p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

46) II-C-16 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:52:01 AM Sheet 46 of 56 
P.2 

^ t ° sr« 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

OFFICE Of 

ilkn O O IOOC AIR QUALITY PLANNING 

WaU Cal lyyO ANDSTANDAROS 

REINFORCED PLASTIC COMPOSITES NESHAP PRE-MACT TEAM MEMBERS 

Dear Team and/or Work Group Member: 

This is to update you on the new industry and environmental 

participants, and provide you with a "blueprint" which describes the 

path for development of Presumptive .MACT. 

John Schweitzer, Technical Director, Composites Institute of the 

Society of Plastics Industry and Steve McNally, Director of Government 

Affairs for the Composites Fabricators Association are the 'industry 

members on the team. They are planning to arrange educational visits to 

reinforced plastic composites plants during April or May for those 

interested. These visits would be within driving distance anp John or 

Steve will contact you about them in the near future. Ben £amar has 

joined the team as a representative of the Sierra Club (Lone Star 

Chapter) . We are also trying to get an environmental representative in 

the South Coast Air Quality Management District. 

The enclosed blueprint outlines a number of tasks for specific 

groups of team members and includes an updated team member address/phone 

list. It would be helpful for you to contact the others in your group 

to prepare for subsequent pre-MACT meetings. 

We are preparing for a Pre-MACT teleconference in May or June 

whereby vendors will be available to make short presentations on 

different "add-on" technologies to reduce styrene emissions. To help us 

choose an optimum date and time for the meeting please call Greg LaFlam 

of Pacific Environmental Services at (919) 941-0333 at your earliest 

convenience to inform him of your availability between May 22, 1995 and 

June 7, 19 95. 

If you have any questions on the enclosed information, please 

contact Ellen Ducey at (919) 541-5408. While I am away for maternity 

leave, Ellen Ducey will be the lead for the project. 

aw-r- . 

p*"Wr-"!r,»'M 

B B i 

s ' I ^ . • .:. . • . 

;i.'. . • i •

 ;-

Sincerely, 

^ K.,n^-^ w r 

il}M:'"

 : "'" """""•'"' I'l Madeleine Strum, Ph.D. 

' ^' i-|!j5 Environmental Engineer 

'/; Coatings and Consumer Products Group 

i 

Enclosure 
P.3 

ADDRESSEES: 

Mohan Balagopalan, SCAQMD 

3ob Burmark, Washington State 

Leonardo Ceron, Region IV 

Lisa Conner, OAQPS/AQSSD (MD-15) 

Laurel Driver, OAQPS/AQSSD (MD-15) 

Ellen Ducey, OAQPS/ESD (MD-13) 

Patricia Embrey, OGC (2344) 

Bob Fegley, ORD (8105) 

Chuck French, OAQPS/AQSSD (MD-15) 

Robert Goulish, Ohio EPA 

Linda Herring, EPA/ESD (MD-13) 

Bruce Jordan, OAQPS/ESD (MD-13) 

No.rm Kaplan, EPA/ORD (MD-61) 

Karen Levy, 'OPAR (6103) 

Maria Maiave, OECA (2223A) 

Haile Mariam, OSW (5302W) 

Craig Matthiessen, OSWER (5101) 

t

teve McNally, Composites Fabricators /Association 

ichard Nielson, Clark County Health District 

Carlos Nunez, ORD (MD-61) 

Ben Pamar, Sierra Club 

Solomon Ricks, OAQPS/EMAD (MD-19) 

Dob Rooc> OSDBU (1230-C) 

Ron Ryan, OAQPS/EMAD (MD-14) 

John Schweitzer, Society of Plastics Industry, Composites Institute 

Jordan Spooner OPPT/PPD (7409) 

Jeri Weiss, Region I 

% 
P.4 

DRAFT DOCUMENT - March 9. 1995 

Madeleine Strum (919) S41 2383 

ANALYTIC BLUEPRINT FOR THE REINFORCED PLASTIC COMPOSITE NESHAP 

Statutory Authority: Section 112 of the Clean Air Act mandates EPA 

to develop standards based on maximum achievable control technology 

(MACT) for major source categories of hazardous air pollutants. 

EPA listed reinforced plastic composites production as a major 

source category for which standards are due in 1997. 

Legislative Deadline: November 15, 1997. 

Court Orders/Other Deadlines: Presently no court-ordered deadline. 

