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OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

20) II-J-11 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 20 of 36 
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TANKS 

EPA January 7, 2000 

Mail Drop 13 

Research Triangle Park, NC 27711 

Attn: Mr. Keith Barnett 

Subject: MACT Commentary 

We are writing as a follow up to our previous joint meeting on December 14, 1999. We would 

like to comment on what we do and the effects we currently expect from the MACT proposal. 

Justin Tanks has provided FRP tanks to a broad industry for over (40) years. Markets include 

Water Treatment, Waste Water Treatment, Food Processing, Pulp & Paper, Chemical, as 

well as others. Each of these markets have unique requirements and buying methodologies. 

As a result of industry competition, each of these markets has become very competitive, thus 

driving down margins. 

Annual sales at our facility over the last five years have averaged 3.4 million with pre-tax 

profits in the range of 2%. We employ an average of (35) employees, the core ofwhich has 

15-20 years service with our company. 

The working life span of our equipment, is directly related to its quality. The quality levels we 

sustain are a function of the workability of the resin systems. The majority of the resins we 

use are in the 45-50 % HAP range. The higher HAP resins are used, not only for their 

competitive pricing, but to allow us to achieve the quality requirements demanded by our 

customer base. Typically the lower the HAP, the more difficult it is to reduce wet out time and 

achieve air free laminates. 

The driving force behind the MACT will force us to move to lower HAP resins, a 100% 

conversion of our spray equipment, rework all labor processes and provide for additional 

record keeping. Each of these has direct cost impacts. 

The core of our resin systems has a HAP content of 45-50%. The average cost of these 

resins, is in the range of $1.20/lb. Bear in mind, the purchase price of resins is based on user 

volumes. Lower HAP resins average $1.95/lb. The base cost differential results in a 63% 

increase in raw material cost per pound of resin used for the lower HAP. 

One rational may be to move directly to the lower HAP resins, unfortunately in our markets, 

we would loose 50% of our sales. These customers would move to more cost effective 

JUSTIN TANKS, L.L.C. • 8 Cedar Creek Avenue • P.O. Box 825 • Georgetown, DE 19947 

(302) 856-3521 • FAX (302) 856-3527 
P.3 

materials. This would require us to develop new markets, which are currently not defined and 

may not even be there. 

Bear in mind, the "End User" typically defines the resin based on compatability for service, 

not HAP content. To change this, will require a major emphasis change with resin suppliers, 

engineering groups and fabricators. It will be like re-inventing the industry. I don't think the 

"End User" will accept the transition with open arms. 

Conversion of equipment to "flow coaters", other than the expense, is not a big impact. There 

are back end benefits, which provide positive results. Particularly with worker exposure to 

emmisions. We have already started converting our small spray unit over to "flow coaters". 

The main problem we foresee is with our Venus Chop Hoop machine. This is a high volume 

(resin) tank fabrication machine. Venus has yet to fully develop and test a "flow coater" type 

spray system for this machine. Conversion cost for this equipment is yet to be defined. This 

is a $350,000.00 investment that will not satisfy MACT as it is currently operating. 

Transitioning into a MACT compliant environment will require redevelopment of all our 

process' as well as retraining of all employees. The estimated cost impact over the first year 

will be $25,000.00-35,000.00. 

Record keeping for MACT compliance is going to be extensive. Due the quantity of resin 

systems and process' to report on, we expect the yearly impact to be a minimum of 

$45,000.00. 

We have run numbers on the last seven months of production using the new UEF factors and 

taking advantage of the "flow coaters" in areas where they are in use. These calculations put 

us at a monthly average of 120% of the MACT floor. The highest month was 140.5 % and the 

lowest was 100.3 % of the floor. We will point out the lowest reported month was a time when 

our production ran the highest volume of low HAP resin. This evaluation concerns us and we 

question the validity of the current MACT floors. 

If through the use of low HAP resins and "flow Coaters", we are unable to achieve the floor, 

the next option is to go to add on controls. Rob Haberiein has been to our facility and I have 

attached a copy of his initial report. In summary, he recommends a preconcentrator, which 

would have a maximum capture of 85%. The cost of the system would be $3,000,000.00 with 

an annual operating cost of $600,000.00. Assuming 50 tpy of capture, which is high, the 

system would cost in excess bf $10,000.00 per ton. 

