p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

148) ll-E-108 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:08 AM Sheet 148 of 264 
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"fr •A-94-52 

H E 

TO: 

FROM: 

DATE: 

MEMORANDUM 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

/ 

Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

November 12, 1997 

SUBJECT: Minutes of October 27, 1997 Meeting Between EPA and Representatives of the 

Pultrusion Industry Council 

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

10:00 am -12:00 am 

ATTENDEES: 

*?£ • 

M-'d 

Mr. John Barker 

Mr. James Gauchel 

Mr. Tom Griffiths 

Mr. Robert Jemison 

Mr. Terry McQuarrie 

Ms. Jan Meyer 

Ms. Melanie Proctor 

Mr. John Schweitzer 

Ms. Madeleine Strum 

Mr. Solomon Ricks 

Strongwell 

Owens Corning 

Omega Pultrusions 

PES 

Glasforms, Inc. 

EPA/ESD/CCPG 

PES 

Composites Institute of the Society 

ofthe Plastics Industry (SPI) 

EPA/ESD/CCPG 

EPA/SCGA 

(540) 645-8129 

(614) 321-7724 

(330) 562-5201 

(919) 941-0333 

(408) 297-9300 

(919) 541-5254 

(919) 941-0333 

(313) 668-4703 

(919) 541-2383 

(919) 541-5242 

PURPOSE 

The Pultrusion Industry Council (PIC) requested a meeting with the EPA to present 

their approach for the existing source MACT for pultrusion. The purpose of the meeting was 

to review and discuss industry's proposed approach for pultrusion. 

i / 
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Madeleine Strum 

November 12, 1997 

Page 2 

INTRODUCTION 

Mr. Schweitzer started the meeting by stating that several members of the PIC have 

contacted the EPA in the past weeks to discuss the MACT compliance options for the 

pultrusion process grouping. Mr. Schweitzer proceeded by saying that this meeting will be a 

continuation of these discussions. Mr. Schweitzer stated that the PIC is proposing the 

following three compliance options that a facility can choose to comply with the MACT 

standard for pultrusion: (1) A resin HAP content limit, (2) an equipment standard including 

the construction of wet area enclosures or the use of direct die injection machines, and (3) an 

emission limit that involves emission testing, the construction of permanent total enclosures, 

and continuous emission monitoring. Mr. Schweitzer explained that PIC representatives were 

prepared to share their ideas for options one and two with the EPA but that the representatives 

who wanted to present option three were unable to attend this meeting due to bad weather 

conditions. Mr. Schweitzer added that the key representatives who were interested in option 

three, Dave Evans who represents Creative Pultrusions and representatives of R. D. Werner, 

might contact the EPA at a later date to discuss the third option. 

DISCUSSION 

Mr. Schweitzer stated that industry representatives agreed that the HAP limit option 

that the EPA previously considered presents a workable compliance option for some pultrusion 

facilities and should therefore be part of the MACT compliance options for pultrusion. In 

referring to Attachment 1, Mr. Schweitzer proceeded by providing details of the resin HAP 

content option, which would limit the rolling annual average resin HAP content to 35 percent 

and would allow compliance by partial or complete replacement of resins with reduced and/or 

no HAP content resins (i.e., epoxy resins). 

Ms. Strum inquired how industry representatives determined a resin HAP content limit 

of 35 percent. Mr. Schweitzer responded that the resin HAP content limit of 35 percent was 

taken from an earlier EPA MACT floor analysis that was based on resin HAP content. Ms. 

Proctor pointed out that the resin HAP content information in the MACT database is based to 

a large extent on 1993 screening survey information and this information would have to be 

verified and updated, which may change the MACT floor resin HAP content, especially if 

epoxy resin usage would now be considered in determining the MACT floor. 

