P.1 

OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

1) IV-E-1 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:25 AM Sheet 1 of 130 
P.2 

MEMORANDUM 

TO: Keith Barnett 

U.S. EPA/ESD/OCG 

FROM: Susan Cassidy and Kenneth Meardon 

Pacific Environmental Services, Inc. (PES) 

1 

EPA AIR DOCK. 

DATE: September 

SUBJECT: Minutes of 

13,2001 

September 7, 2001 Meeting Between EPA and the 

Fabricators Association 

LOCATION: Holiday Inr 

ATTENDEES: 

John Schweitzer 

Charley Brown 

Jim Berry 

Chuck Elkins 

Fred Dierks 

John Barker 

Dianne Coon 

Ken Odette 

Perry Bennett 

Monty Felix 

Lowell Miles 

Mark Aker 

Mark Rowan 

Dan Blackburn 

Kenneth Witt 

Gordon Lowe 

Frank Meadows 

Susan Cassidy 

Keith Barnett 

Kenneth Meardon 

Stuart Sessions 

Steve Bemis 

Aayisha Khursheed 

Marc Fleischaker 

Dennis Crumpler 

Lisa Conner 

i, Durham, NC 9:00 am -

CFA 

Aqua Glass 

Berry Environmental 

CE&A 

Aqua Glass 

Strongwell 

Ashland 

CFA 

MFG 

Alaglass 

Miles Fiberglass 

Aker Plastics 

Able Body Co. 

Able Body Co. 

Able Body Co. 

LASCO Bathware 

PES, Inc. 

PES, Inc. 

U.S. EPA 

U.S. EPA 

Environomics, Inc. 

MASCO/Aqua Glass 

U.S. EPA 

12:30 pm 

(734) 622-0162 

(731)632-2593 

(919)785-9631 

(202)686-3518 

(731)632-2554 

(540)645-8129 

(614) 790-3998 

(703)525-0511 

(440) 994-5207 

(803)874-2731 

(503) 775-7755 

(219) 936-3838 

(417) 623-3060 

(417) 623-3060 

(417) 623-3060 

(714) 993-1220 

(919) 941-0333 

(919) 941-0333 

(919)541-5605 

(919) 941-0333 

(301) 657-7762 

(313)792-6360 

(919)541-7775 

Arent Fox/Aqua Glass (202) 857-6053 

U.S. EPA 

U.S. EPA 

(919)541-0871 

(919)541-5060 

/ 
P.3 

Meeting Minutes 

September 13, 2001 

Page 2 

PURPOSE: 

The purpose ofthe meeting was for the Composite Fabricators Association (CFA) and the 

reinforced plastic composites industry to present comments to the U. S. Environmental Protection 

Agency (EPA) on the proposed MACT standard for the reinforced plastic composites industry. 

Presentations were given by CFA and industry representatives and handouts were provided and 

are attached as follows: (1) Presentation on the Proposed NESHAP for Composites, presented 

by John Schweitzer for the Composite Fabricators Association, attachment #1; (2) Presentation 

from Stuart Sessions for Environomics, attachment #2; (3) Aqua Glass Corporation Comments 

for EPA Hearing, presented by Charley Brown, attachment #3; (4) discussion by Perry Bennett of 

MFG (no hand outs); (5) Comments on Proposed MACT for Reinforced Plastics/Composites 

presented by Craig Peterson for Xerxes Corporation and Proform Company, LLC, attachment #4; 

(6) Presentation by Mark Aker of Aker Plastics (no handouts); (7) Presentation to the EPA on the 

Proposed ENESHAP for Composites, presented by Dan Blackburn, Mark Rowan, and Ken Witt, 

all of Able Body Corporation, attachment #5; (8) Presentation by Gordon Lowe of LASCO 

Bathware, attachment #6; (9) Presentation to EPA on the Reinforced Plastics Composites MACT: 

Why Pollution Prevention should be a compliance option, presented by Dianne Coon of Ashland 

Specialty Chemical Co., attachment #7; and (10) Presentation by John Barker of Strongwell (no 

handouts). 

DISCUSSION: 

Following introductions, Mr. Schweitzer began with his presentation focusing on 

industry's concerns with the control requirements (see attachment #1). In particular, he focused 

on the feasability of 95% capture and control, the costs and affordability of capture and control, 

and pollution prevention alternatives. 

Mr. Schweitzer explained that a CFA contractor (Rob Haberlein) visited 18 operations 

believed to be representative ofthe industry. EMr. Schweitzer stated that, according to the 

findings presented in Mr. Haberlein's report on these 18 operations, retrofitting existing 

operations with enclosures would capture only 80% of emissions on average, with some facilities 

below and others above that level. 

EMr. Schweitzer stated that CFA has not been able to evaluate the two operations (A.R.E. 

and American Standard) used as the basis for EPA's proposed 100% capture and expressed 

concerns with the feasability of achieving 100% capture while maintaining safe worker exposure 

levels and flexibility for a full range of operations. In addition to the questions found in his 

handouts (see page 5 in Attachment 1), Mr. Schweitzer asked the following questions about the 

enclosures at these two facilities: 

How do plants manage the operations to protect the workers? 

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Meeting Minutes 

September 13, 2001 

Page 3 

What are the logistics in meeting the criteria of Method 204? 

Are the practices transferable to all RFP facilitites? 

Mr. Schweitzer also expressed concerns that the one actual total enclosure and the one 

theoretical use of total enclosures described in a technical paper referenced by EPA would not be 

acceptable for many composites manufacturing operations because of product size and worker 

exposures to styrene and other air contaminants. The total enclosure in actual operation in the 

paper is applied to a ship-building operation and the enclosure only covered part ofthe ship and 

has to be moved from one part ofthe ship to the next. The theoretical total enclosure operation 

discussed in the paper considered production of a helicopter and was sized to allow production of 

only one helicopter at a time. EMr. Schweitzer stated that these operations are not similar to 

reinforced composite production in which several molds and/or multiple products of varying size 

are made and where a product needs to be made all at the same time and not in stages. Further, 

Mr. Schweitzer noted the use of respirators and recirculating air and stated that he did not know 

of anyone in the RFP industry doing this. He further expressed concern over whether OSHA and 

fire marshalls would allow the RFP industry to implement such operations. Finally, he noted that 

a 300 ppm exposure to styrene is a violation ofthe OSEHA standards for styrene. 

In discussing the costs associated with capture and control, Mr. Schweitzer expressed a 

number of concerns with EPA's cost analysis and mentioned that industry will provide additional 

cost data to EPA. In particular, EMr. Schweitzer expressed concern that the level of concentration 

of styrene needed in exhaust air for efficient control presents an exposure risk to workers and that 

the variation in operating hours (8 hours per day, 5 days per week versus 24 hour days in EPA's 

cost analysis) will have a substantial impact on the costs. He stated that based on visits to four 

RFP facilities, average worker exposures are 22 to 35 ppm and exhaust concentrations between 

8.4 and 70 ppm. EMr. Schweitzer referred to an industrial hygienist who when asked about the 

possibility of lowering air flows to increase styrene concentration in these four facilities 

recommended against doing so because of increase in both heat stress and styrene exposure to the 

worker. 

Mr. Schweitzer expressed concern about the operating hours used to calculate the costs of 

capture and control pointing out that the operating hours for the 18 facilities studied by Mr. 

Haberlein ranged from 8 hours per day, five days per week up to nearly continuous operation. 

Finally, Mr. Schweitzer expressed industry's position that pollution prevention is a better 

option than capture and control. He noted to the floor requirements appeared to be overall (with 

a few exceptions) very good. However, for above-the-floor, based on an average capture of 80% 

and 95% control efficiency, CFA believes 76% is a better estimate ofthe overall control level that 

can be achieved and that pollution prevention can achieve emission reductions close to that level 

while reducing energy consumption and providing worker protection benefits, all at much lower 

cost than capture and control. 

3 
P.5 

Meeting Minutes 

September 13, 2001 

Page 4 

The second presenter was Mr. Sessions with Environomics (see attachment #2). He 

focused his concerns on the affordability of capture and control and on EPA's economic impact 

analysis (EIA). In particular, Mr. Sessions expressed concerns with assumptions that EPA used 

to determine control costs and with the lack of available data to develop an accurate model of 

affordability. He indicated that it was likely nobody really had the data. Given the complexity of 

the model and the lack of reliable data, Mr. Sessions does not recommend revising the model. 

However, he suggested that EPA take an aggregate look at those subject to the 95% requirement 

versus those that are not. He presented compliance cost information by three groupings of 

facilities: (1) thermoplastics, (2) those facilities that emit more than 100 tons per year of HAP and 

are owned by large businesses and those that emit more than 250 tons per year of HAP and are 

owned by small businesses, and (3) all others. He stated that the 29 facilities that make up the 

second grouping of facilities (those subject to the 95% control requirement) will incur the bulk of 

increased costs for the industry. 

Mr. Sessions presented a detailed cost analysis for 10 facilities and expressed the belief 

that his cost estimates were 2.4 times higher than EPA's and that based on those costs, 7 ofthe 

10 would likely close rather than assume the control costs. Mr. Session indicated that the costs 

calculated by the industry underestimate costs in that they do not include monitoring, 

recordkeeping, and reporting costs. In addition, the costs for the Kohler facilities may also be 

understated. He used the same assumptions as EPA in the cost analysis for interest rate, life of 

service, and indirect cost factors. On the other hand, he used actual air flows, concentrations, 

operating hours, and energy costs and current level (year 2000) of production, which in some 

cases were very different than those used by EPA (year 1998). 

Mr. Sessions commented that the EIA is flawed because it analyzes captive facilities 

(provide product only to parent company) from merchant facilities (sell product in the open 

market). No cost analysis was performed on the 95% control requirement for captive facilities. 

He believes the assumption that all large business facilities are captive and will absorb compliance 

costs is flawed because many facilities operate as stand-alone, merchant facilities even though they 

have large parent companies. According to Mr. Sessions, ofthe 29 facilities identified as being 

subject to the 95% requirement, 24 are clearly merchant facilities, 2 are both merchant and 

captive, and one is debatable. Furthermore, parent companies of captive facilities do consider 

closing facilities under their control and outsourcing rather than assuming increased costs. 

