p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

7) ll-B-2 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:10 AM Sheet 7 of 57 
P.2 

nnE3 c D 

1 

O PACIFIC ENVIRONMENTAt SERVICES, INC. 

r v ^94-5' 

r. "'.< ^-3-2 

Central ParK West 

5001 South Miami Boulevard 

PO Box 12077 

Research Triangle Park. NC 27709-2077 

(919)941-0333 FAX 1919) 941-0234 

DATE: 

SUBJECT: 

September 9, 

L:\N027 

1993 

FROM: 

TO: 

Site Visit Report -- VIATEC - Hastings Engineered Systems 

Hastings, Michigan 

EPA Contract 68D10116; ESD Project 93/58 

PES Project No. N027 

Dean Carroll ~Vr£ > 

Pacific Environmental Services, Inc. (PES) 

Ms. Madeleine Strum 

ESD/CPB (MD-13) 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

I. Purpose 

I J I li W I! 

OCT I 91995 :: t 

ffl 

The purpose of the visit was to observe a resin filament winding 

composites fabrication process and to obtain information about the processes, 

emissions, and any control measures. This information will be used in the 

development of a MACT standard (NESHAP) for the reinforced plastic composites 

production source category. 

II. Place and Date 

VIATEC - Hastings Engineered Systems 

1220 West State Street 

Hastings, Michigan 49058 

VIATEC - Process/Storage Systems 

500 Reed Street 

P.O. Box 99 

Belding, Michigan 48809 

July 14, 1993 9:00 a.m. - 3:00 p.m. 

WASHINGTON. D.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH 
P.3 

/ ' 

0 £?£3JD @S£) 

C; O 

III. Attendees 

VIATEC 

Mr. Ken Kensington, President, CEO 

Mr. Ron Timmer, General Manager - Belding 

Pacific Environmental Services. Inc. 

Mr. Dean Carroll, Environmental Engineer 

IV. Discussion 

The visit began in Mr. Kensington's office in Hastings with Mr. 

Kensington and Mr. Carroll. A discussion was held from 9:00 to 11:00 am, and 

was followed by a tour of the Hastings facility. At 12:15 pm, we travelled to 

the Belding facility (45 minutes away) to view filament winding operations and 

to have a final discussion (1:00 - 3:00 pm). Mr. Kensington stated that no 

topics or material would be classified as confidential business information. 

He also offered to take photographs of several products and processes, and to 

send the pictures to PES. These pictures are in the project file at PES. 

A. Overview of VIATEC Operations 

The VIATEC Corporation is made up of three production facilities; one in 

Hastings, MI, one in Belding, MI, and one in Charlevoix, MI. The Hastings 

facility opened in 1964 under the name Hastings Reinforced Plastics, and 

became VIATEC - Hastings Engineered Systems in 1991. The Belding facility 

began filament winding in 1962 and was bought by VIATEC in 1986. The 

Charlevoix facility produces only stainless steel tanks and handling equipment 

and therefore appears to be exempt from any potential composites NESHAP. 

VIATEC headquarters are in Hastings, MI. Current composites production 

employment is about 110 employees (Hastings and Belding), with 75 percent 

involved in direct labor and 25 percent overhead. The 1992 employment was 

also 110. Operating hours at Hastings are 9 hours/day, 4 days/week, and 4 

hours on Friday. The Belding facility operates 8 hours/day, 5 days/week, with 

four people on second shift. 

The Hastings plant produces custom corrosion resistant products. Most 

products are produced only once at the plant; repeat orders for the same 

product are rare. On the other hand, the Belding plant consistently produces 

the same product. Their product lines include storage vessels, process 

vessels, tank linings, pipes and fittings, VOC control equipment parts, and 

vent stacks. The majority of VIATECs products are for industrial use, such 

as chemical processing, food and pharmaceutical, pulp and paper, iron and 

steel, and wastewater treatment systems. All of VIATEC's production methods 

are categorized as "open molding" processes. Typical vessels include the 

storage of vinegar, pickles, or wastewater. 
P.4 

EJ ©Eg? . 

C=3ES7C 

a 

B. Production Process 

In the Hastings facility, the production processes involve hand lay-up, 

spray-up, and filament winding. Currently, about 60 percent is hand/spray 

layup and 40 percent is filament winding. The hand/spray layup process 

utilizes a forming mold, a mold release agent, different polyester resins, a 

catalyst, and fiberglass reinforcing material. Gel coats are not used by 

VIATEC. The catalyst is only added just prior to the resin application, which 

prevents uncontrolled catalization (scrap). The mold is first "wetted-out" by 

putting down a surfacing veil (fiberglass) and pouring resin over it. This 

layer is 90 percent resin and 10 percent glass, and protects against cracks or 

pits on the surface of the part. The layer is rolled out by hand (using about 

a 4-inch roller) to remove any air bubbles. Finally, two layers of resin and 

glass are applied by either hand lay-up or spray-up. These layers are 75 

percent resin and 25 percent glass, the glass being VA ounce per square foot 

of chopped strand mat. The gel time for all three layers is 18 to 25 minutes. 

The gel time is the time involved until the resin takes on solid 

characteristics (becomes jelly-like), but is not yet dry and hard. The total 

cure time for the final product can be 8 to 24 hours, depending on humidity, 

at which time grinding and cutting can take place. Most parts at VIATEC are 

cured at ambient temperature, although electric heating is sometimes used. 

Filament winding done at Hastings is very similar to that done at 

Belding. At Belding, filament wound products include large storage tanks and 

processing equipment (up to 16 foot diameters). The filament winding process 

begins with the wrapping of a mandrel with mylar. The mandrel is a metal core 

providing the inside diameter of the part. Large parts with diameters of 24 

inches or more have cut-outs to provide a collapsible core when retrieving the 

part or shell. The mylar allows the finished shell, tube, or pipe to slip off 

the mandrel, and is then peeled away and discarded. Once the mandrel is 

wrapped, a combination of resin and reinforced fiberglass mat is applied. 

For corrosive environments, such as wastewater treatment, HCL 

applications, or manure disposal, the first layer of resin involves a 1/8-inch 

corrosion barrier with glass reinforcement. This layer is typically 90 

percent resin and 10 percent glass. The resin-rich material provides optimum 

chemical resistance to toxic chemicals. Most vessels manufactured by VIATEC 

have both chemical and thermal resistance; thermal environments can range from 

0 to 200°F. Engineering design usually calls for 100 to 125 mils (the 1/8-

inch barrier) of corrosion resistance on the inside surface of the vessel. 

(This layer is also typical for parts wound at Hastings.) Subsequent layers 

of laminate receive a 75 percent resin, 25 percent glass application, with the 

same resin composition as the corrosion barrier. The glass applied is a 

continuous fiberglass strand roving, and at VIATEC, up to 30 strands of roving 

can be applied at one time as the carrier travels up and down the sidewall of 

the vessel. The latter layers (two laminates) make up the structural portion 

of the vessel due to the greater amount of reinforcing material. Gel times 

for each layer is 18 to 25 minutes. 
P.5 

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D 

Lay-up and winding require relatively small amounts of time compared to 

the overall production process. Vessels can be wound in 1 day, while the 

accessory parts (hoods, legs, vents, manholes, and nozzles) are time-intensive 

and may require a week or two to fabricate and attach all parts. These parts 

are also reinforced composite products and are attached by a secondary bonding 

process. Delivery time from original placement of the order is usually 6 to 8 

weeks. 

C. Emissions 

Raw materials at VIATEC include mylar, mold release agents, a catalyst, 

polyester resins, reinforcing material, and a small amount of filler. The 

mylar is a solid plastic material and has no hazardous air pollutant (HAP) 

emissions. Mold release agents include "honey wax" and piastilease; honey wax 

has no HAPs, plastilease has 1% by weight methyl ethyl ketone (MEK) according 

to the material safety data sheet (MSDS). The catalyst used at VIATEC is 

methyl ethyl ketone peroxide (MEKP), which is not a HAP. 

Up to 30 different resins are used at VIATEC; the two most widely used 

polyester resins are vinyl ester and Isophthalic polyester. About 60 percent 

of VIATEC's production uses vinyl ester and 35 percent uses isophthalic (5 

percent other). These resins are dissolved in a styrene monomer to make the 

material less viscous. The only HAP in the resins is styrene, although trace 

amounts of epichlorohydrin (0.5% by weight and a HAP) are listed on the MSDS's 

of some resins. This HAP is not known to be emitted in production at VIATEC. 

[PES discussed this compound with Reichhold Chemicals and found that it is 

used with bromide resins as a flame retardant.] VIATEC said that the resin 

was only used on one small job earlier this year and not again since. The 

resin was chosen by customer specification. Copies of 25 MSDS's were made for 

PES to review. Two of these are included as Attachment I to this report which 

show styrene contents of 48 and 50 percent by weight. Nineteen different 

resins were used in production in 1992, with styrene percentages by weight 

ranging from 37 to 55 percent; one was listed at 30-35 percent. 

An estimate of annual emissions from the Belding facility was done in 

the office of Mr. Ron Timmer, General Manager in Belding. Volumes of resin 

received per month from July 1992 to June 1993 were Identified and an annual 

total was determined. A total of 500,000 pounds of vinyl ester and 300,000 

pounds of isophthalic was calculated for this period. From this information 

and EPA's 1988 emission factors for polyester resin fabrication, PES 

calculated a total of 14 tons of annual styrene emissions from VIATEC-Belding 

operations. This calculation is shown in the appendix. 

The reinforcing material (fiberglass) has no HAP components. In regard 

to fillers, VIATEC stated that they use very little of these products to 

replace resin and reduce styrene content. One filler is antimony trioxide 

which also acts as a flame retardant and can replace 3 to 5 percent by weight 

of the resin. (Antimony compounds are on the HAP 11st.) Another filler is 

Cabosil which is not a HAP and can replace 3 percent by weight of the resin. 

Fillers are added in powder form from a holding tank. Bags are dumped 

manually Into the tank and then %-gallon buckets are used to add the filler 

into the resin as it mixes. 
P.6 

D. Control Measures 

No add-on controls are in place at VIATEC. In Hastings, there is an 

internal air make-up system rated at 17,820 cfm to dilute the air. Ceiling 

fans are used and service doors are kept open, weather permitting. The plant 

has three production areas: filament winding with a 14-foot ceiling, cutting 

and pulling with a 16-foot ceiling, and the assembly area with a 30-foot 

ceiling. 

Two filter units are in place at the Hastings facility. In the spray-up 

room, there is a wall filter (approximately 3 feet by 20 feet) running along 

the ground connected to a blower system outside the plant. This unit pulls 

the exhaust air containing styrene from the spray room and vents it to the 

atmosphere. Stack height is approximately 30 feet from the ground. The other 

filter system is connected to a grinding and sanding operation. There is a 

grating surface which allows particles to fall through and be pulled by vacuum 

through a three-part dust filter; a blower then vents the air to the 

atmosphere. Stack height is approximately 18 feet outside the wall of the 

filament winding section of the plant (14 foot interior). For Hastings, the 

distance to the nearest residence is about 1/4 mile, and in Belding, it is 

about 100 yards. Both of the facilities are in an area zoned for industrial 

property. 

No vapor suppressants have been used at VIATEC. A vapor suppressant is 

a material that can be mixed with the resin to reduce styrene emissions during 

hand or spray lay-up. After spraying, the vapor suppressant works its way to 

the top of the laminate and becomes a wax-like material. This wax layer 

inhibits the styrene from volatilizing from the wetted-out surface. VIATEC 

believes that a wax suppressant would greatly decrease product quality, 

particularly with regard to secondary bonding. The wax surface does not 

provide a good material for successive laminates to adhere to. Mr. Kensington 

mentioned that nozzles, legs, manhole covers, etc., could even separate from 

the surface of the tank. 

Low emitting styrene resins have been tested at VIATEC, without success. 

VIATEC engineers reported that these resins were "like toothpaste" and 

unacceptable for production. Mr. Kensington stated that high styrene content 

resins (50 percent) cost about $.70/lb while lower styrene content resins (36 

percent) cost about $1.50/lb. The higher the need for corrosion resistance, 

the lower the styrene content, and thus, the higher the cost. The type of 

tank environment required by the customer usually determines the design 

considerations. 

No high volume low pressure (HVLP) spray guns are in use at VIATEC. 

Shop air pressure is nominally 90 psi. In Hastings, there 1s one designated 

spray lay-up room. An airless air-assisted type Is used which prevents air 

from being entrained in the resin mix. Styrene levels inside the plant were 

estimated to be less than 10 ppm. Styrene concentrations for 1981, 1982, and 

1989 were reported to range from 3 to 24 ppm. 
P.7 

a 

Since January 1993, VIATEC has been working to develop an acetone-free 

manufacturing environment. The use of acetone for the first 6 months of 1992 

was 3,418 while acetone usage for the first 6 months of 1993 was 710. 

Replacetone, a water based emulsifier, is now used in the plants as a cleaner. 

Small amounts (4-5 gallons a day) of acetone are currently used to flush the 

air guns; however, further reductions are expected which will totally 

eliminate acetone usage. 

E. Storage and Waste 

In Hastings, two storage tanks for polyester resin are used. These day 

tanks have a capacity of 715 gallons each and contain vinyl ester. No outside 

or underground storage tanks are used at Hastings. A storage hallway had 

about 30 individual 55-gallon drums on the day of the visit. The facility has 

anywhere from 30 to 50 drums (average 2,220 gallons) on hand for production. 

In Belding, four underground storage tanks (2,000 gallons each) are 

used, all containing vinyl ester resin. One above ground tank (3,500 gallons) 

is used and holds isophthalic resin. Because of frequent use, these two 

resins are called "house resins" for this facility. Open vents exist on all 

tanks; no pressurized valves, thermal vents, or floating vents are used. No 

blanketing of tanks with nitrogen is used to reduce emissions at VIATEC. Two 

day tanks at Belding are equipped with an agitator, pump, catalyst system, 

piping, and valves for mixing and distribution. Pure styrene is kept on hand 

at both facilities. Each location uses about 2 drums (110 gallons) per year. 

There is no process water at the facility. Waste replacetone and other 

cleaners are not processed on site but go directly to the local sewer system. 

All plant water is sanitary and is discharged directly into the sewer system. 

Waste resin (leftover, wrong color) is collected in 55-gallon drums. 

These drums are classified as solid waste and are sent to an approved 

landfill. Reject and scrap parts are put in a "boneyard," which is an 

accumulation of unused parts. Sometimes a small fabricator shop may be 

interested in one of these parts and will provide VIATEC a recovered profit. 

For filament winding, part cut-offs (5 to 15 percent of cured product) are 

typical. These portions are cut up, compacted, and sent to an approved 

landfill. 

F. Summarv 

During the final discussions, Mr. Kensington made the following points 

of interest regarding the composites maximum achievable standard control 

technology (MACT) standard: 

1. The vast array of processes and facilities in the composites 

industry may pose a difficult problem for the EPA to develop the 

regulation. 

2. Housekeeping: If companies would give ample attention to plant 

housekeeping, many emissions could be reduced. 
P.8 

3. VIATEC could operate with a regulation stating that the styrene 

content for corrosion resistant production facilities to be 40 

percent by weight. 

4. Have the resin producers determine and state the bottom end for 

styrene content. This number would determine a lot of the direction 

for the standard. 

Mr. Kensington provided a VIATEC version of the site visit report (10 

pages), which is included as Attachment II to this report. Referenced in this 

report are styrene concentration levels, air permit applications, inspection 

checklists, and copies of two articles on the Composites Industry and styrene 

emissions. 

Attachments 
P.9 

Attachment I 

1 
P.10 

MATERIAL SAFETY 

DATA SHEET 

Ashland 

ASHLAND CHEMICAL, INC. 

Subsidiary 01 Ashland Oil. Inc 

P.O. BOX 2219 

COLUMBUS, OHIO 43216 

(614) 889-3333 

24-HOUR 

Emergency 

Telephone 

1(800) 274-5263 or 

1(800) ASHLAND 

000454 ticTKu HETRONn -31.1. 922 L LI vy Page: 1 

THIS MSDS COMPLIES WITH 29 CFR 1910.1200 (THE HAZARD COMMUNICATION STANDARD) 

lltl>l><tt»at)l<ll<>ltl«»>ll<>«l»><«>«>t»)<Mlt<»»l»>l>tl«»lltll»l<lllttM<)>l>tltll«lllt>Mllt>M I 

Product Name: HETRON 922 L 

VIATEC 

HASTINGS ENGINEER SYSTEMS 

P 0 BOX 340 

HASTINGS MI 49058 

03 56 006 9322000-

Data Sheet No: 0176081-006.000 

Prepared: 05/31/89 

Supersedes: 12/22/88 

ATTN: PLANT MGR./SAFETY DIR. 

PRODUCT: 566642 

INVOICE: 802964 

INVOICE DATE: 07/14/92 

TO: VIATEC 

HASTINGS ENGINEER SYSTEMS 

1220 WEST STATE STREET 

HASTINGS MI 49058 

SECTIO N I-PRODUC T IDENTIFICATIO N 

General or Generic ID: EPOXY METHACRYLATE RESIN 

DOT Hazard Classification : FLAMMABLE LIQUID (173.115) 

SECTIO N I I - COMPONENT S 

IF PRESENT. IARC, NTP AND OSHA CARCINOGENS AND CHEMICALS SUBJECT TO THE REPORTING REQUIREMENTS OF SARA TITLE III SECTION 313 ARE IDENTIFIED IN THIS SECTION. 

SEE DEFINITION PAGE FOR CLARIFICATION . 

INGREDIENT 

VINYL ESTER 

STYRENE 

CAS *: 100-42-5 

% (by WT> 

50-55 

48 

J 

50 PPM 

TLV 

50 PPM 

Note 

( D 

( 2) 

Notes: 

( 1) PEL/TLV NOT ESTABLISHED FOR THIS MATERIAL 

( 2) ACGIH /OSHA SHORT TERM EXPOSURE LIMIT (STEL) FOR STYRENE MONOMER IS 100 PPM. NIOSH RECOMMENDS A LIMIT OF 50 

PPM, 8-HOUR TWA, 100 PPM 15 MINUTE CEI LLI NG. 

THIS CHEMICAL IS SUBJECT TO THE REPORTING REQUIREMENTS OF SECTION 313 OF SARA TITLE III. 

SECTIO N I I I -PHYSICA L DAT A 

Boiling Point 

Vapor Pressure 

Specific Vapor Density 

Specific Gravit y 

Percent Volatile s 

Evaporation Rate 

Appearance 

State 

Form 

for COMPONENT 48%) 293.40 Deg F 

145.22 Deg C) 

760.00 mm Hg 

for COMPONENT( 

AIR = 1 

48%) 

\ 

1.022 -

4.50 mm Hg 

68.00 Oeg P 

20.00 Oeg C) 

3.6 

1.046 

77.00 Deg F 

25.00 Deg C) 

45-50% 

SLOWER THAN ETHER 

CLEAR AMBER COLORED LIQUIO 

LIQUID 

HOMOG SOLN 

SECTIO N IV-FIR E AN D EXPLOSIO N INFORMATIO N 

FLASH POINT 73.0 - 100.0 Deg F ( 22.8 - 37.8 Deg C) 

EXPLOSIVE LIMIT (LOWEST VALUE OF COMPONENT) LOWER - 1.1% UPPER - 6.1% 

EXTINGUISHING MEDIA: REGULAR FOAM OR WATER FOG OR CARBON DIOXIDE OR DRY CHEMICAL 

HAZARDOUS DECOMPOSITION PRODUCTS: MAY FORM TOXIC MATERIALS:. CARBON DIOXIDE AND CARBON MONOXIDE, VARIOUS 

HYDROCARBONS, ETC. 

FIREFIGHTING PROCEDURES: WEAR SELF-CONTAINED BREATHING APPARATUS WITH A FULL FACEPIECE OPERATED IN THE POSITIVE 

PRESSURE DEMAND MODE WHEN FIGHTING FIRES. 

SPECIAL FIRE & EXPLOSION HAZARDS: VAPORS ARE HEAVIER THAN AIR AND MAY TRAVEL ALONG THE GROUND OR MAY BE MOVED BY 

VENTILATION AND IGNITED BY PILOT LIGHTS, OTHER FLAMES, SPARKS. HEATERS, SMOKING, ELECTRIC MOTORS, STATIC 

DISCHARGE, OR OTHER IGNITION SOURCES AT LOCATIONS DISTANT FROM MATERIAL HANDLING POINT. 

