p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

$fj2l) ll-E-181 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:11 AM Sheet 221 of 264 
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_^__g 

TO: 

FROM: 

MEMORANDUM 

Madeleine Strum 

EPA/OAQPS/CCPG 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

r}-9j^z 

DATE: August 17, 1998 

IPA MR DOCKET 

SUBJECT: Minutes of July 9,1998 Meeting Between EPA, WemerCompny,"an~d"tKe" 

Composites Institute of the Society of Plastics Industry 

LOCATION: Pacific Environmental Services, Inc. (PES)/Durham, NC 

8:30 am -12:00 pm 

PARTICIPANTS: 

Mr. Daniel Boyd 

Mr. Dennis DeSilvey 

Mr. Daniel Helman 

Mr. Robert Jemison 

Ms. Melanie Proctor 

Ms. Madeleine Strum 

Composites Institute of the Society 

of Plastics Industry (SPI) 

Werner Company 

Werner Company 

PES 

PES 

EPA/ESD/CCPG 

(410) 827-6244 

(412) 588-2000 

(412) 588-2000 

(919) 941-0333 

(919) 941-0333 

(919) 541-2383 

PURPOSE 

One purpose of the meeting was to gain a better understanding of pultrusion operations 

using pre-wet resin injection. In order to accomplish this objective, representatives of the 

Werner Company showed a video tape of their pre-wet resin injection process that was taped at 

their Greenville, Pennsylvania, facility. Another purpose ofthe meeting was to generate a wet 

area enclosure defimtion for pre-wet resin injection based on the wet area enclosure defimtion 

for pultrusion lines with open baths. 

DISCUSSION 

After Mr. DeSilvey and Mr. Helman presented the video tape of their pre-wet resin 

injection process, they explained individual steps in the process and answered process-related 

questions. Mr. DeSilvey explained that in the production of ladder rail using pre-wet resin 

injection, the Werner Company pre-wets one layer of reinforcing vail, which travels 

approximately 15 inches until another layer of veil is placed on top and on the bottom of the 

first layer. The three layers of veil then travel approximately another 15 inches until they 
P.3 

Madeleine Strum 

August 17, 1998 

Page 2 

reach the die. Mr. DeSilvey indicated that complete wet out is accomplished in the die where 

additional resin is injected. He further explained that resin drip occurs at three main points in 

the process: (1) the pre-wet resin application point, (2) the point where the pre-wetted veil is 

joined with the top and bottom layers of veil, and (3) the entrance of the die. A drip pan that 

collects the resin drip begins prior to the pre-wet station and extends a few inches past the 

entrance to the die. 

Mr. DeSilvey pointed out that the terminology in the EPA's proposed wet area 

enclosure definition for pultrusion lines with open baths, which is shown in Attachment I, is 

not applicable for their pultrusion lines with pre-wet resin injection. He stated that a wet area 

enclosure definition that uses terminology related to pre-wet resin injection would be necessary 

for the Werner Company to use this compliance option for their pre-wet resin injection 

pultrusion lines. The meeting then focused on creating a wet area enclosure definition for prewet resin injection based on the wet area enclosure definition for pultrusion lines with open 

baths. The proposed wet area enclosure definition for pultrusion lines with pre-wet areas prior 

to direct die injection is shown in Attachment EL 

Mr. Helman indicated that the Werner Company reviewed the EPA's proposed wet area 

enclosure definition for pultrusion lines with open baths. He stated that enclosures on their 

open bath pultrusion machines may not be able to be extended to within 0.5 inches or less of 

the die entrance because operators need access to remove glass fibers that collect at the die 

entrance. Ms. Proctor asked if the Werner Company could collect measurements from the 

open bath pultrusion lines and detennine the minimum amount of clearance needed between the 

end of the enclosure and the entrance of the die. Mr. Helman responded that he would collect 

this infonnation and submit it to the EPA. Ms. Strum indicated that the EPA would review the 

wet area enclosure definition to determine if the distance between the end of the enclosure and 

the entrance of the die can be expressed in terms of a percentage of the length of the resin bath. 

At the end of the meeting, Mr. Boyd provided Ms. Strum with a revised copy of 

industry's proposed compliance option 2 (control factor approach) for pultrusion (see 

Attachment IU). He asked Ms. Strum to review and provide comments on this industry 

proposal. 

