Economic
Impact
Analysis
of
the
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
NESHAP:
Final
Report
EPA­
452/
R­
03­
018
August
2003
Economic
Impact
Analysis
of
the
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
NESHAP
By:
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Innovative
Strategies
and
Economics
Group,
C339­
01
Research
Triangle
Park,
NC
27711
This
report
has
been
reviewed
by
the
Emission
Standards
Division
of
the
Office
of
Air
Quality
Planning
and
Standards
of
the
United
States
Environmental
Protection
Agency
and
approved
for
publication.
Mention
of
trade
names
or
commercial
products
is
not
intended
to
constitute
endorsement
or
recommendation
for
use.
Copies
of
this
report
are
available
through
the
Library
Services,
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC
27711,
or
from
the
National
Technical
Information
Services
5285
Port
Royal
Road,
Springfield,
VA
22161.
Page
4
ECONOMIC
IMPACT
AND
SMALL
BUSINESS
ANALYSIS:
MISCELLANEOUS
METAL
PARTS
AND
PRODUCTS
SURFACE
COATING
1
INTRODUCTION
Under
Section
112(
d)
of
the
Clean
Air
Act
(
CAA),
the
U.
S.
Environmental
Protection
Agency
(
EPA)
is
developing
a
National
Emissions
Standard
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
Miscellaneous
Metal
Parts
and
Products
(
Surface
Coating)
source
category
(
MMPP).
The
MMPP
encompasses
all
industries
that
coat
metal
parts
and
products,
but
are
not
subject
to
other
surface
coating
regulations.
This
final
rule
is
expected
to
be
promulgated
in
late
August
of
2003.
The
MMPP
produces
emissions
of
hazardous
air
pollutants
(
HAP)
through
the
process
of
painting
or
otherwise
coating
metal
surfaces.
The
Innovative
Strategies
and
Economics
Group
(
ISEG)
has
developed
this
economic
impact
analysis
(
EIA)
to
support
the
evaluation
of
impacts
associated
with
regulatory
options
considered
for
this
NESHAP.
This
EIA
is
part
of
compliance
with
Section
317
of
the
CAA.

1.1
Scope
and
Purpose
This
report
evaluates
the
economic
impacts
of
pollution
control
requirements
on
coating
operations
at
facilities
included
in
the
MMPP
source
category.
These
requirements
are
designed
to
reduce
emissions
of
HAP
into
the
atmosphere.
The
CAA's
purpose
is
to
protect
and
enhance
the
quality
of
the
nation's
air
resources
(
Section
101(
b)).
Section
112
of
the
Clean
Air
Act
Amendments
of
1990
establishes
the
authority
to
set
national
emission
standards
for
hazardous
air
pollutants.
The
emissions
of
HAP
from
this
source
category
originates
from
the
coating
and
painting
of
the
miscellaneous
metal
parts
and
products.

To
reduce
emissions
of
HAP,
the
EPA
establishes
NESHAP
based
on
maximum
achievable
control
technology
(
MACT).
For
existing
sources,
the
MACT
floor
is
the
average
emissions
limitation
achieved
by
the
best
performing
12
percent
of
sources
(
if
there
are
30
or
more
sources
in
the
category
or
subcategory).
The
MACT
can
be
more
stringent
than
the
floor,
considering
costs,
non­
air
quality
health
and
environmental
impacts,
and
energy
requirements.
The
estimated
costs
for
individual
plants
to
comply
with
the
MACT
standards
are
inputs
into
the
economic
impact
analysis
presented
in
this
report.
Page
5
2
ECONOMIC
IMPACTS
The
MACT
standards
require
facilities
involved
in
the
surface
coating
of
miscellaneous
metal
parts
and
products
to
reduce
the
emissions
of
HAP
from
their
surface
coating
operations
to
meet
the
levels
specified
by
the
NESHAP.
The
costs
of
meeting
the
MACT
standards
will
vary
across
facilities
depending
upon
their
physical
characteristics
and
current
usage
of
coatings
and
solvents.
These
regulatory
costs
will
have
financial
implications
for
the
affected
entities,
and
broader
implications
as
these
effects
are
transmitted
through
market
relationships
to
other
producers
and
consumers.
These
potential
economic
impacts
are
the
subject
of
this
section.

Inputs
to
the
economic
analysis
include:


Identification
of
industry
segments
with
potentially
affected
facilities.


Baseline
characterization
of
facilities
with
miscellaneous
metal
parts
and
products
coating
operations
and
the
companies
that
own
these
potentially
affected
facilities.


Compliance
cost
estimates
for
facilities
(
through
model
plants)
to
meet
the
MACT
floor
standards.

The
EPA
has
estimated
the
national
total
annual
compliance
costs
(
including
monitoring,
recordkeeping,
and
reporting)
for
existing
sources
to
be
$
47.3
million
(
1997
dollars).

2.1
Industry
Segments
The
Miscellaneous
Metal
Parts
and
Products
(
MMPP)
source
category
includes
thousands
of
small,
medium,
and
large
facilities
that
apply
coatings
to
a
metal
substrate
to
produce
a
wide
range
of
parts
and
products.
Coatings
applied
to
the
metal
surfaces
provide
a
protective,
decorative,
or
functional
film
including
protection
from
wear
and
corrosion..
The
coatings
possess
varying
characteristics
which
make
them
suitable
for
different
applications.
In
general,
this
source
category
is
broad
and
includes
all
those
metal
parts
and
products
that
are
not
covered
by
another
coating
source
category,
including
original
equipment
manufacturers
(
OEM)
and
refurbishment
shops.

Households,
businesses,
and
institutions
purchase
and
use
these
miscellaneous
metal
parts
and
products.
The
MMPP
Surface
Coating
source
category
covers
a
wide
variety
of
industry
segments;
no
single
description
could
cover
all
of
these
different
industry
sectors.
For
the
purpose
of
this
analysis,
the
industry
segments
that
have
been
individually
identified
are
listed
below:
Page
6
°
Aerospace
Ground
Support
Equipment
°
Agricultural
and
Construction
Machinery
°
Aluminum
Extrusion
°
Automobile
Parts
°
Contract
Coating
Facilities
°
Heavy­
Duty
Trucks
and
Buses
°
Magnet
Wire
°
Metal
Shipping
Containers
°
Metal
Pipe
and
Foundry
°
Rail
Transportation
°
Recreational
Vehicles
°
Rubber­
to­
Metal
Bonded
Part
Manufacturing
°
Structural
Steel
This
list
should
not
be
considered
as
exhaustive,
and
industries
that
may
be
subject
to
the
rule
developed
for
this
source
category
may
not
be
listed
here.
Each
of
the
industry
segments
listed
above
is
described
in
greater
detail
below:

Aerospace
Ground
Support
Equipment.
More
than
12,000
parts
or
equipment
types
can
be
considered
ground
support
equipment
(
GSE)
in
the
aerospace
industry.
GSE
is
classified
by
the
function
of
the
equipment
and
by
the
items
the
equipment
is
used
to
support.
GSE
is
used
for
auxiliary
purposes,
testing
and
checkout,
handling
of
other
equipment
and
cargo,
mechanical
site
testing,
packaging
and
transport,
servicing,
and
other
miscellaneous
purposes.

