p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

61) ll-E-21 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 61 of 264 
P.2 

x-B-i\ 

MEMORANDUM 

TO: Plastic Composites NESHAP Pre-MACT Team and/or Work 

Group Members 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: June 28, 1995 

L:\N308 

SUBJECT: Summary of Vendor Teleconference 

Enclosed with this memorandum is a summary of the pre-MACT 

teleconference held on May 24, 1995. Two attachments are 

included. One is the technical "fact sheet" material from 

Grace Tec Systems, which we were not able to include in the 

package sent out before the meeting. The other summarizes 

written comments received on various aspects of the pre-MACT 

development from the February 7, 1995 meeting. Any additional 

comments regarding the pre-MACT process would be welcome at any 

time. 

A third meeting is planned for the* end of July to discuss 

the data base for some of the fabrication processes and to 

explore approaches for determining MACT control levels. You 

will be notified of the date and provided with any additional 

information needed for the meeting as soon as it becomes available. 

Attachments 

- a vr 

W*. * f 

V'! 
P.3 

MEMORANDUM 

TO: Madeleine Strum 

U.S. Environmental Protection Agency 

FROM: Kenneth R. Meardon and Greg LaFlam 

Pacific Environmental Services, Inc. 

DATE: June 28, 1995 

SUBJECT: Vendor Pre-MACT Teleconference on May 24, 1995 

I. Purpose 

The purpose of this meeting was to bring together five vendors of control equipment to receive information on their control systems and to discuss how these systems may 

be applicable to the reinforced plastic composites industry. 

II. Location of Teleconference and Participants 

Place: 

Date: 

U.S. Environmental Protection Agency 

N.C. Mutual Building, Room 638 

Durham, North Carolina 

May 24, 1995 

Participants: 

Bijan Etaian, South Coast Air Quality Management District (SCAQMD) 

Mohan Balagopalan, SCAQMD (909) 396-2704 

Nancy Pate (for Jane Caldwell EPA/AQSSD)* (919) 541-0328 

Lisa Conner, OAQPS/AQSSD (919) 541-5060 

Bob Fegley, EPA/ORD* (202) 260-0484 

Christine McPhee, Ohio EPA* (216) 963-1205 

Norm Kaplan, EPA/ORD* (919) 541-2556 

Steve McNally, Composite Fabricators Association* (703) 524-3332 

Arnold Medbery, EPA/OSDBU* (703) 305-5171 

Richard Nielson, Clark County, Nevada* (702) 383-1276 

Carlos Nunez, EPA/ORD* (919) 541-1156 

John Schweitzer, Composites Institute (313) 668-4703 

Jordan Spooner, OPPT/PPD* (202) 260-4418 

Paul Blystone, Purus, Inc. (408) 955-1029 

Magnus Danielsson, Weatherly Inc. (404) 873-5030 
P.4 

Dr. Madeleine Strum 

June 28, 1995 

Page 2 

Anders Munters, AMT, Inc. (813) 540-0006 

Lori Coenen, Grace Tec Systems (414) 339-2789 

Ronald Sundberg, SETCO Inc. (612) 824-1093 

Dan Boyd, industry consultant (410) 827-6244 

John Glunn, Florida DEP (904) 488-0114 

Beth Harden, Florida DEP 

Cleave Holiday, Florida DEP 

Geddes Ramsey, EPA/ORD (919) 541-7963 

Madeleine Strum, EPA/ESD* (919) 541-2383 

Wanita Dunston, EPA intern (919) 541-2306 

Mark Banner, RTI (919) 541-6016 

Emory Kong, RTI (919) 541-5964 

Greg LaFlam, PES (919) 941-0333 

Ken Meardon, PES (919) 941-0333 

Indicates a pre-MACT team and/or EPA Work Group member. 

III. Discussion 

Ms. Strum asked John Schweitzer, Composites Institute, and Steve McNally, 

Composite Fabricators Association, to review the segments of the industry that their 

respective associations represent. Mr. Schweitzer stated that their members are associated 

witii compression molding, pultrusion, and fabrication of corrosion-resisting resin equipment. Mr. McNally stated that their members are associated with filament winding, open 

molding, hand layup, and corrosion work. He also offered to arrange plant tours at subject 

facilities for any member of the pre-MACT team to see how the regulation might affect 

actual processes. Norm Kaplan expressed interest, and Mr. McNally said that he will 

contact Mr. Kaplan for a plant visit somewhere in central North Carolina. 

Mr. Schweitzer/Mr. McNally noted that the Clean Air Management Partnership, 

comprised of four trade associations, was formed about 4 or 5 years ago in response to the 

1990 Clean Air Act Amendments to help the EPA in the development of the MACT 

standards affecting reinforced plastic composites manufacturing. Mr. Schweitzer estimated 

that the Composites Institute and the CFA include probably at least 15 percent of all 

fabricators as members, and provide a good representation of the entire industry. 
P.5 

Dr. Madeleine Strum 

June 28, 1995 

Page 3 

MAGNUS DANIELSSON. WEATHERLY INC. 

Mr. Danielsson stated that their company's technology was developed in Sweden in 

the late 1970's/early 1980's. They use a unique adsorbent, Bonopore, developed and 

patented by our Swedish subsidiary, Chematur Engineering and Nobel Chemicals. The 

process can be used either as a pre-concentrator or for solvent recovery. The equipment is 

composed of four to six fluidized beds, and is able to utilize 100 percent of the adsorbent's capacity (rather than partial capacity). The adsorbent is fed to a desorber where the 

captured VOCs are released. In the pre-concentration mode, the temperature used to 

desorb is approximately 300°F and the reduced air volume goes to a catalytic oxidizer for 

destruction of the VOCs. When the equipment is used for solvent recovery, a moving bed 

desorber is used. We developed the solvent recovery unit first and then die pre-concentrator. 