Mr. McQuarrie pointed out their San Jose facility replaced 25 to 30 percent of their 

styrenated resins with epoxy resins which reduced their weighted average resin HAP content 

from 46 to 31 percent. Mr. McQuarrie added that he knew of one other facility that uses 100 

percent epoxy resins for their pultrusion operation. Mr. Gauchel pointed out that this facility 

(AP Chance) has always used 100 percent epoxy resins. 

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Madeleine Strum 

November 12, 1997 

Page 3 

Ms. Strum pointed out that she thought Glastic Corporation was also using some epoxy 

resins in their pultrusion operation. Ms. Strum added that Glastic Corporation would have to 

be contacted to determine to which extent they are using epoxy resins. 

Ms. Strum indicated that if facilities would be allowed to comply by replacing HAP 

containing resins with low or no HAP containing resins, the MACT floor analysis would have 

to include facilities that use low or no HAP containing resins. Ms. Meyer agreed that the 

basis for compliance and the MACT floor determination would have to be the same. Ms. 

Meyer indicated that the Office of General Council may have to get involved to help determine 

if companies that substituted materials should be in the source category. 

Mr. McQuarrie explained that facilities that were using epoxy resins exclusively should 

not be considered in the MACT floor analysis. He added that facilities in the Bay Area Air 

Quality Management District, are exempt from the standard if they only use epoxy resins. 

According to Mr. McQuarrie facilities that use only epoxy resins should not be included in the 

MACT floor analysis because if they do not emit any HAP, they would not be considered a 

major source. Ms. Strum pointed out that facilities that use only epoxy resins may still have 

to be considered in the MACT floor analysis due to their potential to emit. Ms. Strum added 

that it would be difficult to consider a facility that replaced some of its polyester resin with 

epoxy resin but not to consider a facility that replaced all of its polyester resin with epoxy 

resin. 

Ms. Proctor asked if there are any limitations for switching from polyester to epoxy 

resins. Mr. McQuarrie replied that it can be very difficult for a facility to switch to epoxy 

resins because epoxy resins are more adhesive than polyester resins and the line speed would 

have to be reduced by half. Mr. McQuarrie also indicated that epoxy resins are comparable in 

price to vinyl ester resins and more expensive than polyester resins. Mr. Gauchel added that 

epoxy and polyester resins are different on the molecular level. He added that the reaction 

time for epoxy resins is much lower than for polyester resins for the same product 

specifications. Mr. Griffiths explained that some products cannot be produced with epoxy 

resins and that equipment changes may be required for the products that can be produced with 

epoxy resins because an increased pulling force is needed to process epoxy resins. 

Ms. Strum inquired if Glasforms, Inc. was required by the permitting agency to reduce 

their emissions and if the company replaced some of their polyester resins with epoxy resins in 

response to that requirement. Mr. McQuarrie responded that the permits for their San Jose 

and their Birmingham plants were based on wet area enclosures and that the motivation for 

switching to epoxy resins was to improve product quality and to reduce the facility's HAP 

emissions. Mr. McQuarrie added that their San Jose and Birmingham plants were identical in 

their operation with the exception that the San Jose plant replaced some of their polyester 

resins with epoxy resins whereas their Birmingham plant uses only polyester resins. Mr. 
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Madeleine Strum 

November 12, 1997 

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McQuarrie further explained that the wet area enclosures in their San Jose plant are on both 

their epoxy and polyester resin pultrusion lines since the lines are not designated for a 

particular resin. 

Ms. Strum inquired if the EPA and industry could work together to update the MACT 

database. Mr. Gauchel replied that a PIC meeting was scheduled this week and that they could 

request their members to submit updated weighted average resin HAP content information. 

Mr. Gauchel added that the request for updated data to their members could even be followed 

up with a letter. 

