p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

;3k-Sr-£ 

Document Number: 

0^4)JfceHigDocket Number: 

A-94-52 

Printed 7/3/2008 8:05:48 AM Sheet 24 of 56 
A- ^-5 ^ 

MEMORANDUM 

P.2 

/irldM<>/. 7 

TO: 

FROM: 

DATE: 

Madeleine Strum 

U.S. EPA/ESD/CCPG 

Greg LaFlam and Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

October 17,1995 

L:\N404 

SUBJECT: Industry Description Memorandum 

'JAN 1 92001 

EPAAir,nr.i~<r T 

This memorandum contains the final version of the industry description memorandum, 

as described under task 7 in PES's revised work plan dated August 10, 1995. Comments from 

the September 27 pre-MACT team meeting about the cutoff for major sources have been 

incorporated. 

2.0 DESCRIPTION OF THE AFFECTED INDUSTRY 

Introduction to industry description.1 The reinforced plastic composites industry 

manufactures products from cured, cross-linked resins, usually in combination with reinforcing 

agents and inorganic fillers. This industry produces a wide variety of products traversing such 

market segments as transportation, construction, electronics, consumer products, marine, and 

aerospace. This diverse source category encompasses as many as 33 Standard Industrial 

Classification (SIC) codes.2-

3

 ^^^^^^^^^^^ha s been specificaUy excluded 

from this rule development effort and%i^^|^i^^isi^ttk^ i Plastics are divided into 

two major groups known as thermoset and thermoplastic. Once cured into a solid form, 

thermoset materials remain a hard solid. Thermoplastics, on the other hand, can be melted 

numerous tunes through the application of heat. ^^im^K^^laMW^®»si^!sourc? | 

||§illlligii®ii3MSg^KSte - Thermoset resins are usually liquids or low 

melting point solids in their initial form. In the production of finished goods, thermosetting 
resins are cured into a solid by use of a catalyst, heat, or a combination of both. 

2.1 GENERAL DESCRIPTION 

P.3 

' V. 

2.1.1 Types of industrial groups included.2-

3

 The SIC codes included in the reinforced 

plastic composites source category were determined by searching the toxic release inventory 

system (TRIS) data base for facilities emitting styrene, a major hazardous air pollutant (RAP) 

emitted by this source category. The TRIS data base identified a total set of 232 SIC codes 

under the poUutant styrene. Codes were deleted for categories that clearly did not fit the 

reinforced plastic composites source category. jg^j^maM^jSl.§jrcS^ contain facilities 

involved in the production of plastic composites. 2§i^^ i it is cautioned that ^S^MIiJS^M^ 

t

ti^|^y.afamund«qth^ In addition, there could 

be facilities not encompassed by these 33 SIC codes that may use thermoset resins in their 

operations. Table 2-1 shows a table ofthe 33 SIC codes potentiaUy covered under the plastic 

composites NESHAP. 

2.1.2 Number of sources.2-

4

 The distribution of sources in the reinforced plastic 

composites source category by SIC code is also shown in Table 2-1. The majority of the 

sources tfbfaiiSSfct&kS!^ which classifies 

misceUaneous plastics products. SIC code 307 is an old code used in the 1972 edition of the 

Standard Industrial Classification Manual3, but TRIS still includes several facilities with this 

code. Approximately^^gpt of the sources included in the composites industry are 

classified tttK^f/SKBBB^ wnich applies to motor vehicles and motor vehicle equipment. 

The remaining 

Table 2-2 shows a complete list of the three-digit SIC codes for this source category 

and their definitions. 
TABLE 2-1 

STYRENE SOURCES OBTAINED FROM THE 1993 SURVEY AND 1992 TRIS

 M 

33 SIC Codes Covered Under Plastic Composites N.ESHAP 

P.4 

• ^ 

G&isMr 

Q^ \ 

SWSJWAA 

-" / 

s 

CffWf J 

(S 

1 

WfffhW.AL 

SIC 

Code 

2434 

2511 

. 3079° 

^083^ 

C5684X 

^3Q87) 

f308JP 

r^08^ 

3281 

3296 

3365 

3499 

rlS) 

3612 

3621 

3647 

^37Jp 

^32£ 

^371 ^ 

^715 ) 

Title 

Wood Kitchen Cabinets 

Wood Household Furniture 

Plastics Products, NEC 

Laminated Plastics 

Plastics Pipe 

Custom Compound Resins 

Plastics Plumbing Fixtures 

Plastics Products, NEC 

Cut Stone and Stone Products 

Mineral Wool 

Aluminum Foundries 

Fabricated Metal Products, NEC 

Oil/Gas Field Machinery/Equip. 

