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Fwd: Fw: Styrene & Controlled spraying program & EPA







Mike,

I work with a trade association that is also promoting P2 type solutions to
air emissions. Some of our members are now promoting our technology to the
styrene/composites problem.

In my work I come in frequent contact with the regulation writers in the EPA
and I think I know where they are coming from.

The EPA is results oriented. They want test methods that show directly the
emissions of a given industrial procedure. At times this is difficult to
achieve.

Indirect procedures leave the EPA in a very difficult position to verify that
their regulation standards are being observed. Let us take your approach, for
example. I have seen demonstrations of the laser guided spraying and it does
appear that it is capable of producing adequate coverage with a minimum of
spraying. First of all, you must demonstrate that the amount of material
sprayed (which includes the styrene) per unit part is materially reduced
under actual work conditions. This only demonstrates the potential value of
the technology.

The second step is the tough one. How will you demonstrate that, in actual
practice the styrene emissions are actually reduced.
You would like approval on the simple basis that your sprayers are trained in
this new technology. If the sprayer always sprays exactly as he was taught,
it would be fine. But what if something goes wrong with the laser guide. Will
he stop work until it has been repaired or will he continue spraying without
it in order to keep the line running?

What if he had an argument with his wife and his mind is on his marital
problems? Might he not be paying less attention to that little laser light
than required.?

It is because of possibilities of this sort that the EPA always seeks its
answers in actual emission measurements. Instead of blaming the EPA, you
might do much better in getting your technical minds working on an emission
measurement approach.

Alexander Ross, Ph.D.
Government Affairs Director
RadTech International, NA
Phone: 703-534-9313
Fax:703-533-1910
RossRadtec@AOL.com