p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

146) ll-E-106 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:08 AM Sheet 146 of 264 
P.2 

A-94-5? 

TO: 

FROM: 

DATE: 

MEMORANDUM 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

CCT 2 2 iSS3 

EPA AIR DOCKET 

October 23, 1997 

SUBJECT: Minutes of August 19, 1997, Meeting Between EPA and Representatives of 

the Reinforced Plastic Composites Industry 

LOCATION: EPA/Mutual Building, Durham, NC, 11th floor 

10:00 am -12:00 pm 

ATTENDEES: 

Ms. Nancy Dehmlow 

Mr. Chuck Elkins 

Mr. Robert Jemison 

Mr. Steve McNally 

Mr. Ken Meardon 

Ms. Jan Meyer 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

GLS 

JSC, Inc. 

PES 

Composites Fabricators 

Association (CFA) 

PES 

EPA/ESD/CCPG 

PES 

Composites Institute of the Society 

ofthe Plastics Industry (SPI) 

EPA/ESD/CCPG 

(847) 437-0200 

(703) 312-8540 

(919) 941-0333 

(703) 610-0220 

(919) 941-0333 

(919) 541-5254 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

PURPOSE 

The purpose of the meeting was to brief industry representatives on the new source 

MACT analysis. The briefing presented subcategorization and size cutoff determinations, 

new source MACT floor level results, and example emission reduction and cost results. 

The briefing did not include the presentation of the analyses conducted for mixing and 

cleaning operations. 
P.3 

Madeleine Strum 

October 23, 1997 

Page 2 

DISCUSSION 

Ms. Strum began the presentation by stating that the results of the new source 

MACT analysis have been reviewed by Bruce Jordan, but have not yet been reviewed by the 

Office of General Counsel. Ms. Strum explained that this presentation would not cover new 

source MACT analyses for mixing and cleaning operations. Ms. Strum proceeded by 

discussing the outline of the briefing package (see Attachment 1). She stated that the 

briefing consists ofthe following three parts: (1) Subcategorization and size cutoff 

determinations, (2) New source MACT floor results and example emission reduction and 

cost results for large new sources except closed molding and polymer casting (Group 1), 

and (3) New source MACT floor results and example emission reduction and cost results for 

small new sources and all closed molding and polymer casting operations (Group 2). 

Ms. Strum reviewed three scenarios under which a source would be subject to the 

new source MACT standard and pointed out under which circumstances a source would be 

subject to Group 1 or Group 2 requirements. Ms. Strum explained that the new source size 

(NSS) equation would be used to determine if a new source is subject to Group 1 or Group 

2 requirements. Ms. Strum explained that Group 1 consists of a single subcategory, 

whereas Group 2 consists of a series of subcategories. Ms. Strum further indicated that 

polymer casting and closed molding operations are always included under Group 2, 

regardless of the size of the operations and that closed molding operations are currently 

being defined as resin transfer molding (RTM), vacuum assisted RTM, infusion molding, 

and compression/injection molding. 

The first scenario that Ms. Strum discussed is a new (greenfield) facility or a source 

that meets the criteria for reconstruction as defined in the general provisions. As Ms. Strum 

pointed out, a greenfield or a reconstructed facility would be subject to the new source 

Group 1 requirements if its estimated HAP emissions from all reinforced plastic processes 

except from polymer casting and closed molding operations are equal to or greater than 63 

tons per year. A greenfield or a reconstructed facility is subject to the new source Group 2 

requirements if its estimated HAP emissions from all reinforced plastic processes except 

from polymer casting and closed molding operations are more than 10 tons but less than 63 

tons per year. It was explained that the 63 ton per year cutoff value may change as the EPA 

analyzes the data from the continuous lamination test program. It was further explained that 

the current cutoff was derived in part from an assumed emission factor for continuous 

lamination. 

