p.1 

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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

60) ll-E-20 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:05 AM Sheet 60 of 264 

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P.2 

*" ^ * \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

3 RESEARCH TRIANGLE PARK. NC 27711 1532/ 

Februar y 23 , 199 5 OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

TRANSMITTAL TO REINFORCED COMPOSITE PLASTICS NESHAP PRE-MACT 

TEAM, WORK GROUP AND INFORMATIONAL WORK GROUP MEMBERS 

Dear Team and/or Work Group Member: 

Thanks to all of you who were able to attend the first 

pre-MACT information meeting held February 7, 1995. This is to 

transmit the minutes of the meeting (Enclosure l) and formally 

request your feedback on issues listed in the briefing package 

and discussed during the meeting. For purposes of planning 

subsequent data analyses and information for the pre-MACT 

decision meeting, please send your comments/ideas by March 15, 

1995. You may send them by fax (919-541-5689 or 919-541-0072), 

through the Technology Transfer Network (my user name is 

Madeleine Strum)'', or by mail. If you were unable to attend the 

meeting, please read through the minutes and briefing package and 

provide input where you can. 

I would like to hold a second meeting in May or June in 

which vendors of specific control technologies will present 

information on their systems to the pre-MACT team. This 

scheduling of the meeting will be contingent on when we are able 

to get an environmental representative on the group, and our 

ability to keep this project on schedule in light of my upcoming 

ten weeks of maternity leave (from approximately March 31 through 

June 12). 

In the mean time, I hope that you will keep your thinking 

caps on with regard to this prdject. If you come across 

pertinent data, applicable control technologies or any other 

information that can aid in the project, please give me a call at 

(919) 541-2383. You may also share this information with our 

contractor lead project manager, Mr. Greg LaFlam of Pacific 

Environmental Services, at (919) 941-0333 or any other person on 

the team. For your convenience, a listing of reinforced 

composite plastics NESHAP pre-MACT team, work group and 

informational work group members and EPA contractors working with 

this industry is contained in Enclosure 2. 

*•*** DlX O 1JLH , ^ Sincerely , f! 

i^r ii i 

•' •• r,, .**' /r T 

...-.' -* V:, ** '-"^c I 

2 Enclosures 

V I:: 

Madeleine Strum 

Coatings and Consumer Products Group 

Emission Standards Division, MD-13 
P.3 

ADDRESSEES: 

Mark Bahner/Emory Kong, Research Triangle Institute 

Mohan Balagopalan, SCAQMD 

Bob Burmark, Washington State 

Leonardo Ceron Region IV 

Lisa Conner, OAQPS/AQSSD MD-15 

Laurel Driver, OAQPS/AQSSD MD-15 

Patricia Embrey OGC (mail 2344) 

Bob Fegley ORD, DC (mail 8105) 

Chuck French, OAQPS/AQSSD MD-15 

Robert Goulish, Ohio EPA 

Norm Kaplan, EPA/ORD (MD-61) 

Karen Levy OPAR (mail 6103) 

Maria Malave, OECA; (mail 2223A) 

Haile Mariam, OSW (Mail 5302W) 

Craig Matthiessen, OSWER (mail 5101) 

Ken Meardon/Greg LaFlam, Pacific Environmental Services 

Richard Nielson,/ Clark County Health District 

Carlos Nunez ORD, RTP (MD-61) 

Solomon Ricks, OAQPS/EMAD (MD-19) 

Bob Rose, OSDBU 1230-C 

Ron Ryan, OAQPS/EMAD MD-14 

Jordan Spooner OPPT/PPD (mail 7409) 

Jeri Weiss, Region I, APO 

cc: Lynn Hutchinson, OAQPS/ESD MD-13 

Jan Meyer/Linda Herring, EPA/ESD/CCPG 

Jane Caldwell (MD-15) 

V 
P.4 

EflltLOSurlE I 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUALITY PLANNING 

ANO STANOAROS 

February 23, 1995 

MEMORANDUM 

SUBJECT: Summary of February 7, 1995 Meeting of the Pre-MACT 

Team 

•if 

FROM: Madeleine Strum "T^feiu. 

Coatings and Consumer Products Group, ESD (MD-13) 

TO: Reinforced Composite Plastics NESHAP Project File 

(SAR 3326) 

This memorandum summarizes the first meeting of the pre-MACT 

project team for the development of a presumptive maximum 

achievable control technology (pre-MACT) for the reinforced 

composite plastics industry. The meeting was held by 

teleconference at 2:00 pm eastern standard time. Some team 

members came to the EPA office (Durham, North Carolina.) 

Attendees of the meeting consisted of EPA and State/local 

environmental agency pre-MACT team members and contractors to 

EPA. 

ATTENDEES: 

Mark Bahner, Research Triangle Institute (Contractor to EPA/ORD) 

Bob Burmark, Washington State Department of Ecology, Air Quality 

Program .^ 

Leonardo Ceron, US EPA, Region IV 

Patricia Embrey, US EPA, OGC 

Chuck French, US EPA, OAQPS, Air Quality Strategies & Standards 

Division 

Norm Kaplan, US EPA, ORD, Air and Energy Engineering Research 

Laboratory 

Greg LaFlam, Pacific Environmental Services (Contractor to 

EPA/OAQPS) 

Maria Malave, US EPA, OECA, Office of Compliance 

Ken Meardon, Pacific Environmental Services (Contractor to 

EPA/OAQPS) 

Jan Meyer, US EPA, OAQPS, Emission Standards Division 

Richard Nielson, Clark County Health District, Air Pollution 

Control Division, (Las Vegas, Nevada) 

Solomon Ricks, US EPA, OAQPS, Emissions Monitoring & Analysis 

Division 

Jordan Spooner, US EPA, OPPT, Pollution Prevention Division 

Madeleine Strum, US EPA, OAQPS Emission Standards Division 

3 
P.5 

PURPOSE OF MEETING: 

The purpose of the meeting was to present introductory 

information pertaining to the MACT and pre-MACT process for the 

reinforced composites plastic industry and request feedback from 

team members on various issues pertaining to pre-MACT 

development. 

Attachment 1 contains a copy of the briefing package (with 

corrections incorporated per the meeting discussion). 

DISCUSSIONS: 

1. Team Feedback on Issues (briefing package page 2) 

Madeldine explained that team members' feedback on the first 

three items listed on page 2 were not expected at the meeting, 

but rather after team members have a chance to take the- time to 

analyze the issues and information presented. As for the fourth 

issue, Madeleine explained the large role that the major 

industry trade associations, the Composite Fabricators 

Association (CFA) and Society of Plastics industry (SPI) played 

in the information gathering part of this work. In particular, 

these trade associations helped develop example screening survey 

responses and participated in the plant tours EPA took to learn 

more about the specific manufacturing processes. There was an 

overall agreement that industry should be participating in 

subsequent team meetings, however, the team also felt that 

representatives of environmental organizations should also 

participate. Madeleine noted that finding an environmental 

organization who would be willing to devote efforts to this 

process may not be easy, and requested help from team members 

in trying to recruit an environmental group representative. 

Madeleine also explored the idea of recruiting vendors of control 

technologies for the pre-MACT team, and the feeling was that they 

should not be part of the decision process, but rather be invited 

to some meetings for the purpose of presenting information on 

their technologies. It was explored whether this be done early 

or late in the pre-MACT process. Because the control technology 

information would be helpful upfront, it was thought that this 

should occur earlier rather than later. 

2. Emissions from Area versus Major sources (page 5) 

It was explained that because the reinforced composite 

plastics category is listed as a major source category (major 

sources are those sources that emit or have the potential to emit 

10 tons or more per year of a single HAP, or 25 tons or more per 

year of any combination of HAP) the MACT standard for the 

currently listed source category would only cover major sources. 

However, in the development of the standard it would be necessary 

to analyze whether area sources (sources that have the potential 

to emit less than the major source levels) should also be 

regulated by a MACT or generally achievable control technology 

(GACT) standard (this is called an "area source finding"). This 

decision would be based on health hazard and risk considerations 

pursuant to Section 112(c)(3) of the 1990 Clean Air Amendments. 

/ 
P.6 

Chuck French, from EPA's Risk and Exposure Assessment Group 

(REAG) explained that he would be working with this issue by 

looking at potential health effects due to emissions of styrene 

from sources that emit less than 10 tons per year of styrene (the 

main HAP emitted from the industry). 

It was questioned whether EPA classified styrene as a 

carcinogen. Chuck explained that whether or not styrene should 

be considered a carcinogen and the carcinogen classification was 

very controversial and is currently being debated and reviewed. 

A decision on the EPA cancer classification for styrene would 

likely be made soon. In any case; a numerical estimate of the 

dose-response or cancer potency (i.e. cancer unit risk estimate) 

would not be likely and the health analysis he would be doing 

would be semi-qualitative. However, for health effects other 

than cancer, an inhalation reference concentration (RfC) is 

available to use in the health risk assessment. He would need to 

look at factors such as how far a facility could be from its 

nearest residential neighbors, stack heights, dispersion 

characteristics, etc. to estimate potential exposure to styrene. 

Bob Burmark from the State of Washington noted that his agency 

was conducting & health study on a reinforced composite plant in 

his area and that he could coordinate getting the information to 

Chuck for the area source finding. 

3. Geographic location of plants (page 5) 

Because Ohio has the largest number of facilities, it was 

suggested that we recruit a team member from the State of Ohio to 

participate on the MACT team. It was noted that a member of the 

South Coast Air Quality Management District (a local agency in 

Southern California) was planning to participate, but was 

unfortunately not present at the teleconference due to 

administrative difficulties. 

4. Types of HAP emitted 

Madeleine emphasized that, while styrene is the most abundant 

HAP emitted from a reinforced Composites plastics facility, not 

all the styrene present in a resin is emitted. As a monomer, 

styrene polymerizes and remains in the product. The styrene that 

is emitted from a process is a result of evaporation loss. Some 

of the other chemicals listed in the briefing package (methanol, 

toluene, 1,1,1, trichloroethane and xylene) are likely paint 

solvents used in spray painting the finished product. They may 

also be solvents in mold release chemicals (those chemicals wiped 

or sprayed onto a mold to ease removal of the molded product). 