Action Items for Industry Representatives: 

Collect measurements from the open bath pultrusion lines and determine minimum 

clearance needed between the end of the enclosure and the entrance of the die. 

sl 

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Madeleine Strum 

August 17, 1998 

Page 3 

Action Items for EPA: 

1. Draft the wet area enclosure definition for pultrusion operations with pre-wet areas 

prior to direct die injection (see Attachment II). 

2. Provide the Werner Company with a definition for malfunction (see Attachment IV). 

3. Review the wet area enclosure definition for pultrusion lines with open baths to 

determine if the distance between the end of the enclosure and the entrance of the die 

can be expressed in terms of a percentage of the length of the resin bath (see 

Attachment V). 

4. Review and provide comments on industry's proposed compliance option 2 (control 

factor approach) for pultrusion (see Attachment VI). 

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Attachment I 

WET AREA ENCLOSURE DEFINITION - PULTRUSION LINES WITH OPEN BATHS 

(DRAFT 07/15/98) 

If wet area enclosures are used to meet the Maximum Achievable Control Technology standard for 

pultrusion lines with open baths, they shall be designed and installed according to the following 

criteria: 

1. The enclosure shall cover and enclose the open bath and forming area in which 

reinforcements are wet out and are moving toward the die(s). The surfaces ofthe enclosure 

shall be closed except for openings to allow material to enter and exit the enclosure. 

2. For pultrusion machines with a radio frequency (RF) pre-heat unit, the enclosure shall extend 

from the beginning ofthe resin bath to within 12.5 inches or less ofthe entrance ofthe RF 

pre-heat unit If the stock that is within 12.5 inches or less ofthe entrance to the RF pre-heat 

unit has any drip, it does require an enclosure. The stock exiting the RF pre-heat unit is not 

required to be in an enclosure if the stock has no drip between the exit ofthe RF pre-heat unit 

to within 0.5 inches ofthe entrance ofthe die. For pultrusion machines without a RF preheat unit the enclosures shall extend from the beginning ofthe resin bath to within 0.5 inches 

or less ofthe die entrance. 

3. The total open area of the enclosure shall not exceed 4.0 % of the following calculated 

surface area (A): 

A = 2(HL + HW + LW) 

where, 

H=height measured from the top ofthe resin bath to the top ofthe enclosure. 

The height ofthe enclosure shall not be greater than 1.75 x the depth ofthe 

resin bath. 

L = length measured from the beginning of the .resin bath to within 12.5 

inches (or less as applicable) ofthe RF pre-heat unit or to within 0.5 inches 

ofthe die entrance for pultrusion machines without RF pre-heat units. 

W = width equal to the width ofthe resin bath. 

(a) All areas which are considered open need to be counted in the total open area 

calculation. 

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(b) The area which is displaced by entering reinforcement or exiting product is 

considered open. 

(c) Areas that are covered by brush covers are considered closed. 

4. Open areas for level control devices, monitoring devices, agitation shafts, and/or fill hoses 

shall have no more than 1.0 inch clearance. 

5. Access panels, doors, and/or hatches that are part ofthe enclosure shall remain closed except 

during malfunctions. 

6. No fans, blowers, and/or air lines shall be allowed within the enclosure. The enclosure shall 

not be ventilated. 

7. Resin drip off at the die entrance shall be channeled through a closed pipe or covered trough 

into a container such that the following conditions are met: 

(a) The maximum allowable vertical distance that resin may drip through the open air 

from the bottom ofthe die to the closest point ofthe closed pipe or covered trough 

shall not exceed 1.0 inch. 

(b) The size ofthe opening in the pipe or trough that collects the resin drip shall be no 

longer than the width ofthe die and no wider than 1.0 inch. 

(c) The maximum allowable vertical distance that resin drip may be exposed to air from 

the exit ofthe closed pipe or covered trough to the opening ofthe container shall not 

exceed 6.0 inches. 

(d) The size ofthe opening in the container that collects the resin drip shall not exceed 

1.0 inch in diameter. A funnel may be used to aid in the collection ofthe resin drip. 

