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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

A ${(JA$) ll-E-205 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 245 of 264 
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E9it Incorporated. Environmental Consulting and Research 

Reinforced Plastic Composites 

Pollution Prevention Focus Group Meeting 

September 13, 1993 

Organized by: 

Organics Control Branch 

Air & Energy Engineering Research Laboratory 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 

®@a/FF 

Participants 

Robert Lacovara, Composites Fabricators Association 

Nancy Dehmlow, Great Lakes Terminal & Transport Corporation 

Robert L. Cottrell, ARJAY Technologies, Inc. 

Bill Seemann, Seemann Composites Inc. 

G. Maury Shepherd, Film Technology, Inc. 

Robert McCullough, Binks Manufacturing Company 

Casey Herbert, W.E.T., Inc. 

Mark Livesay, Sunrez Corporation 

Donald E. Cope, Byk-Chemie USA 

William A. Schramm, Reichhold Chemicals, Inc. 

Kenneth Kensington, Viatec Recovery Systems, Inc. 

Fred Dierks, Aqua Glass Corporation 

Gary Multanen, Fiberglass Systems, Inc. 

Bruce Pfund, Professional BoatBuilder Magazine 

Carlos Nunez, U.S. EPA 

David Ocamb, TRC Environmental Corporation 

Rebecca Battye, EC/R Incorporated 

Jeanne LaPlaca, EC/R Incorporated 

Steve Fudge, EC/R Incorporated 

James H. Jones, National Institute for Occupational Safety & Health 

Amy Beasley Spencer, National Institute for Occupational Safety & Health 

George M. Fullbright, Owens/Corning Fiberglas 

Karsten H. Moritz, New Jersey Institute of Technology 

Robert J. Cavalier, Cavalier Enterprises, Inc. 

Gregory A. La Flam, Pacific Environmental Services, Inc. 

Dean A. Carroll, Pacific Environmental Services, Inc. 

University TOWCT, Suite 404 • 3101 Petty Road, Box 37 • Durham, North Carolina 27707 

Telephone: (919) 493-6099 • Fax: (919) 493-6393 
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I. Introduction 

The purpose of this project was to support the U.S. Environmental Protection 

Agency's (EPA) efforts to develop Maximum Achievable Control Technology (MACT) 

regulations for the Reinforced Plastics Composite Production source category. The open 

mold process has been preliminarily identified as the largest potential subcategory of 

emissions within the Reinforced Plastic Composites Production source category. Boat 

Manufacturing also utilizes the open mold process, and many opportunities that were 

identified prior to the meeting were first tested and utilized in the boat manufacturing 

industry. Therefore participants in the meeting represented the open mold segment of the 

Reinforced Plastics Composites source category as well as the Boat Manufacturing source 

category. 

The deadline established for the development of MACT standards for Reinforced 

Plastics is 1997, and it is the year 2000 for Boat Manufacturing. Boat manufacturing is 

listed as a separate category in section 112(c)(8) of the 1990 Clean Air Act amendments. 

The precedent for regulating boat manufacturing as a separate category was set when the 

Occupational Safety and Health Administration (OSHA) exempted boat manufacturing in 

their regulations of worker exposure to styrene. 

Preliminary investigations into these source categories identified source reduction 

techniques that have already been developed but have not fully penetrated the industry. As 

such, the meeting was oriented more towards the discussion of specific products and research 

efforts in a forum where industry could ask questions and discuss the advantages and 

limitations of the technology. Each participant briefly introduced themselves, and provided 

some insight as to why they were participating in the meeting. A copy of each participants 

business card is attached (Attachment 1). 

Four general groups of participants were present at the meeting. The groups 

represented resin manufacturers, resin application equipment manufactures, fabricators, and 

"other." The resin manufacturers included major polyester resin manufacturers, as well as 

manufacturers of styrene suppressant resin additives, photo initiator additives, and water 

emulsified resins. The equipment manufacturers included the largest distributors of spray 

guns, as well as alternative less polluting application equipment including pressurized rollers, 

fabric impregnators, and vacuum bag molders. The fabricators included representatives from 

the tub and shower industry, filament winding, and boat manufacturing. "Other" included 

the U.S. EPA, National Institute of Occupational Safety and Health (NIOSH), trade 

associations, academia, and EPA contractors. A flowchart that illustrates the functions of the 

different EPA offices and the relationship of these offices to the various contractors was 

requested and is attached (Attachment 2). It was noted during the meeting that another 

sector of the industry, reinforcement manufacturers, were not represented at the meeting. 

The meeting began with an introduction on the purpose of the meeting, stressing the 

need for participants to "brainstorm" and not to focus on issues related to the limitations of 
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ideas (economic, mechanical, etc.). The main goals of the focus group were to identify a 

full range of pollution prevention options, including technical changes and/or process 

modifications, and to discuss the possibility of overcoming the limitations of such 

technologies within the industry. In addition, the meeting was intended to in a prioritized list 

of potential source reduction research projects with a time frame for their implementation, if 

possible. 

Status of MACT Standards Development 

The first topic of discussion was the status of the MACT standards development effort 

for Reinforced Plastic Composites Production. This standard is in the first stage of 

development, which is the information gathering phase. Information gathering includes 

literature searches, plant visits, discussions with manufacturers and trade associations and the 

development, distribution and analysis of an Information Collection Request (ICR) or survey 

of the industry. The ICR will yield information on what technology is currently being used 

and will provide the necessary information for determining the MACT floor, which is the 

best performing 12 percent of the industry. 

