p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

73) ll-E-33 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 73 of 264 
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if 

UllliTEQ STATES ENVIRONME|NTAL PROTECTION AGENCY 

, Office of Air Qualify PI inning and Standards 

Research Triangle Ifark, North Carolina 27711 

SDEC-5I99T 

EPA AIR DOCKET *<V 

nrr 1 $ iqpt; 

REINFORCED PLASTIC COMPOSITES NESHAP PRE-MACT TEAM MEMBERS 

Dear Team and/or Work Group Member: 

The pre-MACT team held a teleconference on September 27, 

1995 to discuss issues related to the development of standards 

for the plastic composites industry. The key topics addressed 

included the determination of major sources, subcategorization of 

the industry, and potential formats for the standards. Please 

refer to the attached copy of the meeting minutes for details of 

these and other topics of discussion (Enclosure 1). 

Several issues reguire additional input and information to 

be collected from the pre-MACT team. These issues pertain to the 

subcategorization and analysis of the industry for the purpose of 

setting standards. We need your input oh these matters so that 

the development of MACT floors and proposal of the standards can 

proceed. I have highlighted in Enclosure 2 a list of "core 

issues" on which input, from the team is crucial. In addition, 

please be sure to read the "Next Steps" section of the meeting 

minutes for ways to facilitate the development and progress of 

the rule. In order for us to utilize this information in 

developing the rule, we need to receive your input by November 3, 

1995. 

2383. 

If you have any questions, please contact me at (919) 541-

Sincerely, cerexy, A 

Madeleine Strum 

Project Leader 

Coatings and Consumer Products Group 

Enclosures 
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»; 

ADDRESSEES; , ,_ 

Mark Banner, RTI 

Mohan Balagopalan, SCAQMD "TS^OCIRIA -• 

Janet Beloin, Region I '"' " . 

Bob Burmark, Washington DOE 

Jane Caldwell, OAQPS/AQSSD (MD-15) 

Leonardo Ceron, Region IV 

Lisa Conner, OAQPS/AQSSD (MD-15) 

Patricia Embrey, OGC (2344) 

Bob Fegley, ORD (8105) 

Chuck French, OAQPS/AQSSD (MD-15) 

Linda Herring, EPA/ESD (MD-13) 

Norm Kaplan, EPA/ORD (MD-61) 

Emery Kong, RTI 

Karen Levy, OPAR (6103) 

Maria Malave, OECA (2223A) 

Haile Mariam, OSW (5302W) 

Craig Matthiessen, OSWER (5101) 

Steve McNally, Composites Fabricators Assoc. 

Christine McPhee, Ohio EPA 

Arnold Medbery, OSDBU (1230-C) 

Richard Nielson, Clark County, NV 

Carlos Nunez, ORD (MD-61) 

Nancy Pate, OAQPS/ITPID 

Solomon Ricks, OAQPS/EMAD (MD-19) 

Ron Ryan, OAQPS/EMAD (MD-14) 

John Schweitzer, Composites Institute 

Jordan Spooner, OPPT/PPD (7409) 

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Enclosure 1 

MEMORANDUM 

TO: Madeleine Strum, U.S. EPA/OAQPS/ESD 

FROM: Greg LaFlam, Pacific Environmental Services, Inc. (PES) 

DATE: October 12, 1995 

L:\N308 

SUBJECT: Pre-MACT Team/EPA Workgroup Teleconference - September 27, 1995 

I. Purpose 

The primary purpose of this meeting was to discuss and reach agreement on several 

issues regarding industry subcategorization, identification of major sources, and potential 

formats of the NESHAP standard. A second purpose was to request support from the team 

in obtaining additional data and reaching a consensus on decisions needed in developing a 

regulatory proposal for the plastic composites source category. 

n. Location of Meeting and Participants 

Place: U.S. Environmental Protection Agency 

N.C. Mutual Life Building, Room 1101 

Durham, NC 

Date: September 27,1995, 1:00-3:45 pm 

Participants: Mark Banner, RTI (919) 541-6016 

Mohan Balagopalan, SCAQMD (909) 396-2704 

Janet Beloin, Region I (617) 565-2734 

Jeffrey Best, PES (919) 941-0333 

Dan Boyd, consultant* 

Bernard Brie, Washington DOE (206) 407-6812 

Leonardo Ceron, Region IV (404) 347-3555 

Linda Chappell, OAQPS (919) 541-2864 

Chris Collins, Mohave Desert* 

Lisa Conner, OAQPS/AQSSD (919) 541-5060 

Bob Fegley, ORD (202) 260-0484 

Eric Goehl, Radian (919) 461-1367 

Norm Kaplan, ORD (919) 541-2556 

Jan King, OAQPS (919) 541-5665 

Emery Kong, RTI (919) 541-5964 
P.5 

M " d *'I"' ' tf '"*'*"".vf"' 

Madeleine* Strum 

October'12, 1995 

Page2 

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.., ., , .Richard Nielson, Clark.County...NY (702) 383rl276 ,, > •. 

r^r 4 T - - - , Geddes Ramsey, PRDX919) 541-7963.1,., „.,,;„«.,,,; -

" :" 'K ;• ';;; .Solomon Ricks,,.OAQPS/EMAD.(919)541-5242v,, >|0M ,. 

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 "i/ 5 \ ~. ; Jordan Spopner„OPPT/PPDI(202) 2604418.„ . ^ ,rwW. 

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'*''

 t!^ Ms. Stniriiopened the meeting by asking the participants to introduce themselves. 

She then stated that the meeting would proceed according to the material in the briefing 

package (meeting agenda expanded through the addition of detailed discussion points) which 

had been faxed to'the^oup just'prior to the meeting, and said this package would be

 :" 

included with^the meetSmg minutes (see Attachment 1). 

-• ..; .';./ ••''oir,.; ; .• ...:.d:°.i:'.] .i<:.i:d 

• Ms. Stnim then enumerated the principal goals ofthe meeting as listed in item 2 of 

tiiebriefing package: 1) agree on a methodology for identifying major source facilities in 

the data, base, 2) discuss subcategory issues and agree on an approach, 3) discuss possible * 

formats for the standards for open molding processes, 4) discuss control measures i n use, 

and 5) request thefsupport of the team m acquiring additional data and in reviewing memos 

aid other materials generated under the project .There was no response to Ms.'Strum's 

request for discussion from the group on the goals of the meeting. 

,•;. . ., . .,-•.-. • • - . •.-. • • •• • ' • •. :•'•'••;• • ;'!-{> r. - ; -'\:-\ ^ < • •-'-•. . v\- : _ _ •,.-. . 

The remainder of this summary is divided according to the topic headings in the 

briefing package. 

• 

Facility-Specific Information 

..wu .-;•.-(':.;. ' •• •.-•>' v:.' ..:-'" .' Ai. 

.•ni.. ^(s strum addressed the facility-specific emissions estimates presented in Appendices' A, B^ and C of Enclosure 1 (p. 1-39 through 1-89) of the September 15,1995 mailout to 

the team/Workgroup. Ms. Strum stated that John Schweitzer, Composites Instimte, was 

H-
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Madeleine Strum 

October 12, 1995 

Page 3 

concerned that mese emissions estimates might be misused. She said that these emissions 

estimates were based on a correction of AP-42 factors and should not be used for 

compliance determinations or in permitting situations. Mr. Spooner, with EPA's pollution 

prevention (P2) division, asked if the emissions estimates were corrected with respect to 

TRI. Ms. Strum said that the values were not "corrected," but are calculated estimates 

based on recent findings that AP-42 significantly underestimates emissions. These findings 

are supported by RTI's recent testing (June 1995). Because of the problems associated wim 

the AP-42 emission factors, it is believed that these calculated estimates will provide a more 

accurate estimate of facility-wide emissions. 

Update on Current Testing 

A draft of the test report for the EPA/ORD testing performed at Reichhold 

Chemicals in June 1995 will be submitted by RTI to ORD on September 29,1995. The 

results are to be presented at the CFA Conference in Anaheim, CA (October 18-21,1995). 

Mr. McNally, Composites Fabricators Association, offered to provide more information on 

the conference to those who call him. 

The Pultrusion Industry Council testing in September 1995 examined pollution 

prevention measures and abatement scenarios for pultrusion operations (resin bath 

enclosures and a new process variation). Their test will also allow the comparison of EPA 

Methods 18 and 25A. The timing of the analysis and release of the results is uncertain 

(John Schweitzer of the Composites Instimte was not present at the meeting to provide 

details). 

The CFA testing at Dow in Freeport, Texas is in Phase I, in which operating 

condition variables are being studied. Emissions from manufacturing processes are being 

momtored using gas chromatographic and continuous hydrocarbon momtors (Method 25A), 

The testing will provide a process segment correlation with emissions, using a videotape 

that will actually include a visual representation of emissions during each phase (i.e., resin 

application, placing of fiber mat, resin rollout) of the process. Testing also includes 

determining what is emitted, and determining where and how (mechanisms) emissions 

occur. Phase II will assess the emission reduction effects of P2 measures. Another goal of 

the program is to create a model that will allow updating of process emission factors. Mr. 