I BACKGROUND 

This industry manufactures a huge variety of products traversing 

such market segments as transportation, construction, 

business/appliance, consumer products, marine and aerospace. We 

identified nearly 1000 facilities from the 1991 Toxic Release 

Inventory System in over 50 different SIC codes. The source 

category specifically excludes boat building. The facilities in 

this source category manufacture such diverse products as autobody 

parts, skis, lunch trays, bathtubs, electronic wiring boards and 

storage tanks. A variety of manufacturing processes are used. 

The main HAP emitted from the industry is styrene, which is a 

monomer contained in one of the main materials - unsaturated 

polyester resin. While much of the styrene present in the resin 

reacts and remains bound in the product, some of it evaporates into 

the air during the mixing of the resin, application of the resin, 

and curing. Methyl methacrylate is another HAP used as a monomer 

(like styrene) , but it is used in much lesser quantities. The most 

predominant organic cleaning solvents used are acetone and dibasic 

esters, which are not HAP's. Methylene chloride (a HAP) is used to 

a lesser extent in cleaning, but many plants are phasing it out. 

We investigated State and local rules for this industry, and found 

only one local program (South Coast Air Quality Management District 

(SCAQMD] in California) that has a technology based regulation 

aimed at reducing VOC (styrene is a VOC) . One of the requirements 

SCAQMD regulation 1162 limits the styrene concentration in general 

•purpose polyester resins (except for pultrusion operations or for 

closed-mold systems) to 35% by weight (or requires, when a vapor 

suppressed resin is used, that the weight loss from VOC emissions 

shall not exceed 60 grams per square meter of exposed surface area 

during resin polymerization). Because many industries use resins 

mixed with a filler (effectually reducing the styrene concentration 

to as little as 20% or less), this limitation has no effect on a 

large number of sources. The SCAQMD regulation also requires more 

/ 

2> 
P.5 

DRAFT DOCUMENT - March 9, 1995 

Madeleine Stmm (919) .541 2383 

efficient spray technology. Several states may be looking into 

adopting the SCAQMD regulation, which is supported by the major 

trade associations. We expect more States will be developing 

technology-based regulations, as styrene. has a low odor threshold 

which gives it public attention. Also, the industry appears to be 

growing. 

Bob Burmark, our Washington State team member, informed me that the 

Puget Sound Air Pollution Control Agency (local Agency in 

Washington State) also has a regulation for fiberglass reinforced 

plastics which requires facilities to use an enclosed, vented spray 

area and •'sets spray gun specifications and sets controls on 

volatile clean-up solvents. It does not address resin VOC content. 

Aside from a handful abatement devices (mostly incinerators) found 

at plants whose neighbors have protested (styrene has an extremely 

low odor threshold) or found at plants in nonattainment areas, we 

postulate that the vast majority of plants in the industry are 

uncontrolled. We have indication from control device suppliers 

that the technology for styrene abatement has improved over the 

last few years, making abatement a more cost-effective solution. 

Listed below are some pollution prevention technologies. The 

efficiency of most has not been well established (one goal of the 

ORD pollution prevention project with industry is to get a measure 

of emission reduction) and some are limited in applicability. 

• Vapor suppressed resins - They are being used in some stages of 

hand layup and spray layup processes and provide a reduction in 

styrene evaporation by forming a layer of wax on the surface. They 

tend to be used where applicable, but are not applicable in all 

situations (due to technical limitations). 

• More efficient spray guns - Unfortunately we cannot identify 

which types of spray guns these may be - there are some that argue 

internal mix spray guns are more efficient, but the makers of 

external mix spray guns dispute this. Moving away from spray guns, 

or open molding processes altogether would provide emission 

reductions, but again, many who use spray indicate they cannot 

economically make the product any other way. 

• Lower styrene resins - styrene resin content varies from 30-50% 

and when the resin is "diluted" with filler (as is often done with 

bathtub/shower manufacturing), it is even less. Intuitively, this 

could result in less emissions, but the reduction would depend 

greatly on the process and the baseline styrene content. 

• Refrigeration of resin - a technique used in storing resin to 

reduce evaporative losses. 

X 

4 
P.6 

DRAFT DOCUMENT - March 9, 1995 

Madeleine Strum (919) 541 2383 

• Faster curing resins - the industry is investigating whether a 

quicker cure of the resin would reduce emissions 

• Closed Mold processes - e.g. the SCRIMP process (licensed 

technology which must be purchased) . Need to figure out where it 

can be used and its limitations. 

