p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

85) ll-E-45 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:06 AM Sheet 85 of 264 
P.2 

A- ' 

0 0_3 (j £_E_7C 

A-94-52 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: 

SUBJECT: 

LOCATION: 

August 14, 1996 

P:\N404 

Summary of July 2, 1996 Meeting Between EPA and the Composites 

Fabricators Association (CFA) 

EPA/Mutual Building, Durham, 

10:00 am - 2:00 pm 

ATTENDEES: Mr. Mark Banner 

Mr. Larry Craigie 

Ms. Linda Herring 

Mr. Norm Kaplan 

Mr. Emery Kong 

Mr. Robert Lacovara 

Mr. Greg LaFlam 

Mr. Stephen McNally 

Mr. Kenneth Meardon 

Mr. Carlos Nunez 

Mr. Brian Palmer 

Ms. Nancy Pate 

Ms. Melanie Proctor 

Mr. Geddes Ramsey 

Mr. Ron Ryan 

Ms. Madeleine Strum 

Mr. Chad White 

NC, 11th floor conference room, 

RTI 

Dow Plastics 

EPA/ESD 

EPA/ORD 

RTI 

CFA 

PES 

CFA 

PES 

EPA/ORD 

ERG, Inc. 

EPA/OAQPS 

PES 

EPA/ORD 

EPA/ESD 

EPA/ESD 

ERG, Inc. 

(919) 541-6016 

(409) 238-4495 

(919) 541-5358 

(919) 541-2556 

(919) 541-5964 

(215) 721-9246 

(919) 941-0333 

(703) 610-9025 

(919) 941-0333 

(919) 541-1156 

(919) 461-1218 

(919) 541-5347 

(919) 941-0333 

(919) 541-7963 

(919) 541-4330 

(919) 541-2383 

(919) 461-1211 

PURPOSE 

The meeting was held to discuss the CFA's draft report presenting data on its 

emissions testing program for resin and gel coat spraying operations. The EPA also 

presented and discussed some options for MACT floors for the open molding subcategory. 
P.3 

Madeleine Strum 

August 14, 1996 

Page 2 

DISCUSSION 

CFA Test Data and Available Control Approaches 

After introductions were made, Mr. Lacovara began a discussion of CFA's draft 

project report, "Open Molding Styrene Emissions Test Project Baseline Study - Phase I, 

June 1996. He stressed that the report is preliminary, and many of the details still need to 

be added and corrections made. He also was reluctant initially to allow meeting participants 

to retain possession of copies of the report, since the key CFA member companies had not 

yet had a chance to obtain and review the draft. However, after receiving assurances that 

the information would not be released until the key CFA member companies received and 

reviewed their copies, Mr. Lacovara agreed to allow the copies distributed at the meeting to 

be kept for review. 

The official release date for the Phase I report is set at no later than July 17, 1996. 

Phase U of the study is currently underway and is expected to be completed by the end of 

September. The second phase will investigate the effects of vapor suppressants, filled 

systems (unfilled, low filler, and high filler contents), and different application systems 

(e.g., flow coaters and pressure-fed resin rollers). Phase U will also examine the effect of 

mold shape parameters on resin overspray (including both male and female molds), and will 

study emissions from the manufacture of a larger part (12 ft. x 5 ft. x 2.5 ft. van top). 

Mr. Nunez asked about the relationship between Phase JJ and the quality assurance 

(QA) plan. Mr. Craigie responded that Phase JJ uses smaller tests (fewer test runs because 

fewer variables are being investigated), but has the same calibration checks and procedures 

as Phase I. In addition, the Phase I EPA-approved QA plan is also being used for the Phase 

JJ testing. Mr. Nunez then asked whether the test plan was available, and Mr. Craigie said 

they could provide it. 

Mr. Craigie also noted that some Phase I test results are expected to be extended into 

Phase JJ (i.e., assume the validity of certain Phase I results without doing additional 

testing). He said that Phase I results were being extended into Phase JJ because the results 

obtained on different days (blocks) were not found to be different and this allows the earlier 

data to be used. Mr. Lacovara pointed out a couple of data points where this trend was 

evident. Mr. Kong pointed out that, in the ORD/RTI test program, test run replicates made 

on the same day tended to show less difference than runs separated in time, possibly because 

measurement error tends to be smaller for runs done sequentially. Another possible reason 

includes an inability to control all the variables in the experiment over an extended time. 

Mr. Lacovara said that their data did not exhibit any noticeable "blocking" effect. Mr. 

Nunez expressed a minor concern over whether variables were changed and the possible 

effects on the results, but did not have a problem if they did not change the fundamentals of 

2-
P.4 

Madeleine Strum 

August 14, 1996 

Page 3 

the testing. Mr. Craigie replied that they are relying heavily on their statistician, who is 

scrutinizing the data closely. 