Mr. Sessions stated that the EIA model estimates how much each facility would spend to 

manufacture each product by developing a supply curve for each facility. He said this was not a 

good approach, that EPA does not know what it costs each facility to produce products. Instead, 

he suggests that EPA conduct an economic analysis using an affordability approach. EMr. Sessions 

does not believe that it makes sense to talk about the price of product because ofthe multitude of 

reinforced plastic products produced. Examining price of product is more appropriate, according 

to Mr. Sessions, more uniform products, such as gasoline or cement. EMr. Sessions presented 

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Meeting Minutes 

September 13, 2001 

Page 5 

three criteria for affordability, which he characterized as conservative. The three criteria are (1) 

total annual cost (TAC) as percent of 2000 annual composites revenues, (2) TAC as a multiple of 

2000 annual composites profit, and (3) total capital investment as a multiple of 5 year average 

annual capital expenditures. According to his assessment ofthe compliance costs versus these 

three criteria, capture and control would be either clearly or probably not affordable for 7 ofthe 

10 facilities examined. The financial data used to make this analysis for the 10 facilities can be 

provided to EPA on a confidential basis. 

An EPA representative asked whether CFA would have approved of an analysis based on 

model plants. EMr. Schweitzer replied that CFA does not feel that the model plant is appropriate 

because there is too much variability within the industry to identify representative operations. He 

suggested an approach of taking a detailed look at 10 facilities (one/third ofthe affected facilities). 

Mr. Schweitzer also stated CFA's position that Congress intended that affordability should be 

given special consideration for requirements that go above the floor. Another EPA representative 

asked how industry revenues have been recently. EMr. Sessions responded that business has 

generally been good since the mid-90's, but it has pretty bad for the auto sector over the last year 

and half to two years. 

In the third presentation, Charley Brown from Aqua Glass provided comments on EPA's 

evaluation of add-on control costs and his experience with Aqua Glass (see attachment #3). His 

primary concerns are that he believes inaccurate assumptions were used to develop the proposed 

standard and add-on controls are that the add-on control costs are prohibitively expensive -

competition prevents product price increases to compensate for higher production costs. Mr. 

Brown stated that his units sell for about $200 per unit and that a $4 to $6 increase in price is a 

"big" for his ability to sell his units. He stated that the estimated cost of compliance of $6 million 

dollars is approximately two-thirds of their annual profit over the last several years. EMr. Brown 

stated that his company could not and would not make such an investment in their plant to 

implement capture and control. He felt that increases in unit prices (about $10 per unit) would 

result in the shift to other materials being used to produce tubs and showers. Instead of capture 

and control, EMr. Brown stated that Aqua Glass has had great success with Pollution Prevention 

(P2) efforts at one plant and believes that P2 is a better approach for the industry than add-on 

controls. Mr. Brown indicated that Peter Brewer with the Oregon Department of Environmental 

Quality would be a contact to discuss the P2 approach at their facility. 

An EPA representative asked about exhaust flow rate and concentration data. Mr. Brown 

responded that the data will be included with the formal, written comments. The EPA 

representative also asked Mr. Brown whether Aqua Glass had considered the table of alternative 

point values. EMr. Brown replied that the alternative would not help Aqua Glass achieve 

compliance. 

The fourth presenter was Perry Bennett with MFG. MFG is a family-owned business 

£ 
P.7 

Meeting Minutes 

September 13, 2001 

Page 6 

founded by his father in 1950. Over the years, the company has built a wide variety of products. 

The company has many facilities, all of which operate as separate entities, with the largest facility 

employing 350 people and the smallest employing 35. EMr. Bennett noted that the year 2000 was 

one of their worst business years. 

Under the proposed rule, the company has the potential to be subject to the 95% control 

requirement. Mr. Bennett stated that his company can not afford to implement the 95% control 

requirement. He stated that he will provide details in his written comments. Mr. Bennett 

indicated that each facility operates as a separate business entity and as individual profit centers 

each must justify their operations. The MFG Union City facility at full capacity (3 shifts per day) 

emits about 130 tons per year of HAP. Implementing 95% control at this facility would cost 

about $18,000 per ton of HAP reduced. The best years for this facility were 1998 and 1999; the 

worst year, 2000. According to Mr. Bennett, if an oxidizer system was in place, they would have 

to had to close the facility in 2000. 

According to Mr. Bennett, MFG is not a captive facility and its customers (e.g., auto and 

large truck industry) require annual cost cuts; therefore, the cost of added controls could not be 

passed on to the customers. EMr. Bennett also raised the issue of added energy costs that would 

result from operating an oxidizer with low stack concentrations of styrene (less than 100 ppm). 

Mr. Bennett stated that they had been cited by OSHA for having a styrene concentration 

of more than 100 ppm in a gel coat booth, even though the workers wear respiratory protection. 

In response to the OSHA citation, EMFG entered into a consent agreement with OSHA to reduce 

worker exposure to styrene using engineering controls and has joined a voluntary effort to limit 

worker exposure to 50 ppm based on a toxicologist's recommendation. Mr. Bennett stated that 

they may seek to meet a 20 ppm goal based on the ACGIH's TLV on 20 ppm (which is an 8-hour 

time weight average). 

Mr. Bennett also commented on the impossibility of achieving 100% capture at a 

particular MFG facility that consist of a three-story brick and concrete structure with an overhead 

hoist system and dilution ventilation, with spraying booths, curing, and reinforcements tied in 

between the booths on the third floor and a second building across a public road. He noted that 

tying these two buildings together would be difficult and extremely expensive. In order to obtain 

100 percent capture, Mr. Bennett stated that it would be necessary to tear down the buildings and 

build a new structure. This particular facility has partial coating cure occurring outside ofthe 

booth. 

He also discussed the emission reductions that MFG has achieved through successful P2 

efforts. EMr. Bennett indicated that in the pre-RACT days, their potential to emit was greater than 

400 tons per year of VOC. With post-RACT, their potential to emit VOC decreased to 242 tons 

per year. Currently, their plant wide applicability limit is 164 tons per year of VOC (a "cap" on 
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Meeting Minutes 

September 13, 2001 

Page 7 

emissions). This is equivalent, according to Mr. Bennett, to about 132 tons per year of HAP. 

In order to comply with the proposed rule, Mr. Bennett stated that MFG would have to 

cap each facility in order to maintain emissions less than 100 tons per year, they would have to 

renegotiate their State and Title V permits, and they would never be able to utilize the maximum 

capacities available at each facility. Such a situation, according to Mr. Bennett, would lead to 

employee layoffs, customer and revenue loss, and plant closures. Operating to maintain emissions 

less than 100 tons per year would result in facilities becoming the "ultimate" job shop. 

An EPA representative asked what type of system Mr. Bennett had looked at to determine 

that the cost was too high. Mr. Bennett replied that he considered a concentrator plus oxidizer 

control system. The EPA representative also asked Mr. Bennett if the practice he described of 

pulling products off-line for partial curing outside of booths is typical. Mr. Bennett and other 

industry representatives indicated that it is not uncommon to have partial curing occurring 

between laminate areas. 

The fifth presenter, Craig Peterson for Xerxes Corporation, represented both Xeres and 

Proform, two companies with the same owner (see attachment #4). According to Mr. Peterson, 

the facilities owned by these two companies can not meet any ofthe Method 204 requirements. 

He noted that at Xerxes, the molds are set up in rows with large distances between the molds, 

while at Proform, the molds travel station-to-station in a horse-shoe layout. 

Mr. Peterson then expressed concern that the small business definition is too restrictive 

and his belief that EPA has the discretion to redefine small businesses so that smaller facilities that 

operate as separate entities could obtain the exemptions of other small facilities even if they are 

owned by a larger corporation. EMr. Peterson also stressed that large companies will consider 

shutting down supply divisions and outsourcing their needs if that is deemed cost-effective. An 

EPA representative shared that the Office of General Counsel is concerned that altering the 

definition to benefit legitimate small operations opens the door for large companies to declare 

subsidiaries autonomous solely for the purpose of gaining small business status under the rule, and 

the representative asked industry for input on ways to avoid this type of gaming if the small 

business definition is revised. No immediate suggestions were offered. 

In the sixth presentation, Mark Aker of Aker Plastics, discussed the history ofthe three 

generation, family owned business currently manufacturing bathtubs. The company has three 

facilities and produces about 1,400 units per day. The Martinsburg, West Virginia, facility and 

the Plymouth, IN, facility have stack controls (concentrator and incinerator) and do not meet the 

proposed MACT standard. Mr. Aker stated that they can not meet the Method 204 requirements 

without shutting down operations and restructuring the building. He also stated that he did not 

believe they could achieve Method 204 requirements at any cost. 

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Meeting Minutes 

September 13, 2001 

Page 8 

Mr. Aker discussed the success his company has had in reducing emissions through P2 

efforts and expressed his belief that P2 is the best approach to MACT for the industry. He 

pointed out that they have worked with suppliers since 1990 to lower the HAP content in the 

resin. In 1990, they were using a 44 to 48% HAP resin, which is now down to 35% HAP and still 

use the same amount of filler. Gel coats have gone from 38 to 42% HAP content down to 25% 

HAP content. Further, Mr. Aker stated, they have used spray guns that have achieved at least a 

60% reduction in emissions. 

An EPA representative suggested that Mr. Aker review the point value options to 

determine if the Martinsburg plant can meet the point value limits in Table 5 ofthe proposed rule 

through a combination ofthe existing controls and P2 efforts. The EPA representative then 

explained that the point value limits in Table 5 can be used to comply with the proposed rule by 

controlling a portion of emissions at a facility (e.g., those that might have higher HAP 

concentrations than other emission points). 

The seventh presentation was made by Dan Blackburn, Mark Rowan, and Ken Witt of 

Able Body Corporation (see attachment #5). Their discussion focused on the background of Able 

Body Corporation and their concerns that the cost of capture and control are too high and that the 

nature of their operations, diverse and seasonal product base and small, flexible work cells, does 

not lend itself to 100% capture without sacrificing the flexibility needed to maintain their product 

base. 

Gordon Lowe of LASCO Bathware gave the eighth presentation (see attachment #6). 

LASCO is the largest manufacturer of tubs. Current profit margins are on a downturn, primarily 

because shipping costs have increased due to customer demands for limited volume deliveries. 

LASCO considered building a new plant in Kentucky and dropped the project due to the cost of 

the case-by-case MACT determination that would have required capture and control. The 

company has worked with an EPA representative to develop Pollution Prevention through the 

Permitting Process (P4) with success. EMr. Lowe noted that the South Coast Air Quality 

Management District was coming out with a new rule that would require 65 to 71% reduction for 

all spray booths. Finally, EMr. Lowe shared his experience in achieving lower emission rates using 

FIT technology with gel coat containing 36% styrene than was achieved using atomomized spray 

with a 30% styrene gel coat. 

