p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

37) 11-1-37 

Docket Number: 

A-94-52 

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P.3 

•.' V n .. . tow.-, ->5- •*• 

* y*r£''$S '•;• NORTH DAKOTA 

STATE DEPARTMENT OF HEALTH 

AND CONSOLIDATED LABORATORIES 

ENVIRONMENTAL HEALTH SECTION 

August 9, 1993 

John Jambois, President 

Tecton Products 

4401 15th Avenue NW 

P.O. Box 2712 

Fargo, ND 58108-2712 

Re: Air Pollution Control 

Permit to Operate 

Dear Mr. Jambois: 

1200 Missouri Avenue 

P.O. Box 5520 

Bismarck, North Dakota 58502-5520 

Fax #701-221-5200 

The Department issued a Permit to Construct on September 9, 1991, 

to Tecton Products for a window and door lineals plant located in 

Fargo, North Dakota. On July 15, 1993, the facility was inspected 

by Department personnel. Also on July 15, 1993, a compliance test 

was conducted at the facility. The test report for the compliance 

test which was received by the Department on August 5, 1993, 

indicates compliance with the applicable requirements. 

Based on our review of the permit application, the Air Quality 

Effects Analysis, the Permit to Construct, the results of the 

inspection, and the results of the compliance test, the Department 

hereby issues a Permit to Operate for the source. The Department's 

issuance of the permit is contingent upon compliance with 

applicable sections of the North Dakota Air Pollution Control Rules 

as well as the attached conditions. Please review each condition 

carefully and note the restrictions placed on the source. 

If you have any questions, feel free to contact this Department. 

Sincerely, 

£.flfo£, 

Gary D. Helbling & 

Environmental Engineer 

Air Quality Management Branch 

Div. of Environmental Engineering 

GDHrgsh 

Ene: 

xc/enc: EPA, Denver 

xc: Bill Delmore, Legal Counsel 

Paul Govig, EDC 

Community Health Center, Fargo 

Environmental Health Section 

and Enforcement 

701-221-5150 

Environmental 

Engineering 

701-221-5188 

Municipal 

Facilities 

701-221-5210 

2L 

Waste 

Management 

701-221-5166 

Water 

Quality 

701-221-5210 SL 
P.4 

•NORTH-DAKOTA. 

STATE DEPARTMENT OF HEALTH 

AND CONSOLIDATED LABORATORIES 

ENVIRONMENTAL HEALTH SECTION 

AIR POLLUTION CONTROL 

PERMIT TO OPERATE 

1200 Missouri Avenue 

P.O. Box 5520 

Bismarck, North Dakota 58502-5520 

Fax #701-221-5200 

Pursuant to Chapter 23-25 of the North Dakota Century Code, and the Air 

Pollution Control Rules of the State of North Dakota, and in reliance on 

statements and representations heretofore made by the owner designated 

below, a Permit to Operate is hereby issued authorizing such owner to 

operate the source unit(s) at the location designated below. This Permit 

to Operate is subject to all applicable rules and orders now or hereafter 

in effect of the North Dakota State Department of Health and Consolidated 

Laboratories and to any conditions specified below: 

1. Owner: 

A. Name 

Tecton Products 

B. Address 

4401 15th Avenue NW 

P.O. Box 2712 

Fargo, ND 58108-2712 

2. Permit Number 

M93001 

3. Installation 

Window and Door Lineals Plant 

4. Installation Location 

4401 15th Avenue NW 

Fargo, North Dakota 

Cass County 

5. Expiration Date: 

August ••'• 2 OV* 1996 

6. Source Unit(s): 

A window and door lineals plant consisting of the following equipment: 

1. Five pultrusion machines, Pulstar Models 804 and 1606. 

2. Mixing room and resin bulk tank room (4-6,000-gallon storage 

tanks). Resin consists of unsaturated polyester resin with 

styrene and methyl methacrylate. 

3. One matslitter, Pulstar Model 7824 

4. Five cut-off saws. 

5. Tool and die room. 

6. One paint booth. 

Environmental Health Section 

and Enforcement 

701-221-5150 

Environmental 

Engineering 

701-221-5188 

Municipal 

Facilities 

701-221-5210 3 

Waste 

Management 

701-221-5166 

Water 

Quality. 

701-221-5210 3 
P.5 

Page 2 of 4 

Permit No. M93001 

The facility will utilize the following air pollution control 

equipment: 

v •• •• ..-•-.•• • ... . £ 

1. ..Thermal oxidizer for the control or volatile organic compounds. 

The exhaust for the catalytic oxidizer will be vented to the 

outside air. 

2. Cartridge filter collection for the control of particulate matter 

(fiberglass). The exhaust for the cartridge filter collection 

will be vented back into the building. 

CONDITIONS 

7. A. Emission Limits: Emission limits from the operation of the major 

source unit(s) identified in Item 6 of this Permit to Operate 

(hereafter referred to as "permit") are as follows: 

Source* Air Emission 

Unit Contaminant Limit 

•Thermal Oxidizer Styrene 0.528*lb/hr 

Methyl Methacrylate 0.102 lb/hr 

Odors 2 Odor Concentration 

Units 

•The thermal oxidizer must also control volatile organic compound 

emissions by at least 95M 

B. Fugitive Emissions: All reasonable precautions shall be taken by 

the owner/operator to prevent and/or minimize fugitive emissions 

to the outside air from the operation of the source unit(s) 

identified under Item 6. 

C. Emission Inventory Reports: Emission inventory reports including, 

but not limited to process information regarding the amount and 

types of air contaminants emitted shall be submitted to the 

Department, upon request, on forms supplied by the Department. 

D. Source Operations: The owner/operator shall operate the source 

unit(s) described in Item 6 of this permit in accordance with 

statements, representations, procedures and supporting data 

contained in the initial application, and any supplemental 

information or renewal applications) submitted thereafter. 

E. Alterations, Modifications or Changes: Any alteration, rebuilding, 

repairing, expansion, change in the method of operation, or change 

of location of the source which results in the emission of an 

additional type or greater amount of air contaminants or which 

results in an increase in the ambient concentration of any air 

contaminant, must be reviewed and approved by the Department prior 

to the start of such alteration, rebuilding, repairing, expansion, 

change in the method of operation, or change of location. 

* 
Paqe 3 of 4 

Permit No. M93001 

11 in nn uav anhhorlio fho 

P.6 

v 

F. Nuisance or Danger: This permit s 

maintenance of a nuisance or a danger to public health or safety. 

G. Malfunction Notification: The owner/operator shall notify the 

Department of any malfunction which can be expected to last longer 

than twenty-four hours and can cause the emission of air 

• (*ff contaminants in violation of applicable rules and regulations. 

/ H. "^Storage Tanks Requirement: The proposedthree-way ballvalve for 

•a • flVentinq-emissions from the storage-mtanks,*"'-t;o',"',thewox'i'd*izer*-->S'hal*lii'be 

A-fr""*-', installed-by September 15, 1993. 

ii/>yri i. Permit Renewal and Invalidation: This permit shall be effective 

from the date of its issuance until the date specified in Item 5 

unless sooner suspended, revoked or surrendered. Application for 

renewal of this permit shall be submitted sixty days prior to such 

expiration date. The Department shall approve or disapprove the 

renewal of the permit within sixty days of receipt of the renewal 

application. 

J. New Source Performance Standards: The owner/operator must comply 

with all requirements outlined in 40 CFR Part 60, Subpart V W -

Standards of Performance for Polymeric Coatings of Supporting 

Substrates Facilities. 

K. Change of Ownership: This permit may not be transferred and is to 

be returned to the Department upon the destruction or change of 

ownership of the source unit(s), or upon expiration, suspension or 

revocation of this permit. 

L. Right of Entry: Any duly authorized officer, employee or agent of 

the North Dakota State Department of Health and Consolidated 

Laboratories may enter and inspect any property, premise or place 

at which the source listed in Item 3 of this permit is located at 

any time for the purpose of ascertaining the state of compliance 

with the North Dakota Air Pollution Control Rules. The Department 

may conduct tests and take samples of air contaminants, fuel, 

processing material, and other materials which affect or may affect 

emissions of air contaminants from any source. The Department 

shall have the right to access and copy any records required by the 

Department's rules and to inspect monitoring equipment located on 

the premises. 

M. Other Regulations: The owner/operator of the source unit(s) 

described in Item 6 of this permit shall comply with all State and 

Federal environmental laws and rules. In addition, the 

owner/operator shall comply with all local burning, fire, zoning, 

and other applicable ordinances, codes, rules and regulations. 

N. Permit Issuance: This permit is issued in reliance upon the 

accuracy and completeness of the information set forth in the 

application. The conditions of this permit herein become, upon the 

effective date of this permit, enforceable by the Department 

pursuant to any remedies it now has, or may in the future have, 

under the North Dakota Air Pollution Control Law, NDCC Chapter 23-
_P7 

Page _4_ 

Permit No. 

_ of 4 

M93001 

25. Each and every condition of this permit is a material part 

thereof, and is not severable. 

FOR THE NORTH DAKOTA STATE 

DEPARTMENT OF HEALTH AND 

CONSOLIDATED LABORATORIES 

Date J> my ry. 

Dana K. Mount, Director 

Division of Environmental 

Engineering 

G io 
P.8 

AIR QUALITY EFFECTS ANALYSIS 

OF 

MARVIN WINDOWS 

WINDOW AND DOOR LINEALS PLANT 

FARGO, NORTH DAKOTA 

CASS COUNTY 

FOR 

AIR POLLUTION CONTROL 

PERMIT TO CONSTRUCT 

AUGUST 1991 

Division of Environmental Engineering 

North Dakota State Department of Health 

and Consolidated Laboratories 

1200 Missouri Avenue, Room 304 

Box 5520 

Bismarck, ND 58502-5520 

* 1-
Table of Contents 

P.9 

List of Tables P'S'".'?? 

List of -Eigu^es-.7^.^^ 

Part 1 Proposed Project 

1.1 Project Description 

1.2 Applicable Air Pollution Control Rules 

1.3 Executive Summary and Recommendations . . 

Part 2 Cohtrol Technology Review 

2.1 Findings 

2.2 Allowable Emissions 

2.3 Expected Emissions 

Part 3 Analysis of Impact on Air Quality ... . 

3.1 Overview 

3.2 Ambient Air Quality Analysis 

3.3 Summary . 

Appendix A Permit Application and Supplemental 

Information 

Appendix B Proposed Permit to Construct 

Appendix C Proposed Permit to Operate 

Appendix D Policy for the Control of Hazardous Air 

Pollutant Emissions in North Dakota 

(Air Toxics Policy) 

Page 

ii 

iii 

1 

1 

4 

7 

10 

10 

12 

15 

17 

17 

18 

21 

t 
P.10 

List of Figures 

Page 

Figure 1-1 Plant Location 2 

Figure 2-1 Process Flow Diagram 11 

ii °\ 
P-11 

List of Tables 

Page 

Table 2-1 Expected Emissions 16 

Table 3-1 Maximum Predicted Concentrations 24 

iii 0 
P.12 

Part 1: PROPOSED PROJECT 

1.1 PROJECT DESCRIPTION 

An application for a Permit to Construct for a window and door 

lineals plant to be located in Fargo, North Dakota was felled with 

the Department on July#l^ 1991:r

;by Marvin>Windows . A copy of the 

application is included in Appendix A. 

The door and window products are produced by a process called 

pultrusion, where fiberglass reinforcing material is pulled through 

a resin bath, is saturated and enters a heated die where the 

polyester is cured into a hardened lineal shape which is then cut 

to length by a cut-off saw. The plant will be located in the 

NW 1/4 of Section 34, Township 140N, Range 49W, of Cass County, 

North Dakota. More specifically, 15th Avenue and 44th Street NW, 

Fargo, North Dakota. 

The location of the plant is shown in Figure 1-1. The plant will 

operate 24 hours per day/;rS^dayS;:.-per;.week, 50 weeks, per year. 

Air contaminants emitted to the atmosphere will consist of volatile 

organic compounds emissions (styrene, methyl methacrylate and a 

small amount of acetone). 

The facility will consist basically of the following process 

equipment: 
P.13 

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FOR SAIC BY U S GCOlOGlCAt SU»VCY. OCNVCR. COiORAOO 9099%. OR RC«TON VIRGINIA 77W 

ANI> SIAIC WAICR COMMISSION. lUSMAHCHNONIH llAKOIA "ktfeOI 

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1. PUlctTru#!IiSln^ 

and 5 total within 2 years)t 

2. Mixing room and resin bulk tank room (4-6,000 gallon storage 

tanks). Resin consists of styrene and methyl methacrylate. 

3. One matslitter, Pulsar Model 7824. 

4. Cut-off saws (2 initially and 5 total within 2 years). 

5. Tool and die room. 

The facility will utilize the following air pollution control 

equipment: ' 

1. Catalytic oxidizer for the control of volatile organic 

compounds. The exhaust from the catalytic oxidizer will be 

vented to the outside air. 

2. Bagfilter for the control of particulate matter (fiberglass). 

The exhaust for the bagfilter will be vented back into the 

building. 

13 
P.15 

1.2 APPLICABLE AIR POLLUTION CONTROL RULES 

1.2.1 40 CFR Part 60; Subpart VWtfeE Standards of Performance for 

Polymeric Coating of Supporting Substrates-Facilities, 

The federal standard applies to any facility which conducts coating 

operations and any on-site coating mix preparation equipment used 

to prepare coatings for the polymeric coating of supporting 

substrates and which begins construction, modification, or 

reconstruction after April 30, 1987. The process, which will be 

conducted at, the proposed Marvin Windows facility, is subject to 

this subpart. 

1.2.2 Chapter 33-15-12 - Standards of Performance for New 

Stationary Sources 

This chapter will apply to the proposed facility at such time as 40 

CFR Part 60, Subpart V W is incorporated into the North Dakota Air 

Pollution Control Rules. 

1.2.3 Chapter 33-15-02 - Ambient Air Oualitv Standards 

The facility will not emit any criteria pollutants which are 

subject to a specific ambient air quality standard as outlined in 

this chapter. However, this chapter has a section that states the 

ambient air shall not contain other air contaminants in 

concentrations that would be injurious to human health or wellbeing or unreasonably interfere with the enjoyment of property that \ M 
P.16 

would injure plant or animal life. The Department may establish, 

on a case-by-case basis specific limits of concentration for these 

contaminants. 

To satisfy this section of Chapter 33-15-02, the Department 

utilized the Policy for the Control of Hazardous Air Pollutant 

Emissions in North Dakota (Air Toxics Policy). This policy serves 

as a mechanism to evaluate emissions of hazardous substances from 

a given source and determine what control measures, if any, are 

appropriate. A copy of the Air Toxics Policy is included as 

Appendix D. 

The substances which will be evaluated in accordance with this 

policy are styrene and methyl methacrylate (see Part 3). A small 

amount of acetone will be used (less than 200 gal//ir) for cleanup 

purposes. Acetone emissions will be minimal and, therefore, not be 

evaluated with the Air Toxics Policy. 

1.2.4 Chapter 33-15-03 - Restriction of Emission of Visible Air 

Contaminants 

All emission points vented to the outside air at the facility are 

required to have an opacity less than or equal to twenty percent 

(20%) . 

15 
P.17 

1.2.5 Chapter 33-15-07 - Control of Organic Compounds Emissions 

The emissions of organic compounds gases and vapors is restricted, 

except from an emergency vapor blowdown system or emergency relief 

system, unless these gases and vapors are burned by a flare, or an 

equally effective control device as approved by the Department. 

1.2.6 Chapter 33-15-14 - Designated Air Contaminant Sources. 

Permit to Construct. Permit to Operate 

This chapter states that certain source categories are designated 

as air contaminant sources and are required to obtain an Air 

Pollution Control Permit to Construct and Operate from the 

Department. Surface coating operations, which the Marvin Window 

facility will conduct, is one of the source categories listed as an 

air contaminant source. Therefore, Marvin Windows is required to 

obtain an Air Pollution Control Permit to Construct and Operate for 

the facility. 

1.2.7 Chapter 33-15-16 - Restriction of Odorous Air Contaminants 

Emissions of objectionable odorous substances are restricted to two 

odor concentration units outside the property boundary. 

io 
P.18 

1.3 EXECUTIVE SUMMARY AND RECOMMENDATIONS 

Marvin Windows has applied to the North Dakota State Department of 

Health and Consolidated Laboratories for a window and door lineals 

plant to be located in Fargo, North Dakota. 

Th^^lan ^ * be a major source^*:E.;ofjfsEiany^sregulated;;:;-alr 

contaminant. Volatile organic compounds (VOC) will be emitted. 

As a result of the amount of VOC used and emitted, the plant is 

subject to 40 CFR Part 60, Subpart V W - Standards;,of:,-Performance 

for-Polymeric Coating of Supporting Substrates Facilities. 

Specific emission rates of volatile organic compounds were 

evaluated as outlined in the Policy for the Control of Hazardous 

Air Pollutant Emissions in North Dakota (Air Toxics Policy) and the 

North Dakota Air Pollution Control Rules. 

The Department has determined from its review of the application 

that the technology proposed to control emissions from the plant, 

a catalytic oxidizer for VOCs and a baghouse for particulates, is 

acceptable and the emission rates will comply with the emission 

rate reduction standards specified in 40 CFR Part 60 Subpart VW , 

the Air Toxics Policy, and the North Dakota Air Pollution Control 

Ruies. 

The Department conducted air quality dispersion modeling of the 

styrene and methyl methacrylate emissions from the proposed plant 

to predict the impact on air quality. Both styrene and methyl 

methacrylate are classified by the State of North Dakota as Group 

1> 
P.19 

3 hazardous air pollutants, i.e., substances which are not 

carcinogenic or for which there is insufficient data to establish 

evidence of carcinogenicity, but which nevertheless cause adverse 

health effects at high enough concentrations. Each Group 3 HAP is 

associated with a Maximum Acceptable Ambient Level (MAAL) for 8-

hour and/or 1-hour averaging periods. A maximum ground-level 

concentration less than its corresponding MAAL requires no further 

review by the Department, whereas a maximum ground-level 

concentration which exceeds its corresponding MAAL requires further 

review by the Department to determine if emission controls or 

ambient monitoring are necessary. In addition, the effects of 

multiple Group 3 substances emitted from the same source are 

assumed to be additive. Therefore, for each Group 3 pollutant, the 

ratio of its maximum concentration to its MAAL is computed, and the 

sum of this ratio for all pollutants must be less than 1.0. The 

results of the dispersion modeling were compared to the maximum 

acceptable ambient levels (MAAL) as outlined in the Policy for the 

Control of Hazardous Air Pollutant Emissions in North Dakota (Air 

Toxics Policy). This comparison indicated that the impact from the 

emissions is well below the MAALs outlined in the Air Toxics Policy 

and the sum of the ratio is less than 1.0. 

The Department of Health and Consolidated Laboratories finds the 

Permit to Construct application to be complete and hereby provides, 

for public comment, an assessment and preliminary determination 

concerning the Marvin Windows' proposed plant. In view of the 

results of the evaluation, the preliminary determination of the 

Department is that a Permit to Construct be granted for 

8 IS 
P.20 

construction of the Marvin Windows' window and door lineals plant 

provided it is constructed in accordance with statements, 

representations, and information contained in the application and 

supporting documents. 

The proposed Permit to Construct is included as Appendix B. 

The proposed Permit to Operate is included as Appendix C. 

°i 
P.21 

Part 2: CONTROL TECHNOLOGY REVIEW 

2.1 FINDINGS 

i 

The primary air contaminants emitted will be volatile organic 

compounds consisting of styrene and methyl methacrylate. 

i 

The sources of these air contaminants from the plant will be the 

resin station, die station, bulk storage tank, and high dispersion 

mixer (see Figure 2-1). The air contaminants from these sources 

are vented to a central control device (catalytic oxidizer) with a 

minimum control efficiency of 95%. The exhaust from the catalytic 

oxidizer will be vented to the ambient air. Due to utilization of 

this control device, the emissions from the facility will comply 

with the applicable State rules and policies as well as the Federal 

rules. 

A small amount of acetone will be used (less than 200 gal/yr) for 

cleanup purposes. The acetone emissions will be collected and also 

vented to the catalytic oxidizer. Acetone emissions will be 

minimal. 

The sources of particulate emissions (fiberglass) will be the saw 

station and matslitter which are vented to a common baghouse (see 

Figure 2-1). The exhaust from the baghouse will be vented back 

into the building. Therefore, there will be no particulate 

emissions (fiberglass) vented to the ambient air. 

