P.1 

OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

20) IV-H-1 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:26 AM Sheet 20 of 130 
P.2 

* 

MEMORANDUM 

TO: Reinforced Plastic Composites NESHAP Docket 

FROM: Keith Barnett 

EPA/OAQPS/ESD/MICG 

DATE: January 3, 2002 

SUBJECT: Briefing forthe Small Business Administration and Office of Management and Budget 

on planned changes to the proposed Reinforced Plastic Composites NESHAP. 

LOCATION: Briefing was conducted by teleconference otf Pf^y ^' J <*® 

ATTENDEES: 

Mr. Bryon Allen 

Mr. Keith Barnett 

Mr. Austin Perez 

PURPOSE 

Office of Management and Budget (OMB) 

U.S. Environmental Protection Agency 

Small Business Administration (SBA) 

The purpose of the briefing was to update SBA and OMB on planned changes to the 

proposed Reinforced Plastic Composites ENESHAP. The information provided is attached to this 

cover sheet. 
P.3 

/ 

Keith Barnett 

05/16/2002 11:06 AM 

To: Bryon_P._Allen@omb.eop.gov, austin.perez@sba.gov, Penny 

Lassiter/RTP/USEPA/US@EPA 

cc: Tom Kelly/DC/USEPA/US@EPA 

Subject: Briefing Materials For Reinforced Plastic Composites 

The conference call to discuss changes to the Reinforced Plastic Composites NESHAP is set up for 3:30 

on May 21. The call-in number is 919-541-4332. I have attached the materials I will discuss during the 

briefing. 

OMB-SBA Briefin.q.wr. Cost Effectiveness April 24-2002-Summ; Proposal-Draft Promulgation Floor Compari 

CC-CL tables.xl 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

7-
P.4 

\ 

BRIEFING ON REINFORCED PLASTICS COMPOSITES MACT 

Proposed Rule: 

The rule we proposed required facilities in the following process/product groupings to go abovethe-floor ofthe facility emitted over 100 tpy of HAP (250 tpy if a small business): 

Open Molding 

Centrifugal Casting 

Continuous lamination 

Continuous Casting 

Pultrusion 

SMC Manufacturing 

BMC/Mixing 

Other facilities were not required to go beyond the floor. These facilities were projected to be 

able to meet MACT using pollution prevention (low HAP materials, and non-atomized spray 

application) 

This proposal had an estimated emission reduction of 14,500 TPY for existing facilities. 

The overall cost effectiveness ofthe proposed rule was $2,100 per ton and the incremental cost 

effectiveness was $1,500 per ton for existing facilities 

We did not go above-the-floor for smaller facilities because the economic impacts would be 

significant. 

Planned Major Changes for Final Rule 

• Convert to use of unified emissions factors. This eliminates having facilities deal with two 

sets of equations. One to determine emissions and one to determine compliance with 

MACT. 

Modify floor levels of control as a result of comments to the proposed rule (see tables). 

Existing facilities should still be able to meet these levels with pollution prevention control 

techniques. 

Limit the above-the-floor requirements to centrifugal casting, continuous lamination, 

continuous casting. Changes in our cost algorithms and the floor have resulted in a new 

incremental cost effectiveness of well over $5000 per ton for all process/product 

groupings except these three. (See tables) 

Where we go above the floor, set the threshold as 100 tpy for both large and small 

businesses, rather than 100 tpy for large businesses and 250 tpy for small. There would be 

no additional existing small businesses impacted by setting one threshold rather then two. 

(See table of centrifugal casting and continuous lamination/casting facilities) 

This changes the emission reduction to approximately 8,300 tpy compared to 12,500 if we kept 

1 
P.5 

i 

the above-the-floor option was unchanged from the proposed rule. However, based on the cost 

impacts we calculated, we decided to not go above-the-floor except for centrifugal casting, 

continuous lamination, and continuous casting. These three processes produce high concentration 

emission streams, and are more cost-effective to control. In the case of continuous lamination 

and continuous casting, the floor level of control required add-on controls. 

