p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

30) ll-C-26 

Docket Number: 

A-94-52 

Printed 7/3/2008 8:22:03 A M Sheet 30 of 55 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

October 20, 1995 

Dear Team and/or Work Group Member: 

;*A^-fr,Vli.*! J 'F'V' 

DEC 3 5 

%& EPA AIR DOCKET *& &. 

Per the September 27, 1995 meeting, I am forwarding a copy of a draft "Industry 

Description Memorandum" to the trade association members and others who have volunteered to 

review it. This memorandum contains information on the Standard Industrial Codes included in 

the reinforced plastic composites source category, information about major sources and their 

locations, employment information, resin shipment data, and existing State and local regulations 

for the industry. If anyone else would like to review this memorandum, please contact me at 

(919)541-2383. 

Sincerely, 

^ A 

Madeleine Strum 

Environmental Engineer 

Coatings and Consumer Products Group 

Enclosure 

/ 
P.3 

Addressees: 

Mark Bahner, RTI, w/Enclosure 

Mohan Balagopalan, SCAQMD 

Janet Beloin, Region I (Electronically Sent) 

Bob Burmark, Washington DOE (Electronically Sent) 

Neil Carman, Sierra Club (for Ben Pamar) 

Leonardo Ceron, Region IV (Electronically Sent) 

Linda Chappell, OAQPS/AQSSD (Electronically Sent) 

Patricia Embrey, OGC (Electronically Sent) 

Bob Fegley, ORD (Electronically Sent) 

Chuck French, OAQPS/AQSSD (Electronically Sent) 

Linda Herring, OAQPS/ESD (Electronically Sent) 

Norm Kaplan, ORD (Electronically Sent) 

Emery Kong, RTI 

Karen Levy, OPAR (Electronically Sent) 

Maria Malave, OECA (Electronically Sent) 

Haile Mariam, OSW (Electronically Sent) 

Craig Matthiessen, OSWER (Electronically Sent) 

Steve McNally, Composites Fabricators Assoc, w/Enclosure 

Christine McPhee, Ohio EPA 

Arnold Medbery, OSDBU (Electronically Sent) 

Richard Nielson, Clark County, NV 

Carlos Nunez, ORD (Electronically Sent) 

Nancy Pate, OAQPS/ITPID (Electronically Sent) 

Solomon Ricks, OAQPS/EMAD (Electronically Sent) 

Ron Ryan, OAQPS/EMAD (Electronically Sent) 

John Schweitzer, Composites Institute, w/Enclosure 

Jordan Spooner, OPPT/PPD (Electronically Sent) 

2. 
P.4 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam and Melanie Proctor % 

Pacific Environmental Services, Inc. (PES) 

DATE: October 17, 1995 

L:\N404 

SUBJECT: Industry Description Memorandum 

This memorandum contains the final version of the industry description memorandum, 

as described under task 7 in PES's revised work plan dated August 10, 1995. Comments from 

the September 27 pre-MACT team meeting about the cutoff for major sources have been 

incorporated. 

2.0 DESCRIPTION OF THE AFFECTED INDUSTRY 

Introduction to industry description.1 The reinforced plastic composites industry 

manufactures products from cured, cross-linked resins, usually in combination with reinforcing 

agents and inorganic fillers. This industry produces a wide variety of products traversing such 

market segments as transportation, construction, electronics, consumer products, marine, and 

aerospace. This diverse source category encompasses as many as 33 Standard Industrial 

Classification (SIC) codes.2,3 Plastic composite boat building has been specifically excluded 

from this rule development effort and will be addressed separately. Plastics are divided into 

two major groups known as thermoset and thermoplastic. Once cured into a solid form, 

thermoset materials remain a hard solid. Thermoplastics, on the other hand, can be melted 

numerous times through the application of heat. The reinforced plastic composites source 

category includes only thermoset materials. Thermoset resins are usually liquids or low 

melting point solids in their initial form. In the production of finished goods, thermosetting 

3 
P.5 

resins are cured into a solid by use of a catalyst, heat, or a combination of both. 

2.1 GENERAL DESCRIPTION 

2.1.1 Types of industrial groups included.2*

3

 The SIC codes included in the reinforced 

plastic composites source category were determined by searching the toxic release inventory 

system (TRIS) data base for facilities emitting styrene, a major hazardous air pollutant (HAP) 

emitted by this source category. The TRIS data base identified a total set of 232 SIC codes 

under the pollutant styrene. Codes were deleted for categories that clearly did not fit the 

reinforced plastic composites source category. The 33 remaining SIC codes contain facilities 

involved in the production of plastic composites. However, it is cautioned that not all facilities 

that may fall under these 33 SIC codes are in the composites industry. In addition, there could 

be facilities not encompassed by these 33 SIC codes that may use thermoset resins in their 

operations. Table 2-1 shows a table of the 33 SIC codes potentially covered under the plastic 

composites NESHAP. 

2.1.2 Number of sources.24 The distribution of sources in the reinforced plastic 

composites source category by SIC code is also shown in Table 2-1. The majority of the 

sources (80 percent) are classified under SIC codes 308 and 307, -which classifies 

miscellaneous plastics products. SIC code 307 is an old code used in the 1972 edition of the 

Standard Industrial Classification Manual5, but TRIS still includes several facilities with this 

code. Approximately 6 percent of the sources included in the composites industry are 

classified under SIC code 371, which applies to motor vehicles and motor vehicle equipment. 