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Attachment II 

WET AREA ENCLOSURE DEFINITIONPULTRUSION LINES WITH PRE-WET AREAS PRIOR TO DIRECT DIE INJECTION 

(DRAFT 07/15/98) 

If wet area enclosures are used to meet the Maximum Achievable Control Technology standard for 

pultrusion lines with reinforcement pre-wet areas prior to direct die injection, they shall be designed 

and installed according to the following criteria: 

1. The enclosure shall cover and enclose the forming area in which reinforcements are pre-wet 

and are moving toward the die(s). The surfaces ofthe enclosure shall be closed except for 

openings to allow material to enter and exit the enclosure. 

2. The enclosure shall extend from the point at which the resin is applied to the reinforcement 

to within 0.5 inches or less ofthe die entrance. If there is no drip ofthe wet reinforcement 

12.5 inches prior to the die entrance (except at the face ofthe die), the enclosure shall extend 

from the point at which resin is applied to the reinforcement to within 12.5 inches or less of 

the die entrance. 

3. The total open area ofthe enclosure shall not exceed 4.0 % ofthe following calculated 

surface area (A): 

A = 2(HL + HW + LW) 

where, 

H = height measured from the bottom of the drip pan to the top of the 

enclosure. The height ofthe enclosure shall not be greater than 14 inches. 

L = length measured from the point on the enclosure coinciding with the 

point at which resin is applied to the reinforcement to the point on the 

enclosure closest to the die entrance. 

W = width of the wet reinforcement at the resin application point plus an 

additional 3.0 inches of clearance at each side ofthe wet reinforcement. 

(a) All areas which are considered open need to be counted in the total open area 

calculation. 

(b) The area which is displaced by entering reinforcement or exiting product is 

considered open. 

(c) Areas that are covered by brush covers are considered closed. 

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4. Open areas for level control devices, monitoring devices, agitation shafts, and/or fill hoses 

shall have no more than 1.0 inch clearance. 

5. Access panels, doors, and/or hatches that are part ofthe enclosure shall remain closed except 

during malfunctions. 

6. No fans, blowers, and/or air lines shall be allowed within the enclosure. The enclosure shall 

not be ventilated. 

7. Resin drip off at the die entrance shall be channeled through a closed pipe or covered trough 

into a container such that the following conditions are met: 

(a) The maximum allowable vertical distance that resin may drip through the open air 

from the bottom ofthe die to the closest point ofthe closed pipe or covered trough 

shall not exceed 1.0 inch. 

(b) The size ofthe opening in the pipe or trough that collects the resin drip shall be no 

longer than the width ofthe die and no wider than 1.0 inch. 

(c) The maximum allowable vertical distance that resin drip may be exposed to air from 

the exit ofthe closed pipe or covered trough to the opening ofthe container shall not 

exceed 6.0 inches. 

(d) The size ofthe opening in the container that collects the resin drip shall not exceed 

1.0 inch in diameter. A funnel may be used to aid in the collection ofthe resin drip. 

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Therefore the control factor for the direct die injection machine that can be used in Option 2 has 

not been determined. A machine which would have a considerable amount of drip would likely 

not be as effective, and the result of averaging this scenario using the PIC control factor could 

result in establishing equivalence for a situation that is technically not equivalent to the use of 

WAEs. 

It should be noted that in the example calculation for Option 2, the "emission %" would 

need to be the same as the one associated with the Glasforms' test in which a WAE was not used. 

This value is approximately 12.5% (that is, 12.5 pounds of styrene were emitted for every 100 

pounds of styrene used). 

The example calculation presented in Option 2 serves to further illustrate EPA's concern. 

In the example, three lines have a WAE (thus meeting the equipment standard) but three lines do 

not. There are no other emission reduction techniques being used by the three open bath lines. 

Based on the Option 2 proposal, this scenario is considered equivalent to the proposed MACT 

equipment standard. However, this scenario cannot be deemed equivalent to having all lines 

equipped with a WAE because no emission reduction techniques that are more effective than 

WAEs are being averaged with the open bath lines. 

In conclusion, EPA is concerned that Option 2 will result in scenarios that are not 

equivalent to the use of wet area enclosures. We would like to put further efforts into the design 

ofthe Continuous Emission Monitoring Option, which would involve the measurement of 

alternative emission reduction technologies to assure that when averaged or by themselves, the 

resulting collection of techniques would be equivalent to the use of wet area enclosures on all 

machines. 

