p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

172) ll-E-132 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:09 AM Sheet 172 of 264 
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MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Robert Jemison 

Pacific Environmental Services, Inc. (PES) 

DATE: March 6, 1998 

SUBJECT: Minutes of January 5, 1998 Meeting Between EPA and Representatives of the 

Reinforced Plastic/Composites Industry 

LOCATION: EPA/Mutual Building, Durham, NC, 10th floor 

12:00 pm - 4:00 pm 

ATTENDEES: 

Mr. Perry Bennett 

Ms. Alice Boomhower 

Ms. Linda Chappell 

Mr. Chuck Elkins 

Mr. Robert Haberlein 

Ms. Linda Herring 

Mr. Robert Jemison 

Mr. Bob Lacovara 

Mr. Steve McNally 

Ms. Jan Meyer 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

MFG Justin Tanks, Inc. (440) 

Amoco, Inc. (312) 

EPA/AQSSD/ISEG (919) 

Jelinek, Schwartz & Connolly, Inc. (703) 

Engineering Environmental (410) 

EPA/ESD/CCPG (919) 

PES (919) 

Composite Fabricators (703) 

Association (CFA) 

CFA (703) 

EPA/ESD/CCPG (919) 

PES (919) 

Composites Institute (CI) of the (313) 

994-5207 

856-2326 

541-2864 

312-8540 

268-7367 

541-5358 

941-0333 

525-0511 

525-0511 

541-5254 

941-0333 

668-4703 

Society of the Plastics Industry (SPI) 

EPA/ESD/CCPG (919) 541-2383 
Madeleine Strum 

March 6, 1998 

Page 2 

PURPOSE 

The purpose of the meeting was for representatives of the reinforced plastic composites 

industry and EPA representatives to discuss various issues concerning the MACT Standard for 

the reinforced plastic composites industry. Mr. Schweitzer and Mr. McNally provided tw6 

documents describing their concerns and recommendations regarding these issues prior to the 

meeting. The document provided by Mr. Schweitzer is entitled "Feasibility of MACT for Open 

Molding - Discussion of Industry Position" and is enclosed with this document as Attachment 1. 

The document provided by Mr. McNally is entitled "An Approach to the Maximum Available 

(sic) Control Technology for the Polymer Casting Sub-Category of the Reinforced Plastic 

Composites NESHAP" and is enclosed with this document as Attachment 2. The agenda for the 

meeting was provided by Mr. Schweitzer and is enclosed with this document as Attachment 3. 

DISCUSSION 

The first issue discussed was the MACT model for the open molding process grouping. 

Mr. Schweitzer inquired if the EPA had reached a decision on which emission model it was going 

to use for the open molding process grouping. Ms. Strum indicated that the emission model 

presented at the December 8, 1997 meeting between EPA and industry representatives would be 

used. Mr. Schweitzer inquired if the emission model would be used in conjunction with the 

MACT database to detennine the MACT floors for the open molding process grouping. Ms. 

Strum indicated that the MACT floors would be determined in this manner. Mr. Schweitzer 

further inquired if there were any other uses of the emission model. Ms. Strum indicated that the 

model is a point value system designed to assign point values to emission reduction techniques 

which facilities would use to determine compliance with the MACT standard for the open molding 

process grouping. 

Mr. Lacovara inquired if the point values would be expressed in units of lbs HAP 

emitted/ton of resin consumed or an alternative system of units. Ms. Strum indicated that the 

units would probably be lbs HAP emitted/ton of resin consumed. Ms. Strum added that it should 

be remembered that, in spite of this system of umts, the model is a point value system designed 

to determine compliance and should not be used to estimate facility-specific emissions. Mr. 

Lacovara inquired if AP-42 emission factors would be used to estimate emissions. Ms. Strum 

indicated that emission factors from AP-42 would not be used to estimate emissions from open 

molding, but may be used for other processes. Ms. Strum added that some source specific 

emissions data or emissions information from EPA Region IV may be used to estimate emissions. 

Ms. Strum indicated that it is also possible that the EPA would use the MACT model for 

nationwide emission estimates, but would state that it should not be used for estimating facilityP.3 

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Madeleine Strum 

March 6, 1998 

Page 3 

specific emissions. Mr. Lacovara replied that the industry would be uncomfortable with using 

EPA Region IV information because it did not think such information would be representative of 

the industry. 

Ms. Boomhower inquired as to the scope and applicability of the model being discussed. 

Ms. Strum indicated that the model was applicable to the open molding subcategory which 

consists ofthe following processes: bucket & tool application, mechamcal resin application (spray 

lay-up, flow coaters, and pressure-fed rollers), filament winding and gel coat application. Ms. 

Boomhower inquired as to how the MACT floors would be determined. Ms. Strum replied that 

the MACT floors would be determined by using experimental data and theory to create the MACT 

model and then applying the MACT model to the information contained in the MACT database 

to rank the facilities. 

Mr. Haberlein inquired which curve in the MACT model would be used when the facility 

used flow coaters. Ms. Strum replied that the non-spray curve generated using CFA Phase I data 

for bucket & tool application would be the appropriate curve. Mr. Haberlein replied that this 

represented a change from the previous model presented by the CFA which used the atomized 

spray curve to determine the initial level of emissions for a given HAP content and then applied 

a control factor to account for the emission reduction obtained from using a flow coater or 

pressure-fed roller to apply the resin instead of an atomized spray gun. Ms. Strum replied that 

this did represent such a change. 

Mr. Lacovara inquired whether the MACT floor for the bucket & tool application was 

lower (more stringent) than for mechanical spray application. Ms. Strum indicated that the 

MACT floor for the bucket & tool application is probably lower than for mechanical spray 

application. Ms. Strum further indicated this may be due to the wide use of vapor suppressants 

and lower HAP resins by those facilities that comprise the bucket & tool application MACT floor. 

Ms. Strum added that some ofthe facilities that comprise the mechanical spray application MACT 

floor still use atomized mechanical spray application which results in higher emissions. Mr. 

Lacovara indicated that the CFA's original proposal would encourage facilities to switch from 

atomized mechanical spray application to non-atomized mechanical spray application using flow 

coaters or pressure-fed rollers. Ms. Strum replied that the previous EPA approach would also 

have encouraged such a change. (Note that the current EPA approach is the same as the industry 

approach.) Ms. Strum also noted that with the industry approach there was no incentive to move 

from atomized mechanical spray application to lower emitting bucket & tool application. Mr. 

Schweitzer indicated that such a move would be a "backward step" for a facility due to a decrease 

in the facility's maximum production rate and would therefore not occur. Ms. Strum agreed and 

noted that this would be a rationale for considering bucket & tool application as a separate process 

grouping from mechamcal non spray application. 

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Madeleine Strum 

March 6, 1998 

Page 4 

The next issue discussed involved possible alternatives that facilities could use to 

demonstrate compliance with the MACT standard. Mr. Schweitzer inquired if a "well-run" 

facility, i.e.- one that managed air flows and used good housekeeping practices, could use emission 

testing data to comply with the standard. Ms. Strum indicated that emission test data could 

possibly be used on a case by case basis but only if the facility was using a new technology to 

reduce emissions and not for techniques already covered by the MACT model. Ms. Strum stated 

her concern that if emission testing was allowed to demonstrate compliance with the MACT 

standard, then facilities may, for example, conduct testing with shorter gel times or greater 

laminate thickness than those used to set the MACT standard. Ms. Strum added that EPA will 

have to work on developing a case-by-case procedure that will ensure that the new technology 

used by a facility does not achieve its emission reductions by modifying parameters such as 

shorter gel times or increasing laminate thickness. Mr. Schweitzer indicated his concern about 

the MACT standard limiting long-term opportunities for the use of new emission reduction 

technologies. Ms. Boomhower inquired as to which parameters could not be altered when a 

facility wants to use emission testing to show that use of a new technology results in compliance 

with the MACT standard. Ms. Strum replied that those parameters included gel time, laminate 

thickness, air flow, application rate, and operator technique. 

Mr. Lacovara stated that the curves (equations) that comprise the MACT Model represent 

average emission values since they are based on average parameters for gel time and laminate 

thickness. Mr. Lacovara then inquired if it was reasonable for a facility to use stack testing to 

demonstrate compliance if every parameter (gel time, laminate thickness, etc) were optimized to 

reduce emissions below the average value shown by the curves. Ms. Strum stated her concern 

that even if a facility optimized its parameters to reduce emissions during the test procedure, it 

would be difficult for enforcement personnel to determine whether these parameters were kept at 

an optimal level on a continuous basis. Ms. Strum added that since such parameters were not 

used to determine the MACT floor, they should not be used for compliance. Mr. Lacovara 

indicated that the MACT standard should contain a provision for emissions testing that will allow 

a facility to demonstrate that the facilities emissions were well below those predicted by the 

model. Ms. Meyer indicated that such a provision would have to specify that a facilities emissions 

were significantly below the model. Ms. Meyer continued by stating that significantly may be 

defined as emissions that are 1/10 or

 xh those predicted by the model so there is reasonable 

confidence that actual performance is better than the model. Mr. Lacovara indicated that 

requiring such a large difference between the model and the facilities emissions may be making 

the case by case demonstration too restrictive. Ms. Herring stated that section 112(h) of the Clean 

Air Act would require that EPA conduct an equivalency determination on a case by case basis for 

each new technology and then amend the rule in the Federal Register unless the MACT standard 

specified a case by case approval procedure. Ms. Herring continued by stating that it would be 

desirable if EPA could develop such a procedure to avoid having to amend the rule for each new 

technology while at the same time ensuring that any procedure developed would only approve new 

technologies that produced real emission reductions and meet EPA criteria regarding rule 

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Madeleine Strum 

March 6, 1998 

Page 5 

enforceability. Ms. Boomhower indicated her concern that if the case-by-case procedure for a 

new technology were made plant specific, it would be difficult for a company to develop and 

market a new emissions reduction technology. Ms. Herring replied that the case-by-case 

equivalency determination would not necessarily be plant specific. 