Mr. Danielsson noted that they currently have installations in Europe running of 

styrene emissions ~ one pre-concentrator and four solvent recovery. The first was 

installed in 1989 and is still operating, with no changeout of the adsorbent to date. 

The operating costs of the systems essentially include only the electricity required to 

pull the waste gas stream through the adsorber. For 20,000 cfm, this cost is less than 

$60,000 per year, assuming 24 hours per day, 365 days per year of operation. 

Questions and Answers 

Carlos Nunez: How much attrition is there per year for the fluidized bed? 

Magnus: Approximately 5 % per year. This is a small cost and is included in the estimate 

of operating costs above (i.e., $60,000 per year for a 20,000 cfm system). 

Carlos: What is the concentration range? 

Magnus: For the preconcentrator, less than 300 ppm as styrene. It handles a variety of 

flows and is most cost effective with flows greater than 10,000 cfm. 

Norm Kaplan: What are the cost effectiveness numbers for the system? 

Magnus: Around $700 per ton for 8,760 hours per year of operation and around $1,500 

per ton for 3,000 hours per year of operation. 
P.6 

Dr. Madeleine Strum 

June 28, 1995 

Page 4 

Carlos: What is the capital investment cost? 

Magnus: Around $25 per cfm for a 20,000 cfm unit, for instance. From there, the cost 

per cfm goes up for smaller units and goes down for larger units. 

Norm: What capitalization factor was used to annualize the costs? 

Magnus: Around 0.163 (10 percent interest, 10 years life). 

Greg LaFlam: Which processes in the category could this system be used on? 

Magnus: Any operation from which styrene emissions need to be controlled. Type of 

operation is not important. We recommend preconcentration followed by oxidation. 

Dan Boyd: On what types of processes have preconcentrators been installed? 

Magnus: Those that manufacture septic tanks - open spray box with a polyester resin and 

fiberglass. Flow is around 100 ppm at 12,500 cfm, operating 1 shift per day, 8 hours per 

day. This system used to be a solvent recovery system, but was modified to now be a 

preconcentrator followed by combustion. The efficiency of the system increased following 

the change from around 90% to 97%. No downtime has occurred with the system yet. 

Dan: Are any systems being considered for installation in the United States? 

Magnus: Yes, quite a few. Cannot tell you where at this time, but should be able to 

provide information in a few months. 

Steve McNally: For the preconcentrator system, does the incineration unit add more cost? 

Magnus: The cost of the incineration unit was included in the capital cost stated earlier. It 

runs between 15 and 20 percent of the total capital costs. 

Mark Banner: For the system that treats 12,500 cfm, what is the flow to the incinerator? 

Magnus: Around 500 cfm is going to the incinerator after the preconcentrator. 

Dan: The plastics composite industry has facilities with flows of several hundred thousand 

cfm. Is this a problem for your system? 
P.7 

Dr. Madeleine Strum 

June 28, 1995 

Page 5 

Magnus: Not really. But that is a large flow to handle. The facilities should first see if 

there is anything that could be done to reduce the flow. To handle 200,000 cfm, we would 

probably install five or six adsorbers in parallel. 

Dan: Occupational exposure limits require that large flow rates be maintained in the work 

area. 

Madeleine Strum: What are the workplace styrene concentration level standards in 

Sweden? 

Magnus: In Sweden it is about 25 ppm possibly. Concentrations from the spray booths 

are around 100 ppm. 

Mohan Balagopalan: What is the efficiency of the unit handling 100 ppm? 

Magnus: 97 percent at 100 ppm inlet concentration. 

Richard Nielson: What is die largest stream on which one of your systems has been 

installed? 

Magnus: 35,000 cfm at this time; its concentration is around 100 ppm. 

John: You have five units in operation in Europe. Why not more? 

Magnus: Good question; I do not know. 

Carlos: How are the beds regenerated? 

Magnus: In a fluidized bed with warm air, heated with air from the oxidizer, at around 

300°F. Pulled through the bed, the VOC is released into the smaller air stream. 

Carlos: Is there any polymerization in the bed? 

Magnus: We have never seen any. 

Carlos: How was efficiency measured in these systems? 

Magnus: Carbon tube, Tedlar bags, GC, FID. 

Mohan: What are the conditions of the oxidizer? 
P.8 

Dr. Madeleine Strum 

June 28, 1995 

Page 6 

Magnus: The oxidizer used is a standard one available on the market. If it is a recuperative system, the residence time is > 1 second. 

Norm: There is a 1992 unit installed in Denmark. Why have you focused on the 12,500 

cfm unit? 

Magnus: The unit in Denmark is a solvent recovery unit that is undergoing modification to 

a preconcentration unit. They have not been able to re-use the recovered solvent. 

Norm: Is the flow to the adsorber constant? 

Magnus: The flow is constant, but the concentration is not constant. The flow and 

concentration to the oxidizer are constant, however. 

Emory: What about the adsorber being able to handle non-constant flows? 

Magnus: Capacity of the adsorber is designed to handle peak flow. So if it is designed 

correctly, there is no problem. 

Carlos: Is there a buffer to equalize the concentration to the adsorber? 

Magnus: There is no buffer to smooth out the concentration peaks. The system uses four 

to six beds. 

Norm: For the solvent recovery systems, why can't the solvent be reused? 

Magnus: In the adsorber, we use air instead of nitrogen. As a result, there is some 

oxidation of styrene. This creates some discoloration of the recovered solvent. 

Madeleine: What is the size of the facilities on which you have these systems? 

Magnus: I do not know. I can research that and get back to you. 

Rich: I understand that you have run some tests in either North Carolina or South 

Carolina. Can you summarize the highlights of those tests, the good and die bad? 

Magnus: Yes, we ran some tests in November 1992. We only had recovery units at that 

time. Positive highlights included: system reacts slowly to ups and downs and around 

95 % efficiency with recovery system. 
P.9 

Dr. Madeleine Strum 

June 28, 1995 

Page 7 

Rich: What was the cost effectiveness of the unit? 

