OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

57) IV-C-30 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM 

_ 

Sheet 57 of 273 

p.1 
P.2 

Keith Barnett 

$Jl i 05/17/2002 05:18 PM 

A-94-52 

IV-C-30 

To: John Schweitzer <jschwtzr@gte.net> 

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

Subject: Re: May 23 worksh 

Dear John: 

I have reviewed your list and added comments in Bold text so you can see where the issue is already 

resolved, and where we need to discuss issues. 

CFA Issue List-5-17-02.d 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 
RP/C NESHAP - Open Issues CFA May 23, 2002 

John, I have added my comments in Bold text. 

SJT t S | Issue and CFA position Analysis Status 

II- l Remove above-the-floor 95% capture and control 

for larger existing sources. 

j 95% C&C is not technically feasible or affordable. 

EPA has decided not to require any existing 

sources to install C&C (except centrifugal casting 

and continuous lamination). 

! Many likely new plants are not similar to the floor 

II - 2 I Remove 95% capture and control for new sources, i setting sources, and will not be able to achieve or 

! afford 95% C&C. 

I don't see this requirement changing 

I The floor for existing and new pultrusion I The typical large "custom" pultrusion operations 

III-A ; operations should be 60% reduction (compared to I can achieve on average only 60% control, due to 

I "no control"). I limits in the available control technologies. 

See above 

TTT _ R j Pre-form injection should be a compliance option I Pre-form injection is the most effective available 

I for pultrusion with 90% control. i control for many products. 

We definitely want to include pre-form 

injection. We need to discuss the actual 

demonstrated performance. Also, I don't know 

if I can substitute per-form (assuming we agree 

the 90 percent control is accurate) in lieu of 95 

percent control. This may require some OGC 

input. 

j Pultrusion operations should be able to comply 

III - C j with the 60% reduction as a 12-month rolling 

I average across all pultrusion operations. 

Allows production flexibility while still achieving 

the required emission reductions. 

Since we allow averaging for continuous 

lamination, and open molding, I don't see any 

reason we cannot allow averaging for 

pultrusion. 

III-D 

Wet area enclosures should be permitted for all 

pultrusion sources, and the requirements for these 

enclosures should be modified in certain ways to 

allow practical compliance. 

Wet area enclosures are the most effective 

available control for many products. 

See m-A, but otherwise we can discuss how to 

accomplish this. 

III-E 

IV-A 

Large pultruded products should be exempt from 

control requirements. 

There are no effective commercially available and 

practical controls for large pultruded parts. 

The only source in this group using C&C needs to 

amend its permit to remove 100% capture because 

the enclosure unacceptably limits production. 

We can discuss this. 

IV-B-1 

Capture and control should not be required for 

SMC manufacturing (compounding). 

We don't require capture and control for 

existing sources. It will still be required for new 

sources. 

Covered doctor boxes and folded/sealed edges 

should not be required for SMC compounding. 

These technologies were tried but found to be not 

practical. The rule should require that compound 

be wrapped or placed in closed containers for 

storage and transportation. 

We have dropped the requirement for folding 

and sealing edges, and covering the doctor box. 

We will require the "resin transport system" to 

be covered or closed. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

Comments 

section Issue and CFA position Analysis ! Status 

IV-B-2 The requirement for nylon film for SMC 

compound should allow nylon-containing film. 

Most ofthe barrier films used are blends of nylon 

with other polymers. 

| We are changing the requirement to nylon 

| containing film. We still may need to define 

i what that means. 

V - A 

V -B 

Covers instead of add-on controls should be 

required for larger mixing operations. 

Use."Mixingand.BMC nmtfacturing." 

Covers achieve the same emission reduction as 

C&C for mixers, at much lower cost. 

I Capture and control only required for new 

j sources and that is the floor. 

"BMC manufacturing/mixing" is confusing. j We will change this 

Openings are needed to pennit entry of mixer 

shafts and instrumentation, and to allow venting 

during filling or emptying, and active venting is 

needed when adding fillers. 

! Openings and vents should be allowed in mixing 

V - C j and storage vessels. Active venting should be 

! allowed where needed. 

; We are working on this issue and we need to 

i discuss 

V - D Styrene and MMA should be permitted for 

cleaning in closed systems. 

