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OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

10)IV-E-10 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:26 AM Sheet 10 of 130 
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MEMORANDUM 

TO: Keith Barnett 

U.S. EPA/ESD/OCG 

FROM: Susan Cassidy 

Pacific Environmental Services, Inc. (PES) 

DATE: May 29, 2002, revised January 3, 2003. 

EPA AIR Dona" 

SUBJECT: Minutes of May 23rd Meeting Between EPA and the Composite Fabricators 

Association and Industry Representatives 

LOCATION: U.S. EPA, Research Triangle Park, NC 9:00 am - 3:00 pm 

ATTENDEES: 

U. S. Environmental Protection Agency (EPA) 

Keith Barnett U.S.EPA 

EPA Contractors 

Susan Cassidy PES, Inc. 

Composites Fabricators Association (CFA) 

John Schweitzer CFA 

Bob Lacovara CFA 

Chuck Elkins CE&A (consultant to CFA) 

Composites Manufacturers 

Dianne Coon 

Bruce Crowell 

Ashland 

Reichold 

(919)541-5605 

(919) 941-0333 

(734) 622-0162 

(215)513-7546 

(202)686-3518 

Fred Dierks 

John Barker 

Craig Peterson 

Perry Bennett 

Monty Felix 

Lowell Miles 

Mark Aker 

Resin Manufacturers 

Aqua Glass 

Strongwell 

Xerxes Corporation 

MFG 

Alaglass 

Miles Fiberglass (composites 

Aker Plastics 

(731)632-2554 

(540)645-8129 

(952) 887-1807 

(731)632-2554 

(803)874-2731 

(503) 775-7755 

(219) 936-3838 

(614) 790-3998 

(919) 990-7740 
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Meeting Minutes 

May 23, 2002 

Page 2 

PURPOSE: 

The purpose ofthe meeting was for EPA to brief CFA and industry representatives on 

planned changes to the proposed rule and to discuss the impacts ofthe updated cost analysis. 

EPA distributed an agenda and handouts addressing the final MACT floors for existing sources, 

the cost analysis, other planned changes to the proposed rule, and outstanding issues. A handout 

with the summary ofthe regulatory option cost effectiveness was also distributed. These items 

are included as attachment 1. A second objective was to obtain additional information from CFA 

and industry representatives on some ofthe issues raised during public comment on the proposed 

rule, and to allow the CFA to comment on the changes to the proposed rule. 

Mr. Schweitzer stated that CFA and industry's objective for the meeting is to discuss the 

issues they feel are important and identify options that can be explored where EPA does not 

foresee changes as an option. For example, can EPA talk to OCG about other pursuing other 

options despite the implications ofthe available floor data?. The EPA agreed to include this in the 

day's discussion. A summary of CFA's outstanding issues is included as attachment 2. 

DISCUSSION: 

Proposed Changes 

The meeting attendees briefly discussed the "Information on Draft Final Floors, Costs, and 

Planned Rule Changes" handout. The EPA indicated that the changes in the MACT floors are 

driven by new facility data obtained in recent months. 

The floor for mechanical filled resin application is now 38.4% HAP with non-atomization 

(as compared to 42.8% HAP with non-atomization at proposal). Although that floor has changed 

several times during the reanalysis, EPA does not foresee any additional changes. The corrosion 

resistant floor is now 46.2 % HAP with non-atomized application (compared to 48.3% at 

proposal) and the tooling gel coat floor is now 40% HAP, which is the same as the tooling gel 

coat floor in the Boat Manufacturing MACT. 

The EPA indicated that they had expected to see more public comments on the data used 

to set the floor numbers because they had heard a lot of discussion about errors in the database. 

However, EPA received very few comments and found most people were not helpful with efforts 

to followup, but EPA did make an effort to clarify questionable data. 

Industry expressed some concern about the floor for corrosion-resistant filament winding. 

The provision that allows use ofthe same resin might work, but they not know if they can meet 
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Meeting Minutes 

May 23, 2002 

Page 3 

the new floor. Averaging is essential for compliance. In a previous meeting, an industry 

representative was suggesting 45% HAP was adequate for corrosion-resistant applications, but 

they needed to revisit the numbers because compliance was tight using averaging to achieve the 

proposed floor. 

The EPA responded that they ranked the available information and set the floor according 

to the statutory requirements. There is not really any flexibility to change the floor. Industry then 

commented that the provision allowing a facility to use the same resin in all process groups should 

be sufficient to overcome what industry sees as a low floor for corrosion-resistant filament 

winding. 

The EPA explained that they have very limited data on tooling gel coats because use of 

tooling gel coats was not reported by many companies, Due to the lack of data, EPA looked at 

the data for tooling gel coats in the Boat Manufacturing NESHAP. The new floor of 40% HAP is 

the same as the Boat MACT. However, industry representatives stated that the boat 

manufacturers are having trouble meeting 40% HAP for tooling gel coats. 

Industry questioned the discrepancy in the revised floors for manual and mechanical 

corrosion-resistant process groups when most people use the same resin for both of these process 

groups. The EPA responded that the issue is covered by the provision in the rule that allows a 

facility to use the same resin for all process groups. In some process groups, the floor may be 

driven by a few facilities with low-HAP resins. The EPA looked at combining the corrosionresistant process groups and found that would have resulted in a tighter floor for everyone. 

Industry asked about flexibility for customer requests to use specific resins, such as for 

manufacturing water treatment products. The EPA responded that they are going to consider if 

there is a way to provide flexibility for customer contract requirements. However, they noted that 

it will be important to avoid setting up a loophole where everyone could get their customers to 

issue contract requirements for high-HAP resins. 

The EPA noted that the 60% HAP limit for fire retardant/class 1 smoke & fire resins has 

not changed, but EPA will change the definition for this process/product grouping based on 

industry comments to make it more accurate. 

The EPA stated that due to the results ofthe updated cost analysis, the above-the-floor 

option for add-on controls has been dropped for all process groups except centrifugal casting and 

continuous lamination/casting. In those process groups, the split threshold for small business 

facilities has been dropped and the above-the-floor option will apply to all facilities with emissions 

of 100 tons per year (tpy) or more of HAP. There are no existing small business facilities in these 

process groups in the 100 to 250 tpy range, so there is no impact from dropping the split 

threshold. 
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Meeting Minutes 

May 23, 2002 

Page 4 

CFA's Issues 

Prior to the meeting, the CFA prepared a list of issues that they wanted to address. Mr. 

Barnett added his own comments to the list and included the list in the handout package at the 

meeting. Group discussion focused on certain issues in the list, as discussed below. Refer to 

attachment 2 for more information on these issues. 

Capture and Control for New Sources (II-2) 

Industry question: Why does EPA not see the requirement for 95% capture and control for new 

sources being removed. 