Questions were raised on the criteria for determining the best performing 12 percent 

of the industry. If a technology has been demonstrated to be effective in one sector of the 

industry, industry representatives questioned whether it would be forced onto another sector 

of the industry. One concern was whether a manufacturer building epoxy boats with vacuum 

bag technology (and virtually no emissions) would be classified with a fabricator using 

polyester resins in open molds. Industry representatives pointed out that many boat 

manufacturers have used source reduction techniques and have gone out of business, and 

there was concern that the economics of these alternative technologies would not be studied. 

Assurance was given that EPA is very sensitive to the different processes and products, and 

their limitations to adopting new technologies. 

Questions were also raised regarding the size cutoff for potential regulations. 

Industry representatives asked whether the larger manufacturers would be required to install 

control equipment, thereby penalizing them and giving the smaller facilities (that may be 

under an emissions threshold) an unfair advantage. Conversely, if a small manufacturer 

(building one dinghy a week) uses an exemplary process, could they still qualify in the best 

12 percent. Would a manufacturer with only one spray gun be considered a major source 

because the 10 ton per year cutoff is simply theoretical and is based on the potential to emit 

rather than the actual emissions? EPA indicated that the applicability of the regulation has 

not yet been determined. During the information gathering phase, all manufacturers are 

being considered, even shops with as few as four employees. 

Questions were also raised as to how much of the budget would be geared toward 

fugitive emissions that could be addressed with housekeeping changes (for example, loose 

lids or uncovered drums). 
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A general discussion of regulations affecting the source category and styrene as a 

pollutant was held. Styrene has historically been regulated by EPA under Title I (as a 

precursor to photochemical ozone) along with other volatile organic compound (VOC) 

emissions. OSHA has regulated styrene from a health effects and worker exposure 

perspective. State regulations, zoning and fire laws are also constraints, and they are 

sometimes inconsistent with federal environmental regulations. It was pointed out that 

conflicting regulations end up costing manufacturers significant amounts of money on 

unnecessary changes that have been required more for political than environmental reasons. 

For example, the use of a bottom dump drum is environmentally a superior way to handle 

resin but the zoning department, the fire department, the State and the U.S. EPA all have 

their own rules and they are often contradictory in their objectives. OSHA requirements 

have often led to increased ventilation which is not the same as reduced emissions. 

The low capital intensiveness of this industry was discussed, as well as the future 

inability for new manufacturers to get started based on the complexity and requirements of 

regulations. Historically, there was no barrier preventing anyone with "a pickup truck and a 

garage" from entering this industry. The Europeans are believed to be at a great 

disadvantage to the U.S. in the small boat market, due to the strict regulations there. 

There was a general discussion of technology transfer and the suitability of 

transferring source reduction techniques from one industry segment to another. There is 

concern that filament winding processes and corrosion and chemical resistant products could 

be required to enact the same types of control measures as those used by the less restricted 

tub and shower manufacturers. The uniqueness of the corrosion resistant resins in filament 

winding was brought up, and several of the boat manufacturers stated that many of these 

same concerns are applicable to their industry. For example, some boats are now built with 

a barrier coat of 30 to 75 millimeters of corrosion resistant resin behind the gel coat. It was 

generally agreed that many of the opportunities would have a segment of applicability and 

that no one source reduction measure would be applicable to all product types and all 

processes. It was also acknowledged that many in the industry share the same types of 

problems and that in some areas, technology transfer is appropriate. 

The Composites Fabricators Association (CFA) prepared a document titled Policy 

Statement on Reducing Air Emissions from Open Molding Composites Fabricators 

(Attachment 3). This document includes a chart which breaks down processes into their 

smallest steps. The chart takes the finite number of steps in the production process and looks 

at each individual step as a source of emissions, increasing the feasibility of taking simple 

steps to reduce emissions. It was agreed that there will not be one "magic bullet" technology 

that will solve all emissions problems. An "options list" from which manufacturers would be 

able to choose the best options amongst pollution prevention techniques on a situation-bysituation basis, would be preferable for the new standards. 

The assumption within the industry members of the group appeared to be that the 

standard would be a quantified standard with a required percent reduction. For this industry, 
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that approach is not necessarily valid. The South Coast Air Quality Management District 

(SCAQMD) Rule 1162 does not have such a percent reduction and the Rule 1162 approach is 

still an option. 

The question as to whether emissions as estimated using the AP-42 emission factors 

would be used as the baseline for standards was raised. It was pointed out that many 

manufacturers have already changed processes or incorporated procedures that reduce 

emissions below what AP-42 would estimate. The question of how these manufacturers 

would be credited for these changes was raised. Without an understanding of how the 

baseline is determined, there is no incentive for industry to continue changing and improving 

their emission rates; in fact, they may benefit from delaying the implementation of emission 

reduction changes until the standards are promulgated. The question of how these reductions 

would be quantified was raised. 