10 ao 
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PARIICUIAIES 

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(vented back into 

building) 

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P.23 

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2.2' ALLOWABLE EMISSIONS 

2.2.1 40 CFR Part 60. Subpart V W 

The standard for volatile organic compounds (VOC) as outlined in 40 

CFR Part 60, Subpart W V - Standards of Performance for Polymeric 

Coating of Supporting Substrates Facilities is as follows: 

1. Reduce VOC emissioris to atmosphere from the coating operation 

by^jfci^ reduction" standard); or 

2. Install, operate, and maintain a tpjtal enclosure around the 

coating operation and vent the captured VOC emissions from the 

total enclosure to a control device that is at least £ 0 

percent efficient (alternative standard). 

& 

/At>]y°. 3. For the on-site coating mix preparation equipment, vent the 

I ',•/„.-. VOC emissions to a 95% efficient control device. 

Marvin Windows has elected to install a catalytic oxidizer that is 

95 percent efficient; therefore, the facility will comply with the 

standards outlined in Subpart VW . 

2.2.2 Odor 

Chapter 33-15-16 of the North Dakota Air Pollution Control Rules, 

Restriction of Odorous Air Contaminants states no person may 

C7\CK 
P.24 

discharge into the ambient air any objectionable odorous air 

contaminant which is in excess of two odor concentration units 

outside the property boundary. 

The Handbook of Environmental Data on Organic Chemicals, Second 

Edition, indicates the odorw threshold ..^of*-..methyl -methacrylate is 

approximately 0.30 mg/m? and the odor ^threshold ofw styrene isapproximately 0.26 mg/m3. 

The facility will have a control device (catalytic oxidizer) for 

the control of volatile organic compounds with an efficiency of 

95%. Based on air quality dispersion modeling, the 1-hour and 8-

hour ambient concentration from the facility is expected to be 

0.0026 mg/m3 and 0.0018 mg/m3, respectively, for methyl methacrylate 

and the 1-hour and 8-hour ambient concentration from-the facility, 

for styrerile, is expected to be 0.13 mg/m3 and 0.094 mg/m3, 

respectively. These concentrations are all below the odor 

detectability limit mentioned previously for each pollutant. 

Given the expected control efficiency and the expected ambient 

concentrations, the facility should comply with the odor standard. 

The Department will conduct an inspection of the facility and 

conduct odor measurements, if necessary, to determine compliance 

with the odor standard. 

13 

93 
P.25 

2.2.3 Visible Emissions 

Chapter 33-15-03 of the North Dakota Air Pollution Control Rules, 

Restriction of Visible Emission of Visible Air Contaminants 

requires opacity to less than or equal to twenty percent (20%). 

The emissions which will be emitted from the facility are a vapor 

rather than particulate matter; therefore, the opacity will be 

negligible, if any. 

2.2.4 Control of Organic Compounds 

Chapter 33-15-07 of the North Dakota Air Pollution Control Rules, 

Control of Organic Compounds Emissions states that organic 

compounds gases is restricted, except from an emergency vapor 

blowdown system or emergency relief system, unless these gases and 

vapors are burned by a flare or an equally effective control device 

as approved by the Department. 

A catalytic oxidizer will be used at the facility with a control 

efficiency of 95%. The Department considers this control device, 

which is an incinerator, as equally effective as a flare, and 

therefore, the facility will comply with this rule. 

a4 

14 
P.26 

2.3 EXPECTED EMISSIONS 

2.3.1 Stvrene and Methvl Methacrylate 

Expected emissions for styrene and methyl methacrylate were 

calculated using EPA AP-42, Compilation of Air Pollutant Emission 

Factors, Section 4.12, Polyester Resin Plastics Product 

Fabrication, Table 4.12-2. 

The emission factor outlined in EPA AP-42 incorporates plant 

production rate to calculate the expected emissions. As allowed by 

Section 33-15-01-16 of the North Dakota Air Pollution Control 

Rules, Marvin Windows has requested that information on production 

feed streams at the facility be treated confidential. The 

Department has accepted this information as confidential; 

therefore, the actual calculations of the expected emissions will 

not be shown in this analysis. The Department has calculated the 

expected emissions using an EPA AP-42 emission factor of 5.5%. The 

results of the expected emissions calculations are summarized in 

Table 2-1. 

15 3£ 
P.27 

Table 2-1 

Expected Emissions 

Air Contaminant 

Styrene 

Methyl Methacrylate 

Lb/hr 

0.528 

0.102 

Ton/vr 

1.58 

0.31 

Hours ODeration/vr 

6,000 

6,000 

16 ac? 
P.28 

Part 3: ANALYSIS OF IMPACT ON AIR QUALITY 

3.1 Overview 

The Department has conducted a dispersion modeling analysis to 

evaluate the impact on ambient air quality of air pollutants 

emitted by the proposed Marvin Windows window and door lineals 

plant in Fargo. The manufacturing process will produce significant 

emissions of styrene and methyl methacrylate vented to the ambient 

air. Both pollutants are regulated as hazardous air pollutants 

(HAPs) by the State's Policy for the Control of Hazardous Air 

Pollutant Emissions in North Dakota. The purpose of the modeling 

analysis was to determine whether HAP emissions from the proposed 

Marvin Windows plant will comply with North Dakota's HAP control 

policy. 

Both styrene and methyl methacrylate are classified by the State of 

North Dakota as Group 3 hazardous air pollutants, i.e., substances 

which are not carcinogenic or for which there is insufficient data 

to establish evidence of carcinogenicity, but which nevertheless 

cause adverse health effects at high enough concentrations. Each 

Group 3 HAP is associated with a Maximum Acceptable Ambient Level 

(MAAL) for 8-hour and/or 1-hour averaging periods. A maximum 

ground-level concentration less than its corresponding MAAL 

requires no further review by the Department, whereas a maximum 

ground-level concentration which exceeds its corresponding MAAL 

requires further review by the Department to determine if emission 

controls or ambient monitoring are necessary. In addition, the 

17 

aT 
P.29 

effects of multiple Group 3 substances emitted from the same source 

are assumed to be additive. Therefore, for each Group 3 pollutant, 

the ratio of its maximum concentration to its MAAL is computed, and 

the sum of this ratio for all pollutants must be less than 1.0. 

Styrene and methyl methacrylate will be emitted at several 

different steps in the manufacturing process. At each step, the 

pollutant emissions will be collected into an overhead hood and 

vented into! a common catalytic oxidizer to control the HAP 

emissions. The catalytic oxidizer incinerates the pollutant 

emissions, reducing the emissions by 95%. After exiting the 

catalytic oxidizer, the resultant, controlled HAP emissions from 

all sources combined will be vented to the ambient air through a 

single stack. 

3.2 Procedure 

For modeling problems involving single sources, EPA recommends the 

use of screening models that include a simplified treatment of 

meteorology and are faster to use relative to more refined models. 

The purpose of a screening model is to provide a conservative 

estimate of air quality impact from a simple, single source using 

a minimum amount of resources and time. 

Because the Marvin Windows HAP emissions essentially constitute a 

single-source modeling application, the EPA-approved screening 

model SCREEN was utilized. SCREEN calculates concentrations at 

many downwind distances for a wide variety of possible 
P.30 

meteorological conditions (e.g., wind speed and atmospheric 

stability class) and determines the worst-case concentrations under 

worst-case conditions at any downwind distance. SCREEN 

incorporates the same mathematical algorithms as in other Gaussianplume models. Some of the special features of other, more refined 

dispersion models are also available in SCREEN, including treatment 

of elevated terrain and building downwash effects. 

Building downwash effects, the result of using a stack lower than 

Good Engineering Practice (GEP) height, tend to increase groundlevel concentrations from an elevated source because the turbulent 

flow around a building more rapidly transports the stack emissions 

to the ground. Since Marvin Windows' stack will be less than GEP 

height with respect to the process building, the stack will 

potentially be affected by building downwash effects. 

The SCREEN model requires input of certain source data and userselection of certain technical options. Source data required by 

SCREEN include pollutant emission rate, stack height, stack 

diameter, stack gas exit temperature, and stack gas exit velocity. 

To account for the effects of building downwash, the dimensions of 

the building adjacent to the stack must be input to SCREEN. Source 

and building data utilized for the Marvin Windows analysis are as 

follows: *.,„•: ~, _.-.• ... . Mf ••*': •'.•• "'' J' 

•sr- S*gK' sfe. » sfer .vv'^k.i- i ? >• ute-' *•••• -' Sf' 

, # - vf», s? JEE#'|' •# "

 <*';

'*" 

O, O Q 7 

Styrene emission rate = 0.67 g/sec! 

Methyl methacrylate emission rate = 0.013 g/sec 

Stack height vv..a^,<,.,,..:=;.J;P,.6.7.

 m ? 

19 3fl 
P.31 

= 

=S 

= 

= 

= 

= 

422'K 

10.06 m/sec 

0.66 m 

7.01 m 

77.72 m 

53.34 m 

""1 f f 

IS; 

1 

1; 

I 

l 

|Exit temperature 

£' 

t I Exit velocity 

tStack diameter 

I Building height 

jBuilding length 

I Building width 

Source input data were obtained from Marvin Windows' permit 

application. Building dimensions were obtained from plans provided 

by Marvin Windows. The pollutant emission rates reflect the 95% 

reduction in emissions accomplished by the catalytic oxidizer. 

Because the horizontal cross section of the building deviates 

slightly from a rectangular shape, the maximum building length and 

width were used in the modeling analysis. 

Since access to the building will not be restricted by a fence 

surrounding the plant, receptors (locations at which the model 

calculates pollutant concentrations) were included on Marvin 

Windows' property up to the plant building. The SCREEN model 

calculates concentrations at downwind receptors spaced every 100 

meters apart from the stack out to at least 1000 meters and with a 

larger spacing beyond 1000 meters. Because the terrain near the 

plant is relatively flat, characteristic of the Red River Valley, 

flat terrain was assumed in the modeling analysis. The maximum 

concentration was interpolated between the two receptors with the 

highest concentrations. 

20 
P.32 

Technical options input were basically the same as those normally 

applied in a more refined modeling analysis (e.g., gradual plume 

rise, stack-tip downwash, buoyancy-induced dispersion), consistent 

with EPA guidance. An ambient temperature of 293"K (default) was 

assumed (ambient temperature is the only meteorological variable 

that needs to be specified for SCREEN). SCREEN can be operated in 

either rural or urban mode. Because the proposed Marvin Windows 

site was a borderline rural/urban location, as defined by EPA for 

modeling purposes, SCREEN was executed both in rural and urban 

mode, and the higher of the two maximum concentrations was selected 

(rural mode produced the higher concentrations). Eight-hour 

average concentrations were estimated by multiplying the modeled 

maximum 1-hour concentrations by 0.7, a standard averaging-period 

adjustment factor. Because styrene and methyl methacrylate are not 

natural occurring and there are no nearby sources, background 

concentrations of zero were assumed. 

3.3 Results 

Results of the air quality modeling analysis for the Marvin Windows 

window and door lineals plant in Fargo are summarized in Table 3-1. 

Results are presented for both styrene and methyl methacrylate. 

The applicable Maximum Acceptable Ambient Level (MAAL) is provided 

for each averaging period for comparison with the predicted maximum 

concentrations. 

Table 3-1 shows that the maximum predicted styrene concentrations 

are well below the MAALs for styrene. The extremely small maximum 

21 "9 | 

3 I 
P.33 

predicted 8-hour methyl methacrylate concentration is far below the 

8-hour MAAL for methyl methacrylate and is actually less than 

1/1000 of the 8-hour MAAL. The maximum 1-hour and 8-hour styrene 

concentrations are 3.1% and 4.4% of their respective MAALs. The 

maximum 8-hour methyl methacrylate concentration is 0.04% of its 8-

hour MAAL. 

These concentrations expressed as percentages of their respective 

MAALs can be used to address the additive effects of styrene and 

methyl methacrylate, both Group 3 hazardous air pollutants (HAPs). 

The sum of the maximum 8-hour styrene and methyl methacrylate 

concentrations expressed as percentages of their MAALs is 

4.4% + 0.04% = 4.44% = 0.0444, 

which is less than 1.0, as required by the Department's HAP policy. 

The additive effect of methyl methacrylate is very minor because of 

its small concentration relative to its MAAL. 

Based on the above results, the styrene and methyl methacrylate 

emissions from the proposed Marvin Windows plant will comply with 

the Department's HAP policy and require no further review by the 

Department as Group 3 HAPs. 

Maximum concentrations are predicted to occur at a distance of 21 

meters from the stack, very close to the plant building. This 

would place the maximum concentrations near the northeast corner of 

the building, since the stack is located very close to the 

22 3a 
P.34 

northeast corner of the building. The s&£ong^bu4'ld4ng*»downwash 

effects are responsible for the maximum concentrations occurring so 

close to the building. Maximum concentrations will occur under 

conditions of strong winds and neutral atmospheric stability, 

typical of a cloudy, windy day or night. Under such meteorological 

conditions, the strong winds inhibit plume rise and bend the plume 

over to a relatively low height above the ground, producing high 

ground-level concentrations. 

33 
P.35 

Table 3-1 

Maximum Predicted Concentrations 

(mg/m3) 

Pollutant 

Styrene 

1-hour 

8-hour 

Methyl methacrylate 

1-hour 

8-hour 

Predicted 

Concentration* 

0.13 

0.094 

0.0026 

0.0018 

MAAL 

4.26 

2.13 

_ _ — _ 

4.1 

*A background concentration of zero was assumed. 

24 34 
P.36 

Marvin Windows 

Window and Door Lineals Plant 

Permit Application and 

Supplemental Information 

Appendix A 

Division of Environmental Engineering 

North Dakota State Department of Health 

and Consolidated Laboratories 

1200 Missouri Avenue, Room 34 

Box 5520 

Bismarck, ND 58502-5520 

35 
P.37 

.x PERMIT APPLICATION FOR AIR CONTAMINANT SOURCES 

•I NORTH DAKOTA STATE DEPARTMENT qf •CALTO - AIR POLLUTION CONTROL PR 

SFN 8516 (AP IOO-I) 5/85 

Fl ITY IDENTIFICATION 

Nt*-* of Firm -v Institution 

MARVIN WINDOWS 

Owner or Official to Contact on Air Pollution Matters 

CHARLES VANASSE 

Application Being Made By (Name): 

_ JOHN JAMBOIS 

Tlt. e 

•PRODUCT DEVELOP. 

Mailing Address (Street & No.) 

8043 24TH AVE. SOUTH 

Plant Location (Street & No.) 

15TH AVE. AND 44TH ST. NW_ 

Legal Description ot Plant Site 

{ ;. Section ATTACHED Twp. Rge. 

Land Area at Plant Site 

61.9 4 Acres (or) 2,698.106. 4 Sq. Ft. 

Titl e 

COO - TECTON PRODI 

City 

MINNEAPOLIS 

City 

FARGO 

Latitude (Nearest Second) 

46° 53' 32" _. 

MSL Elevation at Plant 

894.00 USGS 

Longitude (Nearest Secone 

96° 51* 28" 

Number Employees at Local 

45 WITHI N 2.YEARS _ 

GENERAL NATURE OF BUSINESS: 

DESCRIBE NATURE OF BUSINESS STANDARD INDUSTRIAL 

CLASS IFICATION NUMBEA 

PULTRUSION; A PROCESS PRCOUCING WINDOW AND DOOR LINEALS DURING WHICH 

A THERMOSET POLYESTER RESIN MATRIX I S REINFORCED WITH 

MISCELLANEOUS 

PIASTICS 3089 

FIBERGIASS MAT AND ROVING. 

SOURCE IDENTIFICATION AND CATEGORY OF EACH SOURCE INCLUDED ON THIS PERMIT APPLICATION: 

/ gn your Identification Number (1,2 , 

3 , etc. ) to each Source or Permit Unit. 

Lis t ID Number and Identify device 

below, then check appropriate category 

In the box to right of listed device 

YOUR 

IO 

NO 

JEL 

SOURCE OR UNIT 

(Equipment, Machines, Devices, 

BoiIers. Processes, Incinerators. 

Etc.) 

FTiTlE 

PULSTAR:804 5 TOTAL 

PULSTAR 1606 

MIXING ROOM 

RESIN BULK TANK ROOM 

PUISTAR 7824 - MATSLITTER 

CUT-OFF SAWS - 5 TOTAL 

TOOL AND DIE ROOM 

PERMIT TO CONSTRUCT 

M 

3 * 1 

8 5 6 2 25* 5 

fc|g S 

a 

ee 

8 

z 

_? 2 

— i/> 

a s 

5 l-r 8 5 

— UJ 

25 

PERMIT TO OPERATE 

a 

S51 

i— — 

25 

J- • o 

51 s I 

as £§ 

a s 

gfc 

ut a 

a * 

OT. . (Specify) 

2L 

(Continued) 
P.38 

SH 85)6 

IF APPLICATION IS FOR A PERMIT TO CONSTRUCT, PROVIDE THE FOLLOWING OATA: 

.Same of Installe r or Contrecto r 

MalIIn g Address 

Phone Nipper 

Star t Oote/Construc t ComoletEcrt Oat f 

SEPT 15, 1991 MAY 15, 1992 

EST IMATED 

Sf417; 

•i 

i 

(STO 

s 

/bbo-

;iooot 

COST 

•950, 

OF 

000 

EQUIPMENT OR MODIFICATIO N (FOR PERMIT TO CONSTRUCT 

BASIC EQUIPMENT 

AIR POLLUTION CONTROL EQUIPMENT EXISTING •*$ OF CUTE OF APP.. 

NEW AIR POLLUTION CCNTHX EQUIPMENT TO 3E INSTALLED 

MODIFICATION TO EXISTING AIR POLLUTION CONTROL EQUIPMENT 

ONLY) : 

ICATION 

IDENTIFICATION OF AIR CONTAMINANTS (Check all which are emltTed In measurabl e quer.t I • I _ s into 

atmosphere from any operatio n at this facility.) 

ACIDS 

ALKALIES 

ARSENIC " 

ASBESTOS L _ 

BERYLLIUM F _ 

CADMIUM &&. 

VISIBLE EMISSIONS 

CARBON MONOXIOE 

CH.ORINE CO*POUNDS 

OUSTS 

FLUORINE COWOUNDS 

FLY ASH 

HYDROCARBONS 

_ffl 

£ j 

HYDROGEN SULFIDE 

LEAD 

MERCURY 

NITROGEN CC+POUNOS 

ODORS 

ORGANIC CO^fOUNOS 

OTHER (SPECIFY) 

' I PAP.<\RTICULVfI I S 

PESTICIDES 

.ADIOISOTOPES 

SILICA 

SMOKE 

j SULFUR C>POUNt>S 

List Specific Compounds 

FIBERGLASS, FIBERGLASS AND CURED RESIN, STYKENE, ACETONE, METHYL METHACRYLATE 

I Has Source Testing Been Done 

1 At > Fact Ility?f~lYES JQ^NO 

Latest Date When a Testing 

Program was Completed: 

If Program is Continuous, Give Approximate 

Testing Frequency; 

INDICATE WITH "X" WHICH OF THE FOLLOWING FORMS ARE ATTACHED AND MADE PART OF THE APPLICATION 

XX 

• 

AP IOI FUEL BURNING EQUIPMENT USED FOR 

INDIRECT HEATING (SFN 8518) 

AP 102 MANUFACTURING OR PROCESSING 

EQUIPiMENT (SFN 8520) 

AP 103 INCINERATORS 

(SFN 8522) 

AP 104 GRAIN, FEED AND FERTILIZER 

OPERATIONS (SFN 8524) 

AP 105 ASPHALT CONCRETE PLANTS 

(SFN 8526) 

AP 106 CONCRETE BATCH PLANTS AND 

CEMENT HANDLING EQUIPMENT (SFN 8527) 

XX 

XX 

AP 105 ROCK, GRAVEL AND 3AND. 

PLANTS (SFN 8530) 

AP 109 GAS CLEANING 

EQUIPMENT (SFN 8532) 

AP 110 CONPLIANCE 

SCHEDULE (SFN 8534) 

AP H I AIR POL'.-TICN EMERGENCY 

EPISODE ?•_.».:: :Z7'.i zzoa 

AP 112 VOLATILE ORGANI C CC*FOUNDS 

STORAGE TANK (SrN 8535) 

AP 113 INTERNAL COMBUSTION ENGINE 

SOURCES (SFN 3SS>;) 

OTHER ATTACHMENTS ARE AS FOLLOWS AND ARE A PART OF THIS APPLICATION: 

XX 

( 

(AP117 APPLICATION FOR HAP SOURCES 

The undersigned applicant Is fully aware that statements made In this application and the attached exhibits and statements constitute the application for Permlt(s) to Construct and/or Operate Air Contaminant sources from the North 

Dak- State Department of Health and certifies that the Information In this application Is true, correct and complete 

to tne best of his knowledge and belief. Further, the undersigned agrees to comply with the provisions of Chapter 23-

of the North Dakota Century Code and all rules and regulations of the Department, or revisions thereof. He also understands the permit Is non-transferable and. If granted a permit, he will promptly notify the Department upon sale or 

legal transfer of the permitted establishment. 

