# Presentation: 516990

## RECENT CHANGES TO THE EPA MACT RULE FOR COMPOSITES MANUFACTURING

*For Composites  2005*
- September 29, 2005
- Keith Barnett, Environmental Engineer
- Office of Air Quality Planning and Standards
- Emission Standards Division
- Minerals and Inorganic Chemicals Group

## What we are covering

- Rule information resources
- Rule Changes
- Rule applicability
- Covered operations
- RPC/Boat manufacturing interface
- Important dates
- Synthetic minor sources
- New or existing source determination
- General rule requirements
- Initial compliance demonstration
- Frequently asked questions

## Rule information resources

- Rule web page is _[http://www.epa.gov/ttn/atw/rpc/rpcpg.html](http://www.epa.gov/ttn/atw/rpc/rpcpg.html)_
- Rule text and implementation materials are available
- Implementation materials are added as they are developed
- State, local, or EPA regional office for applicability and interpretation questions
- _[barnett.keith@epa.gov](mailto:barnett.keith@epa.gov)__ for questions relating to rule development_

## Rule changes

- Added the following operations to the list of operations with no requirements
- Polymer casting
- RTM
- Application of putties or polyputties
- Clarified that an existing area source that becomes major is still an existing source
- Clarified that facilities could use permit limits to demonstrate they are below 100 tpy threshold

## Rule changes

- Revised the emissions standards section to clarify when the 95 percent control requirement  applies
- Modified Table 3
- Corrected round-off errors
- Removed column of highest organic HAP contents
- Revised footnote on manually applied gel coat
- Revised footnote defining large pultruded parts (1000 reinforcement or glass weight)
- Removed the manual gel coat emission factor equation from Table 1

## Rule changes

- Rewrote options for meeting open molding and centrifugal casting standards
- Removed the term “compliant materials”
- Allow some individual materials, as applied, to be compliant, while others are averaged.
- Require facilities using the same resins for all operation compliance option to use nonatomized mechanical resin application
- Pultrusion compliance options
- Modified direct die injection and preform injection requirements
- Clarified that averaging is allowed

## Rule changes

- Corrected an error in the continuous lamination/casting equations
- Clarified compliance and reporting requirements
- Revised four definitions
- High performance gel coat
- Mixing
- Neat resin plus
- Polymer casting
- Corrected any typos or referencing errors that we found

## Applicability

- This rule applies if you:
- Manufacture reinforced plastics composites, and
- Have your facility at a major source (10 tpy of any one HAP or 25 tpy of any combination of HAP), and
- Use thermoset resins or gel coats, and
- The resins or gel coats contain styrene
- The rule does not apply if you:
- Use less than 1.2 tpy of styrene containing resins and gel coats, or
- Only perform research and development, or
- Only repair reinforced plastic composites, or
- Are an area or synthetic minor source

## Covered Operations with Requirements

- Open Molding
- Compression/injection Molding
- Centrifugal Casting
- Continuous Lamination/Casting
- SMC/BMC Manufacturing
- Pultrusion
- Mixing
- Storage
- Equipment Cleaning

## Covered operation with no requirements

- Polymer Casting
- Resin Transfer Molding (RTM)
- Application of mold sealing and release agents, putties, or polyputties
- Mold stripping and cleaning
- Repair unrelated to your manufacturing operations
- Materials that do not contain resin or gel coat
- Personal activities not part of manufacturing operations
- Prepreg materials
- Non-gel coat surface coatings
- Research and development operations

## RPC/Boat Manufacturing Interface

- The Boat Manufacturing NESHAP _only_ applies if you manufacture boat hulls or decks, or molds for boat hulls or decks
- If you are not subject to the Boat Manufacturing NESHAP, you are subject to this rule if you meet the rule applicability criteria
- If you are subject to the Boat Manufacturing NESHAP, but make parts that are not part of your boats, the non-boat operations are subject to this rule
- You may elect to place all operations under the Boat Manufacturing NESHAP if that results in equal or lower HAP emissions

## Important dates

- The final rule was published on April 21, 2003, the amendment was published on August 25, 2005
- Existing major sources must _still_ comply by April 21, 2006
- Operating new major sources should have complied by April 21, 2003, or startup, whichever was later
- New major sources under construction must comply at startup

## Synthetic Minor Sources

- If your potential to emit is above the major source threshold (10/25 tpy), you can still elect to obtain synthetic minor source status – and the NESHAP will not apply
- You must obtain and comply with Federally enforceable emission limits ensuring that actual and potential emissions are below major source thresholds
- You may use any combination of controls, reduced operating hours, and processes changes to achieve the required emission level
- You must accomplish this prior to the compliance date of April 21, 2006

##  New Source

- You commenced construction after
-      August 2, 2001, and
- When you commenced construction, there were no reinforced plastic composites operations at the facility
- The definition above would include moving an existing facility

## Existing Source

- Any source that is not new
- Existing sources are not considered new as a result of reconstruction

