p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

27) IV-B-29 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 27 of 273 
P.2 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

DATE: 

National Emission Standards for Hazardous Air Pollutants: Reinforced Plastics 

Composites Manufacturing - Capture and Control for Large Parts 

Keith Barnett 

Project Lead for the Reinforced Plastics Composites NESHAP 

Docket for the Reinforced Plastic Composites NESHAP. 

February 10, 2003 

In response to information presented by the American Composites Manufacturing 

Association (ACMA), we are subcategorizing new source floors by part size. Therefore, it is 

necessary to develop the criteria for part size classification. This memorandum documents the 

development ofthe criteria. 

The basis for subcategorizing by part size is that facilities producing large parts are not 

similar to facilities producing parts such as bathware and truck caps because large parts require 

larger airflows relative to emissions, and also require large doors for part access. Some examples 

are underground storage tanks, barge covers, and large domes. Based on this, EPA determined 

that the part volume is the most accurate indicator ofthe difficulty to capture and control open 

molding emissions, with the largest square footage ofany one side being a secondary indicator. 

In order to determine the appropriate volume for open molding parts, we reviewed the 

information for two A.R.E. facilities. A portion ofthe trip report to these facilities is attached 

(Attachment 1), along with additional information on part sizes for A.R.E. and Tecton 

(Attachments 2 through 4), and information on moving parts in and out of permanent total 

enclosures (PTE) (Attachment 5). Table 1 presents the characteristics ofthe A.R.E. facilities. 

Table 1 Characteristics of A.R.E. Facilities 

Location 

Mt. Eaton, Ohio 

Massillon, Ohio 

Part Sizes 

Produced 

Custom Molded 

parts, up to the 

size of a hearse 

body 

Pick-up Truck 

caps 

Type Of 

Production 

Custom molding 

in a single 

permanent total 

enclosure (PTE) 

Production line 

in a single PTE 

Size of PTE 

85'x 75'x 25' 

165'x 68'x 27' 

Size of spray 

booths/areas 

18' x 16' Booth 

18'x 16'Booth 

17.5'x 15'Booth 

42.5'x 37.5* 

(Large parts 

spray up area) 

25'xl9' 

68' x 28* 

1 
P.3 

Both of these facilities meet 95 capture and control requirements. 

The largest single part built at A.R.E. is a custom car body. (A.R.E. does not produce a 

complete car body, only the rear portion). This part had dimensions of 114 inches long, 63 inches 

wide, and 60 inches high. Ifthis part was placed in the smallest possible rectangular six-sided 

box, the interior volume ofthe box would be 250 cubic feet. The largest side ofthe box would be 

50 square feet. Therefore, we choose these dimensions as the largest dimensions for which 

capture and control is demonstrated for open molding. We believe that it is most appropriate to 

base the definition of large part on the actual size ofthe largest part produced. We could have 

considered basing the definition on the size ofthe largest part that would fit into the existing PTE. 

However, we believe that this would be speculative, because there is no data to show that the 

facility is capable of producing the larger parts, or that, if it did, it could do so while meeting 

Method 204. 

For pultruded parts, there is one facility that has 95 percent capture and control. This is 

Tecton in North Dakota. The largest part produced at Tecton is 10 inches wide by 2 inches high. 

The largest number of reinforcements in any part at Tecton was approximately 350. Because the 

capability ofa particular pultrusion machine to accommodate a specific part size is mainly 

dependent to the largest die the machine can accommodate, the most accurate measure ofthe size 

ofa pultruded part is the outside perimeter. Therefore, we choose an outside perimeter of 24 

inches, and 350 reinforcements as the largest parts where capture and control are demonstrated. 

As with open molding, we choose to use the largest part size actually produced, not the largest 

size that the facility believes could be produced. 