EPA Response: The best controlled sources in the industry are controlled at 95% overall HAP 

emissions reduction. For new sources, MACT should be equivalent to the "best controlled similar 

source" and that is defined as the best control of HAP. Therefore, issues related to other 

emissions, such as combustion emissions, are not the focus ofthe MACT determination. The 100 

tpy cutoff in the proposed rule was based on American Standard, which has HAP emissions prior 

to add-on controls of approximately 100 tpy. Below 100 tpy, the requirements for new sources 

are the same as those for existing sources. The EPA's position at proposal was best control was 

existing facilities that achieved or were permitted at 95% capture and control, and that position 

has not changed. The EPA also believes that facilities emitting less than 100 tpy typically operate 

only one shift. This could likely degrade add-on control performance due to frequent start-ups 

and shut-downs. At proposal, there were no facilities emitting less than 100 tpy that had actually 

demonstrated 95% control, but 95% capture and control is demonstrated for larger facilities. 

Industry Comment: One industry representative noted that American Standard never actually 

passed source tests, has never actually achieved 95% control, and may never achieve that, so that 

facility should not be used as the basis for the rulemaking. 

EPA Response: The proposed requirement is based on the facility's permit. The facility agreed 

that the requirement is "achievable" when they accepted the permit condition. The facility says 

that they can achieve 95% and the fact that they haven't achieved it yet is not a compelling 

argument that they cannot meet it. In addition, other facilities identified by EPA have 

demonstrated 95% capture and control. American Standard is the basis for the 100 tpy cutoff but 

it is not the only facility forming the basis for the add-on control requirement. 

Additional Industry Comments: They noted that their issue is the 100 tpy threshold. They believe 

there will be a lot of new sources in the 100 to 250 tpy range that will make very large products. 

It would not be economical to build these facilities if a thermal oxidizer is required. They stated 

that facilities manufacturing large products such as bridge beams, panels, underground storage 

tanks, barge covers, etc. cannot capture emissions and achieve 95% control. They do not foresee 
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Meeting Minutes 

May 23, 2002 

Page 5 

a problem for facilities above 250 tpy because those facilities would most likely be producing 

smaller products using conveyorized applications that are better suited to thermal oxidation. 

EPA Response: There is a custom molding facility under 100 tpy, and it is achieving 95% capture 

and control, and a pultrusion facility making custom parts that indicated they had been doing 

capture and control for 10 years. The EPA used American Standard as the basis for the 100 tpy 

threshold because it seemed to be the best cut-off point. The EPA cannot see any valid rationale 

not to use American Standard as the basis for the threshold cut-off because the facility has 

indicated that they will fix their problems and will meet the permit condition of 95% capture and 

control. Without using American Standard, the threshold would probably have to be something 

even lower. 

Industry Comment: Two industry representatives asked how A.R.E. met the requirement that the 

new source floor be based on a "similar source". 

EPA Response: A.R.E.'s capture system consists ofa large permanent total enclosure (PTE) 

with tunnels to move product in and out. The dimensions are in the trip report and almost 

anything could be built inside that PTE, although air flow might be an issue. The EPA 

acknowledged that large parts might require a building within a building which may be more 

difficult then enclosing a line producing small parts. 

Additional industry comments: They stated that it is "infeasible," not just more difficult. A.R.E. 

has small products that can be moved through tunnels that can be treated as natural draft 

openings. If a facility makes large parts such as barge covers, pools, etc., the facility would need 

huge doors to move products in and out. The enclosure would no longer qualify as a PTE when 

doors of that size are opened and this would limit production to one item at a time, which would 

not be economical. When CFA looked at different P2 options, they carved up the industry and 

also looked at different types of operations to see where add-on control might work, such as 

bathware, but they would never have put large parts into a group where add-on is said to be 

feasible. The examples used as justification, such as shipbuilding, work because they are only 

doing one at time. Those products are so large that only one can be built. Another industry 

representative whose company makes barge covers stated that PTEs would be a serious problem 

for his barge cover operations. 

An industry representative noted that he visited a Boeing facility and saw that a large 

plane such as a 747 can be painted in a PTE, but only one can be produced at a time. He asked 

EPA to consider the implications if Boeing were trying to achieve the same volume that auto 

manufactures meet. Or even trying to produce 5 large planes per week. He believes it would be 

impossible. He also stated although the opportunity exists for highly specialized products with 

limited production to use capture and control, it is not economical for a majority ofthe 

manufacturers in the industry to do so. Sources such as pool manufactures are really not similar 
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Meeting Minutes 

May 23, 2002 

Page 6 

to operations at A.R.E., American Standard, and Lasco. 

EPA response: They understand CFA's concerns, but they have seen PTEs used with large 

product operations. Manufacturers have come up with solutions, so CFA's argument is less 

compelling. The EPA also noted possible difficulties with a size cutoff- how would "big" 

products be defined and what happens to facilities that change products, and how would facilities 

producing both large and small products be handled? 

Industry comment: If a facility increases production so emissions increase from 50 tons to 150 

tons, would that facility become a new source subject to add-on control?. 

EPA Response: It would not, an existing source remains an existing source based on the 

definitions and applicability included in the rule. 

Industry Comments: They stated that the proposed rule will probably result in companies building 

several smaller facilities capped at 100 tpy to avoid capture and control because there is no 

incentive to purchase an oxidizer when smaller facilities do not have to. They believe those 

facilities that have installed capture and control have special circumstances that are better suited 

to capture and control, such as truck caps produced in designer colors and paint operations. 

Another industry representative noted that in markets where price and quality are really important, 

companies will not want to build several smaller facilities instead ofa single large one. He used 

the example of bridge supports - these products have a high liability and quality is harder to 

ensure if production is split among several locations. 

An industry representative indicated that economics are just as important for new facilities. 

If a business is growing but cannot afford to construct a new facility because ofthe capture and 

control requirement, they are forced to lose business to companies already operating in those 

locations. 

Industry then asked if EPA would have more flexibility if convinced that the technology 

for capture and control isn't really there, for example, for small operations with 1 production shift 

or large part manufacturers. 

EPA response: We requested that he send that information. The EPA is not opposed to letting 

facilities out ofthe 95% control requirement if there is a basis to do so, but they cannot commit to 

that now. 

Industry Comment: Could EPA change the new source threshold for capture and control from 

100 tpy to 250 tpy? 

EPA Response: They cannot do that because EPA is bound by the "best ofthe best" requirement 
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Meeting Minutes 

May 23, 2002 

Page 7 

for new source MACT and another facility less than 250 tpy has achieved 95% capture and 

control. 

Industry Comment: What constitutes a new source, including moving the location ofa facility but 

keeping the same process or doubling the production capacity at an existing facility? Industry 

representatives noted that recent changes to the general provisions indicate that moving a source 

to a new location is not automatically a new source and it is an issue that would have to be 

negotiated with the state. 