Signed -OX c u*JiL_ 371

-

-__ .—,_.— _ 
P.39 

LEGAL DESCRIPTION 

Industrial Subdivision No. 3 

Lots 1, 2, 3, 4, 5; Block 14 

Lots 1, 2, 3, 4, 5, 6, 7, 8; Block 15 

Lot 1, Block 17 

Replat of Industrial Subdivision No. 3 

Lot 9; Block 15 

Lot 2; Block 17 

and adjacent street right-of-way of 16th Avenue Northwest and 44th Street 

Northwest, in the City of Fargo, County of Cass, North Dakota. 

^ 
P.40 

EMISSION POINTS (List eecr. point separately, number each and locate on attached flow-chart 

lumber 

1 

Stack MelcTt (Ft.) 

•^q-^Rp-r 

i n E T PK/PP vonv 

(miniimpl 

Stack Dia. (rt. at Top) 

? FY 7TT-T 

Ga^ VoT^ACTM) 

/10,75 4 

/Exit Temp 

300" 

L. 

Ca bas velocity ( s y i 

AIR CONTAMINANTS EMITTED - KNOWN GR SUITE D TM, +

 46 0

 = ^5 ^ =

 1"« 75°° ^ X *• « = ",75 , 

use sane Identification n-jnber as above PCB. 

Nunber Pollutant 

frTYRFWR 

MFTTHVT. MPTTTArPVT.aTP 

ArPTOJP 

Amount 

Pounds/Hr 

^5 -in fii 11 .a*. 

1.27-2.04 

Tons A r 

_£ai 

_JLL 

Basis of Estimate 

- 31.?2 SEE ATTACHED 

-fi.14. R PP an^ar-HPTi 

ARE ANY VOLATILE ORGANIC COMPOUNDS STORED ON PREMISES NO _ x _ YES - List Below 

See Rules 33-15. Section 33-15-01-OA for classes of compounds covered) 

Material Stored 

AROPOT, fl $52 2 

Size Tank (Gallons) 

-______0- -?: TANKS 

vapor Control Devi 

,GA3_A__YTIG- OXIDIZER OR 5 

AFjnpnr, 0 anon -£000. ? TANKS' TZvPRnw ancn-op^ 

ARE ANY ORGANIC SOLVENTS USED OR PRODUCED? 

CIN O (None or less than 50 gallons per year) B Yes - Identify below 

Principal Use Gal/Yr Consulted 

LESS,THANl2^ 

Gal/Yr Produced 

grMPPMT RTTT.K TaNTrv

r7fEftwiip; *M» 

ATFirnrff: MOID. MIX ROOM^RESTN BATH W ^1^Tras*THANv22 0 

IS THERE ANY EMISSION CONTROL EQUIFWENT ON THIS UNIT OR PROCESS? 

D NO G3 Yes - attach Form AP 10? (S>4 8532) 

Does the input material 

or product from this 

process contain finely 

divided material which 

could become airborne? 

D NO D Yes 

Describe storage methods used 

Storage 

Piles 

Type of 

Material 

Particle Size (Average 

Diameter or Screen Size 

Pile Size 

Average Tons 

Pile vetted 

(Yes or NO) 

Pits Cove 

(Yes or N 

Describe any fugitive dust problem: 

..siJL ^ 

Signature of Api 

Attach additional sheets if needed to explain any answe 

Use separate form for each process that emits contamlne 
P.41 

PERMIT 0F*»LICATI0N - CAS CLEANING EQUIPMENT 

STATE DEPARTMENT OF HEALTH - Air Pollution Control Program 

SFN 8532 (AP 109) 10/65 

NOTE: Bead Instructions 

Before Starting re 

APPLICANT 

Name of rirm/Organlzation 

MARVIN WINDOWS 

Person Submitting Application 

JOHN JAMBOIS 

Plant 

Location 1/4 1/4 

Source I.D.# (Form AP 100) 

Title 

COO - TECTON PRODUCTS 

Section niP RGE 

Application Qate 

Phone NO. 

(612 ) . 854-1464 EXT. 14 

Counun.t y 

CASS 

EOUI^ENT 

Type 

O_ Cyclone D Multiclone D Bagfilter 

Q Other (Describe) CARTRIDGE FILTER COLLECTION 

Electrostatic 

D Precipitator D wet Scrubber 

Name of Manufacturer 

TORIT DIVISION DONALDSON CO. 

Model NO. 

4DF48, 2 DFG, ETC 

Oate installed 

Application 

D Boiler D Kiln ffi Other (Specify) 

IPollutants Removed 

Design Efficiency 

FTRERTCTASS 

QQ QQ% 1 b M1UUUN 

Operating Efficiency | caf^f 

Describe Method used to Determine Operating Efficiency: 

ASHRAE TEST RP-53 

GAS CONDITIONS 

Gas volume (SCFM *__9°F., 14.7 psia) 

Gas Temperature (*T.) 

Gas Pressure (In . HJ3) 

Gas velocity (ft/sec) 

Pollutant Concentration 

(Specify Pollutant and 

Unit of Concentration) 

Pressure Drop Throu^i Gas 

Cleaning Device 

Pollutant 

( in H.0) 

Unit of Concentrate 

I.H.ET 

10° P 

1? TN 

•^nn-annn PPM 

-

OUTLET 

7n°p 

0 TN 

3snn-4nnn FPV 

ttach sketch of gas cleaning eguipment and process equipment arrangement. 

Date Signature of Applicant 

MD. 
P.42 

PERMIT APPLICATION FOR HAZARDOUS AIR POLLUTANT (HAP) SOURCES 

HEALTH AN D CONSOLIDATE D LABORATORIES 

Environmenta l Engineering 

SfN 8329 (11/90) AP-liT 

Sb JN A-APPLICANT INFORMATION 

Name 0* fitm of Institution 

MARVIN WINDOWS 

Name of Applicant 

JOHN JAMBOIS 

Mailing Address (street & no 

8043 24TH AVE SOr" 

Title 

CCO TECTON PRODUCTS 

fr&NEAPOLIS 

Standard industrial Classification No 

..MTSC. PIASTICS 3089 

Phone Number 

612-854-1464-EXT 14 

m *«$*& 

FACILITY INFORMATION 

Who to Contact on Air Pollution Matters . 

:HARLES VANASSE 

Mailing Address (street & no ) 

8043 24TH AVE SOUTH 

fitinty Address (street & no ) 

15 TH AVE and 44TH ST. NW 

Title 

PRODUCT DEVELOPMENT 

MINNEAPOLIS 

City and County 

FARGO CASS 

Legal Description of Plant Site ____, „__ . 

1/4 i/4.5^,nATrACHE_?wpAP 100 Rge. 

Land Area at Plant Site 

61.94 AerM(0f) 2,698,106.4 Sq .. 

Latitude (nearest second) 

46° 53' 32" 

MSLEW:wt nB§bs 

State 

MN 

State 

ND 

Phone Number 

612-854-1464 

*$§&% 

Zip Code 

58102 

Longitude (nearest second) 

96° 51 ' 28" 

N

a?bWfTMT,tf&&a t '

o n 

Oescnbe Nature of Bus.^goces ^ ; ^ pwCESS PRODUCING WINDOW AND DOOR LINEALS DURING WHICH A 

THERMOSET POLYEESTER RESIN MATRIX I S REINFORCED WITH FIBERGLASS MAT 

AND ROVING. 

SECTIONS-STACK DATA 

inside Diameter 

?ET ?TN 

inside Area 

530.9 Sq in. 

Height Above Grade 

3 7 ft. 

Are Emission Control Devices in Place? 

if so Complete AP 109 YES 

Gas Temperature at Exit 

300 

Gas velocity at Exit 33 Gas Volu 

ft/sec 

I\5,754 

SCfn 

Basts of Estimate (attach separate sheet if necessary) 

SEE PAGE 2 AP 102 

Nearest Residences or Building 

PHOENIX GROUP BUHDING 

Oistance (ft.) 

460 

Direction 

SOUTH 

Ne»"»st Property Line 

45 TH STREET NW SEE SITE PLAN 

Distance ( ^18 Dire TSfcT 

qi 
P.43 

•>*=\.83-9 

SECTION C • EMISSION STREAM DATA 

Source iD » Form AP-100 

Flow Rate (scfm) 

10,754 ACEM 

Stream Temperature (°F) 

300° F 

Moisture Content (**-b> 

AMBIENT 

Pressure (in Hg) 

0 HG 1 IN WC 

Heat Content (Btu/scfm) 

18,600 BTU/LB 

Mean Particle Diameter (um) 

NA 

Drift velocity (ft/sec) 

Particulate Concentration (gr/dscf) 

Halogens or Metais Present' 

NONE 

Organic Content (ppmv) 

LESS THAN 100PPM 

O. Content (%) 

18% ATMOSPHERE 

SECTION O • POLLUTANT SPECIFIC OATA (Complete One Box for Each Pollutant in Emission Stream) 

Pollutant Emitted 

STYRENE 

/Pfoposed-ETf-nsiTorTRatetlb/hrA 

V 6.5-10.64 _JL ^ 5 MACHINES 

SourcFCTassification (process point, process fugitive, area fugitive) 

PROCESS POINT 

Concentration in emission Stream (ppmv) 

62 PPM 

Solubility 

I N WATER .032 @ 77° F 

Chemical Abstract Services (CAS) Number 

100-42-5 

Emission Source (describe) 

EVAPORATION FROM RESIN SYSTEM 

Pollutant Class and Form (organic/inorganic • particulate/vapor) 

CLASS 3 ORGANIC/VAPOFT 

Vapor Pressure (in. Hg @ °F) 

4.5 Wi @ 68yF 

Molecular Weight (Ib/lb-mole) 

104 

Absorptive Properties 

'00 LBS CARBON ADSORBS 34 LBS STYRENE 

Pollutant Emitted 

METTHYL METHA CRYLATE 

Proposed Emission Rate (lb/hr) "-> 

Qj..27-2..04 5 MACHPES-^ 

Source Classification (process point, process fugitive, area fugitive) 

PROCESS POINT 

Concentration in emission Stream (ppmv) 

LESS THAN 10PPM 

Solubility 

MODERATELY SOLUBLE IN WATER 1.5% 

Chemical Abstract Services (CAS) Number 

80-62-6 

Emission Source (describe) . . 

EVAPORATION FROM RESIN SYSTEM 

Pollutant Class and Form (organic/inorganic - particulate/vapor) 

CLASS 3 ORGANIcTVAPOir 

Vapor Pressure (in. Ha @°F) 

29 m <§ 68* F 

Molecular Weight (Ib/lb-mole) 

100.13 

Absorptive Properties 

POLYMERIZES AND GENERATES HEAT WHEN ADSORBED IN CARBON 

/ mr 

Date I Signature of Applicant 

L J ^ 
P.44 

GENERAL 

PERHiT APPLICATION - VOL»TILE ORGANIC COMPOUNDS 5T0«AGE TANK 

State Department of Health - Air Pollution Control Program 

SFN 8535 (AP 112) 11/85 

Name of Firm or Organization 

.•lARVEEN WINDOWS 

Person Submitting Application 

JOHN JAMBOIS 

Tit i too - TECTON PRODUCTS 

ApplIcation Dot* 

Plant Location 

16TH AVE. AND 44TH ST. NW. FARGO, ND 

Source 10 (AP 100) 

TANK DATA 

CAPACITY: Barrels Gal Ions 

6,000 

DIMENSION: Dl ameter 

10-FT * 

Height 

KTFT 

Length width 

SHAPE: g^eyTlndrice l • Spherical Q Other, Specify 

MATERIALS OF 

CONSTRUCTION: 

(I.e. , steel) 

3/1 6 STAINLESS STEEL 

CONSTRUCTION: • Riveted &Welded • Other, Specify 

COLOR: 

CONDITION: JQtGood CJFair Q Poor 

STATUS: QNe w Construction Q Alteration Q Existing, Give Date Constructed 

TYPE OF TANK: Q;Fixed Roof 

• External Floating 

_J Internal Floating 

• Variable Vapor Space 

• Pressure (low or high) 

D Other, Speci fy 

TYPE OF ROOF: • Pan • Double Deck • Pontoon • Other, Specify 

TYPE OF SEAL: • Metal li e 

Shoe Seal 

___Prlmary Seal Only 

___with Shoe Mounted 

Secondary Seal 

With Rim Mounted 

Seal 

• liquid Mounted 

Res 11 lent Seal 

Primary Seal Only 

With Weather Shield 

With Rim Mounted 

Seal 

• Vapor Mounted 

Res 11 lent Seal 

Primary Seal Only 

With Weather Shield 

with Rim Mounted 

Seal 

VAPOR 0ISPOSAL 

• Atmosphere • Vapor Recovery Utl t • Flare ©Other , Specify 

CARBON ADSORBTION OR CATALYTIC OXIDIZER 

NAME ALL LIQUIDS, VAPORS, GASES, OR MIXTURES OF SUCH MATERIALS TO BE STORED IN THE TANK. 

GIVE DENSITY (LBS/GAL) OR •A.P.I . 

UNSATURATED POLYESTER RESIN, STYRENE, METHYL MErHACRYLATE 

A AROPOL Q8000 8.80 7 LBS/GAL - TANK #1 

B AROPOL Q6522 9.40 7 LBS/GAL - TANK #2 

^ 

Vl-

} 
P.45 

Maximum Fillin g Rate (oarrei s per hcjr or gallon s Der hour) 

Average Outage (Average distance from top of tank shell to liquid surface (ft) 

Average Throughput (Barrels per day or gallons p«r

Average dsy> Throughput 

SEE SPREADSHEET 

Tank Turnovers Per Year 

SEE SPREADSHEET 

IF MATERIAL STORED IS A SOLUTION, SUPPLY THE FOLLOWING INFORMATION 

Name of Solvent 

STYRENE 

Name of Material Dissolved 

POLYESTER RESIN 

Concentration >> Material dissolved Cl by weight' or $ by volume or lbs/gal) 

AROPOL Q80Q0 47% (WEIGHT) AROPOL Q6522 67% (WEIGHT) 

\F MATERIAL STORED IS A GAS OR LIQUIFIED GAS WHICH IS NOT A PETROLEUM PROOUCT, SUPPLY THE FOLLOWING INFORMATION 

Identity the Material 

Pressure at Which Material is Stored (lbs per square Inch gage at *F) 

TAW EMISSIONS 

•'•bl lutant 

Maximum 

Pounds Per Hour Tons Por Year 

Basis and Calculations for Quantities (Attach 

separate sheet It needed) 

Are the standards of perfonnance for new stationary sources; petroleum liquid storage vessels, 40 CFR Part 60, 

Subparts K and Xa (April 4, 1980 Federal Register) being adhered to, where applicable? 

_LJQ_ 

If No, Explain DOES NOT APPLY 

' D6te 

SEfO YOIF APPLICATION TO: 

North Dakota State Department of Health 

01 vision ot Environmental Engineering 

1200 Missouri Avenue, Room 304 

Box #5520 

Bismarck, >C 58502-5520 

PHONE (701)224-2348 

Lm 
P.46 

TANK CLEANING 

Twice a year tank cleaning is recommended. One to three days is the time 

estimated for the procedure. Styrene is the most likely solvent to be used, 

since it is present in the polyester resin allowing the resulting solution to be 

catalyzed and disposed of as a non-hazordous solid waste. We are currently 

considering installing four tanks. This will facilitate coordinating 

deliveries, plus, tank cleaning can be done without stopping production. 

I 
P.47 

Densities of Resin Components 

Aropol Q6522 

Average specific gravity 

Density 

Aropol Q8000 

Average specific gravity 

Density 

= 1.13 

= 1.1272 grams/cubic cro 

= 0.04 07 lbs/cubic inch 

= 9.407 lbs/gallon 

= 1.058 

= 1.0554 grams/cubic cm 

= 0.0381 lbs/cubic inch 

= 8.8070 lbs/gallon 

Mixed formulation (70% Q6522 and 30% Q8000 

Density =' 9.227 lbs/gallon 

Conversion factors used: 

grams/cubic cm. = specific gravity (.9975) 

lbs/cubic inch = grams/cubic cm (1/453.6)(2.54*3) 

lbs/gallon = lbs/cubic inch (1/.0254*3)(1/264.172) 

i\io 
P.48 

PERHIT AF^-VICATION - GAS CLEANING EQUI^ENT 

STATE DEPARTMENT Of HEALTH - Air Pollution Control Program 

STN 8532 (AP 109) 10/85 

NOTE: Read InstructloBefore Starting 

APPLICANT 

Name of firm/organization 

MARVIN WTNTrws 

Person SuDmltting Application 

JOHN JAMBOIS 

Plant 

Location 1/A 1/A 

Source I.D.I (Form AP 100) 

Title 

COO TECTON PRODUCTS 

Section r*p RCE 

Application Date 

JULY 8, 1991 

Phone NO. 

(612) -854-1464 EXT. 14 

County 

CASS 

EOUlfENT 

Type Electrostatic 

D Cyclone Q Multiclone Q Bagfilter 0 Precipitator D *et scrub. 

Q Other (Describe) CATALYTIC OXIDIZER 

Nam* of Manufacturer 

awmTT. .ENVTRrNMFM-AT. .qYSTFflg 

Model NO. 

75 7500 SCFM '* 

Oate Installed 

Application 

D Boiler D Kiln Q Other (Soeclfy) PULTRUSION 

Pollutants Removed 

Design Efficiency j 

Operating Efficiency 

QTVOTNE 

QQ X 

qR * 

METHYL METHACRYLATE 

99 X 

95 X 

X 

X 

Describe Method used to Determine Operating Efficiency: 

TYPICALLY EPA METHOD 25 PPM OUT 

PPM IN 

CAS C0NOITI0NS INL ST OUTIET 

Cas voline (SCTH 68°r. , 1A.7 psia) 7500 SOM 7bU0 Ur'M 

Gas Temperature (T. ) 70° F ?QQ° F 

Cas Pressure (in. HJD) ta BJ 2 TT. 

Cas velocity (ft/sec) 

Pollutant Concentration 

(Specify Pollutant and 

unit of Concentration) 

Pollutant 

STYRENE 

Pressure Drop Through Cas 

Cleaning Device (if i 

MFTHYT. MFTHftTRYTATF; 

In H.J) 

unit of Concentrate 

33 FFS 

LB/HR 

LB/HR 

10.64 LB/HR 

2.04 LB/HR 

33 fPft 

.532 LB/HR 

.102 Lti/HK 

63,813 LBS STYRENE/YR 5 MACHINES = 10.64 LB/F 

6,000 HRS 

attach sketch of gas cleaning equipment and process equipment arrangement. 

9: Ml 

12,276 LBS METHYL METHACRYLATE = 2.04 LB/HR 

Signature df Applicant 

SEE SPREAD SHEET FOR YEAR 5 FIGURES FOR 14 MACHINES 

n 
P.49 

CITY OF FARGO PUBLIC WORKS 

ENGINEERING 

306 Fourth Street North 

Fargo, North Dakota 58102 

Phone: (701) 241-1545 

FAX: (701) 241-8101 

June 21, 1991 

MEMORANDU M 

TO: Maurice Anderson, Community Development Specialist 

FROM: Mark H. Bittner, civil Engineer "} 1 ")&J2_ j/ . &.~tC^^ 

SUBJECT: Marvin Windows Site 

Following is information you requested relative to center of Lot 3, Block 15, Industrial 

Park Sub. No. 3. The exact location of referenced point is 240 feet east of the center of 

44th Street and 800 feet north of the center of 15th Avenue North. 

Latitude 

Longitude 

Elevation 

46<>53'32" 

96°51*28" 

894.00 USGS 

For comparison purposes, the elevation of top of curb directly south on 15th Avenue 

North is 897.02. 

If you have any questions, please call. 

