p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

87) ll-E-47 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:06 AM Sheet 87 of 264 
P.2 

C_J 

A-94-52 

MEMORANDUM 

TO: Madeleine Strum 

U.S. EPA/ESD/CCPG 

FROM: Greg LaFlam and Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

DATE: September 24, 1996 

b:\cbidisk 

..;:%'£»!* :•>&$ ';?£*•.;.';- ..• 

^V;,. EPA AIR DOCKET 

SUBJECT: Summary of August 19, 1996 Meeting Between EPA and Representatives of 

the Kemlite Company 

LOCATION: EPA/Mutual Building, Durham, NC, 11th floor conference room, 

9:00 am -12:30 pm 

ATTENDEES: 

Mr. Greg LaFlam 

Mr. Paul Margherio 

Ms. Melanie Proctor 

Mr. Robert Smith 

Ms. Madeleine Strum 

PES 

Kemlite Co., Inc. 

PES 

Kemlite Co., Inc. 

EPA/ESD 

(919) 941-0333 

(815) 467-8656 

(919) 941-0333 

(815) 467-8600 

(919) 541-2383 

PURPOSE 

The meeting was requested by the Kemlite Company in order to gain infonnation 

on the direction of EPA's rulemaking effort for the continuous lamination subcategory, and 

to give the company an opportunity to describe the processes, control measures, and 

emissions at the company's two manufacturing facilities. Attachment 1 is a list of 

discussion topics distributed by Kemlite at the meeting. 

DISCUSSION 

Mr. Smim stated that Kemlite is not a member of the Society of the Plastics 

Industry (SPI), but has been in touch with SPI. The company's two manufacturing 

facilities, at Joliet, EL and Jonesboro, AR, are an operating division of Kemlite (which is; 

owned by Crane). The correct name for the panel division is Kemlite Company, Inc.; the 

Jonesboro plant was formerly owned by BP Chemicals. The company (along with 

Sequentia) is one of the two largest panel makers, and does not consider itself a small 

business. They legally are a stand-alone business, with about 375 employees (270 at 

Joliet, 105 at Jonesboro). Crane keeps the earnings figures and, since Kemlite Company 

is part of a division, no separate data are available for the company separately. 
P.3 

Madeleine Strum 

September 24, 1996 

Page 2 

In discussing the confidentiality of the company data, the company requested that 

the discussions and portions of the provided printed material be treated as confidential 

business information (CBI). 

Ms. Strum described the function of the Emission Standards Division in developing 

regulations in response to the Clean Air Act. She explained that the draft rule would be 

subject to intensive review, both within and outside of EPA, proposed for public comment 

in a hearing and through written comments, and promulgated as a final rule following 

consideration of comments. Outreach efforts providing assistance to affected sources may 

be available following promulgation. 

A copy of EPA's current data base for continuous lamination facilities was 

provided to Kemlite. They expressed surprise that the Brady Company and Haysite were 

included on the list, and wondered why Glasteel was missing (it was surmised that they are 

possibly too small to be a major source). Ms. Proctor explained that EPA's emissions 

calculations were based on the midpoint of the emission factor range in AP-42 (5.5 percent 

of available monomer). Kemlite stated that they do not use the AP-42 factor, but use their 

own stack test data for emissions reporting and permitting. 

The company distributed several sheets: 1) Kemlite data sheet, 2) schematic 

showing the process at Joliet, 3) schematic of Joliet computer system, 4) spreadsheet 

showing emissions data for one week of production at Joliet, and 5) spreadsheet showing 

monomer loss calculations for Kemlite/Jonesboro, Kemlite/Joliet, and LASCO Panel 

Products in Kentucky. (Ms. Strum had provided to Kemlite emission estimates for 

LASCO based on a mass balance.) The company retrieved and kept all copies of their 

computer system schematic after showing and describing it to EPA and PES. The 

remaining four sheets are included as Attachment 2. 

