p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

8) II-B-3 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:10 AM Sheet 8 of 57 
P.2 

TC , 

OMEGA 

ijI'l^il'HH.'r-MI.'W.lil-liFAH-l 1331 SOUTH CHILLICOTHE ROAD • AURORA. OHIO 44202-9218 • TEL: (216) 562-5201 • FAX: (216) 562-4908 

February 4, 1994 

Ms. Susan Wyatt 

Chief 

Chemicals and Petroleum Branch 

Emission Standards Division 

United States Environmental Protection Agency 

Research Triangle Park, NC 2771i 

Dear Ms Wyatt: 

Attached please find the requested corrected copy of the 

draft report of the site visit performed by Dr. Madeleine 

Strum and representatives of PES on August 10, 1993. 

An MSDS for the degreasing compound SP 202 is attached. 

It should be mentioned here that Omega replaced its vapor 

degreaser with an aqueous cleaning system that has been 

in operation since January 1, 1994: 

Please do not hesitate to call me with any questions you 

may have regarding this report. 

Sincerely, fr ,, 

M 0CTl8m5 .-.Ijjl 

W. C. McSherryfl"jr. 

Environmental Affairs Manager 
P.3 

O PACIFIC ENVIRONMENTAL SERVICES, INC. 

Central Park West 

5001 South Miami Boulevard 

PO Box 12077 

Research Triangle Park, NC 27709-2077 

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

SITE VISIT REPORT 

Date: November 5, 1993 

L:\N027 

Subject: Site Visit -- Omega Pultrusions, Inc. 

Reinforced Plastic Composites NESHAP 

EPA Contract 68010116; ESD Project 93/58 

PES Project N027 

From: Dean Carroll and Greg LaFlam '^Y^^~ 

To: Ms. Madeleine Strum 

ESD/CPB MD-13 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

I. Purpose 

The purpose of the visit was to obtain information on the pultrusion 

process within the reinforced plastic composites industry. This information 

included processes, emissions, and control measures in use at the facility, 

and will be used in the development of a maximum achievable control technology 

(MACT) standard for the reinforced plastic composites production source 

category. 

This site visit was part of a 3-day trip to observe operations at six 

composite facilities by the U.S. Environmental Protection Agency (EPA), its 

contractor, Pacific Environmental Services, Inc. (PES), and representatives of 

two industry trade associations: The Composites Institute of the Society of 

the Plastics Industry (SPI), and the Composites Fabricators Association (CFA). 

II. Place and Date 

Omega Pultrusions, Inc. 

1331 South Chillicothe Road 

Aurora, Ohio 44202-9218 

August 10, 1993 1:30 p.m. 

WASHINGTON. O.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH 
P.4 

III. Participants 

Omega 

Jim O'Mara, Plant Manager 

Walter McSherry, Environmental Affairs Manager 

U.S. Environmental Protection Agency (EPA) 

Madeleine Strum, Project Manager 

Pacific Environmental Services. Inc. (PES) 

Greg LaFlam, Environmental Engineer 

Dean Carroll, Environmental Engineer 

SPI Composites Institute 

. John Schweitzer, Technical Director 

Composites Fabricators Association (CFA) 

Steve McNally, Director of Government Affairs 

IV. Discussion 

A meeting was held in the Omega conference room for introductions and to 

review a site visit questionnaire prepared by PES. The discussion of the 

questionnaire is contained within the report. Mr. O'Mara stated that Omega 

would not consider any portion of the visit or topics of discussion to be 

confidential business information. Mr. O'Mara briefly described the 

operations at the facility, which consist entirely of pultrusion operations. 

In the pultrusion process, reinforcements (typically fiberglass mat or roving) 

are continuously pulled through a resin bath, shaped into specific constant 

cross-sections, and cured to h^djj&s^ through a heated die. Pultruded parts 

at Omega include window slider-pane&uj^l handles, sewer flights, tree 

trimming poles, and lamp panels. AnBlrs^ivWindows is a 1 arge-etisi-omer—of 

Omegas The widest part pultruded at Omega is 33 inches and parts can be up to 

1/4 inch thick. 

