OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

14) 11-1-14 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:21 PM Sheet 14 of 114 

P.1 
P.2 

I . 

^_.Q44>£> 

POLICY STATEMENT ON REDUCING AIR EMISSIONS 

FROM OPEN MOLDING COMPOSITES FABRICATION 

1. The 1990 Amendments to the Clean Air Act (CAA) mandate substantial reductions in the emissions of 

VOCs and hazardous air pollutants, while minimizing the economic and energy costs of such reductions. 

The Composites Fabricators Association and its open molding processing members acknowledge their 

obligation to achieve significant reductions and intend to cooperate with Federal and State agencies to 

accomplish this objective. 

2. To meet this obligation, the open molding, composites industry is prepared to embrace substantial 

change from current practices. The promotion and implementation of souree reduction technologies is 

the most feasible course of action. These changes may involve materials, process and equipment and 

important modifications in work practices. These changes are more desirable from both an environmental 

and an economic perspective than add-on emissions controls, such as thermal oxidation or carbon 

adsorption. 

3. The use of source reduction, which minimizes the release of styrene and other VOC emissions, will 

result in a net savings for fabricators in many cases. In contrast to the release of paint solvents, which is 

an inherent part of the painting process, composites fabricators seek to capture styrene monomer in the 

molded product. The EPA has itself recognized the environmental superiority of achieving clean air through 

source reduction, rather than add-on emissions treatment devices. 

4. A workable open molding emissions reduction strategy will include modifications of raw materials, 

process technologies, application techniques, and work practices, using methods and equipment that are 

currently available and proven in advanced facilities in this segment of the industry. 

5. Emissions of volatile solvents such as acetone and methylene chloride should be reduced to the lowest 

possible levels, as most advanced fabricators have already done. Although not all volatile organic solvents 

are listed as CAA hazardous air pollutants, reduction in use is sensible conservation and will reduce 

overall VOC emissions as well as worker and public exposure to these materials. 

6. The attached chart sets out a broad range of viable changes in raw materials, process technologies and 

work practices that can serve as the basis of an effective emissions source reduction control strategy foe 

the open molding industry. Many of these changes parallel the requirements of Califomia Rule 50,**wnich 

with its current exemptions is a feasible and viable emissions source reauction control regulation. 

Additional technologies, not included in the California regulation, are identified in these control plfin 

options. 

7. Add-on emissions treatment devices are not currently feasible for the compostt€{s inuustry, for a number 

of reasons: 

a. Collection and concentration of air contaminates is a major engineering problem in 

open molding composites production facilities. Because of OSHA limitations on worker 

exposure to styrene, high air flows are necessary to dilute irreducible styrene emissions. 

b. Thermal oxidation is highly undesirable because it is: 

i. highly inefficient when applied to air containing styrene concentrations 

at or near the OSHA PEL standards; .; . ; jj \;j T 
P.3 

ii. beyond the capital expenditure capability of a vast majority of open 

molding composites fabricators. 

Di. highly energy intensive and in the long run contrary to U.S. energy 

conservation and related environmental policies; 

iv. a source of NOx and CO2 emissions that will interfere with the 

attainment of EPA's air quality objectives. 

c. Local opposition to "hazardous waste incineration" could entail years of delay in 

installing thermal oxidation equipment as a result of legal proceedings or required plant 

relocations before implementation. 

d. Carbon adsorption technology has not been fully proven to treat open molding 

fabrication emissions, which often includes peroxide catalyst. The treatment of spent 

carbon requires either thermal incineration or solid waste landfilling. These treatment 

methods run contrary to the goal of pollution reduction. 

8. Open molding composites fabricators, their representative trade associations, raw materials suppliers 

and process equipment suppliers will continue to pursue additional reductions in styrene and other VOC 

emissions by: 

a. Encouragingresearch on low cost, effective waste stream treatment methods, such as 

tong wave IR oxiaauon and ozone injection technology. 

b. Actively conducting industry training programs promoting with source reduction 

methodologies. 

c. Encouraging development of low emission resins and resin systems, in addition to 

alternative monomer or advanced polymer research by resin manufacturers. 

d. Encouraging all open molding composites fabricators to make full use of current!/ 

available low styrene and styrene suppressed resin technology in order to promote a 

market driven demand for improved source reduction technologies. 

