p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

52) ll-C-22 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:01 AM Sheet 52 of 56 
P.2 

3*» 

, - * 

AUG 2 9 1995 

Mr. Glynn Rountree 

Director, Environmental Affairs, 

Safety & Health 

Aerospace Industries Association 

1250 Eye Street, N.W. 

Washington, D.C. 20005-3922 

Dear Mr. Rountree: 

The U.S. Environmental Protection Agency (EPA) is developing 

National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for the reinforced plastic composites industry. This rule will 

address HAP emissions that result from reinforced plastic 

composites fabrication processes (i.e., facilities that 

manufacture products using reinforced thermoset resins). The 

NESHAP is to reflect the maximum achievable control technology 

(MACT) as required by section 112(d) of the Clean Air Act of 

1990. 

The EPA is currently working with representatives of the 

plastic composites industry, local and state regulatory agencies, 

and environmental groups to investigate potential options for 

setting a standard. We invite your association to participate as 

well. Information collection requests (section 114 screening 

surveys) were sent in July 1993 to mailing lists provided by the 

Composites Fabricators Association and the Society of the 

Plastics Industry Composites Institute, and to selected 

facilities that reported styrene emissions on the 1991 TRI Form R 

reports. Most of the information collected by the Agency thus 

far has been for facilities that use polyester resins to 

manufacture products. A copy of the survey distributed in July 

of 1993 is attached. 

We realize that aerospace operations may potentially involve 

a large variety of different resins and processes and we are 

eager to work with the industry in determining and developing 

background information so that the impact on the industry will be 

minimized by selecting the best options for implementing the 

maximum achievable control of emissions. 
P.3 

i* 

Please feel free to contact me at (919) 541-2383 if you have 

any questions regarding this survey or these NESHAP standards 

generally. 

Sincerely, 

Madeleine Strum 

Coatings and Consumer Products Group 

Emission Standards Division 

Enclosure 

cc: Linda Herring, Group Leader 

Coatings and Consumer Products Group 

PREPARED BY: OAQPS:ESD:M.Strum:NCM:11th Fir.:(MD-13):541-2383 

(PES/J.Best/941-0333/8-28-95) 

(ESD Project No. 93/58) 
P.4 

W f% % UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

f ^| ^ £ Office of Air Quality Planning and Standards 

l -±\l/-jL ° Research Triangle Park, North Carolina 27711 

JUL 2 £ 199?. 

The U.S. Environmental Protection Agency (EPA) is conducting 

a "screening survey" of hazardous air pollutant (HAP) emissions 

from a category of sources which we refer to as manufacturers of 

"reinforced plastic composites." Information from this survey 

will be used in developing national emission standards for 

azardous air pollutants pursuant to Section 112 of the Clean Air 

Act (CAA), as amended in 1990. The CAA requires that the EPA 

establish emission standards for all major sources of HAP's, 

using "available data," to determine maximum achievable control 

technology. You can appreciate the importance of assuring the 

EPA has the very best information possible to implement this 

legislation. For that reason, this letter invokes the authority 

of Section 114 of the CAA to secure the needed information. 

This letter requests information on those operations at your 

facility that are associated with the manufacture of reinforced 

plastic composites. Specifically, we wish information on 

different manufacturing steps including but not limited to gel 

coating, hand lay-up, spray-up, pultrusion, filament winding, 

resin transfer molding, cultured marble casting, vacuum/pressure 

bag molding, and compression molding. The screening survey is 

designed to provide information on the variability of process 

characteristics and products within the category of sources that 

manufacture reinforced plastic composites. Its results will be 

used to design a second survey that will be sent to a number of 

facilities in this source category. 

Enclosure 1 itemizes the information requested. Three 

copies of the survey are enclosed. The first one is provided for 

your response (you may need to reproduce it for sufficient copies 

to complete your response). The other two provide guidance on 

possible types of responses. These examples are illustrative; 

they do not describe any known facility. 

f 
P.5 

The EPA's authority to gather information is provided by 

Section 114 of the CAA, as amended (42 U.S.C. 7414). If you 

believe that disclosure of any specific information that you 

submit would reveal a trade secret, you should clearly identify 

such information "confidential" as discussed in the enclosure. 

Do not label an entire response "confidential" if only certain 

portions contain trade secret information. Refer to Enclosure 2 

for the information that the EPA may later require to support 

your claim of confidentiality. Any information subsequently 

determined to constitute a trade secret will be protected under 

18 U.S.C. 1905. If no claim of confidentiality accompanies the 

information when it is received by the EPA, it may be made 

available to the public without further notice 

(40 CFR Part 2.203, September 1, 1976). Because Section 114(c) 

of the CAA exempts emission data from claims of confidentiality, 

any emission data you provide may be made public. A 

clarification of what the EPA considers to be emission data is 

contained in Enclosure 3. 

The EPA contracted Pacific Environmental Services, Inc. 

(PES) under Contract No. 68D10116 to obtain information on your 

industry. Thus, as noted in Enclosure 4, PES has been designated 

an "authorized representative" of the Agency. Therefore, PES has 

the rights discussed above and in Enclosure 2. Accordingly, PES 

will have access to all information provided to the EPA in 

response to this request. As an authorized representative of the 

Agency, PES is subject to the provisions of 42 U.S.C. 7414(c) 

respecting confidentiality of methods or processes entitled to 

protection as trade secrets. 

Enclosure 5 summarizes the EPA's and its Emission Standards 

Division's policies and procedures for handling privileged 

information and describes the commitments and procedures of the 

authorized representative for use of confidential materials. It 

is the EPA's policy that compliance by an authorized 

representative with the requirements in Enclosure 5 provides 

sufficient protection for the rights of submitters of privileged 

information. 

We request that you return the completed information request 

within 30 days of the date stamped on this letter. Your help in 

providing this information is greatly appreciated. If you have 

any questions regarding the information requested or the time 

4 
P.6 

frame for submitting the information, please contact 

Ms. Madeleine Strum, Chemicals and Petroleum Branch, at 

(919) 541-2383. 

Sincerely yours, 

' Bruce G< Jordan 

Director 

Emission Standards Division 

5 Enclosures 

cc: David P. Howekamp, Director, Air and Toxics Division, 

EPA Region IX (w/o enclosures) 

James D. Boyd, Executive Officer, California Air 

Resources Board (w/o enclosures) 

b 
.enclosure i 

Form Approved 

OMB No. 2060-0239 

Approval Expires: 03/31/95 

Public reporting burden for this collection of information is 

estimated to average 8.5 hours per response, including the time for 

reviewing instructions, searching existing data sources, gathering 

and maintaining the data needed, and completing and reviewing the 

collection of information. Send comments regarding this burden 

estimate or any other aspect of this collection of information, 

including suggestions for reducing the burden, to Chief, 

Information Policy Branch. PM-223Y, U. S. Environmental Protection 

Agency, 401 M Street, S.W., Washington, D.C. 20460, and to Office 

of Information and Regulatory Affairs, Office of Management and 

Budget, Washington, D.C. 20503. Include the OMB number in any 

correspondence. 

SCREENING INFORMATION REQUEST 

I. Instructions 

This information request is to be completed for facilities 

that manufacture reinforced plastic composites. The source 

category is defined as the manufacture of products using 

reinforced and/or filled plastic resin, including "prepreg" 

or molded products. Fill out this information request as 

completely as possible from existing information sources. 

No additional monitoring or emissions testing is required 

by your company to respond to this request. 

Attachment 1 presents the list of hazardous air pollutants 

(HAP's) listed in Section 112 of the Clean Air Act. We are 

interested in obtaining information regarding each compound 

identified as a HAP that is used in or emitted by any 

operations, including fugitive emission sources, occurring 

from the manufacture of reinforced plastic composites. 

If you have any questions regarding this request, contact 

Ms. Madeleine Strum of the EPA at (919) 541-2383 or Mr. 

Greg LaFlam of PES at (919) 941-0333. 

Return this information request and any additional 

information to: 

Emission Standards Division (MD-13) 

U. S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Attention: Bruce C. Jordan, Director 

II. General Information 

A. Name of legal owner of plant: 

P.7 

. 
P.8 

B. Name of legal operator of plant, if different from 

legal owner: 

C. Address of legal owner/operator (please specify which): 

D. Size of company: 

1. Approximate number of employees of the business 

enterprise that owns this plant, including where 

applicable the parent company and all subsidiaries, 

branches, and unrelated establishments owned by the 

parent company (answer may be given using the 

following ranges: 0-100; 101-250; 251-500; 

501-750; 751-1,000; 1,001-1,500; and >1,500): 

2. Number of plant employees attached to the 

reinforced plastic composites operation: 

E. Name of plant: 

F. Address of plant: 

G. Name of contact(s) able to answer technical questions 

about the completed survey: 

H. Title(s): 

I. Telephone number: 

1 
P.9 

III. Hazardous Air Pollutants 

Using the list of HAP's provided in Attachment l, complete 

Table 1. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Techniques 

For each HAP emission source (including storage, fugitive 

dust, transfer operations, process fugitives, stacks, and 

waste management), complete Table 2. Provide a brief 

description of any emission reduction measures in place and 

an estimate of the relative quantity of HAP emissions from 

each emission source. 