Power Transformers 

Motors and Generators 

Vehicular Lighting Equipment 

Motor Veh./Pass. Car Bodies 

1

 Truck and Bus Bodies 

J Motor Veh. Parts/Accessories 

Truck Trailers 

Total 

Facilitie 

s 

1 

1 

60 

32 

8 

27 

107 

245 

9 

2 

2 

2 

1 

3 

1 

2 

3 

13 

14 

1 

Major 

Sources• 

0 

1 

24 

12 

3 

11 

41 

129 

3 

1 

2 

2 

1 

1 

0 

1 

1 

9 

6 

1 

HAP Emissions for 

Major Sources from 

1993 Survey and 

1992 TRIS Data for 

Styrene (tons)b 

0 

12 

1,081 

742 

40 

465 

4,929 

9,763 

92 

1,613 

32 

46 

11 

48 

0 

16 

37 

376 

185 

96 
P.5 

TABLE 2-1 (Concluded) 

wfm} 

^ym) 

3*v 

3743 

3792 

3795 

3949 

3965 

3993 

3998 

3999 

4036 

I 8734 

| 

Motor Homes 

Aircraft 

' Aircraft Parts/Equipment, NEC 

RaUroad Equipment 

Travel TraUers/Campers 

Tanks/Tank Components 

Sporting/Athletic Goods, NEC 

Fasteners, Buttons, Etc. 

Signs/Advertising Specialties 

d 

Manufacturing Industries, NEC 

d 

Testing Laboratories 

TOTAL 

6 

1 

1 

1 

18 

1 

8 

3 

1 

3 

23 

1 

1 

602 

5 

1 

1 

1 

13 

1 

3 

0 

1 

2 

12 

0 

0 

291 

173 

22 

28 

128 

510 

77 

64 

0 

56 

30 

359 

0 0

 1 

21,031 1 

* Major sources in this table are considered to be open molding facilities (e.g., facilities conducting gel coating, 

sprayup, hand layup, or filament winding) with more than 4.34 tons of HAP emissions per year and other nonopen molding facilities with more than 10 tons per year of styrene emissions as reported in the 1993 industry 

survey or 1992 TRIS. If survey information was incomplete or unavailable 1992 TRIS data was used to 

detennine die facility's emissions. The reason for choosing a lower cutoff for open molding facilities is that 

recent studies have shown that EPA's emission factor document, AP-42, is likely to underestimate emissions 

for open molding operations by a factor of 2.3. Since many facilities use AP-42 emission factors to calculate 

their emissions, a safety factor is needed to ensure that all major sources are included. 

b

 HAP emissions information was taken from the 1993 industry survey. When survey information was 

unavailable, 1992 TRIS data were used. As explained under footnote a, emissions for open molding facilities 

were multiplied by a factor of 2.3. Since TRIS data do not identify the process used, it was assumed that all 

facilities for which only TRIS data were available engaged in open molding operations. Therefore, facilities 

with TRIS emissions of more than 4.34 tons of styrene per year were considered major sources. 

c

 SIC code 3079 was used in the 1972 edition, but was eliminated in the 1987 edition. TRIS nonetheless 

includes several facilities with this code. While code 3079 has the same title as "new' code 3089, none of the 

TRIS facilities listed under 3079 also appear under 3089. 

d

 SIC codes 3998 and 4036 were not used in the 1972 or 1987 edition, but TRIS includes facilities with these 

codes. 
P.6 

TABLE 2-2 

LIST OF THREE-DIGIT SIC CODES AND DESCRIPTION POSSIBLY INCLUDED IN 

REINFORCED PLASTIC COMPOSITES INDUSTRY "* 

SIC Code DESCRIPTION 

243 MUlwork, Veneer, Plywood, And Structural Wood Members 

251 Household Furniture 

m Miscellaneous Plastics Products (Old Category) 

+\ 29** 'ftftfceiianeous Plastics Products 

Cut Stone And Stone Products 

329 Abrasive, Asbestos, And MisceUaneous NonmetaUic Mineral Products 

336 Nonferrous Foundries 

349 Miscellaneous Fabricated Metal Products 

353 Construction, Mining, And Materials Handling 

Machinery And Equipment 

361 Electric Transmission And Distribution Equipment 

362 Electrical Industrial Apparatus 

• Electrical Lighting And Wiring Equipment 

•H ^Motor Vehicles And Motor Vehicle Equipment 

Aircraft And Parts 

Railroad Equipment 

MisceUaneous Transportation Equipment 

DoUs, Toys, Games And Sporting And Athletics Goods 

Costume Jewelry, Costume Novelties, Buttons, And Miscellaneous 

Notions, Except Precious Metal ' 

Miscellaneous Manufacturing Industries 

Based on styrene emissions and subsequent deletion of clearly inapplicable categories 

d ^U^> \*\% ^^-iW4 
P.7 

2.1.3 Geographic location.2 The gec^rapmc4<rations of major and area sources 

possibly involved in the reinforced plastic composites industry are shown in Table 2-3. The 

geographic information was obtained from die 1993 industry screening survey and 1992 TRIS 