% 
P.4 

*m—/ \ 

FINAL TRIP REPORT 

IT-B -

NONCONFIDENTIAL VERSION BASED ON PLANT COMMENTS 

MEMORANDUM 

TO: 

FROM: 

DATE: 

SUBJECT: 

REFERENCE: 

Project file of Reinforced Plastics Composites Manufacturing NESHAP 

Keith Barnett, U. S. Environmental Protection Agency, Emission 

Standards Division 

December 28, 2000 

Site visit to A.R.E. Inc. 

Reinforced Plastics Composites Manufacturing NESHAP, ESD Project 

No. 93/58 

I. INTRODUCTION AND PURPOSE 

The purpose ofthis visit was to obtain information on the reinforced plastic 

composites manufacturing operations at the two A.R.E. Inc. facilities located in 

Ohio. Specifically we wanted to focus on the capture and control of emissions 

from these processes. 

n. 

UI. 

PLACE AND DATE 

A.R.E. Inc. 

500 Nave Road 

Massillon, Ohio 44648 

330-830-7800 ext. 201 

February 16, 2000 

ATTENDEES 

BDM 2 6 2001-

ffAAIpr.:*:* -,<ET 

Mr. Ralph Gatti, A.R.E. Inc. 

Mr. Chuck Taylor, GT Environmental, Inc. (consultant to A.R.E.) 

Mr. Keith Barnett, U. S. Environmental Protection Agency 

Ms. Melanie Proctor, Pacific Environmental Services (contractor for USEPA) 

IV. SITE INFORMATION 

This site visit covered two facilities, the manufacturing facility in Massillon, Ohio, and the 

facility in Mount Eaton, Ohio. The company had prepared a detailed response to a list of 

questions for both facilities prior to the site visit. This information is included as attachments 1 
P.5 

and 2. Subsequent to the site visit, A.R.E provided additional information in a letter dated 

February 23, 2000. This included information on the two stack test reports, permit information, 

and a determination from Entropy (the company that performed the emissions test) that the exit 

tunnel from the laminating area is not a natural draft opening. This information may be found as 

Attachment 3 to this trip report. 

A.R.E originally had one facility in Mount Eaton. The Ohio EPA has a rule 

(Rule 21-07(G)(2)) that limits organic compound emissions from any one source to 40 pounds 

per day and 8 pounds per hour, or requires 85 percent control. The Mount Eaton facility could 

not meet that requirement without either reducing production by 2/3, or retrofitting add-on 

controls. A.R.E. decided that using add-on controls was the best solution, and that building a 

new facility designed to meet these requirements would be easier that trying to retrofit the Mount 

Eaton facility with add-on controls. They also needed to expand their production space. 

The decision to build the new facility was made in January 1994. At that time A.R.E. was 

a small business with less than 300 employees. The company is now a large business with oyer 

500 employees. The emissions from the Mount Eaton facility in 1993 (based in toxic release 

inventory reports) were 48 tons per year (tpy) of styrene and 74 tpy of total HAP. In 1994 

emissions were 63 tpy of styrene and 91 tpy of total HAP. In 1995 emissions were 57 tpy of 

styrene and 70 tpy of total HAP. The other HAP emitted are from painting operations. In 

August, 1995 the Massillon facility started up. 

Due to the size ofthe new Massillon facility, Ohio EPA required all major processes to 

meet a 95 percent emission reduction requirement. Processes that do not meet the 95 percent 

requirement meet the 40 lb/day and 8 lb/hr requirement of Rule 21-07(G)(2). 

The original plan was to curtail operations at the Mount Eaton facility to the point where 

the facility would meet Ohio EPA rules once the Massillon facility started up. However, due to 

company growth, A.R.E. needed to keep the Mount Eaton facility operating. So they decided to 

retrofit add-on controls at the Mount Eaton facility. This retrofit was completed in 1999. 

