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OAR Box 1384 

Prepped by Charmelle Mathews 

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'Document Number: 

2&o) II-F-! 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 256 of 264 
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Keith Barnett To: Peter_D._Eglinton@omb.eop.gov 

11/07/2000 12:42 PM 

cc: Penny Lassiter/RTP/USEPA/US@EPA 

Subject: Re: Reply 

Dear Peter: 

I. have a letter dated August 2, 2000. It is 4 pages. I have attached a copy. 

The issues raised are the same ones CFA and EPA have discussed before. 

Concerning reviewing the costs and raising the threshold, we believe it is more appropriate to 

propose with our current costs and thresholds, and then reassess after proposal when we have 

comments from all interested parties, not just the CFA. 

The reason the CFA costs are so much higher is they are based the assumption that the HAP 

concentrations that must be controlled are much lower than those we have seen in actual operating 

facilities. We have actually addressed this issue previously in "Addendum to Assessment of 

Styrene Emission Controls for FRP/C and Boat Building Industries". EPA-600-/R-96-136, November 

1996. You should have a copy with the cost materials I sent as part of the SBAR Panel. We also 

discuss the cost differences in the preamble. 

We believe it is cost effective for all facilities above 100 tpy to meet a 95 percent control 

requirement. However, due to small business concerns and in the spirit of SBREFA, we provided 

relief to small businesses. Until we receive additional information through proposal and evaluate the 

CFA costs again we have no information to persuade us to raise the threshold for large companies. 

Regarding changing the preamble to "specify a procedure to allow the industry to fully participate in 

and comment on EPA's subsequent coat analysis", we have maintained an ongoing dialogue with 

the industry throughout this rulemaking, and we don't see that changing. However, given the short 

amount of time we have available between proposal and promulgation, we do not believe 

formalizing another round of comments and responses would be appropriate. To do this would 

jeopardize the 112(j) hammer date of May 2002, and neither we nor the industry want that. Also, 

note that industry already had one chance to comment on the add-on control costing methodologies 

developed in the original ORD cost study as discussed above. 

Regarding the boat manufacturing rule - these sources are not as similar as CFA implies. One major 

difference is the floor level of control for production resin application for all boats is a point value of 

9 1. The largest operation in the RPC industry, filled mechanical non-corrosion resistant resin, had a 

floor point value of 144. The point value range for other production resins are 83 to 190. 

Therefore, the floor level of control for boat manufacturing is more stringent that for RPC. Another 

significant difference is that only one boat manufacturing facility has an add-on control. In the PRC 

source category there are eighteen facilities with add-on controls that we have same data on, and at 

least two more that we are aware of and plan to get data on after proposal. Therefore, add-on 

controls have been much more widely applied in RPC compared to boats. Finally, the boat 

manufacturing NESHAP decisions played no part in this rulemaking. Therefore, I don't believe we 

need to address boat manufacturing in our preamble. 

Regarding the item where CFA requests the preamble be changed to specifically request comment 

on thresholds, we are seeking comments on all aspects of the rule and this item is moot. 
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The CFA has also raised an issue concerning OSHA requirements. They state that requiring capture 

and control will make compliance with OSHA requirements more difficult. There is no reason that a 

facility would be unable to comply with OSHA requirements because they must meet the capture 

requirements in this rule, and we designed the enclosures when we did the costing assuming that 

OSHA requirements would be met with engineering controls. We have also discussed this issue 

directly with OSHA and provided OSHA a copy of the rule and preamble for comment. We have 

incorporated language suggested by OSHA in the preamble on alternatives to address potential 

worker exposure concerns, and are requesting comment on these alternatives. At no time has 

OSHA indicated to me that they believe we should modify the capture requirements. 

OMB letter 

Keith W. Barnett 

U. S. Environmental Protection Agency 

Emission Standards Division 

MD-13 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Peter_D._Eglinton@omb.eop.gov 

Peter_D._Eglinton@om To: Keith Barnett/RTP/USEPA/US@EPA 

b.eop.gov 

11/06/2000 01:45 PM 

cc: 

Subject: Reply 

Hi, Keith. 

I got your voice message. I'm currently hustling on three other EPA rules 

with deadlines around 11/15. Perhaps the ongoing prioritization 

discussions will shed light on the final time frame for your rule. At this 

point, I'm sorry to report that I do not have any questions prepared... 

BTW, did you receive any letters from CFA in August? We did, and will want 

to get your thoughts on their comments. If you already received a letter, 

it likely contains the same info. If not, I'll see if I can pull together 

a summary -- or just fax you a copy. 
P.4 

ll 

E¥/7f/W Composites 

mJUrl WFabricators Wim WAst 'Asociation 

T H E COMPOSITE S CONNECTIO N 

August 2, 2000 

Mr. John Spotila 

Administrator 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Washington DC 20503 

Re: Changes Needed in EPA's Draft Proposed MACT Standard for Reinforced 

Plastics/Composites Manufacturing 

Dear Mr. Spotila: 

The Composites Fabricators Association (CFA) is the national trade group for the 

reinforced plastics/composites ("composites") industry. We are writing regarding EPA's 

draft proposed MACT standard for reinforced plastics/ composites manufacturing that 

OMB will soon receive for review. We urge you to ask EPA to amend its draft proposal 

before it is published. We submitted detailed studies in April to EPA showing that 

EPA's current draft will result in the closure of a number of major composites facilities.1 

EPA has decided to postpone review of our studies and instead to proceed with proposal 

of this draft rule. We seek your intervention to mitigate the adverse consequences of 

EPA's decision and to ensure a fair and adequate addressal of our very serious concerns. 