V. Miscellaneous 

Describe any factors not addressed in the above questions 

that might serve to distinguish your facility from others 

in this source category for purposes of developing a 

separate source category or subcategory and MACT standards. 

b3104-2/650031 

% 
P.10 

^ 

TABLE 1 . HAZARDOUS AIR POLLUTANTS 

Feedstocks 

Products—final and intermediate 

Byproducts (of process or control systems) 

HAP constituents 

\ 
P.11 

A 

TABLE 2. HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

Emission Source 

Storacre: 

Fuqitive Dust: 

Transfer 

Operations: 

Process 

Fuaitives: 

Emission Reduction Techniques 

Type In 

Place 

(Date) 

Future 

(Planned 

Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

• 

1° 
P.12 

TABLE 2 (Continued) 

Emission Source 

Stacks: 

Waste 

Manaaement: 

Other, specify: 

Emission Reduction Techniques 

Type In 

Place 

(Date) 

Future 

(Planned 

Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

(a) If no figures are available, give estimate as one of the 

following ranges: 

less than 0.1 

0.1 to 1 

1 to 10 

10 to 25 

25 to 100 

greater than 100 

tons 

tons 

tons 

tons 

tons 

tons 

// 
P.13 

Attachment 1 

CAS No. Chemical Name Hazardous Air Pollutants (HAPs) 

7S070 

60355 

750S8 

98862 

53963 

107028 

79061 

79107 

107131 

107051 

92671 

62533 

90040 

1332214 

71432 

92875 

98077 

100447 

92524 

117817 

542881 

7S2S2 

106990 

156627 

105602 

133062 

63252 

75150 

56235 

463581 

120809 

133904 

57749 

7782505 

79118 

532274 

108907 

510156 

67663 

107302 

126998 

1319773 

95487 

108394 

106445 

98828 

94757 

3547044 

334883 

132649 

96128 

84742 

106467 

91941 

111444 

542756 

62737 

111422 

121697 

64675 

119904 

60117 

119937 

79447 

68122 

57147 

131113 

77781 

534521 

51285 

121142 

123911 

122667 

106898 

106887 

140885 

100414 

51796 

75003 

106934 

107062 

107211 

151564 

75218 

96457 

7S343 

50000 

76448 

118741 

87683 

77474 

67721 

822060 

680319 

110543 

302012 

7647010 

7664393 

7783064 

123319 

78591 

S8B99 

108316 

67561 

72435 

74839 

Acetaldehyde 

Acetamide 

Acatonitrile 

Acetophanone 

2-Acetylaminofluorene 

Acrolein 

Acrylajgide 

Acryli c ad d 

Acrylonitril e 

Ally l chloride 

4-Aminobiphenyl 

Aniline 

o-Aniaidine 

Asbeetos 

Benzene (including benzene from gasoline) 

Benzidine 

Benzotrichlorida 

Benzyl chloride 

Biphenyl 

Bia(2-ethylbexyl)phthalata (DHCP) 

Bla(chloromethyl)ether 

Biumofora 

1,3-Butadlane 

Calcium cyanamlde 

Caprolactam 

Captan 

carbaryl 

Cartoon disulfide 

Carbon tetrachloride 

carbonyl sulfide 

Catechol 

CBloramban 

Chlordane 

Chlorine 

Chloroacatie acid 

2-Chloroacatophanone 

Chlorobenzene 

chlorobaniilate 

Chloroform 

Chloromethyl methyl ether 

chloroprena 

Creaola/Creeylic acid (iaomera and mixture) 

o-Cresol 

m-Cresol 

p-Cresol 

cumene 

2,4-D, aalta and esters 

DDE 

•iazonethane 

Dlbenzofurane 

1,2 -Dibromo-1 -cbloropropane 

Dibutylphthalat e 

1,4-Dichlorobonz.no(p) 

3,3-Dlchlorobenzidena 

Olchloroathyl athar (Bls(2-cbloroethyl)ether ) 

1,3-Dichloropropena 

Dlchlorvoa 

Dlethanolamina 

H,H-Dlethyl anilin e (H.N-Dihethylaniline) 

Diethy l sulcat a 

3,3-Diaethoxybenzldlne 

Dimethyl amlnoazobanzana 

3,3-Dlaethy l benzidine 

Dimethyl carbamoyl chlorid e 

Dimethyl formamlda 

1,1-Dlmathyl hydrazine 

Dimethyl phthalate 

Dimethyl aultata 

4,6-Dinltro-o-cresol , and salts 

2,4-Dlnitropbeno l 

2,4-Dlnitrotoluana 

1,4-Dioxane (l,4-01ethyleneoxlde ) 

1,2-Diphenylhydrazin. 

Epichlorohydrin (l-Oiloro-2,3-apoxypropane) 

1,2-Epoxybutana 

Ethyl acrylat a 

Ethyl benzene 

Ethyl carbamate (Urethane) 

Ethyl chloride (Chloroethane) 

Ethylene dlbroaide (Dlhramoethane) 

Ethylene dlchlorlda (1,2-Dlchloroethane) 

Ethylene glyco l 

Ethylene lmlae (Aziridine ) 

Ethylene oxide 

Ethylene thiourea 

Ethylidene dichloride (1,1-Dichloroethane) 

Formaldehyde 

Beptachlor 

Hexachlorobenzene 

Hexachlorobutadlene 

Baxarh 1 orocyclopentadlene 

Hexni-h loroethana 

Hexaaathylene-1,6-dllaocyanat e 

Bexamethylphosphoramide 

Hexane 

Hydrazine 

Hydrochloric acid 

Hydrogen fluoride (Hydrofluoric acid) 

Hydrogen sulfid e 

Hydroquinone 

Isophorone 

Lindane (al l iaomera) 

Maleic anhydride 

Methanol 

Methoxychlor 

Methyl bromide (Bromomathane) 

74873 

71556 

78933 

60344 

74884 

108101 

624839 

80626 

1634044 

101144 

75092 

101688 

101779 

91203 

98953 

92933 

100027 

79469 

684935 

62759 

59892 

563B2 

82688 

87865 

108952 

106503 

75445 

7803512 

7723140 

85449 

1336363 

1120714 

57578 

123386 

114261 

78875 

75569 

7S55B 

91225 

106S14 

10042S 

96093 

1746016 

79345 

127184 

75S04S0 

108883 

95807 

SB4849 

9S534 

800US2 

120821 

7900S 

79016 

95954 

88062 

121448 

1582098 

540841 

108054 

593602 

75014 

75354 

1330207 

95476 

108383 

106423 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

o 

0 

0 

o 

0 

Nethyl chloride (Chloromethane) 

Methyl chloroform (1,1,1-Trichlorootbane) 

Methyl ethyl ketone (2-Butanone) 

Methyl hydrazine 

Methyl iodide (lodomethana) 

Methyl isobutyl ketone (Haxone) 

Methyl ieocyanate 

Methyl methacrylate 

Methyl tart butyl ether 

4,4-Mettaylana bls(2-chloroaniline) 

Methylene chloride (Dichloromethane) 

Methylene dlpbenyl dllaocyanata (MDl) 

4,4-Methylanedlanlllne 

Hiphthalene 

Nitrobenzene 

4-Hltroblphenyl 

4-Hltrophsnol 

2-Hltropropana 

N-Hltroao-H-aetbyluraa 

M-Hitrosodiaatbylaaine 

H-Hltrosoaorphollna 

Parathion 

Fentachloronitrobenzene (Quintobenzene) 

Pentachlorophenol 

Phenol 

p-Phenylenediamlna 

Phosgene 

Phoaphine 

Phosphorus 

Fhthalic anhydride 

Polychlorinated biphenyls (Aroclors) 

1,3-Propane sultona 

bata-Propiolaotone 

Proplonaldehyde 

Propoxur (Baygon) 

Propylene dichloride (1,2-Dichloropropane) 

Propylene oxide 

1,2-Propylenimine (2-Mathy1 aziridine) 

Qulnolina 

Qulnona 

Styrene 

Styrene oxide 

2,3,7,8-Tetrachlorodibenzo-p-dioxln 

1,1,2,2-TetrachloroetBane 

Tetrachloroethylene (Perchloroethylene) 

Titanium tetrachloride 

Toluene 

2,4-Toluene diamine 

2,4-Toluene dllaocyanata 

o-Toluldlna 

Toxaphene (chlorinated oamphene) 

1,2,4-Tricblorobenzena 

1,1,2-Trichloroethane 

Trichloroethylene 

h. 