Mr. Bennett inquired if a facility would be considered an existing source or a new source 

if the facility that conducts an open molding process prior to the rule promulgation changes to a 

closed molding process after the rule is promulgated. Mr. Bennett continued by stating that if 

such a facility would be considered a new source it may be discouraged from changing due to the 

being subject to a significantly tighter standard, even though it had reduced its emissions by up 

to 90%. Mr. McNally indicated his belief that many State permits would treat the facility as an 

existing source. Ms. Strum indicated that the EPA did not want to discourage facilities from 

changing to closed molding. Ms. Strum continued by stating that facilities could benefit from 

changing to closed molding in that those facilities could use resin systems with a significantly 

higher HAP content than would be possible with open molding. Ms. Meyer indicated that this 

may be an issue that can be accommodated in drafting the rule. Ms. Herring indicated that if the 

EPA allowed facilities to change from open molding to closed molding without being considered 

a new source in the final rule, there would have to be a provision requiring facilities to notify the 

EPA when such a change occurred. Mr. Bennett stated that there is a trend within the reinforced 

plastic composites industry to change to closed molding to reduce worker exposure to high 

ambient levels of HAP. Mr. Bennett added that it would be undesirable for the rule to discourage 

the continuation of that trend. 

The next issues discussed pertained to the use of vapor suppressed resin systems. Mr. 

Haberlein asked if the values obtained from the vapor suppression effectiveness test would be used 

with both the atomized and non-atomized mechamcal spray applications. Ms. Strum indicated that 

the test would be used for both atomized and non-atomized mechamcal spray applications, but the 

values obtained from the test would be used in different equations in the model (based on the 

process the vapor suppressed resin system is used in). Mr. Haberlein asked if vapor suppressants 

would be taken into account when determining the MACT floors. Ms. Strum replied in the 

affirmative and stated that there were a number of possibilities as to how vapor suppressants could 

be taken into account when determining the MACT floor. Ms. Strum continued by stating the 

possible options were to test the vapor suppressed resin systems of the companies that comprise 

the MACT floor or to use a mutually agreed upon suppressant effectiveness value when 

determining the MACT floor. Mr. Lacovara indicated that it would take a number of months to 

obtain the resins from the various facilities. Ms. Strum indicated that such a delay would be 

deleterious to EPA's schedule for promulgating the standard. Ms. Meyer stated that another 

option may be to assume a vapor suppressant effectiveness value for the present and then conduct 

the testing at a later date. Ms. Proctor stated that another option would be to use the CFA Phase 

U data that was germane to the effectiveness of vapor suppressants. Mr. Lacovara indicated that 

the HAP content ofthe vapor suppressed resin systems tested during the CFA Phase II testing was 

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Madeleine Strum 

March 6, 1998 

Page 6 

between 33 % and 48%. Mr. Lacovara stated his belief that this range of HAP content was typical 

of the industry and as such it would be reasonable to take the average suppressant effectiveness 

value from this range and use this value to help determine the MACT floor. Mr. McNally 

inquired if the EPA assumed that facilities that reported using vapor suppressants were using them 

for all of their resin systems. Ms. Proctor indicated that facilities were given credit for using 

vapor suppressants depending on what percentage of the resin systems used by the facility actually 

contained vapor suppressants. 

Ms. Strum inquired about the preliminary test runs of the vapor suppressed resin test and 

any results obtained in these preliminary test runs. Mr. Lacovara indicated that the industry 

conducted two preliminary test runs but he did not yet receive the test results. Mr. Lacovara 

added that he would provide EPA with the results of those test runs as soon as he received them. 

The next issue discussed pertained to the data verification efforts currently being carried 

out by the EPA. Ms. Boomhower inquired as to the current state of the data verification efforts 

being conducted by EPA. Ms. Strum indicated that the EPA is in the process of updating the 

MACT database with information concerning HAP content and flow-coater/pressure-fed roller 

usage for those facilities in the MACT floor. Ms. Strum added that information for facilities may 

also be updated if EPA obtains information from a permit or an indication that a facility may be 

using a control device. 

The next issues discussed pertained to the distinction between corrosion resistant and noncorrosion resistant products and resin systems. Mr. Schweitzer inquired as to when the MACT 

floor for corrosion resistant applications would be finalized. Ms. Strum indicated that EPA's 

current schedule dictated that the MACT floor for corrosion resistant applications be finalized by 

July 8, 1998. Mr. Haberlein asked how the EPA decided to separate facilities into the corrosion 

resistant and non-corrosion resistant subcategories. Ms. Strum indicated that the EPA used 

industry's definition based on resin type and also considered whether facilities classified 

themselves as corrosion resistant or not. Ms. Proctor stated that EPA may also have to look at 

the end product in addition to the resin type because a facility may chose a resin system defined 

by industry as corrosion resistant for other desirable materials properties (i.e. strength properties). 

Mr. McNally stated that it may be difficult to attempt to compile a list of end products and then 

classify them as corrosion resistant or non-corrosion resistant. Mr. McNally continued by stating 

that corrosion resistant resin systems are usually more expensive and as such a facility would be 

unlikely to use a corrosion resin system unless absolutely necessary. Ms. Proctor noted that a 

vague corrosion-resistant definition that only relies on resin type and some very general product 

requirements may not be desirable because the corrosion resistant definition would be used to 

determine the pool of facilities that determines the MACT floor. Ms. Proctor added that if the 

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Madeleine Strum 

March 6, 1998 

Page 7 

facilities meet the corrosion resistant definition (due to vagueness) that do not really belong in the 

corrosion resistant MACT database they could end up setting the MACT floor for corrosion 

resistant applications. 

Mr. Bennett inquired how EPA would classify a facility that used both corrosion resistant 

and non-corrosion resistant resin systems. Ms. Proctor replied that the facility would be included 

in both the corrosion resistant and non-corrosion resistant MACT database and the corrosion 

resistant and non-corrosion resistant systems used by the facility would be subject to different 

standards. Mr. Bennett inquired if all vinyl ester resin systems were considered to be corrosion 

resistant. Ms. Proctor replied that in general that was the case but in certain instances the 

combination of resin type and product fabricated were the deciding criteria. Ms. Boomhower 

inquired as to whether the EPA considered blended resin systems to be corrosion resistant or noncorrosion resistant. Ms. Strum indicated that the EPA had considered blended resins systems to 

be non-corrosion resistant unless the facility classified itself as corrosion resistant. 

Ms. Boomhower indicated her understanding that the industry definition was a two part 

definition that considered both the type of resin system and other factors. Mr. Schweitzer 

indicated that the definition did contain requirements that products meet certain ASTM standards. 

Ms. Strum requested that industry representatives attempt to revise the second part of the industry 

definition for corrosion resistance. Ms. Strum indicated that one possible clarifying step would 

be to divide the corrosion resistant subcategory into two separate subcategories such as corrosion 

resistant subcategory A and corrosion resistant subcategory B where subcategory A represents a 

higher level of corrosion resistance than subcategory B. Mr. Haberlein indicated that an 

examination of industry corrosion resistant guides may aid in the development of a clear 

definition. Mr. McNally indicated that attempting to define corrosion resistance based on the 

types of environments and products a resin system can withstand may be ineffective. Mr. 

McNally continued by citing an example where a resin system was able to withstand a number of 

aggressive chemical products but failed when tested with distilled water. Ms. Meyer indicated 

her concern that the definition should be clear enough to be easily used by the applicable 

regulatory agencies permitting and enforcement personnel. Mr. Lacovara indicated his concern 

that the new definition should not adversely impact (change) the MACT floor by including a 

number of peripheral products largely unrelated to the majority of products currently in the 

corrosion resistant subcategory. Mr. Lacovara continued by stating that a number of products 

may be constructed of resin systems that are both corrosion resistant and non-corrosion resistant, 

such as when the product has an outer layer that is designed to be corrosion resistant. Mr. 

Lacovara further indicated that this may make compiling a list of corrosion resistant and noncorrosion resistant products difficult and inappropriate. 

The next issues discussed pertained to the use of gel coats. Mr. Lacovara inquired as to 

the size of the gel coat database. Ms. Proctor indicated that the gel coat database contained more 

than 200 facilities. Ms. Strum indicated that there were actually two databases with the first 

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Madeleine Strum 

March 6, 1998 

Page 8 

database containing data from the original 1993 screening surveys (sent to all known facilities in 

the industry) and the second database containing data from the 1997 information collection request 

(sent to nine companies who responded to the original 1993 screening survey). Ms. Strum 

continued by stating that the second survey was sent to the nine companies so that the EPA could 

determine a pound HAP per gallon of resin limit. Ms. Strum further stated that, in retrospect, 

EPA decided not to specify a pound HAP per gallon of resin limit because it could not be 

incorporated into the averaging approach proposed by industry. 

