p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

^'^e^ii-F-n 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 262 of 264 
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Peter_D._Eglinton@o To: Keith Barnett/RTP/USEPA/US@EPA 

mb.eop.gov 

03/06/2001 02:29 PM cc : 

Subject: More comments 

See attached. 

(See attached file: comments on 2-5 version.wpd) 

A-<N-sa 

nnmmftnt s o n 9-.S x/firsii 
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6560-50-P 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 63 

[FRL-] 

RIN 2060-AE79 

National Emission Standards for Hazardous Air Pollutants: 

Reinforced Plastic Composites Production 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: This action proposes national emission standards 

for hazardous air pollutants (NESHAP) for new and existing 

reinforced plastic composites production facilities. The 

proposed standards regulate production and ancillary 

processes used to manufacture products with thermoset resins 

and gel coats. Reinforced plastic composites production 

facilities emit hazardous air pollutants (HAP), such as 

styrene, methyl methacrylate (MMA) ,. and methylene chloride 

(dichloromethane). These HAP have adverse health effects 

including headache, fatigue, depression, irritation of skin, 

eyes, and mucous membranes. Methylene chloride has been 

classified as a probable human carcinogen. These proposed 

standards will implement section 112(d) of the Clean Air Act 

(CAA) by requiring all major sources in this category to 

meet HAP emission standards reflecting the application of 

the maximum achievable control technology (MACT). We 

estimate the proposed NESHAP would reduce nationwide 
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2 

emissions of HAP from these facilities by approximately 

14,500 tons per year (tpy) (65 percent). 

DATES: Comments. Submit comments on or before [INSERT DATE 

60 DAYS AFTER DATE OF PUBLICATION OF THIS PROPOSED RULE IN 

THE FEDERAL REGISTER]. 

Public Hearing. If anyone contacts the EPA requesting to 

speak at a public hearing by [INSERT DATE 20 DAYS AFTER DATE 

OF PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER], a public hearing will be held on [INSERT DATE 30 

DAYS AFTER DATE OF PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER]. 

ADDRESSES: Comments. Written comments should be submitted 

(in duplicate if possible) to: Air and Radiation Docket and 

Information Center (6102), Attention Docket Number A-94-52, 

U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, DC 

20460. We request a separate copy also be sent to the 

contact person listed below in the FOR FURTHER INFORMATION 

CONTACT section. 

Public Hearing. If a public hearing is held, it will be 

held at EPA's Office of Administration Auditorium, Research 

Triangle Park, North Carolina. 

Docket. Docket No. A-94-52 contains supporting information 

used in developing the standards. The docket is located at 

the U.S. EPA, 401 M Street, SW, Washington, DC 20460 in Room 

M-1500, Waterside Mall (ground floor), and may be inspected 

from 8:30 a.m. to 5:30 p.m., Monday through Friday, 
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3 

excluding legal holidays. 

FOR FURTHER INFORMATION CONTACT: Keith Barnett, Organic 

Chemicals Group, Emission Standards Division (MD-13), U.S. 

EPA, Research Triangle Park, North Carolina 27711, (919) 

541-5605, barnett.keith@epamail.epa.gov. For public hearing 

information, contact Maria Noell, Organic Chemicals Group, 

Emission Standards Division (MD-13), U.S. EPA, Research 

Triangle Park, North Carolina 27711, (919) 541-5607. 

SUPPLEMENTARY INFORMATION: 

Comments. Comments and data may be submitted by electronic 

mail (e-mail) to: a-and-r-docket@epa.gov. Electronic 

comments must be submitted either as an ASCII file to avoid 

the use of special characters and encryption problems or on 

disks in WordPerfect® version 5.1, 6.1 or Corel 8 file 

format. All comments and data submitted in electronic form 

must note the docket number: A-94-52. No confidential 

business information (CBI) should be submitted by e-mail. 

Electronic comments may be filed online at many Federal 

Depository Libraries. 

Commenters wishing to submit proprietary information 

for consideration must clearly distinguish such information 

from other comments and clearly label it as CBI. Send 

submissions containing such proprietary information directly 

to the following address, and not to the public docket, to 

ensure that proprietary information is not inadvertently 

placed in the docket: Attention: Keith Barnett, c/o OAQPS 
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4 

Document Control Officer (Room 740B), U.S. EPA, 411 W. 

Chapel Hill Street, Durham, NC 27701. The EPA will disclose 

information identified as CBI only to the extent allowed by 

the procedures set forth in 40 CFR part 2. If no claim of 

confidentiality accompanies a submission when it is received 

by the EPA, the information may be made available to the 

public without further notice to the commenter. 

Public Hearing. Persons interested in presenting oral 

testimony or inquiring as to whether a hearing is to be held 

should contact Maria Noell, Organic Chemicals Group, 

Emission Standards Division (MD-13), U.S. EPA, Research 

Triangle Park, North Carolina 27711, (919) 541-5607 at least 

2 days in advance of the public hearing. Persons interested 

in attending the public hearing must also call Maria Noell 

to verify the time, date, and location of the hearing. The 

public hearing will provide interested parties the 

opportunity to present data, views, or arguments concerning 

these proposed emission standards. 

Docket. The docket is an organized and complete file of the 

information considered by the EPA in the development of this 

rulemaking. The docket is a dynamic file because material 

is added throughout the rulemaking process. The docketing 

system is intended to allow members of the public and 

industries involved to readily identify and locate documents 

so that they can effectively participate in the rulemaking 

process. Along with the proposed and promulgated standards 
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and their preambles, the contents of the docket, excluding 

interagency review materials, will serve as the record in 

the case of judicial review. (See section 307(d)(7)(A) of 

the CAA.) The regulatory text and other materials related, 

to this rulemaking are available for review in the docket or 

copies may be mailed on request from the Air Docket by 

calling (202) 260-7548. A reasonable fee may be charged for 

copying docket materials. 

World Wide Web (WWW). In addition to being available 

in the docket, an electronic copy of the proposed NESHAP 

will also be available on the WWW through the Technology 

Transfer Network (TTN). Following signature, a copy of the 

proposed NESHAP will be posted on the TTN's policy and 

guidance page for newly proposed or promulgated rules 

http://www.epa.gov/ttn/oarpg. The TTN provides information 

and technology exchange in various areas of air pollution 

control. If more information regarding the TTN is needed, 

call the TTN HELP line at (919) 541-5384. 

Regulated Entities. Categories and entities potentially 

regulated by this action include: 

NAICS SIC 

Category code code Examples of regulated entities 
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Industry 325211 

326122 

325991 

326191 

327991 

327993 

332998 

33312 

33651 

335311 

335313 

335312 

33422 

336211 

336112 

336211 

33651 

33653 

336399 

33612 

336213 

336413 

336214 

2821 

3084 

3087 

3088 

3089 

3281 

3296 

3431 

3531 

3531 

3612 

3613 

3621 

3663 

3711 

3711 

3713 

3714 

3714 

3716 

3728 

3743 

3792 

3999 

Reinforced plastic composites 

production facilities that 

manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

Federal 

Government 

Federally owned facilities 

that manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

This table is not intended to be exhaustive, but rather 

provides a guide for readers regarding entities likely to be 

regulated by this action. To determine whether your 

facility is regulated by this action, you should examine the 

applicability criteria in §63.5785 of the proposed rule. If 

you have any questions regarding the applicability of this 

action to a particular entity, consult the person listed in 

the preceding FOR FURTHER INFORMATION CONTACT section. 

Outline. The information presented in this preamble is 
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organized as follows: 

I. Introduction 

A. What is the source of authority for development of 

NESHAP? 

B. What criteria are used in the development of NESHAP? 

C. What are the potential health effects of the HAP emitted 

by the reinforced plastic composites production industry? 

D. How were the proposed NESHAP developed? 

E. What processes and operations are included in the 

Reinforced Plastics Composites Production source category? 

II. Summary of Proposed NESHAP 

A. What source categories and subcategories are affected by 

this proposed rule? 

B. What are the primary sources of HAP emissions and what 

are the emissions? 

C. What is the affected source? 

D. What are the progojjed^emission limits, operating limits, 

and other standards?********^ 

E. What is the MACT model point value and how is it- used in 

these proposed NESHAP? 

F. When would,.I.n_eed__to_ must I comply with these proposed 

options for demonstrating 

NESHAP? 

G. What are 

compliance? 

H. What are the 

requirements? 

I. What are the 

requirements? 

J. What are the 

testing and initial compliance 

continuous compliance 

notification, recordkeeping and 

reporting requirements? 

III. Rationale for Proposed NESHAP 

A. How did we determine the source category to regulate? 

B. What pollutants are regulated under these proposed 

NESHAP? 

C. What is the "affected source" and how did EPA select the 

operations to be regulated by these proposed NESHAP? 

D. What is a new affected source? 

E. How did we determine the MACT floor for existing 

sources? 

F. How did we determine the MACT floor for new sources? 

G. Did we consider control options more., stringent than the 

MACT floor? 

H. Why are some reinforced plastic composites production 

operations not subject to these proposed NESHAP? 

I. How did we select the form of these proposed NESHAP? 

J. How did we select the test methods for determining 

compliance with the proposed NESHAP? 

K. How did we determine the j^^^^^^^moni toring and 

recordkeeping requirements? 

L. How did we select the ^^^^^notificatio n and 

reporting requirements? 
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M. What are some of the areas where we are specifically 

soliciting comments? 

IV. Summary of Environmental, Energy, and Economic Impacts 

A. What facilities are affected by the proposed NESHAP? 

B. What are the air quality impacts? 

C. What are the water quality impacts? 

D. What are the solid and hazardous waste impacts? 

E. What are the energy impacts? 

F. What are the cost impacts? 

G. What are the economic impacts? 

V. Relationship of Proposed NESHAP to Other Standards and 

Programs under the CAA 

A. National Emission Standards for Closed Vent Systems, 

Control Devices, Recovery Devices, and Routing to a Fuel 

Gas System or a Process (40 CFR Part 63, Subpart SS) 

B. Operating Permit Program 

C. NESHAP for Plastic Parts and Products 

VI. Administrative Requirements 

A. Executive Order 12866, Regulatory Planning and Review 

B. Paperwork Reduction Act 

C. Executive Order 13132, Federalism 

D. Executive Order 13084, Consultation and Coordination 

with Indian Tribal Governments 

E. Unfunded Mandates Reform Act of 1995 

F. Regulatory Flexibility Act (RFA), as amended by the 

Small Business Regulatory Enforcement Fairness Act of 1996 

(SBREFA), 5 U.S.C. 601 et see. 

G. National Technology Transfer and Advancement Act 

H. Executive Order 13045, Protection of Children.from 

Environmental' Health Risks and Safety Risks 

I. Introduction 

A. What is the source of authority for development of 

NESHAP? 

Section 112 of the CAA requires us to list categories 

and subcategories of major sources and area sources of HAP 

and to establish NESHAP for the listed source categories and 

subcategories. Reinforced Plastic Composites Production 

(major sources only) was included on the initial list of 

source categories published on July 16, 1992 (57 FR 31576). 

Major sources of HAP are those that have the potential to 
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9 

emit greater than 10 tpy of any one HAP or 25 tpy of any 

combination of HAP. 

B. What criteria are used in the development of NESHAP? 

The CAA requires NESHAP to reflect the maximum degree 

of reduction in emissions of HAP that is achievable. This 

level of control is commonly referred to as the MACT. 

The MACT floor is the minimum control level allowed for 

NESHAP. This concept appears in section 112(d)(3) of the 

CAA. For new sources, the MACT floor cannot be less 

stringent than the emission control that is achieved in 

practice by the best-controlled similar source. The MACT 

standards for existing sources can be less stringent than 

standards for new sources, but they cannot be less stringent 

than the average emission limitation achieved by the bestperforming 12 percent of existing sources in the category or 

subcategory (or the best-performing 5 sources for categories 

or subcategories with fewer than 30 sources). 

In developing MACT, we also consider control options 

that are more stringent than the floor. We may establish 

standards more stringent than the floor based on the 

consideration of cost of achieving the emissions reductions, 

any nonair quality health and environmental impacts, and 

energy requirements. 

C. What are the potential health effects of the HAP emitted 
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by the reinforced plastic composites production industry? 

Today's proposed NESHAP protect air quality and promote 

the public health by reducing emissions of some of the HAP 

listed in section 112(b)(1) of the CAA. 

The HAP emitted by the reinforced plastic composites 

production industry include, but are not limited to, 

approximately 20,000 tpy of styrene, 550 tpy of methyl 

methacrylate, and 1100 tpy of methylene chloride. Exposure 

to these compounds has been demonstrated to cause adverse 

health effects, including chronic health disorders (e.g., 

headache, fatigue, and depression) and acute health 

disorders (e.g., irritation of skin, eyes, and mucous 

membranes and decreased respiratory function). Methylene 

chloride has been classified as a probable human carcinogen 

and styrene as a possible human carcinogen. In general, 

these findings have only been shown with concentrations 

higher than those typically in the ambient air. 

We do not have the type of current detailed data on 

each of the operations covered by today's proposed NESHAP 

(and the people living around the operations) necessary to 

conduct an analysis to determine the actual population 

exposures to the HAP emitted from these facilities and the 

potential for resultant health effects. Therefore, we do 

not know the extent to which the adverse health effects 

described above occur in the populations surrounding these 

operations. However, to the extent the adverse effects do 
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occur, the proposed rule will reduce emissions and 

subsequent exposures. 

1. Styrene 

Acute (short-term) exposure to styrene in humans 

results in mucous membrane and eye irritation and 

gastrointestinal effects. Chronic (long-term) exposure to 

styrene in humans may cause effects on the central nervous 

system (CNS) such as headache, fatigue, weakness, 

depression, and hearing loss. There is limited evidence 

that occupational exposure to styrene is associated with an 

increased frequency of spontaneous abortions and decreased 

frequency of births and an increased risk of leukemia and 

lymphoma. The EPA considers this evidence on occupational 

exposure to styrene to be inconclusive. The International 

Agency for Research on Cancer has classified styrene as a 

Group 2B, possible human carcinogen. The EPA has not 

classified styrene with respect to carcinogenicity. 

2. Methyl Methacrylate 

Methyl methacrylate irritates the skin, eyes, and 

mucous membranes in humans. An allergic response to dermal 

exposure may develop. Respiratory effects following acute 

(short-term) exposure include chest tightness, dyspnea, 

coughing, wheezing, and reduced lung function. Neurological 

symptoms including headache, lethargy, lightheadedness, and 

a sensation of heaviness in the arms and legs have also been 

reported following acute exposure to MMA. Effects to the 
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12 

liver, kidney, brain, spleen, and bone marrow have been 

reported in chronic (long-term) animal studies of MMA 

inhalation. Fetal abnormalities have been reported in 

animals exposed to MMA by injection and inhalation. In 

several animal studies, no carcinogenic effects were 

observed. The EPA has classified MMA in Group E (not likely 

to be carcinogenic in humans). 

3. Methylene Chloride 

Acute (short-term) exposure to methylene chloride by 

inhalation affects the nervous system, causing decreased 

visual, auditory, and motor functions. These effects are 

reversible once exposure ceases. The effects of chronic 

(long-term) exposure to methylene chloride suggest that the 

CNS is a potential target in both humans and animals. 

Limited animal studies have reported developmental effects. 

Human data are inconclusive regarding methylene chloride and 

cancer. Animal studies have shown increases in liver and 

lung cancer and benign mammary gland tumors following the 

inhalation of methylene chloride. The EPA has classified 

methylene chloride as a Group B2, probable human carcinogen. 

D. How were the proposed NESHAP developed? 

We started the development of the proposed NESHAP by 

sending information collection request (ICR) surveys to 

facilities with applicable standard industries 

classification (SIC) codes. In addition to these surveys, 

we consulted with numerous members of the reinforced plastic 
13 

composites industry, representatives of industry trade 

associations, and material and equipment vendors in 

developing the proposed NESHAP. 

We held a series of approximately 35 meetings and 

visited approximately 25 facilities over a period of 8 

years. These meetings and site visits were held to keep 

stakeholders informed and to gather additional data and 

information on issues relevant to the proposed NESHAP. The 

stakeholders helped in data gathering, arranged site visits, 

identified issues and provided information to help resolve 

issues in the rulemaking process. 

We identified the MACT floor control level with 

information obtained through survey responses, site visits, 

telephone contacts, and operating permits. We assessed 

control options more stringent than the MACT floor by 

identifying the level(s) and method(s) of control achieved 

by the best controlled sources in the industry and 

conducting analyses designed to determine the cost, 

economic, energy, and environmental impacts of implementing 

the more stringent control options. 

E. What processes and operations are included in the 

Reinforced Plastic Composites Production source category? 

The Reinforced Plastic Composites Production source 

category involves the production of plastic products from 

cross-linking resins, usually in combination with 

reinforcing materials and inorganic fillers. The production 
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14 

of products that do not contain reinforcing materials is 

also included in this category, as well as the production of 

intermediate compounds which are later used to make the 

final plastic products. These non-reinforced products were 

included because they are produced using the same types of 

resins, have similar emission characteristics and would use 

similar emission controls. This source category is limited 

to those resins which contain-styrene, either by itself or 

with a combination of other monomers or solvents. 

There are a wide variety of operations that use 

styrene-containing resins to make thermoset plastics. Such 

production operations include manual resin application, 

mechanical resin application, filament winding, gel coat 

application, compression/injection molding, resin transfer 

molding, centrifugal casting, continuous 

lamination/continuous casting, polymer casting, pultrusion, 

and sheet molding compound (SMC) manufacturing. There are 

also ancillary operations such as cleaning, mixing/bulk 

molding compound (BMC) manufacturing, and storage that occur 

in conjunction with these production operations. Many 

facilities will use multiple operations in the manufacturing 

of their product. 

II. Summary of Proposed NESHAP 

This preamble section discusses the proposed NESHAP as 

they apply to you, the owner or operator of a new or 

existing reinforced plastic composites production facility. 
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A. What source categories and subcategories are affected by 

this proposed rule? 

Today's proposed rule applies to the Reinforced 

Plastics Composites Production source category. We 

evaluated the use of subcategories based on size (i.e., tpy 

of HAP emitted). These subcategories played an important 

role in defining the new source MACT floors. However, the 

available data that we used to develop the MACT floor for 

existing sources do not show significant differences between 

larger-emitting versus smaller-emitting sources. Thus, we 

did not go through a separate analysis for each subcategory 

of existing sources. 

B. What are the primarv sources of HAP emissions and what 

are the emissions? 

The primary source of HAP emissions from the Reinforced 

Plastic Composites Production source category is the 

evaporation of styrene and other organic liquid HAP 

contained in the resin during the application and/or curing 

of the resin. Since styrene participates in the curing 

reaction, not all of it is emitted. The HAP emissions also 

occur during ancillary operations such as cleaning, 

mixing/BMC manufacturing, and storage. 

Total baseline HAP emissions from the Reinforced 

Plastic Composites Production source category are 

approximately 22,200 tpy. Emissions from spray lay-up and 

gel coating constitute approximately 56 percent and 19 
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percent of the total baseline emissions, respectively. The 

remaining HAP emissions are primarily from hand layup/bucket and tool application, compression 

molding/injection molding, filament winding, SMC 

manufacturing, and centrifugal casting. 

C. What is the affected source? 

Under this proposed rule, the affected source would be 

the combination of all operations regulated under these 

standards at a reinforced plastic composites production 

facility. The following regulated operations are typically 

performed at reinforced plastic composites production 

facilities and are part of the affected source: open 

molding, closed molding, centrifugal casting, continuous 

lamination/continuous casting, polymer casting, pultrusion, 

SMC manufacturing, equipment cleaning, 

BMC/manufacturing/mixing, and storage of HAP containing 

materials. 

D. What are the proposedremission limits, operating limits, 

and other standards? 

We are proposing the requirements of these NESHAP in 

the form of emission limits (i.e., point value, mass rate, 

or percent reduction), operating limits, and work practice 

standards. Work practice standards include design, 

equipment, work practices, and operational standards. 

In developing proposed requirements for reinforced 

plastic composites affected sources, we have provided an 
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alternative format where possible. For example, a facility 

meeting a 95 percent emission reduction requirement for open 

molding processes can alternatively meet a point value. We 

have also provided alternatives for meeting the limits for 

continuous lamination and continuous casting processes. 

We are proposing a threshold for existing sources to 

distinguish between sources that would meet the floor 

requirements, that are generally based on pollution 

prevention, and those that would have to meet a more 

stringent above-the-floor requirement based on 95 percent 

control of HAP emissions. For small businesses, the 

threshold is 250 tpy of combined HAP emissions for open 

molding, centrifugal casting, continuous lamination/casting, 

pultrusion, and SMC manufacturing. The definition of a 

small business for this source category ranges from 500 to 

1000 employees. More specific information on the definition 

of a small business may be found in the discussion of the 

Regulatory Flexibility Act in the Administrative 

Requirements section of this preamble. For businesses that 

are not small businesses, the threshold is combined 

emissions of HAP of 100 tpy from the same operations. 

For all open molding operations (i.e., corrosionresistant, noncorrosion-resistant, tooling, and gel coat) 

and centrifugal casting (corrosion-resistant and 

noncorrosion-resistant) at existing sources below the 

threshold, and new sources with HAP emissions less than 100 
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tpy, you must comply with a HAP emission limit that is 

calculated for your facility using MACT model point value 

equations for each open molding and centrifugal casting 

operation. For open molding and centrifugal casting 

operations at new sources with HAP emissions equal to or 

greater than 100 tpy, and existing sources with HAP 

emissions equal to or greater than the applicable thresholds 

(i.e., 100 tpy for large businesses and 250 tpy for small 

businesses), we are proposing to require owners and 

operators to reduce emissions by 95 percent from these 

operations or comply with a corresponding HAP emission limit 

calculated using the MACT model point value equations. 

We are proposing to require owners and operators of 

continuous lamination/continuous casting operations at 

existing sources below the above-the-floor applicability 

thresholds, and new sources with HAP emissions less than 100 

tpy, to reduce emissions by 58 percent. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators of 

pultrusion operations at existing sources below the abovethe-floor thresholds, and new sources with HAP emissions 

less than 100 tpy, to reduce emissions by 60 percent. This 

reduction is based on applying a wet enclosure or using 

direct die injection to limit emissions. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators at 
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19 

both new and existing sources using injection/compression 

molding operations to reduce HAP emissions through the use . 

of a work practice, whereby only one charge per machine is 

uncovered, unwrapped, or exposed per mold cycle per 

compression/injection molding machine. 

We are proposing to require owners and operators of 

sheet molding compound operations at existing sources below 

the above-the-floor thresholds, and new sources with HAP 

emissions less than 100 tpy, to reduce emissions by using a 

nylon film, or film with equal or lower permeability to 

styrene, to enclose their SMC operation. Other new and 

existing sources must reduce emissions by 95 percent. 

We are proposing to require owners and operators of all 

new and existing reinforced plastic composites affected 

sources to use cleaners containing no HAP. 

We are proposing to require owners and operators of 

resin mixing and bulk molding compound operations at 

existing sources below the above-the-floor applicability 

thresholds, and new sources with HAP emissions less than 100 

tpy, to limit HAP emissions by covering mixers such that 

there are no visible gaps. For other new and existing 

sources, we are proposing to require that you reduce 

emissions from mixing and BMC manufacturing by 95 percent. 

For existing sources that are subject to the above-thefloor control level of 95 percent HAP emission reduction, we 

examined an alternative, based on pollution prevention, that 
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20 

would be more effective than the requirements of the MACT 

floor for existing sources. However, we were unable to 

develop an acceptable alternative to include in the proposed 

standards that meets the statutory requirements of MACT. We 

are soliciting comment on-a possible alternative. 

We are proposing to require all owners and operators at 

any existing or new affected source to keep all organic HAPcontaining storage vessels covered, except during the 

addition or removal of materials. 

E. What is the MACT model point value and how is it used in 

these proposed NESHAP? 

The MACT model point value is a number calculated for 

each open molding operation and centrifugal casting 

operation and is a surrogate for emissions. The MACT model 

point value is a way to rank the relative performance of 

different resin and gel coat emissions reduction techniques. 

This approach allows you to create control strategies using 

different resin and gel coat emissions reduction techniques. 

The proposed standards provide equations to calculate MACT 

model point values based on HAP content and application 

method for each material that you use. These MACT model 

point,values are then averaged and compared to limits in the 

proposed standards to determine if your open molding 

operations are in compliance. 

The MACT model point values have units of pounds of HAP 

per ton of resin or gel coat applied. It is important to 
P.23 

21 

note that the MACT model point values are surrogates for 

emissions, and the MACT model point value equations are used 

only for determining compliance with the proposed Reinforced 

Plastic Composites Production NESHAP. The MACT model point 

value equations cannot be used in place of emission factor 

equations to demonstrate compliance with other regulations. 

The MACT model point value equations only account for 

HAP content and application method. Other factors 

(including curing time, part thickness, and operator 

technique) also affect emissions, and these factors are not 

accounted for in the MACT model point value equations for 

reasons discussed in section III-E. Determining the HAP 

content of materials and the method of application is 

relatively simple, and these factors are the most 

significant in affecting emissions. More information on the 

development of this model is available in the docket. 

F. Whenwouj^^j^nje^dj^tbjauubt I comply with these proposed 

NESHAP? 

' ^^^^^^^^^^^^^^^^^^^Ex i b L iny 

reinforced plastic composites production open molding and 

centrifugal casting operations feo'^Lhat are meetiny standards 

based on 12-monLh rolliny average point valuab—must comply 

within |||2—years of the date the promulgated NESHAP are 

published in the Federal Register-;—but have three years from 

publication to demonstrate compliance with Lhe 12*-month 

rolling average. All other—existing sources must comply 
22 

supporting, data on the feasibility.or_ t_hi-S.r_eg3a_ir_e.ment_.___As_ 

^ntionedlaterin^isweMb^we^are^ ^ an 

alternative, .approach _ to _ a_l lo^. _f aci lit ies; _to_ jdempns tra te. 

gongD^jmce^^^one^ affected 

sources that startup before the promulgated NESHAP are 

published in the Federal Register must comply no later than 

the effective date of the NESHAP, which will be the same as 

the publication date. New affected sources that startup 

after the promulgated NESHAP are published in the Federal 

Register must comply upon startup. Existing area sources 

that increase their emissions or their potential to emit 

such that they become a major source of HAP must be in 

compliance within 3 years of the date they become a major 

source. New area sources that become major sources of HAP 

must comply upon becoming a major source. All new open 

molding and centrifugal casting operations that comply by 

meeting a specified point value on a 12-month rolling 

average will have 1 year from the compliance date to 

demonstrate compliance. 

We are proposing to provide new and existing facilities 
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23 

3 years to comply from the time their HAP emissions reach or 

exceed the applicability thresholds requiring the 

installation of add-on controls, if these HAP emissions 

increases occur after their initial compliance date. We are 

providing this compliance time for new and existing sources 

under these circumstances because complying with the add-on 

control requirements subsequent to your, initial compliance 

date would require the same amount of time as for existing 

sources that must install add-on controls within 3 years of 

the effective date of the NESHAP. 

G. Vfliat are the^rogo^^jtiy-options for demonstrating 

compliance? 

Today's proposed NESHAP provide several options for 

compliance. We are providing these options to afford 

industry the flexibility to decide which method is best 

suited for each particular situation. 

1. Open Molding and Centrifugal Casting Operations 

For open molding operations at existing and new 

sources, this proposal would allow you to choose to comply 

by meeting the individual MACT point value for each 

operation at your affected source, or by meeting the 

weighted average MACT point value for all open molding 

operations at your affected source. In addition, if you 

have any combination of manual resin application, mechanical 

resin application, filament winding, or centrifugal casting 

operations at your affected source, you could comply by 
P.26 

24 

meeting the MACT point value for any one of these operations 

and by using the same resin for all the other operations. 

For open molding and centrifugal casting operations 

where the proposed rule would require you to meet a percent 

reduction, you could use an add-on control device to achieve 

the required reduction or you may choose to meet a MACT 

point value that corresponds to that particular operation's 

percent reduction. 

2. Continuous Casting/Lamination Operations 

For continuous casting/lamination operations at 

existing and new sources, we are proposing that you could 

demonstrate that each continuous casting line and each 

continuous lamination line meets the appropriate standard. 