4 
Summary of Regulatory Option Cost Effectiveness for the Reinforced Plastic Composites Source Category 

Existing Sources -1997 

NOTE: Add Data for facilities added to the database -- numbers listed in table to the right 

Cost Effectiveness April 24-2002-Summary.xls 

12/31/2002 

U") 

Subcategory 

Open Molding 

Process 

Manual Resin Application 

Mechanical Resin Application 

Filament Winding 

Gel Coat Application 

Totals for Open Molding Subcategory 

Closed Molding Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Totals for Closed Molding Subcategory 

Centrifugal Casting Centrifugal Casting 

Totals for Centrifugal Casting Subcategory 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mafls 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mafls 

Totals for Reinforced Plastic Composites Source Category 

Process/Product Grouping 

Corrosion-Resistant 

Non Corrosion-Resistant 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant (Unfilled) 

Non Corrosion-Resistant (Filled) 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant 

Pigmented Production 

Clear Production 

Tooling / Mold Manufacturing 

Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Corrosion-Resistant 

Non Corrosion-Resistant 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

I 

MACT Floor (Actual) 

Total 

Reduction 

(tpy) 

29.6 

61.3 

0.8 

474.7 

4291.4 

0.0 

48.4 

21.2 

0.5 

894.7 

74.9 

19.2 

5916.7 

0.0 

0.0 

0.0 

0.3 

12.9 

13.2 

358.2 

0.0 

127.8 

0.0 

807.1 

164.2 

0.0 

7387.1 

Annual 

Cost 

(J/yr.) 

$1,681,683 

$722,492 

$111,017 

$1,465,347 

$6,460,320 

$0 

$204,752 

$862,776 

$8,870 

$5,695,417 

$406,224 

$698,367 

$18,317,266 

$55,852 

$9,719 

$65,571 

$41,567 

$43,401 

$84,968 

$600,761 

$44,953 

$312,746 

$12,916 

$367,322 

$489,295 

$324,092 

$20,619,890 

Reg. Option w/ Size Limit (Actual) 

Average Total 

Cost Reduction 

Effectiveness 

(Srton) (tpy) 

$56,772 

$11,785 

$131,740 

$3,087 

$1,505 

N/A 

$4,231 

$40,772 

$17,520 

$6,366 

$5,425 

$36,355 

$3,096 

N/A 

N/A 

N/A 

N/A 

$3,357 

$6,445 

$1,677 

N/A 

$2,448 

N/A 

$455 

$2,980 

N/A 

$2,791 

29.6 

170.3 

20.0 

500.4 

6216.7 

0.0 

181.7 

21.2 

134.2 

2435.0 

192.6 

59.0 

9960.6 

0.0 

0.0 

0.0 

0.3 

748.2 

748.5 

576.5 

0.0 

131.1 

0.0 

807.1 

252.2 

0.0 

12476.1 

Annual 

Cost 

(S/yr.) 

$1,681,683 

$1,745,130 

$569,624 

$1,902,806 

$26,901,532 

$0 

$1,368,290 

$862,776 

$4,170,641 

$12,378,936 

$1,519,622 

$960,285 

$54,061,324 

$55,852 

$9,719 

$65,571 

$41,567 

$358,042 

$399,610 

$1,161,829 

$44,953 

$589,117 

$12,916 

$367,685 

$1,548,362 

$324,455 

$58,575,822 

Average 

Cost 

(S/ton) 

$56,772 

$10,244 

$28,540 

$3,802 

$4,327 

N/A 

$7,530 

$40,772 

$31,079 

$5,084 

$7,888 

$16,288 

$5,427 

N/A 

N/A 

N/A 

N/A 

• $479 

$534 

$2,015 

N/A 

$4,493 

N/A 

$456 

$6,140 

N/A 

$4,695 

Regulatory Option 1 (Actual) 

Total 

Reduction 

(tpy) 

170.3 

445.4 

47.4 

761.6 

7603.5 

0.0 

334.4 

319.8 

152.0 

3432.7 

597.1 

109.7 

13973.9 

0.0 

0.0 

0.0 

16.5 

881.2 

897.7 

678.0 

0.0 

258.0 

282.5 

807.1 

408.2 

0.0 

17305.4 

Annual 

Cost 

(S/yr) 

$6,220,618 

$8,798,424 

$3,090,520 

$15,714,912 

$72,315,781 

$0 

$6,600,459 

$11,058,515 

$4,974,215 

$30,315,848 

$13,381,941 

$2,910,610 

$175,381,844 

$55,852 

$9,719 

$65,571 

$278,777 

$881,722 

$1,160,499 

$1,625,109 

$44,953 

$18,170,677 

$5,312,112 

$371,994 

$13,618,276 

$328,764 

$216,079,798 

Average 

Cost 

(S/ton) 

