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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

44) ll-E-4 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:04 AM Sheet 44 of 264 

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O PACIFIC ENVIRONMENTAL SERVICES, INC. 

MEMORANDUM 

Central Park West 

5001 South Miami Boulevard 

PO Box 12077 

Research Triangle Park, NC 27709-2077 

(919) 941 -0333 FAX (919) 941 -0234 

TO: 

FROM: 

DATE: 

Madeleine Strum 

U.S. Environmental Protection Agency/OAQPS/CPB 

Greg LaFlam and Dean Carroll 

Pacific Environmental Services, Inc. (PES) 

June 15, 1993 

L:\N027 

SUBJECT: 

LOCATION: 

ATTENDEES: 

Minutes of June 7, 1993, Meeting Between EPA, PES, and 

Representatives of the Reinforced Composites Industry 

The meeting was held at the EPA/Mutual Building, Durham, NC, 10th 

Floor Conference Room, 1:00 p.m. 

Ms. Rebecca Battye 

Mr. Gerry Bender 

Mr. Jim Berry 

Mr. Samuel Bleicher 

Mr. Dean Carroll 

Dr. Frank Cassis 

Ms. Lisa Conner 

Mr. Roger Crawford 

Ms. Laurel Driver 

Mr. Chuck French 

Mr. Richard Higgins 

Ms. Lynn Hutchinson 

Mr. Kenneth Kensington 

Mr. Greg LaFlam 

Mr. Charles McClaskey 

Mr. Stephen McNally 

Mr. Carlos Nunez 

Mr. Dan Ruggeberg 

Mr. John Schweitzer 

Dr. Madeleine Strum 

Mr. John Tickle 

I i \7 «. 

EC/R 

Molded Fiberglass Company 

EPA/OAQPS/CPB 

Miles and Stockbridge, Counsel 

PES 

Ashland Chemical, Inc. 

EPA/OAQPS/SDB 

Outboard Marine Corporation 

EPA/OAQPS/PAB 

EPA/OAQPS/PAB 

HK Research Corporation 

EPA/OAQPS/SDB 

VIATEC-Hastings 

PES 

Reichhold Chemicals, Inc. 

Composites Fabricators Association (CFA) 

EPA/ORD 

Reichhold Chemicals, Inc. 

Composites Institute of the Society of the Plastics 

Industry (SPI) 

EPA/OAQPS/CPB 

Morrison Molded Fiber Glass (MMFG) 

WASHINGTON, D.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES, CA • CINCINNATI, OH 
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Minutes of June 7, 1993 Meeting 

Page 2 

PURPOSE 

The purpose of the meeting was to allow EPA to meet with several representatives 

from industry to discuss preliminary issues involved in the development of a national 

emission standard for hazardous air pollutants (NESHAP) for the reinforced composites 

production industry. The agenda of discussion issues provided by industry is attached to 

this memorandum. 

DISCUSSION 

Mr. Schweitzer from SPI acted as the coordinator for the industry's presentation 

and discussion. Mr. Bleicher (Miles and Stockbridge) began the discussion by bringing up 

the California best achievable control technology (BACT) rules for polyester resin 

operations, especially the South Coast Air Quality Management District's (SCAQMD's) 

Rule 1162. He reported that a conclusion reached in California is that add-on controls 

generally are economically infeasible for these operations. The combination of the 

California rules and the OSHA requirement to limit occupational styrene exposures to a 50 

ppm permissible exposure limit (PEL) has forced some companies to close their doors or 

leave the State. 

Alternative monomers to replace styrene were discussed. Mr. Dan Ruggeberg of 

Reichhold Chemicals, Inc., said that no other monomers have yet been identified with 

properties equivalent to those of styrene (including low cost). There are alternatives such 

as vinyl toluene or paramethyl styrene; however, they are less desirable in terms of room 

temperature curing, odor, and toxicity. The physical properties of the composite may also 

be compromised when using these alternative monomers. On the subject of substituting 

one resin for another, Mr. Kensington (VIATEC-Hastings) stated that for his company's 

corrosion-resistant tank, pipe, and ductwork production, substitution can be difficult 

because only certain resins will provide the needed high performance properties. 

Mr. LaFlam (PES) asked about the applicability of vapor suppressed resins. Dr. 

Cassis, Ashland Chemical, Inc., stated that all resin manufacturers produce suppressed 

resins, and that they are very common in California. However, these resin formulations 

can pose a problem in the secondary bonding in some products. The suppressant additive 

leaves a paraffin wax-type film between laminations, and may cause delaminations or 

peeling. Suppressed resins are also somewhat more expensive than typical resins. 

