p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

m23*0ll-E-194 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:11 AM Sheet 234 of 264 
f E3BEH ESg^ 

0 

MEMORANDUM 

DATE: October 13,1998 

SUBJECT: Minutes of September 11,1998 Small Business Open Mqlding.Qufreach Meeting 

for the Reinforced Plastics MACT Standard 

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A- <H'52-

LOCATION: EPA / Environmental Research Center / Auditorium 

Research Triangle Park, NC 

9:00 a.m.-3:00 p.m. 

PARTICIPANTS: 

.^/"^OC^T"" ^ 

Mr. Mark Aker 

Mr. Daniel Boyd 

Ms. Linda Chappell 

Mr. Rick Colyer 

Mr. Allen DeBusk 

Mr. Benny Duvall 

Ms. Deborah Elmore 

Mr. Jack Hanley 

Ms. Missy Henricksen 

Mr. Charles Hester 

Mr. David R. Hillis 

Mr. William Holtzclaw 

Mr. Michael Hood 

Mr. Robert Jemison 

Mr. Ken Kensington 

Ms. Patricia Koman 

Mr. Jim Lee 

Mr. Jon Lhommedieu 

Mr. George McAllister 

Ms. Shawn McKee 

Mr. Phil McMillian 

Mr. Steve McNally 

Mr. Ken Meardon 

Ms. Janet Meyer 

Mr. Lowell Miles 

Mr. Richard Moore 

Mr. Gary Multanen 

Aker Plastics, Inc. 

Society of the Plastics Industry (SPI)/ 

Composites Institute (CI) 

EPA/OAQPS/AQSSD/ISEG 

EPA/OAQPS/ESD/CCPG 

Appalachian Plastics, Inc. 

Aker Plastics, Inc. 

EPA/OAQPS/ITPID/ITG 

Process Technologies, Inc. 

Composite Fabricators Association (CFA) 

PES 

East Carolina University 

Holtec, LTD representing 

MFG Justin Tanks, Inc. 

Hood Manufacturing, Inc. 

PES 

Viatec, Inc. 

EPA/OAQPS/ESD/CCPG 

Palmer of Texas, Inc. 

Altec Engineering, Inc. 

Aqua Bath, Inc. 

PES 

Frees, Inc. 

CFA 

PES 

EPA/OAQPS/ESD/CCPG 

Miles Fiberglass & Plastics, Inc. 

Arrowhead Plastic Engineering, Inc. 

Fiberglass Systems, Inc. 

(304)263-2525 

(410)827-6244 

(919)541-2864 

(919)541-5262 

(540)429-2581 

(304)263-2525 

(919)541-5437 

(219)365-9964 

(703)525-0511 

(919)941-0333 

(252)328-4147 

(302)856-3521 

(714)979-7681 

(919)941-0333 

(616)948-3860 

(919)541-4120 

(915)523-5904 

(219)293-1965 

(615)227-0017 

(919)941-0333 

(318)424-2564 

(703)525-0511 

(919)941-0333 

(919)541-5254 

(503)775-7755 

(765)286-0533 

(208)342-6823 
Madeleine Strum 

October 2,1998 

Page 2 

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PARTICIPANTS (Continued): 

Mr. Mark Naylor 

Mr. Jim Noonan 

Mr. Neil Olsen 

Ms. Melanie Proctor 

Mr. Dick Putnam 

Mr. Frank Ranson 

Mr. John Schweitzer 

Mr. Jonathan Spaulding 

Ms. Madeleine Strum 

Ms. Kim Teal 

Aker Plastics, Inc. 

Indiana Clean Mfg. Technology 

& Safe Materials Institute 

Xerxes Corporation 

PES 

Eckler Industries, Inc. 

The Phil Carter System, Inc. 

CFA 

North End Composites, Inc. 

EPA/OAQPS/ESD/CCPG 

EPA/OAQPS/ESD/CCPG 

(304)263-2525 

(765)463-4749 

(612)887-1821 

(919)941-0333 

(407)269-9680 

(734)622-0162 

(207)594-8821 

(919)541-2383 

(919)541-5580 

GOALS AND OBJECTIVES 

Ms. Strum began the meeting by reviewing the meeting agenda (see Attachment 1). This 

review was followed by a brief round of introductions. After the introductions, Ms. Strum began by 

discussing EPA's main goals and objectives for the meeting (see Attachment 2). Ms. Strum stated 

that EPA's main goals and objectives for the meeting were to share information about the progress 

of the proposed rule for the reinforced plastics industry, and gather feedback from the attendees. 

Ms. Strum asked if the attendees had any additional goals for the meeting. The attendees did not 

offer any additional goals. After discussing the goals and objectives, Ms. Strum continued with the 

briefing. 

BRIEFING ON THE MACT RULE DEVELOPMENT AND THE REQUIREMENTS 

CURRENTLY BEING CONSIDERED FOR PROPOSAL (See Attachment 3) 

During the briefing, Ms. Strum covered the following items: legal requirements, standards 

development, status of MACT development, EPA's approach for developing MACT for existing 

open molding sources, and MACT standards being considered for existing open molding sources. 

Legal Requirements 

Ms. Strum reviewed the legal issues and terms associated with the rule-making process. Ms. 

Strum explained that maximum achievable control technology, or "MACT," is the term commonly 

used to describe the standards mandated by section 112 of the Clean Air Act (CAA). EPA is 

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Madeleine Strum 

October 2,1998 

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required by the CAA to list categories of major sources of HAP and develop MACT standards for 

these categories. Reinforced plastics production was one of the major categories listed. 

Standards Development 

Ms. Strum explained the MACT floor represents the minimum level of stringency mandated 

by the CAA. The MACT floor for existing sources is the average of the best performing 12 percent 

of sources for a category or subcategory of more than 30 sources, or the average of the best 

performing five sources if there are less than 30 sources. The average can be the median or the 

mean. Ms. Strum also indicated that subcategories can be based on classes, types, or sizes of 

sources. For the Reinforced Plastics source category, the average (within each subcategory) was 

taken to be the median facility (sixth percentile). 

Mr. Hood inquired if resins used during polymer casting could be averaged with the gel coats 

applied by a facility that uses polymer casting. Ms. Strum responded in the negative and indicated 

that facilities using polymer casting could only average among the gel coats used. Ms. Strum stated 

that because polymer casting is a separate subcategory from open molding and that averaging is not 

allowed across subcategories, averaging between polymer casting and gel coating is not allowed. 

Ms. Strum added that a 12-month rolling average option (for open molding) is being considered to 

add flexibility. 

Mr. Olsen asked for an explanation of the difference between "setting" and "calculating" the 

MACT floor. Ms. Koman stated that the MACT floors are calculated during the rule making 

process, and that the decisions are set when the Federal Register proposal notice is signed by the 

Administrator. Ms. Koman added that comments are taken after the proposal in the Federal Register, 

and that changes may be made as a result of the comments. After the comment period, the rule is 

promulgated in the Federal Register. Mr. Olsen inquired as to when facilities must comply with the 

limits in the rule. Ms. Koman stated that facilities are not required to comply with the MACT 

standard until after the final rule is promulgated. Mr. Olsen asked when the rule would be proposed. 

Ms. Strum replied the rule should be proposed during November 1999. Ms. Elmore stated that the 

current MACT floors represent the data that EPA has gathered through surveys and that attendees 

are welcome to offer data that they feel might aid in the setting of the MACT floors. 

Open Molding Source Approach - Existing 

Mr. Spaulding asked what EPA is considering for the definition of corrosion resistance. Ms. 

Strum stated that the EPA has not developed a definition at this time. Ms. Strum added that both 

the EPA and CFA have suggested definitions to#one another, but no definition has been acceptable 

at this point. 

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Madeleine Strum 

October 2, 1998 

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Mr. Multanen asked about processes that are not listed, such as resin pouring. Ms. Strum 

stated that pouring into an open mold would be considered manual open molding. Mr. Multanen 

expressed concern that any definition not explicitly worded in the rule could be misinterpreted by 

inspectors. Ms. Elmore suggested putting concerns and suggestions into writing and submitting, 

them through the trade association. Ms. Elmore added that EPA needs written documentation to) 

properly take concerns into consideration. Mr. Kensington stated that definitions written by people 

unfamiliar with the industry may not be accurate, so the chance to give feedback about the 

definitions would be beneficial. Mr. Colyer stated that EPA is concerned about proper definitions 

as well, and that suggestions about clarifying definitions would be helpful. Mr. Miles asked if the 

rule could be modified or clarified after the final rule was promulgated. Mr. Colyer replied that 

questions on applicability or interpretation are sent to EPA Regional Offices first for a ruling and 

then to EPA Headquarters, if necessary. Ms. Koman stated that some issues can be handled by 

published guidance materials and others by technical rule revisions. Ms. Meyer indicated that 

definitions can still be clarified after the rule is promulgated, but changes are preferable before 

promulgation. 

Mr. McNally expressed his strong concern regarding EPA's decision to include adhesives 

in the Plastic Parts Surface Coatings MACT Standard rather than the Reinforced Plastics MACT 

Standard. Mr. McNally continued by stating that the removal of adhesives from the scope of the 

Reinforced Plastics Composites MACT is problematic for the industry. Ms. Teal indicated that the 

EPA group addressing the issue is still collecting data and has not yet made a final decision on which 

MACT standard should address adhesives. Several EPA representatives stated that information is 

being collected and suggestions would be welcome. Mr. McNally indicated that no written 

comments were necessary and the EPA should "just do it." Mr. Miles indicated that this issue is an 

important one because adhesives are being used more and more in the reinforced plastics industry. 

Ms. Strum asked how adhesives are applied. Mr. Miles stated that the adhesives are applied using 

either manual or mechanical resin application. Mr. Miles added that the more effective adhesives 

generally contain methyl methacrylate. Ms. Elmore suggested that one possible way to address 

adhesives is to create a separate subcategory for adhesives in the same way that EPA has created a 

separate subcategory for cleaning materials. 

Mr. Holtzclaw indicated that most adhesives are resins in paste form and inquired as to the 

difference between a resin paste and a resin. Mr. Miles stated that one difference is that a resin paste 

is significantly more viscous than a resin in liquid form. Mr. Hood expressed his concern that there 

may be differences in the way that an inspector and a facility define the difference between a resin 

and an adhesive which could lead to compliance problems for the facility. Mr. Miles stated that it 

would be undesirable for a facility to have to comply with another MACT standard simply because 

the facility used adhesives. Mr. Hood stated that complying with a separate MACT standard for 

adhesives would result in an inordinate amount of extra work for a facility that only uses a couple 

of tubes of adhesives a year. 

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Madeleine Strum 

October 2, 1998 

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Point Value System 

Ms. Strum explained the point value system being considered for open molding. Ms. Strum 

pointed out that the system is not a standard emission limit or an emission factor. Ms. Strum 

explained that the goal of the system is to reflect the overall effectiveness of control methods. Ms. 

Strum continued by stating that averaging is allowed within the 10 open molding process groupings 

and that an effectiveness test for vapor suppressed resins is still being developed with the aid of CFA 

representatives. 

Compliance Options 

Ms. Strum stated that the options for compliance include lower HAP content resins, nonatomized applications, add-on control devices, vapor suppressed resins, and vacuum bagging. Mr. 

McNally asked Ms. Strum where she had personally witnessed the vacuum bagging process. Ms. 

Strum indicated that she had witnessed vacuum bagging at a boat manufacturing facility. Mr. 

McNally asked if Ms. Strum had witnessed vacuum bagging at a facility that is part of the Reinforced 

Plastics source category. Ms. Strum responded in the negative but added that EPA representatives 

have called facilities in the Reinforced Plastics source category to collect information about the 

vacuum bagging process. Mr. McNally asked for an example of a product created with vacuum 

bagging where the vacuum bag is applied immediately after resin application. Mr. Miles provided 

an example of recreational vehicle sidewall manufacturing where the vacuum bag is applied shortly 

after resin application. Mr. McNally stated that he did not know of too many applications where the 

bag is applied immediately after the resin is applied to the mold. Mr. McNally continued by stating 

that usually bleeder materials are applied first, then the bag. Mr. McNally indicated that he would 

like to know exactly how the EPA is defining vacuum bagging. Mr. Miles asked Ms. Strum if EPA's 

definition of vacuum bagging included the placement of bleeder material prior to the application of 

the bag. Ms. Strum responded in the affirmative. 

Mr. Holtzclaw stated that vacuum bagging is a process, not a control technology. Mr. Miles 

replied that vacuum bagging could be considered a control technology because it does result in 

closing the mold after the application of resin. Mr. McNally stated that vacuum bagging is done for 

reasons other than reducing emissions. Mr. Miles stated that a facility should receive credit for using 

vacuum bagging even if it was originally intended for purposes other than emission control. Mr. 