Status 

We were early into the information gathering analysis phase when 

the project was halted due to lack of contract funds (November 

1993) . We had collected several hundred screening survey responses 

(from the nearly 1000 facilities surveyed) and had entered about 

500 into a data base. 

EPA's ORD is undergoing a study to evaluate the impacts of 

pollution prevention alternatives for this industry. The study 

will rely heavily on a test project sponsored by the Composite 

Fabricators Association (CFA), whose members are mainly spray layup 

and hand layup facilities. 

Work towards standard development restarted in January 1995 with 

efforts towards developing pre-MACT. A team of State/locals, EPA 

work group members met in February and the team will be expanded to 

include industry trade association participants and environmental 

groups. 

II. TASKS 

A. For Pre-MACT 

1. Find environmental representative(s) (EPA, with help from 

State/locals) NOW-MAY 1995 

2. Further education of Pre-MACT team through site visits arranged 

by industry team members (industry, interested team members) 

APRIL 95 

3. Collect information on State/local air Regulations for this 

industry. (Industry and State/local cooperative effort) 

APRIL 95 

4. Establish process definitions (like subcategories) which would 

need to be analyzed separately for developing different standards. 

EG: gelcoating, resin spray, filament winding, SMC compounding, 

BMC compounding, cultured marble. (Industry effort/EPA to use data 

from survey to estimate emissions by process) NOW-JUNE 95 

/ 

S 
P.7 

DRAFT DOCUMENT - March 9, 1995 

Madeleine Strum (919) 541 2383 

5. Examine add-on control devices. (Pre-MACT vendor meeting/ EPA 

effort to prepare information) MAY 95-JULY 95 

6. Examine source reduction techniques and their specific 

applicabilities/limitations within each process. (Industry/EPA 

(Office of Pollution Prevention/Office of Research and Development) 

effort to prepare infonnation from survey) NOW-JULY 95; DRAFT FOR 

POSSIBLE JUNE MEETING 

7. Brainstorm session Pre-MACT meeting (June 1995) 

8. Develop regulatory alternatives for each process (Pre-MACT 

meeting) LATE JULY OR AUGUST 95 

9. Pre-MACT decision meeting - Pre-MACT determination and/or 

develop questions, data needs AUGUST-SEPTEMBER 95 

B. POST pre-MACT activities 

1. Answering Pre-MACT decision meeting questions 

2. Establish an equation/approach for Potential to emit -

modelling will be done for open molding processes based on CFA test 

results and recent emissions data. Will need to figure out how to 

do this for other processes used in industry (one way is to require 

mass balances). 

3. Area source finding (could be done before Pre-MACT if data is 

provided to Chuck French) 

4. Impact assessments -- emissions, emission reductions, costs, 

etc. May involve survey analysis, model plant developments, 

economic impact analysis 

5. Development of Background Information Document 

6. Development of proposed rule and preamble 

7. EPA Work group review/closure process for proposal 

6 
P.8 

DRAFT DOCUMENT - March 9, 1995 

Madeleine Strum (919) 541 2383 

PRE-MACT TEAM 

Mohan Balagopalan, SCAQMD Pre-MACT TEAM 

Bob Burmark, Washington State Pre-MACT TEAM 

Leonardo Ceron Region IV Pre-MACT TEAM, EPA Work Group 

Lisa Conner, OAQPS/AQSSD MD-15 Pre-MACT TEAM (econ. member) 

Patricia Embrey OGC (mail 2344) EPA Work Group 

Bob Fegley ORD, DC (mail 8105) EPA Work Group 

Chuck French, OAQPS/AQSSD MD-15 Pre-MACT TEAM (health member) 

Robert Goulish, Ohio EPA Pre-MACT TEAM 

Norm Kaplan, EPA/ORD (MD-61) Pre-MACT TEAM 

Karen Levy OPAR (mail 6103) EPA Work Group 

Maria Malave, OECA; (mail 2223A) Pre-.MACT T.EAM, EPA Work Group 

Haile Mariam, OSW (Mail 5302W) EPA Work Group 

Craig Matthiessen, OSWER (mail 5101) EPA Work Group 

Steve McNally, CFA Pre-MACT TEAM 

Richard Nielson, Clark County Health District Pre-MACT TEAM 

Carlos Nunez ORD, RTP (MD-61) Pre-MACT T.EAM, EPA Work Group 

Solomon Ricks, OAQPS/EMAD (MD-19) Pre-MACT TEAM (testing member) 

