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OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

8) IV-B-8 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 8 of 273 
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^V-SZ . 

FINAL TRIP REPORT 

NONCONFIDENTIAL VERSION BASED ON PLANT COMMENTS 

MEMORANDUM 

TO: 

FROM: 

DATE: 

SUBJECT: 

REFERENCE: 

Project file of Reinforced Plastics Composites Manufacturing NESHAP 

Keith Barnett, U. S. Environmental Protection Agency, Emission 

Standards Division 

March 13, 2002, Revised October 17, 2002 

Site visit to Hydro Systems, Inc. 

Reinforced Plastic Composites Manufacturing NESHAP, ESD Project 

No. 93/58 

I. INTRODUCTION AND PURPOSE 

The purpose ofthis visit was to obtain information on the reinforced plastic 

composites manufacturing operations at the Hydro Systems facility in Simi Valley, 

California. Specifically we wanted to focus on the carbon adsorption control 

system. 

H. PLACE AND DATE 

Hydro Systems, Inc. 

50 Moreland Road 

Simi Valley, CA 93063 

805-584-9990 

February 14, 2000 

III. ATTENDEES 

Mr. Larry Burroughs, Hydro Systems, Inc. 

Mr. Keith Barnett, U. S. Environmental Protection Agency 

Ms. Melanie Proctor, Pacific Environmental Services 

Mr. John Schweitzer, Composite Fabricators Association 

IV. SITE INFORMATION 

This facility started up in November/December 1987. They originally operated on their 

permit to construct and had 3 stacks 6-8 feet above the roof. They put in a carbon adsorption 

system in 1988 because they had a number of odor complaints from the surrounding residential 
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areas. The facility has prepared answers to specific questions on control system design and costs. 

The questions and answers are included as attachment 1. 

Process description 

This facility mainly produces bathtubs, though some shower and shower pans are 

produced. They sell to the wholesale plumbing market. All products are made to order. The 

facility has a total of 35,000 square feet of production area. 

Flat acrylic sheets are heated and then vacuum formed to create the surface ofthe tub. 

The formed acrylic sheet then becomes the mold. There are no HAP emissions from this step of 

the process. The sheet is then placed on a wheeled dolly and rolled to the chopper booth. 

The chopper booth is open on three sides. The air intake is in the back ofthe booth. A 

mixture of filler and laminating resin is sprayed using a Polycraft airless spray gun. This step 

takes about 3 minutes. The tub is then moved out ofthe chopping booth area to an area in front 

ofthe tooling booth and is allowed to cure for approximately 1 hour. The actual resin cup cure 

time is 5 minutes, which is fairly short for a lamination resin. After about an hour of cure time, 

tubs are moved back to the chopper booth and receive a second coat ofresin and chopped glass. 

The final product is weighted. Every tub has to meet a weight standard 

The facility operates 2 shifts (16 hr/day). The second shift does not do composites 

production, they prepare the for the day shift. The outdoor temperatures reach the mid-80s in 

summer and are above freezing in winter. 

The styrene concentration on the chopper and roll out areas are < 20 ppm. The remainder 

ofthe plant is in the 1-5 ppm range. Hydro Systems believes the low styrene concentration in the 

plant are due to a vapor suppression effect ofthe filler, and the short resin gel time. The filler also 

gives the product some fire retardancy. They use resin specification sheets for resin monitoring. 

Less than five percent ofthe production has gel coats. This includes tools and some tubs 

and showers. A mold (or plug in the case of tool production) is sprayed with a gel coat in the gel 

coat booth and cures on the production floor. The gel coat booth is enclosed. The remainder of 

the process is the same as that ofthe acrylic tubs. 

The facility also has a booth for making tools (molds). In the tooling booth, tooling resin 

is applied to the gel coated plug manually. Both the tooling and gel coat booth are rarely in 

service. 

All spray booths run 24 hours per day. The chopper booth has an airflow of 24,000 cfm 

and a 10 hp fan motor. The tooling and gel coat booths have flows of 12,000 cfm each and 5 hp 

motors. 

Resin is purchased in bulk (received in 20,000 pound tanker trucks) and stored in covered 

tanks. They pump 1 days production to a high shear mixer where the filler is added. This mixing 

step also generates a lot of heat. The mixed resin and filler are then pumped to a covered day 
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tank. There is a heated 1.5 inch line from the day tank to the chopper gun. Tooling resins are 

received in 55 gallon drums. Gel coat is received in 5 gallon pails. 

Carbon adsorption system 

As a result of odor complains, Hydro Systems looked at options to reduce the ambient 

impact of their styrene emissions. One option considered was taller stacks and more velocity. 

The carbon adsorption system was next cheapest. The carbon system was chosen because they 

considered it to be a known technology. West States Carbon did most ofthe system engineering. 

A sheet metal fabrication company assisted in the design. 

The adsorption system was installed in 1988 and consists of flat panels that look similar to 

pleated air conditioner filters except they are larger, about 3" thick, and filled with activated 

carbon. The chopper booth is set up with 3 passes of carbon. There are 396 panels total. They 

also had to upgrade the fan for the booth to 10 HP. The gel coat booth and tooling booth both 

have two passes of carbon panels and 90 panels each. 

