p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

11) ll-J-2 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 11 of 36 
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<l 

MEMORANDUM 

DATE: October 13, 1998 

SUBJECT: Minutes of September 11, 1998 Small Business Open Molding Outreach Meeting 

for the Reinforced Plastics MACT Standard 

LOCATION: EPA / Environmental Research Center / Auditorium 

Research Triangle Park, NC 

9:00 a.m.-3:00 p.m. 

PARTICIPANTS: 

Mr. Mark Aker 

Mr. Daniel Boyd 

Ms. Linda Chappell 

Mr. Rick Colyer 

V Mr. Allen DeBusk 

Mr. Benny Duvall 

Ms. Deborah Elmore 

Mr. Jack Hanley 

Ms. Missy Henricksen 

Mr. Charles Hester 

Mr. David R. Hillis 

\ Mr. William Holtzclaw 

\/Mr. 

Mr. 

VMr. 

Ms. 

^Mr . 

\.Mr. 

\/Mr. 

Ms. 

Mr. 

Mr. 

Mr. 

., Ms. 

A>Mr. 

\>Mr. 

v Mr. 

Michael Hood 

Robert Jemison 

Ken Kensington 

Patricia Koman 

Jim Lee u4*r*W v 

Jon Lhommedieu 

George McAllister 

Shawn McKee 

Phil McMillian 

Steve McNally 

Ken Meardon 

Janet Meyer 

Lowell Miles 

Richard Moore 

Gary Multanen 

Aker Plastics, Inc. 

Society ofthe Plastics Industry (SPI)/ 

Composites Institute (CI) 

EPA/OAQPS/AQSSD/ISEG 

EPA/OAQPS/ESD/CCPG 

Appalachian Plastics, Inc. 

Aker Plastics, Inc. 

EPA/OAQPS/ITPID/ITG 

Process Technologies, Inc. 

Composite Fabricators Association (CFA) 

PES 

East Carolina University 

Holtec, LTD representing 

MFG Justin Tanks, Inc. 

Hood Manufacturing, Inc. 

PES 

Viatec, Inc. 

EPA/OAQPS/ESD/CCPG 

Palmer of Texas, Inc. 

Altec Engineering, Inc. 

Aqua Bath, Inc. 

PES 

Frees, Inc. 

CFA 

PES 

EPA/OAQPS/ESD/CCPG 

Miles Fiberglass & Plastics, Inc. 

Arrowhead Plastic Engineering, Inc. 

Fiberglass Systems, Inc. 

EPA AIR UUCKi ! 

(304) 263-2525 

410 

919 

919 

540 

304 

919 

219: 

703 

919 

252 

302 

714 

919 

616 

919 

915 

219 

615 

919 

318 

703 

919 

919 

503 

765 

208 

827-6244 

541-2864 

541-5262 

429-2581 

263-2525 

541-5437 

365-9964 

525-0511 

941-0333 

328-4147 

856-3521 

979-7681 

941-0333 

948-3860 

541-4120 

523-5904 

293-1965 

227-0017 

941-0333 

424-2564 

525-0511 

941-0333 

541-5254 

775-7755 

286-0533 

342-6823 
P.3 

Madeleine Strum 

October 2, 1998 

Page 2 

PARTICIPANTS (Continued): 

Mr. Mark Naylor 

Mr. Jim Noonan 

^ 

^ Mr. Neil Olsen 

Ms. Melanie Proctor 

\/Mr. Dick Putnam 

Mr. Frank Ranson 

Mr. John Schweitzer 

^ Mr. Jonathan Spaulding 

Ms. Madeleine Strum 

Ms. Kim Teal 

Aker Plastics, Inc. 

Indiana Clean Mfg. Technology 

.& Safe Materials Institute 

Xerxes Corporation 

PES 

Eckler Industries, Inc. 

The Phil Carter System, Inc. 

CFA 

North End Composites, Inc. 

