p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

63) IV-C-36 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 63 of 273 
P.2 

A-94-52 

IV-C-36 

i> » 

REINFORCED PLASTIC 

COMPOSITES 

MACT STANDARDS 

DEVELOPMENT UPDATE 

r

r^ •!,';> nc"'u 

For the Reinforced Plastic Composites Seminar 

October 16, 2002 

Keith Barnett, Project Lead 

Office of Air Quality Planning and Standards 

Emission Standards Division 

Minerals and Inorganic Chemicals Group 
P.3 

Outline 

Who is subject to this standard? 

What operations are covered? 

What ifl manufacture fiberglass boats or 

boat parts? 

When do I have to comply? 

What are the major changes to rule since 

proposal 

Am I a new or existing source? 

What standards must I meet? 

How do I calculate emission factors? 

How do I achieve 95 percent control? 

What are some of my options to meet 

standards? 

How do I demonstrate initial compliance? 

2 
P.4 

Who is subject to this standard? 

• You are subject to this standard if 

you: 

- Manufacture reinforced plastics 

composites at a facility that is located at 

a major source (10 tpy of any one HAP 

or 25 tpy of any combination of HAP): 

and 

- Use thermoset resins or gel coats that 

contain styrene 

• You are not subject to this standard 

if you: 

- Use less than 1.2 tpy of styrene 

containing resins and gel coats, or 

- Only perform research and 

development, or 

- Only repair reinforced plastic 

composites 
P.5 

What operations are covered and 

have some type of control 

requirements? 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination/Casting 

SMC/BMC Manufacturing 

Pultrusion 

Mixing 

Storage 

Equipment Cleaning 
P.6 

What operations are covered, 

and have no requirements? 

Application of mold sealing and release 

agents 

Mold stripping and cleaning 

Repair unrelated to your manufacturing 

operations 

Materials that do not contain resin or gel 

coat 

Personal activities not part of 

manufacturing operations 

Prepreg materials 

Non-gel coat surface coatings 

Research and development operations 
P.7 

What if I Manufacture Fiberglass 

Boats or Boat Parts? 

You are subject to the Boat Manufacturing 

NESHAP onlv if you manufacture boat 

hulls or decks, or molds for boat hulls or 

decks 

If you are not subject to the Boat 

Manufacturing NESHAP, you are subject 

to this rule if you meet applicability 

requirements regardless ofthe end use of 

the parts 

If you are subject to the Boat 

Manufacturing NESHAP, but make parts 

that are not part ofyour boats, the non-boat 

operations are subject to this rule 

You may elect to place all operations under 

the Boat Manufacturing NESHAP if that 

results in equal or lower HAP emissions 
P.8 

When do I have to comply? 

Proposal was August 2, 2001 

Final rule publication date is part of 10 

year MACT settlement negotiations 

Existing major sources must comply within 

3 years 

New major sources must comply by 

effective date of final rule or startup, 

whichever is later 
P.9 

Major Changes to Rule Since 

Proposal 

The above-the-floor requirements have 

been dropped for existing open molding, 

pultrusion, SMC and BMC manufacturing, 

and mixing operations 

The point value equations have been 

replaced with the appropriate unified 

emission factor (UEF) equations 

We have revised existing source MACT 

floors based on comments received on the 

proposed rule 

- Two floors will require a slightly lower 

HAP content, three are slightly higher 

- We have combined the filled and 

unfilled noncorrosion resistant 

mechanical resin application operations 

types 

8 
P.10 

What is a new Source? 

You commenced construction after 

August 2, 2001; and 

When you commenced construction, there 

were no reinforced plastic composites 

operations at the facility 

Note that the definition above includes 

moving an existing facility (We are 

overriding the General Provisions 

concerning moving sources) 
P.11 

What is an Existing Source? 

Any source that is not new 

Existing sources are not considered new as 

a result of reconstruction 

10 
P.12 

What is the 100 tpy HAP 

Emission Threshold and How Is 

It Determined? 

Sum organic HAP emissions from the all 

operations potentially subject to 95 percent 

control prior to any add-on controls 

For existing sources this is: 

- Centrifugal casting 

- Continuous lamination/casting 

For new sources this is: 

- The two operations above, and 

- Open molding 

- Pultrusion 

- SMC and BMC manufacturing, 

- Mixing 

n 
P.13 

What is the 100 tpy HAP 

Emission Threshold and How Is It 

Determined? 

