p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

81) ll-E-41 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 81 of 264 
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ImwJ luteal lr*z.l 

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P.2 

A-Q4-52 

TO: 

FROM: 

DATE: 

MEMORANDUM 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Greg LaFlam and Ken Meardon 

Pacific Environmental Services, Inc. (PES) 

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Safe*. EPAAIRDGSKET" 

May 24, 1996 

P:\N404 

SUBJECT: Minutes of April 26, 1996 Meeting Between the EPA and Representatives of. 

the Pultrusion Industry Council (PIC) Technical Committee 

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

9:00 am - 12:00 noon 

ATTENDEES: 

Mr. Jim Berry 

Mr. Robert DeGraff 

Mr. Nelson Douglass 

Mr. Dave Evans 

Mr. Tom Griffiths 

Ms. Linda Herring 

Mr. Greg LaFlam 

Mr. Ken Meardon 

Mr. John Schweitzer 

Ms. Madeleine Strum 

EPA/ESD 

Werner Company 

Reichhold Chemicals 

Creative Pultrusions 

Omega Pultrusions 

EPA/ESD 

PES, Inc. 

PES, Inc. 

• SPI/Composites Institute 

EPA/ESD 

(919) 541-5605 

(847) 455-9450 

(919) 990-8256 

(505) 347-2226 

(216) 562-5201 

(919) 541-5358 

(919) 941-0333 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

PURPOSE 

The meeting was requested by the PIC Technical Committee to discuss specific 

approaches to regulating the pultrusion industry, including determination of MACT floors 

and evaluation of emission reduction measures. The EPA also was seeking additional 

information on the control measures that the PIC had tested. These measures may allow 

facilities to achieve floor levels of control. 

DISCUSSION 

After introductions were made, Mr. Schweitzer asked the EPA to summarize the 

current status of the MACT floors for the pultrusion subcategory. Ms. Strum described 

the floor for existing sources as a 47.5 percent reduction (based on the median of the best 
P.3 

Madeleine Strum 

May 24, 1996 

Page 2 

controlled sources, which has a control system with an estimated 50 percent capture and a 

95 percent destruction efficiency). For new sources, the floor is 95 percent reduction of 

totally uncontrolled emissions. Mr. Schweitzer then stated that, despite their economies of 

scale, no new major pultrusion facilities would be built if 95 percent were the required 

level of control; therefore, this standard is not actually "achievable." Instead, new plants 

would consist of many smaller, uncontrolled plants. He felt that encouraging the construction of larger, better controlled facilities (with the attendant better economies of scale) 

would be a smarter approach because both the environment and industry would benefit. 

Mr. Griffiths asked whethernew production lines would be treated as new sources. Ms. 

Herring replied that this would depend on how the affected source was defined in the 

standards. 

Mr. Schweitzer expressed the opinion that the top three pultrusion facilities in the 

EPA's data base are not typical of the pultrusion industry. For one facility (Enduro), he 

said the vast majority of emissions are from the continuous lamination and hand layup/ 

sprayup processes. For the second facility (Owens-Corning), the operation is not profitable with the control system in place. Additionally, for another of the controlled facilities 

(Glastic), the capture efficiency of their building enclosure/carbon filter system is very 

poor. Finally, with regard to the third facility (Tecton), Mr. Griffiths stated that all 

pultruded window lineals must be painted; therefore, Tecton's incinerator is probably 

installed to control both pultrusion and painting operations. Ms. Strum said that Tecton's 

pultrusion operation was controlled with an incinerator; she did not think the painting 

operation was controlled with an incinerator. Tecton's State air permit does not refer to 

emissions control of painting; PIC members pointed out that the painting may be covered 

in a separate permit. In response to Mr. Schweitzer's observation that pultrusion is a 

small part of some facilities' operations, Ms. Strum said that a major source facility with 

any amount of pultrusion would qualify to be regulated under this standard. Ms. Strum 

also said that die Office of General Counsel had advised that the reason for a facility's 

installing control equipment should not be a consideration in the EPA's evaluation of 

controlled facilities. 