The remaining 14 percent of the facilities are distributed over 18 different three-digit SIC 

codes. Table 2-2 shows a complete list of the three-digit SIC codes for this source category 

and their definitions. 

A 
P.6 

TABLE 2-1 

STYRENE SOURCES OBTAINED FROM THE 1993 SURVEY AND 1992 TRIS

 2A 

33 SIC Codes Covered Under Plastic Composites NESHAP 

SIC 

Code 

2434 

2511 

3079c 

3083 

3084 

3087 

3088 

3089 

3281 

3296 

3365 

3499 

3533 

3612 

3621 

3647 

3711 

3713 

3714 

3715 

Title 

Wood Kitchen Cabinets 

Wood Household Furniture 

Plastics Products, NEC 

Laminated Plastics 

Plastics Pipe 

Custom Compound Resins 

Plastics Plumbing Fixtures 

Plastics Products, NEC 

Cut Stone and Stone Products 

Mineral Wool 

Aluminum Foundries 

Fabricated Metal Products, NEC 

Oil/Gas Field Machinery/Equip. 

Power Transformers 

Motors and Generators 

Vehicular Lighting Equipment 

Motor Veh./Pass. Car Bodies 

Tmck and Bus Bodies 

Motor Veh. Parts/Accessories 

Truck Trailers 

Total 

Facilitie 

s 

1 

1 

60 

32 

8 

27 

107 

245 

9 

2 

2 

2 

1 

3 

1 

2 

3 

13 

14 

i 

Major 

Sourcesa 

0 

1 

24 

12 

3 

11 

41 

129 

3 

1 

2 

2 

1 

1 

0 

1 

1 

9 

6 

1 

HAP Emissions for 

Major Sources from 

1993 Survey and 

1992 TRIS Data for 

Styrene (tons)b 

0 

12 

1,081 

742 

40 

465 

4,929 

9,763 

92 

1,613 

32 

46 

11 

48 

0 

16 

37 

376 

185 

96 

<r 
P.7 

TABLE 2-1 (Concluded) 

3716 

3721 

3728 

3743 

3792 

3795 

3949 

3965 

3993 

3998 

3999 

4036 

8734 

Motor Homes 

Aircraft 

Aircraft Parts/Equipment, NEC 

Railroad Equipment 

Travel Trailers/Campers 

Tanks/Tank Components 

Sporting/Athletic Goods, NEC 

Fasteners, Buttons, Etc. 

Signs/Advertising Specialties 

d 

Manufacturing Industries, NEC 

d 

Testing Laboratories 

TOTAL 

6 

1 

1 

1 

18 

1 

8 

3 

1 

3 

23 

1 

1 

602 

5 

1 

1 

1 

13 

1 

3 

0 

1 

2 

12 

0 

0 

291 

173 

22 

28 

128 

510 

77 

64 

0 

56 

30 

359 

0 

0 

21,031 

Major sources in this table are considered to be open molding facilities (e.g., facilities conducting gel coating, 

sprayup, hand layup, or filament winding) with more than 4.34 tons of HAP emissions per year and other nonopen molding facilities with more than 10 tons per year of styrene emissions as reported in the 1993 industry 

survey or 1992 TRIS. If survey information was incomplete or unavailable 1992 TRIS data was used to 

determine the facility's emissions. The reason for choosing a lower cutoff for open molding facilities is that 

recent studies have shown that EPA's emission factor document, AP-42, is likely to underestimate emissions 

for open molding operations by a factor of 2.3. Since many facilities use AP-42 emission factors to calculate 

their emissions, a safety factor is needed to ensure that all major sources are included. 

HAP emissions information was taken from the 1993 industry survey. When survey information was 

unavailable, 1992 TRIS data were used. As explained under foomote a, emissions for open molding facilities 

were multiplied by a factor of 2.3. Since TRIS data do not identify the process used, it was assumed that all 

facilities for which only TRIS data were available engaged in open molding operations. Therefore, facilities 

with TRIS emissions of more than 4.34 tons of styrene per year were considered major sources. 

SIC code 3079 was used in the 1972 edition, but was eliminated in the 1987 edition. TRIS nonetheless 

includes several facilities with this code. While code 3079 has the same title as "new" code 3089, none of the 

TRIS facilities listed under 3079 also appear under 3089. 

SIC codes 3998 and 4036 were not used in the 1972 or 1987 edition, but TRIS includes facilities with these 

codes. 
P.8 

TABLE 2-2 

LIST OF THREE-DIGIT SIC CODES AND DESCRIPTION POSSIBLY INCLUDED IN 

REINFORCED PLASTIC COMPOSITES INDUSTRY

 a4

-

5 

SIC Code 

243 

251 

307 

308 

328 

329 

336 

349 

353 

361 

362 

364 

371 

372 

374 

379 

394 

396 

399 

DESCRIPTION 

Millwork, Veneer, Plywood, And Structural Wood Members 

Household Furniture 

Miscellaneous Plastics Products (Old Category) 