• Calculate these organic HAP emissions 

using 

- Emission factor equations in the rule 

(which are based on the UEF) 

- Other published emission factors 

- Site specific factors if based on 

emission test data 

12 
P.M 

Draft MACT for All Sources 

Below the 100 tpy Threshold 

Operation 

Type 

Open 

Molding -

Corrosion 

Resistant 

and/or High 

Strength 

(CR/HS) 

Open 

Molding -

Non-CR/HS 

Open 

Molding -

Shrinkage 

Controlled 

Resins 

Specific 

Operation 

Mechanical resin 

Application 

Filament 

Application 

Manual Resin 

Application 

Mechanical resin 

Application (Filled 

or unfilled) 

Filament 

Application 

Manual resin 

Application 

Mechanical resin 

Application 

Filament 

Application 

Manual Resin 

Application 

Emission 

Limit 

(lb/ton) 

112 

171 

123 

87 

188 

87 

354 

215 

180 

Allowable 

Resin HAP 

Content 

46.2 NonAtomized 

42 

40 

38.4 NonAtomized 

45 

33.6 

50 

Atomized 

50 

50 

13 
P.15 

Draft MACT for All Sources 

Below the 100 tpy Threshold 

(Con't) 

Operation 

Type 

Open 

Molding -

Gel Coat 

Specific 

Operation 

Tooling Gel 

Coating 

Pigmented Gel 

Coating-White 

and Off White 

Pigmented Gel 

Coating -

NonWhite 

Clear Production 

Gel Coating 

CR/HS or High 

Performance Gel 

Coating 

Fire Retardant 

Gel Coating 

Emission 

Limit 

(lb/ton) 

437 

267 

377 

522 

605 

854 

Allowable 

HAP Content 

(Weight %) 

40 

30 

37 

44 

48 

60 

14 
P.16 

Draft MACT for All Sources 

Below the 100 tpy Threshold 

(Con't) 

Operation 

Type 

Open 

Molding -

Tooling 

Open 

Molding -

Low Flame 

Spread/Low 

Smoke 

Products 

Centrifugal 

Casting 

Specific 

Operation 

Mechanical 

Resin 

Application 

Manual Resin 

Application 

Mechanical 

resin 

Application 

Filament 

Winding 

Manual Resin 

Application 

Non-CR/HS 

CR/HS 

Emission 

Limit 

(lb/ton) 

254 

157 

497 

270 

238 

20 

25 

Allowable HAP 

Content 

(Weight %) 

50+ Nonatomized 

43 Atomized 

45.9 

60 

60 

60 

37.5 

48 

15 
P.17_ 

Draft MACT for All Sources 

Below the 100 tpy Threshold 

(Con't) 

Injection/Compression Molding - Cover 

Charges 

Resin Transfer Molding - No 

Requirements 

Continuous Lamination and Casting - 58.5 

percent control 

Polymer Casting - No Requirements 

16 
P.18 

Draft MACT for All Sources 

Below the 100 tpy Threshold 

(Con't) 

Pultrusion - 60 percent control or wet area 

enclosure (except for large parts) 

Sheet Molding Compound - Nyloncontaining film, cover resin delivery to 

doctor box 

Equipment Cleaning - Cleaning materials 

may contain no HAP (except for closed 

systems) 

Resin Mixing and BMC Manufacturing -

Cover the mixers 

Resin Storage - Cover storage containers 

17 
P.19 

Draft MACT for Existing Sources 

at or above the 100 tpy Threshold 

For existing sources that emit 100 tpy or 

more of HAP combined from 

- Centrifugal Casting 

- Continuous Lamination/Casting 

The requirements are 95 percent control of 

the operations listed above 

The requirements for all other operations 

are the same as facilities below the 

threshold 

18 
P.20 

Draft MACT for New Sources at 

or above the 100 tpy Threshold 

• For new sources that emit 100 tpy or more 

of HAP combined from 

- Open Molding 

- Centrifugal casting 

- Continuous lamination/casting 

- Pultrusion 

- SMC/BMC Manufacturing 

- Mixing 

The new source MACT is 95 percent 

control ofthe operations listed above 

Operations not listed above must meet the 

same requirements as existing sources 

19 
P.21 

How do I Calculate Emission 

Factors? 

Equations are presented in the rule, and are 

identical to current unified emission factors 

published by the CFA. 

Resin use may be based on purchase 

records if you can reasonably estimate how 

the resin is applied 

Resin HAP content may be based on 

MSDS or resin specification sheets 

Emissions are based on organic HAP 

content 

We have added provisions for normal 

manufacturing tolerances 

20 
P.22 

Example Emission Factor 

Calculation 

• Open molding - mechanical resin 

application - nonatomized - noncorrosionresistant 

- Resin HAP content (from MSDS) is 36 

percent 

- Emission Factor (EF) equation is 

• EF = ((0.157)(%styrene)-.0165)x 

2000 

• EF = ((0.157)(0.36)-.0165) x 2000 

• EF = 80 

- Draft final MACT is 87 

- This meets MACT 

• Do not consider catalysts or promoters 

• Do consider any additional monomer 

addition 

21 

/ / / 
P.23 

How do I achieve 95 percent 

control (if required)? 