The carbon is not regenerated on site. The carbon panels are regenerated by West States 

Carbon in Santa Fe Springs. Hydro Systems monitors the styrene concentration in the stack to 

determine when the panels need to be changed. The styrene concentration is about 0.1 ppm just 

after panel change out. When the concentration reaches 2.8 to 2.9 ppm, they do a second 

measurement that day. Ifthe concentration is still in the 2.8 to 2.9 ppm range they change the 

panels that evening. They measure the stack concentration daily. The permit styrene 

concentration limit is 3 ppm. 

They originally had to change the panels every two weeks. This appeared to be a 

excessively short life, so they went back to West States Carbon for a way to lengthen panel life. 

They changed their operation to run the fan on the booths 24 hours per day and panel life 

gradually increased to 1 year. The panel life for the tooling and gel coat booths is 2 years. 

Apparently, by running air over the carbon during nonproduction periods, styrene is desorbed. 

This is acceptable to the permitting authority as long as the 3 ppm stack concentration is not 

exceeded. Therefore, the actual emissions reduction ofthis system is unknown. 

At the time ofthe site visit, they reversed the air flow in the tooling and gel coat booths 

after the second shift (8 hours per day). They discontinued this practice since the site visit 

because it was drawing styrene laden air back into the building, which resulted in some styrene 

escape to ambient air and odor complains. They change out carbon during second shift, when 

there is no production. They can prolong carbon life Vi shift or so especially on a hot day by 

using kraft paper to cover bottom runs of filters. 

When they change panels in the chopping both, they remove the 1st pass, move the 2nd and 

3

rd

 pass panels into the first pass, and then place fresh panels in the 2nd and 3rd passes. In the 

tooling and gel coat booths they replace all the panels. They keep 180 extra panels on site. 

The portable stack monitor is a HUPI 101 that cost $5000.00 in 1998. They calibrate the monitor 

with 10 ppm isobutylene. 
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ATTACHMENT 1 
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RESPONSE TO EPA QUESTIONS, FEBRUARY 2000 -

A. ADD-ON CONTROL DEVICE TECHNICAL DATA -

1. Hazardous air pollutant (HAP) concentration at the pickup points to each 

carbon panel (range and average HAP ppm). Chopper booth -

Estimated range is 1 - 100ppm. Gelcoat Booth - Estimated range is 

1 to 100 ppm. Tooling Booth - Estimated range is 1 - 20 ppm. 

Grinding Booth - Estimated range is 1 - 5 ppm 

2. HAP concentration in the facility (range and average HAP ppm). Range = 

1 to 20 ppm. Average for facility = estimated 3 to 4 ppm. 

1

 3. HAP concentrations at each single emission point at the outlet of each 

carbon panel (range and average HAP ppm). Range = less than 1 ppm 

to 3 ppm. Average = estimated 1.5 ppm. 

4. At which times of the day is monitoring data collected? Various times, 

usually between 8 AM and Noon. 

5. Flow rate to each carbon panel (average and range) Gelcoat Booth is 

12,000 CFM., and contains 90 panels in the first pass. 12,000 * 90 = 

133.33 CFM per panel (?) Chopper Booth is 24,000 CFM and has 180 

panels in the first pass. 24,000 * 180 = 133.33 CFM per panel (?). 

The Tooling Booth is 12,000 CFM and contains 90 panels. 12,000 * 

90 = 133.33 CFM per panel (?). 

6. Weight of each carbon panel before removal for regeneration or 

replacement. 41.5 lbs. 

7. Facility operating hours (daily and annual) First shift = 6:00 AM to 2:30 

PM. Second shift = 3:30 PM to Midnight, Monday through Friday, 

every day except New Year's Day, Memorial Day, July 4th, Labor Day, 

Thanksgiving and the day after Thanksgiving, and Christmas. 

8. Destruction efficiency test results or estimates of the carbon panel system. 

We have no data.. 

9. Method of demonstrating continuous compliance with permit conditions for 

activated carbon panels. Primary method is the absence of odor 

complaints from our neighbors. We are also required to keep a 

record of daily stack testing. 

B. ADD-ON CONTROL DEVICE COST DATA -

1. Carbon panel system capital cost and year ofthe cost data We installed 

the carbon system in the Spring of 1988. We no longer have any 

records of the costs involved, but to the best of our memory we 

spent approx. $400,000 on the system. 

2. Freight cost and sales tax The carbon came from Los Angeles, all the 

fabrication and sheet metal was done locally. The freight and sales 

tax would be included in the figure above. 

3. Electrical power consumption and cost associated with carbon panel 

operation. We upgraded the motors on all booths. Estimated 

increase is $14,100 per year. 
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Carbon panel maintenance costs, media regeneration/replacement costs, 

and frequency of media regeneration/replacement. We currently pay 

$45.00 per panel for regeneration. We change 180 panels each time 

on the Gelcoat Booth @ $45 ea = $8100 + about $300 in labor = 

$8400. We change 180 panels on the Chopper Booth each time, too. 