Unwrapped compression molding charges should 

be allowed for all molds in one cycle ofa press, for 

loading charges into a hopper, and to allow the use 

of slitting machines. 

Cured resin must be removed from mixing and 

storage tanks to prevent contamination. 

I We should be able to accommodate this request 

V - E 

The hopper can be closed after loading, and the slit 

material can be placed in a container or otherwise 

covered. 

We should be able to change this 

I "Compression molding" should include the 

V - F ; addition of paste at the mold, and the use of in-

| mold coating. 

These operations are very common at compression 

molding sources and are considered part ofthis 

process. 

If the in mold coating is gel coat, then that step 

would be the same as any other gel coat 

operation. If this is some other type of material, 

then we need to know what and we can talk 

about how to handle it. 

V - G 

V - H 

Sources should be able to use emission factors that 

have been approved as part of Title Vpermits. 

These factors can be more accurate, and will 

reduce the administrative burden of MACT. 

The use of patching, bonding, and repair matenals *~ .. . .. . j u . • TM n 

, ,,,.,,, . ,

 6

 , • These matenals are widely used, but in small 

should be mcluded m the source category i titi 

definition, with no control requirements. j 

I would be in favor of this as long as the factors 

are adequately supported by test data. 

We need to discuss. But, at least in some cases, 

the base material is the resin and some type of 

filler is added. Therefore, these materials 

would already be covered. But let's discuss 

further. 

V - I 

V -J 

R&D activities should be exempt from control 

requirements. 

This is EPA's usual practice. 

We probably will go ahead an exempt R&D 

based on the definition in 112(c)(7). But let's 

discuss. 

Sources should be allowed to switch compliance 

options. 

Sources may occasionally need to switch to 

averaging, and the rule should provide guidance on 

doing so. 

Lets discuss how that guidance needs to be 

worded, and what Umits would need to be 

placed on switching (if any). 

V - K 

V -L 

The UEF should be used instead ofthe PV. 

The rule should allow the use of CFA's VSE test. 

The UEF are more accurate, and their use will 

reduce the administrative burden ofthe rule. 

Without a test, sources will not be able to take 

credit for use of suppressed resin systems. 

EPA has agreed to use the UEF. 

CFA is preparing the additional test data requested 

by EPA. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

Comments 

section 

Issue and CFA position Analysis Status 

Let's discuss. Aiso, we need to talk about how 

we insure that the equipment is properly 

operated. 

V - M 

V - N 

V-O-l 

A peiformance test should be used to qualify "non- i This will allow the development of new 

atomized" equipment. I equipment, and will increase clarity ofthe rule. 

Sources using averaging should calculate 

emissions as a weighted average of resin used. 

i The proposed rule weighs each month equally, 

I even if widely different amounts of resin are used. 

I think this makes sense. Let's discuss. 

"White/off-white" gel coats should be those that 

contain 10% or more by weight TiO?. 

j Increases clarity ofthe rule. I think this will be OK 

..N.*?^..^.9..^!'.??l,?.s'. 

Need to discuss. 

y:o-2 

V-O-3 

48%.HAP should.be„^ow*^.for CRgelcoat. 

48% HAP should be allowed for high performance 

gel coat. 

j Needed for adequate performance. 

I Needed for adequate performance. 

V-O-4 

V-O-5 

V-O-6 

There should be no HAP limit for fire retardant gel 

coat. 

48% HAP should be allowed for dear gel coat 

used for cultured marble. 

I Needed for adequate performance. 

| Needed for adequate performance. 

| Needed for adequate performance. 

Need to discuss. 

Need to discuss. 

49% HAP should be allowed for pigmented 

tooling gel coat, and 52% for clear. 

Need to discuss. 

V-O-7 

! Gel coat should be considered a resin when applied j 

I manually, and manual application of small j Increases clarity and reduces administrative burden 

j amounts of gel coat should be exempt from j of the rule. 

| recordkeeping requirements. 

Or we could simply treat as all gel coat as 

applied using spray with the same floor. In any 

case, where a small amount of gel coat is 

manually applied, I have no problem in trying 

to include it as part of some other operation 

where you don't have to separately track a 

small amount of materiaL 

| Adopt the industry-suggested definition for "low j Increasesclarityo f a^e . 

