p.1 

OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

13) IV-E-13 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:26 AM Sheet 13 of 130 
P.2 

WJ-IZ-I3 

MEMORANDUM 

TO: Docket for Reinforced Plastic Composites NESHAP 

FROM: Keith Barnett, U.S. Environmental Protection Agency 

DATE: December 17, 2002 

SUBJECT: Minutes of November 4, 2002 Meeting Between EPA and the American 

Composite Manufacturers Association (ACMA, formerly the Composites 

Manufacturers Association.) 

LOCATION: Room 5400, Ariel Rios North, Washington D.C. 

ATTENDEES: 

U. S. Environmental Protection Agency 

Jeff Holmstead, 

William Wehrum, 

Keith Mason 

Keith Barnett 

Anupama Rajaraman 

ACMA 

John Schweitzer 

Chuck Elkins 

John Barker 

Perry Bennett 

Lowell Miles 

William Pedersen 

PURPOSE: 

Assistant Administrator (AA) for Air and Radiation 

Counsel to the AA 

Office of Policy, Economics, and Innovation 

Emissions Standards Division 

Assistant to the AA 

r 

ACMA 

Chuck Elkins & Associates 

Strongwell 

MFG 

Miles Fiberglass 

Shaw Pittman L.L.P 

IPA AIM DCJKfc. 

The purpose ofthe meeting was for the American Composite Manufacturers Association 

(ACMA) to present to Jeff Holmstead information relating to the proposed national emission 

standard for the Reinforced Plastic Composites source category. Specifically, they were 

concerned about the proposed capture and control requirements for new sources manufacturing 

large parts. A copy of their presentation which covers what was discussed at this meeting is 

included as attachment 1. The calculations that from the basis of some of their presentation are 

included as attachment 2. 

During the ACMA presentation, there was discussion of one facility that we stated had 95 
P.3 

percent capture and control, and that ACMA claimed did not meet the 95 percent control 

requirements. Subsequent to this meeting, we obtained additional information on this facility 

(A.R.E. in Mt Eaton, Ohio). This information has also been placed in the docket. 

2_ 
P.4 

Attachment 1 

ACMA Presentation 

3 
MMA 

Sa. 

American Composites Manufacturers Association p. 1 

Briefing for 

Jeff Holmstead 

Office of Air and Radiation 

U.S. Environmental Protection Agency 

Regarding the 

Proposed MACT Requirements for 

New Composite Manufacturing Operations 

November 4, 2002 

CONFIDENTIAL BUSINESS INFORMATION DELETED 
MMA American Composites Manufacturers Association p. 2 

Introduction 

This briefing presents the following issues in more detail, but in summary: 

• EPA's proposed MACT for composite manufacturing would require all new sources with emissions of 

100 tons per year or more to employ "total" enclosures and achieve 95% control. 

• These "floor" requirements are based on three plants that produce large quantities of small 

commodity products. Small part size makes high levels of capture possible, and the combination of 

small part size, uniform part shape, and high volume production makes 95% control feasible. 

• Plants making large and custom products have certain technical characteristics that distinguish them 

from small-part operations and make high levels of capture practically impossible. No such plant has 

ever demonstrated high capture levels. 

• The importance of these technical factors is underlined by their economic results. For composite 

^ manufacturing operations, the cost effectiveness of capture and control is reasonable only for plants 

making large quantities of small uniform products. 

• The proposed rule is in effect a construction ban on the new plants we will need to make products for 

several important markets. 

b> 
MMA American Composites Manufacturers Association p. 3 

Background 

• The Clean Air Act requires EPA to base MACT for new sources on the emission control performance 

of the best controlled "similar" source. CAA sec. 112(d)(2). The Act does not define "similar," but the 

only reading that makes sense is "similar in terms of the factors that EPA must consider in setting 

MACT." These are technical achievability, cost, energy, and non-air quality health and environmental 

impacts. CAA sec. 112(d)(2). The legislative history supports this reading. 

• OAQPS has identified as the floor-setting sources three highly specialized plants that make large 

quantities of uniform small commodity products. OAQPS argues that these plants achieve "total" 

capture1 and hence 95% control through oxidation. OAQPS proposes to require all new sources with 

HAP emissions above 100 tons, even those with very different technical characteristics, to achieve 

the same level of control as these specialized plants. 

• The new plants needed to make large products or custom products will not share the physical 

^> characteristics that allow the floor-setting small-part plants to practically enclose their processes, 

capture a high percentage of their emissions, and achieve 95% control. 

• Accordingly, facilities that are specialized to make uniform small parts are not "similar" to other 

facilities and cannot support a floor standard for them. If EPA insists otherwise and promulgates the 

rule as now drafted, the rule will indefensibly burden future growth ofthe industry in its most 

promising product lines. 

• We believe there are clear technical ways to separate out those sources that are similar to the floorsetting facilities from those that are not, and that this separation is not only legally defensible, but in 

fact required by the Act. 

1

 CFA does not believe that these plants actually satisfy the EPA requirements for total capture. 

Tl 
MMA American Composites Manufacturers Association p. 4 

Background (cont.) 

• To comply with the proposed rule, new plants would have to use EPA Method 204 to demonstrate 

that they achieve "total" capture. 

o Method 204 requires that process enclosures maintain continuous negative pressure during 

routine operations. 

• Small part operations will have small doors and can maintain negative pressure when 

doors are open to remove parts, bring in supplies, etc. 

• This is not possible for large-part operations, where the doors would be too large to 

maintain negative pressure when open. 

o OAQPS has suggested that states are often very "flexible" when enforcing Method 204. 

• However, Method 204 itself provides no flexibility, and local regulators have been very 

inconsistent in the degree to which they have allowed flexible enforcement. This 

uncertainty makes investing in a new plant far too risky. 

• If Method 204 were "flexibly" enforced for large-part operations, the resulting capture 

efficiencies could be so substantially reduced that capture and control would no longer 

be the "best" control approach. Sources will achieve equivalent emission reductions 

using the pollution prevention controls being required for existing sources by this rule. 

These controls have none ofthe negative economic and energy impacts of capture 

and control. EPA has not analyzed this issue in any way. 

o Even if these issues can be resolved, only plants making large quantities of uniform small 

parts will be able to afford capture and control. 
MMA American Composites Manufacturers Association p. 5 

Typical mass-produced small products 

(dimensions in feet) 

°<* 

• Tub/shower units. 

• Pickup truck caps 

• Window lineals.... 

2.5x5x 5 

6x8x 3 

.5 x4in. x 11/4in. 