Joliet Production Process 

The Joliet, IL facility produces laminated panel products on three continuous lines, 

designated LP-3, LP-6, and LP-7. Mix room 1 serves lines LP-3 and LP-6, while mix 

room 2 serves line LP-7. The resin mixture is made in batches and delivered to the 

production lines using a computer controlled process. Ingredient weight records are 

accurate to within 1 percent. 

As depicted on the second page of Attachment 2, the process is not a straight-line 

process like other continuous lamination processes. The resin mixture is dispensed onto 

the carrier film and then turns 180° before entering me curing oven. Thus, the film which 

starts out at the bottom of the mixture becomes the top film of the panel. A bottom film 

may also be added; however, on two of the production lines a bottom film is not needed. 

2 
P.4 

Madeleine Strum 

September 24, 1996 

Page 3 

Instead, a stainless steel belt, 118 inches wide, is used by itself to convey the laminate 

through the oven. 

The resin mixture is dispensed at a temperature of 85 to 90°F. Since a promoted, 

rather than a heat-activated, catalyst is used, the resin begins to gel without the addition of 

heat. Thus, a relatively short, non-heated wet-out table is used. The process has an 

exposed area of wet resin of approximately 24 square feet (8 ft. wide x 3 ft. long). After 

the 3 feet, chopped fibers form a very thick barrier which completely covers the exposed 

resin. In order to promote good wetting of the fibers by a cooler resin mixture, nylon 

filament similar to fishing line is used to hold the mixture to the squeeze rolls. This 

compresses the laminate and ensures good fiber wet-out. The distance from the doctor 

blade to the squeeze rolls is 10 to 12 feet, and the average product width is about 98 

inches. 

A minimal air flow is maintained over the lamination table, and styrene concentrations do not exceed the occupational exposure limit of 50 ppm. A ventilation hood is 

installed about 4 feet over the table, and has a low inlet velocity. 

Emissions Calculations 

The company has developed a method for calculating by computer its emission rate 

in lb/hr, based on the continuous measurements taken of the materials fed into the process, 

theoretical evaporation rate data, and stack test data. The third page of Attachment 2 

shows the results of these calculations for the week of August 11, 1996. kemlite emphasized that, while this calculation of an "E factor" is based on theoretical considerations 

arising from the Ideal Gas Law, the results have been confirmed by a "stack test" at the 

facility. This test was performed in 1991 using a modified EPA Method 18 (sample bags 

analyzed at a lab using GC and mass spec methods). Kemlite also pointed out that fugitive 

emissions are accounted for in the emissions calculations. Ms. Strum suggested the 

possibility of calculating an E factor for each facility in the continuous lamination data 

base, using the Kemlite procedure combined with emission testing results from each 

facility. She requested information from Kemlite's test report that would describe the test 

method and the calculation of the E factor. 

Kemlite described the applicable Illinois State regulation in effect for the Joliet 

facility. A cap of 23 lb/hr applies to all three production lines, or 7.67 lb/hr on a per-line 

basis. As continuous readings are being made (one record per minute), the computer 

system creates a calculation of lb/hr emissions for each 15-rninute period. An alarm 

sounds at a value of 7 lb/hr, and a more urgent alarm sounds at 7.5 lb/hr. Adjustments 

are made to the process to ensure that the calculated emission rate falls below 7 lb/hr. 

3 
P.5 

Madeleine Strum 

September 24, 1996 

Page 4 

The participants reviewed the emission loss comparison prepared by Kemlite for its 

two facilities and for LASCO Panel Products (the last page of Attachment 2). LASCO 

had estimated its process loss percentage by performing a mass balance on its process (accounting for the weights of all liquids and solids entering and leaving the process). 

Kemlite/Jonesboro, with a total enclosure and a regenerative thermal oxidizer (RTO) in 

use, had calculated losses of 0.11 and 0.20 percent (Line 5 with its higher emissions uses 

gel coat and a heated process). Kemlite/Joliet showed a loss (based on the E factor 

calculation) of 0.33 percent of the available monomer. This calculation accounted for 

mixing operations and the panel line (but not resin storage tank losses, which are small). 

