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OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

25) II-B-21 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:00 AM Sheet 25 of 56 
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IT-6-9,1 

MEMORANDUM 

TO: Reinforced Plastics Composites project File 

FROM: Keith Barnett 

DATE: December 13, 1999 

SUBJECT: Emission test data for Intermetro Industries Corporation 

Attached to this cover memo is a portion of an emission test report for Intermetro Industries in 

Fostoria Ohio. This test was conducted for the Ohio EPA. 

The facility rested has two pultrusion lines, each capable of running two rail sections 

simultaneously. The test was on both ofthe lines. These lines were enclosed using a temporary 

total enclosure that met the requirements of EPA Method 204. 

The test results showed that an average of 3.63 pounds per hour of styrene were emitted. The 

source operated at an average rate of 165 pounds of resin per hour. The resin has a 42 percent 

styrene content. Based on this, 5.23 percent ofthe available styrene was emitted. Both lines have 

open resin baths and neither has a wet area enclosure. 

During testing the airflow over the bath was approximately 40 feet per minute. This measurement 

was made over the resin bath prior to testing and was not measured during the actual test. The 

measurement was made with a Air Data MultiMeter model ADM-870 Electronic 

Micromanometer fitted with a Velgrid compound pitot tube. 
-e-a-i 

OhfeERA 

State of Ohio Environmental Protection .Agency 

Northwest District Office 

347 North Dunbridge Road 

Bowling Green, Ohio 43402-9398 

(419) 352-8461 FAX(419) 352-8468 

PLEASE DELIVER THE FOLLOWING PAGES TO: 

NAME: Keit h Barnet t 

COMPANY/DIVISION: US EPA 

FAX NUMBER: (919 ) 541 - 347 0 tel - 560 5 

FROM: Pau l Cha d 

DIVISION: Ai r Oualit y (DAPC) 

TOTAL NUMBER OF PAGES INCLUDING COVER LETTER: 

SENDER'S (SECRETARY'S) SIGNATURE: 

DATE: 11/17/9 9 

SUPERVISOR'S SIGNATURE I F FAXING MORE THAN 20 PAGES 

COMMENTS: 

Hi Keith, 

Here is the test information we discussed. If you 

have any questions, let me know. 

Paul 

IF THERE ARE ANY PROBLEMS, CALL OHIO EPA NWDO AT (419) 352-8461. 

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ON@EFft 

State of Oltio Environmental Protection Agency 

Northwest District Office 

347 North Dunbridge Road 

Bowling Groon, C*K!o 43402 

(419)3S2-8461 FAX (419) 352-8468 

Goorgo V. Voiiiovloh 

Governor 

Stack Test 

August 12, 1998 

Mr.-Ruu VUIA fko,^\L Wu&s^ v-t?U(ua.l V ^ h> Thro RoiM^^ni. 

Intermetro Industries Corporation 4 tQ- M^)S- 5^ ^ 

1150 State Street 

Fostoria, Ohio 44830 

Dear Mr. Veres: 

Re: Intermetro Industries Corp. 

Seneca County o'' 

Premise No. 0374010 Mo^jfo**^ ^ ' 

Start Tpst t « ^ 

The stack test done on your pultrusion lines,Ohio EPA Source No. POOl, on June 10, 1998 has been 

reviewed and found to be in conformance with Ohio EPA methods and procedures. 

Our test review confirms the following reported data as accurate: 

Critical Test Data 

(In Three Run Averages) 

1. Actual Emission Rate: 

2. Allowable Emission Rate: 

3. Source Operating Rate: 

4. Maximum Source Operating Rate: 

VOC 

3.4'/hr 

To be determined 

165'/HR combined 

195.4'/HR combined 

All test information will be used by Ohio EPA personnel for permit processing and review. Thank you 

for your cooperation in this matter, and please call me if you have questions or comments. 

Sincerely, 

Tom Sattler 

Division of Air Pollution Control 

/dlh 

pc: NWDO File 

Stack File 

Paul Chad, DAPC, NWDO 

Printed oo recycled paper 

(revised 12/93) 

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INTRODUCTION 

GLvV>u 

LtoW /YVA, -& 

C/V< 

•^oOv-U/ ^ QAAMI^ U 

The Environmental Analysis Laboratory of Ashland Chemical Co. performed emission testing 

for the pultrusion operation at the InterMetro Industries Corporation plant at 1150 State Street, 

Fostoria, Ohio, on June 10.1998. "Ine pultrusion operation consists of two lines operating in 

parallel to one another. Both were operating at full capacity during the test Air flow and 

emissions were measured by William J. Frost, CIH, Senior Research Chemist, James P. 

