Technical Support Document for Proposed Rule 

National Emission Standards for Hazardous Air Pollutants 

Paint Stripping and Miscellaneous Surface Coating Operations at Area 

Sources 

Warren Johnson: Lead Engineer 

U.S. Environmental Protection Agency 

OAQPS/Sector Policies and Programs Division 

Natural Resources and Commerce Group (E143-03) 

Research Triangle Park, North Carolina 27711 

August 2007 
0223-00-008\tsd for proposed rule iii

Table of Contents 

Section

1.0 Introduction 

2.0 Summary of the Automobile and Mobile Equipment Refinishing Process Based on Site 

Visits to Refinishing Shops 

3.0 Analysis of Generally Available Control Technology (GACT) for Motor Vehicle and 

Mobile Equipment Refinishing Operations at Area Sources Subject to the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Surface 

Coating Area Sources 

4.0 Analysis of Generally Available Control Technology (GACT) for Miscellaneous Plastic 

Part and Metal Part Surface Coating Operations at Area Sources Subject to the National 

Emission Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous 

Surface Coating Operations at Area Sources 

5.0 Estimating the Number of Automotive Refinishing Shops and the Projected Number of 

New Shops 

6.0 Estimating the Number of Miscellaneous Surface Coating Area Sources for Which EPA 

Has Data 

7.0 Development of Model Shops for Sources Subject to the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for Motor Vehicles and Mobile Equipment 

Refinishing Operations for Area Sources 

8.0 Estimate of Baseline Emissions and Emission Reductions for Sources Subject to the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Motor 

Vehicles and Mobile Equipment Refinishing Operations for Area Sources 

9.0 Estimate of Baseline Emissions and Emission Reductions for Sources Subject to the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous 

Surface Coating Area Sources 

10.0 Estimate of Capital and Annual Costs For Automotive Refinishing Operations and 

Miscellaneous Surface Coating Operations Subject to the Proposed National Emission 

Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous Surface 

Coating Operations at Area Sources 
0223-00-008\TSD for proposed rule 1

1.0 Introduction 

Pursuant to Clean Air Act section 112(c)(3)and (k)(3)(B), the EPA is developing national 

emission standards for hazardous air pollutants for the following area source categories: paint 

stripping, plastic parts and products (surface coating), and autobody refinishing. In developing 

this proposed rule, EPA analyzed these three listed source categories and found that it is both 

reasonable and technically feasible to regulate emissions from these three source categories by a 

single set of emission standards. The processes, emission points, emission characteristics, and 

emission controls for plastic parts and products surface coating and autobody refinishing are very 

similar. Additionally, paint stripping is often performed as part of the surface preparation for 

both plastic parts and autobody refinishing. By regulating within the scope of a single set of 

standards, the EPA is reducing the burden of complying with multiple standards on the sources 

performing both the paint stripping and subsequent coating. 

This technical support document is composed of a series of memoranda and reports 

prepared by the EPA to document the findings of the regulatory development process for motor 

vehicle and mobile equipment refinishing and for other miscellaneous surface coating operations 

at area sources. These are generally separate documents for motor vehicle and mobile equipment 

refinishing operations and for other miscellaneous surface coating operations since many of the 

analyses were first performed while these were still being addressed by EPA as separate source 

categories using different sources of data and information. In the interest of efficiency and 

conservation of resources, the EPA has chosen to present this information as a collection of 

existing documents for these two source categories rather than generate an additional document 

containing a synthesis of the information. 

The analyses conducted in relation to paint stripping operations are included in a separate 

technical support document. 

Each section contains a technical memorandum documenting the analysis of collected 

data. Section 2.0 presents a summary of the automobile and mobile equipment refinishing 

process based on site visits to refinishing shops. (A similar summary was not prepared for 

miscellaneous surface coating operations since these were thoroughly documented for the 

NESHAP for major sources for miscellaneous metal parts and products surface coating [40 CFR 

part 63, subpart MMMM], and plastic parts and products surface coating [40 CFR part 63, 

subpart PPPP].) Sections 3.0 and 4.0 present the analyses of generally available control 

technology (GACT) for each of the two surface coating categories. Sections 5.0 and 6.0 present 
0223-00-008\tsd for proposed rule 2

estimates of the number of sources and the projected number of new sources. Section 6.0 also 

includes a list of known miscellaneous metal part and plastic part surface coating facilities for 

which EPA has data and estimates are area sources of HAP. Section 7.0 documents the 

development of model shops for motor vehicle and mobile equipment refinishing operations at 

area sources. (Model shops were not developed for other miscellaneous surface coating 

operations since subsequent analyses were based on survey data of actual shops.) Sections 8.0 

and 9.0 provide estimates of baseline emissions and emission reductions. A single memo, 

included in section 10.0, documents the estimated cost impacts of the proposed rule for both 

motor vehicle and mobile equipment refinishing operations and the other miscellaneous surface 

coating operations. 
2.0 

Summary of the automobile and mobile equipment refinishing 

process based on site visits to refinishing shops 
0223-00-008\Refinish Process Summary 1

MEMORANDUM

To: Kim Teal, U.S. EPA/CCPG (C539-03) 

From: Mike Heaney and Brian Palmer, Eastern Research Group, Inc. 

Date: March 29, 2005 

Subject: Summary of the automobile and mobile equipment refinishing process based on 

site visits to refinishing shops 

In the development of the area source rule for automobile and mobile equipment 

refinishing, EPA and ERG visited 18 facilities that were involved in this activity. Most of these 

were automobile collision repair and refinishing shops, but two were car restoration shops, three 

were mobile equipment repair shops, and one was a race car shop. This memo summarizes the 

observations and information collected during these visits and provides an overview of the 

materials, equipment, and techniques used in automobile and mobile equipment refinishing. 

The same basic materials, equipment, and procedures are used for refinishing 

automobiles and mobile equipment in all shops, whether the job is to repair a spot, refinish a 

panel, or refinish an entire automobile. However, the procedures and equipment do vary in some 

ways from shop to shop depending on the vehicle and amount of refinishing being performed 

and type of finish applied. This memorandum describes the process of refinishing a vehicle after 

other work is completed to either repair collision damage or to restore or refurbish an older 

vehicle. 

1.0 COATING PROCESS

Generally, the refinishing process involves cleaning the surface to ensure proper adhesion 

of the coating, the surface is primed and sealed, a topcoat is applied, and the spray equipment is 

cleaned. 
0223-00-008\Refinish Process Summary 2

Surface Preparation

The first step in the refinish process is preparing the surface. The surface that is being 

refinished is usually a mix of substrates. These substrates may include any or all of the 

following: the existing finish, bare metal, a flexible plastic (such as on a bumper or door fascia), 

body filler, or a factory applied primer on a metal or plastic replacement part. Generally, all 

surfaces have been sanded to create a smooth surface for refinishing and to obtain a good 

mechanical bond between the new finish and the substrate. Body filler has been used to fill dents 

and dings and has been sanded smooth to restore the original contours of the body. 

At various stages in the repair and refinishing process, the surface is normally washed 

with detergent and water and allowed to dry. It is then cleaned with either solvent or a low-VOC 

waterborne solvent wipe to ensure removal of all remaining wax, grease, and other contaminants 

before any body filler or coatings are applied. Surface preparation products may contain toluene 

or xylene. This step is important to remove contamination and ensure proper adhesion of the 

coatings and is necessary even if the existing paint does not have to be removed or if the parts to 

be coated are new. 

If an existing paint surface has no chips or cracks, it may be prepared by merely "scuffsanding" the surface to promote adhesion, followed by a solvent wipe. If the existing finish has 

imperfections or surface corrosion, or the part has been damaged in an accident, the old finish 

may be sanded down to bare metal. 

Salvaged parts with an existing finish will be treated similar to other parts on the vehicle 

being repaired. New replacement parts or re-manufactured parts are typically primed by the part 

manufacturer before they arrive at the shop. However, some shops will re-prime these parts so 

they can ensure they are using a primer compatible with the subsequent finishes and help protect 

the warranty they offer with their work. 

In most coating operations, the areas of the vehicle that are not intended for painting are 

masked off using a variety of products to protect them from over-spray (the portion of the 

coating solids that does not adhere to the surface being sprayed). Some shops are using a 

waterborne soap-like material that can be sprayed over the whole car, except the repaired area, 

and is left in place during the entire collision repair. When the repair is completed, the sprayable 

masking material is washed off with water. During actual surface coating, the areas adjacent to 

the repaired area will be masked off using a masking tape and paper. The rest of the car will be 

covered with a large plastic or cloth sheet that may be reused, depending on the type of 
0223-00-008\Refinish Process Summary 3

operation. Masking the rest of the car also helps keep the spray booth clean of dirt that may 

come off the car while it is in the spray booth. 

Primer Application for Bare Metal

When coatings are applied to bare metal, the surface is treated with a metal conditioner to 

etch the surface and prevent flash rusting. Metal conditioning is usually achieved using a spray 

applied "self-etching" primer, also called a wash primer. This coating etches and primes the 

surface. Self-etching primers are typically a two-part system containing zinc chromate and 

phosphoric acid. Coating suppliers have stated that currently available chromate-free selfetching primers provide less corrosion resistance. A less common, more difficult method is to 

treat bare metal by hand-apply phosphoric acid surface treatment followed by a conversion 

coating. Some bare metal primers can also be obtained and applied from hand-held aerosol cans. 

If a pretreatment wash primer is not needed, the surface is primed using a primer sealer to 

provide corrosion resistance and promote adhesion. 

Nearly all primers are applied by spray application, either in a ventilated prep station or 

in a fully enclosed spray booth. For small areas and some types of specialty primers, the primer 

may be applied from a disposable hand-held aerosol can. Otherwise, they are mixed in the shop 

and sprayed from a gun. 

If a vehicle is being completely restored, such as a vintage car, the body and frame are 

often completely disassembled in what is called a Aframe-off@ restoration. In these cases, all the 

paint is removed by abrasive blasting, usually by an outside vendor. The bare metal frame and 

body are then primed as soon as they return to the shop to prevent corrosion. If the body or 

frame needs welding during the restoration process, then a special weld-though primer may be 

used. A weld-through primer is more heat-resistant than normal bare-metal primers so that 

damage to the primer from welding is limited to a narrow band adjacent to the weld and less 

surface needs to be re-primed after the welding is completed. In many restorations, it may take 

several weeks or months to complete the restoration and the primer may be the only finish on the 

car during that period. The final finish is not applied until the restoration is nearly complete and 

the car is ready for final assembly. 

In some frame-off restorations, the frame and other suspension parts are powder coated 

after abrasive blasting and this will be the final finish. Again, this is usually done by an outside 

vendor. Powder coating has the advantage that it provides a more durable finish at lower cost 
0223-00-008\Refinish Process Summary 4

than conventional painting and this makes it well suited to coating the frame and other parts 

under the car. However, the results are generally not as smooth and glossy as a painted finish so 

the process is limited to the frame and other parts that are not readily visible. 

Adhesion Promoter Application

Many parts of newer cars are made from molded flexible plastic, including the bumper 

covers, door fascia, body side molding, and interior plastic panels. During a collision repair, 

these parts often need to be refinished to match the rest of the vehicle. To establish a good bond 

between the flexible plastic and subsequent layers of finish, a special adhesion promoter is used. 

If a plastic replacement part is obtained from an original equipment manufacturer or from an 

aftermarket supplier, it is usually coated with an adhesion promoter and primed at the factory. 

However, if a salvaged part is being used or an existing part just needs to be refinished to repair a 

scuffed surface, then the shop doing the repair may need to apply the adhesion promoter. These 

are typically a low-solids coating with powerful solvents that will penetrate the plastic to form a 

good bond with the plastic and subsequent finishes. 

Primer Surfacer Application

If imperfections remain in the surface after bare-metal primer application, several coats 

of primer surfacer are applied. Primer surfacers are high-solids coatings that build film thickness 

so that a smooth surface can be created after sanding. They also help provide adhesion and 

corrosion resistance. 

Primer surfacers are usually spray applied, but some shops have started using roll-on or 

brush-on primer surfacers for small repairs. This method can be cost-effective because of the 

time and material saved by not masking the rest of the car and because it can be applied 

anywhere in the shop because there is no over-spray. Roll-on and brush-on primer surfacers 

reduce emissions because the material is high-solids/low-VOC and the transfer efficiency of the 

application method approaches 100-percent. The only wasted primer is what remains on the 

disposable roller or brush after each job. Although these materials are a good alternative for 

small areas, they are not practical for areas larger than about half of a square foot because it is 

difficult to spread an even layer over a large area using a brush or roller. An uneven surface can 

be hard to sand and the ridges that were present in an uneven application (even if they were 
0223-00-008\Refinish Process Summary 5

sanded out) can swell up after subsequent coating and lead to an uneven surface in the final 

finish.1 

Primer Sealer Application

If there are no surface imperfections, some shops apply only a primer sealer to provide 

more corrosion resistance, promote adhesion of subsequent coatings, and enhance the uniform 

appearance of the topcoat. Primer sealers prevent dulling of the topcoat caused by the 

penetration of topcoat solvents into the primer and primer surfacer coats. They also provide a 

homogenous substrate for the top coats. A primer sealer is applied over the whole area that will 

receive a topcoat. Since they are generally applied over a large area and are the last coat before 

the topcoats, primer sealers are usually applied in a spray booth. 

Sealers may also be tinted to match the color of the topcoats to provide better coverage of 

the top coats and hiding of the primers. This is especially useful in some cases where metal-free 

coatings are more transparent than coatings that used lead- or chromate-containing pigments. 

One example observed during this project was the use of a yellow sealer in the painting of school 

buses. Many of the Aschool-bus yellow@ coatings formerly used lead-chromate pigments and 

now use organic pigments, but the organic pigments are less opaque than the lead-chromate 

pigments. A color-matched sealer is needed to get an even color in the topcoat and hide areas 

that were spot primed. 

Topcoat Systems

Top coats used in automobile and mobile equipment refinishing fall into two main 

categories. In collision repair, most newer cars and light trucks are finished in a base coat/clear 

coat system using a colored base coat that is over laid with one or two layers of a clear coat. The 

clear coat protects the base coat and provides gloss. These systems are popular because of their 

deep, rich finish. The basecoat is typically about one-third and the clearcoat two-thirds of the 

total coating used. 

In some cases, a three-stage system consisting of a colored basecoat, a semi-transparent 

midcoat, and a final clearcoat is used to get a pearlescent appearance. Pearlescent toners are 

added to the base coat or the midcoat and have flakes of mica on which are precipitated metals 

 

1

See www.i-car.com, about I-CAR, Current Events/ News, Advantage On-line, February 4, 2002 article about rollon primer-surfacer. 
0223-00-008\Refinish Process Summary 6

such as trivalent chromium. The basecoat and midcoat account for about one-half of the coating 

volume and the clearcoat for one-half. 

Most heavy duty trucks, mobile equipment, older cars (including antiques and classics) 

and older light trucks are refinished with a single stage topcoat. In a single stage topcoat, a 

single coating provides both the color and the gloss. A refinishing job using a single stage 

topcoat is generally less expensive than a refinishing job using a two stage system, both because 

of lower material costs and reduced labor. Single-stage systems are more frequently used in 

shops that primarily repaint whole cars, rather than perform collision repair work. The industry 

term for these shops is production painting shops. 

Mixing Topcoat Colors

The majority of base coats and single stage topcoat colors are mixed from colored toners. 

The toners may be either a solid color or a metallic color. The sparkle of a metallic color comes 

from small flakes of aluminum, although some metallic colors also contain trivalent chromium. 

In the past, the topcoat toners have included heavy metal pigments including lead, 

chromium, cadmium, and others. In recent years, however, most paint suppliers have begun 

removing the heavy metal pigments from the toners and substituted them with organic pigments. 

In some cases, the supplier will offer both a conventional and a metal-free version of a toner or 

other coating. New car and light truck manufacturers have also switched to metal-free topcoat 

colors, so differences in color match between the refinish coatings and the OEM finishes has 

been minimized. The differences will continue to decrease in importance as older vehicles with 

metal-pigmented topcoats are retired from the fleet. 

Shops that use a narrow range of colors, such as a mobile equipment maintenance facility 

or a school bus garage, will usually order colors pre-mixed from their supplier. Small autobody 

repair shops and restorers will also generally order pre-mixed topcoats from local automotive 

paint distributors to match each automobile. 

Most collision repair and production shops, on the other hand, mix their own colors from 

toners and binders using a mixing station. A mixing station typically consists of a computer or 

microfiche reader that contains the coating manufacturer's mixing instructions for each of several 

thousand colors and a digital scale for accurately measuring coatings. The mixing instructions 

are matched to a make and model of vehicle and a color code usually found on the vehicle. 

Shops that mix their own colors typically stock about 30 to 60 colored toners, from which almost 
0223-00-008\Refinish Process Summary 7

any original equipment manufacturer (OEM) color can be produced. The toners, mixing, 

instructions, and scale are usually located in a dedicated room adjacent to the paint booth. 

The color formulas are determined by the coating supplier and specify how much of each 

toner (measured to the nearest 0.1 gram) is added to get a pre-determined volume of coating of a 

certain color. Precision formulation is critical because a deviation of even 0.1 gram may result in 

an unacceptable color match with the rest of the vehicle. 

Although refinish coating formulations are developed for each OEM color, there is often 

variability in the shade color, which requires the painter to make adjustments to the formula. A 

few shops have recently begun using a digital color matching tool to measure the color of each 

section of the car and identify the formula for the closest match to that car. This tool is 

particularly helpful for older cars where the finish has faded. Because of the difficulty of 

matching certain colors, the painter must sometimes refinish more of the automobile rather than 

just the damaged portion. This, of course, increases coating usage. 

Shops that mix their own coatings strive to mix as little as possible to complete a job, but 

always with a slight excess to ensure that enough is available to complete the job and enough to 

be within the precision limits of the mixing station. By minimizing the excess, the shop 

minimizes the cost of materials and the amount and cost of hazardous coating waste disposal. 

Different mixing systems provide different flexibility to the user and can also facilitate 

recordkeeping. Some computer and all micro-fiche based mixing systems only provide 

information on how to mix specific colors and do not record any data for the user. Other mixing 

systems can print out a record of the coating that was mixed indicating the formula and amount 

of coating mixed. The simplest systems will usually only provide the formula to mix colors in 

pints or quarts. 

The more sophisticated computer systems can also be used to mix intermediate coating 

volumes and not just pints or quarts, based on the painter=s judgement in how much is needed for 

a certain job. A painter could decide to mix only a few ounces for a small spot repair or a larger 

amount for a major refinishing. Some systems can also specify how a painter can correct if too 

much of one toner is added. These two features help eliminate waste paint and minimize coating 

costs. 

The most sophisticated mixing systems will even hold the can of toner and control the 

actual pouring of toner into the mixing cup. As the toner amount reaches the specified weight, 

the pour is automatically adjusted to a thin stream and finally stopped at the precise amount. 
0223-00-008\Refinish Process Summary 8

The more sophisticated computer mixing systems that integrate an electronic balance and 

the computer can record how much material is mixed and can also automatically calculate and 

record the amount of VOC that are contained in the coatings. These can be used for all coatings 

and not just the colored coats, as long as everything that is applied is weighed on the scale and 

entered into the computer. This is a useful feature in areas subject to limits on daily or annual 

VOC emissions. 

Waterborne Basecoats

Several companies have introduced waterborne, low-VOC base coats that can be used on 

spot repairs or complete paint jobs. Coating refinish suppliers generally believe that it is more 

feasible to develop a waterborne base coat and than a waterborne clear coat. This strategy 

preserves the durability of the clear coat to protect the base coat and underlying primers. 

Shop conditions and equipment may need to be adjusted and some painter training is 

needed to use waterborne base coats. Waterborne base coats require larger volumes of warm, 

dry air for drying compared to solventborne base coats. Shops may need to increase the air flow 

rate and temperature in their spray booths to use waterborne coatings. For spot repairs, localized 

air blowers may be used to dry a base coat before the clear coat is applied. Guns used to apply 

waterborne base coats must be cleaned with water and alcohol. They cannot be cleaned in the 

same gun cleaner as solventborne coatings since solvents will cause the coating to harden instead 

of dissolve. 

Topcoat Application

If a shop has a spray booth, nearly all top coat application is performed in the spray booth 

to prevent contamination of the final finish. If a sealer is being applied, it is also usually applied 

in the booth immediately before the top coat. Some less visible areas of the car, such as the 

underside of the hood and trunk lids and the door jambs, may be painted outside of the booth (a 

process known as jambing). 

If a single stage topcoat is applied, two or three coats are applied and the paint is cured 

for 20 to 40 minutes while the vehicle is still in the booth. 

With a two-stage system, two or three coats of basecoat are applied, the paint is cured for 

20 to 40 minutes, two or three coats of clear coat are applied, and the clear coat is cured for an 
0223-00-008\Refinish Process Summary 9

additional 30 to 60 minutes. The application of three-stage systems is similar to that of twostage systems with a drying period between the application of each stage. 

If the shop has a heated spray booth, the temperature of the booth is increased to promote 

curing. Heating the booth also decreases the viscosity of the coating so that it flows more easily 

as it cures to create a smooth finish. At production shops, there is often a separate heated curing 

oven after the booth. The vehicle is moved to the curing oven to free up space in the booth for 

the next vehicle. 

When only part of a vehicle has to be refinished, the colored base coat and clear coat 

need to be blended into the existing finish to help hide any difference in color. For example, if a 

front fender is refinished, the color will be blended with the adjacent door and the hood. To 

blend in the color, the door and hood would not be masked during spraying. The door and hood 

surfaces would have been sanded and then prepped to promote adhesion. The painter would 

spray the front fender with the base coat and then also spray the edges of the door and hood so 

there is a gradual transition between the new and existing paint. The painter would then apply a 

full layer of clear coat over all three panels (the fender, door, and hood). The clear coat is not 

feathered out in the middle of the door or hood panels because the thin edge of the clear coat 

layer would weather more easily and quickly become visible. 

After the coating has cured, the vehicle is removed from the spraybooth and the masking 

materials are removed. 

Vehicle finishes are generally not completely smooth and most exhibit different amounts 

of surface texture called Aorange peel,@ since it resembles the rippled skin of an orange. A skilled 

painter can adjust the viscosity of the coating and spray technique to achieve different amounts 

of texture. Often, the refinished area is lightly sanded and then buffed back to a gloss so that the 

texture of the refinished area matches the texture of the rest of the car. 

2.0 COATING EQUIPMENT

Coating application equipment generally includes preparation stations, spray booths, 

spray guns, and spray gun cleaning equipment. 

Preparation Stations

Preparation of the surface for repainting, including sanding and application of the primer, 

usually are done in open areas of the shops or a curtained-off Aprep station@ equipped with 
0223-00-008\Refinish Process Summary 10

ventilation to control sanding dust and coating over-spray. Ventilation of prep stations may 

include exhaust air filters along the building wall, in the floor, or in both the ceiling and floor. 

Some shops use wet sanding and wash down the floors to control sanding dust, either in place of 

or in addition to filters. 

Priming is typically also done in a prep station, although many shops also prime inside a 

spray booth. This could be either the same spray booth as for applying top coat, or in a dedicated 

priming booth. Many prep stations are equipped with portable infrared heating units to facilitate 

drying during cool or humid shop conditions. 

Applying top coat to the door jambs and the underside of hoods and trunk lids (also 

known as jambing) is typically done in the same area as priming, either in a prep station or a 

jambing or priming booth. 

Spray Booths

Spray booths are clean, well-lit, and well-ventilated enclosures for coating operations. 

The primary purpose of the booth is to exhaust flammable vapors from the work area to avoid a 

fire or explosion hazard. They also minimize the presence of dust or paint over-spray that may 

settle on the coating while drying and mar the finish. Booths, especially those that are heated, 

also greatly reduce drying times. Because of their longer drying times, enamel, waterborne, and 

urethane coatings are best applied in a spray booth to minimize the possibility of dust adhering to 

the wet coating. Finally, spray booths also prevent the spread of paint over-spray to other parts 

of the shop. 

A good spray booth is considered by most industry members to be very important to 

running a profitable collision repair and refinishing business by helping to ensure a good quality 

finish. Therefore, the majority of autobody and mobile equipment refinishers use spray booths, 

although it is difficult to determine the exact fraction of shops that have them. Even so, there are 

many small shops and hobbyists that do not use a booth. As the refinish industry continues to 

move toward slower-drying, high-solids paints, more shops that do not already have spray booths 

are likely to purchase them. 

Small shops or hobbyists that do not use a permanent booth will sometimes construct a 

temporary enclosure from plastic sheeting. Alternatively, they may simply clean an area of the 

shop and wet down the floor and walls to control dust during the spraying operation. 
0223-00-008\Refinish Process Summary 11

Some shops have constructed their own permanent booths. The quality and safety of 

these home-made booths is probably highly variable. Some are probably as efficient and safe as 

manufactured booths, but many others are probably not. Safe booth construction and operation 

is governed by the Occupational Safety and Health Administration (OSHA) and by National, 

State, and local building, fire, and electrical codes. 

Construction or installation of a permanent paint booth may also be subject to State and 

Federal regulations controlling the construction and operation of an air emission source. Some 

states do not regulate the construction and operation of a spray booth used for smaller operations 

if it meets certain criteria regarding the maximum amount of coating used per month or year. 

After the vehicle enters the booth, all doors and openings to the booth are closed. Air is 

drawn into the booth through filters to assure a flow of clean air past the vehicle being painted. 

Filters on the air exhaust from the booth remove coating over-spray from the exhaust air. 

Filtration in a paint spray booth can be either dry filtration or wet filtration. Wet filtration is 

often called a water-wash filter system. Dry filters are the more common type for vehicle 

refinishing, although wet filtration is often used in production settings because it can handle a 

higher paint loading. However, wet-filtration booths are more costly to build and maintain. 

Both types of filters only remove coating solids; they do not reduce VOC emissions to the 

atmosphere. 

Three types of spray booths are used in the refinish industry: crossdraft, downdraft, and 

semi-downdraft. In each type of design, spray booths can be operated either at positive or 

negative pressure relative to the air in the shop. Under negative pressure, air tends to be pulled 

into the booth; under positive pressure, air tends to be forced out of the booth. Some booths 

operate at a slightly positive pressure so that air is forced out of the booth and dirt from 

surrounding areas is not sucked into the booth. In some cases, fans are used at both the inlet and 

outlet of the booth to create a balanced air flow and little pressure difference relative to the rest 

of the shop. 

In the crossdraft booth design, incoming air is pulled into the booth through filters 

located in the entrance door. The air travels along the length of the vehicle and then passes 

through particulate filters at the opposite end, where coating over-spray is removed. The air 

then exits through an exhaust stack, carrying with it any solvent vapors or other VOC's. Cross 

draft booth designs are generally the least expensive to purchase and install. A cross draft booth 

can be disassembled and moved if a shop has to relocate. 
0223-00-008\Refinish Process Summary 12

 In a downdraft booth, the air is pulled in through filters in the roof, travels down over the 

top of the automobile, picks up coating solvent and over-spray, and passes into a grate-covered 

pit in the floor of the booth. Downdraft booths are considered state-of-the-art because they 

provide the cleanest drying/curing environment. Specifically, the air flow in downdraft booths is 

less turbulent, which minimizes the mixing of over-spray with air in the rest of the booth. In 

addition, air circulation is more uniformly concentrated around the automobile and solvent vapor 

and over-spray are quickly drawn down and away from the painter and the surface being painted. 

Downdraft designs are generally the most expensive to purchase and install because of the need 

for a pit in the floor of the shop. The use of a pit also makes it difficult to move a downdraft 

booth if a shop relocates. 

The semi-downdraft spray booth is a compromise between cross-draft and downdraft 

designs. Air enters the booth through the ceiling and is discharged either through the back of the 

booth or through panels along the bottom of each side of the booth. It provides some of the 

advantages of a the improved flow of a down-draft booth, but does not require a pit in the shop 

floor. 

In order to decrease the drying time after coating application, many shops with spray 

booths, particularly downdraft booths, heat the air entering the booth. Shops may use small, 

portable, infrared heating units to warm metal surfaces prior to coating application or to speed 

the drying time of the repair. 

Spray Guns

Current practice in the refinish industry is to apply coatings with hand-held spray guns 

that use air pressure to atomize the coating. A key difference between the various types of guns 

available is their transfer efficiency. Simply defined, transfer efficiency is the ratio of the 

amount of coating solids deposited onto the surface of the coated part to the total amount of 

coating solids that exit the gun nozzle. Paint that is sprayed but not deposited onto the surface is 

referred to as "over-spray." Because coating over-spray releases the same relative amount of 

VOC from solvent as the coating that adheres to the vehicle, reducing over-spray reduces VOC 

emissions. By minimizing over-spray, potential emissions of paint solids, including heavy 

metals, are also reduced. 

Less over-spray also benefits the refinisher. Solvent concentration in the booth is 

reduced, less time is spent applying coatings (because more reaches the substrate), and solvent 
0223-00-008\Refinish Process Summary 13

use for cleanup of over-spray is reduced. Additionally, a shop that uses high-transfer efficiency 

spray equipment uses less coating, and therefore will also realize a savings in coating costs. The 

transfer efficiency of spray guns vary dramatically depending on a number of factors, such as the 

shape of the surface being coated, type of gun, velocity of the aerosol, skill and diligence of the 

operator, and extraneous air movement within the spray booth. 

Conventional Spray Guns. Conventional spray guns, also known as suction-feed, are 

becoming obsolete in the auto refinishing industry, although they are still commercially 

available. These guns employ a rapid flow of air through an air line and spray gun to create a 

vacuum which draws the coating from a cup mounted on the spray gun and forces it through the 

gun nozzle. Conventional spray guns operate in air pressure range of 30 to 90 pounds per square 

inch (psi). There are two types of conventional spray guns: syphon-feed and gravity-feed. In 

syphon-feed guns, the paint cup is attached below the spray gun, and the rapid flow of air 

through the gun creates a vacuum that siphons the coating out of the cup. Gravity-feed guns 

have the paint cup attached above the gun. These guns require less air pressure to move the 

coating through the gun and provide substantially better transfer efficiency than syphon-feed 

guns. 

High-Volume, Low-Pressure Spray Guns. High-volume, low-pressure (HVLP) spray 

guns use large volumes of air at low pressure (10 psi or less) to atomize coatings. Because the 

atomized spray leaves the gun at a lower pressure and velocity than in conventional air spraying, 

HVLP guns minimize particle "bounce back." As a result, high transfer efficiency can be 

achieved, with 25 to 50 percent less over-spray than conventional guns. All the shops visited 

during this project were using only HVLP spray guns and industry sources have estimated that 

these types of guns are now used for over 90 percent of automobile and mobile equipment 

refinishing. 

The air source in an HVLP spray system can be a turbine or conventional compressed air. 

Either system can be purchased to handle multiple spray guns. HVLP spray systems can be 

adjusted to apply high-, medium-, and low-solids coatings. 

The painters that were consulted during this project all indicated that learning to use an 

HVLP spray gun took some time, but the benefits of lower coating consumption made up for the 

training required. No painters indicated that HVLP spray guns resulted in coating problems that 

could not be overcome or in reduced finish quality. 
0223-00-008\Refinish Process Summary 14

Low-Volume, Low-Pressure Spray Guns. Low-volume, low-pressure (LVLP) spray guns 

are quite similar to HVLP spray guns in that atomized coatings are released at lower pressure 

(9.5 to 10 psi) and lower velocity than conventional air spray guns. The transfer efficiency of 

LVLP spray guns is reportedly about the same as for HVLP spray guns. The primary difference 

is that LVLP guns use 45 to 60 percent less air for paint atomization. Consequently, energy 

costs for air compression are less than with HVLP guns. 

Equipment Cleaning

Spray equipment can be cleaned manually or with any of several types of gun cleaning 

systems specifically designed for this purpose. Shops that do not have spray gun cleaning 

systems usually rinse the outside of the gun and cup, add solvent to the cup, and then spray the 

solvent into the air or into a drum set aside for spent solvent. None of the shops visited in this 

project used this technique and all had some sort of enclosed or automatic spray gun cleaner. 

A typical enclosed gun cleaner consists of a basin similar to a sink in which the operator 

washes the outside of the gun under a solvent stream. The basin is covered with a lid when it is 

not in use. The gun cup is filled with solvent, the gun tip is placed into a canister attached to the 

basin, and suction draws the solvent from the cup through the gun. The operator then removes 

the cup, places the gun's suction stem under the clean solvent spigot, pulls the trigger, and pumps 

solvent through the gun. The solvent gravitates to the bottom of the basin and drains through a 

small hole to a reservoir that supplies solvent to the recirculation pump. The solvent is changed 

when it no longer cleans satisfactorily. 

An automatic gun cleaner or washer consists of a basin with a tightly fitting lid and with 

cleaning solvent connections inside the basin. The spray gun is attached to the solvent 

connections, the lid is closed, and solvent is automatically pumped both through the gun and 

onto the exterior of the gun. The paint cup is also placed in the cleaner, where the interior and 

exterior are sprayed with solvent. 

Many automatic gun cleaners are capable of cleaning two guns and cups per cleaning and 

are typically designed to clean other equipment such as paint stirrers and strainers. Often they 

also have a solvent spigot to manually rinse spray equipment. Cleaning solvent falls back into 

the cleaner's solvent reservoir for recirculation. Solvent is recirculated until it is too 

contaminated for further use. Some enclosed gun cleaners are equipped with a second solvent 

reservoir that contains virgin solvent that is used as a final rinse. 
0223-00-008\Refinish Process Summary 15

Waste solvents generated by spray equipment cleaning are disposed of by evaporation 

(via spraying into the air, or by placing in open drums), off-site recycling or disposal, or by onsite reclamation. No shops that were visited during this project disposed of solvent by 

evaporation. All either used an off-site disposal service or used on-site reclamation. Very often 

the same vendor for the gun cleaner also picks up spent solvent and provides clean solvent on a 

regular basis. 

In-house recycling can be as simple as letting spent solvents settle and decanting the 

upper layer for reuse. This method, gravity separation, is used where the purity of the solvent is 

not critical and is employed in most cases where a site does not have on-site distillation 

equipment. The recovered solvent is usually used for the initial spray gun cleaning and a small 

amount of virgin solvent is used each time for a final rinse. 

At least one site visited during this project had an automatic gun cleaner that was tied into 

a on-site distillation system. The distillation system accepted solvent from the gun cleaner and 

also waste paint. After work hours, the system was timed to heat the waste paint and solvent and 

distill the evaporated solvent so it could be used again the gun cleaner. The remaining solids 

from the waste paint and spent solvent were disposed of as hazardous waste. This system greatly 

reduced the amount of new solvent consumed by the shop and the amount of hazardous waste 

(and associated fees). 

Care must be taken when a solvent reclaim unit is to be placed in use because solvents 

are combustible. In addition, some on-site reclaimers are not explosion-proof and may pose a 

hazard when operated near other non-explosion-proof electrical equipment. It is recommended 

that reclaim equipment be operated outdoors and away from spark-producing equipment, and 

that the power is turned off when the machine is being emptied. 

The use of solvent for gun cleaning can reportedly be reduced by using Teflon7-lined 

paint cups, which makes paint removal easier. Some facilities use a plastic liner inside the paint 

cup to make cleanup easier and reduce solvent use. The paint-covered plastic liner is discarded 

after each use and the paint cup remains essentially free of paint. 

3.0 RECORDKEEPING PRACTICES 

Most of the shops visited in this project were in California and subject to local and 

regional air district regulations limiting VOC emissions. As a result, all had to keep records to 

demonstrate compliance with VOC content limits for each coating and with monthly limits on 
0223-00-008\Refinish Process Summary 16

the total amount of VOC emitted. Usually, one set of records was used to demonstrate both 

compliance requirements. As mentioned in section 1.7, some shops were able to use their 

computerized paint mixing system to help them record the amount of VOC in the coatings in 

each job. 

To demonstrate compliance with VOC coating limits, most shops recorded the amount of 

material used for each job on a sheet provided by their coating supplier. The sheets also showed 

the maximum relative amount of coating, reducer, activator, etc., that can be used for each 

product to maintain compliance with specific VOC limits. 

Often, the same sheets were also used to calculate total monthly VOC emissions since 

they showed the amount of coating used per job. Many shops used a service called Phone-In 

Record Keeping, Inc. (PIRK). The shop would fax in the VOC sheets that they completed for 

each job and PIRK would then calculate their monthly VOC emissions and deliver a monthly 

report to the shop. The VOC sheets and reports were typically kept in a binder provided by 

PIRK. The estimated cost for the PIRK service was about $80 per month. 
3.0 

Analysis of Generally Available Control Technology (GACT) for Motor Vehicle and 

Mobile Equipment Refinishing Operations at Area Sources Subject to the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Surface 

Coating Area Sources 
0223-00-008\Auto Refinish GACT memo 1

MEMORANDUM 

To: Docket EPA-HQ-OAR-2005-0526 

From: Brian Palmer, Eastern Research Group, Inc. (ERG) and Warren Johnson, U.S. 

EPA, Sector Policies and Programs Division/Natural Resources and Commerce 

Group 

Date: August 7, 2007 

Subject: Analysis of Generally Available Control Technology (GACT) for Motor Vehicle 

and Mobile Equipment Refinishing Operations at Area Sources Subject to the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Miscellaneous Surface Coating Area Sources 

 

The EPA visited over 20 motor vehicle and mobile equipment (MVME) refinishing 

operations and held about 10 meetings and conference calls with industry representatives, 

including trade association representatives and groups of refinishing shop owners. The EPA also 

met four times with representatives of State Small Business Assistance Programs. These visits 

and meetings were documented in memoranda that are included in the docket for the proposed 

rulemaking. The purpose of this memo is to summarize the information collected and present a 

recommendation for the determination of GACT for MVME refinishing operations. 

For the MVME refinishing operations GACT is the use of spray booths and high-volume, 

low-pressure (HVLP) spray guns, along with painter training as a management practice, to 

reduce inorganic HAP emissions from surface coating operations. GACT also includes the use 

of enclosed spray gun washers to reduce emissions from paint spray gun cleaning operations. 

 The hazardous air pollutant (HAP) emissions from MVME refinishing operations come 

primarily from the spray application of coatings. Although most of the HAP are deposited as 

part of the paint film, some of the HAP becomes airborne in the paint overspray. The volume of 

coating deposited as part of the paint film as a fraction of the volume of paint sprayed is referred 

to as the transfer efficiency (for example, if 60 percent of the coating sprayed is deposited as 

paint film then the transfer efficiency is 60 percent). 

Analysis of operations that involve the spray application of coatings has determined that 

GACT for these coating operations is a combination of: 1) confining all spray coating operations 

to a spray booth or equivalent ventilated and filtered enclosure, 2) using only spray equipment 

that is designed to achieve a high rate of transfer efficiency (HVLP or equivalent spray 
0223-00-008\Auto Refinish GACT memo 2

technology), and 3) having the spray equipment operator trained and certified in the techniques 

needed to properly set up and operate high transfer efficiency spray equipment in order to 

optimize the transfer efficiency. 

Based on the site visits, data review, and contacts with industry, we have determined that 

the standard practice among the majority of facilities in the MVME refinishing industry is to 

perform nearly all spray painting inside a spray booth or ventilated prep station enclosed by 

curtains. The only exceptions are priming small areas, or performing spot repairs with an air 

brush. At many facilities, all spray painting is performed in a spray booth or ventilated prep 

station to reduce contaminants that would compromise the final finish and to maintain a clean 

work area. In addition, it is standard practice to filter the exhaust from the booth or prep station 

to capture paint overspray so that it is not deposited on ventilation equipment or surrounding 

property. Therefore, based on the availability and cost-effectiveness, EPA has determined that a 

filtered spray booth or prep station is GACT for all MVME refinishing operations to control 

HAP emissions. It is important to note that filtered spray booths or prep stations are needed at 

almost all spray finishing operations in order to comply with OSHA standards for spray finishing 

operations (29 CFR 1910.94(c)). 

At the majority of facilities that were visited, the spray booths were fitted with either 

fiberglass or polyester fiber filters on the spray booth and prep station exhaust. One facility had 

a water-wash spray booth filter and another had expanded polystyrene foam baffle filters. An 

EPA study entitled “Comparative Study of Spray Booth Filter System Efficiency”, which is 

provided in the public docket for this rulemaking, determined that fiberglass and polyester fiber 

filters had superior performance, relative to other filter types, such as polystyrene foam and 

cardboard baffle filters, in controlling the heavy metals found in paint overspray. The 

information collected on filter efficiency is summarized in a separate memo for the docket.1 

Therefore, based on findings during the site visits, information provided by the industry on the 

most commonly used filters, and the EPA study on filter effectiveness and the cost-effectiveness 

EPA has determined that these fiberglass and polyester fiber filters represent GACT for 

controlling the heavy metals present in paint overspray. 

 

1 Memorandum To: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural Resources and Commerce 

Group (C539-03). From: Mike Heaney and Brian Palmer, Eastern Research Group, Inc. March 26, 2006. Review 

of Spray Booth Filter Information for the Area Source Motor Vehicle and Mobile Equipment Refinishing National 

Emission Standards for Hazardous Air Pollutants (NESHAP). 
0223-00-008\Auto Refinish GACT memo 3

An alternative 98-percent filter efficiency could be provided for those sources that may 

not be using fiberglass or polyester fiber filters. We were not able to collect filter efficiency data 

on all types of filters used in spray booths, and the market may already provide for filters that are 

as equally efficient. The 98-percent filter efficiency alternative is based on a summary of filter 

efficiency data provided by filter vendors.

1

This limit would represent the performance level that 

separates the fiberglass and polyester fiber filters from baffle type filters. The baffle type filters 

were shown in the EPA study to have poor performance in controlling fine particulate that can 

contain heavy metals. 

GACT includes spray equipment that is designed to achieve a high rate of transfer 

efficiency (HVLP or equivalent spray technology) in order to reduce the overall amount of 

coating required to complete each coating job. Reducing the amount of coating required for each 

job would directly lead to significant reductions in the overall emissions from these coating 

operations. Conventional high-pressure air-atomized spray guns have a typical transfer 

efficiency of about 30 percent. That means that for every gallon of coating sprayed, only 0.30 

gallon reaches the part being coated. The remaining 0.70 gallon misses the part and either lands 

on the booth walls and floor or is pulled into the spray booth filters and exhaust system. To get 

one gallon on the part, a conventional spray gun needs to use 3 1/3 gallons of coating. HVLP 

and other types of high-efficiency spray guns use lower air pressures and achieve transfer 

efficiencies of about 50 percent, or greater, with appropriate operator training. To get one gallon 

on the part, a high efficiency spray gun needs to use only 2 gallons of coating. This increased 

transfer efficiency represents a 40 percent decrease in coating consumption and in resultant 

emissions compared to conventional spray guns. 

For these reasons, all of the MVME refinishing operations visited by EPA had already 

switched to HVLP and other types of high efficiency spray guns. About half these sources were 

not required to do so by regulations and have switched in order to reduce coating costs through 

reduced consumption. Regulations for autobody refinishing in 10 States require the use of 

HVLP spray guns or their equivalent statewide, and they are required in ozone non-attainment 

areas in 12 States without a statewide requirement. Given the cost-effectiveness and the fact that 

HVLP or equivalent spray guns have been adopted at the facilities visited by EPA and they are 

required in many States and ozone non-attainment areas, these types of spray guns are GACT for 

spray-applied coatings. 
0223-00-008\Auto Refinish GACT memo 4

Painter training has also been shown to have a significant effect on the amount of coating 

needed and the amount of overspray per job and is a management practice to reduce emissions. 

Requiring spray painters to be trained and certified would ensure that painters are skilled in the 

techniques needed to achieve a high rate of transfer efficiency. Data collected by Spray 

Technique Analysis and Research (STAR®) programs in various states have shown that painter 

training can have a significant effect on the amount of coating used and the transfer efficiency of 

the coating operation. 

The training would include measures intended to increase transfer efficiency and reduce 

overspray and coating usage. The best known of these training programs is the STAR® program 

that originated at the University of Northern Iowa Waste Reduction Center and has now been 

adopted at 37 locations (primarily community colleges) throughout the United States.

