p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

70) ll-E-30 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 70 of 264 
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3-29-1995 11:35 513 746 8087 DURIRON EPP 

1DURC0 

THB DURIRON COMPANY, JN 

8PRINQBORO OPERATIONS 

ROTATING EQUIPMENT BUSINE88 UNIT 

FAX TRANSMITTAL 

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SENT TO: 

NAME: 6Jg«]k 2U»SJ*K 

COMPANY: 

FAX NUMBER: 

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FROM: 

NAME: /)*K AJ/i*ei 

FAX NUMBER (513) 746-6087 

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DATE: ffef/tr 

SUBJECT: 

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70S PLEASANT VALLEY ORIVE/fiPRINGBORO. OH 4S06e.>HONe! S 13-746-8300 • FAX: S13-74e-BOH7 
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08_23-i995 1i:35 513 746"8087 DURIRON EPP P.02X04 

CONTACT REPORT 

From: Wanita Dunston, US Environmental Protection Agency 

Madeleine Strum, US Environmental Protection Agency 

Date ef Contact: August 9,1995 

Contact: Donald Winegar, Senior Engineer 

rjomp-nv/Agencv! The Duriron Company, Inc. 

Telephone Number; (S 13\ 746-8300 

CONTACT SUMMARY 

Notes prepared by Wanita Dunston. 

• Statement of purpose to Donald Winegar, from Wanita Dunston: EPA is developing a 

MACT standard to reduce HAP emissions from the reinforced composite plastics industry. 

A survey was sent in August 1993 to facilities that manufacture reinforced plastic 

composites. The purpose of the survey was to investigate the types of emission control 

devices being used, such as incinerators. 

• WHAT IS THE VOLUMETRIC FLOW RATE THROUGH THE CONTROL DEVICE? 

We don't deal in these terms normally. A few factors come in with regard to our 

operations. I (Donald) will look into my records. I normally deal in lb/hr, Ib/s, etc. There 4* -

is no way to measure that machine hot; we can measure it cold, but that doesn't give us 

any information on emissions when it is running. 23.. 23 #//(r &C in/tut" 

• WHAT IS THE INLET CONCENTRATION OF HAP CONSTITUENTS TO THE 

OXIDIZER? There are some other things going on at the same time. We have taken 

measurements at the outlet. There are several streams which do not go the oxidizer but 

exhaust in the same stream as the incinerator exhaust SO, YOU MEAN, LET'S SAY ' Of^ 

THAT THERE ARE 3 PROCESS LINES, "1", "2" AND "3". ALL THREE LINES 

ARE OPERATING, AND LINE 2 EXHAUSTS TO THE INCINERATOR. LINES 1 

AND 3 DO NOT EXHAUST TO THE INCINERATOR, BUT THEIR STREAMS MIX 

WITH THE E3ffiAUSJ|RQM THE INCINERATOR. Yes. We measure the Wet 

concentrations as the&AJJ is being generated, ie,, as the part being produced enters the 

tec 

• WHAT ARE THE CAPTURE AND DESTRUCTION EFFICIENCIES FOR THE 

INCINERATOR? Some efficiency calculations are not exact; they are engineering 
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'08-29-1995 11:36 " 5T3 746 8087 DURIRON EPP P.03/04 

calculations and"bost/fruess". These values are arrived at by providiny-iown inputs: and 

are not directlj(calculat6jp In due time, we may have to do directlcalculation^ It is not 

easy to measure For SARA III-] 3, I've done some calculations (mass balance 

concentrations); I will send them to you. 

• ON PAGE 6 OF THE SURVEY, IN TABLE 2 FOR THE EPOXY MOLDING 

PREPREG COMPOUND, WHAT DO "STACKS: ACETONE" AND "STACKS: 

MD3K" REFER TO? Well, if you refer to the survey, we briefly explained our process. 

"We manufacture our own epoxy molding compound. Fiberglass roving is pulled through 

a varnish bath of epoxy resin and solvent The fiberglass is impregnated with the varnish 

and is pulled into an oven where the solvent is driven off. The roving is then cooled and 

chopped into a molding compound, The solvent vapor is exhausted from the oven and $J£-

introduced into a catalytic incinerator where it is burned at 90+% efficiency." So it comes 

from the epoxy molding compound. The varnish bath is enclosed. Fumes are exhausted 

and out into the stack. The streamas the end of the oven goes through the stack to the 

roof. There are openings in the(6over for the roving to pass through, and so the capture 

efficiency has never been calculated] There are other trace amounts in the room, but there 

are floor ievel vents which are exhausted through the stack to the roof. 

weTn 

• YOUR INCINERATOR IS CATALYTIC; WHO WAS THE MANUFACTURER? The 

equipment was from S-M-Mt-Matthey-Bishop, but they are no longer in business. 0f£ 

Johnson-Matthey still makes catalyst beds (and catalytic incinerators, too, I think). 