The second scenario under which a source would be subject to the new source 

MACT standard is construction at an existing facility that results in the expansion of an 

existing process. Ms. Strum explained that the expansion would be subject to Group 1 

requirements if the added reinforced plastic composites HAP emissions are equal to or 

Ir 
P.4 

Madeleine Strum 

October 23, 1997 

Page 3 

exceed 63 tons of HAP emissions per year. If the added reinforced plastic composites HAP 

emissions are more than 10 tons but less than 63 tons per year, the expansion would be 

subject to Group 2 requirements. 

The third scenario under which a source would be subject to the new source MACT 

standard is construction at an existing facility during which a process is added that does not 

currently exist at the facility. According to Ms. Strum, the added process would be subject 

to Group 1 requirements if the reinforced plastic composites HAP emissions from the added 

process are equal to or exceed 63 tons per year. If the reinforced plastic composites HAP 

emissions from the added process are less than 63 tons per year, the expansion would be 

subject to Group 2 requirements. 

Ms. Strum explained that the size cutoff determination was based on emissions 

because the presence of control devices appeared to be based on emissions rather than resin 

or HAP usage. As Ms. Strum pointed out, emission factors for reinforced plastic 

composites processes vary greatly depending on the process and therefore the same amount 

of resin or HAP usage can result in very different emissions depending on the production 

process. 

Ms. Strum proceeded by explaining that the size cutoff of 63 tons of annual HAP 

emissions was derived by listing all reinforced plastic composites facilities that use an addon control device to reduce HAP emissions by approximately 95 percent and by determining 

the lowest uncontrolled HAP emissions from all processes vented to a control device. Ms. 

Strum pointed out that while the size cutoff was derived by counting all HAP emissions 

vented to the control device including emissions from non-reinforced plastic composites 

processes, the size cutoff would be only applied for reinforced plastic composites processes. 

Ms. Strum further explained that, based on the current analysis, Enduro Fiberglass 

in Fort Worth, Texas, has the lowest amount of HAP emissions that are controlled by a 

control device. Enduro's combined HAP emissions from continuous lamination and 

hetrolac application are estimated to be 63 tons per year. As explained earlier, Ms. Strum 

pointed out that this number is expected to change once new continuous lamination emission 

data from EPA testing at LASCO Panel Products are available. 

Mr. Schweitzer asked how the combined uncontrolled HAP emissions of 63 tons 

were estimated for Enduro. Ms. Strum replied that the continuous lamination emissions for 

Enduro were based on the midpoint of the AP-42 emission factor. Ms. Proctor added that 

the Hetrolac application emissions (which contributed to the 63 tons per year) were 

extracted from an emission test report. Mr. Schweitzer inquired if the continuous 

lamination emissions could not be determined from the emission test report. Ms. Proctor 

replied that the continuous lamination emissions could not be determined from the emission 

3 
i 5 _ 

Madeleine Strum 

October 23, 1997 

Page 4 

test report because the reinforced plastic composites emissions determined in the emission 

test included emissions from pultrusion operations, which have now been discontinued. 

Ms. Strum continued by discussing how the NSS equation was derived and how it 

would be used. Ms. Strum explained that the NSS equation was derived only for the 

purpose of determining if a new facility is subject to Group 1 or Group 2 requirements. 

The NSS equation consists of emission factors and annual HAP usages for specified 

reinforced plastic composites processes. It was emphasized that this equation should riot be 

used to estimate acmal emissions from any one specific facility. As Ms. Strum pointed out 

the emission factors in the NSS equation are average emission factors based on the best 

available data. Based on emission studies, it was determined that the emission factors for 

spray-up, hand lay-up, and filament winding vary depending on the resin HAP content. 

Ms. Strum explained that for the processes for which the emission factors vary based on the 

resin HAP content, the emission factors in the NSS equation were based on the HAP content 

limit for Group 2 sources. 

Ms. Strum proceeded by providing an example size cutoff determination for a new 

pultrusion facility that also conducts painting operations. The example is shown on page six 

of Attachment 1. 

In reviewing this example, Mr. Schweitzer asked if a new pultrusion facility that is 

planning to use only direct die injection can meet an equipment standard or meet an 

equivalent emission limit. Ms. Strum replied that the EPA might provide an equivalent 

emission limit. 