Miscellaneous Plastics Products 

Cut Stone And Stone Products 

Abrasive, Asbestos, And Miscellaneous Nonmetallic Mineral Products 

Nonferrous Foundries 

Miscellaneous Fabricated Metal Products 

Construction, Mining, And Materials Handling 

Machinery And Equipment 

Electric Transmission And Distribution Equipment 

Electrical Industrial Apparatus 

Electrical Lighting And Wiring Equipment 

Motor Vehicles And Motor Vehicle Equipment 

Aircraft And Parts 

Railroad Equipment 

Miscellaneous Transportation Equipment 

Dolls, Toys, Games And Sporting And Athletics Goods 

Costume Jewelry, Costume Novelties, Buttons, And Miscellaneous 

Notions, Except Precious Metal 

Miscellaneous Manufacturing Industries 

Based on styrene emissions and subsequent deletion of clearly inapplicable categories 

\ 

7 
P.9 

2.1.3 Geographic location.2 The geographic locations of major and area sources 

possibly involved in the reinforced plastic composites industry are shown in Table 2-3. The 

geographic information was obtained from the 1993 industry screening survey and 1992 TRIS 

data. A major source is defined as a source emitting 10 tons or more of a single hazardous air 

pollutant per year or 25 tons or more of any combination of HAPs. Since AP-42 appears to 

underestimate emissions for open molding sources by a factor of 2.3, it was decided that any 

open molding source emitting more than 4.34 tons of styrene per year and any non-open 

molding source emitting more than 10 tons of styrene per year would be considered a major 

source. The 4.34 ton cutoff for open molding operations was determined by dividing the 

cutoff for a major source (10 tons) by 2.3, which appears to be the factor by which AP-24 

underestimates open molding emissions. Table 2-3 shows a large number of facilities located 

in Ohio (64), Indiana (57), California (51), and Texas (45). Indiana has the largest number of 

major sources (38), followed by Ohio with 35 major facilities. The largest number of 

non-major sources is located in Ohio (29), followed by California (25), and Florida and North 

Carolina with 20 facilities each. 

© 
P.10 

TABLE 2-3 

DISTRIBUTION OF MAJOR AND AREA SOURCES BY STATE

 2 3 

STATE 

Alabama 

Arkansas 

Arizona 

California 

Colorado 

Delaware 

Florida 

Georgia 

Hawaii 

Idaho 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Minnesota 

NUMBER OF 

MAJOR SOURCES 

3 

3 

2 

26 

0 

1 

10 

7 

0 

2 

17 

38 

5 

10 

5 

3 

1 

2 

0 

11 

9 

NUMBER OF 

NON-MAJOR 

SOURCES 

11 

4 

4 

25 

3 

4 

20 

14 

2 

2 

12 

19 

6 

4 

7 

2 

2 

4 

3 

19 

9 

TOTAL 

14 

7 

6 

51 

3 

5 

30 

21 

2 

4 

29 

57 

11 

14 

12 

5 

3 

6 

3 

30 

18 

7 
P.11 

TABLE 2-3 (Concluded) 

Mississippi 

Missouri 

Nebraska 

Nevada 

New Hampshire 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Puerto Rico 

Rhode Island 

South Carolina 

South Dakota 

Tennessee 

Texas 

Utah 

Virginia 

Washington 

West Virginia 

Wisconsin 

TOTALS 

1 

5 

4 

1 

1 

0 

0 

7 

12 

1 

35 

4 

9 

14 

0 

0 

2 

2 

11 

27 

3 

3 

12 

1 

11 

321 

5 

6 

4 

0 

2 

7 

2 

12 

20 

1 

29 

3 

4 

19 

1 

2 

12 

1 

7 

18 

2 

7 

10 

3 

15 

368 

6 

11 

8 

1 

3 

7 

2 

19 

32 

2 

64 

7 

13 

33 

1 

2 

14 

3 

18 

45 

5 

10 

22 

4 

26 

689 

8 

10 
P.12 

2.1.4 Employment.3 the distribution of workforce size by facility is shown in Table 

2-4. Employment data were obtained from the 1993 industry screening survey. In this survey 

facilities were asked to report their number of employees in ranges (0-100; 101-250; 251-500; 

501-750; 751-1,000; 1,001-1,500; and > 1,500). From the total facilities responding, about 

half of the facilities (363) did report discrete numbers for employees in their.survey response. 

Since the ranges asked for in the survey were rather broad, only the facilities that reported 

discrete numbers were used in Table 2-4 to get a better understanding of the actual size of the 

facilities. It was assumed that the facilities that reported discrete numbers were a good 

representation ofthe industry as a whole. According to the survey information, the average 

number of employees for a facility in the reinforced plastic composites industry is 53. About 

70 percent of the 363 facilities reported 50 or less employees, approximately 16 percent of the 

facilities reported employee numbers ranging from 51 to 100, 11 percent reported 101 to 400 

employees, while only one facility each reported 600 and 1440 employees. 

2.1.5 Distribution by process.2*

3

 There are a number of different processes that can be 

used to produce reinforced plastic composites. A full description of the different processes is 

provided in the process description and emission points memorandum.6 The most common 

processes are: sprayup, hand layup, cultured marble casting, compression molding, 

pultrusion, continuous lamination, filament winding, gel coating, and casting/centrifugal 

casting. Some facilities prepare their own molding compound, which is then sold or used in 

their own operation. There are also a number of facilities that use more than one process at 

their facility. Gel coating, for example, is typically used in conjunction with other lamination 

processes. Table 2-5 shows the distribution of 246 major sources by production process. The 

data for this table were collected from the 1993 industry screening survey. The 1992 TRIS 

data were not incorporated into Table 2-5 because TRIS data do not contain process 

information. Since only 1993 survey information is used in Table 2-5, the total number of 

major sources is smaller here (246) than in Table 2-3 (321), which uses survey and TRIS data. 

