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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

84) ll-E-44 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:06 AM Sheet 84 of 264 
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g|piig?i 

<*f D 

TO: 

FROM: 

DATE: 

A-94-52 

MEMORANDUM 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

August 14, 1996 

P:\N404 

SUBJECT: Summary of June 13, 1996 Meeting Between EPA and Representatives of 

the Continuous Lamination Industry 

LOCATION: EPA/Mutual Building, Durham, NC, 11th floor conference room, 

9:00 am - noon 

ATTENDEES: 

Mr. William Dannhauer 

Ms. Linda Herring 

Mr. DuWayne Kniess 

Mr. Greg LaFlam 

Ms. Maria Malave 

Mr. Ken Meardon 

Ms. Hilary North 

Mr. Carl Novak 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

Kalwall 

EPA/ESD 

Resolite 

PES, Inc. 

EPA/OECA 

PES, Inc. 

Lasco Panels 

Sequentia 

PES, Inc. 

SPI/Composites Institute 

EPA/ESD 

(603) 224-6881 

(919) 541-5358 

(412) 452-6800 

(919) 941-0333 

(202) 564-7027 

(919) 941-0333 

(606) 371-7720 

(800) 637-0095 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

Note: Ms. Malave participated by telephone. 

PURPOSE 

The meeting was requested by the SPI Composites Institute on behalf of companies 

in the continuous lamination (panel making) industry, in order to discuss EPA's data base 

and MACT floor determinations for this subcategory. The EPA also wished to expand its 

information base by asking the companies questions about their fabrication processes and 

the HAP control measures in use at their facilities. 

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Madeleine Strum 

August 14, 1996 

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FACIUTY PROCESSES AND CONTROLS 

After the participants introduced themselves, industry representatives provided 

information on their companies and manufacturing processes. The following information 

was provided by Mr. Novak from Sequentia regarding the company's two facilities, at 

Grandview, Missouri and Grand Junction, Tennessee. Sequentia produces flat and 

corrugated composite panels in a continuous lamination process. Resin is received at the 

facility with about a 33 percent by weight styrene content, and extra styrene is added along 

with other ingredients to produce a 40-41 percent styrene mixture. The resin matrix is 

applied continuously in a flat sheet to a plastic carrier film using a doctor bar, and 

chopped glass is dropped onto the resin and compacted into the wet layer by squeeze 

rollers. A top film is laid down on the layer and the thickness is set using rollers. 

Curing is accomplished using a two-stage heater (oven) system. The first stage 

produces gelation (partial cure and solidification), while the second stage completes the 

cure chemistry. The ovens used by Sequentia at Grandview for their "narrow" lines are 

heated by natural gas. The oven for the wide flat line uses electrically heated plates to 

achieve gel, and gas for me final cure stage. The oven at Grand Junction uses steam 

(radiator air exchange) and gas. Cured panels are trimmed to width and cut to length 

using water jet technology. Mr. Novak said that materials account for 65 to 80 percent of 

total product cost. Market uses are for truck/trailer parts, signage, traffic control, and 

construction. 

Sequential mixing tanks are operated closed at all times except when materials are 

being added or removed. Measured styrene vapor concentrations are 14 ppm with the 

mixers closed, and over 600 ppm when the mixers are open. From the mix tank, the 

materials are dropped into a closed tank on which a vacuum is drawn. From this drop 

tank, the material is fed to a feed tank, which is kept full. The feed tank is agitated and 

kept closed during agitation. The material is fed from the feed tank through a pump for 

in-line catalyst mixing and then layered onto the carrier film. It is here tfiat the material is 

first exposed to me air. 

Compression of the material occurs when a top film is laid down on the open layer 

of resin and fiber. The only escape of materials during compression is out the sides. At 

Sequentia, they grip the top and bottom carrier films with clips. This decreases the 

amount of open space along the sides, but is not as effective as a fold. The resin mix with 

its carrier films is then heated to a gel, which can be defined as the point at which you 

"cannot move the liquid around with your finger." Some minor emissions may occur after 

the gel state has been reached, but the styrene is essentially locked into the resin material. 

Mr. Novak pointed out that the surface cures first, followed by the interior of me 

laminate. 

