MEMORANDUM

SUBJECT:

NSPS Subpart EE Determination for Milton Steel

FROM:

John B. Rasnic, Director
Manufacturing, Energy, and Transportation Division
Office of Compliance

TO:

Elaine B. Wright, Director
Air, Radiation & Toxics Division
Region III

The following determination comes in response to your memorandum dated April 21, 1995. In your correspondence you ask whether the Milton Steel facility in Milton, Pennsylvania, should be regulated under New Source Performance Standards (NSPS) Subpart EE or under the State Implementation Plan (SIP) regulating miscellaneous metal parts. Having reviewed the information you provided, as well as other information defining pallet racks and metal furniture, NSPS Subpart EE applies to the Milton Steel facility.

NSPS Subpart EE applies to the organic coating of metal furniture. Metal furniture operations are defined by the 1987 Standard Industrial Classification (SIC) Manual. In SIC 2542 -- Office and Store Fixtures, Partitions, Shelving, and Lockers, Except Wood, the definition specifically includes pallet racks. In the document titled, Surface Coating of Metal Furniture - Background Information for Proposed Standards, EPA-450/3-80-007a, both metal partitions and metal storage racks are listed as metal furniture industry subgroups. In EPA-450/2-77-032, Control of Volatile Organic Emissions from Existing Stationary Sources Volume III: Surface Coating of Metal Furniture, the general discussion defines metal furniture to include, ". . .tables, chairs, waste baskets, beds, desks, locker, benches, shelving, file cabinets, lamps, room dividers and many other similar products. (emphasis added)

The above information indicates Milton Steels dip tanks used to coat pallet racks must meet NSPS Subpart EE. EPA Region IV came to the same conclusion with a similar facility that produces pallet racks. Region IV sent to you on May 2, a copy of their determination regarding the applicability of Subpart EE to pallet rack facilities.

If you have any questions regarding this determination, please contact me at (202) 564-2300 or Greg Waldrip of my staff at (202) 564-7024.

cc: Mamie Miller
Greg Waldrip
David McGuigan, Region III
Perry Pandya, Region III
David Savage, Region IV