Typical large and custom products 

Barge covers 4.5 x 24 x 30 

Utility poles 2 dia. x 85 

Wind turbine blades 9.5 dia. x 112 

Cooling tower components 1 x 4 x 48 

Bridge beams VA x 3 x 60 

Chemical process/storage tanks.... 10 dia. x 30 

Underground gasoline tanks 10 dia. x 20 

o assembled 10 x 74 

Motor home sidewalls 8 x 30 to 9 x 42 

o roofs 8!^x40 

o shower stalls 21/4 x 3 x 5 

o front and rear caps 8V2 x 9/4x 4 

Model space ship 15 x 14 x 4 

Tanks 3 dia. x 5 to 14 x 30 

Rail car platforms 101^x30 

o door liners 10 x 12 

Submarine conning tower 12x5x1 2 

o battery box 3 x 4 x35 

o superstructure 14 x 7 x 75 

Gold domes for a church 25 dia. 

Yacht 100 

o flying bridge .20 x 12 

Facade for an athletic store 50 x 12 x 3 

And thousands more... 

• Composite products are made by applying glass fibers and liquid resin to molds that are the shape ofthe final product. 

• Once applied, the resin chemically reacts to form a solid product, which is then removed from the mold. 

• Composites successfully compete against other material systems when the application calls for large structural shapes 

in combination with corrosion resistance, light weight, and/or design flexibility. 
MMA American Composites Manufacturers Association p . 6 

Example small mass-produced 

products 

Figure 1. Spray application of resin to tub/shower unit in spray 

booth. Workers can be positioned upstream to reduce exposure. 

Figure 2. Tub/shower molds on dollies, in front of spray booths. 

Small enclosures can capture high percentage of emissions. 

Figure 3. Tub/shower molds on overhead conveyor. Molds are 

quickly moved through production process. 

T) 

o 
MMA American Composites Manufacturer s Association p.7 

O 

Example large and custom products 

•. , 

Figure 4. Motor home sidewall, up to 42 feet long. 

Figure 5. Motor home front end. Structural requirements demand 

precise placement of reinforcement and careful assembly. 

Figure 6. Underground storage tank assembly. Photo CBI. 

Assembled products up to 10 x 74 feet. 

Figure 7. UST section and mold. Photo CBI. Overhead crane is 

used to remove 10 x 20 foot sections from lower half of mold. 
MMA American Composites Manufacturers Association p. 8 

Large and custom products (cont.) 

Figure 8. Applying resin and glass to barge cover mold. Photo 

CBI. Resin is applied to glass mat on overhead platform, which 

moves to drape the material on the mold. 

Figure 9. Barge cover and mold. Photo CBI. Molds are moved to 

various process stations during production, and completed covers 

are removed from molds using overhead cranes. 

Figure 10. Applying glass and resin to horizontal tank mold. 

Photo CBI. 

to 
MMA American Composites Manufacturers Association p. 9 

Large and custom products (cont.) 

c° 

Figure 11. Camper top. Highly customized product made in small 

quantites. 

Figure 12. Architectural dome. Highly customized product is 

typical of custom molding operations. 

Figure 13. Spray application of resin and glass to vertical 

chemical process/storage tank. 

5 
MMA American Composites Manufacturers Association p. 10 

Large and custom products (cont.) 

V^o 

Figure 14. Wind turbine blades. 

Figure 15. Wind turbine blade. A major new market for 

composites. 

Figure 16. Pultruded utility poles. Light weight, easy to install, and 

no wood preservatives needed. 

Figure 17. Pultruded bridge beams. Significant cost and 

performance benefits for transportation infrastructure rehabilitation. 
MMA American Composites Manufacturers Association p. 11 

Technical characteristics of plants 

-G 

Part size 

Number of products 

produced per day 

Emissions 

Process logistics 

Process area 

Process complexity 

Air flows needed to 

protect workers 

Feasibility of "total" 

capture 

Feasibility of 95% 

control 

Plants dedicated to the mass-production of 

small uniform products 

Up to 10 feet 

500+ 

Up to 1,000 tons per year 

Fast and often automated - molds are moved on 

conveyors or dollies 

Compact - often not much larger than a single 

product 

Low - simple laminates require limited interaction of 

worker with products 

Low - workers can be stationed upstream of 

products 

High - process enclosures can have continuously 

open small doors and still meet the requirements 

for total enclosure 

High - low volume air flows with high HAP 

concentration results in easier oxidation 

Plants producing large and custom products 

Up to 75+ feet 

1-20 

Up to 250 tons per year 

Large molds and products require slow movement using 

fork trucks, overhead cranes, teams of workers 

Large - to accommodate production of several large 

products plus associated equipment 

High - complex laminates require skilled workers to 

accurately apply resin and place glass reinforcement 

High - needed to protect workers stationed all around 

and inside products during production (high air flows 

are also needed to maintain negative pressure with 

large doors) 

Low to very low - process enclosures need large doors 

that are frequently open and subject to wind loads 

Low - high volume air flows with low HAP concentration 

dramatically increase the size and cost of air 

movement and control equipment, and increase the 

need for supplemental fuel 

For all these strictly physical reasons, large and custom parts facilities are likely to have more difficulty 

maintaining and operating add-on controls than specialized small parts facilities, and the performance of 

add-on controls at these facilities will be far less predictable. These factors are unquestionably relevant 

to determinations of "similarity." See 66 Fed. Reg. 40331. 

oi 
MMA American Composites Manufacturers Association p. 12 

Technical characteristics: Process density 

"Process density" is a measure that integrates several of the relevant technical characteristics, including 

part size, process complexity, production rate, and other factors that determine the practical feasibility of 

capture and control. 

_ annual quantity of product throughput, raw material usage, or emissions 

size (volume) of process area 

Figure 18 

\j^ • Plants dedicated to the production of small uniform products have very high process density. These 

plants make large quantities of product in small process areas. 

• Plants producing large and custom products have low process density. These plants make small 

quantities of product in very large process areas. 
MMA American Composites Manufacturers Association p. 13 

^ 

Technical characteristics: Process density (cont.) 

We calculated the process density for six plants that are representative of likely new plants. Two ofthe 

plants are dedicated to the mass-production of uniform small parts (A.R.E. is one of the floor-setting 

plants), and four make large parts. 

Products 

Typical Part 

Size 

feet 

Process 

Density 

tpy/1,000ft3 

Massproduced 

small parts 

A.R.E. 

pickup 

truck 

caps 

10.4 

10.1 

Plant A 

bathware 

7.5 

8.33 

Large and custom parts 

Monaco 

motor 

home 

sidewalls 

12-45 

0.18 

Plant B 

motor 

home, 

truck 

14.7 

0.28 

Proform 

UST, 

barge 

covers 

17-30 

0.15 

Xerxes 

UST 

17 

0.17 

>. 