Mr. Schweitzer also asked if a facility would be allowed to conduct their own 

emission testing to determine if the facility exceeds the Group 1 cutoff of 63 tons per year. 

Ms. Strum responded that the EPA would consider allowing actual emission testing at the 

facility to determine if the facility exceeds the 63 ton size cutoff. 

Mr. Schweitzer inquired how a new facility would determine how much resin they 

will use. Ms. Strum replied that a new facility has to do a certain amount of planning 

before they begin to operate in order to obtain the necessary permits. Thus, a facility would 

have to provide an estimate of how much resin they are planning to use. Mr. Schweitzer 

asked if a facility that has estimated HAP emissions of 42.8 tons based on the NSS equation 

will be able to increase their resin usage and still be subject to Group 2 requirements as long 

as their estimated emissions based on the NSS equation are below 63 tons per year. Ms. 

Strum confirmed that the facility in Mr. Schweitzer's example would be subject to the 

Group 2 requirements as long as their estimated emissions based on the NSS equation are 

below 63 tons per year, under the approach presently envisioned. 

H 
P.6 

Madeleine Strum 

October 23, 1997 

Page 5 

Mr. McNally asked if a new facility would be classified as a Group 1 or Group 2 

source if the facility's emission estimate based on the NSS equation is less than 63 tons per 

year, but later emission testing shows that actual emissions exceed 63 tons per year. Ms. 

Meyer responded that the facility would be classified as a Group 2 source unless the facility 

used the wrong information in the NSS equation. As was pointed out during the meeting, 

the EPA recognizes that the equation is based on average factors an as long as the correct 

input information is used the equation would have to prevail. 

Ms. Strum proceeded by discussing the MACT floor level results for Group 1 

sources (see page seven of Attachment 1). Ms. Strum added that fhe 95 percent emission 

reduction requirement applies to corrosion and noncorrosion-resistant applications. 

Ms. Strum continued by presenting example MACT floor emission reduction and 

cost results for a new source with 100 tons of HAP emissions per year. The example is 

shown on page eight of Attachment 1. Ms. Strum added that the ductwork and blower costs 

are based on cost data provided by one facility, but these costs will be reassessed by using 

supplemental chapters of the OAQPS cost manual. 

Mr. Elkins inquired how the cost for the permanent total enclosure (PTE) was 

estimated. Ms. Strum replied that the cost for the PTE was derived from two other 

rulemakings, which were the magnetic tape and the wood furniture NESHAP. Mr. Elkins 

asked if these two industries are similar to the reinforced plastic composites industry and if 

the estimated cost is sufficient. Ms. Strum explained that these costs are 

additional/incremental costs for a new plant and should therefore only reflect the additional 

cost to make sure that a spray booth, for example, meets the PTE criteria. Ms. Meyer 

added that if the industry representatives have better cost information for PTE construction 

at new facilities, the EPA would appreciate that information. 

Mr. McNally asked why none of the reinforced plastic composites facilities that are 

using add-on controls are using a rotary concentrator with an oxidizer to control their HAP 

emissions. Ms. Strum indicated that one possibility of why some facilities might not want 

to use a rotary concentrator with an oxidizer is that some facilities have other HAP 

emissions in addition to styrene from operations such as painting. Ms. Strum further 

explained that these facilities might not want to vent these other HAP emissions to the 

rotary concentrator because it could interfere with the proper operation of the system. 

Mr. McNally inquired if he could have a copy of the cost calculations for the three 

different add-on control devices. The EPA agreed to send Mr. McNally a copy of the three 

add-on control cost spread sheets. 

b 
P.7 

Madeleine Strum 

October 23, 1997 

Page 6 

Ms. Strum proceeded by discussing the MACT floor level results for Group 2 

sources. Ms. Strum pointed out that Group 2 sources were subcategorized based on process 

in the same way as existing sources. 

Ms. Strum stated that the new source MACT floor for two of the subcategories was 

based on a "neat resin plus" HAP content limit. In order to avoid any confusion about the 

terminology, Ms. Strum defined neat resin as the resin received by the supplier, which does 

not include additives such as filler and reinforcement. According to Ms. Strum, the "neat 

resin plus" HAP content accounts for any addition of HAP that may be added to the 

supplied resin at the facility where the resin is used. The "neat resin plus" does not include 

filler added at the facility. 