McNally said that, so far, the numbers are correlating with the ORD results; i.e., emission's 

are significantly greater than calculated using the AP-42 emission factors. Preliminary 

results for all processes and a completed analysis for hand layup should be available by the 

middle of October. Ms. Strum encouraged the timely completion of CFA's testing so that 

the analyses could be included in developing the standards. Ms. Strum also stated that 

anyone who has specific test data should submit the results to EPA. Ms. Strum asked Mr. 

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Madeleine Strum 

October 12, 1995 

Page 4 

r

 Nielson, Clark County, NV, if the new LASCO plant has any data. Mr. Nielson noted that 

, f e

 performance testing at the new LASCO (bathware) plant showed that acmal emissions were 

921 tpy using Method 25A, versus 281 tpy calculated using 

AP-42 factors. Mr. McNally added that the CFA testing had not yet produced a specific, 

statistically valid emission factor multiplier that the CFA felt comfortable in recommending 

to its member companies.. 

.&<-

ORD/RTI Report 

Ms. Strum stressed that this report is a preliminary draft but will not be revised 

further by RTI; however, the results displayed in this report are less important than the 

issues it brings out for discussion (e.g., analysis and mechanics of looking at MACT 

floors). She pointed out in Appendix G how the effect of vapor suppressants is different in 

different resins. Ms. Strum also noted that we are seeking a semi-quantitative way of 

evaluating and accounting for the emission reduction techniques in use. 

OA/OC Discussion of Data Summary 

The preliminary draft data summary is being distributed so that team members can 

2 , help identify any errors and assist in the updating of the information. Ms. Strum pointed 

out that this is a "working" preliminary draft and encouraged the team to submit comments 

on the infonnation. 

Determination of Major Sources 

This discussion generally followed the list of topics shown in item 7 of the briefing 

-^package (see Attachment 1). Ms. Strum pointed out that page 3-3 of Enclosure 3 lists the 

major sources that submitted a response to EPA's screening survey. 

Ms. Strum explained that at the present time, ESD wishes to restrict the MACT 

analysis to only major sources, which are defined in terms of "potential to emit" (PTE), and 

not actual emissions. Ms. Strum stated that facilities have the potential to operate 24 hours 

a day, 365 days a year. Therefore, estimated actual emissions had to be extrapolated to 

represent potential emissions before a listing of major sources could be developed. Ms. 

Strum pointed out that if EPA were to use actual emissions, facilities that could potentially 

be covered by the rule may not be included in the MACT floor determination. In addition, 

Ms. Strum noted that few facilities know their actual emissions. Ms. Strum asked the team 

if we should wait for testing results in order to detennine accurate emission factors for 

estimating major.sources. Ms. Strum received no response from the team and continued the 

discussion. She presented the assumptions for major source determination listed under item 

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Madeleine Strum 

October 12, 1995 

Page 5 

# 7 of the briefing package. Ms. Strum stated that we were extremely conservative because 

data are not available for all major sources and it was considered desirable to err on the side 

of overcounting rather than undercounting. This also has the effect of allowing the MACT 

floor to be based on more sources (more than the minimum of 5 specified in the Act). 

Mr. Nielson stated that perhaps the permit limits based on PTE could be used to 

identify major sources. Ms. Strum replied that this permit infonnation is not available to 

EPA. Mr. McNally pointed out that CFA members that have applied as a "synthetic minor" 

source in their permits have done so as a matter of convenience, and it would be inappropriate to eliminate them from the data base. Mr. Balagopalan, SCAQMD, said that his 

District has its own emission factors which are different from the AP-42 factors, and that he 

was collecting the emissions estimates for their facilities and would compare these results 

with the TRI values. Mr. Nielson noted that the comparative LASCO emission results were 

281 tpy (AP-42), 472 tpy (SCAQMD factors), and 921 tpy (Method 25A testing). Mr. 

Brie, Washington State, felt that emission factors should be a site-by-site determination. He 

asked whether only major sources on the basis of acmal emissions could be considered in 

the MACT floor calculations, since cunent non-majors will never become major sources. 

Ms. Strum stated that the assumption that actual emissions were also potential emissions had 

been used in some other rulemaking projects. Ms. Strum said that we would redo the 

analysis of major sources assuming that potential emissions were equal to actual emissions. 

She also stated that actual emissions that were based on AP-42 would continue to be 

corrected using a multiplying factor of 2.3 for open molding processes (i.e., any sprayup, 

hand layup, gel coat, or filament winding source whose actual emissions exceeded 10/2.3 = 

4.3 tpy would be considered major). 

Missing data — 

Ms. Strum stated that the list of potential major sources was generated using 32 SIC 

codes and TRI data for styrene. Mr. Balagopalan asked if other HAP's are emitted. Ms. 

Strum responded that they are, and stated that styrene is the major contributor to emissions. 

Mark Bahner, RTI, referred to page 1-8 of Enclosure 1 that lists HAP's from the industry. 

Ms. Strum asked the team whether to include those sources that appeared major 

based on TRI but for which EPA did not have data (processes, resin use, control measures, 

etc.). The team felt strongly that major sources for which EPA does not have data should 

be included in the MACT analysis. Ms. Strum stated that we would supply the team with a 

list of the major sources for which additional information is necessary (see Attachment 2). 

Mr. Santos requested a list of the items EPA would need in order to include a source in the 

data base, and Ms. Strum indicated that EPA would provide that information (see 

Attachment 3). 

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Madeleine Strum 

October 12, 1995 

Page 6 

Stttaategoriaation ofthe Industry 

Ms. Strum pointed out that subcategorization is necessary due to the very diverse 

range of processes and products in this industry. She also stated that all subcategories 

studied so far have the potential to achieve emission reductions. Issues in attempting to 

subcategorize by process include: some unusual processes or process combinations don't fit 

under the standard process categories; some processes, such as vacuum bag molding, can be 

considered eidier a process or a pollution prevention technique; and, should additional 

subcategories such as conosion resistant products be considered? 

Ms. Strum presented the issues associated with process and product 

subcategorization of the industry (item 8 of the briefing package). 

Mr. McNally pointed out the problems inherent in subcategorizing by product type; 

for example, bathtubs can be made by any of several processes, and available control 

measures may not be applicable to all of these processes. Mr. Bahner stressed that RTI's 

analysis for a tub/shower subcategory (Enclosure 2 in the September 15, 1995 mailout) was 

restricted to products made by the gel coating and sprayup processes. Mr. Balagopalan said 

that SCAQMD's Rule 1162 allows a choice: material (maximum resin monomer percentage 

by resin category) or selection of lower emitting process. He also said that it is easier to 

make standards based on processes. Mr. Balagopalan stated that SCAQMD uses material 

standards for conosion resistant, fire retardant, general purpose, and high strength resins, 

and for pigmented and non-pigmented gel coats. Ms. Strum stated that it might be possible 

to set standards for open molding processes only using these four classifications. She stated 

that we should add the material classifications to the industry checklist (Attachment 3). Ms. 

Strum stated that the checklist is a voluntary survey and that EPA is not requiring any 

facilities to complete and submit the information. Mr. McNally asked if there is any 

limitation on the voluntary survey. Ms. Strum responded "no." Mr. McNally then 

recommended that, in any additional data gathering performed, EPA request infonnation on 

material usage rather than calculated emissions. Ms. Strum agreed that this would be a 

preferable approach. 

Format of the Standards 

Ms. Strum stated that she wanted to address the format of the standards for open 

molding processes since these operations account for at least 75 percent of industry 

emissions. Ms. Strum presented emissions reduction techniques listed on page 3-23 of 

Enclosure 3. She stated diat all of the techniques listed may not qualify as an emissions 

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Madeleine Strum 

October 12,1995 

Page 7 

reduction technique and asked the team what techniques should be retained. No response 

was received and Ms. Strum suggested that the team review me list and provide comments. 

Ms. Strum then asked the team if anyone was aware of a facility that is using fiow 

coating equipment. Mr. McNally said that most resin fiow coating equipment is used in the 

boat manufacturing industry, and it typically is used to apply resin with no fiber chopping 

equipment. He added that the CFA wishes to evaluate all potential techniques in its test 

program. 

The participants then discussed the averaging option for open molding processes 

presented in Enclosure 4 of the September 15,1995 mailout. Ms. Strum stated that the 

averaging option could be used to establish a point system and that compliance would be 

determined by a number. Ms. Strum emphasized that all of the data necessary to use this 

approach were not presently available, but could be acquired by the team working together. 

