,
glass
Ash
tray
Plastic,
metal
Van/
utility
vehicle
rear
Plastic,
metal
Airbag
cover
Plastic
Exterior
Parts:

Grille
Plastic,
metal
Wheel
cover
Plastic,
metal
Lighting
Plastic,
glass
Headlamp
or
taillamp
reflector
Plastic,
glass
Headlamp
lense
Plastic,
glass
Facia
cladding
Plastic
Window
encapsulation
cladding
Plastic
Body
sides,
fenders
Plastic,
steel,
aluminum
Bumper
Plastic,
steel,
aluminum
Functional
Parts:

Engine
fan
Plastic,
steel
Fuel
tank
Plastic,
steel
Housings
Plastic,
metals
Sources:
U.
S.
Environmental
Protection
Agency,
Office
of
Compliance,
Office
of
Enforcement
and
Compliance
Assurance.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project
 
Profile
of
the
Motor
Vehicle
Industry.
EPA/
310­
R­
95­
009.
Washington,
DC:
U.
S.
Environmental
Protection
Agency.

Fettis,
Gordon.
1995.
Automotive
Paints
and
Coatings.
Weinheim,
Germany:
Verlagsgesellschaft
mbH.
2­
27
included
in
this
analysis
are
owned
by
130
firms.
Firms
owning
facilities
that
coat
motor
vehicle
or
business
machine
parts
appear
to
have
somewhat
more
market
power
than
those
that
coat
miscellaneous
parts.
The
relatively
larger
degree
of
concentration
might
not
be
so
obvious
if
it
were
possible
to
further
specify
the
product
markets
for
miscellaneous
parts
and
products.
However,
it
is
intuitively
obvious
that
specific
requirements
that
original
equipment
manufacturers
(
OEMs)
impose
on
their
suppliers
of
plastic
vehicle
and
business
machine
parts
would
make
it
more
likely
that
coating
facilities
would
have
close
relationships
with
their
customers
and
hence
more
market
power
than
the
facilities
that
coat
miscellaneous
plastic
parts
and
products.

This
section
describes
the
ownership
structure
of
surface
coating
facilities,
including
the
overall
concentration
levels
in
industries
affected
by
the
Plastic
Parts
and
Products
NESHAP,
the
number
and
size
of
firms
owning
affected
surface
coating
facilities,
the
vertical
and
horizontal
integration
of
those
firms,
and
the
current
number
of
small
businesses
affected
by
the
NESHAP.
The
terms
facility
and
establishment
are
used
synonymously
in
this
analysis
and
refer
to
the
physical
location
where
products
are
coated.
Likewise,
the
terms
company
and
firm
are
used
synonymously
and
refer
to
the
legal
business
entities
that
own
facilities.

2.4.1
Market
Power
of
Firms
The
ownership
concentration
of
surface
coating
facilities
is
important
because
it
affects
the
firms'
ability
to
influence
the
price
of
surface
coating
services
or
the
price
of
inputs
they
purchase.
If
an
industry
is
perfectly
competitive,
then
individual
producers
are
not
able
to
influence
the
price
of
the
output
they
sell
or
the
inputs
they
purchase.
This
condition
is
most
likely
to
hold
if
the
industry
has
a
large
number
of
firms,
the
products
sold
are
undifferentiated,
and
entry
and
exit
of
firms
are
unrestricted.
Product
differentiation
can
occur
both
from
differences
in
product
attributes
and
quality
and
from
brand
name
recognition
of
products.
Entry
and
exit
of
firms
are
unrestricted
for
most
industries
except,
for
example,

in
cases
when
government
regulates
who
is
able
to
produce,
when
one
firm
holds
a
patent
on
a
product,
when
one
firm
owns
the
entire
stock
of
a
critical
input,
or
when
a
single
firm
is
able
to
supply
the
entire
market.

When
compared
across
industries,
firms
in
industries
with
fewer
firms,
more
product
differentiation,
and
restricted
entry
are
more
likely
to
be
able
to
influence
the
price
they
receive
for
a
product
by
reducing
output
below
perfectly
competitive
levels.
This
ability
to
influence
price
is
referred
to
as
exerting
market
power.
At
the
extreme,
a
single
monopolistic
firm
may
supply
the
entire
market
and
hence
set
the
price
of
the
output.
On
the
input
market
2­
28
side,
firms
may
be
able
to
influence
the
price
they
pay
for
an
input
if
there
are
few
firms,
both
within
and
outside
the
industry,
that
use
that
input.
At
the
extreme,
a
single
monopsonist
firm
may
purchase
the
entire
supply
of
the
input
and
hence
set
the
price
of
the
input.

Surface
coating
is
a
competitive
industry
in
that
surface
coating
is
not
a
differentiated
product
but
rather
a
process
that
is
extremely
similar
across
a
wide
range
of
products.
In
addition,
surface
coating
facilities
are
owned
by
a
large
number
of
firms,
and
the
cost
of
surface
coating
equipment
is
low
enough
that
entry
into
the
market
is
not
extremely
difficult.

Although
surface
coaters
make
up
small
portions
of
the
industries
in
which
they
are
classified,
the
differing
levels
of
concentration
in
those
industries
may
indicate
the
relative
degrees
of
market
power
among
surface
coaters
in
different
industries.
Table
2­
7
presents
several
different
measures
of
concentrations
in
industries
that
coat
plastic
parts
and
products,

including
four­
firm
concentration
ratios
and
Herfindahl
index
numbers
for
each
industry.
A
four­
firm
concentration
ratio
greater
than
50
percent
is
often
considered
high.
The
Department
of
Justice's
Horizontal
Merger
Guidelines
claim
that
a
Herfindahl
index
number
less
than
1,000
indicates
an
unconcentrated
industry
while
a
Herfindahl
index
number
between
1,000
and
1,800
indicates
a
moderately
concentrated
industry
and
an
index
number
above
1,800
indicates
a
highly
concentrated
industry.
As
Table
2­
7
shows,
industries
that
produce
motor
vehicles
and
business
machines
do
appear
to
be
more
concentrated
than
those
producing
miscellaneous
plastic
parts.