Alternatively, you could average all your continuous casting 

and continuous lamination lines together, and demonstrate 

that they meet the appropriate standard. An additional 

alternative would be to capture your emissions from your 

wet-out area in.a permanent total enclosure that meets EPA's 

criteria, as specified in Method 204 in appendix M of 40 CFR 

part 51, and vent these wet-out emissions through a closed 

vent system to a control device achieving 95 percent 

reduction of HAP emissions. Under this proposed rule, these 

alternatives could be used in combination to demonstrate 

compliance. 

3. Pultrusion Operations 

For existing and new pultrusion operations, under this 
P.27 

25 

proposed rule you could capture and vent your emissions to a 

control device that achieves the required percent reduction 

of HAP emissions. You could also elect to use direct die 

injection pultrusion machines with resin drip collection 

systems that meet the criteria specified. We are also 

proposing an additional alternative only available to 

existing sources: the use of a wet-area enclosure with a 

resin drip collection system. For both new and existing 

sources, you could use the available options in combination 

to achieve compliance under this proposed rule. 

4. Ancillary Operations 

For ancillary operations at all sources, such as 

cleaning, storage, and mixing/BMC operations at existing 

sources, the only option we are proposing is to comply with 

the specified work practice standards. 

H. What are the testing and initial compliance 

requirements? 

We are proposing to require owners and operators of all 

affected sources which use a control device to demonstrate 

compliance to conduct an initial performance test using 

specified EPA test methods. The owner or operator would 

test at the inlet and outlet of the control device, and 

using these results, calculate a percent reduction. 

We are also proposing to require owners and operators 

that use permanent total enclosures to conduct a design 

evaluation as specified by EPA Method 204. If your 
P.28 

26 

enclosure does not meet the requirements for a permanent 

total enclosure, you would need to test the enclosure using 

EPA Methods 204B through E to determine the capture 

efficiency. 

Prior to the initial performance test, owners and 

operators of affected sources would be required to install 

the parameter monitoring equipment to be used to demonstrate 

compliance with the operating limits. During the initial 

performance test, the owners and operators would use the 

parameter monitoring equipment to establish operating 

parameter limits. 

I. What are the continuous compliance requirements? 

If you use an add-on control device, we are proposing 

that you monitor and record the operating parameters 

established during the initial performance test, and 

calculate average operating parameter values averaged over 

the period of time specified in these proposed NESHAP to 

demonstrate continuous compliance with the operating limits. 

If you use the MACT point value system to maintain a 

point value less than or equal to the appropriate point 

value listed in today's proposed NESHAP, we are proposing to 

require that you calculate the point value one time if the 

resins or gel coats used in the operation remain the same, 

or if all the resins and gel coats used individually meet 

the required ^values . You are required to 

calculate the point value on a 12-month rolling average each 
27 

month if the resin or gel coat varies between operations or 

over time, and not all resins or gel coats taken 

individually meet the required point value. 

If you are complying with work practice standards, we 

are proposing that you demonstrate compliance with the work 

practice standards in today's proposed NESHAP by performing 

the necessary work practices and by keeping a record 

certifying that you are in compliance with the work 

practices. 

J. What arethe grop^osedjiotification, reporting, and 

recordkeeping requirements? 

We are proposing that you submit Initial Notification, 

Notification of Performance Tests, and Notification of 

Compliance Status reports by the specified dates in the 

proposed NESHAP, which may vary depending on whether the 

affected source is new or existing. 

You would also need to submit semiannual compliance 

reports. If you take action that is inconsistent with your 

approved startup, shutdown, and malfunction (SSM) plan, then 

you would need to submit SSM reports within 2 days of 

starting such action, and within 7 days of ending such 

action. 

We are proposing that you keep a copy of each 

notification and report, along with supporting documentation 

for 5 years. Of this time, the first two years must be onsite. You would need to keep records related to SSM, 
P.30 

28 

records of performance tests, and records for each 

continuous parameter monitoring system. Under this proposed 

rule, if you must comply with the work practice standards, 

you would also need to keep records certifying that you are 

in compliance with the work practices for 5 years. If you 

are use the MACT point value system to demonstrate 

compliance, you would need to keep all data, assumptions, 

and calculations used to determine your MACT point value. 

For new and existing continuous lamination/casting 

operations, you would also need to keep the following 

records when complying with the percent reduction or pound 

per ton requirements: all data, assumptions, and 

calculations used to determine the percent reduction and/or 

pounds per ton, as applicable; a brief description of the 

rationale for the assignment of an equation or factor to 

each formula; all data, assumptions, and calculations used 

to derive facility-specific emission estimations and 

factors; identification and-rationale for the worst-case 

scenario; and documentation that the appropriate regulatory 

agency has approved all emission estimation equations and 

factors. 

III. Rationale for Proposed NESHAP 

A. How did we determine the source category to regulate? 

Reinforced Plastic Composites Production was included 

on the initial list of source categories published on July 

16, 1992 (57 FR 31576) . In establishing the source category 
P.31 

29 

list, we stated that we would refine category descriptions 

during the rulemaking process, if necessary, based on 

additional information available. We did not find it 

necessary to refine the source category description for 

Reinforced Plastic Composites Production. However, we did 

define a number of different process groupings in order to 

develop representative MACT floors as described in the 

section on MACT floor development. 

B. What pollutants are regulated under these proposed 

NESHAP? 

The proposed NESHAP regulate total HAP rather than 

individual HAP compounds. Standards for total HAP simplify 

compliance and enforcement compared with standards for 

individual HAP compounds. Styrene is the HAP emitted in the 

largest magnitude. Other HAP emitted from reinforced 

plastic composites production facilities include MMA and 

methylene chloride. 

C. What is the "affected source" and how did EPA select the 

operations to be regulated by these proposed NESHAP? 

To provide compliance flexibility, we defined the 

affected source as the combination of all reinforced plastic 

composites operations at a site. This broad source 

definition allows a manufacturer to determine compliance by 

averaging the HAP content of different products used 

throughout the facility, within certain defined operations, 

and to use different application techniques as needed to 
P.32 

30 

meet product quality specifications. 

D. What is a new affected source? 

A new affected source is any reinforced plastic 

composites production facility that meets both of these 

criteria: 

• It commenced construction after today's date; and 

• It is at a site that does not presently contain 

any reinforced plastic composites production 

operations. 

In section 112 of the CAA, the definition of new 

sources also includes stationary sources that commence 

reconstruction after the publication date of a proposed 

NESHAP. The Small Business Advocacy Review (SBAR) Panel 

recommended that we carefully review our definition of 

reconstruction for this industry. As defined in the General 

Provisions for 40 CFR part 63, "reconstruction" means the 

replacement of components of an affected, or a previously 

unaffected, stationary source to such an extent that: (1) 

the fixed capital cost of the new components exceeds 50 

percent of the fixed capital cost that would be required to 

construct a comparable new source; and (2) it is 

technologically and economically feasible for the 

reconstructed source to meet the relevant standards (as 

established by the Administrator or a State) pursuant to 

section 112 of the CAA. 

We envision that the types of changes that would 
P.33 

31 

typically occur at existing facilities would include 

replacement of spray equipment and molds. We do not believe 

that it would be technologically and economically feasible 

for an existing source making these types of changes to meet 

new source MACT. Thus, such changes do not meet the 

definition of reconstruction in the General Provisions and 

would not subject the sources making such changes to new 

source MACT. 

E. How did we determine the MACT floor for existing 

sources? 

Several considerations underlie our MACT floor 

determinations. These considerations include: if/how the 

source category is to be subcategorized, how emissions types 

within the affected source are to be analyzed, and what are 

the best performing sources. 

We identified 433 facilities that are major sources 

based on their potential to emit or have the potential to be 

major sources based on collocation with other HAP-emitting 

processes not part of this source category. 

If technical differences in emissions characteristics, 

processes, control device applicability, or opportunities 

for pollution prevention exist within the source category, 

it may be appropriate to set separate floors based on these 

characteristics. In analyzing the available data on this 

source category, it was apparent that reinforced plastic 

composite facilities, as a whole, are extremely diverse in 
P.34 

32 

their emissions characteristics, control device 

applicability, and opportunities for pollution prevention. 

Therefore, we explored various ways of grouping the 

operations that may be present at these facilities. 

For existing sources, it was apparent that almost all 

of the existing source floors would be based on pollutionprevention techniques such as lowering the HAP content in 

resins and gel coats, covering baths and containers holding 

resins, and using nonatomized spray applications. The 

extent and performance of pollution-prevention techniques 

are dependent on the specific operation. For this reason, 

the data were subdivided by specific operation, and a floor 

for each operation was developed. 

Operations were segregated by several factors. The 

first was mold type (i.e., open, partially open, and 

closed). We also segregated operations by resin and gel 

coat application method; these include mechanical, manual, 

filament winding, and centrifugal casting. The type of mold 

and resin application method impacts the emission potential 

of a particular operation and also the effectiveness and 

applicability of different control techniques. We also 

segregated continuous operations such as pultrusion, 

continuous lamination, continuous casting, and the 

manufacture of sheet molding compound. 

The final criteria used was product type. The required 

properties of the final product place certain constraints on 
P.35 

33 

the raw materials that can be used. This, in turn, 

influences the limits on levels of HAP in the raw materials. 

We identified several product criteria where the raw 

materials required to produce the product are dissimilar 

enough that a separate floor determination was required. 

The first is corrosion resistance. Reinforced plastic 

composites can generally be divided into two types--

corrosion-resistant and noncorrosion-resistant products. 

Corrosion-resistant products require resins specifically 

formulated for corrosion-resistant applications. We also 

included high-strength applications in the corrosionresistant grouping. These applications include products 

such as structural members and utility poles. These require 

resins with higher HAP contents than general purpose resins. 

The higher HAP contents for both corrosion-resistant and 

high-strength applications are. necessary to produce a 

laminate with a greater concentration of styrene crosslinking. This higher level of cross-linking, is necessary 

for either corrosion-resistance or high-strength. 

We also separated gel coats from resins because these 

materials have significantly different functions in the 

final product and are formulated differently. Gel coats 

were further subdivided into clear, white and off-white, and 

other colors. Clear gel coats require significantly higher 

HAP content than pigmented gel coats, and are, therefore, 

unable to be formulated to the same HAP levels. White and 
P.36 

34 

off-white gel coats can be formulated to lower HAP contents 

on a weight-percent basis than other colors due to the fact 

that white pigments are heavier than other color pigments. 

Class 1 fire and smoke rated products were separated 

from other products because their unique properties require 

a resin with a significantly higher HAP content than any 

other products. Separating Class 1 fire and smoke rated 

prpducts was also one of the recommendations of the SBAR 

Panel. 

Tooling resins and gel coats are used to make the molds 

that, in turn, are used to produce reinforced plastic parts. 

Molds must have different properties compared to the 

products they are used to produce. These include a high 

level of dimensional stability and resistance to heat 

compared to other reinforced plastic composites. Therefore, 

separate floors were developed for tooling resins and gel 

coats. 

Once the data were subdivided by specific operation, 

the data were ranked by HAP emissions. Open molding and 

centrifugal casting operations were ranked based on a 

surrogate emission factor called a point value. As 

previously discussed, point values are based on resin and 

gel coat application method and HAP content, and provide a 

relative measure of emissions between operations with 

varying resin and gel coat HAP contents and application 

methods. 
P.37 

35 

Other factors such as gel time, part thickness, 

application temperature, and operator technique also affect 

emissions. However, there is less data available to 

determine the effects of these factors in a production 

setting. In addition, some of these factors, such as part 

thickness, are inherent to the process and cannot be changed 

without changing the final product. For this reason, other 

factors are not included in the MACT model point value 

equations. The point value system was also developed to 

allow a facility to average different operations together to 

meet the applicable proposed standards. The ability to 

average is intended to provide additional compliance 

flexibility. 

The individual operations were then ranked based on the 

point value (for open molding and centrifugal casting), 

percent of emission reduction (pultrusion, continuous 

lamination/casting, SMC manufacturing), covering open 

containers or exposed resin (storage, BMC 

manufacturing/mixing, injection/compression molding), or the 

use on non-HAP cleaning solvents (equipment cleaning). The 

median facility of the top 12 percent (or top 5 for 

operations with less than 30 sources) was then selected as 

representing the existing source floor. 

For some of these operations, the available data were 

insufficient to perform a ranking. These were non-white 

pigmented gel coats, products with a Class 1 fire and smoke 
P.38 

36 

rating, and high-strength products. 

We identified two facilities that produce products that 

require a Class 1 fire and smoke rating. Both facilities 

use a resin with a 60 percent HAP content. We chose use of 

this resin as the floor. From a 60 percent HAP resin, we 

calculated different point values for mechanical, manual, 

and filament winding resin application. 

The data we used to set floors for pigmented gel coats 

were weighted averages reported by the facilities. This 

data included some information on colors, but not enough 

facilities reported color information to perform a 

meaningful ranking. Because of the predominance of white 

and off-white gel coats, these data are not representative 

for other colors. However, many facilities offer other 

colors. The pigments used in white and off-white gel coats ' 

are much denser than the pigments used in other colors. For 

that reason, weight percent HAP in white and off-white gel 

coats tends to be lower. A floor based on white and offwhite gel coat HAP contents would preclude a facility using 

other colors. 

Based on industry comments and the recommendation of 

the SBAR panel, we determined that a HAP content of 37 

percent is the minimum that would provide acceptable gel 

coat performance for gel coats with colors other then white 

and off-white. In the absence of any other data, we adopted 

a 37 percent HAP as the floor for these gel coats. The 37 
P.39 

37 

percent HAP content was converted to a point value using the 

appropriate point value equation. (See the final report of 

the SBAR Panel in the docket.) We request comments and 

supporting data on the appropriateness of 37 percent as a 

minimum HAP content for acceptable performance for gel coats 

with colors other than white and off-white. 

The data supplied by industry did not differentiate 

products that require higher than typical strength 

properties. Therefore, we could not determine a floor with 

the facility data base. We discussed this issue as part of 

the SBAR Panel with several manufacturers that produce highstrength products. We also reviewed the requirements of 

South Coast Air Quality Management District Rule 1162 . Rule 

1162 specifically addresses high-strength products and 

contains the same requirements for high-strength products 

and corrosion-resistant products. As a result, we 

determined using the data for corrosion-resistant resins 

would be the most appropriate way to determine floors for 

high-strength products. Therefore, we are proposing the 

same floors for high-strength products and corrosionresistant products. This is consistent with a 

recommendation of the SBAR Panel. We solicit comments on 

thi s approach. 

There are many facilities that use multiple operations 

to produce a product. An example of this would be a 

facility producing corrosion-resistant tanks using filament 
P.40 

38 

winding to produce the main circular portion, mechanical 

resin application for the tank ends, and manual resin 

application to join the parts together. Industry 

representatives pointed out that the floors we had developed 

from the data base would potentially require a facility to 

use three different resins to produce a single product. 

This could potentially lead to problems of resin 

compatibility and product failures. The SBAR Panel report 

included a recommendation that we allow a facility to use 

the same resin for all processes. 

As a result, we reexamined the floors for facilities 

with multiple processes. We determined that, based on the 

data available, the appropriate approach would be to have a 

provision in the proposed standards to allow a facility to 

select one operation, determine the resin they could use to 

meet the floor, and then use that same resin in all other 

operations. We did not have the data to determine what that 

operation should be in all cases, so we are not specifying a 

particular operation in the proposed standards. We assumed 

that a facility would select the operation that allows them 

to use the highest HAP content resin. 

At the recommendation of the SBAR Panel, we also 

reexamined the floors for tooling resins. Several of the 

small entity representatives that advised the panel stated 

that the proposed floor for tooling resins will result in 

inferior quality tools. We believe that the current floor 
P.41 

39 

for tooling resins allows sufficient flexibility in resin 

HAP content as long as the resin can be applied with 

nonatomized spray technology. We are specifically 

soliciting comment on the applicability of nonatomized spray 

technology to tooling resins. Based on any comments, we 

intend to further examine the floor for tooling resins. 

F. How did we determine the MACT floor for new sources? 

In developing the floor for new sources, we developed 

two subcategories--sources with emissions of 100 tpy or 

above and sources with emissions below 100 tpy. Our reason 

for examining sources with emissions below 100 tpy 

separately is that such facilities are likely to have more 

difficulty maintaining and operating add-on controls than 

larger-emitting sources, and we are unsure of the 

performance of add-on controls at these facilities. 

Separating the data into large and small HAP-emitting 

sources for developing new source MACT floors was also one 

of the recommendations of the SBAR Panel. 

In examining the facilities with emissions of 100 tpy 

or more, we found two facilities that control emissions from 

open molding and mixing by 95 percent overall. These 

facilities range in size from approximately 100 tpy to 1000 

tpy of HAP emissions prior to the add-on control device. 

This level of control was chosen as the new source MACT 

floor for open molding and mixing at facilities with 100 tpy 

or more of uncontrolled emissions. 
P.42 

40 

We also considered whether to evaluate the 

applicability of add-on controls to each of the different 

operations as was done is setting floors for existing 

sources. The two facilities that control emissions by 95 

percent have operations including gel coat and mechanical 

resin application. ' The performance and cost of add-on 

controls is mainly a function of air flows and HAP 

concentration from the process. We have no data to suggest 

that the air flows and HAP concentrations present in other 

open molding production processes in this industry are not 

adequately represented by these two facilities. 

The two facilities produce parts that range in size 

from that of bathtubs to truck caps. It is possible that 

larger size parts may require larger enclosures. We have 

not identified any facilities in the reinforced plastic 

composites industry where processes producing large parts, 

such as storage tanks and swimming pools, have applied 100 

percent efficient capture systems. However, we have 

identified facilities using 100 percent efficient capture 

systems that apply coatings to large parts such as 

helicopters and ships. These coating operations have 

similar issues of large air flows (due to worker exposure 

concerns) and low outlet HAP emission concentrations. Based 

on this, we believe that it is technically feasible to apply 

100 percent efficient capture systems to larger parts in the 

reinforced plastic composites industry. 
41 

We evaluated the applicability of the 95 percent 

control level as the new source floor for other operations. 

Centrifugal casting, continuous lamination/casting, 

pultrusion, and SMC manufacturing are similar in emissions 

characteristics to open molding. There are five facilities 

that have applied highly efficient add-on controls to these 

operations, with overall control efficiencies ranging from 

90 to 95 percent. For this reason, we chose 95 percent 

control as the new source MACT floor for these operations at 

facilities with uncontrolled emissions of at least 100 tpy. 

We also considered whether the new source MACT floor 

for the previously mentioned operations should be 

incorporation of the pollution-prevention measures that make 

up the existing source floors, combined with 95 percent 

control. This approach would actually result in a higher 

overall emissions reduction. In addition, incorporating the 

pollution prevention measures would reduce the potential for 

worker exposure in situations where processes have to be 

enclosed to meet the 95 percent control requirement. 

However, we determined that selecting incorporation of 

pollution-prevention techniques in addition to the 95 

percent control requirement as the new source floor was not 

appropriate because the facilities that incorporate 95 

percent control, which we determined represent the best 

controlled facilities, do not also incorporate the best 

pollution prevention techniques. Therefore, combining the 
P.44 

42 

pollution-prevention requirements with the 95 percent 

control requirements would actually result in an overall 

control level that exceeds the levels at the best controlled 

facilities. 

We are requesting comment on whether the new source 

floor for facilities that must meet the 95 percent control 

requirements should also incorporate the pollutionprevention requirements. We also request that commentors 

provide any available data on worker exposure that would 

help us quantify the benefits of incorporating pollutionprevention requirements with the 95 percent control 

requirements. 

We are not proposing 95 percent control for closed 

molding, polymer casting, equipment cleaning, and resin 

storage, which have much lower emissions than the other 

types of operations. One of the facilities that sets the 

new source floor has a closed molding operation on site. 

This operation is not controlled. We did identify other 

types of controls for these processes. For 

compression/injection molding, which is a type of closed 

molding, the only identified control was the work practice 

of uncovering one charge at a time. Therefore, this was 

chosen as the new source MACT floor for 

compression/injection molding. For polymer casting and 

resin transfer molding, we were not able to identify any 

applicable control techniques. Thus, the new source MACT 
P.45 

43 

floor for these sources is no control. 

For equipment cleaning, the proposed new source floor 

is based on use of cleaners with no HAP. Of the 433 

facilities that reported information on cleaning, 353 

reported using no cleaning materials containing HAP. 

However, we are not regulating solvents used for cleaning 

cured resin or gel coat from application equipment because 

we know of no HAP emission controls. Cured resin or gel 

coat inside a gun is usually the result of operator error or 

an equipment failure. To clean cured resin and gel coat, an 

aggressive solvent is needed, and no low-HAP alternatives 

are available. The equipment is usually soaked in a covered 

bucket resulting in little evaporation of the solvent. The 

amount of solvent needed per year is determined by the size 

of the facility, degree of operator error, and equipment 

failure rates. Because operator error and equipment failure 

are hard to predict, we could determine no basis for an 

annual limit of solvent usage that would be achievable by 

all facilities. These proposed NESHAP, therefore, allow 

HAP-containing solvents only for cleaning cured resin and 

gel coat from the application equipment. 

Over 250 facilities reported covering storage 

containers. We selected covering storage containers as the 

new source MACT floor for storage. We identified two 

facilities that vent the storage areas to a control device; 

however, we determined that the available data are 
P.46 

44 

insufficient to quantify additional emissions reductions 

that would result from controlling storage tanks and 

containers by 95 percent versus just covering the storage 

tanks and containers. 

We calculated separate floors for facilities with less 

than 100 tpy of emissions from open molding, centrifugal 

casting continuous lamination/casting, pultrusion, SMC 

manufacturing, and BMC manufacturing/mixing. Though there 

are facilities with emissions below 100 tpy that have add-on 

controls, data were not available to substantiate their 

level of control. Therefore, we could not state that they 

achieved a level of control above that achieved by the 

pollution-prevention techniques, and thus, meet the 

definition of best controlled facilities. Also, smalleremitting facilities tend to operate with fewer shifts than 

larger ones. The more frequent startups and shutdowns could 

tend to make it more difficult to maintain and operate addon controls compared to larger-emitting facilities. For 

these reasons, the floor for new sources with less than 100 

tpy of emissions is based on pollution-prevention 

techniques. 

For these smaller-emitting facilities, we proposing 

to set the new source MACT floor at the same level as the 

existing source MACT floor. This approach was recommended 

by the SBAR Panel. We believe the existing source MACT 

floor represents the greatest degree of emissions reduction 
P.47 

45 

that is achievable for small facilities under all 

circumstances. For new sources, the CAA requires the MACT 

floor to be based on the HAP emissions control achieved in 

practice by the best controlled similar source, as 

determined by the Administrator. The reinforced plastic 

composites industry is extraordinarily diverse. The 

products produced, even in the same operation, can include 

skylights, bathtubs, and parts for automobiles. Given this 

diversity, it is difficult to identify the "best controlled" 

source. Products manufactured by this industry generally 

must meet certain minimal strength and durability 

requirements. The HAP content of the resin is a factor in 

meeting such requirements. Use of a resin with a given HAP 

content may be the most stringent level of control possible 

for a particular process, while it may be possible to use a 

lower-HAP resin in a different process without jeopardizing 

the strength or durability of the product. 

While some facilities are using lower-HAP materials and 

techniques than represented by the existing source MACT 

floor, we do not believe that these examples are universally 

applicable to all new reinforced plastic composites 

manufacturers. We have no data to precisely define the 

particular combination of requirements where these loweremitting options can be used and still maintain the minimum 

required strength and durability requirements of these 

products. Consequently, we have set the proposed floor at 
P.48 

46 

the most stringent level that we have determined all sources 

emitting less than 100 tpy can achieve. 

We did not find that the quantity of HAP emissions from 

the source had any effect on its ability to incorporate 

pollution-prevention technology, or on the effectiveness of 

these technologies. For that reason, we did not subdivide 

the data for existing sources where the floors are based 

mainly on pollution prevention. 

During the SBAR Panel discussions, many of the small 

entity representatives expressed concern regarding the 

affordability and technical feasibility of add-on controls, 

and commented that they may be able to achieve similar HAP 

reductions using pollution-prevention measures, which tend 

to be less expensive. For example, if a facility could 

reduce its emissions by 50 percent each year for 3 years 

using the pollution-prevention alternative, it may be able 

to achieve reductions similar to thermal oxidation (nearly 

90 percent versus 95 percent). The panel recommended that 

EPA explore with industry the possibility of a more 

stringent pollution-prevention option as an alternative to 

add-on controls. The panel believed that this option should 

be more stringent than the pollution-prevention technology 

present in the current existing source MACT floors. 

We discussed with industry the possibility of a 

pollution-prevention control option in lieu of add-on 

controls. We were unable to develop an option that we 
P.49 

47 

believe meets the statutory requirements of MACT. However, 

we are soliciting comment on a possible pollution-prevention 

alternative to the 95 percent HAP reduction requirement. 

The specific information we are seeking is the maximum level 

of control that can be achieved by pollution prevention, and 

the time necessary to incorporate pollution-prevention 

techniques. The pollution-prevention techniques of which we 

are aware include low HAP resins and gel coats, nonatomized 

resin and gel coat applications, vapor suppressed resins, 

vacuum bagging, accelerated resin curing, and conversion of 

open molding processes to closed molding. We are soliciting 

information on other pollution-prevention techniques of 

which we are not aware, and information on the maximum level 

of emissions reductions achievable by these techniques. 

The general concept of an alternative would be a 

facility that elects to use this option to submit 

notification to the appropriate permitting authority of 

their intent. The facility would then have to submit a plan 

to meet specific emissions reductions through pollution 

prevention. The plan would outline the techniques they 

intend to use', the research and testing required, and a 

schedule with annual milestones for achieving the goal. 

In the next step, the facility would calculate an 

overall emission factor for all processes at the facility 

that are required to meet the 95 percent emission reduction. 

Once a facility has determined a base year emission 
P.50 

48 

factor, they would be required to incorporate the pollutionprevention techniques outlined in the plan and make annual 

reports of progress. If a facility was unable to meet an 

interim milestone, they would be required to provide an 

updated plan within a specified time. 

We are also soliciting comment on determination of a 

base year and baseline emission factor, and reporting 

requirements. 

G. Did we consider control options more stringent than the 

MACT floor? 

For existing sources, an above-the-floor control level 

was evaluated which was based on the new source floor for 

sources with emissions of 100 tpy or more. This above-thefloor control level would require 95 percent control of HAP 

emissions from all open molding, centrifugal casting, 

continuous lamination/casting, pultrusion, SMC 

manufacturing, and resin mixing/BMC manufacturing. 

We then looked at several options. These were 

selecting the floor level of control as MACT for all 

facilities, selecting the above-the-floor level as MACT for 

all facilities, or choosing an alternative where facilities 

at or above a certain HAP emissions quantity would meet the 

above-the-floor level, and the rest would meet the floor. 

In looking at this third alternative, we also evaluated 

different HAP emission thresholds. 

The option of having all facilities meet the above-the-
P.51 

49 

floor level of control had an incremental cost effectiveness 

ratio of $4,3 00 per ton of HAP emission reduction. The 

economic analysis for this option indicated that 126 small 

businesses would be impacted at a level of 3 percent of 

sales or more, and there were 90 projected closures of small 

businesses. We believe that the benefit of controlling all 

existing sources to this level is not commensurate with the 

economic impacts. Therefore, we are not proposing this 

alternative as MACT. 

We then looked at a combination of the MACT floor for 

facilities below a specified HAP emissions quantity based on 

actual emissions prior to any add-on controls, and the 

above-the-floor level of control for larger-emitting 

facilities. We also examined the impacts from the 

standpoint of small businesses and their ability to obtain 

the capital to purchase pollution control equipment. We 

believe that the capital costs of the above-the-floor option 

for most small businesses would be prohibitive because they 

do not have the same access to capital as large businesses. 

The available data indicate that at a threshold of 250 tpy, 

none of the existing small businesses in the data base would 

be impacted significantly by the above-the-floor control 

level. For this reason, we determined MACT for small 

businesses to be the floor for facilities that emit less 

than 250 tpy of HAP, and the above-the-floor control level 

for facilities that emit 250 tpy or more. For large 
P.52 

50 

businesses, we determined MACT to be the floor for 

facilities that emit less than 100 tpy of HAP, and the 

above-the-floor control level for facilities that emit 100 

tpy or more of HAP. The incorporation of the 250 tpy 

threshold for small businesses was one of the 

recommendations of the SBAR Panel, and the economic impacts 

of the selected option are reasonable. 

