p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

40) IV-C-13 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 40 of 273 
P.2 

A-94-52 

IV-C-13 

REINFORCED PLASTIC 

COMPOSITES 

MACT STANDARDS 

DEVELOPMENT UPDATE 

February 1,2002 -_. J 

• EPA AIR DOCKET 

Keith Barnett, Project Lead 

Office of Air Quality Planning and Standards 

Emission Standards Division 

Organic Chemicals Group 
P.3 

Outline 

Who is subject to this standard? 

When do I have to comply? 

Am I a new or existing source? 

What standards must I meet? 

What are some of my options to meet 

standards? 

How do I demonstrate compliance? 

How do I achieve 95 percent control 

(if required)? 
P.4 

Who is subject to this standard? 

A reinforced plastics composites 

production facility that is located at a 

major source (10 tpy ofany one HAP or 25 

tpy ofany combination of HAP): and 

Uses thermoset resins or gel coats that 

contain styrene and/or methyl methacrylate 
P.5 

What operations are covered? 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination/Casting 

SMC/BMC Manufacturing 

Pultrusion 

Mixing 

Storage 

Equipment Cleaning 
P.6 

When do I have to comply? 

Proposal was August 2, 2001 

Final rule about a year after proposal 

Existing major sources must comply within 

3 years from final rule 

New major sources must comply by 

effective date of final rule or startup, 

whichever is later 
P.7 

Rule Status and Planned Changes 

• The major change since proposal is to 

replace the point value equations with 

appropriate unified emission factor (UEF) 

equations. 

• This change does not change the "floor" 

facility except for two process product 

groupings 

• For the two that change, the floor facility 

only shifts by one, so the change is not 

substantive 

• The allowable HAP contents based on 

UEF are higher than at proposal when 

nonatomized application spray is used 
P.8 

Rule Status and Planned Changes 

(Con't) 

• Most ofthe current effort is reviewing the 

control costs for the above the floor option 

• We anticipate that we will have revised 

costs by Spring or Summer 

• We intend to make these revised costs 

available to the Composites Fabricators 

Association, or any other interested parties 

• We also will further investigate the issue of 

the tooling gel coats floors, which industry 

claims is to stringent 

• We will update any errors that are brought 

to our attention in the floor data base. 
P.9 

What is a new Source? 

You commence construction after 

August 2,2001; and 

When you commence construction, there 

are no reinforced plastic composites 

operations at the facility 

8 
P.10 

What is an Existing Source? 

Any source that is not new 

Existing sources are not considered new as 

a result of reconstruction 
p.11 

Overview of Controls to Meet 

Proposed Emission Limits 

Sources below a specified HAP emissions 

threshold 

- low HAP resins and gel coats 

- nonatomized application techniques 

- covering open containers, mixers, resin baths 

- add-on controls for Continuous lamination 

Sources above a specified HAP emission 

threshold must control the operations 

below by 95 percent 

- OpenMolding 

- Centrifugal Casting 

- Continuous Lamination/Casting 

- Pultrusion 

y 

- SMC/BMC Manufacturing 

- Mixing 

10 
P.12 

How Is the HAP Threshold 

Determined? 

Sum emissions from the all operations 

potentially subject to 95 percent control 

Calculate these emissions using 

- unified emission factors for reinforced 

plastic composites 

- facility specific emission factors 

- Results from emission tests 

n 
P.13 

What Are the Threshold Levels? 

New sources -100 tpy actual HAP 

emissions 

Existing sources - actual emissions 

- 250 tpy if small business 

- 100 tpy if nonsmall business 

Small business means less than 500 

employees for most SIC Codes 

12 
P.14 

Proposed MACT for Sources below 

Thresholds 

(Note that the these numbers are now based on UEF) 

Operation 

Type 

Open 

Molding -

Corrosion 

resistant 

Open 

Molding -

NonCorrosion 

Resistant 

Specific 

Operation 

Mechanical resin 

Application 

Filament Winding 

Manual Resin 

Application 

Mechanical resin 

Application 

Mechanical resin 

Application 

Filament Winding 

Manual resin 

Application 

Floor 

UEF 

159 

171 

123 

126 

86 

188 

87 

Allowable 

Resin HAP 

Content 

50+ NonAtomized 

36.3 

Atomized 

42 

40 

50+ NonAtomized 

34 Atomized 

37.9 NonAtomized 

31.2 

Atomized 

45 

33.6 

13 
P.15 

Proposed MACT for Sources below 

Thresholds(Con't) 