2.4.2
Firm
Size
by
Employment
and
Revenue
It
is
likely
that
large
firms
will
be
better
able
to
absorb
the
financial
impacts
of
the
regulation.
Hence,
firm
size
is
a
factor
in
the
distribution
of
the
regulation's
economic
impacts.
The
130
firms
owning
the
185
surface
coating
facilities
have
yearly
revenues
as
low
as
$
1.3
million
and
as
high
as
$
180
billion.
Employment
at
the
firms
ranges
from
15
employees
to
386,000.
Tables
2­
8
and
2­
9
illustrate
the
distribution
of
employment
and
revenues
across
firms
owning
surface
coating
facilities.
Table
2­
8
shows
that
38
percent
of
firms
employ
fewer
than
500
people,
and
38
percent
of
firms
are
relatively
large
and
employ
over
1,000
people.
Table
2­
9
shows
that
many
firms
are
large
based
on
employment
criteria,

but
the
majority
(
70
percent)
have
annual
revenues
less
than
$
500
million.
2­
29
Table
2­
7.
Measurements
of
Concentration
of
Industries
Manufacturing
Coated
Plastic
Parts:
1997
Percentage
of
the
Value
of
Shipments
Accounted
for
by
x
Largest
Companies
Industry
NAICS
Code
Number
of
Companies
Value
of
Shipments
($
106)
x=
4
x=
8
x=
20
x=
50
Herfindahl­
Hirschmann
Index
Automobile
and
Truck
Parts
Automobile
manufacturing
336111
173
95,366
79.5
96.3
99.5
99.9
2,349.7
Light
truck
and
utility
vehicle
manufacturing
336112
84
110,178
99.3
99.9
99.9
99.9
NA
Heavy
duty
truck
manufaturing
336120
75
14,509
74.4
90.3
98.5
99.8
1,597.1
Motor
vehicle
body
manufacturinga
336211
747
9,009
34.4
43.9
59.4
74.9
694.7
Motor
home
manufacturing
336213
75
3,894
52.2
75.4
94.5
99.7
980.2
Travel
trailer
and
camper
manufacturing
336214
761
4,601
26.0
35.3
49.8
67.1
262.2
Gasoline
engine
and
engine
parts
manufacturing
336312
810
25,787
67.5
75.5
84.8
92.8
1,425.1
Vehicular
lighting
equipment
manufacturing
336321
99
3,336
58.3
76.5
92.7
99.1
1,164.4
Other
motor
vehicle
electrical
and
electronic
equipment
manufacturingb
336322
890
18,297
53.4
64.2
75.9
87.1
1,615.3
Motor
vehicle
steering
and
suspension
component
(
except
spring)
manufacturing
336330
183
10,633
60.1
72.3
85.6
97.1
1,415.6
Motor
vehicle
brake
system
manufacturing
336340
203
10,981
59.2
77.2
89.2
96.5
1,101.0
Motor
vehicle
transmission
and
power
train
parts
manufacturing
336350
427
30,106
60.0
79.1
90.9
96.2
1,056.6
All
other
motor
vehicle
parts
manufacturingc
336399
1,271
35,511
27.2
38.3
54.8
70.6
266.4
Motorcycles,
bicycles,
and
parts
manufacturing
336991
373
3,383
67.5
76.7
85.9
92.3
2,036.5
Military
armored
vehicle,
tank,
and
tank
component
manufacturingd
336992
37
1,064
85.0
92.4
99.0
100.0
NA
All
other
transportation
equipment
manufacturing
336999
349
4,437
50.7
75.3
83.0
90.6
885.2
(
continued)
2­
30
Table
2­
7.
Measurements
of
Concentration
of
Industries
Manufacturing
Coated
Plastic
Parts:
1997
(
continued)

Percentage
of
the
Value
of
Shipments
Accounted
for
by
x
Largest
Companies
Industry
NAICS
Code
Number
of
Companies
Value
of
Shipments
($
106)
x=
4
x=
8
x=
20
x=
50
Herfindahl­
Hirschmann
Index
Business
Machine
and
Computer
Equipment
Parts
Office
machinery
manufacturing
333313
158
3,163
53.0
68.2
81.2
93.5
1,208.3
Electronic
computer
manufacturing
334111
531
66,302
45.4
68.5
91.4
97.2
727.9
Computer
terminal
manufacturing
334113
141
1,487
39.4
64.5
87.2
96.5
645.4
Other
computer
peripheral
equipment
manufacturing
334119
1,015
26,911
45.3
60.2
73.0
85.4
659.7
Watch,
clock,
and
part
manufacturinge
334518
145
922
48.1
62.7
86.9
96.9
750.2
Lead
pencil
and
art
good
manufacturingf
339942
171
1,279
52.4
65.6
83.7
94.6
1,047.9
Miscellaneous
Products
Plastics
pipe
and
pipe
fitting
manufacturingg
326122
317
4,792
23.9
37.4
59.8
78.8
260.2
Polystyrene
foam
product
manufacturing
326140
379
4,899
41.4
50.0
65.5
82.7
665.4
Urethane
and
other
foam
product
(
except
polystyrene)
manufacturing
326150
447
6,665
32.3
43.5
62.9
78.8
403.1
All
other
plastics
product
manufacturingh
326199
7,522
65,632
5.0
8.1
13.7
23.3
14.9
Residential
electric
lighting
fixture
manufacturingi
335121
543
2,255
24.5
36.5
55.8
73.6
266.3
Current
carrying
wiring
device
manufacturing
335931
446
5,878
21.2
35.0
59.1
80.3
232.0
Laboratory
apparatus
and
furniture
manufacturing
339111
371
2,221
19.0
33.3
55.1
74.4
202.5
Costume
jewelry
and
novelty
manufacturingj
339914
917
1,288
25.2
41.2
55.3
69.0
256.3
Sporting
and
athletic
goods
manufacturing
339920
2,477
10,634
21.4
29.2
43.6
59.7
161.1
(
continued)
2­
31
Table
2­
7.
Measurements
of
Concentration
of
Industries
Manufacturing
Coated
Plastic
Parts:
1997
(
continued)

Percentage
of
the
Value
of
Shipments
Accounted
for
by
x
Largest
Companies
Industry
NAICS
Code
Number
of
Companies
Value
of
Shipments
($
106)
x=
4
x=
8
x=
20
x=
50
Herfindahl­
Hirschmann
Index
Miscellaneous
Products
(
continued)

Doll
and
stuffed
toy
manufacturing
339931
239
301
31.1
51.1
72.2
89.6
403.9
Game,
toy,
children's
vehicle
manufacturing
339932
756
4,463
42.7
53.1
66.0
80.1
564.0
Sign
manufacturing
339950
5,580
7,998
7.9
12.2
19.5
30.9
34.5
Musical
instrument
manufacturing
339992
552
1,325
32.6
45.5
68.1
83.3
420.8
a
Includes
707
firms
classified
under
the
truck
and
bus
bodies
(
SIC
3713).

b
Includes
252
firms
classified
under
the
electronic
components,
n.
e.
c.
(
SIC
3679),
and
570
firms
classified
under
the
engine
electrical
equipment
(
SIC
3694).

c
Includes
6
firms
classified
under
the
internal
combusion
engines,
n.
e.
c.
(
SIC
3519)
and
1
firm
under
the
all
other
manufacturing
industries
(
SIC
9994).

d
Includes
38
firms
classified
under
the
tanks
and
tank
components
(
SIC
3795).

e
Includes
2
firms
classified
under
the
wire
springs
(
SIC
3495),
and
128
firms
under
the
watches,
clocks,
and
watchcases
(
SIC
3873).

f
Includes
17
firms
classified
under
the
public
building
and
related
furniture
(
SIC
2531),
and
143
firms
under
the
lead
pencils
and
art
goods
(
SIC
3952).

g
Includes
349
firms
classified
under
the
plastics
pipe
(
SIC
3084).

h
Includes
140
firms
classified
under
the
manufacturing
industries,
n.
e.
c.
(
SIC
3999).

i
Includes
497
firms
classified
under
the
residential
lighting
fixtures
(
SIC
3645),
and
53
firms
under
the
manufacturing
industries,
n.
e.
c.
(
SIC
3999).

j
Includes
17
firms
classified
under
the
metal
coating
and
allied
services
(
SIC
3479)
and
80
firms
under
the
fabricated
metal
products,
n.
e.
c.
(
SIC
3499).