Sgniga^f^rfggaor WmmWS^mtW^^J^^^^^^^ ^ Sin^AP-4^3jjpearsto 

underestimate emissions for open molding sources by a factor of 2.3, WlWHBI^^^ ^ 

*SSGfS. The 4.34 ton cutoff for open molding operations was determined by dividing the 

cutoff for a major source (10 tons) by 2.3, which appears to be the factor by which AP-24 

underestimates open molding emissions. Table 2-3 shows a large number of facUities located 

K57), i£f^ p (51), an4J^§&(45). fgj^nM^l^l*i»iii5^fi l 

~ The largest number of 

non-major sources is located in Ohio (29), foUowed by California (25), and Florida and North 

Carolina with 20 facUities each. 
TABLE 2-3 

DISTRIBUTION OF MAJOR AND AREA SOURCES BY STATE2-

3 

P.8 

STATE 

Alabama 

Arkansas 

Arizona 

| CaUfornia 

| Colorado 

| Delaware 

1 Florida 

1 Georgia 

| Hawaii 

Idaho 

IUinois 

Indiana 

Iowa 

1 Kansas 

1 Kentucky 

\ Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan 

Minnesota 

NUMBER OF 

MAJOR SOURCES 

3 

3 

2 

26 

0 

1 

10 

7 

0 

2 

17 

38 

5 

10 

5 

3 

1 

2 

0 

11 

9 

NUMBER OF 

NON-MAJOR 

SOURCES 

11 

4 

4 

25 

3 

4 

20 

14 

2 

2 

12 

19 

6 

4 

7 

2 

2 

4 

3 

19 

9 

TOT.AL 

14 

7 

6 

51 

3 

5 1 

30 I 

21 

2 

4 

29 

57 

11 

14 

12 

5 

3 

6 1 

3 

30 

18 I 
TABLE 2-3 (Concluded) 

_E9_ 

Mississippi 

Missouri 

Nebraska 

Nevada 

New Hampshire 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Puerto Rico 

Rhode Island 

South Carolina 

South Dakota 

Tennessee 

Texas 

Utah 

Virginia 

Washington 

West Virginia 

Wisconsin 

TOTALS 

1 

5 

4 

1 

1 

0 

0 

7 

12 

1 

35 

4 

9 

14 

0 

0 

2 

2 

11 

27 

3 

3 

12 

1 

11 

321 

5 

6 

4 

0 

2 

7 

2 

12 

20 

1 

29 

3 

4 

19 

1 

2 

12 

1 

7 

18 

2 

7 

10 

3 

15 

368 

6 

11 

8 

1 

3 

7 

2 

19 

32 

2 

64 

7 

13 

33 

1 

2 

14 1 

3 | 

18 | 

45 

5 

10 

22 

4 

26 

689 
P.10 

2.1.4 Employment.3 The distribution of workforce size by facility is shown in Table 

2-4. Employment data were obtained from the 1993 industry screening survey. In this survey 

facilities were asked to report their number of employees in ranges (0-100; 101-250; 251-500; 

501-750; 751-1,000; 1,001-1,500; and > 1,500). From me total facilities responding, about 

half of the facilities (363) did report discrete numbers for employees in their survey response. 

Since the ranges asked for in the survey were rather broad, flBBBBflHQHHBI 

facUities. It was assumed diat die facUities mat reported discrete numbers were a good 

representation of the industry as a whole. According to the survey information, jHBSB^P 

ggggHig^t of the 363 facUities #^lfeatJ^S3ftfes!emplo^es. approximately0_WjE&L of die 

employees, whUe only one facUity each reported 600 and 1440 employees. 

2.1.5 Distribution bv process.2-

3

 There are a number of different processes that can be 

used to produce reinforced plastic composites. A full description of the different processes is 

provided in the process description and emission points memorandum.6 The most common 

processes are: •tf^p * VflBpq). 40HBSi£E39Rs » ccffi^RI'^mMHHg, 

0^00 9 pfij^gg^png, ^JUJfUPand^^BHBP 

Some facUities prepare their own molding compound, which is then sold or used in 

their own operation. There are also a number of facUities diat use more dian one process at 

their facUity. Gel coating, for example, is typically used in conjunction widi other lamination 

processes. Table 2-5 shows the distribution of 246 major sources by production process. The 

data for this table were coUected from the 1993 industry screening survey. The 1992 TRIS 

data were not incorporated into Table 2-5 because TRIS data do not contain process 

infonnation. Since only 1993 survey information is used in Table 2-5, me total number of 

major sources is smaller here (246) than in Table 2-3 (321), which uses survey and TRIS data. 

A major source in Table 2-5 is die same as described under section 2.1.3. FacUities 

Uiat used several different processes were counted under each process reported for meir 
TABLE 2-4 

Number Of Employees By Facility Reported In 1993 Survey Response (Total Number Of Facilities Reporting 

Discrete Numbers • 363) 

Number Of Employ* 
P.12 

facility. Table 2-5 shows that flfllligi^^ 

:^^S^^8i*MiWM^P^^^iI^Sg^ffi^^E It is not 

* 

surprising that gel coating is reported by a large number of facilities, since many products 

produced by other processes have a gel coat finish. ^tenaaigB^gggg^Bg. which is reported 

by about ^fecreerifeeittDeigKniltrv. is the third most used process, followed by09Qf p 

^pmCTw^JEaeaciCeW Facilities diat reported mold production, resin production, or die 

use of wet mix in me 1993 industry survey were classified as "other" in Table 2-5. Six 

facUities are classified as injection molding operations; even though injection molding is 

usuaUy done wiui tiiermoplastic resins, these facUities use BMC for injection molding. 