While we might need to consider emissions from mold release for 

the reinforced plastics composites category, the spray painting 

operation would be covered under a separate source category, and 

would therefore not be addressed in the development of the 

reinforced plastic composites MACT standard. These emissions 

would be important, however, in determining whether a relatively 

small reinforced composite plastics plant is a major source. For 

example, a facility which emits 25 tons annually from painting 

but only 1 ton annually from reinforced composite plastics 

operations would be a major source and subject to the reinforced 

y 
P.7 

composite plastics MACT standard. 

5. Principal fabrication processes (page 7) 

In describing the various processes used in the industry to 

manufacture composites, it was noted that there was a significant 

difference in the various types of processes and their emission 

characteristics used in the industry. The making of intermediate 

molding compounds such as sheet molding compound and bulk molding 

compound were included as a fabrication process. 

6. Emission reduction techniques (page 9) 

It was noted that the SCAQMD regulation for polyester resin 

operations included more reduction techniques than indicated in 

the original briefing package. Attachment 1 contains 

corrections. As a reference, the most updated version of the 

rule, as well as additional information from the SCAQMD regarding 

best available control technology determinations is included as 

Attachment 2. 

7. Emission factor estimates (page 10) 

A great deal of discussion focused around the 97 percent 

number obtained from the EPA/Radian testing at General Marble, in 

that it seemed impossible to be that high. Mark Bahner explained 

that one factor that could lead to relatively high emissions 

would be large amounts of overspray. The second point Mark made 

was that the number could be off by 20 percent, and the way it 

should be taken is that the emission factor from this test was, 

as were all the other data points in the table, higher than the 

factors published in AP-42. He has provided the data and the 

calculation and a brief analysis of how different assumptions 

affect the calculation results, which is included as 

Attachment 3. Bob Burmark asked if any of the data points were 

obtained by material balance (or correlated with material balance 

results). It was explained that the data were all based on air 

emission measurements, however, the CFA testing (the box 

entitled "Preliminary (Jan 1995^) test by trade association in 

lab-type set up") will be comparing their data with material 

balance results. Research Triangle Institute (RTI) will also be 

conducting tests to compare emission test results with material 

balance results. 

8. Ongoing work on factors (page 11) 

The CFA testing program was explained. Mark Bahner, who 

under a cooperative agreement with EPA's ORD, has been working 

closely with the CFA test program explained that the CFA 

originally planned to complete testing over a year ago but due to 

postponements was only now getting underway. He explained that 

RTI will embark on an independent testing program this summer. 

The details have not yet been worked out, but the main goals 

would be to quantify emission reductions from pollution 

prevention measures such as styrene suppressants, HVLP spray 

guns, and environmental modification such as low linear air 

velocities and/or low temperature in the application area. 

b 
P.8 

9. Preliminary Survey Analyses: Add on Controls (pages 13-14) 

It was pointed out that dollars per ton analysis is not good 

way to examine the cost of add-on controls. Rather the cost 

should be looked at in comparison with the cost of the 

manufactured product. For example, how much will the cost of 

installing and operating an add-on control device add to the cost 

of the product. Madeleine noted that this type analysis does not 

tend to get done until an option is already selected as part of 

the economic impact analysis. The economic impact analysis tends 

to be very resource intensive, and it will be especially 

difficult for this source category, as products range from small 

relatively inexpensive items to massive infrastructure items such 

as bridges. Richard Nielson1''noted that this type of cost 

analysis was done for the new tub/shower plant that opened in 

Clark County, and he would be able to share the results. 

In terms of researching the feasibility of add-on controls, 

it was suggested that we examine equipment being used by other 

industry categories. An example was given in which a catalytic 

incinerator with 60 percent heat recovery is being used to abate 

the remaining 5 percent of emissions of a pollutant at a chemical 

plant. Information on the operation and costs of this process 

may be helpful po the reinforced composite plastics project. 

Another suggestion was to examine add-on controls in terms 

of the size of the particular process that was being controlled. 

For example, in some standards, the emissions from storage tanks 

under a particular size are subject to a different limit. 

Analogously, we might look at sizes of pultrusion baths to 

determine whether some sizes should be exempt. 

It was also suggested that we use bubbling from the various 

emissions sources of the plant and require a certain percentage 

of control which may be achievable by the use of an add-on 

control for some emission points, and pollution prevention 

techniques for others. 

There was additional discussion on the fact that some 

foreign (European) facilities in this source category use add-on 

controls, and that their costs and emission reductions would be 

useful to develop and analyze options which are more stringent 

than the existing source floor. The add-on control option may 

very well be the new source floor, and we can use data from 

foreign facilities if add-ons are operated more cost-effectively 

and with less negative environmental impacts than they are in 

this country. 

It was noted that SCAQMD recommends including the analysis 

of add-on controls in a BACT analysis (see Attachment 2). 

Finally, it was pointed out that the trade associations have 

posed serious objections to add-on controls (see Attachment 4). 

7 
P.9 

10. Conclusion 

Madeleine requested that team members read the big picture 

ideas (page 15), the various alternatives for a format of the 

standard (pages 16-17) and summary of questions for the team 

(page 18) and provide input on these at some point after the 

meeting. The meeting adjourned at approximately 4pm eastern 

standard time. 

/ 

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P.10 

ATTACH/ilEM i 

Pre-MACT for Reinforced Plastic Composites 

CORRECTED BRIEFING PACKAGE (February 23) 

Pre-Meeting #1: Information 

February 7, 1995 

2pm EST teleconference 

PURPOSE: 

Provide Information to Pre-MACT TEAM on: 

- CAA requirements: MACT, MACT "floor" 

- Pre-MACT Process 

if 

- Source Category Profile 

- Production Processes Encompassed in Source Category 

- Preliminary Screening Survey Results 

Get Your Feedback on: 

t 

- Possible format of the standard 

- Further Screening Survey analyses 

- Further data required (and offers to help gather data) for 

Pre- MACT decision meeting 

- * Industry Participation in Subsequent Team Meetings? 

/ 
P.11 

MACT and the MACT "floor" 

As Prescribed in Clean Air Act (Section 112(d)) 

MACT: "... maximum degree of reduction in emissions of the 

hazardous air pollutants subject to this section [Section 112 of 

the Act] (including a prohibition on such emissions, where 

achievable) that the Aministrator, taking into consideration the 

cost of achieving such emission reductions, and any non1air quality 

health and environmental impacts and energy requirements, 

determines is achievable for new or existing sourcs in the category 

or subcategory to which such emission standard applies " 

MACT could result from: '-' 

- process changes or material substitution, 

- enclosing systems or processes to eliminate emissions, 

- collection, capture, treatment 

- design, equipment, work practice or operational standards 

- combination of above. 

MACT FLOOR - - minimum stringency as prescribed by Clean Air Act 

NEW SOURCES 

"shall not be less stringent than the best controlled similar 

source within the category" 

EXISTING SOURCES 

for source categories or subcategories with more than 30 sources, 

MACT: 

"shall not be less stringent than the average level of control 

achieved by the best performing 12% of sources within the 

category." 

/ 
P.12 

Presumptive-MACT 

Presumptive MACT is: our "best'guess' at MACT, based on data which 

can be obtained in a short timeframe (1-4 months). It is done at 

the beginning of a project in 3-6 months ("If MACT had to be 

determined today, what would it be?") 

Presumptive MACT is used fort Assist State and local agencies in 

making case-by-case determinations for Sections 112(g) and (j). It 

is offered only for guidance, caveated by the depth of available 

information on which it is based. 

How is it developed?: 

It is developed as a conservative estimate of what MACT would be 

after a brief review of available information. Conservative, means 

more stringent (the goal is not to go below the floor), and could 

be done using a "top-down" analysis where the most- stringent 

options are looked at first. It is anticipated that in most cases 

it would not be possible to conduct a formal 'floor' analysis. 

Information which might be available includes: State and local 

regulations, previous regulatory efforts, MACT for a similar source 

category, test reports, permits and perhaps other information. 

Who Plays a role in Pre-MACT?: 

EPA and State/local agencies and Outside Parties. 

What is the result of the final Pre-MACT decision meeting: 

1) The presumptive MACT and a list of questions to be addressed in 

developing a MACT standard 

2) A recommendation of the proposed regulatory path which should 

be taken to develop MACT 
P.13 

SOURCE CATEGORY PROFILE 

A. Number of Sources 

Based on TRI (1992), there are approximately 750 facilities in the 

source category. (Facilities using more than 10,000 pounds of 

styrene annually must report to TRI) 

-- Some industry members believe actual number of facilities could 

be as high as 5,000 to 10,000 — • . 

Out of the 750 from TRI, approximately 297 are major sources. 

(This was based on reported-TRI emissions times a fudge factor) 

NOTE: WE HAVE SURVEY DATA FROM ABOUT 500 SOURCES (it is not known 

how many of the 297 are covered-from a quick review, it appears 

that about 90 or so of these are not covered by survey responses.). 