</> 

c 

CO 

Q 

M 

vt 

m o 

o 

Q. 

12 

10 

8 

6 

4 

2 

^ 

^ 

o -^U 

AR.E. 

1 _ 

" — 

l~— 

*^~\ 

1 

PlantA

 Monaco 

1

 _____ 

"" 

Plant B Proform Xerxes 

TJ 
MMA American Composites Manufacturers Association p. 14 

Technical characteristics: Airflow 

At the suggestion of OAQPS, we also compared the six model plants by the ratio of air flow to amount of 

raw material processed. OAQPS asked us to perform this comparison because this ratio can be used 

as an indication of control feasibility. 

For the plants, we estimated the air flow needed both to protect workers and to maximize capture. 

*s/ 

For air flow 

needed for 

worker 

protection 

For air flow 

needed for 

worker 

protection 

plus max. 

capture 

Air flow + material usage 

cfm/ton 

Massproduced 

small parts 

LU 

Cai 

< 

8.79 

8.79 

Plant A 

5.42 

7.24 

Large and custom parts Monaco 

80.03 

97.96 

Plant B 

35.78 

63.25 

Proform 

42.42 

86.96 

Xerxes 

31.85 

45.57 

CFM air flow per ton of m aterial usage for worker protection 

(blue) and worker protection plus max. capture (red) 

A R E Plant A Monaco Plant B Proform Xerxes 

T3 

00 
MMA American Composites Manufacturers Association p. 15 

Industry's suggested approach 

• The final rule should limit new-source capture and control to those sources that are similar to the 

floor-setting plants, specifically, those that make small products in large quantities (and consequently 

have high process density). 

o The smallest product made by our four model large-part plants has a largest dimension of 12 

feet, and the largest product made by the floor-setting plants has a largest dimension of 10.4 

feet. Therefore, we suggest that the rule define "small open molded parts" as those with no 

dimension of 12 feet or more. 

• Although not specifically addressed in this briefing, we have submitted data and 

analysis to EPA supporting a definition of "small pultruded parts" as those with no more 

than 100 reinforcement feeds and cross sectional surface perimeter of less than 8 

inches. 

__ o We suggest that only those operations with small-part emissions of 100 tpy or more will have 

°S> sufficient process density to feasibly achieve 95% control. The smallest of the floor-setting 

plants emits 100 tpy, and EPA has already agreed that C&C is not feasible for plants with 

emissions of less than 100 tpy. 

TJ 

CO 
MMA American Composites Manufacturers Association p. 16 

Industry's suggested approach (cont.) 

• Our disagreement with OAQPS centers around where to "draw the line" separating new plants that 

should be required to achieve total enclosure and 95% control from those that should not. 

o The OAQPS proposed rule would require total capture and 95% control for all new plants with 

emissions of 100 tons per year or more. This approach would clearly include many facilities 

that are in no way "similar" to the floor-setting plants. 

o For new plants, our approach requires this level of control only for small-part operations with 

emissions of 100 tpy or more, or for 

all processes if total emissions are 

250 tpy or more. 

• We believe that the OAQPS proposed 

approach would "capture" many new 

plants that can not practically achieve total 

capture and 95% control, and would in 

effect prevent their construction. 

• Under our approach, large-part operations will still have to adopt the effective pollution prevention 

controls required of existing sources, and achieve emission reductions of 50-65%. 

• Our approach will allow our industry to grow and provide products for important new markets, while 

still achieving a significant reduction in emissions. 

OAQPS 

proposal 

Industry 

approach 

Total capture and 95% control required at new plants... 

... for small-part operations 

with emissions of... 

100 tpy or more 

100 tpy or more 

... for all other operations if 

total emissions are... 

100 tpy or more 

250 tpy or more 
MMA American Composites Manufacturers Association p.17 

£ 

Economic Characteristics: Control cost effectiveness 

The importance of the technical differences - between plants that make large quantities of small uniform 

products and plants that make large or custom products - is underlined by the economic differences to 

which they give rise. 

Process density has a very large impact on the cost 

effectiveness of a control system (the cost of controlling 

each ton of HAP). Plants with high process densities, like 

the floor-setting small-parts plants, will have much lower 

control costs than plants making large parts. 

Process 

Density 

tpy/1,000ft3 

Control cost 

effectiveness2 

$/ton of HAP 

Massproduced 

small parts 

A.R.E. 

10.1 

758 

Plant A 

8.33 

783 

Large and custom parts 

Monaco 

0.18 

5,425 

Plant B 

0.28 

4,829 

Proform 

0.15 

9,625 

Xerxes 

0.17 

5,994 

2

 Based on potential emissions; control cost estimates based on actual emissions will be higher. Also, our cost estimates for the four large-part 

plants are based on a design that maximizes capture while still providing for the necessary process logistics. We do not believe that these 

"maximum practical" capture systems will satisfy the EPA requirement for total capture or actually achieve more than 80% capture. "Total" capture 

has never been demonstrated for the manufacture of large composite products. 

TJ 

ro 
MMA American Composites Manufacturers Association p. 18 

Economic characteristics: Capital cost 

The capital cost of an add-on control system is driven primarily by the amount of plant air that must be 

captured,.transported to the control system, and then combusted. Because large-part and custom 

plants will typically have much higher air flows, and the capture systems will be larger and much more 

complex, the capital costs for these plants will be much higher. 

N 

Process 

Density 

tpy/1,000ft3 

Capital Cost 

of C&C 

$1,000 

Massproduced 

small parts 

A.R.E. 

10.1 

1.5003 

Plant A 

8.33 

979 

Large and custom parts 

Monaco 

0.18 

1,915 

Plant B 

0.28 

3,571 

Proform 

0.15 

7,320 

Xerxes 

0.17 

3,658 

' Estimate based on the percentage of emissions from the composite manufacturing operation. 
MMA American Composites Manufacturers Association p. 19 

Economic Characteristics: Impact on capital investment 

Large-part and custom plants typically have low capital investments in process equipment, compared to 

plants dedicated to the mass-production of uniform small parts. Accordingly, a requirement for capture 

and control will have a much larger impact on the total capital investment needed to build a new plant for 

large or custom products than it would on the capital cost of a specialized small-parts plant. 

Data on capital investment for two of our model plants is shown below. 

r 

Capital cost 

New plant 

$1,000 

New plant 

with C&C 

$1,000 

Increase 

Mass-produced 

small parts 

Plant A 

7,500 

8,479 

13% 

Large parts 

Proform 

2,378 

9,698 

308% 

ro 
MMA American Composites Manufacturers Association p. 20 

Summary 

• The ability of our companies to continue developing new 

products for new markets is essential to the health of our 

industry. Many of these products will be large and made 

in small quantities. 