Source:
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999.
Manufacturing
 
Industry
Series,
1997
Economic
Census.
Washington,
DC.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2001a.
Economic
Census
 
Concentration
Ratios.

<
http://
www.
census.
gov/
prod/
ec97/
m31s­
cr.
pdf>
2­
32
Table
2­
8.
Distribution
of
Potentially
Affected
Firms
by
Employment:
2000
Employment
Range
Number
of
Firms
Share
of
Total
0
 
500
50
38%

500
 
1,000
22
17%

>
1,000
49
38%

NA
9
7%

Total
130
100%

Source:
Dialog
Corporation.
2001.
U.
S.
Company
Profiles.
<
www.
profound.
com>.
As
obtained
August
29,
2001.
Dun
and
Bradstreet.
2001.
D
&
B
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies.
Bethlehem,
PA:
Dun
&
Bradstreet.
Hoover's
Online.
2001.
Company
Capsules.
<
http://
www.
hoovers.
com>.
As
obtained
June
25,
2001.
Infausta
Incorporated.
2001.
References
[
computer
file].
Omaha,
NE:
Infausta,
Inc.
U.
S.
Bureau
of
the
Census.
2001b.
Quarterly
Financial
Report
for
Manufacturing,
Mining,
and
Trade
Corporations.
First
Quarter,
2001,
Series
QF/
01­
Q1.
Washington,
DC:
U.
S.
Government
Printing
Office.
2­
33
2.4.3
Vertical
and
Horizontal
Integration
Vertical
integration
is
a
potentially
important
dimension
in
analyzing
firm­
level
impacts
because
the
regulation
could
affect
a
vertically
integrated
firm
on
more
than
one
level.
For
example,
the
regulation
may
affect
companies
for
whom
surface
coating
of
plastic
parts
is
only
one
of
several
processes
in
which
the
firm
is
involved.
A
company
that
coats
plastic
parts,
for
example,
may
also
be
involved
in
manufacturing
automobiles,
aircraft,
sporting
goods,
and
appliances.
This
firm
would
be
considered
vertically
integrated
because
it
is
involved
in
more
than
one
level
of
production
including
surface
coating.
A
regulation
that
increases
the
cost
of
coating
plastic
parts
and
products
will
also
affect
the
cost
of
producing
the
final
products
that
use
coated
plastic
parts
and
products
in
the
production
process.
Firms
that
manufacture
and
coat
plastic
parts
and
then
use
those
parts
as
components
in
other
goods,
such
as
automobiles,

are
vertically
integrated.
Firms
comprising
facilities
that
coat
and
manufacture
plastic
parts
are
somewhat
vertically
integrated.
Firms
with
a
single
coating
facility
are
not
vertically
integrated.
Table
2­
9.
Distribution
of
Potentially
Affected
Firms
by
2000
Sales
Company
Sales
Number
of
Firms
Share
of
Total
Less
than
$
5
million
8
6%

$
5
million
to
$
50
million
38
29%

$
50
million
to
$
500
million
45
35%

$
500
million
to
$
1,000
million
8
6%

$
1
billion
or
greater
22
17%

NA
9
7%

Total
130
100%

Source:
Dialog
Corporation.
2001.
U.
S.
Company
Profiles.
<
www.
profound.
com>.
As
obtained
August
29,
2001.
Dun
and
Bradstreet.
2001.
D&
B
Million
Dollar
Directory:
America's
Leading
Public
and
Private
Companies.
Bethlehem,
PA:
Dun
&
Bradstreet.
Hoover's
Online.
2001.
Company
Capsules.
<
http://
www.
hoovers.
com>.
As
obtained
June
25,
2001.
Infausta
Incorporated.
2001.
References
[
computer
file].
Omaha,
NE:
Infausta,
Inc.
U.
S.
Bureau
of
the
Census.
2001b.
Quarterly
Financial
Report
for
Manufacturing,
Mining,
and
Trade
Corporations.
First
Quarter,
2001,
Series
QF/
01­
Q1.
Washington,
DC:
U.
S.
Government
Printing
Office.
2­
34
Horizontal
integration
is
also
a
potentially
important
dimension
in
firm­
level
impact
analysis
because
a
diversified
firm
may
own
facilities
in
unaffected
industries,
giving
them
resources
to
spend
on
complying
with
this
regulation
 
if
they
so
choose.
The
130
potentially
affected
firms
described
in
Section
2.4.2
demonstrate
little
diversification.
Most
of
the
larger
firms
are
oriented
in
a
single
industry,
usually
motor
vehicle
manufacturing.
Many
independent
single­
facility
firms
may
produce
a
wide
variety
of
products.
However,
because
the
Plastic
Parts
and
Products
NESHAP
is
regulating
a
production
process
used
for
all
those
products,
those
firms
will
find
almost
all
products
are
affected
by
the
regulation.

2.4.4
Small
Businesses
Although
the
rule
affects
firms
of
all
sizes,
small
businesses
may
have
special
problems
with
compliance.
The
Regulatory
Flexibility
Act
(
RFA)
of
1980,
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
requires
that
special
consideration
be
given
to
these
entities.
The
Agency
classified
67
potentially
affected
companies
as
small
using
the
approach
outlined
below:

°
Standard
Industrial
Classification
(
SIC)
code
data
were
available
for
105
companies
(
81
percent).
These
codes
were
mapped
to
NAICS
industries
to
determine
the
appropriate
size
standard.
In
cases
where
mapping
resulted
in
two
or
more
NAICS
codes,
we
used
the
highest
size
standard.

°
Of
the
remaining
25
companies,
16
companies
either
had
employment
greater
than
1,500
employees
(
therefore
large
under
any
manufacturing
size
standard)
or
had
employment
less
than
500
employees
(
small
under
any
manufacturing
size
standard).

°
We
assumed
firms
without
employment
data
(
nine
firms)
are
small
in
this
analysis.
This
assumption
may
potentially
overstate
the
number
of
small
firms
in
the
analysis.