She stated that an averaging approach provides flexibility to the industry and allows for 

future emission reductions. Mr. McNally added that such an approach would not restrict 

future developments. Ms. Strum then proceeded to describe the terms in the expression 

(which can be referred to as the control status of the facility), and explained that each 

subcategory may have a different value against which to compare the results of the 

calculation. It is not clear whether the "cure factor" would apply to gel coats as well as 

laminating resins, and Mr. McNally offered to check with gel coat suppliers concerning a 

cure factor that would be equitable across the board. Ms. Strum stated that one concern is 

how to compare the data collected here wim those of SCAQMD, whose test method 309 

would be used or would serve as the model for a potentially revised test to determine a cure 

factor. 

Mr. Spooner asked whether the control status would allow weighting for pollution 

prevention measures, and Ms. Strum explained that the factors do account for the use of low 

styrene and suppressed resins, and improved application techniques. She also stated that the 

P2 provisions adopted in the standards should provide an incentive for facilities to switch to 

feedstocks that do not contain styrene and processes with low or no emissions. Mr. 

McNally stated diat resin manufacturers are competing to develop resins that use a non-HAP 

monomer, because of the marketing advantage that such a product would provide. Mr. 

Bahner felt that additional flexibility would be provided to facilities if the facility could use 

an actual emission rate to meet the standard. A facility would have me choice between use 

of the control status approach and another method shown to be equivalent by way of 

emission measurements. The discussion of the use of this equivalency approach ended with 

the question of the baseline (i.e., what is the industry presently doing?) and how it should 

be established. Ms. Strum requested that the team review the averaging options and submit 

comments. 

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Madeleine Strum 

October 12, 1995 

Page 8 

Next Steps 

Ms. Strum stated that we need to reach agreement on the formats for the standards 

and that this issue had not been decided at the meeting. She encouraged the team to send or 

call in comments on the issues discussed at this meeting. She mentioned that she expected 

industry groups, including SMC manufacturing, to provide proposals for specific subcategories of composite fabrication. Mr. McNally discussed the cultured marble subcategory, 

which uses mostly batch mixing (a separate emission point from casting), with some 

continuous mixing (with lower emissions). He said that he would look into the effectiveness 

of vapor suppressants and continuous mixers for this process. 

A brief discussion occurred concerning the AP-42 emission factors for this source 

category. Mr. McNally said that CFA prefers to use other, more accurate factors when 

they are available. Mr. Nielson pointed out that some companies are using the AP-42 

factors in preparing their title V permit applications. Mr. McNally asked whether, in the 

Clark County district, new emissions data could be inserted into the permit if it became 

available during the comment period. Mr. Nielson replied that it could, but a new comment 

period would be necessary. Ms. Strum stated that the emission factors listed in AP-42 will 

be changed. She also pointed out that these factors do not affect the MACT determination. 

There was a general discussion on fillers used in resins. In particular, Ms. Strum 

questioned the group on whether the cure factor in the control status expression should 

address filled resins. Mr. McNally stated that some resins are formulated to accept fillers. 

He also stated that some manufacturers might be able to supply emissions data for filled 

resins. 

Ms. Strum discussed assigning certain tasks to the team to assist in arriving at a rule 

proposal. These tasks included: check die data summary for errors and provide any new 

information available to update die summary; investigate and provide information on 

additional emission reduction techniques; and review and provide reaction to die numerical 

calculation option for open molding processes as presented in Enclosure 4 of the September 

15, 1995 mailout. 

Ms. Strum also requested that members of the team review drafts of the background 

information memoranda and provide suggestions for change or additional material. 

Initially, it was suggested diat the industry representatives, Messrs. McNally and . 

Schweitzer, review at least the industry profile and process description memos (to which 

Mr. McNally assented). Mr. Spooner agreed to review and comment on the memo 

describing pollution prevention/source reduction measures. Ms. Strum encouraged 

additional team members to contact her if they were interested in reviewing any of these 

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Madeleine Strum 

October 12,1995 

Page 9 

memos. 

Ms. Strum also agreed to prepare a checklist or table of information that could be 

used by team members (especially State or local agency personnel) to gather information on 

the facilities within their jurisdictions. This checklist was forwarded to State and local 

agency personnel on October 6,1995 (Attachment 3). 

it 
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ATTACHMENT 1 

»»* BRIEFING PACKAGE FOR Reinforced Plastic Composites NESHAP 

Pre-MACT Meeting 4 »»» 

September 27. 1995 

1. Introductions IsOO 

2. Goals of the Meeting and Agenda Review XllS. 

— to agree upon a method to determine (for the purposes of analysis only) which 

sources in our data base are major and which are not. 

— fully discuss subcategory issues and agree upon subcategorzation for the 

industry 

—to discuss (agree on?) the format of the standard for certain open molding type 

processes. 

— discuss the control options reported to be in use for certain processes and 

associated issues 

— to request support and commitment from the team to "fill-in" areas of missing 

data and to work together to resolve issues with regard to subcategorization/format 

of the standard 

2J Facility-Specific Information li30 

(clarification of emissions estimates) 

—This refers to Enclosure 1 tables which list facility specific emissions 

— It is important to clarify that facility-specific information presented is not an 

"official" correction to specific facilities' calculations and should not be misused by 

permitting authorities nor cause any particular facility any problems. 

4_. Update on Current Testing Xl23. 

— Office of Research and Development Testing (done at the laboratory of 

Reicchold Chemicals) 

— Pultrusion Industry Council testing (done at the laboratory of Reichhold 

Chemicals) 

\Z 
P.M 

— Composite Fabricators Association Testing on open molding processes (in a 

laboratory at Dow in Freeport Texas) 

If anyone knows of any recent plant-specific testing results, please let me know. 

5. Brief Discussion of QRD/RTI Report (Enclosures 1 and 2) 1*50 

— Tool to understand the mechanics of calculating a MACT floor, and the two 

formats presented. 

— Preliminary draft report 

6. OA/OC Discussion of the Dati**, fly^a;^ (Enclosure 3) llSS. 

— A "working" preliminary draft of the industry analyses. 

— Needs QA/QC and updating. (This is a solication for assistance from industry 

and S/L team members). 

-Purpose is to address and hopefully reach an agreement on issues associated 

with subcategorization and format of the standards. 

Z, Determination of Major Sources (p. 3-3 thru 3-19) 2s00 

— Two reasons why there is an issue of how to determine major sources for the 

purpose of analysis and determination of the MACT floor: 1) Potential to Emit 

2) Difficulty in establishing facilities' actual emissions coupled with inaccuracies 

of AP-42 emission factors 

-Assumptions 

— Facilities were determined to be major sources by reviewing the responses to 

the July 1993 ICR and the 1992 TRIS data. 

— Assumed that a facility's potential to emit is two times its actual emissions. 

— Based on recent emission testing, AP-42 underestimates actual emissions from 

open-molding processes by a factor of 2.3. 

Therefore, facilities that conduct open-molding processes (sprayup, hand 

layup, filament winding, and gel coating) were included as a major source if 

their styrene emissions were equal to or greater than 2.17 tpy. (2.17 x 2.3 = 

5 tpy) 

)3 
P.15 

—Facilities that submitted an ICR and would have emitted more than 2.17 tpy and 

5 tpy of styrene (depending on process) without the use of add-on controls were 

also included. 

—Facilities that emitted more than 2.17 tpy or 5 tpy (depending on process) as 

calculated using the resin information reported on the ICR and the midpoint ofthe 

emission factor ranges listed in AP-42 were also included as major sources. 

-If facility process was unknown, it was assumed that if the facility emits more than 

2.17 tpy, it is major 

—Facilities that emitted more than 5 tpy of methylene chloride as determined from 

the ICR were also classified as major sources. 

• Relevance of Missing Data 

—The EPA is required to base the Standards on the 'information available to the 

Administrator" 

— The analysis presented in enclosure 3 indicates that there are 484 major sources 

and that 321 submitted information to the EPA. 

Revisions have been made to the number of sources within the category 

since the enclosure was prepared. These indicate that there are 442 major 

sources. 327 of them submitted a survey. (327/442 = 74 %) 

Recent revisions included the deletion of many facilities as a major source 

because the facilities are not part of the source category, and the addition 

of a few facilities that submitted infonnation. 

A list ofthe (major source) facilities that the EPA does not have information 

on will be included in the meeting minutes. 

fL. Subcategorization of the Industry Zl2£L 

— Enclosure 3 analyzes subcategories based on processes used and products 

manufactured. 

• Issues Associated with the Different Approaches 

—Subcategorization by process would result in a facility implementing a different 

MACT standard for each process used in the facility. 

|4 
P.16 

Relatively easy for facilities to determine the standards that they must comply 

with. 