2

 Data 

from the STAR® program demonstrate that spray operator training can increase transfer 

efficiency for those using high efficiency spray equipment from an average of about 50 percent 

to 60 percent, or more, representing a 20 percent reduction in coating usage compared to 

untrained operators. This 20 percent reduction in coating usage would translate into a 20 percent 

reduction in emissions of organic HAP that are contained in those coatings. It would also reduce 

emissions of the heavy metals that are in the coatings. 3,4,5

It is important to note that these “untrained” operators are not inexperienced painters. 

They often have many years of experience before they enter these training programs. However, 

they have not been specifically trained in how to best set up and operate high efficiency spray 

equipment and to optimize their technique to maximize transfer efficiency and minimize coating 

consumption. 

About 3,500 painters have already completed STAR® training and at least one company 

operating multiple collision repair shops has established a STAR®-based in-house training 

 

2

Spray Technique Analysis and Research (STAR) School summary. Provided by Sue Schauls, STAR Program 

Manager, Iowa Waste Reduction Center, July 21, 2006. 

3 www.iwrc.org/staruserqueries/avg_of_all_trainees.cfm Summary of IWRC STAR training program. The average 

reduction in gallons of coating used for 382 students trained in the Iowa Waste Reduction Center STAR program 

was 18.55 percent. 

4

http://www.arb.ca.gov/coatings/p2/results.htm Five California body shops had their painters complete a STAR® 

training program. Paint usage decreased 3 to 45 percent after training. The average decrease in usage was 22 

percent. 

5

Final Report PennSTAR Project. Pennsylvania Spray Technique Analysis and Research. Pennsylvania College of 

Technology. May 2006. 
0223-00-008\Auto Refinish GACT memo 5

program. Since many painters already attend regular training sponsored by coating companies 

and trade organizations, these training programs are GACT for MVME refinishing operations. 

The proper training and certification for spray coating operators should be comparable to 

existing programs such as those offered by The Inter-Industry Conference on Auto Collision 

Repair (I-CAR) and the STAR®-based programs offered in various states. The essential 

elements of training and certification that would do the most to improve transfer efficiency and 

minimize emissions should include, at a minimum, include: 

• coating material handling, including spills and clean up, 

• substrate preparations that minimize over spray, 

• proper equipment selection and set-up to optimize transfer efficiency, 

• coating application and spray technique that minimizes over spray, 

• spray equipment cleaning and maintenance, and 

• operating and maintaining a spray booth. 

EPA has determined that GACT also includes that all spray gun cleaning be done in 

enclosed spray gun washers, or the disassembled spray gun should be cleaned by hand without 

the atomizing cleaning solvent. Spraying of cleaning solvent through spray guns outside of an 

enclosed gun washer would be prohibited. All of the facilities visited by EPA had enclosed gun 

washers and other contacts with industry members indicate that this is standard practice among 

well-controlled facilities. Therefore, an enclosed spray gun cleaner or hand cleaning is GACT 

for these source categories to reduce emissions from spray gun cleaning. 
4.0 

Analysis of Generally Available Control Technology (GACT) for Miscellaneous Plastic 

Part and Metal Part Surface Coating Operations at Area Sources Subject to the National 

Emission Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous 

Surface Coating Operations at Area Sources 
0223-00-008\Misc Surface Coating GACT memo 1

MEMORANDUM 

To: Docket EPA-HQ-OAR-2005-0526 

From: Brian Palmer, Eastern Research Group, Inc. (ERG) and Warren Johnson, U.S. 

EPA, Sector Policies and Programs Division/Natural Resources and Commerce 

Group 

Date: August 7, 2007 

Subject: Analysis of Generally Available Control Technology (GACT) for Miscellaneous 

Plastic Part and Metal Part Surface Coating Operations at Area Sources Subject to 

the National Emission Standards for Hazardous Air Pollutants for Paint Stripping 

and Miscellaneous Surface Coating Operations at Area Sources 

The purpose of this memo is to summarize the data available on the use of filtered spray 

booths and high efficiency spray guns at area sources performing miscellaneous surface coating 

operations. Our analysis of these data indicate that the use of a filtered spray booth and high 

efficiency spray equipment, e.g., high-volume low-pressure (HVLP) spray guns, could be 

considered to represent GACT to reduce both inorganic and organic HAP emissions from these 

area source surface coating operations. 

The analysis was completed in the MS Excel spreadsheet. The data for the GACT 

analysis was from the database developed to support the NESHAP for plastic parts and products 

surface coating operations at major sources (40 CFR 63, subpart PPPP). Data were available 

for surface coating operations that perform spray coating and these data indicated whether the 

spray operation was performed in a filtered enclosure, the type of filter, and what type of spray 

equipment was used. Similar data were not available from the database used to develop the 

NESHAP for miscellaneous metal parts and products surface coating operations at major 

sources (40 CFR 63, subpart MMMM). However, we believe that the plastic parts data are also 

representative of the area sources coating metal parts and products. 

The plastic parts and products database includes data for 238 facilities that perform a 

total of 978 surface coating scenarios using spray equipment. These 238 facilities include 126 

area sources representing 402 coating scenarios that use spray equipment (an average of 3.2 

coating scenarios per area source). The attached spreadsheet includes only data for area 

sources. The total number of area sources is estimated to be 831, but not all of these perform 

spraying, and not all sources submitted data on their coating operations. 
0223-00-008\Misc Surface Coating GACT memo 2

The control technologies considered to reduce inorganic HAP from spray coating 

operations are an enclosure, such as a spray booth, with filters fitted on the booth exhaust. The 

most common types of filters are dry filters, such as fiberglass or polyester fiber filters, or wet 

filters such as a water wash system spray booth. The dry filters are generally considered more 

efficient and reliable with lower maintenance than waterwash systems. Dry filters also do not 

create wastewater disposal issues. Dry filter systems can be more easily retrofitted to an 

existing spray coating operation without having to add water supply lines and drains. 

Waterwash systems are generally used in high-volume production settings to avoid having to 

frequently change filters. 

At area sources, 303 of the 402 surface coating scenarios (75 percent) use dry filters to 

control overspray. An additional 52 coating scenarios (13 percent) use waterwash type spray 

booths to control overspray. Therefore, the use of a dry filter or waterwash filter could be 

considered generally available control technology to control overspray that may contain 

inorganic HAP from spray coating operations at area sources. 

Organic HAP emissions can be reduced from spray coating operations by switching to 

more efficient spray gun types that reduce coating consumption by increasing the fraction of 

coating that reaches the part. The fraction of coating that reaches the part, instead of becoming 

overspray, is termed transfer efficiency. Conventional air atomized spray guns have a transfer 

efficiency of about 30 percent. High volume, low pressure (HVLP) spray guns, and other types 

of high efficiency spray guns, have transfer efficiencies that can exceed 50 percent. Therefore, 

switching to an HVLP spray gun could reduce the amount of coating needed for a certain job by 

30 to 40 percent and this would have a similar reduction in organic HAP emissions. 

The use of add-on controls to reduce organic HAP emissions, such as thermal oxidizers, 

is generally not feasible at area sources. Area source surface coating emissions are 

characterized by intermittent emissions with low organic concentrations and high flow rates. 

The high capital cost and operating cost of add-on controls would also put them out of the 

financial reach of most area source surface coating facilities. 

 Of the area source coating scenarios, 303 scenarios (75 percent) were using HVLP spray 

guns. This also represents 71 percent of the area source facilities. Only 25 area source 

facilities (20 percent of facilities) representing 75 coating scenarios reported using conventional 

high-pressure air-atomized spray guns. Three percent of area source facilities reported using 
0223-00-008\Misc Surface Coating GACT memo 3

either electrostatic, air assisted airless, or airless spray technology; one percent did not specify 

the spray technology. Therefore, the use of HVLP spray technology could be considered 

generally available control technology to reduce organic HAP emissions by reducing coating 

consumption in spray coating operations at area sources. 
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

ACS0001 Mitsubishi Motor MFG of America, INC 1 1 1 ACS0001 - Fascia Downdraft w/ water curtain Electrostatic Spray ES Fully enclosed CD001 Water curtain Water 1

ASC013 Subaru-Isuzu Automotive Inc. 1 1 1 ASC013 - Plastic Bumpers Multiple station Electrostatic Spray ES N/A Exhaust stacks Wet eliminator Water 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 MMP2154 - CK Truck Prime Line Primer booth Conventional Air Spray Conv Fully enclosed Building interior Dry filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1

MMP2154 - CK Truck Top Coat 

Line Top coat booth Conventional Air Spray Conv Fully enclosed Building interior Dry filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 MMP2154 - I/P Surlyn Cladding G-car Booth Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 MMP2154 - I/P Surlyn Cladding KSP Door Booth Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 MMP2154 - I/P Surlyn Cladding Module 1 Booth Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 MMP2154 - I/P Surlyn Cladding W-car Booth A Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

MMPP-2154

Delphi Interior & Lighting Systems, Vadalia 

Ops 1 1 1 MMP2154 - I/P Surlyn Cladding W-car Booth B Conventional Air Spray Conv 1 3/4 Enclosed Building interior Dry Filters Filter 1

PPP111A MSX International Special Vehicles - Mt. Elliot 1 1 1

PPP111A - Windshield frame 

coating scenario Spray Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Filters Filter 1 1 1

PPP111B

MSX International Special Vehicles - Lynch 

Rd 1

PPP111B - Prowler Coating 

Scenario Basecoat Booth Conventional Air Spray Conv Fully enclosed Building interior filters Filter 1

PPP111B

MSX International Special Vehicles - Lynch 

Rd 1

PPP111B - Prowler Coating 

Scenario Clearcoat Booth Electrostatic Spray ES Fully enclosed Building interior filters Filter 1

PPP111B

MSX International Special Vehicles - Lynch 

Rd 1 1 1

PPP111B - Prowler Coating 

Scenario Prime Booth Electrostatic Spray ES Fully enclosed Building interior filters Filter 1

PPP111C MSX International Special Vehicles - Purks 1 PPP111C - Interior Trim Refinish Down Draft Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior filter/waterwash Filter 1 1

PPP111C MSX International Special Vehicles - Purks 1 1 1 PPP111C - Vehicle Refinish Down Draft Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior filter/waterwash Filter 1 1 1

PPP111W MSX International - Mandoline 1 1 1

PPP111W - Prototype Coating 

Scenario Spray Booth Conventional Air Spray/HVLP Conv 1 Fully enclosed Building interior Filters Filter 1

PPP111X MSX International Design Fab Center 1 1 1

PPP111X - Prototype Coating 

Scenario Spray Booth Conventional Air Spray Conv 1 Fully enclosed Building interior Filters Filter 1

PPP114A ADAC Plastics Inc. - Saranac 1

PPP114A - Saranac 2 Booth Paint 

Line 1st booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Filters Filter 1 1

PPP114A ADAC Plastics Inc. - Saranac 1 1 1

PPP114A - Saranac 2 Booth Paint 

Line 2nd booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Filters Filter 1 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #1 Automatic booth Conventional Air Spray Conv 3/4 Enclosed Building interior Dry filters Filter 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #10 Rotary Conventional Air Spray Conv 3/4 Enclosed Building interior ry filters Filter 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #9 Stroker Conventional Air Spray Conv 3/4 Enclosed Building interior Dry filters Filter 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #3 Hand booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior ry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #4 Hand booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior ry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #5 Hand booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior ry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #6 Stroker

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #7 Rotary booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 PPP114B - Paint Booth #8 Rotary booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior ry filters Filter 1 1

PPP114B ADAC Plastics Inc. - Grand Rapids 1 1 1 PPP114B - Panit booth #2 Automatic booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filters Filter 1 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Clear Coat Clear booth #1

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Clear Coat Clear booth #2

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Clear Coat Clear booth #3

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Color Coat Color booth #1

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Color Coat Color booth #2

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Color Coat Color booth #3

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 PPP114C - Prime Booth 1st booth

High-volume low-pressure 

spray HVLP 1 Enclosed Control device Dry filters Filter 1 1

PPP114C ADAC Plastics, Inc. - Muskegon 1 1 1 PPP114C - Prime Booth 2nd booth

High-volume low-pressure 

spray HVLP 1 1 Enclosed Control device Dry filters Filter 1 1 1

PPP115A Prince Corp. Lakewood MFG 1 PPP115A - C/K Inline Painting Booths 1-3

High-volume low-pressure 

spray HVLP 1 65%, Hooded Atmosphere Dry Fabric Filter 1 1

PPP115A Prince Corp. Lakewood MFG 1 PPP115A - Central Gluing

High-volume low-pressure 

spray HVLP 1 3/4, Hooder Atmosphere Dry Fabric Filter 1 1

PPP115A Prince Corp. Lakewood MFG 1 PPP115A - Central Paint Booths 1-5

High-volume low-pressure 

spray HVLP 1 3/4, Hooded Atmosphere Dry Fabric Filter 1 1

PPP115A Prince Corp. Lakewood MFG 1 1 1 PPP115A - Vac Wrap Spray Glue Booths 1-4

High-volume low-pressure 

spray HVLP 1 1 3/4, Hooded Atmosphere Dry Fabric Filter 1 1 1

PPP115B Prince Corp. - Maplewood Facility 1 PPP115B - Glue Spray Booths Booths 1 & 2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filters Filter 1 1

PPP115B Prince Corp. - Maplewood Facility 1 1 1 PPP115B - Paint Spray Booths Booths 1-8

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry filters Filter 1 1 1

PPP115C Prince Corp. - Southview Campus 1 PPP115C - B-Van Base Booth 4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP115C Prince Corp. - Southview Campus 1 PPP115C - B-Van Components Booth 4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Fabric Filter 1 1

PPP115C Prince Corp. - Southview Campus 1

PPP115C - Console/ Console 

Parts/ DPTrim Booth 1-3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP115C Prince Corp. - Southview Campus 1 PPP115C - Ivory Door Skins Booth B

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Fabric Filter 1 1

PPP115C Prince Corp. - Southview Campus 1 1 1 PPP115C - Visor Components Booth 5 & 6

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry Fabric Filter 1 1 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP115C Prince Corp. - Southview Campus 1 PPP115C - Spray Gluing Booths 1-3

High-volume low-pressure 

spray HVLP 1 No enclosure Building interior NA

PPP117A Lescoa - Middleville Plant 1

PPP117A - Spray Adhesive 

Scenario Glue Booth Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filters Filter 1

PPP117A Lescoa - Middleville Plant 1 PPP117A - Clean Room Scenario Clean Room Booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Filters Filter 1 1

PPP117A Lescoa - Middleville Plant 1

PPP117A - Conveyor Line 

Scenario Booth L1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Filters Filter 1 1

PPP117A Lescoa - Middleville Plant 1

PPP117A - Manual Booth 

Scenario Booth 3B1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Filters Filter 1 1

PPP117A Lescoa - Middleville Plant 1 1 1 PPP117A - Vinyl Coating Scenario CAD Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed

Building 

interior/Atmospher

e Dry filters Filter 1 1 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Overhead Conveyor 

Scenario 7-3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Filters Filter 1 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Chain on Edge 

Scenario C-1

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD000001 Water wash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Chain on Edge 

Scenario C-2

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD000001 Water wash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Chain on Edge 

Scenario C-3

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD000001 Water wash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Rack Conveyor 

Scenario 7-1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Rack Conveyor 

Scenario 7-2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Rack Conveyor 

Scenario 7-4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP117C Lescoa - Plant # 7 1

PPP117C - Rack Conveyor 

Scenario 7-5

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP117C Lescoa - Plant # 7 1 1 1

PPP117C - Rack Conveyor 

Scenario 7-6

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP118E

Magna International - Brighton Interior 

Systems 1

PPP118E - GMT - 800 Fabrication 

Process N/A Conventional Air Spray Conv No enclosure Atmosphere Dry filter Filter 1

PPP118E

Magna International - Brighton Interior 

Systems 1 PPP118E - SSS<Paint Booth Booth 1 Conventional Air Spray Conv Fully enclosed Control device Dry filter Filter 1

PPP118E

Magna International - Brighton Interior 

Systems 1 PPP118E - SSS<Paint Booth Booth 2 Conventional Air Spray Conv Fully enclosed Control device Dry filter Filter 1

PPP118E

Magna International - Brighton Interior 

Systems 1 1 1 PPP118E - SSS<Paint Booth Booth 3 Conventional Air Spray Conv 1 Fully enclosed Control device Dry filter Filter 1

PPP123 H. A. Parts Products of Indiana Company 1 1 1 PPP123 - Spray Paint Application E-Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Hooded Filters/waterwash Filter 1 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Finish Room North line booth #1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Finish Room North line booth #2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Finish Room Off line booth

High-volume low-pressure 

spray HVLP 1 1/2 hooded Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Finish Room South line booth #1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Finish Room South line booth #2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 PPP126A - Robotic Line Enclosed booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP126A Leon Plastics, Inc. 1 1 1 PPP126A - Robotic Line Enclosed booth #2

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Dry filter Filter 1 1 1

PPP130 Cooper Automotive Co. 1 1 1

PPP130 - Base Coat and 

Aluminize Plastic Reflector Base coat spray Conventional Air Spray Conv 1 3/4 Enclosed Building interior Dry filter Filter 1

PPP131A Vaungarde, Inc. - Bradley 1 PPP131A - Rim Clearcoating Blu-Surf

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere

PPP131A Vaungarde, Inc. - Bradley 1 PPP131A - RIM Topcoating-A Blu-Surf

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere

PPP131A Vaungarde, Inc. - Bradley 1 PPP131A - Rim Topcoating-B Blu-Surf

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere

PPP131A Vaungarde, Inc. - Bradley 1 1 1

PPP131A - Urethane Part Coating 

Scenario-Prime Blu-Surf

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Atmosphere

PPP131B Vaungarde, Inc. - Chestnut 1 PPP131B - Plastic Auto Clearcoat Double Booth (3)

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1 PPP131B - Plastic Auto Prime Double Booth (3)

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1 PPP131B - Plastic Auto Prime-B Double Booth (3)

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1

PPP131B - Plastic Auto TopcoatA Double Booth (3)High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1

PPP131B - Plastic Auto TopcoatB Double Booth (3)High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1

PPP131B - Plastic Auto TopcoatC Double Booth (3)High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1

PPP131B - Plastic Auto TopcoatD Double Booth (3)High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter, training Filter 1 1

PPP131B Vaungarde, Inc. - Chestnut 1 1 1

PPP131B - Plastic Auto TopcoatE Double Booth (3)High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Atmosphere Filter, training Filter 1 1 1

PPP134 Grand Rapids Plastics, Inc. 1 1 1 PPP134 - Painting Parts Single spray booth Conventional Air Spray Conv 1 1/2 enclosed Building interior Filters Filter 1

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB001

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB002

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB003

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB004

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB005

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1

PPP137E U.T. Automotive - Alma Molding Plant 1

PPP137E - Dry Paint Booth 

Application PB010

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1

PPP137E U.T. Automotive - Alma Molding Plant 1 1 1

PPP137E - Dry Paint Booth 

Application PB011

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior

Dry filter Training (6 2'x2' 

filters) Filter 1 1 1

PPP138G

Textron Automotive Company - Port Huron 

Operations 1 PPP138G - Bolster Ahesive Line Adhesive Booth B-1

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Dry filter Filter 1 1

PPP138G

Textron Automotive Company - Port Huron 

Operations 1 PPP138G - Bolster Ahesive Line Adhesive Booth B-3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP138G

Textron Automotive Company - Port Huron 

Operations 1 PPP138G - Paint Line Paint Booth C-1

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Dry filters Filter 1 1

PPP138G

Textron Automotive Company - Port Huron 

Operations 1 1 1 PPP138G - Vac-form Adhesive Adhesive Booth A-1

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1 1

PPP144A Collins & Aikman Plastics, Inc - Homer Plant 1

PPP144A - F-Car Bolster Hot Melt 

Application x-y table Air-assisted airless spray AAAS No enclosure Building interior Op. Training

PPP144A Collins & Aikman Plastics, Inc - Homer Plant 1

PPP144A - GMT 430 Armrest 

(Left & Right) Glue booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filter/Training Filter 1 1

PPP144A Collins & Aikman Plastics, Inc - Homer Plant 1 1 1

PPP144A - G-Van Map 

Compartment Paint Line G-Van spray booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Atmosphere Filters/training Filter 1 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1 PPP144B - Ford Defroster Grill System 4 booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Atmosphere Filter/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1 PPP144B - K-Special Glue Line System 3 booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1 PPP144B - K-Special Paint Line

System 1 Booth A (see Form 

J)

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1 PPP144B - K-Special Paint Line

System 1 Booth B (see Form 

J)

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1

PPP144B - K-Special Small Parts 

Line System 2 Backup

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1

PPP144B - K-Special Small Parts 

Line System 2 Booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/training Filter 1 1

PPP144B

Collins & Aikman Plastics, Inc - Manchester 

Plant 1 1 1 PPP144B - ZJ Door Panel ZJ Spray booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Atmosphere Filters/training Filter 1 1 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Solvent Base 

Coating, Booth 1-A Chain on edge 1-A Conventional Air Spray Conv Fully enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Solvent Base 

Coating, Booth 2-B Booth 2-B Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Solvent Base 

Coating, Booth 3-D Booth 3-D Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Solvent Base 

Coating, Booth 5-E-F Booth 5-E-F Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Solvent Coating, 

Booth 9-C Booth 9-C Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Waterborne Coating, 

Booth 2-B Booth 2-B Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1

PPP144C - Waterborne Coating, 

Booth 3-D Booth 3-D Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144C Collins & Aikman Plastics, Inc. - St. Joseph 1 1 1

PPP144C - Waterborne Coating, 

Booth 9-C Booth 9-C Conventional Air Spray Conv 1 3/4 Enclosed Atmosphere Dry filter/training Filter 1

PPP144D

Collins & Aikman Plastics, Inc. - Williamston, 

Noble Rd 1 PPP144D - K-Special Bolster Bolster Spray Booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters/Training Filter 1 1

PPP144D

Collins & Aikman Plastics, Inc. - Williamston, 

Noble Rd 1 1 1 PPP144D - K-Special Map Pocket Map Pocket Spray Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Filters/Training Filter 1 1 1

PPP145 Atlantic Automotive Components 1 1 1 PPP145 - Painted Plastic Parts Booth 1

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Water Wash Water 1

PPP149 Grand Haven Plastics, Inc. 1

PPP149 - Waterborne (Single 

coat) System Booth 1 thru 6

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters Filter 1 1

PPP149 Grand Haven Plastics, Inc. 1 1 1

PPP149 - Waterborne (Single 

coat) System Booth 7 (recip)

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Filters Filter 1 1 1

PPP151 GHSP - Hart 1 1 1

PPP151 - Water-based Paint 

Application Thermoplastic

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Control device 2 Dry filters Filter 1 1 1

PPP151 GHSP - Hart 1

PPP151 - Water-based Paint 

Application Binks Paint Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Control device Dry filter Filter 1 1

PPP153

Marathon Ashland Petroleum LLC - Findlay, 

OH Garage 1 1 1

PPP153 - Truck/Trailer Body 

Painting Paint Booth Conventional Air Spray Conv 1 Fully enclosed Building interior Paper filters Filter 1

PPP209B Pitney Bowes - Milford 1 1 1

PPP209B - Coating of copier 

covers Binks Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Control device Dry filter Filter 1 1 1

PPP209C Pitney Bowes - Newton 1 1 1

PPP209C - - Aerosol Spray Can 

Application

single booth exists for coating 

of parts Conventional Air Spray Conv 1 3/4 Enclosed Building interior Dry filter overspray control Filter 1

PPP248 Hitemco 1 PPP248 - Copper Coating Waterwash exhaust Arc Spray (zinc arc) 3/4 Enclosed CD000001 Waterwash Water 1

PPP248 Hitemco 1 1 1 PPP248 - Zinc Coating

Zinc Booth (Water Wash 

Exhaust) Arc Spray (zinc arc) 3/4 Enclosed CD000001 Waterwash Water 1

PPP305D Hasbro, Inc. 1 PPP305D - ABS Coating Sample dept. booth #1 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - ABS Coating Sample dept. booth #2 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - ABS Coating Sample dept. booth #3 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Polypropylene Coating Sample dept. booth #1 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Polypropylene Coating Sample dept. booth #2 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Polypropylene Coating Sample dept. booth #3 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Styrene Coating Sample dept. booth #1 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Styrene Coating Sample dept. booth #2 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Styrene Coating Sample dept. booth #3 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Vinyl Coating Sample dept. booth #1 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 PPP305D - Vinyl Coating Sample dept. booth #2 Conventional Air Spray Conv Hooded Building interior Dry filter Filter 1

PPP305D Hasbro, Inc. 1 1 1 PPP305D - Vinyl Coating Sample dept. booth #3 Conventional Air Spray Conv 1 Hooded Building interior Dry filter Filter 1

PPP305E Hasbro, Inc. - Hasbro Games 1 1 1 PPP305E - - Sample Painting Small Vented Booth Conventional Air Spray Conv 1 3/4 Enclosed Atmosphere Dry filters Filter 1

PPP306 Regal Finishing, Inc. 1

PPP306 - Drapery Decorative 

Coating Booth #2

High-volume low-pressure 

spray HVLP 1 1/2 Enclosed Building interior Water Curtain Water 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP306 Regal Finishing, Inc. 1

PPP306 - Drapery Decorative 

Coating Booth #4

High-volume low-pressure 

spray HVLP 1 1/2 Enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1

PPP306 - Drapery Decorative 

Coating Booth #8

High-volume low-pressure 

spray HVLP 1 1/2 Enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - High Heat 300-325 F Booth #2

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Builiding interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - High Heat 300-325 F Booth #4

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Builiding interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - High Heat 300-325 F Booth #8

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Builiding interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - Low Heat 150-165 F Ring Machine 1

High-volume low-pressure 

spray HVLP 1 1/2 Enclosure Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - Low Heat 150-165 F Ring Machine 2

High-volume low-pressure 

spray HVLP 1 1/2 Enclosure Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - Low Heat 150-165 F Small Ring Machine

High-volume low-pressure 

spray HVLP 1 1/2 Enclosure Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1

PPP306 - Medium Heat 200-250 

F Booth #2

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1

PPP306 - Medium Heat 200-250 

F Booth #4

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1

PPP306 - Medium Heat 200-250 

F Booth #8

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 PPP306 - Spindle Top Coat Spindle Top Coat 1

High-volume low-pressure 

spray HVLP 1 1/2 enclosed Building interior Water Curtain Water 1

PPP306 Regal Finishing, Inc. 1 1 1 PPP306 - Spindle Top Coat 2 Spindle Top Coat 2

High-volume low-pressure 

spray HVLP 1 1 1/2 enclosed Building interior Water Curtain Water 1

PPP307A Hackney & Sons Inc. 1 PPP307A - Paint Coating Scenario Cross ventilation filter booth Conventional Air Spray Conv Fully enclosed Building interior Dry filters Filter 1

PPP307A Hackney & Sons Inc. 1 1 1 PPP307A - Thermoset Part Drying Cross ventilation filter booth Conventional Air Spray Conv 1 Fully enclosed Building interior Dry filters Filter 1

PPP307D Hackney & Sons Inc. 1

PPP307D - Paint Coating 

Scenario Cross ventilation filter booth Conventional Air Spray Conv Fully enclosed Building interior Dry filters Filter 1

PPP307D Hackney & Sons Inc. 1 1 1 PPP307D - Thermoset Part Drying Cross ventilation filter booth Conventional Air Spray Conv 1 Fully enclosed Building interior Dry filters Filter 1

PPP313 Design House, Inc. 1 1 1

PPP313 - Painting Plastic 

Shutters Enclosed booth Conventional Air Spray Conv 1 Fully enclosed Building interior Dry filter Filter 1

PPP316 Central Coating Company, Inc 1 PPP316 - E.M.I./R.F.I. Coating Manual spray booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP316 Central Coating Company, Inc 1 1 1

PPP316 - Plastic Parts Coating - 

Polane T & Polane T Plus Manual spray booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filter Filter 1 1 1

PPP319 Document Technologies 1 1 1 PPP319 - Plastic Coating Binks 8' x 7' #BFA-8-7-T-B

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed 7000 cfm Andrea Filter

PPP328 Nero Plastics Inc. 1 PPP328 - DuPont Prime System Prime Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP328 Nero Plastics Inc. 1 PPP328 - Polane Prime System Prime booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filters Filter 1 1

PPP328 Nero Plastics Inc. 1 PPP328 - PPG Prime System Prime Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP328 Nero Plastics Inc. 1 1 1 PPP328 - Sprayfill Prime System Prime

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Dry filters Filter 1 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Glue Application 

(Flocking) Flocking Glue Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed B (atmosphere) Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

1 JBI

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

1 Prince

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

1 Rodgers

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

1 Sepanski

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

2 JBI

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

2 Prince

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

2 Rodgers

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1

PPP333A - Solvent Based Paint - 

2 Sepanski

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1 PPP333A - Waterborne Coatings Rodgers

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333A Summit Polymers, Inc. - Kalamazoo 1 1 1 PPP333A - Waterborne Coatings Sepanski

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1 1

PPP333B Summit Polymers, Inc. - Valley Plant 1

PPP333B - Solvent Baseed 

Painting Small Paint Booth

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry Filter Filter 1 1

PPP333B Summit Polymers, Inc. - Valley Plant 1 1 1 PPP333B - Waterbase Coating Small Paint Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry Filter Filter 1 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) A & B booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) Aerostat booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) Ashtray booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) Fil 74 booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) Lid C booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) VX booth

High-volume low-pressure 

spray HVLP 1 5/6 enclosed Building interior Dry filters Filter 1 1

PPP333C Summit Polymers, Inc. - Syntech Plant 1 1 1

PPP333C - Painting Parts w/ 

HVLP (all parts in Facility) WIN 88 Arolos

High-volume low-pressure 

spray HVLP 1 1 5/6 enclosed Building interior Dry filters Filter 1 1 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP333E Summit Polymers, Inc. - East Plant 1 PPP333E - Soft Touch Painting Paint line

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333E Summit Polymers, Inc. - East Plant 1 1 1 PPP333E - Water Based Painting Paint line

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1 1

PPP333F Summit Polymers, Inc. - Columbia Plant 1 PPP333F - Paint Lines Paint booth #1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333F Summit Polymers, Inc. - Columbia Plant 1 PPP333F - Paint Lines Paint booth #2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1

PPP333F Summit Polymers, Inc. - Columbia Plant 1 1 1 PPP333F - Paint Lines Paint booth #3

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Dry filter Filter 1 1 1

PPP342 American Mannequins Inc. 1

PPP342 - Mannequin Coating 

Scenario Booth 1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP342 American Mannequins Inc. 1 1 1

PPP342 - Mannequin Coating 

Scenario Booth 2

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filter Filter 1 1 1

PPP356 Metro Plastics Technologies, Inc. 1 1 1 PPP356 - Upspray Upspray Air-assisted airless spray AAAS Fully enclosed Building interior Dry Filter Filter 1

PPP384 Jones Performance Products Inc. 1 PPP384 - Black Paint Booth #105 Black paint spray booth Airless Spray Airless 1/2 enclosed Building interior Dry filters Filter 1

PPP384 Jones Performance Products Inc. 1 1 1 PPP384 - Touch up Area No booth, done on shop floor Conventional Air Spray Conv 1 No enclosure Atmosphere NA

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1

PPP389C - - -Automated - 

Thermoplastic Spray Booth (CD-006)

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filter (Particulate) Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1

PPP389C - Automated - Lead 

Insert Unique Booth (CD-006)

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed CD006 Filters Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1

PPP389C - Manual - 

Thermoplastic Main Booth 001

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Particulate Filter Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1

PPP389C - Manual - 

Thermoplastic Main Booth 002

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Particulate Filter Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1

PPP389C - Manual - 

Thermoplastic Main Booth 004

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Particulate Filter Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1 PPP389C - Manual - Thermoset Spray Booth (CD-003)

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Particulate Filter Filter 1 1

PPP389C GI Plastek Limited Partnership, Dec-Rite Div. 1 1 1 PPP389C - Manual - Thermoset Spray Booth (CD-004)

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Particulate Filter Filter 1 1 1

PPP394 Plasti - Paint Inc 1 1 1 PPP394 - Plastic Paint Process Booth 1-4

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Filters Filter 1 1 1

PPP415 S R of Arkansas 1 PPP415 - Black Out Spray Booth SN 32

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 41

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 5

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 6

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Spray Booth SN 7

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

10

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

11

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

12

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

13

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

14

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I Automatic Line

Automatic Paint Machine SN 

9

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I-Body Color Spray Booth SN 43

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I-Body Color Spray Booth SN 44

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Paint I-Body Color Spray Booth SN 8

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP415 S R of Arkansas 1 PPP415 - Black Out Spray Booth SN 26

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Black Out Spray Booth SN 29

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Black Out Spray Booth SN 30

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Black Out Spray Booth SN 31

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Clearcoat Spray Booth SN 28

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Clearcoat Spray Booth SN 39

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Clearcoat Spray Booth SN 42

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Paint I-Body Color Spray Booth SN 25

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 1 1 PPP415 - Prepbooth Spray Booth SN 46

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Basecoat Spray Booth SN 27

HVLP/Electrostatic 

spray/Electrodeposition HVLP 1 Fully enclosed Building interior Water wash Water 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP415 S R of Arkansas 1 PPP415 - Body Color Basecoat Spray Booth SN 37

HVLP/Electrostatic 

spray/Electrodeposition HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Basecoat Spray Booth SN 47

HVLP/Electrostatic 

spray/Electrodeposition HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP415 S R of Arkansas 1 PPP415 - Body Color Basecoat Spray Booth SN 48

HVLP/Electrostatic 

spray/Electrodeposition HVLP 1 Fully enclosed Building interior Water wash Water 1

PPP418 Risdon AMS 1 1 1

PPP418 - Cosmetic Caps 

Coating Line In Vacuum Metalizing 

op Waterwash spray booth Electrostatic Spray ES 3/4 Enclosed Building interior Waterwash baffles Water 1

PPP441 DeKalb Molded Plastics Company 1 1 1 PPP441 - #5 - Adhesives Spray Booth #11 Air-assisted airless spray AAAS 3/4 Enclosed Building interior Dry Filters Filter 1

PPP441 DeKalb Molded Plastics Company 1 PPP441 - #5 - Adhesives Open Air-assisted airless spray AAAS Open N/A N/A

PPP441 DeKalb Molded Plastics Company 1 PPP441 - #1 - Primer, Top Coat Spray Booth (1-11) Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

PPP441 DeKalb Molded Plastics Company 1

PPP441 - #2 - Primer, Color, 

Texture Spray Booth (1-11) Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

PPP441 DeKalb Molded Plastics Company 1 PPP441 - #3- Color Only Spray Booth (1-11) Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

PPP447D

Worthington Custom Plastics, Inc. - St. 

Mathews 1 PPP447D - Paint Coating Dry booths Conventional Air Spray Conv 1/2 enclosed Atmosphere Dry filter Filter 1

PPP447D

Worthington Custom Plastics, Inc. - St. 

Mathews 1 1 1 PPP447D - Paint Coating Mainline Conventional Air Spray Conv 1 Fully enclosed Atmosphere Waterwash Water 1

PPP449 Menasha Corporation - Montec Plastics 1 PPP449 - Cabletron Binks Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter Filter 1

PPP449 Menasha Corporation - Montec Plastics 1 PPP449 - Schneider Binks Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter Filter 1

PPP449 Menasha Corporation - Montec Plastics 1

PPP449 - United Electric 

(Beige)___ Binks Conventional Air Spray Conv 3/4 Enclosed Atmosphere Dry filter Filter 1

PPP449 Menasha Corporation - Montec Plastics 1 1 1 PPP449 - United Electric (Black) Binks Conventional Air Spray Conv 1 3/4 Enclosed Atmosphere Dry filter Filter 1

PPP453 K C Industries, Inc. 1 1 1 PPP453 - Plastic Parts Coating 2 Manual Binks Booths

High-volume low-pressure 

spray HVLP 1 1 1/4 Enclosed Building interior Dry Filters Filter 1 1 1

PPP459B Spensor Industries, Inc. 1

PPP459B - Painting of plastic in 

Batch Booths 1,2,3& Cont. 4 B1 is a Batch Unspecified spray application 3/4 Enclosed Atmosphere Filters Filter 1

PPP459B Spensor Industries, Inc. 1

PPP459B - Painting of plastic in 

Batch Booths 1,2,3& Cont. 4 B2 is a Batch Unspecified spray application 3/4 Enclosed Atmosphere Filters Filter 1

PPP459B Spensor Industries, Inc. 1

PPP459B - Painting of plastic in 

Batch Booths 1,2,3& Cont. 4 B3 is a Batch Unspecified spray application 3/4 Enclosed Atmosphere Filters Filter 1

PPP459B Spensor Industries, Inc. 1 1 1

PPP459B - Painting of plastic in 

Batch Booths 1,2,3& Cont. 4 B4 is continuous Unspecified spray application Fully enclosed Atmosphere Filters Filter 1

PPP479 Midwest Plastic Engineering, Inc. 1

PPP479 - Plastic Part Painting 

and Coating Booth #1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Outside Filters Filter 1 1

PPP479 Midwest Plastic Engineering, Inc. 1

PPP479 - Plastic Part Painting 

and Coating Booth #2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Outside Filters Filter 1 1

PPP479 Midwest Plastic Engineering, Inc. 1

PPP479 - Plastic Part Painting 

and Coating Booth #3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Outside Filters Filter 1 1

PPP479 Midwest Plastic Engineering, Inc. 1 1 1

PPP479 - Plastic Part Painting 

and Coating Booth #4

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Outside Filters Filter 1 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Four Step Painting 

With Shielding - Scenario #5 Booths #1,2,3

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Four Step Painting 

With Shielding - Scenario #5 Booths #8,9,10

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Solvent 

Base - Scenario #2 Booth #11

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Water Base 

- Scenario #1 Booth 2

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Water Base 

- Scenario #1 Booth 7

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Water Base 

- Scenario #1 Booths 4 & 6

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Water Base 

- Scenario #1 Booths 4,6,7

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - One Step Water Base 

- Scenario #1 Booth 11

High-volume low-pressure 

spray HVLP 1 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Shielding Only on Raw 

Part - Scenario #7 Booths 8,9,10

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filter Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Three Step 

Solvent/Waterborne - Scenario 

#4 Booths #1,2,3

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Two Step Solvent - 

Scenario #3 Booth #1 & 3

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Two Step Solvent - 

Scenario #3 Booth #12

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1

PPP488A - Two Step Water Base 

- Scenario #6 Booths #4,5, & 6

High-volume low-pressure 

spray HVLP 1 1/4 Enclosed Building interior Filters Filter 1 1

PPP488A Mack Molding Company - Inman 1 1 1

PPP488A - Two Step Water Base 

- Scenario #6 Booths #6 & 7

High-volume low-pressure 

spray HVLP 1 1 1/4 Enclosed Building interior Filters Filter 1 1 1

PPP488B Mack Molding Company - Statesville 1 PPP488B - -REI Shielding Coat Booth 9

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1 PPP488B - Base Coat Step Booth # 5-8

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1

PPP488B - Base Coat Texture 

Coat Step Booth 9-11

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1 PPP488B - Color Coat Step Booth #5-8

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1

PPP488B - Thermoplastic Part 

Coating (Base + Texture Coat) Booths #1-4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1 PPP488B - Top Coat Step Booth 5-8

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Filters Filter 1 1

PPP488B Mack Molding Company - Statesville 1 1 1 PPP488B - Top Coat Step Booth 9-11

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Filters Filter 1 1 1

PPP514 Mastermold, LLC 1

PPP514 - Thermoset Coating 

Scenario - Prime Coat / Top Coat Main booth Conventional Air Spray Conv Fully enclosed Building interior Filters - Dry Filter 1

PPP514 Mastermold, LLC 1

PPP514 - Thermoset Coating 

Scenario - Prime Coat / Top Coat Main booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Filters - Dry Filter 1 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP514 Mastermold, LLC 1

PPP514 - Thermoset Coating 

Scenario - Topcoat Texture Main booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Filters - Dry Filter 1 1

PPP514 Mastermold, LLC 1 1 1

PPP514 - Thermoset Coating 

Scenario (Double Prime Coat) Main booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Filters - Dry Filter 1 1 1

PPP524 London Industries, Inc. 1 PPP524 - Isuyu Carpet 9 x 6 ft booth and fixture Unspecified spray application Yes Yes N/A

PPP524 London Industries, Inc. 1 1 1 PPP524 - Paint Line 9 ft / 6 ft Booth and Fixture Unspecified spray application Yes Yes N/A

PPP528A Walman Optical - Baltimore 1 1 1 PPP528A - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528B Walman Optical - Bemidji 1 1 1 PPP528B - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528C Walman Optical - Billings 1 1 1 PPP528C - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528D Walman Optical - Denver 1 1 1 PPP528D - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528E Ultra Coatings 1 1 1

PPP528E - Thermoset Coating 

Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

PPP528F Walman Optical - Duluth 1 1 1 PPP528F - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528G Walman Optical - Evansville 1 1 1 PPP528G - UV Cure Scenario Spin Coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls

PPP528H Walman Optical - Fargo 1 1 1 PPP528H - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528I Walman Optical - Fort Wayne 1 1 1 PPP528I - UV Cure Scenario_ Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528J Walman Optical - Great Falls 1 1 1 PPP528J - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528K Walman Optical - Green Bay 1 1 1 PPP528K - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528L Walman Optical - Kent 1 1 1 PPP528L - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528M Walman Optical - Las Vegas 1 1 1 PPP528M - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528N Walman Optical - Minot 1 1 1 PPP528N - UV Cure Scenario Spin Coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls

PPP528O Walman Optical - Missoula 1 1 1 PPP528O - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528P Walman Optical - Montgomery 1 1 1 PPP528P - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528Q Walman Optical - Norfolk 1 1 1 PPP528Q - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528R Walman Optical - Omaha 1 1 1 PPP528R - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528S Walman Optical - Rock Island 1 1 1 PPP528S - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed cd 2000

Overspray collected on 

chamber walls

PPP528T Walman Optical - Sioux Falls 1 1 1 PPP528T - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528U Walman Optical - Springfield 1 1 1 PPP528U - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528V Walman Optical - York 1 1 1 PPP528V - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528W Acurex 1 1 1 PPP528W - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP528X Walman Optical - Duluth 1 1 1 PPP528X - UV Cure Scenario Spin coater

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD2000

Overspray collected on 

chamber walls.