EPA Response: Under this rule, a facility cannot become new by reconstructing. A new source is 

a greenfield site with no reinforced plastic composites operations prior to construction. Moving 

existing operations to a new location would be considered a new source, but expanding 

production at an existing facility would not. The EPA representatives were not familiar with the 

revision to the general provisions. 

Nylon Containing Film (IV-B-2) 

Industry Comment: Nylon-containing film used for sheet molding compound sheet molding 

compound (SMC) can very from 25% to 100% nylon. Industry studies show that 25% nylon film 

is just as good as 100% nylon film for containing emissions. Industry representatives added that 

there is a quality issue with sheet molding compound (SMC) and manufacturers will want to 

retain styrene in the sheet molding compound (SMC) until it is used, so no one will want to use a 

film that allows the styrene to evaporate. 

EPA Response: We are not tied to setting a particular limit because the floor facility does not 

indicate the nylon content of their film. We will probably leave the wording as "nylon containing 

film" in the rule. 

Pultrusion (III-E) 

Industry Comment: The floor setting source for pultrusion (Tecton) lends itself to control, but the 

available technologies do not work for large parts. This is not just a new source issue. Averaging 

can work for large facilities with multiple products, but not for smaller facilities. The phase 1 

pultrusion studies show that air flow and temperature are the only factors that really affect 

emissions. 

EPA Response: We can look at other options and will consider the wording proposed by 

Strongwell that identifies parts with greater than 1000 reinforcements as "large". We suggest that 

Strongwell check back in two or three weeks to discuss the issue. We do not see that as a big 

issue and acknowledge that some large parts would be difficult to fully enclose with wet area 

enclosures during production. 
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Meeting Minutes 

May 23, 2002 

Page 8 

Mixing (V-A) 

Industry Comments: If a facility can demonstrate "closed" mixing, does that still require capture 

and control? Industry noted that some facilities are looking at vacuum mixing because they need 

to prevent air entrainment during mixing, and that others are using nitrogen blanketing and would 

not want to pull nitrogen into the mixer. Another industry representative asked if vacuum assisted 

is considered active venting, and a third industry representative noted that vacuums only result in 

a very slight increase in evaporation. MFG uses a closed system to add filler with a computer 

controlled conveyor. A switch automatically opens the cover to the dust collector vent and turns 

it off when the conveyor stops. Mixing starts up after the dust collector vent is closed. They also 

sweeps the head space just before opening the mixture. 

EPA Response: The rule requires 95% reduction and does not specify routing emissions to a 

control device. An uncovered mixer would be the "uncontrolled" emission level to use as the 

baseline for measuring 95% reduction. The EPA indicated that they will look at their notes and 

does not foresee this as a problem. We will look into changing the rule language to clarify that 

covers are required only during mixing and will look into changing or deleting the wording related 

to no active venting. 

In Mold Coating and Liquid Composite Molding (V-F) 

Industry Comment: There is a process called in mold coating where the compression mold press is 

opened partially for a brief period to inject coating into the mold. Industry requested language to 

allow for the slight mold opening for this process. The coating does contain some HAP. 

Similarly, liquid composite molding was not addressed in the rule. In this process, glass and resin 

are combined at the mold. This issue is discussed in MFG's and CFA's written comments. 

Repair, Patching, and Bonding Materials (V-H) 

Industry comment: They desire to avoid compliance issues related to patching, bonding, and 

repair materials and request that language in the source category description specifically include 

these materials with no control requirements. This would avoid the potential problem of state 

inspectors considering these materials plastic coatings subject to control requirement. 

Switching Compliance Options (V-J) 

Industry Comment: Industry requested the ability to switch between the different compliance 

options in the proposed rule. 

EPA response: We will work on rule language to allow facilities to switch compliance options. 
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Meeting Minutes 

May 23, 2002 

Page 9 

Vapor Suppressed Resin (V-L) 

Industry comment: The vapor suppressed resin test protocol is still in the works, specifically with 

work need to ensure precision and repeatability ofthe test. 

EPA Response: We asked to be copied on communications related to the test protocol and 

indicated that we would like to have the protocol within 30 days if at all possible. 

Performance Tests (V-M) 

Industry Comment: Language in CFA's comments discussed a procedure to allow equipment 

manufacturers to demonstrate that equipment is "non-atomized". 

EPA Response: We will consider rewording the rule to include "non-atomized or lower emitting" 

application technologies. 

12 Month Averaging (V-N) 

EPA Comment: We will change the form ofthe equations for 12 month averaging so that it is 

weighted by resin use rather than simply averaging the results for each month. We asked about 

the comments he received requesting a 12 month calendar average rather than rolling average 

because we do not see how a calendar month buys more flexibility for facilities. 

Industry response: They originally made that comment based on predictability and they will 

revisit that comment. 

Specialty Gel Coats (V-O-2 through V-Q) 

Industry Comment: They had requested a new process product grouping of fire retardant gel coat. 

Fire retardant gel coat is generally made from fire retardant resin and that the HAP limit for fire 

retardant resins should be adequate for gel coats also. These gel coats do have a high HAP 

content because they have a lot of methyl methacrylate A gel coat HAP limit of 60% should be 

adequate for low flame/smoke resins. Industry suggested a proposed new definition for clarity. 

EPA Response: We agreed to look at the look at the rule language. The request for 48% HAP 

corrosion resistant gel coat can probable be supported and definition proposed by industry looks 

adequate. 

Gel Coat HAP Limits 

EPA Comment: We are limited by the available data in the HAP floor. We asked for examples of 
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Meeting Minutes 

May 23, 2002 

Page 10 

the products for which a higher HAP is needed for technical reasons. 

Industry Comment: Several industry representatives explained that the cultured marble industry 

has been particularly affected by product failures such as cracking and a higher HAP gel coat 

seems to be the only solution. 

Tooling Gel Coat - 40% HAP 

Industry Comment: Boat manufactures are having trouble complying with the 40% HAP limit for 

tooling gel coat. Boat manufacturers did not push this issue in the Boat Manufacturing NESHAP 

rulemaking because they assumed they could meet the requirement through averaging, but they 

are now having trouble with that. Facilities that are making tools for other facilities cannot 

average and can't make high quality tools with low-HAP gel coat. Few composites 

manufacturers submitted data on tooling gel coat because they assumed they would be able to 

meet limits through averaging. Facilities that are making tools to sell to others are most affected 

because they need high quality tools in order to sell them. While most facilities would be able to 

make or use tooling gel coats with 40% HAP, most could not eliminate all tooling gel coats with 

HAP content greater than 40%. 

EPA Response: We cannot change that floor now but will consider the issue further. 