If MACT proceeds in its current direction, I feel it is going to be very difficult to achieve to 

floors. We will very likely close the doors. There is no way to justify the additional 

expenditures required for add-on controls, if we cannot meet the floor without them. 

As additional information, I have enclosed some photos of our shop and product we fabricate. 

You should note the complexity and size of the equipment. If you can, you should visit our 

web site-justintanks.com. 
P.4 

I would like to thank you for this opportunity. I trust the EPA will re-evaluate their approach 

and look for a better way, which allows companies like ours to continue our long standing 

history of supplying equipment to the industry. 

Respectfully 

President 
P.5 

A lamination operations at Justin occur in four distinct areas: 

Horizontal Mandrel Stations - two stations located together in one area. These stations produce 

extremely large tank vessels using manual application, mechanical application, and 

filament winding. 

Vertical Mandrel Stations (6) - six stations located together in one area. These stations produce 

small to extremely large tank vessels using manual application, mechanical application, 

and filament winding. 

Part Assembly - the large tank parts are assembled on the open shop floor using mostly manual 

and some mechanical application. 

Small Parts Fabrication - small ancillary tank parts are produced on numerous small tables 

using manual application. 

The maximal capture system for the combined operations at Justin would consist of the 

following enclosures: 

Horizontal Mandrel Stations - one large horizontal flow booth enclosure with an open door and 

about 40,000 cfm of exhaust to capture the emissions. This booth will have a new fixed 

rear wall with large filtered exhaust inlets. The total project cost for the horizontal booth 

would probably be in excess of $120,000. 

Vertical Mandrel Stations - six vertical booths (one per station) with at least 15,000 cfm per 

booth. These booths will have moveable side curtains, ceiling supply and in-ground 

floor exhaust. These booths will require extensive reconstruction to install. The total 

project cost for the vertical booths would probably be in excess of $300,000. 

Part Assembly - due to the large size ofthe parts and scattered locations across the plant floor, 

the only practical approach would be to make the building into a Building Enclosure. 

Unfortunately, the existing building is very leaky, and the exterior doors cannot be closed 

during production. The doors are opened to allow for ingress and egress of parts, tools, 

raw materials, and waste, and to cool the employees in the summer months. For these 

reasons, part assembly cannot be practically enclosed. The emissions from this area may 

be as much as 5% ofthe total emissions. 

Small Parts Fabrication - small enclosures must be custom designed to match each type of 

small part. This is too complicated to assess at this time and would require extensive 

design and experimentation. For these reasons, Small Parts Fabrication cannot be 

practically enclosed at this time. The emissions from this area may as much as 5% ofthe 

total emissions. 

Due to the sporadic emissions pattern, high exhaust flow rate, and low exhaust concentration, the 

only feasible control technology option would be a preconcentrator oxidizer system similar to the 

Durr system at Aker Plastics in West Virginia. This system would be sized at 130,000 cfm to 
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include the total exhaust flows from the horizontal and vertical booths. The approximate 

installed cost for the Durr system and the new enclosures would be in excess of $3 million. The 

annualized control cost would be in excess of $600,000 per year (based on the reported costs for 

the Aker system). 

Assuming about 50 tpy of captured emissions per year, the control cost effectiveness for the 

maximal capture and control system would be in excess of $10,000 per ton. Note that less than 

85% ofthe total plant emissions would be captured by this system. 

Rob Haberiein 

January 6, 2000 
P.7 

Date 

Company 

Plant 

Period 

12/22/99 

Justin Tanks, LLC 

Plant Summary of MACT Point Values and Styrene Emissions 

MONTH 

May-99 

Jun-99 

Jul-99 

Aug-99 

Sep-99 

Oct-99 

Nov-99 

Dec-99 

Jan-00 

Feb-00 

Mar-00 

Apr-00 

Total 

Monthly 

Material 

Usage 

see note 1 

(lb/mo) 

43,951 

22,099 

27,781 

29,030 

27,480 

32,601 

28,159 

0 

0 

0 

0 

0 

Monthly 

Weighted 

Average 

MACT 

Point Value 

see note 2 

(Ib/ton) 

250.3 

218.3 

192.2 

201.1 

183.0 

203.5 

174.3 

0.0 

0.0 

0.0 

0.0 

0.0 

Monthly 

Weighted 

Average 

MACT 

Floor 

see note 3 

(Ib/ton) 