EPA/OAQPS/ESD/CCPG 

EPA/OAQPS/ESD/CCPG 

(304) 263-2525 

(765) 463-4749 

(612)887-1821 

(919) 941-0333 

(407) 269-9680 

(734)622-0162 

(207)594-8821 

(919)541-2383 

(919)541-5580 

GOALS AND OBJECTIVES 

Ms. Strum began the meeting by reviewing the meeting agenda (see Attachment 1). This 

review was followed by a brief round of introductions. After the introductions, Ms. Strum began by 

discussing EPA's main goals and objectives for the meeting (see Attachment 2). Ms. Strum stated 

that EPA's main goals and objectives for the meeting were to share information about the progress 

of the proposed rule for the reinforced plastics industry, and gather feedback from the attendees. 

Ms. Strum asked ifthe attendees had any additional goals for the meeting. The attendees did not offer 

any additional goals. After discussing the goals and objectives, Ms, Strum continued with the 

briefing. 

BRIEFING ON THE MACT RULE DEVELOPMENT AND THE REQUIREMENTS 

CURRENTLY BEING CONSIDERED FOR PROPOSAL (See Attachment 3) 

During the briefing, Ms. Strum covered the following items: legal requirements, standards 

development, status ofMACT development, EPA's approach for developing MACT for existing 

open molding sources, and MACT standards being considered for existing open molding sources. 

Legal Requirements 

Ms. Strum reviewed the legal issues and terms associated with the rule-making process. Ms. 

Strum explained that maximum achievable control technology, or "MACT," is the term commonly 

used to describe the standards mandated by section 112 ofthe Clean Air Act (CAA). EPA is required 
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Madeleine Strum 

October 2, 1998 

Page 3 

by the CAA to list categories of major sources of HAP and develop MACT standards for these 

categories. Reinforced plastics production was one ofthe major categories listed. 

Standards Development 

Ms. Strum explained the MACT floor represents the minimum level of stringency mandated 

by the CAA. The MACT floor for existing sources is the average ofthe best performing 12 percent 

of sources for a category or subcategory of more than 30 sources, or the average of the best 

performing five sources if there are less than 30 sources. The average can be the median or the mean. 

Ms. Strum also indicated that subcategories can be based on classes, types, or sizes of sources. For 

the Reinforced Plastics source category, the average (within each subcategory) was taken to be the 

median facility (sixth percentile). 

Mr. Hood inquired if resins used during polymer casting could be averaged with the gel coats 

applied by a facility that uses polymer casting. Ms. Strum responded in the negative and indicated 

that facilities using polymer casting could only average among the gel coats used. Ms. Strum stated 

that because polymer casting is a separate subcategory from open molding and that averaging is not 

allowed across subcategories, averaging between polymer casting and gel coating is not allowed. Ms. 

Strum added that a 12-month rolling average option (for open molding) is being considered to add 

flexibility. 

Mr. Olsen asked for an explanation ofthe difference between "setting" and "calculating" the 

MACT floor. Ms. Koman stated that the MACT floors are calculated during the rule making process, 

and that the decisions are set when the Federal Register proposal notice is signed by the 

Administrator. Ms. Koman added that comments are taken after the proposal in the Federal Register, 

and that changes may be made as a result ofthe comments. After the comment period, the rule is 

promulgated in the Federal Register. Mr. Olsen inquired as to when facilities must comply with the 

limits in the rule. Ms. Koman stated that facilities are not required to comply with the MACT 

standard until after the final rule is promulgated. Mr. Olsen asked when the rule would be proposed. 

Ms. Strum replied the rule should be proposed during November 1999. Ms. Elmore stated that the 

current MACT floors represent the data that EPA has gathered through surveys and that attendees 

are welcome to offer data that they feel might aid in the setting ofthe MACT floors. 

Open Molding Source Approach - Existing 

Mr. Spaulding asked what EPA is considering for the definition of corrosion resistance. Ms. 