''^eertain'processes can be considered emission control techniques and not 

processes (i.e. vacuum bag molding - isn't it really a P2 technique for a 

TaMe 2: W^ A HR^hiLni4 JfMS E?&ff?2 W® irt*»tWtof a& m^m- *M»?ees for the 

Should non-process attributes (eg, corrosion resistance) also be used to 

Tab'w 2:

 CWi

£tl f HH^^^nS n (feat !baw Iwm Wca*jfl^ as TOSF-W •:.nare«?<! fe tfv; 

•ffuqwi^c wt' •rk4ft*,*a.u.s\m$ MAC! IkusidMfh -u\d «:itJ -s'-c* w.b»»5.« a ***;,«-««••** so 

— Subcategorization by products was investigated to determine if distinct product 

type groupings with similar emission reduction options could be developed. In 

addition, the EPA wanted to determine if facilities are using low HAP emitting 

processes to produce similar products. , , . 

s.vune the? «• This subcategorization would require that a MACT'standard be established 

fke^y ** pou>breachproduck^bcategory:"5^ '• ^'^- a'

1

-'^ K :»

J

 *'; '; *Y- J" "<•» 

hs'ii'^; «/',iS)'.«iJC'.v sou:..,i*,:-. 7W*1VK pi.*'->w JM vsiablisiviv: N5AC.'li SrawiMvi* -;v;e ±dJ.bd.:l :o Ifte 

N -v-MACr ^The products mahufactuTed by the^industiy were initially segregated info 14 

iistc^ Ao<i\'.:..- categories] About 70 facilities manufacture items that fall into one or more 

ujvc •*- .•'»*»••• O product subcategories:•-<•**•*•* **.*.•:i ii*.' '*... • 

Di,. Subcategorization by product could potentially'require facilities tb change 

.!i:;vr.ir1f£t.;.,ntheir current manufacturing process •' • • >r..d:_:. >..»d .<•••...-. .•.»«»...'.-.» •>..• ..>.•«. M> 

• - SubQategorization by Processes (pv 3-21 and 3-22V' ...\ ,.- ., 

had. i;Kh..'te\; 

- Subcategorization by Products Manufactured (p. 3-36 and 3-37) 

";>••"••'•• •'•'..•i)-..':--*' ^'.birriU',:'; :•'.' VH'.-Ar-' vAVir'1 i c i-.^A •H*,J f*''V'', .••.•.KI.'XT •*^iC' ,^nvt v "».»- bii:*.wi 

. >_.^ tj -• •.•JTT.V,-:*- *«,••'•." r."-".v.".Vi- '** *'•: -.:v> ,-:y !'* :id<:'hk*u. kwnYt&C',•:.•.* S".^^ :>.Ad;d.':.v. ihvi /•"•••*.• 

9'«' Format o f ,the Standards [; ;,,,, rv..,,,,.., y<v ?;>•.«. v«;..•<-/r^wl the 2t4 5 :>?' 

' -Discussio n o f Contro l Options fo r Open Molding Processe s 

U.:: ft-... ( p j j:23 V 3^24. 3r28 . and1 3>30l"*u" " - " u' "" ;: , ^ - " 

,/(oic.vn, ;.u .......•..;»?!-, •.-.-*:-'.-v.*>.. •..,..•< ...,...•«••.•• .>.'*.*; >•:*•* r-v ;:*.•:-.-..n -:^w-^'.'.t*i--i2 vv-v^u. •».!.« 

,:.;."• ••?.*>.•:; -tsf /U'v : •.(-."••t'<•,!!>' • ::<••:..•«.-.,,.:.r., YtjW". ' :•; '•' •".'• cv . ,^, • *.:

 , ;!iWi'. - •:£»«*»w 

sv;.\, T— 'Examine emissions/reduction techniques associated • with' open molding 

,, 1,s-v processesjirst. (E.g. sprayup, hand layup, and gel coating) since these operations 

- i r ; account for at least 75% of industry emissions ... v. >v • ...••> '.' v 

.,;:. — Pages 3-23, 3-24, and 3-28 list emission reduction techniques. What should 

qualify as an emission reduction technique? Should additional subcategories be 

developed? (eg. can't use vapor suppressed resins for corrosion resistant 

n j applications)? .;,,. ., _-. i-.\-t »••>*. .,.••••_ .Ay^-Au^vc-A.: v,,f. ".•. n '. . 

cr-A-.sd-r-K-'.'-..Mi.'A.w,h" -M-....;•• .*.... -i *-:• •:,')• ; ..•--;.'!•• .•:•;.*..''

 }^d\:i: ;.!••• 

- Discussio n of a n Averagin g Pormat Optio n (Enclosure 4) 

I'd 
P.17 

10, Next Steps 3*20 

- Subcategorization and Format of the Standards for 

Sprayupi Hand Layup, and Gel Coating 

- E3tplore Formats for Other Subcategories 

- Receive Industry Developed Subcategory Proposals (e.g.. BMC 

and SMC manufacturing. cultured marble. continuous lamination. 

etc.) 

- Incorporate New Test Information into Analyses 

- Assignments for the Pre-MACT Team and Work Group 

- QA/QC of Data Summary (Enclosure 3) 

- Investigate Additional Emission Reduction Techniques 

- Provide Data to Implement Averaging Format and 

Work Out Details 

- Evaluate HAP Emissions/Reduction Techniques from 

Cleaning Operations 

- Review Background Memoranda 

Emission Reduction Techniques 

Industry Profile 

Processes 

i(j> 
P.18 

UV.v 

Wm 

vm 

w? 

mi' 

WE*. 

vmmf 

OM 

n.i 

mi 

ROC WO 

su-*-

UM'* 

m< 

ACC 

. A5€-

ntr. 

(m.. 

CAW 

cox 

KA'i 

sm*. 

( » • 

<te* 

»«."*' • 

HW-fc* 

i.Ei> 

i.eir. 

imt 

PU* 

*.WA 

RAN 

ST*-
P.19 

ATTACHMENT 2 

ANALYSES OF MAJOR SOURCES FOR MACT DETERMINATION 

Table 1: Table 1 lists all facilities that have been identified as major sources for the 

purpose of determining MACT Standards. 

Table 2: Table 2 lists all facilities that have been identified as major sources for the 

purpose of determining MACT Standards and did not submit a survey to 

EPA. 

•••Notes on Tfrbtelmd 2••• 

In this rulemaking effort, EPA had previously determined that a major source is any 

source that actually emits more than 5 tpy of any one HAP. Using the 5 tpy specification, a 

facility's potential to emit would be 2 times greater than actual emissions or 10 tpy. Tables 

listing the major sources for the purpose of establishing MACT Standards were distributed to the 

Pre-MACT team/Workgroup for the September 27,1995 meeting based on the specifications 

listed above. At the conclusion ofthe September 27,1995 meeting, EPA determined that these 

criteria must be revised and the analysis used to determine major sources should be redone. 

The EPA has revised the specifications for inclusion as a major source for MACT 

determination and prepared the enclosed updated tables. Currently, the EPA has established a 10 

tpy level of emissions for any one HAP as the criterion that defines major sources for MACT 

determination. In addition, facilities that emit more than 25 tpy of combined HAP's have also 

been included. 

Several facilities have been included in Table 1 that have TRI emissions below 10 tpy. 

These facilities submitted an industry survey to EPA and major source determination was based 

on the information reported in the survey. In addition, recent testing has indicated that AP-42 

underestimates emissions from open molding processes. The EPA has incorporated the results of 

the testing into the analysis of major source determination for facilities that reported open 

molding processes; therefore, many facilities that use open molding manufacturing processes and 

currently use AP-42 to estimate the emissions reported to TRI, have been included as major 

sources. In addition, for the purpose of establishing MACT Standards, emissions from facilities 

were calculated by assuming that none ofthe facilities are using any emissions reduction 

techniques. Therefore, States and local agencies should not assume that inclusion of any facility 

in these tables indicates that the facility is a major source for compliance determinations and 

enforcement purposes or that actual emissions from the facility are greater than 10 tpy. 

Table 2 lists facilities that did not submit an industry survey to EPA. All facilities with 

TRI emissions greater than 4.34 tpy have been classified as major sources. This level of 

emissions was established based on recent testing and by assuming that all facilities are using 

open molding processes only. 

II 
Tabl a 1 

MAJOR SOURCES SORTED BY STATE 

FACILITY NAME 

RUBBER & PLASTIC APPLICATORS 

STERLING PLUMBING GROUP INC. 

VMC FIBERGLASS PRODUCTS, INC. /TRW3LAS 

BP CHEMICALS INC. 

SMITH FIBERGLASS PRODS. INC. 

TANKINETICS INC. 

COLEMAN SPAS INC. 

ULTRA INSTALLATIONS INC. 

ACME FIBERGLASS INC. 

ACME REINFORCED PLASTICS INC. 

ADVANCED SPA DESIGNS 

ARMORCAST PRODS. CO. 

ASSOCIATED PLASTICS INC. 

BECKETT ENTERPRISES 

BP CHEMICALS 

BRISTOL FIBERLIGHT INDUSTRIES 

CDR SYSTEMS CORP. 

CLARK MFG. 

CUSTOM FIBREGLASS MFG. CO. 

GENERAL MARBLE CO. 

