OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

33) ll-J-24 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:40:24 AM Sheet 33 of 36 

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jschwtzr@gte.net 

04/26/2000 01:25 PM 

To: Keith Barnett/RTP/USEPA/US@EPA, Jonathan.Pawlow@sba.gov, 

Austin.Perez@sba.gov 

cc: 

Subject: CFA materials to SERs 

Keith, Jon, Austin: 

Attached are some materials CFA recently sent to the SBREFA SERs (as 

"supplemental" to the information sent by EPA). 

Keith: I just left you two (long, sorry!) voice-mail messages rearding s<J>me 

of these attached documents. 

Thanks. 

M19 rii 

EPA AIR DOCKET 

FROM = = = = = = = = = = = = 

John Schweitzer 

Sr. Director of Gov't. Affairs 

Composites Fabricators Assoc. 

voice 734.622.0162 

fax 734.622.0122 

jschwtzr@gte.net 

www.cfa-hq.org 

m* 

- memo to SERs rev.doc 

- Revised critical issues April 00.doc 

MM - Low hap approach 1 .doc 

Questionnaire for SERs.doc 

Wk, 
P.3 

April 21, 2000 

To: Composites MACT SBREFA Small Entity Representatives 

Fr: Ken Odette and John Schweitzer, CFA 

Re: Materials for May 2 meeting 

To help focus on the most constructive issues for the May 2 meeting of the Small Entity 

Representatives and the Federal SBREFA Panel, CFA is providing the following 

materials (Exhibits 1, 2, 3, and 4 were sent to you by FedEx for delivery on April 24; 

Exhibits 5, 6, and 7 are attached to this fax. Note: These materials are intended to 

supplement the documents sent to you recently by EPA.): 

Exhibit 1: A summary of the existing source and new source floors. A "floor" is the 

minimum stringency level for the MACT. For existing sources, the floor is set at the 

level of control used by the average of the best controlled 12% of facilities. For new 

sources, the floor is set at the level of controlled achieved by the best controlled single 

source. EPA can set MACT at levels "above-the-floor," if such control would be 

affordable. (The floors are stated in terms of maximum point values. Go to http://www. 

cfa-hq.org/reg-mact.htm and download document No. 5 if you need help in determining 

the actual point value for your operations.) 

Important question for SERs: "Can you meet the floors and still make 

acceptable products and make reasonable profits?" 

Exhibit 2: A summary of existing source floors for open molding, showing the 

facilities that set the floors. EPA is required to base MACT on "similar" sources. 

Important question for SERs: "Is your operation really similar to the floorsetting source(s), in terms of your ability to use resin with this HAP content and 

the other controls needed to meet the floor(s)?" 

Exhibit 3: CFA's Report, "Feasibility of the Cost of the Capture and Control of 

Hazardous Air Pollutant Eniissions from the Open Molding of Reinforced Plastics 

Composites." This report is the basis of CFA's claim that capture and control 

(oxidation) is much more expensive and less effective than EPA suggests. The data in 

the report are based on 18 case studies. EPA is proposing to require 95% capture and 

oxidation for existing sources with emission of 100 tons per year or more (this is an 

"above the floor" requirement) and for all new and reconstructed sources with emissions 

of 10 tons per year or more. 

Page 1 
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Important questions for SERs who may (a) trigger the capture and oxidation 

requirements for existing sources with emissions of 100 tons per year or 

more, (b) reconstruct (i.e. substantially modify) an existing source, or (c) 

build a new source: "Is your operation similar to one of the 18 case studies 

(Exhibit 3, Section VLB.; see also Table of Contents page 7), so you can use the 

case study as a reasonable estimate of what capture and oxidation would cost your 

facility? With these costs, can you still make acceptable products and make 

reasonable profits?" 

Exhibit 4: CFA's Report, "Pollution Prevention for Open Molding of Composites." 

This report is the basis of CFA's claim that pollution prevention (P2) can achieve most of 

the emission reductions of capture and oxidation, while still being affordable for 

fabricators. 

Important question for SERs: "Is your operation similar to any of the 6 model 

facilities contained in the report, so you can use the P2 emission reduction 

estimates and costs as reasonable estimates for your own operation?" 

