p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

137) ll-E-97 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:07 AM Sheet 137 of 264 
P.2 

I 

\\'i-?7 

MEMORANDUM 

TO: 

FROM: 

DATE: 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

June 24, 1997 

SUBJECT: Minutes of May 9, 1997, Meeting Between EPA and Representatives of the 

Reinforced Plastic Composites Industry 

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

9:00 am-11:00 am 

ATTENDEES: 

Ms. Nancy Dehmlow 

Mr. Nelson Douglas 

Ms. Linda Herring 

Mr. Bruce Jordan * 

Mr. Richard Martens 

Mr. Steve McNally 

Mr. Ken Meardon 

Ms. Jan Meyer 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

GLS 

Reichhold Chemicals, Inc. 

EPA/ESD/CCPG 

EPA/ESD/CCPG 

Reichhold Chemicals, Inc. 

Composites Fabricators 

Association (CFA) 

PES 

EPA/ESD/CCPG 

PES 

Composites Institute of the Society 

of the Plastics Industry (SPI) 

EPA/ESD/CCPG 

(312) 664-3500 

(919) 990-8256 

(919) 541-5358 

(919) 541-5572 

(919) 990-8007 

(703) 610-0220 

(919) 941-0333 

(919) 541-5254 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

Mr. Jordan was present only initially to introduce the purpose of the briefing 

PURPOSE 

The purpose of the meeting was to brief industry representatives on MACT 

simplification options for the existing source MACT analysis. The briefing presented 

process subcategory groupings, existing source MACT floor level results, and existing 

source MACT floor emission reduction results for noncorrosion-resistant and corrosionresistant resins. 
P.3 

* 

\ 

Madeleine Strum 

June 24, 1997 

Page 2 

INTRODUCTION 

Mr. Jordan introduced the briefing by stating that the MACT floor analysis 

previously presented to industry appeared to be extremely complex and that he, therefore, 

instructed his staff to explore other options that would simplify the standard. Mr. Jordan 

further explained that the goal of the MACT simplification analysis was to offer a simple 

way to comply with the standard for those who wanted something simple, while still 

offering other, but more complex, options to comply. As Mr. Jordan pointed out, facilities 

that carry out a variety of processes would be subject to several different standards under 

the previously presented MACT floor analysis. Mr. Jordan explained that one commonality 

in all the different production processes for this source category is the use of styrene and, 

therefore, this MACT simplification analysis focused on combining as many processes as 

possible into one process subcategory and providing one resin HAP content limit. Mr. 

Jordan continued to explain that if a facility wanted to use a higher resin HAP content as 

determined in the MACT floor analysis, the rule could provide other equivalent options to 

comply. Mr. Jordan closed his introduction by stating that he was pleased with the results 

of the MACT simplification analysis and that the EPA is planning to move forward with this 

approach unless industry representatives could provide strong and convincing arguments for 

using another approach to determine MACT floors for this source category. Mr. Jordan 

also strongly encouraged industry to help develop options that would be equivalent to the 

HAP content limit for specific processes. 

DISCUSSION 

Ms. Strum began to present the results of the MACT simplification analysis by 

stating that this presentation would focus only on existing source MACT floors. Ms. Strum 

explained that two major changes occurred in the MACT analysis that was previously 

presented to industry: (1) The process subcategories were regrouped to simplify the MACT 

floor analysis, and (2) the MACT database was expanded by adding sources with actual 

emissions of less than 10 tons of HAP per year to the database that have potential HAP 

emissions in quantities that they would be defined as major sources. According to Ms. 

Strum, this step was taken because the review of other rules showed a more conservative 

determination of a facility's potential to emit. For example, a facility's potential to emit 

was determined by increasing its operating hours to 3 shifts per day. Determining the 

potential to emit conservatively, has resulted in a larger, more representative, and more 

robust database. 

Ms. Strum proceeded by discussing the outline of the briefing package (see 

Attachment 1). She pointed out that a separate MACT floor analysis was conducted for 

noncorrosion-resistant and corrosion-resistant resins. Ms. Strum stated that she would first 

- 2 -
P.4 

Madeleine Strum 

June 24, 1997 

Page 3 

discuss process subcategory groupings, MACT floor level results, and MACT floor 

emission reduction results for noncorrosion-resistant resins and then for corrosion-resistant 

resins. 

