p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

12) IV-B-12 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 12 of 273 
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MEMORANDUM 

TO: Docket 94-52, Reinforced Plastic Composites NESHAP 

FROM: Keith Barnett, Environmental Protection Agency 

DATE: August 23, 2002 

SUBJECT: Resins for non-gel coated parts. 

We received a verbal comment on the proposed rule from a consultant concerning a facility that 

made parts that had no gel coat. The consultant stated that the resins used had HAP contents 

above the limits in the floors in the proposed rule. They said that they could not reduce the resin 

HAP content because the resin would stick to the mold. The resin is manufactured by Ashland 

Chemical. (See attached E-mail). He also stated that if they could not use this resin, they would 

have to gel coat the parts, which would increase emissions significantly. The parts produced are 

underground septic tanks. 

According to Ashland, this resin has a vapor suppressant (that is what the "S" in the resin 

identification number means). The resin contains 44 percent HAP. The emission limit for noncorrosion resistant resin is 87 lb/ton. A 44 percent HAP resin has an emission factor of 105 lb/ton 

with no suppression. Therefore, ifthe suppressant reduces emissions by 17 percent, this resin 

meets MACT. 

Bases on this, it is very likely that once the resin is tested for suppressant effectiveness, it will 

meet MACT. Therefore, we have determined that a new process/product grouping for noncorrosion resistant parts without gel coats is not warranted at this time. 

F B 2 1 <:33 

EPA AIR DOCKET 1 
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V 

Michael Blankestyn 

< Michael.Blankestyn@ 

rmtinc.com > 

Keith, \ ^ %^ \ y^ JOW* ^ ^OTo: Keith Barnett/RTP/USEPA/US@EPA 

cc: 

Subject: Re: Reinforced Plastics MACT 

01/02/2002 10:47 AM ft^v Q^Uxw i - No ~ M F & P ^t(}0" Q JO & 

The resin supplier is Ashland (FRP Supply Division). Their supplier contact 

is Jeff Wollet. His number is (888) 377-7877. His voice mail is (614) 

790-3400 x-6419#. His email is jkwollet@ashland.com. Let me know if you need 

any additional information. Thanks. 

-Mike Blankestyn 

RMT, Inc. 

Dublin, Ohio 

> » <Barnett.Keith@epamail.epa.gov> 12/26/01 03:27PM > » 

Dear Michael: 

I don't have a solution for this problem. I need to check with my 

technical sources to see if this is a common issue, or an unusual one. 

I don't remember getting any comments on this issue. Could you also 

tell me the name of the resin supplier? It would be helpful if I could 

talk to them. 

I called CFA to see if they were aware of this issue and see if they had 

any information about it. 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Michael Blankestyn 

<Michael.Blankestyn@r 

Barnett/RTP/USEPA/US@EPA 

mtinc.com> 

Plastics MACT 

To: 

cc: 

Subject: 

Keith 

Reinforced 

12/21/2001 11:00 AM 

Keith, („"$**•> (\Mi-V- j^l^MT^ fii^X te^V j 

I just wanted to lay out the scenario that the client I have is in 

regarding the reinforced plastics MACT. I understand that the comment 

period is over for this MACT, but I wanted to reiterate in case any 

other similar cases come up. 

The Ohio client of mine currently uses a high styrene content resin 

(44%) in their fiberglass application operations. This higher styrene 

content resin is required so that no gel coating is needed prior to 

fiberglass application. Currently, over two thirds of their business is 

for parts that do not have gel -coating. Unfortunately, this resin 

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cannot be currently classified as corrosive resistant and therefore will 

not be able to meet the MACT standard in its current form. One 

alternative to MACT compliance would be for the facility to utilize a 

lower styrene content resin and gel coat every part. This scenario 

would make the resin MACT compliant, but would result in higher supply 

costs and a significant increase in styrene emissions due to the large 

increase in gel coat usage. 

If you have any questions or comments, please contact me at 614-793-0026 

x-6221. I will be out of the office during the holiday season and will 

return on Wednesday, January 2, 2002. Have a good holiday break. 

Thanks. 

-Mike Blankestyn 

RMT, Inc. 

Dublin, Ohio 

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