• Our analysis demonstrates that there are significant 

technical differences between the floor-setting plants that 

mass-produce small uniform products and the many new 

plants that will make large and custom products. These 

technical differences have a profound impact on the 

feasibility of capture and control. Small part size makes 

high levels of capture possible, and high process density 

makes 95% control feasible. 

• Congress did not intend the Clean Air Act to prevent 

expansion of businesses or the invention of new 

products. We believe that our approach meets the 

statutory requirements to impose reasonable air pollution 

controls on new facilities, but will still allow our industry to 

produce new products. 

Recently commercialized large products 

Figure 19. Unibody camper mold and camper assembly. 

Improved structural properties and leak resistance. 
MMA American Composites Manufacturers Association p. 21 

Summary (cont.) 

• We suggest the following approach to MACT for new 

sources: 

o Any new source with emissions of 100 tons per 

year or more from the production of tub/shower 

units, pickup truck caps, window lineals, small 

open molded parts or small pultruded parts is 

required to reduce those emissions by 95%. 

• "Small open molded parts" is defined as 

those with no dimension greater than 12 feet 

(measured as the distance between the 

furthest two points on the part as it is 

removed from the mold). 

• "Small pultruded parts" is defined as those 

with no more than 100 reinforcement feeds 

and cross sectional surface perimeter of no 

more than 8 inches. 

o Any new source with emissions of 250 tons per 

year or more is required to reduce those 

emissions by 95%. 

o Any other composite manufacturing operation at a 

new source is required to comply with the 

applicable existing-source MACT. 

Recently commercialized large products: 

Figure 20. Wind fairing and artist rendering of installation 

on the Whitestone Bridge. Light weigth, easily installed, 

maximizes bridge capacity, won't rust or corrode. Photos CBI. 

Ol 
MMA American Composites Manufacturers Association p. 22 

Summary (cont.) 

• Additional industry considerations: 

o The floor-setting plants are specialized to make small parts. We considered suggesting that 

only specialized small-part plants should be required to achieve 95% capture and control. 

However, this would aliow sources to avoid this requirement simply by not being specialized. 

Accordingly, we suggest that the capture and control requirements apply to the emissions 

from production of small parts from any new facility if these small-part emissions exceed 100 

tons per year. This approach would allow custom molders some ability to serve this segment 

of the market while assuring that they did not produce so many small parts as to undermine 

the basic 95% control requirement. 

o There are no existing large-part or custom plants with emissions of more than 250 tons per 

year. We do not currently see how large-part plants larger than 250 tpy could achieve 

capture and control more readily than the existing plants. Although it is not certain that such 

^ plants will be built, we acknowledge that EPA may be concerned about the emissions 

consequences if they are. Therefore, to address these EPA concerns, we are willing to 

accept a final rule that would require 95% capture and control for any new large-part plant 

that emits more than 250 tons per year. 

f \ 
P.27 

Attachment 2 

Calculations used by ACMA to develop process density and cost effectiveness. 

II* 
iJ 

DRAFT 

Compactness Ratios 

(smaller values indicate processes 

that are more compact) 

process floor area per ton 

204 PTE floor area per ton 

process volume per ton 

204 PTE volume per ton 

process airflow per ton 

204 PTE airflow per ton 

process floor area per cfm 

204 PTE floor area per Cfm 

process volume per cfm 

204 PTE volume per cfm 

Small Parts 

Truck Caps 

A.R.E 

Massillon 

Bathware 

Plant A 

ft2/ton 

ft2 /ton 

ft3/ton 

ft3/ton 

cfm/ton 

cfm/ton 

ft2/cfm 

ft2/cfm 

ft3/cfm 

ft3/cfm 

10 

21 

99 

574 

95 

95 

0.11 

0.22 

1.0 

6.0 

existing RTO existing RTO 

15 

16 

120 

129 

59 

78 

0.26 

0.21 

2.0 

1.6 

Large Parts 

RV/Truck 

Plant B 

129 

141 

3,623 

4,233 

388 

685 

0.33 

0.21 

9.3 

6.2 

RV/Sidewall 

Monaco 

Hines 

236 

384 

5,697 

9,790 

867 

1,061 

0.27 

0.36 

6.6 

9.2 

UST UST/Covers 

Xerxes Proform West 

Hagerstown Memphis 

205 

245 

5,726 

6,846 

650 

930 

0.31 

0.26 

8.8 

7.4 

216 

414 

6,551 

12,373 

771 

1,581 

0.28 

0.26 

8.5 

7.8 

Control Cost Effectiveness Control costs increase significantly due to size of parts - more NDO airflow and larger enclosures needed 

Typical process at Permitted 

Emission Rate 

$/ton 

Method 204 at Permitted Emission 

Rate - including additional buildings & $ / ton 

NDO flows 

$758 

$758 

$657 

$783 

$4,873 

$4,830 

$4,791 

$5,425 

$5,242 

$5,994 

$5,762 

$9,626 
P.29 

A.R.E. Massillon - truck cap (small-part) production 

Production Activity 

units 

Gelcoating & Lamination of 

FRP Truck Caps 

Automotive Spray Painting of 

Finished Truck Caps 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Process Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Part Box 

Volume 

Enclosures 

Process Enclosures 

Gelcoat Booth: 

Gelcoat Cure Tunnel: 

Glassroom Booth: 

Resin Cure Tunnel: 

Inside Gelcoat Booth: 

Gelcoat Cure / Exit Tunnel: 

Method 204 Total Enclosure 

Lamination Room: 

Floor Areas 

Total Process Enclosure Floor 

Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Total Process Enclosure 

Volume 

Method 204-type Enclosure 

Volume 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type enclosure 

Additional floor area 

Capital Cost 

Annual Cost 

tpy 

cfm 

cfm 

cfm 

ft 

ft 

ft3 

ft2 

ft2 

ft3 

ft3 

ft2 

TCI$ 

TAC$ 

525 

50,000 

included above 

50,000 

6'Wx 8'Lx 3'H 

10.4 

144 

19'Wx25'Lx 9/4'H 

11'Wx79'Lx SV.'H 

28'Wx68' Lx111/«' H 

10'Wx79'Lx 8V4'H 

19'Wx25'Lx 9'/4'H 

10'Wx84'Lx 8'/4'H 

68'Wx164'Lx27'H 

5,353 

11,152 

52,074 

301,104 

NONE REQUIRED 

0 

0 

0 

500 

50,000 

included above 

50,000 

NA 

Plant-wide 

Total 

1,025 

100,000 

Comments and/or References 

standard truck cap 

diagonal dimension 

not shown in EPA trip report 

Natural Draft Openings 

Four Inlet Vents: 

