Date: September 30, 2005

From: David Randall

To: Gary Blais

Subject: Minutes of June 28, 2005 Conference Call Among Participants in
Implementation Partnership Group for Miscellaneous Coating Manufacturing
NESHAP

I.  [Purpose]{.underline}

The sixth conference call of the Implementation Partnership Group for
the Miscellaneous Coating Manufacturing (MCM) NESHAP was held on June
28, 2005. The purpose of the call was to update participants on the
status of implementation tools under development and decide how much can
be completed by the end of EPA=s fiscal year on September 30.

II. [Participants]{.underline}

[Industry Representatives]{.underline}

Mark Collatz, Adhesive and Sealant Council

David Darling, National Paint and Coatings Association (NPCA)

Alison Keane, NPCA

[USEPA]{.underline}

Gary Blais, OAQPS

Marcia Mia, OECA

[State Regulatory Agencies]{.underline}

Bill Juris, Ohio EPA

[EPA Contractor]{.underline}

David Randall, RTI International

III. [Discussion]{.underline}

The discussion focused primarily on the applicability flowcharts and
inspection checklists. Gary Blais mentioned that the available resources
would only allow for completion of these two tools.

1\. [Applicability Flowcharts]{.underline}

Gary Blais asked if anyone had any comments on the revised flowcharts.
David Darling indicated that NPCA had a few minor editorial comments on
the revised flowcharts. He would send written comments to Gary Blais
after the conference call.

2\. [Inspection Checklists]{.underline}

Alison Keane suggested using the electroplating checklists as a template
for the MCM checklists. David Darling indicated that these checklists
are more concise and easier to follow than the HON checklists. They will
forward a copy to Gary Blais after the conference call.

3\. [Miscellaneous]{.underline}

Gary Blais noted that the air toxics website posted amendments to the
rule on May 13, and he asked if these changes would affect the
flowcharts and checklists. David Darling indicated that NPCA was
submitting an adverse comment on one issue, but the other amendments
will go final (and any that are applicable are already incorporated in
the flowcharts, except for the edits needed as noted above). After the
conference call, Marcia Mia noted that the definition of coating will
likely be revised, which could affect the facility applicability
flowchart (figure 1).

Marcia Mia mentioned that OECA has prepared a Q&A letter to address some
issues raised by 3M. Most of the issues are related to the MON, but some
relate to coatings manufacturing. She will send a copy to the group.

IV. [Action Items]{.underline}

1\. David Randall will:

-   Revise the draft applicability flowcharts to address NPCA review
    comments.

-   Review the electroplating inspection checklists and draft MCM
    inspection checklists.

2\. Alison Keane and David Darling will:

-   Send written copy of additional comments on flowcharts to Gary
    Blais.

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-   Send to Gary Blais a copy of example checklists to consider using as
    a template for the MCM checklists.

3.  Marcia Mia will:

    -   Send to NPCA a copy of letter from OECA to 3M that addresses
        issues raised by 3M on the MON and MCM rules.