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OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

62) IV-C-35 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 62 of 273 
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<H* 

Keith Barnett 

10/04/2002 01:40 PM 

A-94-52 

IV-C-35 

To: "Newton, Drek (NFESC)" <newtonda@nfesc.navy.mil> 

cc: 

Subject: RE: Repair exclusionsH 

Dear Drek: 

I have attached a Word Perfect file with the sections ofthe rule that cover if you facility is affected, what 

operations at your facility are excluded, and the definition of nonroutine manufacture. 

Repair exemptions.wf 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

EPA AIR DOCKET 
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Am I subiect to this subpart? 

(a) You are subject to this subpart if you own or operate a 

reinforced plastic composites production facility that is located 

at a major source of HAP emissions. Reinforced plastic 

composites production is limited to operations in which 

reinforced and/or nonreinforced plastic composites or plastic 

molding compounds are manufactured using thermoset resins and/or 

gel coats that contain styrene to produce plastic composites. 

The resins and gel coats may also contain materials designed to 

enhance the chemical, physical, and/or thermal properties of the 

product. Reinforced plastic composites production also includes 

cleaning, mixing, HAP-containing materials storage, and repair 

operations associated with the production of plastic composites. 

(b) You are not subject to this subpart if your facility 

only repairs reinforced plastic composites. Repair includes the 

non-routine manufacture of individual components or parts 

intended to repair a larger item as defined in §63.5935 

(c) You are not subject to this subpart if your facility is 

a research and development facility as defined in Section 

112(c)(7) of the Clean Air Act (CAA). 

(d) You are not subject to this subpart if your reinforced 

plastic composites operations use less than 1.2 tpy of thermoset 

resins and gel coats that contain styrene combined. 

What parts of mv plant does this subpart cover? 

(a) This subpart applies to each new or existing affected 

source at reinforced plastic composites production facilities. 

(b) The affected source consists of all parts of your 

facility engaged in the following operations: open molding, 

closed molding, centrifugal casting, continuous lamination, 

continuous casting, polymer casting, pultrusion, sheet molding 

compound (SMC) manufacturing, bulk molding compound (BMC) 

manufacturing, mixing, cleaning of equipment used in reinforced 

plastic composites manufacture, HAP-containing materials storage, 

and repair operations on parts you also manufacture. 

(c) The following operations are specifically excluded from 

any requirements in this subpart: application of mold sealing and 

release agents, mold stripping and cleaning, repair of parts that 

you did not manufacture, including non-routine manufacturing of 

parts, personal activities that are not part of the manufacturing 

operations (such as hobby shops on military bases), prepreg 

materials as defined in §63.5935, non-gel coat surface coatings, 

repair or production materials that do not contain resin or gel 

coat, and research and development operations as defined in 

Section 112(c)(7) of the CAA. 

(d) Production resins that must meet military specifications 

are allowed to meet the organic HAP limit contained in that 

specification. In order for this exemption to be used, you must 

supply to the permitting authority the specifications certified 

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as accurate by the military procurement officer, and those 

specifications must state a requirement for a specific resin, or 

a specific resin HAP content. Production resins for which this 

exemption is used must be applied with nonatomizing (nonspray) resin application equipment unless you can demonstrate this 

is infeasible. You must keep a record of the resins for which 

you are using this exemption. 

Non-routine manufacture means that you manufacture parts solely 

to replace worn or damaged parts of a reinforced plastic 

composites product, or a product containing reinforced plastic 

composite parts, that was originally manufactured in another 

location. For a part to qualify as non-routine manufacture, it 

must be used for repair or replacement, and the manufacturing 

schedule must be based on the current or anticipated repair needs 

of the reinforced plastic composites product, or a product 

containing reinforced plastic composite parts. 

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