2.5
Markets
and
Trends
Because
plastic
parts
are
used
in
such
widely
varied
products
as
automobiles,

computers,
and
toys,
surface­
coated
plastic
parts
and
products
are
found
in
many
markets.

The
demand
for
surface
coating
services
is
driven
by
all
of
these
markets.
This
section
describes
some
of
the
major
trends
in
these
markets,
including
domestic
production
and
consumption,
changes
in
net
exports,
and
price
trends.
2­
35
2.5.1
Production
Parts
coated
for
use
in
computer
equipment
are
likely
to
have
experienced
the
largest
increase
in
production
in
the
past
years,
since
the
computer
and
peripheral
equipment
industry
has
been
expanding
rapidly,
as
shown
in
Table
2­
10.
Table
2­
10
also
illustrates
that
the
automobile
and
light
duty
truck
industries
have
been
growing
and
that
the
miscellaneous
product
industries
have
been
decreasing
production
fairly
steadily.

2.5.2
Consumption
Tables
2­
11
through
2­
13
indicate
how
much
the
above
increases
and
decreases
in
production
can
be
accounted
for
by
changes
in
domestic
and
foreign
consumption.
Most
notably,
net
exports
of
goods
decreased
for
all
industries
described.
At
least
some
of
this
decrease
is
due
primarily
to
the
rapid
growth
of
the
U.
S.
economy
(
and
domestic
demand
for
goods)
relative
to
other
economies
rather
than
to
an
increase
in
the
total
share
of
foreign
producers
in
the
market.
Apparent
domestic
consumption
increased
for
every
industry
shown
except
for
costume
jewelry.

2.5.3
Pricing
Trends
Prices
for
products
manufactured
by
the
transportation
industries
and
miscellaneous
manufacturing
industries
have
risen
while
prices
for
office,
computing,
and
accounting
machines
have
dropped
37.6
percent
from
1990
to
1999,
as
shown
in
Table
2­
14.
This
fact,

along
with
the
tremendous
increase
in
the
value
of
domestic
product
shipments
in
the
computer
industry,
suggests
that
the
volume
of
plastic
parts
used
as
inputs
into
business
machines
and
computers
has
increased
dramatically
over
the
past
5
years,
even
more
so
than
indicated
solely
by
the
data
on
value
of
shipments.
Table
2­
14
shows
price
changes
for
all
three
industry
groups
that
produce
a
large
number
of
surface­
coated
plastic
parts.
2­
36
Table
2­
10.
Value
of
Domestic
Producta
Shipments
in
Some
Industries
Using
Surface
Coated
Plastic
Parts
(
106
$
1997)

1995
1996
1997b
1998b
1999c
Change
from
1995
to
1999
(%)

Automobile
and
Light
Duty
Truck
Parts
Automotive
Parts
and
Accessories
(
NAICS
336370,
336311,
336321,
335911,
336322,
336312,
336330,
336340,
336350,
336399)
$
145,926.6
$
148,090.6
$
167,600.0
$
258,228.0
$
196,015.3
34%

Motor
Vehicles
and
Bodies
(
NAICS
336111,
336112,
336120,
336211,
336992)
$
208,599.5
$
205,776.5
$
215,359.0
$
306,998.6
$
224,644.9
8%

Motorcycles
and
Parts
(
NAICS
334111)
$
1,442.0
$
1,623.2
$
1,658.7
$
1,770.5
$
1,924.3
33%

Business
Machine
and
Computer
Equipment
Parts
Computers
and
Peripherals
(
NAICS
334111,
334112,
334113,
334119)
$
60,533.8
$
68,334.7
$
84,300.0
$
106,301.6
$
123,742.3
104%

Miscellaneous
Products
Dolls,
Toys,
and
Games
(
NAICS
339931,
336991,
339932)
$
4,605.7
$
4,193.0
$
4,261.0
$
4,195.2
$
4,175.9
 
9%

Sporting
and
Athletic
Goods
(
NAICS
339920)
$
9,018.7
$
9,289.4
$
9,510.0
$
9,299.5
$
9,256.7
3%

Bicycles
and
Bicycle
Parts
(
NAICS
334111)
$
1,024.6
$
969.5
$
975.0
$
859.2
$
694.9
 
32%

Costume
Jewelry
and
Novelties
(
NAICS
339914)
$
278,893.6
$
2,052.6
$
71,611.5
$
11,842.9
$
10,167.3
 
35%

a
Product
shipments
include
all
specific
products
classified
within
the
industries
listed
regardless
of
whether
the
establishments
producing
those
products
fall
within
the
industry
classification.
b
Estimate
c
Forecast
Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.
Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu37__#,
pcu357_#,
pcu39__#,
pcu3751#
1,
and
pcu3751#
2.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.
2­
37
Table
2­
11a.
Production
and
Apparent
Consumption
of
Automotive
Parts
and
Accessories
(
NAICS
336370,
336311,
336321,
335911,
336322,
336312,
336330,
336340,
336350,
336399
[
SICs
3465,
3592,
3647,
3691,
3694,
3714])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
145,926.6
$
144,381.7
$
1,544.9
1996
$
148,090.6
$
147,572.0
$
518.6
1997
$
148,201.0
$
147,682.0
$
519.0
1998
$
258,228.0
$
256,981.7
$
1,246.4
1999
$
196,015.3
$
197,012.3
 
$
997.0
Change
from
1995
to
1999
(%)
34%
36%
 
165%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu37__#.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.

Table
2­
11b.
Production
and
Apparent
Consumption
of
Motor
Vehicles
and
Bodies
(
NAICS
336111,
336112,
336120,
336211,
336992
[
SICs
3711,
3713])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
208,599.5
$
272,191.6
 
$
63,592.0
1996
$
205,776.5
$
269,973.7
 
$
64,197.1
1997
$
215,359.0
$
283,891.0
 
$
68,532.0
1998
$
306,998.6
$
416,267.3
 
$
109,268.7
1999
$
224,644.9
$
310,041.2
 
$
85,396.3
Change
from
1995
to
1999
(%)
8%
14%
 
34%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu37.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.
2­
38
Table
2­
11c.
Production
and
Apparent
Consumption
of
Motorcycles
and
Parts
(
NAICS
334111
[
SIC
37512])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
1,442.0
$
2,033.5
 
$
591.5
1996
$
1,623.2
$
2,134.3
 
$
511.0
1997
$
1,658.7
$
2,102.7
 
$
444.1
1998
$
1,770.5
$
2,428.3
 
$
657.9
1999
$
1,924.3
$
2,869.4
 
$
945.1
Change
from
1995
to
1999
(%)
33%
41%
 
60%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu37__#,
and
pcu3751#
2.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.