The company has 124 employees (80 percent involved in direct labor) and 

runs three shifts, 5 days a week. A fabrication department is utilized for 

secondary drilling and cutting. The tour involved observing the storage area, 

the pultrusion process area, and the fabrication area. The Aurora, Ohio area 

is an attainment area for ozone and has no VOC imposed limits or toxic rule 

for styrene. 

A. Storage Area 

The storage area was outside in the back corner of the property. An 

air-conditioned room is used to store catalyst, and is equipped with a 
P.5 

"pop-off" roof in case of large pressure increases. Three catalysts are used 

at Omega; Perkadox 16, USP-245, and Tert-Butyl Perbenzoate (TBPB). Mr. 

McSherry sent material safety data sheets (MSDS's) for these compounds, which 

do not indicate any hazardous air pollutants (HAP's). All MSDS's for the 

catalyst, resin, mold release, filler, additive, and pigment are attached to 

the report. 

A fenced cage area (outside) was observed which contained spent 

methylene chlor^Je^^FJ^teen 55-gallon drums were in the cage and were to be 

sent off-site toAbe use'cTin fuel-blending. Methylene chloride is currently 

used both as a vapor degreaser and for cleaning fiberglass parts. Omega 

stated that methylene chloride will be phased out at their facility by the 

Fall of 1993. No acetone is used at Omega. 

Inside the plant, a waste resin storage area contained about 10 

55-gallon drums of resins that were polymerizing to a solid form. In warmer 

weather pre-catalyzed drums can naturally exotherm and cure on their own in 1 

day. Omega indicated that these drums accumulate at a rate of about one per 

day. These scrap drums were originally labeled as hazardous, but once they 

polymerize, those labels come off and they are then nonhazardous. Omega has 

performed testing on this cured material and been approved by the Ohio EPA to 

dispose of the waste to a landfill. Notifications are given to both the U.S. 

EPA and Ohio EPA, and shipments are made about once a month. For resin 

spills, sorbent "pigs" (large sponges) are used which also solidify and are 

part of this waste resin storage total. Omega has a 90-day period in which to 

use (react) the waste resin material or it must be shipped offsite as 

hazardous waste. During cooler seasons, some resin, which has not been 

processed and is unpolymerized, must be removed from the plant within 90 days. 

The material is still hazardous and very expensive to dispose of. Production 

scrap parts are sent to an approved landfill although possible recycling 

efforts are being looked into. 

Some raw resyuis stored^inX large above-ground storage tanks(40,000 to 

Sjft^O pounds). Th w tanks >5xin a separate room ami has a sprinkler system and 

i>tow out ceiling because of safety and flammability concerns. 

Two different polyester resins are held in four bulk storage tanks 

filled by tanker. The capacities of these tanks are 58,159, 58,814, 38,208, 

and 38,298 pounds; however, one is kept empty. Pure styrene is stored in a 

separate bulk tank (capacity 2,500 gallons) which is equipped with a 

conservation vent. This tank has a pressure relief valve which releases if 

the pressure increases above 3 or 4 pounds and automatically resets itself. 

-Emi ssions-f-rom-this-t-ank-were-^eported-as-278_pounds_iJi_J992»- IxcenE,. 

B. Pultrusion Area 

The first step in the pultrusion process involves the mixing of resin, 

mold release, catalyst, and filler. The resins are either unsaturated 

polyester resin or vinyl ester resin. Both contain styrene monomer, which is 

a HAP. In 1992, 2,538,356 total pounds of styrene-containing materials were 

used including pure styrene monomer. The breakdown of resin usage is as 

follows: 
P.6 

V* 

• • • (=3 

o 

Resin 

Ashland 3058 

Reichhold 8105 

Reichhold 31027 

Ashland 610 

Ashland 1419 

Reichhold 8101 

Chem Central 

(vinyl ester) 

Union Carbide 

(LP-90 additive) 

Chem Central 

(styrene monomer) 

Total 

Percent Stvrene 

30 

40 

33 

22 

38 

35 

33 

50 

100 

Pounds in 1992 

1,419,158 

472,950 

22,797 

3,000 

500 

500 

8,148 

314,586 

296,717 

2,538,356 

The LP-90 additive resin also containsJe^s^^p^Dfcrcentv^nyl acetate, 

which is a HAP. Omega indicated thal^ae: vinyVester-4ra5=$een used in 1993 

and that current polyester resin use is similar to 1992. 