Massillon Facilitv 

This facility produces caps for pick-up trucks. Figure 1 presents a process flow diagram 

for this facility. Emission points in Figure 1 identified by P are process operations. Emission 

points identified by "Z" are exempt from Ohio permitting requirements. Emission points identified 

by "K" are coating operations. Figure 1 also shows the portions ofthe process that are contained 

in a permanent total enclosure (PTE). Table 1 presents size and airflow information on specific 

production areas. 

Molds are stored next to the lamination area. A mold is taken from storage through mold 

maintenance, mold cleaning and release application, and then enters the lamination area through 

6 
P.6 

t)2-'12/03 WED 10:35 FAX 2022604400 

EPA_AIR DOCKET 

@)002 P 

Z302 

Touch-Up 

Area 

Z309 

Paint Repair 

Sandin

g and 

Grinding 

Booth 

Z319 

Final 

Assembly 

Area 

V * 

cv KOO 

>. pra IntS 

a 

a. 

ooth 

III 

iers: lea 

o 

c 

iS 

** 

a. 

a. 

o ?5 

"1 

CO O 

ISJ £• 

- Ol 

T - 3 

n C N £ 

O -D 

T* CD 

<••> * 2 Nl

 n 

O 

- 1 P011 

Mold Cleaning 

and Release 

Application 

Booth 

4 -

Z301 

Mold 

Maintenance 

>•» 
TABLE 1. A.R.E., INC, MASSILLON FACILITY PTE AND SPRAY BOOTH DESIGN 

INFORMATION. 

* 

~iS§v 

PTE Description 

Mold Maintenance 

Resin Mix Room 

Glass Room 

Gelcoat Booth 

Gelcoat Tunnel #1 

Laminate Room 

Resin Tunnel #2 

Exit Tunnel #3 

Total from Glass Room 

Paint Booth #1 

Paint Booth #2 

Paint Booth #3 

Paint Booth #4 

Paint Mix Room 

Total to RTO* 

Length 

(ft) 

30 

28.67 

164.67 

25.33 

78.67 

68 

78.67 

84 

54 

54 

54 

54 

38.67 

Width 

(ft) 

18 

20.67 

68 

19 

11 

28 

10 

10 

13 

13 

13 

13 

20 

Height 

(ft) 

11 

22 

27 

9.25 

8.75 

11.25 

8.75 

8.75 

11 

11 

11 

11 

13.67 

Volume 

(cuft) 

5,940 

13,037 

302,334 

4,452 

7,572 

21,420 

6,884 

7,350 

7,722 

7,722 

7,722 

7,722 

10,572 

Exhaust 

(cfm) 

8,700 

900 

13,500 

6,600 

14,940 

6,500 

8,700 

50,240 

12,500 

12,500 

12,500 

12,500 

1,000 

109,940 

Air Exchanges 

(#/mln) 

1.5 

0.1 

-AB-dB3'Mj5K5liji8m3g 

a? *-*&**gM3Simi8 

3.0 

0.9 

0.7 

0.9 

1^2 

1.6 

1.6 

1.6 

1.6 

0.1 

Openings 

Description 

17 @ (1.5x1.5) 

None 

4@(5x2); 1 @(10x4) 

1@ (16x6.67) 

2 @ (11x4) 

2@(10x8); 1 @(20x 

2 @ (10x4) 

2 @ (10x4) 

None 

None 

None 

None 

None 

Area 

38.25 

N/A 

40.0 

106.7 

88.0 

320.0 

80.0 

80.0 

N/A 

N/A 

N/A 

N/A 

N/A 

Comments 

This unit is under construction 

Exhausts into Glass Room 

NDOs are 4 louvered air intake ducts ir 

Opening inside Glass Room 

Openings inside Glass Room 

Openings inside Glass Room 

Openings inside Glass Room 

i roof 

One opening inside and one NDO outside 

HS& 

Each booth consists of a separate painting 

room and curing oven. 

Includes Mold Maintenance, Glass Room, 4 Paint Spray Booths and Paint Mix Room. 