Composites Fabricators Association 

September 1993 
OPEN MOLDING SOURCE REDUCTION CONTROL TECHNOLOGY 

Hand lay-up / Spray-up / Gel Coat Processing Composites Fabricators Assn 

Polyester/Vlnylester Styrenated Resin Application ecFA.AuguM.ien 

PROCESS STEP POTENTIAL EMISSION 

POINT 

MATERIALS CONTROL 

TECHNOLOGY 

PROCESS CONTROL 

TECHNOLOGY 

WORK PRACTICE 

CONTROL TECHNOLOGY 

MATERIAL HANDLING 

Storage* 

Containers 

Transferring (pouring) 

material 

Mixing operations 

Additive blending operations 

FLUI D HANDLIN G 

EQUIPMENT 

Inaerbng pump auction tube 

in drum 

Pump lines and fittings 

Cleaning fatsre and screens 

Purging rsein lines 

Relieving high pressure 

Ones 

Open top containers or poorly 

sealed lids 

Duration between opening 

and use. Residual resin on 

drum top. Drips on drum. 

Open top containers, 

and drips. 

Open top containers. Spills 

and drips. 

Open top containers. Spills 

and drips. 

Open top container. Spate 

and drips. 

Leaks 

Spills end drip* 

SpHIs. drips and overspray 

Spf Is. drips and overspray 

£;&*} 

Use pumps or pour spouts 

121 

Use mixers with closed tops 

(21 

Use mixers with dosed tope 

121 

Use closed top with suction 

tube access. [1] 

Keep process as continuous 

as possible to avoid purging. 

Use purpose made container 

to avoid overspray. (3) 

Use by-pass hose beck Into 

resin container. (1 j 

Keep well sealed lids on 

containers while in storage 

IU 

Open drums immediately 

before use. Avoid spills. 

Clean up immediately. [1] 

Avoid spills [1] 

Avoid open tops and spills [11 

Avoid open tope and spills [1] 

Avoid open tops and spills. 

(11 

Mftlntafn fitUngs snd pump 

packings to avoid leaks. [1] 

Avoid leaks, spBIs and drips 

outside approved containers 

(U 

Purge gun and linee Into an 

approved container. Avoid 

•pits and drips [1] 

Re-circulate back to resin 

container. (11 
PROCESS STEP 

GEL COAT APPUCATION 

Spray application 

Fan pattern overspray 

Curing process 

Postcuring process 

HAND LAY-UP • BATCH MIX 

APPUCATION 

Containsr bansfer operation 

Resin mbdng operation 

Wet resin application 

Laminating operations 

POTENTIAL EMISSION 

POINT 

Atomizing gel coat into spray 

pattern. 

Spraying off mold edges. 

Spraying from long distances. 

High air velocity transporting 

atomized gel coal 

Surface area evaporation. 

Residual styrene evaporation. 

Open top containers. Spills 

and drips. 

Open top 

and drips. 

Spills 

Wetted surface area exposed 

to atmosphere. 

Wetted surfoce 

to atmosphere. 

area exposed 

MATERIALS CONTROL 

TECHNOLOGY 

Use low viscosity gel cost (3] 

Use low viscosity gel coat (3] 

Use fast gel time gel coat (2] 

Use low gel time gel coat [2] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. |3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filed 

system wtwra spptic&bls. [3] 

PROCESS CONTROL 

TECHNOLOGY 

Use low pressure or air 

containment spray equip • 

ID 

Use fan pattem with com» 

patable with part size and 

shape. Avoid high velocity air 

flow in spray area, [1] 

Maintain adequate minimum 

shop and mold temperatures 

to expedite curing. Maintain 

catalyst levels to expedite 

curing. [2] 

Contain post cure area. Use 

IR heating devices. (3] 

Use transfer pumps or pour 

spouts. Use pressure fed 

roller applicators to eliminate 

this operation. [3] 

Mix and replace Hd untt use. 

Use pressure fed roller 

applicators to eliminate this 

operation. [3] 

Use closed molding method. 

Design laminate to reduce 

resin usage. (4] 

Keep air flow wHhln ventilation 

limits. (2] Keep ambient 

temperaturee within Hmits. [3] 

Use doeed molding method. 

(4] 

WORK PRACTICE 

CONTROL TECHNOLOGY 

Operate spray equipment at 

lowest poaswls pressure. 

Spray as does to mold as 

practical. (1] 

Contain spray pattern wHhln 

mold perimeter. Spray as 

doss to mold as practical. 

Operate spray equipment at 

lowest possible preeeure. 1*11 

Calibrate spray equipment on 

a regular basis. Apply 

recommended gel coat ml 

thickness. (1] 

Monitor post curs 

ternperature and dwell time. 

Ul 

Avoid open top containers 

and spills. [1] 

Avoid open top containers 

and spills. [1] 

TJ 
PROCESS STEP 

Reein in mix containers 

laminate curing 

Edge Trimming operation 

Post curing process 

HAND LAV-UP - RESIN 

SPRAY APPUCATION 

Spray application 

Fan pattem overspray 

Laminating operationa 

Laminate curing 

POTENTIAL EMISSION 

POINT 

Residual resin in containers. 

Surface area exposed to 

atmosphere. 

Surface area evaporation. 

