p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

19) ll-B-14 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:11 AM Sheet 19 of 57 
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A-94-52 

ll-fi-lf 

FINAL NONCONFIDENTIAL SITE VISIT REPORT 

PER COMPANY REVIEW 

TO: Madeleine Strum 

U.S. Environmental Protection Agency 

FROM: Kenneth R. Meardon and Melanie Proctor 

Pacific Environmental Services, Inc. 

DATE: April 22, 1997 

SUBJECT: Site Visit to Cytec Industries 

I. Purpose 

The purpose of this visit was to discuss emission reduction measures considered and 

implemented by Cytec Industries in support of the development of MACT standards for the 

BMC manufacturing subcategory of the Reinforced Composite Plastics NESHAP. 

II. Location and Date 

Cytec Industries, Inc. 

12600 Eckel Road 

Perrysburg, Oliio 43552 

July 25, 1996 

IH. Participants 

Cytec Industries 

Robert Leitzman, Plant Manager, Perrysburg, OH 

Stephen V. Byrne, Regulatory Specialist, Linden, NJ 

Jennifer DeMarco-Handley, Environmental/Safety Coordinator 

U.S. Environmental Protection Agencv 

Madeleine Strum, Project Manager 
~ 

Ms. Madeleine Strum 

April 22, 1997 

page 2 

Ohio Environmental Protection Agencv 

Chad Delbecq, Division of Air Pollution Control* 

• 0 

Pacific Environmental Services. Inc. 

Kenneth R. Meardon, Senior Environmental Scientist 

Melanie Proctor, Environmental Scientist 

* Mr. Delbecq was only present during the morning discussion. 

IV. Discussion 

Mr. Leitzman noted that he just received the site visit letter on Monday, July 22, 1996, 

and they did not have time to assemble the requested infonnation. He suggested that we 

review their process and then identify the items requested in the site visit letter that we still 

needed additional information on. He also requested that the EPA send him a copy of the 

contract with PES to ensure that PES is subject to the same confidential business information 

(CBI) procedures and responsibilities as the EPA. Ms. Strum indicated that she would do this. 

Mr. Meardon briefly explained the in-house procedures that PES follows for handling CBI and 

how the site visit report will be prepared and submitted to Cytec for their review. It was also 

noted that a non-CBI version would be created and that the CBI-version would be retained in 

the CBI files at PES or EPA or both. 

Using a series of overhead slides (see Attachment 1), Mr. Leitzman began with a 

presentation overview of Cytec Industries. Cytec was formed in December 1993, when it was 

spun off from American Cyanamid, and is comprised ofthe chemical business formally owned 

by American Cyanamid. Cytec's home office is in West Patterson, NJ. Cytec has total sales 

of approximately $1.2 billion per year. There are approximately 5,000 people in the 

company, with 32 locations worldwide, including sales offices and production facilities. 

The Perrysburg facility is the only Cytec plant that manufactures bulk molding 

compound (BMC). They have manufacturing operations, a warehouse, and a product 

development center at the facility. Cytec has essentially the same people, plants, and 

operations as when owned by American Cyanamid. 

s 
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Ms. Madeleine Strum 

April 22, 1997 

page 3 

Mr. Leitzman reviewed the Perrysburg facility's history, which included the plant 

start-up in 1960. 

Mr. Leitzman then presented a summary overview of the BMC production operations. 

Three basic resins are used at the facility — vinyl-toluene-based resins, styrene-based resins, 

and diether-based resins. Some vinyl-toluene-based resin products also contain styrene in 

addition to vinyl-toluene. The BMC mixers at Cytec, range in capacity from 25-gallons to 

600-liters (about 160 gallons). None of the mixers are pressurized. Approximately 300 

different products are produced, representing many combinations of resins, fibers, fillers, and 

colors. The facility produces BMC in both one-step (i.e., the paste mixing and compounding 

is performed in a single vessel) and two step processes (i.e., the paste mixing and 

compounding occurring in different tanks). 

Once produced, the BMC is either packed in bulk form or extruded into one of several 

shapes (rope, log, slug) and then packed. The packaged BMC is placed in cold storage on site 

and then shipped to the customer. Cold storage extends the shelf-life of the BMC before it is 

used. 

After the brief process overview, Mr. Leitzman asked a series of questions: 

1. Why is Fibercast in the same subcategory as Cytec? Mr. Leitzman explained 

based on Cytec's information Fibercast just produces centrifugally-cast pipe. 