Hendershott, Staff Scientist, and Clifford R. Glowacki, CIH, Senior Group Leader, of Ashland 

Chemical Co. Tom Sattler ofthe Ohio Environmental Protection Agency monitored the three 

one hour test sessions. David Lipiro/of ECRM designed and supervised the construction ofthe 

temporary total enclosure, and was present for consultation during the tests. Mr. Tom Rash 

represented InterMetro. \ 

* 2>30-qoS-O4ll 

SUM.MARY OF RESULTS £oVSH3 -3SW CPPV3 

The styrene emissions measured during the three one-hour test periods are summarized as 

follows: 

Start Time 

11:15 

13:15 

15:30 

Pounds/Hour 

as Styrene 

3.4 

3.5 

4.0 

Pounds/Hour 

as Carbon 

3.2 

3.3 

3.7 

Styrene Emitted 

as % Of Paste 

2.1 

2.2 

2.4 

(sr/kwe) 

The column labeled "Pounds/Hour as Styrene" refers to the total quantity of styrene emitted 

during tlie one hour period starting at the indicated time. The column labeled "Pounds/Hour as 

Carbon" is calculated, based on the empirical formula of styrene, CgHg, which indicates that 

styrene is 92.3% carbon, and 7.7% hydrogen by weight The column headed "Styrene Emitted as 

% Of Paste" refers to the total quantity of styrene measured, expressed as a percentage ofthe 

total paste used in production of pultrusions during the defined one hour test 

Detailed calculations for these emission rates may be found in the attached Tables 1 through 5. 

The field data may be found in Appendix A. The production data showing the total quantities of 

paste used may be found in Appendix B. 

Total Enclosure Determination 

A temporary total enclosure (TTE) complying with USEPA Method 204 was installed before the 

start of the tests. It included a fugitive emissions duct to be used if necessaiy to insure natural air 

flow conditions. The TTE was designed with sheet plastic walls that could be pulled up to 

prevent any interference with the natural air flow. On June 9, the day before the tests were run, a 

base line of emissions was established. The plastic was then pulled down to prevent fugitive 

emissions, and a new base line was established without tiie use ofthe fugitive emission duct 

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The baseline emissions were 108.8 ppm with the walls open, and 107.7 ppm with the walls 

closed. This amount of change was within the Hmits specified in Method 204; therefore, it was 

not necessary to use the fugitive emission duct during actual testing June 10. 

Before and during each test, smoke tubes were used to confirm that air flow at each opening was 

into tlie TTE. 

Velocity Measurements 

Velocity measurements were performed in compliance with USEPA reference Methods 1 and 2. 

The duct being sampled was round, 9.5 inches in diameter. Access ports were drilled which were 

greater than eight diameters from the last previous disturbance, and greater than two diameters 

from the next disturbance. One port allowed measurements on the vertical cross section, the 

other allowed measurements on the horizontal cross section. Eight points, four per each cross 

section, were measured. 

Differential pressures were measured with the use of an inclined manometer and a standard pitot 

tube. The results were manually recorded in a bound notebook by a member ofthe testing team. 

These records are included in Appendix A. The temperature and humidity were also recorded 

during each run. These were used to calculate a corrected flow rate for each test, as shown in 

Tables 4 and 5. 

Air Sampling 

USEPA Reference Method 25.A, using a Ratfisch 63A (serial # 0622092) flame ionization 

analyzer, was used to detennine concentration of styrene in the air stream. Air was taken from 

the centroid ofthe duct with a V* inch OD stainless steel probe connected to a 25 foot long 

Teflon® lined tube which was heated to approximately 50° C to prevent condensation. The 

Ratfisch analyzer was equipped with a pump which was adjusted to maintain a sample pressure 

of 2 psi to achieve constant sample flow. 

A certified reference gas containing 479 ppm styrene-in-air was used to prepare calibration 

standards on site with the use of an Environics 4040 gas diluter.- The diluter blended the certified 

reference gas with pure air to achieve intermediate levels of calibrated styrene-in-air blends. 

Calibration gases were transferred to a Tedlar® bag and introduced at the end ofthe umbilical 

tube to negate system bias. 

A copy ofthe certification of the reference gas is shown in Appendix C. 

Air Composition 

The composition ofthe air was determined in accordance to USEPA Method 3A,using a Nova 

Combustion Gas analyzer. The Nova analyzer was calibrated for C02 and CO using a reference 

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gas containing 50 ppm CO and 1.0% C02, and using ambient air outside the TTE as a reference 

for 20.9% oxygen. 

The moisture content ofthe air stream was measured in compliance with USEPA Reference 

Method 4 using the wet bulb/dry bulb method. The moisture content ofthe air inside the TTE 

was measured during each ofthe 1-hour tests, and recorded in the bound notebook shown in 

Appendix A. 

Corrections for the moisture, oxygen, and C02 content were incorporated in the calculations to 

detennine corrected flow rates. 

