p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

yfytf) ll-E-206 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 246 of 264 
PES * 

TO: 

FROM: 

DATE: 

SUBJECT: 

, • t , 

Keith Barnett 

MEMORANDUM 

U.S. EPA/ESD/OCG 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

January 18, 2000 

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(T-e-^ob 

Minutes of December 15, 1999 Meeting Between EPA and Representatives of the 

Reinforced Plastic/Composites Industry 

LOCATION: EPA/Mutual Building, Durham, NC, 9:00 am - 12:00 

ATTENDEES: 

Mr. 

Mr. 

Mr. 

Mr. 

Ms. 

Mr. 

Mr. 

Mr. 

Mr. 

Mr. 

' Ms. 

Mr. 

Mr. 

PURPOSE 

The 

Keith Barnett 

Chuck Elkins 

Robert Haberlein 

Robert Jemison 

Penny Lassiter 

David Lipiro 

Ken Meardon 

Lowell Miles 

Gary Multanen 

William Pedersen 

Melanie Proctor 

John Schweitzer 

Stuart Sessions 

purpose of the meeting 

industry and EPA representatives 

EPA/ESD/OCG 

Chuck Elkins & Associates 

Engineering Environmental 

PES 

EPA/ESD/OCG 

Environmental Compliance & 

Risk Management, Inc. 

PES 

Miles Fiberglass 

Fiberglass Systems 

Shaw Pittman 

PES 

Composite Fabricators 

Association (CFA) 

Environomics 

pm 

(919) 541-5605 

(202) 686-3518 

(410) 268-7367 

(919) 941-0333 

(919) 541-5396 

(330)908-0411 

(919) 941-0333 

(503) 775-7755 

(208) 850-9299 

(202) 663-8852 

(919) 941-0333 

(734) 622-0162 

(301) 657-7762 

was for representatives of the reinforced plastic composites 

to discuss various issues concerning the tentative MACT 

Standard for the reinforced plastic composites industry. Mr. Schweitzer provided a document 

describing their questions and concerns regarding EPA's current MACT floors. The document 

provided by Mr. Schweitzer is entitled "Questions on Above-the-Floor MACT for Existing 

Sources and MACT for New and Reconstructed Sources" and is enclosed with this document as 

Attachment 1. 
P.3 

Meeting Minutes 

January 18, 2000 

Page 2 

DISCUSSION 

Mr. Schweitzer started the meeting by explaining that the Composites Fabricators 

Association (CFA) hired a number of consultants to further study the issue of add-on control 

devices used in the reinforced plastic composites industry. He added that CFA asked for this 

meeting to discuss add-on control device issues and to determine which information CFA and their 

consultants can gather. 

The first issue raised focused on the feasibility, cost, and affordability of achieving 95 

percent control of emissions. The participants discussed the use of permanent total enclosures 

(PTEs) to obtain 100 percent capture of emissions. Additional topics discussed related to this 

issue included the methodology of sizing PTEs, multiple PTEs versus one building PTE, 

movement of products within and between PTEs, and method 204 criteria to demonstrate 100 

percent capture. 

The EPA contractor explained that the OAQPS cost manual and the RTI/EPA document 

entitled "Assessment of Styrene Emission Controls for FRP/C and Boat Building Industries" were 

used to cost add-on control systems to reduce emissions by 95 percent. 

The participants also discussed the type of device used in the EPA cost analysis, which was 

a rotary concentrator in conjunction with a thermal incinerator. In addition, the turndown ratio 

of a pre-concentration device, the operating hours, the air flow, and emission stream 

concentrations to the control device were discussed. Other costs that were addressed in 

conjunction with the add-on control device costs were recordkeeping and monitoring costs. 

CFA representatives urged the EPA and their contractor to not just rely on vendor 

information, but to visit facilities that use add-on control devices. In particular, CFA 

representatives suggested a visit to the Aker Plastics facility in Martinsburg, West Virginia, and 

the A.R.E. facility in MassiUon, Ohio. 

The second issue raised focused on the size cutoff above which facilities are required to 

meet the above MACT floor standard. Under EPA's current approach the size cutoff is 100 tons 

of hazardous air pollutant (HAP) emissions per year. The participants discussed the method used 

to estimate emissions to determine if facilities fall above or below the size cutoff, actual versus 

permitted emissions, and the method used to adjust 1992 facility data to 1997 data. 