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Attachment VI 

EPA's Comments on Option 2 ~ 

Action Item from Meeting with Dan Boyd and Werner Representatives 

This document discusses EPA's concerns with "Option 2 - The use of Control Factors..." 

as a means of establishing equivalence to the equipment standard currently being considered as 

MACT for the pultrusion industry. The equipment standard is an enclosure around the wet area 

ofthe pultrusion machine and is denoted a "wet area enclosure" (WAE). Option 2 would allow a 

facility to demonstrate equivalency to the proposed equipment standard by using other specific 

emission reduction techniques for which "control factors" (which estimate the effectiveness of 

the techniques to reduce emissions) were assigned. The option also allows averaging of these 

techniques. These emission reduction techniques are: (1) the use of direct die injection machines 

(2) the use of air flow management to reduce the air flow at the wet area to no more than 15 feet 

per minute, and (3) the use of WAEs. By the nature ofthe control factor equation, lowering the 

HAP content ofthe resin would also be considered an emission reduction technique. 

The primary concern is that Option 2 may allow for scenarios which are not truly 

equivalent to WAEs. One reason is the lack of data to detennine the relative effectiveness ofthe 

emission reduction techniques (and hence control factors) and how they interact with one 

another. There are two studies from which control factor values could be considered: (1) The 

study conducted at Glasforms which determined the effectiveness of a WAE by testing a single 

machine (using a total temporary enclosure [TTE] as defined by EPA and a total hydrocarbon 

analyzer [THA]) with and without the wet area enclosure; and (2) A study conducted by the 

Pultrusion Industry Council (PIC), also on a single machine using a TTE and THA. The PIC 

study determined the effectiveness of a WAE, air flow management, direct die injection, and 

resin injection. Since the WAE at Glasforms is being considered as the equipment standard, it is 

the Glasforms' test data on which the WAE effectiveness needs to be based. Glasforms did not 

test the other techniques that are being considered by the control factor option, therefore no data 

are available on how these techniques relate to the actual production WAE. If air flow 

management is not as effective as the control factor which was assigned to it in Option 2 (which 

was from the PIC study), then Option 2 could result in establishing equivalence for a situation 

that is technically not equivalent to the use of WAEs. 

In addition, the Option 2 equation assumes a linear relationship between resin HAP 

content and pounds of HAP emitted per ton resin used. There has been no testing for pultrusion 

opertions to determine the relationship between the HAP content ofthe resin and emissions nor 

how the HAP content interacts with the other emission reduction techniques. The assumption 

that the relationship between resin HAP content and emissions is linear could result in 

establishing equivalence for a situation that is technically not equivalent to the use of WAEs. 

Furthermore, the data from the PIC study are not valid for determining the control factor 

for direct die injection machines as defined by the proposed PIC definition. The direct die 

injection machine at the PIC smdy had nearly no drip, however, the definition for direct die 

injection machines proposed by the PIC does not have a limitation on the amount of drip. 
P.11 

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1243 0 

Federal Register / Vo l 59. No. 51 / Wednesday. March 16, 1994 / Rules and Regulations 

a State permitting authority is called a 

part 70 pennit in this part. 

9. Section 61.10 is amended by 

adding paragraphs (o) through (j) to read, 

as follows: 

§61.10 Source reporting and waiver 

request 

' * (e) For the purposes of this part, time 

periods specified in days shall be 

measured in calendar days* even if tha • 

word "calendar" is absent, unless 

otherwise spedfied in an applicable 

requirement 

(f) For the purposes of this part, if an 

explicit postmark deadline is not 

specified in an applicable requirement 

for the submittal of a notification, 

application, report, or odier written 

communication tn the Administrator, 

the owner or operator shall postmark 

the submittal on or before the number 

of days specified in the applicable 

requirement For example, if a 

notification must be submitted IS davs 

before a particular event is scheduled to 

take place, die notification shall be 

postmarked on or before IS days 

preceding the event: likewise, if a 

notification must be submitted 15 days 

after a particular event takes place, the 

notification shall be postmarked on or 

before 15 days following the end of the 

event The use of reliable nonGovernment mail carriers that provide 

indications of verifiable delivery of 

information required to be submitted to 

the Administrator, similar to the 

postmark provided by the U.S. Postal 

Service, or alternative means of delivery 

agreed to by the pennitting audiority, is 

acceptable. 