McNally inquired whether or not applying a vacuum was necessary to obtain credit. Ms. Proctor 

indicated that the successful application of a vacuum would provide assurance that a complete seal 

was achieved. Mr. Spaulding asked how a resin is distributed with vacuum bagging and whether 

roll-out is allowed within the EPA's definition of vacuum bagging. Ms. Strum indicated that the 

EPA did not want to assign the same level of credit for vacuum bagging which would be done after 

roll-out as vacuum bagging which would be done without roll-out. Ms. Strum continued by stating 

that the 45% reduction credit presently being assigned to vacuum bagging is for vacuum bagging 

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Madeleine Strum 

October 2,1998 

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without roll-out. Mr. Holtzclaw stated that the application of a film to the mold (after resin 

application and roll-out) may represent a potential control technology missed by the EPA. Several 

attendees stated that they covered the filament wound part with a bag after filament winding and 

stated that this was an emission reduction technique that should be considered in the point value 

system. Ms. Proctor asked how the EPA would assign an emission reduction credit to such a control 

technology without any data. Mr. Hood stated that since the applied film can block HAP emissions 

from escaping, the credit assigned to such a control technique should be similar to the credit assigned 

to vacuum bagging. Mr. Holtzclaw stated that the emission reduction credit should be similar to 

vapor suppressed resins. 

Mr. Schweitzer stated that he did not believe that any companies are successfully using vapor 

suppressed resins in corrosion resistant applications requiring secondary bonding. Mr. Schweitzer 

added that when making a corrosion resistant product, secondary bonding problems often prohibit 

the usage of vapor suppressed resins. Several attendees expressed concern that the point values for 

the corrosion resistant subcategories are low enough to force companies to use vapor suppressed 

resins to comply with the standard which could cause secondary bonding problems. Ms. Proctor 

indicated that facilities in the corrosion groupings do not have to use VSR and that there are no 

facilities within the MACT floor that are using VSR. Mr. Kensington asked about the origin of the 

vapor suppressed resin effectiveness numbers. Ms. Strum stated that the 35% effectiveness credit 

for unfilled resins came from test data and that tests of filled resin systems indicate that suppressants 

in filled systems are generally ineffective. Ms. Strum added that the standard would require case by 

case testing to determine the effectiveness of the vapor suppressants used by individual facilities. 

Mr. McNally questioned the effectiveness of vapor suppressants in reducing methyl methacrylate 

emissions. Mr. Holtzclaw stated that due to secondary bonding issues, corrosion resistant tanks and 

fittings often have to be made from the same material, making mixing parts made from higher and 

lower HAP resins impossible. Mr. Olsen suggested that EPA put an asterisk on the maximum point 

value for mechanical application and note that the point value also applies to all secondary parts and 

to attaching secondary parts to the primary part, where the primary part is made by mechanical 

application. Ms. Strum indicated that the facilities in the floor for manual operations are also doing 

secondary bonding and so there is no reason to separate out secondary bonding applications. She 

added that she did not understand the issue since there were facilities in the floor for manual 

operations that conduct secondary bonding. Ms. Koman stated that a small group of people should 

look into the secondary bonding issue further. Persons indicating they would participate included: 

John Schweitzer, Bill Holtzclaw, Dan Boyd, and Neil Olsen. 

Mr. Kensington stated that he believed that the data for facilities setting the corrosion 

resistant floor were incorrect and that EPA needed to visit these facilities. EPA explained that the 

facilities confirmed the data in writing. Mr. Schweitzer also stated that he believed the data in the 

database were wrong. After additional discussion, it was agreed that EPA would send the CFA the 

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Madeleine Strum 

October 2, 1998 

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database were wrong. After additional discussion, it was agreed that EPA would send the CFA the 

copies of contact reports for companies setting the MACT floor so that CFA could review the 

information. 

Mr. DeBusk asked why there is a difference in the point value limit for filled and unfilled 

mechanical resin application. Ms. Strum indicated that non-atomized application (pressure-fed 

rollers, flow-coaters) was not considered a viable control option for filled resin systems and therefore 

the EPA decided to separate unfilled and filled mechanical resin application. Ms. Strum added that 

tests done both by CFA and elsewhere have shown that the effectiveness of vapor suppressants are 

greatly reduced in filled resins as compared to unfilled resins. Mr. DeBusk indicated that his 

company was applying a filled resin system using pressure-fed rollers. Ms. Proctor asked what type 

of filler was contained in the filled resin system applied with pressure-fed rollers. Mr. DeBusk 

indicated that the filler was aluminum trihydrate. Ms. Proctor indicated that if filled resin systems 

could be applied with non-atomized application, then it may be possible for the EPA to recombine 

filled and unfilled mechanical resin application. Mr. DeBusk inquired why the EPA had not 

separated filament winding application into filled and unfilled groupings. Ms. Proctor responded 

that there were very few facilities in the filament winding database that used filled resin systems. 

Mr. DeBusk responded that approximately 80% of the resin that his facility used to produce filament 

wound parts is filled. 

Mr. Schweitzer asked if any of the representatives in attendance knew if their facilities used 

styrene for cleaning purposes. Mr. Multanen answered in the affirmative, but stated that they reused 

the styrene afterwards in the fabrication process. Mr. Multanen asked if a facility reuses styrene after 

cleaning, is this use considered cleaning or part of the fabrication process. Mr. Schweitzer stated that 

cleaning with styrene should not be prohibited as long as the styrene is reused in the production 

process. Ms. Strum stated that the EPA would need to address this issue. 

Mr. Holtzclaw asked about the proposed requirement for mixers to be completely covered 

with no visible gaps around the mixing shaft. Mr. Holtzclaw stated that resins were often mixed in 

55 gallon drums with the mixing shaft going through the bung hole located in the top of the 55-

gallon drum. Mr. Miles indicated that a large number of gel coats are also mixed in 55 gallon drums. 

Mr. Holtzclaw asked if the proposed standard for mixing would allow for a visible gap around the 

mixing shaft for this type of mixing. Ms. Proctor responded in the negative and asked Mr. Holtzclaw 

if facilities could seal the mixing shaft in some way. Mr. Holtzclaw responded in the negative. Mr. 

Kensington stated that covering the mixer is good enough and that a requirement for no visible gaps 

or seals is not necessary. Mr. Spaulding asked if the mixing cover requirement could be changed 

to "mostly covered" or "substantially covered" or "reasonable covered". Ms. Elmore stated that 

those terms were unenforceable (due to being vague) and that any cover requirement would have to 

be expressed in enforceable terms. Mr. Spaulding asked if the standard could be written to allow 

for a certain maximum gap size. Ms. Strum indicated that the EPA would investigate the allowance 

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Madeleine Strum 

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of a gap between the mixing shaft and the mixer cover. Ms. Strum asked what size gap would be 

needed. Attendees suggested allowing a two-inch gap, a one and a half inch gap, or a half inch 

visible gap around the mixer shaft, as well as determining an allowable gap as a factor of the 

diameter of the mixer shaft. Mr. DeBusk stated that filler is often added during the mixing process 

and inquired if the standard would allow the mixer to be open when adding filler. Ms. Proctor 

indicated that the current EPA approach would allow the mixer to be open for the purpose of adding 

materials. 

Mr. McNally stated that the CFA has recommended that mixing vessels with less than a 25-

gallon capacity be exempted from a mixer cover requirement. Mr. McNally then inquired if the EPA 

would provide a technical recommendation on how to supplant small batch mixers that have less 

than 25 gallons of capacity or if the EPA would allow a size cutoff. Ms. Strum indicated that the 

EPA could examine whether a size cutoff for mixing vessels was warranted. Mr. Holtzclaw 

indicated manual mixing in a 5-gallon pail is a common practice in industry and inquired if this type 

of mixing would require a cover. Ms. Strum indicated that the EPA intended to exempt hand mixing 

from the mixing cover requirement. It was inquired whether hand mixing with a motorized device 

such as a mixing shaft on a drill motor would be exempt. Ms. Strum answered in the negative and 

stated that EPA would need to develop a definition of hand mixing. 

Mr. Holtzclaw asked if EPA's requirement for covered storage containers differentiated 

between when the material is being used and when the material is being stored. Ms. Meyer inquired 

if this was an issue that EPA needed to clarify. Mr. Multanen responded in the affirmative. Mr. 

Multanen stated that in his facility, his employees frequently use small containers of resin when 

fabricating products. Mr. Multanen asked if his employees would have to cover those containers 

whenever they set the container down. Ms. Elmore suggested that one way to address the issue 

raised by Mr. Holtzclaw and Mr. Multanen would be to set a maximum length of time that a 

container could be uncovered. Mr. Kensington asked if there was a size cutoff for the covered 

storage container requirement. Ms. Strum responded in the negative. Mr. Kensington held up a 

coffee cup and stated that there were temporary containers in use at his facility that were as small 

as the coffee cup he held in his hand. Mr. Kensington also stated that containers this small should 

not be subject to the storage container requirement. Mr. McNally indicated that it was unreasonable 

for the EPA to require covers on small storage containers. Mr. McNally continued by stating that 

this was especially true since the CFA had submitted to the EPA emissions data that indicated that 

HAP emissions from small containers were insignificant. 

Mr. Miles stated that industry needs controlled spraying in order to meet the point value 

limits required by the standard. Mr. Miles stated that testing has demonstrated that controlled 

spraying reduces emissions and that industry should be provided with incentives (in the standard) 

to use controlled spraying. Mr. Miles also indicated that controlled spraying could be made 

enforceable. Mr. Multanen inquired why controlled spraying was not considered enforceable. Ms. 

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Madeleine Strum 

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Strum indicated that the CFA controlled spraying program had been ruled unenforceable by EPA's 

Office of Enforcement. Ms. Strum added that operator training would be included as part of the 

standard as a required work practice, but controlled spraying would not be included as a control 

option in the point value system for open molding. Mr. Miles stated that if a facility was operating 

a controlled spraying program in a manner similar to an ISO 9000 type of quality assurance program 

that it should be enforceable. Mr. Schweitzer stated that industry representatives should be allowed 

to present to EPA's Office of Enforcement a modified version of CFA's program of controlled 

spraying that is designed to address EPA's enforceability concerns. Ms. Meyer inquired as to when 

the CFA would have a modified proposal ready to present to the EPA, and Mr. Schweitzer stated that 

he would provide EPA with a date by September 22,1998 when the CFA would be ready to present 

a modified control spraying proposal. 

Mr. Hood raised a question about the ability of companies to meet MACT standards while 

under a government contract requiring them to use particular resins. Mr. Hood stated that the U.S. 

Military and governmental agencies often have specific requirements for resins used in fire-retardant 

applications. He gave an example of building code requirements in Los Angeles which require the 

use of fire-proof panels. He said that these panels must be manufactured from Class 1 fire retardant 

resins which have a HAP content high enough to make them difficult to use under the proposed 

MACT standards. Ms. Koman asked if a list of those required resins could be provided to EPA. Mr. 

Hood then asked about corrosion resistant and fire retardant resins being interchangeable under the 

proposed rule. Ms. Proctor stated that the current EPA approach does not consider a fire-retardant 

product or application to automatically be a corrosion resistant product or application. Mr. Hood 

stated that if these resins could be classified in the corrosion resistant product grouping, the high 

HAP content would not cause as much of a compliance issue for facilities using the resins. 

Mr. Hood inquired about the definition of corrosion resistance. After a discussion on 

common uses of these resins and the possibility of defining corrosion resistance based on chemistry, 

Ms. Proctor stated that the definition of "corrosion resistant" needs to be defined by the application. 

Mr. Multanen stated that there are currently many applications for higher HAP corrosion resistant 

resins in non-corrosion resistant applications due to their high quality and low shrinkage. For 

example, certain sections of the tub and shower units produced by Mr. Multanen's company for a 

major hotel chain are produced using a corrosion resistant resin. Mr. Multanen added that changing 

to lower HAP corrosion resistant resins may not be economically feasible. Ms. Koman asked that 

such situations be documented and submitted to EPA to aid in the economic analysis. Ms. Koman 

added that any company which does not want the information to be public record can submit it as 

confidential business information. 

Mr. Miles asked about the economic impact analysis. Ms. Chappell explained the economic 

impact analysis is currently underway and stated that information that would be helpful in the costing 

process includes annual revenues, units produced, sales figures, change in sales, profit margins, and 

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Madeleine Strum 

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costs of switching materials. She stated that it would be particularly useful to know if the MACT 

standard would cause facilities to change their product production. Some manufacturers agreed to 

provide this information if it would be kept confidential. Ms. Chappell agreed to send a list of 

questions about needed facility information to the CFA. 

Mr. Spaulding indicated his belief that resins used for mold manufacturing should be grouped 

with corrosion resistant applications. He stated that because tooling gel coats were broken out 

separately from other gel coats, tooling resins should be broken out separately from other resins. Mr. 