Industry representatives independently developed costs 

for add-on controls and submitted them to the Agency. Their 

analysis is in the docket for this proposed rulemaking. The 

SBAR Panel recommended that we reconsider our estimates of 

costs for add-on controls in light of that study. The 

industry cost estimates are at least three times higher than 

our cost estimates. The major reason for these differences 

in cost are the design assumptions for the permanent total 

enclosures and the estimated air flows. Our cost estimates 

assume an inlet concentration of 100 parts per million by 

volume (ppmv). The industry'study assumes lower 

concentrations that vary based on the specific facility. 

However, available test data for measured concentrations in 

the exhaust streams for reinforced plastic composites 

facilities range from 61 to 249 ppmv, with an average 

concentration of 120 and a median of 82. Based on this, we 

believe our 100 ppmv estimate is still reasonable, and we 

have decided not to revise our cost analysis at this time. 

We will review the industry's cost analysis in more depth 
P.53 

51 

following proposal, and make any appropriate changes based 

on our review and on comments we receive. We are soliciting 

comment on the cost and feasibility of add-on controls, data 

on design and operation of permanent total enclosures from 

this or similar industries, and data on typical exhaust HAP 

concentrations and air flows for reinforced plastic 

composite facilities. 

We did not identify an above-the-floor option for the 

following operations: closed molding, polymer casting, and 

equipment cleaning. We were able to find no examples where 

any closed molding process was controlled using add-on 

controls. Therefore, we believe it is not technically and 

economically feasible to use add-on controls for closed 

molding processes. We do not believe it is technically 

feasible to use add-on controls for equipment cleaning 

operations. In any case, application of the floor level of 

control we are proposing would eliminate HAP-containing 

cleaners, except for cases where cured resin has to be 

removed from application equipment. This floor level of 

control would achieve close to 100 percent HAP emissions 

reductions. 

For new sources, we examined an above-the-floor option 

of requiring all sources to meet the 95 percent control 

requirement for open molding, centrifugal casting, 

continuous lamination/casting, pultrusion, SMC 

manufacturing, and resin mixing/BMC manufacturing. We 
P.54 

52 

determined that, even if we could resolve the issues 

surrounding the performance of add-on control devices at the 

smaller-emitting sources, the incremental cost effectiveness 

ratio would be $15,000 per ton of HAP emissions reduction. 

For this reason, we chose the floor level of control as MACT 

for new sources. 

We also considered an above-the-floor control level for 

both existing and new sources of combining the pollutionprevention techniques of the existing source floors with a 

95 percent control requirement. As previously discussed, 

the benefits of this approach would be that by incorporating 

the pollution-prevention measures, the overall emission 

reduction would be increased. In addition, the potential 

for worker exposure in these situations would be reduced. 

However, we determined the incremental emission reduction 

for this control level was approximately 2 percent of 

baseline. Based on the costs of meeting existing source 

floors, the cost effectiveness ratio of this small 

additional benefit would be $36,900 per ton of HAP emission 

reduction. Though there may be worker exposure benefits, we 

did not include this above-the-floor control level in this 

proposed rule. This possibility is still under 

consideration and we are are requesting comment. We also 

request that commentors provide any available data on worker 

exposure that would allow us to quantify the additional 

worker exposure benefits of incorporating pollution-
P.55 

53 . 

prevention requirements with the 95 percent control 

requirements. 

We did not identify an above-the-floor option for new 

sources for the following operations: closed molding, 

polymer casting, and equipment cleaning for the same reasons 

as discussed above for existing sources. 

We also examined an above-the-floor control option for 

existing sources based on pollution prevention. As was the 

case with the new source MACT floor, we are unable at this 

time to develop an alternative that we believe meets the 

statutory requirements of MACT. However, we are 

specifically soliciting comments on pollution-prevention 

techniques that could be used in lieu of the above-the-floor 

alternative as were discussed in the section on new source 

floors. 

H. Why are some reinforced plastic composites production * 

operations not subject to these proposed NESHAP? 

These proposed NESHAP would not;regulate mold sealing 

and release agents and mold, stripping and cleaning solvents 

because we were unable to set MACT floors or determine MACT 

for these operations. In both cases, the information and 

data available to us suggest that mold maintenance 

practices, part shape and size, and production schedules 

determine emissions more than the HAP content of these 

materials. We do not have sufficient data to identify and 

prescribe work practices to reduce emissions from these 
P.56 

54 

operations. Therefore, these proposed NESHAP do not require 

controls for these materials. 

For mold stripping and cleaning solvents, the amount of 

HAP used per unit of mold surface area applied depends on 

facility-specific mold maintenance practices and production 

requirements. These may include mold cycle time, how often 

the mold is used, and whether the mold is stored indoors or 

outdoors. The size of the part may.also influence mold 

maintenance. We do not have sufficient data to identify 

those differences in production requirements or work 

practices that determine mold cleaning solvent usage. 

Therefore, we cannot identify a MACT floor or MACT. 

I. How did we select the form of these proposed NESHAP? 

We decided to offer several forms for complying with 

the proposed NESHAP. The purpose of multiple forms is to 

provide the flexibility to comply in the most cost-effective 

and efficient manner. We considered the following factors 

in selecting the form of the proposed NESHAP: 

• The form should allow for multiple compliance 

techniques for the various types of facilities in 

the industry. 

• The form should simplify compliance and ensure 

that the cost of compliance is not excessive. 

• The form should be enforceable. 

The form of these proposed NESHAP is based on a 

combination of emission limits (point values or percent 
P.57 

55 

reduction), equipment standards, and work practice 

standards. 

1. Emission Limits Based on Point Values 

These proposed NESHAP for open molding operations and 

centrifugal casting operations are based on point values 

which are in units of pounds of HAP per ton of resin used. 

The point value development has been previously described. 

This form was chosen over an absolute emission limit because 

it accurately determines the amount of pollution-prevention 

control a source has incorporated in its process, but does 

not require a facility to perform emission testing. This 

form also allows for averaging across open molding processes 

or across centrifugal casting processes. This means that a 

source has the option to over-control some operations, 

under-control others (relative to the limit for that 

individual process), but still meet the overall limit for 

such operations combined. This allows a source to have 

additional flexibility in meeting the proposed standards. 

The emission limits for open molding and centrifugal 

casting for new sources are based on a percent reduction 

using add-on controls. However, we have provided an 

alternative standard for new sources also based on point 

values. These point values were determined by applying the 

required percent reduction requirement to the existing 

source MACT floors. The new source floor is based on a 

control efficiency, and the facilities that have these 
P.58 

56 

controls do not have examples of every possible type of open 

molding or centrifugal casting process. Therefore, we were 

not able to use the best-controlled sources to directly 

determine a point value that is equivalent to the 95 percent 

emissions reductions requirement for all operations. For 

operations where we could directly determine a point value 

equivalent, the approach of using existing source floors and 

applying 95 percent control is slightly more stringent. 

Therefore, we believe applying this approach to all open 

molding and centrifugal casting operations will produce a 

limit that is no less stringent, while providing 

opportunities for facilities to incorporate pollution 

prevention- into their process, meet a percent reduction 

requirement less than 95 percent, but still meet the new 

source floor. 

2. Emission Limits Based on Percent Reduction 

The form of the standards for new open molding, 

centrifugal casting, SMC manufacturing, and resin/mixing/BMC 

manufacturing, and the standards for new and existing 

sources for pultrusion and SMC manufacturing are based on a 

percent reduction. These standards were all developed from 

facilities using add-on controls. It is possible to design 

a control device to meet a specified percent reduction. But 

based on the data available, it was not possible to 

determine an uncontrolled emission factor for open molding, 

centrifugal casting, SMC manufacturing, and mixing/BMC 
P.59 

57 

manufacturing that was generally applicable. Therefore, we 

could not develop a standard based on an emission factor. 

For continuous lamination/casting, we were able to develop 

an absolute emission limit based on the facilities that set 

the floor. These absolute emission limits are presented as 

alternatives to the percent reduction limits. In the case 

of pultrusion operations, there are alternative standards 

based on wet-area enclosures or direct die injection. 

Emission testing has determined that using this equipment as 

specified in the proposed rule will achieve the percent 

reductions specified in the NESHAP. 

3. Emission Limits Based on Equipment/Work Practice 

Standards 

Section 112(h) of the CAA states that ". . . if it is 

not feasible in the judgement of the Administrator to 

prescribe or enforce an emission standard for control of a 

hazardous air pollutant or pollutants, the Administrator 

may, in lieu thereof, promulgate a design, equipment, work 

practice, or operational standard, or combination thereof . 

. .." Section 112(h)(2) further defines the phrase "not 

feasible to prescribe or enforce an emission standard" as 

any situation in which ". . .a hazardous air pollutant or 

pollutants cannot be emitted through a conveyance designed 

and constructed to emit or capture such pollutant, .. . or 

the application of measurement methodology to a particular 

class of sources is not practicable due to technological and 
P.60 

58 

economic limitations." 

The emission limits for equipment cleaning and storage 

at new and existing sources are based on work practice and 

equipment standards. The reason for choosing work practice 

and equipment standards for storage is that storage areas 

may be located outside the rest of the production area, and 

in some cases, may be located outside the building. We do 

not believe it would be practicable due to economic 

limitations to test storage areas, and we do not have 

sufficient data to calculate an emission limit for the 

required work practice. 

The standard for existing pultrusion facilities is 

based on the equipment standard combined with a work 

practice. We have proposed the standard as a percent 

reduction to allow the use of add-on controls. However, we 

do not believe it would be technologically or economically 

feasible to actually test facilities that choose to use a 

wet-area enclosure or direct die injection. 

The limits for SMC and resin mixing/BMC at existing 

facilities are also based on work practices or equipment 

standards. We have no data to determine a specific percent 

reduction to the work practices for these operations. 

Therefore, we could not set a specific emission limit. 

Cleaning operations may take place outside the regular 

production area. It would not be technologically or 

economically practicable to perform emission testing for 
P.61 

59 

cleaning operations. 

4. Selection of Averaging Time for Demonstrating Compliance 

As a reinforced plastic composites manufacturer, we are 

proposing that you could would show compliance with the 

%_^_^_^_^_^_(%_^_£ 

proposed NESHAP on a 12-month, rolling-average basis. Under 

this proposed rule, you could would determine compliance at 

the end of each month from the data collected over the past 

12 months. We believe a 12-month averaging time provides a 

balance between operating flexibility and enforceability of 

the proposed standards. The 12-month period is sufficiently 

long so that you can identify potential compliance problems 

and change your operations in time to maintain compliance. 

The rolling-average aspect provides an enforceable emission 

limit 12 times per year. 

Many reinforced plastic composites manufacturers 

already track material usage monthly to comply with State 

regulations and permit requirements, so we believe monthly 

tracking is consistent with current practice. Tracking on a 

more frequent basis would be unnecessarily burdensome for 

this particular industry. Reinforced plastic composites 

manufacturers need a 12-month rolling-average period to 

respond to both short-term variations in HAP content that 

are inherent in all chemical products, and to account for 

short-term needs for higher-HAP materials due to variations 

in product mix. 

In order—to calculate a 12-month rolling average, 
60 

facilities rnufcl have 12 months of data. The CAA requires 

existiiiy—sources—to be in compliance no—later—than 3—years 

after—the publication date. It also authorizes EPA—to 

establish dn earlier—compliance date. In order—to make it 

clear—and legally—enforceable—that facilities must begin 

collecting data at—two years after—final rule publication, 

the compliance date for—facilities—that must comply—with a 

12-month rolling average is—two years. We have no reason—to 

believe that a—two year—compliance date in not achievable.— 

The nonatoiuized application technologies and low HAP resins 

and gel coats appear—to currently be widely available.— 

Facilities—the must meet a 12-month rolling averaye still 

have 3 years to demonstrate comp 11ance. 

J. How did we select the proposed test methods for 

determining compliance with the proposed NESHAP? 

The proposed NESHAP have several options for achieving 

compliance. For open molding and centrifugal casting, this 

includes meeting a specified point value for existing . 

sources, or a percent reduction or point value for new 

sources. For most other processes, you achieve compliance 

by using an enclosure and add-on control device to meet a 

percent reduction requirement or an absolute emission limit. 

In order to calculate a point value, under this 

proposed rule, you must determine the HAP content of the raw 

material. The method to determine material HAP content is 

the use of the Material Safety Data Sheets (MSDS) or other 
P.63 

61 

product specification sheets provided by the material 

manufacturer. We chose not to propose requiring testing of 

the material. The data used to develop the standards were 

mainly based on MSDS; therefore, we believe it is reasonable 

that MSDS be used to determine compliance. 

Under the proposed NESHAP, if you chose to use an 

enclosure and add-on control device, you would have to 

determine the capture efficiency of the enclosure and 

measure the HAP from the control device. To determine the 

capture efficiency of the enclosure, you would use EPA 

Method 204 (Criteria for and Verification of Permanent or 

Temporary Total Enclosure). If the enclosure meets the 

criteria in EPA Method 2 04 for a permanent total enclosure, 

then you could.assume that its capture efficiency is 100 

percent. If the enclosure is not a total enclosure, then 

you would build a total temporary enclosure around it that 

meets the definition of a total temporary enclosure in EPA 

Method 204. You would then have to measure emissions from 

both the control device and the total temporary enclosure 

and use the combined emissions to determine compliance. 

To measure HAP, you would be able to use either EPA 

Method 18 (Measurement of Gaseous Organic Compound Emissions 

by Gas Chromatography) to measure the sum of individual 

species of HAP, or EPA Method 25A (Determination of Total 

Gaseous Organic Matter Concentration Using a Flame 

Ionization Analyzer) for total hydrocarbons (THC) as a 
P.64 

62 

surrogate for total HAP. The EPA Method 25A would allow you 

the flexibility to use a simpler method than EPA Method 18 

which does not speciate HAP in cases where measuring THC is 

sufficient to demonstrate compliance. You could measure THC 

as a surrogate for total HAP if most of the THC emitted from 

an enclosure were HAP, such as styrene and MMA from resin 

and gel coat operations. For compliance determinations, the 

EPA will assume that all THC measured with EPA Method 25A 

are HAP. 

We have not included in this proposed rule a test 

method for determining the effectiveness of vapor suppressed 

resins. A draft protocol entitled "Vapor Suppressant 

Effectiveness Test Protocol," dated April 7, 1999, has been 

developed by industry and is available for review in the 

docket for this proposed rule. The draft protocol is 

insufficiently detailed for inclusion in this proposed rule. 

We are currently requesting additional details and 

soliciting comment on the test protocol or an alternate test 

protocol. 

K. How did we determine the gaop^^^Smoni tormq and. 

recordkeeping requirements? 

Which monitoring and recordkeeping requirements you 

would meet depend on how you choose to comply with these 

proposed NESHAP. For each compliance option, the proposed 

monitoring and recordkeeping requirements are the minimum 

necessary to determine initial and ongoing compliance and 
P.65 

63 

are consistent with the General Provisions (40 CFR part 63, 

subpart A) . 

This section describes how to comply with emission 

limits based on point values, emission averaging provisions, 

equipment and work practice standards, and the emission 

limit for an add-on control device. 

1. Compliance with Emission Limits Based on Point Values 

For all operations subject to HAP content limits, we 

are proposing four tasks: monitor and record the HAP 

content of the material used, monitor and record the monthly 

consumption of the material, monitor and record which 

operations use the material, and record the computations to 

show that the weighted average point value over the past 12 

months meets the proposed standards. 

The SBAR Panel recommended that we look for 

alternatives to simplify reporting and recordkeeping. We 

have identified two alternatives we believe simplify the 

reporting and recordkeeping process. The first is that an 

owner and operator may use purchase records to determine 

monthly consumption. However, an owner and operator can 

track actual material flows to each process if desired. We 

believe this is reasonable because facilities have no 

financial incentive to keep significant inventories of raw 

material on hand, and we have no evidence that keeping large 

amounts of raw material on hand is a common practice. 

Therefore, purchases and actual consumption should track 
P.66 

64 

fairly closely. We are requiring that the owner and 

operator have a reasonable method to estimate the amounts of 

each resin used by a specific operation. The second 

alternative applies where all the materials used in an 

operation result in a point value that meets the emission 

limit, in which case, an owner and operator only need to 

record HAP content and the resulting point value and do not 

need to track monthly consumption of each individual 

material. 

2. Compliance with Averaging Provisions 

To comply with the averaging provisions for open 

molding operations and centrifugal casting operations, you 

must monitor and record HAP content as well as how use of 

the material is split between different operations, and you 

must record the computations needed to show compliance. You 

must use these data as well as the MACT model point value 

equations in the proposed NESHAP to calculate the point 

values in that operation for the past 12 months. Compliance 

is then determined relative to the allowable weighted 

average point value calculated for those operations for the 

past 12 months. Compliance would be calculated monthly, and 

monthly purchase records may be used to determine resin and 

gel coat use. 

3. Compliance with Equipment and Work Practice Standards 

The proposed NESHAP require resin and gel coat mixing 

containers to be fitted with covers that have no visible 
P.67 

65 

gaps. You will be required to inspect container covers each 

month to ensure the covers are in place and properly 

maintained. You must record the results of the inspections. 

The inspections should be sufficient to ensure that the 

covers are in place and properly maintained. We believe 

monthly inspections are a reasonable interval because the 

nature of failure in these pieces of equipment is likely due 

to wear and tear and not a sudden failure. Longer time 

periods between inspections, however, would allow a failure 

to go too long before being repaired. 

The proposed NESHAP for production resin and tooling 

resin requires most manufacturers to use nonatomized resin 

application methods to comply. These methods include 

flowcoaters and pressure-fed resin rollers, among others. 

We could identify no parameters to monitor whether these 

methods are being used. Rather, compliance through the use 

of these methods would be determined during enforcement 

inspections. As long as flowcoaters, pressure-fed resin 

rollers, or other similar devices are installed and operated 

according to manufacturer's specifications, they will comply 

with the requirements to use nonatomized resin application 

methods. 

4. Compliance for Sources Using Enclosures and Add-On 

Control Devices 

The requirements for enclosures and add-on control 

devices in the proposed NESHAP are consistent with other air 
P.68 

66 

quality regulations that require capture and control of 

emissions. They are the minimum needed to demonstrate that 

the capture and control system is operated properly. 

We are proposing that you must initially demonstrate 

compliance with the emission limit by demonstrating that the 

enclosure is a total enclosure or by also measuring the 

fugitive emissions that escape the enclosure. You would 

also need to measure the efficiency of the add-on control 

using EPA Method 25A for THC (as a surrogate for HAP) or EPA 

Method 18 for HAP. The EPA Method 18 measures individual 

HAP that you sum to calculate total HAP. 

After the initial compliance test, we are proposing 

that you must monitor control device parameters to 

demonstrate that the control device continues to be operated 

as it was during the initial test. In the case of thermal 

oxidizers, you would need to monitor and record combustion 

temperature every 15 minutes both during and after the 

performance test. We are proposing that you must calculate 

the average temperature achieved during the test. After the 

test, you would need to maintain the average temperature at 

or above the temperature achieved during the performance 

test. Temperature monitors and recorders are standard 

features on thermal oxidizers. For other devices we are 

proposing that you must determine appropriate parameters to 

monitor and receive our approval to use these parameters. 

L. How did we select the proposed •notification and 
P.69 

67 

reporting requirements? 

We believe that the proposed notices and reports are 

the minimum needed to determine if you are subject to the 

proposed NESHAP and whether you are in compliance. We are 

proposing that you must submit an initial notification 

stating that you are subject to the proposed NESHAP. After 

the compliance date for your facility, you would need to 

submit a notification of your compliance status. You would 

also need to submit semiannual reports of your compliance 

status. If you have an add-on control device and you become 

out of compliance, we are proposing that you must submit 

quarterly reports of your compliance status until we approve 

a request to return to semiannual reporting. 

If your facility is a new source, we are proposing that 

you have additional preconstruction notification 

requirements. You would also have additional notification 

and reporting requirements if you use an add-on control 

device, including notifications and reports for the control 

device performance test. These proposed notification and 

reporting requirements are consistent with those specified 

in the General Provisions. We believe that these 

requirements are the minimum needed for us to determine 

compliance for sources with add-on control devices. 

The SSM plan specified by the General Provisions will 

be required only for sources using an add-on control device 

and will apply only to the add-on control device. For 
P.70 

68 

operations not using a control device, the nature of the 

materials and equipment used to comply with the proposed 

Reinforced Plastic Composites Production NESHAP is such that 

malfunctions will not lead to excess emissions. 

M. What are some of the areas where we are specifically 

soliciting comments? 

The purpose of this section is to highlight particular 

issues of concern to the EPA or to other parties. We 

solicit comments on these issues, along with data to support 

the comments. 

The proposed rule requires that certain new and 

existing sources control HAP emissions by 95 percent. In 

order to meet this requirement, facilities will likely have 

to capture 100 percent of their emissions from the affected 

processes and route these emissions to an add-on control 

device. We are soliciting data on the technical feasibility 

of permanent total enclosures (PTE) ,- factors that affect the 

feasibility of PTE such as product size, operation grouping, 

and vent stream concentrations and air flow from the 

processes where capture systems are used; and interactions 

of these requirements with OSHA rules. For example, the 

feasibility of 100 percent emissions capture using PTE is 

based on data from two facilities. We believe that the 

process operations in these facilities are representative of 

the industry as a whole. However, we are soliciting comment 

on types of facilities that may not be able to apply PTE, 
P.71 

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 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. 

The proposed rule sets different thresholds for 

existing source requirements at small versus large 

businesses, above which control of HAP emissions by 95 

percent is required. The higher threshold for small 

businesses is based on concerns that it is more difficult 

for small businesses to raise the necessary .capital to 

purchase add-on controls to comply with the 95 percent 

control level. We solicit comments on this conclusion, 

along with data on capital availability for large and small 

businesses and the impact of this threshold on large 

businesses. We solicit information and data on other 

factors to consider in evaluating control requirements more 

stringent than the MACT floor, including data on costs to 

the industry. 
P.72 

70 

We believe that we have captured the full range of 

processes and products in our proposed operation groups. We 

request comments with supporting data on any processes or 

products that might not be adequately represented. Along 

these lines, we have specifically provided separate process 

groups for products with a Class I smoke and fire rating, 

and have defined high strength products as part of the 

corrosion resistant process group because of specific 

product requirements that require specialized raw materials. 

We solicit comments on this approach and data on any 

additional processes or products that have unique properties 

that may require separate process groupings for MACT floor 

development. 

This proposed rule contains point value equations for 

open molding and centrifugal casting. We are soliciting 

comments on the data and assumptions used to develop MACT 

point value equations, and information on other methods or 

emission models that could be used to rank facilities for 

the purposes of setting MACT. 

The proposed rule allows tha t open molding and 

centrifugal casting operations _loikf_^§£^§tl_S_^^f^^_^^_lf__^_^ 

a rolling 12-monBh>period. In order to demonstrate 

bgjmglfcm_cj^_b^ 

ithe^^final^jr^^ must meet 

a point value on a 12-month rolling average be in compliance 

2 years after publication of—the final rule. The reason is 
P.73 

71 

that in order—to have 12 months of data available -- i.e. 

:arting two years from publication, to calculate the 

averaye at 3 years after—final rule publication,—facilities 

would need to be rn coiuplranee and collec tiny data 2 years 

after—final rule publication. We are soliciting comment 

with supporting data on w^^^^^^^SfwilRiif^ii&i^^SwsfeiSiB 

p^bl^c;at^Ptn_ja^;a.the selection of a 2 year—compliance date for 

these specr f re cases. We considered other options for tliese 

operations. One option was a 3 year—compliance date,—and 

basing compliance on a cumulative averaye until 12 months 

had passed. However,—this would reduce the flexibility of 

the average until 12 months had been reached. We also 

considered a 3 year—compliance date,—with an additional—3r2-

months—to demonstrate compliance. We rejected—this 

alternative because it would potentially allow—facilities—to 

exceed the emission limits based on point values after—the 3 

'ear compliance date mandated in the CAA.We^arg4also 

We also solicit information on the adequacy or 
P.74 

72 

necessity 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. 

IV. Summary of Environmental, Energy, and Economic Impacts 

A. What facilities are affected by the proposed NESHAP? 

There are approximately 433 existing facilities 

manufacturing reinforced plastic composites that are major 

sources and would be subject to the proposed NESHAP. The 

rate of growth for the reinforced plastic composites 

industry is estimated to be 84 new facilities over the next 

5 years. 

B. What are the air quality impacts? 

The 1997 baseline HAP emissions from the reinforced 

plastic composites industry are approximately 22,200 tpy. 

The proposed NESHAP would reduce HAP from existing sources 

by 14,500 tpy, a reduction of 65 percent. 

The proposed NESHAP would result in small increases in 

other air pollution emissions from combustion devices that 

will be installed in the next 5 years to comply with today's 

proposed rule. These increases result from both the 

combustion device directly, and estimated emissions that 

occur at electrical generating plants to generate the 

electricity necessary to operate the add-on controls and 
73 

associated air handling equipment. These emissions are 

estimated to be 38 tpy of sulfur oxides (SOx), 69 tpy of 

nitrogen oxides (NOx), 125 tpy of carbon monoxide (CO), and 

1.5 tpy of particulate matter (PM) emissions. 

C. What are the water quality impacts? 

We estimate that the proposed Reinforced Plastic 

Composites Production NESHAP will have no adverse water 

quality impacts. We do not expect anyone to comply by using 

add-on control devices or process modifications that would 

generate wastewater. 

D. What are the solid and hazardous waste impacts? 

We estimate that the proposed NESHAP would decrease the 

amount of solid waste generated by the reinforced plastic 

composites industry by approximately 1,400 tpy. The 

decrease in solid waste is directly related to switching to 

nonatomized resin application equipment (i.e., flowcoaters 

and resin rollers). Switching to flowcoaters results in a 

decrease in overspray because of a greater transfer 

efficiency of resin from flowcoaters to the part being 

manufactured. A decrease in resin overspray consequently 

reduces the amount of waste from disposable floor coverings, 

cured resin waste, and personal protective equipment (PPE) 

for workers. Disposable floor coverings are replaced on a 

periodic basis to prevent resin buildup on the floor. We 

estimate that solid waste generation of floor coverings will 

decrease by approximately 360 tpy and that cured resin solid 
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waste will decrease by approximately 1,040 tpy. 

We project that the decreased overspray from 

flowcoaters will result in a decreased usage of PPE, which 

also consequently reduces the amount of solid waste. 

Workers who use flowcoaters typically wear less PPE than 

when using spray guns because of the reduced presence of 

resin aerosols and lower styrene levels in the workplace. 

Because we did not have information on the many different 

types of PPE currently used, we did not estimate this 

decrease in solid waste. 

Some facilities that switch from spray guns to 

flowcoaters may have a small increase of hazardous waste 

from the used flowcoater cleaning solvents. However, most 

facilities would not see an increase under this proposed 

rule, and the overall impact on the industry will be small 

relative to the solid waste reductions. Nearly all 

flowcoaters require resin and catalyst to be mixed inside 

the gun (internal-mix) and must be flushed when work is 

stopped for more than a few minutes. External-mix spray 

guns do not need to be flushed because resin is mixed with 

catalyst outside the gun. Facilities that switch from 

external-mix spray guns to flowcoaters will use more 

solvent. Solvent usage should not change at facilities 

switching from internal-mix spray guns to flowcoaters. The 

most common flushing solvents are acetone and water-based 

emulsifiers. Only a couple of ounces of solvent are 
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75 

typically needed to flush the mixing chamber and nozzle of 

flowcoaters and internal-mix spray guns. 

We do not have adequate data to predict the potential 

solvent waste impact from switching to flowcoaters. The 

magnitude of the impact depends on the type of gun currently 

used (internal- or external-mix), the frequency of flushing, 

and the type of solvent used. However, because of the small 

amount of solvent used, and since most is allowed to 

evaporate, we believe the overall solvent waste increase 

will be small compared to the solid waste reductions. 

E. What are the energy impacts? 

We determined that the overall energy demand for 

operations in the Reinforced Plastic Composites Production 

source category could increase by 159 million standard cubic 

feet per year of natural gas, and 10 million kilowatt hours 

of electricity per year as a result of the proposed rule. 

