p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

tisyx.?, H-E-151 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:10 AM Sheet 192 of 264 
4 EpIJ, 

f*~5~~~ 

MEMORANDUM 

P.2 

A 9^ 52. 

N-E.15 / 

TO: 

FROM: 

DATE: 

SUBJECT: 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

May 6, 1998 

Minutes of April 17, 1998 Conference Call Between EPA and Representatives 

of the Pultrusion Industry Council 

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

11:00 am-1:00 pm 

PARTICIPANTS: 

Mr. Bill Busco 

Mr. Dan Boyd 

Mr. Nick Cray 

Mr. Denis DeSilvey 

Mr. Dave Evans 

Mr. James Gauchel 

Mr. Tom Griffiths 

Mr. Robert Jemison 

Mr. Terry McQuarrie 

Ms. Jan Meyer 

Ms. Melanie Proctor 

Ms. Madeleine Strum 

R. D. Werner Company 

Composites Institute ofthe Society 

ofthe Plastics Industry (SPI) 

R. D. Werner Company 

R. D. Werner Company 

Creative Pultrusions 

Owens Corning 

Omega Pultrusions 

PES 

Glasforms, Inc. 

EPA/ESD/CCPG 

PES 

EPA/ESD/CCPG 

(847) 455-9450 

(410) 827-6244 

(847) 455-9450 

(724) 588-2000 

(505) 347-2226 

(614) 321-7724 

(330) 562-5201 

(919) 941-0333 

(408) 297-9300 

(919) 541-5254 

(919) 941-0333 

(919) 541-2383 

PURPOSE 

The Pultrusion Industry Council (PIC) requested a meeting/conference call with the 

EPA to discuss the proposed industry approach for the existing source maximum achievable 

control technology (MACT) standard for pultrusion. The different compliance options 

proposed by industry are described in Attachment I. The wet area enclosure compliance 

option presented in Attachment 1 was revised based on discussions between the EPA and 

Glasforms. The revised wet area enclosure compliance option is shown in Attachment II. 
P.3 

Madeleine Strum 

May 6, 1998 

Page 2 

DISCUSSION 

Mr. Evans started the meeting by stating that Ms. Strum requested a review of how die 

emission factor was determined for Phase U of the PIC study conducted at Reichhold 

Chemicals, Inc. Mr. Evans pointed out that the emission factor in terms of percent available 

hazardous air pollutants (HAP) can be determined in two different ways: (1) by calculating the 

emission factor based solely on the resin processed or (2) by using all the resin that entered the 

process (i.e., resin bath) regardless of whether it was processed through the entire pultrusion 

line or not. 

Ms. Strum indicated that the resin that does not go through the entire pultrusion 

machine may have to be subtracted from the total resin because the emission factor associated 

with the resin that is left over in the bath is different from the emission factor of the resin that 

is processed through the entire machine. Mr. McQuarrie pointed out that industry generally 

calculates emissions by counting all the resin that enters the process regardless of whether it is 

processed or left over because it is very difficult to subtract the resin left over in the resin bath 

from the total amount of resin that went into the process. 

Mr. Griffiths wanted to verify if the emission factor from the Glasforms emission test 

was determined by the "total available HAP method" meaning that the emission factor was 

based on all of the resin including the resin waste resin as opposed to the amount of HAP 

processed through the entire machine. Mr. McQuarrie confirmed that the "total available 

HAP method" was used in the Glasforms emission test. Ms. Proctor added that the data from 

the test report seem to indicate that all the available HAP in the Glasforms emission test was 

also processed through the entire machine (i.e., there was no waste resin). 

Mr. Evans shifted the focus of the discussion to the latest industry MACT proposal for 

pultrusion. He indicated that the first compliance option listed in the proposal is use of a 

continuous emission monitor (CEM) and a total enclosure to show compliance with the MACT 

emission limit. 

