p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

? II-F-12 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 263 of 264 
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Jonathan.Pawlow@sb To: Peter_D._Eglinton@omb.eop.gov, Keith Bamett/RTP/USEPA/US@EPA 

a.gov 

03/08/2001 12:07 PM cc : 

Subject: More on RPC comments 

Dear Gentlemen, 

I looked over Peter's comments sent to Keith on Tues, 3/6, and I concur with them. I think the 

approach laid out makes sense. I have a couple of additional minor comments: 

1. I am wavering on whether the rule and the Preamble are clear enough on what the 

12-month rolling average is, and how it is to be calculated. The rule contemplates (as I 

understand it) that facilities are to calculate their resin usage on a monthly basis each calendar 

month. At the end of 12 months, they will have 12 one-month averages, which they then are to 

average into a 12-month average (i.e., the average of the 12 one-month averages). I could 

envision that some less sophisticated facility operator may interpret the rule's 12-month average 

as the average of 12 months of daily averages, or some other form of averaging over the course 

of 12 months, which would not be correct (as I understand it). Keith, I recommend that you add 

a sentence or two in the Preamble (maybe in Section 4, Selection of Averaging Time for 

Demonstrating Compliance, around pp. 59-60 of the draft text, or in some other suitable 

location???) and in the rule text (maybe in Section 63.5798(a), around pp. 111-112 of the draft 

text, or in some other suitable location???), making it crystal clear that the 12-month rolling 

average is to be determined by arithmetically averaging the 1-month averages, which they are 

required elsewhere in the rule to determine, for each of the preceding 12 one-month periods. I 

also recommend that you add a sentence or two explaining what a "rolling average" is. I've run 

into numerous people over the years who don't know what it is. 

2. I have a couple of other edits to the Preamble, which have been copied and pasted into 

the attached WordPerfect document. The first edit is aimed at adding back in an accidentally 

deleted word, and the second edit is aimed at clarifying the discussion of the additional 

alternative on which we will be soliciting comment. In the same attached document, I 

highlighted (in green) a couple of sentences (which Peter proposed taking out, in his edit) that I 

would not object to leaving in. 

3. Keith, don't forget to change the name of the EPA Administrator (from Browner to 

Whitman). 

Gentlemen, please call me if there are any questions. 

«Reinforced Plastics- Proposed Text Edits (3.8.01 ).wpd» 

Best regards, 
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Jon 

Jon Pawlow 

Jonathan R Pawlow, Esq. 

Assistant Chief Counsel 

Office of Advocacy 

Small Business Administration 

409 Third Street, S.W., 7th Floor 

Washington, D.C. 20416 

(202) 205-6951 (direct) 

(202) 481-0433 (fax) 

(202) 205-6928 (alternate fax) 

J0nathan.pawl0W@sba.g0V (e-mail) Rfiinforrfirt Plnstirs- Prnnnsfid T<=>yt FrlH 
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JRP (3/8/01) 

RPC MACT Rule Proposed Text Edits 

<add JRP text (yellow highlighted)> 

.delete JRP text (yellow highlighted)] 

SSMiM is fesa) to (MmB(mBmms\^M = JRP supports leaving this text in, 

with the edits shown in such text. 

Text from Page 69: 

along with data to support these comments. We solicit data on a 

facility's ability to maintain and operate add-on controls. We 

are especially interested in cost and design data from facilities 

in this industry that have successfully applied add-on controls. 

Data on control <device> inlet air flows and HAP device inlet 

concentrations combined with worker exposure monitoring data 

would be especially useful. We solicit data on typical operating 

hours in this industry, particularly in relation to the size of 

facilities and their operations (e.g., resin use or number of 

employees) since operating hours affect cost effectiveness and 

the number of start-ups and shutdowns. 

Text from Pases 70-72: 

The proposed rule allows .requires that-open molding and 

centrifugal casting operationsJto___ay^_rag£_jDO_^^ 

rolimg^^mo ^ 

i!_J3je-_jgnd^__(_y[_^^ 

facilitie s ;would nee d to haveviQLaLTimistmee^ a point value an a 

12-iMlnroinngaverdgeDei n compliance 2 years after 

publication of—tire—final rule. The reason is that in order ti 

have 12 months of data available^- i.e. 

gublicatibn.l to calculate—the average 

pubTTca11on,—facilities would need to be in compliance and 

collecting data 2 years after—final rule publication. We are 

soliciting comment with supporting data on whether it is feasible 

jtjc_^j3eg_ji-^ccjj[jgct^ 

these^si 

Je also considered 

a 3 year—compliance date,—with an additional 12 months—to 
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demons ti a te compliance . We rej ec ted tins alternative because rt 

would putentially alluw facilities—to exceed the emission limits 

[from] the compliance date to demonstrate compliance. <This 

would, in effect, allow open molding and centrifugal casting 

cj3§ra__J;cj_uiJ_ua_J^ 

coiBRiiancjLJJjitiJ^^ 

3JLi525JU_§LJsyLteE_J^ 

required to demonstrate compliance.> Such an approach is 

S5iis_LSvt^ntL_j_7i_th_^J_^ 

r^cruestcomment^^ 

^We^alsoisoTicitinfoIr^^ of 

the monitoring, recordkeeping, and reporting requirements in this 

proposed rule. We specifically solicit comments on the 

recordkeeping and reporting burden estimates set forth in Section 

VI in the Paperwork Reduction Act section and information on ways 

to minimize respondent burden.