2,4,S-Trlchlorophenol 

2,4,6-Trlchlorophenol 

Triethylamlna 

Trifluralin 

2,2,4-*rl»ethylpant«ne 

vinyl acetate 

Vinyl bromide 

Vinyl chloride 

Vinylidene chloride (1,1-Dlchlozoethylena) 

Xylenes (isomers and mixture) 

o-Xylenea 

a-Xylenes 

P-Xylenea 

Antimony Coapounda 

Arsenic Compounds (inorganic Including arsine) 

Beryllium Compounds 

Cadmium Compounds 

Chromium Compounds 

Cobalt Compounds 

Coke oven Emissions 

Cyanide Coapounda •! 

Glycol ethera *2 

Uad Coapounda 

Manganeae Compounds 

Mercury Coapounda 

Fina mineral fibers -. 

Bickel Compounds 

Folycyllc organic Matter »4 

Radionuclides (Including radon) -S 

Selenium Coapounda 

•compass., 5 «£\ii£sl2B*"2 w t^^, »• »»« 

antimony, JTMij=. etc > a. part .< that ch^cS ^ iSSSu^ : 

•^-sHSa 5^ ^-=pBW? era,-""TM' "~l 

diethyl. ^ JSJSU^RtfSSoSSRS. 85?' 

n • 1, 2, or 3 

" - alkyl or ary l gxoupe 

»i»r_i B'_? '

 o r

 ?TM»P" "hieh, when removed, yield 

^l-SL^f " "1,

th

J. ? • •«"'=turei H-(OCB2(i)X-oS; 

•3 Tnri!S. . "* «<=!«««•<> from the glyco l category. 

rino Ln il.lt v. °""«1«; ^"Pounds with sor e than on. benz.n. ring, and vhich hav. . boilin g point greate r than or equal t o 100-

docay!* * tyP * "' "° "

 Mhlc h

 "P<">t«"eou.iy undergoes radloaotlva 
P.M 

SURVEYS 2 AND 3 (EXAMPLES) 

i'b 
P.15 

s 

^PfcAy Lflyi/p 

III. Hazardous Air Pollutants 

Using the list of HAP's provided in Attachment 1, complete 

Table 1. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Techn 

For each HAP emission source (inc] 

dust, transfer operations, process 

waste management), complete Table 

description of any emission reduction 

an estimate of the relative quantity of 

each emission source. 

Miscellaneous 

Describe any factors not« 

that might serve to distil 

in this source categoi 

separate source catego} 

We are subject to 

District (CA) Rule 

Number of Gel 

Bo 

fugitive 

stacks, and 

a brief 

in place and 

emissions from 

ed in the above questions 

your facility from others 

pses of developing a 

egory and MACT standards. 

ir Quality Management 

Number of Spra Primary laminate 10 

Secondary laminate 3 

Spraying ah open area. 10' X 10'. 

Resin Make Unsaturated polyester resin & 

filler 

StyrA - 35% by weiaht of resin as supplied. 

/ / Sy = 20% as applied. 

ys^/on: 12'deep x 10'wide x 10'high 

Booth mation Rate: 14.500 acfm per booth 

Binks Air Guns. HVLP - Gel Coat. Model # G-755 

- Resin & Chopped Fiber. Model # R-715 

Cure 1 hour at ambient temperature 

Clean-up materials Acetone-Free, manufactured by 

XYZ Corporation. Anytown. IL. 100 crallonsfday 

Typical height of exhaust point (from ground): 40 feet 

Approximate distance of plant exhaust to nearest 

residence: If4 mile. 

4-
P.16 

Ab*cU W f h + 4* 

^P^A Y LAY fp' 

pIV. Source Reduction Techniques, (with Table 2) 

1. Conservation Vents: In place since plant start-up. 

2. Vacuum Filters: Portable suction vacuum units for dust 

control during finishing. Filter type. 

HEPA. manufactured*by The Filter 

Company. Tiptown. Mfkxas. 

3. LidsfCovered Containers: We keepftfbn 

not usihg^t 

.covered when 

4. Spraying: 1. Spray Gun Training Prog. nitiated 

November 1989/^proved to^reduce 

emissions by i^t^roTn 23ff to 184 tpy. . 

2. Planned i 

incinera 

catalytic 

n spray booths will meet 

EPA'S d& of a permanent total 

enclosure et 100% capture of 

pollui ^^^alytic Incinerator planned 

from the 10 primary spray 

iciency =97% 

$ 1 Million 

ing Cost - $ 40.000 

5. Water Based nmiT.:!TT, Fant went Acetone Free in 1992 

W^mfanufacturer: XYZ Corporation. 

Anytown. IL. 

6. Enclosed tf\xers:\jtnclosed (closed top) mixers for 

fifes inf filler mixing. Allows mixing 

vacuum. Styrene-laden air stream 

is vented to a condenser to recover 

styrene monomer. 

7. foticuvfed Scr\hp Resin: Collected and kept in closed 

containers. 55 gallon drums sent 

off-site to disposal facilities. 

8. Housekeeping: Spills are cleaned up immediately. 

9. Enclosed Spray Guns: Use of enclosed cleaner to reduce 

Methylene Chloride emissions. 

10. Production Reiects: Parts stored temporarily on site. 

then taken to off-site landfill. 

ft 
P.17 

^?KAV LAV/VP 

A 

TABLE 1. HAZARDOUS AIR POLLUTANTS 

Process: Spray-Up 

Feedstocks 

Mold Release 

Gel Coat 

50 ton/yr 

1000 tpy/ 

Unsaturated Polyester Resin 

(Including Promoters) 

2000 tpy 

HAP constituents 

None 

Styrene (40% by 

'p weight) as 

ied by ABC 

Co. 

yrene (35% by 

weight) as 

supplied by DEF 

Resins Co. 

-Dimethyl 

phthalate (DMT) 

-Cobalt compounds 

Styrene (used as thinner 

Initiator /Catalyst (M, 

Chopped Fiberglass 

Filler (Calcium ^aJrfeaoate; 

Color Paste 

Products—final Smd in 

Bath Tub 

Tub/Sh 

Shower 

Byproducts (of process or control systems) 

Fugitive Dust unknown tpy 

(machining, drilling) 

Unreacted Scrap Resin 1% of raw material 

Resin Overspray 10% gf raw material 

Cleanup Material 2000 gal/yr 

Unreacted Styrene 

Unreacted Styrene 

Unreacted Styrene 

Styrene, DMT, 

Cobalt compounds 

Methylene 

chloride (100%) 

[fc 
P.18 

^PEAY LAY-UP. 

TABLE 2. HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

Emission Source 

(Spray-Up) 

EXAMPLE 

Emission Reduction Techniques 

In 

Place 

(Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

Storage: 

Tanks (2) 

40,000 gallons 

each 

Conservation 

Vents 

'less than 0.1 

Fugitive Dust: 

Finishing 

Grinding 

Polishing 

Vacuum 

Filters 

less than 0.1 

(total dust) 

Transfer 

Operations: 

Pouring Resin 

(open system) 

Connecting Jfump~ 

Lines 

1 * 

less than 0.1 

Spraying 

Curing 

46 * 

. . . . 10 * 

% ^£E. ^ALCVLA-nori ^ME&T , p*4 t 7 . 

6U0SEJ> Ui^ S I'D ^PJ2AV &Vti$. 

n 
P.19 

^PPAY LAWP 

TABLE 2 (Continued) 

Emission Source 

{Spray-Up) 

EXAMPLE 

Emission Reduction Techniques 

Type In 

Place 

(Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

Stacks: 

Spraying Spray Gun 

Training 

Program 

Catalytic 

Incinerator 

w/100% tote 

enclosure 

138 * 

(before 

control) 

Waste 

Management: 

Clean Up: 

-General 

-Handwiping 

•Spray Gun 

-Mix Tank /" 

(Methyl* 

1/92 

Cleaning^ 

-Scrap M&smj 

11 •* 

less than 0.1 

less than 0.1 

less than 0.1 

1 * 

Other. 

