p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

34) 11-1-34 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:21 PM Sheet 34 of 114 
July 11, 1995 

DEPARTMENT OF 

ENVIRONMENTAL 

Richard Nielsen 

Clark County Health District 

Air Pollution Control 

P.O. Box 4426 

Las Vegas, NV 89127 

QUALITY 

EASTERN REGION 

Bend Office 

Re: Styrene Source Test Information 

Dear Mr. Nielsen: 

Enclosed please find the Source Test Review Reports (2) for the Aqua Glass, Klamath Falls 

facility as prepared by our source test coordinator, Thane Jennings. The source test 

documents themselves are rather large so I did not attempt to copy them. I hope that you 

will fmd this information useful. 

The source test protocol for the October 24-27 test (test #1) is described in the September 7, 

1994 letter to Mr. Gantenbein of BWR (consultant). The initial source test protocol from 

BWR, also enclosed, was found to be deficient in many areas. Test #1 was conducted to 

fulfil a source test requirement in the Air Contaminant Discharge Permit (ACDP). 

The DEQ received the protocol for test #2 months after the test was conducted. We have not 

formally reviewed or approved the protocol. The test was conducted to develop styrene 

emissions infonnation for Aqua Glass, but was later submitted to the DEQ as additional 

emissions information for PSD permitting purposes. Ihave enclosed a copy of the protocol 

for test #2 for your information. 

The DEQ is expecting the full PSD application from Aqua Glass on or about August 15, 

1995. We have already received the BACT analysis and have made a preliminary BACT 

decision which incorporates a combination of process modifications and thermal oxidation. 

However, the BACT determination will not become final until the proposed permit has gone 

through public notice and formal review by the EPA Region X as part of the PSD process. 

I hope the recent test event at the LASCO facility in Moapa went well. I would like to 

discuss this with you, at least when you receive the test results if not earlier. 

If you or your source test coordinator, Mason McNinch, would like to discuss 

testing methodology and results determination, don't hesitate to contact Thane 

Jennings of our office. He can be reached at extension 247. As we found 

with test #2 at Aqua Glass, the results were not always presented in a 

conservative manner. Thane essentially recalculated the emission rates from 

scratch to verify the reported results. 

2146 NE 4th Street 

Suite 104 

Bend. OR 97701 

(503) 388-6146 

DEQ/CR-101 

/ 
P.3 

Richard Nielsen 

July 11, 1995 

Page 2 

If you have any questions or would like additional infonnation you may reach me at 503-

388-6146, extension 243. 

Sincerely, 

Peter J. Brewer 

Air Quality 

PJB:ns 

Enclosure 

cc:

 S7< Madeleine Strum 

US Environmental Protection Agency 

MD-13 

Research Triangle Park, NC 27711 

Thane Jennings: DEQ:Bend/file 

^ 
BWR ASSOCIATES, INC. 

P.4 

ENVIRONMENTAL CONSULTANTS WNmswSmSSu,,^ 

July 22, 1994 

L r?6 1994 

John Hector, P.E. CENTRAL REGION 

Oregon Department of Environmental Quality

 aEHD 

2146 N.E. Fourth, #104 

Bend, OR 97701 

REGARDING: Source Test Plan for Conpliamrp Bnissicn. Testing, Aqua Glass, 

Klamath Falls, Oregon 

Dear Mr. Hector: 

This correspondence is to notify the Agency of the pending source test for the 

above-referenced facility, scheduled for September 23-25,"1994. Unless changed 

by the Agency, this uotice also serves as the approved source test plan. 

1. Sources to be Tested: 

Coltics 

tjtore> 

SOURCE I.D. 

—*-c . 

v D. 

H. 

J. 

L. 

P. 

X. 

DESCRIPTION 

First gel-coat cubicle north 

First gel-coat cubicle south 

First chop booths, combined 

Cover coat cubicle 

Foam cubicle 

Base chop booths, combined 

Heat room 

2. Source Description: The e-xhausts of the above processes (except 

X) are controlled by foam/paper filtration 

and water fall impingement particulate 

removal systems, and exit through vertical 

stacks located above the roof. 

3. Pollutant(s) to be Monitored: Particulate matter (Total & JM10) and 

styrene. 

4. Methods Approved: Particulate Matter- CDEQ Methods 1-4,8 & 9. 

(Total Se EMJQ) assuming all particulate 

to be FM,g. 

Styrene- EPA Method TO-14, verbally 

pre-approved by Mark Fisher 

of CDEQ. 

5. Number of Sampling Replicates: 

Particulate Matter- Three (3) M8 for the source with rhe 

highest potential to emit. Aqua 

Glass has determined that Source H is 

the largest particulate emitting 

source. Methods 1-4 & 9 will be 

utilized in duplicate on the 

remaining sources. 

;AV » MEDFORD. OREGON 37501-1343 • [503] 779-2646 

3 
P.5 

/ 

9 

— BWR ASSOCIATES, INC. 

ENVIRONMENTAL CONSULTANTS 

Styrene- Three integrated samples per source. 

extended over a one hour period. 

6. Source Testing Personnel: "RJO BWR Associates, Inc. representatives 

7. Source Site Personnel Contact: Scott Dickson. Facilities Manager 

Telephone: (503) 882-7711 

8. Applicable Process/Production Information as specified in section 13 

of the ACDP is to b e Collected by Aqua Glass for BWR Associates; 

Inc. and wil l include: 

A) Production rate in fiberglass bath tub units. 

B) Pressure drop across the booth boundary. 

C) Weight of all fiberglass bath tub -.tni.ts produced witr-to** 

testing from production data cr by physically weighing 

each unit to within one pound. 

( V* D) Interior styrene in air testing, utilizing the averag.-. 

V

y*0 of three randomly located detector tube sanples during 

o ne hou r whe n stack styrene samples are being taken. 

\Q . These samples are to be taken from the air five feet 

.^7 _/h above the main manufacturing roo m floor. Detector tubes 

vl , 0 shall have a styrene range of 2-100 ppm. 

/ n * 9. It is assumed today, but it should be confirmed on or befora the 

A^y ^» test day that duct airflow measuring meets the •cri.ceria.-in.-CDSQ 

' Methods 1 and 2. Other special sampling considerations,. inriudi-:_g 

sampling site configurations, equipment limitations, special 

methods, etc.: 

A) CDEQ Method 8 will be modified to increase tiie sample 

rate to decrease the sanple time to two hours per sample 

or less. 

B) The particulate concentrations obtained from Source H 

will be utilized in combination with the individual 

measured flows to determine mass emission rates. 

10. Other Process Considerations, including intermittent production, 

special feed or product, etc.: process operations at 33% or more of 

capacity. 

In no case will sampling replicate(s) be accepted if separated by a time duration 

of twenty-four (24) or more hours, unless prior authorization is granted by the 

Agency. 

The source to be tested must operate at a nominal rate during testing. Rates net 

in agreement with those stipulated in the Air Contaminant Discharge Permit can 

result in test rejection for application to detennine compliance. Imposed 

process limitations could also result in test report rejection. 

Source test reports must be suhnitted to the Agency within thirty (30) days of 

the test dates, unless another deadline has been stipulated, either by permit 

condition, or the Department letter approval. 

0' 

k? 

920 MASON WAY • MEDFORD. OREGON 37501-1 343 • [503] 779-2646 
:"_.___ BWftj ASSOCIATES, INC. ^ 

ENVIRONMENTAL CONSULTANTS 

Aqua Glass will send one (1) copy of the completed source test report to the 

Department of Environmental Quality, Attn: John Hector, 2146 NE Fourth, #104, 

Bend, Oregon 97701. 

If you have any questions, or need additional infonnation, please let'me know. 

Sincerely, 

R. L. Gantenbein, Jr. T.E. 

General Manager 

cc: Scott Dickson, Aqua Glass 

Source Test Coordinator, CDEQ Portland 

RLG/cb 

93-0895X 

- 5SC VASC^.-A'AY • MEDFORD. OREGON 37501-1343 • [503] 779-2646 

5 
P.7 

State of Oregon 

Department of Environmental Quality Memorandum 

To: Frank Messina: ER-Bend 

From: 'Thane Jennin 

Subject: Source Test Review Repon Permit Number: 

. Aqua Glass Test Date: 

' Klamath County Report Received: 

Source Testers: Engineering Environmental 

: Process: Fiberglass Manufacturer 

A •': 

18-0093 

March 7, 1995 

April 3. 1995 

Tvpe of Facilitv 

Sources not listed which would emit 10 or 

more tons/yr VOC uncontrolled, medium cost 

SIC 

3088 

On March 7. 1995 an air source test was performed at Aqua Glass to verify results from a 

previous source test performed in October 1994. The Department has not received a source 

test protocol nor was notification received until after the test had been performed, therefore 

Department personnel were not present during the testing, and no review and approval of test 

protocol is possible. 

The current test was designed to calculate a styrene unit emission factor using the styrene 

emissions from both point and fugitive sources. To simplify the styrene fugitive emission 

measurement the doors opening on the main production area were kept closed, as much as 

possible during the test. Also, certain exhaust fans were turned off to restrict the fugitive 

emission points to an easily measurable number. During the original test only point sources 

were used to calculate the styrene unit emission factor. Fugitive emissions were quantified 

indirectly during the original test by measuring the ambient styrene concentrations at possible 

fugitive emission points such as doorways and exhaust fans. 