Spaulding added that it would be unnecessary to create another process/product grouping for mold 

manufacturing. Mr. Hood stated that isophthalic resins were typically used for mold making and 

these resins required higher HAP contents. Ms. Strum asked if vinyl ester resins were ever used in 

the industry for mold manufacturing. Mr. Spaulding indicated that vinyl ester resins were 

occasionally used by the industry. Ms. Strum pointed out that data from the boat manufacturing 

industry indicated that several boat facilities use low HAP vinyl ester resins to build molds. Mr. 

Multanen stated that molds are constantly sprayed with chemicals that contain styrene (a corrosive 

chemical) and as such should be considered a corrosion-resistant application. Ms. Strum indicated 

that she did not see a difference between a boat mold being sprayed with a resin and a mold used to 

produce a non-boat product. 

Mr. DeBusk asked about the possibility of exemptions for unique products. He said that 

Appalachian Plastics developed a product with performance characteristics that can only be achieved 

with a modified acrylic resin that contains 60% HAP (mostly methyl methacrylate.) Mr. DeBusk 

stated that currently the facility is considered a minor source, but with the anticipated growth for this 

product, it could become a major source. Mr. DeBusk stated that he could currently make the unique 

product under the proposed standard by averaging in another product that uses a low HAP resin, but 

his continuing ability to do so would depend on the market for the latter product. Furthermore, Mr. 

DeBusk said that this higher HAP resin had many applications and the current requirements would 

not allow his company to grow. Mr. DeBusk stated that they currently cannot afford a control 

device. Mr. Noonan asked whether the operation utilizing the 60% by weight HAP resin was filled. 

Mr. DeBusk stated that it was highly filled. Mr. Noonan said that the problem was EPA's treatment 

of filled resins. Mr. McNally disagreed, indicating that this unique product was a good example of 

where the industry was headed and raised the question about how future products with similar issues 

would be addressed under the standard. Mr. McNally added that he felt there is no MACT floor for 

this industry. Ms. Meyer asked Mr. McNally to provide a rationale for this position. 

Many attendees expressed concern over Aker Plastics, Inc. presence in the gel coat floor 

because of their use of a low HAP gel coat that is not applicable to products in the industry that need 

to withstand weathering. Ms. Proctor indicated that Cook carries low HAP gel coats for other 

applications, for example, marine applications. Mr. Spaulding indicated that his Cook Composites 

Representative did not recommend this low HAP gel coat. Mr. Schweitzer expressed concern over 

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using information from suppliers for regulatory development. He stated that suppliers often indicate 

they have a new product before all of the problems have been worked out and that suppliers have had 

to pull papers they have prepared from conferences at the last minute because their product was not 

ready. Mr. Hood stated that he did not believe that the 24.3% gel coat made by Cook Composites 

was widely available to all companies. He said that his distributor does not have this gel coat. Mr. 

Multanen stated that some companies may have special relationships with resin and gel coat 

manufacturers and distributors which allow them to purchase a wider selection of resins and gel 

coats at a lower cost. Mr. Schweitzer stated that he believed most low HAP gel coats to still be 

under development or inaccessible to many companies. Ms. Proctor indicated that she would check 

back on the availability of the Cook low HAP gel coat and discuss whether the company 

recommends that the low HAP marine gel coat not be used. 

Mr. Mark Aker spoke about his experience with the low HAP gel coat. He stated that Aker 

Plastics uses more than 3,000,000 pounds per year and have been using the low HAP gel coat for two 

years. Mr. Aker continued by stating that it initially took six months to adjust to the new gel coat. 

Mr. Aker added that although the gel coat costs more per pound, less is needed to produce products, 

thus actually reducing overall production costs. Mr. Aker also stated that the application of this resin 

must be controlled to a thickness of 3 mils in order to be cost effective. Many attendees stated that 

they would not be able to achieve that tight of a specification. Mr. Aker concluded by stating that 

he could not say that their low HAP gel coat would work for all companies but that he also felt that 

some companies in the industry were simply going to have to "step up to the plate" and try the new 

low HAP gel coats and resins. Mr. Naylor said that it is possible that companies that make repetitive 

products may be at an advantage when changing their gel coats to lower HAP versions. Mr. Naylor 

added that if a company makes a variety of products with different required physical properties that 

it would have to test out a wider variety of low-HAP gel coats (in order to obtain the required 

product properties) and thus could encounter additional costs or technical difficulties. Attendees 

identified this as a small business issue, noting that while a big company like Aker would have the 

technical resources to make the low HAP gel coat work, small businesses do not have resources 

needed to do this. They also noted that this was a custom product versus repetitive product issue, 

in that facilities making repetitive products would be more focused on the one product and could 

devote the resources to that product. 

u 
P.13 

Madeleine Strum 

October 2, 1998 

Page 12 

Action Items for Industry Representatives: 

1. By September 22, will give a date by which proposal to address concerns about the controlled 

spraying compliance option will be completed. 

2. Report of industry group on secondary bonding issues during the week of September 22. 

3. Submit specific information regarding concerns and suggestions to EPA directly or 

through CFA. Helpful information includes: annual revenues, units produced, sales 

figures, change in sales, profit margins, costs of switching materials. 

4. Provide examples of government specifications or requirements for use of certain higher 

HAP resins. 

Action Items for EPA: 

1. Post meeting summary on the web. 

2. Post averaging example on the web that illustrates the averaging allowed between the 

process/product groupings of the open molding subcategory. After further thought, the EPA 

decided that since this example is not self-explanatory and that it would be counter 

productive to include it on the website. However, the EPA will give an averaging 

demonstration at the CFA's Annual Convention on October 23, 1998. 

3. Send contact reports to CFA. (Sent September 21,1998) 

4. Reinvestigate controlled spraying with the Office of Enforcement and Compliance 

Assurance (OECA) when the new information is received from the CFA. 

(CFA information was sent to OECA on October 2, 1998) 

5. Explore secondary bonding issue with small group identified at meeting. (Additional1 

information requested from CFA October 5, 1998) 

6. Send list of economic questions to CFA to assist EPA in economic impact analysis. 

\Z 
P.14 

^•fJa'hMSni I 

DRAFT 8/20/98 

SMALL BUSINESS OPEN MOLDING OUTREACH MEETING 

SEPTEMBER 11,1998 

MEETING AGENDA 

WELCOME AND INTRODUCTIONS 9:00am - 9:30am 

We will go around the room and participants will state their names, affiliation, a little about their role in 

the organization (if its a trade group or EPA) or type of business they have (for small business participants) 

GOALS AND OBJECTIVES 9:30am -10:00am 

EPA rule development staff will share their goals and objectives for the meeting. We will also ask meeting 

participants to share their goals and objectives. We will record their input and attempt to address these 

goals and objectives throughout the day. 

BRIEFING ON THE MACT RULE DEVELOPMENT 10:00am - 11:00am 

AND THE REQUIREMENTS CURRENTLY BEING 

CONSIDERED FOR PROPOSAL 

The EPA rule development project lead will give a briefing regarding rule development, status, and the 

requirements being considered. There will be a Q&A session immediately following. Questions may also 

be asked during the presentation. 

BREAK 11:00am- 11:15am 

SMALL BUSINESS FEEDBACK INCLUDING 11:15am - 12:30pm 

DISCUSSION OF EMISSION REDUCTION TECHNIQUES 

BEING CONSIDERED AND/OR USED 

We will go around the room and give everyone an opportunity to speak. We will record information on 

flip charts. 

LUNCH IN EPA CAFETERIA 12:30pm - 1:30pm 

AVERAGING DEMONSTRATION 1:30pm - 2:00pm 

We will show how averaging across the various process/product groupings can be used to meet the open 

molding requirements being considered. 

REVIEW OF FEEDBACK/IDEAS 2:00pm - 3:00pm 

15 
P.15 

DRAFT: 8/20/98 

Goals and Objectives 

• Provide information to small businesses 

potentially affected by the reinforced 

plastics MACT standard 

Legal requirements and background 

Status of MACT development 

EPA's approach for developing MACT for 

existing open molding sources 

MACT standards being considered for 

existing open molding sources 

Averaging within open molding 

• Obtain feedback from small businesses 

on the MACT standards being 

considered for open molding 

Discuss small businesses' operations, 

pollution prevention/emission reduction 

experiences 

Listen to small businesses' reactions to the 

standards being considered 

Collect ideas to minimize cost impacts for 

small businesses, while still meeting legal 

requirements and objectives 

A 
P.16 

//A th mm / 'S 

REINFORCED PLASTICS 

MACT STANDARDS 

DEVELOPMENT FOR 

EXISTING OPEN MOLDING 

SOURCES 

Briefing Package 

for Outreach Meeting 

with Small Businesses 

September 11,1998 

Madeleine Strum, Project Lead 

Office of Air Quality Planning and Standards 

Emission Standards Division 

Coatings and Consumer Products Group 

DRAFT: 9/10/91 

Outline 

Legal requirements and background 

Status of reinforced plastics MACT 

development 

EPA's approach for developing MACT for 

existing open molding sources 

MACT standards being considered for 

existing open molding sources 

DRAFT: Ilium 

>5> 
Legal Requirements and Background 

Legal Requirements 

• MACT = "maximum achievable control 

technology." This term is commonly used 

to describe the standards mandated by 

section 112 of the Clean Air Act 

• Law contains a list of hazardous air 

pollutants (HAP) that the EPA is mandated 

to regulate (e.g., styrene, methyl 

methacrylate, others) 

• Law requires EPA to list industry 

categories of major sources of HAP 

(major: potential to emit 10 tons per year 

of a single HAP or 23 of a combination of 

HAP) and develop MACT standards for 

them 

• EPA listed more than 200 major source 

categories -- Reinforced Plastics 

Composites Production is one of them 

DRAFT: 9/IIV9I 

Standards Development 

• Law prescribes the minimum level of 

stringency of the standard, denoted as the 

"MACT floor" 

• Stringency can be different for new versus 

existing sources 

• For existing sources: 

- the MACT floor is the average of the best 

performing 12 percent of the existing sources if 

there are 30 or more sources in the category or 

subcategory 

- the MACT floor is the average of the best 

performing 5 sources if there are less than 30 

sources in the category or subcategory 

- ihe average of the best performing sources can 

be the mean or the median 

• Subcategories can be based on classes, 

types, and sizes of sources 

DRAFT: 9/IU/98 

KP 
P.18 

Different subcategories can have different 

floors ~ cannot allow sources to average 

across subcategories 

MACT floor for new sources is the level of 

emission control that is achieved in 

practice by the best controlled similar 

source 

Timing 

• This MACT standard is due in the year 

2000 (proposal is usually a year before rule 

is final) 

• Compliance date established by rule, but 

generally can be no more than 3 years after 

rule is final 

DRAFT: 9/IIV9I 

Status of MACT Standard 

Development 

Still in pre-proposal rule development 

phase. 

Subcategories currently being considered 

are: 

- open molding 

- closed molding 

- polymer casting 

- pultrusion 

- continuous lamination/casting 

- SMC manufacturing 

- equipment cleaning 

- mixing of HAP-containing materials 

- storage of HAP-containing materials 

MACT floors have been calculated 

Cost data to determine economic impacts 

have been collected and costs are being 

computed 

DRAFT: 9/ltVJt 

i l l 
P.19 

EPA's Approach for Developing MACT for 

Existing Open Molding Sources 

Currently, the open molding subcategory 

has been broken out into process/product 

groupings, for which individual MACT 

floors have been established 

Latest approach to determine MACT floors 

is the use of a "point value" system 

involving averaging 

This type of an approach was suggested by 

industry representatives in September 1997 

DRAFT: 9/IIWS 

The Open Molding Product/Process 

Grouping Currently Being Considered Are: 

• Mechanical resin operations (e.g., spray 

guns that atomize, flow coaters, pressurefed rollers) 

- corrosion 

- non corrosion filled 

- non corrosion unfilled 

• Manual resin operations (e.g., bucket-andbrush, bucket-and-tool) 

- corrosion 

- non corrosion 

• Filament winding/centrifugal casting 

- corrosion 

- non corrosion 

• Gel coat operations 

- tooling 

- clear 

- pigmented 

DRAFT: 9/IUfll 

l& 
P.20 

What is a Point Value System? 

It is a method to combine specific emission 

reduction techniques into a numericstandard 

The poirit value determines the extent to 

which emission reduction techniques are 

employed & their combined effectiveness 

A point value limit is not an emission limit 

A MACT point value limit is determined 

for each product/process grouping within 

the open molding subcategory 

Facilities that have more than one 

product/process grouping can average 

DRAFT: 9/III/9J 

Question: 

How do I know if I am meeting the point 

value limit(s) in the MACT standard? 