Magnus: Should be in the report. Similar numbers to those that I noted earlier. 

Dan: I think the test was at Wilson,' NC for a bleed system widi low cfm. 

Magnus: That is correct. It was a slip stream from a spray booth. 

John: I just wanted to point out at diis time that industry has a lot of information on uiese 

topics, and that silence on our part should not be interpreted as agreement with what is 

being said. 

Carlos: When will industry provide this information? 

John: When appropriate. We will share it with the vendors, and welcome further 

opportunity to discuss these technologies. 

PAUL BLYSTONE. PURUS INC. 

The PURUS system is called PADRE, and is based on adsorption. The system is 

small relative to the needs of the plastic composites industry, with the largest current 

installation handling around 7,000 cfm. The PADRE system uses fixed bed adsorbers. 

They have around 50 installations, mostly on remediation technologies/processes (e.g., 

chlorinated solvents) at Superfund sites, but are branching out into some industrial 

applications (e.g., paint spray booths). Their system could possibly be used for small flow 

major sources in the future, especially in the long-term as industry reduces flows. 

The technology uses fixed beds, with one adsorber on-line while the other is either 

desorbing or on standby. Vacuum and temperature (_<180 degrees C) are used to achieve 

the desorption. The exact "recipe" depends on the compounds being treated. They use 

four different type of adsorbents, provided by Rohm & Haas and by Dow. A 2-stage 

condenser is used to recover the desorbed VOC as a liquid. There are a few cases where 

their customers are routing the offgas to an oxidizer. As a company, Purus strictly sells 

their units as recovery systems. 

They have conducted two pilot tests. One was a wastewater stripper, which had 

been an air stripper followed by a carbon adsorber, at a facility mat manufactures styrene. 

This pilot test ran into cost problems and adsorbent problems (the adsorbent lost capacity 
P.10 

Dr. Madeleine Strum 

June 28, 1995 

Page 8 

after 1 or 2 desorption cycles). It was treating a slip stream with a concentration of 15 to 

20 ppm of a mixture of volatiles and water vapor. For this facility, they could return the 

recovered stream back into the feedstock as quality control was not as important a factor in 

the manufacture of styrene. 

The second pilot test was for a composite manufacturing facility and some molding. 

A slip stream [around 150 cfm and 10 to 100 ppm (spikes)] off of the main stream was 

treated. At this pilot test, they measured the adsorption capacity of the bed over time, and 

saw no drop in adsorption capacity over multiple desorption cycles. The recovered product 

was slightly off-color (due to water). A second recovery step is likely to be needed before 

it could be reused. The ability to reuse the solvent is still an open question, and may be 

the key to use of the system in this industry due to the high value of the recovered styrene. 

Questions and Answers 

Carlos: What is the cost of the system in terms of $/cfm and $/ton of recovered material? 

Paul: For chlorinated solvents, around $0.50 to $1.00/lb to get operating cost for 

recovery. For larger systems, need $15 to $25/cfm capital cost. Anticipate that Purus 

would fall into this range. 

Carlos: How much adsorbent needs to be replaced using the fixed bed technology? 

Paul: Do not know. Longest running system is 3 years old and so far no replacement has 

been needed. The resin used in the system is about lOx the cost for activated carbon. 

Under accelerated life tests, there is still no indication of loss of adsorbent capacity. 

Norm: Have they installed a system to control styrene emissions? 

Paul: No. They have a pilot test, however, of less than 3 months on a styrene emission 

stream. 

Carlos: What is the size of the particles in the bed? 

Paul: They are about the size of a "BB" pellet. The manufacturers are trying to increase 

the size. 

Carlos: What about surface area? 
P.11 

Dr. Madeleine Strum 

June 28, 1995 

Page 9 

Paul: Don't know. Can refer to the technical sheets. They have excellent surface area 

relative to carbon. There is no ash content to act as a catalyst. 

Carlos: What about moisture? Does relative humidity affect performance? 

Paul: Varies depending on the adsorbent. Dow, for example, has a resin for ketone 

recovery that is more polar than others and thus has a higher affinity for water. However, 

relative to carbon, all of the adsorbents we use are hydrophobic. 

Carlos: With carbon, too high a humidity level results in moisture around the carbon, 

which adversely affects adsorption capabilities. 

Paul: True, unless trying to recovery methanol. 

Christine McPhee: What sort of control system parameters can be monitored to ensure 

efficiency of the systems being discussed today? 

Paul: Possibly some sort of styrene monitor. Could log desorption temperatures and 

cycles, or measure styrene influent and effluent. At the second pilot test, we looked at a 

Foxboro analyzer, which seemed to perform well. Other parameters (temperature, cycle 

time, vacuum level) could be recorded. 

Norm: Your cost effectiveness estimate seems to be an order of magnitude higher than 

reported by Magnus. 

Paul: The number I reported is for capital cost, not operating cost. 

Magnus: If we built smaller systems like Paul's, we would probably have cost effectiveness values in the same ballpark as his. 

Carlos: The control device is only good as the capture efficiency. 

Paul: I cannot really speak for this industry, but elsewhere capture efficiency seems pretty 

good. At a large auto assembly plant in Los Angeles, paint spray booths (250,000 ppm) 

recirculate 90% of air and still maintain negative pressure and protection of workers. This 

reduces flow by an order of magnitude before treating. 

Question: Isn't this an unfair comparison? 
P.12 

Dr. Madeleine Strum 

June 28, 1995 

Page 10 

Paul: Yes. This industry may not have the same resources to design such recirculation 

systems. I have seen other industries where it is done. Maybe SPI could lead the way for 

the smaller facilities. 

RON SUNDBERG. SETCQ 

Our systems (MIAB of Sweden) are fixed bed concentrators for intermittent 

applications using a carbon filter media. MIAB uses carbon adsorption and desorption with 

warm air to concentrate dilute solvent vapors to a much smaller air stream for efficient 

destruction in a catalytic incinerator. Using this process, the solvent can also be recovered. 