The most recent test was perfonned using longer sample periods and a different collection 

media then the October 1994 test. Styrene concentration was measured using duplicate 

charcoal tube samples taken at 8 stacks over a 10-hour period. In addition to the above 

measurements, shon term styrene concentration was measured at the eight stacks during 5 

consecutive 2-hour periods. Charcoal tube samples Jve re also used to quantify styrene 

emissions at the exit of five exhaust fans over a 10-hour period. The 10-hour sampling 

period was chosen to approximate the length of one shift at the plant. 

io 
P.8 

Memo To: Frank Messina 

May 4, 1995 

Page 2 

SmaU battery powered pumps are used to withdraw stack gas from the stack through the 

charcoal tube. These pumps are calibrated at a panicular sample flowrate before the test and 

this calibration is checked after the test. Four of the pumps failed the post test calibration 

and therefore the results for those samples are deemed unacceptable by NIOSH standards. 

Stack gas velocity was measured in the stacks once during the 10-hour sampling period. 

Stack gas velocity measurements are normally performed in triplicate. During the previous 

source test, stack gas velocity measurements were performed 6 times at each site. Data 

quality is improved by increasing the number of flow measurements. Upstream and 

downstream disturbance locations were not recorded for the stack gas velocity measurement 

locations. Source test repons without this information are normally rejected by the 

Department. However, since this source test was not Department approved the issue of data 

quality requirements is moot. The combined volumetric flowrate from the point sources 

measured during this test was 15% higher than the volumetric flowrate measured during the 

previous test. 

The volumetric flowrate of the exhaust fans was not measured directly, but was calculated 

using the manufacturer's fan curves and estimating the rotational rate of the fan blades. 

Exhaust fan emissions comprised 1% of the total styrene emissions by weight. 

Two charcoal tubes were spiked with liquid styrene at one-half the highest quantitated 

standard concentration and one-fifth of the highest quantitated standard concentration. The 

mean spike recovery was 73.1% and was used to correct all sample concentrations associated 

with this analysis event. The source test repon did not contain the laboratory repon or the 

sample chain of custody. The Depanment received the laboratory repon in a submittal from. 

Secor on April 20, 1995. 

The reponed styrene emission factor, 8.11 lbs styrene/bathtub unit, is actually the lowest 

value of the range of values measured during the source test. Upon further analysis of the 

data the Department has determined that the styrene emission factor calculated over a 10-

hour shift should have been reponed as 8.1 lbs styrene/bathtub unit < factor < 9.1 lbs 

styrene/bathtub unit. 

The styrene emission factor calculated using the short term sample is useful for comparison 

with the emission factor calculated from previous source test data because it more closely 

approximates the 30-minute sampling period used during the first test. The 2-hour samples 

are used to calculate an hourly styrene emission rate which is multiplied by 5 and divided by 

the facility shift production to calculate a shon term emission factor. An average of the 5 

shon term emission factors yields a value of 9.4 lbs styrene/bathtub unit which is exactly the 

number reponed during the previous source test. 

n 
P.9 

Memo To: Frank Messina 

May 4, 1995 

Page 3 

Conclusions 

The styrene emission factor for the 1994 air source test was 9.4 lbs styrene/bathtub unit. 

During the most recent air source test a reduction in the emission factor is achieved by 

extending the sampling period over one shift length, the mean of the duplicate samples is 8.6 

lbs styrene/bathtub unit. 8.6 lbs styrene/bathtub unit is the appropriate emission factor to 

predict future emissions of styrene from Aqua Glass. Enforcement actions should be based 

on the previous Department approved and witnessed test because of process and facility 

changes in the interim between tests and the fact that the results of the new source test are 

not substantially different than the previous test. 

cc: John Hector:: DEQ: ER-Bend 

Peter Brewer: DEQ: ER-Bend 

AH Nikukar: DEQ: HQ 

Nancy Couch: DEQ: HQ 

15 
P.10 

September 7, 1994 " 

Oregon 

DEPARTMENT OF 

ENVIRONMENTAL 

R. L. Gantenbem QUALITY 

-J 

-n^ 

BWR Associates, Inc. 

920 Mason Way EASTERN REGION 

Medford, Oregon 97501 Bend Office 

Re: Source Test of Spray Booths 

ACDP 18-0093 

Dear Mr. Gantenbein: 

The BWR Source Test Plan for conducting emissions testing of spray booth emissions 

and ambient air at Aqua Glass, Klamath Falls, Oregon has been reviewed and is approved by 

the DEQ with the following conditions: 

i 

1) The DEQ must be notified of any changes in the source test plan prior to testing. 

Significant changes not acknowledged by the DEQ which could affect accuracy and 

reliability of results will result in test report rejection. 

2) Method-specific quality assurance/quality control (QA/QC) procedures must be 

performed to ensure that the data is valid for detennining source compliance. 

Documentation of the procedures and results shall be presented in the source test 

•repon for review. Omission of this critical infonnation will result in rejection of the 

data, requiring a retest. 

3) The ambient air concentration of styrene shall be measured at five different 

locations inside the plant using EPA Method TO-14, Determination of Volatile 

Orgamc Compounds (VOCs) in Ambient Air Using Summa Passivated Canister 

Sampling and Gas Chromatographic Analysis. The five sampling locations will be 

determined by taking 10 indicator mbe measurements prior to the EPA TO-14 

measurement. The main production area is to be divided into 10 equal areas, 

indicator mbe samples are to be taken at the centroid of each equal area at a height of 

five feet. The five centroid measurement points with the highest styrene 

concentration, as determined by the detector tube will be used as the EPA Method 

TO-14 measurement point. The EPA TO-14 measurement will be taken as a 30 

minute integrated sample concurrent with one of the stack sampling tests. 

m 2146 NE 4th Street 

Suite. 104 

Bend. OR 97701 

(503) 388-6146 

OEQ/CR-im 

°l 
P.11 

R. L. Gantenbein 

September 7, 1994 

Page 2 

«*"---'."''-»-*«-.s-.'>-»*"7>-«v—?»«-rir>-•-"•—»• s._-+:^.JW . •.f»-r_ «•>•«..•.:*.»•**—:'V_-s.-— ->»•«.—•*;<-. •- •__.*._«••«• .-_• —.••.._»,._• %_».o J^-Tti.ct^.-....r-..*_._v-<CT.^-off-~^;»>-'t_T_i»—«•. ' 

4) The following sites will be tested in triplicate for flowrate, moisture content, 

styrene and paniculate using EPA Method TO-14 and Oregon Source Test Methods 1-

4 and 8: 

Gel Coat Cubicle #1 

Gel Coat Cubicle Wl 

First Chop booths, combined 

Base Chop booths, combined 

Foam Cubicle 

Cover! Coat Cubicle 

Heat Room 

The EPA TO-14 measurement will be taken as a 30 minute integrated sample. The 

Method 8 will be performed for a period to be determined by the source tester so that 

the method detection limit is at least 0.0011 grains- per dry standard ft3. If the filter ^:> 

weights mm but to be negative it will be assumed that an insufficient sample volume ''-f?i'' 

was measured and the test results may be rejected. Flowrate measurements must be 

performed concurrendy with the Method TO-14 measurements. Molecular weight 

may be calculated based on an oxygen concentration of 20.9% v/v and a carbon 

dioxide concentration of 0.04% v/v. 

5) Styrene emissions shall be presented in the following units; ppm, lbs styrene/hr, 

lbs styrene/bath mb unit and lbs styrene/lbs bath mb unit for each emission point. 

PMl0 emissions shall be presented in the following units; grains/dscf, PM10/hr, lbs 

PM10/bath tub unit for each emission point. 

6) PJease provide the name and address of the laboratory(s) performing the 

analytical work and a copy of their Statement of Qualifications. 

V 

re* 

10 
P.12 

R. L. Gantenbein 

September 7, 1994 

Page 3 

When submitting future source test protocols please include all the information requested in 

Source Sampling Manual Volume I, State of Oregon DEQ Air Quality Division, such as 

facility address, number of test replicates including blanks, etc. Should you have any 

questions regarding the above conditions please feel free to contact me at 388-6146 extension 

247. 

Sincerely, 

Thane Jennings 

Source Test Coordinator 

Eastern Region - Bend 

TJ/ns 

cc: John Hector, Air Quality Manager, Eastern Region - Bend 

Steve Crane: DEQ:WR 

Jack Herbert: DEQ:NWR 

Dennis Siivola: DEQ:Medford 

Scott Dixon 

Aqua Glass Western, Inc. 

5855 Washburn Drive 

Klamath Falls, Oregon 97603 

ll 
%\ 

Concentration, ng/Lr 

r\j oi -j 

cn o cn 

ooo o 

!>?<__ "•*^SD?e?V_"efo"(j! ^ Ol Q Oi 

o o o 

ro oi •. 

cn o 01 0 0 o 

Acetone 

Hexanal 

Ethylbenzene _b 

m.p-Xylene to 

2-Heptanone 

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•!.••• • !•••• ! 

on 

cn 

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o-Xylene |b 

Propylbenzene p 

Ethyl 3-

ethoxypropionate 

Umonene |CD 

2-(2-

Butoxyethoxy)ethanol 

Naphthalene fch-O 

Pentamethylbenzene • 

Junipene CD 

Methyl laurate _p 

1,1.3,3-

Tetramethoxypropane 

Hexyl acetate 

IndanlJ) 

C3-Benzenes 

Terpenes 

C4-Benzenes 

D-o 

C5-Benzenes tl 

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P.M 

STYRENE SOURCE TEST PLAN 

FORTHE 

AQUA GLASS FACILITY 

IN KLAMATH FALLS, OREGON 

prepared for , 

the State of Oregon 

Department of Environmental Quality 

Air Quality Division 

on behalf of 

Aqua Glass Corporation 

5855 Washburn Way 

Klamath Falls, Oregon 97603 

by 

Robert A. Haberiein, PhJD. 