Mr. McQuarrie continued the industry presentation by presenting the second proposed 

MACT compliance option for pultrusion, which consists of an equipment standard. In 

referring to Attachment 2, Mr. McQuarrie proceeded by providing details of the equipment 

standard option, which would allow facilities to comply by constructing wet area enclosures 

around their pultrusion lines. Mr. McQuarrie summarized the information that is presented in 

greater detail in Attachment 2, which covered the following areas: (1) Wet area enclosure 

definition, (2) emission test data from the San Jose Glasforms, Inc. facility that demonstrates 

the effectiveness of the wet area enclosure, (3) air quality management district approvals, and 

(4) enforcement. Mr. McQuarrie indicated that wet area enclosures are currently being used 

by both Glasforms, Inc., facilities and by Structron, which is located in Sari Diego, California. 

Mr. McQuarrie concluded his presentation by stating that wet area enclosures are an accepted 

control technology for pultrusion by the Bay Area Air Quality Management District, the 

Department of Health in Jefferson County, Alabama, and the Air Pollution Control District 

County of San Diego, California. 

Ms. Proctor asked whether the line speeds at which the emission tests were conducted 

at the San Jose facility were representative of the line speeds at the other two facilities that 

were using the emission factor determined in the San Jose emission tests. Mr. McQuarrie 

responded that he believed that the line speed at the San Jose facility is representative of the 

line speeds at the other two facilities because the products produced at these facilities are 

similar. 

Ms. Strum asked if any of the information contained in Attachment 2 would be 

considered confidential business information by Glasforms, Inc. Mr. McQuarrie indicated that 

this information is already available to the public through the Bay Area Air Quality 

Management District and is not considered confidential. 

Ms. Strum requested the industry representatives to better describe the criteria for the 

wet area enclosure and to develop a check list that could be used both in the rule and by an 

inspector to determine compliance. Ms. Strum added that all clearances and openings would 

have to be defined and more detail would have to incorporated into the definition of how the 

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Madeleine Strum 

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resin drip is collected. Ms. Proctor added that vague wording in the current definition, such 

as "... .they are designed to fit", would have to be better defined. Ms. Meyer agreed and 

added that "designed to fit" does not necessarily require that it fits in practice. Mr. Griffiths 

and Mr. McQuarrie volunteered to improve the definition and provide it to the EPA within 

one week. 

Mr. Schweitzer pointed out that the second part of the proposed equipment standard is 

direct die injection. Ms. Strum indicated that industry also needs to provide a definition for 

direct die injection that quantifies the maximum amount of drip allowed. Mr. Gauchel 

explained that their facility uses direct die injection on a daily basis, but based on his 

observations, the amount of drip varies and depends on the product they are producing. 

Mr. Gauchel asked if facilities would be allowed to average emissions from open bath 

and direct die operations. Ms. Strum pointed out that if direct die injection would be 

considered as part ofthe equipment standard, averaging between resin processed by direct die 

injection and open bath pultruders would not be allowed. Ms. Strum added that, in the case of 

an equipment standard, the portion of the operation that uses direct die injection would be 

considered to be in compliance without being able to claim an emission credit for that part of 

the operation. Ms. Strum further explained that if a performance standard would be set in 

terms of pounds of emissions per ton of resin used, averaging could be allowed. Ms. Strum 

stated that the level of detail required to define direct die injection would be considerably less 

for an equipment standard where averaging would not be allowed as compared to a 

performance standard that would allow averaging. 

Mr. Schweitzer briefly addressed the third proposed MACT compliance option for 

pultrusion, which consists of an emission limit and involves one time emission testing, the 

construction of permanent total enclosures, and continuous emission monitoring. Ms. Strum 

pointed out that in the case of a one time emission test the worst case condition would have to 

be defined and tested to show compliance with the emission limit and records of the process 

parameters would have to be kept of each run. Mr. Gauchel stated that the worst case 

condition would be different for each individual company and may be difficult to predict in 

some cases. Mr. Gauchel also pointed out that most companies already keep all the necessary 

production parameter data except perhaps for air flow data. 

Industry representatives asked whether they would have to make any revisions with 

regard to the resin HAP content compliance option. Ms. Strum indicated that the resin HAP 

content limit would have to be expressed on a percent by weight basis and that the resin should 

be referred to as neat resin plus any HAP added. 

