p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

13) ll-J-4 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 13 of 36 
P.2 

XL 

From: KEITH BARNETT p N AN A \ I 

TO: ALDRIDGE -AMANDA GA. S «***• fc^*** U •**** * l*¥"*»* |. 

Date: 1/4/00 3:17pm 

Subject: Costs for the Reinforced Plastics Composites MACjT 

To the Small Entity Owners/Operators: 

Based on the December 14 small entity outreach meeting, and a subsequent 

meeting with representatives of the Composites Fabricators Association, I 

wanted to send to you some additional information on the approach we are using 

to calculate costs to meet the MACT floors. 

This discussion focuses on the floor level of control for existing sources. 

To meet these floors, open molding facilities would be required to use 

pollution prevention techniques including low HAP resins and gel coats, and 

flow coaters. 

Several times in our discussions, it was implied that if facilities could 

switch to lower HAP materials, they would already have done so. In our 

analysis, we looked for available resins and gel coats that could meet the 

floor. As long as a lower HAP resin/gel coat that appeared to have the 

necessary physical properties was available, we based the floor on switching 

to that resin, even if that meant higher raw materials costs. The 

corresponding raw materials cost increases form the basis of most of the costs 

of meeting the floor level of control. It is these costs that led us to 

determine that their may be significant economic impacts associated with this 

rule, even at the floor level of control. 

The information presented here does not deal with issues of the costs of add 

on controls. That information will be provided at a later time. 

In performing our analysis, we assumed that a facility would use first convert 

flow coaters where possible. We assumed that flow coaters can be used for all 

unfilled resin systems, and cannot be used for filled resins or gel coats. If 

switching to flow coaters would not allow the facility to meet MACT, then they 

would convert to lower HAP gel coats and resins. We did not assume partial 

conversion. We assumed if any resin/gel coat conversion was required, then 

all of the resin in that particular category would be converted. 

Attached is a portion of the cost analysis that discusses costs of converting 

to low HAP resins and gel coats. You may find the analysis a little hard to 

follow, and we are planning to revise the discussion. However, I wanted to go 

ahead and make this available to the small entity representatives so you could 

see our basic methodology for costing existing source floors. 

In reviewing this information, be aware that we tried to determine "typical" 

scenarios for meeting the floor. We realize that the scenario shown will not 

fit every facility. But we do believe it will fit the majority of the 

industry. 

Facilities that believe they can't meet existing source floors still have the 

option of applying some type of partial add on control. These partial control 

options are not nearly as expensive as the 95 percent control options we 

evaluated. It could be as simple as a gas burner in an exhaust stack if it 
P.3 

can be tested and shown to reduce emissions. 

Also attached is a table with the existing source floors, and an estimate of 

the resin/gel coat HAP content required to meet the floor. 
P.4 

6.2 PROCEDURES USED TO ANALYZE COMPLIANCE OPTIONS 

6.2.1 Low HAP Resins for Corrosion Resistant Applications 

Available Cost Information

 CR1 CR

 " 

The EPA collected cost and/or physical properties information for thermoset resins 

designed specifically for corrosion resistant applications from the following major resin 

manufacturers: Alpha Owens Corning (AOC), Ashland Chemical Company, Dow Chemical 

Company, Interplastic Corporation, and Reichhold. 

The cost information submitted by Dow, Interplastic, and Reichhold is summarized in 

Table CR-1. The cost information submitted by Ashland Chemical and AOC was submitted as 

confidential business information (CBI) and is not included in the table. In addition to the cost 

information submitted by the resin manufacturers, two facilities submitted confidential estimates 

of the cost of replacing existing high HAP resins used by their facilities with low HAP resins. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP corrosion resistant resins with low 

HAP corrosion resistant resins. 

Step 1: Select cost and physical properties information from resin manufacturers for the purpose 

of determining the average cost differential associated with replacing a high HAP 

corrosion resistant resin with a low HAP corrosion resistant resin. 

Note 1: Dow Chemical, Interplastic, and Reichhold provided detailed cost and physical 

properties information that could be used for determining the average cost of replacing a 

high HAP corrosion resistant resin with a low HAP corrosion resistant resin. 

Note 2: The information provided by Reichhold was selected because (1) this company 

manufactures high HAP isophthalic and/or bisphenol-A-fumarate resins and low HAP 

vinyl ester resins, and (2) the replacement of a high HAP isophthalic or bisphenol-Afumarate resin with a low HAP vinyl ester resin was assumed to be the most likely resin 

replacement scenario. 

Note 3: The information provided by Dow Chemical and Interplastic was not used 

because it was assumed that the resin replacement scenarios that could be analyzed using 

data from these two companies was less representative than the scenarios that could be 

analyzed using the data from Reichhold. The resin replacement scenarios that could be 

analyzed using the data provided by these two companies were replacing high HAP vinyl 

ester or isophthalic resins with low HAP vinyl ester resins. 

Note 4: Ashland Chemical and AOC only provided cost information for a small number 

of resins that was inadequate for the purpose of determining the average cost differential. 

AOC also did not provide detailed information on the physical properties of the resins 

manufactured by AOC. 
P.5 

Table CR-1. Non-CBI Cost Information for Corrosion Resistant Resins Provided by Resin Manufacturers 

Resin Manufacturer 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Dow Chemical Company 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Interplastics Corporation 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Reichhold 

Resin Product Number 

DERAKANE 411-350 

DERAKANE 411-45 

DERAKANE 411-50 

DERAKANE 470-300 

DERAKANE 470-36 

DERAKANE 441-400 

DERAKANE510A 

DERAKANE510C 

DERAKANE5 ION 

DERAKANE 8084 

COREZYN CORVE8300 

COREZYN CORVE8360-34 

COREZYN CORVE8430 

COREZYN CORVE8440 

COREZYN CORVE8450 

COREZYN CORVE8515-34 

COREZYN CORVE8710 

COREZYN CORVE8730-34 

COREZYN CORVE8730-45 

COREZYN MVR8040 

COREZYN MVR8060 

COREZYN COR75-AQ-010 

COREZYN COR75-AQ-001 

DION 9100 

DION 9300 

ATLAC 580 

DION 9480 

DION 9420 

DION 6694 

ATLAC 382 

ATLAC 4010 

DION 6631 

Resin Typeab 

Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester 

Novalac - Epoxy - Vinyl Ester 

Novalac - Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester (FR) 

Epoxy - Vinyl Ester (FR) 

Novalac - Epoxy - Vinyl Ester (FR) 

Epoxy - Vinyl Ester (TF) 

Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester 

Epoxy - Vinyl Ester (FR) 

Epoxy - Vinyl Ester (FR) 

Epoxy - Vinyl Ester (FR) 

Epoxy - Vinyl Ester (TF) 

Epoxy - Vinyl Ester (High Crosslink) 

Novalac - Epoxy - Vinyl Ester 

Novalac - Epoxy - Vinyl Ester 

Vinyl Ester (FR) 

Vinyl Ester (FR) 

Isophthalic 

Isophthalic 

Bisphenol - Epoxy - Vinyl Ester 

Bisphenol - Epoxy - Vinyl Ester 

Urethane - Vinyl Ester 

Novalac - Epoxy - Vinyl Ester 

Vinyl Ester (High Cross-link) 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Isophthalic 

HAP 

Content 

(% by wt.) 

45.0 

45.0 

50.0 

33.0 

36.0 

33.0 

38.0 

37.0 

35.0 

42.0 

45.0 

35.0 

52.0 

40.0 

40.0 

35.0 

31.0 

35.0 

45.0 

40.0 

40.0 

48.0 

48.0 

43.5 

30.0 

46.0 

39.0 

34.5 

48.0 

50.0 

50.0 

48.0 

Salec 

Price 

($ / lb) 

$1.56 

$1.57 

$1.53 

$1.71 

$1.74 

$1.65 

$2.00 

$1.71 

$2.00 

$1.90 

$1.58 

$1.68 

$1.84 

$1.76 

$1.75 

$2.09 

$1.80 

$2.09 

$1.89 

$1.81 

$2.10 

$1.07 

$1.07 

$1,365 

$1,435 

$1,465 

$2,050 

$1,760 

$1,460 

$1,320 

$1,320 

$1,050 

Sale Price 

Shiptnent 

Size Basis 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

Truck Load 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

80 Drums 

a

FR indicates brominated fire-retardant resin or resin that is fire-retardant with the addition of antimony trioxide or alumina trihydrate. 

indicates a resin with additives (such as an elastomer backbone) designed to produce a resin with greater toughness and flexibility. 

CA11 sale prices are in 1998 dollars and are for non-promoted resins. 

Step 2: Using the information selected in Step 1, determine the cost differentials associated with 

replacing high HAP corrosion resistant resins with low HAP corrosion resistant resins for 

different maximum allowable resin HAP contents and a representative set of chemical 
P.6 

environments at multiple continuous temperature limits. 

Note 1: A chemical environment is defined as a type of chemical with a specific range of 

concentrations. The maximum continuous temperature limit for a specific chemical 

environment is the maximum temperature (based on testing conducted by the resin 

supplier) that a properly constructed plastic composite storage tank or type of process 

equipment can continuously handle (sustain) without experiencing structural failure. 

Example 1: Table CR-2 provides examples of specific chemical environments and 

maximum continuous temperature limits. 

Table CR-2: Examples of Specific Chemical Environments with Maximum Continuous Temperature Limits 

PHEfl-M! 

bDMironmentfc 

ifflrd-ITOITOtaontifhlTOlTO 

Acetic Acid 

Aluminum Sulfate 

Calcium Hypochlorite 

Ethyl Alcohol 

Hydrochloric Acid 

Nickel Chloride 

Potassium 

Dichromate 

Sodium Oxalate 

Tannic Acid 

Zinc Sulfite 

0-25 

0- 100 

0 - 100 

0-1 0 

0- 10 

0 - 100 

0 - 100 

0- 100 

0 - 100 

0-100 

BionlSiliOO] IBionl93:o:0] rA^la-gTS&Ol IEi5nl9M0l lEionPlgQl IBM 

210 

210 

180 

120 

210 

210 

210 

180 

210 

210 

210 

210 

180 

120 

210 

210 

210 

180 

210 

210 

210 

200 

200 

140 

200 

200 

200 

180 

200 

200 

210 

220 

180 

150 

210 

210 

210 

180 

210 

210 

210 

220 

ND 

150 

210 

210 

210 

ND 

210 

210 

210 

220 

210 

150 

210 

220 

220 

200 

220 

220 

210 

210 

200 

140 

210 

210 

210 

200 

210 

210 

200 

200 

NR 

140 

200 

200 

200 

180 

200 

ND 

170 

170 

NR 

ND 

160 

140 

170 

ND 

170 

130 

a

 Examples represents 10 of 608 chemical environments listed in the Reichhold Corrosion Resin Selection and Design Guide. 