Engineering Environmental 

100 A Annapolis Street , 

Annapolis, MD 21401 

Neil P. Juiinski, PhD., C.I.H. 

NuChemCo Incorporated 

7008-G Litde River Turnpike 

Annandale, Virginia 

Daniel P. Boyd, PhD. 

Daniel P. Boyd & Company 

Wye HaU, Wye Island 

Queenstown, Maryland 

February 21, 1995 

MAY J c 19=5 

CEmKl__8»_N 

6EMD 

/3 
P.15 

Engineering Environmental 

Consulting Services 

! List of Figures 

1-* Styrene Concentration Profile at Typical Bathware Facility H-3 

2 Diagram of the Aqua Glass Process and Styrene Emissions H-4 

3 Cross-section View of a Typical Waterfall Spray Boo tfi H-5 

4 Diagram of EPA Method 18 Integrated Bag Sampling Train H-7 

5 Diagram of Recommended Stack Test Setup 11-12 

List of Tables 

1 Stack & Fan Descriptions - Expected Flows & Concentrations H-2 

2 Sample Row Rate versus Sample Duration & Concentration 11-14 

3 Typical Sample Train Pump Specification H-17 

4 Precision Rotameter Calibration Data H-18 

5 Standard Charcoal Adsorption Tubes 11-20 

List of Appendices 

A Roof Fan Performance Curves from Loren Cook 

ui 

H 
P.16 

Engineering Environmental 

Consulting Services 

I. B. Oregon DEQ Source Test Plan Requirements 

According to the Oregon DEQ Source Sampling Manual, a source test plan shall 

include, as a minimum, the following fifteen items: 

1. Source name and address. 

2. Source site personnel; contact name and phone number. 

3. Source testing personnel; company, contact name and phone number. 

4. Scheduled date of the source test. 

5. Source description, including a description of the pollution control device and sample 

locations. 

6. Pollutant to be measured. 

7. Test methods. 

8. Number of sampling replicates. 

9. Applicable process/production information to be collected during the source test 

10. Control device operating parameters to be monitored during the testing. 

11. Fuel samples and type of analysis; who will collect them and who will perform the 

analysis. 

12. Visible emissions measurements; who will take opacity readings during the source test 

and are they, certified. 

13. Other sampling considerations. 

14. Other process considerations. 

15. The source test plan shall include the following statements, unless otherwise specified 

by ACDP cc-ndition or DEQ letter 

a. The duct air flow measuring meets criteria in EPA Methods 1 and 2. 

b. The sampling replicates shall not be separated by a time duration greater than 

twenty-four hours. 

c. The source to be tested must be operated at a normal production rate during 

testing. 

d. The DEQ must be notified of any changes in source test plans prior to testing. 

e. Mediod-specific quality assurance/quality control (QA/QC) procedures must be 

performed to ensure data validity. Documentation of the procedures and results 

shall also be presented in the source test report for review. 

f. Source test reports must be submitted to the DEQ within thirty days. 

g. Two (2) copies of the completed source test report must be sent to the 

Department; one (1) to the DEQ Regional Operations staff person responsible 

for the source and the second copy to the Source Testing Coordinator, 

Department of Environmental Quality Headquarters in Portland. 

The following sections discuss several source-specific testing details, describe the 

logistics of the stack test plan and provide a test plan summary in the Oregon DEQ format 

1-2 

15 
P.17 

Engineering Environmental 

Consulting Services 

A substantial amount of the finer aerosols pass through the booth's separation baffles 

and remain in the exhaust These fine aerosols pose a special problem for the charcoal wbes, 

because the moisture could saturate the carbon adsorbent and interfere with the sampling. 

Therefore, it is recommended that the water level in the booth pan should be dropped below 

the lower edge of the entrainment throat to stop the formation of aerosols in the exhaust 

during the test This action should have no impact upon the styrene concentration level in the 

exhaust. 

TABLE 1 Stack & Fan Descriptions - Expected Flows & Concentrations 

Stck 

ID 

1 

2 

3 

4 

5 

6 

7 

8 

Fan 

ID 

A 

B 

C 

D 

E 

Ref 

ID 

D (EF-20) 

C (EF-21) 

L (EF-27) 

J (EF-23) 

H (EF-13, 

EF-19, 

EF-25) 

P (EF-22, 

EF-26) 

X 

- (EF-31) 

Ref 

ID 

EF-10 

EF-3 

EF-7 

EF-43 

EF-14 

Source 

Description 

Gel Coat #1 

! Gel Coat #2 

Foam Coat 

Cover Coat 

First Chop 

Base Chop 

Roll/Heat Room 

Mix Room 

Fan 

Description 

Maintenance Area 

Finishing Area 

Warehouse Area 

Production Area 

Receiving Area 

Stack 

Diameter 

(inches) 

34 

34 

24 

34 

34 

34 

28 

34 

Expected 

Flowrate 

(dscfm) 

4,000 

24,000 

30,000 

4,000 

12,000 

Expected 

Howrate 

(dscfm) 

13,300 

13,500 

7,500 

10,300 

26,200 

18,100 

8,200 

N/A 

Expected Range 

Concentration 

(ppm) 

125-250 

• 125-250 

20-50 

100-200 

125-250 

25-75 

25-75 

N/A 

Expected Range 

Concentration 

(ppm) 

5-10 

5-10 

5-10 

5-10 

5-10 

n-2 

Mt 
P.18 

Engineering Environmental 

Consulting Services 

FIGURE 1 Diagram of the Aqua Glass Process and Styrene Emissions 

VentX 

_ / 

Heat Room 

VentD 

w Clean Mold mean Mora ^ 

VentC 

Gel Coat #1 GerCoat #2 

First Chopper 

VentH 

v" VentV Yem 

VentP 

Base Chopper 

VentL 

Foam Coat 

Cover Coat 

Vent J 

Legend 

L 

Remove from Moid 

Touch-up 

4* 

Shipping/Warehouse i 

I Vented Air Emissions 

>• 

now 

n-4 

\n 
P.19 

9 9 9 <?i 9 9 9 ????? ? 

BLOCKED 

FAN«C 

BLOCKED BLOCKED 

MrHojIIOn 

BLOCKED 

FAN#D 

STACK #6 

fcahH 

FAN#E 

tota aa raw «EA B*SI OOP 

STACK« mr -I I I I ' <-

T^T^ f%> 

' ''a^1' Wj 

STACK #7 

STACK #4 

ir* <«-« 

STACK #3 

tal Sta, 

BLOCKED 

~d 

—0 

—0 

—0' 

—0 

-0 

-0 

.-0 

-© 

—0 

-0 

STACK. *i 0U_ _ 

'-0 

-0 

Ihb, 

r * 
P.20 

Engineering Environmental 

Consulting Services 

FIGURE 3 Cross-section View of a Typical Waterfall Spray Booth 

S-O 

ADJUST SAWTOOTH ON 

ITSn © FOR PROPE R 

UiVbHEfc PSRFORMtMCS 

n-5 

\°\ 
P.21 

Engineering Environmental 

Consulting Services 

FIGURE 4 Diagram of EPA Method 18 Integrated Bag Sampling Train 

Stack 

Wall 

Filter 

(glass wool) 

Reverse 

(3") Typo 

Pitot Tube 

Rigid Leakproof Container 

n-7 

10 
P.22 

Engineering Environmental 

Consulting Services 

7.4.1.8 Rotameter. O to 100 cc/min, to detect changes in flow rate during sampling. 

7.4.2 Sampling and Analysis. It is suggested that the tester follow the sampling and analysis portion 

of the respective NIOSH method section entitled "Procedure.'' Calibrate the pump and limiting orifice 

flow rate through adsorption tubes with the bubble tube flowmeter before sampling. The sample system 

can be operated as a "recirculating loop" for this operation. Record the ambient temperature and 

barometric pressure. Then, during sampling, use the rotameter to verify that the pump and orifice 

sampling rate remains constant 

Use a sample probe, if required. Minimize the length of flexible tubing between the probe and 

adsorption tubes. Several adsorption tubes can be connected in series, if the extra adsorptive capacity is 

needed. Provide the gas sample to the sample system at a pressure sufficient for the limiting orifice to 

function as a sonic orifice. Record the total time and sample flow rate (or the number of pump strokes), 

the barometric pressure, and ambient temperature. Obtain a total sample volume commensurate with the 

expected concentration^) of the volatile organic(s) present, and recommended sample loading factors 

(weight sample per weight adsorption media). Laboratory* tests prior to actual sampling may be 

necessaiy to predetermine this volume. When more than one organic is present in the emissions, then 

develop relative adsorptive capacity information. If water vapor is present in the sample at 

concentrations above 2 to 3 percent, the adsorptive capacity may be severely reduced. Operate the gas 

chromatograph according to the manufacturer's instructions. After establishing optimum conditions, 

verify and document these conditions during all operations. Analyze the audit samples (see Section 

7.4.43), then the emission samples. Repeat the analysis of each sample until the relative deviation of 

two consecutive injections does not exceed 5 percent 

7.43 Standards and Calibration. The standards can be prepared according to the respective NIOSH 

method. Use a minimum of three different standards; select the concentrations to bracket the expected 

average sample concentration. Perform the calibration before and after each day's sample analyses. 