ALL FIVE GALLON PAILS AND URGER METAL CONTAINERS INCLUDING TANK CARS AND TANK TRUCKS SHOULD BE GROUNDED 

AND/OR BONDED WHEN MATERIAL IS TRANSFERRED. 

NEVER USE WELDING OR CUTTING TORCH ON OR NEAR DRUM (EVEN EMPTY) BECAUSE PRODUCT (EVEN JUST RESIDUE) CAN 

IGNITE EXPLOSIVELY. 

POLYMERIZATION WILL TAKE PLACE UNDER FIRE CONDITIONS. IF POLYMERIZATION OCCURS IN A CLOSED CONTAINER, 

CONTINUED ON PAGE: 2 

a 
i T L 

MATERIAL SAFETY 

DATA SHEET 

Ashland 

ASHLAND CHEMICAL, INC. 

Subsidiary Ul Ashlaml Oil. Inc . 

P.O. BOX 2219 

COLUMBUS, OHIO 43216 

(614) 889-3333 

24-4330UR 

Emergency 

Tele'phone 

1(800) 274-5-263 

1(800) ASHLAND 

or 

000454 HETRON 92 2 L 

SECTIO N IV-FIR E AND EXPLOSIO N INFORMATIO N ICootiOUO d 

Page: 2 

THERE IS A POSSIBILITY IT WILL RUPTURE VIOLENTLY. COOL STORAGE CONTAINER WITH WATER, IF EXPOSED TO FIRE. 

NFPA CODES: HEALTH- 2 FLAMMABILITY- 3 REACTIVITY- 2 

SECTIO N V-HEALT H HAZAR D DATA 

PERMISSIBLE EXPOSURE LEVEL: NOT ESTABLISHED FOR PRODUCT. SEE SECTION II. 

EFFECTS OF ACUTE OVEREXPOSURE: 

EYES - CAN CAUSE SEVERE IRRITATION, REDNESS. TEARING, BLURRED VISION. 

SKIN - PROLONGED OR REPEATED CONTACT CAN CAUSE MODERATE IRRITATION. DEFATTING, DERMATITIS. 

BREATHING - EXCESSIVE INHALATION OF VAPORS CAN CAUSE NASAL AND RESPIRATORY IRRITATION. CENTRAL NERVOUS SYSTEM 

EFFECTS INCLUDING DIZZINESS. WEAKNESS, FATIGUE, NAUSEA. HEADACHE AND POSSIBLE UNCONSCIOUSNESS, AND EVEN 

DEATH. 

SWALLOWING - CAN CAUSE GASTROINTESTINAL IRRITATION. NAUSEA. VOMITING, AND DIARRHEA. 

FIRST AID: 

IF ON SKIN: THOROUGHLY WASH EXPOSED AREA WITH SOAP AND WATER. REMOVE CONTAMINATED CLOTHING. LAUNDER 

CONTAMINATED CLOTHING BEFORE RE-USE. 

IF IN EYES: FLUSH WITH LARGE AMOUNTS OF WATER, LIFTING UPPER AND LOWER LIDS OCCASIONALLY, GET MEDICAL ATTENTION. 

IF SWALLOWED: DO NOT INDUCE VOMITING, KEEP PERSON WARM, QUIET, AND GET MEDICAL ATTENTION. ASPIRATION OF MATERIAL 

INTO THE LUNGS DUE TO VOMITING CAN CAUSE CHEMICAL PNEUMONITIS WHICH CAN BE FATAL. 

IF BREATHED: IF AFFECTED. REMOVE INDIVIDUAL TO FRESH AIR. IF BREATHING IS DIFFICULT, ADMINISTER OXYGEN. IF 

BREATHING HAS STOPPED, GIVE ARTIFICIAL RESPIRATION. KEEP PERSON WARM, QUIET, AND GET MEDICAL ATTENTION. 

PRIMARY ROUTE(S) OF ENTRY: 

INHALATION, SKIN CONTACT 

EFFECTS OF CHRONIC OVEREXPOSURE: 

THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER (IARC) HAS CLASSIFIED STYRENE IN GROUP 28 (POSSIBLY CARCINOGENIC 

TO HUMANS). IHIS CLASSIFICATION IS NOT BASED ON ANY SIGNIFICANT NEW EVIDENCE THAT STYRENE MAY BE 

CARCINOGENIC, BUT RATHER ON A REVISED DEFINITION FOR GROUP 2B ANO CONSIDERATION OF NEW DATA ON STYRENE 

OXIDE. A NUMBER OF LIFETIME ANIMAL STUDIES WITH STYRENE INCLUDING THOSE CONDUCTED IN THE NCI BIOASSAY 

PROGRAM HAVE NOT SHOWN STYRENE TO BE CARCINOGENIC. 

OVEREXPOSURE TO STYRENE HAS APPARENTLY BEEN FOUND TO CAUSE THE FOLLOWING EFFECTS IN UBORATORY ANIMALS: 

ABNORMALITIES, KIDNEY DAMAGE AND LUNG DAMAGE. 

LIVER 

SECTIO N V -REACTIVIT Y DATA 

HAZARDOUS POLYMERIZATION: 

CATALYSTS. 

CAN OCCUR ~ AVOID EXPOSURE TO EXCESSIVE HEAT, PEROXIDES AND POLYMERIZATION 

STABILITY: STABLE 

INCOMPATIBILITY: AVOID CONTACT WITH:, STRONG ALKALIES, STRONG MINERAL ACIDS. 

SECTIO N VII-SPIL L OR LEAK PROCEDURES 

STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: 

SMALL SPILL: ABSORB LIQUID ON VERMICULITE, FLOOR ABSORBENT. OR OTHER ABSORBENT MATERIAL AND TRANSFER TO HOOD. 

LARGE SPILL: ELIMINATE ALL IGNITION SOURCES (FLARES, FLAMES INCLUDING PILOT LIGHTS. ELECTRICAL SPARKS). PERSONS 

NOT WEARING PROTECTIVE EQUIPMENT SHOULD BE EXCLUDED FROM AREA OF SPILL UNTIL CLEAN-UP HAS BEEN COMPLETED. 

STOP SPILL AT SOURCE. PREVENT FROM ENTERING DRAINS, SEWERS. STREAMS OR OTHER BODIES OF WATER.PREVENT FROM 

SPREADING. IF RUNOFF OCCURS. NOTIFY AUTHORITIES AS REQUIRED. PUMP OR VACUUM TRANSFER SPILLED PRODUCT TO 

CLEAN CONTAINERS FOR RECOVERY. ABSORB UNRECOVERABLE PRODUCT.TRANSFER CONTAMINATED ABSORBENT, SOIL AND 

OTHER MATERIALS TO CONTAINERS FOR DISPOSAL. 

WASTE DISPOSAL METHOD: 

SMALL SPILL: ALLOW VOLATILE PORTION TO EVAPORATE IN HOOD. ALLOW SUFFICIENT TIME FOR VAPORS TO COMPLETELY CLEAR 

HOOD DUCT WORK. DISPOSE OF REMAINING MATERIAL IN ACCORDANCE WITH APPLICABLE REGUUTIONS. 

URGE SPILL: DESTROY BY LIQUID INCINERATION IN ACCORDANCE WITH APPLICABLE REGUUTIONS. 

CONTAMINATED ABSORBENT MAY BE DEPOSITED IN A LANDFILL IN ACCORDANCE WITH LOCAL. STATE ANO FEDERAL 

REGUUTIONS. 

SECTIO N VI I I - PROTECTI VE EQUIPMEN T TO BE USED 

RESPIRATORY PROTECTION: IF WORKPLACE EXPOSURE LIMIT(S) OF PRODUCT OR ANY COMPONENT IS EXCEEDED (SEE SECTION II), 

A NIOSH/MSHA APPROVED AIR SUPPLIED RESPIRATOR IS ADVISED IN ABSENCE OF PROPER ENVIRONMENTAL CONTROL. OSHA 

REGUUTIONS ALSO PERMIT OTHER NIOSH/MSHA RESPIRATORS (NEGATIVE PRESSURE TYPE) UNDER SPECIFIEO CONDITIONS 

(SEE YOUR SAFETY EQUIPMENT SUPPLIER). ENGINEERING OR ADMINISTRATIVE CONTROLS SHOULD BE IMPLEMENTED TO 

REDUCE EXPOSURE. 

VENTILATION: PROVIDE SUFFICIENT MECHANICAL (GENERAL AND/OR LOCAL EXHAUST) VENTIUTION TO MAINTAIN EXPOSURE BELOW 

TLV(S). 

PROTECTIVE GLOVES: WEAR RESISTANT GLOVES SUCH AS:, POLYVINYL ALCOHOL 

EYE PROTECTION: CHEMICAL SPUSH GOGGLES IN COMPLIANCE WITH OSHA REGUUTIONS ARE ADVISED: HOWEVER. OSHA 

REGUUTIONS ALSO PERMIT OTHER TYPE SAFETY GLASSES. (CONSULT YOUR SAFETY EQUIPMENT SUPPLIER) 

CONTINUED ON PAGE: 3 

n 
P.12 

MATERIAL SAFETY 

DATA SHEET 

Ashland 

ASHLAND CHEMICAL, INC. 

Subsidiary 01 Ashland Oil, Inc 

P.O. BOX 2219 

COLUMBUS, OHIO 43216 

(614) 889-3333 

24-HOUR 

Emergency 

Telephone 

1(800) 274-5263 or 

1(800) ASHLAND 

000454 

SECTIO N 

HETRON 922 L 

I-PROTECT!V E EQUIPMEN T TO BE USE D (Continuo d 

Page: 3 

OTHER PROTECTIVE EQUIPMENT: NORMAL WORK CLOTHING COVERING ARMS AND LEGS. 

SECTIO N IX-SPECIA L PRECAUTION S OR OTHE R COMMENT S 

CONTAINERS OF THIS MATERIAL MAY BE HAZARDOUS WHEN EMPTIED. SINCE EMPTIED CONTAINERS RETAIN PRODUCT RESIDUES 

(VAPOR, LIQUID, AND/OR SOLID), ALL HAZARD PRECAUTIONS GIVEN IN THIS DATASHEET MUST BE OBSERVED. 

EXPOSURE TO AEROSOLS AND MISTS WHEN MATERIAL IS SPRAYED MAY PRESENT A GREATER RISK OF INJURY FROM COMPONENTS 

BECAUSE HIGHER CONCENTRATIONS ARE IN THE ATMOSPHERE THAN RESULT FROM VAPOR ALONE. PROVIDE ADEQUATE 

VENTIUTION AND IF NECESSARY, USE RESPIRATORY PROTECTION. 

THIS PRODUCT IS A CORROSION-RESISTANT MATERIAL AND IS EXEMPT FROM THE PROCESS REQUIREMENTS OF SCAQMD RULE 1162 

UNTIL JULY 1, 1992. 

SCAQMD RULE 1162 ESTABLISHES SPECIFIC PROCESS, CONTROL, HOUSEKEEPING AND RECORDKEEPING REQUIREMENTS FOR 

FABRICATION OPERATIONS USING POLYESTER RESIN MATERIALS. IT IS THE RESPONSIBILITY OF THE FABRICATOR TO 

ENSURE COMPLIANCE WITH THESE REQUIREMENTS. 

THE INFORMATION ACCUMUUTED HEREIN IS BELIEVED TO BE ACCURATE BUT IS NOT WARRANTED TO BE WHETHER ORIGINATING 

WITH THE COMPANY OR NOT. RECIPIENTS ARE ADVISED TO CONFIRM IN ADVANCE OF NEED THAT THE INFORMATION IS 

CURRENT, APPLICABLE, AND SUITABLE TO THEIR CIRCUMSTANCES. 

LAST PAGE—SEE ATTACHMENT PAGE ENCLOSED—LAST PAGE 
P.13 

MATERIAL SAFETY 

DATA SHEET 

Ashland 

ASHLAND CHEMICAL, INC. 

Subsidiary ol Ashalnd Oil, Inc. 

P.O. BOX 2219 

COLUMBUS, OHIO 43216 

(614) 889-3333 

2#MI0UR 

Emergency 

Telephone 

1(800) 274-5263 

1(800) ASHLAND or 

DEFINITIONS 

This definition page is intended for use with Material Safety Data Sheets supplied by the Ashland Chemical Company. 

Recipients of these data sheets should consult the OSHA Safety and Health Standards (29 CFR 1910). particularly 

subpart G - Occupational Health and Environmental Control, and subpart I - Personal Protective Equipment, for 

general guidance on control of potential Occupational Health and Safety Hazards. 

SECTION I 

PRODUCT IDENTIFICATION 

GENERAL OR GENERIC ID: Chemical family or product 

description. 

DOT HAZARD CLASSIFICATION: Product meets DOT 

criteria for hazards listed. 

SECTION II 

COMPONENTS 

Components are listed in this section if they present a 

physical or health hazard and are present at or above 

1% in the mixture. If a component is identified as a 

CARCINOGEN by NTP. IARC. or OSHA as of the date 

on the MSDS, it will be listed and footnoted in this 

section when present at or above 0.1 % in the producL 

Negative conclusions concerning carcinogenicity are not 

reported. Additional health information may be found in 

Section V. Components subject to the reporting 

requirements of Section 313 of SARA Title III are 

identified in the footnotes in this section, along with 

typical percentages. Other components may be listed if 

deemed appropriate. 

Exposure recommendations are for components. OSHA 

Permissible Exposure Limits (PELS) and American 

Conference of Governmental Industrial Hygienists 

(ACGIH) Threshold Limit Values (TLVs) appear on the 

line with the component identification. Other 

recommendations appear as footnotes. 

SECTION III 

PHYSICAL DATA 

BOILING POINT: Of product if known. The lowest 

value of the components is listed for mixtures. 

VAPOR PRESSURE: Of product if known. The highest 

value of the components is listed for mixtures. 

SPECIFIC VAPOR DENSITY: Compared to AIR = 1. If 

the Specific Vapor Density of a product is not known, 

the value is expressed as lighter or greater than air. 

SPECIFIC GRAVITY: Compared to WATER = 1. If 

Specific Gravity of product is not known, the value is 

expressed as less than or greater than water. 

pH: If applicable. 

PERCENT VOLATILES: Percentage of material with 

initial boiling point below 425 degrees Fahrenheit and 

vapor pressure above 0.1mm Hg at 6 8 F. 

EVAPORATION RATE: Indicated as faster or slower 

than ETHYL ETHER, unless otherwise stated. 

SECTION IV 

FIRE AND EXPLOSION DATA 

FLASH POINT: Method identified. 

EXPLOSION LIMITS: For product if known. The lowset 

value of the components is listed for mixtures. 

HAZARDOUS DECOMPOSITION PRODUCTS: Known or 

expected hazardous products resulting from heating, 

burning or other reactions. 

SECTION IV (cont) 

EXTINGUISHING MEDIA: Following 

Protection Association criteria. 

National Fire 

FIREFIGHTING PROCEDURES: Minimum equipment to 

protect firefighters from toxic products of vaporization, 

combustion or decomposition in fire situations. Other 

firefighting hazards may also be indicated. 

SPECIAL FIRE AND EXPLOSION HAZARDS: 

hazards not covered by other sections. 

States 

NFPA CODES: Hazard ratings assigned by the National 

Fire Protection Association. 

SECTION V 

HEALTH HAZARD DATA 

PERMISSIBLE EXPOSURE LIMIT: For product. 

THRESHOLD LIMIT VALUE: For producL 

EFFECTS OF ACUTE OVEREXPOSURE: Potential local 

and systemic effects due to single or short term 

overexposure lo the eyes and skin or through inhalation 

or ingestion. 

EFFECTS OF CHRONIC OVEREXPOSURE: Potential local 

and systemic effects due to repeated or long term 

overexposui e to the eyes and skin or through inhalation 

or ingestion. 

FIRST AID: Procedures to be followed when dealing 

with accidental overexposure. 

PRIMARY ROUTE OF ENTRY: Based on properties and 

expected use. 

SECTION VI ' 

REACTIVITY DATA 

HAZARDOUS POLYMERIZATION: Conditions to avoid to 

prevent hazardous polymerization resulting in a large 

release of energy. 

STABILITY: Conditions to avoid to prevent hazardous or 

violent decomposition. 

INCOMPATIBILITY: Materials and conditions to avoid to 

prevent hazardous reactions. 

SECTION VII 

SPILL OR LEAK PROCEDURES 

Reasonable precautions to be taken and methods of 

containment, clean-up and disposal. Consult federal, 

state and local regulations for accepted procedures and 

any reporting or notification requirements. 

SECTION VIII 

PROTECTIVE EOUIPMENT TO BE USED 

Protective equipment which may be needed when 

handling the product. 

SECTION IX 

SPECIAL PRECAUTIONS OR OTHER COMMENTS 

Covers any relevant points not previously mentioned. 

ADDITIONAL COMMENTS 

Containers should be either reconditioned by CERTIFIED firms or properly disposed of by APPROVED firms. Disposal of 

containers should be in accordance with applicable laws and regulations. "EMPTY" drums should not be given to 

individuals. Serious accidents have resulted from the misuse of "EMPTIED" containers (drums.pails.etc). Refer to Sections 

IV and IX. 

l l 
P.M 

MATERIAL SAFETY DATA SHEET 

REICHHOLD CHEMICALS. INC. 

Reactive Polymers Division 

800 Capitola Drive 

Research Triangle Park 

Durham. NC 27713 

Inlormatlon Tolophono No. 919-544-9225 

ALL CHEMICAL EMERGENCIES 

1-800-424-9300 

Issue Date: 03/19/90 

asacaaaaBaioBoaaaxaaBasssaisasacaaaansasssasaaiisaEsc s 

Page 

aacaaaaaBcsaaaaaoaaacaaami 

1 

IB 

SECTION I - PRODUCT IDENTIFICATION 

Product Code: 

Trade Name: 

Formerly: 

Product Class: 

CA.S. Number 

-oo»/ 

31-730-00 

ATLAC(R) 31-730-00 

At lac 580-05A 

Vinyl Eater Resin 

Mixture 

BBBBSBBBBBaBBaaBSBaaaBasBsasBBBaasBBaBBaasaBaBSBBaasBsaBBBaauaaaBBBSBBBBaBBai: 

SECTION II - INGREDIENTS 

Ingredients CAS « 

Ueight Exposure 

max. '/. Limits 

Vinyl Ester Resin 

Styrene Monomer 

Proprietary 

100-42-5 

50.0 ^yNone assigned 

50.0 • 50.0 ppm 

BBBBBBBBBBaaaBBaaBBBBaaBBBBnaaaBBaaBBBaaaBaaBBBaa CBBBBBaaMBUBSBBnaBSBBBaB B 

SECTION III - PHYSICAL DATA 

Boiling Point: 295 Deg. F. Vapor Density: Heavier than Air. 

Volatile X: 50 Specific Grav: 0.9 - 1.2 

Evap. Rate: Slower than n-Butyl Acetate.-

A earance: Amber clear liquid. Pungent odor. 

aaaaBBKKaacBSDaaaaaaiiiaaBaaaaacaaacaBaaBacaacBoaBaasaicanaaaaaaBBaasaaaaaaaaaaaaa 

SECTION IV - FIRE AND EXPLOSION HAZARD DATA 

Flammability Class: 1C Flash Point: 89 Deg. F LEL 1 .1 

-EXTINGUISHING MEDIA: 

Uater spray, foam, dry chemical, carbon dioxide or any 

Class B extinguishing agent. 

-SPECIAL FIREFIGHTING PROCEDURES: 

Firefighters and others exposed to vapors or products of 

combustion should wear self-contained breathing apparatus. 

Equipment should be thoroughly decontaminated after use. 

-UNUSUAL FIRE 4 EXPLOSION HAZARDS: 

At elevated temperatures, such as in a fire, polymerization 

may take place. If polymerization takes place in a closed 

container, there is the possibility of violent rupture of 

the container. Product vapors may form an explosive mixture 

in air. 

aBaBBBBaBBBBBaBSBBaBBaaaaaBsaaBSBaaBBBBaaaBaaaaBBBsasaBaaBBBaaaaBBaaBBB! 

SECTION V - HEALTH HAZARD DATA 

-PERMISSIBLE EXPOSURE LEVEL: 

OSHA PEL and ACGIH TLV for styrene are both 50 ppm for an 8-hour 

Time Ueighted Average (TUA). The OSHA and ACGIH Short Term 

Exposure Level (STEL) are 100 ppm for a 15-minute period. 

Exposure to styrene may exceed the STEL during a 15-minute 

(cont.) 