Ms. Strum indicated that the current new source MACT floor determination for 

Group 2 semi-open/open reinforced plastics processes is a 34 percent "neat resin plus" HAP 

content limit and non-spray resin application methods or equivalent. However, Ms. Strum 

pointed out that there are sources in this process subcategory that use resins with a "neat 

resin plus" HAP content as low as 28 percent. But according to Ms. Strum, the EPA has 

questions concerning the technological feasibility of setting the new source MACT floor at a 

28 percent neat resin plus HAP content limit. Ms. Strum continued by asking industry 

representatives to provide information that would help to support the current new source 

MACT floor determination of a 34 percent neat resin plus HAP content limit. 

Ms. Strum pointed out that the EPA is no longer considering a resin HAP content 

limit for polymer casting. The EPA is, however, still investigating work practices in 

polymer casting operations that could be used in the new source MACT floor determination 

for this process subcategory. 

As Ms. Strum indicated, the new source MACT floor for Group 2 SMC 

manufacmring sources currently consists of work practices, which include the use of nylon 

film or equivalent, folding edges, and covers on the doctor box. 

According to Ms. Strum, the new source MACT standard for Group 2 BMC 

manufacmring sources would be a performance standard that would be expressed in terms of 

pounds of HAP emissions per ton of resin used. Ms. Strum explained that the EPA already 

collected the data to set the emission limit for BMC manufacmring sources, but data still has 

to be approved for public use by the company that provided the data. 

Mr. Schweitzer pointed out that it seemed strange to require an emission test on a 

process that could be very tightly closed. Mr. Schweitzer added that an equipment standard 

instead of a performance standard appeared more appropriate for this process. Mr. 

I 
P.8 

Madeleine Strum 

October 23, 1997 

Page 7 

Schweitzer volunteered to provide information of how an equipment standard could be 

written for this subcategory. 

Ms. Proctor pointed out that it would still have to be shown that the equipment 

standard that Mr. Schweitzer was suggesting was equivalent to the new source MACT floor 

determination. Mr. Schweitzer indicated that emission test data on tightly closed BMC 

machines was available and could be provided to the EPA for comparison with the current 

new source MACT floor determination. 

Ms. Strum proceeded by presenting the new source MACT analysis for Group 2 gel 

coating sources. Ms. Strum indicated that the EPA recently sent out section 114 

information collection requests to gel coating facilities in order to determine the new and 

existing source MACT floor for gel coating in terms of pounds of HAP per gallon of gel 

coat. 

As Ms. Strum explained, the new source MACT floor for Group 2 corrosionresistant applications was determined to be a 35 percent neat resin plus HAP content limit 

and non-spray resin application methods or equivalent. Mr. McNally pointed out that he 

was very concerned about a 35 percent neat resin plus HAP content limit for corrosionresistant applications across the board. 

Mr. Schweitzer stated that there are three alternatives for the new source MACT 

floor determination for the corrosion-resistant subcategory. According to Mr. Schweitzer, 

the first alternative is that the MACT floor determination remains at a 35 percent neat resin 

plus HAP content limit, which would lead to no new growth for most of fhe corrosionresistant industry. Mr. Schweitzer added that, even though vinyl ester resins with a 35 

percent neat resin plus HAP content will work for most corrosion-resistant applications, the 

economic impact of switching to a low HAP containing vinyl ester resin will eliminate the 

industry. Mr. Schweitzer stated that gasoline storage tanks made from reinforced plastic 

composites would not be cost competitive when compared to steel tanks. Mr. Schweitzer 

indicated that steel storage tanks would take over that segment of the market, even though 

composites tanks last longer and do not have to be excavated on a regular basis. In 

addition, Mr. Schweitzer pointed out that facilities would have difficulties selling tanks 

made out of different resins than those that are currently used, since the new low HAP 

resins have not been tested for the same duration of time as the currently used resins. 

