p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

89) ll-E-49 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:06 AM Sheet 89 of 264 
P.2 

A-94-52 

• l-£-l|f 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: October 2, 1996 

P:/N504 

:;$^^''i.,:i*'$$#>'d :-V . 

SUBJECT: Minutes of July 29, 1996 Meeting Between EPA and Representatives of the 

Pultrusion Industry Council 

LOCATION: EPA/Mutual Building, Durham, NC, 11th floor conference room, 

8:30 am - 10:30 am 

ATTENDEES: 

Mr. John Barker 

Mr. Larry Connors 

Mr. Nelson Douglass 

Mr. Jim Gauchel 

Mr. Tom Griffiths 

Ms. Linda Herring 

Mr. Greg LaFlam 

Mr. Walt McSherry 

Mr. Ken Meardon 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

MMFG 

Liberty POLYGLAS 

Reichhold Chemicals 

Owens-Corning 

Omega Pultrusions 

EPA/ESD 

PES 

Omega Pultrusions 

PES 

PES 

SPI/Composites Instimte 

EPA/ESD 

(540) 645-8129 

(412)466-8611 

(919) 990-8256 

(614) 321-7724 

(216) 562-5201 

(919) 541-5358 

(919) 941-0333 

(216) 562-5201 

(919) 941-0333 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

PURPOSE 

The meeting was requested by the Pultrusion Industry Council (PIC) to discuss the 

following three topic areas: 1) PICs latest MACT rule proposal, 2) EPA's MACT floor for 

new pultrusion sources, and 3) the additional PIC Phase II test data requested by EPA. 

/ 
P.3 

Madeleine Strum 

October 2, 1996 

Page 2 

DISCUSSION 

PICs MACT Proposal for Pultrusion 

To begin the meeting, each participant introduced him- or herself, and Messrs. 

Connors and Gauchel identified themselves as the newly-elected Chairman and Co-Chair, 

respectively, of the PIC. Mr. Griffiths then stated the three principal aims of the meeting 

(as listed above under Purpose), and proceeded to describe the PICs suggested MACT 

proposal for the pultrusion industry (see Attachment 1). 

The PIC proposal consists of four provisions. Mr. Griffiths reviewed the first three 

provisions without any extensive discussion. These provisions include conservation vents 

for resin storage tanks, covers for mixing and transfer tanks and reservoirs, and a limit of 

0.015 lb of HAP solvent per lb of composite produced. 

The heart of the PIC proposal is contained in the fourth provision, which specifies 

an allowable maximum Pultrusion Emission Control Status (PECS) value for existing and 

for new sources. The PECS represents the total level of control from the following 

selected pollution prevention measures in use in the operation, as applicable: (1) direct die 

injection, (2) preform resin injection, (3) wet area enclosures for open baths, and 

(4) restricted airflow (< 15 fpm) across open baths. The PECS value is determined by 

weighting the effectiveness of the individual measures according to the amount of HAP 

monomer processed through each control. 

The PIC proposal considers four forms of pollution prevention measure (as noted 

above) and assigns a Control Factor, cf (i.e., the amount of emissions remaining after use 

of the technology) to each one. Under this scheme, the most effective of the four measures 

is direct die injection (cf = 0.01, or 99 percent control), followed by preform resin 

injection (cf = 0.15), wet area enclosures (cf = 0.41), and air flow management to 15 

ft/min or less (cf = 0.53). The proposal would allow any combination of these control 

measures, including areas with "no control" (cf = 1.00), as long as the overall PECS for 

the operation meets or exceeds the required MACT level, which was calculated by the PIC 

to be 0.68 for existing sources and 0.37 for new sources. 

Preform Resin Injection 

Mr. Griffiths described preform resin injection as being harder to define than direct 

die injection. He emphasized tiiat the 1 percent resin "leakage" permitted in the industry's 

proposed definition applies only to the area upstream of the saturation chambers. Resin 

drip-off from the wet reinforcement during and after the saturation step and from the front 

of the die would be permitted, and would not count toward the 1 percent limit. The length 

of exposed wet reinforcement in the direction of pull would be limited to no more than 15 

2 
P.4 

Madeleine Strum 

October 2, 1996 

Page 3 

inches. 

A discussion ensued concerning how this proposal corresponds to the conditions 

that existed in the PICs 1995 Phase II pultrusion study. Mr. Douglass noted that he could 

not recall the exact length of the wet-out area in the study (although it was probably about 

9 to 12 inches), but that the length used was specific for the profile run during the study 

(ladder rail). Certain profiles may need to have slightly longer wet-out areas. 

Ms. Proctor asked how a setup with a different profile could be compared to the 

results from the study. Mr. Griffiths agreed that this would be difficult to do in terms of 

developing a regulation. He did emphasize that the study was a commercial setup, and not 

just a test run. Ms. Proctor pointed out that the conditions in the definition should 

correspond to the experiment, because that was where the reductions were measured. She 

added that perhaps less reduction credit could be given for wetted lengths greater than 15 

inches. She also suggested that we should consider focusing more on defining or 

describing specifically what was done during the study rather than on quantifying what was 

done. Ms. Strum concurred, stating that we need to reexamine the actual test conditions 

for considering how to deal with preform resin injection. She emphasized the concern that 

the definition does not represent the production configuration that achieved the 91 percent 

emissions reduction. Mr. Barker said that they could obtain more information to describe 

what was done during the study. Mr. Gauchel explained that, in the 15 inches of wet-out 

area, the product goes from a flat form to the final shape before entering the die. During 

the study, a C-channel shape was created. More complex shapes may require additional 

preformers. He explained that in some instances some ofthe preformers may be located in 

the saturation chamber, although, typically, the preformer(s) is (are) located 3 to 4 inches 

downstream from the saturation chamber. From that point to the die, there is a one-layer 

form. Preformers downstream of the saturation chamber are never closed and some 

drippage occurs off them and the die. Mr. Gauchel noted that the drip pan is situated no 

more than 12 inches below the preformers. 