$36,525 

$19,752 

$65,232 

$20,634 

$9,511 

N/A 

$19,738 

$34,579 

$32,715 

$8,832 

$22,413 

$26,535 

$12,551 

N/A 

N/A 

N/A 

$16,896 

$1,001 

$1,293 

$2,397 

N/A 

$70,426 

$18,801 

$461 

$33,360 

N/A 

$12,486 

Note 1: All dollars are 1998 calendar year dollars. 
Summary of Regulatory Option Cost Effectiveness for the Reinforced Plastic Composites 

Existing Sources -1997 

NOTE: Add Data for facilities added to the database - numbers listed in table to the right 

Cost Effectiveness April 24-2002-Summary.xls 

12/31/2002 

Subcategory 

Open Molding 

Process 

Manual Resin Application 

Mechanical Resin Application 

Filament Winding 

Gel Coat Application 

Process/Product Grouping 

Corrosion-Resistant 

Non Corrosion-Resistant 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant (Unfilled) 

Non Corrosion-Resistant (Filled) 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant 

Pigmented Production 

Clear Production 

Tooling / Mold Manufacturing 

Totals for Open Molding Subcategory 

Closed Molding Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Totals for Closed Molding Subcategory 

Centrifugal Casting Centrifugal Casting Corrosion-Resistant 

Non Corrosion-Resistant 

Totals for Centrifugal Casting Subcategory 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mafls 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mafls 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Totals for Reinforced Plastic Composites Source Category 

Reg. Option w/ Size Limit (Incremental) 

Total 

Reduction 

(tpy) 

0.0 

109.0 

19.1 

25.8 

1925.3 

0.0 

133.3 

0.0 

133.7 

1540.2 

117.8 

39.7 

4043.9 

0.0 

0.0 

0 

0.0 

735.3 

735.3 

218.3 

0.0 

3.4 

0.0 

0.0 

88.0 

0.0 

5089.0 

Annual 

Cost 

(S/yr.) 

$0 

$1,022,637 

$458,607 

$437,460 

$20,441,211 

$0 

$1,163,537 

$0 

$4,161,771 

$6,683,518 

$1,113,398 

$261,918 

$35,744,058 

$0 

$0 

$0 

$0 

$314,641 

$314,641 

$561,068 

$0 

$276,371 

$0 

$363 

$1,059,067 

$363 

$37,955,932 

Average 

Cost 

($/ton) 

N/A 

$9,378 

$23,991 

$16,986 

$10,617 

N/A 

$8,727 

N/A 

$31,131 

$4,339 

$9,455 

$6,589 

$8,839 

N/A 

N/A 

N/A 

N/A 

$428 

$428 

$2,570 

N/A 

$82,289 

N/A 

N/A 

$12,032 

N/A 

$7,458 

Regulatory Option 1 (Incremental) 

Total 

Reduction 

(tpy) 

140.7 

384.1 

46.5 

286.9 

3312.1 

0.0 

286.0 

298.6 

151.5 

2538.0 

S22.2 

90.5 

8057.2 

0.0 

0.0 

0 

16.2 

868.3 

884.5 

319.8 

0.0 

130.3 

282.5 

0.0 

244.1 

0.0 

9918.3 

Annual 

Cost 

(S/yr.) 

$4,538,935 

$8,075,932 

$2,979,503 

$14,249,566 

$65,855,461 

$0 

$6,395,707 

$10,195,739 

$4,965,345 

$24,620,431 

$12,975,717 

$2,212,243 

$157,064,578 

$0 

$0 

$0 

$237,210 

$838,321 

$1,075,531 

$1,024,348 

$0 

$17,857,932 

$5,299,196 

$4,671 

$13,128,981 

$4,671 

$195,459,908 

Average 

Cost 

(S/ton) 

$32,262 

$21,024 

$64,028 

$49,665 

$19,883 

N/A 

$22,362 

$34,141 

$32,766 

$9,701 

$24,849 

$24,451 

$19,494 

N/A 

N/A 

N/A 

$14,602 

$966 

$1,216 

$3,203 

N/A 

$137,098 

$18,756 

N/A 

$53,796 

N/A 

$19,707 

Note 1: All dollars are 1998 calendar year dollars. 
Summary of Cost Effectiveness for Recommended Final Rule for Reinforced Plastic Composites Source Catego 