Answer: 

Plug in your HAP content, application 

method and other emission reduction 

techniques into the MACT Model 

Model consists of equations for: 

• atomized resin (mechanical) 

• non-atomized resin (mechanical or 

manual) 

• filament winding/centrifugal casting 

• gel coat 

Model will contain methods to 

incorporate: 

- vapor suppressed resins (VSR) 

- vacuum bagging 

- add-on control 

DRAFT: 9/IUI9I 

ft 
P.21 

The emission reduction techniques being considered 

in the model are: 

- lower HAP resins and gel coats 

- non atomized resin application technology 

- vapor suppressed resins (VSR) 

- vacuum bagging (immediately after resin 

application) 

- add-on control device 

You may need to do more than one of the 

above to meet the limits 

We are planning to incorporate a procedure 

into the rule which will allow you to use 

other enforceable emission reduction 

techniques which are not addressed by the 

point value system 

DRAFT: 9/111/91 

Point Value System Summary 

Each product/process grouping will have a 

MACT point value "limit" 

Use MACT model to determine if your 

emission reduction techniques meet the 

point value limits 

Facility has the option to meet a weighted 

average limit for all of its product/process 

groupings on a time-averaged basis (12 

months rolling average) 

DRAFT: 9/I1K9I 

"2JO 
P.22 

MACT Standards Being Considered for 

Existing Open Molding Sources 

What are the MACT point value limits 

and some corresponding potential 

compliance options for the open 

molding process/product groupings? 

DRAFT: 9/l(V9» 

The following notes apply to the compliance 

options listed: 

• All % HAP limits are in terms of % by weight 

and are based on the HAP content of the neat 

resin and any added HAP (filler not included) 

• VSR effectiveness is assumed to be 35% except 

for filled resins where it is assumed to be 0. For 

MACT compliance purposes a VSR 

effectiveness test needs to be conducted. 

Therefore, HAP contents presented in 

compliance options with VSR are approximate. 

The actual HAP content allowed will be based 

on the results of the effectiveness test. 

• Vacuum bagging effectiveness is assumed to be 

45%. This will be further investigated. 

Therefore, HAP contents presented in 

compliance options with vacuum bagging could 

change. 

DRAFT: 9/KI/9I 

VL 
P.23 

Mechanical Resin Operations 

- non corrosion unfilled 

point value = 90 pounds of HAP/ton of resin used 

Some compliance options that will meet the above point 

value: 

28.1 % HAP and atomized or 

36.0% HAP and non-atomized or 

33.1% HAP and atomized with VSR or 

43.6% HAP and non-atomized with VSR or 

35.3% HAP and atomized with vacuum bagging or 

46.9% HAP and non-atomized with vacuum bagging 

DRAFT: 9/11V98 

Mechanical Resin Operations (continued) 

- non corrosion filled 

point value - 160 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

35.0% HAP and atomized or 

44.0% HAP and atomized with vacuum 

bagging or depending on VSR effectiveness 

for filled resins, there may also be a higher 

HAP resin option with the use of VSR 

DRAFT: 9/II19I 

£2-
P.24 

Mechanical Resin Operations (concluded) 

Corrosion 

point value = 160 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

35.0% HAP and atomized or 

46.4% HAP and non-atomized or 

41.3% HAP and atomized with VSR or 

56.3% HAP and non-atomized with VSR or 

44.0% HAP and atomized with vacuum 

bagging or 

60.5% HAP and non-atomized with vacuum 

bagging 

DRAFT: 9/1CWJ 

Manual Resin Operations 

- non corrosion 

point value = 71 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

32.3% HAP or 

39.1% HAP with VSR or 

42.1% HAP with vacuum bagging 

- corrosion 

point value = 85 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

35.0% HAP or 

42.4% HAP with VSR or 

45.6% HAP with vacuum bagging 

DRAFT: 9/IOTI 

12> 
Filament Winding/Centrifugal Casting 

- non corrosion 

point value = 130 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

35.0% HAP or 

48.8% HAP with VSR 

- corrosion 

point value = 148 pounds of HAP/ton of resin used 

Some compliance options that will meet the above 

point value: 

38.7% HAP or 

54.0% HAP with VSR 

DRAFT: MUSI 

Gel Coating 

- clear production 

point value = 518 pounds of HAP/ton of gel 

coat used 

A compliance option that will meet the above 

point value: 

44.0% HAP 

- pigmented production 

point value =• 274 pounds of HAP/ton of gel 

coat used 

A compliance option that will meet the above 

point value: 

31.2% HAP 

DRAFT: 9/llttt 

• 

-2-4 

P.25 

J 

1 

to 
P.26 

Gel Coating (concluded) 

Tooling 

point value = 431 pounds of HAP/ton of gel 

coat used 

A compliance option that will meet the above 

point value: 

39.8% HAP 

DRAFT: 9/1IV9I 

Reinforced plastics MACT standard will also 

address ancillary emission points 

• Cleaning: potential requirement will be 

that cleaning materials contain no HAP 

• Mixing of HAP-containing materials: 

potential requirement will be that mixers 

are to be closed or covered during mixing 

(except when materials are added or 

removed from the vessel) such that there 

are no visible gaps and there is no active 

venting 

• Storage of HAP-containing materials: 

potential requirement will be that 

containers are to be covered (except when 

materials are added or removed from the 

vessel) 

DRAFT: WHWI 

11 

(LO 
EPA MACT Model Point Values1 

HAP 

Content 

(%bywL) 

26.0 

27.0 

28.0 

29.0 

30.0 

31.0 

32.0 

33.0 

34.0 

35.0 

36.0 

37.0 

38.0 

39.0 

40.0 

41.0 

42.0 

43.0 

44.0 

45.0 

46.0 

47.0 

48.0 

49.0 

50.0 

Manual Resin Application 

(Hand Lay-Up/Bucket & Tool Application) 

Non-Vapor 

Suppressed 

43 

47 

51 

55 

60 

64 

69 

74 

79 

85 

90 

96 

102 

108 

114 

121 

128 

135 

142 

149 

157 

165 

173 

181 

189 

Vapor 

Suppressed 

28 

31 

33 

36 

39 

42 

45 

48 

52 

55 

59 

62 

66 

70 

74 

79 

83 

87 

92 

97 

102 

107 

112 

117 

123 

Vacuum 

Bagging 

24 

26 

28 

30 

33 

35 

38 

41 

44 

47 

50 

53 

56 

59 

63 

66 

70 

74 

78 

82 

86 

90 

95 

99 

104 

Mechanical Resin Application 

Atomized Application 

Non-Vapor 

Suppressed 

7

_

4 

81 

89 

96 

107 

117 

127 

137 

149 

.160 

173 

185 

199 

213 

227 

243 

258 

275 

292 

309 

328 

347 

366 

387 

407 

Vapor 

Suppressed 

48 

53 

58 

64 

70 

76 

82 

89 

97 

104 

112 

121 

129 

138 

148 

158 

168 

179 

190 

201 

213 

225 

238 

251 

265 

Vacuum 

3 

Bagging 

41 

45 

49 

54 

59 

64 

70 

76 

82 

88 

95 

102 

109 

117 

125 

133 

142 

151 

160 

170 

180 

191 

201 

213 

224 

Non-Atomized Application 

Non-Vapor 

Suppressed 

43 

47 

51 

55 

60 

64 

69 

74 

79 

85 

90 

96 

102 

108 

114 

121 

128 

135 

142 

149 

157 

165 

173 

181 

189 

Vapor 

Suppressed 

28 

31 

33 

36 

39 

42 

45 

48 

52 

55 

59 

62 

66 

70 

74 

79 

83 

87 

92 

97 

102 

107 

112 

117 

123 

Vacuum 

Bagging 

24 

26 

28 

30 

33 

35 

38 

41 

44 

47 

50 

53 

56 

59 

63 

66 

70 

74 

78 

82 

86 

90 

95 

99 

104 

Filament Winding/ 

Centifugal Casting 

Non-Vapor 

Suppressed 

88 

93 

97 

102 

106 

111 

116 

120 

125 

130 

135 

139 

144 

149 

154 

159 

164 

169 

175 

180 

185 

190 

195 

201 

206 

Vapor 

Suppressed 

57 

60 

63 

66 

69 

72 

75 

78 

81 

84 

87 

91 

94 

97 

100 

104 

107 

110 

113 

117 

120 

124 

127 

130 

134 

Gel Coat 

Application 

Atomized 

Application 

194 

208 

222 

237 

253 

269 

286 

302 

320 

338 

356 

375 

394 

413 

433 

454 

475 

496 

518 

540 

563 

586 

610 

634 

658 

Note 1: MACT Model point values are in units of pounds of HAP per ton of resin or gel coat 

Note 2: The MACT Model point values shown for vapor suppressed resins applied by manual resin application, mechanical resin application, and filament winding/centrifugal casting are applicable for unfilled 

resin systems only. In the case of filled resin systems, the non-vapor suppressed point values should be used, regardless of whether or not the resin system contains a vapor suppressant The point values 

shown for vapor suppressed resins assume a 35% reduction in emissions when a vapor suppressed resin is used in an unfilled resin system. The point values for a vapor suppressed resin used by a facility to 

comply with the MACT standard will be obtained from an equation that uses results of a laboratory test conducted on the facility's vapor suppressed resin. 

Note 3: The MACT Model point values shown for applications with vacuum bagging assumed that the use of vacuum bagging reduced HAP emissions by 45% when the bag and vacuum were applied to the mold 

immediately after the application of the resin and no roll-out of the applied resin occurred. EPA may modify the vacuum bagging credit used to generate the MACT Model point values shown above to 

reflect more recent emissions data after further study. Therefore, the vacuum bagging point values shown above are subject to change. 
P.28 

Averaging within Open Molding 

Facilities doing better than the point value 

limit in one open molding product/process 

grouping can average with another 

product/process grouping that exceeds the 

point value limit. Standard is met if 

weighted average point value limits are met. 

Averaging will be over a 12-month rolling 

period. That means, every month, you can 

compute your point value(s) by taking the 

previous 12 months of resin and gel coat 

data. 

£7 
P.29 

Corrosion - Resistant Manual Resin Application Draft Summary Table (09/04/98) 

Important Notes: 

1) The point values used in this summary table should not be used to determine actual emissions at a specific facility. 

The point value approach does not take Into account all of the various parameters that can affect e specific facility's emissions. 

(2) This database only contains facilities for which the Administrator has information. Other facilities that should be part of this database may exist 

(3) For the purpose of this summary table, vapor suppressed resins (VSR) were assumed to reduce emissions by 35%. The point value for a VSR used by a 

facility to comply with the MACT standard will be obtained from an equation that uses results of a laboratory test conducted on the facility's vapor 

suppressed resin. 

Bank 

1 

2 

3 

4 

5 

B 

0 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

27 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

42 

aoThe 

atthefi 

b»Poii 

Plant Name.' x 

Weighted 

Average % HAP 

In neat resin plus a 

Velasco Scale Co. (Plastics Oiv.) I 38.7 

Resolite I 39.0 

HartzeU Fan, Inc. (Bldg 275) 

1. M. Penna, Inc. 

Magnum Plastics, Inc. 

Beetle Plastics, Inc. 

40.0 

40.0 

40.0 

41.0 

Industrial Linings, Inc. 

ABC Industries, Inc. (Grand Junction, CO) 

ABC Industries, Inc. (Wallace, ID) 

ABC Industries, Inc. (Winona Lake, IN) 

Appalachian Plastics, Inc. 

Fibercast Co. 

Fibergrata Corp. 

Raven Industries, Inc. (Sioux Falls) 

Rubber & Plastic Applicators 

Smith Fiberglass Products, Inc. (Little Rock) 

Xerxes Corp. (Avon) 

42.0 

43.4 • 

•;...• :43.4 

• • • 43.4 , • . ' • . 

'SiRaWK^ssBSS'Ss 

*«mS43;4::«S:5S«|S 

•?8feS8^4SBMBS;,8!; 

• '43.4: 

• • 43.4 • 

SffiS§M434#gf*S& 

iSljl§iS^i&^Ha@# 

MACT Model 

Point Vahie 

(before MACT) 

(IbsAonLb 

79 

65 

85 

108 

108 

114 

114 

114 

121 

128 

128 

128 

128 

128 

137 

137 

137 

137 

137 

137 

137 

137 

137 

137 

Hastings Reinforced Plastics-Viatec (Hastings) | 44.4 J 145 

Owens-Coming (Mount Union) 

Owens-Coming Tanks (Valparaiso) 

Peterson Products 

Picken's Plastics, Inc. 

45.0 

45.0 

45.0 

45.0 

International Reinforced Plastics 

Nova Group, Inc. 

Parkson Aeration & Fiberglas Corp.. Inc. 

New England Plastic Coated Products, Inc. 

MFG Justin Tanks. Inc. 