ND = There is no data to establish a continuous temperature limit for this resin and chemical environment. 

c

 NR = This resin is not recommended for this chemical environment at any temperature. 

Note 2: The cost differential associated with replacing a high HAP corrosion resistant 

resin with a low HAP corrosion resistant resin is primarily dependent on the chemical 

environment, the continuous operating temperature, and the HAP content of the low HAP 

resin replacement. 

Example 2: Table CR-3 provides actual cost differentials for the first four chemical 

environments listed in Table CR-2 at eight different continuous operating temperatures. 

An examination of the cost differentials in the table indicates the following: 

(1) Different chemical environments may result in dissimilar cost differentials even if 

identical continuous operating temperatures and HAP content limits are present. 

(2) Different continuous operating temperatures may result in dissimilar cost differentials 

even if identical chemical environments and HAP content limits are present. 
P.7 

(3) Different HAP content limits may result in dissimilar cost differentials even if 

identical chemical environments and continuous operating temperatures are present. 
Table CR-3: Examples of Cost Differentials for Different Chemical Environments, Continuous Temperature Limits, and HAP Content Limits

 a,b 

Chemical Environment = Acetic Acid [0 - 25%] 

Pre-MACT Resin Cost & HAP Content 

Cost (S/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least ExjDensive__ 

HAP (% bv Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Actual Cost Differential ($/lb) = Average(Final Cost-Initial Cost) at a Specific Continuous Temperature 

100 F 

0.385 

0.385 

0.315 

0.000 

120 F 

0.385 

0.385 

0.315 

0.000 

140F 

0.385 

0.385 

0.315 

0.000 

160 F 

0.385 

0.385 

0.315 

0.000 

180 F 

0.115 

0.115 

0.045 

0.000 

200 F 

0.115 

0.115 

0.045 

0.000 

220 F 

N/A 

N/A 

N/A 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

Chemical Environment = Aluminum Sulfate [0 -100%] 

Pre-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Actual Cost Differential ($/lb) = Average(Final Cost-Initial Cost) at a Specific Continuous Temperature 

100 F 

0.385 

0.385 

0.315 

0.000 

120 F 

0.385 

0.385 

0.315 

0.000 

140 F 

0.385 

0.385 

0.315 

0.000 

160 F 

0.385 

0.385 

0.315 

0.000 

180 F 

0.115 

0.115 

0.045 

0.000 

200 F 

0.115 

0.115 

0.045 

0.000 

220 F 

0.300 

0.300 

0.300 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

Chemical Environment = Calcium Hypochlorite [0 -100%] 

Pre-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Actual Cost Differential ($/lb) = Average(Final Cost-Initial Cost) at a Specific Continuous Temperature 

100 F 

0.115 

0.115 

0.045 

0.000 

120 F 

0.115 

0.115 

0.045 

0.000 

140 F 

0.115 

0.115 

0.045 

0.000 

160 F 

0.115 

0.115 

0.045 

0.000 

180 F 

0.115 

0.115 

0.045 

0.000 

200 F 

N/A 

N/A 

N/A 

0.000 

220 F 

N/A 

N/A 

N/A 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

Chemical Environment = Ethyl Alcohol [0 -10%] 

Pre-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost & HAP Content 

Cost ($/lb} 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP(%by Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Actual Cost Differential ($/lb) = Average(Final Cost-Initial Cost) at a Specific Continuous Temperature 

100 F 

0.115 

0.115 

0.045 

0.000 

120 F 

0.115 

0.115 

0.045 

0.000 

140 F 

0.440 

0.440 

0.440 

0.000 

160 F 

N/A 

N/A 

N/A 

0.000 

180 F 

N/A 

N/A 

N/A 

0.000 

200 F 

N/A 

N/A 

N/A 

0.000 

220 F 

N/A 

N/A 

N/A 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

1

 The post-MACT resin must be capable of handling the same chemical environment at the same continuous temperature as the pre-MACT resin currently in use while not exceeding a certain HAP 

:ontent. The actual cost differential associated with replacing a specific high HAP corrosion resistant resin is calculated by subtracting the price ofthe high HAP corrosion resistant resin from the 

nice of the least expensive low HAP corrosion resistant resin replacement that meets the criteria discussed in the previous footnote. 

5 
P.9 

Note 3: The low HAP resin replacement must be capable of handling the same chemical 

environment at the same continuous temperature as the High HAP resin currently in use 

while not exceeding a certain level of HAP content. 

Note 4: The actual cost differential associated with replacing a specific high HAP 

corrosion resistant resin is calculated by subtracting the price of the high HAP corrosion 

resistant resin from the price of the least expensive low HAP corrosion resistant resin 

replacement that meets the criteria discussed in Note 3. 

Step 4: Using the information calculated in Step 3, determine the average cost differentials 

associated with replacing high HAP corrosion resistant resins with low HAP corrosion 

resistant resins for each maximum allowable HAP content range and specific continuous 

temperature. The results of this analysis are summarized in Table CR-4. 

Note 1: The average cost differential for a maximum allowable HAP content range and 

specific continuous temperature is the average ofthe individual cost differentials 

determined for each chemical environment at that maximum allowable HAP content 

range and specific continuous temperature. 

Step 5: Select a representative cost differential for replacing a high HAP corrosion resistant resin 

with a low HAP corrosion resistant resin from the cost differentials calculated in Step 4. 

Note 1: The average cost differential selected from Table X is $0,455 per pound. This 

cost differential represents the highest average cost differential for the resin replacement 

options possible at a specific temperature and group of chemical environments. This 

average cost differential was selected because it does not substantially underestimate or 

overestimate the cost associated with replacing a high HAP corrosion resistant resin with 

a low HAP corrosion resistant resin. 

Note 2: The average cost differential was used by the EPA rather than a series of facility 

specific cost differentials. Facility specific cost differentials could not be determined 

because the majority of facilities did not provide the EPA with information on the actual 

corrosion resistant resins used by the facility. 

Step 6: Multiply the price differential selected in Step 5 by the facility's resin usage in the 

applicable open molding and centrifugal casting corrosion resistant process/product 

groupings. 

Note 1: For the corrosion resistant mechanical resin application process/product 

grouping within the open molding subcategory, the price differential selected in Step 5 

was not multiplied by the facility's resin usage if the adoption of non-atomized resin 

application equipment was the only step necessary for the facility to attain compliance. 

Note 2: With the exception stated in Note 1, the cost differential in Step 5 was multiplied 

by all the resin in the applicable process/product groupings rather than a partial amount of 

the resin. The use of averaging between the applicable process/product groupings was 

also not considered in the cost estimate. 
Table CR-4: Corrosion Resistant Resin Properties and Cost Analysis Based on Resins Supplied by Reichhold 

Resin 

Name 

Dion 9100 

Dion 9300 

Atlac 580 

Dion 9480 

Dion 9420 

Dion 6694 

Atlac 382 

Atlac 4010 

Dion 6631 

Resin Type 

Bisphenol - Epoxy - Vinyl Ester 

FR Bisphenol - Epoxy - Vinyl Ester 

Urethane Vinyl Ester 

Novalac Vinyl Ester 

High Cross Link Vinyl Ester 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Bisphenol - A - Fumarate 

Isophthalic 

HDT" 

(DegF) 

220 

230 

244 

260 

320 

270 

270 

205 

225 

(% by Wt) 

43.5 

30.0 

46.0 

39.0 

34.5 

48.0 

50.0 

50.0 

48.0 

Price

 b 

(S/lb) 

1.365 

1.435 

1.465 

2.050 

1.760 

1.460 

1.320 

1.320 

1.050 

All Reichhold Resins with a HAP Content Less Than or Equal To 35% HAP by Weight 

All Reichhold Resins with a HAP Content Less Than or Equal To 40% HAP by Weight 

All Reichhold Resins with a HAP Content Less Than or Equal To 45% HAP by Weight 

All Reichhold Resins Combined Regardless of HAP Content 

Pre-MACT Resin Cost & HAP Content 

Cost ($/lb) 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive: 

HAP (% bv Wt) 

No Limit 

No Limit 

No Limit 

No Limit 

Post-MACT Resin Cost & HAP Content 

Cost ^$/lb} 

Least Expensive 

Least Expensive 

Least Expensive 

Least Expensive 

HAP (% bv Wt) 

< = 35% 

< = 40% 

< = 45% 

No Limit 

Chemical Environments Resin is Capable of Handling at a Specific Continuous Temperaturec 

100F 

404 

404 

444 

421 

286 

454 

478 

436 

188 

417 

454 

454 

508 

80% 

80% 

87% 

83% 

56% 

89% 

94% 

86% 

37% 

82% 

89% 

89% 

100% 

120 F 

362 

362 

386 

366 

264 

404 

406 

369 

171 

378 

402 

402 

444 

82% 

82% 

87% 

82% 

59% 

91% 

91% 

83% 

39% 

85% 

91% 

91% 

100% 

140 F 

323 

323 

360 

329 

249 

374 

377 

341 

151 

340 

359 

359 

406 

80% 

80% 

89% 

81% 

61% 

92% 

93% 

84% 

37% 

84% 

88% 

88% 

100% 

160 F 

275 

275 

294 

273 

218 

314 

313 

278 

100 

292 

301 

301 

337 

82% 

82% 

87% 

81% 

65% 

93% 

93% 

82% 

30% 

87% 

89% 

89% 

100% 

180 F 

260 

260 

270 

258 

214 

290 

292 

248 

0 

279 

286 

286 

316 

82% 

82% 

85% 

82% 

68% 

92% 

92% 

78% 

0% 

81% 

83% 

83% 

100% 

200 F 

182 

182 

195 

183 

168 

237 

213 

180 

0 

205 

210 

210 

254 

72% 

72% 

77% 

72% 

66% 

93% 

84% 

71% 

0% 

81% 

83% 

83% 

100% 

220 F 

1 

1 

0 

28 

9 

110 

4 

0 

0 

10 

31 

31 

113 

1% 

1% 

0% 

25% 

8% 

97% 

4% 

0% 

0% 

9% 

27% 

27% 

100% 

240 F 

0 

0 

0 

0 

0 

6 

1 

0 

0 

0 

0 

0 

6 

0% 

0% 

0% 

0% 

0% 

100% 

17% 

0% 

0% 

0% 

0% 

0% 

100% 

Average Cost Differential ($/lb) = Average(Final Cost-Initial Cost) at a Specific Continuous Temperature

 d 

100 F 

0.240 

0.267 

0.205 

0.000 

120 F 

0.241 

0.262 

0.199 

0.000 

140 F 

0.242 

0.258 

0.195 

0.000 

160 F 

0.219 

0.234 

0.170 

0.000 

180 F 

0.125 

0.139 

0.076 

0.000 

200 F 

0.136 

0.146 

0.085 

0.000 

220 F 

0.275 

0.455 

0.453 

0.000 

240 F 

N/A 

N/A 

N/A 

0.000 

Heat Deflection Temperature (HDT) 

Sale price of resins based on 80 drum shipment size (1998 dollars). 

c

 The number and percentage of chemical environments a resin is capable of handling at a specific continuous temperature. For example, Dion 9300 is capable of handling 404 (approximately 80%) of 

the chemical environments at 100 °Fout of a possible 508 chemical environments that can be handled by all Reichhold resins (listed above) at 100 °F. 