Mixing 'Enclosed 

Dome Mixing 

1/94 1 * 

(a) If no figures are available, give estimate as one of the 

following ranges: 

less than 0.1 

0.1 to 1 

1 to 10 

10 to 25 

25 to 100 

greater than 100 

tons 

tons 

tons 

tons 

tons 

tons 

l* 
P.20 

(X) 

£?JZAy LA Y V 9 

I . SPEAY L/WVP . CWISS(OM J 6UVUATI5S J tx/i'wpiE BASE D 

<?M Ap- 4 2 £M4S/O N ^-rog s ( l°\%%) P^!2 POLVESTTB . 

^ES/rJ PLAS-H^ S F f. %V.\c fir-no M . 

/u^i'wfl no r Vapor — <^u ppr e ssed • C4 nV *• n~i~> o »----Q A-e s 1 rvj 

- ^£ L ^A T Ewiss/^M FACT* p. = 3 

— 4>P|SAy LAYI/P EM)5^/ON FACTP^ = 

a . Get. £*tT : (\ooo +fv\ ( 0.4. 

b. ^?EAY LAWP : ^200 0 

6. TOTAL B t*.*$tw <, r 

?^ = \ 7.0 4-0^5 /tV1 

y +1 7 ^y = |17 -U^/ 

7 4"**s Jfy\ oo p. 0 

<r 

T 

- ^-.-KPAflT-e OF TH-e a^BsW u <?P TME'-S^ EM i«sior/ s .is. ' 

- 0.S % E^iTTEkA Fie\>y IA\^ I M6» C«-f+er recovery) - ) Tf"/ 

. 13.S'/. ., £^wkni2s7 ^yi ^ = |<24 " 

- ' 5 % '/ ^ \\ " CUR I NO =: \0 

i ' 

UowfcXE* SrstfJ W IS DOME I N TWO A*EA S (> e 154): 

2 5 / w

^ OK« A*E A (xo'*\o') ***ce*> FU 6 ITIV6S ; 4. 6 

7 £ % IM SOOTHS (WIT H ^TTU^S ) ; 138 

^LCf L ATio NJ'-

lb A _ A - *? 7 l4o lk/< (fll.07 

(2Z , I AO \\ ' \ / ' ^ n-

r 

Z l W . lb 

- 11. o 7 Jr£*. 
y 

(""ULTRuSlorJ 

P.21 

III. Hazardous Air Pollutants 

Using the list of HAP's provided in Attachment 1, complete 

Table 1. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Technj 

For each HAP emission source (incl 

dust, transfer operations, process" 

waste management), complete Table 2. 

description of any emission reduction 

an estimate of the relative q 

each emission source. 

V. Miscellaneous 

Describe any factors not 

that might serve to di§£ir? 

in this source catego 

separate source categ 

Corrosion resista 

e, fugitive 

stacks, and 

a brief 

in place and 

emissions from 

ed in the above questions 

your facility from others 

,ioses of developing a 

egory and MACT standards. 

s for our product does not 

allow us to substi ative monomers. We are 

also looking x 

Chemical Compa 

yapor suppressing resin that ABX 

tly developed. 

10 pultrusion ma 

3 feet widi 

long by 4JB,lllfell 

20 feet long. 4 feet high, and 

th dimensions are 2 feet wide by 5 feet 

t f)oint^eight (from ground to point of release) : 50' 

ftance of plant exhaust to nearest 

mile. Each pultrusion machine has a maximum 

4" X 8" and a speed of 30 feet per hour, and 

150 pounds of composite product per hour. We are 

performing emissions testing at our plant for internal 

environmental goals: however, we used AP-42 factors for 

this survey. • 

b3104-2/650031 

ZO 
PuL T R U $ I C-KJ 

A Wo^cU \*\e n4- -h» p- 3 

IV. Source Reduction Techniques, (with Table 2) 

1. Conservation Vents: In place since plant start-up. 

2. Vacuum Filters: Portable suction vacuum units for dust 

, control during finjf&hing. Also at 

cut-off point. 

3. LDAR: We check for leaks once a 

4. Covered Resin Bath: stom-designed 

clear plastic hood over Hood vented 

through stack to atmos 

Investigating altern Acetone & Methylene 

Chloride with a Testing is on-going. 

Call us at (444r<B3S^ for details. 

Enclosed Mixk s loss of styrene. 

Housekeeping: \jfeean up resin spills, closed containers 

rags, line clean-up. • 

Sjfflap/Leftofer Resin: Kept in closed containers. 

55 gallon drums sent off-site 

to a disposal facility. 

Production Reiects: Parts stored temporarily on site. 

then taken to off-site landfill. 

nA 
s 

^Vm-T^-V ^m l O h) 

TABLE 1. HAZARDOUS AIR POLLUTANTS 

Process: Pultrusion HAP constituents 

Feedstocks 

Styrene (used as thinner) 250 ton/yr^ Styrene 

Unsaturated Polyester Resin 5,000 

(Including Promoters) 

Initiator/Catalyst (MEKP) 

ne (50% by 

t) 

ethyl 

thalate 

obalt compounds 

Filler 

Calcium Carbonate 

Aluminum Trihydrate 

Fiberglass Mat 

Fiberglass Strand Rov, 

Products—final and inter: 

Ladder Rails 

I-Beam Structufckls 

/ • • *•> ' .. ^ •••• / 

' - •*- - - -•>,• ••>•- • y 

8,000 tpy 

Unreacted, 

residual styrene 

Unreacted, 

residual styrene 

roceas or control systems) 

Unknown 

quantity 

Cleanup Material 2,860 gal/yr 

•Styrene 

-Dimethyl 

phthalate 

-Cobalt compounds 

Methylene 

chloride (100%) 

It 
P.24 

?VL T R ^ 5 I O fJ 

TABLE 2 . HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

Emission Source 

Pultrusion 

Emission Reduction Techniques Tota l HAP 

Emission 

Estimate , 

Tons/Year 

(a) 

Storage : 

Tanks (4) 

25,000 gallons 

Conservation 

Vents 

less than 0.1 

Fugitive Dust: 

Part Cut-off Vacuum 

Filter 

less than 0.1 

(total dust) 

Transfer 

Operations: 

Pumping to Dip 

Bath 

less than 0.1 

Process 

Fugitives: 

Curing 

Die 

7 * 

# ^ BB- aCAL-CVLfij-totJ ^EET , f*"^8, "7" 

v> 
TABLE 2 (Continued) 

P.25 

P u LT£ I/^IOI J 

If no flquxfes are avai 

f ollowingNsanges: 

less than 0.1 

0.1 to 1 

1 to 10 

10 to 25 

25 to 100 

greater than 100 

lable, < 

tons 

tons 

tons 

tons 

tons 

tons 

a f 
P.26 

I 

P V L TT? W £ ) o h) 

CALCULATION SIA^ET 

L.CUL- AT) 0 rsi b X A- iv\ P L £ 

BA^^D PN) /\?-4-X E^l^/ 0 l J FA^TD R fl*l& A 

E /"I S S / e>iJ fpitrw R (£.F?) I $ 

E'S-n,n*Tgb SryRtN/c EM>SS/*ISJS ; 

(too* +pv^ #.«?<> ^ ?^ (as<p> 

lU//vJ6 TWe TOTAL £/w>5*/» 

E^TlMATTs HC W Tn-ese EMI S 

#x i »J ^ 

'/ZgS/fJ BAn J 

* Vt\n0r A- 4-\f>t>t-tS'>'<mij) 

137, 5 -j?h $ ^TWV^a i 

37. 5 TPjJs/yp , w e WIL L MOtJ 

pi-sreiB^TED AT ou>g. PLANT 

0-n*rp. S ca ^ > 

/.4 

ZZ 

7 

7 

-/-*>/ 

H>Y 

+fy 

-hv 

131-4 tyy 

XL. /VleT^v/e/ie^wM®r/cl f Ca I Cut*iJ <rv\ '• 

jk,S£° yJ/m) ( )|.07 i^ \ r 31,6* 0 I t 

y* 

v > l '^00 0 |jj ^ /fr. s -hr»S/Cyt 

s 
P.27 

V 

-"*'*" "" Enclosure £ 

EPA»* Inferaetlon Gathering Authority 

Under Section 114 of th» Clean A1r Ac * 

Undar Section 114 of th* Act (42 U.S.C. 7414}, Congress has given tht 

If* S. EnviI omenta\ Protection Agency broad authority to secure) Inforaation 

. . needo*"(a> for th* purpose (1) of developing- or assisting lit tho development 

of any Implementation plan under Section U O or 111(d)» any standard of 

performance under Section 111* or any eaission standard under .Section 112 

(11) of determining whether any person Is In violation of any sudt standard or 

any requirement of such a plan, dr (111) carrying out any provision of this 

Act." Among other things. Section 114 authorizes EPA to mate Inspections, 

conduct tests, examine records, and require owner* or operators- of emission 

sources to submit Information reasonably required for tht purpose of 

developing such standards. In addition, the EPA Office of General Counsel has 

Interpreted Section 114 to Include authority to photograph or require 

submission of photographs of pertinent equipment, emissions, or both. 

