MEMORANDUM 

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

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

DATE: November 19, 2015 

SUBJECT: Documentation of Aerospace Manufacturing and Rework facilities that meet the 

Small Business Administration definition of small entity 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 specialty coatings, according to the EPA's 2011 

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

sources and, therefore, not subject to the Aerospace 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 all facilities with fewer than 1500 employees 

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

indicated the number of employees in the parent company. 

In Table 2, the HAP content of each of the specialty 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 available 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 surface 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 ID Facility Name Address City State Zip Code

Total 

Number 

Of 

Employees 

At Facility 

Size Of P

Compa

(includin

subsidia

branches

relate

establishm

owne

343 CTL Aerospace, Inc. 5616 Spellmire Drive Cincinnati OH 45246 210 523 Southwest United 

Industries, Inc. 

422 S. St. Louis Ave. Tulsa OK 74120 182 

652 PGM of New England 

LLC 

5 Perimeter Road Manchester NH 03103 42 

2014 Quality Plating Co. of 

Tulsa 

2665 N. Darlington Tulsa OK 74115 48 

2025 EDAC Technologies 1798 New Britain 

Avenue 

Farmington CT 6032 75 
Table 2: Specialty Coatings used by facilities listed in Table 1, calculated HAP content compared to the final rule HAP/VOC 

SITE ID FACILITY NAME Coating Manufacturer Product Total Volume (gal) Specialty Coating Category C

343 CTL Aerospace, 

Inc. 

ACHESON COLLOIDS COMPANY 

MOLYDAG 254 0.3 Dry lubricative material 

343 CTL Aerospace, 

Inc. 

Akzo Nobel Aerospace Coatings 

8B6A; LAMINAR X500 CONDUCTIVE BLACK 

0.1 Electrostatic discharge or 

electromagnetic interference coat 

2025 EDAC 

Technologies 

PPG Industries DX520 (Metal 

conditioner) 

1 Other - Coating used to clean meta

2025 EDAC 

Technologies 

PPG Industries UA-11 (Urethane 

accelerator) 

0.25 Other - Coating used to accelerate 

coating (not actually used as a stan

2025 EDAC 

Technologies 

PPG Industries DX579 (metal cleaner) 1 Other - Coating used to clean meta

2014 Quality Plating 

Co. of Tulsa 

PRC Desoto 825-009/910- 175/020-044 37.06 High Temperature Coating 

2014 Quality Plating 

Co. of Tulsa 

Akzo Nobel 10P4-2/EC-117 2608.95 Compatible Substrate 

Primer 

2014 Quality Plating 

Co. of Tulsa 

Akzo Nobel 454-4-1/CA-109 79.39 Fuel Tank Coating 

2014 Quality Plating 

Co. of Tulsa 

Everlube Products 

Everlube 620C 9.22 Solid Film 

Lubricant 

2014 Quality Plating 

Co. of Tulsa 

Akzo Nobel 23T3-10/PC-216 182.78 Antichafe Coating 

523 Southwest 

United Industries, Inc. 

AC Products AC-828-T-RTU Green 330 Seal coat maskant 
SITE ID FACILITY NAME Coating Manufacturer Product Total Volume (gal) Specialty Coating Category C

523 Southwest 

United Industries, Inc. 

PRC Desoto 515X346/910X520 2.83 Flexible 

Primer 

523 Southwest 

United Industries, Inc. 

PRC Desoto 825-009/910- 175/020-044 4.75 High Temperature Coating 

523 Southwest 

United Industries, Inc. 

Akzo Nobel 10P4-2/EC-117 599.22 Compatible Substrate 

Primer 

523 Southwest 

United Industries, Inc. 

Everlube Products 

Everlube 620C 27.63 Solid Film 

Lubricant 

523 Southwest 

United Industries, Inc. 

Akzo Nobel 23T3-10/PC-216 9.12 Antichafe Coating