The ninth presenter was Dianne Coon of Ashland Specialty Chemical (see attachment #7). 

She discussed the negative impact that a control-based standard will have on research to develop 

low-HAP coating technology in the fiiture. An EPA representative asked if she had looked at the 

market share of small versus large users. Ms. Coon replied that approximately one-third ofthe 

market will have to go to oxidation under the proposed standard. 

The final presenter was John Barker of Strongwell, also appearing on behalf of the 

2 
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Meeting Minutes 

September 13, 2001 

Page 9 

pultrusion industry. He had three main topics: (1) preform injection, (2) averaging, and (3) large 

parts. With regard to preform injection, Mr. Barker discussed the options available in the 

proposal: wet area enclosures, direct die injection, and 95% capture and control. He shared that 

wet area enclosures work well to achieve approximately 60% reduction; direct die injection has 

limited use for the pultrusion industry and Strongwell has not had much success with it (hard to 

get the product throughly wetted out, process speeds are lower, and tooling has shorter lifespan); 

and that 95% capture and control using Method 204 is too restrictive to work well for the 

pultrusion industry. EMr. Barker suggested that preform injection, which tests show to achieve at 

least 90% reduction, be added to the proposed rule as an option. 

With regards to averaging, Mr. Barker noted that the current rule allows for access for 

adjustments for up to 30 minutes in each shift and if the 30 minute allowance for access is 

exceeded, the line must shut down, the process drained, etc., until the next shift begins. EMr. 

Barker noted that 30 minutes may be a good overall average, but that the 30 minutes does not 

allow for flexibility for start-up of new product lines and for large parts and intricate parts, which 

require a lot of adjustments during production. He pointed out that the proposed rule does not 

have an allowance for startup or shutdown, for extraordinary events that require lengthier access, 

or for new product startup and personnel training. EMr. Barker proposed that the rule allow 

averaging across preform injection, wet area enclosures, and direct die injection such that as long 

as the average emission reduction achieves 60% the owner or operator is in compliance. If a 

pultrusion line exceeds the 30-minute limit, rather than be shut down, the rule would allow the 

owner or operator to average it with other pultrusion lines to demonstrate 60% emission 

reduction. The pultrusion line that exceeded the 30 minute access limit would be entered into the 

averaging equation as an "uncontrolled" line and other lines would have to be "over-controlled." 

Mr. Barker suggested that the averaging provision be based on a 12-month rolling average. 

With regard to large parts (such as beams where there are 1,000 feeds and a 16-inch cross 

diameter), EMr. Barker requested an exemption from the rule. He stated that such parts require 

constant operator access and there is no demonstrated control for such large parts. He felt the 

concept of controlling air flow as a control measure was not very practical. 

An EPA representative asked for clarification between direct die injection and preform 

injection. EMr. Barker explained that with direct die injection the resin injection takes place only in 

the die, but with preform injection, there is a chamber around the die in which the resin is injected. 

The EPA representative then indicated that the intent ofthe proposed rule was not to have 

excluded preform injection. 

Industry representatives indicated that they will be submitting formal written comments on 

the proposed rule and thanked EPA representatives and contractors for their time. 

? 
P.11 

ATTACHMENT 1 

John Schweitzer 

Composites Fabricators Association 

/s-
Presentatio

n on the 

Proposed NESHAP for Composites 

Composites Fabricators Association 

September 7,2001 

Research Triangle Park, NC 

Proposed NESHAP 

EPA has proposed that certain 

companies achieve 95% control of 

HAP emissions by use of capture 

and oxidation control technologies. 

We know that EPA does not intend 

to threaten the economic vitality of 

these companies. 

Proposed NESHAP 

To make sure that 95% capture and 

control is achievable, EPA must 

answer the following questions: 

A. Is 100% capture feasible for the 

full range of operations? 

B. What are the real costs of C&C? 

C. Is C&C affordable? 

D. Is C&C better than pollution 

prevention? 

X 

A. Is 100% capture feasible for the full 

range of operations? 

• An engineer retained by CFA visited 

18 actual and typical open molding 

operations, and designed enclosures 

that would capture the maximum 

amount of emissions, while still 

allowing the necessary movement of 

molds, products, workers, and 

material, and protecting workers 

from heat stress and styrene 

exposures. 

• On average, the enclosures for these 

18 plants would capture only 80% 

of emissions. 

A. Is 100% capture feasible for the full 

range of operations? 

• Compared to our 18 case studies — for 

which we have provided all the data — 

EPA's proposal is based on only two 

plants that supposedly achieve 100% 

capture. We have not been able to evaluate 

the controls or operations at diese plana. 

• For these two plants, EPA needs to fully 

answer the following: 

1

 What are the worker exposures to heat stress and 

styiene? Precisely what measures are taken to 

protect workers? 

How ire molds, products, workers, and material 

moved into, within, and oot ofthe enclosures? 

Kow precisely do the enclosures continuously meet 

the fall criteria of Mediod 204? 

How would these facilities make larger parts tike 

R/V sidewafls or underground gasoline storage 

tanks? 

Precisely bow would exisanj plants be retrofitted to 

resemble these two "tnodetrf" How much would 

this cost? 

A. Is 100% capture feasible for the full 

range of operations? 

• EPA has pointed to a technical paper 

describing one actual and one theoretical 

use of total enclosures for coating of 

aircraft and ships. However, the 

enclosures described in the paper could 

never be used to manufacture 

composites, because: 

• They would oot allow multiple large products to be 

made simultaneously, as required for profitable 

composites manufacturing. 

< They would not allow an entire product to be made 

in one step, as required for molding composites 

products. 

• They require the use of recirculation and/or 

respirators, which are not practical for composites 

They would result in overexposure of workers lo 

airborne contaminants. 
B

. What are costs of C&C? 

EPA's current cost analysis employs 

very inaccurate estimates of 

enclosure exhaust concentration, 

enclosure size, and operating hours. 

Industry is providing updated 

information in these areas so that 

EPA can improve its cost estimates. 

^ 

B. What are costs of C&C? 

CFA will provide the results of an 

industrial hygiene survey of four 

actual and typical composites 

molding operations, where the 

average exhaust concentrations 

ranged from 8.4 to 70 ppm, while the 

average occupational exposures 

ranged from 22.3 to 35.5 ppm. 

- The industrial hygicnist determined that 

the exhaust concentrations could not be 

increased without unacceptably 

increasing the risk of heat stress or 

exposure to styrene. 

B. What are costs of C&C? 

CFA will also provide data from the 

18 case study plants showing that 

enclosures would range in size from 

14,000 sq. ft. to over 250,000 sq. ft., 

and that operating hours vary 

between 40 hours per week to 

continuous operation. 

For EPA's cost estimates, if a plant 

was assumed to exhaust air at 

SOpppm instead of lOOppm, and was 

assumed to operate 8 hours/day 

instead of 24, the control cost would 

increase by a factor of 6. 

C. Is C&C affordable? 

Stuart Sessions of Environomics has 

studied EPA's affordability analysis, 

and has also prepared an 

independent assessment of 

affordability. The results of Stuart's 

analyses will be provided by CFA in 

our written comments. 

D. Is C&C better than P2? 

• Pollution prevention can achieve 

emission reductions comparable to 

those that can realistically be 

achieved with capture and control. 

• C&C-8M4x95% = 76% 

• P2 = 65% on average 

- For many ofthe sources that would be 

required tinder the proposed rule to employ 

capture and control, P2 will result in 

emission reductions of 70-80%. 

• Pollution prevention, unlike capture 

and control, can be afforded by all 

composites manufacturers. 

• Pollution prevention has energy-

usage and worker protection benefits, 

while capture and control is worse 

for both. 

Proposed NESHAP 

To make sure that 95% capture and 

control is achievable, EPA must 

answer the following questions: 

A. Is 100% capture feasible for 

the full range of operations? 

B. What are the real costs of 

C&C? 

C Is C&C affordable? 

D. Is C&C better than pollution 

prevention? 

In preparing the final rule, EPA 

needs to answer these questions 

fully and fairly, using the best 

available infonnation. 

TJ 
P.M 

ATTACHMENT 2 

Stuart Sessions 

Environmetrics 

\3 
AFFORDABILITY OF 95% CAPTURE/CONTROL REQUIREMENT 

1. Compliance cost estimates for individual facilities are the starting point in analyzing 

affordability 

• Detailed analysis of sample facilities suggests costs will be at least 2.4x greater than 

EPA estimates 

2. EPA's Economic Impact Analysis (EIA) does not analyze the affordability ofthe 95% 

requirement. The EIA simply assumes the requirement is affordable. 

• While EPA could alter the EIA model somewhat to analyze affordability, the model as 

a whole is very ambitious and complex. Data do not exist to implement it 

• Where data are lacking, many of EPA's assumptions are incorrect 

oi 
AFFORDABILITY OF 95% CAPTURE/CONTROL REQUIREMENT 

3. We suggest two simpler, more common-sense approaches to affordability analysis 

• The facilities subject to the 95% requirement will face much higher compliance costs 

per pound of product than the great bulk ofthe industry. These facilities will have to 

absorb these costs. The increased costs will reduce these facilities' profits sharply, 

threatening their viability 

^ • Detailed financial analysis of 10 facilities shows serious affordability problems for all 

of them. Our judgment is that at least 7 of them would more likely close than pay the 

costs of capture and control 

TJ 

CD 
^ • 

ESTIMATED COSTS FOR 95% CAPTURE/CONTROL 

Comparison of EPA and CFA cost estimates for 95% capture/control for 12 facilities likely 

subject to the requirement: 

• CFA estimates costs at least 2.4x greater than EPA 

Why "at least"? Discuss: MRR costs, Kohler 

Why the difference in cost estimates? 