Mr. Schweitzer pointed out that, while it is technically feasible to vent emissions 

from the pultrusion process alone to an incinerator, it would not be economically feasible. 

When asked whether the industry had analyzed control devices other than incinerators, Mr. 

Schweitzer said that the industry's experience had not been good with alternate technologies. He noted that a Polyad adsorption system had exploded. (Ms. Strum called the 

vendor (Weatherly) and was told the explosion was not at a facility emitting styrene; it was 

due to a pollutant for which the system was not originally designed.) Mr. Griffiths agreed 

that economic viability is the bottom line issue for the industry. Mr. Schweitzer stated his 

belief that Congress could not have intended that this potential level of hardship occur, and 

asked whether the EPA could utilize an interpretation of the Clean Air Act that would 

avoid it, such as has recently been done by the EPA for section 112(g). Ms. Herring said 

2. 
P.4 

Madeleine Strum 

May 24, 1996 

Page 3 

that the only flexibility available under section 112(d) is subcategorization. She stressed 

that the EPA does not want to impose hardship on anyone, but that, unlike section 112(g), 

a lot of precedent has been set in interpreting section 112(d) and setting HAP standards. 

She also said that the subcategorization may not be based on economic considerations. 

Mr. Schweitzer then observed that, under the dry cleaning standard, small cleaners had 

been exempted from control equipment requirements on that basis. It was noted that dry 

cleaning also covered area sources, which are not necessarily subject to MACT. The PIC 

representatives noted that it would be very difficult to structure a rule on the basis of the 

end-products that could be subject to particular control technologies. 

Ms. Herring asked whether, in the absence of a MACT standard, there would be 

any major sources at facilities that performed pultrusion only. Mr. Schweitzer said that 

there are diree facilities that are pultruders only and are also major sources. Mr. Griffiths 

pointed out that these companies are Creative Pultrusions (24 machines at two locations), 

Omega Pultrusions, and MMFG (Bristol, VA). Ms. Herring asked what growth was 

expected in the pultrusion industry. Mr. Evans said that 10 percent growth per year is 

projected over the next 5 years, with two or three new machines being installed per 

month, or a doubling in capacity by the end of the century. Mr. Griffiths said that they 

would not remain competitive if control equipment had to be installed, and the increased 

costs of operation will not be able to be passed on to customers. He noted that when they 

first started out they knew very little about the costs of abatement. Since then, they have 

hired a consultant to visit many facilities and study control devices. Based on the results 

of this effort, their conclusion has been that the costs of such devices for facilities with 10 

to 15 lines would not allow them to be competitive; that the costs "eat up the profits and 

then some." Mr. Griffiths did note that they are not opposed to abatement, but they can't 

afford to spend $1.5 million dollars for controls. Mr. Evans said that their competitors 

are aluminum extrusions, pre-stressed concrete, and (wooden) tool handles. 

Mr. Berry pointed out that Congress probably intended the industries with the 

smallest environmental impacts to survive. Mr. Evans noted that standards generally 

impact small businesses much more heavily than larger ones, yet in this industry a $40 

million company with 230 employees is one of the larger facilities. Mr. Berry indicated 

that a residual risk assessment would be performed 7 years after the standards are issued. 

Mr. Schweitzer stated that, while an odor problem exists, studies are being conducted, the 

results of which he felt would show that the effects of styrene are not likely to show 

excess diseases and the industry, therefore, does not present a health risk. He further 

stated that the half-life of styrene is very short and the decomposition products are benign. 

Thus, he did not feel "residual risk" would be an issue for the industry in 7 years. 

Two of the companies present at the meeting reviewed the emission reduction 

measures in effect at their production facilities. Creative Pultrusions has instituted many 

pollution prevention measures, such as a temperature controlled environment and air 

_? 
P.5 

Madeleine Strum 

May 24, 1996 

Page 4 

curtain barriers at the wet areas of the machines. Mr. Evans said that their emissions have 

been reduced, but the company cannot evaluate the impact of the measures individually. 

