OAR Box 1415 

Prepped by Ollie Stewart 

Document Number: 

11) IV-E-11 

Docket Number: 

A-94-52 

Printed 7/15/2008 9:38:26 AM 

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N-e-n 

MEMORANDUM 

TO: Docket for Reinforced Plastic Composites NESHAP 

FROM: Keith Barnett, U.S. Environmental Protection Agency, Emissions Standards 

Division 

DATE: July 31,2002 

SUBJECT: Meeting with representatives ofthe Reinforced Plastic Composites Industry 

On July 30, 2002, a meeting was held in the Office ofthe Director ofthe Emissions 

Standards Division between representatives ofthe reinforced plastic composites industry and the 

U. S. Environmental Protection Agency. The attendees were as follows: 

Representing the Composites Fabricators Association (CFA) 

John Schweitzer, CFA, Senior Director of Government Affairsr 

Bill Pedersen, Shaw Pittman 

Chuck Elkins, Chuck Elkins & Associates 

Representing the U. S. Environmental Protection Agency 

. ' 1 ~ 'J '•..•*•. 

EPA AIR noCKRT ; 

Sally Shaver, Director, Emission Standards Division 

Penny Lassiter, Group Leader, Organic Chemicals Group 

Keith Barnett. Project Lead for Reinforced Plastic Composites ENESHAP 

The purpose ofthe meeting was to allow the CFA representatives to express their 

concerns about new source MACT for facilities producing large parts. Attached to this 

memorandum are the talking point from the meeting, and two additional handouts provided by the 

CFA. 

As a result ofthe meeting, it was agreed that EPA would review the analysis prepared by 

Dr. Rob Haberlein (Attachment 3) and respond to the CFA whether not this information supports 

CFA's contention that capture and control is not feasible for large parts. The CFA 

representatives agreed to respond with additional information on what part size they consider to 

be large. 
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Attachment 1 

Talking Points prepared by CFA for July 30 meeting 

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Composite Fabricators Association - July 30,2002 

"Talking points" for meeting with EPA on MACT for new sources making large parts 

EPA's proposed MACT rule for composites would reqxiire all new sources with emissions of 

lOOtpy or more to achieve 100% capture and 95% control of all emitted HAP. 

EPA has pointed to the purported use of 100% capture and 95% control by a few existing 

sources as demonstration that this level of control is achievable. These sources, however, 

were designed to make only small parts, while many ofthe likely new sources will be 

designed to make large parts. 

The following technical factors define the dissimilarity between these two groups of 

sources and explain why sources making large parts can not achieve the same high 

levels of capture that may be possible for sources making small parts: 

o Process enclosures must have doors that allow molds and parts to be continuously or 

frequently moved into and out ofthe enclosures. EProduction continues while the 

doors are open, so high levels of capture must be maintained at all times. 

Maintaining capture is possible if small doors are used, but not possible if doors 

sized for large parts are used. 

o Process areas for small parts open into larger buildings, protecting them from wind 

loads. Large parts, however, are moved from process areas directly onto trucks for 

shipment, meaning the process areas for large parts open directly to the outside of 

buildings, making them susceptible to wind loads. We know of no way to maintain 

capture when even moderate wind loads are present. 

o Workers in plants making small parts are protected from overexposure to HAPs by 

positioning them upstream ofthe parts, and by using contained process enclosures 

("spray booths"). Spray booths employ "pull" ventilation, where fresh air flows into 

die booths through die doors, past die workers, across the parts, and dien the 

contaminated air is "pulled" out die exhaust vents. Workers in plants making large 

parts, however, are positioned all around and inside ofthe parts, and die parts are 

located in large open process areas (the parts are too large and the manufacturing 

process too complex for the parts to fit into spray booths). Workers are protected by 

the use of "push-pull" ventilation, where fresh air is "pushed" into one side ofthe 

open process area, flows across the parts and workers, and then contaminated air is 

"pulled" out ofthe opposite side. Some of die "pushed" air spills into the open area 

and is not captured by die "pull" exhaust. It is impossible to achieve high levels of 

capture in large open process areas that use push-pull ventilation. 

