Surface Coating of Miscellaneous Metal Parts
and Products:
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NESHAP/MACT Rule Site
Considerations
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Sources
- US EPA Documents I, II, III
Metal Painting and Coating Pollution Prevention Notebook
 A
wide variety of metal parts and products are coated for decorative
or protective purposes. These are used by hundreds of small industrial
categories that include large farm machinery and small appliances.
Some facilities manufacture and coat metal parts and then assemble
them to form a final product to be sold directly for retail. Others,
often called "job shops," manufacture and coat products
under contract with specifications differing from product to product.
The metal parts are then shipped to the final product manufacturer
to be assembled with other parts into some final product. Such facilities
are often located in the vicinity of the manufacturers for whom
they perform this service.
 The MMPP Surface Coating source category encompasses all industries
that coat metal parts and products, but are not subject to other
surface coating regulations. The Miscellaneous Metal Parts and Products
source category includes thousands of small, medium, and large size
facilities that apply coatings to a metal substrate to produce a
wide range of parts and products. Coating is defined as a protective,
decorative, or functional film applied as a thin layer to a substrate
or surface which cures to form a continuous solid film. In general,
this source category is broad and includes all those metal parts
and products that are not covered by another coating source category.
The MMPP source category comprises numerous diverse operations
that apply surface coatings to many products including (but not
limited to):
railroad cars, medical equipment, electronic equipment,
wheelbarrows, magnet wire, heavy duty trucks, hardware, power tools,
pipes, structural steel, sporting goods, lawn mowers, bicycles,
auto parts, musical instruments, steel drums, army tanks, and industrial
machinery.
 The MMPP category is truly a “catch-all” source category.
Although the industries in this category generally fall into Standard
Industrial Classification (SIC) codes 33 through 39, applicability
cannot be stated in terms of SIC codes, since SIC codes do not identify
which facilities perform surface coating. In addition, other coating
MACT source categories (e.g., large appliances, metal furniture,
metal cans, metal coils, etc.) may cover portions of many of the
same SIC categories, overlapping with MMPP. To complicate matters
further, a wide variety of coating technologies and application
methods are employed across all these industry segments. Nationwide,
there are thousands of facilities involved in coating of MMPP, with
an estimated 1500 or more being classified as major sources and
are subject to the MMPP MACT rule.
 Add-on controls are relatively rare in the MMPP category. It was
anticipated that reduction of emissions of hazardous air pollutants
(HAP) would be achieved primarily through the use of low-HAP materials.
The size of each facility is dependent on things such as the number
of coating lines, size of parts or products coated, type of coating
operation (i.e., spray, dip, flow, or roll coat), and number of
coats of paint applied.
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