Bob Rose, OSDBU 1230-C EPA Work Group 

Ron Ryan, OAQPS/EMAD MD-14 Pre-MACT Team 

John Schweitzer, SPI Pre-MACT TEAM 

Jordan Spooner OPPT/PPD (mail 7409) Pre-MACT TEAM, EPA Work Group 

Madeleine Strum, OAQPS/ESD Pre-MACT TEAM, EPA Work Group 

Jeri Weiss, Region I, APO EPA Work Group 

r 
OUAPT DOCUMENT -- March 9, 1995 

Madeleine Strum (919) 541 2383 

REINFORCED COMPOSITE PLASTICS WORK GROUP/TEAM MEMBER TABLE 

CORE WORK GROUP MEMBERS ARE IN BOLD TYPE. 

NAME 

.Madeleine .Strum 

MUTUAL DURHAM 

*ELLEN DUCEY 

919 541 5408* (while 

Madeleine is away) 

Linda Herring 

MUTUAL DURHAM 

(•Jordan Spooner 

(WATERSIDE 

MALL, DC) 

/.Mnrin Malavc 

(DC) 

'. Haile Mariam 

(WATERSIDE 

MALL. DC) 

• i'nlricia Lmbrcy 

(WATERSIDE 

.MALL. DC) 

•;, Karen Levy 

1 

OFFICE 

OAQPS/ESD/ 

Coatings and 

Consumer Products 

Group (CCPG) 

OAQPS/ESD/CCPG 

OPPT 

Pollution Prevention 

Division 

OECA 

OSW 

Waste Min. Branch 

OGC 

OPAR 

PHONE# 

919 541-2383 

919 541 5358 

202 260 4418 

202 564 7027 

703 308 8439 

202 260 7625 

202 260 8952 

FAX* 

919 541 0072 

919 541 0072 

202 260 0178 

202 564 0050 

703 308 8433(? 

ADDRESS 

MD-13 

USEPA 

RTP, NC 27711 

MD-13 

USEPA 

RTP, NC 27711 

i> - • ' 

Ni/Mlcode 7409' 

401 M. St. SW 

Washington DC 20460 

OECA/2223A 

401 M. St. SW 

Washington DC 20460 

401 M St. SW 

Washington DC 20460 

202 260 0586 (ro2344)~ " 

401 M Stf SW„ 

Washington.DC 20460 

202 260 9766 Mailcode 6103 

401 M^StrerfjS-.l/V, 

Comments 

Project Lead 

to whom all correspondence 

should be directed; 

WORKGROUP CHAIR 

Group Leader for Coatings 

and Consumer Products Group 

Source Reduction Review 

Program (SRRP) Project 

Coordinator from OPPT 

OECA WG member 

c^ 

r.O 
DRAFT DOCUMENT -- March 9, 1995 

Madeleine Stnim (919) 541 2383 

1-

fr 

fl 

Pi 

/'1l 

// 

NAME 

/"•Bob Fcgley 

(WATERSIDE 

.MALL. DC) 

r

.Rob Burmark 

• Mohan Balagopalan 

• Robert Goulish 

' .lohn Schweitzer 

. Steve McNally 

OFFICE 

ORD 

State of Washington 

South Coast Air 

Quality Management 

District 

Ohio EPA 

(Northeast District 

Office) 

Society of Plastics 

Industry, Composites 

Institute, Technical 

Director 

Composite 

Fabricators 

Association 

Director of Govt. 

Affairs 

PHONEg 

202 260 0484 

206 407 6812 

909 396 2704 

216 425 9171 

313 668 4703 

703 524 3332 

FAX/? 

202 260 6932 

206 407 6802 

909 396 3342 

ZJ4. 1*7 

076 7 

313 668 4708 

703 524 2303 

ADDRESS 

401 M StHSW 

Dept.Ecology; Air 

program; PO Box 

47600; Olympia, 

Washington 98504-

7600 

SCAQMD-,21865 E. 

Copley Drive, 

Diamond Bar, CA 

91765-4182 

Ohio EPA 

Division of Air 

Pollution Control 

Northeast District 

Office 

2110 East Aurora 

Road 

Twinsburg, Ohio 

44087 

1441 While oireet 

Ann Arbor, MI 

48104 

1735'Northlyrin St. 

Suite 950 . 