Exit Tunnel "exit" opening 

NDO Free Area ft2 

four-5'Wx 2'H 

10'Wx 4'H 

80 

Add-on Control Costs 

Capital Cost TCI $ 

Annual Cost TAC $ 

Cost Effectiveness $ I ton 

Compactness Ratios 

process floor area per ton ft2 / ton 

204 PTE floor area per ton ft2 / ton 

process volume per ton ft3 / ton 

204 PTE volume per ton ft3/ton 

process airflow per ton cfm/ton 

204 PTE airflow per ton cfm/ton 

process floor area per cfm ff/cfm 

204 PTE floor area per cfm ft2 / cfm 

SEE CFA C&C Report 

$3,000,000 

$988,000 

$1,015 

10 

21 

99 

574 

95 

95 

0.1 

0.2 

SEE EPA trip report 

$2,324,800 

$738,400 

$758 

assuming 6,100 hr/yr 

assuming 95% of 1,025 tpy PTE 

"204 PTE" = Method 204 

permanent total enclosure 

process volume per cfm 

204 PTE volume per cfm 

1.0 

6.0 

1$ 
P.30 

Plant A - automated bathware (small-part) production 

Production Activity 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Typical Part 

Box Volume 

Enclosures 

Process Enclosures 

Gelcoat Booth 

Gelcoat Cure Tunnel 

Barrier Coat 

Barrier Coat Cure Tunnel 

Lam 1 Spray/Roll Booth 

Lam 1 Cure Tunnel 

Lam 2 Spray/Roll Booth 

Lam 2 Cure Tunnel 

tpy 

cfm 

cfm 

cfm 

ft 

ft 

n

3 

Lamination of Bathware Tub 

& Shower Units 

four molding stations on oval 

conveyor line 

426 

25,000 

8,400 

33.400 

2.5'Wx5'Lx5'H 

7.5 

63 

18'Wx12'Lx8'H 

12'Wx108'Lx8'H 

18'Wx18'Lx8'H 

12'Wx110'Lx8'H 

1SWx3Z\.xSH 

12'Wx104'Lx8'H 

18'Wx25'Lx8'H 

12'Wx80'Lx8'H 

Comments and/or References 

Plant has +90% control system 

PTE before RTO control unit, not inclu 

tpy of repair & misc. emissions in plan 

To RTO unit 

SEE NDO section below 

assume 33,000 cfm 

approx 70 SF 

Measured diagonally at greatest span 

SEE Plant plan drawing 

booths are 18'wide 

tunnels are 12'wide 

Method 204 Total Enclosure 

Gelcoat booth entrance tunnel 

Base storage rooms 

Floor Areas 

Process Floor Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Process Volume 

Method 204-type Enclosure 

Volume 

above process enclosures plus 

12'Wx20'Lx8'H 

two - 6'Wx20'Lx8'H 

ft2 

ft2 

ft3 

ft3 

6,390 

6,870 

51,120 

54,960 

SEE Building Additions section below 

needed to isolate gelcoat booth entrance 

needed to isolate base storage area 

inside booths and tunnels 

including additional tunnel & storage areas 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type enclosure 

Floor area ft2 

Capital Cost TCI$ 

Annual Cost TACS 

12'Wx20'Lx8'H 

6'Wx20'Lx8'H 

0 

$0 

$0 

New gelcoat entrance tunnel and base 

storage areas next to Lam booths; base 

inventory is restocked between workshifts 

(included in initial construction cost) 

Natural Draft Openings 

NDO Doorways 

NDO Free Area 

NDO Airflow at 200 fpm 

n

3 

cfm 

Gelcoat Booth in - 3' W x 7' H 

Lam 2 Booth out - 3' Wx T H 

42 

8.400 

Add-on Control Costs 

Typical at PTE 

Capital Cost TCI $ 

Annual Cost TACS 

Cost Effectiveness J/(on 

w/ Building Addition & NDO 

Capital Cost TCI $ 

Annual Cost TACS 

Cost Effectiveness $7 ton 

Compactness Ratios 

process floor area per ton fe / ton 

204 PTE floor area per ton te/ton 

process volume per ton ft3 / ton 

204 PTE volume per ton fe/ton 

process airflow per ton cfm/ton 

204 PTE airflow per ton cfm/ton 

process floor area per cfm fe/cfm 

204 PTE floor area per cfm ffl aim 

process volume per cfm fe/cfm 

204 PTE volume per cfm fe/cfm 

$963,100 

$265,900 

71657 

S979.000 

$316,950 

$783 

15 

16 

120 

129 

59 

78 

0.3 

0.2 

2.0 

1.6 

- 100% capture is currently achieved with 

doorway face velocities that are much less 

than 200 fpm (needed for Method 204) 

assuming 25,000 cfm & 426 tpy 

assuming 6,660 hr/yr operation 

assuming 95% of 426 tpy PTE 

assuming 33,000 cfm & 426 tpy 

assuming 6,660 hr/yr operation 

assuming 95% of 426 tpy PTE 

it 
P.31 

Plant B - misc. RV & truck (large-part) production 

Production Activity 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Typical Part 

Box Volume 

tpy 

Gelcoating and Lamination of 

Misc. RV & Truck Parts 

three cross-connected 

production lines 

129 

cfm 

cfm 

cfm 

ft 

ft 

50,000 

38,400 

88,400 

custom parts max size 

9'Wx10'Lx6'H 

14.7 

Comments and/or References 

Maximum HAP emissions 

booths only - cure areas not captured 

SEE NDO section below 

use 90,000 cfm system 

Measured diagonally at greatest span 

540 

Enclosures 

Process Enclosures 

Gelcoat Booths 

Gelcoat Cure area 

Lamination Booths 

Lamination Roll/Cure area 

two - 16'Wx30'Lx16'H 

40'Wx130'Lx30'H 

three - 16'Wx30'Lx 16'H 

70'Wx130'Lx30'H 

downdraft supply, sidewall exhaust 

approx. room dimensions at booth height 

downdraft supply, sidewall exhaust 

approx. room dimensions at booth height 

Method 204 Total Enclosure 130'Wx140'Lx30'H SEE Building Additions section below 

Floor Areas 

Process Floor Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Process Volume 

Method 204-type Enclosure 

Volume 

ft2 

ft2 

ft3 

ft3 

16,700 

18,200 

467,400 

546,000 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type enclosure 

Floor area 

Capital Cost 

Annual Cost 

Natural Draft Openings 

NDO Doorways 

NDO Free Area 

NDO Airflow at 200 fpm 

ft2 

TCI$ 

TAC$ 

ft2 

cfm 

NONE REQUIRED 

0 

$0 

$0 

16'Wx12'H 

192 

38,400 

SEE Method 204 plan view - new curing 

rooms to enclosure entire process (part of 

initial building cost) 