Operation 

Type 

Open 

Molding -

Tooling 

Open 

Molding -

Products that 

require Class 

1 Fire and 

Smoke 

Ratings 

Centrifugal 

Casting 

Specific 

Operation 

Mechanical 

Resin 

Application -

Tooling 

Manual Resin 

Application -

Tooling 

Mechanical 

resin 

Application 

Filament 

Winding 

Manual Resin 

Application 

Non CR 

CR 

Floor 

UEF 

254 

122 

497 

270 

237 

396 

536 

Allowable 

HAP Content 

(Weight %) 

50+ Nonatomized 

43 Atomized 

39.9 

60 

60 

60 

35.5 

48 

14 
P.16 

Proposed MACT for Sources below 

Thresholds(Con't) 

Operation 

Type 

Open 

Molding -

Gel Coat 

Specific 

Operation 

Tooling Gel 

Coating 

Pigmented 

Gel Coating 

- White and 

Off White 

Pigmented 

Gel Coating -

NonWhite 

Clear 

Production 

Gel Coat 

Point Value 

(Ib/ton) 

398 

267 

377 

522 

Allowable 

HAP Content 

(Weight %) 

38 

31.7 

37 

44 

15 
P.17. 

Proposed MACT for Sources below 

Thresholds (Con't) 

Injection/Compression Molding - Cover 

Charges 

Resin Transfer Molding - No 

Requirements 

Continuous Lamination and Casting - 58.5 

percent control 

Polymer Casting - No Requirements 

16 
P.18 

Proposed MACT for Sources below 

Thresholds (Con't) 

• Pultrusion - 60 percent control or wet area 

enclosure 

• Sheet Molding Compound - Nylon film, 

fold or seal edges, cover doctor box 

• Equipment Cleaning - Cleaning materials 

may contain no HAP 

• Resin Mixing and BMC Manufacturing -

Cover the mixers 

• Resin Storage - Cover storage containers 

17 
P.19 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 1 

Change all your resins and gel coats to 

ones with HAP contents below the 

standard 

This is the simplest method and results in 

the least reporting and record keeping 

18 
P.20 

Meeting P2 Standards 

Option 1 Example 

Prior to MACT 

- Atomized application of 45 percent 

HAP noncorrosion resistant filled resin 

- Atomized application of a 35 percent 

HAP white gel coat 

After MACT 

- Nonatomized application of 45 percent 

HAP noncorrosion resistant filled resin 

- Atomized application of 31 percent 

HAP white gel coat 

19 
P.21 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 2 

Change your resins and gel coats so the 

weighted average meets MACT 

Requires purchase records by resin type, 

and monthly average calculation 

Average is based on last 12 months of 

operation 

20 

/ • / / -
P.22 

Meeting P2 Standards 

Option 2 Example 

Prior to MACT 

- Currently use two noncorrosion 

resistant unfilled resins, one 37 percent 

HAP and one 42 percent HAP 

- nonatomized mechanical application 

- ratio ofresin use is 60/40 

after MACT (Floor = 86) 

- convert 42 percent HAP resin to less 

than 39.25 percent HAP 

- maintain same 60/40 split 

21 
P.23 

Meeting P2 Standards 

Open Molding and Centrifugal 

Casting Option 

Determine the highest resin HAP content 

allowable for each operation 

Use this resin for all operations 

Can not include gel coats or mix corrosion 

and noncorrosion resistant operations 

22 
P.24 

Meeting P2 Standards 

Option 3 Example Prior to MACT 

making corrosion resistant tanks 

using atomized mechanical (end caps), 

filament winding (body), and manual 

application (joining parts) 

using 50 percent HAP resin 

23 
P.25 

Meeting P2 Standards 

Option 3 Example After MACT 

Determine MACT for each operation 

- Mechanical is 50+ percent HAP resin 

nonatomized application 

- Filament winding is 42 percent HAP 

resin 

- Manual is 40 percent HAP resin 

Select highest allowable HAP level (50+ 

percent) 