Ms. Strum explained that Fibercast has several subcategory operations, 

including BMC manufacturing and that it is on this basis that die two facilities 

are included in the BMC subcategory. Ms. Strum further explained the general 

approach for defining existing and new source MACT floors and pointed out 

that the level of control considered for the BMC subcategory is based only on 

the controls associated with the BMC portion of each facility in the subcategory. 

Ms. Strum also noted that her preference is to set a performance standard if 

possible (I. e. pounds of emissions per ton of material produced). 

2. Is there a "baseline" year on which the standards are being set? 

Ms. Strum replied that even though most of the information was collected in the 

1993 surveys, the EPA is updating the information in its database whenever 

new information is found about a facility. 

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Ms. Madeleine Strum 

April 22, 1997 

page 4 

What is the definition of "affected source"?. 

Ms. Strum replied that the EPA is still working on the "affected source'' 

definition for this source category. One possible option is to define an "affected 

source" that is subject to the new source standard as a source which has been 

modified and where reconstruction costs represent at least 50 percent of the cost 

for the entire facility. 

What is the timetable for the standard? 

Ms. Strum stated diat the reinforced plastics NESHAP was scheduled to be 

proposed by November 1996 with promulgation occurring November 1997, but 

these dates have been postponed. The latest dates are April 1997 for proposal 

and April 1998 for promulgation, but Ms. Strum noted that she was not sure 

that these latest dates could be met. 

What is the timetable for compliance once the standard is promulgated? 

Ms. Strum explained that the timetable could vary depending on the specific 

requirements of the rule, but that the Clean Air Act allows for up to 3 years 

after promulgation for compliance, wim the possibility of extending compliance 

to a fourth year. 

How is profitability considered in determining the standards? 

In reply, it was noted that when setting a standard at the MACT floor, which is 

required by die Clean Air Act, profitability impacts are analyzed, but the 

standard is still set to be at least as stringent as the MACT floor. 

Is there an emission tiireshold below which me standards do not apply? 

Ms. Strum replied that standards are expected to apply only to major sources 

since die reinforced plastic composites industry was listed as a major source 

category (an area source category finding has not yet occurred). By definition a 

major source has the potential to emit 10 tons per year of a single HAP or 25 

tons per year of a combination of HAP. 

H 
P.6 

Ms. Madeleine Strum 

AprU 22, 1997 

page 5 

Mr. Leitzman noted mat Cytec's HAP emissions are limited to styrene and memylene 

chloride. He men noted diat the State of Ohio has a rule that limits VOC emissions to 8 lbs/hr 

or 40 lbs/day, which is applicable to each of meir mixers. Their odier operations diat emit 

HAP include extrusion and packaging, but mey are not subject to die Ohio rule. Mr. 

Leitzman also noted diat based on emission modeling results the facility is in compliance. 

In looking at ways to comply with die Ohio regulation, Cytec considered downstream 

controls. They stated diat mey examined all of me add-on controls, including mermal 

oxidation, catalytic oxidation, and carbon adsorption (bodi nitrogen stripping and steam 

stripping), but found mem prohibitive from a cost perspective. They also examined 

condensation and biofiltration. 

Cytec tested die use of condensation as an emission reduction technique on their 

mixers. A condenser was installed on a collection line to capture styrene as it escaped die 

mixer. The condensed styrene was dien fed back into die mixer. According to Cytec, die 

concentration of me styrene exiting die mixer was so low that die condenser could not 

condense it and no styrene was being returned to me mixer. Cytec could not recall die 

operating temperamre of the condenser. They pointed out diat die concentration of me styrene 

leaving the mixer was below saturation at the temperamre of die condenser, in die 500 ppm 

range, and dius was not near a condensible concentration. Mr. Leitzman noted diat Cytec 

tested die condenser after some of die ventilation optimization techniques were put in place, 

and dius die concentrations would be expected to be lower dian previously. 

Biofiltration was ruled out as an emission control option for BMC production because 

Cytec did not believe it to be a well-established technique. Cytec noted diat me U.S. 

Department of Energy has a biofiltration unit in operation and Ms. Strum noted mat a unit in 

Sweden is being used to control styrene. Cytec pointed out diat diey have a biofiltration unit 

in a Cytec plant in Maine, but mat die costs of operation have not been fiilly identified. They 

noted diat mat unit has to be heated during die winter and is currently being plagued widi a 

centipede/millipede infestation. Based on Cytec's estimates, the costs of a biofiltration unit 

would run approximately $1 million capital wim annual operating cost around $300,000 to 

$400,000. 