Prepare the calibration curve by using the least squares method. 

7.4.4 Quality Assurance. 

7.4.4.1 Determination of Desorption Efficiency. During the testing program, determine the desorption 

efficiency in the expected sample concentration range for each batch of adsorption media to be used. 

Use an intemal standard. A minimum desorption efficiency of SO percent shall be obtained. Repeat the 

desorption determination until the relative deviation of two consecutive determinations does not exceed 

S percent. Use die average desorption efficiency of these two consecutive determinations for the 

correction specified in Section 7.4.4.5. If the desorption efficiency of the compound(s) of interest is 

questionable under acmal sampling conditions, use of the Method of Standard Additions may be helpful 

to determine this value. 

7.4.4.2 Determination of Sample Collection Efficiency. For the source samples, analyze the primary 

and backup portions of the adsorption tubes separately. If the backup portion exceeds 10 percent of the 

total amount (primary and back-up), repeat the sampling with a larger sampling portion. 

7.4.4.3 Analysis Audit Immediately before the sample analyses, analyze the two audits in accordance 

with Section 7.4.2. The analysis audit shall agree with the audit concentration within 10 percent 

7.4.4.4 Pump Leak Checks and Volume Flow Rate Checks. Perform both of these checks 

immediately after sampling with all sampling train components in place. Perform all leak-checks 

according to the manufacturer's instructions, and record the results. Use the bubble-tube flowmeter to 

measure the pump volume flow rate with the orifice used in the test sampling, and record the result If 

H-9 

7.1 
P.23 

Engineering Environmental 

Consulting Services 

BL D. Recommended Test Protocol 

The recommended styrene vapor source test protocol for the Aqua Glass Plant is EPA 

Method 18, incorporating NIOSH Method 1501 adsorption tube collection as specified in 

Section 7.4 and adjusted for the expected styrene concentrations. The recommended method 

is henceforth referred to as the "Alternate EPA Method 18." In general, the Alternate Method 

18 protocol uses EPA Method 18 procedures to measure the exhaust stack flow rates with a 

pitot tube/manometer and to measure the sampling flow rates with a precision-metered and 

calibrated sampling train. NIOSH Method 1501 procedures are used to collect and analyze 

the styrene vapor concentration in the exhaust. The actual flow rates through the tubes are 

adjusted to prevent sorbent breakthrough and to ensure that the styrene-to-carbon mass 

loading ratio remains within the validated range. A diagram of the recommended test setup is 

shown in Figure 5. A detailed description of the testing equipment specifications is provided 

in Section II-E below, as part of the QA/QC procedures. 

The following three (3) sets of styrene samples were included as part of this source 

test for the Aqua Glass Plant: 

* Two (2) concurrent ten-hour integrated charcoal tube samples per stack for the eight 

(8) stacks, during one (1) ten-hour production shift 

* Five (5) consecutive two-hour integrated charcoal tube samples per stack for the eight 

(8) stacks, during one (1) ten-hour production shift. Note that these sample run 

concurrently with the ten-hour samples. 

* One (1) ten-hour integrated charcoal tube samples per roof fan for the five (5) 

operational roof fans during one (1) ten-hour production shift 

Test Equipment - This test protocol uses a standard pitot tube & manometer to 

measure exhaust duct velocities, and uses a precision hot-wire anemometer to verify low duct 

velocity measurements. Styrene samples are collected in standard charcoal sample tubes 

using sample flow pumps that are calibrated with a precision rotameter meter. The sample 

pumps are activated by internal timers, which allows for simultaneous starting and stopping of 

all pumps. A single sample pump is connected in series to two (2) charcoal tubes per stack 

(sample replicates) through a calibrated flow manifold. A standard colorimetric detector tube 

is used to measure the approximate styrene concentration in die exhaust duct during samplingsAtmospheric pressure is measured with a portable barometer. The exhaust's dry bulb and wet 

bulb temperatures are measured with a digital thermometer and/or certified glass-bulb 

thermometers. 

H-ll 

2t 
P.24 

Engineering Environmental 

Consulting Services 

Sampling Location - the preferred sampling location is inside the plant building, at 

the suction-side stack sections that lead firom the spray booths to the roof-mounted exhaust 

fans. These indoor locations have a uniformly warm ambient air temperature, which ensures 

proper operation of the sampling equipment and minimizes calibration drift due to 

temperature fluctuations. The suction side of the exhaust duct is also more suited to the 

sample pump back pressure specifications and offers a better flow profile for the pitot tube 

measurements. Stack #1 through Stack #4 will be sampled inside the building, using a 

combination of floor-mounted scaffolding and existing suspended equipment catwalks. Note 

that these locations are within the distance-to-flow-disturbance guidelines specified in Method 

1 and Method 2. 

However, four (4) of the stacks to be tested (Stack #5 to Stack #8) will require 

outdoor sampling locations on the plant roof. Roof-top access is needed because two of these 

stacks consist of multiple exhaust streams that are manifolded together on the roof (two 

separate flows for Stack #6 and three flows for Stack #5) and two of the stacks (Stack #7 and 

Stack #8) cannot be easily accessed from within the building. In order to rninimize the 

effects of cold and windy weather, temporary heated enclosures will be constructed around 

each of these outdoor stacks. These enclosures will be constructed from steel scaffolding 

covered with polyethylene plastic film and heated with small electric heaters, if necessary. 

Note that these locations are also within the distance-to-flow-disturbance guidelines specified 

in Metiiod 1 and Method 2. 

Sample Flow Rate - based upon a 800/200 mg charcoal tube, the sample flow rate 

for each stack sample will be set between 300 and 750 ml/min. The flow rate is adjusted 

within this range to ensure that the styrene-to-carbon mass loading ratio remains within the 

validated range specified in Method 1501 for the expected styrene concentrations and 

sampling intervals. The approximate sampling concentrations will be checked during each 

day of testing using one-minute grab samples taken with standard colorimetric detector tubes. 

NuChemCo has prepared a table of recommended sample flow rates based upon sample 

duration and styrene concentrations in the exhaust This table is shown in Table 2 below [Ref 

- NuChemCo]. 

The following six (6) agencies have adopted or accepted the recommended Method 18 

procedures for stack testing of styrene emissions from fiberglass manufacturing facilities: 

Virginia DAPC - styrene vapor stack testing at three (3) fiberglass manufacturing 

facilities [ref - EES Reports] 

Pennsylvania DEQ - styrene vapor stack testing to show compliance with operating 

pennit for a fiberglass part facility [ref - EES Reports]. 

Missouri DNR - styrene vapor stack testing for fiberglass truck manufacturing facility 

[ref - EES Report]. 

E-13 

23 
P.25 

Engineering Environmental 

Consulting Services 

California SCAQMD - styrene stack testing for a fiberglass manufacturer [ref -EES]. 

i 

Ohio EPA - styrene vapor stack testing at two (2) fiberglass part manufacturing 

facilities [ref - EES Reports]. 

EPA Office of Air and Energy Engineering Research Laboratory, Research 

Triangle Park - Method 18 is currently used to measure styrene emissions at a North 

Carolina bathware facility [ref - Bobby Daniels, Task Officer, EPA, AEERL]. 

II. E. QA/QC Procedures & Analysis of Testing Error 

The quality assurance and quality control (QA/QC) procedures and calculation of 

measurement error for six (6) important test variables are listed in the following sections. 

EL E. 1. Exhaust Flow Rates 

PITOT TUBE & MANOMETER 

The test protocol will use a Dwyer Instruments Model #125-AV inclined manometer, 

or its equivalent, with a 0.0" to 1.00" water column static pressure and a 0.005" scale 

precision, or a Dwyer Instruments Model #125-AV inclined manometer, or its equivalent, 

with a 0.0" to 2.00" water column static pressure and a 0.02" scale precision. The pitot tube 

is a Dwyer model #160-36, or equivalent, stainless steel pitot tube with a 36" insertion length 

that complies with ASHRAE and AMCA specifications. An equivalent "S-type" manometer 

may be substituted- The equation to calculate air velocity from the pitot pressure difference 

reading is: 

air velocity (fpni) = 10962 x A pressure (in wg)05 

air density0-5 [eq 1] 

where the dry air density is given by: 

air density = : 1.325 x barometric press (in Hg) 

air temperature (°R) [eq 2] 

The ASHRAE psychometric tables will be used to correct the dry air density due to 

the relative humidity of the exhaust Assuming standard conditions (using a dry air density of 

0.075), the readings provided by the pitot tube/manometer in the lowest expected velocity 

range of about 1,060 fpm is: 

H-15 

it 
P.26 

Engineering Environmental 

Consulting Services 

IL E. 2. Sample Flow Rate 

The sampling train will use a SKC Model #224-PCXR8 precision sampling pump, or 

its equivalent, to draw a precise sample volume through the charcoal adsorption tube. 