Agricultural
and
Construction
Machinery.
The
Agricultural
and
Construction
Machinery
Industry
is
covered
by
the
1997
North
American
Industry
Classification
System
(
NAICS)
code
series
3331
(
Agricultural,
Construction,
and
Mining
Machinery
Manufacturing)
and
series
33392
(
Material
Handling
Equipment
Manufacturing).
The
Agricultural
and
Construction
Machinery
Industry
excludes
corrals,
stalls,
and
holding
gates
which
are
covered
by
NAICS
code
332323
(
Ornamental
and
Architectural
Metal
Work
Manufacturing)
and
are
categorized
within
the
Structural
Metal
Industry.
Railway
truck
maintenance
equipment,
which
is
covered
by
NAICS
code
33651
(
Railroad
Rolling
Stock
Manufacturing)
and
are
categorized
in
the
Rail
Transportation
Industry.
Hand­
held
clippers
for
shearing
or
grooming
animals,
covered
by
SIC
3523,
are
also
excluded
from
the
Agricultural
and
Construction
Machinery
Industry.
A
list
of
the
NAICS
codes
that
describe
this
industry
and
corresponding
SIC
codes
is
provided
below.

333111
Farm
Machinery
and
Equipment
Manufacturing
[
includes
SIC
3523
(
Farm
Machinery
and
Equipment),
except
corrals,
stalls,
and
holding
gates;
farm
conveyors
and
farm
elevators,
stackers
and
bale
throwers;
and
hand
hair
clippers
for
animal
use.]
333112
Lawn
and
Garden
Tractor
and
Home
Lawn
and
Garden
Equipment
Manufacturing
[
includes
SIC
3524
(
Lawn
and
Garden
Tractors
and
Home
Lawn
and
Garden
Equipment),
except
nonpowered
lawnmowers]
Page
7
33312
Construction
Machinery
Manufacturing
[
includes
SIC
3531
(
Construction
Machinery
and
Equipment),
except
railway
truck
maintenance
equipment;
and
winches,
aerial
work
platforms
and
automotive
wrecker
hoists.]
333131
Mining
Machinery
and
Equipment
Manufacturing
[
includes
SIC
3532
(
Mining
Machinery
and
Equipment,
Except
Oil
and
Gas
Field
Machinery
and
Equipment)]
333132
Oil
and
Gas
Field
Machinery
and
Equipment
Manufacturing
[
includes
SIC
3533
(
Oil
and
Gas
Field
Machinery
Equipment)]
333921
Elevator
and
Moving
Stairway
Manufacturing
[
includes
SIC
3534
(
Elevator
and
Moving
Stairways)]
333922
Conveyor
and
Conveying
Equipment
Manufacturing
[
includes
SIC
3535
(
Conveyors
and
Conveying
Equipment);
and
farm
conveyors
and
farm
elevators,
stackers
and
bale
throwers
from
SIC
3523
(
Farm
Machinery
and
Equipment)]
333923
Overhead
Traveling
Crane,
Hoist,
and
Monorail
System
Manufacturing
[
includes
SIC
3536
(
Overhead
Traveling
Cranes,
Hoists,
and
Monorail
Systems);
and
winches,
aerial
work
platforms,
and
automotive
wrecker
hoists
from
SIC
3531
(
Construction
Machinery
and
Equipment)]
333924
Industrial
Truck,
Tractor,
Trailer,
and
Stacker
Machinery
Manufacturing
[
includes
SIC
3537
(
Industrial
Trucks,
Tractors,
Trailers,
and
Stackers),
except
metal
pallets,
and
metal
air
cargo
containers]

Aluminum
Extrusion.
The
Aluminum
Extrusion
Industry
is
covered
by
the
NAICS
code
331316
(
Aluminum
Extruded
Product
Manufacturing).
The
Aluminum
Extrusion
Industry
is
grouped
with
establishments
primarily
engaged
in
extruding
aluminum
and
aluminum­
based
alloy
basic
shapes,
such
as
rod
and
bar,
pipe
and
tube,
and
tube
blooms,
including
establishments
producing
tube
by
drawing.
Aluminum
extrusion
manufacturers
produce
a
wide
array
of
products
for
several
market
sectors.
The
major
market
categories
serviced
by
aluminum
extruders
and
included
in
the
MMPP
source
category
are
building
and
construction,
transportation,
and
consumer
durables.
The
building
and
construction
market
category
consists
of
doors,
windows
and
shutters,
mobile
homes,
curtain
walls,
bridge
rails
and
decks,
street
and
highway
construction,
architectural
shapes,
patio
and
pool
enclosures,
light
and
flag
poles,
louvers
and
vents,
and
conduits.
Included
in
the
transportation
category
are
aircrafts,
trailers
and
semitrailers,
passenger
cars,
trucks
and
buses,
travel
trailers,
and
recreational
vehicles.
The
consumer
durables
market
covers
products
such
as
refrigerators
and
freezers,
major
appliances,
furniture,
boats,
outboard
motors,
sports
and
athletic
equipment,
and
toys.
Other
major
market
categories
serviced
by
the
aluminum
extrusion
industry
include
electrical
goods,
machinery
and
equipment,
distributors
and
jobbers,
and
exports.
Most
aluminum
extruders
produce
products
for
multiple
market
sectors.

Automobile
Parts.
The
Automobile
Parts
Industry
is
covered
by
the
NAICS
codes
336211
(
Motor
Vehicle
Body
Manufacturing)
and
the
NAICS
code
series
3363
(
Motor
Vehicle
Parts
Page
8
Manufacturing).
The
Automobile
Parts
Industry
includes
establishments
primarily
engaged
in
manufacturing
motor
vehicle
parts
and
accessories,
but
not
engaged
in
manufacturing
complete
motor
vehicles
or
passenger
car
bodies.
NAICS
code
336211
includes
dump
truck
lifting
mechanisms
and
fifth
wheels.
A
list
of
the
NAICS
codes
in
series
3363
and
corresponding
SIC
codes
(
except
SIC
3714)
that
are
relevant
to
the
MMPP
source
category
is
provided
below.