Mr. Griffiths stated that they would examine whether they could develop a 

description of preform resin injection more accurately reflecting the setup used for the 

Reichhold test. The revised description will "tighten up" the wording about the locations 

and amounts of resin drippage. Ms. Strum stated that she was concerned about the vertical 

drip distance and its effect on emissions. Mr. Douglass stated that he did not think the 

length of drip is important to the level of emissions. He said this distance is typically 

about 6 inches; facilities try to minimize this drop to prevent possible splashing of resin 

out of the drip pan. Industry also noted that sufficient space/distance must be provided to 

allow workers to access the area above the drip pan with their hands in case of jam-ups or 

breakage of the reinforcement. The participants discussed the possibility of limiting the 

amount of wet reinforcement surface area that may be exposed, but due to varying part 

widths and number of reinforcement layers, this approach was deemed complicated and 

3 
P.5 

Madeleine Strum 

October 2, 1996 

Page 4 

impractical. Ms. Strum suggested that the Control Factor for preform resin injection be set 

at the overall control status (PECS) required for existing sources, and then the standard 

would contain only a reasonable description of preform resin injection, without specific 

requirements for quantification of leakage. She thought this was what was suggested at the 

previous meeting with the PIC, and that attendees at that meeting were amenable to it. Mr. 

Griffiths stated that the PIC would go back and consider this as a group. 

A discussion was held concerning the air flow around the preform resin injection 

apparatus because styrene has been shown to evaporate more rapidly when the resin is 

exposed to higher air flow velocities. Mr. Gauchel stated that the air flow can be 

controlled, and the amount of closure for the collected resin can also be controlled. Mr. 

Douglass pointed out that during the study the resin was collected in a funnel underneath 

the small drip area with a hose at the bottom ofthe funnel to recycle the resin back to the 

process. He stated that this approach limited exposure of the dripping resin to air flow. 

He also said that total leakage was less than 1 percent. 

Mr. Griffiths noted that the tests were designed primarily to smdy air flow 

management, and they did not consider well enough how to define the operation (e.g., the 

amount of resin leakage). He also noted how difficult measuring backflow can be, as it 

varies with resin viscosity. 

Ms. Strum asked Mr. Barker about the conditions existing in MMFG-Bristol's 

preform resin injection setup. He stated that, while some aspects of the operation are 

considered proprietary, he would provide to EPA videotape of the production operation at 

MMFG. Mr. Barker also agreed to provide a quantitative description (surface area and 

amount) of the leakage (exposed to air) from the device used in the tests. 

Wet Area Enclosures 

Mr. Griffiths clarified that the radio frequency (RF) preheat unit referred to in the 

description of wet area enclosures is used to start the cure process for certain thick parts, 

and is well sealed to minimize radiation leakage. As a result, resin would not be expected 

to leak from such a unit. 

Ms. Strum asked whether the openings during the test had a 3/8-inch clearance. 

Mr. Douglass stated that for all incoming materials, hoses, etc. there was a 3/8-inch 

clearance. Mr. Griffiths pointed out that the size of the slots around the roving will vary 

with the weight of the roving (e.g., 1/2 ounce versus a 2 ounce roving). He said it is 

possible to describe what is coming into the enclosure and to set specific clearances, but 

that the proposed 3/8-inch specification was an attempt to simplify. He also noted that 

industry does not want to conduct operations poorly, so clearances will be what they need 

to be to provide a smooth production operation. SPI noted that clearances need to be large 

H 
P.6 

Madeleine Strum 

October 2, 1996 

Page 5 

enough to accommodate splices where that practice occurs. Mr. Griffiths felt that the 3/8-

inch clearance was sufficient to accommodate most reinforcements. Ms. Proctor asked 

about the possibility of specifying the size of the clearance as a percentage of the roving or 

reinforcement size. Mr. Griffiths pointed out that industry has information that relates the 

opening size to specific reinforcements, and could provide the information to EPA for 

review. 

Air Flow Management . 

In the discussion on air flow management, it was stated that the proposed 15 feet 

per minute or less air flow requirement would be considered to apply at 3 inches above the 

wet surface. 

The utility and practicality of the "puff of smoke" technique for measuring air flow 

was discussed, and some thought that this method may not be accurate or reliable enough 

for measuring the variable flows at many plants. Also, the smoke may dissipate too 

quickly to allow a determination to be made. Mr. Schweitzer agreed to research the 

applicability of smoke pencils for this purpose. The anemometer made by Solomat was 

described as having the ability to integrate variations in flow velocity and provide a stable 

reading at low flows. Mr. Schweitzer provided Ms. Strum with a copy of sales literature 

on the Solomat anemometer, but price information was not available (see Attachment 2). 