A major source in Table 2-5 is the same as described under section 2.1.3. Facilities 

that used several different processes were counted under each process reported for their 
TABLE 2-4 

Number Of Employees By Facility Reported In 1993 Survey Response (Total Number Of Facilities Reporting 

Discrete Numbers = 363) 

^ 

Number Of Employees 
P.M 

facility. Table 2-5 shows that the most frequently used process is resin sprayup reported by 64 

percent of all major surveyed facilities followed by gel coating with 62 percent. It is not 

surprising that gel coating is reported by a large number of facilities, since many products 

produced by other processes have a gel coat finish. Compression molding, which is reported 

by about 17 percent of the industry, is the third most used process, followed, by filament 

winding with 12 percent. Facilities that reported mold production, resin production, or the' 

use of wet mix in the 1993 industry survey were classified as "other" in Table 2-5. Six 

facilities are classified as injection molding operations; even though injection molding is 

usually done with thermoplastic resins, these facilities use BMC for injection molding. 

11 

f3 
P.15 

TABLE 2-5 

DISTRIBUTION OF MAJOR SOURCES BY PROCESS

 2

-

3 

(Total Number Of Major Sources = 246) 

PROCESS 

Casting "/Centrifugal Casting 

Compounding (SMC, BMC & TMC) 

Compression Molding 

Continuous Lamination 

Cultured Marble Casting 

Filament Winding 

Gel Coating 

Injection Molding 

Hand Layup 

Prepregging 

Pultrusion 

RTM 

Sprayup 

Vacuum Bagging 

Other 

NUMBER OF 

FACILITIES 

6 

17 

42 

12 

14 

30 

152 

6 

26 

6 

19 

13 

158 

1 

9 

% OF FACILITIES REPORTING 

PROCESS 

2 

7 

17 

5 

6 

12 

62 

2 

11 

2 

8 

5 

64 

>1 

4 

Casting is a different process from cultured marble casting and centrifugal casting. 

12 

tf 
P.16 

2.2 MAJOR MARKETS AND PRODUCTS 

2.2.1 M.nor market categories.47 The major market categories included in the 

reinforced plastic composites source category are: transportation, packaging, building and 

construction, electrical/electronics, furniture and furnishings, consumer and»institutional 

products, industrial/machinery, adhesives/inks/coatings, and exports. The transportation 

market category includes motor vehicles and parts, railroad equipment, travel trailers, 

campers, aircraft, boats, and recreational vehicles. The SIC codes included under this market 

category are 371, 372, 374, and 379. The packaging market category includes all sorts of 

shipping containers like drums, boxes, and crates as well as packaging materials. The SIC 

code 308, Miscellaneous Plastics Products, covers this market category. The building and 

construction market category includes items like pipe, conduit, plumbing fixtures, showers, 

bathtubs, siding, flooring, skylights, and railings. The SIC codes most closely related to this 

category are 353 and 308, which cover construction, materials handling and equipment, and 

miscellaneous plastic products. SIC code 243 relates to millwork, veneer, plywood, and 

structural wood members, which also covers products used in the building and construction 

market sector. The electronics market category includes home and industrial appliances, 

resistors, and wire and cable coverings. The SIC codes for this market category are 349, 361, 

362, and 364. The furniture market category relates to products such as household and office 

furniture and covers SIC code 251, which is household furniture. Consumer and industrial 

products are covered by SIC codes 308, 394, 396, and 399 and cover a wide variety of goods 

ranging from toys, sporting goods, costume jewelry, buttons, and ladders to barber shop 

equipment. 

2.2.2 Resin use bv market category.7 According to 1993 data, a total of 

6,900,544,000 pounds of thermoset resin is used per year on a dry weight basis. The majority 

of the resin (67 percent) is used for the building and construction market. The transportation 

market uses approximately 9 percent of all thermoset resin. All other major markets use only 

a small amount of the total thermoset resin produced. Table 2-6 provides information about 

the quantity of resin used and the distribution of thermoset resin sales and usage by major 

13 
P.17 

market category for 1993. 

The 1995 U. S. reinforced plastics industry (thermoset and thermoplastic) is projected 

to continue to increase by 4.3 percent over 1994. Catherine Randazzo, the Executive Director 

of the SPI Composites Institute, predicts a 4.4 percent growth in the transportation market. 

The Institute concludes that about 37 percent of the growth in the transportation market will be 

in SMC, which is mainly used for exterior body panels, specifically hood applications. 

Growth is also expected in construction, electrical/electronic, and consumer product markets.8 

TABLE 2-6 

1991 USE OF THERMOSET PLASTIC RESINS BY MARKET CATEGORY

 7 

(Thousands of Pounds, Dry Weight Basis)2 

MAJOR MARKET 

Transportation 

Packaging 

Building & Construction 

Electrical/Electronic 

Furniture & Furnishings 

Consumer & Institutional Products 

Industrial/Machinery 

Adhesives/Inks/Coatings 

All Other* 

Exports 

TOTALS 

RESIN QUANTITY 

617,326 

79,975 

4,628,885 

234,481 

146,727 

350,654 

191,001 

168,464 

270,292 

212,739 

6,900,544 

PERCENT OF TOTAL 

8.9 

1.2 

67.1 

3.4 

2.1 

5.1 

2.8 

2.4 

3.9 

3.1 

100 

Phenolic is on a gross weight basis. 