Mr. DeGraff stated that the Werner Company also has placed many measures into effect, 

including temperature control and resin die injection. 

Mr. Griffiths made a presentation discussing the four principal emission reduction 

approaches that the pultrusion industry has evaluated. These are: 1) die injection, 2) 

preform injection, 3) maximal wet area enclosure (WAE), and 4) low air flow past the wet 

area (15 fpm or less). Ms. Strum noted that the die injection machine tested in the 

pultrusion study was at least equivalent to (if not better than) an add-on control device. 

Mr. DeGraff then stated that Werner could not verify that they have seen 95 percent 

emission reduction from their die injectors. He said that there were reductions, but there 

is also a cost in terms of higher scrap generation. Mr. Griffiths stressed that some of 

these reduction measures may not be appropriate for some types of product. However, 

there are too many criteria involved to decide in advance all the cases where die injection 

would be feasible (e.g., shape of part, porosity requirements, electrical properties, etc.). 

Mr. Douglass pointed out that products with lower filler content or thin-walled construction are more likely to be able to be made successfully with die injection. The company 

representatives estimated that injected dies add 30 percent (Creative Pultrusions) to 40 

percent (Werner) to tooling costs, with respect to the cost of regular dies. Mr. Evans 

pointed out that the total costs would include the resin feed system costs as well as the die 

costs. The dies do wear out and have to be reworked or replaced; Omega Pultrusions has 

replaced three dies in 14 years. 

Ms. Strum asked whether the industry had developed a definition for this control 

measure, and Mr. Griffiths read a definition for "in-die injection." Since there inevitably 

is some loss or leakage of resin at the inlet side of the injected die (known as backflow), 

the group discussed ways to measure and limit backflow, and the control efficiency that 

should be attributed to this measure. The difficulties of enforcing a requirement and 

verifying compliance were discussed. One approach could involve placing a limit on the 

amount of backflow allowed, expressed as a percentage of resin use or total production. 

In this scheme, a 99 percent emission reduction efficiency might be assumed for the 

situation in which the die remained dry (as occurred in the pultrusion study), with the 

efficiency reduction reduced proportional to the measured amount of backflow. The group 

discussed certifying new injection dies on the basis of their backflow. Mr. Evans said 

that, due to die wear, a backflow test should be run on a die at fixed production intervals 

(such as every 10,000 feet of product). 

Mr. Griffiths then read a suggested definition for "preform injection." This 

measure, which allows considerably more wet resin to be exposed to the air than in-die 

injection (and the wet area is not covered), achieves its reduction by reducing the length of 

the wet area (from approximately 60 inches in the normal case to 15 inches with preform 

H 
P.6 

Madeleine Strum 

May 24, 1996 

Page 5 

injection). Therefore, tracking the cycling of resin from the preformer to the drip pan is 

not needed to verify the emission reduction from this control measure (as it is with in-die 

injection). Ms. Strum suggested that, as long as the length of the wet area was not more 

than 15 inches, it would be considered in compliance. Since it may be unclear how much 

the wet area was reduced in any particular situation, this technique would not be given any 

extra credit for averaging. 

Mr. Griffiths then read the industry's definition for "covered wetout device," and 

showed photographs depicting this measure. He said that the wetout area is considered to 

extend from the entrance of the resin bath to the entrance of the die. 

The group discussed the use of low air flows (15 fpm or less) past the wet area as 

another control measure that has been shown to achieve reductions. The issue of whether 

instruments are available to measure such a low flow was brought up, and the participants 

felt that demonstrating compliance with this level could present a problem. Mr. Schweitzer said he would investigate this issue and provide results to the group. Another issue 

discussed was the frequency with which an air flow reading should be taken to ensure 

compliance with a low air flow requirement. Suggestions ranged from once per shift or 

day, to once per production run that lasts more than 1 day. 

