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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

67) ll-E-27 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 67 of 264 
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V 

jr-^-27 

ODD O 

a 

MEMORANDUM 

TO: Madeleine Strum, EPA/ESD 

FROM: Greg LaFlam, PES 

DATE: August 25, 1995 

L:/N308 

SUBJECT: Pre-MACT Team Teleconference on Pollution Prevention 

I. Purpose 

The purpose of this meeting was to share information on a recent pollution 

prevention test program and to discuss two additional fabrication processes that offer a 

potential for low styrene emissions. 

II. Location of Meeting and Participants 

Place: U.S. Environmental Protection Agency 

N.C. Mutual Life Building, Room 1019 

Durham, NC 

Date: July 31, 1995 

Participants: Bijan Ataian, SCAQMD (909) 396-2454 

Mark Bahner, RTI (919) 541-6016 

Jeffrey Best, PES (919) 941-0333 

Dan Boyd, industry consultant (410) 827-6244 

Mark Callicut, Reichhold Chemicals (919) 990-8013 

Amir Dejbakhsh, SCAQMD (909) 396-2618 

Chuck French, EPA/OAQPS (919) 541-0467 

Eric Goehl, Radian (919) 461-1367 

Tom Hedger, Magnum Industries (813) 573-2955 

Mark Hollenbech, Cook Composites (816) 391-6044 

Kenneth Jacobs, Liquid Control Corp. (216) 494-1313 

Norm Kaplan, EPA/ORD (919) 541-2556 

Bob Lacovara, CFA (703) 524-3332 

Greg LaFlam, PES (919) 941-0333 

Tom Maves, Ohio EPA (216) 963-1205 

Steve McNally, CFA (703) 524-3332 

Arnold Medbery, EPA/OSDBU (703) 305-5171 
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Madeleine Strum 

August 18, 1995 

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Richard Nielson, Clark County, NV (702) 383-1276 

Carlos Nunez, EPA/ORD (919) 541-1156 

Brian Palmer, Radian (919) 461-1218 

Nancy Pate, EPA/OAQPS (919) 541-5347 

Everett Pearson, TPI Inc. (401) 245-1200 

Solomon Ricks, EPA/OAQPS (919) 541-5242 

Tony Sasson, Ohio EPA (216) 963-1205 

John Schweitzer, Composites Institute (313) 668-4703 

Jordan Spooner, EPA/OPPT (202) 260-4418 

Madeleine Strum, EPA/OAQPS (919) 541-2383 

George Tunis III, Hardcore Composites (302) 427-9250 

III. Discussion 

Ms. Strum opened the meeting by asking the attendees present in the meeting 

room to introduce themselves. She said that this meeting would be similar to the 

previous pre-MACT team teleconference (vendor presentations on several add-on 

control options), but with the theme of pollution prevention (P2). Mr. Spooner, with 

EPA's pollution prevention division, stated that his role was to be a pollution prevention advocate, and to present to the group the available policy options. 

The remainder of the meeting consisted of presentations given by participants in 

a recent EPA program to assess options for preventing pollutant emissions from 

sprayup and gel coating operations, and by industry representatives of two fabrication 

processes with reduced styrene emissions. (Descriptive material related to these 

presentations was distributed to the team as an enclosure to the meeting notice dated 

July 21, 1995.) 

EPA/ORD Pollution Prevention Program 

Mr. Bahner, a contractor to EPA/ORD, presented preliminary results of a recent test 

program. He described the test objectives as: 1) comparing a mass balance approach 

for determining emissions to EPA Method 25A (total hydrocarbon analyzer) emission 

measurements; 2) establishing baseline emission results (from "uncontrolled" materials 

and practices) to compare with results from pollution prevention techniques; and 3) 

determining emission reductions for a variety of approaches that included changes to 

operational parameters and work practices, resin and gel coat formulations, and 

appUcation equipment. 
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Madeleine Strum 

August 18, 1995 

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The testing utilized "controlled" spraying (a P2 technique), a more refined 

application technique designed to result in less overspray than typical spraying. This 

change in operator spray technique was found to have an effect in reducing emissions. 

