(a copy of the draft FESOP is attached as Exhibit A)
4.
Two special conditions were included in the FESOP based on the Agency’s
incorrect conclusion that NACME engaged in metal coil surface coating operations because itapplies rust preventative oil to some steel coils pickled at its Facility prior to shipment tocustomers.
NACME pointed out that its Facility does not engage in either prime coating or finish coating
operations within the meaning of the Metal Coating standard and, as such, was not subject to thestandard.
The EPA AD does
not address at all the issue of what constitutes a coating operation within the mean...
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