CFA used EPA's cost curves, annualization assumptions, indirect cost factors 

Differences regarding air flows, concentrations, operating hours, energy costs 

Differences in emissions and production from EPA's 1997 estimates to current 

actual 

TJ 
Comparison of Cost Estimates for Capture and Oxidation 

Facility 

Aker Plastics, Plymouth, IN 

Aqua Glass, Adamsville, TN 

Aqua Glass, Klamath Falls, OR 

MFG, Union City, PA 

Strongwell, Bristol, VA 

Xerxes, Anaheim, CA 

Xerxes, Hagerstown, MD 

Xerxes, Sequin, TX 

Xerxes, Tipton, IA 

Three Additional Facilities 

Total for all facilities 

Facility 

Aker Plastics, Plymouth, IN 

Aqua Glass, Adamsville, TN 

Aqua Glass, Klamath Falls, OR 

MFG, Union City, PA 

Strongwell, Bristol, VA 

Xerxes, Anaheim, CA 

Xerxes, Hagerstown, MD 

Xerxes, Sequin, TX 

Xerxes, Tipton, IA 

Three Additional Facilities 

Total for all facilities 

Capital Costs 

EPA 

$2,379,856 

$10,775,909 

$1,361,105 

$1,061,633 

$1,526,576 

$967,519 

$595,523 

$595,523 

$592,154 

$2,884,046 

$22,739,844 

CFA 

$5,000,000 

$11,780,542 

$3,150,777 

$3,894,186 

$3,914,000 

$2,744,100 

$2,669,100 

$1,833,900 

$2,276,500 

$10,387,358 

$47,650,463 

Annual O&M Costs 

EPA 

$123,036 

$503,511 

$104,632 

$71,242 

$80,788 

$39,224 

$23,178 

$23,178 

$22,747 

$188,750 

$1,180,286 

Differences in Cost Estimates (Relative 

Capital 

Total 

$2,620,144 

$1,004,633 

$1,789,672 

$2,832,553 

$2,387,424 

$1,776,581 

$2,073,577 

$1,238,377 

$1,684,346 

$7,503,312 

$24,910,619 

Costs 

Percent 

210% 

109% 

231% 

367% 

256% 

284% 

448% 

308% 

384% 

360% 

210% 

CFA 

$400,000 

$1,535,022 

$335,132 

$444,006 

$942,511 

$396,729 

$323,529 

$219,221 

$273,291 

$1,025,794 

$5,895,235 

Annualized Total Costs 

EPA 

$586,619 

$2,676,301 

$350,112 

$255,374 

$313,754 

$181,549 

$117*104 

$117,104 

$115,928 

$689,589 

$5,403,434 

»to EPA Estimates) 

Annual O&M Costs 

Total 

$276,964 

$1,031,511 

$230,500 

$372,764 

$861,723 

$357,505 

$300,351 

$196,043 

$250,544 

$837,044 

$4,714,949 

Percent 

325% 

305% 

320% 

623% 

1167% 

1011% 

1396% 

946% 

1201% 

543% 

499% 

CFA 

$1,111,888 

$3,212,306 

$783,732 

$998,450 

$1,499,777 

$787,427 

$703,549 

$480,327 

$597,413 

$2,504,720 | 

$12,679,589 | 

Annualized Total Costs 

Total 

$525,269 

$536,005 

$433,620 

$743,076 

$1,186,023 

$605,878 

$586,445 

$363,223 

$481,485 

$1,815,131 

$7,276,155 

Percent 

190% 

120% 

224% 

391% 

478% 

434% 

601% 

410% 

515% 

363% 

235% 
°%y 

EPA's ECONOMIC IMPACT ANALYSIS - MERCHANT VS. CAPTIVE 

EPA's EIA does not analyze the affordability ofthe 95% requirement for the facilities to 

which it will apply. The EIA simply assumes that the requirement is affordable for them 

• 

• 

• 

The 95% requirement applies nearly exclusively to large business facilities > 100 TPY 

(28 of 29 facilities) 

EPA assumes that all large business facilities are captive 

EPA assumes that all captive facilities will absorb the compliance costs, suffer an 

equivalent reduction in profits, and stay in business. EPA does not analyze the 

possibility of closing these facilities (outsourcing) 

EPA does analyze affordability for facilities that are merchant 

y 

co 
EPA's ECONOMIC IMPACT ANALYSIS - MERCHANT VS. CAPTIVE 

-s> 

We disagree with EPA's assumptions: 

• Ofthe 29 facilities requiring oxidation, 24 are clearly merchant, not captive. 2 more 

are both merchant and captive. 1 is debatable. See next page 

• Many (most?) facilities that might be thought of as captive also produce products for 

the market generally 

• Owners of captive facilities do seriously consider outsourcing. RV industry example 

EPA should drop the captive/merchant distinction. Captive RPC producers are part of 

market supply. Owners of captive operations are part of market demand 

While EPA could alter the EIA model somewhat to fix this, the remainder ofthe model has 

serious problems also 

Tl 

S3 

O 
EPA's Estimates for the 29 Facilities Needing Oxidation 

Sb 

o. 

I 

Facility Name 

AKER Plastics Co.. Inc. (Plymouth, N Oak Rd) 

Aqua Glass Corp. (Adamsville) 

Aqua Glass Corp. (Klamath Falls) 

Dixie-Pacific Manufacturing Co. 

Eljer Plumbingware (Wilson) 

Fleetwood (Decatur - formerly Gold Shield) 

Fleetwood (Fontana - formerly Gold Shield) 

Holiday Rambler Corp., Plant 36 and 37 

MFG - Molded Fiber Glass Co. (Union City) 

Morrison Molded Fiber Glass (Bristol) 

R. D. Werner Co., Inc. 

Sequentia, Inc. (Grand Junction) 

Shakespeare Co. 

Sherman Poles 

Syntechnics 

S.W.C. Industries, Inc. (Swirl-Way Div.) 

Tomkins - LASCO Bathware (Anaheim) 

Tomkins - LASCO Bathware (Cordele) 

Tomkins - LASCO Bathware (Elizabethtown) 

Tomkins - LASCO Bathware (Lancaster) 

Tomkins - LASCO Bathware (Moapa) 

Tomkins - LASCO Bathware (South Boston) 

Tomkins - LASCO Bathware (Three Rivers) 

Tomkins - LASCO Bathware (Yelm) 

Tomkins - LASCO Panel Products (KY) 

United Technologies Motor Systems 

Universal-Rundle Corp. (New Castle) 

Universal-Rundle Corp. (Ottumwa) 

Universal-Rundle Corp. (Union Point) 

SUBTOTAL for Oxidation Required 

Resin 

3,185.1 

11,313.0 

1,205.7 

1,298.0 

1,205.7 

2,343.0 

1,074.4 

867.0 

3,359.8 

4,428.6 

5,288.9 

12,644.9 

2,944.9 

2,487.5 

1.154.3 

1,205.7 

3,896.0 

2,446.6 

2,665.8 

2,815.3 

7,854.6 

3,249.5 

3,500.5 

3,357.6 

13,592.2 

6,052.7 

4.192.5 

3,093.0 

1,710.0 

114,432.8 

Materials Usage (TPY) 

Reinforce. 

702.2 

3,490.2 

507.1 

1,662.9 

507.1 

666.2 

394.3 

190.8 

161.6 

7,334.3 

9.086.6 

5,246.3 

2,978.9 

3,089.2 

687.5 

507.1 

675.0 

415.0 

655.0 

356.0 

3,974.0 

709.0 

584.0 

575.0 

4,396.8 

0.0 

765.6 

804.0 

476.0 

51,597.8 

Filler 

2,378.7 

4,000.0 

1,062.4 

41.0 

1,062.4 

313.1 

417.3 

59.2 

0.0 

1.256.9 

230.3 

2,803.3 

601.6 

0.0 

0.0 

1,062.4 

4,890.8 

3,092.2 

3,304.6 

3,564.7 

9,844.6 

4,078.6 

4,386.6 

4,215.6 

3,479.0 

16,246.9 

3,256.6 

3,276.0 

1,347.0 

80,271.7 

Est production in mlln lbs/yr 

Scrap 

997.0 

3,079.7 

451.8 

180.1 

451.8 

511.0 

305.6 

177.3 

180.2 

601.5 

623.3 

2,195.9 

383.4 

334.6 

296.4 

451.8 

1,548.5 

975.1 

1,081.9 

1,102.6 

3,533.0 

1,325.7 

1,386.3 

1,337.2 

2,282.7 

702.6 

1,346.3 

1,169.9 

574.9 

29,588.0 

433.4 

Pre-MACT 

Emissions 

(TPY) 

377.0 

1524.0 

164.4 

253.5 

164.0 

356.8 

128.4 

112.6 

112.3 

102.0 

198.3 

247.8 

166.3 

520.5 

139.0 

117.3 

655.6 

413.2 

235.7 

263.7 

1286.7 

370.2 

589.1 

257.9 

137.2 

175.4 

1142.1 

503.8 

203.0 

10.918.0 

Small 

Business? 

1 

1 

Oxidation 

Required? 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

I 

EPA Cost Ests. ($1000) 

Capital 

Cost 

2,380 

10,776 

1,361 

417 

1,360 

2.172 

1,103 

1,096 

1,062 

Annual 

O&M Cost 

123 

504 

105 

18 

104 

115 

88 

76 

71 

No costs for c/c for 

these 2, why not? 

1,622 

3,575 

428 

1,158 

1,160 

3,761 

2,534 

427 

432 

7,471 

485 

3,424 

1,877 

1,209 

1,267 

7,001 

3,017 

1,574 

64,149 

162 

186 

22 

88 

79 

215 

134 

143 

158 

425 

121 

193 

161 

127 

104 

374 

166 

127 

4.189 

Annual 

Total 

587 

2676 

350 

95 

250 

544 

273 

267 

255 

314 

309 

462 

708 

103 

299 

280 

975 

633 

188 

204 

1951 

173 

881 

512 

347 

340 

1808 

766 

415 

Merchant 

or 

Captive? 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Both, RV Parts 

Both, RV Parts, Tanks 

Captive?, RV Parts 

Merchant, Truck Parts 

Merchant, Ladder rail 

?, Ladder Parts 

Merchant, Panels 

Merchant, Fishing 

Rods 

Merchant, Utility Poles 

Merchant, Tanks, RR 

Car Covers 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Panels 

Unknown, Possibly 

Captive 

Merchant, Bathware 

Merchant, Bathware 

Merchant, Bathware 

16,9651 
EPA's ECONOMIC IMPACT ANALYSIS - OVERVIEW 

EPA's analysis and model are very ambitious 

• Attempt to simulate production costs and supply functions for every regulated 

merchant RPC producer, demand for 10 different RPC product classes, price and 

output changes in each market, response ofeach producer to their particular 

compliance costs, etc. Huge simultaneous equation model 

• Commendable attempt to estimate price and output changes rather than assume them. 