02/15/2000 

**• 
P.8 

a tunnel. The tunnel entrance has a roll up door that is closed unless a mold is being moved into 

the tunnel. A mold cleaning and release spray booth that will be ducted to the regenerative 

thermal oxidizer (RTO) was under construction at the time ofthe site visit. This booth will be 

inside the PTE and will be assumed to meet 100 percent capture. Some minor mold repairs are 

performed in the mold maintenance area (Z301). 

The lamination area consists of two spray booths. The first is the gel coat booth (POOl) 

where the gel coat is applied to the mold. The second is a long laminate spray booth (68 feet x 

28 feet) where two layers of laminate are applied using atomized spray-up (chopper guns) at two 

different stations (P002 and P003). The resin contains 36 percent styrene, and the gel coat 

contains up to 38 percent styrene by weight. However, the facility calculates their potential to 

emit assuming a 42 percent resin HAP content because their air emissions permit allows them to 

use resin with up to 42 percent styrene. The air exchange rates are 3 per minute in the gel coat 

booth and 0.7 per minute in the laminate spray booth. Roll-out ofthe first layer of laminate takes 

place between spray-up area #1 and #2. Roll-out ofthe second laminate layer takes place outside 

the spray booth but within the PTE. After roll-out the parts exit the PTE through a 84 foot 

tunnel. The resin cure time is approximately 90 minutes. Curing ofthe resin is completed in the 

exit tunnel. The tunnel itself is vented to the RTO. For this reason, the tunnel exit is not 

considered a natural draft opening (NDO) (See Attachment 3). At the time ofthe visit, the 

facility was making improvements to the seals on the bottoms ofthe roll-up doors. 

The resin and gel coat spray booths were designed to meet OSHA requirements for 

worker exposure. There were no special provisions made in the design ofthe spray booths 

because they were going into a permanent total enclosure. As shown in Figure 1, the facility met 

the requirements for a PTE by building a wall around the lamination area where the spray booths 

are located. The walls are cinder block walls that reach from the floor to the building roof. The 

roof is 27 feet above the floor. There are. vents that route air from the PTE to the RTO in the 

roofs ofthe three spray booths (POOl, P002, and ?003), the gel coat tunnel, the resin tunnel, and 

the exit tunnel. The only natural draft openings (NDO) are 4 louvered air intake ducts high in the 

walls near the roof. These NDO open inside the building. More specific design information in the 

booths and enclosures may be found in attachment 1. The PTE design was done by Q Source in 

Cincinnati, Ohio, and GT Environmental. 

The PTE is not air conditioned. There are 4 air makeup fans that have maximum flow 

rates of 40,000 cfin each. The air flow is sufiBcient to maintain an acceptable interior temperature. 

The temperature in the lamination area in summer is approximately the same as the outside 

ambient temperature, except that it lags an hour or so behind outside temperature changes. In the 

summer the temperature can reach the 90s. In winter the makeup air is heated. 

After the parts exit the tunnel, railings and other parts are added and they are painted in 

one of 4 spray booths. The paint spray booths are also vented to the RTO and also meet the 

requirements of EPA Method 204 for a PTE. Each spray booth has two zones, a spray zone and 

a oven zone. Parts remain in the spray booths for approximately 44 minutes, ofwhich 22 minutes 

is paint application and 22 minutes is paint drying. The part does not exit the spray booth until 

the paint is completely dry. All operations subsequent to the lamination area will not be covered 

w 

7 
P.9 

by the reinforced plastic composites NESHAP. The painting operations will be covered by the 

plastic parts coating NESHAP. 

Resin and gel coat use for the Massillon facility in 1997 were 3,539,728 and 584,866 

pounds respectively. The RTO operates at all times the facility operates. The RTO had an 

average destruction efficiency of 98.27 percent during a December 1995 test. The state permit 

requires a 95 percent destruction efficiency. At the same time the testing company certified that 

the enclosure meet the requirements of EPA Method 204 for a PTE. 

