p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

l-F-7 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 258 of 264 
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r\-°\dS^_ 

<L-f"J. CONTACT REPORT 

Off 

Person Calling: 

Person Called: 

Date of Contact: 

t 

Keith Barnett and Penny Lassiter 

U.S. Environmental Protection Agency 

OAQPS/ESD/OCG 

919-541-5605 and 919-541-5396 

Mr. Peter D. Eglinton 

Office of Management and Budget 

Room 10202 

725 17th Street NW 

Washington D.C. 

202-395-5887 

December 11,2000 

Contact Summary: 

The purpose of this call was to discuss OMB comments received December 7, 2000 on 

the proposal package for the Reinforced Plastic Composites NESHAP. The OMB comments are 

attached in a redline strikeout version of the preamble. 

The OMB comments were discussed and addressed in a revised version of the preamble. A 

redline strikeout copy ofthe revised preamble is attached. 

Keith Barnett 

i 
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COMMENTS RECEIVED FROM OMB ON DECEMBER 7, 2 000 

6560-50-P 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 63 

[FRL-] 

RIN 2060-AE79 

National Emission Standards for Hazardous Air Pollutants: 

Reinforced Plastic Composites Production 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: This action proposes national emission standards 

for hazardous air pollutants (NESHAP) for new and existing 

reinforced plastic composites production facilities. The 

proposed standards regulate production and ancillary 

processes used to manufacture products with thermoset resins 

and gel coats. Reinforced plastic composites production 

facilities emit hazardous air pollutants (HAP), such as 

styrene, methyl methacrylate (MMA), and methylene chloride 

(dichloromethane). These HAP have adverse health effects 

including headache, fatigue, depression, irritation of skin, 

eyes, and mucous membranes. Methylene chloride has been 

classified as a probable human carcinogen. These proposed 

standards will implement section 112(d) of the Clean Air Act 

(CAA) by requiring all major sources in this category to 

meet HAP emission standards reflecting the application of 

the maximum achievable control technology (MACT). We 

estimate the proposed NESHAP would reduce nationwide 
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2 

emissions of HAP from these facilities by approximately 

14,500 tons per year (tpy) (65 percent). 

DATES: Comments. Submit comments on or before [INSERT DATE 

60 DAYS AFTER DATE OF PUBLICATION OF THIS PROPOSED RULE IN 

THE FEDERAL REGISTER]. 

Public Hearing. If anyone contacts the EPA requesting to 

speak at a public hearing by [INSERT DATE 20 DAYS AFTER DATE 

OF PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER], a public hearing will be held on [INSERT DATE 30 

DAYS AFTER DATE OF PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER]. 

ADDRESSES: Comments. Written comments should be submitted 

(in duplicate if possible) to: Air and Radiation Docket and 

Information Center (6102), Attention Docket Number A-94-52, 

U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, DC 

20460. We request a separate copy also be sent to the 

contact person listed below in the FOR FURTHER INFORMATION 

CONTACT section. 

Public Hearing. If a public hearing is held, it will be 

held at EPA's Office of Administration Auditorium, Research 

Triangle Park, North Carolina. 

Docket. Docket No. A-94-52 contains supporting information 

used in developing the standards. The docket is located at 

the U.S. EPA, 401 M Street, SW, Washington, DC 2 0460 in Room 

M-1500, Waterside Mall (ground floor), and may be inspected 

from 8:30 a.m. to 5:30 p.m., Monday through Friday, 
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3 

excluding legal holidays. 

FOR FURTHER INFORMATION CONTACT: Keith Barnett, Organic 

Chemicals Group, Emission Standards Division (MD-13), U.S. 

EPA, Research Triangle Park, North Carolina 27711, (919) 

541-5605, barnett.keith@epamail.epa.gov. For public hearing 

information, contact Maria Noell, Organic Chemicals Group, 

Emission Standards Division (MD-13), U.S. EPA, Research 

Triangle Park, North Carolina 27711, (919) 541-5607. 

SUPPLEMENTARY INFORMATION: 

Comments. Comments and data may be submitted by electronic 

mail (e-mail) to: a-and-r-docket@epa.gov. Electronic 

comments must be submitted either as an ASCII file to avoid 

the use of special characters and encryption problems or on 

disks in WordPerfect® version 5.1, 6.1 or Corel 8 file 

format. All comments and data submitted in electronic form 

must note the docket number: A-94-52. No confidential 

business information (CBI) should be submitted by e-mail. 

Electronic comments may be filed online at many Federal 

Depository Libraries. 

Commenters wishing to submit proprietary information 

for consideration must clearly distinguish such information 

from other comments and clearly label it as CBI. Send 

submissions containing such proprietary information directly 

to the following address, and not to the public docket, to 

ensure that proprietary information is not inadvertently 

placed in the docket: Attention: Keith Barnett, c/o OAQPS 
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4 

Document Control Officer (Room 740B), U.S. EPA, 411 W. 

Chapel Hill Street, Durham, NC 27701. The EPA will disclose 

information identified as CBI only to the extent allowed by 

the procedures set forth in 40 CFR part 2. If no claim of 

confidentiality accompanies a submission when it is received 

by the EPA, the information may be made available to the 

public without further notice to the commenter. 

Public Hearing. Persons interested in presenting oral 

testimony or inquiring as tp whether a hearing is to be held 

should contact Maria Noell, Organic Chemicals Group, 

Emission Standards Division (MD-13), U.S. EPA, Research 

Triangle Park, North Carolina 27711, (919) 541-5607 at least 

2 days in advance of the public hearing. Persons interested 

in attending the public hearing must also call Maria Noell 

to verify the time, date, and location of the hearing. The 

public hearing will provide interested parties the 

opportunity to present data, views, or arguments concerning 

these proposed emission standards. 

Docket. The docket is an organized and complete file of the 

information considered by the EPA in the development of this 

rulemaking. The docket is a dynamic file because material 

is added throughout the rulemaking process. The docketing 

system is intended to allow members of the public and 

industries involved to readily identify and locate documents 

so that they can effectively participate in the rulemaking 

process. Along with the proposed and promulgated standards 
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5 

and their preambles, the contents of the docket, excluding 

interagency review materials, will serve as the record in 

the case of judicial review. (See section 307(d)(7)(A) of 

the CAA.) The regulatory text and other materials related 

to this rulemaking are available for review in the docket or 

copies may be mailed on request from the Air Docket by 

calling (202) 260-7548. A reasonable fee may be charged for 

copying docket materials. 

World Wide Web (WWW). In addition to being available 

in the docket, an electronic copy of the proposed NESHAP 

will also be available on the WWW through the Technology 

Transfer Network (TTN). Following signature, a copy of the 

proposed NESHAP will be posted on the TTN's-policy and 

guidance page for newly proposed or promulgated rules 

http://www.epa.gov/ttn/oarpg. The TTN provides information 

and technology exchange in various areas of air pollution 

control. If more information regarding the TTN is needed, 

call the TTN HELP line at (919) 541-5384. 

Regulated Entities. Categories and entities potentially 

regulated by this action include: 

NAICS SIC 

Category code code Examples of regulated entities 
P.8 

Industry 

Federal 

325211 

326122 

325991 

326191 

327991 

327993 

332998 

33312 

33651 

335311 

335313 

335312 

33422 

336211 

336112 

336211 

33651 

33-653 

336399 

33612 

336213 

336413 

336214 

Government 

This 

provides 

regulated 

facility 

applicabi 

you have 

action to 

2821 

3084 

3087 

3088 

3089 

3281 

3296 

3431 

3531 

3531 

3612 

3613 

3621 

3663 

3711 

3711 

3713 

3714 

3714 

3716 

3728 

3743 

3792 

3999 

6 

Reinforced plastic composites 

production facilities that 

manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

Federally owned facilities 

that manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

table is not intended to be exhaustive, but rather 

a guide for readers regarding entities likely to be 

by this action. To determine whether your 

is regulated by this action, you should examine the 

lity criteria in §63.5785 of the proposed rule. If 

any questions regarding the applicability of this 

a particular ent 

the preceding FOR FURTHER 

Outl 

ity, consult the person listed in 

INFORMATION CONTACT section. 

ine. The information presented in this preamble is 
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organized as follows: 

I. Introduction 

A. What is the source of authority for development of 

NESHAP? 

B. What criteria are used in the development of NESHAP? 

C. What are the potential health effects of the HAP emitted 

by the reinforced plastic composites production industry? 

D. How were the proposed NESHAP developed? 

E. What processes and operations are included in the 

Reinforced Plastics Composites Production source category? 

II. Summary of Proposed NESHAP 

A. What source categories and subcategories are affected by 

this proposed rule? 

B. What are the primary sources of HAP emissions and what 

are the emissions? 

C. What is the affected source? 

D. What are the emission limits, operating limits, and 

other standards? 

E. What is the MACT model point value and how is it used in 

these proposed NESHAP? 

F. When must I comply with these proposed NESHAP? 

G. What are my options for demonstrating compliance? 

H. What are the testing and initial compliance 

requirements? 

I. What are the continuous compliance requirements? 

J. What are the notification, recordkeeping and reporting 

requirements? 

III. Rationale for Proposed NESHAP 

A. How did we determine the source category to regulate? 

B. What pollutants are regulated under these proposed 

NESHAP? 

C. What is the "affected source" and how did EPA select the 

operations to be regulated by these proposed NESHAP? 

D. What is a new affected source? 

E. How did we determine the MACT floor for existing 

sources? 

F. How did we determine the MACT floor for new sources? 

G. Did we consider control options more stringent than the 

MACT floor? 

H. Why are some reinforced plastic composites production 

operations not subject to these proposed NESHAP? 

I. How did we select the form of these proposed NESHAP? 

J. How did we select the test methods for determining 

compliance with the proposed NESHAP? 

K. How did we determine the monitoring and recordkeeping 

requirements? 

L. How did we select the notification and reporting 

requirements? 

IV. Summary of Environmental, Energy, and Economic Impacts 

A. What facilities are affected by the proposed NESHAP? 

B. What are the air quality impacts? 
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C. What are the water quality impacts? 

D. What are the solid and hazardous waste impacts? 

E. What are the energy impacts? 

F. What are the cost impacts? 

G. What are the economic impacts? 

V. Relationship of Proposed NESHAP to Other Standards and 

Programs under the CAA 

A. National Emission Standards for Closed Vent Systems, 

Control Devices, Recovery Devices, and Routing to a Fuel 

Gas System or a Process (40 CFR Part 63, Subpart SS) 

B. Operating Permit Program 

C. NESHAP for Plastic Parts and Products 

VI. Administrative Requirements 

A. Executive Order 12866, Regulatory Planning and Review 

B. Paperwork Reduction Act 

C. Executive Order 13132, Federalism 

D. Executive Order 13084, Consultation and Coordination 

with Indian Tribal Governments 

E. Unfunded Mandates Reform Act of 1995 

F. Regulatory Flexibility Act (RFA), as amended by the 

Small Business Regulatory Enforcement Fairness Act of 1996 

(SBREFA), 5 U.S.C. 601 et sea. 

G. National Technology Transfer and Advancement Act 

H. Executive Order 13045, Protection of Children from 

Environmental Health Risks and Safety Risks 

I. Introduction 

A. What is the source of authority for development of 

NESHAP? , 

Section 112 of the CAA requires us to list categories 

and subcategories of major sources and area sources of HAP 

and to establish NESHAP for the listed source categories and 

subcategories. Reinforced Plastic Composites Production 

(major sources only) was included on the initial list of 

source categories published on July 16, 1992 (57 FR 31576). 

Major sources of HAP are those that have the potential to 

emit greater than 10 tpy of any one HAP or 25 tpy of any 

combination of HAP. 
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9 

B. What criteria are used in the development of NESHAP? 

The CAA requires NESHAP to reflect the maximum degree 

of reduction in emissions of HAP that is achievable. This 

level of control is commonly referred to as the MACT. 

The MACT floor is the minimum control level allowed for 

NESHAP. This concept appears in section 112(d)(3) of the 

CAA. For new sources, the MACT floor cannot be less 

stringent than the emission control that is achieved in 

practice by the best-controlled similar source. The MACT 

standards for existing sources can be less stringent than 

standards for new sources, but they cannot be less stringent 

than the average emission limitation achieved by the bestperforming 12 percent of existing sources in the category or 

subcategory (or the best-performing 5 sources for categories 

or subcategories with fewer than 30 sources). 

In developing MACT, we also consider control options 

that are more stringent than the floor. We may establish 

standards more stringent than the floor based on the 

consideration of cost of achieving the emissions reductions, 

any nonair quality health and environmental impacts, and 

energy requirements. 

C. What are the potential health effects of the HAP emitted 

by the reinforced plastic composites production industry? 

Today's proposed NESHAP are intended to protect air 

quality and promote the public health by reducing emissions 
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10 

of some of the HAP listed in section 112(b)(1) of the CAA. 

The HAP emitted by the reinforced plastic composites 

production industry include, but are not limited to, 

styrene, methyl methacrylate, and methylene chloride. 

[COMMENT: Can EPA provide the level of emissions (e.g., 

tons Tier year) for each of these?] Exposure to these 

compounds has been demonstrated to cause adverse health 

effects, including chronic health disorders (e.g., headache, 

fatigue, and depression) and.acute health disorders (e.g., 

irritation of skin, eyes, and mucous membranes and decreased 

respiratory function). Methylene chloride has been 

classified as a probable human carcinogen and styrene as a 

possible human carcinogen. In general, these findings have 

only been shown with concentrations higher than those 

typically in the ambient air. [COMMENT: Can EPA elaborate 

on the relative magnitude of the difference in ambient 

concentrations and the concentrations that caused the 

effects?] 

We do not have the type of current detailed data on 

each of the operations covered by today's proposed NESHAP 

(and the people living around the operations) necessary to 

conduct ,an analysis to determine the actual population 

exposures to the HAP emitted from these facilities and the 

potential for resultant health effects. Therefore, we do 

not know the extent to which the adverse health effects 

described above occur in the populations surrounding these 
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11 

operations. However, to the extent the adverse effects do 

occur, the proposed rule willwould reduce emissions and 

subsequent exposures. 