• (g) Notwithstanding time periods or 

postmark deadlines specified in this 

part for the submittal of infonnation to 

the Administrator by an owner or 

operator, or the review of such 

Information by the Administrator, such 

time periods or deadlines may be 

changed by mutual agreement between 

the owner or operator and the 

Administrator. Procedures governing 

the implementation of tiiis provision are 

specified in paragraph (j) of this section. 

(h) If an owner or operator of a 

stationary source in a State with 

delegated autiiority is required to 

submit reports under this part to die 

State, and if the State has an estabUshed 

timeline for die submission of reports 

that is consistent with die reporting 

frequency(ies) specified for such source 

under this part, the owner or operator 

may change tne dates by which reports 

under tiiis part shall be submitted 

(without changing the frequency of 

reporting) to be consistent with the 

State's schedule by mutual agreement 

between the owner or operator and die 

State. The allowance in the previous 

sentence applies in each State beginning 

1 year after the source is requiredto be 

in compliance with the applicable 

subpart ta this part. Procedures 

governing die implementatf on of tms 

provision are specified in paragraph (J) 

of this section. , 

(i) If an owner or operator sup«£_f_f 

one or more stationary sources aifected 

WT ainimnn n III w_— s 

standards set tinder part 60. part 63. or 

both such parts of this chapter, he/she 

may arrange by mutual agreement 

between the owner OT operator and die 

Administrator (or die State with an 

approved permit program) a common 

schedule on which reports reouired by 

each applicable standard shaii be 

submittftd throughout the year. The 

aUowance in the previous sentence 

applies in each State beginning 1 year 

after die source is required to be in 

compliance wim die applicable subpart 

ta this part, or 1 year after the source is 

required to be in compliance with the 

appUcable part 60 or part 63 standard, 

whichever is latest Procedures 

governing die implementation of this 

provision are specified in paragraph (j) 

of this vMTtlon. 

(j)(D(i) Until an adjustment of a time 

period or postmark deadline has been . 

approved by die Administrator under 

paragraphs (j)(2) and (0(3) of tiiis 

section, the owoer ox operator of an 

affected source remains strictiy subject 

to the requirements of tiiis part. 

(U) An owner or operator shall request 

the adjustment provided for in 

paragraphs (0(2) and (j)(3) of this section 

each time he or she wishes to change an 

appUcable time period or postmark 

deadline specified in this part. 

(2) Notwithstanding time periods or 

postmark deadlines specified in this 

part for die submittal of information to 

the Administrator by an owner or 

operator, or die review of such 

information by die Administrator, such 

time periods or deadlines may be 

changed by mutual agreement between 

the owner or operator and die 

Administrator. An owner or operator 

who wishes to request a change in a 

time period or postmark deadline for a 

particular requirement shall request die 

adjustment in writing as soon as 

practicable before the subject activity is 

required to take place. The owner or 

operator shall include in die request 

whatever infonnation he or she 

considers useful to convince die 

Administrator that an adjustment is 

warranted. 

(3) If. in the Administrator's 

judgment, an owner or operator's 

request for an adjustment to a particular 

time period or postmark deadline is 

wananted. die Administrator wiU 

approve the adjustment The 

Administrator will notify die owner or 

operator in writing of approval or 

disapproval of die request for an 

adjustment wititin 15 calendar days of 

receiving sufficient information to 

evaluate die request 

(4) If the Administrator is unable to 

meet a spedfied deadline, he or she wll 

notify the owner or operator of any 

significant delay and inform the owner 

or operator of the amended schedule. 

PART 63-NATIONAL EMISSION 

STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS FOR SOURCE 

CATEGORIES 

* 10. The audiority citation for part 63 

continues to read as foUows: 

Antbcritr: Sections 101.112.114. lie. and 

301 of the Clean Air Act as amended by Pub. 

L. 101-549 (42 U.S.C 7401.7412.7414. 

7416.7601). 

11. Part 63 is amended by adding 

subpart A to read as follows: 

' Subpart A—General Provisions 

' Sac 

63.1 Applicability. 

6 U Definitions. 

633 Units and abbreviations. 

63.4 Prohibited activities and 

circumvention. 