Equipment Modifications 

In a typical spray up or chop operation, half of the styrene emissions are believed to 

occur during, and as a result of, the spraying, and half are believed to occur during the 

curing process. There is now such a wide range of application equipment that the fraction 

from application can range from approximately 80 percent from an older high pressure 

airless gun to perhaps 20 percent with a high volume low pressure (HPLV) gun. Eliminating 

the use of spraying where it is not necessary could be a help iri reducing emissions. With 

the exception of applying gel coat (where spraying is necessary for acceptable cosmetics) and 

chop (where spraying is an inherent part of the process), spraying is used to transfer the 

resin from the drum or tank onto the mold. In many cases, using equipment that does not 

atomize the resin, such as pressure-fed roller equipment or flow-coaters with pour heads, 

dramatically increases transfer efficiency and reduces emissions. Pre-impregnated fiberglass 

or pre-pregs could be a viable option in certain circumstances. Use of these technologies 

need not be extremely expensive, because the spray equipment manufacturers are currently 

producing equipment which is either adaptable to or focused on these types of applications. 

Spray Guns 

There was a discussion of changes in spray gun technology, which has advanced 

dramatically since 1985. One equipment vendor believes fifty percent of the field is using 30 

to 40 year old spray technology (i.e. the airless high pressure spray gun). Using newly 

advanced spray guns significantly reduces spray gun emissions. It is believed that two 

percent of the resin weight is lost as air emissions during spraying. 

Spray guns are required for gel coat operations, and typically higher pressures are 

used to atomize the gel coat. However, one equipment vendor believes that gel coat 

operations only account for 8 to 12, or maybe 15, percent of the total emissions. The 

emission rate for gel coat operations is higher than during resin application, but the quantity 

of gel coat used is a small percent of the total resin use. The use of rollers and brushes to 
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apply gel coat in England was brought up, but the industry representatives were quick to 

point out that the United Kingdom's gel coats are of a lower quality than American gel coats. 

Changing to a less cosmetically perfect process would be impossible for many industry 

segments. 

Nevertheless, low pressure, low volume gel coat spraying can reduce emissions 

significantly. By using a pressure of 35 (as opposed to 65) psi, a smaller nozzle orifice, and 

a lower viscosity gel, a lot less gel coat is used to cover a surface, and the only economic • 

loss is in increased labor demands, due to the comparative slowness of the process. Using 

recommendations such as these, a 45 percent reduction in gel coat spending can be achieved. 

Operator training was listed as the key to making these changes effective. 

It was pointed out that regulations prohibiting the use of spray guns might not reduce 

emissions. Industry emphasized the importance of creating incentives for producers to do 

things more efficiently, rather than forcing them to meet regulatory requirements. 

The issue of "equipment loyalty" and a general reluctance on the part of 

manufacturers to change equipment brands was raised. It was pointed out that MACT 

standards will be phased in over a period of years and that studies have shown that replacing 

equipment is profitable to manufacturers, with payback time being less than one year in some 

cases, due to the amount of resin saved. 

Pressure Fed Rollers 

The use of pressure fed rollers as a way to reduce emissions was discussed. Certainly 

for many applications, a spray gun is not necessary and a pressure fed roller that meters 

resin will result in an even distribution of the resin witii significantly less waste and less 

emissions. Often molds are designed to be used with spray gun technology and by rethinking 

the manufacturing process, rollers can be used instead of spray guns. The pressure fed roller 

technology should eventually penetrate the fabrication industry because it can be shown that 

there is an economic incentive for using this technology. Government should not force 

adoption of this technology, by banning the use of the spray gun; rather, industry should be 

educated that a higher quality, lower cost product can be produced using this technology, 

which is also less polluting. 

Vacuum Bag Molding 

Vacuum bag molding is a technology that has been in existence since 1948. The 

MARCO vacuum bag method, dry fabric was placed on the mold, there was a resin trough 

around the part, and the vacuum pulled the resin up and through the fabric. Sometimes the 

resin would have to infuse up six feet. New advances in vacuum bag molding have 

occurred, primarily in the resin delivery technique. In vacuum assisted resin transfer and in 

the vacuum infusion process, the resin goes over the fabric and under the vacuum bag. The 

resin only has to infuse through the thickness of the part. 

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Vacuum bag molding is rather simple; the fabric is laid on the mold dry, a resin 

distribution system is put on top of the fabric, the vacuum bag is put over the mold, and a 

vacuum is drawn which pulls the resin over the fabric. Parts made using this process have 

been around for a while and have undergone extensive testing. Vacuum bag molding works 

with flat, female, and male molded parts. The quality of the finished parts is similar to that 

in the aerospace industry, with glass contents of 70 percent and a virtually porosity free 

product. Small parts can be made, and currently available materials, including epoxies, 

phenolics, polyesters, and vinyl esters, work with the system. This system wets out fiber 

underneath a core. 

One company has been working with vacuum bag molding under contract to the 

Naval Research lab, focusing on the ability to produce very large, high quality parts. The 

Navy has required the development of this technology using materials already on the market. 

OSHA has been unable to detect emissions in this shop while using the vacuum bag 

technology, despite the fact that the building is air conditioned and there is no special 

ventilation at work. In addition, the workers are happier with a clean, comfortable 

environment. 

Recently Tillis & Pearson (boat manufacturers in Rhode Island) have begun using this 

new technology with existing molds. They have built at least sixty Jay 80's and they are 

gearing up to build other boat models. They are saving money and labor with this 

technology, building half of a 64 foot hull in less than an hour. 