Mr. Schweitzer concluded by pointing out that the industry has come part way by 

tentatively accepting the 47.5 percent reduction level as an achievable floor for existing 

pultrusion sources. Mr. Griffiths provided to the EPA the industry's proposed MACT 

standard for pultrusion operations (included as an attachment to this memorandum). 

ACTION ITEMS 

Mr. Schweitzer and the other PIC members agreed to perform followup activities 

pursuant to the discussions at the meeting. These activities are: 

1. Revise the industry's control measure definitions as discussed at the meeting. 

2. Investigate the availability of instruments that will provide reliable 

measurements of air flow in the vicinity of 15 feet per minute. 

3. Develop a preliminary method to calibrate a resin injected die (i.e., determination of resin backflow). 

The EPA and PES agreed to investigate the MMFG facility in Bristol, VA and add 

it to the data base if appropriate. 

Attachment 

3 
prcv/>'dedi oT 

P.7 

t 

Proposed MACT Standard For Pultrusion 

1. Bulk resin storage tanks shall have conservation vents. 

2. Mixing and transfer tanks shall remain covered unless 

materials are being added to the tank. 

3. One of the following (A. or B. or C.) shall be employed to 

reduce HAP emissions from the pultrusion process. 

A. Direct Resin Injection. 

Direct resin injection shall be defined as a 

pultrusion system in which the reinforcements enter 

the application system dry. After being wet out, the 

reinforcements are not exposed to air prior to being 

cured"~±nr-4he. die. 

B. The modified resin injection system is composed of one 

or two reinforcement saturation (wet out) chambers. 

The reinforcement wet out occurs within enclosed 

chambers by pressured resin mixes transferred to the 

chamber without air exposure. The direct exposure of 

the wet out reinforcements to air is minimized by a 

combination of metal shields, dry reinforcement, and/or 

dry surfacing veil. A maximum exposure of 15" of wet 

reinforcement along the direction of pull is permitted. 

Drip-off of excess resin mix at the entrance to the die 

and injector(s) are permitted. 

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P.8 

C. A covered wet out device plus one of the following 

methods of minimizing air flow over wet areas. 

The covered wet out device shall be the apparatus where 

the reinforcements and liquid resin initially make 

contact. The openings to allow dry reinforcements to 

enter and wet reinforcement to exit may be no larger 

than the dimension of those reinforcements plus 3/8". 

The wet out device shall be fully enclosed to limit 

contact of the resin with free flowing air. This 

enclosure will consist of a fully enclosed block design 

or covers. The assembled covers shall have no gaps 

wider than 3/8". Ports for level control devices, 

monitoring devices, agitation shafts, fill hoses, etc. 

shall have no more than 3/8" per side clearance. Any 

lid or opening for adding resin or reinforcements to a 

bath shall be designed to fit. 

i. Enclose Wetted Areas. 

From the exit of the covered wet out device to the 

die entrance or resin preheater entrance, 66% 

(40%) of the preform area shall be enclosed to 

minimize air flow. 

The enclosure shall be designed to cover the top, 

bottom, and both sides of the area, including drip 

pans, resin pans, sumps, etc. The openings for 

-2- 7 
P.9 

wet reinforcements to enter and exit the enclosure 

may have a maximum 12" per side clearance around 

the wet reinforcements. (See drawing #1) 

Access panels, doors, hatches or flexible curtains 

will be considered as part of the enclosure 

provided they are designed to fit. 

Appropriate measures to protect personnel from 

exposure to hazardous vapors will be taken. 

Enclosure materials shall be non-porous to exclude 

the free flow of air. Both rigid and flexible 

materials are allowed. \y„ 

L - Length of space between resin bath and die. 

W - Width of saturated reinforcements. 

t = Thickness of saturated reinforcements 

(See Fig. 1) 

Proposed MACT has that the enclosure must be 

within 12" of the wet reinforcements. 