We determined this net increase based on the additional 

energy demand for control devices installed to meet the 

proposed standards. No information for comparison is 

available on the baseline energy consumption for this source 

category. 

F. What are the cost impacts? 

We have estimated the capital costs for emission 

control equipment, including equipment such as open 

container covers, resin bath enclosures, capture systems, 

and control devices as $73.9 million for existing sources 
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76 

and $11.7 million for new sources. The capital costs 

include the costs to purchase and install the control 

equipment. 

We have estimated that annual costs of the proposed 

rule are $26.0 million per year for existing sources and 

$3.2 million for new sources. Annual costs include fixed 

annual costs, such as reporting, recordkeeping and capital 

amortization, and variable annual costs such as natural gas. 

The estimated average cost effectiveness ratio of the 

proposed rule is $1,600 per ton of HAP emissions reduction 

for existing sources and $2,200. per ton of HAP emissions 

reduction for new sources. 

As discussed elsewhere in this preamble, we will review 

in more depth the industry's analysis on the cost of this 

proposed rule following proposal. Where appropriate, we 

will make changes to our estimates of costs based on our 

review and on comments we receive, and make the results of 

our detailed review available in the public docket at 

promulgation. 

G. What are the economic impacts? 

The Agency conducted a detailed economic impact 

analysis to determine the market- and industry-level impacts 

associated with the proposed rule. We expect the aggregate 

price increase for reinforced plastic composites would be 

only 0.3 percent, or $0.01 per pound, as a result of the 

proposed standards. We project that directly affected 
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77 

producers would reduce total production by 0.8 percent, 

while producers not directly affected would increase their 

production by 0.3 percent. Markets for reinforced plastic 

composites used in general construction, corrosion-resistant 

products, and land transportation are expected to be more 

heavily impacted with price increases of up to 0.5 percent 

and reductions in directly affected domestic production of 

between 1 and 1.5 percent. 

In terms of industry impacts, captive producers of 

reinforced plastic composites are expected to fully absorb 

their compliance costs, while merchant producers will 

attempt to pass through costs to their customers. Through 

the market impacts described above, the proposed NESHAP 

create both gainers and losers within the merchant segment. 

Some merchant facilities are projected to experience profit 

increases with the proposed rule; however, the majority that 

continue operating are projected to lose profits. 

Furthermore, the economic impact analysis indicates that 29 

out of 299 merchant facilities (9.7 percent) and 73 out of 

471 product lines (15.5 percent) at these facilities are at 

risk of closure because of the proposed NESHAP. All of the 

facilities determined to be at risk for closure are believed 

to be small businesses. More information on the measures we 

have taken to minimize these impacts may be found in section 
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IV-F which discusses the Regulatory Flexibility Act. 

Based on the market analysis, the annual social costs 

of the proposed rule are projected to be $25.7 million. 

These costs are distributed across the many consumers and 

producers of reinforced plastic composites. Producers, in 

aggregate, are expected to bear $10.6 million annually in 

costs, with those directly affected by the proposed NESHAP 

losing $19.3 million and those not subject to the proposed 

NESHAP gaining $8.7 million. The consumers of reinforced 

plastic composites are expected to incur the remaining $15.1 

million in costs associated with the proposed NESHAP. For 

more information, consult the docket for this project. 

V. Relationship of Proposed NESHAP to Other Standards and 

Programs under the CAA 

A. National Emission Standards for Closed Vent Systems, 

Control Devices. Recovery Devices, and Routing to a Fuel Gas 

System or a Process (40 CFR Part 63. Subpart SS) 

If you use an add-on control device(s) to control 

emissions, you will need to comply with certain provisions 

in 40 CFR part 63, subpart SS, for add-on controls. The 

standards in subpart SS cited by the proposed NESHAP are 

applicable to most sources using an add-on control device. 

The proposed NESHAP cite these sections in subpart SS rather 

than repeating them in the proposed regulatory text. 

B. Operating Permit Program 
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79 

Under the operating permit program codified at 40 CFR 

parts 70 and 71, all major sources subject to standards 

under section 111 or 112 of the CAA must obtain an operating 

permit (See §§70.3(a)(1) and 71.3(a)(1)). Therefore, all 

major sources subject to these proposed NESHAP must obtain 

an operating permit. 

Some reinforced plastic composites production 

facilities may be major sources based solely on their 

potential to emit even though their actual emissions are 

below the major source level. These facilities may choose 

to obtain a federally enforceable limit on their potential 

to emit so that they are no longer considered major sources 

subject to the proposed NESHAP. Sources that opt to limit 

their potential to emit (e.g., limits on operating hours or 

amount of material used) are referred to by the EPA as 

"synthetic area" sources. To become a synthetic area 

source, you must contact your local permitting authority to 

obtain an operating permit with the appropriate operating 

limits. These operating limits will then be federally 

enforceable under 40 CFR 70.6(b). 

C. NESHAP for Plastic Parts and Products 

There are currently NESHAP under development for 

proposal that will regulate coating of plastic parts and 

products. The SBAR Panel recommended that we consider the 

interaction of the Plastic Parts and Product NESHAP with 

today's proposed NESHAP. The Plastic Parts and Products 
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NESHAP may potentially affect facilities that produce 

reinforced plastic parts and then apply a coating to the 

finished parts. We have coordinated with this project and 

have determined that there should be no overlap (i.e., 

specific operations covered by today's proposed NESHAP 

should not also be covered in the Plastic Parts and Products 

NESHAP). We have not determined any requirements of the 

proposed NESHAP that would overlap, conflict, or cause a 

duplication of effort. 

VI. Administrative Requirements 

A. Executive Order 12866: Regulatory Planning and Review 

Under Executive Order 12866 (58 FR 51735, October 4, 

1993), we must determine whether a proposed regulatory 

action is "significant" and therefore subject to Office of 

Management and Budget (OMB) review and the requirements of 

the Executive Order. The Executive Order defines 

"significant regulatory action" as one that is likely^ to 

result in a rule that may: 

(1) Have an annual effect on the economy of $100 

million or more or adversely affect in a material way the 

economy, a sector of the economy, productivity, competition, 

jobs, the environment, public health or safety, or State, 

local, or tribal governments or communities; 

(2) Create a serious inconsistency or otherwise 

interfere with an action taken or planned by another agency; 

(3) Materially alter the budgetary impact of 
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81 

entitlements, grants, user fees, or loan programs or the 

rights and obligations of recipients thereof; or 

(4) Raise novel legal or policy issues arising out of 

legal mandates, the President's priorities, or the 

principles set forth in the Executive Order. 

Pursuant to the terms of Executive Order 12866, the EPA 

has submitted this action to OMB for review. Changes made 

in response to suggestions or recommendations from OMB will 

be documented and included in the public record. 

B. Paperwork Reduction Act 

The information collection requirements in this 

proposed rule have been submitted for approval to the OMB 

under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. 

An ICR document has been prepared by EPA (ICR No. ) and a 

copy may be obtained from Sandy Farmer by mail at the Office 

of Environmental Information, Collection Strategies Division 

(2822), U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, 

DC 20460, by e-mail at "farmer.sandy@epa.gov," or by calling 

(202) 260-2740. A copy may also be downloaded from the 

internet at "http://www.epa.gov/icr." 

These proposed NESHAP contain monitoring, reporting, 

and recordkeeping requirements. We believe that the 

proposed notices and reports are the minimum needed by us to 

determine if you are subject to the NESHAP and whether you 

are in compliance. We believe the proposed recordkeeping 

requirements are the minimum necessary to determine initial 
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and ongoing compliance. Based on reported information, we 

would decide which reinforced plastic composites facilities 

and what records or processes should be inspected. The 

recordkeeping and reporting requirements are consistent with 

the General Provisions of 40 CFR part 63. 

These proposed recordkeeping and reporting requirements 

are specifically authorized by section 114 of the CAA (42 

U.S.C. 7414). All information submitted to us for which a 

claim of confidentiality is made will be safeguarded 

according to our policies in 40 CFR part 2. 

The EPA expects these proposed NESHAP to affect a total 

of approximately 486 facilities over the first 3 years after 

promulgation of the rule. This includes 433 existing 

facilities, and 53 new reinforced plastic composites 

facilities will become subject to the proposed NESHAP during 

the first 3 years. 

The estimated average annual burden for the first 3 

years after promulgation of these proposed NESHAP for 

industry and the implementing agency is outlined below. You 

can find the details of this information collection in the 

"Standard Form 83 Supporting Statement for ICR No. 

in Docket No. A-94-52. 

Affected entity 

Industry 

Implementing agency 

Total hours 

15,122 

11,293 

Labor costs 

$673,120 

$450,972 

Total 

Annual 

O&M 

Costs 

$17,265 

NA 

Total 

costs 

$690,385 

$450,972 
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Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, 

or disclose or provide information to or for a Federal 

agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, 

validating, and verifying information, processing and 

maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train 

personnel to be able to respond to a collection of 

information; search data sources; complete and review the 

collection of information; and transmit or otherwise 

disclose the information. 

An agency may not conduct or sponsor, and a person is 

not required to respond to a collection of information 

unless it displays a currently valid OMB control number. 

Control numbers for EPA's regulations are listed in 40 CFR 

part 9 and 48 CFR chapter 15. 

Comments are requested on the Agency's need for this 

information, the accuracy of the provided burden estimates, 

and any suggested methods for minimizing respondent burden, 

including the use of automated collection techniques. Send 

comments on the ICR to the Director, Office of Environmental 

Information, Collection Strategies Division (2822), U.S. 

EPA, 1200 Pennsylvania Avenue NW, Washington, DC 20460; and 
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to the Office of Information and Regulatory Affairs, OMB, 

725 17th Street, NW, Washington, DC 20503, marked 

"Attention: Desk Officer for EPA." Include the ICR number 

in any correspondence. Since OMB is required to make a 

decision concerning the ICR between 30 and 60 days after 

[INSERT DATE OF PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER], a comment to OMB is best assured of 

having its full effect if OMB receives it by [INSERT DATE 30 

DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER]. The final rule will respond to any OMB or public 

comments on the information collection requirements 

contained in this proposal. 

C. Executive Order 13132, Federalism 

Executive Order 13132, entitled "Federalism" (64 FR 

43255, August 10, 1999), requires EPA to develop an 

accountable process to ensure "meaningful and timely input 

by State and local officials in the development of 

regulatory policies that have federalism implications." 

"Policies that have federalism implications" is defined in 

the Executive Order to include regulations that have 

"substantial direct effects on the States, on the 

relationship between the national government and the States, 

or on the distribution of power and responsibilities among 

the various levels of government." 

This proposed rule does not have federalism 

implications. It will not have substantial direct effects 
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85 

on the States, on the relationship between the national 

government and the States, or on the distribution of power 

and responsibilities among the various levels of government, 

as specified in Executive Order 13132. No reinforced 

plastic composites production facilities subject to these 

proposed NESHAP are owned by State or local governments. 

Therefore, State and local governments will not have any 

direct compliance costs resulting from this proposed rule. 

Furthermore, these proposed NESHAP do not require these 

governments to take on any new responsibilities. Thus, the 

requirements of section 6 of the Executive Order do not 

apply to this proposed rule. Thus, Executive Order 13132 

does not apply to this rule. 

In the spirit of Executive Order 13132, and consistent 

with EPA policy to promote communications between EPA and 

State and local governments, EPA specifically solicits 

comment on this proposed rule from State and local 

officials. 

D. Executive Order 13084, Consultation and Coordination 

with Indian Tribal Governments 

On November 6, 2000, the President issued Executive 

Order 13175 (65 FR 67249) entitled, "Consultation and 

Coordination with Indian Tribal Governments." Executive 

Order 13175 took effect on January 6, 2001, and revokes 

Executive Order 13084 (Tribal Consultation) as of that date. 

The EPA developed this proposed rule, however, during the 
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86 

period when Executive Order 13084 was in effect; thus, EPA 

addressed tribal considerations under Executive Order 13084. 

The EPA will analyze and fully comply with the requirements 

of Executive Order 13175 before promulgating the final rule. 

Under Executive Order 13084, we may not issue a 

regulation that is not required by statute, that 

significantly or uniquely affects the communities of Indian 

tribal governments, and that imposes substantial direct 

compliance costs on those communities unless the Federal 

government provides the funds necessary to pay the direct 

compliance costs incurred by the tribal governments, or we 

consult with those governments. If we comply by consulting, 

we are required by Executive Order 13084 to provide to the 

OMB in a separately identified section of the preamble to 

the rule, a description of the extent of our prior 

consultation with representatives of affected.tribal 

governments, a summary of the nature of their concerns, and 

a statement supporting the need to issue the regulation. In 

addition, Executive Order 13084 requires us to develop an 

effective process permitting elected officials and other 

representatives of Indian tribal governments "to provide 

meaningful and timely input in the development of regulatory 

policies on matters that significantly or uniquely affect 

their communities." 

We are not aware of any Indian tribal governments or 

communities affected by the proposed rule. Accordingly, the 
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requirements of section 3(b) of Executive Order 13084 do not 

apply to this proposed rule. 

E. Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 

(UMRA), Pub. L. 104-4, establishes requirements for Federal 

agencies to assess the effects of their regulatory actions 

on State, local, and tribal governments and the private 

sector. Under section 202 of the UMRA, we must generally 

prepare a written statement, including a cost-benefit 

analysis, for proposed and final rules with "Federal 

mandates" that may result in expenditures to State, local, 

and tribal governments, in the aggregate, or to the private 

sector, of $100 million or more in any 1 year. Before 

promulgating a rule for which a written statement is needed, 

section 205 of the UMRA generally requires us to identify 

and consider a reasonable number of regulatory alternatives 

and adopt the least costly, most cost effective, or least 

burdensome alternative that achieves the objectives of the 

rule. The provisions of section 205 do not apply when they 

are inconsistent with applicable law. Moreover, section 205 

allows us to adopt an alternative other than the least 

costly, most cost-effective, or least burdensome alternative 

if the Administrator publishes with the final rule an 

explanation why that alternative was not adopted. Before we 

establish any regulatory requirements that may significantly 

or uniquely affect small governments, including tribal 
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governments, it must have developed under section 2 03 of the 

UMRA a small government agency plan. The plan must provide 

for notifying potentially affected small governments, 

enabling officials of affected small governments to have 

meaningful and timely input in the development of our 

regulatory proposals with significant Federal 

intergovernmental mandates, and informing, educating, and. 

advising small governments on compliance with the regulatory 

requirements. 

We have determined that this proposed rule does not 

contain a Federal mandate that may result in expenditures of 

$100 million or more by State, local, and tribal 

governments, in the aggregate, or the private sector in any 

1 year. The total cost to the private sector is 

approximately $29.2 million per year. This proposed rule 

contains no mandates affecting State, local, or Tribal 

governments. Thus, today's proposed rule is not subject to 

the requirements of sections 202 and 205 of the UMRA. 

We have determined that this proposed rule contains no 

regulatory requirements that might significantly or uniquely 

affect small governments because it contains no requirements 

that apply to such governments or impose obligations upon 

them. 

F. Regulatory Flexibility Act (RFA), as amended by the 

Small Business Regulatory Enforcement Fairness Act of 1996 

(SBREFA), 5 U.S.C. 601 et sea. 
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The RFA generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to 

notice and comment rulemaking requirements under the 

Administrative Procedure Act or any other statute unless the 

agency certifies that the rule will not have a significant 

economic impact on a substantial number of small entities. 

Small entities include small businesses, small 

organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of today's 

proposed rule on small entities, small entity is defined as 

(1) a small business ranging from 500-1,000 employees; (2) a 

small governmental jurisdiction that is a government of a 

city, county, town, school district or special district with 

a population of less than 50,000; and (3) a small 

organization that is any not-for-profit enterprise which is 

independently owned and operated and is not dominant in its 

field. The table below presents the size threshold for 

small businesses by SIC Code. 

Category 

Manufacturing 

SIC Codes 

3621 

3711 

3716 

3728 

3743 

NAICS Codes 

335312 

336211, 

33612 

336213 

336413 

33651 

336112, 

Maximum 

Number of 

Employees to 

be Considered 

a Small 

Business 

1000 
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2821 325211 750 

3296 327993 

3431 332998 

3531 33312, 33651 

3612 335311 

3613 335313 

3663 33422 

3714 33653, 336399 

All other All other 500 

identified identified 

SIC Codes NAICS Codes in 

in this this source 

source category 

category 

In accordance with section 603 of the RFA, EPA prepared 

an initial regulatory flexibility analysis (IRFA) that 

examines the impact of the proposed rule on small entities 

along with regulatory alternatives that could reduce that 

impact. The IRFA is available for review in the docket and 

is summarized below. 

Section 112 of the CAA requires us to list categories 

and subcategories of major sources and, in some cases, area 

sources of HAP and to establish NESHAP for the listed source 

categories and subcategories. Reinforced plastic composites 

production (major sources only) was included on the initial 

list of source categories published on July 16, 1992 (57 FR 

3157 6). Major sources of HAP are those that have the 

potential to emit greater than 10 tpy of any one HAP or 25 

tpy of any combination of HAP. 

The objective of this proposed rule is to apply 

standards based on maximum achievable control technology to 
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all major sources in this source category. The criteria 

used to establish MACT are contained in section 112 (d) of 

the CAA. 

Based on SBA size definitions and reported sales and 

employment data, EPA identified 278 of the 356 companies 

owning reinforced plastic composites facilities as small 

businesses. Although small businesses represent almost 80 

percent of the companies within the source category, they 

are expected to incur only 31 percent of the total industry 

compliance costs of $26.0 million. The average total annual 

compliance cost is projected to be $30,000 per small company 

as compared to the industry average of $70,000 per company. 

Under the proposed standards, the mean annual compliance 

cost, as a share of sales, for small businesses is 0.7 

percent, and the median is 0.4 percent, with a range of 0.01 

to 7.5 percent. The EPA estimates that 17 percent of small 

businesses (or 47 firms) may experience an impact greater 

than 1 percent of sales, but only 3 percent of small 

businesses (or 8 firms) may experience an impact greater 

than 3 percent of sales. 

The Agency also performed an economic impact analysis 

(EIA) that accounted for firm behavior to provide an 

estimate of the facility and market impacts of the 

regulation. This industry is characterized by profit 

margins of 3 to 4 percent. Small businesses were found to 

have higher per-unit production costs under baseline 
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conditions and incur slightly higher per-unit compliance 

costs. As a result of these factors, the economic analysis 

indicates that almost 10 percent of facilities owned by 

small business are at risk of closure because of this 

proposed rule. 

Although any facility closures are cause for concern, 

the number of facilities at risk for closure would be the 

same if this proposed rule required only the MACT floor 

level of control for all facilities. The MACT floor is the 

least stringent level allowed by statute. As discussed 

below, this proposed rule contains a significant number of 

accommodations for small business. Without additional data, 

we do not believe we can make the proposed rule any less 

stringent and comply with the objectives of the CAA. In 

this regard, we have requested data and comment elsewhere in 

this preamble on issues relevant to this industry. 

The EPA's efforts to minimize small-business impacts 

have materially improved today's proposal. Economic 

analysis of provisions under earlier consideration for 

inclusion in this proposed rule indicated greater impacts on 

small businesses than those proposed today. In earlier 

versions, almost 42 percent of the total industry compliance 

costs would have been incurred by small businesses (compared 

with 31 percent of costs incurred by small businesses in 

today's proposal). The average total annual compliance cost 

would have been roughly $50,000 per small company (compared 
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with $30,000 in today's proposal). About 22 percent of 

small businesses (or 60 firms) would have experienced an 

impact greater than 1 percent of sales (compared with 17 

percent of small businesses in today's proposal). And 7 

percent of small businesses (or 19 firms) would have 

experienced impacts greater than 3 percent of sales 

(compared with 3 percent of small businesses in today's 

proposal). The reduction in small-business costs from 

earlier versions of this proposed rule is attributable to 

EPA's outreach and accommodation for small firms in keeping 

with both RFA and CAA requirements, including the conduct of 

a SBAR Panel, as discussed further below. 

The proposed reporting and recordkeeping requirements 

for these small businesses include initial notifications, 

startup notifications and compliance reports. These 

requirements were discussed in more detail under the 

discussion of the Paperwork Reduction Act above. We 

estimate that 302 existing facilities owned by small 

businesses will be impacted by these requirements, and 53 

new facilities will be impacted in the first three years. 

The professional skills required to complete these reports 

include the ability to calculate emissions and resin use and 

read and follow report format guidance. All facilities 

impacted by this proposed rule should have personnel with 

the necessary skills because they would need these skills to 

comply with other regulatory requirements such as Toxic 
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Release Inventory (TRI) reporting. 

Provisions to minimize the reporting and recordkeeping 

requirements on small business have been incorporated into 

this proposed rule. These provisions include allowing: the 

facility to substantiate resin and gel coat HAP.contents 

with Material Safety Data Sheets rather then requiring 

testing of each resin and gel coat; use of resin purchase 

records to determine resin use; and exemption of facilities 

that can demonstrate that all their resin and gel coats 

comply with the required HAP content limits from the 

requirement to keep records of resin use and calculate point 

value averages. These provisions have also been extended to 

all companies subject to today's proposed NESHAP. 

These facilities may also be subject to the NESHAP 

being developed for plastic parts and products. There 

should be no duplication of effort as a result of this 

proposed rule and the Plastic Parts and Products NESHAP 

being developed because these NESHAP will cover different 

operations. Facilities subject to this proposed rule are 

also subject to emissions estimate reporting under the TRI 

requirements. In this proposed rule, we could determine no 

ways to combine TRI and the reporting requirements of the 

proposed NESHAP because the objectives and statutory 

authorities of these requirements are different. However, 

we invite comments from all interested parties on ways to 

combine these reports and still meet the statutory 
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requirements of the CAA. 

As indicated above, we have incorporated significant 

alternatives into the proposed rule to minimize the impact 

on small business but still meet the objectives of the CAA. 

As required by section 609(b) of the RFA, EPA conducted 

outreach to small entities and convened a SBAR panel to 

review advice and recommendations from representatives of 

the small entities that potentially would be subject to the 

proposed rule requirements. The panel convened on April 6, 

2000 and was comprised of representatives from OMB, the SBA 

Office of Advocacy, the EPA Small Business Advocacy Chair, 

and the Emission Standards Division of the Office of Air 

Quality Planning and Standards of EPA. The panel solicited 

advice from 17 small entity representatives (SER) from a 

cross-section of the different industry sectors likely to be 

directly regulated by this action. On April 18, 2000, the 

panel distributed a package of descriptive and technical 

materials explaining the rule-in-progress to the SER. On 

May 2, .2000, the panel met with the SER to hear their 

comments on preliminary options for regulatory flexibility 

and related information. The panel also received written 

comments from the SER in response to both the outreach 

materials and the discussions at the meeting. 

Consistent with RFA/SBREFA requirements, the panel 

evaluated the assembled materials and small-entity comments 

on issues related to the elements of the IRFA. A copy of 
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the panel report is included in the docket for this proposed 

rule. 

The panel considered numerous regulatory flexibility 

options in response to concerns raised by the SER. The 

major concerns included the affordability and technical 

feasibility of add-on controls, the resin and gel coat HAP 

contents required to meet some of the MACT floors, and the 

regulatory treatment of speciality products. 

These are the major panel recommendations and EPA's 

response in today's proposal: 

• Recommend setting higher thresholds than EPA had 

initially considered for requirements to use add-on 

controls. 

Response: In today's action, EPA proposes to allow 

facilities owned by small firms to emit 250 tpy (as 

distinct from the 100 tpy limit for facilities owned by 

large firms) before installing add-on controls. 

• Recommend setting the new source floor for small-owned 

sources at the level of the existing source floor. 

Response: Today's proposal includes this provision. 

• Recommend establishing separate floors for speciality 

products. 

Response: Today's proposal includes this provision. 

• Explore pollution-prevention alternatives to add-on 

controls. 

Response: The EPA did explore this possibility with 
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industry sources. Although we could not devise a 

workable pollution-prevention alternative to include in 

today's proposal, the Agency is requesting comment on 

how such a mechanism might be structured within the 

requirements of the CAA. 

Recommend allowing individual facilities to use the 

same resin in all resin application processes. 

Response: Today's proposal includes this provision. 

Reconsider the resin HAP content requirement for 

tooling resins. 

Response: Today's proposal includes a revised 

provision. 

Recommend separate floors for white and non-white gel 

coats. 

Response: Today's proposal includes this provision. 

Reconsider the Agency's estimates of the cost of add-on 

controls. 

Response: Even though today's proposal eliminates the 

likelihood that existing small-owned facilities will be 

subject to add-on controls, EPA has reconsidered its 

cost estimates in light of those offered by the 

industry. As discussed elsewhere in this preamble, EPA 

continues to believe our estimates are realistic. 

Nevertheless, as mentioned in section Ill-M, we are 

soliciting comments on all data and assumptions that 

affect add-on control costs. Moreover, as mentioned 
p.1 

98 

previously, we will review in more depth the industry's 

analysis on the cost of this proposed rule following 

proposal. Where appropriate, we will make changes to 

our estimates of costs based on our review and on 

comments we receive, and make the results of our 

detailed review available in the public docket at 

promulgation. 

• Recommend grouping high-strength applications with 

corrosion-resistant operations. 

Response: Today's proposal includes this provision. 

Detailed information on all these recommendations is 

contained in the panel report in the docket for this 

proposed rule. 

G. National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and 

Advancement Act (NTTAA) of 1995 (Public Law No. 104-113; 15 

U.S.C. 272 note) directs EPA to use voluntary consensus 

standards in their regulatory and procurement activities 

unless to do so would be inconsistent with applicable law or 

otherwise impractical. Voluntary consensus standards are 

technical standards (e.g., materials specifications, test 

methods, sampling procedures, business practices) developed 

or adopted by one or more voluntary consensus bodies. The 

NTTAA directs EPA to provide Congress, through annual 

reports to OMB, with explanations when an agency does not 
P.2 

99 

use available and applicable voluntary consensus standards. 

This proposed rulemaking involves technical standards. 

The EPA proposes in this rule to use EPA Methods 1, IA, 2, 

2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 18, 25, 25A, 204, and 

204B,C,D,E. Consistent with the NTTAA, the EPA conducted 

searches to identify voluntary consensus standards in 

addition to these EPA methods. One voluntary consensus 

standard was identified as applicable and EPA proposes to 

use this standard in this proposed rule. 

The one consensus standard, ASTM D6420-99, Standard 

Test Method for Determination of Gaseous Organic Compounds 

by Direct Interface Gas Chromatography-Mass Spectrometry 

(GC/MS), is appropriate in the cases described below for 

inclusion in this proposed rule in addition to the currently 

available EPA Method 18 codified at 40 CFR part 60, 

appendix A. 

Similar to EPA's performance based Method 18, ASTM 

D6420-99 is also a performance based method for measurement 

of gaseous organic compounds. However, ASTM D6420-99 was 

written to support the specific use of highly portable and 

automated GC/MS. While offering advantages over the 

traditional Method 18, the ASTM method does allow some less 

stringent criteria for accepting GC/MS results than reguired 

by Method 18. Therefore, ASTM D6420-99 is a suitable 
P.3 

100 

alternative to Method 18 where: (1) the target compound(s) 

are those listed in Section 1.1 of ASTM D6420-99, and (2) 

the target concentration is between 150 parts per billion 

(volume) and 100 ppm(v). 

For target compound(s) not listed in Table 1.1 of ASTM 

D6420-99, but potentially detected by mass spectrometry, the 

regulation specifies that the additional system continuing 

calibration check after each run, as detailed in section 

10.5.3 of the ASTM method, must be followed, met, 

documented, and submitted with the data report even if there 

is no moisture condenser used or the compound is not 

considered water soluble. 

For target compound(s) not listed in Table 1.1 of ASTM 

D6420-99, and not amenable to detection by mass 

spectrometry, ASTM D6420-99 does not apply. 

As a result, EPA proposes to incorporate by reference 

(IBR) ASTM 6420-99 into 40 CFR 63.14 for application with 

proposed subpart WWWW of part 63. The EPA will also cite 

Method 18 as a gas chromatography (GC) option in addition to 

ASTM D6420-99. This will allow the continued use of other 

GC configurations. 