Mr. McNally inquired if the EPA was planning to differentiate between clear and 

pigmented gel coats. Ms. Strum indicated that there may be different MACT floors for clear and 

pigmented gel coats. Ms. Strum inquired if there was any difference between clear gel coats or 

if all clear gel coats were essentially the same. Mr. McNally replied that not all clear gel coats 

are the same due to the fact that some clear gel coats are used for sanitary applications and these 

types of clear gel coats differ from those used in the boating industry. Mr. Lacovara stated that, 

in general, clear gel coats are made from iso-neopentyl glycol types of resins because of 

difficulties with making the gel coats clear using other resin systems. Ms. Strum stated that it 

may be difficult to set different floors for clear and pigmented gel coats since facilities often did 

not distinguish between their usage of clear and pigmented gel coats when responding to the 1993 

screening survey. Mr. Jemison stated that only one facility indicated using a clear gel coat in the 

responses to the 1997 information collect request. Mr. Lacovara indicated that there were 

essentially only four major gel coat manufacturers and it should be relatively easy to obtain up-todate information on typical gel coat usage and HAP content. 

i 

Ms. Strum indicated that the EPA obtained information from two facilities indicating nonspray application of gel coats. Mr. Lacovara stated that gel coat could be applied by non-spray 

application in certain cases. Mr. Jemison noted that both of the facilities were in the corrosion 

resistant database. Mr. McNally stated that the gel coat used in such instances may be a gel coat 

formulated "in-house" rather than a manufacturer supplied gel coat. Mr. Lacovara stated that the 

facilities may be applying a resin system as a cosmetic finish using bucket and tool application and 

describing such a resin system as a "gel coat." Ms. Strum stated that the facilities indicated that 

they were applying the gel coats using a flow coater. Mr. Lacovara stated his belief that it was 

impossible to apply a gel coat using a flow coater due to the uneven streams of gel coat that would 

result from using such a device. Mr. Jemison indicated that he questioned the individuals 

carefully when they indicated use of a flow coater to apply a gel coat and these individuals were 

persistent in their statements concerning the use of flow coaters to apply gel coats. Mr. Jemison 

also stated that there may be differences in the terms that individuals use when referring to gel 

coats and flow coaters and it may be helpful for industry representatives to speak to the two 

facilities to verify the information the EPA has obtained. Mr. Lacovara indicated that industry 

would be willing to speak with the two facilities to ascertain uie accuracy of the information. Ms. 

Strum indicated that EPA could provide the telephone contact reports containing the relevant 

information. 

<6 
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Madeleine Strum 

March 6, 1998 

Page 9 

Mr. Lacovara asked if the EPA would use the same non-spray curve for flow coaters 

applying gel coats as would be used for flow coaters applying resin systems. Ms. Strum indicated 

that it may be necessary to use a different curve since gel coats normally produce greater 

emissions than resin systems. Ms. Proctor raised the issue of where to place facilities that apply 

gel coat by means other than spray gun (i.e. poured gel coat in continuous lamination). Mr. 

Schweitzer indicated that the gel coat in this case should be treated as if it were resin for 

continuous lamination. Ms. Proctor inquired as to why gel coat and resin should be treated as the 

same when they are used in the continuous lamination process when gel coat and resin are treated 

separately in the atomized mechamcal spray process. Mr. McNally stated that the emission 

potential of sprayed gel coat application is different from sprayed resin application due to, at least 

in part, the layers of gel coat being thinner than the typical laminate thickness of a resin system. 

Mr. Lacovara indicated that it was due to the greater atomization of the gel coat necessary to 

produce a more attractive finish. 

The next issues discussed pertained to industry's presentation of a possible approach to 

MACT for the polymer casting subcategory. Mr. McNally briefly reviewed industry's proposal 

(Attachment 2). Ms. Strum indicated that it may be inappropriate to have a cover exemption for 

vacuum mixing since it was her understanding that the emissions would simply be evacuated out 

of the mixer into the atmosphere. Ms. Boomhower indicated that industry representatives would 

investigate vacuum mixing further to determine if that was indeed the case. 

Ms. Strum indicated that she felt the proposed size cutoff of 55 gallons below which 

covered containers would not be required was too large. Ms. Strum continued by stating that the 

size cutoff for containers used in mixing, storage and transfer of resins that is selected should take 

into account the fact that EPA is planning to address mixing, storage, and transfer of resins as 

separate subcategories rather than proposing different requirements for each process. Mr. 

McNally indicated that the size cutoff selected should take into account industry diversity and that 

it would be inappropriate to impose standards on very small containers. Mr. McNally also stated 

that the language used in the rule should be very specific so as not to be interpreted more 

stringently by enforcement personnel than was intended by the rule. 

Mr. Lacovara indicated that he felt there should be an exemption from covered container 

requirements for cultured marble mixing. Mr. Lacovara continued by stating that the mixer had 

to be open for the operator to pour in pigments used in the manufacture of the cultured marble 

product and observe how those pigments are distributed throughout die resin system. Ms. Strum 

replied by stating that the pouring of the resin system into a container was different from mixing 

the resin system in a container. 

Ms. Proctor suggested that facilities could be contacted and asked what size containers they 

normally cover to detennine the MACT floor for mixing, storage, and transfer of HAP containing 

materials. Ms. Strum stated that another option was to set a certain size in the proposed rule and 

°\ 
P.11 

Madeleine Strum 

March 6, 1998 

Page 10 

men ask for public comment. Ms. Meyer stated that EPA had to be careful with the language to 

account for times when facilities legitimately need to access the mixer. 

Ms. Strum inquired if a size cutoff was necessary if a provision for access to the mixer was 

included in the final rule. Mr. McNally explained all mixers that are larger that 5 gallons could 

be covered as long as a provision for access to the mixer was included in the final rule. Mr. 

McNally further explained that all containers including those that are smaller than 5 gallons could 

be covered when they are not in use. Ms. Strum inquired if the access provision would only be 

applicable to mixers. Mr. McNally and Mr. Lacovara responded in the affirmative. Mr. 

Lacovara stated that the emissions from open containers are generally very low. He added that 

CFA collected emission data from an open five gallon container which showed very low 

emissions. Mr. Lacovara offered to provide this emissions data to the EPA. 

Ms. Boomhower inquired if it was useful or practical to create a rule that would require 

enforcement on every five gallon container that was left uncovered. Ms. Meyer indicated that one 

possible option was to require a management plan or standard operating procedure that required 

covers for those containers with less than five gallons capacity rather than having each noncovered bucket represent a violation. Ms. Meyer continued by stating that there were of number 

of different ways a covered container requirement could be structured and that all meeting 

participants should remember that there are several possible approaches to this issue. 

The next issue discussed was the current status of EPA's approach to MACT for new 

sources. Mr. Schweitzer inquired if EPA planned to conduct any additional analyses for new 

sources. Ms. Strum indicated that no new analyses were planned. Ms. Proctor indicated that the 

only change that could occur would be in the magnitude of the size cutoff as a result of analyzing 

the emissions data on continuous lamination that the EPA expected to receive from LASCO. Mr. 

Schweitzer indicated that the current size cutoff separating small new sources from large new 

sources would require a control device uiat was more expensive than the entire production facility 

for certain application techniques such as open molding. Mr. McNally stated that there was a 

fundamental dissimilarity between the open molding fabrication technique and the continuous 

lamination fabrication technique used by the facility upon which the size cutoff was based. Mr. 

Lacovara stated that continuous lamination was an automated process usually requiring a 

substantially larger capital investment for a new facility than a new facility with similar production 

capacity which used the open molding process. Mr. Lacovara added that this difference in capital 

cost results in a different level of feasibility for add-on controls. 

Ms. Meyer stated that in the past EPA considered the similarity of emission streams rather 

than the similarity of application techniques. Ms. Strum stated that EPA examined emission 

streams in the past rather than products or materials throughput because emission streams are 

easier to analyze. Mr. Lacovara stated that the emissions from an open molding facility, such as 

American Standard, were dissimilar to emissions from a continuous panel line and as such it may 

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Madeleine Strum 

March 6, 1998 

Page 11 

not be reasonable to use emissions from a continuous panel line to set the size cutoff separating 

small new sources from large new sources. 

Mr. Schweitzer indicated that industry has concerns about the feasibility of the MACT 

standard for open molding. Mr. Schweitzer continued by stating the industry's position that 

monomer content is not a control (particularly for the conosion resistant subcategory) and that 

facilities may have problems making products if the MACT floors are set too low. 

Action Items for Industry Representatives: 

1. Provide results from the preliminary runs of the vapor suppressant effectiveness test. 

2. Provide a clearer definition of the second part of the industry definition for conosion 

resistance. 

3. Investigate the vacuum mixing process to determine if emissions from vacuum mixing 

are directly evacuated into the atmosphere. 

4. Provide a rationale for the size cutoff below which mixing containers do not require a 

cover including an explanation of why there should be any size cutoff if access to mixers 

is allowed (i.e. to add ingredients or to empty the mixer). 

Action Items for EPA: 

1. Provide industry representatives with a list of products that meet the industry defimtion 

for conosion resistance but the EPA may not consider to be conosion resistant products. 

2. Provide industry representatives with the two telephone contact reports documenting 

conversations where reinforced plastic/composites facilities indicated use of a flow 

coater to apply a gel coat. 

w 
12/31/97 13:24 ©919 341 5689 EPA ESD CCPG 

P.13 

@001 

• - - ^ 

Please deliver this fax to: 

Madeleine Strum 

US EPA 

Total pages (incldg. cover): 1 

Problems with this fax? Call 313.668.4703 

Madeleine, please seethe attached proposed agenda for our meeting or 

Jan. 5, plus our discussion on feasibility ofthe standard. 

