p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

23) ll-J-14 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 23 of 36 
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XERXES6 2 T ' 

CORPORATION 

VIA FAX AND MAIL 

January 10, 2000 

Mr. Keith Barnett 

Office of Air Quality Planning and Standards 

Emission Standards Division (MD-13) 

Organic Chemicals Group 

Research Triangle Park, NC 27711 

RE: SBREFA Meeting Follow-up 

Dear Keith: 

The issues that Xerxes and Proform are most concerned about, and which were 

addressed during my brief presentation on December 14, 1999, are as follows: 

1. The cost alone to accurately monitor the regulations is estimated at $30,000 -

$40,000 annually, per plant. Xerxes has seven plants. This will require 

management personnel with the time, training, skill and ability not only to keep 

accurate records, but also a management information system to advise the plant 

management of the MACT implications on the business. 

This cost cannot be passed along to our customers because our competition, 

which uses low carbon steel to produce barge covers and underground steel 

tanks, would be at a significant advantage. Moreover, we are competing with 

foreign steel that has been dumped into our markets, making the competitive 

situation even worse. 

2. The 95% capture technology could not be achieved with the large components 

such as Proform's barge covers (23' x 33' molds). The mold size creates a 

situation where the material is applied by an impregnator, which travels over the 

mold, plus gun booms which pivot over and away from the mold surface. In 

addition, the molds are mounted on carts, which travel from station to station. 

CORPORATE OFFICE/7901 XERXES AVENUE SOUTH, MINNEAPOLIS, MINNESOTA 55431-1288 

PHONE (612) 887-1890 FAX (612) 887-1870 
P.3 

Page Two 

SBREFA Meeting Follow-up 

January 10, 2000 

3. Xerxes and Proform believe that the 100 TPY threshold for a small business is 

not realistic, not economically feasible, and not capable of financing. No lending 

institution will finance such an expensive project against a low capitalized plant. 

The threshold, therefore, should be raised to 200 TPY or above before it will be 

realistic or make any economic sense. 

Based on the proposed MACT floors as currently drafted, Xerxes believes it can 

meet the MACT floors in four tank plants, but would fall short in three other plants 

(see attached Table A). The table is based on the production data as of 

November 30, 1999. In making our calculations, Xerxes used the best available 

flowchopper technology for those activities where such use has proven suitable. 

Even though flowchopper technology was not actually used during the data time 

period for all plants, Xerxes used the flowchopper point values where we verified 

that it was practical to use such technology in our operation. Xerxes' composite 

plant point value margin is extremely thin in terms of meeting the MACT floors as 

currently proposed. Even when Xerxes implemented the use of flowchopper 

technology, we were unable to meet the requirements in three of our plants. 

Xerxes has not been able to use the flowchopper technology in vertical tank 

mandrels. As a result, this hampers Xerxes' ability to meet MACT and makes 

averaging essential to our operations and MACT compliance. 

Xerxes' ability to comply with the proposed standard is in question. Therefore, 

the opportunity to use a calendar-based composite point value is critical. Our 

average order-to-ship time is 3 to 5 weeks. With market surges and no control 

over our customer's product orders and options, Xerxes has no assurance that it 

could meet a rolling 12 month average below the MACT floors. Given our normal 

market shipping times, order surges and seasonal fluctuation over a calendar 

year, the calendar-based composite point value approach would be essential. 

One reason why Xerxes' plant composite point values (using the proposed 

MACT floor set forth in Table B hereto) are marginal is the low point value of 124 

for the "CR Manual Resin Application." We use hand lay-up to assemble our 

tanks and add accessories such as fittings, monitors, manways, tops, baffles, 

pipes and flat bottoms. This resin has the same HAP content as used in making 

the tank itself. The low point value of 124 used for the "CR Manual Resin 

Application," therefore, is not realistic for a typical corrosion fabricator such as 

Xerxes, that manufacturers large tanks and ducts. The "CR Manual Resin 

Application" database was set by a fan manufacturer, which appears to conduct 

far more hand lay-up using a much lower HAP content resin. This type of single 

product manufacturing has no relationship to Xerxes' bonding of accessories to 

its large tanks. 
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Page Three 

SBREFA Meeting Follow-up 

January 10, 2000 

Therefore, Xerxes recommends that, under the corrosion classification, the CR 

Manual Resin Application point value should be the same as the CR Mechanical 

Resin Application point value. 