Existing Sources 

-\l 

Process 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination/Casting 

, 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mat'ls 

[Totals for Source Category 

Average imparts 

total 

Reduction 

toy* 

5916.7 

0.0 

748.5 

576.5 

0.0 

127.8 

0.0 

807.1 

164.2 

0.0 

8340.8 

Annual 

Cost 

(S/yM 

$18,317,266 

$65,571 

$399,610 

$1,161,829 

$44,953 

$312,746 

$12,916 

$367,322 

$489,295 

$324,092 

$21,495,600 

cost 

Effectiveness 

(Stout) 

$3,096 

N/A 

$534 

$2,015 

N/A 

$2,448 

N/A 

$455 

$2,980 

N/A 

incremental Impacts 

Recommended Rule Compared to Floor 

totaf 

Reduction 

toy) 

0.0 

0.0 

735.3 

218.3 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

$2,577| 953.6 

Annual 

Cost 

<$/y*,> 

$0 

$0 

$314,641 

$561,068 

$0 

$0 

$0 

$0 

$0 

$0 

$875,710 

Cost 

Effectiveness 

{S/ton* 

NA 

NA 

$428 

$2,570 

NA 

NA 

NA 

NA 

NA 

NA 

$9181 

Note 1: All dollars are 1998 calendar year dollars. 
Centrifugal Casting - CR DRAFT 

12/31/2002 

CC-CL tables.xls 

Rank 

1 

2 

Corrosion - Resistant Centrifugal Casting (updated) 

Important Notes: 

The average emission factors used in this spread sheet to calculate emissions should not be used to determine or estimate actual emissions at a specific facility. 

A facility's specific emissions shown in this spread sheet may not represent the facility's actual emissions and should therefore not be used. | 

This database only contains facilities for which the Administrator has infonnation. Other facilities that should be part of this database may exist. 

Plant Name 

Fibercast Co. 

Raven industries. Inc. (Sioux Falls) 

Projected Tota) (including assumed values): 

Average: 

Filler/Resin Ratio: 

Reinforcement to Resin + Filler Ratio: 

(.eqend 

Facilities that comprise MACT floor 

Existing Source MACT Floor 

Assumed values - no data provided 

Verified in Telecon 

Site Visit Data 

Footnotes: 

Centifugal 

Casting 

Machines 

19 

8 

27 

14 

0.00 

0.72 

Resin 

(tpyt 

372 

46 

417.7 

208.9 

Weighted 

Average % HAP 

in neat resin Dius' 

47.0 

49.0 

48.0 

FiDer 

(tPV>° 

1 

0 

1.2 

0.6 

Reinforce. 

(tort 

269.1 

32.9 

302.0 

151.0 

Scrap 

(tpv) 

38.5 

4.7 

43.3 

21.6 

(ExistTM Source 

Pre-MACT 

Emissions 

(tov) 

4.9 

12.5 

17.4 

8.7 

Post-MACT 

Emissions 

(tDV) 

4.9 

12.2 

17.1 

8.6 

a = The HAP percentages are in terms of weight percent and they are based on the HAP content of the neat resin plus any HAP that is added to the resin at the facility (fillers not included). 

b = Finer quantities for fadDties lhat indicated filler use but did not quantify the amount were determined by using the average finer/resin ratio from fadDties with known filler quantities. 

c = Point values are expressed in pounds of HAP per ton of neat resin plus. I I lll l 1 

Current 

Emissions 

(lbs/ton)c 

26 

547 

N/A 

N/A 

Other 

Reduction 

Technloues 

Centr. casting 95% control, filament wind, no control 

None 

^ 

Tl 
Centrifugal Casting - Non CR DRAFT 

12/31/2002 

CC-CL tables.xls 

-£> 

Rank 

1 

2 

3 

4 

5 

6 

Noncorrosion - Resistant Centrifugal Casting (updated) 

Important Notes: 

The average emission factors used in this spread sheet to calculate emissions should not be used to determine or estimate actual emissions at a specific facility. 

A facility's specific emissions shown in this spread sheet may not represent the facility's actual emissions and should therefore not be used. 

