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OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

2) IV-E-2 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:25 AM Sheet 2 of 130 
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-

Briefing for | 

Dr. John Graham 

i— 

EPA AIR DOCKtET 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Regarding the 

Proposed NESHAP (MACT Standard) for 

Reinforced Plastic Composites Production 

(66 FR 40324) 

Composites Fabricators Association 

November 13, 2001 

A-W-5TVJ-erZ. 

1 
The Composites Fabricators Association is the national trade association for the 

reinforced plastics composites industry. With over 900 member companies, CFA 

represents molders and fabricators of composite products, as well as suppliers of 

raw materials, equipment, and services to this industry. 

Comments or questions regarding this briefing should be directed to: 

John Schweitzer 

Senior Director of Government Affairs 

Composites Fabricators Association 

1655 N. Fort Myer Drive, Suite 510 

Arlington, VA 22209 

Phone: 734.622.0621 

Fax: 734.622.0122 

Email: jschwtzr@gte.net 
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Introduction 

Chemistry and emissions: A composite product is made by combining liquid 

resins and glass fiber reinforcements in a mold, where a chemical reaction then 

"cross-links" (cures) the resin, forming a solid part. 

Composite resins typically contain styrene, which is the agent that cross-links the 

resin during cure. Styrene is listed as a Hazardous Air Pollutant (HAP). 

Some of the styrene does evaporate during the resin application and curing 

processes. However, the more styrene that stays in the product, the better. The 

industry uses a variety of pollution prevention (P2) technologies to reduce the loss of 

styrene from the process, including: 

• Resins with lower styrene content, 

• Resin application technologies that result in lower surface areas of sprayed 

material and therefore lower evaporation rates, 

• Additives that migrate to the surface of the curing part and reduce styrene 

evaporation, and 

• Closed or covered curing. 

The development and use of these P2 technologies result from the combined 

entrepreneurial efforts of the resin manufacturers, the equipment manufacturers, 

and the fabricators. These techniques have the triple benefit of protecting the 

workers from excessive emissions, reducing air emissions from the plant, and 

improving the output of the facility. 

Products: This same combination of chemical and engineering ingenuity among 

the resin manufacturers, equipment manufacturers, and fabricators has resulted in 

the creation of thousands of kinds of products, many of them previously made with 

other materials, such as metal, ceramic, or wood, and some of them brand new, 

made possible by the unique properties of the composite material. 

These products include: 

• Modular tub/shower units 

• Pick-up truck caps 

• Recreational vehicle parts 

• Truck bodies 

• Underground gasoline storage 

tanks 

• Pollution control equipment 

• Barge covers 

• Swimming pools 

• Utility poles 

• Windmill blades 

• Bridge beams 
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Manufacturing processes: Manufacturing processes used to make composites 

include: 

Open molding, where the resin and reinforcement are applied to and then cured 

on an open mold - used to make tub/shower units, R/V parts, truck bodies, 

storage tanks, etc. Typical open molding processes are characterized by a large 

range of product sizes, large process areas, and the close interaction of workers 

with the products. 

Closed (compression) molding, where 

resin and reinforcement are placed 

into a metal mold, which is then 

closed for curing - used to make 

automotive body panels, electrical 

components, etc. 

Pultrusion, where resin is applied to 

continuous reinforcements, which 

are then pulled into the mold where 

the resin is cured - used to make 

ladder rail, window lineals, bus 

panels, bridge beams, etc. 

Adding resin to the reinforcement in a small 

compression molding press. 

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Pultrusion process. Glass reinforcement (roving) is pulled through a resin bath or "impregnator," 

and then into the die (mold), where the resin is cured. 
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Applying resin and reinforcement to a 

chemical storage tank. 

Typical large process area for open molding 

tub/shower units. 

Large open molded truck hood, still rn the 

mold. 

Application of resin and reinforcement, and 

"roll-out," of R/V part. 

Application of resin and reinforcement, and 

"roll-out," of tub/shower units. 

Typical open molding operations. 
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I 

EPA's proposed NESHAP for composites 

The floors: In setting MACT standards, the Clean Air Act requires EPA to 

establish "floors" - i.e., rules that bring manufacturing facilities in this country up 

to a level of control equivalent to that achieved by the top 6% of an industry's 

facihties. 

EPA has correctly determined that the technology that best characterizes these 

floors for the composites industry is a set of pollution prevention (P2) techniques. 

CFA supports EPA's determination that these pollution prevention techniques 

represent the proper floors under the Act. Although we have submitted a number of 

technical changes to EPA that we believe are essential, these needed changes are 

not the issue we want to discuss with you today. 