According to the SKC performance specifications, the Model #224-PCXR8 pump has the 

following characteristics [ref - SKC; Operating Instructions for Universal Sample Pump, Model 224-PCXR8; 

Form #37713; Aug 92]: 

TABLE 3 Typical Sample Train Pump Specification 

Flow range -, 1,000 to 5,000 ml/min 

; 100 to 500 ml/min with low flow control 

Flow control - ± 5% set point constant flow 

Flow compensation range: 

750 ml/min 

1,000 

2,000 

2,500 

3,000 

4,000; 

RunTime -

5" to 40" water back 

0" to 40" 

0" to 40" 

0" to 40" 

0" to 35" 

0" to 20" 

8 hr minimum at 4,000 ml/n 

pressure 

tin and 2 

Operating Temperature - -20°C to 45°C (-4°F to 113°F) 

The combined exhaust duct static pressure and charcoal tube pressure drop should not exceed 

these compensation ratings. The sample pump flow accuracy at a sampling rate of one (1) 

liter per minute will be ± 50 ml/minute. 

This test sampling train will also use a Cole-Parmer Instrument Company, Chicago, 

EL, Model 3216-45 precision rotameter, or its equivalent, to QA/QC the flow rate caUbration 

of the sample pumps. Cole-Palmer provides flow meter caUbration data tables [ref - Cole-Palmer 

Document No. 217] for several combinations of tube and float which includes flow meter tube 

#N112-02 at standard conditions of 70°F and 14.70 psia using an 1/8" diameter carboloy float 

(stock #ZC2 with a density of 14.98 g/ml), a #N082-03 at standard conditions of 70°F and 

14.70 psia using an 1/8" diameter glass float with a density of 2.53 g/ml, and #N082-03 at 

standard conditions of 70°F and 14.70 psia using an 1/8" diameter stainless steel float with a 

density of 8.04 g/ml. These calibration curves are Usted in Table 4 below. 

E-17 

Z$ 
P.27 

"•***i^"****i 

Engineering Environmental 

Consulting Services 

The QA/QC procedure for the local barometric pressure readings is provided by 

comparing the local measurement at the plant with the barometric pressure reported at the 

nearby weather recording station, located at the Klamath Falls airport 

IL E. 4. Exhaust Temperature 

A digital thermometer and/or glass bulb thermometer will be used to measure the 

exhaust temperature. Any thermometer with a ± 1% accuracy and a display resolution of 

0.1°C (0.2°F) is suitable. Stack exhaust temperature readings will be recorded at the end of 

each duct traverse. 

The QA/QC bf the temperature measurements wiU be perfonned by comparing the 

simultaneous steady-state temperature readings of the digital thermometer and a fullimmersion glass stem laboratory thermometer with a 0.1°C resolution that meets SAMA and 

NIST requirements for accuracy. If the exhaust exhibits a range of temperatures, a series of 

QA/QC temperature comparisons will be performed at the low, middle, and high temperature 

values within the exhibited range. 

EL E. 5. Relative Humidity 

A digital thennometer and/or glass bulb thermometer also will be used to measure the 

dry-bulb and wet-bulb exhaust temperatures. Any thermometer with a ± 1% accuracy and a 

display resolution of 0.1°C (0.2°F) is suitable. The wet bulb reading is measured after a wet 

"sock" has been placed over the temperature probe. Wet-bulb temperature readings will be 

recorded at the beginning of each duct traverse. 

The QA/QC of the relative humidity measurements wiU be provided by comparing the 

simultaneous steady-state wet-bulb/dry-bulb temperature readings of the digital thennometer 

and a bench top wet-bulb/dry-bulb hygrometer that incorporates two (2) NIST-certified fullimmersion glass stem laboratory thermometers. 

EL E. 6. Styrene Vapor Concentration 

Several sizes of charcoal adsorption tubes are commercially available, as shown in 

Table 5 below. The proper combination of flow tube size and sample flow rate will be 

dependent upon the styrene concentration of the exhaust and the sample duration. For 

relatively high-concentration stack samples, the stack test protocol will use a SKC model 26-

16 mbe with a 200 mg back sorbent section and a 800 mg front sorbent section, as specified 

in Section 7.4.1.6 of EPA Method 18. However, a smaUer tube, such as model 226-01, may 

be used to sample low styrene concentrations. A smaller tube generaUy increases the 

H-19 

2& 
P.28 

Engineering Environmental 

Consulting Services 

A detailed description of the AML GC analysis procedure is available by phone from Mr. 

Chris Case of American Medical Laboratories at (800) 348-1590. 

DETECTOR TUBE EQUIPMENT 

This test setup uses a Kitigawa Model #8014-400A detector tube piston-type pump, or 

its equivalent, to estimate the sample concentration during the stack sampling. The 

corresponding detector tube for styrene vapor is a Matheson Model #158S with a sampUng 

range from 5 to 300 ppm with one stroke, 2.5 to 150 ppm with two strokes, and 10 to 600 

ppm with one-half stroke. 

EL F. Miscellaneous Production Data 

In order to correlate the measured styrene emission rates with the corresponding 

production activity, the foUowing plant production data will be recorded during each day of 

testing: 

* Production shift start and stop times. 

* Number of work breaks; include the start and stop time of each break. 

* Number of units produced and laminate surface area of each unit. 

Also, any modifications to the plant that would affect ventilation flow rates during the testing 

wiU be recorded. This includes: 

Opening and closing of exterior buUding doors. 

Deactivation or activation of ventilation fans. 

Replacement or removal of spray booth filters. 

The number of units produced during a ten-hour work shift is the sum of the foUowing three 

values: 

One-half of the number of units in process at the beginning of the shift 

AU of the units started and completed during the shift 

One-half of the number of units in process at the end of the shift 

n-21 

2.1 
P.29 

Pollutant to be measured: 

Styrene vapor only. 

Engineering Environmental 

Consulting Services 

Fan 

ID 

A 

B 

C 

D 

E 

Fan 

Description 

Maintenance Area 

Finishing Area 

Warehouse Area 

Production Area 

Receiving Area 

Expected 

Flowrate 

(dscfm) 

4,000 

24,000 

30,000 

4,000 

12,000 

Expected Range 

Concentration 

(ppm) 

5-10 

5-10 

5-10 

5-10 

. 5-10 

Test methods 

Exhaust Row Rate -

Barometric Pressure -

Air Temperature -

Relative Humidity -

Styrene Concentration 

& Sample Flow Rate 

EPA Method 1 & EPA Method 2 

EPA Method 18, Section 7.4.1. 

NIST-certified Thermometer 

Wet bulb/Diy bulb Thennometer 

EPA Method 18, using Section 7.4 Absorption Tube 

Procedure, equivalent to NIOSH Method 1501 

Number of sampling repUcates 

One (1) day of testing, consisting of a typical ten-hour workshift: 

Two (2) simultaneous integrated ten-hour samples per stack, for eight (8) 

stacks. 

Five (5) concurrent integrated two-hour samples per stack, for eight (8) stacks, 

taken concurrently with the ten-hour samples. 

One (1) integrated two-hour samples per roof fan, for five (5) roof fans, taken 

concurrently with the ten-hour stack samples. 

m-2 

21 
P.30 

Engineering Environmental 

Consulting Services 

d. The DEQ shaU be notified, in writing, of any changes in source test plans prior 

to testing. 

e. Method-specific quaUty assurance/quaUty control (QA/QC) procedures shaU be 

perfonned to ensure data vaUdity. FuU documentation of the procedures and 

results shaU also be presented in the source test report for review. 

f. The source test report shall be submitted to, the DEQ within thirty days of the 

last day of testing. 

g. Two (2) copies of the completed source test report shaU be sent to the 

department; one (1) to the DEQ Regional Operations staff person responsible 

for the source and the second copy to the Source Testing Coordinator, 

Department of Environmental QuaUty Headquarters in Portland. 

16. Signatures > 

For the Aqua Glass Corporation: 

name ^t e 

title 

For Engineering Environmental: 

name date 

title 

m-4 

ii\ 
Engineering Environmental 

Consulting Services 

FIGURE 6a Performance Curve for Fan #A 

P.31 

LORE N COO K -COMPAN V 

MOOEL NO. 30-LSU TEST NO. 88-160 IMPELLER DIAM 30.13 OUTLET AREA 5.074 

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3 4 6 6- 7 8 8 10 

cri nu tn&&\A \ \ n 1000' S 

11 12 
P.32 

Engineering Environmental 

Consulting Services 

FIGURE 6c Performance Curve for Fan #C 

STEEL UP BUST PROPELLER VENTILATOR * MODEL SUB 

HIGH TEMPERATURE SMOKE CONTROL VENTILATOR - MODEL SUBH 

FAN 

* « £ 

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P.33 

Engineering Environmental 

Consulting Services 

d. The DEQ shall be notified, in writing, of any changes in source test plans prior 

to testing. 

e. Method-specific quality assurance/quality control (QA/QC) procedures shall be 

performed to ensure data validity. Full documentation of the procedures and 

results shall also be presented in the source test report for review. 

f. The source test report shall be submitted to, the DEQ within thirty days of the 

last day of testing. 

g. Two (2) copies of the completed source test report shall be sent to the 

department; one (1) to the DEQ Regional Operations staff person responsible 

for the source and the second copy to the Source Testing Coordinator, 

Department of Environmental Quality Headquarters in Portland. 