According to Mr. Schweitzer, the second alternative is that the MACT floor 

determination for corrosion-resistant applications takes the different segments of the 

corrosion-resistant market into account, which would imply a further subcategorization of 

the industry. Mr. Schweitzer pointed out that this alternative would probably not work 

because it would result in the creation of hundreds of subcategories. 

n 
P.9 

Madeleine Strum 

October 23, 1997 

Page 8 

Mr. Schweitzer stated that the third alternative is that the MACT floor determination 

for corrosion-resistant applications looks at a larger grouping of applications. Based on Mr. 

Schweitzer's opinion, the MACT floor determination for this subcategory could be made, 

for example, by examining different application techniques or work practices that would 

reduce emissions instead of focusing on the amount of HAP in the resin, which is present to 

provide certain performance aspects of the product. 

Ms. Strum addressed Mr. Schweitzer's argument against the first alternative by 

stating that in the MACT floor determination the costs of compliance with the standard are* 

not taken into account. Mr. Elkins asked if the EPA would retain a new source MACT 

floor determination, knowing that it would eliminate a market. Ms. Strum reminded 

industry representatives that the EPA has no data that indicate that the corrosion-resistant 

market would be eliminated. Mr. Elkins inquired what course of action the EPA would take 

if such data were available. Ms. Meyer replied that in some cases, such as in the Marine 

Vessel Loading standard, a flexible approach has been developed to avoid negative 

economic impacts of the magnitude described above. 

Mr. McNally added that a resin with a neat resin plus HAP content of 35 percent 

cannot be used for underground storage tanks. Ms. Meyer replied by reminding Mr. 

McNally that any facility can still construct a PTE and vent the emissions to a control 

device to comply with the standard. 

Ms. Proctor asked if industry representatives are planning to share any data 

concerning their ideas for new source MACT floor options for corrosion-resistant 

applications. Mr. McNally replied that industry representatives are planning to first submit 

information on existing source MACT floor options for corrosion-resistant applications. 

Mr. McNally added that this information would be submitted to the EPA on September 11, 

1997. 

Ms. Strum continued by presenting the new source MACT analysis for the closed 

molding subcategory. As Ms. Strum indicated, the new source MACT floor for closed 

molding sources consists of work practices, which include requirements to cover all charges 

and to only expose one charge at any time. 

Ms. Strum proceeded by presenting example new source MACT floor emission 

reduction and cost results for Group 2 process subcategories with a HAP content limit. The 

example is shown on page ten of Attachment 1. 

In reviewing the emission reduction and cost impacts for Group 2 sources, Mr. 

McNally asked if the example new source MACT floor costs include retraining costs. Ms. 

<{ 
P.10 

Madeleine Strum 

October 23, 1997 

Page 9 

Strum responded that retraining costs were not included because these cost calculations were 

done for new sources and therefore retraining costs would not be applicable. 

In addition, Mr. McNally asked how the resin costs were determined for the 

example new source MACT floor costs. Ms. Proctor replied that the resin costs were 

determined based on a 40 percent HAP resin at a cost at $0.70 per pound. The costs for 

resins with different HAP contents were adjusted based on the price of styrene, which was 

priced at $0.30 per pound. The EPA agreed to send Mr. McNally a copy of the resin cost 

calculations. 

Mr. McNally also inquired if the cost calculations included re-qualification costs, 

which are costs that a facility would incur to demonstrate to their customer that the products 

produced with MACT compliant resins still meet their product specifications. Ms. Strum 

replied that re-qualification costs were not included in the example cost calculations. Ms. 

Strum pointed out that assessing these costs would be very difficult because the EPA would 

have to know which new facilities would be subject to such a cost and how many products 

each new facility would have to re-qualify. Ms. Meyer asked industry representatives to 

provide information about re-qualification costs. 

Action Items for Industry Representatives: 

1. Provide information of how an equipment standard could be written for the BMC 

subcategory and provide emission test data on a BMC machine that would meet this 

equipment standard. 