Ms. Strum reviewed 3 different options that were considered for the MACT floor 

analysis for noncorrosion-resistant resins. As Ms. Strum pointed out, Option 1 is the option 

that was previously presented to industry. Under Option 1, the reinforced plastic 

composites industry is subcategorized into 12 different process subcategories as shown in 

Attachment 1. Ms. Strum stated that under this option, each process subcategory has a 

different existing source MACT standard. 

According to Ms. Strum, Option 2 presents a possible way to simplify the MACT 

floor analysis conducted under Option 1. Under Option 2, all reinforced plastic composites 

processes are combined into one process subcategory except for entirely closed molding 

processes (RTM and Compression/Injection Molding) and the MACT floor is based on the 

resin HAP content and the resin application method except for filled spray applications. 

Ms. Strum indicated that the MACT floor for this option is a 30 percent resin content limit 

or equivalent and non-spray resin application methods for Spray Unfilled, Hand Unfilled, 

Hand Filled, Continuous Lamination/Casting, Pultrusion, and Filament Winding operations. 

According to Ms. Strum, a resin application standard was not considered for filled spray 

applications because non-spray resin application devices, such as flow coaters or pressure 

fed rollers, may not be able to be used to apply filled resins. Ms. Strum added that facilities 

that spray unfilled resins may continue their resin spray application provided that they can 

achieve an equivalent emission reduction to a non-spray facility that uses a 30 percent resin 

HAP content, which would require the spray facility to lower its resin HAP content to a 

calculated equivalent of less than 30 percent. 

Ms. Strum explained that the project team questioned the technological feasibility of 

a 30 percent resin HAP content limit for all facilities grouped under Option 2 and noted that 

this resin HAP content limit is largely driven by Polymer Casting, SMC and BMC 

operations. Therefore, the EPA examined Option 3, which presents another possible way to 

simplify the MACT analysis conducted under Option 1. The MACT floor analysis under 

Option 3 combines as many processes as possible into one process subcategory and 

establishes a MACT floor that is considered technologically feasible for all facilities within 

that subcategory. Option 3 groups semi-open/open reinforced plastics processes. Under 

this option, all reinforced plastic composites processes are combined except for Polymer 

Casting, SMC, BMC, and entirely closed molding processes (RTM and 

Compression/Injection Molding). Ms. Strum explained that the MACT floor for Option 3 is 

determined based on the resin HAP content and the resin application method except for 

filled spray applications. Ms. Strum indicated that the MACT floor for this option is a 34 

percent resin content limit or equivalent and non-spray resin application methods for Spray 

3 
_R5_ 

Madeleine Strum 

June 24, 1997 

Page 4 

Unfilled, Hand Unfilled, Hand Filled, Continuous Lamination/Casting, Pultrusion, and 

Filament Winding operations. Ms. Strum added that, as described under Option 2, facilities 

that spray unfilled resins may continue their resin spray application provided that they can 

achieve an equivalent emission reduction to a non-spray facility that uses a 34 percent resin 

HAP content, which would require the spray facility to lower their resin HAP content to a 

calculated equivalent of 32 percent. The MACT floor for Spray Filled is a 34 percent resin 

content limit or equivalent without a resin application method standard for the same reason 

as explained under Option 2. Ms. Strum pointed out that under this option, the MACT 

floor for Polymer Casting is a 28 percent resin content limit or equivalent. As Ms. Strum 

indicated, the MACT floor for BMC Manufacturing under this option is a 6 percent 

emission reduction. According to Ms. Strum, the best controlled BMC Manufacturing 

facility reduces its emissions by 95 percent by using an oxidizer, the second best controlled 

facility uses pollution prevention techniques to reduce emissions by approximately 70 

percent, and the third best controlled facility, which sets the MACT floor, reduces 

emissions by an estimated^p^ehfthrougrT the useof carbon filters. 

In discussion of the resin HAP content limits, Ms. Dehmlow asked if the resin HAP 

content only referred to styrene or a combination of HAP. Ms. Strum responded by 

explaining that the resin HAP content includes a combination of all volatile organic HAP. 

