The proposed MACT (Maximum Achievable Control Technology) standard for the Reinforced Plastics Composites (RPC) industrial group will be published in April 2000.  The final rule will be developed based on comments received on the proposed rule and will be published about  April 2001.  Mr. Keith Barnett, project officer for the USEPA offered  a preview of the MACT standard at “Composites ‘99" (the annual Composite Fabricators Association meeting) in Chicago on October 28, 1999.

Mr. Barnett presented the proposed standard and discussed relevant issues during a one hour presentation made to approximately 100 participants at the CFA Seminar.  This status report will summarize Mr. Barnett’s comments and some recommended actions for facilities subject to their MACT standard.

Ø      RPC is subdivided into twenty-three subcategories of processed/product groupings.  These subcategories are classified according to the following groupings:                               

                                    - Open molding

                                    - Centrifugal casting                                                                             

                                    - Closed molding

                                    - Continuous lamination/continuous casting

                                    - Polymer casting

                                    - Pultrusion      

                                    - SMC

                                    - Equipment cleaning

- Resin mixing/BMC

- Resin storage

Ø      The standard is expressed as a “Point Value” that is:                             

- Calculated based on resin HAP (Hazardous Air Pollutant) content and application       method or

- Work practice or equipment standard or

- A percent emission reduction.  

Ø      Point Value equations are used to calculate a facility’s point Value.   Equations are established for

                   - Atomized resin application

                                     - Non-atomized resin application

                                      - Filament winding

                                     - Centrifugal casting

                                     - Gel coat atomized application 

        Ø The following methods/control technology are incorporated into the point value                          equations allowing the facility to employ a number of techniques to reduce its point value

                                      - Reduce resin/gel coat HAP content

                                      - Convert to non-atomized application

                                      - Vacuum bagging

 - Vapor suppressed resins

 - Add-on controls (part or all of emissions).

Ø     Open molding/process groupings can average across the facility.

Ø     Existing sources will be required to comply within three years of the date of the final rule (expected to be April 2001).

Ø     New sources (sources constructed after the published date of the proposed rule, expected to be April 2000) have to comply upon start up of the new source or the effective date of the final rule, whichever is latest.

Ø     The following new sources will probably have to use add on controls to comply with the MACT standard.

                                     - Non CR (Corrosion Resistant) Mechanical Resin Application - Unfilled

                                      - Non CR Mechanical Resin Application - Filled

                                      - Manual Resin Application - Tooling

                                      - Non CR Manual Resin Application

                                      - Tooling Gel Coating

                                     - Pigmented Gel Coating

                                      - Centrifugal Casting - CR 

One comment made by Mr. Barnett caught most of the industry participants by surprise.  Mr. Barnett stated that all existing facilities that emit styrene in excess of 100 TPY (tons per year) will be required to comply with 95% capture and control emission reduction within three years of the date of the final rule.  This issue was not found in any of the information presented by Mr. Barnett, but was made verbally at the meeting.

This “point value” system is new and may take some time to understand how it will impact your facility.   The point value system proposed by USEPA should allow facilities to select a low HAP emission technology that fits their application.  A number of new technologies (flowcoating, fluid  impingement technology, and extremely low styrene content resins) are currently being tested and/or used allowing facilities to choose the technology that makes most sense for their application.  It is important that all sources affected by the proposed MACT rule become familiar with the point value system of calculating compliance with the MACT standard.  In order to assist you, the following tables and information are posted on BCA’s website.

Ø      Table 1 MACT floors and new source MACT.

Ø      Table 2.  Summary of point value equations.

Ø      An example calculation provided by USEPA.

 In addition, the following EPA website can be used as a resource for information on the RPC MACT standard.  

                                    http://www.epa.gov/tnnuatwl/coat/rein_plas.html

Given the above information, I have a few recommendations for fabricators that may be subject to the MACT standards.

Ø      Participate in the last round of negotiations as stakeholders by contacting Mr. Barnett at the USEPA.  his e-mail address is below.

                          barnett.keith@epa.gov

      It is important that any additional point value equations be proposed to Mr. Barnett. In addition, comments concerning the proposed standards should be forwarded to Mr. Barnett before the standard is proposed.  After the standard is proposed, stakeholders will have a second opportunity to propose formal comments on the proposed rule.

Ø      Any facility that is proposing to construct or modify a facility that may be subject to the new facility standards should accelerate their permitting and construction process to ensure that the permit is issued and construction begins prior to the anticipated April 2000 proposed date for publishing of the proposed rule.  If this deadline is not met, the facility will be subject to new source standards and may require additional controls to be implemented when the MACT standard is published.

Ø      If you have not already done so, survey the technology and application systems that are being proposed for low styrene emission systems.  Purdue University’s Clean Manufacturing Technology Institute (CMTI) has been working with CFA to test low styrene emission systems and is a good resource for technology information.  You may contact CMTI at the following e-mail address:

                                                noonan@ecn.purdue.edu

Ø      Begin the budgeting process to make sure that technology improvements and/or control devices required to comply with this standard are included in your long range budgets. 

 We will continue to monitor developments with this standard as they become available and if you wish to receive updates on this MACT standard, please let me know at the following e-mail address:

                                                        bcarter@bcaconsultants.com

 Bruce D. Carter  

Table 1.  MACT Floors for New and Existing Sources

 ^a Meeting this point value is assumed to require an add-on control.  The overall emission control efficiency necessary to meet this value varies from approximately 40 to 95 percent depending on the process/product grouping.

 ^b Where only a number is shown the floor is based on a point value.  WP = work practice.  EQ = equipment standard.

 ^c Based on applying a wet area enclosure or direct die injection.

Table 2.  Summary of Point Value Equations

^a The equation for vacuum bagging with roll-out would be applicable when a facility rolls out the applied resin prior to applying the vacuum bagging materials.  The equation shown for this type of application assumes that the facility starts the vacuum bagging/closed mold curing process two minutes after the end of the roll-out stage.

^b The equation for vacuum bagging without roll-out would be applicable when a facility applies the vacuum bagging materials immediately after resin application without rolling out the resin.  The equation shown for this type of application assumes that the facility starts the vacuum bagging/closed mold curing process two minutes after the end of the application (or roll-out) stage.

Example Calculation

         ·        Non-corrosion resistant unfilled resin, spray application

         ·        Existing source MACT floor is 104

         ·        Potential compliance options:

        §         37.1 percent HAP resin with flow coater application

     §         29.7 percent HAP resin with atomized application

        §         37.1 percent HAP resin with atomized application and add on controls ( 42 percent  
                          overall efficiency.

           §         Add on controls with 95 percent overall efficiency

           §         48.4 percent HAP resin with flow coater application and vacuum bagging without rollout

           §         35.7 percent HAP resin with atomized application and vacuum bagging without rollout

• VSR can be used but will be site specific