To estimate emissions from their mixers, Cytec tried material balances and odier 

similar analytical methods, but found diem to be all non-repeatable. On die odier hand, they 

conducted carbon mbe testing and found very good repeatability in die results. Ms. Strum 

expressed concern over diis technique and asked how soon die tubes were analyzed after die 

5 
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Ms. Madeleine Strum 

April 22, 1997 

page 6 

samples were collected. Mr. Leitzman replied diat the samples were chilled and dien sent out 

overnight for analysis. According to Mr. Leitzman, die repeatability of me results seem to 

indicate diat diis method provided reliable results. The State of Ohio is having Cytec conduct 

a source test in me near fiimre on one of die mixers. This source test will be used to validate 

die carbon mbe testing Cytec has conducted. 

Based on customer requests, Cytec replaced styrene widi vinyl-toluene, a non-HAP, in 

some resin formulations. They have done diis in a number of formulations, and believe diey 

have gone about as far as diey can. Cytec also noted diat vinyl toluene is more expensive dian 

styrene and has a higher odor direshold (I. e. is less of an odor problem). 

To meet the Ohio regulations, Cytec went back to die actual mixing operations to 

determine how emission reductions could be achieved without using add-on controls. One 

modification was die placement of covers on each of die open top mixers. The mixers are 

operated widi covers diat fit over die area used to add die raw materials. The automated lines 

are completely closed except when emptying. The mixers do vent (namral draft not dirough 

forced ventilation) during mixing around die sides of die covers, which are sealed, and die 

vented emissions are captured dirough a hood and vented to die atmosphere. The automated 

lines vent directly dirough a pipe containing a butterfly-type valve, which is in die closed 

position during mixing. A small amount of space remains around die edge of die valve 

allowing vapors to escape. Based on stack testing, Cytec has seen an emission reduction of 

about a 50 percent at die entire plant level after covering the mixers. Since me facility has 

emission sources other dian mixers, which were not modified by emission reduction measures, 

Cytec expects die percent emission reduction achieved at each mixer to be much higher than 

50 percent. 

Since 1992 or 1993 Cytec maintains a non-explosive environment within some of their 

mixers by using a mtrogen-blanket. They noted diat die nitrogen-blanket can force styrene out 

of die resin, so die amount of nitrogen used needs to be optimized, in order to minimize 

styrene emissions. Cytec noted diat dieir corporate policy is to maintain concentrations to less 

man 25 percent of die lower explosive level (LEL) of styrene, but in practice die aim to keep 

concentrations to less 10% ofthe LEL for styrene. 

Cytec also examined dieir ventilation systems on die mixers, as to how each is 

evacuated. Originally, each of die open top mixers were evacuated using a side vent diat 

pulled air from widiin die mixer during mixing. They noted diat die harder die ventilation 

pulls on die mixers, the more styrene is lost. Thus, diey attempted to optimize die ventilation 

rate in conjunction widi die nitrogen going in for me nitrogen blanket. This optimization has 

led diem to eliminate this side vent completely from the mixers during mixing. Instead, mere 

is no active evacuation of die mixer during mixing. When me product is removed from the 

6 
P.8 

Ms. Madeleine Strum 

April 22, 1997 

page 7 

mixer, there is a side vent diat pulls air across die top of die open mixer to remove styrene 

emissions from die room. There are also vents along the bottom of the mixers and top of die 

mixers to remove air from around die mixer or to capmre particulates during filling of the dry 

material. The purpose of these vents is to reduce worker exposure to styrene and particulates. 

According to Cytec, die addition of die covers and die optimization of the ventilation 

rates resulted in more styrene staying in die BMC. The reduced styrene losses allowed Cytec 

to reformulate their resin mixture wim less amounts of styrene input dian before die emission 

reduction techniques were applied. 

V. Plant Tour 

The first mixer observed had an opening in die top of die mixer mat is opened to add 

die resin and fillers. The resin is added via a tap on a resin barrel diat is suspended from a 

hoist. When adding resin, die barrel is moved via die hoist to die mixer and die tap is opened. 