EPA's current approach amounts to a construction ban on the new plants that will be needed 

to make large parts. 

The final rule should set different control requirements for new plants making large 

versus small parts. These requirements should be based on die relevant technical 

characteristics of diese operations. 

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Attachment 2 

Discussion of 95 percent capture and control for making large parts 

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Composite Fabricators Association July 26, 2002 

Discussion: 

95% Capture and Control for New Sources Making Large Parts 

We discuss diese and other issues in greater detail below, but in summary: 

• The proposed MACT requirement for new composite manufacturing operations with 

emissions of 100 tpy or more - to employ add-on controls achieving 100% capture and 

95% overall control - will effectively prevent die construction of new plants designed to 

build large products. 

• The rule should distinguish between tiiose new sources constructed to make primarily 

small parts, where enclosures with high capture efficiencies can be employed, and otiier 

sources that cannot feasibly use such enclosures. 

• EPA should rely on the important technical and operational differences between small and 

large part production to establish the appropriate MACT requirements. 

• In addition to the technical considerations, achieving high levels of capture for large parts 

would be so expensive that EPA's proposed requirement amounts to a construction ban. 

• New plants with emission of 100 tpy or more making large parts should be required to 

employ the same effective pollution prevention controls as smaller new plants and 

existing plants. 

Background and EPA's Proposed MACT Rule 

The Clean Air Act requires MACT for new sources of hazardous air pollutants to require at least 

the degree of emission reduction "achieved in practice by the best controlled similar source." 

CAA §112(d)(3). In the proposed MACT standard for composite manufacturing (66 FR 40324), 

EPA asserted that this "floor" language required all new open molding and pultrusion sources 

with potential emissions over 100 tons per year to install add-on control systems achieving 100% 

capture and 95% overall control. 

EPA pointed to two plants that make small parts - the A.R.E. and American Standard operations 

in Ohio - as the justification for imposing this "floor" requirement on open molding sources. 66 

FR 40331. The justification for the pultrusion requirement is less focused, but appears to rest on 

another plant - Tecton in North Dakota - that also makes only small parts. 

As noted, the Clean Air Act requires new source "floor" controls only for sources that are 

"similar" to the floor-setting sources. The proposal's only discussion of this requirement relates to 

the size of parts made by the floor-setting facilities. EPA said: 

The two facilities [that set the floor] produce parts that range in size from that of 

bathtubs to truck caps. It is possible that larger size parts may require larger 

enclosures. We have not identified any facilities in the reinforced plastics 

composites industry where processes producing large parts, such as storage tanks 

and swimming pools, have applied 100% efficient capture systems. However, we 

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Composite Fabricators Association July 26, 2002 

have identified facilities using 100% efficient capture systems that apply coatings 

to large parts such as helicopters and ships. These coating operations have similar 

issues of large air flows (due to worker exposure concerns) and low outlet HAP 

concentrations. Based on this, we believe it is technically feasible to apply 100 

percent efficient capture systems to larger parts in the reinforced plastics 

composites industry. 66 FR 40332. 

As far as we know, EPA rested this claim entirely on a contractor study entitled "VOC/HAP 

Control Systems for the Shipbuilding and Aerospace Industries" by M. Lukey and V. Toothman. 

CFA's Comments 

CFA's comments on the new source issue focused on the study that EPA had cited to support its 

floor proposal. CFA pointed out that, according to the Lukey and Toothman study, neither of die 

two facilities studied had actually achieved the claimed level of control. Indeed, it was not clear 

they had even installed add-on technology, or operated it for any meaningful period if they had 

installed it. The study's estimate of add-on control performance rested entirely on theoretical 

projections. Further, the study revealed that serious worker overexposure could result. CFA 

pointed out many technical and operational differences between drydocks and hangers and 

composites fabrication facilities, all of which would make capture and control more difficult for 

composite manufacturing operations. 

