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OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

21) ll-J-12 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 21 of 36 
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A-9 4-6.3i 

ar-i-iaFrom: Mike Hood <m-hood@pacbell.net> 

To: RTP3.RTMU546(BARNETT-KEITH),RTPMAINHUB.INTERNET("j 

Date: 1/7/00 4:57pm 

Subject: Small Business MACT Review 
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Hood Manufacturing, Inc

 2621 s*Birch Strcel 

_ __ . _, .__. Santa Ana, Ca 92707 

Custom Fiberglass Products 714-979-7681 Phone 

714-979-4854 Fax 

Mr. Keith Barrett January 7, 2000 

United States EPA 

Emission Standards Division 

Mail Drop 13 

Research Park, NC. 27111 

Dear Mr. Barrett: 

Thank you for the opportunity to participate in the EPA's Small Business MACT 

Review. I want to recap my companies' position on the proposed draft. 

We cannot meet the proposed point limits for gel-coat unless we use 30% or 

less HAP gel-coats. This low HAP gel-coat is currently not now available to us. We 

use over 150 color formulas of gel-coats with an average HAP around 39%. I believe 

that in the future it is likely that my supplier will be able to reformulate these colors 

with quality materials with HAPs of around 35%. I base this belief upon conversation 

with my supplier and by reviewing the HAP contents of some of the gel-coats I use. 

For some colors, 30% HAP will cause poor weathering and surface failure, 

particularly in outdoor applications. Furthermore, handling characteristics change as 

the HAP content is modified, therefore, any application or processing changes should 

only be considered after the HAP contents are stabilized. Gel-coat application is a 

critical process. Applications too thick by as little as .005" increases cost by 25%-30% 

and causes cosmetically flawed products due to "lift-off', cracking, checking and 

porosity to mention a few problems. Since this law must be implemented based on 

current technology I believe you must consider what is generally available to the 

industry. Point values based on Hap contents of 33 to 35% is technically practical. 

Maybe you could set point values for indoor & outdoor application by colors. 

However, I really believe that that suggestion is too cumbersome to administer. 

We also apply a substantial amount of gel-coat to molded parts to impart a "nonglossy" appearance. This is accomplished by brushing or spraying a suppressed gelcoat. There is no provision in the draft for this process. If we were able to meet the 

point value with 35% gel-coat, this issue would be resolved. 

"Averaging" to meet the MACT point values, as agreed, is not a good business 

decision, since we do not have controls of our markets. 
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• Page 2 January 11,2000 

I think your "above the floor controls" were determined in a rather arbitrary 

manner. Of greatest concern to me is what criteria would trigger 100% capture and 

95% control rates? I would want a very clear definition of "reconstruction". My hope 

is that some day I will grow my company to the point I need to "reconstruct". My 

concern is that I will not be able to afford the "add-on" controls. I know the law is blind 

as to "economic consideration" but that is the key to all business decisions. The 

companies in the database that use some form of add-on control are not the same as 

I am. Those companies seem to service large markets of relatively the same 

products (possibly with mechanized production lines). I rarely make more than 200 

units of anything the same and never have had any kind of mechanized production 

line. The decision to install an "add-on control", for those who use them, might not 

have been primarily for economic reasons. I do not have a good solution to this "addon control" issue but any decision about growing I make will be carefully considered 

in light of such controls. My investigation indicate that just the cost to permit and 

prove compliance will cost about $30,000.00 a year. 

The record keeping aspect of this law will be a heavy burden on my company. 

Determining and recording what kind and the amount of materials containing HAPs, 

for us, would best be accomplished based on purchase records rather than daily 

consumption records. I believe purchase records would be infinitely more accurate. 

Still they will be costly to complete. 

I alluded to the problems of "definitions" in my comments on re-construction. 

I expect and hope that the EPA will clearly define all terms as they apply to this 

law and make those definitions a part of the MACT floors. Terms left to 

interpretation by an inspector begs for lawsuits and provides for unfair 

competition between more liberally interpreting jurisdictions. Please clearly define 

all terms. 

I believe that there are major discrepancies in the database, and that the 

grouping of very dissimilar businesses inherently contributes to the illogical new 

source floors. I know that is the way the law is written, but it makes more sense 

to me to have found the "Existing Source Floors" and reduced them by some 

percentage. Then check to see if anyone was able to attain that floor point value. 

I am particularly concerned that sources used to set the floors are inaccurate. 

From discussions I have had with my competitors, I am convinced that there 

exists an inconsistent interpretation of how to calculate emissions. This problem 

causes the database to be flawed. 

An excellent example of the poor logic of the law would be comparing a new 

source Centrifugal Caster manufacturing a 48" diameter pipe using a "Non CR." resin 

with a new source floor points of 391 and a new source open molder using the same 

resin and the same mold, but mechanically applied with a new source floor of 22 

unfilled. This seems to be a result of whether someone is manufacturing cleanly 

rather than if one can manufacture cleanly. 
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• Page 3 January 11,2000 

I believe that the EPA has continued to update the database and used that 

base to set lower floors. I thought the EPA was to base the floors on 1993 data. 

On slide #7 of the presentation made to the CFA's annual meeting it states "VSR 

resins were not used in determine the floor". I question this statement in view of 

the fact that we have used VSR resins for non-corrosive applications since 1988. 

This would have been on our reports and on other companies reports governed 

under the jurisdiction of the SCAQMD. 

In summary, our industry's diversification makes the statute requirements of 

this law unable to define fairly MACT floors for both new and existing sources. I 

doubt this law provides you the flexibility to establish floors that will meaningfully 

contribute to cleaner air. 

Keith, I believe you have done your best, but there are no ears to hear. 

"Justice" remains not only blind, but now she is deaf! 

Respectfully, 

Michael R. Hood 

President