Ashworth Plastic Products 

46.0 

46.0 

46.3 

46.7 

48.9 

50.0 

149 

149 

149 

149 

151 

156 

157 

157 

159 

162 

180 

189 

Beden-Bsugh Products, Inc. | 56.9 [ 253 

Average: 

Legend: 

Assumed'values-'Nb'data prow 

Footnotes: 

HAP percentages are in tenns of weight percent and they are based on the HAP o 

jcjlity (fillers not included), 

it values ere expressed as pounds of HAP per ton of neat resin plus. 

Other;.:''' 

Emission Reduction 

Techniques

 : 

_^_^_^_^_^_l__^_^_^_^_^_^_ ^ 

B__^_^_^_^_^9_^_^_^_^_^_Hn 

43.4 

ontent of the neat resin plus i 

1 

261 

my HAP that is added loth e resin 
P.30 

Noncorrosion - Resistant Manual Resin Application Draft Summary Table (09/04/98) 

Important Notes: 

(1) The point values used In this summary table should not be used to determine actual emissions at a spedfic fecOity. 

The point value approach does not take Into account all of fhe various pararmtere that can affed a specific facBiys emissions. 

(2)TO*a_ab_*oritycorttairufaeBtiesfwwtt^ 

(3) For tha purpose of this summary table, vapor suppressed rash* (VSR) were assumed to reduce amissions by 35%. Th« pott value for a VSR used by a 

facSay to comply with the MACT standard win be obtained from an ee^auon that uses resute of a laboratory test conduded on to 

suppressed resin. 

(4) Va_um b«ggir«fclosed mold airing was assumed to re_R^ 

such that no roll-out takes place. This assumption maybe modified after further study. 

Bank 

•'-' 'i 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

48 

47 

48 

49 

SO 

Plant Name 

CeremlcCeoljnpJ£we_Co_^^^^^^^^^^^^^^^^^^^ ^ 

Bowie Manufacturing, Inc. 

William Kreysler & Associates, tnt 

MonarohPtasticJria^^^^^^^^^^^^^^^^^^^^^^ ^ 

Johnson Truck Bodies 

New York Blower C a (Plant #2) 

Nlanara Fiberglass. Inc. 

Universal Plasties. Inc. 

Teco. Inc. 

Eckter Industries 

Retterbush Injection Molded Fiberglass Corp. 

Custom FSirealass Manufacturing Ca 

Pickerft Plasties, Ina 

Fiber-Tech Industries. Inc. 

Prototype Concepts, Inc. 

Diamond Coach Corp. 

IMCO Reinforced Plastics. Inc. 

Plastic Composites Corp. 

Robrov Industries, Ina (Beldino. Ml) 

Seal Reinforced Fiberglass 

Warminster Fiberglass C a (Jacksonville) 

Warminster Fiberglass Co. (Southampton) 

Ffoerotass Industries, Ina 

Aero Transportation Products 

ED Industries, Ina (Sportsman Pickup Covers) 

McClartn Plasties, Ina 

S. R. Smith. Ina 

Arrowhead Plastic Engineering, Ina 

Chance Operations, Ina 

Hv-Tec Ftoergtass. Ina 

Gormen-Hupp Co. 

IKG Industries 

Norton Performance Plastics Corp. > 

Century Manufacturing Co. 

Blue Dolphin Fiberglass Pools 

Gruber Systems. Ina 

Larson C a 

Oxford CMP. Ina 

pmra i F.R.P. 

Simon-TeWed, Ina 

Fowler Manufacturing. Ina 

M.C. Gffl Corp. 

Weighted 

Average* HAPr 

In nmrt resin plug's •. 

32.0 

33.5 

33.6 

______iS_____ 

35.0 

35.0 

35.0 

35.0 

35.4 

37.0 

37.0 

44.9 

45.0 

38.0 

46.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

41.0 

•iSv^asSi'ir^-iH^SA?. 

S^'^i^^ilyv*®^.?; 1; 

••: ••41 7 <'•••.••'•:•• 

^riM^^4V*S;*giJ»jS 

43.0 

43.0 

43.0 

44.0 

45.0 

47.0 

48.0 

50.0 

50.0 

50.0 

50.0 

50.0 

50.0 

50.5 

57.4 

MACT Modal 

Point Value 

(before MACT) 

fibs/ton) b • 

47 

63 

69 

71 

74 

77 

77 

78 

78 

84 

85 

85 

85 

85 

87 

96 

98 

96 

97 

102 

102 

114 

114 

114 

114 

114 

114 

114 

121 

126 

126 

126 

126 

135 

135 

135 

142 

149 

165 

173 

189 

189 

189 

189 

189 

189 1 

193 

258 

Other 

Emission Reduction 

• .• .Tec&lauiM •• •.'-

Vacuum Begging 

VSR 

VSR 

VSR 

Average: 417 

29i 
P.31 

Noncorrosion - Resistant Manual Resin Application Draft Summary Table (09/04/98) 

Legend: 

As8um^val-^»feq_tfpreihte ^ 

a • The HAP percentages are in terms of weight percent and they are based on the HAP content of the neat resin plus any HAP that is added to the resin 

at Ihe fadlity (fillers not included). 

b • PoW values are expressed as pounds of HAP per ton of neat resin plus. 

&> 
P.32 

Corrosion - Resistant Mechanical Resin Application Draft Summary Table (09/04/98) 

Important Notes: 

(1) Tha point values used In this summary table should not be used to determine actual emissions ale specific facility. 

The pott value approach does not take Into aeoount all of the various parameters that can affed a specific fadlily's emissions. 

(2) This database only contains fa—Hies for which the Admirustrator h u Information. Olher facilities that should be part of this database may exist 

Bank 

: 1 1 

2 

? 3 

• 4 

5 

6 

7 

8 

9 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

SO 

51 

52 

53 

54 

Plant Nana 

pSfieTanKUi^^^^^^^^T^^^^^^^^^^^v!^ ! 

F.E. Meyers 

vetasoo Scale Co. (Plastics Dtv.) 

HEMCOCorp. 

L M. Pema. Ina 

Magnum Plastics, Ina 

Yankee Plastic Co. 

Beetle Plastics, Ina 

Delta Fiberglass Structures, Ina 

Keamey/Westem Power Products 

HartzeB Fan, Ina (Bldg 275) 

Appalachian Plastics,'Ina 

MFG - Molded Fiber Glass Co. (Union City) 

Non Metallic Resources, Ina 

Raven Industries, Ina (Sioux Falls) 

Smith Ffcergtass Products, h a (LttBe Rock) 

Xerxes Corp. (Avon) 

Xerxes Corp. (Lakeland) 

Xerxes Corp. (Seguin) 

Xerxes Corp. (Tipton) 

Xerxes Corp. (Wmiamsport) 

Owens-Coming (Aubumdale) 

Owens-Corning (Mount Union) 

Owens-Comino Ffoergtas (Conroe) 

Owens-Coming Tanks (Valparaiso) 

Pickenrs Plastics, Ina 

Nova Group, Ina 

RedEwald, ma 

Bradley Specialties Corp. 

GPICorp. 

Hastings Reinforced Plastics • Viatec (Hastings) 

Parkson Aeration & Ffeergtas Corp.. Ina 

H & R Industries. Ina 

New England Plastic Coated Products, Ina 

Diamond Fiberglass Fabricators. Ina 

Spears Fabrication 

MFG Justin Tanks. Ina 

Ashworth Plastie Products 

MBes Fiberglass » Plasties. Ina 

Owens-Coming Fbergjas (Bakersfiekf) 

Beden-Baugh products. Ina 

Weighted 

Average % HAP 

In neat resin phis a 

35.6 

S,®^»s.»3;iMisiiS^ 

38.0 

38.7 

40.0 

40.0 

40.0 

40.0 

41.0 

41.0 

42.0 

42.3 

S^i.a^i^B'KSV^;^! 

:•.:.—•:..'43.8^-: v;--i 

;^;£;5w*;S418.tt;Vss»s%S 

gS5&*8^a^ssj£& 

«iSSS«43S»^i2 « 

^SS^ijSJSiiSas®® 

g^j@®o;8^siss 

i?!^iS®?4a8|asjgigij® 

ai®ig®»3JJS!lSS!i®J 

45.0 

45.0 

45.0 

45.0 

45.0 

45.1 

45.5 

48.0 

46.0 

48.2 

46.3 

46.3 

46.7 

47.0 

_-_-_J__-_-_ -

48.9 

50.0 

50.0 

50.0 

56.9 

MACT Model 

Pott Value 

(before MACT) 

flbsftonib 

114 

120 

152 

160 

168 

185 

193 

• 199 

209 

227 

227 

227 . 

227 

243 

243 

258 

258 

258 

263 

288 

288 

288 

288 

288 

288 

288 

288 

288 

288 

290 

309 

309 

309 

309 

309 

309 

309 

311 

318 

328 

328 

331 

333 

333 

341 

347 

347 

384 

407 

407 

407 

570 

Other./': 

Emission ReducBon 

•j".;-...". - :>.••:• •'.*&£ •:.V.:M,tfK%.''?'.>: V-'^jrF7"

7

] 

_____^___^^^IHH^^H|MH 

^^^^^^^^^^^^^^^^^^^^^^^H —B—i——IHI1_B__^_l_l__^__| 

LH_i_H_B__H-_H-_i 

Average: 43.8 

liOgentt 

Asaime*v_^-»>lo—ttpn»Madg,&^ ^ 

iS' 
P.33 

Corrosion - Resistant Mechanical Resin Application Draft Summary Table (09/04/98) 

a » The HAP percentages are In terms of weight percent and they are based on the HAP content of the neat resin pus any HAP that Is added to Ihe resin 

at the fadlity (fillers rot incused). 

b • Point values are expressed as pounds of HAP per ton of neat resin pus. 

£L\ 
P.34 

Noncorrosion - Resistant Unfilled Mechanical Resin Application Draft Summary Table (09/04/98) 

Important Notes: 

(1) The point values used in this summary table should not be used to determine actual emissions at a specfflc facility. 

The pott value approach does not take into account aO of the various parameter that can aifed a specific fad^ s emissions, 

(2) Thb database only contains facilities for which the AdmWstratorr_i information. Other fac—las that should be part of this database may exist 

(3) For the purpose of this summary table, vapor suppressed restis (VSR) were assumed to reduce emissions by 35%. The point value for a VSR used by a 

faculty to comply with the MACT standard will be obtained from en eolation that usmresulte of a laboratory ted conduded on tta 

suppressed resin. 

(4) Vacuum bagging/closed mold curing was assumed to reduce emissions by 45% wnen dosed mold curirxjoecuraimmedlalefyef^ 

such that no roll-out takes place. This assumption may be modified alter further study. 

Plan* Name 

Weighted 

Average % HAP 

h neat resin. pJus, a ' 

MACT Model 

PottVaue 

(before MACT) 

(fbjflgflXb. 

Lawrence Wltlman SCO.. Ina 

33 

59 

74 

78 

83 

90 

102 

112 

114 

117 

121 

121 

121 

137 

143 

148 

Other 

VSR 

18 lOrayson Tool Co. 

19 

20 Into! Manufacturing, tna 

34.0 149 

149 

150 

160 

VSR 

22 

23 

24 

- 2 5 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

38 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

ACME ReWbreed Plastics. Ina 

Epoch tndustrifls • 

G&bon Fiberglass Reprod., Ina 

Gtesspec Associates. Ltd. 

Johnson Truck Bodies 

Marley Coolina Tower C a 

New York Blower Co. (Plant #2) 

Newport Laminates 

Style Crest Products 

Universal Plastics, Ina 

VMC Ffeeralass Products. Ino/Tri-Glas 

Kreider Manufacturing, ma 

Molded Plastic Industries. Ina 

Comteeh Antenna Systems. Ina 

Dow Chemical (Russeftvffle. AR) 

Fixe Body Industries, ma 

RetterbushMedioi^AoWedr^ 

Continental Camper Ca . Ina 

Pickerrs Plastics. Ina 

Murphy Body Co. 

Alliance Eauoment Co.. Ina 

Covermaster. Ina 

Fbergtass Forms, Ina 

Fberglass Specialties. Ina 

r_—i line of Asts—a. ma 

PhD Carter System, h a 

Piedmont Ffeerglass. ma 

Ptos-Tech, Ltd. 

