Date 
November 4, 2021 
Subject 
Data collection 
Stakeholder 
Jeff Jones
(810) 364-4333
EPA in attendance 
- 
ERG in attendance 
Liz Hubbard 
Facility Contact with Conformance Coating & Prototype, Inc in Marysville, MI - Surface Coating of Plastic Parts for Business Machines (NSPS Subpart TTT) 

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). Conformance Coating and Prototype, out of St. Clair MI, was identified in an EPA database as subject to Subpart TTT. We collected your MI 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. 


 Describe your business and surface coating process and approximately what fraction of your operation is used to coat plastic parts for business machines: 
      Facility mostly coats medical devices and military machines.
      A lot of what they coat is analyzing equipment. 
      They coat x-ray machines, castor wheels and brackets, armored personnel carriers for tanks, automotive parts, light covers, electronic devices and machines.
      Mostly coat for larger companies and the military but sometimes do smaller jobs as well. 
 Can you share with us an approximate annual surface coating throughput (approximately what fraction is used to coat plastic parts for business machines)? 
      Less than 10% of facility throughput is used for coating business machines. Currently not coating business machines, but they sometimes do.
      No powder coating at facility, only spray coating.
 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? 
      Yes, they were audited last year and have modified the facility since. Cannot smell paint in the parking lot or in the building. Their water and air samples have shown no particulates.
 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)? 
      Work in conjunction with advanced engineering teams to develop low or no VOC paints, and always order low VOC and low HAP paints where available.
   Want to avoid exposing workers to toxicity. 
      Facility uses waterborne paints where possible. Majority of paints are still solvent borne. A little more than 80% solvent borne, a little less than 20% waterborne.
      Dispose of paint cans with a third-party company; no paint cans or other materials containing paint are thrown in the regular dumpster.
 Do you track either spray booths' transfer efficiency or VOC concentrations in booth exhaust? 
      Absolutely, we actually weigh the padding that we throw away in the dumpster to measure how much paint is contained in it.
 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? 
      We would provide an environment of HEPA filtration for all spray applications, we would convert to waterborne paints, and I think anything else would be a major capital investment, but there does exist equipment that does a better job of atomizing paint. I would use equipment that would electrostatically draw paint to the part rather than using a spray booth that leads to a lower transfer efficiency and more contamination and paint waste.
 Do you have plans to expand your coating operation for plastic parts for business machines?  
      Not at this time.
 Do you have other industry contacts that are knowledgeable about the rule and might have useful input in our review? 
      Thomas Bell  -  co-owner of Technical Finishing Incorporated in Flint, Michigan 
 Believes they also coat plastic parts for business machines.