Cost per change out = $8400. We change 90 panels each time on the 

Tooling Booth @ $45 ea = $4050 + $150 in labor = $4200. We 

probably change the Chopper Booth once a year and the other two 

maybe every other year. Annual cost probably averages about 

$14,700. 

Overhead, property tax, insurance, and administration cost associated 

with the carbon panel system. 

« Carbon Regeneration (5> $14,700/yr. ( #4 above) 

•» Increased Electrical Use @ $14,100/yr. ( #3 above) 

© Annual Motor Replacement @ $900/yr (based on avg. motor 

life of 3 years) 

« We replace the pre-filters more frequently - about once/mo. at 

a cost of about $400/mo. for filters + labor = $4800/yr. 

* Cost to transport filters for regeneration - about $225 round 

trip. 

<•> Property tax is 1% of original cost. = approx. $4000/yr. 

o Insurance - annual premium to cover the system is approx. 

$2000. 

• Administration Cost - $5400/yr. ( #6 below) 

Record keeping and reporting time and costs associated with the carbon 

panel system, list of records and reports currently required, and time and 

costs to prepare these reports. Time to check stacks and record 

results = approx Vz hr/day. X 240 days =120 hrs/yr. Time spent each 

month to update other reports = approx. 5 hrs/mo. (including 

Accounting dept) X 12 = 60 hrs/yr. Total time = 180 hrs/yr. @ avg. 

30/hr = $5400/yr. For a list of reports required, please see Permit to 

Operate, Condition 15. 

CAPTURE SYSTEM TECHNICAL DATA . ^ 

1. List of retrofitting done to the building to capture emissions. There 

were no modifications made to the building other than the 

installation of the carbon adsorption system. (We consider all 

electrical and plumbing relating to the carbon system to be part of 

the system, not part of the building). 

2. List of emission points captured and vented to the carbon panel 

system. The primary emission points are the chopper gun, which 

is installed in front of the Chopper Booth, and parts which have 

been chopped but have not yet cured These parts are located in 

front of the Chopper Booth and in front ofthe Tooling Booth. The 

other source of emissions is the gelcoat gun, which is located 

inside the Gelcoat Booth 
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3. Number and size of permanently open doors or any other openings in 

the building enclosure. The shop has three truck doors - two on 

the South wall (22' X 13' and 20' X 16') and one on the West wall 

(10' X 14') There are also four man-doors (approx. 3' X 7') Two 

other man-doors lead to the office area of the building. No doors 

are permanently open, but when we are operating we keep one of 

the truck doors open (see Condition 10. of our Permit to 

Operate).. 

4. Can the building be considered a permanent total enclosure based on 

Method 204? We have no idea. 

5. Capture efficiency test results on building enclosure or facility estimate 

of capture efficiency if no test results are available. We have no idea. 

6. Methods of demonstrating continuous compliance with airflow balance 

requirements in the permit. Absence of odor complaints from our 

neighbors. 

D. CAPTURE SYSTEM COST DATA -

1. Capital cost to retrofit the building to capture emissions and year of the 

cost data. There was no retrofitting to the building, only the 

installation of the carbon adsorption system. 

2. Incremental operating and maintenance costs of the building 

associated with capturing emissions. There are no incremental cost 

increases other than those associated with the carbon system 

itself. 

E. DUCTWORK TECHNICAL DATA 

1. Basic ducting materials before and after carbon panel system installation 

(steel/aluminum/plastic, circular/straight, insulated/non-insulated) Steel, 

before and after. 

2. Basic ducting configuration before and after carbon panel system 

installation (general configuration, length, diameter, location of tees, 

dampeners, elbows, and fans. All ducting changes for the carbon 

system were made within the building. Gelcoat Booth - we added 2 

ea 34" dia. 90°sweep elbows, approx. 10' of 34,^.. dia. duct, and tied 

into the existing exhaust stack on the roof. ' Chopper Booth - we 

added 2 ea 24" X 72" X 36" square transitions to the top of the 

carbon, 2 ea 24" X 60" X 72" long square ducts, one 54" X 72" X 48" 

square transition, approx. 16' of 42'" round duct, and two 42" dia. 45° 

elbows, and tied into the existing exhaust stack on the roof. The 

Tooling Booth only required the addition of 2 ea 34" dia. 45° elbows 

to tie into the existing exhaust stack on the roof. 

3. Measured/estimated/assumed velocity of gas stream in ductwork. No 

data available. 

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DUCTWORK COST DATA 

1. Capital cost to retrofit ductwork to vent emissions to the carbon panel 

system and year of the cost data. We installed the ductwork in 1988 

and its cost is included as part of the entire carbon system cost. 

2. Freight cost and sales tax for ductwork retrofitting. Included in system 

cost. 

3. Incremental electrical power consumption and cost associated with duct 

fan operation due to installation of carbon panel system. Approx. 

$14,100/yr. ( B.3. above). 

4. Incremental ductwork maintenance costs due to installation of carbon 

panel system. No increase in ductwork maintenance costs. 

5. Incremental ductwork overhead, property tax, insurance, and 

administration costs due to installation of carbon panel system. Included 

in B.5. above. 

t