MHB/avl 

CC: Robert C Welton 

Attachment 

4$ 
P.50 

Replat of Industrial Sub. No. 3; Lot 2, Block 17; and Lot 9, Block 15 

503,553.6 square feet platted lots 

Industrial Sub. No. 3; Lot 1, Block 17; Block 14; and Lots 1-8, Block 15 

1,971,525.6 square feet platted lots 

223,027.1 square feet platted roadway 

2,698,106.4 square feet total 

61.94 Acres 

•U 
P.51 

PROJECT 
P.52 

470000 FCCT 

|N DAH|" 

^^. i i ^ 

46'5M0 " 

r'J • tnJUBTVI 

H) 12 910*000 FCCT IN. DU J 

/ 

9«'S?'}0"

 H I

 " "O'ooo Fein " 0-K.I • HA 

J> Mapped, edited, ind published by the Geological Survey 

K( . I H A; « l/AHCO SOUTH) HI 

ton. tt w..._i IUM 11 

SCALE 124 OOO 

J* 

Conlfol bv USGS *nd USC AGS 

Culture »Ad diaiA«o ••* PiM compiled Irom tiriil photograph* 

tiktn 1954 Topography or pianttabia lurvayt 1959 

Pohrconic proiachOA 1927 No^th American datum 

10.000-foot (nd* bated OA Norm Dakota coordinate tytiem. 5 'J*j 

Multi ton*. *no Minnesota coordinate .vtlem, central lone 

1000-meter Un>-«r»l Tranivtrie Mtrcetor grid tick*. 

lent 14, tho-an m blue 

Red tmt indicate* aree. in which only 

landmark building* •' • mown 

l(i-,i .•"'•"* (n-Mli ••• |NH|ilf > .*M|»lr-"l tji.ili •. <i.il 1 J...|l 4 ii,.|J > -l 

I ,-.,:. )•• ' • .1. ' l"> '' . II.*- .ill.J....,!..*. ,H_I | H | , | , i... >, • 

K....I. li l .«..!« •<*- • •!• .. —i . -J .itl..... .Mt. , 

/_'.»• „ 

/ i n MII.» CONTOUR INTERVAL 5 FCET 

NAIiONAl G-EOOCtlC vCRttCAL QATUM OF I9 » 

THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY STANOAROt 

fOR SALE BV U S CfOlOClCAL SURVEV. OCNVCR.COLORADO 60??* OR RESTON VIRGINIA ??W 

ANti 'SIAlt WAllM (.UMMISSION, IIISUAIfCK.NOHIII HAKUlA IH'.OI 

A IOI III It IIIM.IIIIIINI, HifUI.MAIMIH: M»»"» ANO .VUBOiS lS AVAIlAtlll UN MHJUCil 
P.53 

PROJECT BOUNDARIES 

5 0. 
- — : -*c- ^ 

1. FOOD SERVICE OF AMERICA 

2. . HOENIX GROUP 

3. SPECIAL RESOURCE MANAGEMENT 

4. NABISCO 

5. FARGO ASSEMBLY CO. 

BUILDING LOCATIONS 

6. McARTHUR COMPANY 

7. J.B. PRODUCTS 

8. TAPP REPAIR SERVICE 

9. OPP CONSTRUCTION 

10. SANITATION PRODUCTIONS 

53 
P.55 

PLATTED PROPERTIES 
EXHAUST 

(ID#I ) 

EXHAUST 

(ID#7-) 

FIBROUS 

ROVING 

STATION 

STYRENE 

EMISSION 

500 CFM 

34 PPM 

A 

LIOUID 

ENTRY 

FINISHED 

PRODUCT EXIT 

FIBROUS 

MAT STATIOH 

RESIN 

STATION 

I 

STATION 

PULLER 

STATION 

BAGHOUSE 

I 

iti n *<• 

comm 

STYRENE 

EMISSION 

2000 CFM 

77PPM 

FIBERGLASS 

PARTICULATES 

EMISSION 

350CFM 

iAW STAT IOI 
-6— 

A 

BAGHOUSE 

A 

FIBERGLASS 

PARTICULATES 

500 CFM 

UNCUT 

CUT 

MAT SLITTING AREA 
P.58 

ESTIMATED 'UNCONTROLLED EMISSIONS 

5 PULTRUDERS YEAR 2 

DTV BY 

DIV BY 

I 

DIV BY 

63,813 TOTAL STYRENE EMISSION/YR 

6000 HOURS OF PRODUCTION/YR 

LBS/HR EMISSION 

LBS/MIN EMISSION 

LBS TO GRAMS 

SECONDS 

GRAMS/SEC EMISSION 

1 HR MAAL (ND MAAL 4.26) 

2.44 8 HOUR MAAL (ND MAAL 2.13) 

X 

X 

X 

10.64 

60 

.177 

453.6 

80.29 

60 

1.34 

2.6 

3.48 

.7 

THIS PERMIT IS INTENDED TO APPLY TO 5 PULTRUDERS. 2 WILL BE 

INSTALLED AND OPERATING IN YEAR 1. 3 MORE ARE PROJECTED POR 

YEAR 2. THE FOLLOWING FIGURES ARE ESTIMATES OF RESIN USE AND 

STYRENE EMISSIONS IN YEAR 2. 

* SEE PAGE 4.12-8 US EPA AP-42 SUPPLEMENT B SEPT. 1988 

5 
P.59. 

ESTIMATED REDUCTION IN STYRENE EMISSIONS 

USING 95% EFFICIENT CATALYTIC OXIDIZER 

(7500 CFM) 5 MACHINES YEAR 2 

63,813 LB STYRENE EMISSICN/YR 

DIV BY 6,000 

10.64 LB/HR 

X .05 95% EFFICIENT OXIDATION 

. .53 LB/HR TO ATMOSPHERE 

DIV BY 60 

.0088 LB/MIN 

X 453.6 

4.02 GRAMS/MIN 

DIV BY 60 

.067 GRAMS/SBC 

X 2.6 

.1742 1HOUR MAAL (ND MAAL 4.26) 

X .7 

.1218 8HOUR MAAL (ND MAAL 2.13) 

y 
P.60 

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P.62 

PROPOSED WASTE STREAM MANAGEMENT PLANS FOR TECTON, INC. 

FARGO, NORTH DAKOTA 

I. Bulk Storage Tanks 

Tecton will have 2^*6000 gallohSbulksstorage tanks for uncured resin that contains 40%» 

sjpfnlf* These tanks will require cleaning approximately twice per year. The 

cleaning agent will be the solvent in the resin; styrene; v 

1. SRM can provide cleaning services for the tanks and manage the disposal 

of the contents, which will be catalyzed. Cleaning with styrene in a closed 

space will require level A protective clothing (self-containing breathing 

apparatus), which SRM is trained to use and owns. SRM also has a Certified 

Industrial Hygienist (CIH) on staff for health and safety oversight of this 

project. 

2. It would be possible to reduce exposure levels in the cleaning operations 

of these tanks and thus reduce the risk level and expenses in cleaning. SRM 

would be pleased to offer engineering suggestions for the construction of these 

tanks to make them easily and most cost effectively cleaned. Potential ideas 

are: at least one 24 inch manway that is easily removable; preferably another 

manway elsewhere on the tank for ventilation exhaust; a hard plumbed purge 

on the tank for exhaust; etc. SRM can also provide the air quality expertise 

in the event scrubbers are needed on the exhaust to meet air quality 

standards. 

n. Mold Release Solvents, Mold Cleanup, Mixing Room Cleanup 

SRM holds agreements with approximately 20 disposal facilities which offer a variety 

of waste management methods. It is our policy to offer' companies a choice of 

facilities and waste management options which will best suit their needs. Wastes 

from the above operations, for example, may be managed by fuel blending, grinding 

and fuel blending or direct incineration. Some of the paints may be suitable for 

landfill disposal depending upon their chemical analysis and regulatory status. 

m . Spent Acetone Solvent 

There are a number of methods of managing acetone wastes. If the recovery value 

of the solvent is high enough, redistillation and reuse is usually the best choice. SRM 

can provide recycling services off-site either as drummed waste or in bulk tankers of 

waste and can return the product for reuse. We will provide pricing for a number 

of options, including on-site distillation using a mobile solvent still SRM owns and 

operates or an in-plant still operated by Tecton. SRM can than manage the still 

bottoms. Other options if the quality ofthe acetone is not high enough for recycling 

include fuel blending and direct incineration. 

r 
.?•?! :o:

' --

4SH_HI ^ -IMEHMM L EHl'3 TO •?? 15-1I50Q7 _•—_• 3 9e'6 P. 10 . 

TABLE 4.12-2 . EMISSION FACTORS FOR UNCONTROLLED POLYESTER RESIN 

PRODUCT FABRICATION PROCESSES* 

(100 x mass of VOC emitted/mass of monomer Input) 

• 

^ 

( '!>' *JiO 

Process 

Hand layup 

Spray layup 

Continuous lamination 

Pultruslond 

Filament winding* 

Marble casting 

Closed ooldingg 

Resl 

NVS 

5-1 0 

9-1 3 

4 - 7 

(TTT? 

5 - JO 

1 - 3 

1 - 3 

n 

VSb 

- 7 

3 - 9 

1 - 5 

1 - 5 

2 - 7 

1 - 2 

1 - 2 

Eoi sion 

Factor 

Rating 

C 

B 

B 

© 

D 

B 

D 

Cel Coat 

NVS 

26 - 35 

26 - 35 

c 

c 

c 

f 

c 

VSb 

8-2 5 

• 

8-2 5 

c 

c 

-

r. 

c 

1 

Esission 

Factor 

Rating 

0 

B 

_ 

— 

— 

• — 

— 

•Reference 9. Ranges represent the variability of processes ani sensitivlty of ealsslons to process paraneters. Single value factors should be 

selected with caution. NVS • nonvapor-suppressed resin. VS • vapor-tup* 

pressed rerln. 

bFactors are 30-70* of those for nonvapor-suppressed resins. 

CGel coat i% not normally used in this process. 

dp'Mn factors for the continuous laclns.ion process are assuc.-7'. eo apply. 

\i factors for the hand layup pr '• are assumed to apply. 

.• rs unavailable. However, when parts are subsequently sprayed 

• it- 1 coat, hand and spray layup ^. . coat factors are as sue.", tc apply, 

«•?•»-.. .actors for marble casting, a semiclosed process, are assumed to 

/••pply. 

TABLE 4.12-3. TYPICAL RESIN STYRENE PERCENTAGES 

Resin Application 

Hand layup 

Spray layup 

Continuous lamination 

Filaaent winding 

Marble casting 

Closed molding 

Cel coat 

•in Styr>e Content* 

(wgt. 

43 

43 

40 

40 

32 

•5.' 

35 

•"May vary by at leas, _r5 percentasi point* 

•8 EMISSION FACTOR? 

fa 

9/88 

 
P.64 

:

:_L-a3-1591 35:08 =£CM ASHLAND CHEM: CSL EH&S S612=5<:DC23—2B566 

s Rorvn and Haas Conpany 

Independence Mall West 

Philadelphia, PA H105 

HEALTH EMERGENCY 

SPILL EMERGENCY 

CHEMTREC 

: 215-512-3000 

: 215-592-3000 

: 100-424-9300 

MATERIAL SAFETY 

DATA SHEET 

PRODUCT IDENTIFICATION 

METHYL METHACRYLATE - 50 ppm MEHQ 

Product code 

Key 

MSDS date 

Supersedes 

65281 

905516-7 

09/12/90 

05/25/89 

Rohm and Haas 

Hazard Rating 

Toxicity 2 

Fire 3 

Reactivity 2 

Special 

Scale 

4«IXTRSMe 

J'WICM 

-.•MOO-KATE 

•USIICWT 

•J.INSICNUICANT 

COMPONENT INFORMATION 

No. 

1 Methyl methacrylate 

2 Other ester adducts 

3 MEHQ 

CAS REG NO. AMT.(%) 

80-62-6 99.8 MIN 

Not Required 0.20 MAX 

150-76-5 0.005 

EMERGENCY RESPONSE INFORMATION 

FIRST AID PROCEDURES 

Inhalation 

Eye Contact 

Skin Contact 

Ingestion 

Move subject to fresh air. Give artificial respiration if breathing has stopped. 

Get prompt medical attention. 

Flush eyes with a large amount of water for at least 15 minutes. Consult a 

physician if irritation persists. 

Remove and wash contaminated clothing thoroughly. Wash skin thoroughly with 

soap and water. See a physician. 

If swallowed, give 2 glasses of water to drink. Never give anything by mouth 

to an unconscious person. See a physician. 

# > 

PAGE 1 of 9 
P.65 

JL:L-03-1351 0S:39 '--SCM fiSHLPND CHEMICHL EH&3 TO 56125546323--28S6S P.22 

Rohm and Haas Company 

Independence Mall west 

Philadelphia. PA 1910S 

PRODUCT: METHYL METHACRYLATE - SO ppm 

MEHQ 

KEY: 905516-7 

DATE: 09/12/90 

FIRE FIGHTING INFORMATION 

Unusual Hazards 

Extinguishing Agents 

Vapors can travel to a source of ignition and flash back. Heat can cause 

polymerization. Heated containers can explode. 

Use the following extinguishing media when fighting fires involving this material: 

- polar solvent (alcohol) foam - carbon dioxide - dry chemical - water spray 

Personal Protective Equipment 

Wear self-contained breathing apparatus (pressure-demand MSHA/NIOSH approved or equivalent) and full protective gear. 

Special Procedures 

EXPLOSION HAZARD. Fight advanced fires from a protected location Use 

water spray to cool containers exposed to fire. 

SPILL OR LEAK HANDLING INFORMATION " ' 

Personal Protection 

Procedures 

Appropriate protective equipment must be worn when handling a spill of this 

material. See the PERSONAL PROTECTION MEASURES Section for recommendations. 

If exposed to material during clean-up operations, see the FIRST AIO PROCEDURES 

Section for actions to follow. 

Keep spectators away. Eliminate all ignition sources. Contain spills immediately 

with inert materials (e.g. sand, earth). Transfer liquids and solid diking material 

to separate suitable containers for recovery or disposal. Contaminated monomer 

may be unstable. Add inhibitor to prevent polymerization. See WASTE DISPOSAL 

Section for information regarding the disposal of contained spills. 

NOTE: Spills on porous surfaces ean contaminate groundwater. 

CAUTION: Keep spills and cleaning runoff out of municipal sewers and open 

bodies of water. 

(A 

PAGE 2 of 9 
P.66 

JLL-33-1SS1 35=3S 

s 

FROM ftSHL.SND CHEniCflL EH&5 TG 96129346823—25566 P.24 

Rehm and Haas Company 

Xnd«p«neene« Mall West 

Philadelphia. PA 19105 

PRODUCT: METHYL METHACRYLATE - 50 ppm 

MEHQ 

KEY: 90SS16-7 

DATE: 09/12/90 

HAZARD INFORMATION 

HEALTH EFFECTS FROM OVEREXPOSURE 

Primary Routes of Exposure 

Inhalation 

Skin Contact 

Inhalation 

Inhalation of vapor or mist can cause the following: 

- irritation of nose and throat 

Repeated or prolonged exposure can cause the following: 

- headache - nausea - drowsiness - unconsciousness 

Eye Contact 

Material, as supplied, ean cause the following: 

- slight irritation 

Skin Contact 

Material can cause the following: 

- moderate skin irritation - skin sensitization 

Ingestion 

Material is possibly harmful if swallowed. 

Delayed Effects 

Prolonged or repeated exposure can cause the following: 

- allergic skin reaction - kidney damage - liver damage 

FIRE AND EXPLOSIVE PROPERTIES ' 

Flash Point 10°C/50°F Setaflash Closed Cup 

Auto-ignition temperature 435°C/815°F 

Lower explosive limit 2.1% 

Upper explosive limit 12.5% 

REACTIVITY INFORMATION 

Instability 

This material is considered stable under specified conditions of storage, shipment 

and/or use. See STORAGE ANO HANDLING INFORMATION Section for specified 

CONTINUED 

PAGE 3 of 9 / .£-

^'.Wm- « --> + Qmt»>,mm<J-%r-4 * • _ • ^ - - -*----- -
P.67 

;LL-33-lSSl 39=13 F^.Cr, SSHLhND CHE-llCnL EH&3 3612S546E23—2SS66 

Rohm and Haas Company PRODUCT: METHYL METHACRYLATE - SO ppm 

Independence Mall West M . u n Philadelphia. PA 1910S menu 

KEY: 905516-7 

DATE 09/12/90 

CONTINUATION 

conditions. However, this material can undergo hazardous polymerization. See 

Hazardous Polymerization for conditions to avoid. 

Hazardous Decomposition Products 

There are no known hazardous decomposition products for this material. 

Hazardous Polymerization 

Excessive aging, heat contamination with polymerization eatalysts, oxygen-free 

atmosphere, inhibitor depletion or ultraviolet light (sunlight) may cause 

polymerization. 

An uncontrolled polymerization may produce a rapid release of energy with the 

potential for an explosion of unvented closed containers. 

Incompatibility 

Avoid contact with the following: 

- acids - bases • oxidizing agents - reducing agents - UV light 

r

»'VIRONMENTAL IMPACT 

Environmental Toxicity 

Rainbow trout (Salmo gairdneri), 96 Hour LC50: 80 mg/l (Slightly toxic) 

Daphnia magna, LC50: 70 mg/l (Slightly toxic) 

Rainbow trout (Salmo gairdneri). LC50: 170 mg/I (Practically non-toxic) 

ACCIDENT PREVENTION INFORMATION 

COMPONENT EXPOSURE INFORMATION 

Component Information 

No CAS REG NO. AMT.(%) 

1 Methyl methacrylate 80-62-6 99.8 MIN 

2 Other, ester adducts Not Required 0.20 MAX 

3 MEHQ 150-76-5 0.005 

Exposure Limit Information \ 

Component ; ROHM AND HAAS OSHA ACGIH 

No. Units TWA STEL TWA STEL TLV STEL 

ppm Q>0j) (7S) 100 None 100 None 

•i ar^ j ^ a a a a 

3 mg/m3 5 None 5 None 5 None 

, CONTINUED, 
P.68 

.A. -33-1=91 39=13 • =~.CM PSHLHNC C.-Er.iCAL Er-&3 rt.i=--cc<io 5—-cc 

Rohm and Haas Company 

Independence Mall west 

Philadelphia, PA 19105 

PRODUCT: METHYL METHACRYLATE - 50 ppm 

MEHQ 

KEY: 905516-7 

DATE: 09/12/90 

CONTINUATION 

a Not Required 

NOTE: Contact Rohm and Haas Company for air monitoring method 

PERSONAL PROTECTION MEASURES 

Respiratory Protection 

Eye Protection 

Hand Protection 

Other Protection 

A respirator protection program meeting OSHA 1910.134 and ANSI Z88.2 requirements must be followed whenever workplace conditions warrant a 

respirator's use. None required if airborne concentrations are maintained below 

the TWA/TLVs listed in the COMPONENT EXPOSURE INFORMATION Section. For 

airborne concentrations up to 10 times the TWA/TLVs listed in the COMPONENT 

EXPOSURE INFORMATION Section wear a MSHA/NIOSH approved (or equivalent) 

half-mask, air-purifying respirator. Air-purifying respirators should be equipped 

with organic vapor cartridges and dust and rriist filters. For airborne concentrations up to 100 times the TWA/TLVs listed in the COMPONENT EXPOSURE 

INFORMATION Section wear a MSHA/NIOSH approved (or equivalent) fullfacepiece airline respirator in the positive pressure mode with emergency escape 

provisions. 

Use chemical splash goggles (ANSI 237.1 or approved equivalent). Eye protection 

worn must be compatible with respiratory protection system employed. 

The glove(s) listed below may provide protection against permeation. Gloves 

of other chemically resistant materials may not provide adequate protection: 

- Butyl rubber 

Rinse and remove gloves immediately after use. Wash hands with soap and 

water. 

Gloves should be removed and replaced immediately if there is any indication 

of degradation or chemical breakthrough. 

NOTE: Material is a possible skin sensitizer. 

Use chemically resistant apron or other impervious clothing to avoid prolonged 

or repeated skin contact. 

PAGE 5 of 9 (Pr 
_^_^_ _ P.69 

JUL-33-13S1 39=11 FRCM PSHLAND CHE"ICSL c~i&5 TG 36125546323—25566 ~.2~ 

Rohm and Haas Company PRODUCT: METHYL METHACRYLATE - 50 ppm 

Independence Mall West MRU « 

Philadelphia. PA 1910S IY1EHQ 

KEY: 905516-7 

DATE: 09/12/90 

FACILITY CONTROL MEASURES 

Ventilation 

Use local exhaust ventilation with a minimum capture velocity of 100 ft/min. (30 

m/min.) at the point of vapor evolution. Refer to the current edition of Industrial 

Ventilation: A Manual of Recommended Practice published by the American 

Conference of Governmental Industrial Hygienists for information on the design, 

installation, use. and maintenance of exhaust systems. 

