p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

32) ll-J-23 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:40:24 AM Sheet 32 of 36 
P.2 

Prom: KEITH BARNETT 

^ j-a a 

To: RTPMAINHUB.Internet. "Peter_D._Eglinton@omb.eop.gov. . . 

Date: 4/4/00 1:22pm 

Subject: Data for Reinforced Plastics 

Attached is the revised cost chapter. Most of the information in this chapter 

has already been transmitted. However, this revised chapter provides some 

additional explanation of some of he costing assumptions, and is more clearly 

laid out than the previous information. I believe this additional explanation 

will address the questions that were raised on costing issues. The appendices 

have been mailed to Jennifer Greenamoyer. 

Note that we still consider this cost chapter a draft. 

I also am attaching the draft source category description chapter. This 

document was not on the list we agreed to send, but I think it will be useful. 

Note that this is also still in draft form. 

Keith Barnett 

CC: ALDRIDGE-AMANDA, LASSITER-PENNY, RTPMAINHUB.INTERN... 

9?mi 

EPA AIR norxi 
P.3 

TABLE OF CONTENTS 

Page 

6.0 COST IMPACTS OF THE PROPOSED MACT STANDARD 6-1 

6.1 INTRODUCTION 6-1 

6.2 BASIC STEPS IN THE COST ANALYSES 6-2 

6.2.1 Basic Overview of Costing Analysis 6-2 

6.2.2 Selecting Control Techniques for Costing Analyses 6-2 

6.2.3 Selecting Type of Cost for Cost Components of 

Control Techniques 6-4 

6.2.4 Selecting Annualization Time Periods/Capitalization Factors .. . 6-10 

6.3 DEVELOPMENT OF COSTS FOR SPECIFIC CONTROL 

TECHNIQUES 6-12 

6.3.1 Low HAP Resins for Corrosion Resistant Applications 6-12 

6.3.2 Low HAP Resins for Non-Corrosion Resistant Applications ... . 6-16 

6.3.3 Low HAP Resins for Mold Manufacturing (Tooling) 6-17 

6.3.4 Low HAP Pigmented Production Gel Coats 6-18 

6.3.5 Low HAP Clear Production Gel Coats 6-22 

6.3.6 Low HAP Tooling Gel Coats 6-25 

6.3.7 Testing of New Low HAP Resins and Gel Coats 6-28 

6.3.8 Training to Use New Low HAP Resins and Gel Coats 6-29 

6.3.9 Recertification of Products 6-30 

6.3.10 Production Problem Costs Due to Switching to New Low 

HAP Resins and Gel Coats 6-31 

6.3.11 Long Term Increase in Labor Cost 6-31 

6.3.12 Equipment Change Costs 6-32 

6.3.13 Adoption of Non-Atomized Resin Application Equipment 6-32 

6.3.14 Uncovering only One Charge per Compression/Injection 

Molding Machine 6-37 

6.3.15 Wet Area Enclosures with Resin Drip Collection System 

For Pultrusion Operations 6-37 

6.3.16 Closed or Covered Doctor Boxes, Folded Edges, and Low 

Styrene Permeable Film for SMC Operations 6-39 

6.3.17 Non-HAP Cleaning Materials 6-40 

6.3.18 Closed/Covered Mixing with No Visible Gaps in Mixer Cover .. 6-41 

6.3.19 Wet Area Enclosures for Resin Wet Out Areas at Continuous 

Lamination and Casting Operations 6-43 

6.3.20 Permanent Total Enclosures (PTEs) 6-45 

6.3.21 Capture Devices for Centrifugal Casting Operations 6-49 
6.3.22 Duct Work from Wet Area Enclosures and Permanent Total 

Enclosures to Add-On Control Devices 6-52 

6.3.23 Add-on Control Device Costing 6-58 

6.3.24 Monitoring, Recordkeeping, and Reporting 6-62 

6.4 RESULTS OF THE COST IMPACTS ANALYSIS 6-67 

6.5 COST EFFECTIVENESS OF THE MACT FLOOR AND 

THE ABOVE-THE-FLOOR CONTROL OPTIONS 6-71 

6.6 REFERENCES 6-76 

APPENDICES 

6.1 Summary of Costing Components for Existing Continuous Lamination 

and Casting Sources 

6.2 Summary of Controls on Existing Continuous Lamination and Casting 

Sources to Meet the MACT Floor and Regulatory Alternatives for 

Existing and New Sources 

6.3 Corrosion-resistant Resins - Properties, Example Chemical Environments 

and Maximum Continuous Temperature Limits, and Cost Differentials 

6.4 Spray Gun and Flowcoater System Costs and Components 

6.5 Personal Protective Equipment Cost Comparison 

6.6 Wet Area Enclosure Costs for Continuous Lamination Sources 

6.7 Chapter 11, Permanent Total Enclosures, OAQPS Control Cost Manual, 

5th Edition, EPA 453/B-96-001, February 1996 

6.8 Chapter 10, Hoods, Ductwork, and Stacks, OAQPS Control Cost Manual, 

5th Edition, EPA 453/B-96-001, February 1996 

6.9 Duct Work for Continuous Lamination and Casting Sources for Existing 

and New Source MACT Floor and Regulatory Alternative 

6.10 Air Flows from Wet Area Enclosures, PTEs, and Ovens at Continuous 

Lamination and Casting Facilities 
P.5 

6.11 Duct Work Figures for Continuous Lamination and Casting Facilities 

6.12 Natural Gas and Electricity Costs 

6.13 An Assessment of Stvrene Emission Control Technologies for the FRP 

and Boat Building Industries. Mark Bahner, Emery Kong, and Sonji Tumer, 

Research Triangle Institute, and Assessment of Stvrene Emission Controls 

for FRP/C and Boat Building Industries. Final Report. (Chapter 5, Appendix A, 

and Appendix B). Emery J. Kong, Mark A. Bahner, and Sonji L.Turner 

Research Triangle Institute. 

6.14 Chemical Engineering Cost Indices 

in 
P.6 

LIST OF TABLES 

No. Title Page 

6-1 Basic Steps in the Costing Analyses for New and 

Existing Sources 6-3 

6-2 Control Techniques Selected for Existing Sources 6-5 

6-3 Control Techniques Selected for New Sources 6-7 

6-4 Type of Cost Associated with Control Techniques 

Cost Components 6-9 

6-5 Annualization Time Periods and Capitalization Factors 6-11 

6-6 Available Cost Information for Corrosion Resistant Resins Provided 

by Reichhold 6-13 

6-7 Average Cost Differential for Corrosion Resistant Resins 

at Different Specific Continuous Temperatures 6-15 

6-8 Available Cost Information for Tooling Resins from 

Resin Manufacturers 6-17 

6-9 Available Cost Information for Pigmented Production Gel 

Coats from Cook Composites and Polymers 6-19 

6-10 Available Cost Information for Clear Production Gel Coats 

from Gel Coat Manufacturers 6-23 

6-11 Available Cost Information for Tooling Gel Coats from 

Gel Coat Manufacturers 6-27 

6-12 Testing ofNew Low HAP Resins 6-28 

6-13 Training Costs to Use New Low HAP Resins 6-30 

6-14 Impact of Switching to Low HAP Resins on 

Production Efficiency 6-31 

6-15 Long-term Increase in Labor Cost 6-32 

iv 
P.7 

LIST OF TABLES 

(continued) 

No. Title Page 

6-16 Equipment Change Costs 6-32 

6-17 Cost Analysis Elements for Switching to Flowcoaters 6-34 

6-18 Available Cost Information for Wet Area Enclosures 6-38 

6-19 Cost Information for HAP- and non HAP- Containing 

Cleaning Solvents 6-40 

6-20 Available Cost Data for Closed/Covered Mixing 

with No Visible Gaps 6-41 

6-21 Per Mixer Compliance Cost Assigned to a Facility Based on 

Existing Level of Compliance 6-42 

6-22 Dimensions and Costs for Wet Out Area Enclosures for 

Continuous Lamination and Casting Operations 6-46 

6-23 Cost Information for Specific Equipment and Structural 

Components Used in Construction of the 

Permanent Total Enclosures 6-48 

6-24 Facility Criteria Used to Determine the Number and Size of 

Permanent Total Enclosures for Operations Other 

than Continuous Lamination and Casting 6-50 

6-25 Duct Work Cost Information and Design Equations 6-53 

6-26 Specific Equations for Rotary Concentrator/Thermal Oxidizer 

System Parameters and Costs 6-59 

6-27 MRR Information by Activity 6-63 

6-28 Wage Rates 6-66 

6-29 MACT Floor Costs for Existing Sources 6-68 

6-30 MACT Floor Costs for New Sources 6-68 
P.8 

LIST OF TABLES 

(concluded) 

No. Title Page 

6-31 Costs for the Above-the-floor Control Option Without the HAP 

Emission Size Limit for Existing Sources 6-69 

6-32 Costs for the Above-the-floor Control Option Without the HAP 

Emission Size Limit for New Sources 6-69 

6-33 Costs for the Above-the-floor Control Option With the HAP 

Emission Size Limit for Existing Sources 6-70 

6-34 Costs for the Above-the-floor Control Option With the HAP 

Emission Size Limit for New Sources 6-70 

6-35 Cost Effectiveness of the Above-the-Floor Control Option Without 

the HAP Emission Size Limit for Existing Sources 6-72 

6-36 Cost Effectiveness of the Above-the-Floor Control Option With 

the HAP Emission Size Limit for Existing Sources 6-73 

6-37 Cost Effectiveness of the Above-the-Floor Control Option Without 

the HAP Emission Size Limit for New Sources 6-74 

6-38 Cost Effectiveness of the Above-the-Floor Control Option With 

the HAP Emission Size Limit for New Sources 6-75 

vi 
P.9 

6.0 COST IMPACTS OF THE PROPOSED MAC T STANDARD 

6.1 INTRODUCTION 

This chapter presents information describing the estimated cost impacts of potential 

MACT standards on the Reinforced Plastic Composites source category and the methodology 

used to estimate these cost impacts. The information presented includes cost data collected by 

the EPA, the basic steps and assumptions used in the costing analyses, the detailed procedures 

and assumptions used to estimate the costs for specific control techniques, the results of the cost 

impact analyses, and the cost effectiveness of above-the-floor control options. 

We calculated capital and annual costs for each existing and projcted new facility for two 

levels of control.. These are the MACT floor level, which is the minimum level of control 

required by law, and a more stringent level of control. The more stringent level of control is 

called the above-the-floor control level. 

We also evaluared three regulatory alternatives. In Regulatory Alternative 1 all new and 

exisitng facilities are required to meet the floor level of control. In Regulatory Alternative 2 the 

above the floor control level is applied to all facilities with combined emissions of HAP of 100 

tons per year (TPY) or more from the following operations: open molding, centrifugal casting, 

continuous lamination/casting, pultrusion, SMC manufacturing, and BMC 

manufacturing/mixing. All other facilities must meet the floor level of control. In the third 

regulatory alternative all facilities regardless of size are required to meet the above-the-floor 

control level. 

The cost results presented here were also used as inputs to the economic analyses presented 

in Chapter 7. 

6-1 
P.10 

6.2 BASIC STEPS IN THE COST ANALYSES 

6.2.1 Basic Overview of Costing Analyses 

The costing analyses used by the EPA are designed to determine the total capital and 

annual costs that will be incurred by facilities in the reinforced plastic composites source 

category due to the proposed rule. We conducted the costing analyses for individual facilities for 

both existing and new sources at the MACT floor and the above-the-floor control options. The 

costing analyses consist of multiple steps, which are summarized in Table 6-1 for new and 

existing facilities. Section 6.3 discusses these steps in more detail. 

6.2.2 Selecting Control Techniques for Costing Analyses 

The first step in the costing analyses is determining the specific control techniques 

required for each operation and/or group of operations to achieve the level of control specified by 

the MACT floor and the above-the-floor control options. For certain operations and/or group of 

operations, there are multiple control techniques available that are capable of providing the 

required level of control. For example, vacuum bagging, vapor suppressants, low HAP 

materials, adoption of non-atomized resin application equipment, and add-on control devices are 

all control techniques that provide the required level of control for the unfilled non-corrosion 

resistant mechanical resin application operations at the existing source to meet the MACT floor. 

For those operations or group of operations where multiple control techniques were 

available, we selected the control technique that would be the least expensive for the majority of 

facilities for the cost analysis. For example, for unfilled non-corrosion resistant mechanical resin 

application operations required to meet the existing source MACT floor, we selected nonatomized resin application equipment (followed by replacement of high HAP resins with low 

HAP resins if necessary) as the least expensive compliance option for the majority of facilities. 

We assumed add-on control devices are more expensive than non-atomized resin application 

equipment and low HAP resins in all cases. We did not select vacuum bagging or vapor 

suppressants as potential control techniques because we had no cost data and the ability to apply 

these techniques is very site specific. 

6-2 
p.11 

TABLE 6-1. BASIC STEPS IN THE COSTING ANALYSES FOR 

NEW AND EXISTING SOURCES 

Basic Steps in the Costing Analysis for Existing Sources Basic Steps in the Costing Analysis for New Sources 

For each operation and/or group of operations, the control technique(s) that were used in the costing analyses were selected. 

The cost component(s) associated with each ofthe selected control technique(s) were determined. 

The type(s) of cost (total capital cost, annual variable cost, annual fixed cost) to associate with each cost component were determined. 

The time periods and capitalization factors used in annualizing total capital costs were selected. 

The total capital cost (TCC) associated with each cost component of each selected control technique was calculated. 

The annual variable cost (ACV) associated with each cost component of each selected control technique was calculated. 

The annual fixed cost (AFC) associated with each cost component of each selected control technique was calculated. 

The TCC for each cost component of each control technique were summed to obtain the total TCC. 

The ACV for each cost component of each control technique were summed to obtain the total ACV. 

The AFC for each cost component of each control technique were summed to obtain the total AFC. 

The total TCC, AVC and AFC from each control level were divided (pro-rated) between applicable operations using uncontrolled pre-MACT 

HAP emissions. 

The total TCC, AVC and AFC for each operation were determined by summing the pro-rated TCC, AVC and AFC from each applicable 

control technique. 

The total TCC, AVC and AFC for each operation (in terms of dollars 

per ton of resin or dollars per ton of gel coat) was determined for each 

existing facility (serving as a surrogate for each projected new growth 

facility) by dividing the total TCC, AVC and AFC for each operation 

by the resin and gel coat usage ofthe existing facility. 

The average cost per ton of resin or per ton of gel coat for each 

operation at each projected new growth facility was determined by 

averaging the dollars per ton or resin or dollars per ton of gel coat for 

each operation for the group of existing facilities serving as surrogates 

for each operation at the projected new growth facility. 

The total TCC, AVC, and AFC for each operation for each projected 

new growth facility was detennined by multiplying the average cost 

per ton or resin or per ton of gel coat for each operation used by each 

projected new growth facility by the projected resin or gel coat usage 

in each operation for the projected new growth facility. 

The total TCC, AVC and AFC for each operation grouping were determined by summing the TCC, AVC and AFC from each operation. 

The total TCC, AVC and AFC for each facility were determined by summing the TCC, AVC and AFC from each grouping. 

The total TCC, AVC and AFC for the source category were determined by summing the TCC, AVC and AFC. 

6-3 
P.12 

We used a thermal oxidizer with rotary concentrator for the operations and/or groups of 

operations where an add-on control device was the control technique selected to provide the 

required level of control. Where we costed thermal oxidizers/rotary concentrators, we costed the 

thermal oxidizer/concentrator based on the facility using its current resins and gel coats (i.e., we 

did not cost switching to lower HAP resins and/or gel coats). 

For facilities with multiple operations,'we costed one add-on control device for the entire 

facility and then apportioned the costs for that device among each operation based on the relative 

contribution of each operation to the HAP emissions upstream of the control device. Tables 6-2 

and 6-3 summarize by operation and/or group of operations the control techniques selected for 

existing and new sources, respectively. Appendices 6.1 and 6.2 provide additional information 

concerning the control techniques selected for continuous lamination/casting. 

6.2.3 Selecting Tvpe of Cost for Cost Components of Control Techniques 

Total capital and annual cost of a control technique are made up of various components. 

Not all of these components are applicable to each technique. Table 6-4 lists these components, 

and identifies the components applicable to each individual control technique. 

The total capital cost (TCC) represents the cost of equipment purchased by a facility to apply 

a control technique. Examples of total capital costs are the purchase of non-atomized resin 

application equipment, the purchase of a permanent total enclosure (PTE), the purchase of duct 

work connecting a PTE to an add-on control device, and the purchase of an add-on control 

device. Total capital costs are annualized to obtain fixed annual costs for the purpose of 

calculating the total annual costs associated with a control level. 

In certain cases, a facility will incur costs that occur during the 1st year of compliance 

with the proposed rule, such as product recertification costs, new materials testing costs, and 

certain monitoring, reporting, and recordkeeping costs. These costs are not total capital costs in 

the sense that these costs do not represent the purchase price of equipment. However, these costs 

are included in TCC and are annualized to obtain fixed annual costs using the same calculation 

methods as total capital costs for the purpose of calculating the total annual costs associated with 

a control level. 

6-4 
TABLE 6-2. CONTROL TECHNIQUES SELECTED FOR EXISTING SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Operation 

Manual Resin - Non CR 

Manual Resin - CR 

Manual Resin - Tooling 

Mechanical Resin - Non CR -

Unfilled 

Mechanical Resin - Non CR -

Filled 

Mechanical Resin - CR 

Mechanical Resin - Tooling 

Filament Winding - Non CR 

Filament Winding - CR 

Pigmented Production Gel 

Coat 

Clear Production Gel Coat 

Tooling Gel Coat 

Compression/Injection (C/I) 

Molding 

Resin Transfer Molding 

Control Level Required by 

Existing Source MACT Floor 

76 lbs / ton 

124 lbs/ton 

97 lbs / ton 

104 lbs/ton 

144 lbs/ton 

190 lbs/ton 

256 lbs / ton 

173 lbs/ton 

163 lbs/ton 

265 lbs / ton 

504 lbs / ton 

394 lbs / ton 

Uncover/Unwrap/Expose Only 

1 Charge per C/I Molding 

None (No MACT Floor) 

Control Techniques Selected for 

Complying with the MACT Floor 

Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Resin 

Non-Atomized Application 

& Low HAP Content Resin 

Low HAP Content Resin 

Non-Atomized Application 

& Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Gel Coat 

Low HAP Content Gel Coat 

Low HAP Content Gel Coat 

Uncover/Unwrap/Expose Only 1 

Charge per C/I Molding Machine 

None (No MACT Floor) 

Control Level Required 

by the Above-the-Floor 

Control Option 

Entire Group of Operations 

95.0% Control Efficiency 

Uncover/Unwrap/Expose Only 

1 Charge per C/I Molding 

None (No MACT Floor) 

Control Technique(s) Selected 

for Complying with the Abovethe-Floor Control Option 

Entire Group of Operations 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Uncover/Unwrap/Expose Only 1 

Charge per C/I Molding Machine 

None (No MACT Floor) 

6-5 
TABLE 6-2. CONTROL TECHNIQUES SELECTED FOR EXISTING SOURCES 

(concluded) 

Group of Operations 

Centrifugal Casting 

Continuous Lamination/ 

Continuous Casting 

Pultrusion 

Polymer Casting 

SMC Manufacturing 

BMC Manufacturing/ 

Mixing 

Equipment Cleaning 

Storage of HAP 

Containing Materials 

Operation 

Centrifugal Casting - Non CR 

Centrifugal Casting - CR 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Control Level Required by 

Existing Source MACT Floor 

396 lbs / ton 

536 lbs / ton 

58.5% Control Efficiency or 

15.7 lbs/ton 

60.0% Control Efficiency 

None (No MACT Floor) 

Closed/Covered Doctor Box / 

Folded Edges/Nylon Him 

Closed/Covered Mixing w/ 

No Visible Gaps in Cover 

No HAP Cleaning Solvents 

Closed or Covered Storage 

Containers 

Control Techniques Selected for 

Complying with the MACT Floor 

Low HAP Content Resin 

Low HAP Content Resin 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Wet Area Enclosures w/ 

Resin Drip Collection 

None (No MACT Floor) 

Closed/Covered Doctor Box / 

Folded Edges/Nylon Film 

Closed/Covered Mixing w/ 

No Visible Gaps in Cover 

Acetone 

Closed or Covered Storage 

Containers 

Control Level Required 

by the Above-the-Floor 

Control Option 

Entire Group of Operations 

95.0% Control Efficiency 

95.0% Control Efficiency or 

1.4 lbs / ton 

95.0% Control Efficiency 

None (No MACT Floor) 

95.0% Control Efficiency 

95.0% Control Efficiency 

No HAP Cleaning Solvents 

Closed or Covered Storage 

Containers 

Control Technique(s) Selected 

for Complying with the Abovethe-Floor Control Option 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

None (No MACT Floor) 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Acetone 

Closed or Covered Storage 

Containers 

NOTE 1: The above-the-floor control options considered for existing sources generally require control levels more stringent than the control levels required by the existing source MACT floor. 

NOTE 2: In cases where add-on control devices were required for more than one operation and/or group of operations at a facility, only one add-on control device was costed for the facility and the 

costs associated with that add-on control device were assigned to each operation and/or group of operations based on the magnitude of uncontrolled HAP emitted by each operation and/or group of 

operations. 

6-6 
TABLE 6-3. CONTROL TECHNIQUES SELECTED FOR NEW SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Operation 

Manual Resin - Non CR 

Manual Resin - CR 

Manual Resin - Tooling 

Mechanical Resin - Non CR -

Unfilled 

Mechanical Resin - Non CR -

Filled 

Mechanical Resin - CR 

Mechanical Resin - Tooling 

Filament Winding - Non CR 

Filament Winding - CR 

Pigmented Production Gel 

Coat 

Clear Production Gel Coat 

Tooling Gel Coat 

Compression/Injection (C/O 

Molding 

Resin Transfer Molding 

Centrifugal Casting - Non CR 

Control Level Required by 

New Source MACT Floor 

50 lbs / ton 

85 lbs / ton 

72 lbs / ton 

22 lbs / ton 

12 lbs/ton 

120 lbs/ton 

205 lbs / ton 

113 lbs/ton 

144 lbs /ton 

19 lbs/ton 

429 lbs / ton 

29 lbs / ton 

Uncover/Unwrap/Expose Only 

1 Charge per C/I Molding 

None (No MACT Floor) 

391 lbs/ton 

Control Technique Selected 

for Complying with the MACT 

Floor 

Add-On Control Device (95.0%) 

Low HAP Content Resin 

Low HAP Content Resin 

Add-On Control Device (95.0%) 

Add-On Control Device (95.0%) 

Non-Atomized Application 

& Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Resin 

Low HAP Content Resin 

Add-On Control Device (95.0%) 

Low HAP Content Gel Coat 

Add-On Control Device (95.0%) 

Uncover/Unwrap/Expose Only 1 

Charge per C/I Molding Machine 

None (No MACT Floor) 

Low HAP Content Resin 

Control Level Required 

by the Above-the-Floor 

Control Option 

Entire Group of Operations 

95.0% Control Efficiency 

Uncover/Unwrap/Expose Only 

I Charge per C/I Molding 

None (No MACT Floor) 

Entire Group of Operations 

VD.U%I control tniciency 

Control Technique (s)Selected 

for Complying with the Abovethe-Floor Control Option 

Entire Group of Operations 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Uncover/Unwrap/Expose Only 1 

Charge per C/I Molding Machine 

None (No MACT Floor) 

Add-on Control Device: Thermal 

uxiaizer w/ Kotary concentrator 

6-7 
TABLE 6-3. CONTROL TECHNIQUES SELECTED FOR NEW SOURCES 

(concluded) 

Group of Operations 

Continuous Lamination/ 

Continuous Casting 

Pultrusion 

Polymer Casting 

SMC Manufacturing 

BMC Manufacturing/ 

Mixing 

Equipment Cleaning 

Storage of HAP 

Containing Materials 

Operation 

Centrifugal Casting - CR 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Control Level Required by 

New Source MACT Floor 

26 lbs / ton 

82.6% Control Efficiency or 

5.7 lb/ton 

95.0% Control Efficiency 

None (No MACT Floor) 

95.0% Control Efficiency 

95.0% Control Efficiency 

No HAP Cleaning Solvents 

Closed/Covered Storage 

Containers 

Control Technique Selected 

for Complying with the MACT 

Floor 

Low HAP Content Resin 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

None (No MACT Floor) 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Acetone 

Closed/Covered Storage 

Containers 

Control Level Required 

by the Above-the-Floor 

Control Option 

95.0% Control Efficiency or 

1.4 lb / ton 

95.0% Control Efficiency 

None (No MACT Floor) 

95.0% Control Efficiency 

95.0% Control Efficiency 

No HAP Cleaning Solvents 

Closed/Covered Storage 

Containers 

Control Technique (s)Selected 

for Complying with the Abovethe-Floor Control Option 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

None (No MACT Floor) 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Add-on Control Device: Thermal 

Oxidizer w/ Rotary Concentrator 

Acetone 

Closed/Covered Storage 

Containers 

NOTE 1: The above-the-floor control options considered for new sources generally require control levels more stringent than required by the control levels 

required by the new source MACT floor. 

NOTE 2: In cases where add-on control devices were required for more than one operation and/or group of operations at a facility, only one add-on control 

device was costed for the facility and the costs associated with that add-on control device were assigned to each operation and/or group of operations based on 

the magnitude of uncontrolled HAP emitted by each operation and/or group of operations. 