After presenting these 3 MACT analysis options, Ms. Strum explained that the EPA 

favors "Option 3 because it offers a simple, technologically feasible compliance option, while 

still offering other, but more complex, options to comply through equivalencies that can be 

incorporated into the standard. Ms. Strum indicated that the EPA would like to get some 

help from industry in incorporating equivalencies into the standard. In particular, Ms. 

Strum asked for information on which emission reduction techniques could be identified as 

equivalencies in the rule and how compliance can be demonstrated for these emission 

reduction techniques. Ms. Strum pointed out that she would like more information on how 

compliance could be demonstrated if emission reduction techniques such as vacuum bagging 

or vapor-suppressants would be used. Ms. Strum indicated that she did not like to use the 

SCAQMD can lid test to determine the effectiveness of vapor-suppressants because the test 

did not correlate well with emissions. 

Ms. Strum proceeded by presenting calculated industry emissions and the MACT 

floor emission reduction results for each of the 3 MACT analysis options for noncorrosionresistant resins. Ms. Strum emphasized that while the emission factors used to calculate 

overall process emissions from the entire industry are believed to be a good overall estimate 

of emissions, the average process emission factors should not be used to calculate facility 

specific emissions because the emission factors that are used for a given process may vary 

among facilities within the same process depending on process specifics, including ambient 

conditions. 

4 
P.6 

Madeleine Strum 

June 24, 1997 

Page 5 

Ms. Dehmlow inquired why the process specific MACT database tables that were 

recently distributed to industry showed a column with the pounds of HAP emissions per ton 

of resin used for only some of the process database tables. Ms. Strum responded that this 

column was used to rank some of the process subcategories considered under Option 1, but 

the column was not necessary for all process categories under this option; nor is it necessary 

for Option 3, the current option. Ms. Strum further explained that under Option 1 some 

process subcategories, where different types of emission reduction techniques were reported 

to be used, were ranked based on "pounds of HAP emissions per ton of resin". According 

to Ms. Strum, process subcategories that did not report any emission reduction techniques 

other than, for example, the use of resins with low HAP contents, could be ranked directly 

on the resin HAP content. 

Ms. Strum continued by presenting the MACT floor analysis and the MACT floor 

level results for corrosion-resistant resins. Ms. Strum explained that for the corrosionresistant MACT analysis, corrosion-resistant resin applications from all reinforced plastic 

composites processes are combined into one process subcategory. As Ms. Strum pointed 

out, the processes for which corrosion-resistant resin applications have been identified are 

Hand Layup, Spray Layup, Filament Winding, and Centrifugal Casting operations. 

Ms. Strum explained that in the corrosion-resistant MACT floor analysis previously 

presented to industry, each process with corrosion-resistant resin applications was broken 

out into its own process subcategory. Ms. Strum pointed out that the MACT floor under 

the previous MACT analysis was a 42 percent resin HAP content limit for corrosionresistant Spray Layup. Ms. Strum indicated that after extending the database to include 

potential major sources and after combining all corrosion-resistant processes into one 

process subcategory, the MACT floor under the MACT simplification analysis is a resin 

HAP content limit of 38 percent and non-spray resin application methods. As Ms. Strum 

pointed out, the non-spray resin application requirement applies to all facilities in this 

subcategory, since no significant amounts of filler usage were reported for corrosionresistant applications. Ms. Strum explained that switching to non-spray resin application 

methods is not expected to pose a problem because no significant amounts of filler are being 

used. 

Mr. Schweitzer inquired if the non-spray application requirement is based on 

facilities in the database that reported the use of flow coaters. Ms. Strum replied that the 

non-spray requirement is not based on the use of flow coaters, but that it is based on 

facilities that do not use spray techniques to apply the resin. 

Ms. Herring asked if equivalencies would also be considered for the 38 percent resin 

HAP content limit for corrosion-resistant resins. Ms. Strum responded that equivalencies 

could also be considered for this process subcategory. According to Ms. Strum, a higher 

5 
P.7 

Madeleine Strum 

June 24, 1997 

Page 6 

resin HAP content limit could be allowed, for example, if vacuum bagging is being used. 

