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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

16) ll-C-42 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:27 PM Sheet 16 of 343 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

AUG I 3 1996 

Mr. John Schweitzer 

Composites Institute 

1441 White Street 

Ann Arbor, Michigan 48104 

OFFICE OF 

AIR QUAUTY PLANNING 

•* AtWSTANOARDS^ 

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"'•'"•'V- &w1 . EPA AIR DOCKET 

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A-94-52 

Dear John: 

During the July 29, 1996 meeting on MACT for pultrusion, you 

requested information about Tecton's capture and emission control 

system. Per your request, I am sending you Tecton's operating 

permit and data from a 1993 emission test, which are considered 

not to be confidential business information (CBI). The operating 

permit contains information about Tecton's process, emissions, 

and emission capture and control system. The 1993 emission test 

shows inlet and stack concentrations, flow data, and the removal 

efficiency of the control device. 

You mentioned in the last meeting that you were concerned 

about worker exposure in the enclosures. We are still trying to 

put together non CBI data about the concentration measured in 

Tecton's enclosures and will be able to share this information 

with you as soon as we receive itr. 

_ Sincerely, 

^UjtQu^ J^ 

Madeleine Strum 

Environmental^ Engineer 

Coatings and Consumer Products Group 

2 Enclosures 

cc: John Jambois, Tecton Products (w/o Enclosures) 
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Interpol! Laboratories, Inc. . 

4500 Ball Road N.E. 

Circle Pines, Minnesota 55014-1819 

TEL: (612) 786-6020 

FAX: (612)786-7854 

RESULTS OF THE JULY 15, 1993 

TOTAL HYDROCARBON DRE TEST ON THE 

THERMAL OXIDIZER AT THE TECTON PRODUCTS 

PIANT IN FARGO, NORTH DAKOTA 

Submitted to: 

TECTON PRODUCTS 

Box 102 

Fargo, North Dakota 58103 

Attention: Charlie Vanasse 

Reviewed by: 

Report Number 3-9415 

July 29, 1993 

DD/djd 

Daniel J. Deepen 

Manager 

Stationary Source Testing Department 

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TABLE OF COIMTE^S 

ABBR^IATIONS iii 

1 INTRODUCTION 1 

2 SUM.MARY AND DISCUSSION 3 

3 RESULTS 5 . 

3.1 Orsat & Moisture Analyses 6 

APPENDICES: 

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• A - Volumetric How Rate Determinations 

' B - Location of Test Ports 

C - Reid Data Sheets 

I D - Interpol I Laboratories Analytical Data 

E - THC Stripcharts 

1 F - Me^urement System Performance Specifications 

G - Process Documentation 

• H - Procedures 

I - Calculation Equations. 

** J - Sampling Equipment Calibration Data 

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1 INTRODUCTION 

On July 15, 1993, Interpoll Laboratories personnel conducted a total hydrocarbon 

(THQ destruction removal efficiency (DRE) test on the thermal oxidizer in accordance with 

Subpart W V of CFR Title 40, Part 60 at the Tecton Products Facility in F^go, North Dakota. 

Data colleaed in February 1993 to determine face velocities for two total enclosures are also 

included in this report for reference. On-site testing was performed by E. Trowbridge and 

R. Aschenbach. Coordination between testing activities and plant operation was provided 

by Charlie Vanasse of Tecton Products. The test was witnessed by Gary Helbling of the 

North Dakota State Department of Health - Air Quality Management Branch. 

The system tested consists of two total enclosures to capture VOC emissions from 

each of two pultruder lines designated Line 1 and Line 2. The air and VOCs which are 

pulled from the total enclosures is routed to a thermal oxidizer to remove the VOCs prior 

to expelling the cleaned air to atmosphere. During these tests the thermal oxidizer bed 

temperature averaged 1690°F. 

EPA Method 2, CFR Title 40, Part 60, Appendix A (revised July 1,1992), was used 

determine the volumetric flow rate in each ofthe two total enclosure exit ducts. The natural 

draft openings were documented and measured by Tecton Products personnel and verified 

by E. Trowbridge of Interpoll Laboratories. 

The concentration of total hydrocarbons (THQ was measured simultaneously at the 

thermal oxidizer Inlet and Outlet as per EPA Method 25A, (ibid), using two fatfisch Model 

RS55 Total Hydrocarbon Analyzers (heated flame ionization detector). The sample gas 

stream was extracted from the source through a heated probe and filter. The particulate free 

gas stream was then transported through a heated teflon umbilical (250 °F) into the analyzer 

oven where a portion ofthe gas is fed into the heated FID. The analyzer was calibrated with 

zero, low, mid and high propane in air gas standards. The analog output of each HFID was 

monitored with stripchart recorders. A volumetric flow rate determination was conduaed 

at each test site in accordance with EPA Method 2 in order to calculate total hydrocarbon 

mass rates. 