## Overview of Controls

- Most operations at existing sources must
- Use low HAP resins and gel coats
- Use nonatomized application techniques
- Cover open containers, mixers, resin baths
- Centrifugal casting operations at existing sources must meet a 95 percent emission reduction requirement if they emit over 100 tpy of HAP
- Continuous lamination/casting operations at existing sources
- Must meet a 95 percent emission reduction requirement if they emit over 100 tpy of HAP
- Otherwise meet a 58.5 percent emission reduction

## Overview of Controls

- New sources with HAP emissions below the 100 tpy threshold meet the same limits as existing sources
- New sources at or above the 100 tpy threshold must control the operations below by 95 percent
- Open Molding
- Centrifugal Casting
- Continuous Lamination/Casting
- Pultrusion
- SMC/BMC Manufacturing
- Mixing

## Large Parts Exemptions

- Two different large parts exemptions
- One applies only to existing pultrusion operations
- Allows pultrusion machines making large parts to substitute “air flow management” for the 60 percent emission reduction requirement
- In this exemption, a large part must have a cross sectional area of 60 inches or more and 1000 or more reinforcements

## Large Parts Exemptions

- One applies only to operations at new sources otherwise subject to the 95 percent capture and control requirements
- Large part production operations are allowed to meet the limits in Table 3, rather then 95 percent capture and control
- A large open molding part must either exceed 250 cubic feet of volume, or 50 square feet on any one side
- A large pultruded part must exceed 24 inches outside perimeter, or 350 or more reinforcements

## How Do I determine if I am above the 100 tpy HAP Emission Threshold ?

- Sum emissions from operations potentially subject to 95 percent control prior to any add-on controls (and only these operations)
- Calculate these emissions using
- Equations in Table 1
- Unified emission factors
- Other published emission factors
- Site specific factors if based on emission test data

## Work Practice Standards

- Injection/Compression Molding - Cover Charges
- Equipment Cleaning -  Cleaning materials may contain no HAP (except for closed systems, and cleaning cured resin from application equipment)
- Resin Storage - Cover storage containers
- Sheet Molding Compound – Nylon- containing film, cover resin delivery to doctor box

## Work Practice Standards

- Resin Mixing and BMC Manufacturing - Cover the mixers, keep vents closed during mixing
- Pultrusion of large parts – air flow management

## Initial Compliance Demonstration

- Emission limits - perform emission factor calculations as specified in the rule
- Work practice standards - submit a certified statement that the work practice is being performed
- Equipment standards - submit a certified statement that the equipment is in place and meet the requirements specified in the rule

## Calculating Emission Factors

- Equations are presented in Table 1 of the rule
- Resin use may be based on purchase records
- Resin HAP content may be based on MSDS or resin specification sheets
- If averaging, you must determine the amounts of resin used for each specific operation

## Example Emissions Factor Calculation

- Open molding - mechanical resin application - nonatomized - filled -noncorrosion resistant
- Resin HAP content (from MSDS) is 36 percent
- Emission factor equation from rule is
- EF = ((0.157)(%HAP)-0.0165) x 2000
- EF = ((0.157)(0.36)-0.0165) x 2000
- EF = 80
- Emission Limit is = 88 lb/ton
- This resin, as applied,  would be considered compliant
- Do not consider catalysts or promoters
- Do consider any additional monomer addition

## Frequently Asked Questions

- If I use more than 1.2 tpy of resin and gel coat (combined) am I subject to the rule?
- No, you must be a major source of HAP (i.e. area sources are not covered)
- If my emissions are less than 100 tpy am I exempt?
- Not if you are a major source

## Frequently Asked Questions 

- What resin HAP content, hours of operation, and parts do I use to calculate PTE?
- Generally you have to do a reasonable worst case analysis, but not make assumptions that would result in an impossible scenario

## Frequently Asked Questions

- Should I use the UEF equation for MMA?
- Not for purposes of complying with this rule.  If you have a gel coat with 30 percent styrene, and 5 percent MMA, then the input to the equation in Table 1 is 0.35 (30 percent plus 5 percent, expressed as a decimal).  This would include calculations to determine if you are above or below the 100 tpy threshold

## Frequently Asked Questions 

- Should I use the UEF equation for MMA when reporting emissions?
- You should use the most accurate method available for reporting emissions for Title V purposes
- Can site specific factors be used in lieu of Table 1 factors.
- Yes, if they are supported by actual facility emissions test data
- If my resins contain no styrene am I covered by the NESHAP?
- No, unless you use styrene containing gel coats

## Frequently Asked Questions 

- If I move do I become a new source?
- Yes, if the new location does not already have reinforced plastic composites operations.
- If I am an open molder below the 100 tpy emission level and move (becoming a new source), and several years after the move my emissions increase above 100 tpy, do the 95 percent capture and control requirements apply?
- Yes

## Frequently Asked Questions 

- How do I know if my materials are resins, and/or thermoset resins?
- We do not define “resin” and “thermoset resin” in the rule.  If you have questions on your materials, ask the materials supplier.
- I use a putty-like filler, is this covered?
- No.