Messrs. Craigie and Lacovara discussed various sets of units in which the emission 

test results are being presented: two of these units are percentage of available styrene (input 

to the process), or % AS, and pounds of emissions per pound of resin used (lb/lb resin). 

Mr. Craigie said that these latter units are preferred when comparing two similar situations. 

He also pointed out that the same amount (weight or volume) of resin is used when making 

a part with either a 35 percent or a 50 percent styrene resin (assuming a similar density for 

each resin). When calculating emissions as styrene per unit weight of resin used, therefore, 

the effect of the resin's styrene content is more important; that is, expressing emissions as 

weight resin is more indicative of what is happening. Another set of units described by Mr. 

Lacovara, which is used in the report to express the results, is grams per square foot (of 

mold surface) per kg of resin used (g/ft2/kg resin used). All of the statistical analysis in the 

study is based on the % AS results. 

The CFA presented a graph of styrene emission concentrations versus time for hand 

layup and a similar graph for sprayup. For hand layup, the styrene concentration rose from 

0 ppm to about 68 ppm during application over a 14-minute time period, fell from 68 ppm 

to about 20 ppm during rollout over a 13-minute period, and continued to decrease from 20 

ppm to less than 5 ppm during curing over a 2-hour period. Styrene emissions were 

approximately 52 percent from application, 23 percent from rollout, and 25 percent from 

curing. 

For sprayup, the styrene concentration rose from zero to about 500 ppm during 

application over a 5-minute period, fell from 500 ppm to about 50 ppm during rollout over a 

10-minute period, and continued to decrease from 50 ppm to less than 5 ppm during curing 

over a 1.5-hour period. 

Mr. Lacovara said that the CFA testing generally corifirmed the ORD/RTI test result 

that emissions are distributed approximately 50 percent during resin application and 50 

percent during rollout and curing (for either hand or spray layup). Also, CFA found that 

post-application emissions are about equally divided between the rollout and curing phases. 

He agreed that the level of emissions from application is a function of the amount sprayed, 

while the level of emissions from rollout and curing are a function of surface area. 

Test runs were carried out for two laminate thicknesses (0.041 and 0.088 inch) and 

two gel coat film thicknesses (0.018 and 0.024 inch). Emissions from production of the 

thicker laminate tended to be lower, indicating that buildup of a thick laminate in a single 

spraying process may be preferable to applying multiple thin layers. Mr. McNally emphasized that, while this may present an opportunity for control, laminate thickness itself should 
P.5 

Madeleine Strum 

August 14, 1996 

Page 4 

not be the basis for a control requirement. However, as a work practice, requiring the 

application of as thick a layer as practicable (in place of multiple thinner layers) may 

deserve consideration. 

Mr. Lacovara felt that applying the resin at a faster rate may achieve a small net 

reduction in emissions by reducing spray time, although the peak styrene concentration is 

higher. He noted that this is an expected effect for shorter spray times (e.g., 30 seconds up 

to 2 minutes) which are typical in much of the industry, but could not say what the results 

might be for longer (5-minute) spray times. 

The study also indicated that, for high (42 percent) styrene resin, uiere was a 30 

percent emission reduction resulting from increasing the resin delivery rate (or decreasing 

the spray time). The study also showed no reduction of styrene emissions when using a 35 

percent styrene resin. Mr. Lacovara believed that a requirement for an increased delivery 

rate (at the spray gun tip) achieved through an optimized orifice would achieve source 

emission reduction benefits, and it would represent a "win-win" situation. He did not 

believe that increased delivery rate achieved through higher pressures would yield any 

emission reduction benefits. 

Emissions also appear to be less for resins and gel coats with shorter gel times. 

Therefore, another control approach may be to optimize the gel time, keeping in mind that 

different processes and products may have different time requirements (i.e., the time needed 

to apply and roll out the resin will vary with applicator, size of part, amount of labor 

available, etc.). Mr. Craigie pointed out that gel time is selected to correspond to the part 

being made. Mr. Lacovara then noted that gel time can be tailored to anything you want 

and that there is a "shortest" applicable gel time for every part. As an example, the 

allowable gel time might be set at 1.2 times the lamination (layup) time. 

Mr. Lacovara also stated that the amount of resin or gel coat overspray was found to 

be critical to the emission level. As a result, changes in work practices (such as a "controlled" spraying technique) could make a substantial difference in emissions. He said he 

would provide a copy of a study of gel coat transfer efficiency that was performed about 10 

years ago. Ms. Strum also asked for the video tape showing the techniques used in this part 

of the study, and Mr. Lacovara said he would provide these tapes. 

Mr. Lacovara discussed an approach to optimizing the operation of the resin or gel 

coat spray gun, which he felt would lead to a reduction in emissions. The tip pressure for a 

specific gel coat or resin and tip size would be "optimized" by gradually turning up the line 

pressure until an adequate fan pattern was achieved (i.e., no inconsistencies in fan shape). 