This inlormatlon is furnished without warranty, representation, inducement of license ol any kind, onccpl thai it is .ir.cui.ilo to the best ol NwrhrwM Opimciis l»r s ^'owii-fliti' 

or obtained irom sources boiievedby Reichhold Chemicals, inc lo bo accuiaio. and Reichhold Chemicals, Inc does not assume any iog,«i irsixmsitiiiitv loi usi< <» n'liiim-i* ut>i«> 

same Customers are encouraged lo conduct iheir own tests Bolore using any product, read its label 

K 
PA5^ 

MATERIAL SAFETY DATA SHEET 

REICHHOLD CHEMICALS, INC. 

Reactive Polymers Division 

800 Capitola Drive 

Research Triangle Park 

Durham, NC 27713 

Inlormatlon Telephone No. 919-544-9225 

ALL CHEMICAL EMERGENCIES 

1-800-424-9300 

Product Code: 31-730-00 

Issue Date: 03/19/90 Page 

SECTION V - HEALTH HAZARD DATA (cont.) 

however 

ppm. 

the average for 

-PERMISSIBLE EXPOSURE LEVEL: (cont.) 

period (no ceiling for brief exposures), 

a single STEL period must not exceed 100 

-EFFECTS OF OVEREXPOSURE: 

SKIN: Prolonged or frequent contact may cause defatting and 

dryness of the skin with resultant irritation and possible 

dermatitis. Styrene may be absorbed through the skin in toxic 

amounts. 

EYES: May cause irritation. Liquid splashes may result in more 

serious injuries. May cause lachrymation (tears). 

INHALATION: Vapors may cause mucous membrane irritation and 

upper respiratory tract discomfort. High concentrations may 

result in headache, nausea, insensibility and other central 

nervous system effects. Repeated exposure to high concentrations 

may cause liver and kidney damage. 

INGESTION: May cause gastrointestinal disturbances, pain and 

discomfort. 

-FIRST AID: 

SKIN: Uash with soap and water. 

EYES: Flush with copious amounts of water for 15 minutes. 

Seek immediate medical aid. 

INHALATION: Remove victim from exposure. If victim is unconscious, administer artificial respiration and/or oxygen as 

needed. Seek medical aid. 

INGESTION: DO NOT INDUCE VOMITING (aspiration hazard). Seek 

immediate medical aid. 

-PRIMARY ROUTE(S) OF ENTRY: 

Inhalation and Skin Absorption. 

-CARCINOGENICITY: 

The International Agency for Research on Cancer (IARC) has 

classified styrene as possibly carcinogenic to humans (class 

2B). The IARC 2B classification is not based on significant new 

evidence that styrene might be a carcinogen, but on a revised 

IARC classification scheme and new data on styrene oxide. 

BBaBBBBBBBBBaBBaassaaBaaBBaaaBasaaBBaBBsssa'BaBSBBBXBBBBBBBaaBBBaBsaaBaBaaBBaBBB 

SECTION VI - REACTIVITY DATA 

STABILITY: C 3 Unstable 

HAZARDOUS POLYMERIZATION: 

-INCOMPATIBILITY: 

Strong acids and oxidizing agents 

Cx3 Stable 

Cxi May occur C , Will not occur 

This mlormation is luinished without warranty, representation, inducement ot license Ol any kind, eicopi that H is arc\naie 10 Ihe best Ol RpirhUnlil Chomir.US Inr S knowltHKli' 

or oblamed Irom sources believed by Reichhold Chemicals Inc lo De accurate, ana Reichhold Chemicals. Inc floes nol assume any ipgal K>Ri>ons'biMy ipr us«» O' 'oii.inri* mvn 

same Customers ate encouraged lo conduct Iheir own tests Belore using any product, read ns label 

4-
P.16 

MATERIAL SAFETY DATA SHEET 

REICHHOLD CHEMICALS, INC. 

Reactive Polymers Division 

BOO Capitola Drive 

Research Triangle Park 

Durham. NC 27713 

Information Telephone No. 919-544-9225 

ALL CHEMICAL EMERGENCIES 

1-800-424-9300 

Product Code: 31-730-00 

Issue Date> 

BBBBBBBBBB a 

03/19/9 0 Page 

SBBBBBSBSaSSBSaBSSBBBBSBBBaBBBBBBBBBBBB I 

SECTION VI - REACTIVITY DATA (cont.) 

•CONDITIONS TO AVOID: 

Heat and direct sunlight. 

•HAZARDOUS DECOMPOSITION PRODUCTS: 

Heating of this material to decomposition may cause 

the emission of irritating, acrid fumes. 

I BBBBBBBBBSBBSaSSBSBBBBBSBBBBBBBBBBBBBSBSBSSBBB8SBBBBBBBBBBSaBBSSBBBBBBBBBBBBB B 

SECTION VII - SPILL OR LEAK PROCEDURES 

-STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR 8PILLED: 

Remove all sources of ignition. Ventilate area. Absorb spill 

with an absorbent material such as sawdust, vermiculite or 

sand and place in a closed container. If large spill, dike 

the area to prevent this material from-entering water systems or 

sewers. 

-UASTE DISPOSAL METHOD: 

This material has been tested and found to have a flash point 

below 140 F. If discarded, this material and containers should 

be treated as hazardous wastes based dn the characteristic of 

ignitability as defined under the federal RCRA regulations 

(40 CFR 261). Disposal of this material and its container, 

requires compliance with applicable labeling, packaging, and 

record keeping standards. Extreme care should be taken to 

ensure that it is disposed of only in a facility permitted 'for 

disposal of hazardous wastes. 

For further information, contact your state or local solid waste 

agency or the United States Environmental Protection Agency's 

RCRA hotline (1-800-424-9346 or 202-382-3000). 

BBBBBBBBBBaSaBaBSBBBSSBBBBBSBSSBBBBBSBSBBBBBSBSBaBSaSBBBaBBBSBSBBBSBBB B 

SECTION VIII - SPECIAL PROTECTION INFORMATION 

-RESPIRATORY PROTECTION: 

A canister-type respirator must be worn to prevent the inhalation of vapors or spray mists when the TLV or PEL is exceeded. 

-VENTILATION: 

General ventilation is required during normal use. 

Local ventilation may be required during certain operations 

to keep exposure levels below the TLV listed in Section II 

of this data sheet. 

-PROTECTIVE GLOVES: 

Uear appropriate impervious gloves to prevent skin contact. 

This information is furnished without warranty. iep«o%nni.-ittpn. nKjur.rnm.ni or iirrvisp ol any kmn mrppi lhat ii isar rttialc Id Hip Irpst of MPHJ»r»iiliM3hrmii\i's liv HknnwliMliti* 

nr ohtamed Irom sources helwved by Reichhold Chemicals. Inc to ho accuiaio and H^«.ii»oin Ohpmii.ai.v Inc dm", nut assump any UMI.II ipsimiiS'hiMy li.i iIS)> in >i<ii,inri> u|x>" 

samu Customers aio oncouragcd lo conduct then own tests Outore usmg any PMKIIJCI. mad its label 

19 
P.17 

MATERIAL SAFETY DATA SHEET 

REICHHOLD CHEMICALS. INC. 

Reactive Polymers Division 

600 Capitola Drive 

Research Triangle Park 

Durham, NC 27713 

Information Telephone No. 919-544-9225 

ALL CHEMICAL EMERGENCIES 

1-800-424-9300 

Product Code: 31-730-00 

Issue Date: 03/19/90 Page 4 

BBSSBBBBS!BSCBSSSSB3BSSSSBSSSBOSBBSBSSS3Ba=SSBSBS»SOBBSSBSSBBB3SSBSSWBBSSSBSBBS S 

SECTION VIII - SPECIAL PROTECTION INFORMATION (cont.) 

-EYE PROTECTION: 

Uear face shield or chemical goggles. 

-OTHER PROTECTIVE EQUIPMENT: 

Wear protective clothing to prevent skin contact. 

Eye wash station and safety shower should be available. 

BaBBBBBBBBBBBBBB8BSBSBBSSBBSBSSBBSSBSaSBBSBBaBBSBBB88SBBBBSBBBSBBSBSBBBS8SSBBS B 

SECTION IX - SPECIAL PRECAUTIONS 

-PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING: 

Avoid storage above 100 Deg. F. Avoid prolonged or repeated 

skin contact. Avoid Inhalation of heated vapors or spray mists. 

-OTHER PRECAUTIONS: 

Avoid improper addition of promoter and/or catalyst. A promoter 

and catalyst used with this product should always be mixed 

separately with the product and must never be mixed together. 

BBSSBSSBBSSBBBBBBSSSBSBBSaaBBBBSBSSBSSSBSSBBaBBSSBSBSSBSBSSBSBSBSSBBBSSBBBBSSS B 

SECTION X - SUPPLEMENTAL INFORMATION 

-REGULATORY INFORMATION: 

SCAQMD Rule 1162 establishes specific process, control, 

housekeeping, and recordkeeping requirements for fabrication 

operations using polyester resin materials. It is the 

responsibility of the fabricator to ensure compliance with ' 

these requirements. 

Styrene is NOT currently listed as a carcinogen by California's 

Safe Drinking Water and Toxic Enforcement Act of 1986 

(Proposition 65). 

-SARA STATUS: 

One or more of the chemical substances listed in section II of 

this MSDS is subject to the reporting requirements of section 

313 of the Superfund Amendments and Reauthorization Act (SARA) 

of 1986 and 40 CFR 372 

This material has been categorized as having the following 

hazard(s) as defined by SARA Title III regulations (40 CFR 370): 

acute, chronic, fire, reactive. 

-DOT PROPER SHIPPING NAME: 

Resin Solution 

-UN NUMBER: 

UN1866 

-DOT HAZARD CLASS: 

Flammable liquid 

This intormaiion is lurnished wilhoul warranty, representalion. inducement or license ol any Kina eicopi thai it is arciiialp to lhe bost ol Rwhhnkl Chpnur.Hs Inr s kiu'wipdQP 

or obtained Irom sources believed by Reichhold Chemicals Inc lo Be accurate, and Rpichhnirf Chpmicais Inr oops nm assume any 'prtal IPSIViiwhiiiiv im IISP O> n'li.mrp m>ni> 

same Customers am encouraged to conduct their own IPSIS BPIIMP usmq any pindiiri lead as label 

l <» 
P.18 

Attachment II 

n 
P.19 

ge-cj. 1-31- ?3 

l/HUec 1220 W. State Street 

Hastings, Ml 49058 

(616) 945-9578 

HASTINGS ENGINEERED SYSTEMS FAX: 616-945-2357 

Jul y 26, 1993 

Mr. Dean Carroll 

Environmental Engineer 

Pacific Environmental Services, Inc. 

Central Park West 

5001 South Miami Blvd. 

PO Box 12077 

Research Triangle Park, NC 27709-2077 

Subject: VIATEC FACILITY VISIT JULY 14, 1993 

Dear Mr. Carroll: 

First of all we at VIATEC want to thank you for spending 

the time at our facilities to better familiarize 

yourself, your Company and EPA with our different 

processes to manufacture corrosion resistant products 

from reinforced plastics composites. 

The day went rather quickly as we visited our two 

facilities, one in Hastings, Michigan and the other in 

Belding, Michigan (approximately 45-50 miles apart), 

there was a lot of questions, information gathering and 

documents exchanged. 

Listed below is hopefully a complete accounting of your 

visit, if after your review you see any errors or 

omissions, please contact me so I can correct. 

* VIATEC was given an opening interview and respond to 

verbal questionnaire. 

Continued on page 2 

Designers and Manufacturers of Corrosion Resistant Process Equipment 

18 
P.20 

Continued on page 3 

Iffitec 

HASTINGS ENGINEERED SYSTEMS 

Page 2 (continued) 

July 26, 1993 

* VIATEC waived its right to have all data and 

information held confidentially, VIATEC expressed its 

position in that they find no problem sharing within PES, 

EPA and CAMP any of the information, data, photo's and 

documents. As it helps further educate all parties in , 

Corrosion Resistant Composites, VIATEC copied REC with

 pe 

all the various product types of Corrosion Resistant 

resins they have used in their custom fabricating 

facilities in Hastings, Michigan for the year 1992, the 

results were 19 different Corrosion Resistant resins were 

used. The styrene content varied from a low of 36% by 

weight to a high of 50% by weight, styrene % figures were 

obtained from individual resin manufacturers product data 

sheets. 

* Acetone (VOC) usage data from the Hastings facility 

was submitted and copy given to P^C. />e. 

VIATEC has embarked on a "ACETONE FREE" manufacturing 

environment starting in 1993, results were 3,418 gallons 

of acetone used for the first 6 months in 1992 at the 

Hastings facilities, for the same period in 1993, 710 

gallons of acetone was used in the first 6 months, data 

was obtained from purchase order documents. 

VIATEC has a corporate goal of zero acetone usage. The 

one area where acetone is only being used is in the flush 

system of their FRP deposit resin and glass guns. 

Acetone has been replaced with water base emsulfiers, the 

second half of 1993 should show a further reduction from 

the 710 gallons. 

* Material Safety Data Sheets (MSDS) were obtained for 

the various styrenated corrosion resistant resins used by 

VIATEC,is their manufacturing process, copies were given 

to PJSC, we reviewed the different MSDS's and found the 

various levels of styrene (36% - 50%) in the corrosion 

resistant resins. 
P.21 

Page 3 (continued) 

July 26, 1993 

* VIATEC expressed to ^E£ that corrosion resistant 

resins need the higher styrene content not to lower the 

price but is necessary in its polymer chemistry to 

produce a high, corrosive resistant resin. VIATEC did 

not have the data available to show the amounts of resins 

used in its manufacturing process with respect to their 

% of styrene levels. 

* VIATEC expressed to IJEC how the actual composite 

reinforcements can effect a laminates physical 

properties, therefore it can effect the amount of 

laminate (LBS) that goes into the Corrosion Resistant 

structure. 

* Test results of styrene in the employees work place 

were reviewed and copies given to Pjlc, these were results 

of the 3M badge testing VIATEC has done over the years. 

* VIATEC's air permits as issued by the Michigan Dept. 

of Natural Resources (DNR) Air. Quality Division were 

reviewed and copies given to PEC. 

* Shop tour of VIATEC's Hastings facility was conducted, 

the following items were observed, photos were taken and 

given to PEC. 

A-H. Floor observation of a tape wound pipe section, 54" 

dia. x 10' - 0" long. (See photo A-H) 

B-H. Floor observation of a completed (ready to ship) 

one (1) piece chemical holding tank 16' - 0" dia. x 10' -

0" high. (See photo B-H) 

C-H. Floor observation of ASME-RTP-1 demonstration 

vessel, 3' - 6" x 10' - 0" high on legs. (See photo C-H) 

D-H. Floor observation of hand tape winding of a 3/4" 

dia. piece of pipe section. (See photo D-H) 

E-H. Floor observation of hand lay-up 90° elbow x 3' -

0" dia. (See photo E-H) 

Continued on page 4 

l/ialec 

HASTINGS ENGINEERED SYSTEMS 
P.22 

Page 4 (continued) 

July 26, 1993 

F-H. Floor observation of secondary bonding technique to 

a pressure vessel by shop laminator. (See photo F-H) 

G-H. Floor observation of hand lay-up flanging to three 

(3) 3' - 0" x 20' - 0" section of composite pipe. (See 

photo G-H) 

H-H. Floor observation of grinding booth where small 

parts are trimmed, ground, drilled and back faced. (See 

photo H-H) 

I-H. Visual inspection of mechanical collecting device 

(fan, filter house & stack) for grinding booth. (See 

photo I-H) 

J-H. Visual inspection of spray booth area and 

collections systems (filters, hood, fan, stack). (See 

photo J-H) 

K-H. Floor inspection of raw materials receiving area 

that shows incoming resin (55 gal. drums) and 

reinforcements (on pallets), also area where their raw 

materials are stored. (See photo K-H) 

L-H. Visual inspection of our BONE-YARD, that is 

miscellaneous outside storage area for product rejects, 

cut-off, overages and mistakes. (See photo L-H) 

M-H. Visual inspection of two (2) elevated resin tank 

storage area located in production area, 700 gallons 

capacity each. (See photo M-H) 

VIATEC described past projects that they have completed 

over the years that illustrate the large and uniqued 

shaped products they have done such as 100 foot stacks, 

shop fabricated and field installed systems, 10 foot 

diameter duct systems and fittings, PEC was given all 

available product literature that VIATEC uses in their 

promotion and sales efforts. 

After our VIATEC/Hastings visitation we than traveled to 

our VIATEC/Belding, Michigan plant where we toured our 

filament wound tank manufacturing facilities. 

Continued on page 5 

Vfflec 

HASTINGS ENGINEERED SYSTEMS 

n.\ 
P.23 

Page 5 (continued) 

July 26, 1993 

* Shop tour of VIATECs Belding facility was conducted, 

the following items were observed, photos were taken and 

given to P/lfc. 

A-B. Floor observation 12' - 0" dia. composite tank 

shell being manufacturing, included very close personnel 

observations of the actual resin, chop fibers and resin 

being applied to the 12' - 0" dia. rotating mandrel. 

(See photo A-B) 

B-B. Floor observation of resin rich surface 12' - 0" 

composite tank shell being rolled out by operators. (See 

photo B-B) 

C-B. Floor observation and inspection of our resin (day 

tanks) distribution system for our 12' - 0" dia. and 10' 

- 0" dia. production mandrels, system included tanks, 

agitators, pump, catalyst system, piping and valves. 

(See photo C-B) 

D-B. Floor observation of tank components department 

were done that illustrates the tanks bottoms and heads. 

Molds are on rotating mechanisms that are of steel 

construction, sizes are 8, 9, 10 and 12 foot diameters. 

(See photo D-B) 

E-B. Floor observation of shop personnel hand laying up 

a 8' - 0" dia. dished tank bottom to a 8 • - 0" tank 

shell, rotating mandrel. (See photo E-B) 

F-B. Floor observation and explanation of 7' - 0" dia. 

steel mandrel and how it is prepared for production. 

(See photo F-B) 

G-B. Floor observation of finished tank components - 8', 

9', 10 • and 12' heads and bottoms ready for assembly area 

and secondary bonding. (See photo G-B) 

H-B. Floor observation of a finished composite tank 5' -

0" dia. x 8' - 0" with cone bottom on legs, explained to 

BEC the exterior finish surface, why and how the exterior 

is furnished to obtain for corrosion resistant service. 

(See photo H-B) 

Continued on page 6 

Vffiec 

HASTINGS ENGINEERED SYSTEMS 

7 7 
P.24 

Page 6 (continued) 

July 26, 1993 

I-B. Floor observation of 12' - 0" tank shells and heads 

assembled on shop floor. (See photo I-B) 

J-B. Floor observation of 12' - 0" dia. x 30' x 0" shell 

on shop floor being prepared for assembly. (See photo JB) 

During our plant tours VIATEC either verbally and or 

illustrated how our mandrels and mold are prepared for 

the application of resin reinforced composites, we showed 

the mylar (polyester film) that is applied to the mandrel 

or wax that is applied to a compounded surface mold 

(heads or bottom), we showed on the shop floor how the 

parts are removed or stripped from the mandrels, the 

parting film being removed and the composite part(s) 

being trimmed or de-flashed to the assembly surfaces. 

Secondary bonding was shown on how the surfaces have to 

be properly prepared (ground) prior to any secondary 

bonding of any tank/vessel fittings, manways, lifting 

lugs, shell to head joints, shell to bottom joints, shell 

to shell joints, this was illustrated by the shop floor 

personnel performing an inside seam in a 12' - 0" dia. 

tank on the floor, the procedure of the composite 

strapping being "wet-out" with resin, the wet laminate 

being carried to the tanks manway, the transfer of the 

"wetted-out" composite strapping to another shop 

personnel inside the vessel, then the "wetted-out" strap 

being applied inside the 12' - 0" tank to an inside seam. 

At the conclusion of the visit at VIATEC's tank plant in 

Belding we all assembled together which included Ron 

Timmer - Plant Manager, Ken Kensington - CEO and Dean 

Carroll - Envir. Eng., PEC. 

Discussions took place and any questions were answered in 

addition the following documents were given to ^EC. 

* VIATEC internal document (2 pages) which details the 

manufacturing inspection events which will help assist 

PEC to better understand the seperate operations 

necessary in the manufacture of composite tanks. 

Continued on page 7 

l/iatec 

HASTINGS ENGINEERED SYSTEMS 

I.S 
P.25 

Page 7 (continued) 

July 26, 1993 

* Copy of SPI paper given Feb. 8 - 11, 1993 at National 

Conference, Composites Institute, SPI, Author Joseph S. 

McDermott, title: "Assessment of the Impact of 

Environmental Regulations on Composites Industry Markets 

and Processes". 