Consistent with OAQPS Economic Analysis Resource Document 

We don't believe this approach can realistically be implemented for this industry 

• RPCs encompass an incredibly diverse set of products 

• EPA has virtually none ofthe data needed to implement the model. Nearly all 

relationships are assumed. Many assumptions are inaccurate 

• What data EPA has is old and often inaccurate 

|N> 
EPA's EIA - SOME OF THE PROBLEMS 

Assumption that each ofthe 10 market segments produces a reasonably homogeneous RPC 

product, with every producer in a market segment receiving the same price per pound for 

their product 

• Vastly different products are subsumed within "land transportation" or within 

"corrosion resistant products", with widely varying prices, characteristics, production 

^ requirements, etc. 

r. 

Process for identifying the highest cost producer in each market segment 

• EPA's process in fact identifies only the facility that uses the highest proportion of 

reinforcement ($1.25/lb)/lowest proportion of filler ($.09/lb) in making its products 

Assumption that the price ofthe RPC product for the entire market segment is given by the 

production cost ofthe supposed highest cost producer in that segment 

• In fact, the supposed highest cost producer (using mostly reinforcement) likely makes 

a completely different product from another producer using a different materials mix 

ro 

co 
u 

EPA's EIA - SOME OF THE PROBLEMS 

Assumption that every merchant producer has an upward sloping supply function as given 

by the "generalized Leontieff technology' ,« 

• In fact, most producers can produce substantially more output than they currently do, 

at constant or declining marginal costs, by adding shifts or increasing operating hours 

Assumption that every merchant producer earns the same 4.4% profit margin on their 

revenues 

• Affordability ofthe 95% requirement varies across producers as a function of: 1) 

Their particular compliance costs; relative to 2) Their pre-regulatory profitability. 

This assumption eliminates any variability in (2), thus ignoring one ofthe primary 

factors that makes the requirement affordable for some producers and not for others 

10 

£ 
EPA's EIA - SOME OF THE PROBLEMS 

Assumption that a producer will decide to comply if the facility's post-regulation revenues 

are sufficient to cover total costs (variable plus fixed) 

• A producer will regard compliance as a long-term investment decision. The producer 

will decide to comply if revenues are sufficient to cover costs and provide an adequate 

^ return on investment 

- ^ 

Assumption that market supply elasticity is 1 

• No evidence is cited. We would assume an elasticity of greater than one, given: 1) 

The ease of expanding output with additional operating hours; and 2) The extremely 

low barriers to entry in the industry 

Assumption that market demand elasticity is -0.5 

• No evidence is cited. We would assume an elasticity of less than -1. Most major RPC 

products face intense competition from other materials. Examples: bathware, USTs 

n 

ro 

Ol 
EPA's EIA - SUMMARY 

Very ambitious methodology requires vast amount ofdata, virtually none of which EPA 

has 

EPA's conclusions depend on a series of assumptions made when data is lacking. Many 

assumptions appear incorrect 

We believe that affordability should be evaluated using a much simpler approach, relying 

^ on available data and avoiding the need for unfounded assumptions 

Also, note that the EIA does not address or support EPA's argument that limited access to 

capital justifies relaxed capture/control threshold for facilities owned by small businesses 

12 

TJ 

S3 
A SIMPLER ASSESSMENT OF AFFORDABILITY 

EPA's estimates show sharply different compliance cost burdens for different groups of 

RPC producers: 

SLi 

RPC Producer Group 

Thermoplastic producers 

LB>100 TPY; SB>250 TPY 

All other RPC producers 

Total 

Proposed Req't 

None 

95% C/C 

Pollution 

prevention 

xxx 

Annual 

Production 

(million pounds) 

1729 

433 

976 

3138 

% of Total 

55% 

14% 

3 1% 

100% 

Ann. Compliance 

Cost ($ in 

millions) 

zero 

$16,965 

$9,061 

$26,026 

Compliance 

Cost/lb 

product 

zero 

$.0392 

$.0093 

$.0083 

13 
A SIMPLER ASSESSMENT OF AFFORDABILITY 

• Most ofthe industry (thermoplastic producers) will incur no compliance costs 

• Another large segment ofthe industry (all others) will incur modest compliance costs 

(0.9 cents/lb of product, relative to EPA's estimated average price per pound of $3.48, 

or 0.27% of revenues) 

^ • A small portion ofthe industry (14%) - facilities facing the 95% requirements - will 

incur much higher compliance costs (3.9 cents/lb of product, or 1.13% of revenues) 

• In the highly competitive national market for RPCs, prices will rise very little as a 

result ofthe regulation. The large volume of unaffected and minimally affected 

producers will keep prices from rising. The producers facing the much higher costs to 

meet the 95% requirement will have to absorb virtually all of their costs 

14 

ro 

oo 
• 

• 

A SIMPLER ASSESSMENT OF AFFORDABILITY 

Note that CFA believes costs to meet the 95% requirement will be at least 2.4 times 

what EPA estimates. If so, costs to meet the 95% requirement would be at least 9.4 

cents/lb of product, or at least 2.7% of revenues 

Relative to an average profit margin of 4.4% (EPA estimate), compliance costs to 

meet the 95% requirement would then consume 62% of average profits for this 

already low-profitability industry 

This would likely pose serious affordability problems for most ofthe facilities 

affected by the 95% requirement 

15 

TJ 

ro 

co 
CFA's AFFORDABILITY CASE STUDIES 

3* 

For 10 RPC facilities with emissions actually or likely exceeding 100 TPY and owned by 

large businesses, we compared estimated annualized compliance costs for capture/control 

against financial capability (from recent detailed survey) 

• Total annualized costs compared with annual facility revenues 

• Total annualized costs compared with annual facility profits 

• Total required capital investment compared with historical capital investment levels at 

the facility 

Conclusions: 7 or more ofthe 10 representative facilities will more likely close than pay 

the costs of capture and control 

• Capture/control poses affordability concerns for all 10 facilities 

• Clearly not affordable for 4 facilities 

• Probably not affordable for 3 facilities 

• Possibly not affordable for 3 facilities 

16 

co 

o 
P.31 

9/4/01 

Capture and Control Costs Relative to Annual Revenues, Profits and Capital Expenditures 

For 100+ TPY Facilities Owned by Large Businesses 

Facility 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

TAC as a % of 2000 

Annual Composites 

Revenues 

X 

© 

0 

X 

XX 

0 

X 

© 

X 

© 

TAC as a Multiple of 

2000 Annual 

Composites Profit 

XXX 

© 

XX 

xxx 

xxx 

© 

xxx 

X 

© 

© 

TCI as a Multiple of 5 Yr 

Avg Annual Capital 

Expenditures 

XXX 

X 

© 

xxx 

© 

© 

xxx 

X 

xxx 

© 

OVERALL 

IMPACT 

XX 

© 

X 

XX 

XX 

© 

XX 

X 

X 

© 

Key: 

Total Annual Cost as Total Annual Cost as a Total Capital Investment 

a % of Composites Multiple of Composites as a Multiple of 5 yr. Avg. 

Annual Revenues Annual Profit Annual Capital Expenditures 

0 

© 

X 

XX 

xxx 

< 3 % 

3 - 5 % 

5 -10 % 

10 - 20 % 

> 20 % 

<0.5 

0.5 -1.0 

1.0-2.0 

2.0 - 5.0 

>5.0 

<1 

1-5 

5-10 

10-15 

>15 

Probably affordable 

Significant burden; 

possibly not affordable 

Probably not affordable 

Clearly not affordable 

Impossible 

For 4 ofthe 10 facilities, capture and oxidation is clearly not affordable. 

For 3 of the 10 facilities, it is probably not affordable. 

For 3 ofthe 10 facilities, it is a significant burden and possibly not affordable. 

J© 
A FINAL ECONOMIC CONCERN 

Affordability depends fundamentally on a comparison between a facility's profitability and 

the compliance costs it faces 

• This comparison will be largely unaffected by whether the facility is owned by a large 

business or a small business 

• 

• 

No rational business, large or small, will make a compliance investment in a facility 

V^ that will not be sufficiently profitable 

Access to capital, for an economically non-productive investment, is a concern 

whether the facility is owned by a small business or a large one 

18 

S3 
P.33 

ATTACHMENT 3 

Charley Brown 

Aqua Glass Corporation 

39-
AQUA GLASS CORPORATION 

Comments for EPA Hearing 

September 7, 2001 

1. Overview 

2. Add-on Control Evaluation 

3. P2 Experience 

4. Problems with Proposed Rule 

5. Conclusions and Impact 
AQUA GLASS CORPORATION 

OVERVIEW 

• Second largest tub and shower manufacturer in the U.S. 

> Produce one of every four gelcoat tubs and showers 

• Subsidiary of Masco Corporation 

> Managed autonomously as if stand alone company 

> Sells product to wholesalers and retailers, not to Masco 

• Three factories located in small communities - our biggest plant is in Adamsville, TN which 

has about 1800 residents in a county which has 20,000 total residents. 

Adamsville. TN McEwen. TN Klamath Falls. OR Total 

Annual Payroll $23 Million $5 Million $5 Million $33 Million 

Approx. Headcount 1,000 200 200 1,400 

'00 Annual HAP Emissions 727 TPY 429 TPY 107 TPY 1,263 TPY 

• These rules would have a potentially devastating impact on the communities in which we 

operate. 

• Over 1,200 suppliers 

> Purchases of over $125 million annually 

(j\ 
AQUA GLASS CORPORATION 

Add-on Control Evaluation 

te 

Estimated Actual Costs of Add-on Controls at Aqua Glass 

Total capital investment ($) 

Annual cost of controls 

($/year at PTE) 

Annual cost of controls 

($/year at year 2000) 

Cost effectiveness of 

controls ($/ton HAP 

removed at PTE) 

Cost effectiveness of 

controls ($/ton HAP 

removed year 2000) 

Adamsville 

$11,780,600 

$3,392,600 / 

year 

$ 3,452,200 / 

year 

$2,220/ton 

$ 5,020 / ton 

Klamath Falls 

$3,150,800 

$917,600/year 

$ 847,900 / year 

$ 6,640 / ton 

$ 8,430 / ton 

McEwen 

$6,177,554 

$l,723,571/year 

$l,728,471/year 

$2,599/ton 

$ 4,797/5on 

'Total;: '"'./I 

$21,108,954 

$6,033,771/year 

$6,028,571/year 

$3816/ton 

$6075/ton 

> The total capital investment represents several years of historical operating profits 

> The annual operating costs represent a major portion of annual profits 

> Add-on controls are prohibitively expensive 

If add on controls become mandatory as proposed, Aqua Glass will not be able to 

operate its plants at the reduced profit margins which the regulations would imply. 
Ui 

-6"^ 

AQUA GLASS CORPORATION 

P

2

 Experience 

Aqua Glass and the State of Oregon Department of Environmental Quality (DEQ) have 

proven that P2 works 

> 6 year, $4 million development program 

> 81% reduction in per tub emissions certified by stack tests 

> No add on controls used 

Steady P2 Success: Emission Rates per Unit at Klamath Falls 

Test Date 

Emission 

Rate 

(lbs/unit) 

Percentage 

Redaction 

of Baseline 

March 

1995 

8.84 

N/A 

May 

1997 

4.38 

50.5% 

February 

1998 

3.07 

65.3% 

December 

1998 

2.59 

70.7% 

December 

1998 

2.09 

76.4% 

February 

1999 

1.84 

79.2% 

October 

2000 

1.65 

81.3% 

Title V Permit issued in 2001 

DEQ repeatedly tells the Aqua Glass success story. 