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Madeleine Strum 

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Sequentia owns six production machines: four in Grand Junction (all operating) and 

two in Grandview (one running and one shut down). These machines produce wide and 

narrow flat panels, as well as corrugated panels, and range in length (doctor box to shear 

station) from approximately 120 to 260 feet. Mr. Novak noted that the 260 foot total 

lengm for the wide flat line is very long compared to the other lines typical in tiieir plants 

and in the industry. For the corrugated panels, there is about 80 to 90 feet of heated oven 

and 30 to 35 feet of wet area. These distances are more typical of me machines they 

have. The Grandview facility operates 10 to 12 hours per day, while the Grand Junction 

facility operates 24 hours per day. 

Sequentia performs annual gravimetric emissions testing (similar to the static test in 

use in me South Coast Air Quality Management District in California) on its resins to 

determine volatile losses in grams per square foot of surface. These tests are performed at 

a fixed temperature of 90 °F. The test results consistently show compliance with the limits 

set by the State of Missouri DNR. 

Mr. Novak explained that, in order to improve the working environment and to 

reduce evaporative losses, the company constructed local enclosures over the wet areas of 

the machines in the summer of 1991 (these do not enclose the oven area of the machines). 

These enclosures are made of stainless steel and glass, so that the process can be observed 

from outside the enclosure. Sequentia has experienced no problems with styrene accumulating or polymerizing on the glass. They clean the inside of the enclosure once or 

twice a month and dust the outside. Very little additional maintenance of the enclosures is 

required. Initially, they had problems with the seals because of the styrene, which 

attacked the seals. They now have better seal materials tibat are resistant to styrene. They 

routinely check the seals for breaks and cracks. When it is necessary to make adjustments 

to the process, an operator wearing a respirator opens a small door on the enclosure and 

leans in to make the adjustment. Ms. Strum asked if he knew how much of the time the 

doors are open. Mr. Novak said that they can track that information. He noted diat the 

enclosures are not completely air-tight, but are sealed all the way around. He said that, 

within the enclosure, the styrene is believed to achieve a quasi-saturated condition, in 

which the amount of styrene going out of the resin matrix equals the amount going back 

in. He noted that this condition is transient and saturation is probably never reached 

(opening the doors to the enclosure likely results in the loss of any equilibrium). Mr. 

Novak then pointed out that the air within the enclosure is very still and vapor losses 

would not be expected to be significant. 

Mr. Novak felt mat this quasi-saturation is unique in the industry and noted that 

one would not have saturation conditions in enclosures vented to control devices as would 

be required under subpart W V of 40 CFR part 60. Mr. Meardon asked whether the 

facility is using less styrene now diat emissions are presumed to be lower; Mr. Novak 

responded that the properties of the product have improved, but was not sure if they are 
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Madeleine Strum 

August 14, 1996 

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using less styrene. 

The company is presently engaged in performing a daily mass balance on the 

process at its Grand Junction facility, which involves accounting for all weight of materials 

entering and leaving the process. Ms. Strum asked whemer this procedure could allow 

quantification of styrene losses as a function of available styrene (total input to me 

process). Mr. Novak felt that, while not providing a precise answer, this procedure could 

give a good indication of the upper limit of styrene losses. He noted that the scales they 

use are checked quarterly to an accuracy of 1 pound in 2,000 pounds (2/10 of 1 percent). 

Mr. Novak thought mat this procedure has indicated that about 0.2 percent of the material 

is unaccounted for (in the sum of product, scrap, etc.), in contrast to an estimated 3 to 4 

percent loss before the enclosures were in place. The annual employee exposure checks 

also show reductions in the 8-hr weighted average concentrations in the breathing zone 

with the enclosures in place, from 3,900 to 32 ppm. It was noted that within the enclosure 

there is a styrene concentration gradient. They have a concentration sensor at the top of 

the enclosure. Mr. Novak felt uiat the concentration near the top of the product was 

around 2,500 ppm, but at the top of the enclosure it never got anywhere near 25 percent 

of the lower explosive limit (LEL) for styrene. Mr. Schweitzer stated that the LEL for 

styrene is 10,000 ppm. Mr. Novak noted that the sensor has an alarm that is set at a 

lower trigger level than 25 percent of the LEL and the alarm has never been activated. 

Mr. Novak could not quantify the emission reduction the enclosure might be 

achieving, but in his opinion it is significant. He stated that the mass balances they were 

performing showed between 50 and 100 lb of material being lost compared to what was 

going in, which includes evaporative losses. Mr. Schweitzer pointed out that without a 

stack test you cannot tell whether these differences are due to actual VOC loss or test 

measurement error. Mr. Novak said that he could develop a worst-case scenario in which 

all loss is assumed to be styrene (HAP). At 100 lb per day and 240 days per year, tins is 

. less than 13 tpy. 