MIAB has two product lines, an intermittent duty unit and a continuous duty unit. 

The intermittent duty MIAB F is based on an activated carbon fixed bed adsorber. The 

continuous duty MIAB C uses a fluidized bed adsorber with activated carbon as the 

adsorbent. 

MIAB F. Installations ffl and #2 on Data Sheets 

The intermittent duty unit, the MIAB F solvent filter, uses a fixed bed carbon 

adsorber. During the work day, the MIAB F solvent filter cleans the solvent vapors from 

the ventilation air. After the work shift is complete, the solvent filter is shut down for 

desorption. The MIAB F uses warm air to desorb the carbon bed, typically over a 14-hour 

period. If more than one work shift is required, two MIAB F units are operated in 

parallel; while one bed is being desorbed, the other is cleaning the air stream. The normal 

inlet concentration for the MIAB F is 0.2 g/m3 to 0.6 g/m3 of solvent. 

The activated carbon bed of the MIAB F is configured so that when it is desorbed 

with warm air, the solvent vapor concentration in the strip gas is at a constant level, 

typically at 4 to 6 g/m3. The inique configuration of the MIAB F eliminates the initial 

peak in concentration that occurs when a carbon bed of traditional design is desorbed with 

warm air. At the 4 to 6 g/m concentration, the solvent can be efficiently destroyed in a 

catalytic incinerator without supplemental fuel. A constant concentration of solvent in the 

strip air stream that is treated by the catalytic incinerator is very important for safe, 

economical incineration of the solvent. 

Two applications of the MIAB F to the control of styrene are presented on page 1 

of the Fact Sheets submitted. The first application (#1) is at 23,000 cfm with 96% of the 
P.13 

Dr. Madeleine Strum 

June 28, 1995 

Page 11 

solvent in the 23,000 cfm stream destroyed in a catalytic incinerator. The unit has been 

operating since 1992. The carbon was changed after 2 years. 

In the second application, 93% of the styrene is recovered. The MIAB F cleans 

18,000 cfm at a concentration of 30 ppmv of styrene. In the solvent recovery process, the 

MIAB F is used as a pre-concentrator ahead of another fixed carbon bed. The MIAB F is 

desorbed with warm air into the second bed. The second bed is desorbed by indirect 

heating with steam and using an air strip gas. Using this process, a very high concentration of solvent can be obtained and ultimately condensed from the final strip gas. The 

styrene recovered is destroyed and not reused since the supplier would not guarantee the 

quality of the recovered material. The unit was installed in 1991 and it is still operating 

with the original carbon. 

MIAB C. Installations 3 and 4 

The continuous duty MIAB concentrator is based on a fluidized bed using activated 

carbon as the adsorbent. I believe that MIAB is the only firm that has successfully used 

activated carbon in a fluidized bed, and the only firm that seems confident in using carbon 

adsorption to control styrene vapors. The warm air desorption approach apparently avoids 

the problem of the styrene polymerizing on the carbon. At present we do not have a full 

scale commercial installation of the MIAB C; however, we have just completed a 3-month 

pilot test on styrene in Sweden (a test report is available). This pilot test is the application 

that is presented on the second fact sheet (#3). We have also included a proposed 

installation (#4) to show the projected performance and cost of a full scale unit. 

The MIAB C has three major components: a fluidized bed adsorption section, a 

fluidized bed desorption section, and a catalytic incinerator. The air stream enters the 

adsorption section consisting of three fluidized stages of activated carbon in series. 

Typically, the adsorption section is designed to remove over 90% of the solvent from the 

air stream, but can be designed for higher removal efficiencies. 

The activated carbon migrates between the adsorption section, where the incoming 

air is purified, and the desorption section, where the carbon is regenerated. The carbon 

continuously passes through the desorption bed and is recycled back to the adsorption 

sections. The desorption section is another fluidized bed and uses a small stream of warm 

strip gas to fluidize the carbon adsorbent. The warm strip gas removes the solvent from 

the carbon adsorbent. The carbon is recirculated to the adsorption section through a 

pneumatic tube. A valve regulates the recirculating flow of adsorbent within the system 

and thus can be used to make adjustments in performance. 
P.M 

Dr. Madeleine Strum 

June 28, 1995 

Page 12 

Questions and Answers 

Mohan: What are the capacities of the facilities on which you have installed your equipment? 

Ron: The MIAB F fixed bed unit has been installed at 23,000 and 18,000 cfm. It has 

been designed to fit an inlet air flow range of up to 50,000 cfm using single units. The 

two applications cited are at inlet concentrations of 20 to 25 ppmv; however, the design 

concentration can be as high as 0.2 g/m3 to 0.6 g/m3. 

Carlos: When do the beds change cycle? 

Ron: The MIAB F is sized to operate over one shift and desorb over the next 14 hours. 

Greg: Can you recommend any parameters for monitoring? 

Ron: I assume you could monitor data on the operation of the catalytic incinerator. 

Typically, any supplemental energy needed for complete oxidation is added by an electric 

heater, or by natural gas. Under normal operation and after a short startup, no supplemental energy is needed. Thus, if the amount of solvent in the strip gas were to decrease 

because of loss of adsorption capacity, the amount of supplemental energy needed for 

destruction of the solvent would increase. This, of course, assumes that conditions in the 

process being controlled remain somewhat constant. 

Madeleine: What happens to the recovered styrene? 

Ron: In the case cited, it is hauled off and burned. The quality of the styrene could not 

be guaranteed. I do not know if the recovered styrene qualifies as a hazardous waste. 

Carlos: Could it be used as a fuel for the catalytic oxidizer? 

Ron: I assume it could be. 

Christine: What is the concentration of the recovered styrene? 