The average cost differential is the average of the individual cost differentials at a specific continuous temperature. For example, the average cost of replacing the least expensive resin (with no HAP 

limit) that is capable of handling a chemical environment at 100 °F with the least expensive resin (maximum HAP = 35%) that is capable of handling a chemical environmental 100 °Fis $0.24/ lb. 
p.ll 

6.2.2 Low HAP Resins for Non-Corrosion Resistant Applications 

Available Cost Information

 NCR"'-NCR

 "2-

NCR

 "3-

NCR" «• NCR "5

-

NCR "6 

The EPA collected cost and/or physical properties infonnation for thermoset resins used 

primarily for non-corrosion resistant applications from the following major resin manufacturers: 

Alpha Owens Corning (AOC), Ashland Chemical Company, Cook Composites & Polymers 

(CCP), Interplastic Corporation, and Reichhold. The information submitted by these 

manufacturers is summarized in Table NCR-1. 

Table NC-1. Non-CBI Cost Information for Non-Corrosion Resistant Resins Provided by Resin Manufacturers 

Resin Manufacturer 

Alpha Owens Corning 

Alpha Owens Corning 

Alpha Owens Corning 

Ashland Chemical 

Ashland Chemical 

Ashland Chemical 

Ashland Chemical 

Ashland Chemical 

Ashland Chemical 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Interplastic Corporation 

Interplastic Corporation 

Interplastic Corporation 

Interplastic Corporation 

Reichhold 

Reichhold 

Reichhold 

Resin Product Number 

80-6100 

80-067 

15-654 

MR 12506 

LB-1127-37 

AROPOL P-9252T 

MR 12909CS 

AME 5000 

AME 4000 

Stypol 40-4862 

Stypol 40-4867 

Stypol 40-4872 

Stypol 40-4877 

Stypol 40-4882 

COR61-AA-189 

VEX200-167 

MVR8031 

CORVE8117 

Polylite 33233 

Polylite 33087 

Hydrex 33250 

Resin Type 

Polyester (DCPD) 

Polyester (DCPD) 

Vinyl Ester (Skin Coat) 

Polyester 

Polyester (DCPD) 

Polyester 

Polyester 

Vinyl Ester 

Vinyl Ester 

Polyester 

Polyester 

Polyester 

Polyester 

Polyester 

Polyester (DCPD) 

Vinyl Ester 

Vinyl Ester 

Vinyl Ester 

Polyester (DCPD-Ortho. Blend) 

Polyester (Orthophthalic) 

Vinyl Ester - DCPD Blend 

HAP 

Content 

(% by wt.) 

35.0 

38.0 

35.0 

42.0 

42.0 

42.0 

44.0 

35.0 

47.0 

39.0 

39.0 

39.0 

39.0 

39.0 

36.5 

34.9 

44.9 

47.5 

38.0 

38.0 

45.0 

Sale" 

Price 

($/lb) 

$0.75 

$0.73 

$1.35 

$0.65 

$0.65 

$0.74 

$0.73 

$1.36 

$1.26 

$0.63 

$0.63 

$0.63 

$0.63 

$0.63 

$0.87 

$1.60 

$1.41 

$1.56 

$0.75 

$0.75 

$1.55 

Sale Price 

Shipment Size 

Basis 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

Tanker Truck 

a

 All sale prices are in 1998 dollars. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP non-corrosion resistant resins with 

low HAP non-corrosion resistant resins. 

Step 1: Assume the average cost differential associated with the replacement of high HAP noncorrosion resistant resins with low HAP non-corrosion resistant resins for the plastic 
P.12 

composites source category is the same as for the boat manufacturing source category. 

Note 1: This assumption was made due to very limited information on the actual resins 

used by facilities in the non-corrosion resistant process/product groupings of the plastic 

composites source category. 

Note 2: The average cost differential for the boat manufacturing source category for noncorrosion resistant resins was $0,055 per pound for facilities that replaced a high HAP 

polyester resin (>35% HAP by wt.) with a low HAP polyester resin (35% HAP by wt.). 

Note 3: The average cost differential for the boat manufacturing source category for noncorrosion resistant resins was $0,077 per pound for facilities that replaced a high HAP 

vinyl ester resin (>35% HAP by wt.) with a low HAP vinyl ester resin (35% HAP by wt.). 

Note 4: The average cost differential selected to represent the replacement of high HAP 

non-corrosion resistant resin with low HAP non-corrosion resistant resin was $0,055 per 

pound. This average cost differential was selected because the majority of facilities using 

non-corrosion resistant resins in the plastic composites source category indicated the use 

of polyester resins rather than vinyl ester resins. 

Step 2: Multiply the cost differential selected in Step 1 by the facility's resin usage in the 

applicable open molding and centrifugal casting non-corrosion resistant process/product 

groupings. 

Note 1: For the non-corrosion resistant (unfilled) mechanical resin application process/ 

product grouping in the open molding subcategory, the cost differential selected in step 1 

was not multiplied by the facility's resin usage if the adoption of non-atomized resin 

application equipment was the only step necessary for the facility to attain compliance. 

Note 2: With the exception stated in Note 1, the cost differential selected in Step 1 was 

multiplied by all the resin in the applicable process/product groupings rather than a partial 

amount of the resin. The use of averaging between the applicable process/product 

groupings was also not considered in the cost estimate. 

Note 3: The cost differentials used in the boat manufacturing source category are based 

on the assumption that resins with 35% HAP by weight are adequate for compliance. The 

reinforced plastics source category has non-corrosion resistant process/product groupings 

that require resins with HAP contents less than 35% by weight for compliance. The cost 

differential selected in Step lwas assumed to still be applicable for these process/product 

groupings. 
P.13 

6.2.3 Low HAP Resins for Mold Manufacturing (Tooling) 

Available Cost Information 

The EPA collected cost and properties infoimation on tooling resins from five (5) major 

resin manufacturers. The cost information submitted by these resin manufacturers is summarized 

in Table TR-1 below. 

Table TR-1. Non-CBI Cost Information for Tooling Resins from Resin Manufacturers 

G&^KfininflNfiii®? 

Alpha-Owens Corning 

Ashland Chemical Company 

Cook Composites & Polymers 

Interplastic Corporation 

Interplastic Corporation 

Reichhold 

Bfe8alsi!^StrDii^ 

80-6100 

AME 5000 

Stypol 040-4232 

MVR8031 

CORVE-Series Vinyl Ester 

Hydrex 33-250 

DCPD-Vinyl Ester 

Vinyl Ester 

Isophthalic 

Vinyl Ester 

Vinyl Ester 

DCPD-Vinyl Ester 

35 

31 

41 

44.9 

47.5 

45 

Ms 

Kites 

mm 

$0.85 

$1.46 

$1.08 

$1.51 

$1.66 

$1.53 

Ms Kites 

SMpBHiB 

§to03asfc 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP tooling resins with low HAP 

tooling resins. 

Step 1: Estimate the amount of tooling resin used by facilities by assuming that 2 lbs of tooling 

resin must be used for every 100 lbs of production resin. 

Note: This assumption is necessary because a number of facilities did not indicate 

tooling resin or gel coat use in responding to the 1993 Information Collection Request 

(ICR) due to the typically small amounts of these materials that facility's use (relative to 

production materials). 

Step 2: Assume facilities will comply by using a low HAP tooling resin with a HAP content of 

40.0% by weight. 

Note: This assumption is necessary because facilities may also comply by using manual 

or non-atomized mechanical resin application and a HAP content of 50.0%. It is unlikely 

facilities will adopt the use non-atomized resin application solely to apply tooling resin 

given the small quantities of tooling resin typically used (relative to production resin). 

Further, the type of non-atomized mechanical resin technology most likely to be adopted 

by facilities (i.e. flow-coaters) is often incompatible with the high level of filler present in 

many tooling resins. 

Step 3: From the available cost information in Table TR-1, select the cost associated with the 

tooling resin most likely to represent the High HAP tooling resins currently in use. 

10 
P.14 

Note: The tooling resin selected for this step is the Reichhold Hydrex 33-250 (45% HAP, 

$1.53). This resin was selected because the HAP content of the resin is near the average 

HAP content of the tooling resin process/product grouping (46.4% by weight). 

Step 4: From the available cost information in Table X, select the cost associated with the 

tooling resin most likely to represent the low HAP tooling resin facilities will use to 

comply with the standard. 

Note: The tooling resin selected for this step is the Ashland AME 5000 (31% HAP, 

$1.46). This resin was selected because it is the most expensive resin in Table X with a 

low enough HAP content sufficient for compliance. 

Step 5: Calculate the cost differential between the selected high HAP and low HAP tooling 

resins. 

Note 1: The cost differential between the tooling resins selected in steps 3 and 4 is 

$0.07/lb ($1.53 - $1.46). This cost differential represents a cost savings of $0.07/lb. 

Note 2: A cost savings is also obtained ifthe Interplastic CoReyzn MVR 8031 (44.9% 

HAP, $1.51) or the Interplastic CORVE-series vinyl ester (47.5% HAP, $1.66) are 

chosen as the high HAP tooling resin in step 3. 

Note 3: Selection ofthe Cook Composites Stypol 040-4232 (41% HAP, $1.08) as the 

high HAP tooling resin would not result in a cost savings. However, the HAP content of 

this resin is not close to the average HAP content of the tooling resin process/product 

grouping. 

Step 6: Assign zero cost to the use of low HAP tooling resins rather than a cost savings. 

Note 1: The assignment of zero cost to the use of low HAP tooling resins rather than a 

cost savings has the effect of making the cost estimate more conservative. This 

assumption is necessary given the limited amount of actual data on tooling resin usage 

currently available to the EPA. 

11 
P.15 

6.2.4 Low HAP Pigmented Production Gel Coats 

Available Cost Infonnation 

The EPA collected cost and properties information on pigmented production gel coats 

from two major gel coat manufacturers. The cost information submitted by these gel coat 

manufacturers is summarized in Table PGC-1 below. 