Control Factor Issues 

With regard to the proposed backflow limit for direct die injection of 5 lb of resin 

perhr, Ms. Strum stated that the actual backflow she observed in the PICs Phase II study 

appeared to be much less, perhaps 5 ounces per hour. Mr. Connors noted that the OwensCorning facilities in Europe operate with essentially no backflow, while their facilities in 

the United States have a certain percentage loss. Ms. Strum asked Mr. Connors if they 

could provide a write-up on what their company is doing. Mr. Griffiths stated that the 

system Mr. Connors referred to is preliminary. He also stated that he thought that the 

amount of backflow could be expressed as a percentage of the amount of resin passing 

through the die. Mr. Connors noted that if you "drop" some glass, you get a localized low 

pressure spot that results in a temporary higher backflow of resin. Mr. Griffiths stated that 

he would go back and look at the percentage backflow from the testing. He felt the intent 

was to get people to use direct die injection, but still believes preform resin injection is 

preferable to using the standard uncontrolled open bath configuration. Mr. Gauchel 

expressed concern that a backflow limit would not be met during startup and shutdown of 

the operation. Mr. Schweitzer agreed to obtain actual backflow rates for direct die 

injection semps engaged in ladder rail production. Ms. Strum asked about the feasibility of 

allowing unrestricted backflow, but requiring collection of all of the resin in a closed 

system. Mr. Gauchel replied that, for existing systems, space may not be available, but 

5 
P.7 

Madeleine Strum 

October 2, 1996 

Page 6 

would not be a problem for new systems. He stated that any die injection system will have 

some resin backflow, but that the amount could certainly be minimized. 

PECS Values 

In reviewing the industry's PECS calculations, PIC noted that their existing source 

PECS value is 0.68 on the basis of the five facilities that they know to be major sources. 

They noted that Creative Pultrusions is using air flow management; that Omega's Control 

Factor value is 1.0 and not really 0.68, because what they are currently doing does not 

meet the proposed defimtion that would give them the credit identified in the proposed 

averaging scheme; and that MMFG is at 0.98 because only a small part of what they are 

doing would receive any credit. Mr. Connors stated that the real state-of-the-art in the 

industry is closer to a 1.0 Control Factor than anything else. Mr. Gauchel pointed out that 

the 1.0 value is based on the definitions contained in the document and that a lot of what 

people are doing can be improved very quickly. Mr. Griffiths said that, for example, they 

would be able to reduce the length of the wet area in a preform resin injection setup to 

meet the industry's proposed definition (15 inches maximum). Ms. Proctor noted that, if 

the Tecton Products facility was added to the list of major facilities, the existing MACT 

floor would be 0.38 as presented in this document. 

New Source MACT 

Mr. Schweitzer asked for more information on the pultrusion operation at Tecton 

Products in Fargo, North Dakota (which the EPA visited in June 1996). Ms. Strum noted 

that Tecton is a pultruder, is pennitted for five lines, and has emission points typical of 

other pultruders (bath, drip, and die), and thus belongs in this subcategory. Mr. Griffiths 

stated that it was his understanding that Tecton controls both pultrusion and painting 

operations using an oxidizer. Ms. Strum noted that this was not the original setup, that the 

oxidizer operated at least 7 months without the painting operations, and that Tecton was in 

the process of asking the State if they could disconnect the painting operations from the 

oxidizer. She noted that the State has given their okay for this to occur. This facility uses 

total enclosures (per EPA's criteria) and a thermal oxidizer to control styrene emissions, 

and presumably could serve as the basis for EPA's new source MACT floor determination. 

Mr. Schweitzer indicated that industry is largely unfamiliar with Tecton's operation, but he 

believed that Tecton installed the incinerator to control emissions from both its pultrusion 

and its painting operations. Ms. Strum stated that the controls are in place principally for 

the pultrusion emissions, and emphasized that the company is planning to remove the 

controls from the painting operation with the State's approval. 

Mr. Schweitzer asked about the styrene concentrations that exist within Tecton's 

enclosures, and whether they meet the OSHA worker exposure limits. He also asked 

whether workers could enter the enclosures and whether the enclosures encompass the 

^ 
P.8 

Madeleine Strum 

October 2, 1996 

Page 7 

roving and mat creels. Ms. Strum stressed that much of the details of the operation are 

considered confidential business information (CBI) by Tecton, but that the North Dakota 

permit and the test report for the incinerator could be supplied to provide information 

about the system. Mr. Schweitzer asserted that EPA should not rely on CBI data in setting 

MACT floors, since this will limit industry's ability to fully evaluate the control 

technology. He felt that this control technology may not be available to other pultrusion 

operations, and that the industry needed more information so that it could evaluate the 

feasibility of this form of control. He also felt that certain lines may be able to use 

enclosures, while others may not. Pultrusion could therefore be shut out of some markets 

if an enclosure/control device standard were enacted. Mr. Griffiths agreed that he could 

not evaluate the feasibility of enclosures based on what he knew. Mr. Schweitzer 

requested blueprints and engineering specifications on Tecton's system. Ms. Strum agreed 

to provide non-CBI from the permit and test report, including styrene concentration levels 

both in the enclosure and in the inlet and exhaust of the incinerator. She stated that EPA 

considers the non-confidential information available for Tecton sufficient to support a new 

source floor of 95 percent control. 

Data from PICs Phase II Study 

A brief discussion was held concerning EPA's request to PIC for additional Phase 

II study test data that was not included in the study report. The PIC supplied the 

information (see Attachment 3) with the caution that it not be used to calculate emission 

factors for pultrusion, noting that the study was not designed to establish emission factors. 

Mr. Griffiths stated that certain data were subject to error and were not measured, such as 

the rate of styrene processed through the system. However, the calculation was estimated 

to be 8.5 lb of styrene processed per hour, with a minimum expected error of ±10 percent. 

He pointed out that line speed does not affect the time rate of styrene emitted, but does 

affect emissions expressed as a percentage of the total styrene entering the process. Mr. 

Griffiths said the test speed was 2 ft/min and, for a 4 ft/min speed, the emission factor 

would likely be a factor of 2 lower. 

