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OAR Box 1834 

Prepped by Keeia Richards 

Document Number: 

33) IV-E-06 

Docket Number: 

A-90-07 

Printed 11/10/2008 2:14:35 PM Sheet 33 of 61 
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* & \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

x ^ ANN ARBOR. MICHIGAN 48105 

AUG 1 0 1992 

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n/-£-Olp 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

SUBJECT: Phone Conversation and Meeting Between EPA and the Motor 

& Equipment Manufacturers Association (MEMA) 

FROM: Carolyn Krueger, Chemical EngineexC^Mjb^^^UJ^'>/ 

Special Regulatory Projects Branch/ 

THRU: Judith Gray, Project Manager 

Special Regulatory Projects 

TO: 

Glenn W. Passavant, Branch Cfirle 

Special Regulatory Projects Branch 

Docket A-90-07 

n —h -' / 

On Monday, July 13, 1992, Carolyn Krueger, of the EPA, phoned 

Paul Haluza, of MEMA, to follow up on his May 28th meeting with 

Sheri Dunatchik, of EPA. The purpose of the call was to inquire 

whether MEMA was still considering the possibility of voluntarily 

conducting its own survey of its members to gather information 

which would assist in defining "small business". Mr. Haluza said 

that MEMA was still interested in the issue. He mentioned that he 

would be at EPA's Ann Arbor facility on Thursday, July 23, 1992, 

and suggested meeting then to discuss what types of information 

would be of most useful. 

Accordingly, on July 23, 1992, Carolyn Krueger and Ines 

Figueroa, of EPA, met with Paul Haluza and Alan Jones, of MEMA, and 

Marc Fleischaker, of Arent Fox Kintner Plotkin and Kahn. At the 

meeting, Ms. Krueger suggested a number of company data items that 

would be useful in determining what characterized a small fuel and 

fuel additive business (see attached list). MEMA thought that a 

survey limited only to its own members would not be representative 

of the nationwide aftermarket industry and suggested that EPA 

provide company names and addresses of other non-member aftermarket 

manufacturers. Ms. Krueger said she would need to consult with her 

managers as to whether this was possible. In the meantime, MEMA 

would begin developing a survey and would target the survey mailing 

for mid-September, 1992. 

Attachment 
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POSSIBLE SMALL BUSINESS INFORMATION 

COMPANY TYPE: - privately held 

- publicly traded (or part of a company that is publicly traded) 

- single-unit business 

- multi-unit business (e.g., divisional organization 

- division or subsidiary of another entity 

RESOURCES: Total F/FA Related Only 

Annual revenue 

Annual net income (profit) 

Number of employees 

Bottom-line profit percentage 

before f/fa production 

would cease 

PRODUCTS: 

No. of fuels produced/blended: 

No. of bulk additives produced: 

No. of aftermarket additives produced (not relabeled): 

FUELS: For each fuel produced/blended: 

Fuel type (e.g., gasoline, diesel) 

If gasoline, does it qualify for the "substantially similar" criteria 

Annual production volume* 

ADDITIVES: For each additive produced: 

Bulk or aftermarket 

Intended for which fuel type 

Purpose-in-use of the additive 

Annual production volume* 

Concentration-in-use 

Recommended amount in use (e.g., 16 oz. per x gallon fuel tank, ppm in fuel) 

and frequency of use 

Other than emptying bottle or can into fuel tank, is there a 

special means of introduction into vehicle/engine 

* Standard units; units may or may not be standard for fuels and additives, but should be 

consistent among all additives and all fuels.