p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

116) ll-E-76 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:07 AM Sheet 116 of 264 
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V--.-.*'fl A-94-FL 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: October 21, 1996 

P:\N504 

SUBJECT: Minutes of September 26, 1996 Meeting on Regulatory IssuesManufacturing of Corrosion-Resistant Composites Products 

LOCATION: EPA/Mutual Building, Durham, NC, 10th floor conference room, 

1:00 pm-3:30 pm 

ATTENDEES: 

Mr. Kenneth Kensington 

Mr. Greg LaFlam 

Mr. Steven Linnemann 

Mr. Richard Martens 

Mr. Frank Mayfield 

Mr. Ken Meardon 

Mr. Frank Pickering 

Mr. John Schweitzer 

Mr. Edward Short 

Ms. Madeleine Strum 

Viatec 

PES 

RL Industries, Inc. 

Reichhold Chemicals 

Ershigs, Inc. 

PES 

Ershigs, Inc. 

SPI/Composites Institute 

MFG Justin Tanks 

EPA/OAQPS 

(616) 948-3860 

(919) 941-0333 

(513) 874-2800 

(919) 990-8007 

(817) 865-8171 

(919) 941-0333 

(360) 733-2620 

(313) 668-4703 

(302) 856-3521 

(919) 541-2383 

PURPOSE 

The meeting was requested by the Society of the Plastics Industry (SPI) and several 

companies that manufacture products using what they call "premium," corrosion-resistant 

resins. Their purpose was to present a draft proposed definition for this industry segment 

and to explain their desire to be considered separately in developing MACT standards for 

the reinforced plastic composites industry. 

DISCUSSION 

The meeting began with the attendees introducing themselves. Mr. Schweitzer said 

that those present at the meeting were manufacturers of large structures using corrosionresistant (CR) resins, primarily by means of the filament winding and open molding 

processes. He pointed out that the control technologies that have been under discussion 
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Madeleine Strum 

October 10, 1996 

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for the industry (such as low-monomer content resins, vapor suppressant additives, and 

highly-filled resins) may not apply to the CR resin industry segment and could compromise 

the CR properties of the products. The companies in this segment typically are custom 

shops and do not have standard product lines. 

Mr. Schweitzer handed out a draft proposal defining users of CR resins as a 

distinct subcategory for the purpose of the MACT standards (Attachment). He explained 

that the handwritten markups on the proposal had been added too recently to be incorporated into the printed version. Under this proposal, at least two of the three conditions listed 

in the definition would have to be satisfied in order for a facility to qualify for the CR 

MACT subcategory. Ms. Strum asked whether in fact all three conditions would need to 

be satisfied. She was concerned that someone might fulfill conditions 2 and 3, yet not be 

a CR facility, and she suggested that condition 1 (resin type) be a prerequisite for defining 

all CR facilities and then such facilities would be required to meet either condition 2 

(performance standard) or condition 3 (application) to qualify for the CR subcategory. 

Industry members agreed that (1) meeting conditions 2 and 3 alone would not adequately 

define this segment and (2) satisfying condition 1 in addition to either condition 2 or 3 

would adequately define the segment. 

The EPA and PES suggested that the definition should allow for potential new 

developments in resin types used in CR applications. The industry agreed that this would 

be a good idea, but Mr. Martens said that companies may not have the incentive to 

develop new resins if there were a lot of regulatory hoops to go through. 

The group discussed whether users would be likely to switch to the use of one of 

the premium, CR resins in order to avoid a monomer content limit or a requirement to use 

vapor suppressants that may be imposed on non-CR fabrication applications. Mr. Schweitzer said it would be "stupid" for a manufacturer to cheat in this way, because premium 

resins are more expensive than low-monomer or suppressed resins. In fact, the company 

representatives agreed that the term "premium" in the industry's proposal (condition 1) is 

virtually equivalent to "more expensive." Mr. Schweitzer also pointed out that odor 

complaints are common near these facilities, and this problem would not be alleviated by 

switching to the higher monomer content, nonsuppressed CR resins. Mr. Martens said it 

would be a "logistical nightmare" to substitute the premium resins where they were not 

needed. 

Industry stressed that the distinction between CR and non-CR resins is quite clear, 

and that most resins do not qualify as CR resins. Nonetheless, Mr. Martens said that it is 

difficult to define a "corrosion-resistant" resin. The CR resins compete successfully 

against metals, primarily because they are relatively maintenance-free. They said that the 

resin (which is corrosion-resistant, but brittle) and glass fibers (which are non-CR, but 

strong) work together to create a strong, corrosion-resistant structure, typically, a 

X 
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Madeleine Strum 

October 10, 1996 

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resin-rich surface layer is built into the product to protect the reinforced laminate from 

corrosion (wear). Mr. Mayfield noted that CR resins perform in a variety of environments-acidic, caustic, solvents, blends-all of which pose special problems and concerns. 