ACTION ITEMS 

Follow-up activities agreed to by meeting participants: 

Party Action Agreed to 

1. U.S. EPA (M. Strum) Provide non-CBI information on Tecton's system to 

J. Schweitzer 

7 
P.9 

Madeleine Strum 

October 2, 1996 

Page 8 

2. PIC (J. Barker) 

3. PIC (J. Schweitzer) 

4. PIC (T. Griffiths) 

Attachments 

Provide photos of the PIC test setup and quantitative 

description to M. Strum 

Provide videotape of MMFG's preform resin injection 

setup to M. Strum 

Research the applicability of smoke pencils for 

measuring low air flows in pultrusion operations 

Obtain information on resin backflow rates in 

direct die injected ladder rail production and provide 

to M. Strum 

Revise PICs definition of "preform resin injection" 

based on the meeting discussion 

Go back and look at the conditions ofthe Phase II test 

and re-examine the assignment of a 0.15 control factor 

for preform resin injection 

Provide information on opening sizes specified for 

various types of reinforcement to M. Strum 

7 
. P.10 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:32:08 rage to n 

Attachment 1 

Pultrusion Industry Council 

MACT Standards for Pultrusion 

Proposal 

Resin storage 

Bulk resin storage tanks shall have conservation vents. 

Mixing and transfer tanks, and reservoirs 

Mixing and transfer tanks, and reservoirs at pultrusion machines, shall remain covered unless 

materials arc being added. Clearance of 3/8 inch per side shall be allowed for mixing shafts, 

fill-pipes, etc. 

Cleaning operations 

HAP solvent purchases (oilier llian reactive diluents or monomers) shall be no more than 0.015 

pounds per pound of composite produced. 

Pultrusion operations 

A Pultrusion Emission Control Status (PECS) shall be calculated monthly, for all pultrusion 

production for the previous 12 months. 

For existing sources, the 12-month-moving-average PECS shall not exceed 0.68.1 

For new sources, the 12-month-moving-average PECS shall not exceed 0.3 7.2 

1

 A PECS of 0.68 is the average PECS achieved in practice by the Werner Co.(p.38), Bedford 

Reinforced Plastics(1.0), Creative Pultrusion(0.37), Omega(0.65), and MMFC(0.98) facilities (located, 

respectively, in Franklin Park, III., Bedford, Pa., Bedford, Pa., Aurora, Ohio, and Bristol, Va.). These 

five facilities are the only pultrusion major sources known to the Pultrusion Industry Council. 

2

 A PECS of 0.37 is the control achieved in practice by the besNoontrolled of these fadlities 

(Creative Pultrusions, Bedford, PA). 

1 pictmact003/)uly 22,1990 

7 
. P.11 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:32:35 Page 3 of 9 

4.1. I he PhCS is the weighted average of the Control l-actors for each of the control technologies 

employed during the reporting period. The Control Factors are weighted by die amount of 

styrene (or other HAI* monomer) processed with each of the control technologies. 

The formula for calculating PrCS is as shown: 

Where PECS = Pultrusion Emission Control Factor 

spt= amount of styrene or other HAP monomer processed, for each control 

technology 

. cft = control factor for each control technology 

4.2. Control Technologies 

For pultrusion, MALI is any combination of direct die injection, preform resin injection, wet 

area enclosures, air flow management, and "no control,'' as long as the PECS meets or exceeds 

the required level. Other control methods may be employed, as long as the source can 

demonstrate, to die satisfaction of its permitting authority, that such other methods achieve a 

level of emission reduction at. least, as stringent, as the MACT. 

Direct die injection is a pultrusion system in which the reinforcement, enters the application 

system dry. Wet reinforcement is not exposed to air prior to being cured in die die. 

Preform resin injection is composed of reinforcement saturation (wet out) chambers. The wet 

out occurs within the enclosed chambers by pressurized resin mixes transferred to the chamber 

without air exposure. After exiting the saturation chambers, the wet reinforcement may be 

exposed to the air, but a maximum exposure of 15 inches of wet reinforcement along the 

direction of pull is permitted. 

Leakage or drip-off of excess resin is permitted at the saturation chambers, along the 

wet reinforcement, and at the die. However, leakage from the saturation chamber shall be 

no more than 1 % of die resin processed. (Example: if a pultrusion line processes 100 pounds 

of resin per hour, then no more than one pound per hour may leak from the saturation 

chamber.) Shrouds, covers, and/or odier devices may be provided around the saturation 

chambers to prevent contact of wet resin with air, and to collect leaked resin and return it to 

the reservoir. Only resin exposed to freely moving plant air shall be considered as leakage. 

Wet area enclosures are designed to prevent die contact of free-flowing air with wet resin. 

The enclosure will be designed to cover the top, bottom, sides, and ends of the area in which 

reinforcements are wet out, and die area in which wet reinforcements are moving toward the 

die. The enclosure will be fit to the die entrance or radio frequency (RF) preheat unit. A 

covered resin bath may function as part of the endosure. Access panels, doors, hatches, or 

flexible curtains shall be considered part of ihe enclosure provided they are designed to fit. 

There will be no open flow of resin into or out of the endosure. 

Openings to allow dry reinforcement to enter the endosure may be no larger tiian the 

dimensions of those reinforcements plus 3/8 inch. Ports for level control devices, monitoring 

2 pictmact003/)uly 22,199C 

/o 
P.12 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:33:18 rage4oi» . . 

devices, agitation shafts, fill hoses, etc., shall have ho more dian 3/8 inch per side dearance. 

Appropriate measures shall be taken to protect personnel from exposure to hazardous 

atmospheres. 