* Copy of SPI paper given Feb. 8-11 , 1993 at National 

Conference Composites Institute, SPI, Authors, Lisa M. 

Adkins, Kathy E. Kitchen and Danny S. Landes, title: 

"The Determination of Styrene Emissions During the Hand 

Lay-Up and Spray-Up Processes". 

In addition to our discussions we reviewed in detail the 

many Corrosion Resistant resins that are used in our 

industry as to their ranges of chemical and temperature 

resistancy depending on the customers environment. We 

discussed the relationships as to the significant cost 

ranges the resins can have as far as to chemical service 

I.E. the cost of premium grade high corrosion resistant 

vinyl-ester at $1.50/lb with 36% styrene content vs. a 

good corrosion resistant tera-thathic resin at $.70/lb 

with 50% styrene content. 

We discussed on how the clients chemical resistant 

service application if first obtained and reviewed and 

than a most cost effective resin is selected, in other 

words we don't put a $1.50/lb resin in a fabrication that 

can use a $.70/lb resin or vica versa. 

At the conclusion of our visit it was stated that if 

there were any other questions or needed information, REC 

can contact VIATEC at anytime. There was a lot of data 

and information "compressed" into a six (6) hour visit. 

On July 16, 1993 VIATEC received from PEC a telephone 

request on more information and data on the industrys 

standard 100 mil (min.) corrosion barrier, as a result of 

that telephone request VIATEC faxed their standard 

manufacturing sheet and specifications which best 

describes those construction practices, (copy attached). 

Continued on page 8 

l/Iafec 

HASVNGS ENGINEERED SYSTEMS 
P.26 

Page 8 (continued) 

July 26, 1993 

Hopefully after receipt and review of our report letter, 

EEC and the EPA feels they have gained some practical 

industry knowledge and a better understanding of the 

fabrication size issues we face, not to mention the 

worldwide competiveness that now exists. 

As earlier stated in our first and second EPA - CAMP 

meeting held in Research Triangle Park, NC on June 7 and 

June 21, 1993 VIATEC is embarked on a mission to better 

educate and assist in giving shop floor knowledge to 

anyone that will listen and try to better understand the 

corrosion resistant composites business here in America. 

As always, call if you have any questions or requests. 

Sincerely, 

Kenneth Kensington {CEO) CEO<) 

cc: file 

cc: Mr. John Schweitzer 

SPI/CI 

1441 White Street 

Ann Arbor, MI 48104 

cc: Mr. Charles R. McClaskey 

V-P Marketing 

Reactive Polymers Div. 

Reichhold Chemicals, Inc. 

PO Box 13582 

Research Triangle Park, NC 27709-3582 

cc: Mr. Bob LaCovara 

Dir. Regulatory Affairs 

Composites Fabricators Assoc. 

1735 North Lynn Street 

Suite 950 

Arlington, VA 22209-2022 

Continued on page 9 

Viatec 

HASTINGS ENGINEERED SYSTEMS 

XS> 
P.27 

Page 9 (continued) 

July 26, 1993 

cc: Mr. Steve McNally 

Dir. Govt. Affairs 

Composites Fabricators Assoc. 

1735 North Lynn Street 

Suite 950 

Arlington, VA 22209-2022 

cc: Dr. Frank Cassis 

Ashland Chemical Co. 

Composite Polymers Div. 

PO BOX 22118 

Los Angeles, CA 90022 

Enclosures: Photos 

VIATEC's 100 Mil Corrosion Barrier 

Specification Sheet 

l/iafec 

HASTINGS ENGINEERED SYSTEMS 

1 < o 
P.28 

V... 

4.0 FABRICATION 

4.1 LAMINATE-The laminate consists of an inner surface, an interior layer and an exterior 

layer or laminate body. The combination of 

the inner surface and the interior layer is 

known as the corrosion resistant barrier. 

The compositions specified for this barrier 

are intended to achieve optimum chemical 

resistance. 

4.1.1 INNER SURFACE - The inner surface shall be free of cracks and 

crazing wjth a smooth finish and 

with an average of not over 2 pits 

per square foot, providing pits are 

less than 1/8" in diameter and not 

over 1/32" deep and are covered 

with sufficient resin to avoid exposure of the veil. Some waviness 

is permissible as long as the surface is smooth and free of pits. The 

inner surface will be 10-20 mils, 

thick consisting of a resin-rich layer 

reinforced with chemical surfacing 

mat (veil). 

4.1.2 INTERIOR LAYER - A minimum of 

100 mils, of the laminate next to the 

inner surface shall be reinforced 

with approximately 30% by weight 

of chopped glass roving (see 3.9). 

The resin used is the same as used 

for the inner surface layer after the 

inner surface layer gels but before it 

cures. 

4.1.3 EXTERIOR LAYER, SIDEWALL-The 

exterior layer or body of the laminate for the sidewall portion of the 

tanks shall be composed of filament wound glass fibers (3.10) and 

resin as specified under the resin 

system (3.1). This layer consists of 

not less than 60% or more than 

70% glass by weight. Some special 

applications, with a requirement for 

a high axial strength, may have one 

or more layers of combination mat, 

or axially oriented unidirectional mat 

exterior layer. The exterior surface 

shall be relatively smooth with no 

exposed fibers or sharp projections. 

INNER 

SURFACE 

FILAMENT 

WOUND LAYER 

\ ^ w 

4.1.4 EXTERIOR LAYER, OTHER • For 

heads, bottoms, and other nonfilament wound items; the exterior 

layer or body of the laminate shall 

be a continuation of the interior 

layer (4.1.2) using the same glass 

and resin to build up to the required 

thickness. For some highly stressed 

applications, one or more layers of 

combination mat may be Incorporated in the exterior layer. The exterior surface shall be relatively 

smooth with no exposed fibers or 

sharp projections and chemically 

resistant to the intended service. 

Veil may be added to the exterior 

layer if requested. 

4.2 Minimum head and bottom thicknesses are 

in accordance with the NBS Voluntary Product Standard PS 1&69 unless otherwise 

specified. 

4.2.1 Standard tanks and thicknesses will 

be designed for a minimum specific 

gravity service of 1.2 with an allowable design factor minimum of 10:1. 

Minimum wall thicknesses are based 

on the ASTM D3299-81 standards. 

4.2.2 The thickness of the filament 

wound portion of the tank shell may 

be varied with tank height (taperedwall construction) as long as the 

ASTM requirements are met at any 

height level. 

4.2.3 Special tank thicknesses and 

designs are available upon request. 

4.3 Pigments, when used, shall be in the outer 

layer of the laminate construction only. 

4.4 Laminates shall be without dry spots or 

pockets of unreinforced resin. 

4.4.1 The laminate shall have a BARCOL 

hardness of at least 90% of the 

resin manufacturer's minimum 

specified hardness for the cured 

resin when tested in accordance 

with ASTM D2583-81. 

4.5 All cut edges exposed to the chemical environment shall be coated with resin and 

veil. 

4.6 All mold release agents shall be removed 

before shipment. 

4.7 The outer surface shall be relatively smooth 

and no glass fibers shall be exposed. 

4.8 Where pieces of chopped strand mat or 

combination mat are used, there shall be a 

minimum of 1" overlap of adjacent pieces. 

Joints will be staggered in succeeding layers. 

^ ^ 
CLAYTON ENVIRONMENTAL CONSULTANTS, INC. 

22345 Roethel Drive Novi, Michigan 48050 

Mr. Gary Nicholson 

VIATEC/HASTINGS REINFORCED 

1220 West State Street 

Hastings, MI 49058 

Dear Mr. Nicholson: 

Date Reported: 22-MAR-8w 

Date Received: 22-FEB-89 

Clayton Project No.: 558: 

P.O. No.: 009649-00 

The following is our report on the samples submitted for analysis, 

Lab 

Number 

712283 

712284 

712285 

712286 

712287 

712288 

Limit of 

Sample Description 

XI-9924 (13) 

XI-9994 (17) 

XD-1692 (5) 

XD-1769 (8) 

XI-1888 (16) 

XD-1382 (1) BLANK 

Detection: 

Sampling Time 

(minutes) 

456 

456 

486 

484 

498 

— 

Ac 

(mg) 

3.1 

0.97 

2.8 

3.1 

1.8 

(0.32) 

0.005 

:e 

* 

m< 

tone 

( 

7 

ppm) 

71 

22 

61 

67 

38 

— 

Styrene 

(mg) (ppm) 

1.2 23^|V"°',:-

 ; 

0.28 5.4 **"*•*• 

1.3 23 PE«*-V » 

1.1 20 -ToAro •: 

0.29 5.1 Pr-Tl. 

(0.049) * 

0.005 mg 

Analytical Method: 3M Organic Vapor Analytical Method No. 5, May 1984. 

The calculations are based 

on a sampling rate of: 40.1 cc/min 

* Actual value of client blank; results have not been blank corrected. 

26.8 cc/min 

We appreciate the opportunity to be of assistance to you. Please call our Client Services 

Department at (313) 344-2650 or me if you have any questions. 

3.o -2-y f>r 

Manager^ Laboratory Services 

M>\R 2' ' '«9B9 

•a 

°0 

•'-•"iC -'•'•..'. ' '..'-' IN> 
P.30 

J W ff t> 2.. 

£.'''-' V 

•-•H dKftnD ORGANIC Vft POR MONITOR '' ' y 

GAS CHROMATOGRAPHIC ANALYSIS REPURT 

OCCUPATIONAL rtEfiuTH RHD SAFETY PR03JUCTS DIVISI0N/3 M 

ST. PHUL J f1 IHHE3GTA 55144 

-./ V 

' t . ••• 

irnrt'f RE I Hi-OK CED P s_ ft 3D TIC 3." itiC. 

1220 wEST STATE STREET 

HASTINGS? Ml 49058 

" H '• G Ff R Y :\ IC H 0 L 3 0 N ? Q U A L1 T Y C 0 N i R 0 L 

ri 

REPORTS 01-175-82 

EMPLOYEE: BILL LftKE 

SAMPLE CODE: DL-3794 

DftTE EXPOSED: 6-17-82 EXPOSURE TIME < MIH >:503 

i\-

• 

COMPOUND N ft PIE 

ACETONE 

STYREHE 

MICROGM MG/PI3 

364.3 18.2 

j.092.5 81.5 

PPM 

7.6, 

EMPLOYEE: MIKE COLE 

SAMPLE CODE: DL-3635 

DftTE EXPOSED: 6-i7-82 EXPOSURE TIME<MIH;> :509 

COMPOUND NAME ^ 

.. .ftC ( IV. 

STYRENE 

MICROGM . MG--M3 _. PPM . 

^-.-^J^2^^v^6..6,--...,-.3..i5, 4- ... 

2165. 3 '• iol. 2 37. 8 

EMPLOYEE: / JIM HUVER 

SAMPLE CODE: DL-3834 -

DATE EXPOSED: 6-17-82 

COMPiJuND NAME 

ACETONE 

STYREHE 

EXPOSURE J TIME<MIH>:5&5 

MICROGM 

1396.7 

1134.1 

I'1G''M3 

70.8 

82. S 

• PPM 

£9.5 

i9.5 

EMPLOYEE: D. BAKER 

SAMPLE CODE: DL-3327 

DATE EXPOSED: 6-11-82 EXPOSURE TI Mc.'.: MIH > : o05 

COMPOUND NAME 

.•"•ACETONE' 

STYREHE 

MICROGM 

775. 0 

669. 1 

MG.-'fl3i.A' 

3 3 . 9 

50. 2 

PPC] 

16.4 

11.3 

EMPLOYEE: RICK ASPI HALL 

SAMPLE CODE: DL-3391 

DATE EXPOSED: 6-17-32 EXPOSURE TIME(MIN>:514 

COMPOUND NAME 

ACETONE 

STYRENE 

MIC R 0 G M Pi G / M 3 P ? Pi 

1184.8 53. 4 2t.'6 

14 73. 9 i08. ~ 25. 5 

a. 

<7,°l 
P.31 

i-MPLOYLt.: b!_riNK 

SAMPLE CODE: DL-375': 

DATE EXPOSED: 6-17-S XPOSURL TIML(MIH):0 

IMPOUND NAME 

ACETONE 

STYREHE 

M i U K U G M 

hi} * * 

N D * * 

'•'11J••••' I'l . Kh'M 

CH 

EMPLOYEE: RALPH PAYNE 

SAMPLE CODE: DL-3748 

DATE EXPOSED: 6-17-82 EXPOSURE TIME<MIH>:480 

!OhPOUND NAME 

ACETONE 

STYREN E 

MICROGM 

759. 2 

736. 2 

MG^M3 

4 0 . 1 

59. 7 

PPM 

16.9 

14.0 

**THE MINIMUM DETECTABLE LIMIT OF THE ANALYTICAL METHOD :.,IS *0 MICROGRAMS 

.*.. A . ;*.*'«•*•• 

PREPARED BY 

DATE -7- ?-2^. 

*mcYYc: KISS 

.. v-

^ 0 
P.32 

COMPANY: 

REPORT* 

L"JT 

<T-vr<s' t\( 

3M BRAND ORGANIC VAPOR MONITOR 

GflS CHROMATOGRAPHIC AHALYSIS REPORT 

OCCUPATIONAL HEALTH AND SAFETY PRODUCTS DIVISI0N/3M 

ST. PAUL? MINNESOTA 55144 

HASTINGS REINFORCED PLASTICS 

1226 kl. STATE ST. 

HAST IHGSJ MI 49053 

ATTN: ROH BENNER 

011-057-8 2 

RECEIVED 

MAR 1 5 1982 

HASTINGS HEINFORCED PLASTICS 

.i.-rij^otrf.t.-iTj,. 

EMPLOYEE: . DOUG NICHOLSON 

SAMPLE CODE: DL3774 

DATE EXPOSED: 2-16 EXPOSURE lIMECMIN):484 

COMPOUND NAME 

ACETONE 

STYRENE 

MICROGM 

434.0 

206.5 

MG/M3 

26.0 

16. 1 

PPM 

18.9 

3.8 

EMPLOYEE: ED HUS3 

SAMPLE CODE". DL343S 

DATE EXPOSED: 2-16 EXPOSURE TIME(MIN):476 

COMPOUND NAME 

ACETONE 

STYRENE 

MICROGM 

1897.0 

371.7 

MG/M 3 

103.6 

30.4 

EMPLOYEE: MIKE PIERSON 

SAMPLE CODE: DL3736 

DATE EXPOSED: 2-16 EXPOSURE TIME(MIN>:433 

PPM 

43. 6 

7.1 

COMPOUND NAME 

ACETONE 

STYRENE 

MICROGM 

1011.7 

641.3 

MG/M3 

54.5 

51.7 

PPM 

22.9 

12. 1 

EMPLOYEE: STEVE ROBINSON 

SAMPLE CODE: DL3562 

DftTE EXPOSED: 2-16 EXPOSURE TIME(MIrO :469 

COMPOUND NAME 

ACETONE 

STYRENE 

EMPLOYEE: MIKE HCOK 

SAMPLE CODE: DL3592 

DATE EXPOSED: 2-16 EXPOSURE TIMECMIN):473 

COMPOUND NAME 

ACETONE 

STYRENE 

z=> EMPLOYEE: MATT DUNNIGAN 

^ Q SAMPLE CODE: DL3694 

MICROGM 

1112.4 

1235.7 

MG-yM3 

61.7 

102.5 

PPM 

26.0 

24. 1 

MICROGM 

1426.0 

269. 6 

MG/M 3 

78.4 

22.2 

PPM 

33. 0 

S.ii 

DATE EXPOSED: 2-16 EXPOSURE TIME<MIN>:47G 
P.33 

H'-Ei OHL 

STYREHE 

I 1 a O 

1 2. 9 

:• c . i 

3. 0 

HKk 

m ; z. 

. E C 0 D E: D L 3 3 6 o 

EXPOSED: 2-16 EXPOSURE TIMEUIIN): 8 

COMPOUND HAME 

ACETONE 

STYRENE 

MICROGM MG/M3 

HD ** 

HD ** 

**THE MINIMUM DETECTABLE LIMIT OF THE ANALYTICAL METHOD IS 10 MXCROGRfiMS 

• PREPARED BY 

DATE 3-//HP2. 

^ 
P.34 

;•>: , -\ Ci '-Pj. ^ r. 

3M BRAND ORGANIC VAPOR MONITOR 

GAS CHROMATOGRAPHIC ANALYSIS REPORT 

OCCUPATIONAL hEALTH AND SAFETY PRODUCTS DIVISION/3M 

ST. PAUL-. MINNESOTA 55144 R ^ C F I V E D 

COMPANY: HASTINGS REINFORCED PLASTICS* INC HASTINGSREINFCRCEO PLASTICS 

1220 HEST STATE ST. QPPQftiqAI 

HASTINGS.- MI 49053 otr«£O|30l 

REPORT #: 81-266-81 AM W 7|8i9tI|Hi£il.2|3,4.St6 

MICROGM 

750.3 

343. 8 

MG/M3 

43. 1 

25.6 

PPM 

18.2 

b.0 

EMPLOYEE: BLANK CONTROL 

SAMPLE CODE: DL3441 

DATE EXPOSED: 9-11-81 EXPOSURE TIMECMIN):496 

• 

COMPOUND NAME MICROGM MG/M3 PPM 

ACETONE . ND ** 

STYRENE ND ** 

EMPLOYEE: FRANK HUSS 

SAMPLE CODE: DL3601 

BATE EXPOSED: 9-11-81 EXPOSURE TIMECMIN):492 

COMPOUND NAME 

ACETONE 

STYRENE 

' EMPLOYEE: DICK ROBINSON 

SAMPLE CODE: DL3709 

DATE EXPOSED: 9-11-81 EXPOSURE TIME<MIN):499 

COMPOUND NAME 

ACETONE 

STYRENE 

EMPLOYEE: GENE SHADE 

SAMPLE CODE: DL3752 

DATE EXPOSED: 9-11-81 EXPOSURE TIMECMIN):488 

COMPOUND NAME MICROGM MG/M3 PPM 

ACETONE 1396.1 81.O 34.1 

STYRENE 1629.0 77.4 i8.2 

EMPLOYEE: ARLENE CLARK 

SAMPLE CODE: DL3S04 

DATE EXPOSED: 9-11-81 EXPOSURE TIME<MIN):496 

COMPOUND NAME 

ACETONE 

STYRENE 

MICROGM 

1412.3 

642.6 

MG/M3 

88. 1 

47.3 

PPM 

33.7 

11.1 

MICROGM 

4618.2 

2367.5 

MG/M3 

263. 5 

175. 1 

PPM 

ilQ.9 

41. 1 

• 

r 

'§ 

33 
EMPLOYEE: RICK 5ENNER 

SAMPLE CODE: DL3849 

DATE EXPOSED: 9-11-81 EXPOSURE TIMECMIH):489 

COMPOUND NAME MICROGM MG/M3 PPM 

ACETONE 8366.7 484. 1 203.8 

STYREHE 307.6 23. 1 5.4 

* * A MINIMUM GF 18 MICROGRAMS WAS HOT DETECTED BY THE INSTRUMENT 

PREPARED BY —JC 

...y.Y.UlC-— 

—3 

r'?fm 

Y$C 

YYf 
P.36 

_..._., . _ _ 'ZrZAy BooThf 

wr 

OT 02 m 

*) 2 1982 Mr. Kenneth A. Kensington

 lJ0C 

President & General Manager 

Hastings Reinforced Plastics, Inc. 

1220 West State Street 

Hastings, Michigan 49058 

Dear Mr. Kensington: 

This letter 1s 1n reference to your Permit to Operate application for a 

grinding booth with exhaust system and dry filter control, located at 1220 

West State Street, Hastings, Michigan. This application, Identified as No. 

461-80, has been evaluated and approved by the A1r Quality Division, pursuant 

to the delegation of authority from the Michigan A1r Pollution Control Commission. 

This approval 1s based upon and subject to compliance with all administrative 

rules of the Commission and conditions stipulated in the attached supplement. 

Thank you for your cooperation. If you have any questions regarding this 

permit, please contact me at (517) 322-1333. 

Sincerely, 

Randal S. Telesz, Engineer 

Permit Unit 

A1r Quality Division 

RSfrkb 

Enclosure 

ect Joe Holmes 

3>S 
P.37 

3. KQO notified. yeS & 4 . RRD ^ ^ 

«• NSPS? ves Ntc H 8 f „„t1f1e d D) ^ 7. , ESHAPS V Ves(UnitCMef .~— -

•>• "D T Yes (EPA 8 co notified 0) $ ""' ^

 D) * ' 

9- Const. co«enced? ^giifEnf . Sup . not1f1e / - ^ N o 

10. Source description (Installation date /, « ,„ 5 

<?yl. 