336311
Carburetor,
Piston,
Piston
Rings,
and
Valve
Manufacturing
[
includes
SIC
3592
(
Carburetor,
Pistons,
Piston
Rings,
and
Valve
Manuf.)]
336312
Gasoline
Engine
and
Engine
Parts
Manufacturing
336321
Vehicular
Lighting
Equipment
[
includes
SIC
3647
(
Vehicular
Lighting
Equipment)
336322
Other
Motor
Vehicle
Electrical
and
Electronic
Equipment
Manufacturing
[
includes
SIC
3694
(
Electrical
Equipment
for
Internal
Combustion
Engines)]
33633
Motor
Vehicle
Steering
and
Suspension
Components
(
except
Spring)
Manufacturing
33634
Motor
Vehicle
Brake
System
Manufacturing
33635
Motor
Vehicle
Transmission
and
Power
Train
Parts
Manufacturing
33636
Motor
Vehicle
Seating
and
Interior
Trim
Manufacturing
[
incl.
metal
motor
vehicle
seat
frames
SIC
3499
(
Fabricated
Metal
Products,
nec)]
33637
Motor
Vehicle
Stamping,
Metal
[
includes
SIC
3465
(
Automotive
Stampings)]
336391
Motor
Vehicle
Air­
Conditioning
Manufacturing
[
includes
motor
vehicle
air­
conditioning
from
SIC
3585
(
Air­
Conditioning
and
Warm
Air
Heating
Equipment
and
Commercial
and
Industrial
Refrigeration
Equipment)]
336399
All
Other
Motor
Vehicle
Parts
Manufacturing
[
includes
luggage
and
utility
racks
from
SIC
3429
(
Hardware,
Not
Elsewhere
Classified);
stationary
engine
radiators
from
SIC
3519
(
Internal
Combustion
Engines,
Not
Elsewhere
Classified);
gasoline,
oil,
and
intake
filters
for
internal
combustion
engines
from
SIC
3599
(
Industrial
and
Commercial
Machinery
and
Equipment,
Not
Elsewhere
Classified);
and
trailer
hitches
from
SIC
3799
(
Transportation
Equipment,
Not
Elsewhere
Classified)]

Contract
Coating
Facilities.
Contract
coating
facilities,
or
"
job
shops",
may
be
described
as
facilities
that
perform
surface
coating
operations
for
a
variety
of
industries
on
a
contract
basis.
These
facilities
may
specialize
in
coating
products
for
one
specific
industry;
or
may
coat
several
products
for
several
different
industries.
Job
shops
may
be
covered
by
several
NAICS
codes
including
NAICS
code
332812
(
Metal
Coating,
Engraving
(
except
Jewelry
and
Silverware)
and
Allied
Services
to
Manufacturers).
Included
are
establishments
primarily
engaged
in
performing
enameling,
lacquering,
and
varnishing
services
of
metal
products
for
the
trade.
Also
included
in
this
industry
are
establishments
which
perform
these
types
of
activities
on
their
own
account
on
purchased
metals
or
formed
products.
Page
9
Heavy­
Duty
Trucks
and
Buses.
The
Heavy­
Duty
Trucks
and
Buses
Industry
is
covered
by
the
NAICS
code
331316
(
Motor
Vehicle
Body
Manufacturing).
The
Heavy­
Duty
Truck
and
Buses
Industry
is
grouped
with
establishments
primarily
engaged
in
manufacturing
large
truck
and
bus
bodies
and
cabs
for
sale
separately
or
for
assembly
on
purchased
chassis,
or
in
assembling
large
truck
and
bus
bodies
on
purchased
chassis.
Also
included
in
this
industry
sector
are
truck
trailers
which
are
covered
by
the
NAICS
code
336212
(
Truck
Trailer
Manufacturing).
The
truck
trailer
industry
is
grouped
with
establishments
primarily
engaged
in
manufacturing
truck
trailers,
truck
trailer
chassis
for
sale
separately,
detachable
trailer
bodies
(
cargo
containers)
for
sale
separately,
and
detachable
trailer
(
cargo
container)
chassis,
for
sale
separately.

Magnet
Wire.
The
Magnet
Wire
Industry
is
covered
by
the
NAICS
codes
331319
(
Other
Aluminum
Rolling
and
Drawing),
331421
(
Copper
Rolling,
Drawing,
and
Extruding);
331422
(
Copper
Wire
[
except
mechanical]
Drawing),
33149
(
Nonferrous
Metals
[
except
copper
and
aluminum]
Rolling,
Drawing,
and
Extruding),
and
335929
(
Other
Communication
and
Energy
Wire
Manufacturing).
The
Magnet
Wire
Industry
is
grouped
with
establishments
primarily
engaged
in
drawing,
drawing
and
insulating,
and
insulating
wire
and
cable
of
nonferrous
metals
from
purchased
wire
bars,
rods,
or
wire
and
includes
establishments
primarily
engaged
in
manufacturing
insulated
fiber
optic
cable.
Magnet
wire
is
produced
predominantly
in
large
facilities
which
both
draw
and
insulate
the
wire
and
sell
it
for
use
in
electrical
and
electronic
products.

Metal
Shipping
Containers.
Metal
shipping
containers
are
classified
by
the
NAICS
code
332439
(
Other
Metal
Container
Manufacturing).
The
Metal
Shipping
Containers
Industry
consists
of
establishments
primarily
engaged
in
manufacturing
metal
shipping
barrels,
drums,
kegs,
and
pails,
and
includes
the
following
products:

°
Containers,
shipping:
barrels,
kegs,
drums,
packages
­
liquid
tight
(
metal)
°
Drums,
shipping:
metal
°
Milk
(
fluid)
shipping
containers,
metal
°
Pails,
shipping:
metal
­
except
tinned
This
industry
also
includes
the
reconditioning
of
shipping
containers
which
is
classified
by
the
NAICS
code
81131
(
Commercial
and
Industry
Machinery
and
Equipment
{
except
Automotive
and
Electronic}
Repair
and
Maintenance).