Above the floor: Our concern is that EPA has proposed to exercise its discretion to 

add an additional, highly onerous, requirement to the rule: an above-the-floor 95% 

capture and control requirement for larger existing composites operations, including 

open molding and pultrusion. EPA has also proposed that larger new sources also 

comply with this 95% capture and control requirement. 

Achieving 95% capture and control will require composites manufactures to capture 

100% of the process emissions, and then send this stream of emissions (combined 

with large amounts of ventilation air) to an oxidizer (incinerator) or other control 

device with 95% efficiency. 
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EPA's supporting analysis 

In proposing the 95% capture and control requirement for larger existing and new 

sources, EPA must show that: 

• 100% capture is practically achievable by typical composites manufacturing 

operations. 

• 95% capture and control is aheady achieved in practice by at least some example 

facilities, and that these example facilities are similar to typical composites 

manufacturing operations. 

• 95% capture and control for composites manufacturing operations is cost 

effective. 

• 95% capture and control for composites manufacturing is a regulatory approach 

that maximizes net benefits when energy, environmental, and worker safety 

impacts are considered. 

• 95% capture and control is affordable for composites manufacturers. 

EPA's analysis of these five basic questions does not use the best reasonably 

obtainable information, but instead is based on a large number of assumptions and 

on incomplete information. EPA therefore reaches highly erroneous conclusions to 

each of these five questions. 

We are confident that if EPA were to analyze these questions according to the 

principles and guidance for quality analysis contained in Executive Order 12866, 

EPA could only conclude that the requirements for 95% capture and control should 

be eliminated from the final rule. 

We are here today to ask that your office help ensure that this type of disciplined 

review of this issue is undertaken, that we have a fair opportunity for input, that 

senior managers in the Administration review the results and make a considered 

determination on the matter, and that your office carefully review their 

determination. 
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What the best information shows 

We would like to address each of these five questions and explain what we believe 

the best information shows: 

1. Is 100% capture really achievable? 

2. How much capture and control is actually achieved by EPA's example facilities 

and are these facilities really similar to typical composites manufacturing 

operations? 

3. What will it really cost to achieve 95% capture and control? 

4. Does this discretionary imposition of a 95% capture and control requirement 

maximize net benefits when energy, environmental and worker safety are 

considered? 

5. Is capture and control really affordable? 
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1. Is 100% capture really achievable? 

The need for enclosures: EPA's proposed rule would require facilities subject to 

the 95% capture and control requirements to use process enclosures to capture 100% 

of the emissions from all stages of the process. 

Process enclosures for composites manufacturing are designed to: 

• Remove contaminated air from the workplace to achieve OSHA requirements for 

limiting occupational exposures to the HAPs emitted from the process, 

• Allow enough cool air to enter the workplace so that workers are not subject to 

excessive heat stress, 

• Be large enough to accommodate the work, including the simultaneous 

production of several large products, 

• Have large doors to allow products, molds, and raw materials to enter and exit, 

and 

• Allow the safe movement of workers and egress in case of emergency. 

The pictures at the beginning of this presentation illustrate some of these 

challenges. All of these objectives are contrary to achieving 100% capture and costeffective control, which would require smaller enclosures, lower air flow with 

limited input of fresh air, and small doors or doors that are kept closed. In short, if 

enclosures are designed to meet the OSHA requirements for occupational exposures 

to styrene and heat stress, and to accommodate the frequent movement and 

simultaneous production of several large products, 100% capture is not practically 

achievable. 

What is really achievable: CFA hired an experienced engineer to visit 18 typical 

open molding operations and design process enclosures with the highest practical 

capture efficiencies. The engineer determined that these enclosures, which he 

designed to achieve the OSHA requirements and allow the efficient production of 

products, would achieve on average only 80% capture. His 300-page report was 

submitted to EPA in April 2000 and is part ofthe docket, but was not used by EPA 

in making its decisions. 
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2. How much capture and control is actually achieved by EPA's 

example facilities, and are these facilities really similar to typical 

composites manufacturing operations? 

EPA points to two open molding operations in Ohio and one pultrusion operation in 

North Dakota as examples showing that 95% capture and is achievable in practice 

by composites manufacturers. In fact, these facilities do not achieve 95% capture 

and control, and they would not satisfy EPA's proposed rule. 

The facts: 

According to information we obtained from the state permitting agency, one of 

these two open molding operations has had continuing problems with its control 

device and has never achieved 95% capture and control. In addition, this 

operation employs a very unusual molding process, making it much easier for 

them to capture emissions compared to typical open molding operations. 