Xerxes is particularly concerned over the potential impact of product changes 

and what is meant by "reconstruction." Our products often change over a period 

of time. Your present rules of the 50% of the cost to build a new facility sized for 

the new product may be reasonable to some industries; however, since most 

Xerxes facilities have a low capital cost, it is not fair to our company. We know 

that new product opportunities are a way of life for our business. We cannot be 

restricted by rules that do not provide a practical solution or flexibility to build our 

products or convert our facilities, as needed. 

I hope that the foregoing explains our position. If not, please call me for any needed 

clarification. 

Thank you for the opportunity to meet with your group and express our concerns. 

Yours truly, 

Neil C. Olsen 

VP - Manufacturing Operations & 

Materials Management 

NCO/lmw 

Attachment 

n/MACT Followup.doc 
P.5 

TABLE A 

MACT Compliance 

Anaheim, CA 

Avon, OH 

Hagerstown, MD 

Lakeland, FL 

W. Memphis, AR 

Seguin, TX 

Tipton, IA 

Weighted 

Average 

MACT 

Point Value 

(Ib/ton) 

165.9 

184.1 

175.0 

181.3 

133.8 

187.2 

174.0 

Weighted 

Average 

MACT Floor 

(Ib/ton) 

185.2 

182.1 

183.6 

178.2 

135.8 

185.5 

186.6 

Weighted 

Percent 

of MACT 

Floor 

(% of floor) 

89.5 

101.1 

95.3 

101.7 

98.5 

100.9 

93.3 

Using our latest calendar year data. 

• Applied best available technology to all plants, even though 

they did not have the equipment. 
Table 1. Existing Source MACT Floors For Open Molding and Centrifugal Casting 

OQ 

UJ 

-J 

m 

< iSource 

Open Molding 

Centrifugal Casting 

Process/Product Groupings 

Corrosion Resistant (CR) Mechanical Resin 

Application 

Non CR Mechanical Resin Application-Unfilled 

Non CR Mechanical Resin Application-Filled 

Manual Resin Application-Tooling 

Mechanical Resin Application-Tooling 

CR Manual Resin Application 

Non CR Manual Resin Application 

CR Filament Winding 

Non CR Filament Winding 

Tooling Gel Coating 

Pigmented Gel Coating 

Clear Production Gel Coating 

NonCR 

CR 

Existing Sources 

MACT Floor 

190 

104 

144 

97 

256 

124 

76 

163 

178 

394 

265 

504 

396 

536 

Required HAP 

Content' 

48.3 and FC 

37.1 and FC 

33.9 

36 

50+%andFC 

40 

32.3 

42 

45 

38 

30 

44 

35.5 

48 

Facility which sets floor" 

An Cor Industrial Plastics Inc. (42 and 

50% FC) 

Custom Fiberglass Molding. Inc. 

Hydro Systems, Inc. (42.6 and CF) 

Norton Performance Plastics(47 and 

VB) 

Prestigious Accessories Inc. (43) 

Hartzell Fan, Inc. 

CDR Systems Corp (35 and VB) 

Industrial Fiberglass Specialties, Inc. 

Water Heater Innovations, Inc.. 

Marble Creations 

U. S. Fiberglass Products Inc. 

Laminated Products Inc 

Henderson, Black & Green Inc. 

Average of Raven and Fibercast 

' Represents the HAP content required to meet the point value. Where FC is shown it is assumed 100 flow coaters are also used. 

b

 Where the facility representing the floor meets the point value using a resin/gel coat with a different HAP content than is shown in the previous column, the resin HAP 

content and other controls used at the facility are shown in parenthesis. FC = Flow Coater, VB = Vacuum Bagging, CF = Carbon Filters