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Title: NSPS FOR SURFACE COATING OF METAL FURNITURE

Recipient: WITKOPP, BEN, DELL ENGINEERING

Author: KERTCHER, LARRY F., AIR COMPLIANCE BRANCH, REGION V

Date: 09/13/88

Subparts: EE

References: 60.310


Are contact adhesives subject to Subpart EE?

Contact adhesives are not considered surface coatings and therefore are not subject to Subpart EE. Surface coating operations regulated by Subpart EE are defined as operations applying prime, base or clear coats. Hardboard panels are also not subject to Subpart EE.


September 13, 1988

Mr. Ben Witkopp

Dell Engineering, Inc.

245 East Lakewood Blvd.

Holland, Michigan 49424­2066

Dear Mr. Witkopp:

I am writing in response to your request for interpretation of the New Source Performance Standard, Subpart EE ­ Standards of Performance for Surface Coating of Metal Furniture. Specifically youve asked the following questions:

1. Will a company using contact adhesives to bond the components of office partition panels be subject to Subpart EE.

2. If the use of hardboard panel falls within the same regulations.

With regard to question 1, the U.S. Environmental Protection Agencys (U.S. EPA) position is that contact adhesives are not considered surface coatings and therefore not subject to subpart EE. It is U.S. EPAs interpretation that surface coating operations regulated by Subpart EE are defined as operations applying prime, base or clear coats.

As to your second question, the use of hardboard panel will not make the above operation subject to Subpart EE since it is intended only to regulate the surface coating of metal furniture.

You are also reminded that even though the application of contact adhesives is not subject to NSPS Subpart EE, all other State and local environmental regulations must be complied with. You should verify the applicable regulations with the Michigan Department of Natural Resources.

If you have any questions or comments please contact Spiros Bourgikos of my staff at (312) 886­6862.

Sincerely yours,

(signed)

Larry F. Kertcher, Chief

Air Compliance Branch (5AC­26)




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