Exhibit 5: CFA's Table of Critical Issues for Open Molding MACT. This table 

summarizes the critical issues that should be addressed as part of the SBREFA process, 

and suggests solutions for each. 

Important questions for SERs: "Which of the critical issues apply to your 

operations? Are there others? Which of the solutions listed would address your 

specific problems with MACT?" 

Exhibit 6: CFA's Survey for SERs. This survey will help you organize your comments 

for the May 2 meeting. You should fill out the survey and bring it with you to give to 

EPA. If you can send us a copy ahead of time, we can be better prepared to help you 

prepare for this meeting. (Send completed materials to Ken Odette, fax 703.525.0743.) 

Also bring or send copies of any previous correspondence with EPA on MACT. 

Exhibit 7: CFA's Low HAP/ High Hap approach to setting MACT floors. CFA 

believes that this approach is needed to address the dissimilarity in several of EPA's 

process/product groups, and should be adopted by EPA to address several of the critical 

issues listed in Exhibit 5. 

Important questions for SERs: "What is the minimum HAP content that you 

need in each of your resin applications in order to achieve the MACT standard? 

If the floors were set based on this Low HAP/High HAP approach - instead of on 

the specific HAP contents used by the floor-setting sources - could you then 

achieve the MACT standard?" 

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Please call John Schweitzer (734.622.0162) or Ken Odette (703.525.0511) if you have 

any questions about the SBREFA program. We will discuss the documents and issues 

described above during the pre-meeting the moming of May 2, and during a conference 

call to be held in the coming days (watch your fax for a notice with the conference call 

information). 

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CFA Exhibit 6 

Information from Composites Industry Small Entity Representative 

Date: 

Name: 

Name of firm: 

Address: 

Types of products produced: 

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Types of processes employed (circle all that apply): 

Closed Molding 

Injection/Compression Molding 

RTM 

Continuous Lamination/ Continuous Casting 

Polymer Casting 

Pultrusion 

SMC Compounding 

Equipment Cleaning 

Resin Mixing, BMC Compounding 

Resin Storage 

Open Molding 

Corrosion Resistant (CR) Mechanical Resin Application 

Non CR Mechanical Resin Application-Unfilled 

Non CR Mechanical Resin Application-Filled 

Manual Resin Application-Tooling 

Mechanical Resin Application-Tooling 

CR Manual Resin Application 

Non CR Manual Resin Application 

CR Filament Winding 

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Non CR Filament Winding 

Tooling Gel Coating 

Pigmented Gel Coating 

Clear Production Gel Coating 

Centrifugal Casting 

NonCR 

CR 

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Name Company. 

Existing Source Floors 

Complete one copy of this page for each process/product group (e.g., corrosion resistant 

mechanical, manual tooling, pigmented gel coat, etc.) applicable to your operations. 

1. Process/product group (see list on page 1): 

2. What techniques/technologies do you believe you are now using or could use in the near futuer to 

reduce your emissions: 

3. How do your costs compare to those given in the CFA Pollution Prevention report (Exhibit 4)? 

What model facility is closest to your situation? Are your costs higher, lower, or about the same 

as those in the report? Comments: 

4. Do you believe the combination of these techniques will allow you to meet the floor? 

If yes, go to next process/product group. If no, please answer remaining questions under this category. 

If you have already answered them in your letter(s), you may provide a short answer and reference 

those letters for more detail. 

5. How is your facility similar to the facility setting this particular floor (see Exhibit 2)? How is it 

dissimilar? 

6. What do you believe the barriers are to your meeting this floor in this case? 

7. Is your problem one of those listed on the CFA "critical issues" list (Exhibit 5)? If so, what letter? 

If not, how would you state the problem in general terms? 

8. What do you believe you need the MACT standard to allow you to do in order for you to meet the 

floor? (e.g. % styrene content in the resin, etc.) 

9. Which of the following solutions might provide relief to your situation and which would you 

prefer and why? Which do you not like? 

10. Case by case waiver 

11. Low HAP-categories, like Rule 1162 (see 

Exhibit 7) 

12. Subgroupings for small businesses 

13. Facility-specific standard 

14. Other solution: 

Might 

work Prefer Dislike 

15. Explain why your prefer one or more options: 

16. Explain why you dislike one or more options: 

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Name Company. 