2. Provide information about re-qualification costs if such data are available. 

Action Items for EPA: 

1. Provide a copy of the three add-on control cost spreadsheets. 

2. Provide a copy of the resin cost calculations. 

°\ 
P.11 

/}-/+<*chrr.s„f 3Z 

PROJECT BRIEFING 

REINFORCED PLASTIC COMPOSITES PRODUCTION 

NEW SOURCE MACT FLOOR ANALYSIS 

(NOT INCLUDING MIXING AND 

CLEANING ANALYSES) 

BRIEFING FOR: 

Society of the Plastics Industry/Composites Institute and 

Composite Fabricators Association Representatives 

Project Lead: Madeleine Strum 

August 19, 1997 

^ 
P.12 

OUTLINE 

Part A Subcategorization and Size Cutoff Determinations 

New Source MACT Size Groupings 

Group 1: Large New Sources Except Closed 

Molding and Polymer Casting Operations 

Group 2: Small New Sources and all Closed 

Molding and Polymer Casting Operations 

Size Cutoff Determination 

New Source Size (NSS) Equation 

Part B Group 1 - Large New Sources 

MACT Floor Level Results 

Example MACT Floor Emission Reduction and Cost Results 

Part C Group 2 - Small New Sources 

Process Subcategory Groupings and MACT Floor Level 

Results 

Example MACT Floor Emission Reduction and Cost Results 

2 

w 
P.13 

SUBCATEGORIZATION AND SIZE CUTOFF 

DETERMINATIONS 

New Source MACT Size Groupings 

Group 1 - Large New Sources Except Closed 

Molding and Polymer Casting Operations * 

(Single Subcategory) 

New or reconstructed 

Total reinforced plastic composites 

emissions t 63 tpy** (closed 

molding and polymer casting not 

included) 

OR 

Construction at existing facilities: Expanding 

existing process 

Added reinforced plastic composites 

emissions *: 63 tpy** (closed 

molding and polymer casting not 

included) 

OR 

Construction at existing facilities: 

Adding new process 

Total added reinforced plastic 

composites emissions h 63 tpy** 

(closed molding and polymer casting 

not included) 

Group 2 - Small New Sources and all Closed 

Molding and Polymer Casting Operations 

(Series of Subcategories) 

New or reconstructed 

Total reinforced plastic composites 

emissions < 63 tpy** (closed molding and 

polymer casting not included) 

Closed molding and polymer casting 

operations regardless of emissions 

OR 

Construction at existing facilities: 

Expanding existing process 

Added reinforced plastic composites 

emissions "r 10 tpy and < 63 tpy** (closed 

molding and polymer casting not included) 

Closed molding and polymer casting 

operations regardless of emissions 

OR 

Construction at existing facilities: 

Adding new process 

Total added reinforced plastic composites 

emissions < 63 tpy** (closed molding and 

polymer casting not included) 

Closed molding and polymer casting 

operations regardless of emissions 

Closed molding operations are resin transfer molding (RTM), vacuum assisted RTM (VARTM), infusion 

molding, and compression/injection molding. 

Cutoff may change after new data is analyzed and a new emission factor is determined. 

Part A - Subcategorization and Size Cutoff Determinations 

1, 
G^> 

Reinforced Plastic Composites Facilities That Abate Emissions 

Through The Use Of Add-On Controls* 

Facility Name 

Processes Controlled by Control 

Device 

Total Uncontrolled HAP Emissions 

from Processes Controlled by Device 

(tpy) 

Overall Control Efficiency of Approximately 95 % 

A. R. E. (MassiUon) 

Crane Kemlite (Jonesboro) 

American Standard 

Fibercast 

Navistar International 

Tecton 

Enduro Fiberglass 

(Ft Worth) 

Spray Filled, Gel Coating, and 

Painting 

Continuous Lamination 

Spray Filled 

Centrifugal Casting and BMC 

SMC and Painting 

Pultrusion and Painting 

Continuous Lamination and Hetrolac 

Application 

871 

96 

94 

84 

75 

>96 

63** 

This is not a complete list of facilities that use add-on control devices. Other facilities use control devices, but their capture efficiency is not 

known. 

