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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

66) ll-C-92 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:29 PM Sheet 66 of 343 
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|> A ro UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| ^j} ^ | RESEARCH TRIANGLE PARK, NC 27711 

X ! > A 84 52 

11 - C-72 

JUN 4 I998 ~— - . OFFICE OF 

AIR QUALITY PLANNING 

ANO STANDARDS 

Mr. John Schweitzer/Mr. Steve McNally 

Composite Fabricators Association 

1655 North Fort Myer Drive, Suite 510 

Arlington, Virginia 22209 

Dear John and Steve: 

This is to follow up on the teleconference call that Melanie Proctor, Charles Hester, and I 

had with you on May 26,1998 to discuss the cost elements listed in your May 9, 1998 letter. 

This letter summarizes my understanding of what the Composite Fabricators Association (CFA) 

had in mind for the various costs listed and reviews the action items discussed. 

Direct Costs 

Under the direct costs, the CFA indicated that the testing of corrosion resins would be a 

cost incurred by the resin manufacturer; the corrosion testing would be done once per resin. The 

CFA estimated that no more than 40 percent ofthe composite manufacturers using vapor 

suppressants receive the resin already suppressed. Thus, at least 60 percent of suppressant users 

would be testing at the facility. However, if we determine (in the development ofthe test 

method) that the vapor suppressant test needs to be done by the composites manufacturing 

facility, then 100 percent ofthe facilities will need to do testing. 

Indirect Costs 

The CFA considers the higher labor costs due to processing problems as a one-time cost 

and, potentially, a continuous cost. If, for example, the new resin system results in a greater rollout time (due to a viscosity change), this could increase labor cost on a continuous basis. The 

one-time cost is associated with the learning curve. The cost of rework and scrap due to 

processing problems is a one-time cost associated with the learning curve. Because a compliance 

date will be provided that will allow facilities time to comply with the rule, the CFA agreed that 

the cost pertaining to lost business is no longer an issue. The cost for training workers to handle 

the new equipment or materials would be a one-time cost. 

The cost of testing new application equipment, suppressants, or resins involves a facility 

trying out the various choices available to choose the one that works best for their situation. This 

is a one-time cost. The cost of additional materials would be a continual cost that would result if 

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Internet Address (URL) • http://www.epa.gov 

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a facility needed to increase the amount of resin used or use a more expensive glass or filler to 

attain the necessary product quality using a new resin system. The cost of rework, returns, and 

scrap due to product failure is a one-time cost that would result if a product failed. According to 

the CFA, whenever there is a chemistry change to the resin, the quality ofthe product could be 

negatively effected. If this occurred, it could result in a small cost (one part) or large cost (a 

truck load or all parts made under the warranty). The CFA considers the cost of lost business as 

a cost of losing a customer due to problems with product quality. This is a one-time cost. 

It was agreed that the laboratory tests of new resins or suppressants was already covered 

under the direct costs and other testing costs. The cost of making sample products is considered 

a cost to test the sample products, since the cost to make the sample products would already be 

covered by the costs previously discussed. This is a one-time cost. The cost of laboratory, 

engineering, and third-party activities is related to the UL testing discussed subsequently. An 

example of products that would require UL testing Me fuel storage tanks; it was assumed this 

would be a one-time cost that would be needed to be done whenever the resin system was 

changed. However, the CFA will speak to storage tank manufacturers to get a better 

understanding of UL testing and its cost. The CFA agreed that fabricators were already required 

to participate in ASTM, ASME, and other bodies that govern product requirements, so this 

would not be a cost ofthe standard. The EPA explained that the potential for business closure is 

evaluated in the economic impact analysis ofthe rule and that this is not a cost ofthe compliance 

ofthe rule. 

Action Items 

As discussed in the meeting, we request that the CFA provide supporting information 

needed to allow us to consider incorporating the costs suggested in the May 9, 1998 letter. One 

area where further information is needed is the specifics of which products and/or under which 

particular situations will facilities incur the product failure and processing problems costs. Also 

needed are specific parameters required to cost the elements discussed in this letter that are 

associated with changing to lower HAP content resins, non spray resin applicatipn techno logy, 

and vapor suppressants. The CFA also agreed to investigate cost savings involved. We 

understand that the CFA will provide written supporting documentation. Separate 

documentation would be needed for each ofthe above changes. 

Further, the CFA will provide details on UL testing and associated costs. We request 

this information be provided by June 30, 1998. As soon as we receive this information, we will 

analyze how the above costs will be incorporated in the cost analysis. 

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If you have any questions on the above summary or action items, please call me at 

(919)5412383. 

Sincerely, 

t I ^IcJib/* i!A^r 

Madeleine Strum 

Environmental Engineer 

Coatings and Consumer Products Group 

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