Table PGC-1. Non-CBI Cost Information for Pigmented Production Gel Coats from Gel Coat 

Manufacturers 

Gel Coat Manufacturer 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polvester 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polvmers 

Gel Coat 

Product Number 

YG-371201 

WG-312792 

AG-01091 

AG-3808 

RG-29-0309 

GG-29-1700 

LG-29-7189 

TG-29297 

WG-2X000 

WG-LSS-0000 

AG-00618 

AG-LSG-0613 

WG-3000 

BG-3550 

WG-XL-0000 

WG-29-0000 

WG-MP-0000 

944-P0LYC0R 

951-ARMORCOTE 

953-BUFFBACK 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

963-Marine LOW VOC 

944-POLYCOR 

951 -ARMORCOTE 

953-BUFFBACK 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

963-Marine LOW VOC 

944-POLYCOR 

951-ARMORCOTE 

953-BUFFBACK 

961-LOW VOC ARMORCOTE 

962-Sanitary LOW VOC 

963-Marine LOW VOC 

Gel Coat 

Base 

Color 

White 

White 

Gray 

Gray 

Red 

Green 

Blue 

Brown 

White 

White 

Gray 

Gray 

White 

Black 

White 

White 

White 

White 

White 

White 

White 

White 

White 

Black 

Black 

Black 

Black 

Black 

Black 

Red 

Red 

Red 

Red 

Red 

Red 

Styrene*1 

Content 

(% bv wt.1 

27.19 

27.71 

32.29 

36.72 

24.36 

17.39 

20.75 

21.86 

37 

28 

33 

25 

35.7 

37.4 

23.3 

13.2 

27.9 

MMA' 

Content 

<% bv wt.1 

4.00 

4.00 

0.00 

0.00 

17.50 

25.00 

25.00 

25.00 

0 

0 

0 

0 

0.0 

0.0 

13.6 

20.4 

9.1 

HAP1 

Content 

<% bv wt.1 

31.19 

31.71 

32.29 

36.72 

41.86 

42.39 

45.75 

46.86 

37 

28 

33 

25 

35.7 

37.4 

36.9 

33.6 

37.0 

36 

40 

35 

29 

25 

25 

40 

44 

39 

31 

30 

30 

38 

40 

35 

30 

30 

30 

Sale" 

Price 

«/B>1 

$3.39 

$1.80 

$1.70 

$1.70 

$3.29 

$2.97 

$2.97 

$2.88 

$1.89 

$1.99 

$1.39 

$1.52 

$1.53 

$1.54 

$2.05 

$2.99 

$2.43 

$1.68 

$3.01 

$2.18 

$1.99 

$1.99 

$1.99 

$1.70 

$3.01 

$2.18 

$1.99 

$1.99 

$1.99 

$2.71 

$4.81 

$4.09 

$3.51 

$3.51 

$3.51 

Sale Price 

Shipment 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

Drum 

"Styrene, methyl methacrylate, and total HAP contents are shown to the number of decimal places reported by the gel coat manufacturer. 

All sales prices are in 1998 dollars. Blank spaces in the table indicate information was not provided by the manufacturer. 

12 
P.16 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP pigmented production gel coats 

with low HAP pigmented production gel coats. 

Step 1: Assume that the color distribution of pigmented production gel coats currently used by 

facilities in the open molding subcategory is 80% by volume white gel coat and 20% by 

volume red gel coat. 

Note 1: This assumption is necessary because the information available to the EPA on 

the color distribution of gel coats used by individual facilities within the open molding 

subcategory is extremely limited. The color distribution is important because different 

color pigmented production gel coats have different prices and physical properties. 

Step 2: From the available cost information in Table PGC-1, select the cost associated with the 

pigmented production gel coats most likely to represent the High HAP pigmented 

production gel coats currently in use. 

Note 1: The white gel coat selected for this step is the Cook Composites & Polymers 

944-POLYCOR (36.0% HAP, $1.68/lb). This gel coat was selected because it can be 

matched with a low HAP white pigmented production gel coat produced by the same 

manufacturer and costs more than the low HAP white pigmented production gel coats. 

The other high HAP white gel coats produced by Cook Composites are more expensive 

than the low HAP white pigmented production gel coats. 

Note 2: The red gel coat selected for this step is the Cook Composites & Polymers 944-

POLYCOR (38.0% HAP, $2.71/lb). This gel coat was selected because it can be 

matched with a low HAP red pigmented production gel coat produced by the same 

manufacturer and costs more than the low HAP red pigmented production gel coats. The 

other high HAP red gel coats produced by Cook Composites are more expensive than the 

low HAP red pigmented production gel coats. 

Step 3: From the available cost information in Table PGC-1, select the cost associated with the 

pigmented production gel coats most likely to represent the low HAP pigmented 

production gel coats facilities will select to comply with the MACT standard. 

Note 1: The white gel coat selected for this step is the Cook Composites & Polymers 962 

- Sanitary LOW VOC (25.0% HAP, $1.99/lb). This gel coat was selected because it can 

be matched with a high HAP white pigmented production gel coat produced by the same 

manufacturer and has a low enough HAP content for compliance with the MACT 

standard. 

Note 2: The red gel coat selected for this step is the Cook Composites & Polymers 962 -

Sanitary LOW VOC (30.0% HAP, $3.51/lb). This gel coat was selected because it can be 

matched with a high HAP red pigmented production gel coat produced by the same 

manufacturer and has a low enough HAP content for compliance with the MACT 

13 
P.17 

standard. 

Step 4: Determine the amount of low HAP white and red pigmented production gel coat a facility 

will need to use to comply with the existing source point value limit and obtain the same 

surface area coverage for each color of gel coat used (i.e. white and red). 

Note 1: Due to differences in density and the amount of styrene emitted during 

application and curing, the amount of surface area that can be covered by equal amounts 

of low HAP and high HAP gel coats is different. Low HAP gel coats generally have a 

higher density than high HAP gel coats. This higher density equates to a lower volume of 

gel coat per lb of gel coat purchase. This lower volume can result in less total gel coat 

coverage per lb of gel coat purchased. Conversely, low HAP gel coats emit less styrene 

and methyl methacrylate with the result that less of the applied gel coat material 

evaporates into the atmosphere. This fact that less material evaporates can result in more 

total coverage per lb of gel coat purchased. 

Note 2: These two factors are simultaneously present in different degrees and the 

combined effect of both factors will determine if the facility must increase or decrease the 

amount of gel coat purchased in order to obtain the same amount of surface area 

coverage. 

Note 3: Due to the cost of the selected low HAP pigmented production gel coats being 

greater than the cost of the selected high HAP pigmented production gel coats, it was 

assumed that facilities would only use the amount of low HAP pigmented production gel 

coat necessary to comply. 

Note 4: Due to the substantially cost differential between the low HAP white and low 

HAP red pigmented production gel coats, it was assumed that facilities would replace all 

of the high HAP white pigmented production gel coat prior to replacing any of the high 

HAP red pigmented production gel coat. 

Step 5: Calculate the annual total cost incurred by the facility prior to the implementation of the 

MACT standard by multiplying the amount of pigmented production gel coat used by the 

facility annually (using the color distribution assumed in step 1) by the cost of the high 

HAP pigmented production gel coats selected in step 3. 

Step 6: Calculate the annual total cost incurred by the facility due to the purchase of high HAP 

pigmented production gel coats after the implementation of the MACT standard by 

multiplying the amount of high HAP pigmented production gel coats that will still be 

used after implementation of the MACT standard by the price of the pigmented 

production gel coats selected in step 3. 

Step 7: Calculate the annual total cost incurred by the facility due to the purchase of low HAP 

pigmented production gel coat after the implementation of the MACT standard by 

multiplying the amount of low HAP pigmented production gel coats that will be used by 

the price of the pigmented production gel coats selected in step 2. 

Step 8: Calculate the annual total cost incurred by the facility after the implementation of the 

14 
P.18 

6.2.5 

MACT standard by summing the products calculated in steps 6 and 7. 

Low HAP Clear Production Gel Coats 

Available Cost Information 

The EPA collected cost and properties information on clear production gel coats from 

two major gel coat manufacturers. The cost information submitted by these gel coat 

manufacturers is summarized in Table CGC-1 below. 

Table CGC-1. Non-CBI Cost Information for Clear Production Gel Coats from Gel Coat Manufacturers 

<M Ossfi Sr&ijEifesaDaF 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Cook Composites & Polymers 

@s0 ©SSC KSSJIBIC Ktanifeaf 

CG-LE-570 

CG-07009 

CG-21009 

942-XA-220 

(M©m 

Hfess 

©ste? 

Clear 

Clear 

Clear 

Clear 

BStvren'eiB 

34 

47.2 

43.7 

l 

0.0 

6.1 

35 

47.2 

49.8 

45.0 

Kites 

$2.10c 

$1.53 

$1.68 

$1.92 

M s Kites 

SMpBSBG 

Drum 

Drum 

Drum 

Drum 

Styrene, methyl methacrylate, and total HAP contents are shown to the number of decimal places reported by the gel coat manufacturer. 

All sales prices are in 1998 dollars. Blank spaces in the table indicate information was not provided by the manufacturer. 

CA price range of $ 1.95 - $2.25 was reported for this gel coat. The price value shown is the midpoint of this range. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP clear production gel coats with 

low HAP clear production gel coats. 

Step 1: Assume that facilities will use only the amount of low HAP clear production gel coat 

necessary to comply with the MACT standard. 

Note: The MACT floor point value for the gel coat application/clear production gel coats 

corresponds to a HAP content of 44.0% by weight. The available low HAP clear 

production gel coat has a substantially lower HAP content of 35.0% by weight. It is 

assumed that this large differential in the HAP content (and the higher price of the low 

HAP clear production gel coat) will result in facilities using only the amount of low HAP 

clear production gel coat necessary to comply. 

Step 2: Determine the amount of low HAP clear production gel coat a facility will need to use to 

comply with the existing source point value limit and obtain the same surface area 

coverage. 

Notei: Due to differences in density and the amount of styrene emitted during 

application and curing, the amount of surface area that can be covered by equal amounts 

of low HAP and high HAP gel coats is different. Low HAP gel coats generally have a 

higher density than high HAP gel coats. This higher density equates to a lower volume of 

gel coat per lb of gel coat purchase. This lower volume can result in less total gel coat 

coverage per lb of gel coat purchased. Conversely, low HAP gel coats emit less styrene 

15 
P.19 

and methyl methacrylate with the result that less of the applied gel coat material 

evaporates into the atmosphere. This fact that less material evaporates can result in more 

total coverage per lb of gel coat purchased. 

Note 2: These two factors are simultaneously present in different degrees and the 

combined effect of both factors will determine if the facility must increase or decrease the 

amount of gel coat purchased in order to obtain the same amount of surface area 

coverage. 

Step 3: From the available cost information in Table CGC-1, select the cost associated with the 

clear production gel coat most likely to represent the High HAP clear production gel coats 

currently in use. 

Note: The gel coat selected for this step is the Neste Polyester CG-07009. This gel coat 

was selected because the HAP content is representative of the HAP content used by the 

majority of facilities currently using clear production gel coats. 

Step 4: From the available cost information in Table CGC-1, select the cost associated with the 

clear production gel coat(s) most likely to represent the low HAP clear production gel 

coats selected by facilities to comply. 