Above the Floor 

Are your emissions likely to exceed 100 tons per year any time in the next several 

years? If not, skip this page. 

17. Which, if any, ofthe case studies from the CFA "Feasibility and Cost" report (Exhibit 3, Section 

VLB.; see also Table of Contents page 7) is most similar to your situation? 

18. Do you believe your costs would be higher, lower, or about the same as those shown in the report 

for this case study? Why? 

19. Is capture and oxidation a possible option for your facility? Explain: 

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Name Company. 

New/Reconstructed 

Are you likely to make significant changes to your existing plant, move to a new location, 

or build a new plant in the next several years? If not, skip this page. 

20. What kinds of capital investments do you routinely make over the life of a plant? 

21. What kinds of capital investments might you make over the life of a plant that would represent a 

MAJOR reconstruction of your plant or portion of your plant? 

22. Which of these kinds of investments would represent opportunities for you to increase the amount 

of pollution prevention or control applied at the plant? 

23. Under what circumstances might you wish to establish or move to a new facility? 

24. How likely is it that such circumstances might present themselves in the next 10 years? 

25. At a new facility, what opportunities would there be for you to add new pollution prevention or 

control technologies? 

26. Which, if any, ofthe case studies from the CFA "Feasibility and Cost" report (Exhibit 3, Section 

VLB.; see also Table of Contents page 7) is most similar to your likely reconstructed or new 

operation? 

27. Do you believe your costs would be higher, lower, or about the same as those shown in the report 

for this case study? Why? 

28. Is oxidation a possible option for your facility? Explain: 

Page 6 
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Working Draft 

CFA Exhibit 7 April 21, 2000 

Low HAP/High HAP 

Fine tuning the characterization of the floor-setting sources 

in the open molding MACT database 

Early in the MACT development process EPA staff decided to divide the reinforced 

plastics industry into a relatively small number of process groups for the purpose of 

setting the MACT floors. This approach has many undeniable administrative 

advantages for EPA and the companies that have to comply. However, the reinforced 

plastics industry is very diverse and having only a small number of groups means that 

companies that have very different processes and products are put into the same 

group. This creates a tension between the administrative benefits of a small number 

of categories and the problems of grouping dissimilar sources together. This tension 

has been at the heart of the continuing difficulty of defining MACT floors that meet 

the statutory requirements and constraints of bringing all sources up to the level of 

control currently demonstrated by the best controlled sources to which they are 

similar. 

EPA has now heard from numerous sources that the draft MACT floors are not 

correct because these sources are grouped unfairly with sources that are dissimilar, 

and that they would thereby be required to use resins and application techniques that 

are product/production specific to the sources that are identified as setting the MACT 

floors. The commonly suggested solution to this problem is to create more groups to 

accommodate better the diversity in the industry. However, to date, despite 

considerable effort by both EPA and industry representatives, this idea of creating 

more categories, with a few exceptions, has appeared to create more problems than it 

solves. 

Another approach to these problems is not to create more groupings, but to take a 

closer look at how the present groupings are characterized or described. More 

specifically, once sources are arranged in the process groups, EPA must describe or 

characterize the pollution prevention/control techniques being employed by these 

sources. There is no statutorily prescribed way that these sources must be described. 

One characteristic that EPA and contractor staff identified as a way to describe these 

sources is the weighted average HAP content in the resin used by the source. The 

staff chose to identify that resin HAP content down to the precision of a single 

percentage point. Because HAP content in the resin is a factor that in this industry is 

directly tied to the specific product produced and its intended use, this degree of 

precision has produced a very serious problem. It has had the effect of accentuating 

the dissimilarities between the floor setting sources and the rest of the sources in the 

groups, because the products and their uses contained within a single category 

grouping - and hence the HAP content of the resin - are quite varied. This level of 

precision with regard to HAP content of the resin has led to numerous complaints that 

EPA is proposing to hold sources to levels met by sources in the category that are 

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P.13 

Working Draft 

very dissimilar to them - levels which they cannot meet and still produce their 

products. 