Manual Gel Coat Application (V-O-7) 

Industry comment: There is no unified emission factor (UEF) equation for manual application of 

gel coat. They suggested EPA use the manual resin UEF for manual gel coat application. EPA 

also need to address manual application of gel coat where gel coat is also applied using nonatomized spray. 

EPA Response: We will add a footnote to the table of emission factors to clarify how to treat 

manual gel coat for both compliance and emissions estimation. 

Low Shrink Resin (V-Q) 

EPA Comment: We will look into creating a single "specialty" category to include low shrink 

resins with Class 1 Smoke and Fire resin. We is only aware of one manufacturer making the resin. 

HAP Content Testing (V-R) 

EPA Comment: We do not plan to add a requirement to test resins for HAP content. However, 

we will add the +/- 2% allowance to account for normal manufacturing tolerances. 
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Page 11 

Corrosion Resistant Filament Winding (V-S) 

Industry Comment: They are concerned about the potential problem ofthe lower HAP content 

limit for filament winding for facilities that do not have other operations and cannot take 

advantage ofthe provision allowing use ofthe same resin across multiple processes. 

EPA Response: The floor for filament winding is 42% and we are limited by the data. Possible 

fixes discussed included applying some resin mechanically to the mandrel to take advantage ofthe 

"same resin" provision. 

Centrifugal Casting Definition (3/26-1) 

Industry Comment: The centrifugal casting UEF is based on Fibercast, who has a very unique 

process of blowing hot air through a pipe which results in emissions of about 20% ofthe styrene. 

This number is not accurate for typical centrifugal casters who use a nearly closed process with 

very minimal emissions. Using the UEF based on Fibercast would put a lot of small facilities 

above the 100 tpy threshold and would require them to install capture and control. A suggested 

alternative is to define these process as "closed molding" rather than centrifugal casting and have 

the centrifugal casting definition only include those process that blow hot air through the mold. 

Some centrifugal casters put resin in with flow coaters and could be considered mechanical 

application. 

EPA Response: We will revisit the UEF for centrifugal casting and make any appropriate changes. 

Filament Winding (3/26-2) 

EPA Comment: We recently received a phone call about a process that drips resin onto winders. 

The caller wondered what factor should be used. 

Industry Response: The process most resembles manual application and suggested changing the 

"filament winding" definition to "filament application" using a resin bath. 

Robotic Loaders (5/23-2) 

Industry Comment: Robotic loading devices used for compression molding operations are 

essentially moving arm that cannot be operated properly with the requirement that only one 

charge per cavity may be opened at time. 

EPA response: We will revise rule language to allow the use of robotic loaders. 
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Meeting Minutes 

May 23, 2002 

Page 12 

New Source Definition (5/23-3) 

Industry Comment: This is no longer an issue. 

All HAP Assumed to be Styrene (5/23-4) 

EPA Comment: We may need to revise the rule language to clarify that we are only regulating 

organic HAP. It is not our intention to cover solids materials in the resin because we do not 

believe they are emitted during the manufacturing process. 

Revisions to Table 1 for New Technologies (5/23-5) 

Industry comments: Industry is interested is a simple way to incorporate new technologies into 

the emission factor equations in Table 1 ofthe rule, so they can take advantage of new techniques 

without a lengthy approval process. They indicated that the rule needs language describing how 

new data can be used and needs a mechanism to include new technologies in the UEF structure 

without requiring a modification to the rule. 

EPA Response: There is an "equivalent demonstration" in the general provisions that allows 

facilities to petition EPA to do an equivalency test on a case by case basis. We acknowledge that 

the process is not easy and that perhaps we need to put something in the rule to simplify the 

process. We need to research how we can accomplish it. 

EPA's Issues 

Customer Requirements 

EPA Comment: EPA has discussed the problem of customer contracts with CFA and 

acknowledged that it can be difficult to get customers to change their requirements. We are 

considering a exclusion for customers with resin-specific contracts but needs to do it in such a 

way that customers have to certify that they need the resin rather than allowing facilities to go to 

the states themselves for an exemption. This process would help prevent the exclusion from being 

misused. We will continue to work on this issue. 

Industry Comment: The Boat Manufacturing NESHAP exempts certain government specifications 

and that could be a possible way to handle this problem. 

DOD small scale manufacturing & repair operations 

EPA Comment: Are the same resins are used in small scale DOD operations as the rest ofthe 

industry? If the resins are used for repair operations only, they would already be exempt, but they 
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Meeting Minutes 

May 23, 2002 

Page 13 

could be affected if they are used to manufacture products from molds. 

Industry Response: In some cases, DOD must use highly specific resins. 

Prepreg Materials 

Industry Comment: Prepreg materials are primarily used for in the aerospace industry. However 

that it really depends on how "prepreg" is defined because different industry groups use the term 

to refer to different materials. Ninety-nine percent of prepreg materials are styrene-free. Most 

are epoxy and there are small quantities of polyester prepregs. Prepreg is similar to sheet molding 

compound (SMC) and is "preimpregnated fiber." 

EPA Response: We do not plan to cover prepreg materials. 

Resin Bath Covers 

Industry comment: The proposed height limit for pultrusion resin bath covers does not allow 

room for adjustments. They would prefer that the rule not even mention height because it does 

not impact emissions. 

Point Value Alternatives in Table 5 of proposed rule 

EPA Comment: This table was added to the rule as an afterthought in an effort to provide 

greater flexibility. We received a lot of comments that it is too stringent and plan to go back and 

look at it again. The table is less critical now that the add-on control requirement has been 

dropped for existing sources, but it might be of interest for new sources. We also want to reward 

people who have already done a lot of pollution prevention. 

Action Items 

The EPA agreed to the following action items as a result of this meeting: 

Determine how the boat industry plans to meet the 40% HAP content limit for tooling gel 

coat. 

Change the definition of non-atomized application technology to clarify the types of 

technology 

• Consider changing the centrifugal casting definition and emissions factors to differentiate 

between facilities that blow heated air through the mold, and those that do not. 
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Meeting Minutes 

May 23, 2002 

Page 14 

Work on a strategy for incorporating new application technologies into the standards. 

Consider the implications of wet area enclosures for pultrusion of large parts 
P.16 

Attachment 1 

Materials provided by EPA at the meeting 
P.17 

Meeting Agenda 

1. Presentation of draft final floors for existing sources (30 min). If CFA still has any floor 

issues, we can briefly discuss these. I don't see any ability for us to further change the floors. If 

there are areas of concern, we may be better able to address these in compliance options (such as 

the existing provision allowing use of one resin in multiple operations). 

2. Brief discussion of revised cost analysis results (15 min). Because we are no longer planning 

to go above the floor for open molding or pultrusion, we do not plan to prepare a detailed 

response to CFA's costing analysis, or to discuss the cost analysis in detail. 