A careful examination of the other example open molding operation's permits 

and related test reports, available in the docket, show that the state failed to 

fully employ EPA's accepted test method when it certified the capture and control 

performance. EPA is completely unjustified in assuming that this facility 

achieves 100% capture. 

The example pultrusion facility makes only one product (window lineals), while 

typical pultrusion operations make hundreds of different products of widely 

varying sizes. Enclosures may be feasible at the example facility because ofthe 

small size of the product, and the fixed manufacturing process. In terms of the 

ability to achieve 100% capture, this operation is not similar to the large 

majority of other pultrusion facilities. 

EPA's trip report for the example pultrusion facility notes that operators must 

enter the enclosures to make process adjustments, while an accompanying test 

report shows that the styrene concentrations in the enclosures are over 400 ppm, 

well in excess ofthe 100 ppm OSHA Short Term Exposure Limit. The proposed 

rule and its preamble make no mention of this serious worker health concern, 

but instead propose that other pultrusion operations employ this technology. 

EPA's standard for process enclosures achieving 100% capture (Method 204) 

requires that all enclosure doors that are not open during enclosure testing 

"shall be closed during routine operation of the process." This requirement is 

routinely violated at the example pultrusion facility and at the second of the two 

example open molding facilities, as noted in EPA's trip reports. Yet EPA ignores 

this fact, assumes 100% capture for the example facilities, and proposes a MACT 

standard that requires 100% capture. 

In a MACT standard for a very similar industry (fiberglass boat building), EPA 

decided that the use of capture and control technology by a source should not 

serve as the basis for MACT, because the facility that uses it is not similar to 

others in that industry. EPA has not explained why it has not followed that 

sensible precedent in setting MACT for the composites industry. 

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3. What will it really cost to achieve 95% capture and control? 

EPA has estimated the cost for affected facilities to achieve 95% capture and 

control, and has determined that these costs are reasonable compared to the 

quantity of pollutant that will be destroyed. 

However, EPA's cost estimates are based on a number of incorrect assumptions, 

including: 

• EPA has assumed that the air exhausted from process enclosures will contain 

100 ppm styrene, and that typical operations run 3 shifts per day. However, 

exhaust concentrations are typically under 50 ppm because of OSHA 

requirements, and many plants operate only one shift per day. If EPA had used 

more representative estimates for just these two factors, the Agency's estimate 

ofthe capital cost ofthe control would have increased by 4-6 times. 

• EPA assumed certain process enclosure sizes. However, in many cases, EPA's 

assumed enclosures would not have been large enough to enclose even a single 

part, let alone the several parts that are produced simultaneously. 

• EPA overestimated the economic life of the enclosures, and significantly 

underestimated the cost of electricity and natural gas that would be needed to 

operate the control equipment. 

• EPA assumed the use of a "pre-concentrator" system that would reduce the size 

and cost of the control device, but which is not used successfully by the example 

facilities. EPA also ignored the cost of the monitoring devices that would be 

needed to demonstrate the continuous performance of the pre-concentrator and 

enclosure. 

In April of 2000, CFA provided more accurate information to EPA for use in 

estimating the cost of capture and control. This information showed that the cost of 

capture and control is excessive for this industry and that the benefits of the 

emission reductions do not justify the costs. The Agency admitted that its analysis 

was flawed, but instead of using CFA's data in preparing the proposed rule, the 

Agency only agreed to consider the information following the comment period. In 

effect, this deprived the industry during the comment period of the opportunity to 

review a cost analysis that EPA believes supports its decision. 
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4. Does this discretionary imposition of a 95% capture and control 

requirement maximize net benefits when energy, environmental and 

worker safety are considered? 

Marginal benefits: A fair analysis of the data shows that the capture and control 

requirement achieves, at best, only a very small increment of HAP reduction 

compared to P2 for this industry. The difference is on the order of 5-10%. 

Worker Safety: The use of process enclosures that achieve 100% capture will 

seriously undermine the ability of plants to protect their workers in accordance with 

OSHA. In the proposed rule, EPA acknowledged that this conflict potentially exists, 

but then carried out no analysis of this issue, despite the fact that these concerns 

were brought forcefully to the Agency's attention long before proposal. CFA 

therefore engaged the services of a Certified Industrial Hygienist who visited four 

typical composites manufacturing operations, and determined that, if the enclosures 

were modified in an attempt to achieve 100% capture, worker exposure to HAP 

(styrene) vapors, heat stress, and other risks would be increased to an unacceptable 

level. This seems a very poor trade-off for such a marginal reduction in air 

emissions. 