Steve McNally will fax, or bring on Monday, the referenced discussion oifi 

polymer casting and polymer concrete. 

Thanks, 

John Schweitzer 

^ 
P.M 

12/31/97 13:24 ©919 541 5689 EPA ESD CCPG (2)002 

Please deliver this fax to; 

Madeleine Strum 

USEPA 

Total pages (incldg. cover): 19 

Problems with this fax? Call 313.668.4703 

Madeleine, please see the attached proposed agenda for our meeting or 

Jan. 5, plus our discussion on feasibility ofthe standard. 

Steve McNally will fax, or bring on Monday, the referenced discussion orji 

polymer casting and polymer concrete. 

Thanks, 

John Schweitzer 

cc: Jan Meyer, Steve McNally 

b 
P.15 

: i '' 

12/31/97 13:25 091 9 541 5689 EPAESD CCPG 10003 

John Schweitzer Technical Director Composites Institute 

Regional Office 1441 White Street Ann Arbor MI 48104 

Phone 313.668.4703 Fax 313.668.4708 

E-mail jschwcft@socplas.org 

December 30, 1997 

To: Madeleine Strum, EPA 

He: Agenda and Materials for January 5 Meeting 

Madeleine, please review the following suggested agenda for our working session, 

12noon lo 4pm, Monday, January 5, 1998. We understand that you have not come to 

a decision regarding all aspects of ihe composite MACT. However, we would find it 

helpful to understand your current thinking on the topics outlined below. Tn some 

cases, as noted, we will present our own current ideas on the topics. Please let me 

know if you would like us to make any changes to this agenda. 

I. Emission Models 

On a number of occasions (as recenlly as December 8), we have provided information 

and analysis r.o ESD, for your use in establishing an emission model for MACT, and 

we appreciate that you have carefully reviewed this information. According to the 

December 1 draft, "Milestones for Reinforced Plastics," ESD will finalize the 

emission model for open molding processes in December. On January 5, we would 

like to learn what model ESD has chosen. 

We would also like to better understand how the model is to be used - to set floors? 

to estimate emissions? l-o demonsixHip. compliance? And will the model address the 

pollution prevention controls in our proposed control matrix? 

In addition, wc would like to discuss how facilities will demonstrate comphance with 

the standard. For example, will facilities use ESD's model, the CFA model, stack 

test data (if available), control factors for new technologies derived from testing, 

some combination, or ...? 

II. Subcategories 

ESD is considering how to subcategory the open molding industry. Wc originally 

suggested that groups be established for mechamcal and manual resin application 

(to encourage and reward facilities for switching to flow coaters from spray-up), 

while ESD grouped all non-spray together, including manual application. On 

January 5, we would like to review ESD's current thinking on subcategories. 
. P.16 

12/31/97 13:25 ©919 541 5689 EPA ESD CCPG @004 

III. Corrosion Floor 

We would like to discuss your current plans for how and when ESD will set the floor 

for corrosion fabrication. We should also discuss possible ways to define the 

corrosion subcategory. 

IV. Gel Coat 

We understand that ESD is collecting additional information on gel coats. We would 

like to discuss the process and schedule you have in mind for gel coat apphcation. 

V. Polymer Concrete and Cast Polymer 

We would like to present our evaluation of the issues in polymer concrete and cast 

polymer (summary attached), and would like to explore how consideration of these 

issues might be incorporated into the MACT for this category. 

VI. New Sources 

We have focused most of our efforts on existing sources, and have just recently 

begun consideration of your suggested approach for new sources. However, we are 

concerned that the 63 ton per year small/large cui-ofTmay not be appropriate for 

open molding. Our preliminary analysis indicates that this level may require newopen molding facilities to install controls that are as expensive or more expensive 

than the entire facility. We will continue our analysis and will provide information 

to ESD soon. What is your schedule for further consideration of new sources? 

ln addition, we would like to explore the use, by facilities, of our emission model in 

determining if they will be large or small new sources. Also, we would like to 

discuss how new sources might be able to employ the pollution prevention options in 

our matrix to avoid being classified as large new sources. 

VII. Test for Suppressants 

We have started development ofthe suppressant test, per our December 8 meeting. 

On January 5. we will have some preliminary data to share with you. 

2 

I* 
P.17 

From: John Schweitzer To: Madeleine Strum Oate: 12/31/97 Time: 10:03:04 AM Page 4 of 19 

VIII. Your Leave 

On January 5, we would Uke to discuss what work can be carried out during your 

leave. In particular, we would like to know how we can best continue our efforts 

during this period. Are there specific things we can do during your absence? How • 

can we best communicate with ESD during this period? 

DC Draft Schedule 

Wc would like to understand how we can assist you in the various activities shown 

on the December 1 draft schedule. For example, can we help by providing comments 

on the Draft Industry Description Memo? 

X. Feasibility ofthe Standard 

Based on our knowledge ofthe composites industry, and our understanding of ESD's 

current approach to MACT for composites, we beheve that the ultimate feasibility of 

the standard for open molding depends on where the floors are set, and on the 

standard providing sufficient flexibility for us to continue making quahty products 

using the materials and processes needed. A summary of our position on feasibility 

is attached, and we respectfully ask that you take our suggestions into consideration 

as you develop the standard. 

XI. Other Issues 

Does ESD have any additional items for discussion? 

Attachments 

1. Feasibility ofMACT for Open Molding - Discussion of Industry Position 

2. Issues Related to Polymer Concrete and Cast Polymer 

(6 
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• The standard, must allow us to test and use new control technologies to meet the MACT 

emission limitation. 

• Facihties must have the option of complying with the standard by aggregating all open 

molding operations and by averaging across a rolling 12 -month period.. 

We believe that these conclusions are consistent with development of 8 MACT standard that 

meets the requirements ofthe Clean Air Act, and that results in a veiy substantial reduction 

of emissions from tills industry. 

MACT Floors for Open Molding 

BPA's database of composite industry facilities, emissions, and controls serves as the basis 

for setting the MACT floors, or minimum control levels, for each of the subcategories. Understandably, EPA wants th© database to contain the most up-to-date and accurate information 

possible, and the Agency and its contractor have worked hard to collect information from the 

industry. We, too, want the database to accurately portray the wide range of materials, 

processes, product*, and facilities common in tha industry. However, EPA should be aware 

that the viability of our proposed approach depends on the levels at which the floors ore set 

and on the required MACT emission limitations. EPA can use our approach to meet the 

MACT emission limits wo proposed, but w* will have to reevaluate the feasibility of this 

approach if the floors are significantly reducedGiven the complexity ofthe open molding and corrosion subcategories, the floors will 

be largely an artifact of ihe process used in setting these levels, and not necessarily a useful 

indication ofthe level of control that could reasonably or feasibly be applied to even a 

majority of the facilities. For example, these subcategories are certainly large and diverse 

enough that, Riven sufficient time and effort, EFA could find unusual facilities with emissions low enough that die resulting floors would not be feasible. Also, in setting the floors, 

EPA could base emission estimates on manufacturing variables that are not always "controls" (i.e., intentionally selected to reduce emissions). For example, monomer content in 

resin is used, as a control by many sources. However, for other sources, monomer type and 

concentration play an essential role in polymer chemistry, and therefore product performanna, and monomer is not really available for use as a "control," In this case, too. the floors 

are likely not to be widely applicable. 

Congress intended that EPA use reasonable judgement when setting floors. EPA is 

not expected to conduct 9n exhaustive search for faciUties that might make unusual products 

or usa unusual technology, but rather to employ a process that results in floors that are in 

fact fflflfiibla and achievable for at least a large majority of sources within a subcategory. 

2 

tn 
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EPA may have suggested improvements regarding the derivation of the MEI J;, the emission model, the enforceability and practicality ofthe standard, or other similar issues, and 

we agree that these are useful areas for discussion and improvement. However, wc oppose 

consideration of limits on materialfi, processing, and other possible technology-based additions to the required emission limitations. As long as sources are meeting the MACT emission limits, and doing so in an enforceable manner, EPA is not compelled to, and must not, 

dictate how facUities make products. 

In particular, the standard should not set floors so low, or restiict the use of averaging, so that facilities arc unable to use the resins or processes they need to make acceptable 

products. Under our proposed performance-based approach, sources will naturally use the 

resins with the lowest-possible HAP content, and will use high-HAP resins only when 

required for processing or product performance, or when needed to make products that are 

competitive in the marketplace, Nevertheless, if the floors are set so low that the use of lowHAP resins is necessary to meet the emission limits, then the standard will severely Umit the 

flexibihty we need to make products, and in many cases, will drive us out of markets, or out 

of business altogether, We agree that the MACT emission limits should be set so that 

facilities have an incentive to use low-HAP resins, hut we do not. agree that they should be so 

low that sources do not have alternatives for the many cases where the use of high-HAP 

resins is required. For example, corrosion fabricators should be able to achieve MACT by 

using low-emitting application equipment, such as flow applicators, in combination with 

isophthalic resins containing 45% styrene. 

There are a number of compeUing reasons why the standard must not overly restrict 

the use of higher-HAP content resins: 

• Restrictions on monomer type and content are inappropriate r*strictions on the polymer 

chemistry that we employ to make products i.e.: monomer is not a "control." 