63.5 Construction and reconstruction. 

63.6 Compliance wtth standards and 

maintenance requirements. 

63.7 Performance testing requirements. 

63.8 Monitoring tequii-enients. 

63.9 Notification requirements. 

63.10 Recordkeeping and reporting 

requirements. 

63.11 Conool device requirements. 

63.12 State authority and delegations. 

63.13 Addresses of State air poUution 

controt agencies and EPA Regional 

Offices. _ 

63.14 Incorporations by~referenoe. 

63.15 AvaUabUity of information and 

confidentiaUty. 

^^» ^ A^Qenerni Provisions/ 

ffa-t^Appflcabttlty. 

fa) General. (1) Terms used 

throughout this part are defined ta 

§ 63.2 or in the Clean Air Act (Act) as 

amended ta 1990. except that individual 

subparts of tills part may indude 

specific definitions in addition to or diat 

supersede definitions ta § 63.2. 

(2) This part contains national 

emission standards for hazardous air 

pollutants (NESHAP) estabUshed 

pursuant to section 112 of the Act as 

amended November IS. 1990. These 

standards regulate spedfic categories of 

Stationary sources that emit (or have the 

potential to emit) one or more 

f 0 
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12434 Federal Register 7 Vol. 59. Na 51 / Wednesday.-March 16. 1994 / Rules and Regulations 

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under common control thatamits or has 

ue potential to emit considering 

controls, ta die aggregate, 10 tons per 

year or more of any hazardous air 

' poUutant or 25 tons per year or more of 

any combination of hazardous air . 

poUutants, unless die Administrator 

establishes a lesser quantity, or in die 

case of radionucUdes, different criteria 

from those spedfied in this sentence. 

* Malfunction means any sudden, 

infrequent and not reasonably 

preventable failure of air poUution' 

control equipment process equipment 

or a process to operate ta a normal or 

usual manner. Failures that are caused 

ta part by poor maintenance or careless 

operation ara not malfunctions. 

New source means any affected source 

die constmction or reconstruction of 

which is commenced after die' 

Administrator first proposes a relevant 

emission standard under dus part 

One-hour period, unless otherwise 

defined ta an appUcable subpart means 

any 60-minute period commencing on 

die hour. 

Opacity means die degree to which 

emissions reduce die transmission of 

Ught and obscure die view of an object 

ta the background. For continuous 

opadty monitoring systems, opadty 

means the fraction of taddent light that 

is attenuated by an optical medium., 

Owner or operator means any person 

who owns, leases, operates, controls, or 

supervises a stationary source. 

Port 70 pennit means any permit 

issued, renewed, or revised pursuant to 

part 70 of this chapter. 

Performance audit means a procedure 

to analyze blind samples, die content of 

which is known by die Administrator, 

simultaneously witii the analysis of 

performance test samples ta order to 

provide a measure of test data quaUty. 

Performance evaluation means the 

conduct of relative.accuracy testing. 

caUbration error testing, and other 

measurements used ta validating die 

continuous monitoring system data. 

Performance test means die coUection 

of data resulting from die execution of 

a test method (usuaUy three emission 

test runs) used to demonstrate 

compUance widi a relevant emission 

standard as spedfied ta die perfomiance 

test section of the relevant standard. 

Permit modification means a change 

to a titie V pennit as defined ta 

regulations codified ta this chapter to 

implement title V of the Act (42 U.S.C 

7661). 

Permit program means a 

comprehensive State operating pennit 

system established pursuant to title V of 

the Act (42 U.S.C 7661) and regulations 

codified in part 70 of this chapter and 

applicable State regulations, or a 

comprehensive Federal operating permit 

system .established pursuant to title V of 

the Ad and regulations codified in this 

chapter. 

Pennit revision means any pennit 

modification or administrative permit 

amendment to a tide V permit as 

defined ta regulations codified ta this 

chapter to implement title V of die Act 

(42 U.S.C 7661). 

Pennitting authority means: (1) The 

State air pollution control agency, local 

agency, otiier State agency, or other 

agency authorized by die Administrator 

to carry out a permit program under part 

70 of this chapter; or 

(2) Hie Administrator, ta die case of 

EPA-implemented permit programs 

under tide V of die Act (42 U.S.C 7661). 