B. Styrene Emissions 

Total from Major and non major sources: 

styrene in 1992. 

about 15,000 tons of 

Emissions from Non major sources contribute about 10% of this 

total. /' 

C. Types of Industrial Groups Included 

The Sources SPAN more than 50 SIC Codes, for example: 

308: Miscellaneous Plastic Products 

3088 Plastics Plumbing Fixtures 

3083 Laminated Plastics Plate, Sheet and Profile Shapes 

3089 Plastics Products, Not Elsewhere Classified 

371: Motor Vehicles/Equipment 

3713 Truck and Bus Bodies 

3792 Travel Trailers and Campers 

372: Aircraft and Parts 

3728 Aircraft Parts & Equipment 

394: Toys and Sporting Goods 

3949 Sporting and Athletic Goods, Not Elsewhere Classified 

D. Geographic Location 

TEN STATES WITH LARGEST NUMBER OF FACILITIES ARE: 

Ohio (70 facilities] 

Indiana (65) 

California (51) 

Texas (45) 

Pennsylvania (37) 

North Carolina (34) 

Michigan (33) 

Florida (32) 

Illinois (31) 

Wisconsin (31) 

Note Washington State has 21 facilities; Nevada has 1 facility 

(based on 1992) 

/ 

a 
P.14 

BASIC PRODUCTION PROCESS 

Combine raw materials in a fixed shape 

- unsaturated polyester resin with cross-linking monomer 

(usually styrene) or corrosion resistant polyester resins 

(typically these have higher concentrations of styrene) 

- additional styrene for thinning (sometimes) 

- fillers and additives (sometimes) 

- fiber reinforcement (glass, carbon, kevlar, etc) - except 

for synthetic marble casting 

Cure Product at ambient temperature, or under heat and/or pressure 

Perform finishing operations (cutting, drilling, sanding) 

TYPES OF HAP's EMITTED (from highest to lowest emitted) 

Styrene - monomer used in fabrication process 

methylene chloride - cleaning 

methanol 

toluene *x 

MEK 

1,1,1 trichloroethane 

xylene 

methyl methacrylate - sometimes used as a monomer in fabrication 

processes, also used in cleaning 

13 
P.15 

Principal Fabrication Processes 

OPEN MOLDING TYPE 

gelcoating - spraying a layer of pigmented polyester resin on 

surface of mold or as a thin sheet. Usually done in conjunction 

with a hand or spray layup process or marble casting. 

resin spray up - spraying a resin 

onto an open mold to build 

a layer (laminate) or 

multiple layers of plastic. 

After the spraying 

step, the wet laminate is 

typically rolled with a roller 

for removal of air gaps, 

and then left to cure. 

/' 

hand lay-up or pre-pregging - pouring, brushing 

resin onto glass 

—ReMorcement 

Spray-Up Gun 

"Continuous 

Roving 

Reinforcement 

filament winding - saturating* a glass mat with resin by dipping it 

into a resin bath, and winding it around a rotating mold. Or 

winding the glass mat around the mold and then spraying it with 

resin to saturate it. 

marble casting 

and curing it. 

pouring a highly filled resin into a hollow mold 

Xh 
P.16 

CONTINUOUS PROCESSES (lite printing) 

pultrusion - Glass matting and fibers 

are pulled through 

a bath of resin and through a 

closed heated die for curing. 

continuous lamination 

CONTINUOUS LAMINATING: 

Heal Source 

Continuous Strand Roving _ 

MatorOoth f j 

Resin AppScator 

FMNCO*MAT 

CAMMER SHEETS 

MEAT SOURCE 

FMSHCO STOCK 

SQUEEZE ROUS 

RES* SAW 

COKnWUOU8tAMW«*TIHO 

production of sheet molding compound 

Continuous Continuous 

strand roving strand roving 

V 

Chopped? 

roving— ^ ^ 

iT'*»- ^ 

Resin/filler 

paste Carrier film 

Chain link 

compaction belt 

Resin/filler 

paste Take-up roll 

Carrier 

film 

\\ 

Pufing Device 

MIXING TYPE OPERATIONS 

production of bulk molding compound 

CLOSED MOLDING TYPE 

closed molding processes (compression molding, resin injection 

molding) 
P.17 

EMISSION REDUCTION TECHNIQUES 

STORAGE/TRANSFER OPERATIONS: Add on controls, refrigerated storage 

CLEANING OPERATIONS: Use of nonHAP cleaning material, Limit 

Quantity of HAP used in cleaning (*) 

MIXING OPERATIONS: Add on controls, closed piping, puimping (versus 

pouring), covers on mixers (*) 

FABRICATION PROCESSES: 

ADD ON (treatment and recovery) 

thermal/ca£alytic incineration (used in U.S.) 

concentration-incineration (POLYAD system used in Europe) 

concentration-recovery (PURUS system tested in U.S.) European 

fluidized bed system) 

biofiltration (AMT system used in Swedish plant for 5 years) 

SOURCE REDUCTION 

Material Changes': 

low styrene gelcoats, low styrene resins (*), non-styrene based 

resins (eg. epoxy), faster curing resins, vapor suppressed resins, 

other formulations (UV cured, W.E.T.) 

Using less permeable film materials for sheet molding compound 

Process Changes: 

Switching from Open to Closed Mold 

Example: SCRIMP process (vacuum assisted resin infusion molding) 

Equipment Changes: 

using flow coaters instead of spray, using more efficient spray 

equipment (*), covered pultrusion baths (*) 

Environmental Changes:

 x 

low linear air velocities to decrease styrene evaporation rate 

low temperature in application area 

Housekeeping: 

Operator training, solvent tracking, leak detection and repair, 

keeping containers closed (*) 

* those items that form basis of South Coast rule for reducing VOC 

from Polyester Resin Operations 

/ 

H, 
RESULTS OF ORD's INVESTIGATION OF EMISSION ESTIMATES 

FROM VARIOUS PROCESSES 

••Recent test data shows AP-42 may under-estimate percent of 

available styrene which is emitted^ 

EMISSION FACTORS EXPRESSED AS PERCENT AVAILABLE STYRENE 

100* (grams styrene emitted per gram styrene in resin) 

Emission Factor 

Source 

j Process 

j type --> 

V 

•r 

AP-42 (based on 1982 

data) 

EPA/Southern Research 

Insitute at Eljer 

Plummingware (1993) 

EPA/Radian testing at 

Venetian Marble in VA 

EPA/Radian testing at 

General Marble in NC 

Radian Testing 

at CORTEC plant in 

Ohio (1993) 

(flat line spray 

operation) - -

continuous process) 

Preliminary (Jan 1995) 

test by trade 

association in labtype set up 

Bison Engineering 

testing at GEA dynamic 

I fabricators, ID 

GEL COAT 

(spray) 

26-35 

66 

68 

97 

42/29' 

41 

RESIN 

SPRAY UP 

9-13 

24 

RESIN 

SPRAY 

UP 

vapor 

suppre 

ssed 

3-9 

16 

HAND 

LAY 

UP 

5-10 

17 

Discrepancies may be due to: 

Method of testing (18 versus 25A) , 

Differences in environmental factors (air velocity across 

surface) proper enclosure, 

Proper tracking of the quantity of resin used in tests 

1 Emission factor of 42% for conventional gelcoat, 29% is fo 

a "high performance" gel coat with a fast gel time 

x5 

n 
EMISSION FACTORS . continued 

Some industry members have used factors that are less than AP-42 

emission factors for some processes 

1 

AP - 42 

Pultrusion Industry 

Council Testing on 

pultrusion machine^ 

Plant- test in Ohio 

Facility

 ,f (through 

verbal 

communication) 

Pultrusion 

4-7 

1.15 

Mixing 

1 (paint mixing) 

0.5 (resin 

mixing) 

•study notes that the experimental conditions do not necessarily 

represent conditions present or attainable in all pulltrusion 

operations. In particular, the more complex parts typically 

pultruded may have larger resin baths, wet out areas, and may 

consequently hajfe higher emissions. 

ONGOING WORK ON FACTORS 

Testing being done by CFA for Open Molding to calculate "baseline" 

emissions from resin/gelcoat spray up. Purpose is to study also 

the effectiveness of Pollution Prevention control options 

Additional Data from New LASCO plant (Clark County) may be 

available within next 6 months 

CFA also exploring a model to predict emission factors depending on 

various factors 

EPA ORD Contractors are working on a model to predict emission 

factors depending on various factors 

We will use results of model (hopefully an industry-EPA consensus) 

for calculation of potential-to-emit in the MACT standard 

AP-42 updating will be based on results obtained from this project 
P.20 

PRELIMINARY SURVEY RESULTS -- EMISSIONS BY PROCESS* 

Total emissions of styrene from the source category is on the order 

of 15,000 tons per year (includes both major and area sources) 

We estimate that about 10% of the total emissions are from area 

sources. 

EMISSIONS 

(NOTE TRI DATA MULTIPLIED BY A FUDGE FACTOR for gelcoating, hand 

lay-up, resin spray up) 

Process 

gel coating 

resin spray up 

hand lay up and; pre-pregging 

filament winding 

pultrusion 

continuous lamination 

closed mold 

unknown 

TOTAL 

1992 Styrene Emissions 

(Tons) 

4006 

5115 

1108 

226 

161 

189 

583 

4256 

15,644 

• Table needs to be updated (to reduce the tonnage of "unknown"). 

We need also to figure out the riumber of major sources that perform 

each process. 
P.21 

Preliminary Survey Results U.S. Plants with ADD-ON Controls 

Process/ 

process type 

gel coating 

(continuous flat-line spray 

process) * 

gel coating, resin spray up, 

mixing 

H .» 

Gel coat and resin spraying 

pultrusion** 

pultrusion, continuous 

lamination, acrylic spraying 

pultrusion 

i 

continuous lamination 

sheet mold compounding 

sheet mold compounding 

Mixing, closed molding, possibly 

pultrusion and hand lay up 

unknown 

unknown 

Confidential business 

information (CBI) 

Processes listed are CBI

 x 

R+D facility -- prepregging 

prepregging phenolic resins 

epoxy resin casting, painting 

not using styrene based resins 

Location 

Washington Court 

House, Ohio 

Lancaster, 

Texas 

Elizabethtown, PA 

South Boston, VA 

Hazleton, PA 

Fort Worth, TX 

Sand Springs, OK 

Jonesboro, Arizona 

Dekalb, Illinois 

Columbus, Ohio 

South Euclid, Ohio 

Witchita, Kansas 

Magna, Utah 

• CBI * 

* CBI * 

Tempe, Arizona 

Hoosick Falls, 

NY 

Springboro Ohio 

* CBI * 

Install 

Date 

1992 

1985 

1985 

1986 

1990 

1991 

1990 

1993 

1993 

Planned 

1994 

1993 

1993 

* overall control efficiency was determined to be between 88-95% 

** one of possibly more whose add-on device controls paint 

emissions as well as emissions from this category 

One additional plant has conducted testing an add-on from 

mixing/general plant and found test very successful. 