The emissions at the RTO inlet were measured as 69.27 pounds per hour as carbon in the 

1995 test. Approximately 57 percent ofthe mass flow to the RTO is styrene from the open 

molding operations. The remainder is various solvents from the painting operations. The inlet 

concentration to the RTO was 431 ppm. The relative air flows are 50,240 acfin from the open 

molding operations and 51,000 acfm from the painting operations. Note that all paint spray 

booths cannot operate in the spray mode at the same time if all other units are operating. 

This facility was retested on June 12, 2000. The RTO again met the 95 percent 

destruction requirement and the PTE was again certified as meeting the requirements of EPA 

Method 204. 

There are two resin storage tanks located inside the building that vent to the RTO. There 

are three tanks in the closed resin mix room. The tanks vent into the room, and the room vents, 

into the lamination area PTE. 

The add-on controls allow the facility to have flexibility in their operations. They can use 

higher solvent paints and higher HAP resins than would be allowed if they did not have the addon controls. Worker exposure to styrene in the lamination areas was recently measured as 116 

ppm for the chopper gun operator when spraying is actually taking place. That is about 20 

percent ofthe time. Concentrations for other workers in the spray booths were 43 ppm. This 

facility meets the voluntary OSHA standard of 50 ppm for an 8-hour average. The spray gun 

operators wear respirators with charcoal filters as a precautionary measure. Any other workers 

with any exposure to 50 ppm or more of styrene are also required by company rules to wear 

respirators. 

This facility does not use any flow coaters or fluid impingement technology to apply resin. 

The stated reason was they believe that flow coaters do not work well when you have vertical 

surfaces. 

Startup from the weekend shutdown begins on Sunday at 8:00 pm and takes about 2 

hours. The RTO typically operates at 1500° F, but is allowed to go as low as 1450° F. They do 

not have continuous emission monitors on the RTO, they must continuously monitor the RTO 

temperature. 

The original capital cost and operating costs ofthe system are shown in attachment 1. 

The cost impact ofthe control device did increase the prices for the truck caps. 
P.10 

The biggest technical challenge for the control system is properly balancing the air flow. 

You must keep the enclosure under negative pressure. However, too much negative pressure in 

the enclosure makes the equipment work harder then necessary to maintain the airflow out ofthe 

enclosure. The dampers for the air handling system are controlled from the RTO control room. 

Mount Eaton Facilitv 

The Mount Eaton facility does custom molding and produces the tools for both Mount 

Eaton and Massillon. This facility is about 1/3 the size of Massillon on a square footage basis. 

The types of parts produced at Mount Eaton include rooftop carriers, tanneau covers, and 

equipment covers. At one time they also produced custom car bodies. The largest part size is 

approximately 12' x 4' x 4'. Though this facility is 1/3 the size of Massillon in a square footage 

basis, it uses less than 1/3 ofthe amount ofresin used at Massillon. In 1997 (prior to the 

installation ofthe RTO), this facility used 174,622 lb. ofresin and 16,555 lb. of gel coat, which 

were less than 5 percent of total materials used by A.R.E. 

This facility was the original facility for A.R.E. that evolved from a one room area. Based 

on the success ofthe control system at the Massillon facihty and the need to accommodate 

growth, A.R.E. decided to retrofit Mount Eaton with controls. They do not consider retrofit to 

be technically challenging if sufficient floor space is available. They built PTE in the existing 

building and then moved existing spray booths inside the PTE. The control device at Mount 

Eaton was started up in March of 1999. 

Figure 2 presents the current facility layout and Table 2 presents design information on 

individual spray booths. More detailed design and cost information are presented in 

Attachment 2. 