Potential to emit means the maximum 

capadty pf a stationaiy source to emit 

a poUutant under its physical and 

operational design. Any physical or 

operational Umitation on die capadty of 

the stationary source to emit a poUutant 

induding air poUution control 

equipment and restrictions on hours of 

operation or on the type or amount of 

material combusted, stored, or' . 

processed. shaU be treated as part of its 

design if the Umitation or die effect it 

would have on ""t«*i"-*« is federaUy 

enforceable. * 

/reconstruction means die 

replacement of components of an 

affected or a previously unaffected 

.stationary source to such an extent that: 

(1) The fixed capital cost of die new 

components exceeds SO percent.of the 

fixed capital cost Uiat would be required 

to construct a comparable new source:. 

and 

(2) It is tecfanolpgically and 

economically feasible for the 

reconstructed source to meet die 

relevant standard(s) estabUshed by the 

Administrator (or a State) pursuant to 

section 112 of die Act Upon ' 

reconstruction, an affected source, or a 

stationary source tbat becomes an 

affected source, is subjed to relevant 

standards for new sources, induding 

compUance dales, irrespective of any 

change ta emissions of hazardous air 

poUutants from that source. 

Regulation promulgation schedule 

means die schedule for the 

promulgation of emission standards 

under this part established by the 

Administrator pursuant to section 

112(e) of the Act and pubUshed in the 

Federal Register. 

Relevant standard means: 

(1) An emission standard: 

(2) An alternative emission standard: 

(3) An alternative emission Umitation: 

or 

(4) An equivalent emission limitation 

established pursuant to seaion 112 of 

the Act that applies to tbe stationary 

source, the group of stationary sources, 

or die portion of a stationary source 

regulated by such standard or 

limitation. 

A relevant standard may include or 

consist of a design, equipment, woric • 

practice, or operational requirement or 

other measure, process, mediod, system, 

or technique (induding prohibition of 

emissions) that the Administrator (or a 

State) estabUshes for new or existing 

sources to which such standard or 

limitation appUes. Every relevant 

standard established pursuant to section 

112 of the Ad indudes subpart A of this 

part and aU appUcable appendices of 

this part or of other parts of this chapter 

tiiat are referenced in diat standard. 

Responsible official means one of the 

foUowing: 

(1 j For a corporation: A president, ' 

secretary, treasurer, or vice president of 

the corporation ta charge of a pnndpal 

business function, or any odier person 

who performs similar poUcy or 

decision-making functions for the 

corporation, or a duly authorized . 

Representative of such person if the 

* representative is responsible for the 

' overall operation of one or more 

manufacturing, production, or operating 

fadUties and either 

(i) The fadUties employ more than 

250 persons or have.gross annual sales 

or expenditures exceeding $25 miUion 

(ta second quarter 1980 dollars); or 

(ii) Ine delegation of audiority to 

such representative is approved ta 

advance by the Administrator. 

(2) For a partnership or sole 

proprietorship: a general partner or die 

proprietor, respectively. 

(3) For a munidpaUty, State, Federal, 

or otiier pubUc agency: eidier a 

prindpal executive officer or ranking 

elected official. For the purposes of this 

part, a prindpal executive officer of a 

Federal agency indudes die chief 

executive officer having responsibUity. 

for die overaU operations of a prindpal 

geographic unit ofthe agency (e.g.. a 

Regional Administrator of the EPA). 

(4) For affected sources (as defined in 

this part) applying for or subject to a' 

title V permit: "responsible offiaal" 

shaU have die same meaning as defined 

ta part 70 or Federal title V regulations • 

in this chapter (42 U.S.C 7661), 

whichever is appUcable. 

flun means one of a series of emission 

or other measurements needed to 

' determine emissions for a representative 

operating period or cycle as spedfied in 

this part. . 

Shutdown means the cessation of 

operation pf an affected source for any 

purpose. 

w 
P.13 

B/BsFornit 

inr I 

271 Barnard Avenue, San Jose, California 95125 

Pax (408)297-0601 Phone (408)297-9300 

Normal Delivery x Urgent Delivery Confidential 

Company: Pacific Environmental 

Services, inc. 