Strum stated that the EPA has not developed a definition at this time. Ms. Strum added that both the 

EPA and CFA have suggested definitions to one another, but no definition has been acceptable at this 

point. 
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Madeleine Strum 

October 2, 1998 

Page 4 

Mr. Multanen asked about processes that are not listed, such as resin pouring. Ms. Strum 

stated that pouring into an open mold would be considered manual open molding. Mr. Multanen 

expressed concern that any definition not explicitly worded in the rule could be misinterpreted by 

inspectors. Ms. Elmore suggested putting concerns and suggestions into writing and submitting them 

through the trade association. Ms. Elmore added that EPA needs written documentation to properly 

take concems into consideration. Mr. Kensington stated that definitions written by people unfamiliar 

with the industry may not be accurate, so the chance to give feedback about the definitions would be 

beneficial. Mr. Colyer stated that EPA is concerned about proper definitions as well, and that 

suggestions about clarifying definitions would be helpful. Mr. Miles asked if the rule could be 

modified or clarified after the final rule was promulgated. Mr. Colyer replied that questions on 

applicability or interpretation are sent to EPA Regional Offices first for a ruling and then to EPA 

Headquarters, if necessary. Ms. Koman stated that some issues can be handled by published 

guidance materials and others by technical rule revisions. Ms. Meyer indicated that definitions can 

still be clarified after the rule is promulgated, but changes are preferable before promulgation. 

Mr. McNally expressed his strong concern regarding EPA's decision to include adhesives in 

the Plastic Parts Surface Coatings MACT Standard rather than the Reinforced Plastics MACT 

Standard. Mr. McNally continued by stating that the removal of adhesives from the scope of the 

Reinforced Plastics Composites MACT is problematic for the industry. Ms. Teal indicated that the 

EPA group addressing the issue is still collecting data and has not yet made a final decision on which 

MACT standard should address adhesives. Several EPA representatives stated that information is 

being collected and suggestions would be welcome. Mr. McNally indicated that no written comments 

were necessary and the EPA should "just do it." Mr. Miles indicated that this issue is an important 

one because adhesives are being used more and more in the reinforced plastics industry. Ms. Strum 

asked how adhesives are applied. Mr. Miles stated that the adhesives are applied using either manual 

or mechanical resin application. Mr. Miles added that the more effective adhesives generally contain 

methyl methacrylate. Ms. Elmore suggested that one possible way to address adhesives is to create 

a separate subcategory for adhesives in the same way that EPA has created a separate subcategory 

for cleaning materials. 

Mr. Holtzclaw indicated that most adhesives are resins in paste form and inquired as to the 

difference between a resin paste and a resin. Mr. Miles stated that one difference is that a resin paste 

is significantly more viscous than a resin in liquid form. Mr. Hood expressed his concern that there 

may be differences in the way that an inspector and a facility define the difference between a resin and 

an adhesive which could lead to compliance problems for the facility. Mr. Miles stated that it would 

be undesirable for a facility to have to comply with another MACT standard simply because the 

facility used adhesives. Mr. Hood stated that complying with a separate MACT standard for 

adhesives would result in an inordinate amount of extra work for a facility that only uses a couple of 

tubes of adhesives a year. 
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Madeleine Strum 

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Point Value System 

Ms. Strum explained the point value system being considered for open molding. Ms. Strum 

pointed out that the system is not a standard emission limit or an emission factor. Ms. Strum 

explained that the goal ofthe system is to reflect the overall effectiveness of control methods. Ms. 

Strum continued by stating that averaging is allowed within the 10 open molding process groupings 

and that an effectiveness test for vapor suppressed resins is still being developed with the aid of CFA 

representatives. 

Compliance Options 

Ms. Strum stated that the options for compliance include lower HAP content resins, nonatomized applications, add-on control devices, vapor suppressed resins, and vacuum bagging. Mr. 

McNally asked Ms. Strum where she had personally witnessed the vacuum bagging process. Ms. 

Strum indicated that she had witnessed vacuum bagging at a boat manufacturing facility. Mr. 