6-8 
P.17 

TABLE 6-4. TYPE OF COST ASSOCIATED WITH CONTROL TECHNIQUE COST 

COMPONENTS

 a 

Add-On Control Devices w/ Associated Equipment 

- Total Capital Cost - Add-On Control Device 

- Total Capital Cost - Permanent Total Enclosure (PTE) 

- Total Capital Cost - Wet Out Area Enclosure (WAE) 

- Total Capital Cost - Capture Device (CD) for Centrifugal Casting Machines 

- Total Capital Cost - Ductwork from PTE, CD, or WAE to Add-On 

- Direct Operating Cost Minus Utilities - Add-On Control Device 

- Electricity Costs - Add-On Control Device/Ductwork 

- Fuel Costs - Add-On Control Device 

- Overhead, Property Tax, Insurance Administration 

TCC 

X 

X 

X 

X 

X 

AVC 

X 

X 

X 

AFC 

X 

X 

X 

X 

X 

X 

Resin Bath Wet Area Enclosure / Resin Drip Collection System 

- Total Capital Cost - Wet Area Enclosure / Resin Drip Collection System 

- Operating & Maintenance (0 & M) 

X 

X 

X 

Closed/Covered Mixing 

- Cost of Mixer Covers Replaced Annually X 

Replacement of Spray Equipment w/ Flowcoater 

- Total Capital Cost - Flowcoater / Salvage Value Spray Guns 

- Decrease in Personal Protective Equipment Usage 

- Decrease in Floor Coverings Usage 

- Decreased Resin Usage Due to Increased Transfer Efficiency 

X 

X 

X 

X 

X 

Materials Replacement 

- Replacement of Existing Resin with Low HAP Resin 

- Replacement of Existing Gel Coat with Low HAP Gel Coat 

- Product Recertification (Resin and Gel Coat) 

- New Material Testing 

X 

X 

X 

X 

X 

X 

Monitoring, Record keeping, & Reporting 

- Subpart A Notifications (Year 1) - Construct/Reconstruct, Anticipated Start-

- Semi-Annual Report, Periods of Non-Compliance Report, Maintain HAP 

- Develop Training Program / Records System (Year 1) 

- Conduct Training Program / Keep Training Records 

- Reading Standard (Year 1) 

- Reviewing Standard (Annually) 

- Performance Tests, Develop O&M Plan, SS&M Plan (Year 1) 

- Semi-Annual Start-up, Shut-Down & Malfunction (SS&M) Report 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

TCC = Total Capital Cost, AVC = Annual Variable Cost, AFC = Annual Fixed Cost 

6-9 
P.18 

The annual variable costs (AVC) of a cost component are costs that will vary from year to 

year based on production and emission variations at a facility. An example of a production based 

annual variable cost is the variation in the annual cost of using low HAP material replacements 

due to annual variations in the amount of raw materials used by a facility. An example of an 

emissions based annual variable cost is the variation in electricity and fuel costs of an add-on 

control device that occur due to variations in the flow rate and HAP concentration of the 

emission stream being sent to the add-on control device. 

The annual fixed costs (AFC) of a cost component are costs that remain fixed from year 

to year. These costs are primarily annualized total capital costs although certain pieces of 

equipment replaced annually and certain types of monitoring, recordkeeping, and reporting costs 

are also annual fixed costs. For example, the annual replacement of mixer covers is an annual 

fixed cost that is not obtained by annualizing a total capital cost. 

6.2.4 Selecting Annualization Time Periods / Capitalization Factors 

The cost components for a number of compliance options include TCC that must be 

annualized into annual fixed costs (AFC). In order to annualize a total capital cost, an 

annualization period and interest rate for each cost component must be determined. The 

annualization period and interest rate are used to generate a capitalization factor for each cost 

component. The capitalization factor is multiplied by the. total capital cost to obtain the annual 

fixed cost. 

Table 6-5 summarizes the annualization periods and capitalization factors for each cost 

component. For cost components based on equipment, we selected the annualization periods 

based on the expected life of the equipment. For the cost components identified as materials 

replacement and monitoring, recordkeeping and reporting, we used an annualization period of ten 

years. We used an annual interest rate of seven percent for all cost components. 

6-10 
P.19 

TABLE 6-5. ANNUALIZATION TME PERIODS AND CAPITALIZATION FACTORS • 

Add-On Control Devices w/ Associated Equipment 

- Add-On Control Device 

- Permanent Total Enclosure (PTE) 

- Wet Out Area Enclosure (WAE) 

- Capture Device (CD) for Centrifugal Casting Machines 

- Ductwork from PTE, WAE or CD to Add-On Control Device 

Time Period 

(years) 

10 

30 

30 

10 

10 

Capitalization 

Factor 

0.1424 

0.0806 

0.0806 

0.1424 

0.1424 

Resin Bath Wet Are Enclosure / Resin Drip Collection System 

- Resin Bath Wet Area Enclosure / Resin Drip Collection System 30 0.0806 

Replacement of Sprav Equipment w/ Flowcoater 

- Flowcoater / Salvage Value Spray Guns 7 0.1856 

Materials Replacement 

- Product Recertification 

- Product Testing 

10 

10 

0.1424 

0.1424 

Monitoring, Record keeping, & Reporting 

- Subpart A Notifications (Year 1) - Construct/Reconstruct, Anticipated 

StartUp, Actual Startup, Notice of Compliance Status 

- Develop Training Program / Records System (Year 1) 

- Reading Standard (Year 1) 

- Performance Tests, Develop O&M Plan, SS&M Plan (Year 1) 

10 

10 

10 

10 

0.1424 

0.1424 

0.1424 

0.1424 

a

 Capitalization factors for each cost component are based on the annualization period shown in the table and an 

annual interest rate of 7.0%. 

6-11 
P.20 

6.3 DEVELOPMENT OF COSTS FOR SPECIFIC CONTROL TECHNIQUES 

6.3.1 Low HAP Resins for Corrosion Resistant Applications ' " 

We determined the costs for the use of low HAP resins for corrosion resistant 

applications by (1) estimating a single average cost differential between high HAP and low HAP 

corrosion resistant resins and (2) applying the average cost differential to the quantity of high 

HAP corrosion resistant resin currently used at the facility, all of which would be replaced with a 

low HAP corrosion resistant resin. We applied this procedure to open molding and centrifugal 

casting corrosion resistant operations, except for open molding corrosion resistant operations 

where the use of flow-coater technology by itself allowed the open molding corrosion resistant 

operation to meet the MACT floor point value. 

We collected cost and/or physical properties information for thermoset resins designed 

specifically for corrosion resistant applications from five major resin manufacturers: Alpha 

Owens Corning (AOC), Ashland Chemical Company, Dow Chemical Company, Interplastic 

Corporation, and Reichhold. 

The cost differential associated with replacing a high HAP corrosion resistant resin with a 

low HAP corrosion resistant resin is primarily dependent on the chemical environment1 and the 

continuous operating temperature to which the cured resin is exposed and on the HAP content of 

the low HAP resin replacement. Therefore, we examined the available data to determine which 

data would best take into account the numerous chemical environments and operating 

temperatures to which the cured corrosion resistant resins are exposed and the available low HAP 

resin replacements, which must be capable of handling the same chemical environment at the 

same continuous temperature as the high HAP resin currently in use while not exceeding a 

certain level of HAP content. 

We determined that the Reichhold data were the most useful data provided to conduct the 

cost analysis. The data submitted contained cost, property, and resin applicability data on high 

1

 A "chemical environment" is a combination of a specific chemical at a specific concentration. 

The maximum continuous temperature limit for a specific chemical environment is the maximum 

temperature (based on testing conducted by the resin supplier) that a properly constructed plastic 

composite storage tank or type of process equipment can continuously handle (sustain) without 

experiencing structural failure. 

6-12 
P.21 

HAP isophthalic and/or bisphenol-A-fumarate resins and low HAP vinyl ester resins. 

Information on high and low HAP resin pairs is needed to determine the cost differential for 

switching to compliant resins. Based on information from companies that switched to lower 

HAP corrosion resistant resins, we assumed the replacement of a high HAP isophthalic or 

bisphenol-A-fumarate resin with a low HAP vinyl ester resin is the most likely resin replacement 

scenario. Reichhold was the only company that supplied data that could be used for this 

scenario. Therefore, we used the data from Reichhold (see Table 6-6) in calculating the cost 

differential. Table A6-4 in Appendix 6.3 summarizes the corrosion resistant properties of the 

Reichhold resins including the number of resins that could be used in a number of chemical 

environments at specific continuous operating temperatures. 

TABLE 6-6. AVAILABLE COST INFORMATION FOR CORROSION RESISTANT 

RESINS PROVIDED BY REICHHOLD 

Resin Product Number 

DION 9100 

DION 9300 

ATLAC 580 

DION 9480 

DION 9420 

DION 6694 

ATLAC 382 

ATLAC 4010 

DION 6631 

Resin Type 

Bisphenol - Epoxy - Vinyl Ester 

Bisphenol - Epoxy - Vinyl Ester 

Urethane - Vinyl Ester 

Novalac - Epoxy - Vinyl Ester 

Vinyl Ester (High Cross-link) 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Isophthalic 

HAP Content 

(% by wt.) 

43.5 

30.0 

46.0 

39.0 

34.5 

48.0 

50.0 

50.0 

48.0 

Sale Price 

($ / lb) 

$1,365 

$1,435 

$1,465 

$2,050 

$1,760 

$1,460 

$1,320 

$1,320 

$1,050 

a

 All sale prices are in 1998 dollars based on a shipment size of 80 drums and are for non-promoted resins. 

There are numerous different chemical environments and continuous operating 

temperatures to which cured corrosion resistant resins may be exposed. Therefore, we examined 

all chemical environments for which Reichhold provided data. Table A6-5 in Appendix 6.3 

provides examples of specific chemical environments and maximum continuous temperature . 

limits that were examined in the cost analysis. 

6-13 
P.22 

For the set of environments and operating temperatures identified in the information 

supplied by Reichhold, we calculated the actual cost differential associated with replacing each 

specific high HAP corrosion resistant resin by subtracting the price ofthe high HAP corrosion 

resistant resin from the price ofthe least expensive low HAP corrosion resistant resin 

replacement that is capable of handling the same chemical environment at the same continuous 

temperature as the high HAP resin currently in use while not exceeding a certain level of HAP 

content. (Table A6-6 in Appendix 6.3 provides actual cost differentials for the first four 

chemical environments listed in Table A6-5 in Appendix 6.3 at eight different continuous 

operating temperatures.) 

Next, we calculated the average cost differentials associated with replacing high HAP 

corrosion resistant resins with low HAP corrosion resistant resins for each maximum allowable 

HAP content range and specific continuous temperature. Table 6-7 summarizes the results of 

this analysis. The average cost differential for a maximum allowable HAP content range and 

specific continuous temperature is the average ofthe individual cost differentials determined for 

each chemical environment at that maximum allowable HAP content range and specific 

continuous temperature. 

The majority of facilities did not provide information on the actual corrosion resistant 

resins used by the facility. Therefore, we could not determine facility-specific cost differentials. 

Because of this, we selected a single average cost differential from Table 6-7 to apply to all 

facilities. The selected average cost differential is $0,455 per pound, which represents the 

highest average cost differential for the resin replacement options possible at a specific 

temperature and group of chemical environments. 

We calculated the cost to each individual facility by multiplying the selected average cost 

differential by the quantity of resin currently used in the applicable open molding and centrifugal 

casting corrosion resistant operations at that facility. We assumed that all of the corrosion 

resistant resin currently used in these operations at a facility would be replaced with a low HAP 

corrosion resistant resin. We made this assumption because (1) for many products, a facility will 

6-14 
TABLE 6-7. AVERAGE COST DIFFERENTIAL FOR CORROSION RESISTANT RESINS 

AT DIFFERENT SPECIFIC CONTINUOUS TEMPERATURES 

Pre-MACT Resin Cost 

and HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% by Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost 

and HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% by Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Average Cost Differential ($/lb) 

100 F 

0.240 

0.267 

0.205 

0.000 

120 F 

0.241 

0.262 

0.199 

0.000 

140 F 

0.242 

0.258 

0.195 

0.000 

160 F 

0.219 

0.234 

0.170 

0.000 

180 F 

0.125 

0.139 

0.076 

0.000 

200 F 

0.136 

0.146 

0.085 

0.000 

220 F 

0.275 

0.455 

0.453 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

The average cost differential is equal to the average final cost less the average initial cost. It is the average ofthe individual cost differentials at a specific continuous 

temperature. For example, the average cost of replacing the least expensive resin (with no HAP limit) that is capable of handling a chemical environment at 100 °F with the least 

expensive resin (maximum HAP = 35%) that is capable of handling a chemical environment at 100 °F is $0.24 / lb. 

6-15 
P.24 

want to use the same HAP-level resin to ensure product consistency, (2) using one type of resin 

will be easier for a facility to order and track, and (3) operators at a facility may find it easier to 

apply only one type of resin rather than switching between resins. In addition, this assumption 

(of replacing all pre-MACT resins) is conservative, because some facilities with distinct product 

lines may elect to switch only the resins used in some of their product lines in order to achieve 

compliance. 

6.3.2 Low HAP Resins for Non-Corrosion Resistant Applications

 12 

We determined the costs for the use of low HAP resins for non-corrosion resistant 

applications by (1) estimating a single average cost differential between high HAP and low HAP 

non-corrosion resistant resins and (2) applying the average cost differential to the quantity of 

high HAP non-corrosion resistant resin currently used at the facility, all of which would be 

replaced with a low HAP non-corrosion resistant resin. We applied this procedure to open 

molding and centrifugal casting non-corrosion resistant operations, except for open molding noncorrosion resistant operations where the use of flow-coater technology by itself allowed the open 

molding non-corrosion resistant operation to meet the MACT floor point value. 

As with corrosion resistant resins, there was very limited information on the actual resins 

used by facilities for non-corrosion resistant operations. Therefore, we used the average cost 

differential for all facilities. We obtained the average cost differential from the cost analysis 

developed for the boat manufacturing source category. The average cost differential we used was 

$0,055 per pound for facilities that replaced a high HAP polyester resin (>35% HAP by wt.) with 

a low HAP polyester resin (35% HAP by wt.). The average cost differential for the boat 

manufacturing source category for non-corrosion resistant resins was $0,077 per pound for 

facilities that replaced a high HAP vinyl ester resin (>35% HAP by wt.) with a low HAP vinyl 

ester resin (35% HAP by wt.). 

The average cost differential selected to represent the replacement of high HAP noncorrosion resistant resin with low HAP non-corrosion resistant resin was $0,055 per pound. We 

selected this average cost differential because facilities that use non-corrosion resistant resins in 

6-16 
P.25 

the plastic composites source category predominantly use polyester resins rather than vinyl ester 

resins. 

The cost differentials used in the boat manufacturing source category are based on the 

assumption that resins with 35% HAP by weight are adequate for compliance. The reinforced 

plastics source category has non-corrosion resistant operations that require resins with HAP 

contents less than 35% by weight for compliance. However, we assumed that the selected cost 

differential was still applicable. 

6.3.3 Low HAP Resins for Mold Manufacturing (Tooling) 

The use of tooling resin with respect to the use of production resin varies from facility to 

facility. Many facilities did not indicate tooling resin use in responding to the 1993 Information 

Collection Request (ICR) due to the typically small amounts of this material that a facility uses 

relative to its use of production materials. The tooling resin use data provided by Pillings F.R.P., 

Bremen Glass, and Custom Fiberglass Molding was reported to be 5.1, 0.3, and 1.2 percent of the 

production resin, respectively. These data average to about 2 pounds of tooling resin for every 

100 pounds of production resin. We used this ratio to calculate tooling resin usage. 

We collected cost and properties information on tooling resins from five (5) major resin 

manufacturers. Table 6-8 summarizes the available cost information submitted by these resin 

manufacturers. 

TABLE 6-8. AVAILABLE COST INFORMATION FOR TOOLING RESINS 

FROM RESIN MANUFACTURERS 

Resin Manufacturer 

Alpha-Owens Coming 

Ashland Chemical Company 

Cook Composites & Polymers 

Interplastic Corporation 

Interplastic Corporation 

Reichhold 

Resin Product Number 

80-6100 

AME 5000 

Stypol 040-4232 

MVR8031 

CORVE-Series Vinyl Ester 

Hydrex 33-250 

Resin Type 

DCPD-Vinyl Ester 

Vinyl Ester 

Isophthalic 

Vinyl Ester 

Vinyl Ester 

DCPD-Vinyl Ester 

HAP Content 

(% by wt.) 

35 

31 

41 

44.9 

47.5 

45 

Sale Price 

($ / lb) 

$0.85 

$1.46 

$1.08 

$1.51 

$1.66 

$1.53 

All sale prices are in 1998 dollars on a shipment size basis of drums. 

6-17 
P.26 

We calculated the average cost ofthe three "high" HAP vinyl ester resins (i.e., those with 

HAP contents equal to or greater than 44.9 percent by weight). The average cost for these three 

resins is approximately $1.57 per pound. We then compared this cost to the costs of the two 

"low" HAP vinyl ester resins. The average high HAP vinyl ester resin cost is higher than either 

of the two low HAP vinyl ester resins. Based on this, the use of low HAP vinyl ester tooling 

resins could result in a cost savings to the affected facilities. We could not make this comparison 

between high HAP and low HAP isophthalic tooling resins. Therefore, we assumed a zero cost 

for switching to low HAP tooling resins rather than a cost savings in order to make the cost 

estimate more conservative. 

6.3.4 Low HAP Pigmented Production Gel Coats

 1314 

We calculated the cost of converting to low HAP pigmented production gel coats by (1) 

determining the costs of low and high HAP pigmented production gel coats, (2) determining the 

amount and basic color type (white/off-white and bright) of pigmented production gel coat 

currently used at a facility (pre-MACT floor), (3) determining the amount and type (low and high 

HAP) of pigmented production gel coat in order to comply with the MACT floor (after MACT 

floor), and (4) applying the cost to the amount of low and high HAP pigmented production gel 

coat to determine facility costs pre-MACT floor and after MACT floor. 

We collected cost and properties information on pigmented production gel coats from two 

major gel coat manufacturers. In addition, we collected detailed pigmented gel coat usage data 

from some facilities in the MACT floor. Of the MACT floor facilities surveyed, five reported 

using Cook Composite pigmented gel coats and one of the five also reported using Neste 

pigmented gel coats. 

In developing cost estimates for high and low HAP pigmented production gel coats, it is 

necessary to identify "matched" pairs of gel coats; that is, match a high HAP pigmented gel coat 

with a low HAP pigmented gel coat that would replace the high HAP pigmented gel coat. Of the 

data supplied by the two gel coat manufacturers, only the Cook Composite data allowed us to 

identify matched pairs. Since more facilities use Cook Composite resins than Neste resins and 

only the Cook Composite data could be used to develop matched pairs, we used the Cook 

6-18 
P.27 

Composites data above in developing cost estimates for low and high HAP pigmented production 

gel coats. 

Table 6-9 presents the available cost data from Cook Composites for those pigmented gel 

coat lines (i.e., Polycor ISO standard, sanitary low VOC, Armorcote High Performance, and low 

VOC Armorcote) identified as being used by these five MACT floor facilities in the gel coat 

survey. 

TABLE 6-9. AVAILABLE COST INFORMATION FOR PIGMENTED PRODUCTION 

GEL COATS FROM COOK COMPOSITES AND POLYMERS 

Gel Coat Product Number 

944-POLYCOR ISO Standard 

951 -ARMORCOTE High Performance 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

944-POLYCOR ISO Standard 

951-ARMORCOTE 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

944-POLYCOR ISO Standard 

951-ARMORCOTE 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

Gel Coat Base Color 

White 

White 

White 

White 

Black 

Black 

Black 

Black 

Red 

Red 

Red 

Red 

HAP Contenta 

(% by wt.) 

36 

40 

29 

25 

40 

44 

31 

30 

38 

40 

30 

30 

L 1 

Sale Price 

($ / lb) 

$1.68 

$3.01 

$1.99 

$1.99 

$1.70 

$3.01 

$1.99 

$1.99 

$2.71 

$4.81 

$3.51 

$3.51 

HAP contents are shown to the number of decimal places reported by Cook Composites. 

All sales prices are in 1998 dollars and are on a drum size shipment basis. 

The first matched pair is the 944-Polycor ISO standard and the 962-Sanitary low VOC. 

The results of a detailed gel coat usage survey show that almost all of the surveyed facilities that 

use Cook Composites & Polymers gel coats use either the 944-POLYCOR gel coat or 962-

Sanitary Low VOC. Further, these two gel coats are used in producing the same basic products 

(bath). Therefore, we assumed that the 962-Sanitary low VOC gel coat would be a substitute 

wherever the 944-Polycor ISO standard gel coat is being used. The second matched pair appears 

6-19 
P.28 

to be the 951-Armorcote High Performance and the 961-Low VOC Armorcote gel coats. 

Although the low VOC gel coat appears to be a substitute for the 951 gel coat, it is unclear 

whether the low VOC Armorcote is also a "high performance" gel coat. However, because the 

amount of the Armorcote resin used appears to be so much lower relative to the Polycor ISO 

standard resin, we used the data of the Polycor ISO Standard/Sanitary low VOC pair to develop 

the cost estimate. 

In developing the cost estimate, we also considered the color of the gel coats. Color 

distribution is important because different color pigmented production gel coats have different 

prices and physical properties. Based on discussions with gel coat suppliers, there are three basic 

color groupings of pigmented gel coats, which are whites and off whites, black and dark colors, 

and bright colors, such as red. The cost information provided by Cook Composites listed prices 

for: (1) white gel coats, which are representative of white and off white gel coats, (2) black gel 

coats, which are representative of black and dark color gel coats, and (3) red gel coats, which are 

representative of red and other bright color gel coats. 

Results of a detailed gel coat usage survey, which was sent to nine companies with 

facilities in the top portion of the MACT database, show that white/off white gel coats are the 

most predominant colors used followed by red/bright colored gel coats. The survey also shows 

that the use of black/dark color gel coats is insignificant for the facilities that responded to the 

survey. We did not use any quantitative data on color usage from the survey, however, because 

the facilities surveyed only represent about five percent of the total pigmented gel coat usage in 

the MACT database. In addition, the surveyed facilities, which mainly produce bathware and 

transportation products, may not be a representative sample of all facilities using pigmented gel 

coats. 

Based on qualitative results of the pigmented gel coat usage survey, we assumed that the 

color distribution of pigmented production gel coats currently used by facilities in open molding 

operations is 80% by volume white/off white gel coat and 20% by volume red/bright colored 

coat. We assumed no usage of black/dark colored gel coat in the cost analysis because the 

amount reported in the detailed gel coat usage survey is insignificant compared to the other 

colors. We then applied these percentages to the total pigmented production gel coats estimated 

6-20 
P.29 

for each facility to calculate pre-MACT usage of white/off white and red/colored pigmented gel 

coats. 

Next, we identified the costs for the white/off white and red/bright colored gel coat pairs. 

The white/off white high HAP gel coat selected (944-POLYCOR ISO standard) has a cost of 

$1.68 per pound The white/off white low HAP gel coat selected (962 - Sanitary LOW VOC) has 

a cost of $1.99 per pound. This yields a switching cost of $0.28 per pound. The red/bright 

colored high HAP gel coat selected (944-POLYCOR ISO standard) has a cost of $2.71 per 

pound. The red low HAP gel coat selected (962 - Sanitary LOW VOC) has a cost of $3.51 per 

pound. This yields a switching cost of $0.80 per pound. 

We then determined the amounts of low HAP white/off white and red/bright colored 

production gel coat each facility will need to use to comply with the existing source MACT floor 

and obtain the same surface area coverage. Due to differences in density and the amount of HAP 

emitted during application and curing, the amount of surface area that can be covered by equal 

amounts of low HAP and high HAP gel coats on a weight or mass basis is different. Low HAP 

gel coats generally have a higher density than high HAP gel coats. This higher density equates to 

a lower volume of gel coat per pound of gel coat purchase. This lower volume can result in less 

total gel coat coverage per pound of gel coat purchased. Conversely, low HAP gel coats emit 

less styrene and methyl methacrylate with the result that less of the applied gel coat material 

evaporates into the atmosphere. This fact — that less material evaporates -- can result in more 

total coverage per pound of gel coat purchased. 

These two factors are simultaneously present in different degrees and the combined effect 

of both factors determines if the facility must increase or decrease the amount of gel coat 

purchased in order to obtain the same amount of surface area coverage. In calculating how much 

low HAP pigmented production gel coat would be needed at a facility to reach a specific control 

level, we considered the actual HAP contents of the pigmented production gel coats at each 

facility, where that information was known. Otherwise, we used an average pigmented 

production gel coat HAP content of 37 percent for determining how much low HAP pigmented 

production gel coat is needed to comply with the MACT floor. Finally, because of the cost 

differential between the low HAP white/off white and high HAP white/off white production gel 

6-21 
P.30 

coats is substantially smaller than the cost differential between the low HAP red/bright colored 

and the high HAP red/bright colored production gel coats, we assumed that facilities would 

replace all of the high HAP white/off white pigmented production gel coat prior to replacing any 

of the high HAP red/bright colored pigmented production gel coat. 

Once we determined the usages of white/off white and red/bright colored production gel 

coat usages for low and high HAP gel coat, we calculated the annual total cost incurred by the 

facility prior to the implementation of the MACT floor level of control by multiplying the 

amount of white/off white and red/bright colored production gel coats used by the facility 

annually (regardless of the HAP content) by the respective costs of the selected high HAP 

white/off white and red/brightly colored production gel coats and summing the results. Next, we 

calculated the annual total cost incurred by the facility for complying with the MACT floor by (1) 

multiplying the amount of high HAP white/off white and red/bright colored production gel coats 

that will still be used after implementation ofthe MACT floor level of control by the respective 

cost of the selected high HAP white/off white and red/bright colored production gel coats, (2) 

multiplying the amount of low HAP white/off white and red/bright colored production gel coats 

that will be used after implementation of the MACT floor level of control by the respective costs 

of the selected low HAP white/off white and red/bright colored production gel coats, and (3) 

summing the two results. We then determined the cost of complying with the MACT floor for 

each facility by subtracting the after MACT high and low HAP pigmented production gel coat 

costs from the pre-MACT pigmented production gel coat costs. 

6.3.5 Low HAP Clear Production Gel Coats

 1314 

We calculated the cost of using low HAP clear production gel coats by (1) determining 

the costs of low and high HAP clear production gel coats, (2) determining the amount and type 

(low and high HAP) of clear production gel coat currently used at a facility (pre-MACT floor), 

(3) determining the amount and type (low and high HAP) of clear production gel coat in order to 

comply with the MACT floor (after MACT floor), and (4) applying the cost to the amount of low 

and high HAP clear production gel coat to determine facility costs pre-MACT floor and after 

6-22 
P.31 

MACT floor. Compliance with the MACT floor point value for clear production gel coats 

corresponds to a HAP content of 44.0% by weight. 

We collected cost and properties information on clear production gel coats from two 

major gel coat manufacturers. Table 6-10 summarizes the available cost information submitted 

by these gel coat manufacturers. 

TABLE 6-10. AVAILABLE COST INFORMATION FOR CLEAR PRODUCTION 

GEL COATS FROM GEL COAT MANUFACTURERS 

Gel Coat Manufacturer 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Cook Composites & Polymers 

Gel Coat Product 

Number 

CG-LE-570 

CG-07009 

CG-21009 

942-XA-220 

Gel Coat 

Base Color 

Clear 

Clear 

Clear 

Clear 

Styrene 

Content 

34 

47.2 

43.7 

MMAa 

Content 

1 

0.0 

6.1 

HAP Content

 a 

(% by wt.) 

35 

47.2 

49.8 

45.0 

Sale Price 

($ / lb) 

$2.10c 

$1.53 

$1.68 

$1.92 

Styrene, methyl methacrylate, and total HAP contents are shown to the number of decimal places reported by the gel coat 

manufacturer. 

All sales prices are in 1998 dollars and are on a drum size shipment basis. 

NOTE: Blank spaces in the table indicate information was not provided by the manufacturer. 

Based on the data collected, high HAP (45 to 50%) clear production gel coats cost 

between $1.53 and $1.92 per pound when delivered in drums. We selected the Neste Polyester 

CG-07009 gel coat to represent a typical high HAP gel coat because the Neste's HAP content is 

representative of the HAP content used by the majority of facilities currently using clear 

production gel coats. This gel coat costs $1.53 per pound. 