In some applications where cosmetics are not a primary concern, the surface is neither 

skin coated nor gel coated. The cured resin is translucent and any problems in the final 

product are clearly visible. Because the products are produced in one step, however, there is 

a problem with print through. Reichhold is currently assisting in providing ideas and/or 

research in solving this print through problem. Production shops do typically include a gel 

coat step. Improvements in the cosmetic quality produced by the vacuum bagging, non-gel 

coat process are being investigated in order to allow for the use of this technology among 

more manufacturers. Warpage is not a problem with this technology. A collective problem 

solving effort could be made in this field. It was pointed out that free exchange of 

information and cooperation would be invaluable to solving a lot of the problems being 

discussed. 

Vacuum bag molding technology is a cost effective source reduction option for large 

boat manufacturing. There are secondary benefits, to this process as well, including a 

reduction in solid waste, the need for little re-training of employees, an increase in 

competitiveness, no need for chemical re-formulation, and a reduction in OSHA concerns. 

This is a "new old process," because it is a way to use old techniques with new innovations. 

Vacuum bag molding is slowly penetrating some segments of the reinforced plastics 

composite production and boat manufacturing industry; however, there are concerns in 

pushing the technology too fast. This technology does not eliminate all emissions. Hand lay 
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up, secondary bonding, and gel coating applications are still used in shops that use vacuum 

bag molding technology. 

Vacuum bag molding may be an ideal system, but it is not currently viable for high 

volume production applications, including tubs and showers and entry level boats (17 to 18 

feet in length). In the 17 and 18 foot segment of the marine industry, cosmetics are 

incredibly important and will make adoption of this technology difficult. There is no 

economic advantage to building small boats with this technology; the current boat weights are 

acceptable. 

It is believed that this technology is advantageous for some boat manufacturers and 

the aerospace industry, where vacuum assisted resin transfer technology provides an 

economic advantage over the use of pre-pregs. Side panels for Class A motor homes are 

currently built using vacuum bag molding technology, although they are believed to use wet 

laminate. This technology was believed to be easily transferrable to that industry segment, 

although there were no class A motor home fabricators present at the meeting. There is an 

emissions reduction in using dry laminate, because the use of wet laminates has emissions 

until the vacuum is drawn. This process also works with photo initiated resins. 

Laminating or Fabric Impregnator machines 

The process of impregnating laminate using a fabric impregnator was described. The 

process is to squeeze the resin into the fabric using rollers that resemble "grandma's wash 

wringer." This technology can accurately wet out 100 square feet of laminate per minute, 

versus the 10 square feet that a skilled operator could accomplish. 

This technology allows the use of lower viscosity resins, which allows reductions in 

the monomer content of the resin. In addition, 48 to 50 ounce roving can be used. In the 

past, the weight of the roving was restricted by how long it took to properly wet out the 

roving by hand. This can result in using fewer laminating steps to build the product, which 

results in fewer emissions. 

Process changes often require other changes to make the technology work. For 

example, workers need to be re-trained and there are other changes that facilitate the use of 

fabric impregnators, including tilting molds, custom configured resins, alternative catalysts, 

and/or initiators. 

One problem with the fabric impregnator is that the boat industry tends to run very 

short gel times. This means that the project needs to run through the machine in twenty 

minutes and then the process must shut down while it is cleaned. In an elegant combination 

of many technologies, photo initiated resins can be used with the fabric impregnator. In this 

combination, the fabricating can be interrupted by throwing a tarp over the project while a 

lunch break is taken and then the work can resume without cleaning the machines. 

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Resins and Resin Additives 

A second way to reduce emissions is through the resin formulation. One option for 

complying with SCAQMD Rule 1162 is to reduce the styrene content of the resin to 35 

percent. Resins of this type are termed low styrene resins and have different physical 

properties which may result in fabricators increasing the number of laminating layers. The 

possibility that the SCAQMD Rule 1162 may have increased emissions by requiring more 

laminating steps was raised. The lack of analysis toward actual emission reductions achieved 

through rule 1162 was discussed. 

Fabricators have a range of additives, often called micro ingredients and processing 

aids, which can be added to a base resin. The additives on the market have many functions. 

The most common additives are catalysts and mold release agents. Different catalysts can 

affect the cure time of the resin and consequently the emission rate. The next most common 

additives are used to increase air release and facilitate wetting of the laminate. The low 

styrene resins have sacrificed some properties, and processing agents are used to enhance the 

properties of air release and fiber wetting. 

In the marine industry, the use of low styrene resins can result in a product that is 

more prone to cracking. Rather than dealing with this problem by adding more glass (and 

consequently more resin, creating more emissions) additives pan be used to increase 

flexibility and decrease cracking. 

Styrene Suppressants 

Additives that suppress styrene emissions work by crystallizing at the surface of the 

laminate. Evaporation of styrene cools the surface, which crystallizes the additive. The 

functioning of the additive is very dependent upon its solubility in the resin, which in turn is 

dependent upon the temperature and the exotherm of the resin. High air flows across the 

surface will result in rapid reaction of the additives, due to the increased evaporation of 

styrene. Styrene suppressant additives can reduce curing emissions by 80 percent when used 

with a standard orthophthalic resin with a fifteen minute gel time, using methyl ethyl ketone 

peroxide (MEKP) initiator and cobalt. These reductions do not apply to emissions from 

spraying operations. The use of these additives will have an emission reduction effect in 

handling operations such as fugitive emissions from an uncovered drum. 

There was a discussion of the suitability of using styrene suppressant resins in 

corrosion resistant and fire retardant applications, due to problems of secondary bonding. 

