Facility Contact with Mack Molding in Arlington, VT - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
October 19, 2021
Subject
Data collection
Stakeholder
Brian Sullivan, facilities manager 
802-375-2511
brian.k.sullivan@mack.com
EPA in attendance
-
ERG in attendance
Liz Hubbard

No answer when we initially called this Mack Molding location, but received a call back from Brian Sullivan. He did not feel comfortable sharing information over the phone and asked if we could send him an email instead as he wanted to confirm our contractor credentials. 
Mr. Sullivan responded to our email request saying that he would verify our contractor designation letter and spoke with Keith Barnett on the phone. Mr. Sullivan stated that he might make a CBI claim on some of the information that was requested. 
Mr. Sullivan later followed up with an email which said that he had spoken with the plant manager and that they do not currently manufacture business machines. The most recent contract involving business machines that they know of was a contract with Xerox 20 years ago.
Facilities
The Clean Air Act requires the EPA to periodically review and revise its federal rules. We are asking for your help with this requirement for the NSPS Subpart TTT (Surface Coating of Plastic Parts for Business Machines). Your facility was identified in an EPA database as subject to Subpart TTT. We collected your air permit from the Vermont Department of Environmental Conservation and have confirmed this. 
We have prepared a short telephone survey for facilities that are subject to this rule. We hope to learn more about the impact of the 1988 rule, ways it might be improved for future facilities, and to look for innovation in the control of air pollution (e.g., new add-on control technologies, new work practices or operational procedure).  After the call we can share with you a copy of the minutes and discuss any necessary changes.
 Describe your business and surface coating process and approximately what fraction of your operation is used to coat plastic parts for business machines? 
 When did the facility open and how has production changed over time? 
 Today, how many different products are coated (what fraction are plastic parts for business machines)?
 How many spray booths do you have (what fraction are used for coating plastic parts for business machines)?
 Because of COVID we are unable to visit facilities. Do you have a promotional video that might take the place of a plant tour? Is there a possibility of scheduling a virtual plant tour?

 Can you share with us an approximate annual surface coating throughput (approximately what fraction is used to coat plastic parts for business machines)? 
 Can you provide a range of the amount of coating used on a single product? 

 We found your facility in a database indicating it is subject to NSPS subpart TTT (i.e., Surface Coating of Plastic Parts for Business Machines). Have you implemented any procedures or VOC control technologies to comply with that rule? 

 Have you made other accommodations to comply with Subpart TTT requirements and standards (e.g., VOC reporting requirements)? Are there business reasons for using paints with more than minimum VOC (e.g., because higher solvent contents are necessary for effective paint transfer for your product, or because the solvents preventing your coating from spoiling)? 

 Do you track either spray booths' transfer efficiency or VOC concentrations in booth exhaust?

 If you were building a new plant in a different location to address a growing demand applying surface coating to plastic parts for business machines, how would it be different?

 Do you have plans to expand your coating operation for plastic parts for business machines?

 Do you have other industry contacts that are knowledgeable about the rule and might have useful input in our review? 