Air flow management, is comprised of any combination of shields or covers, air curtains, or 

general ventilation design, which maintains an air velodty of 15 feet per minute or less at three 

inches above the wet. reinforcement 

Air flow is measured by one of two methods: 

1. A puff of smoke is released from a smoke pendl 3 inches above the exit from 

the resin bath, and the distance travelled by die puff in 4 seconds is measured. 

Repeat this measurement at 3 inches above the entrance to the die, and at 3 

indies above the midpoint between the bath and the die. The average 

distance (ravelled by die diree smoke puffs in 4 seconds shall not exceed 1 

foot (1 foot in 4 seconds is 15 feet per minute.) 

2. I he probe of a hot-wire anemometer is held three inches above the exit ofthe 

resin bath, and slowly rotated for one minute. The instrument takes readings 

every second, and the average for the one-minute period is recorded1. I he 

measurement is repeated at the center ofthe wet area, and at die entrance to 

the die. The average of these three readings shall not. exceed 15 feet, per 

minute. 

\Solomat. Model MPM 500E Anemometer (or equivalent) will perform the one-second sampling 

and one-minute-averaging. (Solomat telephone: 800-765-6628.) 

3 pictmact003fluly22,1996 

ll 
— — — , P.13 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:33:46 Page 5 of 9 

4.3. Control Factors 

For each control technology, the Control Factor represents the amount of emissions remaining 

after use of the technology, compared to uncontrolled operations.4 In general, the Control 

Factor for a given technology is calculated by die formula: 

. _ Emissions wtth control technology 

' Emissions without control 

For example, if the emission rate from an uncontrolled operation was 0.92 pounds styrene per 

hour, and if the emission rate from production of the same part using a Wet Area Endosure 

was 0.38 pounds styrene per hour, dien: 

cf = P-H - 0.41 Jw 0.92 

For Direct Die Injection with less than 5 pound per hour backflow, the Control Factor shall be 

0.01. Tor Direct. Die Injection with backtiow of 5 pound per hour or more, die Control Tactor 

shall be calculated widi the formula: 

* B Ibsjhour bacfifiow 

******* Ibslhour total resin processed 

The Control Factor for Preform Resin Injection is 0.15. 

The Control Factor for Wet Area Endosures is 0.41. 

The Control Factor for Air Flow Management to 15 ft/rniri or less is 0.53. 

I he Control l-actor for "no control" is 1.0. 

"The Control Factor is not useful in estimating total emissions, since most of the styrene processed 

polymerizes and remains in the part. Rather, the Control Tactor is only an estimate of the ratio of 

controlled to uncontrolled emissions. 

4 pictmact003/July22,1990 

ll 
P.M 

From: John Schweitzer To: Madeleine Strum Cite: 7/22/96 Time: 12:34:12 rage o OT a 

4.4. Example PfcCS Calculation 

Assume that for the most recent 12 month period, a pultrusion fadlity has run the following 

products widi the Control Technologies shown: 

Product. 

A 

B 

C 

D 

E 

Totals 

Control 

Technology 

Die injection 

Preform injector 

Wet Area Endosure 

None 

Air Flow Management 

Control 

Factor 

0.02 

0.15 

0.41 

1.0 

0.53 

Lbs.Styrene 

Processed 

1,750 

5,000 

3,000 

1,500 

2,000 

13,250 

cf x sn 

350 

750 

1,230 

1,500 

1,060 

4,890 

Then die PECS5 for litis 12-motilh period would be as shown: 

PECS 4,890 

13,250 

0.37 

5This is not an emissions estimate; see Footnote 4. 

pictmacL003/July 22,199G 
P.15 

JOHN SCHWEITZER "511 66 8 470 9 p.e i 

WERNER CO. 

To 

Office 

Subject 

N.K. Cray 

Asst. General Mngmnt. 

Solomat Hotwire Anemometer -

Air Flow Measuring Instrument 

Inter-Office Correspondence 

Attachment 2 

0aie June 14,1996 

Jrorn G- Nosch G*-y *-fr' 

Office Want Eogineering 

CnfMS t.O J.Schwciteer 

AnjFM?W ftffiASTKffiMElSTS (PWmVSIQNWT-QT O 

Po^ptipn.Of Instrument; 

A Hotwire Anemometer (air flow measuring instrument) made hy Solomat, Model* MPM SOOB 

with Hotwire Probe, Model* 129MSX (See Attachments) 

Measurement Prgreforfr. 

The tip ofthe hotwire probe is held vertically 2" - 3" above glass mat at three locations. 

1) Entrance to die. 

2) Between die entrance Jind wet-out tank. 

3) Over wet-out. tank* 

The hotwire probe is slowly rotated about center to pick up varying air drafts or currents. Meter 

has automatic averaging feature and the measurements wc made over one minute. Averaging 

features include one sample per second. 

/•-*• 

Special Note; 

Accuracy of thesft types of insuun'ents are very low at low air speeds. For instance, 

below 30 rpm. 

posMrFa* 

GN/ani2 

9S«B1 oc. M unf 200-d CZl-l 0' S9P6SSt*804t 

H 
P.16 

JOHN SCHWEITZER 7 1 ? 66 8 470 8 P . 8 2 

X 

I 

s 

v 

V 

s 

500e Specifications 

DtSPLAYi 4H digit Uquid Crystal Display (LCO*: lcnw c*$t • decimal poK vwtoily, kw. Iwllwy, fidrAiwn, maximum and wim synDois. 

ami englreering unit ara displayed, ^* 

Features indude: leading zero suppression, autoranginj. two Vspby chock1 mono*, SLY* m v rods. 

