p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

#261 ) ll-F-10 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 261 of 264 
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U-f- to 

Keith Barnett To: Peter_D._Eglinton@omb.eop.gov 

02/22/2001 09:13 AM 

cc: 

Subject: RE: reinforced plastics 

Dear Peter: 

I don't think these are significant. We cover the manufacture of reinforced composites. Most of 

what the military does is repair. I had a similar conversation on this issue with someone else in 

DOD. We specifically mention that this NESHAP covers manufacturing and are silent on the fact 

that it does not cover repair. 

If an aerospace facility is making composites using styrene based thermoset resins, it would 

potentially be covered by two NESHAP, but that is unavoidable, and appropriate. 

I suggest DOD formally submit their comments to the docket in the comment period. We probably 

will get similar comments form other sources and it would be best to craft language to deal with 

them all at once. 

Keith W. Barnett 

U. S. Environmental Protection Agency 

Emission Standards Division 

MD-13 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

Peter_D._Eglinton@omb.eop.gov 

PeterD. Eglinton@om To: Keith Barnett/RTP/USEPA/US@EPA 

b.eop.gov 

02/21/2001 03:51 PM 

cc: 

Subject: RE: reinforced plastics 
P.3 

Hi, Keith. 

Last week, DoD contacted us expressing interest in the RPC proposal. I 

mentioned that we were trying to reach closure, but that we'd like to know 

if they have significant concerns. Following are their comments. Please 

let me know your thoughts. 

Thanks! 

Peter 

03:48 PM 

Forwarded by Peter D. Eglinton/OMB/EOP on 02/21/2001 

(Embedded 

image moved 

to file: 

PIC17066.PCX) 

"Ling, Alison D" <Ling.Alison@HQ.NAVY.MIL> 

02/21/2001 03:45:25 PM 

Record Type: Record 

To: 

cc: 

Peter D. Eglinton/OMB/EOP 

'drek newton' <newtonda@nfesc.navy.mil>, 'lisa trembly' 

<ltrembl@nfesc.navy.mil>, "Ellis, Kathy L" <Ellis.Kathy@hq.navy.mil> 

Subject: RE: reinforced plastics 

Peter: 

Our initial concerns are as follows based on feedback from the Navy 

Aviation 

Depots 

and our quick review of the draft rule. 

1. Overlap with other NESHAPS. At many facilities (private and military) 

the 

solvent cleaning operations regulated by this rule will already be 

regulated 

by the Aerospace NESHAP or 

the future Miscellaneous Metal Parts and Products NESHAP. The Aerospace 

NESHAP would cover RPC related solvent cleaning operations since it is not 

limited to solvent prep. Regardless a solvent tank used to clean a spray 

gun could also be used to clean a RPC related item. Language should be 

added 

to the rule to prevent overlap and make it clear which rule covers the 

solvent 

cleaning operations. 

2. Low Use Exemption. We recommend the rule include a low use exemption. 

We would not want, and EPA probably does not intend, that a military 

installation that emits little or no HAP from resin each year to be 

affected 

by this rule. Much of the military 

aircraft are made with carbon-based composites which use resins that do not 

contain 

styrene or methyl methacralate (MMA). The resins emit small amounts of 

volatile amines but not much HAPs. For example, one of our Depots that 
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does 

a lot 

of composite work involving military aircraft, has facility wide emissions 

of styrene 

and MMA of only 4 0 pounds and 3 pounds per year, respectively. Their 

styrene and MMA 

emissions are probably from a very small amount of fiberglass work. 

Surface 

coating NESHAPs exempt facilities that use between 200 and 1,200 gallons 

per 

year of coatings. EPA 

should create a comparable exemption that covers affected resins, gel coats 

and solvent used in affected RPC operations. Thus facilities that qualify 

for the exemption would only need to track resin usage and not need to 

calculate rolling-average point values. They would also not be considered 

an affect source under the rule. 

3. Scope of Rule. Although the emission limits are in the form of total 

HAPs, the preamble 

says the intent of this rule is to only regulate RPC operations involving 

resins and gel coats that contain styrene and/or methyl methacrylate (end 

of 

section I). If that is indeed the intent, the rule does not clearly exempt 

resins that do not contain these two HAPs. 63.5780 says matter of factly 

that "These 

operations use resins or gel coats that contain styrene and/or methyl 

methacrylate..." but the exemption should be more clear to avoid confusion. 

E.g., "This rule only affect operations that use resins or gel coats that 

contain styrene and/or MMA." 

We appreciate the opportunity to provide comments, please let me know if 

you would like to discuss any of these comments further. 

Alison Ling 

(703)604-8226 

Ms 

PIC17066