In addition to the voluntary consensus standards EPA 

proposes to use in this proposed rule, the search for 

emissions monitoring procedures identified 17 other 
P.4 

101 

voluntary consensus standards. The EPA determined that 13 

of these 17 standards identified for measuring emissions of 

the HAP or surrogates subject to emission standards in the 

proposed rule would not be practical due to lack of 

equivalency, detail, and/or quality assurance/quality 

control requirements. The remaining four of the 17 

consensus standards identified are under development or 

under EPA review. Therefore, we do not propose to use these 

voluntary consensus standards in this proposed rulemaking. 

More information on the reasons we chose not to propose to 

use these standards is available in the docket for this 

proposed rule. 

The EPA takes comments on proposed compliance 

demonstration requirements in this proposed rulemaking.and 

specifically invites the public to identify potentially 

applicable voluntary consensus standards. Commentors should 

also explain why this proposed rule should adopt these 

voluntary consensus standards in lieu of or in addition to 

EPA's methods. Emission test methods and performance 

specifications submitted for evaluation should be 

accompanied with a basis for the recommendation, including 

method validation data and the procedure used to validate 

the candidate method (if method other than Method 301, 40 

CFR part 63, appendix A was used). 
P.5 

102 

Table 6 of proposed subpart WWWW lists the EPA test 

methods and performance standards. Most of the standards 

have been used by States and industry for more than 

10 years. Nevertheless, under §63.7(f), the proposal also 

allows any State or source to apply to EPA for permission to 

use an alternative methods in place of any of the EPA 

testing methods or performance standards listed in the 

proposed NESHAP. 

H. Executive Order 13045, Protection of Children from 

Environmental Health Risks and Safetv Risks 

Executive Order 13045 (62' FR 19885, April 23, 1997) 

applies to any rule that: (1) is determined to be 

"economically significant" as defined under Executive Order 

12866, and (2) concerns an environmental health or safety 

risk that we have reason to believe may have a 

disproportionate effect on children. If the regulatory 

action meets both criteria, the Agency must evaluate the 

environmental health or safety effects of the planned rule 

on children, and explain why the planned regulation is 

preferable to other potentially effective and reasonably 

feasible alternatives considered by the Agency. 

The EPA interprets Executive Order 13045 as applying 

only to those regulatory actions that are based on health or 

safety risks, such that the analysis required under section 

5-501 of the Executive Order has the potential to influence 

the regulation. This proposal is not subject to Executive 
P.6 

NESHAP: Reinforced Plastic Composites Production -

Proposed Rules - Page 103 of 191 

Order 13045 because it is based on technology performance 

and not on health or safety risks. 

List of Subjects in 40 CFR Part 63 

Environmental protection, Air pollution control, 

Hazardous air pollutants, Incorporation by reference, 

Reporting and recordkeeping requirements, and Volatile 

organic compounds. 

Dated 

Carol M. Browner, 

Administrator. 
P.7 

104 

For the reasons stated in the preamble, title 40, chapter I, 

part 63 of the Code of the Federal Regulations is proposed 

to be amended as follows: 

PART 63 -- [AMENDED] 

1. The authority citation for part 63 continues to read as 

follows: 

Authority: 42 U.S.C. 7401 et sea. 

2. Section 63.14 is proposed to be amended by adding 

paragraph (b) ( ) to read as follows: 

§63.14 Incorporation by reference 

**** * 

(b) * * * 

( ) ASTM D642 0-99, Standard Test Method for 

Determination of Gaseous Organic compounds by Direct 

Interface Gas Chromatography-Mass spectrometry, IBR approved 

for §63.5798 and §63.5850. 

**** * 

3. Part 63 is proposed to be amended by adding subpart WWWW 

to read as follows: 

Subpart WWWW-National Emission Standards for Hazardous Air 

Pollutants: Reinforced Plastic Composites Production 

Sec. 

What This Subpart Covers 

§63.5780 What is the purpose of this subpart? 

§63.5785 Am I subject to this subpart? 

§63.5790 What parts of my plant does this subpart cover? 

§63.5795 How do I know if my reinforced plastics composites 

production facility is a new affected source or an 

existing affected source? 
P.8 

105 

§63.5797 What are model point values and how are they 

used in this subpart? 

§63.5798 How do I determine my facility's HAP emissions on 

a tons per year (tpy) basis? 

§63.5800 When do I have to comply with this subpart? 

Standards 

§63.5805 What standards must I meet to comply with this 

subpart? 

Options for Meeting Standards 

§63.5810 What are my options for meeting the standards for 

new and existing open molding and centrifugal 

casting operations? 

§63.5820 What are my options for meeting the standards for 

continuous lamination/casting operations? 

§63.5825 What are my options for meeting the standards for 

new pultrusion operations? 

§63.5830 What are my options for meeting the standards for 

existing pultrusion operations? 

General Compliance Reguirements 

§63.5835 What are my general requirements for complying 

with this subpart? 

Testing and Initial Compliance Requirements 

§63.5840 By what date must I conduct a performance test or 

other initial compliance demonstration? 

§63.5845 When must I conduct subsequent performance tests? 

§63.5850 How do I conduct performance tests, performance 

evaluations, and design evaluations? 

§63.5855 What are my monitor installation and operation 

requirements? 

§63.5860 How do I demonstrate initial compliance with the 

standards? 

Additional Compliance Calculation Procedures for Continuous 

Lamination/Casting Operations 

§63.5865 What data must I generate to demonstrate 

compliance with the standards for continuous 

lamination/casting operations? 

§63.5870 How do I calculate annual uncontrolled and 

controlled emissions from my wet-out area(s) and 

from my oven(s)? 

§63.5875 How do I determine the capture efficiency of the 

enclosure on my wet-out area and the capture 

efficiency of my oven(s)? 
P.9 

106 

§63.5880 How do I determine how much neat resin plus is 

applied to the line and how much neat gel coat 

plus is applied to the line? 

§63.5885 How do I calculate percent reduction to 

demonstrate compliance? 

§63.5890 How do I calculate an emission factor to 

demonstrate compliance? 

Continuous Compliance Requirements 

§63.5895 How do I monitor and collect data to demonstrate 

continuous compliance? 

§63.5900 How do I demonstrate continuous compliance with 

the standards? 

Notifications, Reports, and Records 

§63.5905 What notifications must I submit and when? 

§63.5910 What reports must I submit and when? 

§63.5915 What records must I keep? 

§63.5920 In what form and how long must I keep my records? 

Other Requirements and Information 

§63.5925 What parts of the General Provisions apply to me? 

§63.5930 Who implements and enforces this subpart? 

§63.5935 What definitions apply to this subpart? 

Tables 

Table 1 to Subpart WWWW - Model Equations to Calculate Point 

Values for Specific Open Molding and Centrifugal Casting 

Process Streams 

Table 2 to Subpart WWWW - Compliance Dates for New and 

Existing Reinforced Plastic Composites Facilities 

Table 3 to Subpart WWWW - Emission Limits for Existing Small 

Business Sources Emitting Less Than 250 TPY of HAP, or Other 

Sources Emitting Less Than 100 TPY of HAP 

Table 4 to Subpart WWWW - Work Practice Standards 

Table"5 to Subpart WWWW - Alternative Emission Limits for 

Open Molding and Centrifugal Casting Operations Where the 

Standard Is Based on a Percent Reduction Requirement 

Table 6 to Subpart WWWW - Basic Requirements for Performance 

Tests, Performance Evaluations, and Design Evaluations for 

New and Existing Sources Using Add-On Control Devices 

Table 7 to Subpart WWWW - Options Allowing Use of the Same 

Resin Across Different Operations That Use the Same Resin 

Type 

Table 8 to Subpart WWWW - Initial Compliance With Emission 

Limits 
P.10 

107 

Table 9 to Subpart WWWW - Initial Compliance With Work 

Practice Standards for Existing Sources 

Table 10 to Subpart WWWW - Data Requirements for New and 

Existing Continuous Lamination Lines and Continuous Casting 

Lines Complying with a Percent Reduction Limit on a Per Line 

Basis 

Table 11 to Subpart WWWW - Data Requirements for New and 

Existing Continuous Lamination and Continuous Casting Lines 

Complying with a Percent Reduction Limit or a Lbs/Ton Limit 

on an Averaging Basis 

Table 12 to Subpart WWWW - Data Requirements for New and 

Existing Continuous Lamination Lines and Continuous Casting 

Lines Complying with a Lbs/Ton on a Per Line Basis 

Table 13 to Subpart WWWW - Applicability and Timing of 

Notifications 

Table 14 to Subpart WWWW - Requirements for Reports 

Table 15 to Subpart WWWW - Applicability of General 

Provisions (Subpart A) to Subpart WWWW 

What This Subpart Covers 

§63.5780 What is the purpose of this subpart? 

This subpart establishes national emission standards 

for hazardous air pollutants (NESHAP) for reinforced plastic 

composites production. This subpart also establishes 

requirements to demonstrate initial and continuous 

compliance with the emission standards. 

§63.5785 Am I subject to this subpart? 

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 hazardous air pollutants (HAP) 

emissions. Reinforced plastic composites production 

consists of operations in which reinforced and/or 

nonreinforced plastic composites or plastic molding 

compounds are manufactured. These operations use thermoset 

resins and/or gel coats that contain styrene and/or methyl 
P.11 

108 

methacrylate to produce plastic composites, which contain 

materials designed to enhance the chemical, physical, and/or 

thermal properties of the product. Reinforced plastic 

composites production also includes cleaning, mixing, and 

material storage associated with the production of plastic 

composites. 

§63.5790 What parts of my 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 plastics composites manufacture, material 

storage, any other plastic composites operations. 

§63.5795 How do I know if my reinforced plastics composites 

production facilitv is a new affected source or an existing 

affected source? 

(a) A reinforced plastic composites production 

facility is a new affected source if it meets all the 

criteria in paragraphs (a)(1) and (2) of this section. 

(1) You commence construction of the affected source 

after fINSERT DATE OF PUBLICATION OF THIS PROPOSED RULE IN 
P.12 

109 

THE FEDERAL REGISTER]. 

(2) When you commence construction, no other reinforced 

plastic composites production affected source exists at that 

site. 

(b) For the purposes of this subpart, an existing 

affected source is any affected source that is not a new 

affected source. 

§63.5797 What are model point values and how are thev used 

in this subpart? 

The model point value is a number calculated using the 

equations in Table 1 to this subpart. Equations are 

available for each open molding operation and centrifugal 

casting operation. The model point values have units of 

pounds (lbs) of HAP per ton of resin or gel coat applied. 

Point values are used in this subpart to determine 

compliance with certain emission limits in Tables 3 and 5 of 

this subpart. The model point values are surrogates for 

emissions, and the model point value equations are used only 

for determining compliance with this subpart. The model 

point value equations cannot be used in place of emission 

factor equations to demonstrate compliance with other 

regulations. 

§63.5798 How do I determine my facility's HAP emissions on a 

tons per vear (tpy) basis? 

To determine your facility's HAP emissions, you must 

use the procedures in either paragraph (a) or (b) of this 
P.13 

110 

section and calculate the combined HAP emissions in tpy from 

the following operations: open molding, centrifugal casting, 

continuous lamination, continuous casting, pultrusion, sheet 

molding compound manufacturing, mixing, and bulk molding 

compound manufacturing. 

(a) For existing facilities, you may use the procedures 

in either paragraph (a)(1) or (2) of this section. 

(1) Use point value equations or emission factors. 

Calculate a weighted average emission factor on a lbs/ton of 

resin and gel coat basis. Base the weighted average on the 

12 months of operation prior to the effective date of this 

subpart. Multiply the weighted average emission factor by 

resin and gel coat use over the same period. You may 

calculate this emission factor based on the point value 

equations in Table 1 of this subpart, or you may use any 

emission factor approved by us such as factors from the 

Compilation of Air Pollutant Emission Factors, Volume I: 

Stationary Point and Area Sources (AP-42). This calculation 

must be repeated and reported annually. 

(2) Conduct performance testing. Perform performance 

testing using the methods specified in this subpart to 

determine a facility-specific emission factor in lbs of HAP 

emissions per ton of resin and gel coat used. The test 

should be performed under conditions expected to result in 

the highest possible HAP emissions, or the facility must 

stay within 10 percent of the same mix of operations that 

occurred during testing. Multiply this factor by annual 
P.M 

111 

resin and gel coat use to determine annual emissions. 

(b) For new facilities, calculate a weighted average 

emission factor on a lbs/ton of resin and gel coat basis. 

Base the weighted average on your projected operation for 

the 12 months subsequent to facility startup. Multiply the 

weighted average emission factor by projected resin use over 

the same period. You may calculate this emission factor 

based on the point value equations in Table 1 of this 

subpart, or you may use any emission factor approved by us, 

such as factors from AP-42, or emission test data from 

similar facilities. This calculation must be repeated and 

reported annually. 

§63.5800 When do I have to comply with this subpart? 

(a) You must initially comply with the standards in 

this subpart by the dates specified in Table 2 to this 

subpart. Facilities meeting an emissions standard based on 

a 12 month rolling average must begin collecting data one 

^^r^before^Jon the compliance date in order to demonstrate 

compliance. 

(b) If your facility is a new affected source and emits 

less than 100 tpy of HAP at.the time of initial compliance 

with this subpart, and subsequently increases its actual HAP 

emissions to 100 tpy or more, then your facility must 

subsequently meet the standards in §63.5805(d). You must be 

in compliance with these more stringent standards within 3 

years of the date your facility meets or exceeds the 100 tpy 

threshold. 
P.15 

112 

(c) If your facility is an existing affected source and 

emits less than 250 tpy (if you are a small business) or 100 

tpy of HAP (if you are not a small business) at the time of 

initial compliance with this subpart, and subsequently 

increases its actual HAP emissions to 250 tpy or more (small 

business) or to 100 tpy or more (non-small business), then 

your facility must subsequently meet the standards at 

§63.5805(b). You must be in compliance with these more 

stringent standards within 3 years of the date your.facility 

meets or exceeds the 250 tpy or 100 tpy threshold. 

Standards 

§63.5805 What standards must I meet to comply with this 

subpart? 

All facilities must meet the requirements of (a) 

through (f) of this section that apply. There are options 

to meeting these standards described in §§63.5810 through 

63.5830. 

(a) If you have an existing facility that is a small 

business, as defined by the Small Business Administration's 

(SBA's) regulations at 13 CFR 121.201, and emits less than 

250 tpy of HAP, or a facility that is not a small business 

and that emits 100 tpy or less of HAP from the combination 

of all open molding, centrifugal casting, continuous 

lamination/casting, pultrusion, SMC manufacturing, and 

mixing/BMC manufacturing, you must meet the annual average 

emission limits in Table 3 of this subpart and the work 

practice standards in Table 4 of this subpart that apply to 
P.16 

113 

you. 

(b) If you have an existing facility that is a small 

business as defined by the SBA regulations at 13 CFR 121.201 

and emits 250 tpy or more of HAP, or if you' have a facility 

that is not a small business and emits 100 tpy or more of 

HAP from the combination of all open molding, centrifugal 

casting, continuous lamination/casting, pultrusion, SMC 

manufacturing, and mixing/BMC manufacturing operations, you 

must reduce the total HAP emissions from these operations by 

at least 95 percent by weight and meet any applicable work 

practice standards in Table 4 of this subpart that apply to 

you. As an alternative to meeting 95 percent by weight, you 

may meet the emission limits in Table 5 of this subpart. If 

you have a continuous lamination/casting operation, that 

operation may alternatively meet an emission limit of 1.47 

lbs of HAP per ton of neat resin plus and neat gel coat plus 

applied 

(c) If you have a new facility that emits less than 100 

tpy of HAP from the combination of all open molding, 

centrifugal casting, continuous lamination/casting, 

pultrusion, SMC manufacturing, and mixing/BMC manufacturing, 

you must meet the annual average emission limits in Table 3 

of this subpart and the work practice standards in Table 4 

of this subpart that apply to you. 

(d) If you have a new facility that emits 100 tpy or 

more of HAP from the combination of all open molding, 

centrifugal casting, continuous lamination/casting, 
P.17 

114 

pultrusion, SMC manufacturing, and mixing/BMC manufacturing, 

you must reduce the total HAP emissions from these 

operations by at least 95 percent by weight and meet any 

applicable work practice standards in Table 4 of this 

subpart that apply to you. As an alternative to meeting 95 

percent by weight, you may meet the emission limits in Table 

5 of this subpart. If you have a continuous 

lamination/casting operation, that operation may 

alternatively meet an emission limit of 1.47 lbs of HAP per 

ton of neat resin plus and neat gel coat plus applied. 

(e) If you use an add-on control device to comply with 

this subpart, you must meet all requirements contained in 40 

CFR part 63, subpart SS. 

Options for Meeting Standards 

§63.5810 What are my options for meeting the standards for 

new and existing open molding and centrifugal casting 

operations? 

You must use one of the following methods in paragraphs 

(a) through (c) of this section to meet the standards in 

§63.5805. 

(a) Meet the individual model point values for each 

operation. Demonstrate that you meet the individual model 

point values for each open molding operation and for each 

centrifugal casting operation in Table 3 or 5 of this 

subpart that apply to you. This is done in two steps. 

First, determine a point value for each individual resin and 

gel coat, application method, and control method you use in 
P.18 

115 

a particular operation. Then, calculate a weighted average 

of those point values based on -•resin and gel coat use. 

These calculations shall be performed monthly, and within 30 

days of the end of the month. You must either be at or 

below the applicable point value in Table 3 or 5 of this 

subpart each month, or at or below the applicable point 

value in Table 3 or 5 of this subpart, based on a 12-month 

rolling average. The procedures are described in paragraphs 

(a)(1) and (2) below. 

(1) Calculate your actual point values for each 

different process stream within each operation. Process 

streams within operations are different from each other if 

any of the following three characteristics vary: the neat 

resin plus or neat gel coat plus HAP content, the 

application technique, or the control technique. You must 

calculate the different process stream point values by using 

the appropriate model point value equations in Table 1 of 

this subpart for open molding and for centrifugal casting. 

If you want to use vapor suppressants to meet the point 

value for open molding, you must determine the vapor 

suppressant effectiveness by conducting testing to 

demonstrate the vapor suppressant effectiveness. If you 

want to use an add-on control device to meet the point 
P.19 

116 > 

value, you must determine the add-on control factor by 

conducting capture and control efficiency testing as 

indicated in Table 6 of this subpart. The point value 

calculated from the equations in Table 1 of this subpart is 

multiplied by the add-on control factor to calculate the 

point value after control. Use Equation 1 of this section 

to calculate the add-on control factor used in the model 

point value equations. 

. ,, _ . , „ - % Control Efficiency 

Add-on Control Factor = 1 - - 100 (Eq. 1) 

Where: 

% Control Efficiency = a value calculated from 

emission test measurements 

made according to the 

requirements of Table 6 of 

this subpart 

(2) Calculate your actual operation point value for 

each calendar month for each open molding operation and for 

each centrifugal casting operation by calculating the 

weighted average of the individual process stream point 

values within each respective operation. To do this, sum 

the product of your actual process stream point values and 

the amount of neat resin plus and neat gel coat plus used in 

each process stream and divide the numerator by the total 

amount of neat resin plus and neat gel coat plus used in the 

process streams. Use Equation 2 of this section to 

calculate your actual individual point value for each 

operation. 
P.20 

117 

_jj (Actual Process Stream PV± * Material^ Actual 

Operation - J_i (Eq.2) 

Point Value ^S ^ 

/,Materiali 

i=l 

Where: 

Actual Process Stream 'PVi = actual point value 

from process stream i, 

lbs/ton 

Materiali = neat resin plus or neat 

gel coat plus used during 

the calendar month for 

process stream i, tons 

n = number of process 

streams where you 

calculated a point value 

(b) Point value averaging option. Demonstrate that you 

meet the weighted average point value of the open molding 

operations and the weighted average point value of the 

centrifugal casting operations in Table 3 or 5 of this 

subpart that apply to you. When using this averaging 

option, do not apply the procedures across open molding and 

centrifugal casting operations. 

(1) Calculate the weighted average point value for your 

facility to determine which point value you must meet. To 

do this, you must sum the product of the individual point 

values in Table 3 or 5 of this subpart, and the amount of 

neat resin plus or neat gel coat plus used in each operation 
P.21 

118 

and divide the numerator by the total amount of neat resin 

plus and neat gel coat plus used in the operation. Use 

Equation 3 of this section to calculate the weighted average 

point value.-

2_) ( PV± * Material^ 

Weighted Average Point Value = -i-^ (Eq. 3) 

2_, Materiali 

i = l 

Where: 

PVi = point value from operation i, lbs/ton 

from Table 3 or 5 of this subpart 

Materiali = neat resin plus or neat gel coat plus 

used during the calendar month for 

operation i, tons 

n = number of operations 

(2) Calculate your actual weighted average point value 

for each calendar month to determine if you meet the 

weighted average point value calculated in paragraph (b)(1) 

of this section. Do this by summing the product of your 

actual operation point values and the amount of neat resin 

plus and neat gel coat plus used in each operation and 

dividing the numerator by the total amount of neat resin 

plus and neat gel coat plus used in the operation groupings. 

You must calculate your actual individual point values for 

each operation as described in paragraphs (a)(1) and (2) of 

this section. Use Equation 4 of this section to calculate 

your actual weighted average point value. 
P.22 

119 

Actual Jj (Actual Operation PV, * Material. 

Weighted j_=i * ^ 

Average Point J^ (Eq. 4) 

Value 2^, Materiali 

i = l 

Where: 

Actual Individual PVi = Actual point value from 

operation i, lbs/ton 

Materiali

 = neat resin plus or neat gel 

coat plus used during the 

calendar month for operation 

i, tons 

n = number of operations 

(c) Select one resin point value for multiple 

operations. If you have any combination of manual resin 

application, mechanical resin application, filament winding, 

or centrifugal casting, you may elect to meet the point 

value for any one of these operations and use that 

operation's same resin in all of the resin operations listed 

in this paragraph (c). If you select this option, for 

purposes of assigning point values and determining 

compliance, use Table 7 of this subpart which presents the 

possible combinations based on a facility selecting the 

application process that results in the highest allowable 

HAP content resin. The averaging provisions in paragraph 

(b) of this section may still be used, but you must use the 

point value(s) according to this paragraph (c) to calculate 

compliance. 

§63.5820 What are my options for meeting the standards for 
P.23 

120 

continuous lamination/casting operations? 

You must use one or more of the options in paragraphs 

(a) through (d) of this section to meet the standards in 

§63.5805. Use the calculation procedures in §63.5865. 

(a) Compliant line option. Demonstrate that each 

continuous lamination line and each continuous casting line 

complies with the applicable standard. 

(b) Averaging option. Demonstrate that all continuous 

lamination and continuous casting lines combined comply with 

the applicable standard. 

(c) Add-on control device option. If your operation 

must meet the 58.5 weight percent emission limit in Table 3 

of this subpart, you have the option of demonstrating that 

you achieve 95 percent control of all wet-out area 

emissions. 

(d) Combination option. Use a combination of options 

in paragraphs (a) and (b) of this section or, for affected 

sources at existing facilities, a combination of options in 

paragraphs (a), (b), and (c) of this section (in which one 

or more lines meet the standards on their own, two or more 

lines averaged together meet the standards, and one or more 

lines have their wet-out areas controlled to a level of 95 

percent). 

§63.5825 What are my options for meeting the standards for 

new pultrusion operations? 

You must use one or more of the options in paragraphs 

(a) through (c) of this section to meet the 95 percent 
P.24 

121 

emission reduction standard in §63.5805. 

(a) Add-on control device option. Capture the 

emissions and vent them to a control device or any 

combination of control devices that achieves a 95 percent 

reduction of HAP emissions. Conduct capture and destruction 

efficiency testing as indicated in Table 6 of this subpart 

to determine the percent emission reduction. 

(b) Direct die injection with resin drip collection 

option. Use direct die injection pultrusion machines with 

resin drip collection systems that meet the following 

criteria in paragraphs (b)(1) through (3) of this section: 

(1) All the resin that is applied to the reinforcement 

is delivered directly to the die. 

(2) No exposed resin is present except at the face of 

the die. 

(3) Resin drip is captured in closed piping and 

recycled directly to the resin injection chamber. 

(c) Combination option. Use a combination of options 

in paragraphs (a) and (b) of this section in which some 

lines meet the standards by complying with paragraph (a) of 

this section, and the remaining lines meet the standards by 

complying with paragraph (b) of this section. 

§63.5830 What are my options for meeting the standards for 

existing pultrusion operations? 

You must use one or more of the options in paragraphs 

(a) through (d) of this section to meet the 60 weight 

percent emission limit in Table 3 of this subpart as 
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122 

required in §63.5805. 

(a) Add-on control device option. Capture the 

emissions and vent them to a control device or any 

combination of control devices that achieves a 60 weight 

percent reduction of HAP emissions. Conduct capture and 

destruction efficiency testing as indicated in Table 6 of 

this subpart to determine the percent HAP emission 

reduction. 

(b) Wet area enclosure with resin drip collection 

option. Design, install, and operate wet area enclosures 

and resin drip collection systems on pultrusion machines 

that meet the criteria in paragraphs (b)(1) through (11) of 

this section. 

(1) The enclosure must cover and enclose the open resin 

bath and the forming area in which reinforcements are prewet or wet-out and moving toward the die(s). The surfaces 

of the enclosure must be closed except for openings to allow 

material to enter and exit the enclosure. 

(2) For pultrusion machines with a radio frequency preheat unit, the enclosure must extend from the beginning of 

the resin bath to within 12.5 inches or less of the entrance 

of the radio frequency pre-heat unit. If the stock that is 

within 12.5 inches or less of the entrance to the radio 

frequency pre-heat unit has any drip, it must be enclosed. 

The stock exiting the radio frequency pre-heat unit is not 

required to be in an enclosure if the stock has no drip 

between the exit of the radio frequency pre-heat unit to 
P.26 

123 

within 0.5 inches of the entrance of the die. 

(3) For open bath pultrusion machines without a radio 

frequency pre-heat unit, the enclosure must extend from the 

beginning of the resin bath to within 0.5 inches or less of 

the die entrance. 

(4) For pultrusion lines with a pre-wet area prior to 

direct die injection, the enclosure must extend from the 

point at which the resin is applied to the reinforcement to 

within 12.5 inches or less of the entrance of the die(s). 

If the stock that is within 12.5 inches or less of the 

entrance to the die has any drip, it must be enclosed. 

(5) The enclosure can only be constructed high enough 

to clear the highest part of the pultrusion line that must 

be inside the enclosure. 

(6) The total open area of the enclosure must not 

exceed 2 times the cross sectional area of the puller 

window(s) and must comply with the requirements in 

paragraphs (b)(6)(i) through (iii) of this section. 

(i) All areas which are open need to be included in the 

total open area calculation with the exception of access 

panels, doors, and/or hatches that are part of the 

enclosure. 

(ii) The area which is displaced by entering 

reinforcement or exiting product is considered open. 

(iii) Areas that are covered by brush covers are 

considered closed. 

(7) Open areas for level control devices, monitoring 
P.27 

124 

devices, agitation shafts, and/or fill hoses must have no 

more than 1.0 inch clearance. 

(8) The access panels, doors, and/or hatches that are 

part of the enclosure must close tightly to avoid vapor 

leakage. Damaged access panels, doors, and/or hatches that 

allow vapor leakage must be replaced. 

(9) The enclosure may not be removed from the 

pultrusion line and access panels, doors, and/or hatches 

that are part of the enclosure must remain closed whenever 

resin is in the bath except for the time period discussed in 

paragraph (b)(10) of this section. 

(10) The maximum length of time the enclosure may be 

removed from the pultrusion line or the access panels, 

doors, and/or hatches and may be open is 30 minutes per 8 

hour shift (or 45 minutes per 12 hour shift). 

(11) No fans, blowers, and/or air lines may be allowed 

within the enclosure. The enclosure must not be ventilated. 

(c) Direct die injection with resin drip collection 

option. Use direct die injection pultrusion machines with 

resin drip collection systems that meet all the criteria in 

paragraphs (c)(1) through (3) of this section. 

(1) All the resin that is applied to the reinforcement 

is delivered directly to the die. 

(2) No exposed resin is present except at the face of 

the die. 