Other changes found to affect emission levels were low-styrene and styrene-suppressed 

gel coats and resins, and switching from spray guns to flow coaters and pressure-fed 

resin rollers. No significant difference was found between air-assisted airless, HVLP/ 

external mix, and HVLP/internal mix spray guns. Also, over the velocity range tested, 

air velocity was not found to have a significant effect. Finally, use of a benzoyl 

peroxide (BPO) catalyst did not significantly reduce emissions compared to a methyl 

ethyl ketone peroxide (MEKP) catalyst. 

The results of the testing tended to confirm an earlier finding that emission 

factors were approximately 2.3 times higher than the midpoint of the AP-42 factor 

range for these operations. Individual reduction measures were found to lower styrene 

emissions by up to approximately 40 percent. 

Questions and discussion followed Mr. Banner's presentation. Spooner: What 

do you consider a "significant" emissions difference? Nunez: Greater than about 10 

percent. Nunez: How do "normal" and "controlled" spraying compare? Hedger, 

Lacovara: Controlled spraying has better transfer efficiency, less wasted resin. More 

styrene is lost from the thin film of overspray, which cures more slowly than the thicker 

layer on the mold. Nielson: Is EPA Method 25A specific for measuring styrene; are 

emissions measured as higher or lower using this method? Bahner: Styrene was the 

only VOC present in the materials, so the measurements in this case represented 

styrene emissions. Lacovara: In the CFA-sponsored testing at Dow Chemical, 

measurements using Method 25A and a real-time gas chromatograph showed good 

agreement. Strum: Were airless spray guns tested? Banner, Lacovara: No, these 

guns are being phased out in this industry and their use is not common. However, 

since they are still in use at some facilities, they may be added to the CFA Phase II 

testing program. 

Mr. Hollenbech, Cook Composites and Polymers, discussed the gel coat 

supplied by his company for the testing. This gel coat, which has a low styrene content 

(about 25 percent) and a vapor suppressant, is still undergoing field testing and is not 

yet commercially available. He stated that the properties of this product are comparable to the better gel coats that are available (but not the top of the line products). It 

is presently being produced only in white and off-white. Intended applications are in 

the marine, sanitary (tubs, etc.), and transportation markets. Mr. Hollenbech concluded by cautioning that establishing standards on the basis of this product would be 

premature. 
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Madeleine Strum 

August 18, 1995 

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During questions and discussion, Mr. Hollenbech related that this gel coat has 

very good properties, but some tackiness, and lower shrinkage than normal. While the 

actual formula contains both styrene and methyl methacrylate, the product tested 

contained only styrene. McNally: Is the current restriction on colors a limitation of 

the product or merely a process issue? Hollenbech: A full range of colors for the 

product is technically possible and the company plans to offer several color choices in 

the future. Also, the product has a higher cost than normal gel coats, but due to the 

higher solids film less may be needed to build the surface layer. The product has been 

available for approximately 1 year and is presently being used by some facilities. 

Mr. Callicut, Reichhold Chemicals, briefly described the low-styrene and 

styrene-suppressed resins supplied by his company for the test program. These resins 

contained ingredients to promote good secondary bonding despite the presence of the 

suppressant, and wetting agents to compensate for the lowered styrene content. A 

resin system containing fillers was not tested. 

In response to a question, Mr. Callicut said that the suppressed resin containing 

extra wax (to further suppress emissions) could be used in any application as long as 

good surface preparation was carried out. LaFlam: What is the potential effect on 

emissions when using BPO versus MEKP catalysts? Callicut, Banner: The selection 

of catalyst would probably not be a large factor. Emissions measured from the two 

resin/catalyst formulations in the recent test program showed no significant difference. 

Mr. Hedger, Magnum Industries, described the three types of spray guns 

supplied by his company for the test program. He said that, since a true HVLP system 

(as used for painting) could not be used for resin products, the HVLP used here was 

actually a modified air-assisted airless system and so both gun types showed similar 

emission levels. Spooner: What is the prevalence of flow coaters and pressure-fed 

rollers versus spray gun technology? Hedger: Flow coaters are used approximately 5:1 

over rollers (rollers have limitations when making large or complex shaped parts), and 

the two types of equipment account for about 30 percent of sales in the open molding 

sector. Gel coats must still be applied using spray equipment. 

Alternative Low-Emission Fabrication Processes 

George Tunis III, Hardcore Composites, discussed a vacuum infusion fabrication process termed the Seeman composite resin infusion molding process (SCRIMP). 

