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OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

19) IV-B-19 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 19 of 273 
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MEMORANDUM 

TO: Docket A-94-52 

FROM: Susan Cassidy and Kenneth R. Meardon 

Pacific Environmental Services, Inc. 

DATE: November 1,2002 

SUBJECT: Table 7 - Options Allowing Use ofthe Same Resin Across Different 

Application Methods 

Section 63.5810(c) ofthe reinforced plastics NESHAP includes a provision that allows a 

facility to use the same resin across multiple application methods, provided that resin meets the 

HAP content limitation for one ofthe application methods in which it is used. The HAP content 

limitations for this provision are detailed in Table 7 ofthe rule. 

The provisions of Section 63.5810(c) can only be used by facilities that wish to use the 

same resin across different application methods. A facility can not use the maximum HAP 

content limits in Table 7 ofthe final rule for different resins regardless of their HAP content. A 

facility that uses the same resin in three application techniques and another resin in a fourth 

application technique can use Table 7 for the resin used in the three applications but not for the 

resin used in the fourth application technique. The resin used in the fourth application technique 

must comply with the limits found in Table 3 ofthe final rule. 

In addition, the provisions found in Section 63.5810(c) apply to only three types of resins: 

corrosion resistant and/or high strength resin, non-corrosion resistant resin, and tooling resin. 

Shrinkage controlled resins, low-flame/low-smoke resins, and flame retardant resins are not 

included because the emission limitations for these resins in Table 3 are already based on the 

same HAP content regardless ofthe application technique. 

Determination of Maximum HAP Contents 

Table A presents the maximum HAP content limits for each ofthe three resin types by 

application method. These maximum HAP content limits are based on the emission limitations 

found in Table 3 ofthe final rule. The maximum HAP content limits in Table 7 ofthe final rule 

were determined by looking at all processes for which the same resin type could be used, and 

selecting the HAP content limit that allows the highest HAP content. A facility must use a 

resin(s) with a HAP content(s) lower than or equal to that allowed for an application technique at 

that facility. A facility may also average resin organic HAP contents for each type and 

application method. Use an average weighted by resin use over the last 12 months. Examples 1. 

through 3 illustrate how the values in Table 7 ofthe final rule were derived. Example 4 
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Table 7 - Options Allowing Use ofthe Same Resin Across Different Application Methods 

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illustrates the use of averaging to comply. 

Example 1 

Facility A uses the same corrosion-resistant resin in four different operations - centrifugal 

casting, nonatomized mechanical application, filament application, and manual application. 

Taken individually, these application techniques have emission limits for existing sources that 

correspond to a maximum HAP contents of 51.9%, 46.2%, 42%, and 40.0%, respectively. Under 

the "same resin" provisions outlined in section 63.5810(c) ofthe rule, this facility may use the 

same corrosion-resistant resin in all four application methods, provided the HAP content of that 

resin is 48% or less. This allows the facility to use a 48% HAP resin in manual application rather 

than the 40% HAP resin that would be required by Table 3 ofthe final rule. This example is 

illustrated in the following table. 

Resin Type 

Corrosion-resistant 

Application Method 

Centrifugal casting 

Mechanical, non-atomized 

Filament 

Manual 

Maximum HAP 

Content (from Table 

3) by Application 

Method 

51.9 

46.2 

42 

40 

Allowable Maximum HAP 

Content for Use of Same Resin 

Across Application Method 

(Table 7) 

51.9 

51.9 

51.9 

51.9 

Example 2 

Facility B uses the same corrosion-resistant resin in nonatomized mechanical application, 

filament application, and manual application, but not in centrifugal casting. For this facility, the 

maximum HAP content is 46.2%, because that is the highest allowed for the application 

techniques for that resin type. This is illustrated in the following table. 

Resin Type 

Corrosion-resistant 

Application Method 

Mechanical, non-atomized 

Filament 

Manual 

Maximum HAP 

Content (from Table 

3) by Application 

Method 

46.2 

42 

40 

Allowable Maximum HAP 

Content for Use of Same Resin 

Across Application Method 

(Table 7) 

46.2 

46.2 

46.2 

Example 3 

Facility C is using the same corrosion-resistant resin in filament application and manual 
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Table 7 - Options Allowing Use ofthe Same Resin Across Different Application Methods 

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application, but not mechanical or centrifugal casting, can use a resin with a maximum HAP 

content of 42%. This is illustrated in the following table. 

Resin Type 

Corrosion-resistant 

Application Method 

Filament 

Manual 

Maximum HAP 

Content (from Table 

3) by Application 

Method 

42 

40 

Allowable Maximum HAP 

Content for Use of Same Resin 

Across Application Method 

(Table 7) 

42 

42 

Example 4 

Facility B uses two corrosion resistant resins. One has a HAP content of 48% and the 

other a HAP content of 40%. Over the last 12 months, the facility used 50 tons ofthe 48% HAP 

resin and 25 tons ofthe 40% HAP resin in the non-atomized spray operations. The weighted 

average would be: 

(48% x 50) + (40% x 251 =45 percent. 

75 

The limit is 46.2%, so this process complies. 

In filament winding, the facility used 45 and 30 tons of these two resins. The weighted 

average would be: 

(48% x 45) + (40% x 30) = 44.8% 

75 

The limit is 46.2%, so this operation complies. 

Table A lists the combinations of resin category and application techniques included in 

Table 7 with the maximum HAP content for each process from Table 3 ofthe rule. For each 

resin category, the process groups are ranked from high to low HAP content. At each facility, the 

application technique in use at the facility with the highest maximum HAP content determines 

the maximum allowed HAP content for all application techniques within that resin category. 

A facility must be using the same resin (or combination of resin if averaging) to take 

advantage ofthe alternative limits in Table 7. For example, a facility that has non-atomized 

mechanical application for tooling resin can use a tooling resin with a HAP content up to 91.4% 
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Table 7 - Options Allowing Use ofthe Same Resin Across Different Application Methods 

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in that process. That same resin can also be used for manual or atomized mechanical tooling 

operations. The facility cannot use a 91.4% HAP resin in the non-atomized mechanical 

application and a 50% resin in manual tooling applications because the 50% resin does not 

comply with the limit for manual application and the resin is not being used in another process 

for which is does comply. 

TABLE A 

Resin Type and Application Techniques Included 

in Table 7 of the RFP NESHAP 

Resin Type 

Corrosion-Resistant/High Strength 

Resin 

Non-corrosion-resistant resin 

Tooling Resin 

Application Technique 

Centrifugal Casting 

Non-Atomized Mechanical 

Application 

Filament Application 

Manual Application 

Filament Application 

Mechanical Application 

Manual Application 

Centrifugal Casting 

Non-atomized mechanical Application 

Manual Application 

Atomized Mechanical Application 

Max. HAP 

content 

51.9% 

46.2% 

42% 

40% 

45% 

38.4% 

33.6% 

37.5% 

91.4% 

45.9% 

43%