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OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

51) ll-C-21 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:01 AM Sheet 51 of 56 
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»,£%•% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I ^ ^ 5 Office of Air Quality Planning and Standards 

I XM/ X / Research Triangle Park, North Carolina 27711 

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Mr. Tom Hedger 

Manufacturing and Product Development 

Magnum Industries 

11701 Fifty-six Court 

Cle.arwater, FL 34620 

Dear Mr. Hedger: 

The U.S. Environmental Protection Agency (EPA) is developing National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for the reinforced plastic composites 

industry. The NESHAP is to reflect the maximum achievable control technology as required 

by section 112(d) ofthe Clean Air Act of 1990. The EPA is currently investigating emission 

reduction techniques and controls used by major sources (for example, those facilities that 

have the potential to emit more than 10 tons per year of styrene). 

As you are aware from your participation in the July 31, 1995 teleconference, the EPA 

is currently working with representatives of the reinforced plastic composites industry, local 

and state regulatory agencies, and environmental groups to investigate potential options for 

setting a standard. Companies such as yours can help in this effort by providing information 

that will be used to develop a number of regulatory alternatives. One option we would like to 

consider is an emissions averaging approach for determining compliance. The standard would 

be based on the average emissions level achieved by the best performing facilities (i.e. those 

using pollution prevention techniques or controls). We believe this approach would provide 

the industry wim a great deal of flexibility and would provide quantifiable emission 

reductions. Such an approach would also provide credit for the use of flow coaters and 

pressure-fed rollers used in hand lay-up and spray-up operations. 

In addition, we are investigating an option that would incorporate the use of flow 

coaters and rollers if emissions averaging is not used. In order for us to determine whether 

the use offlow coaters and rollers is a viable control option, it is necessary to obtain 

information on the extent of their use and the conditions of use. 

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Your company could assist us in obtaining information so that we can explore these 

regulatory options further. 

Mr. Jeffrey Best of PES spoke with Mr. Charles Stard on 

August 17, 1995 and stated that the EPA would appreciate your providing information on the 

use offlow coaters and pressure-fed rollers. The information we are particularly interested in 

obtaining is a list of U.S. companies that currently use these flow coaters and rollers. This 

information would greatly assist our development of regulatory alternatives which could 

potentially encompass the use of these equipment technologies. We would also like to thank 

you for your interest and participation in the testing conducted by RTI and sponsored by 

EPA's Office of Research and Development. Please feel free to include any other information 

that you feel is important for EPA to consider. If you have any questions regarding this 

request, please contact me at (919) 541-2383. 

Sincerely, 

Madeleine Strum 

Coatings and Consumer Products Group 

Emission Standards Division 

cc: Linda Herring, Group Leader 

Coatings and Consumer Products Group 

PREPARED BY: OAQPS:ESD:M.Strum:NCM:llth Fir.:(MD-13):541-2383 

(PES/J.Best/941-0333/8-18-95) 

(ESD Project No. 93/58)