35.0 

• -o 35.0- .• 

• • 35.0'--'" 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.3 

38.0 

37.0 

37.0 

37.0 

_—___!£__—_—_i 

38.0 

45.0 

39.5 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

160 

160 

160 

160 

160 

160 

160 

160 

160 

160 

160 

164 

173 

185 

185 

185 

185 

199 

201 

220 

227 

227 

227 

227 

227 

227 

227 

227 

• " '\,,,; ' ' '' 

VSR 

id 
P.35 

Noncorrosion • Resistant Unfilled Mechanical Resin Application Draft Summary Table (09/04/98) 

52 

S3 

54 ' 

55 

56 

57 

58 

59 

60 

81 

62 

63 

84 

65 

68 

67 

68 

69 

^70 

71 

72 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

B3 

84 

85 

.-'••88 

87 

88 

89 

90 

91 

92 

93 

94 

95 

98 

97 

98 

99 

100 

101 

102 

Seal Reinforced Fiberglass 

iyntechnics 

Warminster Fiberglass Co. (Jacksonville) 

Warminster Fiberglass Co. (Southampton) 

Aero Transportation Products 

C & K Fiberglass Plastics. Ina 

Delta Fiberglass & Environmental Products, Ina 

Fiberglass Plus Recreational Industries, Inc. 

Gtas Master, ma (Plant #1) 

Glas Master, ma (Pbnt«2) 

GPM Industries, ma 

Mlchlana Fiberglass,Ina •><•' 

Olympic Ffeerglass Industries, Inc. 

Plastj-Fab, Inc. 

Tom Smith Ffeergtass, Inc. 

Ffeerglass Industries, ma 

Lund Industries, ma 

Northwest Bodies. Ina 

Elmore Truck Accessories, Ina 

Ffeerglass & Plastic Fab.. Ina 

Global Glass. Ina 

Standard Glas, Ina 

Bala Products Ltd. (Salisbury) 

U.S. Ffeerglass Products. Ina 

Arrowhead Plastic Engineering, Ina ' 

Chance Operations. Ina 

Ffeerdome. ma (Ptenttl) 

Gorman-RuppCo. ? 

Marguis Corp. 

Monarch Plastic, Ina 

Spectafty Plastics Associates. Ine 

Arrow Dynamics, Ina 

Beaver Motor Coaches, ma 

Evelsnds, Ina 

Flberglasi Engineering Corp. 

Mother Manufacturing Co.. Ina 

Peterson Products 

Pifflngs F.R.P. 

Sknon-Teleled, Inc. 

TraB Wagons. Ina 

KBK Industries, Ina 

Baja Products (Tucson) 

Attbar Plastics. Ina 

Fiber Pad, Ina 

Pearl Baths, Ina 

Am tech Corp. 

Krrttfs, h a 

Plastic Development Co. 

Ultra/Gtes of Lakeville 

40.0 

40.0 

40.0 

40.0 

iiSSSpSiw^i^iiiS? 

i*ffiKSSaSol2'Sti®Sii 

llJMSJio^iimi l 

!&SiS§40l2l§8lli§S 

#3SII^MJilISI8 

E^^ian i iif^SSiiblSS^IMIi 

^^S*_SM?i i 

Si^iiilii^^ S 

40.3 

44.0 

41.0 

41.0 

41.5 

42.0 

42.0 

42.0 

42.0' 

47.5 

46.0 

43.0 

43.0 '•:':• ••, > '. 

43.0 •• • 

. 44.o^,v«;v-;ft"' 

44.0 

44.0 ' 

44.0 

45.0 

• 45.0 '• 

' 45.6'C' 

45.0 

45.0 

45.0 

45.0 

45.0 

45.0 

46.0 

47.5 

48.0 

48.0 

48.7 

50.0 

50.0 

50.0 

50.0 

227 

227 

227 

227 

230 

230 

230 

230 

230 

230 

230 

230 

230 

232 

241 

243 

243 

250 

258 

258 

258 

258 

263 

284 "•••-'' 

.:>..'275': 

'•" 275:?.'-

m:is292' ' 

292 

292 

292 

292 

309 

309 

309 

•309J'''-;UV'' 

'309 • 

309 

--•• 309 

309 

309 

328 

347 

358 

368 

366 

380 

407 

407 

407 

407 

Some VSR 

.,.'(••.",.'. - •:•• = .-. • > : 

VSR (75%) 

Carbon filters. VSR (50%) 

• •'•'• ' • • '"T-.; : " ' .• •< -...?' '•'•'••.• 

'•"-V" ' .:••:. :'% ' ' '•' \y. >;•: • 

'•" • • • •••. 1 '--.;:^""- " - . •";•• • .'•••' • > • 

•

 : " - ' •'••• • •;'.'.«/,:.. : • 

- " • ' ••":'; '••••.•.' " ->:? • 

Average: 40.2 

a • The HAP percentages are in terms of weight percent end they are based on the HAP content of the neat resin pus any HAP that is added to the resin 

at the faettty (fflers m l induderfl 

b • PoW va—N ara expressed as pounds of HAP per ton of neat resin put. 

s\ 
P.36 

Noncorrosion - Resistant Filled Mechanical Resin Application Draft Summary Table (09/04/98) 

Important Notes: 

(1) The point values used in this summary table should not be used to detanTilne actual emissions at a specific facffly. 

The pott value approach does not take Into account aS of the various parametera that can affed a specatefecBiys emissions. 

(2) THs database only contains facMies for which the Administrator Ir a information. Other faefflies that should be part of this database may exist 

(3) Na emission reduction credit was given for the use of vapor suppressants bi filled resin systems. 

(4) Vacuum bagging/dosed mold curing was assumed to reduce emtestara by 45% when dosed mold curing occurs immecOmely after reshape 

such that no roll-out lakes place. This assumption may be modified altar further study. 

Rank, 

1 1 

'2 

3 

' 4 

."-'5 

6 

7 

8 

9 

10 

11 

12 

13 

U 

15 

16 

17 

18 

19 

20 

21 

22 

- 23 

24 

25 

28 

27 

28 

29 

30 

31 

32 

33 

34 

35 

38 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

Plant Name .•.•.?._•: 

:'•••:-'':-7 •'L- t :":-""'T-=- - -- , .----_---- - -^—_•- - "..-T-T^--" - z-^.s - — ~ -

Glasstss. ma 

Ffeergless Products. Ina 

Astoria Industries, Ina 

Americh Corp. (Hollywood, CA) 

Hess County Industries of WV, Ina 

MFG -Molded Fiber Glass C a (Adelanto) 

S.W.C. Industries, ma (SwH-Way Dtv.) 

Odom Ffeerglass, Ina 

Ecktor Industries 

Tornkkts - LASCO Bathware (EBzabethtown) 

Accra Industries, Ina 

Fleetwood (Fontana - formerly Gold Shield) 

American Reinforced Plasties 

Cedar Manufacturing, Ina (Bremen Glas) 

Tomkkts • LASCO Bathware (Lancaster) 

A Ft E, ma (Mount Eaton) 

20th Century Ffeemtass. Ina (Plant #4) 

A-1 Ffeerglass. Ina 

Clark Manufacturing 

Jason International, Ina (N. tittle Rock. AR) 

KbhterCa 

Mr. Tubs, ma 

Plastic Composites Corp. 

Universal Rundle Corp. (Union Pott) 

Fleetwood (Decatur - formerly Gold Shield) 

Cr—lama Fiberglass, Ina 

Bathcraftlna 

TomMns - LASCO Bathware (South Boston) 

Electric-Glass. Inc. 

Hoi—ay Rambler Corp.. Plant 36 end 37 

Aqua Bath Co.. Ina 

Aqua Glass Corp. (Klamath Falls) 

Associated Plasties, Ina 

ED Industries, ma (Sportsman Pickup Covers) 

Efer Pumbingware (Wilson) 

Glasoo Plastics. Ina 

Images Products Corp. 

Jason Industries. Inc. (Elkhart IN) 

Leer Midwest 

MeCtarin Plasties, Inc. 

Mireds Recreation Co. 

S. a Smith. Ina 

Acme Ffeerglass, ma 

AKER P——3 Co., Ina (Plymouth. N Oak Rd) 

AKER Plastics Co., ma (Plymouth. Pideo Or) 

Weighted 

Average % HAP 

In neat resin nfctt ft 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

37.0 

47.7 

37.5 

37.8 

37.9 

38.0 

477 

38.5 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.2 

41.0 

41.2 

48.1 

42.0 

42.0 

. '42.6''. •• 

^Al'lA^SiO 42^>Si~'Y-'&^;A:: 

;S^W^S?4_B'S5feSf^X?Sil 

:

;•.•:•.. •••;•,.42.6 • v .•':•••• 

:

;®^SsS?4—S^fSiiKfiS; 

'!-I*.'.T.-. t.ii.l^^i. 0 y . .-.1VV.V.-.V. • 

•'•.••:•:••'.'•. '426' . •':'•;::•'• ' 

?$&mmM&m$^M 

i^&??MitiSsis^MsMi 

?m^$w$W6^iw^ 

'£&&^$4$&$8£&&&^$ 

S^M^aj^MSSSS 

43.0 

43.0 

43.0 

MACT Model 

Pott Value 

(before MACT) 

(Tbs/tonjb 

. 13 . 

13 

17 

107 

160 

160 

160 

160 

160 

160 

160 

161 

185 

189 

192 

196 

197 

199 

203' 

206 

227 

227 

227 

227 

227 

227 

227 

227 

230 

243 

248 

256 

258 

258 

268 

268 

268 

268 

268 

288 

268 

268 

268 

268 

268 

268 

275 

275 

275 

• •/•,';'v:'.--pihiir^i::-!V- ''" kv'v. ' 

:•..•; EmtssjcnRe_|dion..s,v;••;',.>• . , :>, 

:•?•*'•'•'• ..'..i.'\x \v<:1Mhntau«,''.^'i}:'|...'..\ii.>.C',.i '.••" 

VSR (Filled Resin Systems) 

Thermal Oxidizer (47.6% Control). VSR (Fled) 

VSR (Filled Resh Systems) ' 

"•'••••• VSR (Filed Resin Systems) '.* V 

Thermal Oxidizer (43.7% Control). VSR IFOedl 

. . '... .V. ' .;'••• .•;',•• , M ;'..-: 

. . • • 

VSR (50%. Filled Resin Systems) 

VSR (Filled Resin Systems) 

Thermal Oxidizer (30.2% Control). VSR (72%. Fined) 

C8I 

VSR (FBed Resin Systems) 

VSR (FBted Resin Systems) 

VSR (Fffled Resin Systems) 

36 
P.37 

Noncorrosion - Resistant Filled Mechanical Resin Application Draft Summary Table (09/04/98) 

S3 

54 

55 

SB 

57 

58 

59 

60 

i61 

62 

63 

''64 

65 

66 

*e»>-

'-es" 

69 

70 

^ir'-

72 

73 

74 

75 

78 

.v77:-

78 

79 

60 

Americh Corp. (Charlotte. NC) 

Aqua Glass Corp. (AdamsviDe) 

Armorcast Products Co. 

Sunset Plastics, Inc. 

Bremen Glas, Ina 

Custom Fireglass Manufacturing Co. 

Brurnd Products of Florida, ma 

G. W. Ffeerglass, Inc. 

McClure Industries, Inc. 

Country Coach, ma 

UrwmsaM—idleCorp?(Oth.ifitwa) '"' 

B]erManufactunng(Va)oosta) 

Tbrnkta- LASCO Bathware (Moapa) . "V 

TomWns7-IXSCQBaOrmn (Anaheim) 

Tomldns - LASCO Bathware (Three Rivera) 

Tomldns-LASCO Bathware (Cordate) 

National Fiber Glass Products, Ina • 

Nordic Fiberglass. Ire. (Devils Lake) 

Nordic Ffeerglass. h a (Warren) 

Fiberglass Systems, Ina 

Oasis Industries. Ina 

Space Tables, Ina 

Accurate Glass, Ina 

Great Lakes Plastics Corp. 

Larson Co. 

DascoPro.lna 

Untversal-Rundle Corp. (New Castle) 

43.0 

43.0 

43.0 

43.0 

44.0 

44.9 

45.0 

45.0 

45.0 

••'

 ; 45. 9 -•-.••'•: 

46.5 

470 

470 

47.7 

47.7 

478 

48.0 

485 

485 

49.0 

49.0 

49.0 

60.0 

50.0 

50.0 

55.0 

60.2 

275 

275 

275 

275 

292 

308 

309 

.-.^309 ..... . 

309 

326 

334 

337 

347 

347 

360 

360 

362 

368 

376 

376 

387 

387 

387 

407 

407 

407 

523 

662 

VSR (FUed Resin Systems) 

VSR (Filled Resin Systems) 

VSR (Filled Resm Systems) 

x--- . .-. -.••• , -.•;• . -.;.•••->•:*;•.. . • • •-•••.• 

VSR (Fined Resin Systems) 

. .-n\V . .-...:.. 

VSR (Filled Resin Systems) 

v^R(Fttled Resin SYStems)< 

VSR (FHIed Resm Systems)" 

VSR (FISed Resin Systems) 

VSR (Filled Resin Systems) 

' VSR (Filled Resin Systems) 

:-',:\ . 