PPP540 Moonlight Industries Inc. 1 1 1

PPP540 - Plastic Part Coating 

Scenario Booth 1-11

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filters Filter 1 1 1

PPP546 Nu-Coat Industries, Inc. 1

PPP546 - Metal Coating (Primrt / 

Solvent - Based) Automotive booth Unspecified spray application

14' x 28' JBI 

automotive spray 

booth

34" diam fan/roof 

vent Spun glass filter Filter 1

PPP546 Nu-Coat Industries, Inc. 1

PPP546 - Plastic Coating 

(Solvent) Automotive booth Unspecified spray application

14' x 28' JBI 

automotive spray 

booth

34" diam fan/roof 

vent Spun glass filter Filter 1

PPP546 Nu-Coat Industries, Inc. 1 PPP546 - Primer / Water Borne Automotive booth Unspecified spray application

14' x 28' JBI 

automotive spray 

booth

34" diam fan/roof 

vent Spun glass filter Filter 1

PPP546 Nu-Coat Industries, Inc. 1 1 1

PPP546 - Single Component 

Water - Borne Automotive booth Unspecified spray application

14' x 28' JBI 

automotive spray 

booth

34" diam fan/roof 

vent Spun glass filter Filter 1

PPP548 Continental Plastics Company 1

PPP548 - - Knee Bolster Coating 

Scenario Spray booty # 3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1

PPP548 - - Knee Bolster Coating 

Scenario Spray booty # 4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1

PPP548 - - Remote Bezel & Arm 

Rest Scenario Spray booty # 1 & 2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1

PPP548 - - Remote Bezel & Arm 

Rest Scenario Spray booty # 2 & 3

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1

PPP548 - - Remote Bezel & Arm 

Rest Scenario Spray booty # 4 & 5

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1

PPP548 - Glove Box Coating 

Scenario Spray booty # 1

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP548 Continental Plastics Company 1 1 1

PPP548 - Glove Box Coating 

Scenario Spray booty # 2

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filters Filter 1 1 1

PPP571 Advanced Fiber Products, Inc. 1 1 1 PPP571 - Spray Coating Scenario Spray Booth Conventional Air Spray Conv 1 3/4 Hooded Building interior Filters Filter 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths 

#12,#13,#14 & #15 Filter Booth #12

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths 

#12,#13,#14 & #15 Filter Booth #13

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths 

#12,#13,#14 & #15 Filter Booth #14

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

PPP583 Plastech 1

PPP583 - Spray Paint Booths 

#12,#13,#14 & #15 Filter Booth #15

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths #16, 

#17, #18 & #19 Filter Booth #16

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths #16, 

#17, #18 & #19 Filter Booth #17

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP583 Plastech 1

PPP583 - Spray Paint Booths #16, 

#17, #18 & #19 Filter Booth #18

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP583 Plastech 1 1 1

PPP583 - Spray Paint Booths #16, 

#17, #18 & #19 Filter Booth #19

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry Filter Filter 1 1 1

PPP594 Consolidated Coating Company 1

PPP594 - Thermoset Part 

Coating Scenario Conveyor Booths 2,3,11,12

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters Filter 1 1

PPP594 Consolidated Coating Company 1

PPP594 - Thermoset Part 

Coating Scenario Conveyor Booths 4&5

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters Filter 1 1

PPP594 Consolidated Coating Company 1

PPP594 - Thermoset Part 

Coating Scenario Conveyor Booths 6&7

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Atmosphere Filters Filter 1 1

PPP594 Consolidated Coating Company 1 1 1

PPP594 - Thermoset Part 

Coating Scenario Conveyor Booths 8,9,10

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Atmosphere Filters Filter 1 1 1

PPP595 Krueger International Inc. - Manitowoc 1 PPP595 - General Coating Spray Booth 1 Conventional Air Spray/HVLP Conv 3/4 Enclosed CD001 Filters Filter 1

PPP595 Krueger International Inc. - Manitowoc 1 PPP595 - General Coating Spray Booth 2 Conventional Air Spray/HVLP Conv 3/4 Enclosed CD002 Filters Filter 1

PPP595 Krueger International Inc. - Manitowoc 1 1 1 PPP595 - General Coating Spray Booth 3

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed CD003 Filters Filter 1 1 1

PPP597 C & D Aerospace Inc. 1 1 1

PPP597 - Thermoset Part 

Coating 14'x12.6x8h

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Atmosphere

Inlet filters & outlest filters 

(32 - 20"x20"x2") Filter 1 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1

PPP634 - Automotive Interior 

Trim Opened Face

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1

PPP634 - Automotive Interior 

Trim Opened Face

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1

PPP634 - Automotive Interior 

Trim Opened Feaced

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filters Filter 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1 PPP634 - EMI-Sheilding Open Faced

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1 PPP634 - Lens Opened Face

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1 1 1

PPP634 - Non-Automotive 

Applications Opened Faced

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filter Filter 1 1 1

PPP634 Conformance Coatings & Prototype, Inc. 1

PPP634 - Full Gloss Paint 

Systems Clean Room

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Waterwash Water 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 PPP636 - Line #1 3/4 enclosed

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 PPP636 - Line #2 3/4 enclosed

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filter Filter 1 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 PPP636 - Line #3 Line #3

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 PPP636 - Line #4 Line #4

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry Filter Filter 1 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 PPP636 - Line #5A Line #5A

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Dry filter Filter 1 1

PPP636

JSJ Plastics, Inc. (formerly Michigan Plastics 

Products Company) 1 1 1 PPP636 - Line #5B (Color Coat) Line #5B

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Dry filter Filter 1 1 1

PPP637A Rexam Cosmetic Packaging, Inc. 1 PPP637A - Sprayed UV Topcoat Booth 2

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed Building interior Dry filters Filter 1 1

PPP637A Rexam Cosmetic Packaging, Inc. 1 1 1 PPP637A - Sprayed UV Topcoat Booth 3

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filters Filter 1 1 1

PPP637B Rexam Cosmetic Packaging, Inc. 1 1 1 PPP637B - Sprayed UV Topcoat Booth 1 Electrostatic Spray ES 3/4 Enclosed Building interior Dry filters Filter 1

PPP642 Maracle Industrial Finishing Co., Inc. 1

PPP642 - Auto Line Coating 

Scenario Base Coat Booth #1 and/or Conventional Air Spray Conv 3/4 Enclosed Atmosphere Waterwash Water 1

PPP642 Maracle Industrial Finishing Co., Inc. 1

PPP642 - Auto Line Coating 

Scenario Texture Booth #2 Conventional Air Spray Conv 3/4 Enclosed Atmosphere Waterwash Water 1

PPP642 Maracle Industrial Finishing Co., Inc. 1

PPP642 - Batch Line Coating 

Scenario 4'X8' Spray Booth Conventional Air Spray/HVLP Conv 3/4 Enclosed Atmosphere Waterwash Water 1

PPP642 Maracle Industrial Finishing Co., Inc. 1 1 1

PPP642 - Batch Line Coating 

Scenario 8'X10' Spray Booth Conventional Air Spray/HVLP Conv 1 3/4 Enclosed Atmosphere Waterwash Water 1

PPP645A Applied Coating Technology, Inc. 1 PPP645A - Conductive Coating Batch Booth Conventional Air Spray/HVLP Conv 3/4 Enclosed Building interior Dry filters Filter 1

PPP645A Applied Coating Technology, Inc. 1 1 1 PPP645A - Top Coat Plastic Parts Line Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed B Waterwash Water 1

PPP645B Applied Coating Technology Inc. 1 1 1

PPP645B - Top Coat Plastic 

Parts Line booth Conventional Air Spray Conv 1 3/4 Enclosed Building interior Waterwash Water 1

PPP671A Spectrum Cubic - McConnell 1 1 1 PPP671A - Clearcoat Line 2 automatic spray booths Conventional Air Spray Conv 1 Fully enclosed Control device Waterwash Water 1

PPP677 Diversified Coatings, Inc. 1 1 1 PPP677 - Misc. EM1/RF1 Peviliss booth

High-volume low-pressure 

spray HVLP 1 1 100% Exterior Proclean filters Filter 1 1 1

PPP680 A & K Finishing, Inc. - Plant 2 1 1 1

PPP680 - Water Based Plastic 

Part Coating Coating Booths Conventional Air Spray/HVLP Conv 1 3/4 Enclosed B Dry Fabric Filters Filter 1

PPP680 A & K Finishing, Inc. - Plant 2 1

PPP680 - Solvent Based Plastic 

Part Coating Coating Booths

High-volume low-pressure 

spray HVLP 1 3/4 Enclosed B Dry Fabric Filters Filter 1 1

PPP680A A & K Finishing, Inc. - Plant 1 1 1 1

PPP680A - Solvent Based Plastic 

Part Coating Coating Booths

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed B Dry Fabric Filters Filter 1 1 1

PPP683A Spalding Sports Worldwide - Chicopee 1 1 1 PPP683A - Golf Ball Painting Binks water wash

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Water wash Water 1

PPP683B Spalding Sports Worldwide - Gloversville 1 1 1 PPP683B - Golf Ball Painting Binks water wash

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Water wash Water 1

PPP684 Perfect Plastics Industries, Inc. 1 PPP684 - Primer Coat #1 - Auto Conveyance

High-volume low-pressure 

spray HVLP 1 Fully enclosed B Dry filter Filter 1 1

PPP684 Perfect Plastics Industries, Inc. 1 1 1 PPP684 - Primer Coat #2 - Manual

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed B Dry filter Filter 1 1 1

PPP687 G. S. Industries of Bassett, Inc. 1

PPP687 - Polystyrene part 

coating 1/4 Enclosed Conventional Air Spray Conv 1/4 Enclosed B Dry filters Filter 1

PPP687 G. S. Industries of Bassett, Inc. 1 1 1

PPP687 - Silver coating on 

polystyrene frames 1/4 Enclosed Conventional Air Spray Conv 1 1/4 Enclosed B Water catch containers

RPC162 San Juan Pools of Oklahoma, Inc. 1

RPC162 - Swimming Pool 

Manufacturing Scenario Spray on gelcoat

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior Operator training
FTN Facility_name

FTN

Count

Area 

Source 

Count

Area 

Source 

Scenarios ScenarioName_new SprayBooth Spray Gun Technology

Spay

Gun

Abbr

HVLP at 

Area 

Source 

Scenario

s

HVLP at 

Area 

Source

Conv 

Spray At 

Area 

Source 

Facilities Enclosure Vent Overspray Control Filter Abbr

Dry Filter at 

Area Source 

Scenarios

Water Wash 

Filters At Area 

Source 

Scenarios

HVLP and 

Filter at Area 

Source 

Scenarios

Unique Area 

Source FTN 

with HVLP 

and Dry Filters

RPC162 San Juan Pools of Oklahoma, Inc. 1

RPC162 - Swimming Pool 

Manufacturing Scenario

Spray on polyester resin w/ 

mat and woven roving

High-volume low-pressure 

spray HVLP 1 fully enclosed Building interior Operator training

RPC162 San Juan Pools of Oklahoma, Inc. 1 1 1

RPC162 - Swimming Pool 

Manufacturing Scenario

Spray on vinyl ester resin 

w/mat

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Operator training

RPC170B TPI Composites, Inc. - Portsmouth Facility 1 1 1 RPC170B - Spray booth 70' DOWNDRAFT Air-assisted airless spray AAAS Fully enclosed Building interior Dry filters Filter 1

RPC180 Fibertech Incorporated 1 1 1

RPC180 - Standard Gel Coat 

Process Gel coat booths

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed Building interior Dry filter Filter 1 1 1

RPC212 Sabre Yachts 1

RPC212 - Boot Top Application 

(Activator) Completion area

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212 Sabre Yachts 1

RPC212 - Boot Top Application 

(Thinner) Completion area

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212 Sabre Yachts 1 RPC212 - Mold Coating Booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212 Sabre Yachts 1 1 1 RPC212 - Mold Coating Booth #2

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior N/A

RPC212A Sabre Yachts 1

RPC212A - Boot Top Application 

(Activator) Completion area

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212A Sabre Yachts 1

RPC212A - Boot Top Application 

(Thinner) Completion area

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212A Sabre Yachts 1 RPC212A - Mold Coating Booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed Building interior N/A

RPC212A Sabre Yachts 1 1 1 RPC212A - Mold Coating Booth #2

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior N/A

RPC217 Hot Box 1 1 1 RPC217 - Gel Coat Spraying Square with open end Conventional Air Spray Conv 1 Booth Itself

Exhaust fan with 

filter bank Tip Pressure

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Backup Gelcoat Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD5 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Basecoat Booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD6 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Basecoat Booth #2

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD7 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Clearcoat Booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD8 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Clearcoat Booth #2

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD9 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper Gelcoat Booth

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD1 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper HAF Resin Booth #1

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD3 Wall Filter Filter 1 1

RPC228A Glasstite West 1 RPC228A - Fiberglass topper HAF Resin Booth #2

High-volume low-pressure 

spray HVLP 1 Fully enclosed CD4 Wall Filter Filter 1 1

RPC228A Glasstite West 1 1 1 RPC228A - Fiberglass topper Skin Resin Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed CD2 Wall Filter Filter 1 1 1

RPC271 Hy-Tec Fiberglass Inc. 1 1 1

RPC271 - Fiberglass boom paint 

scenario

Paint Booth Zone #5 

"FESOP"

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Building interior Filters Filter 1 1 1

RPC331 Mckenzie Sports Products, Inc. 1

RPC331 - Target Painting 

Process Booth #B 01- B 04 Conventional Air Spray Conv 3/4 Enclosed Building interior Dry Filters Filter 1

RPC331 Mckenzie Sports Products, Inc. 1 1 1

RPC331 - Target Painting 

Process Booth #B 01-B04 Conventional Air Spray Conv 1 3/4 Enclosed Building interior Dry filters Filter 1

RPC348 GatorGrate 1 1 1 RPC348 - Painting Paint Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Control device Dry Filter Filter 1 1 1

RPC361 ACCRA Industries, Inc. 1 1 1

RPC361 - Air Assist Spray Gel 

Coat Gel Coat Booth

High-volume low-pressure 

spray HVLP 1 1 3/4 Enclosed control device- O2

Dry Filter w/ Operator 

Training Filter 1 1 1

RPC404 Peterson Products 1 1 1

RPC404 - Thermoset reinforced 

plastic coating scenario Urethane Spray Booth

High-volume low-pressure 

spray HVLP 1 1 Fully enclosed Control device dry fabric filters Filter 1 1 1

126 126 402 303 89 25 302 52 222 53
5.0 

Estimating the Number of Automotive Refinishing 

Shops and the Projected Number of New Shops 
0223-00-008\Estimate of new shops/yr 1

MEMORANDUM 

TO: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural 

Resources and Commerce Group 

FROM: Brian Palmer, Eastern Research Group, Inc. (ERG) 

DATE: February 22, 2006 

SUBJECT: Estimating the number of automotive refinishing shops and the projected 

number of new shops. 

This memo describes how we estimated the total number of automotive refinishing shops 

and the number of new shops that could be expected in a 5-year period after promulgation of the 

area source rule for automotive and mobile equipment refinishing operations. The basic 

approach for estimating the number of new shops is to divide the total number of shops by the 

average age of shops to obtain the average number of new shops per year. This approach 

assumes a constant number of shops (this is supported by U.S. Census data), and a constant 

turnover rate between new and old shops per year, and assumes this trend will continue in the 

future. 

Body Shop Business (www.bodyshopbusiness.com) does an annual survey of the 

industry. For the years 1996 to 2002 they included a shop owner profile that reported the 

average number of years a shop owner has owned their business. We assumed that this is the 

average age of each shop as a “source” under the definition of a source in the Clean Air Act. 

This assumption does not account for shops that may have changed locations without changing 

ownership (these would be considered new sources), or shops that change ownership without 

changing location (these would be considered existing sources), but we assumed that these tend 

to cancel each other out and do not affect the actual number of new shops. 

The average number of years that each shop owner owned a business was reported as 

follows (the years represent the year of the survey data, which was reported in the next calendar 

year): 
0223-00-008\Estimate of new shops/yr 2

1996: 20.9 years 

1997: 22 years 

1998: 21.5 years. 

1999: more than 19 years 

2000: 23.9 years 

2001: 22.5 years 

2002: 24.9 years 

Assuming that we count the response for 1999 to be 19 years, the average age of a shop 

for these seven years was 22.1 years. 

The 1998 and 2000 Body Shop Business Industry Profile reported that the data were 

collected through surveys conducted by Babcox Research, a division of Babcox Publications, 

and executed via a nationwide mail program to 6,000 body shops. The survey consisted of six 

two-page questionnaires (each questionnaire addressed a different topic), and each questionnaire 

was sent to a subsample of 1,000 BodyShop Business magazine readers. Readers were chosen 

through a systematic sampling procedure in which every "nth" name was selected from a 

BodyShop Business subscription list. The sample was adjusted to provide geographic 

representation. Surveys were mailed in February or March, and Babcox Research received 1,237 

completed questionnaires in 1998 (a 21.2 percent return rate), and 946 completed questionnaires 

in 2000 (a 15.9 return rate). This information was not included for other survey years. 

The 2002 U.S. Census reported that 35,200 businesses reported under the heading 

NAICS 811121, “Automotive body, paint, and interior repair and maintenance.” This is 

comparable to the numbers reported in 1997 (35,569 businesses) and 1992 (35,043 businesses), 

indicating that the number of shops is relatively constant, in spite of other variables that could 

affect the number of shops (cars on the road, miles driven, consolidation of smaller shops, etc.). 

At www.lycos.com, we searched in the Yellow Page listings for “auto body shops.” The 

site returned 72,961 listings under “Auto Body Repair & Painting,” which is twice the number 

provided by the census. The U.S. Census data may under-represent automotive refinishing shops 

since they may be included under a larger service center, such as a dealership. We expect that 

the actual number may be in between these two values. Some industry associations may be able 

to give us more accurate figures. 

If we divide the current number of listings, by the average age of each business, then we 

will have the average number of new shops per year: 
0223-00-008\Estimate of new shops/yr 3

35,200 shops ÷ 22.1 years = 1,593 new shops per year according to the 2002 census. 

72,961 shops ÷ 22.1 years = 3,301 new shops per year according to the Yellow Pages at 

www.lycos.com. 

Using these numbers, we estimate that the number of new shops in the 5-year period after 

promulgation would be 7,965 from the U.S. Census data and 16,505 from the Yellow Pages data. 

Table 1 summarizes the 1992, 1997, and 2002 U.S. Census data for SIC 7532, “Top, 

Body, And Upholstery Repair Shops and Paint Shops,” and NAICS 811121, “Automotive Body, 

Paint, And Interior Repair And Maintenance.” 

Table 1. Summary of U.S. Census Data for Automotive Body, Paint, 

And Interior Repair And Maintenance 

Year 1992 1997 2002 

Number of 

establishments 

35,043 35,569 35,200 

Receipts/Revenue 

($1,000) 

$12,262,486 $17,755,296 $22,405,337 

Annual Payroll 

($1,000) 

$3,444,504 $5,172,206 $6,880,027 

Paid Employees 165,894 205,172 220,393 
6.0 

Estimating the Number of Miscellaneous Surface Coating Area 

Sources for Which EPA Has Data 
0223-00-008\ Estimating the number of sources 1

MEMORANDUM 

TO: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural 

Resources and Commerce Group 

FROM: Brian Palmer, Eastern Research Group, Inc. (ERG) 

DATE: July 19, 2006 

SUBJECT: Estimating the Number of Miscellaneous Surface Coating Area Sources for 

Which EPA Has Data. 

This memo describes how we estimated the number of miscellaneous surface coating area 

sources for which EPA has data. The estimated number of shops is based on the number of area 

source surface coating shops in the merged database from the plastic parts and products and 

miscellaneous metal parts and products major source surface coating rules (40 CFR 63, subparts 

MMMM and PPPP). We estimate that there are 831 miscellaneous surface coating area sources 

for which we have data. The attached spreadsheet lists those area sources and provides 

information about each source. 

The merged database had 1360 unique facility identification numbers (FACID). Some 

FACIDs are repeated in the facility information table of the database, Form A, because multiple 

rows of data were entered for some shops with a separate row for each product or coating line in 

the shop. 

Form A also listed the Title V major source status of each facility when they completed 

the survey in 1995 or 1996. For each facility, we also estimated their total HAP consumption, 

when coating data were provided in their survey response. Some facilities did not provide 

coating data, because they knew at the time that they were not major sources for HAP and would 

not be subject to either of the major source rules. We grouped facilities by their reported Title V 

status and total HAP consumption. Based on their Title V status and their HAP consumption, we 

predicted whether or not they would be an area source potentially subject to the area source rule. 

Table 1 summarizes the number of sources in each Title V status and HAP consumption category 

and our estimate of the total number of area sources. 
0223-00-008\ Estimating the number of sources 2

Table 1 also summarizes the rules we used in deciding whether to group a facility as an 

area source or major source. 

It is important to note that 512 of the 831 sources we estimated are area sources did not 

report their major source status and did not report any data; we assumed that these did not report 

data because they were not major sources and were instead area sources. We also assumed that 

37 sources that reported their Title V status as “unknown” and did not report any data were area 

sources. The lack of data for these sources introduces some uncertainty into our estimate of the 

number of area sources. The best way to resolve this would be to perform a line-by-line analysis 

of Form A (the facility information form) of the merged data to see if there are any comments 

that could shed light on the facilities major source status and why they did not provide any data. 

It is also important to note that reported Title V major source status at the time the survey 

was completed may have been based on criteria pollutant emissions and not on HAP emissions. 

Some sources may have declared they were major sources based on criteria pollutants, but may 

not exceed the major source threshold for HAP. About 20 percent of facilities that reported they 

were a major source for Title V did not provide data. These two factors also introduce some 

uncertainty that could be resolved only through a line-by-line review of the comments included 

in Form A. 

We have data for 236 facilities that we estimated are area sources. An additional 46 

facilities reported that they were “minor or area sources,” or “synthetic minor sources,” but did 

not provide any data, for a total of 282 facilities. 

We have data for 430 facilities that we estimated are major sources. No data are 

available for 99 facilities that declared they were major sources. 

Reported Title V Status HAP 

Consumption

Area or Major 

Sources? 

Number 

Total Number of Unique FACID in Merged Database 1360 

Blank <25 tpy Area 19 

Blank or CBI No data Area 512 

Minor or Area Source <25 tpy Area 79 

Minor or Area Source No data Area 28 

Synthetic Minor Source <25 tpy Area 66 

Synthetic Minor Source No data Area 18 

Unknown <25 tpy Area 72 

Unknown No data Area 37 

Total number of Area Sources 831 
0223-00-008\ Estimating the number of sources 3

Reported Title V Status HAP 

Consumption

Area or Major 

Sources? 

Number 

Blank >25 Major 11 

Major Source >0 Major 401 

Major Source No data Major 99 

Minor or Area Source; Synthetic Minor Source, 

Unknown 

>25 tpy Major 18 

Total Number of Major Sources 529 
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

ACS0001

Mitsubishi Motor MFG of America, 

INC US Route 150 Normal IL 61761 Facility under August 1986 BACT determination Fascia and Plastic Bumpers for automobiles

ASC013 Subaru-Isuzu Automotive Inc.

5500 State Road 38 

East, PO Box 5689 Lafayette IN 47903

ASC14 General Motors - Doravile Doraville

MMPP-0004 E/M Engineered Coating Solutions

16470 East 13 Mile 

Road Roseville MI 48066

Minor or area 

source

State of Michigan Air 

Permit that limits facility 

emissions below Title V 

status.

3 steel and cinder block buildings totaling 28,000 square feet used 

for the application of Engineered Specification Coatings Paints, Varnishes, Lacquers & Enamels

MMPP-0049 Metal Finishing Company Inc.

1423 South McLean 

Boulevard Wichita KS 67213

Minor or area 

source

Total HAP and VOC 

emissions, as well as 

single HAP emissions 22.39 

Job shop providing a variety of coatings for corrosion resistance 

and appearance enhancement for the metal parts manufacturing 

industry. Electroplating and surface finishing. Farm machinery and equipment

MMPP-0060 Yale Security 100 Yale Avenue Lenior City TN 37771

Minor or area 

source

Actual and Potential 

emissions less than 

thresholds Manufacurer of locks door locks

MMPP-0083 Skyline Woodland

1720 East Beamer 

Street Woodland CA 95776

Synthetic minor 

source Manufactured home assembly Manufactured homes

MMPP-0119 Rawson-Koenig, Inc. 2301 Central Parkway Houston TX 77092 Unknown 6.45 

Various forms of bulk sheet metal are cut, punched, formed, 

assembled, and painted in the production of pickup tool boxes, light 

to medium duty service/utility truck beds and smaller truck 

equipment accessories. Truck-Utility Bodies

MMPP-0175

PACCAR Winch Division (aka 

Braden Carco Gearmatic)

800 East Dallas St, 

P.O. Box 547 Broken Arrow OK 74012

Minor or area 

source

Oaklahoma Air Quality 

Permit. 3.82 

Heavy duty winches are manufactured at this facility and can be 

distinguished from other miscellaneous metal parts surface coating 

operations in the following areas: color is customer specified, 

weather resistant coatings, salt water protective coatings, Winches

MMPP-0244 Dukane Corp 2900 Dukane Drive St. Charles IL 60174

Synthetic minor 

source

Emissions have potental 

to exceed the major 

threshold - hours of 

operation limitation in 

permit. 1.09 

Manufacturer of electrical and electronic equipment process 

including metal forming, metal finishing and painting, printed circuit 

coard soldering and assembly Audio Visual Equipment

MMPP-0282 Nucor Building Systems

West SC Highway #3, 

200 Whetstone Rd 

(PO Box 1006) Swansea SC 29160

Synthetic minor 

source

Internal data 

collection(Potential to 

emit VOC) - 

Metal building systems sales, engineering and fabrication. 

(Production of roll-formed and built-up steel building components, 

which are subsequently painted) Metal Building Systems

MMPP-0286 Emerson Electric Company

1315 North 13th 

Street Rogers AR 72756

Synthetic minor 

source 12.05 

Manufacturer of fractional horsepower electrical motors and 

components used for fractional electrical motors. Electrical Motors

MMPP-0349 Dearborn Mid-West Conveyor Co. 2601 Mid-West Drive Kansas City KS 66111 Unknown 9.20 Metal fabrication manufacture of conveyor systems. Conveyor Systems

MMPP-0468 Alabama Tank, Inc.

P.O. Box 760 - 85 3 

Mile Rd. Atmore AL 36504 Unknown NA Non-Pressure Vessel Storage Tank Manufacturer. Underground Storage Tanks

MMPP-0474 Chemtrom fire Systems

184-B E. Meadowlake 

Parkway Swainsboro GA 30401 Unknown UNKNOWN UNKNOWN

MMPP-0483 CP Louisiana, Inc.

6000 Jefferson 

Highway Jefferson LA 70123

Minor or area 

source

Under 25 tons of HAPs 

and Under 100 tons of 

total VOCs 17.73 Manufacturer of 55 gallon steel drums 55-gallon steel drums

MMPP-0503 Modine Manufacturing Company 1140 Northpoint Blvd. Blythewood SC

29016887

3

Minor or area 

source

Potential emissions are 

less than threshold 

values. - 

Manufacturer of aluminum oil coolers for the automotive industry. 

This facility uses a HAP-free powder painting process. However, 

some touch-up paint is done with aerosol cans. Oil Coolers

MMPP-0504 Modine Manufacturing Company

1221 Magnolia 

Avenue Buena Vista VA 24416

Minor or area 

source

Actual and potential 

emissions of all criteria 

pollutants and HAPs are 

below the applicable 

thresholds - 

Heat transfer equipment manufacturing with a powder paint surface 

coating operation. There are no HAP emissions for this operation. Space heaters

MMPP-0508 Modine Manufacturing Company 1401 Industrial Street Emporia KS 66801

Synthetic minor 

source PTE HAP emissions - Manufacturing facility producing copper/brass radiators. Radiators

MMPP-0511 Suburban Manufacturing Co. 676 Broadway Street Dayton TN 37321

Synthetic minor 

source

Emissions inventorybased. 19.82 PTAC units and RV components (water heaters, various furnaces, 

cooktops, and ovens) RV Components

MMPP-0563 Nylint Corporation 1800 16th Avenue Rockford IL 61104

Minor or area 

source VOC per air permit 2.27 manufactures steel toy trucks Games, toys, child vehicles

MMPP-0578

Carolina Steel Fabrication, 

Greensboro Plant

1451 South ElmEugene St Greensboro NC 27420Minor or area 

source Air emissions inventory. 2.68 manufacture of structural steel components Structural steel components

MMPP-0599 Monaco Coach Corporation 65906 State Rd. 19 Wakarusa IN 46573

Synthetic minor 

source

usage of chaulks, 

sealants, painting and 

solvents. 6.78 

 travel trailer MANUFACTURING FACILITY INCLUDING CHASSIS 

CONSTRUCTION, VEHICLE ASSEMBLY AND PAINT travel trailers

MMPP-0601

Rexnord Corporation - Link Belt 

Bearing Division 7601 Rockville Rd Indianapolis IN 46214

Minor or area 

source Minor Source

Bearing Manufacturer - operations include grinding, drilling, 

machining, heat treatment, painting, stamping, & assembly. Ball & Roller Bearings

MMPP-0606 Pee Dee Tank Company Inc.

1333 N. Douglas 

Street Florence SC 29503 Unknown

Steet tank manufacturing - 150 gal - 20,000 gallons. Rolling of steel 

sheets, welding, sand blasting, painting, coating. Fuel storage tanks

MMPP-0609 Modine Manufacturing Company 239 Factory St LaPorte IN 46350

Synthetic minor 

source Paint VOCs 2.12 

Manufacturer of heat transfer equipment for heavy duty industrial 

and automotive applications. Process uses copper, brass, steels, 

solder and paint in production quantities. Heat transfer equipment

MMPP-0638 EQUIMETER, INC. (PLANT 1)

805 LIBERTY 

BOULEVARD DUBOIS PA 15801

Minor or area 

source - 

MANUFACTURER OF GAS METERS, REGULATORS AND 

RELATED PRODUCTS. NATURAL GAS METERS

MMPP-0641 Munster Steel Company, Inc. 9505 Calumet Ave. Munster IN 46321 Unknown

Particulate matter, 

VOC's 1.80 

Structural steel fabrication: flame or mechanically cut steel, 

abrasive blasting, and spray coating. Structural Steel

MMPP-0657

Chief Industries, Inc. - Custom 

Products Division 1808 Raymond Road Grand Island NE

68802207

8

Minor or area 

source coating operations 10.69 

Fabricates steel doors, windows and furniture for the corrections 

facility industry. METAL FURNITURE

MMPP-0658 Dexter Axle Division - Plant 12 3075 E. Pearl St. Fremont IN 46737

Synthetic minor 

source Glycol Ethers - 

Trailer and utility axle manufacturers. Primary process - welding 

assembly & painting. Utility Axles

MMPP-0669

Union Pacific Railroad - Centennial 

Yard 3250 Kimzey Street Fort Worth TX 76107

Minor or area 

source 0.21 

Diesel engine service center, railcar maintenance shop, railroad 

switchyard Maintenance of Way Equiptment

MMPP-0670

Union Pacific Railroad - System 

Signal Shop

601 South Marshall 

Street Sedalia MO 65301

Minor or area 

source

True minor source 

based on emission 

inventory 0.21 Repair and overhaul railroad equipment Repair Railroad Equipment

MMPP-0710 ABB Power T&D Company, Inc.

300 N. Curry Pike, PO 

Box 341 Bloomington IN 47404

Minor or area 

source

All emissions below 

Title V requirements 0.96 

Manufacture of circuit breakers, reclosers, oil insturment 

transformers and arresters for electrical distribution and substation 

protection. Switchgear and switchboard apparatus

1
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

MMPP-0744 Modine Manufacturing Company 615 Bierley Road Pemberville OH 43450

Synthetic minor 

source

PTE calculation, 

limitation on regulated 

chemical emissions; 

Facility is a non-Title V 

source because it has a 

federally enforceable 

State Operating Permit 

(FESOP) for operations 

with air emissions 1.54 

Manufacture of products using shearing, forming, cleaning, welding, 

brazing, soldering, assembly, testing, painting, and packaging 

operations. Truck radiators

MMPP-0785

Broderson Manufacturing 

Corporation

14741 W. 106th 

Street Lenexa KS 66215 Unknown 2.11 Manufacturer of mobile hydraulic cranes. Mobile hydraulic cranes

MMPP-0789 TRT Heating Products Inc. 604 Liberty Lane West Kingston RI 02892

Minor or area 

source

Painting VOC HAP's 

content 3.44 Manufacturing facility producing unit & baseboard heaters. Heaters

MMPP-0821 Hytek Finishes Company 8127 South 216th St Kent WA 98032

Synthetic minor 

source Mass balance analyses 13.45 JOB SHOP-- Metal finishes. Ski Tops

MMPP-0943 Jayco Inc. 903 South Main Middleburry IN 46540

Synthetic minor 

source

Mass balance chemical 

emission calculations - 

234 TPY potential to 

emit VOC 24 buildings assembling recreational vehicles Recreational Vehicles

MMPP-0974 Modine Manufacturing Company

3300 W. Seventh 

Street Joplin MO 64801

Minor or area 

source

Actual and potential 

emissions of all criteria 

pollutants and HAP's are 

below applicable 

thresholds. Facility has 

state operating permits 

that limit process 

emissions.

Manufacture of products using machining, shearing, forming, 

welding, brazing, assembly, testing, cleaning, painting and 

packageing operation. Truck Oil Coolers

MMPP-0976

Modine Manufacturing CompanyKnoxville TN5050 S. National 

Drive Knoxville TN 37914

Minor or area 

source NA - 

Manufacture of aluminum oil coolers for off-highway applications 

(see comments). Aluminum Oil Coolers

MMPP-1019 Modine Manufacturing Company 600 Water Street Logansport IN 46947

Minor or area 

source

No VOC or HAP 

emissions are over 

regulatory levels.

Heat transfer equipment manufacturer with a non-HAP powder paint 

surface coating operation. Oil Coolers

MMPP-1021 Modine Aftermarket Holdings, Inc.

6309 South Central 

Avenue Los Angeles CA 90001

Minor or area 

source

Potential is lower than 

threshold values. - 

Manufacturer of vehicular radiator cores. This facility paints only a 

few units per month with a non-HAP containing coating. Radiator Cores

MMPP-1042 Chicago Blower Corporation 1675 Glen Ellyn Road Glendale Hgts. IL 60139 Unknown - Manufactures industrial blowers Industrial fans

MMPP-1052 Delong's, Inc. 301 Dix Rd. Jefferson City MO 65109

Minor or area 

source

State basic potential 

emissions from blasting, 

painting, plant heat less 

than 100 TPY. 

Calculations. 3.83 Fabricates structural steel and miscelaneous metal parts Fabricated Structural Metal

MMPP-1059 Modine Aftermarket Holdings, Inc.

7391 N.W. 78th 

Street Medley FL 33166

Minor or area 

source

Potential is lower than 

threshold 0.04 

Manufacturer of vehicular radiator cores. Certain customers require 

that these cores be painted. Radiator Cores

MMPP-1061 Modine Aftermarket Holdings, Inc.

2777 North Highway 

59 Merced CA 95348

Minor or area 

source

Potential is lower than 

threshold values. 0.23 

Manufacturer of vehicular radiator cores. Only a small portion of 

these products require painting. Radiator Cores and Completes

MMPP-1062 Modine Manufacturing Company 400 College Avenue Pemberville OH 43450

Synthetic minor 

source

Not classified as a title V 

facility. Facility has a 

Federally Enforceable 

State Operating Permit 

(FESOP) for operations 

with air emissions.

Manufacture of products using machining shearing, forming, 

welding, assembly, testing, cleaning, painting and creating 

operations. Industrial Oil Coolers & Radiators

MMPP-1068 Modine Manufacturing Company 822 Industrial Drive Trenton MO 64683

Synthetic minor 

source

VOC & HAP emissions 

from painting. 6.41 

Manufacturing facility producing copper/brass and aluminum 

radiators. Radiators

MMPP-1097

DANIEL MEASUREMENT AND 

CONTROL, INC.

9720 OLD KATY 

ROAD HOUSTON TX 77055

Minor or area 

source

The facility is not a major 

source of any criteria 

pollutants, and 

therefore, not subject to 

Title V. 15.72 Manufacturer of fluid meters and counting devices. Fluid meters and counting devices

MMPP-1107

Vulcraft-Utah, Division of Nucor 

Corporation

1875 West Highway 

13 South Brigham UT 84302 Unknown

Emission inventory and 

current approval order. 

Fugitive emissions 

question will resolve 

status. - 

Manufacturing of K-series, LH/DLH/SIS series, steel joist and 

related parts. Steel Joist

MMPP-1163 SMI Joist Nevada 2121 Trento Lane Fallon NV 89406

Minor or area 

source

VOC emissions>100 

tons/yr (includes fugitive 

emissions) 1.07 

Fabricator of steel span joists for commercial and industrial 

buildings. Joists are engineered structural members used to 

support roof decking. Steel Span Joists

MMPP-1234 Winnebago Industries Inc.

605 West Crystal 

Lake Road Forest City IA 50436

Minor or area 

source

Potential to emit >100 

ton/yr regulated 

pollutants, potential to 

emit >25 ton/yr 

combination of HAPs

Vertically integrated motor home manufacturing facility that includes 

vacuum forming and rotocasting of plastics, aluminum extrusion, 

cabinet making, and surface coating of steel, plastics, aluminum, 

and wood. Motor Homes

MMPP-1237 John W. Hancock, Jr., Inc. 2535 Duiguids Lane Salem VA 24153

Synthetic minor 

source

Permit limits for VOC 

and HAPs 3.02 Mfg. Open web steel joist and rack systems Joist and rack systems

MMPP-1272 SMI Owen Steel 2105 South Beltline Columbia SC 29201

Minor or area 

source

VOC emissions <100 

tons, HAP emissions 

<10/25 tons thresholds 8.83 Structural steel fabrication facility Structural Steel

MMPP-1273 Windsor Door - Little Rock Plant

5800 Scott Hamilton 

Drive Little Rock AR 72209 Unknown 3.15 Roll form and assemble overhead doors and components. Metal Forming & Assembly

MMPP-1275

American Buildings Co - Eufaula 

Plant

820 State Docks 

Road Eufaula AL 36027 Unknown Metal buildings systems manufacturer. Metal Buildings Pdts

MMPP-1277

American Buildings Co - LaCrosse 

Plant

501 Golden Eagle 

Drive LaCrosse VA 23950 Unknown Metal buildings systems manufacturer. Metal Buildings Products

MMPP-1282

Kewanee Boiler Manufacturing 

Co., Inc 101 Franklin Street Kewanee IL 61443

Minor or area 

source Annual air emissions. Manufacturer of commercial and industrial boilers. Boilers

2
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

MMPP-1289 Nucor Building Systems

305 Industrial 

Parkway Waterloo IN 46793

Synthetic minor 

source

IDEM permitting 

Process: Potential to 

emit VOC exceeds 

100TPY. 5.43 Metal building systems sales, engineering and fabrication. Metal Building Systems

MMPP-1310

American Buildings Co - El Paso 

Plant Rt 24 E El Paso IL 61738 Unknown Metal buildings systems manufacturer. Metal Buildings Parts

MMPP-1313

American Buildings Co. - Carson 

City Plant 2401Conestoga Drive Carson City NV 89706 Unknown Metal buildings systems manufacturer. Metal Buildings Pdts.

MMPP-1352 E/M Engineered Coating Solutions

One John Downey 

Drive New Britain CT 06051

Minor or area 

source

State of Connecticuy 

Consent Order that 

limits facility emmisions 

below Title V Status. 5.71 

39,000 sq/ft Cinder Block & Steel Building, used for the Application 

of Engineered Specification Coatings. Paints, Vanishes, Enamels

MMPP-1353

Alliant Techsystems--TCAAP 

Operations

Twin Cities Army 

Ammunition PlantBuilding 502 New Brighton MN 55112

Synthetic minor 

source

Mass balance & EPA 

emission factors. 1.99 

Manufacture finished metal piece parts, including surface coating, 

for defense products. Metal Parts & Units

MMPP-1366 Cummins Engine Co, Inc 4500 Leeds Ave Charleston SC 29405 Unknown

This site is permitted 

under both Title V and 

Conditional Major 

Permits. The Title V is 

for diesel engine test 

facility. 0.48 Manufactures combustion engines and parts Combustion engines and parts

MMPP-1441

Coleman Powermate 

Compressors 118 West Rock St. Springfield MN 56087

Minor or area 

source NA 13.50 Manufacture air compressors. Air & Gas Compressors

MMPP-1477 Custom Pipe Coating, Inc. 7177 Cavalcade Houston TX 77028 Unknown

>10 tons/yr VOC in 

nonattainment county 13.18 The operation cleans and coats steel pipe Steel Pipe

MMPP-1490 FARR Company 3501 Airport Road Jonesboro AR 72403 Unknown VOC / HAP emissions. Air filtration system manufacturer. Air Filtration Equiptment

MMPP-1494

Accessory Controls and 

Equipment Corporation

805 Bloomfield 

Avenue Windsor CT

06095232

2

Minor or area 

source

Emission limitations in 

connecticut general 

surface coating permit 

are below major source 

thresholds. 1.16 

Manufacturing business-ground support equipment and 

accessories for aircraft.

Air Conditioning and Industrial Refridgeration 

Eqi

MMPP-1495

Berenfield Containers, Inc. Mason 

Plant

1229/1234 Castle 

Drive Mason OH 45040

Synthetic minor 

source

Moderate attainment 

area with federally 

enforceable Ohio EPA 

permit # 14-83-09-0257. 23.70 

Two buildings used for manufacturing steel drums. One plant 

manufactures 55 gal drums by air assisted spray. It also roller 

coats drum shells-find ends for the small drum and drum ends for 

itself. Steel Shipping Containers

MMPP-1502 Flex-O-Lite, Inc. 2025 Hitzert Court Fenton MO 63026

Synthetic minor 

source Potential to Emit VOC's

Pavement reflective tape manufacturing facility (painted aluminum 

foil 0.003" thick). Pavement-marking tape

MMPP-1522 Eugene Welding Company 2420 Wills Street Marysville MI 48040 Unknown 13.41 Manufacturer of steel tubing and storage rack systems. Steel Tubing

MMPP-1538 Southern Post - Utah 920 W. 600 North Brigham City UT 84302

Minor or area 

source 3.57 Steel fence post manufacturing and painting facility. Steel Fence Post

MMPP-1606

Copperweld Bimetallics Metallon 

Division

690 Narragansett 

Park Dr. Pawtucket RI 02861

Minor or area 

source

Engineering Estimates - 

State of Rhode Island 

determined that Metallon 

is not a major source.

Mechanical cladding and roll coating of metals to produce metal 

composites with unique mechanical, physical, chemical and 

electrical properties to meet requirements of customers. Clad Metals

MMPP-1652 Copperweld Miami Division

9054 N. County Rd. 

25-A Piqua OH 45356 Unknown

Facility Manufactures low carbon welded steel tubing- processes 

include welding, drawing, cleaning, cutting and stenciling. Welded steel tubing

MMPP-1654 Copperweld Chicago Division 7401 S. Linder Ave. Chicago IL 60638 Unknown

Smaller source lifetime 

State Operating permit. CCD is a Manufacturer of Welded Steel Structural Tubing. Welded steel tubing

MMPP-1661 McElroy Manufacturing, Inc. 833 N. Fulton Tulsa OK 74115

Minor or area 

source Emission inventory

Provider of fusion equipment for polyolefin pipe and fittings, also fin 

tube machines. Standard metal working techniques are used. Pipe fusion equipment

MMPP-1860 Canam Steel Corporation

555 North Yearling 

Road Columbus OH 43213 Unknown 2.73 

Facility produces fabricated steel. The products vary in size and can 

be up to several tons. Joists, Girders and Bridging

MMPP-1900 Canam Steel Corporation 2002 Morgan Road Sunnyside WA 98944 Unknown - 

Facility produces fabricated steel. The products vary in size and can 

be up to several tons. Joists, Girders and Bridging

MMPP-1901 Canam Steel Corporation

140 South 30th 

Street, P.O. Box 5057 Lafayette IN

47903505

7 Unknown 0.33 

Facility produces fabricated steel. The products vary in size and can 

be up to several tons. Joists, Girders and Bridging

MMPP-1903 Canam Steel Corporation 2000 Main Street Washington MO 63090 Unknown 0.33 

Facility produces fabricated steel. The products vary in size and can 

be up to several tons. Joists, Girders and Bridging

MMPP-1905

Briggs & Stratton Poplar Bluff 

Missouri Plant Route 11 Box 20 Poplar Bluff MO 63901

Synthetic minor 

source

Permit limitations, 

emission calculations 

and material balance 1.85 

Facility manufactures air-cooled engines and engine components. 

Operatons at the facility include painting, machining, die cast, 

stamping, assembly and plating. Engines and engine components

MMPP-1909

Briggs & Stratton Statesboro 

Georgia Plant

7251 Zell Miller 

Parkway Statesboro GA 30458

Minor or area 

source

permit limitations, 

emission calculations, 

and material balance 7.90 

manufactures air-cooled engines and engine components. 