Under Section 114, EPA Is empowered to obtain Information described by 

V that section even If you consider 1t to be confidential. You may, however, 

request that EPA treat such Information as confidential. Information obtained 

under Section 114 and covered by such a request will ordinarily be released to 

the public only 1f EPA determines that the Information is not entitled to 

confidential- treatment.* Procedures to be used for making confidentiality 

determinations, substantive criteria to be used 1n such determinations, and 

special rules governing Information obtained under Section 114 are set forth 

1n 40 CFlfcPart 2 published In the Federal Register on September 1, 1976 

(40 FR 36902). 

•Section 114 requires public availability of all emission data and authorizes 

disclosure of confidential Information In certain circumstances. See 

40 FR 36902 - 36912 (September 1, 1976). 

T.& 
P.28 

^^^T«« k Lrwi* * <» r~.1v*. «r It 1* drt«*nrt that * 

^S^tT^r*.^ . or £M drtn . to <*•* » «**» » busln... 

«.».• BMeautlons taken 1n connection therewith? 

"'T^nen t confidentiality detection*. ^^SZ^ t 

Federal agencies, and a copy of any such determinations or reference to it.. 

If available: and disclosure of thn Information would 

4. Whether your company asserts that disclosure or 

w KM W t« result 1n substantial harmful effect! on the business 

^ t Cp-T t n ^ i# » . what tho,. taMI effect.-I d «-• »» * * 

STS^ST - lubstantl.l. and an *** » « th. c»s.« relation^ 

betwen disclosure and such hanrfu.l effects. 

-vl 
P.29 

7042 Federal Register / Vol. 56. No. 35 / Thursday, February 21. 1991 / Notices 

Dated: February 14.1B91. 

Paul Lapsloy, 

Director. Regulatory Management Division. 

(FR Dot 91-4113 Filed 2-20-01; 6:45 Bm] 

BILUNO COOE 8S60-S0-U 

[AD-fRL-3906-3] 

Disclosure of Emission Oata Claimed 

as Confidential Under Sections 110 

and 114(c) of ths Ctean Mr Act 

AGENCY: Environmental Protection 

Agency (EPA). 

ACTION: Notice of policy on public 

release of certain emission data 

submitted under sections 110 and 114(c) 

of the Clean Air Act (CAA). 

SUMMARY: Section 114(c) of the CAA 

excludes emission data from the general 

definition of trade secret information. 

Certain classes of data submitted to the 

EPA under sections 110 and 114(a) of the 

CAA are emission data, and. as such, 

connnot be withheld from disclosure as 

confidential pursuant to section 1905 of 

title IS of the United States Code. This 

notice clarifies EPA's current policy, and 

solicits comment regarding that policy 

and categories of data which it 

considers excluded from a trade secret 

definition. 

DATES Written comments pertaining to 

this notice are requested by April 22. 

1991. 

ADDRESSES: Submit comments to: Nancy 

D. Riley, U.S. Environmental Protection 

Agency. Emission Standards Division. 

Pollutant Assessment Branch (MD-13). 

Research Triangle Park. NC 27711. 

FOR FURTHER INFORMATION CONTACT: 

Timothy Mohin (telephone: (919) 541-

5349 commercial/FTS 629-5349) or 

Karen Blanchard (telephone: (919) 541-

5503 commercial/FTS 029-5503). 

PoUutant Assessment Branch (MD-13). 

Emission Standards Division: or Thomas 

Rosendahl (telephone: (919) 541-5404 

commercial/FTS 629-5404). National Air 

Data Branch (MD-14). Technical 

Support Division; U.S. Environmental 

Protection Agency, Research Triangle 

Park. North Carolina 27711. 

SUPPLEMENTARY INFORMATION: The EPA 

routinely uses, the authority of sections 

110 and 114(a) of the CAA to gather 

technical information from Industries 

involved In operations that lead to 

emission of pollutants to the ambient 

air. This information has been used, 

among other things, to better 

characterize emitting facilities and to 

evaluate the need for and impacts of 

poiential regulation. 

Information requests under sections 

110 and 114(a) of the CAA typically 

include questions on uncontrolled and 

controlled emission rates and emission 

parameters of the pollutant or group of 

poUutants of concern. The respondents 

sometimes claim that its response 

constitutes trade secret information, and 

thus, should be treated as confidential. 

Claims of confidentiality may be made 

under section 114(c) of the CAA. which 

states: upon a showing 

satisfactory to the Administrator by any 

person that records, reports, or 

information, or a particular part thereof, 

(other than emission data) to which the 

Administrator has access under this 

section if made public, would divulge 

methods or processes entitled to 

protection as trade secrets of such 

person, the Administrator shall consider 

such ' * * confidential in accordance 

with the purposes of Bection 1905 of title 

18 of the United States Code* * Vl f 

the Administrator so determines, the 

information is not disclosable to the 

public. 

However, section 114(c) of the CAA 

provides that information claimed to be 

a trade secret but which constitutes 

emission data may not be withheld as 

confidential Although typically the EPA 

evaluates whether infonnation 

constitutes emission data on a case-bycase basis, it believes that some kinds of 

data will always constitute emission 

data within the meaning of section 

114(c). The purpose of this notice is to 

describe, without attempting to be 

comprehensive, that information which 

the EPA generally considers to be 

emission data, and which cannot qualify 

as confidential under either section 

114(c) or section 110 (as set forth in 40 

CFR 51.321,51.322 and 51.323) of the 

CAA. The EPA is issuing this notice to 

clarify its policy and procedures, to 

facilitate the use of these data In 

automated data systems and computerbased simulation models, and to 

expedite processing of claims for 

confidentiality or requests for 

disclosure. 

The EPA presently determines that 

data submitted to it as emission data 

does not qualify as confidential if it 

meets the foUowing defir. tion under 40 

CFR 2.301(a)(2)(i): 

a. Definitions. Forthe purpose of this 

section: (1) Act means the Clean Air 

Act, aa amended, 42 U.S.C. 7401 et seq. 

(2)(i) Emission data means, with 

reference to any source bf emission of 

any substance into the air— 

(A) Information necessary to 

determine the identity, amount 

frequency, concentration, or other 

characteristics (to the extent related to 

air quality) of any emission which has 

been emitted by the sttuce (or of any 

poUutant resulting from any emission by 

the source), or any combination of the 

foregoing: 

(B) Information necessary to 

determine the identity, amount, 

frequency, concentration, or other 

characteristics (to the extent related to 

air quality) of the emission which, under 

an applicable standard or umitation, the 

source was authorixed to emit 

(including, to the extent necessary for 

such purposes, a description of the 

manner or rate of operation of the 

Bource), or any combination of the 

foregoing; 

(C) A general description of the 

location and/or nature of the source to 

the extent necessary to Identify the 

source and to distinguish it from other 

sources (including, to the extent 

necessaiy for such purposes, a 

description of the device, installation, or 

operation constituting the source). 

The table below lists tha specific data 

fields which the EPA presently 

considers to constitute emission data 

and provides a brief description of what 

each data Geld describes. Tha 

descriptions are intended to provide 

general information. This list is not 

exhaustive and, therefore, other data 

might be found, in a proper case, to 

constitute emission data. 

Emission Data Field. 

Facility Identification: The foUowing data 

fields are needed to estabUsh the identity and 

location of emission source*, this shall also 

Include a description or an identifier of the 

device, installation, or operation constituting 

the source. These data are uaed to locate 

source, for dispersion evaluation and 

exposure modeling. 

Plant Name and related point identifiers 

Addrew 

Oty 

County 

AQCR (Air Quality Control Region) 

MSA. PMSA..CMSA (Metropolitan Statistical 

Areas) 

State 

Zip Code 

Ownership and point of contact Information 

Locational Identifiers: 

Latitute & Longitude, or UTM Grid 

Coordinates 

SIC (Standard Industriai Classification) 

Emission point, device or oparatlon 

description, information 

SCC (Source Classification Code.) 