The standard for spraying operations might include a styrene content limit, the spray gun 

V 
P.6 

Madeleine Strum 

August 14, 1996 

Page 5 

optimization approach, or some combination that allows reduction credit for performing the 

optimization. A training program for the optimization could be made part of the rule. 

Mr. Craigie summarized the parameters that appear to affect HAP emissions from 

open molding processes, and that may be controlled through source reduction measures. 

These are: 

Overspray Styrene content Spray pattern 

Gel time Vapor suppressant Spray technique 

EPA's Control Options 

After a lunch break, Ms. Proctor reviewed EPA's preliminary control options for the 

open molding subcategory (see Attachment). These options are based directly on the 

MACT floor control levels determined from the facility data base. The HAP contents in 

these options are "as-supplied" (i.e., before filler is added). The industry representatives 

felt that the monomer content levels reflected in the options appeared to be reasonable, but 

said that they would need to think further and discuss the values with other experts. Mr. 

McNally thought that the 35 percent limit may not be a problem. However, Mr. Lacovara 

believed that any limit below 35 percent could present a problem to many fabricators. He 

mentioned that, in stormwater permitting, facilities are mandated not to pollute through that 

pathway, but are allowed to develop their own plan for preventing pollution. He asked 

whether a similar approach could work for this NESHAP rule. 

Mr. McNally discussed the difference between the certification sheet and the 

specification sheet for resins. The (production) specification indicates a guaranteed range 

for the styrene content of a batch (e.g., a "45 percent styrene" resin may be shown as 43-47 

percent). A certification (of analysis) represents a more precise and costly analysis of the 

exact styrene content of a batch. He felt that the specification sheet should be used in the 

NESHAP to verify the monomer content of resins and gel coats. Ms. Strum said she would 

provide EPA's data supporting the floor options to Mr. McNally so that he could identify 

member companies and verify the information attributed to each of their facilities. Mr. 

McNally said he would review the feasibility of the monomer content limits in EPA's 

preliminary control options. He said he would also provide suggestions of best management 

practices that may have application in the rule. 

•s 
P.7 

Madeleine Strum 

August 14, 1996 

Page 6 

Action Items 

Action items agreed to at the meeting consisted of the following: 

Early. 

1. U.S. EPA (M. Strum) 

Action Agreed to 

Provide data supporting the currently studied 

MACT floor options to S. McNally 

2. CFA (R. Lacovara) Provide gel coat transfer efficiency study to M. Strum 

Provide test videos to M. Strum 

3. CFA (S. McNally) 

4. Dow (L. Craigie) 

Review EPA's facility list to identify member 

companies and verify accuracy of information for those 

members 

Review feasibility of EPA's suggested resin content 

limits and give comments to M. Strum 

Provide recommended best management practices to M. 

Strum 

Provide Phase JJ test plan to C. Nunez 

Memo - July 16, 1996 

Attachment 

6 
P.8 

Memo - August 14, 1996 

Attachment 

DRAFT 07/01/96 

OF MACT FLOORS FOR 

NON CORROSION RESISTANT OPEN MOLDING 

Option 1: Subcategorization without Size Differentiation 

CATEGORY 

Spray Application 

Unfilled 

Filled 

Hand Application 

Filled and Unfilled 

EXISTING SOURCES 

38.2% with vapor suppressant or 

33.7% without vapor suppressant 

35% with vapor suppressant or 

34% without vapor suppressant 

40 % with vapor suppressant or 

32% without vapor suppressant 

NEW SOURCES 

35% with vapor suppressant or 

33% without vapor suppressant 

Add-on Control (95% reduction) 

38% with vapor suppressant or 

26% without vapor suppressant 

Option 2: Subcategorization with Size cutoff at 2000 tpy of Resin Usage 

CATEGORY EXISTING SOURCES NEW SOURCES 

Spray Application 

Unfilled, <2000 tpy 

Resin Usage 

Filled, <2000 tpy 

Resin Usage 

Filled, > 2000 tpy 

Resin Usage 

Unfilled, > 2000 tpy 

Resin Usage 

38.2% with vapor suppressant or 

33.7% without vapor suppressant 

35% with vapor suppressant or 

34% without vapor suppressant 

Add-on (24% min. control 

efficiency) and vapor suppressant or 

Add-on with min. control efficiency 

of 34% or 

43% with vapor suppressant 

no facilities in database 

35% with vapor suppressant or 

33% without vapor suppressant 

Add-on control (95% reduction) 

Add-on control (95% reduction) 

no facilities in database 

Hand Application 

Filled and Unfilled 40 % with vapor suppressant 

32% without vapor suppressant 

26 % without vapor suppressant or 

38 % with vapor suppressant 

1