Table
2­
12.
Production
and
Apparent
Consumption
of
Computers
and
Peripheral
Equipment
(
NAICS
334111,
334112,
334113,
334119
[
SICs
3571,
3572,
3575,
3577])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
60,533.8
$
71,611.5
 
$
11,077.7
1996
$
68,334.7
$
84,088.1
 
$
15,753.4
1997
$
84,300.0
$
106,100.0
 
$
21,800.0
1998
$
106,301.6
$
132,433.7
 
$
26,132.1
1999
$
123,742.3
$
156,812.2
 
$
33,069.9
Change
from
1995
to
1999
(%)
104%
119%
 
199%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu357_#.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.
2­
39
Table
2­
13a.
Production
and
Apparent
Consumption
of
Dolls,
Toys,
and
Games
(
NAICS
339931,
336991,
339932
[
SICs
3942,
3944])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
4,605.7
$
11,907.1
 
$
7,301.5
1996
$
4,193.0
$
12,899.0
 
$
8,706.0
1997
$
4,261.0
$
15,351.0
 
$
11,090.0
1998
$
4,195.2
$
16,170.3
 
$
11,975.0
1999
$
4,139.3
$
16,548.2
 
$
12,408.9
Change
from
1995
to
1999
(%)
 
10%
39%
 
70%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu39__#.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.

Table
2­
13b.
Production
and
Apparent
Consumption
of
Sporting
and
Athletic
Goods
(
NAICS
339920
[
SIC
3949])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
9,018.7
$
10,269.8
 
$
1,251.1
1996
$
9,289.4
$
10,459.3
 
$
1,169.9
1997
$
9,510.0
$
10,675.0
 
$
1,165.0
1998
$
9,299.5
$
10,854.1
 
$
1,554.6
1999
$
9,415.1
$
10,981.3
 
$
1,566.2
Change
from
1995
to
1999
(%)
4%
7%
 
25%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu39__#.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.
2­
40
Table
2­
13c.
Production
and
Apparent
Consumption
of
Bicycles
and
Bicycle
Parts
(
NAICS
334111
[
SIC
37511])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
1,024.6
$
1,719.8
 
$
695.1
1996
$
969.5
$
1,563.2
 
$
593.7
1997
$
975.0
$
1,644.0
 
$
669.0
1998
$
859.2
$
1,681.5
 
$
822.2
1999
$
694.9
$
1,722.4
 
$
1,027.5
Change
from
1995
to
1999
(%)
 
32%
0%
 
48%

Sources:
U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&
Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

Prices
adjusted
using
data
from
the
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu3751#
1.
Available
at
www.
bls.
gov.
Obtained
on
July
12,
2000.

Table
2­
13d.
Production
and
Apparent
Consumption
of
Costume
Jewelry
and
Novelties
(
NAICS
339914
[
SIC
3961])
(
106
$
1997)

Year
Domestic
Production
Apparent
Domestic
Consumption
Net
Exports
1995
$
1,813.6
$
2,195.8
 
$
382.2
1996
$
1,681.6
$
2,041.0
 
$
359.3
1997
$
1,229.0
$
1,552.0
 
$
323.0
1998
$
1,195.5
$
1,569.5
 
$
374.0
1999
$
1,170.2
$
1,571.2
 
$
401.0
2­
41
Table
2­
14.
Price
Indices
in
Industries
that
Produce
Surface­
Coated
Plastic
Parts
Year
Transportation
Equipment
(
NAICS
[
SIC
37])
Office,
Computing,
and
Accounting
Machines
(
NAICS
333,
334,
339
[
SIC
357])
Miscellaneous
Manufacturing
Industries
(
NAICS
339
[
SIC
39])

1990
115.6
NA
114.9
1991
119.8
NA
117.5
1992
123.0
NA
119.6
1993
126.3
NA
121.5
1994
130.1
NA
123.3
1995
132.2
70.5
125.9
1996
134.2
63.4
127.8
1997
134.1
55.9
129.0
1998
133.6
48.8
129.7
1999
134.5
44.0
130.3
Change
in
price
from
1990
to
1999
(%)
16.3%
 
37.6%
a
13.4%

NA
=
not
available
a
This
is
the
percentage
change
from
1995
to
1999.

Source:
U.
S.
Bureau
of
Labor
Statistics,
Producer
Price
Index
Revision
 
Current
Series,
Series
pcu37__#,
pcu357_#,
and
pcu39__#.
<
http://
www.
bls.
gov>.
As
obtained
on
July
12,
2000.
3­
1
SECTION
3
ECONOMIC
IMPACT
ANALYSIS
Under
the
authority
of
Title
III
of
the
Clean
Air
Act,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
is
currently
developing
a
regulation
to
reduce
organic
hazardous
air
pollutants
(
HAPs)
from
the
application
of
coatings
to
various
plastic
parts
and
products
in
over
20
different
industries.
Although
the
rule
affects
firms
of
all
sizes,
small
businesses
may
have
special
problems
with
compliance.
The
Regulatory
Flexibility
Act
(
RFA)
of
1980,
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
requires
that
special
consideration
be
given
to
these
entities.
Therefore,
this
section
focuses
on
the
compliance
burden
for
small
businesses
to
determine
whether
this
rule
is
likely
to
impose
a
significant
impact
on
a
substantial
number
of
the
affected
small
entities
(
SISNOSE)
within
this
source
category.

3.1
Results
in
Brief
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
is
projected
to
increase
the
costs
of
surface
coating
of
plastic
parts
by
approximately
$
10.8
million
(
1998
dollars).
Of
these
costs,
$
8.6
million
are
projected
to
be
incurred
by
63
large
firms,
while
$
2.3
million
in
costs
are
projected
to
be
incurred
by
67
small
firms.
EPA's
economic
impact
analysis
focused
on
assessing
impacts
to
small
businesses.
EPA
estimates
that
companies
in
32
NAICS
codes
will
be
affected
by
the
rule.
The
number
of
small
businesses
in
each
NAICS
code
was
determined
based
on
the
size
standards
defined
by
the
Small
Business
Administration
(
SBA)
for
that
NAICS
code.
The
mean
costs
incurred
by
small
businesses
($
34,300)
are
much
smaller
than
the
mean
costs
estimated
for
large
businesses
($
136,000).

EPA
assessed
the
economic
impacts
of
the
regulation
by
comparing
the
engineering
cost
estimates
to
baseline
company
sales.
For
small
companies,
the
cost­
to­
sales
ratio
(
CSR)

averages
0.26
percent.
The
maximum
CSR
for
a
small
company
is
1.83
percent.
For
large
companies,
the
average
CSR
is
0.03
percent,
and
the
maximum
CSR
is
0.43
percent.
No
company,
large
or
small,
is
projected
to
incur
costs
exceeding
2
percent
of
baseline
sales.
1These
include
Dialog
Corporation
(
2001),
Dun
&
Bradstreet
(
2001),
Hoover's
(
2001),
and
InfoUSA
(
2001).
In
addition,
these
data
were
supplemented
by
ICR
survey
responses.

