OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

3) ll-C-29 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:45:55 PM Sheet 3 of 343 

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s*° sr.,, 

A-94-52 

1-C - 2") 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

MAR 7 1996 

Mr. Mark Smith 

Cor Tec Company 

2351 Kenskill 

Washington Court House, Ohio 43160 

Via Facsimile at (614) 335-4843 

Dear Mr. Smith: 

This is to provide background information for our conference 

call on Monday, March 11, 1996 at 1:30pm. The purpose of this 

call is to better understand Cor Tec's operations with respect to 

the process-based approaches we are considering for developing 

emission standards for the reinforced plastic composites 

industry. As you know, there is a large number of different 

processes in this industry. We have defined our processes from 

more of an emission/emission reduction viewpoint than a product 

viewpoint, and for this reason, the manufacture of a single 

product or what may be considered to be a single process by a 

manufacturer may entail two different processes (and hence two 

separate emission standards) from an emission viewpoint. Our 

goal in the call is to agree upon the processes we have 

identified for Cor Tec. 

The following contains a description of those processes for 

which we are developing separate emission limits that you may 

consider to be relevant to Cor Tec's operations. 

Gel coating groups together facilities in which gel coat is 

applied by an operator (typically using a spray gun but may be 

applied using a brush or other application method) to the 

surface of a mold. The gel coat is applied to the surface which 

will be the outermost visible part of the product. The gel coat 

is then cured at elevated or ambient temperature. 
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Hand/spray lav-up groups together facilities which pour, 

brush, spray, use a flow coater or impregnator to apply resin or 

resin and reinforcement to the surface of a mold or to 

reinforcement that has been placed onto the mold. The resin is 

then typically rolled out and cured at ambient or elevated 

temperature, but may also be cured via a vacuum bag process. The 

process may be repeated to build up several layers of resin. 

Continuous lamination/continuous rasHna is a substantially r 

automated process for producing laminates on an in-line conveyer. 

The process involves applying resin or gel coat onto a flat,

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moving surface, and then curing the material, typically in an 

oven through which the laminate is automatically moved. 

Polymer casting involves the production of a non-reinforced 

composite that combines polymers, fillers, and additives by •*— 

pouring or dispensing these materials into open or partially open 

molds and then curing them at elevated or ambient temperature. 

We are considering that the process that Cor Tec 

characterizes as gel coating best fits into the Environmental 

Protection Agency's (EPA) continuous lamination /continuous 

casting description. The major characteristics are that the 

process is a flat process, has a moving conveyer belt, and 

involves a machine which is fixed in space. The present control 

option for this particular category is to remove about 50 percent 

of the hazardous air pollutants (HAP) emitted from this process. 

This value was derived based on data the EPA has on the level of 

performance achieved by the median of the best performing five 

sources that conduct this process. With regard to this level, 

Cor Tec was one of the best performing sources by achieving an 

overall removal efficiency of 91 percent. 

The process associated with the second part of Cor Tec's 

operation involving the laminating table and vacuum bagging is 

more difficult to determine. We are considering this to fit into 

the hand/spray lay-up process. 

We considered polymer casting, but vacuum bag molding does 

not seem to be a cure method for polymer casting, and polymer 

casting typically involves a concave mold. We also considered 

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continuous lamination for this operation, but it seems not to 

involve a moving belt and is more of an operator-driven process 

rather than machine driven. 

For your information, the limit we are considering for 

hand/spray lay-up is a wcontrol status" of around 1.5 pounds 

(lbs) HAP per gallon of resin matrix, where the matrix includes 

both resin and filler. A facility's control status is not only 

based on the quantity of HAP contained in the matrix, but also 

pollution prevention and control techniques that reduce 

emissions. The use of vacuum bag molding and non-spray 

application processes, for example, are two such techniques that 

would achieve a "credit" which is incorporated in the calculation 

of a facility's control status. In particular, the lbs HAP per 

gallon of the resin matrix is multiplied by 0.55 for vacuum bag 

molding and 0.55 for the use of a non-spray application process. 

The control status of 1.5 lbs HAP per gallon was derived by 

computing the median control status of the best performing 

12 percent of the facilities using hand/spray lay-up, considering 

the credits achieved by various pollution prevention and emission 

control techniques. With this approach, using your styrene and 

filler contents reported in the 1993 survey response, we 

determined for this process that Cor Tec has a control status of 

0.8 lbs HAP per gallon of resin matrix. 

I hope this provides you with sufficient background 

information for our call. Please be aware that the emission 

standard for this industry is still very much under development 

and although the deadline is fast approaching, we have much to do 

before we even propose. We look forward to your assistance in 

determining the most appropriate placement of Cor Tec's 

operations with respect to our process definitions. If you have 

any questions before Monday's call, do not hesitate to call me at 

(919) 541 2383. 

Sincerely, 

Madele'ine Strum 

Coatings and Consumer Products Group 

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