p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

74) ll-E-34 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 74 of 264 
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A-94-52 

CONTACT REPORT 

From: Wanita Dunston, US Environmental Protection Agency Intern 

Contact: Charlie Stanier 

Company/Agency: International Paper | ; / ftu ht'5 fQQJ 

Date of Contact: 

'•(*,v*'"''-ft*.* '*?i^»*,._* 

November 21,1995 p _ EP^AIRDOCKFT 

tel: (410) 519-2094 fax: (410)519-2112 

Contact Summary 

(Notes prepared by Wanita Dunston) 

(Retyped by C. Stanier, strikeout indicates deletion, italic indicates insertion) 

• I NOTICED FROM MEDELEINE'S STRUMS' NON-CBI CONTACT REPORT THAT 

A MASS BALANCE WOULD BE PERFORMED TO DETERMINE THE QUANTITY 

OF HAPs ABSORBED BY CARBON FILTERS. HAS THIS BEEN PERFORMED 

YET? An internal stack test report was used for TRI, SARA 313 reporting. Mr. Stanier 

has the values for the weight gain ofthe carbon bed. See attachment A. 

• WHAT ARE THE HAP EMISSIONS (IN TPY) FOR EACH PROCESS? I NOTICED 

THAT [THERE] APPEAR TO BE ONLY THREE PROCESS. International Paper has 

VOCs calculated, but it is not speciated for each process. M. Strum (conversation of 

12/15/95) agreed that this information was not necessary. 

• HOW MANY LINES ARE BEING OPERATED, AND HOW MANY ARE BEING 

CONTROLLED? There are three processes, as indicated in the survey, and no lines are 

duplicated. Process 1 refers to the mixing plant and continuous casting line. Material for 

the continuous lamination casting line is produced here in ihe mixing plant, ft The mixing 

plant is non-controlled. The continuous casting line is controlled by condensation and 

carbon filtration of oven exhaust. For process 2, the process is like cultured marble 

casting (as Madeleine referred to it in the contact report), but chemically, it is different. 

(Mr. Stanier will check on how their shaped goods manufacturing is different, and get 

back to us with that information). The products are shaped goods, such as 

kitchen/bathroom sinks. Process 3 is the particle manufacturing line, and it is controlled. 

The products, particles, are a filled polystyrene polyester. SEE ATTACHED 

INFORMATION B. 

• IT IS STATED FOR CONTINUOUS LAMINATION CASTING THAT THE 

EMISSIONS BETWEEN THE DISPENSING MECHANISM AND THE OVEN FOR 

THE LINE ARE "PARTIALLY CONTROLLED". WHAT IS MEANT BY THIS? 

Continuous lamination casting is partially controlled. The process involves putting^i/Zeflf 

liquid polymer on the belt. There is a gap to allow filled liquid polymer into the system. 
P.3 

This gap allows fugitive emissions to escape, and therefore, the capture efficiency is not 

100% at the dispensing mechanism. 

• WOULD YOU LIKE TO MAKE ANY ADDITIONAL COMMENTS REGARDING 

YOUR FACILITY? Currently, a fiberglass RACT is being put together. Maryland 

looked at our processes, and it looks as though RACT is not applicable. 

Also, since the time of Madeleine's contact report, a speciated stack test has been 

done n the particle manufacturing process and shaped goods. Mr. Stanier will summarize 

this and send it to EPA in non-cbi form. He will also draw a simple layout ofthe process, 

in a generalized form, to let us know where the emissions are coming from. 

ADDITIONAL QUESTIONS - See attached section C. 

1. WHAT IS THE VOLUMETRIC FLOW RATE TO THESE FILTERS? 

2. WHAT ARE THE HAP EMISSIONS (in tpy) FOR EACH EMISSION POINT? 

3. WHO IS THE MANUFACTURER (OR DESIGNER) OF THE FILTERS USED? 

*Please forward all additional correspondence to Madeleine Strum [tel: 919.541.2383. fax: 

919.541.0072]*-Thanks. 

Information is accurate as marked. 