McNally asked if Ms. Strum had witnessed vacuum bagging at a facility that is part ofthe Reinforced 

Plastics source category. Ms. Strum responded in the negative but added that EPA representatives 

have called facilities in the Reinforced Plastics source category to collect information about the 

vacuum bagging process. Mr. McNally asked for an example of a product created with vacuum 

bagging where the vacuum bag is applied immediately after resin application. Mr. Miles provided an 

example of recreational vehicle sidewall manufacturing where the vacuum bag is applied shortly after 

resin application. Mr. McNally stated that he did not know of too many applications where the bag 

is applied immediately after the resin is applied to the mold. Mr. McNally continued by stating that 

usually bleeder materials are applied first, then the bag. Mr. McNally indicated that he would like to 

know exactly how the EPA is defining vacuum bagging. Mr. Miles asked Ms. Strum if EPA's 

definition of vacuum bagging included the placement of bleeder material prior to the application of 

the bag. Ms. Strum responded in the affirmative. 

Mr. Holtzclaw stated that vacuum bagging is a process, not a control technology. Mr. Miles 

replied that vacuum bagging could be considered a control technology because it does result in 

closing the mold after the application ofresin. Mr. McNally stated that vacuum bagging is done for 

reasons other than reducing emissions. Mr. Miles stated that a facility should receive credit for using 

vacuum bagging even if it was originally intended for purposes other than emission control. Mr. 

McNally inquired whether or not applying a vacuum was necessary to obtain credit. Ms. Proctor 

indicated that the successful application ofa vacuum would provide assurance that a complete seal 

was achieved. Mr. Spaulding asked how a resin is distributed with vacuum bagging and whether rollout is allowed within the EPA's definition of vacuum bagging. Ms. Strum indicated that the EPA did 

not want to assign the same level of credit for vacuum bagging which would be done after roll-out 

as vacuum bagging which would be done without roll-out. Ms. Strum continued by stating that the 

45% reduction credit presently being assigned to vacuum bagging is for vacuum bagging without roll-
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Madeleine Strum 

October 2, 1998 

Page 6 

out. Mr. Holtzclaw stated that the application ofa film to the mold (after resin application and rollout) may represent a potential control technology missed by the EPA. Several attendees stated that 

they covered the filament wound part with a bag after filament winding and stated that this was an 

emission reduction technique that should be considered in the point value system. Ms. Proctor asked 

how the EPA would assign an emission reduction credit to such a control technology without any 

data. Mr. Hood stated that since the applied film can block HAP emissions from escaping, the credit 

assigned to such a control technique should be similar to the credit assigned to vacuum bagging. Mr. 

Holtzclaw stated that the emission reduction credit should be similar to vapor suppressed resins. 

Mr. Schweitzer stated that he did not believe that any companies are successfully using vapor 

suppressed resins in corrosion resistant applications requiring secondary bonding. Mr. Schweitzer 

added that when making a corrosion resistant product, secondary bonding problems often prohibit 

the usage of vapor suppressed resins. Several attendees expressed concern that the point values for 

the corrosion resistant subcategories are low enough to force companies to use vapor suppressed 

resins to comply with the standard which could cause secondary bonding problems. Ms. Proctor 

indicated that facilities in the corrosion groupings do not have to use VSR and that there are no 

facilities within the MACT floor that are using VSR. Mr. Kensington asked about the origin ofthe 

vapor suppressed resin effectiveness numbers. Ms. Strum stated that the 35% effectiveness credit 

for unfilled resins came from test data and that tests of filled resin systems indicate that suppressants 

in filled systems are generally ineffective. Ms. Strum added that the standard would require case by 

case testing to determine the effectiveness ofthe vapor suppressants used by individual facilities. Mr. 

McNally questioned the effectiveness of vapor suppressants in reducing methyl methacrylate 

emissions. Mr. Holtzclaw stated that due to secondary bonding issues, corrosion resistant tanks and 

fittings often have to be made from the same material, making mixing parts made from higher and 

lower HAP resins impossible. Mr. Olsen suggested that EPA put an asterisk on the maximum point 

value for mechanical application and note that the point value also applies to all secondary parts and 

to attaching secondary parts to the primary part, where the primary part is made by mechanical 

application. Ms. Strum indicated that the facilities in the floor for manual operations are also doing 

secondary bonding and so there is no reason to separate out secondary bonding applications. She 

added that she did not understand the issue since there were facilities in the floor for manual 

operations that conduct secondary bonding. Ms. Koman stated that a small group of people should 

look into the secondary bonding issue further. Persons indicating they would participate included: 

John Schweitzer, Bill Holtzclaw, Dan Boyd, and Neil Olsen. 