Other Protective Equipment 

Facilities storing or utilizing this material should be equipped with an eyewash 

facility and a safety shower. 

STORAGE AND HANDLING INFORMATION 

Storage Conditions 

Handling Procedures 

Other 

Store out of direct sunlight in a cool place. Avoid temperature extremes during 

storage; ambient temperature preferred. Material can burn; limit indoor storage 

to approved areas equipped with automatic sprinklers. Total absence of oxygen 

will inactivate the inhibitor. Do not store under oxygen-free environment Leave 

air space over liquid surface in all containers introducing air periodically if stored 

more than 6 months. Use monomer within 1 year. Conduct a stability test on 

material stored in bulk every month; drums and pails every 3 months using test 

method TM-1011A available from Rohm and Haas Company. 

This material is a potential skin sensitizer. See the PERSONAL PROTECTION 

MEASURES Section prior to handling. 

CONTAINERS HAZARDOUS WHEN EMPTY. Since emptied containers retain 

product residue (vapors and/or liquid) follow all MSDS and label warnings even 

after container is emptied. 

SUPPLEMENTAL INFORMATION 

TYPICAL PHYSICAL PROPERTIES " 

Appearance Clear 

Color Colorless 

State Liquid 

Odor Characteristic Fruity odor 

Viscosity 0.53 CPS 

Specific Gravity (Water » 1) * .. . 0.94 

CONTINUED 

PAGE 6 of 9 ML 
P.70 

;UL-33-1351 35= ?CM ASHLAND CHEMICAL t.-'&S 56123546323—2S566 ,25 

Rohm and Haas Company 

Independence Mall west 

Philadelphia, PA 19105 

PRODUCT: METHYL METHACRYLATE - 50 ppm 

MEHQ 

KEY: 90S516-7 

DATE 09/12/90 

CONTINUATION 

Vapor Density (Air = 1) 3.5 

Vapor Pressure 29 mm Hg @2Q*Ct68'\* 

Melting point -48°C/-54°F 

Boiling point 101°C/214°F 

Solubility in water 1.5 % Moderately soluble 

Percent Volatility 100 

Evaporation rate (BAe

 B 1) ... . > 1 

iy\ftl€tiJlA<T_ bJ^-KlH'X yQQjm 

TOXICITY INFORMATION 

Acute Data 

Sensitization Data 

Epidemiology Data 

Dermal LD50 - rabbit >5000 mg/kg 

Oral LDSO - rat: >5000 mg/kg 

Inhalation LC50 - rat 7094 ppm for 4.0 hr 

Skin Irritation - rabbit: moderate irritation 

Eye Irritation - rabbit slight irritation 

Sensitization - human: Allergic response observed 

In a retrospective study of the effects of exposure to ethyl acrylate and methyl 

methacrylate on workers hired in one plant between 1933 and 1945, a higherthan-expected incidence of colorectal cancer mortality was observed. A study 

on workers hired after 1945 in the same plant, and a study on workers hired 

after 1942 in a second plant, did not show an increased risk of colorectal 

cancer mortality. 

WASTE DISPOSAL 

Procedure 

After the addition of excess inhibitor, incinerate liquid and contaminated diking 

material in accordance with local, state, and federal regulations. 

REGULATORY INFORMATION 

WORKPLACE CLASSIFICATIONS 

This product is considered hazardous under the OSHA Hazard Communication 

Standard (29CFR 1910.1200). 

This product is a 'controlled product' under the Canadian Workplace Hazardous 

Materials Information System (WHMIS). 

PAGE 7 of 9 tfl 
P.71_ 

JUL-33-1SS1 0S= 12 FRCM ASHLAND CHEMICAL EHg5 TQ .36125546323—26566 F.2S 

Rohm and Haas Company PRODUCT: METHYL METHACRYLATE - 50 ppm 

Independence Mall Vest Meur\ 

Philadelphia. PA 19105 ivifcnu 

ygW-l* KEY: 905516-7 

DATE: 09/12/90 

TRANSPORTATION CLASSIFICATIONS 

Proper shipping name METHYL METHACRYLATE, INHIBITED 

US DOT Hazard Class FLAMMABLE LIQUID 

Identification number UN 1247 

DOT shipping label Flammable Liquid 

EMERGENCY PLANNING & COMMUNITY RIGHT-TO-KNOW (SARA TITLE 3) 

Section 311/312 Categorizations (4QCFR 370) 

This product is a hazardous chemical under 29CFR 1910.1200, and is categorized 

as an immediate and delayed health, and flammability and reactivity physical 

hazard. 

Section 313 Information (4QCFR 372) 

This product contains a chemical which is listed in Section 313 above de minimis 

concentrations. The following listed chemicals are present: (Quantity present is 

found elsewhere on this MSDS.) 

- Methyl methacrylate (80-62-6) 

CERCLA INFORMATION (40CFR 302.4) 

This material has a component or components with a reportable quantity under 

/ the. Comprehensive Environmental Response, Compensation, and Liability Aet 

(CERCLA) and the Superfund Amendments and Reauthorization Act (SARA) Title 

III Section 304. The components. CAS numbers, and reportable quantities are 

listed below. Spills of a component in excess of its reportable quantity must 

be:reported to the National Response Center (1-800-424-8802) and to the 

appropriate state and local emergency response organizations. 

Methyl methacrylate (80-62-6) lOOOIbs. 

RCRA INFORMATION 

When this product becomes a waste, it is classified as a hazardous waste under 

criteria of the* Resource Conservation and Recovery Act, Category: U-162 (40 

CFR 261). 

CHEMICAL CONTROL LAW STATUS 

All components of this product are listed or are excluded from listing on the 

U.S. Toxic Substances Control Act (TSCA) Chemical Substanee Inventory. 

PAGE 8 of 9 TO 
P.72 

."•_i_-e3-i35i *fs-;..• --cr-. ASrLr-N.; „.—c." . _AL E.—&3 rb.i-=:UEa23—2o566 -.1 2 

0 Rohm and Haas Company 

Independence Mali Vest 

Philadelphia. PA 19105 

PRODUCT: METHYL METHACRYLATE - 50 ppm 

MEHQ 

KEY: 905516-7 

DATE: 09/12/90 

ABBREVIATIONS: 

ACGIH = American Conference of Governmental Industrial Hygienists 

OSHA " Occupational Safety and Health Administration 

TLV • Threshold Limit Value 

PEL • Permissible Exposure Limit 

TWA - Time Weighted Average 

STEL « Short-Term Exposure Limit 

BAe s Butyl acetate 

I Bar denotes a revision from previous MSDS in this area. 

The information eonttintd her tin it based en data considered accurate. However, ne warranty Is espresso* 

er Implied regarding th« accuracy of thes* date er the results te be obtained from the us* thereof, 

•.ohm and Haas Company assumes ne responsibility for ptrsongl injury or property damage to »*nd**S. users 

or third parties ceustd fry the material. Such venaees or users sssum* *H risks associated with the us* 

o< the material. 

PAGE 9 of 9 II 
P.73 

• ! • 

Dow U.S.A. 

Material Safety Data Sheet 

Emergency S17 636-4400 

Product Code: 81352 

Product Name: STYRENE MONOMER 

Effectiv e Date: 10/17/90 Date Printed: 07/03/91 

Page: 1 

MSDS-.000258 

1. INGREDIENTS: (% w/w. unless otherwise noted) 

Styrene, minimum 

(Inhibitor: p-t-butylcatechol 

55 PPm» max.) 

CAS# 000100-142-5 99-6% 

CAS# 027213-78-1 

This document is prepared pursuant to the OSHA Hazard 

Communication Standard (29 CFR 1910.1200). In addition, other 

substances not 'Hazardous' per this OSHA Standard may be listed. 

Where proprietary ingredient shows, the identity may be made 

available as provided in this standard. 

2. PHYSICAL DATA: 

BOILING POINT: 293F, l^C 

VAP. PRESS: U.S mmHg @ 20C 

VAP:. DENSITY: 3.6 

SOL. IN WATER: 0.032 @ 25C 

SP. GRAVITY: .9031* @ 25/25C 

APPEARANCE: Colorless liquid, 

00OR: Sweet odor. 

3. FIRE AND EXPLOSION HAZARD DATA: 

FLASH POINT: 88F; 31C 

METHOD USEO: Tag Closed Cup 

FLAMMABLE LIMITS 

LFL: 1.1 Vol. % 

UFL: 6.1 Vol. % 

EXTINGUISHING MEDIA: Water fog, foam, alcohol foam, carbon 

dioxide, dry chemical. 

(Continued on page 2) 

(R) Indicates a Trademark of The Dow Chemical Company 

^ 
P.74 

D ow Chemical U.S.A.* Midland, Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: 2 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MSDS:000258 

3. FIRE AND EXPLOSION HAZARD DATA: (CONTINUED) 

FIRE 6 EXPLOSION HAZARDS: Material autoignites at 91 UF, l*90C 

in air. Polymerization will take place under fire conditions. 

If polymerization occurs in a closed container, there is a 

possibility it will explode. Cool storage containers with 

water, if exposed to fire. 

FIRE-FIGHTING EQUIPMENT: Wear positive-pressure, self-contained 

breathing apparatus; wear goggles if eye protection is not 

provided by the breathing apparatus. 

4. REACTIVITY DATA: 

STABILITY: (CONDITIONS TO AVOID) Polymerizes easily. Store 

below 90F, 32C. Maintain inhibitor and dissolved oxygen level. 

INCOMPATIBILITY: (SPECIFIC MATERIALS TO AVOID) Acid, caustic, 

oxidizing material, metallic halides (salts). 

HAZARDOUS DECOMPOSITION PRODUCTS: None known. 

HAZARDOUS POLYMERIZATION: Avoid heat, metallic (halide) salts -

such as ferric and aluminum chlorides, unintended contact with 

peroxides, and depletion of inhibitor and oxygen. (See section 

9 for additional information.) 

5. ENVIRONMENTAL AND DISPOSAL INFORMATION: 

ACTION TO TAKE FOR SPILLS/LEAKS: Small spill or leak - absorb 

with suitable agent, such as sand or vermiculite; wash area 

with soap and water. Large spill - contain with dikes, pump 

water into area, recover styrene to be burned or purified for 

reuse. Some absorbents, such as Zorb-all, may initiate 

polymerization. 

(Continued on page 3) ' 

(R) Indicates a Trademark of The Dow Chemical • Company 

* An Operating Unit of The Dow Chemical Company 

?3> 
P.75 

Dow Chemical U.S.A.* Midland. Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: 3 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MSDS:000258 

5. ENVIRONMENTAL AND DISPOSAL INFORMATION: (CONTINUED) 

DISPOSAL METHOD: Incinerate in properly designed furnace. 

Comply with federal, state, and local regulations. Call The 

Dow Chemical Company for additional help. 

6. HEALTH HAZARD DATA: « 

EYE: May cause moderate irritation with corneal injury. Vapors 

may irritate eyes. Vapors may cause lachrymation (tears). 

SKIN CONTACT: Prolonged or repeated exposure may cause skin 

irritation, even a burn. Repeated contact may cause drying or 

flaki ng of ski n. 

SKIN ABSORPTION: A single prolonged exposure is not likely to 

result in the material being absorbed through skin in harmful 

amounts. The dermal LD50 has not been determined. Repeated 

skin exposure may result in absorption of harmful amounts. 

INGESTION: Single dose oral toxicity is low. The oral LD50 for 

rats is 5000 mg/kg. Small amounts swallowed incidental to 

normal handling operations are not likely to cause injury; 

swallowing amounts larger than that may cause injury. If 

aspirated (liquid enters the lung), may be rapidly absorbed 

through the lungs and result in injury to other body systems. 

Ingestion may cause irritation of the mouth, throat, and 

gastrointestinal tract. 

INHALATION: Excessive vapor concentrations are attainable and 

could be hazardous on single exposure. Signs and symptoms of 

excessive exposure may be anesthetic or narcotic effects and 

irritation to upper respiratory tract. 

SYSTEMIC (OTHER TARGET ORGAN) EFFECTS: Repeated excessive 

1 

(Continued on page ->) 

(R) Indicates a Trademark of The Dow Chemical Company 

* An Operating Unit of The Dow Chemical Company 

1*4 
D ow Chemical U.S.A.* Midland. Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: k 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MSDS:000258 

6. HEALTH HAZARD DATA: (CONTINUED) 

exposures to high amounts may cause central nervous system, 

liver, kidney effects and respiratory or eye irritation. 

Repeated excessive exposures to smaller amounts may cause 

central nervous system effects and respiratory or eye 

irritation. Styrene is reported to have caused hearing 

loss in laboratory animals upon exposure to high concentrations 

(sixteen times the TLV and higher); however, the relevance 

of this to humans is unknown. 

CARCINOGENICITY: For hazard communication purposes under OSHA 

Standard 29 CFR Part 1910.1200, this chemical is listed as a 

potential carcinogen by IARC. Neither the data from various 

long-term animal studies nor from epidemiology of workers 

exposed to styrene provide an adequate basis to conclude that 

styrene is carcinogenic. 

TERATOLOGY (BIRTH DEFECTS): Birth defects are unlikely. Even 

exposures having an adverse effect on the mother should have 

no effect on the fetus. 

REPRODUCTIVE EFFECTS: In animal studies, styrene monomer has 

been shown not to interfere with reproduction. 

MUTAGENICITY (EFFECTS ON GENETIC MATERIAL): Results of in vitro 

('test tube') mutagenicity tests have been inconclusive. 

Results of mutagenicity tests in animals have been inconclusive. 

7. FIRST AID: 

EYES;: Flush eyes with plenty of water. 

SKIN: Wash off in flowing water or shower. 

INGESTION: Do not induce vomiting. Call a physician and/or 

(Continued on page 5) 

(R) Indicates a Trademark of The Dow Chemical Company 

* An Operating Unit of The Dow Chemical Company 

% 
P.77 

Dow Chemical U.S.A.* Midland. Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: 5 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MSDS:O0O258 

7. FIRST AID: (CONTINUED) 

transport to emergency facility immediately. 

INHALATION: If inhaled, remove to fresh air. If not breathing, 

resuscitate. If breathing is difficult, oxygen should be 

administered by qualified personnel. Call a physician or 

transport to a medical facility. 

NOTE TO PHYSICIAN: Because rapid absorption may occur through 

lungs if aspirated and cause systemic effects, the decision of 

whether to induce vomiting or not should be made by a 

physician. If lavage is performed, suggest endotracheal and/or 

esophageal control. Danger from lung aspiration must be 

weighed against toxicity when considering emptying the stomach. 

If burn is present, treat as any thermal burn, after 

decontamination. No specific antidote. Supportive care. 

Treatment based on judgment of the physician in response to 

reactions of the patient. Repeated excessive exposure may 

aggravate preexisting liver and kidney disease. 

8. HANDLING PRECAUTIONS: 

EXPOSURE GUIDELINE (S): Styrene, monomer: ACGIH TLV and OSHA PEL 

are 50 ppm TWA, 100 ppm STEL. 

VENTILATION: Control airborne concentrations below the exposure 

guideli ne. 

RESPIRATORY PROTECTION: Atmospheric levels should be maintained 

below the exposure guideline. When respiratory protection is 

required for certain operations, use an approved air-purifying 

respirator. 

SKIN PROTECTION: Use protective clothing impervious to this 

material. Selection of specific items such as gloves, boots, 

(Continued on page 6) 

(R) Indicates a Trademark of The Dow Chemical Company 

* An Operating Unit of The Dow Chemical Company 

U 
D ow Chemical U.S.A.* Midland. Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: 6 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MSDS:000258 

8. HANDLING PRECAUTIONS: (CONTINUED) 

apron, or full-body suit will depend on operation. 

EYE PROTECTION: Use chemical goggles. If vapor exposure causes 

eye discomfort, use a full-face respirator. 

9. ADDITIONAL INFORMATION: 

SPECIAL PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: 

Practice care and caution to avoid explosive conditions. 

Equipment should be grounded during transfer, and non-sparking 

pumps should be used. 

Hazardous polymerization can occur under certain conditions, 

including increased temperature, low inhibitor concentration, 

and low oxygen concentration. To minimize this possibility, 

store in a cool place away from direct sunlight and maintain 

proper concentrations of TBC inhibitor and oxygen. Monitor and 

control inhibitor level at >5 ppm and the dissolved oxygen 

level at a minimum of 15 ppm. The monomer should be aerated 

once a week for about 30 minutes. Store below 90F, 32C; ideal 

storage temperature is 78F, 26C or lower. Avoid skin and eye 

contact. Avoid breathing vapors. Refer to bulletin 115-608, 

"The Oow Family of Qfyropi/- "^""r 1 1 , 

MSDS STATUS: Revised section 3. 6, 7 and 8. 

For information regarding state/provincial and federal regulations see 

(R) Indicates a Trademark of The Dow Chemical Company 

* An Operating Unit of The Dow Chemical Company 

^ r 
P.79 

D o w Chemical U.S.A.* Midland, Ml 48674 Emergency Phone: 517-636-4400 

Product Code: 81352 Page: R-l 

Product Name: STYRENE MONOMER 

Effective Date: 10/17/90 Date Printed: 07/03/91 MS0S:OOO258 

REGULATORY INFORMATION: (Not meant to be all-inclusive—selected 

regulations represented.) 

NOTICE: The information herein is presented in good faith and believed 

to be accurate as the effective date shown above. However, no 

warranty,! express or implied, is given. Regulatory requirements are 

subject to change and may differ from one location to another; it is 

the buyer's responsibility to ensure that its activities comply with 

federal, state or provincial, and local laws. The following specific 

information is made for the purpose of complying with numberous federal, 

state or provincial, and local laws and regulations. See MSD Sheet for 

health and safety information. 

U.S. REGULATIONS 

SARA 313 INFORMATION: This product contains the following substances 

subject to the reporting requirements of Section 313 of Title I I I of 

the Superfund Amendments and Reauthorization Act of 1986 and UO CFR 

Part 372:' 

CHEMICAL NAME CAS NUMBER CONCENTRATION 

STYRENE 000100-I.2-5 99 * 

SARA HAZARD CATEGORY: This product has been reviewed according to the 

EPA "Hazard Categories" promulgated under Sections 311 and 312 of the 

Superfund Amendment and Reauthorization Act of 1986 (SARA Title III) and 

is considered, under applicable definitions, to meet the following 

categories: 

An immediate health hazard 

A delayed health hazard 

A fire hazard 

A reactive hazard 

(Continued on page R-2) 

(R) Indicates a Trademark of The Oow Chemical-Company 

* An Operating Unit of The Dow Chemical Company 

yt 
P.80 

i 250ini per \<NU ai a test temperature 01 55'C (I30T). as 

•Jetem-uned by jpecme test method 261 21. 

If ii is a solid waste thai exhibits the characteristic of corrosivity. but is not listed as a hazardous waste in subpart D. 

then il has the EPA hazardous waste number of D 002. 

Reactivity 

The reactivity characteristic identifies waste which under 

routine conditions presents a hazard because of instability or extreme reactivity, and the tendency to explode. A material is considered reactive if a representative sample ofthe waste has any of 

the following propenies: 

I. 

Composition/ Liquid 

2. 

3. 

4. 

5. 

6. 

If it is normally unstable and readily undergoes violent change 

without detonating. 

If it reacts violently with water. 

If it forms potentially explosive mixtures with water. 

if. when mixed with water, it generates toxic gases, vapors or 

fumes in a quantity sufficient to present a danger to human 

health or environment. 

If it is a cynaide- or sulfide-bearing waste, which, when exposed to pH conditions between 2 and 12.5. can generate toxic 

gases, vapors or fumes in a quantity sufficient to present 

danger to human health or environment. 

If it is capable of detonation or explosive reaction when subjected 10 a j'.rong initiating source or if healed under confinement. 

If ii is readily capable of detonation or explosive decomposition or reaction at standard temperature or pressure. 

If it is a forbidden explosive as defined in 49 Code of Federal 

Regulations 173.51, or a Class A explosive as defined in 49 

Code of Federal Regulations 173.53, or a Class B explosive as 

defined in 49 Code of Federal Regulations 173.88. 

If it is a solid waste that exhibits the characteristic of reactivity, 

but is not listed as a hazardous waste in subpan D, then it has 

the EPA Hazardous Waste number of D 003. 

Toxicity 

The toxicity characteristic identifies waste which may release 

toxic materials in sufficient amounts to pose a substantial hazard to 

human health or the environment. 