11 
TABLE 2-5 

DISTRIBUTION OF MAJOR SOURCES BY PROCESS

 2

-

3 

(Total Number Of Major Sources = 246) 

P.13 

PROCESS NUMBER OF 

FACILITIES 

% OF FACILITIES REPORTING 

PROCESS 

Casting'/Centrifugal Casting 

Compounding (SMC, BMC & TMC) 17 

Continuous Lamination 

42 

12 

Cultured Marble Casting 14 

Injection Molding 

30 

152 

Prepregging 

26 H 

RTM 

19 

13 

158 

Vacuum Bagging >1 

Other 

Casting is a different process from cultured marble casting and centrifugal casting. 

12 
P.M 

2.2 MAJOR MARKETS AND PRODUCTS 

2.2.1 M-ajor market categories.47 TheggSi'j^^gkjp|lca^p^ included in die 

reinforced plastic composites source categoiy are: transportation, packaging, building and 

construction, electrical/electronics, furniture and furnishings, consumer and institutional 

products, industrial/machinery, adhesives/inks/coatings, and exports. 

The packaging market category includes all sorts of 

shipping containers like drums, boxes, and crates as well as packaging materials. The SIC 

code 308, MisceUaneous Plastics Products, covers diis market category. The building and 

construction market category includes items like pipe, conduit, plumbing fixtures, showers, 

bathtubs, siding, flooring, skylights, and railings. The SIC codes most closely related to this 

category are 353 and 308, which cover construction, materials handling and equipment, and 

miscellaneous plastic products. SIC code 243 relates to miUwork, veneer, plywood, and 

structural wood members, which also covers products used in die building and construction 

market sector. The electronics market category includes home and industrial appliances, 

resistors, and wire and cable coverings. The SIC codes for diis market category are 349, 361, 

362, and 364. The furniture market category relates to products such as household and office 

furniture and covers SIC code 251, which is household furniture. Consumer and industrial 

products are covered by SIC codes 308, 394, 396, and 399 and cover a wide variety of goods 

ranging from toys, sporting goods, costume jewelry, buttons, and ladders to barber shop 

equipment. 

2.2.2 Resin use bv market category.7 According to jgff data, ^0 W 

a small amount of me total thermoset resin produced. Table 2-6 provides information about 

the quantity of resin used and the distribution of thermoset resin sales and usage by major 

13 
P.15 

««** eggS^-3 

market category for 1993. 

The^99lClJ. Srreinforcedrplastics industfy^tffermoset and diermoplastic)f^projec6SiF; 

fetptii^^ Cadierine Randazzo, the Executive Director 

of die SPI Composites Institute, predicts a$f#Jpcrcent 

The Institute concludes diat abouj 

TABLE 2-6 

1991 USE OF THERMOSET PLASTIC RESINS BY MARICET CATEGORY7 

(Thousands of Pounds, Dry Weight Basis)* 

MAJOR MARKET 

Transportation 

Packaging 

Building & Construction 

Electrical/Electronic 

Furniture & Furnishings 

Consumer & Institutional Products 

Industrial/Machinery 

Adhesives/Inks/Coatings 

AUOther* 

Exports 

TOT.ALS 

RESIN QUANTITY 

617,326 

79,975 

4,628,885 

234,481 

146,727 

350,654 

191,001 

168,464 

270,292 

212,739 

6,900,544 

PERCENT OF TOTAL I 

8.9 I 

1.2 I 

67.1 

3.4 

2.1 

5.1 

2.8 

2.4 

3.9 

3.1 

100 

Phenolic is on a gross weight basis. 

All odier totals do not include disclosure data; therefore, diese totals may not equal 

me sum of their respective components. 

14 
P.16 

2.3.RESIN 

2.3.1 Resin usage hv type.1 A number of |heimose^ti^|gginsfare used in die 

composites industry. fMfeM.^^ ^ 

aDDroximatel\y/,9iPerge'M^ti{Sioimiresinsius< 

Polyesters are produced by die condensation polymerization of dicarboxUic acids and glycols. 

There sire many different acids and glycols used in polyester resin production to achieve die 

desired properties in the formulated resin. j^inceJgffiRSlre so versatile and since diey can 

be easUy modified or taUored during resin creation, they 

comparatively gffg8& and meir usage has 

historicaUy been limited to high performance applications. Epoxies can be used in most 

composite production processes, particularly vacuum-bag molding, compression molding, 

filament winding, and hand lay-up operations. 