Pipe
and
Foundry.
The
Pipe
and
Foundry
Industry
is
covered
by
the
NAICS
code
33121
(
Iron
and
Steel
Pipe
and
Tube
Manufacturing
from
Purchased
Steel),
and
the
NAICS
code
series
3315
(
Foundries).
This
industry
segment
includes
establishments
primarily
engaged
in
the
production
of
welded
or
seamless
steel
pipe
and
tubes
and
heavy
riveted
steel
pipe
from
purchased
materials.
Also
included
are
establishments
primarily
engaged
in
manufacturing
iron
and
steel
castings
and
those
establishments
primarily
engaged
in
manufacturing
castings
and
die­
castings
of
aluminum,
brass,
bronze,
and
other
nonferrous
metals
and
alloys.
A
list
of
the
NAICS
codes
used
to
describe
this
industry
and
corresponding
SIC
codes
is
provided
below.
Page
10
33121
Iron
and
Steel
Pipe
and
Tube
Manufacturing
from
Purchased
Steel
[
includes
SIC
3317
(
Steel
Pipe
and
Tubes)]
331511
Iron
Foundries
[
includes
SIC
3321
(
Gray
and
Ductile
Iron
Foundries)
and
3322
(
Malleable
Iron
Foundries)]
331512
Steel
Investment
Foundries
[
includes
SIC
3324
(
Steel
Investment
Foundries)]
331513
Steel
Foundries
(
except
Investment)
[
includes
SIC
3325
(
Steel
Foundries,
Not
Elsewhere
Classified)]
331521
Aluminum
Die­
Casting
Foundries
[
includes
SIC
3363
(
Aluminum
Die­
Castings)]
331522
Nonferrous
(
except
Aluminum)
Die­
Casting
Foundries
[
includes
SIC
3364
(
Nonferrous
Dies­
Castings,
except
Aluminum)]
331524
Aluminum
Foundries
(
except
Die­
Casting)
[
includes
SIC
3365
(
Aluminum
Foundries)]
331525
Copper
Foundries
(
except
Die­
Casting)
[
includes
SIC
3366
(
Copper
Foundries)]
331528
Other
Nonferrous
Foundries
(
except
Die­
Casting)
[
includes
SIC
3369
(
Nonferrous
Foundries,
Except
Aluminum
and
Copper)]

Rail
Transportation.
The
Rail
Transportation
Industry
is
covered
by
the
NAICS
code
33651
(
Railroad
Rolling
Stock
Manufacturing).
The
Rail
Transportation
Industry
includes
establishments
primarily
engaged
in
building
and
rebuilding
locomotives
(
including
frames
and
parts,
not
elsewhere
classified)
of
any
type
or
gauge;
and
railroad,
street,
and
rapid
transit
cars
and
car
equipment
for
operation
on
rails
for
freight
and
passenger
service.
Locomotive
fuel
lubricating
pumps
and
cooling
medium
pumps
are
covered
by
NAICS
code
333911
(
Pump
and
Pumping
Equipment
Manufacturing).
In
accordance
with
NAICS
code
33651,
this
industry
sector
also
includes
railway
truck
maintenance
equipment,
which
is
also
covered
by
SIC
code
3531
(
Construction
Machinery
and
Equipment).

Recreational
Vehicles.
The
Recreational
Vehicle
Industry
is
covered
by
the
NAICS
codes
336213
(
Motor
Home
Manufacturing)
and
336214
(
Travel
Trailer
and
Camper
Manufacturing).
The
industry
includes
establishments
primarily
engaged
in
manufacturing
self­
contained
motor
homes
on
purchased
chassis.
NAICS
336213
includes
establishments
primarily
engaged
in
manufacturing
travel
trailers
and
campers
for
attachment
to
passenger
cars
or
other
vehicles,
pickup
coaches
(
campers)
and
caps
(
covers)
for
mounting
on
pickup
trucks.
NAICS
code
336214
also
includes
automobile,
boat,
utility,
and
light
truck
trailers,
which
are
also
covered
by
SIC
code
3799
(
Transportation
Equipment,
Not
Elsewhere
Classified).

Rubber­
to­
Metal
Bonded
Part
Manufacturing.
The
Rubber­
to­
Metal
Bonded
Parts
Manufacturing
Industry
is
covered
by
the
NAICS
codes
326291
(
Rubber
Product
Manufacturing
for
Mechanical
Use)
and
326299
(
All
Other
Rubber
Products
Manufacturing).
This
industry
includes
establishments
primarily
engaged
in
manufacturing
molded,
extruded,
and
lathe­
cut
Page
11
mechanical
rubber
goods,
generally
for
machinery
and
equipment.
It
also
consists
of
establishments
primarily
engaged
in
manufacturing
industrial
rubber
goods,
rubberized
fabrics,
and
vulcanized
rubber
clothing,
and
miscellaneous
rubber
specialties
and
sundries,
not
elsewhere
classified.
Many
of
the
products
manufactured
in
this
industry
are
fabricated
for
use
in
the
automotive
industry.

Structural
Steel.
The
Structural
Steel
Industry
is
covered
by
the
NAICS
codes
332114
(
Custom
Roll
Forming),
332311
(
Prefabricated
Metal
Building
and
Component
Manufacturing),
332312
(
Fabricated
Structural
Metal
Manufacturing),
332321
(
Metal
Window
and
Door
Manufacturing),
and
332323
(
Ornamental
and
Architectural
Metal
Work
Manufacturing).
This
industry
includes
establishments
primarily
engaged
in
fabricating
iron
and
steel
or
other
metal
for
structural
purposes,
such
as
bridges,
buildings,
and
sections
for
ships,
boats,
and
barges
as
well
as
establishments
primarily
engaged
in
manufacturing
ferrous
and
nonferrous
metal
doors,
sash,
window
and
door
frames
and
screens,
molding,
and
trim.
It
also
includes
establishments
primarily
engaged
in
manufacturing
architectural
and
ornamental
metal
work,
such
as
stairs
and
staircases,
open
steel
flooring
(
grating),
fire
escapes,
grilles,
railings,
and
fences
and
gates,
except
those
made
from
wire;
establishments
primarily
engaged
in
manufacturing
portable
and
other
prefabricated
metal
buildings
and
parts
and
prefabricated
exterior
metal
panels;
establishments
primarily
engaged
in
manufacturing
miscellaneous
structural
metal
work,
such
as
metal
plaster
bases,
fabricated
bar
joists,
and
concrete
reinforcing
bars;
and
establishments
primarily
engaged
in
custom
roll
forming
of
metal.
In
accordance
with
NAICS
code
332323,
the
structural
metal
industry
also
consists
of
metal
corrals,
stalls,
and
holding
gates,
which
are
covered
by
SIC
code
3523
(
Farm
Machinery
and
Equipment).