Ron: It is all styrene except for moisture from the ambient air that is adsorbed on the 

carbon bed. I don't know the quality since it is burned. 

Mohan: What is the cost of replacing the carbon? 
P.15 

Dr. Madeleine Strum 

June 28, 1995 

Page 13 

Ron: The carbon replacement cost is not included in the costs presented in the data sheets; 

however, it is relatively small. For the fluidized bed it would be around 1% of operating 

costs. We will have a small (1,000 cfm) test unit available and are looking for an 

application in the United States. 

Carlos: What can we do to help you in finding a demonstration site? 

Ron: We would appreciate your assistance. I would like to pursue this further after the 

conference. 

Carlos: What is the source of your carbon? 

Ron: I understand it is a standard crushed carbon made from cocoanut shells. 

Norm: Referring to your graphic, how do you maintain a constant concentration of styrene 

in the gas? 

Ron: We do not use buffers to smooth the peaks. The uniform solvent concentration 

results from the physical configuration of the carbon bed and how the strip gas flows 

through the bed. It would be easiest to describe by sending you some patent sketches. 

LORI COENEN. GRACE TEC SYSTEMS 

Grace Tec Systems has over 1,600 oxidation systems (catalytic and thermal) 

controlling emissions from such industries as graphic arts, printing, and specialized 

applications. We have been in the oxidizer market since 1970. Currently, we do not have 

any applications controlling styrene emissions, but generally handle most VOCs. 

The Enterprise System is a thermal regenerative system with ceramic media for the 

heat exchange. The system is used for VOC and odor control. It converts organics to 

C02 and water, with a 95% thermal efficiency, and we will guarantee a 98% VOC 

destruction efficiency. Air enters through an inlet manifold, and it is then preheated in the 

ceramic media, then enters the combustion chamber, and exits through a second bed of 

ceramic media, with an outlet temperature only slightly higher than the inlet temperature. 

The minimum residence time is 1 second. 
P.16 

Dr. Madeleine Strum 

June 28, 1995 

Page 14 

Questions and Answers 

Madeleine: I understand that there is a proposed unit for a pipe manufacturer using 

molding processes and fiberglass reinforced plastic parts. 

Lori: Yes, in Texas. It would be handling 10,000 cfm. The proposal went out in 

November and we have been asked for a re-quote recently. The process emits around 2 

pounds of styrene per hour. 

Steve: Can you review the costs of your units? 

Lori: For the 10,000 cfm unit, capital costs would be about $280,000 or $28/cfm. For a 

50,000 cfm unit, the capital costs would drop to about $14 or $15 per cfm. At higher 

solvent loadings, the unit becomes self-sustaining except for electricity. 

Steve: What about the costs for the unit proposed in Texas? 

Lori: Annual costs were estimated to be around $6 per hour to operate at 28 lbs/hr 

loading for 10,000 cfm flow. This is equivalent to about $5.10 per cfm operating costs. 

ANDERS MUNTERS. AMT INC. 

Mr. Munters represents Bioclean from Sweden. They brought their biofilter onto 

the market in 1989 after 10 years of research. The biofilter uses microorganisms to clean 

the air, and is being used in a variety of applications. 

Bioclean experimented with various media, and mostly uses a media composed of 

peat, moss, and bark. A very important part of a biofilter is to ensure that the moisture 

content is correct. Any problems that they have encountered have been the result of 

"channeling," where areas of the biofilter dry out and the air will funnel out of the dry 

areas. Biofilters break the VOC down into C02 and water, and will remove odors and 

most organics. Aliphatic solvents including ethanol, acetane, isopropyl alcohol, methyl 

ethyl ketone, and methylformiate are exceptionally degradable. Aromates, merkaptanes, 

and other aliphatic solvents with larger molecules than 6 C-atoms degrade at a slower rate. 

Some very stable solvents in high concentrations such as benzene can be difficult to 

degrade. Stable solvents sometimes break down more easily through co-metabolism (in 

conjunction with other solvents). Chlorinated hydrocarbons are degradable with two or 
P.17 

Dr. Madeleine Strum 

June 28, 1995 

Page 15 

less chlorine atoms present. In general, efficiencies of up to 99% can be achieved, but 

such systems are not always the most economical. 

Questions and Answers 

Question: Styrene has 8 carbons. What kind of efficiencies have you seen for styrene? 

Anders: Good results, 90 to 95 percent. 

Question: What types of operations have you installed the biofilters on? 

Anders: We have applications on pharmaceutical plants, POTWs, one manufacturer of 

tops for pickup trucks, and various others. The manufacturer of the truck tops turns out 

about 2,000 parts per year. They use spray and hand layup, operating 8 hours per day 

with 2 weeks off in the summer. Even though the filters are not used for 2 weeks in the 

summer, they come back, even after as much as 4 weeks of downtime. This particular 

filter is designed for 85 % efficiency (doing fine) for 10,000 ppm. 

Mohan: Some bakeries have purchased biofilters. 

Carlos: I understand that biofilters need a large amount of space to accommodate them. 

Anders: The standard filter is contained in a 20-foot shipping container; they can be 

stacked three high. This reduces the amount of sq ft required. We have a patented 

combination unit (for 1 to 2 shifts per day) with a carbon adsorber. We use the carbon 

adsorber first, and it is then desorbed through the biofilter. We have installed this 

combination unit on two or three paint operations. 

Norm: What are the flow rates from the carbon adsorber to the biofilter? I assume they 

are reduced? 

Anders: The carbon adsorber does act as a concentrator. It basically stretches the time, 

storing the VOCs for 8 hours and then releasing them to the biofilter over the next 16 

hours. 

Christine: What operating parameters could be monitored to ensure efficiency of the 

biofilter? 

Anders: The biofilter is a fairly simple piece of equipment. Control of moisture in the 

filter is most important to its performance. A fan pulls the air through the filter. Once the 
P.18 

Dr. Madeleine Strum 

June 28, 1995 

Page 16 

system passes its initial performance test, there is not much need to check anything to 

ensure it is working correctly. Some customers have continuous monitors or run checks of 

moisture content. 

