# MEMORANDUM

TO: Docket EPA-HQ-OAR-2014-0830

FROM: Kim Teal, U.S. EPA/OAQPS

DATE: November 19, 2015

SUBJECT: Documentation of Aerospace Manufacturing a nd Rework facilities that meet the

Small Business Administration definition of small e ntity and that use specialty

coatings.

The facilities listed in Table 1 of this memorandum were identified as small businesses (entities

with fewer than 1500 employees) and that use specia lty coatings, according to the EPA's 2011

Information Collection Request (ICR). This list doe s not include facilities that were not major

sources and, therefore, not subject to the Aerospac e Manufacturing and Rework NESHAP (40

CFR part 63, subpart GG).

Some facilities in the ICR database did not report any information on the size of the parent

company. If the number of employees at the facility was greater than 1500, these were

assumed to not be a small business. The status of a ll facilities with fewer than 1500 employees

in the ICR database was also confirmed through an o n-line search for company information that

indicated the number of employees in the parent com pany.

In Table 2, the HAP content of each of the specialt y coatings used at the facilities that were

small companies is compared to the VOC/HAP content limits in the final rule. All of the specialty

coatings used by these facilities, based on the ava ilable ICR data, are already compliant with the

VOC/HAP content limits in the final rule.

One facility, EDAC Technologies, does not actually use any materials that qualify as specialty

coatings. Two reported materials appear to be surfa ce cleaning solvents. The third material is

used as an additive in other coatings that were not reported as specialty coatings; it is not used

as a coating by itself.Table 1: Aerospace Manufacturing and Rework Facilities that meet the definition of small entity.Site IDFacilityNameAddress City State Zip CodeTotalNumberOfEmployeesAt FacilitySize Of ParentCompany(including allsubsidiaries,branches, andrelatedestablishmentsowned)343CTL Aerospace, Inc.5616 Spellmire DriveCincinnatiOH45246210210523Southwest UnitedIndustries, Inc.422 S. St. Louis Ave.TulsaOK74120182190652PGM of New EnglandLLC5 Perimeter RoadManchesterNH03103421042014QualityPlating Co. ofTulsa2665 N. DarlingtonTulsaOK7411548482025EDAC Technologies1798 New BritainAvenueFarmingtonCT603275390Table 2: Specialty Coatings used by facilities listed in Table 1, calculated HAP content compared to the final rule HAP/VOC limits.SITE IDFACILITYNAMECoatingManufacturerProductTotalVolume(gal)Specialty Coating CategoryCalculatedHAPcontent(g/l)Final RuleHAP/VOCCoatingLimit(g/liter)343CTL Aerospace,Inc.ACHESONCOLLOIDSCOMPANYMOLYDAG 2540.3Drylubricative material403880343CTL Aerospace,Inc.Akzo NobelAerospaceCoatings8B6A; LAMINAR X500CONDUCTIVE BLACK0.1Electrostatic discharge orelectromagnetic interferencecoat1228002025EDACTechnologiesPPG IndustriesDX520 (Metalconditioner)1Other-Coating used to clean metal before coating2025EDACTechnologiesPPG IndustriesUA-11 (Urethaneaccelerator)0.25Other-Coating used to accelerate hardening of urethanecoating (not actually used as a stand-alone coating)2025EDACTechnologiesPPG IndustriesDX579 (metal cleaner)1Other-Coating used to clean metal before coating2014Quality PlatingCo. of TulsaPRC Desoto825-009/910-175/020-04437.06High Temperature Coating4388502014Quality PlatingCo. of TulsaAkzoNobel10P4-2/EC-1172608.95Compatible SubstratePrimer2977802014Quality PlatingCo. of TulsaAkzo Nobel454-4-1/CA-10979.39Fuel Tank Coating2927202014Quality PlatingCo. of TulsaEverlubeProductsEverlube620C9.22Solid FilmLubricant1098802014Quality PlatingCo. of TulsaAkzo Nobel23T3-10/PC-216182.78Antichafe Coating33660523SouthwestUnitedIndustries, Inc.AC ProductsAC-828-T-RTU Green330Seal coatmaskant7781230SITE IDFACILITYNAMECoatingManufacturerProductTotalVolume(gal)Specialty Coating CategoryCalculatedHAPcontent(g/l)Final RuleHAP/VOCCoatingLimit(g/liter)523SouthwestUnitedIndustries, Inc.PRC Desoto515X346/910X5202.83FlexiblePrimer478640523SouthwestUnitedIndustries, Inc.PRC Desoto825-009/910-175/020-0444.75High TemperatureCoating438850523SouthwestUnitedIndustries, Inc.Akzo Nobel10P4-2/EC-117599.22Compatible SubstratePrimer297780523SouthwestUnitedIndustries, Inc.EverlubeProductsEverlube 620C27.63Solid FilmLubricant109880523SouthwestUnitedIndustries, Inc.Akzo Nobel23T3-10/PC-2169.12Antichafe Coating33660