p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

66) ll-E-26 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 66 of 264 
P.2 

CZJCZD CZJ 

a 

T?~g-£6 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam and Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

DATE: August 4, 1995 

L:\N308 

SUBJECT: Minutes of July 25, 1995, Meeting Between EPA and Representatives of the 

Reinforced Plastic Composites Industry 

LOCATION: The meeting was held at Reichhold Chemicals, Inc. in 

Research Triangle Park, NC, 9:30 am - 1:30 pm 

* < [TENDEES: 

Mr. Mark Bahner 

Mr. Jeffrey Best 

Mr. Nick Cray 

Mr. Nelson Douglas 

Ms. Wanita Dunston 

Mr. Tom Griffiths 

Mr. Norm Kaplan 

Ms. Ellen Lackey 

Mr. Greg LaFlam 

Mr. Eloy Martinez 

Mr. Ken Meardon 

Ms. Melanie Proctor 

Mr. Solomon Ricks 

Mr. John Schweitzer 

Ms. Madeleine Strum 

Ms. Connie Turlingta 

RTI . OC'f ; 

PES / .: 

Werner Company C£C " 

Reichhold Chemicals, Inc. ^.^r , 

EPA/ESD/CCPG ^-—- ^ 

Omega Pultrusions 

EPA/ORD 

Dow Chemical Corporation 

PES 

Dow Chemical Corporation 

PES 

PES 

EPA/EMAD/Source Characterization 

Composites Institute of the Society of the Plastics 

Industry (SPI) 

EPA/ESD/CCPG 

Reichhold Chemicals, Inc. 

PURPOSE 

The purpose of the meeting was to discuss the experimental design of the 

Pultrusion Industry Council Phase II Emission Study. The study is intended to examine 

methods of limiting exposure of wet resin to moving air streams by enclosing wet areas of 

the pultrusion machine or by employing different types of resin injection. 
P.3 

OEJGSJ EE3 

n- . . 

a Madeleine Strum 

August 4, 1995 

Page 2 

DISCUSSION 

Mr. Schweitzer from SPI acted as the coordinator for the industry's presentation 

and discussion. He introduced the subject by first summarizing results obtained from the 

Phase I emission study. These results showed that, of the operational variables studied, 

air flow through the test chamber had, by far, the largest effect on styrene emissions. Mr. 

Schweitzer described the outcome of the Phase I study as positive since air flow is a 

variable that can be changed in the production process, whereas other variables such as the 

surface area of the part or bath surface area would be impossible to change without 

interfering with product specifications. 

Mr. Schweitzer proceeded by asking for comments on the proposed experimental 

design for the Phase II study. Ms. Strum (EPA) inquired as to whether a plant air flow of 

100 ft/min used in the experimental design is representative of typical pultrusion 

operations. Mr. Griffiths (Omega Pultrusions) noted that air flow in his plant was highly 

variable. Mr. Schweitzer agreed that more information needs to be collected on this issue 

before proceeding with Phase II and volunteered to contact industry to collect this 

information. 

According to Mr. Schweitzer, Phase II is intended to follow up on the first phase 

of the study and examine reductions of styrene emissions for different scenarios in which 

exposure of wet resin to moving air is limited. Air flow around the wet area can be 

reduced by partially enclosing the wet area. However, it is not possible to completely 

enclose the wet area since openings are needed to feed glass or veil into the resin bath. 

Depending on the complexity of feeds of glass or veil and the frequency of manual 

adjustments required, the percentage of the wet area that can be covered will vary. In the 

Phase II study, the wet area will be covered 40%, 66%, and to the maximum practical 

degree in different test runs. 

Another way to reduce styrene emissions is by minimizing contact of wet resin and 

plant air by using resin injection at the preform stage or by direct die injection. In the 

preform injection process resin is pumped into a preform box as the roving is fed through 

the box. Mr. Griffiths stated that preform injection cannot be used for composites with 

complex shapes because a large amount of space is necessary to form the fibers. Direct 

die injection involves the injection of resin directly into the heated forming die. Mr. Cray 

(Werner Company) pointed out that direct die injection generally changes the properties of 

the composite to a degree that is unacceptable for products for the electrical industry. 

There are also problems with inadequate wet-out of the roving in the preform resin 

injection and direct die injection process because the roving is not worked and sheared 

enough to be wetted out completely. Mr. Griffiths added that holes as small as 28 

microns due to insufficient wet-out will cause the composite to be rejected for electrical 

applications. In addition, lack of wet-out is undesirable for all products since it interferes 
P.4 

0QH . 