1. If the extract from a representative sample of waste contains 

any of the contaminants listed in Table I of 40 Code of Federal 

Regulations 261.21 at a concentration equal to or greater than 

the respective value given in that table. Where the waste contains less than O.S percent filterable solids, the waste itself after 

filtering is considered to be the extract for the purpose of this 

section. (Determined using specific test methods described in 

Appendix II.) 

2. If it is a solid waste that exhibits the characteristic of extraction 

procedure toxicity, but is not listed as a hazardous waste in subpan D, has the EPA Hazardous Waste number specified in 

Table I of 40 Code of Federal Regulations 261.21 which corresponds to the toxic contaminant causing it to be hazardous. 

THE PULTRUSION PROCESSING FACILITY 

Hazardous Wtste Classification 

The following pultrusion mix fonnulation was used as a typical 

sample submitted for waste characterization analysis. In iu liquid 

sttte it was determined to be a hazardous waste based upon its 

ignitability. 

2 /SESSION 12-A 

Unsaturated polyester Res 

Siyrene 

in (in styrene) 

Polyvinyl Acetate Copolymer 

Pigment Components 

Inorganic Filler 

Magnesium Carbonate 

Alcohol Phosphate 

pH 

Density 

1. Corrosivity 

2. Reactivity-Sulfide 

Cyanide 

3. Flash Point 

4. EP Toxicity (mg/L) 

Arsenic 

Silver 

Barium 

Cadmium 

Chromium 

Mercury 

Lead 

Selenium 

NA = Non-Applicable 

Waste Analysis 

Results 

NA 

1.04 g/ml 

<1 mm/year 

<0.1 mg/kg 

<0.1 mg/kg 

75*F (24*Q 

<0.05 

<0.02 

<1.0 

<0.0I 

<0.27 

<0.001 

<0.02 

<0.05 

58-W* 

15-20% 

2-4% 

0.50-0.77% 

16.32-24.32% 

130-0.32% 

0.05-1.0% 

EPA Standard 

(Max. Allowable) 

>6.35 mm/year 

500 mg/kg 

2S0 mg/kg 

< 140#F (60*C) 

5.0 

5.0 

100.0 

1.0 

5.0 

0.02 

S.O 

1.0 

The preceding pultrusion mix fonnulation after solidification 

was used as a typical sample submitted for waste characterization 

analysis and in its solid sute was evaluated as non-hazardous, as it 

did not exceed established limits for the four basic criteria defined. 

Composition/Solid 

Unsaturated polyester Resin (in styrene) 

Styrene 

Polyvinyl Acetate Copolymer 

Pigment Components 

Inorganic Filler 

Magnesium Carbonate 

Alcohol Phosphate 

Bis (4-4 Butylcyclohexyl) Peroxydicarbonate 

± Butyl Perbenzoate 

pH 

Density 

1. Corrosivity 

2. Reactivity-Sulfide 

Cyanide 

3. Flash Point 

4. EP Toxicity (mg/L) 

Arsenic 

Silver 

Barium 

Cadmium 

Chromium 

Mercury 

Lead 

Seleneum 

Waste Analysis 

Resulu 

NA 

1.04 g/ml 

1 mm/year 

0.1 mg/kg 

0.1 mg/kg 

230°F (110#C) 

0.05 

0.02 

I.O 

0.01 

0.07 

0.001 

0.06 

O.OS 

73-83% 

0.5% 

2-4% 

0.50-0.77% 

16.32-24.32% 

0.30-0.32% 

0.05% 

0.40-0.80% 

0.20-0.40% 

EPA Standard 

(Max. Allowable) 

6.3S mm/year 

500 mg/kg 

250 mg/kg 

140#F (60#C) 

5.0 

5.0 

100.0 

1.0 

5.0 

0.20 

S.O 

1.0 

NA = Non-Applicable 

The cost of the waste characterization analysis by an independent lab is approximately $110000 and will take 4-6 weeks. 

Q y] 

K3 
P.81 

<\ 

The material in us sohd <SJIC IS mw-ha/jrdous and can be disposed of without regulations. The material in its liquid stale is a 

hazardous waste and is regulated under RCRA. and must be sent 

o a federally approved hazardous waste management facility 

transported solely by EPA authorized transporters. In order to do 

so. you must notify the Environmental Protection Agency or your 

authorized State Agency of your activities and apply for a U.S. 

EPA identification number. You can satisfy these requirements by 

filling Form 8700-12 'Notification of Hazardous Waste Activity," 

submitting one notification form per sice or location. All information you submit in the notification can be released to the public. 

RCRA requires an EPA identification number and a hazardous 

waste manifest io accompany the waste to its final destination. The 

manifest is a tracking document designed to record the movement 

of hazardous waste from the generator's premises to the authorized 

off-site treatment, storage, or disposal facility. On-site waste management does not require a manifest. At this time, the Environmental Protection Agency allows waste treatment without 

pennit but does caution the policy may be changed. This allows 

small companies to treat hazardous waste, to react on-site unused 

thermosetting plastic rcsin into inert solid wastes, without a permit 

as long as the waste is treated within 180 days and the volume of 

accumulated waste does not exceed 6000 kg (13,200 lbs.) at any 

one time. 

EMISSION CONTROLS 

Understanding how to determine if your waste is hazardous and 

how to dispose of it is an importam first step, if you are a manufacturer of fiberglass reinforced plastic composite profiles, you also 

have to comply with your State's regulations on plant operations. 

All permits and regulations referred to in the following discussion will be in regard to a new pultrusion facility in Ohio. The 

Ohio Environmental Protection Agency requires an application for 

pennit to install for all new or modified sources of pollution under 

the provisions of OAC Rule 3745-31. 

The significant information required on this permit is a description of the product or service to be produced and a description of 

the source or facility. Also include a list naming all materials and 

chemicals and quantities that will be used or produced by the 

source or facility. For all air pollution sources you are required to 

provide actual (if measured) or estimated emissions stating the 

amount of each air contaminant from each source in pounds per 

hour and tons per year at maximum and average conditions. 

For example, the sources of emission will be: 

Source Maximum* 

1. Pultrusion Machine (monomer emissions at resin bath 

and die exit) 

2 Mix Room (monomer) . 

Dust Collection 

Cut off saws 

Mat Slitting 

Fiber collection 

HX) CFM. 200 PPM = .33 

lbs/hr* or 1.38 tons/yr 

100 CFM. 20& PPM = 33 

lbs/hr* or 1.38 tons/yr 

350 CFM = .056 lbs/hr or 

.23 tons/yr* 

500 CFM = .14 Ibs/hr or 

.58 tons/yr* 

"Average to be determined based on level of operation after a reasonable 

period of time. 

'Lbs/hr based on 24 hours per day. 348 days per year operation. 

'Oust collection estimated on an average product weight of material displaced by the thickness of the anting blade. 

'Mat tlining estiinated on an avenge amount of slit widths per roll of 

material displaced by the thickness of the slining blade. 

The applicant must suic thai he will U M ihe best available technology, or technology that is recognized as acceptable throughout 

the pultrusion industry and considered standard and cost effective 

to control emissions. This can be accomplished by the use of resins 

wuh low levels of styrene nwnomer. exposure of as little styrene 

monomer or styrenated resin to the atmosphere as possible, the use 

of smaller and deeper containers, keeping containers of this 

material covered (or as closed as possible) and finally collecting 

dust (fiberglass particulates) which is exhausted into a high efficiency collector system. 

An Appendix (Appendix A. Process Data) for each air contaminant source must accompany the application. The significant information required in the Appendix is a process flow diagram 

showing entry and exit points of all raw materials, intennediate 

products, by-products, and finished products. Emission data 

should be included whether it is actual or theoretically determined. Figure I is a flow diagram of a pultrusion machine line showing all information that is required. Data was collected with a toxic 

gas detector at the liquid entry and finished product exit points 

(Exhaust I). With an exhaust duct velocity set at 85 CFM at bot 

points, the highest reading achieved was IOO PPM directly over th< 

liquid entry and 25 PPM at the finished product exit (see Table I) 

Figure 1 shows dust collection of fiberglass particulates (Exhausi 

2) at the saw station, which was estimated based on an avtragt 

product weight of material displaced by the cutting blade thick 

ness. Figure 2 is a flow diagram of a mix room showing all information that is required, along with dala collected using the ume 

gas detector with the same exhaust duct velocity. I2S PPM directly 

over the mixer was the highest reading achieved (see Table 2). 

Figure 3 shows the dust collection of fiberglass particulates 

(Exhaust 2) at the mat slitter, which was estimated based on an 

average amount of slit widths per roll of material displaced by the 

slitting blade thickness. The final approval of the "Permits to Install* normally will take 3-4 months at a cost of $1500 for each 

source of emission. For example, a two-machine operation with 

mixing and slitting capability would have six emission sources 

based on the flow charts described. 

When you have received final approval of the pennit to install, 

you must notify the appropriate district office of the EPA or local 

air agency, in writing, of the construaion starting date, the construction completion date, and the date the facilities will be placed 

in operation. They will then send an application for a pennit to 

operate. This permit cover sheet requires information similar to 

the permit to install. If no changes have occurred, the previously 

completed Appendix A (Process Data) can be attached to the application. The final approval of the "Permits to Operate* normally 

will take 2-3 weeks at an additional cost of $15.00 for each source 

of emission. 

CONCLUSIONS 

The disposal of solid and hazardous waste has been a grave concern not only to the Federal Government, but also the public. Disposal of materials has become increasingly more difficult because 

of the continuing technological advances in development of raw 

materials and methods of manufacturing, and the potential long 

term changes in raw materials that are discarded. Disposal of solid 

and hazardous waste in or omo land without careful planning and 

management can present a danger to human health and the environment. 

The objectives of the Regulatory Programs are to promote the 

protection of health and the environment and to develop waste 

management plans (RCRA) which will promote improved waste 

management techniques and environmentally safe disposal of nonrecoverable residues. Other waste management systems such as 

Subtitle C of the Code of Federal Regulations enforces a "cradle to 

grave" control approach. 

KA 

^D 

SESSION I2-A/3 

( 
P.82 

Tlie icmforced plastics industry h.is become a focal point f.ir 

Federal and Sute agencies concerning styrene and paniculate 

emissions inside a facility as well as transferring these emissions 

outside the facility. All of the regulations and requirements ire 

time consuming and costly, but they do slow down the chain of 

events of contaminating the environment. Hopefully, the reinforced plastics industry will continue to take a constructive role in 

reaching solutions to problems and minimizing the need for excessive regulation in the future. 

RKFERENCKS 

1. Code of Federal Regulations Title «0 ftiru 190-399. Subchapter I Solid 

U-aMo. Pafu 26a 261. 262 {Revised as of July I. 1985). 

2. "Environmental Protection Agency Hazardous Wisie Proposed Guidelines and Regulations ind Proposed on Identification ind Listing." 

Federal Refiner. Part IV (December 18. 1978). 

.V The Resource Cooservition and Recovery Act. Public Law 94-580. 

94th Congress (Ociober 21. 1976). 

BIOGRAPHIES 

Kenneth J. Elias 

Mr. Kenneth J. Elias is the Director of Manufacturing for 

Pultrusion Technology. Inc. and Viapul Corporation. He received 

an associates degree in Electro-Chemical Technology from Cleveland Institute of Technology in 1969. After spending seven yean at 

Firestone Tire and Rubber Company in plastic processing research. Mr. Elias joined a division of Monogram Industries and 

spent six yean as a process engineer in the pultruded products 

group. 

In 1982, Ken Elias joined Pultrusion Technology. Inc. In 1986. 

Ken Elias. Jeff Martin, and Joe Sumerak formed Viapul Corpora' 

tion. a pultrusion manufacturing development entity. 

Dawn K. Wilkins 

Mrs. Dawn K. Watkins is a 1967 graduate of Miami University 

of Ohio where she obtained a Bachelor of Science Degree in Applied Science. She has spent ten years in a supervisory position in 

the graphics and graphics management function with a great deal 

of customer service responsibility. 

ln early 1986, Mn . Watkins came to Pultrusion Technology, Inc. 

as Sales Service Administrator. In this role, she functions externally in a customer service role while internally she is responsible for 

the establishment and integration of systems to pennit a smooth interaction between departments at Pultrusion Technology, Inc. 

TABIE 1. Appendix A of "Permit lo Operoie." 

EMISSIO N DATA * 

Exhaust 1 - Machine Emission 

Test No. 

I 

1 

2 

3 

4 

5 

6 

7 

8 

Resin Station/ 

Liquid Entry 

35 PPM 

100 PPM 

95 PPM 

30 PPM 

35 PPM 

50 PPM 

30 PPM 

50 PPM 

Exhaust 1 

Finished Product 

Exit 

15 PPM 

5 PPM 

25 PPM 

8 PPM 

15 PPM 

"* 20 PPM 

10 PPM 

15 PPM 

Mix Room Emission 

f\J. 

Test No. 

1 

2 

3 

- 4 

5 

6 

High Dispersion Mixer 

40 PPM 

35 PPM 

80 PPM 

8 5 PPM 

125 PPM 

95 PPM 

#0 

A 

* Duct velocity set at 85 CFM, PPM readings with toxic gas 

detector I8014-400A 

4/SESSION 12-A 

% 

K' 
P.83 

Marvin Windows 

Window and Door Lineals Plant 

Proposed Permit to Construct 

Appendix B 

Division of Environmental Engineering 

North Dakota State Department of Health 

and Consolidated Laboratories 

1200 Missouri Avenue, Room 304 

Box 5520 

Bismarck, ND 58502-5520 

yx 
P.84 

(Proposed) 

AIR POLLUTION CONTROL 

PERMIT TO CONSTRUCT 

Pursuant to the Air Pollution Control Rules of the State of North 

Dakota (Article 33-15 of the North Dakota Administrative Code), the 

North Dakota State Department of Health and Consolidated 

Laboratories hereby grants a Permit to Construct for the following 

facility: 

I. General information: 

i 

i 

A. Source: 

1. Name: Marvin Windows 

2. Location: 15th Avenue & 44th Street NW 

Fargo, North Dakota 58102 

3. Source Type: Window and Door Lineals Plant 

4. Equipment at the Facility: 

a. Five pultrusion machines, Pulsar Models 805 

and 1606. 

b. Mixing room and resin bulk tank room (4-6,000-

gallon storage tanks). Resin consists of 

, styrene and methyl methacrylate. 

c. One matslitter, Pulsar Model 7824. 

O Hi 
P.85 

d. Five cut-off saws. 

e. Tool and die room. 

The facility will utilize the following air pollution 

control equipment: 

1. Catalytic oxidizer for the control or volatile 

organic compounds. The exhaust for the catalytic 

oxidizer will be vented to the outside air. 

2. Bagfilter for the control of particulate matter 

(fiberglass). The exhaust for the bagfilter will 

be vented back into the building. 

B. Owner/Operator (Permit Applicant): 

1. Name: Marvin Windows 

2. Address: 804 3 24th Avenue South 

Minneapolis, MN 55425 

3. Application Date: July 8, 1991 

This Permit to Construct is subject to all applicable rules, 

regulations, and orders now or hereafter in effect of the North 

Dakota State Department of Health and Consolidated Laboratories and 

to the conditions specified below: 

y 
P.86 

II. Permit Conditions: 

A. Special Conditions: 

1. Emission Limits: The emissions of air contaminants 

from the source unit shall not exceed the following 

rates: 

Source Unit Contaminant •Emission Rate 

Catalytic Oxidizer Styrene 

Methyl Methacrylate 

Odors 

0.528 lb/hr 

0.102 lb/hr 

2 odor concentration 

units 

*The catalytic oxidizer must also control volatile organic 

compound emissions from the source unit by at least 95%. 

2. Performance Testing: Following completion of 

construction and within 60 days after achieving the 

maximum production rate at which the facility will 

be operated, but not later than 180 days after 

initial start-up of the facility, the owner or 

operator shall conduct performance tests of the 

catalytic oxidizer as specified by this Department. 

Additional requirements are as follows: 

45 
P.87 

a. Test methods and procedures used shall be 

those set forth in the North Dakota Air 

Pollution Control Rules, 40 CFR Part 60, 

Subpart V W - Standards of Performance for 

Polymeric Coating of Supporting Substrates 

Facilities, or equivalent methods approved by 

the Department and the U.S. Environmental 

Protection Agency. Performance test 

guidelines shall be obtained from this 

Department prior to developing testing 

procedures to ensure they will comply with the 

specified requirements. 

b. The Department shall be notified 30 days prior 

to the date of the tests to allow for a 

pretest meeting with the Department and to 

afford the Department the opportunity to have 

an observer present. The test results shall 

be submitted to the Department for review and 

approval. 

c. Safe sampling platforms shall be provided. 

Utilities for sampling and testing equipment 

shall be provided. Plans and specifications 

showing the size and location of the ports, 

platforms and utilities shall be submitted to 

the Department for review and approval. 

U 
P.88 

3. The facility must comply with all applicable 

provisions outlined in 40 CFR Part 60, Subpart V W 

- Standards of Performance for Polymeric Coating of 

Supporting Substrates Facilities. 

B. General Conditions: 

1. This permit shall in no way permit or authorize the 

maintenance of a public nuisance or danger to 

public health or safety. 

2. The owner/operator identified in Item I.B. of this 

permit shall comply with all State and Federal 

environmental laws and rules. In addition, the 

owner/operator shall comply with all local 

building, fire, zoning, and other applicable 

ordinances, codes, rules and regulations. 

3. Construction of the above described facility shall 

be in accordance with information provided in the 

permit application as well as any plans, 

specifications and supporting data submitted to the 

Department. The Department shall be notified ten 

days in advance of any significant deviations from 

the specifications furnished. The issuance of this 

Permit to Construct may be suspended or revoked if 

the Department determines that a significant 

43-
P.89 

deviation from the plans and specifications 

furnished has been or is to be made. 

4. All reasonable precautions shall be taken by the 

owner to prevent and/or minimize fugitive emissions 

during the construction period. 

5. Within thirty days after completion of 

construction, this Department must be notified of 

the date of completion of construction and the 

actual or proposed date of startup. 

6. Any duly authorized officer, employee or agent of 

the North Dakota State Department of Health and 

Consolidated Laboratories may enter and inspect any 

property, premise or place at which the source 

listed in Item I.A. of this permit is or will be 

located at any time for the purpose of ascertaining 

the state of compliance with the North Dakota Air 

Pollution Control Rules and the conditions of this 

permit. 

7. Any violation of a condition issued as part of this 

approval to construct as well as any construction 

which proceeds in variance with any information 

submitted in the application, is regarded as a 

violation of construction authority and is subject 

1% 
to enforcement action. 

8. This Permit to Construct shall become invalid if 

construction is not commenced within eighteen 

months after receipt of such permit, if 

construction is discontinued for a period of 

eighteen months or more; or if construction is not 

completed within a reasonable time. 

9. This Permit to Construct is issued in reliance upon 

the accuracy and completeness of the information 

set forth in the application. Notwithstanding the 

tentative nature of this information, the 

conditions of this permit herein become, upon the 

effective date of this permit, enforceable by the 

Department pursuant to any remedies it now has or 

may in the future have, under the North Dakota Air 

Pollution Control Law, NDCC Chapter 23-25. Each 

and every condition of this permit is a material 

part thereof, and is not severable. 

FOR THE NORTH DAKOTA STATE 

DEPARTMENT OF HEALTH AND 

CONSOLIDATED LABORATORIES 

Date By_ 

Dana K. Mount, Director 

Division of Environmental 

Engineering 

a T| 
P.91 

Marvin Windows 

Window and Door Lineals Plant 

Proposed Permit to Operate 

Appendix C 

Division of Environmental Engineering 

North Dakota State Department of Health 

and Consolidated Laboratories 

1200 Missouri Avenue, Room 304 

Box 5520 

Bismarck, ND 58502-5520 

°1D 
P.92 

(Proposed) 

AIR POLLUTION CONTROL 

PERMIT TO OPERATE 

Pursuant to Chapter 23-25 of the North Dakota Century Code, and the Air 

Pollution Control; Rules of the State of North Dakota, and in reliance on 

statements and representations heretofore made by the owner designated below, 

a Permit to Operate is hereby issued authorizing such owner to operate the 

source unit(s) at the location designated below. This Permit to Operate is 

subject to all applicable rules and orders now or hereafter in effect of the 

North Dakota State Department of Health and Consolidated Laboratories and to 

any conditions specified below: 

1. Owner: 

A. Name 

Marvin Windows 

B. Address 

8043 24th Avenue S 

Minneapolis, MN 55425 

2. Permit Number 

3. Installation 

Window & Door Lineals Plant 

4. Installation Location 

15th Avenue & 44th Street NW 

Fargo, North Dakota 58102 

Cass County 

5. Expiration Date: 

6. Source Unit(s): 

A window and door lineals plant consisting of the following process 

equipment: 

1) Five pultrusion machines, Pulsar Models 804 and 1606. 