SPECIAL FEATURES: MIN/MAX: Minimum and merinup- •neasuiemerna oT twnuwuiure, iwmidny, pressure and alrspcao or WM are 

.«^"|Mica|yaorea Tne four MIN and tour MAX memor.-s can De reviewed using the MIN/MAX and SYM80LS switches 

SYMBOL The SYMftrtl s^hselacktheenglmu^irttnr^tywofmsas^mcn t 

AVERAGE The average of a continuous AM of measurements • an be calculated by the processor. Wu AVQ swittJi Uuaue stats fl« averaging 

peitod,Twoohamels-Mn*iedvwc^irt)ieH^^ 

caicutetMandrjispi-rystliema-^^ 

DISPLAY HOLD- l/T) ran ne trozsn* using IWs push witch. Display •«t^lrnst6•norr^*:, mod. »*en HOLD ewRehte released. 

DISPLAY HOLD/ALTERNATCi Switch sdeeb ccostsnt monito; ar eUvnatlng temperature/metturcingi it mode. 

Battery Type* 9 tmif AWI* . stm PW (NPDA 1604) 

Battery Life: 12 io 23 hours of continuous use: 

depends on typo of measurement From 1 to 4 hours usage 

after BAT symbol »w**-> 

AG Po*arwiri-£ Input via (lie 500c 2.1mm OCwcKst (posltr s up). 

IK rout WAI* 7 to lZVlx; 100mA raSnj-, double insulated. 

PRESSURE 

Range/ 

Resolution: 

Sensor2aro 

Tempcoltyp): 

511IPX 

±30.000 in I \_0 

£7000 Pa 

± 1.000 PSID 

OOainH^C 

2Pe/°C 

512HPX 

.00/150.0C?SIG 

-000/io.oco Bar 

Usaga Condition*; 0,/50*cp2,/iaoTH<80XRH| 

Storage Conditions -20V+65X1-57180*H witnout twtery 

-20"/55*C t-S,/130T)«*h battery (<KH RH» 

Dimensions: 253 x 92 x 40mm (IO- x 3.G" x 1.0) 

Weight: 550e (19iod with Battwy. 

Ma^ofcCaKbimpectttsfatartAOOv^inte^danAiv^ 

steel arUHnen BrecKet Case ts vi&ttr resaaM, not wateiproof. 

513LWX 

±150.00 In H^O 

S2000 0 Pa 

± 5,000 PSIO 

.04hH,0/»C 

lOPa^C 

514HWX 

.00/300.0 FSIO 

,000/20.000 6ar 

515BPX 

.0000/1.1500 mbar 

.0000/15.00 PSIA 

.02-nbar/^ 

mpsm 

J3020er/°C 

.oispa^c 

.001Bar/°l 

• riW«Q * MfiQUfluai * mil ATARI fi TrMPfRA-fllftfS ff KM YRW^SAnjISffO AT THE USAGE TQyir*EMIU-|£ 

Temperature range: -10"/70**c, 14*/160? Accuracy mainlined: 0*/50*C 

Senior linearity and Hysteresis {2S<Ck .1* FS |tvp) JM K> (max) PITOT 

Rangft/Rosolutiort LW100/)Oni/s 

300^0000 ft/irin 

Pitot Accuracy: Pitot static airspeed measurements have errors from 

6 aourcea* (!) Pitot static lubes are t-fpiwIV ±0,5% siceuwe 

|2) Ue SOOe EiiMitzes the pressure meesuran-icrrt to airspeed -.or o 

contermvsoooiicatio-icf ±lX(ma)QoItrte reading. 

$ Tha 5MV» measures pressure to (typically) sOilX toressure Wfl 

accuracy ot tow pressures {assuming correct lerotag of the toner). 

(4) The 500B cuwetts ft* 0 e effect of temperature changu tc the ptot 

WuatJon (Separate from sensor temperature compensation) orny I the 

"a^be^meawr1rigtempp^atura(5]Tlv>500e(toesi*otcc,Tectto 

static pressure In the Pitot equation, but tho manual explain* how to 

irate this (usually small) CWIGCUUH. 

Pitot Tompeet Pressure eansor temperai-im drift rterwnds nr. tha 

efaspeed. A! 20Ws. the typical drift ta *.3 m/eTC with a maximum 

drift of 1.0 m/sTC. iWs drift is better at I("^airspeeds, ** WMSe a t •** 

step***. This drift can be compietery compensated by ZtfoKfllW 

censor at the tragi temperature. 

TKERMOCOllPt F/PtlOOTYPEK 

Sensor: 

Ratife/Resolution50fa Accuracy: 

Confom ihy* 

Cold Junction (2S°Qi 

Temperature Error 

GiuiiidAlumtilflQ. 

Therrtotoufra 

OIN 43710 

-80.(T/1270iO*C 

-IIO.OV220OY 

£17% reading 

irci-Bowo 

rcuw/m . 

9FW\WtiLttt_ 

irr 

iiz-xriimf) 

#CQPr) 

JXtT 

moo 

PiatmuniRTD 

(Ft IOO) 

DIN437r**r-/RSt<30* 

-90O*/800.<rc 

-co.<rMm 

L^rdgnMOlution: 

j02SXreadirai 

£Sfi"9S.'tVX.'f) 

mwrmrr. 

JXrig 

(C0OB/O0O<tC. 

?0OVl30Otj 

M/A 

.OOWRSTC 

KOTWIREWAfJ 

50flo Accuracy. 

Conformity: 

MS/CNX 228MS/GNX 

.«FS J0S*KS 

jOSirWs N/A 

1 ft/mm 

IIUMlOnY 

%RKfenge& 

ftesuhrtloiv 

SftOdfteairaey: 

TbUHCoofueniity. 

