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OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

24) II-J-15 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 24 of 36 
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From: 

To: 

Date: 

Subject: 

Alex Sizemore <anomaly@prodigy.net> 

Keith Barnett <BARNETT.KEITH@epamail.epa.go\ 

1/11/00 3:57pm 

Emission Standards: Small Business Concerns 

Mr. Keith Barnett 

Emission Standards Division (MD-13) 

> 

JAN 1 9 2001 

EPA AIR DOCKET J 

Re: Small Business concerns about pending MACT for the Small Business Advocacy Review 

Panel consideration. 

Arrowhead Plastic Engineering, Inc. is a 27 year old company, employing approximately 190 

people, located in three states, and is primarily a custom fabricator. Growing out of a garage 

shop operation, the first of four current plants was an adaptation of an old school-house building 

configuration. This facility currently has fourteen (14) exhaust stacks and eleven (11) emission 

generating operations. 

Although our business track record and the flexibility of being a custom fabricator affords us 

potential business opportunities for significant growth on a regular basis, the proposed 100 TPY 

(Ton Per Year) emission limit that would require 95% control and 100% capture will prohibit this 

plant from ever pursuing it's Title V operating level of 249 TPY. The cost, regardless of who's 

system or estimated cost per stack is used for add on controls to 14 stacks would be economically 

prohibitive and will restrict the future growth and business opportunities for this plant to 100 TPY 

ifthis becomes the MACT limit requiring 95% control for existing businesses. 

Our second plant has a similar situation in that it consists of five (5) buildings spread over sixteen 

(16) acres of land. Therefore, due to the physical characteristics ofthis plant, the 95% control 

and 100% capture would also be an economic impossibility. Thus, the proposed 100 TPY MACT 

limit requiring this 95% control will also limit the potential growth ofthe second ofour three (3) 

custom fabricating plants. 

Our third plant is the newest ofthe three (3) and is all in one (1) building with appropriate control 

devices. However, this plant is operating near its capacity and would require a major investment 

for expansion and would then be required to have 95% control to meet the MACT requirements. 

This would then also become economically prohibitive and will restrict the potential for future 

growth. . 

"Arrowhead as a three state corporation and twenty-seven year growth history, therefore, has its 

future growth potential restricted by the proposed 100 TPY limit that would require add on 

controls." 

Also, while we have invested in converting one plant to flow coaters and a second plant primarily 

uses power-fed rollers, we still have serious problems meeting the MACT point levels due to our 

"custom" molding requirements for gel coats and secondary bonding operations. In one plant 

alone we have thirty-seven (37) different gel coats, many requiring UV resistance for custom 
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truck and bus body parts or other similar exterior applications. These applications typically have 

gel coats specified by the customer which are required to meet transportation industry durability 

requirements that could not be met by the lower styrene percent gel coats. 

One ofour primary products in one plant is commercial truck roofs up to 24 feet in length. 

These roofs have galvanized steel support bows that are automatically bonded to the roof with 

adhesive. We have thus far been unable to find a lower styrene content resin that will maintain the 

adhesion characteristics ofthe current 41% orthophalic resin. 

Many ofour custom products for our customers require secondary laminations of structural 

components for mounting purposes. These customers are not willing to risk resin changes that 

might adversely effect these secondary bonding operations and lead to product liability problems. 

Therefore, to change resins to meet the proposed MACT point values will require very expensive 

adhesion testing at the very least and will also be a very long term process if even possible. 

Please consider the ramifications listed above in finalizing your MACT standards. We have been 

building this company for nearly 28 years in a very competitive market and would like the 

opportunity to continue to grow our business for our employees and future generations. 

Thank you for your consideration in establishing the MACT standards. 

Sincerely, 

Richard L. Moore 

V.P. Engineering & Quality 

Arrowhead Plastic Engineering, Inc. 

eMail: plastic@indy.net 

CC: John Schwitzer <jschwtzr@gte.net>, Arrowhead Plast...