Even water can be considered a corrosive environment (thus, only certain resins can be 

used in food handling or potable water applications). Industry also noted that the length of 

performance of CR resins is a relative term. In some applications, they may last many 

years (e.g., a vinyl ester tank in service for 21 years), but in others they may perform 

adequately for as little as 1 year or less. However, even in the shorter life applications the 

customers are pleased because CR resins still provide a longer performance life than 

alternative materials. Failure of CR resins might occur from sudden process changes or 

permeability of the handled liquid into the structure. Failure might also occur as a result 

of simple mechanical damage. Mr. Martens noted that the resin-rich surface is in contact 

with the corrosive environment and over time may reach a level of "unacceptability" and 

would then need to be replaced. Mr. Linneman also noted that performance life is 

affected by the quality of fabrication. 

Industry said that the different resin chemistries compete for different applications; 

while each resin is typically matched to a set of applications, there is some overlap in 

selecting resins. As an example of the specificity of resin type to application, Mr. 

Martens described the case of a chlorine dioxide bleach tower that was designed for use in 

a pulp and paper plant, for which 28 resins were tested and only 1 of them was found to 

be suitable. Industry also stressed that the suppliers of CR resins may specify different 

resins as being "best" for a given application. Mr. Mayfield stated that, nevertheless, each 

resin chemistry has its own "best" applications. 

Industry was asked to describe novolac vinyl esters and bisphenol fumarates, two of 

the CR resins listed in their definition. They said novolac vinyl esters are based on 

novolac epoxy, and are especially suited to hot solvent applications. They are more 

expensive than normal vinyl esters (which are bisphenol A-based) and not as tough, but 

are perhaps the most corrosion-resistant resin in use. Mr. Pickering noted that the novolac 

vinyl esters are used in the most aggressive atmospheres. Bisphenol fumarates are the 

original CR resins, used in high pH and oxidizing environments, and have excellent 

resistance properties, but are being replaced in many applications by vinyl esters because 

the vinyls have added toughness, a lower price, and are "more friendly" in the fabrication 

shop. 

The group discussed the use of vapor suppressants in combination with CR resins. 

Industry said that the presence of suppressants could affect the chemical resistance of the 

product, which could be a major liability issue for the fabricator. Mr. Martens emphasized that the life of a product could be shortened (through reduced chemical resistance 

and/or insufficient bonding of components), and Reichhold would not be comfortable 

endorsing the use of suppressants in CR applications. Mr. Kensington said the success of 

3 
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Madeleine Strum 

October 10, 1996 

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his business depends on the life of the products; if it can be demonstrated that these 

additives do not impact this property, he would look into giving them a trial. Ms. Strum 

mentioned that Dow had developed suppressants for use in conjunction with vinyl ester 

resins. Mr. Kensington responded that he is one of the largest CR product manufacturers, 

and Dow has not approached his company about this product. Mr. Schweitzer said that a 

large portion of the CR industry was represented at the meeting, and they were not using 

nor were they familiar with the successful use of such additives in CR applications. He 

repeated that the product maker bears liability if the product fails, so they have to be 

conservative in making any changes to their formulas or methods. 

Mr. Schweitzer said that low styrene content resins usually have a lower molecular 

weight, and these resins are not used in this segment of the industry. Mr. Martens said 

that CR polyesters are "cooked out" to the highest possible molecular weight, so more 

monomer is required to make them workable. While there are vinyl esters available with 

a 35 percent monomer content, these resins do not work in all applications. 

Mr. Schweitzer said that if a HAP monomer content limit below 50 percent were 

imposed on this industry, it would mean that certain resins and products would no longer 

be allowable. Mr. Martens stated that some products would be removed from the market 

with a standard lower than the 48 percent allowed in California's South Coast district. 

Mr. Schweitzer said industry's MACT proposal (not included in their handout) consists of 

a combination of housekeeping, covers on containers, operator training, and leak detection 

and repair requirements. 

Mr. Meardon asked about tests to distinguish a CR resin. Mr. Schweitzer replied 

that there is no such standard analytical test. After some discussion about using several 

test methods to define a CR resin, industry generally agreed that the use of test methods is 

not a realistic option for defining a CR resin. 