WHAT ARE THE CAPITAL/OPERATING COSTS FOB. THIS UNIT? I don't exactly 

know that. I don't know if our accounting department handled that information or *?A 

calculated the specific costs associated. 

• IS THERE AN EMISSION TEST AVAILABLE FROM YOUR FACILITY? WeU, there 

is difficulty in getting these measurements, as I described earlier. We maintain the LEL on _JJ£ 

solvents, to prevent explosion. We measured stack output to comply with the permit, but 

no ongoing information is available. 

ADDITIONAL QUESTIONS/COMMENTS 

1. PLEASE CHECK WITH ACCOUNTING TO FIND THE CAPITAL/OPERATING 

COSTS ASSOCIATED WITH THE OXIDIZER; IF THIS IS NOT POSSIBLE, COULD YOU 

PROVIDE THE MAKE/MODEL OF THE UNIT, AS WELL AS THE PHONE NUMBER FOR 

JOHNSON-MATTHEY?,-- .*/© - 97/ S/OO 

2. WHATARE THE CAPITAL/ANNUALIZED OPERATING COSTS FOR THE 

OXIDIZER? &> **/ fc«0uj dpe&fUj C*rff . 

3. WHAT IS THE INLET CONCENTRATION (TO THE INCINERATOR) OF HAP ^ '*'* V7,r* 

CONSTITUENTS? (phenol, formaldehyde, methanol, etc.) < / fa % + **-*** '*"* ' 

7 

4. IN THE SURVEY, IT IS STATED THAT YOUR PLANT CONTAINS: 2 REACTORS,

 f 

t 

3 
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*08-29-1995" 11:36 513* 746~ 8087 DURIRON EPP " "" P*. 04/04 

4 COATERS, 9 LAMINATE PRESSES, AND 7 MOLDING PRESSES. HOW MANY OF 

THE ABOVE COMPONENTS ARE CONTROLLED? ~73tf U t»T t&. 

1 

5. IT IS FURTHER STATED THAT SOLVENT FUMES (CONSISTING OF LESS - O 

THAN 0.1 TPY OF HAP EMISSIONS) ARE VENTED TO THE INCINERATOR DURING ' 

THE SATURATION PROCESS. ARE THESE THE SAME ONES YOU WERE REFERRING ' 

TO IN THE SATURATION PROCESS DESCRIPTION ABOVE1? 

6. WHYARETHERENOEMISSIONSFROMCURrNGDURINGTHELAMrNATION/ ^ 

TUBE ROLLING PROCESS, BUT THERE ARE EMISSIONS FROM THE SATURATION ' 

PROCESS? A?3?

 9etr ff9C6&s . 

7. CFA (COMPOSITES FABRICATION ASSOCIATION) WOULD TERM YOUR -^ 1 W * 

PROCESS AS CONTINUOUS LAMINATION. CONTINUOUS LAMINATION IS DEFINED^-^^ j 

AS THB FOLLOWING: reinforcement and resin are combined on a plastic film that is pulled ."^j itf^ 

through the process. A second plastic film is applied over the reinforcement and resin to allow 

mixing and exclusion of air that is usually accomplished by compaction rollers. The curing is done 

in an oven. In this process, sheets are continually produced, like SMC, then heat is applied to 

cure them; the application has a bath. It is also similar to pultrusion. 

8. WHY DO YOUR EPOXY RESINS HAVE HAP EMISSIONS? (IN SATURATION y 

PROCESS, THE 20 TPY OF EPOXY RBSIN LISTED IN THE FEEDSTOCKS IS STATED \ 

TO CONTAIN TOLUENE AND MEK.) WB WERE TOLD (AND HAVE FOUND FROM 

VARIOUS SOURCES) THAT EPOXY RESINS HAVE NO HAP EMISSIONS, j , ^ 

SZstks arc ***& (»TM < se/t/***^ sa/ury^. a*J? e&6e« jpsvcessdJ? 

-ffe Mc's <*r< -Afe JZ/JASU/S* ^ 

9. WHY ISN'T THE SATURATION PROCESS REFERRED TO AS PREPREG 

MANUFACTURING? jT / 

Information is accurate: 

Donal •onad Winegar U 

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