There are three spray booths and a large component spray-up area in the PTE. One spray 

booth is for gel coat, and the other two are for resin application. Molds enter the PTE, and parts 

exit, through large roll-up doors. The doors are kept closed during normal operation. Because 

this is a much lower volume operation, tunnels to allow curing to be completed are not necessary. 

The Mount Eaton facility also has a resin transfer molding operation. This includes a gel 

coat spray booth. Neither of these operations is vented to the RTO. The resin mix room and 

mold fabrication areas also do not vent to the RTO. Molds for both the Massillon and Mount 

Eaton facility are fabricated at Mount Eaton. 

There are 4 paint spray booths at the Mount Eaton facility. These booths were present 

prior to the retrofit ofthe RTO. Each booth is a separate PTE. These booths do not have 
Figure 2. A.R.E., Inc. Mount Eaton Facility General Process Flow Diagram as of 

February 11,2000. 

Resin Mix Room 

Catalyst 

Gelcoat 

(drums) 

Catalyst 

o 

Catalyst 

-Total EnclosureR013 

Fiberglass 

Spray-Up #1 

R014 

Fiberglass 

Spray-Up #2 

R012 

Gelcoat Booth 

Z129 

Mold 

Maintenance 

R016 

Large 

Component 

Fiberglass 

Spray-Up Area 

Regenerative Thermal Oxidizer 

(RTO) 

j** * 

Paint Mix Room 

2112-2115 

Paint Gun Cleaners 1-4 

Plant #2 Mold Fabrication 

Z128 Sanding and Grinding 

R008- Gelcoat and Primer Booth#1 

R009-Gelcoat and Primer Booth #2 

R010-Ceramic Spray-Up Area 

R011-Spray-Up Area 

R004 

Paint Spray 

Booth #1 

R005 

Paint Spray 

Booth #2 

R006 

Paint Spray 

Booth #3 

R007 

Paint Spray 

Booth #4 

Waxed 

Part Mold 

Z120 

Welding Area 

Fiberglass 

Part 

Z123 

Fossliner 

Booth 

Z121 

WoodShop 

P003 

Trim Booth 

P001 

RTM 

Equipment 

i i 

R003 

Gelcoat Booth 

•4 

4 

2122 RTM 

Tank 

Z127 

Foam 

Sanding 

P004 

Sanding/ 

Grinding 

Booth 

Each Booth is an Enclosure 

Painted 

Part 

Z116-Z117 

Paint Gun Cleaners 

Located throughout 

the facility 

R015 

Primer Booth 

P002 Prep 

Area 

2126 

CNC Cutting 

Room 
V 

TABLE 2. A.R.E., INC, MOUNT EATON FACILITY PTE AND SPRAY BOOTH DESIGN 

INFORMATION. 

PTE Description Length 

(ft) 

Width 

(«) 

Height 

(ft) 

Volume 

(cuft) 

Exhaust 

(cfm) 

Air Exchanges 

(#/mtnl 

Openings 

Description Area 

Comments 

Glassroom 85 75 1 @ (8 x 6.33); 1 @ (8 x 8) 114.6 NDOs for parts egress and mold ingress/egress 

Gelcoat Booth 17.5 15 3,150 5,890 None N/A Opening inside Glass Room 

Gelcoat Flash-Off Area 40 16 5,120 4,930 1.0 None N/A Open area within Glass Room 

Spray-Up #1 18 16 12 3,456 7,580 2.2 None N/A Opening inside Glass Room 

Spray-Up #2 

Rollout Flash-Off Are i 

7,S- N-*-» 

Total from Glass Rocm ^V^.'- : ^-.r-l i>.frf.^5gg? P 31 ,C 

N'A Opening inside Glass Room 

t'm'S 

»3£ Open area within Glass Room 

I****-*"* "til • — " 

Paint Booth #1 

Paint Booth #2 

Paint Booth #3 

Paint Booth #4 

27 

27 

27 

27 

14 

14 

14 

14 

3,402 

3,402 

3,402 

3,402 

6,300 

6,200 

3,840 

3,860 

1.9 

1.8 

1.1 

1.1 

None 

None 

None 

None 

N/A 

N/A 

N/A 

N/A 

All four paint spray booths have two modes (spray 

and bake). The flowrate in the bake mode is less 

than the spray mode. Either booth #1 or #2 is in 

the bake mode when all units are in operation. 