3. Other planned changes to proposed rule (30 min) 

4. Outstanding issues (til 3 pm) 

5. Wrap-up and list of any action items. 
P.18 

INFORMATION ON DRAFT FINAL FLOORS, COSTS, AND PLANNED RULE CHANGES 

Proposed Rule: 

The rule we proposed required facilities in the following process/product groupings to go abovethe-floor ofthe facility emitted over 100 tpy of HAP (250 tpy if a small business): 

Open Molding 

Centrifugal Casting 

Continuous lamination 

Continuous Casting 

Pultrusion 

SMC Manufacturing 

BMC/Mixing 

Other facilities were not required to go beyond the floor. These facilities were projected to be 

able to meet MACT using pollution prevention (low HAP materials, and non-atomized spray 

application) 

This proposal had an estimated emission reduction of 14,500 TPY for existing facilities. 

The overall cost effectiveness ofthe proposed rule was $2,100 per ton and the incremental cost 

effectiveness was $1,500 per ton for existing facilities 

We did not go above-the-floor for smaller facilities because the economic impacts would be 

significant. 

Planned Major Changes for Final Rule 

Convert to use of unified emissions factors. This eliminates having facilities deal with two 

sets of equations. One to determine emissions and one to determine compliance with 

MACT. 

• Modify floor levels of control as a result of comments to the proposed rule (see tables). 

We believe that existing facilities should still be able to meet these levels with pollution 

prevention control techniques, though some facilities may have to average. 

• Limit the above-the-floor requirements to centrifugal casting, continuous lamination, 

continuous casting. Changes in our cost algorithms and the floor have resulted in a new 

incremental cost effectiveness of well over $5000 per ton for all process/product 

groupings except these three. (See tables) These three processes produce high 

concentration emission streams, and are more cost-effective to control. In the case of 

continuous lamination and continuous casting, the floor level of control required add-on 

controls. 

Where we go above the floor, set the threshold as 100 tpy for both large and small 
P.19 

businesses, rather than 100 tpy for large businesses and 250 tpy for small. There would be 

no additional existing small businesses impacted by setting one threshold rather then two. 

(See table of centrifugal casting and continuous lamination/casting facilities) 
P.20 

OUTSTANDING ISSUES TO DISCUSS 

1. Small scale manufacturing at DOD facilities and repair operations 

2. Averaging (calendar year verses 12-month rolling average 

3. Combining the one resin for multiple operations provision with averaging 

4. Patching, bonding and repair materials 

5. Prepreg materials 

6. Speciality materials/gel coats. This includes conduction gel coats, corrosion resistant gel 

coats, low shrink resins, high performance gel coats, surface gel coats, etc. 

7. Status of VSR test method 

8. Pigmented (non-white) gel coat HAP limit 

9. Changes in compliance method (part of CFA comments) 

10. Height limit for resin bath covers (pultrusion), language for doors and access panels, venting 

the enclosure. 

11. Defining nylon containing film (SMC Manufacturing) 
Comparison of MACT Floors for Open Molding - Proposed Rule and Final Rule 

Process Group 

Manual Corrosion Resistant 

Manual Noncorrosion Resistant 

Manual Tooling 

Mechanical Noncorrosion Resistant Unfilled 

Mechanical Noncorrosion Resistant Filled 

Mechanical Corrosion Resistant 

Mechanical Tooling 

Filament Winding - Corrosion Resistant 

Filament Winding - Noncorrosion Resistant 

Gel Coat - Pigmented Production-White 

Gel Coat - Pigmented Production-Non-White 

Gel Coat - Clear Production 

Gel Coat - Tooling 

Proposed 

Rule Floor 

123 

87 

122 

86 

126 

159 

254 

171 

188 

267 

377 

522 

398 

Proposed Rule 

Maximum Resin HAP 

content (weight 

percent) 

40.00 

33.60 

39.90 

-

38 nonatomized 

42.8 nonatomized 

48.3 nonatomized 

43 atomized or 

55.1 nonatomized 

42.00 

45.00 

30.00 

37.00 

44.00 

38.00 

Draft Floor for 

Promulgated 

Rule 

123 

87 

157 

87 

87 

112 

254 

171 

188 

267 

377 

522 

437 

Draft Promulgation 

Maximum Resin HAP 

content (weight percent) 

40.00 

33.60 

45.90 

38.4 nonatomized 

38.4 nonatomized 

46.2 nonatomized 

43 atomized or 

91.4 nonatomized 

42.00 

45.00 

30.00 

37.00 

44.00 

40.00 

Percent 

Change in 

Allowable HAP 

0.00 

0.00 

+6 

+0.4 

-4.4 

-2.1 

Resin HAP is basically 

unlimited for nonatomized application 

0.00 

0.00 

0.00 

0.00 

0.00 

+2 

All floor changes result in a more lenient floor except for Mechanical Noncorrosion Resistant Filled and Mechanical Corrosion Resistant. 

We believe that facilities could still meet the floor for 

Mechanical Noncorrosion Resistant filled without add-on controls, though some averaging may be required. 

TJ 

ho 
Summary of Cost Effectiveness for Recommended Final Rule for Reinforced Plastic Composites Source Catego 

Existing Sources 

Process 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mat'ls 

Totals for Source Category 

Average impacts 

TotaJ 

Reduction 

ttpy) 

5916.7 

0.0 

748.5 

576.5 

0.0 

127.8 

0.0 

807.1 

164.2 

0.0 

8340.8 

Annual 

Cost 

($/yr-l 

$18,317,266 

$65,571 

$399,610 

$1,161,829 

$44,953 

$312,746 

$12,916 

$367,322 

$489,295 

$324,092 

$21,495,600 

Cost 

Effectiveness 

<$/tw} 

$3,096 

N/A 

$534 

$2,015 

N/A 

$2,448 

N/A 

$455 

$2,980 

N/A 

$2,577 

incrementaf impacts 

Recommended Rule Compared to Ftoor 

TotaF 

Reduction 

fowl 

0.0 

0.0 

735.3 

218.3 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

953.6 

Annual 

Cost 

<*/y*.) 