Note: The gel coat selected for this step is the Neste Polyester CG-LE-570. This gel coat 

was selected because it is the only low HAP clear gel coat for which the EPA had cost 

information. 

Step 5: Calculate the annual total cost incurred by the facility prior to the implementation of the 

MACT standard by multiplying the amount of clear production gel coat used by the 

facility annually by the cost ofthe high HAP clear production gel coat selected in step 3. 

Step 6: Calculate the annual total cost incurred by the facility due to the purchase of high HAP 

production gel coat after the implementation of the MACT standard by multiplying the 

amount of high HAP clear production gel coat that will still be used after implementation 

of the MACT standard by the price of the clear production gel coat selected in step 3. 

Step 7: Calculate the annual total cost incurred by the facility due to the purchase of low HAP 

production gel coat after the implementation of the MACT standard by multiplying the 

amount of low HAP clear production gel coat that will be used after implementation of 

the MACT standard by the price of the clear production gel coat selected in step 4. 

Step 8: Calculate the annual total cost incurred by the facility after the implementation of the 

MACT standard by summing the products calculated in steps 6 and 7. 

16 
P.20 

6.2.6 Low HAP Tooling Gel Coats 

Available Cost Infoimation 

The EPA collected cost and properties information on clear production gel coats from 

two major gel coat manufacturers. The cost information submitted by these gel coat 

manufacturers is summarized in Table TGC-1 below. 

Table TGC-1. Non-CBI Cost Information for Tooling Gel Coats from Gel Coat Manufacturers 

Gel Coat Manufacturer 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Neste Polyester 

Cook Composites & Polymers 

Cook Composites & Polymers 

Cook Composites & Polymers 

Ferro Corporation 

Ferro Corporation 

Ferro Corporation 

Gel Coat Product Number 

BG-55000 

RG-55005 

YG-55000 

YG-57000 

YG-5776V (Vinyl Ester) 

CG-5116V (Vinyl Ester) 

945-B-201 

945-GA-104 

945-YA-058 

GV 03894 

58-601230** 

GV 01767 

Gel Coat 

Base 

Color 

Black 

Red 

Orange 

Orange 

Orange 

Clear 

Black 

Green 

Orange 

Red 

Tangerine 

Black 

Styrene" 

Content 

(% by wt.) 

40.8 

45.7 

41.3 

41.7 

53.2 

54.0 

36.94 

29.23 

36.97 

MMA" 

Content 

(% by wt.) 

5.0 

0.0 

0.0 

5.0 

0.0 

0.0 

3.00 

3.00 

3.00 

HAP" 

Content 

(% by wt.) 

45.8 

45.7 

41.3 

46.7 

53.2 

54.0 

48 

48 

48 

39.64 

32.23 

39.97 

Sale" 

Price 

($ / lb) 

$2.72 

$2.72 

$3.36 

$3.36 

$4.11 

$3.47 

$3.06 

$3.77 

$3.77 

$3.48 

$4.99 

$2.93 

Sale Price 

Shipment 

Size Basis 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

5 Gal. Pail 

50 lbs 

50 lbs 

50 lbs 

"Styrene, methyl methacrylate, and total HAP contents are shown to the number of decimal places reported by the gel coat manufacturer. 

All sales prices are in 1998 dollars. Blank spaces in the table indicate information was not provided by the manufacturer. 

c

 According to the manufacturer (Ferro Corporation), this gel coat is a heavy metal free pigmented system with a very high heat distortion 

temperature. The manufacturer also indicated that the gel coat does not have many customers at this time resulting in the unusually high cost. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to the replacement of high HAP tooling gel coats with low HAP 

tooling gel coats. 

Step 1: Assume all facilities known or assumed to use tooling resin use tooling gel coat. 

Note 1: This assumption is necessary because a number of facilities did not indicate 

tooling resin or gel coat use in responding to the 1993 Infoimation Collection Request 

(ICR) due to the typically small amounts of these materials that facility's use (relative to 

production materials). 

Step 2: Estimate the amount of tooling gel coat used by facilities by assuming that 15 lbs of 

tooling gel coat must be applied for every 100 lbs of tooling resin. This assumption may 

be expressed as a tooling gel coat to tooling resin ratio of 0.15. 

Note 1: This assumption is necessary because a number of facilities did not indicate 

tooling resin or tooling gel coat use in responding to the 1993 Information Collection 

17 
P.21 

Request (ICR) due to the typically small amounts of these materials that facility's use 

(relative to production materials). 

Note 2: The ratio of 0.15 is an average based on two applied gel coat to applied resin 

ratios calculated using actual data. The first ratio is the amount of pigmented production 

gel coat applied per production resin applied using manual and/or mechanical resin 

application (0.215). The second ratio is the amount of clear production gel coat applied 

per production resin applied during the polymer casting process (0.085). Since facilities 

that manufacture products using open molding processes and/or polymer casting also 

manufacture molds, the average of these ratios was used to obtain the 0.15 ratio. 

Step 3: Estimate the average HAP content of the tooling gel coats used by facilities by using the 

average HAP content of the gel coat application/tooling gel coat process/product 

grouping (with the exception of facilities where the HAP content of the tooling gel coat is 

known). 

Note 1: This assumption was necessary because the EPA does not have HAP content 

information for the majority of facilities believed to use tooling gel coat. 

Step 4: From the available cost information in Table TGC-1, select the tooling gel coat(s) most 

likely to represent the High HAP tooling gel coats currently in use. 

Note 1: The gel coat selected for this step is Neste Polyester BG-55000. This gel coat 

was selected since the gel coat color (black) is a typical tooling gel coat color and the 

HAP content of the tooling gel coat (45.8% by wt.) is close to the average HAP content 

of the gel coat application/tooling gel coat process/product grouping. 

Note 2: This gel coat was selected rather than any of the orange/tangerine tooling gel 

coats, due to the lack of a standard (non-specialty) low HAP orange/tangerine tooling gel 

coat. The Ferro Corporation tangerine gel coat shown in table X is not a standard 

orange/tangerine tooling gel coat. 

Step 5: From the available cost information in Table TGC-1, select the tooling gel coat(s) most 

likely to represent the low HAP tooling gel coats selected by facilities to comply. 

Note 1: The gel coat selected for this step is Ferro Corporation GV 01767. This gel coat 

was selected because it is a logical match for the high HAP Neste Polyester BG-55000 

due to the identical color and presence of methyl methacrylate. 

Note 2: The existing source MACT floor is set by a gel coat (Polydyne 151 Orange) with 

a HAP content of 38.0% by weight. No cost infoimation is available for this gel coat. 

The HAP content of the gel coat selected in step 5 is 39.97%. 

Step 6: Calculate the cost differential between the selected high HAP and low HAP tooling gel 

coats. 

18 
P.22 

Note 1: The cost differentia] between the gel coats selected in steps 3 and 4 is $0.21/lb 

($2.72 - $2.93). This cost differential was used to calculate the direct annual cost 

incurred by facilities in replacing high HAP tooling gel coats with low HAP tooling gel 

coats. 

Step 7: Calculate the annual cost incurred by the facility by multiplying the cost differential in 

step 6 ($0.21/lb) by the total amount of tooling gel coat used by the facility. 

6.2.7 Testing of New Low HAP Resins and Gel Coats 

Available Cost Infoimation 

The EPA collected information on testing costs that facilities incurred to verify that the new 

low HAP resins exhibit acceptable physical properties. Testing cost data to switch from high to 

low HAP gel coats were not available. The cost infoimation discussed here only pertains to 

testing conducted by the facility. Testing conducted for facilities by independent testing firms is 

discussed in Section 6.2.8 (Recertification of Products). 

Testing cost data to switch from high to low HAP resins were collected from nine facilities. 

Three of the nine facilities that provided testing cost data submitted their data as CBI.REF1,2,3 

Table TS-1 below shows the non-CBI testing cost data provided to the EPA: 

Table TS-1. Testing of New Low HAP Resins 

IS-isfflto 

Bowie Manufacturing, Inc.

 REF4,S 

Dixie-Pacific Manufacturing Company, Inc.REF6 

Fiber Pro, Inc.REF7 

LASCO Bathware (Yelm)

 REF8 

LaValley Construction Company

 REF9 

Shenandoah Fiberglass Products Company

 REF1° 

Kssns? ©sto GIMP 

©mmm 

Greater than 35.0 

39.8 

40.0 

46.0 

43.0 

45.0 to 50.0 

wmM iRHinll'MSlj^^B 

sntgntlS^^^ I 

31.0 and 32.7 

35.0 

35.3 

37.0 and 30.0 

34.0 

35.0 

^^^^^^^BFp^i^^nwnsni^^JMni^ro^^^^^^^ll 

^^^^HM0§ ! aaSStefeite 1 

"Minimal" 

"A few hundred dollars" 

None 

$5,000 per Trial 

No cost tothe facility 

(all testing was done by the supplier) 

$ 3,000 per Trial 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual cost 

incurred by facilities due to the testing of new low HAP resins and gel coats. 

Step 1: Based on the data shown in Table TS-1, assume that the average testing cost for resins 

is $3,000 per trial. A trial is considered to be a series of tests to determine the 

suitability of a particular resin. Thus, if a facility tests three different resins, a total of 

three trials is assumed to be conducted. 

Note 1: As seen in Table TS-1 and some of the CBI cost data, testing costs may vary 

from zero cost to costs larger than $3,000 per trial. While both ends of this range may 

be encountered by facilities, neither is considered to be typical and so neither the 

highest nor the lowest reported costs were used in determining the $3,000 estimate. 

19 
P.23 

Step 2: Assume that the testing costs for switching from high to low HAP gel coats are the 

same as for switching from high to low HAP resins. Thus, a testing cost of $3,000 

per trial is assumed for switching to lower HAP gel coats. 

Step 3: Assume that for estimating the total "testing" costs for a facility, a total of three trials 

would be performed for each ofthe following groupings: corrosion resistant resins, 

non-corrosion resistant resins, tooling resins, pigmented gel coats, clear gel coats, and 

tooling gel coats. Thus, a total "testing" cost of $9,000 for each of these groupings 

has been assumed. 

Note 1: The amount of testing that a facility does is highly variable and depends on 

the product being manufactured and the extent of the testing done by the resin or gel 

coat supplier. 