Emissions Parameters: The foUowing data 

fields are needed to eatablish the 

characteristics of the emissions. This 

Infonnation ls needed for the analyses of 

dispersion and potential control equipment 

Emission type 

(e.g.. nature of emluiona such as CCs), 

particulate or a specific toxic compound. 

and origin of emluiona such aa procea. 

vents, storage tanks or equipment leaks) 

Emission rate 

vv 
P.30. 

Federal Register / VoL 56. No. 35 / Thursday, February 21. 1991 / Notices 7043 

(e.g., the amount released to the 

atmosphere over time such as kg/yr or 

!bs/hr) 

Release height 

(e.g., height above ground level where the 

poUutant is emitted to the atmosphere) 

Description of terrain end surrounding 

structures 

(e.g, the size of the area associated with 

adjacent structures in square meters and 

terrain descriptions such as 

mountainous, urban, or rural) 

Stack or vent diameter at point of emissions 

(e.g., the Inside diameter of vent at the 

point of emission to the atmosphere in 

meters) 

Release velocity 

(e.g., velodty of release in m/sec) 

P.elease temperature 

(e.g., temperature of release at point of 

release in degrees Kelvin) 

Frequency of release 

(e.g., how often a release occurs in events 

per year) 

Duration of release 

(e.g., the time associated with a release to 

the atmosphere) 

Concentration 

(e.g., the amount of an emission stream 

constituent relative to other stream 

constituents expressed as parte per 

million (ppm). volume percent, or weight 

percent) 

Density of the emissions stream or average 

molecular weight 

(e.g., density expressed as fraction or 

multiple of the density of ain molecular 

weight in g/g-mole) 

BoUer or process design capacity 

(e.g.. the gross heating value of fuel input to 

a boiler at its maximum design rate) 

Emission estimation method 

(e.g., the method by which an emission 

estimate has been calculated such as 

material balance, source test use of AP42 emission factors, etc.) 

Percent space heat 

(eg., the percent of fuel used for space 

heating) 

I lourly maximum design rate: 

(e.g., the greatest operating rate that would 

be expected for a source in a 1-hour 

period) 

The EPA has determined that these 

data are emission data and releasable 

upon request. This determination 

applies to data currently held by EPA as 

well as to information submitted to EPA 

in the future. Future requests for 

infonnation under sections 110 and 114 

of the CAA will indicate that these 

emission data will not be held 

confidential. This detennination applies 

only to the data listed in the table. 

Determinations will continue to be made 

on a case-by-case basis for data not 

specified in this generic determination. 

After consideration of comments on 

this policy, a revioed policy/ 

detennination may be published. 

Dated: February 6.1991. 

Michael Shapiro, 

Acting Assistant Administrator for Air and 

Radiation. 

[FR Doc 91-4114 Filed 2-20-S1: 8:45 am) 

SIUJNO CODE S5SO-M-U 

[OPP-2O0OO0A; FRt.-3S79-4] 

Request for Proposals; Research and 

Development on Antimicrobial Test 

Methodology and Statistical Support 

on Experimental Design and Data 

Analysis; Extension of Proposal 

Deadline 

AGENCY: Environmental Protection 

Agency (EPA). 

ACTION: Extension of proposal deadline. 

SUMMARY: This notice announces the 

extension of deadline for a Request for 

Proposal that published in the Federal 

Register of December 6.1990. The 

Request for Proposal was published to 

solicit proposals which will result in the 

development of a reproducible, reliable, 

and statistically valid sporicidal test 

method used to evaluate the efficacy of 

antimicrobial products bearing sterilizer 

or sporicidal claims. In addition, 

proposals for statistical support to 

independently evaluate the 

experimental designs of projects and to 

analyze results from on-going test 

methodology research were also 

solicited. 

DATES: The new deadline for proposal 

submission to the Agency is February 

28.1991. 

ADDRESSES: The original and eight 

copies must be sent to: Grants 

Operations Branch (PM-218F), 

Environmental Protection Agency, 401M 

St., SW., Washington. DC 20460. One 

copy of the original-must be sent to: 

Susan Parker, Registration Division 

(H750SC), Environmental Protection 

Agency, 401M St.. SW.. 204B0. 

Application Kits may be obtained from: 

Grants Operationa Branch (PM-218F), 

Environmental Protection Agency, 401M 

St, SW.. Washington. DC 20460, or call: 

(202) 382-5266. 

FOR FURTHER INFORMATION CONTACT: 

Susan Parker, Registration Division 

(H750SC), Environmental Protection 

Agency. 401M St., SW., Washington, DC 

20460. Phone number: (703) 557-2141. 

SUPPLEMENTARY INFORMATION: EPA 

issued a Request for Proposal in the 

Fedaral Register of December 8,1990 (55 

FR 50388). The original submission 

deadline was January 30,1991: the new 

deadline for proposal submission is 

extended to February 28,1991. 

Dated: February 111991. 

Douglas D. Campt, 

Director, Office of Pesticide Programs. 

[FR Doc. 91-4120 Filed 2-20-91: 8:45 am] 

BIUJNO CODE (560-6O<* 

[OPP-1C0B*1; FRL-3877-6J 

Emergency Exemptions 

AQENCY: Environmental Protection 

Agency (EPA). 

ACTION: Notice. 

SUMMARY: EPA has granted specific 

exemptions far the control of various 

pests to the seven States as listed below 

and one by the United States 

Department of .Agriculture. Four crisis 

exemptions were initiated, two by the 

Florida Department of Consumer 

Services and two by the United States 

Deportment of Agriculture. These 

exemptions, issued during the months of 

November and December, except for the 

one in October, are subject to 

application and timing restrictions and 

reporting requirements designed to 

protect the environment to the maximum 

extent possible. Infonnation on these 

restrictions is available from the contact 

persons in EPA listed below. 

DATES: See each specific and crisis 

exemption for its effective dale. 

FOR FURTHER INFORMATION CONTACT: 

See each emergency exemption for the 

name of the contact person, lh e 

following infonnation applies to all 

contact persons: By mail: Registration 

Division (H7505C), Office of Pesticide 

Programs, Environmental Protection 

Agency. 401M St.. SW., Washington. DC 

20480. Office location and telephone 

number Rm. 71B. CM #2,1921 Jefferson 

Davis Highway, Arlington, VA (703-

557-1808). 

SUPPLEMENTARY INrORMATION: EPA has 

granted specific exemptions to the: 

1. California Department of Food and 

Agriculture for the use of chlorothalonil 

on mushrooms to control verticillium 

diseases; November 14,1990, to 

November 13,1991. (Susan Stanton) 

2. California Department of Food and 

Agriculture for the use of avermectin Bi 

on celery to control serpentine 

leafminers; November 19,1990, to 

November 18,1991. (Libby Pemberton) 

3. California Department of Food and 

Agriculture for the use of methyl 

bromide on carrots to control 

nematodes; December 21,1990, to 

December 20,1991. (Libby Pemberton) 

4. Idaho Department of Agriculture for 

the use of pendimethalin on spearmint 

and peppermint to control kochia and 

iA 
P.31 

— 1 

Enclosure 4 

j*'""'- , 

- *jJ L * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

! ST 2 *7 ° ff,C e ° f *'.r Qua,itV Planning and Standards 

**r^- * Research Triangle Park, North Carolina 27711 

4

t OQO ^ 

FOR STAND^^ ^ REPRESENTATIVE 

rSEcS^???f ?EnP^?5MANCE F0R NEW STATIONARY SOURCES HA5S5 2 ESSSTS S ^?Sn?D!JASTE C°MBUSTION (SECTION 129)7 (SECT^N^iff ^M2 I

SSS D S F0R AZARDOUS AIR POLLUTANTS 

(SECTION 112) , AND FEDERAL OZONE MEASURES (SECTION 183) 

(PES)U?sehe?eSvrdesiS«i°i16'

 Pacifi c

 Environmental Services 

ESiiimlm^^ Representative of the 

Agency for tL pu^ose Sf assign* Jn^^ J **of«tion s^r7\^^^ 

«^7S2i."22S2 S£B5rS5!S.uS5 g,?-"-c-

7411'and 

U.s:c!h74lf

 Si?Set

nS?tid S -?

 pursuan t t o

 the Clean Air Act, 42 

preseritltioA o?L^SSlSS S "El f^*6 3 ?**'

 U*°n 

named herein: (l) shall hive t riS? ^^" ^ Representative 

through any premises in whT^h\l

 gh * °? entr y to ' upon ' o r 

which record! rehired to hf TM!? ^SGi°n sourc e *• located or in 

fil aro ?««4.f^ 5 ,5°

 b e

 aamtained under 42 U.S.C. 7414 (a\ 

ini'copy aSy

a

«c«df SLS. 3 t reas ?»^ ° «• - have access

 (?i 

required Snde"« 5 s c ?!« ??? "onitorin, equipment or method 

that the owner or S&£a?2J ^Si^JBiM S S*SS . 

processes entitled toPprotection as 

September 1? i9?I) t DPmente d b y 4 0 CF R 2 '

3 0 1

 <h> <41 TM 36912, 

Date: AUG 2 5 1992 

Designation Expires: September 30, 1993 

"\ 

^. John S. Sfeit2 . 