A^z_ 

Charlie Stanier 

2_ 
P.4 

A. A mass balance to evaluate HAP adsorption in the [CFHP] carbon beds has not been 

performed. 

Currently available information shows condensation of 4.0X10"4 lb condensate per lb matrix 

applied to the casting machine, and a weight gain in the carbon beds of 6.8x10"4 lb per lb 

matrix applied to the castmg machine. 

B. Description of installations: 

"Process 1" - Fountainhead Sheet Manufacture 

A. Mixing of resin with filler: not controlled 

B.| Continuous casting (CFHP - Continuous Fountainhead Process): controlled 

with condenser and carbon bed - capture efficiency not determined 

This operation produces 3' wide cured sheets in 1/4", 1/2" and 3/4" thicknesses. 

Material is continuously cast and then cut into 8,10, and 12 foot sections. 

"Process 2" - Casting of polyester shaped goods: not controlled 

The product from this area is kitchen and bathroom sinks. These are produced by 

pouring catalyzed, filled polyester resin into closed molds. The difference between 

this operation and cultured marble is as follows: In cultured marble, the male 

portion ofthe mold is sprayed with a gel coat with a high styrene content. This is 

then backfilled with a filled polyester, giving a layered product. Our shaped goods 

products are homogenous, made by casting filled polyester in a closed mold. 

"Process 3" - Production of polyester particles 

This operation produces polyester particles (sorted by size) for addition to "Process 

T'iand "Process 2". The particles are produced in 2 steps: 

A.i Casting a thin (<l/4") ribbon of Fountainhead material (20" wide) on a 

continuous casting machine (moving belt and curing oven) - the oven and 

mix tanks are controlled by a carbon bed. 

B. Size reduction (grinding/crushing) followed by sorting by size - no VOCs. 

C. Styrene PPM (volume) of exhaust gases (to atmosphere) from each process. 

High cone, streams Low cone, streams 

Continuous Sheet Casting Process 

mixing only 4000 - 8000 

casting only * 

Particle Casting ; * 

Shaped Goods Plant 4000 - 8000 

*High concentration streams in this area are controlled. 

Additional questions: 

1. Volumetric flow to the CFHP carbon bed is approximately 75 scfm. 

3. 

2-

0-

14 

45 

0.4-2 

1- 17 
P.5 

Volumetric flow to the particle plant carbon bed is 216 scfin. 

2. Agreed that this infonnation was not needed (Strum / Stanier 12/15/95). 

3. The VOC control system was designed cooperatively between in house personnel and 

HYDROSYSTEMS, INC. 

Attachments 

Summarized results from 1995 styrene stack tests performed in particle casting plant and 

shaped goods plant 

i 

See attached summary. The test results were combined with the production data during the test to 

create lb VOC / lb product emission factors used to compute emissions for reporting and Title V 

planning. The development ofthe in-house factors involves detailed production information and is 

considered confidential business information. 

PLEASE MOTE -

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,,,. ' 

ENVIRONMENTAL INC. 

May 11, 1995 

Mr. Charlie Stanier 

Environmental Engineer 

International Paper Corporation 

NEVAMAR Division 

8339 Telegraph Road 

Odenton, Maryland 21113 

Subject: Fugitive Emission Estimates Associated with Shaped Goods 

Plant (SGP) and Particle Plant (PP) 

EMS Project No.: 6214 ' 

Dear Charlie: 

Enclosed is a summary report that presents estimates of MMA and 

Styrene Fugitive Emissions that were generated by the SGP and PP 

operations during the day shifts of April 19 and April 20, 1995. 

A Sentex Scentograph Plus II field portable gas chromatograph was 

used to sample ppm concentrations of MMA and Styrene. Also 

included in the report is an estimate of VOC emissions for Stack 5 

in the Shaped Goods Plant as well as an estimate of mass loading 

for the Particle Plant carbon unit. Due to high source 

concentrations and/or the presence of interferents, these sources 

could not be sampled with the gas chromatograph and were measured 

using a JUM VE-7 Flame Ionization Analyzer. Joe Slaughter of EMS, 

yourself, and the undersigned participated in the field 

sampling/analysis activities. 