Ms. Strum explained that the MACT floor for pultrusion is based on an equipment 

standard which consists of wet area enclosures. Ms. Strum further explained that the EPA 

would allow facilities to show equivalency with the equipment standard. She pointed out that 

the EPA has emission test data for the wet area enclosures at Glasforms that set the MACT 

floor. According to Ms. Strum, the emission test data for the wet area enclosures show HAP 

emissions of 22 pounds per ton of resin used. She also pointed out that the test data are 

associated with a particular line speed and a particular product. Ms. Strum explained that the 

line speed during the emission test of the wet area enclosures did not exceed 18 inches per 

minute. She stated that an emission test intended to show equivalency with the wet area 

enclosures would also have to be conducted at a line speed not exceeding 18 inches per minute 

- > 

U 
P.4 

Madeleine Strum 

May 6,1998 

Page 3 

because faster line speeds are expected to result in lower emissions in terms of pounds of HAP 

emitted per ton of resin used. Ms. Strum added that if the emission test of the wet area 

enclosures at Glasforms would have been conducted at faster line speeds the equivalent 

emission limit to the wet area enclosures would likely have resulted in a lower equivalent 

emission limit than 22 pounds of HAP emissions per ton of resin used. 

Mr. Griffiths indicated that imposing a given line speed on a facility for emissions 

monitoring would result in a very unrealistic scenario. He also stated that the PIC Phase I 

study only showed a weak correlation between line speed and the emission rate. Ms. Strum 

replied that it is not the EPA's intent to impose a line speed on facilities. However, she 

pointed out that the first step of the equivalency determination consists of running the 

pultrusion machines at a line speed of 18 inches per minute or less to establish that the 

emission reduction technology used by the plant is in fact equivalent to the wet area 

enclosures. She explained that after the equivalency with the wet area enclosures has been 

established, the second step is to measure the emissions while running the pultrusion machines 

at the typical production line speed. Ms. Strum indicated that if the emissions in step two of 

the equivalency determination have been shown to be 10 pounds of HAP emissions per ton of 

resin used, then the facility would have to show that this level of emissions is not exceeded by 

using a CEM. 

Mr. Griffiths asked if each line needs its own total enclosure with its own CEM or if 

several lines can be in one enclosure and share a CEM. Ms. Strum replied that either one of 

the two options would be acceptable. Mr. Griffiths inquired how compliance would be shown 

when a facility operates several pultrusion lines with continually changing products in one total 

enclosure. Ms. Proctor suggested that during the imtial equivalency determination step, all 

lines would be operated at a line speed not exceeding 18 inches per minute to show that the 

equivalent HAP emission limit of 22 pounds per ton of resin used is met. She continued by 

stating that after equivalency with the wet area enclosures has been demonstrated, the facility 

would then run each of the pultrusion machines at the typical production line speed to 

determine the facility specific emission limit based on the typical line speeds of the pultrusion 

machines. This facility specific emission limit would have to be met at all times as shown by 

using a CEM. 

Mr. Evans inquired if the emission limit could be exceeded as long as the exceedences 

were balanced by lower emissions during another part of the averaging time period. Ms. 

Meyer responded in the affirmative and stated that a monthly or annual emissions averaging 

time could be used. : V 

Mr. Griffiths voiced the concern that the equivalent emission limit was derived based 

on only one emission test conducted at Glasforms. Concern was also expressed that no 

statistical analyses could be conducted and that no confidence intervals could be established 

3 
P.5 

Madeleine Strum 

May 6, 1998 

Page 4 

since only one emission test run was used to determine the equivalent MACT emission limit. 

Mr. Griffiths also stated that he would like to see the emission test report to better understand 

how the equivalent HAP emission limit of 22 pounds per ton of resin used was established. 

Ms. Strum asked Mr. McQuarrie if the EPA could share the Glasforms test report with 

the PIC members. Mr. McQuarrie indicated that the confidential business information (CBI) 

contained in the test report would have to be removed prior to sharing the information. It was 

agreed that the EPA would send the emission test report that Glasforms provided to the EPA 

during the October 27, 1997 meeting back to Glasforms and that Mr. McQuarrie would mark 

all information that he considers to be CBI. It was further agreed that the EPA would create a 

non-CBI version of the emission test report, which would be distributed to PIC members. Ms. 

Meyer reminded everyone that the description of the test procedures and the results of the 

emission test cannot be considered confidential. 

Ms. Strum stated that the equivalent MACT emission limit was based on only one test 

but she also pointed out that no other facility specific data were available. Ms. Meyer added 

that if other facilities would like to submit emission data on the effectiveness of wet area 

enclosures the EPA would be happy to review these data. 