[•P*^. Director 

Office of Air Quality Planning 

and Standards 

yo 
P.32 

/ ' Enclosure $ 

Mt y , SmrtroiwiiU* Protection Agency* 

Of f 1c* of Afr Quality Pfenning andr standard* (OAQPS* 

Efllssto* Standards Qlvlsloir IESOV 

•.'''• ^3^ : January 198* 

Su—ryof ESP/CAOPS 

Procedures for Safeguarding confidential BuTln-es* Information- (can 

1. Purposes 

This memorandum, describe* Agency policy an* procedures* pertaining to tht 

handling and safeguarding of inf ome tio* that My beenttttt* ta confidential 

treatment for reason* of tusl nes* confidentiality by thcESff; OAQPS, Office of 

Air and Radiation, U.S. Environmental Protection Agency2. Other Appl 1 ablt Oocumontt: 

a. Clean Air Act as amended* 

b. 40 CFR, Chapter l. Part 2, Subpart a - Confidentiality of Business 

Information. 

e. EPA Security Manual, Part It , Chapters 8 and9. 

d. Clean Air Act Confidential Business Information Security Manual for 

Federal Employees. 

e. Clean A1r Act Confidential Business Information Security Manual for 

Contractors. 

3. Exception: 

This docunent was prepared as a summary of data gathering and handling 

procedures used by the ESO, OAQPS, EPA. Nothing In this document shall be 

construed as superseding or being In conflict with any applicable regulations, 

statutes, or policies to which EPA 1s subject. 

4. Definition: 

Confidential Business Information - Information claimed by the provider to 

bt confidential. This information may be Identified with such titles as trade 

secret, secret, administrative secret, company secret, secret proprietary, 

privileged, administrative confidential, company confidential, confidential 

proprietary, or proprietary. NOTE: These markings should not be confused witn 

the classification markings of National Security Information Identified In 

Executive Order 11652. 

V 
fe Background 

Section- U4(cl of tiieCltiit Afr Acre*aaendt* read* a* fal Toutr 

"Any record*; reports** or Inforoattow obttlne* under subseettotr (al 

sh*tj||$tvttfeb.l* to th* public, except that upon a shotting satisfactory 

tar tha> tort nl strator by any perso* that records, reports, or Information, 

or particular part thereof-, (other than emission dotal, to whlctr the 

Adml nl strator ha* accts* undar tht* sacttoi* 1 f mad* public, woul d 

divulge method* or processes entitled to protactto* a * trad* secrets 

of such person, th* Administrator shall consider such recordv 

report, or Information or particular portlo* thereof* confidential 

In accordance wl tiv ,th* purpose* of Sectloir 190* *s> THI* 18 of th* 

United States Cod*,' except that such record^ report^ or Information 

may be disclosed to other officers-, employee** or authorize*? 

representatives of the United States concerned w1 ttt carrying out 

this Act or when relevant In any proceeding under this Act-" 

The treatment of cat by the U.S. EPA, Including data obtained under 

Section I U of the Clean Air Act, Is governed by Title 40, Part 2, of the Code 

of Federal Regulations. These regulations require EPA offices ta Include a 

notice with each request for information to inform the businass of: (I) Its right 

to assart a claim of confidentiality covering part or all of th* Information, 

(2) the method for asserting a claim, and (3> the effect of failure to assert a 

claim at time of submission. In addition, the regulations: (1) set forth procedures for the safeguarding of confidential information; (2) contain provisions 

for providing confidential Information to authorized representatives; (3) contain 

provisions for the release of Information to the Congress, Comptroller General, 

other Federal agencies. State and local governments, and Courts; (4) permit the 

disclosure of information within EPA to employees with an official need for the 

Information; and tS) prohibit wrongful use of such information and cite penalties 

for wrongful.disclosure. Further, the regulations contain the Agency's basic 

rule concerning the treatment of requests for information under the Freedom of 

Information Act (5 U.S.C. S52). 

6. Procedures: 

a. Requests for Information 

Each request originating in the ESO for information made under the provisions 

of Section 114(a) s signed by the Division 01 rector. The request Includes ESO* s 

standard enclosu'j EPA's Information Gathering Authority Under Section 114 of 

the Clean Air A- • «h1ch was designed to meet the requirement of 40 CFR Part 2 

discussed abov* 

S-
p> Receipt of confidential nunntii inronwatioir P.34 

* ' . • • <• 

lipoidreceipt of Infprmatloi*for whtcfr conf Identlar treataenr has beerr 

requested* th* of fic* of th* Of rector (00J direct* thr logging?: of tft* material 

and thfctsta^llshHiit of * permananefllev If confidential treatment Is requested, 

butlJtnd«i«*tf1cally nartedt th* material will bt staflped- "Subject to 

Conf1deftt^Sit.CTai*tr If part of tht Material 1s claimed to bt confidential, 

that portions marked "Suttact to Conf 1 dantlal 1 ty Cl aim." In compl 1 ance wl th 

Sections 2.204. and Z.2Qd.of 40 CFH Part 2, tht Branch Chief responsible for the 

requested Information*re»1e»* th* Information to detenelnt whether It 1s likely 

to b* confidential 1* contrast to being available .in tht open literature, 

whether I t 1s ealsslo* dat*, and whether It likely provides Its holder with a 

competitive advantage If .th* Inforaation Is'clearly not confidential, tht 

Branch Chief prepare* a letter for signature of tht Olvlsion 01 rector, ESO, to 

notify th* business of this finding* If tht Information is possibly confidential, 

tht Branch Chief sends a meoorandia* to Inform tht 00, ESO, of this finding, gives 

a brief description of the material (what it 1s, ho* many pages, etc.l. Identifies 

I t with tht correct ESO project nueber, and lists thos* persons who are authorized 

to hav* access to the Information. Tha Information and memoranda art hand 

carried to tht 00 and placed In tht CBI files with tht material. A record of who 

will set tht. Information (Attachment A) Is also filed with tht folder containing 

the Information. If CBI Is received from the owner via an authorized represent*" 

or a third party, the same procedure Is followed, with tht addition of clearly 

Identifying the Information and its source. By regulation, Information for which 

confidential treatment Is requested must be so marked or designated by the submitter 

The EPA takes additional measures to ensure that the proprietary designation is 

uniformly Indicated and Immediately observable. All unmarked or undesignated 

Information (except as noted below) 1s freely releasable. 

c. Storage of Confidential Business Information 

Folders, documents, or material containing CBI (as defined) shall be secured, 

at a minimus,. In a combination-locked cabinet. Normal ESO procedure Is to secure 

this information 1n a cabinet equipped with a security bar and locked using a 

four-way, changeable combination padlock. In addition, the entrance door to the 

CBI storage room 1s equipped with a changeable combination simplex lock. The 

locked files are under the control of the 00. 

Knowledge of the combinations of the locking devices 1s limited to the Oocumen' 

Control Officer (OCO) and the minimus nunber of persons required td effectively 

maintain normal business operations. Records of the locking device combination 

are stored elsewhere in conformance with the requirements of the EPA Security 

Manual. 

3 ^ 
P.35 

Combtnaciri:-''"'-.• therlock* *r*nonwl 1/changed whenevar* 

knowledge?of th^:;-tnination* I t transferred^ termtnat.es eiiejtoyfnin'c, nor longer 

authori zeeV iccess^ jr whenever th* possi bi 11 ty exi str that th* conti nat 1 on j 

may havtsbedp^^tcftto comorcml^** 

FfTes?ma^b*i checked out upon confirmation that the requesting; person is 

authorized to rectiv*th*>1nformat1onr. AH confidential' flits must bt returned 

no later than 4:00 p.rr* oit th*sam»day they are removed* Tht Intended user nust 

sign tht CRt Control Record whe* th* file Is checked out* 

The Individual who signs out a confidential flit Is responsible for its 

safekeeping* Tht fil * mist not b* left unattended* The Information nust not be 

disclosed to any non-authpntzedpersonnel. 

