OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

45) IV-C-18 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 45 of 273 

P.1 
P.2 

A-94-52 

IV-C-18 

Cassidy Mike 

<Mike.Cassidy@kohler 

.com> 

02/28/2002 09:37 AM 

To: Keith Barnett/RTP/USEPA/US@EPA 

cc: Hafele Myron <Myron.Hafele@kohler.com>, 'John Schweitzer/CFA' 

<jschwtzr@gte. net> 

Subject: RE: Revised Floors for Noncorrosion Resistant resins 

Keith, 

Chanks for the information. Please note the following for our open-molding 

bu^i^esses regarding the revised proposed floor, "the draft revised flop>-^s 

35 perfc**5{it HAP resin and non-atomized resin application": 

1) The 35% fiAP resin for filled resins is significantly lov^e-fthan what 

we're currently asking. We apply filled resins with non^a-tomizing equipment, 

but we experience po^sx product quality with resins cefTtaining less than 

about 40% HAP. Getting^<o less than 35% HAP wi^'not be feasible in the 

near future. This is a significant issue sjj*t5e the great majority of the 

resin we use is applied in a riJ^ed sys^e 

2) Non-atomized resin applicatjx>«^for^smfilled resins is currently not 

feasible for our open-molding^-cSperations^^v^e apply gel coat resins as 

unfilled resins. Again, mo^t of our gel coat^v^xceed the 35% HAP. More 

significant is the fapte*^that we've been unsuccessful in applying gel coats 

with non-atomized shipment. We experience very poor^qyality with the 

finished gel coax material and we anticipate that non-atolbi^zed application 

of gel coat^resin will not be feasible in the ,nea-r-future. 

Mike Gassidy 

m 2 7 J,J33 

EPA AIR DOCKET 

Original Message 

From: Barnett.Keith@epamail.epa.gov 

[mailto:Barnett.KeithSepamail.epa.gov] 

Sent: Monday, February 25, 2002 1:00 PM 

To: Cassidy Mike 

Subject: Revised Floors for Noncorrosion Resistant resins 

Dear Mike: 

I am forwarding the E-mail I sent to John Schweitzer at CFA on the 

revised floors. 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Forwarded by Keith Barnett/RTP/USEPA/US on 02/25/2002 01:58 PM 

Keith Barnett 

02/22/2002 

To: 

cc: 

j schwtzr@gte.net 

KRMeardon@mactec.com, Penny 
P.3 

12:49 PM 

Noncorrosio n 

Lassiter/RTP/USEPA/US@EPA 

bcc : 

Subject: Revised Floors for 

Resistant resins 

Dear John: 

Attached is an excel spreadsheets with the revised floors for 

noncorrosion resistant resins. the draft revised floor is 35 percent 

HAP resin and non-atomized resin application. It is interesting to note 

that this is identical to the floor for production resin in the 

fiberglass boat manufacturing rule. 

We believe that now combining filled and unfilled noncorrosion resistant 

resins is appropriate based on the following rationale: 

The reason that we originally split out filled and unfilled resins was 

that non-atomized mechanical resin application of filed resins was not 

possible, and we wanted to be able to include non-atomized resin 

application is an applicable emission reduction technique on the floor 

for unfilled resins. Now, both filled and unfilled resins can be 

applied using non-atomized resin application technology. So this reason 

no longer exists. 

A possible second reason to keep filled and unfilled resins separate 

would be that,all other things being equal, filled resins need a higher 

HAP content specifically due to the presence of the filler, and the 

effect of the filler on the handling characteristics of the resin. If 

that were true, combining filled and unfilled resins might result in a 

floor for filled reins that was not achievable. However, combining 

filled and unfilled resins does not result in a lower floor for filled 

resins. Therefore even if filled resins do need more HAP compared to 

the unfilled, this point is moot. 

In contrast, there are compelling reasons to now combine filled and 

unfilled. One is that it simplifies the rule. the second is that most 

of the best controlled facilities use add-on controls. The use of 

fillers does not impact add-on control performance. If we create an 

artificial separation here, we are essentially reducing the total 

population of facilities and biasing the floor. 

Combining filled and unfilled resins is also consistent with our 

approach for tooling resins (which may be filled or unfilled), and 

manual and filament winding resin application, where we do not 

differentiate between filled and unfilled. Based on out approach for 

these other application methods, the presence of filler, in and of 

itself, is not a reason to separate noncorrosion resin into different 

process product groupings. 

(See attached file: MechNonCR Combined comparison3.xls) 
P.4 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

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