An integrated flue gas sample was extraaed simultaneously with the Stack THC 

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samples using a specially designed gas sampling system Interna fl 

- V d«e«ab.e rn,eakage „ disaMeJ . ^ integrffled ^ ^ * * 

analyzed for methane by GOFID/CSV. TM"«raa were also 

The important results of the test are summarized in Section 2. Field data and all 

other supporting information are presented in the appendices. 

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2 SUMMARY AND DISCUSSION 

The results of the THC DRE test are summarized below. The measured THC 

concentration at the Inlet averaged 47b DDm£,w which corresponds to an average mass rate 

of 2.00 LB CMR. The THC concentradon averaged 15 ppmC.w at the Stack and the 

emission rate averaged 0.061 LB C/HR. The resulting removal efficiency averaged 96.96%. 

Concentration* Vol Flow Mass I^ate Removal 

Time (oomC.w) (PSCFM) (LB C/HR,- Effic 

(HRS) Inlet Stack Inlet Stack Inler Stack (%) 

1015-1115 471 12 2070 2220 1.86 0.051 97.26 

1230-1330 483 9 2302 2140 2.12 0.037 98.26 

7535-1635 474 & ___& 2150 ' 2.03 0.094 qs.17 

Average 476 15 2207 2170 2.00 0.061 96.96 

ppmC.w - ppm carbon on a wet or aaual basis. 

• - Concentrations reported are total nonmethane hydrocarbons (methane results at the 

stack have been used to compute 4NJMTHC from THC (see appendix D for methane 

analyses). 

The produaion records for these tests are included in Appendix G and indicate that 

Line 1 produced 120.25 Ib/hr and Line 2 produced 188.25 Ibrtir for a total of 308.50 lb/hr 

of finished product. 

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The results ofthe February 1993 face velocity determination** un rhe total enclosure* 

v e summarized below. Identical measurements wer? pprfnrmed on each of the two total 

enclosures ar rhis facility. Copies of the natural draft opening measurc-n innis are included 

in Appendix C. 

MnP 1 Tnrat hnrinsnri* 

Total Natural Draft Opening ........ . (fr) 1.2 

(nr) O.Ilt 

Joral Flnw Out (cfm) 4S0 

(mVhr) 77-1.7 

Face Veloaty (m/hri 6./J50 

Line 2 Total enclosure ' 

Total Natural Draft Opening (fr* O.'.'JB 

(nr) 0.U8G2 

Total Flow Out (cfm) 430 

(m'/hr) 730.6 

Face Velocity (m/hri 0.470 

Both The line 1 and Line 2 Total rnclosurcs met the minimum fact* velocity 

requirement of 5ubpart VW which is 3,600 irvlw. Sine? both of the resulting face x-ulocirie* 

were below 9,000 m/hr streamer* were used to verify thar the flow was into the enclosure) 

during these tests. 

No difficulties were encountered in the field or in the data redut tiun. On [he basis 

of these facts and a complete review of the data and results, it i« nur opinion that the results 

reported hp/Pin are accurate and closely reflea the aetu.il value.i which existed di ihe time* 

the test was performed. 

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3 RESULTS 

The results of the g^ composition (orsat) are presented on the following page. The 

results have been calculated on a personal computer using programs written in Extended 

BASIC specifically for source testing calculations- EPA-published equations have been used 

as the basis of the calculation techniques in these programs. 

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Docket No. A-94-52 

Subcategory II-Cl 

The enclosure may be found in docket number A-94-52, item II-I-Y0 

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U.S. Environmental Protection Agency 

Office of Air & Radiation (OAR) 

Docket & Information Center 

(Air Docket) 

Telephone: (202) 260-7548 

Facsimile: (202) 260-4400 

FAX TRANSMISSION COVER 

DATE: 03/18/99 

FROM: Joseph P. Moeltner, Jr. (c) - RIM V, DOM 

Armstrong Data Services (ads) 

U.S. Environmental Protection Agency 

Office of Air & Radiation (OAR) Docket & Information Center 

(Air Docket) 

TO: Marlae Fry (202) 974-5276 = p 

Society of the Plastics Industry (SPI) (202) 296-7218 = f 

TOTAL NO. OF PAGES INCLUDING COVER SHEET: 10 

MESSAGE: Ms. Fry, 

Attached please find a copy 

requested from our office. 

Docket: A-94-52 

II-I-37 will follow via mail... 

We certainly hope that this helps...If I can 

please do not hesitate to contact me. 

Thank you very much. 

of the document that you 

ll-C-42 

be of any further assistance...