This database only contains facilities for which the Administrator has information. Other facilities that should be part of this database may exist. 

Plant Name 

Dixie-Pacific Manufacturing Co. 

Henderson, Black & Green, Inc. 

Sherman Poles 

Altec Industries, Inc. (Midwest Oper.) 

Structural North America 

Raven Industries, Inc. (Sioux Falls) 

Projected Total (including assumed values): 

Average 

Filler/Resin Ratio: 

Reinforcement to Resin + Filler Ratio: 

Legend 

Facilities that comprise MACT floor 

Existing Source MACT Floor 

Assumed values - no data provided 

Verified in Telecon 

Footnotes: 

Centifugal 

Casting 

Machines 

31 

10 

19 

14 

1 

8 

83 

14 

0.03 

0.85 

Resin 

(tpv) 

1298 

393 

2487 

233 

21 

46 

4478.5 

746.4 

Weighted 

Average % HAP 

In neat resin plus* 

35.0 

35.5 

37.5 

44.5 

45.2 

49.0 

41.1 

Filler 

(tPV) ° 

41 

12 

0 

0 

1 

0 

54.1 

9.0 

Reinforce. 

(tpv) 

1136.9 

344.2 

2112.1 

308.5 

8.3 

38.8 

3948.8 

658.1 

Scrap 

(tpv) 

148.6 

45.0 

276.0 

32.5 

1.8 

5.1 

508.9 

84.8 

Existlnq 

Pre-MACT 

Emissions 

(tpv) 

253.5 

77.8 

520.5 

57.8 

5.4 

12.5 

927.6 

154.6 

Source 

Post-MACT 

Emissions 

(tpv) 

253.5 

77.8 

520.5 

48.8 

4.5 

9.6 

914.6 

152.4 

a « The HAP percentages are in terms of weight percent and they are based on the HAP content of the neat resin plus any HAP that is added to the resin at the facility (fillers not included). 

b = Filler quantities for facilities that indicated filler use but did not quantify the amount were determined by using the average filler/resin ratio from facilities with known filler quantities. 

c = Point values are expressed in pounds of HAP per ton of neat resin plus. | | lll l 1 

Pre-MACT 

Emissions 

(Ibs/tonlc 

391 

396 

419 

496 

504 

547 

Other 

Reduction 

Techniques 

None 
Continuous Lamination/Continuous Casting DRAFT 

12/31/2002 

CC-CL tables.xls 

Rank 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Continuous Lamination / Continuous Casting (updated] 

Important Notes: 

The emission estimates used in this spread sheet should not be used to determine actual emissions at a specific facility. 

A facility's specific emissions shown in this spread sheet may not represent the facility's actual emissions and should therefore not be used. 

This database only contains facilities for which the Administrator has information. Other facilities that should be part of this database are likely to exist. 

Plant Name 

Enduro Fiberglass (formerly W. R. Grace) 

Crane Kemlite (Jonesboro - formerly BP Chemicals) 

International Paper (Nevamar) 

W.H. Brady U.S.A. Inc. (Cameron Ave.) 

Kalwall Corp. 

Tomkins - LASCO Panel Products (KY) 

Resolite 

Sequentia, Inc. (Grand Junction) 

Crane Kemlite (Joliet) 

Glasteel Industrial Laminates 

Projected Total (including assumed values): 

Average 

Filler/Resin Ratio: 

Leaend 

Facilities that comprise MACT floor 

Existing Source MACT Floor 

Assumed values • no data provided 

Verified in Telecon 

Based on Permit Information 

Site Visit Data 

Based on Patent Information 

Resin 

ftPV) 

1235.2 

6250.0 

1872.1 

232,5 

3510.0 

13203.2 

1781.3 

12644.9 

16830.0 

1104.0 

58663.1 

5866.3 

#REF! 

%HAPa 

neat resin olus 

35.5 

38.6 

37.8 

33.0 

40.5 

42.5 

43.2 

43.8 

44.0 

51.5 

41.0 

Filler ° 

(tpy) 

#REF! 

#REFl 

3266.2 

0.0 

817.8 

3379.6 

311.5 

2803.3 

12436.2 

#REFI 

#REF! 

#REFI 

See ratio calc below 

Reinforce. 