$0 

$0 

$314,641 

$561,068 

$0 

$0 

$0 

$0 

$0 

$0 

$875,710 

Cost 

Effectiveness 

{$«on> 

NA 

NA 

$428 

$2,570 

NA 

NA 

NA 

NA 

NA 

NA 

$918 

Note 1: All dollars are 1998 calendar year dollars. 
Summary of Regulatory Option Cost Effectiveness for the Reinforced Plastic Composites Source Category 

Existing Sources • 1997 

NOTE: Add Data for facilities added to the database ~ numbers listed in table to the right 

Cost Effectiveness April 24-2002-Summary.xls 

10/8/2002 

Subcategory 

Open Molding 

Process 

Manual Resin Application 

Mechanical Resin Application 

Filament Winding 

Gel Coat Application 

Totals for Open Molding Subcategory 

Closed Molding Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Totals for Closed Molding Subcategory 

Centrifugal Casting Centrifugal Casting 

Totals for Centrifugal Casting Subcategory 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mat"Is 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Mat1 Is 

Totals for Reinforced Plastic Composites Source Category 

Process/Product Grouping 

Corrosion-Resistant 

Non Corrosion-Resistant 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant (Unfilled) 

Non Corrosion-Resistant (Filled) 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant 

Pigmented Production 

Clear Production 

Tooling / Mold Manufacturing 

Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Corrosion-Resistant 

Non Corrosion-Resistant 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Mot Applicable 

Mot Applicable 

MACT Floor (Actual) 

Total 

Reduction 

(tpy) 

29.6 

61.3 

0.8 

474.7 

4291.4 

0.0 

48.4 

21.2 

0.5 

894.7 

74.9 

19.2 

5916.7 

0.0 

0.0 

0.0 

0.3 

12.9 

13.2 

358.2 

0.0 

127.8 

0.0 

807.1 

164.2 

0.0 

7387.1 

Annual 

Cost 

(«yr.) 

$1,681,683 

$722,492 

$111,017 

$1,465,347 

$6,460,320 

$0 

$204,752 

$862,776 

$8,870 

$5,695,417 

$406,224 

$698,367 

$18,317,266 

$55,852 

$9,719 

$65,571 

$41,567 

$43,401 

$84,968 

$600,761 

$44,953 

$312,746 

$12,916 

$367,322 

$489,295 

$324,092 

$20,619,890 

Reg. Option w/ Size Limit (Actual) 

Average Total 

Cost Reduction 

Effectiveness 

($fton) (tpy) 

$56,772 

$11,785 

$131,740 

$3,087 

$1,505 

N/A 

$4,231 

$40,772 

$17,520 

$6,366 

$5,425 

$36,355 

$3,096 

N/A 

N/A 

N/A 

N/A 

$3,357 

$6,445 

$1,677 

N/A 

$2,448 

N/A 

$455 

$2,980 

N/A 

$2,791 

29.6 

170.3 

20.0 

500.4 

6216.7 

0.0 

181.7 

21.2 

134.2 

2435.0 

192.6 

59.0 

9960.6 

0.0 

0.0 

0.0 

0.3 

748.2 

748.5 

576.5 

0.0 

131.1 

0.0 

807.1 

252.2 

0.0 

12476.1 

Annual 

Cost 

(Wyr) 

$1,681,683 

$1,745,130 

$569,624 

$1,902,806 

$26,901,532 

$0 

$1,368,290 

$862,776 

$4,170,641 

$12,378,936 

$1,519,622 

$960,285 

$54,061,324 

$55,852 

$9,719 

$65,571 

$41,567 

$358,042 

$399,610 

$1,161,829 

$44,953 

$589,117 

$12,916 

$367,685 

$1,548,362 

$324,455 

$58,575,822 

Average 

Cost 

(Sfton) 

$56,772 

$10,244 

$28,540 

$3,802 

$4,327 

N/A 

$7,530 

$40,772 

$31,079 

$5,084 

$7,888 

$16,288 

$5,427 

N/A 

N/A 

N/A 

N/A 

$479 

$534 

$2,015 

N/A 

$4,493 

N/A 

$456 

$6,140 

N/A 

$4,695 

Regulatory Option 1 (Actual) 

Total 

Reduction 

(tpy) 

170.3 

445.4 

47.4 

761.6 

7603.5 

0.0 

334.4 

319.8 

152.0 

3432.7 

597.1 

109.7 

13973.9 

0.0 

0.0 

0.0 

16.5 

881.2 

897.7 

678.0 

0.0 

258.0 

282.5 

807.1 

408.2 

0.0 

17305.4 

Annual 

Cost 

(Vyr.) 

$6,220,618 

$8,798,424 

$3,090,520 

$15,714,912 

$72,315,781 

$0 

$6,600,459 

$11,058,515 

$4,974,215 

$30,315,848 

$13,381,941 

$2,910,610 

$175,381,844 

$55,852 

$9,719 

$65,571 

$278,777 

$881,722 

$1,160,499 

$1,625,109 

$44,953 

$18,170,677 

$5,312,112 

$371,994 

$13,618,276 

$328,764 

$216,079,798 

Average 

Cost 

($/ton) 

$36,525 

$19,752 

$65,232 

$20,634 

$9,511 

N/A 

$19,738 

$34,579 

$32,715 

$8,832 

$22,413 

$26,535 

$12,551 

N/A 

N/A 

N/A 

$16,896 

$1,001 

$1,293 

$2,397 

N/A 

$70,426 

$18,801 

$461 

$33,360 

N/A 

$12,486 

Note 1: All dollars are 1998 calendar year dollars. 
Summary of Regulatory Option Cost Effectiveness for the Reinforced Plastic Composites 

Existing Sources -1997 

NOTE: Add Data for facilities added to the database - numbers listed in table to the right 

Cost Effectiveness April 24-2002-Summary.xls 

10/8/2002 

Subcategory 

Open Molding 

Process 

Manual Resin Application 

Mechanical Resin Application 

Filament Winding 

Gel Coat Application 

Process/Product Grouping 

Corrosion-Resistant 

Non Corrosion-Resistant 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant (Unfilled) 

Non Corrosion-Resistant (Filled) 

Tooling / Mold Manufacturing 

Corrosion-Resistant 

Non Corrosion-Resistant 

Pigmented Production 

Clear Production 

Tooling / Mold Manufacturing 

Totals for Open Molding Subcategory 

Closed Molding Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Compression/Injection Molding 

Resin Transfer Molding (RTM) 

Totals for Closed Molding Subcategory 

Centrifugal Casting Centrifugal Casting Corrosion-Resistant 

Non Corrosion-Resistant 

Totals for Centrifugal Casting Subcategory 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Maf Is 

Continuous Lamination/Casting 

Polymer Casting 

Pultrusion 

SMC Manufacturing 

Cleaning Operations 

BMC/Mixing Operations 

Storage of HAP Containing Maf Is 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Not Applicable 

Totals for Reinforced Plastic Composites Source Category 

Reg. Option w/ Size Limit (Incremental) 

Total 

Reduction 

(tpy) 

0.0 

109.0 

19.1 

25.8 

1925.3 

0.0 

133.3 

0.0 

133.7 

1540.2 

117.8 

39.7 

4043.9 

0.0 

0.0 

0 

0.0 

735.3 

735.3 

218.3 

0.0 

3.4 

0.0 

0.0 

88.0 

0.0 

5089.0 

Annual 

Cost 

(Wyr.) 