All other totals do not include disclosure data; therefore, these totals may not equal 

the sum of their respective components. 

14 

*tf 
P.18 

2-3 RESIN 

2.3.1 Resin usage bv type.1 A number of thermosetting resins are used in the 

composites industry. The most common ones are unsaturated polyesters, epoxies, vinyl esters, 

and phenolics. Unsaturated polyesters are the most commonly used resins, Representing 

approximately 75 percent of the total resins used in the thermoset composites market. 

Polyesters are produced by the condensation polymerization of dicarboxilic acids and glycols. 

There are many different acids and glycols used in polyester resin production to achieve the 

desired properties in the formulated resin. Since polyesters are so versatile and since they can 

be easily modified or tailored during resin creation, they have found almost unlimited use in 

all segments of the composites industry. Epoxy resins are primarily used for fabricating high 

performance composites with superior mechanical properties, resistance to corrosive liquids 

and atmospheres, superior electrical properties, good performance at elevated temperatures, or 

a combination of these properties. Epoxies are comparatively expensive and their usage has 

historically been limited to high performance applications. Epoxies can be used in most 

composite production processes, particularly vacuum-bag molding, compression molding, 

filament winding, and hand lay-up operations. Vinyl esters are used for their mechamcal 

toughness and good corrosion resistance. They were developed to incorporate advantages of 

epoxy resins into better handling and faster curing products typical of unsaturated polyester 

resins. Phenolics are usually dark colored, limiting them to applications that are red, black, or 

brown. During the composite fabrication and curing step, phenolic resins produce water, 

which has to be removed from the process. Urea and melamine resins can be used for light 

colored products. 

2.3.2 Maior resin manufacturers.7 Table 2-7 shows a listing of some of the major 

resin manufacturers who participated in the SPI monthly statistical report in 1993. As 

indicated in the table, a number of these manufacturers are involved in the production of 

several different resins. The survey did not contain any information on the manufacturers of 

vinyl esters and gel coat. 

15 

ft 
P.19 

TABLE 2-7 

SOME OF THE MAJOR RESIN MANUFACTURERS BY RESIN TYPE

 a 7 

Epoxy 

Manufacturers 

Ciba-Geigy 

Corporation 

Dow Chemical 

U.S.A. 

Reichhold 

Chemicals 

Rhone-Poulenc 

Shell Chemical 

Company 

Union Carbide 

Corporation 

Melamine 

Manufacturers 

American 

Cyanamid 

Company 

BTL Specialty 

Resins 

Corporation 

Hoechst 

Celanese 

Corporation 

Neste Resin 

Corporation 

Occidental 

Chemical 

Corporation 

Rhone-Poulenc 

Phenolic 

Manufacturers 

Allied-Signal 

Corporation 

Ashland 

Chemical 

Georgia Pacific 

Corporation , 

Neste Resin 

Corporation 

Plaslok 

Corporation 

Rogers 

Corporation 

Unsaturated 

Polyester 

Manufacturers 

Cook 

Composites & 

Polymers 

Dow Chemical 

U.S.A. 

Interplastic 

Corporation 

Owens-Corning 

Fiberglass 

Corporation 

Pioneer Plastics 

Corporation 

Reichhold 

Chemicals 

Urea 

Manufacturers 

Borden 

Chemical 

Company 

Cytec 

Industries 

Georgia Pacific 

Corporation 

Monsanto 

Chemical 

Company 

Shell Chemical 

Company 

Spurlock 

Adhesives 

Information for gel coat and vinyl esters were not included in the SPI survey; 

however, Cook Composites and Polymers is a major manufacturer of gel coats. 

2.3.3 Resin production and sales.7 Resin production and sales data are available for 

thermoset resins. However, not all thermoset resins produced and sold are intended 

exclusively for the reinforced plastic composites industry. Table 2-8 presents information on 

the production and sales of five different thermoset resins: epoxy, melamine, phenolic, 

unsaturated polyester, and urea. When examining the epoxy resin production data it is 

16 

/fc 
P.20 

important to note that only about 20 percent of the epoxy resins are used for fiber reinforced 

laminates and composites. Table 2-9 provides infonnation on the actual end use of the epoxy 

resin produced in 1993. The total production of unsaturated polyester is not as high as the 

total production of some of the other resins, but most of the unsaturated polyester resin is used 

for the production of reinforced plastics. This information is shown in Table 2-10. According 

to Table 2-8, the production of phenolic resin is higher than the production of any other resin. 

But when examining the end-use data for phenolic resins (Table 2-11), it becomes apparent 

that approximately 93 percent of the phenolic resin is used for bonding and adhesives. Only a 

relatively small fraction (5 percent) is used for molding compounds. 