The amount of resin added is monitored using a scale diat weighs die suspended barrel. Once 

die initial ingredients are added, die opening in me top of the mixer is covered, and mixing 

begins. Fiberglass is placed in a chute over die mixer. The opening in die top of die mixer is 

then opened again to allow the fiberglass to enter die mixer. This is done dirough vibration of 

die chute and extended "fingers" help distribute die fiberglass more evenly into the mixer. 

After die fiberglass reinforcement is added, die opening in the top of die mixer is covered and 

mixing resumes. Once the cycle is completed, die tank is opened and tipped forward, and die 

BMC is removed manually. 

During mixing, the top of die mixer, which has an opening to add raw materials, is 

covered widi a somewhat tight fitting cover. A difference in die fit of die covers was observed 

between the different mixers. According to Cytec, adding die cover cut down noticeably on 

die styrene odor and emissions. Vents at die back of die top of die mixer, which pull air 

perpendicular to die covered opening in the top of die mixer, are used to capmre emissions 

during die filling of die mixer and emissions that leak around die sides of die covers during 

mixing. There appeared to be a very strong pull, especially from one ofthe vents. There is 

no active evacuation of the head space of die mixer once it is in operation. The capmred 

emissions from the vent at die back of die top of die mixer are vented dirough a baghouse to 

die atmosphere. Not all mixers at Cytec have nitrogen blanketing. 

Another mixer observed during die plant tour is a jacketed mixer for cooling and 

heating. All of die additive materials, including die fiberglass and filler, are added to a hopper 

diat is hydraulically lifted tb die top of die mixer and die material is dropped in dirough an 

opening in die top of die mixer. A vent at die top of mixer evacuates and captures die 

particulate emissions diat occur during die addition of diese materials and vents diem to a 

1 
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Ms. Madeleine Strum 

April 22, 1997 

page 8 

baghouse. When asked, Cytec noted diat diey have never seen any styrene polymerization in 

their baghouses. The resin is added via a retractable pipe line over die top of die mixer. If 

required, additional styrene is hard-piped directly into die mixer. Nitrogen is also hard-piped 

into the mixer to provide die nitrogen-blanket. 

A cover is placed over die opemng dirough which die raw materials are added. The 

cover is fairly tight fitting, but still allows room for emissions to escape from the mixer during 

operation. These emissions are captured by die same vent used to capture particulate 

emissions during filling of raw materials. There is no active evacuation of air widiin die 

mixing vessel during operation. 

Once die mixing cycle is completed, die mixer is opened and tipped over to allow 

access to remove die BMC, which is done manually. There is a side-vent diat pulls air across 

die top of die mixer when it is opened. In addition, mere is a bottom vent to pull away 

emissions from the bottom when die mixer is tipped over to remove the material. These two 

vents and die top vent are always "on" and continually pull air away from die mixer. When 

die mixer is closed, die bottom and the side-vent pull air from the production room. The total 

flow from die evacuation vents around diis mixer is estimated to be approximately 1,300 cftn. 

Resin is fed directly (hard piped) into anodier mixer, which is enclosed, from barrels 

stored on die second level. The dry materials are weighted or measured and dien placed 

manually into one of two hoppers on top of die mixer. These hoppers are opened in a certain 

sequence to drop die material into die mixer. For one hopper, a rotating set of vanes (similar 

to a revolving door) moves the material into the mixer. Pre-chopped fiberglass is also fed into 

die mixer via a conveyor belt. The order in which diese material are added varies depending 

on die specific BMC product. 

The mixer has an induced draft pulled on it by die baghouse fan. During filling, 

displacement air is vented dirough a pipe to die baghouse. The butterfly-type valve in die line 

is open at this time to allow displacement of air. Since air displacement does not occur during 

mixing, me valve is closed to reduce the draw on die mixer. A small amount of space remains 

around die edge of die valve to allow vapors to escape. Flow from the mixer is estimated to 

be 150 cftn witii a concentration of 600 ppm. 

At die conclusion of die mixing cycle, the bottom of the mixer opens up and drops die 

finished BMC onto a conveyor belt. The conveyor belts moves die BMC to die extruder belt, 

where it is fed dirough an extruder and extruded as "slugs." The slugs are then placed into a 

cart, and as diey are stacked diey are covered widi plastic at different points. 

1 
P.10 

Ms. Madeleine Strum 

April 22, 1997 

page 9 

Anotiier enclosed mixer uses chutes and hoppers to add dry materials dirough a 

hydraulic door. Once mixing is begun in diis vessel, it is closed, but some emissions are still 

allowed to emerge out of die vents. 