$0 

$1,022,637 

$458,607 

$437,460 

$20,441,211 

$0 

$1,163,537 

$0 

$4,161,771 

$6,683,518 

$1,113,398 

$261,918 

$35,744,058 

$0 

$0 

$0 

$0 

$314,641 

$314,641 

$561,068 

$0 

$276,371 

$0 

$363 

$1,059,067 

$363 

$37,955,932 

Average 

Cost 

($/ton) 

N/A 

$9,378 

$23,991 

$16,986 

$10,617 

N/A 

$8,727 

N/A 

$31,131 

$4,339 

$9,455 

$6,589 

$8,839 

N/A 

N/A 

N/A 

N/A 

$428 

$428 

$2,570 

N/A 

$82,289 

N/A 

N/A 

$12,032 

N/A 

$7,458 

Regulatory Option 1 (Incremental) 

Total 

Reduction 

(tpy) 

140.7 

384.1 

46.5 

286.9 

3312.1 

0.0 

286.0 

298.6 

151.5 

2538.0 

522.2 

90.5 

8057.2 

0.0 

0.0 

0 

16.2 

868.3 

884.5 

319.8 

0.0 

130.3 

282.5 

0.0 

244.1 

0.0 

9918.3 

Annual 

Cost 

(Wyr.) 

$4,538,935 

$8,075,932 

$2,979,503 

$14,249,566 

$65,855,461 

$0 

$6,395,707 

$10,195,739 

$4,965,345 

$24,620,431 

$12,975,717 

$2,212,243 

$157,064,578 

$0 

$0 

$0 

$237,210 

$838,321 

$1,075,531 

$1,024,348 

$0 

$17,857,932 

$5,299,196 

$4,671 

$13,128,981 

$4,671 

$195,459,908 

Average 

Cost 

(Sfton) 

$32,262 

$21,024 

$64,028 

$49,665 

$19,883 

N/A 

$22,362 

$34,141 

$32,766 

$9,701 

$24,849 

$24,451 

$19,494 

N/A 

N/A 

N/A 

$14,602 

$966 

$1,216 

$3,203 

N/A 

$137,098 

$18,756 

N/A 

$53,796 

N/A 

$19,707 

Note 1: All dollars are 1998 calendar year dollars. 
P.25 

John Schweitzer To: Keith Barnett/RTP/USEPA/US@EPA 

<jschwtzr@gte.net> cc: 

Subject: May 23 workshop 

05/17/2002 03:12 PM 

Please respond to John 

Schweitzer 

Keith, in preparation for our May 23 workshop pn the proposed rule, we have prepared the attached 

summary of "open issues." This includes issues identified in our Oct. 25 comments and in subsequent 

correspondence with you. 

The summary also contains the following items, which we may not have raised previously: 

1. SMC manufacturing. Our Oct. 25 comments suggested that SMC compound should be wrapped 

or placed in closed containers prior to shipment. In addition, we also suggest that compound 

edges could alternatively be folded or sealed, in those few cases where this is technically 

feasible. 

2. Compression molding. Our Oct. 25 comments suggested that the rule should allow sufficient 

charges to be open (uncovered) at the press for one press cycle. In addition, we also suggest 

that, when robotic loading devices are employed, sufficient charges may be open (uncovered) for 

two press cycles - one open charge will be staged in the loader, and the other charge ready to 

be placed in the loader. 

3. New sources. Because ofthe low capital investment needed for many composite manufacturing 

operations, we suggest that a new source be clearly defined as one at a site where previously 

there was no composite manufacturing operations, and that all other operations are considered 

existing sources. We understand that this is consistent with comments you have made 

previously; but it needs to be stated very clearly in the final rule. 

4. Definition of HAP. Since EPA's database and floor calculations assumed that all HAP were 

styrene, the final rule should clearly state that, for the purposes of MACT, all HAP are assumed 

to be styrene. (The formulas that we suggested in our comments for use in Table 1 of the rule 

are stated in terms of %HAP rather than % styrene.) 

5. New P2 technologies. The final rule should provide a procedure to revise Table 1 of the rule so 

that new P2 technologies can be used to meet the MACT emission limits. 

It might be helpful for you to identify in advance those open issues where you agree with our position 

and expect to readily change the final rule. At the start of our May 23 meeting, we could quickly review 

these issues, and then spend the bulk of the meeting on issues where you either disagree with us or are 

not sure how to solve the problem. 

We look forward to reviewing the items in the attached summary with you on May 23. Thank you for 

your consideration of our comments. 

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

John Schweitzer 

Sr. Director of Gov't. Affairs 

Composites Fabricators Assoc. 

voice 734.622.0162 

fax 734.622.0122 

ischwtzr(a)Qte.net 

• 

www.cfa-ha.org MACT open issues May 23 2002.1 
RP/C NESHAP - Open Issues CFA May 23, 2002 

Comments 

section 

II- l 

Issue and CFA position 

Remove above-the-floor 95% capture and control 

for larger existing sources. 

II - 2 j Remove 95% capture and control for new sources. 

Analysis 

95% C&C is not technically feasible or affordable. 

Many likely new plants are not similar to the floor 

setting sources, and will not be able to achieve or 

afford 95% C&C. 

Status 

EPA has decided not to require any existing 

sources to install C&C (except centrifugal casting 

and continuous lamination). 

j The floor for existing and new pultrusion 

III - A j operations should be 60% reduction (compared to 

! "no control"). 

The typical large "custom" pultrusion operations 

can achieve on average only 60% control, due to 

limits in the available control technologies. 

III-B 

III-C 

Pre-form injection should be a compliance option 

for pultrusion with 90% control. 

Pultrusion operations should be able to compiy 

with the 60% reduction as a 12-month rolling 

average across all pultrusion operations. 

Pre-form injection is the most effective available 

control for many products. 

Allows production flexibility while still achieving 

the required emission reductions. 

III-D 

Wet area enclosures should be permitted for all 

pultrusion sources, and the requirements for these 

enclosures should be modified in certain ways to 

allow practical comphance. 

Wet area enclosures are the most effective 

available control for many products. 

III-E 

IV- A 

Large pultruded products should be exempt from 

control requirements. 

There are no effective commercially available and 

practical controls for large pultruded parts. 

The only source in this group using C&C needs to 

amend its permit to remove 100% capture because 

the enclosure unacceptably limits production. 

IV-B-1 

Capture and control should not be required for 

SMC manufacturing (compounding). 

Covered doctor boxes and folded/sealed edges 

should not be required for SMC compounding. 

These technologies were tried but found to be not 

practical. The rule should require that compound 

be wrapped or placed in closed containers for 

storage and transportation. 

See also 5/23 comment. 

IV-B-2 

V - A 

The requirement for nylon film for SMC 

compound should allow nylon-containing film. 

Covers instead of add-on controls should be 

required for larger mixing operations. 

Use "Mixing and BMC manulfacturing." 

Most of the barrier films used are blends of nylon 

with other polymers. 

