p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

16) ll-J-7 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 16 of 36 
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MILES 

^FIBERGLASS 

C COMPOSITES 

January 6, 2000 

JAN 1 9 2001 

EPA AIR DOCKET 

Mr. Keith Barnett 

USEPA 

MD-13 

RTP,NC 27711 

Dear Keith, 

Miles Fiberglass & Composites is a small family owned business located in two facilities 

in the Portland, Oregon metropolitan area. We have been in the composites business for 

37 years. As a custom molder, we build a large variety of products for very diverse 

applications. As an example, we build platforms for hauling automobiles on railroad cars 

that measure 10 feet by 30 feet long. We make sidewalls for motorhomes that are 8'/feet 

by 40' feet long. We also build smaller parts that are less than one square foot. 

Because ofthe shape and size ofthe products we build and the configuration ofour 

buildings, we must move our resin application equipment to the mold site rather than 

move the molds to the equipment. This process results in the total building being the 

emission site and precludes us from constructing any kind ofa spray or lay-up booth 

system. Control and collection in this situation is basically impossible. We also have 

large overhead doors that are continually being opened and shut. This also interrupts any 

consistent airflow. Overhead cranes are used to pick up large parts and transport them 

out of doors to flatbed trucks waiting for transport. I believe that even with complicated 

ducting systems it would be impossible to capture and control our emissions with any 

efficiency what so ever. 

Another problem we have with the MACT proposal is the MACT floors. The floors for 

the resin are basically "one-size fits all". We use different resin for different applications. 

For instance, the sidewall products that we manufacture are used in extreme temperature 

and stress conditions. We have developed resin and lamination requirements over the 

past 17 years that have proven to be reliable and enduring. EPA's current floors would 

not allow us to continue using these resins. The process for achieving these results have 

been costly and long term, through trial and error and testing and failures in the field. To 

fix a failure in the product after it has been installed on a motorhome is a $10,000 

proposition. With an exposure of hundreds of walls per year, material failure would have 

Corporate & Portland Location: 

8855 SE Otty Rd., Portland, OR 97266 

Fax (503) 774-2561 • Phone (503) 775-7755 

Web: www.milesfiberglass.com 

Oregon City Location: 

1516 Main St., Oregon City, OR 970<15 

Fax (503) 656-3176 • Phone (503) 657-83-15 

Email: mfc@milesfiberglass.com 
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Page 2 

January 6, 2000 

catastrophic financial consequences to our company. We can not entertain changing the 

resin for motorhome sidewalls. 

There may be low HAP resins available that will meet or exceed our requirements for 

heat and stability, but the costs are so extremely high that our customers say they could or 

would go to other materials such as stainless steel or aluminum. I have contacted our 

suppliers which represents three manufacturers that supply vinylester resins. They do 

have vinylester resins they think would be adequate for our applications on sidewalls. 

The cost ofthe vinylester is a problem. We currently pay $ .86 per pound for ISO resin 

and our supplier, Composites One, 1-800-255-6006, Bill Barnes, tells me the best price 

for vinylester for our application would be $1.71 per pound or an $ .85 difference in cost. 

That would be almost 100% increase in the material cost. At a production rate of 100 

walls per week and a conservative estimate of $166.41 increase in wall material cost, we 

would increase our wall resin cost by $735,488 per year. Another problem with 

vinylester is that our experience shows that it takes longer to cure and therefore decreases 

the production rate. Reduction in production rates increases costs. 

Another issue is using low HAP gel coats as a method to comply with MACT. I 

understand that some gel coat suppliers are stating publicly that they have low HAP gel 

coats readily available and they will work for most applications. Unfortunately that has 

not been our experience. We have tried low HAP gel coats over the past few months and 

have had no success in getting them to work in our equipment. We ordered a new 

version two months ago to try but have not received the material yet. 

I don't believe a material should be included in a standard that is still in the development 

stages. I think a material should be in the public domain for at least two years and proven 

to work for the general population ofthe industry "to perform as advertised" before it is 

included in a regulation. 

Another problem area we have is with flow-coaters. I know flow-coaters have been 

around for close to two years, and in many cases have been made to work. The problem 

is that during the time they have been on the market they have continually been revised. I 

do believe they are improving, but our experience has been that they have progressed 

from not performing at all to working fairly well for most applications but not working at 

all for some applications. As one example, we cannot produce good quality molds 

(tooling) using flow-coaters. 

I'm not saying flow-coaters should not be in the MACT Standard but what I am saying is 

that it is recognized that they should not be considered as a total replacement for spray 

guns. 
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January 6, 2000 

The floors should be changed so that we can use ISO resins (including tooling) and 

atomized spray resin application where needed. The standard should also allow 

additional compliance options such as controlled spray. 

In summary, I believe our company, and for the most part the entire industry, wants to do 

whatever is possible to be good stewards for the environment. On the other hand, our 

resources are limited in terms of money and people. We not only have the Clean Air Act 

to contend with, but also the hazardous waste regulations, the fire regulations, OSHA, 

local building codes and many others that I won't get into now. 

We are willing to do whatever is necessary to comply with reasonable requirements that 

will make a difference in the environment. However, I hope the final outcome ofthe 

MACT Standard will not completely devastate our business and cost the livelihoods of 

some 100 families that are counting our company for a secure and comfortable living. 

Sincerely, 

Lowell H. Miles 

President 

^i^^i/^/j'/fit- h* 

LHM/jk 

Cc: John Schweitzer 

Gary Multanen