Data Collection 

Analyses were conducted in accordance to USEPA reference method 25 A, using a Ratfisch 

Model RS 63 CA (serial # 0622092) flame ionization analyzer. The stream was sampled and 

analyzed continuously. Data were recorded by a Grant Squirrel data logger, Model 1203. The 

Squinel meter takes a reading every 0.1 seconds, which are then averaged over a 10 second 

period, and then recorded at the end of each 10 second period. The data were then down-loaded 

and converted to Excel spreadsheet format Calculations were performed in the excel 

spreadsheet which may be found in Tables 1,2, and 3. 

Quality Assurance 

The Ratfisch analyzer was calibrated using styrene-in-air standard mixtures. The original

 v 

standard was certified to contain 479 ppm styrene by National Specialty gases. This standard 

was diluted to intermediate concentration levels using an Environics model 4040 NIST traceable 

diluter. Certification sheets for the calibration gas mixture may be found in Appendix C. The 

certification sheet for the diluter may be found in Appendix D. Styrene-in-air standard mixtures, 

as well as zero air, were placed in Tedlar® bags and introduced at the end ofthe umbilical tube 

to negate system bias. This was perfonned before and after each one hour run. 

Calculations 

Vapor Stream Flow Rates 

To compute volumetric flow rates at the ventilation duct, formulae from USEPA Methods 2,3,4 

and 5 were used: 

v

-=

K

-

c^i(S 

where: 

vs is the stack gas velocity (fl/sec) 

Kp is a pitot tube constant in English units (85.49 ft/sec) 

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Cp is the pitot tube coefficient (1.00 for the standard pitot tube used) 

Ap is the differential pressure taken at the pipe or duct of interest (inches of water 

column) 

Ts is the absolute temperature taken in the pipe or duct (°F+460) 

Ps is absolute pressure inside the pipe or duct (inches of Hg) 

Md = O.44O(%C02)+O32O(%02)+O28O(% tf2 +%CO) 

Bw = 

VFWXRH 

100 

where: 

Ms is the molecular weight ofthe vapor stream on a wet basis (lbs/lb-mole) 

Md is the molecular weight ofthe vapor stream on a dry basis (lbs/lb-mole) 

Bws is the proportion by volume ofthe water vapor in the gas stream 

VFW is the volume fraction of water at the measurement temperature if the air was 

saturated 

RH is the relative humidity 

Vntfstd)is m e tota l volume of gas extracted from the vapor stream on a dry basis (L) 

For example, the flow rate at the ventilation duct from data recorded at 14:00:01 hours on June 

10,1998 was calculated as follows: 

Mrf=0.440(0%CO2)+0320(20.7%C>2)+0280(793%^2+0%CO) = 28.8'%r.1,o;t 

M, = 28.8 *(l-0.0188)+l8.0 *0.0188 = 28.7'%,_Mofe 

0.0294*64% 

*- ioo—"° 018 8 

v, = 85.49*1.00*^0667 * . 

5355° R 

292inchesHgX2Wylla_nelt 

^ssym 

where: 

528°R is the standard temperature 

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535.5°R is the ambient temperature 

Converting vs (ft/sec) to dry standard cubic feet per hour (dscfihr) requires: 

Q,,* 3600(1-BjvtA^-£ £ 

* "

 V "*' * T, 29.92inchesHg 

... where: 

A is the cross-sectional area ofthe pipe or duct through which the vapor stream is flowing (ft2) 

Therefore the fully conected volumetric flow rate for the ventilation duct at the point in time 

noted above is: 

fiU =3600*(l-0.0188)*45.5y a e *0.49// 2*^|*^^^=76,100 ^ 

Note: Qsd in this example may be slightly different from that shown in the spreadsheet due to 

rounding. 

Ibsfhr VOC from On-Line Instruments 

Using volumetric flow rates such as the one computed above, the calculation of lbs/hr VOC from 

the ppm concentrations indicated by the on-line hydrocarbon analyzers was accomplished as: 

\

E

-

E

>)xm2 RF 

24.45 

= lbs 

453,59237*35314*360 

where: 

E is the voltage reading from the Squirrel data logger 

Eo is the voltage reading from the Squirrel data logger when zero gas was being passed 

through the Ratfisch hydrocarbon analyzer 

RF is a response factor derived from the voltage readings at known concentrations of styrene 

(volts/ppm) 

104.2 is the molecular weight of styrene 

24.45 is the molar volume of an ideal gas at standard pressure (29.92 inches Hg)and room 

temperature (528°R)(L/mole) 

453,59237 is the number of milligrams in a pound (mg/lb) 

35314 is the number of cubic feet in a cubic meter (ft?/m3) 

360 is the number of readings logged per hour by the Squirrel data logger (intervals/hour) 

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As an example, the amount of VOC flowing through the ventilation duct during the 10-second 

interval before 14:00:01 hours on June 10,1998 was calculated by: 

(9.42-(0.00) 

0.0510556 

*1042 

24.45 

*76,100 

453,59237*35314*360 

= 0.0\Q4lbsas Styrene 

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