Date 
October 19, 2021 
Subject 
Data collection 
Stakeholder 
Brigitte Miller
info@coatingsusa.com
(540) 636-7911
EPA in attendance 
- 
ERG in attendance 
Liz Hubbard 
Facility Contact with Coatings USA, LLC in Front Royal, VA - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT) 

 Initially contacted facility on 10/13/2021 and was told that Brigitte Miller was busy and would call back when available.

 Had not heard back from facility by 10/18/2021 so called again and left a voicemail. Received a call back from the spouse of the co-owner (Brigitte) who said that they are a very small shop. He says they have converted most of their customers to either zero or low VOC emission coatings. Now they do a lot of carbon fiber finishing. Forwarded my contact information to Brigitte.

 Received a call back from Brigitte on 10/19/2021 and was able to ask survey questions.

Mission:
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 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.

 Ms. Miller responded to this information by saying that the facility eliminated plastic parts from their coating line a long time ago (did not know exact timeframe), and they essentially only coat metal parts now with few exceptions. 
      They used to coat IBM computer monitor housing, keyboards, etc.; cleaned them up and repainted, but this was years ago. Used to do fog coating of their plastic parts but decided to eliminate those so that they could narrow the source categories that are applicable to their facility. 
      Ms. Miller said that they worked with David Taylor at VADEQ during their last permit renewal to narrow the source categories that apply to this facility. Since they already were coating so few of these parts, they did not feel it was worth having to comply with another rule which is why they have mostly switched to metal parts only.
      Although they do not currently coat any plastic parts for business machines, they are still listed as subject to TTT in their most recent air permit (from 2015).
They do coat some different non-metal parts that are cosmetic (some are carbon fiber, not sure if this would be considered plastics) and small parts used for components, but not aware of any used for business machines. They also coat the grips for some firearms, and those might be plastic parts, but she wasn't sure.
 Based on the above information, only asked select questions from the survey that seemed like they might still apply.


 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? 

Facility uses low VOC coatings, and they have spray booths with filters that are 99.9% efficient (this is an estimate from what Ms. Miller could recollect during the call). They also use HVLP spray guns for spray coating.

Note: This question was asked more generally "If they have any procedures or VOC control technologies at the facility" since Ms. Miller stated that Subpart TTT does not apply to their facility. 

 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)? 

Pretty much everything they coat (manufacturers are trending toward more environmentally friendly paints) uses low VOC coatings. A lot more water-based paints are available now. Between industry practices and paint that is now supplied, they tend to go the route of lower VOCs. They source a lot of their paints from Sherwin-Williams.

Note: As discussed above, this question was asked more generally since the facility is not currently an active Subpart TTT painter.
 Do you track either spray booths' transfer efficiency or VOC concentrations in booth exhaust?

No, it's not something that they track. If booth filters are not operating at peak performance then they will restrict air flow, so they aren't measured with a device, but they can tell based on their performance when it is time to replace filters. No monitoring device aside from air flow sensor that indicates when to change the filter. 

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

      No, and no plans to start coating them unless there is a big change in industry. Industry would have to pursue them in order to consider coating these parts again.

 Do you have other industry contacts that are knowledgeable about the rule and might have useful input in our review? 
      
      Ms. Miller mentioned a few facilities and some directories that we might consider searching, but there were no facilities that she felt certain would be spray coating plastic parts for business machines:  
 Sally Precision in Waynesboro, Virginia  -  manufacturing facility; believe they only do powder coating
 Frederick County Customs  -  don't think they do business machines
 Protype Industries in northern Virginia  -  manufacturing but also do CNC and may liquid coat
 Finishing.com is a resource used by some industries; anodizing, electroplating, may not even do spray coating, but we could check
 Thomas directory might have something (thomasnet.com)  -  might help us find some more facilities to contact
      