This low loss level for an operation without a control device was attributed to the short 

wet-out and unheated resin used in Joliet's process. Finally, the LASCO mass balance 

showed a loss of 1.59 percent for their narrow line and a calculated loss of 2.72 percent 

for their wide line. 

Other Issues 

The participants discussed the glass enclosures used over the wet areas of the panel 

making operation at Sequentia in Grand Junction, MO. Kemlite expressed skepticism that 

the enclosures could provide significant emission reduction, due to the need to open them 

frequently to correct glass fiber defects, etc. They also had concerns about the safety of 

such enclosures, in that styrene concentrations might approach the LEL, or unsafe 

occupational exposures could occur during production. 

Kemlite said that, while only acetone is used for cleaning at Jonesboro, the Joliet 

facility uses methylene chloride. Ms. Strum asked about the source of the n-butyl acrylate 

which the company had listed in its response to EPA's screening survey. They responded 

that this is a monomer used in gel coats, but it was not clear whether this compound is 

considered a HAP in the Clean Air Act. (A subsequent check of the CAA list by PES 

indicated that n-butyl acrylate is not on the list.) 

Ms. Strum discussed the elements of EPA's tentative definition for continuous 

lamination. Key elements of the definition included: 1) a continuous process, 2) an in-line 

conveyor, 3) typically cured in a oven, and 4) usually includes a top and bottom film 

during curing. Kemlite provided some comments on certain details of the definition, 

including the need for carrier films in all panel processes. Since Kemlite uses a steel belt 

on some of its processes to cure the product, Mr. Margherio suggested the use of the term 

"impervious surface" instead of "film" in the definition. Ms. Strum said that the definition 

would be reviewed and Kemlite's comments considered. 

Ms. Strum reviewed a number of possible formats for the continuous lamination 

standard. These included performance standards (pounds of emissions per pound of 

monomer, resin, or product) and a design/equipment standard (enclose process and route 

U 
P.6 

Madeleine Strum 

September 24, 1996 

Page 5 

captured emissions to a 95 percent efficient control device). On the basis of the low 

emission rate (0.33 percent of available monomer) calculated for Kemlite's Joliet facility, 

it appeared that this facility might move into the third ranking spot in the MACT floor 

table, just below the two facilities using incinerators. This would indicate a preliminary 

MACT floor for existing sources of 0.33 percent of available monomer. Mr. Smith 

stressed that Joliet's process was refined over several years, and it would be very difficult 

for existing sources to convert to that technology. 

ACTION ITEMS 

The meeting participants agreed to take the following actions: 

Party Action Agreed to 

1. EPA/PES Confirm whether the presence of Brady and Hay site, and the 

absence of Glasteel, in the subcategory are appropriate 

Revise definitions of continuous lamination and 

continuous casting per discussion 

2. Kemlite Check feasibility of doing a mass balance at Joliet 

Provide to the EPA pertinent information from 1991 test 

report. (This information has been received.) 

5 
P.7 

~ Headquarters 

P.O. Box 2429 

Jcfet. ffinois 60434 

Tel 815-467-8600 

Kemlite Company, Inc. 800-435-00&0 

Fax 815-467-8666 

CRANE Kemlite. 

KEMLITE / USEPA Visit on 8/19/96 

1. Discuss confidentiality of information. All printed material and 

discussion of Kemlite data must be held in confidence. 

2. Information on the EPA MACT effort. 

• What is the group's identification? How does it fit into the 

USEPA organization? 

• What is the group's charter? 

• What is the time table? 

3. What facilities are grouped into the subcategory in which 

Kemlite has been placed? What definition was used? 

4. Discussion of Kemlite's position based on attached outline. 

5. What is the current thinking on MACT regulations for the panel 

industry? 

Manufactuing F.TCiHir-o r !- iM I V'IIH til < '.'iii. .•- •: 

Jo6et. Illinois ^ England 

Jonesboro. Akansas Singapore 
P.8 

Attachment 2. 