## Frequently Asked Questions

- What if I manually apply gel coat?
- If you manually apply only, or you use manual and atomized spray application, treat the gel coat as if it were applied using atomized spray
- If you use only manual gel coat and nonatomized gel coat application, treat as if you apply all manual gel coat using nonatomized spray
- If you do manual, atomized, and nonatomized gel coat application, treatment will vary
- We removed the equation for manual gel coat in Table 1
- Use the most accurate method available for purposes of semi-annual emissions reporting

## Frequently Asked Questions

- If I build a new building next to my current building, does the new building become a new source?
- The best source to answer these questions is your permitting authority because the decision may rest on site specific factors.
- My gel coat contains alpha-methyl styrene.  Should the percentage of this chemical be added to the styrene content?
- No, alpha-methyl styrene is not a HAP.

## What we covered

- Rule information resources
- Rule changes
- Rule applicability
- Covered operations
- RPC/Boat manufacturing interface
- Important  dates
- Synthetic minor sources
- New or existing source determination
- General rule requirements
- Initial compliance demonstration
- Frequently asked questions

## Other Questions?

## Meeting P2 StandardsOpen Molding and Centrifugal Casting Option 1

- Change your resins and gel coats to ones that, as applied, meet the appropriate emission limits
- This is the simplest method and results in the least reporting and record keeping

## Meeting P2 StandardsOption 1 Example

- Prior to MACT
- Atomized application of 45 percent HAP noncorrosion resistant filled resin (EF = 283, EL = 88)
- Atomized application of a 35 percent HAP white gel coat
-     (EF = 335, EL = 267)
- After MACT
- Nonatomized application of 35 percent HAP noncorrosion resistant filled resin (EF = 77, EL = 88)
- Atomized application of 30 percent HAP white gel coat or nonatomized application of 40.8 percent HAP white gel coat (EF = 267, EL = 267)

## Meeting P2 StandardsOpen Molding and Centrifugal Casting Option 2

- Change your resins and gel coats so the weighted average emission factor is less than or equal to the weighted average emission limit
- Requires purchase records by resin type, and monthly average calculation
- Average is based on last 12 months of operation

## Meeting P2 StandardsOption 2 Example

- Prior to MACT
- Currently use two corrosion resistant resins, one 42 percent HAP and one 55 percent HAP
- nonatomized mechanical application
- ratio of resin use is 60/40            (average EF = 115, EL = 112)
- After MACT
- Replace 55 percent HAP resin with resin containing 52 percent HAP
- maintain same 60/40 split          (average EF = 111.4, EL = 112)

## Meeting P2 StandardsOpen Molding and Centrifugal Casting Option 3

- Determine the highest resin HAP content allowable for each operation
- Use this resin for all operations
- Can not include gel coats or mix corrosion and noncorrosion resistant operations

## Meeting P2 StandardsOption 3 Example Prior to MACT

- Making corrosion resistant tanks
- Using atomized mechanical (end caps), filament winding (body), and manual application (joining parts)
- Using 50 percent HAP resin

## Meeting P2 StandardsOption 3 Example After MACT

- Determine MACT for each operation
- Mechanical is 46.4 percent HAP resin nonatomized application
- Filament winding is 42 percent HAP resin
- Manual is 40 percent HAP resin
- Select highest allowable resin HAP level (46.4 percent)
- Maintain a weighted average resin HAP content of 46.4 percent or less for all three operations

## How do I demonstrate Initial Compliance for add-on controls?

- If you are using add-on controls, you must perform a compliance test prior to the compliance date (or within 180 days after startup if a new source)
- Performance tests methods are EPA Method 18, 25, 25A
- The PTE must be certified using EPA Method 204
- If the PTE does not meet 204 criteria, you must test for capture using EPA Methods 204B-204E

## How Do I Demonstrate Initial Compliance for a PTE?

- Determine the equivalent diameters of all NDO and exhausts
- Determine the equivalent diameters of all NDO from HAP emission points and exhausts from NDO (must be at least four)
- Measure PTE surface area (AT) and NDO surface area (AN).  The ratio of AT/AN must 0.05 or less.

## How Do I Demonstrate Initial Compliance for a PTE (Con’t)?

- Measure all exhaust flows (QO) and all forced makeup air flows (QI) using EPA Method 2.
- Calculate the average NDO facial velocity as  FV= (QO - QI)/AN
- FV must be 200 fpm or more; or
- measure pressure differential across enclosure
- differential must be 0.007 inches of water or more

## How Do I Demonstrate Initial Compliance for a PTE (Con’t)?

- Verify direction of flow is inward for all NDO using streamers, smoke tubes, or tracer gases
- If FV is 500 or more, inward flow verification is not required