Paint Mix Room 28.5 8 10 2,280 1,000 0.4 None N/A 

Total to RTO* 50,000 

* Includes Glass Room, 4 Paint Spray Booths and Paint Mix Room. Note that all four Paint Spray Booths cannot be in the "spray" mode when all other units are operating. 

02/15/2000 

t-0 
P.13 

separate spray and oven zones. Both operations take place in the same zone. Parts are kept in 

the PTE until dry. The paint spray booths and paint mix room vent to the RTO. 

Control Equipment Maintenance and Costs 

A.R.E. has a maintenance contract with Durr, the company who manufactured the RTO. 

Durr now has the responsibility for all maintenance ofthe RTO and receives a fixed fee every 

month. This gives Durr an incentive to keep the RTO operating as efficiently as possible to 

reduce maintenance costs. They also upgrade as necessary to balance resource use and equipment 

longevity. There is a Durr employee on site who covers both facilities. Durr can also 

troubleshoot RTO problems remotely through a modem. 

Prior to this contract, A.R.E performed maintenance themselves. A.R.E. personnel stated 

that they believe cost estimates for RTO rarely take into account repair costs for fans, and burner 

parts. A.R.E has fixed the life cycle costs over ten years as a result ofthe contracts with Durr. 

A.R.E. said that the cost of natural gas, and the total system pressure drop had increased over 

time. 

A.R.E. choose to use an RTO rather than a hybrid concentrator/oxidizer system because 

of concerns related to the technical feasibility of concentrators with styrene and multiple other 

VOC constituents. They also had concerns that, because ofthe variety of solvents in the painting 

operations, the performance ofa hybrid system might be more variable that a RTO alone. When 

A.R.E. retrofitted add-on controls at Mount Eaton, they saw no reason to change the type of addon control because the Massillon control system was working well, and the Mount Eaton facility 

also had styrene emissions and painting operations. 

P 

IV 
P.14 

Avfcp^rx/-*^^ ARalph Gatti To: Keith Barnett/RTP/USEPA/US@EPA 

<RGATTI@4are.com> cc: 

Subiect: Hearse Body Dimensions 

02/21/2003 02:13 PM 

Keith, 

Not as large as I thought. 

114" long 

63" wide 

60" high 

Hope this helps you get this down the road. 

Ralph 

**************************** 

Ralph Gatti 

President 

A.R.E. Inc. 

(330) 830-7800, ext 201 

www.4are.com 

**************************** 

13 
P.15 

A*W&C/1,NS<^T 3 

Ralph Gatti 

<RGATTI@4are.com> 

02/21/2003 02:59 PM 

To: Keith Barnett/RTP/USEPA/US@EPA 

cc: 

Subject: The largest part 

Keith, 

The largest part that could currently make without modification to the PTO 

would be 18' long x 9' wide x 6' deep. 

If the hearse wasn't big enough to get you down the road maybe this will be. 

Ralph 

**************************** 

Ralph Gatti 

President 

A.R.E. Inc. 

(330) 830-7800, ext 201 

www.4are.com 

**************************** 

14 
02/25/03 TUE 17:23 FAI 701 277 0219 TECTON PRODUCTS 

FEB.24.2003 8:51flM hbhii r^+ H NO.570 P.2 

P.16 

@002 

CONTACT REPORT 

Person Calling: 

Person Called: 

Date of Contact: 

Keith Barnett 

U.S Environmental Protection Agency 

OAQPS/ESD/MICG 

919-S41-S605 

John Jambois 

President 

Tecton Products 

February 21,2003, and February 24,2003 

Contact Summary: 

I called Mr. Jambois to obtain information on part sizes and thdr current controls. 