1. Styrene 

Acute (short-term) exposure to styrene in humans 

results in mucous membrane and eye irritation and 

gastrointestinal effects. Chronic (long-term) exposure to 

styrene in humans may cause effects on the central nervous 

system (CNS) such as headache, fatigue, weakness, 

depression, and hearing loss. There is limited evidence 

that occupational exposure to styrene is associated with an 

increased frequency of spontaneous abortions and decreased 

frequency of births and an increased risk of leukemia and 

lymphoma. The EPA considers this evidence on occupational 

exposure to styrene to be inconclusive. The International 

Agency for Research on Cancer has classified styrene as a 

Group 2B, possible human carcinogen. The EPA has not 

classified styrene with respect to carcinogenicity. 

2. Methyl-Methacrylate 

Methyl methacrylate irritates the skin, eyes, and 

mucous membranes in humans. An allergic response to dermal 

exposure may develop. Respiratory effects following acute 

(short-term) exposure include chest tightness, dyspnea, 

coughing, wheezing, and reduced lung function. Neurological 

symptoms including headache, lethargy, lightheadedness, and 

a sensation of heaviness in the arms and legs have also been 
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12 

reported following acute exposure to MMA. Effects to the 

liver, kidney, brain, spleen, and bone marrow have been 

reported in chronic (long-term) animal studies of MMA 

inhalation. Fetal abnormalities have been reported in 

animals exposed to MMA by injection and inhalation. In 

several animal studies, no carcinogenic effects were 

observed. The EPA has classified MMA in Group E (not likely 

to be carcinogenic in humans). 

3. Methylene Chloride 

Acute (short-term) exposure to methylene chloride by 

inhalation affects the nervous system, causing decreased . 

visual, auditory, and motor functions. These effects are 

reversible once exposure ceases. The effects of chronic 

(long-term) exposure to methylene chloride suggest that the 

CNS is a potential target in both humans and animals. 

Limited animal studies have reported developmental effects. 

Human data are inconclusive regarding methylene chloride and 

cancer. Animal studies have shown increases in liver and 

lung cancer and benign mammary gland tumors following the 

inhalation of methylene chloride. The EPA has classified 

methylene chloride as a Group B2, probable human carcinogen. 

D. How were the proposed NESHAP developed? 

We started the development of the proposed NESHAP by 

sending information collection request (ICR) surveys to 

facilities with applicable standard industries 

classification (SIC) codes. In addition to these surveys, 
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13 

we consulted with numerous members of the reinforced plastic 

composites industry, representatives of industry trade 

associations, and material and equipment vendors in 

developing the proposed NESHAP. 

We held a series of approximately 35 meetings and 

visited approximately 25 facilities over a period of 8 

years. These meetings and site visits were held to keep 

stakeholders informed and to gather additional data and 

information on issues relevant to the proposed NESHAP. The 

stakeholders helped in data gathering, arranged site visits, 

identified issues and provided information to help resolve 

issues in the rulemaking process. 

We identified the MACT floor control level with 

information obtained through survey responses, site visits, 

telephone contacts, and operating permits. We assessed 

control options more stringent than the MACT floor by 

identifying the level(s) and method(s) of control achieved 

by the best controlled sources in the industry and 

conducting analyses designed to determine the cost, 

economic, energy, and environmental impacts of implementing 

the more stringent control options. 

E. What processes and operations are included in the 

Reinforced Plastic Composites Production source category? 

The Reinforced Plastic Composites Production source 

category involves the production of plastic products from 

cross-linking resins, usually in combination with 
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14 

reinforcing materials and inorganic fillers. The production 

of products that do not contain reinforcing materials is 

also included in this category, as well as the production of 

intermediate compounds which are later used to make the 

final plastic products. [COMMENT: Please elaborate on the 

rationale for including "products that do not contain 

reinforcing material". given the more limited scope implied 

bv the title.] This source category is limited to those 

resins which contain styrene, either by itself or with a 

combination of other monomers or solvents. 

There are a wide variety of operations that use 

styrene-containing resins to make thermoset plastics. Such 

production operations include manual resin application, 

mechanical resin application, filament winding, gel coat 

application, compression/injection molding, resin transfer 

molding, centrifugal casting, continuous 

lamination/continuous casting, polymer casting, pultrusion, 

and sheet molding compound (SMC) manufacturing. There are 

also ancillary operations such as cleaning, mixing/bulk 

molding compound (BMC) manufacturing, and storage that occur 

in conjunction with these production operations. Many 

facilities will use multiple operations in the manufacturing 

of their product. 

II. Summary of Proposed NESHAP 

This preamble section discusses the proposed NESHAP as 

they apply to you, the owner or operator of a new or 
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15 

existing reinforced plastic composites production facility. 

A. What source categories and subcategories are affected bv 

this proposed rule? 

Today's proposed rule applies to the Reinforced 

Plastics Composites Production source category. We 

evaluated the use of subcategories based on size (i.e., tpy 

of HAP emitted). These subcategories played an important 

role in defining the new source MACT floors. However, we 

had no ieason Lo believethe available data that we used to 

develop the MACT floor for existing source MACT floors were 

size-dependent;—thaL—rs-;—we did not observe any—dif leience 

in—Llie data fromsources do not show significant differences 

between larger-emitting versus smaller-emitting sources. 

Thus, we did not go through a separate analysis for each 

subcategory of existing sources.— 

B. What are the primary sources of HAP emissions and what 

are the emissions? 

The primary source of HAP emissions from the Reinforced 

Plastic Composites Production source category is the 

evaporation of styrene and other organic liquid HAP 

contained in the resin during the application and/or curing 

of the resin. Since styrene participates in the curing 

reaction, not all of it is emitted. The HAP emissions also 

occur during ancillary operations such as cleaning, 

mixing/BMC manufacturing, and storage. 

Total baseline HAP emissions from the Reinforced 
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Plastic Composites Production source category are 

approximately 22,200 tpy. Emissions from spray lay-up and 

gel coating constitute approximately 56 percent and 19 

percent of the total baseline emissions, respectively. The 

remaining HAP emissions are primarily from hand layup/bucket and tool application, compression 

molding/injection molding, filament winding, SMC 

manufacturing, and centrifugal casting-. 

C. What is the affected source? 

TUnder the proposal, the affected source xswould be the 

combination of all operations regulated under these 

standards at a reinforced plastic composites production 

facility. The following regulated operations are typically 

performed at reinforced plastic composites production 

facilities and are part of the affected source: open 

molding, closed molding, centrifugal casting, continuous 

lamination/continuous casting, polymer casting, pultrusion, 

SMC manufacturing, equipment cleaning, 

BMC/manufacturing/mixing, and storage of HAP containing 

materials. 

D. What are the emission limits, operating limits, and 

other standards? 

We are proposing the requirements of these NESHAP in 

the form of emission limits (i.e., point value, mass rate, 

or percent reduction), operating limits, and work practice 

standards. Work practice standards include design, 
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17 

equipment, work practices, and operational standards. 

In developing proposed requirements for reinforced 

plastic composites affected sources, we have provided an 

alternative format where possible. For example, a facility 

meeting a 95 percent emission reduction requirement for open 

molding processes can alternatively meet a point value. We 

have also provided alternatives for meeting the limits for 

continuous lamination and continuous casting processes. 

We are proposing a threshold for existing sources to 

distinguish between sources that would meet the floor 

requirements, that are generally based on pollution 

prevention, and those that would have to meet a more 

stringent above-the-floor requirement based on 95 percent 

control of HAP emissions. For small businesses, the 

threshold is 250 tpy of combined HAP emissions for open 

molding, centrifugal casting, continuous lamination/casting, 

pultrusion, and SMC manufacturing. The definition of a 

small business for this source category ranges from 500 to 

1000 employees. More specific information on the definition 

of a small business may be found in the discussion of the 

Regulatory Flexibility Act in the Administrative 

Requirements section of this preamble. For businesses that 

are not small businesses, the threshold is combined 

emissions of HAP of 100 tpy from the same operations. We 

believe that it is cost effective for these facilities to 

meet this requirement. Nevertheless, we request comments 
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18 

(with supporting data) on the impacts of a 100 tpy threshold 

for businesses that are not small businesses. 

For all open molding operations (i.e., corrosionresistant, noncorrosion-resistant, tooling, and gel coat) 

and centrifugal casting (corrosion-resistant and 

noncorrosion-resistant) at existing sources below the 

threshold, and new sources with HAP emissions less than 100 

tpy, you must comply with a HAP emission limit that is 

calculated for your facility using MACT model point value 

equations for each open molding and centrifugal casting 

operation. For open molding and centrifugal casting 

operations at new sources with HAP emissions equal to or 

greater than 100 tpy, and existing sources with HAP 

emissions equal to or greater than the applicable thresholds 

(i.e., 100 tpy for large businesses and 250 tpy for small 

businesses), we are proposing to require owners and 

operators to reduce emissions by 95 percent from these 

operations or comply with a corresponding HAP emission limit 

calculated using the MACT model point value equations. 

We are proposing to require owners and operators of 

continuous lamination/continuous casting operations at 

existing sources below the above-the-floor applicability 

thresholds, and new sources with HAP emissions less than 100 

tpy, to reduce emissions by 58 percent. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators of 
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19 

pultrusion operations at existing sources below the abovethe-floor thresholds, and new sources with HAP emissions 

less than 100 tpy, to reduce emissions by 60 percent. This 

reduction is based on applying a wet enclosure or using 

direct die injection to limit emissions. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators at 

both new and existing sources using injection/compression 

molding operations to reduce HAP emissions through the use 

of a work practice, whereby only one charge per machine is 

uncovered, unwrapped, or exposed per mold cycle per 

compression/injection molding machine. 

We are proposing to require owners and operators of 

sheet molding compound operations at existing sources below 

the above-the-floor thresholds, and new sources with HAP 

emissions less than 100 tpy, to reduce emissions by using a 

nylon film, or film with equal or lower permeability to 

styrene, to enclose their SMC operation. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators of all 

new and existing reinforced plastic composites affected 

sources to use cleaners containing no HAP. 

We are proposing to require owners and operators of 

resin mixing and bulk molding compound operations at 

existing sources below the above-the-floor applicability 

thresholds, and new sources with HAP emissions less than 100 
P.22 

20 

tpy, to limit HAP emissions by covering mixers such that 

there are no visible gaps. For other new and existing 

sources, we are proposing to require that you reduce 

emissions from mixing and BMC manufacturing by 95 percent. 

For existing sources that are subject to the above-thefloor control level of 95 percent HAP emission reduction, we 

examined an alternative, based on pollution prevention, that 

would be more effective than the requirements of the MACT 

floor for existing sources. However, we were unable to 

develop an acceptable alternative to include in the proposed 

standards that meets the statutory requirements of MACT. We 

are soliciting comment on a possible alternative. 

We are proposing to require all owners and operators at 

any existing or new affected source to keep all organic HAPcontaining storage vessels covered, except during the 

addition or removal of materials. 

E. What is the MACT model point value and how is it used in 

these proposed NESHAP? 

The MACT model point value is a number calculated for 

each open molding operation and centrifugal casting 

operation and is a surrogate for emissions. The MACT model 

point value is a way to rank the relative performance of 

different resin and gel coat emissions reduction techniques. 

This approach allows you to create control strategies using 

different resin and gel coat emissions reduction techniques. 

The proposed standards provide equations to calculate MACT 
P.23 

21 

model point values based on HAP content and application 

method for each material that you use. These MACT model 

point values are then averaged and compared to limits in the 

proposed standards to determine if your open molding 

operations are in compliance. 

The MACT model point values have units of pounds of HAP 

per ton of resin or gel coat applied. It is important to 

note that the MACT model point values are surrogates for 

emissions, and the MACT model point value equations are used 

only for determining compliance with the proposed Reinforced 

Plastic Composites Production NESHAP. The MACT model point 

value equations cannot be used in place of emission factor 

equations to demonstrate compliance with other regulations. 

The MACT model point value equations only account for 

HAP content and application method. Other factors 

(including curing time, part thickness, and operator 

technique) also affect emissions, and these factors are not 

accounted for in the MACT model point value equations. 

Determining the HAP content of materials and the method of 

application is relatively simple, and these factors are the 

most significant in affecting emissions. It is much more 

difficult to determine the effects of other factors on 

emissions. [COMMENT: Can EPA provide examples of these 

"other factors", to perhaps encourage public input?] For 

this reason, other factors are not included in the MACT 

model point value equations. More information on the 
P.24 

22 

development of this model is available in the docket'. EPA 

welcomes comments on the data and assumptions used to 

develop the MACT point value equations. 

F. When must I comply with these proposed NESHAP? 

Existing reinforced plastic composites production 

operations must comply within 3 years of the date the 

promulgated NESHAP are published in the Federal Register. 

New affected sources that startup before the promulgated 

NESHAP are published in the Federal Register must comply no 

later than the effective date of the NESHAP, which will be 

the same as the publication date. New affected sources that 

startup after the promulgated NESHAP are published in the 

Federal Register must comply upon startup. Existing area 

sources that increase their emissions or their potential to 

emit such that they become a major source of HAP must be in 

compliance within 3 years of the date they become a major 

source. New area sources that become major sources of HAP 

must comply upon becoming a major source. 

We are proposing to provide new and existing facilities 

3 years to comply from the time their HAP emissions reach or 

exceed the applicability thresholds requiring the 

installation of add-on controls, if these HAP emissions 

increases occur after their initial compliance date. We are 

providing this compliance time for new and existing sources 

under these circumstances because complying with the add-on 

control requirements subsequent to your initial compliance 
P.25 

23 

date would require the same amount of time as for existing 

sources that must install add-on controls within 3 years of 

the effective'date of the NESHAP. 

G. What are my options for demonstrating compliance? 

Today's proposed NESHAP provide several options for 

compliance. We are providing these options to afford 

industry the flexibility to decide which method is best 

suited for each particular situation. 

1. Open Molding and Centrifugal Casting Operations 

For open molding operations at existing and new 

sources, this proposal would allow vou mavto choose to 

comply by meeting the individual MACT point value for each 

operation at your affected source,— or by meeting the 

weighted' average MACT point value for all open molding 

operations at your affected source. In addition, if you 

have any combination of manual resin application, mechanical 

resin application, filament winding, or centrifugal casting 

operations at your affected source, you mayeouId comply by 

meeting the'MACT point value for any one of these operations 

and by using the same resin for all the other operations. 