Step 4: For facilities that use the resins or gel coats in the groupings discussed in Step 3 for 

several different process/product groupings, the testing costs are divided among those 

process/product groupings. Table TS-2 below show how testing costs were divided 

among process/product groupings: 

Table TS-2. Division of Testing Costs Among Process/Product Groupings 

Raw Materia] Grouping 

Corrosion Resistant Resins 

Non-Corrosion Resistant Resins 

Tooling Resins 

Pigmented Gel Coats 

Clear Gel Coats 

Tooling Gel Coats 

Cost per Trial 

($) 

3,000 

3,000 

3,000 

3,000 

3,000 

3,000 

Estimated 

Number of Trials 

3 

3 

3 

3 

3 

3 

Total Testing Cost 

($) 

9,000 

9,000 

9,000 

9,000 

9,000 

9,000 

Process/Product Grouping Over which Testing Costs are 

Divided (if Conducted at the Facility) 

Manual Corrosion Resistant 

Mechanical Corrosion Resistant 

Filament Winding Corrosion Resistant 

Centrifugal Casting Corrosion Resistant 

Manual Non-Corrosion Resistant 

Mechanical Non-Corrosion Resistant 

Filament Winding Non-Corrosion Resistant 

Centrifugal Casting Non-Corrosion Resistant 

Manual Tooling 

Mechanical Tooling 

Pigmented Production Gel Coats 

Clear Production Gel Coats 

Tooling Production Gel Coats 

6.2.8 Training to Use New Low HAP Resins and Gel Coats 

Available Cost Infoimation 

The EPA collected infoimation on training costs that facilities incurred associated with 

switching to lower HAP resins. Training cost data to switch from high to low HAP resins were 

collected from five facilities. Training cost data to switch from high to low HAP gel coats were 

not available. Table TN-1 below shows the training cost data provided to the EPA: 

20 
P.24 

Table TN-1. Training Costs to Use New Low HAP Resins 

Facility 

Dixie-Pacific Manufacturing Company, Inc.REF6 

Fiber Pro, Inc.REF7 

LASCO Bathware (Yelm)

 REF8 

La Valley Construction Company

 REF9 

Shenandoah Fiberglass Products Company

 REF1° 

Former Resin HAP 

Conicnt (%) 

39.8 

40.0 

46.0 

43.0 

45.0 to 50.0 

New Resin HAP 

Content (%) 

35.0 

35.3 

37.0 and 30.0 

34.0 

35.0 

Training Cost for Switching 

to Lower HAP Resin ($) 

None 

None 

None 

Minimal 

None 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual cost 

incurred by facilities due to training for switching to new low HAP resins and gel coats. 

Step 1: Based on the data shown in Table TN-1, assume that there are no training cost 

incurred due switching to lower HAP resins. 

Step 2: Assume that the training cost for switching from high to low HAP gel coats are the 

same as for switching from high to low HAP resins. Thus, no training costs are 

assumed for switching to lower HAP gel coats. 

6.2.9 Recertification of Products 

Available Cost Infoimation 

The EPA collected information on product recertification costs for independent testing that 

facilities incurred due to switching to low HAP resins or gel coats. Recertification cost data were 

collected from two facilities both of which considered their data to be confidential.REF1,3 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual cost 

incurred by facilities due to product recertification. 

Step 1: Assume that only underground gasoline storage tanks incur product recertification 

costs, since these appear to be the only mass produced stock products requiring 

independent certification. 

Note 1: Custom made tanks or other specialty products are assumed to need 

individual product ceitification regardless of the type and HAP content of the resin. 

Thus, switching to a lower HAP resin is not assumed to affect product certification 

costs for custom products. 

Step 2: A typical product recertification cost of $ 50,000 was assumed for each underground 

gasoline storage tank product line where the resin is changed. 

21 
P.25 

Step 3: For facilities that use different process/product groupings to produce underground 

gasoline storage tanks, the recertification costs are divided among those 

process/product groupings. 

6.2.10 Production Problem Costs Due to Switching to New Low HAP Resins and Gel Coats 

Available Cost Information 

The EPA collected information on production problem costs that facilities incurred due to 

switching to lower HAP resins. Production problem cost data to switch from high to low HAP 

resins were collected from nine facilities. Two of the nine facilities that provided these cost data 

submitted their data as CBI.REF2 Table PP-1 below shows the non CBI production problem cost 

data provided to the EPA: 

Table PP-1. Production Problem Costs Due to Use New Low HAP Resins 

Facility 

Bowie Manufacturing, Inc.

 REF4*5 

Dixie-Pacific Manufacturing Company, Inc.REF6 

Fiber Pro, Inc.REF7 

LASCO Bathware (Yelm)

 REF8 

LaValley Construction Company

 REF9 

Shakespeare Electronics & Fiberglass Division

 REF" 

Shenandoah Fiberglass Products Company

 REFI° 

Former Resin HAP 

Content (%) 

Greater than 35.0 

39.8 

40.0 

46.0 

43.0 

42.0 

45.0 to 50.0 

New Resin HAP 

Content (%) 

31.0 and 32.7 

35.0 

35.3 

37.0 and 30.0 

34.0 

33.0 

35.0 

Production. Problem Cost for Switching 

to Lower HAP Resin ($) 

None 

None 

None 

"Significant" 

"Minimal" 

None 

None 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual cost 

incurred by facilities due to production problems associated with switching to new low HAP 

resins and gel coats. 

Step 1: Based on the data shown in Table PP-1, assume that generally there are no production 

problem costs incurred due switching to lower HAP resins and gel coats. 

6.2.11 Long-Term Increase in Labor Cost 

Available Cost Information 

The EPA collected information on long-term increased labor costs associated with switching 

to lower HAP resins. Changes in long-term labor costs associated with switching to low HAP 

resins were collected from two facilities. Table LC-1 below shows changes in the long-term 

labor costs provided to the EPA: 

22 
P.26 

Table LC-1. Long-Term Increase in Labor Cost 

mm® <smm«m> ®» 

Bowie Manufacturing, Inc.

 REF4*5 

La Valley Construction Company

 REF9 

Greater than 35.0 

43.0 

31.0 and 32.7 

34.0 

ELsaj^TftetajuD OrssaB* tai Ikftaar (Jt o ctos 

None 

None 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual increase 

in long-term labor costs incurred by facilities associated with switching to new low HAP resins 

and gel coats. 

Step 1: Based on the data shown in Table LC-1, assume that facilities generally do not incur 

an increase in long-term labor costs due switching to lower HAP resins/gel coats. 

6.2.12 Equipment Change Costs 

Available Cost Information 

The EPA collected information on equipment change costs associated with switching to 

lower HAP resins. Equipment change costs associated with switching to low HAP resins were 

collected from five facilities. Three of the five facilities that provided these cost data submitted 

their data as CBI.REF1*

2

*

3

 Table EC-1 below shows the non-CBI equipment change cost data 

provided to the EPA: 

Table EC-1. Equipment Change Costs 

Bittner Industries, Inc.REF12 

Bowie Manufacturing, Inc.

 REF4*5 

Greater than 35.0 

Greater than 35.0 

32.5 

31.0 and 32.7 

None 

None 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the annual 

equipment change costs incurred by facilities associated with switching to new low HAP resins 

and gel coats. 

Step 1: Based on the data shown in Table EC-1, assume that facilities generally do not incur 

any equipment change costs due switching to lower HAP resins/gel coats. 

Note 1: Some of the CBI cost data discusses significant anticipated equipment 

changes. However, since these costs are only anticipated and no actual costs were 

reported by facilities that have made resin/gel coat changes, no costs were assumed 

for equipment changes. 

6.2.13 Adoption of Non-Atomized Resin Application Equipment 

See ERG Memo 

23 
P.27 

6.2.14 Uncovering only one Charge per Compression/Injection Molding Machine 

Available Cost Information 

Cost data on uncovering only one charge as opposed to several charges per 

compression/injection molding machine for each mold cycle were not available. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the direct annual 

cost incurred by facilities due to uncovering only one charge as opposed to several charges per 

compression/injection molding machine for each mold cycle. 

Step 1: Assume that uncovering more than one charge at a time per molding cycle has a 

negative impact on the quality of the SMC or BMC charge. This is presumed to be 

true because the uncovered charges loose monomer more quickly than covered 

charges, which is needed for a proper polymerization reaction.

 REF13 

Step 2: Assume that for the production of the same amount of total product, it does not take 

the operator of the compression/injection molding machine any longer to only 

uncover one charge per mold cycle than to uncover several charges per mold cycle at 

once. 

Step 3: Given the assumptions in Steps 1 and 2 above, uncovering only one charge as 

opposed to several charges per compression/injection molding machine for each mold 

cycle is not expected to generate any costs. 

Step 4: The direct annual cost incurred by facilities due to uncovering only one charge as 

opposed to several charges per compression/injection molding machine for each mold 

cycle was assumed to be zero. 

24 
P.28 

6.2.15 Wet Area Enclosures with Resin Drip Collection System 

Available Cost InformationPLC1 

The EPA collected cost information on the design, installation, and operation of wet area 

enclosures and resin drip collection systems installed on pultrusion lines. This information is 

summarized in Table PL-1. 

Table PL-1. Available Cost Information for Wet Area Enclosures and Resin Drip Collection Systems " 

^^^^^B^^^^^^^KomRn3n(^Konamon^^^^H^^^^^^^B 

Design, Installation, and Operation of Wet Area Enclosure 

Design, Installation, and Operation of Resin Drip Collection System 

Design, Installation, and Operation of Wet Area Enclosure 

Design, Installation, and Operation of Resin Drip Collection System 

Steams 

Large 

Large 

Small 

Small 

^•Iiotai^iiwaiMost^H 

$765.15 per year 

No Information 

$396.52 per year 

No Information 

/Swmrwfl (S^rstrfftom until 

IMMifiaiEnsgCcfefi 

$754.81 per year 

No Information 

$436.55 per year 

No Information 

"Cost figures are for large and small wet area enclosures installed on pultrusion lines at the Glasforms, Inc. facility in Birmingham, Alabama. 

Cost Methodology & Assumptions"^2 

The following steps (and associated assumptions) were used to calculate the annual 

capital and operating & maintenance costs incurred by facilities. 

Step 1: Assume all facilities not currently in compliance will install one wet area enclosure and 

one resin drip collection system per pultrusion line present at the facility. 

Note 1: This assumption is necessary because there is insufficient infoimation describing 

the type of pultrusion lines present at the facilities. The majority of the facilities did not 

indicate the type of pultrusion line present at the facility. Some facilities indicated more 

than one type of line but did not provide specific numbers (e.g., some facilities indicated 

the use of direct die injection but did not indicate the number of machines utilizing this 

technology). 

Note 2: This assumption will probably make the cost estimate more conservative since 

facilities that utilize direct die injection without resin pre-wet will not have to install wet 

area enclosures and hence will incur less cost than estimated. 

Step 2: For facilities that did not provide specific information on the number of pultrusion lines 

present at their facility, assume that the number of lines present at these facilities may be 

estimated using the reported resin usage for the pultrusion operations at the facility and 

the pultrusion line to pultruded resin ratio calculated from facilities for which data are 

available. 

Note 1: This assumption is necessary because 7 out of 31 facilities did not provide the 

number of pultrusion lines present at their facility. 

