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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

59) ll-E-19 

f Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 59 of 264 
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A-S4-62 

Revised by Charlie Stanier on 3/22/95 

per comments of 

Nelson O'Neill 

Ken Bunk 

Rich Baehr 

Facility Manager 

Fountainhead Manufacturing Manager 

Production Manager, Continuous Line 

The following may be treated as ajtet^confidential document, j 

The following has been proofed for technTcahtecumoy and sensitive business information. 

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CONTACT REPORT 

From: Madeleine Strum, US EPA, OAQPS/ESD, Coatings and Consumer Products Group 

Date of Contact: February 16, 1995 

Contact: Mr. Charlie Stanier 

Company/Agency: International Paper, Decorative Products Division, Odenton Facility 

(Formerly Nevamar Corporation), Odenton, Maryland 

Telephone Number: 410 519 2094 

CONTACT SUMMARY: 

The Odenton Facility of International Paper, Decorative Products Division, was contacted to 

clarify the information on the control of styrene emissions provided by the facility in the August 

23,1993 screening survey response. 

Mr. Stanier, an Environmental Engineer to whom further questions regarding the survey should 

be addressed, explained that the legal owner and operator ofthe facility is International Paper (it 

is no longer Nevamar Corporation which was indicated in the 1993 survey). The plant employs 

between 751-1000 persons, and the number of employees associated with the reinforced 

composite plastic category operations at the plant is currently in the range of 0-100. 

The first process discussed was the continuous line used to produce solid surface plastic sheets. 

The State permit information supplied with the 1993 survey has changed slightly. The facility 

has an operating permit (02-0021) to cover all facility operations, and an air construction permit 

(02-00216-0214) specifically addressing the continuous line. 

The feed stocks into the continuous process include unsaturated polyester resin (containing no 

more than 35% by weight styrene), a proprietary volatile additive, styrene, catalyst, pigment and 

various fillers (the fillers are particulates and contain no volatile organic HAP materials). Pure 

styrene is used to dissolve the catalyst. The main HAP's emitted is styrene. The emissions 

depend on the extent of cross-linking that these monomers undergo in the curing ofthe resin 

mixture. The facility no longer uses HAP in cleaning operations (they switched from methylene 

chloride to an aqueous - type cleaning material). 

Emission points from the continuous process include: 1) emissions from the vents of storage 
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tanks, mix tanks and portable tanks (matrix storage totes) which contain HAP materials; 2) 

emissions between the dispensing mechanism and the oven on the continuous line, and 3) 

emissions from the oven (which is nitrogen blanketed). Transfer between resin storage tanks, 

mix tanks and matrix storage totes is done via closed piping; however, uncontrolled HAPs are 

emitted from the vents of weigh tanks, mix tanks, and portable tanks (emission point 1). 

Emissions from the application ofthe mix to the line (i.e., between the dispensing mechanism 

and the oven - emission point 2) are partially controlled. From the dispensing mechanism, the 

resin mixture is distributed and flattened to a desired thickness within a three foot wide ban. All 

of this area is enclosed and nitrogen blanketed, and is vented to the same control system as 

emission point 3. 

The control system for emission point 3 was designed by the engineering staff at the facility. 

Emissions are controlled primarily by condensation ofthe styrene vapors released as the resin 

mix is cured in the oven. Emissions resulting from the vapor space above the condensate 

collection tank are further controlled by sending them to a carbon filter bed. The facility has 

around 8 filter bed units ranging from 1330-1500 pounds of carbon each. A single filter bed is 

on line for about 7 days and picks up approximately 500 pounds of VOCs and water. Spent 

units are sent offsite for regeneration. The condensate, which consists of mainly of styrene and 

water, is sent offsite as hazardous waste for use in fuel blending. Measurements done on the 

inlet and outlet to the carbon filters have indicated a nearly 100% efficiency on the carbon filters. 

The capture efficiency ofthe system, i.e., the quantity of HAP emitted that is either condensed or 

absorbed by the carbon, has not been measured. The facility plans to use a mass balance to 

determine this quantity for the purpose of its Title V permit application. 

Mr. Stanier indicated that he had data on the cost ofthe carbon filter system (both capital and 

operating costs) and would be able to forward the information to us. 

The second process discussed was that associated with the shaped goods plant. This process is a 

cast polymer (cultured marble) in which a resin mixture is pumped into a partially closed mold, 

is cured and then is removed from the mold. The feed stocks that go into the resin mix include 

unsaturated polyester resin (containing no more than 35% by weight styrene), a proprietary 

volatile additive, catalyst, pigment and various fillers (the fillers are particulates and contain no 

volatile organic HAP materials). 

The emission points associated with this process are (1) vents from storage drums containing 

HAP materials, (2) mixing ofthe resin, (3) filling ofthe mold and (4) initial curing in the curing 

oven. Post curing in the second oven has negligible emissions since the material is mostly cured 

before entering the second oven. 

Mr. Stanier estimated that the largest emission points in this process are the mixing and mold 

filling operations. Mixing is done in vented closed vessels, and the filling ofthe mold is done 
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manually by an operator that directs the "faucet" containing the resin mix into a small opening of 

the mold. In 1993, the facility estimated emissions from the mixing process to be 0.2 tons per 

year, and emissions from the filling process to be 0.6 tons per year. These estimates are based, 

respectively, on a stack test from the exhaust ofthe mixing vessels, and an industrial hygiene test 

in the filling area. (Industrial hygiene tests in this area are an 8-hour sampling procedure using 

either active or passive sampling techniques.) Mr. Stanier explained that because the molds are 

nearly completely sealed (except for a small opening where they are filled), curing emissions are 

expected to be negligible. The second curing oven would have negligible emissions because the 

polymer has almost completely cured in the first oven. The primary mold release used in this 

process is water-based with silicone-derived additives. 

The third process discussed is a casting process used to make polyester particles. The particles 

are used as an input (part ofthe filler) to the previous two processes. The feed stocks that go into 

the resin mix include unsaturated polyester resin (containing no more than 35% by weight 

styrene), a proprietary volatile additive, catalyst, pigment and various fillers (the fillers are 

particulates and contain no volatile organic HAP materials). 

The emission points from this process involve the vents from the storage tanks, pre-mix tanks, 

mixer and the oven. Emissions vented from the pre-mix tanks and mixer are controlled by the 

same type of carbon filter beds used to control the emissions from the condensate tank from the 

first process (the continuous line). The oven emissions from this casting process are also 

controlled by these filter beds. Note that oven emissions are cooled down (from about 120 F to 

80 F) before they enter the filter bed. 

The fourth process listed on the survey is no longer operated (it was replaced with the continuous 

line). 

/CTY 
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fc 

Docket Mo.A„§4_52 

Category ^T- if 

The following infonnation is located 1n the confidential files of the 

Director, Emission Standards Division, Office of Air Quality Planning and 

Standards, U. S. Environmental Protection Agency, Research Triangle Park, 

North Carolina 27711. This information is confidential pending final 

determination by the Administrator and 1s not available for public inspection. 

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