Use this resin in all applications 

24 
P.26 

Options for Meeting Standards 

Pultrusion 

Wet area enclosures to meet the 60 percent 

reduction requirement 

Direct die injection to meet the 60 and 95 

percent reduction requirements 

Add-on controls 

We are strongly considering allowing 

averaging of pultrusion lines 

25 

LS^ 
P.27 

Options for Meeting Standards 

Continuous Lamination/Casting 

Can average lines 

Existing sources can elect to control only 

wet out area emissions by 95 percent 

Can meet an alternative emission limit of 

14.7 lb/ton (58.5 percent control level) or 

1.47 lb/ton (95 percent control level) 

26 
P.28 

How do I Calculate UEF 

The equivalent UEF equation will replace 

the corresponding point value equation in 

the final rule 

Resin use may be based on purchase 

records 

Resin HAP content may be based on 

MSDS or resin specification sheets 

If averaging, you must determine the 

amounts of resin used for each specific 

operation 

27 
P.29 

Example UEF Calculation 

Open molding - mechanical resin 

application - non atomized - filled -

noncorrosion resistant 

- Resin HAP content (from MSDS) is 36 

percent 

- UEF equation is 

• UEF = ((0.157)(%styrene)-.0165) x 

2000 

• UEF = ((0.157)(0.36)-.0165) x 2000 

• UEF = 80 

- Proposed MACT Floor is 126 

- This meets MACT 

Do not consider catalysts or promoters 

Do consider any additional monomer 

addition 

28 
P.30 

How do I demonstrate Initial 

Compliance 

For UEF emission limits - perform UEF 

calculations as specified in the rule 

For work practice standards - submit a 

certified statement that the work practice is 

being performed 

For equipment standards - submit a 

certified statement that the equipment is in 

place and meet the requirements specified 

in the rule 

29 

9 i) 
P.31 

How do I achieve 95 percent control 

(if required) 

• Enclose operations requiring 95 percent 

control with a permanent total enclosure 

• Design and operate enclosure in 

accordance with EPA Method 204 

• Install and operate a 95 percent efficient 

control device 

- Concentrator/oxidizer 

- Thermal oxidizer 

- Catalytic oxidizer 

30 
P.32 

What are the Method 204 PTE 

Requirements 

All natural draft openings (NDO) at least 

four diameters from the nearest HAP 

emitting point 

> All exhaust points at least four diameters 

from the nearest NDO 

All NDO not to exceed 5 percent ofthe 

enclosure's surface area 

The average NDO facial velocity is at least 

200 fpm 

31 
P.33 

What are the Method 204 PTE 

Requirements (Con't) 

The direction of airflow in all NDO shall 

be inward 

All PTE exhausts must discharge through a 

control device 

NDO area may be reduced by plastic strips 

or air curtains 

32 
P.34 

How do I Demonstrate Initial 

Compliance For Add-on Controls 

Perform a compliance test prior to the 

compliance date 

Performance tests methods are EPA 

Method 18, 25, 25A 

The PTE must be certified using EPA 

Method 204 

Ifthe PTE does not meet 204 criteria, you 

must test for capture using EPA Methods 

204B-204E 

33 
P.35 

How Do I Demonstrate Initial 

Compliance for a PTE 

Determine the equivalent diameters of all 

NDO and exhausts 

Determine the equivalent diameters of all 

NDO from HAP emission points and 

exhausts from NDO (must be at least four) 

Measure PTE surface area (AT) and NDO 

surface area (AN). The ratio of AT/AN 

must 0.05 or less. 

34 
P.36 

How Do I Demonstrate Initial 

Compliance for a PTE (Con't) 

- Measure all exhaust flows (Q0) and all 

forced makeup air flows (Qj) using 

EPA Method 2. 

- Calculate the average NDO facial 

velocity as FV= (Q0 - Q^/AN 

- FV must be 200 fpm or more; or 

- measure pressure differential across 

enclosure 

- differential must be 0.007 inches of 

water or more 

35 
P.37 

How Do I Demonstrate Initial 

Compliance for a PTE (Con't) 

Verify direction of flow is inward for 

all NDO using streamers, smoke tubes, 

or tracer gases 

If FV is 500 or more, inward flow 

verification is not required 

36