For open molding and centrifugal casting operations 

where vuu are recmiiedthe proposed rule would require you to 

meet a percent reduction, you ma-ycould use an add-on control 

device to achieve the required reduction or you may choose 

to meet a MACT point value that corresponds to that 

particular operation's percent reduction. 
P.26 

24 

2. Continuous Casting/Lamination Operations 

For continuous casting/lamination operations at 

existing and new sources, we are proposing that you mary 

ocould demonstrate that each continuous casting line 

and each continuous lamination line meets the appropriate 

standard. Alternatively, you maycould average all your 

continuous casting and continuous lamination lines together, 

and demonstrate that they meet the appropriate standard. An 

additional alternative -rswould be to capture your emissions 

from your wet-out area in a permanent total enclosure that 

meets EPA's criteria, as specified in Method 204 in appendix 

M of 40 CFR part 51, and vent these wet-out emissions 

through a closed vent system to a control device achieving 

95 percent reduction of HAP emissions. TUnder the proposal, 

.these alternatives may alsocould be used in combination to 

demonstrate compliance. We request comments on the 

feasibility of ensuring a permanent total enclosure for the 

variety of products manufactured at your facility. 

3. Pultrusion Operations 

For existing and new pultrusion operations, under the 

proposal vou maycould capture and vent your emissions to a 

control device that achieves the required percent reduction 

of HAP emissions. You maycould also elect to use direct die 

injection pultrusion machines with resin drip collection 

systems that meet the criteria specified. AWe are also 

proposing an additional alternative only available to 
P.27 

25 

existing sources—rs: the use of a wet-area enclosure with a 

resin drip collection system. For both new and existing 

sources, you maycould use the available options in 

combination to achieve compliance under the proposal. 

4. Ancillary Operations 

For ancillary operations at all sources, such as 

cleaning, storage, and mixing/BMC operations at existing 

sources, the only option availablewe are proposing is to 

comply with the specified work practice standards. 

H. What are the testing and initial compliance 

requirements? 

We are leuuiiiiiuproposinq to require owners and 

operators of all affected sources which use a control device 

to demonstrate compliance to conduct an initial performance 

test using specified EPA test methods. The owner or 

operator would test at the inlet and outlet of the control 

device, and using these results, calculate a percent 

reduction. 

We are also leuuirinqproposing to require owners and 

operators that use— permanent total enclosures to conduct a 

design evaluation as specified by EPA Method 204. If your 

enclosure does not meet the requirements for a permanent 

total enclosure, you musLwould need to test the enclosure 

using EPA Methods 204B through E to determine the capture, 

efficiency. We request comments on the feasibility of using 

a permanent total enclosure for all affected processes. 
P.28 

26 

Prior to the initial performance test, owners and 

operators of affected sources arewould be required to 

install the parameter monitoring equipment to be used to 

demonstrate compliance with the operating limits. During 

the initial performance test, the owners and operators would 

use the parameter monitoring equipment to establish 

operating parameter limits. 

I. What are the continuous compliance reguirements? 

If you use an add-on control device, we are proposing 

that you monitor and record the operating parameters 

established during the initial performance test, and 

calculate average operating parameter values averaged over 

the period of time specified in these proposed NESHAP to 

demonstrate continuous compliance with the operating limits. 

If you use the MACT point value system to maintain a 

point value less than or equal to the appropriate point 

value listed in today's proposed NESHAP, we are proposing to 

require that you calculate the point value one time if the 

resin used in the operation remains the same, or calculate 

the point value on a 12-month rolling average each month if 

the resin varies between operations or over time. 

If you are complying with work practice standards, we 

are proposing that you demonstrate compliance with the work 

practice standards in today's proposed NESHAP by performing 

the necessary work practices and by keeping a record 

certifying that you are in compliance with the work 
P.29 

27 

practices. 

We request comments on each of these requirements. 

J. What are the notification, reporting, and recordkeeping 

requirements? 

We are proposing that you submit Initial Notification, 

Notification of Performance Tests, and Notification of 

Compliance Status reports by the specified dates in the 

proposed NESHAP, which may vary depending on whether the 

affected source is new or existing. 

You mustwould also need to submit semiannual compliance 

reports. If you take action that is inconsistent with your 

approved startup, shutdown, and malfunction (SSM) plan, then 

you must would need to submit SSM reports within 2 days of 

starting such action,— and within 7 days of ending such 

action. 

We are proposing that you keep a copy of each 

notification and report, along with supporting 

documentation. [COMMENT: For how long?] You mustwould 

need to keep records related to SSM, records of performance 

tests, and records for each continuous parameter monitoring 

system. -rUnder the proposal, if you must comply with the 

work practice standards in today's proposed NESHAP, you 

musLwould also need to keep records certifying that you are 

in compliance with the work practices. [COMMENT: For how 

long?] If you are usinquse the MACT point value system to 

demonstrate compliance, you mustwould need to keep all data, 
P.30 

28 

assumptions, and calculations used to determine your MACT 

point value. For new and existing continuous 

lamination/casting operations, you mustwould also need to 

keep the following records when complying with the percent 

reduction or pound per ton requirements: all data, 

assumptions, and calculations used to determine the percent 

reduction and/or pounds per ton, as applicable; a brief 

description of the rationale for the assignment of an 

equation or factor to each formula; all data, assumptions, 

and calculations used to derive facility-specific emission 

estimations and factors; identification and rationale for 

the worst-case scenario; and documentation that the 

appropriate regulatory agency has approved all emission 

estimation equations and factors.-

We specifically request comments on the Agency's need 

for this information; the amount of burden associated with 

the proposed notification, reporting, and recordkeeping 

requirements; and any suggested methods for minimizing 

respondent burden, including the use of automated collection 

techniques. 

III. Rationale for Proposed NESHAP 

A. How did we determine the source category to regulate? 

Reinforced Plastic Composites Production was included 

on the initial list of source categories published on July 

16, 1992 (57 FR 31576). In establishing the source category 

list, we stated that we would refine category descriptions 
P.31 

29 

during the rulemaking process, if necessary, based on 

additional information available. We did not find it 

necessary to refine the source category description for 

Reinforced Plastic Composites Production. [COMMENT: Can 

EPA elaborate on the decision criteria used to determine 

whether or not to refine the source category description?] 

B. What pollutants are regulated under these proposed 

NESHAP? 

The proposed NESHAP regulate total HAP rather than 

individual HAP compounds. Standards for total HAP simplify 

compliance and enforcement compared with standards for 

individual HAP compounds. Styrene is the HAP emitted in the 

largest magnitude. Other HAP emitted from reinforced 

plastic composites production facilities include MMA and 

methylene chloride. 

C. What is the "affected source" and how did EPA select the 

operations to be regulated by these proposed NESHAP? 

To provide compliance flexibility, we defined the 

affected source as the combination of all reinforced plastic 

composites operations at a site. This broad source 

definition allows a manufacturer to determine compliance by 

averaging the HAP content of different products used 

throughout the facility, within certain defined operations, 

and to use different application techniques as needed to 

meet product quality specifications. 

D. What is a new affected source? 
P.32 

30 

A new affected source is any reinforced plastic 

composites production facility that meets both of these 

criteria: 

• It commenced construction after today's date; and 

• It is at a site that does not presently contain 

any reinforced plastic composites production 

operations. 

In section 112 of the CAA, the definition of new 

sources also includes stationary sources that commence 

reconstruction after the publication date of a proposed 

NESHAP. The Small Business Advocacy Review (SBAR) Panel 

recommended that we carefully review our definition of 

reconstruction for this industry. As defined in the General 

Provisions for 40 CFR part 63, "reconstruction" means the 

replacement of components of an affected, or a previously 

unaffected, stationary source to such an extent that: (1) 

the fixed capital cost of the new components exceeds 50 

percent of the fixed capital cost that would be required to 

construct a comparable new source; and (2) it is 

technologically and economically feasible for the 

reconstructed source to meet the relevant standards (as 

established by the Administrator or a State) pursuant to 

section 112 of the CAA. 

We envision that the types of changes that would 

typically occur at existing facilities would be replacement 

of spray equipment and molds. We do not believe that it 
P.33 

31 

would be technologically and economically feasible for an 

existing source making these types of changes to meet new 

source MACT. Thus, such changes do not meet the definition 

of reconstruction in the General Provisions and would not 

subject the sources making such changes to new source MACT._ 

We welcome comments about other types of changes that should 

be considered outside the definition of reconstruction. 

E. How did we determine the MACT floor for existing 

sources? 

Several considerations underlie our MACT floor 

determinations. These considerations include: if/how the 

source category is to be subcategorized, how emissions types 

within the affected source are to be analyzed, and what are 

the best performing sources. 

We identified 433 facilities that are major sources 

based on their potential to emit or have the potential to be 

major sources based on collocation with other HAP-emitting 

processes not part of this source category. 

If technical differences in emissions characteristics, 

processes, control device applicability, or opportunities 

for pollution prevention exist within the source category, 

it may be appropriate to set separate floors based on these 

characteristics. In analyzing the available data on this 

source category, it was apparent that reinforced plastic 

composite facilities, as a whole, are extremely diverse in 

their emissions characteristics, control device 
P.34 

32 

applicability, and opportunities for pollution prevention. 

Therefore, we explored various ways of grouping the 

operations that may be present at these facilities. 

For existing sources, it was apparent that almost all 

of the existing source floors would be based on pollutionprevention techniques such as lowering the HAP content in 

resins and gel coats, covering baths and containers holding 

resins, and using nonatomized spray applications. The 

extent and performance of pollution-prevention techniques 

are dependent on the specific operation. For this reason, 

the data were subdivided by specific operation, and a floor 

for each operation was developed. 

Operations were segregated by several factors. The 

first was mold type (i.e., open, partially open, and 

closed). We also segregated operations by resin and gel 

coat application method; these include mechanical, manual, 

filament winding, and centrifugal casting. The type of mold 

and resin application method impacts the emission potential 

of a particular operation and also the effectiveness and 

applicability of different control techniques. We also 

segregated continuous operations such as pultrusion, 

continuous lamination, continuous casting, and the 

manufacture of sheet molding compound. 

The final criteria used was product type. The required 

properties of the final product place certain constraints on 

the raw materials that can be used. This, in turn, 
P.35 

33 

influences the limits on levels of HAP in the raw materials. 

We identified several product criteria where the raw 

materials required to produce the product are dissimilar 

enough that a separate floor determination was required. 

The first is corrosion resistance. Reinforced plastic 

composites can generally be divided into two types--

corrosion-resistant and noncorrosion-resistant products. 

Corrosion-resistant products require resins specifically 

formulated for corrosion-resistant applications. We also 

included high-strength applications in the corrosionresistant grouping. These applications include products 

such as structural members and utility poles. These require 

resins with higher HAP contents than general purpose resins. 

The higher HAP contents for both corrosion-resistant and 

high-strength applications are necessary to produce a 

laminate with a greater concentration of styrene crosslinking. This higher level of cross-linking is necessary 

for either corrosion-resistance'or high-strength. 

We also separated gel coats from resins because these 

materials have significantly different functions in the 

final product and are formulated differently. Gel coats 

were further subdivided into clear, white and off-white, and 

other colors. Clear gel coats require significantly higher 

HAP content than pigmented gel coats, and are, therefore, 

unable to be formulated to the same HAP levels. White and 

off-white gel coats can be formulated to lower HAP contents 
P.36 

34 

on a weight-percent basis than other colors due to the fact 

that white pigments are heavier than other color pigments. 

Class 1 fire and smoke rated products were separated 

from other products because their unique properties require 

a resin with a significantly higher HAP content than any 

other products. Separating Class 1 fire and smoke rated 

products was also one of the recommendations of the SBAR 

Panel. 

Tooling resins and gel coats are used to make the molds 

that, in turn, are used to produce reinforced plastic parts. 

Molds must have different properties compared to the 

products they are used to produce. These include a high 

level of dimensional stability and resistance to heat 

compared to other reinforced plastic composites. Therefore, 

separate floors were developed for tooling resins and gel 

coats.— 

We believe we have captured the full range of processes 

and products in our proposed categories. We request 

comments with supporting data on any processes or products 

that might not be adequately represented. 

Once the data were subdivided by specific operation, 

the data were ranked by HAP emissions. Open molding and 

centrifugal casting operations were ranked based on a 

surrogate emission factor called a point value. As 

previously discussed, point values are based on resin and 

gel coat application method and HAP content, and provide a 
P.37 

35 

relative measure of emissions between operations with 

varying resin and gel coat HAP contents and application 

methods. Data to quantify the impacts of other factors that 

may affect emissions are not easily obtainable and were not 

available for this analysis. [COMMENT: Can EPA provide 

examples of such "other factors" and the potential impact of 

omitting them from the analysis?] The point value system 

was also developed to allow a facility to average different 

operations together to meet the applicable proposed 

standards. The ability to average is intended to provide*? 

additional compliance flexibility. 

The individual operations were then ranked based on the 

point value (for open molding and centrifugal casting), 

percent of emission reduction (pultrusion, continuous 

lamination/casting, SMC manufacturing), covering open 

containers or exposed resin (storage, BMC 

manufacturing/mixing, injection/compression molding), or the 

use on non-HAP cleaning solvents (equipment cleaning). The 

median facility of the top 12 percent (or top 5 for 

operations with less than 30 sources) was then selected as 

representing the existing source floor. 

For some of these operations, the available data were 

insufficient to perform a ranking. These were non-white 

pigmented gel coats, products with a Class 1 fire and smoke 

rating, and high-strength products. 

We identified two facilities that produce products that 
P.38 

36 

require a Class 1 fire and smoke rating. Both facilities 

use a resin with a 60 percent HAP content. We chose use of 

this resin as the floor. From a 60 percent HAP resin, we 

calculated different point values for mechanical, manual, 

and filament winding resin application. 

The data we used to set floors for pigmented gel coats 

were weighted averages reported by the facilities. This 

data included some information on colors,.but not enough 

facilities reported color information to perform a 

meaningful ranking. Because of the predominance of white 

and off-white gel coats, these data are not representative 

for other colors. However, many facilities offer other 

colors. The pigments used in white and off-white gel coats 

are much denser than the pigments used in other colors. For 

that reason, weight percent HAP in white and off-white gel 

coats tends to be lower. A floor based on white and offwhite gel coat HAP contents would preclude a facility using 

other colors. 

Based on industry comments and the recommendation of 

the SBAR panel, we determined that a HAP content of 37 

percent is the minimum that would provide acceptable gel 

coat performance. In the absence of any other data, we 

adopted a 37 percent HAP gel coat as the floor. The 37 

percent HAP content was converted to a point value using the 

appropriate point value equation. (See the final report of 

the SBAR Panel in the docket.) We request comments and 
P.39 

37 

supporting data on the appropriateness of 37 percent as a 

minimum HAP content for acceptable gel coat performance. 