M 

It 
PRELIMINARY SURVEY RESULTS ADD ON CONTROLS 

PROCESS #FACILITIES 

Gelcoating 

PERCENT OF CATEGORY WHICH 

HAS ADD-ON CONTROLS 

(INCLUDES BOTH MAJOR AND 

NON MAJOR SOURCES) 

4.0 (may be less if take 

out continuous 

process) 

Resin Spray up 2.2 

Hand Lay up 

Pultrusion AND 4 

Continuous Lamination 

0.0 (did not count 

facilities not using 

styrene) 

11 (industry interpretation 

of our data shows it is 

closer to 0, and they would 

not group continuous 

lamination with 

pultrusion) 

We don't know how much of the emissions are vented to the 

control device, and we don't know overall control efficiencies of 

the majority. 

Other emission reduction techniques reported in survey 

have not yet been tabulated. 
_P^23 

Possibilities for MACT (BIG PICTURE) 

1. Adopt South Coast Air Quality Management District Rule 1162 for 

existing source MACT 

Advantages -- Other States are adopting the rule, thus it 

probably will affect 12% of facilities (easy MACT floor) 

Disadvantages -- rule exempts'the majority of the processes 

and requires status-quo for gel coating, and any process which uses 

fillers (large part of resin spray up and hand lay up) 

Consequently, this approach may not get any emission reduction. 

2. Use 1162 and negotiate additional work practice standards on 

other processes with the industry (eg. cover on pultrusion bath) 

Advantages - - may get industry support, may encourage industry 

to institute test program(s) and "design" equipment standard for 

pultrusion. 

Disadvantages -- We do not now have data on work practice 

standards nor their emission reduction impacts. This approach 

would ignore the emission reduction potential from add-on devices. 

/' 

i / 

/ 

3. Put efforts in the exploration of add-on controls for new 

source MACT 

Advantages -- will encourage innovation in pollution 

prevention such as resins with no styrene, styrene recovery devices 

Disadvantages -- could be a difficult sell (even though these 

devices are out there) 

4. Do a "process-by-process" MACT rather than subcategorizaton. 

Exempt certain processes/resins from MACT as did the SCAQMD rule -

e.g.: compression molding, corrosion resistant resins, pultrusion, 

continuous lamination, SMC production. Perhaps develop 

housekeeping-type requirements.for these. 

%Q 
POSSIBLE FORMATS OF A STYRENE EMISSION STANDARD 

Important in figuring out HOW TO ANALYZE DATA 

1) PLANT-WIDE STYRENE EMISSION LIMIT: grams styrene emitted per 

meter squared surface coated 

ADVANTAGES 

- Units are familiar to industry (used in South Coast rule) 

- Give credits to thin application of gelcoating (less total resin 

used) 

- Credits minimization of usage of resin (i.e better spray methods) 

DISADVANTAGES 

- Depending on how you take surface area into account, you may 

penalize thick layers of resin 

- We don't have very good data to come up with a number without 

having to use significant estimating procedures to determine 

emissions 

- Plants will need to measure/calculate surface area for every 

piece coated and Measure or /calculate emissions 

- Difficult to demonstrate compliance/enforce 

- Would penalizey:those products that, for quality reasons, may need 

more resin thickness (more grams emitted, same surface area) 

2) Emission limit on styrene from resins used (either the resin assupplied by the supplier, or the resin as-applied, that is, after 

mixing with additives, fillers, etc. by the manufacturer) in terms 

of grams per meter squared 

ADVANTAGES 

- It is very familiar to the industry: South Coast Rule utilizes 

this already, and resin suppliers keep data on this quantity 

- With a test method, it should be relatively easy to demonstrate 

compliance 

DISADVANTAGES 

- Won't address emissions from application, only curing; therefore 

we would need to address methods to minimize resin usage/resin 

evaporation during spraying (i.e. better spray guns, operator 

training, closed containers) in a different format such as a work 

practice standard -- this could actually be an advantage, however. 

- Analysis of South Coast test method showed problem -- EPA would 

have to adopt a new method 

- We will likely need to give exemptions for many types of 

resins/applications 

"As - applied" disadvantage : those companies with highly filled 

resins will not get any emission reduction if their data are 

averaged in with companies that don't fill the resins (however, we 

could treat them separately and derive a separate limit for filled 

resins) 

- "As - Supplied" disadvantage: companies could thin resins with 

additional styrene and that would not count as emissions 

-*£ 

21 
P.25 

POSSIBLE FORMATS OF A STYRENE EMISSION STANDARD... continued 

3) PLANT WIDE LIMIT grams emitted per kg resin used 

ADVANTAGES 

- Should be relatively easy to keep records of kg resin used 

- May be able to do a mass balance (weigh resin going into process, 

weigh resin going out of process) to calculate emissions 

DISADVANTAGES 

- We don't have very good data to come up with a number without 

having to use significant estimating procedures to determine 

emissions 

- Problems.rwith testing/ compliance / enforcement: Mass balance 

techniques can be very innaccurate, we would have to come up with 

a protocol and quality assurance procedures 

4) Emission limit on resins used (either the resin as-supplied by 

the supplier, or the resin as-applied, that is, after mixing with 

additives, fillers, etc. by the manufacturer) in terms of grams per 

kg resin used 

ADVANTAGES f 

- We could possibly utilize EPA Method 24 for measurement of 

nonvolatiles content (they have recently added in procedures for 

multicomponent coatings -- which encompasses catalyzed coatings) 

DISADVANTAGES 

- Won't address emissions from application, only curing; therefore 

we would need to address methods to minimize resin usage/resin 

evaporation during spraying (i.e. better spray guns, operator 

training, closed containers) in a different format such as a work 

practice standard -- this could actually be an advantage, however. 

5) Employ a semi-quantitative POINT system and write reg based on 

facility getting a certain cumulative points based on the emission 

reduction techniques they use.x We assign points to the various 

emission reduction techniques 

ADVANTAGES 

- Provides Flexibility and choices 

- Once we have a point scheme, we would be able to calculate a MACT 

floor from survey very easily 

- Idea originated from a member of industry. 

DISADVANTAGES 

- may be complicated to work out a point scheme 

- even more complicated to come up with a limit 

- would not necessarily encourage P2 techniques that we might have 

left out 

- would need to work out compliance procedures for each technique 

we apply points to 
P.26 

SUMMARY OF QUESTIONS FOR TEAM 

1. Do we open all of our meetings to industry trade association 

groups? If so, should we try to identify interested environmental 

groups for participation? 

2. What additional data analyses are necessary? What data do you 

think industry could provide? 

3. Any big picture MACT ideas? 

4. What would be a good format of the standard? 

5. Is it reasonable to use performance data/cost 

data/environmental impact data on add-on controls for this industry 

based from facilities that are using these devices in Europe? 

eg: if a U.S. plant has installed carbon filters in which costs 

and environmental impacts are poor, but we find European 

technologies that get the same or better reduction and are 

favorable in these impacts, can we use the European data for 

evaluating feasibility, and U.S. data for justification that this 

should be the floor for new sources? 

/' 

6. How would 'you group "similar" processes together (eg, for 

purposes of new source MACT floor). For example: should 

continuous lamination, pultrusion, the continuous gel coat spray 

line be considered "similar" with respect to the feasibility of 

add-on controls? 

1-b 
P.27 

FEB 06 '95 09= ISAM SCHUTUJ HUtxn =>"x* 

*mctiM£HT'3~-

\ 

(Adopted March 6,19$7)(Amended April 3,1987}(Amenoea ^u^ * -, ~~ . 

(Ajncnded December 7,1990) (Amended August 2,l#l){Ainended July 10,1992 

(Amended May 13,1994] 

RULE 1162, POLYESTER RES1K OPERATIONS 

(a) Applicability 

This role shaU apply to all polyester resin operations that fabricate, rework, 

repair, or touch-up products for commercial, military, or iaduttrial use including, 

but not limited to, boats, tubs, pools, shewer enclosures, tp ^ bathroom fixtures, 

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

storage tanks, transportation parts, and other industrial and consumer products.. 

(b) Definitions 

For the purpose of this rule, the following definitions Shall apply: 

(1) AIRLESS SPRAY \s a coating application system in which the coating 

fluid i^ supplied to the gun under fluid pressure and air is not added to 

the gun. 

AIR-ASSISTED AIRLESS SPRAY is a coating application system in 

which the coating fluid is supplied to the gun under fluid pressure and air 

is combined at the spray cap. 

CORROSION-RESISTANT MATERIALS are polyester resin materials 

used to make products for corrosion resistant applications such as tooling, 

fuel or chemical tanks and boat hulls. 

EXEMPT COMPOUNDS are any of the following compounds: 

(2) 

(3) 

(A) Group I 

dichlorotrifluoToethane (HCrOixjj 

tetrafluoroethane (HFC-134a) 

dichlorofluoroethane (HCFC-141b) 

chlorodifluoroethane (HCFC-142b) 

trifluoromethane (HFC-23) 

2-chloro-l,l,l,2-tetrafluoroethane (HCFG124) 

pentafluoroethane (HFC-125) 

1,1,2,2-tetrafluoroethane (HFG134) 

1,1,1-trifluoroethane (HFC-143a) 

1,1-difluoroethane (HFC-152a) 

cyclic branched, or linear, completely fluorinated alkanes 

^ 4 
FEB 06 '95 89:18m SCRQMD RDMIN SERV 909 39633S0~ " JL28 

Rule 1162 (Cont) (Amended May 13,1994) 

cyclic branched, or linear, completely fluorinated ethers with no 

unsaturations 

cyclic branched, or linear, completely fluorinated tertiary 

amines with no unsaturations 

sulfur-containing perflaorocarbons with no unsaturations and 

with sulfur bonds only to carbon and fluorine 

(B) Group II 

methylene chloride 

, carbon tetrachloride 

l,Ll^chloroethane (methyl chloroform) 

tricMorotrifluoroethane (CFC-113) 

eacNorodifluoroniethane (CFC-12) 

trichlorofluoromethane (CFC-11) 

dichlorotetrafluoroethane (CFC-114) 

chloropentafluoroethane (CFC-115) 

Use of Group II compounds may be restricted in the future because they 

are either toxic, potentially toxic, or upper-atmosphere ozone depleters, 

or cause other environmental impacts. Specifically, the District Board 

has established a policy to phase out chlorofluorocarbons (CFCs), methyl 

chloroform (LLl-trichloroethane or TCA), and carbon tetrachloride by 

December 31,1995. 