Ms. Strum also pointed out that the CEM option would require facilities to do daily 

calibration and accuracy checks. Mr. Evans explained that according to a CEM vendor that he 

contacted the CEMs are self-calibrating and equipped with a microprocessor unit. Ms. Meyer 

indicated that there are specific performance specifications for CEM units contained in Title 40 

of the Code of Federal Regulations part 60 (40 CFR 60) that the EPA would have to refer to 

in this MACT rule. Ms. Meyer added that this rule would need to refer specifically to 

specifications 8 and 9 in Appendix B and Appendbc F of 40 CFR 60. She explained that 

Appendix F specifies quality control and quality assurance procedures for CEMs. Mr. 

Jemison added that Appendix F also requires quarterly cylinder gas audits and an annual 

relative accuracy test audit. He indicated that the annual relative accuracy test audit on the 

CEM system is one of larger costs associated with the CEM. Mr. Jemison explained that this 

test requires a test company to measure emissions using a certain number of reference method 

test runs which are then compared to the CEM emission measurements for the same time 

period. He added that a certain percent relative accuracy has to be met in this test. Ms. 

Meyer indicated that she raised these issues to make sure that it is understood that there are 

some added costs associated with using CEMs to show compliance. 

\ -' 
P.6 

Madeleine Strum 

May 6, 1998 

Page 5 

Ms. Strum shifted the focus of the discussion to the second compliance option proposed 

by the PIC which consists of the use of control factors and recordkeeping requirements to 

show that the MACT equivalent emission limit is met. Ms. Strum indicated that she had a 

couple of comments about this proposed compliance option. First, she pointed out that the 

baseline (open bath and wet areas) emission factor of 5 percent in the control factor equation 

should be replaced with the baseline emission factor of approximately 12 percent determined 

from the Glasforms emission test. Ms. Strum explained that since the equivalent MACT 

emission limit of 22 pounds of HAP per ton of resin used was based on the Glasforms test, the 

baseline emission factor had to come from the same study. Second, Ms. Strum stated that a 

facility would not be allowed to use the air flow management control factor in addition to the 

wet area enclosure control factor because the emission reduction from both of these measures 

are not expected to have an aggregating effect. 

Mr. McQuarrie inquired if the control factor of 0.41 for the wet area enclosures would 

have to be changed to a control factor of 0.20 based on the emission test at Glasforms. Ms. 

Strum agreed that the factor should be changed to 0.20 reflecting an 80 percent emission 

reduction that the wet area enclosures achieved at Glasforms compared to the baseline case. 

Mr. McQuarrie asked which control factor the EPA would use for air flow 

management and how the air flow would be measured. Ms. Strum indicated that the EPA does 

not have a control factor for air flow management from the Glasforms test. She also indicated 

that the EPA would like industry to propose an approach that would outline monitoring 

requirements and the method used to show continuous compliance with air flow management 

requirements. Ms. Strum explained that this proposal should include the instrumentation used 

and the records that would have to be kept to show that the air flow management requirements 

are met on a continuous basis. She added that the EPA would send the industry proposal to 

their enforcement division and let them judge if the steps outlined in the industry proposal can 

be used to demonstrate continuous compliance with air flow management requirements. 

Mr. McQuarrie inquired if data to derive a control factor for air flow management 

could be obtained from emission testing at Creative Pultrusions. Mr. Evans stated that 

Creative Pultrusions is using air dams to control the air flow over the wet area to 15 feet per 

minute, but also pointed out that their emission data could not be used to derive a control 

factor for air flow management alone because several different reduction technologies were 

used in addition to air flow management. Ms. Strum indicated that in the absence of any other 

data the control factor of 0.51 from the PIC study may have to be used but the EPA would still 

need more information from industry as to how continuous compliance with air flow 

management requirements would be shown. 

S 
P.7 

Madeleine Strum 

May 6, 1998 

Page 6 

Ms. Strum pointed out that a facility that wants to comply by using air flow 

management on some of their pultrusion lines would also have to process a fair amount of 

resin by direct die injection because, as seen by the control factors, air flow management alone 

does not allow a facility to comply with the standard. 

The next compliance option discussed was the third compliance option proposed by the 

PIC which consists of the use of direct die injection. Ms. Strum asked if the PIC could make 

a video tape available to EPA that shows the direct die injection process. Mr. Evans pointed 

out that Mr. Gauchel promised to provide a video tape that would show the direct die injection 

process. Mr. Evans asked Ms. Strum to contact him if she would not receive the tape within a 

week. 