• Adjusting monomer type and content is one important way resin suppliers adjust product 

properties, and thereby reduce the risk of failed products. 

• Facihties will suffer significant economic impacts if prevented from using the full range 

of resins. 

Monomer is not a "control" 

Unsaturated polyester resins ara tha product of a condensation reaction between difuncttonal 

acids and alcohols, crosslinked with a chemical containing a vinyl unsaturation, typically 

styrene. These three basic building blocks (acid, alcohol, and vinyl monomer) can be varied 

in composition and concentration to obtain a myriad of properties. Resin suppliers continu-
P.20 

From: John Schweitzer To: Madeleine Strum Date: 13/31/97 Tims: 10:03:04 AM Page 9 of 18 

ally adjust resin components and concentrations to customize products for specific applications. 

Perhaps due to a mistaken analogy of composites to coatings, some EPA staff may 

beheve that styrene, because soma of it evaporates during the manufacture of products, can 

be replaced or its concentration ohanged without significantly changing the properties of 

products. In fact, the type and amount of monomer both impart unique properties to the 

polymer. The particular monomer used in a resin, and its concentration, are selected based 

on product specifications, the choice of acid and alcohol used to form the ester, the process 

technology, the cure and processing properties required, and the type of reinforcement 

incorporated in the resin matrix. Changing monomer or monomer concentration alters the 

polymer s properties; this is always the case. 

Tn certain applications, substitution of monomers can be accomplished to meet 

specific product requirements. This does not mean chat the products are identical in properties, but only that the new resin formulation can meet the requirements of a spacifie per. 

formance test. Whether the new resin meets the requirements will often depend on the 

judgement ofresin suppher, fabricator, or end user (see the discussion starting on page $}. 

Where the difference between higher and lower styrene content is not material to product 

performance, we understand EPA's desire to encourage use of the low styrene resin. Howaver, EPA takes this position too far if the standard attempts to dictate resin compositions, 

Our ability to compete depends on our ability to formulate products with a full range of 

properties. Efforts by EPA to rastriot this flexibihty are unacceptable and not mandated by 

the Clean Air Act. 

EPA has not regulotcd the monomer content of any other polymer - or ranked 

facihties and set floors based on monomer content - in any other MACT standard. Many of 

the monomers used for other polymers might b* considered more hazardous than styrene, 

including butadiene, acrylonitrile, vinyl chloride, and formaldehyde. Further, CAA Section 

112 does not envision altering product properties to achieve a level of control equivalent to 

the top 12%. As a matter of consistency with the Act, and with other MA.CT standards, EPA 

should reconsider its approach here. 

Incidentally, since monomer type and content are so important in determining processing and product properties, it could be argued that it is inappropriate to set floors by 

ranking facilities according to monomer content, or, as we've proposed by emission estimates 

based largely on monomer content. After all, monomer is not a control. Given the important 

5 

43 
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role that polymer chemistry plays in composites manufacturing, monomer type and content 

could be better used to establish subcategories.3 

Aa we've noted previously, however, the subcategorization approach we proposed on 

September 13 is much more likely to result in a reasonably simple and workable standard, 

even though the subcategories are really highly diverse groupings. The ranking method 

employed to set the floors is a convenience that allows UR to satisfy the requirements of CAA 

Section 112(d), but is not. really defensible on strictly technical grounds. As long as the 

standard allows us to meet our proposed MACT amission limits on an open-molding aggregate, rolling annual average basis, and does not. place overly stringent restrictions on our 

ability to make products, we can raduce emissions to comply with the CAA and continue to 

make products. This is true even though, because the subcategories contain many highly 

diverse oparations, and monomer i3 not a control, our proposed MELs aro actually not 

achievable for many specific material/process/product combinations. 

Resin suppliers must be able to adjust monomer content to suit applications 

li is certainly true thai any product presantly made with a high-HAl-* resin can ba phyeiocdly 

constructed using a low-HAP resin, or, foi* that matter, using steel, wood, or concrete. However: Will the resulting product provide acceptable performannft? Will it last long enough? 

Does the resin provide sufficient strength and chemical resistance to give the needed margin 

of safety in appUcations whara product, failures can result in injury, death, or environmental 

damage'-' These ara all technical, as opposed to economic, considerations. 

Unfortunately, we seldom have unambiguous answers to these technical questions. 

For example, what is "acceptable performance?" What is "long enough?" How can we define 

a standard "needed margin of safety?" In practice, these questions are decided on a product -

* EPA has used HAP-«ontent limitation most appropriately where the chemical of concern is not part of 

the final product. This is the case for coatings, where tha solvent evaporates, and for blowing agents. 

As diseuaaud in detail above, the monomer used in composite manufacturing is required to build the 

polymer, and the majority of it becomes part of the final product. HAP-eonUm. limits are also appropriate where the emissions can not be readily minimised or controlled, in industries where process 

chances may alter the rate at whicli HAPs are emitted, but not the amount. This is the MBA with many 

coating applications, where coating* are appliod in such a manner and at such locations that no control 

is feasible. This can also be true of blowing agents, where much ofthe HAP is emitted after the product 

leaves the production facility. For composites, the emission period ie always relatively short, is* limited 

to the actual production process, and process changes can be employed Lo reduce the total amount of 

HAPs emitted, 

ZO 
P.22 

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by-product basis, by the end-user, fabricator, and resin supplier, typically based on long 

experience with specific resins and fabrication methods in specific apphcations. 

For example, high-HAP resins, suoh as chlorendic acid polyesters, are recommended 

by many resin suppliers for certain highly aggressive chemical environments^ because they 

give a hiRh level of performance. In these sama apphcations, would a low-HAT vinyl ester 

resin be acceptable? Perhaps. But. again, this decision must be made on a case-by-case basis, and will depend heavily on the experience and judgment ofthe user, fabricator, and resin 

suppUer. A MACT standard that reduces the performance or safety margin, by requiring the 

use of low-HAP resins with even marginal reductions in properties, may cause end-usera to 

choose non-composite materials. 

How are resins selected? For corrosion apphcations, in particular, end users and fabricators 

often rely on recommendations made by resin suppliers. Suppliers base such recommendations on extensive laboratory testing of 

Fig. 1 - On recommending resins... 

"We consider the following factors when recommending a 

resins in literally thousands of 

different chemical environments, as 

well as decades of successes (or 

failures) of products in the Held. The 

suppliers then publish studies or 

guides that offer resin 

recommendations for specific chemical 

services. 

EPA might prefer end users 

and fabricators to select resins with 

lower styrene content, and, in many 

cases, this might ba feasible. 

However, dua to the significant 

damage, and health and 

environmental impacts, which can 

result from product failures, resin 

selection is of necessity veiy 

conservative. Users and fabricators 

are very unlikely to assume this 

liability. And given the importance of satisfactoiy product performance, it is frankly very 

unlikely that resin suppliers will ever be willing to use monomer content as a significant 

resm: 

What is the application? Pulp and paper, mining, petroleum, sewage, plating, or other? 

What process will be used to fabricate the product -

hand lay-up, spray, ftow-coater, filament winding. 

RTM? 

What is the structure - tank, pipe, plate? Does it have 

a lining, and, if so, of what? 

What are the chemicals to which it will be exposed? 

Are there likely impurities not already identified? 

What pH range and specific gravity? 

What is the expected service life? 

What is the operating temperature? What is the highest upset condition? Is the temperature cyclic, and, if, 

so, what is the cycle? 

Is there pressure or vacuum applied? What is the 

operating condition? What is the highest upset condition? Does the pressure cycle? 

If fire or smoke resistance required? 

Is there a requirement on toxic by-products from burning? 

Is a UV stabilizer required?" 

"When we've answered all these questions to our satisfaction, then our Corrosion Product Leader will review our 

corrosion guide, our historical experience and product 

testing, and use his judgement to recommend a resin." 

- Mike Grotke, Alpha/Owens-Corning 

7 
P.23 

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basis for recommending resi ns. For similar reasons, fabricators are not likely to ignore the 

technical advice ofresin suppliers. 

One of the difficulties in setting 

MACT based nn HAP-eontent - and a 

reason why EPA should not even 

consider monomer type and content to 

be a control for the corrosion 

subcategory - is that different resin 

suppliers recommend different resin 

types, with different monomers and 

monomer concentrations, for the same 

apphcations. This is because different 

suppliers have proprietary formulas 

and resins, have differing experience in 

various end uses, employ different 

criteria, and may be more-or-less 

conservative when it comes to 

recommending resins for extreme 

environments. 

Figures 1 and 2 describe the 

processes used by two resin suppliers to 

recommand resins for corrosion 

apphcations. While other suppliers 

may employ different processes and 

different criteria, all will depend on the 

ability to adjust the chemistry of the 

resin, including monomer type and 

content, to suit particular apphcations. 

Pig. 2 - More on recommending a resin... 

"When a request is placed upon our lab to recommend a resin for use in the fabrication of piece of 

equipment that will be exposed to a corrosive environment, several facts need to be considered. The most 

important criteria are case histories. Positive or 

negative, an example where a resin has been used for 

a given application brings with it information that has a 

higher level of credibility than any other source of 

information. If there is a successful case history, the 

same resin is likely to be recommended once again, 

We might recommend a different resin if premium 

polyester is being used, and laboratory testing shows a 

vinyl ester to have equal or superior performance, 

because il is easier to fabricate a good part out of s 

vinyl ester. 

"If there is an unsuccessful case history, we 

convey that to the requestor, and indicate the mode of 

failure. We will then recommend a resin that would be 

expected tb give superior performance in the property 

requiring improvement. 