(5) FIRE RETARDANT MATERIALS are polyester resin materials used to 

make products thai are resistant to flame or fire. 

(6) GEL COAT is a polyester resin surface coating, either pigmented or 

dear, that provides a cosmetic enhancement and improves resistance to 

degradation from exposure to the elements. 

GENERAL PURPOSE POLYESTER RESINS are materials that are 

not corrosion resistant, fire retardant, high strength, vapor suppressed, or 

gel coats. 

HIGH-STRENGTH MATERIALS are polyester resins which have 

casting tensile strength of 10,000 psi or more and which are used for 

manufacturing of high performance boats and skis. • 

HIGH-VOLUME, LOW-PRESSURE. (HVLP) SPRAY is a coating 

application system which is operated at air pressure of between 0.1 and 

10 pounds per square inch gauge (psig) at the air cap .of the spray gun. 

(7) 

(8) 

1162 - 2 
' FEB 8 6 '9 5 89:i6AM SCflQMD ADMIN SERV * » ^ ^ 

Rule 1162 (Cont) (Amended May 13,1994) 

•N 

(10) MONOMER is a relatively low-molecular-weight organic compound such 

. as styrene that combines with itself, or other similar conrpounds, by a 

cross-Unking reaction to become a cured thermosetting resin. 

(11) POLYESTER RESIN MATERIALS are unsaturated polyester resins, 

such as isophthalic, orthophthalic, halogenated, bisphenol A, vinyl ester, 

or furan resins; cross-linking agents; catalysts; gel coats; inhibitors; 

accelerators; promoters; and any other material containing VOC used in 

r polyester resm operations. 

(12) POLYESTER RESIN OPERATIONS fabricate, rework, repair, or 

touch-up products for commercial, muhaty, or industrial use by nuxing, 

pouring, hand laying-up, .impregnating, mjectmg, forming, winding, 

spraying, and/or curing by using unsaturated polyester resin materials. 

(13) PULTRUSION is a process where continuous roving strands are moved 

through a strand-tensioning device into a resin bath for impregnation and 

then passed through a heated die for curing. 

(14) REPAIR is that portion of the fabrication process that requires the 

addition of polyester resin materials to portions of a previously fabricated 

product in order to mend damage. 

(15) TOUCH-UP is that portion of the process that is necessary to cover 

minor imperfections. 

(16) VAPOR SUPPRESSED RESIN is a polyester resin material which 

contains additives to reduce VOC evaporation loss to less than sixty (60) 

grams per square meter of surface area as determined and certified by 

resin manufacturers. 

(17) VOLATILE ORGANIC COMPOUND (VOC) means any volatile 

chemical compound that contains the element carbon, exduding 

methane, carbon monoxide, carbon dioxide, carbonic add, metallic 

carbides and carbonates, ammonium carbonate, and exempt compounds. 

(c) Requirements 

(1) For each process, a person operating a polyester resin operation shall 

comply with either the material requirements or one of the applicable 

process requirements set forth below: 

1162 - 3 
P.30 

FEB 06 '95 09:17W1 SGSQMD ADMIN SERV 909 396 3350 

P.5 

Role ll62<Cont^ 

(Amended May 13,1»4) 

(A) MaterialReouirements^^^ resin niaterial in a polyester 

Units specified in the Table below. 

Geoertl Purpose Polyester Reofl 

MooomerOooWttia 

Fobetter Redn 

KliierWs«AppGed 

^n..«u>xMif Percent 1 

(ii) 

(m) 

(2) 

(3) 

(4) 

(B) Process Requirements 

(i) The weight loss of polyester materials shall be less than 

four (4) percent when a dosed-mold system is used. 

When a vapor suppressed resin is used, the weight loss from 

VOC emissions shall not exceed sixty (60) grams per square 

meter of exposed surface area during resin polymerization. 

A pultrusion operation shall have covered wet-out baths. 

From the exit nf the bath to the die »& but 18 inches of the 

preform distance shall be endosed to minimize air flow. 

The weight loss of polyester materials shall be less than 

three (3) percent in a pultrusion operation. 

For spraying operations, in addition to complying with the requirements 

specified in paragraph (c)(1), a person shall use high-volume-lowpressure (HVLP), airless, air-assisted airless, or electrostatic spray 

equipment. For iouch-up and repair, a hand-held, air-atomized spray gun 

which has a container for resin as part of the gun may be used. 

Any person operating a polyester resin operation shall keep the resin 

materials in closed containers except when filling or emptying the 

container. 

Solvent cleaning operations shall comply with Rule 1171 - Solvent 

Cleaning Operations. 

1162-4 

1/1 
FEB 06 '95 09:17M1 SCfiQMD ADMIN SERV 909 a * p ^ 

Rule 1162 (Cont.) (Amended May 13,1994) 

(d) Control Equipment 

In lieu of complying with the requirements of paragraph (c)(1) and (c)(2), a 

person may install and operate an emission control system vmichudeslgried and 

operated in accordance with guidelines published in the 20th Edition of the 

Industrial Ventilation Manual by the American Conference of Governmental 

Industrial Hygjenists for the collection of fugitive emissions from polyester resin 

materials, and which system is approved by the Executive Officer's designee, and 

• has an overall captore and control effidency of 90 percent or more on a mass 

basis. 

(e) Recordkeeping Requirements 

(1) A person subject to the provisions of this rule shall maintain daily 

records. Such records shall be made available to the Executive Officer's 

designee upon request and shaU be kept for not less than two years. The 

records shall contain: 

(A) The manufacturer's name, the type and amount of each of the 

polyester resin materials used; and 

(B) The weight (in percent) of monomer for all polyester resin 

materials, and, if adding VOC-containing materials to the 

polyester resin, the amount of VOC-containing materials, in 

grams, and the VOC content in grams per liter, of VOC-containing 

materials; and 

(C) For vapor suppressed resins, a certificate from a resin 

manufacturer for each resin type; and 

(D) For closed-mold and pultrusion systems, the weight loss (in 

percent) of polyester resin materials for each appUcation. 

(2) Records for cleaning solvents subjea to Rule 1171 • Solvent Cleaning 

Operations shall be maintained pursuant to Rule 109. 

(3) Any person using an emissions control system as a means of complying 

with this rule shall maintain daily records of all key system parameters,-

including hours of operation, temperatures, pressures and flow rates, that 

are necessary to ensure control efficiency requirements. 

1162-5 

1% 
FEB 06 '95 09:17m SCfiQMD (mm SERV 939 396 3350 

P.7 

Rule 1162 (Cont.) (Amended May 13,1994) 

Oi) 

.compliance with subdivision (e) at such time manufacturers specify which 

individual compounds are used in the coating formulations and. identify 

the test methods, which, prior to such analysis, have been approved by the 

USEPA and the SCAQMD, mat can be used to quantify the amounts of 

each exempt compound. 

Exemptions 

(1) „ Until July 1,1994, the provisions of paragraphs (c)(1) and (c)(2) and 

subdivision (d) shall not apply to: corrosion resistant, fire retardant, and 

high strength materials. 

(2) Until July 1,1994,- The provisions of (c)(1) shall not apply to gel coats. 

1162 - 7 
FEB 06 '95 09:i8flM SCRQriD Hunm ac*v 

Rule 1162 (Cont.) (Amended May 13,1994) 

(4) The records shall also contain the rnanufacturer's name, type and amount 

of corrosion resistant, fire retardant, high strer^ materials and gd coats 

used, which are temporarily exempt from process requirements until 

. Jury L1994. 

(f) ' Methods of Analysis 

The VOC content of each of the polyester resin materials shall be determined by 

using USpPA Reference Method 24 (Determination of Volatile Matter Content, 

Water Content, Density Volume Solids, and Weight Solids of Surface Coating, 

Code of Federal Regulations Title 40, Appendix A, utilizing Procedure B of 

ASTM Method D2369), or the SCAQMD Method 304. The monomer content 

shall be determined by Method 312, and weight loss of polyester resin materials 

shall be determined by Method 309; and the exempt compound's content shall 

be determmed by Methods 302 and 303 in the South Coast Air Quality 

Management District's (SCAQMD) Laboratory Methods of Analysis for 

Enforcement Samples. 

(g) Test Methods 

(1) The effidency of the control device and the VOC content measured and 

calculated as carbon in the control device exhaust gases shall be 

determined by USEPA's Test Method 18, or Air Resources Board (ARB) 

Method 422 for the determination of emissions of Exempt Compounds 

and USEPA's Test Methods 25, 25A, or SCAQMD's Method 2S.1 

(Determination of Total Gaseous Non-Methane Organic Emissions as 

Carbon) for the determination of total organic compound emissions. 

Emissions determined to exceed any limits established by this rule 

through the use of any of the above-referenced test methods shall 

constitute a violation of the rule. 

(2) The following classes of compounds: cyclic, branched, or linear, 

completely fluorinated alkanes; cyclic, branched, or linear, completely 

fluorinated ethers with no unsaturations; cydic, branched, or linear, 

completely fluorinated tertiary amines with no unsaturations; and sulfurcontained perfluorocarbons with no unsaturations and with sulfur bonds 

only to carbon and fluorine; will be analyzed as exempt compounds for 

1162 - 6 

^ 0 
^ 

SOUTH COAST AIR QUALITY MAKAGEMENT DISTRICT 

Best Available Control Technology (BACT) Guideline 

Equipment or Process: Fiberglass Fabrication - Hand and Spray Layup 

Equipment Rating: All 

KOG NOX 3Q2L m 

Revision: 

Date: 10/07/88 

JEASRi 

BACI 

1cchnolo<)icaUy Feasible 1.3 

1. Afterburner l> 0.3 | 

Second Retention T?me| 

at > 1400° F> | 

2. Carbon Adsorber | 

Afterburner (>, 0.3 

Second Retention Ttm 

• t > 1*00° f> 

BACT 

Achieved in Practice or 

Contained in EPA Approved SIP 

Compliance with SCAOMO,a 

Rule 1162 and Dee of 

Aqueous Eftulalon Cleaner 

Instead of Acetone for 

Clean-Up to Mexlnum 

Extent Possible 

Afrleaa Spray Equipment | 

and Spray tooth iriih 

iReeh Type f titer s 

1 

^ 

BACT 

For Sraall Business 

1.3 

1. Afterburner «£ 0.3 \ 

Second Retention Tine 

at > U00° f> 

2 . Carbon Adsorber 

3. Complfence Mlth 

SCAM),* Rule 1162 

and Use of Aojueoua 

Emulsion Cleaner 

Instead of Acetone 

for Clean-up to 

Maximum Extent 

Posatble 

Afterburner <> 0 3 

Second Retention Ttaa 

at > 1400° n 

2 . Airless Spray Equipment mi Spray loath 

tilth Hesh Type 

Ft Iter* 

Alternate Basic Equipment 

or Process 

Closed Holding Process 

\. Requires Economic Analysis 

2 . Ho Economic Analysis 

3 . Control technologies are in descending order of efficiency. 

analysis. 