Ms. Strum pointed out that some facilities may also be able to use vapor-suppressants for 

corrosion-resistant application, which would allow those facilities to increase their resin 

HAP content above 38 percent. 

Mr. Martens asked if new emission reducing technologies that could be developed in 

the future would be allowed as equivalencies in complying with the MACT standard. Mr. 

Martens added that not allowing for equivalent new emission reduction technologies would 

prevent the development of those new technologies. Ms, Meyer responded that the answer 

to this question is largely dependent on how the rule will be structured. Ms. Meyer pointed 

out that a performance standard would allow the greatest amount of flexibility for industry 

to comply with the standard. Ms. Meyer also pointed out that there is always the option of 

amending the rule to incorporate new technologies that have evolved. Ms. Meyer explained 

that the rule could also spell out the criteria that would have to be fulfilled to determine if 

other means of emission reductions can be considered equivalent to the MACT standard. 

According to Ms. Meyer, it could then be decided on a case-by-case basis if an emission 

reduction measure is equivalent to the MACT standard. 

Mr. Martens inquired if the case-by-case determination would have to be made on an 

emission reduction method or a facility basis. Ms. Meyer replied that the case-by-case 

determination would have to be made on a facility basis. Ms. Meyer added that once a 

number of facilities have shown that a particular emission reduction method is equivalent to 

the MACT standard for the facilities tested, it usually becomes easier for other facilities to 

demonstrate the equivalency of this particular emission reduction method, which could lead 

to an acceptance of a particular emission reduction method. 

Ms. Proctor asked Mr. Martens if he had any particular emission reduction methods 

in mind when he asked about equivalencies of upcoming emission reduction technologies. 

Mr. Martens replied that he was thinking about technologies like UV curing, the SCRIMP 

process, and new resin formulations with higher strength characteristics that allow the use 

of less resin and monomer per part by making the part thinner. 

Ms. Strum pointed out that she would like to allow the use of the SCRIMP process 

as an equivalent option to comply with the MACT standard. Ms. Strum agreed that new 

resin formulations could potentially result in the use of less resin, however, she pointed out 

that she could not imagine how the use of less resin could be incorporated into the rule 

without imposing production limits. 

Mr. Martens stated that resins with lower HAP contents generally have lower 

molecular weights and the low molecular weight resins are generally less strong and more 

brittle than those with higher molecular weights. Mr. Martens pointed out that facilities 

(o 
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Madeleine Strum 

June 24, 1997 

Page 7 

might use the low HAP, low molecular weight resins that have inferior strength properties 

to comply with the MACT standard, but facilities might make the part thicker by using 

more resin to increase the strength of the part, which might result in the same HAP 

emissions as if they were using a resin with a higher HAP content and better strength 

properties. 

Mr. Martens also pointed out that products that require high filler loadings, such as 

corrosion-resistant polymer concrete, may need resins with a higher monomer content to 

produce a good product. Ms. Strum responded that there are facilities in the MACT 

database with high filler loadings and low monomer contents. Mr. McNally replied that 

most products with high filler contents need high resin monomer contents. Mr. McNally 

added that only products such as cultured marble bath products could have high filler 

loadings and resins with low HAP monomer contents. 

Ms. Strum explained that in determining the MACT floors no preferential treatment 

was given to facilities that use high amounts of filler. Mr. McNally disagreed by pointing 

out that he thought that the term "HAP percent in the neat resin plus" meant that facilities 

were allowed to include their filler to determine the resin HAP content. Ms. Strum replied 

that Mr. McNally's interpretation was incorrect and that the term "HAP percent in the neat 

resin plus" meant that any additional HAP that is added to the resin at the facility should be 

included in determining the overall resin HAP content. According to Ms. Strum, filler or 

any other resin additives except for HAP monomer should not be included in the resin HAP 

content calculation. 

Mr. Meardon directed the focus of the meeting back to Mr. Jordan's introduction of 

the briefing and the results of the MACT simplification analysis. Mr. Meardon asked if 

industry representatives could provide any feedback concerning the approach and the results 

of the MACT simplification analysis. In addition, Mr. Meardon asked industry 

representatives to focus on equivalent MACT floor options if possible. Mr. Schweitzer 

responded by saying that industry would have to examine the results and the implications of 

the new analysis more carefully before they could provide any specific coniments. 

