p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

<ftjJ6tf\\-F-3 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 254 of 264 
P.2 

=== — E - f-3 

Office of Air yuauty nanmng ana 

Standards 

Emission Standards Division (MD-13) 

Organic Chemicals Group 

Research Triangle Park, NC 27711 

FAX COVER SHEET 

TO Mr. Peter D. Eglinton COMPANY 0ffic e o f Managemeil t an d 

Budget 

OFFICE* 202-395-5887 FAX* 202-395-7285 

FROM Keith Barnett 

OFFICE* (919) 541-5605 FAX* (919) 541-3470 

DATE 

October 13, 2000 

NUMBER OF PAGES INCLUDING COVER SHEET 

10 

COMMENTS: 

Dear Peter: 

The changed pages for the Reinforced Plastic Composites MACT follow. 

Keith 

/ " 

Transmitted from the Organic Chemicals Group 

Fax Number: (919) 541-3470, 10th Floor 

Confirmation Number: (919)541-5607 
P.3 

"ILE MODE 

©6 MEMORY TX 

P. 1 

* * * COMMUNICATION RESULT REPORT ( OCT.13.2000 3=15PM ) * * * 

TTI 

OPTION ADDRESS (GROUP) _ _ RESULT PAGE 

912023957285 OK P. 10/10 

REASON FOR ERROR 

E-l) HANG UP OR LINE FAIL 

E-3) NO ANSWER 

E-2) BUSY 

E-4) NO FACSIMILE CONNECTION 

Office of Air Quality Planning and 

Standards 

Emission Standards Division (MD-13) 

Organic Chemicals Group 

Research Triangle Park, NC 27711 

FAX COVER SHEET 

TO Mr. Peter D. Eglintou COMPANY office of Management jand 

Budget I 

omcEi 202-395-5887 FAX* 202.395-7285 

FROM Keith Barnett 

omCE* (919) 541-5605 »AX# (919 )

 541.347o 

DATE; 

October 13, 2000 

NUMBER OF PAGES INCLUDING COVER 6HEBT 

10 

COMMENTS; 
P.4 

99 

consists of operations in which reinforced and/or 

nonreinforced plastic composites or plastic molding 

compounds are manufactured. These operations use thermoset 

resins and/or gel coats that contain styrene and/or methyl 

methacrylate to produce plastic composites, which contain 

materials designed to enhance the chemical, physical, and/or 

thermal properties of the product. Reinforced plastic 

composites production also includes cleaning, mixing, and 

material storage associated with the production of plastic 

composites. 

§63.5790 What parts of my plant does this subpart cover? 

(a) This subpart applies to each new or existing 

affected source at reinforced plastic composites production 

facilities. 

(b) The affected source consists of all parts of your 

facility engaged in the following operations: open molding, 

closed molding, centrifugal casting, continuous lamination, 

continuous casting, polymer casting, pultrusion, sheet 

molding compound (SMC) manufacturing, bulk molding compound 

(BMC) manufacturing, mixing, cleaning of equipment used in 

reinforced plastics composites manufacture, material 

storage, any other plastic composites operations. 

§63.5795 How do I know if my reinforced plastics composites 

production facility is a new affected source or an existing 

affected source? 

(a) A reinforced plastic composites production 

facility is a new affected source if it meets all the 
P.5 

101 

tons per year (tpy) basis? 

To determine your facility's HAP emissions, you must 

use the procedures in either paragraph (a) or (b) of this 

section and calculate the combined HAP emissions in tpy from 

the following operations: open molding, centrifugal casting, 

continuous lamination, continuous casting, pultrusion, sheet 

molding compound manufacturing, mixing, and bulk molding 

compound manufacturing. 

(a) For existing facilities, you may use the procedures 

in either paragraph (a)(1) or (2) of this section. 

(1) Use point value equations or emission factors. 

Calculate a weighted average emission factor on a lbs/ton of 

resin and gel coat basis. Base the weighted average on the 

12 months of operation prior to the effective date of this 

subpart. Multiply the weighted average emission factor by 

resin and gel coat use over the same period. You may 

calculate this emission factor based on the point value 

equations in Table 1 of this subpart, or you may use any 

emission factor approved by us such as factors from the 

Compilation of Air Pollutant Emission Factors, Volume I: 

Stationary Point and Area Sources (AP-42). This calculation 

must be repeated and reported annually. 