As seen in Table 6-10, the only clear production gel coat with a low enough HAP content 

to meet the MACT floor (35%) costs $2.10 per pound. We used this cost to cost all low HAP 

clear production gel coats for compliance with the MACT floor. 

Because the selected low HAP clear production gel coat has a substantially lower HAP 

content of 35.0% by weight than the 44% by weight needed to meet the MACT floor, we 

assumed that this large differential in the HAP content (and the higher price of the low HAP clear 

6-23 
P.32 

production gel coat) will result in facilities using only the amount of low HAP clear production 

gel coat necessary to meet the required control level. 

We then determined the amount of low HAP clear production gel coat each facility will 

need to use to comply with the existing source MACT floor point value limit and obtain the same 

surface area coverage. Due to differences in density and the amount of styrene emitted during 

application and curing, the amount of surface area that can be covered by equal amounts of low 

HAP and high HAP gel coats on a mass basis is different. Low HAP gel coats generally have a 

higher density than high HAP gel coats. This higher density equates to a lower volume of gel 

coat per pound of gel coat purchase. This lower volume can result in less total gel coat coverage 

per pound of gel coat purchased. Conversely, low HAP gel coats emit less styrene and methyl 

methacrylate with the result that less of the applied gel coat material evaporates into the 

atmosphere. This fact - that less material evaporates - can result in more total coverage per 

pound of gel coat purchased. 

These two factors are simultaneously present in different degrees and the combined effect 

of both factors determines if the facility must increase or decrease the amount of gel coat 

purchased in order to obtain the same amount of surface area coverage. In calculating how much 

low HAP clear production gel coat would be needed at a facility to reach the MACT floor point 

value, we considered the actual HAP contents of the clear production gel coats at each facility, 

where that infoimation was known. Otherwise, we used an average clear production gel coat 

HAP content of 47.3 percent for determining how much low HAP clear production gel coat is 

needed to comply with the MACT floor. 

Once we determined the clear production gel coat usages for the pre-MACT and after 

MACT scenarios, we calculated the annual total cost incurred by the facility prior to the 

implementation of the MACT standard by multiplying the amount of clear production gel coat 

used by the facility annually (regardless of the HAP content) by the cost of the selected high HAP 

clear production gel coat. Next, we calculated the annual total cost incurred by the facility for 

complying with the MACT floor by (1) multiplying the amount of high HAP clear production gel 

coat that will still be used after implementation of the MACT standard by the price of the 

selected high HAP clear production gel coat, (2) multiplying the amount of low HAP clear 

6-24 
P.33 

production gel coat that will be used after implementation of the MACT standard by the price of 

the selected low HAP clear production gel coat, and (3) summing the two results. We then 

determined the cost of complying with the MACT floor for each facility by subtracting the after 

MACT high and low HAP clear production gel coat costs from the pre-MACT clear production 

gel coat costs. 

6.3.6 Low HAP Tooling Gel Coats

 l31 5 

We determined the costs for the use of low HAP tooling gel coats by (1) estimating the 

amount of tooling gel coat currently used, (2) estimating a single average cost differential 

between high HAP and low HAP tooling gel coats and (3) applying the average cost differential 

to quantity of high HAP tooling gel coats currently used at the facility, all of which would be 

replaced with a low HAP tooling gel coats. As discussed below, we calculated these costs for all 

open molding operations (except filament winding) and all polymer casting operations with 

average tooling gel coat HAP contents greater than the MACT floor level of 38 percent. 

Based on information available, open molding operations (except filament winding) and 

polymer casting operations use reinforced plastic composite molds in their manufacturing 

processes. These molds, which are gel coated, are made from tooling resins. While few facilities 

in the 1993 Information Collection Request (ICR) survey indicated the use of tooling gel coats 

(possibly because they are used in small amounts relative to production materials), we assumed 

that all facilities known or assumed to use tooling resin also use tooling gel coat. 

While a few facilities identified the amount of tooling gel coat used, most facilities did 

not provide that information. For the latter facilities, we had to estimate the amount of tooling 

gel coat being used. We did this by applying a tooling gel coat to tooling resin ratio of 0.15 (i.e., 

15 lbs of tooling gel coat must be applied for every 100 lbs of tooling resin). This ratio is based 

on an average ratio of production gel coat to production resin. No information was available 

relating the use of tooling gel coat to tooling resin. The ratio of 0.15 is an average based on two 

applied gel coat to applied resin ratios calculated using actual data. The first ratio is the amount 

of pigmented production gel coat applied per production resin applied using manual and/or 

mechanical resin application (0.215). The second ratio is the amount of clear production gel coat 

6-25 
P.34 

applied per production resin applied during the polymer casting process (0.085). Since facilities 

that manufacture products using open molding operations and/or polymer casting operations 

likely manufacture and/or repair molds, we used the average of these ratios to obtain the 0.15 

ratio. 

Once we determined the tooling gel coat usage for each facility, we identified the average 

HAP content of the tooling resin at each facility in order to determine which facilities would 

need to switch to a low HAP resin. Again, only a few facilities identified their tooling gel coat 

HAP contents. For the other facilities, we estimated the average HAP content of their tooling gel 

coats by using the average HAP content of tooling gel coat operations for those facilities where 

the actual HAP content of the tooling gel coat is known. The calculated average HAP content is 

greater than the existing MACT floor level of 38 percent. Therefore, we assumed that facilities 

within unknown tooling gel coat HAP contents would switch to low HAP tooling gel coats in 

order to comply with the MACT floor. 

We collected cost and properties information on tooling gel coats from two major gel coat 

manufacturers. Table 6-11 summarizes this information. From the available cost information, 

we selected Neste Polyester BG-5500 as the tooling gel coat most likely to represent the high 

HAP tooling gel coats currently in use. We selected this gel coat because the gel coat color 

(black) is a typical tooling gel coat color and the HAP content of the tooling gel coat (45.8% by 

wt.) is close to the average HAP content of the tooling gel coat operation. 

Next, we selected the tooling gel coat(s) most likely to represent the low HAP tooling gel 

coats selected by facilities to comply. The existing source MACT floor is set by a gel coat 

(Polydyne 151 Orange) with a HAP content of 38.0% by weight. However, no cost information 

was available for this gel coat. 

We selected the Ferro Corporation GV 01767 gel coat as the.low HAP tooling gel coat 

because the Ferro GV 01767 gel coat is a logical match for the high HAP Neste Polyester BG55000 due to the identical color and presence of methyl methacrylate. In addition, this gel coat is 

one of the more commonly used lower HAP tooling gel coats for which cost data were available. 

We then calculated the cost differential between the selected high HAP and low HAP 

tooling gel coats, which is $0.21per pound ($2.72 - $2.93). We used this cost differential to 

6-26 
P.35 

TABLE 6-11. AVAILABLE COST INFORMATION FOR TOOLING 

GEL COATS FROM GEL COAT MANUFACTURERS 

Gel Coat Manufacturer 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Cook Composites & 

Polymers 

Cook Composites & 

Polymers 

Cook Composites & 

Polymers 

Ferro Corporation 

Ferro Corporation 

Ferro Corporation 

Gel Coat Product 

Number 

BG-55000 

RG-55005 

YG-55000 

YG-57000 

YG-5776V (Vinyl Ester) 

CG-5116V (Vinyl Ester) 

945-B-201 

945-GA-104 

945-YA-058 

GV 03894 

58-601230

 c 

GV 01767 

Gel Coat 

Base Color 

Black 

Red 

Orange 

Orange 

Orange 

Clear 

Black 

Green 

Orange 

Red 

Tangerine 

Black 

Styrene 

Content 

(% by wt.) 

40.8 

45.7 

41.3 

41.7 

53.2 

54.0 

36.94 

29.23 

36.97 

MMAa 

Content 

(% by wt.) 

5.0 

0.0 

0.0 

5.0 

0.0 

0.0 

3.00 

3.00 

3.00 

HAPa 

Content 

(% by wt.) 

45.8 

45.7 

41.3 

46.7 

53.2 

54.0 

48 

48 

48 

39.64 

32.23 

39.97 

Sale" 

Price 

($ / lb) 

$2.72 

$2.72 

$3.36 

$3.36 

$4.11 

$3.47 

$3.06 

$3.77 

$3.77 

$3.48 

$4.99 

$2.93 

Sale Price 

Shipment 

Size Basis 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

50 lbs 

50 lbs 

50 lbs 

Styrene, methyl methacrylate, and total HAP contents are shown to the number of decimal places reported by the gel coat 

manufacturer. 

All sales prices are in 1998 dollars. 

According to the manufacturer (Ferro Corporation), this gel coat is a heavy metal free pigmented system with a very high heat 

distortion temperature. The manufacturer also indicated that the gel coat does not have many customers at this time resulting in 

the unusually high cost. 

NOTE: Blank spaces in the table indicate information was not provided by the manufacturer. 

6-27 
P.36 

calculate the direct annual cost incurred by facilities in replacing high HAP tooling gel coats with 

low HAP tooling gel coats. 

6.3.7 Testing of New Low HAP Resins and Gel Coats 

We determined the costs of testing new low HAP resins and gel coats for each facility by 

estimating (1) a cost per trial and (2) the number of trials each facility would be required to 

perform. We estimated these costs for the following resin and gel coat groupings: corrosion 

resistant resins, non-corrosion resistant resins, tooling resins, pigmented gel coats, clear gel coats, 

and tooling gel coats. The cost information discussed here only pertains to testing conducted by 

the facility. Testing conducted for facilities by independent testing firms is discussed in Section 

6.3.8 (Recertification of Products). 

We collected infoimation on testing costs that facilities incurred to verify that the new 

low HAP resins exhibit acceptable physical properties from six facilities. Table 6-12 presents 

these data. Testing cost data to switch from high to low HAP gel coats were not available. 

TABLE 6-12. TESTING OF NEW LOW HAP RESINS 

Facility 

Bowie Manufacturing, Inc. ' 

18 Dixie-Pacific Manufacturing Company, Inc. 

19 Fiber Pro, Inc. 

20 LASCO Bathware (Yelm) 

21 LaValley Construction Company 

22 Shenandoah Fiberglass Products Company 

Former Resin HAP 

Content (%) 

Greater than 35.0 

39.8 

40.0 

46.0 

43.0 

45.0 to 50.0 

New Resin HAP 

Content (%) 

31.0 and 32.7 

35.0 

35.3 

37.0 and 30.0 

34.0 

35.0 

Testing Cost including 

Labor and Materials 

"Minimal" 

"A few hundred dollars" 

None 

$5,000 per Trial 

No cost tothe facility 

$ 3,000 per Trial 

As seen in Table 6-12, testing costs may vary from zero cost to $5,000 per trial. Based on 

these data, we selected $3,000 per trial as an average cost for switching to lower HAP resins. 

Testing costs for switching from high to low HAP gel coats were not available. We 

assumed that the testing costs for switching from high to low HAP gel coats are the same as for 

switching from high to low HAP resins. 

6-28 
P.37 

The amount of testing that a facility does is highly variable and depends on the product 

being manufactured and the extent of the testing done by the resin or gel coat supplier. For each 

resin or gel coat grouping identified above, we assumed that 3 trials would be necessary. For 

example, if Facility A uses corrosion resistant resins and non-corrosion resistant resins, we 

assumed that Facility A conducted 3 trials for the corrosion resistant resins and 3 trials for the 

non-corrosion resistant resins, for a total of 6 trials. 

Facilities may also use several application techniques to apply the different resin 

groupings. For example, Facility A may use manual and mechanical application techniques to 

apply the corrosion resistant resins and manual, mechanical, and filament winding application 

techniques to apply the non-corrosion resistant resins. For facilities that apply the resins using 

multiple application techniques, we divided the testing costs equally among the application 

techniques. For example, Facility A would perform 3 trials for the corrosion resistant resins at a 

total cost of $9,000. We then distributed this $9,000 equally over the manual corrosion resistant 

resin application operations and the mechanical corrosion resistant resin application operations 

(i.e., we allocated $4,500 to each of these two operations). For the non-corrosion resistant resins, 

Facility A would also incur a total of $9,000 for trials. With three application techniques being 

used for non-corrosion resistant resins, we then distributed the $9,000 cost equally over the 

manual non-corrosion resistant operations, the mechanical non-corrosion resistant operations, 

and the non-corrosion resistant filament winding operations (i.e., we allocated $3,000 to each of 

these three operations). 

For gel coats, we assumed that the total number of trials would be equal to 3 each for 

clear production gel coat, pigmented production gel coat, and tooling gel coat. We did not 

allocate these trial costs among application techniques because a different type of gel coat is used 

in these operations. 

6.3.8 Training to Use New Low HAP Resins and Gel Coats 

We collected information on training costs that facilities incurred associated with 

switching to lower HAP resins from five facilities. Table 6-13 presents this information. 

Training cost data to switch from high to low HAP gel coats were not available. 

6-29 
P.38 

TABLE 6-13. TRAINING COSTS TO USE NEW LOW HAP RESINS 

Facility 

18 Dixie-Pacific Manufacturing Company, Inc. 

19 Fiber Pro, Inc. 

21) 

LASCO Bathware (Yelm) 

LaValley Construction Company 

22 Shenandoah Fiberglass Products Company 

Former Resin HAP 

Content (%) 

39.8 

40.0 

46.0 

43.0 

45.0 to 50.0 

New Resin HAP 

Content (%) 

35.0 

35.3 

37.0 and 30.0 

34.0 

35.0 

Training Cost for Switching 

to Lower HAP Resin ($) 

None 

None 

None 

Minimal 

None 

As seen in Table 6-13, four out of the five facilities reported no (zero) training costs 

incurred due switching to lower HAP resins and the fifth reported "minimal" costs. Therefore, 

we assumed there would be no training costs for a facility to switch to lower HAP resins or gel 

coats. 

6.3.9 Recertification of Products 

Recertification of products may be necessary when switching from high HAP to low HAP 

resins or gel coats and is generally required for those products that are mass produced. The only 

mass produced stock products identified that we believe requires independent certification appear 

to be underground gasoline storage tanks. Custom made tanks or other specialty products are 

assumed to need individual product certification regardless of the type and HAP content of the 

resin. Thus, we assumed that switching to a lower HAP resin does not affect product 

certification costs for custom products. 

No data were available on product recertification costs. We assumed a typical product 

recertification cost of $50,000 for each underground gasoline storage tank product line where the 

resin is changed. We believe that this number is reasonable for this cost. For facilities that use 

different operations to produce underground gasoline storage tanks, we divided the $50,000 

recertification cost equally among each operation. For example, if Facility B produces 

underground storage tanks using manual operations and mechanical operations, the total 

recertification cost to the facility was $50,000 with $25,000 being allocated to the manual 

operations and the other $25,000 allocated to the mechanical operations. 

6-30 
P.39 

6.3.10 Production Problem Costs Due to Switching to New Low HAP Resins and Gel Coats 

This is a cost that could occur if switching to low HAP resins and gel coats resulted in 

less efficient production. We collected data on this potential cost from seven facilities (see 

Table 6-14). 

TABLE 6-14. IMPACT OF SWITCHING TO LOW HAP RESINS ON 

PRODUCTION EFFICIENCY 

Facility 

Bowie Manufacturing, Inc. 

Dixie-Pacific Manufacturing Company, Inc. 

19 Fiber Pro, Inc. 

20 LASCO Bathware (Yelm) 

LaValley Construction Company 

Shakespeare Electronics & Fiberglass Division 

Ll 

Shenandoah Fiberglass Products Company 

Former Resin HAP 

Content (%) 

Greater than 35.0 

39.8 

40.0 

46.0 

43.0 

42.0 

45.0 to 50.0 

New Resin HAP 

Content (%) 

31.0 and 32.7 

35.0 

35.3 

37.0 and 30.0 

34.0 

33.0 

35.0 

Impact on Production 

None 

None 

None 

"Significant" 

"Minimal" 

None 

None 

As seen in the data shown in Table 6-14, five of the 7 facilities reported no impact on 

production associated with switching to lower HAP resins, one facility reported "minimal" costs, 

and one reported "significant" costs. Further, information was not available that would allow us 

to identify which facilities would incur production problems. Based on these factors, we 

assumed that, in general, there is no loss of production efficiency due switching to lower HAP 

resins. Therefore, there is no increase in production costs occurring due to a loss of production 

efficiency. 

6.3.11 Long-Term Increase in Labor Cost 

Another method of identifying the impacts of switching to lower HAP content resins 

would be to look for long term increases in labor costs occurring at facilities where the switch 

had occurred. Table 6-15 presents the available data for two facilities. As seen in Table 6-15, 

both facilities reported no long-term increase in labor costs due to switching to lower HAP resin. 

6-31 
P.40 

TABLE 6-15. LONG-TERM INCREASE IN LABOR COST 

Facility 

Bowie Manufacturing, Inc. ' 

'1\ LaValley Construction Company 

Former Resin HAP 

Content (%) 

Greater than 35.0 

43.0 

New Resin HAP 

Content (%) 

31.0 and 32.7 

34.0 

Long-Term Increase in Labor Cost due 

to Switching to Lower HAP Resin ($) 

None 

None 

6.3.12 Equipment Change Costs 

Another potential cost considered for switching to lower HAP resins and gel coats would 

be purchase of new spray equipment and/or laminating tools due to changes in wet resin physical 

properties. Table 6-16 presents the available information on this potential cost from two 

facilities. 

TABLE 6-16. AVAILABLE EQUIPMENT CHANGE COSTS 

Facility 

24 Bittner Industries, Inc. 

Bowie Manufacturing, Inc. 

Former Resin HAP 

Content (%) 

Greater than 35.0 

Greater than 35.0 

New Resin HAP 

Content (%) 

32.5 

31.0 and 32.7 

Costs for New Spray Equipment and/or 

Laminating Tools 

None 

None 

As seen in Table 6-16, the available information shows that these two facilities did not 

incur any equipment change costs due switching to lower HAP resins. Some facilities stated they 

anticipated costs due to equipment changes. However, these are only anticipated costs. 

Therefore, we judged it reasonable to assume that a facility would not have to purchase new 

spray equipment or laminating tools in order to switch from high HAP resin and gel coats to low 

HAP resins and gel coats. 

6.3.13 Adoption of Non-Atomized Resin Application Equipment 

We based the cost associated with switching from atomized to non-atomized resin 

application equipment for the reinforced plastic composites source category on cost data 

compiled for the boat manufacturing MACT standard.25 The cost analysis for complying with 

the requirements for non-atomized resin application has four elements: (1) the equipment cost to 

6-32 
P.41 

switch from atomized resin spray guns to non-atomized resin flowcoaters, (2) cost savings from 

the reduced need for personal protective equipment (PPE) with non-atomized resin application 

system,26,2? (3) cost savings from reduced resin consumption because of the greater transfer 

efficiency of flowcoaters compared to spray guns, and (4) the cost savings from the reduced use 

of floor coverings associated with reduced resin overspray. We estimated the cost impact of 

switching to flowcoaters as the total difference in annualized capital and indirect costs for resin 

spray guns and resin flowcoaters over 10 years after the compliance date required by the rule. 

The predominant atomized spray gun technology used in the reinforced plastic composite 

facilities are chopper spray guns. Non-atomized resin application technologies used include resin 

flowcoaters and pressure-fed resin rollers. In the cost impact analysis, we assume that reinforced 

plastic composites manufacturers will switch from chopper spray guns to chopper flowcoaters, 

because chopper flowcoaters are more similar to chopper spray guns and can apply chopped 

roving, whereas resin rollers and resin impregnators cannot. In addition, some spray guns can be 

converted to flowcoaters simply by changing the resin spray tip to a flowcoater nozzle and by 

switching to a modified chopped roving delivery chute. 

The cost increase for switching to flowcoaters is offset for many facilities by decreased 

need for, PPE, floor coverings, and reduced resin loss from higher transfer efficiency and reduced 

resin overspray with flowcoaters. The majority of facilities have an estimated net cost savings 

when PPE, floor covering, and resin cost savings are added to the flowcoater cost impacts. These 

net cost savings were counted as zero costs, rather than used to offset cost impacts for other 

regulated materials, such as gel coats. Table 6-17 summarizes the cost and savings factors used 

to estimate the costs of switching to flowcoaters for each of the four elements. The following 

paragraphs describe briefly the derivation of the cost factors for each of the four elements. For 

more information, please refer to Reference 25. 

Equipment Cost to Switch from Atomized Spray Guns to Flowcoaters. Although most 

manufacturers currently have spray guns that can be converted to flowcoaters by changing the 

nozzle and chute, only the newer models of guns generally can be converted. Therefore, we 

assumed that the entire gun would be replaced at an average cost of $2,225 per unit. In addition, 

6-33 
P.42 

TABLE 6-17. COST ANALYSIS ELEMENTS FOR SWITCHING TO FLOWCOATERS 

Cost Analysis Element 

Equipment cost due to switch 

Personal protective equipment 

Reduced resin consumption 

Reduced disposable floor coverings 

Cost (Savings) 

$1,112 per spray gun 

switched 

($595) per worker 

($0.60) per ton of 

reduced noncorrosion resistant 

resin usage 

($1.05) per ton of 

reduced corrosion 

resistant resin usage 

($7.78) per ton of 

resin applied 

Comment 

This is a net cost for switching a single 

atomized spray gun to a flow coater. 

This is a net savings per worker. The 

analysis assumed one worker per spray gun. 

Thus, this factor can also be expressed as a 

savings of $595 per spray gun switched. 

The savings factors are applied to the 

amount of non-corrosion resistant/corrosion 

resistant resin no longer used due to the 

increased transfer efficiency of flow coaters 

versus spray guns. This is calculated as 

follows: 

(1-0.9719) * (resin use prior to 

switch to flowcoaters) 

This is a net savings per ton of resin applied 

currently applied with spray guns. 

one manufacturer, Binks, does not offer a flowcoater. Facilities currently using Binks spray guns 

would also need to buy a new resin and catalyst pumps at a cost of $4,000 per unit for each Binks 

spray gun they currently operate. These facilities should still be able to use their existing carts 

and booms, so they should not have the full cost of replacing the spray gun unit. Since only 

limited information was available on the manufacturer of their spray guns at reinforced plastic 

facilities, we assumed that all facilities would replace both the spray gun and the pump at a cost 

of $6,225 to obtain a conservative cost estimate. 

We estimated the cost of switching to flowcoaters from spray guns as the net annual 

difference in cost between a facility that continues to use spray guns, and the same facility 

switching from spray guns to flowcoaters before the spray guns have reached the end of their 

useful economic life. That is, we estimated the costs for the same plant under two scenarios: 

(1) the plant operates spray guns in the absence of the rule and (2) the same plant must switch to 

flowcoaters while the spray guns are still functional. Appendix 6.4 provides more detail on the 

6-34 
P.43 

costs of flowcoater system and components, and provides an example of the derivation of the net 

annual cost per spray gun shown in Table 6-17. 

Cost Savings from Reduced Personal Protective Equipment. Workers who operate 

flowcoaters can typically reduce the amount of PPE they wear, compared to spray gun operators, 

because of the reduced presence of resin aerosols and lower styrene levels in the workplace. 

Personal protective equipment typical wom by spray gun operators include Tyvek® paper suits, 

respirators, safety glasses, gloves, and hair and shoe covers. The paper suits cannot be used for 

more than one day because the workers typically tape the ankles and wrists closed. Workers 

using non-atomized resin application, such as flowcoaters, do not typically use the respirators 

and paper suits used by workers using resin spray guns. Instead, the paper suits are typically 

replaced with a plastic apron and no respirator is usually needed. The other types of PPE worn 

(e.g., safety glasses, gloves, hair and shoe covers) are the same for both atomized and nonatomized open mold resin application methods. 

We estimated the cost savings for personal protective equipment based on the cost of the 

equipment used. The analysis conservatively assumes there is one lamination worker per resin 

spray gun or flowcoater that must wear PPE. However, at most facilities, there are two, three, or 

four workers for each spray gun or flowcoater that also wear PPE.26,27 The cost savings from 

PPE at those facilities would be higher than the savings shown in Table 6-17. Additional savings 

may come through reduced need for training and medical monitoring associated with the use of 

respirators, but these costs would be more difficult to quantify and are not included in this 

analysis. 

We also assume in the analysis that only half of the workers that switch from using spray 

guns to flowcoaters will reduce their PPE usage.26,27 In some cases, even with flowcoaters, a 

facility cannot reduce styrene levels below the level requiring a respirator. Tn other cases, a 

worker may continue to wear a respirator out of personal preference. However, the majority of 

workers at facilities observed by EPA that have switched to flowcoaters or other types of nonatomized resin equipment do not wear respirators, so cost savings would again be higher than 

estimated in this analysis. 

6-35 
In estimating these cost savings, we assume that the plant operates 50 weeks per year and 

that each worker uses two aprons per week at a cost of $2 per apron, or $200 per year. If half the 

workers use the same PPE as spray gun operators ($l,389/year) and half use only aprons 

($200/year), the average cost per worker using flowcoaters is $794 per year. The difference in 

PPE cost between atomized and non-atomized resin workers is $595 per worker per year. 

Appendix 6.5 provides additional detail on the costing of this element. 

Reduced Resin Consumption Due to Greater Flowcoater Transfer Efficiency Compared to 

Sprav Guns. The Research Triangle Institute (RTI) and EPA resin and gel coat study measured 

the transfer efficiency of air-assisted airless resin spray guns and flowcoaters.26 Based on the 

results of this study, a facility switching to flowcoaters from spray guns will only need 97.19 

percent of the resin they consumed with spray guns to build the same parts because of reduced 

resin lost as overspray. To estimate cost savings from reduced resin usage, we multiplied the 

amount of resin applied by spray guns by 0.9719 to determine the amount of resin needed with 

flowcoaters. We then multiplied the difference in resin amounts needed with spray guns and 

flowcoaters by $0.60 per pound for non corrosion resistant resins and $1.05 for corrosion 

resistant resins to determine the resin cost savings from reduced resin overspray. We selected the 

costs of $0.60 and $1.05 per pound of resin because they were the lowest resin list prices 

available for non-corrosion resistant and corrosion resistant resins, respectively. If more 

expensive resins are used, cost savings could be higher. 

Cost Savings from Reduced Disposable Floor Coverings. Reinforced plastic composites 

manufacturers typically cover the floors of the lamination areas with heavy kraft paper or 

cardboard to catch resin overspray. The floor coverings are replaced on a periodic basis to 

prevent resin build-up on the floor of the lamination area. Because there is less overspray from 

flowcoaters than from spray guns, resin buildup on the floor covering is slower and the floor 

coverings do not need to be replaced as frequently. Based on data generated for the boat 

manufacturing MACT, we derived a unit savings of $7.78 per ton of resin applied. We estimated 

the floor covering cost savings for reinforced plastic composites facilities that switch from spray 

guns to flowcoater by multiplying the $7.78 per ton cost savings by the tons of resin currently 

6-36 
P.45 

applied with spray guns that will be applied with flowcoaters after compliance with the MACT 

standard. 