The EPA contractor explained that Toxic Release Inventory (TRI) data was downloaded 

from the Internet and used to determine growth estimates on a facility basis. These growth 

estimates were then used to adjust 1992 resin usage data reported in the screening surveys to 1997 

data used in the economic analysis. 
P.4 

Meeting Minutes 

January 18, 2000 

Page 3 

The third issue discussed focused on the economic impact analysis, in which the cost of 

the standard was analyzed with respect to company sales data. The EPA contractor explained that 

1997 company sales data and average resin cost data were used in the economic analysis. 

Additional topics discussed related to this issue included plant closure analysis, the use of post-tax 

versus pre-tax sales data, the role of the business cycle, and passing on standard costs by 

increasing sales prices. The economic impact discussion related to new sources focused on 

profitability and barrier to entry issues. 

CFA representatives explained that the capital investment in process and related equipment 

in this industry is very low. They voiced concern that these facilities routinely replace more than 

50 percent of their process equipment in terms of capital value and thus quickly meet the criteria 

for reconstructed sources. 

CFA representatives indicated that they are planning to survey 20 actual plants to conduct 

a cost and MACT floor feasibility evaluation. They asked for input from EPA for the selection 

criteria to come up with a representative sample. The participants discussed CBI issues related 

to the expected data and if CFA representatives can share facility names and data with the EPA. 

The fourth issue discussed focused on the MACT floors for new sources that are currently 

under consideration. Industry representatives questioned the similarity between sources setting 

the new source MACT floors and new sources that likely come on line. In addition, industry 

representatives stated that they preferred EPA's previous MACT floor approach that would have 

required new open molding sources below a certain size limit to achieve the same level of control 

as existing sources. Additional topics that were discussed related to this issue included the Boat 

MACT Standard, legal requirements for setting MACT floors, similarity between sources, and 

the previously considered size cutoff for new sources. 

After industry representatives voiced their concerns regarding the MACT floors currently 

under consideration, Mr. Barnett suggested that they should take another look at the MACT 

database only focusing on areas where there are "real" problems with meeting the standards and 

let him know where these areas are. 

The fifth issue discussed focused on secondary environmental impacts due to the use of 

add-on control devices. Other topics that were addressed in conjunction with this issue included 

the temperature of the add-on control device, carbon dioxide, carbon monoxide, and nitrous oxide 

emissions, and styrene's potential effects as an ozone scrubber. 

The last issue discussed addressed companies that requested exemptions for the MACT 

standard. The discussion focused on two companies that requested exemptions, which are 

Appalachian Plastics and Reichhold Chemicals, Inc. Appalachian Plastics requested an exemption 
P.5 

Meeting Minutes 

January 18, 2000 

Page 4 

for their class I fire and smoke retardant resin and Reichhold Chemicals, Inc., requested an 

exemption for a low shrink tooling resin. 

Action Items for Industry Representatives: 

1. Review MACT database and provide feedback as to where there are "real" problems with 

the current MACT floors. 

Action Items for EPA: 

1. Provide industry representatives with the web-site address used to collect TRI data for 

growth estimates. 

2. Provide industry representatives with a copy of EPA/RTI report titled "Assessment of 

Styrene Emission Controls for FRP/C and Boat Building Industries." 
Composites Fabricators Association 

December 15,1999 

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Questions 

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Above-the-Floor MACT for Existing Sources 

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MACT for New and Reconstructed Sources 

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ESD's Current Approach 

• Both existing and new sources with actual total HAP emissions of 100 tons per year or 

more will be required to control 95% of all HAP emissions. 

• Most new sources, even those with emissions as low as 10 tons per year, wiil be required 

to achieve very low emission rates, often requiring installation of an incinerator. 

• CFA is concerned that these requirements: 

• May not be technically achievable. 

• May not be affordable for the large majority of sources, most of which are small 

businesses. 

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• May not reflect the most environmentally-smart emission reduction techniques for this 

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CFA Presentation December 15,1999 p.2 
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ESD's Current Approach 

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• CFA is working to understand the impacts of the possible MACT requirements. 9 

• Rob Haberlein of Engineering Environmental is evaluating the technical feasibility and j] 

cost of the 95 % capture and control requirement. 

• Stuart Sessions of Environomics is evaluating the economic impact Caffordabilit/1) of 

this requirement. 