178.1 

169.9 

170.2 

163.3 

168.8 

174.1 

173.9 

0.0 

0.0 

0.0 

0.0 

0.0 

Monthly 

Weighted 

Percent of 

MACT 

Floor 

see note 4 

(% of floor) 

140.5% 

128.5% 

112.9% 

123.2% 

108.4% 

116.9% 

100.3% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

Rolling 

12-Month 

Weighted 

Average 

Percent of 

MACT 

Floor 

see note 5 

(% of floor) 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Total 

Monthly 

Styrene 

Emissions 

based on 

UEF Factors 

see note 6 

(lb/mo) 

5,298 

2,301 

2,500 

2,681 

2,236 

2,737 

1,929 

0 

0 

0 

0 

0 

Total Annual Styrene Emissions (lb/yr) 19,682 
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_ _ 

TANKS 

AMERICAS FOREMOST PROVIDER OF CUSTOM 

ENGINEERED FIBERGLASS TANKS. 

For more than 40 years, Justin has provided cost effective Fiberglass 

Reinforced Plastic (FRP) tanks and ancillary products for a wide range 

of applications. Our expertise has earned us the reputation among our satisfied 

Fortune 100 customers that "Justin tanks never fail". 

Justin with its pioneering technology builds the world's finest tanks with 

a wide variety of configurations. Our FRP tanks and vessels provide 

outstanding corrosion resistance, standing up to a wide range of temperatures , 

acids, alkalies, and other corrosive chemicals. FRP tanks costs less, provide a greater strength to 

weight ratio than steel or alloys, have an excellent thermal value and perform better than 

other materials in a variety of applications. 

The Justin plant located in Sussex County Airpark in Georgetown, Delaware, is 

one of the few in the industry specifically designed and built to fabricate FRI3 tanks and 

equipment. Through the use of multi-station vertical and horizontal winders, Justin provides 

tanks with diameters ranging from 3 through 14 foot. Tanks 

are fabricated utilizing both filament wound and contact molded processes. 

Non standard diameters and configurations are also available 

to meet customer needs. 

Justin's highly skilled team provides complete solutions j 

and stand by support from design through installation. 

We support our product during all phases of the project. 

< 

Fabrication 

Field Service 

. 
P.20 

40 Years of Manufacturing Integrity 

You Can Rely On 

i KB 

, _ 
P.21 

Justin manufactures accessory items to meet 

your process requirements .. . exactly! 

We Say What We Build, 

Build What We Say! 

Service 

For JUSTIN TANKS L.L.C 

P.O. Box 825 • 8 Cedar Creek Ave. 

Georgetown, DE 19947 

(302) 856-3521 • FAX (302) 856-3527 

www.justintanks.com 
P.22 

JUSTIN TANKS IS COMMITTED TO PROVIDING HIGH QUALITY 

LIQUID STORAGE TANKS THROUGH A PARTNERSHIP OF 

SERVICE, THROUGHOUT THE LIFECYCLE OF OUR PRODUCT. 

Justin Provides 

• Most Economically Viable Solutions with 

Uncompromising Quality 

• Engineering and Specifications for a Variety 

of Customer Specific Applications 

• Access to Quality Inspection Records 

^ ^ All Resin Systems and Applications 

^ ^ » Computer Aided Designs 

• Field Modifications and Repair 

• Mixer Systems 

Full Compliment of Accessories Including; 

• Agitation 

• Factory Insulated Tanks 

• Temperature Maintenance Systems 

• Platforms & Walkways 

• Ladders & Cages 

• Handrail Systems 

• Flanged Nozzles & Access Manways 

Justin Capabilities 

Filament Wound and Contact Molded Tanks 

Built to Industiy or Customer Specific Standards 

Size is Determined by Shipping and Handling 

Limitations - Usually Up to 14' ft. Diameter 

Vertical, Horizontal and Rectangular 

Configurations 

Dished, Coned or Flat Bottoms 

Industries Served 

Chemical 

Food Processing 

Pulp and Paper 

Water Treatment 

Waste Water Treatment 

Brewing & Distillation 

Ph.irm.ieeutie.il 

Biological 

Enerav 

Paint & Dye 

Aqu.ieiiltiue 

• • 

_. - ., • . 

____A:.!f-x.» i 

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