The data supplied by industry did not differentiate 

products that require higher than typical strength 

properties. Therefore, we could not determine a floor with 

the facility data base. We discussed this issue as part of 

the SBAR Panel with several manufacturers that produce highstrength products. We also reviewed the requirements of 

South Coast Air Quality Management District Rule 1162. Rule 

1162 specifically addresses high-strength products and 

contains the same requirements for high-strength products 

and corrosion-resistant products. As a result, we 

determined using the data for corrosion-resistant resins 

would be the most appropriate way to determine floors for 

high-strength products. Therefore, we are proposing the 

same floors for high-strength products and corrosionresistant products are—the same. This is consistent with a 

recommendation of the SBAR Panel. We welcome comments on 

this approach. 

There are many facilities that use multiple operations 

to produce a product. An example of this would be a 

facility producing corrosion-resistant tanks using filament 

winding to produce the main circular portion, mechanical 

resin application for the tank ends, and manual resin 

application to join the parts together. Industry 

representatives pointed out that the floors we had developed 
P.40 

38 

from the data base would potentially require a facility to 

use three different resins to produce a single product. 

This could potentially lead to problems of resin 

compatibility and product failures. The SBAR Panel report 

included a recommendation that we allow a facility to use 

the same resin for all processes. 

As a result, we reexamined the floors for facilities 

with multiple processes. We determined that, based on the 

data available, the appropriate approach would be to have a 

provision in the proposed standards to allow a facility to 

select one operation, determine the resin they could use to 

meet the floor, and then use that same resin in all other 

operations. We did not have the data to determine what that 

operation should be in all cases, so we are not specifying a 

particular operation in the proposed standards. We assumed 

that a facility would select the operation that allows them 

to use the highest HAP content resin.— 

At the recommendation of the SBAR Panel, we also 

reexamined the floors for tooling resins. Several of the 

small entity representatives that advised the panel stated 

that the proposed floor for tooling resins will result in 

inferior quality tools. We believe that the current floor 

for tooling resins allows sufficient flexibility in resin 

HAP content as long as the resin can be applied with 

nonatomized spray technology. We are specifically 

soliciting comment on the applicability of nonatomized spray 
P.41 

39 

technology to tooling resins. Based on any comments, we 

intend to further examine the floor for tooling resins. 

F. How did we determine the MACT floor for new sources? 

In developing the floor for new sources, we developed 

two subcategories--sources with emissions of 100 tpy or 

above and sources with emissions below 100 tpy. Our reason 

for examining sources with emissions below 100 tpy 

separately is that such facilities are likely to have more 

difficulty maintaining and operating add-on controls than 

larger-emitting sources, and we are unsure of the 

performance of add-on controls at these facilities. 

Separating the data into large and small HAP-emitting 

sources for developing new source MACT floors was also one 

of the recommendations of the SBAR Panel. We request 

comments and supporting data on whether a 100-tpy threshold 

adequately addresses fundamental differences in the ability 

to maintain and operate add-on controls. 

In examining the facilities with emissions of 100 tpy 

or more, we found three facilities that control emissions 

from open molding and mixing by 95 percent overall. These 

facilities range in size from 100 tpy to 1,000 tpy of HAP 

emissions prior to the add-on control device. This level of 

control was chosen as the new source MACT floor for. open 

molding and mixing at facilities with 100 tpy or more of 

uncontrolled emissions. [COMMENT: Can anything be said 

about the representativeness of the three facilities? Do 
P.42 

40 

their products range in size, so that it's clear that add-on 

controls would be considered feasible across all facilities 

with emissions greater than 100 tpy? It would seem that 

"emissions characteristics" is not the only factor in 

judging whether controls are feasible throughout the current 

subcategory(ies).] 

We evaluated the applicability of the 95 percent 

control level as the new source floor for other operations. 

Centrifugal casting, continuous lamination/casting, 

pultrusion, and SMC manufacturing are similar in emissions 

characteristics to open molding. [COMMENT: See above 

comment. Why didn't EPA evaluate the controls in place for 

the best performer in each type of operation? Can EPA 

guarantee that add-on controls are feasible for all 

operations, regardless of product size or process?] For 

this reason, we chose 95 percent control as the new source 

MACT floor for these operations at facilities with 

uncontrolled emissions of at least 100 tpy. We request 

comments on our approach to setting the requirement for addon controls for all new operations with emissions greater 

than 100 tpy. 

We also considered whether the new source MACT floor 

for the previously mentioned operations should be 

incorporation of the pollution-prevention measures that make 

up the existing source floors, combined with 95 percent 

control. This approach would actually result in a higher 
P.43 

41 

overall emissions reduction. In addition, incorporating the 

pollution prevention measures would reduce the potential for 

worker exposure in situations where processes have to be 

enclosed to meet the 95 percent control requirement._ 

[COMMENT: How can this be an option if it doesn't represent 

the actual practices of the best performing facility?] 

However, we determined that selecting incorporation of 

pollution-prevention techniques in addition to the 95 

percent control requirement as the proposed new source floor 

was not appropriate because the facilities that incorporate 

95 percent control, which we determined represent the best 

controlled facilities, do not also incorporate the best 

pollution prevention techniques. Therefore, combining the 

pollution-prevention requirements with the 95 percent 

control requirements would actually result in an overall 

control level that exceeds the levels at the best controlled 

facilities. 

We are still considering whether the new source floor 

for facilities that must meet the 95 percent control 

requirements should also incorporate the pollutionprevention requirements, and request comment on this issue. 

We also request that commentors provide any available data 

on worker exposure that would help us quantify the worker 

exposure impacts of setting a 95 percent control (with 100 

percent capture) requirement as well as the costs and 

benefits of incorporating pollution-prevention requirements 
P.44 

42 

with thea 95 percent control requirements*.— 

We drdare not selecLproposinq 95 percent control for 

closed molding, polymer casting, equipment cleaning, and 

resin storage, which have much lower emissions than the 

other types of operations. One of the facilities that sets 

the new source floor has a closed molding operation on site. 

This operation is not controlled. We did identify other 

types of controls for these processes. For 

compression/injection molding, which is a type of closed 

molding, the only identified control was the work practice 

of uncovering one charge at a time. Therefore, this was 

chosen as the proposed new source MACT floor for this • 

operation. [COMMENT: Is "compression/injection molding", 

and its associated control option, representative of the 

other types of "closed molding" and feasible controls?] For 

polymer casting and resin transfer molding, we were not able 

to identify any applicable control techniques. Thus, the 

proposed new source MACT floor for these sources is no 

control. 

For equipment cleaning, the proposed new source floor 

is based on use of cleaners with no HAP. Of the 433 

facilities that reported information on cleaning, 353 

reported using no cleaning materials containing HAP. 

However, we are not regulating solvents used for cleaning 

cured resin or gel coat from application equipment because 

we know of nb HAP emission controls. Cured resin or gel 
P.45 

43 

coat inside a gun is usually the result of operator error or 

an equipment failure. To clean cured resin and gel coat, an 

aggressive solvent is needed, and no low-HAP alternatives 

are available. The equipment is usually soaked in a covered 

bucket resulting in little evaporation of the solvent. The 

amount of solvent needed per year is determined by the size 

of the facility, degree of operator error, and equipment 

failure rates. Because operator error and equipment failure 

are hard to predict, we could determine no basis for an 

annual limit of solvent usage that would be achievable by 

all facilities. These proposed NESHAP, therefore, allow 

HAP-containing solvents only for cleaning cured resin and 

gel coat from the application equipment. 

Over 250 facilities reported covering storage 

containers. We selected covering storage containers as the 

new source MACT floor for storage. We identified two 

facilities that vent the storage areas to a control device; 

however, we determined that the available data are • 

insufficient to quantify additional emissions reductions 

that would result from controlling storage tanks and 

containers by 95 percent versus just covering the storage 

tanks and containers. 

We calculated separate floors for facilities with less 

than 100 tpy of emissions from open molding, centrifugal 

casting continuous lamination/casting, pultrusion, SMC 

manufacturing, and BMC manufacturing/mixing. Though there 
P.46 

44 

are facilities with emissions below 100 tpy that have add-on 

controls, data were not available to substantiate their 

level of control. Therefore, we could not state that they 

achieved a level of control above that achieved by the 

pollution-prevention techniques, and thus, meet the 

definition of best controlled facilities. Also, smalleremitting facilities tend to operate with fewer shifts than 

larger ones. The more frequent startups and shutdowns could 

tend to make .it more difficult to maintain and operate addon controls compared to larger-emitting facilities. For 

these reasons, the floor for new sources with less than 100 

tpy of emissions is based on pollution-prevention 

techniques. 

For these smaller-emitting facilities, we are 

seLLinqproposinq to set the new source MACT floor at the 

same level as the existing source MACT floor. This approach 

was recommended by the SBAR Panel. We believe the existing 

source MACT floor represents the greatest degree of 

emissions reduction that is achievable for small facilities 

under all circumstances. For new sources, the CAA requires 

the MACT floor to be based on the HAP emissions control 

achieved in practice by the best controlled similar source, 

as determined by the Administrator. The reinforced plastic 

composites industry is extraordinarily diverse. The 

products produced, even in the same operation, can include 

skylights, bathtubs, and parts for automobiles. Given this 
P.47 

45 

diversity, it is difficult to identify the "best controlled" 

source. Products manufactured by this industry generally 

must meet certain minimal strength and durability 

requirements. The HAP content of the resin is a factor in 

meeting such requirements. Use of a resin with a given HAP 

content may be the most stringent level of control possible 

for a particular process, while it may be possible to use a 

lower-HAP resin in a different process without jeopardizing 

the strength or durability of the product. 

While some facilities are using lower-HAP materials and 

techniques than represented by the existing source MACT 

floor, we do not believe that these examples are universally 

applicable to all new reinforced plastic composites 

manufacturers. We have no data to precisely define the 

particular combination of requirements where these loweremitting options can be used and still maintain the minimum 

required strength and durability requirements of these 

products. Consequently, we have set the proposed floor at 

the most stringent level that we have determined all sources 

emitting less than 100 tpy can achieve. We request comments 

on our rationale for establishing a 100-tpy threshold as 

opposed to other levels (e.g., 250 tpy). 

We did not find that the quantity of HAP emissions from 

the source had any effect on its ability to incorporate 

pollution-prevention technology, or on the effectiveness of 

these technologies. For that reason, we did not subdivide 
P.48 

46 

the data for existing sources where the floors are based 

mainly on pollution prevention. 

During the SBAR Panel discussions, many of the small 

entity representatives expressed concern regarding the 

affordability and technical feasibility of add-on controls, 

and commented that they may be able to achieve similar HAP 

reductions using pollution-prevention measures, which tend 

to be less expensive. For example, if a facility could 

reduce its emissions by 50 percent each year for 3 years 

using the pollution-prevention alternative, it may be able 

to achieve reductions similar to thermal oxidation (nearly 

90 percent versus 95 percent). The panel recommended that 

EPA explore with industry the possibility of a more 

stringent pollution-prevention option as an alternative to 

add-on controls. The panel believed that this option should 

be more stringent than the pollution-prevention technology 

present in the current existing source MACT floors. 

We discussed with industry the possibility of a 

pollution-prevention control option in lieu of add-on 

controls. We were unable to develop an option that we 

believe meets the statutory requirements of MACT. However, 

we are soliciting comment on a possible pollution-prevention 

alternative to the 95 percent HAP reduction requirement. 

The specific information we are seeking is the maximum level 

of control that can be achieved by pollution prevention, and 

the time necessary to incorporate pollution-prevention 
P.49 

47 

techniques. The pollution-prevention techniques of which we 

are aware include low HAP resins and gel coats, nonatomized 

resin and gel coat applications, vapor suppressed resins, 

vacuum bagging, accelerated resin curing, and conversion of 

open molding processes to closed molding. We are soliciting 

information on other pollution-prevention techniques of 

which we are not aware, and information on the maximum level 

of emissions reductions achievable by these techniques. 

The general concept of an alternative would be a 

facility that elects to use this option to submit 

notification to the appropriate permitting authority of 

their intent. The facility would then have to submit a plan 

to meet specific emissions reductions through pollution 

prevention. The plan would outline the techniques they 

intend to use, the research and testing required, .and a 

schedule with annual milestones for achieving the goal. 

In the next step, the facility would calculate an 

overall emission factor for all processes at the facility 

that are required to meet the 95 percent emission reduction.. 

Once a facility has determined a base year emission 

factor, they would be required to incorporate the pollutionprevention techniques outlined in the plan and make annual 

reports of progress. If a facility was unable to meet an 

interim milestone, they would be required to provide an 

updated plan within a specified time. 

We are also soliciting comment on determination of a 
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48 

base year and baseline emission factor, and reporting 

requirements. 

G. Did we consider control options more stringent than the 

MACT floor? 

For existing sources, an above-the-floor control level 

was evaluated which was based on the new source floor for 

sources with emissions of 100 tpy or more. This above-thefloor control level would require 95 percent control of HAP 

emissions from all open molding, centrifugal casting, 

continuous lamination/casting, pultrusion, SMC 

manufacturing, and resin mixing/BMC manufacturing._ 

[COMMENT: As mentioned previously, please clarify how EPA 

is confident that each of these processes, and that all 

product sizes, are represented by a source that can meet a 

100% capture/95% control requirement.] 

We then looked at several options. These were 

selecting the'floor level of control as MACT for all 

facilities, selecting the above-the-floor level as MACT for 

all facilities, or choosing an alternative where facilities 

at or above a certain HAP emissions quantity would meet the 

above-the-floor level, and the rest would meet the floor. 

In looking at this third alternative, we also evaluated 

different HAP emission thresholds. 

The option of having all facilities meet the above-thefloor level of control had a reasonablean incremental cost 

effectiveness of $XX,XXX per ton of HAP, which we consider 
P.51 

49 

reasonable. However, when we performed the economic 

analysis for this option, 126 small businesses would be 

impacted at a level of 3 percent of sales or more, and there 

were 90 projected closures of small businesses. We believe 

that the benefit of controlling all existing sources to this 

level is not commensurate with the economic impacts. 

Therefore, we didare not chooseproposinq this alternative as 

MACT. 