Ms. Strum also voiced the concern that the proposed compliance options one and two 

may not be equal in the emission reduction they would achieve. Ms. Strum stated that if a 

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Madeleine Strum 

November 12, 1997 

Page 6 

facility would comply by using the resin HAP content compliance option, the emissions of that 

facility could vary depending on the other process parameters (i.e., air flow) and thus the 

emission reduction achieved by that facility may not be equivalent to a facility that would use 

wet area enclosures. 

Ms. Proctor suggested to first update the MACT database to incorporate data from 

facilities that constructed wet area enclosures and that replaced HAP containing resins with 

reduced or no HAP containing resins and then to redetermine the MACT floor. Ms. Proctor 

noted the once the MACT database would be updated, the MACT floor would probably be 

more stringent than the one that was previously determined. Ms. Proctor added mat once the 

MACT floor has been determined, each proposed option should at minimum meet the MACT 

floor. 

Ms. Strum pointed out that one way to demonstrate that each compliance option meets 

at least the MACT floor would be to set an emission limit in terms of pounds of HAP 

emissions per ton of resin processed, and require each facility to demonstrate that they meet 

that emission limit. Mr. Griffiths indicated that a performance standard expressed in pounds 

of HAP emissions per ton of resin used would be preferable to this diverse industry since it 

would allow the maximum amount of flexibility in complying with the standard. 

Action items fw Industry Representatives; 

1. Provide EPA with a more detailed definition for the wet area enclosure in form of a 

check list. 

2. Provide EPA with a definition for direct die injection. 

3. Request updated weighted average resin HAP content data including the use of nonHAP containing resins (i.e., epoxy resins) from PIC members and forward data to 

EPA. 

4. Attempt to locate "quality" emission data that shows a complete list of the process 

parameters during the emission test and, if available, forward that data to EPA. 

Action Items for EPA: 

1. EPA will explore the inclusion of epoxy resins as a compliance option for the standard. 

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Pultrusion MACT - HAP content option 

The source shall use resins with a total HAP content of no more than 35%. 

This provision may be complied with by partial or complete replacement of 

resins with reduced and/or no HAP content; i.e., epoxy resins, alternative 

monomers, etc. 

Compliance with this provision shall be demonstrated on a rolling annual 

average basis. At the end of each month, total HAP monomers used divided 

by total resin used, for the previous 12 months, may not exceed 0.35 (35%). 

Also at the end of each month, the total HAP monomers used divided by total 

resin used, for the previous 3 months, may not exceed 0.46 (0.35 x 1.3). (This 

provision is taken from the HON.) 

Definitions 

Total HAP monomers used = all HAP monomers processed, including HAP 

monomers blended with resin as received, and HAP monomers added by the 

source. 

Total resin used = all thermoset resins processed, including HAP monomers 

blended with the resin as received and added by the source. 

!«|i?(»"-

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Docket No. K-ff- S 2L 

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Wot area endofiures(resln bath covers) shall be designed to prevent the contact of 

free-flcrwing air wftb wet resin in order to teduce oiganie compound emtaeioee. The 

enclosure shaU bo designed to oover the top, bottom, and ttie aides of the area In which 

ceoiforoements are wet out, and are mowing toward Ihe d)e(a). The encfosvie shall be 

fitted to the die entrance or radio frequency (RF) preheat unit; thus the enclosure 

cover* aD aides except the entrance. The entrance aUows reinforcements) to enter the 

en-etaeure. Access panels, doors, hatches, or textile curtains ahall be considered part 

of 1he enclosure provided that they are designed to IIL Porta for level confrol devices, 

monitoring dovicea. agitation shafts, fill hoses, etc., ehai have no more than 1.0" 

clearance. 

Resin drip off at the die entrance shaU be allowed, but must be collected in a device 

that is covered and has no more dran 1.0* clearance around the drip off. 

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