There are resin additives in existence which reduce styrene emissions without introducing 

secondary bonding problems, and manufacturers have supporting data. However, there are 

limits to the use of additives in reducing emissions. 
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Benzoyl Peroxide (BPO) 

Benzoyl peroxide (BPO) can be used instead of methyl ethyl ketone peroxide (MEKP) 

as an initiator. One fabricator began an analysis of BPO when the Occupational Safety and 

Health Administration (OSHA) was considering lowering the acceptable worker exposure 

limit for styrene to 50 ppm. Knowing that they exceeded the 50 ppm threshold, one 

fabricator wanted to find a way to reduce the concentration without spending a lot of money 

on an engineering solution. TTiey began using BPO and noticed significant reductions in the 

concentrations of styrene in the spray booths. 

A test was conducted to determine how much the emissions were reduced using the 

BPO. The same amount of material was sprayed on two molds, using the same spray booth, 

using the same level of initiator. Gas tex sensidyne tubes were placed an inch above the 

laminate in a number of different intervals. The styrene coming off the laminate cured using 

BPO was determined to be two thirds less than the styrene coming off the laminate cured 

with MEKP. 

The BPO decreases the gel time dramatically, allowing the products to reach the 

required Barcol hardness in an hour, as opposed to the 48 hours required with the use of 

MEKP. 

The cost of using BPO is over twice as high as MEKP, but there are savings that 

offset these costs. Respirators are no longer required for the work force, due to the low 

reading of styrene emissions in the spray booths, and the employees are happier. The BPO 

enhances the properties of the products being built, which include horse trailer tops, tubs and 

showers, and small open molded tanks. It is recognized that many factors affect the fracture 

rate, but it is believed the BPO has reduced fracture rates. 

The chemical limitations of using BPO in a chemical resin were mentioned. 

Differences between the tub/shower industry segment and the filament winders was 

discussed, including the lack of fillers in filament winding and the different types of resins 

that are used. The filament winders have tried BPO and dimethyl aniline (DMA) but were 

unable to achieve the desired Barcol hardness readings. The chemistry for the vinyl ester 

resins is different and as such the desired Barcol hardness cannot be achieved using 

BPO/DMA initiators. For the filament winders, the production of a flimsy part is 

unacceptable and they need to use post curing to achieve the desired Barcol hardness. 

There was a request for a more scientific and defensible test to quantify these 

findings. 

Photocuring Resin Additives 

Light-cured or photocured resin is another new technology that is penetrating the 

industry. In this process, a photocuring additive is mixed with the resin, the resin is applied, 

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the product is exposed to light, and the product cures usually within 10 seconds. Barcol 

hardness can be reached in 10 minutes, at which point the part is removed from the mold. 

Within 10 seconds of the light application, the styrene is locked inside the part and emissions 

cease. The photocuring additives have no effect on reducing emissions during spraying or 

other applications methods, the emission reduction is achieved in the curing phase. 

Advantages of photocuring resin include: 

No mixing and dosing is necessary; mixing and metering systems for curing agents 

are not needed. 

No mixing and metering errors. 

No limits on the processing time (the "pot life") by the addition of the catalyst and the 

accelerator. 

Fast gelling and short curing times. 

Curing with less stress. 

Reduced evaporation of styrene. 

Re-use of resin waste. 

Low cleaning costs. 

Less cleaning agents required. 

Disadvantages include: 

Cannot be pigmented. 

Only limited quantities of transparent fillers can be added. 

Light cured resin is more expensive than standard resin, but there are savings 

associated with it. For example, there is less waste, since the resin can be gathered up and 

reused. In addition, both labor and solvent costs for clean up are reduced because the resin 

does not cure until the light is activated. Costs associated with this system include the cost 

of the resin and the lamps. The cost is dependent upon the application, and the quantity and 

reactivity of the resin. The photocuring additive costs 20 to 25 cents a pound. Fluorescent 

lamps work well and are less expensive than mercury vapor lamps. This process can 

increase the production schedule and costs should be analyzed on a case by case basis to 

determine if the increased costs of the resin will result in savings in other production costs. 

Heat is not required for photocuring resin and it works well in cold weather. 

However, the application method (spraying, rolling, etc.) does require a warm resin that will 

flow. This type of resin allows wide variations in both the temperature and viscosity of the 

resin formulation. It can be held at a temperature of 130 °F for a while and can move very 

quickly through the resin transfer molding system. 

Photocuring additives are BASF technology. This curing system results in complete 

cross-linking; the products have no styrene smell, even if they are broken. Laminates up 

5/8" thick can be made in one step. This resin has been used with 24 ounce rovings and a 

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fabric impregnator, and the laminate was cured in one step. Full curing can be achieved, 

even in corners, with the use of hand held lights. 

This process is in commercial production. The Army is currently using patches 

created by this process. The patches are preimpregnated repair kits. They can be used to 

patch aluminum, steel, or fiberglass. A small boat manufacturing facility in Florida is also 

using this process. In addition, a firm in Texas is using this technology to build 52 inch 

couplings for sewage pipes. As part of a teaching program, this resin is used to build a 

couple of boats a year. One advantage of this system is that the brushes and rollers can be 

wrapped in foil overnight and used again the next day, thereby reducing the amount of 

solvents and the time used in clean-up. 

This resin will not work well in the tub/shower industry because the fillers used, 

primarily calcium carbonate, are opaque and interfere with the curing. This resin can, 

however, be used with polypropylene core materials, because they allow the penetration of 

light. 