The last compliance option discussed consists of the construction of wet area 

enclosures. Ms. Strum explained that the basic concept was taken from the previous wet area 

enclosure definition provided by industry but that details had to be added to make the 

definition complete. She pointed out that one major change from the previous definition was 

that the total allowable open area expressed in terms of the total surface area changed from 5 

to 4 percent. Ms. Proctor added that another change was made to limit the height of the 

enclosure to 1.55 times the depth of the resin bath. She explained that this was done to 

prevent someone from building an unnecessarily large enclosure to increase the total surface 

area of the enclosure which would allow a larger open area. Mr. McQuarrie added that the 

height limitation was based of measuring the depth of all baths and the heights of all 

enclosures at Glasforms. 

Ms. Strum indicated that reinforcement that displaces a portion of the open area as it 

enters a slot in the enclosure should not be subtracted from the open area in the enclosure 

because the total allowable open area expressed in terms of the total surface area was 

determined without subtracting entering reinforcement. Ms. Strum explained that pipes that 

go into the enclosure can, however, be subtracted from the total open area. Ms. Meyer 

clarified that only the annulus between the pipe and the surface of the enclosure would be 

considered an open area in that case. Mr. McQuarrie added that based on the revised wet area 

enclosure definition openings that are covered by brush covers are not counted as open areas. 

Ms. Strum pointed out that some time was spent in describing how resin drip has to be 

collected. She added that the resin drip collection described in the definition is not the most 

efficient (in terms of reducing emissions) but she stated that it was based on the MACT floor 

facility. Ms. Strum also stated that the EPA still needs to work on the definitions of the terms 

used in the wet area enclosure definition. 

v 

C 
P.8 

Madeleine Strum 

May 6, 1998 

Page 7 

After discussing the four proposed MACT options for pultrusion, Mr. Evans 

summarized the status and the action items for each of the options. It was agreed that the EPA 

would finalize the CEM/total enclosure compliance option. Mr. Evans promised to take the 

lead in revising the control factor compliance option and to outline a proposal of how 

continuous compliance can be demonstrated wim air flow management requirements. Mr. 

Evans stated that Mr. Gauchel is supposed to provide a video tape to the EPA that shows the 

direct die injection process. It was agreed that the wet area enclosure compliance option is 

considered finalized with the exception of the work on the definition of terms. 

Action Items for Industry Representatives: 

1. Revise control factor compliance option and outline proposal of how continuous 

compliance can be demonstrated with air flow management requirements (Dave Evans). 

2. Provide EPA with a video tape of direct die injection (James Gauchel). 

Action Items for EPA; 

1. Finalize the CEM/total enclosure compliance option. 

1 
P.9 

•: 

04/07/98 12:09 ©919 541 5689 EPA ESD CCPG 

Apv-06-9 8 09:Z4A C*r©ativ© Pui-true i one 1 50S 3A7 57A1 

Fax Sheet 

Monday, April 06,1998 

@ooi 

p. oi 0 

•••m 

*TO: 

•&FROM: 

ri 

; Madeleine Strum 

*:i-»-

..'• ii 

";i I Dave Evans 

{.•I.ti : 

,:3 ii ••feSOBJBBCTa ?PICT MACT Propos.isae i 

|Npi^Ek;Q F PAGESOnciuding cover): 6 

,'CCrJ'' 

•I.; : 

r 

:{!•.• i f; i 

i f ;• 

•Madeleine;;'! i 

f. linclosisd 15 the MACT proposal the Technical Commiitee lias been working oiuo dale. ( •.); 

i;', I informed icyeryone of ihe teleconference on April 17th instead of Ihc visiLThis may work oui better 

V' anyway jasinbre people seemed interested in being involved. 

|*'. We wcire not running any injection dies in PA . However Jim Gauchel has videos of ones he ran and will he--

p.forwardjngithose to you so you can compare ihem to the Reichold iesi. •.' • 

$";•..• I .will do the: promised calculations this week and get them to you. 

• •' tin that subject the group was curious if you had calculated the pound.s per ion of resin on Ihe dcmonsiruiioii 

£ project at Reichold. If so do they tie into the numbers wc are looking ai for the MACT Standard? We emiUI

 :;' 

:, hav* those calculated if you: haven't. 

.".:** 

- -rti 

• ill! 