16: Signatures'. 

For the Aqua Glass Corporation: 

name date 

title 

For Engineering Environmental: 

name date 

title 

m-4 

3<L 
P.34 

Engineering Environmental 

Consulting Services 

FIGURE 6a Perfonnance Curve for Fan *#A 

LORE N COO K -COMPAN Y 

MODEL NO. 30-LSU TEST NO. 88-160 IMPELLER OIAM 30.13 OUTLET AREA 5.074 

1.75 

1.5 

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CD 

XI 

> 

m 

x 

o 

1 3 

to 

m 

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*£_ 

m 

\ *n 1000'S 
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Consulting Services 

FIGURE 6c Performance Curve for Fan #C 

STEEL UPBLAST PROPELLER VEKTILATOR - MODEL SUB 

HIGH TEMPERATURE SMOKE COKTROL VENTIUTOR - MODEL SUBH 

FAM 

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42887 

11.179 

45S39 

12.763 

44137 

14.491 

SOWS 

11370 

1/2 

CFM 

BHP 

21617 

4.447 

23S07 

S.063 

2S206 

1716 

26789 

6.413 

23324 

7.1 SS 

29841 

7.946 

31371 

1788 

32954 

9.686 

34440 

10.577 

36363 

11.521 

38020 

12.516 

38583 

13.577 

26449 

1171 

29984 

7245 

33071 

1360 

38377 

9.694 

39682 

11J14 

43144 

12.909 

46030 

14.754 

48762 

18.8*11 

SI 

CPM 

BHP 

22SOS 

1440 

24441 

1394 

2*196 

7.171 

28164 

7.890 

29771 

8.856 

31310 

9.778 

32826 

10.752 

34350 

11.778 

35902 

11855 

37S2S 

11874 

29441 

lis? 

33041 

9-04 

36170 

(1_ta2 

38336 

12.644 

42332 

14.782 

44347 

11455 

V4 

CFU 

BHP 

2359S 

7.018 

2S032 

7.834 

27920 

iMi 

29480 

9.797 

31337 

10.797 

32913 

11.853 

M-t-tfl 

12344 

35946 

14.137 

32980 

11.578 

34458 

n m 

38360 

1-1822 

4Z72_l 

16.472 

7/1 

CFM 

BHP 

. 

24628 

6.614 

27423 

9.710 

29472 

10.766 

31315 

11355 

33010 

12.996 

34616 

14.193 

34785 

15.174 

40091 

17.026 

1 

CFM 

BHP 

26641 

10.484 

29090 

11.742 

31181 

12.949 

330S3 

14.184 

<30QM 

17.173 

— i-vw.it.F M euM. FOBV a*>g &tf) « i >___•_• attaa tw . Nrtamno* ntrgi <*> not Mute t» rtrdk, 
P.36 

Engineering Environmental 

Consulting Services 

FIGURE 6e Performance Curve for Fan #E 

LORE N COO K COMPAN V 

MODEL NO. 48-LSU TEST NO. 88-169 IMPELLER DIAM 48.00 OUTLET AREA. 12.83 

CD 

D 

> 

m 

I 

o 

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(/) 

m 

TJ 

o *s 

m 

n 

"0 2 4 6 3 10 IE 1144 I 1B6 '^^ '*J3r"" . a 22 24 °.5 £3 30 32 34 3637 

~ -. A r\oc\ • •**; 
P.37 

State of Oregon 

Department of Environmental Quality Memorandum 

To: Frank Messina: ER-Bend 

From: Thane Jennings 

Subject: Source Test Review Report 

Aqua Glass 

Klamath County 

Source Testers: AGI 

Process: Fiberglass Manufacturer 

Tvpe of Facilitv ! 

Sources not listed which would emit 10 or 

more tons/yr VOC uncontrolled, medium cost 

Permit Number: 

Test Date: 

Report Received: 

Date: January 10, 1995 

"M- *( 

18-0093 

October 24-27, 1994 

January 9, 1995 

SIC 

3088 

Particulate Emissions from Aqui 

Source 

Gel Coat #1 

Gel Coat #2 

First Chopper 

Base Chopper 

Foam Coat 

j Cover Coat 

| Total 

i Glass 

: 

\ (gr/dscf) 

Measured 

0.0002 

0.0002 

0.0002 

0.0003 

0.0007 

0.0002 

Limit 

0.0011 

l^^^§^^.^^B^^l 

Particulate Emissions 

lb/hr 

0.0200 

0.0178 

0.0437 

0.0423 

0.0494 

0.0150 

0.1882 

lb/bathtub unit 

0.0017 

' 0.0011 

0.0015 

0.0018 

0.0016 

0.0005 

0.0068 

• * — 

1 

lb/lb bathtub 

unit 

13.35E-6 

9.63E-6 

12.61E-6 

14.04E-6 

13.36E-6 

4.41E-6 

67.4E-6 

It should be noted that sum of the lbs/unit in the two tables, Particulate Emissions firom Aqua Glass 

and Styrene Emissions from Aqua Glass are not a simple sum of the lbs/unit for each spray booth. 

Gel Coat #1 and Gel Coat #2 are parallel processes, that is each bathtub unit will pass through only 

one of the Gel Coat booths. The attached process diagram shows the flow of bathtub units. The 

The sum of the particulate and styrene for the spray booths in Lbs/unit is calculated by averaging 

the lbs/unit from Gel Coat #1 and Gel Coat ffl 

3(o^' 
P.38 

Memo To: Frank Messina 

January 10, 1995 

Page 2 

This report has been reviewed and it has been determined that the test methods conducted, data 

provided, and calculations perfonned are sufficient for evaluating the compliance of this source for 

permitted parameters. Average bathtub unit weight is 124 lbs/unit. Particulate emissions from this 

source are assumed to be less than 10 /x in diameter. Particulate matter was below the performance 

standard of 0.0011 grains/dscf. The particulate matter mass emission rate was below the short and 

long tenn PSELs. The test results show styrene emissions exceed the daily and annual Plant Site 

Emission Limits, (PSELs). The opacity was not measured, as it is assumed to be zero because of the 

low particulate concentration, opacity was confirmed to be zero during the source test by the DEQ 

observer, Thane Jennings. 

These source tests were conducted to satisfy the requirements of condition 10-14 for demonstrating 

compliance with conditions 2, 3, and 6-8 of the ACDP issued on January 20, 1993. The testing was 

performed in accordance with the methods approved in. the source test plan and QA/QC 

documentation was sufficient for evaluating the validity of the data. 

The permit states that the average ambient concentration of styrene samples taken from 5 different 

sampling locations representative of fugitive air that would seep out from the plant, shall not exceed 

5 ppm. The average of the 5 ambient samples was 15 ppm. The shipping and receiving area was 

the only one of the five sampling locations below five ppm, at 3.4 ppm. An informal styrene 

survey of the plant was perfonned by DEQ staff on Oct. 24 using a photo ionization detector, 

(PID), the PID was calibrated with isobutylene and a response factor of 0.5 was used to correlate 

the instrument response from isobutylene to styrene. PID readings taken on the plant floor ranged 

from 30 to 140 ppm, the highest reading was taken inside the heat room. Rooftop readings ranged 

from 1 ppm to 12 ppm taken at the northeast corner of the building. PID readings were taken at the 

Gelcoat #1 and il stacks, ffl stack varied from 250 to 400 ppm and ffl stack from 250 to 470 ppm. 

Styrene concentration was measured at seven exhaust fan outlets at the rooftop. The results are 

shown in the table below and a map of the rooftop showing the exhaust fan location is included with 

this memo. 

3<l 
Memo To: Frank Messina 

January 10, 1995 

Page 3 

P.39 

Rooftop Exhaust Fan Styrene Concentration 

Exhaust Fan 

EF-2 

EF-3 

EF-4 

EF-11 

EF-34 

EF-? 

Maintenance 

Concentration 

(ppm v/v) 

30-50 

15 

20 

13 

70 

70 

100 

Stvrene Emissions from Aqua Glass 

Source Flowrate 

(DSCFM) 

Styrene Emissions 

ppm (v/v) lb/hr lb/bathtub unit lb/lb bathtub unit 

Gel Coat ffl 13335 210 45.5 3.91 0.031 

Gel Coat ffl 13467 223 48.8 3.23 0.027 

First Chopper 26214 233 99.2 3.42 0.028 

Base Chopper 18069 65 19.0 0.78 0.006 

Foam Coat 7502 50 6.1 0.20 0.002 

Cover Coat 10326 193 32.5 1.11 0.009 

Heat Room 

Total 

8184 65 8.6 

259.7 

0.29 

9.4 

0.002 

0.105 

3% 
P.40 

Memo To: Frank Messina 

January 10, 1995 

Page 4 

Summary of Ambient Styrene Sampling 

Production Area Location 

i 

1. Touch-up Area 

2. Maintenance Area 

3. Shipping and Receiving 

4. Wood Shop j 

5. Exhaust Fan #3 

Average 

Ambient Concentration 

(ppm y/v) 

5.4 

43 

3.4 

15 

7.6 

15 

During the month of October, the production rate was 8,240 bathtub units which is roughly 40% of 

the planned production capacity. During the air source test, production was 40% to 50% of the 

design capacity. The PSELs shown in the table are calculated using the emission factors from the 

air source test and the design capacity of 250,000 bathtub units per year. Actual emissions for 1994 

are as follows: 

Particulate 

(54,137 bathtub units year * 0.0068 lbs PM unit)/(250 days/year * 20 hrs/day) = 0.07 lbs/hr 

54,137 bathtub units * 0.0068 lbs PM unit/2000 lbs/ton = 0.18 tons/year 

Stvrene 

(54,137 bathtub units/250 days) * 9.4 lbs/unit = 2035 lbs/day 

54,137 bathtub units * 9.4 lbs styrene/unit/2000 lbs/ton = 254 tons/year 

If Aqua Glass were to continue operating at 40% of capacity in 1995 they would exceed their long 

term PSEL for styrene in 50 days of operation. 