O 

Madeleine Strum 

August 4, 1995 

Page 3 

with the strength, corrosion resistance, and durability of the product. 

In response to Mr. LaFlam's (PES) question about manufacturing or treating the 

roving to enhance wet-out, Mr. Douglas explained that treating the roving would be 

possible but it would be beyond the scope of the study to evaluate new technologies that 

were not yet demonstrated. 

Mr. Meardon (PES) asked that industry participants try to distinguish between 

process improvements possible for new and existing facilities when talking about 

implementation of processes reducing styrene emissions. He also asked which products 

can be produced by using preform and die injection. Mr. Schweitzer repeated that very 

large parts or parts with complex reinforcement would be difficult if not impossible to 

produce by resin injection. 

Mr. Bahner (RTI) pointed out the importance of establishing a baseline for styrene 

emissions for the pultrusion industry. According to AP-42, styrene emissions are 4-7% of 

available styrene whereas recent emission measurements for pultrusion found emissions to 

be 1.5% of available styrene. Facilities that use AP-42 to calculate their styrene emissions 

may overestimate their emissions if AP-42 is wrong. This may cause a facility to be 

classified as a major source even though the facility emits less than 10 tons of styrene per 

year. In response to Mr. Bahner, Mr. Schweitzer stated that pultrusion facilities typically 

do not have stacks and therefore sampling results may not be available and tests may be 

too difficult and expensive to conduct. Group members agreed that a review of the AP-42 

factors for pultrusion is beyond the scope of this work group. Mr. Schweitzer emphasized 

that this study was not designed to establish emission factors for the pultrusion process. 

In response to a question by Ms. Strum about the range of line speeds and the 

effect of the line speed on air flow, Mr. Griffiths explained that me line speed in a 

production environment may range from 4 inches to 8 feet per minute. Mr. Douglas 

(Reichhold Chemicals) added that emissions are not correlated with line speed. Even 

though increased line speed increases the air flow and thereby styrene emissions, it also 

increases the production rate. Increasing the production rate means that the equipment 

does not have to operate as long to reach the same output, thus reducing styrene 

emissions. 

Mr. Kaplan (EPA) asked if cooling the wet area enclosure could be used as a 

means of reducing styrene emissions. Mr. Schweitzer explained that air conditioning the 

wet area enclosure would increase air flow over the wet area, which was exactly what they 

were trying to avoid. Other cooling options like cooling coils would cause water to 

condense on the coils and drip into the resin bath, which is undesirable. 

In a discussion of the proposed experimental runs, Ms. Strum suggested the 
P.5 

CJEJEgJ (S 3 

Madeleine Strum 

August 4, 1995 

Page 4 

addition of another run without resin cover to serve as a control. Mr. Schweitzer agreed 

to add the additional run to the study. Mr. Kaplan proposed to add a run with the total 

temporary enclosure (TTE) fan shut off while running only the wet area enclosure (WAE) 

fan to determine how much styrene would be present in the total temporary enclosed area 

in the worst case scenario. Mr. Schweitzer responded that the run would not provide any 

additional information. He explained that the WAE fan will not remove 100% of the 

styrene emissions because the wet area is not completely covered and therefore styrene 

would continue to evaporate from the resin bath into the total enclosed area until an 

equilibrium is reached. Eventually, the styrene vapors in the total temporary enclosed area 

would reach dangerous levels and cause unacceptable working conditions for employees. 

Mr. Kaplan recommended that the air from the resin bath be sent to the WAE 

exhaust in the wet area enclosure experiments. Perhaps the air from the resin bath could 

be directed through the WAE enclosure with a simple L-shaped duct. Mr. Schweitzer 

replied that venting air from the resin bath as opposed to just covering it would increase 

styrene evaporation. But he promised to further investigate this issue. 

The group then went to the laboratory pultrusion line to view the intended 

experimental setup and design (the test setup was only partially constructed). Mr. Douglas 

explained how the equipment would be operated during the testing and answered questions 

about the test program, including how much of the wet area can be covered depending on 

the complexity of the product. 

The trials for the Phase U emission study are tentatively scheduled to begin on 

September 6, 1995 and are expected to last 8-9 working days. 

ACTION ITEMS 

0

 Mr. Schweitzer agreed to add another run to the test schedule, a control run with 

the wet area completely uncovered. 

0

 Mr. Schweitzer will investigate plant air flow information relative to pultrusion 

operations. 

° Mr. Schweitzer will discuss with the Pultrusion Industry Council members the 

usefulness of sending the air above the resin bath to the WAE exhaust in the wet 

area enclosure experiments.