• f I • • Headquarters 

CRANE K0 m |t© __£*££ 

• I W l • IMIA_S« Tel 815-467-8600 

Kemlite Company, Inc. soo 435 oo&o 

r

 " Fax 815-467-8666 

Kemlite Data 

Output in the range of million square feet per year, 

million from Joliet 

million from Jonesboro 

Resin consumption is in the range of 35 million pounds per year, 

itiillion from Joliet 

million from Jonesboro 

Monomer consumption 

Above resins contain 30 - 40% monomer as purchased 

Minor amounts of monomer are added to the resin during the 

processing. 

Kemlite Joliet process 

Schematic showing basic similarities/differences from the 

rest of the panel lines. 

Emission Data 

Schematic showing the computer system that supports 

conformance to the IEPA Operating Permit. 

Spread sheet showing one week of production of volume grades 

including the highest VOC emitting grade (FXI) . Data 

shows only resin mix and monomer data. Nothing 

proprietary could be derived from the data. 

Spread sheet showing monomer loss calculations for 

Jonesboro, Joiet, and Lasco. 

Joliet IEPA Permit 

Basic restrictions are: 

1. Cap on VOC emissions per hour (7.67 pounds/hr) . 

2. Cap on VOC content in purchased resins (43%). 

3. Option on conforming to one of the following: 

A. Cap on % VOC in resin mix deliverd to the panel line. 

B. Cap on emissions (60 grams/square meter of exposed 

resin). 

Joliet Title V CAAPP Application 

Jonesboro is not permitted by the Arkansas EPA. The facility emits 

under 10 TPY of VOC. Abatement achieved by an oxidizer having a 

95% destruction efficiency. 

: 

:

" .^"unr g Fsciiitie^ ".-••••;:• • •;;-•• 

Jdiet, Illinois England 
RESIN 

PROMOTER 

PIGMENT 

CATALYST 

KEMLITE CONTINUOUS PROCESS 

POLYESTER / GLASS FIBER PANELS 

JOLIET FACILITY 

promoted OdttLluSt ^^T5U5 

oA 

BOHOM FILM 

UNWIND 

± fcA>\ 

Shorter +^ a^ o>fta,r Imcs 

SQUEEZE ROLLS 

Coi 1! ^ £>y<_-\* 

rt_*el ^u__J_- -Wr\a«r>ana 

u.r<__ 

T~h_. ^0 ° -+_cWocy 

vjjois ou.-V -th<__ <nk*& 

CUT TO LENGTH 

TRIM TO WIOTH 

CURE D PANE L 

BOTTOM FILM 

WIND UP 

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P.10 

Emissions Data from Major Product Line Production - Week of 8/11/96 

Run time 

136 

128 

119 

308 

23 

63 

182 

297 

282 

38 

89 

424 

55 

480 

480 

76 

403 

312 

167 

172 

144 

163 

480 

191 

159 

117 

11 

170 

298 

63 

416 

116 

54 

479 

479 

479 

401 

194 

128 

173 

161 

17 

121 

38 

441 

479 

479 

479 

479 

Mix Used Err 

6562 

5872 

3844 

8506 

922 

2594 

8444 

7978 

7547 

2456 

5209 

24866 

1769 

15847 

15394 

2262 

14784 

11994 

7691 

8166 

6878 

7644 

19453 

12497 

10766 

7856 

741 

11612 

8803 

2053 

16791 

4337 

2116 

19400 

19681 

20028 

16822 

13091 

8275 

10909 

10347 

1081 

4378 

1366 

19575 

21347 

21725 

21137 

20934 

ission Lbs, l^ 

15.26 

13.62 

8.96 

20.54 

2.14 

6.01 

19.08 

18.50 

17.45 

1.66 

3.56 

17.16 

2.03 

17.02 , 

16.37 

2.41 

15.76 

12.79 

8.17 

8.67 

7.30 

8.13 

20.74 

7.25 

6.31 

4.60 

0.44 

6.94 

7.05 

1.65 

13.48 

3.46 

2.40 

22.11 

22.41 

22.73 

19.09 

7.32 

4.88 

6.59 

6.04 

0.61 

3.22 

1.01 

14.41 

15.91 

15.91 

15.20 

15.24 

don % Mix 

21.89% 

21.89% 

21.89% 

21.89% 

21.89% 

21.89% 

21.89% 

21.89% 

21.89% 

21.93% 

21.93% 

21.93% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

18.98% 

18.98% 

18.98% 

18.98% 

18.98% 

31.39% 

31.39% 

31.39% 

31.39% 

40.83% 

40.83% 

40.83% 

40.83% 

40.83% 

18.98% 

18.98% 

18.98% 

18.98% 

18.98% 

31.39% 

31.39% 

31.39% 

31.39% 

31.39% 

31.39% 

31.39% 

Avail Mon. 

1436.42 

1285.38 

841.45 

1861.96 

201.83 

567.83 

1848.39 

1746.38 

1652.04 

538.60 

1142.33 

5453.11 

722.28 

6470.33 

6285.37 

923.57 

!

 6036.31 

4897.15 

314024 

3334.18 

2808.29 

3121.05 

7942.66 

2371.93 

2043.39 

1491.07 

140.64 

2203.96 

2763.26 

644.44 

5270.69 

1361.38 

863.96 

7921.02 

8035.75 

8177.43 

6868.42 

2484.67 

1570.60 

2070.53 

. 1963.86 

205.17 

1374.25 

428.79 

6144.59 

6700.82 

6819.48 

6634.90 

6571.18 

% Loss 

1.06% 

1.06% 

1.06% 

1.10% 

1.06% 

1.06% 

1.03% 

1.06% 

1.06% 

0.31% 

0.31% 

0.31% 

0.28% 

0.26% 

0.26% 

0.26% 

0.26% 

0.26% 

0.26% 

026% 

0.26% 

0.26% 

0.26% 

0.31% 

0.31% 

0.31% 

0.31% 

0.31% 

0.26% 

0.26% 

0.26% 

0.25% 

0.28% 

0.28% 

0.28% 

0.28% 

0.28% 

0.29% 

0.31% 

0.32% 

0.31% 

0.30% 

0.23% 

0.24% 

0.23% 

0.24% 

0.23% 

0.23% 

0.23% 

Loss Rate 

Lbs/hr 

6.73 

6.38 

4.52 

4.00 

5.58 

5.72 

6.29 

3.74 

3.71 

2.62 

2.40 

2.43 

2.21 

2.13 

2.05 

1.90 

2.35 

2.46 

2.94 

3.02 

3.04 

2.99 

2.59 

228 

2.38 

2.36 

2.40 

2.45 

1.42 

1.57 

1.94 

1.79 

2.67 

2.77 

2.81 

2.85 

2.86 

2.26 

2.29 

229 

225 

2.15 

1.60 

1.59 

1.96 

1.99 

1.99 

1.90 

1.91 

1 
P.11 

Emission Loss of Avaiiabie Monomer Process Loss % (1) 

Kemlite/Jonesboro: 

(emission test runs) 

Line 4 

Line 5 

Kemlite/Joliet 1995 

(year 1995 totals) 

Lasco: 

mass balanace test rur 

Total Mix 

lbs. 

840 

3344 

44573230 

Total Monomer; Emissions 

lbs. , lbs. 

260.4 

1203.84 

13104530 

437.1 

5.68 

48.65 

43510 

< 

11.9 

% Loss 

2.18% 

4.04% 

• 

0.33% 

2.72% 

Abated Loss % (2) ! 

! 

I 

0.11% 

0.20% 

NA 

NA 

Notes: 

(i) Process Loss %= Emissions fibs.) x100 

(Total lbs. available 

monomer delivered 

to the process) 

(2) Jonesboro facility RTO destruction efficiency is 95%. 

lo