TD 

CO 
AQUA GLASS CORPORATION 

Klamath Falls Facility Emissions Reduction By P2 

c * 

^ 

Gelcoat #1 

Gelcoat #2 

Foam 

Covercoat 

First Chop #1,3,5 

Base Chop 

Mar-55 

Styrene Styrene 

May-97 

Styrene Styrene 

Feb-98 

Styrene Styrene 

12/03/98 

Styrene Styrene 

12/04/98 

Styrene Styrene 

02/23/99 

Styrene Styrene 

Emission Ra mission Rai mission Rai mission Ra mission Ra' mission Rai mission Ra mission Ra mission Ra mission Rai mission Rai mission Rat 

Stack 1 

Stack 2 

Stack 3 

Stack 4 

Stack 5 

Stack 6 

Heat Rooms/Rollii Stack 7 

Mix Room 

Acrylic #1 

Acrylic WI 

First Chop #2 

Stack 8 

Stack 9 

Stack 1 

Stack 1 

Covercoat Dead Zc Stack 1 

Maintenance 

Finishing 

Warehouse 

Production 

Receiving 

Units Per Test 

Fan A 

FanB 

FanC 

FanD 

FanE 

I 

(lb/shift) 

228.25 

223.19 

16.39 

185.46 

493.68 

138.20 

68.75 

32.01 

0.00 

0.00 

0.00 

0.00 

19.25 

24.53 

22.22 

18.59 

23.32 

1493 84 

(lb/unit) 

1.351 

1.321 

0.097 

1.097 

2.921 

0.818 

0.407 

0.189 

0.000 

0.000 

0.000 

0.000 

0.114 

0.145 

0.131 

0.110 

0.138 

8.839 

169 

(lb/shift) 

197.20 

219.30 

9.35 

59.50 

255.00 

71.40 

26.35 

10.20 

64.60 

38.25 

25.50 

75.65 

5.95 

9.35 

4.25 

4.25 

7.65 

1083.75 

(lb/unit) 

0.797 

0.886 

0.038 

0.240 

1.030 

0.288 

0.106 

0.041 

0.261 

0.155 

. 0.103 

0.306 

0.024 

0.038 

0.017 

0.017 

0.031 

4.378 

247.5 

(lb/shift) (lb/unit) 

215.90 0.837 

136.00 0.527 

7.65 0.030 

41.65 0.161 

128.35 0.497 

91.80 0.356 

30.60 0.119 

7.65 0.030 

33.15 0.128 

22.95 0.089 

15.30 0.059 

42.50 0.165 

2.55 0.010 

5.95 0.023 

2.55 0.010 

3.40 0.013 

.5.10 0.020 

793.05 3.074 

258 

(lb/shift) 

91.80 

104.55 

8.50 

36.55 

118.15 

40.80 

24.65 

14.45 

31.45 

15.30 

19.55 

32.30 

2.55 

0.00 

5.95 

0.00 

1.70 

548.25. 

(lb/unit) 

0.434 

0.494 

0.040 

0.173 

0.559 

0.193 

0.117 

0.068 

0.149 

0.072 

0.092 

0.153 

0.012 

0.000 

0.028 

0.000 

0.008 

2.592 

211.5 

(lb/shift) 

110.30 

106.50 

219.80 

37.50 

474.10 

219| 

(lb/unit) 

0.504 

0.486 

0.943 

0.161 

2.094 

233 

(lb/shift) 

89.4 

75.1 

15.5 

24.3 

58.3 

23.5 

32.6 

6.4 

42.8 

27.2 

24.7 

26.7 

1.9 

2.2 

2.2 

3.2 

2.8 

458.8 

(lb/unit) 

0.353 

0.296 

0.061 

0.096 

0.230 

0.093 

0.129 

0.025 

0.169 

0.107 

O.097 

0.105 

0.007 

0.009 

0.009 

0.013 

0.011 

1.810 

253.5 
AQUA GLASS CORPORATION 

KLAMATH FALLS P2 PROJECT 

6 Years of investment and intense work with suppliers 

• Scrap reduction 

• Control of finished product weight 

• Non or low HAP based materials in other operations 

• Increased process control 

• Temperature-controlled spraying 

• Controlled-spraying techniques 

r • New resin and gelcoat formulations 

^^ • Use of vapor-suppressed resins 

• Increased filler contents 

• Ongoing assistance from resin suppliers to deliver lower styrene-content resins without sacrificing 

product performance 

• Lower styrene-content gelcoats - 30% less styrene than in 1993 

• Higher viscosity and lower styrene content laminating resins 

• Four distinct generations of spray equipment 

in order to apply the knowledge gained across all facilities. 

Mandatory add-on controls would totally stop this type of development because it is the large companies 

that drive it. In addition, add-on controls would penalize the success we have achieved at Klamath Falls. 

CO 
CM 

AQUA GLASS CORPORATION 

Problems with the Proposed Rule 

1. Mandatory add-on controls are bad for Aqua Glass and for the Industry. 

> Additional P2 development would be stopped 

> Energy usage would double (111% increase in 2002 for Adamsville) 

2. Mandatory add-on controls are bad for the factory workers 

> Higher PPM HAP levels are needed to "fuel" the burners 

• EPA's assumed 100 ppm HAP would violate Tennessee OSHA standards 

• "Space suits" are not an option due to size of product/mobility required 

> Method 204 requires a closed building which would cause unbearable heat 

• Even with an open building, heat exhaustion is a problem. This is more 

than an OSHA problem; it is a people problem. 

3. The proposed rule contains simplified assumptions which in Aqua Glass9 case are 

simply wrong or rely on data estimates which lead to bad cost analysis. 

> Exhaust air flows 

> Exhaust concentrations 

> Part size 

> Production throughput 

> Worker and part access 

> Peak vs. actual operating rates 

7 

V 
AQUA GLASS CORPORATION 

Problems with the Proposed Rule (Cont'd) 

> The 95% C&C controls make no sense regardless of how many are 

employed, and our lawyers tell us that such distinctions between businesses 

are legally dubious. 

4. The proposed rule makes bad comparisons. 

> Open molded FRP process is not similar to a spray finishing process. 

-^ > Divisions of larger corporations sell to the same customers as small 

independent companies and have investment criteria that are very similar. 
-fc. 

AQUA GLASS CORPORATION 

Conclusions and Impact 

1. If the rule is implemented as proposed, it will cripple Aqua Glass. 

2. The proposed rule is: 

> bad for Aqua Glass and for the Industry 

> bad for the workers 

> full of errors 

> full of faulty financial analysis 

> blind to the impact on businesses and people 

> legally falls short of its mandate 

All ofthe above problems are resolved by eliminating the "above the floor" 

add-on controls requirements and relying on our successful and proven P2 

approach, a direction which Aqua Glass strongly advocates. 

ro 
P.43 

ATTACHMENT 4 

Craig Peterson 

Xerxes Corporation and Proform Corporation 

4% 
P.44 

COMMENTS ON PROPOSED MACT 

FOR REINFORCED PLASTICS/COMPOSITES 

Presented to: 

U.S. EPA 

Research Triangle Park 

September?, 2001 

Xerxes Corporation 

Proform Company, LLC 

By: Craig Peterson 

Vice President and 

General Counsel 

^3 
P.45 

I. Background 

A. Xerxes Corporation and a sister company, Proform Company, LLC, 

are both owned by a common Owner. That Owner has no other 

reinforced plastic/composites companies. 

B. Xerxes Products 

1. Underground Storage Tanks 

a. Female Molds 

• Flow Choppers 

• Hand lay up 

b. Part Size 

• Up to 12-ft. wide x 12-ft. high x 69-ft. long 

2. Above Ground Tanks 

a. Male Molds 

• Flow Chop 

• Hand lay up 

• Filament Winding 

b. Part Size 

• Up to 14-ft. wide x 14-ft. high x 45-ft. long 

3. Five Manufacturing Plants: 

a. Anaheim, California 

• Above Ground and Underground Storage Tanks 

• 11 molds 

• 74 employees 

b. Hagerstown, Maryland 

• Underground Storage Tanks 

• 12 molds 

• 70 Employees 

2 
P.46 

c. Seguin, Texas 

• Underground Storage Tanks 

• 10 Molds 

• 39 Employees 

d. Tipton, Iowa 

• Underground Storage Tanks 

• 9 Molds 

• 50 Employees 

e. West Memphis, Arkansas 

• Underground Storage Tanks 

• 4 Molds 

• 17 Employees (loaned employees from Proform) 

f. Corporate Office, Minneapolis, Minnesota 

• 36 Employees 

C. Proform Products 

1. Barge Covers -

Part Size: 23-ft. long x 30-ft. wide x 4-1/2 ft. high 

2, Molds 

a. Motorized carriages and scaffolding are 28-ft. 6 in. long 

x 36-ft. 4 in. wide x 8-ft. high 

b. Motorized carriages travel, station to station inside plant • 

Area covered: 138-ft. long x 100-ft. wide x 25-ft>high 

II. Xerxes and Proform are Small Businesses 

A. Xerxes 

• 269 employees 

B. Proform 

• 78 employees (including the 17 employees loaned to Xerxes) 

3 
P.47 

1 

C. Xerxes and Proform Are Regulated As Large Businesses 

SBA Definition of Small Business - less than 500 employees 

• Common Ownership must include'hotels, farm implement 

sales, and other non composites businesses 

D. Large Businesses Would Be Subject to 100-Ton Per Year Above-theFloor MACT Threshold 

Plants have or will exceed 100 ton per year threshold 

III. Kev Points 

A. Xerxes and Proform cannot afford the 95% capture and control 

requirement. 