• David Lipiro of Environmental Compliance and Risk Management Inc. is evaluating the 

I non-economic impacts, including environmental impacts, of capture and control 

(oxidation) for open molding. 

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CFA Presentation December 15.1999 p. 3 

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95% Control: Technical Feasibility, Cost, and Affordability 

? How do we know that 100% capture is feasible for existing or new sources? 

? How has EPA considered: § 

- the large and varied part sizes, 

- the need to continuously move molds and products in and out of process areas, 

- the typical practice of spray/roll-out/cure of several products at the same time, 

*j - and the need to control occupational exposures to 50ppm? 

s ? How has EPA evaluated the cost of retrofitting existing sources to achieve 100% 

I — - capture? 

1 ? How is EPA evaluating the cost and economic impact of the 95% control requirement for 

existing sources? 

? What are the factors that might significantly impact the outcome of these analyses? 

? How can EPA and CFA conduct their studies of technical feasibility, cost, and affordability, 

to yield the most useful information? 

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CFA Presentation December 15,1999 p. 4 
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Similarity of Floor-Setting-Sources to Actual New and 

Reconstructed Sources 

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? Are the specific sources that set the new source floors really "similar" to most likely new § 

and reconstructed sources, in terms of the practical ability to use emission reduction 

techniques or controls? 

• Some examples: 

- In the Non-Corrosion Mechanical Filled database, the best controlled source is much 

larger (by a factor of 100 or more) than most existing or likely new sources. 

| - In the Pigmented Gel Coat database, the best controlled source is a very large 

5 facility that has the technical resources needed to use a specialty low-HAP gel coat 

I (which is not even available to most of the other sources in this group). 

- In the Corrosion Mechanical database, both of the two best controlled sources make 

products for specific markets, where the required resins happen to have low HAP 

content. By contrast, the large majority of likely new sources in this group will make 

products for a range of end uses, and will therefore need to use a much wider range 

of resins with a wider range of HAP content. Note that the third-best controlled 

source uses resin with 44% HAP, versus 34% and 33% for the two top sources. 

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Standards for Reconstructed Sources 

• A very large number of open molders have very low capital investment in process and 

related equipment, and do not own their land or buildings. 

• No matter how the standard might define "reconstruction/'these sources will routinely 

replace more than 50% of their process equipment (in terms of capital value). The act of 

so doing will not make them any more able to comply with the new source floors than 

other existing sources that have not "reconstructed." 

? As existing open molding sources make routine replacement of process equipment, or 

adopt low-emitting application equipment to comply with existing source MACT, will they 

become reconstructed sources subject to new source MACT? 

? Will they be reasonably able to comply with the new source standards? 

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CFA Presentation December 15,1999 p. 6 
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New Source MACT- Different Standards Based on Size 

• EPA's previous (Fall, 1998) approach to MACT would have required new open molding 

sources with emissions of less than 95 tons per year to achieve the same level of control 

as existing sources. This approach: 

• Provided achievable requirements for most likely new sources. 

- Allowed existing sources to become reconstructed sources without triggering 

requirements they simply can not achieve. 

? Can EPA return to its previous approach to new source MACT? 

? What is the basis for EPA's claim that the Act does not allow the setting of different new 

source standards for different sized sources? 

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CFA Presentation December 15,1999 p. 7 

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Is oxidation really the "best" control for open molding? 

? Is oxidation an environmentally smart control for the open molding of composites? 

• The intermittent nature of the molding process, the large and varying size of parts, and 

the need to manage occupational exposures, mean that large quantities of natural gas 

must be bumed to control a small amount of HAP. 

• Styrene rapidly degrades in the atmosphere to ultimately form non-toxic substances. 

• Widespread use of oxidation to control open molding emissions will result in the release 

of large quantities of NOx, contributing to smog problems, and C02, which adds to 

global warming. 

• There is only one rotary concentrator, one fluidized bed concentrator, and one plantwide RTO presently in use at composites manufacturing operations, and the operating 

efficiencies of these units are not clear. 

- Many existing sources have zoning, noise control, or lease restrictions that will prevent 

installation of an incinerator. 

? How is EPA conducting its analysis of the non-economic impacts to the composites 

industry of the 95% control requirements? 

? What are the factors that might significantly impact the outcome of this analyses? 

? How can EPA and CFA conduct their evaluations of the non-economic impact of 

incinerators to yield the most useful information? 

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CFA Presentation December 15,1999 p. 8