• Enclose operations requiring 95 percent 

control with a permanent total enclosure 

• Design and operate enclosure in 

accordance with EPA Method 204 

• Install and operate a 95 percent efficient 

control device 

- Concentrator/oxidizer 

- Thermal oxidizer 

- Catalytic oxidizer 

• If you do not use a permanent total 

enclosure, you must test for capture 

efficiency, and overall capture and control 

must be 95 percent or more 

22 
P.24 

Options to Meet Standards 

Open Molding and Centrifugal 

Casting 

You may average open molding 

operations, and separately average 

centrifugal casting operations (12-month 

rolling average) 

All operations of a specific resin type (CR, 

Non-CR, and Tooling) may use the same 

HAP content resin 

Operations subject to 95 percent control 

have alternative point value limits 

You may change compliance options 

23 

. * .* r * 

/ .' **'" 
P.25 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 1 

Change all your resins and gel coats to 

ones with HAP contents below the 

standard 

This is the simplest method and results in 

the least reporting and record keeping 

24 
P.26 

Meeting P2 Standards 

Option 1 Example 

Prior to MACT 

- Atomized application of 45 percent 

HAP noncorrosion-resistant resin 

- Atomized application of a 35 percent 

HAP white gel coat 

After MACT 

- Nonatomized application of 38 percent 

HAP noncorrosion-resistant resin 

- Atomized application of 30 percent 

HAP white gel coat 

- If nonatomized gel coat application is 

possible, allowable HAP content will 

be higher 

25 
P.27 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 2 

Change your resins and gel coats so the 

weighted average meets MACT 

Requires purchase records by resin type, 

and monthly average calculation 

Average is based on last 12 months of 

operation 

Average is weighted based on resin use 

over that period 

26 
P.28 

Meeting P2 Standards 

Option 2 Example 

Prior to MACT 

- Currently use two noncorrosion 

resistant resins, one 37 percent HAP 

and one 42 percent HAP 

- nonatomized mechanical application 

- ratio of resin use is 60/40 

after MACT (Emission limit = 87) 

- convert the 42 percent HAP resin to 

resin with 40 percent HAP or less 

- maintain same 60/40 split 

27 
P.29 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 3 

Determine the highest resin HAP content 

allowable for each operation 

Use this resin for all operations 

Can not include gel coats or mix corrosion 

and noncorrosion resistant operations 

28 
P.30 

Meeting P2 Standards 

Option 3 Example Prior to MACT 

making corrosion-resistant tanks 

using atomized mechanical (end caps), 

filament winding (body), and manual 

application (joining parts) 

using 50 percent HAP resin 

29 
P.31 

Meeting P2 Standards 

Option 3 Example After MACT 

Determine MACT for each operation 

- Mechanical is average of 46.2 percent 

HAP resin with nonatomized 

application 

- Filament winding is 42 percent HAP 

resin 

- Manual is 40 percent HAP resin 

Select highest allowable average HAP 

level (46.2 percent) 

Maintain this average resin HAP content 

for all corrosion-resistant operations 

30 
P.32 

Options for Meeting Standards 

Pultrusion 

Wet area enclosures, preform injection, or 

direct die injection to meet the 60 percent 

reduction requirement 

You may average across different 

machines for both percent reduction and 

times that covers or doors are open 

For averaging purposes, direct die injection 

and preform injection are assumed to 

achieve a 90 percent HAP emission 

reduction 

31 
P.33 

Options for Meeting Standards 

Continuous Lamination/Casting 

Can average lines 

Existing sources can elect to control only 

wet out area emissions by 95 percent 

Can meet an alternative emission limit of 

14.7 lb/ton (58.5 percent control level) or 

1.47 lb/ton (95 percent control level) 

32 
P.34 

How Do I Demonstrate Initial 

Compliance for a PTE? 

Determine the equivalent diameters of all 

NDO and exhausts 

Determine the equivalent diameters of all 

NDO from HAP emission points and 

exhausts from NDO (must be at least four) 

Measure PTE surface area (AT) and NDO 

surface area (AN). The ratio of AT/AN 

must 0.05 or less. 

35 
P.35 

How Do I Demonstrate Initial 

Compliance for a PTE (Con't)? 

• Verify direction of flow is inward for all 

NDO using streamers, smoke tubes, or 

tracer gases 

• If FV is 500 or more, inward flow 

verification is not required 

37