226RHX 

10.0/70.0 

JXRH 

OX 

355RH/356RH/ 357RH/35BRMX 

.0/100.0 

3XKH 

OX 

RPM 

Semen 

Range/Resolution: 

Accuracy/ 

Conformity: 

»nwix 

InfrarodRghtwith 

oMargct indicator 

30.0/20000 

(Autoranjind 

427TMX 

(tvtirtiue 

30.U/200UU 

(Autorwigiftg. 

.02X 

DEWPOIKT 

Dewpolnt Ranee & -asrmjrc 

RwUrticm -27D°/19£.0If 

Uewolnt Conformhy. (induding wmor and MPM COOe 

Bwfermity errors) lXt2^trticaL2*^r^->\fna)dmumwri8n 

irtMwrina condaona en h*NiMn \f « -md WX RH (-Kf/oOTi 

or30»te9t»niH6tf^X«). 

RS50& RS232 OUTPUT OPTION 

Interface Type-. 1*32320. bidi/ttttonaf ASOl 

Format • 7/8 bits. odd/«venwriry, U2 aop wts 

Baud Rats *-VlW/O00/<"00/1200/4800/9600 

Handsfnldne XON/XpFFnrS-WtreCrS/KIS 

HOWOT Options: li mterfaco and OOOe ccflftiuow CN 

2) Interface continuous ON, SOOe •sleep" mo 38 

S) IntMfam MWI fiOOfl: *steeo' mode. 

Features: Selea 1 of 32 tiiwi ids wEUi MX units. Control ALL .wlteh 

functor** and MIN/MAVAVEXAQC features via titrfac*. 

AN500-. ANALOG OUTPUT OPTION 

±1.00 VDC (1mA max)-

SOiiV/bUOuV per dl([it switch selectable. 

Ranfifc 

RMetaKtcn: . 

Conneetors: 35m m jack SOCKot fposltlvo tip): analoa out 

Subiiiluialuie coaxial socket; flags PtlOO output 

«nen SOUe is in 'ALT£ftNATC mode. 

SWo Switch: Autonnge override. 

A N I ANALM wma t OPTION 

Provides r«o channel itmullaneous output fioiti MPM 50OVAN5OO 

system ^ tha Ati tHNAit mooe). 

oosix 96. t>i unr 90Q-d S2A-1 0TT-J OBtDlHD eQNiHn <;«5tr6fi<;trR0iI 

/ . < 
JOHN 9CHI.IE1T2CR 

P.17 

Z l ? 6,6.9 470 8 P.O ? 

•—>-. 

Anemomerer n vues 

Precis-en »in>petx) measurements are vttfti for those mv.tfved 

In heating and ventilation, air conditioning. f>l*nt mainf-oar-co 

and laboratories. 

The hot wire probe menitort the cooling of a hot wire o« 

thermistor to measure airspeed, while tne vane probe 

electronically monitors ihe rotational tyeed nf a small 

propollat*. 

The small proba az9 and fast response of tho hot wiro r-^hc \t 

ideal for monitoring slow air flows, e.g. dr«fl detection if, clean 

rooms and small ducts. Two hotwire probes are available; your 

choice is between the standard 127 or the more versatile 129; 

select either the telescopic 129M3X or Uie flexible lZSOm for 

measuring airflow in difficult or inaccessible placw. 

I he traditional vana orobe Incorporates a njggwJ ronstr*)rtinn 

with special low friction bearings. Choose either the 28SMSX 

with telescopic latiUle uf Use 2S8QNX wilh flexible sha*! for 

measuring overhead ducts and difficult to reach spots. 

* 

i4W-76Si6lrt 

\ 

127MSX HOTWIRE: Fact raeponca, compact probe decign 

arid low speed sensitivity *How easy checking of drafts, fur- •> 

hoods and human comfort conditions. 

1WM0X . •a^-w-.o 

~ - 'r ' 3*>iAtDll»B«d 2Wr.«ittendedi -I* * 

129GNX 

.••ek »i»A 

•j^a^^^^axa^ 

1*%* . 

129 HOTWIRE With last response and low speed sensitivity 

this prebe is Ideal for tha 0-2500 ft/min r^ntf. ijnscrew ths 

protective ca§a and the sensor is nearly omnidirectional. 

The telescopic handle 129MSX gives oxvi length for 

mnnitfirlrig ducts white ths 1?9GNX fte<ihl« shaft allows ac 

ccw to overhead grlHc work. 

228MSX 

V

JV; if* 

* r v 

}*•»'*. t9tW<4 5»»-»«ft^9*« 

. . .*Hi. 

220GNX , ^ 

• tots 160 in 

228 YANfc: witn a rugged design of stelnio* *ie*l body, 

tung^an wirr-ide shaft and sapphire bearings, this probe ••, 

best to* high speed/high accuracy mewurf mentl and 

where ambient piea-juies vary (e,g. ducting ta high-rise 

buildings). This anemometer can withstand shock ano 

abuse. Th« 228MSX tdaseopic handi* wllapses to a comt*ti stepi for easy transport The flexible 229GNX allows 

access to overhead grille work. The detachable 04 1 is a I 

mater oxtontfon f c bnth the 129GNX and 228GNX. Riving 

•yen greater reach whan you need It. Sa« aeeessnries P*g* 

Sensor 

RjnjeUlr»P»»iJ)tfw'l 

fc/Wa-

'wl- (T*mperehw) 

Wllll'ClB/J 

utam. 