Mr. Kensington stated that he believed that the data for facilities setting the corrosion resistant 

floor were incorrect and that EPA needed to visit these facilities. EPA explained that the facilities 

confirmed the data in writing. Mr. Schweitzer also stated that he believed the data in the database 

were wrong. After additional discussion, it was agreed that EPA would send the CFA the copies of 

contact reports for companies setting the MACT floor so that CFA could review the information. 
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Madeleine Strum 

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Mr. DeBusk asked why there is a difference in the point value limit for filled and unfilled 

mechanical resin application. Ms. Strum indicated that non-atomized application (pressure-fed 

rollers, flow-coaters) was not considered a viable control option for filled resin systems and therefore 

the EPA decided to separate unfilled and filled mechanical resin application. Ms. Strum added that 

tests done both by CFA and elsewhere have shown that the effectiveness of vapor suppressants are 

greatly reduced in filled resins as compared to unfilled resins. Mr. DeBusk indicated that his company 

was applying a filled resin system using pressure-fed rollers. Ms. Proctor asked what type of filler 

was contained in the filled resin system applied with pressure-fed rollers. Mr. DeBusk indicated that 

the filler was aluminum trihydrate. Ms. Proctor indicated that if filled resin systems could be applied 

with non-atomized application, then it may be possible for the EPA to recombine filled and unfilled 

mechanical resin application. Mr. DeBusk inquired why the EPA had not separated filament winding 

application into filled and unfilled groupings. Ms. Proctor responded that there were very few 

facilities in the filament winding database that used filled resin systems. Mr. DeBusk responded that 

approximately 80% ofthe resin that his facility used to produce filament wound parts is filled. 

Mr. Schweitzer asked if any ofthe representatives in attendance knew if their facilities used 

styrene for cleaning purposes. Mr. Multanen answered in the affirmative, but stated that they reused 

the styrene afterwards in the fabrication process. Mr. Multanen asked if a facility reuses styrene after 

cleaning, is this use considered cleaning or part ofthe fabrication process. Mr. Schweitzer stated that 

cleaning with styrene should not be prohibited as long as the styrene is reused in the production 

process. Ms. Strum stated that the EPA would need to address this issue. 

Mr. Holtzclaw asked about the proposed requirement for mixers to be completely covered 

with no visible gaps around the mixing shaft. Mr. Holtzclaw stated that resins were often mixed in 

55 gallon drums with the mixing shaft going through the bung hole located in the top ofthe 55-gallon 

drum. Mr. Miles indicated that a large number of gel coats are also mixed in 55 gallon drums. Mr. 

Holtzclaw asked ifthe proposed standard for mixing would allow for a visible gap around the mixing 

shaft for this type of mixing. Ms. Proctor responded in the negative and asked Mr. Holtzclaw if 

facilities could seal the mixing shaft in some way. Mr. Holtzclaw responded in the negative. Mr. 

Kensington stated that covering the mixer is good enough and that a requirement for no visible gaps 

or seals is not necessary. Mr. Spaulding asked ifthe mixing cover requirement could be changed to 

"mostly covered" or "substantially covered" or "reasonable covered". Ms. Elmore stated that those 

terms were unenforceable (due to being vague) and that any cover requirement would have to be 

expressed in enforceable terms. Mr. Spaulding asked ifthe standard could be written to allow for a 

certain maximum gap size. Ms. Strum indicated that the EPA would investigate the allowance ofa 

gap between the mixing shaft and the mixer cover. Ms. Strum asked what size gap would be needed. 

Attendees suggested allowing a two-inch gap, a one and a half inch gap, or a half inch visible gap 

around the mixer shaft, as well as determining an allowable gap as a factor ofthe diameter ofthe 

mixer shaft. Mr. DeBusk stated that filler is often added during the mixing process and inquired if 
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Madeleine Strum 

October 2, 1998 

Page 8 

the standard would allow the mixer to be open when adding filler. Ms. Proctor indicated that the 

current EPA approach would allow the mixer to be open for the purpose of adding materials. 