The most efficient control technology ma t be considered first irhen conducting en economic 

Best Available Control Technology Guideline 69 

Fiberglass Fabrication -

Hand and Spray Layup 

TJ 
) 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Best Available Control Technology (BACT) Guideline 

Equipment or Process: Fiberglass Fabrication - Panel Manufacturing 

Equipment Rating: All 

ROG NOX -SPJC. £QBAcr 

Technologically Feasible 

1 

BACT 

Achieved in Practice or 

Contained In EPA Approved SIP' 

|Curing Oven, In^reanaItloo Tables, Mixing 

\Tanks, Storage Tanks and 

JHotdtng tanks Vented to 

\en Afterburner Cj.0.3 

|Sec. Retention Time at *} 

11400° f > or a Carbon 

(Adsorber with Vow 

|Styrene Resin and Water 

\&a*ed or Aqueous, Hon-

| Vol at He Organic Cow 

|pound Cleaning Solvent 

J 

Natural Gas Fired 

Curing Oven tilth Radiant 

Burner , Electrically 

Heated Cellophane Oven 

and Laminating Table 

|Curing Oven, Inpregna-

\tfoh Tables and Mixing 

(Tanks Vented to an 

|Afterburner (£0. 3 See. 

(Retention Time at >. 

Storage and 

\Kold1ng Tanks Vented to 

|a Carbon Adsorber 

Natural Cos ft red 

Curing Oven, Electrically Heated Cellophane 

Oven and laminating 

Table 

Natural Gas Natural Oas 

Revision: 

Date: 10/07/88 

-i 

"R 

& 

8' 

PAKEs 

Natural Baa Fired Curing 

Ovens, Cellophane Ovens 

|Vented to an Afterburner 

<> 1.3 Sec. Retention 

Ttaa at > 1400° n and 

•anel Cutting Saw Vented 

to tagjheuM 

natural CM Fired Curing 

ene. Cellophane Ovens 

iVsated to an Etcctrestatle Precipitator and 

Penal Cutting Sea Vented 

toBaghouce 

70-J. 

Fiberglass Fabrication -

Panel Manufacturing 
^ > ) J 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Best Available Control Technology (BACT) Guideline 

Equipment 

Equipment 

or Process*. 

Rating: All 

Fiberglass Fabrication - Panel Manufacturing Revision: 1 

Date: 04/05/90 

SKCTT V for Sraoll Business1

'-" 

^ 

VP 

'Alternate Beiic tquvproent 

or Process 1• * 

BACI - 5CAOK> 

Fuel Policy' 

Board's Clean 

ROG i. impregnation tables. 

Curing Oven, Mixing 

Tanks, Storage Tanks 

and Holding Tanks 

Vented to tn Afterburner l» 0.3 See. 

Retention rime at > 

14G06 F) or a Carbon 

Adsorber with Low 

styrene Resin and 

Water Based or 

Aqueous, Non-Volatile 

Organic Compound 

Cleaning Solvent 

2. Impregnation Tables, 

Curing Owen and nixing Tanks Vented to 

an Afterburner (> 0.3 

Sec. Retention Tine 

at > HCO * M . Storage**and Holding Tanks 

Vented to a Carbon 

Adsorber 

NOX SOX 

Electric Keat 

SSL 

Electric Beat Electric Heat Electric Wee* 

Hat. Gas or Other Equtvalent Clean Fuels as 

Standby fuel or Equivalent Control Technology 

Hat. Gee or Other Eeuivalent Clean Fuels as 

Standby Fuel or equivalent Control Technology 

\. Requires Economic Analysis 

Z. Ho Economic Analysis 

5. Control technologies are in descending order of efficiency. 

analysis. 

T. fairs' rffffftM 

Curing ©vena. Cellophane Ovens Vented to 

an Afterburner (> 0.3 

See. Retention TIM 

at • WOO* F) and 

•ami Cutting tan 

Vented t e Safhous* 

I. Natural fiae Fired 

Ourlngjjbrena, Cellophane Ovena Vented to 

an eiectroetatle 

Precipitator end 

Panel Cutting Sou 

Vented to • iegKouse 

1. electric Heat and Uae1 

•I •jon-flasticlnd 

Cellophane 

2. electric teat 

3 . flee «f Non-Plaetlclzed Cellophane 

Hai. Caa or OAher Eou\-

valent Clean FuaU as 

Standby fuel er Equivalent Control fethnology 

The isost efficient control technology oust be considered first atten conducting an economic 

Best Available Control Technology Guideline 70-2 

Fiberglass Fabrication -

Panel Manufacturing (cont'd) 
) 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Best Available Control Technology (BACT) Guideline 

Equipment or Process: Fiberglass Fabrication - Pultrusion 

Equipment Rating: All 

Revision: 

Date: 10/07/&8 

ROG NOX SOx CO PART . 

BACT \\. Afterburner <>. 0.3 \ \ | \ | 

Technologically Feasible ' | Second Retention 1 1 I 1 I 

I Time at », 1400° F> \ \ j \ | 

|2. Carbon Adsorber | | \ 1 1 

BACT |Stryene Supreased Besln | | \ \ \ 

Achieved in Practice or | | \ \ \ | 

Contained in EPA Approved SIP \ | | [ | \ 

BACT (l . Afterburner <>. 0.3 | | I I 1 

For Small Business ' | Second Retention' 1 1 1 1 1 

j Tine at > 1400° F> \ | j | \ 

| 2. Carbon Adsorber | 1 1 1 1 

|3. Stryene Supresaed \ \ | \ | 

\ Resin | '| | 1 1 

Alternate 8a*ic Equipment \ II I 1 1 

or Proceti | II I 1 1 

8 

1. Requires Economic Analysis 

2. No Economic Analysis 

3. Control technologies are in descending order of efficiency. The most efficient control technology oust be considered first when conducting an economic 

analysis. 

Best Available Control Technology Guideline I J. Flberalass Fabrication - Pultrusion 
P.38 

MfacV\ (went 3 

Memorandum 

To: ft4D£LEttoe 5TG.UM. Date: V?/*5" 

From: /**£(& BAHtOE.fl. 

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Research Triangle Institute

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P.39 

RESEARCH TRIANGLE INSTITUTE /RTI 

Center for Environmental Analysis 

FAX TRANSMITTAL COVER SHEET 

TO: 

Page 1 of 8 

Date Ilfii»h4 

TF-.ftftY COVJL&Y I BOB L/\CO\/A(Kr\ 

D ow gHgfriiC/iLs/ £»F . A. 

FAX: 

PHONE: 

(4o4 ) 73 8 -O-Z/2.1 

(*0<j) 2/3,8 -5Z7.- 7 

FROM: 

PHONE: 

MARK 6dHAJ£^ . 

POLLUTION PREVENTION PROGRAM 

HOBBS BUILDING 

(919)541- CAtk FAX: (919)541-7155 

SUBJECT: 

PROJECT NO: 

SELELCTeib ?&&&£> OF TUB. 

FA CTO rZ , NOTE PiSSOfiApTfotJ OF 

\G H&/p/? y o f $P&tV(\(0& AMD AODiTio/0 

COrt T <9V/^rO EMtSSiO^S . 

3040 Comwailis Road • Post Ollice Box 12;9-i 

Telephone 919 i 

Research Ttiangle Park, Noun Carolina 27709-2194 USA 

•56'i6 • Fax\)l9 5-S1-7155 

~b^o 
P.40 

DCN No.: 92-275-026-54-11 

Radian No.: 275-026-54 

EPA No.: 68-D9-0054 

DETERMINATION OF STYRENE 

EMISSIONS FROM THE CULTURED 

MARBLE AND SINK 

MANUFACTURING INDUSTRY 

FINAL REPORT 

General Marble 

jjncolnton, NC 

Work Assignment Z54 

EPA Contract 68D90O54 

prepared for: 

Robert McCrackan 

Emission Measurement Branch 

Research Triangle Park, North Carolina 

Prepared by: 

Radian Corporation 

Research Triangle Park, N.C 22209 

June, 1992 

37 
2.0 DESCRIPTION OF FACILITY AND SAMPLING LOCATIONS 

2.1 Description of Facility 

General Marble, located in Uncolnton, N.G, manufactures products 

consisting almost entirely of bathroom sinks. This facility can be characterized as a large 

production operation in contrast to smaller custom manufacturing operations. The 

normal plant operating schedule is from 6:00 AM to 12:00 midnight, Monday through 

Friday.-? 

Including two 10 minute work breaks and 30 minutes for lunch, the 

operating schedules for specific tasks are as follows: 

Spray Booth 6:30 AM to 11:15 PM 

Casting - 7:00 AM to 11-30 PM 

Gel Coat Oven 6-30 AM to 11:15 PM 

Post Curing Oven 7:30 AM to 1130 PM 

Grinding/Sanding 7:00 AM to 3:30 PM 

The resin \s purchased in bulk liquid form and transported to the facility 

by tanker truck. The resin h stored on site in four 4000 gallon tanks which are housed 

in a separate room attached to the main manufacturing area. The gel coat, a more 

highly refined version of the resin, is purchased in bulk liquid form in 55 gallon drums. 