Add-on Control Costs 

Typical at PTE 

Capital Cost TCI $ $1,090,700 

Annual Cost TAC$ $314,300 

Cost Effectiveness $/ton $4,873 

wf Building Addition & NDO 

Capital Cost TCI $ $1,915,400 

Annual Cost TAC $ $591,900 

Cost Effectiveness $/ton $4,830 

Compactness Ratios 

assuming 50,000 cfm & 129 tpy 

assuming 6,000 hr/yr operation 

assuming 50% of 129 tpy PTE 

assuming 90,000 cfm & 129 tpy 

assuming 6,000 hr/yr operation 

assuming 95% of 129 tpy PTE 

process floor area per ton 

204 PTE floor area per ton 

process volume per ton 

204 PTE volume per ton 

process airflow per ton 

204 PTE airflow per ton 

process floor area per cfm 

204 PTE floor area per cfm 

process volume per cfm 

204 PTE volume per cfm 

ft2/ton 

ft2 /ton 

ft3/ton 

ft3/ton 

cfm/ton 

cfm/ton 

ft2/cfm 

ft2/cfm 

ft3/cfm 

ft3/ cfm 

129 

141 

3.623 

4,233 

388 

685 

0.3 

0.2 

9.3 

6.2 

3o 
Monaco Hines - two types of RV parts; sidewalls and misc. fiberglass parts 

P.32 

Production Activity 

two separate operations 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Part Box 

Volume 

Enclosures 

Process Enclosures 

Gelcoating & Lamination of 

units Sidewall Panels 

Panel Line 

one automated oval 

production line 

tpy 53 

Gelcoating and Lamination of 

Misc. Fiberglass Parts 

Fiberglass 

ten fixed molding stations 

120 

Plant-Wide 

Totals 

173 

cfm 

cfm 

cfm 

ft 

ft 

ft3 

50,000 

4,800 

54,800 

sidewall panel 

8'Wx45'Lx0.5 , H 

45.7 

180 

Panel Line Room -

67'Wx322'Lx26' H 

100,000 

28,800 

128,800 

roof 

roof -10'Wx45 ,Lx1' H 

endcap - 8'Wx9'Lx4' H 

roof 46.1 endcap 12.7 

roof 450 endcap 288 

Fiberglass Room -

ten - 24'Wx80'Lx16' H 

150,000 

33,600 

183,600 

Comments and/or References 

SEE plant's PTE spreadsheet 

10,000 cfm wall fan per fixed station 

SEE NDO section below 

Additional exhaust flow needed to 

balance NDO airflow into the rooms, 

assume 184,000 cfm 

Method 204 Total Enclosure 67'Wx322'Lx26'H 160"Wx320'Lx26' H 

Floor Areas 

Process Floor Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Process Volume 

Method 204-type Enclosure 

Volume 

ft2 

ft2 

ft3 

ft3 

21,574 

21,574 

618,410 

618,410 

19,200 

44,800 

367,200 

1,075,200 

40,774 

66,374 

985,610 

1,693,610 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type room 

enclosures w/o exterior doors 

Floor area tt2 

Capital Cost TCI $ 

Annual Cost TAC $ 

Natural Draft Openings 

NONE REQUIRED 

O 

$0 

$0 

NONE REQUIRED 

0 

$0 

$0 

0 

$0 

$0 

SEE Plant plan view - inside rooms will 

enclosure both operations (cost of room 

is part of Initial building cost) 

NDO Doorways 

NDO Free Area 

NDO Airflow at 200 fpm 

Add-on Control Costs 

ft2 

cfm 

Typical at PTE 

Capital Cost TCI $ 

Annual Cost TACS 

Cost Effectiveness $/ton 

w/ Building Addition 8. NDO 

Capital Cost TCI $ 

Annual Cost TAC $ 

Cost Effectiveness $ / ton 

Compactness Ratios 

process floor area per ton 

204 PTE floor area per ton 

process volume per ton 

204 PTE volume per ton 

process airflow per ton 

204 PTE airflow per ton 

process floor area per cfm 

204 PTE floor area per cfm 

process volume per cfm 

204 PTE volume per cfm 

ft2/ton 

ft2/ton 

ft3 /ton 

ft3 /ton 

cfm/ton 

cfm/ton 

fr/cf m 

fr/cf m 

ft3/cfm 

ft3/cfm 

one-12'Wx2' F 

24 

4.800 

Panel Line 

407 

407 

11.668 

11,668 

943 

1,034 

0.4 

0.4 

12.4 

11.3 

one-12'Wx12'H 

144 

28,800 

168 

33,600 

Fiberglass Room 

160 

373 

3,060 

8,960 

833 

1,073 

0.2 

0.3 

3.7 

8.3 

$2,998,800 

$745,900 

54,79* 

$3,571,100 

$891,600 

$5,425 

Plant-Wide 

236 

384 

5,697 

9.790 

867 

1.061 

0.3 

0.4 

6.6 

9.2 

Slot and door remains open continuously 

assuming 150,000 cfm & 173 tpy 

assuming 4,000 hr/yr (two-shift) operation 

assuming 90% of 173 tpy PTE 

assuming 184,000 cfm & 173 tpy 

assuming 4,000 hr/yr (two-shift) operation 

assuming 95% of 173 tpy PTE 

3| 
P.33 

Xerxes Hagerstown - UST (large-part) production only 

Production Activity 

Lamination & Assembly of . 