CFA also addressed the capture and control issue more generally, primarily in the context of 

EPA's proposal of an "above-the-floor" capture and control requirement for existing sources. As 

part of that argument, CFA explained that plants making large parts are not similar to those 

existing plants making small parts that EPA claims achieve 95% control, because of problems 

associated with capture of emissions and moving products and molds into and out of process 

enclosures. 

CFA also pointed out that there was no reason to believe that even the plants making small parts 

that had installed capture and control had in fact achieved the 100% capture efficiency that EPA 

claims. In particular CFA argued that even though EPA had proposed use of Mediod 204 to 

measure or demonstrate capture efficiency at facilities subject to the MACT standard, the 

conditions for a valid Method 204 enclosure could not generally be met at composites fabrication 

facilities, and were particularly hard to meet at facilities that made large parts. See CFA's Oct. 

25, 2001 comments, p. 27-29, and also comments on the proposed composite MACT from 

STAPPA/ALAPCO (IV-D-72) and the Indiana Department of Environmental Management (IVD-75). 

EPA's Current Position 

As we understand it, EPA's current thinking on this issue is as follows: 

• The only dissimilarities between plants making small parts and tiiose making large parts 

are economic, and the Act precludes the use of economic considerations when 

establishing different control requirements for different types of sources. 

• The process enclosure at A.R.E. (a facility that produces small parts and reportedly 

achieves 100% capture) is large enough for the production of large parts such as barge 

covers. 

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Composite Fabricators Association July 26, 2002 

• Moving products and molds into and out ofthe enclosures while maintaining 100% 

capture will be more difficult (more expensive) for large parts, but the industry will find a 

solution if required. 

• Local regulators will sometimes waive the requirements of Method 204, and owners of 

new plants making large parts can negotiate favorable permit conditions for their process 

enclosures. 

CFA's Response 

CFA still does not believe that 100% capture of composites manufacturing emissions is feasible. 

In particular, plants making large parts can not achieve high levels of capture. Regarding MACT 

requirements for the new plants that will be needed to make these large products, CFA believes 

that EPA's approach is in error in several important ways: 

1. There are important technical factors that differentiate small part from large part 

manufacturing, and for new sources, EPA should use these differences to set 

appropriate control requirements for each group. 

New plants built to make large parts will have to be technically dissimilar to those existing plants 

that reportedly achieve 100% capture and 95% control. In particular, plants making large parts 

will not be able to achieve high levels of capture because ofthe following technical 

characteristics: 

• The need to frequently move molds and products in and out of process areas, and to 

provide doors or openings that are large enough, means that enclosures for large parts can 

not practically achieve high levels of capture. Process enclosures for composite 

manufacturing operations must have doors or other openings to allow molds to be 

brought into and products out ofthe enclosures. These doors must be opened frequently, 

during which time production operations (and emissions of HAP) continue. It can take 

over an hour to carefully move a large complex product, during which time enclosure 

doors must be open. Plants making small parts can use continuously open doors in the 

process enclosures to allow the movement of products and molds; these doors are small 

enough so that sufficient negative pressure is maintained in the enclosures even when the 

doors are open. The doors needed for large parts, however, will be too large; when these 

doors are open, negative pressure will not be maintained in the enclosures, and high 

levels of capture will not be achieved. 

• The "push-pull" ventilation and higher air flows needed to protect workers making large 

parts result in much lower achievable capture efficiencies. Workers in plants making 

small parts are protected from overexposure to HAPs by positioning them upstream of 

the parts, and by using contained process enclosures ("spray booths"). Spray booths 

employ "pull" ventilation, where fresh air flows into the booths through the doors, past 

the workers, across the parts, and then contaminated air is "pulled" out the exhaust vents. 

Workers in plants making large parts, however, must be positioned all around and inside 

ofthe parts, and the parts are located in large open process areas (the parts are too large 

and the manufacturing process too complex for the parts to fit into spray booths). 

Workers are protected by the use of "push-pull" ventilation, where large amounts of fresh 

air is "pushed" into one side ofthe open process area, flows across the parts and workers, 

and then contaminated air is "pulled" out ofthe opposite side. Some ofthe "pushed" air 

spills into the open area and is not captured by the "pull" exhaust. It is impossible to 

achieve high levels of capture in large open process areas that use push-pull ventilation. 