They were developed toj 

If Phenolics are usually dark colored, limiting mem to applications diat are red, black, or 

brown. During the composite fabrication and curing step, phenolic resins produce water, 

which has to be removed from die process. Urea and melamine resins can be used for Ught 

colored products. 

2.3.2 M^jor resin manufacturers.7 Table 2-7 shows a listing of some of the major 

resin manufacturers who participated in the SPI mondily statistical report in 1993. As 

indicated in the table, a number of these manufacturers are involved in the production of 

several different resins. The survey did not contain any information on die manufacturers of 

vinyl esters and gel coat. 

15 
P.17 

TABLE 2-7 

SOME OF THE MAJOR RESIN MANUFACTURERS BY RESIN TYPEa7 

1 — •- • 

Epoxy 

Manufacturers 

Ciba-Geigy 

Corporation 

Dow Chemical 

U.S.A. 

Reichhold 

Chemicals 

Rhone-Poulenc 

SheU Chemical 

Company 

Union Carbide 

Corporation 

Melamine 

Manufacturers 

American 

Cyanamid 

Company 

BTL Speci^ty 

Resins 

Corporation 

Hoechst 

Celanese 

Corporation 

Neste Resin 

Corporation 

Occidental 

Chemical 

Corporation 

Rhone-Poulenc 

Phenolic 

Manufacturers 

AUied-Signal 

Corporation 

Ashland 

Chemical 

Georgia Pacific 

Corporation 

Neste Resin 

Corporation 

Plaslok 

Corporation 

Rogers 

Corporation 

Unsaturated 

Polyester 

Manufacturers 

Cook 

Composites & 

Polymers 

Dow Chemical 

U.S.A. 

Interplastic 

Corporation 

Owens-Corning 

Fiberglass 

Corporation 

Pioneer Plastics 

Corporation 

Reichhold 

Chemicals 

Urea 

Manufacturers 

Borden 

Chemical 

Company 

Cytec 

Industries 

Georgia Pacific 

Corporation 

Monsanto 

Chemical 

Company 

SheU Chemical 

Company 

Spurlock 

Adhesives 

Information for gel coat and vinyl esters were not included in the SPI survey; 

however, Cook Composites and Polymers is a major manufacturer of gel coats. 

2.3.3 Resin production and sales.7 

thermoset resins 

'. Table 2-8 presents information on 

the production and sales of five different tiiermoset resins: epoxy, melamine, phenoUc, 

unsaturated polyester, and urea. When examining me epoxy resin production data it is 

16 
P.18 

important to note that||fi|5[|]|^^ 

l^iijia^ Md^^posps. Table 2-9 provides information on die actual end use of the epoxy 

resin produced in 1993. The total production of unsaturated polyester is not as high as uie 

total production of some of the odier resins, but most of die unsaturated polyester resin is used 

for the production of reinforced plastics. This information is shown in table 2-10. According 

to Table 2-8, die production of phenoUc resin is higher dian the production of any odier resin. 

But when examining die end-use data for phenolic resins (Table 2-11), it becomes apparent 

diat approximately 93 percent of die phenoUc resin is used for bonding and adhesives. Only a 

relatively smaU fraction (5 percent) is used for molding compounds. 

TABLE 2-8 

1993 RESIN PRODUCTION AND SALES BY RESIN TYPE7 

RESIN TYPE 

Epoxy 

Melamine 

• 

Phenolic 

Unsaturated Polyester 

Urea 

PRODUCTION IN 

MILLIONS OF POUNDS 

512 < 

270 

SALES IN MILLIONS OF 

POUNDS 

S

 53 5 

^ _ . . 

261 

3,078 <^ 3,081 

1,264 ^ 

1,744 

1 . 1,280 

1,743 

|*u * t*<dr+f*j 

t

cJL*u£l+'+&' 

7 

n 

17 
P.19 

TABLE 2-9 

EPOXY RESIN CONSUMPTION BY END-USE7 

EPOXY RESIN END-USE 

Bonding & Adhesives 

| Flooring, Paving, and Aggregates 

Protective Coatings 

¥?te?K@HfefeeitiEHHM&i3i^^ 

Tooling, Casting, and Molding Resins 

AU Other Uses 

TOTAL 

- — • • - ' 