Operations at the facility include painting, machining, die cast, 

stamping, and assembly. Engine and engine components

MMPP-2055 DaimlerChrysler Sterling Stamping 35777 Van Dyke Sterling Heights MI 48084

Minor or area 

source

All pollutants are below 

major source status. - 

Steel is formed into various sizes for utilization in autombiles. 

Some assembly (welding and adhesives) takes place. Automotive Parts

MMPP-2099

Ford Motor Co. - Buffalo Stamping 

Plant

3663 Lake Shore 

Road Buffalo NY 14219

Minor or area 

source

Emission cap by rule 

(6NYCRR Part 201-

7.3(e) 1.58 metal stamping operations with some subassembly work Auto parts stamping

MMPP-2102

Ford Motor Co. Dearborn 

Stamping Plant 3001 Miller Road Dearborn MI

Minor or area 

source Engineering Evaluation. - 

Two million square foot facility located within Rouge Complex. 

Manufacturing of stamping and subassembly parts for various 

assembly plants. Metal Stampings

MMPP-2106

Ford Motor Co. Walton Hills 

Stamping Plant 7845 Northfield Road Walton Hills OH 44146

Minor or area 

source

Title V emission 

inventory initial 

engineering study 1995, 

and 1997 review. 0.22 

Automotive stamping plant performing sub-assembly of some 

components requiring sealants. Automotive Stampings

MMPP-2107

Ford Motor Co. Woodhaven 

Stamping Plant 20900 West Road Woodhaven MI 48183

Minor or area 

source

Inventory of regulated 

air pollutant emissions 

and regulatory review. - 

Automotive stampings, automotive body sub assembly involving 

resistance welding and application of sealers. Automotive Stampings

MMPP-2113 DaimlerChrysler Detroit Axle 6700 Lynch Road Detroit MI 48234

Synthetic minor 

source FESOP for NOx 4.49 

The primary activity at the Detroit Axle Plant is manufacturing of 

automotive axles. The facility is a supplier and producer of gears, 

brake systems, and sway bars. Automotive Products

3
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

MMPP-2118

Daimler Chrysler Mound Road 

Engine 20300 Mound Road Detroit MI 48234

Synthetic minor 

source FESOP for NOx Manufacture Automotive V6, V8, and V10 Engines. Internal Combustion Engines

MMPP-2120

Daimler Chrysler Toledo 

Machining 8000 Chrysler Drive Perrysburg OH 43551

Synthetic minor 

source

Limit natural gas usage 

to keep NOx emissions 

below 100 tons per 

year. - Manufacture Steering Column and Transmission Parts Steering Column Tubes

MMPP-2121

Daimler Chrysler Twinsburg 

Stamping Plant

2000 East Aurora 

Road Twinsburg OH 44087

Synthetic minor 

source

FESOP for NOx and 

VOC - 

Stamp metal automotive parts, assemble doors and liftgate for 

Minivans, sport utility vehicle and automobiles. Automotive Parts

MMPP-2125 New Venture Gear - Syracuse

6600 New Venture 

Gear Dr. East Syracuse NY 13057

Synthetic minor 

source FESOP for NOx 0.00 

Manufactures manual transmissions, transaxles, transfer cases, 

differential cases and gear sets. Automotive Parts

MMPP-2154

Delphi Interior & Lighting Systems, 

Vadalia Ops

250 Northwoods 

Boulevard Vandalia OH 45377

Synthetic minor 

source Permit Limitations 5.46 

Manufacturer of miscellaneous parts and subassemblies for 

automotive and light-duty truck applications. Auto. Parts and Products

MMPP-2158

Delphi Automotive Systems, 

Kettering II Plant

4991 Hempstead 

Station Drive Kettering OH 45429

Minor or area 

source

Less than Title V major 

source thresholds 3.38 Assembly and finishing of automotive struts Struts

MMPP-2172

GM Powertrain Fredericksburg 

Components 11032 Tidewater Trail Fredericksburg VA 22408

Minor or area 

source

Emission inventory 

determined that plant is 

a Title V - Minor source. Manufacturer of Automotive Transmission Components Transmission Torque Converter Clutch

MMPP-2182 Canam Steel Corporation 50 Eastman Street Easton MA

02334124

5

Minor or area 

source

PTE well below 

thresholds 0.18 

Facility produces structural steel. The products vary in size and 

shape. Structural Steel Parts

MMPP-2183 Amtrol, Inc. (KY) 3200 Bullardtreet Paducah KY 42003

Minor or area 

source

Kentucky DEP Permit S95-015. 0.05 

Manufactures non-refillable pressurized metal tanks. Process 

operations include pressing, punch, welding, brazing, cleaning, 

coating, finishing, and packaging. Metal Tanks

MMPP-2192 Risdon Corporation 60 Electric Avenue Thomaston CT 06787

Synthetic minor 

source

Synthetic minor perit 

application filed with the 

State

Manufacturing of cosmetic spray pumps and caps for fragrence 

industry Metal Cosmetic Closures

MMPP-2200

Therma-Tru Corporation HMF 

Division 306 Old Dairy Road Wilmington NC 28405 Unknown

Air emissions inventory - 

not title V. 1.10 Hollow metal door manufacturing; metal door frame manufacturing. Metal Door Frames

MMPP-2203 Therma-Tru Corporation

18515 North Dixie 

Highway Bowling Green OH 43402 Unknown

de minimus based on 

AEI 0.09 Hollow metal door manufacturing. Metal Doors

MMPP-2204

Tectron Division of Allied Tube & 

Conduit

650 Heritage Road, 

P.O. Box 5007 De Pere WI 54115 Unknown

Facility is exempt based 

upon MTE < 10 tons

Convert steel coil to steel tubing. Two rolling mills. Three cutting 

machines. One mill coats periodically with clear coat lacquer. Steel Tubing

MMPP-2205

A-G Safety Sales and Service of 

Alabama 35580 Highway 59 Stapleton AL 36578 Unknown Factory owned relief valve sales and service center valves

MMPP-2207 Babcock & Wilcox Company

East 1/2 Mile Street, 

P.O. Box 1297 West Point MS 39773

Synthetic minor 

source

Emissions survey for 

VOC, particulate matter 

(PM), SO2, NOx, CO, 

TRS, LEAD, 

CFCs/HCFCs, HAPs 

(VOC/non-VOC). 19.97 Onshore facility - fabrication of structural steel and tubing. Structural Steel and Tubing Fabrication

MMPP-2208 Diamond Power International

2600 East Main 

Street, P.O. Box 415 Lancaster OH 44130

Synthetic minor 

source

Xylene, Toluene, and 

total hazardous air 

pollutants.Application to 

be submitted in early 

1999. 4.76 Manufacturer of boiler cleaning equipment Water Gauges

MMPP-2210

J. B. Smith Manufacturing 

Company 6618 Navigation Blvd Houston TX 77001 Unknown 0.67 

A 1.7 acre facility, employing 75 people that manufactures pipe 

nipples Swages

MMPP-2211 S-B Power Tool Company

250 Bolton Sullivan 

Drive Herber Springs AR 72543

Synthetic minor 

source

Styrene varnish of motor 

armatures & fields. 156000 sqft power tool manufacturing plant Power Tools

MMPP-2213 Morin Actuator 110 Commerce Drive Pelham AL 35124 Unknown Machining and assembly for pneumatic/hydraulic valve actuators Valve actuators

MMPP-2215 Grinnell Corporation

10210 Statesville 

Road Cleveland NC 27013 Unknown 0.11 

Machining, assembly, and testing of various water meters and fir 

protection valves and devices. water meters

MMPP-2217 Ansul Fire Technology Center Pierce Avenue Marinette WI 54143

Synthetic minor 

source Throughput 16.33 

Manufacture wheeled and stationary pressure tanks for fire control 

units Pressure Tanks

MMPP-2221 ABB Power T&D Company Inc. 201 Hickman Drive Sanford FL

32771820

1 Unknown 1.68 

Manufacture low and medium voltage switchgear with the following 

processes, painting, plating, epoxy coating and plastisol dip. Low & Medium Voltage Switchgear

MMPP-2223

A-G Safety, Sales and Service of 

Texas 2303 Decker Drive Baytown TX 77520

Minor or area 

source

Emit less than 3 tons 

per year: small quantity 

generator. 1.78 

Sales & service company that assembles & repair pressure relief 

valves. Sales & Service of Pressure Relief Valves

MMPP-2224 Allied Tube & Conduit 2525 N. 27th Ave. Phoenix AZ 85009

Synthetic minor 

source

Maricopa County Air 

Permit #97-0297. 10.66 

Manufacturer of welding metal, sprinkler, fence and mechanical 

tubular products. Metal Pipe Products

MMPP-2225 Yarway Corporation 480 Norristown Rd. Blue Bell PA 18914 Unknown Machine shop using turning, grinding, and welding operations Valves

MMPP-2226

Grinnell Corporation- Flow Control 

Division

2870 Old Jackson 

Road Henderson TN 38340

Minor or area 

source 0.18 Manufacturer of threaded, stamped, and fabricated metal products. Pipe Nipples

MMPP-2229 ABB Power T&D Company

2300 Mechanicsville 

Rd. Florence SC 29501 Unknown

150000 sqft. Facility with a machine shop, weld, paint, plate & 

assembly operations producing low & medium volt circuit breakers. Circuit Breakers

MMPP-2232 Kendall Sheridan 5439 State Route 40 Argyle NY 12809

Minor or area 

source Manufacturing facility of plastic surgical medical tubing and devices. Plastic Surgical Medical Tubing

MMPP-2233 Henry Pratt Company

401 South Highland 

Ave Aurora IL 60506

Minor or area 

source

Annual Emissions under 

25 tons. 11.73 

136,000 sq. ft. facility on 6.7 acres land in industrial zone in an 

urban area. Butterfly Valves

MMPP-2234 Henry Pratt Company 900 South Depot Ave Dixon IL 61021

Minor or area 

source

Annual Emissions - 

under 25 tons. 11.29 

160,000 sq. ft. facility on 7 acres of land in an industrial zone in a 

rural community. Rectangular Valves

MMPP-2235

Crosby Valve, Inc. (Anderson 

Greenwood/Crosby) 43 Kendrick St. Wrentham MA 02093 Unknown 1.03 

Machining and assembly of materials to make valves and testing of 

completed valve. Valves

MMPP-2237 Alliant Techsystems LAP Facility

29745 Alliant Drive, 

Gate 4 Wilmington IL 60481 Unknown 0.51 Load, assemble and package medium caliber amunition. Light Weight 30mm Ammunition

MMPP-2240 Tyco Value Added Systems 15 Tyco Drive Stafford Springs CT 06076

Minor or area 

source

Potential VOC 

emissions are less than 

50 tpy. 0.15 Contract Mfg. - Printed circuit assembly and heatsink fabrication. Heatsink

MMPP-2242 Johnstown America Corporation

Route 403, West 

Taylor Township Johnstown PA 15906

Synthetic minor 

source

VOC Emissions from 

painting of railroad cars. Railroad freight car maufacturer Railraod Freight Cars

MMPP-2252 Nelson Division - Mineral Point

856 Fair Street, P.O. 

Box 172 Mineral Point WI 53565

Synthetic minor 

source 3.28 Muffler manufacture. Mufflers

4
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

MMPP-2253 Nelson Division - Wautoma

431 Division Street, 

P.O. Box 680 Wautoma WI 54615

Synthetic minor 

source 5.39 Muffler manufacturer. Mufflers

MMPP-2257 Mueller Company - Cleveland

620 Industrial 

Boulevard Cleveland TN 37311

Synthetic minor 

source

Mostly exempt 

processes. 0.47 Manufacturer of stainless steel pipe products Service Clamps & Tapping Sleeves

MMPP-2260

Pines Trailer a Division of Great 

Dane Limited Par

1925 Harbor Front 

Road Greenville MS 38701

Synthetic minor 

source Not Applicable 17.00 Manufacturer of Truck Trailers Tuck Trailers

MMPP-2272 Rockwell Automation - Dodge 330 East Tenth Street Columbus IN 46131

Minor or area 

source

Engineer calculations & 

material mass balances 2.88 Manufacturer of gear reducers Gear Reducers

MMPP-2273 Rockwell Automation - Reeves 1225 7th Street Columbus IN Unknown Speed Reducers

MMPP-2275 Rockwell Automation - Athens

195 Collin Industrial 

Blvd. Athens GA 30613

Synthetic minor 

source Mass Balance 5.53 Assemble Electric Motors. Electric Motors

MMPP-2276 Rockwell Automation - Bogart 200 Whitehead Rd. Bogart GA Unknown Calculations (Exempt) Assemble Electric Motors. Electric Motors

MMPP-2277 Rockwell Automation - Madison 2855 Michigan Road Madison IN 47250 Unknown Electric Motor Manufacturing. Electric Motors

MMPP-2278

Rockwell Automation - Euclid 

Facility 24703 Euclid Ave. Cleveland OH 44117

Minor or area 

source 6.20 Manufacturer of Drive Systems. Drive Systems

MMPP-2290 RV Products Division 3050 N. St. Francis Wichita KS 67219 Unknown Manufacturing facility for room R.V. airconditioning. R.V. Air Conditioners

MMPP-2291

Paxton and Vierling Steel 

Company 5th and Avenue H Carter Lake IA 68101 Unknown

Paxton and Vierling 

Steel Co. has submitted 

a Voluntary Operating 

Permit, but has not 

received comments or 

instruction from the Iowa 

Department of Natural 

Resources. 6.41 PVS fabricates steel. Trucks, Trailers

MMPP-2293

Cives Steel Company, Northern 

Division 8 Church Street Gouverneur NY 13642 Unknown See comment sheet 3.73 

Steel fabrication shop that cuts, welds, bends, shears, punches, 

grinds, blasts, and paints structural steel for industrial and 

commercial structures. Fabricated structural steel

MMPP-2295 Tenneco Automotive - Monroe

1601 Highway 498 

North Paragould AR 72450

Minor or area 

source

Mass balance 

calculations

SIC 3714 manufacture of transportation equipment - specifically, 

motor vehicle parts and accessories Strut

MMPP-2296 The Pullman Company

503 Weatherhead 

Street Angola IN 46703

Synthetic minor 

source

Potential emissions are 

below Title V threshold 

levels 19.48 Rubber to metal suspension component manufacturer Torque rods/track bars

MMPP-2297

Tenneco Automotive - Monroe 

Anderson

416 A.M. Ellison 

Road Anderson SC 29621 Unknown

Less than 3 gallons of 

paint used in booth per 

year

Manufactures proto-type of shocks and struts. Machine rebuild and 

design - R&D Struts

MMPP-2298

Tenneco Automotive Engineering 

Center 3901 Willis Road Grass Lake MI 49240 Unknown

Due to extreme low 

volume of paint use Title 

V not applicable to this 

facility

Engineering center that designs, manufactures and tests 

automobile exhaust prototypes Tail pipe assemblies

MMPP-2302 Walker Manufacturing Company 3160 Abbott Lane Harrisburg VA 22801

Synthetic minor 

source

Emissions inventory and 

operational hours. Automotive Exhaust Systems Manufacturer. Mufflers & Pipes

MMPP-2309 North American Transformer 1200 Piper Drive Milpitas CA 95035

Minor or area 

source Air Survey done in 1995. 0.12 Power Transformer Manufacturer. Power Transformers

MMPP-2310 E/M Engineered Coating Solutions 2172 Old Highway 8 New Brighton MN 55112

Minor or area 

source

State of Michigan Air 

Permit that limits facility 

emmisions below Title V 

Status. 12.38 

50,000 sq/ft Concrete & Steel Building used for the Application of 

Engineered Specification Coatings. Paints, Vanishes, Enamels

MMPP-2312 E/M Engineered Coating Solutions 6525 Midway Road Fort Worth TX

76117538

6

Minor or area 

source

State of Texas Air 

Permit that limits facility 

emmisions below Title V 

Status. 5.09 

3 Concrete & Steel Buildings totaling 42,800 sq/ft, used for the 

Application of Engineered Specification Coatings. Paints, Vanishes, Enamels

MMPP-2313 E/M Engineered Coating Solutions

900 Calcon Hook 

Road Sharon Hill PA 19079

Minor or area 

source

State of Pennsylvania 

Air Permit that limits 

facility emmisions below 

Title V Status. 3.50 

30,000 sq/ft Cinder Block & Steel Building, used for the Application 

of Engineered Specification Coatings. Paints, Vanishes, Enamels

MMPP-2316 E/M Engineered Coating Solutions 875 Maude Avenue Mountain View CA 94043 Unknown Not Applicable. 1.77 

Application of solid film lubricants and conformal coatings to 

industrial parts. Semi-Conductor Manufacturing Equipment

MMPP-2318 Crispaire Division of Airxcel, Inc. 2002 Hoover Street Cordele GA 31015

Synthetic minor 

source Engineering Studies 2.74 Manufacturer of HVAC Equipment HVAC Equipment

MMPP-2319 Crispaire Division of Airxcel, Inc.

2385 Saturn Court 

NW Norcross GA 30092 Unknown 0.32 Manufacturer of HVAC Equipment HVAC Equipment

MMPP-2320 Regal Ware, Inc. 1100 Redmond Road Jacksonville AR 72076

Minor or area 

source

Minor Source. Emit less 

than 100 tons of VOC. Aluminum cookware maufacturers Metal Stamping

MMPP-2323 HighSteel Structures, Inc.

3501 W. Fourth 

Street Williamsport PA 17701

Synthetic minor 

source

VOC emissions less 

than 50 tpy, no single 

HAP in excess of 10 

tpy. Company decision. 8.88 

Production facility with fabrication paint, maintenance and office 

areas. Outside parking and storage areas. Structural steel bridge

MMPP-2332 The Vendo Company

7209 North Ingram 

Avenue Fresno CA 93650

Minor or area 

source

No major source of 

pollutants. 1.06 see comments Automatic Vending Machines

PPP101 Springs Transit 1210 S. Hancock

Colorado 

Springs CO 80903

PPP102

Mitsubishi Motor MFG. Of 

America, Inc.

100 N. Mitsubishi 

Motorway Normal IL 61761

Auto assembly plant that does plastic parts coating within this 

facility.

PPP106

New United Motor Manufacturing, 

Inc. (NUMMI) 45500 Fremont Blvd. Fremont CA 94538

Automobile and light-duty truck assembly plant. Processes include 

metal stamping, welding, assembly, coating and plastic molding. 

Ancillary processes include wastewater pretreatment.

PPP109 Wheeled Coach 1619 E. Essex Rd Hutchinson KS 67501

PPP111A

MSX International Special 

Vehicles - Mt. Elliot 9500 Mt Elliot Detroit MI 48211

Minor or area 

source Permit Limitations 15.34 

Fabrication of specialty cars, show car maintenance, misc. 

piecework. Windshield frame

PPP111AA

MSX International Special 

Vehicles - 275 Rex 275 Rex Blvd. Auburn Hills MI 48326

PPP111B

MSX International Special 

Vehicles - Lynch Rd 6334 Lynch Road Detriot MI 48234

Minor or area 

source Permit Limitations 0.69 Prowler Painting Hood Sides

PPP111BB MSX International Engineering 521 First ST Benicia CA 94510

PPP111C

MSX International Special 

Vehicles - Purks 4400 Purks Auburn Hills MI 48326

Minor or area 

source Permit Limitations 1.98 Prepping of vehicles; Painting of vehicles and misc. parts. Vehicle refinish

5
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP111CC

MSX International Staffing 

Services/Recruitment

22792 Centre Drive 

Suite 290 Lake Forest CA 92630

PPP111D

MSX International Special 

Vehicles - California 1343 E. Wilshire Ave Santa Ana CA 92705

PPP111E

MSX International Engineering & 

Engineering Illustration Services 255 Rex Blvd. Auburn Hills MI 48326

PPP111F

MSX International Marketing 

Services 1426 Pacific Drive Auburn Hills MI 48326

PPP111G

MSX International Diversified 

Document Solutions

12801 Prospect 

Street Dearborne MI 48126

PPP111H

MSX International Engineering 

Services 14661 Rotunda Dearborne MI 48120

PPP111I MSX International - Newman 22731 Newman Dearborne MI 48124

PPP111J MSX International - Garrison

19855 W. Outer Dr. 

Stes. 300 & 500 Dearborne MI 48124

PPP111K

MSX International Technical & 

Engineering Illustration Services 5361 Gateway Blvd Flint MI 48507

PPP111L

MSX International Enterprise 

Imaging

1464 John A. Papalas 

Dr Lincoln Park MI 48146

PPP111M

MSX International Accessory 

Services & Engineering Services

1120 John A. Papalas 

Dr Lincoln Park MI 48146

PPP111N

MSX International Engineering 

Services - Avis 32201 N. Avis Madison Heights MI 48071

PPP111O MSX International - Tech Row 999 Tech Row Madison Heights MI 48071

PPP111P MSX International - D.E.C.S 1765 Star Batt Rochester Hills MI 48309

PPP111Q MSX International - Southfield

28333 Telegraph, 

Stes. 115, 301, 400 Southfield MI 48034

PPP111R

MSX International Training 

Services

12220 E. 13 Mile 

Road Warren MI 48093

PPP111S

MSX International Special 

Vehicles - St Louis 11425 Moog Drive St Louis MO 63146

PPP111T

MSX International Staffing 

Services

336 W. Passiac 

Street Rochelle Park NJ 07662

PPP111U

MSX International Staffing 

Services

2636 NW 26th Ave, 

Ste. 206 Portland OR 97204

PPP111V

MSX International Staffing 

Services

1605 Beech St,. Ste. 

B El Paso TX 79925

PPP111W MSX International - Mandoline 1100 E. Mandoline Madison Heights MI 48071

Minor or area 

source Permit Limitations 0.18 Automobile prototype, design, and modeling Prototypes

PPP111X

MSX International Design Fab 

Center

30031 Stephenson 

Hwy Madison Heights MI 48071

Minor or area 

source Permit Limitations 1.31 Prototype fabrication of motor vehicles Prototypes

PPP112 Tower Automotive Products Co.. 3533 N. 27th St Milwaukee WI 53216

PPP114A ADAC Plastics, Inc. 2.01 

PPP114A ADAC Plastics Inc. - Saranac 6138 Riverside Dr Saranac MI 48881

Minor or area 

source Potential Emissions 2.01 

This facility molds, paints and assembles Cowl panels (leaf 

screens) then ships to Ford for assembly. They are molded out of 

2 different plastics then only painted black using a waterborne paint. Cowl panels

PPP114B

ADAC Plastics Inc. - Grand 

Rapids 10.59 

PPP114C ADAC Plastics, Inc. - Muskegon 2050 Port City Blvd. Muskegon MI 49442 15.33 

This facility molds, paints and assembles interior and exterior door 

handles and arm rest control panels. They are then shipped to 

various customers for assemble on vehicles. Door handles

PPP115A Prince Corp. Lakewood MFG 205 Douglas Ave. Holland MI 49424 Not Applicable 4.44 Assembly and manufacturing - interior automobile components Interior Automotive Components

PPP115B Prince Corp. - Maplewood Facility 88 48th Street Holland MI 49423 Not Applicable 2.06 

Automotive components-Interior automotive plastic part 

manufacturing Interior automotive components

PPP115C

Prince Corp. - Southview 

Campus

1600 S. Washington 

Ave Holland MI 49423 Potential Emissions 3.75 Automotive components MFG-Interior Automotive Parts. Interior automotive components

PPP115D

Prince Corp. - Beechwood 

Facility 205 Douglas Ave. Holland MI 49424 Interior automotive components - non-plastic.

PPP115E

Prince Corp. - Cottonwood 

Facility

1650 S. Washington 

St. Holland MI 49423 Automotive components mfg. - interior automotive parts.

PPP115F

Prince Corp. - Interior 

Technology 1776 Airport Ct Holland MI 49423 Non- plastic headliner manufacturing for the automotive industry.

PPP115G

Prince Corp. - Meadow Brook 

Facility 70 W. 48th St. Holland MI 49423 Interior automotive components - non-plastic.

PPP115H Prince Corp. - Technical Campus 915 E. 32nd St. Holland MI 49423 Product development of interior automotive components.

PPP116 Morton International 2910 Waterview Dr Rochester Hills MI 48309

This is a marketing, sales and technical lab facility for a coatings 

manufacture, Morton Int. No production of plastic parts is done at 

this location.

PPP117A Lescoa - Middleville Plant 900 E. Main St. Middleville MI 49333

Synthetic minor 

source Permit Limitations 3.10 

We coat and assemble ash trays, glove boxes and other misc. 

interior trim pieces for automotive assembly plants. Tail Lamp Housings

PPP117C Lescoa - Plant # 7 3225 32nd St. S.E. Kentwood Mi 49512

Synthetic minor 

source Permit Limitations 3.20 

This facility molds, paints and assembles interior trim components 

for automobile assembly plants. Shift Bezels

PPP118E

Magna International - Brighton 

Interior Systems

100 Brighton Interior 

Drive Brighton MI 48116 Unknown 0.64 

Brighton Interior Systems produces interior door panels for vehicles 

by casting & press operations. Vinyl door inserts

PPP120 Lyntex Manufacturing Co 4385 Garfield St. Ubly MI 48475

PPP121

Key Plastics, Inc. - Howell Division 

(Libralter Plastics Inc.)

1301 McPherson 

Park Dr. Howell MI 48843

PPP122A Seibert Oxidermo - Romulus

16255 Wahrman 

Road Romulus MI 48174

The Seibert Romulus site produces conductive primers and 

industrial coatings for the Automotive Industries and related 

markets.

PPP122B Seibert Oxidermo - Detroit 6455 Strong Avenue Detroit MI 48211

The Soubrette Detroit site produces only water based paint 

products for the Automotive Industries and related markets.

PPP123

H. A. Parts Products of Indiana 

Company 2200 St Rd 240 East Greencastle IN 46135 Unknown - We paint grilles, and other exterior parts for auto assembly plants. Side protector

PPP126A Leon Plastics, Inc. 22.18 

PPP126A Leon Plastics, Inc. 4901 Clay Ave. S.W. Grand Rapids MI

49548307

4 Unknown 22.18 

We paint rigid plastic as well as soft padded fe\lexible vinyl 

automotive interior trim. Knee bolsters

6
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP126B Leon Plastics, Inc.

PPP128 Pilkington Libby Owens-Ford Co.

11700 T.C. Clinton 

Rd. Clinton MI 49236

Add components to auto glass. No product is coated per definition 

given. Corp. verified by talking with Bruce Moore.

PPP130 Cooper Automotive Co. 400 East 2nd St. Boyertown PA 19512

Synthetic minor 

source Potential Emissions 3.24 Manufacture glass (and plastic) sealed beam headlamps. Plastic headlamp reflector

PPP131A Vaungarde, Inc. - Bradley 1000 Bradley St Owosso MI 48867

Minor or area 

source 3.52 Reaction injection molding and painting for auto industry. Spoilers

PPP131B Vaungarde, Inc. - Chestnut 630 Chestnut Owosso MI 48867

Synthetic minor 

source Actual Emissions 6.69 

Topcoating of plastic parts for automobile, agricultural and 

recreational industries. Fenders

PPP134 Grand Rapids Plastics, Inc.

4050 Roger B. 

Chaffee Grand Rapids MI 49518

Minor or area 

source Potential Emissions

GRP uses conventional air spray (one gun) and an air booth to 

apply solvent based paints to plastic parts for the automotive, 

household appliance, and office furniture industries. Refrigerator Grill

PPP137E

U.T. Automotive - Alma Molding 

Plant 1965 Williams Road Alma MI 48801

Minor or area 

source Potential Emissions

Facility injection molds numerous automotive trim parts for various 

OEMs. Only a small fraction of these parts are painted/coated. Plastic injection molded trim

PPP138G

Textron Automotive Company - 

Port Huron Operations 2100 Dove St Port Huron MI 48060

Synthetic minor 

source Potential Emissions 0.73 Manufacturer & finisher of interior automotive door trim. Interior door trim

PPP141 Purolator Products Company

PPP144A

Collins & Aikman Plastics, Inc - 

Homer Plant 300 Elm Street Homer MI 49245

Synthetic minor 

source 0.03 

The facility manufactures automobile interior plastic trim parts, such 

as armrests and interior panels. G-van Map Cpmpartment

PPP144B

Collins & Aikman Plastics, Inc - 

Manchester Plant

500 West Madison 

Street Manchester MI 48158

Synthetic minor 

source 7.84 

This facility manufactures automobile interior plastic trim parts, such 

as armrests and interior panels. ZJ Door Panel

PPP144C

Collins & Aikman Plastics, Inc. - 

St. Joseph 211 Kerth Street St. Joseph MI 49085

Minor or area 

source 21.88 Injecting plastic molding of interior automotive plastic parts. 5385

PPP144D

Collins & Aikman Plastics, Inc. - 

Williamston, Noble Rd 1560 Noble Road Williamstown MI 48895

Minor or area 

source 0.01 

The facility manufactures automobile interior plastic trim parts, such 

as armrests and interior panels. K-Special Bolster

PPP144E

Collins & Aikman Plastics, Inc. - 

Williamston, Progress Ct 845 Progress Court Williamstown MI 48895

PPP145 Atlantic Automotive Components 1285 N. Crystal Ave Benton Harbor MI 49022

Minor or area 

source Potential Emissions - Coating of plastic parts for interior of automobiles. Plastic Steering Cover

PPP148

Newcor Rubber and Plastics 

Group

1825 S. Woodward 

Ave. Suite 245 Bloomfield Hills MI

48302057

4

PPP149 Grand Haven Plastics, Inc. 1425 Aerial View Dr. Grand Haven MI 49417

Minor or area 

source 6.75 

G.H.P is an injection molder and finisher of thermoplastic parts 

offering spray painting (water borne), assembly, pad printing, hot 

stamping and sonic welding. Sun visor components

PPP150 American Commercial Vehicles 1100 N. Elm St Orrville OH 44667

PPP151 GHSP - Hart 1500 Industrial Drive Hart MI 49420

Synthetic minor 

source Permit Limitations 0.33 

Two types of plastic parts manufactured at the facility are robotically 

or hand-spray painted before use in either on-site or off-site 

assembly processes. Pad painting/printing on some of the parts is 

also performed. Lenses

PPP153

Marathon Ashland Petroleum LLC 

- Findlay, OH Garage 1500 Lima Ave Findlay OH 45840 Permit Limitations Automotive Painting (I.e., body parts, fiberglass) Truck/trailer Body Parts

PPP154 Schien Body & Equipment Co. North University Carlinville IL 62626

We own a dump Trailer Manufacturing Co. known as Schein 

Equipment Inc. Address RR#2 Box 232 Carlinville, IL 62626. We 

do not do any plastic coating of any kind. Owner John Schein 

(217)854-2513. Schein Body and Equipment Co closed down in 

1992.

PPP201 IBM Rochester 3605 Highway 52 N Rochester MN 55901

PPP203A

Unisys Corporation - Blue Bell, 

PA

Township Line & 

Union Meeting Rds. Bluebell PA 19424

UNISYS no longer manufactures at the Bluebell location. This 

facility is the world headquarters and houses administrative and 

corporate functions.

PPP203B

Unisys Corporation - Roseville, 

MN 2276 Highcrest Rd. Roseville MN 55113 Computer engineering and software development.

PPP203C

Unisys Corporation - Bldg C Salt 

Lake City, UT 420 N. 2200 W. Salt Lake City UT 84116

We are just an office site. No manufacturing is conducted here 

anymore.

PPP203D Unisys Corporation - San Diego 10850 Vin Frontera San Diego CA 92127

PPP206 Group Technologies, Inc.

10901 Malcolm 

McKinley Dr. Tampa FL 33612

Group Technologies, Inc. designs and assembles printed circuit 

card assemblies. Per conversation w/ Bruce Moore this activity is 

not categorized as coating of plastic parts or products.

PPP207 Technicon Industries, Inc. 4412 Republic Ct. Concord NC 28027 Flame laminators.

PPP209B Pitney Bowes - Milford 105 Woodmont Rd Milford CT

Minor or area 

source Potential Emissions 0.12 Spray painting of copier compounds for appearance. Photocopier covers

PPP209C Pitney Bowes - Newton Edmund Road Newton CT

Synthetic minor 

source Potential Emissions 0.08 

Spray painting of weighing scale platens and covers, for 

remanufactured product. platten

PPP209D Pitney Bowes - Danbury 34 Executive Drive Danbury CT

Minor or area 

source Potential Emissions meter covers

PPP215 Compaq Computer Corporation 20555 State Highway Houston TX 77070

PPP216 Ovation Instruments, Inc. 37 Greenwoods Road New Hartford CT 06057

Ovation Instruments is a manufacture of musical instruments and it 

is not in the business machine parts subcategory of the plastic parts 

and products surface coating industry.

PPP225 Motorola, Inc. - Corporate Offices

1303 E. Algonquin 

Rd. Schaumberg IL 60196

PPP237

Drake Communication Products 

Inc. 33 Comac Loop Ronkonkoma NY 11779

PPP242 Kewaunee Scientific Corporation

2700 West Front 

Street Statesville NC 28677

Manufacture laboratory (wood and metal ) furniture and fume hoods. 

No plastic parts.

PPP244 Ionedge Corporation 513,B, N. Link Lane Fort Collins CO 80524

PPP245 O'Sullivan Corporation 1944 Valley Avenue Winchester VA 22601

O'Sullivan owns and operates a polyvinyl chloride (PVC) 

(unsupported film) calendering facility. Once the PVC is made it can 

be coated, printed or laminated on a continuous web

PPP246 Pinnacle Technologies

16153 Common 

Road Roseville MI 48066

This facility is a prototype plastic tooling manufacturer. No 

production of parts is done at this facility.

PPP248 Hitemco 160 Old Bethpage Not Reported NY 11084

Minor or area 

source Permit Limitations - Not Reported Transducer blocks

7
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP250A

Lucent Technologies, Inc. - 

Denport West

1200 W. 120th 

Avenue Westminster CO 80234

The manufacturing and repair of BCS products including Enterprise 

Communication Office Platforms (ECOP), Call Centers, Message 

Management & Response (Octel Messaging), Small Business 

Systems (Merlin), and Misc. Wireless, & Data Networking Products, 

Wareho

PPP250AA

Lucent Technologies, Inc. - Little 

Rock Repair and Distribution 

Center

7400 Scott Hamilton 

Drive Little Rock AR 72209

Sort used telecommunication equipment and repair specific BCS 

product lines. Distribute refurbished product to customers. Also 

operate a telephone call center (National Parts Service Center) 

which provides overnight delivery of product to business custome

PPP250B

Lucent Technologies, Inc. - 

Power Systems 3000 Skyland Drive Plano TX 75149

Epoxy coating of large power transformers done by dipping 

transformers into tank of epoxy resin followed by curing in oven. No. 

VOC's present in Epoxy Resin.

PPP250BB

Lucent Technologies, Inc. - 

Charlotte Global Provisioning 

Center

6701A Northpark 

BLVD. Charlotte NC 28216

This facility conducts repair of network type equipment including 

circuit boards. It also conducts screening activities to find good 

units and circuit boards from a number of unknown quality units that 

have been purchased from service providers. The good

PPP250C

Lucent Technologies, Inc. - 

Columbus Works

6200 East Broad 

Street Columbus OH 43213 Manufactures wireless switches for the telecommunication industry

PPP250CC

Lucent Technologies, Inc. - 

Concord Technology Center 300 Baker Avenue Concord MA

01742216

8

Sales, Marketing, Design, Development, Assembly and Test of 

Data Networking Systems LAN and Wan Networking products

PPP250D

Lucent Technologies, Inc. - AG 

Communication Systems 333 East First Street Genoa IL 60135

PPP250DD

Lucent Technologies, Inc. - 

Cirent Semiconductor

9333 South John 

PKWY. Orlando FL 32819 Semiconductor Manufacture- Wafer Fabrication

PPP250E

Lucent Technologies, Inc. - 

Denport South 2929 Blaird Road Shreveport LA

71118382

3

Facility manufactures business phones and PBX switches, mostly 

through assembly of parts.

PPP250F

Lucent Technologies, Inc. - Red 

Hills Bell Lab 480 Red Hill Road Middletown NJ 07748

Facility estimated R & D Annual HAP Emission Rates previously 

submitted to the EPA

PPP250G

Lucent Technologies, Inc. - 

Murray Hill Bell Labs

600/700 Mountain 

Ave. Murray Hill NJ 07974

Facility estimated R & D Annual HAP Emission Rates previously 

submitted to the EPA

PPP250H

Lucent Technologies, Inc. - 

Network Software Center 2600 Warrenville Rd. Lisle IL 60532

Facility estimated R & D Annual HAP Emission Rates previously 

submitted to the EPA

PPP250I

Lucent Technologies, Inc. - 

Crawford Hill Bell Labs

791 Holdel-Keyport 

Road Middletown NJ 07748

Facility estimated R & D Annual HAP Emission Rates previously 

submitted to the EPA

PPP250J

Lucent Technologies, Inc. - 

Holmdel Bell Labs

101 Crawfords 

Corner Rd. Holmdel NJ 07733

Facility estimated R & D Annual HAP Emission Rates previously 

submitted to the EPA

PPP250K

Lucent Technologies, Inc. - 

Engineering Research Center

Carter Road(Route 

56) Princeton NJ 08542 R & D facility

PPP250L

Lucent Technologies, Inc. - 

Chester Bell Labs 50 North Road Chester NJ 07930

Facility estimated R & D Annual HAP Emission Rates previously 

Submitted to the USEPA.

PPP250M

Lucent Technologies, Inc. - 

Whippany Bell Labs 67 Whippany Road Whippany NJ 07981

Facility estimated R & D Annual HAP Emission Rates previously 

Submitted to the USEPA.

PPP250N

Lucent Technologies, Inc. - 

Indian Hill Main

2000 N.Naperville 

Road Naperville NJ 60566

Facility estimated R & D Annual HAP Emission Rates previously 

Submitted to the USEPA.

PPP250O

Lucent Technologies, Inc. - 

Omaha Works 120th and I Street Omaha NE

The Omaha Works is part of the Network Systems business unit of 

lucent Technologies and is located in Omaha, Nebraska on a 340 

acre site. The facility is engaged in manufacturing of 

telecommunications, data communication, video and audio system 

equipment.

PPP250P

Lucent Technologies, Inc. - 

Reading Facility 2525 N. 12th Street Reading PA 19612

Facility Manufactures Semiconductors, optoelectronic components, 

and related devices (SIC Code 3674) for the Information 

Management Industry

PPP250Q

Lucent Technologies, Inc. - 

Atlanta Works

2000 Northeast 

Expwy. Norcross GA 30071

Manufacture of optical glass fiber and fiber optic cable. Fiber is 

produced by depositing silica vapor onto pure glass tube then 

drawing the softened glass down to the required fiber diameter. 

Fiber optic cable is manufactured by coloring the glass fibers

PPP250R

Lucent Technologies, Inc. - 

Merrimack Valley Works 1600 Osgood St. N.Andover MA 01845

Merrimack Valley designs, manufactures, markets and customer 

supports transmission systems.

PPP250S

Lucent Technologies, Inc. - 

Litespec Optical Fiber L.L.C. 76 Alexander Drive RTP NC 27709 Manufactures fiber optic cables telecommunication industries

PPP250T

Lucent Technologies, Inc. - Fitel 

Lucent Technologies

201 Adamson 

Industrial Blvd. Carrollton GA

30117938

2

This facility manufactures loose tube fiber optic cable. The glass 

fiber is manufactured at other locations.

PPP250U

Lucent Technologies, Inc. - 

Mount Olive Product Realization 

Center

450 Clark Drive, 

International Trade 

Center Mount Olive NJ 07828

Assemble wireless telephone infrastructure equipment. 

Manufacture circuit packs for the wireless equipment.

PPP250V Lucent Technologies, Inc. - 555 Union Blvd. Allentown PA 18103122 Manufactures silicon wafers and semiconductor chip

PPP250W Lucent Technologies, Inc. -

7725 West Reno 

Avenue Oklahoma City OK 73127 Manufactures and assembles telecommunication

PPP250X

Lucent Technologies, Inc. - 

Phoenix Global Provisioning 

Center

3750 W. Indian 

School Road Phoenix AZ 85019

This location manufactures end of life cycle equipment that has 

been transferred from the larger Works location. It also has facilities 

for manufacturing state of the art equipment in small quantities. It is 

also a Global Provisioning Center engaged in wh

PPP250Y

Lucent Technologies, Inc. - 

Kansas City Global Provisioning 9501W.. 67th Street Merriam KS 66203

This location manufactures end of life cycle equipment that has 

been transferred from the larger Works location. It also 

manufactures custom cable assemblies. It also is a Global 

Provisioning Center that conducts whole order delivery of custom 

orders.

PPP250Z

Lucent Technologies, Inc. - 

Indianapolis Customer Information 

Center

2885 N. Franklin 

Road Indianapolis IN 46219

This location prints and distributes documents for both AT&T and 

Lucent Technologies

PPP301 Volant Ski Corporation

10601 W I-70 

Frontage Rd N CO 80033 Unknown 1.22 Manufacture of snow ski and snowboards Snow Skis

PPP302 Conarc Inc

20 School St. PO Box 

24 Terryville CT 06763

PPP303 BASF Corporation NA NA

PPP304 Hicks & Otis Prints, Inc. 9 Wilton Avenue Norwalk CT 06851

8
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP305A

Hasbro, Inc. - 1027 Newport Ave. 

Pawtucket 1027 Newport Ave. Pawtucket RI 02861

PPP305B

Hasbro, Inc. - 1011 Newport Ave. 

Pawtucket 1027 Newport Ave. Pawtucket RI 02861

PPP305C

Hasbro, Inc. - 200 Narragansett 

E. Providence

200 Narragansett 

Park Dr. E. Prividence RI 02916

PPP305D Hasbro, Inc. 615 Elsinore Place Cincinnati OH 45202 Unknown Not Applicable 0.34 Coating of toy prototypes for research and development. Toys, Prototypes

PPP305E Hasbro, Inc. - Hasbro Games 50 Dunham Rd Beverly MA 01915 Unknown 0.04 Marketing and R & D departments. Prototype molds

PPP306 Regal Finishing, Inc. 3927 Bessemer Coloma MI 49038

Synthetic minor 

source Permit Limitations 11.97 We coat a wide variety of plastic parts on a contract basis. Vehicular lighting equipment

PPP307A Hackney & Sons Inc.

PO Box 880 - 400 

Hackney Ave. Washington NC 27889

Minor or area 

source Potential Emissions 19.62 

We coat plastic slab which comprise approximately 10% of the total 

surfaces covered. The slabs are used on roll-up doors. Truck bodies, doors

PPP307B Kidron Inc

PO Box 17 - 13442 

Emerson Rd. Kidron OH 44636 All other forms - same as PPP307A

PPP307C Kidron Inc 3330 Flightline Dr. Lakeland FL 33811 All other forms - same as PPP307A

PPP307D Hackney & Sons Inc. 300 Hackney ave. Independence KS 67301

Minor or area 

source Potential Emissions 19.62 

(The functions at this location are the same as at the Washington 

NC facility - Reporting # PPP307A.) We coat plastic slab which 

comprise approximately 10% of the total surfaces covered. The 

slabs are used on roll-up doors. Truck bodies, doors

PPP308

Parker Hannifin Corporation, Finite 

Filter Division 500 Glaspie St. Oxford MI 48371

PPP309 Plascore, Inc. 615 N. Fairview Zeeland MI 49464

Manufacturer of honeycomb structures composed of laminated 

plastic tubing, aluminum sheets, and resinated nylon paper sheets, 

used for a wide variety of purposes. No coating of plastic parts, only 

adhesives (99% VOC free) are used at this facility.

PPP311 Cairn Studio 200 McKenzie Rd. Mooresville NC 28115

Cairn Studio is a manufacturer of polyester resin figurines with a 

pecan shell flour filler using a casting process. We are not a major 

source for the coating operations.

PPP312A Crown Group - Detroit Plant 6300 E. Seven Mile Detroit MI 48234

Misc. metal parts consisting of metallic and non-metallic 

components are coated under Mich. Rule 336.1621(9)(e) and as 

such are regulated under R. 336.1632.