GLASFORMS INC. 

GOLD SHIELD FIBERGLASS INC. 

HESS CO. IND. INC. 

JACUZZI WHIRLPOOL BATH INC. 

JACUZZI WHIRLPOOL BATH INC. 

JBI INC. 

LASCO BATHWARE 

LEERWEST 

MFG/WEST 

NEWPORT LAMINATES 

OWENS-CORNING 

STOCKLANDCO. 

SUNSET PLASTICS INC. 

XERXES CORP. 

MFG JUSTIN TANKS INC. 

BLUE DOLPHIN FIBERGLASS POOLS 

CDR SYSTEMS CORP. 

CLASSIC MOTOR CARRIAGES 

COMTECH SYSTEMS, INC. 

FLORIDA LINE OF ASTATULA INC. 

FOWLER MFG. INC. 

OWENS CORNING FIBERGLAS CORP. 

SPECIALTY PLASTICS ASSOCIATES. INC. 

TAMPA FIBERGLASS 

XERXES CORP. 

BATHCRAFT INC. 

EUERMFG. 

FIBERGLASS IND. INC. 

CITY 

MOBILE 

HUNTSVILLE 

DALEVILLE 

JONESBORO 

LITTLE ROCK 

HARRISON 

CHANDLER 

MESA 

HAYWARD 

MARYSVILLE 

ANAHEIM 

NORTH HOLLYWOOD 

RIVERSIDE 

COMPTON 

SANTA ANA 

SANTA ANA 

CORCORAN 

CHINO 

LONG BEACH 

GUASTI 

SAN JOSE 

FONTANA 

LAHABRA 

IRVINE 

SANTA ANA 

COMPTON 

ANAHEIM 

WOODLAND 

ADELANTO 

SANTA ANA 

BAKERSFIELD 

IRVINE 

ANDERSON 

ANAHEIM 

GEORGETOWN 

LARGO 

PALATKA 

MIAMI 

SAINT CLOUD 

ASTATULA 

ATLANTIC BEACH 

AUBURNDALE 

LAKELAND 

TAMPA 

LAKELAND 

VALDOSTA 

VALDOSTA 

FORT VALLEY 

ST 

AL 

AL 

AL 

AR 

AR 

AR 

AZ 

AZ 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

DE 

FL 

FL 

FL 

FL 

FL 

FL 

FL 

FL 

FL 

FL 

GA 

GA 

GA 

REPORTED 

1992 TRI 

FACILITY 

TOTAL AIR 

RELEASES 

(TONS) 

4.2 

41.0 

7.2 

5.2 

4.5 

18.2 

6.0 

10.5 

3.2 

19.1 

2.8 

11.3 

6.8 

13.0 

8.6 

15.5 

31.0 

21.3 

3.0 

49.5 

39.9 

20.7 

7.0 

6.2 

183.5 

25.9 

1.1 

8.4 

5.4 

7.9 

6.9 

85.6 

11.8 

20.6 

12.3 

21.8 

7.2 

7.1 

14.5 

10.0 

26.2 

49.4 

8.4 

4.5 

'8 
P.21 

INTERNATIONAL MARBLE INC. 

LASCO BATHWARE 

MR. TUBS INC. 

UNIVERSAL-RUNDLE CORP. 

CEDAR MFG. 

FIBRE BODY INDUSTRIES, INC. 

NORTHWEST BODIES INC. 

UNIVERSAL-RUNDLE CORP. 

XERXES CORP. 

DYNAMIC FABRICATORS 

FIBERGLASS SYSTEMS 

APPUED COMPOSITES. CORP. 

BP CHEMICALS INC. 

FIBERBASIN INC. 

H&RIND. INC. 

KEMLITECO. 

L & M CAST STONE PRODS. 

MARBLE WORKS 

MARBLECAST PRODUCTS INC. 

NATIONAL FIBER GLASS PRODUCTS 

OASIS INDUSTRIES, INC. 

R. D.WERNER CO. INC. 

RESINOID ENGINEERING CORP. 

ROCKWELL INTERNATIONAL* 

ROXITE FIBERGLASS 

SPAULDING COMPOSITES CO. (SPECIALTY PLASTICS DIV.] 

SUPERIOR HOME PRODS. INC. 

UNIQUE MARBLE PRODS. INC. 

20TH CENTURY FIBERGLASS INC. 

ACCURATE GLASS INC. 

AKER PLASTICS CO. INC. 

ARROWHEAD PLASTIC ENG. INC. 

BETTER WAY PRODUCTS INC. 

BREMEN GLAS INC. 

C&KPLASTICSINC. 

CAMEO MARBLE 

COVERMASTER INC. 

EAGLE CRAFT INC. 

EAGLE-PICHER IND. INC. 

EAGLE-PICHER IND. INC. 

EAGLE-PICHER INDUSTRIES INC. 

FIBER-TRON CORP. 

GENCORP AUTOMOTIVE INC. 

GENCORP AUTOMOTIVE INC. 

GLOBAL GLASS INC. 

GOLD SHIELD FIBERGLASS INC. 

GOLD SHIELD FIBERGLASS INC. 

GREAT DANE TRAILERS INC. 

HOLIDAY RAMBLER CORP. 

INDUSTRIAL DIELECTRICS INC. 

INTERPLASTICCORP. 

KREIDERMFG.INC. 

LEER INC. 

LEER MIDWEST 

MASTER FAB INC. 

MILLENNIUM PRODUCTS INC. 

OWENS-CORNING FIBERGLAS 

PLASTIC COMPOSITES CORP. 

QUALITY COMPONENTS INC. 

RANCH FIBERGLAS INC. 

STANDARD GLAS, INC. 

WOODSTOCK 

CORDELE 

SUGAR HILL 

UNION POINT 

CEDAR RAPIDS 

SWEACITY 

MANSON 

OTTUMWA 

TIPTON 

RATHDRUM 

BOISE 

SAINT CHARLES 

SAINT CHARLES 

CHICAGO 

BEECHER 

JOLIET 

CHICAGO 

SOUTH ELGIN 

WHEELING 

ROMEOVILLE 

BATAVIA 

FRANKLIN PARK 

SKOKIE 

CENTRALIA 

ROCK FALLS 

DEKALB 

MARYVILLE 

EFFINGHAM 

ELKHART 

TERRE HAUTE 

PLYMOUTH 

MUNCIE 

NEW PARIS 

BREMEN 

MILLERSBURG 

NEW ALBANY 

ELKHART 

PLYMOUTH 

HUNTINGTON 

ASHLEY 

GRABILL 

ELKHART 

MARION 

SHELBYVILLE 

ELKHART 

DECATUR 

DECATUR 

BRAZIL 

WAKARUSA 

NOBLESVILLE 

SOUTH BEND 

LIGONIER 

ELKHART 

ELKHART 

GOSHEN 

ELKHART 

VALPARAISO 

FORT WAYNE 

ELKHART 

ELKHART 

FIREMEN 

GA 

GA 

GA 

GA 

IA 

IA 

IA 

IA 

IA 

ID 

ID 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

2.5 

170.7 

6.3 

94.2 

15.3 

9.4 

121.4 

36.4 

15.1 

59.2 

5.6 

7.3 

33.9 

4.7 

22.8 

4.4 

35.5 

32.4 

4.7 

8.5 

4.5 

32.4 

10.8 

109.2 

7.5 

7.5 

57.8 

10.2 

11.0 

79.5 

6.2 

4.1 

3.4 

7.1 

15.3 

40.7 

44.0 

12.3 

12.9 

64.0 

0.0 

18.7 

0.7 

5.0 

20.0 

3.6 

66.5 

27.0 

57.7 

18.5 

4.0 

7.0 

10.7 

n 
STARCRAFT AUTOMOTIVE CORP. 

SUPREME CORP. 

ULTRA/GLAS OF LAKEVILLE INC. 

VEE ENG. INC. 

VIKING FORMED PRODS. 

BOEING WICHITA 

CHARLOMA FIBERGLASS INC. 

DIAMOND COACH CORP. 

FIBERGLASS FORMS INC. 

KBKIND. INC. 

LITE MFG. 

MARLEY COOLING TOWER CO. 

PALMER MFG. & TANK INC. 

RIGID FORM INC. 

SMITH FIBERGLASS PRODS. INC. 

DOM-FAB, INC. 

EBONITE INTL. INC. 

FOSROC INC. 

SYNTECHNICS INC. 

TOMKINS IND. INC. 

GMC (INLAND FISHER GUIDE DIV.) 

INDUSTRIAL PIPE & PLASTICS 

RESIN SYS. INC. 

INTERNATIONAL PAPER 

XERXES CORP. 

FIBERGLASS PRODS. INC. 

BELDING TANK TECHNOLOGY (F.KA D & R FABRICATION) 

CONWAY PRODUCTS CORP. 

DGPINC. 

E-T-M ENTS. INC. 