Rather than starting over with new categories or groupings, many of these identified 

problems of dissimilarity can be solved by taking a closer look at how the floor 

setting sources should be characterized. Specifically, with regard to the description of 

the HAP content ofthe resin, the problem ofthe diversity in the database categories 

may be greatly ameliorated ifthe HAP content is designated as "high HAP" content 

or "low HAP" content for each ofthe sources. The floors would be set by the 

sources using low HAP content resin (and other techniques, such as advanced 

application technology) and all the sources in that category would be required by the 

resulting floor to use a combination of low HAP content resin and advanced 

application technology, or their equivalent. This approach allows the level of 

precision used in the characterization of the floor-setting sources to match the level of 

precision used in grouping the diverse sources of the industry into such a small 

number of floor categories. This approach would help bring the proposed floors 

closer to the statutory mandate of setting floors that bring all sources within a 

category up to the level of control currently demonstrated by the best controlled 

sources to which they are similar. 

The criteria by which these floor setting sources would be characterized - namely, 

high HAP and low HAP resin content - are already well established in the regulation 

ofthis industry because of California rule 1162 which, since its final adoption six 

years ago, has been picked up as well by other states. Specifically, rule 1162 requires 

the use of low HAP resins, and sets the maximum HAP monomer content by weight 

according to certain process/product groups that are easily translated, with some 

easily fixed exceptions, into the current structure of the Federal MACT rule. 

Rule 1162 essentially establishes the following categories of low HAP materials: 

Process/Product Group 

General purpose 

Corrosion-Resistant 

Fire Retardant 

High Strength 

Clear Gel Coat 

Pigmented Gel Coat 

Rule 1162 Maximum Monomer 

Content by Weight (as applied) 

35% 

48% 

42% 

48% 

50% 

45% 

Point values for sources using low-HAP materials would be calculated using the 

maximum monomer contents for low-HAP materials established in Rule 1162. For 

example, if a source made non-corrosion resistant products using resin with 33% 

HAP and non-atomized application, its point value (for ranking database sources and 

setting floors) would be calculated using 35% HAP (since this is the Rule 1162 limit 

for general purpose resins) and non-atomized application. 
P.M 

Working Draft 

Note that Rule 1162 allows the weight of filler and other additives to be added to the 

resin weight when calculating monomer content, allowing in effect resins with higher 

monomer contents to be used for filled systems. The "as applied" concept will not 

work in the point value system, and so the floor for filled systems will have to be set 

using the specific HAP contents used by sources rather than by low HAP / high HAP 

approach. The resulting floor for filled resins should still be achievable since a new 

pollution prevention technology is available for filled resins (non-atomized 

application) that is not represented in the current floor. 

Also, Rule 1162 does not set HAP limits for tooling. CFA has suggested that the 

MACT requirements for tooling be based on equipment and work practices (and not 

HAP content), since limiting HAP content will result in lower quality tools and more 

re-work (and more emissions). Alternatively, tooling could reasonably be regulated 

in the corrosion group with 48% HAP limit (tooling must be resistant to corrosion 

(solvent) attack just like other corrosion-resistant products). Less than 2% of resin 

and gel coat is used for tooling. 

The existing-source floors for the open molding process/product groups determined 

by the HAP-category approach are shown in the table below. 

Process/Group 

CR Mechanical 

Non-CR 

Mechanical 

Non-CR 

Mechanical 

Filled 

CR Manual 

Non-CR Manual 

CR Filament 

Winding 

Non-CR 

Filament 

Winding 

Pigmented Gel 

Coat 

Clear Gel Coat 

Existing-Source Floor 

Based on Specific HAP 

Content 

48.3% HAP and 100% 

non-atomized 

37.1% HAP and 100% 

non-atomized 

34% HAP 

40% 

32.3% 

42% 

45% 

30% 

44% 

Existing-Source Floor Based on Low HAP / 

High HAP Characterization 

48% and 50% non-atomized 

35% and 100% flow coaters 

No low HAP / high HAP characterization can be 

established for filled; however, the current floor will 

allow 43% HAP with non-atomized 

48% 

35% 

48% 

35% - This level is well below any in the 

database. This is a very small and specialized 

group, and perhaps no source could comply with 

Rule 1162. The floor for this group should remain 

at 45% HAP. 