Step 3: Assume the cost information available related to the installation of "large" (as opposed 

to "small") WAEs should be used to make the cost estimate more conservative. The 

25 
P.29 

exact dimensions of the "large" and "small" WAEs used at Glasforms are CBI. 

However, some indication of the relative size of the WAEs may be inferred from the 

section 114 screening survey submitted by Glasforms for their San Jose, CA facility . 

The survey response indicated that the largest resin bath present at the facility was 8' long 

by 3' wide and the smallest resin bath was 3' 5" long by 1' 7" wide. 

Note 1: This assumption is necessary because there is insufficient infoimation available 

on the size ofthe pultrusion lines present at facilities that conduct pultrusion operations. 

As a result of this lack of information, it is impossible to judge whether the pultrusion 

line at the facilities will require "small" or "large" wet area enclosures. 

Step 4: Assume that the cost overestimation that occurs due to the conservative assumptions in 

Step 1 (i.e. that all pultrusion lines will require a wet area enclosure) and Step 3 (i.e. 

using the greater cost associated with "large" wet area enclosures) are sufficient to 

compensate for assigning zero cost for the design, installation, and operation of a resin 

drip collection system. 

Note 1: This assumption is necessary because there is insufficient information available 

to cost the resin drip collection system. The resin drip collection system present at 

Glasforms consists of a plastic pipe (modified with a cut-out), a funnel, and a container 

(shaped like a bleach jug) for collecting resin. Due to the relatively simple materials and 

design of this resin drip collection system, the cost associated with implementing the 

resin drip collection system should be minimal compared to the design, installation, 

and operation of the wet area enclosure. Finally, resin collected in the drip collection 

system may be recycled by the facility, thereby reducing the facility's raw material costs. 

Step 5:Use the same capital cost annualization period for wet area enclosures as indicated by the 

OAQPS cost manual for permanent total enclosures (i.e. 30 years). 

Note 1: This assumption is necessary because the OAQPS cost manual does not specify 

a capital cost annualization period for wet area enclosures installed on pultrusion lines. 

The annualization period for permanent total enclosures was assumed to be appropriate 

due to the similarity in construction materials. 

Step 6: Multiply the capital cost per line ($765) by the number of pultrusion lines present 

at the facility to obtain the facility-specific total capital cost to be annualized. Annualize 

the total capital cost using a 30 year annualization period to obtain the annual capital cost. 

Step 7: Multiply the annual operating & maintenance cost per line ($755) by the number of 

pultrusion lines present at the facility to obtain the facility-specific annual operation & 

maintenance cost. 

Step 8: Sum the annual capital cost and annual operating & maintenance cost to estimate the total 

cost that will be incurred by the facility in complying with the existing source MACT 

standard for pultrusion operations. 

26 
P.30 

6.2.16 Closed or Covered Doctor Boxes, Folded Edges, and Low Styrene Permeable Film 

Available Cost Infoimation 

Cost data on closing or covering doctor boxes, folding edges, and using low styrene 

permeable film (e.g., Nylon) for SMC production were not available. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the direct annual 

cost incurred by facilities due to closing or covering doctor boxes, folding edges, and using low 

styrene permeable film (e.g., Nylon) for SMC production. 

Step 1: Assume that not closing or covering doctor boxes, not folding edges, and not using 

low styrene permeable film has a negative impact on the quality of the SMC. This is 

presumed to be true because more monomer is lost if the above mentioned actions are 

not taken, which is needed for a proper polymerization reaction. 

Step 2: Assume that the benefits for closing or covering doctor boxes, folding edges, and 

using low styrene permeable film outweigh the costs of taking the above mentioned 

actions. 

Step 3: Given the assumptions in Steps 1 and 2 above, closing or covering doctor boxes, 

folding edges, and using low styrene permeable film is not expected to generate any 

net costs. 

Step 4: The direct annual cost incurred by facilities due to closing or covering doctor boxes, 

folding edges, and using low styrene permeable film was assumed to be zero. 

6.2.17 Non-HAP Cleaning Materials 

Available Cost Infoimation 

Based on 1993 industry screening surveys, the most prevalent HAP-containing cleaner used 

in this industry is methylene chloride and a commonly used non HAP-containing cleaner is 

acetone. Some facilities also use methyl ethyl ketone, which is a HAP-containing cleaner. The 

EPA collected cost data on the most commonly used HAP- and non HAP-containing cleaning 

solvents. The cost data for acetone, methylene chloride, and methyl ethyl ketone are shown in 

Table CM-1 below. 

Table CM-1. Cost Information for HAP- and non HAP- Containing Cleaning Solvents 

iSSKcrrtlSTippiiei-^^^^^^^^^B 

Worth Chemical Corporation

 REFM 

Worth Chemical Corporation

 REF14 

Fiberglass Coatings Inc.REF15 

(gfesaa? 

Acetone 

Methylene Chloride 

Methyl Ethyl Ketone 

0 

100 

100 

$2.73 

$7.29 

$5.00 

55 Gallon Drum 

55 Gallon Drum 

55 Gallon Drum 

27 
P.31 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the direct annual 

cost incurred by facilities due to switching from HAP- to non HAP-containing cleaners. 

Step 1: Assume that facilities will comply by switching from using methylene chloride or 

methyl ethyl ketone to acetone. This is presumed to be true because the 1993 industry 

screening surveys indicated that the most prevalent HAP-containing cleaner used in 

this industry is methylene chloride and a commonly used non HAP-containing cleaner 

is acetone. 

Step 2: Calculate the cost differential between methylene chloride or methyl ethyl ketone and 

acetone based on the infoimation provided in Table CM-1. 

Note 1: The cost differential between methylene chloride and acetone is $4.56/gallon 

($7.29/gallon-$2.73/gallon). This cost differential represents a cost savings of $4.56 

per gallon of cleaner. 

Note 2: The cost differential between methyl ethyl ketone and acetone is $2.27/gallon 

($5.00/gallon-$2.73/gallon). This cost differential represents a cost savings of $2.27 

per gallon of cleaner. 

Step 3: Assume the HAP-containing cleaners can be more effective than non HAP-containing 

cleaners particularly for cured or partially cured resins. In this case, the use of a non 

HAP-containing cleaner may require more time and/or physical effort than the use of 

a HAP-containing cleaner to remove the resin. 

Step 4: Assume that for the same cleaning task no more acetone is used than methylene 

chloride or methyl ethyl ketone. 

Step 5: Assume that the cost savings in Steps 2, outweigh the cost of additional time and 

labor described in Step 3. 

Step 6: The direct annual cost incurred by facilities due to switching from HAP- to non HAPcontaining cleaners was assumed to be zero. 

28 
P.32 

6.2.18 Closed/Covered Mixing with No Visible Gaps in Mixer Cover 

Available Cost Infoimation

 M1*M2 

The EPA collected cost infoimation associated with the adoption of closed/covered mixing 

practices where there are no visible gaps in the mixer cover and no active ventilation of the 

mixer. This information is summarized in Table M-l. 

Table M-l. Summary of Available Information for Closed/Covered Mixing with No Visible Gaps 

Components of 

Mixer Cover Cost 

Materials to Construct Mixer Cover 

Labor to Construct Mixer Cover 

Total Mixer Cover Cost 

Component Cost 

(1998$) 

$50 

$45 

$95 

Frequency of 

Replacement 

Semiannual 

Semiannual 

Semiannual 

Annual Cost 

(1998 $/yr) 

$100 

$90 

$190 

The infoimation is based on mixing operations conducted at the Glasforms, Inc. facility 

located in Birmingham, Alabama. At the Glasforms facility, mixing is conducted in 55 gallon 

drums. The 55 gallon drum is covered by a plywood disk large enough to cover the entire drum 

top. The front third of the cover is hinged to allow for the addition of various materials during or 

prior to the mixing process. The mixer cover has a bristle-covered opening that allows the cover 

to be placed around the mixer shaft. The bristle-covered opening allows for easy replacement 

and removal of the mixer cover during mixing operations while leaving no visible gap between 

the mixing shaft and the mixer cover. 

The mixer covers are manufactured "in-house" by Glasforms. The labor costs and the 

raw material costs are approximately $45 per mixer cover and $50 per mixer cover, respectively. 

During the mixing operation, the mixer cover comes in contact with the promoted resin resulting 

in the gradual buildup of an uneven, cured resin layer on the inside of the cover. After 

approximately six months this layer increases in size to the point where the mixer cover must be 

replaced in order for proper mixing to occur. Based on the combined labor and material cost of 

$95 per mixer cover and the semi-annual frequency of replacement, the annual cost per mixer is 

estimated to be $190 for a 55 gallon mixing vessel. 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to calculate the direct annual 

cost incurred by facilities due to installation of mixer covers with no visible gaps and no active 

ventilation of the mixer. 

Step 1: Determine the number of mixers present at the facility. 

Note 1: The annual cost per facility is partially dependant on the number of mixers 

present at the facility. The number of mixers present at a facility is dependent on the 

size of the mixing vessels used, the type of materials to be mixed, the length of time 

required to completely mix the materials used by the facility, and the capability of the 

facility to use mixed materials due to production capacity and product demand. 

29 
P.33 

Note 2: The infoimation available to estimate the number of mixers at each facility is 

extremely limited. Therefore, the number of mixers present at each facility was estimated 

based on the annual usage of materials that are likely to require mixing or agitation (i.e. 

resins, fillers, and gel coats). 

Note 3: Using the ratio of mixers to the approximate usage of these materials at 

Glasforms' Birmingham facility, one mixer was assumed for every 400 tons of material 

per year. Facilities using less than 400 tons per year of materials were assumed to have 

only one mixer and the number of mixers per facility was rounded to the nearest whole 

number. It was also assumed that all mixing at the facility occurs in a 55 gallon or larger 

mixing vessel. 

Example 1: An examination of a facility's annual material usage indicates 500 tons of 

resin, 500 tons of filler, and 200 tons of gel coat. This represents 1200 tons per year of 

material potentially requiring mixing or agitation. Assuming one mixer for every 400 

tons of material potentially requiring mixing or agitation, this facility would require three 

mixers. 

Step 2: On a per mixer basis, determine the facility's cost of complying with the requirement for 

closed/covered mixing vessels with no visible gaps in the mixer cover and no active 

ventilation. 

Note 1: The annual cost per facility is partially dependent on the existing degree of 

compliance with the standard. Table M-2 summarizes the cost assigned per 

mixer based on a facility's existing level of compliance. 