We then looked at a combination of the MACT floor for 

facilities below a specified HAP emissions quantity based on 

uncontrolled emissions, and the above-the-floor level of 

control for larger-emitting facilities. We also examined 

the impacts from the standpoint of small businesses and 

their ability to obtain the capital to purchase pollution 

control equipment. We believe that the capital costs of the 

above-the-floor option for most small businesses would be 

prohibitive because they do not have the same access to 

capital as large businesses. The available data indicate 

that at a threshold of 250 tpy, none of the existing small 

businesses in the data base would be impacted significantly 

by the above-the-floor control level. For this reason, we 

determined MACT for small businesses to be the floor for 

facilities that emit less than 250 tpy of HAP, and the 

above-the-floor control level for facilities that emit 250 

tpy or more. For large businesses, we determined MACT to be 

the floor for facilities that emit less than 100 tpy of HAP, 
P.52 

50 

and the above-the-floor control level for facilities that 

emit 100 tpy or more of HAP. The incorporation of thxs 

differenLe 250 tpy threshold f or small btrsmsHsss and leu.ye 

businesses was one of the recommendations of the SBAR Panel, 

and the economic impacts of the selected option are 

reasonable. 

We specifically request comment on these assumptions and 

our conclusion, including the impacts of the rule for large 

businesses with emissions between 100 tpy and 250 tpy. 

'_ In setting requirements that are more stringent than 

the MACT floor, the statute allows the consideration of the 

cost of achieving the emissions reductions, anv nonair 

quality health and environmental impacts, and energy 

requirements. We often use "cost effectiveness" to evaluate 

the merits of more stringent requirements. We request 

comments and supporting data on other measures of the "costs 

of achieving the emissions reductions" that could affect our 

decision, as well as on the other factors mentioned above. 

.We also request comments with supporting data on any 

unanticipated consequences of requiring 100 percent capture 

and 95 percent control of emissions as an above-the-floor 

requirement, including interactions with OSHA regulations. 

Industry representatives independently developed costs 

for add-on controls and submitted them to the Agency. Their 

analysis is in the docket for this proposed rulemaking. The 

SBAR Panel recommended that we reconsider our estimates of 
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51 

costs for add-on controls in light of that study. The 

industry cost estimates are at least three times higher than 

our cost estimates. [COMMENT: Can EPA provide the actual 

cost figures?] The major reason for these differences in 

cost are the design assumptions for the permanent total 

enclosures and the estimated air flows. Our cost estimates 

assume an inlet concentration of 100 parts per million by 

volume (ppmv). The industry study assumes lower 

concentrations that vary based on the specific facility. 

However, available test data for measured concentrations in 

the exhaust streams for reinforced plastic composites 

facilities range from 61 to 249 ppmv. [COMMENT: Please 

provide more information with which to judge whether 100 

ppmv is reasonable — not just that it falls between 61 and 

249? For example, what is the average concentration, 

weighted by the number of sources that emit such 

concentrations? If most sources are closer to 61 ppmv, CFA 

may have a stronger point.] Based on this, we believe our 

100 ppmv estimate is still reasonable, and we have decided 

not to revise our cost at this time. We do intend to review 

the industry's cost analysis in more depth following 

proposal, and make any appropriate changes based on comments 

we receive. We are soliciting comment on the cost and 

feasibility of add-on controls, information on design and 

operation of permanent total enclosures from this or similar 

industries, and information on typical exhaust 
P.54 

52 

concentrations for reinforced plastic composite facilities. 

We did not identify an above-the-floor option for the 

following operations: closed molding, polymer casting, and 

equipment cleaning. We were able to find no examples where 

any closed molding process was controlled using add-on 

controls. Therefore, we believe it is not technically and 

economically feasible to use add-on controls for closed 

molding processes. We do not believe it is technically 

feasible to use add-on controls for equipment cleaning 

operations. In any case, application of the floor level of 

control we are proposing would eliminate HAP-containing 

cleaners, except for cases where cured resin has to be 

removed from application equipment. This floor level of 

control would achieve close to 100 percent HAP emissions 

reductions. 

For new sources, we examined an above-the-floor option 

of requiring all sources to meet the 95 percent,control 

requirement for open molding, centrifugal casting, 

continuous lamination/casting, pultrusion, SMC 

manufacturing, and resin mixing/BMC manufacturing. We 

determined that, even if we could resolve the issues 

surrounding the performance of add-on control devices at the 

smaller-emitting sources, the incremental cost effectiveness 

of this option would be unreasonable. [COMMENT: Please 

provide cost effectiveness figures, to give a sense of what 

was judged as "unreasonable".] For this reason, we chose 
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53 

the floor level of control as MACT for riew sources. 

We also considered an above-the-floor control level for 

both existing and new sources of combining the pollutionprevention techniques of the existing source floors with a 

95 percent control requirement. As previously discussed, 

the benefits of this approach would be that by incorporating 

the pollution-prevention measures, the overall emission 

reduction would be increased. In addition, the potential 

for worker exposure in these situations would be reduced. 

However, we determined the incremental emission reduction 

for this control level was approximately 2 percent of 

baseline. Based on the costs of meeting existing source 

floors, the cost effectiveness of this small additional 

benefit would be unreasonable, even though there may be 

worker exposure benefits. [COMMENT: Please provide cost 

effectiveness figures, to give a sense of what was judged as 

"unreasonable".] Therefore we did not include this abovethe-floor control level in this proposed rule. This 

possibility is still under consideration and we are are 

requesting comment. We also request that commentors provide 

any available data on worker exposure that would allow us to 

quantify the additional worker exposure benefits of 

incorporating pollution-prevention requirements with the 95 

percent control requirements. 

We did not identify an above-the-floor option for new 

sources for the following operations: closed molding, 
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54 

polymer casting, and equipment cleaning for the same reasons 

as discussed above for existing sources. 

We also examined an above-the-floor control option for 

existing sources based on pollution prevention. As was the 

case with the new source MACT floor, we are unable at this 

time to develop an alternative that we believe meets the 

statutory requirements of MACT. However, we are 

specifically soliciting comments on pollution-prevention 

techniques that could be used in lieu of the above-the-floor 

alternative as were discussed in the section on new source 

floors. 

H. Why are some reinforced plastic composites production 

operations not subject to these proposed NESHAP? 

These proposed NESHAP would not regulate mold sealing 

and release agents and mold stripping and cleaning solvents 

because we were unable to set MACT floors or determine MACT 

for these operations. In both cases, the information and 

data available to us suggest that mold maintenance 

practices, part shape and size, and production schedules 

determine emissions more than the HAP content of these 

materials. We do not have sufficient data to identify and 

prescribe work practices to reduce emissions from these 

operations. Therefore, these proposed NESHAP do not require 

controls for these materials. 

For mold stripping and cleaning solvents, the amount of 

HAP used per unit of mold surface area applied depends on 
P.57 

55 

facility-specific mold maintenance practices and production 

requirements. These may include mold cycle time, how often 

the mold is used, and whether the mold is stored indoors or 

outdoors. The size of the part may also influence mold 

maintenance. We do not have sufficient data to identify 

those differences in production requirements or work 

practices that determine mold cleaning solvent usage. 

Therefore, we cannot identify a MACT floor or MACT. 

I. How did we select the form of these proposed NESHAP? 

We decided to offer several forms for complying with 

the proposed NESHAP. The purpose of multiple forms is to 

provide the flexibility to comply in the most cost-effective 

and efficient manner. We considered the following factors 

in selecting the form of the proposed NESHAP: 

• The form should allow for multiple compliance 

techniques for the various types of facilities in 

the industry. 

• The form should simplify compliance and ensure 

that the cost of compliance is not excessive. 

• The form should be enforceable. 

The form of these proposed NESHAP is based on a 

combination of emission limits (point values or percent 

reduction), equipment standards, and work practice 

standards. 

1. Emission Limits Based on Point Values 

These proposed NESHAP for open molding operations and 
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56 

centrifugal casting operations are based on point values 

which are in units of pounds of HAP per ton of resin used. 

The point value development has been previously described. 

This form was chosen over an absolute emission limit because 

it accurately determines the amount of pollution-prevention 

control a source has incorporated in its process, but does 

not require a facility to perform emission testing. This 

form also allows for averaging across open molding processes 

or across centrifugal casting processes. This means that a 

source has the option to over-control some operations, 

under-control others (relative to the limit for that 

individual process), but still meet the overall limit for 

such operations combined. This allows a source to have 

additional flexibility in meeting the proposed standards. 

The emission limits for open molding and centrifugal 

casting for new sources are based on a percent reduction 

using add-on controls. However, we have provided an 

alternative standard for new sources also based on point 

values. These point values were determined by applying the 

required percent reduction requirement to the existing 

source MACT floors. The new source floor is based on a 

control efficiency, and the facilities that have these 

controls do not have examples of every possible type of open 

molding or centrifugal casting process. Therefore, we were 

not able to use the best-controlled sources to directly 

determine a point value that is equivalent to the 95 percent 
P.59 

57 

emissions reductions requirement for all operations. For 

operations where we could directly determine a point value 

equivalent, the approach of using existing source floors and 

applying 95 percent control is slightly more stringent. 

Therefore, we believe applying this approach to all open 

molding and centrifugal casting operations will produce a 

limit that is no less stringent, while providing 

opportunities for facilities to incorporate pollution 

prevention into their process, meet a percent reduction 

requirement less than 95 percent, but still meet the new 

source floor. 

2. Emission Limits Based on Percent Reduction 

The form of the standards for new open molding, 

centrifugal casting, SMC manufacturing, and resin/mixing/BMC 

manufacturing, and the standards for new and existing 

sources for pultrusion and SMC manufacturing are based on a 

percent reduction. These standards were all developed from 

facilities using add-on controls. It is possible to design 

a control device to meet a specified percent reduction. 

[COMMENT: Can EPA demonstrate that add-on controls are 

currently used bv at least one source in each process 

category and for all product sizes, and that the level of 

control for these sources is 95% (with 100% capture)?] But 

based on the data available, it was not possible to 

determine an uncontrolled emission factor for open molding, 

centrifugal casting, SMC manufacturing, and mixing/BMC 
P.60 

58 

manufacturing that was generally applicable. Therefore, we 

could not develop a standard based on an emission factor. 

For continuous lamination/casting, we were able to develop 

an absolute emission limit based on the facilities that set 

the floor. These absolute emission limits are presented as 

alternatives to the percent reduction limits. In the case 

of pultrusion operations, there are alternative standards 

based on wet-area enclosures or direct die injection. 

Emission testing has determined that using this equipment as 

specified in the proposed rule will achieve the percent 

reductions specified in the NESHAP. 

3. Emission Limits Based on Equipment/Work Practice 

Standards 

Section 112(h) of the CAA states that ". . . if it is 

not feasible in the judgement of the Administrator to 

prescribe or enforce an emission standard for control of a 

hazardous air pollutant or pollutants, the Administrator 

may, in lieu thereof, promulgate a design, equipment, work 

practice, or operational standard, or combination thereof . 

. .." Section 112(h)(2) further defines the phrase "not 

feasible to prescribe or enforce an emission standard" as 

any situation in which ". . . a hazardous air pollutant or 

pollutants cannot be emitted through a conveyance designed 

and constructed to emit or capture such pollutant, .. . or 

the application of measurement methodology to a particular 

class of sources is not practicable due to technological and 
P.61 

59 

economic limitations." We request comments on whether this 

situation could arise for sources we propose to include 

under the requirement to achieve 100 percent capture and 95 

percent control. 

The emission limits for equipment cleaning and storage 

at new and existing sources are based on work practice and 

equipment standards. The reason for choosing work practice 

and equipment standards for storage is that storage areas 

may be located outside the rest of the production area, and 

in some cases, may be located outside the building. We do 

not believe it would be practicable due to economic 

limitations to test storage areas, and we do not have 

sufficient data to calculate an emission limit for the 

required work practice. 

The standard for existing pultrusion facilities is 

based on the equipment standard combined with a work 

practice. We have proposed the standard as a percent 

reduction to allow the use of add-on controls. However, we 

do not believe it would be technologically or economically 

feasible to actually test facilities that choose to use a 

wet-area enclosure or direct die injection. 

The limits for SMC and resin mixing/BMC at existing 

facilities are also based on work practices or equipment 

standards. We have no data to determine a specific percent 

reduction to the work practices for these operations. 

Therefore, we could not set a specific emission limit. 
P.62 

60 

Cleaning operations may take place outside the regular 

production area. It would not be technologically or 

economically practicable to perform emission testing for 

cleaning operations. 

4. Selection of Averaging Time for Demonstrating Compliance 

As a reinforced plastic composites manufacturer, we are 

proposing that you would show compliance with the proposed 

NESHAP on a 12-month, rolling-average basis. YUnder the 

proposal, you would determine compliance at the end of each 

month from the data collected over the past 12 months. A 

12-month averaging time provides a balance between operating 

flexibility and enforceability of the proposed standards. 

TWe believe the 12-month period is sufficiently long so that 

you can identify potential compliance problems and change 

your operations in time to maintain compliance. The 

rolling-average aspect provides an enforceable emission 

limit 12 times per year. 

Many reinforced plastic composites manufacturers 

already track material usage monthly to comply with State 

regulations and permit requirements, so we believe monthly 

tracking is consistent with current practice. Tracking on a 

more frequent basis would be unnecessarily burdensome for 

this particular industry. Reinforced plastic composites 

manufacturers need a 12-month rolling-average period to 

respond to both short-term variations in HAP content that 

are inherent in all chemical products, and to account for 
P.63 

61 

short-term needs for higher-HAP materials due to variations 

in product mix. We welcome comments on these assumptions. 

J. How did we select the test methods for determining 

compliance with the proposed NESHAP? 

The proposed NESHAP have several options for achieving 

compliance. For open molding and centrifugal casting, this 

includes meeting a specified point value for existing 

sources, or a percent reduction or point value for new 

sources. For most other processes, you achieve compliance 

by using an enclosure and add-on control device to meet a 

percent reduction requirement or an absolute emission limit. 

In order to calculate a point value under the proposal, 

you must determine the HAP content of the raw material. The 

method to determine material HAP content is the use of the 

Material Safety Data Sheets (MSDS) or other product 

specification sheets provided by the material manufacturer. 

We chose not to requirepropose requiring testing of the 

material. The data.used to develop the standards were 

mainly based on MSDS; therefore, we believe it is reasonable 

that MSDS be used to determine compliance. 