Mr. McNally stated that the CFA has recommended that mixing vessels with less than a 25-

gallon capacity be exempted from a mixer cover requirement. Mr. McNally then inquired ifthe EPA 

would provide a technical recommendation on how to supplant small batch mixers that have less than 

25 gallons of capacity or ifthe EPA would allow a size cutoff. Ms. Strum indicated that the EPA 

could examine whether a size cutoff for mixing vessels was warranted. Mr. Holtzclaw indicated 

manual mixing in a 5-gallon pail is a common practice in industry and inquired ifthis type of mixing 

would require a cover. Ms. Strum indicated that the EPA intended to exempt hand mixing from the 

mixing cover requirement. It was inquired whether hand mixing with a motorized device such as a 

mixing shaft on a drill motor would be exempt. Ms. Strum answered in the negative and stated that 

EPA would need to develop a definition of hand mixing. 

Mr. Holtzclaw asked if EPA's requirement for covered storage containers differentiated 

between when the material is being used and when the material is being stored. Ms. Meyer inquired 

if this was an issue that EPA needed to clarify. Mr. Multanen responded in the affirmative. Mr. 

Multanen stated that in his facility, his employees frequently use small containers of resin when 

fabricating products. Mr. Multanen asked if his employees would have to cover those containers 

whenever they set the container down. Ms. Elmore suggested that one way to address the issue 

raised by Mr. Holtzclaw and Mr. Multanen would be to set a maximum length of time that a container 

could be uncovered. Mr. Kensington asked if there was a size cutoff for the covered storage 

container requirement. Ms. Strum responded in the negative. Mr. Kensington held up a coffee cup 

and stated that there were temporary containers in use at his facility that were as small as the coffee 

cup he held in his hand. Mr. Kensington also stated that containers this small should not be subject 

to the storage container requirement. Mr. McNally indicated that it was unreasonable for the EPA 

to require covers on small storage containers. Mr. McNally continued by stating that this was 

especially true since the CFA had submitted to the EPA emissions data that indicated that HAP 

emissions from small containers were insignificant. 

Mr. Miles stated that industry needs controlled spraying in order to meet the point value limits 

required by the standard. Mr. Miles stated that testing has demonstrated that controlled spraying 

reduces emissions and that industry should be provided with incentives (in the standard) to use 

controlled spraying. Mr. Miles also indicated that controlled spraying could be made enforceable. 

Mr. Multanen inquired why controlled spraying was not considered enforceable. Ms. Strum indicated 

that the CFA controlled spraying program had been ruled unenforceable by EPA's Office of 

Enforcement. Ms. Strum added that operator training would be included as part ofthe standard as 

a required work practice, but controlled spraying would not be included as a control option in the 

point value system for open molding. Mr. Miles stated that if a facility was operating a controlled 

spraying program in a manner similar to an ISO 9000 type of quality assurance program that it should 
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Madeleine Strum 

October 2, 1998 

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be enforceable. Mr. Schweitzer stated that industry representatives should be allowed to present to 

EPA's Office of Enforcement a modified version of CFA's program of controlled spraying that is 

designed to address EPA's enforceability concerns. Ms. Meyer inquired as to when the CFA would 

have a modified proposal ready to present to the EPA, and Mr. Schweitzer stated that he would 

provide EPA with a date by September 22,1998 when the CFA would be ready to present a modified 

control spraying proposal. 

Mr. Hood raised a question about the ability of companies to meet MACT standards while 

under a government contract requiring them to use particular resins. Mr. Hood stated that the U.S. 

Military and governmental agencies often have specific requirements for resins used in fire-retardant 

applications. He gave an example of building code requirements in Los Angeles which require the 

use of fire-proof panels. He said that these panels must be manufactured from Class 1 fire retardant 

resins which have a HAP content high enough to make them difficult to use under the proposed 

MACT standards. Ms. Koman asked if a list of those required resins could be provided to EPA. Mr. 