Emission Reductions. When asked about die measurements diey have taken so far on 

die mixers and tiieir effectiveness, Cytec estimated diat emissions after modifications for one 

of dieir mixers showed an emission reduction of about 67 percent. 

Mr. Leitzman explained diat storage tanks are vented to die atmosphere and die vents 

are equipped witii flame arresters. 

Mr. Leitzman noted diat one of Cytec's mixers with a long batch cycle time was found 

to emit more dian anotiier mixer with a short batch cycle time. Cytec noted diat mixing time 

is an indicator of die efficiency of die mixer, but diat not all formulations could be mixed at 

die same rate. The key in producing BMC is to provide enough time to ensure everything is 

properly mixed, witiiout agitating die material excessively. Finally, Cytec noted diat some 

formulations simply can not be "rushed" and diat die namre of die formulation will require a 

longer mix time. 

VI. Review of Site Visit Questionnaire 

After die plant tour, die site visit questionnaire was reviewed to ensure all of die points 

were covered and to identify specifically die additional information Cytec would provide at a 

later date. 

Witii regard to production information, Cytec said diey could provide it, but tiiat it 

would be CBI. They again noted diat diey have about 300 different formulations, but mat 

about 75% of what they produce can be classified into 6 or 7 products. Some of their major 

markets/products include headlight housings, valve covers, circuit breakers, and toaster oven 

end pieces. They noted tiiat headlight housings needed certain heat resistant and assembly 

properties, mat valves covers needed certain heat and flame resistant properties, and tiiat 

circuit breakers needed certain heat and electric charge resistant properties. Cytec noted tiiat 

the toaster oven end pieces are not painted afterwards, but are produced witii various colored 

BMC products. The high gloss achieved is a function of die BMC itself, additives, and die 

molds used to produce die piece (chrome-plated, highly polished). Cytec stated diat diey could 

provide die total annual production of BMC, but not by product. They also stated diat diey 

could supply a price list. (The above mentioned infonnation, which was provided by Cytec 

on October 21,1996, is shown in Attachment 1). 

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Ms. Madeleine Strum 

April 22, 1997 

page 10 

With regard to process description, Cytec noted again tiiat they plan make some 

process changes to one of their mixers. In doing tiiis, they will still use the current holding 

tanks for die mixer. These will serve the same function as the drums used to fed die resins to 

the otiier mixers in tiie facility. Cytec noted diat diey have no expansion plans at diis time. 

Most of die growdi in the business is likely to come from in-roads they can make in the metals 

market. 

Ms. Strum asked about growth in die thermoset resins versus the thermoplastic resins. 

Cytec noted diat tiiere is greater interest in using thermoplastics by some of their markets 

because thermoplastics are less expensive and die higher properties (e.g., heat resistance) of 

thermoset resins may not really be needed in some applications. 

Mr. Leitzman was asked to provide information from material safety data sheets 

(MSDS) for die different resins used at Cytec. Ms. Strum pointed out diat the only 

information from the MSDS needed is die styrene content of die different resins used. Mr. 

Leitzman promised to provide a summary table of tiie styrene content in each of Cytec's 

resins. (This information, which was provided by Cytec on October 21,1996, is shown in 

Attachment 1). 

When asked about die use of cleaners, Cytec noted tiiat they use methylene chloride 

primarily because they have frequent color changes in their products. Color changes are done 

in die smaller mixers. If Cytec is not doing any color changes, they use other non-HAP 

cleaners. Cytec also attempts to produce lighter colored products earlier in die sequence and 

switch to darker colors toward die end of die sequence to avoid cleaning in between color 

changes. For example, switching colors from grey to black requires no equipment cleaning, 

whereas a color change from black to grey does require cleaning. When asked how frequentiy 

diey make color changes, Cytec stated diat for one of tiieir mixers they may go a day or two 

with no color changes, but on some days it may be as many as 15 or 16 color changes per 

mixer. Such a large number of color changes would be very unusual and does not imply that 

mere would be 15 or 16 cleanings because they try to go from light to dark colors. 

Cytec noted that dieir metiiylene chloride usage has dropped significantly from 3 years 

ago. They use Thermoclean for some applications, but have not been able to use it for color 

changes. Thermoclean is a sodium medasilicate, which needs to be heated to around 150°F. 

They cannot use it for color changes because they need a quick turnaround time on the mixer. 