Underground Storage Tanks 

UST 

twelve UST molding stations 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Typical Part 

Box Volume 

Smallest Large-Part 

"Greatest" Part Dimension of 

Smallest Large-Part 

Enclosures 

Process Enclosures 

Lamination -

Assembly -

Misc Parts/Testing/Repair -

tpy 

cfm 

cfm 

cfm 

ft 

ft 

ft3 

ft 

200 

130,000 

56,000 

186,000 

10 Dia x 20' Las molded 

10 Dia x 40' L as assembled 

22.4 

2,000 

6' Diax 16' Las molded 

17.1 

55'Wx328'Lx28'H 

45'Wx328'Lx28'H 

60'Wx135'Lx28'H 

Comments and/or References 

SEE Xerxes MACT comments (styrene only) 

SEE NDO section below 

Measured diagonally at greatest span 

Measured diagonally at greatest span 

Building Enclosure 

100'Wx328'Lx28'H 

60'Wx135'Lx28'H 

Method 204 Total Enclosure 

100'Wx378'Lx28'H 

60Wx185'Lx28'H SEE Building Additions section below 

Floor Areas 

Process Floor Area 

Building Enclosure Floor Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Process Volume 

Building Enclosure Volume 

Method 204-type Enclosure 

Volume 

ft2 

te 

te 

te 

te 

40,900 

40,900 

48.900 

1,145,200 

1.145,200 

The process is current enclosed inside a building 

The process is cunent enclosed inside a building 

1.369,200 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type room 

enclosures with no exterior 

doors 

Floor area 

50' x 60 airlock to North side 

50'Wx60'Lx28'H 50' 