•M,3f 

•a.u.i i" B0.U _ ^ / . .—j———- ^ Covered bynPermit Nol^ . 

"•

 C T:; '

 /

d e :c r ;pti0 ; . w

j

t h bu,,di^ •* «« * H.,^ . 

Fi'l*tr Ars.\ z. /fa fi-2 

How **-te r /7/ ;„ Clr»\ 

13. Operating schedule ...hours/da y " ^ ^ 

'«• TM type USAGE % Sulfu r / yS/W6e k f * -eks/year 

Heat content Densit y %Ash_ 

AJA 

15. Attainment Status 

Other 

Non-attainmpnf 

P - Primary S - Secondary A - All standards 

Non-attainment: emissions logged Yes.(TSP S02 

RACT for VOC Yes (He) Basis? 

Uncontrolled 

PPH TPY 

1f In proximity to non-attainment 

CO VOC) ^Replacemen t D ) 

Expected 

PPH TPY Allowed 

PPH TPY Limit 

-MICH EPA 

3£ 
P.38 

18. How is collected material disposed of? 0* ,*-.*.• .-'.-,- hY.r-r/rjtc /i\,.JYi;i 

19. Dispersion? /res ' No Basis 

20. 

21 

ACFM Temperature and Velocity Calc. l& *r 

¥- if" 

3. n -ftL 

Pa£t-ieu4aie Emission Calc. ^VT.£. V - , , T /W' l 

"" '*'& ' -•,**/*?? 0*H.ti)(, i? W"\ - < : < J '"'/'••• 

JC:,:VY./,.r.U. 

3 ^xjii. ' i f.?.r 

g'JM}'. c^c , 

- .r! r *->/->•'[ /e <JZ! C.G*". *-•,&•'}'¥»<• ' 

22. 

JL\ lu-ttot-i A..Y*r 

SOo Emission Calc. kl.r^%C - ^ <.,UuYCCr, ;,, -:>.? .: -r.Yr.UY.-Y A'I* 

N A ••• C /--• ' 

m . ' ( r] /^.?,,/} (~37 V . . ._ 

> r 

23. VOC EifflssTotrCalc. /}})&»*J 

/ 

Sci-i tzcxlc*.!.<+ton Y-> -'';A^ -'i>^r'""V.-.v.-if.-."-«.- -f-/ /c* 

24. 

• J »\ //•. ,.•! ..'</: 

Basis for expected compliance, reasons fpr not sending cease and desist letter if 

construction commenced, and other comments. -r> , -„ ••- v. - .„.,.'•• , / 

£.clt->£*»d-rtd'''ofj -C->r SC'ryrS'Jti:. •-2 i<'Y <>.••'''•'M/M* ,Y~<-1 Y-- ••''•'•-.-•'!*•-•>> &>&'•) '\-.--.Ct <••'•• 

fd.tr c*i->stz*t'.r'

>

^i*f'- 7/itf C.om.f>o.t.u h«~5 btetJ aA-^ra.-(-J^j •/*<?! 5fre<J Lao("f> r//~r<: 

fA.^^I^-jS *,m± OJ* A«>'0 ,jW - r cc^e 4 A. Ce,*?!*''^"' -C'U ro.tr f^ -/or ocl»r. 

-r/^rcY,,,t. .oc *r<: ^ i ,.^w.,J7v,.Reviewed by: /•;.«o,/, / •;;- • 

Date: f / 

3 7 
P.39 

J\PR 1 4 1981 

SUPPLEMENT TO PERMIT No. 460-80 

Hastings Reinforced Plastics, Inc. 

Hastings, MI 

GENERAL CONDITIONS 

1. Approval of the Permit to Operate will remain in effect as long as compliance with 

Commission rules and with specific conditions of this permit is maintained. 

2. The restrictions and conditions of this Permit to Operate shall apply to any person or legal 

entity which now or shall hereafter own or operate the facilities for which this Permit to 

Operate is issued. The Applicant shall immediately notify the Commission in writing of 

such change in ownership or principal operator status of this facility. 

3. Rule 208(3b) - Operation of this facility shall not interfere with the attainment or 

maintenance of the air quality standard for any air contaminant. 

4. Operation of this facility shall not result in significant deterioration of air quality. 

5. Rule 901 - Operation of this facility shall not result in the emission of an air contaminant 

which causes injurious effects to human health or safety, animal life, plant life of 

significant economic value, or property, or which causes unreasonable interference with the 

comfortable enjoyment of life and property. 

6. Rule 201 - Applicant shall not reconstruct, alter, modify, expand or relocate this facility 

unless plans, specifications and an application for a Permit to Install are submitted to and 

approved by the Commission. 

7. Approval of this permit does not obviate the necessity of obtaining such permits or 

approvals from other units of government as required by law. 

8. Applicant shall provide notification of any abnormal conditions or malfunction of process or 

control equipment covered by this application resulting in emissions in violation of the 

Commission rules or of any permit conditions for more than two hours shall be made to the 

District Engineer. Such notice should be made as soon as reasonably possible but not later 

than 9:00 a.m. of the next working day. The applicant shall also submit to the District 

Engineer, in writing, within 10 days, a detailed report, including probable causes, duration 

of violation, remedial action taken, and what steps are being undertaken to prevent a 

reoccurrence. 

3« 
P.40 

PC\t\r<\<AJ~ tV IY et<Y\..i 

RECEIVED 

STATE OF MICHIGAN 

NATURAL RESOURCES COMMISSION 

THOMAS J. ANDERSON 

MARLENE J. FLUHARTY 

3RRY KAMMER ^5555^ ' • l/ l A TC A 

. STEWART MYERS -wan*- VIAItl r 

MAY * 1988 

R^MODND0P!UPORE

 JAME S J

-

 BLANCHARD

-

 Govemor

 Hmim& wmimv SYSTEMS 

DEPARTMENT OF NATURAL RESOURCES 

STEVENS T. MASON BUILDING 

BOX 30028 

LANSING, Ml 48909 

GORDON E. GUYER, Director 

April 29, 1988 

Mr. Kenneth Kensington, General Manager 

Hastings Reinforced Plastics 

1220 W. State Street 

Hastings, Michigan 49058 

Dear Mr. Kensington: 

This letter is in reference to your Permit to Install application for the hand 

filament winding area, located at 1220 W. State Street, Hastings, Michigan. 

This application, identified as No. 116-88, has been evaluated and approved by 

the Air Quality Division, pursuant to the delegation of authority from the 

Michigan Air Pollution Control Commission. 

This approval is based upon and subject to compliance with all administrative 

rules of the Commission and conditions stipulated in the attached supplement. 

Please review these conditions thoroughly so that you may plan for and take the 

actions necessary to ensure compliance with all of these conditions. Also note 

that Condition No. 1 requires you to apply, in writing, for a permit to operate 

within 30 days after completion of construction. 

You are advised that contaminants discharged to the surface waters and/or 

groundwaters; materials disposed of on land; hazardous waste storage, 

treatment, and disposal; and resource recovery facilities must be approved by 

other divisions of the Department of Natural Resources. Additionally, your 

plant environment must be in compliance with all applicable requirements of the 

Departments of Public Health and Labor. 

Approval of this permit does not constitute a waiver by the State of Michigan 

of its right to bring appropriate legal action against the applicant for 

failing to obtain the required permit prior to the commencement of 

construction. 

Thank you for your cooperation. Please contact me if you have any questions 

regarding this permit. 

Sincerely, 

/ Gregory My Edwards, Senior Engineer 

Nortliwest Permit Unit 

Air Quality Division 

517-373-7023 

GME:clp 

Enclosure 

TM

26 cc: Dick VandeBunt 

I /OD ,-.,£, ._—•', -TL i • 3 5'<r 
P.41 

SUPPLEMENT TO PERMIT NO. 116-88 

Hastings Reinforced Plastics 

Hastings, Michigan 

April 29, 1988 

GENERAL CONDITIONS 

1. Rule 208(2) - Not more than 30 days after completion of the installation, 

Applicant shall apply, in writing, for a Permit to Operate. Completion of 

the installation is deemed to occur not later than commencement of a trial 

operation pursuant to Rule 201(4). Written application should be sent to: 

Chief, Permit Unit, Air Quality Division, Department of Natural Resources, 

P.O. Box 30028, Lansing, Michigan 48909. 

2. Rule 201(4) - Trial operation of the equipment is permitted until the 

Michigan Air Pollution Control Commission acts upon the Permit to Operate. 

Operation of the equipment shall permanently cease upon denial of the 

Permit to Operate by the Commission. 

3. Rule 208(3)(a) and (c) - Applicant shall demonstrate compliance with all 

Commission rules and with all general and special conditions of this 

permit prior to issuance of the Permit to Operate. 

4. Rule 201 - Applicant shall not reconstruct, alter, modify, expand, or 

relocate this equipment unless plans, specifications, and an application 

for a Permit to Install are submitted to and approved by the Commission. 

5. Rule 901 - Operation of this equipment shall not result in the emission of 

an air contaminant which causes injurious effects to human health or 

safety, animal life, plant life of significant value, or property, or 

which causes unreasonable interference with the comfortable enjoyment of 

life and property. 

6. Rule 208(3)(b) - Operation of this equipment shall not interfere with the 

attainment or maintenance of the air quality standard for any air 

contaminant. 

7. Operation of this equipment shall not result in significant deterioration 

of air quality. 

8. Rule 912 - Applicant shall provide notification of any abnormal conditions 

or malfunction of process or control equipment covered by this 

application, resulting in emissions in violation of the Commission rules 

or of any permit conditions for more than two hours, to the District 

Supervisor. Such notice shall be made as soon as reasonably possible, but 

not later than 9:00 a.m. of the next working day. Applicant shall also, 

within 10 days, submit to the District Supervisor, a written detailed 

report, including probable causes, duration of violation, remedial action 

taken, and the steps which are being undertaken to prevent a reoccurrence. 

40 
P.42 

Hastings Reinforced Plastics 

Permit No. 116-88 

Page 2 

April 29, 1988 

9. Approval of this application does not exempt the Applicant from complying 

with any future regulations which may be promulgated under Act 348, P.A. 

1965, as amended. 

10. Approval of this permit does not obviate the necessity of obtaining such 

permits or approvals from other units of government as required by law. 

11. Act No. 53 - Applicant shall notify any public utility of any excavation, 

tunneling and discharging of explosives or demolition of buildings which 

may affect said utility's facilities in accordance with Act 53 of the 

Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan 

Compiled Laws and comply with each of the requirements of that Act. 

12. The restrictions and conditions of this Permit to Install shall apply to 

any person or legal entity which now or shall hereafter own or operate the 

equipment for which this Permit to Install is issued. Any new owner or 

operator shall Immediately notify the Chief of the Permit Unit, in 

writing, of such change in ownership or principal operator status of this 

equipment. 

13. Rule 201(5) - If the installation, reconstruction, relocation, or 

alteration of the equipment for which this permit has been approved has 

not commenced within, or has been interrupted for, 18 months, this permit 

shall become void unless otherwise authorized by the Commission. 

SPECIAL CONDITIONS 

14. There shall be no visible emissions from the hand filament winding area. 

15. The volatile organic compound (VOC) emission rate from the hand filament 

winding operation shall not exceed 0.28 pounds per hour nor 1.3 tons per 

year. 

16. Applicant shall not substitute any raw materials for those described in 

this permit application which would result in an appreciable change in the 

quality or any appreciable increase in the quantity of the emission of an 

air contaminant without prior notification to and approval by the Air 

Quality Division. 

17. Resin and catalyst usage rates on a monthly basis shall be kept on file 

for a period of at least two years and made available to the Air Quality 

Division upon request. 

4( 
P.43 

DEPARTMENT OF NATURAL RESOURCES 

AIR QUALITY DIVISION 

P.O. BOX 30028 

LANSING, MICHIGAN 48909 

STATE OF MICHIGAN 

AIR USE PERMIT 

APPLICATION 

APPLICATION NO. 

iU-KK 

FOR AUTHORITY TO INSTALL, CONSTRUCT, RECONSTRUCT, RELOCATE, OR ALTER, 

AND OPERATE PROCESS, FUEL-BURNING, OR REFUSE-BURNING EQUIPMENT AND/ 

OR CONTROL EQUIPMENT (PERMITS TO INSTALL AND OPERATE ARE REQUIRED 

BY ADMINISTRATIVE RULES PURSUANT TO ACT 348, P.A. 1965, AS AMENDED). 

yiyioiui. 

APPUCANT: Business License Name of Corporation, Partnership, Individual Owner, Govemment Agency fem 

ffiSDNB FEMCRID HASHES, E C 

2. MAILING ADDRESS: Number and Street; City or Village; State; Zip Code 

1220 W. State St. Bastirgs, ME 49058 PERMIT SECTION. 

EQUIPMENT OR PROCESS LOCATION: Number and Street; City. Village or Township 

Same as $2 

COUNTY 

Parry 

ZIP CODE 

49058-

4. GENERAL NATURE OF BUSINESS: 

Assarbly & Eaxfcatkn of Oaiposite isrts 

^iJ^Sj^X**? 0* *

 a " ° ;i ^ ' diflBe ^aenBndE^cmbef^l-dia . to 30- dia., themrass is ttatlicirid cataliaad fleete r resins are pcuroa & distributed c ^ 

wpcwe roqaitty at tte pxdrt as far as air ertragxiErt: ic the oanposite laminate is conosmod. 

tne resin velcpt can be lost after catalyzabicn. 

rf ifi^K^^^Sfff16,?^ ^ (1) dWB

 <*^ > * P°i**ter used cbrfng a 40 week jear or a total 

..curcdifirts. a * 40 wa& ^ vas baaad m air best estirate^ "***«« 

J^S?^i^^l! 1 6 thre e (3 ) N*** ^ s 336 */ <kta ste* s (MSCS's) cn tt e pollste r resins we have usad 

cn au s nana riiament windsr. 

6. ESTIMATED COST: 

Air Pollution Control Equipment $ Total Project $ 

7. ACTION AND TIMING: ESTIMATED 

STARTING DATE 

ESTIMATED 

COMPLETION DATE 

f ~ | Installation, construction, reconstruction, or alteration MJL\XmJr_f Jul U9 S 

j I Relocation 

| [ Change of Ownership 

8. NAME OF PRIOR OWNER AS IN ITEM 1 ABOVE. AND PRIOR AIR USE PERMIT NUMBER. IF ANY: 

NAME PERMIT NO. 

9. NAME AND TITLE OF OWNER OR AUTHORIZED MEMBER OF FIRM 

M_ KamethL. Ksnsdngbcn Signature 

Title: General Manager Date: 12-31-87 Phone N06I6 94^9578 

10. CONTACT PERSON IF DIFFERENT THAN ITEM 9: 

Name Phone Noi SL6- %

t

ytm\ 

11. DISPOSITION OF APPUCATION: 

Receipt of all information 

required by Rule 203 

Permit to install approved * on 

Permit to operate approved * on 

Application/permit voided on 

Application/permit denied on 

FOR DNR USE ONLY 

APR 2 9 1988 

Signature 

Signature 

Signature 

Signaturu 

•^MdWL 

'Subject to compliance with all Commission Rules and Conditions stipulated in the attached supplement. 

AQ-1 INSTRUCTIONS FOR COMPLETING AND FILING ARE ON REVERSE SIDE 

A7 

PR 6615 

5/84 
P.44 

(-? ri'*\d.i}n* rt>oo~f~71 

STATE OF MICHIGAN 

NATURAL RESOURCES COMMISSION 

JACOB A. HOEFER WILLIAM G. MILLIKEN, Governor 

E. M. LAITALA 

pinFTM» DEPARTMENT OF NATURAL RESOURCES 

PAUL n. VVcNDLcn 

HARRY H. WHITELEY STEVENS T. MASON BUILDING 

JOAN L. WOLFE BOX 30028 

CHARLES G. YOUNGLOVE LANSING. Ml 48909 

HOWARD A. .TANNER. Director 

Mr. Kenneth A. Kensington k?}{ 0 2 loop 

President & General Manager °^ 

Hastings Reinforced Plastics, Inc. 

1220 West State Street 

Hastings, Michigan 49058 

Dear Mr. Kensington: 

This letter is in reference to your Permit to Operate application for a 

grinding booth with exhaust system and dry filter control, located at 1220 

West State Street, Hastings, Michigan. This application, identified as No. 

461-80, has been evaluated and approved by the Air Quality Division, pursuant 

to the delegation of authority from the Michigan Air Pollution Control Commission. 

This approval is based upon and subject to compliance with all administrative 

rules of the Commission and conditions stipulated in the attached supplement. 

Thank you for your cooperation. If you have any questions regarding this 

permit, please contact me at (517) 322-1333. 

Sincerely, 

•fasrUJlj, 75&Umy 

Randal S. Telesz, Engineer 

Permit Unit 

Air Quality Division 

RST:kb 

Enclosure 

cc: Joe Holmes 

RECEIVED 

APR 03 1982 

HASTINGS REINFORCED PLASTICS 

R1026 1/80 41 
P.45 

09/07/93 11:15 ©616 948 3850 VIATEC CTRL SVCS ©001 

VIATECTM 202 South Broadway 

CENTRAL SERVICES Hastings, MI 49058 

Tel. (616) 948-3860 

FAX No. 616 948-3850 

TELEFAX TRANSMITTAL SHEET 

DESTINATION Pacific Environmental Services. Inc. 

DESTINATION CONTACT Dean A. Carroll - Environ. Enqr. 

ORIGINATOR Kenneth Kensington 

NUMBER OF PAGES TRANSMITTED (Including Cover) 1 

DATE TRANSMITTED 9-7-93 

DESTINATION FAX NO. 9J9-941-0234. 

SUBJECT __ Confidentiality Release. 

Subject: Air Permit 461-80 - grinding booth. 

Dear Mr. Carroll: 

This fax letter is to release you or other parties of the 

confidentiality use of our Air Permit 461-80 - titled "GRINDING 

BOOTH" as applied for in 1982 with the state of Michigan DNR air 

quality resource department, we at this time consider in nonconfidential information. 

Sincerely/ 

Kenneth L. Kensington

 J CEO 

44-
P.46 

AIR QUAL1IY UIVISION 

MICHIGAN DEPARTMENT OF NATURAL RESOURCES -

P.O. BOX 30028, LANSING, MICHIGAN 48909

 V £ * o 

'^PLICATION TO THE AIR POLLUTION CONTROL COMMISSION TM4y ;

 V£ i 

for authority lo construct, install or altar A/a "*• Q /Q

 C 

APPLICATION MO 

t/M-fr 

o 

Qu, ^o end HOjy .

 J 

for parmit to oparata process, fual burning, rafusa burning and/or air pollution control sfyjipawnt 

; ./tyi PERMIT TO RC ISSUCO TO: fSuiui i L«cci»«« N»mt of Corporation. Pvtmmr.hip. /adurieW Owitr, Governmental A f*cy) 

Huntings RPInforced Plastics, Inc. 

1. MAILINO ADORIS*: (Numher. Street. Cur or Kifia**. Zip Cod*) 

1220 W. Stet e Stree t - Hastings. Michigan 49058 

lu1. EQUIPMENT OR PROCESS LOCATION: (Number, Street. City or VilUf. Tounukip. Zip Code) 

L8_£2 : 

C VPE OP ORGANIZATION. 

fir] Corporation f~) Partnership • Individual Ownar • Gevernatentel Agenc Mncy J 

C

OKMCRAL NATURE OF BUSINESS. 

Ajgfmbly and Fabrication of Fihargleea Perta : 

• EOUIPMENT DESCRIPTION: Application is hereby mode far porn. 

See Attached Drawing 

Exhaust Booth - Grinding 

V. or. V\ c^rTvxa^V 

IV 

isslen te cawstisJs^wTAirWpiltar and t< 

—-,-..„ lioe u/w <5»v" "* 

THIS HRSTT IS TO 

BE USED ONLY IN 

CONNECTION WITH 

CONTRACT OR PROPOSALS 

OF THIS COMPANY. 

IT T•- NOT TO BE 

COPIED, REPRODUCED, 

EXHIBITED OR USED 

PIBHCTTT OTA INDIRECTLY 

ta oparata td* following equipment 

LL T ESTIMATEO COST: Air Pollution Control Equipment | _ 12LANY WtW®B3lMgfaf&L 

S PRESENT STATUS O F EQUIPMENT: (Chech emd tompUte app/waeb iie W TH E INTEREST S U-fe' 

( ) Construction or installation not started ... . 