(Based on information provided by Mr. Leitzman, Cytec will discontinue the use of all 

HAP containing cleaners in early 1997). 
P.12 

Ms. Madeleine Strum 

April 22, 1997 

page 11 

When asked about die cost of die modifications to the mixers, Cytec estimated tiiat they 

probably spent somewhere between $35,000 and $50,000 total for all of die mixers. Cytec 

agreed to provide more specific information on the costs. It was suggested that this 

information could be provided in the form of materials and labor required and diat EPA would 

then estimate the costs. (This information, which was provided by Cytec on October 21, 

1996, is shown in Attachment 1). 

VII. Action Items (All the information requested below was provided by Cytec on 

October 21, 1996. The information is shown in Attachment 1). 

Cvtec 

1. Provide as much detailed information on the source tests as possible for each 

mixer, especially process information like the amount of HAP going in and 

coming out of die process. 

2. Performance data to calculate the pounds of HAP emitted per pound of product 

produced for each individual mix system before and after the emission reduction 

technique was put in place to calculate the overall perfonnance of your 

operation. 

3. .Amount of HAP cleaner usage per ton of product. 

4. HAP content of resins (or MSDS — "ingredients" page only) plus die amount of 

HAP added. 

5. Cost data or materials and labor requirements for modifications to die mixers. 

6. Copies of overhead slides. 

7. Provide information about dietiier-based resin products and explain if these 

products also contain styrene or other HAP. 

M 
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/tHtthto,*! 3 

CVTEC 

CYTEC INDUSTRIES INC. 

P.O. Box 148 

Perrysburg, OH 43552 

Tel: (419) 874-7941 PUBLIC DOMAIN 

Oaober 21,1996 

Dr. Madeleine L. Strum 

United States EPA 

Office of Air Quality Planning and Standards 

Emissions Standards Division ' '•'•' 

MD-13 

Research Triangle Park, NC 27711 

RE: Manufacturing and Emissions Data for BMC MACT 

Dear Dr. Strum: 

Pursuant to your request fbr additional information to assist in me MACT detennination for die Bulk 

Molding Compounds mdustry, we are enclosing die infonnation requested as discussed at our Jufy 25, 

1996 meeting. 

Due to die nature ofthe infonnation requested, we inquired about existing confidentiality agreements 

between die agency and it's contractors. Dr. Meardon provided us with a copy ofthe confidentiality 

agreement and associated infonnation firom die EPA contractor, PES. Discussed during the meeting, a 

portion of u e infonnation being submitted is confidential business information- We request that all 

information stamped 'Trade Secret" be kept confidential An identical version of diis packet, marked 

"Public Domain", is also attached, with all confidential information blacked out 

The attached information is a compilation of me documents reviewed and/or requested during die 

7/25/96 meetmg and addresses die following topics: 

Copies of the overhead slides shown during die meeting 

Dichloromethane usage 

List of high volume process raw materials & components 

Pre & post modification emissions numbers 

A brief description of each attachment precedes tie attachments and will assist in die understmdmg tie 

information. 

\Z 
P.M 

PUBLIC DOMAIN 

Due to the variability of processes included in the BMC Source category, we support EPA's interest in a 

>erformance-based standard (e.g. Ib HAP/ton product produced). This approach is advantageous for die 

following reasons: 

• it encourages pollution prevention 

• it provides flexibility to regulated facilities 

• it is less prescriptive, which is consistent with initiatives to streamline 

environmental regulation 

• add-on controls are not amenable to some ofthe process equipment used in BMC 

facilities. 

Due to die relative vintage ofthe processes, and the success we have achieved on emissions reductions, 

;ve recommend that tile performance of flHHHHHHHMHH^e considered New Source 

md Existing Source MACT, respectively. 

.•\kematively, the work practice standards developed by Cytec which achieved significant emissions 

reductions could be specified as MACT (e.g. fJ///_____J/K-Wt minimize oo&cer ventilation, keep 

product covered). 

Our discussion on MACT was a learning experience for us as I am sure it was fbr you. The Perrysburg 

Plant is very interested in the development ofthe MACT detennination fbr our industry and I am sure 

you will find die attached infonnation useful. If you have questions regarding this information, or need 

additional information, please do not hesitate to call me at (419)874-7941, ext 411 or Jennifer DeMarcoHandley at ext. 432. 

Sincerely, 

CYTEC INDUSTRIES INC. 