•i •».sij 

; # 

Hi! 

i '*? j 

t ';*J 

i l 

l ' .Dave-Evans'. 

;

;

 Operations; Director Western Division 

t •:• > 

*••; ' 

!';V. 

V 

. & .• 

i.f.-. 

t

:

i * 

•lit 

1 . 

I I i * 

• -1 j ' i"-'*tA*ff 

< '* y 

' ^-,*! 

'•'1 •. 

' !j :" 

>n. $ 

i*ii: 

'••\IJ*I 

OPT1CNA1 F IBM M (7-80) 

f FA* TRANSMITTAL 

Ffom 

JflpAnjJt-. 

OspUAgoncy 

Prottc OJL. 

l"«)*, 

1 

75*0-01-317-7368 l 

^7/f^-

« Ol piisjuc *• A , 

fiKti&'-fa"* ZJr-ujn 

Phone# 

wjys-ioi 

ra<" 

GENEHAL SERVICES AC DMINlSTRATlON 

V I 

- '"3 'j ;'rj 

'' IE! 

* G Iff 

?to* 

Sir 

OT-
P.10 

04/07/98 12:09 ©919 541 5689 EPA ESD CCPG 

_Apy*oe-9S.!d9::25A Creat i 

i Frenv J«tw Sefw^Uer. To: DavW Cwim 

• 1 i v i ; v 

• •• •• ••{,* •

 ;

 -

©.002 

ve Pultrusions o«t«. •.Jul* 1 BOB 34 7 5741 P.02 

4''* 

B! 

i'l 

:fi! 

;m i !•?* 

April 0.1998 Beviied 

Pultrusion Industry Council 

•ji-rr^c^^RpppSA^HitViiv' 

i l l 

' i.f. \ t \ I. 

• -\ -

Eact pultrusior. operaliorj. al erisung major sources shall comply with ans ofthe following 

options:. 

A'.Continuous Embaion Monitor and ToUd Enclosure Khali he employed to bhow thai lh* 

.pyduusioft operations at a source dc noi emit more than 30 pounds of IIAP per every ton 

j iof:Tcsin processed. 

i : 

2. An annual emission l«st. combined with monthly emission estimates using conlrol 

iat-ioK. shall be employed to show thai th* combined puHr usion oper aliens al a source 

do not Pmit more than 30 pounds of RAP p**"" ton of rtsvn processed. 

3. Direct die injection shall "be employed. 

j*. NS'et area enclosures with 5'i maximum opening shall be employod to minimi Kr TM>ntact 

of wei rcwri to free flowing air. 

Bach of these Cour option^ is explained on the following pages. 

I S' 

*.*» 

' '8 

ib 

§ 1 

Am 

• I* 

Isf. 

*•'. I 

I. 

i :..fl 

•l -IN ' 

I . . 

h' 

as 'rf 

sill 

••j** i f 

.?•* . •• 

•$.. :-U 

°l \ \ 

I. ' 

yi 
04/07/98 12:09 091 9 541 5689 EPA ESD CCPG 

vo Pultrusion e 

. Prom. Jo^SSttwiilnnTs; D«to &*n» 

I 

Hi; 

i

j

i 

•J»\.. •«..»«» 

1 505! 347 574 1 

•:|i'-" -

•il.'r 

•!::• 

•. ?*-. • : 

V V:r 

* 

..••t-! • • 

*.-X •* • 

*.-pi-' 

• ,.w ••• 

•••-.fi--:,. 

•.$" : 

•*• • 

4 . 

I 

* i' 

• I. 

i'V 

• v-

•.* i s. 

!1V 

•.'• if 

i :Tt 

;f 

••!?• 

• >r' 

' -1. 

> 

j Option 1 -CEM and Total Enclosure to Demonstrate Emission Limit 

! The source shall comply with an overage Emission Limitation nf 30 pounds HAP emitted 

f jj«*-r ton ofresin pTocesscd (including any HA? monomer added). Compliance with thtt 

;. Emission Limitation-ahall he dcmonstraterl by rhp following method: 

The pultrusion macnincs :'hell be enclosed in a Porrcsuie.it Total EnclosureOO- designed and 

operated according to EPA Method 20-1 except under special renditions sueh as: 

a. During polyester tesin deliYcriesb. During waste pickups; 

c. During equipment malftinerion: 

d. During rou line xn ainten an ee an ri OIM n i n « activities. 