The daily mixing of the resin with crushed marble filler is performed in three large open 

top mixing vats. Each vat will contain 1200 lbs. of mix of which 23% by weight is resin. 

Smaller 120 lb. "workingf batches are removed from the vats as needed. Catalyst \s then 

added to the "working" batch before pouring onto the molds. The casting process uses 

closed molds which have been "gel coated". (Approximately 16,000 lbs. of mix is used 

per day to produce 500 - 600 units.) 

The emission points for styrene within the building are the mixing vats, the 

gel coat spray area and the point in the process where the resin is applied to the molds. 

dkd.196 

StyTCtK-Pol 

2-1 

nfi 
The entire manufacturing operation is housed in a large single room except 

for the resin storage tanks which are in a separate room attached to the larger room. 

Individual units are produced in a clock wise flow through the facility. Molds are 

cleaned and waxed as the first step in the process. The molds then proceed to the spray 

booth where a thin layer of resin, "gel coat', is applied. The molds move down a 

conveyer passing through a gel coat drying oven. A premixed composition of resin, filler 

and catalyst are applied to the molds manually using hand held trowels. The back of the 

mold is clamped into place and the assembly is mechanically vibrated to remove bubbles 

and allow the resin to settle. The molds continue to travel along the conveyer passing 

through a curing oven and on to the sanding and grinding area. The finished products 

then go to the warehouse area for packaging and shipment 

Exhaust fans are used to vent the work place air to the outside of the 

building. The gel coat drying oven an3 the curing oven, have two ducts each that extend 

through the roof. The spray booth has a single duct that also extends through the roof. 

The tank room has a floor level intake vent that exhausts through a louvered fan 

mounted on an outside walL Each of the four storage tanks has a two inch static vent 

pipe that extends through an outside walL Particulate from the grinding and sanding 

operation and from the mixing vats is controlled by a high efficiency filtration system. 

The filtered air is returned to the work place and not vented to the outside of the 

building. Five louvered exhaust fans are mounted near the ceiling on the back outside 

walL These fans are for general building exhaust (not associated with a specific 

operation) and are operated only in the wanner months of the year. No emission 

controls are in place except for the filtration system. Figure 2-1 is a diagram of the plant 

product area. 

22 Sampling Locations 

The sampling locations are described in the following sections. Sketches of 

the locations are contained in the appendices. 

dkd.196 

StyrcncJ-'nl 

2-2 

3^j 
Exhaust Fans 

Grinding ...75^5^^..^.. . 

Sanding L.Q..Q..Q......JS 

Area —— . 

Polishing 

Area 

Curing 

Oven 

Package 

Shipping 

Area 

Shaker 

Pouring 

Area 

O 

G 

Batch^ 

Mix ( J 

Miy 

o 

o 

Mold 

Prep 

I J). Fan 

Q 

8 

o 

•a 

Gel 

Coat 

Oven 

/ 

/ 

Doors 

Mbdng 

Tanks O O O 

L 

Exhaust 

Fan 

—Epl 

o s 

• a 

Tank 

Room 

Garage Doors 

Figure 2-1. General Marble Plant Production Area 

2-3 

ko 
P.44 

/ 

W W . Serene^-^oaaadEo^oaRaleSununary 

General Marble (March 1992) 

Date 

. SamplingTime-

:

 Styrene 

{^jjgeeotratioo 

Run Avenge 

Styrene 

Cooceotratloo 

Avenge 

SUck 

Flow Rate 

(dscftn) 

Emission 

Rate. 

(Ib/hr) 

Curing Oven Inlet 3/05/92 

Curing Oven Outlet 

Avcra 

1620-1720 

1725-1825 

1830-1930 

13.6 

13.6 

10.2 

b 

14.4 

14.9 

13,6 

10.2 

2484 

2484 

3/05/92 

Avenge 

1005-1105 

Duplicate 

1230-1330 

Duplicate 

1515-1615 

5.4 

4.9 

5.3 

5.1 

a 8.8 

a 8.8 

a 8.4 

a 7.9 

11.8 

11.7 

1H 

5.2 

5.2 

8.8 

8.2 

11.8 

3423 

3423 

3423 

3423 

3423 

a Calculated Styrene concentration using peak heights. 

b Low sample volume. cation 3 2 5. 

N/A = Not applicable 

3-7 

4-1 

0.507 
P.45 

a Calculated Styrene concentration using peak heights. 

b Low sample volume. lculated. See Section 3.2.5. 

c Sample was a grab sample, no emis«on rate ca 

N/A = Not applicable 

3-8 

k\ 
32JS Styrene Emission Summary 

Monthly inventory data relative to the consumption of resin, gel coat and 

filler was available from General Marble. The inventory data for the month of 

February; 1992*shows that 114,805 lbs. of resin; 6289 lbs; of gel coat and 499,000 lbs. of 

filler was used in the manufacturing process. For this time period, the number of 

production Jays was 19. The average daily use of resin, gel coat and filler is calculated 

to be 6042 lbs.,-331 lbs. and 26,263 lbs. respectively. The average daily consumpu'on of 

resin was calculated to be. 6,373 lbs. (resin plus gel coat) which was used to produce a 

daily average of 608 units. This shows that on the average for every pound of resin^if 

units can be produced. This agrees very closely with the daily production logs. From the 

data given in Table 3-3, the styrene emission rates from the spray booth, gel coat oven 

inlet and outlet the curing oven inlet and outlet and the tank room exhaust can be 

summed to give an.average plant-wide emission rate of 12,4 lbs./hour. For a 16'hour 

production day, the daily styrencemission rate would be 198Tbs7dayr Therefore the 

daily emission rate of styrene would be 198 lbs. per 6373 lbs of resin, used. 

dkd.196 

Styrcoe-Frd 

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REGULATORYNEWS 

"7T~TTTTC7T7VTCTO—» —T~ 

P.47 

CoMffia't^ Uf$4i> Hades 

LOOKING INTO THE FUTURE 

In this column, I'd like to offer a few 

predictions for the future of the composites industry. No doubt my prognostic ability is not infallible. Yet the 

trends seem both clear enough and 

dangerous enough to warrant a few 

educated guesses about the future. If 

I'm proven wrong, so much the better 

for the industry. And if I'm right, then I 

can go on Oprah. 

Smaller facilities will escape 

regulation under the CAA, and 

will therefore enfoy a significant advantage over their 

larger, highly-regulated competitors. Under the 1990 amendments to the Clean Air Act, EPA and 

the states are to require major sources 

in the composites industry to adopt 

Maximum Achievable Control Technology to reduce emissions of styrene. Major sources are facilities with 

the potential to emit 10 tons per year 

or more of styrene, assuming continuous operations. Any facility that is not 

a major source is considered an "area 

source." 

I expect EPA to either exempt area 

sources from regulation under the 

MACT standard altogether, or set a 

readily-achieved .level of control similar to California's Rule 1162. For major 

sources, the MACT requirement for 

new production capacity will be at 

least as stringent as the best controlled similar source. EPA fully expects that this level of control will be 

expensive — in effect, major sources 

will have to adopt the highest level of 

control that they can afford. 

Area sources are also exempt from 

many of the permitting requirements 

under Title V. The permitting process 

for major sources will be time-consuming, costly, and will place significant operational restrictions on facilities. While area sources may still be 

required to have some sort of permit, 

particularly those sources qualifying 

under state "synthetic minor" programs, these permits will be obtained 

through a streamlined process. Area 

sources will not be required to perform all of the monitoring and reporting activities required of major sources. 

Requirements for "cose-bycase" MACT may make EPA 

irrelevant. By the time EPA publishes the composites MACT standard, 

most major sources in the industry will 

have already negotiated MACTs with 

their states. These case-by-case 

MACTs are required under sections 

112(g) and 112(j) of the 1990 Amendments to the CAA. 112(g) requires 

case-by-case MACT for new construction and modifications, and takes effect as early as 1995.112(j) applies to 

existing sources, and takes effect in 

November of 1997. 

In submitting applications for these 

case-by-case MACTs, facilities are to 

follow the same procedures EPA will 

follow for MACT: survey industry facilities and determine the level of control 

achieved; identify similar sources in 

other industries and look at their controls; rank all controls identified by 

control efficiency, cost effectiveness, 

energy and cross-media impacts; and 

finally select the most effective affordable control. (Incidentally, no one 

knows what "affordable" means. EPA 

may eventually set some cost figure, 

in dollars per pound of styrene collected or destroyed- In the meantime, 

determining what is an affordable level 

of control will be a matter for negotiation with your state.) 

In addition to placing the MACTdevelopment burden on individual 

facilities, these cose-by-cose requirements make the MACT 

development process a freefor-all. It's very possible that the 

industry will see dozens of different 

facilities all making independent MACT 

determinations. 

Once a permit is granted based on 

a certain MACT, the technology becomes a matter of public record, and 

states will rely on this record when 

reviewing MACT applications from 

other facilities. This means that the 

first company to get a MACT approved 

by its state has, in effect, paid for a 

MACT determination for its entire industry. On the other hand, a large, 

well capitalized company can use this 

process to set an expensive level of 

control for the entire industry. 

Take another look at abatement. Just the mention of thedreaded 

word "incinerator" is enough to send 

shivers through the most hardened 

composites industry manager. Certainly, incineration technology, with its 

high capital and operating costs, and 

NOx and C02 emissions, is a poor 

choice for many composites facilities. 

Yet, for a number of reasons, the industry should be looking for workable 

and affordable abatement controls. 

("Abatement" means end-of-stack 

control technology, such as absorption, condensation, incineration, etc.) 

The first reason is the preference 

of EPA for abatement controls. This preference is based on 

both a long tradition of using abatement technology to control air pollutants, and a realization that such controls are easier to enforce than work 

practices and operational standards. 

EPA has agreed to use pollution 
P.48 

prevention technology for MACT, but 

only when affordable abatement controls are not available. Further, the 

pollution prevention technology must 

result in significant reductions in emissions (minimum of 60%). the reductions must be supported by hard data, 

and the technology must be enforceable as a practical matter. For example. low-VOC coatings have been 

accepted by EPA as MACT. because 

it is easy to verify their effectiveness 

(since all of the VOC evaporates, putting less in the formula necessarily 

means that less will evaporate), and 

enforcement is simply a matter of 

checking the label on the drum. 

