On an inspection conducted on June 26, 2002, U.S. EPA observed Trelleborg Wheel Systems applying extreme performance coatings on miscellaneous metal parts coating lines with a VOC content in excess of 3.5 lbs/gal. Information obtained via Section 114 Request has shown that this practice has occurred since October 1997. This is in violation of OAC 3745-21-09(U) (SIP Rule 09(U)), Ohio SIP emission limits for miscellaneous metal parts and products coating lines. U.S. EPA issued NOVs on September 26, 2002 and May 23, 2003 for these violations.
While the applicability of SIP Rule 09(U) to Trelleborg Wheel Systems� coating lines seems clear, documents suggest that the Ohio Environmental Protection Agency (OEPA) and the Akron Air Quality Management District (Akron AQMD)determined that Trelleborg Wheel Systems did not need to comply with this rule. As a result, EPA decided not to issue a penalty to Trelleborg for these violations.
In addition, the OEPA�s current PTIs for all three of Trelleborg�s coating lines contain state-enforceable provisions that prohibit switching to coatings which would result in the increase in emissions of any HAP. The only coating that Trelleborg has identified that it can use on its main production line, K011, and that complies with SIP Rule 09(U) would result in an increase in the emission rate of perchloroethylene, a HAP. As explained more fully below, the OEPA has issued a draft revised PTI for public comment that covers all three lines