• It should br noted thai the facility/source will not operate in excess of \0% of the time 

j Under, the special enhditions identified above* and 'here will be uo sifmficam inaease in 

:

. emission rates during special condition activities. Becord Veeping procedures will be 

• available and maintained demonstrating that the source is in compliance with MACT 

'Standards during special conditions. 

In addition, doots. that lire usually closed, used for employee access and exit will no* be 

deemed Natural Draft Openings (NDO's). 

A Continuous "Eminsions Monitor (GEM) shall be employed to measure emissions. Fd;r 

gaps" in emiwion concentrations resulting from resin deliveries or waste pick-ups. 

historical and op^ratinR (""EM data will be used to reconcile emissions durins "gap*" so ihey 

ar^.rv-presentafcivo. Acceptable Volatile Organic Compound (VOC) detection -*rincipl*s. are 

those that are identified and meet performance specification* in 40 <7FR. Fart 60 Appendix 

B and include ihe following* technologies: 

a. i'-flaine ionization (Fl) 

h. ;$&©toionization (PI) 

c.) 'Inondispersive infrared alsurp tion (SDJR) 

djijjothar detection principles that are appropriate for VOC speci«* 

..ft'.: ' 

•r 

A 

(1) how average 

concentration durinp a one (1) hour interval. 

•iM . .• ! 

Every month, the lotal pounds HAP emitted, as measured by the pEM 8nd multiplied by 

monthly air flow measurements, for th* most recent 12-month period, shall bt» divided by 

rhe. total rexin plus HAP monomers and solvent processed during that 12-monrh period, and 

this ratio shall noi eicw»l 00 pounds IIAP emitted per ton of maw rials prowled. | 

•;;;,' • t 

in 

• j ;. 

I 

• 1 

[0 

©003 

P

'f3 - f 

? ;

 •••• » 

••:; i # 

\d 

»:' 

• -w 

.11 I* 

Ar* 

m 

. vV 

•i.i 

n 

W 

'• **•. 

a ' 

•E 

'•"si 

inm 

' : » 

i i: 

' '••BIMP 
_E.12_ 

>•• vt/vi/vo 12:111 •S'919 541 5689 

r AM* :§•• 

_: Apl"*06J;9S.309:25A Creativ e Pultrusion s 

. • fto«. Jo,y>SisjwBiiar!To:OjwHEv»n» »..T. J~. 

I'-: 

EPA ESD CCPG 

1 50 5 3* 7 574 1 P.0 4 

^Option 2 - Control Factors, Record Keeping, and Annual Emission Test to Show 

:vEmissions Less than 30 LBS HAP per ton of rosin processed 

r| 

j Based on the 30 lbs HAP emitted per ton of resin processed requirement, the following will 

| bo monitored on * monthly basis with reports available for inspection by the appropriate 

• authorities: 

:: I 1. Total JIAP based on Inventory ond Purchasing records and the MSDS SARA 315. 

HAP Component Percentage 

: 2. Control Factors-

'.' ; 3. Percentage of Emissions ficom AP-42 

i V 

mv, 

'or .the purpose .of calculating the following factors vill ?pply ft* on line emissions controls: 

" 'x': ! 

Control Faejfii 

1.00 

0.51 

0.41 

0.01 

\ -t '; Control . 

: ;:] ij Open hath, wet ar«-ac' 

.'|j i! Air Flow Man agament 

:. '3 jj Enclosed wet areas 

•:."'!{ •;. Direct Die Injection 

'•!tj|: _ j 

JTh'^fbiinula for determining* total HAP emissions is: 

"i JiMi' ((Control Factor) K( HAP uaed*.05» / Quantity resin processed in tons * pounds 

ii* 

IIAP/ ton ofresin processed 

!}:ii d.-

i-rtp.jcamphvin a fix line 

I lj''. • ; ;,j.' • Thia would lie an acceptable ooeration. 

; is'- j . ij! •'

 r 

operation as indicated: 

m • . ' 

>\i 3.Una«with DIPTnJBrt.ion 

• :l.\:. .H lines with Endosad wet ureas 

rt !!

 40.000 lbs . Resin at 35% HAP tO.ot 4S 

v.r..ii 

•"' ' i ' i ' 

.

!