Robert A Leitzman 

Plant Manager 

jdh 

ittachments 

ZOPY: Dr. Kenneth Meardon 

Ms. Melanie Proctor 

Pacific Environmental Services, Inc. 

Central Park West 

5001 S. Miami Boulevard 

.PO Box 12077 

Research Triangle Park, NC 27709-2077 

TLE: MACTCOVE.WPD/JDH 

Mr. Chad Delbecq 

Ohio EPA, NWDO 

Div. of Air Pollution Control 

347 N. Dunbridge Road 

P.O. Box 466 

Bowling Green, Ohio 43402-0466 

13 

Page 2 
P.15 

PUBLIC DOMAIN 

DESCRIPTION OF ATTACHMENTS 

A brief description of each attachment, as follows, will assist in the understanding the information 

attached. 

Overhead Slides - Attachment I 

Copies of die overhead slides shown during the meeting on 7/25/96 include a summaiy of dje physical 

location ofthe Cytec Perrysburg Plant, WK__\^t___\ a general process flow diagram and an overview 

of some ofthe employee programs in which many ofthe employees participate. 

Lbs. Stvrene Emission/Ton Styrenated Product Manufactured - Attachment ITI 

Attachment m includes die emissions divided by the tons of styrenated BMC manufactured for the given 

year. Modifications J^^BHHHHHflflHH B

 wer e

 -itiated in the 4th quarter of 1995, 

therefore, the post-modification emissions data(see Attachment VI) was only used in a portion ofthe 

emissions calculated for 1995. 

High Volume Resin Prices - A^c}\rj}mt TTT 

Two types of resin containing VOCs are used at the Perrysburg Plant, including styrenated resins and 

vinyl toluene based resins. Ihe highest volume resins and the list price per pound of these resins are 

included. 

Dichloromethane Usage - Attar^-me-nt TTT 

Methylene Chloride is used for cleaning the mixers, extruders and parts between color changes. Listed in 

this attachment is the total amount of Methylene Chloride emitted per ton of all production in 1995, 

including the non-VOC containing BMC. 

I'i 
P.16 

PUBLIC DOMAIN 

DESCRIPTION OF ATTACHMENTS (CONT.) 

ist of High Volume Process Raw Materials & Components - Attachment TV 

i.ttachnient IV is a list ofthe high volume raw materials and the percentage of components of these raw 

latenals utilized at the Perrysburg Plant. Included in the Ust are the styrenated and vinyl toluene based 

isins. 

•Te & Post Modification Emissions Rates- Attachment VI 

.Tie emissions data measured through in-house testing before and afler modifications were made^ H 

This attachment 

ichides the highest data point measured after die initial moomcanons were completed, as weU as the 

verage ofthe data for each product, both pre and post modification. 

HE: MA.CTCOVR.WPD/JDH 

\5 
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ATEaCWENT I 

POLYESTER MOLDING COMPOUNDS 

PERRYSBURG PLANT 

FACILITIES 

o Location 

- Perrysburg Township 

Wood County, Ohio 

o Plant Property 

•i 

- 65 Acres total 

o Buildings 

Manufacturing/Warehousing 

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ATTACHMENT I (CONT.) 

PUBLIC DOMAIN 

•TM» 

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ATTACHMENT III PUBLIC DOMAIN 

CYTEC INDUSTRIES INC. 

MACT INFORMATION 

•4NUAL EMISSIONS (LBS)' 

^;.:il.jli;^i;j^:ip;^SI^R£lji 

1995 45,920 

1994; 48,380 

95 METHYLENE CHLORIDE USAGE 

pCiPaiSi^Biiii 

23,320 

39,820 

53,480 

missions numbers are from annual Air Fee Emissions Report. 1994 & most of 1896 emissions 

ased on gravimetric emissions numbers. The most current emissions data is based on 

al emissions testing 

MACTINF0.WK4/JDH 

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ATTAOSENr I(GGNT.) 