6.3.14 Uncovering only one Charge per Compression/Injection Molding Machine 

Cost data on uncovering only one charge as opposed to several charges per compression/ 

injection molding machine for each mold cycle were not available. We believe it is reasonable to 

assume that it does not take the operator of the compression/injection molding machine any 

longer to only uncover one charge per mold cycle than to uncover several charges per mold cycle 

at once for the production of the same amount of total product. Further, uncovering more than 

one charge at a time per molding cycle may have a negative impact on the quality of the SMC or 

BMC charge, because the uncovered charges lose monomer more quickly than covered charges. 

This monomer loss could adversely impact the polymerization reaction.28 Thus, requiring only 

one charge at a time to be uncovered may in fact provide benefits. Given these considerations, 

we concluded that uncovering only one charge as opposed to several charges per compression/ 

injection molding machine for each mold cycle is not expected to result in any costs. 

6.3.15 Wet Area Enclosures with Resin Drip Collection Svstem for Pultrusion Operations 

The basic approach we used to cost wet area enclosures and resin drip collection systems 

for pultrusion operations was to determine the number of pultrusion lines at each facility with 

pultrusion operations and multiply that number of lines by cost factors for capital cost, 

annualized capital cost, and annual operating costs. 

In calculating costs associated with wet area enclosures and resin drip collection systems, 

we first determined the number of pultrusion lines at each individual facility. Most of the 

pultrusion facilitites (24 out of 31) indicated the number of pultrusion lines at the facilities. For 

the other seven facilities, we estimated the number of pultrusion lines by using the reported resin 

usage for the pultrusion operations at the facility and the pultrusion line to pultruded resin ratio 

calculated from facilities for which data are available. 

We assumed that facilities not already determined to be in compliance would install one 

wet area enclosure and one resin drip collection system per pultrusion line at the facility. This 

6-37 
P.46 

assumption will make the cost estimates more conservative (i.e., overestimate the cost) because 

facilities that utilize direct die injection without resin pre-wet will not have to install wet area 

enclosures. 

One facility provided cost information on the design, installation, and operation of wet 

area enclosures.29 Table 6-18 summarizes this information. 

TABLE 6-18. AVAILABLE COST INFORMATION FOR WET AREA ENCLOSURES

 a 

Compliance Condition 

Design, Installation, and Operation of Wet Area 

Design, Installation, and Operation of Wet Area 

Size of Wet 

Area Enclosure 

Large 

Small 

Total Capital Cost 

$765.15 per year 

$396.52 per year 

Annual Operation 

and Maintenance 

$754.81 per year 

$436.55 per year 

a

 Cost figures are in 1998 dollars and are for large and small wet area enclosures installed on pultrusion lines at the 

Glasforms, Inc. facility in Birmingham, Alabama. 

While this facility did not provide any cost information on the resin drip collection 

systems installed on pultrusion lines, it did provide a description of the resin drip collection 

system. The resin drip collection system present at Glasforms consists of a plastic pipe 

(modified with a cut-out), a funnel, and a container (shaped like a bleach jug) for collecting resin. 

We calculated total capital costs, annualized capital costs, and annual operating costs for 

wet area enclosures.30 As seen in Table 6-18, capital costs are provided for "large" and "small" 

wet area enclosures. However, there is insufficient information available on the size of the 

pultrusion lines present at facilities to determine whether the pultrusion line at the facilities will 

require "small" or "large" wet area enclosures. We used the capital cost for the "large" wet area 

enclosure (i.e., $765 per wet area enclosure) for all pultrusion lines requiring wet area enclosures. 

This decision is likely to be conservative in that some facilities will be able to install the less 

expensive "small" wet area enclosures to comply. We calculated the total capital cost for each 

facility for the installation of wet area enclosures by multiplying the number of pultrusion lines 

present at the facility by $765 per line. 

In calculating the annualized capital cost of the wet area enclosure, we used an interest 

rate of 7 percent and an annualization period of 30 years. This yields an annualization capital 

6-38 
P.47 

cost factor of 0.0806. The OAQPS cost manual does not specify a capital cost annualization 

period for wet area enclosures installed on pultrusion lines. We assumed the annualization 

period for PTEs is appropriate due to the similarity in construction materials. We calculated the 

annualized capital cost for each facility for wet area enclosures by multiplying the number of 

pultrusion lines present at the facility by $62 per line ($765 x 0.0806). 

Finally, consistent with the assumption that all pultrusion lines would install the "larger" 

wet area enclosures, we used the annual operating cost shown in Table 6-18 for the large wet area 

enclosure to estimate annual operating costs for all wet area enclosures installed on pultrusion 

lines. Thus, we calculated the annual operating and maintenance cost for each facility for wet 

area enclosures by multiplying the number of pultrusion lines present at the facility by the annual 

operation and maintenance cost of $755 per line. 

Due to the relatively simple materials and design ofthis resin drip collection system at 

Glasforms, we assumed the cost associated with implementing the resin drip collection system is 

minimal compared to the design, installation, and operation of the wet area enclosure. Also, 

resin collected in the drip collection system may be recycled by the facility, thereby reducing the 

facility's raw material costs. Therefore, we assumed the resin drip collection system to have no 

cost. 

6.3.16 Closed or Covered Doctor Boxes. Folded Edges, and Low Stvrene Permeable Film for 

SMC Operations 

Cost data on closing or covering doctor boxes, folding edges, and using low styrene 

permeable film (e.g., Nylon) for SMC production were not available. We believe that failure to 

close or cover doctor boxes, failure to fold edges, and failure to use low stryrene permeable film 

have a negative impact on the quality of the SMC, because more monomer is lost if these actions 

are not taken and proper polymerization reaction may be adversely affected by the lost monomer. 

Conversely, the use of these three techniques may result in less raw materials being used and 

improved polymerization reactions. In the absence of being able to quantify these relative costs 

and savings, we assumed that the net direct annual cost incurred by facilities due to closing or 

covering doctor boxes, folding edges, and using low styrene permeable film is zero. 

6-39 
P.48 

6.3.17 Non-HAP Cleaning Materials 

Based on 1993 industry screening surveys, the most prevalent HAP-containing cleaner 

used in this industry is methylene chloride and a commonly used non HAP-containing cleaner is 

acetone. Some facilities also use methyl ethyl ketone, which is a HAP-containing cleaner. We 

collected cost data on the most commonly used HAP- and non HAP-containing cleaning 

solvents. Table 6-19 presents the available cost data for acetone, methylene chloride, and methyl 

ethyl ketone. 

TABLE 6-19. AVAILABLE COST INFORMATION FOR HAP- AND 

NON HAP- CONTAINING CLEANING SOLVENTS 

Solvent Supplier 

Worth Chemical Corporation 

Worth Chemical Corporation 

Fiberglass Coatings Inc. 

Cleaner 

Acetone 

Methylene Chloride 

Methyl Ethyl Ketone 

HAP Content 

(%) by weight 

0 

100 

100 

Sale Price 

($ /gal) 

$2.73 

$7.29 

$5.00 

Sale Price Shipment 

Size Basis 

55 Gallon Drum 

55 Gallon Drum 

55 Gallon Drum 

Based on the data collected, there are potential raw materials savings of $2.27 per gallon 

when switching from methyl ethyl ketone to acetone and of $4.56 per gallon when switching 

from methylene chloride to acetone. Therefore, we assumed that all facilities currently using 

methylene chloride would switch to acetone. 

The cost savings from switching could be offset by the increase in time and/or physical 

effort required by the use of a non HAP-containing cleaner to remove the cured or partially cured 

resins. No data are available to quantify this. Because cleaning material costs decrease, we 

assigned a net cost of zero for switching from HAP- to non HAP-containing cleaners. 

6.3.18 Closed/Covered Mixing with No Visible Gaps in Mixer Cover 

We calculated the costs associated with closing or covering mixers such that there are no 

visible gaps in the mixer cover by determining (1) the capital cost and annual cost for installing 

and operating mixer covers with no visible gaps, (2) the degree to which mixing being conducted 

6-40 
P.49 

at each facility is already in compliance with the proposed requirement, and (3) the number of 

mixers at each facility. 

Table 6-20 summarizes the available cost information associated with the adoption of 

closed/covered mixing practices where there are no visible gaps in the mixer cover and no active 

ventilation of the mixer.29'

33 

TABLE 6-20. AVAILABLE COST DATA FOR CLOSED/COVERED 

MIXING WITH NO VISIBLE GAPS 

Components of Mixer Cover Cost 

Materials to Construct Mixer Cover 

Labor to Construct Mixer Cover 

Total Mixer Cover Cost 

Component Cost 

$50 

$45 

$95 

Frequency of 

Semiannual 

Semiannual 

Semiannual 

Annual Cost 

$100 

$90 

$190 

The information in Table 6-20 is based on mixing operations conducted at the Glasforms, 

Inc., facility located in Birmingham, Alabama. At the Glasforms facility, mixing is conducted in 

55 gallon drums. The 55 gallon drum is covered by a plywood disk large enough to cover the 

entire drum top. The front third of the cover is hinged to allow for the addition of various 

materials during or prior to the mixing process. The mixer cover has a bristle-covered opening 

that allows the cover to be placed around the mixer shaft. The bristle-covered opening allows for 

easy replacement and removal of the mixer cover during mixing operations while leaving no 

visible gap between the mixing shaft and the mixer cover. 

The mixer covers are manufactured "in-house" by Glasforms. The labor costs and the 

raw material costs are approximately $45 per mixer cover and $50 per mixer cover, respectively. 

During the mixing operation, the mixer cover comes in contact with the promoted resin resulting 

in the gradual buildup of an uneven, cured resin layer on the inside of the cover. After 

approximately six months this layer increases in size to the point where the mixer cover must be 

replaced in order for proper mixing to occur. Based on the combined labor and material cost of 

$95 per mixer cover and the semi-annual frequency of replacement, we estimated the annual cost 

per mixer to be $190 for a 55 gallon mixing vessel. 

6-41 
P.50 

We identified information on the way mixing was being performed relative to compliance 

with the proposed standard for each facility, because the annual cost per facility is partially 

dependent on the existing degree of compliance with the proposed standard. Table 6-21 

summarizes the cost assigned per mixer based on a facility's existing level of compliance. 

TABLE 6-21. PER MIXER COMPLIANCE COST ASSIGNED TO A FACILITY 

BASED ON EXISTING LEVEL OF COMPLIANCE 

Current 

Type of Mixing 

(Open/Closed) 

Open 

Open 

Open 

Closed 

Closed 

Closed 

Closed 

Closed 

Closed 

Mixer Cover 

Installed on 

Mixer 

No 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Visible Gaps 

Present in 

Mixer Cover 

N/A 

N/A 

N/A 

Yes 

Yes 

Yes 

No 

No 

No 

Nitrogen 

Blanketing 

Used w/ Mixer 

N/A 

N/A 

N/A 

No 

No 

No 

No 

No 

Yes 

Mixer Actively 

Vented to 

Atmosphere 

No 

Yes 

No 

No 

Yes 

No 

No 

Yes 

No 

Mixer Actively 

Vented to 

Control Device 

No 

No 

Yes 

No 

No 

Yes 

No 

No 

Yes 

Annual Cost 

per Mixer 

(% of Max) 

100% 

100% 

0% 

50% 

50% 

0% 

0% 

0% 

0% 

Annual Cost 

per Mixer 

($/yr) 

$190 

$190 

$0 

$95 

$95 

$0 

$0 

$0 

$0 

The annual cost per facility is also dependant on the number of mixers present at the 

facility. Information of the number of mixers was available for some facilities. For the 

remainder of the facilities, we estimated the number of mixers. The number of mixers at a 

facility is dependent on a number of factors, including the size of the mixing vessels used, the 

type of materials to be mixed, the length of time required to completely mix the materials used by 

the facility, and the capability of the facility to use mixed materials due to production capacity 

and product demand. Because most of these factors were unknown, we based the number of 

mixers on the annual usage of materials that are likely to require mixing or agitation (i.e., resins, 

fillers, and gel coats). 

To estimate the number of mixers at a facility, we used the ratio of mixers to the 

approximate usage of these materials at Glasforms' Birmingham facility. This ratio is one mixer 

6-42 
P.51 

for every 400 tons of material mixed per year. We assumed that facilities using less than 400 

tons per year of materials have only one mixer. We rounded the number of mixers per facility up 

to the nearest whole number. For example, a facility that used 1250 tons per year of material 

potentially requiring mixing or agitation was estimated to have 4 mixers (1250/400 = 3.125; 

rounded up to the nearest whole number = 4). 

Once the number of mixers were estimated or identified and the degree of compliance 

with the proposed standard was identified, we estimated the total annual cost of complying with 

the requirement(s) for mixing vessels by multiplying the estimated or actual number of mixers 

present at the facility by the applicable annual cost per mixer identified in Table 6-21. 

6.3.19 Wet Area Enclosures for Resin Wet Out Areas at Continuous Lamination and Continuous 

Casting Operations 

Wet out area enclosures are enclosures constructed around the wet out area of a 

continuous lamination or casting line that capture emissions from the wet out area. We based the 

costing for these enclosures on wet out area enclosures found at the Kemlite-Sequentia facility in 

Grand Junction, Tennessee (see Appendix 6.6) Costs in 1992 dollars for the four wet area 

enclosures at this facility were reported as follows: 

Wide Line: $23,000 

Narrow Line: $ 8,300 

Narrow Line: $12,000 

Narrow Line: $14,000 

We escalated these costs to 1998$ using the CE equipment cost indices of 393.7 for May 

1992 and 433.0 for March 1998. 

We used these costs to estimate the costs for building wet out area enclosures at the other 

facilities by relating the estimated volumes of the wet out area enclosures at the KemliteSequentia facility to the estimated volume of the wet out area enclosures at the other facilities. 

We estimated the volumes of the enclosures using available data on the length and width of each 

continuous lamination and casting line. For some lines, we had to estimate these dimensions. 

We used an enclosure height of three-feet for each line. We then calculated the volume of each 

6-43 
P.52 

enclosure. At the Kemlite-Sequentia facility, we estimated each enclosure on the narrow lines to 

have a volume of 487.5 cubic feet and the enclosure on the wide line to have a volume of 1,116 

cubic feet. 

We then calculated the capital costs (1998$) of the wet area enclosures using the 

following formulas: 

For narrow lines: 

(volume of wet out area enclosure/487.5)0'

6

 x $11,433 x (433.0/393.7) 

where: $11,433 = the average cost of the three narrow line enclosures 

For wide lines: 

(volume of wet out area enclosure/1,116)0'

6

 x $23,000 x (433.0/393.7) 

We estimated annualized capital costs of the wet out area enclosures using a life 

expectancy of 30 years and an interest rate of 7 percent. We selected a life of 30 years based on 

the life expectancy of PTEs (see discussion below on permanent total enclosures). The resulting 

annual capitalization factor is 0.0806. 

We judged operating costs to consist solely of maintenance costs. We estimated 

• maintenance costs for each enclosure at a facility using 2 hours per week, 52 weeks per year, and 

$45.04 per hour labor rate (see Section 6.3.24). 

Table 6-22 summarizes the estimated volumes, capital costs, operating costs, and 

annualized costs for wet out area enclosures. We did not cost wet out area enclosures for 

Enduro, Ft. Worth and Krane Kemlite, Jonesboro, because these facilities have enclosures 

sufficient to meet both regulatory alternatives for existing sources and to meet the MACT floor 

and the regulatory alternative for new sources. For Intemational Paper, Odenton, additional 

control of the sheet line only is necessary, but a PTE is more likely to be constructed than to 

further enclose the wet out area with a wet out area enclosure. Thus, we did not cost a wet out 

area enclosure for the sheet line at International Paper's Odenton facility. 

6.3.20 Permanent Total Enclosures (PTEs) 

6-44 
P.53 

We costed PTEs for continuous lamination and casting operations, open molding 

operations (including manual resin application, mechanical resin application, filament winding, 

and gel coat application), pultrusion operations, SMC manufacturing operations, and mixing 

operations. In general, we costed PTEs for these operations by identifying the number and size 

of PTEs at each facility and then applying costing algorithms to each PTE. The costing 

algorithms used are found in Chapter 11 of the OAQPS Cost Manual (see Appendix 6.7). 

Table 6-23 summarizes the assumptions and costs used in estimating the costs of PTEs. 

In costing PTEs, we assumed that the type of material selected to construct each PTE was 

identical regardless of the process generating the emissions captured by the PTE. These 

materials are identified in Table 6-23. In addition, we assumed that each PTE would have the 

same types of safety equipment and instrumentation. 

The costs shown in Table 6-23 are in 1997$. We escalated these costs to 1998$ using the 

Chemical Engineering equipment cost indices for July 1997$ (434.2) and the July 1998$ (434.8), 

which yields an escalation factor of 1.006. 

We determined the number and size of PTEs at each facility for the reinforced plastic 

composites operations identified above. The total number of PTEs costed for any one facility 

was dependent on the number of these operations present at the facility. 

For continuous lamination and casting facilities, we assumed each line has its own PTE. 

Thus, for a facility with three continuous lamination lines, three PTEs were assumed to be 

constructed. In general, we sized each continuous lamination/casting PTE using the length ofthe 

wet out area, adding a total of 12 feet to the width of the wet out area, and a height of 8 feet. 

For the other operations, the size and dimensions of each PTE is dependent on the 

number, size, and shape of the equipment that must be used within the PTE, and the amount of 

6-45 
TABLE 6-22. DIMENSIONS AND COSTS FOR WET OUT AREA ENCLOSURES 

FOR CONTINUOUS LAMINATION AND CASTING OPERATIONS 

Company Location Line Identifier 

Width 

(ft) 

Length 

(ft) 

Height

 a 

(ft) 

Estimated 

Volume 

(ft3) 

May 1992$

 c 

Capital Costs 

($) 

1998$ 

Capital Costs 

($) 

Facilities that already have enclosures sufficient for complying with MACT floors and regulatory alternatives: 

Krane-Kemlite 

Krane-Kemlite 

Enduro 

International Paper 

International Paper 

Jonesboro 

Jonesboro 

Ft. Worth 

Odenton 

Odenton 

5w 

4n 

1 

Sheet 

Particle 

9.33 

5 

17 

3.33 

2 

90 

90 

52 

10 

10 

8 

8 

8 

3 

3 

6717.60 

3600.00 

7072.00 

99.90 

60.00 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

Facilities assumed to require installation of wet out area enclosures to comply with MACT floors or regulatory alternatives: 

Glasteel 

Kalwall 

Krane-Kemlite 

Krane-Kemlite 

Krane-Kemlite 

Kemlite-Sequentia 

Kemlite-Sequentia 

Kemlite-Sequentia 

Kemlite-Sequentia 

Lasco Panel Products 

Lasco Panel Products 

Lasco Panel Products 

Resolite 

W.H. Brady 

Collierville 

Bow 

Joilet 

Joilet 

Joilet 

Grand Junction 

Grand Junction 

Grand Junction 

Grand Junction 

Florence 

Florence 

Florence 

Zelienople 

Milwaukee 

ln 

ln 

LP-3n 

LP-6n 

LP-7n 

lw 

2n 

3n 

4n 

lw 

2n 

3n 

ln 

ln 

4 

5 

9 

9 

9 

9.3 

5 

5 

5 

9.3 

4 

4 

6.67 

4 

65 

19.1 

13 

13 

13 

40 

32.5 

32.5 

32.5 

43 

34 

34 

28 

45 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

780.00 

286.25 

351.00 

351.00 

351.00 

1116.00 

487.50 

487.50 

487.50 

1199.70 

408.00 

408.00 

560.00 

540.00 

15,158 

8,307 

9,388 

9,388 

9,388 

23,000 

8,300 

12,000 

14,000 

24,020 

10,275 

10,275 

12,425 

12,157 

16,671 

9,136 

10,325 

10,325 

10,325 

25,296 

9,129 

13,198 

15,398 

26,418 

11,300 

11,300 

13,665 

13,370 

1998$e 

Annualized 

Capital Costs 

($/yr) 

na 

na 

na 

na 

na 

1,344 

736 

832 

832 

832 

2,039 

736 

1,064 

1,241 

2,129 

911 

911 

1,101 

1,078 

1998$

 f 

Annual 

Operating 

Costs 

($/yr) 

na 

na 

na 

na 

na 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

4,684 

6-46 
Footnotes to Table 6-22 

Height of enclosure assumed to be 3 feet for all lines unless facility-specific data were provided. The height ofthe enclosures for Krane-Kemlite, Jonesboro, and Enduro reflect 

the height of existing permanent (total) enclosures. 

Width of line (not product width) x length of line (from resin laydown to oven entry) x height of enclosure. 

Kemlite-Sequentia: From October 27, 1998, telephone conversation with Mr. Carl Novak. Lasco, lw line: Based on line 1 w at Kemlite-Sequentia ratioing volumes to the 0.6 

power times $23,000. All other lines: Based on the average cost ofthe three other Kemlite-Sequentia costs (=$11,433) ratioing volumes to the 0.6 power times $11,433. 

d

 Escalated May 1992$ to 1998$ using CE equipment cost index of 393.7 for May 1992 and 433.0 for March 1998. 

Based on 7 percent interest rate and 30 year life, which yields a factor of 0.0806. 

f 

Based on 2 hours per week per line, 52 weeks per year, and a labor rate of $45.04 per hour. 

6-47 
TABLE 6-23. COST INFORMATION FOR SPECIHC EQUIPMENT AND STRUCTURAL COMPONENTS 

USED IN CONSTRUCTION OF PERMANENT TOTAL ENCLOSURES 

Equipment or 

Component Type 

Walls 

Doors 

Windows 

Ceiling 

Louvers 

LFL Detectors 

Safety Equipment 

Lighting 

Instrumentation 

Engineering 

Contractors 

Compliance Test 

Description of Specific Equipment 

Used in a PTE or Structural 

Comnonent of a PTE 

Modular Panel 

Mandoor, Hollow Steel, 3' x 7' 

Window, Lexan, 4' x 3' 

Drop Ceiling, Sheet Metal 

Catalytic Bead 

Alarm Bell 

Alarm Signal 

Fluorescent, 2'x4', four 40 watt 

Differential Pressure Monitor 

Units 

sqft 

Each 

Each 

sqft 

Each 

Each 

Each 

Each 

Each 

Each 

Each 

Each 

Materials 

(1997$) 

$9.76 

$575.00 

$85.00 

$1.69 

• 

$3,325.00 

$70.00 

$50.00 

$65.00 

$487.00 

Installation 

(1997$) 

$7.97 

$415.00 

$125.00 

$16.51 

$100.00 

$60.00 

$30.00 

$51.00 

$200.00 

Costing Assumptions and Considerations 

Modular panel for all PTEs; used estimated 

square footage for each PTE. 

2 mandoors, hollow steel for all PTEs; should 

require only personnel access to the interior. 

Lexan windows, 4'x3'; used one window 

roughly every 7.5 feet of PTE length with 

windows on both sides. 

Drop ceiling, sheet metal for all PTEs; used 

estimated square footage for each PTE. 

None. Assumed that natural draft opening 

would provide all air through the enclosure. 

Velocities through the NDOs range from 200 

to 400 feet per minute. 

2 catalytic bead monitors per PTE. 

One alarm bell and one alarm signal per PTE. 

Not required. 

Not required. 

Fluorescent, 2'x4', four 40 watt; one fixture per 

10 linear feet of wet out area. 

One differential pressure monitor, one surge 

dampener, and one alarm per PTE 

$15,000 per PTE. 

$2,500.00 per PTE. Applies only to PTE 

certification. 

6-48 
P.57 

materials that will be processed using this equipment. Table 6-24 presents the assumptions used 

to determine the number and size of PTEs at each facility using these other operations. 

6.3.21 Capture Devices for Centrifugal Casting Operations 

We calculated capital and annualized capital costs for capture devices for centrifugal 

casting operations by (1) determining the number of centrifugal casting machines at a facility, (2") 

determining the cost of the capture device per machine, and (3) multiplying the number of 

centrifugal casting machines by the cost per machine. 

We determined the total number of centrifugal casting machines at a facility by using the 

number reported in the industry screening survey. For facilities that did not report the number of 

centrifugal casting machines, we divided the resin used in centrifugal casting by the average resin 

usage per machine ratio of 42.67 to calculate the number of machines. This ratio of 42.67 was 

based data from facilities in the screening survey. 

We collected cost information for capture devices for centrifugal casting machines from 

Fibercast Company, which installed exhaust covers on the end of each of their 16 casting 

machines. The cost for exhaust covers for their 16 centrifugal casting machines was $22,710 in 

1992. We escalated the 1992$ capital costs to 1998$ by using the Chemical Engineering 

magazine average CE cost index of 389.5 for 1998 divided by the average CE cost index of 358.2 

for 1992, which yields an escalation factor of 1.087. The 1998$ capital cost for the 16 machines 

is thus estimated to be $24,686. 

We then calculated the capital cost for exhaust covers per machine by dividing the total 

cost of $24,686 by the number of casting machines ($24,686/16 = $1,543). We multiplied this 

value by the number of casting machines at a facility to estimate the total capital cost for 

installing capture devices on the centrifugal casting machines. 

Finally, we calculated the annualized capital costs by multiplying the total capital costs by 

a capital recovery cost factor of 0.0806, which is based on a 7 percent interest rate and a 30 year 

time period. 

6-49 
TABLE 6-24. FACILITY CRITERIA USED TO DETERMINE THE NUMBER AND SIZE OF PERMANENT TOTAL 

ENCLOSURES FOR OPERATIONS OTHER THAN CONTINUOUS LAMINATION AND CASTING 

Operation 

Open Molding Manual Resin Application 

-CR 

-Non CR 

-Tooling 

Mechanical Resin Application

 b 

-CR 

-Non CR (Unfilled) 

-Non CR (Filled) 

-Tooling 

Filament Winding (FW)

 b 

-CR 

-Non-CR 

Gel Coat Application

 Dc 

-Pigmented Production 

-Clear Production 

-Tooling 

Number 

ofPTE's 

1 

1 

1 

1 

Dimension Selection Criteria

 a 

Resin Usage = 0 to <3 tpy 

Resin Usage = 3 to <5 tpy 

Resin Usage = 5 to <10 tpy 

Resin Usage = 10 to <50 tpy 

Resin Usage = 50 to <200 tpy 

Resin Usage = 200 to <1000 tpy 

Resin Usage > 1000 tpy 

Resin Usage = 0 to <85 tpy 

Resin Usage = 85 to <300 tpy 

Resin Usage = 300 to <1000 tpy 

Resin Usage = 1000 to <5000 tpy 

Resin Usage > 5000 tpy 

Note: PTE Dimensions Based Only on 

Number of Filament Winding Machines. 