AMOUNT USED IN 

MH J JONS OF 

POUNDS 

33 

34 

218 I 

B-WmW l 

17 I 

31 I 

414 | 

18 
P.20 

TABLE 2-10 

UNSATURATED POLYESTER CONSUMPTION BY END-USE7 

AMOUNT USED IN MILUONS OF 

POUNDS 

Marine And Marine Accessories 267 

Transportation 98 

General Construction 71 

Batiiroom Components & Fixtures 145 

Pipes, Tanks, and Fittings 141 

Panels 88 

Electrical/Electronic 32 

Recreational Goods, Toys, etc. 18 

Other Consumer Goods 16 

Other Reinforced Goods 36 

Reinforced Plastics, Total 

Transportation/Body Putty 48 

Construction 154 

Consumer Goods 35 

Gel Coats 62 

Other Non Reinforced Goods 27 

Other End-Uses, Total 

19 
P.21 

TABLE 2-11 

PHENOLIC RESIN CONSUMPTION BY END-USE7 

PHENOUC RESIN END-USE .AMOUNT USED IN 

.MILUONS OF POUNDS 

Molding Compounds 160 

Bonding & Adhesives for Laminating 177 

Bonding & Adhesives for Coated or Bonded Abrasives 25 

Bonding & Adhesives for Friction Materials 49 

Bonding & Adhesives for Insulation Materials 375 

Bonding & Adhesives for Plywood 1,540 

B Bonding & Adhesives for Fibrous and Granulated Wood 485 

AU Odier Bonding & Adhesives 189 

Protective Coatings 12 

AU Odier Uses 39 

TOTAL 3,051 

2.4 EXISTING REGULATIONS 

2.4.1 Introduction.M8 Existing regulations for the reinforced plastic composites 

industry have been reviewed in order to evaluate potential control strategies and their 

effectiveness. The areas that have implemented regulations for this source category include 

die Puget Sound Air PoUution Control District (PSAPCA) in Washington, California's Bay 

Area, the Soudi Coast .Air Quality Management District (SCAQMD), San Diego, Santa 

Barbara, Yolo-Solano, San Joaquin VaUey, and Ventura County Air Pollution Control 

Districts, and the States of Maryland and Illinois. Each regulation applies to polyester resin 

20 
and gel coating operations tiiat fabricate or rework products for commercial, military, or 

industrial use including, but not limited to, boats,' tubs, pools, shower enclosures, spas, 

bauiroom fixtures, jigs, tools, molds, air pollution control equipment, sewage treatment 

equipment, storage tanks, transportation parts, and otiier industrial and consumer products. 

Is (defined, for example, by 

SCAQMD as unsaturated polyester resins, such as isophthalic, ortiiophthalic, halogenated, 

bisphenol A, vinyl ester, or furan resins; cross-linking agents; catalysts; gel coats; inhibitors; 

accelerators', promoters; and any odier material containing VOC used in polyester resin 

operations). The strategies used include the use of certain spray gun or application equipment, 

appUcation of resin material widi a low monomer content, use of vapor suppressed resins, use 

of add-on control equipment, switching to low VOC or water base cleaners, resin application 

in an enclosed area with a dry filter to control overspray, and covering resin storage 

containers. Some of the regulations allow a combination of emission reduction strategies to 

achieve compliance. 

2.4.2 Summary of existing regulations.*•" The key points of die existing air quality 

regulations affecting the reinforced plastic composites industry are presented in Table 2-12. 

The regulations apply to any facUity, existing or new, diat manufactures products from 

polyester resin material. However, some of the regulations include exemptions for certain 

compounds, processes, and resin usage. The Soutii Coast regulation exempts a number of 

chlorine containing compounds including chlorofluorocarbons, methyl chloroform, and carbon 

tetrachloride from dieir regulation, whUe die Bay Area and the State of Maryland exempt 

processes such as touch-up and repair operations. The amount of resin used by a facility can 

also be the basis for exemption. Ventura County, for example, exempts facilities diat use less 

than 20 gaUons of polyester resin material per month, whUe San Diego County exempts 

marine vessel repair operations using less dian 0.5 gaUon of resin each day and aU odier repair 

operations using less dian 1 gallon per day. The State of Maryland exempts facilities diat have 

less dian 20 pounds of actual VOC emissions per week. 

The State of Illinois and California's Bay Area, South Coast, San Diego, Santa 

21 
TABLE 2-12 

REGULATORY SUMMARY FOR THE REINFORCED PLASTIC COMPOSITES INDUSTRY

 9"18 

RULE PROVISION BAY AREA 

REGULATION 8 

RULB 30 

By weight as applied 

50ft By weight as applied 

PUGETSOUND 

REGULATION U 

SECTION 3.08 

SOUTH COAST RULE 1162 

& STATE OF ILLINOIS 

SECTION 218.660 

35 ft By weight as applied 

48 ft By weight as applied 

SAN DIEGO RULE 67.12, 

VENTURA COUNTY 

RULB 74.14* 

35 % By weight as applied 

50 ft By weight as applied 

STATE Of MARYLAND 

COMAR26.U.19.XX 

35 ft By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

SO % By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

50 ft By weight as applied 4^XLBy weight as applied for 

South Coast, 50 ft for Illinois 

SO ft By weight as applied 50 ft By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