2The
manufacturing
sector
includes
North
American
Industry
Classification
System
(
NAICS)
codes
311
to
339.

3The
profit
rate
is
computed
as
income
before
income
taxes
divided
by
net
sales.

3­
2
EPA
concludes
that
the
rule
will
not
result
in
significant
impacts
to
a
substantial
number
of
small
entities.
Although
EPA
does
not
project
disproportionate
or
significant
impacts
for
small
businesses,
the
Agency
has
tried
to
reduce
impacts
on
small
entities
by
affording
them
extensive
flexibility
in
demonstrating
compliance
through
pollution
prevention
rather
than
use
of
add­
on
control
technology,
and
has
sought
input
from
small
entities
throughout
its
outreach
to
affected
industries.

3.2
Baseline
Data
Set
The
engineering
analysis
determined
costs
for
185
facilities
potentially
affected
by
the
plastic
parts
NESHAP.
Using
facility
names
and
addresses
(
where
available),
EPA
identified
130
ultimate
parent
companies
in
publically
available
company
databases1
and
collected
sales,

profit,
and
employment
information.
The
following
sections
describe
the
results
of
the
data
collection.

3.2.1
Sales
Data
Summary
Companies
owning
facilities
potentially
affected
by
the
plastic
parts
NESHAP
reported
a
broad
range
of
annual
sales
(
see
Figure
3­
1).
In
2000,
sales
revenue
ranged
from
$
1.3
million
to
over
$
185
billion
with
a
median
value
of
$
88
million.
Sixteen
companies
(
13
percent)
reported
less
than
$
10
million
in
annual
sales.

3.2.2
Profit
Data
Summary
Companies
affected
by
the
plastic
parts
NESHAP
appear
to
be
less
profitable
on
average
than
the
manufacturing
sector.
2
Broad
industry
profitability
measures
reported
in
the
Quarterly
Financial
Reports
(
QFR)
(
Bureau
of
the
Census,
2001)
show
the
manufacturing
sector's
profit
rate3
was
8.4
percent
for
the
four
quarters
of
2000
compared
to
6.9
percent
for
industries
potentially
affected
by
the
rule.
However,
the
use
of
aggregate
two­
digit
SIC
data
may
actually
understate
this
difference.
Profitability
data
available
for
32
companies
show
an
average
(
median)
profit
rate
of
3.0
(
2.56)
percent,
with
54
percent
of
the
sample
reporting
3­
3
rates
below
3
percent
for
2000
(
see
Figure
3­
2).
The
sample
consists
of
30
large
firms
and
two
small
firms,
suggesting
inferences
about
profitability
drawn
from
this
sample
are
7%
6%
26%

13%
24%

7%
18%

0%
5%
10%
15%
20%
25%
30%

<$
5
$
5­
9
$
10­
49
$
50­
99
$
100­
499
$
500­
1,000
>
1,000
Sales
Range
($
Millions)
Frequency
(%)
Total
Firms
Figure
3­
1.
Distribution
of
Firm
Sales
(
n=
121)
4
Standard
Industrial
Classification
(
SIC)
code
data
were
available
for
105
companies
(
81
percent).
These
codes
were
mapped
to
NAICS
industries
to
determine
the
appropriate
size
standard.
In
cases
where
mapping
resulted
in
two
or
more
NAICS
codes,
we
used
the
highest
size
standard.
Of
the
remaining
25
companies,
16
companies
either
employed
more
than
1,500
employees
(
therefore
large
under
any
manufacturing
size
standard)
or
employed
fewer
than
500
employees
(
small
under
any
manufacturing
size
standard).
We
assumed
firms
without
employment
data
(
nine
firms)
are
small
in
this
analysis.
This
assumption
may
potentially
overstate
the
number
of
small
firms
in
the
analysis.

3­
4
applicable
to
large
firms.
The
only
two
profit
data
observations
for
small
firms
show
profit
rates
of
0.8
percent
and
 
3.7
percent.

Given
the
limited
profitability
data
for
small
firms,
we
examined
QFR
data
and
compared
the
industry
profitability
rates
to
those
of
firms
with
less
than
<$
25
million
in
assets
(
proxy
for
small
firms).
The
rates
are
very
similar,
and
in
some
cases,
smaller
firms
were
actually
more
profitable
in
2000.
However,
we
concede
that
QFR
data
are
reported
at
the
two­
digit
SIC
level
and
it
is
unclear
whether
we
would
find
the
same
relationships
between
small
and
large
companies
in
the
source
category.

3.2.3
Employment
Data
and
Identification
of
Small
Firms
Using
the
SBA's
size
standards
for
NAICS
codes
standards,
we
identified
67
companies
(
52
percent)
as
small
for
this
analysis.
4
Company
employment
ranged
from
15
to
6%
16%
32%

16%
29%

0%
5%
10%
15%
20%
25%
30%
35%

<
0
0­
1%
1­
3%
3­
5%
>
5%

Profit
Rate
Frequency
Figure
3­
2.
Distribution
of
Profit
Rates
(
n=
31)
3­
5
CSR
(%)


n
i

1
TACC
TR
j
(
3.1)
386,000
employees
with
a
median
value
of
679
employees
(
see
Figure
3­
3).
These
data
also
suggest
the
affected
sources
may
include
small
specialty
coating
companies
as
well
as
large
vertically
integrated
firms
such
as
automobile
manufacturers.

3.3
Methods
EPA
assessed
the
economic
and
financial
impacts
of
the
rule
using
the
ratio
of
compliance
costs
to
the
value
of
sales
(
cost­
to­
sales
ratio
or
CSR)
using
revenues,
control
costs,
and
accounting
measures
of
profit.
The
analysis
assesses
the
burden
of
the
rule
by
assuming
the
affected
firms
absorb
the
control
costs,
rather
than
passing
them
on
to
consumers
in
the
form
of
higher
prices.
One
drawback
for
this
approach
is
that
it
does
not
consider
interaction
between
producers
and
consumers
in
a
market
context.
Therefore,
it
likely
overstates
the
impacts
on
firms
affected
by
the
rule
and
understates
the
impacts
on
consumers.
We
used
the
following
equation
to
compute
the
CSR:
3­
6
where
TACC
=
total
annual
compliance
costs,

i
=
indexes
the
number
of
affected
plants
owned
by
company
j,

n
=
number
of
affected
plants,
and
TRj
=
total
revenue
of
parent
company
j.

Given
the
profitability
data
presented
in
previous
sections,
we
selected
1
and
3
percent
CSR
thresholds
as
indicators
of
significant
economic
impact.