Arlington, VA 

22209-2022 

Comments 

4 

• 
DRAFT DOCUMENT -- March 9, 1995 

Madeleine Strum (919) 541 2383 

ii 

Mi 

w 

NAME 

- ^ h

 Ro;i0

 ' HcJlery 

(Crystal City. VA ) ' 

Ron Ryan 

(l-PA.RTP) 

Leonardo Ccron 

Jeri Weiss 

Chuck French 

laurel Driver 

Craig Matlliiessen 

(WATERSIDE 

MALL. DC) 

(";irlos Nunez 

Norm Kaplan 

Lisa Conner 

f.MUTUAL 

DURHAM. NC) 

OFFICE 

Deputy Small 

Business 

Ombudsman 

OAQPS/EMAD 

/Emission Inventory 

& Factors Group 

Region 4 

Region 1 

AQSSD/Risk & 

Exposure 

Assessment Group 

PHONE# 

703 305-55+1-

919 541 4330 

phone 404 

347 3555 ext 

4196 

617 565 9177 

919 541 0467 

AQSSD/Visibility 

and Ecosystem 

Protection Group 

OSWER 

ORD/AEERL 

ORD/AEERL 

OAQPS/AQSSD/ 

Innovative Strategies 

& Economics Group 

FAX* 

703 305 6462 

919 541 0684 

404 347 2130 

617 565 4939 

sm OSXL 

919 541 2859 

202 260 9781 

202 260 9781 

5338 (sec.) 

919 541 1156 

919 541 2556 

SoGO 

919 541-3569-

SW 0837 

ADDRESS 

OSDBU 

1230-C J401 M Stff SW. 

MD-14 

U-S.se/. /Voioi. l^T 

345 CourtlanffStreet, 

NE. 

Atlanta, GA 30365 

Jt&.&* fiyit.1 

JFK Federal Building 

Boston, Mass 02203-

2211 

MD-15 

MD-15 

Comments 

•not sure if they are ou WG yet" 

information only 

lead Regional WG member 

information only 

202 260 0927 

919 541 2157 

919 541 5227 

5^1 OSl^ 

-Sifl*; U.S.EPA 

401 M strif e 

Washington^DC 20460 

MD-61; RTP, NC 

27711 

MD^T; RTP, NC 

27711 

MD-15 

USEPA 

RTP, NC 27711 

infonnation only 

not sure if he is WG yet 

ORD pollution prevention 

project coordinator 

cost, economic and impact 

analysis lead 

C> >. 

» 
DRAFT DOCUMENT •- March 9, 1995 

Madeleine Strum (919) 541 2383 

/'/J 

NAME 

Solomon Ricks 

(GRAND SLAM. 

RTP) 

.lane Caldwell 

(MUTUAL 

DURHAM. NC) 

• Richard Nielson 

OFFICE 

OAQPS/EMAD/Sou 

rce Characterization 

Group A 

OAQPS/AQSSD/He 

alth Effects and 

Standards Group 

Clark County Health 

District (Las Vegas) 

PHONE# 

919 541 5242 

919 541 0328 

702 383 1276 

FAX/f 

919 541 1039 

fax 702 383 

1443 

ADDRESS 

MD-19 

USEPA 

RTP, NC 27711 

MD-15 

USEPA 

RTP, NC 27711 

Shadow Lane, Las 

Vegas^m 

Comments 

measurement lead 

information only 

Piifuhf 

Acronyms: 

AQS5D= Air Quality Strategies and Standards Division (which is within OAQPS) 

LM.\D= Emissions. Monitoring & Analysis Division (which is within OAQPS) 

ESD= Emissions Standards Division (which is within OAQPS) 

OECA= Office of Enforcement and compliance assurance 

OGC= Office of General Counsel 

OI'AR = Office of Policy Analysis and Review 

OPPT = Office of Pollution Prevention and Toxics 

OSDRU = Office of Small and Disadvantaged Businesses 

OSW= Office of Solid Waste 

ORD= Office of Research and Development 

AI:.ERL= Air and Energy Engineering Research Laboratory 

EPA CONTRACTORS ON PROJECTS RELATING TO THE SOURCE CATEGORY OF REINFORCED COMPOSITE PLASTICS: 

I OK OAQPS/ESD Project: 

Ken Meardon/Greg LaFlam; Pacific Environmental Services (919) 941 0333 (ph) 941 0234 in person 

FOR ORD/AEERL Project: 

Mark Bahner/Emory Kong; Research Triangle Institute (919) 541 6016 by fax 7155 

• \ 

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