Storage procedure*'for CBI by an authorized representative* of EPA (see 

Section d. below) nust h*, at a minimum, as secure as thos* established for EPA 

offices within OAQPS. Whenever CBI is removed from tht EPA files to b* transmitted 

to an authorized representative, a memorandum is placed in the-file Indicating 

what Information was transmitted, tht dat*, and tht recipient* The authorized 

representative returns a signed receipt to the OCO* 

d. Access to Confidential Business Information 

. Only authorized EPA employees may open and distribute CBI. 

Only employees who require and art authorized access to CRI in the performance 

of their official duties art permitted to review documents and, upon receiving a 

confidential docuinent, must sign and date the form shown in Attachment A to 

certify their access to the document. 

The CBI files are controlled by the 00, ESO, and maintained by a contractor 

cleared for access as an authorized representative. Access to the information is 

limited to those persons having a need to know 1n performing their offleal duties. 

The ESO Branch having primary Interest In the CBI provides a memorandum for 

the record designating those personnel who are authorized to use CBI In a program 

under which CBI can he requested. No person is automatically entitled to access 

based solely on grade, position, or security clearance. The names of persons 

granted access to CBI are placed on the Clean Air Act CRI access list, which 

Indicates the specific CBI each person Is permitted to see. The access list is 

reviewed and updated periodically. 

Companies under contract to perform work for EPA may be designated authorized 

representatives of EPA if such designation Is necessary in order for the contractor 

to carry out the work required by the contract. As authorized representatives. 

- ^ 
P.36 

« > • •... . • 

contractors may b* granted access tcPCBfcby thrdiraetoi^ESI^.Th#fdirqiiing' " 

condition* apply wheir i t ha* bee*determined that disclosure-!» ntctssaryrr 

( U tNTconttettor designated a* r ^ miy. 

us* suc!*<gl^tdentlal- informatlo*only for thr purpost of carrying out tht wort 

required^lb*dist rtfralw fron disci oil ng th* Information to anyone other than 

EPA without having receded fro*EPA prior written approval of each affected 

business or of an EP* legal offlcr, and (c) nust return to EPA all copies of the 

information (and any abstract* or excerpts therefrom) upon request or whenever 

th* information is no longer required for the performanc* of th* work. 

(2) Th* authorized contractor designated as a representative aust obtain a 

written agreement fro* each'Of its employees who will hav* access to the Informatiai 

A eopy of each empToye* -agreement (Attachment B) must bt furnished to EPA-before 

access is permitted. 

(1) The contractor designated as an authorized representative must agree that 

tht conditions 1n th* contract concerning tht ust and dlsclosur* of CBI are 

Includtd for tht benefit of, and shall be enforceable by, both EPA and any affected 

business having a proprietary interest in th* Information. 

Information may be released to. or accessed by EP*> employees other than OAQPS 

employees only upon approval of the 01 rector, ESO. 

Requests for CBI from other Federal agencies, Congress, the Comptroller Gen*-

Courts, etc., are processed by the 00, ESO, 1n accordance with 40 CFR 2, Subpar: 

Requests under the Freedom of Information Act are handled In accordance with 

40 CFR 2, Subpart A. The ESO Freedom of Information Coordinator must be consulted 

prior to responding to any request for Information If a claim of confidentiality 

has been asserted or If there is reason to believe that a claim might be made if 

the business knew release was Intended. 

e. Use and Disclosure of Confidential Business Information 

The CBI as defined may not be used In publications, supporting documents, 

memoranda, ate., that become a part of the public domain, except as provided for 

In 40 CFR 2 Subpart B. 

Th*CBI may not be sunmaHzed without the approval of the Project Manager 

responsible for the CBI. Any authorized reproduction shall be provided by the 

CBI office staff. Further, all authorized reproductions must be Introduced into 

the CBI control system and treated according to the same procedures applicable to 

the original confidential material. 

The EPA generated documentsor material, or extracts, of Information containl 

CBI, must be stamped "Subject to Confidentiality Claim" and a cover sheet must be 

attached to Identify the material as CBI. 

35 
P.37 

"1 

f~ Handllnoof Other* Information V., - v 

Reports, memoranda, docitMiiW^atd:,. prepared byEPfrorritx authorized 

represenUttve* ar* not: normally drcul ated outsl dt EPA for comment or revlew» 

prior tff pulfeatloerexcepd 1m suchr cases as described above-(6.d.3) wherein car 

1s expressli&wluded*. Howeven btcaust Indus trial-data-gather ing visits, plant 

inspectlonsvandsourc* Usting cai* Involv* inadvertent receipt of CBI, it is the 

policy of ESOt to protect all partte* Involved In th* following manner. 

Prior, to or at th*1nce*t1o*of a plant Inspection, data-gathering visit, or 

sourc* test. EPA or-Its authorized representative discusses with a responsible 

Industry official th* information sought, how i t is to b* used, and how It 1s to 

be protected. A copy of tht* siaawy is usually provided to tht industry official 

being consulted; • 

Following an Inspection, visit, or test, a trip report is prepared to Include, 

as practicable, all Information received by EPA or its authorized representative 

during tha visit or test. The report may bt prepared by either EPA or Hs authorized 

representative. The draft of that report 1s clearly Identified, on an attached, 

colored cover sheet as "Confidential Pending Determination." A second copy of 

tht draft trip report is forwarded by EPA to tht responsible Industry official 

for review. The responsible Industry official 1s requested by cover letter to 

review the report, clearly mark any Information considered to be confidential, 

and return tha marked up-report to the responsible EP* employee within 2 weeks of 

receipt. Tha original draft 1s kept in tha CBI "pending" file until tha marked-up 

copy 1s returned by the business firm. 

When the reviewed copy of the report, as marked by the responsible plant 

official, Is received by EPA, information designated confidential Is placed in 

the CBI files as described above. The original draft of the trip report is 

edited to delete the confidential Information and to accommodate technical changes, 

and the trip report 1s issued. 

2 Attachments 

^ 
P.38 

Attachment A 

CAA CONff DOmTMLiUSINISS INFORMATION 

CONTROL RICOR* 

,0ATt CONTROL NUMOSIfc 

OATioroocuMHir. oocuMtmrAUTHOi* 

oiscnimom (Moviomo onoaiaiaTTOidTiTti; SUSJICT. NUMOIII or co m NUMOIOO* MOI D 

RtttmNOATS^ PISTftUCTtONOATf: IMTIALSt 

CAtM PfftSON WHOIS OiVfN ACCtSSTO TMSOOCUMINTMUSTriUINTKtINroaMaTIOflBfLOW. 

CHECK-OUT CHICK-IN 

mawATuni QATt 0AT1 

DO NOT DETACH 

CAA Form 1 

37 
P.39 

Attachments 

AUTHOWUTtO*fOdACCtS*TttCAACatfO*lPAC0NTWACT0ntNiW.OVttS 

FUUNAWS: POSITION 

ssm CONTMCTOm 

it it the responsibility ef o«eftAtittnrimn*Olfieia* to ensure that the employ eee unear his/her 

supervision whe require aeeeemtmCAACa* 

1. sign the Confidentiality Agreement for SFA Contractor employees 

2. Are fully Informed rotvain * their security raaponmeuitlos f or CAA CSt 

3. Obtain acoaaa only ta that CAA est required to perf erm the* official dutleo 

SIONATURE OP AUTHORIZWO OFFICIAL 

TITLS 

TELEPHONE NO. OAT*. 

LOCATION 

IL CONFIDENTIALITY AGREEMENT POR CFA CONTRACTOR EMPLOYEES 

I understand that I will have aceata to certain Confidential Businass information submitted to 

CFA or its authorised representatives under tha Clean Air Aot (CAA). 

This access Is granted in accordance with my official duties as an employee of an Environmental 

Froteotlon Agency contractor. 

I understand that CAA C8I may not Be disclosed escept aa authorised by CAA and Agency 

regulations, i understand that I may face criminal prosecution if i willfully disclose CBI to any 

pwttn not authorised to raeeive it. in addition. I understand that I may bo subject to 

disciplinary action fcr violation of this agreement with penalties ranging up to and including 

dismissal. 

I agree that I will treat any CAA CBI furnished to me as confidential and that i will follow the 

procedures set forth tn the CAA Confidential Business information Security Manual for 

Contractors. 

I hava read ant understand these procedures. 

SIQNATURt TELEPHONE NO. DATE 

UL HAVINO COMFLETEO REQUIREQ TRAININO ANO FASSE0 REQUIREO TEST, THE ABOvE-NAMEQ 

EMPLOYEE IS HEREBY AUTHORlZEO TO HAVE ACCESS TO CAA C8L 

SIGNATURE CBI COCO TELEPHONE NO. OATS 

CAA FORM 2