Under the proposed NESHAP, if you chose to use an 

enclosure and add-on control device, you would have to 

determine the capture efficiency of the enclosure and 

measure the HAP from the control device. To determine the 

capture efficiency of the enclosure, you would use EPA 

Method 204 (Criteria for and Verification of Permanent or 
P.64 

62 

Temporary Total Enclosure). If the enclosure meets the 

criteria in EPA Method 2 04 for a permanent total enclosure, 

then you could assume that its capture efficiency is 100 

percent. If the enclosure is not a total enclosure, then 

you would build a total temporary enclosure around it that 

meets the definition of a total temporary enclosure in EPA 

Method 204. You would then have to measure emissions from 

both the control device and the total temporary enclosure 

and use the combined emissions to determine compliance. We 

request comments and supporting data on the feasibility of 

100 percent capture and 95 percent control for specific 

processes and product types. We also request comments on 

whether such requirements would conflict with other 

applicable regulations. 

To measure HAP, you would be able to use either EPA 

Method 18 (Measurement of Gaseous Organic Compound Emissions 

by Gas Chromatography) to measure the sum of individual 

species of HAP, or EPA Method 25A (Determination of Total 

Gaseous Organic Matter Concentration Using a Flame 

Ionization Analyzer) for total hydrocarbons (THC) as a 

surrogate for total HAP. The EPA Method 25A would allow you 

the flexibility to use a simpler method than EPA Method 18 

which does not speciate HAP in cases where measuring THC is 

sufficient to demonstrate compliance. You could measure THC 

as a surrogate for total HAP if most of the THC emitted from 

an enclosure were HAP, such as styrene and MMA from resin 
P.65 

63 

and gel coat operations. For compliance determinations, the 

EPA will assume that all THC measured with EPA Method 25A 

are HAP. 

We have not included in this proposed rule a test 

method for determining the effectiveness of vapor suppressed 

resins. A draft protocol entitled "Vapor Suppressant 

Effectiveness Test Protocol," dated April 7, 1999, has been 

developed by industry and is available for review in the 

docket for this proposed rule. The draft protocol is 

insufficiently detailed for inclusion in this proposed rule. 

We are currently requesting additional details and 

soliciting comment on the test protocol or an alternate test 

protocol. 

K. How did we determine the monitoring and recordkeeping 

requirements? 

Which monitoring and recordkeeping requirements you 

would meet depend on how you choose to comply with these 

proposed NESHAP. For each compliance option, the proposed 

monitoring and recordkeeping requirements are the minimum 

necessary to determine initial and ongoing compliance and 

are consistent with the General Provisions (40 CFR part 63, 

subpart A) . 

This section describes how to comply with emission 

limits based on point values, emission averaging provisions, 

equipment and work practice standards, and the emission 

limit for an add-on control device. 
P.66 

64 

1. Compliance with Emission Limits Based on Point Values 

For all operations subject to HAP content limits, we 

are proposing four tasks: monitor and record the HAP 

content of the material used, monitor and record the monthly 

consumption of the material, monitor and record which 

operations use the material, and record the computations to 

show that the weighted average point value over the past 12 

months meets the proposed standards. 

The SBAR Panel recommended that we look for 

alternatives to simplify reporting and recordkeeping. We 

have identified two alternatives we believe simplify the 

reporting and recordkeeping process. The first is that an 

owner and operator may use purchase records to determine, 

monthly consumption. However, an owner and operator can 

track actual material flows to each process if desired. We 

believe this is reasonable because facilities have no 

financial incentive to keep significant inventories of raw 

material on hand, and we have no evidence that keeping large 

amounts of raw material on hand is a common practice. 

Therefore, purchases and actual consumption should track 

fairly closely. We are requiring that the owner and 

operator have a reasonable method to estimate the amounts of 

each resin used by a specific operation. The second 

alternative applies where all the materials used in an 

operation result in a point value that meets the emission 

limit, in which case, an owner and operator only need to 
65 

record HAP content and the resulting point value and do not 

need to track monthly consumption of each individual 

material. 

2. Compliance with Averaging Provisions 

To comply with the averaging provisions for open 

molding operations and centrifugal casting operations, you 

must monitor and record HAP content as well as how use of 

the material is split between different operations, and you 

must record the computations needed to show compliance. You 

must use these data as well as the MACT model point value 

equations in the proposed NESHAP to calculate the point 

values in that operation for the past 12 months. Compliance 

is then determined relative to the allowable weighted 

average point value calculated for those operations for the 

past 12 months. [COMMENT: Would facilities have to 

continually monitor changes in materials and processes -- in 

effect houriv, daily computations? Or does EPA envision 

facilities taking account of their operations once a month?] 

3. Compliance with Equipment and Work Practice Standards 

The proposed NESHAP require resin and gel coat mixing 

containers to be fitted with covers that have no visible 

gaps. You will be required to inspect container covers each 

month to ensure the covers are in place and properly 

maintained. You must record the results of the inspections. 

The inspections should be sufficient to ensure that the 

covers are in place and properly maintained. MWe believe 
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66 

monthly inspections are a reasonable interval because the 

nature of failure in these pieces of equipment is likely due 

to wear and tear and not a sudden failure. Longer time 

periods between inspections, however, would allow a failure 

to go too long before being repaired. We request comments 

on these assumptions. 

The proposed NESHAP for production resin and tooling 

resin requires most manufacturers to use nonatomized resin 

application methods to comply. These methods include 

flowcoaters and pressure-fed resin rollers, among others. 

We could identify no parameters to monitor whether these 

methods are being used. Rather, compliance through the use 

of these methods would be determined during enforcement 

inspections. As long as flowcoaters, pressure-fed resin 

rollers, or other similar devices are installed and operated 

according to manufacturer's specifications, they will comply 

with the requirements to use nonatomized resin application 

methods. 

4. Compliance for Sources Using Enclosures and Add-On 

Control Devices 

The requirements for enclosures and add-on control 

devices in the proposed NESHAP are consistent with other air 

quality regulations that require capture and control of 

emissions. They are the minimum needed to demonstrate that 

the capture and control system is operated properly. 

¥We are proposing that you must initially demonstrate 
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67 

compliance with the emission limit by demonstrating that the 

enclosure is a total enclosure or by also measuring the 

fugitive emissions that escape the enclosure. You mustwould 

also need to measure the efficiency of the add-on control 

using EPA Method 2 5A for THC (as a surrogate for HAP) or EPA 

Method 18 for HAP. The EPA Method 18 measures individual 

HAP that you sum to calculate total HAP. 

After the initial compliance test, we are proposing 

that you must monitor control device parameters to 

demonstrate that the control device continues to be operated 

as it was during the initial test. In the case of thermal 

oxidizers, you mrrs-trwould need to monitor and record 

combustion temperature every 15 minutes both during and 

after the performance test. YWe are proposing that you must 

calculate the average temperature achieved during the test. 

After the test, you mustwould need to maintain the average 

temperature at or above the temperature achieved during the 

performance test. Temperature monitors and recorders are 

standard features on thermal oxidizers. For other devices, 

we are proposing that you must determine appropriate 

parameters to monitor and receive our approval to use these 

parameters. 

We welcome comments on these requirements. 

L. How did we select the notification and reporting 

requirements? 

TWe believe that the requiredproposed notices and 
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68 

reports are the minimum needed to determine if you are 

subject to the proposed NESHAP and whether you are in 

compliance. ¥We are proposing that you must submit an 

initial notification stating that you are subject to the 

proposed NESHAP. After the compliance date for your 

facility, you mustwould need to submit a notification of 

your compliance status. You mustwould also need to submit 

semiannual reports of your.compliance status. If you have 

an add-on control device and you become out of compliance, 

we are proposing that you must submit quarterly reports of 

your compliance status until we approve a request to return 

to semiannual reporting. 

If your facility is a new source, we are proposing that 

you will have additional preconstruction notification 

requirements. You willwould also have additional 

notification and reporting requirements if you use an add-on 

control device, including notifications and reports for the 

control device performance test. These proposed 

notification and reporting requirements are consistent with 

those specified in the General Provisions__ andWe believe 

that these requirements are the minimum needed for us to 

determine compliance for sources with add-on control 

devices. 

The SSM plan specified by the General Provisions will 

be required only for sources using an add-on control device 

and will apply only to the add-on control device. For 
P.71 

69 

operations not using a control device, the nature of the 

materials and equipment used to comply with the proposed 

Reinforced Plastic Composites Production NESHAP is such that 

malfunctions will not lead to excess emissions. 

We request comments on our need for this information, 

the burden of the requirements, and any suggested methods 

for minimizing respondent burden. 

IV. Summary of Environmental, Energy, and Economic Impacts 

A. What facilities are affected by the proposed NESHAP? 

There are approximately 433 existing facilities 

manufacturing reinforced plastic composites that are major 

sources and would be subject to the proposed NESHAP. The 

rate of growth for the reinforced plastic composites 

industry is estimated to be 84 new facilities over the next 

5 years. 

B. What are the air quality impacts? 

The 1997 baseline HAP emissions from the reinforced 

plastic composites industry are approximately 22,200 tpy. 

The proposed NESHAP would reduce HAP from existing sources 

by 14,500 tpy, a reduction of 65 percent. 

The proposed NESHAP willwould result in small increases 

in other air pollution emissions from combustion devices 

that will be installed in the next 5 years to comply with 

today's proposed rule. These increases result from both the 

combustion device directly, and estimated emissions that 

occur at electrical generating plants to generate the 
P.72 

70 

electricity necessary to operate the add-on controls and 

associated air handling equipment. These emissions are 

estimated to be 38 tpy of sulfur oxides (SOx), 69 tpy of 

nitrogen oxides (NOx), 125 tpy of carbon monoxide (CO), and 

1.5 tpy of particulate matter (PM) emissions. 

C. What are the water quality impacts?— 

We estimate that the proposed Reinforced Plastic 

Composites Production NESHAP will have no adverse water 

quality impacts. We do not expect anyone to comply by using 

add-on control devices or process modifications that would 

generate wastewater. 

D. What are the solid and hazardous waste impacts? 

We estimate that the proposed NESHAP willwould decrease 

the amount of solid waste generated by the reinforced 

plastic composites industry by approximately 1,400 tpy. The 

decrease in solid waste is directly related to switching to 

nonatomized resin application equipment (i.e., flowcoaters 

and resin rollers). Switching to flowcoaters results in a 

decrease in overspray because of a greater transfer 

efficiency of resin from flowcoaters to the part being 

manufactured. A decrease in resin overspray consequently 

reduces the amount of waste from disposable floor coverings, 

cured resin waste, and personal protective equipment (PPE) 

for workers. Disposable floor coverings are replaced on a 

periodic basis to prevent resin buildup on the floor. We 

estimate that solid waste generation of floor coverings will 
P.73 

71 

decrease by approximately 3 60 tpy and that cured resin solid 

waste will decrease by approximately 1,040 tpy. 

DWe proiect that the decreased overspray from 

flowcoaters will result in a decreased usage of PPE, which 

also consequently reduces the amount of solid waste. 

Workers who use flowcoaters typically wear less PPE than 

when using spray guns because of the reduced presence of 

resin aerosols and lower styrene levels in the workplace. 

Because we did not have information on the many different 

types of PPE currently used, we did not estimate this 

decrease in solid waste. 

Some facilities that switch from spray guns to 

flowcoaters may have a small increase of hazardous waste 

from the used flowcoater cleaning solvents. However, most 

facilities willwould not see an increase under the proposal, 

and the overall impact on the industry will be small 

relative to the solid waste reductions. Nearly all 

flowcoaters require resin and catalyst to be mixed inside 

the gun (internal-mix) and must be flushed when work is 

stopped for more than a few minutes. External-mix spray 

guns do not need to be flushed because resin is mixed with 

catalyst outside the gun. Facilities that switch from 

external-mix spray guns to flowcoaters will use more 

solvent. Solvent usage should not change at facilities 

switching from internal-mix spray guns to flowcoaters. The 

most common flushing solvents are acetone and water-based 
P.74 

72 

emulsifiers. Only a couple of ounces of solvent are 

typically needed to flush the mixing chamber and nozzle of 

flowcoaters and internal-mix spray guns. 

We do not have adequate data to predict the potential 

solvent waste impact from switching to flowcoaters. The 

magnitude of the impact depends on the type of gun currently 

used (internal- or external-mix), the frequency of flushing, 

and the type of solvent used. However, because of the small 

amount of solvent used, and since most is allowed to 

evaporate, we believe the overall solvent waste increase 

will be small compared to the solid waste reductions. 

E. What are the energy impacts? 

We have determined that the overall energy demand for 

operations in the Reinforced Plastic Composites Production 

source category willcould increase by 159 million standard 

cubic feet per year of natural gas, and 10 million kilowatt 

hours of electricity per year as a result of the proposed 

rule. We determined this net increase based on the 

additional energy demand for control devices installed to 

meet the proposed standards. No information for comparison 

is available on the baseline energy consumption for this 

source category. 

F. What are the cost impacts? 

We have deLeiminedestimated the capital costs for 

emission control equipment, including equipment such as open 

container covers, resin bath enclosures, capture systems, 
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and control devices as $73.9 million for existing sources 

and $11.7 million for new sources. The capital costs 

include the costs to purchase and install the control 

equipment. 

We have deteriviinedestimated that annual costs of the 

proposed rule are $26.0 million per year for existing 

sources and $3.2 million for new sources. Annual costs 

include fixed annual costs, such as reporting, recordkeeping 

and capital amortization, and variable annual costs such as 

natural gas. G. What are the economic impacts? 

The Agency conducted a detailed economic impact 

analysis to determine the market- and industry-level impacts 

associated with the proposed rule. We expect the aggregate 

price increase for reinforced plastic composites would be 

only 0.3 percent, or $0.01 per pound, as a result of the 

proposed standards. BWe proiect that directly affected 

producers would reduce total production by 0.8 percent, 

while unaffected producers not directly affected would 

increase their production by 0.3 percent. Markets for 

reinforced plastic composites used in general construction, 

corrosion-resistant products, and land transportation are 

expected to be more heavily impacted with price increases of 

up to 0.5 percent and reductions in directly affected 

domestic production of between 1 and 1.5 percent. 

In terms of industry impacts, captive producers of 
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reinforced plastic composites are expected to fully absorb 

their compliance costs, while merchant producers will 

attempt to pass through costs to their customers. Through 

the market impacts described above, the proposed NESHAP 

create both gainers and losers within the merchant segment. 