The Impact of EPA's Proposal 

EPA proposes to require many composites manufacturers using open molding processes 

to reduce emissions ofthe Hazardous Air Pollutants (HAPs) from their operations by 

95% by installing capture and control equipment (oxidizers). Our engineering and 

economics experts made site visits and collected information from 17 typical open 

molding composites operations. They found that: 

1. For these 17 typical composites manufacturing operations, the capture and 

control systems would be 3-10 times more expensive than EPA estimated. 

These controls will cost composites manufacturers up to $40,000 per ton of HAP 

1

 These reports were also provided to Mr. Peter Eglinton of your office. 

1 
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controlled. Such controls are clearly not cost-effective - EPA typically considers 

control costs of $5,000 per ton to be reasonable. We believe this shows that EPA 

has not accurately evaluated the difficulty of capturing emissions from composites 

manufacturing operations. Many composite manufacturers make products that are 

large, that are of widely varying sizes and shapes, and that are made on molds that 

are frequently moved around in the manufacturing facility; these factors mean that 

capture of emissions is much more difficult and expensive than EPA has 

estimated. 

2. Of the 17 facilities our ex-EPA economist expert determined that 15 simply 

could not afford the proposed controls and would close, and that the controls 

would be a "significant burden" for the remaining two. The economist 

collected financial data from these companies, and carefully compared the cost of 

the controls to the revenues, profits, and historical levels of capital investment for 

those facilities EPA has not done a comparable analysis. 

3. Open molding operations owned by large companies are no more able than 

those owned by small companies to afford capture and control systems. 

Citing concerns over affordability of controls, EPA has agreed to establish a much 

higher emission threshold for small businesses required to install controls. EPA 

staff have informed us that they will not provide this higher threshold to 

businesses that do not quality as "small businesses" because they believe these 

"larger" businesses will have better access to capital. Yet access to capital 

becomes important only if the proposed investment is economically rational in the 

first place. Our economist finds that the costs of capture and control are so high 

relative to the revenues and profits ofthe open molding facilities in this size range 

that nearly all the facilities - both those owned by large businesses and those 

owned by small businesses - will simply close rather than make a compliance 

investment in a facility that would no longer be viable. (See the attached July, 

2000 Environomics report.) 

4. EPA's capture and control requirements will make it more difficult for 

composites manufacturers to comply with OSHA worker protection 

standards. Efficient capture and control requires concentrating air pollutants in 

the workplace air. OSHA regulations, however, require composites 

manufacturers to use dilution ventilation to achieve low concentrations of air 

pollutants in the workplace. EPA rules should not jeopardize our industry's 

OSHA compliance. 

5. Our evaluation of capture and control showed that 30 tons of greenhouse 

gases would be released for every 1 ton of HAP controlled. Because capturing 

HAP emissions from these operations is so difficult, large quantities of electricity 

and natural gas would be consumed by the capture and control equipment. This in 

turn would generate greenhouse gasses. Styrene, the primary HAP emitted by 

composites manufacturing operations, naturally degrades in the atmosphere to 

non-toxic substances within 24 hours. Greenhouse gases, on the other hand, have 

atmospheric lifetimes of 50 to 200 years. 
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d 

6. EPA states in the recently proposed MACT for boat manufacturing that 

capture and control is "not applicable," because of varying product sizes and 

worker protection concerns. " Boats are made using the same materials and 

manufacturing processes as many composite products, but are receiving different 

treatment by EPA. 

These issues are discussed at length in the two attached briefing memoranda and in the 

documents on our web site, www.cfa-hq.org/best.htm. 

Please note that we are not suggesting that these facilities should have no controls. In 

fact, we have suggested to EPA that these plants should be required to adopt the available 

pollution prevention controls. These pollution prevention controls can achieve emission 

reductions of 50% or more, and they help facilities protect workers and are available at 

reasonable cost. 

Changes that should be made to the proposal 

We agree with EPA that small businesses with emissions less than 250 tons per year 

cannot afford expensive capture and control requirements. We disagree with EPA that 

facilities ofthe same size and making the same kind of products that happen to be owned 

by a larger company can afford these same controls. EPA's proposal should be changed 

before publication to treat all these facilities the same - namely, apply these capture and 

control requirements to existing facilities only i/they exceed 250 tons HAP emissions per 

year without regard to whether they meet the definition of "small business." 

In addition, the preamble to the draft rule should be amended to: 

1. specify a procedure that will allow industry to fully participate in and comment on 

EPA's subsequent review of costs, affordability, and impacts since EPA has 

refused to conduct this review prior to proposal and to put it in the docket for the 

proposed rule; 

2. explain that EPA has come to different conclusions regarding applicability of 

capture and control for a very similar industry (boat manufacturing), and seek 

public comments regarding this different approach as applied to reinforced plastic 

composites; and 

3. if the above requested change to the rule itself is not made, seek comments on 

raising the threshold for capture and control for existing sources to 250 tons per 

year for all sources, not just for those that are owned by small businesses. 

* * * * 

Thank you for your consideration. Please do not hesitate to contact me if we can provide 

any additional information. 
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Sincerely, 

John Schweitzer 

Senior Director of Government Affairs 

Phone: 734.622.0162 

Fax: 734.622.0122 

E-mail: jschwtzr@gte.net 

Cc: Mr. Peter Eglinton, Office of Management and Budget (via E-mail) 

Attachments (3)