Carlos: What factors are critical to monitor performance? 

Anders: I do not know. If you have the correct moisture, the biofilter works. We have a 

built-in PLC that monitors and controls the moisture content. 

Christine: What else do customers look for? 

Anders: They check pressure drop over the filters, pH, and can take a simple bacteria 

count. 

Norm: What about temperature? 

Anders: There is some temperature rise. You could monitor that. If you put less in, 

though, you get a smaller temperature rise, but the biofilter is still working properly. 

Oftentimes you can smell whether or not the biofilter is working. 

Paul: For bioremediation, one can measure flow rate to ensure retention, bio-uptake (CO 

monitoring). 

Beth Harden: What about monitoring porosity and the temperature range for the bacteria? 

Anders: I will need one of my technical people to address those questions. 

Question: What would upset the system? 

Anders: Have not had any upsets so far where the bacteria have died. 

Carlos: How frequently have you had to change the media? 

Anders: The bed needs to be regenerated every 3 to 5 years. But since 1989, none have 

been changed yet. Lower pH will consume the bio-bed media. 

Carlos: How is the material disposed of? Is it a hazardous waste? 

Anders: No, it is not considered a hazardous waste. The Swedish government is very 

critical and looked at the old filter media and determined that it could be used as compost. 
P.19 

Dr. Madeleine Strum 

June 28, 1995 

Page 17 

Emory: How do the bacteria react to seasonal temperature changes? 

Anders: The filters in Sweden are insulated, and operate over a wide temperature range 

(-20°F to 100°F). 

Greg: What are the sources of the microorganisms? 

Anders: It varies. For example, local sludge may be used. In some cases it is better to 

use specially grown bacteria. 

John: Why is it that Sweden is a "hotbed" of control technology? 

Anders: The Swedish government wants to clean up the air. A lot of government 

subsidies, but the regulations are on the books. 

John: Are any of the costs offset by the government? 

Ron: I do not believe they are. 

Anders: Some of the first ones were subsidized in order to get the technology out; but 

today, no. There were initially various government grants to develop biofilters. 

Magnus: None of our installations has been subsidized by the government. 

ADDITIONAL DISCUSSION 

Carlos: Regarding government assistance, in ORD there is the Federal Technology 

Transfer Assistance program which works with industry to develop technologies. 

John: Need to look into government subsidies; I will look into more closely. Investment 

costs in European countries are very different. Will see if I can get more information. 

Rich: For Anders. Cost effectiveness numbers of $929 per ton of styrene controlled. Do 

you get much resistance to this number in this country? 

Anders: Basically, we are just starting out in this country. We tried to sell to some 

companies, but they felt EPA would not be affecting them for the next 10 years, so the 

interest was not there. 
P.20 

Dr. Madeleine Strum 

June 28, 1995 

Page 18 

Dan: In evaluating these technologies, do not just look at the $/ton of pollutant removed, 

but also look at the capital cost versus the facility's profitability. 

Emory: Are there any other technologies that could be used by the industry? 

Answer: Source reduction technologies are in use in the industry. 

Mohan: Pre-coated carbon filters to adsorb styrene. 

Lori: Catalytic systems using platinum-palladium on a bead (precious metal, not monolith). 

Florida DEP: The EPA's Control Technology Center (CTC) evaluated styrene removal 

control technologies. Check with Bob Blasczak or Chuck Darvin. 

Madeleine: Polyad was one of the technologies evaluated. The results were positive. 

Carlos: A Quad scrubber was the other technology evaluated. The tests may not be 

finished. The Quad scrubber is a very different technology, based on an acid or base 

liquid chemical scrubber. May have achieved a 50% reduction in the evaluation. 

Steve: Generally, the applicable control technologies are all variations on a theme: 

adsorbent and then purge and control. Very few offer straight oxidation. 

Paul: Has industry lowered the VOC content of the raw materials used in the industry? 

Steve: Unlike other industries, styrene is a reactive diluent that creates the plastic material 

and is not simply a carrier that evaporates. 

Paul: Has industry looked at catalysts to speed up the reaction and thereby reduce 

volatility? 

Steve: The industry is looking at this. The ability to do this varies from process to 

process - it is process specific and product specific. We can get promoters into the 

material; this option is currently available. How much VOC emissions are controlled is 

not addressed at this time. 

Mark: ORD and RTI are looking at reductions from pollution prevention and source 

reduction ~ styrene suppressants and application equipment. A test protocol was issued 
P.21 

Dr. Madeleine Strum 

June 28, 1995 

Page 19 

and comments have been received and addressed. A test at Reichold Chemical is scheduled for June 5, 1995. 

Dan: Can the protocol be made available? 

Carlos: Yes. 

Anders: One key to effective control is reducing the amount of flow to the system (not the 

amount of VOC). Managed air using laminar flow techniques. 

Ron: Will a list of meeting participants be provided? 

Madeleine: Yes. It will be part of the minutes to this meeting. 

Carlos Nunez asked the representatives of the industry trade groups whether they 

could provide the vendors with process parameters for actual plants so that the vendors 

could provide accurate cost estimates. Industry pointed out that there are few commonalities between facilities, and such a task would be a huge undertaking (costly), and the 

vendors themselves would incur large costs. The vendors basically agreed that to get good 

cost estimates would require considerable time and money. Mr. Schweitzer pointed out 

that the industry had been frustrated in past attempts to establish model plants due to the 

diversity of individual facilities. Also, a considerable fraction of the total control cost 

would be for a capture system, which varies dramatically for different facilities. Industry 

suggested that EPA do a sensitivity analysis of stream parameters, which would probably 

be as representative of the industry as any specific data that they provided. They also 

noted that EPA had surveyed about 1,000 facilities for this information in 1992. It was 

pointed out by EPA that the information obtained was not stream parameter information 

because collection information constraints required that a much more general questionnaire 

be used to gather information. No resolution of this discussion was reached. 