B. Xerxes and Proform produce very large parts in very large rooms that 

are not compatible with Method 204. 

C. Xerxes and Proform are actually small businesses, but would be 

regulated as "large businesses" under the proposed MACT Rule. 

IV. Xerxes and Proform Cannot Afford the 95% Capture and 

Control Requirement 

A. Stuart Sessions: Environomics. Inc.. see analysis of cost of controls 

and affordability 

1. Xerxes and Proform cannot afford the cost of add-on controls. 

2. EPA already agrees that small businesses cannot afford add-on 

controls. 

B. Restriction of Production 

1. Xerxes and Proform would be required to stay below the 

100-ton threshold. 

4 

4f 
P.48 

2. Xerxes and Proform must restrict production and limit growth 

opportunities. 

3. Loss of environmentally friendly products. 

V. Xerxes and Proform Produce Very Large Parts in Very Large 

Rooms That Are Not Compatible With Method 204 Total 

Enclosures 

A. Molds and Parts Are Too Large To Fit Inside Total Enclosures 

1. Xerxes • 

a. Molding - Part Size: 

• 10-ft. wide x 10-ft. high x 16.5-ft. long (Example) 

b. Turning Fixture: 

• 10-ft. high xl7-ft. wide x25.5-ft. long 

c. Rotate 28 rpm: Raw materials enter open end 

d. Overhead cranes/gantries to de-mold: 

• 20-ft.high 

e. Assembly - Part Size 

• Up to 10-ft. wide x 10-ft. high x 74-ft. long 

2. Proform 

a. Molding - Part Size: . 

• 23-ft. long x 30-ft. wide x 4-ft.5 in. high 

b. Molds: 

• 28-ft. 6 in. long x 36-ft. 4 in. wide x 8-ft. high 

c. Molds travel station to station on motorized carriages 

d. Impregnator: 

• Suspended from 25-ft. ceiling 

• Travels and lays down resin and glass 

fi 
P.49 

3. EPA Standards - MACT Background Information Document 

a. Gelcoating Enclosure: 

• 19-ft.x36-ftx 10-ft. 

b. Resin Lamination Enclosure: 

• 44-ft'.x83-ftx 10-ft. 

c. Xerxes' and Proform's Molds/Parts Do Not Fit Inside 

EPA Enclosures 

B. Airflows Do Not Meet Method 204 

1. Xerxes 

a. Molds: 100 fpm 

b. High air flow, low styrene concentrations 

c. Meets OSHA PEL of 50 ppm 

d. Requires redesign of ventilation system for 200 fpm 

• Results in even lower styrene concentrations 

• Oxidizers become more costly 

2. Proform 

a. Push-pull airflow over mold 

b. Meets OSHA PEL of 50 ppm 

c. System not designed for 200 fpm > 

d. Requires redesign of ventilation system for 200 fpm 

• Results in even lower styrene concentrations 

• Oxidizers become more costly 

C. Building Doors Must be Opened 

1. Xerxes - Typical Roll Up Door: 20-ft. x 21 ft. 

2. Proform -Roll Up Doors: 16-ft. x28-ft. 

If? 
P.50 

VI. Xerxes and Proform Should be Considered a Small Business 

for Purposes of Above-the-FIoor MACT 

A. 100-Ton per Year Threshold Is Onerous and Unfair 

1. Xerxes and Proform Are Small Businesses 

a. Xerxes employees: 269 

b. Proform employees: 78 

c. Total: 347 

2. SBA Small Business Definition 

a. Less than 500 employees 

b. Requires inclusion of non-composites (and nonmanufacturing) businesses 

c. Discretionary 

3. Financing Add-On Controls 

a. No cross pledging of assets - different banks 

b. Difficult to finance non-productive add-on controls 

4. Disparity Within Composites Industry 

• Another composites-only business with more employees is 

exempt up to 250 tons 

5. Competitive Disadvantage With Steel Tanks > 

a. Steel tanks are already cheaper 

b. Steel tanks already have a 50% market share 

6. Absorption of Add-on Control Costs 

• Xerxes cannot raise its prices to cover the cost of add-on 

controls 

49 
P.51 

7. Innovations Will Suffer 

a. Double wall fiberglass tanks 

b. Water tight septic tanks 

VII. Conclusion 

A. Xerxes and Proform cannot afford the above-the-floor 95%) capture 

and control requirements. 

B. Xerxes and Proform make very large parts making Method 204 

infeasible. 

C. Xerxes and Proform should not be regulated as large businesses. 

MACTspeech.9501 

5* 
P.52 

ATTACHMENT 5 

Dan Blackburn, Mark Rowan, and Ken Witt 

Able Body Corporation 

57 
P.53 

I 

1000 Schifferdecker Avenue. • Joplin, Missouri. 64801 • (417)623-3060 • FAX 417-623-4617 

n 

ABLE BODY 

CORPORATION 

Presentation to the EPA 

On the proposed NESHAP 

For Composites 

September 7,2001 

Research Triangle Park, NC 

Presented By: 

Dan Blackburn 

Vice President of Quality and Continuous Improvement 

Mark Rowan 

Vice President of Operations 

Ken Witt 

Environmental and Safety Manager 

5? 
P.54 

1000 Schifferdecker Avenue. • Joplin, Missouri. 64801 • (417)623-3060 • FAX 417-623-4617 

n 

September 7, 2001 JLK ? 

I. Summary of Able Body Corporation 

• Full service supplier to the OEM's. 

• Incorporated in 1970 in Joplin, MO. 

• Four Strategic business units which are treated as separate profit centers: 

1. Metal fabrication and assembly. 

2. Closed molded composites (resin transfer molding - RTM, sheet molding 

compound - SMC). 

3. Vacuum formed plastics. 

4. Open molded fiberglass. 

• Diverse customer base: 

Kawasaki - PWC and rail car components. 

Honda -PWC. 

Freightliner truck components. 

Case agricultural components. 

Marley cooling tower components. 

Ottawa truck cab assemblies. 

OshKosh military vehicle components. 

Numerous small customers for components and assemblies. 

Three manufacturing sites: 

1. 1000 Schifferdecker Avenue in Joplin Missouri 

• Two separate plants at this location. 

• 270 full time manufacturing employees. 

• Closed molded truck components. 

• CNC metal fabrication and assemblies. 

• Open molded personal watercraft boats (PWC). 

2. Pittsburg Kansas facility 

• 46 full time manufacturing employees. 

• Vacuum formed plastic assemblies and painted components for the 

truck and marine industry. 

3. 3550 West Seventh Street in Joplin Missouri 

• 82 full time manufacturing employees. 

• Open molded fiberglass components for: 

• Truck industry 

• Cooling towers 

• Water Slides 

• Agricultural industry 

• Military vehicles 

• Fire truck industry 

s3 
P.55 

• This totals to 398 full time manufacturing jobs and a total corporate employment 

level of 517 people. 

II. Capture and Control cost concerns 

• Capture and control cost does not make good economic sense, and if forced into 

it would cause us to shut down our open mold fiberglass operations. This is only 

one of our four strategic business units, however the loss of these sales would 

jeopardize the entire company and could lead to the loss of all jobs, fiberglass 

and non-fiberglass. Our justification for this concern on cost is due to several 

reasons: 

1. The Initial capital outlay which is equivalent to approximately 80-90% of our 

annual open mold fiberglass sales. 

2. Our fiberglass operations are spread over three buildings at two different 

sites, which does not lend itself to one centralized capture and control 

device. In addition these buildings are older and not set up for this type of 

flow. It is our understanding that the EPA study was performed on facilities 

that were new, heavily modified and or built after 1990. 

3. Our product mix is very diverse and seasonal which lends itself to individual 

work cells that can be modified quickly to accommodate our customers. This 

is in contrast to a single building with one product line, which could funnel 

through a single capture and control device. 

4. To stay competitive in the global economy we have adopted the Kaizen 

methodology of lean manufacturing. This leads us to small work cells which 

will not allow you to force all products through a "monument" in order to 

accommodate a single capture and control device. 

5. We cannot pass these costs along to our customers, as they are demanding 

annual cost down on prices and we have to constantly compete with the 

small garage shop type businesses that are less than the 100 tons per year 

limit. 

6. With the down turn of the trucking industry, we have witnessed our workforce 

drop from 1160 in June of 1999 to 390 in December of 2000. This forced us 

to re-grow and diversify our business with a multitude of product lines from 

very small parts of 1'x1' to very large parts of 8'x20'. This does not lend itself 

to a single capture and control device. 

• Able Body has in the past and to stay viable in the future will need to produce 

sales of products that will cause us to emit more than the 100 tons per year of 

styrene at each of our fiberglass plants. Therefore we will be effected by the 

above-the-floor proposal. 

• Therefore we are asking for the above-the-floor requirement in the final rule be 

removed. 

• The demand for open molded fiberglass is not going away. This new proposal is 

simply going to move the business from established companies with formal 

systems to small lessor regulated garage shops or to other countries eliminating 

jobs in the United States. 

y 
P.56 

III. Boat MACT vs. Open Mold MACT 

• Able Body produces small boats known as personal watercraft (PWC) along with 

a wide variety of other open mold parts. 

• How is the EPA going to treat this type of product mix under the proposed Open 

Mold MACT? 

• We would like a formal response to this question. 

IV. Closing Statement 

• I would like to close by saying that Able Body Corporation is very proud of its 

ISO-9002 certified facilities and the fact that we are compliant on all current 

regulatory fronts. We have staffed properly to maintain internal formal programs 

designed to assure continued compliance. Along with working towards reduction 

efforts to stay current with the latest technology of our business such as the 

lower emissions impingement nozzles and low styrene monomer resins and 

gelcoats. 

• In summary Able Body Corporation truly understands the responsibility of being 

a good steward of our environment. The facts are we simply cannot afford this 

approach. Able Body is appreciative of this opportunity to be heard, however at 

the same time we remain fearful that the full weight of this decision is not 

understood. Any decision that will force our employees out of work is viewed by 

our company as serious matter. 

Respectfully submitted on behalf of all Able Body employees, 

Mark Rowan 

Vice President 

Daniel C. Blackburn 

Vice President 

Quality and Continuous Improvement 

meth Witt 

Wironmental and Safety Manager 

5t> 
P.57 

ATTACHMENT 6 

Gordon Lowe 

LASCO Bathware 

9P 
P.58 

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 

TITLE 29 

DEPARTMENT OF LABOR 

29CFR1910 SUBPART-Z TOXIC AND HAZARDOUS SUBSTANCES 

SECTION 1910.1000 AIR CONTAMINENTS 

(a) Table Z-l 

(l)Other substances - 8 hour Time Weighted Averages. An employee's exposure to any substance in 

Table Z-l, the exposure limit of which is not proceeded by a "C", shall not exceed the 8-hour Time 

Weighted Average given for that substance in any 8-hour work shift of a 40-hour work week. 

