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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

80) ll-E-40 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 80 of 264 

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A-94-52 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam and Ken Meardon 

Pacific Environmental Services, Inc. (PES) 

DATE: April 29, 1996 

P:\N404 

SUBJECT: P-MACT Team Teleconference on MACT Floors and Related Issues 

Plastic Composites NESHAP 

I. Purpose 

The purpose of the meeting was to brief the P-MACT team and the EPA Work 

Group on the preliminary MACT floors and key issues in setting these floors, and to 

receive the team's feedback on these determinations. 

JJ. Location of Meeting and Participants 

Place: 

Date: 

Participants: 

U.S. Environmental Protection Agency, OAQPS/ESD 

N.C. Mutual Life Building, 11m Fir. conf. room 

Durham, NC 

March 20, 1996 

Mohan Balagopalan, South Coast AQMD (909) 396-2704 

Bob Burmark, Washington DOE (206) 407-6812 

Linda Chappell, OAQPS (919) 541-2864 

Leslye Fraser, OGC (202) 260-7609 

Bob Goldberg, Washington DOE* 

Elena Guilfoil, Washington DOE* 

Linda Herring, OAQPS (919) 541-5358 

Norm Kaplan, ORD (919) 541-2556 

Greg LaFlam, PES (919) 941-0333 

Jim Lehmann, Mojave Desert AQMD* 

Maria Malave, OECA (202) 564-7027 

Steve McNally, CFA (703) 524-3332 

Christine McPhee, Ohio EPA (216) 963-1205 

Ken Meardon, PES (919) 941-0333 

Arnold Medbery, OSDBU (703) 305-5171 

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Madeleine Strum 

April 29, 1996 

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Richard Nielson, Clark County, NV (702) 383-1276 

Nancy Pate, OAQPS (919) 541-5347 

Alex Santos, CARB* 

John Schweitzer, Composites Institute (313) 668-4703 

Madeleine Strum, OAQPS (919) 541-2383 

* These participants are not regular members of the team or Workgroup nor are 

they EPA contractors. 

III. Discussion 

Ms. Strum began the meeting by asking all participants to introduce themselves. 

She then led the group through the briefing package which had been distributed to the team 

as an enclosure to the meeting notice dated February 29, 1996. 

Ms. Strum reviewed the experience of the Emission Standards Division (ESD) with 

the P-MACT team approach in this project. She said that this industry is large and 

complicated, and this may have contributed to the low level of response from team 

members to requests for input. Therefore, in light of the limited resources and short 

schedule available, she noted that the P-MACT approach was being phased out and that 

the project would be continued under a more conventional (non-P-MACT) approach. Ms. 

Guilfoil expressed concern by asking whether discussions would still be held on the issues, 

and whether the standards would have the needed support. Ms. Strum expressed the hope 

that ESD would not lose support in deciding to go in this direction. She also stated that 

she would continue to work with team members on an individual basis. 

Ms. Strum proceeded to discuss the approaches considered in determining the best 

performing facilities in each subcategory, including the calculation of a "control status" 

(CS) value to serve as an indicator of the level of emission control. One team member 

asked about me origin of the reduction factor of 0.60 for vapor-suppressed resins (VSR). 

Ms. Strum said it was based on results of a test program conducted by EPA/ORD, which 

found an emission reduction figure of 40 percent. Mr. Lehmann asked for the test report, 

and Ms. Strum said that it could be requested from ORD. He expressed the opinion that 

more than "limited" data are needed to support a standard, and that limited data are "little 

better than nothing." Mr. McNally said he shared this concern, and said that the CFA is 

presently conducting further emissions testing to measure some additional variables in 

these processes. He pointed out mat EPA's AP-42 emission factor document does not 

address all process variations. Finally, Mr. McNally noted that their method for determining the level of control is not that much different from the EPA's method. 

