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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

100) ll-E-60 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:06 AM Sheet 100 of 264 
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INTERNATIONAL ® 

/W4-52. 

ii-E-40 

\—' 

PAPER 

DECORATIVE PRODUCTS DIVISION 

Certified Mail»: P199 189128 

8339 TELEGRAPH ROAD 

ODENTON, MD 21113-1397 

PHONE 410 519 5134 

FAX 410 519 2112 

anuary 31,1997 

Ms. Linda Herring 

Group Leader 

Coatings and Consumer Products Group 

United States EPA 

Research Triangle Park, NC 27711 

Re: Review of CBI Documents 93185-C18-11C and 93185-C18-I1D (MACT phone 

conversation on 8/9/96 and 7/12/96) 

Dear Ms. Herring: 

The enclosed documents do not contain any confidential business information relative to our 

manufacturing process. The enclosed documents have been approved for release to the public 

files for Reinforced Plastic Composites National Emission Standards for Hazardous Air 

Pollutants. 

If you have any questions or concerns please contact me at 410-519-5134. 

Enclosures 

Sincerely, / 

Karen Dellario 

Environmental Engineer 

v. Al 

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foi&rtir-'iti 

NON CONFIDENTIAL CONTACT REPORT 

From: Madeleine Strum 

us EPA, OAQPS/ESD, Coatings and Consumer Products Group 

Date of Contact: July 12, 1996 

Contacts: Charlie Stanier and Karen Dellario 

Company: International Paper, Decorative Products Division, 

Odenton Facility, Odenton, Maryland 

Telephone Number: 410 519 2094 (Mr. Stanier) 

5134 (Ms. Dellario) 

Mr. Stanier and Ms. Dellario were contacted to determine whether 

the Fountainhead continuous line might fit into the surface 

category of paper coating, rather than the subcategory of 

continuous casting/continuous lamination since the resin matrix 

is dispensed on a paper web. Dan Brown and Madeleine Strum of 

the Coatings and Consumer Products Group initiated the call. 

Madeleine had just visited two continuous lamination facilities 

earlier that week and called to investigate the similarities and 

differences between the Fountainhead continuous line to these 

continuous lamination processes. Because the continuous 

lamination processes used plastic film to hold the resin (and 

fibers) to make the laminate rather than paper, Madeleine thought 

that the process might be covered under the paper, film and foil 

coating category. Dan Brown, also in EPA's Coatings and Consumer 

Products Group, is the project lead for this effort. 

Mr. Stanier described the continuous casting process. The 

process entails the dispensing of a catalyzed resin matrix on 

highly coated paper. The facility buys the 'coated paper, and the 

purpose of using coated paper is for easy peal off. The paper is 

not part of the produat. After the paper is peeled, both surfaces 

are sanded to give a smooth, marble-like finish. The product is 

a counter top surface that feels like marble. It is similar to 

Dupont's Corian surface. The product is made in three 

thicknesses: 1/4 inch, K inch and 3/4 inch. 

The catalyzed resin matrix consists of unsaturated polyester 

resin (containing styrene monomer)and alumina trihydrate filler. 

The mixing process was not discussed during the phone call, 

however, it was noted that the matrix was heated to between 90 

and 100 degrees Fahrenheit. This is necessary to provide for the 

proper viscosity of the resin. In the continuous process, the 

matrix is dispensed on the paper through a one inch diameter pipe 

connected to a dispensing die. In the first 10 feet of the 

line, gravity flattens out the matrix to make it 3 0 inches wide . 

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and the selected thickness. After moving through these 10 feet of 

the line, the matrix is pulled through the oven. Madeleine asked 

whether a top film was placed over the matrix before it passed 

through the oven. She explained that this is common practice in 

a continuous lamination process. Charlie Stanier noted that 

there is no top film placed over the matrix in this casting 

process. 

It was determined over the phone that the process would not be in 

the paper coating subcategory because the paper is peeled off to 

make the final product. The process may still be considered 

under the reinforced plastic composites category due to the 

similarities in materials used and similarity in emission points. 

It is still not clear whether the facility would be covered in 

the continuous lamination subcategory under the reinforced 

plastics source category. Main differences between this process 

and the continuous lamination process include the lack of fibers 

or mat added to the laminate and the lack of plastic film to 

cover the resin matrix as it enters the oven. 

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Docket No. A-94-52 

Category II-E 

The following information is located in the confidential files of the Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U. S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This information is 

confidential pending final determination by the Administrator and is not available for public 

inspection. 

Telecon, M. Strum, EPA:OAQPS:CCPG, K. Meardon and M. Proctor, PES, Inc. with C. 

Stanier and K. Dellario, International Paper, (formerly Nevamar Corp.), dated, July 12, 1996. 