A second reason to have a look at 

abatement controls is the requirements 

for case-by-case MACT described 

above. The important question is: 

what will your state accept as 

MACT? MACT applications based 

on abatement are likely to gain rapid 

approval by states. On the other hand, 

applications based on pollution prevention options, such as suppressed 

resin technology, will be a problem for 

states unless the applicant can clearly 

demonstrate both significant levels of 

reduction and enforceability. 

The composites industry has already 

seen a number of cases where a facility has installed abatement, not because it was specifically required, or 

even because it was beneficial for the 

environment, but only in order to obtain an operating permit. Further, once 

even one facility in your industry obtains a permit based on abatement, 

you will find it very difficult to convince 

your state that the same level of control shouldn't apply to your facility. 

The final factor favoring abatement 

is the possibility that your state will 

decide to regulate styrene as a carcinogen (see the discussion on styrene classification, below). Abatement 

will be the only way to meet the strict 

fence-line limits that will be set for 

styrene if it is regulated as a carcinogen. 

The battle with EPA over styrene classification will never 

end. Since it is impossible to prove 

absolutely that styrene (or any substance, for that matter) is not a carcinogen, there will always be some 

uncertainty. EPA will prefer to deal 

with this uncertainty by simply assuming the worst, and proceed to regulate 

styrene as a carcinogen. 

SIRC deserves much credit for preventing an outright classification of 

styrene as a carcinogen. Some staffers at EPA, however, have decided 

that they can simply.regulate styrene 

as if it had a carcinogen classification? 

An example is the EPA proposal under 112(g). which regulates styrene 

more stringently than benzene, a 

known human carcinogen. SIRC and 

the other industry groups will continue 

the fight, and so far the science supports our position. However, the 

other side has a powerful 

weapont righteousness. 

In addition to the 112(g) regulation, 

there are other areas where EPA can 

practice stealth classification. For example, in deciding what is an "affordable" level of control, EPA will determine the health effects of exposure to 

styrene, in effect making a classification. 

By the end of the decade, I also 

expect EPA to add styrene to the list of 

substances' for which TCLP testing is 

required. If styrene is regulated as a 

carcinogen, the TCLP level will be set 

low enough so that overspray, partially-cured edge trims, and other industry solid waste will have to be 

disposed of as hazardous waste, at 

an industry-wide cost of some $100 

million per year. 

We'r e paying for our success. 

Industry has effectively challenged 

EPA over every regulation, and after 

decades of effort only a handful of 

industries were regulated under the 

CAA. In 1990, Congress said 

"Enough!," and with the help of George 

Bush (let's give credit where it's due), 

amended the CAA. Now we're faced 

with requirements like those under 

112(g) and 112(j). which pretty much 

make it irrelevant whether EPA writes 

regulations or not. 

Now, we are not entirely helpless 

here. For one. neither Congress nor 

EPA intends to put significant numbers of companies out of business by 

requiring expensive controls, and it's 

up to us to make sure this doesn't 

happen. 

Second, companies have much 

to gain by taking as much 

control of the process as they 

can. Build relationships with your state 

regulators and legislators. Start work 

on your permit application as soon as 

you can, think strategically about the 

terms of your permit, and attend CI's 

Permit Workshop in January. Start 

thinking about abatement (I know, it 

hurts — try it for just a few minutes a 

day in the beginning). 

Finally, Cl. CFA, SIRC, and the other 

industry groups are working hard to 

change the future. Get involved in 

these efforts. For more information, 

contact me at 313-668-4703. 

John Schweitzer 

Cl Technical Director 
Ewcio50£& 

WOOD FURNITURE NESHAP WORK GROUP MEMBER TABLE iijQS 9fa.fi fi'sf 

CORE WORK GROUP MEMBERS ARE IN BOLD TYPE. 

NAME 

Madeleine Strum 

MUTUAL DURHAM 

Linda Herring 

MUTUAL DURHAM 

Jordan Spooner 

(WATERSIDE 

MALL, DC) 

Maria Malave 

(DC) 

Haile Mariam 

(WATERSIDE 

MALL, DC) 

Patricia Embrey 

(WATERSIDE 

MALL, DC) 

Karen Levy 

Dan Axelrad 

(WATERSIDE 

MALL, DC) 

Bob Fegley 

(WATERSIDE 

MALL, DC) 

OFFICE 

OAQPS/ESD/ 

Coatings and 

Consumer Products 

Group (CCPG) 

OAQPS/ESD/CCPG 

OPPT 

Pollution Prevention 

Division 

OECA 

OSW 

Waste Min. Branch 

OGC 

OPAR 

OPPE 

ORD 

PHONE# 

919 541-2383 

919 541 5358 

202 260 4418 

202 564 7027 

703 308 8439 

202 260 7625 

202 260 8952 

202 260 9363 

202 260 0484 

FAX# 

919 541 0072 

919 541 0072 

202 260 0187 

202 564 0050 

703 308 8433 

202 260 0586 

202 260 9766 

202 260 0512 

202 260 6932 

ADDRESS 

MD-13 

US EPA 

RTP, NC 27711 

MD-13 

USEPA 

RTP, NC27711 

MAilcode 7409 

401 M. St. SW 

Washington DC 20460 

OEC A/2223 A 

401 M. St. SW 

Washington DC 20460 

5302W 

401 M St. SW 

Washington DC 20460 

2344 

401 M St SW 

Washington DC 20460 

Mailcode6103 

401 M. St 

Mailcode 2126 

401 M St. SW 

mail 8105 

401 M St. SW 

Comments 

Project Lead 

to whom all correspondence 

should be directed; 

WORKGROUP CHAIR 

Group Leader for Coatings 

and Consumer Products Group 

Source Reduction Review 

Program (SRRP) Project 

Coordinator from OPPT 

OECA WG member 

* 

dismissed himself and OPPE 

fromWG 1/95 

o 

A: 
NAME 

Bob Burmark 

Mohan Balagopalan 

Bob Rose 

(Crystal City, VA) 

Ron Ryan 

(EPA;RTP) 

Leonardo Ceron 

Jeri Weiss 

Chuck French 

Laurel Driver 

Craig Matthiessen 

(WATERSIDE 

MALL, DC) 

Carlos Nunez 

OFFICE 

State of Washington 

South Coast Air 

Quality Management 

District 

Deputy Small 

Business 

Ombudsman 

OAQPS/EMAD 

/Emission Inventory 

& Factors Group 

Region 4 

Region 1 

AQSSD/Risk & 

Exposure 

Assessment Group 

AQSSD/Visibility 

and Ecosystem 

Protection Group 

OSWER 

ORD/AEERL 

PHONE# 

206 407 6812 

909 396 2704 

703 305 5511 

919 541 4330 

phone 404 

347 3555 ext 

4196 

617 565 9177 

919 541 0467 

919 541 2859 

202 260 9781 

202 260 9781 

5338 (sec.) 

919 541 1156 

FAX# 

206 407 6802 

909 396 3342 

703 305 6462 

919 541 0684 

404 347 2130 

617 565 4939 

202 260 0927 

919 541 2157 

ADDRESS 

Dept Ecology; Air 

program; PO Box 

47600; Olympia, 

Washington 98504-

7600 

SCAQMD;21865 E. 

Copley Drive, 

Diamond Bar, CA 

91765-4182 

OSDBU 

1230-C 

401 M St , SW 

MD-14 

345 Courtland Street, 

NE 

Atlanta, GA 30366 

APO 

JFK Federal Building 

Boston, Mass 02203-

2211 

MD-15 

MD-15 

5101; US EPA 

401 M St. SW 

Washington DC 20460 

MD-61; RTP, NC 

27711 

Comments 

not sure if they are on WG yet 

information only 

lead Regional WG member 

information only 

information only 

not sure if he is WG yet 

ORD pollution prevention 

project coordinator 
NAME 

Norm Kaplan 

Lisa Conner 

(MUTUAL 

DURHAM, NC) 

Solomon Ricks 

(GRAND SLAM, 

RTP) 

Jane Caldwell 

(MUTUAL 

DURHAM, NC) 

Richard Nielson 

OFFICE 

ORD/AEERL 

OAQPS/AQSSD/ 

Innovative Strategies 

& Economics Group 

OAQPS/EMAD/Sou 

rce Characterization 

Group A 

OAQPS/AQSSD/He 

alth Effects and 

Standards Group 

Clark County Health 

District (Las Vegas) 

PHONE ft 

919 541 2556 

919 541 0560 

919 541 5242 

919 541 0328 

702 383 1276 

FAX# 

919 541 5227 

919 541 1039 

fax 702 383 

1443 

ADDRESS 

MD-61; RTP, NC 

27711 

MD-15 

USEPA 

RTP, NC 27711 

MD-19 

USEPA 

RTP, NC 27711 

MD-15 

USEPA 

RTP, NC 27711 

PO Box 4426, 625 

Shadow Lane, Las 

Vegas 89127 

Comments 

cost, economic and impact 

analysis lead 

measurement lead 

information only 

Acronyms: 

AQSSD = Air Quality Strategies and Standards Division (which is within OAQPS) 

EMAD= Emissions, Monitoring & Analysis Division (which is within OAQPS) 

ESD= Emissions Standards Division (which is within OAQPS) 

OECA= Office of Enforcement and compliance assurance 

OGC= Office of General Counsel 

OPAR = Office of Policy Analysis and Review 

OPPT = Office of Pollution Prevention and Toxics 

OSDBU = Office of Small and Disadvantaged Businesses 

OSW= Office of Solid Waste 

ORD= Office of Research and Development 

AEERL= Air and Energy Engineering Research Laboratory 

EPA CONTRACTORS ON PROJECT: 

FOR OAQPS/ESD Project: 

Ken Meardon/Greg LaFlam; Pacific Environmental Services (919) 941 0333 (ph) 941 0234 in person 

FOR ORD/AEERL Project: 

Mark Bahner/Emory Kong; Research Triangle Institute (919) 541 6016 by fax 7155