Carlos: Steve and John. Can we have industry through the associations provide EPA/vendors with prospective problems and prospective solutions and costs. This would give us 

the "facts" on all the options available to us. 

John: We have hired an environmental engineer to follow EPA procedures for case-bycase (Tier 1 and Tier 2). Once completed, we will share the results with EPA in the 

coming months. 
P.22 

Dr. Madeleine Strum 

June 28, 1995 

Page 20 

Carlos: A number of vendors today have shown technologies at a reasonable cost. If they 

have this pool of plant information from you, can you give me your best shot as to whether 

you can control or not control? 

Industry: Collecting emissions for ducting to control devices is a big issue. Most facilities 

do not have stacks. 

Steve: The EPA needs to consider the "hidden" costs in regulation - transport gases to 

control devices, permitting costs for control devices, etc. 

Christine: It depends on how permits are implemented in the States. In Ohio, the control 

device does not require a permit. 

Greg: To date, we have received only a few comments from the team members. Everyone is encouraged to look back at the original material or today's discussion. Please write 

up and submit any comments to EPA. 

Madeleine: I would like to have a teleconference later this summer to discuss pollution 

prevention and to have an industry proposal during the next call. 

Dan: I think we lose a lot by not interacting directly with team members. Can we meet 

somewhere? 

Madeleine: Due to budget constraints, not likely. However, you are always more than 

welcome to travel to Durham to meet. 
P.23 

FACT SHEET 

Information on Grace TEC Systems VOC abatement technologies: 

Manufacturen 

Grace TEC Systems 

Industnal Emission Control Products 

W.R. Grace & Co. - Conn. 

830 Prosper Road, P.O. Box 30 

DePere.W! 54115-0030 

(414) 336-5715 

FAX (414) 337-1585 

Name of Technology: 

Enterprise Thermal Regenerative Oxidizer 

Description of Technology: 

The Enterprise Is a thermal oxidizer for VOC and odor control. It combines high 

temperature thermal oxidation with regenerative heat exchange to efficiently convert 

VOCs and other odor causing organic compounds to carton dioxide and water. It 

comes standard with a 95% heat exchanger efficiency and a 98% VOC destruction 

efficiency. The unit consists of an exhaust fan with AC drive, inlet manifold, two 

ceramic filled energy recovery columns, a combustion chamber, a nozzle mix burner 

with gas train, an outlet manifold, and PLC control system.. 

Air from the process is fed into the first bed of ceramic media through the inlet manifold 

by the exhaust fan, and is preheated to nearly the combustion chamber temperature. 

Bumers in the combustion chamber raise the temperature of the air to the operating 

setpoint and the oxidation process is completed. Retention time in the combustion 

chamber is a minimum of one second. Hot purified air then enters the second column 

and passes down through the ceramic media and is cooled. The purified air then passes 

through the outlet valve and manifold, at a temperature only slightly higher than that of 

the inlet stream. 

Industrial Applications 

Grace TEC Systems is the leader in oxidation technology, with over 1,600 

oxidation systems installed throughout the world. Grace TEC Systems offers catalytic, 

thermal recuperative and thermal regenerative oxidizers. Applications include the 

Graphic Arts, Flexographic/Rotogravure printing industries, as well as many specialized 

applications in the packaging, coating, healthcare, and textile industries. Our oxidizers 

have been on the market in industrial use since 1970. 

Three typical applications for the Enterprise are listed below, including sell price and 

operating costs. The first is a unit recently proposed to a plastic pipe manufacturer, and 

the other two units have been sold to a graphic arts printer, and a food packaging 

company, respectively. 
P.24 

riHY-^j-iyy^ a? "54 GRACE EM1551ON CONTROL PR 414 339 2784 P. 03 

Enterprise 10000 (Proposed) 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Destruction efficiency: 98% 

Capital Cost: S282.950.00 

Operating costs: 

Natural gas usage @ S.45/therm: 

Electricity® $.06/kWh 

Annual operating cost/cfm 

Enterprise 20000 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Pipe manufacturing molds 

10430 scfm 

140 deg. F 

Styrene 

28LB/hr 

$3.20/hr 

$2.91/hr 

$5.13 

Graphic Arts Printing Operation 

22,000 scfm 

325 deg. F 

Maglesol 

151#tor 

Destruction efficiency: 98% 

Capital Cost: $397,370.00 

Operating costs: 

Natural gas usage @ $.45/therm: 

Electricity @ $.06/kWh 

Annual operating cost/cfm 

Enterprise 50000 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Destruction efficiency: 98% 

Capital Cost $742,148.00 

Operating costs: 

Natural gas usage @ $.45/thenm: 

Electricity® $.06/kWh 

Annual operating cost/cfm 

$0.00/hr (self-sustaining at VOC loading) 

$8.28/hr 

$3.30 

Food packaging 

50000 scfm 

100 deg. F 

Toiuene.hexane.propanol.lBA.MEK 

437LB/hr 

$0.0Q/hr (self-sustaining at solvent loading) 

$U.94/hr 

$2.62 

THTQI P OH. 
P.25 

Enterprise 10000 (Proposed) 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Destruction efficiency: 98% 

Capital Cost: $282,950.00 

Operating costs: 

Natural gas usage @ $.45Aherm: 

Electricity® $.Q6/kWh 

Annual operating cost/cfm 

Enterprise 20000 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Pipe manufacturing molds 

10430 scfm 

140 deg. F 

Styrene 

28LB/hr 

$3.20/hr 

$2.91/hr 

$5.13 

Graphic Arts Printing Operation 

22,000 scfm 

325 deg. F 

Maglesoi 

151-Whr 

Destruction effidency: 98% 

Capital Cost: $397,370.00 

Operating costs: 