PPP312B Crown Group - Ecorse PLT. 100 Mill St. Ecorse MI 48229

Current permits allow coating of plastic substrate parts. No plastic 

parts are currently being processed.

PPP312C Crown Group - Livonia PLT. 31774 Enterprise Livonia MI 48150

PPP312D Crown Group - Port Huron PLT. 1631 Dove St. Port Huron MI 48180

PPP312E Crown Group - Portland TN PLT. 133 Davis Portland TN 37148

PPP312F

Crown Group - Fort Wayne IN. 

PLT. 4301 Engle Rd Fort Wayne IN 46804

PPP313 Design House, Inc. 14700 Commerce Dr

Menmomnee 

Falls WI 53051 Unknown Not Applicable 7.93 

Application of paint to polystyrene shutters by spraying & cleaning 

of application equipment. Polystyrene plastic

PPP316 Central Coating Company, Inc 165 Shrewsburg St West Boylston MA 01583

Synthetic minor 

source Permit Limitations 4.47 

Central Coating Company Inc. applies E.M.I./R.F.I. Coating and 

cosmetic coatings on plastic housings for the computer, medical 

and business machine industries. Central Coating Co. Inc. is a job 

shop. Coating plastic housings

PPP317 Fontaine Modification Company 5135 Cougar Trail Rd Dublin VA 24084

This facility is providing surface coating of heavy duty truck bodies, 

bumpers, doors, and hangers. The coating category would be 

automotive and light duty trucks?

PPP319 Document Technologies

PPP319 Document Technologies 2265 W Desert Cove Phoenix AZ 85029

Minor or area 

source We recote our external copymachine covers. Copymachine covers

PPP320 Applied Composites, Corp. 333 North 6th St. St. Charles IL 60174

PPP321D

The Budd Company - Plastics 

Division

PPP323A

Wilson Sporting Goods Co. - 

Corporate Headquarters 8700 W. Bryn Mawr Chicago IL 60631

This location is the corporate headquarters - All employees at this 

location are office workers.

PPP323B

Wilson Sporting Goods Co. - 

Rosemont Tech Center

5551 N. Milton 

Parkway Rosemont IL 60018

PPP323D

Wilson Sporting Goods Co. - 

Greenville 206 Georgia St. Fountain Inn SC 29644

PPP323E Wilson Sporting Goods Company

PPP323F HYE Precision Products 745 Carroll St. Perry GA 31069

PPP323G

Wilson Sporting Goods Co. - 

Newbury PK

3533 Old Conejo Rd., 

Unit 103 Newbury Pk. CA 91320

PPP323H

Wilson Sporting Goods Co. - 

Sparta

4600 Roberts 

Mathers Hwy Sparta TN 38583

PPP323I

Wilson Sporting Goods Co. - 

Springfield 601 Central Ave. Springfield TN 37172

PPP323J

Wilson Sporting Goods Co. - 

Tullahoma 303 Wilson Ave. Tullahoma TN 37388

PPP324 JRLON, Inc. 4344 Fox Road Palmyra NY 14522

Minor or area 

source

We are a New York Sate permitted "small quantity" HAP 

source(1996VOC total emissions aprox 7,000#'s). Mr Mike Bryant 

of the Eastern Research Group informs us via phone that we were 

included in the database for this questionnaire in advert entry and 

are no

PPP325 W. Kendall & Sons, Inc. 10270 W. US Hwy. 30 Wanatah IN 46390

PPP328 Nero Plastics Inc. 401 S. Delaney Rd Owosso MI 48867 Unknown Permit Limitations 7.62 We are custom plastic-molders of various products. Truck body panels

PPP331 Shrock Mfg, Inc. 28531 Jami Dr. Elkhart IN 46515

PPP332 Diamond Brands Inc. 1800 Cloquet Ave. Cloquet MN 55720

PPP333A

Summit Polymers, Inc. - 

Kalamazoo 6700 Sprinkle Rd Kalamazoo MI 49001

Synthetic minor 

source Permit Limitations 12.59 Injection molding, painting for automotive parts. Automotive Plastic Parts

PPP333B

Summit Polymers, Inc. - Valley 

Plant 3140 E Kilgore Kalamazoo MI 49002

Synthetic minor 

source Permit Limitations 5.38 Injection molding of plastic automotive parts. Automotive Plastic Parts

PPP333C

Summit Polymers, Inc. - Syntech 

Plant

PPP333C

Summit Polymers, Inc. - Syntech 

Plant 1211 Progress St Sturgis MI 49091 Unknown

Injection molder, decorator & assembler of plastic parts for 

automotive interiors. plastic products

9
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP333E

Summit Polymers, Inc. - East 

Plant 6717 Sprinkle Rd Kalamazoo MI 49002

Synthetic minor 

source Permit Limitations 2.85 Injection molding & painting of plastic automotive parts. Automotive Plastic Parts

PPP333F

Summit Polymers, Inc. - 

Columbia Plant

1550 E Boone 

Industrial Blvd Columbia MO 65202

Minor or area 

source Permit Limitations 1.09 Injection molding & painting of plastic automotive parts. Automotive Plastic Parts

PPP334 Evaporated Coatings, Inc. 2365 Maryland Rd. Willow Grove PA 19090

We do not apply coatings as defined in Enclosure 1. Chemicals 

listed on Table 2 are not used.

PPP339 E-S Plastic Products ,Inc. 809 Mohr Ave Waterford WI 53185

Minor or area 

source Potential Emissions 0.00 

Custom plastic injection molder with pad printing and vacuum 

metallizing secondary operations. Timing Light parts

PPP341 Resinart 1621 Placentia Ave. Costa Mesa CA 92627

PPP342 American Mannequin

PPP342 American Mannequins Inc. 220 N. Sunset Ave. City of Industry CA 91744 Unknown

We manufacture mannequins and props for the retail environment. 

We paint the fiberglass mannequins. Mannequins

PPP343

Eyelematic Manufacturing 

Company, Inc. 1 Seemar Rd Watertown CT 06795

PPP346 Aeroquip Corp. 1035 Mecklenburg Mooresville NC 28115 Plant closed 4/1997.

PPP347 GenCorp Inc. 175 Ghent Road Fairlawn OH 44333330

PPP348 Sun Plastic Coating Co. 42105 Postiff Plymouth MI 48170

PPP356 Metro Plastics Technologies, Inc. 9175 E. 146th St. Noblesville IN 46060

Minor or area 

source Permit Limitations 0.08 

Plastic injection molding of miscellaneous parts. Coating operation 

on one production part - a cover site tube. Occasional use of spray 

coatings to illustrate customer color choices. Cover site tube

PPP357 General Electric Company - EMD

1350 South Second 

St. Coshocton OH 43812

This facility produces copper clad laminate for the printed wiring 

board industry. The five main processes are: Raw material receipt 

and storage; resin making; paper and fiberglass impregnation; 

lamination; and fabrication.

PPP359 Strick Corp. RR 8 Box 281 Danville PA 19030000

PPP362 The DECC Co. Inc 1266 Wallen Ave. SW Grand Rapids MI 49507

PPP363 Precision Dynamics, Inc. 1033 Carter Ave. Charlotte NC 28206

PPP365 Fleet Painting 708 Poplar Ave. Nashville TN 37210

We paint over-the-road van trailers and straight trucks (Ryder rental 

type trucks with 18-30 ft cargo boxes) for the trucking and service 

industries. We don't do body work or paint cars or light trucks.

PPP368A

Winona Corporation - Winona 

Lake 205 First Str. Winona Lake IN 46590

PPP368B Winona Corporation - Mentone PO Bos 527 Mentone IN 46539

PPP368C Winona Corporation - Elkhart 4519 Wyland Dr. Elkhart IN 46516

PPP369A

Flambeau Corporation - Blow 

Molding operating Division 715 Lynn Ave. Baraboo WI 53913

Minor or area 

source Actual Emissions Custom blow molding offering value add assembly, etc.. Tool container

PPP369B

Flambeau Corporation - Injection 

Molding Operating Division 801 Lynn Ave. Baraboo WI 53913

Minor or area 

source Potential Emissions Custom injection molding offering value add assembly, etc.. Hand sets

PPP369C

Flambeau Corporation - Micro 

Division

1655 Corporate 

Center Drive Sun Prairie WI 53590

Minor or area 

source Potential Emissions Custom injection molding offering value add assembly, etc.. 940373

PPP369D

Flambeau Corporation - Southeast 

Division 1330 Atlanta Hwy. Madison GA 30650

Minor or area 

source Potential Emissions Custom injection molding offering value add assembly, etc.. 067601

PPP371 SAS Rubber Company 474 Newell Str. Painsville OH 44077

PPP372

Akron Porcelain & Plastics 

Company 2739 Cory Ave. Akron OH 44314

PPP373 L & J of New England, Inc. 15 Sagamore Rd. Worcester MA 01605399

PPP375A Lincoln Composites - Main Plant 4300 Industrial Ave. Lincoln NE 68504

Synthetic minor 

source Permit Limitations

Manufacturer of a wide variety of specialty filament wound 

composite structures from glass, Kevlar or graphite with epoxy resin 

systems; made to individual customer specifications on a limited 

production scale. Products include pressure vessels for aerosp Waste Tanks

PPP375B Lincoln Composites - NGV 4131 N. 48th Street Lincoln NE 68504

Minor or area 

source Permit Limitations

Fabrication of all composite fuel tanks for fleet vehicles (buses) and 

automobiles and other uses using glass and carbon filament 

winding with an epoxy resin around a high density polyethylene 

(HDPE) thermoplastic liner. Natural gas vehicle fuel tanks

PPP375C Lincoln Composites - 820 4720 NW 38th Street Lincoln NE 68504

Minor or area 

source Permit Limitations

Fabrication of composite filament wound external fuel tanks for 

military customers. Tanks are wound around plastic or resin inner 

liners and painted to customer's specifications prior to shipping. External Aircraft Fuel Tanks

PPP376A M. H. Eby, Inc. - Blue Ball 1194 Main Street Blue Ball PA 17506

PPP376B

M. H. Eby, Inc., Ohio Division - 

West Jefferson 4435 State Route 29 West Jefferson OH 43162

PPP379 Carrom Company 218 E. Dowland St Ludington MI 49431

We use some plastic parts in assembly, and coat wood parts with 

sealers, finishes, inks & enamels; but do not coat any plastic 

products.

PPP382 Peerless Coatings, Inc. 1611 22nd St. SE Cullman AL 35055 Manufacture of wood and industrial coatings.

PPP383 Nautilus International Corp. 709 Powerhouse Rd. Independence VA 24348

PPP384 Jones Performance Products, Inc. 1.07 

PPP389A

GI Plastek Limited Partnership - 

Bellville 1202 Mill Road Bellville OH 44813

Manufacturer of plastic components that supports a variety of 

industries. NO coating operations are preformed at this facility.

PPP389B

GI Plastek Limited Partnership - 

Marysville 648 Clymer Road Marysville OH 43040

This facility produces injection molded parts for a variety of 

industries. NO coating operations are performed at this facility.

PPP389C

GI Plastek Limited Partnership, 

Dec-Rite Div. 692 Clymer Road Marysville OH 43040 Unknown 9.32 

This facility performs secondary assembly and finishing operations 

for plastic parts, most of which are molded by a company related 

injection molding plant that is located next door to it. Plastic top cover

PPP394 Plasti - Paint Inc 801 Woodside Dr St Louis MI 48880

Synthetic minor 

source Permit Limitations 7.00 We paint products for the automotive market. Plastic products

PPP395A

Burpee Company - Barrington 

Plant

128 West Liberty 

Street Barrington IL 60010

Synthetic minor 

source Potential Emissions 0.09 

The Burpee Company's Barrington plant fabricates and coats metal 

parts. However, some plastic parts are glued together and used in 

the final metal product. Gasket & Plastic backing

PPP395B Burpee Company - Cary Plant 170 Detroit Street Cary IL 60013

Minor or area 

source Potential Emissions - 

The Burpee Company's Cary plant produces miscellaneous plastic 

parts by injection molding. Some parts require gluing together to 

form the final product. Plastic holders

PPP396 Novabus Incorporated

42 Earl Cummings 

LPW Roswell NM 88201

PPP397 Massee Products Ltd. 2612 N 5th Street Niles MI 49120

10
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP398 FET Engineering, Inc. 903 Nutter Drive Bardstown KY 40004

PPP404 Sajar Plastics, Inc.

15285 South State 

Avenue Middlefield OH 44062

Products include various plastic parts that are painted/coated. 

These products include toys, misc. retail articles, medical, lawn & 

garden, entertainment, electrical, electronic, telecommunications, 

banking, business equipment and transportation articles

PPP405 Pharmacia & Upjohn Company 7000 Portage Road Kalamazoo MI 49001

PPP406 Newport Thin Film Laboratory Inc 4534 Carter Court Chino CA 91710

PPP407A MetoKote Corporation - Plant #6

3435 Stop Eight 

Road Dayton OH 45414 Electrocoating of miscellaneous metal parts.

PPP407B MetoKote Corporation - Plant #7

2945 South Gate 

Drive Sumter SC 29154 Electrocoating of miscellaneous metal parts.

PPP407C MetoKote Corporation - Plant #8

8186 Industrial Park 

Drive Grand Blanc MI 48439 Electrocoating of miscellaneous metal parts.

PPP407D MetoKote Corporation - Plant #9

5477 Evergreen 

Parkway Sheffield Village OH 44054 Electrocoating of miscellaneous metal parts.

PPP407E MetoKote Corporation - Plant #11 5750 State Route 251 Peru IL 61354 Electrocoating of miscellaneous metal parts.

PPP407F MetoKote Corporation - Plant #12 1540 Cainsville Road Lebanon TN 37090 Electrocoating of miscellaneous metal parts.

PPP407G MetoKote Corporation - Plant #13

8040 Center Point 70 

Blvd. Huber Heights OH 45424 Electrocoating of miscellaneous metal parts.

PPP407H MetoKote Corporation - Plant #14 702 Lewiston Road Grovetown GA 30813 Electrocoating of miscellaneous metal parts.

PPP407I MetoKote Corporation - Plant #15

312 Savannah Park 

Road Cedar Falls IA 50613 Electrocoating and wet coating of miscellaneous metal parts.

PPP407J MetoKote Corporation - Plant #17 7251 Zellmiller Pkwy. Statesboro GA 30458 Electrocoating of miscellaneous metal parts.

PPP407K MetoKote Corporation - Plant #18

43963 Plymouth Oaks 

Blvd. Plymouth MI 48170 Electrocoating of miscellaneous metal parts.

PPP407L MetoKote Corporation - Plant #19 4040 Vista Drive Roanoke VA 24019 Powdercoating of miscellaneous metal parts.

PPP407M MetoKote Corporation - Plant #21

6615 Maumee 

Western Road Maumee OH 43537

Electrocoating, powdercoating, and wet painting of miscellaneous 

metal parts.

PPP407N MetoKote Corporation - Plant #22 3116 N. Wilson Ct. Walker MI 49544 Electrocoating of miscellaneous metal parts.

PPP407O MetoKote Corporation - Plant #23 6703 NC Highway 55 Fuquay Varina NC 27526 Electrocoating of miscellaneous metal parts.

PPP407P MetoKote Corporation - Plant #24

2320 Northeast 

Avenue Waterloo IA 50703 Electrocoating of miscellaneous metal parts.

PPP407Q MetoKote Corporation - Plant #26

9610 Corporate Park 

Dr. Loudon TN 37774 Electrocoating of miscellaneous metal parts.

PPP407R MetoKote Corporation - Plant #27 100 S.L. White Blvd. LaGrange GA 30241 Electrocoating of miscellaneous metal parts.

PPP407S MetoKote Corporation - Plant #28 3015 5th Ave. East Moline IL 61244 Electrocoating & powdercoating miscellaneous metal parts.

PPP407T MetoKote Corporation - Plant #29

5000 Wommack 

Road Sanford NC 27330 Electrocoating and wet painting of miscellaneous metal parts.

PPP407V MetoKote Corporation - Plant #1 1075 Prosperity Road Lima OH 45801

This plant is research and development only, no full production is 

completed at this facility.

PPP408 Viking Pools Inc.

PPP411 Marlam Industries, Incorporated

834 E Hammond 

Lane AZ 85034

This facility manufactures cultured marble products such as tubs, 

sinks, etc. Also, the facility manufactures laminated countertops and 

corian. The painting or coating of plastic parts does not occur at this 

facility.

PPP412

Onvoy / Division of Badger Plug 

Company 610 Beliot Road Walworth WI 53184

PPP415 S R of Arkansas - 

PPP416

Astro Industries Inc. - Division of 

Borden Chemical 114 Industrial Blvd. Morganton NC 28655

PPP417 Select Engineering, Inc. 260 Lunenburg Street Fitchburg MA 01420

PPP418 Risdon AMS 60 Electric Ave. Thomaston CT 06787

Synthetic minor 

source Actual Emissions 4.24 

Mold components for assembly of cosmetic pumps. Vacuum 

metalizing of cosmetic closures (caps) for fragrance industry. Cosmetic caps

PPP420B

Polaris Industries, Inc. - Spirit 

Lake 17.34 

PPP420B

Polaris Industries, Inc. - Spirit 

Lake 1900 Hwy 71 Spirit Lake IA 51360

Synthetic minor 

source Permit Limitations 17.34 

Polaris Industries, Inc. designs, engineers, manufactures and 

markets snowmobiles, all-terrain vehicles, personal watercraft and 

motor cycles for recreational and utility use. Watercraft

PPP422 Viskase Corporation 106 Blair Bend Drive Loudon TN 37774

PPP425A Contempoary Products - Plant 1

N57 W13580 

Reichert Ave.

Menomonee 

Falls WI 53051 7.16 

PPP425B

Contemporary Products, Inc. - 

Plant 2

N57 W13282 Carmen 

Ave

Menomonee 

Falls WI 53051

PPP425C Contemporary Products, Inc. CBI

PPP425D Contempoary Products - Plant 4

N56 W13640 Silver 

Spring Ave

Menomonee 

Falls WI 53051

PPP427B

Thomasville Furniture Industries, 

Inc. - Plant B

PPP427E

Thomasville Furniture Industries, 

Inc. - Plant E/COF/CDK/New Y 1425 Unity Street Ext. Thomasville NC 27360

PPP427F

Thomasville Furniture Industries, 

Inc. - Fayette Plant

Jefferson Industrial 

Park Fayette MS 39069

PPP427G

Thomasville Furniture Industries, 

Inc. - Upolstery Cutting Plant # 8

890 F Avenue Drive 

SE Hickory NC 28602

PPP427I

Thomasville Furniture Industries, 

Inc. - Sawmill Plant 4003 Hwy 321-A Hudson NC 28638

11
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP427J

Thomasville Furniture Industries, 

Inc. - Johnson City Plant 815 Love Street Johnson City TN 37605

PPP427K

Thomasville Furniture Industries, 

Inc. - Plant N 150 Jennings Street Thomasville NC 27360

PPP427M

Thomasville Furniture Industries, 

Inc. - Smethport Lumber Yard 151 Smethport Drive West Jefferson NC 28694

PPP427N

Thomasville Furniture Industries, 

Inc. - Conover Plant

1118 Old Hwy 70A 

West Conover NC 28613

Synthetic minor 

source Potential Emissions

We manufacture wood furniture, which may contain plastic parts 

such as decorative moldings, feet, etc.. Upholstered furniture

PPP427O

Thomasville Furniture Industries, 

Inc. - Upolstery Plant 7

2260 Highland 

Avenue Hickory NC 28601

PPP427Q

Thomasville Furniture Industries, 

Inc. - Upolstery Cutting Plant 6

3165 Highland 

Avenue Conover NC 28613

PPP427R

Thomasville Furniture Industries, 

Inc. - Carysbrook Plant Route 15 & 615 Fork Union VA 23055

PPP427S

Thomasville Furniture Industries, 

Inc. - Statesville Plant 820 Cochran Street Statesville NC 28677

PPP427T

Thomasville Furniture Industries, 

Inc. - Troutman Plant 4

350 Old Murdock 

Road Troutman NC 28166

PPP427U

Thomasville Furniture Industries, 

Inc. - Troutman Plant 3 Old Murdock Road Troutman NC 28166

PPP430 Timpte Inc. 1827 Industrial Drive David City NE 68632

Timpte is not subject to the submittal of information on the 

questionnaire because Timpte Inc. only surface coats metals.

PPP431 The Shelburne Corporation 6221 Shelburne Road Shelburne VT 05482

PPP432 Southern Defense Systems, Inc. 168 Technology Way Eastaboga AL 36260

PPP433 Genesee Coatings, LLC 56 Harvester Ave. Batavia NY 14020 Note: Exempt per Bruce Moore (less than 25 gallons per month)

PPP434

American Coatings Technologies, 

Inc. 200 Industrial Blvd. Greenville NC 27834

PPP437

General Electric Company - d/b/a 

GE Plastics 1 Lexan Lane Mt. Vernon IN 47620 CBI CBI Coating of plastic sheet and plastic film. Extrusion/coating of plastic sheets/film

PPP438 Vincent Industrial Plastics, Inc. 920 North Adams St Henderson KY 42420

PPP439

Asheville Paint and Powder Coat, 

Inc. 16 Old Charlotte Hwy Asheville NC 28805 Commercial powder coater of ferrous and non-ferrous metal parts.

PPP441 DeKalb Molded Plastics Company 6422 US 6 West Butler IN 46721

Minor or area 

source Potential Emissions 2.23 Structural Plastic Molding and Finishing Plastic Parts

PPP442 Mattel - Murray 307 Poor Farm Rd. Murray KY 42071

PPP446 SHAT-R-SHIELD 116 Ryan Patrick Dr. Salisbury NC 28147

PPP447A

Worthington Custom Plastics, Inc. 

- Lebanon 655 Industrial Drive Lebanon KY 40033

PPP447D

Worthington Custom Plastics, Inc. 

- St. Mathews 130 Worthington Dr. St. Matthews SC 29135 Unknown

Injection molded plastic parts producer. Some products receive 

conventional "wet Paint" coating applications and final assembly. 

Primary market served is automotive and lawn and garden. Plastic Tractor side frames

PPP448A

Mack Molding Company - Inman 

Plant

PPP449

Menasha Corporation - Montec 

Plastics 96 Palmer Road Monson MA

01057021

7

Minor or area 

source Potential Emissions 1.24 

Producer of custom injection molded plastic parts for a variety of 

industrial customers. Electronic equipment covers

PPP450 J. H. Emerson Co. 22 Cottage Park Ave Cambridge MA 02140

PPP451 NYPRO Colorado 805 S Lincoln St. Longmont CO 80501

PPP452 Danmar Products, Inc.

221 Jackson 

Industrial Drive Ann Arbor MI 48103 Unknown 11.48 

We coat a foam product for the handicapped population, such as 

wheelchair cushions, helmets and floatation devices for swim 

therapy. Assistive Medical Devices

PPP453 K C Industries, Inc. 741 Waverly Court Holland MI 49423

Synthetic minor 

source Permit Limitations 0.01 

KC Industries is a job shop that finishes wood, metal and plastic 

substrates. We perform powder coat and wet coat application. We 

have both batch and overhead operations. 9593W, Primer

PPP455

Cardinal Scale Manufacturing 

Company 203 East Daugherty Webb City MO 64870

PPP4584

Donnelly Corporation - 40th 

Street facility 40th Street Holland MI 49423

PPP458A Donnelly Corporation - Arizona

4400 S Santa Rita 

Avenue Tuscan AZ

85714164

2

PPP458G

Donnelly Corporation - Grand 

Haven 1800 Hayes Grand Haven MI 49417

PPP458I

Donnelly Corporation - 128th 

Avenue North 128th Avenue North Holland MI 49424

PPP458J

Donnelly Corporation - North 

Industrial Complex John F Donnelly Drive Holland MI 49424

PPP458K Donnelly Corporation - Kentucky One Morgan Place Mt. Sterling KY 40353

PPP458N

Donnelly Corporation - Newaygo 

Facility 700 S. Park Dr. Newaygo MI 49937

PPP459A Spensor Industries, Inc. 902 Buffaloville Rd. Dale IN 47523

Custom fabrications/molding of thermo formed plastic for appliance 

housings, housings for exercise equipment, housings for projector 

TV's, refrigeration housings on trucks, etc.

PPP459B Spensor Industries, Inc. 16 Dunn St. Dale IN 47523

Minor or area 

source Potential Emissions 6.43 

Custom fabrications/molding of thermo formed plastic for appliance 

housings, housings for exercise equipment, housings for projector 

TV's, refrigeration housings on trucks, etc. Housings for Refrig. Units on trucks

PPP460

St. Croix of Park Falls, LTD (St. 

Croix Fishing Rods) 856 4th Ave N. Park Falls WI 54552 Unknown 0.03 

Painting fishing blanks by means of a squeegee process. This is all 

done manually! No control devices are used! Fishing rod blanks

PPP463 Goodyear Tire & Rubber Co.

PPP465 GZA GeoEnvironmental, Inc.

North 4140 

Duplainville Pewaukee WI 53072

PPP469B

Green Tokai Company LTD. - 

Maysville 1780 Downing Drive Maysville KY 41086

Minor or area 

source Potential Emissions 0.22 

Manufacture automobile moldings by plastic extrusion, injection 

molding and finishing processes Weather-strip molding

PPP470 American Extruded Plastics Inc. 938 Reynolds Place Greensboro NC 27403 Custom extrusion of plastic.

PPP472 3-D Manufacturing Company, Inc. 500 Airport Drive Shawano WI 54166

Synthetic minor 

source Permit Limitations

3-D Manufacturing, Inc. produces, finishes and paints emergency 

response vehicles (fire trucks, Ambulances. Etc.) Emergency Response Vehicles

12
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP475

Amery Technical Products 

(AMTEC, Inc.) 241 Venture Drive Amery WI 54001

PPP476B Eastman Kodak Company - KPG 460 Buffalo Road Rochester NY 14652

Synthetic minor 

source Potential Emissions

The facility serves as a manufacturing and research center for 

electronic imaging media, aluminum optical media dicks and 

polycarbonate writable CD dicks are coated via spin coat 

technology. Coating applied to polycarbonate disks are restricted 

to resear Aluminum optical media disks

PPP476C

Eastman Kodak Company - Kodak 

Colorado Division

9952 Eastman Park 

Drive Windsor CO

80551159

0

PPP477A

LaCrosse Footwear, Inc. - 

Claremont Division 401 Washington St. Claremont NH

03743277

6

PPP478 Rehau Incorporated 1110 N. Clay Street Sturgis MI 49091

Synthetic minor 

source Permit Limitations

Gravure coating of vinyl trim ("edgeband") for the furniture industry. 

Profiles are extruded then coated in-line. Vinyl (PVC) T-Molding

PPP479 Midwest Plastic Engineering, Inc. 1501 Progress Sturgis MI 49091 Unknown 0.01 Spray painting of plastic parts. Plastic parts

PPP485 Aero Spec Paint & Finish, Inc. 3215 Bennett St. N. St Petersburg FL 33713

PPP487B Artic Cat Inc. - Thief River Falls

601 Brooks Avenue 

South Thief River Falls MN 56701

PPP488A Mack Molding Company - Inman 10769 Asheville Hwy Inman SC 29349

Synthetic minor 

source Permit Limitations 17.51 

We mold, assemble, and paint a wide variety of plastic parts on a 

contract basis. Plastic parts

PPP488B

Mack Molding Company - 

Statesville 149 Water Tank Road Statesville NC 28677

Synthetic minor 

source Permit Limitations

We are an injection molding facility + we coat a wide variety of 

plastic parts that we mold. As of 11-9-98 we are around 85% waterbased paints. Plastic Parts

PPP490 Christian Brothers, Inc. 1001 State Ave. North Warroad MN 56763

PPP494 Rutland Plastic Technologies, Inc. 10021 Rodney St. Pineville NC 28134

PPP497 Kenro Incorporated 200 Industrial Drive Fredonia WI 53021

PPP499

McClain E-Z Pack (formerly Galion 

Solid Waste Equipment, Inc.) 500 Sherman St. Galion OH 44833

Manufacturer of refuse equipment - Front loaders - side loaders - 

rear loaders, etc.

PPP502 AMF Bowling Products, Inc. 8100 AMF Drive Mechanicsville VA 23111

PPP503 Astro Cap Manufacturing, Inc.

PPP504 Wilson Marble, Inc. 1134 E. Wabash O'Fallon MO

63366277

4 Unknown Potential Emissions

Marble casting operation. Gel applied to molds via HVLP equip. in 

spray booth, marble matrix hand applied to molds - open - 

semiclosed. Vanity tops

PPP506

Knapheide Manufacturing 

Company 436 South 6th St Quincy IL 62301

PPP509 Exxene Corporation

PPP510 Arkay Plastics Illinois, Inc.

PPP510 Arkay Plastics Illinois, Inc. 2009 S. Main St. Paris IL 61944 Unknown Permit Limitations

Plastic injection molding of automotive parts and other customer 

items (TV set cases); spray painting of molded parts; adhesive 

spray painting for parts assembly; and foam-in-place molding of 

automotive parts. Plastic automotive parts

PPP511

GAC Plastics, LLC (formerly 

Glass Alternatives Corp.)

65 Fochtman 

Industrial Dr. Petaskey MI 49770 7.04 

Coating and painting a variety of molded plastic parts on a contract 

basis. CBI

PPP514 Mastermold, LLC 111 Grell Lane Johnson Creek WI 53038

Synthetic minor 

source Permit Limitations 15.16 

We coat a variety of plastic parts on a contract basis. Majority is 

prime coat only. Top coat used are of very low gloss, satin finish, 

higher solids material. Onan RV generator boxes

PPP515 V.J Dolan & Company Inc. 1830 N.Laramie Chicago IL 60639

PPP516 Beck Industries 74 Newport Leola PA 17540

PPP517 Fluoro-Seal, Inc. 6018 Griggs Road Houston TX 77023

PPP520 Federated Panit Mfg. Co. Inc. 1882 S. Normal Ave Chicago IL 60616

PPP522A Handi-Craft Co.

1111 Roe St./P.O. 

Box 50 Bonne Terre MO 63628

PPP522B Handi-Craft Co.

4433 Flyer Ave. St. 

Louis St. Louis MO 63116

PPP523 Amdek, Inc.

PPP524 London Industries, Inc. 350 E. High St. London OH 43140

Synthetic minor 

source Potential Emissions 5.55 

We coat a variety of plastic parts on a contract basis for the 

automotive industry. Plastic Auto Parts

PPP525 Fisher Barton, Inc. 201 Frederick St. Watertown WI 53094

PPP527 Norplas Industries Inc. 7825 Caple Blvd. Northwood OH 43619

PPP527ZZ Norplas Industries Inc. 7825 Caple Blvd. Northwood OH 43619

PPP528A Walman Optical - Baltimore 6304 Blair Hill Lane Baltimore MD 21209 Unknown 0.05 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528B Walman Optical - Bemidji 510 Beltcamp Ave Bemidji MN 56601 Unknown 0.00 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528C Walman Optical - Billings 454 Moore Ln Suite 5 Billings MT 59101 Unknown 0.07 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528D Walman Optical - Denver

495 W. Cedar 

Avenue Denver CO 80223 Unknown 0.06 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528E Ultra Coatings

6820 Shingle Creek 

Parkway Brooklyn Center MN 55430 Unknown 4.53 Plastic Parts on contract basis. Plastic windows

PPP528F Walman Optical - Duluth 426 Medical Arts Bldg Duluth MN 55802 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528G Walman Optical - Evansville

1121 Diamond Ave. 

Expwy Evansville IN 47711 Unknown 2.77 Optical lab preparing spectacle lenses some of which are coated. Plastic lenses

PPP528H Walman Optical - Fargo

1404 33rd St So. 

Suite K Fargo ND 58103 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528I Walman Optical - Fort Wayne 4629 Lima Road Fort Wayne IN 46808 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528J Walman Optical - Great Falls

410 Central Ave, 320 

Strain Bldg Great Falls MT 59401 Unknown 2.75 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528K Walman Optical - Green Bay 715 14th Avenue Green Bay WI 54304 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528L Walman Optical - Kent

20417 80th Avenue 

South Kent WA 98032 Unknown 0.05 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528M Walman Optical - Las Vegas

3321 Sunrise Avenue 

Suite 110 Las Vegas NV 89101 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

13
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP528N Walman Optical - Minot 17 2nd Ave. S.E. Minot ND 58701 Unknown 2.78 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528O Walman Optical - Missoula 1245 South 3rd West Missoula MT 59801 Unknown 0.05 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528P Walman Optical - Montgomery 1601 Forest Avenue Montgomery AL 36106 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528Q Walman Optical - Norfolk 887 norfolk Square Norfolk VA 55411 Unknown 0.08 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528R Walman Optical - Omaha 11019 I Street Omaha NE 68137 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528S Walman Optical - Rock Island 211 18th Street Rock Island IL 61201 Unknown 0.00 Optical lab processing spectacle lenses some of which are coated. Plastic lenses

PPP528T Walman Optical - Sioux Falls 1733 South Sherman Sioux Falls SD 57105 Unknown 0.04 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528U Walman Optical - Springfield 4179 W Jefferson Springfield IL 62707 Unknown 0.05 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528V Walman Optical - York 150 Rose Court York PA 17402 Unknown 0.03 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528W Acurex

6820 Shingle Creek 

Pkwy Brooklyn Center MN 55430 Unknown 2.72 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528X Walman Optical - Duluth 2775 Premier Pkwy. Duluth GA 30097 Unknown 0.01 Optical lab preparing prescription lenses some of which are coated. Plastic lenses

PPP528Y Walman Optical - Minneapolis 801 12th Ave N. Minneapolis MN 55411 Unknown 0.06 Optical lab processing spectacle lenses some of which are coated. Plastic lenses

PPP531 DGP Inc. 3260 Fenner St. Marlette MI 48453

PPP534 Galbreath, Inc. Plant #7 1301 W. Culver Rd. Knox IN 46534

Misc. Metal Parts & Products This facility manufactures Dump 

Trailers for the Waste Handling Industries. No plastic parts are 

made or coated at this facility.

PPP535 California Products Corporation 169 Waverly Street Cambridge MA 02139000

PPP537 Plas-Tech Coatings, Inc.

1000 N. Five Points 

Rd. West Chester PA 19380

PPP540 Moonlight Industries Inc. 5320 W. River Drive Comstock Part MI 49321 Unknown 6.91 

6 HVLP spray guns and paint booths spraying solvent reduced 

materials in an industrial setting. We coat a very large variety of 

plastic parts on a "job-shop" and contractual basis. Furniture Industry related parts

PPP541 Tiffany Marble Manufacturing, Inc.

271 Larkin Williams 

Industrial Ct. Fenton MO 63026

Minor or area 

source Permit Limitations

Manufacturer of sink tops, bathtubs, shower pans, shower walls, and 

miscellaneous access. Sink Tops

PPP546 Nu-Coat Industries, Inc.

PPP546 Nu-Coat Industries, Inc. 7709 West 20th Ave Hialeah FL 33014 Unknown We coat plastic parts for the office equipment industry. Telephone sets

PPP548 Continental Plastics Company

33525 Groesbeck 

Hwy Fraser MI 48026

Synthetic minor 

source Permit Limitations 5.03 

The facility uses three coating lines to coat injection molded plastic 

interior automobile parts. Plastic auto interior parts

PPP551A

Donaldson Company, Inc. - 

Bloomington

1400 West 94th 

Street Bloomington MN 55431

PPP551B

Donaldson Company, Inc. - 

Baldwin, Locust St 980 Locust Street Baldwin WI 54002

PPP551C

Donaldson Company, Inc. - 

Baldwin, Evergreen St 500 Evergreen Street Baldwin WI 54002

PPP551D

Donaldson Company, Inc. - 

Chillicothe 400 Donaldson Drive Chillicothe MO 64601

PPP551E

Donaldson Company, Inc. - 

Cresco 111 Donaldson Ct. Cresco IA 52136

PPP551F Donaldson Company, Inc. - Dixon 815 Progress Drive Dixon IL 61021

PPP551G

Donaldson Company, Inc. - 

Frankfort 3260 W. State Rd. 28 Frankfort IN 46041

PPP551H

Donaldson Company, Inc. - 

Grinnell 201 East Street South Grinnell IA 50112

PPP551I

Donaldson Company, Inc. - 

Nicholasville 200 Etter Drive Nicholasville KY 40356

PPP551J

Donaldson Company, Inc. - 

Stevens Point 5200 Coye Drive Stevens Point WI 54481

PPP551K

Donaldson Company, Inc. - 

Feasterville 1741 Lorette Ave. Feasterville PA 19053

PPP551L

Donaldson Company, Inc. - Old 

Saybrook 8 Custom Drive Old Saybrook CT 06475

PPP551M

Donaldson Company, Inc. - Port 

Huron 2630 Dove St. Port Huron MI 48060

PPP551N

Donaldson Company, Inc. - 

Rensselaer 1401 South Melville Rensselaer IN 47978

PPP551O

Donaldson Company, Inc. - 

Mooresville 297 Rolling Hills Rd. Mooresville NC 28115

PPP554 Attwood Corporation 1016 N. Monroe Lowell MI

49331026

0 Potential Emissions 0.01 

Plastic injection molding of marine hardware and office furniture 

components. Surface coating is limited to one stamp pad printer to 

apply decals to marine pumps; one part with a hot stamped decal; 

and occasional adhesives in the assembly of marine parts. Marine pumps and blowers

PPP556 Kelley Technical Coatings, Inc.

1445 & 1401 S. 15th 

St. Louisville KY 40210 We manufacture Paint & Coatings, but do not apply them.

PPP560 United Gilsonite Laboratories

1396 Jefferson 

Avenue Dunnmore PA 18509

PPP562 Pepro Enterprises, Inc. 4385 Garfield Street Ubly MI 48475

PPP565 Milton Bradley Company 443 Shaker Road

East 

Longmeadow MA 01028

PPP569 G & L Industries (ASC Calamco)

1370 East South 

Street Owosso MI 48667

Foam pieces are coated with a resin/catalyst mixture and are 

applied to a substrate material and covered with vinyl or carpet. This 

is a patented process and does not incorporate traditional coating 

methods.

PPP571 Advanced Fiber Products, Inc. 200 Cameron Ave. LaCrosse WI 54601

Minor or area 

source Consultant 2.20 Manufacture of structural fiberglass - Pultrusion process Tubes for aerial lift trucks

PPP575A

Johnson Controls, ASG - Battle 

Creek 76 Armstrong Rd. Battle Creek MI 49015 Wood fiber automotive interior systems.

14
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP575B

Johnson Controls, ASG - 

Roseville 18125 10 Mile Road Roseville MI 48066 Plastic automotive interior systems.

PPP575C

Johnson Controls, ASG - 

Delaney 615 South Delaney Owosso MI 48867 Plastic automotive interior systems.

PPP575D

Johnson Controls, ASG - Havre 

de Grace 1601 Clark Road Havre de Grace MD 21078 Plastic automotive interior systems.

PPP575E

Johnson Controls, ASG - Brut 

Plastics 1500 Crooks Clawson MI 48017 Plastic automotive interior systems.

PPP575F Johnson Controls, ASG - Ofallon 864 Hoff Road Ofallon MO 68336 Plastic automotive interior systems.

PPP575G

Johnson Controls, ASG - 

Chestnut 401 S. Chestnut Owosso MI 48867 Plastic automotive interior systems.

PPP575H

Johnson Controls, Inc., 

Automotive Systems Group - 

Sterling Heights 6600 East 15 Mile Sterling Heights MI 48312 Plastic automotive interior systems.

PPP575I

Johnson Controls, Inc., 

Automotive Systems Group - 

Nashville Plastics Products 660 Massman Drive Nashville TN Waterbase paint line - service parts.

PPP575J

Johnson Controls, Inc., 

Automotive Systems Group - 

Auburn Hills Division 3800 Lapeer Auburn Hills MI 48326 Plastic automotive interior systems.

PPP582 Newcourt, Inc. 150 Earland Dr. New Holland PA 17557

PPP583 Plastech - 

PPP584 L & W Products 3982 Terry Diane Beaverton MI 48612

PPP585 Commercial Cam Co. Inc. 1444 S. Wolf RD. Wheeling IL 60090

PPP589

United Paint and Chemical 

Corporation

24671 Telegraph 

Road Southfield MI 48034

PPP593 Columbia MFG. Inc. One Cycle St Westfield MA 01085

Any and all plastic parts are purchased. We do not coat plastic parts 

of any kind.

PPP594 Consolidated Coating Company 5 William Way Bellingham MA 02019

Minor or area 

source Permit Limitations 3.08 

Application of coatings to a wide variety of Plastic and metal Parts 

on a contract basis Computer housings

PPP595

Krueger International Inc. - 

Manitowoc 1400 S 4st Str. Manitowoc WI 54220

Synthetic minor 

source Permit Limitations - 

KI Manitowoc manufactures office partitions. The partitions 

(referred to as systems walls or panels) are made of metal cores 

with metal and/or plastic components and trim and are typically 

covered with upholstery or vinyl. They also manufacture desk 

compo Up-Ceiling Cover Holder

PPP597 C & D Aerospace Inc. 1945 S. Grove Ave. Ontario CA 91761

Synthetic minor 

source Potential Emissions 2.27 Manufacturer of aircraft interiors. Aircraft interior plastic parts

PPP598 Booth Electrosystems, Inc. 30 Bypass 25 N. Greenville SC 29611

PPP601

Rene Composite Materials 

Corporation 226 Industrial Park Pearisburg VA 24134 CBI CBI CBI

PPP602 Universal Coating Inc.

1167 West. Frances 

Road Mt. Morris MI 48458

PPP606 Martix Enterprises

PPP608 Shickel Corporation 115 Dry River Road Bridgewater VA 22812

PPP611A Red Spot Paint & Varnish Co., Inc. 1016 E. Columbia St. Evansville IN 47711

PPP611B

Red Spot Paint & Varnish Co., Inc. 

- Westland 550 S. Edwin St. Westland MI 48185

PPP612

Molded Fiber Glass Composite 

Systems Company - Ashtabula 2925 MFG Place Ashtabula OH 44004

PPP612A Molded Fiber Glass - Union City 55 Fourth Ave Union City PA 16438

PPP614A

Tnemec Company, Inc. - North 

Kansas City 123 W. 23rd Avenue

North Kansas 

City MO

64116309

4

PPP614B Tnemec Company, Inc. - 417 E. Weber Street Compton CA 90222142

PPP619A PCI 8120 Goldie Street Walled Lake MI 48390 Coating of polyester film.

PPP619B PCI

#6 Wolfer Industrial 

Park Spring Valley IL 61362 Coating of polyester film.

PPP622 Pyramid Finishes 13954 Stansbury Detroit MI 48226

PPP624 3M Columbia 5400 Route B Columbia MO 65205

Minor or area 

source Permit Limitations

The principal activity at 3M Columbia is the production of electronic 

products. In addition, optical components are produced. Plastic lenses for use in projectors

PPP625

The Gillette Company - 

Stationery Products Group - 

Arrow Park 1400 N. Parker Dr. Janesville WI 53545

PPP629 Gentex Optics, Inc. PO Box 336 Carbondale PA 18407

PPP632 Tex-Sol Plastics 4706 Broom St San Antonio TX

78217370

9

Synthetic minor 

source - Dip coating and molding of plastisol. Dip coating & formed product

PPP633

Chromium Corporation - 

Conductive Coatings Division 2602 Spence Street Lufkin TX 75904 CBI CBI CBI CBI

PPP634

Conformance Coatings & 

Prototype Inc. - 

PPP634

Conformance Coatings & 

Prototype, Inc. 2321 Busha Hwy Marysville MI 48040 Unknown Permit Limitations - 

CCP supports various molding facilities by decorating plastic 

products. We supply both automotive and non-automotive 

applications. Non-automotive

PPP636

JSJ Plastics, Inc. (formerly 

Michigan Plastics Products 

Company) 1500 S. Beechtree St Grand Haven MI 49417

Minor or area 

source Actual Emissions 2.60 

Plastic molding (misc. plastic parts including automotive, furniture, 

appliance, etc.), finishing and assembly. No final product - all for 

other manufacturers. Plastic parts

PPP637A Rexam Cosmetic Packaging, Inc. 230 Ella Grasso Ave Torrington CT 06790

Minor or area 

source Permit Limitations 0.62 

Decorative spray coating of plastic parts used for the packaging of 

cosmetic products, I.e. lipstick. Plastic parts I.e. lipstick containers

PPP637B Rexam Cosmetic Packaging, Inc. 129 Industrial Lane Torrington CT 06790

Minor or area 

source Permit Limitations 0.09 

Decorative spray coating of plastic parts used for the packaging of 

cosmetic products, I.e. lipstick. Plastic parts I.e. lipstick containers

PPP638 Flexible Technologies 528 Carwellyn Road Abbeville SC 29620

PPP639 Chicago Candle Corp. 141 West 62nd Street Chicago IL 60621

PPP642

Maracle Industrial Finishing Co., 

Inc. 39 Commercial St. Webster NY 14580 Unknown 0.75 

We job shop a wide variety of plastic parts; the majority of which are 

office equipment skins, on a quote/purchase order basis. Office Equipment Covers

15
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

PPP643

Sherwin William's Automotive 

Finishes Corp.