< ) Construction or inttollotion partly completed 

( ) Construction complotod 

( ) Equipment is to ko altarod 

( ) Equipment is partly altarod 

( ) Equipment has boon altarod 

( ) Change of location and/or ownership 

HA^a^oREINFORfilK 

PLASTICS, INC. 

Data 

May 1975 

• NAME OF PRIOR OWNER AS IN ttl ABOVE. ANO PRIOR AIR POLLUTION CONTROL PERMIT NUMBCR. IP AMY: 

INeme) MOn e (Fink MemUr) 

»0 TYPE OR PRINT NAME ANO TITLE OF OWNER OR AUTHORIZED MEMBER OP PIRM: 

r»—; K«nn«th L. Kensington • /T^ . President & floral M.n.fAr 

> • 

h -

3- m 

«• 

3 

»» DISPOSITION OP APPLICATION: 

^S/A^^b^j^^,.. ^ .. SEP 1 7 1980 Sifnatut*. 

Signature. 

^m7 

ro*M AP., ,M ./» .

 D(hU,m «WP/emeni. /fMSfwtiea* Iter «—phrtot (ii s /•» » or* OR MMM I «<*>/ 
P.47 

e° 

. .^^NLO.. ^ 

m 1 4 1901 

Kenneth L. Kensington 

President & General Manager 

Hastings Reinforced Plastics, Inc. 

1220 West State Street 

Hastings?,MI 49058 

Dear Mr. Kensington: 

This letter 1s 1n reference to your Permit to Install and Operate application 

for your acetone tank and fiberglass molding operation with Modiglass dry 

air filter, located at 1220 West State Street, Hastings, Michigan. This 

application, Identified as No. 460-80, has been evaluated and approved by 

the A1r Quality Division, pursuant to the delegation of authority from the 

Michigan Air Pollution Control Commission. 

This approval 1s based upon and subject to compliance with all administrative 

rules of the Commission and conditions stipulated in the attached supplement. 

Furthermore, you are advised that resource recovery facilities and materials 

disposed of on land must be approved by the Resource Recovery Division of 

the Department of Natural Resources; and the Inplant environment must be in 

compliance with the applicable requirements of the Occupational Health Division of the Department of Public Health. 

Approval of this permit does not constitute a waiver by the State of Michigan 

of its right to bring appropriate legal action against the applicant for failing to obtain the required permits prior to the commencement of construction. 

Additionally, in reference to our telephone conversation on April 3, 1981, 

concerning confidential information, it was agreed that all Material Safety 

Data Sheets and allowable calculations are not considered confidential material. 

Thank you for your cooperation. If you have any questions regarding this 

permit, please contact me at (517) 322-1333. 

Sincerely, 

Ur 

Randal S. Telesz, Engineer 

Permit Unit , .. t <i \&\ 

Air Quality Division \Jb^ 

RST:kb W 

Enclosure 

cci :'• Joe Holaes 

4-J& 

bo»"»°» »» * 
P.48 

SUPPLEMENT TO PERMIT No. 461-80 

Hastings Reinforced Plastics 

Hastings, MI 

APS U ^ 1982 

GENERAL CONDITIONS 

1. Approval of this Permit to Operate will remain in effect as long as compliance with all 

Commission rules and with all general and special conditions of this permit is maintained. 

2. Rule 201 - Applicant shall not reconstruct, alter, modify, expand, or relocate this equipment unless plans, specifications, and an application for a Permit to Install are submitted 

to and approved by the Commission. 

3. Rule 901 - Operation of this equipment shall not result in the emission of an air 

contaminant which causes injurious effects to human health or safety, animal life, plant 

life of significant economic value, or property, or which causes unreasonable interference 

with the comfortable enjoyment of life and property. 

4. Rule 208(3)03) .- Operation of this equipment shall not interfere with the attainment or 

maintenance of the air quality standard for any air contaminant. 

5. Operation of this equipment shall not result in significant deterioration of air quality. 

*>. Rule 912 - Applicant shall provide notification of any abnormal conditions or malfunction 

of process or control equipment covered by this application, resulting in emissions in 

violation of the Commission rules or of any permit conditions for more than two hours, to 

the District Engineer. Such notice shall be made as soon as reasonably possible, but not 

later than 9:00 a.m. of the next working day. Applicant shall also, within 10 days, submit 

to the District Engineer a written detailed report, including probable causes, duration of 

violation, remedial action taken, and the steps which are being undertaken to prevent a 

reoccurrence. 

7. Approval of this application does not preclude the Applicant from complying with any 

future regulations which may be promulgated under Act 348, P.A. 1965, as amended. 

8. Approval of this permit does not obviate the necessity of obtaining such permits or 

approvals from other units of government as required by law. 

9. The restrictions and conditions of this Permit to Operate shall apply to any person or legal 

entity which now or shall hereafter own or operate the facilities for which this Permit to 

Operate is issued. Any new owner or operator shall immediately notify the Chief of the 

Permit Unit, in writing, of such change in ownership or principal operator status of this 

equipment. 

SPECIAL CONDITIONS 

10. Rule 331 - The particulate emission from the grinding booth shall not exceed 0.10 pounds 

per 1,000 pounds of exhaust gases, calculated on a dry gas basis. 

11. Visible emissions shall not exceed 20% opacity except as specified in Rule 301(la) and (b). 

i2. Applicant shall not operate the grinding booth unless the exhaust filters are in place and 

operating properly. 

RST:kb 

4-7 
P.49 

STATE OF MICHIGAN 

sst. 

NATURAL RESOURCES COMMISSION 

JACOB A. HOEFER 

• M LAITALA WILLIAM G. MILLIKEN, Governor 

PAuTrwENDLER DEPARTMENT OF NATURAL RESOURCES 

HARRY H. WHITELEY STEVENS T. MASON BUILDING 

JOAN L. WOLFE ' BOX 30028 

CHARLES G. YOUNGLOVE LANSING, Ml 48909 

HOWARD A. TANNER. Director 

SEP 17 1980 V¥ ^ $ ° 

Hastings Reinforced Plastics, Inc., ^ T 

Kenneth L. Kensington 

President and General Manager 

1220 W. State Street 

Hastings, MI 49058 

Dear Mr. Kensington: 

Your application for a Permit to Install a grinding booth with exhaust system 

and dry filter control located at 1220 W. State St., Hastings, Michigan, has 

been evaluated. This application, identified as No. 461-80, has been approved 

by the staff 1n the name of the Michigan Air Pollution Control Consulssion 

pursuant to the delegation of authority entered by the Commission. 

This approval 1s based on and subject to compliance with all Commission rules 

and conditions stipulated in the attached supplement. 

Furthermore, you are advised that resource recovery facilities and materials 

disposed of on land must be approved by the Resource Recovery Division of the 

Department of Natural Resources; and adequate inplant exhaust ventilation must 

be provided to permit compliance with applicable Occupational Health requirements as required by the Department of Public Health. 

Issuance of this permit does not constitute a waiver by the State of Michigan 

of its right to bring appropriate legal action against the permittee for 

failing to obtain the required permits prior to the coiranencement of construction. 

Thank you for your cooperation. If you have any questions, please contact this 

office at (517) 322-1333. 

Sincerely, 

Randal S. Telesz, Engineer 

Permit Unit 

Air Quality Division 

Enclosure 

cc: Ooe Holmes 

:dr 

R1026 1/80 

H 
P.50 

AIR QUALiIY DIVISION 

MICHIGAN DEPARTMENT OF NATURAL RESOURCES ^/ > , 

P.O. BOX 30028, LANSING, MICHIGAN 48909 ^ O v 

APPLICATION MO 

/ PLICATION TO THE AIR POLLUTION CONTROL COMMISSION ty JQ <*£) 

for authority to construct, install or altar vY; A? O 

— ^//> °J 

for parmit to oparata process, fual burning, rafusa burning and/or air pollution control aqOipkapt 

"i PERMIT TO BC ISSUEO TO: {Bm.ir.ete License Neme of Corporation. fanner.hip. Indu/idaal Owner. Covernmaatal Agency) 

Hastings Reinforced Plasti c a, Inc^r2 MAILIMO AOORESS: (Hunker. Street. Cuy or Village. Zip Code) 

1220 W. State Stree t - Haatlnga, Michigan 49058 

1. EQUIPMENT on PROCESS LOCATION: (Numker. Street. City or Village. Township. Zip Code) 

Same aa #2 

4 TYPE OP ORGANIZATION. 

Kr) Corporation Q Partnarskip Q Individual Ownor Q Go¥arnmontel Agency 

S. OIMERAL NATURE OF BUSINESS. 

Aflflfttnhly anri FaTvriraM nn nf TMhprgl ABB Parfa -J 

• EQUIPMENT DESCRIPTION: Application is karoby mod* far permission ta canstruct, install or altar and ta oparata tba fallowing aqulpma,,, 

-NOTICE-. , 

See Attached Drawing TmS^^fl^T O 

Exhaust Booth - Grinding B E USE D QNL Y I N 

CONNECTION WITH 

CONTRACT OR PROPOSALS 

OF THIS COMPANY. 

IT IS NCT TO SE 

COPIES. REPRODUCED, 

EXHIBITED OR- ^JSED 

L "T'"Ttoco'

T:

 * c-

E—« ^"^^Ml 

Lo r\ V\ ^^VC\ oA 

•n-RTTi.T JMJLifl JM^^^sfaS PRESENT STATUS OF EQUIPMENT: (Chech and complete applicable ue-itY "• 

TO TOS^NTERESTS QSii-t^ 

( ) Construction or installation not stortod TT AOTTfftR REINFOfeftfr " °"* 

( ) Construction or installation partly complotod . . . „ cirpTn O TTO T -

( ) Construction complotad PIJABTIUD , IINO . MaV 197 5 

( ) Equipmont is to ko oltorad _________ _ —-—>—_____ _ 

( ) Equipmont is partly oltorad • __________^_ _ 

( ) Equipmont hos boon altarod __________ _ __________ _ 

( ) Ckongo of location and/or ownor skip ^_________ _ .-———_---_____ . 

t NAME OF PRIOR OWNER AS IN HI AROVE. ANO PRIOR AIR POLLUTION CONTROL PERMIT NUMRER. IP AMY: 

(Name) Non e ffarmk Hmm^at) 

10 TYPE OR PRINT NAME ANO TITLE OF OWNER OR AUTHORIZED MEMBER OF FIRM: I 

^ Kfflmeth L. JtenBtngf-nn—JL _ ITHM PrM^an f *. *ffn trnl Mnnaccl: 

is..*,,,)- *l ~* \ ^ V rD.«.6r»lXi79 — I*-— wa.;frU6)9ft5-957. 

a 

ac w 

I I . DISPOSITION OF APPLICATION: 

* 

Subject to compliance with all SEP 1 7 1980 YC&C -J W (ft 

Paraiit ta install appravad and isswad — ila«»».»- W 6^ * //AXttrr 

Commission Rules and conditions ^ 

Parmit ta oparata appraUaa'ind issuad an Sifnatura 

stipulated in the attached supplement. 

FORM AP-I IM •/» • f/wPsMtai /or aam^UHmt Oto <am ars oo IMM I ,ida) 

d-d 
P.51 

SUPPLEMENT TO PERMIT No. 461-80 

Hastings Reinforced Plastics, Inc. 

Hastings, MI 

SEP i 7 1980 

GENERAL CONDITIONS 

1. Applicant shall demonstrate compliance with all Commission rules and with all specific 

conditions of this permit prior to issuance of the Permit to Operate. 

2. The restrictions and conditions of this Permit to Install shall apply to any person or legal 

entity which now or shall hereafter own or operate the facilities for which this Permit to 

Install is issued. The Applicant shall immediately notify the Commission of such change in 

ownership or principal operator status of this facility. 

3. /Act No. 53 - Applicant shall notify any public utility of any excavation, tunneling and 

•J discharging of explosives or demolition of buildings which may affect said utility's facilities 

in accordance with Act No. 53 of the Public Acts of 1974, being Sections 460.701 to 

460.718 of the Michigan Compiled Laws and comply with each of the requirements of that 

Act. 

4. Rule 201(4) - Trial operation of the equipment is permitted until the Commission acts upon 

the Permit to Operate. 

5. Rule 208(2) - Not more than 30 days after completion of the installation, the Applicant 

shall apply, in writing, to the Commission for a Permit to Operate. Completion of the 

installation is deemed to occur not later than commencement of a trial operation pursuant 

to Rule 201(4). Written application should be sent to: Chief, Permit Unit, Air Quality 

Division, Department of Natural Resources, Box 30028, Lansing, Michigan 48909. 

6. Rule 208(3b) - Operation of this facility shall not interfere with the attainment or 

maintenance of the air quality standard for any air contaminant. 

7. Operation of this facility shall not result in significant deterioration of air quality. 

8. Rule 901 - Operation of this facility shall not result in the emission of an air contaminant 

which causes injurious effects to human health or safety, animal life, plant life of 

significant economic value, or property, or which causes unreasonable interference with the 

comfortable enjoyment of life and property. 

9. Rule 201 - Applicant shall not reconstruct, alter, modify, expand or relocate this facility 

unless plans, specifications and an application for a Permit to Install are submitted to and 

approved by the Commission. 

10. Approval of this permit does not obviate the necessity of obtaining such permits or 

approvals from other units of government as required by law. 

11. Notification of any malfunction of process or control equipment resulting in emissions in 

violation of the Commission rules or of any permit conditions should be made to the 

District Engineer. Such notice should be made as soon as possible but not later than 9:00 

a.m. of the next working day. The notice shall include a program of corrective action and 

shall be confirmed in writing. 

5~o 
P.52 

Hastings Reinforced Plastics, Inc. 

Permit No. 461-80 

Page 2 

SPECIAL CONDITIONS 

12. Rule 331 - The particulate emission rate from the grinding booth shall not exceed 0.10 

pounds per 1,000 pounds of exhaust gases, calculated on a dry gas basis. 

13. Visible emissions are limited to an opacity of less than or equal to 20% except as specified 

in Rule 301. 

14. Applicant shall not operate the grinding booth unless the exhaust filters are in place and 

operating properly. 

RST:kb 

o o o, I o 

\ po 

. C l-> oo 0,6 \ • 

L . 

. ©co l 1. 

r, 
P.53 

J\ ct -h i * -

>

/

1

 tt 

HASTINGS • REINFORCED 1220 W. State Street 

Hastings, Michigan 49058 

PLASTICS, IMC. Tel. 616 945-9578 

Sl?'} 

March 17, 1988 

Ms. Linda L. Wardell - Engineer 

Northwest Permit Unit 

Air Quality Division 

Department of Natural Resources 

Stevens T. Mason Building 

Box 30028 

Lansing, MI 48909 

Reference: APPLICATION #78-88 

AIR USE PERMIT 

Dear Ms. Wardell: 

As per your letter dated 3-11-88 and its request to give you written 

notice for permission to operate. This letter so notifies you that 

the acetone recovery still has been in operation. This was so 

indicated in Section 7 of the application titled "Action & Timing". 

Our Company and its people want to thank you and your departments 

quick response and action in this matter in assisting us to comply 

to current regulations and procedures. 

If there "is anything more we need to do please contact the writer. 

Sincerely, 

VIATEC - HASTINGS ENGINEERED SYSTEMS 

' -"-

 ,!—Y- Y~ 

Kenneth L. Kensington , 

President 

cc: file 

cc: Copy of Notice Company Name Change 

KLK/lr 

Designers and fvlnnulaclure's of Corrosion Resistant Tank:? • Ducts Hood?. Fin-no Scmbbeis •?. Related Equipment 

91 
P.54 

HASTINGS •REINFORCED 1220 W. State Street 

Hastings, Michigan 49058 

PLASTICS, IMC. Tel. 616 945-9578 

March 17, 1988 

Ms. Linda L. Wardell - Engineer 

Northwest Permit Unit 

Air Quality Division 

Department of Natural Resources 

Stevens T. Mason Building 

Box 30028 

Lansing, MI 48909 

Reference: APPLICATION #78-88 

AIR USE PERMIT 

Dear Ms. Wardell: . 

As per your letter dated 3-11-88 and its request to give you written 

notice for permission to operate. This letter so notifies you that 

the acetone recovery still has been in operation. This was so 

indicated in Section 7 of the application titled "Action & Timing". 

Our Company and its people want to thank you and your departments 

quick response and action in this matter in assisting us to comply 

to current regulations and procedures. 

If there is anything more we need to do please contact the writer. 

Sincerely, 

VIATEC - HASTINGS ENGINEERED SYSTEMS • 

t ••*<- ^--Y-'U 

Kenneth L. Kensington 

President 

c c : fil e 

cc: Copy of Notice Company Name Change 

^a=a», KLK/J.r 

is,;.Sir | Designers and Manufacturers ol Corrosion Resistant Tanks • Ducts • Hoods iW K Scrubbers 5 Related Equipment 

5T3 
P.55 

STATE OF MICHIGAN 

NATURAL RESOURCES COMMISSION 

THOMAS J. ANDERSON 

MARLENE J. FLUHARTY 

•RRY KAMMER 

. STEWART MYERS 

DAVID D. OLSON 

RAYMONO POUPORE 

JAMES J. BLANCHARD, Governor 

DEPARTMENT OF NATURAL RESOURCES 

STEVENS T. MASON BUILDING 

BOX 30028 

LANSING, Ml 48909 

GORDON E. GUYER, Director 

March 11, 1988 

1

 i #-• r\ 

Mr. Kenneth Kensington 

Hastings Reinforced Plastics, Inc. 

1220 W. State Street 

Hastings, Michigan 49058 

Dear Mr. Kensington: 

This letter is in reference to your Permit to Install application for an 

acetone recovery still, located at 1220 W. State Street, Hastings, Michigan. 

This application, identified as No. 78-88, has been evaluated and approved by 

the Air Quality Division, pursuant to the delegation of authority from the 

Michigan Air Pollution Control Commission. 

This approval is based upon and subject to compliance with all administrative 

rules of the Commission and conditions stipulated in the attached supplement. 

Please review these conditions thoroughly so that you may plan for and take the 

actions necessary to ensure compliance with all of these conditions. Also note 

that Condition No. 1 requires you to apply, in writing, for a permit to operate 

within 30 days after completion of construction. 

You are advised that contaminants discharged to the surface waters and/or 

groundwaters; materials disposed of on land; hazardous waste storage, 

treatment, and disposal; and resource recovery facilities must be approved by 

other divisions of the Department of Natural Resources. Additionally, your 

plant environment must be in compliance with all applicable requirements of the 

Departments of Public Health and Labor. 

Approval of this permit does not constitute a waiver by the State of Michigan 

of its right to bring appropriate legal action against the applicant for 

failing to obtain the required permit prior to the commencement of 

construction. 

Thank you for your cooperation, 

regarding this permit. 

Please contact me if you have any questions 

Sincerely, 

\MU&,W*YJJlC 

Linda L. Wardell, Engineer 

Northwest Permit Unit 

Air Quality Division 

517-373-7023 

R1026 

LLWrclp 

Enclosure 

c c : Dick VandeBunt 

1/86 ,.x:~;^.i: £Tf 
P.56 

SUPPLEMENT TO PERMIT NO. 78-88 

Hastings Reinforced Plastics, Inc, 

Hastings, Michigan 

March 11, 1988 

GENERAL CONDITIONS 

1. Rule 208(2) - Not more than 30 days after completion of the installation, 

Applicant shall apply, in writing, for a Permit to Operate. Completion of 

the installation is deemed to occur not later than -commencement of a trial 

operation pursuant to Rule 201(4). Written application should be sent to: 

Chief, Permit Unit, Air Quality Division, Department of Natural Resources, 

P.O. Box 30028, Lansing, Michigan 48909. 

2. Rule 201(4) - Trial operation of the equipment is permitted until the 

Michigan Air Pollution Control Commission acts upon the Permit to Operate. 

Operation of the equipment shall permanently cease upon denial of the 

Permit to Operate by the Commission. 

3. Rule 208(3)(a) and (c) - Applicant shall demonstrate compliance with all 

Commission rules and with all general and special conditions of this 

permit prior to issuance of the Permit to Operate. 

4. Rule 201 - Applicant shall not reconstruct, alter, modify, expand, or 

relocate this equipment unless plans, specifications, and an application 

for a Permit to Install are submitted to and approved by the Commission. 

5. Rule 901 - Operation of this equipment shall not result in the emission of 

an air contaminant which causes injurious effects to human health or 

safety, animal life, plant life of significant value, or property, or 

which causes unreasonable interference with the comfortable enjoyment of 

life and property. 