Facility wjthjhe IbwestUotaFuncontroIled HAP emissiorisjfrom processes that are controlled by«ja control device. The.emission estimate may 

chaTTge*!fternewl5ontin^^ data'is afaiyz^'d^M^afnlw'reTmiission factor" is*~determined. 

Part A - Subcategorization and Size Cutoff Determinations 

TJ 
J^-

New Source Size (NSS) Equation 

(15JXA) + (184x5) + (13.2xQ + (3.0xD) + (10.7 xE) + (18.4xF) + (55.8xG) + (51.0xH) + (2.0x7) 

100 

A = Tons of HAP Used per Year in Filled Spray-up 

B = Tons of HAP Used per Year in Unfilled Spray-up 

C = Tons of HAP Used per Year in Hand Lay-up 

D = Tons of HAP Used per Year in Continuous Lamination/Casting 

E = Tons of HAP Used per Year in Pultrusion 

F = Tons of HAP Used per Year in Filament Winding 

G = Tons of HAP Used per Year in Centrifugal Casting 

H = Tons of HAP Used per Year in Gel Coating 

I = Tons of HAP Used per Year in SMC, and BMC Manufacturing 

Grouping Determination Based On NSS Equation 

If NSS > 63 tpy*, emission reduction of 95 % is required 

If NSS < 63 tpy*, compliance with MACT standard for small new sources is required 

* Cutoff may change after new data is analyzed and a new emission factor is determined. 

Part A - Subcategorization and Size Cutoff Determinations 

5 
P.16 

Example Size Cutoff Determination for a New Pultrusion Facility 

that also Conducts Painting Operations (a Facility Similar to Tecton) 

Assumptions used in the example size cutoff determination 

Pultrusion is the only reinforced plastics process at this facility 

The facility also conducts painting operations in which at least 54 

tpy of HAP are emitted 

The facility uses 1,000 tpy of resin in the pultrusion process with a 

neat resin plus HAP content of 40 percent 

New Source Size Calculation 

Tons of HAP per used in pultrusion: 1,000 tpy X 0.4 = 400 tpy 

NSS = ' x where, E is the tpy of HAP used in pultrusion 

100 

NSS = 42.8 tpy 

Since the calculated reinforced plastics emissions are below 

63 tpy* based on the NSS equation, this new source is a Group 2 

source 

Therefore this source would not be required to reduce its 

reinforced plastics emissions by 95 percent, even though total 

uncontrolled facility HAP emissions are at least 96 tpy (42.8 tpy 

from pultrusion and more than 54 tpy from painting). 

Cutoff may change after new data is analyzed and a new emission factor is determined. 

Part A - Subcategorization and Size Cutoff Determinations 

6 

15 
P.17 

GROUP 1 - LARGE NEW SOURCES EXCLUDING 

CLOSED MOLDING AND POLYMER CASTING 

MACT Floor Level Results 

Processes (Includes Corrosion- and 

Noncorrosion-Resistant Applications) 

Spray Filled 

Spray Unfilled 

Hand Unfilled 

Hand Filled 

Continuous Lamination/Casting 

Pultrusion 

Filament Winding 

Centrifugal Casting 

Gel Coating 

SMC 

BMC 

New Source MACT Floor 

95 % Emission Reduction 

Part B - Group 1 - Large New Sources Except Closed Molding and Polymer Casting 

\ < . 
P.18 

Example MACT Floor Emission Reduction and Cost Results 

for a New Source with 100 tpy of Emissions 

Assumptions used in the example emission reduction and cost 

calculations 

Sum of all reinforced plastics emissions excluding emissions 

from closed molding is 100 tpy 

HAP concentration vented to the control device is 50 ppm 

Annual operating hours are 6,664 (average annual operating 

hours for reinforced plastic composites facilities that abate 95 

percent of their emissions through the use of add-on controls) 

Cost to construct permanent total enclosure (PTE) is $ 20,000 

Ductwork and blower costs are $ 66,000 

Example Emission Reduction and Cost Table for 3 Different 

Add-On Control Devices for a Group 1 Facility 

Rotary Concentrator 

Catalytic 

Oxidizer (95% 

Heat Recovery) 