(3) Resin drip is captured in closed piping and 

recycled directly to the resin injection chamber. 
P.28 

125 

(d) Combination option. Use a combination of options 

in paragraphs (a) through (c) of this section in which 

different pultrusion lines comply with different options 

described in paragraphs (a) through (c) of this section. 

General Compliance Requirements 

§63.5835 What are my general requirements for complying 

with this subpart? 

(a) You must be in compliance at all times with the 

work practice standards in Table 4 of this subpart, as well 

as emission limits in Table 3 or 5 of this subpart, as 

applicable, that you are meeting without the use of add-on 

controls. 

(b) You must be in compliance with all emission limits 

in this subpart that you meet using add-on controls, except 

during periods of startup, shutdown, and malfunction. 

(c) You must always operate and maintain your affected 

source, including air pollution control and monitoring 

equipment, according to the provisions in §63.6(e)(1)(i). 

(d) You must develop and implement a written startup, 

shutdown, and malfunction plan according to the provisions 

in §63.6(e)(3) for any emission limits you meet using an 

add-on control. 

Testing And Initial Compliance Requirements 

§63.5840 By what date must I conduct a performance test or 

other initial compliance demonstration? 

You must conduct performance tests, performance 

evaluations, design evaluations, capture efficiency testing, 
P.29 

126 

and other initial compliance demonstrations by the 

compliance date specified in Table 2 of this subpart wilh 

one excepLion. Open moldiny and centrifugal casting 

operations Llial are required Lo meet a pumL value on a- -±-2-= 

month rolliny average musL meet a 2 year—compliance dale and 

demonslrale compliance 3 years afler publicalion of—the 

final rule. 

§63.5845 When must I conduct subsequent performance tests? 

You must also conduct a performance test every 5 years 

following the initial performance test for any standards you 

meet with an add-on control device. 

§63.5850 How do I conduct performance tests, performance 

evaluations, and design evaluations? 

(a) If you are using any add-on controls to meet an ' 

emission limit in this subpart, you must conduct each 

performance test, performance evaluation, and design 

evaluation in 40 CFR part 63, subpart SS, that applies to 

you. 

(b) Each performance test must be conducted according 

to the reguirements in §63.7(e)(1) and under the specific 

conditions that 40 CFR part 63, subpart SS, specifies. 

(c) Each performance evaluation must be conducted 

according to the requirements in §63.8(e) and under the 

specific conditions that 40 CFR part 63, subpart SS, 

specifies. 

(d) You may not conduct performance tests or 

performance evaluations during periods of startup, shutdown, 
P.30 

127 

or malfunction, as specified in §63.7(e)(l). 

(e) You must conduct three separate test runs for each 

performance test required in this section, as specified in 

§63.7(e)(3). Each test run must last at least 1 hour. 

(f) You must conduct a design evaluation of any 

permanent total enclosures as specified by EPA Method 204. 

If your enclosure does not meet the Method 204 design and 

operation requirements for a permanent total enclosure, you 

must test the enclosure to determine the capture efficiency 

by Methods 2B through E or an alternative method that meets 

the data quality objectives and lower confidence limit 

approaches contained in 40 CFR part 63, subpart KK. Test 

runs for Methods 2B through E or alternative test methods 

must be at least 3 hours. 

§63.5855 What are my monitor installation and operation 

requirements? 

You must monitor and operate all add-on control devices 

according to the procedures in 40 CFR part 63, subpart SS. 

§63.5860 How do I demonstrate initial compliance with the 

standards? 

(a) You must demonstrate initial compliance with each 

emission standard in paragraphs (a) through (d) of §63.5805 

that applies to you, as shown in Tables 8 and 9 of this 

subpart. 

(b) If using an add-on control device, you must 

establish each site-specific operating limit in 40 CFR part 

63, subpart SS, that applies to you. 
P.31 

128 

Additional Compliance Calculation Procedures For 

Continuous Lamination/Casting Operations 

§63.5865 What data must I generate to demonstrate 

compliance with the standards for continuous 

lamination/casting operations? 

(a) For continuous lamination/casting affected sources 

complying with a percent reduction requirement, you must 

generate the data identified in Tables 10 and 11 of this 

subpart for each data requirement that applies to your 

facility. 

(b) For continuous lamination/casting affected sources 

complying with a lbs/ton limit, you must generate the data 

identified in Tables 11 and 12 of this subpart for each data 

requirement that applies to your facility. 

§63.5870 How do I calculate annual uncontrolled and 

controlled emissions from my wet-out area(s) and from my 

oven(s)? 

To calculate your annual uncontrolled and controlled 

emissions from your wet-out areas and from your ovens, you 

must develop uncontrolled and controlled wet-out area and 

uncontrolled and controlled oven emission estimation 

equations or factors to apply to each formula applied on 

each line, determine how much of each formula for each end 

product is applied each year on each line, and assign 

uncontrolled and controlled wet-out area and uncontrolled 

and controlled oven emission estimation equations or factors 

to each formula. You must determine the overall capture 
P.32 

129 

efficiency using the procedures in Table 6 of this subpart. 

(a) To develop uncontrolled and controlled emission 

estimation equations and factors, you must, at minimum, do 

the following as specified in paragraphs (a)(1) through (6) 

of this section: 

(1) Identify each end product and the thickness of each 

end product produced on the line. Separate end products 

into the following end product groupings, as applicable: 

corrosion-resistant gel coated end products, noncorrosionresistant gel coated end products, corrosion-resistant 

nongel coated end products, and noncorrosion-resistant 

nongel coated end products. This step creates end 

product/thickness combinations. 

(2) Identify each formula used on the line to produce 

each end product/thickness combination. Identify the amount 

of each such formula applied (need to specify a time frame). 

Rank each formula used to produce each end product/thickness 

combination according to usage within each end product/ 

thickness combination. 

(3) For each end product/thickness combination being 

produced, select the formula with the highest usage rate for 

testing. 

(4) If not already selected, also select the worst-case 

formula (likely to be associated with the formula with the 

highest HAP content, type of HAP, application of gel coat, 

thin product, low line speed, higher resin table 

temperature) amongst all formulae. (You may use the results 
P.33 

130 

of the worst-case formula test for all formulae if desired 

to limit the amount of testing required.) 

(5) For each formula selected for testing, conduct at 

least one test (consisting of three runs). During the test, 

track information on HAP content and type of HAP, end 

product thickness, line speed, and resin temperature on the 

wet-out area table. 

(6) Using the test results, develop uncontrolled and 

controlled emission estimation equations (or factors) or 

series of equations (or factors) that best fit the results 

for estimating uncontrolled and controlled emissions, taking 

into account the HAP content and type of HAP, end product 

thickness, line speed, and resin temperature on the wet-out 

area table. 

(b) In lieu of using the method specified in paragraph 

(a) of this section for developing uncontrolled and 

controlled emission estimation equations and factors, you 

may use any of the methods specified in paragraphs (b)(1) 

through (4) of this section, as applicable. 

(1) For either uncontrolled or controlled emission 

estimates, you may use previously established, facilityspecific emission equations or factors, provided they allow 

estimation of both wet-out area and oven emissions, where 

necessary, and have been approved by the regulatory agency. 

If a previously established equation or factor is specific 

to the wet-out area only or to the oven only, then you must 

develop the corresponding uncontrolled or controlled 
P.34 

131 

equation or factor for the other emission source. 

(2) For uncontrolled (controlled) emission estimates, 

you may use controlled (uncontrolled) emission estimates and 

control device destruction efficiency to calculate your 

uncontrolled (controlled) emissions provided the control 

device destruction efficiency was calculated at the same 

time you collected the data to develop your facility's 

controlled (uncontrolled) emission estimation equations and 

factors. 

(c) Assign to each formula an uncontrolled emission 

estimation equation or factor based on the end product/ 

thickness combination for which that formula is used. 

(d)(1) To calculate your annual uncontrolled emissions 

from wet-out areas that do not have any capture and control 

from wet-out areas that are captured by an enclosure but are 

vented to the atmosphere and not to a control device, 

multiply each formula's annual usage by its appropriate 

emission estimation equation or factor and sum the 

individual results. 

(2) To calculate your annual uncontrolled emissions 

that escape from the enclosure on the wet-out area, multiply 

each formula's annual usage by its appropriate uncontrolled 

emission estimation equation or factor, sum the individual 

results, and multiply the summation by 1 minus the percent 

capture (expressed as a fraction). 

(3) To calculate your annual uncontrolled oven 

emissions, multiply each formula's annual usage by its 
P.35 

132 

appropriate uncontrolled emission estimation equation or 

factor and sum the individual results. 

(4) To calculate your annual controlled emissions, 

multiply each formula's annual usage by its appropriate 

emission estimation equation or factor and sum the 

individual results to obtain total annual controlled 

emissions. 

(e) Where a facility is calculating both uncontrolled 

and controlled emission estimation equations and factors, 

you must test the same formulae. In addition, you must 

develop both sets of equations and factors from the same 

tests. 

§63.5875 How do I determine the capture efficiencv of the 

enclosure on my wet-out area and the capture efficiencv of 

my oven(s)? 

(a) The capture efficiency of a wet-out area enclosure 

is assumed to be 100 percent if it meets the design and 

operation requirements for a permanent total enclosure 

specified in EPA Method 204. If a permanent total enclosure 

does not exist, then a temporary total enclosure must be 

constructed and verified using Method 204, and capture 

efficiency testing must be determined using Methods 204B 

through E. 

(b) The capture efficiency of an oven is to be 

considered 100 percent provided the oven is operated under 

negative pressure. 

§63.5880 How do I determine how much neat resin plus is 
P.36 

133 

applied to the line and how much neat gel coat plus is 

applied to the line? 

Use the following procedures to determine how much neat 

resin plus and neat gel coat plus is applied to the line 

each year. 

(a) Track formula usage by end product/thickness 

combinations. 

(b) Use in-house records to show usage. This may be 

either from automated systems or manual records. 

(c) Record daily the usage of each formula/end product 

combination on each line. This is to be recorded at the end 

of each run (i.e., when a changeover in formula or product 

is made) and at the end of each shift. 

(d) Sum the amounts from the daily records to calculate 

annual usage of each formula/end product combination by 

line. 

§63.5885 How do I calculate the percent reduction to 

demonstrate compliance? 

(a) Compliant line option. If all of your wet-out 

areas have permanent enclosures that meet the requirements 

of Method 204 for a permanent total enclosure, and all of 

your wet-out area emissions and oven emissions are vented to 

an add-on control device, use Equation 1 of this section to 

demonstrate compliance. In all other situations, use 

Equation 2 of this section to demonstrate compliance. 
P.37 

134 

PR = dnlet) - (Outlet) x 1QQ {) 

(Inlet) 

Where: 

PR = percent reduction 

Inlet = emissions entering the control device, lbs 

per year 

Outlet = emissions exiting the control device to the 

atmosphere, lbs per year 

PR = 

(WAEu + 0u) - (WAEc + 0c) 

(WAE„ + 0n) 

x 100 (Eq. 2) 

Where: 

PR = 

WAEU = 

Ou = 

WAEC = 

Oc = 

percent reduction 

uncontrolled wet-out area emissions, lbs per 

year 

uncontrolled oven emissions, lbs per year 

controlled wet-out area emissions, lbs per 

year 

controlled oven emissions, lbs per year 

(b) Averaging Option. Use Equation 3 of this section 

to calculate percent reduction. 

PR = 

___ WAEu i + ___ Ou 

i=i j=i te WAEc i + £ Ocj 

£ WAEui + £ Ouj 

i-i J=i 

I- x 100 (Eq. 3) 

Where: 

PR 

WAE.., 

°

u j 

WAE., = 

percent reduction 

uncontrolled emissions from wet-out area 

i, lbs per year 

uncontrolled emissions from oven j , lbs 

per year 

controlled .emissions from wet-out area 
P.38 

135 

i, lbs per year 

Ocj = controlled emissions from oven j, lbs 

per year 

i = number of wet-out areas 

j = number of ovens 

m = number of wet-out areas uncontrolled 

n = number of ovens uncontrolled 

o = number of wet-out areas controlled 

p = number of ovens controlled 

(3) Add-on control device option. Use Equation 1 of 

this section to calculate percent reduction. 

(4) Combination option. Use Equations 1 through 3 of 

this section, as applicable, to calculate percent reduction. 

§63.5890 How do I calculate an emission factor to 

demonstrate compliance? 

(a) Compliant line option. Use Equation 1 of this 

section to calculate an emission factor in lbs/ton. 

WAE + WAE +0+ 0 

E = H £ H £ (Eq. 1) 

(R + G) 

Where: 

E = emission factor in lbs/ton of resin and 

gel coat 

WAEU = uncontrolled wet-out area emissions, lbs 

per year 

WAEC = controlled wet-out area emissions, lbs 

per year 

0U = uncontrolled oven emissions, lbs per 

year 

0C = controlled oven emissions, lbs per year 

R = total usage of neat resin plus, tpy 

G = total usage of neat gel coat plus, tpy 

(b) Averaging option. Use Equation 2 of this section 

to demonstrate compliance. 
P.39 

136 

£ WAE . + ___ WAE . + £ 0 . + T_ 0 . 

i = l i = l j = l j=l

 J vtq- ^) 

(R + G) 

Where: 

E = emission factor in lbs/ton of resin and gel 

coat 

WAEui = uncontrolled emissions from wet-out area i, 

lbs per year 

WAEci = controlled emissions from wet-out area i, lbs 

per year 

0uj = uncontrolled emissions from oven j , lbs per 

year 

0cj = controlled emissions from oven j , lbs per 

year 

i = number of wet-out areas 

j = number of ovens 

m = number of wet-out areas uncontrolled 

n = number of ovens uncontrolled 

o = number of wet-out areas controlled 

p = number of ovens controlled 

R = total usage of neat resin plus, tpy 

G = total usage of neat gel coat plus, tpy 

(c) Combination option. Use Equations 1 and 2 of this 

section, as applicable, to demonstrate compliance. 

Continuous Compliance Requirements 

§63.5895 How do I monitor and collect data to demonstrate 

continuous compliance? 

(a) You must collect and keep a record of data as 

indicated in 40 CFR part 63, subpart SS. 

(b) You must monitor and collect data as specified in 

paragraphs (b)(1) through (4) of this section. 

(1) Except for monitoring malfunctions, associated 

repairs, and required quality assurance or control 

activities (including, as applicable, calibration checks and 
P.40 

137 

required zero and span adjustments), you must conduct all 

monitoring in continuous operation (or collect data at all 

required intervals) at all times that the affected source is 

operating. 

(2) You may not use data recorded during monitoring 

malfunctions, associated repairs, and required quality 

assurance or control activities for purposes of this 

subpart, including data averages and calculations, or 

fulfilling a minimum data availability requirement, if 

applicable. You must use all the data collected during all 

other periods in assessing the operation of the control 

device and associated control system. 

(3) At all times, you must maintain necessary parts for 

routine repairs of the monitoring equipment. 

• (4) A monitoring malfunction is any sudden, infrequent, 

not reasonably preventable failure of the monitoring 

equipment to provide valid data. Monitoring failures that 

are caused in part by poor maintenance or careless operation 

are not malfunctions. 

(c) You must collect and keep records of resin and gel 

coat use, HAP content, and operation where the resin is used 

if you are meeting any emission limits based on a point 

value. Resin use records may be based on purchase records 

if you can reasonably estimate how the resin is applied. 

The HAP content records may be based on Material Safety Data 

Sheets or on resin specifications supplied by the resin 

supplier .IIS 
P.41 

138 

(d) If you initially demonstrate that all resin and gel 

coat meet the applicable point value emission limits, then 

resin and gel coat use records are not required. If after 

this initial demonstration you change to a higher HAP resin 

or gel coat, or the increase the resin or gel coat HAP 

content, or change to a higher emitting resin or gel coat 

application method, then you must either again demonstrate 

that all resins and gel coats still meet the applicable 

point value emission limits, or begin collecting resin use 

records and calculate compliance on a 12-month rolling 

average. 

(e) You must record all times that wet area enclosures 

on any pultrusion machines are open, and resin is present in 

the resin bath. 

§63.5900 How do I demonstrate continuous compliance with 

the standards? 

(a) You must demonstrate continuous compliance with 

each standard in §63.5805 that applies to you according to 

the methods specified in paragraphs (a)(1) through (3) of 

this section. 

(1) Compliance with emission limits for sources using 

add-on control devices is demonstrated following the 

procedures in 40 CFR part 63, subpart SS. Sources using 

add-on controls may also use continuous emission monitors to 

demonstrate continuous compliance as an alternative to 

control parameter monitoring. 

(2) Compliance with emission limits using the point 
P.42 

139 

value system is demonstrated by maintaining a point value 

less than or equal to the appropriate point value listed in 

Table 3 or 5 of this subpart, on a 12-month rolling average. 

(3) Compliance with the work practice standards in 

Table 4 of this subpart is demonstrated by performing the 

work practice required for your operation. 

(b) You must report each deviation from each standard 

that applies to you in §63.5805. The deviations must be 

reported according to the requirements in §63.5910. 

(c) With the exception provided in paragraph (d) of 

this section, during periods of startup, shutdown or 

malfunction, you must meet the emission limits and work 

practice standards that apply to you. 

(d) During periods of startup, shutdown, or 

malfunction, you do not need to meet the standard(s) in 

§63.5805 that require an add-on control device, but you must 

operate your affected source in accordance with the startup, 

shutdown, and malfunction plan and meet all standards that 

do not require the operation of the add-on control device. 

(e) Consistent with §§63.6(e) and 63.7(e)(1), 

deviations that occur during a period of malfunction for 

those affected sources and standards specified in paragraph 

(d) of this section are not violations if you demonstrate to 

the Administrator's satisfaction that you were operating in 

accordance with the startup, shutdown, and malfunction plan. 

The Administrator will determine whether deviations that 

occur during a period of startup, shutdown, and malfunction 
P.43 

140 

are violations, according to the provisions in §63.6(e). 

Notifications, Reports, And Records 

§63.5905 What notifications must I submit and when? 

(a) You must submit all of the notifications in Table 

13 of this subpart that apply to you, by the dates in Table 

13 of this subpart. The notifications are described more 

fully in subpart A, General Provisions, referenced in Table 

13. 

(b) If you change any information submitted in any 

notification, you must submit the changes in writing to the 

Administrator within 15 calendar days after the change. 

§63.5910 What reports must I submit and when? 

(a) You must submit each report in Table 14 of this 

subpart that applies to you. 

(b) Unless the Administrator has approved a different 

schedule for submission of reports under §63.10(a), you must 

submit each report by the date in Table 14 of this subpart 

and according to paragraphs (b)(1) through (5) of this 

section. 

(1) The first compliance report must cover the period 

beginning on the compliance date that is specified for your 

affected source in §63.5800 and ending on June 30 or 

December 31, whichever date is the first date following the 

end of the first calendar half after the compliance date 

that is specified for your source in §63.5800. 

(2) The first compliance report must be postmarked or 

delivered no later than July 31 or January 31, whichever 
P.44 

141 

date follows the end of the first calendar half after the 

compliance date that is specified for your affected source 

in §63.5800. 

(3) Each subsequent compliance report must cover the 

semiannual reporting period from January 1 through June 30 

or the semiannual reporting period from July 1 through 

December 31. 

(4) Each subsequent compliance report must be 

postmarked or delivered no later than July 31 or January 31, 

whichever date is the first date following the end of the 

semiannual reporting period. 

(5) For each affected source that is subject to 

permitting requirements pursuant to 40 CFR part 70 or 71, 

and if the permitting authority has established dates for 

submitting semiannual reports pursuant to §70.6(3)(iii)(A) 

or §71.6(3)(iii)(A), you may submit the first and subsequent 

compliance reports according to the dates the permitting 

authority has established instead of according to the dates 

in paragraphs (b)(1) through (4) of this section. 

(c) The compliance report must contain the information 

in paragraphs (c)(1) through (6) of this section: 

(1) Company name and address. 

(2) Statement by a responsible official with that 

official's name, title, and signature, certifying the truth, 

accuracy, and completeness of the content of the report. 

(3) Date of the report and beginning and ending dates 

of the reporting period. 
P.45 

142 

(4) If you had a startup, shutdown or malfunction 

during the reporting period and you took actions consistent 

with your startup, shutdown, and malfunction plan, the 

compliance report must include the information in 

§63.10(d)(5)(i). 

(5) If there are no deviations from any emission 

limitations (emission limit and operating limit) that 

applies to you, and there are no deviations from the 

requirements for work practice standards in Table 4 of this 

subpart, a statement that there were no deviations from the 

emission limitations or work practice standards during the 

reporting period. 

(6) If there were no periods during which the 

continuous monitoring system (CMS), including a continuous 

emission monitoring system (CEMS), and operating parameter 

monitoring systems was out of control as specified in 

§63.8(c)(7), a statement that there were no periods during 

the which, the CMS was out of control during the reporting 

period. 

(d) For each deviation from an emission limitation 

(i.e., emission limit, operating limit) and for each 

deviation from the requirements for work practice standards 

that occurs at an affected source where you are not using a 

CMS to comply with the emission limitations or work practice 

standards in this subpart, the compliance report must 

contain the information in paragraphs (c)(1) through (4) of 

this section and in paragraphs (d)(1) and (2) of this 
P.46 

143 

section. This includes periods of startup, shutdown, and 

malfunction. 

(1) The total operating time of each affected source 

during the reporting period. 

(2) Information on the number, duration, and cause of 

deviations (including unknown cause, if applicable), as 

applicable, and the corrective action taken. 

(e) For each deviation from an emission limitation 

(i.e., emission limit and operating limit) occurring at an 

affected source where you are using a CMS to comply with the 

emission limitation in this subpart, you must include the 

information in paragraphs (c) (1.) through (4) of this section 

and in paragraphs (e)(1) through (12) of this section. This 

includes periods of startup, shutdown, and malfunction. 

(1) The date and time that each malfunction started and 

stopped. 

(2) The date and time that each CMS was inoperative, 

except for zero (low-level) and high-level checks. 

(3) The date, time and duration that each CMS was out 

of control, including the information in §63.8(c)(8). 

(4) The date and time that each deviation started and 

stopped, and whether each deviation occurred during a period 

of startup, shutdown, or malfunction, or during another 

period. 

(5) A summary of the total duration of the deviation 

during the reporting period and the total duration as a 

percent of the total source operating time during that 
P.47 

144 

reporting period. 

(6) A breakdown of the total duration of the deviations 

during the reporting period into those that are due to 

startup, shutdown, control equipment problems, process 

problems, other known causes, and other unknown causes. 

(7) A summary of the total duration of CMS downtime 

during the reporting period and the total duration of CMS 

downtime as a percent of the total source operating time 

during that reporting period. 

(8) An identification of each hazardous air pollutant 

that was monitored at the affected source. 

(9) A brief description of the process units. 

(10) A brief description of the CMS. 

(11) The date of the latest CMS certification or audit. 

(12) A description of any changes in CMS, processes, or 

controls since the last reporting period. 

(f) Each affected source that has obtained a title V 

operating permit pursuant to 40 CFR part 70 or 71 must 

report all deviations as defined in this subpart in the 

semiannual monitoring report required by §70.6(3) (iii) (A) or 

§71.6 (3) (iii) (A). If an affected source submits a 

compliance report pursuant to Table 14 of this subpart along 

with, or as part of, the semiannual monitoring report 

required by §70.6(3) (iii) (A) or §71.6(3) (iii) (A), and the 

compliance report includes all required information 

concerning deviations from any emission limitation 

(including any operating limit) or work practice requirement 
P.48 

145 

in this subpart, submission of the compliance report shall 

be deemed to satisfy any obligation to report the same 

deviations in the semiannual monitoring report. However, 

submission of a compliance report shall not otherwise affect 

any obligation the affected source may have to report 

deviations from permit requirements to the permit authority. 

(g) You should submit compliance reports and startup, 

shutdown, malfunction reports based on the requirements in 

Table 14 of this subpart. You do not need to consider the 

requirements in §63.999 when submitting these reports. 

§63.5915 What records must I keep? 

(a) You must keep the records listed in paragraphs 

(a)(1) through (3) of this section. 

(1) A copy of each notification and report that you 

submitted to comply with this subpart, including all 

documentation supporting any Initial Notification or 

Notification of Compliance Status that you submitted, 

according to the requirements in §63.10(b)(2)(xiv). 

(2) The records in §63.6(e) (3)(iii) through (v) related 

to startup, shutdown, and malfunction. 

(3) Records of performance tests, design, and 

performance evaluations as required in §63.10(b)(2)(viii). 

(b) If you use an add-on control device, you must keep 

all records required in 40 CFR part 63, subpart SS, to show 

continuous compliance with this subpart. 

(c) You must keep all data, assumptions, and 

calculations used to determine point values for operations 
P.49 

146 

listed in Tables 3 and 5 of this subpart. 

(d) You must keep a certified statement that you are in 

compliance with the work practice requirements in Table 4 of 

this subpart, as applicable. 

(e) For a new or existing continuous lamination/ 

casting operation, you must keep the records listed in 

paragraphs (e)(1) through (4) of this section, when 

complying with the percent reduction and/or lbs/ton 

requirements specified in paragraphs (a) through (d) of 

§63.5805. 

(1) You must keep all data, assumptions, and 

calculations used to determine percent reduction and/or 

lbs/ton as applicable; 

(2) You must keep a brief description of the rationale 

for the assignment of an equation or factor to each formula; 

(3) When using facility-specific emission estimation 

equations or factors, you must keep all data, assumptions, 

and calculations used to derive the emission estimation 

equations and factors and identification and rationale for 

the worst-case formula; and 

(4) For all, emission estimation equations and emission 

factors, you must keep documentation that the appropriate 

regulatory agency has approved them. 

§63.5920 In what form and how long must I keep mv records? 

(a) You must maintain all applicable records in such a 

manner that they can be readily accessed and are suitable 

for inspection according to §63.10(b)(1). 
P.50 

147 

(b) As specified in §63.10(b)(1), you must keep each 

record for 5 years following the date of each occurrence, 

measurement, maintenance, corrective action, report, or 

record. 

(c) You must retain your records of the most recent 

2 years onsite, or your records must be accessible to an 

inspector while onsite. Your records of the remaining 

3 years may be retained offsite. 

Other Requirements And Information 

§63.5925 What parts of the General Provisions apply to me? 

Table 15 of this subpart shows which parts of the 

General Provisions in §§63.1 through 63.15 apply to you. 

§63.5930 Who implements and enforces this subpart? 

(a) This subpart can be administered by us, the EPA, or 

a delegated authority such as your State, local, or tribal 

agency. If the EPA Administrator has delegated authority 

to your State, local, or tribal agency, then that agency has 

the authority to administer and enforce this subpart. You 

should contact your EPA Regional Office to find out if. this 

subpart is delegated to your State, local, or tribal agency. 

(b) In delegating implementation and enforcement 

authority of this subpart to a State, local, or tribal 

agency under section 40 CFR part 63, subpart E, the 

authorities contained in paragraph (c) of this section are 

not delegated. 

(c) The authorities that will not be delegated to 

State, local, or tribal agencies are listed in paragraphs 
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148 

(c)(1) through (4) of this section: 

(1) Approval of alternatives to the emission standards 

in §63.5805 under §63.6(g). 

(2) Approval of major alternatives to test methods 

under §63.7(e)(2)(ii) and (f) and as defined in §63.90. 

(3) Approval of major alternatives to monitoring under 

§63.8(f) and as defined in §63.90. 

(4) Approval of major alternatives to recordkeeping 

and reporting under §63.10(f) and as defined in §63.90. 

§63.5935 What definitions apply to this subpart? 

Terms used in this subpart are defined in the Clean Air 

Act, in 40 CFR 63.2, the General Provisions, and in this 

section as follows: 

Atomized mechanical application means application of 

resin or gel coat with spray equipment that separates the 

liquid into a fine mist. This fine mist may be created by 

forcing the liquid under high pressure through an elliptical 

orifice, bombarding a liquid stream with directed air jets, 

or a combination of these techniques. 

Bulk molding compound (BMC) means a putty-like molding 

compound that contains resins, catalysts, fillers, and 

reinforcements in a form that is ready to mold. Bulk 

molding compound can be used in compression molding and 

injection molding operations to manufacture reinforced 

plastic composites products. 