(2) Conduct performance testing. Perform performance 

testing using the methods specified in this subpart to 

determine a facility-specific emission factor in lbs of HAP 

emissions per ton of resin and gel coat used. The test 
P.6 

102 

should be performed under conditions expected to result in 

the highest possible HAP emissions, or the facility must 

stay within 10 percent of the same mix of operations that 

occurred during testing. Multiply this factor by annual 

resin and gel coat use to determine annual emissions. 

(b) For new facilities, calculate a weighted average 

emission factor on a lbs/ton of resin and gel coat basis. 

Base the weighted average on your projected operation for 

the 12 months subsequent to facility startup. Multiply the 

weighted average emission factor by projected resin use over 

the same period. You may calculate this emission factor 

based on the point value equations in Table 1 of this 

subpart, or you may use any emission factor approved by us, 

such as factors from AP-42, or emission test data from 

similar facilities. This calculation must be repeated and 

reported annually. 

§63.5800 When do I have to comply with this subpart? 

(a) You must initially comply with the standards in 

this subpart by the dates specified in Table 2 to this 

subpart. 

(b) If your facility is a new affected source and emits 

less than 100 tpy of HAP at the time of initial compliance 

with this subpart, and subsequently increases its actual HAP 

emissions to 100 tpy or more, then your facility must 

subsequently meet the standards in §63.5805(d). You must be 

in compliance with these more stringent standards within 3 

years of the date your facility meets or exceeds the 100 tpy 
P.7 

104 

emission limits in Table 3 of this subpart and the work 

practice standards in Table 4 of this subpart that apply to 

you. 

(b) If you have an existing facility that is a small 

business as defined by the SBA regulations at 13 CFR 121.201 

and emits 250 tpy or more of HAP, or if you have a facility 

that is not a small business and emits 100 tpy or more of 

HAP from the combination of all open molding, centrifugal 

casting, continuous lamination/casting, pultrusion, SMC 

manufacturing, and mixing/BMC manufacturing operations, you 

must reduce the total HAP emissions from these operations by 

at least 95 percent by weight and meet any applicable work 

practice standards in Table 4 of this subpart that apply to 

you. As an alternative to meeting 95 percent by weight, you 

may meet the emission limits in Table 5 of this subpart. If 

you have a continuous lamination/casting operation, that 

operation may alternatively meet an emission limit of 1.47 

lbs of HAP per ton of neat resin plus and neat gel coat plus 

applied 

(c) If you have a new facility that emits less than 100 

tpy of HAP from the combination of all open molding, 

centrifugal casting, continuous lamination/casting, 

pultrusion, SMC manufacturing, and mixing/BMC manufacturing, 

you must meet the annual average emission limits in Table 3 

of this subpart and the work practice standards in Table 4 

of this subpart that apply to you. 
P.8 

105 

(d) If you have a new facility that emits 100 tpy or 

more of HAP from the combination of all open molding, 

centrifugal casting, continuous lamination/casting, 

pultrusion, SMC manufacturing, and mixing/BMC manufacturing, 

you must reduce the total HAP emissions from these 

operations by at least 95 percent by weight and meet any 

applicable work practice standards in Table 4 of this 

subpart that apply to you. As an alternative to meeting 95 

percent by weight, you may meet the emission limits in Table 

5 of this subpart. If you have a continuous 

lamination/casting operation, that operation may 

alternatively meet an emission limit of 1.47 lbs of HAP per 

ton of neat resin plus and neat gel coat plus applied. 

(e) If you use an add-on control device to comply with 

this subpart, you must meet all requirements contained in 40 

CFR part 63, subpart SS. 

Options for Meeting Standards 

§63.5810 What are my options for meeting the standards for 

new and existing open molding and centrifugal casting 

operations? 

You must use one of the following methods in paragraphs 

(a) through (c) of this section to meet the standards in 

§63.5805. 

(a) Meet the individual model point values for each 

operation. Demonstrate that you meet the individual model 

point values for each open molding operation and for each 
P.9 

106 

centrifugal casting operation in Table 3 or 5 of this 

subpart that apply to you. This is done in two steps. 

First, determine a point value for each individual resin and 

gel coat, application method, and control method you use in 

a particular operation. Then, calculate a weighted average 

of those point values based on resin and gel coat use. 

These calculations shall be performed monthly. You must 

either be at or below the applicable point value in Table 3 

or 5 of this subpart each month, or at or below the 

applicable point value in Table 3 or 5 of this subpart, 

based on a 12-month rolling average. The procedures are 

described in paragraphs (a)(1) and (2) below. 