TABLE 2-8 

1993 RESIN PRODUCTION AND SALES BY RESIN TYPE

 7 

RESIN TYPE 

Epoxy 

Melamine 

Phenolic 

Unsaturated Polyester 

Urea 

PRODUCTION IN 

MILLIONS OF POUNDS 

512 

270 

3,078 

1,264 

1,744 

SALES IN MILLIONS OF 

POUNDS 

535 

261 

3,081 

1,280 

1,743 

17 
P.21 

TABLE 2-9 

EPOXY RESIN CONSUMPTION BY END-USE

 7 

EPOXY RESIN END-USE 

Bonding & Adhesives 

Flooring, Paving, and Aggregates 

Protective Coatings 

Fiber Reinforced Laminates & Composites 

Tooling, Casting, and Molding Resins 

All Other Uses 

TOTAL 

AMOUNT USED IN 

MILLIONS OF ' 

POUNDS 

33 

34 

218 

81 

17 

31 

414 

18 
P.22^ 

TABLE 2-10 

UNSATURATED POLYESTER CONSUMPTION BY END-USE

 7 

UNSATURATED POLYESTER END-USE 

Marine And Marine Accessories 

Transportation 

General Construction 

Bathroom Components & Fixtures 

Pipes, Tanks, and Fittings 

Panels 

Electrical/Electronic 

Recreational Goods, Toys, etc. 

Other Consumer Goods 

Other Reinforced Goods 

Reinforced Plastics, Total 

Transportation/Body Putty 

Construction 

Consumer Goods 

Gel Coats 

Other Non Reinforced Goods 

Other End-Uses, Total 

AMOUNT USED IN MILLIONS OF 

POUNDS' 

267 

98 

71 

145 

141 

88 

32 

18 

16 

36 

912 

48 

154 

35 

62 

27 

326 

19 
P.23 

TABLE 2-11 

PHENOLIC RESIN CONSUMPTION BY END-USE7 

PHENOLIC RESIN END-USE 

Molding Compounds 

Bonding & Adhesives for Laminating 

Bonding & Adhesives for Coated or Bonded Abrasives 

Bonding & Adhesives for Friction Materials 

Bonding & Adhesives for Insulation Materials 

Bonding & Adhesives for Plywood 

Bonding & Adhesives for Fibrous and Granulated Wood 

All Other Bonding & Adhesives 

Protective Coatings 

All Other Uses 

TOTAL 

AMOUNT USED IN 

MILLIONS'OF POUNDS 

160 

177 

25 

49 

375 

1,540 

485 

189 

12 

39 

3,051 

2.4 EXISTING REGULATIONS 

2.4.1 Introduction.9-18 Existing regulations for the reinforced plastic composites 

industry have been reviewed in order to evaluate potential control strategies and their 

effectiveness. The areas that have implemented regulations for this source category include 

the Puget Sound Air Pollution Control District (PSAPCA) in Washington, California's Bay 

Area, the South Coast Air Quality Management District (SCAQMD), San Diego, Santa 

Barbara, Yolo-Solano, San Joaquin Valley, and Ventura County Air Pollution Control 

Districts, and the States of Maryland and Illinois. Each regulation applies to polyester resin 

20 

7> 
P.24 

and gel coating operations that fabricate or rework products for commercial, military, or 

industrial use including, but not limited to, boats, tubs, pools, shower enclosures, spas, 

bathroom fixtures, jigs, tools, molds, air pollution control equipment, sewage treatment 

equipment, storage tanks, transportation parts, and other industrial and consumer products. 

The purpose of these rules is to limit volatile organic compound (VOC) emissions from the 

manufacturing of products containing polyester resin materials (defined, for example, by 

SCAQMD as unsaturated polyester resins, such as isophthalic, orthophthalic, halogenated, 

bisphenol A, vinyl ester, or furan resins; cross-linking agents; catalysts; gel coats; inhibitors; 

accelerators; promoters; and any other material containing VOC used in polyester resin 

operations). The strategies used include the use of certain spray gun or application equipment, 

application of resin material with a low monomer content, use of vapor suppressed resins, use 

of add-on control equipment, switching to low VOC or water base cleaners, resin application 

in an enclosed area with a dry filter to control overspray, and covering resin storage 

containers. Some of the regulations allow a combination of emission reduction strategies to 

achieve compliance. 

2.4.2 Summarv of existing regulations.9-'8 The key points of the existing air quality 

regulations affecting the reinforced plastic composites industry are presented in Table 2-12. 

The regulations apply to any facility, existing or new, that manufactures products from 

polyester resin material. However, some of the regulations include exemptions for certain 

compounds, processes, and resin usage. The South Coast regulation exempts a number of 

chlorine containing compounds including chlorofluorocarbons, methyl chloroform, and carbon 

tetrachloride from their regulation, while the Bay Area and the State of Maryland exempt 

processes such as touch-up and repair operations. The amount of resin used by a facility can 

also be the basis for exemption. Ventura County, for example, exempts facilities that use less 

than 20 gallons of polyester resin material per month, while San Diego County exempts 

marine vessel repair operations using less than 0.5 gallon of resin each day and all other repair 

operations using less than 1 gallon per day. The State of Maryland exempts facilities that have 

less than 20 pounds of actual VOC emissions per week. 