BMC manufacturing means a process that involves the 

preparation of BMC. 
P.52 

149 

BMC manufacturing/mixing means a grouping of processes 

that involves BMC manufacturing and/or mixing. 

Centrifugal casting means a process for fabricating 

cylindrical composites, such as pipes, in which composite 

materials are positioned inside a rotating hollow mandrel 

and held in place by centrifugal forces until the part is 

cured. 

Charge means the amount of SMC or BMC that is placed 

into a compression or injection mold to complete one mold 

cycle. 

Cleaning means removal of composite materials, such as 

cured and uncured resin from equipment, finished surfaces, 

floors, hands of employees, or any other surfaces. 

Clear production gel coat means an unpigmented, 

unfilled, quick-setting resin used to improve the surface 

appearance and/or performance of composites. It can be used 

to form the surface layer of any composites other than those 

used for molds in tooling operations. 

Closed molding means a grouping of processes for 

fabricating composites in a way that HAP-containing 

materials are not exposed to the atmosphere except during 

the material loading stage (e.g., compression molding, 

injection molding, and resin transfer molding). 

Composite means a shaped and cured part produced by 

using composite materials. 

Composite materials means a combination of the 

following materials: resin, gel coat, monomer, catalyst, 
P.53 

150 

pigment, filler, and reinforcement. 

Compression molding means a closed molding process for 

fabricating composites in which composite materials are 

placed inside matched metal dies that are used to cure the 

materials under heat and pressure without exposure to the 

atmosphere. The composite materials used in this process 

are generally SMC or BMC. 

Compression/injection molding means a grouping of 

processes that involves the use of compression molding 

and/or injection molding. 

Continuous casting means a continuous process for 

fabricating composites in which composite materials are 

placed on an in-line conveyor belt to produce cast sheets 

that are cured in an oven. 

Continuous lamination means a continuous process for 

fabricating composites in which composite materials are 

typically sandwiched between plastic films, pulled through 

compaction rollers, and cured in an oven. This process is 

generally used to produce flat or corrugated products on an 

in-line conveyor. 

Continuous lamination/casting means a grouping of 

processes that involves the use of continuous lamination 

and/or continuous casting. 

Controlled emissions means those emissions that are 

vented from a control device to the atmosphere. 

Corrosion-resistant end-use applications means 

applications where the product is manufactured specifically 
P.54 

151 

for an application that requires a level of chemical 

inertness or resistance to chemical attack above that 

required for typical reinforced plastic composites products. 

These applications include chemical processing and storage; 

pulp and paper production; sewer and wastewater treatment; 

power generation; potable water transfer and storage; food 

and drug processing; pollution or odor control; metals 

production and plating; semiconductor manufacturing; 

petroleum production, refining, and storage; mining; textile 

production; nuclear materials storage; and cosmetic 

production, as well as end-use applications that require 

high strength. 

Corrosion-resistant industry standard includes the 

following standards: ASME RTP-1 or Sect. X; ASTM D5364, 

D3299, D4097, D2996, D2997, D3262, D3517, D3754, D3840, 

D4024, D4160, D4161, D4162, D4184, D3982, or D3839; 

ANSI/AWWA C950; UL 1316 or UL 1746, or written customer 

requirements for resistance to specified chemical 

environments. 

Corrosion-resistant product means a product made with a 

corrosion-resistant resin and is manufactured to a 

corrosion-resistant industry standard, or a food contact 

industry standard, or is manufactured for corrosionresistant end-use applications involving continuous or 

temporary chemical exposures. 

Corrosion-resistant resin means a resin that either: 

(1) Displays substantial retention of mechanical 
P.55 

152 

properties when undergoing ASTM C-581 coupon testing, where 

the resin is exposed for 6 months or more to one of the 

following materials: material with a pH > 12.0 or <. 3.0, 

oxidizing or reducing agents, organic solvents, or fuels or 

fuel additives as defined in 40 CFR 79.2. In the coupon 

testing, the exposed resin needs to demonstrate a minimum of 

50 percent retention of the relevant mechanical property 

compared to the same resin in unexposed condition. In 

addition, the exposed resin needs to demonstrate an 

, increased retention of the relevant mechanical property of 

at least 2 0 percent when compared to a similarly exposed 

general-purpose resin. For example, if the general-purpose 

resin retains 45 percent of the relevant property when 

tested as specified above, then a corrosion-resistant resin 

needs to retain at least 65 percent (45 percent plus 20 

percent) of its property. The general-purpose resin used in 

the test needs to have an average molecular weight of 

greater than 1,000, be formulated with a 1:2 ratio of maleic 

anhydride to phthalic anhydride and 100 percent diethylene 

glycol, and a styrene content between 43 to 48 percent; or 

(2) Complies with industry standards that require 

specific exposure testing to corrosive media, such as UL 

1316, UL 1746, or ASTM F-1216. 

Doctor box means the box or trough on an SMC machine 

into which the liquid resin paste is delivered before it is 

metered onto the carrier film. 

Filament winding means an open molding process for 
P.56 

153 

fabricating composites in which reinforcements are fed 

through a resin bath and wound onto a rotating mandrel. The 

materials on the mandrel may be rolled out or worked by 

using nonmechanical tools prior to curing. Resin 

application to the reinforcement on the mandrel by means 

other than the resin bath, such as spray guns, pressure-fed 

rollers, flow coaters, or brushes is not considered filament 

winding. 

Filled means that fillers have been added to a resin 

such that the amount of inert substances is at least 10 

percent by weight of the total resin plus filler mixture. 

Fillers means inert substances dispersed throughout a 

resin, such as calcium carbonate, alumina trihydrate, 

hydrous aluminum silicate, mica, feldspar, wollastonite, 

silica, and talc. Materials that are not considered to be 

fillers are glass fibers or any type of reinforcement and 

microspheres. 

Fluid impingement technology means a spray gun that 

produces an expanding non-misting curtain of liquid by the 

impingement of low-pressure uninterrupted liquid streams. 

Food contact industry standard means a standard related 

to food contact application contained in Food and Drug 

Administration's regulations at 21 CFR 177.2420. 

Gel coat application means a process where either clear 

production, pigmented production or tooling gel coat is 

applied. 

High strength resins means polyester resins which have 
P.57 

154 

a casting tensile strength of 10,000 pounds per square inch 

or more and which are used for manufacturing products that 

have high strength requirements such as structural members 

and utility poles. 

Injection molding means a closed molding process for 

fabricating composites in which composite materials are 

injected under pressure into a heated mold cavity that 

represents the exact shape of the product. The composite 

materials are cured in the heated mold cavity. 

Manual resin application means an open molding process 

for fabricating composites in which composite materials are 

applied to the mold by pouring or by using hands and 

nonmechanical tools, such as brushes and rollers. Materials 

are rolled out or worked by using nonmechanical tools prior 

to curing. The use of pressure-fed rollers and flow coaters 

to apply resin is not considered manual resin application. 

Material storage means an ancillary process which 

involves keeping HAP-containing materials, such as resins, 

gel coats, catalysts, monomers, and cleaners, in containers 

for any length of time. Containers may include bulk storage 

terminals, tanks, totes, vessels, and buckets. 

Mechanical resin application means an open molding 

process for fabricating composites in which composite 

materials (except gel coat) are applied to the mold by using 

mechanical tools such as spray guns, pressure-fed rollers, 

and flow coaters. Materials are rolled out or worked by 

using nonmechanical tools prior to curing. 
P.58 

155 

Mixing means the blending or agitation of any HAPcontaining materials in vessels that are 5.00 gallons (18.9 

liters) or larger. Mixing may involve the blending of 

resin, gel coat, filler, reinforcement, pigments, catalysts, 

monomers, and any other additives. 

Model point value equations means algebraic expressions 

that were derived to estimate the quantity of HAP emitted 

based on parameters that can be regulated. Parameters that 

can be regulated include resin and gel coat HAP content. 

Model point value equations were derived for open molding 

and centrifugal casting processes. They are used to 

calculate point values that reflect the relative emission 

control status of a process. Model point value equations 

are not to be used to estimate actual emissions because not 

all parameters that are known to affect emissions are 

incorporated into the equations. 

Mold means a cavity or matrix into or onto which the 

composite materials are placed and from which the product 

takes its form. 

Neat gel coat plus means gel coat plus any organic HAPcontaining materials that are added to the gel coat by the 

supplier or the facility, excluding catalysts and promoters. 

Neat gel coat plus does include any additions of styrene or 

methyl methacrylate monomer in any form, including in 

catalysts and promoters. 

Neat resin plus means neat resin plus any organic HAPcontaining materials that are added to the resin by the 
P.59 

156 

supplier or the facility. Neat resin plus does not include 

any added filler, reinforcements, catalysts, or promoters. 

Neat resin does include any additions of styrene or methyl 

methacrylate monomer in any form, including in catalysts and 

promoters. 

Non-atomized mechanical application means the use of 

application tools other than brushes to apply resin and gel 

coat that do not create a fine liquid mist. Examples 

include flow coaters, pressure fed rollers, and fluid 

impingement technology spray guns. 

Noncorrosion-resistant resin means any resin other than 

a corrosion-resistant resin or a tooling resin. 

Noncorrosion-resistant product means any product other 

than a corrosion-resistant product or a mold. 

Operation means a specific process typically found at a 

reinforced plastic composites facility. Examples of 

operations are noncorrosion-resistant manual resin 

application, corrosion-resistant mechanical resin 

application, pigmented gel coat application, mixing and 

storage. 

Operation Group means a grouping of individual 

operations based primarily on mold type. Examples are open 

molding, closed molding, and centrifugal casting. 

Open molding means a process for fabricating composites 

in a way that HAP-containing materials are exposed to the 

atmosphere. Open molding includes processes such as manual 

resin application, mechanical resin application, filament 
P.60 

157 

winding, and gel coat application. 

Pigmented production gel coat means a pigmented quicksetting resin used to improve surface appearance and/or 

performance of composites. It can be used to form the 

surface layer of any composites other than those used for 

molds in tooling operations. 

Point value means a relative measure of the use of 

emissions reductions techniques and their effectiveness. 

Model point value equations were developed for each open 

molding and centrifugal casting process to calculate point 

values, which have units of lbs of HAP emissions per ton of 

neat resin plus or neat gel coat plus used. Point values 

are calculated by using the appropriate model point value 

equation for a given process, multiplied by any applicable 

control factors. Control factors are used to incorporate 

emissions reductions achieved from add-on control devices. 

Polymer casting means a process for fabricating 

composites in which composite materials are ejected from a 

casting machine or poured into an open, partially open, or 

closed mold and cured. After the composite materials are 

poured into the mold, they are not rolled out or worked 

prior to curing. The composite materials may or may not 

include reinforcements. Products produced by the polymer 

casting process include cultured marble products and polymer 

concrete. 

Pultrusion means a continuous process for manufacturing 

composites that have a uniform cross-sectional shape. The 
P.61 

158 

process consists of pulling a fiber-reinforcing material 

through a resin impregnation chamber or bath and through a 

shaping die, where the resin is subsequently cured. There 

are several types of pultrusion equipment, such as open 

bath, resin injection, and direct die injection equipment. 

Resin transfer molding means a process for 

manufacturing composites whereby catalyzed resin is 

transferred or injected into a closed mold in which 

fiberglass reinforcement has been placed. 

Sheet molding compound (SMC) means a ready-to-mold 

putty-like molding compound processed into sheet form. The 

molding compound is sandwiched between a top and a bottom 

film, and it contains resins, catalysts, fillers, chemical 

thickeners, mold release agents, reinforcements, and other 

ingredients. Sheet molding compound can be used in 

compression molding to manufacture reinforced plastic 

composites products. 

SMC manufacturing means a.process which involves the 

preparation of SMC. 

Tooling means mold production or repair. 

Tooling gel coat means a gel coat that is used to form 

the surface layer of molds. Tooling gel coats generally 

have high heat distortion temperatures, low shrinkage, high 

barcol hardness, and high dimensional stability. 

Tooling resin means a resin that is used to produce 

molds. Tooling resins generally have high heat distortion 

temperatures, low shrinkage, high barcol hardness, and high 
P.62 

159 

dimensional stability. 

Uncontrolled oven emissions means those emissions 

emitted from the oven through closed vent systems to the 

atmosphere and not to a control device. These emissions do 

not include emissions that may escape into the workplace 

through the opening of panels or doors on the ovens or other 

similar fugitive emissions in the workplace. 

Uncontrolled wet-out area emissions means any or all of 

the following: emissions from wet-out areas that do not have 

any capture and control, emissions that escape from wet-out 

area enclosures, and emissions from wet-out areas that are 

captured by an enclosure but are vented to the atmosphere 

and not to an add-on control device. 

Unfilled means that there has been no addition of 

fillers to a resin or that less than 10 percent of fillers 

by weight of the total resin plus filler mixture has been 

added. 

Vapor suppressant means an additive, typically a wax, 

that migrates to the surface of the resin during curing and 

forms a barrier to seal in the styrene and reduce styrene 

emissions. 

Vapor-suppressed resin means a resin containing a vapor 

suppressant added for the purpose of reducing styrene 

emissions during curing. 
P.63 

160 

Table 1 to Subpart WWWW - Model Equations to Calculate Point 

Values for Specific Open Molding and Centrifugal Casting 

Process Streams 

If your operation And you 

type is a new or use... 

existing... 

With. Use this Model Point Value (PV) 

Equation "'

 b' c. .. 

1.open molding 

operation 

manual 

resin 

application 

nonvaporsuppressed 

resin 

PV = 0.028 x (%HAP) 

vaporsuppressed 

resin 

PV = 0.028 x (%HAP)2'

275 x 

(1-(0.5419 x VSR test value)) 

vacuum 

bagging/ 

closed-mold 

curing with 

roll out 

PV = 0.028 x <%HAP)2'-75 x (1-

0.2133) 

vacuum 

bagging/ 

closed-mold 

curing 

without 

roll-out 

PV = 0.028 x (%HAP)2'

275 x (1-

0.4554) 

mechanical 

resin 

application 

nonvaporsuppressed 

resin and 

atomized 

application 

PV = 0.028 x (%HAP)' 

vaporsuppressed 

resin and 

atomized 

application 

PV = 0.028 x (%HAP)2'

425 x (1-

(0.4559 x VSR test value)) 

vacuum 

bagging/ 

closed-mold 

curing with 

roll-out and 

atomized 

application 

PV = 0.028 x (%HAP)2,a25 x (1-

0.1535) 

vacuum 

bagging/ 

closed-mold 

curing 

without 

roll-out and 

atomized 

application 

PV = 0.028 x (%HAP)2"

5 x (1-

0.3261) 

nonvaporsuppressed 

resin and 

nonatomized 

application 

PV = 0.028 x (%HAP)' 

vaporsuppressed 

resin and 

nonatomized 

application 

PV = 0.028 x (%HAP)2'

275 x (1-

(0.5419 x VSR test value)) 
161 

P.64 

filament 

winding 

closed-mold 

curing with 

roll-out and 

non atomized 

application 

PV = 0.028 x (%HAP)2'

27S x (1-

0.2133) 

vacuum 

bagging/ 

closed-mold 

curing 

without 

roll-out and 

nonatomized 

application 

PV = 0.02 8 x (%HAP) 227 5 x 

0.4554 ) 

(1-

nonvaporsuppressed 

resin 

PV = 1.675 x (%HAP)] 

vaporsuppressed 

resin 

gel coat nonvaporapplication suppressed 

gel coat 

PV = 1.675 x (%HAP)'-225 x (1-

(0.4693 x VSR test value)) 

PV = 0.890 x (%HAP)*'675 

2. centrifugal 

casting operation 

centrifugal 

casting 

nonvaporsuppressed 

resin 

PV 11.16 x (%HAP) 

a To obtain the model point value for an operation with an add-on control device 

multiply the PV above by the add-on control factor calculated using Equation 1 

of §63.5810. The model point values have limits of lbs of HAP per ton of resin 

or gel coat applied. 
P.65 

162 

b %HAP means total weight % of HAP in the resin or gel coat prior to the addition 

of fillers, catalyst, and promoters. 

c VSR test value means the percent reduction in HAP emissions expressed as a 

decimal measured by the VSR test method. 
163 

Table 2 To Subpart WWWW - Compliance Dates for New and 

Existing Reinforced Plastic Composites Facilities • 

If your facility 

is. . . 

and.•• then you must comply by this 

date: 

1. an existing 

source 

is a major source on or 

before the publication 

date of the final rule 

[date 3 years after the 

publication date of the final 

rule], or 

you must accept and meet an 

enforceable HAP emission limit 

below the major source 

threshold prior to [date 3 

years after the publication 

date of the final rule]. 

t-.—an uxibLluyj 

s um ce 

ih. a luajui—buuiLe un ui 

bufui'u Llie yublXLALIUII 

ddLfe 

and 

iL Lliu fina l lulu . 

lici£} uyun muldiuy ur 

uunLiifuyd l uasLiu y 

oyeidLiuiib—LhaL ai a 

uuiuylyiny wit h yuinL 

VdiUUb un a 12LJlllUlltll 

xullin y avuidy u bat>it> 

[JaLu 2 yuait. afLui—the 

yubliuaLiu n dat e ul—Lliu fina l 

mle ] ,—or 

yuu mutL auuuyL and muuL an 

uufuiuuabl e HAP uinifafaiuii limi t 

buluw Lliu ma J Ul bUUJ. UU 

Lluubliuld yiiui—to—[daLu 3 

yeai b afLui—Lliu yubliiaLiu n 

daLu u£—Lliu fina l lulu ] .— 

2-3-. an existing 

source that is an 

area source 

becomes a major source 

after the publication 

date of the final rule 

3 years after becoming a major 

source or [date 3 years after 

the publication date of the 

final rule], whichever is 

later. 

4-.—an WAitLiny 

bumue LhaL it. au 

aiua bUUlL c 

bcrt_uiiies. a majui sumc u 

alLu i Lliu yubliuaLiu n 

dat e uf—Lliu fina l lul u 

and 

tars- muldiuy u i 

cuuLiifuya l uabLiny 

upuiaLiuiib—LhaL ai u 

Luiuylyiiiy—wiLli yuinL 

valuufa un a lS^wuiiLli 

rullin y avuiay u bafaifa 

2 yuai b afLu i buuuiuiny a itiajui 

t>uuiuu ui—[daLu 2 yuai b afLur 

Lliu yubliuaLiu u daLu u£ Lliu 

fina l mlu ] , wliiuhuvui—rs' 

laLui . 

'3'S. a new source is a major source at 

startup 

upon startup or [publication 

date of the final rule], 

whichever is later. 

S-6. a new source is an area source at 

startup and becomes a 

major source 

Immediately upon becoming a 

major source. 

Table 3 to Subpart WWWW - Emission Limits for Existing Small 

Business Sources Emitting Less Than 250 TPY of HAP, or Other 

Sources Emitting Less Than 100 TPY of HAP 

I£ your 

operation type 

is... 

And you use. Your emission limit is 

1. Open molding 

- corrosionresistant (cr)b 

Mechanical resin 190 lb/ton 

...3Pi?.L4.SS!r.i.?.??. 

,..?!iiMl§P..t.. windin g l.?.3...ib/tgn_i 
P.67 

164 

Manual resin 

application 

Mechanical resin 

application-unfilled 

Mechanical resin 

application-filled 

Filament winding 

Manual resin 

application 

Mechanical resin 

application 

Manual resin 

application 

Mechanical resin 

application 

Filament winding 

Manual resin 

application 

Tooling gel coating 

White/off white 

pigmented gel coating 

All other pigmented 

gel coating 

Clear production gel 

coating 

124 

110 

144 

178 

83 

256 

123 

575 

253 

311 

394 

265 

377 

504 

536 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/tonlb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

lb/ton 

2 . Open moldin g 

- non-cr 

3 . Open moldin g 

- tooling 

4. Open molding 

- products that 

require class 1 

fire and smoke 

ratings 

5. Open molding 

- gel coat 

6. Centrifugal 

....9.§.$£.ing...-....9„r. 

7. Centrifugal 396 lb/ton 

....9.§.?..tin2...7...non-cr 

8. Pultrusion reduce total HAP emissions 

by at least 60 weight 

jaercent 

9. Continuous reduce total HAP emissions 

lamination/ by at least 58.5 weight 

Casting percent or 

not exceed an emission 

limit of 15.7 lbs of HAP 

per ton of neat resin plus 

and nest gel cost plus 

* Emission limits for open molding and centrifugal casting expressed as 

lb/ton are point values calculated using the equations shown in Table 1 

of this subpart. You must be at or below these values based on a 12-

month rolling average. 

b Corrosion-resistant applications also include high-strength products. 

Table 4 to Subpart WWWW - Work Practice Standards 

For ; You must....' 

1. a new or existing 

closed molding operation 

using 

compression/injection 

molding^ 

uncover, unwrap or expose onlyone charge per mold cycle per 

compression/injection molding 

machine 

2. a new or existing 

cleaning operation 

not use Cleaning solvents that 

contain HAP 
P.68 

165 

3. a new or existing keep containers that store HAP 

materials storage materials closed or covered 

operation except during the addition or 

remp^val___o^^__mate£i_als 

4. an existing pultrusion keep access panels, doors, 

operation using a wet-area and/or hatches closed whenever 

enclosure resin is in the bath, except 

that access panels, doors, 

and/or hatches may be open 30 

minutes per 8-hour shift, or 45 

minutes .per_^ 

5. an existing SMC close or cover the doctor box on 

manufacturing operation each SMC manufacturing machine 

6. an existing SMC fold or seal edges of SMC prior 

manufacturing operation to storage and/or transport 

7. an existing SMC use a nylon film or a film with 

manufacturing operation an equal or lower permeability 

to styrene than nylon to enclose 

SMC 

8. a new or existing BMC use mixer covers with no visible 

manufacturing/ gaps present in the mixer covers 

mixing;...operation__a 

9. an existing BMC not actively vent mixers to the 

manufacturing/mixing atmosphere 

10. a new or existing BMC keep the mixer covers closed 

manufacturing/ during mixing except when adding 

mixing operation

 a materials to the mixing vessels 

a Containers of 5 gallons or less may be open when active 

mixing is taking place, or during periods when they are in 

process (i.e., they are actively being used to apply resin). 

For polymer casting mixing operations, containers of 21 

gallons or less may be open while active mixing is taking 

place. 

Table 5 to Subpart WWWW - Alternative Emission Limits for 

Open Molding and Centrifugal Casting Operations Where the 

Standard Is Based on a Percent Reduction Requirement 

If your Your emission 

operation And you use... limit is °... 

type is... 

1. Open Mechanical Resin 10 lb/ton 

Molding - ...Application 

Corrosion- "Fiiamen^wTiiidTng 9 lb/tori 

Resistant 

(CR) Manual Resin Application 7 lb/ton 

2. Open Mechanical Resin 8 lb/ton 

Molding - Application-Unfilled 

"Nbn-CR

 : 
P.69 

166 

Mechanical Resin 6 lb/ton 

Application-Filled 

...Fiiament___Windino;_ .?....lk/.£.9n. 

Manual....Resin:„ Application .*L..lk/.t:9n. 

3. Open Mechanical Resin 13 lb/ton 

Molding - Application 

Tooling Manual Resin Application 7 lb?ton 

4. Open Mechanical Resin 29 lb/ton 

Molding - Application 

Products that . Filament Winding 13 lb/ton 

require Class 

1 Fire and Manual Resin Application 16 lb/ton 

Smoke Ratings 

5 . Open ...Top 1 ino; Gel Coat ing .?. iL.lb 1.£ p n 

Molding - Gel White/off white Pigmented 14 lb?'ton 

Coat ...Gel...Coating. 

A ll other Pigmented Gel 19 lb/ton 

Coating . 

Clear Production Gel 26 lb/ton 

Coating 

6.Centrifugal 27 lb?"ton 

....Casting - CR 

7.Centrifugal 20 lb/ton 

Casting -

...Non-CR... 

a The emission limits are calculated using the equations 

shown in Table 1 of this subpart. You must be at or below 

these values based on a 12-month rolling average. 

b Corrosion-resistant applications also include high-strength 

products. 
P.70 

167 

Table 6 to Subpart WWWW - Basic Requirements for Performance 

Tests, Performance Evaluations, and Design Evaluations for 

New and Existing Sources Using Add-On Control Devices 

For ... You must Using According to the 

following 

recruirements. 

1. each 

enclosure 

used to 

collect and 

route HAP 

emissions to 

an add-on 

control 

device 

determine the 

capture 

efficiency of 

each enclosure 

used to 

capture HAP 

emissions sent 

to an add-on 

control device 

Method 204 and 

Methods 2 04B 

through E in 

Appendix M of 

40 CFR part 

51, or 

an alternative 

test method 

that meets the 

data quality 

objectives and 

lower 

confidence 

limit 

approaches for 

alternative 

capture 

efficiency 

protocols and 

test methods 

contained in 

40 CFR part 63 

subpart KK, 

appendix A. 

Enclosures that 

meet the 

requirements for 

a permanent 

total enclosure 

are assumed to 

have a capture 

efficiency of 

100%. Enclosures 

that do not meet 

permanent total 

enclosure 

requirements 

must determine 

the capture 

efficiency by 

constructing a 

temporary total 

enclosure 

according to the 

requirements of 

Method 204 and 

measuring the 

mass flow rates 

of the HAP in 

the exhaust 

streams going to 

the atmosphere 

and to the 

control device, 

or 

use an 

alternative test 

method that 

meets the 

requirements of 

40 CFR part 51 

appendix M. 
168 

P.71 

2. each 

control 

device used 

to comply 

with an 

percent 

reduction 

requirement, 

or a point 

value limit 

determine the 

control 

efficiency of 

each control 

device used to 

control HAP 

emissions 

the 

appropriate 

test methods 

specified in 

40 CFR part 

63, subpart 

SS. 

Testing and 

evaluation 

requirements are 

contained in 40 

CFR part 63, 

subpart SS. 

3. each 

control 

device used 

to comply 

with a 

emission 

factor limit 

for 

continuous 

lamination/ 

continuous 

casting 

determine the 

control 

efficiency of 

each control 

the 

appropriate 

test methods 

specified in 

Testing and 

evaluation 

requirements are 

contained in 40 

device used to 40 CFR part 63 CFR part 63, 

control HAP subpart SS. subpart SS. 

emissions, or 

determine the 

mass HAP 

emission rate 

at the control 

device outlet 
169 

P.72 

Table 7 to Subpart WWWW - Options Allowing Use of the Same 

Resin Across Different Operations That Use the Same Resin 

Type 

If your facility 

has the 

following resin 

application 

operation... 

1. Corrosionresistant (CR) 

nonatomized 

mechanical 

2. CR 

centrifugal 

casting 

3. CR filament 

winding 

4. Non-CR 

filament winding 

5. Non-CR 

nonatomized 

filled 

mechanical 

6. Non-CR 

nonatomized 

unfilled 

mechanical 

7. Non-CR 

centrifugal 

casting 

8. Non-CR 

atomized filled 

mechanical 

9. Non-CR manual 

10. Tooling 

nonatomized 

mechanical 

11. Tooling 

atomized 

mechanical 

The highest resin 

weight percent HAP 

content you can use 

for... 

CR Mechanical 

CR Filament Winding 

CR Manual 

CR Centrifugal Casting 

CR Filament Winding 

CR Manual 

CR Centrifugal Casting 

CR Filament Winding 

CR Manual 

Non-CR Mechanical 

(filled or unfilled) 

Non-CR manual. 

Non-CR centrifugal 

casting 

Non-CR nonatomized 

unfilled mechanical 

Non-CR Manual 

Non-CR centrifugal 

casting 

Non-CR manual 

Non-CR centrifugal 

casting 

Non-CR manual 

Non-CR atomized filled 

mechanical 

Non-CR Manual 

Non-CR atomized 

unfilled mechanical 

tooling manual 

tooling manual 

is... 

48.3 

48 

42 

45 

42.8 

38 

35.5 

33.9 

33.6 

55.1 

43 

The point 

value 

assigned to 

all uses of 

this resin 

is. .. 

190 

536 

163 

178 

144 

110 

396 

144 

83 

256 

256 
P.73 

170 

Table 8 to Subpart WWWW - Initial Compliance With Emission 

Limits 

For ... That must meet 

the following 

emission limit, 

You have demonstrated initial 

compliance if... 