Natural gas usage ® $.4S/therm: 

Electricity® S.06/kWh 

Annual operating cost/cfm 

Enterprise 50000 

Application: 

Exhaust Flow: 

Exhaust Temperature: 

Solvent (VOC): 

VOC emissions: 

Destruction efficiency: 98% 

Capital Cost: $742,148.00 

Operating costs: 

Natural gas usage ® $.45/therm: 

Electricity® $.06/kWh 

Annual operating cost/cfm 

$0.0Q/hr (self-sustaining at VOC loading) 

$8.28/hr 

$3.30 

Food packaging 

50000 scfm 

100 deg. F 

ToIuene.hexane,propanol,IBA.MEK 

437|_B/hr 

$0.00/hr (self-sustaining at solvent loading) 

$14.94/hr 

$2.62 

TRTOI P on 
P.26 

Attachment 

June 28, 1995 

SUMMARY OF COMMENTS RECEIVED ON PRE-MACT TOPICS 

During the first pre-MACT team teleconference on February 7, 

1995, Madeleine Strum provided information on the plastic 

composites fabrication industry and raised several issues 

concerning this rulemaking effort. She requested feedback from 

the team on such topics as potential formats of the standard and 

the data needed by the team to make the pre-MACT decisions. The 

request for input was repeated during the second team conference 

call on May 24, 1995. 

Written responses have been received from three members of 

the team and the ORD contractor. The questions and the team 

responses are summarized below. Commenters are numbered 

according to the code at the end of this attachment. 

Question 1. Should the team meetings be opened to industry trade 

association groups a*nd interested environmental groups? 

Response: It was agreed among participants at the first 

meeting to include industry and environmental representatives on 

the team. The three commenters on this question (1, 2, 3) 

acknowledged the team's decision and agreed that these interests 

should be represented. 

Question 2. What additional data analyses are necessary? What 

data could industry provide? 

Response: One commenter (4) cited three desirable types of 

data analyses: 1) determine emission factors by process using 

available data and recent studies; 2) estimate the number of 

sources and total emissions, attempting to reduce the 27 percent 

of emissions for which the process is "unknown"; and 3) obtain 

additional data on add-on controls, considering cost 

effectiveness, both for U.S. and European systems. 

A second commenter (3) suggested that the analysis of EPA's 

1993 screening survey responses should be completed, but believed 

that another survey might be necessary to determine "baseline" 

and pollution prevention (P2) measures in use. 

One commenter (2) felt that information on the cost 

effectiveness of U.S. and European control systems was needed, as 

well as opinions from regulators on how effective these systems 

are. Another (1) believed that data on reductions achievable 

using readily available P2 technologies and practices would be 

beneficial. A third commenter (3) thought that industry could 

supply better data if another, more detailed survey was developed 

and sent out. 
P.27 

Attachment 

June 28, 1995 

Question 3. Do you have any ideas on the MACT "big picture"? 

Response: Two of the commenters (3, 4) felt that South 

Coast Rule 1162 might be a good starting point, at least for 

existing sources (with work practices added to reduce the smaller 

emission points). Efforts should be concentrated on the 

processes with the highest emissions. One (3) pointed out that 

the South Coast rule probably does not represent the control 

level of the top 12 percent for the gel coating process. Another 

team member (2) thought that a MACT floor should be developed 

based on the 12 percent criterion, and that "filler" techniques 

(adding solid fillers to decrease the styrene percentage in the 

resin mix) should not be allowed to take the place of true 

emission reductions. The fourth commenter (1) stressed the need 

to encourage P2 innovation. For new source MACT, this commenter 

stated that add-on controls should be explored. 

Question 4. What would be a good format for the standard? 

Response: Five possible formats were suggested by Dr. Strum 

for discussion: 1) plant-wide limit (g styrene/m coated); 

2) limit on styrene from resin used (as-supplied by vendor or asapplied) (g/m ); 3) plant-wide (g styrene/kg resin used); 4) 

limit on resin used (g/kg resin); and 5) semi-quantitative POINT 

system based on the total of techniques used (flexibility). 

Two commenters (1, 2) favored the plant-wide limit in g/kg 

resin used, while a third (4) fe^t that there would be 

uncertainties in developing monitoring protocols and determining 

means of compliance for this format. One (2) said that this 

limit could be determined by taking South Coast's 60 g/m2 rule 

and applying a MACT reduction of 33 percent, so final emissions 

would represent a 33 percent reduction over existing Rule 1162 

uncontrolled emission levels. Allow flexibility in choice of 

controls to achieve the limit. 

One commenter (3) felt that the best format would depend on 

the results of ongoing testing. The standard currently should 

include a numerical emission limit plus a list of P2 measures or 

controls that will achieve the limit (example: g/m2 limit, plus 

add-on controls, styrene content limit, HVLP spray guns, etc.). 

The numerical limit is needed because it would allow reduction 

methods not specifically mentioned in the standard. Specific 

measures are needed because this will allow plants to avoid 

testing if they use those measures. The standard should allow 

substitution of mass balance calculations for testing. 

Question 5. Is it reasonable to use data from control systems 

being used in Europe for evaluating feasibility? 
P.28 

Attachment 

June 28, 1995 

Response: Two team members (1, 2) felt that the European 

control technologies should be factored in. Another (3) believed 

that industry may challenge this approach, and that the CAAA do 

not appear to indicate that foreign technologies should be 

considered. 

Question 6. How should "similar" processes be grouped together 

for purposes of new source MACT floor determination? 

Response: One commenter (3) stated that only processes that 

have "nearly the same" emissions and potential reduction measures 

should be grouped together (example: don't combine the gel 

coating process with continuous lamination and pultrusion 

processes due to their different emission factors and likely 

control measures). 

Commenters 

1. Jordan Spooner 

2. Richard Neilson 

3. Mark Bahner 

4. Maria Malave