Omega mixes in an internal mold release agent with the original resin, 

which helps lubricate the "wetted-out" fiberglass mat and rovings pulled 

through the forming die. Mold release agents include Zelec, Tech-Lube 500, 

and Synpron 131, and constitute about 1.5 percent of the applied resin. 

According to the MSDSs, no HAP's are in these products. 

The catalysts added are either Perkadox 16, USP-245, or TBPB, and are 

typically 1 to 2 percent of the overall resin material. Fillers used at Omega 

are calcium carbonate (CaC03), clays, or alumina trihydrate (AljO,) and 

typically make up about 35 percent of the pultruded product. Fillers are less 

expensive than resins and allow a reduction in resin raw material, thereby 

saving both money and styrene emissions. No HAP's are contained in these 

fillers. 

Once the resin material is fully mixed it is poured into a bath to dip 

fiberglass reinforcements. (How is the mixing done and where? How is it 

transferred to the baths? Please explain in detail.) The fiberglass can be 

in a mat or woven roving form. The fiberglass mat ranges from about 6 inches 

to 33 inches wide, is about 1/8 inch thick, and is on spools as it is fed into 

the machine. The roving is like s.tr.ing or bailer twine (about 1/8 - 1/4 inch 

diameter) and is stored on spools;br "creels." 

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Omega uses either a resin bath or (newly designed) injector blocks to 

wet-out the fiberglass mat and rovings. The resin bath simply allows the 

glass to become saturated with resin material before entering the forming die. 

The injector blocks provide an enclosed "hollow" block pumped full of resin 

and do a better job of wetting-out the mat and roving. The blocks are also an 

effective way of reducing styrene emissions since they eliminate the large 

surface area of open resin baths. Omega pointed out that the largest 

contributor of emissions at their plant is actually the large surface area of 

the wet rovings and mat exposed to the air. It is therefore desirable to 

shorten the distance from the bath/injector block to the curing die as much as 

possible. In both cases, a drip pan is necessary to collect excess resin and 

recirculate it to the process. 

The advantages of the resin injector blocks are that they reduce styrene 

odor, eliminate lost resin when shut down (previously lost in the bath), and 

more thoroughly wet-out the fiberglass. Disadvantages include the cost for 

pumps and the time and cost to design and machine the blocks. Injector blocks 

are custom made for each product order. 

Manual^eftlling of resin baths occurs about five times per shift and is 

done using-Jaucfcels. Line speed can be from 6 to 60 inches per minute and 

typically runs around 40 inches per minute. Set-up time for a new job can 

take 2 operators 2 days (32 total labor-hours). 

Permanent steel dies create the final product in the pultrusion process. 

Constant lineals are run out and cut to various lengths per customer order. 

It should be noted that there may be many pre-forming stages before entering 

the die. These allow the fiberglass mat and roving to take on complex shapes 

when curing but also increase the distance that the saturated fiberglass is 

suspended in the air and emitting styrene. Omega runs 15 pultrusion machines 

and all emissions in the facility are fugitive. 

C. Fabrication Area 

Omega performs secondary fabrication processes on about 70 percent of 

their parts. Dust control systems are in operation using flexible hose and 

vacuum lines supplied by Transmatic. Point of generation units can be 

connected to local air vacuums which pull very strong negative pressures. 