2.2
Manufacturing
Facilities
Based
on
responses
to
the
Section
114
letters,
the
EPA
identified
321
facilities
within
this
source
category
expected
to
be
major
sources
subject
to
the
MACT
standard
and
its
associated
costs.
Of
this
sample,
a
total
of
294
facilities
reported
employment
data
with
an
average
(
median)
of
824
(
400)
employees
and
a
range
from
2
to
13,287
employees.
For
the
purpose
of
this
analysis,
these
facilities
represent
the
universe
of
potentially
affected
sources
with
the
economic
impacts
estimated
based
on
the
regulatory
costs
applied
to
each
using
the
"
model
plant"
costing
approach
described
in
the
Background
Information
Document
(
BID).

2.3
Companies
The
EPA
identified
221
ultimate
parent
companies
within
this
industry
survey
sample
and
obtained
their
sales
and
employment
data
from
either
their
survey
response
or
one
of
the
following
secondary
sources:

1.
Ward's
Business
Directory
2.
Hoover's
Company
Profiles
3.
Company
Websites.
Page
12
Appendix
A
provides
a
listing
of
these
221
companies
identified
from
the
industry
survey
that
owned
and
operated
the
321
facilities
within
this
source
category.

Annual
sales
and
employment
data
were
available
for
147
of
the
companies
(
67
percent)
and
net
income
data
were
available
for
76
of
the
companies
(
34
percent).
The
average
(
median)
annual
sales
of
companies
reporting
data
were
$
7.2
billion
($
567
million)
with
a
range
of
$
5
million
to
$
161
billion.
These
figures
include
revenues
from
all
operations.
The
average
(
median)
employment
for
these
companies
was
26,956
employees
(
2,725
employees)
with
a
range
of
100
to
594,000.
In
addition,
the
average
(
median)
annual
net
income
of
companies
reporting
data
were
$
775
million
($
64
million)
with
a
range
from
­$
898
million
to
$
22.1
billion.
The
available
data
indicate
8
of
the
76
companies
reported
negative
net
income,
or
profit
losses,
for
1997.
These
observed
negative
profit
levels
in
the
baseline
are
determined
by
factors
outside
the
scope
of
this
analysis.
For
example,
Sunbeam
Corporation
has
continued
to
experience
negative
net
income
and
is
reorganizing
under
Chapter
11
bankruptcy
protection.
In
other
situations,
such
as
that
for
Union
Pacific
Corporation
and
Rockwell
International,
the
company
is
no
longer
experiencing
such
losses.

Companies
owning
facilities
within
the
MMPP
source
category
can
be
grouped
into
small
and
large
categories
using
Small
Business
Administration
(
SBA)
general
size
standard
definitions
by
NAICS
codes.
For
most
NAICS
codes,
the
size
standard
is
based
on
the
number
of
employees
but
in
some
cases,
the
size
standard
is
based
on
the
annual
sales
of
the
company.
There
are
a
multitude
of
different
NAICS
codes
across
the
ultimate
parent
companies
owning
these
facilities.
For
these
NAICS
codes,
the
small
business
definition
ranges
are
500
to
1,500
employees
and
$
5
million
in
annual
sales.
Using
these
guidelines
and
available
data,
the
EPA
identified
29
small
parent
businesses,
or
20
percent
of
all
companies
reporting
sales
and
employment
within
this
source
category.

For
1997,
the
annual
average
(
median)
sales
for
the
small
companies
was
$
107
million
($
31
million)
with
a
range
of
$
8
to
$
950
million
and
the
average
(
median)
employment
was
317
employees
(
300
employees)
with
a
range
of
100
to
780
employees
.
Net
income
data
was
not
available
for
the
29
identified
small
businesses.
For
large
companies,
the
annual
average
(
median)
sales
was
$
8.7
billion
($
871
million)
with
a
range
of
$
50
million
to
$
161
billion
and
the
average
(
median)
employment
was
32,393
employees
(
3,978
employees)
with
a
range
of
500
to
594,000.
The
annual
average
(
median)
net
income
for
the
large
companies
was
$
492
million
($
11
million).

2.4
Economic
Impact
Results
In
conducting
an
economic
impact
analysis,
the
EPA
typically
models
the
responses
by
producers
and
markets
to
the
imposition
of
the
proposed
regulation.
The
alternatives
available
to
producers
in
response
to
the
regulation
and
the
context
of
these
choices
are
important
in
determining
the
economic
and
financial
impacts.
Economic
theory
predicts
that
producers
will
take
actions
to
minimize
their
share
of
the
regulatory
costs.
Producers
decide
whether
to
Page
13
continue
production
and,
if
so,
determine
the
optimal
level
consistent
with
market
signals.
These
choices
and
market
feedback
allow
them
to
pass
costs
forward
to
the
consumers
of
their
endproducts
or
services
and/
or
to
pass
costs
backward
to
the
suppliers
of
production
inputs.
However,
given
the
wide
diversity
of
products
that
will
be
affected
by
the
regulation,
the
EPA
focuses
the
economic
impact
analysis
on
the
initial
distribution
of
costs
across
existing
facilities
and
companies
owning
these
existing
facilities.
The
small
business
impact
of
the
regulation
is
analyzed
in
Section
3.

2.4.1
Facility­
Level
Compliance
Cost
Burden
Based
on
the
"
model
plant"
costing
analysis
described
in
the
BID,
Table
2­
1
summarizes
the
compliance
cost
burden
across
the
321
facilities
in
the
EPA
database.
These
facilities
account
for
roughly
20
percent
of
the
total
annual
compliance
costs
of
the
regulation
(
i.
e.,
$
9.3
million
of
$$
47.3
million
for
all
sources).
As
shown
in
Table
2­
1,
the
annual
average
(
median)
cost
per
facility
is
$
32,758
($
28,582)
with
a
range
from
$
25,947
to
$
140,487
per
year.
The
estimates
here
indicate
that
the
distribution
of
costs
across
facilities
is
skewed
toward
the
lower
impact
levels,
i.
e.,
the
median
value
is
lower
than
the
average
value.

Table
2­
1.
Summary
of
Compliance
Cost
Burden
on
Facilities
in
the
Miscellaneous
Metal
Parts
and
Products
Source
Category:
1997
Item
All
Facilities
Total
Facilities
(#)
321
Total
Costs
($/
yr)
$
9,303,212
Per
Facility
($/
yr)

Average
Median
Minimum
Maximum
$
32,758
$
28,582
$
25,947
$
140,487
2.4.2
Company­
Level
Compliance
Cost
Burden
Based
on
the
industry
survey
responses,
the
EPA
was
able
to
identify
221
companies
that
owned
321
potentially
affected
facilites
within
this
source
category.
Of
this
total,
we
were
able
to
obtain
sales
data
for
147
companies
and
net
income
data
for
76
companies.
For
those
companies
with
sales
data,
the
economic
impact
analysis
indicates
that
these
regulatory
costs
average
less
than
0.1
percent
of
company
sales
with
a
range
from
zero
to
1.25
percent.
For
those
companies
with
positive
net
income
data,
these
regulatory
costs
average
0.2
percent
of
company
net
income
with
a
range
from
zero
to
3.6
percent.
For
those
companies
reporting
negative
net
income
for
1997,
these
regulatory
costs
average
0.001
percent
of
company
sales
with
a
range
from
zero
to
Page
14
0.004
percent
of
company
sales.
Thus,
these
costs
would
not
exacerbate
the
baseline
financial
condition
of
any
these
companies.

