p.1 

OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

28) IV-H-9 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:26 AM Sheet 28 of 130 
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Keith Barnett j _ Tq^ Bry_on_P._Allen@omb.eop.gov 

i 

02/04/2003 01:06 PMEPA Ai 

k,.nC r^.-^777o ^rcc:rJB.\\ Wehrum/DC/USEPA/US@EPA, Cecilia Kim/DC/USEPA/US@EPA, 

Penny Lassiter/RTP/USEPA/US@EPA 

Subject: RE: Reinforced Plastic Composites NESHAP - Definition of Large 

PartsU 

Dear Bryon: 

I wanted to follow up with you concerning Kevin Bromberg's last message. The following is the basis for 

EPA's definition of large parts. I believe we took a reasonable approach to this definition based on 

facilities currently operating. I also discuss why we cannot use the ACMA definition for large parts. 

The basis for the 400 cubic foot volume is A.R.E. in Mt. Eaton, Ohio, which meets the 95 percent capture 

and control requirements. The largest part built at A.R.E. is a custom car body. A full size automobile is 

approximately 6x15x 5 feet. This is a volume of 450 cubic feet. I originally planned to use a 

maximum part volume of 500 cubic feet, but later decided it would be more appropriate to round down to 

400 cubic feet, to give facilities some leeway and account for the mold volume. This eliminated the 

majority of the parts on the ACMA parts list from capture and control requirements. 

It was then suggested (by Office of General Counsel) that it might be more appropriate to have two 

criteria. One on volume and one on length. The problem was how to select a length. The largest single 

part dimension where permanent total enclosures have been applied were at Noble Composites. The 

longest part they produce is 50 feet. So we selected any dimension that exceeds 50 feet. This 

eliminated several more parts on the ACMA list, but did not eliminate flat panel type products (which was 

our intention). 

I read the telecon between Noble Composites and Kevin Bromberg. My understanding is that Noble 

bags the parts in the enclosure and pulls a vacuum after the part is out ofthe enclosure. I do not believe 

that the part will emit HAP after bagging. Therefore, the lamination operation will meet the requirements 

of EPA Method 204, which is the requirement in the rule. Even if there are emissions as the part leaves 

the booth that would violate the EPA Method 204 criteria, the reason is that they chose to vacuum bag 

rather then cure the part in the booth. A new facility could opt to extend the booth and completely cure 

the part prior to removal from the booth, which is exactly what Noble Composites does in their gel coat 

booth. Or they could seal the bag prior to taking the part out of the booth to insure there are no 

emissions. 

The point is that the issues raised by ACMA for large parts are not applicable to parts such as recreation 

vehicle sidewalls. The ACMA has stated that the reason that the facilities making large parts are not 

"similar" to the facilities that set the new source floors is that they have to open large doors to get parts 

and material in and out, and must have much larger permanent total enclosures with higher airflows than 

the facilities that have capture and control. This is not the case with large flat parts such as recreational 

vehicle sidewalls. They require openings in the permanent total enclosures no larger than those at 

facilities that currently meet 95 percent capture and control. Flat panels can be cured in enclosures as 

small as 4 feet high. Therefore, we have no basis to have a large parts definition that results in large flat 

panels being excluded from capture and control requirements. 

Further, we see no justification for the ACMA's suggested definition (parts with any dimension over 12 

feet are "large parts"). The basis of that definition, according to ACMA, was that their analysis showed 

that facilities making custom molded parts of 12 feet or more are less cost effective to control than 

facilities making smaller parts. First, that statement is insufficient justification. We can not consider 

costs when developing floors. Second, A.R.E. Mt. Eaton is a custom molding facility. They have 95 

percent capture and control. They have built parts up to the size of car bodies. The large part spray-up 

area at this facility is approximately 42.5 feet x 37.5 feet x 25 feet high. Therefore, they have room for 

parts much larger than 400 cubic feet, and certainly can build parts that exceed 12 feet long. Third, 

reviewing the comments submitted by the ACMA on the proposed rule, their own cost analysis shows 

that capture and control where the facility manufactures flat parts, and parts with volumes up to 400 
P.3 

cubic feet, was cost-effective, with an estimated cost effectiveness of less than $4000 per ton of HAP 

emission reduction. This is lower that all but one ofthe cost examples in the ACMA comments. It is also 

below some facilities that produce bathware, which will be subject to capture and control. The ACMA 

line of reasoning was that control of large parts was more expensive than small parts, and, therefore, 

there must be technical differences that make large part production "not similar" to small part production 

when considering add-on controls. Based on the ACMA line of reasoning, if the cost of control for small 

parts and large flat parts are similar, then the facilities must be technically similar. So I fail to see how a 

facility producing long flat parts can not be "similar" the facilities that set the new source floors. 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, N C 27711 

919-541-5605 

bamett.keith@epa.gov 

"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

"Bromberg, Kevin L." To: '"Bryon_P._Allen@omb.eop.gov"' <Bryon_P._Allen@omb.eop.gov>, 

<kevin.bromberg@sba Keith Barnett/RTP/USEPA/US@EPA 

.gov> cc: 

02/03/2003 0Q-4Q AM Subject: RE: Reinforced Plastic Composites NESHAP - Proposed Suggestion • 

12 Feet DimensionI've sent both of you faxes from Noble Composites that contradict the one 

plant that EPA says can make 100% capture and control for large parts. The 

gel coat spray booth can do so, but not the laminate booth. Every motor 

vehicle sidewall raust go through both booths, and therefore this plant 

cannot do 100% capture. Many of the parts in the industry list, for which 

ACMA says 100% capture is not feasible, would be captured by EPA's latest 

approach. 

Keith, for what plant, if any, can EPA demonstrate 100% capture and control? 

What is the EPA's basis for the suggested dimensions below? 

If there is no further evidence, I suspect that the only number supported by 

the record is ACMA's proposal to define "small open molded parts" with no 

dimension greater than 12 feet. If EPA has no record support for another 

dimension, or definition, the 12 foot dimension reasonably well captures big 

facilities that specialize in small parts, and are reasonably expected to be 

able to design in a 100% capture system, because it does not have the 

diversity of parts that many facilities have, who cannot design in such a 

system. 

Let's see if we can wrap this up quickly 

Kevin 

Original Message 

From: Bryon_P._Allen@omb.eop.gov [mailto:Bryon_P._Allen@omb.eop.gov] 

Sent: Thursday, January 30, 2003 5:06 PM 

To: kevin.bromberg@sba.gov 

Subject: Reinforced Plastic Composites NESHAP 

Kevin-