This system utilizes five 30-horsepower turbines. Three of these turbines are 

in service in the fabrication area of the plant; the other two pull sawdust 

and chips from the cut-off stations in the pultrusion area. Dust bags are 

emptied every 2 weeks and sent to a landfill. 

D. Emissions and Air Management 

Emissions of two HAP's were reported on the 1992 Form R report for 

Omega. The Form R report is attached to this report. Total styrene emissions 

were 64,810 pounds (32 tons), and methylene chloride emissions were 123,225 

pounds (62 tons). 

Using the Aropol 3058 resin and assuming a 35 percent filler content, 

actual styrene content as applied is 19.5 percent (30 percent styrene content 
P.8 

• D D CZS CZDl IUO 

a 

x 65 percent resin material). Omega used the 1988 AP-42 emission factor of 6 

percent for the pultrusion process for its Form R report. The AP-42 emission 

factor for pultrusion is 4 to 7 percent. 

Methylene chloride is expected to be replaced this year. D-limonene, a 

turpene based cleaner being tested, and a resin emulsifier system are 

candidates for methylene chloride replacement. Another solvent was indicated 

to be in use in 1992 which contained methanol. (What solvent is this? Is an 

MSDS available? What is it used for?) -frTnrs w^ s A b*L.c£.a.'$>-<L <WWJr> . A l 

M*t>* ** ATTACMfcO . 

Other HAP's emitted include a trace amount of vinyl acetate from the 

LP-90 additive resin. Pigments may be used for coloring products and contain 

lead. *tAre pigments added in particulate form? Please describe.) A resin 

additive from BYK Chemie (990) is added to replace styrene containing resin at 

about 1 or 2 percent of the applied resin. This material has no styrene 

content, but does contain xylene and naphtha (16 percent and 18 percent, 

respectively). Omega believes these compounds are held in the final product. 

Total use of this material in 1992 was 11,200 pounds, or 5.6 tons.* ft&MCjTS A££ 

No vapor suppressants are used by Omega. The time required for a wax to 

come to the top of a resin layer is not available in the pultrusion process. 

Mixed resin from the bath or injector block is fully cured within a couple of 

minutes as the glass travels through the hot die. 

The overall facility was observed to be very clean; employees are 

trained on housekeeping procedures. Styrene concentrations in the plant were 

said to be 4 ppm. Two air management projects have been attempted in the 

facility to collect air and reduce styrene concentrations. The first was to 

envelope a pultrusion machine to enclose and capture the process emissions. A 

casing 3 inches away from the machine and bath was constructed to provide a 

somewhat total enclosure. The air was then routed to a vent stack to the 

atmosphere. The second experiment was the attachment of a 6-inch duct at the 

base of a pultrusion machine to pull the exhaust air away and up a stack to 

the atmosphere. Unfortunately, neither attempt demonstrated an improvement in 

the plant air styrene concentrations. 

Three air make-up systems are in operation at Omega, and plant air is 

monitored in the facility every 2 months. The warehouse has two -44iTet5-ef-oarL&T& 6P. 

10,000 cfm providing ventilation and air turnover. In the pultrusion area, 

roughly 50,0000 cfm are inletted while three exhaust ports vent through the 

ceiling. The fabrication area has three long bag units bringing fresh air 

into the plant. This part of the plant was a very dusty area, with a somewhat 

foggy appearance. The bag units are very long units, like long blimps 

(estimated 100 feet long by 3 feet in diameter) attached to the ceiling. 

Portholes allow the air to exit the bag while two exhaust fans pull the air 

and dust out. 

No process water with any hazardous material content is created at 

Omega. The facility has an agreement with the City of Aurora to discharge 

aqueous material to the sewer system.

 <r(Does this include aqueous cleaning 

solutions?) ^- Y ^ Tvio . -
^___

 P9 

10/08/32 10:55 CHEMICAL SOLVENTS INC. 002 

(\0Dfe 

^**************»mm*****************************************m************** 

Page 1 

MATERIAL SAFETY DATA SHEET 

repared by- FS 

•\te of Preparation- 10-08-92 Fox*: 

nnufacturer: CHEMICAL SOLVENTS, INC. 