Energy Use: Significant quantities of electricity and natural gas will be needed to 

operate the controls required for larger sources in EPA's proposed rule. For each 

ton of HAP controlled, the proposed capture and control technology will consume 

78,000 cubic feet of natural gas and 12,000 kilowatt-hours of electricity. For the 

typical facility, this will double its energy requirements. 

Other Environmental Values: Further, for each ton of styrene controlled, these 

systems will cause the generation of more than 30 tons of greenhouse gases. EPA 

did not consider this impact in its decision, but has considered increased greenhouse 

gases in other MACT rules. 

Impact on P2 Innovation: EPA's imposition of capture and control on the larger 

facihties in this industry directly and seriously undercuts the process of innovation 

for P2 resins and application techniques for the rest of the industry. These larger 

facihties have been the leaders in the development of these techniques, but once 

95% capture and control is imposed, they will have a strong incentive not to use P2. 

Small communities: Small communities will also be directly affected because 

these larger composites manufacturing facilities are usually the primary employer 

in the small communities in which they are located. 

The balance: The small increment in benefits that would be achieved by imposing 

95% capture and control is greatly outweighed by the very negative impact of this 

requirement on the workers, energy usage, other environmental values, and the 

communities in which these plants are located, not to mention the impact on the 

companies themselves, which we will address next. 

10 
P.M 

5. Is capture and control really affordable? 

The Clean Air Act requires that EPA consider the affordability of any proposed 

above-the-floor control requirement. 

EPA's analysis: The primary input to EPA's affordability assessment was the 

Agency's control cost estimates, which are inaccurate for the reasons discussed 

above. 

Further, for almost all ofthe facilities that would be subject to the 95% capture and 

control requirement, EPA simply assumed that the controls would be affordable, 

and did not perform any analysis. 

At the core of EPA's analytical problems is that it did not base its decisions on the 

best reasonably obtainable information about this industry. Even after CFA 

submitted detailed data on the industry, EPA chose to continue to rely upon a 

general economic model for its costing and affordability determinations. While this 

general model may be suitable for analyzing some industries, it is totally unsuited 

for the composites industry. This general economic model requires a large amount 

of data, almost none of which is available for the composites industry. EPA was 

therefore forced to use assumptions, many of which are patently incorrect. 

What the Data Show: CFA hired an ex-EPA economist (Stuart Sessions) to work 

with 10 of the 30+ plants that will be subject to this capture and control 

requirement to determine the affordability of this requirement. He found that 6-8 

out of the 10 facilities whose financial data he analyzed in detail would not be able 

to afford the controls, even under very conservative criteria, and would therefore 

close. 

In addition, these larger facilities must compete directly with the rest of the 

industry's facihties that are not subject to this more stringent provision, raising 

serious distributional and equity issues because these facilities do not differ in any 

material way from those facihties in which they are in competition. 

Any impact of this seriousness needs to be assessed in detail. In our view, it is not 

responsible to use a general economic model that is driven almost entirely by 

assumptions, to determine the impact and affordability of this capture and control 

requirement on these companies. We believe these companies, their communities, 

and the industry as a whole deserve better. Our analysis shows that the impact on 

our industry as a whole and on these companies will be disastrous, and we do not 

believe that any responsible EPA manager, if presented with these facts, would 

decide to inflict these consequences on us. 

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What we want to ask of you 

Now that the comment period is over, and the real EPA analysis of costs and 

affordability has yet to be done, our challenge is how to ensure that this analysis is 

done fairly and the facts are laid before the appropriate EPA managers. 

As you can see, we do not believe the facts support a determination by EPA that: 

• 100% capture is really achievable; 

• The example facilities actually achieve 95% capture and control or that they are 

similar to typical composites manufacturing operations; 

• The costs of this additional control are reasonable; 

• The benefits outweigh the costs; or that 

• The affected companies will really be able to stay open. 

We believe there are at least four aspects of this problem on which you could help 

us, acting entirely within the normal process of your office, as we understand it: 

• Assist and guide EPA staff in carrying out this analysis in a manner that is 

consistent with the principles and analysis quality requirements of Executive 

Order.12866; and 

• Insist that EPA staff give us a fair chance to critique their new analysis, 

bringing to bear our unique expertise and knowledge of the industry, since we 

did not have a fair opportunity to do so during the comment period. 

Hopefully, these two steps will be sufficient to resolve this issue satisfactorily. 

However, just in case, we ask that you take two additional steps: 

• Insist that senior EPA managers have the benefit of the new analysis when 

finalized and our critique of this final version, if any, at the time they make a 

final decision about capture and control; and 

• Give a careful review to the Agency's determination in the course of your normal 

review of the final rule. 

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