Facility Contact with ALUDEC / Douglas Corp. - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT)
Date
March 28, 2022
Subject
Data collection
Stakeholder
Chloe Colvin
(952) 826-3235
EPA in attendance
-
ERG in attendance
Bryan Lange
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). Commercial Finishing Corp 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.
Background:
In a 2021 search, ERG identified one RBLC entry representing a single facility with the "Plastic Parts for Business Machines Surface Coating" process type, i.e., Douglas Corporation in Minnesota. The facility is a manufacturer of plastic product identifiers, including nameplates, decals, and decorative trim. Its clients primarily include automobile and large equipment manufacturers.
On September 9, 2020, Douglas Corp. was acquired by Aludec USA, Inc.
 Describe your business and surface coating process and approximately what fraction of your operation is used to coat plastic parts for business machines:
In the US, Aludec has 260 staff at 3 locations i.e., one does molding, this Minnesota location pants, and a third cooperate headquarters. 
Aludec does not actively painted plastic parts for business machines. The Minnesota facility paints automotive parts for John Deere, Jeep, Chrysler.
Chloe Colvin has been there 3-years. During her period of employment, they have not painted plastic parts for business machines at all. Ms. Colvin would ask a more senior staff member to see if plastic parts for business machines have been painted in the past. 
