p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

9) IV-B-9 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 9 of 273 
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MEMORANDUM 

NONCONFIDENTIAL VERSION BASED ON PLANT COMMENTS 

TO: Keith Barnett 

U.S. EPA/ESD/MISG 

FROM: Kenneth R. Meardon 

Pacific Environmental Services, Inc. (PES) 

DATE: March 18, 2002, Revised September 17, 2002 

SUBJECT: Trip Report for January 17, 2002, Visit to Profor[n 

LOCATION: Proform, West Memphis, AR 

ATTENDEES: 

cr--> o 7 */r i i UJ L • (• '••J 

EPA AIR DOCKET 

Mr. Craig Peterson 

Mr. Roderick Annis 

Mr. John Schweitzer 

Mr. Rob Haberiein 

Mr. Lyndon Poole 

Mr. Bill Swafford 

Mr. Nick Nixon 

Mr. Keith Barnett 

Dr. Kenneth Meardon 

Mr. Frank Meadows 

Ms. Susan Cassidy 

Proform (952) 887-1807 

Proform (870) 735-5353 

Composites Fabricators Association (734) 662-0162 

Engineering Environmental 

Consulting Services (410) 268-7367 

Arkansas DEQ (501) 682-0747 

Arkansas DEQ (501) 682-0746 

Arkansas DEQ (870) 935-7221 

EPA/MICG (919) 541-5605 

PES (919) 941-0333 

PES (919) 541-0333 

PES (919) 541-0333 

PURPOSE 

The purpose of this trip was to observe and discuss plant operations to evaluate the 

feasibility of permanent total enclosures or the use of building enclosures to capture emissions 

in response to public comments made on the proposed NESHAP for reinforced plastics 

composites. 

INTRODUCTION 

The facility, which is located on 27 acres, started building parts in 1997. The facility 

produces barge covers for a company in Indiana and underground storage tanks (UST) for 

national distribution. The barge cover production area is approximately 47,700 square feet and 

the UST production area is approximately 15,800 square feet. A Phase III expansion is being 

considered, which would add another 52,000 cfm of air flow to the facility. 
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Keith Barnett 

March 18, 2002 

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The barge covers are used on grain barges. Steel barge covers may flake and drop steel 

flakes into the grain; the RFP covers do not do this. The UST are used primarily for storage of 

gasoline, water, and chemicals. The UST are warranted for 30 years and must be good in any 

ground conditions in which they are installed. The UST undergo stringent structural testing, 

including vacuum and pressurized tests. 

Directed air flow systems (push-pull) are used within the facility. The air flow system 

was designed by Frees, who has returned on several occasions to increase the air flows in order 

to reduce employee exposure. The facility has conducted employee exposure testing and found 

exposures to be below 50 ppm. However, workers still have to be rotated to avoid exceeding 

this limit. It was noted and observed that, at laminate station 2, some workers are on the 

downwind side of the mold. There are heaters and chillers located in the general ventilation 

system to the production area. 

The facility has conducted tests to determine styrene concentrations in the stacks. Mr. 

Haberiein indicated that they had tried to qualify the building as a Method 204 compliant 

enclosure, but that the building had failed. It was noted that the first source test inspector (Mr. 

Ken Fells of ADEQ) requested a demonstration of Method 204. He was shown that the 

building did not meet Method 204 using smoke and, rather than call off the source test, ADEQ 

waived the criteria and noted that the test was conducted with "capture as best as possible." 

Barge Cover Production. 

The description of the barge cover production process has been claimed to be 

confidential business information. 

UST Production 

The construction of UST occurs at work stations and not in a continuous line fashion and 

begins with building two halves in rotating molds. Workers stand on platforms inside the molds 

and use FIT technology to apply the resin (no gel coat is used) to the rotating mold, which 

rotates at 24 revolutions per minute. The mold is ventilated with air flows ranging from 50 to 

100 feet per minute at the entrance to the mold. Currently, two molds are 8-foot diameter and 

the other two are 10-foot diameter. Construction ofthe UST follows a proprietary schedule, 

which is very complex, in order to develop a safe product. It was noted that there is a very 

high potential liability with an in-ground failure of an UST. 

The rotation of the mold keeps the resin against the inside of the mold as it cures. The 

concentration in the mold decreases significantly when the spraying stops and as the cure 

progresses. Thus, the average concentration in the air flow from the UST mold may be high 

while spraying, but it drops after rolling and during curing. There will be a long period of time 

when the concentration will be low. The air ventilation system is turned off when the UST is 
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Keith Barnett 

March 18, 2002 

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pulled from the mold. 

The halves are removed from the molds and then joined using manual application 

techniques. In addition, manways, collars, and fittings are attached to the UST as needed using 

manual application techniques. A resin putty, comprised of resin used in the construction of the 

UST and filler, is applied to even out right angles and apply fitings. 

Miscellaneous 

1. Utility costs for electricity have been constant since the facility began operation. 

2. The increase in gas usage in 2001 versus previous years is likely explained by 

increase in operating hours (number of shifts) and a very cold winter. 

3. Doors could be considered natural draft openings, although it was questioned as to 

why anyone would want to do so in trying to qualify a building enclosure as a Method 204 

enclosure. 

Action Items 

EPA requested that Proform provide information on resin and gel coat usage and HAP 

contents.