In the continuous operation Particle Plant, the results of the 

field sampling activities indicate that the mass emissions of MMA 

are estimated to be 2,47 lbs/day, and Styrene to be 3.18 lbs/day. 

The VOC loading to the PP carbon unit is estimated to be 65.55 

lbs/day as carbon. In the batch operation Shaped Goods Plant, mass 

emissions of MMA are estimated to be 0.26 lbs/hr, and styrene to be 

0.49 lbs/hr. SGP Stack 5 VOC emissions are estimated to be 0.14 

lbs/hr as carbon. Further analysis, i.e. a weighted average of the 

Stack 5 emissions obtained by multiplying flow times concentration 

for each of the 99 data points, yields an "actual" VOC emission of 

0.23 lbs (as carbon) for the period of sampling. This works out to 

be 0.14 lbs/hr, coincidentaUy, the same as the figure reported 

above where estimated emissions were based on an average 

concentration and an average velocity for the entire run. 

4580-G Mack Ave., Frederick, Maryland 21701 (301) 695-5828 Fax (301) 695-3348 
P.7 

ENVIRONMENTAL M l 

Mr. Charlie Stanier 

Page 2 

May 11, 1995 

The summary

 ; table at the beginning of Section l presents the 

concentrations and mass emission rates of MMA and Styrene, 

respectively, as well as concentrations and mass emission 

rates/loading of VOCs. As a back-up to this mass emission data, 

additional tables in Section 1 present air flows and measured 

concentrations for each source. Please note that an additional page 

for SGP Stack 5 reflects calculation of the previously reported 

"actual" VOC emissions. Strip chart integrations for VOCs and 

specific gas chromatographic data for MMA and Styrene emitted from 

each source are included in Section 2. Field notes are included in 

Section 3. 

Please feel free to contact me if you have any questions about the 

findings presented in this report. EMS appreciates the opportunity 

to be of continuing service to Nevamar and thanks you for your 

support during sampling events. 

Very truly yours, 

EMS Environmental, Inc. 

Vincent V. Dobbs 

Group Leader 

Air Quality Management 

cc: Joe Slaughter 

^ 
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Area 

SGP: 

PP: 

Area 

PP: 

Source 

Stack 5 

Vent 23 

Stack 3 

Vent 13 

Stack 2 

Subtotals 

Stack 2 

Vent 2 

Vent 1 

Stack 3 

Stack 1 

Subtotals 

Totals 

Source 

Carbon unit 

Cone, avg 

ppm 

13.19 

3.76 

0.25 

19.46 

0.78 

1.42 

1.37 

0.04 

0.53 

Fugitive Emission 

Summarv 

MMA 

Mass 

lbs/hr 

0.05 

0.11 

1.96E-03 

0.10 

0.26 

0.01 

0.03 

0.05 

1.01 E-04 

1.57 E-03 

0.09 

0.35 

Emissions 

lbs/day 

0.33 

0.80 

1.30 

2.42E-03 

0.04 

2.47 

Mass Loading 

Summary 

MMA 

Cone.avg 

ppm 

16.72 

9.86 

7.19 

8.92 

1.56 

1.81 

1.31 

0.49 

1.31 

STYRENE 

Mass 

Ibs/hr 

0.07 

0.31 

0.06 

0.05 

0.49 

0.03 

0.04 

0.05 

1.28E-03 

4.07E-03 

0.13 

0.62 

STYRENE 

Emissions 

lbs/day 

0.69 

1.06 

1.30 

0.03 

0.10 

3.18 

Cone.avg 

ppm 

17,049 

Cone, avg 

ppm 

3.013 

VOCs (as carbon) 

Mass Emissions 

Ibs/hr 

0.14 

0.14 

0.14 

lbs/day 

1 

VOCs (as carbon) 

Mass 

lbs/hr 

2.73 

Loading 

lbs/day 

65.66 

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