This contact report was for the purpose to determine whether the Fountainhead 

continuous line might fit into the surface category of paper coating, rather than the subcategory 

of continuous casting/continuous lamination since the resin matrix is dispensed on a paper web. 

The confidential information is comprised of a 2-page report. 

CN-504-1/93185-C18-11C 

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"• (}3/l&/Mfi)-

NONCONFIDENTIAL CONTACT REPORT 

From: Madeleine Strum, US EPA, OAQPS/ESD, Coatings and Consumer' 

Products Group 

Kenneth Meardon and Melanie Proctor, Pacific Environmental Services, 

Inc. (PES) 

Date: August 9, 1996 

Contact: Charlie Stanier and Karen Dellario 

Company: International Paper, Decorative Products Division, Odenton Facility 

(Formerly Nevamar Corporation), Odenton, Maryland 

Telephone Number: (410) 519-5134 (Ms. Dellario) 

(410) 519-2094 (Mr. Stanier) 

CONTACT SUMMARY: 

The Odenton Facility of International Paper, Decorative Products Division, was contacted 

to clarify the following three main issues: 1) determine if the continuous line process used to 

produce solid surface plastic sheets is in the continuous lamination subcategory; 2) quantify the 

emission reduction achieved in the continuous line process, and 3) determine if there are any 

planned changes to the continuous line process within the next two years. 

International Paper's continuous line process does not use fiberglass reinforcements and is 

controlled with a condenser and carbon filters. Ms. Strum inquired if International Paper has 

experienced any problems with particles clogging the condenser and if this type of control system 

could be used if fiberglass reinforcement was used in the process. Mr. Stanier explained that all 

particulate matter within the matrix is completely wetted with resin before emissions are vented to 

the condenser. According to Mr. Stanier the condenser only collects water vapors, styrene, 

[confidential material] and traces' of xylene (less than 1/10 of a percent). Mr. Stanier noted that 

they did not anticipate water in the vapor stream when the system was initially designed and thus 

they decided to operate a condenser as the main control device at a temperature of 100° K (-279° 

F), and a carbon filters to "polish" off the emission stream from the condenser. However, ice 

formation on the condenser forced International Paper to increase the condenser temperature and 

to rely on the carbon filters to meet environmental requirements. The condenser is primarily used 

as a "precooler". Mr. Stanier explained that International Paper has some problems with 

polystyrene "gum" build up in their valves and in the condenser. However, the build up can be 

cleaned up easily and does not pose a big problem based on Mr. Stanier's opinion. According to 

Mr. Stanier, the emission control system used at the Odenton facility could probably not be 

applied if reinforced fibers were present in the process gas stream. Some additional precondenser filtration system would likely be necessary. 

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When Mr. Stainer was asked how he would classify the processes at the Odenton facility, 

he explained that the facility casts polymers in either bowl or sink shapes and in thin or thick 

sheets. The thin and thick sheets are produced in a continuous line process. The Odenton facility 

still has a permit to cast sheets in aluminum molds, but this process is not in use anymore. 

Mr. Meardon asked whether polymer casting of sinks and bowls could be controlled by 

the same type of emission control system that is used for the continuous line process. Mr. Stanier 

explained that carbon filters are only feasible when the flow of the emission stream is low and the 

VOC content is high as in the case of the partially enclosed continuous line process. According to 

Mr. Stanier, other VOC sources that would be feasible to vent to the emission control system 

include oven exhaust, mixing exhaust, and the exhaust from the dispensing area where the mold is 

filled.' Mr. Stanier explained that the sink and bowl casting process at the Odenton facility cannot 

be enclosed due to space limitations at the facihty. If the entire room would be vented to the 

control system, the air flow would have to be increased considerably, which would interfere with 

the proper functioning of the carbon filters. Mr. Stanier thought that it might be difficult but 

possible to enclose polymer casting at a newly constructed facility and vent emissions to a control 

device. But according to Mr. Stanier, continuous processes are much easily and more effectively 

controlled by add-on control devices than batch processes. 

Mr. Stanier added that from a cost perspective, it did not make sense to control any of 

their processes with the type of control system in place at the Odenton facility. The cost to 

control one ton of HAP with the condenser and the carbon beds is between $20,000 and $30,000. 

If the facility could redesign the emission control system, Mr. Stanier thought they would cover 

the sheets produced in the continuous line process with a gas impermeable film to more effectively 

control emissions. 

In order to determine in which subcategory a specific process belongs, the EPA is 

developing definitions that would distinguish the different subcategories based on process 

characteristics. Ms. Proctor read tl^following preliminary definitions for continuous 

lamination/continuous casting and polymer casting and asked Mr. Stanier to comment on these 

definitions with regard to the processes at the Odenton facility: 

Continuous lamination/continuous casting is a substantially automated process for 

producing laminates on ah in-line conveyer. The process involves applying resin or gel 

coat onto a flat, moving surface, and then curing the material, typically in an oven through 

which the laminate is automatically moved. 