2.4.3
Summary
This
analysis
indicates
that
the
compliance
cost
of
this
standard
should
not
cause
producers
to
cease
or
significantly
alter
their
current
operations.
Hence,
no
firms
or
facilities
are
expected
to
be
at
risk
of
closures
because
of
the
standard.

3
SMALL
BUSINESS
IMPACTS
This
regulatory
action
will
potentially
affect
the
economic
welfare
of
owners
of
miscellaneous
metal
parts
coating
facilities.
The
ownership
of
these
facilities
ultimately
falls
on
private
individuals
who
may
be
owner/
operators
that
directly
conduct
the
business
of
the
firm
(
i.
e.,
"
mom
and
pop
shops"
or
partnerships)
or,
more
commonly,
investors
or
stockholders
that
employ
others
to
conduct
the
business
of
the
firm
on
their
behalf
(
i.
e.,
privately­
held
or
publiclytraded
corporations).
The
individuals
or
agents
that
manage
these
facilities
have
the
capacity
to
conduct
business
transactions
and
make
business
decisions
that
affect
the
facility.
The
legal
and
financial
responsibility
for
compliance
with
a
regulatory
action
ultimately
rests
with
these
agents;
however,
the
owners
must
bear
the
financial
consequences
of
the
decisions.
While
environmental
regulations
can
affect
all
businesses,
small
businesses
may
have
special
problems
in
complying
with
such
regulations.

The
Regulatory
Flexibility
Act
(
RFA)
of
1980
requires
that
special
consideration
be
given
to
small
entities
affected
by
federal
regulation.
The
RFA
was
amended
in
1996
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
to
strengthen
the
RFA's
analytical
and
procedural
requirements.
This
section
examines
the
MMPP
source
category
and
provides
a
screening
analysis
to
determine
whether
this
rule
is
likely
to
impose
a
significant
impact
on
a
substantial
number
of
the
small
entities
(
SISNOSE)
within
this
industry.
The
screening
analysis
employed
here
is
a
"
sales
test,"
which
computes
the
annualized
compliance
costs
as
a
share
of
sales
for
each
company.

The
Small
Business
Administration
(
SBA)
defines
a
small
business
in
terms
of
the
sales
or
employment
of
the
owning
entity.
These
thresholds
vary
by
industry
and
are
evaluated
based
on
the
industry
classification
(
NAICS
Code)
of
the
affected
facility.
Responses
to
the
industry
survey
indicated
multiple
industry
classification
codes
with
a
small
business
definition
ranging
from
500
to
1,500
employees
or
less
than
$
5
million
in
annual
sales.
The
EPA
determined
a
company's
size
standard
based
on
the
reported
NAICS
codes
for
these
facilities.
In
cases
where
companies
own
facilities
with
multiple
NAICS's,
the
primary
NAICS
code
and
associated
SBA
definition
was
used.
Based
on
EPA's
database,
29
companies
were
identified
as
small
(
20
percent
of
companies
reporting
sales
and
employment
data)
and
the
remaining
118
being
large
(
80
percent).
The
identification
of
companies
as
small
or
large
is
included
in
the
company
data
listed
Page
15
in
Appendix
A.

Table
3­
1
reports
total
annual
compliance
costs
and
summary
statistics
for
the
cost­
to­
sales
ratios
for
small
and
large
companies.
Table
3­
1
shows
that
the
aggregate
compliance
costs
incurred
by
small
businesses
represents
14
percent,
or
$
856,000,
of
the
industry
sample's
total
of
$
5.95
million
for
those
reporting
sales
and
employment
data.
The
annual
compliance
costs
for
small
businesses
range
from
zero
to
1.17
percent
of
their
sales.
The
mean
(
median)
compliance
cost­
to­
sales
ratio
is
0.17
(
0.01)
percent
for
the
identified
small
businesses
and
0.01
(
0.01)
percent
for
the
large
businesses.
These
results
are
expected
to
be
"
representative"
of
the
distributional
impacts
across
companies
by
size.
After
reviewing
the
range
of
costs
(
as
compared
to
their
sales)
expected
to
be
borne
by
small
businesses,
the
EPA
has
determined
the
costs
are
typically
small
and,
thus,
certifies
that
this
action
will
not
have
a
significant
impact
on
a
substantial
number
of
small
entities.

Table
3­
1.
SBREFA
Screening
Analysis
on
Miscellaneous
Metal
Part
and
Products
Sample
by
Company
Size:
1997
Small
Large
All
Companies
Total
Number
of
Companies
29
118
147
Total
Annual
Compliance
Costs
($
103/
yr)
$
856
$
5,095
$
5,951
Average
TAC
per
company
($
103/
yr)
$
29.5
$
43.2
$
40.5
Cost­
to­
Sales
Ratios
Average
0.17%
0.01%
0.04%