FALLS FIBERGLAS PRODS. INC. 

GENCORP AUTOMOTIVE INC. 

GREAT LAKES PLASTICS CORP. 

HASTINGS GROUP INC. 

HASTINGS REINFORCED PLASTICS 

LASCO BATHWARE 

MOLDED PLASTIC IND. INC. 

CARSTENS IND. INC. 

ECOWATER SYSTEMS 

GLASSTITE INC. 

LUND IND. 

MMFG 

NORDIC FIBERGLASS INC. 

PEARL BATHS INC. 

PRECISION FIBERGLASS INC. 

UNIVERSAL PLASTICS INC. 

AERO TRANSPORTATION PRODS. 

ED IND. INC. 

G. W. FIBERGLASS INC. 

MIRACLE RECREATION CO. 

SEQUENTIAINC. 

LAVALLEY CONSTRUCTION CO. 

BAJA PRODUCTS LTD. 

CAIRN STUDIO LTD. 

CAROLINA COUNTERS 

CONCEPT PLASTICS INC. 

EUER PLUMBINGWARE 

ERSHIGS INC. 

GENERAL MARBLE CO. 

MURPHY BODY CO. 

OMC SPRUCE PINE 

GOSHEN 

GOSHEN 

LAKEVILLE 

FORT WAYNE 

MIDDLEBURY 

WICHITA 

CHERRYVALE 

OSWEGO 

INDEPENDENCE 

RUSH CENTER 

BONNER SPRINGS 

OLATHE 

GARDEN CITY 

PAOLA 

WICHITA 

ERLANGER 

HOPKINSVILLE 

GEORGETOWN 

PADUCAH 

FLORENCE 

MONROE 

LAKE CHARLES 

SULPHUR 

ODENTON 

WILLIAMSPORT 

AUBURN 

GREENVILLE 

HOLLAND 

MARLETTE 

GRAND LEDGE 

ALGONAC 

IONIA 

HANCOCK 

BELDING 

HASTINGS 

THREE RIVERS 

HOLT 

MELROSE 

WOODURY 

DUNNELL 

MINNEAPOLIS 

CHATFIELD 

WARREN 

BROOKLYN PARK 

GROVE CITY 

MAPLE GROVE 

INDEPENDENCE 

ROGERSVILLE 

O'FALLON 

MONETT 

GRANDVIEW 

BILOXI 

SALISBURY 

MOORESVILLE 

LOCUST 

HIGH POINT 

WILSON 

WILSON 

LINCOLNTON 

WILSON 

SPRUCE PINE 

IN 

IN 

IN 

IN 

IN 

KS 

KS 

KS 

KS 

KS 

KS 

KS 

KS 

KS 

KS 

KY 

KY 

KY 

KY 

KY 

LA 

LA 

LA 

MD 

MD 

ME 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

MN 

MN 

MN 

MN 

MN 

MN 

MN 

MN 

MN 

MO 

MO 

MO 

MO 

MO 

MS 

NC 

NC 

NC 

NC 

NC 

NC 

NC 

NC 

NC 

P22 

'"> "* 

5.0 

35.6 

14.0 

5.0 

47.0 

17.5 

19.6 

16.6 

64.0 

8.9 

200.9 

129.3 

77.2 

18.0 

4.9 

20.1 

5.3 

50.0 

76.1 

0.8 

4.6 

6.8 

46.5 

6.4 

15.0 

7.7 

9.6 

17.1 

50.9 

27.0 

17.0 

6.0 

247.3 

13.9 

5.6 

17.5 

33.7 

17.5 

8.9 

16.1 

10.5 

1.3 

23.1 

12.1 

180.5 

11.0 

18.9 

9.8 

4.4 

35.0 

2.6 

10.1 

14.6 

11.0 

10.5 

23.6 
PIEDMONT FIBERGLASS 

PRODELINCORP. 

TIFFANY MARBLE & GLASS CO. 

NORDIC FIBERGLASS INC. 

A-1 FIBERGLASS INC. 

CENTURY MFG. CO. 

GRAYSON TOOL CO. 

SQUARE D COMPANY (LINCOLN) 

KALWALLCORP. 

CARSONITE INTL CORP. 

ALLIED SIGNAL LAMINATE SYSTEMS 

AN-CORINDL PLASTICS INC. 

EMSIG MFG. CORP. 

GENERAL MARBLE CO. 

GMC 

METAL CLADDING INC. 

MOHAWK METAL PRODUCTS INC. 

A. R. E. INC. 

A R. E., INC., (MASSILLON) 

ALLIED MOULDED PRODS. INC. 

AMERICAN CUSTOM IND. INC. 

AMERICAN CYANIMID 

BAILEY TRANSPORTATION PRODUCTS 

BUDD CO. 

BUDD CO. 

BUDD CO. 

CAMOPLAST ACCUFAB INC. 

CINCINNATI FIBERGLASS INC. 

COR TEC CO. 

FINDLAY IND. INC. 

FINDLAY IND. INC. 

GLASGO PLASTICS INC. 

GLASTICCORP. 

GOODYEAR TIRE & RUBBER CO. 

HADLOCK PLASTICS CORP. 

ITEN IND. 

MAR-BAL INC. 

MOLDED FIBER GLASS CO. 

MONARCH PLASTIC INC. 

NAVISTAR INTL TRANSPORTATION 

NEWARTESIAN LIMITED PARTNERSHIP (MARBLE PLANT) 

OMEGA PULTRUSIONS INC. 

PICKEN'S PLASTICS INC. 

PLAS-TANKS IND. INC. 

PREMIX INC. 

PREMIX/E.M.S. INC. 

SCHMITT MARBLE PRODS. INC. 

STRUCTURAL N A 

STYLE CREST PRODS. 

U.S. FIBERGLASS PRODS. INC. 

XERXES CORP. 

XERXES CORP. 

BEETLE PLASTICS INC. 

FIBER PAD. INC. 

FIBERCAST CO. 

UNIT PARTS CO. 

AMERICAN SPA MFG. CO. 

BEAVER COACHES INC. 

COUNTRY COACH INC. 

FIBER-FAB INC. 

KEARNEY/WESTERN POWER PRODS. 

MOORESVILLE 

CONOVER 

RANDLEMAN 

DEVILS LAKE 

HASTINGS 

AURORA 

MINDEN 

LINCOLN 

BOW 

CARSON CITY 

HOOSICK FALLS 

NORTH TONAWANDA 

HUDSON 

HORNELL 

MASSENA 

NORTH TONAWANDA 

FRANKFORT 

MOUNTEATON 

MASSILLON 

BRYAN 

SYLVANIA 

PERRYSBURG 

CONNEAUT 

VAN WERT 

CAREY 

NORTH BALTIMORE 

CHILLICOTHE 

BATAVIA 

WASHINGTON COURT 

FINDLAY 

FINDLAY 

SPRINGFIELD 

SOUTH EUCUD 

JACKSON 

GENEVA 

ASHTABULA 

CHAGRIN FALLS 

ASHTABULA 

ORRVILLE 

COLUMBUS 

MANSFIELD 

AURORA 

ASHTABULA 

FAIRFIELD 

NORTH KINGSVILLE 

LANCASTER 

LOVELAND 

CHARDON 

FREMONT 

MIDDLEBRANCH 

AVON 

NORTH RIDGEVILLE 

ARDMORE 

TULSA 

SAND SPRINGS 

OKLAHOMA CITY 

WOODBURN 

BEND 

JUNCTION CITY 

GERVAIS 

HOOD RIVER 

NC 

NC 

NC 

ND 

NE 

NE 

NE 

NE 

NH 

NV 

NY 

NY 

NY 

NY 

NY 

NY 

NY 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OK 

OK 

OK 

OK 

OR 

OR 

OR 

OR 

OR 

7.4 

7.6 

46.1 

11.1 

23.7 

20.5 

1.6 

18.3 

4.5 

6.7 

7.6 

15.3 

8.2 

8.3 

7.9 

55.6 

7.2 

13.9 

9.5 

34.0 

25.3 

36.2 

15.2 

15.5 

119.5 

12.6 

4.7 

5.1 

27.4 

35.2 

8.5 

2.6 

12.5 

4.6 

4.7 

7.5 

32.4 

13.9 

7.0 

14.5 

10.4 

3.7 

3.1 

37.0 

5.6 

24.0 

16.5 

7.5 

33.0 

9.9 

7.5 

9.1 

7.2 

7.3 

11.2 

2\ 
MARQUIS CORP. 

MCCLURE IND. INC. 

PLASTI-FAB 

S. R. SMITH INC. 

CREATIVE PULTRUSIONS INC. 

HAYSITE REINFORCED PLASTICS 

JONES & HUNT INC. 

LASCO BATHWARE 

LEER INC. 

MCCLARIN PLASTICS INC. 

MOLDED FIBER GLASS TRAY CO. 

OWENS CORNING FIBERGLAS CORP. 