1. Open 

molding and 

centrifugal 

casting 

operations, 

A point value 

emission limit 

shown in Table 

or 5 of this 

subpart 

you have met the appropriate 

point value for these 

operations as calculated 

using the procedures in 

§63.5810 on a 12-month 

rolling average 

_the_ 1 yudi—af tei—the 

appropriate compliance date 

2. Open 

molding, 

centrifugal 

casting, 

continuous 

lamination/ 

casting, SMC 

manufacturing, 

mixing/BMC 

manufacturing 

operations, 

reduce total HAP 

emissions by at 

least 95 percent 

by weight 

total HAP emissions, based on 

the results of the capture 

efficiency and destruction 

efficiency testing specified 

in Table 6 of this subpart, 

are reduced by at least 95 

percent by weight, 

3.Continuous 

lamination/ 

casting 

operations 

reduce total HAP 

emissions by at 

least 58.5 weight 

percent or 

not exceed an 

emission limit of 

15.7 lbs of HAP 

per ton of neat 

resin plus and 

neat gel coat 

plus 95 percent 

by weight 

total HAP emissions, based on 

the results of the capture 

efficiency and destruction 

efficiency testing specified 

in Table 6 of this subpart 

and the calculation 

procedures specified in 

§§63.5865 through 63.5890, 

are reduced by at least 58.5 

percent by weight or 

total HAP emissions, based on 

the results of the capture 

efficiency and destruction 

efficiency testing specified 

in Table 6 of this subpart 

and the calculation 

procedures specified in 

§§63.5865 through 63.5890, do 

not exceed 15.7 lbs of HAP 

per ton of neat resin plus 

and neat gel coat plus 
P.74 

171 

4.Continuous reduce total HAP 

lamination/ emissions by at 

casting least 95 weight 

operations percent or 

not exceed an 

emission limit of 

1.47 lbs of HAP 

per ton of neat 

resin plus and 

neat gel coat 

plus 95 percent 

by weight 

total HAP emissions, based on 

the results of the capture 

efficiency and destruction 

efficiency testing specified 

in Table 6 of this subpart 

and the calculation 

procedures specified in 

§§63.5865 through 63.5890, 

are reduced by at least 95 

percent by weight or 

total HAP emissions, based on 

the results of the capture 

efficiency and destruction 

efficiency testing specified 

in Table 5 and the 

calculation procedures 

specified in §§63.5865-

63.5890, do not exceed 1.47 

lbs of HAP per ton of neat 

resin plus and neat gel coat 

plus 

5.Pultrusion reduce total HAP 

operations emissions by at 

least 60 percent 

by weight 

total HAP emissions, based on 

the results of the capture 

efficiency and add-on control 

device destruction efficiency 

testing specified in Table 6 

of this subpart, are reduced 

by at least 60 percent by 

weight, or 

as part of the notification 

of initial compliance status, 

the owner/operator submits a 

certified statement that all 

pultrusion lines not 

controlled with an add-on 

control device are using 

direct die injection and/or 

wet-area enclosures that meet 

the criteria of §63.5825. 
P.75 

172 

6.Pultrusion reduce total HAP 

operations emissions by at 

least 95 percent 

by weight 

total HAP emissions, based on 

the results of the capture 

efficiency and add-on control 

device destruction efficiency 

testing specified in Table 6 

of this subpart, are reduced 

by at least 95 percent by 

weight, or 

as part of the notification 

of initial compliance status, 

the owner/operator submits a 

certified statement that all 

pultrusion lines not 

controlled by an add-on 

control device are using 

direct die injection that 

meets the criteria of 

§63.5825. 
P.76 

Table 9 to Subpart WWWW. 

Practice Standards 

173 

Initial Compliance With Work 

For ... That must meet 

the following 

standard... 

You have demonstrated 

initial compliance if. 

1. a new or 

existing closed 

molding 

operation using 

compression/ 

injection 

molding 

uncover, unwrap 

or expose only 

one charge per 

mold cycle per 

compression/ 

injection molding 

machine 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status that 

only one charge is 

uncovered, unwrapped or 

exposed per mold cycle 

per compression/ 

injection molding machine 

2. an existing 

SMC 

manufacturing 

operation 

close or cover 

the doctor box on 

each SMC 

manufacturing 

machine 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status that 

the doctor box on each 

SMC manufacturing machine 

is closed or covered 

3. an existing 

SMC 

manufacturing 

operation 

fold edges of SMC 

prior to storage 

and/or transport 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status that 

the edges of SMC are 

folded prior to storage 

and/or transport 

4. an existing 

SMC 

manufacturing 

operation 

use nylon film or 

a film with an 

equal or lower 

permeability to 

styrene than 

nylon to enclose 

SMC 

the owner or operator 

submits a certified 

statement in the notice 

of.compliance status that 

a nylon film or film with 

an equal or lower 

permeability to styrene 

than nylon is used to 

enclose SMC 

5. a new or 

existing BMC 

manufacturing/mi 

xing operation 

use mixer covers 

with no visible 

gaps present in 

the mixer covers 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status that 

each mixer is equipped 

with a cover that does 

not contain any visible 

gaps 
174 

P.77 

6. an existing 

BMC 

manufacturing/mi 

xing operation 

keep the mixer 

covers closed 

during mixing 

except when 

adding materials 

to the mixers 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status that 

mixer covers are closed 

during mixing except when 

adding materials to the 

mixers 

7. an existing 

BMC 

manufacturing/mi 

xing 

not actively vent the owner or operator 

mixers to the submits a certified 

atmosphere statement in the notice 

of compliance status that 

mixers are not actively 

vented to the atmosphere 

Table 10 to Subpart WWWW - Data Requirements for New and 

Existing Continuous Lamination Lines and Continuous Casting 

Lines Complying with a Percent Reduction Limit on a Per Line 

Basis 

For each line 

where the wetout area... 

And the 

oven... 

You must determine... 

1. has an 

enclosure that 

is not a PTE 

and the 

captured 

emissions are 

controlled by 

an add-on 

control device 

is annual uncontrolled wet-out 

uncontrolled area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

the capture efficiency of 

the wet-out area enclosure; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 
P.78 

175 

2. has an 

enclosure that 

is a PTE and 

the captured 

emissions are 

controlled by 

an add-on 

control device 

is annual uncontrolled wet-out 

uncontrolled area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

that the wet-out area 

enclosure meets the 

requirements of Method 204 

for a PTE; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 

3. is 

uncontrolled 

is 

controlled 

by an add-on 

control 

device 

annual uncontrolled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

annual controlled oven 

emissions; 

the capture efficiency of 

the oven; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 
P.79 

176 

4. has an 

enclosure that 

is not a PTE 

and the 

captured 

emissions are 

controlled by 

an add-on 

control device 

is 

controlled 

by an add-on 

control 

device 

annual uncontrolled wet-out 

area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

annual controlled oven 

emissions; 

the capture efficiency of 

the wet-out area enclosure; 

inlet emissions to the addon control device; 

outlet emissions from the 

add-on control device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 

5. has an 

enclosure that 

is a PTE and 

the captured 

emissions are 

controlled by 

an add-on 

control device 

is 

controlled 

by an add-on 

control 

device 

that the wet-out area 

enclosure meets the 

requirements of Method 204 

for a PTE; 

the capture efficiency of 

the oven; and 

the destruction efficiency 

of the add-on control 

device. 

Table 11 to Subpart WWWW - Data Requirements for New and 

Existing Continuous Lamination and Continuous Casting Lines 

Complying with a Percent Reduction Limit or a Lbs/Ton Limit 

on an Averaging Basis 

For each That You must determine 

1. wet-out 

area 

is uncontrolled annual uncontrolled wetout area emissions. 
P.80 

2. wet-out 

area 

177 

has an enclosure 

that is not a 

PTE 

the capture efficiency of 

the enclosure; and 

annual emissions that 

escape the enclosure. 

3. wet-out 

area 

has an enclosure 

that is a PTE 

that the enclosure meets 

the requirements of 

Method 204 for a PTE. 

4. oven 

5. line 

is uncontrolled annual uncontrolled oven 

emissions. 

is controlled or 

uncontrolled 

the amount of neat resin 

plus applied; and 

the amount of neat gel 

coat plus applied. 

6. add-on 

control 

device 

total annual inlet 

emissions; and 

total annual outlet 

emissions. 

Table 12 to Subpart WWWW. Data Requirements for New and 

Existing Continuous Lamination Lines and Continuous Casting 

Lines Complying with a Lbs/Ton on a Per Line Basis 

For each line 

where the wetout area ... 

And the oven You must determine 

1. is 

uncontrolled 

is 

uncontrolled 

annual uncontrolled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; and 

annual neat resin plus and 

neat gel coat plus applied. 
P.81 

178 

2. has an 

enclosure that 

is not a PTE 

and the 

captured 

emissions are 

controlled by 

an add-on 

control device 

is annual uncontrolled wet-out 

uncontrolled area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

the capture efficiency of 

the wet-out area enclosure; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 

.3. has an 

enclosure that 

is a PTE, and 

the captured 

emissions are 

controlled by . 

an add-on 

control device 

is annual uncontrolled wet-out 

uncontrolled area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

that the wet-out area 

enclosure meets the 

requirements of Method 204 

for a PTE; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 
P.82 

179 

4 . is 

uncontrolled 

is 

controlled 

by an add-on 

control 

device 

annual uncontrolled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

annual controlled oven 

emissions; 

the capture efficiency of 

the oven; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 

5. has an 

enclosure that 

is not a PTE 

and the 

captured 

emissions are 

controlled by 

an add-on 

control device 

is 

controlled 

by an add-on 

control 

device 

annual uncontrolled wet-out 

area emissions; 

annual controlled wet-out 

area emissions; 

annual uncontrolled oven 

emissions; 

annual controlled oven 

emissions; 

the capture efficiency of 

the wet-out area enclosure; 

the capture efficiency of 

the oven; 

the destruction efficiency 

of the add-on control 

device; and 

the amount of neat resin 

plus and neat gel coat plus 

applied. 
P.83 

180 

6. has an 

enclosure that 

is a PTE, and 

the captured 

emissions are 

controlled by 

an add-on 

control device 

is 

controlled 

by an add-on 

control 

device 

that the wet-out area 

enclosure meets the 

requirements of Method 2 04 

for a PTE; 

the capture efficiency of' 

the oven; 

inlet emissions to the addon control device; and 

outlet emissions from the 

add-on control device. 

Table 13 to Subpart WWWW. Applicability and Timing of 

Notifications 

If your 

facility... 

You must submit, By this date. 

1. is an 

existing 

source 

subject to 

this 

regulation 

an Initial 

Notification 

containing the 

information specified 

in §63.9(b)(2) 

No later than the 

dates specified in 

§63.9(b)(2) 

2. i s a new 

source 

subject to 

this 

regulation 

the notifications 

specified in 

§63.9(b)(3) to (5) 

No later than the 

dates specified 

§63.9(b)(4) and 

(5) 

3. qualifies 

for a 

compliance 

extension as 

specified in 

§63.9(c) of 

subpart A 

a request for a 

compliance extension 

as specified in 

§63.9(c) 

No later than the 

dates specified in 

§63.6(i) 

4 . ffi-scomplying 

with model 

point value 

averaging 

piuvisioiifc 

• a Nutificatiuii of 

Compliance Status ab 

specified in 563.9(h)! 

No latei—than 1 

year plus 30 days 

after your 

faciliLy's 

cornp 11duee daLe. g< 
181 

P.84 

5 T is 

complying 

with HAP 

content 

limits, 

application 

equipment 

requirements, 

^o r ^emi s s i on 

liittiL othe r 

Lhan model 

point value 

averaging 

provisions., 

2£_9_tfeer 

emission 

limit 

a Notification of 

Compliance Status as 

specified in §63.9(h) 

No later than 30 

calendar days 

after your 

facility's 

compliance date. 

5*6*. is 

complying by 

using an addon control 

device and is 

not complying 

by meeting a 

model point 

value in 

Table 5 

a notification of 

intent to conduct a 

performance test as 

specified in §63.9(e) 

No later than the 

date specified in 

§63.9(e). 

a notification of the 

date for the CMS 

performance evaluation 

as specified in 

§63.9(g) 

Submit with the 

notification of 

intent to conduct 

a performance 

test. 

a Notification of 

Compliance Status as 

specified in §63.9(h) 

No later than 60 

calendar days 

after the 

completion of the 

add-on control 

device performance 

test and CMS 

performance 

evaluation 
P.85 

182 

Table 14 to Subpart WWWW - Requirements for Reports 

You must submit The report must contain... 

a(n) 

You must submit 

the report... 

1. compliance 

report 

If there are no deviations from 

any emission limitations 

(emission limit, operating 

limit, opacity limit, and 

visible emission limit) that 

applies to you and there are no 

deviations from the requirements 

for work practice standards in 

Table 4 of this subpart that 

apply to you, a statement that 

there were no deviations from 

the emission limitations and 

work practice standards during 

the reporting period. If there 

were no periods during which the 

CMS, including CEMS, and 

operating parameter monitoring 

systems, was out of control as 

specified in §63.8(c)(7), a 

statement that there were no 

periods during the which the CMS 

was out of control during the 

reporting period. 

If you have a deviation from any 

emission limitation (emission 

limit, operating limit, or work 

practice standard) during the 

reporting period, the report 

must contain the information in 

§63.5910(d). If there were 

periods during which the CMS, 

including.CEMS, and operating 

parameter monitoring systems, 

was out of control, as specified 

in §63.8(c)(7), the report must 

contain the information in 

§63.5910(e). 

If you had a startup, shutdown 

or malfunction during the 

reporting period, and you took 

actions consistent with your 

startup, shutdown, and 

malfunction plan, the compliance 

report must include the 

information in §63.10(d)(5)(i). 

semiannually 

according to the 

requirements in 

§63.5910(b). 
183 

P.86 

2. an immediate 

startup, 

shutdown, and 

malfunction 

report if you 

had a startup, 

shutdown, or 

malfunction 

during the 

reporting 

period that is 

not consistent 

with your 

startup, 

shutdown, and 

malfunction 

plan 

actions taken for the event 

the information in 

§63.10(d)(5)(ii) 

by fax or telephone 

within 2 working 

days after starting 

actions 

inconsistent with 

the plan. 

by letter within 7 

working days after 

the end of the 

event unless you 

have made 

alternative 

arrangements with 

the permitting 

authority. 

(§63.10(d)(5)(ii)) 

Table 15 to Subpart WWWW 

A) to Subpart WWWW 

Applicability of General Provisions (Subpart 

The general 

provisions 

reference... 

That addresses... And Subject to the following 

applies to additional 

subpart infonnation... 

WWWW... 

§63.1(a)(1) General 

applicability of 

the general 

provisions 

Yes Additional terms defined 

in subpart WWWW; when 

overlap between subparts 

A and WWWW of this part, 

subpart WWWW takes 

precedence. 

§63.1(a)(2) 

through (4) 

General 

applicability of 

the general 

provisions 

Yes 

§63.1(a)(5) 

„.„„...„.„.„..__. 

through (7) 

Reserved 

General 

applicability of 

the general 

provisions 

No 

Yes 

§63.1(a)(8) General Yes 

applicability of 

the general 

provisions 

§63.1(a)(9) Reserved No 
184 

P.87 

§63.1(a)(10) 

through (14) 

§63.1(c)(1) 

General 

applicability of 

the general 

provisions 

Yes 

§63 

§63 

§63 

K b) (1) 

K b) (2) 

K b) (3) 

Initial 

applicability 

determination ' 

Title V operating 

permit requirement 

Record of the 

applicability 

determination 

Yes 

Yes 

Yes 

Subpart WWWW clarifies 

the applicability in 

§§63.5780 and 63.5785. 

All major affected 

sources are required to 

obtain a title V permit. 

Applicability of 

this part after a 

relevant standard 

has been set under 

this part 

Yes Subpart WWWW clarifies 

the applicability of 

each paragraph of 

subpart A to sources 

subject to subpart WWWW. 

§63.1(c)(2) Title V operating Yes 

permit requirement 

All major affected 

sources are required to 

obtain a title V 

operating permit. Area 

sources are not subject 

to subpart WWWW. 

§63.1(c)(3) 

„.„„.....„„.„...„.„... 

Reserved No 

Requirements for 

an existing source 

that obtains an 

extension of 

compliance 

Yes 

§63.1(c)(5) Notification 

requirements for 

an area source 

that increases HAP 

emissions to major 

source levels 

Yes 

§63.1(d) 

§63.1(e) 

Reserved No 

Applicability of Yes 

permit program 

before a relevant 

standard has been 

set under this 

part 

§63.2 Definitions Yes Subpart WWWW defines 

terms in §63.5935. When 

overlap between subparts 

A and WWWW occurs, you 

must comply with the 

subpart WWWW 

definitions, which take 

precedence over the 

subpart A definitions. 

§63.3 Units and 

abbreviations 

Yes Other units and 

abbreviations used in 

subpart WWWW are defined 

in subpart WWWW. 
185 

P.88 

§63.4 Prohibited 

activities and 

circumvention 

Yes §63.4(a)(4) is reserved 

and does not apply. 

§63.5(a)(1) 

through (2) 

Applicability of 

construction and 

reconstruction 

Yes Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(b)(1) Relevant standards 

for new sources 

upon construction 

Yes Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(b)(2) 

§63.5(b)(3) 

Reserved No 

New construction/ Yes 

reconstruction 

Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(b)(4) Construction/ 

reconstruction 

notification 

Yes Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(b)(5) Construction/ 

reconstruction 

compliance 

Yes Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(b)(6) Equipment addition Yes 

or process change 

Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(c) 

§63.5(d)(1) 

Reserved No 

Yes 

§63.5(f)(1) 

through (2) 

General 

application for 

approval of 

construction or 

reconstruction 

Approval of 

construction or 

reconstruction 

based on prior 

State 

preconstruction 

review 

Yes 

Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.5(d)(2) 

§63.5(d)(3) 

§63.5(d)(4) 

§63.5(e)(1) 

through (5) 

Application for 

approval of 

construction 

Application for 

approval of 

reconstruction 

Additional 

information 

Approval of 

construction or 

reconstruction 

Yes 

No 

Yes 

Yes 

§63.6(a)(1) Applicability of 

compliance with 

standards and 

maintenance 

requirements 

Yes 
186 

P.89 

§63.6(a)(2) Applicability of 

area sources that 

increase emissions 

to become major 

sources 

Yes 

§63.6(b)(1) 

through (2) 

Compliance dates 

for new and 

reconstructed 

sources 

Yes Subpart WWWW clarifies 

compliance dates in 

§63.5800. 

§63.6(b)(3) Compliance dates Yes 

through (5) for area sources 

that become major 

sources 

Reserved No 

Subpart WWWW clarifies 

compliance dates in 

§63.5800. 

§63.6(b)(6) 

§63".'6(b)"(T)" Compliance dates 

for new sources 

resulting from new 

unaffected area 

sources becoming 

subject to 

standards 

Yes Subpart WWWW clarifies 

compliance dates in 

§63.5800. 

§63.6(c)(1) Compliance dates Yes 

through (2) for existing 

sources 

Reserved No 

Subpart WWWW clarifies 

compliance dates in 

§63.5800. 

§63.6(c)(3) 

through (4) 

„..„„...„„..„....„„... 

Compliance dates Yes 

for existing area 

sources that 

become major 

Reserved No 

Subpart WWWW clarifies 

compliance dates in 

§63.5800. 

§63.6(d) 

§63""6"(e)"("rr 

through (2) 

Operation & 

maintenance 

requirements 

Yes 

§63.6(e)(3) Startup, shutdown, Yes 

and malfunction 

plan and 

recordkeeping 

Subpart WWWW requires a 

startup, shutdown, and 

malfunction plan only 

for sources using add-on 

controls 

§63.6(f)(1) Compliance except No 

during periods of 

startup, shutdown, 

and malfunction 

Subpart WWWW requires 

compliance during 

periods of startup, 

shutdown, and 

malfunction, except 

startup, shutdown, and 

malfunctions for sources 

using add-on controls 

§63.6(f) (23) Methods for 

determining 

compliance 

Yes 

§63.6(g)(1) 

through (3) 

Alternative 

standard 

Yes 
P.90 

187 

§63.6(h) 

§63.6(i)(1) 

through (14) 

§63.6(i) (15) 

§63.6(i)(16) 

§63.6(j) 

§63.7(a)(1) 

§63.7(a)(2) 

§63.7(a)(3) 

§63.7(b)(1) 

§63.7(b)(2) 

Opacity and 

visible emission 

Standards 

Compliance 

extensions 

Reserved 

Compliance 

extensions 

Presidential 

compliance 

exemption 

Applicability of 

performance 

testing 

requirements 

Performance test 

dates 

Section 114 

authority 

Notification of 

performance test 

Notification of 

rescheduled 

performance test 

No 

Yes 

No 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Subpart WWWW does not 

contain opacity or 

visible emission 

standards. 

Subpart WWWW initial 

compliance requirements 

are in §63.5840. 

§63.7(c) Quality assurance Yes 

program, including 

test plan 

Except that the test 

plan must be submitted 

with the notification of 

the performance test. 

§63.7(d) Performance Yes 

testing facilities 

§63.7(e)(1) 

through (4) 

Conditions for 

conducting . 

performance tests 

Yes Performance test 

requirements are 

contained in §63.5850. 

Additional requirements 

for conducting 

performance tests for 

continuous 

lamination/casting are 

included in §63.5865. 

§63.7(f) 

_..„.„„... . 

Use of alternative 

test method 

Yes 

Performance test 

data analysis, 

recordkeeping, and 

reporting 

Yes 

§63.7(h) Waiver of Yes 

performance tests 

§63.8(a)(1) Applicability of Yes 

through (2) monitoring 

requirements 
188 

P.91 

§63.8(a)(3) 

§63"'8(aj"("4")" 

Reserved No 

Monitoring 

requirements when 

using flares 

Yes 

§63.8(b)(1) Conduct of 

monitoring 

exceptions 

Yes 

§63.8(b)(2) Multiple effluents Yes 

through (3) and multiple 

monitoring systems 

§63.8(c) (1) (i) Ensure immediate 

repair or 

replacement of CMS 

parts to correct 

"routine" or 

otherwise 

predictable 

malfunctions 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(c)(1)(ii) Report CMS 

malfunctions that 

are not addressed 

by the startup, 

shutdown, and 

malfunction plan 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(c)(1) 

(iii) 

Compliance with 

CMS operation and 

maintenance 

requirements 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(c)(2) 

through (3) 

Monitoring system 

installation 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(c)(4) CMS requirements Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(c)(5) COMS minimum 

procedures 

No Subpart WWWW does not 

contain opacity 

standards 

§63.8(c)(6) 

through (8) 

CMS calibration 

and periods CMS is 

out of control 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(d) CMS quality 

control program, 

including current 

test plan and all 

previous versions 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 
189 

P.92 

§63.8(e)(1) Performance Yes 

evaluation of CMS 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(e)(2) Notification of 

performance 

evaluation 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(e)(3) 

through (4) 

§63.8(e)(5)(i) 

CMS requirements/ Yes 

alternatives 

Reporting Yes 

performance 

evaluation results 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(e)(5) 

(ii) 

Results of COMS 

performance 

evaluation 

No Subpart WWWW does not 

contain opacity 

standards. 

§63.8(f)(1) 

through (3) 

Use of an 

alternative 

monitoring 

method 

Yes 

§63.8(f)(4) Request to use an 

alternative 

monitoring method 

Yes 

§63.8(f)(5) Approval of 

request to use an 

alternative 

monitoring method 

Yes 

§63.8(f)(6) Request for 

alternative to 

relative accuracy 

test and 

associated records 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.8(g)(1) 

through (5) 

Data reduction Yes 

§63.9(a)(1) 

through (4) 

Notification 

requirements and 

general 

information 

Yes 

§63.9(b)(1) Initial 

notification 

applicability 

Yes 

§63.9(b) (2). Notification for 

affected source 

with initial 

startup before 

effective date of 

standard 

Yes 
P.93 

190 

§63.9(b)(3) Notification that 

subject to the 

rule for new or 

reconstructed 

affected source 

with initial 

startup after 

effective date and 

for which an 

application for 

approval of 

construction or 

reconstruction is 

not required 

Yes 

§63.9(b)(4) 

(i) through 

(iii) 

Notification for a Yes 

new or 

reconstructed 

major affected 

source with 

initial startup 

after effective 

date for which an 

application for 

approval of 

construction or 

reconstruction is 

required 

§63.9(b)(4)(iv) Reserved No 

§63.9(b)(4)(v) Notification for a Yes 

new or 

reconstructed 

major affected 

source with 

initial startup 

after effective 

date for which an 

application for 

approval of 

construction or 

reconstruction is 

required 

Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.9(b)(5) After effective 

date of standard, 

notification of 

intended 

construction or 

reconstruction 

Yes Existing facilities do 

not become reconstructed 

under subpart WWWW. 

§63.9(c) Request for 

compliance 

extension 

Yes 

§63.9(d) Notification of Yes 

special compliance 

requirements for 

new source 

§63.9(e) Notification of 

performance test 

Yes 
191 

P.94 

§63.9(f) Notification of 

opacity and 

visible emissions 

observations 

No Subpart WWWW does not 

contain opacity or 

visible emission 

standards. 

§63.9(g)(1) Additional 

notification 

requirements for 

sources using CMS 

Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.9(g)(2) Notification of 

compliance with 

opacity emission 

standard 

No Subpart WWWW does not 

contain opacity emission 

standards. 

§63.9(g)(3) Notification that 

criterion to 

continue use of 

alternative to 

relative accuracy 

testing has been 

exceeded 

Yes 

§63.10(b)(2) 

(vi) through 

(xi) 

CMS records Yes 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.9(h)(1) 

through (3) 

§63.9(h)(4) 

§63.9(h)(5) 

through (6) 

§63.9(i) 

§63.9(j) 

§63.10(a) 

(1) through 

§63.10(b)(1) 

§63.10(b)(2) 

(i) through 

(7) 

(v) 

Notification of 

compliance status 

Reserved 

Notification of 

compliance 

status 

Adjustment of 

submittal 

deadlines 

Change in 

information 

provided 

Applicability of 

recordkeeping and 

reporting 

Records retention 

Records related to 

startup, shutdown, 

and malfunction 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes Only applies to 

facilities that use an 

add-on control device. 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.10(b)(2) 

(xii) 

Record of waiver 

of recordkeeping 

and reporting 

Yes 

§63.10(b)(2) 

(xiii) 

Record for 

alternative to the 

relative accuracy 

test 

Yes 
192 

P.95 

§63.10(b) 

(2)(xiv) 

Records supporting Yes 

initial 

notification and 

notification of 

compliance status 

§63.10(b)(3) Records for 

applicability 

determinations 

Yes 

§63.10(c)(1) CMS records Yes This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.10(c) 

(2) through (4) 

Reserved No 

§63.10(c) CMS records Yes 

(5) through (8) 

This section applies if 

you elect to use a CMS 

to demonstrate 

continuous compliance 

with an emission limit. 

§63.10(c)(9) 

§63"l0(d)"(ij' 

Reserved No 

General reporting Yes 

requirements 

§63.10(d)(2) Report of 

performance test 

results 

Yes 

§63.10(d)(3) Reporting results No 

of opacity or 

visible emission 

observations 

Subpart WWWW does not 

contain opacity or 

visible emission 

standards. 

§63.10(d)(4) Progress reports 

as part of 

extension of 

compliance 

Yes 

§63.10(d)(5) Startup, shutdown, Yes 

and malfunction 

reports 

Only applies if you use 

an add-on control 

device. 

§63.10(e) Additional 

(1) through (3) reporting 

requirements for 

CMS. 

Yes This section applies if 

you have an add-on 

control device and elect 

to use a CEM to 

demonstrate continuous 

compliance with, an 

emission limit. 

§63 

§63 

§63 

10(e)(4) 

10(f) 

11 

Reporting COMS 

data 

Waiver for 

recordkeeping or 

reporting 

Control device 

requirements 

No 

Yes 

Yes 

Subpart WWWW does not 

contain opacity 

standards. 

Only applies if you 

elect to use a flare as 

a control device. 
P.96 

193 

§63.12 State authority Yes 

and delegations 

§63.13 Addresses of State Yes 

air pollution 

control agencies 

and EPA Regional 

Offices 

§63.14 Incorporations by Yes 

reference 

§63.15 Availability of Yes 

information and 

confidentiality