Tecton products has 95 percent capture and control on all their pultrusion machines. The 95 

capture and control has been confirmed through emission tests. 

The largest parts they can produce would he 16 inches wide by 6 inches in height. The possible 

length is unlimited. 

The largest parts they have actually produced were approximately 10" wide and 1.5*' to 2" high. 

The longest part length was 40 feet. 

The maximum number of reinforcements in any cf the parts they have produced Is 348. 

* * 

\ 

Confirmation: I confirm that the infonnation above is A . correct correct -with the changes 

noted above. 

Signature: 

>,' 

16 02/24/03 MON 07: 5& [TX/RX NO 8535] ©002 
P.17 

A c-tftc/l r<\en+ ^ 

How do facilities move parts and equipment in and out of a Permanent Total Enclosure 

(PTE) and still comply with EPA Method 204? 

EPA Method 204 consists of 4 design criteria and 2 operational criteria. The design criteria are 

straightforward and simple to verify. The operational criterial are also very simple, except when 

considering doors used to move equipment, molds, and parts in and out ofthe enclosure. The 

operational criteria read as follows: 

The average facial velocity through all natural draft openings (NDO's) shall be at least 200 

feet per minute. The direction of air flow through all NDO's shall be inward 

All access doors and windows that are not treated as NDO's shall be closed during routine 

operation ofthe process 

It is this last criteria that has been most confusing to the reinforced plastics industry. 

Why is this important? 

Fabricators must move parts and equipment in and out of PTE. If they are required to treat 

access doors as NDO's, the airflow required to ventilate the PTE, and the cost of control, are 

increased. For small parts this increase may be negligible, but for large parts this could double the 

airflow requiring control. 

What does the criteria really mean? 

The requirement that access doors and windows be closed is not intended to require that these 

doors be closed at all times. It means that doors must be closed any time that you are not actually 

moving parts or equipment through them. 

Why don't we just say that? 

Obviously, in some situations an access door should be treaded as an NDO. For example, ifthe 

access door is used so often that it is almost always open, then it should probably be considered 

an NDO. We could establish a time limit, but every facility is going to be different, and a specific 

time limit would reduce the flexibility ofthe method. We allow the permitting authority to make 

their own determinations concerning when a door should be considered an NDO. Factors they 

typically consider are: 

Size ofthe door 

Location, i.e. is it close to the actual emission points, or far away 

• What percentage of time is the door open 

• Does the door have hanging plastic strips or an air curtain to reduce the effective area? 

How can a facility determine if a door will be treated as an NDO? 

A facility would need to submit to the permitting authority the design ofthe PTE showing 

emission points, air flows, door locations,, and estimated time the doors will be open. It would be 

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up to the permitting authority to approve or disapprove the design. Ifthe design is approved, 

then it is the responsibility ofthe facility to build and operate the PTE in accordance with the 

submitted design. We do not see this as a tremendous burden since a new facility will have to do 

this in any case. 

Does this mean that at some times, the PTE will not have 200 feet per minute through all 

openings? 

Yes. We recognize that allowing access doors to be opened to move material through them can 

potentially result in HAP escaping the PTE. We have never stated that meeting the requirements 

of EPA Method 204 will mean 100 capture of emissions, 100 percent ofthe time. The method 

was intended to get as close as we can to 100 percent capture, but still allow facilities to run their 

production processes in an efficient manner. However, as long as the approved Method 204 

design and operating criteria are met, we credit the facility with 100 percent capture. 

It should be noted that 200 feet per minute is a very conservative figure based on the NIOSH 

industrial ventilation guidelines. So even when doors are open and a facility does not have 200 

fpm through all openings, capture efficiency will still be 100 percent if all airflow is inward. 

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