Regenerative 

Thermal 

Oxidizer (95% Heat 

Recovery) 

Controlled 

Emissions 

(tpy) 

5 

5 

5 

Emission 

Reduction 

(tpy) 

95 

95 

95 

PTE 

Cost 

($) 

20,000 

20,000 

20,000 

Ductwork & 

Blower Cost 

($) 

66,000 

66,000 

66,000 

Total 

Capital 

Cost ($) 

905,100 

1,636,700 

1,611,500 

Total 

Annualized 

Costs ($) 

314,100 

429,000 

477,300 

Dollars 

per Ton 

($/ton) 

3,300 

4,500 

5,000 

Part B - Group 1 - Large New Sources Except Closed Molding and Polymer Casting 

n 
P.19 

GROUP 2 - SMALL NEW SOURCES AND ALL 

CLOSED MOLDING AND POLYMER CASTING 

Process Subcategory Groupings and MACT Floor Level Results 

Processes 

Spray Filled 

Spray Unfilled 

Hand Unfilled 

Hand Filled 

Continuous Lamination/Casting 

Pultrusion 

Filament Winding 

Polymer Casting 

SMC 

BMC 

Gel Coating 

Corrosion-Resistant Applications 

(Spray, Hand, Filament Winding, 

and Centrifugal Casting) 

Closed Molding (RTM, VARTM, 

Infusion Molding, and 

Compression/Injection Molding) 

New Source MACT Floor 

Neat resin plus HAP content limit* of 34 % (could be 

28%) or equivalent and non-spray resin application 

except for filled resins 

No HAP content limit 

Nylon film or equivalent, fold edges, and cover doctor 

box 

lbs of emissions per ton of neat resin plus 

HAP content limit (lbs/gallon) still to be determined 

Non-spray resin application and neat resin plus HAP 

content limit* of 35 % or equivalent 

Only expose one charge at any time. All other charges 

are to be covered. 

Neat resin is defined as the resin received by the supplier and does not include additives such as filler and 

reinforcement. The neat resin plus HAP content accounts for any addition of HAP that may be added to 

the supplied resin. The neat resin plus HAP content is calculated as shown below: 

Neat Resin Plus HAP Content = 

(X * N) + H 

N + H 

* 100 % 

where, X = weight % HAP ofthe neat resin divided by 100 % 

N = neat resin in pounds per year 

H = HAP added to the neat resin in pounds per year 

Part C - Group 2 - Small New Sources and All Closed Molding and Polymer Casting 

l« 
Example MACT Floor Emission Reduction and Cost Results for a New Source with 275 tpy Resin Use 

• Assumptions used in the example emission reduction and cost calculations 

Resin usage is 275 tons per year 

Neat resin plus HAP content without MACT in place would be 40 percent 

Example Emission Reduction and Cost Table for Different Processes at Group 1 Facilities 

-o 

Filled Spray 

Hand 

Continuous Lamination 

Pultrusion 

Filament Winding 

Corrosion-Resistant Hand 

Without MACT in Place 

Neat Resin Plus 

HAP Content (%) 

40 

40 

40 

40 

40 

40 

Resin 

Cost ($) 

385,000 

385,000 

385,000 

385,000 

385,000 

467,500 

Emissions 

(tpy) 

21.6 

16.6 

3.3 

11.8 

21.2 

16.6 

With MACT in Place 

Neat Resin Plus 

HAP Content (%) 

34 

34 

34 

34 

34 

35 

Resin 

Cost ($) 

407,000 

407,000 

407,000 

407,000 

407,000 

495,000 

Emissions 

(tpy) 

14.7 

12.4 

2.8 

10.0 

17.2 

13.0 

Emission 

Reduction 

(tpy) 

6.9 

4.2 

0.5 

1.8 

4.0 

3.6 

Dollars per Ton not 

incl. Gel Coat ($/ton) 

3,200 

5,200 

44,000* 

12,200 

5,500 

7,600 

Cost may change after new data is analyzed and a new emission factor is determined. 

Part C - Group 2 - Small New Sources and All Closed Molding and Polymer Casting 

10