Hood then asked about corrosion resistant and fire retardant resins being interchangeable under the 

proposed rule. Ms. Proctor stated that the current EPA approach does not consider a fire-retardant 

product or application to automatically be a corrosion resistant product or application. Mr. Hood 

stated that if these resins could be classified in the corrosion resistant product grouping, the high HAP 

content would not cause as much ofa compliance issue for facilities using the resins. 

Mr. Hood inquired about the definition of corrosion resistance. After a discussion on 

common uses of these resins and the possibility of defining corrosion resistance based on chemistry, 

Ms. Proctor stated that the definition of "corrosion resistant" needs to be defined by the application. 

Mr. Multanen stated that there are currently many applications for higher HAP corrosion resistant 

resins in non-corrosion resistant applications due to their high quality and low shrinkage. For 

example, certain sections ofthe tub and shower units produced by Mr. Multanen's company for a 

major hotel chain are produced using a corrosion resistant resin. Mr. Multanen added that changing 

to lower HAP corrosion resistant resins may not be economically feasible. Ms. Koman asked that 

such situations be documented and submitted to EPA to aid in the economic analysis. Ms. Koman 

added that any company which does not want the information to be public record can submit it as 

confidential business information. 

Mr. Miles asked about the economic impact analysis. Ms. Chappell explained the economic 

impact analysis is currently underway and stated that information that would be helpful in the costing 

process includes annual revenues, units produced, sales figures, change in sales, profit margins, and 

costs of switching materials. She stated that it would be particularly useful to know ifthe MACT 

standard would cause facilities to change their product production. Some manufacturers agreed to 

provide this information if it would be kept confidential. Ms. Chappell agreed to send a list of 

questions about needed facility information to the CFA. 
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Madeleine Strum 

October 2, 1998 

Page 10 

Mr. Spaulding indicated his belief that resins used for mold manufacturing should be grouped 

with corrosion resistant applications. He stated that because tooling gel coats were broken out 

separately from other gel coats, tooling resins should be broken out separately from other resins. Mr. 

Spaulding added that it would be unnecessary to create another process/product grouping for mold 

manufacturing. Mr. Hood stated that isophthalic resins were typically used for mold making and 

these resins required higher HAP contents. Ms. Strum asked if vinyl ester resins were ever used in 

the industry for mold manufacturing. Mr. Spaulding indicated that vinyl ester resins were 

occasionally used by the industry. Ms. Strum pointed out that data from the boat manufacturing 

industry indicated that several boat facilities use low HAP vinyl ester resins to build molds. Mr. 

Multanen stated that molds are constantly sprayed with chemicals that contain styrene (a corrosive 

chemical) and as such should be considered a corrosion-resistant application. Ms. Strum indicated 

that she did not see a difference between a boat mold being sprayed with a resin and a mold used to 

produce a non-boat product. 

Mr. DeBusk asked about the possibility of exemptions for unique products. He said that 

Appalachian Plastics developed a product with performance characteristics that can only be achieved 

with a modified acrylic resin that contains 60% HAP (mostly methyl methacrylate.) Mr. DeBusk 

stated that currently the facility is considered a minor source, but with the anticipated growth for this 

product, it could become a major source. Mr. DeBusk stated that he could currently make the unique 

product under the proposed standard by averaging in another product that uses a low HAP resin, but 

his continuing ability to do so would depend on the market for the latter product. Furthermore, Mr. 

DeBusk said that this higher HAP resin had many applications and the current requirements would 

not allow his company to grow. Mr. DeBusk stated that they currently cannot afford a control 

device. Mr. Noonan asked whether the operation utilizing the 60% by weight HAP resin was filled. 

Mr. DeBusk stated that it was highly filled. Mr. Noonan said that the problem was EPA's treatment 

of filled resins. Mr. McNally disagreed, indicating that this unique product was a good example of 

where the industry was headed and raised the question about how future products with similar issues 

would be addressed under the standard. Mr. McNally added that he felt there is no MACT floor for 

this industry. Ms. Meyer asked Mr. McNally to provide a rationale for this position. 