45% 

50% 

Note that high-strength and high-temperature applications (and possibly tooling) 

should be added to the corrosion-resistant process/product ("specialty") group, which 

is consistent with Rule 1162. 
CFA Review of "Critical Issues" for Open Molding MACT Exhibit 5 REVISED April 18,2000 OXIDATION 

* 

A 

B 

C 

Critical Issue 

Whether the environment and 

workplace health disadvantages of 

oxidation disqualify it as "best 

technology" for MACT floor purposes. 

Whether the environmental and 

workplace health disadvantages of 

oxidation, together with its high 

costs and low affordability, disqualify it as above the floor 

MACT. 

If oxidation is not disqualified as a 

"floor" technology, which facilities should be required to install it. 

Discussion 

For CFA's 18 case study facilities, control of 

emissions by oxidation increased greenhouse 

gas and criteria pollutant emissions 30 times 

more than it reduced HAPs. Any practicable 

capture and control approach will force 

sources to violate OSHA regulations on 

workplace exposures and use of ventilation 

controls. 

Based on CFA's 18 case studies, capture and 

oxidation is at least 3 to 10 times more expensive and is less effective than EPA claims. 

Careful economic analysis of 17 case studies 

demonstrated that none of them could afford 

capture and oxidation. 

A small number of open molders do employ 

capture and oxidation. 

Possible solution(s) 

A-l. In light ofthe recently available industry data and 

analysis, EPA should reconsider whether oxidation is 

really the "best" control for open molding. 

B-l. In light ofthe recently available industry data and 

analysis, EPA should reconcile the large disparity in the 

cost estimates and reconsider whether oxidation is really 

an affordable and viable above the floor technology. 

C-1. Any above the floor or new/reconstructed source 

requirement for end-of-stack controls should be limited 

to those sources that are identical (in all respects relevant 

to the technical feasibility and cost of such controls) to 

those that are the basis for the MACT requirement. 

* Letter code does not imply priority among issues. 

P. 1 of 4 
CFA Review of "Critical Issues" for Open Molding MACT Exhibit 5 REVISED April 18, 2000 NE

W SOURCES 

D 

E 

Critical Issue 

New source floors are so low that 

many new and reconstructed 

sources will be forced to install 

C+C and/or highly specialized and 

infeasible P2 technology. 

The definition of "reconstruction" 

must recognize the small business 

and low capital character of this 

industry. 

Discussion 

In several of the open molding groups, the 

best-controlled source is not really similar -

in terms of technical and financial ability to 

use C+C and P2 controls - to the majority of 

other sources. 

Many open molders have very low capital 

investment. If EPA adopts a narrow definition of "affected facility," or a broad definition of "reconstruction," routine changes at a 

facility (for example, replacing an atomized 

spray gun with a non-atomized gun) could 

trigger new source MACT. 

Possible solution(s) 

D-l. Only large new or reconstructed sources (with PTE 

above 100 tons per year) should be required to achieve 

levels more stringent than the existing source floors, and 

these levels should not require oxidation. 

- and -

D-2. MACT requirements for smaller new and reconstructed sources should not differ substantively from 

those for existing sources. 

E-l. EPA should not a narrow definition of reconstruction for this rule, and in particular should not count investment in equipment that will protect workers or reduce emissions toward triggering "reconstruction." 

- and -

E-2. New source MACT should apply only to larger 

sources (see Critical Issue D). 

- and -

E-3. Since MACT for new and reconstructed sources 

becomes effective on proposal, EPA should allow industry to comment on the reconstruction definition before 

proposal. 

P. 2 of 4 
CFA Review of "Critical Issues" for Open Molding MACT Exhibit 5 REVISED April 18, 2000 

Critical Issue Discussion Possible solution(s) 

The HAP limit for resin 

used for non-corrosion 

manual is too low for 

many products. 

Resin used for non-corrosion manual is limited to 32.3% HAP, while the resin 

for mechanical application is limited to 37.1% (assuming non-atomized application). Technically this makes no sense. Sources use the same drum of resin to 

make multiple components - whether by manual or mechanical - and the components are then often joined together to make a single product all parts of which 

must have the same physical and chemical properties. 

G-1. Use the low HAP characterization approach to set the 

floors. 