Median
0.01%
<
0.01%
<
0.01%

Minimum
0.00%
0.00%
0.00%

Maximum
1.17%
0.14%
1.17%
Page
16
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
AB
Volvo
$
26,276
79,820
$
1,066
No
AO
Smith
Corporation
$
918
9,700
$
45
No
United
Industrial
Corp.
$
221
1,900
No
ABB
Ltd.
$
30,872
199,232
$
1,305
No
Accessory
Controls
and
Equipment
Corp.
ACF
Industries,
Inc.
$
580
2,100
No
Advanced
Technical
Products,
Inc.
$
165
1,568
$
6
No
Airxcel,
Inc.
Alcoa
Inc.
$
15,340
103,500
$
853
No
Alliant
Techsystems,
Inc.
$
1,090
6,110
$
51
No
Allied
Hastings
Barrel
&
Drum
Service
Allied
Signal,
Inc.
$
15,128
70,400
$
1,331
No
Allied
Tube
and
Conduit
Corporation
$
170
1,200
No
Aluminum
Shapes
L.
L.
C.
$
100
900
No
Amana
Refrigeration
Inc
$
590
550
Yes
American
Buildings
Company
$
441
2,850
$
15
No
American
Meter
Company
$
100
800
No
American
Railcar
Industries
American
Safety
Razor,
Inc.
$
298
2,257
$
10
No
AMPCOR
II,
Inc.
AMSTED
Industries,
Inc.
$
1,252
9,100
No
AMTROL,
Inc.
$
202
1,875
­$
13
No
Anderson
Greenwood
and
Co.
Arkansas
Steel
Associates
Arvin
Industries,
Inc.
$
2,499
14,963
$
78
No
ASMO
Co.
Ltd.
AWH
Corporation
Behlen
Mktg.
Inc.
$
100
900
No
Berenfield
Containers,
Inc.
$
21
200
Yes
Blue
Bird
Corporation
$
626
2,877
$
22
No
Bodor
Corporation
(
dba
Explorer
Van
Company)
Briggs
&
Stratton
Corporation
$
1,502
7,615
$
106
No
Broan
Manufacturing
Company,
Inc.
$
280
1,000
No
Brock
Enterprises,
Inc.
$
130
1,600
No
Brunner
Engineering
&
Mfg.
$
12
200
Yes
Burlk
Woods,
Alabama
Tank,
Inc.
Burnham
Corporation
$
144
Yes
Caldwell
Tanks,
Inc.
California
Steel
Industries
Canam
Steel
Corporation
Carolina
Steel
Steel
Corp
$
150
800
No
Carriage,
Inc.
Case
Corporation
$
6,149
17,700
$
64
No
Page
17
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
(
Continued)

Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
Caterpillar,
Inc.
$
20,977
65,824
$
1,513
No
CCX
Industries,
Inc.
Central
Can
Company
CF&
I
Steel,
L.
P.
Chicago
Blower
Corporation
Chief
Industries,
Inc.
$
83
1,200
No
CHS
Acquisition
Corp.
$
53
300
Yes
Cives
Corporation
$
130
900
No
Coffeyville
Re­
Con,
Inc.
Columbian
Steel
Tank
Company
$
10
100
Yes
Commercial
Metals
Company
$
2,368
7,350
$
43
No
Container
Recyclers
Inc.
Cooper
Industries,
Inc.
$
3,651
28,100
$
423
No
Cooper
Tire
and
Rubber
Company
$
1,876
10,766
$
127
No
Copperweld
Corporation
$
436
2,500
No
CP
Louisiana,
Inc.
Crane
Company
$
2,269
12,500
$
138
No
Crown
Cork
&
Seal
Co.
Inc.
$
8,300
38,459
$
105
No
CSX
Corporation
$
9,898
46,147
$
537
No
Cummins
Engine
Company,
Inc.
$
6,266
28,300
­$
21
No
DaimlerChrysler
$
154,615
441,500
$
5,656
No
Deere
&
Company
$
13,626
37,000
$
1,021
No
Delong's,
Inc.
$
15
100
Yes
Delphi
Automotive
Systems
$
28,479
197,560
­$
93
No
DENSO
International
America
Duchossois
Industries,
Inc.
EBSCO
Industries
$
1,000
4,000
No
Emerson
Electric
Co.
$
13,447
111,800
$
1,229
No
Equimeter,
Inc.
Escalade,
Inc.
$
91
725
$
6
No
ESCO
Corporation
Essex
Group,
Inc.
$
1,204
4,100
No
Esterline
Technologies
$
353
3,100
No
Eugene
Welding
Company
$
5
Evans
Industries,
Inc.
$
67
500
Yes
Farr
Company
$
122
1,285
$
7
No
FKI
Industries,
Inc.
Ford
Motor
Company
$
144,416
345,175
$
22,071
No
Franklin
Electric
Company,
Inc.
$
273
2,321
$
24
No
Galveston­
Houston
Company
710
No
Page
18
Hargrove
Manufacturing
Gehl
Company
$
262
1,127
$
15
No
GATX
Corporation
$
1,763
6,000
$
132
No
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
(
Continued)

Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
General
Electric
Company
$
99,820
293,000
$
9,296
No
General
Motors
Corporation
$
161,315
594,000
$
2,956
No
Geneva
Steel
$
721
1,625
­$
19
No
Glaval
Corporation
$
300
600
No
Gooder­
Henrichsen
Company,
Inc.
$
14
100
Yes
Gower
Corporation
$
18
Yes
Great
Dane
Limited
Partnership
$
1,000
4,700
No
Greenbrier
Companies
$
540
2,865
$
20
No
Harley­
Davidson,
Inc.
$
2,064
6,200
$
214
No
Hart
and
Cooley,
Inc.
$
130
1,700
No
Hay
and
Forage
Industries
$
110
900
No
Hexcel
Corporation
$
1,089
6,875
$
50
No
High
Industries,
Inc.
Honda
Motor
Co.,
Ltd.
$
52,372
112,200
$
2,564
No
Hoover
Group
$
125
500
Yes
ICO
Worldwide,
Inc.
$
281
1,605
$
6
No
Indiana
Heat
Transfer
$
8
100
Yes
Reading
Body
Works,
Inc.
$
32
300
Yes
ITT
Industries,
Inc.
$
4,493
33,000
$
1,533
No
J
&
L
Structural,
Inc.
J.
T.
Walker
Industries
J.
B.
Jensen
Sr.
Jackson
Products,
Inc.
700
No
Jayco,
Inc.
$
250
1,200
No
Johnstown
America
Industries,
Inc.
$
560
3,300
No
Kawada
Industries
USA
$
68
500
Yes
Ken­
Koat,
Incorporated
Keymark
Corporation
Keystone
Consolidated
Industries,
Inc.
$
370
2,100
$
4
No
Kline
Iron
&
Steel
Company,
Inc.
Konstant
Products,
Inc.
Leed
Himmel
Company
LeTourneau,
Inc.
Loxcreen
Company,
Inc.
$
65
700
No
LTV
Corp.
$
4,273
14,800
­$
27
No
L
&
B
Protective
Coatings
Inc.
Renault
S.
A.
$
43,430
138,320
$
1,561
No
MagneTek,
Inc.
$
663
14,900
$
39
No
Newmar
Corp
$
175
600
Yes
Marion
Steel
Company
$
100
400
Yes
Page
19
Mark
III
Industries
$
950
780
Yes
Century
Tube
Corporation
McCook
Metals
LLC
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
(
Continued)

Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
McDermott
International,
Inc.
$
3,150
20,350
$
153
No
McElroy
Manufacturing,
Inc.
$
14
200
Yes
Metal
Finishing
Company,
Inc.
Modine
Manufacturing
Company
$
1,111
8,700
$
74
No
Monaco
Coach
Corporation
$
595
3,043
$
23
No
Morgan
Chemical
Products,
Inc.
M­
TEK,
Inc.
Mueller
Co.
$
200
2,300
No
Munster
Steel
Company,
Inc.
$
8
100
Yes
New
Columbia
Joist
$
30
200
Yes
National
RV
Holding
$
81
400
Yes
Navistar
International
Transportation
Corp.
$
7,830
17,558
$
299
No
NCI
Building
Systems,
L.
P.
$
675
3,700
$
37
No
Nesco
Container
Corp
$
20
100
Yes
New
Venture
Gear,
Inc.
$
1,033
4,000
No
NIBCO
Inc.
$
500
3,500
No
Nortek
Inc.
$
1,738
9,640
$
35
No
Northrop
Grumman
Corporation
$
8,902
49,600
$
194
No
Northwestern
Steel
and
Wire
Company
$
596
2,000
$
42
No
Nucor
Corporation
$
4,151
7,200
$
264
No
Nylint
Corporation
$
20
200
Yes
Oce'
USA
Incorporated
Olympic
Steel,
Inc.
$
560
1,000
No
Oregon
Steel
Mills,
Inc.
$
893
2,426
$
12
No
Owen
Industries,
Inc.
PACCAR,
Inc.
$
7,895
23,000
$
417
No
Pee
Dee
Tank
Company,
Inc.
Peerless
Products
Inc.
Phelps
Dodge
Corporation
$
3,063
13,924
$
191
No
Pitt­
Des
Moines
Inc.
$
567
2,479
$
20
No
Plasti­
Line,
Inc.
$
103
1,200
No
Premoor,
Inc.
Quoin,
Inc.
R.
C.
Tway
Company,
Inc.
R.
V.
Hopkins
Rawson­
Koeing,
Inc.
$
21
300
Yes
Ready
Metal
Manufacturing
Company
Regal
Ware,
Inc.
$
190
1,800
No
Replogle
Globes,
Inc.
$
16
200
Yes
Rexnord
Corporation
$
533
4,800
No
Page
20
Roanoke
Electric
Steel
Corp.
$
295
1,215
$
19
No
Robert
Bosch
GmbH
$
30,200
188,017
$
510
No
General
Steel
Drum
Corporation
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
(
Continued)

Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
Bigbee
Steel
and
Tank
Rockwell
Collins,
Inc.
Rockwell
International
$
6,752
41,000
­$
427
No
Rogar
Hebert
Schuff
Steel
Company
$
67
500
No
Sequa
Corporation
$
1,802
11,050
$
64
No
Sheffield
Steel
Corporation
$
163
673
$
2
No
Skyline
Corporation
$
665
3,500
$
26
No
Sonoco
Products
Company
$
2,558
16,500
$
180
No
SST
Truck
Co.,
LLC.
Standard
Spray
Subaru­
Isuzu
Automotive,
Inc.
$
420
2,200
No
Sunbeam
Corporation,
Inc.
$
1,837
14,196
­$
898
No
Supreme
Industries
$
223
2,000
$
9
No
Tenneco
Automotive
$
1,800
14,800
No
Texas
Finishing
Company
Ducane
Company
$
47
500
Yes
Vendo
Company
Therma­
Tru
Corporation
Three
Rivers
Aluminum
Company,
Inc
$
50
800
No
Tomkins
Industries,
Inc.
$
1,400
14,000
No
Toro
Company
$
931
3,300
No
Trailmobile
Corporation
$
400
1,700
No
Tredegar
Industries
$
700
3,400
$
69
No
Trinity
Industries
$
2,927
17,450
$
185
No
Truth
Hardware
Corporation
$
77
800
No
Tuscaloosa
Steel
Corporation
$
275
400
Yes
Tyco
International
$
12,311
87,000
$
1,175
No
U.
S.
Industries,
Inc.
USX
Corporation
$
27,877
43,513
$
647
No
Union
City
Body
Company
L.
P.
Union
Pacific
Corporation
$
10,553
65,000
­$
633
No
Union
Tank
Car
Company
$
580
2,600
No
United
Structures
of
America,
Inc.
Van
Leer
Containers,
Inc.
VP
Buildings,
Inc.
W
&
W
Steel
Company
Wabash
National
Corporation
$
1,292
5,302
$
23
No
Waterloo
Industries,
Inc
$
130
1,200
No
Wells
Aluminum
Corporation
Yes
West
Union
Corporation
Page
21
Windsor
Metal
Specialties,
Inc
Winnebago
Industries,
Inc.
$
525
3,010
$
24
No
Appendix
A.
Baseline
Data
for
EPA
Sampled
Companies
Operating
Facilities
With
Miscellaneous
Metal
Parts
and
Products
Coating
Operations:
1997
(
Continued)

Company
Name
Sales
($
106)
Employment
(#)
Net
Income
($
106)
Small
Business
Worthington
Industries,
Inc.
$
1,478
10,000
No
Wyman­
Gordon
Forgings,
Inc.
$
849
3,955
$
37
No
Yale
Security
Inc.
$
200
2,500
No
YKK
Corporation
$
1,711
9,506
$
78
No
Kidde­
Fenwal
$
65
400
Yes
Chemtrom
Fire
Systems
Note:
Baseline
data
provided
in
this
table
reflect
reported
financial
condition
as
of
1997
and
do
not
account
for
any
changes
associated
with
imposition
of
the
MACT
standards.
Page
22
TECHNICAL
REPORT
DATA
(
Please
read
Instructions
on
reverse
before
completing)

1.
REPORT
NO.

EPA­
452/
R­
03­
018
2.
3.
RECIPIENT'S
ACCESSION
NO.

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

9.
PERFORMING
ORGANIZATION
NAME
AND
ADDRESS
U.
S.
EPA
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
10.
PROGRAM
ELEMENT
NO.

11.
CONTRACT/
GRANT
NO.

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
final
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
NESHAP.
The
economic
impacts
of
the
rule
are
estimated
by
comparing
the
expected
costs
of
compliance
to
the
sales
of
affected
firms.
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
20
20.
SECURITY
CLASS
(
Page)

Unclassified
22.
PRICE
EPA
Form
2220­
1
(
Rev.
4­
77)
PREVIOUS
EDITION
IS
OBSOLETE
Page
23
Page
24
United
States
Office
of
Air
Quality
Planning
and
Standards
Publication
No.
EPA­
452/
R­
03­
018
Environmental
Protection
Air
Quality
Strategies
and
Standards
Division
August
2003
Agency
Research
Triangle
Park,
NC