Average: 42.8 

AJs-toMe^aMaamade^ 

ai« The HAP percentages ere In terms of weigh! percent and they are based on the HAP content of the nett resm p—i any HAP that badoed to the rash 

at the fee—y (fillers not Included). 

bi« Point values are expressed as pounds of HAP per ton of neat resin plus. 

&u> 
P.38 

Corrosion - Resistant Filament Winding/Centrifugal Casting Draft Summary Table (09/04/98) 

Important Notes: 

(1) The point values used In this summary table should not be used to determine actual emissions at a specific fadlity. 

The point value approach does not take into account all of the various parameters that can affed a spedfic fadltt/s emissions. 

(2) This database ctty cartains facilities for which the Administrator has Wbmiation Other fac—ies that should be part of this database may exist 

Bank 

1 

••'2 

"'3 

•'"'4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

Plant Name •...-.*" 

Velasco Scale Co.(Plastics Dlv.) ..::..: ___^ _ ; 

Xenon Co., Ina 

Industrial Ffeerglass Spec—ties, Ina 

Beetle Plastics, Ina 

Xerxes Corp. (Avon) 

Xerxes Corp. (Anaheim) 

Smith Fiberglass Products, Ina (Little Rock) 

Smith Fiberglass Products, Ina (Wichita) 

Ssnon-Telelect Ina 

International Paper (Hampton) 

ABC Industries. Ina (Winona Lake. IN) 

ABC Industries. Ina (Wallace, ID) 

ABC Industries. Ina (Grand Junction. CO) 

Rubber & Plastic Applicators 

RedEwald. Ina 

Owens-Comina Tanks (Valparaiso) 

Owens-Comina Ffeerglas (Conroe) 

Owens-Coming (Mount Union) 

Owens-Coming (Aubumdale) 

Fowler Manufacturing, Ina 

Ameron, Ina (Burkbumett) 

Nova Group. Ina 

International Reinforced Plastics 

GPI Corp. 

Specialty Plastics. Ina 

Ecowater Systems 

Hastings Group. Inc.-vlatec (Belding) 

MFG Justin Tanks, Ina 

Diamond Fiberglass Fabricators. Ina 

Owens-Coming Fiberglas (Bakersfield) 

ConleyCorp. 

Weighted 

Average % HAP 

in neat resm pus a 

48.0 

;^^^87_-_ _ 

42.0 

^^^42j()^ ^ 

42.2 

iiSssS44lBiJiifSS; 

ISSS&l44!tfSPfS:sS^ 

^SS^ielfiSiS ' 

SSStsMesiM^SS 

*SiKV:>::^r:^"S441S^^.^'^i^:V^V.v': 

!SiKSi®44jjSs?iSS5t 

44.8 

§I§is£4^S«SS: 

^t§lM8Si*S§;§ 

45.0 

45.0 

45.0 

45.0 

45.0 

45.0 

45.0 

45.1 

46.0 

46.0 

47.0 

48.0 

48.5 

48.9 

49.0 

50.0 

50.0 

MACT Model 

Point Value 

(before MACT) 

(lbs/ton) b 

52 

144 

148 

154 

154 

184 

164 

164 

164 

165 

167 

169 

178 

179 

179 

179 

179 

179 

179 

179 

179 

179 

180 

180 

180 

180 

180 

180 

180 

180 

180 

185 

185 

190 

195 

198 

200 

201 

201 

206 

208 

Other 

Emission Reduction 

^ • •••••:•" ' ' • ~ . •: -^ - • ^ | 

' 

•H--M-I 

Average: 

Legend 

Assumed values - no data 

Footnotes: 

a • The HAP percentages are in terms of weight perceti and they are based on the HAP ocntert of the neat resm plus any HAP that b added to the resin 

at the facility (fillers not included). 

b <• Point values are expressed as pounds of HAP per ton of neat resin pus. 

31 
P.39 

Noncorrosion - Resistant Filament Winding/Centrifugal Casting Draft Summary Table (09/04/98) 

Important Notes: 

(1) The point values used In this summary table should not be used to determine actual emissions at a specific facility. 

The point value approach does not take into account all of the various parameters that can affect a spedfic facility's emissions. 

(2) Thb database only contains facilities for which the Administrator has Information Other facilities that should be part of th'o database may exist 

(3) For the purpose of this summary table, vapor suppressed resins (VSR) were assumed to reduce emissions by 35%. The point value for a VSR used by a 

facility to comply with the MACT standiard will be obtained from an equation that uses resulte of a laboratory tad oonduded on the fadlitys vapor 

suppressed resin 

Bank 

1 

2 

3 

4 

5 

6 

7 

8 

9 

• ' " E'ant^ Name ;•' ••.••''• • . .'• 

Emsig Manufacturing Corp. 

Henderson. Black & Green, Ina 

Sherman Poles 

weighted.;.. 

Average % HAP; 

^^mneatresinptoiB^ ^ 

35.1 

35.5 

^^^^37^^^^ ^ 

MACT Model 

Pott Value 

(before MACT) 

(lbs/ton) fa 

117 

120 

130 

130 

132 

142 

177 

181 

201 

. Other.' 

Emission Reduction 

•••'.' • Techniques':' •.'• ' "'••^i-'';' 

Average 40.0 

a « The HAP percentages ara In terms of weight percent and they are based on the HAP content of the neat resin pus any HAP that b added to the resin 

at Ihe fadlity (fillers rat Included). 

b « Point values are expressed as pounds of HAP per ton of neat resin pus. 

3fc 
P.40 

Pigmented Production Gel Coat Draft Summary Table (09/04/98) 

Important Notes: 

(1) The pott values used h thb summary table should not be used to de—rnine actual emissions at a soecifk; facility. 

The poW value approach does not take into account BB of tha various parametere that can affad a specific fadlity's emissions. 

(2) Thb database only centalInstac—ies far which the Admin—raW has Infonnatkin. Other facilities that should be part of thb database may exist 

Weighted 

Average 

% HAP in 

Neat Gel 

Coat plus a 

MACT Model 

Point Vatua 

(before MACT) 

(Ibsfton^q 

t—nfnlon Rtductlon 

ThemuilCoca—r (90% Control) 

Trarrr-C-ftg»(85% Control) 

Ca—V_C—llzarW1%Cbntrol) 

"W-!'

,

i

:

.\"'"-'' 

Thermal OxkBzer (47.5% Controfl 

Thermal Oxidizer (47.5% Connor) 

'>Si^'*'#*v''''-v'. 

><\<S »»:-• • •!'• " ••••. ^ ' 

28 20th Century Ffeerglass. Ina (Plant «4) 

303 

303 

35.0 338 

A-1 Ffeerglass. Ina 35.0 338 

30 Aero Transportation Products 35.0 338 

Altec Industries. Ina (Midwest Oper.) 35.0 338 

Americh Corp. (Charlotte. NC) 35.0 338 

Americh Corp. (Hollywood. CA) 35.0 338 

34 Arrow Dynamics. Ina 35.0 338 

35 AMbar Plastics. Ina 35.0 338 

38 C &K Ffeerglass Plastics, ma 35.0 338 

37 Century Manufacturing Co. 35.0 338 

Cl—tana Ffeerglass. to— 35.0 338 

39 [Covarmaster. ma 

_ l 

_ 1 

42 |Fl»erdome, ma (Plant «1) 35 0 338 

Glasspee Associates. Ltd. 35.0 338 

Great Lakes Plastics Corp. 35.0 338 

HEMCOCorp. 35.0 338 

Her—pa Marble of Ohio. Ina 35.0 338 

47 Hofiday Rambler Corp.. Plans 36 and 37 35.0 338 

KKratra.ma 35.0 338 

*49 KrusoarMamationattnc. 

I»~!J_HI_HHH_I1 

53 

54 

Lawrence WWman 8, Co. ma 

Leer East Ina 

Leer Midwest 

McCtarin Plastics. Ina 

350 33B 

338 

35.0 

35.0 

35.0 

35.0 

338 

338 

338 

338 

&l 
P.41 

•« 

• ".' ' ' ' 

i 

Pigmented Production Gel Coat Draft Summary Table (09/04/98) 

55 

58 

57 

58 

59 

60 

61 

62 

63 

64 

65 

''68' •' 

67 

68 

.-,:« _ .•• 

70 

71 

72 

73 

••;74>---

'•?75 ' 

Melcher Manufacturing Co., Ina 

Molded Plastic Industries, Ina 

Murphy Body Ca 

Osborne Industries, ina 

Peterson Products 

PhO Carter System, ina 

Pickerfs Plastics, ma 

Piedmont Ffeerglass, Ina 

Plastic Development Co. 

Retterbuah Wectjon Molded Ffeerglass Corp. 

Robroy Industries, he. (BekJlno. Ml) 

Seal Reinforced Fiberglass . -"" " ' 

Shion-Telelect Ina 

Standard Glas. Ina '.'•••K;UStytoCrestPrbducts 

Tom Smith Ffeerglass. ma 

Trail Waaons. Ina 

Universal Plastics, ma 

Universal Rundta Com. (Union PoW) 

Univeraal-Rundle Corp. (New Castle) 

Xerot\ Cci, ma''&> •."••v-' 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

35.0 

350 

35.0 

35.0 

35.0 

' 35:0'-: 

:•..•••'.•:;' 3S.o:' : 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

338 

77 iNort—Fiberglass. IrxirDev-Lake) 1 35— 1 341 

= 79 iRaventndi_Sle^1r_(SleuxFalls):. iSf?*;.> ;S;Sii»H.;'i->^',¥—_^^.'-'S:|-.. .•'"••'841 . 

80 

81 

82 

83 

84 

85 

88 

87 

88 

69 

90 

91 

92 

93 

94 

95 

98 

97 

98 

99 

100 

101 

102 

103 

104 

105 

108 

107 

108 

109 

110 

111 

112 

113 

114 

'115 

116 

117 

118 

119 

120 

NordieFibergfassJneJWan^^ 

Eduer Industries 1 35> 

H & R Industries, ma >\ 35.9 

EJerMarwfecturkwWaldost*) 

Ffeerglass &Plastie Fab., Ina 

FioridsLmeofAstatulama 

Hy-Tec Ffeerglass, trie. 

Newport Laminates 

Northwest Bodies, Ina 

Oasis Industries, Ina 

Primero, Ina 

Vertex Plasties, h a 

Pearl Baths, Ina 

Tomkhs - LASCO Bathware (Anaheim) 

Tomkins - LASCO Bathware (Cordate) 

Tomkhs - LASCO Bathware (Moapa) 

Tomkhs - LASCO Bathware (Three Rivers) 

Tomkhs - LASCO Bathware (Yean) 

Arrowhead Plastic Engineering, Ina 

Sunset Plasties, ma ^^^^^^^ i 

Eter P—nbhgware (Wilson) 

Accurate Glass, h e 

Ffere Body Industries, Ina 

Monarch Ptastta ma 

National Ffeer Glass Products. Ina 

Aqua Glass Corp. (Klamath Fads) 

Diamond Fbarg—u Fabrics—rs. h a 

E-T-MEr—rprises. h a 

ED Industries, Ina (Sportsman Pickup Covers) 

Gtasst—'. ma 

38.0 

36.0 

38.0 

36.0 • 

.,,., sao 

38.0 

36.0 

38.0 

36.0 

36.0 

36.2 

36.4 

36.4 

36.4 

38.4 

36.4 

36.6 

36.6 

36.8 

37.0 

37.0 

37.0 

37.0 

-^a^jjjjvji^ -

<—kSKsia!—?"-^' 

NssSi&aeJi^Sft'^ 

^>jr.Mtf^-H." 

'•<-i^3a9^vv s 

347 

349 

350 

351 

353 

356 

356 

356 

356 

358 

356 

358 

356 

358 

356 

360 

384 

364 

364 

364 

364 

367 

367 

371 

375 

375 

373 

375 

373 

373 

373 

373 

373 

• 

• 

^ 

" V 

''"- ' ' ;: - ' " •'•'•" • ' ••^' - -••••' • 

""^jl"^ji^W-^S~^~^~f^-~^^^~vl~^^^ 

•' ••"•'••' •'• -

;

" ' ,-vfc;; ;" ' W ' ••:'•£:' 

1

 \ 

s 

4 

< 

:

- •''-;*•• • 

2 
P.42 

Pigmented Production Gel Coat Draft Summary Table (09/04/98) 

121 

122 

123 

124 

125 

126 

127 

'•••'i28>" 

129 

130 

131 

132 

133 

134 

135 

138 

137 

138 

139 

140 

141 

142 

143 

144 

145 

148 

147 

148 

149 

150 

151 

152 

153 

154 

. 155 

158 

157 

158 

159 

160 

161 

162 

163 

164 

165 

163 

167 

168 

169 

170 

171 

172 

173 

174 

175 

176 

177 

178 

179 

180 

161 

182 

183 

184 

185 

186 

Hood Mar—aduring, Ina 

Jason Industries, h a (Elkhart IN) 

Mirade Recreation Co. 