Employee Partidpatiion 

Quality Improvement Teams 

Cost Improvement 

Customer Liaison 

Raw Materials 

Capital Improvement 

Housekeeping 

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PUBLIC DOMAIN 

ATTACHMENT IV 

CYTEC INDUSTRIES INC. PROCESS RAW MATERIALS/COMPONENTS 

RAW MATERIAL 

RESINS - HIGHEST VOLUME 

STYRENE BASED 

RESIN #1 

RESIN #2 

WWYL TOLUENE BASED 

RESIN #1 

MONOMER 

FILLERS - HIGHEST VOLUME 

FILLER #1 

FILLER #2 

FILLER #3 

REINFORCEMENT RBERS 

FIBER #1 

RBER #2 

ALYSTS/INHIBITORS - HIGHEST VOLUME 

SOUD CATALYST 

SOUD INHIBITOR 

UQUID CATALYST #1 

UQUID CATALYST #2 

COMPONENTS 

STYRENE ' 

CALCIUM CARBONATE 

ALUMINA TRIHYDRATE 

KAOUN CLAY 

CHOPPED STRAND RBERGLASS 

SIZING 

NYLON FLOCK 

BENZOYL PEROXIDE 

WATER 

BUTYLATED HYDROXY TOLUENE 

Di - (2-ethylhexyl)phthalate 

Butyl benzyl phthalate 

t-BUTYL PERBENZOATE 

EEBQENI 

VINYL ESTER RESIN 

STYRENE 

POLYESTER RESIN 

STYRENE 

POLYESTER RESIN 

VINYL TOLUENE 

60-70 

• .30-40 

68-70 

30-32 

68-72 

29-33 

100 

100 

100 

9-5-100 

97-99 

<1-3 

100 

75 

25 

25 

10 . 

99-100 

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PUBLIC DOM/IIN 

ATTACHMENT IV (CONT.) 

CYTEC INDUSTRIES INC. PROCESS RAW MATERIALS/COMPONENTS 

PIGMENTS • HIGHEST VOLUME 

SOUD PIGMENT #1 

SOUD PIGMENT #2 

PASTE PIGMENT #1 

PASTE PIGMENT #2 

DDIIWES - HIGHEST VOLUME 

TRACE ADDITIVE #1 

TRACE ADDITIVE #2 

TRACE ADDITIVE #3 

CARBON BLACK 

ZINC SULFIDE 

2, B/BON RED ORGANIC PIGMENT 

UNSATURATED POLYESTER RESIN 

CARBON BLACK 

IRON OXIDE 

UNSATURATED POLYESTER RESIN 

CALCIUM STEARATE (TECHNICALLY PURE) 

HYDRATED AMORPHOUS SIUCA 

POLYETHYLENE POWDER 

100 

98 

27 

73 

12 

23 

65 

100 

87(MIN) 

100 

TRACE ADDITIVE #4 

TRACE ADDITIVE #5 

TRACE ADDITIVE #6 

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ATTACHMENT VI PUBLIC DOMAIN 

EMISSIONS REDUCTIONS THROUGH PROCESS MOOIRCATIONS 

PERRYSBURG FACILITY '• 

Highest & Average Emissions Measured, Lbs VOC Emitted/Lbs VOC Used 

Prod. Group 

Prod. 1 

Prod 2 

Prod. 3 

Prod. 4 

Highest Emission 

Pre-Modificatlon 

0.0195 

NA 

0.0134 

0.0192 

Average Emission 

Pre-Modificatlon 

0.0131 

NA 

0.0128 

0.0160 

Highest Emission 

Post Modification 

0.0028 

0.0038 

0.0074 

0.0055 

Average Emission 

Post Modification 

-0.0022 

" 0.0024 

0.0043 

0.0044 

Prod. Group 

Prod.1 

Prod. 2 

Prod. 5* 

Prod. 6 

Highest Emission 

Pre-Modiffcatfon 

NA 

0.0399 

NA 

NA 

Average Emission 

Pre-Modification 

NA 

0.0340 

NA 

NA 

Highest Emission 

Post Modification 

0.0058 

0.0125 

0.0270 

0.0140 

Average Emission 

Post Modification 

0.0043 

0.0110 

0.0209 

0.0099 

"Currently not manufactured^ 

The measurements shown represent the highest and average ofthe emissions 

recorded for each product group through in-house testbig. NA indicates this product was not manufactured 

and, consequently, not measured unto after the modifications were made. 

In most cases, the highest emissions data point was measured after the initial 

modifications were complete. Modifications to the mixers have continued 

throughout our ongoing emissions reduction project 

FILE PREiPOST.WK^OH • 9/23/96 

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P.24 

Docket No. A-94-52 

Category II-B 

The following information is located in the confidential files ofthe Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This information is 

confidential pending final determination by the Administrator and is not available for public 

inspection. 

Copy 1 - Site Visit report dated 3/5/97, 30 pages 

CN-N404-11 

96185-C18-08 

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