Attention: Melanie Proctor 

cc: Dave Evans 

Dr. Dan Boyd 

FAX* (919)941-0234 

Date: July 28,1998 

From: Terry McQuarrie 

Dear Melanie: 

This FAX is In response to your inquiry of earlier today. With reference to the drawings 

of the depth of the baths at the Birmingham facility, I did forward these dimensions to 

Ms. Linda Herring in my correspondence of May 8,1998. However, the drawings 

themselves are considered CBI as referenced in the letter. However, for the small bath 

the depth of the bath is 8 inches where the enclosure is 14 inches in height, which is the 

1.75 referenced in the May 8,1998 correspondence. You can use this as nonconfidential information, but not the actual drawing attached to the May 8 

correspondence. 

The second item we discussed was the distance from the exit of the enclosure to the die 

as a percentage of the enclosure. For the non-RF baths, this is 0.5 inch/57 inches 

(enclosure) which = 0.877%. However, for the RF enclosure the distance Is 12.5 

inches/98 inches = 12.8%. However, this material is not dripping. So, the critical issue 

is not the distance, but whether the exiting material Is dripping or not, and if it is, it must 

be enclosed. 

I hope this helps. Please call me if you need any further information. 

\i> 
P.M 

Sample Calculation: 

Assumptions -. 

Three lines with open bath 

Three lines with Enclosed Wet Area 

40,000 lb Resin process at 35% styrene processed monthly 

Egual resin usage across lines 

AP-42 emission factor of 0.05 for pultrusion 

[{1.0} x {(40000 x 0.35) x 0.05}/2 

+ {0.2$} x {(40000 x 0.35) x 0.05}/2] / 20 

= 21.0 lbs HAP/ton resin processed 

This would be an acceptable operation as the emissions would be 

less that 22 lbs HAP per ton resin processed. 

Air Flow Management Note: 

In order to achieve the 51 percent reduction in emissions using air 

flow management, an air flow of no more that 15 ft/min across the 

wet area must be maintained. Each facility must determine the 

methods necessary to achieve this air flow and provide evidence to 

assure that it is continually maintained. For example a facility 

can use partial enclosures such as air curtains or tents to direct 

the air flow. In order to assure compliance with the air flow 

rate, the facility may choose to use continuous monitoring and 

recording of results or use maintenance and other records which 

demonstrate that the air flow is maintained at acceptable levels on 

a continuous basis. This requirement gives each facility the 

maximum flexibility to install and demonstrate compliance with the 

provisions of this section 

Enclosed Wet Area Note: 

The EPA has chosen to use a single experiment conducted on a rod 

line at Glasforms to determine the 0.20 control factor for wet area 

enclosure. It should be noted that the PIC has submitted data to 

EPA on ladder rails production that indicates a control factor of 

0.41. More discussion on the appropriate factor for wet area 

enclosure appears to be necessary. 

n 
/f^hnhm^iHl 

OPTION 2 - The Use of Control Factors and Recordkeeping to 

Demonstrate Emissions Less than 22 lbs HAP per ton of resin 

processed. 

Based on the 22 lbs HAP emitted per ton resin processed 

requirement, the following items will be monitored monthly. 

Records of this monthly monitoring aind calculations will be kept 

and be available for inspection by the appropriate authorities. 

1. Total HAPs used in the process based on Inventory, 

Purchasing and Use records and the MSDS SARA 313 HAP 

Component Percentage. 

2. Determination using control factors of the HAPs emitted 

per ton resin processed on a monthly basis. This level 

must be kept below 22 lbs HAP/ton resin processed as a 12 

month rolling average. 

For the purpose of calculating the emissions the following factors 

will used for on line emission controls: 

Control Control Factor 

1. Open bath, wet areas 1.00 

wet resin exposed to air flow 

2. Air Flow Management 0.51 

maximum of 15 ft/min across wet areas 

3. Enclosed wet areas (see Option 4) 0.20 

4. Direct Die Injection (see Option 3) 0.01 

Example Calculation: 

Founds HAP/ton Resin Processed = 

[{Control Factor} x {HAP Used x emission %}]/Tons Resin 

Processed 

where: 

Control factor from above table 

HAP used from purchasing, inventory and use records and MSDS 

documented HAP percentage. 

Emission % from AP-42 or best available data 

CV