(e) To achieve compliance with paragraphs (a) through (d) of this section, administrative or engineering 

controls must be first determined and implemented whenever feasible. When such controls are not feasible 

to achieve full compliance, protective equipment or any other protective measures shall be used to keep the 

exposure of employees to air contaminates within the limits prescribed in this section. 

OSHA APPROVED 

Styrene Industry's Plan: 

The styrene industry agrees to establish a voluntary compliance program, the objective of which is to 

comply with the PEL established for styrene during the 1989 rulemaking; inhalation exposure that do not 

exceed 50 PPM on an 8-hour TWA, and a 100 PPM 15-minute ceiling, which is supported by health 

science and feasibility considerations. 

r? 
P.59 

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 

TITLE 29 

DEPARTMENT OF LABOR 

29CFR1910 SUBPART H - HAZARDOUS MATERIALS 

SECTION 1910.107 SPRAY FINISHING USING FLAMMABLE AND COMBUSTIBLE MATERIALS 

(9) (b) SPRAY BOOTHS 

(5) (i) The spraying operations except electrostatic spraying operations shall be so designed 

installed and maintained that the average air velocity over the open face ofthe booth (or booth cross section 

during spraying operations) shall be not less than 100 linear feet per minute. 

(9) (d) VENTILATION 

(2)General. All spray areas shall be provided with mechanical ventilation adequate to remove flammable 

vapors, mist, or powders to a safe location and to confine and control combustible residues so that life is 

not endangered. Mechanical ventilation shall be kept in operation at all times while spraying operations are 

being conducted and for a sufficient time thereafter to allow vapors from drying coated articles and drying 

finishing material residue to be exhausted. 

(11) Room intakes. Air intake openings to rooms containing spray finishing operations shall be adequate 

for the efficient operation of exhaust fans and shall be so located as to minimize the creation of dead air 

pockets. 

(12) Drying spaces. Freshly sprayed articles shall be dried only in spaces provided with adequate 

ventilation to prevent the formation of explosive vapors. In the event adequate and reliable ventilation is 

not provided such drying spaces shall be considered a spraying area. 

(9) (m) ORGANIC PEROXIDES AND DUAL COMPONENT COATINGS 

(l)Conformance. All spraying operations involving the use of organic peroxides and other dual component 

coatings shall be conducted in approved sprinklered spray booths meeting the requirements of this section. 

(9) (n) SCOPE 

This section applies to flammable and combustible finishing materials when applied as a 

spray by compressed air, "airless" or "hydraulic atomization," stream, electrostatic methods, or by any 

other means in continuous or intermittent processes. 

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140 

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122 

6 

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Tl 

o 
MINIMUM AIR FLOW TO MEET EMPLOYEE EXPOSURE LEVEL OF 50 PPM TWA 

MAKE-UP AIR ELEC. POWER REQUIREMENTS (MEETS OSHA REQ.) 

cfm 

90000 

h.p. 

35 

kw/hp 

0.75 

kwh req. 1 $ per kwh 

26.25 | $0,086 

$ per hour 

$2.26 

$ per shift 

$18.06 

cfm 

90000 

outside 

air temp 

45 

inside 

air temp 

75 

MAKE-UP AIR FUEL REQUIREMENTS (MEETS OSHA REQ.) 

temp btu 

rise 

30 

required 

2,916,000 

styrene 

0 

btu per 

therm 

100,000 

therms per 

hour 

29.16 

cost per 

therm of gas 

0.75 

cost/hr. 

21.87 

CFM 

90000 

gas 

cost/shift 

$18.06 

electric 

cost/shift 

$174.96 

total 

$193.02 

shirts/day 

3 

days/year 

250 

energy cost 

cost/year 

$ 144,765.00 

S> NOTE: THIS ENERGY REQUIREMENT IS TO SATISFY EMPLOYEE EXPOSURE AND PROCESS TEMPERATURE 

Tl 
RTO 

CFM 

24000 

48000 

96000 

120000 

anaheim 

indoor 

ait temp 

80 

80 

80 

80 

gelcoat 

18% 

rto temp 

1600 

1600 

1600 

1600 

barrier ct 

4% 

rto 

therm, eff. 

94% 

94% 

94% 

94% 

laminates 

4% 

temp 

rise 

91.2 

91.2 

91.2 

91.2 

gelcoat 

262.6538 

btu/hr 

required 

2,363,904 

4,727,808 

9,455,616 

11,819,520 

barrier ct 

117.83925 

btu from 

styrene 

1,168,546 

1,168,546 

1,168,546 

1,168,546 

laminates 

912.662625 

btu per 

therm 

100,000 

100,000 

100,000 

100,000 

therm gas/ 

hour 

11.95358294 

35.59262294 

82.87070294 

106.5097429 

styrene 

emissions/hr 

88.03 

66.02 

cost 

per/therm gas 

0.75 

0.75 

0.75 

0.75 

styrene btu 

per Ib. of styrene 

17,700 

17,700 

operating 

cost/hr. 

8.965187208 

26.69446721 

62.15302721 

79.88230721 

total 

btu/hr 

1558060.941 

1168545.706 

@75% eff. 

@75% eff. 

@75% eff. 

@75% eff. 

@ 100% eff. 

@75% eff. 

RTO 

CFM 

24000 

48000 

96000 

120000 

gas 

cost/shift 

$ 71.72 

$ 213.56 

$ 497.22 

$ 639.06 

electric 

cost/shift 

$51.60 

$103.20 

$206.40 

$232.20 

total 

$123.32 

$316.76 

$703.62 

$871.26 

shirts/day 

3 

3 

3 

3 

days/year 

250 

250 

250 

250 

energy cost 

cost/year 

$ 92,491.12 

$ 237,566.80 

$ 527,718.16 

$ 653,443.84 

capital cost 

RTO capital 

$ 415,000 

$ 830,000 

$ 1,245,000 

$ 1,336,000 

other cap. 

$ 200,000 

$ 400,000 

$ 500,000 

$ 600,000 

$ 

$ 

$ 

$ 

total cap 

615,000 

1,230,000 

1,745,000 

1,936,000 

deprecation 

cost/year 

$ 61,500 

$ 123,000 

$ 174,500 

$ 193,600 

total 

operating cost 

$ 153,991 

$ 360,567 

$ 702,218 

$ 847,044 

NOTE: OPERATING COST IS FOR ENERGY AND CAPITAL ONLY - NO MAINENANCE COST INCLUDED 

— 

rto/cfm 

24000 

48000 

96000 

120000 

h.p. 

100 

200 

400 

450 

kw/hp 

0.75 

0.75 

0.75 

0.75 

kwhreq. 

75 

150 

300 

337.5 

$ per kwh 

$0,086 

$0,086 

$0,086 

$0,086 

$ per hour 

$6.45 

$12.90 

$25.80 

$29.03 

$ per shift 

$51.60 

$103.20 

$206.40 

$232.20 

rto fuel requirements 

ro 
POLLUTION PREVENTION EXAMPLE 

30% STYRENE GELCOAT VS. 36% STYRENE GELCOAT RESULTS 

STYRENE 

% 

30% 

36% 

POUNDS 

PER GALLON 

11.3 

10.6 

CU. IN/CU.FT. 

12"X12"X12" 

1728 

1728 

GALLONS 

PERCU.FT. 

7.48 

7.48 

CU.IN PER 

GALLON 

231.0160428 

231.0160428 

CU.IN/SQ.FT. 

@ 20 MILLS 

2.88 

2.88 

RESIN 

LBS./CU.IN. 

0.048914352 

0.045884259 

RESIN 

SQ. FT. 

0.140873333 

0.132146667 

STYRENE 

SQ. FT. 

0.042262 

0.047573 

0.888365 

0.833333 

STYRENE 

% 

30% 

36% 

UEF 

ATOMIZED 

17.8% 

16.0% 

UEF 

NON-ATOMIZED 

9.3% 

11.2% 

ATOMIZED 

EMISSIONS 

PER SQ.FT 

0.025075453 

0.021169896 

NON-ATOMIZED 

EMISSIONS 

PER SQ.FT 

0.013089481 

0.014734353 

USAGE 

VARIANCE 

PER SQ.FT 

15% 

0 

NON-ATOMIZED 

EMISSIONS 

PER SQ.FT 

0.015052903 

0.014734353 

PERCENT 

INCREASE 

ATOMIZED VS. NON-ATOMIZED 

2.2% 

CONCLUSION: GELCOAT @ 36% STYRENE USING NON-ATOMIZED SPRAY EQUIPMENT HAS LESS EMISSIONS 

PER SQUARE FOOT OF PRODUCT THAN GELCOAT @ 30% STYRENE USING ATOMIZED EQUIPMENT 

I I 
P.64 

ATTACHMENT 7 

Dianne Coon 

Ashland Specialty Chemical Company 

0 
6"^ 

Presentation to EPA on the Reinforced Plastics 

Composites MACT 

Why pollution prevention should be 

a compliance option 

Dianne Coon 

Ashland Specialty Chemical Co. 

9/7/01 
Oxidation Diminishes Market Need for 

much Lower HAP Resins 

Ashland is a major supplier to the composites 

industry 

We have a strong R&D dept that has the proven 

ability to discover new technology 

The $ spent in R&D must be market-driven and 

justified with an acceptable return 

If high-volume users are forced to oxidation, then 

the market need for much lower HAP resins is 

greatly diminished 
Long-Term Effect of oxidation 

If fabricators go to oxidation then: 

- They have no reason to demand a lower HAP than they 

currently use to meet OSHA 

- Efforts would continue to ensure the small and medium 

volume-users can meet the RPC MACT 

- There would be little R&D effort to drive HAP's down 

to substantially lower levels than MACT currently 

requires 

^1 
Why pollution prevention makes more 

sense for the industry 

If fabricators are given the option of using 

pollution prevention then: 

- Those high-volume users will demand even lower HAP 

resins which will in turn drive innovation 

- Ashland can then justify R&D efforts to drive HAP's 

much lower 

- The results of that research will give the entire industry 

a better ability to lower emissions 

- Would need time to create these programs, innovate, 

and commercialize the technology 

oo 
P.69 

Xfl 

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