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OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

26) II-J-17 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 26 of 36 
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Fiberglass Systems, Inc. 

Boise, Idaho 

Telephone: 208.342.6823 tf- J-O 

Mr. Keith Barnett, project lead 

Office of Air Planning and Standards 

United States environmental Protection Agency 

MD13 

Research Triangle Park, NC 27711 

y 26, 2000 

Dear Mr. Barnett: 

This is my third letter addressed to the Project Lead concerning issues raised as EPA has 

proceeded towards promulgation of our industry's MACT standard. My two previous 

letters were in October 1998 and January 1999 addressed to Dr. Strum. 

There are a number of issues that concern me, primarily as the owner of a small business 

and secondarily as an active member of our national trade association. These are the issues 

that need to be addressed by EPA and resolved so the MACT standard does not shut down a 

large component of our industry: 

*EPA should be careful not to require a control technology (incinerators) that cause 

more environmental harm (Nox, C02 etc.) than benefit. 

*My company can not afford to install and operate an incinerator. 

*My company can not practically achieve the capture efficiencies needed to feed an 

incinerator. 

*Our industry is so complex, especially for companies under $15 million in sales who 

are custom molders or niche product companies, it may be impossible to identify a 

subcategory or group for which incinerators make sense. 

* Companies have been focused for a number of years to achieve low styrene 

emission concentrations to protect our workers, which makes incinerators more expensive. 

*For pigmented gel coal we need a HAP limit of 37% or higher. 

*We fill resins at levels from 10% to 50%, and all of these should meet the MACT 

definition of a filled system. 

*MACT needs to allow the use of not-yet-developed technologies, like a new 

generation of resin application guns, or something that is new and revolutionary. 

*One of the specification advantages Fiberglass Systems has in the development of 

our niche product line is the use of a high-HAP tooling resin as a component of a wheel 

chair accessible shower stall. This has afforded us a level of success in a market where our 

competitors are 30 to 50 times larger than us and in the majority of cases owned by billion 
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dollar holding companies. The MACT you develop needs to allow those of us who are 

small business to continue to have the ability to compete in the market place. 

Styrene should not even be on the list for the host of reasons you are already cognizant. If 

you and others are correct and there is not the political will to refine the Clean Air Act, you 

do have it within your authority to develop a MACT that modifies how styrene is managed. 

Removing styrene and in the process dumping emissions in the air that are proven to have 

environmentally negative impacts makes no logical sense. To select this process because it 

is easy to monitor or regulate is circumventing the overriding goal, which is cleaner air. I 

was raised to believe that "easy is not always the best way" and it was disturbing to me 

when I heard you say incineration is the method of choice because it will be easy to monitor 

and enforce. Working together to achieve cleaner air should be our collective goal. 

Removing one pollutant and in the process generating an even greater environmental harm 

is not correct by any logical standards. It is time to acknowledge that incineration is a bad 

idea and to move on to better options. 

In the particular situation of Fiberglass Systems incineration is very problematic. As I 

understand the engineering requirements relayed to me by my plant engineer from his 

consultation with Frees, Inc., the stack needs to be 30% higher than the top of our building. 

By the time I meet the stack requirements it would fall onto the railroad right of way, 

beyond our property boundary, creating an uninsurable risk. On the other side of the 

building the local fire department has not allowed any obstructions attached to the building 

in the alley separating property lines. 

As I understand your proposed MACT, the rule making will devastate the small business 

intenties that comprise a huge portion of the industry employment base. By definition as a 

group we fabricate a broad spectrum of product, which in most companies do not conform 

to automation techniques. If we have been successful enough so that our production 

volumes force us into "incineration levels" it does not necessarily relate that our profit 

margins will justify the capital expenditure necessary to install the incineration equipment. 

Capture efficiencies you are proposing will be extremely hard to achieve when the product 

line is as varied as it is in my company. From what I understand to be the environment 

necessary to achieve a capture efficiency of 95 percent, companies like mine will never be 

able to comply because of a variety of obstacles, some of which I will attempt to describe. 

Your proposed MACT requires that no more than two percent of the side walls of a building 

can open. Locking or blocking doors violates fire codes. In hot climates, like Boise during 

the summer, it is impractical and futile to tell your labor force the roll up doors must be 

secured shut. Our current exhaust fans, with strategically open doors provides a cooling 

effect on the production floor. Losing the ability to utilize open doors would probably 

dictate the installation of air conditioning throughout the production plant, which would not 

economically pencil out. But, if we could justify installing coolers on the make-up air units 

and then, as required by the proposed MACT maintain 200cfm through any openings it 

would not be possible to capture at 95 percent efficiency because of the dilution that would 
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take place. Based on Fiberglass Systems profitability the past three years, and our budget 

for 2000 and 2001, it would be economic suicide to install an incineration system that 

mightr cost as little as $1,000,000. But the cost will be closer and more than likely over 

$2,000,000 for incineration plus the likely additional cost of refrigeration for cooling. 