Monomer Content Limit for .48 ft By weight as applied 50 ft By weight as applied, 

only for Ventura County 

Monomer Content Limit For 250 Grams of VOC per liter Z. i 

of coating applied ^W^W 

50 ft By weight as applied, if 

actual VOC emissions are 

20 lbs or more per day 

By weight as applied 50 ft By weight as applied 

Monomer Content Limit For 250 Grams of VOC per liter 

of coating applied Z£% By weight as applied 45 ft By weight as applied 

Usage Of Vapor-Suppressed 

Resin With Limited VOC 

Emissions 

Or 

Weight loss from VOC 

emissions not to exceed 60 

grams per square meter of 

exposed surface area 

Or 

Weight loss from VOC 

emissions not to exceed 60 

grams per square meter of 

exposed surface area 

Or 

Weight loss from VOC 

emissions not to exceed 60' 

grams per square meter of 

exposed surface area 

Or Or 

22 
TABLE 2-12 (Continued) 

n 

RULE PROVISION 

Use Closed Mold System 

Or 

Pultrusion Operations 

Requirements 

And 

Specific Spray Equipment 

And 

BAY AREA 

REGULATION 8 

RULB50 

Use Closed Mold System 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP) 

And 

PUGETSOUND 

REGULATION D 

SECTION 3.08 

, , , 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP) 

And 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

With less dum 4 ft weight loss 

of polyester material 

Or 

Covered wet-out baths, enclose 

distance from exit of bath to 

die except for 18 inches of 

preform distance for South 

Coast. Sft maximum weight 

loss of polyester material for 

South Coast and 4ft for Illinois 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP): for 

touch-up and repair use of 

hand-held, air-atomized spray 

gun is permitted 

And 

SAN DIEGO RULE 67.12 A 

VENTURA COUNTY 

RULE 74.14 

Use Closed Mold System 

And 

Airless spray, air-assisted 

airless spray, electrostatic 

spray, or high volume, low 

pressure spray (HVLP): for 

touch-up and repair use of 

hand-held, air-atomized spray 

gun is permitted 

And 

STATE Of MARYLAND 

COMAR26.11.I9.XX 

And 

Facilities with more dian 

100 lbs of actual VOC 

emissions per day must use 

airless spray or air-assisted 

airless spray guns, low 

pressure nozzles, pressure fed 

rollers, flow coaters, or other 

non-atomized application 

technique 

And 

#"•» -

23 
TABLE 2-12 (Continued) 

RULE PROVISION 

Storage Requirements 

And 

Cleaning Material 

Requirements 

BAY AREA 

REGULATION 8 

RULB50 

Closed containen for storage. 

self-closing container* for 

disposal of waste material, 

resin, and cleaning materials 

And 

VOC content of cleaning 

material is not to exceed 200 

grams per liter of material; 

use equipment for collecting 

cleaning material and 

minimize evaporation 

PUGETSOUND 

REGULATION 0 

SECTION 3.08 

Closed containers for storage 

and disposal of VOC-containing 

materials. 

And 

Any VOC-containing material 

used for cleanup of spray 

equipment, including resin lines. 

can only be used if equipment 

for collecting VOC-containing 

material is employed and 

evaporation to the atmosphere is 

minimized. 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

Closed containers 

And 

Solvent cleaning operations 

shall comply with Rule 1171 

for the South Coast Rule. 

Illinois requires solvent 

recovery system when using 

more than 4 gallons of cleaning 

materials per day with more 

dun 200 $ of VOM per liter 

(1.7 lbs per gallon). Solvent 

recoveiy on site or by 

commercial service. Waste 

residue from solvent recoveiy 

system at die source must have 

less than 20ft VOM by weight 

SAN DIEGO RULE 67.12 & 

VENTURA COUNTY 

RULE 74.14 

Self-closing containers for 

storing resin, cleaning 

materials, and waste materials 

for San Diego, Yolo-Solano, 

and San Joaquin. Closed 

containers for storage of all 

VOC containing materials for 

Ventura County and Santa 

Barbara County. 

And 

Use VOC reclamation system 

for cleaning materials, unless 

materials contain less than 200 

grams of VOC per liter (1.7 lbs 

per gallon), or materials have 

initial boiling points greater 

dian 190" C, or average usage 

is less than 0.5 gallons per day 

for San Diego, 15 gallons per 

week for Ventura County, and 

4 gallons per day for YoloSolano and San Joaquin. 

Solvent residue from 

reclamation system shall not 

exceed 20 ft VOC by weight. 

STATE Of MARYLAND 

COMAR26.11.19.XX 

Use non-VOC clean-up 

materials 

24 

to 

Ul 
TABLE 2-12 (Concluded) 

RULE PROVISION 

In Lieu Of All The Above 

Except Storage And Cleaning 

Material Requirements, Facility 

may use Control Equipment 

And 

Application Area Restrictions 

Resin Usage or Emissions 

Exemptions 

Other Exemptions 

BAY AREA 

REGULATION 8 

RULE 50 

In lieu of all the above except 

storage and cleaning material 

requirements, facility may use 

control equipment, which 

must reduce VOC emissions 

by at least 85 ft 

H _ » 

Any touchup and repair 

operations 

PUGET SOUND 

REGULATION D 

SECTION 3.08 

And 

Enclosed Area widi dry filter to 

control overspray 

SOUTH COAST 

RULE 1162 & STATE OF 

ILLINOIS SECTION 218.660 

In lieu of all die above except 

storage and cleaning material 

requirements, facility may use 

control equipment wim overall 

capture and control efficiency 

of at least 90 ft on a mass 

basis 

*^_« 

SAN DIEGO RULE 67.12 & 

VENTURA COUNTY 

RULE 74.14 

In lieu of all dw above except 

storage and cleaning material 

requirements, facility may use 

control equipment wim total 

capture of VOCs and control 

efficiency of at least 85 ft by 

weight in Ventura County. 

