p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

17) ll-B-12 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:10 AM Sheet 17 of 57 
F 

P.2 

46/Szr-c/e-oy 

TO: Project File 

Reinforced Plastic Composites NESHAP 

FROM: Melanie Proctor and Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: December 17,1996 

SUBJECT: Site Visit-Tecton Products, Fargo, ND 

EPA Contract 68D10116, ESD Project 93/58 

PES Project N404 

NON CBI SITE VISIT REPORTSV ^ ^Z^SS 6 'p|j ^ 

A-94-52 

1 1 B> | 1 

I. Purpose 

The purpose of this visit was to determine the ways in which pultrusion operations vary 

from one to another and if the new source MACT standard for pultrusion should be based on the 

emission control achieved by Tecton Products. The visit was also intended to provide a better 

understanding ofthe pultrusion process, the parameters that affect the technical feasibility of 

applying air emission controls, and the potential economic impact of those controls on pultrusion 

operations. 

II. Place and Date 

Tecton Products 

4401 15th Avenue, NW 

Post Office Box 2712 

Fargo, North Dakota 58108 

June 4 and 5, 1996 

III. Participants 

Tecton Products 

Mr. John Jambois, President 

Mr. Brad Kirby, Project Engineer 

Mr. Mitch Irmen, Production Controller/Safety Director 

Ms. Kathy Axtman, Purchasing Agent 
P.3 

Site Visit Report - Tecton Products 

Page 2 

U. S. EPA 

q Dr. Madeleine Strum, Project Manager 

North Dakota State Department of Health 

Mr. Gary Helbling, Environmental Engineer* 

Mr. Karl Corrigan, Environmental Engineer* 

PES 

Mr. Greg LaFlam, Environmental Engineer 

Ms. Melanie Proctor, Environmental Scientist 

* ND State employees participated on June 4 only. 

IV. General Facility Information 

Tecton Products began construction of its production facility in the summer of 1991. 

After construction was completed in the summer of 1992, Tecton obtained an operating pennit 

(permit number M93001) in August 1993 and began production. John Jambois pointed out that 

rumors of Tecton's prior existence and environmental problems in Minnesota are untrue. He 

stated that Tecton never existed in Minnesota or any other location. Tecton is a privately held 

company and does not provide annual reports to the public. 

The production area is 40,000 ft2. A total of 26 acres of land surrounding the operation 

can be used for further expansion. 

V. Description of Products 

Tecton currently produces approximately 15 different styles of window and door lineals 

via the pultrusion process. The windows and door lineals are painted and then assembled by 

Marvin Windows. Painting is a necessary step to produce a more weather resistant product. 

Tecton produces components for two distinct product lines, Marvin Windows and Integrity 

Windows. 

VI. Pultrusion Operations 

Tecton's current operating permit, which will expire in August of 1996, allows the 

facility to operate 5 pultrusion lines. The new operating permit will reflect the planned 

expansion and will be submitted to the State this summer. 

a 
P.4 

Site Visit Report - Tecton Products 

Page 3 

Tecton's permit allows them to emit 38 tons of HAP per year, which would make them a 

major source. Mr. Jambois did not provide the annual resin usage for its facility. Tecton uses 

filler in their product, but was not willing to share filler-resin ratios or any information pertaining 

to their resin matrix recipe. 

Each ofthe pultrusion lines at Tecton is equipped with a total enclosure which extends 

from the beginning ofthe resin bath to a point slightly beyond the die exit (about 6 inches). The 

infonnation about the emission control system is explained in more detail in section X. During 

the visit, it was verified that Tecton's process can be classified as a pultrusion process containing 

the typical emissions points of resin bath, drip, and die. The total length ofthe pultrusion 

process within each enclosure is approximately 16 feet. 

VII. Resin Storage and Mixing 

Resin is delivered by tanker trucks and pumped into storage tanks, which are located in a 

room that is vented to the thermal oxidizer. The resin storage room is temperature controlled and 

kept at 60° F. The mixing room is also temperature controlled and vented to the thermal 

oxidizer. 

VIII. Cleaners 

No HAP cleaners have ever been used at Tecton. The facility uses only acetone for 

cleanup operations. 

IX. Paint Booth 

The paint booth operates 24 hours per day, 7 days per week. Since VOC concentrations 

are high within the paint booth, workers wear respirators when painting. 