•idross : 3751 Jenningit Road 

Cleveland, Ohio 44109 

:rtlephone#: (216) 741-9310 Night: (216) 741-9310 

laergcncyj: (800) 424-9500(Chemf-.c )-National: (800) 362-0693 

SECTION I PRODUCT IDENTIFICATION 

M&nufaoturer's Code Identification: RP202 

Product Class: 

Trade Name: SP 202 * 

HMIS Information: Health- 3 Flammability- 1 

Reactivity- o 

HAZARD INDEX: 4» Severe 3= Serious 2- Moderate 1= Slight 0= Least 

.****************************************** ******* *********** ****** ******** 

SECTION II HAZARDOUS INGREDIENTS 

DICHLOROMETHANE 

01 * CAS# 75-09-2 

EXPOSURE LIMIT: 

OSHA TWA (final): SOO PPM 

ACGIH TLV/TWA: 50 PPM 

OSIIA CEILING: 1000 PPM 

METHAMOL 

02 - CAS# 67-56-1 

EXPOSURE LIMIT: 

OSHA TWA (final): 200 PPM 

ACGIH TLV/TWA: 200 PPM 

** *** ** ******************************** ******** **************************** 

SECTION III PHYSICAL DATA 

Doiling Range: High- 148.0 F Low- I0.T.0 b' 

Vapor Pressure: 352.00 MMHG at 68 F 

Vapor Density: Huuvlur Than Air 

Evaporation Rate: Faster than Butyl AuolaI* 

height p«r Gallon: 10.C4 

X Volatile by Weight: 100.00 

Physical State: LIQUID 

OCT 8 '92 10:50 21S ?4'1 3310 56 PGGE.002 
P.10 

10/88/92 10:36 CHBIICrt. SOLVENTS INC. B0i 

:.*******•***************************************************************** 

CHEMICAL SOLVKNTS, INC. 

RP202 MATERIAL SAFETY DATA SHEET Page 2 

SP 202 

.************************************************************************** 

\ppearance : CLEAR 

:Jor: SOLVENT 

Odor Threshold : N/A 

,M: N/A 

freezin g Point : N/A 

'ite r Solubility : SLIGHT 

.oefflcien t o f Water/Oi l Distribution : N/A 

..+******************** * ************************************** ************* 

SECTION IV PTRE AND EXPLOSION DATA 

Flammability Classification: N/A DOT: N/A 

EXTINGUISHING MEDIA 

Use C02, DRY CHEMICAL or FOAM. For large fire9 the fire deportment may 

uae water to carry foam or a dry chemical. 

UNUSUAL FIRE AND EXPLOSION HAZARD: * 

Concentrated vapors can be ignited by high intensity Ignition suuruuu. 

firefighters should wear self-contained pressure breathing apparatus due 

to the thermal decomposition products, avoid skin contact. 

Do NOT weld or cut on containers. 

*************************************************************************** 

SECTTON V HEALTH HAZARD k FIRST AID 

FIRST AID: 

INHALATION: Move victim to fresh air. If breathing haa stopped, administer 

artificial respiration. Seek medical attention. 

SKIN: Remove contaminated clothing. Wanh well with soap and water 

for ar least 15 minutes. Launder contaminated clothing before wearing. 

EYES: Flush eyos immediately with water for at. leant. ] 5 minutes. 

If irritation persists seek medical attention. 

INGESTION: Do not Induce vomiting. Seek medical attention immediately. 

HEALTH TOXTCTTY: 

EYE CONTACT: This material may cause irritation, burning, redness, And 

swelling. 

INGESTION: Poisonous if swallowed. Can cause nausea and even blindness 

if large amounts arc swallowed. 