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Composite Fabricators Association July 26, 2002 

Much larger process areas are needed to produce large parts. Due to the complexity and 

thickness ofthe laminate, large parts require more lamination steps and longer curing 

periods than small parts. Further, large parts are typically built at fixed molding stations, 

and then moved to other large open areas for finishing and assembly (where HAPs are 

also emitted); in the small part operations that achieve high levels of capture, all.of the 

HAP-emitting steps take place in spray booths or contained curing rooms. Finally, large 

part manufacturing typically requires greater operational flexibility, so that changes in 

product size, shape, and manufacturing methods can be accommodated readily; the small 

part operations that achieve high levels of capture, on the other hand, rarely change the 

basic size or shape of products. Consequently, the process areas needed to make large 

parts, compared to those needed for small parts, are much larger than would be predicted 

by just comparing the size ofthe parts. 

• To accommodate loading of parts onto trucks, large part operations often open directly to 

the outside of buildings, making the enclosures susceptible to wind loads. Enclosures for 

small parts typically open inside buildings, providing greater resistance to wind loads, 

and consequently higher achievable capture efficiencies. For any process enclosure that 

opens directly to the outside, we know of no way to maintain capture when even 

moderate wind loads are present. 

The existing plants that employ high capture efficiency enclosures, all of which make small parts, 

can not fairly or legally be used by EPA to establish control requirements for plants making large 

parts. Technically, they are not similar. No existing composite manufacturing plants making 

large parts employ - or could employ - high capture efficiency enclosures. 

As far as we can tell from the materials available in the docket, the A.R.E. process enclosure is 

not large enough for the practical manufacture of barge covers or other large products, contrary to 

EPA's claim. Even if it were, this enclosure is in fact not used to make such parts, and we 

believe that it is unsuitable for such use. For example, the A.R.E. enclosure has no provision to 

, allow the movement of molds and products into and out of die enclosure while still maintaining 

negative pressure in the enclosure, as would be required by die MACT rule. 

The attached analysis by Dr. Rob Haberlein of Engineering Environmental Consulting Service 

contains a detailed comparison ofthe A.R.E. facility and another plant familiar to EPA (Proform) 

that makes large parts and is very similar to the new plants that the industry will need to build. 

Dr. Haberlein demonstrates that the A.R.E. facility could not feasibly be used to make large 

products, that plants built to make large products could not feasibly employ die same ventilation 

and capture technologies as A.R.E., and that plants built to make large products could not feasibly 

comply with the full requirements of Method 204. 

2. New plants built to make large parts will not be able to afford to achieve high levels 

of capture. 

EPA has not provided any support for its assertion that only economic factors distinguish plants 

that make small parts from plants that make large parts. As noted above, CFA believes that in 

fact a clear set of technical and operational differences separate plants that make small parts from 

those that make larger parts. But we also believe that these plants are distinguished by economic 

considerations. 

The achievability and affordability of capture and control for a given plant depends largely on the 

high volume production of small and uniform parts. It is less difficult and less costly for small 

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Composite Fabricators Association July 26, 2002 

parts to be made in specially constructed booths or enclosures with openings or tunnels that 

achieve high capture efficiencies while still permitting the necessary flow of parts, molds, 

workers, and materials into and out ofthe production areas. It is not an accident that all ofthe 

plants on which EPA has based the 95% capture and control requirement make small parts such 

as tub/shower units, pick-up truck caps, and window lineals. 

An engineer retained by CFA designed "maximum practical" capture and control systems for a 

number of typical plants, including several that resemble likely new plants. One of these plants 

makes tub/shower units (small parts), and one makes gasoline storage tanks and barge covers 

(large parts). Installing and operating the control systems (that do not necessarily achieve 100% 

capture) would cost approximately $5,000 per ton of HAP controlled for the plant making small 

parts, but over $25,000 per ton of HAP controlled for the plant making large parts. See the R. 