6. Rule 208(3)(b) - Operation of this equipment shall not interfere with the 

attainment or maintenance of the air quality standard for any air 

contaminant. 

7. Operation of this equipment shall not result in significant deterioration 

of air quality. 

8. Rule 912 - Applicant shall provide notification of any abnormal conditions 

or malfunction of process or control equipment covered by this 

application, resulting in emissions in violation of the Commission rules 

or of any permit conditions for more than two hours, to the District 

Supervisor. Such notice shall be made as soon as reasonably possible, but 

not later than 9:00 a.m. of the next working day. Applicant shall also, 

within 10 days, submit to the District Supervisor, a written detailed 

report, including probable causes, duration of violation, remedial action 

taken, and the steps which are being undertaken to prevent a reoccurrence. 

SS 
P.57 

Hastings Reinforced Plastics, Inc. 

Permit No. 78-88 

Page 2 

March 11, 1988 

9. Approval of this application does not exempt the Applicant from complying 

with any future regulations which may be promulgated under Act 348, P.A. 

1965, as amended. 

10. Approval of this permit does not obviate the necessity of obtaining such 

permits or approvals from other units of government as required by law. 

11. Act No. 53 - Applicant shall notify any public utility of any excavation, 

tunneling and discharging of explosives or demolition of buildings which 

may affect said utility's facilities in accordance with Act 53 of the 

Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan 

Compiled Laws and comply with each of the requirements of that Act. 

12. The restrictions and conditions of this Permit to Install shall apply to 

any person or legal entity which now or shall hereafter own or operate the 

equipment for which this Permit to Install is issued. Any new owner or 

operator shall immediately notify the Chief of the Permit Unit, in 

writing, of such change in ownership or principal operator status of this 

equipment. 

13. Rule 201(5) - If the installation, reconstruction, relocation, or 

alteration of the equipment for which this permit has been approved has 

not commenced within, or has been interrupted for, 18 months, this permit 

shall become void unless otherwise authorized by the Commission. 

SPECIAL CONDITIONS 

14. There shall be no visible emissions from the acetone recovery still. . 

15. The disposal of collected air contaminants shall be performed in a manner 

which minimizes the introduction of air contaminants to the outer air. 

16. Applicant shall not substitute any raw material for that described in this 

permit application which would result in an appreciable change in the 

quality or any appreciable increase in the quantity of the emission of an 

air contaminant without prior notification to and approval by the Air 

Quality Division. 

?6 
P.58 

DEPARTMENT OF NATURAL RESOURCES 

AIR QUALITY DIVISION 

P.O. BOX 30028 

LANSING. MICHIGAN 48909 

STATE OF MICHIGAN 

AIR USE PERMIT 

APPLICATION 

PPLICATION NO. 

FOR AUTHORITY TO INSTALL, CONSTRUCT, RECONSTRUCT, RELOCATE, OR ALTER, -rt Ut-> • ! i lJI\/lSll)r< 

AND OPERATE PROCESS, FUEL-BURNING, OR REFUSE-BURNING EQUIPMENT AND/ 

OR CONTROL EQUIPMENT (PERMITS TO INSTALL AND OPERATE ARE REQUIRED . r n 

BY ADMINISTRATIVE RULES PURSUANT TO ACT 348, P.A. 1965, AS AMENDED). f tlD 6 " 1988 

1. APPUCANT: Business Ucense Name of Corporation. Partnership, Individual Owner, Government Agency 

HASTINGS REINFORCED PLASTICS, INC. >ERMIT SECTION 

2. MAILING ADDRESS: Number and Street; City or Village; State; Zip Code 

1220 W. State St. Hastings, MI 49058 

3. EQUIPMENT OR PROCESS LOCATION: Number and Street; City. Village or Township 

Same as #2 

COUNTY 

Barry 

ZIP CODE 

490^8 

4. GENERAL NATURE OF BUSINESS: 

Assembly & fabrication of composite parts 

5. EQUIPMENT OR PROCESS DESCRIPTION: Acetone Recovery Still: We hand wash out our brushes, rollers, resin 

depositor parts, the acetone becomes contaminated with the polyester resin, we then 

batch together and place in our recovery still to be condensed and recovered. We then reuse the acetone again in our shop, it has been our industry practice to use a recovery 

unit. On the unit we purchased & currently have in use, it is our best estimate from 

our production records we use the unit two (2) times a week and load a 35 gallon batch 

per cycle based on 50 weeks per year. This would be a total of 3500 gallons per year that 

is cycled through the unit. 

The cooling coil in the recovery still is operated in a "closed loop" recirculating tank, 

purchased ice is added to this recirculating tank to keep the recirculating water temperature down so the unit will maintain a high solvent recovery rate. 

This recovery still is located in our plant facilities, 

on file with your agency. 

Our plant facility drawing is 

6. ESTIMATED COST: 

Air Pollution Control Equipment $ 11,500.0 0 Total Project $ 1 3 . 5Q Q . Q Q 

7. ACTION AND TIMING: 

| y | Installation, construction, reconstruction, or alteration 

| j Relocation 

I | Change of Ownership 

ESTIMATED 

STARTING DATE 

ESTIMATED 

COMPLETION DATE 

- already in use 

8. NAME OF PRIOR OWNER AS IN ITEM 1 ABOVE. AND PRIOR AIR USE PERMIT NUMBER. IF ANY: 

NAME PERMIT NO. 

9. NAME AND TITLE OF OWNER OR AUTHORIZED MEMBER OF FIRM 

Name . 

Kenneth L. Kensington 

Twe: General Manager 

Signature 

Date: 12-31~87 

\L K^~» \\^ . 

Phone NO. i 616 945-957

Y 

8 

10. CONTACT PERSON IF DIFFERENT THAN ITEM 9: 

Name W i 1 1 i 3TT1 Rlirahdn f f Phone No. ( filfi Qac;-Q57f t 

1 1 . DISPOSITION OF APPUCATION: 

Receipt of all information 

required by Rule 203 

Permit to install approved * on 

Permit to operate approved * on 

Application/permit voided on 

Application/permit denied on 

FOR DNR USE ONLY 

MAR 11198 8 Signature 

Signature 

Signature 

Signature 

iljutTm* 

'Subject to compliance with all Commission Rules and Conditions stipulated in the attached supplement. 

AQ-1 INSTRUCTIONS FOR COMPLETING AND FILING ARE ON REVERSE SIDE 

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P.62 

'nual Conference, Composites Institute, The Society of the Plastics Industry, Inc. February 8-11, 1993 

JOSEPH S. MCDERMOTT j 

Assessment of the Impact of Environmental Regulation on 

Composites Industry Markets and Processes 

ABSTRACT 

The composites industry is facing the impact of numerous regulatory mandates. 

End users need to know whether any of these measures, or their combined 

accumulation, will price reinforced plastics out of the market or otherwise 

make them effectively unavailable. Materials suppliers need to know whether 

they will bear the greatest impact, through mandated formulation changes or 

through loss of certain applications. Molders and fabricators need to know 

how to manage regulatory compliance and to plan for world-class 

competitiveness. 

This paper reviews the composites industry by material and process, 

relative to markets and dominant applications in each. Then it discusses the,, 

most critical environmental demands on the most vulnerable markets. The 

production adjustments which can be foreseen are identified. 

It is concluded that most environmental requirements can be met by 

present or imminent technology. While a few isolated applications may be 

lost to composites by the adverse impact of environmental considerations, 

such uses were probably marginally viable in any case, because of competing 

materials, process advantages, or cost structure in their markets. It is also 

noted in passing tiiat certain RP applications stand to thrive because of the 

effect of environmental regulations on conventional materials and processes. 

In either case, defensive or expansive, the critical issue for profitability in 

composites will be management's commitment to upgrading processes for 

efficiency and environmental excellence. The primary tool is immediate, 

well-informed, proactive business planning. 

REGULATORY COMPLIANCE CHALLENGES 

T

he best known regulatory challenges are those which present 

serious compliance difficulty. These are identified as: 

1) OSHA's Air Contaminant Standard. Workers may not be 

exposed to more than 50 parts-per-million of styrene, averaged 

over the 8-hour work day, and no more than 100 ppm during any 

fifteen minute period. There is also an increasing incidence of 

enforcement of the provision for exposure to nuisance dust, at 5 

mg/m3 for the respirable fraction and 15 mg/mJ for total dust. A 

permissible exposure limit of 1 fiber/cm3 has been proposed for 

glass fiber. These PELs require open process or so-called contact 

molders (spray-up, hand lay-up, many filament-winding operations, and some others) to install a variety of remedial controls. 

2) EPA's Clean Air Act. The 1990 amendments to the Act provide 

in Title I for ozone abatement on a phased-in schedule, relative to 

regional severity of the smog problem. Title III identifies 189 

hazardous air pollutants, including styrene, which must be controlled by the adoption of Maximum Achievable Control Techt Composites Services Corp. 

1 / SESSION 5-C 

nology (MACT), to be determined by industrial process category. 

Title VI addresses depletion of ozone in the upper atmosphere and 

will affect a number of users still employing CFCs. The implementation of these provisions is spelled out in Title V, which will 

extend rigorous requirements for air pollution permits to most 

industrial sources. This environmental regulation will, affect 

virtually all RP processors. The compliance difficulty will vary 

widely depending on a facility's location, the materials handled, 

process or engineering controls, the practices of other sources in 

the category, and the implementation priorities adopted by the 

state or regional air quality management district. 

3) Waste management, recycling in particular. For most RP 

processors, the issue of hazardous and solid waste disposal is a 

matter of understanding options and the expense, rather than 

technical feasibility. The public demand at present for high 

recycling rates is not yet embodied in statutes, but nevertheless is 

a serious problem in certain market sectors. Durable goods endusers, concerned for their image among consumers, are requiring 

their suppliers to achieve environmental "correctness," with an 

impact that in some cases is more immediate than complying with 

a regulation that has emerged from due process negotiation. 

4) Public right-to-know, in several forms. Just as the demands of 

important customers receive immediate attention, apart from a 

regulatory mandate, there are certain new regulations whose 

compliance simply requires the presentation of infonnation. 

Although such rules do not set a performance standard, often the 

community disclosure provisions exert a serious pressure on an 

industrial facility. The annual Form R Estimate of Releases to the 

Environment, for example, required as part of the Superfund 

amendments of 1986, has become a powerful tool in the hands of 

local environmental groups. When the access to records is combined with imperfect knowledge of health risk, or a sensitive local 

situation (such as nuisance odor), the impact on a processor can 

be greater than that of a negotiable citation for an OSHA or EPA 

citation. Another example is the requirement in many states that 

the air quality or stormwater discharge pennit include the step of 

a local public hearing. Often these forums prove more grueling 

for small manufacturers than compliance with a permissible 

limit, or the expense of the permit fee. 

OTHER REQUIREMENTS 

The above four types of regulation are not the only environmental 

rules which processors must observe. But other OSHA, EPA, and 

local forms of regulation are not typically compliance problems 

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unless they have been overlooked, or there is some unusual circumstance. They are generally a time and cost concem. In this category 

we put the OSHA Hazard Communication Standard (MSDS, labeling, and written training programs), written programs for controlling 

hazardous material spills, leaking underground storage tank 

remediation, and accommodation to the needs of the local fire 

protection service. 

BEYOND COMPLIANCE 

Before discussion of whether any sectors of the RP industry are 

threatened by the difficult rules cited, it is worth noting that merely 

"meeting the standard" is not winning, in the field of environmental 

management. Continually being on the defensive and reacting is not 

associated wim control. The Responsible Care(sm) program of the 

Chemical Manufacturers Association sets a higher standard. A 

facility controls its own destiny when top management initiates 

programs to provide a safe workplace and make a healthful impact on 

the community, beyond observance of the number or letter of the la w. 

Operators who set their own standards of excellence seldom pay 

fines and do not have to worry about compliance. 

OSHA'S AIR CONTAMINANT STANDARD 

As a legal technicality, the Occupational Safety and Health Administration has been set back in vigorous enforcement of the Air 

Contaminant Standard, as this paper is written. A court decision has 

found that OSHA did not thoroughly document the need for, or the 

safety of, certain ofthe Permissible Exposure Levels in this Standard. 

But while OSHA's appeals are on file the standard is still in effect. 

Even if the finding of record holds, it is likely that the PEL will be reinstituted through some other proceeding. An RP operator would not 

be well-advised, from various liability perspectives, to believe he can 

ignore the proposed 50 ppm and 100 ppm levels. 

This standard has significant impact on more than half of the 

U.S. RP industry, because statistics indicate that contact molding 

still dominates production (Table 1). The markets served and products made by these processes will not disappear abruptly as the 

result of institution of the standard as proposed, but compliance will 

be difficult. 

First, the regulation itself provides for the use of personal protection equipment (respirators) for builders of large boats and similar 

structures when engineering controls are infeasible. But those seeking this exemption will in most cases be required to develop expensive documentation of the technical infeasibihty. And the cost of 

implementing a respirator program, itself subject to standards, is not 

to be taken lightly. • 

A more welcome finding is the fact that spray booth operators and 

hand lay-up technicians are able to maintain exposure levels somewhat below the requirements of the standard, by using a combination 

of engineering and administrative techniques, without respirators. A 

number of molders are doing so, through re-design of work stations 

and worker training. The other features which play a part are 

specifically-designed laminar air flow, high-efficiency transfer equipment, resin formulation, and tool or worker mobility. There is also a 

segment — though not a dominant part — of the contact molding 

group which can resort to closed processes such as resin transfer 

molding as an altemative. A variety of economic and design considerations affect the viability of this option. It goes without saying that 

to the degree contact molders are hard pressed to implement a range 

of such solutions, there is opportunity for suppliers or technologies 

which enable molders to reduce exposures and meet the standards. 

But what if the PELs were further reduced, to the 25 ppm level 

cited in some Scandinavian countries? In our opinion, markets would 

still not be lost to RP. But there would be a significant reduction in 

the number of tub/shower, lavatory, and truck cap manufacturers, for 

example, and of employment in such contact molding sectors. As 

many as 25% or one-third of the small operators, undercapitalized 

and with several other non-complying conditions, would not be 

viable enterprises. The surviving processors, with reduced competition, would in some cases then be able to leverage increased market 

share to invest in closed molding or new process development. In 

fact, theoretically, one can imagine that, forced to upgrade manufacturing to RTM or SMC compression molding, some RP producers 

would achieve quality and efficiency that would further drive aluminum, cast iron, ceramic tile, and thermoformed plastic to reduced 

market share. 

EPA CLEAN AIR ACT 

The Environmental Protection Agency, through the states, is faced 

with one of its most complicated tasks in implementing the many 

specific provisions of the 1990 Amendments. Since styrene, and 

acetone used widely in open process clean-up, generate emissions 

which are precursors to ground-level formation of ozone, the use of 

these materials will be a high priority for reduction in metropolitan 

areas which exceed national ambient air quality standards for smog. 

The industry is fortunate to the extent a significant improvement can 

be made at individual facilities using acetone, because altemative 

cleaners are gradually proving themselves as new systems able to 

supplant a majority of acetone use. For a time, this reduction may 

shield some operators from the demand that styrene emissions be 

curtailed drastically. The mechanism for such reduction would be 

Reasonably Available Control Technology (RACT, not to be confused with MACT in Title III, below) as specified in an EPA Control 

Technology Guideline. In the absence of a CTG for reinforced plastic 

processing, regulators would borrow allowable emission ranges 

from analogous industrial processes. 

Title III of the Amendments regulates air toxics through Maximum Available Control Technology (MACT). The definition of 

MACT for various industries will be established through an EPA 

survey, in the best case assisted by industry participation. The law 

calls for EPA to identify the environmentally top performing 12% of 

an industry, taking into account economic cost/benefit ratios, and 

identify their technology or practices as MACT for all other industrial sources so categorized. MACT for some large industries has 

already been defined. Recently we have learned that MACT for 

reinforced plastics processes, and a separate MACT for boat builders, will enter the research-and-drafting stage at EPA early in 1994. 

Then the required level of performance is to be promulgated in 1997, 

and several years are alio wed for implementation by affected sources. 

The industry, through the coalition of trade associations known as the 

Clean Air Management Partnership (CAMP) has been successful in 

establishing a means of doing research to assist EPA in developing 

MACT. The intention, of course, is to accurately describe air toxics 

emissions from RP processes, and to see that similar processes are 

grouped in the proper categories. 

The Immediate Problem 

This rational approach, with generous time for planning, has now 

turned into a problem because of other features ofthe Act, such as its 

penalties on the states for slow implementation, and the impatience 

of environmental activists. In essence, we have 50 "clean air acts" in 

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the U.S., because the State Implementation Plans (SIPs) are not 

waiting for MACT. In their urgency to maintain their share of Federal 

funding, and meet political pressures, states are resorting to abstract 

risk assessments based on conservatively written air dispersion 

modeling. Several historical EPA listings and assessment programs 

enable zealous state mathematicians to calculate health effects on the 

community with ambient air level counts of styrene at the part-perbillion level. It is at this regulatory crossroads that the status of 

styrene as a possible carcinogen becomes critical, for the factors of 

the community exposure calculation change by a factor of at least 10, 

depending on whether carcinogens or simply hazardous air pollutants are being evaluated. 

The ambient air level (AAL) risk assessments are an immediate 

issue for the RP industry because operators are obliged to apply for 

permits when adding new equipment, expanding a facility, or locating a new start-up operation. We have served as consultants to 

investors who have declined to relocate operations in one area as 

compared to another because of inhospitable interpretation of computer modeled risk assessments, or the perception that permit approval would be granted only if expensive end-of-the-stack control 

technologies were made part of the construction plan. Once again, 

the impact ofthis regulation is not likely to close markets or eliminate 

RP products, but it will affect individual companies and perhaps the 

geographical distribution of molding facilities. 

A long-term aspect ofthe future for RP processors with measurable emissions is definitely their location. Should they be as remote 

from other sources as possible? Not necessarily. Some regional 

offices are more zealous than ever to "prevent further deterioration," 

and a new source in a non-industrialized area will be the nail which 

sticks out and gets hammered down. On the other hand, if a processor 

is located next to a Fortune 100 chemical producer which signs on to 

EPA's voluntary "zero emissions" effort, and the large company 

makes significant improvements, the smaller source could soon find 

itself the prominent "polluter" in its neighborhood. 

The alert manager in our industry will have developed a working 

relationship with the local air quality management district, and 

"greenfield" proponents will take the first opportunity to do so. There 

is a degree of flexibility in local implementation plans. A cooperative 

attitude, followed by education of the regulator on the operating 

needs ofa facility and the willingness to adopt reasonable abatement 

measures will at present assure an operator of securing permit status 

in most cases. 

RECYCLING 

Thus far this presentation makes it appear that open process molders, 

including those who spread resin over mat open to the air before 

compression, or those with open resin baths in pultrusion or winding, 

are most environmentally threatened, and that injection molders, 

compression molders, or those with otherwise low emissions inside 

the plant or to the outside air, are relatively "safe." This is too quick 

a conclusion. 

First, even those operations which are in prior compliance with 

OSHA standards and EPA regulations will need to take the measurements, demonstrate compliance, and achieve lowest achievable 

emission rates relative to their process category. This documentation 

itself is a requirement, and demands attentive effort. 

The biggest environmental problem for high-volume, closed 

process RP molders may come from their markets and customers. 

Counter-intuitively, the success of composites in automotive products is the start of this issue. Competing materials forced our industry 

to prove that "thermosets are not recyclable" is a fallacy. But, next, 

automotive waste after a vehicle's useful life became significant 

enough a concern in Europe, as embodied in German regulations, to 

have spread to the U.S. and Japan as well. In Europe the automotive 

OEM and in turn their suppliers are obliged to provide for the reuse 

or disposal of plastic components, at least at the level of secondary 

or tertiary recycling. Incineration, or waste-to-energy disposal, does 

not qualify as recycling in many parts ofthe world at this time. "Neat" 

thermoplastics demonstrate capability to be melted for reuse in 

molding the same part as the reclaimed item (secondary recycling). 

Or, when engineering properties degrade to some extent, at least a 

polypropylene dashboard element can be recycled into a battery case 

housing where appearance requirements are not as stringent (tertiary). Thermosets, and reinforced thermoplastics for that matter, do 

not demonstrate melt recyclability as readily. They require more 

steps, but recycling of RP — at least the salvage from production 

operations, if not post-consumer waste—has now become commercial through granulation techniques. The current amount of recycle 

content, at 20% by weight of such filler in SMC components, if it 

proves to be a limit, could be criticized in the future as insufficient to 

qualify composites as sufficiently recyclable, relative to glass, aluminum, and some forms of thermoplastics. 