However, Mr. Schweitzer explained that industry would in general prefer a more flexible 

standard that would allow them to be innovative in complying with the MACT standard. 

Mr. Schweitzer further pointed out that a performance standard would provide the 

maximum amount of flexibility for facilities to comply with the MACT standard, which 

would encourage the development of innovative emission reduction techniques. 

Ms. Strum emphasized that the EPA prefers to write performance standards when 

ever possible, but the problem for this industry is that very little emissions data are available 

to set a performance standard. Ms. Meyer added that a performance standard would require 

1 
P.9 

Madeleine Strum 

June 24, 1997 

Page 8 

facilities to test their emissions and to conduct continuous process monitoring to 

demonstrate compliance. 

Mr. Schweitzer asked if emission factors could be used to calculate a performance 

standard in terms of "pounds of emissions per ton of resin used" to determine the equivalent 

performance standard to a given resin HAP content limit. Ms. Strum replied that this might 

not be possible because, even within the same process, individual facility emission factors 

vary greatly. Ms. Strum added that the EPA might further investigate the feasibility of this 

option. 

It was also pointed out that if the standard was based on calculated "lb emission/ton 

resin" as an equivalency for a resin HAP content limit, a facility that conducts emission 

testing might find that they are not in compliance with the calculated equivalency even 

though it meets the resin HAP content limit. This might occur because the facility's 

emission factor is not the same as the assumed process average emission factor that was 

used to set the calculated performance standard. 

In a discussion about the possible options to set the MACT floor standard, Ms. 

Meyer described the latitude the EPA has in stetting MACT standards leading Mr. McNally 

to the idea of basing the MACT standard on an emission cap. Ms. Meyer pointed out that 

in order to set an emission cap, the EPA would have to show that this emission limit is 

equivalent to the MACT floor. Mr. McNally indicated that the approach to set an emissions 

cap could have some merit in that it would still allow innovation and flexibility for the 

industry. Ms. Meyer added that this approach would, of course, still require facilities to 

test emissions and to do continuous process monitoring. Concerns were raised whether an 

emissions cap would limit facility growth. Mr. McNally thought an emissions cap would 

encourage facilities to find innovative solutions to reduce their emissions. Ms. Meyer, on 

the other hand, felt an emissions cap could limit a facility's growth options. 

The industry representatives indicated that they would like to further review the 

material and the options discussed in this meeting. Mr. Schweitzer asked if a follow up 

meeting could be scheduled to allow industry to respond to the issues raised today after 

discussing these issues with members of the industry. A tentative date was set for July 8, 

1997 to meet at the EPA/Mutual Building to continue the discussion. (This date was later 

changed to August 14, 1997). 
P.10 

PROJECT BRIEFING 

REINFORCED PLASTIC COMPOSITES PRODUCTION 

EXISTING SOURCE MACT ANALYSIS 

BRIEFING FOR: 

Society ofthe Plastics Industry/Composites Institute and 

Composite Fabricators Association Representatives 

Project Lead: Madeleine Strum 

May 9,1997 

°i 
P.11 

OUTLINE 

Part A Noncorrosion-Resistant Resins - Existing Sources 

• Process Subcategory Groupings 

MACT Floor Level Results 

• MACT Floor Emission Reduction Results 

Part B Corrosion-Resistant Resins - Existing Sources 

• Process Subcategory Grouping 

• MACT Floor Level Results 

• MACT Floor Emission Reduction Results 

o 
P.12 

PROCESS SUBCATEGORY GROUPINGS FOR 

NONCORROSION-RESISTANT RESINS 

Option 1 - All process subcategories separate (present basis) 

Option 2 - Combine all subcategories except for Closed Molding 

(RTM & Compression/Injection Molding) and 

determine MACT floor based on resin HAP content and 

resin application method except for filled spray 

application 

Option 3 - Combine all subcategories except for BMC, SMC, 

Polymer Casting, and Closed Molding (RTM & 

Compression/Injection Molding) and determine MACT 

floor based on resin HAP content and resin application 

method except for filled spray application 

Part A - Noncorrosion-Resistant Resins 

ll 
Comparison of Existing Source MACT Floors for Different Grouping Options in 

Noncorrosion-Resistant Applications 

^ 

Process Subcategory 

Spray Filled 

Spray Unfilled 

Hand Unfilled 

Hand Filled 

Continuous Lamination/Casting 

Pultrusion 

Filament Winding 

Polymer Casting 

SMC 

BMC 

RTM 

Compression/Injection Molding 

Option 1: 