ItlltR 

Tnermlitor 

•HOtWirt' 

.01/1200 

2/2*00 

32e/125«F 

£M 

U3MSI/6HX 

Thennlswr 

•KotWifO" 

.01/12 00 

2/2*00 

3*7125'F 

3%KtXii.05 

2m sunflaw. Otne/ langiiw: 

22IMHSM 

Vnr« 

.05/40. X) 

IOLW-.TO 

u-n>*.-f 

2**RDG±20 

special OR. :i 
_ . P.18 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:34:31 rage / oi 9 

Attachment 3 

July 29,1996 

To: Madeleine Strum, US EPA 

Fr: John Schweitzer 

Re: Pultrusion Industry Council Phase II Emission Study 

In response to your request the Pultrusion Industry Council is pleased to provide the 

information shown below. 

As you know, this information was not included in the report of the Phase II study, and its 

omission was not an oversight. Rather, the PIC was concerned that the data would be 

misused. The Phase II study was designed to determine the relative effectiveness of various 

source reduction technologies, and to determine what concentration and quantity of styrene 

might be collected in a close capture device. 

The Phase II data is not suitable for use in calculating emission factors for pultrusion. To 

generate data for calculation of emission factors, the study would have included consideration 

of air flow conditions typical of a commercial pultrusion operation, changes in line speed, part 

geometry, configuration ofthe wet reinforcement and the drip pan of exposed resin. The 

processing experience of our member companies also indicates that styrene evaporates from 

the system on a regressively sliding scale and an extension of the time period would definitely 

be required. We know from this study and again from the experience of our members that 

these factors could have a significant impact on the total time weighted emissions of a facility 

and the emission factors derived from same. 

The reporting period being discussed for the MACT standard regarding the Pultrusion Emission 

Control Status is monthly. This timeframe may result, in lower emission factors than were 

experienced during this controlled experiment We also know from this study that these 

control factors have very significant impacts on emissions and emission factor calculations. 

No single study can replicate the wide variability of commercial pultrusion operations. The 

Phase II study nevertheless does give us some useful information about, the relative effects of 

several source reduction technologies. In reality there is no "typical" pultrusion line, because 

of wide variability in the speed, air flow, part geometry, wet-glass configuration, etc. Because 

of this fact emission factors must be determined on a per site basis. 

I he PIC is providing this data in the spirit of cooperation with you in the preparation of a 

MACT standard. We respectfully request that you do not distribute this data beyond those 

at EPA who arc directly involved in the MACT development process for pultrusion. The PIC 

hopes that you understand their concern that this data cannot accurately be used to 

determine an emission factor for the purpose of ascertaining whether or not a pultrusion 

facility is subject to I itle V permitting. 

.mem 

n 
From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:35:14 

P.19 

Page 8 of9 

rom the report ofthe Phase II study: 

*dhn. 

PIC Phase II 

Run 

A,AA(avg.) 

U,UU (avg.) 

| -,.« ,, ; 

G 

H 

1 

J 

Styrene 

emilled — 

Ibs/hr 

0.91 

0.72 

* 0.30 

0.66 

0.09 

0.01 

0.49 

l2 

stru2976.mem 
. P.20 

From: John Schweitzer To: Madeleine Strum Date: 7/22/96 Time: 12:35:31 Page 9 of 9 

PIC Phase II Lmission Study — Styrene Calculation 

MMFG - Ladder rail profile 

Measured weight/ft.: 0.6447 lbs 

Calculation of fiber content by weight: 

100 (113 yield roving) x 0.00295 lbs. (wt. of 1-113 yield roving - 1 foot long) = 

0.295 lbs/ft .^ ^ 

Continuous strand mats: 5.75 in. + 5.25 in. + 5.25 in. widths = 16.25 total width 

16.25 in. x 0.0052 lbs (wt. 1 oz csm 1 in x 12ihf^O.d045 lbs/ft 

Total fiber weight/foot . 0.3795 lbs

 >? s ^ ^ ?tt* ** 

Calculation of resin mix content by weight: *'«*«-£ I \. 

0.6447 (profile wl/fool) - 0.3795 = 0.2652 lbs. 

:» • M t 

Calculation of styrene content, by weight: -KtK- '!*"<»% 

Total weight of resin mix = 124.5 lbs. •-.m^m «*-. 

Base resin = 99 lbs @ 32.6% styrene + I Ib additional styrene (to dissolve 

Percadox16) 

99 lbs / 124.5 lbs. = 79.52% (resin in mix) 

79.52% x 0.2652 (resin wt) - 0.211 lbs (po!yester*tesin per foot) 

0.211 lbs x 32.6% (styrene in base resin) = 0.0687136' lbs/ft 

1 lb/ 124.5 lbs = 0.8%styrene •"••«•* ;*' 

0.8% x 0.2652 (resin wl.) = 0.00212 lbs. addilionahslyrene (lo dissolve P-16) 

0.068786 lbs/ft + 0.00212 lbs/ft = 0.070906 lbs/ft ..(total styrene per 1 ft length of 

profile) ...,..,. j^ . 

0.070906 lbs/ft x 2 ft/minute pull rate = 0.1418 Jbs^nin 

0.1418 Ibs/min x 60 minutes/hr = 8.51 lbs (styrene processed per hour) 

Base on the above calculations, the estimated styrene processed per hour is 8.5 pounds. 

This calculation is by no means exact, and may be subject, to error of ± 10% or more. 

• • •: -.^aemt • • 

•,r«W*A*K fc 

'' •'<! ', w& 

•'• Hdw azsy 

• •••' \'": U*«e i ' 

•••• r:rvm. 

';••" ! H « • 

,** ' ' ferafr< 

..; 1 i U&rt. 

. • ' (| Tt' 

stru297C .mem 

'i