Currently, there is a joint effort to integrate the technologies of vacuum assisted resin 

transfer and photocuring resins. In the vacuum process, the fibers are washed out when the 

resin is pulled through. The photocuring resin can be used to staple the reinforcement in 

place by selectively curing small areas of resin. Once the reinforcement is securely in place 

the vacuum will be drawn and the resin will be pulled through. 

Water Emulsified Resin 

In the past, water emulsified resins have had a lot of problems; the resin shrank, there 

were problems getting all of the water out, the laminates had cracking problems, and the 

cured product tended to give up its physical and mechanical properties, resulting in a product 

that was unsatisfactory in structural applications. A new water emulsified resin has recently 

been developed that does not have these problems and limitations and is believed to have 

lower styrene emissions. The peak exotherm (185 °F) and vapor pressure are lower than for 

neat resin. Therefore, the styrene is less volatile and emissions are reduced. 

The new water emulsified resin is produced by adding an agent to the water and 

another agent to the resin, and a machine is used to emulsify the resin and water. This 

results in an emulsified resin that contains forty percent less styrene than neat resin. This 

reduces overall cost of the resin by eight to ten cents a pound. The emulsified resin is 

stable; it can be manufactured at a resin manufacturing facility and shipped. The intent is to 

license the technology, sell the machine and have the fabricators emulsify the resin on site. 

This would avoid the cost of shipping the water. 

The water comes out of the resin during the curing process, and a high density 

cellular structure is produced. No post curing is required. Secondary bonding is believed to 

be enhanced due to the properties of the agents that are added to emulsify the resin. There 

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have not been any tests on this resin for chemical resistance. The initial market was seen as 

the marine and tub/shower segments of the industry. Any fire retardant and temperature 

resistent properties that are in the base resin will be maintained in the emulsified resin. The 

cured resin has equal physical and mechanical properties to those of a neat resin. The cured 

resin is thicker and stiffer per dollar of resin applied. 

There have been no formal emission rate tests. Some tests were conducted with 

draegger tubes. Emissions are believed to be lower because of the lower styrene content, the 

lower exotherm and the lower vapor pressure. It was generally agreed that a 40 percent 

reduction in the styrene content of the resin will not necessarily translate into a 40 percent 

reduction in the emissions; the reduction could be higher. Humidity is known to effect 

emission rates and the evaporation of water would probably also effect the emissions from 

this resin. 

This process has been tested by building a commercial fishing boat which is still in 

the water and shows no signs of problems. During the construction of the boat there was no 

need to periodically open up the building to air out the styrene emissions. In addition, test 

panels were prepared and sent to laboratories for tensile, flexibility, and impact tests. One 

test panel was made with three layers of 1.5 ounce chop strand mat and the other test panel 

was made with three layers of 1.5 ounce chop strand mat and three layers of continuous 

roving. The higher glass content panel did have higher numbers than the neat resin but 

statistically no difference in the structural tests were observed. The thickest laminate 

produced was 3/8 inch, and no cracking, steaming, or boiling up of the resin was observed. 

The emulsified resin is white, which requires that workers in the marine industry, 

who are accustomed to clear resins, become comfortable with rolling out a white resin where 

the existence of air bubbles would not be visible. This resin is very easy to roll out. This 

resin is not yet in commercial use. 

The water emulsified resin can be used with MEKP or BPO and standard spray 

equipment. There is the possibility that the tips of the spray guns may corrode due to the 

water. A venus chopper gun was used during the building of the commercial fishing boat. 

The resin has good structural properties because it is thicker and stiffer than neat resin. 

There was a request to include this water emulsified resin in the CFA emission test 

program. 

Research to Determine a Non-volatile Cross Linking Agent 

The Emission Reduction Research Center is a cooperative organization composed of 

academia and industrial representatives. The consortium is composed of New Jersey Institute 

of Technology (NJTT), the Massachusetts Institute of Technology (MIT), Ohio State 

University and Pennsylvania State University. Their current funding is from the National 

Science Foundation. They are currently researching a new resin formulation that utilizes a 

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P.15 

non-volatile cross linking agent. They are just beginning this research effort and do not have 

anything to put on the table at this time. 

Fabricators 

Several concerns were voiced by the fabricators. The ICR and the difficulty of 

estimating baseline emissions with the current tools available was discussed. In addition, the 

lack of definition of the target for the regulation was of concern. Specifically, it was 

questioned whether an 80 percent emission reduction of emissions from an open mold 

process using a spray gun would be enough. Inquiries were also made as to whether 

reductions that can be achieved by switching from a spray gun to a pressure fed roller would 

be enough or would the fabricator need to go all the way to vacuum bag molding? After the 

emissions from spraying resin are reduced, the emissions from spraying gel coat will be the 

next single largest chunk of emissions and the next logical target for reductions. 

A discussion of plant visits was held. No application control equipment (for example, 

incinerators) has been observed in this industry, by EPA representatives, although some is 

known to exist. One fabricator mentioned that during a plant visit to his facility, he held 

back nothing and showed the contractors everything they wished to see, in order to ensure 

that there was a good understanding of his industry and the problems which misguided 

regulation could have on his business. 

Filament winding uses historical data for corrosion and chemical resistant properties. 

Filament winding typically uses a standard MEKP initiator; there are no fillers, the curing is 

typically done at room temperature, they often build very large vessels, and secondary 

bonding is an important issue because of the liability if one of these vessels were to fail. 