Gel Coat Usage = 0 to <50 tpy 

Gel Coat Usage = 50 to < 100 tpy 

Gel Coat Usage = 100 to <300 tpy 

Gel Coat Usage = 300 to <700 tpy 

Gel Coat Usage = 700 to <1500 tpy 

Gel Coat Usage > 1500 tpy 

Length 

(ft) 

10 

16 

24 

40 

50 

60 

75 

24 

56 

83 

86 

130 

PTE 

Area 

/50 ft 

20 

36 

46 

68 

46 

68 

Width 

(ft) 

10 

16 

24 

30 

36 

45 

50 

19 

24 

44 

56 

86 

50 

20 

19 

24 

24 

46 

46 

Height 

(ft) 

10 

10 

10 

12 

12 

12 

12 

10 

10 

10 

12 

12 

10 

10 

10 

10 

10 

10 

12 

Surface Area 

(sqft) 

600 

1,152 

2,112 

4,080 

5,664 

7,920 

10,500 

1,772 

4,288 

10,352 

13,040 

27,544 

#ofFW 

Machines x 

750 + 250 

1,600 

2,468 

3,608 

5,104 

6,072 

8,996 

6-50 
TABLE 6-24. FACILITY CRITERIA USED TO DETERMINE THE NUMBER AND SIZE OF PERMANENT TOTAL 

ENCLOSURES FOR OPERATIONS OTHER THAN CONTINUOUS LAMINATION AND CASTING 

(concluded) 

Operation 

Pultrusion 

SMC 

Manufacturing 

Mixing 

Not Applicable 

Not Applicable 

Not Applicable 

Number 

of PTE's 

1 

# of SMC 

Machines 

1 

Dimension Selection Criteria

 a 

# of Pultrusion Machines = 1 to 10 

# of Pultrusion Machines = 11 

# of Pultrusion Machines > 11 

Note: Dimensions Constant. Number of 

PTE's = Number SMC Machines 

Dimensions Constant. 

Length 

(ft) 

40 

82 

267 

55 

30 

Width 

(ft) 

22 + 12 

x (# - 1) 

100 

107 

24 

24 

Height 

(ft) 

8 

8 

8 

12 

14 

Surface Area 

(sqft) 

Depends 

on# 

19,312 

63,122 

4,536 

2,600 

One PTE was assumed to be used per operation rather than multiple PTE's being used for different operations. 

Resin or gel coat usage is the annual usage for this group of operations. 

Facilities applying gel coat (of any type) in conjunction with polymer casting were assumed to use a PTE with dimensions 14'x 18' x 10' = (1,144 sqft). 

6-51 
P.60 

6.3.22 Duct Work from Wet Area Enclosures and Permanent Total Enclosures to Add-On 

Control Devices 

Duct work is necessary to vent the captured emissions from PTEs, from centrifugal 

casting capture devices, from enclosures on continuous lamination and casting wet out areas, and 

from the continuous lamination and casting ovens to the control device. We used the cost 

algorithms based on Chapter 10, Hoods, Ductwork, and Stacks, OAQPS Control Cost Manual, 

5th Edition (Cost Manual). Table 6-25 summarizes basic assumptions and equations used in 

estimating duct work costs. This table shows the duct work cost components and the design 

equations for the duct work, the electricity costs, and the direct and indirect cost factors. We 

escalated the equipment costs reported in the Cost Manual, which are in 1993 dollars, to 1998 

dollars by using the annual average CE cost indexes. Appendix 6.8 contains pertinent pages 

from Chapter 10 of the Cost Manual. 

The cost of duct work is based on: (1) the flow rate of the gas stream being vented to the 

control device, (2) the length of duct work required, including the number of elbows, tees, and 

dampers, and (3) the type of material used to construct the duct work. Appendix 6 presents a 

summary of the flow rates, costs, duct diameters and lengths, and number of elbows, tees, and 

dampers used to estimate the duct costs for existing continuous lamination and casting sources 

and new continuous lamination and casting sources. 

Air Flow Rates 

In general, air flow rates are based on the mass of emissions captured, the operating hours 

per year of the source, and the concentration of the emissions. We calculated the flow rate of the 

gas stream out of a wet area enclosure, a centrifugal casting capture device, or a PTE to the 

control device using one of several methods as described below. 

We first calculated the air flow rates for each operation, except for ovens at continuous 

lamination and casting operations, using the following equation: 

Q = I * (454000 mg/lb) * 1/H * (1 hr/60 min) * (1 m3/4.326 mg) * (35.3 ft3/m3) * 1/C 

where: Q = air flow rate, cubic feet per minute 

I = emissions capture and vented to the control device, pounds per year 

H = operating hours per year 

C = concentration of emissions, parts per million by volume 

6-52 
TABLE 6-25. DUCT WORK COST INFORMATION AND DESIGN EQUATIONS 

Equation 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Parameter 

Calculated 

Duct Diameter 

(feet) 

Straight 

Ductwork ($/foot) 

Dampers 

($/damper) 

Elbows ($/elbow) 

Equipment Cost 

(1998 $) 

Purchased 

Equipment Cost 

(1998 $) 

Total Capital 

Investment 

(1998 $) 

Straight Duct 

Friction Loss per 

100 feet of Duct 

Length 

Curved Elbow 

Friction Loss 

Variable 

Dd 

SD 

D 

E 

EC 

PEC 

TCI 

Fd 

Fc 

Equation 

= 1.128 x[Qs/(Vx 60)]°5 

= 1.55x(DJ0936 

_ 4 5 ^ g 0.0597 x (Dili) 

_ 5 3 4e0.0633(Diii) 

= (SD + D + E) * EF 

= EC* 1.1 

= PEC* 1.61 

= 0.136 x (1/Dd)"8 x (V/1000)18 

= kf lx((Vx60)/4016) 2 

Additional Information 

Qs = Flow Rate of Gas Stream (scfm) 

V = Velocity of Gas Stream (feet per second) 

Dj,, = Duct Diameter, inches 

Galvanized Circular, Spiral-Wound Duct with 1-Inch 

Insulation 

Din = Duct Diameter, inches 

Double-wall "opposed-blade" butterfly dampener with 1-

inch fiberglass insulation.; galvanized carbon steel. 

Dj,, = Duct Diameter, inches 

Double-walled "gored" 90° elbows, galvanized carbon steel 

with one-inch insulation 

EF = Escalation Factor = 1998 CE Cost Index (389.5) / 

1993 CE Cost Index (359.2) 

EC = Equipment Cost (1998 $) 

PEC = Purchased Equipment Cost (1998 $) 

Dd = Duct Diameter, Feet 

V = Velocity of Gas Stream (feet per second) 

1^ = Friction Loss Factor 

V = Velocity of Gas Stream (feet per second) 

6-53 
TABLE 6-25. DUCT WORK COST INFORMATION AND DESIGN EQUATIONS 

(concluded) 

Equation 

Number 

10 

11 

12 

13 

14 

15 

Parameter 

Calculated 

Electricity Cost 

(1998 $/yr) 

Property Tax, 

Insurance, & 

Administration 

(1998 $/yr) 

Capital Recovery 

Cost Factor 

Annualized 

Capital Costs 

(1998 $/yr) 

Total Variable 

Annual Cost 

(1998 $/yr) 

Total Fixed 

Annual Cost 

(1998 $/vr) 

Variable 

EC 

PTIA 

CRC 

ACC 

AC(V) 

AC(F) 

Equation 

= (1.175 x IO"4) x Pc x Q„ x 

(Fd + Fc )xOf/E 

= TCI * 0.04 

= (0.07*(1.07)10)/((1.07)10-1) 

= TCI * CRC 

= EC 

= PTIA + ACC 

Additional Information 

Pc = Price of Electricity ($/kWh) = 0.0448 $/kWh 

Qa = Flow Rate of Gas Stream (AFCm). Note: assume Qa = 

Qs 

Fd = Straight Duct Friction Loss 

Fc = Curved Elbow Friction Loss 

Of = Operating Factor (hr/yr) = 6000 hr/yr 

E = Combined Fan Motor Efficiency = 0.6 

TCI = Total Capital Investment (1998 $) 

Assume 10 Year Period and 7% Interest Rate 

TCI = Total Capital Investment (1998 $) 

CRC = Capital Recovery Cost Factor 

EC = Electricity Cost (1998 $) 

PTIA = Property Tax, Insurance, & Administration 

(1998 $/yr) 

ACC = Annualized Capital Costs (1998 $/yr) 

6-54 
P.63 

Emissions. We calculated wet out area and oven emissions on a pound per hour basis 

from continuous lamination and casting operations using the estimated annual wet out area and 

oven emissions and operating hours per year for that line. We based operating hours for 

continuous lamination and casting operations on actual or estimated operating hours for 1997 for 

each line. The percent of the emissions from the wet out area captured varied between the 

MACT floor and the regulatory alternatives. We assumed oven emissions to be captured 100 

percent as the ovens are operated under negative pressure. 

Operating Hours. W estimated emissions on a pound per hour basis from centrifugal 

casting machines and other reinforced plastic operations using annual emission estimates and 

6,000 operating hours per year. We assumed emissions from centrifugal casting machines are 

captured 100 percent by their capture devices. In addition, we assumed emissions from all 

operations located inside PTEs are captured 100 percent based on the enclosure meeting EPA's 

five point criteria for a total enclosure. 

Concentrations. For continuous lamination and casting operations, we used a target 

concentration to the add-on control device, based on tests conducted at Lasco Panel Products and 

test data from Krane-Kemlite's Jonesboro facility, of 500 ppmv in estimating air flows from wet 

out area enclosures and, based on Enduro data and Krane-Kemlite's Jonesboro test data, 200 

ppmv for PTEs. For continuous casting, we used a target concentration, based on Fibercast data, 

of 3,500 pppv.. Actual concentrations used in the costing for PTEs vary for some continuous 

lamination and casting facilities because higher flow rates were used to ensure at least 15 air 

changes per hour in the PTE (see discussion below). 

For all other operations we used a concentration of 100 ppmv at the inlet to the control 

device. Actual data from operating facilities show that stack HAP concentrations range from 61 

to 249 ppmv with a mean of 120 ppmv. We choose 100 ppmv as a conservative estimate. The 

actual number comes for the current OSHA exposrue limits for styrene. Though the industry has 

agreed to a voluntary standard of 50 ppmv, the available data do not support using 50 ppmv as 

the concentration level expected at the inlet to a control device. 

Next, we calculated air flow rates for PTEs using the size of the natural draft openings 

(NDOs) in the PTE and a velocity of 200 feet per minute, which is the minimum velocity 

6-55 
P.64 

required specified in EPA's five-point criteria used to determine if an enclosure qualified as a 

total enclosure. The following equation was used: 

Q = NDO * 200/feet per minute 

where: Q = air flow rate, cubic feet per minute 

NDO = natural draft openings, square feet 

We calculated the size of the NDOs in a PTE using a percentage of the surface area of the 

PTE. Although the EPA's five-point criteria for total enclosures allows for NDOs of up to 5 

percent of the total surface area of the PTE, we found that reinforced plastic composite facilities 

with PTEs have much lower percentages. For PTEs on operations other than continuous 

lamination and casting, the EPA used a factor of 0.2 percent to calculate the NDOs. For 

continuous lamination and casting operations, we found one facility with a PTE to have NDOs 

representing approximately 1 percent of the total surface area of the PTE. Because other 

facilities may not be able to achieve this low percentage (due to the wide variation in 

configuration of continuous lamination and casting lines), we used 2 percent to calculate the 

NDOs for PTEs installed on the other continuous lamination and casting operations. 

Once we estimated these two air flow rates, we selected the larger of the two for costing 

purposes. Appendix 6.10 contains tables summarizing the air flow volumes calculated for the 

continuous lamination and casting facilities. 

For continuous lamination and casting PTEs, we also considered the number of air 

changes per hour to ensure proper engineering design. According to Chapter 11 of the OAQPS 

Cost Manual (see Appendix 6.7), 10 to 15 air changes per hour are generally considered 

necessary to provide adequate worker comfort within an enclosure. Based on this guidance, we 

used air flows in the costing that were at least equivalent to 15 air changes per hour. If either of 

the calculated air flows equated to air flows less than 15 air changes per hour, we used the air 

flow necessary to achieve 15 air changes per hour in the costing. 

For continuous lamination and casting ovens, we estimated air flows for each oven using 

oven air flow data obtained during the Lasco Panel Products source test. The data obtained 

showed an air flow rate of approximately 3,754 dry standard cubic feet per minute. We 

estimated the volume of the oven to be approximately 3,348 cubic feet. These values yield a 

factor of 1.1213 cubic feet of dry air flow per minute per cubic foot of oven volume. We 

6-56 
P.65 

estimated the oven volumes associated with the other continuous lamination and casting lines 

(see Table A6-11 in Appendix 6.10) and used the 1.1213 factor to estimate air flow out of the 

oven to the control device. We calculated the concentration of the air flow from the oven using 

this estimated air flow and the estimated oven emission rate, with the assumption that the only 

HAP in the air stream is styrene. The resulting estimated HAP concentrations ranged from 26 to 

331 ppm. 

Length of Duct and Number of Elbows, Tees, and Dampers 

Figures 1 through 7 in Appendix 6.11 illustrate the length of duct work and the number of 

dampers, elbows, and tees estimated for each continuous lamination and casting facility. In 

general, we used only major differences between configurations to develop facility- or linespecific duct work assumptions. These are shown in the figures. 

For operations other than continuous lamination and casting, we used the same set of 

parameters for each PTE located at the facility. In general, we used duct work components 

consisting of three separate sections of straight duct work, three 90° elbows, and one dampener. 

The straight duct work is comprised of two 15 foot long sections of ducting and one 75 foot long 

section of duct work. 

Electricitv Costs 

Electricity costs are incurred to move the air to through the duct work and to the control 

device. The cost of the electricity depends on the volume of air moved, friction loss, operating 

hours, and cost of electricity. We calculated the volume air moved as described above. We 

calculated straight duct and curved elbow friction losses using Equations 8 and 9 in Table 6-25. 

(These equations are taken from Chapter 10 of the Cost Manual, see Appendix 6.8.) 

In calculating these friction losses, we used velocity data obtained from the source test at 

Lasco Panel Products. For all operations, except the ovens at continuous lamination and casting 

operations, we used 38 feet per second as the velocity of the gas stream from the PTE or wet out 

area enclosure through the ductwork to the control device. For continuous lamination and 

casting ovens, we used a velocity of 33 feet per second. 

We also used the operating hours used to calculate the air flows, as discussed above, in 

estimating electricity costs. 

6-57 
P.66 

We calculated the electricity cost using costs reported by the Department of Energy. The 

industrial seven-month cost average (January through July 1998) was reported to be $0.0448 per 

kWh (see Appendix 6.12). 

6.3.23 Add-On Control Device Costing 

We selected specific costing information and equations associated with the installation 

and operation of add-on control devices from chapter 3 of the OAQPS Control Cost Manual and 

an EPA document titled "Assessment of Styrene Emission Controls for FRP/C and Boat Building 

Industries." Table 6-26 summarizes the equations used to calculate add-on control device 

parameters and costs. Appendix 6.13 presents two papers presenting additional information on 

the derivation of these costing algorithms. While there are a variety of different types of add-on 

control devices available, we assumed that all facilities would use a combined rotary concentrator 

and thermal oxidation system. Even though this particular type of add-on control device may not 

be the most cost effective device for all facilities, we made this assumption to simplify the 

costing analyses. 

The capital cost of the control device is primarily based on the flow and concentration to 

the control device. We summed the flows from each PTE and each capture device to determine 

the total flow to the control device. We estimated the HAP concentration in ppm vented to the 

control device using the sum of the emissions from each PTE/capture device in tpy, the facility 

operating hours per year, and the sum of the flows from each PTE/capture device in cfm. 

We calculated the control device equipment costs using Equation 5 of Table 6-26. We 

escalated the equipment costs, which are based on data collected from Durr in 1996 dollars, to 

1998 dollars by using the Vatavuk Air Pollution Control Indexes (see Appendix 6.14). 

We calculated the purchased equipment cost (PEC) in 1998 dollars using Equation 6 of 

Table 6-26. The PEC include costs for control device instrumentation, sales tax, and freight. We 

assumed that instrumentation costs are 10 percent of the control device equipment costs, sales tax 

are 5 percent of the control device equipment costs, and freight costs are 5 percent of the control 

device equipment costs. 

6-58 
TABLE 6-26. SPECIFIC EQUATIONS FOR ROTARY CONCENTRATOR/THERMAL 

OXIDIZER SYSTEM PARAMETERS AND COSTS 

Equation 

Number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Parameter Calculated 

Flow Rate (cfm) 

Concentration (ppm) 

Electrical Power (kW) 

Fuel Usage (BTU/hr) 

Rotary Concentrator 

and Thermal Oxidizer 

Equipment Cost (1998 

$) 

Purchased Equipment 

Cost (1998 $) 

Total Capital 

Investment (1998$) 

Direct Operating 

Costs, Excluding Fuel 

and Electricity Costs 

(1998 $/yr) 

Fuel Costs (1998 $/yr) 

Variable 

Q 

c 

EP 

FU 

EC 

PEC 

TCI 

DOC 

FC 

Equation 

= I * (2000 lb/ton) * (454000 mg/lb) * 1/H * 

(1 hr/60 min) * (1 m3/4.326 mg) * (35.3 ft3/m3) * 1/C 

= I * (2000 lb/ton) * (454000 mg/lb) * 1/H * (1 hr/60 min)* 

(35.3 ftVm3) * 1/Q * (1 m3/4.326 mg) 

= 3.019 + 0.00071 *Q 

If Q < 75000: = (0.001507 + 5.4E-05 * Q) * 1.0E+06 

If Q *> 75000: = 1080000 - 18330 * C 

= 97113 + 8.34098 * Q + 1.38246E-05 * Q2 

-4.866E-11*Q3*EF, 

= EC* 1.2 

= PEC * 1.61 + (5000 + (2.3 * Q)) 

= (4 hr/wk) * (52 wk/yr) * (45.04 $/l.OE+04 hr-cfm) * 1.15 * Q 

+ (4840 $/yr + 4190 $/yr + (0.25 $/yr-cfm) * Q) * EF2 

= (FU BTU/hr) * (3.24 S/1.0E+06 BTU) * H 

Comments 

I = Control Device Input Mass (tpy) 

H = 6000 operating hours per year for operations 

other than continuous lamination and casting. 

H = facility specific information for continuous 

lamination and casting operations 

EF, = Escalation Factor 

EF, = 1998 Vatavuk Air Pollution Control Index 

for Thermal Incinerators (110.5)/1996 Vatavuk 

Air pollution Control Index for Thermal 

Incinerators (108.2) 

EF2 = Escalation Factor 

EF2 = 1998 Vatavuk Air Pollution Control Index 

for Thermal Incinerators (110.5)/1995 Vatavuk 

Air pollution Control Index for Thermal 

Incinerators (105.9) 

H = 6000 operating hours per year for operations 

other than continuous lamination and casting. 

H = facility specific information for continuous 

lamination and casting operations 

6-59 
TABLE 6-26. SPECIFIC EQUATIONS FOR ROTARY CONCENTRATOR/THERMAL 

OXIDIZER SYSTEM PARAMETERS AND COSTS 

(concluded) 

Equation 

Number 

10 

11 

12 

13 

14 

15 

Parameter Calculated 

Electric Cost (1998 

$/yr) 

Overhead, Property 

Tax, Insurance, and 

Administration 

(1998 $/yr) 

Capital Recovery Cost 

Factor 

Annualized Capital 

Costs (1998 $/yr) 

Total Variable Annual 

Cost (1998 $/yr) 

Total Fixed Annual 

Cost (1998 $/vr) 

Variable 

ELC 

OPTIA 

CRC 

ACC 

AC(V) 

AC(F) 

Equation 

= H * EP * 0.0448 $/kWh 

= (DOC * 0.6) + (TCI * 0.04) 

= (0.07* (1.07)'°)/((1.07)10-1) 

= TCI * CRC 

= DOC + (Fuel Costs $/yr) + (Electric Cost $/yr) 

= OPTIA + ACC 

Comments 

H = 6000 operating hours per year for operations 

other than continuous lamination and casting. 

H = facility specific information for continuous 

lamination and casting operations 

Rates are from Chapter 3, Thermal and Catalytic 

Incinerators, OAQPS Control Cost Manual, 5th 

Edition, EPA 453/B-96-001. February 1996. 

Page 3-52. 

7 percent for 10 years. 

6-60 
P.69 

We calculated the total capital investment for the control device using the OAQPS Cost 

Manual as shown in Equation 7 of Table 6-26. This equation calculates the total direct costs 

based on PEC, site preparation costs, and cost of buildings to house the control device. 

We assumed that the site preparation cost are $5,000 plus $2.3 per cfm of flow and that the cost 

of buildings to house control devices are zero because all control devices were assumed to be 

outdoors. 

We calculated the direct operating costs excluding fuel and electricity costs using 

Equation 8 of Table 6-26. This equation estimates the maintenance costs associated with the 

operation of the control device. We based maintenance costs on 4 hours per week, 52 weeks per 

year, at a labor rate of $45.04 per hour for each 10,000 cfm of the control system. We added an 

additional 15 percent for supervisory cost. We assumed an annual maintenance contract of 

$4,840 for each control device. We also included additional costs, such as costs for media 

replacement, in the direct operating cost calculation. 

The labor rate used to calculate the direct operating cost is already in 1998 dollars. We 

escalated the non-labor related direct operating costs, which are based on July 1995 data, to 1998 

dollars using the Vatavuk Air Pollution Control Indexes. 

We calculated the fuel costs for the control device using Equation 9 of Table 6-26. The 

fuel cost is the product of the fuel usage (see Equation 4), the annual operating hours, and the 

fuel cost. We based the fuel cost on natural gas costs reported by the Department of Energy (see 

Appendix 6.12). The industrial six-month cost average (January through June 1998) for natural 

gas was reported to be $3.24 per 1,000 standard cubic feet (scfm). This is equivalent to 

approximately $3.24 per million BTU. 

We calculated the electricity costs for the control device using Equation 10 in Table 6-26. 

The electricity cost is the product of the electrical power consumed (see Equation 5), the annual 

operating hours, and the electricity cost. We based the electricity cost on costs reported by the 

Department ofEnergy (see Appendix 6.12). The industrial seven-month cost average (January 

through July 1998) was reported to be $0.0448 per kWh. 

We calculated overhead, property tax, insurance, and administration cost using Equation 

11 of Table 6-26. We calculated the overhead cost based on 60 percent of the direct operating 

6-61 
P.70 

cost and the property tax, insurance, and administration cost based on 4 percent of the total 

capital investment. We derived these percentages from the OAQPS Control Cost Manual. 

We calculated the capital recovery cost factor using a 7 percent interest rate and a 10 year 

time period. We then calculated the annualized capital cost by multiplying the total capital 

investment by the capital recovery cost factor. Next, we calculated the total variable annual cost 

by summing the direct operating costs, the fuel cost, and the electric cost. Finally, we calculated 

the total fixed annual cost by summing the overhead, property tax, insurance, and administration 

cost, and the annualized capital costs. 

6.3.24 Monitoring, Recordkeeping, and Reporting 

Table 6-27 summarizes the monitoring, recordkeeping, and reporting (MRR) 

requirements associated with complying with the proposed rule. We used the estimated hours 

and costs for MRR tasks based on data developed for other standards and from the Emission 

Standards Division (ESD) Procedures Manual.34 For those MRR tasks for which no hour 

estimates were available, we made assumptions to estimate the MRR hours. 

As seen in Table 6-27, we identified six MRR categories: (1) reading rule, (2) 

performance tests and other requirements for facilities complying by using an add-on control 

device, (3) employee training, (4) subpart A notifications, (5) percent HAP monomer records for 

open molding and centrifugal casting operations and records for other pollution prevention 

techniques used in open molding, and (6) developing a record system. We developed 

information for each of these six categories for: (1) applicability (e.g., existing facilities, new 

facilities, facilities with control devices, etc.), (2) first year hours, (3) annual hours, and (4) 

assumptions. 

We determined the total first year MRR hours and the total annual MRR hours on a 

facility basis (based on applicability) for all activities listed in Table 6-27. The EPA then 

determined the first year MRR hours and the annual MRR hours for each process within a group 

of operations (based on applicability) for each activity. 

Once we estimated the number of hours, we calculated the cost by applying the wage 

rates developed for the Architectural Coatings Information Collection Request (ICR) (see 

Table 6-28). 

