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 Aker Plastics, Inc. (304) 263-2525

Mr. Daniel Boyd Society of the Plastics Industry (SPI)/

Composites Institute (CI) (410) 827-6244

Ms. Linda Chappell EPA/OAQPS/AQSSD/ISEG (919) 541-2864

Mr. Rick Colyer EPA/OAQPS/ESD/CCPG (919) 541-5262

Mr. Allen DeBusk Appalachian Plastics, Inc. (540) 429-2581

Mr. Benny Duvall Aker Plastics, Inc. (304) 263-2525

Ms. Deborah Elmore EPA/OAQPS/ITPID/ITG (919) 541-5437

Mr. Jack Hanley Process Technologies, Inc. (219) 365-9964

Ms. Missy Henricksen Composite Fabricators Association (CFA) (703) 525-0511

Mr. Charles Hester PES . (919) 941-0333

Mr. David R. Hillis East Carolina University (252) 328-4147

Mr. William Holtzclaw Holtec, LTD representing

MFG Justin Tanks, Inc. (302) 856-3521

Mr. Michael Hood Hood Manufacturing, Inc. (714) 979-7681

Mr. Robert Jemison PES (919) 941-0333

Mr. Ken Kensington Viatec, Inc. (616) 948-3860

Ms. Patricia Koman EPA/OAQPS/ESD/CCPG (919) 541-4120

Mr. Jim Lee Palmer of Texas, Inc. (915) 523-5904

Mr. Jon Lhommedieu Altec Engineering, Inc. (219) 293-1965

Mr. George McAllister Aqua Bath, Inc. (615) 227-0017

Ms. Shawn McKee PES (919) 941-0333

Mr. Phil McMillian Frees, Inc. (318) 424-2564

Mr. Steve McNally CFA (703) 525-0511 Mr. Ken Meardon PES (919) 941-0333

Ms. Janet Meyer EPA/OAQPS/ESD/CCPG (919) 541-5254

Mr. Lowell Miles Miles Fiberglass & Plastics, Inc. (503) 775-7755

Mr. Richard Moore Arrowhead Plastic Engineering, Inc. (765) 286-0533

Mr. Gary Multanen Fiberglass Systems, Inc. (208) 342-6823PARTICIPANTS (Continued):

Mr. Mark Naylor Aker Plastics, Inc. (304) 263-2525

Mr. Jim Noonan Indiana Clean Mfg. Technology

& Safe Materials Institute (765) 463-4749

Mr. Neil Olsen Xerxes Corporation (612) 887-1821

Ms. Melanie Proctor PES (919) 941-0333

Mr. Dick Putnam Eckler Industries, Inc. (407) 269-9680

Mr. Frank Ranson The Phil Carter System, Inc.

Mr. John Schweitzer CFA (734) 622-0162

Mr. Jonathan Spaulding North End Composites, Inc. (207) 594-8821

Ms. Madeleine Strum EPA/OAQPS/ESD/CCPG (919) 541-2383

Ms. Kim Teal EPA/OAQPS/ESD/CCPG (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 if the 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 of MACT 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 of the Clean Air Act (CAA). EPA is required by the CAA to list categories of major sources of HAP and develop MACT standards for these categories. Reinforced plastics production was one of the 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 of the 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 of the 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 of the 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 of the 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.

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 concerns 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.

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 of the 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, non-atomized 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 of the 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 of resin. 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 of a vacuum would provide assurance that a complete seal was achieved. Mr. Spaulding asked how a resin is distributed with vacuum bagging and whether roll-out 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-out. Mr. Holtzclaw stated that the application of a film to the mold (after resin application and roll-out) 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 of the 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 of the 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.

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% of the resin that his facility used to produce filament wound parts is filled.

Mr. Schweitzer asked if any of the 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 of the 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 of the 55-gallon drum. Mr. Miles indicated that a large number of gel coats are also mixed in 55 gallon drums. Mr. Holtzclaw asked if the 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 if the 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 if the standard could be written to allow for a certain maximum gap size. Ms. Strum indicated that the EPA would investigate the allowance of a 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 of the diameter of the mixer shaft. Mr. DeBusk stated that filler is often added during the mixing process and inquired if 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 if the EPA would provide a technical recommendation on how to supplant small batch mixers that have less than 25 gallons of capacity or if the 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 if this 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 of the 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 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 of a 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 of the 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 if the 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.

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 of a 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 of the 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. 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 of the 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 of this 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 of a 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.

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 of the 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.

Memorandum

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