"If there is no case history available, we 

evaluate the required service. If the piece of equipment is going to be exposed to a fair amount of 

physical or thermal stress, we will try to recommend a 

vinyl ester, as they produce tougher parts. If no 

physical or thermal abuse is anticipated, we would next 

look at the chemical environment. If we have run 

corrosion testing (ASTM C 581) on any resins in the 

environment, we rely on this information. If we have 

not run any testing, we look for similar environments. 

If we have several resins that perform well in the 

environment, we will recommend the least expensive 

resin. 

"If it is an aggressive chemical environment, liability issues demand that we select the resin that we 

believe will perform best in the given application. At 

this point there is little regard given to the cost of the 

resin." •- Tim Pepper, Ashland Chemical 

For example, Ashland Chemical has recommended that tanks for an extraction mining operation be made with high-HAP resins. Extraction mining is a fairly common process, 

where a mineral is dissolved in a relatively dilute acid solution. typicaUy sulfuric acid. The 

solution is kept as hot as possible to faeihtate dissolution. The hot solution is brought into 

successive large vats, allowing the solution to be purified, and then transferred to another 

vat. After the appropriate purification is carried out, the desired mineral is oxidized, and 

precipitated onto a diode. The diodes can be removed from the solution, and the desired 

mineral collected. The process allows the efficient collection of extremely pure minerals. 

8 
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Asldand found that a formidable hurdle was the fact that very few materials stand 

up to hot acidic solutions. The initial recommendation was a tank made out. of a low-styrene 

novolac vinyl ester resin. Many tanks were fabricated, and they started to foil within 

months of installation. After several attempts to build better tanks, o set of tanks was made 

out of a liigh-styrene cresol novolac vinyl ester resin. This resin is known for imparting a 

unique eombin ati nn of toughness, resistance to oxidising environments, and superb thennal 

performance: Eight years later, thare has only been one failure, and it was caused by an 

eiror in fabrication that resulted in walls only half as thick as the specifications. Analysis of 

a section of tha failed tank shows virtually no loss of properties due to corrosion. 

Ashland Chemical has also recommended higher-HAP resins for hot caustic solutions, one of'the most aggreuive chemical environments, common, for example, in the pulp 

and paper industry. Ashland has found that styrene imparts a high degree of chemical 

resistance to caustic environments. The two Asliland resin systems that give acceptable 

performance up to 150°F contain up to 45% styrene, and the system that gives acceptable 

performance up to 1S0°F contains up to 50% styrene. Tables 1 and 2 show ASTM C-581 

results, relative costs, and styrene content-for these three resins and the other best performing low styrene systems Ashland has tested. The C581 data is hsted as the pereent 

property retention after 12 months exposure to the given environment. Ashland considers a 

sample that drops to lass than 50% ofthe original value to have failed. As shown in the 

tables, Ashland's low styrene vinyl esters performad vary poorly in hot caustic. 

Product 

BPA Vinyl Ester 

Novolac Vinyl Ester 

Cresol Novolac VE 

BPA/Fumarlc PE 

BPA Vinyl Ester 

Product 

BPA Vinyl Ester 

Novolac Vinyl Ester 

Cresol Novolac VE 

BPA/Fumaric PE 

BPA Vinyl Ester 

a 1. Ashland's 

% Styrene 

35 

35 

44 

50 

45 

ASTM C-581 Results, 10% Caustic at 150°F 

Hardness 

0% 

0% 

51% 

83% 

17% 

Stiffness 

Coupon failed, 

29% 

81% 

78% 

54% 

Strength 

soft&pliable 

23% 

56% 

84% 

31% 

le 2. Ashland's ASTM C-581 Results. 5% Caustic at 180°F 

% Styrene 

35 

35 

44 

50 

45 

Hardness 

0% 

0% 

7% 

100% 

54% 

Stiffness 

Coupon failed, 

Coupon failed, 

42% 

84% 

70% 

Strength 

soft&pliable 

soft&pliable 

39% 

51% 

64% 

Cost 

1.00 

1.08 

1.00 

1.00 

0.88 

Cost 

1.00 

1.08 

1.00 

1.00 

0.88 

9 

1s> 
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ragt ii orIU . 

Again, other resin suppliers may usa other criteria, consider different and proprietary resins, and make other recommendations for these apphcations. But all would rely on 

an ability to adjust monomer type and content to suit specific applications. If the MACT 

standard limits our ability to tailor products in this way, or places an inappropriate emphasis on monomer content when ranldng facihties and setting floors, then tliis essantisd ability 

to adjust our polymer chemistry will be restricted ur lost. 

Fig. 3 - Case Study: Underground Gasoline Storage Tanks 

EPA is certainly aware that leaking underground gasoline storage tanks (UGSTs) pose a significant threat to the 

purity of ground water in many communities. For the most 

part, this problem has been alleviated by EPA's UGST 

program, which has requiredthe installation of corrosionresistant tanks. Composite tanks, along with cathodically 

protected steel tanks and composite/steel hybrids, have 

provided the corrosion resistance needed to protect the 

environment. The all-composite tanks enjoy inherent 

corrosion and rust resistance; composite UGSTs have 

been unearthed after 30+ years of continuous service, and 

have shown no sign of corrosion or other damage. 

The table below shows the retail prices for UGSTs constructed with'the various materials (source of data in table 

can be provided to EPA as CBI, on request). Retail prices 

are used rather than costs so that a comparison can be 

made among composite, hybrid, and steel tanks. Most or 

all of the differences in the prices for the composite tanks 

can be attributed to differences in resin cost. 

It can be clearly seen that replacing isophthalic resins 

with vinyl ester resins will make the composite tanks 

significantly more expensive than the steel tanks, and 

therefore not competitive in the marketplace. A MACT 

standard that effectively limits or prohibits iso resins from 

use in constructing UGSTs will simply and clearly force the 

domestic manufacturers of these products out of business. 

Retail Price tor 8,000 Gallon Tank 

Isophthalic tank 

ISO outer tank, terephthalic inner 

Vinyl ester lined isophthalic tank 

Iso outer, part'l iso inner, VE liner 

Pure 100% vinyl ester tank 

Composite iso wrap steel tank 

Cathodically protected steel tanks 

Economic Impact of limits on higherHAP resins 

Isophthalic resin systems, which 

require relatively liigher levels of 

styrene content, provide a useful 

combination of moderate cost and pood 

product performance. Vinyl aster 

resins, which can provide at least 

equivalent perform anna levels, are 

significantly more expensive. Products 

made with isophthalio resins 

Successfully compete with products 

made from other materials, such as 

stainlass steel, that are lags expensive 

than the composite products would be 

if made with vinyl ester resin (for 

example, see the ca3c study illustrated 

in Figure S). 

ln most cases, the composite 

manufacturer is not able to pass the 

higher vinyl ester resin costs along to 

the customer, and the customer simply 

will not select the composite product. 

Often, the composite manufacturer is a small business, with a small, specialized product hne. 

In these cases, the inability to use isophthalic resins will simply mean that he goes out of 

business. 

The Composites Institute recently surveyed several of its member companies that 

produce corrosion resistant tanks and equipment, Each company was asked to report, for its 

10 

$3,800 

N/A 

S4.800 

N/A 

$5,800 

54,000 

$3,700 

N/A. 

$6,000 

N/A 

$9,000 

$11,000 

$7,800 

$7,500 

<zH 
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« y « i;i tji 19 

most, recent fiscal year, its resin costs, total production costs, and total soles revenue (for 

composites production), and, for the same period, what its resin costs would have been if it 

had to use vinyl ester resins instead of isophthaho resins. A summary the data obtained in 

this survey ia shown in Table 3.* 

The "operating margins" in the table 

represent the ratio of sales revenue to manufacturing costs. An excess of revenue over 

manufacturing costs (operating margin greater 

than 1.0) is required for a company to pay for 

sales, administrative, and other expenses, and 

return a profit. It is unlikely that a company 

with an operating margin of less than 1 .2 is 

profitable. Of the 12 companies shown, 10 

would simply not survive a MACT standard 

that prohibited their usa of isophthaho resins. 

Incidentally, the variation in impact of 

restricting HAP content apparent among the 

facihties in Table 3 reveals the variation in the 

products made, and markets served, by the 

corrosion industry. Facihty F, for example, does 

not use isophthaho resin to make its particular 

products, while most of the other facihties use 

large amounts of iso resin to make their 

products. 

Facility 

A; 

B 

C 

D 

E 

F 

G 

H 

1 

J 

K 

L 

Table 3 

Operating Margin 

Sales Revenue + Total Manufacturing Cost 

Actual Fiscal Year 

1.26 

1.21 

.12 

1.34 

1.01 

1.3 

1.13 

1.3 

1.2 

1.26 

1.15 

1.27 

Were Replaced 

With Vinyl Ester 

Resins 

0.83 

0.9 

1.1 

0.96 

0.95 

1.3 

0.85 

i 

0.9 

0.86 

0.9 

0.98 

0.97 

New Test Protocol 

The CFA testing performed at the Dow facihty in Freeport, Texas has been instrumental in 

quantifying emissions from controUed and uncontrolled open mold processes. This tastinghas allowed us to develop reasonably accurate and useful amission models for use by facihties and regulators in estimating emissions from open mold processes, and to develop our 

4

 The raw data and identity of the participating companies in Table 3 can b« provided to EPA as CBI, 

on ioquest. 