Within the shop, ten different resins can be in use at one time. Often the structures are built 

in the field. There are forty years of data on some of these resins, which allow for a great 

deal of confidence in the use of these materials to build vessels that will house acids and 

other substances that will cause great environmental damage in the event of an accident. 

The use of specialty resins with chemical and corrosion resistant properties is not 

limited to the filament winding segment of the industry. The marine industry often uses a 

corrosion resistant vinyl ester barrier coat to reduce blistering. In addition, products built for 

the government (specifically the defense department) often require these higher properties. 

The plastic composites industry has been hit with a number of regulations and 

investments to comply with these regulation are often counterproductive. For example, 

automatic handling equipment that would pump resin throughout the plant could be installed 

in a facility for approximately $20,000. This type of equipment significantly reduces 

"housekeeping" emissions, such as fugitive emissions from uncovered drums and reduces 

labor costs. Installation of automatic handling equipment in some States and localities, 

however, conflicts with city planning ordinances arid fire department regulations (the fire 

department prefers that resin be poured into buckets). To comply with these other 

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P.16 

regulations an additional $60,000 would be required to install a containment area to hold the 

liquid bins, a sprinkler system over the containment areas, sump pumps to pump rain water 

out of the bin, etc. Costs associated with new operating permits were mentioned, as well as 

the cost of having a full time employee who only deals with regulations. Also, the 

uncertainty of the regulations that are being developed was voiced as a problem. 

One tub and shower fabricator stated that in a small (roughly 130 units a day) shop, 

he reduced gel coat usage by one third. This was accomplished when the pump pressure was 

reduced from 65 psi down to 35 psi, on a 20 to 1 pump, the orifice size of the spray tip was 

reduced from 21,000 to 18,000 and the viscosity of the gel coat was lowered. Measurement 

of gel coat usage showed that previously the manufacturer used 164 ounces of gel coat to 

cover a tub/shower and using the new low pressure gun reduced the gel coat usage to 124 

ounces of material to cover a tub/shower at the same thickness. Labor costs increased, but 

the actual gel coat costs have been reduced by 40 percent. 

Additional reductions for this fabricator could be achieved by his using a lower fluid 

pressure; for example, 350 psi instead of 700 psi. But the high pressure is used because this 

fabricator still chooses to use an external mix gun. Operator training is very important to 

reduce gel coat usage. 

Another tub/shower manufacturer stated that he is locked into using the spray booths 

that his company uses. They are currently able to produce 80 to 90 tub/showers per gel coat 

operator (as opposed to the 25 to 30 that are produced using the lower pressures mentioned 

above). Due to the conveyor line nature of the way this shop is set up, it would be 

impractical to have the tub/showers held up to apply the gel coat with lower pressure. 

A discussion of reducing emissions through reductions in the number of laminating 

steps was raised. It was pointed out that in California there could be a negative impact 

(increased emissions), because using low styrene resins may result in a fabricator using five 

laminating layers instead of four to compensate for the loss of structural properties of the low 

styrene resins. It was pointed out that emissions could be reduced by reducing the number of 

laminating layers. Some boat manufacturers are beginning to use 60 ounce glass and putting 

down one layer. 

Fabricators must compete not only with other composites fabrications but with other 

materials, such as steel stamped tubs and tiles. This plant has 30 models at one plant and 40 

models at another plant. Tying up the molds to use low pressure guns would be impractical. 

High volume serial production is not limited to the tub/showers sector of the industry. 

The transportation segment, which includes truck hoods, truck cabs, van tops, etc., would 

have the same problems with technology transfer as the tub/shower segment. 

Purchasing new equipment as a result of MACT regulations could have a profitable 

impact on many manufacturers. Old, airless, high pressure equipment can be replaced with 

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P.17 

new equipment with a pay back period of less than one year. Replacement of old equipment 

can be a money maker. This is a very low capital intensive industry. It was mentioned that 

a side effect of regulation could be the development and expansion of new technologies, with 

an overall lowering of costs. 

Test Programs 

A discussion of the upcoming CFA test program for open mold processes was held. 

The purpose of the test program is to get data to support the regulatory development effort. 

The tests will be conducted at the DOW Chemical facility in Freeport, Texas. DOW is a 

major manufacturer of styrene, and this facility has the analytical equipment and people to 

support the testing. The tests will be conducted over a 30 to 45 day time period in a 

controlled environment. The data will be public and will hopefully be used in the 

development of revised emission factors. The testing is currently scheduled to begin in 30 to 

40 days. 

The tests will be used to establish baseline emission rates. Seven variables will be 

analyzed, including percent styrene, airflow, ambient temperature, gel time, surface area, 

and delivery rate (the seventh variable was not remembered at the time of the meeting). 

Each variable will be tested at two points with other factors held constant, and the data will 

be analyzed using the Taguchi scientific method. The results of the test could be used in the 

development of a predictive tool. 

The CFA is contributing $30,000 to address direct costs for the on-site testing. They 

are also contributing indirect costs for non direct billed expenses, such as professional time. 

The total cost of the program is probably closer to $50,000 to $60,000. Lack of resources 

will exclude additional test scenarios. The test will measure percent styrene lost. They will 

run a spray application of resin and a spray application of gel coat, and then hand batch it. 

Ideally, they would like to analyze seven resins and about 20 variables, and all of the 

currently available application equipment. The resources are simply not available for this. 