Mr. Tickle (MMFG) referred to the success of current emission reductions at his 

facility and stated that a requirement to make further significant reductions could create a 

very difficult situation. Mr. Berry (EPA) stated that we recognize that regulatory 

approaches based on percent reductions can be perceived as punitive. With regard to 

coating rules, the Agency has a history of focusing on the end result, the allowable 
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Minutes of June 7, 1993 Meeting 

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emissions, thereby taking the prior reductions into account, and companies having already 

taken action would not be "penalized". 

Mr. Bleicher stated that companies would experience difficulty in responding to the 

questionnaire in terms of performing emission measurements. Variations in ambient 

temperature and humidity can greatly affect emission values. Further, most emissions are 

fugitives, compounding the difficulty. Companies do not know the answers to these 

questions and cannot afford to find out. 

Mr. Schweitzer brought up the industry survey, which the composites industry has 

been developing. Several representatives stressed that most companies would be reluctant 

to respond unless their identities were kept confidential. A "coding" system to accomplish 

this was discussed as a possible solution. The EPA tentatively agreed that such coded 

responses may be acceptable. Mr. Berry stated that EPA is moving ahead with its own 

initiative to send out the "generic" information collection request (ICR) questionnaire to 

gain information on the industry. After receiving these responses and learning more about 

the industry, EPA plans to send a detailed Section 114 questionnaire to nine companies 

(the limit imposed by OMB). The allowed response time for these industry questionnaires 

was stated to typically be 60 days. Industry agreed to continue developing its survey, and 

that they would send it out to companies not covered in EPA's mailout. 

In response to a question by Mr. Bleicher, the plan and schedule for the standard 

development (hearings, proposal, and promulgation) were briefly discussed by Mr. Berry. 

The basic formula for determining the level of the standard was also described. This 

NESHAP is on a 2-year schedule. The maximum achievable control technology (MACT) 

"floor" was explained to be the average of the best performing 12 percent of the industry, 

for which the Administrator has emissions information. The Act requires that new sources 

be required to achieve the "best of the best" demonstrated technology. Mr. Berry 

explained that this approach presents a special challenge in the case of an industry such as 

composites production, in which most emissions are fugitives and quantifiable emission 

reductions are not widespread. Among the traditional elements of the Agency's 

rulemaking process, the traditional public hearing was stated to possibly be unnecessary. 

Mr. McNally (CFA) discussed the possibility of subcategorizing the industry in 

setting this standard. Industrial representatives agreed to provide recommendations for 

possible plant visits to EPA/PES. Industry was greatly concerned to hear that EPA 

personnel were budgeted to make only one plant visit. PES, however, will likely be able 

to make several visits, concentrating on areas where several suitable facilities are located 

near one another. 

The topic of pollution prevention was discussed, which EPA stressed as being a 

likely area for determining the best 12 percent. The fact that California control measures 

have reportedly achieved 40 to 50 percent reductions may assist in the development of the 
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Minutes of June 7, 1993 Meeting 

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rule. The main options that EPA sees as available at this time are air management (to 

maximize fugitive concentrations) with control and low-emitting resins. 

Reichhold and CFA collectively mentioned that videotapes and training materials 

are available to be reviewed. These materials provide information on the range of 

composites processes. Mr. McClaskey also invited EPA/PES to visit their facility in 

Research Triangle Park, NC to observe the small-scale production processes in their 

laboratory and to learn about the array of resins provided by Reichhold (some 500 

products). 

Finally, Mr. Schweitzer stated that the emission evaluation programs sponsored by 

SPI are ongoing. Study results on emissions from pultrusion and other molding processes 

will be provided to EPA as they are available. 

ACTION ITEMS 

EPA/PES 

• EPA/PES will finalize the generic ICR and mailing list for mailout in June. The 

EPA will provide a copy of its final mailing list to SPI so that they can encourage 

cooperation by the recipients. 

• EPA/PES plan to make at least one plant visit in June, with others to follow, based 

on coordination with industrial contacts. 

• EPA/PES will contact Mr. McClaskey to set up a visit to Reichhold's facility in 

Research Triangle Park, North Carolina. 

Industry 

• 

• 

Industrial representatives will provide EPA/PES with orientation materials so that a 

broader understanding of the industry and its processes can be realized. 

Industry will provide input to EPA on their recommendations for plant visits by 

EPA/PES. 

Industry will continue its development of a survey questionnaire according to a 

timetable that will be consistent with EPA's regulatory schedule (to be ready within 

2 months after this meeting). 

DAC:ly