2) Mixing room and resin bulk tank room (4-6,000-gallon storage 

tanks). Resin consists of styrene and methyl methacrylate. 

3) One matslitter, Pulsar Model 7824. 

4) Five cut-off saws. 

5) Tool and die room. 

The facility will utilize the following air pollution control equipment: 

1) Catalytic oxidizer for the control of volatile organic compounds. 

The exhaust for the catalytic oxidizer will be vented to the 

outside air. 

qi 
2) Bagfilter for the control of particulate matter (fiberglass). The 

exhaust for the bagfilter will be vented back into the building. 

CONDITIONS 

7. A. Emission Limits: Emission limits from the operation of the major 

source unit(s) identified in Item 6 of this Permit to Operate 

(hereafter referred to as "permit") are as follows: 

Source* Air **Emission 

Unit Contaminant Limit 

Catalytic Styrene 0.528 lb/hr 

Oxidizer Methyl Methacrylate 0.102 lb/hr 

•Minor source units not listed are subject to the applicable 

emission limits specified in the North Dakota Air Pollution Control 

Rules. 

••The catalytic oxidizer must also control volatile organic 

compound emissions from the source unit by at least 95%. 

B. Fugitive Emissions: All reasonable precautions shall be taken by 

the owner/operator to prevent and/or minimize fugitive emissions to 

the outside air from the operation of the source unit(s) identified 

under Item 6. 

C. Emission Inventory Reports: Emission inventory reports including, 

but not limited.to process information regarding the amount and 

type of volatile organic compounds used and air contaminants 

emitted, shall be submitted to the Department, upon request, on 

forms supplied by the Department. 

D. Source Operations: The owner/operator shall operate the source 

unit(s) described in Item 6 of this permit in accordance with 

statements, representations, procedures and supporting data 

contained in the initial application, and any supplemental 

information or renewal application(s) submitted thereafter. 

E. Alterations, Modifications or Changes: Any alteration, rebuilding, 

repairing, expansion, change in the method of operation, or change 

of location of the source which results in the emission of an 

additional type or greater amount of air contaminants or which 

results in an increase in the ambient concentration of any air 

contaminant, must be reviewed and approved by the Department prior 

to the start of such alteration, rebuilding, repairing, expansion, 

change in the method of operation, or change of location. 

F. Nuisance or Danger: This permit shall in no way authorize the 

maintenance of a nuisance or a danger to public health or safety. 

^ 
G. Malfunction Notification: The owner/operator shall notify the 

Department of any malfunction which can be expected to last longer 

than twenty-four hours and can cause the emission of air 

contaminants in violation of applicable rules and regulations. 

H. Permit Renewal and Invalidation: This permit shall be effective 

from the date of its issuance until the date specified in Item 5 

unless sooner suspended, revoked or surrendered. Application for 

renewal of this permit shall be submitted sixty days prior to such 

expiration date. The Department shall approve or disapprove the 

renewal of the permit within sixty days of receipt of the renewal 

application. 

I. New Source Performance Standards: The facility shall comply with 

the requirements of 40 CFR Part 60, Subpart V W - Standards of 

Performance for Polymeric Coating of Supporting Substrates 

Facilities. 

J. Odor Restriction: This permit shall in no way authorize the 

discharge of any objectionable odorous air contaminant which is in 

excess of two odor concentration units outside the property 

boundary. 

K. Change of Ownership: This permit may not be transferred and is to 

be returned to the Department upon the destruction or change of 

ownership of the source unit(s), or upon expiration, suspension or 

revocation of this permit. 

L. Right of Entry: Any duly authorized officer, employee or agent of 

the North Dakota State Department of Health and Consolidated 

Laboratories may enter and inspect any property, premise or place 

at which the source listed in Item 6 of this permit is located at 

any time for the purpose of ascertaining the state of compliance 

with the North Dakota Air Pollution Control Rules. The Department 

may conduct tests and take samples of air contaminants, fuel, 

processing material, and other materials which affect or may affect 

emissions of air contaminants from any source. The Department 

shall have the right to access and copy any records required by the 

Department's rules and to inspect monitoring equipment located on 

the premises. 

M. Other Regulations: The owner/operator of the source unit(s) 

described in Item 6 of this permit shall comply with all State and 

Federal environmental laws and rules. In addition, the 

owner/operator shall comply with all local burning, fire, zoning, 

and other applicable ordinances, codes, rules and regulations. 

N. Permit Issuance: This permit is issued in reliance upon the 

accuracy and completeness of the information set forth in the 

application. The conditions of this permit herein become, upon the 

effective date of this permit, enforceable by the Department 

pursuant to any remedies it now has, or may in the future have, 

under the North Dakota Air Pollution Control Law, NDCC Chapter 23-

Vr 
P.95 

25. Each and every condition of this permit is a material part 

thereof, and is not severable. 

FOR THE NORTH DAKOTA STATE 

DEPARTMENT OF HEALTH AND 

CONSOLIDATED LABORATORIES 

Date , By. 

Dana K. Mount, Director 

Division of Environmental 

Engineering 

°tA 
P.96 

Marvin Windows 

Window and Door Lineals Plant 

Department Policy for the Control of 

Hazardous Air Pollutant Emissions 

in North Dakota 

(Air Toxics Policy) 

Appendix D 

Division of Environmental Engineering 

North Dakota State Department of Health 

and Consolidated Laboratories 

1200 Missouri Avenue, Room 304 

Box 5520 

Bismarck, ND 58502-5520 

q^> 
P.97 

POLICY FOR THE CONTROL OF HAZARDOUS 

AIR POLLUTANT EMISSIONS IN NORTH DAKOTA 

(Air Toxics Policy) 

PURPOSE 

This document establishes the policy to be used by the North Dakota 

State Department of Health and Consolidated Laboratories, Division 

of Environmental Engineering, for the evaluation of permit 

applications from sources emitting Hazardous Air Pollutants (HAP's) 

into .the ambient air. This policy document is effective until 

modified by the Department or formal rules are promulgated. 

APPLICABILITY 

This document is applicable to all new or modified air contaminant 

sources, as designated in 33-15-14-01 of the North Dakota Air 

Pollution Control Rules, required to submit an application for 

Permit to Construct under Section 02 of Chapter 33-15-14. This 

includes: (1) all sources designated as Air Contaminant Sources; 

(2) any category of sources subject to a state or federal New 

Source Performance Standard (NSPS); (3) any source subject to 

review under state or federal Prevention of Significant 

Deterioration of Air Quality (PSD) Rules; (4) any source whose 

emissions impact significantly state or federal Ambient Air Quality 

Standards (AAQS); and (5) any source subject to National Emission 

Standards for Hazardous Air Pollutants (NESHAP). 

Certain, additional sources of HAP's will be considered for 

emission control by the Department on a case-by-case basis or as 

deemed appropriate. These may include "nontraditional" sources 

such as air strippers for the removal of organic contaminants from 

groundwater, ethylene oxide sterilizers, or any existing or new 

source where there is reason to believe that HAP's being emitted 

pose a significant risk to human or environmental health. 

Sources affected by this document are required to complete an Air 

Pollution Permit Application (AP 100) if an application has not 

been submitted, a HAP Permit Application (AP-117), and any 

additional information needed by the Department to evaluate the 

potential human or environmental risk from HAP's. 

AUTHORITY 

The Department has authority to control HAP emissions under Chapter 

33-15-02-04, subsection 3 of the North Dakota Air Pollution Control 

Rules which states, "The ambient air shall not contain air 

contaminants in concentrations that would be injurious to human 

health or well-being or unreasonably interfere with the enjoyment 

of property or that would injure plant or animal life. The 

Department may establish, on a case-by-case basis, specific limits 

of concentration for these contaminants." 

C\ 

% 
P.98 

by various local, state and federal rules. Particulate matter less 

than 10 microns in diameter (PM ), sulfur dioxide, nitrogen 

dioxide, carbon monoxide, and lead emissions are regulated by 

placing emissions limits on designated air contaminant sources. 

The Federal NSPS program regulates, in addition to the previously 

mentioned pollutants, the emission rates of fluoride, sulfuric acid 

mist, hydrogen sulfide, reduced sulfur compounds, and volatile 

organics from select sources. Some effort has been made to control 

HAP's on the federal and state levels through the NESHAP program. 

However, promulgation of new NESHAP's by EPA has been slow, 

requiring 4-5 years. Presently four pollutants, asbestos, 

beryllium, mercury, and vinyl chloride are designated NESHAP's 

under the state regulations with three additional pollutants, 

benzene, radionuclides, and arsenic, regulated at the federal level 

for certain facilities. Also, the NESHAP program has concentrated 

on pollutants posing a national health risk, not a local health 

risk. Small population centers are often overlooked in the federal 

process. 

Increased local and national concern about the release of 

hazardous/toxic substances, the relative slowness of NESHAP 

promulgation at the federal level, and increased encouragement at 

the federal level, are the primary impetuses for a policy document 

delineating the Department's policy with respect to the control of 

routine releases of HAP's. 

APPROACH 

The approach used by the Department to evaluate permit applications 

for sources releasing HAP's into the ambient air is based upon 

classification of the HAP into one of the three categories 

(discussed below), where each category represents the present 

certainty of a substance being a human carcinogen. Substances are 

classified as known human carcinogens, suspected or reasonably 

anticipated human carcinogens, and as noncarcinogens or substances 

lacking sufficient data to determine carcinogenicity. It is the 

Department's position that the classification of a substance as a 

known or suspected human carcinogen will be based on determinations 

made by either: (1) the International Agency for Research on 

Cancer (IARC); (2) the National Toxicology Program (NTP); or (3) 

the American Conference of Governmental Industrial Hygienists 

(ACGIH). These agencies are recognized experts in the disciplines 

of toxicology and carcinogenesis. Other substances not classified 

as a known or suspected human carcinogen by one of these agencies 

will be regulated by using adjustments to the Threshold Limit 

Value-Time Weighted Average (TLV-TWA), the Threshold Limit ValueShort Term Exposure Limit (TLV-STEL), or the Threshold Limit ValueCeiling (TLV-C), as published by the ACGIH (1990). Additional 

pollutants not listed in the ACGIH handbook which pose a 

significant health risk, either directly or indirectly, will be 

evaluated on a case-by-case basis. 

Q 
P.99 

the list of Group 3 substances. These substances have been removed 

based on the Department's determination that the ambient standard 

for PM10 adequately addresses emissions of these substances. 

The ACGIH (1990) defines the TLV-TWA as the time-weighted average 

concentration for a normal 8-hour workday and a 40-hour work week, 

to which nearly all workers may be repeatedly exposed, day after 

day, without adverse effect. The TLV-STEL is the concentration to 

which workers can be exposed to continuously for a short period of 

time without suffering from: (1) irritation; (2) chronic or 

irreversible tissue damage; or (3) narcosis of sufficient degree to 

increase the likelihood of accidental injury, impair self-rescue or 

materially reduce work efficiency, and provided that the daily TLVTWA is not exceeded. The TLV-C is the concentration that should 

not be exceeded during any part of the working exposure. Eighthour and 1-hour Maximum Acceptable Ambient Levels (MAAL) for the 

pollutants specified in Appendix 3 are established from the TLV-TWA 

and TLV-STEL/TLV-C, respectively of the ACGIH. It must be stressed 

that the MAAL for a substance is not an ambient standard. Rather, 

the MAAL will be used by the Department as a mechanism to further 

evaluate the need for control of pollutant emissions from sources 

whose modeled concentrations exceed either the 8-hour or 1-hour 

MAAL. Also, only certain substances in Appendix 3 have a 1-hour 

MAAL. These substances have been recognized by the ACGIH as having 

acute effects as well as chronic effects and have an appropriate 

TLV-STEL or TLV-C. Therefore, the Department believes an 

additional shorter averaging period is warranted for these 

substances. 

Computation, of both the 8-hour and 1-hour MAAL's are based on the 

application of certain correction factors to the TLV-TWA and TLVSTEL/TLV-C, respectively. Eight-hour MAAL's are calculated by 

first extrapolating the dose incurred during a 40-hour work week to 

an "equivalent" continuous weekly dose by dividing the TLV-TWA by 

4.2 (168/40 hours). The TLV-TWA is then adjusted by dividing by a 

factor of 1.75 representing the average lung ventilation volume of 

10 cubic meters/24 hours for a 6-year old child weighing 20 kg 

compared to the average ventilation volume of 20 cubic meters/24 

hours for an adult weighing 70 kg (Commonwealth of Massachusetts 

1985). This is done to protect children, whom for various reasons 

such as differing ventilation, absorption, and excretion rates, and 

immature immune systems, may be more susceptible to the effects of 

these pollutants. Finally, the TLV-TWA is divided by a safety 

factor of 10 to protect additional portions of the exposed 

population and provide additional safety. Therefore, the 

preliminary 8-hour MAAL is given by equation 1. 

(1) Preliminary MAALe.heur » TLV-TWA / (4.2 X 10 x 1.75) 

However, to simplify calculation of the MAAL and considering that 

divisors from 10 to 300 are presently used by a number of states 

depending on the toxicity of the substance being emitted, the 

safety factor was adjusted to 13.6, resulting in a divisor of 100. 

0 itf 
_ex 

conditions modeled with PTDIS were the same conditions used in the 

current EPA version of the PTPLU screening modal. An assumed 

mixing height of 5000 meters was used in the model to simulate 

unlimited vertical mixing. Plume rise was not simulated in the 

screening procedure; therefore, ambient temperature datum was not 

required (i.e., the PTDIS option to specify release height was 

used). 

Other simplifying assumptions made in producing Table 1 were that 

terrain or building-induced plume downwash effects were not a 

factor. For the greater release heights, the presence of either of 

these factors have a potential to increase ground-level 

concentrations. For the lower release heights, downwash effects 

may instead decrease ground-level concentrations. For most types 

of sources, the potential for increased concentrations due to these 

effects is expected to be more than offset by the fact that plume 

rise was not considered in this analysis. In fact, a review of 

many sources modeled previously by the Department indicated that 

the concentrations listed in Table 1 would be conservative for each 

of the sources modeled, which included several with elevated 

terrain or plume downwash situations. 

Based on the Department's previous modeling experience, it is 

expected that Table 1 will produce appropriate concentration 

estimates for all types of sources except for those which meet all 

of the following criteria: 

1) no plume rise, 

2) stack height greater than 10 meters, and 

3) possibility of building-induced plume downwash or terrain 

effects. 

For any sources which meet the above criteria, a source-specific 

dispersion modeling analysis should be conducted. 

Finally, the Department used an assumed emission rate of 1.0 g/sec 

to produce the estimated concentrations in Table 1. Therefore, to 

estimate the maximum 1-hour, ground-level concentration from a 

source, the pollutant emission rate in g/sec must be multiplied by 

the appropriate value in Table 1. 

Calculations 

To obtain an estimate of the maximum 1-hour off-property 

concentration using Table 1, for comparison to the 8-hour and 1-

hour MAAL, perform the following procedure: 

1) determine the release (stack) height of the pollutant 

from the source in meters (m). Ignore any plume rise. 

2) select the row in Table 1 having a release height nearest 

to, but less than or equal to, the actual release height. 

n 
P.2 

carcinogen. Also, in no case shall a source which is emitting a 

Group 1 substance that is also regulated under NSPS and NESHAP be 

allowed to obtain a variance to LAER which is less stringent than 

the requirements of NSPS or NESHAP. 

Facilities emitting more than one HAP will be given special 

consideration by the Department, because of the possibility of 

synergism between pollutants. For example, where two or more 

carcinogenic risk assessments are required, risks from the 

individual pollutants will be assumed to be additive and the 

combined maximum individual lifetime risk from all carcinogenic 

HAP'8 must be less than 1 x IO'6. Similarly, the effects of 

multiple Group 3 substances emitted from a source are assumed to be 

additive, if the available toxicity data are insufficient to 

determine otherwise. The release of multiple Group 3 HAP's into 

the ambient air will be evaluated according to equation 4; 

MC. MC. MC, MC 

(4) + + -i- + ... + - — <- 1 

MAAL, MAAL, MAAL, MAAL 

where MCX, MC., MCn are the modeled ambient concentrations for HAP's 

1, 2, ..., n and MAAL1# MAAL., MAAL. are the Maximum Acceptable 

Ambient Levels for HAP's 1, 2, ..., n. A sum of less than 1 will 

be considered acceptable, whereas a sum greater than one will 

trigger further review by the Department. 

When classifying substances as Group 1, Group 2, or Group 3, the 

Department will use the most restrictive classification where lists 

from the ACGIH, IARC, or NTP do not agree. For example, benzene is 

classified as a known human carcinogen by NTP and a Group 1 

substance by the Department, although classified as a suspected 

human carcinogen by ACGIH. As new information becomes available 

through the NTP, ACGIH, or IARC, the composition of Group 1, Group 

2, or Group 3 may change. These lists will be periodically 

reviewed by the Department. The Department will also consider 

alternative classifications for a specific Group 1, Group 2, or 

Group 3 substance and an alternative MAAL for a Group 3 substance, 

provided the affected source or person(s) can demonstrate to the 

satisfaction of the Department by presenting scientific data that 

reclassification or an alternative MAAL is more scientifically 

valid. 

Risk assessments should be conducted according to the document, 

"Guidelines for Carcinogenic Risk Assessment" published in the 

Federal Register (September 24, 1986: 33992-34003). The 

carcinogenic unit risk factors provided in Appendix D of this 

document are to be used when calculating the maximum individual 

lifetime risk of developing cancer. .The unit risk factors given in 

Appendix D are from 40 CFR Part 260; February 21, 1991. Also, 

"Guidelines for Exposure Assessment" (Federal Register, September 

24, 1986: 34042-34054) should be closely followed when performing 

the exposure assessment. The Department acknowledges the problem 

of exposure from multiple environmental pathways, but will 

presently consider only exposure through the air. Any questions 

100 
P.3 

DOCUMENTATION 

American Conference of Governmental Industrial Hygienists. 1990. 

Threshold Limit Values and Biological Exposure Indices for 1990-

1991. ISBN 0-936712-86-4. 

Code of Federal Regulations. September 24, 1986. Guidelines for 

Carcinogenic Risk Assessment, pp 33992-34003. 

Code of Federal Regulations. September 24, 1986. Guidelines for 

Exposure Assessment, pp 34042-34054. 

Commonwealth of Massachusetts. 1985. The Chemical Health Effects 

Assessment Methodology and The Method to Derive Acceptable Ambient 

Levels. Department of Environmental Quality Engineering. 

International Agency for Research on Cancer. 1982. Chemicals, 

Industrial Processes and Industries Associated with Cancer in 

Humans. IARC Monographs. Supplement 4. 

National Toxicology Program. 1982. Third Annual Report on 

Carcinogens. U.S. Department of Health and Human Services. 

National Toxicology Program. 1985. Fourth Annual Report on 

Carcinogens. U.S. Department of Health and Human Services. 

U.S. EPA. 1979. Guidance for Lowest Achievable Emissions Rates 

from 18 Major Stationary Sources of Particulates, Nitrogen Dioxide, 

Sulfur Dioxide, or Volatile Organic Compounds. EPA-450/3-79-024. 

U.S. EPA. 1985. The Air Toxics Problem in the United Statesx An 

Analysis of Cancer Risks for Selected Pollutants. Office of Air 

and Radiation, and Office of Policy, Planning and Evaluation. 100 

pp. 

State of North Dakota. December 17, 1990. Guideline for Air 

Quality Modeling Analyses. Division of Environmental Engineering. 

Code of Federal Regulations. February 21, 1991. Appendix V, Risk 

Specific Doses, pp. 7232-7233. 

11 toi 
•EA-I 

Appendix A. Group 1 hazardous air pollutants known to cause cancer 

in humans which require LAER. 

4-Aminodiphenyl 

Arsenic and inorganic compounds 

Asbestos 

Auramine 

Benzene 

Benzidine 

Bis(chloromethyl)ether (BCME) and technical grade chloromethyl 

methyl ether (CMME) 

Chromium (VI), water insoluble compounds, and zinc chromates 

Coke oven emissions 

2-Naphthylamine 

Nickel, inorganic nickel compounds (including nickel carbonyl) 

4-Nitrodipheny1 

Thorium dioxide 

Vinyl chloride 

Manufacture of Pharmaceuticals: 

Azathioprine, N,N-bis(2-chloroethyl)-2-naphthylamine 

(chlornaphazine), 1,4-Butanediol dimethylsulfonate (myleran), 

Chlorambucil, Conjugated estrogens, Cyclophosphamide, 

Diethylstilbestrol (DES), Melphalan, Mustard Gas, N,N-Bis (2-

chloroethyl)-2naphthylamine, Phenacetin, Treosulphan, certain 

chemotherapeutics 

12 [09s 
•££-* 

Appendix B. Group 2 hazardous air pollutants suspected of 

causing cancer in humans which require BACT. 