Many attendees expressed concern over Aker Plastics, Inc. presence in the gel coat floor 

because of their use ofa low HAP gel coat that is not applicable to products in the industry that need 

to withstand weathering. Ms. Proctor indicated that Cook carries low HAP gel coats for other 

applications, for example, marine applications. Mr. Spaulding indicated that his Cook Composites 

Representative did not recommend this low HAP gel coat. Mr. Schweitzer expressed concern over 

using information from suppliers for regulatory development. He stated that suppliers often indicate 

they have a new product before all ofthe problems have been worked out and that suppliers have had 

to pull papers they have prepared from conferences at the last minute because their product was not 

ready. Mr. Hood stated that he did not believe that the 24.3% gel coat made by Cook Composites 

was widely available to all companies. He said that his distributor does not have this gel coat. Mr. 
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Madeleine Strum 

October 2, 1998 

Page 11 

Multanen stated that some companies may have special relationships with resin and gel coat 

manufacturers and distributors which allow them to purchase a wider selection of resins and gel coats 

at a lower cost. Mr. Schweitzer stated that he believed most low HAP gel coats to still be under 

development or inaccessible to many companies. Ms. Proctor indicated that she would check back 

on the availability ofthe Cook low HAP gel coat and discuss whether the company recommends that 

the low HAP marine gel coat not be used. 

Mr. Mark Aker spoke about his experience with the low HAP gel coat. He stated that Aker 

Plastics uses more than 3,000,000 pounds per year and have been using the low HAP gel coat for two 

years. Mr. Aker continued by stating that it initially took six months to adjust to the new gel coat. 

Mr. Aker added that although the gel coat costs more per pound, less is needed to produce products, 

thus actually reducing overall production costs. Mr. Aker also stated that the application ofthis resin 

must be controlled to a thickness of 3 mils in order to be cost effective. Many attendees stated that 

they would not be able to achieve that tight ofa specification. Mr. Aker concluded by stating that 

he could not say that their low HAP gel coat would work for all companies but that he also felt that 

some companies in the industry were simply going to have to "step up to the plate" and try the new 

low HAP gel coats and resins. Mr. Naylor said that it is possible that companies that make repetitive 

products may be at an advantage when changing their gel coats to lower HAP versions. Mr. Naylor 

added that if a company makes a variety of products with different required physical properties that 

it would have to test out a wider variety of low-HAP gel coats (in order to obtain the required 

product properties) and thus could encounter additional costs or technical difficulties. Attendees 

identified this as a small business issue, noting that while a big company like Aker would have the 

technical resources to make the low HAP gel coat work, small businesses do not have resources 

needed to do this. They also noted that this was a custom product versus repetitive product issue, 

in that facilities making repetitive products would be more focused on the one product and could 

devote the resources to that product. 
P.13 

Madeleine Strum 

October 2, 1998 

Page 12 

Action Items for Industry Representatives: 

1. By September 22, will give a date by which proposal to address concerns about the controlled 

spraying compliance option will be completed. 

2. Report of industry group on secondary bonding issues during the week of September 22. 

3. Submit specific information regarding concerns and suggestions to EPA directly or 

through CFA. Helpful information includes: annual revenues, units produced, sales 

figures, change in sales, profit margins, costs of switching materials. 

4. Provide examples of government specifications or requirements for use of certain higher HAP 

resins. 

Action Items for EPA: 

1. Post meeting summary on the web. 

2. Post averaging example on the web that illustrates the averaging allowed between the 

process/product groupings ofthe open molding subcategory. After further thought, the EPA 

decided that since this example is not self-explanatory and that it would be counter 

productive to include it on the website. However, the EPA will give an averaging 

demonstration at the CFA's Annual Convention on October 23, 1998. 

3. Send contact reports to CFA. (Sent September 21, 1998) 

4. Reinvestigate controlled spraying with the Office of Enforcement and Compliance 

Assurance (OECA) when the new information is received from the CFA. 

(CFA information was sent to OECA on October 2, 1998) 

5. Explore secondary bonding issue with small group identified at meeting. (Additional 

information requested from CFA October 5, 1998) 

6. Send list of economic questions to CFA to assist EPA in economic impact analysis. 
P.M 

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