Table M-2. Per Mixer Compliance Cost Assigned to a Facility Based on Existing Level of Compliance 

©HBSffi 

Open 

Open 

Open 

Closed 

Closed 

Closed 

Closed 

Closed 

Closed 

Setoff ©SH®? 

mm 

No 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

ffusaffito 

N/A 

N/A 

N/A 

Yes 

Yes 

Yes 

No 

No 

No 

KKsts-ps* 

SMf!**-?^ 

N/A 

N/A 

N/A 

No 

No 

No 

No 

No 

Yes 

IWixer/A"etJKel\B 

WstmospilieTeM 

No 

Yes 

No 

No 

Yes 

No 

No 

Yes 

No 

B^i'XeniiSgTiSJSim 

KflmrSI^icel 

No 

No 

Yes 

No 

No 

Yes 

No 

No 

Yes 

£mw_]©m 

®mMM_B 

100% 

100% 

0% 

50% 

50% 

0% 

0% 

0% 

0% 

^nnrrfi*flca»sG 

$190 

$190 

$0 

$95 

$95 

$0 

$0 

$0 

$0 

Step 3: Estimate the total annual cost of complying with the requirement for closed/covered 

mixing vessels with no visible gaps in the mixer cover and no active ventilation by 

multiplying the per mixer compliance cost by the estimated or actual number of mixers 

present at the facility. 

30 
P.34 

6.2.19 Add-on Control Devices (Thermal Oxidizers) 

To be added at a later date. 

6.2.20 Monitoring, Recordkeeping, and Reporting 

Available Cost Infoimation 

At this time no specific facility cost data are available to determine the monitoring, 

recordkeeping and reporting (MRR) requirements for the Reinforced Plastic Composites MACT 

standard, since no facility has conducted these activities yet. However, the EPA has data on the 

estimated hours and costs for MRR tasks of other standards that they developed. Hour estimates 

for some common MRR tasks were available from the Emission Standards Division (ESD) 

Procedures Manual.REF16 For those MRR tasks for which no hour estimates were available, 

assumptions were made to estimate the MRR hours. For the cost estimation of the MRR hours, 

wage rates that were used for the Architectural Coatings Infoimation Collection Request (ICR) 

were available. Table MRR-1 below shows the wage rates used for the Architectural Coatings 

ICR: 

Table MRR-1. Wage Rates for Architectural Coatings ICR REF17 

GfcSB MSss GJsfis fens EteusiB 

•jffikfea?S*iaaa®p[L^) iMipiMB^Ii/wffiiig 

Clerical 

Technical 

Management 

11.95 

18.86 

28.54 

1.41 

1.43 

1.40 

1.67 

1.67 

1.67 

28.14 

45.04 

66.73 

Cost Methodology & Assumptions 

The following steps (and associated assumptions) were used to determine the MRR hours and 

direct annual cost incurred by facilities due to MRR requirements. 

Step 1: Assume that MRR requirements may occur in any of the following six categories: (1) 

reading rule, (2) performance tests and other requirements for facilities complying by 

using an add-on control device, (3) employee training, (4) subpart A notifications, (5) 

percent HAP monomer records for open molding and centrifugal casting operations 

and records for other pollution prevention techniques used in open molding, and (6) 

developing a record system. 

Step 2: Identify all activities that fall within the six categories described in Step 1. 

Step 3: Compile the following infoimation for each expected activity identified in Step 2: (1) 

Applicability (e.g., existing facilities, new facilities, facilities with control devices, 

etc.), (2) first year hours, (3) annual hours, and (4) assumptions. 

Note 1: Table MRR-2 lists the information that was compiled for each activity by 

31 

_J 
P.35 

MRR category described in Step 1: 

Step 4: Determine the total first year MRR hours and the total annual MRR hours on a facility 

basis (based on applicability) for all activities listed in Step 2. 

Step 5: Determine the first year MRR hours and the annual MRR hours on a subcategory 

basis (based on applicability) for all activities listed in Step 2. 

Step 6: Assume that all of the MRR work is performed by managerial staff with one hour of 

clerical support for every eight hours of managerial work. For example, if 280 hours 

are estimated for a given activity, 280 hours are assumed to be spent as managerial 

hours and 35 hours (280/8 = 35) are assumed to be spent as clerical hours. 

Note 1: Assuming that all work is performed by management probably over-estimates 

the cost impact of the rule's MRR requirements for some facilities. 

Step 7: For each subcategory, determine the first year MRR costs by multiplying the first year 

management and clerical hours by the associated labor rate for that category, $66.73 

and $ 28.14 per hour, respectively. 

Step 8: For each subcategory, determine the annual MRR costs by multiplying the annual 

management and clerical hours by the associated labor rate for that category, $66.73 

and $ 28.14 per hour, respectively. 

Step 9: Annualize the first year MRR costs over a ten year period for each subcategory using 

a seven percent interest rate. 

Step 10: Add the annualized first year MRR costs and annual MRR costs for each subcategory 

to obtain the total annual costs. 

Step 11: For subcategories with process/product groupings, divide the total annual subcategory 

cost for a facility evenly among the process/product groupings (conducted at the 

facility) for each particular subcategory. 

32 
Table MRR-2. MRR Information by Activity 

MRR Category 

Read rule 

Performance tests and 

other requirements for 

facilities with add-on 

controls 

Employee training 

Table MRR-2. M 

Activity 

Read promulgated rule and 

Subpart A, General Provisions 

Initial performance test -

Control device efficiency 

Initial performance test -

Capture efficiency 

Notification of initial 

performance test 

Report of initial performance 

test 

Development of operation and 

maintenance plan 

Development of startup, 

shutdown, and malfunction 

(SSM) plan 

Records and reports of SSM 

and corrective measures taken 

Development of operator 

training course 

Time to train personnel 

Records of operators 

completing operator training 

course 

RR Information by Activity 

Applicability 

All existing and new facilities 

Facilities complying by using 

control devices that have not 

done testing 

Facilities complying by using 

control devices that have not 

done testing 

Facilities complying by using 

control devices 

Facilities complying by using 

control devices 

Facilities complying by using 

control devices 

Facilities complying by using 

control devices 

Facilities complying by using 

control devices 

Facilities with work practice 

requirements 

All facilities 

All facilities 

First Year Hours 

8 Hours per facility plus 1 

additional hour per subcategory 

280 Hours per facility

 REF'4 

40 Hours per facility 

2 Hours per facility 

Included in performance test 

hours 

40 Hours per facility 

20 Hours per facility 

2 Hours per facility 

8 Hours for work practices and 

24 hours for spray training 

Small Facilities: 

2 Hours for Work practices and 4 

for spray training 

Medium Facilities: 

4 Hours for Work practices and 8 

for spray training 

Large Facilities: 

8 Hours for Work practices and 

16 for spray training 

2 Hours per facility 

33 

Annual Hours 

1 Hour per facility 

None 

None 

None 

None 

None 

None 

2 Hours per facility 

None 

None 

2 Hours 

Assumptions 

Reading rule and Subpart A will be necessary 

for compliance 

Facilities that already conducted destruction 

efficiency testing according to EPA 

requirements do not have to retest 

Facilities that already conducted capture 

efficiency testing according to EPA 

requirements do not have to retest 

Does not apply to facilities that already 

demonstrated destruction and capture 

efficiency 

Does not apply to facilities that already 

demonstrated destruction and capture 

efficiency 

None 

None 

SSM report hours are covered under reports 

of accedences and periods of noncompliance 

Training hours are incremental hours between 

current level training and MACT level 

training 

Training new employees based on 

requirements in the standard does not take 

more time than training new employees 

without MACT standard in place 

Small <. 100 Employees 

Medium > 100 <. 250 Employees 

Large > 250 Employees 

None 

' -
MRR Categorv 

Subpart A 

notifications 

Percent HAP 

monomer and 

pollution prevention 

records 

Develop record 

system 

Activity 

Notification of construction and 

reconstruction 

Notification of anticipated 

startup 

Notification of actual startup 

Notification of compliance 

status 

Semiannual report -

Compliance certification 

Semiannual report -

Periods of noncompliance and 

methods used to attain 

compliance 

Records of HAP percent and 

weighted average HAP 

concentration calculations and 

records of other pollution 

prevention techniques 

Develop record system 

Applicability 

New facilities 

New facilities 

New facilities 

All facilities 

All facilities 

All facilities with periods of 

noncompliance 

Open Molding and Centrifugal 

Casting facilities 

All facilities 

First Year Hours 

2 Hours per facility

 REF14 

2 Hours per facility

 REF14 

2 Hours per facility

 REFI4 

4 Hours per facility

 REFI4 

8 Hours per facility

 REF'4 

16 Hours per facility

 REFI4 

12 Hours per facility 

Work practices: 1 Hour 

HAP content and other pollution 

prevention measures: 5 Hours 

Control devices: 2 Hours 

Annual Hours 

None 

None 

None 

None 

16 Hours per 

facility 

(8 hours X 2)REFI4 

32 Hours per 

facility 

(16 hours X2)REF"* 

12 Hours per 

facility 

None 

Assumptions 

No reconstruction will occur at existing 

facilities 

No reconstruction will occur at existing 

facilities 

No reconstruction will occur at existing 

facilities 

None 

Only one semiannual report is submitted in 

the first year plus the Notification of 

compliance status 

20 Percent of facilities will have some 

periods of noncompliance and 80 percent will 

not have any periods of noncompliance 

None 

None 

34 
Table 1. Existing Source MACT Floors For Open Molding and Centrifugal Casting 

Source 

Open Molding 

Centrifugal Casting 

Process/Product Groupings 

Corrosion Resistant (CR) Mechanical Resin 

Application 

Non CR Mechanical Resin ApplicationUnfilled 

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 

Non CR Filament Winding 

Tooling Gel Coating 

Pigmented Gel Coating 

Clear Production Gel Coating 

NonCR 

CR 

Existing Sources 

MACT Floor 

190 

104 

144 

97 

256 

124 

76 

163 

178 

394 

265 

504 

396 

536 

Required HAP 

Contenta 

48.3 and 100% 

FC 

37.1 and 100% 

FC 

33.9 

36 

43 

40 

32.3 

42 

45 

38 

30 

44 

35.5 

48 

Facility which sets floor

 b 

An Cor Industrial Plastics Inc. (42 and 

50% FC) 

Custom Fiberglass Molding, Inc. 

Hydro Systems, Inc. (42.6 and CF) 

Norton Performance Plastics(47 and 

VB) 

Prestigious Accessories Inc. 

Hartzell Fan, Inc. 

CDR Systems Corp (35 and VB) 

Industrial Fiberglass Specialties, Inc. 

Water Heater Innovations, Inc.. 

Marble Creations 

TJ. S. Fiberglass Products Inc. 

Laminated Products Inc 

Henderson., Black & Green Inc. 

Average of Raven and Fibercast 

a

 Represents the HAP content required to meet the point value. Where FC is shown it is assumed 100 flow coaters are also used. 

b

 Where the facility representing the floor meets the point value using a resin/gel coat with a different HAP content than is shown in the previous column, the 

resin HAP content and other controls used at the facility are shown in parenthesis. FC = Flow Coater, VB = Vacuum Bagging, CF = Carbon Filters 

14