] j. IfCf s «40.000 x 0.35)0.0G)/20 * (0.41 x ((40.000 x 0.Sfi)O.O5)/2)]} / U0} - 24.? lbs 

• ;!?;'. HAP/ton . : • 

Combinations or controls can also he factored into a multiple line operation. For example 

the-Eacility above with th* same controls at the die but also Air Flow Management, would be 

thffRarne formula times the additional factor or: 

i\ r 

itt.7xO.RI-s'J 2.6 lbs/ton 

:! i 

w 

i

: i! 
P.13 

04/07/98 12:10 ©919 541 5689 EPA ESD CCPG 

Apy-osOe-ie^OS: 26fi 

From: Jonn ScnwiiUtr .To. DtrM Ei mt 

Si 

Creative Pultrusions 1 505 347 5741 

(2)005 

P.05 

Option 3 - Direct Die Injection 

L 

. *r • 

*.. 

I 

•J. 

-r* * 

. fc* 

1 «' i 

Direct- die injection shall he employed, such dial all resin applied lo the reinforcement is 

delivered diwetl-r to the die. No pw-wwtring of The reintorrement is allowed. Any rewn 

ssuing from the die entrance must be collected in a «>.««• that is covered and has no more 

hah 1.0 inches of clearance around the dw »niranoR. 

" WIS I :} : * 

:•«;••!. ! ;. i 

'.•'* l-l . •• • .. 

: 41 (, •' .; 

!**. ? . I . •; 

.•' 

: :i-

..J! -':'i 

« 

i:v 

tfi. 

• •)•• 

WV 

;

-!i 

m 

• 'i j ".-• 

..;. 1- .. 

fr 

,'.-*i 

.'.vM ; 

•:ii' 

'*£• ! 

i'i; 

j: 11 

i ' •;!!• 

.••'ji 

' fri1 

ii 

:te.:.-4i4.1 I '2 
P.M 

04/07/98 12:11 ©919 541 5689 EPA ESD CCPG 

• Ap*r^06-9B :OS:26A Creafiv e Pultrusion s 1 50 5 34 7 574 1 

• hwn : John SchwtHjer ,To David CvaM vmw. "J" " •»•<• • •••.•-«•" • 

» .•' . '-.' • 

:l 

! --ii'*:-

iM.! it 

Op3; tion4-

m 

nolosures 

!

 ']'••• 'Tncfwjurce shall employ enclosures on all wet process areas when using open resin baths. 

. I Cnc&sutes shall be designed and installed acecrdhig to the following criteria: 

f. .*.-' 

•If.-

?. • 

V 

*• 

d 

: r 

L. -The endosure shall cowx the top. botcom. and sides of ii*- open bath area in vt'hjfh 

:

 reinforcements are wet. out and are moving toward the diefr). Th* end* of tha enclosure 

shall b* closed as mucj as practical with allowance for openings to cnabl* the material 

to; enter and exit the e-iclosurc. , 

l .l The enclosure ahall extend&om the fiber carding index lo within 6 inches of the die 

i l l 

entrance or'Radio t>pquenry (RF) prcheal unit. 

r" 

1.2 The ope/t areas ofthe enclosure shall not exceed 3*i.uf the total area of the top. 

; bottom, sides, and ends ofthe enclosure. 

• •,' i . ; 

. J.-3 The stock rating cht KF preheat unit, and just prior to the die. docs not rpepiiTP a 

.-•« \. cover. 

2. Resin drip off ac the dc entrance shall be allowed, but must be collected in a device that 

is covered end has no more than 1.0 inch clearance around the drip off. 

3. Access panpla, doors, hatches, or flexible curtains -shall be considered part of the 

enclosure. 

-I. .Porta for lpvd control de-vieey. m-miiorifig devices, agitation shaOs. X311 hows, vie... shall 

have no more than 1-0 Inches clearance. 

5. -|No fans, blowers or airlines shall be allowed within the pnclosure. The enclosure shall 

;nbtbe ventilated. 

1 * * '. 

6. ijProcedures shall be enforced and records kept to show that the enclosure is in placo 

.'during operation. 

;•'• « 

...p. 

••' & 

fd '• 

ii*. 

• :v lit'-. 

ill!, 

iii-

'ifc-i*.: wm 

A Mf 

•T. 

• 'i: 

. 1 

il; 

::i.-. 

il ." 

Ilh' 

-i i'-

:; ;•• 

,:'•• Ij 

fW '• 

• . <s . •. 