Polymer casting involves the production of a non-reinforced composite that combines 

polymers, fillers, and additives by pouring or dispensing these materials into open or 

partially open molds and then curing them at elevated or ambient temperature. 

Mr. Stanier pointed out that the process of casting sinks and bowls definitely belonged in 

the polymer casting subcategory and that the continuous line process for casting thin and thick 

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sheets appeared to belong in the continuous lamination/continuous casting subcategory based on 

the definitions provided. However, Mr. Stanier explained that the products produced in the 

continuous line process, are non-reinforced and traditionally produced by polymer casting. Mr. 

Stanier inquired if the continuous lamination/continuous casting definition would include 

reinforced and non-reinforced products. 

Ms. Strum indicated that no final decisions have been made concerning the subcategory 

definitions. According to Ms. Strum, there is some flexibility in how the facilities are 

subcategorized, but due to the variety of products in the reinforced plastics industry, 

subcategorization is likely determined based on process rather than product. Ms. Strum further 

explained that if International Paper's continuous line process does not fit in any of the existing 

subcategories, this process could be placed in its own subcategory. 

The next major issue of the discussion was the descriptiorr of the continuous line process 

with its enclosure and the emission reduction achieved in this process. Mr. Stanier explained that 

the continuous line consists of a 100 foot long and 40 inch wide belt that moves in a circle. Filled 

resin is dispensed onto the moving belt and reaches an oven 10 feet after the point where the resin 

has been dispensed. Approximately one foot after the resin has been dispensed onto the belt, an 

enclosure, which covers the area above and below the belt, encloses the belt and the oven. Where 

the dispensed resin enters the enclosure, there is a 4 to 6 inch gap in the enclosure to allow the 

resin mixture to enter the enclosure. 

The oven has boxes with lids on either side of the oven to access the sheets that are being 

produced. In areas where frequent access is needed the lids are automated, while screw down 

covers are placed in areas of low maintenance. The oven is nitrogen blanketed and kept under 

positive pressure to avoid any oxygen from entering the oven which could potentially cause an 

explosion. The enclosure upstream from the oven is kept at neutral pressure allowing some of the 

air from the oven to be drawn away from the oven into the enclosure and escape (through the 

entrance and any other openings in the enclosure) to the atmosphere. According to Mr. Stanier, 

the hazardous air pollutant (HAP) concentration escaping out of the enclosure through the gap 

near the resin dispensing area can be as high as 400 to 600 ppm. Mr. Stanier explained that the 

HAP concentration within the facility is close to the threshold limit'value (TLV), but that the TLV 

is not exceeded. Mr. Stanier further explained that it is impossible to create a negative pressure 

environment in the oven or in the*enclosure in general because the risk of explosion is too high. 

The emissions from the enclosure around the continuous line including emissions from 

totes and pumps are vented to the emission control system. Mr. Stanier estimated that the 

capture from the entire continuous line process fifty percent or less. The control efficiency of the 

condenser and the carbon filters, which are changed once a week, is 99 to 100 percent. The 

compounds collected by the condenser are sent off as hazardous waste. 

The Odenton facility also operates a particle line that produces 20 inch wide ribbons. The 

production of polyester particles is a continuous process that is controlled by a carbon bed. Mr. 

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Stanier pointed out that the oven in that line can operate at negative pressure without the risk of 

explosions. According to Mr. Stanier the emission capture efficiency of that line is 92 percent. 

The last purpose of the discussion was to determine if International Paper is planning any 

changes to the continuous line process within the next two years. Mr. Stanier noted that the 

continuous line is producing 3 different sheets varying in width and the entrance gap into the 

enclosure is cut to accommodate the widest sheet produced. According to Mr. Stanier, the only 

planned change to the continuous line process is to cover up part of the entrance gap when 

narrower sheets are produced. This would increase the capture efficiency for the narrower sheets. 

Mr. Stanier added that Maryland's fiberglass RACT requirement caused them to look at 

retrofitting the enclosure, but International Paper found that the costs were not justifiable. 

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Docket No. A-94-52 

Category II-E 

The following information is located in the confidential files of the Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U. S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This information is 

confidential pending final determination by the Administrator and is not available for public 

inspection. 

Telecon, M. Strum, EPA:OAQPS:CCPG, K. Meardon and M. Proctor, PES, Inc. with C. 

Stanier and K. Dellario, International Paper, (formerly Nevamar Corp.), dated, August 9,1996. 

This contact report was for the purpose to clarify three main issues 1.) determine if the 

continuous line process used to produce solid surface plastic sheets is in the continuous 

lamination subcategory; 2.) quantify the emission reduction achieved in the continuous line 

process, and 3.) determine if there are any planned changes to the continuous line process within 

the next two years. The confidential information is comprised of a 4-page report. 

CN-504-1/93185-C18-11D