This process is jointly controlled by Bill Seeman, Hardcore, and TPI Incorporated 

(Everett Pearson). Other companies wishing to utilize the process are assessed an 

initial fee (which includes training) and then a royalty (5 percent of laminate). 
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Madeleine Strum 

August 18, 1995 

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Mr. Tunis stated that SCRIMP is similar to traditional vacuum bagging and 

resin transfer molding, but has several advantages and produces superior quality parts. 

The process is best suited for larger parts with low production quantities. Parts 

produced include oil rigs, railcars and ferry bumpers, bridge sections, Navy vessel 

components, and airframe parts. SCRIMP produces composites of up to 70-75 percent 

fiber content by volume, and is effective with 50-100 oz. cloth reinforcements (up to 

200 oz. cloths are anticipated in the future). Laminates up .to 6 inches thick with 

several layers of core materials can be produced. All reinforcements, trusses, and core 

materials are placed in the mold and sealed by a bagging system. The bags can be 

composed of a silicone material, which may be used many times, or of a one-time use 

material which provides a smoother finish on the inside surface. The bagging system is 

sealed to the materials using a simple "zip lock" system and by appUcation of vacuum. 

Resin is distributed under the bagging system by way of an "artery and capiUary" 

distribution network. Since resin is infused after a vacuum is apphed to the bagged 

system, there is no direct exposure of uncured resin to the air. Cross-linking is 

enhanced due to low styrene loss and voids are essentiaUy eliminated, resulting in 

laminate comparable in quality to aerospace epoxy composites. 

To get an idea of emissions from the SCRIMP process, activated carbon filters 

were installed in the line to the vacuum pump. Measurements indicated that only 

0.0061 percent of the styrene put into the molding process appears in the vacuum 

pump exhaust stream. Strum: Have weights been recorded? Pearson: Measurements show less than a 0.1 percent weight loss between the resin infused and that 

ending up on the part. Mr. Tunis compared styrene emissions from the molding of 30 

million lb of resin as 20-90 tons using conventional open molding versus only 20-90 

pounds using the SCRIMP process. 

Mr. Pearson emphasized the cleanliness of the SCRIMP work environment and 

the fact that worker morale has been improved to a fantastic degree in the 2 years his 

company has been using SCRIMP. Savings are realized due to reduced labor and 

cleanup materials, and in lower plant ventilation rates (the TPI plant uses no exhaust 

fans). McNally: Are any parts not able to be SCRIMPed? Pearson: SCRIMP is not 

competitive for many parts (such as tubs/showers) produced by sprayup, but further 

developments in preforms (reinforcements premolded into the final shape using a 

binder system) will likely change this. 

Mr. Jacobs, Liquid Control Corporation, discussed the resin-transfer molding 

(RTM) process. The process uses metering, mixing, and dispensing equipment to 

inject catalyzed resin at 40 to 50 psi pressure into a closed mold containing glass 

reinforcement. The process is most suitable for smaller parts, such as bathtubs, 

produced at moderate production rates. The gel coat is sprayed onto the mold halves 

prior to part molding using conventional spraying techniques. The RTM process 
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Madeleine Strum 

August 18, 1995 

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differs from the SCRIMP process in that parts with two finished sides are produced. 

Also, RTM uses hard, two-part molds that can withstand considerable molding 

pressure. In RTM, resin moves along fiber bundles paraUel to the fiber direction, 

while in the SCRIMP process resin moves over the fiber layers and down through the 

fiber bundles. In response to a question, Mr. Jacobs indicated that there is no 

licensing fee for the use of the RTM process. Ms. Strum noted that, per the 1982 

article on RTM distributed to the team before the meeting, MFG selected RTM for 

making bathtubs, but it was not known whether the company was still engaged in this 

effort. 

Representatives of CFA said that a compendium of articles on RTM would be 

pubUshed in 60 to 90 days. 

Next Steps 

Ms. Strum encouraged the team/Work Group members to provide any comments they have on any aspect of the pre-MACT decision to herself or to Greg 

LaFlam at PES. With regard to the next meeting of the team, she proposed the issue 

of subcategorization of the industry for regulatory purposes as the main topic for the 

meeting. 

Mr. Bahner said that RTI is preparing a report on emissions from the various 

processes and the implications for the MACT floor determination. This report should 

be ready in August. Ms. Strum felt that this report could be distributed to the team 

and then discussed at the next meeting.