6-62 
TABLE 6-27. MRR INFORMATION BY ACTIVITY 

MRR Category 

Read rule 

Performance tests 

and other 

requirements for 

facilities with addon controls 

Activity 

Read promulgated rule 

and Subpart A, General 

Provisions 

Initial performance test -

Control device efficiency 

Initial performance test -

Capture efficiency 

Notification of initial 

performance test 

Report of initial 

performance test 

Development of operation 

and maintenance plan 

Development of startup, 

shutdown, and 

malfunction (SSM) plan 

Records and reports of 

SSM and corrective 

measures taken 

Applicability 

All existing and new 

facilities 

Facilities complying by 

using control devices that 

have not done testing 

Facilities complying by 

using control devices that 

have not done testing 

Facilities complying by 

using control devices 

Facilities complying by 

using control devices 

Facilities complying by 

using control devices 

Facilities complying by 

using control devices 

Facilities complying by 

using control devices 

First Year Hours 

8 hours per facility plus 1 

additional hour per each 

group of operations at the 

facility 

280 hours per facility 

40 hours per facility 

2 hours per facility 

Included in performance 

test hours 

40 hours per facility 

20 hours per facility 

2 hours per facility 

Annual Hours 

1 hour per facility 

None 

None 

None 

None 

None 

None 

2 hours per facility 

Assumptions 

Reading rule and Subpart A will 

be necessary for compliance 

Facilities that already conducted 

destruction efficiency testing 

according to EPA requirements 

do not have to retest 

Facilities that already conducted 

capture efficiency testing 

according to EPA requirements 

do not have to retest 

Does not apply to facilities that 

already demonstrated 

destruction and capture 

efficiency 

Does not apply to facilities that 

already demonstrated 

destruction and capture 

efficiency 

None 

None 

SSM report hours are covered 

under reports of accedences and 

periods of noncompliance 

6-63 
TABLE 6-27. MRR INFORMATION BY ACTIVITY 

(continued) 

MRR Category 

Employee training 

Employee Training 

(continued) 

Subpart A 

notifications 

Subpart A 

notifications 

(concluded) 

Activity 

Development of operator 

training course 

Time to train personnel 

Records of operators 

completing operator 

training course 

Notification of 

construction and 

reconstruction 

Notification of anticipated 

startup 

Notification of actual 

startup 

Notification of compliance 

status 

Semiannual report -

Compliance certification 

Applicability 

Facilities with work 

practice requirements 

All facilities 

All facilities 

New facilities 

New facilities 

New facilities 

All facilities 

All facilities 

First Year Hours 

8 hours for work practices 

and 24 hours for spray 

training 

Small Facilities: 

2 hours for work practices 

and 4 for spray training 

Medium Facilities: 

4 hours for Work practices 

and 8 for spray training 

Large Facilities: 

8 hours for Work practices 

and 16 for spray training 

2 hours per facility 

2 hours per facility

 Ret 37 

2 hours per facility

 Ket 37 

2 hours per facility

 Ret 37 

4 hours per facility

 Ret 37 

8 hours per facility

 Ref37 

Annual Hours 

None 

None 

2 hours 

None 

None 

None 

None 

16 hours per facility 

(8 hours X 2) 14 

Assumptions 

Training hours are incremental 

hours between current level 

training and MACT level 

training 

Training new employees based 

on requirements in the standard 

does not take more time than 

training new employees without 

MACT standard in place 

Small -s 100 Employees 

Medium > 100-s 250 

Employees 

Large > 250 Employees 

None 

No reconstruction will occur at 

existing facilities 

No reconstruction will occur at 

existing facilities 

No reconstruction will occur at 

existing facilities 

None 

Only one semiannual report is 

submitted in the first year plus 

the Notification of compliance 

status 

6-64 
TABLE 6-27. MRR INFORMATION BY ACTIVITY 

(continued) 

MRR Category 

Percent HAP 

monomer and 

pollution 

prevention records 

Develop record 

system 

Activity 

Semiannual report -

Periods of noncompliance 

and methods used to attain 

compliance 

Records of HAP percent 

and weighted average 

HAP concentration 

calculations and records of 

other pollution prevention 

techniques 

Develop record system 

Applicability 

All facilities with periods 

of noncompliance 

Open Molding and 

Centrifugal Casting 

facilities 

All facilities 

First Year Hours 

16 hours per facility 

12 hours per facility 

Work practices: 1 hour 

HAP content and other 

pollution prevention 

measures: 5 hours 

Control devices: 2 hours 

Annual Hours 

32 hours per facility 

(16 hours X 2) 14 

12 hours per facility 

None 

Assumptions 

20 Percent of facilities will have 

some periods of noncompliance 

and 80 percent will not have an> 

periods of noncompliance 

None 

None 

6-65 
P.74 

TABLE 6-28. WAGE RATES 38 

Labor Class 

Clerical 

Technical 

Management 

Base Labor Rate from 

Bureau of Labor Statistics 

(BLS) ($/hr) 

11.95 

18.86 

28.54 

Fringe Benefit Loading 

Rate from BLS 

1.41 

1.43 

1.40 

Overhead and Profit 

Rate 

1.67 

1.67 

1.67 

"Loaded" Wage Rate 

($/hr) 

28.14 

45.04 

66.73 

In calculating the MRR costs, we assumed that all of the MRR work is performed by 

managerial staff with one hour of clerical support for every eight hours of managerial work. For 

example, if 280 hours are estimated for a given activity, we assumed that 280 hours are spent as 

managerial hours and 35 hours (280/8 = 35) are spent as clerical hours. This assumption 

probably over-estimates the cost impact of the rule's MRR requirements for some facilities 

because at some facilities some ofthe work will be performed by technical rather than 

managerial staff. 

For each operations group at a facility, we determined the first year MRR costs by 

multiplying the first year management and clerical hours by the associated labor rate for that 

MRR category, $66.73 and $ 28.14 per hour, respectively. Then, we determined the annual 

MRR costs for each operations group by multiplying the annual management and clerical hours 

by the associated labor rate for that MRR category, $66.73 and $ 28.14 per hour, respectively. 

We annualized the first year MRR costs for each operations group at a facility over a ten 

year period using a seven percent interest rate. We then summed the annualized first year MRR 

costs and annual MRR costs for each operations group at a facility to obtain the total annual 

MRR costs for the facility. For each operations group with multiple individual operations at a 

facility (e.g., open molding with manual corrosion resistant resins, mechanical corrosion resistant 

resins, filament winding), we divided the annual MRR cost for that operations group equally 

among the each ofindividual operations within that operations group conducted at the facility. 

6-66 
P.75 

6.4 RESULTS OF THE COST IMPACTS ANALYSIS 

As previously discussed, two control levels were costed for each new and existing 

facility. These are the floor level of control, and he above the floor option. Based on these 

control levels we developed three regulatory alternatives. These are as follows. 

• Regulatory Alternative 1 - All new and existing facilities are required to meet the applicable 

floor level of control. 

• Regulatory Alternative 2 - All new and existing facilities with combined emissions of HAP 

of 100 tons per year (TPY) or more from the following operations: open molding, centrifugal 

casting, continuous lamination/casting, pultrusion, SMC manufacturing, and BMC 

manufacturing/mixing are required to meet the above-the-floor control level. All other 

facilities must meet the floor level of control. 

• Regulatory Option 3 - All new and existing facilities must meet the above-the-floor control 

level. 

Tables 6-29 and 6-30 summarize the total capital and annual costs for existing and new 

sources for Regulatory Alternative 1. As seen in these tables, the annual costs for this alternative 

for existing and new sources is approximately 24 million dollars per year and approximately 36 

million dollars per year, respectively. The total annual cost would be approximately 60 million 

dollars per year. 

Tables 6-31 and 6-32 summarize the total capital and annual costs for existing and new 

sources for Regulatory Alternative 2. As seen in these tables, the annual costs associated with 

this alternative for existing and new sources is approximately 35 million dollars per year and 

approximately 37 million dollars per year, respectively. The total annual cost would be 

approximately 72 million dollars per year. 

Tables 6-33 and 6-34 summarize the total capital and annual costs for existing and new 

sources For Regulatory Alternative 3. As seen in these tables, the annual costs associated with 

6-67 
P.76 

this alternative are approximately 67 million dollars per year and approximately 66 million 

dollars per year, respectively. The total annual cost would be approximately 133 million dollars 

per year. 

6.5 COST EFFECTIVENESS OF REGULATORY ALTERNATIVES 

The incremental cost effectiveness of Regulatory Alternatives 2 and 3 are determined by 

dividing the difference in their annual costs compared to Regulatory Alternative 1 by the 

difference in the emission reduction. We calculated the cost effectiveness for both above-the 

floor Regulatory Alternatives for each applicable group of operations and the source category. 

Tables 6-35 and 6-36 summarize the cost effectiveness of Regulatory Alternative 2 for new and 

existing sources, respectively. Tables 6-37 and 6-38 summarize the cost effectiveness for 

Regulatory Alternative 3. 

6-68 
P.77 

TABLE 6-29. REGULATORY ALTERNATIVE 1 COSTS FOR EXISTING SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$8,514,382 

$24,581 

$34,975 

$2,186,848 

$18,258 

$166,630 

$5,465 

$265,782 

$186,824 

$231,502 

$11,635,248 

AVC 

(1998$/yr) 

$19,506,299 

$0 

$306,629 

$171,972 

$0 

$156,285 

$0 

$0 

$0 

$0 

$20,141,185 

AFC 

(1998$/yr) 

$1,743,172 

$66,446 

$13,260 

$428,789 

$44,788 

$33,962 

$13,648 

$367,599 

$531,730 

$326,133 

$3,569,527 

AVC + AFC 

(1998$/yr) 

$21,249,471 

$66,446 

$319,889 

$600,761 

$44,788 

$190,247 

$13,648 

$367,599 

$531,730 

$326,133 

$23,710,712 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

TABLE 6-30. REGULATORY ALTERNATIVE 1 COSTS FOR NEW SOURCES

 a 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$39,369,283 

$1,361 

$73,136 

$606,715 

$55,688 

$50,377,160 

$417,024 

$43,128 

$65,246,245 

$42,759 

$156,232,499 

AVC 

(1998$/yr) 

$2,630,302 

$0 

$212,465 

$62,462 

$0 

$2,296,484 

$18,100 

$0 

$2,491,688 

$0 

$7,740,651 

AFC 

(1998$/yr) 

$8,488,081 

$3,393 

$15,329 

$116,133 

$136,371 

$8,136,496 

$67,699 

$59,596 

$10,988,377 

$59,099 

$28,070,543 

AVC + AFC 

(1998$/yr) 

$11,118,383 

$3,393 

$227,794 

$178,594 

$136,371 

$10,462,129 

$85,769 

$59,596 

$13,480,066 

$59,099 

$35,811,194 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

6-69 
P.78 

TABLE 6-31. REGULATORY ALTERNATIVE 2 COSTS FOR EXISTING SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$85,967,921 

$24,581 

$996,061 

$3,954,242 

$18,258 

$3,744,695 

$5,465 

$265,782 

$4,639,281 

$231,502 

$99,842,789 

AVC 

(1998$/yr) 

$14,728,096 

$0 

$97,676 

$406,259 

$0 

$271,341 

$0 

$0 

$78,829 

$0 

$15,582,199 

AFC 

(1998$/yr) 

$16,475,385 

$66,446 

$205,447 

$755,570 

$44,788 

$542,788 

$13,648 

$368,196 

$986,499 

$326,730 

$19,785,498 

AVC + AFC 

(1998$/yr) 

$31,203,481 

$66,446 

$303,123 

$1,161,829 

$44,788 

$814,129 

$13,648 

$368,196 

$1,065,327 

$326,730 

$35,367,697 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

TABLE 6-32. REGULATORY ALTERNATIVE 2 COSTS FOR NEW SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$49,894,054 

$1,361 

$782,781 

$904,503 

$55,688 

$50,377,160 

$417,024 

$43,128 

$64,447,334 

$42,759 

$166,965,793 

AVC 

(1998$/yr) 

$2,757,389 

$0 

$91,589 

$95,700 

$0 

$2,235,633 

$18,100 

$0 

$2,440,847 

$0 

$7,729,258 

AFC 

(1998$/yr) 

$10,113,864 

$3,393 

$159,048 

$150,834 

$136,371 

$8,136,496 

$67,669 

$59,641 

$10,818,307 

$59,144 

$29,704,766 

AVC + AFC 

(1998$/yr) 

$12,871,252 

$3,393 

$250,637 

$246,535 

$136,371 

$10,462,129 

$85,769 

$59,641 

$13,259,153 

$59,144 

$37,434,024 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

6-70 
P.79 

TABLE 6-33. REGULATORY ALTERNATIVE 3 COSTS FOR EXISTING SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$237,457,540 

$24,581 

$1,931,743 

$5,565,694 

$18,258 

$17,470,185 

$7,722,530 

$265,782 

$36,842,574 

$231,502 

$307,530,389 

AVC 

(1998$/yr) 

$12,777,228 

$0 

$125,607 

$561,286 

$0 

$870,043 

$424,898 

$0 

$569,467 

$0 

$15,328,530 

AFC 

(1998$/yr) 

$40,582,719 

$66,446 

$398,407 

$1,063,823 

$44,788 

$2,774,751 

$1,372,417 

$372,294 

$4,658,328 

$330,828 

$51,664,801 

AVC + AFC 

(1998$/yr) 

$53,359,947 

$66,446 

$524,015 

$1,625,109 

$44,788 

$3,644,794 

$1,797,315 

$372,294 

$5,227,795 

$330,828 

$66,993,331 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

TABLE 6-34. REGULATORY ALTERNATIVE 3 COSTS FOR NEW SOURCES 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

TCC 

(1998$) 

$245,598,477 

$1,361 

$1,270,512 

$965,090 

$55,688 

$49,649,834 

$421,290 

$43,128 

$34,800,786 

$42,759 

$332,848,349 

AVC 

(1998$/yr) 

$9,866,451 

$0 

$75,143 

$106,958 

$0 

$2,247,737 

$18,826 

$0 

$608,319 

$0 

$12,923,435 

AFC 

(1998$/vr) 

$40,089,651 

$3,393 

$260,954 

$170,708 

$136,371 

$7,976,547 

$68,650 

$60,225 

$4,513,964 

$59,728 

$53,340,192 

AVC + AFC 

(1998$/yr) 

$49,956,103 

$3,393 

$336,098 

$277,666 

$136,371 

$10,224,284 

$87,477 

$60,225 

$5,122,283 

$59,728 

$66,263,627 

TCC, AVC, AFC are the abbreviations for Total Capital Cost, Annual Variable Cost, and Annual Fixed Cost, respectively. 

6-71 
TABLE 6-35. COST EFFECTIVENESS OF REGULATORY ALTERNATIVE 2 FOR EXISTING SOURCES a, b 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

Regulatory Alternative 1 

(MACT Floor) 

Total 

Cost 

($/vr) 

$21,249,471 

$66,446 

$319,889 

$600,761 

$44,788 

$190,247 

$13,648 

$367,599 

$531,730 

$326,133 

$23,710,712 

Emission 

Reduction 

(tons/yr) 

7056.4 

0.0 

44.0 

360.6 

0.0 

228.1 

0.0 

807.1 

153.3 

0.0 

8649.5 

Regulatory Alternative 2 

Total 

Cost 

($/yr) 

$31,203,481 

$66,446 

$303,123 

$1,161,829 

$44,788 

$814,129 

$13,648 

$368,196 

$1,065,327 

$326,730 

$35,367,697 

Emission 

Reduction 

(tons/yr) 

13625.2 

0.0 

859.6 

580.8 

0.0 

348.2 

0.0 

807.1 

292.3 

0.0 

16513.2 

Incremental 

Total 

Cost 

($/vr) 

$9,954,010 

$0 

($16,767) 

$561,068 

$0 

$623,882 

$0 

$597 

$533,597 

$597 

$11,656,985 

Emission 

Reduction 

(tons/yr) 

6568.7 

0.0 

815.5 

220.2 

0.0 

120.1 

0.0 

0.0 

139.0 

0.0 

7863.5 

Average Cost 

Effectiveness 

($/ton) 

$1,515 

N/A 

($21) 

$2,548 

N/A 

$5,916 

N/A 

N/A 

$3,482 

N/A 

$1,482 

a

 This table presents cost effectiveness values for groups of operations and the source category if the proposed rule requires all existing facilities with 

uncontrolled HAP emissions greater than or equal to 100 tpy to implement the above-the-floor control option of 95% control for the following groups of 

operations: open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, and BMC manufacturing/mixing. 

The average cost effectiveness of the regulatory option for each group of operations and the source category is determined using the following formula: 

Cost Effectiveness (S/ton) = 

Annual Cost of Regulatory Option (S) - Annual Cost of MACT Floor (S) 

Emission Reduction of Regulatory Option (tons) - Emission Reduction of MACT Floor (tons) 

6-12 
TABLE 6-36. COST EFFECTIVENESS OF REGULATORY ALTERNATIVE 2 FOR NEW SOURCES

 a a,b 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

Regulatory Alternative 1 

(MACT Floor) 

Total 

Cost 

($/vr) 

$11,118,383 

$3,393 

$227,794 

$178,594 

$136,371 

$10,462,129 

$85,769 

$59,596 

$13,480,066 

$59,099 

$35,811,194 

Emission 

Reduction 

(tons/vr) 

277.2 

0.0 

101.6 

215.7 

0.0 

760.0 

7.3 

0.0 

133.6 

0.0 

1495.4 

Regulatory Alterntive 2 

Total 

Cost 

($/vr) 

$12,871,252 

$3,393 

$250,637 

$246,535 

$136,371 

$10,462,129 

$85,769 

$59,641 

$13,259,153 

$59,144 

$37,434,024 

Emission 

Reduction 

(tons/yr) 

497.4 

0.0 

655.0 

243.6 

0.0 

760.0 

7.3 

0.0 

133.6 

0.0 

2297.0 

Incremental 

Total 

Cost 

($/vr) 

$1,752,869 

$0 

$22,843 

$67,940 

$0 

$0 

$0 

$45 

($220,913) 

$45 

$1,622,830 

Emission 

Reduction 

(tons/yr) 

220.2 

0.0 

553.5 

27.9 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

801.6 

Average Cost 

Effectiveness 

($/ton) 

$7,960 

N/A 

$41 

$2,435 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

$2,024 

a

 This table presents cost effectiveness values for groups of operations and the source category if the proposed rule requires all existing facilities with 

uncontrolled HAP emissions greater than or equal to 100 tpy to implement the above-the-floor control option of 95% control for the following groups of 

operations: open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, and BMC manufacturing/mixing. 

The average cost effectiveness of the regulatory option for each group of operations and the source category is determined using the following formula: 

Cost Effectiveness (S/ton) = 

Annual Cost of Regulatory Option (S) - Annual Cost of MACT Floor ($) 

Emission Reduction of Regulatory Option (tons) - Emission Reduction of MACT Floor (tons) 

6-73 
TABLE 6-37. COST EFFECTIVENESS OF REGULATORY ALTERNATIVE 3 FOR EXISTING SOURCES a,b 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

Regulatory Alternative 1 

(MACT Floor) 

Total 

Cost 

($/vr) 

$21,249,471 

$66,446 

$319,889 

$600,761 

$44,788 

$190,247 

$13,648 

$367,599 

$531,730 

$326,133 

$23,710,712 

Emission 

Reduction 

(tons/yr) 

7056.4 

0.0 

44.0 

360.6 

0.0 

228.1 

0.0 

807.1 

153.3 

0.0 

8649.5 

Regulatory Alternatvie 3 

Total 

Cost 

($/vr) 

$53,359,947 

$66,446 

$524,015 

$1,625,109 

$44,788 

$3,644,794 

$1,797,315 

$372,294 

$5,227,795 

$330,828 

$66,993,331 

Emission 

Reduction 

(tons/yr) 

16898.3 

0.0 

1001.1 

683.5 

0.0 

466.3 

338.6 

807.1 

421.7 

0.0 

20616.6 

Incremental 

Total 

Cost 

($/vr) 

$32,110,477 

$0 

$204,125 

$1,024,348 

$0 

$3,454,547 

$1,783,667 

$4,695 

$4,696,065 

$4,695 

$43,282,619 

Emission 

Reduction 

(tons/yr) 

9481.8 

0.0 

957.0 

317.6 

0.0 

238.2 

338.6 

0.0 

268.4 

0.0 

11967.1 

Average Cost 

Effectiveness 

($/ton) 

$3,263 

N/A 

$213 

$3,226 

N/A 

$14,505 

$5,268 

N/A 

$17,495 

N/A 

$3,617 

a

 This table presents cost effectiveness values for groups of operations assuming that the proposed rule requires all existing facilities to implement the 

above-the-floor control option of 95% control for the following groups of operations: open molding, centrifugal casting, continuous lamination/casting, 

pultrusion, SMC manufacturing, and BMC manufacturing/mixing. 

The average cost effectiveness of the regulatory option for each group of operations and the source category is determined using the following formula: 

Cost Effectiveness (S/ton) Annual Cost of Regulatory Option ($) - Annual Cost of MACT Floor ($) 

Emission Reduction of Regulatory Option (tons) - Emission Reduction of MACT Floor (tons) 

6-74 
TABLE 6-38. COST EFFECTIVENESS OF REGULATORY ALTERNATIVE 3 FOR NEW SOURCES

 a b 

Group of Operations 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination / Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Equipment Cleaning 

BMC Manufacturing / Mixing 

Storage of HAP Containing Mat'ls 

Totals for the Source Category 

Regulatory Alternative 1 

(MACT Floor) 

Total 

Cost 

($/vr) 

$11,118,383 

$3,393 

$227,794 

$178,594 

$136,371 

$10,462,129 

$85,769 

$59,596 

$13,480,066 

$59,099 

$35,811,194 

Emission 

Reduction 

(tons/vr) 

277.2 

0.0 

101.6 

215.7 

0.0 

760.0 

7.3 

0.0 

133.6 

0.0 

1495.4 

Regulatory Alternative 3 

Total 

Cost 

($/vr) 

$49,956,103 

$3,393 

$336,098 

$277,666 

$136,371 

$10,224,284 

$87,477 

$60,255 

$5,122,283 

$59,728 

$66,263,627 

Emission 

Reduction 

(tons/yr) 

759.0 

0.0 

733.8 

248.1 

0.0 

760.0 

7.3 

0.0 

133.6 

0.0 

2641.9 

Incremental 

Total 

Cost 

($/vr) 

$38,837,719 

$0 

$108,304 

$99,072 

$0 

($237,845) 

$1,707 

$629 

($8,357,783) 

$629 

$30,452,433 

Emission 

Reduction 

(tons/yr) 

481.9 

0.0 

632.2 

32.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

1146.5 

Average Cost 

Effectiveness 

($/ton) 

$80,599 

N/A 

$171 

$3,058 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

$26,561 

a

 This table presents cost effectiveness values for groups of operations assuming that the proposed rule requires all existing facilities to implement the above-thefloor control option of 95% control for the following groups of operations: open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC 

manufacturing, and BMC manufacturing/mixing. 

b

 The average cost effectiveness of the regulatory option for each group of operations and the source category is determined using the following formula: 

Cost Effectiveness (S/ton) = 

Annual Cost of Regulatory Option ($) - Annual Cost of MACT Floor ($) 

Emission Reduction of Regulatory Option (tons) - Emission Reduction of MACT Floor (tons) 

6-75 

oo 
P.84 

6.6 REFERENCES 

1 Letter from Grotke, M., Alpha Owens Corning (AOC) to Strum, M., EPA/ESD. May 1, 

1998. lp . 

2 Letter from Brody, B.G., Ashland Chemical Company, to Strum, M., EPA/ESD. May 7, 

1998. Response to request for cost information for corrosion resistant resins 

produced by Ashland Chemical Company. 2 pp. 

3 Ashland Chemical Company. HETRON® and AROPOLTM Resin Selection Guide for 

Corrosion Resistant FRP Applications. 1997. 47 pp. 

4 Letter from Craigie, L.J., Dow Chemical Company, to Strum, M., EPA/ESD. April 27, 1998. 

1 p. Response to request for cost information for corrosion resistant resins produced by Dow 

Chemical Company. 

5 Dow Chemical Company. DERAKANE Epoxy Vinyl Ester Resins: Chemical Resistance and 

Engineering Guide. October 1995. 40 pp. 

6 Dow Chemical Company. DERAKANE Epoxy Vinyl Ester Resins: Technical Product 

Information. March 1996. 16 pp. 

7 Letter from Herzog, D.J., Interplastic Corporation, to Jemison, R.M., Pacific Environmental 

Services, Inc. August 17, 1998. 1 p. Response to request for cost information for corrosion 

resistant resins produced by Interplastic Corporation. Docket No. U-D-813 

8 Interplastic Corporation. CoREZYN® Vinyl Ester Resins. 1996. 33 pp. 

9 Interplastic Corporation. CoREZYN® Isophthalic Corrosion Resistant Resins. 1998. 10 pp. 

10 Facsimile from Helpler, A., Reichhold, to Strum, M., EPA/ESD. June 1, 1998. 11 pp. 

Response to request for cost and HAP content information for corrosion resistant resins 

produced by Reichhold. 

11 Reichhold. Atlac® and Dion®: Corrosion Resin Selection and Design Guide. 1996. 44 pp. 

12 ERG. Daft Cost Procedures Documentation Memorandum for Boat MACT Standard. April 

16,1999. pp 3 -7. 

13 Letter from Hollenbeck, M., Cook Composites & Polymers, to Proctor, M.S., Pacific 

Environmental Services, Inc. August 26,1998. Response to request for cost and properties 

information for pigmented production, clear production, and tooling gel coats 

produced by Cook Composites & Polymers. 2 pp. 

6-76 
P.85 

14 Facsimile from Nissila, P., Neste Polyester America, to Proctor, M.S., Pacific 

Environmental Services, Inc. November 6, 1998. Response to request for cost and 

properties information for pigmented production, clear production, and tooling gel coats 

produced by Neste Polyester America. 4 pp. 

15 Facsimile from Kigweba, K., Ferro Corporation, to Proctor, M.S., Pacific Environmental 

Services, Inc. November 3, 1998. Response to request for cost and properties 

information for tooling gel coats produced by Ferro Corporation. 

16 Telecon. Hester, C, Pacific Environmental Services, Inc. with Bowie Manufacturing, Inc. 

June 24,1998. Cost data on indirect costs associated with switching to low HAP resins. 

17 Telecon. Jemison, R., Pacific Environmental Services, Inc. with Bowie Manufacturing, Inc. 

April 3, 1998. Resin and gel coat HAP content information. 

18 Telecon. Proctor, M. and McKee, S., Pacific Environmental Services, Inc. with Dixie-Pacific 

Manufacturing Company, Inc. July 29, 1998. Indirect cost data associated with the switch to 

low HAP resin/gel coat. 

19 Telecon. Hester, C, Pacific Environmental Services, Inc. with Fiber Pro, Inc. June 18, 1998. 

Indirect cost data associated with the switch to low HAP resin/gel coat. 

20 Telecon. McKee, S., Pacific Environmental Services, Inc. with LASCO Bathware-Yelm 

Plant. September 2, 1998. Indirect cost data associated with the switch to low HAP resin/gel 

coat. 

21 Telecon. McKee, S., Pacific Environmental Services, Inc. with GL&V LaValley Industries, 

Inc. August 27,1998. Indirect cost data associated with the switch to low HAP resin/gel 

coat. 

22 Telecon. McKee, S., Pacific Environmental Services, Inc. with Shenandoah Fiberglass 

Products Company. July 30, 1998. Indirect cost data associated with the switch to low HAP 

resin/gel coat. 

23 Telecon. Jemison, R., Pacific Environmental Services, Inc. with Shakespeare Electronics & 

Fiberglass Division. March 25,1998. Cost data associated with the switch to low HAP 

resin/gel coat. 

24 Telecon. McKee, S., Pacific Environmental Services, Inc. with Bittner Industries, Inc. 

August 4,1998. Cost data associated with the switch to low HAP resin/gel coat. 

25 ERG. Daft Cost Procedures Documentation Memorandum for Boat MACT Standard. April 

16,1999. pp 8 -19. 

6-77 
P.86 

26 Evaluation of Pollution Prevention Techniques to Reduce Styrene Emissions from Open 

Contact Molding Processes. Volume I, Final Report. Prepared By Emery J. Kong, Mark A. 

Bahner, Robert S. Wright, and C. Andrew Clayton, Research Triangle Institute. Prepared 

for Geddes Ramsey, Air Pollution Prevention and Control Division, National Risk 

Management Research Laboratory, Office of Research and Development, U.S. EPA. 

Research Triangle Park, NC. EPA Publication No. EPA-600/R-97-018a. 

27 Telecon. Larson, P., Larson/Glastron Boats, with Palmer, B., Eastern Research Group, Inc. 

December 7 and 8,1998. Carpet and fabric adhesives and costs associated with switching to 

non-atomized resin application. 

28 Interoffice Correspondence from Anderson, R. D., The Budd Company Plastics Division, to 

Shah, V. C, The Budd Company Plastics Division. September 28, 1995. 

29 Trip Report. Proctor, M.S. (Pacific Environmental Services, Inc.). Report of Plant Visit to 

Glasforms, Inc., Birmingham, Alabama, on January 15, 1998. Prepared for U.S. 

Environmental Protection Agency. July 10, 1998. 128 pp. 