Haberlein report, "Cost of Capture and Control," attached to CFA's October 25, 2001 addendum 

to comments on the proposed rule. 

EPA's proposed approach amounts to a construction ban on new plants making large parts. Such 

a prohibition is frankly inconsistent with Congress's intent, which is that MACT should be 

achievable. Congress did not intend the MACT program to drive industries out of any of their 

existing lines of business. Instead, it intended MACT to bring sources in each of those lines of 

business up to floor control level. That is the basic policy behind the statutory requirement that 

sources subject to new source MACT must be similar to the floor-setting source. Accordingly, the 

Clean Air Act would not support a MACT standard that prohibited the construction of new 

sources to make an important range of composite products. 

Such a standard would also represent indefensible economic and environmental policy even if it 

were legal. Large composite products will be needed to serve several markets that are important 

for both the industry and die country. For example, 

• composite bridge beams, which are just now being studied by the civil engineering 

industry, will provide much longer life than steel beams, and allow the load capacity of 

bridges to be increased, 

• composite windmill blades will provide an important alternative energy supply for our 

country, 

• composite components for motor homes, trucks, and railroad cars are light weight, save 

energy and reduce emissions of greenhouse gases, 

• non-conducting composite utility poles and electrical transmission towers allow tighter 

placement of conductors, providing increased capacity of transmission lines, and 

eliminate the need for toxic wood preservatives, 

• composite gasoline, chemical storage, and septic tanks will not rust or corrode, reducing 

the risk of release into the environment, and 

• composite barge covers do not rust or corrode, preventing the contamination ofthe 

transported grain. 

Our industry's success in providing these products will depend on building efficient and modern 

new plants. The proposed 95% capture and control requirement for larger new sources is not 

achievable or affordable for plants making large products, and will prevent the construction of 

plants large enough to enjoy the necessary logistics, product flow, economies of scale, quality 

control, and management efficiencies. 

Nothing in the Clean Air Act supports EPA's claim that economic factors alone cannot justify 

different control levels. The law limits new source MACT "floor" requirements to sources that 

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Composite Fabricators Association July 26, 2002 

are "similar" to the floor-setting sources. The law does not specify how to determine "similar" 

and therefore sets no limits to EPA's authority to interpret it in a reasonable fashion. Moreover, 

the law also provides that in establishing MACT, the Administrator shall "take into consideration 

the cost of achieving such emission reduction." In fact, EPA has regularly considered cost in 

establishing distinctions among MACT control requirements. In this very rule EPA proposed 

more lenient requirements for facilities owned by small businesses than for other types of 

facilities because ofthe unreasonable economic impact of imposing the tighter requirement on 

small business. See 66 FR 40333. 

3. The final rule should be achievable as written, and not rely on the flexibility of local 

permitting agencies. 

EPA's assertion that even if its method for demonstrating 100% capture is flawed, that this may 

not matter so much since local regulators frequently make exceptions to allow practical 

compliance, is hard to fathom as the justification for a regulation - particularly in the absence of a 

formal reproposal. EPA can not defend die promulgation of a technically indefensible rule by 

asserting that it will be ignored in practice. Moreover, we cannot predict the extent to which local 

regulators will be willing to make exceptions. In some cases of which we are aware, they have 

not been willing to make any. For EPA to promulgate a rule that requires local regulators to 

make exceptions to published EPA guidance, instead of directly addressing the shortcomings of 

such guidance, is simply bad policy and is indefensible. 

4. EPA's apparent change in rationale requires reproposal. 

EPA's current approach, as we understand it, would violate applicable rulemaking procedure 

requirements. EPA proposed capture and control for all new open molding and pultrusion sources 

as a "floor" requirement. EPA conceded that the plants on which it based the requirement only 

made small parts, and raised the question whether they were "similar" to plants that made larger 

parts. EPA concluded, based entirely on the contractor report cited above, that the two types of 

plants were indeed "similar." 

