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OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

50) ll-C-20 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:01 AM Sheet 50 of 56 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

= ^x&si " Office of Air Quality Planning and Standards 

I \*\//L / Research Triangle Park, North Carolina 27711 

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Mr. Ed Hayash 

Sales and Technical Support Manager 

for Plastics Additives 

BYK-Chemie USA 

524 South Cherry Street 

P.O. Box 5670 ' 

Wallingford, CT 06492-7651 

Dear Mr. Hayash: 

The Environmental Protection Agency (EPA) is developing 

National Emissions Standards for Hazardous Air Pollutants 

(NESHAP) for the reinforced plastics composites industry. The 

NESHAP is to reflect the maximum achievable control technology as 

required by section 112(d) of the Clean Air Act of 1990. The EPA 

is currently investigating emission reduction techniques and 

controls used by major sources (for example, those facilities 

that have the potential to emit more than 10 tons per year of 

styrene). 

The EPA is currently working with representatives of the 

reinforced plastics composites industry, local and state 

regulatory agencies, and environmental groups to investigate 

potential options for setting a standard. Companies such as 

yours can help in this effort by providing information that will 

be used to develop a number of regulatory alternatives. One 

option we would like to consider is an emissions averaging 

approach for determining compliance. The standard would be based 

on the average emissions level achieved by the best performing 

facilities (i.e. those using pollution prevention technigues or 

controls). We believe this approach would provide the industry 

with a great deal of flexibility and would provide quantifiable 

emissions reductions. Such an approach would also provide credit 

for the use of vapor suppressants such as BYK-Chemie's 740 

additive. 

In addition, we are investigating an option that would 

incorporate the use of vapor suppressants if emissions averaging 

is not used. In order for us to determine whether the use of 

vapor suppressants is a viable control option, it is necessary to 

obtain information on the extent of their use and the conditions 

of use. 

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Your company could assist us in obtaining information so 

that we can explore these regulatory options further. As we 

discussed in our telephone conversation of August 11, 1995, we 

would appreciate your providing information on the use of 

BYK-Chemie's suppressant. The information we are particularly 

interested in obtaining is a list of U.S. companies that 

currently use the BYK-740 additive or any other additives that 

suppress vapor emissions from thermoset resins. This information 

would greatly assist our development of regulatory alternatives 

which could potentially encompass the use of vapor suppressants. 

Please feel free to include any other information that you feel 

is important for EPA to consider. If you have any questions 

regarding this request, please contact me at (919) 541-2383. 

Sincerely, 

Madeleine Strum 

Coatings and Consumer Products Group 

Emission Standards Division 

cc: Linda Herring, Group Leader 

Coatings and Consumer Products Group