Mr. Lehmann stated that, in considering the role of filler, its chemical characteristics need to be examined. With many inert fillers, an adsorption effect occurs and volatile 

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Madeleine Strum 

April 29, 1996 

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emissions from the resin matrix are reduced almost to zero. One participant asked 

whether the "summation" symbol should be shown at the front of the CS expression, and 

Ms. Strum answered yes, the calculation would be carried out for each separate 

combination of resin matrix and control scenario. 

Ms. Strum stressed that the project schedule does not allow waiting for additional 

data. Mr. Kaplan asked whether a facility would be allowed to demonstrate a reduction 

for VSR that would be better than the EPA's default value. Ms. Strum said that such a 

demonstration would probably be allowed. Mr. Lehmann said that States have already 

taken this approach, with the burden of proof placed on industry. 

Under the subcategory-specific MACT floor analyses, Ms. Strum first described the 

floors for open molding. Mr. Goldberg asked how the data base was collected, and 

suggested' that perhaps the States could supply a more complete data base for all of their 

facilities. Ms. Strum summarized the sources of the data base (1993 screening survey, site 

visit reports, permits, phone contacts, etc.) and pointed out that very few pieces of data 

were collected from the short form we developed for State/local agencies on the P-MACT 

team. Mr. Goldberg asked that the EPA send the data base for Washington State facilities 

to him, and he would check it over, compare it to the State's own data, and provide the 

EPA with the results of his comparison. 

Mr. McNally asked whether the new source floor of 95 percent reduction represented a requirement for a control system to deteriorate "not at all" over 10 years. 

Several participants contributed to this discussion, with most believing that incinerators 

should be able to maintain an essentially fixed control efficiency over their lifetime 

(allowing for variations due to inlet loading, etc.). One participant pointed out that the 

standard is sometimes expressed in terms of a limit on outlet concentration (such as 20 

ppm), which is not tied to inlet concentration. Ms. McPhee said that vendors of incineration systems should have data on any change in their performance level over time. 

Mr. Schweitzer claimed that, in future plant expansions, the cost of the add-on 

control for the "new source" could far outweigh the expansion cost. He said that this 

form of technology simply would be too expensive for some operations, and many would 

be likely to relocate to Mexico. The new source floor of 95 percent control (add-ons) 

would "put a lid" on the ability of industry to grow. Mr. Schweitzer wanted to know at 

the meeting whether the EPA feels it has no flexibility in prescribing this level of control 

as new source MACT. If that were the case, industry lobbyists were prepared to approach 

lawmakers in Washington, DC about getting the Clean Air Act changed. Ms. Herring 

indicated that, if there were operations that did not qualify as a "similar source," there 

may be some flexibility to make a separate floor determination for those sources. Mr. 

Schweitzer felt that the industry is too complicated to define similar sources. 

Mr. Lehmann stated that the 15 facilities in his District are "as different as night and day," 

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Madeleine Strum 

April 29, 1996 

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and their only similarity is the use of styrene resins. Ms. Fraser indicated that the EPA's 

Office of General Counsel would be examining the similar source issue over the next 

couple of months. Mr. Goldberg asked whether the subcategories could be changed or if 

specific emission limitation numbers could be specified for each subcategory. Ms. Strum, 

in response, asked how the subcategories would be redefined. Mr. Balagopalan asked 

whether the "best of the best" criterion takes control costs into account in setting the new 

source MACT floor. Ms. Herring said that costs may influence the level of the standard 

when going above the floor, but not in selecting the floor itself. Ms. Strum mentioned 

that subcategorization by size (resin use) was being investigated as a means of analyzing 

the open molders; however, one new small facility was installing a control device. 

With regard to two of the issues cited for the open molding subcategory, Mr. 