30 Survey Response and attachments from Bass, K.E., Glasforms, Inc. to Jordon, B.C., 

EPA/ESD. August 20,1993. Response to Section 114 screening information request for the 

San Hose, CA facility. Docket No. H-D-283 

31 Telecon. Proctor, M., Pacific Environmental Services, Inc. with Worth Chemical 

Corporation. August 17, 1999. Cost data on acetone and methylene chloride. 

32 Fiberglass Coatings, Inc. Supply Catalog. 1998. Page 34. 

33 Telecon. McKee, S., Pacific Environmental Services, Inc., with McQuarrie, T., Glasforms, 

Inc. October 16, 1998. Telephone contact report collecting information concerning costs of 

mixer covers for the facility in Birmingham, Alabama. 

34 U.S. Environmental Protection Agency, Emission Standards Division. Regulatory Procedures 

Manual. Part 3, Volume X, Section 2.2. October 1990. 

35 Wage rates for the Architectural Coatings Information Collection Request (ICR) 

6-78 
P.87 

MEMORANDUM 

TO: Project File 

Plastic Composites NESHAP 

ESD Project No. 93/58 

FROM: Madeleine Strum 

EPA/OAQPS/CCPG 

DATE: March 16,1998 

SUBJECT: Section 1 - Source Category Description 

This memorandum contains the final version ofthe source category description 

memorandum for the Plastic Composites NESHAP. This memo is included as Section 1 of the 

Supplementary Information Document (docket item no. ). 
TABLE OF CONTENTS 

P.88 

LIST OF FIGURES 

Page 

iv 

LIST OF TABLES iv 

1.1 INTRODUCTION 1-1 

1.1.1 General Introduction 

1.1.2 HAP Emissions 

1.1.3 Processes 

1.1.4 Products 

1-1 

1-1 

1-1 

1-2 

1.2 GENERAL DESCRIPTION 1-2 

1.2.1 Types of Industrial Groups Included 

1.2.2 Distribution of Sources by SIC Code 

1.2.3 Distribution of Sources by Geographic Location 

1.2.4 Number of Employees 

1.2.5 Distribution by Process 

1.2.6 Resin Usage by Process 

1.2.7 Major Markets and Products 

1.3 PROCESS DESCRIPTIONS AND EMISSION POINTS 

1-2 

1-3 

1-3 

1-8 

1-8 

1-10 

1-10 

1-13 

1.3.1 Bulk Molding Compound (BMC) Manufacturing 

1.3.2 Centrifugal Casting 

1.3.3 Compression Molding 

1.3.4 Continuous Lamination/Continuous Casting 

1.3.5 Filament Winding 

1.3.6 Gel Coating 

1.3.7 Hand Lay-up/Bucket and Tool Application 

1.3.8 Injection Molding 

1.3.9 Polymer Casting 

1.3.10 Pressure-Fed Roller/Flow Coater Application 

1.3.11 Pultrusion 

1.3.12 Resin Transfer Molding (RTM) 

1.3.13 Sheet Molding Compound (SMC) Manufacturing 

1.3.14 Spray Lay-up 

1-15 

1-13 

1-14 

1-14 

1-16 

1-17 

1-18 

1-19 

1-19 

1-20 

1-21 

1-22 

1-23 

1-24 

DRAFT 3/16/98 
P.89 

TABLE OF CONTENTS 

(concluded) 

Page 

1.4 ANCILLARY PROCESSES 1-25 

1.4.1 Cleaning 1-25 

1.4.2 Resin Mixing 1-26 

1.4.3 Hazardous Air Pollutant (HAP) Containing Material Storage 1-26 

1.5 REFERENCES 1-28 

iii DRAFT 3/16/98 
P.90 

LIST OF FIGURES 

Page 

HGURE 1-1 NUMBER OF EMPLOYEES REPORTED BY MAJOR SOURCES 

IN THE 1993 INDUSTRY SURVEY 1 -9 

LIST OF TABLES 

TABLE 1-1 DISTRIBUTION OF SIC CODES FOR SOURCES IN THE MACT DATABASE 

1-4 

TABLE 1-2 DISTRIBUTION OF MAJOR SOURCES BY STATE 1-6 

TABLE 1-3 DISTRIBUTION OF MAJOR SOURCES BY PROCESS 1-11 

TABLE 1-4 1992 USE OF THERMOSET PLASTIC RESINS BY PROCESS 1-12 

iv DRAFT 3/16/98 
P.91 

1.0 DESCRIPTION OF THE SOURCE CATEGORY 

1.1 INTRODUCTION1 

1.1.1 General Introduction 

The plastic composites source category involves the production of plastic products from 

cross linking resins, usually in combination with reinforcing materials and inorganic fillers. The 

production of products which do not contain reinforcing materials (i.e., non-reinforced plastics) 

is also included in this category as well as the production of intermediate compounds which are 

later used to make the final plastic products. This source category will be limited to those resins 

which contain styrene, either by itself or with a combination of other monomers or solvents. 

Plastics are divided into two major groups known as thermoset and thermoplastic. Once 

cured into a solid form, thermoset materials remain a hard solid. Thermoplastics, on the other 

hand, can be melted through the application of heat. The plastic composites source category 

includes only thermoset resin materials. Thermoset resins are usually liquids or low melting 

point solids in their initial form. In the production of finished goods, thermosetting resins are 

cured into a solid by use of an initiator, heat, or a combination of both. 

1.1.2 Hazardous Air Pollutant (HAP) Emissions 

The HAP emissions from the plastic composites source category are due primarily from 

the evaporation of styrene and other HAP organic liquids contained in the resin during the 

application and/or curing (cross-linking) of the resin. Since the styrene contained in the resin 

participates in the cross linking reaction, not all of it is emitted. Several different emission 

reduction techniques are applied to reduce emissions from the production of plastic composites. 

The different emission reduction techniques are discussed in detail in the Emission Reduction 

Techniques Memorandum.2 

1.1.3 Processes 

There is a wide variety of processes that utilize styrene-containing cross-linking resins to 

make plastics. Such processes include centrifugal casting, compression molding, continuous 

lamination/continuous casting, filament winding, gel coating (which is typically done in 

combination with one ofthe other processes), hand lay-up/bucket and tool application, injection 

1-1 DRAFT 3/16/98 
P.92 

molding, polymer casting, pressure-fed roller or flow coater application, pultrusion, resin transfer 

molding (RTM), and atomized spray lay-up. Two processes which are used to manufacture 

intermediate products are the manufacture of sheet molding compound (SMC) and manufacture 

of bulk molding compound (BMC). Many facilities, including those that do not perform gel 

coating, use multiple processes to make their products. For example, a facility that performs the 

filament winding process usually conducts hand lay-up and/or spray lay-up operations at the 

same facility. However, there are facilities that may conduct only one process; for example, a 

facility making products using the pultrusion process may not have any other plastics composite 

manufacturing processes on site. 

Different processes have different emissions characteristics and different applicable 

emission reduction techniques. For example, gel coating, spray lay-up, hand lay-up, and 

filament winding (which are characterized under an umbrella term "open molding") are relatively 

high emitting processes as compared to RTM, compression molding, and injection molding 

(which are characterized under the term "closed molding"). The emission reduction technique of 

lowering the HAP content of the resin is effective for reducing emissions from open molding 

processes, but not necessarily for the other types of processes. 

1.1.4 Products 

The source category produces a wide variety of products traversing such broad market 

segments as transportation, construction, electronics, consumer products, marine, and aerospace. 

This diverse source category encompasses at least 43 Standard Industrial Classification (SIC) 

codes.3'

4

 However, boat manufacturing has been specifically excluded from this rule 

development effort and will be addressed under separate action. We have estimated that there 

are approximately 440 major sources in the United States. Information about the vast majority of 

these sources was provided in the 1993 industry screening surveys. Additional data were 

collected during site visits, contact reports, and from facility operating permits. 

1.2 GENERAL DESCRIPTION 

1.2.1 Types of Industrial Groups Included3 

The SIC codes included in the plastic composites source category were determined by 

searching the toxic release inventory system (TRIS) database for facilities emitting styrene, a 

1-2 DRAFT 3/16/98 
P.93 

major HAP emitted by this source category. The TRIS database identified a total set of 232 SIC 

codes under the pollutant styrene. The majority of these codes were deleted for categories that 

clearly did not belong in the plastic composites source category. The 43 remaining SIC codes 

contain facilities involved in the production of plastic composites. However, it is cautioned that 

not all facilities that may fall under these 43 SIC codes are in the composites industry. In 

addition, there could be facilities not encompassed by these 43 SIC codes that may use thermoset 

resins in their operations. With these caveats in mind, Table 1-1 presents the 43 SIC codes 

potentially covered under the plastic composites NESHAP. 

1.2.2 Distribution of Sources bv SIC Code34 

The distribution of major sources in the plastic composites source category by SIC code is 

shown in Table 1-1. The majority of the sources (73 percent) are classified under SIC codes 307 

and 308, which classifies miscellaneous plastics products. SIC code 307 is an old code used in 

the 1972 edition of the Standard Industrial Classification Manual5, but TRIS still includes several 

facilities with this code. Approximately 6 percent of the sources included in the composites 

industry are classified under SIC code 371, which applies to motor vehicles and motor vehicle 

equipment. For approximately 5 percent of the major sources the SIC codes were not reported. 

The remaining 16 percent ofthe sources are distributed over 25 different three-digit SIC codes. 

Table 1-1 shows the SIC code distribution and the description for each SIC code. 

1.2.3 Distribution of Sources bv Geographic Location6 

The geographic locations of major sources involved in the plastic composites industry are 

shown in Table 1-2. The geographic information was obtained from site specific information 

collected for this standard (e.g., the 1993 industry screening surveys, trip reports, and telephone 

contact reports). For this analysis, a major source is defined as a source with potential emissions 

of 10 tons per year or more of a single hazardous air pollutant (HAP) or 25 tpy or more of any 

combination of HAP. A detailed discussion of how facility emissions were determined on a 

process basis is provided in the Emission Factor/Baseline Emission memorandum (SID chapter 

3). Table 1-2 shows that the largest concentration of facilities is in Ohio (42), followed by 

Indiana (38), and Califomia (34). 

1-3 DRAFT 3/16/98 
P.94 

TABLE 1-1 

DISTRIBUTION OF SIC CODES FOR SOURCES IN THE MACT DATABASE3 4'

6 

SIC 

Cnrlp 

2434 

2519 

2522 

2541 

2599 

2821 

3079 

3082 

3083 

3084 

3087 

3088 

3089 

3281 

3296 

3299 

3431 

3499 

3531 

3533 

3546 

3561 

3564 

3589 

3612 

3613 

Three-Digit 

STC POH P 

243 

251 

252 

254 

259 

282 

307 

308 

328 

329 

343 

349 

353 

354 

356 

358 

361 

Fou r Hi ait STP CnHp TitlfWood Kitchen Cabinets 

Household Furniture, NEC 

Metal Office Furniture 

Wood Partitions, Shelving, Lockers, etc. 

Furniture and Fixtures, NEC 

Plastic Materials, Synthetic Resins, & Nonvulcanizable 

Elastomers 

Plastics Products, NEC 

Unsupported Plastic Profile Shapes 

Laminated Plastics 

Plastics Pipe 

Custom Compound Resins 

Plastics Plumbing Fixtures 

Plastics Products, NEC 

Cut Stone and Stone Products 

Mineral Wool 

Nonmetallic Mineral Products, NEC 

Enameled Iron and Metal Sanitary Ware 

Fabricated Metal Products, NEC 

Construction Machinery and Equipment 

Oil/Gas Field Machinery/Equip. 

Power-Driven Hand Tools 

Pumps and Pumping Equipment 

Blowers and Fans 

Service Industry Machines, NEC 

Power Transformers 

Switchgear and Switchboard Apparatus 

Major 

Snnrcp.s*-

1 

1 

1 

1 

1 

2 

38 

2 

20 

6 

8 

74 

170 

5 

2 

3 

2 

3 

Percent of 

TntnlCWA1-

0.2 

0.2 

0.2 

0.2 

0.2 

0.5 

8.7 

0.5 

4.6 

1.4 

1.8 

16.9 

38.9 

1.1 

0.5 

0.7 

0.2 

0.2 

0.2 

0.2 

0.2 

0.5 

0.2 

0.2 

0.2 

0.7 

1-4 DRAFT 3/16/98 
P.95 

TABLE 1-1 (CONCLUDED) 

SIC 

Cnrlp 

3621 

3647 

3663 

3679 

3711 

3713 

3714 

3715 

3716 

3728 

3743 

3792 

3799 

3821 

3949 

3993 

3999 

NA 

Three-Digit 

STC TnHp 

362 

364 

366 

367 

371 

372 

374 

379 

382 

394 

399 

NA 

FniirniaitSTrPnHpTitlP 

Motors and Generators 

Vehicular Lighting Equipment 

Radio/Television Broadcasting/Communication Equipment 

Electronic Components, NEC 

Motor Vehicles/Passenger Car Bodies 

Truck and Bus Bodies 

Motor Vehicles Parts/Accessories 

Truck Trailers 

Motor Homes 

Aircraft Parts/Equipment, NEC 

Railroad Equipment 

Travel Trailers/Campers 

Transportation Equipment, NEC 

Laboratory Equipment and Supplies 

Sporting/Athletic Goods, NEC 

Signs/Advertising Specialties 

Manufacturing Industries, NEC 

No SIC Code reported 

TOTAL 

Major 

Snnrcp.s" 

1 

2 

1 

1 

2 

9 

9 

1 

5 

1 

1 

13 

1 

2 

4 

2 

13 

21 

437 

Percent of 

Tnt.nl (<?„-_* 

0.2 

0.5 

0.2 

0.2 

0.5 

2.1 

2.1 

0.2 

1.1 

0.2 

0.2 

3.0 

0.2 

0.5 

0.9 

0.5 

3.0 

4.8 

100 

Major sources in this table are sources that have the potential to emit 10 tons per year or more ofany single hazardous 

air pollutant or 25 tons per year or more of any combination of hazardous air pollutants. 

Values shown in the table may not add up to 100 percent due to rounding. 

1-5 DRAFT 3/16/98 
P.96 

TABLE 1-2 

DISTRIBUTION OF MAJOR SOURCES BY STATE6 

State 

Alabama 

Arkansas 

Arizona 

California 

Colorado 

Connecticut 

Delaware 

Florida 

Georgia 

Hawaii 

Idaho 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Minnesota 

Mississippi 

Missouri 

Nebraska 

Nevada 

New Hampshire 

Number of 

Major Sources 

9 

4 

3 

34 

1 

1 

3 

18 

9 

1 

3 

15 

38 

11 

11 

6 

3 

2 

2 

3 

17 

13 

4 

10 

5 

2 

2 

Percent of Total 

2.1 

0.9 

0.7 

7.8 

0.2 

0.2 

0.7 

4.1 

2.1 

0.2 

0.7 

3.4 

8.7 

2.5 

2.5 

1.4 

0.7 

0.5 

0.5 

0.7 

3.9 

3.0 

0.9 

2.3 

1.1 

0.5 

0.5 

1-6 DRAFT 3/16/98 
P.97 

TABLE 1-2 (Concluded) 

State 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

South Carolina 

South Dakota 

Tennessee 

Texas 

Utah 

Virginia 

Washington 

West Virginia 

Wisconsin 

TOTALS 

Number of 

Major Sources 

4 

1 

9 

20 

3 

42 

5 

11 

25 

9 

2 

11 

25 

3 

9 

11 

2 

16 

437 

Percent of Total 

(%r 

0.9 

0.2 

2.1 

4.6 

0.7 

9.6 

1.1 

2.5 

5.7 

2.1 

0.5 

2.5 

5.7 

0.7 

2.1 

2.5 

0.5 

3.7 

100.0 

Values shown in the table may not add up to 100 percent due to rounding. 

1-7 DRAFT 3/16/98 
P.98 

1.2.4 Number of Employees6 

The number of employees reported by major sources is shown in Figure 1-1. Employment 

data were obtained from site specific information collected for this standard (mainly the 1993 

industry screening surveys). In the screening survey, facilities were asked to report the number 

of employees attached to the plastic composites operation and the number of employees of the 

business enterprise that owns the facility. The facilities were asked to provide the employment 

information in ranges (0-100; 101-250; 251-500; 501-750; 751-1,000; 1,001-1,500; and >1,500). 

From the total 437 major facilities, information on the number of employees attached to plastic 

composites operations was available for 400 facilities and information on parent company 

employment was available for 406 facilities. The employment information for employees 

directly attached to plastic composites operations shows that approximately 80 percent of the 

major facilities employ 100 employees or less, 12 percent employ between 101 and 250 

employees, 5 percent employ between 251 and 500 employees, 2 percent employ between 501 

and 1,000 employees, and less than 1 percent employ more than 1,000 employees. The 

information on the number of employees of the business enterprise or parent company that owns 

individual facilities indicates that 54 percent of these companies employ 100 employees or less, 

16 percent employ between 101 and 250 employees, 6 percent employ between 251 and 500 

employees, 7 percent employ between 501 and 1,000 employees, and 17 percent employ more 

than 1,000 employees. 

1.2.5 Distribution by Process6 

There are a number of different processes that can be used to produce plastic composites. 

A full description ofthe major processes is provided in Section number 1.3 ofthis memorandum. 

However, there may be additional processes or variations of the major processes that are not 

described in Section 1.3. The following fabrication processes are described: BMC 

manufacturing, centrifugal casting, compression molding, continuous lamination/continuous 

casting, filament winding, gel coating, hand lay-up/bucket and tool application, injection 

molding, polymer casting, pressure-fed roller/flow coater application, pultrusion, RTM, SMC 

manufacturing, and atomized spray lay-up. There are a number of facilities that carry out more 

than one process at their facility. For example, a number of 

1-8 DRAFT 3/16/98 
FIGURE 1-1 

Number of Employees Reported by Major Sources in the 1993 Industry Survey 

350 

100 or less 101-250 251-500 501-750 

Number of Employees 

i r 

751-1000 1001-1500 >1500 

1-9 DRAFT 3/16/98 
p.1 

facilities combine filament winding with spray lay-up, hand lay-up, and/or pressure-fed 

roller/flow coater application processes in order to produce piping and tanks. Several facilities 

that manufacture molding compounds subsequently use this material in their own injection or 

compression molding operations. Table 1-3 shows the distribution ofthe 437 major sources by 

production process. Facilities that use several different processes were counted under each 

process reported for their facility. Table 1-3 shows that the most frequently used processes are 

gel coating which is used by approximately 60 percent ofthe facilities and atomized spray lay-up 

which is used by about 51 percent ofthe facilities. Hand lay-up application, which is reported by 

approximately 21 percent of the facilities, is the third most common process, followed by 

polymer casting with 18 percent. 

1.2.6 Resin Use bv Process6 

According to site specific information collected for this standard, a total of about 284,600 

tons of thermoset resin is used per year. Table 1-4 provides information about the resin usage by 

process. The resin used to produce intermediary products such as SMC and BMC is eventually 

used in other processes such as compression or injection molding to produce the final products. 

Intermediary and final products have been separated in Table 1-4 to avoid double counting of the 

resin. The majority of the products are produced in the spray lay-up process where 

approximately 33 percent ofthe total resin is used. The combination of compression molding 

and injection molding accounts for about 22 percent of the resin used in composites production 

processes. The next most common production process is continuous lamination/continuous 

casting where approximately 18 percent of the total resin is used. 

1.2.7 Maior Markets and Products4'

7 

The major market categories included in the plastic composites source category are: 

transportation, packaging, building and construction, electrical/electronics, and 

consumer/institutional products. The transportation market category includes motor vehicles and 

parts, railroad equipment, travel trailers, campers, aircraft, and recreational vehicles. The SIC codes 

included under this market category are 371, 372, 374, and 379. The packaging market category 

includes various shipping containers like drums, boxes, and crates. The SIC code 308, 

Miscellaneous Plastics Products, covers this market category. The building and construction 

1-10 DRAFT 3/16/98 
P.2 

TABLE 1-3 

DISTRIBUTION OF MAJOR SOURCES BY PROCESS6 

(Total Number Of Major Sources = 437) 

Process 

BMC Manufacturing 

Centrifugal Casting 

Compression/Injection Molding 

Continuous Lamination/Continuous 

Casting 

Filament Winding 

Gel Coating 

Hand Lay-up/Bucket & Tool Application 

Polymer Casting 

Pressure-Fed Roller/Flow Coater 

Pultrusion 

RTM 

SMC Manufacturing 

Spray Lay-up 

Number of 

Facilities 

15 

8 

62 

13 

44 

261 

93 

79 

14 

32 

20 

21 

223 

Percentage of Facilities 

Reporting Process11 (%) 

3.4 

1.8 

14.2 

3.0 

10.1 

59.7 

21.3 

18.1 

3.2 

7.3 

4.6 

4.8 

51.0 

Values shown in the table do not add up to 100 percent since facilities often perform multiple processes. 

1-11 DRAFT 3/16/98 
P.3 

TABLE 1-4 

1992a USE OF THERMOSET PLASTIC RESINS BY PROCESS6 

(Tons per Year) 

Process Grouping Resin Quantity Percent of Totalb

(%) 

Processes for Intermediate Products 

BMC Manufacturing 

SMC Manufacturing 

20,000 

28,700 

Not Applicable 

Not Applicable 

Processes for Final Products 

Centrifugal Casting 

Compression/Injection Molding 

Continuous Lamination/Continuous Casting 

Filament Winding 

Gel Coating 

Hand Lay-up/Bucket & Tool Application 

Polymer Casting 

Pressure-Fed Roller/Flow Coater 

Pultrusion 

RTM 

Spray Lay-up 

TOTALS 

1,700 

61,400c 

51,500 

4,300 

22,800 

9,600 

18,700 

3,700 

14,700 

1,300 

94,800 

284,600d 

0.6 

21.6 

18.1 

1.5 

8.0 

3.4 

6.6 

1.3 

5.2 

0.5 

33.3 

100.0 

a Most of the data is from 1992, which has been collected in the 1993 industry screening surveys. However, the 

data for some facilities has been updated based on trip and contact reports that occurred as recent as 1998. 

b Values shown in the table may not add up to 100 percent due to rounding. 

c Feedstocks are usually SMC or BMC which generally contain 30 percent resin. The resin contained in the 

209,585 ton of feedstock is 62,876 based on the assumption that the feedstock contains 30 percent resin by 

weight. 

d Total resin quantity does not include resin used to produce intermediate products to avoid double counting. 

1-12 DRAFT 3/16/98 
P.4 

market category includes items like pipe, conduit, plumbing fixtures, showers, bathtubs, siding, 

flooring, skylights, and railings. The SIC codes most closely related to this category are 353 and 

308, which cover construction, materials handling and equipment, and miscellaneous plastic 

products. The electronics market category includes home and industrial appliances, resistors, and 

cable coverings. The SIC codes for this market category are 349, 361, 362, 364, 366, and 367. 

Consumer and industrial products are covered by SIC codes 308, 394, and 399 and cover a wide 

variety of goods ranging from toys, sporting goods, buttons, and ladders to barber shop 

equipment. 

1.3 PROCESS DESCRIPTIONS AND EMISSION POINTS 

1.3.1 BMC Manufacturing 

Process description.89 BMC manufacturing consists of preparing an easily handled puttylike molding compound which contains resins, catalysts, fillers, and reinforcements in a "readyto-mold" form. BMC can be used in compression molding and injection molding to manufacture 

products with complex shapes. In the production of BMC, approximately 30 percent resin, 50 

percent filler and additives, and 20 percent reinforcement are combined during energy intensive 

mixing. The mixture is extruded, allowed to thicken and cut into appropriate sizes and shapes. 

The primary reinforcement used in BMC compounds is chopped glass fiber. The choice of the 

resin (polyester or vinyl ester) determines the physical characteristics of the product. BMC is 

used primarily as a replacement for cast metals. Example products include air conditioner 

components, pump housings, computer and business equipment components, and power tools. 

HAP emission points.8,9 In the production of BMC, HAP are released from the mixing 

tank, particularly if the tank is uncovered, partially covered, or actively vented. HAP can also be 

released from covered tanks through leaking seals and covers. During the intensive agitation of 

the resin mixture, the HAP contained in the resin is exposed to the open air and can evaporate. 

HAP emissions may also be released during the product formation and thickening processes. 

1-13 DRAFT 3/16/98 
P.5 

1.3.2 Centrifugal Casting 

Process description.9 In centrifugal casting, resin and fiber reinforcements (if needed) are 

deposited against the inside surface of a rotating mold. A resin applicator which is often located 

in the center of the rotating mold supplies the resin to the inside of the cast. Centrifugal force 

holds the material in place while the part is cured. The outside surface of the part, which is cured 

against the inside surface of the mold, represents the finished surface. The interior surface of the 

centrifugally cast part can be improved by adding an additional coat of pure resin. Centrifugal 

casting is used to commercially produce products such as large and small diameter pipe and 

tanks. The two main limitations in centrifugal casting operations are the inability to spin molds 

of large size and the relatively low productivity per tool. 

HAP emission points.910 During the centrifugal casting process air may be moved through 

the inside of the rotating mold to facilitate the resin distribution and curing. The rotating cast is 

generally vented and HAP are emitted during the actual casting process. In addition to the 

emissions from the inside of the mold, a small amount of HAP can be emitted when the resin is 

transferred to the interior of the mold and when the product is removed. 

1.3.3 Compression Molding 

Process description.9" Compression molding operations involve compressing the 

composite material under hydraulic pressure (at 250 to 3,000 psi) in matched metal dies and 

holding the configured, condensed material in the desired shape until the resin system has cured. 

The composite materials used in the compression molding process include SMC and BMC. The 

production output in compression molding is relatively high because the molding compounds 

cure rapidly in the heated mold. The materials generally yield a good finish without application 

of gel coat. Both surfaces of the molded product will be as smooth as the mold surface. 

Compression molding can reduce high unit production costs, but only ifthe production volume is 

at least 150 parts per mold per shift to sufficiently spread out the high cost of the required 

matched metal dies. Compression molding processes have been successfully used in the 

automotive industry for more than 30 years. The automotive parts that are produced include car 

bodies, truck hoods, fenders, and a variety of smaller vehicle parts. Other types of products 

produced by compression molding include appliances and business equipment components. At 

1-14 DRAFT 3/16/98 
P.6 

least one facility uses compression molding to produce bathtubs, shower stalls, and lavatory 

bowls.12 

HAP emission points."13 Since compression molding is a closed process and no wet 

resin surfaces are exposed during molding, emissions are generally very low. Some HAP 

emissions can occur when BMC or SMC are prepared for molding (i.e., cut and stripped of film, 

etc.) and placed in the mold. Other HAP emissions are released when the mold is opened to 

remove the product, but these emissions are presumed to be extremely low because curing occurs 

inside the closed mold. 