.... ^. . 1 

;• a 

1

 n • '< iw \ 

*. ••rt'Sl. i. 

:M'-

•;r..'; • 

m • 0 

Iglpoe 

p'.'oe v|{ 

1. i«s 1 * e 

. .1 f-f 

i i l 

-m 
P.15 

**••* « * W **W W 4 • i -wwi IWI vi u tw A I f^» 

/^- -/-.Actrt? /^7 c~% /-jr 

inc 

271 Barnard Avenue, San Jose, California 95125 

Fax (408)297-0601 Phone (408)297-9300 

Normal Delivery x Urgent Delivery Confidential 

Company: Pacific Environmental 

Services, Inc. 

Attention: Melanie Proctor 

From: Terry S. McQuarrie 

FAX# (919)941-0234 

Date: April 16,1998 

Dear Melanie: 

Attached is the final revision as per our telephone conversation of eariier today. I have 

taxed a copy to Dave Evans to forward to the PIC Technical Committee and one to 

Madeleine. I look forward to our meeting tomorrow. Thank you for your help and input 

on this project 

II 
, P.16 

WET AREA ENCLOSURE DEFINITION DRAFT: 4/16/98 Revision #2 

If wet area enclosures are used to meet the Maximum Achievable Control Technology standard 

for pultrusion, they shall be designed and installed according to the followmg criteria: 

1. The enclosure shall cover the open bam and enclose the forming area in which 

reinforcements are wet out and are moving toward the die(s). The surfaces ofthe 

enclosure shall be closed except for openings to allow material to enter and exit the 

enclosure. 

2. For pultrusion machines with a radio frequency (RF) pre-heat unit, the enclosure shall 

extend from the beginning ofthe resin bath to within 12.5 inches or less ofthe entrance to 

the RF pre-heat unit If the stock that is within 12,5 inches or less ofthe entrance to the 

RF pre-heat unit has any drip, it does require an enclosure The stock exiting the RF preheat unit is not required to be in an enclosure if the stock has no drip between the exit 

ofthe RF unit to within 1/2 inch ofthe entrance of the die. For pultrusion machines 

'without a RF pre-heat unit the enclosures shall extend fiom the begmning ofthe resin 

bath to within 1/2 inch or lessof the die entrance. 

3. The total open area of the enclosure shall not exceed 4.0 % ofthe following calculated 

surface area (A): 

A = 2(HL + HW + LW) 

•where, 

H = height measured fiom the top of the resin bath to 

the top ofthe enclosure. The height ofthe enclosure 

shall not be greater than 1.55 x uie depth ofthe resin bath. 

L = length measured fiom the begmning ofthe resin bath 

to widiin 12.5 inches ofthe RF pre-heat unit or to within 

1/2 inch of the die entrance for pultrusion machines without 

RF pre-heat units. 

W - width equal to the width of the resin bath. 

(a) All areas which are considered open need to be counted in the total open 

area calculation. 

(b) The area which is displaced by entering reinforcement or exiting product 

is considered open. 

(c) Areas diat are covered by brush covers are considered closed. 

\*> 
P.17 

RPR 16 '98 0i:07R1 GLASFORMS INC r.o^o 

4. Open areas for level control devices, monitoring devices, agitation shafts, and/or fill 

hoses shall have no more than 1.0 inch clearance. 

5. Access panels, doors, and/or hatches that are part ofthe enclosure shall remain closed 

except during malfunctions. 

6. No fans, blowers, and/or air lines shall be allowed widiin the enclosure. The enclosure 

shall not be ventilated. 

7. Resin drip off at the die entrance shall be channeled through a closed pipe or covered 

trough into a container such that the following conditions are met: 

(a) The maximum allowable vertical distance that resin may drip through the open air 

fiom the bottom ofthe die to the closest point ofthe pipe or covered trough shall 

not exceed 1.0 inch. 

(b) The size of the opening in the pipe or trough mat collects the drip shall be no 

longer than die width ofthe die(s) and no wider man 1.0 inch. 

(c) The maximum allowable vertical distance that resin drip may be exposed to air 

fiom the exit of the closed pipe or covered trough to the opening of the container 

shall not exceed 6.0 inches. 

(d) The si2e ofthe opening in the container that collects the drip off shall not 

exceed 1.0 inch in diameter. A funnel may be used to aid in the collection 

ofthe drip off. 

Ko