Some merchant facilities are projected to experience profit 

increases with the proposed rule; however, the majority that 

continue operating are projected to lose profits. 

Furthermore, the economic impact analysis indicates that 29 

out of 299 merchant facilities (9.7 percent) and 73 out of 

471 product lines (15.5 percent) at these facilities are at 

risk of closure because of the proposed NESHAP. [COMMENT: 

What are the sizes of these facilities?] We specifically 

request comments on whether such impacts can be minimized, 

while adhering to statutory requirements to achieve MACT. 

Based on the market analysis, the annual social costs 

of the proposed rule are projected to be $25.7 million. 

These costs are distributed across the many consumers and 

producers of reinforced plastic composites. Producers, in 

aggregate, are expected to bear $10.6 million annually in 

costs, with those directly affected by the proposed NESHAP 

losing $19.3 million and those not subject to the proposed 

NESHAP gaining $8.7 million. The consumers of reinforced 

plastic composites are expected to incur the remaining $15.1 
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million in costs associated with the proposed NESHAP. For 

more information, consult the docket for this project. We 

request comments on our data, assumptions, and findings, 

particularly where alternative assumptions mav affect our 

assessment of above-the-floor MACT requirements. 

V. Relationship of Proposed NESHAP to Other Standards and 

Programs under the CAA 

A. National Emission Standards for Closed Vent Systems, 

Control Devices, Recovery Devices, and Routing to a Fuel Gas 

System or a Process (40 CFR Part 63, Subpart SS) 

If you use an add-on control device(s) to control 

emissions, you will need to comply with certain provisions 

in 40 CFR part 63, subpart SS, for add-on controls. The 

standards in subpart SS cited by the proposed NESHAP are 

applicable to most sources using an add-on control device. 

The proposed NESHAP cite these sections in subpart SS rather 

than repeating them in the proposed regulatory text. 

B. Operating Permit Program 

Under the operating permit program codified at 40 CFR 

parts 7 0 and 71, all major sources subject to standards 

under section 111 or 112 of the CAA must obtain an operating 

permit (See §§70.3(a)(1) and 71.3(a)(1)). Therefore, all 

major sources subject to these proposed NESHAP must obtain 

an operating permit. 

Some reinforced plastic composites production 

facilities may be major sources based solely on their 
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76 

potential to emit even though their actual emissions are 

below the major source level. These facilities may choose 

to obtain a federally enforceable limit on their potential 

to emit so that they are no longer considered major sources 

subject to the proposed NESHAP. Sources that opt to limit 

their potential to emit (e.g., limits on operating hours or 

amount of material used) are referred to by the EPA as 

"synthetic area" sources. To become a synthetic area 

source, you must contact your local permitting authority to 

obtain an operating permit with the appropriate operating 

limits. These operating limits will then be federally 

enforceable under 40 CFR 70.6(b). 

C. NESHAP for Plastic Parts and Products 

There are currently NESHAP under development for 

proposal that will regulate coating of plastic parts and 

products. The SBAR Panel recommended that we consider the 

interaction of the Plastic Parts and Product NESHAP with 

today's proposed NESHAP. The Plastic Parts and Products 

NESHAP may potentially affect facilities that produce 

reinforced plastic parts and then apply a coating to the 

finished parts. We have coordinated with this project and 

have determined that there should be no overlap (i.e., 

specific operations covered by today's proposed NESHAP 

should not also be covered in the Plastic Parts and Products 

NESHAP). We have not determined any requirements of the 

proposed NESHAP that would overlap, conflict, or cause a 
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duplication of effort. 

VI. Administrative Requirements 

A. Executive Order 12866: Regulatory Planning and Review 

Under Executive Order 12866 (58 FR 51735, October 4, 

1993), we must determine whether a proposed regulatory 

action is "significant" and therefore subject to Office of 

Management and Budget (OMB) review and the requirements of 

the Executive Order. The Executive Order defines 

"significant regulatory action" as one that is likely to 

result in a rule that may: 

(1) Have an annual effect on the economy of $100 

million or more or adversely affect in a material way the 

economy, a sector of the economy, productivity, competition, 

jobs, the environment, public health or safety, or State, 

local, or tribal governments or communities; 

(2) Create a serious inconsistency or otherwise 

interfere with an action taken or planned by another agency; 

(3) Materially alter the budgetary impact of 

entitlements, grants, user fees, or loan programs or the 

rights and obligations of recipients thereof; or 

(4) Raise novel legal or policy issues arising out of 

legal mandates, the President's priorities, or the 

principles set forth in the Executive Order. 

Pursuant to the terms of Executive Order 12866, the EPA 

has submitted this action to OMB for review. Changes made 

in response to suggestions or recommendations from OMB will 
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be documented and included in the public record. 

B. Paperwork Reduction Act 

The information collection requirements in this 

proposed rule have been submitted for approval to the OMB 

under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. 

An ICR document has been prepared by EPA (ICR No. ) and a 

copy may be obtained from Sandy Farmer by mail at the Office 

of Environmental Information, Collection Strategies Division 

(2822), U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, 

DC 20460, by e-mail at "farmer.sandy@epa.gov," or by calling 

(202) 260-2740. A copy may also be downloaded from the 

internet at "http://www.epa.gov/icr." 

These proposed NESHAP contain monitoring, reporting, 

and recordkeeping requirements. -TWe believe the 

requiredproposed notices and reports are the minimum needed 

by us to determine who isif you are subject to the NESHAP 

and whether you are in compliance. TWe believe the proposed 

recordkeeping requirements are the minimum necessary to 

determine initial and ongoing compliance. Based on reported 

information, we would decide which reinforced plastic 

composites facilities and what records or processes should 

be inspected. The recordkeeping and reporting requirements 

are consistent with the General Provisions of 40 CFR part 

63. 

These proposed recordkeeping and reporting requirements 

are specifically authorized by section 114 of the CAA (42 
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79 

U.S.C. 7414). All information submitted to us for which a 

claim of confidentiality is made will be safeguarded 

according to our policies in 40 CFR part 2. 

The EPA expects these proposed NESHAP to affect a total 

of approximately 486 facilities over the first 3 years after 

promulgation of the rule. This includes 433 existing 

facilities, and 53 new reinforced plastic composites 

facilities will become subject to the proposed NESHAP during 

the first 3 years. 

The estimated average annual burden for the first 3 

years after promulgation of these proposed NESHAP for 

industry and the implementing agency is outlined below. You 

can find the details of this information collection in the 

"Standard Form 83 Supporting Statement for ICR No. 

in Docket No. A-94-52. 

Affected entityIndus tryImplementing agency Total hours 

15,122 

11,293 

Labor costs 

$673,120 

$450,972 

Total 

Annual 

O&M 

Costs 

$17,265 

NA 

Total 

costs 

$690,385 

$450,972 

Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, 

or disclose or provide information to or for a Federal 

agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, 

validating, and verifying information, processing and 
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80 

maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of 

information; search data sources; complete and review the 

collection of information; and transmit or otherwise 

disclose the information. 

An agency may not conduct or sponsor, and a person is 

not required to respond to a collection of information 

unless it displays a currently valid OMB control number. 

Control numbers for EPA's regulations.are listed in 40 CFR 

part 9 and 48 CFR chapter 15. 

Comments are requested on the Agency's need for this 

information, the accuracy of the provided burden estimates, 

and any suggested methods for minimizing respondent burden, 

including the use of automated collection techniques. Send 

comments on the ICR to the Director, Office of Environmental 

Information, Collection Strategies Division (2822), U.S. 

EPA, 1200 Pennsylvania Avenue NW, Washington, DC 20460; and 

to the Office of Information and Regulatory Affairs, OMB, 

725 17th Street, NW, Washington, DC 20503, marked 

"Attention: Desk Officer for EPA." Include the ICR number 

in any correspondence. Since OMB is required to make a 

decision concerning the ICR between 30 and 60 days after 

[INSERT DATE OF PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER], a comment to OMB is best assured of 
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having its full effect if OMB receives it by [INSERT DATE 30 

DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER]. • The final rule will respond to any OMB or public 

comments on the information collection requirements 

contained in this proposal. 

C. Executive Order 13132, Federalism 

Executive Order 13132, entitled "Federalism" (64 FR 

43255, August 10, 1999), requires EPA to develop an 

accountable process to ensure "meaningful and timely input 

by State and local officials in the development of 

regulatory policies that have federalism implications." 

"Policies that have federalism implications" is defined in 

the Executive Order to include regulations that have 

"substantial direct effects on the States, on the 

relationship between the national government and the States, 

or on the distribution of power and responsibilities among 

the various levels of government." 

This proposed rule does not have federalism 

implications. It will not have substantial direct effects 

on the States, on the relationship between the national 

government and the States, or on the distribution of power 

and responsibilities among the various levels of government, 

as specified in Executive Order 13132. No reinforced 

plastic composites production facilities subject to these 

proposed NESHAP are owned by State or local governments. 

Therefore, State and local governments will not have any 
P.84 

82 

direct compliance costs resulting from this proposed rule. 

Furthermore, these proposed NESHAP do not require these 

governments to take on any new responsibilities. Thus, the 

requirements of section 6 of the Executive Order do not 

apply to this proposed rule. Thus, Executive Order 13132 

does not apply to this rule. 

In the spirit of Executive Order 13132, and consistent 

with EPA policy to promote communications between EPA and 

State and local governments, EPA specifically solicits 

comment on this proposed rule from State and local 

officials. 

D. Executive Order 13 084, Consultation and Coordination 

with Indian Tribal Governments 

Under Executive Order 13 084, we may not issue a 

regulation that is not required by statute, that 

significantly or uniquely affects the communities of Indian 

tribal governments, and that imposes substantial direct 

compliance costs on those communities unless the Federal 

government provides the funds necessary to pay the direct 

compliance costs incurred by the tribal governments, or we 

consult with those governments. If we comply by consulting, 

we are required by Executive Order 13 084 to provide to the 

OMB in a separately identified section of the preamble to 

the rule, a description of the extent of our prior 

consultation with representatives of affected tribal 

governments, a summary of the nature of their concerns, and 
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83 

a statement supporting the need to issue the regulation. In 

addition, Executive Order 13084 requires us to develop an 

effective process permitting elected officials and other 

representatives of Indian tribal governments "to provide 

meaningful and timely input in the development of regulatory 

policies on matters that significantly or uniquely affect 

their communities." 

We are not aware of any Indian tribal governments or 

communities affected by the proposed rule. Accordingly, the 

requirements of section 3(b) of Executive Order 13084 do not 

apply to this proposed rule. 

E. Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 

(UMRA), Pub. L. 104-4, establishes requirements for Federal 

agencies to assess the effects of their regulatory actions 

on State, local, and tribal governments and the private 

sector. Under section 202 of the UMRA, we must generally 

prepare a written statement, including a cost-benefit 

analysis, for proposed and final rules with "Federal 

mandates" that may result in expenditures to State, local, 

and tribal governments, in the aggregate, or to the private 

sector, of $100 million or more in any 1 year. Before 

promulgating a rule for which a written statement is needed, 

section 205 of the UMRA generally requires us to identify 

and consider a reasonable number of regulatory alternatives 

and adopt the least costly, most cost effective, or least 
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burdensome alternative that achieves the objectives of the 

rule. The provisions of section 205 do not apply when they 

are inconsistent with applicable law. Moreover, section 205 

allows us to adopt an alternative other than the least 

costly, most cost-effective, or least burdensome alternative 

if the Administrator publishes with the final rule an 

explanation why that alternative was not adopted. Before we 

establish any regulatory requirements that may significantly 

or uniquely affect small governments, including tribal 

governments, it must have developed under section 203 of the 

UMRA a small government agency plan. The plan must provide 

for notifying potentially affected small governments, 

enabling officials of affected small governments to have 

meaningful and timely input in the development of our 

regulatory proposals with significant Federal 

intergovernmental mandates, and informing, educating, and 

advising small governments on compliance with the regulatory 

requirements. 

We have determined that this proposed rule does not 

contain a Federal mandate that may result in expenditures of 

$100 million or more by State, local, and tribal 

governments, in the aggregate, or the private sector in any 

1 year. The total cost to the private sector is 

approximately $72 million per year. [COMMENT: Previous 

statements mention annual costs of $29.2 million. Thoughts? 

If the figure is $72 million, please clarify that actual 
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expenditures will never exceed $100 million in a 12-month 

period.] This proposed rule contains no mandates affecting 

State, local, or Tribal governments. Thus, today's proposed 

rule is not subject to the requirements of sections 2 02 and 

205 of the UMRA. 

We have determined that this proposed rule contains no 

regulatory requirements that might significantly or uniquely 

affect small governments because it contains no requirements 

that apply to such governments or impose obligations upon 

them. 

F. Regulatory Flexibility Act (RFA), as amended by the 

Small Business Regulatory Enforcement Fairness Act of 1996 

(SBREFA), 5 U.S.C. 601 et seq. 

The RFA generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to 

notice and comment rulemaking requirements under the 

Administrative Procedure Act or any other statute unless the 

agency certifies that the rule will not have a significant 

economic impact on a substantial number of small entities. 

Small entities include small businesses, small 

organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of today's 

proposed rule on small entities, small entity is defined as 

(1) a small business ranging from 500-1,000 employees; (2) a 

small governmental jurisdiction that is a government of a 

city, county, town, school district or special district with 
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a population of less than 50,000; and (3) a small 

organization that is any not-for-profit enterprise which is 

independently owned and operated and is not dominant in its 

field. The table below presents the size threshold for 

small businesses by SIC Code. 

Category 

Manufacturing 

SIC Codes 

3621 

3711 

3716 

3728 

3743 

2821 

3296 

3431 

3531 

3612 

3613 

3663 

3714 

All other 

identified 

SIC Codes 

in this 

source 

category 

NAICS Codes 

335312 

336211, 

33612 

336213 

336413 

33651 

325211 

327993 

332998 

33312, 

335311 

335313 

33422 

33653, 

336112, 

33651 

336399 

All other 

identified 

NAICS Codes in 

this source 

category 

Maximum 

Number of 

Employees to 

be Considered 

a Small 

Business 

1000 

750 

500 

In accordance with section 603 of the RFA, EPA prepared 

an initial regulatory flexibility analysis (IRFA) that 

examines the impact of the proposed rule on small entities 

along with regulatory alternatives that could reduce that 

impact. The IRFA is available for review in the docket and 

is summarized below. 
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Section 112 of the CAA requires us to list categories 

and subcategories of major sources and, in some cases, area 

sources of HAP and to establish NESHAP for the listed source 

categories and subcategories. Reinforced plastic composites 

production (major sources only) was included on the initial 

list of source categories published on July 16, 1992 (57 FR 

3157 6) . Major sources of HAP are those that have the 

potential to emit greater than 10 tpy of any one HAP or 25 

tpy of any combination of HAP. 