395 Boggs Lane 

South Richmond KY 40475

PPP644 Molded Dimentions, Inc. 701 Sunset Road Port Washington WI 53074

PPP645A Applied Coating Technology, Inc. 2411 Pilot Knob Rd. Mendota Heights MN 55120 Unknown 0.61 

Job shop painting chromate conversion, iron phosphate, powder 

painting, liquid painting, masking, silk-screening, pad printing, paint 

stripping. Temperature sensor

PPP645B Applied Coating Technology, Inc.

3225 Columbia Ave. 

NE Minneapolis MN 55418 Unknown 0.26 

Job shop painting, chromate conversion, iron phosphate, powder 

painting, liquid painting, paint stripping, electro-deposition (e-coat) Panel cutter

PPP651 Systems & Electronics Inc. (SEI) #1 McDaniel St. West Plains MO 65775

SIC 3715-Manufacurer heavy transportation Equipment-includes 

machining, welding, cleaning, painting, and assembly of large metal 

parts( ferrous and nonferrous)

PPP652A E & R Coatings, Inc. 3729 W. 49th Street Chicago IL 60632

PPP652B E & R Coatings, Inc. 2911 W. Carroll St. Chicago IL 60612 Plant destroyed by fire 9-5-97-property sold

PPP652C E & R Coatings, Inc. 2906 W. Carroll St. Chicago IL 60612 Operations ceased 3-98-property vacant and for sale.

PPP653

Johnson & Johnson - Personal 

Products

Personal Products Company manufactures sanitary napkins. The 

primary products used in manufacturing include paper pulp, 

polyester non-woven fabrics and hot-melt glues. Per a phone 

conversation with Mr. Bruce Moore, the remainder of this 

questionnaire d

PPP655 Stimsonite Corporation 7542 N. Natchez Ave. Niles IL 60714

Synthetic minor 

source Permit Limitations Manufacturer of traffic reflectors. Traffic reflectors

PPP656 Solar Compounds Corporation 1201 W. Blancke St. Linden NJ 07036

PPP659 Caorilina Extruded Plastics, Inc. 728 Utility ST. Greensboro NC 27405 Custom plastic Extruders

PPP660 Opkor Inc 740 Driving Park Ave Rochester NY 14613 Unknown - 

OpKor Inc. designs, molds, coats and assembles precision 

polymer optics. The company coats a number of polymer lenses 

and mirrors with reflective, antireflective and scratch resistant 

coatings. Video Conferencing Lens

PPP661 Paratronix Inc. 129 Bank St. Ahleboro MA 02703

per our telecon with Mr. Bruce Moore on 11-9-98 at 9:15 am, we do 

not have to complete the survey, as it does not apply to Paratronix 

Inc.

PPP662A

Brentwood Industries, 

Incorporated

610 Morgantown 

Road Reading PA 19611 Potential Emissions

Brentwood Industries, Inc. is a manufacturer of thermoformed 

plastic products. Brentwood purchases PVC, ABS, Styrene, 

Polypropylene, and PETG plastics in rolls and sheets. The plastic is 

thermoformed into a shape that is required for a specific product. T Custom products

PPP663 Dupli-Color Products Company

1601 Nicholas 

Boulevard Elk Grove Village IL 60007 CBI CBI CBI CBI

PPP664 Dollinger Corporation 101 Spruce Street Rich Creek VA 24147

PPP666 Rynone Manufacturing Corp.

PO Box 128 N. 

Thomas Ave. Sayre PA 18840

Told by Bruce Moore, US EPA that this does not apply to our 

industry per phone conversation 10-29-98. We manufacture 

bathroom sink tops only. Please take us off your list Thank you Gary 

Perry.

PPP668 Plastigage Corporation 2917 Widwoo Ave. Jackson MI 49204

Minor or area 

source Potential Emissions

Custom profile plastic extrusion inj. molding, pultrusion and retail 

plastic fabrication.

PPP669 Apex Engineering, Inc.

1234 Wellington 

Place Wichita KS 67203

PPP671A Spectrum Cubic - McConnell 13 McConnell St., SW Grand Rapids MI 49503

Synthetic minor 

source Permit Limitations 2.53 Spectrum coats a variety of automobile interior plastic parts. Auto Interior Parts

PPP673 Four Winns, Inc. 925 Frisbee Cadillac MI 49601

PPP676 Opticote, Inc. 10455 Seymour Franklin park IL 60131

PPP677 Diversified Coatings, Inc. 4580-C Mack Ave Fred MD 21703 Unknown

Job shop - Emi shielding on plastic parts for electronic 

manufacturers for use in USA and abroad Telecommunications

PPP678 Contract Manufacturer, Inc. 300 Ind. Road Madillo OK 73446 We build and paint steel trailers

PPP680 A & K Finishing, Inc. - Plant 2 4436 Donkers Court Kentwood MI 49512 11.23 Coat a variety of automobile related plastic parts.

PPP680A A & K Finishing, Inc. - Plant 1 4175 Danvers Court Kentwood MI 49512 11.17 Coat a variety of automobile related parts.

PPP681 FWD Corporation 105 East 12th St Clintonville WI 54929159

PPP682

Selmer Company, Inc. Vincent 

Bach Div.

600 Industrial 

Parkway Elkhart IN

46515031

0 We produce Brass and Silver musical Instruments

PPP683A Spalding Sports World Wide

PPP683B Spalding Sports World Wide

PPP684 Perfect Plastics Industries, Inc. Bldg 201, 14th St. New Kensington PA 15068 Unknown - 

Molding, finishing, and painting with water borne primer of auto 

bumpers for the aftermarket Plastic Bumpers

PPP687 G. S. Industries of Bassett, Inc. 85 Rosemont Road Bassett VA 24055

Synthetic minor 

source Permit Limitations 4.55 We coat plastic mirror frames Plastic mirror frames

PPP691 Goldberg Brothers, Inc. 8000 East 40th Ave Denver CO 80207

Manufacturer of sheet metal and machined parts. We also do 

welding and powder coating on metal.

PPP692 Seaward international, Inc.

RPC104 USCP - Houston One North Sampson Houston TX 77003

RPC105 Caine Corporation 85 High Street Hebron OH 43025 Not a major source or synthetic minor

RPC108 Advanced Fibermolding, Inc. 20000 19 Mile Road Big Rapids MI 49307

RPC109 Rubber & Plastic Applicators, Inc. 86 Telegraph RD. Mobile AL 36610 Permit Limitations Manufacture Reinforced Plastic Composites Plastic Pipe

RPC110A

Miles Fiberglass & Composites, 

Inc. 1516 Main St. Oregon City OR 97045 We do not do any adhesive coatings to our plastic parts.

RPC110B

Miles Fiberglass & Composites, 

Inc. 8855 SE Otty Rd. Portland OR 97266 We do not do any adhesive coatings to our plastic parts.

RPC111 Downs Manufacturing 715 N Main St Lawton MI 49065 Unknown - We gelcoat Reinforced plastic parts. Go-Karts

RPC113 Comtech Antenna Systems, Inc.

3100 

Communications Rd St. Cloud FL 34769

RPC114 Clean Tech 2017 Horizon Ct Zion IL 60099

RPC116

Hydrodynamics, Inc. Dba 

Associated Fiberglass Engineers 2417 Weaver St Fort Worth TX 76117

RPC117 Mor Tech Fab., Inc. 4945 Hwy 85 South Williston ND 58801

RPC118 Bohn Fiberglass Ind.,Inc. 7100 Distribution Dr. Louisville KY 40258

RPC120 Southern Fiberglass, Inc. 41 Spring St. Jacksonville FL 32254 Mfg. Molded parts. Not a major source or synthetic minor source

16
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

RPC121 Fabwel Composites

16710 Maple City 

Drive Goshen IN 46526

RPC126 Viking Custom Paint

RPC128 Kreider MFG., Inc. 405 Gerber St. Ligonier IN 46767

RPC131 Plaschem Supply & Consulting 1415 Spar Avenue Anchorage AK 99501

RPC132A Beetle Plastics, Inc. - OK

Ardmore Industrial 

Airpark Ardmore OK 73401

RPC132B Beetle Plastics, Inc. - Florida

965 Bunker Avenue 

Building 19 Reynolds 

Industrial

Green Cove 

Springs FL 32043

RPC132C Beetle Plastics, Inc. - Texas 4519 Saunders Road Houston TX 77093

RPC133 Fibreright Automotive MFG., Inc. 50 Boxwood Lane Cheektowaga NY 14227

RPC134 Tri Glass Plastics 10447 Product Drive Rockford IL 61115144

RPC135 Belco Manufacturing Co., Inc.

2303 Taylors Valley 

Rd Belton TX 76513

RPC136

Miller Control and Manufacturing 

Co., Inc. 1008 Southwest Blvd. Clinton NC 28328

RPC139 Fivestar Fabrication 36620 89th Street Twin Lakes WI 53181

RPC140 Competition Specialties, Inc.

16936 County Road 

252 McAlpin FL 32062

RPC141 S. R. Smith, Inc.

RPC142 Fibra-Form Products, Inc. 16431-45th St. NE Rogers MN 55374

RPC144 Pilling's FRP Inc RR1 Box 75 New Columbia PA 17856

RPC145 Dagger Canoe Co. P.O. Box 1500 Harrimah TN 37748 Not a major source or a Synthetic Minor

RPC147A Glastic Corporation - Cleveland 4321 Glenridge Cleveland OH 44121

RPC147B Glastic Corporation - Jefferson 400 E. Jefferson Jefferson OH 44047

RPC148

Shenandoah Fiberglass Pro. Co., 

Inc. 211 E. 4th Street Front Royal VA 22630

RPC149 Hipoint Trailers USA 3747 Colorado Ave Sheffield OH 44054

RPC150 Haysite Reinforced Plastics 5599 New Perry Hwy Erie PA 16509

RPC151 Centek Industries, Inc.

116 Plantation Oak 

Dr. Thomasville GA 31792 Not a major source or synthetic minor

RPC152 Tankinetics, Inc. 230 Industrial Pk Rd Harrison AR 72601

Manufacturing of filament wound/hand lay-up fiberglass tanks and 

boxes. (Gel-coats are used post filament wound and in-mold for 

boxes.)

RPC153 Bittner Industries, Inc. CBI

RPC155 Deflecta-Sheild Corporation 314 East Jefferson IA 50060152

RPC156

Cardinal Fiberglass Industried - 

Perth Amboy 1050 State Street Perth Amboy NJ 08862 We are not a major source or synthetic minor.

RPC159 Yankee Plastic Company 200 South Bellingham Riverdale IA 52722

RPC160 Fibrex Corporation P.O.Box 428 Burlington WA 98233

RPC161 Custom Composites, Inc P.O. Box 689 Baraga MI 49908068 Hand laminated fiberglass parts.

RPC162 San Juan Pools of Oklahoma, Inc. 1518 E. 5th Ct. Tulsa OK

74120400

6 Unknown

Fiberglass swimming pool manufacture w/hand lay up procedures 

gel coat first layer. Redim with fiberglass mat & woven and sprayed 

to the gelcoat layer. Swimming Pool

RPC163B Resolite Polyglas

1575 Lebanon School 

Road West Miffin PA 15122

Manufacture pultruded thermoset plastic composites. Pultruded 

shapes are angles, channels, and rectangular tubing used in 

electrical applications. Also, manufacture small and large molded 

fan blades using a press.

RPC166 Rohrback Tooling & Fabrication Cottage 4 Hill Ave. Glen Rock PA 17327

We went out of business as of 5/1/98 was never a major source or 

synthetic minor.

RPC170A

TPI Composites, Inc. - Warren 

Facility 373 Market Street Warren RI 02885

RPC170B

TPI Composites, Inc. - 

Portsmouth Facility 225 Alexander Rd Portsmouth RI 02871 14.28 

RPC173 Duro Fiber Company, Inc. 11 Park Avenue Hudson NH 03051

RPC174A

McClarin Plastics, Inc - Plastics 

Division 211 Blettner Ave. Hanover PA 17331

RPC174B

McClarin Plastics, Inc - Plastics 

Division 320 Maple Ave Hanover PA 17331

RPC174C

McClarin Plastics, Inc - Plastics 

Division 816 Mcallister St. Hanover PA 17331

RPC176 Lyons Industries 30000 M-62 West Dowagiac MI 49047 Company produces acrylic sinks, tubs and shower enclosures.

RPC178 Wiley Sanders Truck Lines Hwy 29 Troy AL 36079

RPC180 Fibertech Incorporated 4155 Courtney Franksville WI 53126

Synthetic minor 

source Potential Emissions 0.79 

Manufactures custom molded OEM plastic resin products (I.e. 

Garden tractor housings, etc.).

RPC181 DACO Composite Mfg Inc

P.O. Box 487 - 1116 

Foundations Dr. Pilot Point TX 76258

RPC182 Sampson Fiberglass, Inc. 135 N.Kaley St. South Bend IN 46619

RPC184 Acme-Wiley Corp. 147 Litton Dr. Lexington SC 29073

RPC187 J.I. Plastics Co. Inc. 19233 Plunk Rd. Zachary LA 70791 Not a major source or synthetic minor

RPC188 Formcrete Fiberglass Products 1900 Ray Davis Blvd Seminole OK 74868 Manufacture fiberglass concrete forming equipment.

RPC189 Fibernetics, Inc. 2 Cutters Dock Road Woodbridge NJ 07095

RPC190A Viatec, Inc. - Hastings 1220 W. State St Hastings MI 49058

RPC190B Viatec, Inc. - Belding 500 Reed St Belding MI 48809

RPC191 Globe Metallurgical Sales, Inc.

RPC193 Western Power Products 900 Portway Ave. Hoodriver OR 97031

RPC195B

Core Materials Corporation - 

Gaffney 24 Commerce Drive Gaffney SC 29340

This facility was started 1/5/98. It does not currently perform any 

coating operations. This facility is expected to get new business in 

1999 which may require coating operations.

RPC197 Fiberglass Supply, Inc. 152 Toledo St Farmingdale NY 11735

RPC200 Rainsong Graphite Guitars

300 Ohukai Rd, C214 Kihei HI 96753 We manufacture all-graphite guitars. No plastics used here.

RPC201 Eckler's

5130 S. Washington 

Ave. Titusville FL 32780

17
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

RPC202B

HPP Acquisition Co. - DBA: 

Hamilton Plastics/Hamilton 

Bathware

2291 Military Street 

South Hamilton AL 35570

RPC204

Kathabar Inc. - Elizabethtown 

Plant 1301 S. Poplar St. Elizabethtown NC

28337246

1 Not a major source or synthetic minor

RPC206 Xenon Company, Inc. 9996 Lickinghole RD. Ashland VA 23005 Mfg. FRP Corrosion Control Equipment. Not a Major Source

RPC210 Fiberglas & Plastic Fab., Inc.

2832 North Webster 

Avenue Indianapolis IN 46219

Manufacturer of custom molded fiberglass products. Main line is 

industrial housings. We minimal assembly and do not post product 

coatings.

RPC211 Topcon Omni Systems, Inc.

2430 Blvd. OF The 

Generals Norristown PA 19403

RPC212 Sabre Yachts 12 Hawthorne Road Raymond ME 04071 Unknown 0.08 

Manufacture sail and power yachts. Lam-up and construction of 

reinforced fiberglass hulls and decks, which are then assembled.

RPC212A Sabre Yachts Route 302 Casco ME 04077 Unknown 0.12 Manufacturer of power yachts. Sabreline 47

RPC213 Fibertech Corporation 250 South Depot St. Pendleton SC 29670

RPC214A Valmont Industries, Inc.

Highway 275-P.O. 

Box 358 Valley NE

68064035

8

RPC214B Valmont Tulsa

801 N. Xanthus, Box 

2620 Tulsa OK 74110

RPC214C Valmont Indiana

58027 Charlotte 

Avenue Elkhart IN 46516

RPC214D Intermountain Galvanizing 1085 West 400 North Lindon UT 84042

RPC214E Oklahoma Galvanizing

5100 SW Alliance 

Drive Claremore OK 74017

RPC214F Pacific States Galvanizing

9700 SW Herman 

RD. Tulatin OR 97062

RPC214G Calwest Galvanizing

2226 East 

Dominguez Street Long Beach CA 90810

RPC214H Valmont West Point 1700 South Beemer West Point NE 68788

RPC214I Valmont International, Inc. 2105 S. Mannix Drive San Antonio TX 78217

RPC214J American Lighting Systems, Inc.

2551 Valmont Drive, 

Box E Brenham TX 77833

RPC214K Microflect, Inc.

3575 25th St., Box 

12985 Salem OR

97309098

5

RPC216 Redmont, Incorporated P.O. Box 413 Belmont MS 38827

RPC217 Hot Box 250 Cane Ave N Jacksonville FL 32254 Unknown

Manufacture insulated covers for water valves and pumps from both 

aluminum and fiberglass Fiberglass Enclosures

RPC220

Great Plains Fiberglass 

Fabricators, Inc. 93 Ford Lane Hazelwood MO 63042 Not a major source or synthetic minor

RPC221 GHM, Inc.

RR # 1, Box #1286A, 

Ind. Dr. Orwigsburg PA

17961972

7

Minor or area 

source Potential Emissions 0.36 

Manufacturer of fiberglass reinforced plastic tanks for fire fighting 

apparatus. Hand and spray lay-up molding and assembly of tanks. Water storage tanks for fire apparatus

RPC222 Grayson Tool Company 900 West Fifth Street Minden NE 68959

Fiberglas reinforced products, open mold chop spray up with 

gelcoat surface. No coating of our production parts.

RPC223 Composites USA, Inc. One Peninsula Drive North East MD 21901 Fiberglass fabricator - Not a major source or synthetic minor

RPC227 Harwood Industries, Inc.

17833 State Hwy. 31 

E. Tyler TX 75705 Unknown

Gel coating of hand laid, open molded FRP automobile panels and 

parts. Automobile Panels

RPC228 Raven Industries, Inc. 1810 "E" Ave. Sioux Falls SD 57104

RPC228A Glasstite West

1335 West Battaglia 

Road Eloy AZ 85231

Synthetic minor 

source Permit Limitations 2.36 Manufacture fiberglass pickup truck toppers. Fiberglass toppers

RPC229 Pyramid Operating Systems 639 Keystone Rd. Greenville PA 16125 Unknown Not Reported Fiberglas Reinforced Plastic

RPC230 Midwest Towers, Inc. Hwy 19 East Chickasha OK 73018

RPC231 Avia Sport Composits 731 Main Ave. SW Hickory NC 28602

RPC232 Superior Fiberglass, Inc. 205 Beaumont St. Jacksonville TX 75766

RPC234 Wescott's Auto Restyling 19701 SE Hwy 212 Boring OR 97009 Not a major source or a synthetic minor

RPC237 Dyer Fiberglass, Inc. 59 Currie Rd. Dyer TN 38330

RPC238 Neutraman, Inc.

2701 S. Coliseum 

Blvd. Suite 1000-A Ft. Wayne IN 46803

RPC239 Windsor Fiberglass, Inc. 801 Enterprise Dr. Burgaw NC 28425

RPC240A Industrial Pipe & Plastics - LaPort 11807 North D Street LaPorte TX 77571

RPC240B

Industrial Pipe & Plastics - 

Pasadena 3415 Lilac Pasadena TX 77504

RPC240C

Industrial Pipe & Plastics - 

Kansas City 300 W Riddleville Rd Kansas City TX 78118

RPC241 The Fiberglass Shop

2352 Main St, BLDG 

2G Concord MA 01742

RPC242A Warminster Fiberglass Company 725 County Line Rd. Southampton PA 18966

Laminating fiberglass reinforced plastic parts on molds using 

polyester gel-coat, polyester resin and fiberglass reinforcement. 

Hand lay-up, SMC Compression molding.

RPC242B Warminster Fiberglass Company 1428 Elberta St. Jacksonville TX 75766

Laminating fiberglass reinforced plastic parts on molds using 

polyester gel-coat, polyester resin and fiberglass reinforcement. 

Hand lay-up, SMC Compression molding.

RPC243 Steele Plastics, Inc. 1280 Sturgis Rd Conway AR 72032

RPC246 Composite Structures Inc. 2828 N. 23rd St. East Omaha NE

68110272

6 Unknown Potential Emissions

Fiberglas reinforced plastic parts are manufactured in the facility. 

Process includes mold making, gel coating, laminating, grinding, 

sanding and assembly. Truck body parts

RPC247

Marshall Industries Composites, 

Inc.

2250 Central Point 

Parkway Lima OH 45804

RPC249 Electri-Glass, Inc. 63 Compass Drive Jackson TN 38301

RPC250 Crain Enterprises Inc 100 Ohio Ave Mound City IL 62963

RPC253 Primary Plastics, Inc. 315 Scarborough Dr. Endwell NY 13760

RPC255 The Phil Carter System, Inc. 1014 Jefferson Ave. Newport News VA 23607

PCS, Inc. is a fiberglass fabrication facility using open spray up 

processes to manufacture portable sanitation equipment (i.e. 

portable toilets)

18
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

RPC257 Janicki Machine Design

24595 State Route 

20;617/621 Sunset 

Park Drive Sedro-Wolley WA 98284 Not a major source or synthetic minor

RPC260A

Mac Lean-Fogg Company 

Corporate Engineering

690 S. Chaddick 

Drive Wheeling IL

60090473

8 Small Research and Development Engineering facility

RPC260B

Polymer Technologies, A 

MacLean-Fogg Company 420 N. Universal Blvd Whitewater WI 53190

Not a major source or synthetic minor source of emissions of any of 

the substances on the hazardous air pollutants list. No paints, 

adhesives or coatings are used in this injection molding operation.

RPC260C

MacLean Molded Products, a 

MacLean-Fogg Company 410 Mercantile Court Wheeling IL 60090

Not a major source or synthetic minor source of emissions of any of 

the substances on the hazardous air pollutants list. No paints, 

adhesives or coatings are used in this injection molding operation.

RPC260D

Precision Fiberglass, a MacLeanFogg Company 101 Park Avenue Newberry SC 29108

Not a major source or synthetic minor source of emissions of any of 

the substances on the hazardous air pollutants list. This is a 

fiberglass rod manufacturing operation, where there is no respirable 

mineral fibers, and the amounts of constituents in the

RPC260E

Continental Electric Company, a 

MacLean-Fogg Company

6655 Highway 11 

North Trussville AL 35173

Not a major source or synthetic minor source of emissions of any of 

the substances on the hazardous air pollutants list. This facility 

paints the fiberglass rods that our other company, Precision 

Fiberglass, makes: however, no paint constituents in the ag

RPC260F

Metform Corp., a MacLean-Fogg 

Company 2551 Wacker Road Savanna IL 61074

Not a major source or synthetic minor source of emissions of any of 

the substances on the hazardous air pollutants list. This facility 

makes no plastic or molded parts, however we report it for the 

Teflon coating of metal parts, which uses small amounts o

RPC261 Corrosion Controlers, Inc. 2930 Ford Street Washougal WA 98671

RPC264 J. Jones Enterprises 61 Skagit Key Bellevue WA 98006

RPC265 GL & V - LaValley Industries 7600 NE 47th Avenue Vancouver WA 98661

RPC266 G & G Fiberglass Eldonado TX 76936

RPC270 Elmore Truck Accessories, Inc.

107 E. Willis, PO Box 

382 Elmore MN 56027

Fiberglas manufacture products coated include: aerial lift buckets, 

tanks and towers. Towers

RPC271 Hy-Tec Fiberglass Inc. 2204 Suppliers Ct Ft. Wayne IN

46818117

2

Minor or area 

source Permit Limitations 0.28 

We supply the lift truck industry with boom, buckets & small parts 

manufactured with fiberglass reinforced plastic. We hand lay up all 

parts. Buckets and small parts use gelcoat in mold coating. Booms 

are sanded & automotive painted. Fiberglass booms

RPC272 C & K Fiberglass Plastic's, Inc.

200 Wabash St., P.O. 

Box 246 Millersburg IN 46543

RPC273 Appalachian Plastics,Inc. 34001 Glove Dr Glade Spring VA 24340

RPC274 CAD Cut Three Mile Bridge Rd. Montpelier VT 05602

RPC275 Hauk Manufacturing Company

100 North Harris 

Street Cleona PA 17042

RPC277 Mekco Manufacturing, Inc. 11110 Hwy 42 Newton WI 53063

RPC278 Architectural Molded Composites 101 Northern Road Schofield WI 54476 MFG of Architectural Composites Styrid

RPC280 GPI Corporation 101 Northern Road Schofield WI 54476

RPC282 Bedling Tank Technologies, Inc. 200 N. Gooding St. Belding MI 48809

RPC287 CDR Systems Corporation 2 Kay Larkin Circle Palatka FL 32177

RPC291A

Teel Plastics - Lynn Avenue 

Facility 702 Lynn Avenue Baraboo WI 53913

RPC291B

Teel Plastics - Hitchcock Street 

Facility 426 Hitchcock Street Baraboo WI 53913

Minor or area 

source Potential Emissions 1.64 

Plastic tubing produced through extrusion process is coated. 

Currently no tubing is being coated, data is for 1997. Plastic tubing

RPC293

American Matrix Technologies, 

Inc. - (Production & 

Development Canter) 500 57th Street Marion IA 52302 Not a major source or synthetic minor

RPC294 Melcher Mfg. Co., Inc 6017 E. Mission Spokane WA 99212

RPC298 Polymer Components, Inc.

2005 N. Park Central 

Ave. Nicholasville KY 40356

RPC299 Ecological Tanks, Inc. 2247 HWY 151 No. Downsville LA 71234

RPC305

Advanced Generator 

Technologies 18 Lark St. Amsterdam NY 12010

RPC306 Fibercast Company 25 South Main Sand Springs OK 74063

RPC307

Smith Fiberglass Products 

Company, a division of A.O.Smith 

Corporation

2700 West 65th 

Street Little Rock AR 72209

RPC312 Salo Manufacturing, Inc. 26-12th Street S.E. Menahga MN 56464

Minor or area 

source Permit Limitations Manufacture fiberglass tubs and showers. Bath tubs

RPC315 Formed Fiberglass Co., Inc. 809 State Rt. 288 Fombell PA 16123

RPC317 Sikes Composites Corporation

320 Barrett Industrial 

Blvd. Wetumpka AL 36092

RPC318 Glasgo Plastics, Inc.

3240 East National 

Rd. Springfield OH 45505

Synthetic minor 

source Permit Limitations

Bonding of steel inserts to FRP parts and primed other FRP parts 

all on site. Tulip panel

RPC319

Inland Manufacturing - SPA 

Factory 800 Ironwood Olathe KS 66061

We do no coating of plastic parts. Thank you Mr. Moore for helping 

us complete this form.

RPC320 Concept Fiberglass, Inc.

P.O. Box 518 1515 

East 4th Street Grand Island NE 68802

RPC322 Alchem Inc. 3617 Strawberry Rd Anchorage AK 88502 Not a major source or synthetic minor.

RPC323 Gorman-Rupp Company 305 Bowman St. Mansfield OH 44901121

RPC328 Aqua Bath, Co. Inc. 921 Cherokee Ave. Nashville TN 37207

Manufacture a variety of fiberglass reinforced handicap acrylic 

shower and tub/showers

RPC330 Fab-Glas Industries, Inc. 300 Industrial Drive Angole IN 46703

RPC331 Mckenzie Sports Products, Inc.

1910 St. Lukes 

Church Road Salisbury NC 28146

Synthetic minor 

source Permit Limitations 0.20 

We coat fiberglass molds, then pour an expanding foam into mold 

and paint adheres to the product. Target

RPC333 Lunn Industries 1 Garvies Point Road Glen Cove NY 11542 Unknown

Coat parts U.S. Navy, antenna masts, radomes, aerospace panels, 

etc. Surface cleaning

RPC334 Mandish Research International 5055 State R046 Mims FL 32754

19
FACID Facility_name Street City State Zip

Reported Title V 

Status Title_V_basis

Estimated Total HAP (TPY) 

(from "Facility Data Analysis, 

5-3-05.xls") Facility_Description Product

RPC335 Bathcraft Incorporated

1610 James P 

Rodgers Dr Valdosta GA 31601

RPC336

Sequentia, Inc. subsidiary of 

Kemlite, Div of Crane Co. 450 N. Hwy 368 Grand Junction TN 38039

RPC339 FRP Incorporated 1941 US Hwy 62 Winchester OH 45697952

RPC341 National Cycle 2200 Maywood Dr Maywood IL

60153178

3 We form and assemble motorcycle windscreens and accessories.

RPC342

Diamond Fiberglass Fabricators, 

Inc. P.O. Box 106 Victoria TX 77902

RPC346 Plastickos, Incorporated 220 Prospect Park Peachtree City GA 30269

RPC347 Diamond Coach Corporation

2300 West Fourth 

Street Oswego KS 67356

RPC348 GatorGrate 95-1 Levy Rd Atlantic Beach FL 32233 2.40 

RPC348B Seasafe, Inc. 209 Galser Dr. Lafayette LA 70508

Synthetic minor 

source Potential Emissions 1.81 

Structural Fiberglass facility. Produce fiberglass composites 

through pultrusions process. Manufacture fiberglass grating, cable 

tray, handrail, ladders and perform custom fabrication. Do bonding, 

painting, sealing, coating and cleaning. Structural Fiberglass

RPC350

Chautauqua Fiberglass and 

Plastics, Inc. 80 Canal St. Sharpsville PA

16150025

5

Minor or area 

source Consultant 0.28 

We are a custom fabricator of corrosion resistant thermoset plastic 

parts. We apply gel coat to approximately 1% of our parts. We hand 

brush a top coat on approximately 25% of our parts.

RPC351 Kustom City Fiberglass, Inc.

5817 2nd Avenue 

North Great Falls MT 59405

FRP Repairs & custom Production. Not a major source or synthetic 

minor.

RPC354 Kar-Del Plastics, Inc. 1177 Faultless Drive Ashland OH 44805 Unknown

Manufacturing of Fiberglass Reinforced Thermoset Plastics. Hand 

lay-up open molded products. Examples: Scrubber towers, tanks, 

pipe, fittings, ducting, hoods, stacks, housing and other 

miscellaneous parts. Pollution control equipment

RPC357 Custom Fiberglass MFG. 1018 E. Madison Oklahoma City OK 73111

RPC358 Wel- Tech Composites 254 Balwin Rd Satsuma AL 36572 Manufacture FRP flanges. FRP Flange

RPC360 Great Lakes Plastics Corporation

P.O. Box 600 

Houghton County 

Airpark Hancock MI 49930

RPC361 ACCRA Industries, Inc. 586 Progressive Lane South Beliot IL

61080192

0

Synthetic minor 

source Permit Limitations We coat a variety of reinforced plastic parts manufactured on site. FRP Small Floats

RPC362 Earl's Fiberglass, Inc.

128 W. Maricopa 

Fwy. Phoenix AZ 85003

RPC365 C&C Fiberglass, Inc. 3659 Destiny Drive Bremen IN 46506

C&C Fiberglass conducts fiberglass fabrication regulated under the 

reinforced plastic composite NESHAP. Manufactured 

products/composites are not otherwise coated or painted.

RPC366 Fib-Con Corporation 4605 Madison St. Riverdale MD 20737 Not a major source or synthetic minor

RPC367 Westfall Manufacturing Company 381 Metacom Ave. Bristol RI 02809 Unknown 40' x 100' cinder block bldg. Venturi flow meters, static mixers, de filter

RPC370 GEA Dynamic Fabricators W. 13725 Hwy53 Rathdrum ID 83858

RPC372A Aker Plastics Company Inc. 1400 Pidco Plymonth IN 46563048 Bath Tub Manufacturer

RPC372B Aker Plastics Company Inc. 1001 North Oak Road Plymonth IN

46563048

4 Bath Tub Manufacturer

RPC372C Aker Plastics Company Inc.

2011 Mid-Atlantic 

Pkwy Romney WV 25401 Bath Tub Manufacturer

RPC373 Koral Industries, Inc. 1504 South Kaufman Ennis TX 75119 Spray up of fiberglass bathing units.

RPC374 Composite Hobbies, Inc. 217 SW Pumice #C Redmond OR 97756

RPC375 Swimcraft Inc. 462 W 200 N Angola IN 467703

RPC377 Fiberglass Specialties, Inc. 500 Austin Ave Henderson TX 75652

RPC379 Industrial Fiberglass Specialties

RPC380 Frontier Plastic Fabricators, Inc. 4518 W. 56th St. Tulsa OK 74107

Synthetic minor 

source Permit Limitations 0.14 

We are a contract molded custom fiberglass pipe and fittings 

manufacturer. At times some fabrication jobs require adhesive joint 

assembly. Fiberglas pipe

RPC385 New Boston Fiberglass, Inc.

19155 Shook Rd. - 

P.O. Box 188 New Boston MI 48164 Not a major source or synthetic minor.

RPC386 Glasspec Associates LTD 18735 SW 104 Ave Miami FL 33157 Manufacturer of molded fiberglass products

RPC387 Plastic Development Company RD #2 Box 249A-1 Williamsport PA 17701

RPC389 Fiberglas Engineering & Design

7421 Crawfordsville 

Rd. Indianapolis IN 46214 Not a major source or synthetic minor

RPC391

Falls Fiberglass Products, Inc. 

(marked ALL CBI) CBI CBI CBI CBI

RPC396 Palmer Manufacturing & Tank, Inc.

2814 West Jones 

Ave. Garden City KS 67846 Unknown

We mfg. steel and fiberglass tanks. Coating of FRP tanks is with 

pigments + gel coats. Steel tanks coated with paint. Fiberglas tanks

RPC400 Hood Manufacturing Inc. 2621 S. Birch St. Santa Ana CA 92707

RPC401I Jacuzzi Whirlpool Bath - Irvine 1922 Barranca Pkwy Irvine CA 92606

RPC401S

Jacuzzi Whirlpool Bath - Santa 

Ana 3000 W. Secerstrom Santa Ana CA 92704

RPC403

Molded Fiber Glass Companies - 

West 9400 Holly Road Adelanto CA 92301

RPC404 Peterson Products

1325 Old County 

Road Belmont CA 94002

Minor or area 

source Potential Emissions 0.22 

We secondarily paint a variety of reinforced plastic parts 

manufactured on site.

Covers for various medical 

diagnostic/treatment ma

RPC405 Prototype Concepts Inc

10865 Kawama River 

Ave. Fountain Valley CA 92708 Not a major source or synthetic minor

20
7.0 

Development of Model Shops for Sources Subject to the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for Motor Vehicles and Mobile Equipment 

Refinishing Operations for Area Sources 
0223-00-008\Auto Refinishing Model shops 1

MEMORANDUM 

TO: Kim Teal, U.S. EPA, Sector Policies and Programs Division/Natural 

Resources and Commerce Group (E143-03) 

FROM: Brian Palmer, Eastern Research Group, Inc. (ERG) 

Date: July 17, 2006 

Subject: Development of Model Shops for Sources Subject to the National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Motor Vehicles and 

Mobile Equipment Refinishing Operations for Area Sources 

 Model shops were developed for the sources affected by the motor vehicle and mobile 

equipment refinishing area source NESHAP. The model shops were used to estimate cost and 

environmental impacts. Model shops were based on information collected during site visits and 

from other information collected during the development of this NESHAP. 

Development of Model Shops

Table 1 lists the latest available data that estimates the total number of automotive 

refinishing establishments according to the 2003 County Business Patterns. 

Table 1. Number of U.S. Automotive Refinishing Establishments by Employment-size 

Class for the Paint or Body Repair Shops (NAICS 811121) 

Number of Employees 

1-4 5-9 10-19 20-49 50-99 100-

249 

250-

499 

500-

999 

>

1000 

Total 

Establishments 

Number of 

establishments 

20,174 8,177 5,490 1,778 110 22 3 0 1 35,755

Source: 2003 County Business Patterns (NAICS 811121) (USCB 2003). 

We suspect that the establishments with large numbers of employees (e.g., 100 or more 

employees) are actually companies with multiple locations that reported as a single 
0223-00-008\Auto Refinishing Model shops 2

establishment. We did not observe or hear of any single shop locations with 100 or more 

employees during the development of this NESHAP. 

Size classes in the County Business Patterns data were combined to create model shops 

that corresponded to the typical shops observed during site visits. These were small shops with 1 

to 9 employees; medium shops with 10 to 19 employees; and large shops with 20 or more 

employees. These shops sizes corresponded to the number of employees we observed at shops 

with one, two, or three paint booths. 

We estimated the total number of employees in each size range by taking the numerical 

midpoint of the employee range in the County Business Patterns data and multiplying it by the 

number of shops in that range. For example there are 20,174 shops with 1 to 4 employees; the 

midpoint of that range is (1 + 4)/2 = 2.5 employees per shop: 

20,174 shops X 2.5 employees per shop = 50,435 employees. 

The estimated number of employees for shops with 1 to 4 employees was added to the 

estimated number for shops with 5 to 9 employees to obtain the total number of employees for 

shops with 1 to 9 employees. Similar estimates were performed for the medium and large model 

shops. 

Table 2 summarizes the information collected during site visits that was used to develop 

the values for model shop parameters, including number of employees, number of painters, 

number of spray booths, and number of cars refinished per month. 

Table 2. Information Collected During EPA Site Visits 

Name and Location Shop Type 

Vehicles 

per Month

No. of 

Painters 

No. of 

Employees

Gun 

Cleaner?

No. of 

Booths Booth type 

Advanced Restoration and 

Autobody 

Sacramento, CA 

Restoration 1 1 Yes 2 

(one is used 

only for 

sanding) 

downdraft 

The Finish Line Restoration 

Services, Inc. 

Monrovia, CA 

custom restoration 1 1 1 crossdraft 

Durham School District 

Transportation Department 

Garage 

Durham, NC 

fleet vehicles 

(buses) 

3 2 Yes 1 crossdraft 
0223-00-008\Auto Refinishing Model shops 3

Table 2. Information Collected During EPA Site Visits 

Name and Location Shop Type 

Vehicles 

per Month

No. of 

Painters 

No. of 

Employees

Gun 

Cleaner?

No. of 

Booths Booth type 

NC DOT Maintenance 

Garage 

Raleigh, NC 

Highway 

Department 

maintenance 

garage 

5 1 Yes 2 crossdraft, 

semidowndraft 

Gemini Autobody 

Cedar Falls, IA 

collision repair 8 1 1 Yes 1 crossdraft 

Fulton Autobody 

Sacramento, CA 

collision and 

custom restoration

15 1 4 Yes 1 crossdraft 

McJack’s Corvette 

Santa Ana, CA 

Corvette 

restortions and 

repair 

20 1 Yes 1 downdraft 

Dale Bright Auto Service 

Chino, CA 

collision repair 30 1 no 1 crossdraft 

Rush Truck Center, Inc. 

Pico Rivera, CA 

heavy duty trucks 40 Yes 1 downdraft 

Walt Stickel Body and 

Frame Shop, Inc. 

Sacramento, CA 

collision repair 

and refinishing 

45 2 7 Yes 2 downdraft 

Cherry Auto Body 

Chino, CA 

collision repair 60 2 Yes 2 downdraft, 

semidowndraft 

1-Day Paint & Body Centers

La Habra, CA 

production 65 Yes 1 crossdraft 

Coffman's Body Shop 

Cedar Falls, IA 

collision repair 72 4 7 Yes 1 crossdraft 

Niello Collision Service 

Sacramento, CA 

collision repair 90 3 15 Yes 1 downdraft 

California Auto Body 

Sacramento, CA 

collision repair 100 4 Yes 2 crossdraft 

Maaco 

Sacramento, CA 

production 120 2 Yes 1 semidowndraft 

Zimmerman Ford 

Cedar Rapids, IA 

collision repair 150 4 15 Yes 2 downdraft 

Bertolucci’s Body and 

Fender Shop, Inc. 

Sacramento, CA 

collision repair 

and resoration 

200 5 Yes 3 downdraft 

Wondries Family Collision 

Center 

Alhambra, CA 

collision repair 200 Yes 4 downdraft 

Falconi's Collision Center 

Las Vegas, NV 

collision repair 280 5 Yes 4 1 jambing 

booth, 3 

downdraft 

spray booths

Deery Brothers Collision 

Center 

Cedar Falls, IA 

collision repair 300 4 20 Yes 3 downdraft (2 

fullsize 

booths and 

one jambing 

booth) 
0223-00-008\Auto Refinishing Model shops 4

Table 2. Information Collected During EPA Site Visits 

Name and Location Shop Type 

Vehicles 

per Month

No. of 

Painters 

No. of 

Employees

Gun 

Cleaner?

No. of 

Booths Booth type 

Seidner’s Collision Center 

Duarte, CA 

collision repair 310 9 40 Yes 3 downdraft 

Based on this information, we developed the three model shops that are summarized in 

Table 3. The average number of employees per shop was estimated by dividing the total number 

of employees in each model shop size range from the County Business Patterns data by the 

number of shops in each model. We assumed that one third of employees are painters, based on 

information from shops visited. 

In June 2003, Body Shop Business magazine reported that the median amount spent per 

month on coatings was $1,350. We can assume that the median shop is best represented by the 

small model shop, since almost 80 percent of shops are small shops according to the County 

Business Patterns data, and the median is the middle value with 50 percent above and 50 percent 

below. . The annual coating cost for the small, medium, and large model shops was calculated 

using the relative number of cars per month as follows: 

Small shops: ($1350/month)(12 months) = $16,200 

Medium shops: (($1350/month)(12 months)(100 cars/40 cars) = $40,500 

Large shops: ($1350/month)(12 months)(200 cars/40 cars) = $81,000 

Table 3. Summary of Model Shop Parameters 

Parameter Small Medium Large 

Number of employees 1-9 10-19 20 or more 

Number of Shops (from County Business 

Patterns) 

28,351 5,490 1,194 

Total Number of Employees (estimated 

from County Business Patterns) 

107,674 79,605 74,349 

Average number of employees per shop 3.8 14.5 39.4 

Average Number of painters 1.3 4.8 13.1 

Number of Spray Booths 1 2 3 

Number of Cars/Vehicles Refinished Per 

Month 

40 100 200 

Annual Coating Cost $16,200 $40,500 $81,000 
8.0 

Estimate of Baseline Emissions and Emission Reductions for Sources Subject to the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Motor Vehicles 

and Mobile Equipment Refinishing Operations for Area Sources 
0223-00-008\Autobody Baseline Emissions & Reductions 1

MEMORANDUM 

TO: Kim Teal, U.S. EPA, Sector Policies and Programs Division/Natural 

Resources and Commerce Group (E143-03) 

FROM: Brian Palmer, Eastern Research Group, Inc. (ERG) 

Date: July 21, 2006 

Subject: Estimate of Baseline Emissions and Emission Reductions for Sources Subject to 

the National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Motor Vehicles and Mobile Equipment Refinishing Operations for Area Sources 

Introduction and Summary of Results

The purpose of this memo is to document the results and methodology used to estimate 

baseline emissions and emission reductions for sources potentially subject to the proposed area 

source NESHAP for motor vehicle and mobile equipment refinishing operations. Emissions and 

emission reductions were estimated for organic HAP, volatile organic compounds (VOC), 

inorganic HAP, and particulate matter (PM). Table 1 summarizes the baseline emission 

estimates and emission reductions. 