(1) Calculate your actual point values for each 

different process stream within each operation. Process 

streams within operations are different from each other if 

any of the following three characteristics vary: the neat 

resin plus or neat gel coat plus HAP content, the 

application technique, or the control technique. You must 

calculate the different process stream point values by using 

the appropriate model point value equations in Table 1 of 

this subpart for open molding and for centrifugal casting. 

If you want to use vapor suppressants to meet the point 

value for open molding, you must determine the vapor 

suppressant effectiveness by conducting testing to 

demonstrate the vapor suppressant effectiveness. If you 

want to use an add-on control device to meet the point 
P.10 

107 

value, you must determine the add-on control factor by 

conducting capture and control efficiency testing as 

indicated in Table 6 of this subpart. The point value 

calculated from the equations in Table 1 of this subpart' is 

multiplied by the add-on control factor to calculate the 

point value after control. Use Equation 1 of this section 

to calculate the add-on control factor used in the model 

point value equations. 

, ,, „ ^ . „ . % Control Efficiency 

Add-on Control Factor = 1 - — (En 1) 

100 * q*

 ; 

Where: 

% Control Efficiency = a value calculated from 

emission test measurements 

made according to the 

requirements of Table 6 of 

this subpart 

(2) Calculate your actual operation point value for 

each calendar month for each open molding operation and for 

each centrifugal casting operation by calculating the 

weighted average of the individual process stream point 

values within each respective operation. To do this, sum 

the product of your actual process stream point values and 

the amount of neat resin plus and neat gel coat plus used in 

each process stream and divide the numerator by the total 

amount of neat resin plus and neat gel coat plus used in the 

process streams. Use Equation 2 of this section to 

calculate your actual individual point value for each 
P.11 

109 

and divide the numerator by the total amount of neat resin 

plus and neat gel coat plus used in the operation. Use 

Equation 3 of this section to calculate the weighted average 

point value. 

Y, ( PVt * Material.) 

Weighted Average Point Value = — (Eq. 3) 

2j Material. 

i=l 

Where: 

PVi = point value from operation i, lbs/ton 

from Table 3 or 5 of this subpart 

Materia^ = neat resin plus or neat gel coat plus 

used during the calendar month for 

operation i, tons 

n = number of operations 

(2) Calculate your actual weighted average point value 

for each calendar month to determine if you meet the 

weighted average point value calculated in paragraph (b)(1) 

of this section. Do this by summing the product of your 

actual operation point values and the amount of neat resin 

plus and neat gel coat plus used in each operation and 

dividing the numerator by the total amount of neat resin 

plus and neat gel coat plus used in the operation groupings. 

You must calculate your actual individual' point values for 

each operation as described in paragraphs (a)(1) and (2) of 

this section. Use Equation 4 of this section to calculate 

your actual weighted average point value. 
164 

P.12 

Table 9 to Subpart WWWW. 

Practice Standards 

Initial Compliance With Work 

For ... That must meet 

the following 

standard... 

You have demonstrated 

initial compliance if. 

1. a new or 

existing closed 

molding 

operation using 

compression/ 

injection 

molding 

uncover, unwrap 

or expose only 

one charge per 

mold cycle per 

compression/ 

injection molding 

machine 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status 

that only one charge is 

uncovered, unwrapped or 

exposed per mold cycle 

per compression/ 

injection molding 

machine 

2. an existing 

SMC 

manufacturing 

operation 

close or cover 

the doctor box on 

each SMC 

manufacturing 

machine 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status 

that the doctor box on 

each SMC manufacturing 

machine is closed or 

covered 

3. an existing 

SMC 

manufacturing 

operation 

fold edges of SMC 

prior to storage 

and/or transport 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status 

that the edges of SMC 

are folded prior to 

storage and/or transport 

4. an existing 

SMC 

manufacturing 

operation 

use nylon film or 

a film with an 

equal or lower 

permeability to 

styrene than 

nylon to enclose 

SMC 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status 

that a nylon film or 

film with an equal or 

lower permeability to 

styrene than nylon is 

used to enclose SMC 

5. a new or 

existing BMC 

manufacturing/mi 

xing operation 

use mixer covers 

with no visible 

gaps present in 

the mixer covers 

the owner or operator 

submits a certified 

statement in the notice 

of compliance status 

that each mixer is 

equipped with a cover 

that does not contain 

any visible gaps