Covers achieve the same emission reduction as 

C&C for mixers, at much lower cost. 

"BMC manufacturmg/mixing" is confusing. 

Openings are needed to permit entry of mixer 

shafts and instrumentation, and to allow venting 

during filling or emptying, and active venting is 

needed when adding fillers. 

V - B 

V - C 

Openings and vents should be allowed in mixing 

and storage vessels. Active venting should be 

allowed where needed. 

V - D Styrene and MMA should be permitted for 

cleaning in closed systems. 

Cured resin must be removed from mixing and 

storage tanks to prevent contamination. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

Comments 

section 

Issue and CFA position 

Unwrapped compression molding charges should 

be allowed for all molds in one cycle ofa press, for 

loading charges into a hopper, and to allow the use 

of slitting machines. 

Analysis Status 

V - E 

The hopper can be closed after loading, and the slit 

material can be placed in a container or otherwise 

covered. 

See also 5/23 comment. 

j "Compression molding" should include the 

V - F I addition of paste at the mold, and the use of inj mold coating. 

These operations are very common at compression 

molding sources and are considered part of this 

process. 

V - G 

V - H 

Sources should be able to use emission factors that 

have been approved as part of Title V permits. 

These factors can be more accurate, and will 

reduce the administrative burden of MACT. 

The use of patching, bonding, and repair materials 

should be included in the source category 

definition, with no control requirements. 

These materials are widely used, but in small 

quantities. 

V - I 

V - J 

R&D activities should be exempt from control 

requirements. 

This is EPA's usual practice. 

Sources should be allowed to switch compliance 

options. 

Sources may occasionally need to switch to 

averaging, and the rule should provide guidance on 

doing so. 

V - K 

V - L 

The UEF should be used instead ofthe PV. 

The UEF are more accurate, and their use will 

reduce the administrative burden ofthe rule. 

j EPA has agreed to use the UEF. 

The rule should allow the use of CFA's VSE test. 

Without a test, sources will not be able to take 

credit for use of suppressed resin systems. 

CFA is preparing the additional test data requested 

by EPA. 

V - M 

V - N 

A performance test should be used to qualify "nonatomized" equipment. This will allow the development of new 

equipment, and will increase clarity ofthe rule. 

The proposed ruie weighs each month equally, 

even if widely different amounts of resin are used. 

V-O-l 

Sources using averaging should calculate 

emissions as a weighted average of resin used. 

"White/off-white" gei coats should be those that 

contain 10% or more by weight T1O2. 

I Increases clarity ofthe rule. 

j Needed for adequate performance. 

V-O-3 

V-O-4 

48% HAP should be allowed for CR.gel coat. 

48% HAP should be allowed for high performance 

gel coat. 

Needed for adequate performance. 

V-O-5 

V-O-6 

There should be no HAP limit for fire retardant gel 

coat. 

Needed for adequate performance. 

48% HAP should be allowed for clear gel coat 

used for cultured marble. 

Needed for adequate performance. 

Needed for adequate performance. 

49% HAP should be allowed for pigmented 

tooling gel coat, and 52% for clear. 

^1 
RP/C NESHAP - Open Issues CFA May 23, 2002 

Comments 

section Issue and CFA position Analysis Status 

V-O-7 

Gel coat should be considered a resin when applied 

manually, and manual application of small 

amounts of gel coat should be exempt from 

recordkeeping requirements. 

Increases clarity and reduces administrative burden 

ofthe rule. 

V - P Adopt the industry-suggested definition for "low 

flame/smoke." Increases clarity ofthe rule. 

50% HAP should be allowed for low-shrink resin. 

Requirements for testing HAP content should be 

the same as in the boat MACT. 

Needed for adequate performance. 

Increases clarity and reduces administrative burden 

ofthe rule. 

V -R 

V - S 48% HAP should be allowed for CR filament 

winding. 

Remove SIC codes12821 and 3087. 

Needed for adequate performance. 

These industries are not composites manufacturers. 

EPA asked for examples of products for which the 

higher HAP limit is needed for technical reasons. 

V - T 

3/19 Update the combined mechanical database. 

EPA's new combined filled/unfilled mechanical 

apphcation database contains inaccurate 

information, and would result in a before-filler 

HAP limit of 3 5%. 

EPA has reported that the database has been 

corrected and the floors now limit before-filler 

HAP to 39%. 

3/26-1 

Change the definition of "centrifugal casting" to 

include only those operations where hot air is 

blown into the molds to cure the product. Also 

update Table 1. 

Most centrifugal casting operations use ambient 

cure or the molds are closed during cure. In these 

cases, the emission factors for mechanical or 

manual apphcation should be used, and these 

sources should not have to install C&C. 

; Change "filament winding" to "filament 

3/26-2 j apphcation," and include only the apphcation of 

| resin using a resin bath. Also update Table 1. 

Increases clarity ofthe rule. 

4/8 

5/23-1 

Change the definition of "polymer casting" to 

remove the reference to "working" the resin, or 

allow working the resin after molds are closed. 

If the edges of SMC compound is foided or sealed, 

then it should not have to be wrapped or placed in 

closed containers. 

Increases clarity ofthe rule. 

Folding or sealing edges is technically feasible in a 

few cases. 

See comment IV-B-1. 

5/23-2 

When robotic loading devices are employed for 

compression molding operations, sufficient 

charges may be open (uncovered) per cavity for 

two press cycles. 

One open charge will be staged in the loader, and 

the other open charge (pre-stage) ready to be 

placed in the loader. 
RP/C NESHAP - Open Issues CFA May 23, 2002 

S£r?n t S ^ lssu e an d CF A P° sitio n I Analysis j Status 

i- i- -iI . LUUIIJC J a : Because ofthe low capital investment needed for 

; A new source should be clearly defined as one at a ; .. \. . • 

, , ., v

 : many composite manufactunng operations, many 

el-r, , : site where previously there was no composite n . . -^ .. 5/23-3 - . . \. , ,, ,, ,. • small changes to existing sources may trigger new 

: manufactunng operations, and all other operations ; u .TM. f. . . . ? ... . . , , 

; . ,, , -j j • L : source MACT if this defimtion is not clearly I should be considered existing sources. : , , 

I The finai ride should cleariy state that, for the I TM ., . . , , „ , , .. ,„. . i 

,,»- . c-atkr^rr tiTTAr. J a i_

 ! EPAs database and floor calculations assumed that : 5/23-4 : purposes of MACT, all HAP are assumed to be ; „ rT. _ . 

• ^ : all HAP were styrene. I styrene. 

j The finai rule should provide a procedure to revise \ Without a ciear and workable procedure, new and 

5/23-5 ! Table 1 ofthe rule so that new P2 technologies can j effective emission reduction techniques will not be j 

i be used to meet the MACT emission limits. j developed or used.