Stakeholder Meeting with American Coatings Association for Industrial Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
August 25, 2021
Subject
Data collection
Stakeholder
David Darling. Vice President of Health, Safety and Environmental Affairs
EPA in attendance
Lisa Sutton, Keith Barnett
ERG in attendance
Bryan Lange

Mission:
The original NSPS Subpart TTT evaluated what controls were available and then did an environmental benefit analysis to determine if control costs were reasonable. Those costs did not represent a particular plant but were based on models. 
This NSPS Subpart TTT review will address business machine coating lines that come on-line after June 1, 2022 (i.e., the target proposal date specified in the consent decree). EPA will identify the best performer among the existing facilities that are currently subject to the NSPS (promulgated in 1988). EPA will also look at other available controls and costs to determine if tighter standards are appropriate. Cost calculations will likely be based on new business machine coating lines at model facilities.
NSPS' apply all sources regardless of size. Conversely, NESHAPs (e.g., Part 63 Subpart PPPP for plastic parts) apply only to major HAP sources. Preliminary research shows the Subpart TTT source category includes facilities which are mostly an area source of HAP.
The reg. text defines a business machine in 40 CFR 60.721 as a device that uses electronic or mechanical methods to process information, perform calculations, print or copy information, or convert sound into electrical impulses for transmission... and six (6) SIC codes are listed. It is an open question what equipment should be included in today's definition of business machines (e.g., grocery store scanners, ATM machines).
The schedule is set by the consent decree. Specifically, the proposal must be signed by June 1, 2022. EPA hopes to identify the population of existing facilities by fall 2021.
Data collection, to date:
Our initial focus was facilities who reported a release or emissions to TRI and NEI and self-identify under the reg. text SIC codes (or their modern day equivalent NAICS codes). EPA was reluctant to use this information to define the population of existing facilities given that these codes satisfy the U.S. Dept. of Commerce, surface coating is ancillary activity, and reporters sometimes use a flawed logic in choosing NAICS codes.
EPA determined the search results from the ECHO database (which can be searched by applicable Subpart) to provide a more accurate list of existing facilities. 17 facilities were identified, and they are primarily job shops. Job shops are not household names, but flexible contract manufacturers who paint products (e.g., business machines, auto parts) for a collection of customers at a single location. Further, these 17 are not ACA members, but likely use coatings manufactured by them. 
We are learning what we can about these 17 facilities by collecting air permits. Specifically investigating, are they meeting or exceeding VOC limits required in Subpart TTT and how has pollution control since 1988.  Initial findings show these facilities are not Title V sources, do not have pollution control, and don't have more stringent emission limits. 
EPA found one facility in the RBLC that was identified as subject to the NSPS Subpart TTT and record was nearly 20 years ago. The facility was Douglas Corporation, in Minnesota, manufactured plastic product identifiers (e.g., nameplates, decals, decorative trim).
EPA Questions:
 Are there particular manufactured coatings that are specifically for plastic parts? We understand these facilities might not be always coating plastic parts.
ACA Reply: In an informal survey, members say that much of the manufacturing of cell phones and computers occurs oversees. Typewriters aren't used anymore. Our internal market analysis shows that powder coating is becoming more common. It was ACA intent, that they would listen today and then collect information to address your specific questions.
 There are computer manufacturers in North Carolina. Is it safe to assume they are only doing assembly?
ACA Reply: Domestic computer manufacturers are exclusively assembly. Some manufacturing never left (i.e., automobile and aircraft), but smaller consumer electronic devices are now manufactured elsewhere. 
 EPA will share the ECHO list of 17 facilities. If there are similar facilities that are missing from the list or if there is a trade agency that represents them EPA would like to know. 
ACA Reply: Great. That will give my members a facility list to consider.  Would the plastic parts NESHAP residual risk and technology review have information that might be useful or appliable to Subpart TTT?
EPA Reply: It is unlikely its useful given the focus for the NESHAP review is air toxics. EPA has a list of the 128 facilities subject to the plastic parts NESHAP and only one of the ECHO 17 is on both lists (i.e., Erler Industries, Inc). 
 The original NSPS source categories included other surface coating activities (e.g., fabric, paper). Do you have any insight into why EPA chose to limit VOC limits for surface coating of plastic parts for business machines?
ACA Reply: Perhaps when computers were as big as a vehicle, the emissions were greater. You should look to California. They have some of the most stringent regulations and areas with bad air quality. 
EPA Reply: The ECHO 17 list includes a facility in Stockton, CA. East of San Francisco. We have not yet collected that permit.
Follow-up:
EPA shared the ECHO list of 17 facilities. Comments were provided on the individual facilities. 
ECHO Facility
Location
ACA Notes
Cabarrus Plastics, Inc.
Dalton, GA
No website 
CCF of NC, LLC
Asheboro, NC
Not business machines - looks like OEM supplier to Heavy Truck, Appliances, Medical Devices, Automotive, Watercraft, Aerospace & Agricultural Equipment and Off-Road vehicles.
Coatings USA LLC
Front Royal, VA
Really small - general coating company - firearms, motorcycles 
Commercial Finishing Corp.
Indianapolis, IN
General powder coating - mainly metal parts 
Conformance Coating and Prototype, Inc
Marysville, MI
CCP specializes in painting plastic parts for all commodities. These include to date, Industrial, Military, Medical, Business Machine, Institutional, Communications, Private, Sporting Goods, Automotive and Aeronautics.
Erler Industries, Inc.
North Vernon, IN
The Erler companies, with locations in the USA and Mexico, are dedicated to the decoration of plastic and metal parts for a broad range of industries, including telecommunications, handheld devices, automotive, consumer electronics, and domestic - IN appliances. 
FM Structural Plastic Technology, Inc. - FM Corporation
Rogers, AR
We now serve medical, scientific, telecom, industrial, and defense industries to name a few.
Jvisfh, LLC
Farmingtn Hls, MI
Seems more related to automtive oem 
K & K Painting Inc                      
Berthoud, CO
No website - small 
Mack Molding Company
Statesville, NC
Large - ATM machines for example - NC 
Mack Molding Company Inc (Arlington)
Arlington, VT
A division of company above - VT 
Measurement Specialties Inc
Hampton, VA
Seems more electronic component manufacturers 
Plastic Painting Solutions
Stockton, CA
Now B&C Painting solutions - located in CA, seem to paint computer equipment - San Jaoquin Air District 
Plastics Design & Manufacturing         
Centennial, CO
More aerospace and defense? 
Reiss Manufacturing Inc
Blackstone, VA
More rubber gaskets? 
Universal Plastics - Middlefield
Middlefield, OH
More injection molding?
Xerox Corporation - Wilson Center
Webster, NY
I would think this might be a good one to look into given that Xerox is a leader in business equipment manufacturing and located in NY