INHALATION: A major route of potential exposure. This substance depresses 

the nervous system. May cause dizziness at 900 CO 1000 ppm, causes 

nausea, heahnches ond vomiting abuvo 2000 ppiu. At 7,000 ppm causes 

rapid heartbeat arid numbness and tingling may occur. Loss of consciousness and death can occur al. levels above 9,000 ppm. If exposure ia 

prolonged carboxyhemoglobin levels can be elevated and this can cause 

a aubstantiai stress on the cardiovascular aysl.cn. 

Medical conditions aggravated hy this* product uie; alcoholism, liver and 

kidney disease, lung disease, anemia, coronary disease or rhythm disorders 

of the heart. 

PHYSICIANS: Avoid the use of adrenalin (or other heart stimulating drug3) 

when a person ha« been overcome with dichlorome:r.h»iii«f. 

OCT 8 '92 10:51 21S 741 9310 5G PAGE.303 
P.11 

10/08/32 10:56 CHB1ICPL SOLVENTS INC. 004 

.************************************************************************** 

CHEMICAL SOLVENTS, INC. 

RP202 MATERIAL SAFETY DATA SHEET Page 3 

SP 202 

<*************«***************************************************«******* 

.KIN CONTACT: Contact with thia product may cause irritation, defatting, 

.f the skin and dermatitis. Absorption through the skin is possible 

:f contact is prolonged. 

VERALL HEALTH EFFECTS: The TARC and NTP consider methylene chloride 

• o be an animal carcinogen. 

-'A****************************«**«**************«XXSX*X*XX*****«**XXXXXSX* 

SECTTON VI REACTIVITY DATA 

STABILITY: SLable HAZARDOUS POLYMERIZATION: Will not occur. 

AZARDOUS DECOMPOSTTION PRODUCTS: Hydrogen chloride, phosgene and chlorine. 

INCOMPATAB I LIT IES: S.rong alkalis, oxygen, nitrogen peroxide, sodium, 

potassium, and other oxidizers and reactive metals. Do NOT store in 

vluminum containers. Contact with aluminum in pressurized fluid systems 

:r.ay cause violent reactions. 

CONDITIONS TO AVOID: Hot surfaces can cause thermal decomposition. Avoid 

open flames, electric ares, etc. 

r************************************************************************** 

SECTION VII EMERGENCY RESPONSE * DISPOSAL 

DISPOSAL: Dispos e o f this produc t in accordanc e wit h local , stat e and 

federa l regulations . Cal l CHKMTCAL SOLVENTS, INC. fo r recyclin g o r 

-disposal. 

The EMERGENCY RE5PONSE GUIDEBOOK number is: 

74 

PRECAUTIONS IN CASE OF A SPILL OR RELEASE: Avoid vapors and ignition 

sources. Uae appropriate protective equipment. Stop and contain the 

discharge if it can bo done safely. Keep out of drains and war.erways. 

Handle only with trained personnel. Notify authorities as necessary. 

ic* *************************************************************** * ******** * 

SECTION VTTI PERSONAL PROTECTION EQUIPMENT 

HYGIENE: 

Avoid contact with skin and avoid vapors. Do not eat, drink, or smoke 

in ;tl»« work area. W*a£-h hands prior to eating, drinxlng or using rest rooms. 

VENTILATION / RESPIRATORS: 

Use ventilation as required to control vapors concentrations. Avoid 

prolonged or repeated breathing of vapors. If exposure exceeds TLV use a 

NIOSH approved respirator to prcvonL over exposure. 

EYES: Wear splash goggles or a face shield when handling. 

SKIN: Wear solvent x-esistant gloves such as Viton. Use solvent resistant 

boots, apron, and headgear if splashing is possible. 

*************************************************************************** 

SECTION IX STORAGE k TRANSPORTATION 

DOT SHIPPING CLASSIFICATION: (49CFR 172.101) 

Hazardous* substance, n.o..i. ORM-E, NA 9188, 

(Dichloromethane, Methanol] 

HANDLING AND STORTNG PRECAUTIONS 

jtore labeled, sealed containers in a cool, dry, well ventilated area. 

OCT 8 "92 10:51 215 741 9310 56 PAGE.304 
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