Now EPA appears to have completely changed its justification and abandoned all reliance on the 

contractor report. Instead, EPA has offered a new range of justifications. Moreover, EPA no 

longer appears to be arguing that plants that are "similar" to plants that make large parts have 

demonstrated capture and control. Instead, EPA seems to contend that such facihties can make 

capture and control work even if they have not done so already. If this is indeed EPA's position, 

EPA is arguing that capture and control for these facihties can be justified as an "above-the-floor" 

requirement even if it cannot be justified as a "floor" requirement. That is a completely different 

theory of new source MACT from any advanced before in this rulemaking. Our comments would 

have addressed this new line of reasoning had it been explained in the proposed rule. 

We have done our best to respond to what we understand to be EPA's new position. However, the 

law requires an agency that changes its position so fundamentally to issue a supplemental 

proposal and invite a new round of public comment. Informal comments based on undeveloped 

understandings ofthe agency's evolving position are no substitute for the government's 

compliance with this basic requirement. 

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Attachment 3 

Comparison ofthe Characteristics ofthe A.R.E. Massillon Plant and Proform LLC West 

Memphis Plant that affect Capture of Emissions prepared by Dr. Robert Haberlein 

i( 
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ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Comparison of the Characteristics of the A.R.E. Massillon Plant and 

the Proform LLC West Memphis Plant that affect Capture of Emissions 

July 26, 2002 

EPA has proposed that all new open molding facilities with HAP emissions over 100 tpy must 

achieve the same level of capture & control as the A.R.E. Massillon facility, which according to the 

MACT database prepared by EPA, has a 95% effective capture-and-control system. 

EPA believes that this level of control is achievable for all types of open molding facilities, 

including plants that produce large parts. CFA asked Engineering Environmental Consulting 

Services (EECS) to evaluate this claim by comparing the A.R.E. Massillon facility, henceforth called 

the "Massillon plant," to a typical new plant designed to produce large parts. For the purpose of this 

evaluation, the Proform Company LLC plant in West Memphis, Arkansas, henceforth called the 

"Proform plant," is a good example of a typical new large facility (more than 100 tpy) that produces 

large parts. The Proform plant produces barge covers, underground storage tanks (UST), and 

chemical storage tanks. The Proform plant is also a good choice, because EPA recently visited the 

Proform plant site in January 2002. During this visit, EPA received detailed design data from 

Proform and observed firsthand the many technical problems posed by the fabrication of large parts. 

Several characteristics ofthe Massillon plant and the Proform plant are compared in Table 1 on the 

next eleven pages. These characteristics illustrate fundamental technical differences between those 

plants that produce small parts and those plants that produce large parts. The key characteristics 

include: 

Part and mold size 

Process complexity 

Process area required 

Process HAP emission rates 

Ventilation requirements 

Employee exposure 

Enclosure type and size 

Enclosure openings 

Method 204 compliance 

Page 1 of 13 I 2^ 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Table 1 - Comparison ofthe Characteristics at the Massillon and Proform Plants that affect Capture of HAP Emissions 

W) 

Cl^raeteri^e 

Part* 

produced 

' 

l&rtsii&es 

- ' \ 

^ _, ff •* : 

: ",r , _ \ 

• / ' ' ' ' /

 / ' '• 

, ' j. S ' * S fff f '•_ 

: -* ' , , f f f_ 

\ '"" ''A " ">> \ 

KM&* MmMm 

Truck top 

Non-corrosion resin and pigmented gelcoat 

(probably Manual and Mechanical application) 

Truck top 

6'Wx 8'Lx 3'H-typical part 

Proform West Memphis 

Barge cover 

Non-corrosion resin and pigmented gelcoat 

Manual and Mechanical Non-atomized application 

Special impregnator and overhead platforms 

Underground storage tank (UST) 

Corrosion resistant resin 

Manual and Mechanical Non-atomized application 

Special large rotating mold fixtures 

Vertical tank 

Corrosion resistant resin 

Manual, Mechanical Non-atomized and 

Filament Wind application 

Barge cover 

24' Wx 30' Lx 4'/2' H - typical 

26'Wx 31'Lx Mm - max 

29'Wx36'L x 8' H - max Barge cover mold 

UST 

10' diax 48'L - typical 

10' dia x 74' L or 12' dia x 68' L - max 

Vertical tank 

10' diax 40'L - typical 

12' diax 60'L - max 

The parts produced at Proform are many times larger than the relatively small truck top parts produced at Massillon.. 