11 
P.27 

i 

12/31/97 13:28 ©919 5415689 EPA ESD CCPG .®9H . .. ". 

proposed matrix of control options for facilities to use in meeting the MACT emissions 

limitations. 

While the testing has characterized emissions from a wide range of materials, apphcation techniques, et cetera, wa will always have a naad for emission data from new technologies. Such data can ha used to establish control factors for new technologies, so that the 

CFA emission model can be used to estimate emissions from sources using the technologies, 

and so that sources can use the technologies to comply with the MACT emission limits. 

To facilitate such ongoing testing, CFA has developed a lest procedure for characterizing emiesions from open molding operations. EPA has previously been given an early draft 

of this procedure. We are now revising the procedure to address validity and reliability nf 

the testing, and to specify how emission data from a new technology can be converted into a 

control factor for us* with the CFA emission model. The revised protocol will be provided to 

EPA by mid-February. 

The procedure requires a test site to replicate the instrumentation, quahty control, 

airflow, molds, and other important factors from the CFA test program, The procedure also 

requires that a test site be certified as complying with TSO 9000, and that the appropriately 

trained and qualified personnel are available to operate and maintain tha testing and 

analytical equipment. 

Each site is required, on a regular basis, to mold a part using a eet of standard operating conditions (mold, resin and formula, apphcation davice and rate, gel time, et cetera), 

and show that tha resulting emission rate is within some reasonable range of a standard 

emission rata. This standardization prooadure will insure that any significant variation in 

data i« due to the variable being studied, and not due to variation in instrumentation, 

operator technique, or other sources of error. 

We suggest that the MACT standard should allow us to: 1) test new technologies using tho CFA procedure; 2) use the test data to develop control factors for the new technolo* 

gies; S) use the control factors with th* CFA emission model to estimate emissions from 

soureas using the new technologies; 4) use emission reductions resulting from the new 

technologies, and estimated by use of the control factor and model, to meet the MACT 

emission limitation; and 5) also use these emission reductions in our averaging approach to 

offset above-the-floor emissions elsewhere in sources. 

The standard could use the method promulgated as part of the HON for approving 

new technologies demonstrated by the emission testing method [§63.150(1)]. Under tliis 

approach, industry could test a new technology and quantify its emissions, using our proposed protocol. The control factors for this new technology would be submitted to the Agency 

12 

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. . . ........... . f-*!,|C I/O I 

«y<r i / oi is 

for review within a reasonable tima period. Based on how broadly the technology is apphcable to the. composites industry, EPA could publish th* results in the Federal Register. 

Finally, there should be no restrictions on our ability to use tliis procedure to establish control factors for new technologies. Should the standard allow us to use the procedure 

only for technologies that promise very large omission reductions, tliis will stifle innovation 

and discourage development of technologies that achieve smaller, but still important, 

amission reductions. 

Emission Averaging 

We understand that EPA agrees that the open molding MACT should provide an option for 

emission averaging. We appreciate that EPA has apparently taken this position. To make 

sure that EPA and we are in agreement about what averaging is, we'd like to reiterate our 

suggested approach. In short: 

We propose that eaeh major source meet a MACT emission limitation that is 

essentially the weighted average ofthe MACT floors for each ofthe open mold 

processes ai the source. The majority of major sources in the composites industry can change their operations to limit emissions to levels that are as 

stringent these suggested MACT emission limit3. However, to account foi* the 

extreme diversity ofthe Rntijcces within each process group, our facilities must 

be allowed to achieve theee limits on a rolling-annuahaverage basis, aggregating all open mold operations. 

The examples provided to EPA on September 18 demonstrate both the need for, and practicality o£ our averaging approach. 

Consistency with the HON 

During our Septembei-18 meeting with EPA, the Agency suggested that tho emission trading 

provisions in the HON might serve as a useful model for the averaging provisions we need in 

the composite MACT standard. We have carefully reviewed tha HON emission averaging 

provisions and concur that this regulation serves as an excellent model for the composite 

MACT. 

• We note that the HON averaging provisions rely heavily on emission factora for estimating emissions from storage vessels, wastewater, and loading racks. We see a clear 

parallel to the emission averaging we proposed on September 18. 

13 

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• We are also enoour3g«d by EPA's 3trong support for pollution prevention in the HON. 

We advocate the use of pollution prevention wherever feasible, and strongly encourage 

tha Agency to adopt the pollution prevention approach in the HON. 

• The HON averaging provisions exclude sources for which there is no fixed performance 

level and for which determining the magnitude of allowable emissions is not possible 

(e.g., equipment leaks). We agree that where performance levels era not. estabUshed, 

emissions should be excluded from averaging, and there are no sueh sources covered under our proposed averaging approach. 

• The HON allows states to disallow averaging. While states are always free to sat more 

stringent requirements, we propose that the standard formally recognise that averaging 

is Critical to the implementation and feasibility of MACT for open molding, so that states 

are discouraged from disallowing it, 

• The HON apphes a discount factor of 10%, except for pollution prevention. The majority 

ofthe control options in our matrix are pollution prevention techniques, and we do not 

support an across-the-board discount factor in the composite MACT standard. 

• Finally, the HON allows annual averaging, with quarterly checks to shown that emissions do not exceed the MACT emission limitation by more than 00%, We believe that 

this would be a workable approoch for the composite MACT standard. 

Consistency with other MACT standards 

EFA has included emission averaging in a substantial number of MACT standards regulating a diverse group of industries. For example: 

• The petroleum refining MACT utilizes an averaging approach very similar to that 

included in the HON. In order to allow additional averaging opportunities, EPA altered 

the definition of th« petroleum refining source oategory to incorporate marine tank vessel 

loading operations and gasoline loading racke, covered by other MACT standards, when 

located at refineries. This revision "increased flexibility to reduce emissions in the most 

cost-effective manner." 

• The pharmaceuticals MACT and polymers and resins MACTs mirror the HON requirements, adjusted for industry-specific needs. 

• In the primary aluminum MACT, EPA provided an emission averaging approach specific 

to the industry, and disallows averaging for two HAPs (total fluorides and POM). The 

inter-pollutant trading issues ore not germane to the composite MACT, 

t In the proposed polyurethane foam MACT, EPA appears to take two approaches to 

standard development. The first regulates individual emission points (equipment leaks, 

production hne, and equipment cleaning), and the second establishes a source-wide emis14 
P.30 

From: John Sehweltw To: Madeleine Strum Date: 12/31/97 Time: 10:03:04 AM Page 19 ef 18 

sion limitation. Tha source-wide approach is quite similar to averaging, although it is 

not designated as such. 

Conclusion 

As EPA develops the NESHAP for composites, we respectfully suggest that the Agency 

consider the following elements of industry's suggested MACT approach; 

• MACT stands for "maximum achievable eontrol technology." EPA should adopt the 

MACT floors and emission limits we proposed on September 18. Alternatively, before 

proposing floors and MACT emission hmitations, or other requi ram Ants based on the 

floors, EPA should carefully evaluate the "acMevablility'' ofthe floors. Industry can help 

test the feasibility of possible MACT requirements throughout tha highly diverse open 

molding and corrosion subcategories. 

• Especially for the corrosion subcategoi-y, monomer is not a "control." However, so that an 

effective and workable standard can be readily developed and promulgated, we agree 

that monomer contents can be used to estimate emissiona and set floors, as long as the 

resulting floors are in fact achievable by the many diverse facihties in the industry. The 

MACT emission limits must not be sat so low that facihties hav* no choice but to use lowHAP resins. For example, corrosion fabricators should be able to satisfy the standard by 

using low-emitting processes, such ae flow coaters, in conjunction with high-HAP resins. 

• The standard should provide a workable procedure, based on the CFA test protocol, for 

estabUshing control factors for new technologies, and for using these technologies and 

associated eontrol factors to meet the MACT emission limits. 

• Facihties should be able to comply with the MACT emission limits by aggregating all 

open molding operations, and on a rolling-annual-average basis. 

l°\ 
12/31/97 13:31 ©919 541 5689 EPA ESD CCPG 

,. ^i * 

Composites 

Miriam • 

Association 

The Sottm tor G"*.":pcwi«>* EJiKXtsost 

FROM: Steve McNally 

Director of Government Affairs 

PHONE: 703-610-0220 

FAX: 703-619-9756 

PLEASE DELIVER THIS FAX TO: 

Dr. Madeline Strum 

7fc* OsB>f wit* ii.du.ij} 

5Cforr.iAl!;?7 

Pages: 

P.31 

l$!001 

+1(919)541-5689 

Subject: Polymer Casting MACT 

Note: Madeline: 

Attached is a copy ofour presentation on an approach to the portion ofthe MACT which will 

deal with polymer casting operations. 

We look forward to our meeting with you on Monday the 5lh. 

Sincerely, 

Steve McNally 

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January 5,1998 

All Approach to the Maximum Available Control Technology for the Polymer 

Casting Sub-Category ofthe Reinforced Plastic Composites NESHAP 

Polymer casting is a process which involves the use of resin materials containing Hazardous Air Pollutant 

(HAP) components. The process normally involves the blending of a liquid resin with a filler material, the 

addition of a chemical initiator, or catalyst, and then pouring the resulting "matrix'' into a mold. Upon the 

completion ofthe cure ofthe resin matrix, the resulting plastic material is removed from the mold as a solid 

material. There may be certain applications where o casting resin is poured into a mold, with no fil ler 

materials added. 