(93 tons styrene * 2000 lbs/ton)/(1000 unit/day * 0.40 capacity * 9.4 lbs styrene/unit) = 50 days 

Particulate emissions are controlled by a water curtain and a dry disposable filter.. Styrene and 

VOC emissions are uncontrolled 

3V 
P.41 

Memo To: Frank Messina 

January 10, 1995 

Page 5 

Short and Lone Term PSELs 

Pollutant PSEL 

Measured Limit 

Particulate Matter < 10 p. 

lbs/hour 

tons/year 

0.28 

0.85 

1.65 

4.9 

Styrene 

lbs/day 

tons/year 

9,400 

1,175 

744 

93 

Aqua Glass is out of compliance with the short and long term styrene PSELs for two reasons; 

emission factors measured during this source test are higher than those values reported to DEQ by 

Aqua Glass, and Aqua Glass seems to have underestimated the amount of resin and gel coat used to 

produce a bath/shower unit. To illustrate the deficiencies in the information used to calculate the 

styrene PSELs, I will use the 1993 annual report and EPA AP-42 emission factors to calculate 1993 

emissions for the Aqua Glass facility. 

1993 Stvrene Emissions 

EPA AP-42 uses the following range of emission factors for spray layup in the polyester resin 

nroduct fabrication process. 

Process 

Spray Layup 

Resin 

Non-Vapor 

Suppressed 

0.09-0.13 

Vapor 

Suppressed 

0.03-0.09 

Gel Coat 

Non-Vapor 

Suppressed 

0.26-0.35 

Vapor 

Suppressed 

0.08-0.25 

The following calculation uses the higher range of EPA AP-42 styrene emission factors for vapor 

suppressed resins and gelcoat, which would, seem to more closely match the Aqua Glass styrene 

emissions than the lower range of emission factors. Resin styrene content of 0.31 is taken from the 

1993 Aqua Glass annual report,. EPA AP-42 reports a value of 0.43. Gel coat, resin ahd styrene 

usage are all taken from the 1993 Aqua Glass annual report. 

<-VD 
P.42 

Memo To: Frank Messina 

January 10, 1995 

Page 6 

22,277 lbs gel coat*(0.35 lb styrene/lb gel coat)*(0.25 lbs styrene emitted/lb styrene) = 1,949 lbs 

68,900 lbs resin*(0.31 lb styrene/lb resin)*(0.09 lb styrene emitted/lb styrene) = 1,922 lbs 

440 lbs styrene - = 440 lbs 

683 bathtub units produced in 1993 =4,311 lbs 

4,311 lbs styrene/683 units =• 6.3 lbs styrene/unit 

If this emission factor was used to predict future emissions, Aqua glass would emit 789 tons of 

styrene per year at design capacity, which is about 8 times higher than DEQ predicted for this 

facility. 2733 tons/year of styrene per year is the Aqua Glass styrene usage contained in the detail 

sheet of the air contaminant discharge permit, (ACDP). Dividing the styrene usage by the design 

capacity yields value of 22 lbs of styrene applied to each unit. The Aqua Glass consultant Bill 

Griggs stated in a telephone conversation that Aqua Glass uses a 24.5 lbs of styrene/bathtub unit. 

Bill Griggs also stated in the same telephone conversation that the source test shows 40% of their 

styrene usage is emitted to the air based on the source test report. Using Bill's value of 40% 

styrene emitted/used yields a value of 23.4 lbs. of styrene applied to each bathtub unit. Yet in 1993 

Aqua Glass applied 43 lbs of styrene per unit, a number which is roughly double the value in the 

ACDP detail sheet. 

22,277 lbs gel coat * 0.35 lb styrene/lb gel coat = 7,797 lbs styrene 

68,900 lbs resin * (0.31 lb styrene/lb resin) = 21,359 lbs styrene 

440 lbs styrene =• 440 lbs stvrene 

= 29,596 lbs styrene 

29,596 lbs styrene/683 units = 43.3 lbs styrene/bathtub unit 

Recommendations 

The styrene emission factor for the 1994 air source test was 9.4 lbs styrene/bathtub unit, which is 

33% higher than the value calculated using the 1993 annual report and the EPA AP-42 emission 

factors. Another Oregon facility that produces hot-tubs and shower units emits 9 lbs styrene/unit. 

There is definitely room for improvement at Aqua Glass. Bill Griggs has stated that Aqua Glass 

cunentiy uses the following process changes and materials substitution to reduce styrene emissions; 

vapor suppressed resins and gel coat, and airless spray guns. 

Since Aqua Glass already uses the above technologies, add-on control equipment such as thennal 

oxidation seems to be the best method available to reduce vapor emissions from styrene. Aqua 

Glass would need to improve their VOC capture efficiency if they were to receive the benefit of 

installing a thermal oxidizer. Besides thermal oxidation there are emerging technologies such as 

chillers which recover the styrene so it can be reused. 

<q-i 
P.43 

Memo To: Frank Messina 

Januaiy 10, 1995 

Page 7 

Fugitive emissions were not taken into account during the air dispersion modeling originally 

performed at the Aqua Glass facility. It is obvious from the odor complaints, the air source test 

performed by AGI and from the survey performed by DEQ that fugitive emissions are a problem at 

Aqua Glass. FacUity emissions should be modeled again with the fugitive emission sources included 

in the air dispersion model. 

To maintain indoor air quality, the Aqua Glass facility was designed for a combined discharge 

flowrate of 175,000 dscfm (7 stacks x 25,000 dscfm). However, the source test data show a 

combined discharge flowrate of 97,000 dscfm. One way for Aqua Glass to improve their styrene 

capture efficiency and; decrease the ambient styrene concentration would be to increase fan speed, 

at each of the 7 stacks except for the first chopper spray booth stack which had a stack flowrate of 

26,000 dscfm. This would not, however, decrease overall styrene emissions. 

cc: John Hector: DEQ: ER-Bend 

Dave Kauth: DEQr ER-Bend 

Peter Brewer: DEQ: ER-Bend 

Aii Nikukar: DEQ: HQ 

4<L 
z 

Heat Room 

Clean Moid 

Gel Coat #1 Gel Coat #2 

First Chopper 

\ / 

Base Chopper 

Foam Coat 

Cover Coat 

Remove from Mold 

I 

Touch-up 

Shipping/Warehouse 

Legend 

Vented Air Emissions 

-__-________«_____Ba—«"J£> 

Process Row 

AGI 

TECHNOLOGIES 

30.-M52.001 

PROCESS DIAGRAM 

Aqua Glass 

Klamath Falls, Oregon 

ROB 11 Nov 94 

REVIUdJ 

RGURE 

1 

4-3 
...a.aa pollutant Level Data •••••••• 

AQUA GLASS WESTERN, INC. 24-OCT-94 

Unit: Gel Coat #2 

4<V 

P.45 

_r_ No. 

Avg. 

.00007 .00016 .00018 .00014 

gr/dscf 

.0009 .0007 .0015 .001 

lb/bathtub unit 

.0119 .0109 .0246 .0158 

lb/hr 

tyrene 2.85 3.11 3.74 3.23 

lb/bathtub unit 

Styrene 39.9 46.7 59.8 48.8 

lb/hr 

Styrene 180 220 270 223 

ppm 
P.46 

Source Test Report Detail Sheet 

Tested: 24-OCT-94 by AGI Technologiet 

Approved for Agency ute 

Source : 18 - 0093 AQUA GLASS WESTERN. IMC. 

KLAMATH PALLS 

Uni t Tested: Gel Coat »2 

Uni t Type: Spray Booth I Gel Coat 1 

Contro l Device(a): Fabric Filte r , Hater Curtain 

Scack: Diameter: 34.0 inches 

Run Level Data 

Run No. 

Velocit y (FPM) 

Flow (DSCPM) 

Temperatur e (F) 

%H20 

%C02 

Process Race 

Contro l Data 

1 

2S17 

13653 

66 

1 . 3 

. 0 

14 

Bathtub unic/h r 

4 . 7 

i n H20 

2 

2389 

13091 

66 

-9 

. 0 

IS 

Bathtub unit/h r 

4 . 6 

i n H20 

3 

2S00 

13656 

62 

1.0 

. 0 

16 

Bathtub unit/h r 

4 . 6 

i n H20 

Avg 

2469 

13467 

IS 

1 . 1 

. 0 

IS 

45 
P.47 

Source Teat Report Detail Sheet 

Tested: 25-OCT-94 by AGI Technologies 

Approved for Agency use 

Souree: 18 -.0093 AQ0A GLASS WESTERN, INC. 