The State of Illinois and California's Bay Area, South Coast, San Diego, Santa 

21 

Z3 
TABLE 2-12 

REGULATORY SUMMARY FOR THE REINFORCED PLASTIC COMPOSITES INDUSTRY

 918 

£ 

RULE PROVISION 

Monomer Contenl Limit For 

General Purpose Polyester 

Resin 

Monomer Contenl Limit For 

Corrosion-Resistant Polyester 

Resin 

Monomer Contenl Limit For 

Fire Retardant Polyester Resin 

Monomer Content Limit For 

High Strength Polyester Resin 

Monomer Content Limit For 

Clear Gel Coat 

Monomer Content Limit For 

Pigmented Gel Coat 

Or 

Usage Of Vapor-Suppressed 

Resin With Limited VOC 

Emissions 

Or 

BAY AREA 

REGULATION 8 

RULE 50 

35 % By weight as applied 

50 % By weight as applied 

50 % By weight as applied 

250 Grams of VOC per liter 

of coating applied 

250 Grams of VOC per liter 

of coating applied 

Or 

Weight loss from VOC 

emissions not to exceed 60 

grams per square meter of 

exposed surface area 

Or 

PUGET SOUND 

REGULATION II 

SECTION 3.08 

SOUTH COAST RULE 1162 

& STATE OF ILLINOIS 

SECTION 218.660 

35 % By weight as applied 

48 % By weight as applied 

42 % By weight as applied for 

South Coast, 50 % for Illinois 

48 % By weight as applied 

50 % By weight as applied 

45 % By weight as applied 

Or 

Weight loss from VOC 

emissions not to exceed 60 

grams per square meter of 

exposed surface area 

Or 

SAN DIEGO RULE 67.12, 

VENTURA COUNTY 

RULE 74.14-

35 % By weight as applied 

50 % By weight as applied 

50 % By weight as applied 

50 % By weight as applied, 

only for Ventura County 

50 % By weight as applied 

45 % By weight as applied 

Or 

Weight loss from Vpc 

emissions not to exceed 60' 

grams per square meter of 

exposed surface area 

Or 

STATE Of MARYLAND 

COMAR26.ll.19.XX 

35 % By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

50 % By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

50 % By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

50 % By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

Or 

22 
TABLE 2-12 (Continued) 

i 

RULE PROVISION 

Use Closed Mold System 

Or 

Pultrusion Operations 

Requirements 

And 

Specific Spray Equipment 

And 

BAY AREA 

REGULATION 8 

RULE 50 

Use Closed Mold System 

_ 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP) 

And 

PUGET SOUND 

REGULATION II 

SECTION 3.08 

_ 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP) 

And 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

With less than 4 % weight loss 

of polyester material 

Or 

Covered wet-out baths, enclose 

distance from exit of bath to 

die except for 18 inches of 

preform distance for South 

Coast. 3% maximum weight 

loss of polyester material for 

South Coast and 4% for Illinois 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP): for 

touch-up and repair use of 

hand-held, air-atomized spray 

gun is permitted 

And 

SAN DIEGO RULE 67.12 & 

VENTURA COUNTY 

RULE 74.14 

Use Closed Mold System 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP): for 

touch-up and repair use of 

hand-held, air-atomized spray 

gun is permitted 

And 

STATE Of MARYLAND 

COMAR26.11.19.XX 

And 

Facilities with more than 

100 lbs of actual VOC 

emissions per day must use 

airless spray or air-assisted 

airless spray guns, low 

pressure nozzles, pressure fed 

rollers, flow coaters, or other 

non-atomized application 

technique 

And 

23 

*• 

ho 

0) 
TABLE 2-12 (Continued) 

$ 

RULE PROVISION 

Storage Requirements 

And 

Cleaning Material 

Requirements 

BAY AREA 

REGULATION 8 

RULE 50 

Closed containers for storage, 

self-closing containers for 

disposal of waste material, 

resin, and cleaning materials 

And 

VOC content of cleaning 

material is not to exceed 200 

grams per liter of material; 

use equipment for collecting 

cleaning material and 

minimize evaporation 

PUGET SOUND 

REGULATION II 

SECTION 3.08 

Closed containers for storage 

and disposal of VOC-containing 

materials. 

And 

Any VOC-Containing material 

used for cleanup of spray 

equipment, including resin lines, 

can only be used if equipment 

for collecting VOC-containing 

material is employed and 

evaporation to the atmosphere is 

minimized. 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

• Closed containers 

And 

Solvent cleaning operations 

shall comply with Rule 1171 

for the South Coast Rule. 

Illinois requires solvent 

recovery system when using 

more than 4 gallons of cleaning 

materials per day with more 

than 200 g of VOM per liter 

(1.7 lbs per gallon). Solvent 

recovery on site or by 

commercial service. Waste 

residue from solvent recovery 

system at the source must have 

less than 20% VOM by weight. 

SAN DIEGO RULE 67.12 & 

VENTURA COUNTY 

RULE 74.14 

Self-closing containers for 

storing resin, cleaning 

materials, and waste materials 

for San Diego, Yolo-Solano, 

and San Joaquin. Closed 

containers for storage of all 

VOC containing materials for 

Ventura County and Santa 

Barbara County. 

And 

Use VOC reclamation system 

for cleaning materials, unless 

materials contain less than 200 

grams of VOC per liter (1.7 lbs 

per gallon), or materials have 

initial boiling points greater 

than 190° C, or average usage 

is less than 0.5 gallons per day 

for San Diego, 15 gallons per 

week for Ventura County, and 

4 gallons per day for YoloSolano and San Joaquin. 

Solvent residue from 

reclamation system shall not 

exceed 20 % VOC by weight. 