PLASTIC DEVELOPMENT CO. 

RESOUTE 

RYNONE MFG. CORP. 

UNITED PANEL INC. 

UNIVERSAL-RUNDLE CORP. 

WARMINSTER FIBERGLASS CO. 

PARTHENON MARBLE PRODUCTS, INC. 

SHAKESPEARE CO. 

RAVEN IND. INC. 

SIMON-TELELECTINC. 

ADVANCE TRANSFORMER CO. 

AQUA GLASS CORP. 

CHEMGRATE CORP. 

COLUMBIA SPECIALTIES INC. 

CONTINENTAL CAMPER CO. INC. 

ELECTRIC-GLASS INC. 

IKG IND. 

IMAGES PRODUCTS CORP 

NEWARTESIAN MANAGEMENT CO. 

QUAZITE 

SEQUENTIA INC. 

ACCENT MARBLE CO. INC. 

AMERON, INC., (BURKBURNETT) 

AUSTIN COUNTERTOPS INC. 

BELCOMFG.CO.INC. 

CERAMIC COOLING TOWER CO. 

CLARKE PRODUCTS INC. 

COMPOSITE TECHNOLOGY (W.R. GRACE & CO.) 

CRAIG BAKER MARBLE CO. INC. 

DIAMOND FIBERGLASS 

ENDURO FIBERGLASS SYS. INC. 

FIBERFLEX INC. 

FIBERGLASS SPECIALTIES INC, 

FIBERGRATECORP. 

HARWOOD IND. INC. 

INDUSTRIAL MODELS INC. 

KOHLERCO. 

LEE-VAR INC. 

OWENS-CORNING 

PERMIAN FIBERGLASS 

PRESTIGIOUS ACCESSORIES INC. 

RED EWALD INC. 

S. W. C. INDUSTRIES, INC. (SWIRL-WAY DIV.) 

TOMKINS IND. INC. 

VADCO MARBLE INC. 

W. R. GRACE - COMPOSITE TECHNOLOGY 

WARMINSTER FIBERGLASS CO. 

XERXES CORP. 

DELTA FIBERGLASS STRUCTURES 

INDEPENDENCE 

PORTLAND 

TUALATIN 

CANBY 

ALUM BANK 

ERIE 

ORW1GSBURG 

ELIZABETHTOWN 

MILTON 

HANOVER 

UNESVILLE 

MOUNT UNION 

WILLIAMSPORT 

ZEUENOPLE 

SAYRE 

MOUNT BETHEL 

NEWCASTLE 

SOUTHAMPTON 

GREENVILLE 

NEWBERRY 

SIOUX FALLS 

WATERTOWN 

WARTBURG 

ADAMSVILLE 

PINEY FLATS 

COLUMBIA 

LAFOLLETTE 

JACKSON 

NASHVILLE 

ERWIN 

COVINGTON 

LENOIR CITY 

GRAND JUNCTION 

HOUSTON 

BURKBURNETT 

AUSTIN 

BELTON 

FORT WORTH 

GRAND PRAIRIE 

FORT WORTH 

BARKER 

VICTORIA 

HOUSTON 

BIG SPRING 

HENDERSON 

STEPHENVILLE 

TYLER 

GAINESVILLE 

BROWNWOOD 

ANDREWS 

CONROE 

MIDLAND 

TYLER 

KARNES CITY 

HENDERSON 

LANCASTER 

HOUSTON 

FORT WORTH 

JACKSONVILLE 

SEGUIN 

SALT LAKE CITY 

OR 

OR 

OR 

OR 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

PA 

SC 

SC 

SD 

SD 

TN 

TN 

TN 

TN 

TN 

TN 

TN 

TN 

TN 

TN 

TN 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

UT 

5.5 

7.1 

11.0 

26.0 

4.5 

4.7 

34.3 

32.5 

6.9 

6.0 

34.7 

7.8 

6.4 

1.2 

73.4 

5.6 

19.9 

19.0 

3.0 

48.0 

.113.4 

8.2 

2.0 

12.7 

2.1 

7.8 

8.0 

..* 16.1 

39.2 

6.6 

4.5 

7.0 

4.9 

4.8 

1.0 

4.8 

12.6 

10.3 

11.9 

14.4 

30.3 

5.1 

7.4 

32.6 

135.3 

19.6 

22.0 

12.9 

14.5 

17.0 

52.4 

8.8 

4.0 

43.0 

15.9 

£2 
FABALL ENTS. OF UTAH INC. 

HERCULES (BACCHUS WORKS • PLANT 2) 

APPALACHIAN PLASTICS INC. 

FIBERGLASS ENG. CORP. 

TOMKINS IND. INC. 

AMERICAN REINFORCED PLASTICS 

AMTECH CORP. 

ATTBAR PLASTICS INC. 

CHEMGRATE CORP. 

DISCOVERY SPAS 

ERSHIGS INC. 

FIBERGLASS TECH. IND. 

FIBREX CORP. 

HYDRO SWIRL MFG. CORP. 

HYTEC INC. (LASCO BATHWARE) 

LIVINGSTON INC. 

MELCHER MFG. CO. INC. 

ASHLEY FURNITURE IND. INC. 

BRADY USA INC. 

CONTEMPORARY PRODUCTS INC. 

CORROSION TECHNOLOGY INC. 

FIBERDOME INC. 

GPI CORP. 

JOHNSON TRUCK BODIES 

KRUEGER INTERNATIONAL INC. 

LIPPERTCORP. 

MENASHACORP. 

TELCO INC. OF MANAWA 

W. H. BRADY CO. (MILWAUKEE) 

AKER PLASTICS CO. INC. 