2S 

o 

o 

fa 

a 

u 

& 

o 

1/3 

o 

g 

H 

cc 

H 

The HAP limits for 

resin used for corrosion 

manual and for corrosion filament winding 

are too low for many 

products. 

Resin used for corrosion manual is limited to 40% HAP and for corrosion filament winding to 42%, while the resin for mechanical application is limited to 

48.3% (assuming non-atomized application). Technically this makes no sense. 

Sources use the same drum of resin to make multiple components - whether by 

manual, filament winding, or mechanical - and the components are then often 

joined together to make a single product, all parts of which must have the same 

physical and chemical properties. 

H-l. Use the low HAP characterization approach to set the 

floors. 

The HAP limits for 

manual application of 

tooling resin and tooling gel coat are too 

low. 

Tools (molds) must be made to very high shrink-, heat-, and solvent-resistant 

standards. Adjusting the HAP content of tooling resin and gel coat will result in 

lower quality tools, which will require re-made or repaired parts and new tools -

causing in the end more HAP emissions than if there were no HAP limits on 

tooling materials. Less than 2% of resin and gel coat is used for tooling. 

I-l. MACT requirements for 

resins and gel coats used to produce and repair tools (molds) 

should focus on work practices 

(for example, non-atomized for 

mechanical resin application, and 

controlled spray for gel coat application) instead of HAP limits. 

- or -

1-2. Consider tooling to be a specialty application (like corrosion) 

with HAP limit of 48%. 

The HAP limit for mechanical filled will not 

allow the use of resins 

needed for thermoformed thermoplastic 

sheet. 

Use of thermoformed thermoplastic sheet as the surface of a product requires 

resin with 42% HAP, but the floor for mechanical filled will limit HAP to 

33.9%. Many bathware and (increasingly) other products use formed acrylic or 

other thermoplastic sheet as the exterior surface ofthe product. This provides a 

very high quality premium (expensive) product. However, to provide the proper 

bond between the thermoplastic sheet and the composite laminate, a resin with 

higher HAP is needed. Overall emissions are lower because no gel coat is used. 

Problem solved: Sources can 

now use non-atomized application to apply the filled resin with 

the needed HAP content and still 

meet the floor (as long as the 

floor stays at 144 point value). 

P. 3 of 4 
CFA Review of "Critical Issues" for Open Molding MACT Exhibit 5 REVISED April 18, 2000 EXISTIN

G SOURC

E FLOOR

S (cont.) 

K 

L 

M 

Critical Issue 

The HAP limit for clear 

gel coat will not allow 

products to meet ANSI 

requirements for 

plumbing fixtures. 

The HAP limit for 

pigmented gel coat 

(30%) is too low for 

many products. 

Higher HAP limits are 

needed for specialty 

products. 

Discussion 

Clear gel coats will be limited to 44%, but products must be made with 48% 

HAP gel coat to meet the ANSI requirements for sanitary ware. Gel coat with 

HAP content of less than 48% will not pass the ANSI Z-l24 standard for plastic 

plumbing fixtures in most applications. These products represent one of the 

largest uses of clear gel coat. 

The HAP limit for pigmented gel coat is based on formulas containing heavy 

inorganic pigment. Many formulas with much lighter organic pigments will 

have higher HAP contents when measured as a weight percent. 

Several "non-corrosion" products need resins with higher HAP contents, for example ifthe product will be heated in a paint oven or in-use, or for products 

made to Military Specifications. California's SCAQMD Rule 1162 recognizes 

the need for higher HAP resin for products needing heat resistance and high 

strength. Where new low-HAP resins are available, smaller fabricators still need 

5-10 years to test and phase-in new resins for these demanding applications. 

Possible solution(s) 

K-l. Use the low HAP characterization approach to set the 

floors. 

-or -

K-2. Establish a separate process/product group for products 

made to meet ANSI requirements. 

L-l. Use the low HAP characterization approach to set the floors. 

- or -

L-2. Establish a separate process/product group for gel coat 

with organic pigment. 

M-l. Add specialty products 

(needing high strength or high 

heat resistance, or made to meet 

Mil Specs) to the corrosion process/product groups (with 48.3% 

HAP limit). 

P. 4 of 4