All Separate 

35% HAP or 38% HAP VSR 

33.5% HAP or 39% HAP VSR 

32% HAP or 40% HAP VSR 

35% HAP or 38% HAP VSR 

to be determined 

30 lbs emissions per ton of resin 

33% HAP 

28% HAP 

no numerical limit 

6% emission reduction 

no numerical limit 

no numerical limit 

Option 2: 

All Combined Except Closed 

Molding 

30%HA1><M-

«quiyaie*tt 

non-spray and 30% HAP or 

equivalent 

or 

spray and less than 30% HAP* or 

equivalent 

no numerical limit 

no numerical limit 

Option 3: 

All Combined Except 

Polymer Casting, Closed 

Molding, SMC & BMC 

34%HAi*ar 

eqaivalfiHt 

non-spray and 34% HAP or 

equivalent 

or 

spray and 32% HAP or 

equivalent 

28% HAP 

no numerical limit 

6% emission reduction 

no numerical limit 

no numerical limit 

The equivalent resin HAP content for spray application is still to be calculated. 

Part A - Noncorrosion-Resistant Resins 
u> 

Comparison of Expected MACT Emission Reductions for Different Grouping Options in 

Noncorrosion-Resistant Applications at Existing Facilities (Tons per Year) 

Process Subcategory 

Spray Filled 

Spray Unfilled 

Hand Unfilled 

Hand Filled 

Continuous Lamination/Casting 

Pultrusion 

Filament Winding 

Polymer Casting 

SMC 

BMC 

RTM 

Compression/Injection Molding 

TOTAL EMISSIONS ** 

EMISSION REDUCTION 

Current 

Emissions 

6,491 

1,819 

225 

214 

537 

436 

45 

134 

250 

121 

10 

604 

14,942 

Option 1: 

All Separate 

2,597 

860 

87 

35 

> 0 * 

264 

0 

28 

0 

6 

0 

0 

Option 2: 

All Combined Except 

Closed Molding 

3,823 

1,202 

94 

71 

148 

102 

5 

21 

69 

16 

0 

0 

Option 3: 

All Combined Except 

Polymer Casting, Closed 

Molding, SMC & BMC 

2,914 . 

1,016 

62 

41 

97 

62 

0 

28 

0 

6 

0 

0 

>3,877 5,551 4,226 

* MACT emission reductions for this process are still to be determined once testing at LASCO is completed. The current estimate is conservative and 

assumes no emission reduction from this process. 

** Total emissions include emissions from gel coating. 

Part A - Noncorrosion-Resistant Resins 5 
P.15 

<*••• 

PROCESS SUBCATEGORY GROUPING FOR 

CORROSION-RESISTANT RESINS 

Combine all corrosion-resistant subcategories (Hand & Spray 

Layup, Filament Winding, and Centrifugal Casting) and base the 

MACT floor on the resin application method and the resin HAP 

content 

Existing Source MACT Floor for Corrosion-Resistant Applications 

Process Subcategory 

Hand 

Spray 

Filament Winding 

Centrifugal Casting 

Application Method & Resin HAP 

Percent 

Non-Spray Resin 

Application 

& 

38% HAP or equivalent 

Expected MACT Emission Reductions for Corrosion-Resistant 

Applications at Existing Facilities (Tons per Year) 

Process Subcategory 

Hand 

Spray 

Filament Winding 

Centrifugal Casting 

TOTAL EMISSIONS 

EMISSION REDUCTIONS 

Current 

Emissions 

146 

427 

337 

217 

Application Method & Resin HAP 

Percent 

40 

BBBHHB ^ 

|^||||||||||||iHl||lllllISII|| 

^^^^^^^^^ B 

1,127 

390 

Part B - Corrosion-Resistant Resins 

IH