Another issue concerning installation of an incinerator is also pertains to any improvement 

or modification of the current facility that is equal to 51 percent of the fully depreciated 

asset of the affected process. Virtually any scenario, including the process of replacing 

spray guns with flow-coaters would force a company the size of Fiberglass Systems into a 

new or reconstructed MACT by trying to comply with the proposed MACT. As I 

understand it you have built a "catch-22" into the proposed MACT. 

Even if there is a logical way to detennine sub-groups it appears to me that given the huge 

variety of product plus the wide variety of processes used to produce those products it will 

be impossible for incineration, which appears to be your preferred choice to meet the 

Agencies definition of categories and subcategories which is ..."a similar source as a source 

that has comparable emissions, and a design and capacity structure, such that emissions 

from that source can be controlled using the same control technology applied to the given 

source." This definition does not comply with the various realities open-mold fabricators 

operate under producing product using a variety of processes meeting numerous and widely 

varied specifications. 

Another problem that needs to be addressed is concentration of fumes. Simply stated we 

currently focus on dilution of fumes to comply with OSHA rules. Your proposal will 

require concentration of fumes. Which will prove problematic in many of our facilities, plus 

most likely, put us in direct violation of OSHA rules. When rule making by sister agencies 

conflict we are placed in an "impossible situation" and again we have no choice but to 

object. If capture and incineration becomes the rule as it is now proposed you will 

deliberately propose a rule that will, by its promulgation and enforcement, automatically 

require members of this industry to violate established and proposed OSHA rules. Doing so 

will not only be poor public policy but a demonstration of willful bad faith in your dealings 

with, both, the industry and your sister agency. The conflict between OSHA rules and the 

proposed rule is real. As I understand the CFR you are restricted from promulgating a rule 

that conflicts with an existing rule. 

Fiberglass Systems is permitted for 248 tons. Under your proposed rule we will be forced 

to put in incineration unless we reapply for new permits. Currently we should be able to 

comply with the proposed rule by taking advantage of every opportunity your ruling 

identifies as reducing styrene emissions. By the time the rule officially is enforced we 

would in all likelihood not comply. If we elect to apply for new permits under the proposed 

MACT level we would have no room for growth and place ourselves in a position of 

possibly not being permitted for a higher level of production when we have the opportunity 

to grow. If we don't elect to apply for new permits we are placed in a position that is truly 
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devastating to our business as it has evolved. Obviously after spending 30 years in my 

profession of choice fabricating product recognized as "the best" in our niche market 

nationwide I will not just "fold up my tent" and go home. 

The MACT floors for Pigmented Gel Coating is very troubling. Excluding our Tooling gel 

coat use, ofwhich we consumed 1,970 pounds, we used 18 different colors all of them with 

either a 37 or 38 percent styrene level. The combined usage for these colors is 6,658 

pounds or four percent of our sales. But with our nation wide market niche this low number 

is not indicative of the importance of offering these colors. Of the actual gel coats we 

consumed only the LOW VOC WHITE we have tried has a HAP of 30. The 10 surface 

coats we apply that are 24% HAP are a sprayable solid surface finish we offer that totals 

less than one percent of our sales. Personally, I am confident our gel-coat suppliers will be 

able, over time, to provide gel coats with lower HAPS that consistently meet industry 

standards and expectations. The key to success is offering sufficient time to identify the 

chemistry and create materials for the industry to use. To arbitrarily dictate a reduction of 

styrene by 25% in a product as sensitive as polyester gel-coat is reckless. A 30% HAP 

should work for our industry if there is a 10-year phase in time. Write the rule at 40 

reducing it one percent per year for 10 years. Then everyone wins including the air. 

My concerns on resin are three-fold. First, Fiberglass System's fills at three different levels 

depending on the application. Our lowest ratio is 10 percent filler our highest is 50 percent. 

What qualifies as a "filled resin?" Identifying "flow-coaters" in the rule is restrictive, 

confining, capricious and arbitrary. But, even worse it restrains future development of 

equipment advances for our industry. How will the rule be reopened when a new 

revolutionary piece of equipment is developed that currently is not even conceptual? Third, 

when is tooling resin classified as tooling resin? Fiberglass Systems uses tooling resin as a 

significant resin component of one of our product lines. We do so for the property reasons 

most fabricators use tooling resin for "tools" instead of standard production resins. Frankly, 

there is a strong argument for using tooling resins for our entire product line, but to date we 

have elected to proceed with this possibility very slowly. If we produce a product line that 

uses tooling resin are we allowed under the proposed MACT to use 50% HAP material? 

My general reaction to the proposed rule concerning resin is the same as for gel coat, but 

with this caveat, "don't propose a rule that limits the opportunity or potential for invention 

and innovation, the current one does and if it is adopted the opposition should be huge and 

organized." 

I have attempted to illustrate why the proposed MACT will be devastating to Fiberglass 

Systems. We understand that MACT is a reality. Our goal is that you propose MACT that 

affords us an opportunity to continue to provide stable jobs and product in the market place, 

while competing with Big Business. 

Truly Yours 

Gary Multanen