PES distributed copies of facility lists from the EPA's data base for open molding 

and filament winding showing facilities the EPA considers to fit the corrosion-resistant 

designation, based primarily on the information in the 1993 EPA screening survey. The 

industry representatives reviewed and commented on the tables, noting several instances 

where they believed facilities were incorrectly placed. For example, Mr. Pickering 

thought that Owens-Corning used only one resin in a process where chopped glass and 

resin are dropped onto a mandrel. He did not consider this process to be filament 

winding, but more of a continuous lamination process. Industry also stated that they did 

not believe the resins used to make underground gasoline storage tanks are corrosionresistant. They also felt the light poles made by the Shakespeare Company do not qualify 

as corrosion-resistant. Ms. Strum said the tables would be re-evaluated and revised where 

necessary. Industry questioned what they felt were the "too low" monomer content levels 

shown for certain facilities, and said that these were aggregate values. Ms. Strum 

M 
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Madeleine Strum 

October 10, 1996 

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responded that, if these values (as reported by the facilities) were a measure of average 

monomer content, this indicates that these CR facilities are using resins both above and 

below these average levels. 

Mr. Schweitzer asked the EPA and PES what they needed industry to do to assist 

in the rulemaking effort for this industry segment. Mr. Meardon replied that, in order to 

determine MACT floors, the EPA needed to know what users are actually doing in terms 

of monomer content for each of their applications and the amount of each resin that they 

used. This would allow calculation of weighted averages. Industry expressed concern 

about this because they use 200 to 300 different formulations and questioned whether all of 

those data would be useful. Mr. Schweitzer repeated that each environment to which CR 

products are exposed is different, so the materials used by one facility may not be 

appropriate for another facility. The group discussed whether it would be productive to 

survey facilities in an attempt to correlate monomer content with the corresponding 

application or chemical environment. Industry said that such an effort would be very 

time-consuming. Several of the companies present offered to provide any needed data and 

to make their facilities available for a site visit. Mr. LaFlam said that the EPA and PES 

would appreciate any further input that would enable PES to correct the data base. 

ACTION ITEMS 

Mr. Schweitzer said that industry will revise its proposed definition for the 

corrosion-resistant MACT subcategory based on the handwritten markups and on the 

discussions at the meeting. The revision will include the specific emission reduction 

measures industry is proposing for manufacturers using CR resins. Industry will also 

provide to the EPA any additional corrections of the data base. Two of the companies 

(Ershigs and Viatec) agreed to provide the HAP content for their formulations. 

The EPA will revise the data base tables in order to place facilities in the correct 

subcategories, based on input from the industry. 

$ 
1 

Draft proposa l 

Attachment 

> 

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MACT subcategory for the manufacture of 

corrosion-resistant composite products 

Introduction 

While composites in general will not rust or degrade under normal 

conditions, many composite products are specifically formulated and 

produced for applications requiring higher levels of chemical 

purity and/or resistance to corrosion. Such applications include 

waste water treatment, pollution control, metal plating, food and 

drug processing, pulp and paper production, chemical processing, 

and many others. 

These "corrosion resistant" applications often require special 

resins and/or manufacturing technologies to ensure that the 

resulting product is sufficiently chemically resistant or inert. 

The use of these special resins and technologies are often 

incompatible with emission reduction methods commonly used 

elsewhere in the composites industry. For example, corrosion 

resistant composite products often cannot be economically 

manufactured using low-VOC, emission-suppressed, or highly-filled 

resins. 

Subcategory definition 

A composite product shall be considered "corrosion resistant," and 

the manufacture of the product shall be included in the corrosion6 
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resistant MACT subcategory, if any two of the following three 

conditions are satisfied. •> 

1. The product is *a€te with n premium resin or is post-cured at 

temperatures above 100 deg. C. Premium • resins include 

isophthalic polyester,, vinyl ester, .fumarate polyester, 

chlorendic acid polyester, and novolac vinyl ester. . 

2. The product is manufactured to an accepted standard for 

corrosion-resistant or food contact applications. Such 

standards include ASME RTP-1; ASTM D5364, -C502-, D3299, D4097, 

D2996, D2997, D3262, D3517, D37$4, D3840, D4024, D4160, D4161, :>£?$Z., 

D4162, D4163, D4184; ANSI/AWWA C950; d**^ Ssc+-X. •*' I 

3. The product is manufactured specifically for an application 

that requires increased chemical inertness or resistance to 

chemical attack. Such applications include products intended 

for use in chemical processing^ pulp and paper, sewer and 

waste water treatment, potable water, food and drug 

processing- v pollution or odor control, metals plating, 

semiconductor manufacturing, petroleum production and 

refining, and others. 

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