As an aside, the answer of the advanced composites industry, 

speculatively, is to qualify for primary recycling: remove the carbon 

fiber/high temperature resin drive shaft from an overage vehicle and 

use it intact in a new model. 

Closed-process molders face at least two other potential problems 

in the future. The other demonstrated technology for reclaiming 

composites, pyrolysis, may not prove economically supportable or 

"green" enough for purists who associate it with incineration and 

overemphasize the energy demand. The second problem is the 

dismantling and collection infrastructure for post-consumer durable 

goods, which does not fully exist yet. In Europe it is already felt that 

OEMs wish to hot wire the closed loop recycling goal by reducing the 

varieties of materials in their products. A bumper component today, 

for example, would be attacked by a crew of dismantles who would 

take some time to cope with adhesives, metal fasteners, and up to four 

types of structural plastic material (surface, fascia, beam, supports, 

etc.). If dismantling and recycle become dominant practices, end 

users may be inclined to look at specifying a single material, even at 

some invoice-cost penalty, if composite construction is a cost center 

at disposal. 

Another adverse feature of this scenario is that the high valueadded customers sought by composites manufacturers tend to be the 

same blue chip organizations eager to upgrade or promote an environmental image. They may exclude composites from serious consideration without proponents even being aware ofthis factor in the 

equation. The SMC industry is rumored to have had a taste of this 

behavior with regard to retooling the General Motors APV for steel 

exterior panels. A contributing factor is said to have been the 

reluctance of the.European marketing arm to be "stuck with" the 

recycling uncertainty of RP. 

The industry's response on the recycling issue, through trade 

associations here and consortia abroad, make it clear that the subject 

is taken seriously. In our opinion, the energy-conservation and lifecycle costs of composites are a trump card in favor of RP when the 

economic analysis is at its most comprehensive. This will be even 

more true if another round of CAFE mileage limits is introduced, and 

if altemate-fuel/energy vehicles become a significant part of the 

transportation market. In the meantime it is essential that the industry's 

members participate in public policy discussions of waste management altematives and the development of collection infrastructures. 

In our opinion the public has not begun to face the effects of success 

3 / SESSION 5-C 

Gi 
ft i 

if? 

LC' 

fe 

were recycling rates ever to approach the 50% waste stream volume 

set as a goal. The unmanageable accumulations of no market material in that scenario may drive depolymerization technology as a 

reclamation alternative, or stimulate acceptable forms of incineration for energy recovery. In that case the corrosion-resistance of 

composites in all types of storage vessels, containers, and process 

control equipment is likely to increase demand for our materials 

rather than weaken it. 

CONCLUSION 

Is the impact of environmental regulation adverse or beneficial to the 

growth of composites? It seems too early to tell. It is a safe bet that 

there will be individual cases of winners and losers. 

Who should be concerned? Two groups. Those committed to 

production and applications of composites which have environmental drawbacks and are marginally competitive in already progressive 

markets. Bellcore, the R & D arm ofthe regional telephone companies asserts that thermosets as we know them in circuit boards and 

electronic packaging are in the way of a speeding train. "The 

opportunity to injection mold chip, carrier, fiber optic connector arid 

package as one unit, by high-heat, dimensionally-stable, liquid 

crystal polymers is simply too great to pass up, even at $20/lb. for the 

material," Part ofthe motivation in this statement is the escape from 

assembly hazards, etching, and cleaning solvent baths. But a composites player in such markets cannot blame environmental issues as 

the sole factor in the superseding of applications. Where competitors' other performance features are a small part of the equation, 

however, the RP molder must minimize disadvantages, real or 

perceived. The second group who need to seek remedies are processors, and suppliers who depend on them, who are behind on health, 

safety, and environmental initiative. They must seek markets, or 

develop them, which give sufficient return to allow investment in 

environmental improvement ahead of the cutting edge. Knowledgeable investors, valuation professionals, suppliers and customers are 

beginning to review processors' budgets or business plans for environmental line item expenditures. Penalties and citation fines will be 

a negative. Allocations for new equipment, training, and monitoring 

for constant improvement will identify the winners. 

BIOGRAPHY 

Joseph McDermott 

Joseph McDermott was awarded the Masters Degree in 1966 following a joint program at Columbia and Fordham Universities, New 

York City. 

His career began in governmental and association activities. 

From 1976 to 1985 he was manager of the Reinforced Plastics/ 

Composites Institute of the Society of the Plastics Industry, Inc. 

In 1981 Mr. McDermott was a founder of Composites Services 

Corporation, an independent management consulting organization 

which provides single-client market research, business intelligence, 

and counsel on environmental regulatory compliance. Since 1985 he 

has served as CSC President. 

Mr. McDermott is chair of the Air Issues Task Force of the SPI 

Occupational Health and Environmental Issues Committee, a policy 

unit of the SPI Board. He is editor of the Environmental Audit 

Manual ofthe Composites Fabricators Association, and was 1990 

Occupational Health and Safety Program service award honoree by 

the Society of Advanced Composites Materials Association. 

TABLE 1. Open Molding Process Production Based on SPI Composite Institute Market Statistics, 

Rounded for Cyclical Variation, millions of lbs. 

major market 

(total) 

constniction 

470 Mm lbs. 

corrosion-resistance 

350 Mm lbs. 

marine 

350 Mm lbs. 

transportation 

700 Mm lbs. 

other 

630 Mm lbs. 

total: 2.5 billion lbs. 

% open process 

60% 

85% 

90% 

+50% 

varies 

55% 

volume open process 

280 Mm. lbs. 

300 Mm. lbs. 

315 Mm. lbs. 

375 Mm. lbs. 

+/-100Mm. lbs. 

1,370 Mm. lbs. 

products 

tub/shower; 

lavatories; 

architectural 

specialties; 

fascia panels. 

tanks; 

pipe fittings 

scrubbers; 

ducts, etc. 

recreational 

boats; work 

boats and 

marine equip. 

heavy truck; 

pickup caps; 

bus, metro, 

RR pans. 

housings, 

vaults, and 

containers. 

G* 

SI-SSIO'-.' 5-C / -1 

^ 
48th Annual Conference, Composites Institute, The Society of the Plastics Industry, Inc. February 8-11, 1993 COPY 

LISA M. ADKINS t 

KATHY E. KITCHEN t 

DANNY S. LANDES t 

The Determination of Styrene Emissions During the Hand 

LayUp and Spray-Up rrocceses 

ABSTRACT 

Over the past decade, environmental regulations have become increasingly 

more stringent. Many of these regulations are affecting the reinforced plastics 

(RP) industry. Perhaps the regulations causing the most concem are those 

regarding volatile organic compound (VOC) emissions. The VOC which is 

of the most concem to the RP industry is styrene. 

Resin manufacturers are responding to these regulations in a variety of 

ways. One method involves developing resins with lower levels of styrene. 

Another method uses other monomers which are less volatile than styrene. 

These methods are receiving a great deal of interest from fabricators in hopes 

that using a resin with a lower level of styrene or with a different monomer 

will decrease emissions during fabrication processes. 

This paper investigates the amount of styrene lost during two common 

processes used in fabricating RP equipment: hand lay-up and spray-up. The 

spray trials are performed under shop-like conditions and the hand lay-up 

work is done under laboratory conditions. Using resins with various styrene 

levels, the percent styrene is measured before processing, immediately 

following, and thirty minutes later. Styrene loss is measured in two ways, 

parts per million in the air and percent weight loss ofthe part. The results will 

help to detennine if a resin containing a lower percent of styrene will emit less 

styrene during processing than a resin with a higher level of styrene. 

Fabricators can then use this infonnation to help estimate emission levels 

based on resin type, usage, and fabrication process. 

INTRODUCTION 

T

he importance of controlling and decreasing styrene emissions 

is steadily increasing as governmental regulations become 

more stringent. These new regulations have prompted resin manufacturers to investigate economical, realistic ways of controlling 

styrene emissions. Early work evolved around the use of wax 

additives; more current technology involves additive blends which 

are not solely wax containing. In his work with suppressed resin 

systems, Duffy [1] found that an unsuppressed resin system with 47 

percent styrene lost approximately 1.7 percent styrene as compared 

to a suppressed system which lost approximately 0.8-0.9 percent. He 

was able to reduce emissions by as much as 50 percent using a 

specific suppression system. However, potential problems involving 

interlaminar adhesion were encountered with the wax-containing 

systems. Because of these concerns, resin manufacturers began 

investigating other options. They focused particularly on systems 

containing lower percentages of styrene and systems with entirely 

different, less volatile monomers. Saamanen et al. [2] showed that 

during the hand lay-up process, low styrene resins lost from 30 to 60 

t Ashland Chemical, Inc. 

©1992 Ashland Chemical, Inc. 

percent less styrene than standard resins. 

In this study, resins with various levels of styrene were evaluated 

in an effort to correlate the loss of styrene during hand lay-up and 

spray-up operations with the styrene content ofthe resin system. The 

results show that resins with lower styrene content release less 

styrene during spray-up and hand lay-up than resins with higher 

styrene content. The data will also provide the industry with an 

option for meeting California South Coast Air Quality Management 

District Rule 1162. 

EXPERIMENTAL 

A total of seven resins, ranging in styrene content from 32.5 to 48 

percent, were used for the spray-up and hand lay-up trials: five vinyl 

esters, one isophthalic polyester and one chlorendic polyester. Two 

of the five vinyl esters were low styrene resins (Table 1). Currently, 

the majority ofthe data available on low styrene polyesters indicates 

that when the styrene content is lowered to 34.5 percent and the resin 

molecular weight is altered to maintain a workable viscosity, a 

reduction in corrosion resistance is observed. This reduction in 

conosion resistance is due mostly to the alteration of the polymer 

backbone. Since low styrene (LS) vinyl esters do not show the same 

loss in corrosion resistance as LS polyesters, two LS vinyl esters 

were chosen to be evaluated in this study. 

Spray-up 

All styrene measurements were taken using aThermo-Environmental Model 580S photoionization detector (Figure 1). The detector 

monitored the overall maximum styrene level and also the instantaneous styrene level. Each resin was sprayed using a Glas-Craft A AC 

air assist containment spray gun with extemal mix (Figures 2 and 3). 

The spray gun pressure dials were set before spraying and remained 

constant for all resins: resin pressure = 70 psi, atomizing pressure = 25, and air assist containment pressure = 30. 

Uncatalyzed resin was then sprayed into a 21 " x 21 " mold 

containing two layers of chopped glass mat. The mold was contained 

in a hood with an air flow of 1523 ft.'/min. This work was done in a 

hood in order to ensure that the conditions, primarily the ventilation, 

were consistent throughout the testing period. The level of styrene 

was measured in two ways, using a styrene detector to measure levels 

in the air and by calculating styrene loss by weight. 

Before spraying, the initial level of styrene in the air was recorded. During the thirty second spraying process, the spray gun 

operator stood five feet from the mold and the styrene detector w.-ix 

SISSHIN 5-B ,' I 

• I! 

I Mi 

^l 

e s 

x 

ii 
held next to the operator at approximately breathing level (Figure 4). 

An average of the styrene readings taken during spraying was 

recorded. Thirty minutes following spraying, the level of styrene in 

the air was recorded at approximately the same position as during the 

actual spraying. 

Styrene loss by weight was determined by taking a resin sample 

before spraying, immediately following spraying, and thirty minutes 

later. The initial sample was taken from the five gallon pail used for 

the spray trials and both of the other samples were taken from the 

resin which was sprayed into the mold. The percent styrene of each 

sample was measured using the hot plate method. An aluminum 

weighing dish was tared and 0.5 grams of resin were weighed into the 

dish. Approximately 1 ml of toluene solvent was added to dissolve 

the sample. The dish was placed on a 150°Chot plate for 15 minutes 

and was then removed, allowed to cool and re-weighed and the 

percent solids was calculated. 

Hand Lay-up 

The styrene loss during hand lay-up was determined under laboratory 

conditions using uncatalyzed and catalyzed resins. In both cases, 

laminates were made with three plies of 1-1/2 oz. chopped mat and 

one ply of C-glass veil, for a total glass content of 28%. The weights 

of the resin, glass, Mylar® release film, and cardboard base were 

recorded. The styrene level in the laboratory was measured before 

beginning the lay-up process. The laminate was then laid up using a 

tongue blade to spread the resin and saturate the glass. A roller was 

not used in this study because it would have made it difficult to obtain 

accurate resin weights because significant and variable amounts of 

resin can be lost by clinging to the grooves in the roller thus 

significantly changing the resin to glass ratio from one laminate to 

another. In the work done by Saamanem et al. [2], a large percentage 

of styrene was lost during the rolling process. Since the amount of 

styrene lost during the actual rolling process was not measured in this 

study, the amount of styrene lost by the resins tested in this study 

could vary depending on rolling time. The initial weight of the 

laminate was recorded. The styrene detector was placed twelve 

inches away from the laminate for all readings (Figure 5). 

Styrene loss was recorded in two ways, using the styrene detector 

and measuring sample weight loss. Air and weight measurements 

were recorded before beginning the lay-up process and additional 

readings were taken at twenty, thirty, and sixty minutes. 

Each resin was then promoted and catalyzed to twenty and thirtyfive minute room temperature gel times. With the twenty minute 

samples, additional weight and styrene level readings were taken at 

twenty, thirty and sixty minutes. For the thirty five minute gel time 

samples, weights and styrene readings were recorded at thirty, forty, 

and ninety minutes. Different times were chosen in order to record 

styrene levels near the peak exotherm at which time a significant 

amount of styrene was expected to be lost 

RESULTS 

The spray-up results show that there is a significant correlation. 

between weight loss due to styrene evaporation during spraying and 

styrene content of the resin (Figure 6). Figure 6 indicates that resins 

with a lower percentage of styrene tend to lose less styrene during the 

actual spraying process as compared to standard resins. The measurements taken with the styrene detector during the spraying process did not show any significant correlation between styrene vapors 

in the air approximately six feet from the mold and the level of styrene 

in the resin. 

The data for the uncatalyzed laminates shows a correlation 

between styrene lost after thirty minutes and styrene content of the 

resin (Figure 7). Here again, as the styrene content increases, the 

amount of styrene lost increases. 

For both the uncatalyzed and catalyzed laminates, a correlation 

between the level of styrene measured above the laminate and the 

percent styrene in the resin can be developed by taking an average 

of the styrene readings recorded at zero, twenty, thirty, sixty, and 

ninety minutes (Figure 8). This figure shows that, in general, as the 

styrene content ofthe resin increases, the amount of styrene emitted 

increases. 

For the laminates catalyzed at both 20 and 35 minutes, the styrene 

lost based on total styrene content correlates with the styrene content 

ofthe resin. At approximately 40 minutes after the initial gel ofthe 

resin, the amount of styrene lost is less for the LS resins than for the 

standard resins (Figure 9). 

The catalyzed laminate data can also be compared to the styrene 

lost from a suppressed system. Duffy [1] reported that a suppressed 

laminate made with an orthophthalic resin at 45 percent monomer 

and three plies of 1.5 oz. chopped mat lost 1.9 percent styrene after 

sixty minutes. This value is comparable to the 2.1 percent styrene lost 

after sixty minutes by the LS resins catalyzed to a 20 minute gel time. 

For both the uncatalyzed and catalyzed samples, the weight loss 

verses the air measurements above the laminates was graphed. The 

results showed that there was a general trend with greater air readings 

correlating with greater weight loss. 

CONCLUSIONS 

For both the low styrene and standard resins, about 80 percent ofthe 

total styrene emitted is lost during the actual spraying process. The 

remaining 20 percent is lost during the thirty minute period setting in 

the hood. During spraying as well as over the entire thirty minute 

period, the LS resins lost less than half a percent of styrene as 

compared to 3.5 to 9 percent for the standard resins. 

During the hand lay-up process, the LS resins lost an average of 

20 to 40 percent less styrene than the standard resins. 

Styrene lost by LS resins is comparable to that lost by suppressed 

systemsVf4owever. the LS resins provide an advantage over thq 

suppressed systems in that there is not the potential for secondary 

bonding nroblems caused bv wax in the system. 

The data gathered in this study indicates that resins with a lower 

styrene content emit less styrene during the spray-up and hand layup processes. Such characteristics will make these resins attractive to 

fabricators and end-users who are concerned about meeting everincreasing environmental regulations. 

Prices of low styrene resins will be higher than standard resins 

because of higher raw material and processing costs of the plastic 

compound versus styrene. However, in the long run, they can be 

more cost effective in that more material will remain in the laminate 

rather than being lost through evaporation. 

REFERENCES 

1. Duffy, M. J. 1979. "Styrene Emissions—How Effective are Suppressed 

Resins?" 34th Annual Technical Conference, Reinforced Plastics/Composites Institute, SPI. 

2. SaSmiinen, A. J., R. I. NiemilS; T. K. Blomqvist, and E. M. Nikander. 

1991. "Emission of Styrene During the Hand Lay-Up Molding of Reinforced Polyester." Applied Occupational Environmental Hygiene, 6(9): 

790-793. 

2 / SESSION 5-B 

^3k 66 
P.68 

BIOGRAPHIES 

Lisa M. Adkins 

Lisa M. Adkins is aTechnical Service Represenlative in theComposite Polymers Division of Ashland Chemical, Inc. ln addition to 

technical service, she is responsible for research and development in 

lhe area of corrosion resistant and flame retardant resin systems. Lisa 

is a graduate of Mary Washington College where she received a 

bachelor of science degree in chemistry. 

Kathy E. Kitchen 

Kathy E. Kitchen is a Technical Service Representative in the 

Composite Polymers Division of Ashland Chemical, Inc. Hercurrent 

responsibiliiies arc in lechnical service for corrosion resistant, flame 

retardant. and pultrusion resins. Kathy is a graduate of Ohio Stale 

Universiiy wilh a bache!or*s degree in Geology. She has been with 

Ashland Chemical, Inc. for 16 years. 

Danny S. Landes 

Danny S. Landes is a research technician with Ashland Chemical, 

Inc., Composite Polymers Division. His primary responsibility is 

supporting lechnical service in the area of corrosion resistant and 

flame retardant resins. Danny has been with Ashland Chemical, Inc. 

for 5 years. 

TABLE 1. Resin 

Resin 

LS vinyl ester 

LS vinyl ester 

vinyl ester 

chlorendic polyester 

' vinyl ester 

isophthalic polyester 

vinyl ester 

Types and Styrene Levels 

Styrene Level (%) 

32.5 

34.0 

41.8 

42.7 

45.2 

45.5 

47.8 

FIGURE 1. Photoionization detector. 

FIGURE 2. Spray gun apparatus. FIGURE 3. Sptay gun head 

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FIGURE 4. Operation of spray gun and detector. 

FIGURE 5. Placement of detector during laminate 

measurements. 

Styrene Loss During Spraying (%) 

_ 

: 

_ . . . ;.....• 

1 1 

1 i 1 i .1 

o 

o 

^ a 

• 

1 i 

^ O 

i 

4 

3.5 

3 

2.5 

2 

1.5 

1 

0.5 

0 

-0.5 

-1 

30 32 34 36 38 40 42 44 46 48 50 

Styrene Content in Resin (%) 

FIGURE 6. Styrene loss, based on total styrene content, os measured with styrene detector. 

Styrene Loss During Setting (%) 

30 32 34 36 38 40 42 44 46 48 50 

Styrene Content in Resin (%) 

FIGURE 7. Styrene loss, based on total styrene content, during setting, uncatalyzed laminates. 

4 / SESSION 5-B 

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100 

Average Styrene Level Above Resin (ppm) 

7 5 -

50 

25 

° Uncat. 

+" 20 min. 

* 35 min. 

_ 

-

+ 

3 

aminates 

gel time 

gel time 

* 

+ 

*^"^ 6 

X 

% ° 

' + 

3K 

i 

o 

3* 

a 

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i 

D 

30 32 34 36 38 40 42 44 46 48 50 

Styrene Content in Resin (%) 

FIGURE 8. Slyrene concentration above resin as measured by styrene detector. 

4 

3.5 

3 

2.5 

2 

1.5 

1 

0.5 

n 

Styrene Loss During Setting (%) 

_ 

....;. ... —^-" 

_.. :*... ' 

_ , _.i .. i ...i 

• 

• • : 

* 

i 

•' • 

. 

• x 

•• * • ; 

* 20 min. gel time 

* 35 min. gel time 

30 32 34 36 38 40 42 44 46 48 50 

Styrene Content in Resin (%) 

FIGURE 9. Slyrene loss, based on total styrene content, 40 minutes afler gel, catalyzed laminates. 

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