: flame/smoke. This is OK 

V - Q i 50% HAP should be allowed for low-shrink resin, j Needed for adequate performance. 

I don't have a problem with this, but I think we 

need to discuss how best to accommodate 

special resins and gal coats. 

V - R 

Requirements for testing HAP content should be 

the same as in the boat MACT. 

\ Increases clarity and reduces administrative burden 

I ofthe rule. 

I do not intend to put in a test requirement. I 

do plan to put in the manufacturing allowance 

that is in the Fiberglass Boat Manufacturing 

NESHAP. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

^!TM n t s l Issue and CFA position section Analysis Status 

V - S 48% HAP should be allowed for CR filament 

winding. 

Needed for adequate performance. 

EPA asked for examples of products for which the 

higher HAP limit is needed for technical reasons. 

T think the provision allowing the use of one 

resin for multiple operations and averaging 

may solve this problem for most facilities. 

Where a customer specified a resin, we can 

discuss how that can a accommodated in the 

rule. There nay be concerns for OGC on this. 

..?M*..L^..59*..9PJ?.9l¥.'?..*9.^!?..!.l*!Ba' 

V - T Remove SIC codes 2821 and 3087. These industries are not composites manufacturers. 

Applicability of the rule is not based on SIC 

Codes. 

3/19 | Update the combined mechanical database. 

EPA's new combined filled/unfilled mechanical 

apphcation database contains inaccurate 

information, and would result in a before-filler 

HAP limit of 35%. 

EPA has reported that the database has been 

corrected and the floors now limit before-filler 

HAP to 39%. The final floor ended up at 38.4 

percent. 

3/26-1 

3/26-2 

Change the definition of "centrifugal casting" to 

include only those operations where hot air is 

blown into the molds to cure the product. Also 

update Table 1. 

Most centrifugal casting operations use ambient 

cure or the molds are closed during cure. In these 

cases, the emission factors for mechanical or 

manual apphcation should be used, and these 

sources should not have to install C&C. 

We need to talk about this. 

Change "filament winding" to "filament 

application," and include only the apphcation of 

resin using a resin bath. Also update Table 1. 

Increases clarity ofthe rule. 

We need to talk about this. As a matter of fact, 

this issue recently came up for a new facility 

permit. 

i Change the definition of "polymer casting" to 

4/8 I remove the reference to "working" the resin, or 

i allow working the resin after molds are closed. 

: Ifthe edges of SMC compoimd is folded or sealed, 

5/23-1 | then it should not have to be wrapped or placed in 

! closed containers. 

Increases clarity ofthe rule. Should not be a problem. 

Folding or sealing edges is technically feasible in a 

few cases. 

We no longer require folding or sealing edges. 

5/23-2 

5/23-3 

When robotic loading devices are employed for 

compression molding operations, sufficient 

charges may be open (uncovered) per cavity for 

two press cycles. 

One open charge will be staged in the loader, and 

the other open charge (pre-stage) ready to be 

placed in the loader. 

I think we can accommodate this, but we need 

to discuss. 

A new source should be clearly defined as one at a 

site where previously there was no composite 

manufacturing operations, and all other operations 

should be considered existing sources. 

Because ofthe low capital investment needed for 

many composite manufacturing operations, many 

small changes to existing sources may trigger new 

source MACT if this definition is not clearly 

adopted. 

I thought the rule was pretty clear. But if we 

need more clarity let's discuss language. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

sStoirts iissu e and CFA p°siti°

n 

> 

I The final rule should clearly state that, for the 

5/23-4 I purposes of MACT, all HAP are assumed to be 

j styrene. 

Analysis Status 

EPA's database and floor calculations assumed that 

all HAP were styrene. 

Let's discuss, but I don't see a problem with 

this idea, and your statement is accurate. 

j The final rule should provide a procedure to revise 

5/23-5 i Table 1 ofthe rule so that new P2 technologies can 

Without a clear and workable procedure, new and 

effective emission reduction techniques will not be Yes, I agree. Let's discuss. 

j be used to meet the MACT emission limits. I developed or used.