X. Emission Control Svstem 

Tecton's thermal oxidizer achieves an overall control efficiency of at least 95 percent on 

emissions from the pultrusion process, storage and mixing tanks, and painting. Tecton tested the 

control efficiency of its incinerator twice. The first test resulted in a 92.16 percent control 

efficiency, failing the State's requirement of 95 percent emission control. After changes were 

made, a second test indicated a destruction efficiency of 96.6 percent. No styrene odor can be 

detected on the roof of the production building where the stack ofthe incinerator is located. 

Tecton installed the incinerator because the State and the EPA Regional office in 

consultation with the Office of Air Quality Planning and Standards determined that Tecton is 

subject to the New Source Performance Standard (NSPS) for polymeric coating of supporting 

f 
P.5 

Site Visit Report - Tecton Products 

Page 4 

substrates (subpart VW). Mr. Jambois reviewed the NSPS and agreed that the standards were 

applicable to his operation. According to Mr. Jambois, the State of Wisconsin, which was 

originally considered as a possible location for Tecton, would not have required the incinerator. 

Despite the add-on control requirement, Mr. Jambois decided to locate the operation in North 

Dakota. 

The thermal oxidizer used at Tecton has about a 96 percent heat recovery. The minimum 

air flows from each emission point vented to the incinerator are listed in Attachment 1 (CBI). 

The inlet stream is preheated to 160 to 280° F and the outlet temperature measured in the stack is 

200° F. The location ofthe center bed ofthe incinerator shifts up and down due to changes in the 

flow direction (cycling) ofthe inlet stream. The average temperature of all measurement points 

in the incinerator is currently about 1,590° F. In order to maintain a minimum temperature of 

1,680° F at the outer corners ofthe center bed as required by the State, the temperature in the 

middle ofthe center bed reaches 1,890° F. The oxidizer remains operating with minimal 

amounts of natural gas even when no process emissions are vented to the incinerator. If the 

incinerator has to be shut down for any reason, it takes 3 to 4 days to get it back on line. The 

State has to be contacted when the oxidizer is off-line and records have to be kept to show that 

the 5 percent noncompliance hours allowed by the State are not exceeded. 

Even though Tecton currently vents emissions from its painting operation to the control 

device, the thermal oxidizer was not originally designed nor intended to control paint spray booth 

emissions. Tecton did not originally conduct painting operations at their facility, but decided to 

paint their own product to improve product quality. The oxidizer operated for 8 months before 

the spray booth existed. Tecton is planning to remove the paint spray booth exhaust from the 

oxidizer to provide more capacity for the planned expansion ofthe pultrusion operation and has 

discussed this issue with the State. The State does not require add-on controls for painting 

operations and does not object to the planned removal. 

Tecton's pultrusion emissions are captured in permanent total enclosures, which are 

vented to the incinerator. The enclosures at Tecton meet the EPA criteria for 100 percent 

capture. Each pultrusion machine has a separate enclosure constructed out of metal with 

windows for continuous viewing of the process. The air flow in the enclosures is monitored and 

set to achieve a face velocity 10 percent above the minimum requirement of 200 feet per minute 

along any natural draft opening to maintain negative pressure in the enclosures. 

The enclosures were constructed to provide a better working environment. During the 

visit, only a very slight styrene odor could be detected outside the enclosures where employees 

are working. Occasionally, an employee needs to enter the enclosure to make corrections to the 

process. Mr. Kirby explained that the HAP emissions in the enclosure are stratified with higher 

concentrations at the pick up points. He did not think that the HAP concentration in the 

breathing zone ofthe enclosure exceeded 50 ppm. Tecton does not consider the enclosures 

detrimental to its operation. 

I 
P.6 

-ii.' -_» 

Site Visit Report - Tecton Products 

Page 5 

XI. Cost Information 

Based on information provided by Mr. Jambois, control costs are a minor part of Tecton's 

expenses and Tecton is a profitable operation even with the add-on control system in place. 

The participants discussed PES's independent estimation of Tecton's capital cost, annual 

costs, and the cost per ton of HAP controlled so that EPA could validate the control cost 

spreadsheets developed to estimate cost impacts on other facilities that might have to use add-ons 

in the future. PES calculated a control cost of $5,000 per ton of styrene removed based on permit 

information, which assumes five pultrusion machines and does not include painting operations. 

Costs provided by Tecton and calculated by PES were within 20 percent of each other. 

XII. Final Questions and Action Items for Tecton: 

• Provide MSDS for resins 

• Provide a sample copy ofa compliance reporting sheet 

• Provide maximum monthly resin usage (all machines operating) 

6