Table 1. Summary of Baseline Emissions and Emission Reduction Estimates 

Organic HAP VOC Inorganic HAP PM 

Baseline Emissions (ton/yr) 36,906 107,680 11.7 2,909 

% Reduction 18.6% 18.6% 92% 92% 

Emission Reductions (ton/yr) 6,846 19,975 10.8 2,679 

Controlled Emissions (ton/yr) 30,060 87,706 0.9 231 

The remainder of this memo describes the sources of data and methods used to produce these 

estimates. 

Data Sources

Refinish coating data were provided by three refinishing coating suppliers: DuPont, 

PPG, and Sherwin-Williams. The other major refinishing coating suppliers, for which EPA did 

not have data, were Akzo Nobel, BASF, and Valspar. DuPont and PPG provided national sales 
0223-00-008\Autobody Baseline Emissions & Reductions 2

and HAP content data for 2003 that were equal in format to data provided to the California Air 

Resources Board (CARB) in 2001. Sherwin-Williams provided a copy of the same data that 

were reported to CARB in 2001, but did not provide equivalent national data for 2003. The 

method we used to estimate national data for 2003 for Sherwin-Williams is detailed in Appendix 

A to this memo. 

The data provided to CARB and EPA included the coating name and identifying product 

code, gallons sold, density, weight and volume percent solids, weight and volume percent 

volatiles, weight and volume percent exempt (non-VOC) volatiles, weight and volume percent 

water, and name, chemical abstract service (CAS) number, and weight percent of each ingredient 

listed on the material safety data sheet (MSDS) for each product. 

Each of the three companies also provided estimated 2003 sales and HAP content data for 

coatings that contained any one of the following HAP that were identified by EPA as a priority 

HAP for this area source category:

1

benzene cadmium compounds, 

chromium compounds diethylene glycol monobutyl ether 

hexamethylene-1,6-diisocyanate monomer hydrochloric acid 

lead compounds manganese compounds 

methyl ethyl ketone (MEK) methyl isobutyl ketone (MIBK) 

naphthalene nickel compounds 

toluene xylene 

These data were used to estimate baseline emissions and emission reductions of the 

inorganic HAP (cadmium compounds, chromium compounds, lead compounds, manganese 

compounds, and nickel compounds.) 

All of the data reported from these three companies were declared to be confidential 

business information (CBI) by the providers. The data and related analyses are being handled as 

such by EPA and ERG. To protect the confidentiality of these data, only aggregate values from 

the three data providers are being reported in this memo. 

Extrapolating From Reported Data To The Whole Industry

The total volume of coatings from DuPont, PPG, and Sherwin-Williams was estimated to 

be 25.7 million gallons in 2003. The total estimated sales for 2003, based on U.S. Census data, 
0223-00-008\Autobody Baseline Emissions & Reductions 3

were 49.5 million gallons.

2

 Therefore, these three suppliers were estimated to represent about 52 

percent of total sales and this fraction was used to develop estimates for the whole industry from 

the provided data. That is, we divided the estimated total values for baseline emissions from 

these three suppliers by 0.52 to estimate the total baseline emissions for the whole industry. 

We also assumed that all of the motor vehicle and mobile equipment refinish coatings 

sold by these suppliers are used at motor vehicle and mobile equipment refinishing operations. 

However, EPA has been informed in meetings with industry that these coatings are also used on 

non-automotive applications, including aircraft, boats, and other miscellaneous items where a 

high quality and durable finish is desired. However, no reliable estimate of the fraction used in 

non-automotive applications is available and the only available estimates are anecdotal. 

Therefore, we did not correct these values for the amount used in non-automotive applications. 

These automotive refinish coatings are also used at some major source motor vehicle and 

mobile equipment surface coating operations that will not be subject to the area source rule, such 

as recreational vehicle (RV) manufacturers. The EPA does not have data to estimate the volume 

of automotive refinish coating used at all major source motor vehicle or mobile equipment 

surface coating sources. However, we believe that use of refinish coatings by major sources will 

have a minimal effect on the baseline emission and reduction estimates. For example, RV 

manufacturers, perhaps the largest group of major sources that use refinish coatings, used about 

290,000 gallons of coatings in 2000, or about 0.6 percent of refinish coating usage. This was 

estimated using data provided to EPA by the Recreational Vehicle Industry Association (RVIA) 

to support the development of the assembled on-road vehicle surface coating emission limit in 

the major source rule for plastic parts and products surface coating operations (40 CFR 63, 

subpart PPPP). Therefore, we did not correct these values for the amount used by major sources. 

Similarly, we did not try to account for hobbyists who use refinish coatings and assumed 

that refinish coatings would be used only by professional shops that are subject to the area source 

rule. Automotive hobbyists that perform their own surface coating would not be covered. The 

EPA has no reliable data to indicate how much coating is used by hobbyists, or whether 

hobbyists would be adopting any of the control measures specified by the rule for professional 

 

1 Wyatt, S. Memorandum to S. Shaver, P. Lassiter, and ESD Group Leaders. Pollutant Information from Toxicity 

Weighting Analysis ESD Project Leads Should Be Aware of As They Develop Area Source Standards. September 

25, 2003. 

2U.S. Census Bureau data cited in "Coatings Industry Report for 2003." Edward W. Bourguignon. Paint and 

Coatings Industry Magazine. February 2005. 
0223-00-008\Autobody Baseline Emissions & Reductions 4

refinishers, such as the use of a filtered spray booth. Therefore, we cannot adjust the baseline 

emission and reduction estimates to account for coating use by hobbyists, but we expect that the 

effect of hobbyists to be minimal.3

Organic HAP and VOC Baseline Emissions

The baseline emissions of organic HAP and VOC were estimated as being equal to the 

consumption of organic HAP and VOC, less the amount of organic HAP and VOC that is in the 

coatings that become waste and are not used. Refinishers try to estimate the amount of coating 

needed for each job and mix only the amount needed to minimize waste, with a small amount of 

excess to ensure they can finish the job. The refinishers at shops visited and contacted by EPA 

estimated that the amount of coating that becomes waste ranged from 5 to 15 percent, with 10 

percent being the most common response. Paint that is left over at the end of job can sometimes 

be saved for future work, but more often it is put in a sealed waste drum. 

For the baseline and emission reduction estimates, we estimated that 10 percent of paint 

becomes waste. We assumed that all of the organic HAP and VOC in the 90 percent of coatings 

that do not become waste are emitted as the coatings are applied and cure. 

The organic HAP and VOC in the coatings were estimated from the coating data 

provided by the three coating suppliers. Organic HAP ingredients were identified by CAS 

number and did not include chemicals that had been removed from the Clean Air Act list of HAP 

as of May 1, 2006. Total organic HAP for each coating was determined from the total weight 

percent of organic HAP (lb organic HAP/lb coating), coating density (lb/gallon), and coating 

sales (gallons). 

The data provided by the coating suppliers reported the weight percent volatiles, weight 

percent exempt (non-VOC) volatiles, and weight percent water for each material. The fraction of 

VOC in each coating was calculated as the volatile fraction minus the exempt volatiles and 

minus the water: 

wt % VOC = (wt % volatiles) – (wt% exempts) – (wt % water) 

 

3

For example, the Antique Automobile Club of America (www.aaca.org) reports that they had 50,000 members in 

1985. If we assume, as an example, that there are 100,000 hobbyists in the U.S. involved in restoring or 

customizing automobiles, and each used 3 gallons per year to refinish one automobile per hobbyist, that volume 

(300,000 gallons) would still be only 0.6 percent of total gallons sold. Most hobbyists do not refinish a car every 

year, and some use professionals to refinish their cars, or borrow or rent the use of a professional spray booth. 
0223-00-008\Autobody Baseline Emissions & Reductions 5

Total VOC and HAP (both organic and inorganic) for each coating was determined from 

the total weight percent of VOC or HAP (lb VOC or HAP/lb coating), coating density 

(lb/gallon), and coating sales (gallons): 

lb HAP or VOC = (wt% VOC or HAP)/100*(lb/gallon)*(gallons sold) 

Organic HAP and VOC Emissions Reductions

The area source rule would require all shop personnel that spray coatings to complete 

operator training and to use high transfer-efficiency spray equipment. Visits by EPA to over 20 

automotive refinishing operations and meetings with industry indicate that high volume, low 

pressure (HVLP) and other types of high transfer-efficiency spray equipment have been almost 

universally adopted in the refinishing industry. Nearly all shops have already switched to highefficiency equipment because of the potential coating cost savings compared to conventional 

spray equipment. Therefore, no additional emission reductions were estimated from an increased 

use of high efficiency spray equipment. 

However, we estimate that additional organic HAP and VOC emission reductions will 

occur as a result of increased operator training that will lead to decreased coating consumption. 

The Iowa Waste Reduction Center (IWRC) has developed the Spray Technique Analysis and 

Research (STAR) program for spray painters. As part of that training, students complete a 

transfer efficiency test before and after training. The average reduction in gallons of coating 

used for 382 students trained in the STAR program was 18.55 percent, as reported on the IWRC 

web site.

4

We assumed that the 18.55 percent reduction in the amount of coatings used would 

translate directly into an 18.55 percent reduction in organic HAP and VOC emissions as a result 

of increased operator training for spray gun operators: 

Emission reduction = (Baseline emissions)*(18.55%/100) 

 

4 www.iwrc.org/staruserqueries/avg_of_all_trainees.cfm
0223-00-008\Autobody Baseline Emissions & Reductions 6

Inorganic HAP and PM Baseline Emissions and Emission Reductions

The inorganic HAP and solids (which could become emitted as PM) in the coatings were 

estimated from the coating data provided by the three coating suppliers. Inorganic HAP 

ingredients were identified from the data by ingredient name and included compounds of 

cadmium, chromium, lead, manganese, or nickel. Compounds of chromium and lead were most 

common and accounted for 95 percent of the inorganic HAP, by weight, from the three 

companies providing data. 

The baseline emissions and emission reductions of inorganic HAP and PM are affected 

by several variables and their estimates are more complicated than for organic HAP and VOC. 

Solids and inorganic HAP are removed from the potential air stream as coating is applied 

to a part, overspray settles on other surfaces, and overspray passes through a filter before being 

exhausted to the outside of the spray booth, if coatings are applied in a filtered booth. The 

emission process is represented graphically below. The top row of boxes represent the mass of 

inorganic HAP and coatings solids that could be emitted as particulate matter in coating 

overspray and the second row of boxes represent the points at which inorganic HAP and PM are 

removed from the potential emission stream. The mass of inorganic HAP and PM that could be 

emitted decreases as the “coating” moves through the flow diagram from left to right. 

Assumptions Used in Estimating Baseline Emissions and Emission Reductions for PM and 

Inorganic HAP

For the baseline emission estimates of PM and inorganic HAP, we made the following 

assumptions: 

• We assumed that 10 percent of coating becomes waste. 

Potential PM and 

Inorganic HAP that 

could be emitted 

Waste paint Coating reaching 

the part 

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Overspray on 

other surfaces 

Overspray on 

filters

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Final

Emissions 
0223-00-008\Autobody Baseline Emissions & Reductions 7

• We assumed that all painters are already using HVLP spray guns. These were the 

only types of spray guns observed in use during our visits to over 20 automotive 

refinishing operations. 

• The average transfer efficiency of painters was 48 percent, based on the pre-training 

transfer efficiency of painters completing the IWRC STAR program. Transfer 

efficiency is defined as the percent of coating solids that reaches the part and becomes 

the final finish. 

• 50 percent of the sprayed coating that does not reach the part and becomes overspray 

lands on other surfaces, such as masking paper around the area being painted, or 

spray booth walls and floors. 

• 7 percent of all coating is applied at shops that do not have a booth. Body Shop 

Business magazine’s 2003 reader survey reported that 86 percent of shops had either 

a downdraft or cross draft booth. We assumed this meant that 14 percent of shops 

had no booth and we assumed that all shops without a booth were “small” shops (1 to 

9 employees). We estimated that these shops accounted for 7 percent of painters and, 

therefore, 7 percent of paint usage, based on our model shops and County Business 

Pattern data for 2005 from the U.S. Census. 

• 90 percent of coatings are applied in a booth or filtered prep station and 10 percent 

are applied in the open shop environment. During EPA visits, we observed that some 

small jobs (usually a primer application, painting door jambs, or small finish jobs) are 

occasionally done outside a booth. 

• The baseline efficiency of filters in spray booths is 96 percent. This was the median 

efficiency of the filters for which we collected data from filter vendors. 

For the final emission estimates for PM and inorganic HAP, we made the following assumptions: 

• We assumed that 10 percent of coating would still become waste. 

• We assumed that all painters would increase transfer efficiency from a starting 

average of 48 percent to a final average of 59 percent after training, as measured in 

the IWRC STAR program. 

• 100 percent of shops would have a filtered spray booth. 

• 100 percent of coatings would be applied in a filtered booth or filtered prep station. 

 

• Spray booth and prep station filters would have an efficiency of 98 percent. This is 

the efficiency achieved by fiberglass and polyester fiber filters and is the standard 

specified in the proposed rule for filters that were not fiberglass or polyester fiber 

filters. 

 
0223-00-008\Autobody Baseline Emissions & Reductions 8

Methodology for Estimating Baseline Emissions of PM and Inorganic HAP

The following equation was used to estimate the PM (as coating solids, tons/yr) or 

inorganic HAP (tons/yr) that were in the coatings that reached the part, before operator training 

is conducted: 

A = B * C 

Where: 

A = PM, as coating solids, or inorganic HAP reaching the part (tons/yr); 

B = Pre-training transfer efficiency, fraction; 

C = PM, as coatings solids, or inorganic HAP that is in the coating that does not become 

waste, tons/yr. 

The following equation was used to estimate the PM (as coating solids) or inorganic HAP 

that become airborne overspray (tons/yr): 

D = (1 – E) * (C – A) 

Where: 

D = PM, as coating solids, or inorganic HAP that become airborne overspray (tons/yr); 

E = Fraction of overspray that settles on other surfaces; 

C = Inorganic HAP and coatings solids that is in coating that does not become waste, tons/yr; 

A = Inorganic HAP or PM reaching part, tons/yr). 

The following equation was used to estimate baseline emissions of PM or inorganic HAP 

from shops without a booth (tons/yr): 

F = D * G 

Where: 

F = Baseline emissions of PM or inorganic HAP from shops without a booth (tons/yr); 

D = PM, as coating solids, or inorganic HAP that become airborne overspray (tons/yr); 

G = Fraction of coatings applied by shops without a filtered booth. 

The following equation was used to estimate baseline emissions of PM or inorganic HAP 

from shops with a booth (tons/yr): 

H = (1-G)*((D*(1-J))+(D*J*(1-K))) 
0223-00-008\Autobody Baseline Emissions & Reductions 9

Where: 

H = Baseline emissions of PM or inorganic HAP from shops with a booth (tons/yr); 

G = Fraction of coatings applied by shops without a filtered booth; 

D = PM, as coating solids, or inorganic HAP that become airborne overspray (tons/yr); 

J = Baseline fraction of coatings applied in a booth at shops with booths; 

K = Baseline paint overspray filter/arrestor efficiency; i.e., fraction of paint reaching the filter 

that is captured in the filter. 

The following equation was used to estimate the total baseline emissions of PM or 

inorganic HAP (tons/yr): 

L = F + H 

Where: 

L = Total baseline emissions of PM or inorganic HAP (tons/yr); 

F = Baseline emissions of PM or inorganic HAP from shops without a booth (tons/yr); 

H= Baseline emissions of PM or inorganic HAP from shops with a booth (tons/yr). 

Methodology for Estimating Final Emissions of PM and Inorganic HAP

The following equation was used to estimate the PM (as coating solids, tons/yr) or 

inorganic HAP (tons/yr) that were in the coatings that reached the part, after painter training is 

conducted: 

A = BB * C 

Where: 

AA = PM, as coating solids, or inorganic HAP reaching part (tons/yr), after painter training; 

BB = Post-training transfer efficiency, fraction; 

C = PM, as coatings solids, or inorganic HAP that is in the coating that does not become 

waste, tons/yr. 

The following equation was used to estimate the PM (as coating solids) or inorganic HAP 

that become airborne overspray, after painter training is conducted: 

DD = (1 – E) * (C – AA) 

Where: 

DD = PM, as coating solids, or inorganic HAP that become airborne overspray (tons/yr), after 

painter training; 
0223-00-008\Autobody Baseline Emissions & Reductions 10

E = Fraction of overspray that settles on other surfaces; 

C = Inorganic HAP and coatings solids that is in coating that does not become waste, tons/yr; 

AA = PM, as coating solids, or inorganic HAP or PM reaching part (tons/yr), after painter 

training. 

The following equation was used to estimate final emissions of PM and inorganic HAP 

(tons/yr) from all shops. All shops are assumed to have a filtered booth, all coatings are applied 

in the booth and the booth has filters with 98 percent efficiency. 

HH = (DD*(1-JJ))+(DD*JJ*(1-KK)) 

Where: 

HH= Final emissions of PM or inorganic HAP from all shops (tons/yr). 

DD = PM, as coating solids, or inorganic HAP that become airborne overspray (tons/yr), after 

painter training. 

JJ = Final fraction of coatings applied in a booth at all shops (1.0, or 100 percent). 

KK = Final paint overspray filter/arrestor efficiency, fraction of paint reaching the filter that is 

captured in the filter. 
0223-00-008\Autobody Baseline Emissions & Reductions 11

Appendix A: 

Documentation of how total national sales, solids, HAP and VOC were 

estimated from data provided by Sherwin-Williams Automotive Finishes Corporation 

Background: 

Sherwin-Williams provided two sets of data to U.S. EPA for their automotive refinish coatings. 

These data were used to estimate national baseline levels for total gallons of coating used, 

pounds (lb) of coating used, lb of solids used, lb of HAP used, and lb of VOC used. These 

baseline estimates of consumption were used to estimate baseline emissions and potential 

emission reductions. 

One set of data was for all coatings sold in California in 2001. These data were assembled and 

provided to the California Air Resources Board (CARB) for the development of a new suggested 

control measure to reduce VOC emissions from automotive refinish coatings. These data 

included volume (gallons) sold, density, weight percent solids, weight percent HAP (by 

individual ingredient), and weight and volume percent volatiles, exempt (non-VOC) volatiles, 

and water. These data are included in the Microsoft Access database entitled SW forms 3 to 

5 update (CBI).dba. 

The second set of data were for all coatings sold in the United States in 2003 that contained the 

following HAP identified by EPA as priority HAP for regulation of this area source category:

5

 

benzene cadmium compounds, 

chromium compounds diethylene glycol monobutyl ether 

hexamethylene-1,6-diisocyanate monomer hydrochloric acid 

lead compounds manganese compounds 

methyl ethyl ketone (MEK) methyl isobutyl ketone (MIBK) 

naphthalene nickel compounds 

toluene 

Xylene was also included in the list of HAP considered a priority by EPA, but was not provided 

by Sherwin Williams, for an unknown reason. MEK was removed by EPA from the list of HAP 

after these data were provided. 

This set of data was in a Microsoft Excel spreadsheet entitled Sherwin Williams CBI-EPAPriority HAP Data.xls. The data included the product name and code, gallons sold in 2003, 

density, and weight percent content of each of the priority HAP listed above, and total lb of each 

priority HAP. 

Sherwin-Williams did not report complete data for the U.S. that was comparable to the CARB 

data. The coatings that contained the priority HAP did not represent all coatings sold by Sherwin 

Williams, and these data did not include solids, non-priority HAP, and VOC information. 

 

5 Wyatt, S., U.S. EPA, Memorandum to S. Shaver, P. Lassiter, and ESD Group Leaders,, U.S. EPA. Pollutant 

Information from Toxicity Weighting Analysis ESD Project Leads Should Be Aware of As They Develop Area 

Source Standards. September 25, 2003. 
0223-00-008\Autobody Baseline Emissions & Reductions 12

Therefore, ERG needed to estimate total U.S. sales, pound (lb) solids, lb HAP, and lb VOC by 

extrapolating from the two available data sets. We assumed that the California data represented 

nearly all the products that are sold in the U.S. We recognize that there may be some products 

that are not sold in California because they do not comply with California VOC regulations, but 

these are probably off-set by products that are sold in California and not elsewhere in the United 

States. For purposes of this analysis (estimating baseline emissions and emission reductions), we 

believe that this assumption introduces a minimal and acceptable amount of error. 

The final estimates of U.S sales, lb HAP, lb solids, and lb VOC are contained in the Excell 

spreadsheet entitled SW calcs for 5-1-06 (CBI).xls on the bottom of the page entitled “US 

baselines.” The other pages in that spreadsheet provide the data that were used to estimate those 

values. The procedure used is described in the following paragraphs. 

Methodology: 

Step 1. We estimated the percentage of U.S. coatings that were represented by the coatings that 

contained the priority HAP using the CARB data. We assumed that the same percentage of 

coatings in the CARB data would contain the same priority HAP as the U.S. coatings. We 

calculated that 72.75 percent of coatings sold in California, by volume, contained the same 

priority HAP. We assumed that the U.S. data for coatings that contain priority HAP also 

represent 72.75 percent of total U.S. sales. Therefore, we calculated that total U.S. sales 

(gallons) equals the amount containing priority HAP divided by 0.7275. 

Step 2. Similar to step 1, we estimated the percentage of U.S. coatings that were represented by 

the coatings that contained the priority HAP using the CARB data, but this time on a weight 

basis. This weight-basis percentage was used when we scaled up for lb of solids, HAP, and 

VOC, instead of gallons. We calculated that 72.23 percent of coatings sold in California, by 

weight, contained the same priority HAP. 

Step 3. The CARB data provided solids, HAP, and VOC content6data for almost all of the U.S. 

coatings that contained priority HAP, but not all of them. Some of the coatings sold nationally 

are not sold in California because they would not comply with California VOC limits. Also, the 

two data sets are 2 years apart (2001 and 2003) and products may have been added or 

discontinued in that time. We linked the two data sets by the product code and calculated that 

the CARB data provided solids, HAP, and VOC data for 92.12 percent of the U.S. coatings (by 

weight) that contained priority HAP. 

Step 4. We used the CARB data to calculate the total lb solids, HAP, and VOC for those U.S. 

coatings that contained priority HAP. Since these coatings represent only 72.23 percent of all 

 

6

The CARB data did not specifically include actual weight or volume percent VOC content. We calculated VOC 

as total volatiles minus exempt compounds and minus water. We also found that in some cases, water content was 

reported in the CARB data as both an exempt solvent and as water. This resulted in a negative VOC content if the 

water content was more than half the volatile content. If the water and exempt solvent percentages were the same, 

we assumed that water was the only exempt solvent and the exempt solvent value was changed to “zero” on the 

spreadsheet and the water value was left as reported. We did not make this change in the Access database with the 

CARB data. Our decision was supported by a review of several MSDS for the affected materials, copies of which 

have been saved for the project file. 
0223-00-008\Autobody Baseline Emissions & Reductions 13

coatings, and only 92.12 percent of these coatings (by weight) were in the CARB database, we 

had to correct these totals (solids, HAP, VOC) to obtain total U.S. estimates. Therefore, these 

values were divided by (0.7223 x 0.9212 = 0.6654) to obtain the total U.S. estimates for solids, 

HAP, and VOC. 

Alternative Approach: 

For comparison, we also tried simply scaling up the CARB data to national values using the 

relative populations of California and the U.S. from census data. From the 2000 Census, 

California represents 12.2 percent of the U.S. population. We then calculated the total gallons of 

coating, lb solids, HAP, and VOC from the CARB data and divided these by 0.122 to obtain 

national estimates. 

We compared these results to the results we obtained from steps 1 to 4, above. The alternative 

approach based solely on population estimated 6 percent fewer gallons sold, 7 percent more lb 

solids, 27 percent lower lb HAP, and 20 percent lower lb VOC. Scaling from the CARB data 

based on population also resulted in a 30 percent lower emission rate for HAP per lb of solids, 

and a 25 percent lower emission rate for VOC per lb of solids. These results are consistent with 

the fact that coatings sold in California are subject to more stringent VOC regulations than 

coatings sold nationally and that this has resulted in higher solids contents, and lower VOC and 

HAP emission rates. These results also support our decision to use the approach described in 

steps 1 to 4 above, since the results are probably more representative of the coatings sold 

nationally. 
 Gallons 

Coating Coating (ton/yr) 

 Organic HAP 

(ton/yr) VOC (ton/yr) 

Solids 

(ton/yr) 

Total 

Inorganic 

HAP (ton)

Pb in PbCompounds 

(ton/yr)

Cr-6 in CrCompound

s (ton/yr)

Totals for companies A, B, C 25,688,500 100,983 21,281 62,091 32,524 131 78 24

Industry totals (1) 49,500,000 194,587 41,007 119,645 62,671 252 150 46

Other values for industry totals are scaled from the totals for companies A, B, and C based on ratio of 49,500,00/25,688,500 = 1.93

Percent of coating that becomes waste and goes into a "sealed" drum 10%

Non-waste consumption that is potentially emitted (ton/yr) 36,906 107,680 56,404 227 135 42

IWRC measured reduction in gallons of coating sprayed per job as a result of training 18.55%

 Organic HAP VOC

Baseline Organic HAP and VOC emissions (tons/yr) 36,906 107,680

Organic HAP and VOC emissions after training (tons/yr) 30,060 87,706

Organic HAP and VOC reductions after training (tons/yr) 6,846 19,975

Organic HAP and VOC reductions after training (%) 18.55% 18.55%

Pre-training transfer efficiency from IWRC 48.04% 48.04% 48.04% 48.04%

Post-training transfer efficiency from IWRC 59.12% 59.12% 59.12% 59.12%

Pre-training solids and inorganic HAP reaching part (tons/yr) 27,096 109 65 20

Post-training solids and inorganic HAP reaching part (tons/yr) 33,346 134 80 25

Percent of overspray that settles on other surfaces 50%

Pre-training solids and inorganic HAP that become airborne overspray (tons/yr) 14,654 59 35 11

Post-training solids and inorganic HAP that become airborne overspray (tons/yr) 11,529 46 28 9

Percent of coatings applied at a shop without a booth 7% based on the fraction of painters that work at shops without booths

Baseline Emissions from shops without a booth (tons/yr) 1,061 4 3 1

Baseline percent of coatings applied in a booth at shops with booths 90%

Baseline paint arrestor efficiency 96%

Baseline emissions from shops with a booth (tons/yr) 1,849 7 4 1

Total Baseline emissions from all shops 2,909 11.7 7.0 2.1

Rule percent of coatings applied in a booth 100%

Rule paint arrestor efficiency 98%

Post-training air emissions with rule booth usage and paint arrestor efficiency 231 0.9262 0.6 0.2

PM, Inorganic HAP, Pb, and Cr-6 Emission reductions (tons/yr) 2,679 10.8 6 2

PM, Inorganic HAP, Pb, and Cr-6 Emission reductions (%) 92% 92% 92% 92%

PM

Total 

Inorganic 

HAP Pb Cr-6

(1) Industry total for Gallons Coating is from U.S. Census Bureau data cited in

"Coatings Industry Report for 2003." Edward W. Bourguignon. Paint and Coatings Industry Magazine. February 2005.

assumes that small priming jobs, some jambing, and some small finish 

jobs are done outside a booth 
9.0 

Estimate of Baseline Emissions and Emission Reductions for Sources Subject to the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous 

Surface Coating Area Sources 
MSCAS Baseline Emissions & Reductions 1

MEMORANDUM 

To: Kim Teal, U.S. EPA, Sector Policies and Programs Division/Natural 

Resources and Commerce Group (E143-03) 

From: Brandin McDonough and Brian Palmer, Eastern Research Group, Inc. (ERG) 

Date: July 27, 2006 

Subject: Estimate of Baseline Emissions and Emission Reductions for Sources Subject to 

the National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Miscellaneous Surface Coating Area Sources 

 

Introduction and Summary of Results

The purpose of this memo is to document the results and methodology used to estimate 

baseline emissions and emission reductions for sources potentially subject to the miscellaneous 

surface coating area source NESHAP. Emissions and emission reductions were estimated for 

organic HAP, volatile organic compounds (VOC), inorganic HAP, and particulate matter (PM). 

Table 1 summarizes the baseline emission estimates and emission reductions. 

Table 1. Summary of Baseline Emissions and Emission Reduction Estimates 

Organic HAP VOC Inorganic HAP PM 

Baseline Emissions (ton/yr) 853 12,747 0.72 235 

% Reduction 7.5% 7.5% 88% 88% 

Emission Reductions (ton/yr) 64 956 0.63 207 

Controlled Emissions (ton/yr) 789 11,791 0.09 28 

The remainder of this memo describes the sources of data and methods used to produce 

these estimates. 

Data Sources

The data used in this analysis were located in databases created in the development of the 

National Emission Standards for the Surface Coating of Plastic Parts and Products (40 CFR 63, 

subpart PPPP), and the National Emission Standards for Miscellaneous Metal Parts and Products 

Surface Coating Operations (40 CFR 63, subpart MMMM). These two databases were created 
0223-00-008\MSCAS Baseline Emissions & Reductions 2

by obtaining survey responses from more than 1300 coating facilities. Of these facilities, 518 

were estimated to be major sources of HAP and 831 facilities were estimated to be area sources 

based on their reported Title V major source status and HAP consumption.1 We have coating 

data for 236 facilities that we estimated are area sources. The data provided in the survey 

responses from the 236 facilities were used to generate the baseline emissions and emission 

reduction estimates above. 

The baseline emissions and emission reductions were not scaled from 236 facilities to 

831 facilities (e.g., multiplied by a factor of 831/236 = 3.5) because we cannot confirm the actual 

area/major source status of those we estimate to be area sources that did not provide coating data. 

Organic HAP and VOC Baseline Emissions

The baseline emissions of organic HAP and VOC were estimated as being equal to the 

consumption of organic HAP and VOC, less the amount of organic HAP and VOC that is in the 

coatings that become waste and are not used. We estimated that baseline consumption was 947.4 

tons per year (ton/yr) of organic HAP and 14,163 tons/yr of VOC. 

We assumed that 10 percent of coating becomes waste. The fraction of VOC in each 

coating was calculated as the volatile fraction minus the exempt volatiles and minus the water: 

wt % VOC = (wt % volatiles) – (wt% exempts) – (wt % water) 

Total VOC and HAP (both organic and inorganic) for each coating was determined from 

the total weight percent of VOC or HAP (lb VOC or HAP/lb coating), coating density 

(lb/gallon), and consumption (gallons): 

Lb HAP or VOC = (wt% VOC or HAP)/100*(lb/gallon)*(gallons consumed, less waste) 

We estimated baseline emissions of 853 tons of organic HAP and 12,747 tons of VOC 

emitted per year. 

 

1 Memorandum. From B. Palmer, ERG, Inc., to K.Teal, U.S. EPA/NRCG. Estimating the Number of Miscellaneous 

Surface Coating Area Sources for Which EPA Has Data. July 19, 2006. 
0223-00-008\MSCAS Baseline Emissions & Reductions 3

Organic HAP and VOC Emissions Reductions

The area source rule would require all spray coating to be performed using high volume, 

low pressure (HVLP), or equivalent, spray guns. The reduction of emissions achieved by this 

measure is directly related to the reduction in gallons of coatings used as a result from switching 

from conventional spray guns to HVLP. The fraction of coating that reaches the product, instead 

of becoming overspray, is termed transfer efficiency. We assume that conventional spray guns 

achieve 30 percent transfer efficiency and that HVLP spray guns achieve 48 percent transfer 

efficiency.

2

 Switching to an HVLP spray gun would reduce the amount of coating used for each 

job. We estimate that the amount of coating sprayed after switching from conventional spray 

guns to HVLP is reduced by 37.5 percent: 

[(1 / 0.30) – (1 / 0.48)] / (1 / 0.30) = 0.375 

The estimated number of facilities using conventional spray guns is 20 percent. 

Number of facilities using conventional spray guns = (total number of facilities)*(0.2) 

Emission reduction = (Baseline emissions)*(0.375) 

We estimate that facilities switching from conventional spray guns would reduce organic 

HAP emissions by 64 tons per year and VOC emissions by 956 tons per year: 

Inorganic HAP and PM Baseline Emissions and Emission Reductions

The baseline emissions and emission reductions of inorganic HAP and PM are affected 

by several variables and their estimates are more complicated than for organic HAP and VOC. 

Solids and inorganic HAP are removed from the potential air stream as coating is applied 

to a product, overspray settles on other surfaces, and overspray passes through a filter before 

being exhausted to the outside of the spray booth. 

 

2

[Insert references for transfer efficiency for conventional and HVLP spray guns. DfE and IWRC documents.]
0223-00-008\MSCAS Baseline Emissions & Reductions 4

The emission process is represented graphically below. The top row of boxes represent the 

potential inorganic HAP and PM that could be emitted and the second row of boxes represent the 

points at which inorganic HAP and PM are removed from the emission stream. 

We assumed that 10 percent of coating becomes waste since it is not applied after mixing. 

We assumed that 50 percent of the coating that does not reach the product and becomes 

overspray lands on other surfaces, such as masking paper around the area being painted and 

spray booth walls and floors. Some of the remaining fraction that enters the spray booth exhaust 

would be removed depending on whether the booth has filters and their filter efficiency. 

The inorganic HAP and solids in the coatings were estimated from the coating survey 

data. We estimated that baseline consumption was 18.5 ton/yr of inorganic HAP and 6,054 

tons/yr of coating solids. Inorganic HAP ingredients were identified from the data by ingredient 

name and included compounds of cadmium, chromium, lead, manganese, or nickel. Compounds 

of chromium and lead were most common and accounted for 87 percent of the inorganic HAP, 

by weight, from the facilities providing data. 

Emissions of PM and inorganic HAP are affected by paint spray gun transfer efficiency, 

the capture of coating overspray in a spray booth or similar enclosure, and the capture of paint 

overspray in the booth exhaust on a filter or other type of paint overspray arrestor. 

The rule would require that all spray applied coatings would need to be applied with 

HVLP (or similar) spray guns in a filtered spray booth, and the filters would need to meet a 

minimum filter efficiency. 

Assumptions Used in Estimating Baseline Emissions and Emission Reductions for PM and 

Inorganic HAP

For the baseline emission estimates of PM and inorganic HAP, we made the following 

assumptions: 

Potential PM and 

Inorganic HAP that 

could be emitted 

Waste paint Coating reaching 

the product 

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Overspray on 

other surfaces 

Overspray on 

filters

Potential PM and 

Inorganic HAP 

that could be 

emitted 

Final

Emissions 
0223-00-008\MSCAS Baseline Emissions & Reductions 5

• 10 percent of coating becomes waste. 

• 88 percent of coatings are applied in a spray booth; 75 percent of sources in the data have 

a dry filter spray booth and 13 percent use wet filters. 

• 12 percent of coatings is applied outside a booth. 

• 80 percent of coatings are applied with conventional spray guns and 20 percent with 

HVLP spray guns. 

• The average transfer efficiency of conventional spray guns was assumed to be 30 percent 

and for HVLP spray guns was 48 percent. 

 

• 50 percent of the sprayed coating that does not reach the part and becomes overspray 

lands on other surfaces, such as masking paper around the area being painted, or spray 

booth walls and floors. 

• The baseline efficiency of filters in spray booths is 96 percent. This was the median 

efficiency of the filters for which we collected data from filter vendors. 

For the final emission estimates for PM and inorganic HAP, we made the following assumptions: 

• We assumed that 10 percent of coating would still become waste. 

• We assumed that all coatings would be applied with HVLP spray guns with transfer 

efficiency equal to 48 percent. 

 

• 100 percent of shops would have a filtered spray booth. 

• Spray booth filters would have an efficiency of 98 percent. This is the efficiency 

achieved by fiberglass and polyester fiber filters and is the standard specified in the 

proposed rule for filters that were not fiberglass or polyester fiber filters. 

 

Methodology for Estimating Baseline Emissions of PM and Inorganic HAP

The following equation was used to estimate the PM (as coating solids, tons/yr) or 

inorganic HAP (tons/yr) that were in the coatings that reached the part: 

A = B * C 

Where: 

A = PM, as coating solids, or inorganic HAP reaching the part (tons/yr); 

B = Transfer efficiency, fraction; 

C = PM, as coatings solids, or inorganic HAP that does not become waste, tons/yr. 
0223-00-008\MSCAS Baseline Emissions & Reductions 6

The above equation was performed for the fraction of coatings applied with conventional 

spray guns and with HVLP spray guns, and then the two were summed to determine the total PM 

and inorganic HAP reaching the part from all surface coating. 

The following equation was used to estimate the PM (as coating solids) or inorganic HAP 

that become airborne overspray (tons/yr): 

D = (C – A)*(1 – E) 

Where: 

D = PM, as coating solids, or inorganic HAP that become airborne overspray tons/yr); 

C = Inorganic HAP and coatings solids that does not become waste, tons/yr; 

A = Inorganic HAP or PM reaching part, tons/yr); 

E = Fraction of overspray that settles on other surfaces; 

The following equation was used to estimate baseline emissions of PM and inorganic 

HAP (tons/yr): 

F = D*(((1-G)) + (G*(1-H))) 

Where: 

F = Baseline emissions of PM or inorganic HAP from shops without a booth (tons/yr); 

D = Solids and inorganic HAP the become airborne overspray (tons/yr); 

G = Baseline fraction of coatings applied in a booth; 

H = Baseline average paint arrestor efficiency (fraction). 

Methodology for Final Emissions of PM and Inorganic HAP

The following equation was used to estimate the solids and inorganic HAP reaching the 

parts after all facilities are using HVLP spray guns (tons/yr): 

AA = BB * C 

Where: 

AA = PM, as coating solids, or inorganic HAP reaching the part after all facilities are using 

HVLP spray guns (tons/yr); 

BB = Transfer efficiency, fraction, for HVLP spray guns; 

C = PM, as coatings solids, or inorganic HAP that does not become waste, tons/yr. 

The following equation was used to calculate the solids and inorganic HAP that becomes 

airborne overspray after all sources switch to HVLP spray guns (tons/yr): 
0223-00-008\MSCAS Baseline Emissions & Reductions 7

DD = (C-AA)*(1-E) 

Where: 

DD = PM, as coating solids, or inorganic HAP that become airborne overspray after all sources 

switch to HVLP spray guns (tons/yr); 

C = Inorganic HAP and coatings solids that does not become waste, tons/yr; 

AA = PM, as coating solids, or inorganic HAP reaching the part after all facilities are using 

HVLP spray guns (tons/yr); 

E = Fraction of overspray that settles on other surfaces. 

The following equation was used to calculate the final PM and inorganic HAP that are 

emitted from the overspray (tons/yr) after all spraying is done in booths with filters: 

FF = DD*(((1-GG)) + (GG*(1-HH)) 

FF = PM or inorganic HAP that become airborne overspray after all spraying is done in a 

booth with filters (tons/yr); 

DD= PM, as coating solids, or inorganic HAP that become airborne overspray after all sources 

switch to HVLP spray guns (tons/yr); 

GG = Final fraction of coatings applied in a booth; 

HH = Final paint arrestor efficiency (fraction). 
 Gallons Coating 

Coating 

(ton/yr) 

Organic HAP 

(ton/yr) 

VOC 

(ton/yr) 

Solids 

(ton/yr) 

Total 

Inorganic 

HAP (ton) 

Pb 

Compounds 

(ton/yr) 

Cr 

Compounds 

(ton/yr) 

Totals for 236 area sources in merged database 

which submitted data 5,994,596 26,193 947.4 14,163 6,054 18.50 10.58 5.55

Percent of coating that becomes waste and goes into a "sealed" drum 10%

Non-waste consumption that is potentially emitted (ton/yr) 853 12,747 5,449 16.65 9.52 5.00

Percent of operations spraying with conventional spray guns 20.00%

Transfer efficiency from conventional spray guns 30.00%

Transfer efficiency from HVLP 48.00%

Gallons needed to spray to get one gallon on part with conventional guns 3.33

Gallons needed to spray to get one gallon on part with HVLP guns 2.08

Reduction in gallons of coating used as a result of switching from conventional spray guns to HVLP 37.50%

 Organic HAP VOC

Baseline pollutant emissions (tons/yr) 853 12,747

Emissions from operations using conventional spray guns (tons/yr) 171 2,549

Emission reductions from switching from conventional to HVLP (tons/yr) 64 956

Emission reductions as percent of baseline 7.5% 7.5%

(Reductions are due to decreased coating usage after switching to HVLP)

Emissions after operations have switched to using HVLP (tons/yr) 789 11,791

For solids and inorganic HAP, these values are consumption rates, not emissions

Baseline consumption rates (tons/yr) 5,449 16.65 9.52 5.00

Baseline consumption at operations using conventional spray guns (tons/yr) 1,090 3.33 1.90 1.00

Baseline consumption at operations using HVLP spray guns (tons/yr) 4,359 13.32 7.62 4.00

Solids and inorganic HAP reaching part from facilities using conventional spray guns (tons/yr) 327 1.00 0.57 0.30

Solids and inorganic HAP reaching part from facilities using HVLP (tons/yr) 2,092 6.39 3.66 1.92

Total solids and inorganic HAP reaching the parts 2,419 7.39 4.23 2.22

Percent of overspray that settles on other surfaces 50%

Solids and inorganic HAP the become airborne overspray (tons/yr) 1,515 4.63 2.65 1.39

Baseline percent of coatings applied in a booth 88%

Assumes all coatings at sources with a booth are applied in a booth. 75% have dry filters and 13% have wet filters (88% total)

Baseline paint arrestor efficiency 96%

Baseline Air Emissions of PM and Inorganic HAP (tons/yr) 235 0.718 0.41 0.22

Solids and inorganic HAP reaching part after all facilities are using HVLP spray guns (tons/yr) 2,615 7.99 4.57 2.40

Solids and inorganic HAP the become airborne overspray (tons/yr) 1,417 4.33 2.48 1.30

Rule percent of coatings applied in a booth 100%

Rule paint arrestor efficiency 98%

Final (after rule) Air Emissions of PM and Inorganic HAP (tons/yr) 28.33 0.087 0.05 0.03

PM and Inorganic HAP Emission Reductions (tons/yr) 207 0.63 0.36 0.19

PM and Inorganic HAP Emission Reductions (%) 88% 88% 88% 88%
10.0 

Estimate of Capital and Annual Costs For Automotive Refinishing Operations and 

Miscellaneous Surface Coating Operations Subject to the Proposed National Emission 

Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous Surface 

Coating Operations at Area Sources 
0223-00-008\Auto Refinishing Capital & Annual Cost 1

MEMORANDUM 

TO: Warren Johnson, U.S. EPA, Sectors Policies and Programs Division/Natural 

Resources and Commerce Group 

FROM: Brandin McDonough and Brian Palmer, Eastern Research Group, Inc. (ERG) 

DATE: May 18, 2007 

SUBJECT: Estimate of Capital and Annual Costs For Automotive Refinishing Operations and 

Miscellaneous Surface Coating Operations Subject to the Proposed National 

Emission Standards for Hazardous Air Pollutants for Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources 

This memo documents the procedures we used to estimate costs for all surface coating 

area sources that would be regulated under the Miscellaneous Surface Coating Area Source 

National Emission Standards for Hazardous Air Pollutants (NESHAP). We estimate that the 

controls required to comply with the proposed standards for surface coating operations at about 

36,000 automotive refinishing shops and 800 miscellaneous plastic and metal part surface 

coating operations would have no net annual costs to those surface coating operations. The 

initial cost of complying with the proposed standards would be off-set and recovered over time 

by cost savings as a result of more efficient use of labor and materials by surface coating 

operations. 