extension to East side 50' W 

x100'Lx28'H 

8,000 

Capital Cost TCI $ 

Annual Cost TACS 

Natural Draft Openings 

NDO Doorways 

$240,000 

$26,544 

one - 20' W x 14' H open 

one-20Wx14'Hclosed 

NDO Free Area 

NDO Airflow at 200 fpm 

Add-on Control Costs 

Typical at PTE 

Capital Cost 

Annual Cost 

Cost Effectiveness 

w/ Building Addition & NDO 

Capital Cost 

Annual Cost 

Cost Effectiveness 

Compactness Ratios 

process floor area per ton 

204 PTE floor area per ton 

process volume per ton 

204 PTE volume per ton 

process airflow per ton 

204 PTE airflow per ton 

process floor area per cfm 

204 PTE floor area per cfm 

process volume per cfm 

204 PTE volume per cfm 

te 

cfm 

TCIS 

TACS 

S/ton 

TCIS 

TACS 

S/ton 

ffl ton 

ffl ton 

ffl ton 

ffl ton 

cfm/ton 

cfm/ton 

n/cfm 

fe/cfm 

fe/cfm 

ffl cfm 

280 

56,000 

$2,699,100 

$838,700 

$5,242 

$3,658,200 

$1,138,900 

$5,994 

205 

245 

5,726 

6,846 

650 

930 

0.3 

0.3 

8.8 

7.4 

SEE FRP Building Costs 

assuming 11.06% of TCI 

Two "NDO" doors may be open 

simultaneously, but assume only one door 

will be open at a time 

assuming 130,000 cfm & 200 tpy 

assuming 24-hr operation 

assuming 80% of 200 tpy PTE 

assuming 186,000 cfm & 200 tpy 

assuming 24-hr operation plus building costs 

assuming 95% of 200 tpy PTE 

3^ 
Proform West Memphis - three large-parts; barge cover, UST, AGT production 

P.34 

Production Activity 

three separate operations 

Emissions 

HAP Emission Rate PTE 

Exhaust Airflow 

Process Exhaust Airflow 

NDO Exhaust Airflow 

Total Exhaust Airflow 

Part Dimensions 

Typical Part Dimensions 

"Greatest" Part Dimension 

"Most-Compact" Part Box 

Volume 

Smallest Large-Part 

"Greatest" Part Dimension 

tpy 

cfm 

cfm 

cfm 

ft 

ft5 

Gelcoating & Lamination of 

River Barge Covers 

Barge Covers 

one production line 

88,000 

89.600 

177,600 

24'Wx30'Lx4'/i'H 

38.7 

3.240 

Lamination & Assembly of 

Underground Storage Tanks 

UST 

four UST molding stations 

52.000 

56,000 

108,000 

10' Dia x 20' L as molded 

10' Dia x 40' L as assembled 

22.4 

2,000 

6' Dia x 16' L as molded 

17.1 

Lamination & Fil. Wind of 

Aboveground Storage Tanks 

AGT - a.k.a. Vertical Tanks 

four AGT molding stations 

52,000 

56,000 

108,000 

10* Dia x 30' L as molded 

31.6 

3,000 

Plant-Wide 

Totals 

192.000 

201.600 

393,600 

Comments and/or References 

SEE NDO section below 

Measured diagonally at greatest span 

Enclosures 

Process Enclosures 

Building Enclosure 

Method 204 Total Enclosure 

Floor Areas 

Process Floor Area 

Building Enclosure Floor Area 

Method 204 Enclosure Floor 

Area 

Volumes 

Process Volume 

Building Enclosure Volume 

Method 204-type Enclosure 

Volume 

tf 

ff 

ff 

ff 

Gelcoat -

50'Wx165'Lx24' H 

Resin -

50'Wx165'Lx24' H 

10,000 ft3 of the gelcoat and resin 

area has a 40* H ceiling 

Small Parts -

40'Wx100'Lx24'H 

Barge Cover Building -

140'Wx266'Lx24'H 

10.000 ft3 of this enclosure has a 407 

H celling 

140'Wx366'Lx24'H 

20,500 

37,240 

Building Additions 

Additional Building Areas 

required to isolate process in 

Method 204-type room 

enclosures with no exterior 

doors 

Floor area fe 

Capital Cost TCI $ 

Annual Cost TAC $ 

Natural Draft Openings 

NDO Doorways 

NDO Free Area 

NDO Airflow at 200 fpm 

Lamination -

85'Wx55'Lx24'H 

Assembly -

85Wx125'Lx24'H 

UST Building -

85Wx180'Lx24'H 

85'Wx2B0'Lx24'H 

652,000 

1,053,760 

100 extension to North end 

140'Wx100'Lx24'H 

Lamination -

100'Wx100'Lx40'H 

Assembly -

100'Wx80'Lx40'H 

Vertical Tank 8uilding • 

100'Wx180'Lx40'H 

100'Wx280'Lx40'H 

14,000 

$420,000 

$46,452 

one - 28' W x 16' H open 

one-28'Wx16'H closed 

two-20'Wx12'H closed 

ff 448 

cfm 89,600 

15.300 

15,300 

367,200 

367,200 

571,200 

50 extension to West side 

50'Wx85'Lx24'H 

50' extension to East side 

50'Wx85'Lx24'H 

8,500 

$255,000 

$28,203 

one- 20' Wx 14' H open 

one - 20'Wx 14'H closed 

280 

56,000 

18,000 

18,000 

28,000 

612,000 

612,000 

1,120,000 

50 extension to West side 

50'Wx100'Lx24'H 

50 extension to West side 

50'Wx100'Lx24'H 

10,000 

$300,000 

$33,180 

one - 20' W x 14' H open 

one - 20 Wx 14'H closed 

280 

56.000 

53.800 

70.540 

103.040 

1,631,200 

2,032.960 

3,080,960 

32,500 

$975,000 

$107,835 

1.008 

201,600 

SEE Building Additions section below 

SEE FRP Building Costs 

11.06% of TCI 

Two doors per area may bo open 

simultaneously, but assume only one 

door per area will be open 

Add-on Control Costs 

Typical at PTE 

Capital Cost 

Annual Cost 

Cost Effectiveness 

w/ Building Addition & NDO 

Capital Cost 

Annual Cost 

Cost Effectiveness 

Compactness Ratios 

process floor area per ton 

204 PTE floor area per ton 

process volume per ton 

204 PTE volume per ton 

process airflow per ton 

204 PTE airflow per ton 

process floor area per cfm 

204 PTE floor area per cfm 

process volume per cfm 

204 PTE volume per cfm 

TCIS 

TACS 

$/ton 

TCIS 

TAC$ 

$/ton 

ffl ton 

fflton 

ff /ton 

ft3/ton 

cfm/ton 

cfm/ton 

tf/dlrn 

fe/cfm 

ft3/cfm 

fe/cfm 

Barge Covers 

353 

883 

11.241 

23.961 

1,517 

3,062 

0.2 

0.3 

7.4 

7.8 

143 

222 

3,432 

5.338 

1,009 

0.3 

0.2 

7.1 

5.3 

a. Vertical Tanks 

214 

333 

7,286 

13,333 

619 

1.286 

0.3 

0.3 

11.8 

10.4 

$3,656,800 

$1,147,800 

$5,762 

$7,320,000 

$2,277,000 

$9,626 

Plant-Wide 

216 

414 

6.551 

12,373 

771 

1,581 

0.3 

0.3 

8.5 

7.8 

assuming 190,000 cfm 4 249 tpy 

assuming 24-hr operation 

assuming 60% of 249 tpy PTE 

assuming 390,000 cfm & 249 tpy 

plus building & NDO costs 

assuming 95% of 249 tpy PTE 

33 
P.35 

Large-part plant building costs 

Proform West Memphis cost 

Site work $ 472,000 

First-phase building cost $ 1,044,000 

Change orders $ 91,000 

Second-phase addition $ 371,000 

Third-phase addition (projected) $ 400,000 

Total plant building cost $ 2,378,000 

Total plant floor area 70,540 ft2 

Building cost per ft2 33.71 $ per ft2 

Assume TCI of $30 per ft2 

Additional building annual operating costs includes taxes, insurance, 

maintenance is assumed to be 3% of TCI 

Annualized capital cost is assumed at 7% interest for 30 years 

CRF(7%, 30 yr) = 0.0806 or 8.06% 

Trj 
Additional Airflow 

needed to protect 

workers against 

styrene exposure 

VA) 

Small Parts 

Truck Caps 

A.R.E Massillon 

existing RTO 

Information on styrene 

exposure at A.R.E. is not 

publically available and 

has not been provided to 

industry or CFA 

representatives. 

Respirator usage has 

been rumored at A.R.E., 

but such usage cannot 

be confirmed. 

Therefore, the need for 

additional ventilation 

airflow cannot be 

assessed. 

unknown 

Bathware 

Plant A 

existing RTO 

Large Parts 

RV/Truck 

Plant B 

All of the line workers 

wear pressurized-air 

respirator hoods or halfface personal respirators. Almost all of the line 

Thus, ventilation airflow is workers wear half-face 

not needed to protect the personal respirators, 

workers. The local OSHA Thus, ventilation airflow 

office granted the is not needed to protect 

company a special waiver the workers, 

that permits respirator 

usage and very low 

ventilation airflows. 

RV/Sidewall 

Monaco Hines 

0 cfm 0 cfm 

Almost all of the 

production workers wear 

half-face personal 

respirators. Thus, 

ventilation airflow is not 

needed to protect the 

workers, (doublecheck this with Kurt 

Anderson) 

0 cfm 

UST 

Xerxes Hagerstown 

Due to the unique, ideal 

configuration ofthe UST 

work area, additional 

ventilation airflow is not 

needed to protect the 

production workers 

inside the UST molds. 

Current worker 

exposures were 

measured at significantly 

less than the PEL (50 

ppm). Respirators are 

not required. 

0 cfm 

UST/Covers 

Proform West 

Memphis 

The UST operation at 

Proform is identical to 

the Xerxes operation 

(SEE previous column) 

Also, the current 

ventilation airflow in the 

Barge Cover area is just 

able to achieve the PEL 

without respirators. The 

airflow needed for the 

planned Vertical Tank 

area is unknown 

(assumed to be 52,000 

cfm). 

0 cfm 

Additional Airflow 

needed to meet 

Method 204 criteria 

through the NDOs none 8,400 cfm 38,400 cfm 33,600 cfm 56,000 cfm 201,600 cfm 
Actual resin & gelcoat usages cannot be directly determined in advance for a NEW plant. However, typical normalized resin/gelcoat usage-to-emission ratios can be assumed, and these 

assumptions can then be used to convert a NEW plant's permitted PTE (in tpy) into an equivalent annual usage of resin/gelcoat (total lb/yr). 

% Total "Wet" 

Laminate Weight 

30% 

70% 

100% 

100% 

Normalized Resin/Gelcoat Usage Assumptions 

Material Type 

Gelcoat 

Resin 

Total (both) 

Corrosion Resin 

Styrene Content 

40% by wt 

35%bywt 

42%bywt 

UEF factor 

material wt) 

atomized - 21.9% 

non-atom - 3.8% 

non-atom - 4.9% 

(% Styrene Emissions 

(Ib styrene/lb material) 

0.0657 

0.0266 

0.0923 

0.0490 

6" 

PTE (tpy) 

Maximum Material Usage (tpy) 

Gelcoat 

Resin 

Total 

Process airflow (cfm) 

204 PTE airflow (cfm) 

Process airflow per ton material 

204 PTE airflow per ton material 

Small Parts 

Truck Caps 

A.R.E Massillon 

existing RTO 

525 

1,706 

3,982 

5,688 

50,000 

50,000 

8.79 

8.79 

Bathware 

Plant A 

existing RTO 

426 

1,385 

3,231 

4,615 

25,000 

33,400 

5.42 

7.24 

Large Parts 

RV/Truck 

Plant B 

129 

419 

978 

1,398 

50,000 

88,400 

35.78 

63.25 

RV/Sidewall 

Monaco Hines 

173 

562 

1,312 

1,874 

150,000 

183,600 

80.03 

97.96 

UST 

Xerxes Hagerstown 

corrosion resin 

200 

0 

4,082 

4,082 

130,000 

186,000 

31.85 

45.57 

only 

UST/Covers 

Proform West 

Memphis 

249 

(191 is corros.resin only) 

189 

4,338 

4,526 

192,000 

393,600 

42.42 

86.96 

co 

^i