_ ^ _ 

Less dian 20 gallons per month 

of resin usage for San Joaquin 

and Ventura County. Less than 

50 gallons of resin usage per 

year for Santa Barbara. Less 

dum 1 gallon per day for repair 

work except for marine vessels 

for San Diego. No exemption 

for Yolo-Salano 

Any touchup and repair 

operations fbr Yolo-Solano 

STATE Of MARYLAND 

COMAR26.11.19.XX 

Facilities widi less dian 20 lbs 

of actual VOC emissions per 

week 

Any tooling or touch-up and 

repair operations 

Includes summary of Santa Barbara Couniy Rule 349, Yolo-Solano Rule 2.30, and San Joaquin Valley Rule 4684. 

25 

to 

O) 
P.27 

Barbara, Yolo-Solano, San Joaquin Valley, and Ventura County Control Districts have very 

similar rule provisions. They all have limits for die monomer content of general purpose resin, 

specialty resin, and clear and pigmented gel coat. The South Coast and Ventura County 

regulations have a separate monomer content limit for high strength polyester resins. As an 

alternative to complying with a monomer content limit, a facUity can choose to use either 

vapor-suppressed resins widi limited VOC emissions, closed mold systems, or control 

equipment to achieve certain emission reductions. In addition to the material and process 

requirements stated above, all eight above mentioned regulations require the use of specific 

spray equipment for spraying operations, and also specify storage and cleaning material 

requirements. 

PSAPCA's Regulation II Section 3.08 covers some of die same provisions as die eight 

regulations discussed above, such as die usage of specific spray equipment, storage 

requirements, and cleaning material requirements. However, PSAPCA does not address 

monomer content, usage of vapor-suppressed resin or gel coat, closed mold systems, or add-on 

control equipment. Instead, Puget Sound's regulation requires all spray operations to be 

conducted inside an enclosed area that has a dry filter to control overspray. The exhaust from 

the operation must be vented to the atmosphere through a vertical stack. 

The State of Maryland only addresses the resin monomer content, die type of spray 

equipment, and die use of VOC cleaning materials. 

26 
P.28 

2.5 REFERENCES 

1. SPI Composites Instimte, Introduction to Composites Reference 

Handbook. 1992. 

2. 1992 Toxic Release Inventory System. 

3. Responses from section 114 screening survey sent to tiie reinforced plastic 

composites industry. 1993. 

4. Standard Industrial Classification Manual, National Technical 

Information Service. 1987. 

5. Standard Industrial Classification Manual, National Technical 

Information Service. 1972. 

6. Memorandum from LaFlam, G. and Proctor, M., Pacific Environmental 

Services, to Strum, M., EPA/ESD/CCPG. Process Descriptions and Emission 

Points. September 1995. 

7. The Society of the Plastics Industry, Inc., Facts & Figures of die U.S. Plastics 

Industry. September 1994. 

8. C. Randazzo, "This is another year of good news". Reinforced Plastics 

newsletter. Volume XIX, Number 19. September 18, 1995. 

9. Puget Sound Air PoUution Control Agency. Regulation II, Section 3.08 

Polyester, Vinylester, Gelcoat, And Resin Operations. September 12, 1993. 

10. Bay Area Air Quality Management District. Regulation 8 Organic 

Compounds, Rule 50 Polyester Resin Operations. December 5, 1990. 

11. South Coast Air Quality Management District. Rule 1162 Polyester Resin 

Operations. May 13, 1994. 

12. San Diego Air Pollution Control District. Regulation IV, Rule 67.12 Polyester 

Resin Operations. April 6, 1993. 

13. Ventura County Air PoUution Control District. Rule 74.14 Polyester Resin 

Material Operations. May 26, 1992. 

27 
P.29 

14. Maryland State Air Laws, COMAR 26.11.19.XX Control Of VOC 

Emissions From Reinforced Plastic Manufacturing. Draft. July 13, 

1995. 

15. Illinois Organic Material Emission Standards, Tide 35 Subtitle B, Part 

218 Organic Material Emission Standards and Limitations for the 

Chicago .Area. March 3,1994. 

16. San Joaquin Valley Unified Air Pollution Control District. Rule 4684 Polyester 

Resin Operations. May 19,1994. 

17. YOIO-SOIMO .Air PoUution Control District. Regulation II, Rule 2.30 

Polyester Resin Operations. August 25, 1993. 

18. Santa Barbara County Air PoUution Control District. Rule 349 

Polyester Resin Operations. April 27, 1993. 

28