1.3.4 Continuous Lamination/Continuous Casting 

Process description.914 Continuous lamination/continuous casting is a substantially 

automated process for producing flat or corrugated laminates on an in-line conveyor. Continuous 

casting involves putting filled liquid polymer on a belt to produce cast sheets. In continuous 

lamination, resin and chopped glass are sandwiched between two carrier films and passed 

through a curing oven. In this process, the resin mix is metered onto a bottom carrier film, using 

a blade to control the thickness. The film, made of polyester, cellophane, or nylon, forms the 

panel's outer surface. If extra weather resistance is required, a polyvinyl fluoride film, that 

permanently bonds to the resin, is added. In addition, methyl methacrylate can be used as the 

cross-linking agent to increase strength, weather resistance, and protection from ultra violet 

radiation. Reinforcement can be used, but does not have to be part of the process. One way to 

incorporate reinforcement into the product is to chop and evenly distribute continuous strand 

fiberglass rovings into the resin mix where they are allowed to wet out. A second plastic film is 

typically applied over the reinforcement and the material is fed through compaction rollers which 

allow mixing and exclusion of air that is usually trapped between the two films. The glass/resin 

composite is sandwiched between the carrier films and then passed through a curing oven. 

Corrugated products are pulled through a series of forming guides to created the corrugated shape 

of the product before they enter the curing oven. Cured panels are automatically trimmed to 

width and cut to length. The largest use of continuous lamination is for the production of 

skylights, panels, fences, garage doors, awnings, and cooling tower louvers. 

HAP emission points.13 An important source of organic vapor emissions in continuous 

1-15 DRAFT 3/16/98 
lamination/continuous casting operations is the wet out table, where a thin layer of resin is 

exposed for up to a few minutes to the ambient air. In some instances the table is heated, which 

increases the potential to emit organic vapors. Another HAP emission point is the oven in which 

the products are cured. The heat applied in the oven causes volatile monomer in the uncured 

resin to evaporate. 

1.3.5 Filament Winding 

Process description.91315 Filament winding is a composite production process for 

manufacturing products that are surfaces of revolution. In this process, fibers are impregnated 

with resin in a resin bath and wrapped around a rotating mold surface or mandrel following a 

machine controlled geometric pattern. The application of resin by brush or tool, spray gun, or 

pressure-fed roller/flow coater is not considered part of the filament winding process. The 

product is then cured in an oven or at room temperature. All types of reinforcing fibers can be 

utilized in filament winding, but continuous glass fiber is most commonly used due to its high 

specific strength and relatively low cost. The filament winding process uses three common 

patterns: circumferential, helical, and polar winding. The different winding patterns can be 

applied alone or in combination to achieve the desired strength and shape characteristics. There 

are various techniques and materials to produce the mandrel. Reusable steel mandrels are used 

for high volume repetitive products, disposable mandrels are used for short production runs or 

prototypes, and for some products the mandrel becomes an integral liner or core in the final part. 

Example products are storage tanks, air and gas pressure bottles, fuselages, wind turbine and 

helicopter blades, and tubing and pipe. 

HAP emission points.15 The HAP emissions in filament winding operations are released 

from the resin bath and the surface of the mandrel which is covered with resin-rich fiber. The 

surface of the mandrel emits during the winding process and during curing. A study conducted 

by The Dow Chemical Company found that 80 percent of the emissions occur during the winding 

process from the mandrel surface and the bath and the remaining 20 percent are released during 

curing. 

1-16 DRAFT 3/16/98 
P.8 

1.3.6 GelCoating 

Process description." Gel coat is a clear or pigmented non-reinforced finishing layer 

applied to the surface of the mold or the actual product in many production processes in order to 

improve the appearance and surface properties of a product. The average thickness of a gel coat 

layer is between 15 and 20 millimeters. The gel coat is sometimes applied in multiple passes 

which means that the part is completely covered by several thin layers to reach the final thickness 

ofthe part. Gel coating is usually done in conjunction with spray lay-up, hand lay-up, polymer 

casting, or resin transfer molding. In some cases gel coat is also used in conjunction with 

continuous lamination and compression molding. When the gel coat is used in conjunction with 

spray lay-up, hand lay-up, polymer casting, or resin transfer molding it is usually applied by use 

of a spray gun but it can also be applied with non-atomized spray equipment. Gel coat that is 

applied in conjunction with continuous lamination is poured or metered onto a carrier film which 

forms the outer layer of the laminate. When the gel coat is applied in conjunction with 

compression molding, it is typically injected into a closed mold. 

Gel coat spray systems consist of separate sources of gel coat and a catalyst, with a handheld spray gun that mixes both components together into an atomized resin/catalyst stream. Four 

main types of spray guns are available for the application of gel coat: conventional air spray guns, 

airless spray guns, air-assisted airless guns, and high volume low pressure (HVLP) spray guns. 

Conventional air spray guns use compressed air, high fluid pressures, or a combination of fluid 

pressure and compressed air to atomize the gel coat or resin. Airless spray guns atomize the gel 

coat by pumping it at extremely high fluid pressure (1,000 to 3,000 psi) through an atomizing 

nozzle. Air assisted airless guns also use fluid pressure to atomize gel coats through a spray 

nozzle. However, the fluid pressure is considerably lower (400 to 1,000 psi) than for airless guns 

and must therefore be augmented by introducing pressurized air into the gel coat spray pattern as 

it exits the pressure nozzle. HVLP spray guns use a high volume of air (10 to 20 cfm) delivered 

at a pressure of approximately 10 psi to atomize the gel coat. The hydraulic pressure coming to 

the gun is as low as 200 to 2,000 psi. When the gel coat leaves the orifice, the low pressure air 

completes 

1-17 DRAFT 3/16/98 
P.9 

the atomization and encapsulates the gel coat fan on its way to the mold surface, creating a soft, 

low velocity spray. 

Once the gel coat is applied it is commonly cured under ambient conditions. However, in 

some cases heat is applied to accelerate the curing process. 

Specialized booths or bays for gel coat application are used by a number of facilities to 

better manage pollution and worker safety. The use of spray booths for gel coating is most 

common with producers of relatively small items or high volume producers who have 

incorporated moving assembly lines into their operation. 

HAP emission points." HAP emissions from gel coat that is sprayed or poured occur 

during the application of the gel coat and during curing in open mold processes. When the gel 

coat is injected into closed molds, no wet gel coat surfaces are exposed during application and 

curing and emissions are generally very low. Some HAP emissions are released from closed 

mold gel coating when the mold is opened to remove the product, but these emissions are 

presumed to be extremely low because curing occurs inside the closed mold. 

1.3.7 Hand Lay-up/Bucket and Tool Application 

Process description.91316 Hand lay-up/bucket and tool application involves placing 

reinforcement onto the mold and saturating the reinforcement with liquid resin. The 

reinforcement is manually fitted against the surface of a mold and is then wetted with catalyzed 

resin mix, after which it is saturated with more resin and rolled out to remove air bubbles. Most 

hand lay-up/bucket and tool operations use glass fiber chopped strand mats in weight percentages 

of 30 to 45 percent of the composite laminate. Woven roving is used when higher reinforcement 

loadings are desired. The woven roving as a weight percent of laminate may be as high as 65 

percent. The desired laminate thickness is achieved by adding layers of reinforcement and resin. 

The individual layers are smoothed and compacted with squeegees, brushes, and rollers. 

HAP emission points.13 During hand lay-up/bucket and tool applications, a relatively 

large surface of wet resin and/or impregnated fiber is exposed to the atmosphere for most of the 

production cycle. Hazardous air pollutants evaporate from the liquid resin which is in contact 

with the air as it is applied and from the product surface. During rolling and curing, HAP also 

evaporate from the squeegees, brushes, and rollers used in the resin application. Compacting and 

1-18 DRAFT 3/16/98 
P.10 

smoothing the resin surface allows further volatilization of HAP until the resin reaches the gel 

point and then final cure. Several layers of resin are applied in hand lay-up/bucket and tool 

operations until the desired thickness is achieved. Each layer applied increases the amount of 

volatile HAP emitted to the atmosphere. 

1.3.8 Injection Molding 

Process description.9 Injection molding is a closed process that involves feeding liquid 

resin, reinforcing fiber, and other additives into one end of a cooled metallic cylinder. Inside the 

cylinder is a screw or plunger that rotates and reciprocates back and forth along the axis of the 

cylinder. This action meters the resin for the melt volume required to fill the mold and transfers 

the metered resin charge into the mold. An additional function of the injection molding machine 

is to retain the mold, clamping it closed under pressure during injection and ejection of the 

finished part after heat curing takes place. The mold cavity represents the exact shape of the part 

to be produced. Depending on the part size and molding machine capacity, the molds can 

contain one or more cavities. Chopped glass fibers ranging in length from 5 to 40 mm are the 

main reinforcement used in injection molding operations. Fiber loadings vary from 5 to 40 

percent by weight. The injection molding process is well suited for producing a high volume of 

complex products with excellent dimensional accuracy. 

HAP emission points.9 Injection molding is a closed process where no wet resin surfaces 

are exposed. Some HAP emissions may occur when the finished part is ejected from the mold, 

but those emissions are considered very low because curing takes place inside the closed mold. 

In addition, some fugitive emissions can occur when liquid resin is fed into the metallic cylinder. 

1.3.9 Polymer Casting 

Process description.91417 In the polymer casting process, polymers, fillers, and additives 

are combined by pouring or dispensing these materials into open or partially open molds and then 

curing them. Fiberglass reinforcement is not used in cast polymer products. In the polymer 

casting process, the resin matrix is catalyzed and cast onto the mold which is usually vibrated to 

allow air bubbles to escape. Following vibration, the product enters an exothermic stage in 

which the matrix's chemical reaction generates heat that causes the product to cure. In some 

cases a heated oven is used to accelerate cure. Products produced by the polymer casting process 

1-19 DRAFT 3/16/98 
P.11 

include polymer concrete (utility structures and bridges), cultured marble products (sinks, tubs, 

shower panels, and countertops), and bowling balls. 

HAP emission points.14 Sources of emissions in polymer casting include emissions from 

the semi-open polymer casting machine and emissions from curing. Curing emissions can be 

released from the oven or during curing at ambient temperature. 

1.3.10 Pressure-Fed Roller or Flow Coater Application 

Process description.18 Pressure-fed rollers or flow coaters are mechanical resin 

application equipment used to apply resin to an open mold without atomizing the resin or 

spraying it. The process is similar to the spray application process which is described in Section 

1.3.14 except that the resin is not broken up into distinct droplets before arriving at the mold. 

There is other mechanical resin application equipment that can be used to apply resin without 

atomizing (or spraying) it; however, only pressure-fed rollers and flow coaters will be discussed 

here. 

Pressure-fed rollers are used to apply resin to pre-cut pieces of reinforcement which are 

hand-laid into the mold (either before or after they are saturated with the resin). Since the resin is 

"rolled" onto the reinforcement, the roller also aids in distributing and rolling the resin evenly 

onto the reinforcement. However, the detailed roll out step used in flow coating and spray lay up 

is still necessary. A pressure-fed roller consists of a fabric roller which is fed by a continuous 

supply of catalyzed resin. A fluid pump draws resin from a drum or bulk distribution line. The 

resin pump is mechanically linked to a separate catalyst pump. These two pumps supply the 

resin and catalyst in a preset ratio to a mixer in the handle of the roller. The mixer then feeds the 

catalyzed resin to the roller head through the handle of the roller. A valve controlled by the 

operator regulates the amount of resin flowing to the roller head and to the part being fabricated. 

The roller head is covered with a dispensable fabric cover similar to a standard paint roller. 

Resin rollers are intended to be operated almost continuously during a shift to prevent the resin 

from hardening between the mixer and the roller cover. At the end 

1-20 DRAFT 3/16/98 
P.12 

of the shift, the roller cover is discarded and the mixing unit, handle, and roller manifold are 

flushed with solvent. 

Flow coaters are used to apply the resin to the mold in a flow pattern consisting of distinct 

streams of resin as opposed to a spray pattern consisting of resin droplets. Whereas a spray gun 

has a single small orifice, the tip of a flow coater has a dozen or so precisely drilled holes that 

produce steady streams of resin, similar to a small showerhead. The catalyst is mixed with the 

resin before the resin exits the flow coater. At least two manufacturers produce internal-mix 

resin spray guns that can be converted to flow coaters simply by switching the nozzle from 

single-orifice tips to flow coater nozzles. Unlike pressure-fed rollers, flow coaters can also be 

used to simultaneously apply resin and chopped fiberglass reinforcements by fitting the flow 

coater with a chopper head that shoots the chopped glass into the flow pattem. The current 

pressure-fed roller/flow coater equipment is being used in place of conventional spray lay-up 

equipment in numerous products except for those that require high amounts of filler. 

HAP emission points.14 The emission points associated with pressure-fed rollers/flow 

coaters are application ofthe resin and the post-application steps of rolling and curing. 

Hazardous air pollutants are emitted from wet product surfaces during rolling and curing and 

from brushes or rollers used to remove entrapped air from the applied resin. 

1.3.11 Pultrusion 

Process description.91319 Pultrusion is a continuous manufacturing process that produces 

parts with constant cross-sectional shapes. The term "pultrusion" comes from the fact that the 

composite is pulled through an extrusion-type die by a gripper/puller system. In the standard 

pultrusion process, reinforcing fibers are pulled through a resin bath where all materials are 

thoroughly impregnated with liquid resin. The wet fibrous laminate is formed to the desired 

geometric shape in a preforming section and pulled into the heated steel die. As an alternative to 

using a resin bath, resin can be injected into the pre-forming section (resin injection) or directly 

into the forming die (die injection). In the die, the resin cure is initiated by controlling precise 

elevated temperatures. The laminate solidifies in the exact shape of the die cavity as it is being 

continuously pulled by the pultrusion machine. The cured product can 

1-21 DRAFT 3/16/98 
P.13 

then be cut to desired lengths. Example products include electrical insulation materials, ladder 

rails, walkway gratings, structural supports, rods, antennas, and window and door frame lineals. 

HAP emission points.13 The major emission points in pultrusion operations are the resin 

impregnation bath, the drip pan, and the wet reinforcement. Hazardous air pollutants evaporate 

from the surface or exposed areas of the resin bath, the drip pan, and the wet, dripping 

reinforcement into the ambient air. Hazardous air pollutants are released directly from the wet 

reinforcement as it passes through the forming guides after leaving the resin bath. Also, when 

the wet reinforcement passes through the forming guides, excess resin drips into the drip pan, 

creating a large surface area from which styrene can evaporate. Emissions during the curing 

phase are presumed to be insignificant in pultrusion operations, since curing takes place in closed 

metal dies. 

1.3.12 Resin Transfer Molding (RTM) 

Process description.9,11'

13

 RTM is a closed mold process in which matching male and 

female molds, containing continuous or chopped glass fiber strands, are clamped together. 

Usually gel coat is applied to one or both sides of the mold prior to the RTM process. After the 

gel coat application process reinforcing fiber is placed into the bottom half of the mold, the mold 

is closed and resin is pumped into the mold through injection ports designed to contain the resin 

under pressure. A perimeter gasket seals the edges of the mold and air vents located at the gasket 

line evacuate air and restrict loss of resin. Since molding pressures are typically between 30 and 

75 psi, the molds can be made of plastic based composites rather than metal. RTM can thus be 

set up to replace many conventional open molding processes. The molds can be produced from 

the same materials using the same techniques as for conventional mold production, and resin and 

filler materials differ little from those used in open molding. RTM is best suited for intermediate 

volume production (500 to 10,000 parts per year) of small to mid-sized products such as 

restaurant seats, automotive parts, plumbing components, and electrical covers. However, parts 

as large as personal watercraft hulls and decks are also being made with RTM. 

1-22 DRAFT 3/16/98 
P.14 

HAP emission points."13 Since RTM is a closed process, air exchange between wet resin 

surfaces and the atmosphere is greatly limited, resulting in low HAP emissions. Some HAP 

emissions can still be released from the excess resin pumped into the injection port that exits the 

mold through distribution ports. In addition, some HAP emissions are released when the mold is 

opened to remove the product. However, emissions during product release from the mold are 

relatively low because curing occurs inside the closed mold. 

1.3.13 SMC Manufacturing 

Process description.9,20 SMC is an integrated composite material which contains all 

reinforcement, resin, fillers, chemical thickeners, catalysts, mold release agents, and other 

ingredients in an easily handled sheet. SMC can be stored for a period of time prior to molding it 

into complex shapes in compression or injection molding operations. In the SMC production the 

resin paste, a liquid paste with a viscosity between 40,000 and 100,000 centipoise, is pumped 

into the doctor box of the SMC machine. At the SMC machine, the paste is metered through 

doctor blades onto nylon, polyethylene or similar carrier films. Glass fibers are chopped to a 

specific length and uniformly distributed over the lower paste bed. After the upper and lower 

paste beds are brought together, the formed sandwich progresses through a compaction belt 

where it is consolidated. The compacted SMC sheet is rolled into the desired length, packaged in 

a nylon sleeve to reduce evaporation of volatile compounds, and stored in a temperature 

controlled area. Thickening of the resin is influenced by ingredients such as magnesium oxide or 

magnesium hydroxide and can take anywhere from several hours to several days. Once the SMC 

reaches the desired molding viscosity of 6,000,000 to 75,000,000 centipoise, it is cut into desired 

sizes and shapes. Finally, the SMC can then be utilized as a raw material in compression or 

injection molding operations. There are different types of SMC available depending on the 

pattern of reinforcement used, which includes random fiber reinforcement, unidirectional 

continuous fiber, unidirectional continuous fiber with random fiber reinforcement, and 

directional discontinuous reinforcing. SMC is a high throughput, high volume process and is 

widely used in economically demanding markets such as the automotive, appliance, and 

electrical industries. 

1-23 DRAFT 3/16/98 
P.15 

HAP emission points.9'

20

 In the production of SMC, HAP emissions are released from 

the doctor box and the part of the SMC machine where the resin is metered onto carrier films and 

exposed to the open air. Further HAP emissions are released at the compaction belt, where the 

upper and lower paste beds are brought together. During the maturation process, more HAP are 

released until the product reaches its desired molding viscosity. 

1.3.14 Spray Lay-up 

Process description.91314 Spray lay-up is an open mold process that uses mechanical 

spraying equipment that atomizes the resin. In the spray lay-up process, glass fiber reinforcement 

and catalyzed resin are typically sprayed on a mold with a specialized "chopper" spray gun. A 

chopper spray gun simultaneously chops continuous fiber reinforcement into suitable lengths and 

applies it with the catalyzed resin spray. The sprayed resin precoats the chop and both are 

deposited at the same time to the desired layer thickness on the mold surface or on the gel coat 

that was applied to the mold. Woven roving or mats can also be used instead of chopped fiber, in 

which case a spray gun would be used instead of the chopper gun. Basically, there are catalyst 

injection systems which are external mix spray guns and two-pot systems which are internal mix 

spray guns. Catalyst injection guns add catalyst to the already promoted resin through a special 

catalyst injector. This injector pre-measures the amount of catalyst added, which is usually 0.5 to 

2 percent by weight. In the case of a two-pot spray gun,the resin system itself is divided into two 

parts. One side is catalyzed, whereas the other side is promoted. When the two parts are sprayed 

together, a curing reaction is initiated. Airless, air assisted, HVLP, and conventional airatomized spray guns are used in spray lay-up operations, although conventional air spray 

equipment has been virtually replaced by the other technologies. Airless systems dispense the 

resin with hydraulic pressure through special nozzles that break up the resin stream into small 

droplets which saturate the reinforcement. Air atomized spray guns use pressurized air in the gun 

to spray the resin. 

Once the material has been applied to the mold, brushes or rollers are used to remove any 

entrapped air and to assure that the laminate is thoroughly "wet out." Layers of chopped 

1-24 DRAFT 3/16/98 
P.16 

material or specialized reinforcements can be added to the laminate depending upon the 

requirements of the application. 

Parts produced in spray lay-up operations include auto and truck body parts, swimming 

pools, tubs and showers, electrical and equipment housings, tanks, and furniture. The production 

rate is greater for spray lay-up than hand lay-up/bucket and tool application, but generally more 

resin is used in producing similar parts by spray lay-up because of overspray during application. 

HAP emission points.14 The emissions associated with spray lay-up are released during 

application of the resin and the post-application steps of rolling and curing. Hazardous air 

pollutants are emitted from wet product surfaces during rolling and curing and from brushes or 

rollers used to remove entrapped air from the applied resin. It is common practice to apply 

several coats of resin to achieve the desired product thickness. The surface area of each layer 

represents a source of hazardous air pollutant emissions. 

1.4 ANCILLARY PROCESSES 

1.4.1 Cleaning6 

In cleanup operations, a variety of cleaners and solvents that do not contain HAP are used 

including acetone, dibasic ester, diacetone alcohol, and water-based resin emulsifiers or detergent 

cleaners. Even though acetone is treated as a hazardous chemical under RCRA and the Clean 

Water Regulations, acetone is not a HAP. Acetone and other similar solvents like dibasic ester 

and diacetone alcohol are widely used to remove uncured resins from spray equipment, rollers, 

brushes, tools, finished surfaces, and the hands of employees. As a replacement for the 

traditional cleaner acetone, some facilities have switched to water-based resin emulsifiers or 

detergent cleaners. Wash tanks containing the water-based cleaners are used for soaking and 

scrubbing tools. Once the tools are clean, they are dried by dipping the tool or brush into a small 

bucket of acetone or an acetone substitute. Since the primary cleaning is usually done by a 

water-based cleaner, the small amount of acetone used for drying is exchanged infrequently. 

When the wash tanks with the water-based cleaner are emptied, the liquid can be discharged into 

a sanitary sewer. The solids in the bottom of the tank are trapped and disposed of separately. 

Some facilities still use HAP containing cleaners such as methylene chloride as a vapor 

degreaser and for liquid cleaning of parts and equipment. Other HAP components in cleaners 

1-25 DRAFT 3/16/98 
P.17 

may include methyl ethyl ketone, xylene, toluene, and 2-butoxyethanol. 

1.4.2 Resin Mixing6," 

In larger operations, the mixing process is usually carried out in large mixing vats into 

which resin, filler, pigments, and other ingredients are pumped in an automated process. Smaller 

operations may manually add the different ingredients to mixing drums. As the ingredients are 

added during the mixing operation, the containers are generally uncovered, allowing HAP to be 

emitted from the resin. During the actual mixing process, vessels may be completely or partially 

covered. In the 1993 screening survey, about half of the facilities reported covered or partially 

covered mixers. 

1.4.3 HAP Containing Material Storage6,13 

The HAP containing materials that are stored a plastic composites production facilities 

include resins, gel coats, catalysts, mold release agents, and cleaning solvents. These HAP 

containing materials can be stored in permanently mounted storage tanks or in temporary storage 

containers, such as buckets and day tanks. Most small production facilities purchase and store 

their resins in 55 gallon drums, while larger firms purchase practically all of their resins in bulk 

and store them in large storage tanks. The sizes of storage vessels vary greatly and range from 5 

gallon buckets to storage tanks as large as 60,000 gallons. The majority of the facilities that used 

storage tanks reported sizes ranging from 1,000 to 15,000 gallons in the 1993 screening survey.6 

Materials such as gel coats, tooling resin, fire retardant resins, cleaning solvents, and other HAP 

containing additives are almost always purchased and stored in 55 gallon drums. Bulk systems 

are better suited for delivering large quantities of resin to vats for mixing with fillers or other 

additives. The purchase of drums, however, allows smaller facilities the flexibility to meet 

seasonal demands in terms of quantities purchased. This practice enables smaller operations to 

maintain fresh stock at all times. In addition, drums do not require installation of expensive 

storage tanks, resin delivery pumps and piping, and periodic storage tank cleanup. Drums are, 

however, difficult to dispose of and may be considered hazardous material when they contain 

liquid residue. They also require agitation to prevent stratification and to maintain uniform 

properties. HAP emissions from storage tanks are either working losses that occur while filling 

the tank, or breathing losses due to expansion from temperature changes. HAP emissions from 

1-26 DRAFT 3/16/98 
P.18 

drums occur during resin agitation, resin withdrawal, and evaporation of residues left in the 

drums. Emissions from HAP containing storage containers also occur when these containers are 

left uncovered. 

1-27 DRAFT. 3/16/98 
P.19 

1.5 REFERENCES 

1. SPI Composites Institute, Introduction to Composites Reference Handbook. 1992. 

Docket No. H-I-8. 

2. Strum, M., U.S. Environmental Protection Agency to Plastic Composites Project File. 

Date . Memorandum. Emission Reduction Techniques for the Plastic Composites 

Production. Docket No. A-94-52. Document No. II-B- . 

3. 1992 Toxic Release Inventory System. 

4. Standard Industrial Classification Manual, National Technical Information Service. 

1987. 

5. Standard Industrial Classification Manual, National Technical Information Service. 

1972. 

6. Responses from section 114 screening survey sent to the plastic composites 

industry. 1993. 

7. The Society of the Plastics Industry, Inc., Facts & Figures of the U.S. Plastics Industry. 

September 1994. Docket No. IH-18. 

8. Trip report of plant visit to Glastic Corporation, South Euclid, OH. August 11, 1993. 

Docket No. H-B-6. 

9. SPI Composites Institute. Introduction to Composites Reference Handbook. 1994. 

10. Telecon. W. Dunston, EPA:OAQPS, with B. Kinman, Fibercast. Discussion of 

centrifugal casting process and its controls. August 4, 1995. Docket No. II-E-24. 

11. Hillis, R. and D. Davis. Waste Reduction Strategies for Fiberglass Fabricators. Officeof 

Waste Reduction, North Carolina Depaitment of Environment, Health, and Natural 

Resources. 1995. Docket No. H-I-20. 

12. Section 114 screening survey response from Sterling Plumbing Group, Inc., Huntsville, 

Alabama. 1993. Docket No. H-D-593. 

13. Rogozen, M., Science Applications, Inc. Control Techniques for Organic Gas Emissions 

from Fiberglass Impregnation and Fabrication Processes. Prepared for California Air 

Resources Board, Sacramento, CA. June 1982. Docket No. U-I-3. 

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P.20 

14. Compilation of Air Pollutant Emission Factors. AP-42. U. S. EPA, Research Triangle 

Park,NC. pp. 4.12.1 - 4.12.10. Docket No. II-A-l. 

15. Kelley, L., et al., The Dow Chemical Company. Reduction of Styrene Emissions for 

Filament Winding Operations. Docket No. H-I-19. 

16. Elsherif, M. Staff Report, Proposed Rule 1162 - Polyester Resin Operations, South Coast 

Air Quality Management District. Rule Development Division, El Monte, CA. NTIS 

document number PB82-251109. January 23,1987. Docket No. H-I-4. 

17. Dawson, D.K. Cast Polymers Capture Sophisticated Markets. Composites Technology. 

September/October 1995. Docket No. H-I-35. 

18. Lacovara, B. The Year of the Non-Spray Application. Composites Fabrication. March 

1997. Docket No. H-I-42. 

19. Dillner, R. Creative Pultrusions, Inc. Applications for Pultruded Products. Undated. 

Docket No. II-I-2. 

20. Trip repoit of plant visit to Premix, Inc., North Kingsville, OH. August 11,1993. 

Docket No. II-B-5. 

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