A recent pultrusion emission rate study showed that temperature is a level one factor 

in emission rate. Questions were raised concerning the regulation of shop temperature, if 

temperature is found to be very important. Regulation of shop temperature was not ruled 

out. 

Transfer efficiency will not be tested directly in the CFA program. Mass balance will 

be taken into account, but only a limited amount of application equipment will be analyzed. 

Industry representatives stated that they have performed many tests on their own and would 

like to see a protocol established that can be used in a shop environment. The more complex 

CFA results can be used as a calibration method. A list of twenty-one variables that can 

effect transfer rate were mentioned. These variables include temperature, airflow, viscosity, 

gel time, VOC content, volume of resin versus surface area, internal versus external mix 

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P.18 

guns, fluid pressure, tip geometry, spraying versus non spraying, distance from the gun to 

the part, the angle the operator sprays at, vertical versus horizontal spray, and the spray 

pattern used by the operator. 

DOW is a manufacturer of vinyl ester resins, but their resins will not be a part of this 

test program. Corrosion and chemical resistant resins are not part of this program. 

Additives will not be tested in the initial program. 

There is such tremendous variability in emission rates that it is unclear how this 

industry will be regulated and how the MACT floor (best performing 12 percent of the 

industry) will be chosen. The seasonal performance of resins and resin formulations was 

discussed. The question was raised as to how will this variability be taken into account. 

The difficulty of testing in real world applications was discussed. Some fabricators work 

with a 12 foot diameter mandrel which is 30 feet long and can put on 1,000 pounds of resin 

in an hour. Fabricators wanted to know how emissions are to be measured. A meeting 

between the CFA and the Stationary Source Compliance Division (SSCD) is scheduled to 

discuss the difficulty of compliance testing for this industry. 

A commitment to expand the test program if additional resources were made available 

could not be made during the meeting (DOW was not represented at the meeting). Once the 

test equipment is set up, it would be relatively easy to run additional tests. Questions on 

additional resource requirements for specific tests (i.e. how much would it cost to test light 

cured resin?) and how soon funds would be needed were raised. EPA committed to looking 

into their current testing plans, coordinating with OPPT, and OAQPS to determine the 

viability of supplementing the test program. CFA is anxious for this not to be viewed as an 

industry test in a suppliers facility; the results will be public and CFA is anxious for any 

input EPA may have to make the test program useful for their regulatory development effort. 

An inquiry as to whether EPA has an available and suitable laboratory was made. 

The amount of floor space required is rather small, but the airflow and temperature must be 

carefully controlled. Once the CFA tests are completed, it is hoped that additional testing 

can be done in actual fabrication shops and the data compared with the CFA test results. 

The CFA tests will establish baseline emissions under standard conditions. 

It was pointed out that the pultrusion segment of the industry had completed a test 

program in the DOW facility and was planning a second program to refine the data collected 

through the first program. Airflow and resin temperature were found to be the two most 

important variables that came out of the pultrusion study. It was also mentioned that DOW 

is currently testing filament winding and corrosion resistant resins. Both of these two test 

programs utilized the same test protocols. It is hoped that the Taguchi scientific method can 

be used to integrate these data sets. 

The issue of the variability of the styrene itself was raised. A question was raised 

about alpha methyl styrene. It was explained that alpha methyl styrene is used to lower the 

17 
exotherm of the resin and improve workability. Typically, it is added to a resin formulation 

in a concentration of approximately three percent, based on the total weight of the resin. 

The CFA tests will utilize two generic orthophthalic resins, one with a high styrene content 

and the other with a low styrene content. The resins will be cooked in the same batch and 

the styrene will be from the same batch. 

Conclusion 

Styrene is a monomer used in both the Reinforced Plastics Composite Production and 

Boat Manufacturing source categories. Styrene is present in the resin and evaporates during 

material handling, the application process, and the curing process. Because styrene is part of 

the polymerization process, evaporation of styrene is undesirable and represents an economic 

loss to the fabricators. As such industrial representatives from both of the subject source 

categories have continuously sought ways to reduce styrene losses to the atmosphere. 

Source reduction techniques were identified in three general areas, application 

equipment, resin formulation, and fabricating practices. In the area of application 

equipment, emissions are reduced through the increase of transfer efficiency of the resin to 

the mold. This includes the use of high volume low pressure spray guns, pressurized rollers, 

vacuum infusion molding, and fabric impregnators. Resin formulations include styrene 

suppressant additives, alternative initiators that affect gel time, and low styrene resins 

including water emulsified resins. Finally, the fabricators can reduce emissions through 

better housekeeping and by analyzing their processes to determine areas where existing 

source reduction measures can be implemented. 

The CFA is currently planning an emissions testing program to quantify the variables 

that effect emission rates for the open mold process. The consensus of the meeting was that 

the source reduction techniques that have already been identified and developed by industry, 

would benefit from additional emissions testing that quantified the emission reductions. This 

is important in order to rank the different techniques in terms of their emission reduction 

effectiveness and in order to utilize source reduction techniques in a regulatory effort. It was 

agreed that a formal test program is needed and that the current program sponsored by CFA 

will only address the baseline and due to funding constraints will not address the source 

reduction methods discussed during the meeting. The results of the test program should be 

utilized to develop a simpler emission test protocol that can be used by industry to quantify 

emission losses during manufacturing. 

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