Polymer casting generally can be divided into the A following major categories: 

1. Polymer Concrete 

2. Solid Surface Manufacture 

5. Cultured Marble Manufacture 

4. Decorative Casting 

Polvmer Concrete: 

Polymer concrete is a tem which describes products which resemble concrete in a number of important 

respects. The polymer concrete materials utilize many inert filler materials which are could be found in 

ordinary concrete, These, matenals would be various mineral sands, gravel and small rocks. The primary 

difference between polymer concrete and ordinary concrete is that there is no lime or water used in the 

preparation ofthe concrete aggregate. The reaction of the lime and the water is unnecessary, as the 

polymer resin is the agent which binds all ofthe filler materials together. 

Polymer concrete is a premium grade material which is utilized in situations where enhanced physical 

propertieis are desired, where enhanced water resistance is desired, or where there is an overwhelming need 

for the concrete material to be placed into immediate service. 

Polymer concrete is used in the manufacture of manhole covers, utility vaults, outdoor furniture, 

construction, road surfacing, chemical impoundment, civil engineering applications, and it is being 

evaluated as a broad replacement for cast iron in many applications. 

Polymer concrete is sometimes mixed in the field for many field applications. In these applications, the 

materials may be pre-mixed at ihe factory, and placed in drums for delivery to ihe construction site, where 

the catalyst material will be blended into the resin matrix. 

In most situations where polymer concrete products are manufactured at the manufacturer's facility, the 

filler materials are blended together with the catalyst and resin m a large mixer. The aggregate is then 

poured into molds or forms. 

Given the large particle size of the sand, and gravel materials in polymer concrete, it is important that the 

resin materials have a particular viscosity. 

Some polymer concrete applications are in conosive applications. In these applications, a corrosion 

resistant resin is most often employed, The corrosion resistant resins which are currently available for the 

polymer concrete industry are high molecular weight isopthalic acid based resins, and vinylester resins. 

Solid Surface Manufacture: 

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Solid Surface is a tcm which describes a panel material product, which resembles polymer concrete in a 

number of important respects, The solid surface materials utilize finely ground inert filler materials, such 

as alumina tri-hydratc. The polymer resin is the agent which binds all of the filler materials together. 

Solid surface is a premium grade material which is utilized in situations where enhanced physical 

properties are desired. TL is used in the fabrication of countertop products, plastic plumbing fixtures, wall 

panels and many decorative applications. 

In most facilities Where solid surface products are manufactured, the filler materials are blended together 

wilh the catalyst and resin in a large mixer. The aggregate is then poured into molds or forms. The 

desirable properties of solid surface materials are enhanced as the filler content of the matrix is increased 

In order lo increase the filler content, and enhance the "wet-out" ofthe filler particles, the mixing is most 

often conducted in a closed mixing machine, and under vacuum. In some facilities, the uniformity ofthe 

resin and filler materials, and high volumes of production, has permitted the use of automated mixing and 

dispensing equipmem. 

Given high filler loading ofthe solid surface matrbc, and the large amount of surface area of the fine 

particle materials in solid surface, it is important thai ihe resin materials have a particular viscosity. 

Cultured Marble Manufacture: 

Cultured Maible is a tern which describes a polymer product which resembles polymer concrete in a 

number of important respects. The cultured maible materials utilize finely ground inert filler materials, 

such as cakium carbonate, The polymer resin is the agent which binds all ofthe filler materials together. 

Cultured marble is primarily used in the fabrication of plastic plumbing fixtures, wall panels and in many 

decorative applications. It has also been used in countertop applications. 

In most facilities where cultured marble pioducts are manufactured, the filler materials are blended together 

with the catalyst and resin in a large mixer. The aggregate is then poured into molds or forms. The 

desirable properties of cultured marble materials are somewhat enhanced as the filler content of ihe matrix 

is increased. 

The mixing is most often conducted in an open mixing machine. In some facilities, the uniformity of the 

resin and filler materials, and high volumes of production, has permitted the use of automated mixing and 

dispensing equipment. 

It is important that the resin materials have a particular viscosity. The viscosity ofthe resin is controlled 

mainly through the addition of styrene as a "reactive diluent", although some manufacturers have reported 

a limited ability to elevate the temperature ofthe resinduring mixing. This reportedly results in a lowering 

ofthe resin viscosity. This has enabled some manufacturers lo utilize lower monomer content resin 

systems, 

Decorative Casting: 

Decorotive Casting is a tcm which describes polymer products wliich have been crafted lo fulfill a number 

of market niches. The polymer resins arc typically blended with a wide variety of materials lo mimic 

various materials. The fillers include metal powders, mineral fillers, wood flour and a number of other 

natural and man-made materials. 

The final products can be made to mimic cast bronze, animal ivory, marble, and a number of other 

materials. The market niches for these products extend from small decorative figurines to expensive 

museum replicas, and works of art. 

In most facilities where decorative casting products are manufactured, the filler materials arc blended 

together with the catalyst and resin in a large mixer. The aggregate is then poured into molds or forms. 

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The desirable properties or decorative casting materials can be enhanced as the filler content of the matrix 

is manipulated either up or down. 

The mixing is most often conducted in an open mixing machine. In some facilities, the uniformity of the 

resin and filler materials, and high volumes of production, has permitted the use of automated mixing and 

dispensing equipment. 

It is important that the resin materials have a particular viscosity. The viscosity ofthe resin is controlled 

mainly through the addition of styrene as a "reactive diluent", although it may be possible to elevate the 

temperature of the resin during mixing. This reportedly results in a lowering ofthe resin viscosity in 

cultured marble manufacture. This may enabled some manufacturers to utilize lower monomer content 

resin systems. 

There are also instances where the resin materials will be utilized without any filler material having been 

blended into the matrix. Generally this process develops a decorative casting product which relics on ihe 

resin to produce a clear, finished plastic. This application can often be seen in the production of poured 

clear finishes on table tops, dear cast encapsulation of materials, and in the production of decorative or 

artwork pieces which mimic glass. 

Characteristics of Emissions From Polymer Casting: 

During the testing which was performed at the Dow Chemical facility in Freeport Texas, there was an 

evaluation done on the emissions from the production of cultured marble sinks. 

This testing involved a small open top mixer, and a sink mold. The product was manufactured in a manner 

consistent with industry practice, and the resulting emissions were measured. 

Ll general il was found that the emissions from the mixing and casting ofthe product resulted in emissions 

of less than one percent ofthe available HAP in the resin (emissions were measured at 0.9%), 

Ii was noted that approximately 5n% ofthe emissions from the process were developed during the mixing 

portion of the process. 

Emissions Reduction Techniques for Polymer Casting: 

Following is a list of possible melhods of reducing emissions from polymer casting, and a discussion ofthe 

feasibility of adopting these limitations as a portion ofthe regulation. 

Covered Mixing Equipment: The testing performed hy the industry on polymer casting 

indicated that roughly 50% of ihe emissions from polymer casting were developed during the mixing 

process. The industry also feels thai ihese characteristic emissions are present in all of the mixing 

processes which occur throughout the broader Reinforced Plastic Composites Industry. 

A requirement wilhin the regulation which would address covers on mixing processes would be an 

appropriate way lo address emissions from ihc mixing process, but with some limitations. 

Certain portions ofthe industry mix the resin materials under vacuum. The industry feels lhat these 

"vacuum mixing'* processes should be exempted from any requirements for the use of "covers" on the 

mixing operations, since the vacuum mixing process presumes that the system is entirely sealed. 

Also, the industry often mixes and blends materials in small batches which are intended for immediate 

usage. Technically it would be unworkable to place too stringent of a limitation on the mixing and 

blending of resins in small quantities. 

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difficult to accomplish under closed mixing restrictions. Therefore, we would hope lhat smaller batch 

mixing would not be required to be accomplished under closed mixing conditions. 

We would Tecommend that all mixing which is performed in containers of 55 gaUons volume, and larger, 

should be accomplished with tight fitting lida, 

We would also recommend that mixing which is performed under vacuum should be exempted from the 

"tight fitting lid" requirements, as the process is already accomplished in a closed system. 

We would recommend that all material be stored in covered containers, and only those resin containers: 

Which arc less that 55 gallons in volume, and engaged in muring activities, 

Which are less than 55 gallons and being used to transport resin material, 

- Which are less than 55 gallons and being actively in use in the dispensing or application of 

resin material, 

shall be permitted to be uncovered. 

We would also recommend that the regulation require that polymer casting facilities shall develop written 

emissions management procedures. This approach would be modeled after a similar approach which was 

used by ihc BPA in the maintenance wastewater requirements at 40 CFR 63. \ 05. 

These written procedures should include: 

An inventory of all HAP containing materials used in the Polymer Casting Process. 

A step by step description of the handling of the HAP containing materials used in the 

polymer casting process. 

An evaluation and determination regarding the most effective method to eliminate OT reduce 

the exposed surface area of the wet resin. 

An evaluation and determination regarding the reduction or elimination ol" the use of HAP 

containing materials in mold preparation and maintenance. 

An evaluation and determination regarding the reduction or elimination of the use of HAP 

containing materials in clean-up operations. 

An evaluation and determination regarding the effectiveness and technical feasibility of the 

use of styrene suppressants in the manufacturing process. 

Conclusion: 

The Industry feels tiiat this approach will lead to tht most effective reduction of emissions in this industry 

segment, while allowing the industry to continue to manufacture products utilizing this characteristically 

low emitting process. 

26 

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