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P.10 

Define: 

a Distance from the left side of the 

enclosure to the saturated 

reinforcement. 

i2 = Distance from the right side of the 

enclosure to the edge of the saturated 

reinforcements. 

ix ~ Distance from the top of the enclosure 

to the top of the saturated 

reinforcements. 

i2 - Distance from the bottom of the 

enclosure to the bottom of the saturated 

reinforcement. 

An imaginary enclosure can be constructed in the 

area between the resin bath and die with the 

following dimensions: 

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P.11 

Where the following limitations exist on the space 

from the enclosure to the wet reinforcements, 

(proposed MACT). 

hx _ 12" 

h2 _ 12" (1) 

a1 _ 12" (See Fig. 2) 

a2 _ 12" 

The surface area of the enclosure is calculated 

by: 

A = L x (t + h: + h2) + L x (t + \ + h2) + L x 

(W + ax + a2) + L x (W + al + a2) 

A = 2 L x (t + hx + h2) + 2 L x (W + ax + a2) 

A = 2 L [(t + h; + h2)) + (W + ax + a2)] (2) 

(eg) t = 2" 

\ 

h2 

W 

a

i 

a

2 

L 

__ 

_ 

= 

_ 

= 

_ 

10" 

10" 

6" 

8" 

8" 

36" 

A = 2 (36) [(2 + 10 + 10) + (6 + 8 + 8)] 

A = 3168 in2 

-5-

10 
A. •* The enclosure does not have a side opening, 

- To use a 67% coverage factor, reduce "L", 

the length of the imaginary enclosure 

by 33%. (See Fig. 3) 

L1 = .67 X L 

with some restriction on sealing open end. 

B. -• The enclosure contains a side opening for 

continual operation. (See Fig. 4) 

-6-

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\ 

m 

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WET-OUT 

DEVICE 

a L 

ENCLOSURE 

° i _ 

i 

^ \ ' DIE \ 

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Where: 

R = Width of opening (side) 

L2 - New length to maintain a 67% surface 

area coverage with a continual view 

slot. 

L >.L2 > Lx 

_2 must be longer than the enclosure 

without a slot. 

From the surface area formula previously 

presented (2). 

A = 2 L [(t + hx + h2) + (W + ax + a2)] (2) 

Because of the width of the slot "R", the 

effective height of the surface area is reduced 

by (t + hx + h2) -» (t + hx + h2 - .5 R) 

Where the .5 factor accounts for the fact that 

equation (2) is derived for two sides, but the 

slot only goes on one side. Equation (2) 

becomes, for a slot. 

• 67A - A2 - 2 L2 [(t + \ + h2 - R) + 

(W + ax + a2)] (3) 

For a slot in the (eg) previously discussed 

having a total space of L = 36". 

A, = .67A » .67 (3168 in2) = 2122.56 in2 

-7-
P.14 

This is the surface area which must be 

maintained with the slot. From this, the 

constraints on "L2" and "R" can be obtained. 

A2 = 2122.56 = 2 L2 [(2 + 10 + 10 - .5R) + 

(6 + 8 + 8)]. 

A2 = 2122.56 = 2 L2 [(22 - .5R) + 22] 

1061.28 - L2 [44 - .5R] 

.5 L2 R = 44 L2 - 1061.28 

L2 R » 88 L2 - 2122.56 

L , 

24.12 0 (i.e., no slot at this length) 

28.00 12.2 

30 17.2 

To use this: 

(1) Calculate reference surface area in 

equation (2). 

(2) Use equation (3) 

NOTE: The available covering will be a 

function of the preformer size. 

-8- [ 3 
P.15 

NOTE: This assumes a rectangular enclosure. 

The surface area concept works for other 

designs. 

ii. Any shroud, curtain or other covering method shall 

be such as to maintain an air velocity of 15 

ft/min. or less at 3 inches above the wet 

reinforcement. 

4. HAP solvent purchases other than reactive diluents shall be no 

more than .015 lbs. per pound of composites produced. 

-93-"