KLAMATH FALLS I 

Unit Tested: First Chopper 

Unit Type: Spray Booth t Chopper-] 

Control Device(s): Fabric Filter , Water Curtain 

Stack: Diameter: 34.0 inches 

Run Level Data 

Run No. 

Velocity (FPM) 

Flow (DSCFM) 

Temperature (F) 

%H20 

%C02 

Process Rate 

Control Data 

1 

4957 

26571 

71 

1.3 

.0 

31 . 

Bathtub units/hr 

4.9 

in H20 

2 

4955 ' 

26280 

75 

1.7 

.0 

25 

Bathtub 

4.8 

in H20 

units/hr 

3 

4812 

25792 

70 

I.S 

.0 

32 

Bathtub units/hr 

5 

in H20 

Avg 

4908 

26214 

72 

1.5 

.0 

29 

44 
....... pollutant Level Data •••••••• 

AQUA GLASS WESTERN, INC. 25-OCT-94 

Unit: First Chopper 

un No. .1 Avg. 

M .00012 .00027 .0002 .0002 

gr/dscf 

•M .0008 .0024 .0014 .0015 

lb/bathtub unit 

>M .0263 .0608 .0439 .0437 

lb/hr 

Styrene 3.34 3.92 3.01 3.42 

lb/bathtub unit 

Styrene 103.4 98. 96.2 99.2 

lb/hr 

Styrene 240 230 230 233 

pp« 

4-1 
P.49 

Source Test Report Detail Sheet 

Tested: 24-0CT-94 by AGI Technologies 

Approved for Agency use 

Source: 18 • 0093 AQUA GLASS WESTERN, INC. 

KLAMATH FALLS 

Unit Tested: Gel Coat #1 

Unit Type: Spray Booth - [ Gel Coat ] 

Control Device(s): Fabric Filter , Hater Curtain 

Stack: Diameter: 34.0 inches 

Run Level Data 

Run No. 

Velocity (FPM) 

Flow (DSCFM) 

Temperature (F) 

UQO 

%C02 

Process Rate 

Control Data 

1 

2385 

13007 

63 

1.2 

.0 

11 

bathtubs/hr 

S.5 

in H20 

2S51 

13783 

68 

1.3 

.0 

11 

bach cubs/hr 

4.8 

in H20 

2431 

13215 

66 

1.1 

.0 

13 . . 

bathtubs/hr 

4.9 

in H20 

Avg 

2456 

13335 

66 

1.2 

.0 

12 

<*T> 
»«•»•» pollutant Level Data •••••••• 

AQUA GLASS WESTERN, INC. 24-OCT-94 

Unit: Gel Coat »1 

iM\ 

P.50 

n No. Avg. 

.00015 .00022 .0002 .00019 

gr/dscf 

: 0015 .0022 .0018 .0018 

lb/bathtub unit 

.0168 .0243 .0232 .0214 

lb/hr 

:yrene 3.64 4.47 3.63 3.91 

lb/bathtub unit 

-yrene 40.1 49.2 47.2 45.5 

lb/hr 

tyrene 190 220 220 210 

ppm 
>•••••• pollutant Level Data •**••*•• 

AQUA GLASS HESTERN, INC. 26-OCT-94 

Unit*. Base Chopper 

Iun No. 1 Avg. 

PH .00019 .00032 .00032 .00028 

gr/dscf 

?M .0011 .0017 .0025 .0018 

lb/bathtub unit 

?M .0277 .0499 .0494 .0423 

lb/hr 

Styrene .48 .84 1.01 .78 

lb/bathtub unit 

Styrene 12.5 24.4 20.2 19 

lb/hr 

Styrene 44 82 68 65 

ppm 

, ^ D 

P.51 
P.52 

. » 

Source Test Report Detail Sheet 

Tested: 27-0CT-94 by AGI Technologies 

Approved for Agency use 

Source: 18 r 0093 AQUA GLASS WESTERN, INC. 

KLAMATH FALLS 

Unit Tested: Heat Room 

Unit Type: Curing Room [ Fiberglass 1 

Stack: Diameter: 28.0 inches 

Run Level Data 

Run No. 

Velocity (PPM) 

Flow (DSCFM) 

Temperature (F) 

%H20 

%C02 

Process Rate 

Control Data 

1 

2349 

8184 

94 

1.2 

.0 

30 

Bathtub Units/hr 

2 

2349 

8184 

94 

1.2 

.0 

30 

Bathtub Units/hr 

Avg 

2349 

8184 

94 

1.2 

.0 

30 

5\ 
....... pollutant Level Data •••••••• 

AQUA GLASS WESTERN, INC. 27-OCT-94 

Unit: Cover Coat 

'.un No. 1 ' Avg. 

.00013 .00017 .00019 .00016 

gr/dscf 

?M .0004 .0005 .0007 .0005 

lb/bathtub unit 

?M .0118 .0148 .0184 .01S 

lb/hr 

Styrene . 99 .83 1.52 1.11 

lb/bathtub unit 

Styrene 31.7 24.9 41 32.5 

lb/hr 

Styrene 200 150 230 193 

ppm 

s'L 

P.53 
>••••• • pollutan t Leve l Daca ••••••• « 

AQUA GLASS WESTERN. INC. 26-OCT-94 

Unit: Foam Coat 

Run No. Avg. 

.0011 3 .000 4 .00046 .0006 6 

gr/dsc f 

PM '.002 8 .0011 .0011 .001 7 

lb/bachtu b uni t 

PM .083 4 .0296 .035 1 .049 4 

lb/h r 

Styren e .1 9 . 1 9 .23 . 2 

lb/bathtu b uni t 

Styren e 5. 8 7 . 6 6 . 1 

lb/h r 

Styren e 48 42 61 SO 

ppm 

S3 

P.54 
P.55 

0-

0-

0-

0-

©-

0-

0-

0-

©-

0-

©-

0-

0-

io?^99n??? t 

a 

I 

Q 

V.D 

i 

a 

I 

Q 

I 

a 

«_ 

LJ 

5 

•V 

I 

i° 

/ i B 

r 

SP& 

So 

P 

•'it £ 

.« o $ i 

1 $ $ § 

a 

SU 
P.56 

Source Test Report Detail Sheet 

Tested: 26-OCT-94 by AGI Technologies 

Approved for Agency use 

Source : 18 -.0093 AQUA GLASS WESTERN, INC. 

KLAMATH FALLS 

Uni t Tested: Base Chopper 

Uni c Type: Spray Booth [ Chopper ] 

Concrol Device(s): Fabric Filte r , Water Curtain 

Stack: Diameter: 34.0 inches 

Run Level Data 

Run No. 

Velocity (FPM) 

Flow (DSCFM) 

Temperature (F) 

*H20 

%C02 

Process Rate 

Control Data 

1 

3218 

17S8S 

61 

1.2 

.0 

26 

Bathtub - units/hr 

4.8 

in H20 

2 

3389 

1832S 

66 

1.3 

.0 

29 

Bathtub units/hr 

5.3 

in H20 

Avg 

3413 

18298 

70 

1.4 

.0 

20 

Bathcub 

4.8 

in K20 

units/hr 

3340 

18069 

66 

1.3 

.0 

25 

SS 
P.57 

Source Test Report Detail Sheet 

Tested: 26-OCT-94 by AGI Technologies 

Approved for Agency use 

Source : 18 -.0093 AQUA GLASS WESTERN, INC. 

KLAMATH FALLS 

Urtit Tested: Foam Coat 

Uni c Type: Spray Booch [ Foam Coat ] 

Scack : Diameter: 24.0 inches 

Run Level Data 

R un No . 

Velocit y (FPM) 

Flo w (DSCFM) 

Temperatur e (F) 

%H20 

*C02 

Proces s Rate 

Contro l Data 

1 

2856 

7447 

87 

.6 

. 0 

30 

Bathtub Units/h r 

Avg 

2112 2978 2882 

7333 7726 7502 

87 88 87 

.6 .9 .7 

.0 .0 .0 

27 33 30 

Bathtub units/hr Bathtub Units/hr 

5(b 
P.58 

Source Test Reporc Detail Sheet 

Tested: 27-OCT-94 by AGI Technologies 

Approved for Agency use 

Source: 18 - 0093 AQUA GLASS WESTERN, INC. 

KLAMATH FALLS 

Onic Tested: Cover Coat 

OoiC Type: Spray Booth ( Cover Coat 1 

Stack: Diameter: 34.0 inches 

Run Level Data 

Run No. 

Velocit y (FPM) 

Flo w (DSCFM) 

Temperatur e (F) 

%K20 

%C02 

Proces a Rate 

Concro l Daca 

1 

1804 

9770 

65 

1 . 3 

. 0 

32 

BachCub unics/h r 

6 

i n H20 

Avg 

1898 2042 19X5 

1021S 10993 10326 

67 67 66 

1.5 I.S 1.4 

.0 .0 .0 

30 30 31 

Bathtub unics/hr BachCub uniCs/hr 

S.9 5.4 

in H20 in H20 

51 
P.59 

....... Pollutant Level Data •«•**••* 

AQOA GLASS WESTERN, INC. 27-OCT-94 

Unit: Heat Rooo 

N o . 

Avg. 

-_rex»e .22 .35 .29 

lb/bathtub unit 

'-cene 6.6 10.5 8.6 

lb/hr 

^-rene SO 79 65 

ppm 

<£