(tpy) 

1095.5 

3498.0 

0.0 

50.8 

1278.4 

4260.0 

742.1 

5246.3 

9160.6 

0.0 

25,331.7 

2533.2 

Scrap 

(tpv) 

#REF! 

#REF! 

532.6 

30.7 

595.7 

2216,3 

301.3 

2195.9 

4011,0 

#REFI 

#REF! 

#REFI 

Existina Source 

Pre-MACT 

Control 

Factor 

0.1740 

0.2240 

0.4150 

1.0000 

1.0000 

1.0000 

1.0000 

1.0000 

1.0000 

1.0000 

Post-MACT 

Control 

Factor 

0.1740 

0.2240 

0.4150 

0.4150 

0.4929 

0.5647 

0.4150 

0.4150 

1.0000 

0.4150 

Existinq Source 

Pre-MACT 

Emissions 

(Controlled) 

(tpy) 

3.82 

21.62 

12.74 

36.06 

56.26 

191.23 

42.67 

282.49 

23.67 

60.05 

730.61 

73.06 

Post-MACT 

Emissions 

(Controlled) 

(tpv) 

3.82 

21.62 

12.74 

14.96 

27.73 

107.99 

17.71 

117.23 

23.67 

24.92 

372.40 

37.24 

a = The HAP percentages are in terms of weight percent and they are based on the HAP content of the neat resin plus any HAP that is added to the resin at the facility (fillers not included). 

b = Filler quantities for facilities that indicated filler use but did not quantify the amount were determined by using the average filler/resin ratio from facilities with known filler quantities. 

Pre-MACT 

Emissions 

(Uncontrolled) 

(tpv) 

21.97 

96.50 

30.71 

36.06 

56.26 

191.23 

42.67 

282.49 

23.67 

60.05 

841.61 

84.16 

The filler/resin ratio shown is based only on facilities that conduct continuous lamination. Filler information from International Paper, a continuous casting facility, was not used. | 

Reduction 

Techniques 

Thermal Oxidizer (83% Overall Control) 

Thermal Oxidizer (78% Overall Control) 

Condenser/Carbon filters (58.5% Overall Control) 

Number 

of lines 

1 

2 

2 

1 

1 

3 

1 

4 

3 

1 

^ 
Comparison of MACT Floors for Open Molding - Proposed Rule and Final Rule 

Process Group 

Manual Corrosion Resistant 

Manual Noncorrosion Resistant 

Manual Tooling 

Mechanical Noncorrosion Resistant Unfilled 

Mechanical Noncorrosion Resistant Filled 

Mechanical Corrosion Resistant 

Mechanical Tooling 

Filament Winding - Corrosion Resistant 

Filament Winding - Noncorrosion Resistant 

Gel Coat - Pigmented Production-White 

Gel Coat - Pigmented Production-Non-White 

Gel Coat - Clear Production 

Gel Coat - Tooling 

Proposed 

Rule Floor 

123 

87 

122 

86 

126 

159 

254 

171 

188 

267 

377 

522 

398 

Proposed Rule 

Maximum Resin HAP 

content (weight 

percent) 

40.00 

33.60 

39.90 

38 nonatomized 

42.8 nonatomized 

48.3 nonatomized 

43 atomized or 

55.1 nonatomized 

42.00 

45.00 

30.00 

37.00 

44.00 

38.00 

Draft Floor for 

Promulgated 

Rule 

123 

87 

157 

87 

87 

112 

254 

171 

188 

267 

377 

522 

437 

Draft Promulgation 

Maximum Resin HAP 

content (weight percent) 

40.00 

33.60 

45.90 

38.4 nonatomized 

38.4 nonatomized 

46.2 nonatomized 

43 atomized or 

91.4 nonatomized 

42.00 

45.00 

30.00 

37.00 

44.00 

40.00 

Percent 

Change in 

Allowable HAP 

0.00 

0.00 

+6 

+0.4 

-4.4 

-2.1 

Resin HAP is basically 

unlimited for nonatomized application 

0.00 

0.00 

0.00 

0.00 

r 

0.00 

+2 

All floor changes result in a more lenient floor except for Mechanical Noncorrosion Resistant Filled and Mechanical Corrosion Resistant. 

| 

We believe that facilities could still meet the floor for 

Mechanical Noncorrosion Resistant filled without add-on controls, though some averaging may be required.