Schweitzer stated that in many processes filler cannot be used without compromising the 

properties of me product; in these instances, add-on controls would have to be used to 

comply. Mr. McNally stressed that applications using corrosion-resistant resms had severe 

limits on the ability to change the formulation, saying that such a change could mean that 

the resin formula was no longer corrosion-resistant. Ms. Strum said that we would look at 

separating out facilities using corrosion-resistant resins (not for exemption, but to consider 

them for a separate subcategory). 

Ms. Strum pointed out that four pultrusion operations are using control devices, 

and that the 47 percent reduction MACT floor for existing pultrusion operations (which 

reflects control by an incinerator) could apparently be met through an equipment standard 

(wet area enclosure). Mr. Schweitzer pointed out that the "median" MACT floor facility 

(Owens-Corning) is losing money. Mr. Nielson asked how a pultrusion facility would 

demonstrate that it is equivalent in control to the median source. 

Ms. Strum stated that data are not available to calculate an existing source MACT 

floor for gel coating operations (gel coats have a variety of densities). However, we do 

have data necessary to set a floor for new source gel coating operations. 

For continous lamination/continuous casting, Ms. Strum said mat the existing 

source MACT floor is a 49 percent reduction. Mr. Schweitzer asked whether controls 

installed in the past (such as covers) would be counted toward the 49 percent requirement, 

thus raising the issue of at what point in time do credits occur for existing pollution 

prevention measures and add-on controls. He felt it would be absurd for a facility to have 

to disconnect its existing controls in order to demonstrate that it had applied new controls 

on top of some "uncontrolled" situation. Mr. Goldberg also wondered about the timeframe against which baseline and controlled scenarios would be evaluated. Ms. Strum 

answered that this floor level was intended to be applied as a 49 percent reduction of 

emissions through an abatement device applied to the continuous lamination/continuous 

casting processes. In other words, a cover would not get reduction credit. Mr. 

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Madeleine Strum 

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Schweitzer expressed dissatisfaction with this answer. Ms. Strum then acknowledged that 

a new issue had been identified. 

For BMC compounding, the Agency's data have been revised since the meeting 

review package was distributed. Current new source floor values are 100 percent capture 

and 95 percent control. The control device in question is also used for other composites 

processes at the same facility. For SMC compounding, a revised new source floor of 90 

percent (100 percent capture and 90 percent control) has also been specified since the 

meeting review package was assembled. This control device is also used to control 

emissions from painting operations. 

Mr. Goldberg asked how the suggested work practices fit into the MACT scheme. 

Could the standards consist only of work practices with no other control limits for any of 

the subcategories? Ms. Strum responded that the work practices are part of the floors in 

addition to the numerical limits. Mr. Goldberg asked whether the standards could consist 

of a set of pollution prevention measures and work practices that facilities would determine 

to be feasible. Mr. Meardon then asked how the EPA or the States would enforce a set of 

such measures that would vary among facilities. Ms. Strum reiterated that the reductions 

from many such measures had not been quantified. Mr. Goldberg said that current test 

efforts should help in deciding what emission reductions should be attributed to many of 

these measures. He felt that the control status value approach is a good start, but should 

be taken further by including additional measures. Mr. Balagopalan pointed out that South 

Coast's Rule 1162 sets monomer content limits, and that the marketplace plays a big role 

in the direction of the rule. If certain provisions cannot be met, compliance extensions are 

usually granted. 

Ms. Guilfoil asked whether the Agency is still on track to complete a first draft 

framework for the proposal preamble and rule in June 1996. Ms. Strum responded that 

the next step is to present impact analyses and the results of this meeting to management. 

The Agency is on track if no significant changes are made to the decisions, but probably is 

not if the direction changes. Ms. Guilfoil requested that a draft of the proposal be 

prepared sooner rather than later because of the contentious issues involved. 

IV. Action Items 

The EPA and PES offered to extract the Washington State facilities from the data 

base and send this listing to Mr. Goldberg. Mr. Goldberg, in turn, said that he would 

review this list, compare it to the State's own data, and provide the EPA with the results 

of the comparison. 

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