CLEARFIELD 

CLEARFIELD 

GLADE SPRING 

MIDLAND 

SOUTH BOSTON 

TACOMA 

YELM 

VANCOUVER 

WOODINVILLE 

VANCOUVER 

BELLINGHAM 

SPOKANE 

BURUNGTON 

BELLINGHAM 

YELM 

AUBURN 

SPOKANE 

WHITEHALL 

MILWAUKEE 

MENOMONEE FALLS 

HOWARD 

LAKE MILLS 

SCHOFIELD 

RICE LAKE 

GREEN BAY 

MENOMONEE FALLS 

WATERTOWN 

MANAWA 

MILWAUKEE 

MARTINSBURG 

UT 

UT 

VA 

VA 

VA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

WA 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

Wl 

WV 

0.4 

5.1 

0.0 

91.0 

14.8 

2.8 

15.6 

4.5 

7.2 

9.3 

12.3 

4.2 

7.7 

204.4 

19.1 

4.7 

12.4 

63.5 

6.2 

5.9 

7.7 

8.0 

17.3 

0.3 

22.7 

7.1 

103.4 

&3 
Table 2 

These facilities submitted an incomplete survey or did not submit a survey 

SORTED BY STATE (facility with TRI emissions >4.34 or TRI emissions » 01 

FACILITY NAME CITY 

TANKINETICS INC. HARRISON 

COLEMAN SPAS INC. CHANDLER 

ULTRA INSTALLATIONS INC. MESA 

ADVANCED SPA DESIGNS ANAHEIM 

BECKETT ENTERPRISES COMPTON 

JACUZZI WHIRLPOOL BATH INC. SANTA ANA 

JACUZZI WHIRLPOOL BATH INC. IRVINE 

JBIINC. COMPTON 

LEER WEST WOODLAND 

OWENS-CORNING BAKERSFIELD 

SILVESTRI STUDIO INC. LOS ANGELES 

STOCKLAND CO. IRVINE 

OWENS CORNING FIBERGLAS CORP. AUBURNDALE 

TAMPA FIBERGLASS TAMPA 

DYNAMIC FABRICATORS RATHDRUM 

BP CHEMICALS INC. SAINT CHARLES 

FIBERBASIN INC. CHICAGO 

L & M CAST STONE PRODS. CHICAGO 

MARBLE WORKS SOUTH ELGIN 

MARBLECAST PRODUCTS INC. WHEEUNG 

ROXITE FIBERGLASS ROCK FAUS 

UNIQUE MARBLE PRODS. INC. EFFINGHAM 

BETTER WAY PRODUCTS INC. NEW PARIS 

FIBER-TRONCORP. ELKHART 

FOREMAN IND. INC. WARSAW 

GENCORP AUTOMOTIVE INC. SHELBYVILLE 

INTERPLASTICCORP. SOUTH BEND 

MASTER FAB INC. GOSHEN 

QUALITY COMPONENTS INC. ELKHART 

STARCRAFT AUTOMOTIVE CORP. GOSHEN 

SUBARU-ISUZU AUTOMOTIVE INC. LAFAYETTE 

SUPREME CORP. GOSHEN 

VEE ENG. INC. FORT WAYNE 

VIKING FORMED PRODS. MIDDLEBURY 

LITE MFG. BONNER SPRINGS 

PALMER MFG. & TANK INC. GARDEN CITY 

RIGID FORM INC. PAOLA 

FOSROC INC. GEORGETOWN 

INDUSTRIAL PIPE & PLASTICS LAKE CHARLES 

RESIN SYS. INC. SULPHUR 

BRUNSWICK CORP. MUSKEGON 

CONWAY PRODUCTS CORP. HOLLAND 

DGP INC. MARLETTE 

E-T-M ENTS. INC. GRAND LEDGE 

FALLS FIBERGLAS PRODS. INC. ALGONAC 

KB LIGHTING INC. KENTWOOD 

KEELER BRASS AUTOMOTIVE KENTWOOD 

CARSTENS IND; INC. MELROSE 

MMFG CHATFIELD 

PRECISION FIBERGLASS INC. GROVE CITY 

CAIRN STUDIO LTD. MOORESVILLE 

OMC SPRUCE PINE SPRUCE PINE 

TIFFANY MARBLE & GLASS CO. RANDLEMAN 

GMC MASSENA 

METAL CLADDING INC. NORTH 

MOHAWK METAL PRODUCTS INC. FRANKFORT 

•24-

ST 

AR 

AZ 

AZ 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

CA 

FL 

FL 

ID 

IL 

IL 

IL 

IL 

IL 

IL 

IL 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

IN 

KS 

KS 

KS 

KY 

LA 

LA 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

Ml 

MN 

MN 

MN 

NC 

NC 

NC 

NY 

NY 

NY 

REPORTED 

1992 TRI 

FACIUTY 

TOTAL AIR 

RELEASES 

(TONS) 

4.5 

18.2 

6.0 

19.1 

6.8 

7.0 

20.7 

6.2 

25.9 

5.4 

0.0 

7.9 

14.5 

10.0 

15.1 

59.2 

5.6 

4.7 

22.8 

4.4 

4.7 

4.5 

7.5 

15.3 

0.0 

44.0 

5.0 

27.0 

7.0 

5.0 

0.0 

35.6 

5.0 

47.0 

200.9 

77.2 

18.0 

5.3 

4.6 

6.8 

0.0 

15.0 

7.7 

9.6 

17.1 

0.0 

0.0 

5.6 

17.5 

10.5 

35.0 

23.6 

46.1 i 

8.2 

8.3 

7.9 
P.27 

AMERICAN CUSTOM IND. INC. 

CAMOPLASTACCUFAB INC. 

CINCINNATI FIBERGLASS INC. 

FINDLAY IND. INC. 

FINDLAY IND. INC. 

GLASTICCORP. 

GREENVILLE TECH. INC. 

HADLOCK PLASTICS CORP. 

MAR-BAL INC. 

PLAS-TANKS IND. INC. 

PREMIX INC. 

PREMIX/E.M.S. INC. 

XERXES CORP. 

UNIT PARTS CO. 

AMERICAN SPA MFG. CO. 

FIBER-FAB INC. 

COLONIAL FIBERGLASS IND. INC. 

MCCLARIN PLASTICS INC. 

AUGUSTA FIBERGUSS COATINGS 

ADVANCE TRANSFORMER CO. 

CHEMGRATE CORP. 

QUAZITE 

BELCOMFG.CO.INC. 

CLARKE PRODUCTS INC. 

CRAIG BAKER MARBLE CO. INC. 

HARWOOD IND. INC. 

INDUSTRIAL MODELS INC. 

LEE-VAR INC. 

OWENS-CORNING 

PERMIAN FIBERGLASS 

VADCO MARBLE INC. 

FENCO INC. 

CHEMGRATE CORP. 

DISCOVERY SPAS 

FIBERGLASS TECH. IND. 

HYDRO SWIRL MFG. CORP. 

ASHLEY FURNITURE IND. INC. 

CORROSION TECHNOLOGY INC. 

GENERAL FIBERGLASS SUPPLY 

MASTERMOLD INC. 

TELCO INC. OF MANAWA 

SYLVANIA 

CHILLICOTHE 

BATAVIA 

FINDLAY 

FINDLAY 

JEFFERSON 

GREENVILLE 

GENEVA 

CHAGRIN FALLS 

FAIRFIELD 

NORTH KINGSVILLE 

LANCASTER 

NORTHRIDGEVILLE 

OKLAHOMA CITY 

WOODBURN 

GERVAIS 

HANOVER 

HANOVER 

BLACKVILLE 

WARTBURG 

PINEY FLATS 

LENOIR CITY 

BELTON 

GRAND PRAIRIE 

BARKER 

TYLER 

GAINESVILLE 

ANDREWS 

CONROE 

MIDLAND 

HOUSTON 

STAUNTON 

WOODINVILLE 

VANCOUVER 

SPOKANE 

BELLINGHAM 

WHITEHALL 

HOWARD 

WAUKESHA 

JOHNSON CREEK 

MANAWA 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OH 

OK 

OR 

OR 

PA 

PA 

SC 

TN 

TN 

TN 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

TX 

VA 

WA 

WA 

WA 

WA 

Wl 

Wl 

Wl 

Wl 

Wl 

13.9 

15.2 

15.5 

4.7 

12.6 

12.0 

0.0 

8.5 

12.5 

7.0 

14.5 

10.4 

16.5 

9.9 

7.5 

7.3 

0.0 

6.9 

0.0 

48.0 

8.2 

16.1 

7.0 

4.8 

4.8 

5.1 

7.4 

135.3 

19.6 

22.0 

8.8 

0.0 

4.5 

7.2 

12.3 

7.7 

12.4 

5.9 

0.0 

0.0 

7.1 

2*S~ 
P.28 

ATTACHMENT 3 

Instructions: Fill out a separate sheet for each process or resin/material. Do not report painting. 

Facility name: 

Address and phone: 

Contact: 

Reporting year: 

Manufacturing process: Sprayup Hand Layup 

Pultrusion Continuous Lamination Compression Molding 

Mfr. of SMC Compound .Mfr. of BMC Compound Other (explain) 

Filament Winding Cultured Marble Casting 

Centrifugal Casting Resin Transfer Molding 

Application Techniques (if applicable): 

Pressure fed rollers Airless 

Other (explain) 

Brushes Flow coaters 

Air-assist Airless/HVLP 

Material/Resin type: 

Unsaturated Polyester 

Vinylester 

Epoxy 

Qty. Used (tons per year): 

Bulk Molding Compound Sheet Molding Compound 

Gel Coat (clear) Gel Coat (pigmented) 

Other (explain) 

HAP #1 in material/resin: Weight % as supplied: 

HAP #2 in material/resin: Weight % as supplied: 

HAP #3 in material/resin: Weight % as supplied: 

Is HAP added to material/resin: (y or n) HAP:_ Qty added (tons per year): 

Is filler added to material/resin: ( y or n ) Qty added (tons per year): 

Is the material/resin vapor suppressed? (y or n) 

Emissions from process (tons per year):_ 

Basis: AP-42 testing 

Test results of static emission test? (y or n ) 

g/m2 as applied g/m2 as supplied 

Products Manufactured: Product classification: 

Corrosion Resistant High Strength 

Fire Retardent General Purpose 

Do you use any emission reduction or pollution prevention techniques or add-on controls during Ifae 

manufacturing process (e.g., vacuum bagging, low monomer resin formulations, carbon filter 

system, etc.)? ( y or n) 

List types: 

Are any HAPs contained in formulations used for cleaning operations? ( y or n ) 

( Note: Report this information once for each facility) Qty. of cleaner (tons per year): 

HAP: HAP weight %: 

% 
P.29 

Enclosure 2 

CORE ISSUES 

The pre-MACT team has decided to begin developing standards for 

the industry by using manufacturing process subcategories. For 

sprayup, hand layup, and gel coating processes, the team is 

considering adopting an averaging scheme to determine compliance. 

This approach could potentially be adopted for other processes. 

Issues that reguire your input are listed below. Please include a 

rationale for each response that you provide. 

Issue #1; Should fabrication of corrosion resistant products be 

considered a separate industry subcategory? If yes, 

please provide suggestions for the format of the 

standards. 

Issue #2; Should vacuum bag molding be considered a pollution 

prevention (P2) technique for hand layup and sprayup 

processes, or should it be considered to be a distinct 

subcategory? 

Issue #3: Do you believe that the averaging format (control 

status expression) presented at the meeting is 

workable? If so, can you provide details on possible 

refinements to this approach? 

- Issue #4: Should solid fillers added to resins be considered a 

P2 technique (for lowering the net monomer content) 

and, therefore, receive credit in the averaging scheme 

(and serve to make the floor more stringent)? If not, 

could you provide suggestions for the format of the 

standards for filled resins and whether a separate 

subcategory should be established? 

Issue #5: Do you have additional information on facilities that 

have recently conducted emissions tests? 

Issue #6: How should the industry baseline be determined? That 

is, how should we use our data on the use of emission 

reduction measures to develop a baseline (e.g., mean, 

use of all the data, worst case, etc.)? 

2d*