3.4
Results
Small
firms
do
not
bear
a
disproportionate
share
of
the
total
annual
compliance
costs
(
TACC).
As
shown
in
Table
3­
1,
small
companies
account
for
approximately
21
percent
of
12%
17%

12%
18%
40%

0%
10%
20%
30%
40%
50%

<
100
100­
249
250­
499
500­
1,000
>
1,000
Employment
Range
Frequency
(%)

Figure
3­
3.
Distribution
of
Firm
Employment
(
n=
121)
5For
more
information
on
costs,
see
Teal
and
Burlew
(
2001).

3­
7
the
rule's
$
10.8
million
TACC.
In
addition,
the
average
small
company's
TACC
is
much
smaller
than
large
firms
($
34,000
per
company
compared
to
$
136,000).
5
The
results
of
the
screening
analysis
show
that
three
small
firms
are
projected
to
incur
compliance
costs
that
are
between
1
and
3
percent
of
sales.
This
represents
approximately
5
percent
of
the
affected
small
firms
with
data.
No
small
firm
is
projected
to
incur
costs
greater
than
3
percent
of
sales.
For
small
firms
with
sales
data,
the
average
(
median)
CSR
is
0.26
percent
(
0.08
percent).
In
contrast,
none
of
the
62
large
firms
are
affected
at
greater
than
1
Table
3­
1.
Summary
Statistics
for
SBREFA
Screening
Analysis:
2000
Small
Large
Total
Total
number
of
companies
67
63
130
Total
annual
compliance
Costs
($
TACC)
$
2,301,368
$
8,580,662
$
10,882,030
Average
($
TACC)
per
company
$
34,349
$
136,201
$
83,708
Distribution
of
Cost­
to­
Sales
Ratios
Number
Share
Number
Share
Number
Share
Companies
with
sales
data
58
87%
63
100%
121
93%

Compliance
costs
are
<
1%
of
sales
55
95%
63
100%
118
98%

Compliance
costs
are
1%
to
3%
of
sales
3
5%
0
0%
3
2%

Compliance
costs
are

3%
of
sales
0
0%
0
0%
0
0%

Compliance
Cost­
to­
Sales
Ratios
Mean
0.260%
0.032%
0.141%

Median
0.081%
0.008%
0.029%

Maximum
1.834%
0.425%
1.834%

Minimum
0.003%
0.000%
0.000%
3­
8
percent
of
sales.
The
average
(
median)
CSR
is
0.03
percent
(
0.01
percent)
for
all
large
firms
with
data.
Figure
3­
4
summarizes
the
distribution
of
impacts
by
firm
size.

3.5
Estimated
Impacts
on
Small
Businesses
The
RFA
generally
requires
an
agency
to
prepare
a
regulatory
flexibility
analysis
of
any
rule
subject
to
notice
and
comment
rulemaking
requirements
under
the
Administrative
Procedure
Act
or
any
other
statute
unless
the
agency
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Small
entities
include
small
businesses,
small
organizations,
and
small
governmental
jurisdictions.

For
purposes
of
assessing
the
impacts
of
today's
rule
on
small
entities,
a
small
entity
is
defined
as
(
1)
a
small
business
whose
parent
company
has
fewer
than
500
or
1,000
employees,
depending
on
the
size
definition
for
the
affected
North
American
Industry
Classification
System
(
NAICS)
code;
(
2)
a
small
governmental
jurisdiction
that
is
a
government
of
a
city,
county,
town,
school
district,
or
special
district
with
fewer
than
50,000
people;
and
(
3)
a
small
organization
that
is
any
not­
for­
profit
enterprise
that
is
independently
5%
14%
81%
100%

0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%

0%
>
0­
0.5%
>
0.5­
1%
>
1­
3%
>
3­
5%
>
5­
7%
>
7­
10%
>
10­
15%
>
15­
20%
>
20%

CSR
Range
Frequency
(%)
Small
Firms
Large
Firms
Figure
3­
4.
Distribution
of
Cost­
to­
Sales
Ratios
(
CSRs):
Small
and
Large
Firms
(
n=
121)
3­
9
owned
and
operated
and
is
not
dominant
in
its
field.
It
should
be
noted
that
companies
in
32
NAICS
codes
are
affected
by
this
rule,
and
the
small
business
definition
applied
to
each
industry
by
NAICS
code
is
that
listed
in
the
Small
Business
Administration
(
SBA)
size
standards
(
13
CFR
121).

After
considering
the
economic
impacts
of
today's
rule
on
small
entities,
EPA
certifies
that
this
action
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
We
have
determined
that
67
of
the
130
firms,
or
51
percent
of
the
total,
affected
by
this
rule
may
be
small.
While
the
number
of
small
firms
appears
to
be
a
large
proportion
of
the
total
number
of
affected
firms,
the
small
firms
only
experience
21
percent
of
the
total
national
compliance
cost
of
about
$
11
million
(
1997$).
Of
the
67
affected
small
firms,
only
three
firms
are
estimated
to
have
compliance
costs
that
exceed
1
percent
of
their
revenues.

The
maximum
impact
on
any
affected
small
firm
is
a
compliance
cost
of
1.8
percent
of
its
sales.
Finally,
while
there
is
a
difference
between
the
median
compliance
cost­
to­
sales
estimates
for
the
affected
small
and
large
firms
(
0.08
percent
compared
to
0.01
percent
for
the
large
firms,
and
0.03
percent
across
all
affected
firms),
no
adverse
economic
impacts
are
expected
for
either
small
or
large
firms
affected
by
the
rule.
Therefore,
the
affected
small
firms
are
not
disproportionately
affected
by
this
rule
as
compared
to
the
affected
large
firms.

Although
this
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities,
EPA
nonetheless
has
tried
to
reduce
the
impact
of
this
rule
on
small
entities.

Small
entities
will
be
afforded
extensive
flexibility
in
demonstrating
compliance
through
pollution
prevention
rather
than
the
use
of
add­
on
control
technology.
Pollution
prevention
methods
of
compliance
will
not
only
minimize
capital
and
operating
costs
but
will
result
in
reduced
burden
associated
with
recordkeeping
and
reporting.
The
Agency
has
also
reached
out
to
stakeholders
that
are
small
entities
or
that
represent
small
entities
as
part
of
our
outreach
to
affected
industries.
R­
1
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prod/
ec97/
97m3399f.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999m.
"
Gasoline
Engine
and
Engine
Parts
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3363b.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999n.
"
Industrial
Truck,
Tractor,

Trailer,
and
Stacker
Machinery
Manufacturing."
Manufacturing
 
Industry
Series,

1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3339g.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999o.
"
Laboratory
Apparatus
and
Furniture
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3391a.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999p.
"
Light
Truck
and
Utility
Vehicle
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3361b.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999q.
"
Magnetic
Optical
Recording
Media
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3346c.
pdf>.
As
obtained
December
1999.
R­
5
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999r.
"
Military
Armored
Vehicle,