The objective of this proposed rule is to apply 

standards based on maximum achievable control technology to 

all major sources in this source category. The criteria 

used to establish MACT are contained in section 112 (d) of 

the CAA. 

Based on SBA size definitions and reported sales and 

employment data, EPA identified 278 of the 356 companies 

owning reinforced plastic composites facilities as small 

businesses. Although small businesses represent almost 80 

percent of the companies within the source category, they 

are expected to incur only 31 percent of the total industry 

compliance costs of $26.0 million. The average total annual 

compliance cost is projected to be $30,000 per small company 

as compared to the industry average of $70,000 per company. 

Under the proposed standards, the mean annual compliance 

cost, as a share of sales, for small businesses is 0.7 

percent, and the median is 0.4 percent, with a range of 0.01 
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to 7.5 percent. The EPA estimates that 17 percent of small 

businesses (or 47 firms) may experience an impact greater 

than 1 percent of sales, but only 3 percent of small 

businesses (or 8 firms) may experience an impact greater 

than 3 percent of sales. 

The Agency also performed an economic impact analysis 

(EIA) that accounted for firm behavior to provide an 

estimate of the facility and market impacts of the 

regulation. This industry is characterized by profit 

margins of 3 to 4 percent. Small businesses were found to 

have higher per-unit production costs under baseline 

conditions and incur slightly higher per-unit compliance 

costs. As a result of these factors, the economic analysis 

indicates that almost 10 percent of facilities owned by 

small business are at risk of closure because of this 

proposed rule. 

Although any facility closures are cause for concern, 

the number of facilities at risk for closure would be the 

same if this proposed rule required only the MACT floor 

level of control for all facilities. The MACT floor is the 

least stringent level allowed by statute. As discussed 

below, this proposed rule contains a significant number of 

accommodations for small business. WeWithout additional 

data, we do not believe we can make the proposed rule any 

less stringent and comply with the objectives of the CAA._ 

We welcome comments and supporting data on this conclusion. 
P.91 

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The EPA's efforts to minimize small-business impacts 

have materially improved today's proposal. Economic 

analysis of provisions under earlier consideration for 

inclusion in this proposed rule indicated greater impacts on 

small businesses than those proposed today. In earlier 

versions, almost 42 percent of the total industry compliance 

costs would have been incurred by small businesses (compared 

with 31 percent of costs incurred by small businesses in 

today's proposal). The average total annual compliance cost 

would have been roughly $50,000 per small company (compared 

with $30,000 in today's proposal). About 22 percent of 

small businesses (or 60 firms) would have experienced an 

impact greater than 1 percent of sales (compared with 17 

percent of small businesses in today's proposal). And 7 

percent of small businesses (or 19 firms) would have 

experienced impacts greater than 3 percent of sales 

(compared with 3 percent of small businesses in today's 

proposal). The reduction in small-business costs from 

earlier versions of this proposed rule is attributable to 

EPA's outreach and accommodation for small firms in keeping 

with both RFA and CAA requirements, including the conduct of 

a SBAR Panel, as discussed further below. 

The oro iectedproposed reporting and recordkeeping 

requirements for these small businesses include initial 

notifications, startup notifications and compliance reports. 

These requirements were discussed in more detail under the 
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discussion of the Paperwork Reduction Act above. We 

estimate that 302 existing facilities owned by small 

businesses will be impacted by these requirements, and 53 

new facilities will be impacted in the first three years. 

The professional skills required to complete these reports 

include the ability to calculate emissions and resin use and 

read and follow report format guidance. All facilities 

impacted by this proposed rule should have personnel with 

the necessary skills because they would need these skills to 

comply with other regulatory requirements such as Toxic 

Release Inventory (TRI) reporting. 

Provisions to minimize the reporting and recordkeeping 

requirements on small business have been incorporated into 

this proposed rule. These provisions include allowing: the 

facility to substantiate resin and gel coat HAP contents 

with Material Safety Data Sheets rather then requiring 

testing of each resin and gel coat; use of resin purchase 

records to determine resin use; and exemption of facilities 

that can demonstrate that all their resin and gel coats 

comply with the required HAP content limits from the 

requirement to keep records of resin use and calculate point 

value averages. These provisions have also been extended to 

all companies subject to today's proposed NESHAP. 

These facilities may also be subject to the NESHAP 

being developed for plastic parts and products. There 

should be no duplication of effort as a result of this 
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proposed rule and the Plastic Parts and Products NESHAP 

being developed because these NESHAP will cover different 

operations. Facilities subject to this proposed rule are 

also subject to emissions estimate reporting under the TRI 

requirements. In this proposed rule, we could determine no 

ways to combine TRI and the reporting requirements of the 

proposed NESHAP because the objectives and statutory 

authorities of these requirements are different. However, 

we invite comments from, all interested parties on ways to 

combine these reports and still meet the statutory 

requirements of the CAA. 

As indicated above, we have incorporated significant 

alternatives into the proposed rule to minimize the impact 

on small business but still meet the objectives of the CAA. 

As required by section 609(b) of the RFA, EPA conducted 

outreach to small entities and convened a SBAR panel to 

review advice and recommendations from representatives of 

the small entities that potentially would be subject to the 

proposed rule requirements. The panel convened on April 6, 

2000 and was comprised of representatives from OMB, the SBA 

Office of Advocacy, the EPA Small Business Advocacy Chair, 

and the Emission Standards Division of the Office of Air 

Quality Planning and Standards of EPA. The panel solicited 

advice from 17 small entity representatives (SER) from a 

cross-section of the different industry sectors likely to be 

directly regulated by this action. On April 18, 2 000, the 
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panel distributed a package of descriptive and technical 

materials explaining the rule-in-progress to the SER. On 

May 2, 2000, the panel met with the SER to hear their 

comments on preliminary options for regulatory flexibility 

and related information. The panel also received written 

comments from the SER in response to both the outreach 

materials and the discussions at the meeting. 

Consistent with RFA/SBREFA requirements, the panel 

evaluated the assembled materials and small-entity comments 

on issues related to the elements of the IRFA. A copy of 

the panel report is included in the docket for this proposed 

rule. 

The panel considered numerous regulatory flexibility 

options in response to concerns raised by the SER. The 

major concerns included the affordability and technical 

feasibility of add-on controls, the resin and gel coat HAP 

contents required to meet some of the MACT floors, and the 

regulatory treatment of speciality products. 

These are the major panel recommendations and EPA's 

response in today's proposal: 

• Recommend setting higher thresholds than EPA had 

initially considered for requirements to use add-on 

controls. 

Response: In today's action, EPA proposes to allow 

facilities owned by small firms to emit 250 tpy (as 

distinct from the 100 tpy limit for facilities owned by 
P.95 

93 

large firms) before installing add-on controls. 

Recommend setting the new source floor for small-owned 

sources at the level of the existing source floor. 

Response: Today's proposal includes this provision. 

Recommend establishing separate floors for speciality 

products. 

Response: Today's proposal includes this provision. 

Explore pollution-prevention alternatives to add-on 

controls. 

Response: The EPA did explore this possibility with 

industry sources. Although we could not devise a 

workable pollution-prevention alternative to include in 

today's proposal, the Agency is requesting comment on 

how such a mechanism might be structured within the 

requirements of the CAA. 

Recommend allowing individual facilities to use the 

same resin in all resin application processes. 

Response: Today's proposal includes this provision. 

Reconsider the resin HAP content requirement for 

tooling resins. 

Response: Today's proposal includes a revised 

provision. 

Recommend separate floors for white and non-white gel 

coats. 

Response: Today's proposal includes this provision. 

Reconsider the Agency's estimates of the cost of add-on 
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controls. 

Response: Even though today's proposal eliminates the 

likelihood that existing small-owned facilities will be 

subject to add-on controls, EPA has reconsidered its 

cost estimates in light of those offered by the 

industry. As discussed elsewhere in this preamble, EPA 

continues to believe our estimates are realistic._ 

Nevertheless, we request comments on both our analysis 

and the materials submitted by industry, to help inform 

our decision on the final regulations. 

• Recommend grouping high-strength applications with 

corrosion-resistant operations. 

Response: Today's proposal includes this provision. 

Detailed information on all these recommendations is 

contained in the panel report in the docket for this 

proposed rule. 

G. National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and 

Advancement Act (NTTAA) of 1995 (Public Law No. 104-113; 15 

U.S.C. 272 note) directs EPA to use voluntary consensus 

standards in their regulatory and procurement activities 

unless to do so would be inconsistent with applicable law or 

otherwise impractical. Voluntary consensus standards are 

technical standards (e.g., materials specifications, test 

methods, sampling procedures, business practices) developed 

or adopted by one or more voluntary consensus bodies. The 
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NTTAA directs EPA to provide Congress, through annual 

reports to OMB, with explanations when an agency does not 

use available and applicable voluntary consensus standards. 

This proposed rulemaking involves technical standards. 

The EPA proposes in this rule to use EPA Methods 1, IA, 2, 

2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 18, 25, 25A, 204, and 

204B,C,D,E. Consistent with the NTTAA, the EPA conducted 

searches to identify voluntary consensus standards in 

addition to these EPA methods. One voluntary consensus 

standard was identified as applicable and EPA proposes to 

use this standard in this proposed rule. 

The one consensus standard, ASTM D642 0-99, Standard 

Test Method for Determination of Gaseous Organic Compounds 

by Direct Interface Gas Chromatography-Mass Spectrometry 

(GC/MS), is appropriate in the cases described below for 

inclusion in this proposed rule in addition to the currently 

available EPA Method 18 codified at 40 CFR part 60, 

appendix A. 

Similar to EPA's performance based Method 18, ASTM 

D6420-99 is also a performance based method for measurement 

of gaseous organic compounds. However, ASTM D6420-99 was 

written to support the specific use of highly portable and 

automated GC/MS. While offering advantages over the 

traditional Method 18, the ASTM method does allow some less 
P.98 

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stringent criteria for accepting GC/MS results than required 

by Method 18. Therefore, ASTM D6420-99 is a suitable 

alternative to Method 18 where: (1) the target compound(s) 

are those listed in Section 1.1 of ASTM D6420-99, and (2) 

the target concentration is between 150 parts per billion 

(volume) and 100 ppm(v). 

For target compound(s) not listed in Table 1.1 of ASTM 

D6420-99, but potentially detected by mass spectrometry, the 

regulation specifies that the additional system continuing 

calibration check after each run, as detailed in section 

10.5.3 of the ASTM method, must be followed, met, 

documented, and submitted with the data report even if there 

is no moisture condenser used or the compound is not 

considered water soluble. 

For target compound(s) not listed in Table 1.1 of ASTM 

D6420-99, and not amenable to detection by mass 

spectrometry, ASTM D6420-99 does not apply. 

As a result, EPA proposes to incorporate by reference 

(IBR) ASTM 6420-99 into 40 CFR 63.14 for application with 

proposed subpart WWWW of part 63. The EPA will also cite 

Method 18 as a gas chromatography (GC) option in addition to 

ASTM D6420-99. This will allow the continued use of other 

GC configurations. 

In addition to the voluntary consensus standards EPA 
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proposes to use in this proposed rule, the search for 

emissions monitoring procedures identified 17 other 

voluntary consensus standards. The EPA determined that 13 

of these 17 standards identified for measuring emissions of 

the HAP or surrogates subject to emission standards in the 

proposed rule would not be practical due to lack of 

equivalency, detail, and/or quality assurance/quality 

control requirements. The remaining four of the 17 

consensus standards identified are under development or 

under EPA review. Therefore, we do not propose to use these 

voluntary consensus standards in this proposed rulemaking. 

More information on the reasons we chose not to propose to 

use these standards is available in the docket for this 

proposed rule. 

The EPA takes comments on proposed compliance 

demonstration requirements in this proposed rulemaking and 

specifically invites the public to identify potentially 

applicable voluntary consensus standards. Commentors should 

also explain why this proposed rule should adopt these 

voluntary consensus standards in lieu of or in addition to 

EPA's methods. Emission test methods and performance 

specifications submitted for evaluation should be 

accompanied with a basis for the recommendation, including 

method validation data and the procedure used to validate 
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98 

the candidate method (if method other than Method 301, 40 

CFR part 63, appendix A was used). 

Table 6 of proposed subpart WWWW lists the EPA test 

methods and performance standards. Most of the standards 

have been used by States and industry for more than 

10 years. Nevertheless, under §63.7(f), the proposal also 

allows any State or source to apply to EPA for permission to 

use an alternative methods in place of any of the EPA 

testing methods or performance standards listed in the 

proposed NESHAP. 

H. Executive Order 13 045, Protection of Children from 

Environmental Health Risks and Safetv Risks 

Executive Order 13045 (62 FR 19885, April 23, 1997) 

applies to any rule that: (1) is determined to be 

"economically significant" as defined under Executive Order 

12866, and (2) concerns an environmental health or safety 

risk that we have reason to believe may have a 

disproportionate effect on children. If the regulatory 

action meets both criteria, the Agency must evaluate the 

environmental health or safety effects of the planned rule 

on children, and explain why the planned regulation is 

preferable to other potentially effective and reasonably 

feasible alternatives considered by the Agency. 

The EPA interprets Executive Order 13 045 as applying 

only to those regulatory actions that are based on health or 
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99 

safety risks, such that the analysis required under section 

5-501 of the Executive Order has the potential to influence 

the regulation. This proposal is not subject to Executive 

Order 13045 because it is based on technology performance 

and not on health or safety risks. Additionally, this 

proposed rule is not economically significant as defined by 

Executive Order 12866. 
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NESHAP: Reinforced Plastic Composites Production 

Proposed Rules - Page 100 of 182 

List of Subjects in 40 CFR Part 63 

Environmental protection, Air pollution control, 

Hazardous air pollutants, Incorporation by reference, 

Reporting and recordkeeping requirements, and Volatile 

organic compounds. 

Dated 

Carol M. Browner, 

Administrator.