# Presentation: 516991

## REINFORCED PLASTICCOMPOSITES NESHAPApplicability and Requirements of the Final Rule

*For Composites 2004*
- October 6, 2004
- 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 applicability
- Covered operations
- RPC/Boat manufacturing interface
- Important dates
- Synthetic minor sources
- Planned corrections and clarifications
- New or existing source determination
- General rule requirements
- Initial compliance demonstration
- Open molding compliance examples
- Frequently asked questions

## Rule information resources

- Rule web page at _[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 on this web site
- As new implementation materials are developed, they will be added
- 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_

## 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
- 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
- Existing major sources must 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

## Planned Corrections and Clarifications

- Correct three round-off errors in
-     Table 3
- CR/HS mechanical resin application emission limit should be 113 lb/ton, not 112.
- Non-CR/HS mechanical resin application emission limit should be 88 lb/ton, not 87
- Tooling gel coat emission limit should be 440 lb/ton, not 437 lb/ton
- Change the presentation of compliant resin/gel coats in Table 3
- Considering dropping the last column (it has confused both regulated sources and state and local agencies)
- Clarify that you are only required to show that individual resin and gel coats, as applied, meet their individual Table 3 HAP emissions limits in lb/ton to deem the material as compliant

## Planned Corrections and Clarifications

- Requiring facilities using the same resins for all operation compliance option in  63.5810(c) to use nonatomized mechanical resin application
- Considering changing rule to allow some materials to be compliant while others are averaged
- Clarify that an existing area source that becomes major is still an existing source

## Planned Corrections and Clarifications

- Add polymer casting and RTM to the list of operations with no requirements (but remember that co-located gel coating operations do have requirements)
- Are considering changing definition of large pultruded parts for existing sources (1000 reinforcements versus glass weight)
- Any other typos or referencing errors that we have found (if you know of any, please send them to _[barnett.keith@epa.gov](mailto:barnett.keith@epa.gov)__)_

##  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 existing sources must only meet the existing source floor
- low HAP resins and gel coats
- nonatomized application techniques
- covering open containers, mixers, resin baths
- add-on controls for continuous lamination/casting
- Existing sources with centrifugal casting and continuous lamination/casting operations that emit over 100 tpy of HAP must
- Use add-on controls for both centrifugal casting and continuous lamination/casting (95 percent control)
- Meet the same requirements as other existing sources for their other operations

## 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

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

- Change your resins and gel coats to ones that individually 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 = 87)
- 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 = 87)
- 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 46.2 percent HAP resin nonatomized application
- Filament winding is 42 percent HAP resin
- Manual is 40 percent HAP resin
- Select highest allowable resin HAP level (46.2 percent)
- Maintain a weighted average resin HAP content of 46.2 percent or less for all three operations

## 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 = 87 lb/ton
- This resin 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

## 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?
- If the filler contains a resin, that by itself, could be used to make reinforced plastic composites, then it is a filled resin.  If the filler does not contain a resin, then it is not covered, even if it contains styrene.

## Frequently Asked Questions

- What if I manually apply gel coat?
- For compliance purposes, treat the gel coat as if it were applied using atomized spray, or
- If you use some nonatomized gel coat application, treat as if you apply all manual gel coat using nonatomized spray
- Do not use equation 1.h in Table 1 for any compliance calculations
- You may (but are not required) to use equation 1.h in Table 1 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 applicability
- Covered operations
- RPC/Boat manufacturing interface
- Important  dates
- Synthetic minor sources
- Planned corrections and clarifications
- New or existing source determination
- General rule requirements
- Initial compliance demonstration
- Open molding compliance examples
- Frequently asked questions

## Other Questions?

## 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