OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

19) ll-J-9 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 19 of 36 

P.1 
P.2 

11-I 0-lfl0 17:25 ALTC ENGINEERING . INC ID = 219 294 4073 P.01 

A-<N ^ 

kmfimcrlng 

Quality Fiberglass Design and fabricator 

January 6, 2000 

Mr. Keith Barnett, Project Lead 

Office of Air Quality Planning and Standards 

Emission Slandards Division (MD-13) 

Organic Chemicals Group 

Research Triangle Park, NC 27711 

Re: Small Entity Outreach - Reinforced Plastics Composites MACT Standards 

Dear Mr. Barnett 

Thank you for the opportunity to comment on development of this very crilical standard for our 

industry. Your forthright approach is appreciated even if we do get a surprise here and there. 

Ahec Engineering, Inc. Dackground 

Altec is a seven-year-old company that has manufactured primarily front and rear caps for Class A 

recreational vehicles for the last five years. The company has grown from 25 employees five 

years ago to 65 employees today. We are bordered on one side by a residential area resulting in 

the nearest residence being 145 teet from our building. So far we have gotten along well with our 

neighbors by being very responsive to their concerns including noise. Part ofthat responsiveness 

has been working hard at pollution prevention. We did a Pollution Prevention Grant Project for 

the Indiana Department of Environmental Management on Flow Coaling in 1997-1998, and we 

are currently testing low pressure Fluid Impact Technology (Magnum) flow coat equipment. 

Gel Coai 

(Note: Ll S. Fiberglass Products, Inc. is the floor facility for Pigmented del Coat. They only 

make septic tanks. The gel coats they use are a gray sandable primer at 33% styrene and a 

cosmetic gel coat at 37%. It is my understanding that they never have used a 30% gel coat. 

Ref Jeff Wallet (Ashland Chemical) 6J4-790-3400 6419*. The plant number is 330-499-X531, I 

talked to Virgil at the plant, who referred me to Jeff Wallet as the technical resource. J 

As a resuh of Altec's BACT limit being improperly set at 31% styrene in 1996, we have put a 

considerable effort into unsuccessful attempts to reach that level. An extensive trial in the spring 

of 1998 caused extensive loss of product and production when a subtle quality detect appeared 

after an apparently successful beginning. The problem was that our production rate was too low 

fbr the shelf life ofthe gel coat, ln other words a larger operation lhan ours could have used this 
0 1 - i 0-130 17:25 ALTC ENGINEERING. INC ID=219 294 4073 

P.3 

P . 02 

material successfully. We are back to gel coats in the 33% to 34% styrene range waiting for our 

supplier io come up with another prototype. 

Our parts arc very visible components on expensive vehicles. In addition to thc fact that a high 

quality standard is required, there is an obvious requirement for weatherability, including 

ultraviolet protection. It would be reasonable to have indoor and outdoor categories for gel coat. 

Products that are exposed to the weather have a requirement for higher levels of pigment and 

ultra violet controlling additives that increase the need for styrene and/or MMA. 

Add on controls (Incineration) 

While a small business could reach production levels that result in emissions greater lhat 100 tons 

VOC, ihey would be at great disadvantage paying for the controls and operating them compared 

to ihc large corporations, ln Altec's case, an incinerator could increase the capital investment by 

a factor of three to live without increasing production which would mean thai it could not be 

financed, lt is my understanding thai incinerators are very noisy. Whh our residential location, a 

significant noise level would make our neighbors very unhappy. In the spirit of more equal 

opportunity for small business perhaps there could be two tonnage levels, one for large and one 

for small business. Until a few months ago we thought our future included a 249-ton limit. 

Would a 100-ton large business, 150 ton small business threshold for add on controls be possible? 

Record Keeping 

Record keeping and reporting will cost Ahec $10,000 to $15,000 per year. 1 understand the need 

for a lot ofthe record keeping for purposes of averaging and keeping the system fair. On the 

other hand, this will bc one more "layer". Perhaps materials whose use could be considered 

insignificant are(?) or could be excluded. In Indiana we are still having to report infonnation for 

ihc Construction Permii - a BACT report for instance. Perhaps another EPA White Paper could 

give us some relief in that area. I understand the dangers of averaging but I believe that it is 

essential. 

Keepmg AP - 42 Current 

Ihis industry was thrown into chaos by aUowing the AP-42 factor lo bc the law from LaFlam 

(1987 ) to Kong et al in 1995. Obviously money and manpower for such work is very expensive. 

Ifl understand this situation correctly, there is no provision for an innovation to be tested to EPA 

specification at the expense ofthe innovator or thc industry at a place like the Indiana Clean 

Manulacturing Technical Institute at Purdue. If my understanding is correct, I believe this is a 

mistake. This is a very innovative industry with excellent leadership and technical expertise in ihe 

Composites Fabricators Association (CFA). lf we are to have new tonnage limitations and a 

series of limits on how wc produce our product there should be an avenue for market driven 

compliance through invention. 

Banking Emissions 
P.4 

01-10-£?0 17:2G ALTC ENGINEERING. INC ID=219 294 4073 P . 0 3 

This was mentioned in the meeting. I believe there is merit to ihc concept. I believe that some of 

thc small businesses wiU be more vulnerable to cycles, and less able to control their destiny than 

the large businesses. The illustration wc heard was a strike at a primary customer's plant. Could 

we be allowed a 24 or 36-month averaging period as a means of accomplishing this purpose? 

Keiih, thank you again for the opportunity to comment. I hope I have been able to provide 

something meaningful, and express it clearly. If clarity is a problem, 1 can be contacted at: 

219-293-1965x225 work 

219-705-0873 mobile 

219-637-9008 home 

altecO 1 (3)eaithlink.net 

Beerean31 (3>aol com 

Sincerely, 

/7T W tf\ *~r<4vk***~*-J^*-' 

Jon L'hommedieu 

Compliance Manager 

Altec Engineering, Inc. 

CC: SBA, CFA 

I UALetlerKI'A Shreia01062U00.wptl