2-Acetylaminofluorene 

Acrylamide 

Acrylonitrile 

Aflatoxina 

2-Aminoanthraquinone 

1-Amino-2-methylanthraquinone 

o-Anisidine and o-anisidine hydrochloride 

Antimony trioxide 

Benzotrichloride 

Beryllium and beryllium compounds 

1,3-Butadiene 

Cadmium and cadmium compounds 

Carbon tetrachloride 

Chloroform 

4-Chloro-o-phenylenediamine 

Chrysene 

p-Cresidine 

Cupferron 

Cycasin > 

2,4-Diaminoanisole sulfate 

2,4-Diaminotoiuene 

Di(2-ethylhexyl)phthalate 

l,2-Dibromo-3-chloropropane (DBCP) (pesticide) 

1,2-Dibromoethane (EDB) 

3,3'-Dichlorobenzidine 

1,2-Dichloroethane (EDC) 

Diepoxybutane 

1,1-Dimethylhydrazine 

Diethyl sulfate 

Dimethyl sulfate 

3,3-Dimethyoxybenzidine (o-dianisidine) 

4-Dimethylamihoazobenzene 

3,3'-Dimethylbenzidine 

Dimethylcarbamoyl chloride 

1,4-Dioxane 

Direct black 38 

Direct blue 6 , 

Epichlorohydrin 

Ethyl acrylate 

Ethylene dibromide 

Ethylene oxide 

Ethylene thiourea 

Formaldehyde 

Hexachlorobenzene (HCB) 

Hexachlorobutadiene 

Hexamethylphosphoramide 

Hydrazine and hydrazine sulfate 

Hydrazobenzene 

Lead acetate and lead phosphate 

Lead chromate 

Lindane and other hexachlorocyclohexane isomers 

4,4'-Methylene bis(2-chloroaniline) (MOCA) 

13 lo3 
P.6 

Manufacture of Pharmaceuticals: 

Adriamycin, l-(2-Chloroethyl)-3-cyclohexvl-l-nitro«rt„,—. 

(CCNU), Dacarbazine, EthinylesJadiol/lron Sxtran cSJl S 

Mestranol, Metronidazole, Norethisterone, Estrogens and 

progestins (not conjugated), Estrone, Phenazopyridine 

hydrochloride, Phenytoin and sodium salt of phenvtoin 

Propylthiouracil Reserpine, Selenium sulfidS, Streptozotocin, 

Tris(1-azindmyl)phosphine sulfide, uracil, Nitrogen mustard 

15 
P.7 

Appendix C. Group 3 hazardous air pollutants which are 

noncarcinogenic or have insufficient data for classification with 

respect to carcinogenicity and their MAAL(s) ("e" denotes MAAL 

based on TLV-Ceiling). 

Acetaldehyde 

Acetic acid 

Acetic anhydride 

Acetone 

Acetonitrile 

Acetylene tetrabromide 

Acetylsalicylic acid (aspirin) 

Acrolein 

Acrylic acid 

Aldrin 

Allyl alcohol 

Allyl chloride 

Allyl glycidyl ether 

Allyl propyl disulfide 

Aluminum 

Metal dust 

Pyro powders 

Welding fumes 

Soluble salts 

Alkyls 

2-Aminopyridine 

Amitrole 

Ammonia 

Ammonium chloride fumes 

Ammonium perfluorooctanoate 

Ammonium sulfamate 

n-Amyl acetate 

sec-Amyl acetate 

Aniline and homologues 

An isidine (o-, p- isomers) 

Antimony & compounds, as Sb 

Antimony trioxide, as Sb 

ANTU 

Arsenic, soluble compounds as As 

Arsine 

Asphalt (petroleum) fumes 

Atrazine 

Azinphos-methyl 

Barium, soluble compounds, as Ba 

Barium sulfate 

Benomyl 

Benzoyl peroxide 

Benzyl chloride 

Biphenyl 

Bismuth telluride 

Se-doped 

MAAL 

8-hour 

1.8 

.25 

17.8 

.67 

.14 

.05 

.0023 

.059 

.0025 

.048 

.03 

.23 

.12 

.1 

.05 

.05 

.02 

.02 

.02 

.002 

.17 

.1 

.001 

.1 

5.32 

6.65 

.076 

.005 

.005 

.005 

.003 

.002 

.0016 

.05 

.05 

.002 

.005 

.1 

.1 

.05 

.052 

.013 

.1 

.05 

Ima/m3) 

1-hour 

2.7 

.37 

.21 

23.80 

1.01 

.006 

.095 

.06 

.47 

.18 

.24 

.2 

16 06 
P.8 

Chlorine 

Chlorine dioxide 

Chlorine trifluoride (c) 

Chloroacetaldehyde (c) 

Chloroacetone 

alpha-Chloroacetophenone 

Chloroacetyl chloride 

Chlorobenzene 

o-Chlorobenzylidene malononitrile (c) 

Chlorobromomethane 

Chlorodifluoromethane 

Chlorodiphenyl (42% chlorine) 

Chlorodiphenyl (54% chlorine) 

1-Chloro-1-nitropropane 

Chloropentafluoroethane 

Chloropicrin 

beta-Chloroprene 

o-Clorostyrene 

o-Chlorotoluene 

Chlorpyrifos 

Chromium Metal 

Chromium (II) compounds as Cr 

Chromium (III) compounds as Cr 

Chromium (VI) water soluble compounds as Cr 

Chromyl choride 

Clopidol 

Cobalt metal, dust and fume, as Co 

Cobalt carbonyl, as Co 

Cobalt hydrocarbonyl, as Co 

Copper 

Fume 

Dusts & mists, as Cu 

Cotton dust, raw 

Cresol, all isomers 

Crotonaldehyde 

Crufomate 

Cumene 

Cyanamide 

Cyanides, (inorganics) as CN 

Cyanogen 

Cyanogen chloride (C) 

Cyclohexane 

Cyclohexanol 

Cyclohexanone 

Cyclohexene 

Cyclohexylamine 

Cyclonite 

Cyclopentadiene 

Cyclopentane : 

Cyhexatin 

2,4-D 

DDT 

Decaborane 

Demeton 

Diacetone alcohol 

.015 

.0028 

.0032 

.0023 

3.45 

10.6 

35.4 

.01 

.005 

.10 

63.2 

.0067 

.36 

2.83 

2.59 

.002 

.005 

.005 

.005 

.0005 

.0016 

.1 

.0005 

.001 

.001 

.002 

.01 

.002 

.22 

.057 

.05 

2.46 

.02 

.05 

.21 

10.3 

2.06 

1.0 

10.10 

.41 

.015 

2.03 

17.2 

.05 

.10 

.01 

.0025 

.0011 

2.38 

.029 

0083 

0038 

032 

038 

0039 

4.25 

.0075 

.0075 

18 lOk 
P.9 

Divinyl benzene 

Emery 

Endosulfan 

Endrin 

Enflurane 

Epichlorohydrin 

EPN 

Ethanolamine 

Ethion 

2-Ethoxyethanol (EGEE) 

2-Ethoxyethyl acetate (EGEEA) 

Ethyl acetate 

Ethyl alcohol 

Ethylamine 

Ethyl amyl ketone 

Ethyl benzene 

Ethyl bromide 

Ethyl butyl ketone 

Ethyl chloride 

Ethylene chlorohydrin (c) 

Ethylenediamine 

Ethylene dichloride 

Ethylene glycol vapor (c) 

Ethylene glycol dinitrate 

Ethylenimine 

Ethyl ether 

Ethyl formate 

Ethylidene norbornene (c) 

Ethyl mercaptan 

N-Ethylmorpholine 

Ethyl silicate 

Fenamiphos 

Fensulfothion 

Fenthion 

Ferbam 

Ferrovanadium dust 

Fibrous glass dust 

Fluorides, as F 

Fluorine 

Fonofos 

Formamide 

Formic Acid 

Furfural 

Furfuryl alcohol 

Gasoline 

Germanium tetrahydride 

Glutaraldehyde (c) 

Glycerin mist 

Glycidol 

Graphite, natural (respirable dust) 

Graphite, synthetic 

Hafnium 

Halothane 

Heptachlor 

Heptane, n 

.53 

.1 

.001 

.001 

5.66 

.076 

.005 

.075 

.004 

.18 

.27 

14.4 

18.8 

.18 

1.31 

4.34 

8.91 

2.34 

26.4 

.25 

.4 

.0031 

.0088 

12.1 

3.03 

.013 

.24 

.85 

.001 

.001 

.002 

.1 

.01 

.1 

.025 

.016 

.001 

.18 

.094 

.079 

.4 

8.9 

.0063 

.1 

.76 

.025 

.1 

.005 

4.04 

.005 

16.4 

.15 

5.43 

11.1 

.033 

1.27 

15.2 

.25 

.03 

.031 

.6 

14.8 

.008 

20.5 

20 10^ 
P.10 

Mercury 

Alkyl compounds 

All forms except alkyl 

Vapor 

Aryl and inorganic compounds 

Mesityl oxide 

Methacrylic acid 

Methomyl 

Methoxyclor 

2-Methoxyethanol 

2-Methoxyethyl acetate (EGMEA) 

4-Methoxyphenol 

Methyl acetate 

Methyl acetylene 

Methyl acetylene-propadiene mixture (MAPP) 

Methyl aerylate 

Methylacrylonitrile 

Methylal 

Methyl alcohol 

Methylamine 

Methyl n-amyl ketone 

N-Methyl aniline 

Methyl bromide 

Methyl n-butyl ketone 

Methyl chloride 

Methyl chloroform 

Methyl 2-cyanoacrylate 

Methylcyclohexane 

Methylcyclohexanol 

o-Methylcyclohexanone 

Methylcyclopentadienyl 

manganese tricarbonyl, as Mn 

Methyl demeton 

Methylene bisphenyl isocyanate (MDI) 

Methylene bis (4-cyclohexylisocyanate) 

Methyl ethyl ketone (MEK) 

Methyl ethyl ketone peroxide (c) 

Methyl formate 

Methyl isoamyl ketone 

Methyl isobutyl carbinol 

Methyl isobutyl ketone 

Methyl isocyanate 

Methyl isopropyl ketone 

Methyl mercaptan 

Methyl methacrylate 

Methyl parathion 

Methyl propyl ketone 

Methyl silicate 

alpha-Methyl styrene 

Metribuzin 

Mevinphos 

Mica, respirable dust 

Mineral wool fiber 

.0001 

.0005 

.001 

.6 

.7 

.025 

.1 

.16 

.24 

.05 

6.06 

16.4 

16.4 

.35 

.027 

31.1 

2.62 

.13 

2.33 

.022 

.19 

.2 

1.03 

19.1 

.091 

16.1 

2.34 

2.29 

.002 

.005 

.00051 

.00054 

5.9 

2.46 

2.34 

1.04 

2.05 

.00047 

7.05 

.0098 

4.1 

.002 

7.05 

.06 

2.42 

.05 

.00092 

.03 

.1 

.0003 

1.0 

7.57 

20.5 

3.28 

2.07 

24.6 

.18 

3.44 

8.85 

.015 

3.68 

1.67 

3.07 

8.81 

4.83 

.0027 

22 10$ 
P.11 

Phosphoric acid 

Phosphorus (yellow) 

Phosphorus oxychloride 

Phosphorus pentachloride 

Phosphorus pentasulfide 

Phosphorus trichloride 

Phthalic anhydride 

m-Phthalodinitrile 

Picloram 

Picric acid 

Pindone 

Plperazine dihydrochloride 

Platinum 

Metal 

Soluble salts, as Pt 

Potassium hydroxide (c) 

Propargyl alcohol 

Propionic acid 

Propoxur 

n-Propyl acetate 

n-Propyl alcohol 

Propylene dichloride 

Propyl glycol: dinitrate 

Propylene glycol monomethyl ether 

Propylene oxide 

n-Propyl nitrate 

Pyrethrum 

Pyridine 

Quinone 

Resorcinol 

Rhodium 

Metal 

Insoluble compounds, as Rh 

Soluble compounds, as Rh 

Ronnel 

Rosin core solder pyrolysis 

products, as formaldehyde 

Rotenone (commercial) 

Rouge 

Rubber solvent (Naphtha) 

Selenium and compounds, as Se 

Selenium hexafluoride, as Se 

Sesone 

Silica-amorphous 

Diatomaceous earth (uncalcined) 

Precipitated silica 

Silica gel 

Silica-crystalline 

Cristobalite, respirable dust 

Quartz, respirable dust 

Silica (fused), respirable dust 

Tridymlte, respirable dust 

Tripoli, of contained respirable dust 

Silicon 

Silicon carbide 

.01 

.001 

.0063 

.0085 

.01 

.011 

.061 

.05 

.1 

.001 

.001 

.05 

.01 

.00002 

.023 

.3 

.005 

8.35 

4.92 

3.47 

.0034 

3.69 

.48 

1.07 

.05 

.16 

.0044 

.45 

.01 

.01 

.0001 

.1 

.001 

.05 

.1 

15.9 

.002 

.0016 

.1 

.1 

.1 

.1 

.0005 

.001 

.001 

.0005 

.001 

.1 

.1 

.03 

.03 

.02 

.02 

10.4 

6.14 

5.08 

5.53 

1.72 

.9 

24 \DC

\ 
P.12 

Tin 

Metal 

Oxide & inorganic compounds, 

except SnH4, as Sn 

Organic compounds, as Sn 

Titanium dioxide 

Toluene 

Toluene-2,4-diisocyanate (TDI) 

m-Toluidine ] 

Tributyl phosphate 

Trichloroacetic acid 

1,2,4-Trichlorobenzene (c) 

1,1,2-Trichloroethane 

Trichloroethylene 

Trichloroflouromethane (c) 

Trlchloronaphthalene 

1,2,3-Trichloropropane 

1,1,2-Trichloro-1,2,2 trifluoroethane 

Triethylamine 

Tri fluorobromomethane 

Trimellltic anhydride 

Trimethylamine 

Trimethyl benzene 

Trimethyl phosphite 

2,4,6-Trinitrotoluene (TNT) 

Triorthocresyl phosphate 

Triphenyl amine 

Triphenyl phosphate 

Tungsten, as W 

Insoluble compounds 

Soluble compounds 

Turpentine 

Uranium (natural) 

Soluble & Insoluble, as U 

n-Valeraldehyde 

Vanadium, as V.0S, respirable dust and fume 

Vegetable oil, mists 

Vinyl acetate 

Vinylidene chloride 

Vinyl toluene 

VM & P Naphtha 

Warfarin 

Welding fumes (not otherwise classified) 

Wood dust (certain hard woods as beech & oak) 

Soft Wood 

Xylene 

m-Xylene a,a'-diamine (c) 

Yttrium 

Zinc chloride fume 

Zinc oxide 

fume 

dust 

Zirconium compounds, as Zr 

.02 

.02 

.001 

.1 

3.77 

.00036 

.088 

.022 

.067 

.55 

2.69 

.05 

.6 

76.7 

.41 

60.9 

.00039 

.24 

1.23 

.1 

.005 

.001 

.05 

.03 

.05 

.01 

5.56 

.002 

1.76 

.0005 

.1 

.35 

.2 

2.42 

13.7 

.001 

.05 

.01 

.05 

4.34 

.01 

.01 

.05 

.1 

.05 

5.65 

.0014 

.37 

10.7 

56.2 

95.9 

.62 

.36 

.1 

.03 

.006 

.70 

.79 

4.83 

.1 

6.51 

.001 

.02 

.1 

.1 

1\0 

26 
P.13 

Appendix D. Unit risk factors for carcinogenic constituents. 

Constituent 

Acrylamide 

Acrylonitrile 

Aldrin 

Aniline 

Arsenic 

Benz(a)anthracene 

Benzene 

Benzidine 

Benzo(a)pyrene 

Beryllium 

Bis(2-chloroethyl)ether 

Bis(chloromethyl)ether 

Bis(2-ethylexyl)phthalate 

1,3-butadiene 

Cadmium 

Carbon Tetrachloride 

Chlordane 

Chloroform 

Chloromethane 

Chromium VI 

DDT 

Dibenz(a,h)anthracene 

1,2-dibromo-3-chloropropane 

1,2-dibromoethane 

1,1-dichloroethane 

1,2-dichloroethane 

1,1-dichloroethylene 

1,3-dichloropropene 

Dieldrin 

Diethylstilbestrol 

Dimethylnitrosamine 

2,4-dinitrotoluene 

1,2-diphenylhydrazine 

1,4-dioxane 

Epichlorohydrin 

Ethylene Oxide 

Ethylene Dibromide 

Formaldehyde 

Heptachlor 

Heptachlor Epoxide 

Hexachlorobenzene 

Hexachlorobutadiene 

Alpha-hexachloro-cyclohexane 

Beta-hexachloro-cyclohexane 

Gamma-hexachloro-cyclohexane 

Hexachlorocyclohexane, Technical 

Hexachlorodibenzo-p-dioxin (1,2 mixture) 

Hexachloroethane 

Hydrazine 

Hydrazine Sulfate 

Unit Risk Factor 

LmVi/cn 

1.3 E-03 

6.8 E-05 

4.9 E-03 

7.4 E-06 

4.3 E-03 

8.9 E-04 

8.3 E-06 

6.7 E-02 

3.3 E-03 

2.4 E-03 

3.3 E-04 

6.2 E-02 

2.4 E-07 

2.8 E-04 

1.8 E-03 

1.5 E-05 

3.7 E-04 

2.3 E-05 

3.6 E-06 

1.2 E-02 

9.7 E-05 

1.4 E-02 

6.3 E-03 

2.2 E-04 

2.6 E-05 

2.6 E-05 

5.0 E-05 

3.5 E-01 

4.6 E-03 

1.4 E-01 

1.4 E-02 

8.8 E-05 

2.2 E-04 

1.4 E-06 

1.2 E-06 

1.0 E-04 

2.2 E-04 

1.3 E-05 

1.3 E-03 

2.6 E-03 

4.9 E-04 

2.0 E-05 

1.8 E-03 

5.3 E-04 

3.8 E-04 

5.1 B-04 

1.3 E+00 

4.0 E-06 

2.9 E-03 

2.9 B-03 

27 W\ 
TABLE 1. 

Maximum 1-hour Ground-Level Centerline Concentrations (ag/m^) 

Downwind Distance (meters) 

p 

Release 

Ht. (•) 

1 

5 

10 

20 

30 

50 

100 

200 

-

10 

300 

.82 

•'neg. 

neg. 

neg. 

neg. 

neg. 

neg. 

20 

210 

8.6 

•15 

neg. 

neg. 

neg. 

neg. 

neg. 

30 

120 

10 

1.3 

neg. 

neg. 

neg. 

neg. 

neg. 

HO 

77 

9.2 

2.2 

.028 

neg. 

neg. 

neg. 

neg. 

-

50 

51 

8.4 

2.1 

.14 

.001 3 

neg. 

neg. 

neg. 

75 

21 

11 

2.5 

.49 

.054 

neg. 

neg. 

neg. 

100 

16 

9.4 

2.0 

.61 

.17 

.0028 

neg. 

neg. 

150 

8.0 

6.1 

2.6 

.64 

.29 

.050 

neg. 

neg. 

200 

4.9 

4.0 

2.4 

.53 

.29 

.10 

.0013 

neg. 

300 

2.5 

2.1 

1.7 

.59 

.25 

.11 

.020 

neg. 

400 

1.5 

1.3 

1.1 

.60 

.21 

.11 

.036 

.0019 

500 

1.0 

.93 

.83 

.53 

.25 

.093 

.034 

.0087 

750 

.53 

.48 

.44 

.35 

.24 

.069 

.031 

.011 

1000 

.34 

.32 

.28 

.24 

.19 

.087 

.025 

.0071 

2000 

.12 

.11 

.10 

.092 

.083 

.060 

.014 

.0066 

5000 

.032 

.032 

.031 

.027 

.023 

.021 

.0081 

.0019 

y 

'Emission rate of 1.0 grams/sec was used. Terrain, Halted vertical mixing, and structurallyInduced downwash effects not accounted for. 

2Plume rise Is not taken Into account (release ht. • plume ht.) 

^Negligible Is defined as less than 0.001 allllgrams/m3