Mr. Novak noted uiat at Grandview they have over 3 months worth of daily mass 

balance data, but uiat the first part of that data was questionable because the people at the 

plant were just learning the procedures. The procedure is now set, and me last monm of 

data represents really good solid numbers. At Grand Junction, uiey are just implementing 

die same procedures, and it will take at least 3 months to "shake down" the protocol 

before they get numbers they can believe. 

Mr. Novak offered to provide documentation of their methodology for the mass 

balance procedure, as well as calibration information for the instruments used. He also 

said he would provide a drawing of meir process and a diagram of their production 

building, and cost data on meir enclosures. 

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Madeleine Strum 

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In response to a question, Mr. Novak was unable to quantify the distribution of 

emissions within the process, but felt that the wet portion (prior to adding the top film) 

would be the area of highest emissions. In contrast, the oven section is expected to have 

low emissions due to the "closed mold" effect of the top film. Mr. Novak expected that 

the mixing process should be relatively low-emitting due to the small surface area-tovolume ratio of the mixture. Another small source would be the resin storage tanks, 

which emit displaced styrene vapors each time die tanks are filled. 

Mr. Dannhauer described Kalwall's process as similar to Sequentia's; however, no 

enclosures are used (he said that the plant has a comfortable working environment). The 

facility operates its one machine 24 hours per day, 5 days per week. He stated tiiat they 

conducted a stack test 2 years ago using a total enclosure and monitoring the exit points. 

Areas of highest emissions were me wet areas (95+ percent). Their machines are very 

similar to what Mr. Novak described, but with a number of variations. In their machine 

me film is gripped and stretched by clamps, and extends about 4 inches beyond the resin 

on each side, so mere is expected to be virtually no vapor leakage at the edges. Mr. 

Dannhauer offered to provide their complete test report. 

Resolite uses one machine and a "unique" process (with some proprietary features) 

to produce corrosion-resistant/fire retardant panel products (almough Mr. Kniess said me 

process is similar to the others with respect to terminology). The company's machine is 

quite small (5 ft. wide x 16 ft. resin laydown length), which is similar in size to Sequentia's corrugated panel line. Resolite is required by meir insurance company to maintain 

ambient styrene concentrations within the facility to less than 25 ppm. Their ovens are 

different, using gas-fired recirculation, are about 100 feet long, and have no cool-down 

area. Their wet-out area is enclosed as much as possible. They run the equivalent of 1.5 

shifts per day, 5 days per week. 

They are exploring the possibility of installing an in-line degassing system from the 

tanks to the doctor blades. Mr. Kniess noted mat air inhibits curing and you do not want 

air in the resin, where it can become entrained and lead to voids within the panel and on 

die surface. Resolite is also looking into me possibility of further enclosing the wet area, 

but believes it could be difficult due to the small size and me fact that the machine is 

installed in a restricted space within the facility. Personnel do not need respirators in me 

area of the machine. The corrosion-resistant resins in use (isophthalic polyesters, vinyl 

esters, etc.) have a typical styrene content of about 29 percent, although Mr. Kniess could 

not characterize specific ranges for the resins. Mr. Kniess noted that their emissions are 

around 32 tpy and mat mey have RACT in place for the State of Pennslyvania. They 

submitted to the State their title V operating permit reflecting their RACT in November 

1995, but have not heard back from the State. Mr. Kniess said he would check me 

specific styrene contents or ranges and send me information to EPA. He also will send 

me stack test results available for this process. 

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Madeleine Strum 

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Mr. Schweitzer emphasized that corrosion-resistant resins require a higher styrene 

content than general purpose resins. Mr. Novak, in discussing the resin mixtures used at 

this type of facility, said that styrene contents are typically in the range of 2.9 to 3.7 

pounds per gallon of finished mix. 

Lasco Panels operates uiree panel production lines, two narrow (4 feet wide) and 

one wide (9.3 feet wide), 24 hr/day, 7 days/wk. The wide line was equipped with an 

enclosure in me fall of 1994. The process is essentially the same as Sequentia's, with a 

30-foot long wetout area. Lasco uses wheels to grip and stretch me carrier film, which 

cannot be done for corrugated panels. These are run through a forming shoe, in which it 

is very difficult to push out material from me side. Emissions are essentially unmeasurable (i.e., negligible). Employee exposure checks are made twice per year; these checks 

indicate ppm values in me teens and 20's (Kentucky's standard is 50 ppm). In July 1995, 

the company changed its resin supplier, which led to a lower resin styrene content. Ms. 