Tank,
and
Tank
Component
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3369b.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999s.
"
Motor
Home
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3362c.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999t.
"
Motor
Vehicle
Body
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3362a.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999u.
"
Motor
Vehicle
Brake
System
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3363f.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999v.
"
Motor
Vehicle
Steering
and
Suspension
Components
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3363c.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999w.
"
Motor
Vehicle
Transmission
and
Power
Train
Parts
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3363g.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999x.
"
Motorcycle,
Bicycle,
and
Parts
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3369a.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999y.
"
Musical
Instrument
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3399n.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999z.
"
Office
Machinery
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3333c.
pdf>.
As
obtained
December
1999.
R­
6
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999aa.
"
Other
Computer
Peripheral
Equipment
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3341d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999bb.
"
Other
Metal
Container
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3324d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999cc.
"
Other
Motor
Vehicle
Electrical
and
Electronic
Equipment
Manufacturing."
Manufacturing
 
Industry
Series,

1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3363d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999dd.
"
Plastics
Pipe
and
Pipe
Fitting
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3261e.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999ee.
"
Polystyrene
Foam
Product
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3261i.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999ff.
"
Printed
Circuit
Assemble
(
Electronic
Assembly)
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3344h.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999gg.
"
Showcase,
Partition,

Shelving,
and
Locker
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3372d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999hh.
"
Sign
Manufacturing."

Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3399l.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999ii.
"
Sporting
and
Athletic
Good
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3399e.
pdf>.
As
obtained
December
1999.
R­
7
U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999jj.
"
Travel
Trailer
and
Camper
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3362d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999kk.
"
Truck
Trailer
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3362b.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999ll.
"
Unsupported
Plastics
Profile
Shape
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3261d.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999mm.
"
Urethane
and
Other
Foam
Product
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.

<
http://
www.
census.
gov/
prod/
ec97/
97m3261h.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1999nn.
"
Vehicular
Lighting
Equipment
Manufacturing."
Manufacturing
 
Industry
Series,
1997
Economic
Census.
<
http://
www.
census.
gov/
prod/
ec97/
97m3363c.
pdf>.
As
obtained
December
1999.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
1997
Economic
Census:
The
Bridge
Betwen
NAICS
and
SIC.
<
http://
www.
census.
gov/
epcd/
ec97brdg/>.
Last
updated
on
June
27,
2000.

U.
S.
Department
of
Commerce,
Bureau
of
the
Census.
2001a.
Economic
Census
 
Concentration
Ratios.
<
http://
www.
census.
gov/
prod/
ec97/
m31s­
cr.
pdf>

U.
S.
Department
of
Commerce,
International
Trade
Administration.
2000.
U.
S.
Industry
&

Trade
Outlook
2000.
New
York:
The
McGraw­
Hill
Companies.

U.
S.
Environmental
Protection
Agency.
1994.
Alternative
Control
Techniques
Document:

Surface
Coating
of
Automotive/
Transportation
and
Business
Machine
Plastic
Parts.

EPA
435/
R­
94­
017.
Research
Triangle
Park,
NC:
U.
S.
Environmental
Protection
Agency.
R­
8
U.
S.
Environmental
Protection
Agency,
Office
of
Compliance,
Office
of
Enforcement
and
Compliance
Assurance.
1995.
EPA
Office
of
Compliance
Sector
Notebook
Project
 
Profile
of
the
Motor
Vehicle
Industry.
EPA/
310­
R­
95­
009.
Washington,

DC:
U.
S.
Environmental
Protection
Agency.

U.
S.
Environmental
Protection
Agency,
OAQPS,
Coatings
and
Consumer
Products
Group.

1998.
"
Preliminary
Industry
Characterization:
Surface
Coating
of
Plastic
Parts
and
Products."
Research
Triangle
Park,
NC:
U.
S.
Environmental
Protection
Agency.

U.
S.
Environmental
Protection
Agency
(
EPA).
2001.
ICR
Survey
Responses.
Washington,

DC:
U.
S.
Environmental
Protection
Agency.
TECHNICAL
REPORT
DATA
(
Please
read
Instructions
on
reverse
before
completing)

1.
REPORT
NO.

EPA­
452/
R­
03­
019
2.
3.
RECIPIENT'S
ACCESSION
NO.

4.
TITLE
AND
SUBTITLE
Economic
Impact
Analysis
of
the
Plastic
Parts
and
Products
NESHAP:
Final
Report
5.
REPORT
DATE
August
2003
6.
PERFORMING
ORGANIZATION
CODE
7.
AUTHOR(
S)
8.
PERFORMING
ORGANIZATION
REPORT
NO.

RTI
Project
Number
7647­
004­
392
9.
PERFORMING
ORGANIZATION
NAME
AND
ADDRESS
RTI
International
Center
for
Regulatory
Economics
and
Policy
Research,
Hobbs
Bldg.
Research
Triangle
Park,
NC
27709
10.
PROGRAM
ELEMENT
NO.

11.
CONTRACT/
GRANT
NO.

68­
D­
99­
024
12.
SPONSORING
AGENCY
NAME
AND
ADDRESS
Director
Office
of
Air
Quality
Planning
and
Standards
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
13.
TYPE
OF
REPORT
AND
PERIOD
COVERED
14.
SPONSORING
AGENCY
CODE
EPA/
200/
04
15.
SUPPLEMENTARY
NOTES
16.
ABSTRACT
This
report
evaluates
the
economic
impacts
of
the
Surface
Coating
of
Plastic
Parts
and
Products
NESHAP.
The
report
includes
an
industry
profile
and
assesses
the
impact
of
the
regulation
by
comparing
the
engineering
cost
estimates
to
baseline
company
sales.
The
report
also
provides
the
screening
analysis
for
small
business
impacts.

17.
KEY
WORDS
AND
DOCUMENT
ANALYSIS
a.
DESCRIPTORS
b.
IDENTIFIERS/
OPEN
ENDED
TERMS
c.
COSATI
Field/
Group
economic
impacts
small
business
impacts
social
costs
Air
Pollution
Control
Economic
Impact
Analysis
Regulatory
Flexibility
Analysis
18.
DISTRIBUTION
STATEMENT
Release
Unlimited
19.
SECURITY
CLASS
(
Report)

Unclassified
21.
NO.
OF
PAGES
83
20.
SECURITY
CLASS
(
Page)

Unclassified
22.
PRICE
EPA
Form
2220­
1
(
Rev.
4­
77)
PREVIOUS
EDITION
IS
OBSOLETE
United
States
Office
of
Air
Quality
Planning
and
Standards
Publication
No.
EPA­
452/
R­
03­
019
Environmental
Protection
Air
Quality
Strategies
and
Standards
Division
August
2003
Agency
Research
Triangle
Park,
NC