STATE Of MARYLAND 

COMAR26.11.19.XX 

Use non-VOC clean-up 

materials 

24 

ro 

->i 
TABLE 2-12 (Concluded) 

V 

RULE PROVISION 

In Lieu Of All The Above 

Except Storage And Cleaning 

Material Requirements, Facility 

may use Control Equipment 

And 

Application Area Restrictions 

Resin Usage or Emissions 

Exemptions 

Other Exemptions 

BAY AREA 

REGULATION 8 

RULE 50 

In lieu of all the above except 

storage and cleaning material 

requirements, facility may use 

control equipment, which 

must reduce VOC emissions 

by at least 85 % 

Any touchup and repair 

operations 

PUGET SOUND 

REGULATION II 

SECTION 3.08 

And 

Enclosed Area with dry filter to 

control overspray 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

In lieu of all the above except 

storage and cleaning material 

requirements, facility may use 

control equipment with overall 

capture and control efficiency 

of at least 90 % on a mass 

basis 

J 

SAN DIEGO RULE 67.12 & 

VENTURA COUNTY 

RULE 74.14 

In lieu of all the above except 

storage and cleaning material 

requirements, facility may use 

control equipment with total 

capture of VOCs and control 

efficiency of at least 85 % by 

weight in Ventura County. 

_ 

Less than 20 gallons per month 

of resin usage for San Joaquin 

and Ventura County. Less than 

50 gallons of resin usage per 

year for Santa Barbara. Less 

dian 1 gallon per day for repair 

work except for marine vessels 

for San Diego. No exemption 

for Yolo-Salano 

Any touchup and repair 

operations for Yolo-Solano 

STATE Of MARYLAND 

COMAR26.U.19.XX 

Facilities with less than 20 lbs 

of actual VOC emissions per 

week 

Any tooling or touch-up and 

repair operations 

Includes summaiy of Santa Barbara County Rule 349, Yolo-Solano Rule 2.30, and San Joaquin Valley Rule 4684. 

25 
P.29 

Barbara, Yolo-Solano, San Joaquin Valley, and Ventura County Control Districts have very 

similar rule provisions. They all have limits for the monomer content of general purpose resin, 

specialty resin, and clear and pigmented gel coat. The South Coast and Ventura County 

regulations have a separate monomer content limit for high strength polyester resins. As an 

alternative to complying with a monomer content limit, a facility can choosq to use either 

vapor-suppressed resins with limited VOC emissions, closed mold systems, or control 

equipment to achieve certain emission reductions. In addition to the material and process 

requirements stated above, all eight above mentioned regulations require the use of specific 

spray equipment for spraying operations, and also specify storage and cleaning material 

requirements. 

PSAPCA's Regulation II Section 3.08 covers some of the same provisions as the eight 

regulations discussed above, such as the usage of specific spray equipment, storage 

requirements, and cleaning material requirements. However, PSAPCA does not address 

monomer content, usage of vapor-suppressed resin or gel coat, closed mold systems, or add-on 

control equipment. Instead, Puget Sound's regulation requires all spray operations to be 

conducted inside an enclosed area that has a dry filter to control overspray. The exhaust from 

the operation must be vented to the atmosphere through a vertical stack. 

The State of Maryland only addresses the resin monomer content, the type of spray 

equipment, and the use of VOC cleamng materials. 

26 
P.30 

2.5 REFERENCES 

1. SPI Composites Institute, Introduction to Composites Reference 

Handbook. 1992. 

2. 1992 Toxic Release Inventory System. 

3. Responses from section 114 screening survey sent to the reinforced plastic 

composites industry. 1993. 

4. Standard Industrial Classification Manual, National Technical 

Information Service. 1987. 

5. Standard Industrial Classification Manual, National Technical 

Infonnation Service. 1972. 

6. Memorandum from LaFlam, G. and Proctor, M., Pacific Environmental 

Services, to Strum, M., EPA/ESD/CCPG. Process Descriptions and Emission 

Points. September 1995. 

7. The Society of the Plastics Industry, Inc., Facts & Figures of the U.S. Plastics 

Industry. September 1994. 

8. C. Randazzo, "This is another year of good news". Reinforced Plastics 

newsletter. Volume XIX, Number 19. September 18, 1995. 

9. Puget Sound Air Pollution Control Agency. Regulation n, Section 3.08 

Polyester, Vinylester, Geicoat, And Resin Operations. September 12, 1993. 

10. Bay Area Air Quality Management District. Regulation 8 Organic 

Compounds, Rule 50 Polyester Resin Operations. December 5, 1990. 

11. South Coast Air Quality Management District. Rule 1162 Polyester Resin 

Operations. May 13, 1994. 

12. San Diego Air Pollution Control District. Regulation IV, Rule 67.12 Polyester 

Resin Operations. April 6, 1993. 

13. Ventura County Air Pollution Control District. Rule 74.14 Polyester Resin 

Material Operations. May 26, 1992. 

27 
P.31 

14. Maryland State Air Laws, COMAR 26.11.19.XX Control Of VOC 

Emissions From Reinforced Plastic Manufacturing. Draft. July 13, 

1995. 

15. Illinois Organic Material Emission Standards, Title 35 Subtitle B, Part 

218 Organic Material Emission Standards and Limitations forvthe 

Chicago Area. March 3, 1994. 

16. San Joaquin Valley Unified Air Pollution Control District. Rule 4684 Polyester 

Resin Operations. May 19, 1994. 

17. Yolo-Solano Air Pollution Control District. Regulation n, Rule 2.30 

Polyester Resin Operations. August 25, 1993. 

18. Santa Barbara County Air Pollution Control District. Rule 349 

Polyester Resin Operations. April 27, 1993. 

28 

3®