Initial and annualized costs were estimated for the following proposed rule requirements: 

• Completing painter training to properly set up and use high-volume low-pressure 

(HVLP) spray guns to increase transfer efficiency at all by an estimated 94,533 

painters. 

• Upgrading to HVLP spray guns at 208 sources with the purchase of an average of 3 

guns per source (624 spray guns, total). 

• Installing enclosed and automated gun washers at 5,214 sources. 

• Complying with equipment specifications or minimum efficiency standards for paint 

spray booth exhaust filters. 
0223-00-008\Auto Refinishing Capital & Annual Cost 2

Table 1 summarizes the initial cost and annualized cost impacts of the miscellaneous surface 

coating standards. As explained in the following sections, we estimate that the proposed 

standards for surface coating operations will have no net annual cost after cost savings are taken 

into account. 

Table 1. National Initial and Annualized Costs of Miscellaneous Surface Coating Area 

Source Requirements. All costs are in millions (MM) of dollars. 

Cost Item Number required Capital Cost ($MM) Annualized Cost ($MM)

Painter 

Training 

94,533 $94.5 $18.9 

HVLP guns 624 $0.44 $0.06 

Gun washers 5,214 $9.4 $1.33 

Total $104.3 $20.29 

The cost of installing and operating spray booths are not included in the estimated total 

costs impacts for this rule because spray booths are previously required for compliance with 

existing OSHA standards (29 CFR 1910.94(c) and 1910.107(b)). Some surface coating sources 

may need to replace their current filters for ones with higher paint overspray capture efficiency, 

but the higher efficiency filters are readily available and will not result in an additional cost. 

Assumptions and Procedure for Estimating Painter Training Costs

To estimate painter training costs, we developed four categories of model shops. Three 

model shops represented automotive refinish shops and one model shop represented a 

miscellaneous surface coating operation. 

The three model automotive refinish shops were based on information obtained in the 

2003 U.S. Census County Business Patterns and through EPA site visits, and are summarized in 

Table 2.1These models included the total number of employees and number of painters. 

 

1 Memorandum. To: Kim Teal, U.S. EPA, Sector Policies and Programs Division/Natural Resources and Commerce 

Group (E143-03). From: Brian Palmer, Eastern Research Group, Inc. July 17, 2006. Development of Model Shops 

for Sources Subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Motor Vehicles 

and Mobile Equipment Refinishing Operations for Area Sources. 
0223-00-008\Auto Refinishing Capital & Annual Cost 3

Table 2. Summary of Automotive Refinishing Model Shop Parameters 

Shop Size Small Medium Large 

Number of Vehicles Refinished Per Month 40 100 200 

Number of employees 1-9 10-19 20 or more 

Estimated Number of Shops (from County 

Business Patterns) 

28,351 5,490 1,914 

Total Number of Employees (estimated from 

County Business Patterns) 

107,674 79,605 74,349 

Average number of employees per shop 3.8 14.5 39.4 

Number of Painters Per Shop 2 4 7 

Total Number of Painters Needing Training 56,702 21,960 13,398 

We estimated the number of painters for the three sizes of auto shops based on 

observations made during EPA site visits. Table 3 presents the number of vehicles per month 

and the number of painters at each of the sites visited by EPA. The sites with very low numbers 

of vehicles (5 or fewer per month) were either custom restoration shops or mobile equipment 

repair shops. 

Table 3. Vehicle and Painter Information Collected During EPA Site Visits 

Name and Location 

Vehicles per 

Month 

No. of 

Painters 

Advanced Restoration and Autobody, Sacramento, CA 1 1 

The Finish Line Restoration Services, Inc., Monrovia, CA 1 1 

Durham School District Transportation Department Garage, Durham, NC 3 2 

NC DOT Maintenance Garage, Raleigh, NC 5 1 

Gemini Autobody, Cedar Falls, IA 8 1 

Fulton Autobody, Sacramento, CA 15 1 

McJack’s Corvette, Santa Ana, CA 20 1 

Dale Bright Auto Service, Chino, CA 30 1 

Walt Stickel Body and Frame Shop, Inc., Sacramento, CA 45 2 

Cherry Auto Body, Chino, CA 60 2 

Coffman's Body Shop, Cedar Falls, IA 72 4 

Niello Collision Service, Sacramento, CA 90 3 

California Auto Body, Sacramento, CA 100 4 

Maaco Sacramento, CA 120 2 

Zimmerman Ford , Cedar Rapids, IA 150 4 

Bertolucci’s Body and Fender Shop, Inc., Sacramento, CA 200 5 

Falconi's Collision Center, Las Vegas, NV 280 5 

Deery Brothers Collision Center, Cedar Falls, IA 300 4 

Seidner’s Collision Center, Duarte, CA 310 9 

Based on the site visit information and contacts with industry, we estimated that a small 

shop (40 cars per month), would have two painters. For a medium shop (100 cars per month), 
0223-00-008\Auto Refinishing Capital & Annual Cost 4

we estimated four painters, and for a large shop (200 cars per month) we estimated seven 

painters. 

ERG contacted a coating vendor, Robert Blair of Finishmaster Automotive and Industrial 

Paint, who is a former auto refinisher and he concurred with our model shop estimates and 

observations for the number of painters at small and medium shops.

2

 He suggested that the 

number of painters for most of the large shops that we visited was probably too low because it 

only included the journeyman (finish) painters and did not include the painters that performed 

the priming and jamming, also known as prep painters. He confirmed that a shop servicing 300 

cars per month would have about nine painters, total. Therefore, for the large model shop, we 

estimated seven painters because it is the midpoint between the number of painters for a medium 

shop (100 cars per month) and the confirmed number of painters for a shop painting 300 cars 

visited during site visits. Since the proposed rule would require both prep and journeyman 

painters to receive training, we included both in the total number of painters. 

The model miscellaneous surface coating shop was developed from survey data collected 

from miscellaneous metal parts and miscellaneous plastic parts surface coating operations. The 

area source surface coating facilities reported an average of three coating scenarios. We 

assumed that the miscellaneous surface coating model shop would have three painters that would 

need training and three spray guns, one painter and spray gun per scenario. We estimated that 

831 facilities were represented by the miscellaneous surface coating model shop, for a total of 

2,463 painters who would need training. 

We estimated a training cost of $1,000 per painter for both automotive refinish painters 

and miscellaneous surface coating painters. This includes $360 tuition cost and $640 labor cost 

for 16 hours of training time at $40 per hour. These are based on the I-CAR 16-hour refinishing 

course sequence that included “Refinishing Equipment and VOC Regulations,” “Surface 

Preparation and Masking,” and “Color Theory, Application, Tinting, and Blending.”3

Since the training would be valid for a period of 5 years, the annualized cost was 

assumed to be one-fifth of the initial training cost, to account for worker turnover and the need to 

 

2

Telephone Call Record: Robert Blair, Field Sales Manager, Finishmaster Automotive and Industrial Paints. March 

2, 2007. 

3

http://www.i-car.com/html_pages/training_programs/pricing.shtml. A the time these costs were first estimated by 

ERG in July 2006, costs were $90 per unit and each unit was equal to 4 hours of instruction; 16 hours of instruction 

would cost $360 for 4 units. 
0223-00-008\Auto Refinishing Capital & Annual Cost 5

train new painters. The initial national cost to train 94,553 painters would be $94.5 million and 

the annual cost would be $18.9 million. 

However, we believe that the actual annual cost of training to improve painter efficiency 

could be offset through reduced coating consumption and associated cost. Although the actual 

volume of coating use that can be reduced at each shop through training is difficult to estimate, it 

can be reduced substantially. Painter training programs that address increasing transfer 

efficiency, such as the Iowa Waste Reduction Center (IWRC) Spray Technique Analysis and 

Research (STAR®) program, have shown that the amount of coating sprayed per job can be 

reduced by 13 to 18 percent.4 This increase in efficiency is expected to translate into reduced 

coating costs, but a one-to-one savings is not expected since, in some cases, a minimum amount 

of coating may still need to be mixed to achieve the correct color match and the excess coating 

will result in some coating becoming waste. 

It is important to note that these “untrained” operators are not inexperienced painters. 

They often have many years of experience before they enter these training programs. However, 

they have not been specifically trained in how to best set up and operate high efficiency spray 

equipment and to optimize their technique to maximize transfer efficiency and minimize coating 

consumption. 

Annual coating costs were estimated for each model shop based on information provided 

by Robert Blair of Finishmaster Automotive and Industrial Paint.5 Mr. Blair provided the 

estimated coating costs for the following customer shops, which he felt are typical of many 

automotive refinish shops: 

Shop 1: 2 painters, 40 to 50 cars per month, $5,000 per month for coatings. 

Shop 2: 9 painters, 300 cars per month, $35,000 per month for coatings. 

Mr. Blair felt that these two shops were indicative of the average coating cost for all likesized shops. Based on the information provided, we estimated the average coating cost per car is 

about $110: 

$35,000/month ÷ 300 cars/month = $116/car 

$5,000/month ÷ 45 cars/month = $111/car. 

 

4 www.iwrc.org/staruserqueries/avg_of_all_trainees.cfm (accessed on March 31, 2006) and 

http://www.star4d.org/database.cfm (accessed on July 17, 2006). 

5 Telephone Call Record: Robert Blair, Field Sales Manager, Finishmaster Automotive and Industrial Paints. March 

2, 2007. 
0223-00-008\Auto Refinishing Capital & Annual Cost 6

The annual coating cost for the small (40 cars/month), medium (100 cars/month), and 

large (200 cars/month) model shops was calculated using the relative number of cars per month 

as follows: 

Small shops: ($110/car)(40 cars/month)(12 months) = $58,200/yr 

Medium shops: ($110/car)(100 cars/month)(12 months) = $132,000/yr 

Large shops: ($110/car)(200 cars/month)(12 months) = $264,000/yr 

We estimated the annual coating savings that would be required to offset the training cost 

of $1,000 per painter in a single year. Since the proposed rule would allow a painter to use 

training completed in the last 5 years to satisfy the training requirements and the training 

certification is valid for 5 years, we also estimated the annual coating savings that would be 

required to offset the training costs over a 5 year period. 

Table 4 shows the percent reductions of coating use and cost required to offset the 

training costs for both 1 year and 5 year payback periods for each of the three model shop types. 

If a shop were able to reduce annual coating use and costs by 5 percent, then the model shops 

would see a net cost savings in the first year, even after including the cost of training. These 

savings based on a 5 percent coating reduction are also presented in Table 4. 

Table 4. Estimated Cost Savings Needed to Offset Training Costs in 1- and 5-Year Periods, 

and Estimated Net Cost Savings in 1 Year if Shops Reduce Coating Costs by 5 Percent 

Shop Size Small Medium Large 

Number of Vehicles Refinished Per Month 40 100 200 

Estimated Number of Painters 2 4 7 

Estimated Training Cost per Shop $2,000 $4,000 $7,000 

Annual Coating Cost $58,200 $132,000 $264,000 

Reduction in coating use and cost required to 

recoup the training costs in 1 year. 

3.4% 3.0% 2.7% 

Reduction in coating use and cost required to 

recoup the training costs in 5 years. 

0.7% 0.6% 0.5% 

Coating cost savings at 5 percent reduction in 

annual coating cost 

$2,910 $6,600 $13,200 

Net cost savings in 1 year after training cost at 

5 percent reduction in annual coating cost 

$910 $2,600 $6,200 

The coating reduction required to offset the cost of painter training in a single year, 

included in Table 4, was calculated by dividing the estimated cost of painter training by the 

estimated annual coating cost, for each model shop. 
0223-00-008\Auto Refinishing Capital & Annual Cost 7

Small shops: (2 painters * $1,000) ÷ $58,200 = 3.4 percent 

Medium shops: (4 painters * $1,000) ÷ $132,000 = 3.0 percent 

Large shops: (7 painters * $1,000) ÷ $81,000 = 2.7 percent 

The coating reduction required to offset the cost of painter training over 5 years was 

calculated by simply dividing the reduction needed in a single year by 5. All size model shops 

could recover their training costs in 1 year if the coating costs were reduced by at least 3.5 

percent. We expect that most shops could reduce their costs by at least this amount, and could 

begin to see cost savings that exceed the cost of initial training in the first year after training is 

completed. 

These estimates are consistent with estimates from the Iowa Waste Reduction Centers 

STAR® program, as reported by the EPA’s Design for the Environment (DfE) program.6 The 

STAR® program, in year 2000, estimated that a shop refinishing 15 cars per week (60 cars per 

month) that switched from conventional to HVLP spray guns could save $6,900 per year in 

coating costs. The same shops switching to HVLP and receiving training to use more efficient 

spray techniques were estimated to save $13,000 per year. We could assume that the difference, 

$6,100/year, would be the savings from training alone at shops that already use HVLP spray 

guns. This value ($6,100/year) is between the estimated cost savings for the small and medium 

model shops, when we assume that coating costs were reduced by 5 percent. 

Although cost savings were not specifically estimated for miscellaneous surface coating 

shops, we expect that reduced coating consumption at these facilities would also be sufficient to 

offset the additional cost of painter training. 

Assumptions and Procedure for Estimating HVLP Spray Gun Costs

We have assumed that HVLP spray guns are the industry standard for auto refinishing 

area sources and that only a substantial number of miscellaneous surface coating facilities would 

need to purchase HVLP spray guns. We estimated that 25 percent of miscellaneous surface 

 

6

http://www.epa.gov/dfe/pubs/auto/spraygun/spraygun.pdf United States Environmental Protection Agency. 

Design for the Environment, Auto Refinishing Shop Project. June 2000. “HVLP SPRAY GUNS: Cost-effective, 

environment-friendly technology.” EPA 744-F-00-004. 
0223-00-008\Auto Refinishing Capital & Annual Cost 8

coating area sources do not use HVLP spray guns, based on the percentage of sources that did 

not report using these types of spray guns or an equivalent, such as electrostatic spray guns. We 

estimated that there are a total 831 miscellaneous surface coating area sources and an average of 

three coating scenarios per area source. The number of area sources and the estimated percent 

needing to purchase HVLP spray guns is based on survey data collected from area sources in 

response to the EPA surveys used to develop 40 CFR part 63, subparts MMMM and PPPP.7,8 

We assumed that area sources would probably need to purchase multiple spray guns and 

assumed that one new spray gun would be purchased for each coating scenario reported by a 

source. We estimated that the total number of spray guns required is: 

831 sources * 25% needing spray guns* 3 guns/source = 624 guns 

The estimated cost for an industrial quality HVLP spray gun and accessories (e.g., larger 

diameter hose, gauges, extra air caps) is $700, based on vendor information.9 The total capital 

cost to purchase 624 guns would be $0.44 million 

We estimated annualized costs using the standard method and factors presented in the 

EPA Air Pollution Control Cost Manual (EPA/452/B-02-001). Table 5 shows the cost elements 

used to estimate annualized capitol costs. Capital recovery factors for all equipment were based 

on a 10-year economic life and 7 percent interest. 

 

7 Memorandum. To: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural Resources and 

Commerce Group. From: Brian Palmer, Eastern Research Group, Inc. July 19, 2006. Estimating the Number of 

Miscellaneous Surface Coating Area Sources for Which EPA Has Data. 

8 Memorandum to: Kim Teal, U.S. EPA, Sectors Policies and Programs Division/Natural Resources and Commerce 

Group (E143-03). From: Brian Palmer, Eastern Research Group, Inc. July 19, 2006. Analysis of Generally 

Available Control Technology (GACT) Options for the National Emission Standards for Hazardous Air Pollutants 

(NESHAP) for Miscellaneous Surface Coating Operations at Area Sources. 

9 HVLP Spray Gun Costs – Model 248 Astro 

http://www.airmaxproducts.com/finishing_supplies.htm

Low End HVLP Spray Gun: High Point http://www.spraygunworld.com/products/HP/Highpoint2.html

Sata Jet 2000 HVLP Spray Gun: Model # SAT61168 http://search.cartserver.com/search/search.cgi?cartid=a6834&category=datapaint&maxhits=20&keywords=SAT61168

Compressed Air Hoses for HVLP – Costs 

http://www.1st-in-hvlp.com/compressed_air_hose.htm

Sata Satajet 3000 HVLP Spray Gun: Model SAT133025 

http://www.spraygunworld.com/products/SATA/SATA%20HVLP%20133025.htm

DeVilbiss HVLP Spray Gun: Model DEVGTI620S - GTI2000 HVLP 

http://www.spraygunworld.com/products/DeVilbiss/DeVilbiss%20DEVGTI620S.htm
0223-00-008\Auto Refinishing Capital & Annual Cost 9

Table 5. Derivation of Net Annualized Cost 

Capital Cost Elements 

Installed Cost A 

Annualized Capitol Cost Elements

Equipment Economic Life n = 10 years 

Interest Rate i = 7 percent (0.07) 

Capital Recovery Factor B = i*(1 + i)n = 0.142 

(1 + i)n-1 

Annualized Capital Recovery Cost C = A*B 

Using the capital recovery factor as derived above (10 year life, 7 percent interest), the 

annualized capital cost for an HVLP gun is $700 × 0.142 = $100 per gun. We assumed that 

sources would have no additional insurance, tax, or other administrative overhead costs for the 

spray guns since these were replacements for existing spray guns. 

Cost savings from improved transfer efficiency and reduced coating usage were not 

estimated for the miscellaneous surface coating sources since we do not have coating cost data 

specific to these sources. However, based on the information collected by the IWRC and 

summarized above with respect to painter training, we expect that the cost savings compared to 

conventional spray guns would be sufficient to at least offset the annualized capital costs of 

purchasing HVLP or equivalent spray guns. 

Assumptions and Procedure for Estimating Gun Washer Costs

We estimated that about 5,214 sources would not have automated enclosed spray gun 

washers. While sources often use multiple spray guns, a single gun washer is typically adequate 

to service all spray guns at a facility, particularly for area sources. The EPA visited over 20 

automotive refinishing facilities and all but the smallest shop used an automatic, enclosed spray 

gun washer. The one shop that did not have a gun washer cleaned guns by hand in a small 

covered parts cleaning tray that held solvent. This latter shop would be able to comply with the 

proposed standards as long as no cleaning solvent was atomized through the spray gun. 

For automotive refinishing shops, we assumed that 14 percent of shops, or about 5,006 

shops, that did not report having a spray booth would also not have a gun washer. For 

miscellaneous surface coating shops, we assumed that the same 25 percent of shops that did not 

have HVLP spray guns, or about 208 shops, would also not have a gun washer. 
0223-00-008\Auto Refinishing Capital & Annual Cost 10

The estimated capital cost for a spray gun washer was $1,800, based on calls with gun 

washer vendors and information available from internet-based searches.10 We assumed that 

shops without a spray gun washer would install a durable, low-cost spray gun washer instead of a 

more expensive model. However, less expensive gun washers are available, including a 

frequently observed model that is available for less than $1,000. 

The total capital cost to purchase 5,213 gun washers would be $9.4 million. 

Using the same capital recovery factor as derived above, the annualized capital cost for a 

gun washer is $1,800 × 0.142 = $256. 

The total annualized cost for all 5,214 sources estimated to need an enclosed spray gun 

washer was $1.33 million per year. However, we estimate that the initial cost of a gun washer 

could be offset within 1 year at nearly all shops through reduced labor to wash spray guns and 

through more efficient use of cleaning solvent, compared to manual spray gun washing. The 

more efficient use of solvent would reduce solvent costs and the costs to properly dispose of 

spent solvent. 

Although spray gun washers can potentially reduce solvent and labor costs, and reduce 

emissions, the actual volume of solvent that can be reduced is difficult to estimate due to 

variances in enclosed gun cleaner makes, models, and solvent recovery efficiency. The 

Department of Defense’s Joint Services Pollution Prevention Handbook states that “automatic 

paint gun washers can reduce the amount of solvent used and paint solvent waste generated by 

70 to 80 percent when compared to manual paint gun cleaning.” 11 As a conservative estimate, 

we used a 70 percent reduction of solvents to calculate associated cost savings. Even greater 

reductions in solvent use and waste generation are possible with systems that also use a still to 

recover clean solvent from waste paint and spent solvent, but these are more expensive than just 

an automated gun washer. 

To estimate potential cost savings for automated gun washers compared to manual gun 

washing we used the following assumptions: 

Labor Rate ($/hour): $40.00 

Solvent cost: $6.75/gallon 

 

10 Paint Gun Equipment Washer from SAFETY-KLEEN: Model 1111 

http://www.safety-kleen.com/SKInternet/SKShoppingDetailParts.aspx?ItemCode=6512

Manual Paint Gun Washer from SAFETY-KLEEN: Model 1077 

http://www.safety-kleen.com/SKInternet/SKShoppingDetailParts.aspx?ItemCode=6630

11 http://p2library.nfesc.navy.mil/P2_Opportunity_Handbook/4_9.html 
0223-00-008\Auto Refinishing Capital & Annual Cost 11

Paint sludge waste disposal cost: $5.10/gallon 

Monthly equipment service fee: $17.00 

The labor rate is based on an industry survey by Body Shop Business magazine.

12

 The 

costs for solvent, paint sludge waste disposal, and the monthly service fee are based on 

information from a site visited by EPA. 

We assumed each vehicle would require at least 3 gun washings for a primer, color coat, 

and clear coat. We also assumed that manual gun washing would require 10 minutes and 

automatic gun washing would require 1 minute of labor to load the gun in the washer, based on 

the assumptions in the Joint Services Pollution Prevention Handbook.13 We assumed that 

manual gun cleaning would require the use of 10 ounces of solvent per gun and automated gun 

washing 3 ounces per gun (a 70-percent reduction). We assumed no costs for paint sludge waste 

or solvent disposal for manual gun cleaning, even though it would be difficult to avoid these 

costs and remain in full environmental compliance for waste disposal. For waste paint sludge 

disposal costs with a gun washer, we assumed that the volume of waste sludge was equal to 

solvent purchases to maintain a constant solvent level in the machine. 

The results of the gun washer cost analysis are presented in Table 6. Since we observed 

enclosed gun washers at all but one automotive refinishing shop visited by EPA, only results 

estimated for shops refinishing only 10, 20, and 40 cars per month are presented here since these 

are the shops most likely to have to purchase a gun washer. 

Even a shop refinishing 10 cars per month could see a net annual cost savings that would 

offset the initial cost of an enclosed spray gun washer. A major component of these cost savings 

is the cost of labor saved. However, even if the assumptions are changed to reduce the 

difference in labor required to clean guns manually and with a gun washer (e.g., 5 minutes and 2 

minutes, respectively), the cost savings could still offset the initial cost of a gun washer in 5 

years or less. 

 

12 http://www.babcox.com/editorial/bb/704OperationsProf.pdf

13 http://p2library.nfesc.navy.mil/P2_Opportunity_Handbook/4_9.html 
0223-00-008\Auto Refinishing Capital & Annual Cost 12

Table 6. Gun Washer Cost Savings Analysis 

Model Shop Parameters 

Cars per month per model shop 10 20 40 

Gun washings per month 30 60 120 

Manual Gun Washing Calculated values 

Calculated manual solvent use per month 

(gallons) 2.3 4.7 9.4 

Manual solvent cost per month $ 15.82 $ 31.64 $ 63.28 

Manual gun washing labor per month 

(hours) 5.00 10.00 20.00 

Manual gun washing labor cost per month $ 200.00 $ 400.00 $ 800.00 

Total Monthly Cost $ 215.82 $ 431.64 $ 863.28 

Total Annual Cost for Manual Gun Washing $2,589.84 $5,179.69 $10,359.38 

Automated Gun Washing Calculated values 

Gun washer virgin solvent use per month 

(gallons) 0.7 1.4 2.8 

Gun washer solvent cost per month $ 4.75 $ 9.49 $ 18.98 

Gun washer waste sludge disposal cost per 

month $ 3.59 $ 7.17 $ 14.34 

Gun washer labor per month (hours) 0.50 1.00 2.00 

Gun washer labor cost per month $ 20.00 $ 40.00 $ 80.00 

Service fee per month $ 17.00 $ 17.00 $ 17.00 

Monthly cost for solvent, waste, labor and 

fee $ 45.33 $ 73.66 $ 130.33 

Annual cost for solvent, waste, labor, and 

fee $ 543.98 $ 883.97 $ 1,563.94 

Annualized capital cost of gun washer $ 256.28 $ 256.28 $ 256.28 

Total Annual Cost for Gun Washer $ 800.26 $1,140.25 $ 1,820.22 

Estimated Annual Cost Savings for 

Automated Gun Washer Compared to 

Manual Gun Washing $1,789 $4,039 $ 8,539 

Assumptions and Procedure for Estimating Spray Booth Costs 

The proposed rule would require all spray applied surface coating to be done in a 

ventilated enclosure, such as a spray booth, with fiberglass or polyester fiber filters on the 

exhaust, or filters that are demonstrated to achieve at least 98-percent overspray capture 

efficiency. The capital cost of installing a spray booth and annual operating costs were not 

included in the capital and annualized cost estimates because spray booths or similar enclosures 

are already required by existing OSHA standards such as 29 CFR 1910.94(c) or 1910.107(b). 

The proposed rule would only specify exhaust filter requirements, which are not addressed by 

the existing OSHA standards. We do not expect that the proposed standards would have any 
0223-00-008\Auto Refinishing Capital & Annual Cost 13

cost impacts since compliant exhaust filters are readily available and the cost difference among 

exhaust filters is negligible. 

We have included a discussion of spray booth capital and annualized costs for 

informational purposes for those affected sources that may need to install a spray booth to 

comply with this proposed rule as well as other existing rules. 

Based on this information we have gathered, we estimate that about 5214 area sources 

affected by this rule may not have a spray booth. This estimate includes 5005 automotive 

refinishing shops and 208 miscellaneous surface coating area sources. A 2003 reader survey 

reported that 51 percent of automotive refinishing shops had a downdraft spray booth and 35 

percent had a cross draft spray booth.14 We assumed this meant that 14 percent of shops had no 

spray booth. Based on a population of 35,755 automotive refinishing shops, according to the 

2003 County Business Patterns from the U.S. Census, we estimated that 5,006 shops may not 

have spray booths. 

For miscellaneous surface coating shops, we used data collected in support of 40 CFR 63 

subparts PPPP and MMMM that showed that 25 percent of miscellaneous surface coating area 

sources did not report having spray booths with dry filters. Based on this information, we 

estimated that 208 miscellaneous surface coating area sources affected by this rule may not have 

spray booths. 

 The estimated capital cost for a spray booth was $10,000, including installation. This 

approximate cost was based on the cost of an inexpensive cross draft automotive refinishing 

booth.15 We assumed that sources without a booth would purchase the lowest cost booth needed 

to comply, rather than more expensive booths, such as downdraft booths or booths with separate 

heating systems. We also assumed that this cost would be a reasonable surrogate for the cost of 

a booth used in miscellaneous surface coating operations. Using the capital recovery factor 

derived above (0.142), the annualized capital recovery cost for the booth is $1,420. 

The total annualized costs are equal to the annualized capital costs, plus the annual 

operating costs for the spray booth. The estimated annual operating costs for a spray booth are 

listed Table 7: 

 

14 http://www.bodyshopbusiness.com/bb/Purchases.pdf

15 See, for example, http://www.sprayshield.com/cgi-bin/hazel-cgi/hazel.cgi?action=serve&item=ECF-1000.html. 

Web page for an economy cross flow spray booth ($4899), plus cost for exhaust package ($700) and fire suppression 

system ($2,999). 
0223-00-008\Auto Refinishing Capital & Annual Cost 14

Table 7. Estimated Spray Booth Annual Operating Costs. 

Annual Operating Cost Item Cost per year 

Air Intake Filters (Cross Flow Booth) $ 152

Exhaust Filters (paint extractors) (Cross Flow Booth) $ 58 

Exhaust Filters disposal $ 440

Taxes, insurance, admin. costs (4% of installed capital cost):$ 400

Natural gas to heat make-up air $ 2,011

Electricity for fan in booth $ 171

The costs for intake and exhaust filters and used filter disposal are based on the estimated 

costs provided by an automotive collision repair facility visited by EPA. These costs have been 

estimated for a small automotive refinishing facility that refinishes 40 cars per month, since these 

small facilities are most likely to not already have a booth. Taxes, insurance, and administrative 

costs were assumed to be 4 percent of the installed capital cost. This is a standard assumption 

for EPA cost estimates. 

Natural gas is needed to heat the air that is used by the booth during cold weather months 

to maintain a constant shop and booth temperature. We estimated the annual cost of natural gas 

using the following assumptions: 

• The booth would operate 1,000 hours per year at a flow rate of 10,000 cubic feet per 

minute. 

• For 500 hours per year of operation, the air would need to be heated from 50 degrees 

F (a national average wintertime temperature) to 70 degrees F. 

• The heater would be 80 percent efficient. 

• The price of natural gas would be $13.50 per thousand cubic feet (mcf), based on the 

average cost for natural gas from the Energy Information Administration for the 

Winter of 2005 to 2006 (October to March, inclusive). 

• The heating value of natural gas would be 950 Btu per cubic foot. 

The estimated annual cost of natural gas would be $2011: 

$2011

(density of air 13.1lb/cf)(0.80 heater efficiency)(950 Btu/cf)(1,000 cf/mcf)

(10,000 cfm)(heat capacity of air 0.24 Btu/lb oF)(70 - 50 oF)($13.50/mcf)(60 min/hr)(500 hrs)

=

Electricity would be needed to operate the fans of a spray booth to move the air in and 

out of the spray booth. Electricity costs were estimated using an algorithm adapted from the 

OAQPS Control Cost Manual procedure to estimate operating costs for ventilation ductwork. 
0223-00-008\Auto Refinishing Capital & Annual Cost 15

The algorithm estimated annual electricity cost based on flow rate, pressure drop, and electricity 

cost per kilowatt-hour (kwh). We estimated the annual cost of electricity using the following 

equation and assumptions: 

Annual electricity cost ($/yr) = 0.0001175*Hours*Flow*∆P*Price/Efficiency 

Where: 

0.0001175 = an empirical computational constant with units of 

(hrs ∙ acf ∙ in. water/min ∙ kwh) 

Hours = annual hours of operation, assumed to be 1,000 hours per year. 

Flow = booth air flow rate, assumed to be 10,000 cubic feet per minute, based on 

vendor information. 

∆P = The total pressure drop across the spray booth system (inlet filters, outlet 

filters, and ductwork) would be 1.0 inches of water. This is over twice the 

maximum pressure drop for a loaded spray booth filter to also account for 

the pressure drop of the inlet filters. 

Price = The price for electricity, $0.0872 per kwh, based on the national average 

for 2005 from the U.S. Energy Information Service. 

Efficiency = The fan and motor combined efficiency, using the standard assumption 

from the OAQPS Control Cost Manual of 60 percent. 

The annual operating cost for a spray booth is estimated to be $3,231. After adding the 

annualized capital cost of $1,424, the total annualized cost for a spray booth would be $4,655 per 

year. 
Number of U.S. Automotive Refinishing Establishments by Employment Size Class for the Paint or Body Repair Shops (NAICS 811121)

1-4 5-9 10-19 20-49 50-99 100-249 250-499 500-999 1000+ Totals

Number of 

Establishments 20,174 8,177 5,490 1,778 110 22 3 - 1 35,755

Source: 2003 County Business Patterns

Estimated Average 

Number of 

Employees 

(basedon midpoint 

of size range) 2.5 7 14.5 34.5 74.5 174.5 324.5 0 1000

Employees per 

business size range 

(based on median) 50,435 57,239 79,605 61,341 8,195 3,839 974 - 1,000 262,628

Average number of employees per shop 7.3

Body ShopBusiness reported a median of 5 employees per shop and an average of 7.1 per shop.

Model shop sizes are small (1-9 employees), medium (10 - 19 employees) and large (20 or more employees)

Small Medium Large

Shops per size 

class 28,351 5,490 1,914 35,755

Employees per size 

class 107,674 79,605 75,349 262,628

Average employees 

per size class 3.80 14.50 39.37

Number of painters 

per model shop 2 4 7

Total Painter s per 

shop size class 56,702 21,960 13,398 92,060

Booths per model 

shop 1 2 3

Total number 

booths 23,345 10,980 5,742 40,067

From Body Shop Business June 2003 Reader Survey

Average salary of painters: $ 43,725 $ 21.02 $/hr

Average posted labor rate ($/hr) for metal/refinish work: $ 40

Percent of shops with a downdraft spray booth: 46%

Percent of shops with a crossdraft spray booth: 40%

Percent of shops with a prep station 31%

Percent of shops without a booth 14%

Assume these are are all small shops

Number of small shops without a booth 5,006

Number of Employees

Automotive Ref. Pop. Data
From Body Shop Business June 2003 Reader Survey

Average salary of painters: $ 43,725

Average posted labor rate ($/hr) for metal/refinish work: $ 40

Body Shop Business reported that 67.4% of shops had at least one ASE certified tech (not necessarily a painter)

32.7% of shops hired techs from votech schools.

Total number of employees estimated from 2003 County Business Patterns: 262,628

Total estimated number of painters: 92,060

Percent of painters who are trained per year 20%

Total number of painters trained per year: 18,412

Hours of training: 16

Tuition cost of training course (Based on I-CAR Refinishing Course sequence): $ 360

Labor cost of training based on average posted labor rate $ 11,783,680

(#painters X hours X posted labor rate)

Tuition cost of training ($360 per course based on ASE tuition cost) $ 6,628,320

Total training cost (labor and tuition) $ 18,412,000

Estimated coating cost per car $110

Baseline coating costs

Cost per model shop: Annual cost

Small shops: 40 cars/mo $ 52,800

Medium shops 100 cars/mo $ 132,000

Large shops 200 cars/mo $ 264,000

Training
References

Labor Rate ($/hour) $ 40.00 From Body Shop Business survey

Solvent cost ($/gallon) $ 6.75 From Seidners

Paint sludge waste disposal cost ($/gallon) $ 5.10 From Seidners

Monthly service fee $ 17.00 From Seidners, assumed to be the same for all size shops.

Capital Cost of Gun Washer $ 1,800.00 From web and calls to vendors. Some washers are <$1,000.

Inerest rate 7%

Capital recovery period (years) 10

Caclulated Capital Recovery Factor 0.1424

Annualized capital cost at 7% interest over 10 years $ 256

Gun washings per car (primer, base, clear) 3 Assumed

Minutes per manual gun cleaning 10 From DoD P2 Handbook gunwasher cost benefit analysis

Solvent used per manual gun washing (ounces) 10 From Becca (gun washer vendor)

Minutes per automated gun washer cleaning 1 From websites

Gun washer solvent efficiency 70% This assumes a gun washer reduces solvent use by this percent compared to manual gun washing

DoD P2 Handbook reported that gun washers could reduce solvent usage 70 to 90 percent

Virgin solvent use and sludge volume disposal are assumed to be equal to maintain a constant solvent level in the gun washer.

Cars per month per model shop 10 20 40 100 200

Gun washings per month 30 60 120 300 600

Calculated manual solvent use per month (gallons) 2.3 4.7 9.4 23.4 46.9

Annual VOC emissions (lbs) 196.9 393.8 787.5 1,968.8 3,937.5

Manual Washing Calculated values

Manual solvent cost per month $ 15.82 $ 31.64 $ 63.28 $ 158.20 $ 316.41

Manual gun washing labor per month (hours) 5.00 10.00 20.00 50.00 100.00

Manual gun washing labor cost per month $ 200.00 $ 400.00 $ 800.00 $ 2,000.00 $ 4,000.00

Total Monthly Cost $ 215.82 $ 431.64 $ 863.28 $ 2,158.20 $ 4,316.41

Annual cost $ 2,589.84 $ 5,179.69 $ 10,359.38 $ 25,898.44 $ 51,796.88

Automated Washing Calculated values

Gun washer virgin solvent use per month (gallons) 0.7 1.4 2.8 7.0 14.1

Gun washer solvent cost per month $ 4.75 $ 9.49 $ 18.98 $ 47.46 $ 94.92

Gun washer waste sludge disposal cost per month $ 3.59 $ 7.17 $ 14.34 $ 35.86 $ 71.72 Assumed sludge volume = virgin solvent volume.

Gun washer labor per month (hours) 0.50 1.00 2.00 5.00 10.00

Gun washer labor cost per month $ 20.00 $ 40.00 $ 80.00 $ 200.00 $ 400.00

Service fee per month $ 17.00 $ 17.00 $ 17.00 $ 17.00 $ 17.00

Monthly cost for solvent, waste, labor and fee $ 45.33 $ 73.66 $ 130.33 $ 300.32 $ 583.64

Annual cost for solvent, waste, labor, and fee $ 543.98 $ 883.97 $ 1,563.94 $ 3,603.84 $ 7,003.69

Annualized capital cost of gun washer $ 256.28 $ 256.28 $ 256.28 $ 256.28 $ 256.28

Total Annual Cost $ 800.26 $ 1,140.25 $ 1,820.22 $ 3,860.12 $ 7,259.97

Annual Cost Difference $ 1,789.58 $ 4,039.44 $ 8,539.16 $ 22,038.31 $ 44,536.91

Assumptions

Gun Washer
Number of area sources (entire category) 831 (Spray booths)

Scenarios per source 3 (From GACT memo, 2nd paragraph)

Fraction of sources without a booth: 0.25

Fraction of sources without enclosed gun washer0.25

Fraction of sources without HVLP spray guns: 0.25

Number of spray booths required 208 Based on survey Form D-4, 25% of area source scenarios do not use a filtered booth

Number of enclosed gun cleaners required 208 Based on survey Form D-4, 25% of area source scenarios do not use HVLP spray guns

Number of HVLP spray guns required 663 (1 per scenario)

Number of painters (3/source) 2493

HVLP spray gun capital cost

Installed Capital Cost (ICC) 700 includes new supply hose, spare parts

Interest rate 0.07

Equipment Life (Years) 10

Capital recovery factor 0.142378

Annualized capital cost 99.66425

Gun washer capital cost

Installed Capital Cost (ICC) 1800

Interest rate 0.07

Equipment Life (Years) 10

Capital recovery factor 0.142378

Annualized capital cost 256.2795

National costs

Number of spray guns per source 3 (1 per scenario, 3.2 scenarios per source)

Number of gun washers per source 1

Number of sources 831

Fraction without HVLP spray guns 0.25 Based on survey Form D-4, assumed to be same fraction (25%) of area sources that spray do not use a filtered booth

Fraction without enclosed gun washers 0.25 Assumed to be the same fraction that do not have a filtered booth.

HVLP guns 623.25 guns 

Gun washers 207.75 washers

Total capital cost for spray guns 436275

Total capital cost for gun washers 373950

HVLP Guns - Annualized costs 62115.75

Gun washers - annualized costs 53242.07

Misc metal & plastic part surface coating sources needing HVLP spray guns and gun washers

Misc. HVLP & washers
Spray Booth Cost Analysis

Installed Capital Cost $ 10,000

Interest rate 7%

Equipment Life (Years) 10

Capital recovery factor 0.142377503

Annualized capital cost $ 1,424

Annual Operating Costs Small Shop

Air Intake Filters (Cross Flow Booth) $ 152

Exhaust Filters (paint extractors) (Cross Flow Booth) $ 58

Exhaust Filters disposal $ 440

Taxes, insurance, admin. costs (4% of installed capital cost): $ 400

Natural gas to heat make-up air $ 2,011

Electricity for fan in booth $ 171

Annualized capital and operating costs per booth $ 4,655

Number of automotive shops that may need to purchase a booth: 5,006

Total capital cost for all shops $ 50,057,000

Total annual cost for all shops without a booth $ 23,301,883

Booth
Annual Costs for Seidner's Collision Centers 

Material or Equipment Description Cost Typical Monthly, Quarterly, or Annual Usage Annual Cost

Small Medium Large

Based on 100 repaired vehicles per month

Cost per 

car 40 100 200

Virgin Solvent (VOC 225gm/lt) used in gun washing equipment $6.75/gal 25 gallons/month $2,025 $1.69 $810.00 $2,025.00 $4,050.00

Paint Related Waste (liquid) Recycled Waste Hauled to Recycler $3.50/gal 28 gallons/month (adding for overpour) $1,176 $0.98 $470.40 $1,176.00 $2,352.00

Paint Related Waste (Sludge) Non Recycled Waste $5.10/gal 2 gallons/month $122 $0.10 $48.96 $122.40 $244.80

Paint Related Waste (Solid) Non Recycled Waste $6.80/gal 2 gallons/month $163 $0.14 $65.28 $163.20 $326.40

Monthly Service fee $17.00/month $204 $0.17 $81.60 $204.00 $408.00

Air Intake Filters (Down Draft Booth) $500/booth 1000 hours of booth operation (one year) $500 $0.42 $200.00 $500.00 $1,000.00

Air Intake Filters (Cross Flow Booth) $95/booth 250 hours of booth operation (one quarter) $380 $0.32 $152.00 $380.00 $760.00

Exhaust Filters (paint extractors) (Down Draft Booth) $30.00/booth one exchange/month $360 $0.30 $144.00 $360.00 $720.00

Exhaust Filters (paint extractors) (Cross Flow Booth) $12.00/booth one exchange/month $144 $0.12 $57.60 $144.00 $288.00

Exhaust Filters disposal $275/drum Quarterly (hauled to hazardous waste facility) $1,100 $0.92 $440.00 $1,100.00 $2,200.00

Air line maintenance (Oil Coalescing Filter & Desiccant beads) $125 semi annual $250 $0.21 $100.00 $250.00 $500.00

Air line exchange (heat breaks down airlines) $35/hose Quarterly $140 $0.12 $56.00 $140.00 $280.00

Color Correct Fluoresant Lamps $9.50/lamp 10/year $95 $0.08 $38.00 $95.00 $190.00

$6,660

Shop Size and Cars per Month

Annual Costs

Seidners
TOTAL ANNUAL COST SPREADSHEET PROGRAM--STRAIGHT DUCTWORK [1]

INPUT PARAMETERS

Spray booth flowrate (acfm): 10,000

Fan-motor combined efficiency (fraction): 0.60

Pressure drop (in. w.c.):[2] 1.000

ANNUAL COST INPUTS

Operating factor (hours/year): 1,000

Electricity price ($/kWhr) [3]: $ 0.0872 Average for 2005 from the U.S. Energy Information Service

 ANNUAL COSTS 1,958 kWhr/source

Item Cost ($/yr) 9,802,829 kWhr for all sources

Electricity $ 171

Notes:

-------

[1] Algorithm and data used to develop this program were taken from 'OAQPS

Control Cost Manual', 5th edition, Chapter 10.

[2] Assumed a pressure drop of 1.0 inches water column based on loaded exhaust filters.

[3] Average for 2005 from the U.S. Energy Information Service

http://tonto.eia.doe.gov/merquery/mer_data.asp?table=T09.09

accessed on June 28, 2006.

Electricity
Spreadsheet to estimate the cost of natural gas to heat make-up air maintain shop temperature during cold weather months

Assume no heating required 6 summer months 

Assume average daytime outdoor temperature of 50F, nationwide 6 months per year

Operate booth at 70F, 14,000 cfm, 1000 hrs/yr, 500 hrs/winter

Natural Gas cost from Energy Information Administration for Winter 2005-2006

$/mcf

Oct-05 $14.60 

Nov-05 $15.10 

Dec-05 $14.26 

Jan-06 $14.24 

Feb-06 $13.11 

Mar-06 $12.11 

Avg = $13.90

Flow, cfm

density of air at 

60F (lb/cf)

heat capacity of 

air (Btu/lb oF) ΔT (o

F) min/hr

heater 

efficiency gas price

low heating 

value (Btu/cf) (cf/mcf)

time 

(hrs)

10000 0.24 20 60 $ 13.90 500 = $2,011

13.1 80% 950 1000 year

Flow, cfm

density of air at 

60F (lb/cf)

heat capacity of 

air (Btu/lb oF) ΔT (o

F) min/hr

heater 

efficiency

low 

heating 

value 

(Btu/cf) (cf/mcf)

time 

(hrs)

10000 0.24 20 60 500 = 144.64 mcf

13.1 80% 950 1000 year

 144.64 mcf/yr 5005.7 724,006.43 mcf/yr

shops needing a booth

Nat Gas