Semi-cured trim-off exposed 

to atmosphere. 

Residual styrene evaporation. 

Atomizing resin into spray 

pattern. 

Spraying off mold edges. 

Spraying from long distance. 

High air velocity transporting 

atomized resin. 

Wetted surface area exposed 

to atmosphere. 

Surface area evaporation. 

MATERIALS CONTROL 

TECHNOLOGY 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Uss filled 

system where applicable (3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. |3] use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. (3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. [3] 

Uae low styrene or styrene 

suppressed resin where 

applicable. [3] Uss filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. (3] Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. (3] 

PROCESS CONTROL 

TECHNOLOGY 

Use measured batch mixes. 

(21 

Maintain adequate minimum 

shop and mold temperatures. 

Maintain catalyst levels to 

expedite curing. [2] Use 

minimum velocity air flow 

i laminate (3] 

Place trim-off in dosed 

container or submsrgs in 

water bath. [2] 

Contain post cure area if 

possibls. Uss IR heating 

devices. [3] 

Eliminate spraying with 

pressur s fed rolle r 

applicators. [2] Uae low 

pressure or air containment 

spray equipment (1] 

Eliminate spraying with 

pressur e fed rolle r 

applicators. (2] Use low 

pressure or air containment 

spray equipment (1] Avoid 

high velocity air flow in apray 

area. (11 

Keep air flow within ventilation 

limits. [2J Keep ambient 

temperatures within linuts (3] 

Use deeed molding metiiod. 

W 

Maintain adequate minimum 

shop and mold temperatures. 

Maintain catalyst levels to 

expedite curing. [2] Use 

minimum velocity air flow 

PI 

WORK PRACTICE 

CONTROL TECHNOLOGY 

Avoid open tops. Use all resin 

(21 

. + 

Work with areas that allow 

fastest reasonable gel 

(2] 

Place trim-off in container 

immediately after removal 

from part (1) 

Monito r pos t cur s 

temperature and dwell time. 

(11 

Operate spray equipment at 

lowest possibls pressure. (1 ] 

Contain fan pattem 

mdd perimeter. Spray as 

doss to mold as practical. 

Operate spray equipment at 

lowest possible pressure. (1] 

TJ 
PROCESS STEP 

EOQ# trimminQ operation 

SPRAY-UP APPUCATION 

Spray application 

Fan pattern overspray 

Laminating operations 

Laminate curing 

Edgs trimming operation 

Poet curing process 

POTENTIAL EMISSION 

POINT 

Osffli cuisd trim-off sxpoeed 

to strnoephere. 

Residual styrene evaporation. 

Atomizing 

pattem. 

reein into apray 

Spraying off mdd sdges. 

Spraying from long distance. 

High air velocity transporting 

Wetted surface area exposed 

to atmosphere. 

Surface area evaporation. 

Semi cured trim-off exposed 

to atmosphere. 

Residual styrene evaporation. 

MATERIALS CONTROL 

TECHNOLOGY 

Uee low styrene or styrene 

suppressed resin where 

applicable. (3] Uae filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. (3) Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. [3] 

Uss low styrene or styrene 

suppressed resin where 

applicable. (3] Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. (3] Use filled 

system where applicable. [3] 

Use low styrene or styrene 

suppressed resin where 

applicable. [3] Use filled 

system where applicable. [3] 

Uee low gd time resin. (1] 

PROCESS CONTROL 

TECHNOLOGY 

Place trim-off in doeed 

container or submsrgs in 

water bath. [2] 

Contain post cure area if 

possible. Uss IR heating 

devices. [3] 

Use low pressure or air 

containmsnt spray equipment 

[11 

Use low pressure or air 

containmen t spra y 

equipment (1] Avoid high 

velocity air flow in apray area. 

IU 

Keep air flow within ventilation 

limits. [2] Keep ambient 

temperatures within limits (3] 

Uss doeed molding method 

w 

Maintain adequate minimum 

shop and mdd tempsraturss. 

Maintain catalyst levels to 

expedite curing. [2] Uss 

minimum velocity air flow 

across laminate. [3] 

Place trim-off in dosed 

container or submsrgs in 

water bath. [21 

Contain post cure area If 

possible. Uss IR 

devices. [3J 

WORK PRACTICE 

CONTROL TECHNOLOGY 

Ptaos trim-off In conteinsr 

immediately After ramovsl 

from part [1] 

Monitor post temperature snd 

dwell. (1] 

Operate apray equipment at 

lowest possibls pressure. (1] 

Contain tan pattem within 

mold perimeter. Spray aa 

dose to mdd as practical. 

Operate spray equipment at 

lowest possible pressure. (1] 

Placs trim-off 

Immediately 

from part. (1) 

after removal 

Monito r pos t cur s 

temperature and dwell. (1| 

TJ