North said Lasco performed a mass balance to support a RACT analysis for the State of 

Kentucky, but me company has not yet received a response from me State. She offered to 

provide mass balance data for me facility, the procedure used to calculate the mass 

balance, and a diagram showing the enclosure used on the facility's wide line. 

Ms. Strum surveyed the attendees to review their operating practices with respect 

to mixing tanks and the use of covers. Kalwall and Sequentia operate them closed with 

covers. (Sequentia has a lock-down mechanism to ensure a tighter fit). Resolite uses 

covers during mixing; they have one holding tank that is open — it is behind a closed door 

in a room by itself. Lasco's mix tanks are left uncovered tiiroughout the mixing process. 

MACT FLOOR DETERMINATIONS 

In response to company questions about EPA's determination of facility "control 

status" (CS) and MACT floors for me continuous lamination/casting subcategory, Ms. 

Strum summarized and discussed with the group the methodology used in these calculations. She emphasized that the control status parameter was developed specifically for 

open molding operations (hand and spray layup); however, a CS value is shown in the 

floor for continuous lamination/casting as a means of providing flexibility for control to 

that subcategory. Mr. Novak stated mat mis flexibility would not help panel makers in 

meeting a standard based on the MACT floor. Ms. Strum said mat in the future alternative monomers could be developed to help provide control; Mr. Schweitzer indicated that 

present alternatives are more costly and EPA should not count on any feasible alternatives 

coming on me scene in the foreseeable future. Mr. Schweitzer also stated that there is not 

a direct linear relationship between styrene content and emissions. He said that, for 

example, a 20 percent reduction in styrene content would not cause a 20 percent reduction 

in emissions. Ms. Strum agreed mat the exact relationship is unknown. Industry 

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Madeleine Strum 

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expressed concern that me MACT floor for new sources would be a control level reflecting the use of incineration, and apparently no credit would be given for ottier control 

approaches. Mr. Novak asked why styrene should be drawn off the process, and men 

incinerated, when its evaporation has aheady been controlled using a sealed enclosure. In 

addition, he pointed out that incineration consumes natural gas and creates undesirable 

combustion products. He also asked what baseline the percentage reduction requirement 

would be compared to. Ms. Strum responded diat the baseline was intended to be the 

emissions presently coming from the process. Mr. Schweitzer said mat, while EPA must 

create a "one-size-fits-all" MACT standard, "true" MACT would look different at different 

facilities (even within the same subcategory). Mr. Novak pointed out that the (controlled) 

Crane Kemlite facility was designed from me ground up and funding was provided by BP 

Chemicals, a large corporation. In contrast, many facilities are privately owned and 

cannot afford the large outlay for add-on controls, and cannot pass the cost through to 

customers because there is no value added to the product. 

Ms. Strum said that EPA is still reviewing me data base for accuracy and completeness, and some of the preliminary facility information could change, affecting the MACT 

floor determinations. She stated that alternate control technologies are available, such as 

VOC concentrators, wliich could make controls more economical. Mr. Schweitzer 

responded that concentrators are not in use at any of the facilities in EPA's data base. 

Mr. Schweitzer requested a copy of a non-confidential phone contact report for one 

continuous laminating facility (whose basic operating data are being treated as confidential), and Ms. Strum agreed to provide it. 

Ms. Strum discussed with Mr. Novak the potential for a site visit to Sequentia's 

Grand Junction, Tennessee, facility to view meir enclosed process, and the other companies present also extended invitations to EPA to visit their facilities. 

ACTION ITEMS 

Each of me companies attending the meeting offered to provide additional information to EPA to help the Agency understand me process emissions and the control measures 

in use at their facilities. In addition, EPA and PES agreed to perform certain actions. 

The action items from the meeting are as follows: 

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Madeleine Strum 

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Company 

1. Sequentia 

Materials to be Provided 

mass balance data (methodology, calibrations) 

drawing of process 

diagram of building and all openings 

enclosure costs 

2. Kalwall complete emissions test report 

3. Resolite resin styrene contents 

stack test results 

4. Lasco 

5. EPA/PES 

mass balance data 

procedure for calculating mass balance 

diagram of process enclosure 

Actions to be Performed 

call Crane Kemlite to confirm total enclosure 

investigate a site visit to Sequentia's 

Grand Junction, TN facility 

provide non-confidential telephone contact report 

for one facility in data base to Mr. Schweitzer 

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