Odom Ffeerglass, h a 

P_dfe Composites Corp. 

S.W.C. Industries, h a (Swirt-Wey Div.) 

Xerxes Corp. (Seguh) 

Xerxes Corp. (Waaamsport) 

An—ch Corp. • " " 

F_*Fab.m a 

ACME ReWoreed Plastics, Ina 

Aqua Glass Corp. (AdamsviOe)" 

Blue Dotohh Fiberglass Pods 

Epoch Industries 

Appi—cliian Plastics, ma 

Associated Plastics, h a 

Fleetwood (Fori—ia - formerly Gold Shield) 

3. R. Smith. Ina 

A R E., ina (Mount Eaton) 

EaoJa Craft Ina 

Universal-Rundle Corp. (Ottumwa) 

Beaver Motor Coaches, Ina 

KBK Industries. Inc. 

-".•,••': 38.9.-. . 

^il?385Kiis^ 

«t§li363l^lS 

5^^3§3l1S^P 

*m-£>9lr-&R 

^^3l3i^ # 

®J?^_t9liS§t?IJ 

B8-agaBBB 

*SSSSS«B3?SSKSSS8i5 

37.4 

37.5 

37.S 

37.5 

37.5 

37.5 

37.5 

37.8 

37.5 

38.0 

38.0 

38.0 

38.0 

38.5 

38.5 

FberPad,ha 1 38.8 

Space Tables, fna 1 39.0 

. : • '.':. ' 

.- -....-. . - ' 

Accra Industries, h a 

Acme Ffeerglass, h a 

Affiance Equipment Co., ma 

Astoria Industries, h a 

Bradley Specialties Corp. 

Ceramic Cooling Tower Ca 

Chance Operations, Ina 

Comteeh Antenna Systems, Ina 

Continental Camper Co., h a 

Delta Ffeerglass Structures, ma 

Diamond Coach Corp. 

Elmore Truck Accessories, ma 

Ffeerglass Forms, Ina 

Ffeerglass Plus Recreational Industries, Ina 

Ffeerglass Products. Ina 

Fbergtess Spedsllies. Ina 

Ffeerglass Systems, h a 

G. W. Ffeergtess, Ina 

Gfeben Ffeerglass Reared., Ina 

Gtasgo Plastics, Ina 

GrevsonTodCo. 

LM.Pema.lna 

KeameyrWestem Power Products 

KohlerCo. 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

373 

373 

373 

373 

373 

373 

373 

•;'<:-4v--'373--''v. -•'"' 

373 

382 

384 

384 

384 

384 

385 

385 

385 

385 

393 

394 

394 

394 

404 

404 

409 

414 

415 

416 

419 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

434 

,. 

. . 

' • • ••- •*" • :;••• A - . • ,-• - ..-• : •;.;.•.••;:.•.•.• .<. • 

.. '..i-j^* • • 

'•.'•• > ' •' 

•'•' • ..,^.v•'W,^

,

 •(.' 

. ' . '•'.*• ' ••' * 

'*' • ^- c'Vv ; *:• .. -. 

. • . •.•:*;. o 

. .W' • 

• • "' : : ; '• ' ' • •..'.•.i-.l.":,A: vr;•:.-;•': - ' 

\\t\: '-' ' • , . 

•• . ,- . .-, . ,•!•.' • 

• ' i l ' '"' : 

Larson C o 1 40.0 ^ 1 434 i | 

Martoy Coofino Tower Ca 

MFG - Molded Ffeer Glass Co. (Adelanto) 

Nbosra Ffeergtess. h a 

Non Me—tic Resources, h a 

PeciV Tank. Ltd 

Prototype1 Concopts, Inc. 

RedEwaktha 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

40.0 

434 

434 

434 

434 

434 

434 

434 

HI 
P.43 

« A 4 

Pigmented Production Gel Coat Draft Summary Table (09/04/98) 

187 

188 

189 

190 

191 

192 

193 

194 

:"195 :•' 

196 

'.197-i'v 

198 

199 

200 

;

'20l" 

202 

203 

204 

205 

206 

Syntechnics 

Taco. b— 

Warminster Fiberglass C a (Jacksonville) 

Warminster Ffeerglass C a (Southampton) 

Yankee Plastic Co. 

Custom Fbreglass Manufacturing Co. 

American Reinforced Plasties 

GPICorp. ••:rFleetwood (Decatur • formerly Gdd Shield) 

Bristol Ffeeriite Industries 

GormavRuppCo. .. 

Bninnel Products of Florida, ma . 

Ffeerglass Engineering Cora 

United Panel Ina 

MFG-Molded Fiber Gtess Co. (Union City) 

Mart—cast Products, h a 

Rynone Mar—acturhg Corp. (Sayre Plant) 

40.0 

40.0 

40.0 

4tt0 

40.0 

40.4 

40.5 

41.0 

41.4 

41.4 

42.0 

45.0 

45.0 

45.0 

49.0 

50.0 

50,0 

434 

434 

434 

434 

434 

442 

444 

454 

462 

. 463 

475 

541 

541 

541 

634 

658 

658 

'•. ' ^>^c : ..•.,'... , .. • 

:::}.• ::\-y;>-: .:'•' 

...'.'?•••. ' "" '' ' .'''•• ' A ' 

Average: 36.9 

AssumedvBk^s.nodala 

a • The HAP percer—gas are h terms of weigM per—ra and lh ^ 

at the facility. 

b • Pott values are expressed as pounds of HAP per ton of neat gel coat pus. 

.42--
P.44 

Clear Production Gel Coat Draft Summary Table (09/04/98) 

Important Notaa-

(1) The point values used h thb summary table should not be used to determine actusi emissions at a spedfic fadlity. 

The pott value approach does net take into account aB of the various pararratersthd can alfed a spedftefadB/s emissions. 

(2)Thbdatabasa only contains facOHies for whidi the Administrator has[information. Other facilities that should be part of thb database may exist 

Bank Plant Nama 

Weighted 

Average 

% HAP in 

Neat Gal 

Coat plus a 

MACT Model 

Point Value 

(before MACT) 

Other 

Emission Reduction 

''•'"•''"'-Tjchnkiua •. •• 

Tri-CSy Marble, Ina 40.0 *$m^\iTMi>'-<>ft-&y 

Venetian Marble. Ina (Hetotes, TX) 40.0 

Marble Designs, tna 43.0 

I Mesa Fully Formed, h a 44.0 

Austh Countertops. h a 45.0 

Cameo Marble 45.0 541 

Cap—1 Marbto Creations. Ina 45.0 541 

10 Carolina Counters 45.0 541 

Central Mart— Products, Ina 45.0 541 

12 Foremost to—riots. Ina 45.0 541 

13 GesmarCorp. 45.0 541 

14 KJBfrioo Corp. 45.0 541 

15 Upper! Corp. 450 541 

16 SchmlH Marble Products 45.0 541 

17 Southeast Marble, Ina 45.0 541 

18 United States Marble. Ina 45.0 541 

50 

51 

52 

53 

54 

Capon Vslsy Marble, ma 

Cutuwd Marble Produc—, Ltd. 

htamational Marble, ma 

Mjrt—cast Produds. h a 

M ho w Mart— Manuf adurina ma 

55 IPWsfsCu-red Marble, ma 

50.0 

50.0 

50.0 

500 

50.0 

50.0 

658 

658 

658 

658 

658 

658 

t& 
P.45 

Clear Production Gel Coat Draft Summary Table (09/04/98) 

57 

58 

59 

60 

61 

62 

R&DMatble 

Synmar, Ina 

Venetian Marble, Ina (Richmond, VA) 

Roma Marble. Ina 

Accent Marble Co.. h a (Houston. TX) 

Parthenon Marble Products. Ina 

50.0 

50.0 

50.0 

52.5 

53.0 

60.0 

658 

658 

658 

721 

734 

926 

Average: 47.3 

• •The HAP percentages are h tennt of weight p^ ^ 

atthefaciay. 

b'• PoW values Bra expressed as pounds of HAP par ton of neat gel coat pus. 

H 
P.46 

Tooling Gel Coat Draft Summary Table (09/04/98) 

Important Notes; 

(1) The point values used h this summary table should not be used to determine actual emissions at a specific facility. 

The point value approach does nrt take into account all of the various parameters that can affed a specific facility's emissions. 

(2) Thb database only contains facilities for which the Administrator has information. Other facilities that should be part of thb database may exist 

Bank 

1 

2 

••" 3 

• 4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

Plant Name 

A R. E, Ina (Masslfon) ^V?:" •.'il-v' l...::a£. - ..-'.. ...' ., -.•:'-'2-.".: 

Eckler Industries 

Gruber Systems, Ina 

Balhcraft, h g 

S. R. Smith. Ina 

Weighted 

Average 

% HAP In 

Neat Gel 

Coat plus q 

^^42TJ^^ ^ 

45.6 

48.0 

MACT Model 

Pott Value 

(before MACT) 

(lbs/ton) b 

30 

394 

431 

431 

433 

434 

475 

475 

533 

553 

563 

574 

575 

585 

590 

592 

596 

610 

Other 

Emission Reduction 

..:'..:••;. . Thermal .ttddliar (95% Control) . . •..•<•' . 

44.2 

Footnotes: 

a a The HAP percentages are h terms of weight percent and they are based on the HAP content of the neat gel coat pus any HAP that b added to the gel coat 

at the facility. 

b » Pott values are expressed es pounds of HAP per ton of neat gel coat pus. 

4^ 
P.47 

•.•.«,~j...-.-.;.. 

WEBSITE ADDRESSES 

Coatings and Composites Rule Development — main page: 

www.epa.gov/ttn/uatw/coat/coat.html 

Reinforced Plastics Project: 

www.epa.gov/ttn/uatw/coat/rein/reinplas.html 

Boat Manufacturing Project: 

www.epa.gov/ttn/uatw/coat/boat/boat_man.html 

US EPA's Small Business Assistance Program: 

www.epa.gov/ttn/sbap 

4o? 
P.48 

T ' I 

* o • 

Meeting Announcement: Reinforced Plastics MACT Standard Development 

* What is the purpose? 

The purpose is to provide a forum for small businesses to discuss concerns, present ideas, 

and to provide feedback on the rule development and potential requirements. 

* Why should small businesses be interested? 

Small businesses should be interested because they may be impacted by the rule being 

developed for the reinforced plastics industry. This forum will provide an opportunity for 

small businesses to provide insight and suggestions that could make the impacts of the 

rule less costly. 

* What part of the reinforced plastics industry will the meeting address? 

Open molders. Open molders produce composite plastics using styrene and/or methyl 

methacrylate containing thermosetting resins by any one or more of the following 

processes: 

* gel coating 

* mechanical (eg. spray up, flow coating, pressure fed roller) or manual (eg. bucket and 

brush) application of resin 

* filament winding/centrifugal casting 

* Where is the Meeting? 

The meeting well be held at the Environmental Protection Agency's Environmental 

Research Center (ERC) Auditorium, Research Triangle Park, North Carolina. The ERC 

is the large brick building is at the corner of N.C. Highway 54 and Alexander Drive. 

Directions can be found at "www.epa.gov/ttn/uatw/coat/coord/map_dir" For persons 

wishing to participate by telephone, a telephone conference call-in number will be 

available (see "For more information contact"). 

* When is the meeting? 

The meeting will be from 9:00 am to 3:00 pm, on Friday, September 11, 1998. 

* Who will be in attendance? 

The Composites Fabricators Association (CFA) and the SPI/Composites Institute 

(SPI/CI) are currently identifying a total of 20 small businesses in the open molding 

subcategory who could represent the small business interests in the rule development. 

Other businesses representatives are welcome to attend. EPA encourages businesses preregister to assist in planning. 

•W 
* 

••' u *. . 

P.49 

* How do I pre-register? 

If you have been identified and contacted by the CFA or SPI/CI as a potential participant, 

you are already pre-registered. Otherwise you can pre-register by either calling or 

sending electronic mail (E-mail) to Madeleine Strum (see "For further information"). 

Please include the following information: your name, affiliation (company, position) 

phone number, E-mail address, mailing address, and fax number. 

* Who to contact for more information? 

Madeleine Strum, EPA, Project Lead for MACT Standard Development. 

Phone- (919)541-2383 Fax- (919)541-5689. 

E-mail: strum.madeline@epamail.epa.gov Mailing Address: MD-13, RTP, NC 27711 

For additional information in regards to the rule development status check the reinforced 

website. The website address is: http://www.epa.gov/ttn/uatvv/coat/rein/rein_plas.html 

* Anything else? 

The meeting is casual dress. 

m