For example, the part "box volume" (WxL x H) of a typi 

4% of a typical Barge Cover part at Proform 

4% of a typical UST part 

4% of a typical Vertical tank 

cal truck top part is only: 

Page 2 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

- ^ 

Characteristic 

Process 

descriptions 

A,IUL Massillon 

Truck top 

The truck top parts are produced on a continuous 

production line that employs wheeled molds that are 

manually pushed along a track. The line reportedly has 

six process steps: 

1. gelcoat application in a gelcoat booth 

2. gelcoat curing in a gelcoat cure tunnel . 

3. laminate application in a Glassroom booth 

4. laminate curing in a resin cure tunnel 

5. gelcoat application to the inside ofthe laminate 

6. inside gelcoat curing in a gelcoat cure tunnel 

The cured truck top parts are removed from the molds 

and then exit the Lamination Room through a separate 

exit tunnel attached to the room. 

The truck part is then prepared for paint application in a 

separate room area, the prepped part is moved into one of 

four paint spray booths, and paint is applied and allowed 

to cure while remaining inside the booth. 

Proform West Merophis 

Barge cover 

1. gelcoat application - two stations using a special 

overhead crane-mounted work platform 

2. gelcoat curing - one station 

3. laminate applications (several) - two stations using a 

special overhead crane-mounted impregnator device 

4. laminate curing - one station 

UST 

Fixed work stations - four special rotating molds fixtures 

1. laminate applications (several) 

2. spacer installations (for double-wall tank) 

3. laminate curing inside mold 

4. tank section pulled from mold 

5. tank sections assembled into final part on shop floor 

Vertical tank 

1. laminate applications (several) - on shop floor 

2. filament wind (several layers) - filament creels 

3. laminate curing - on shop floor 

4. tank section pulled from mold 

5. tank sections/parts assembled 

Due to the size and complexity ofthe large parts, the lamination operations at Proform are intermittent instead of 

continuous. The great mass and multiple laminate layers ofthe large parts at Proform require the workers to start and 

stop lamination activities several times. Each laminate layer must cure before the next layer is added. Shell 

separation parts and other reinforcements must be inserted between some of these layers, and the workers must take 

frequent work breaks. A typical large part must remain in its mold for six to ten hours from start to finish. The 

ventilation fans must operate during the entire process. Due to these technical factors, the smaller process enclosures 

employed at Massillon are not practical for the large parts made at Proform. 

Page 3 of 13 

TJ 

oi 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Characteristic 

Process areas j 

\.,',,'Sy".,y ' , '\ ' i 

AJUL Massillon 

Only part ofthe floor area and volume inside the 

Lamination Room is used to enclose the actual lamination 

processes. The following partial enclosures are 

reportedly contained inside the room: 

Gelcoat Booth: 19' W x 25' L x 9V*' H 

Gelcoat Cure Tunnel: 11' W x 79' L x 83/4' H 

Glassroom Booth: 28'Wx68'L x 83/4'H 

Resin Cure Tunnel: 10' W x 79' L x 83/4' H 

Inside Gelcoat Booth: 19' W x 25' L x 9%' H 

Gelcoat Cure Tunnel: 11' W x 79' L x 83/4' H 

Total process floor area - 5,380 ft2 process 

Total process volume - 47,570 ft3 process 

The remaining non-enclosed floor area (about 5,770 ft2) 

and volume (about 231,200 ft3) inside the Lamination 

Room is used to contain the spaces between the open 

booths and tunnels, and to provide worker and mold 

access. Note that the entire Lamination Room measures: 

68'Wxl64'Lx25' H 

Xxoform WfeSt Memphis 

Barge cover 

Gelcoat - 50' W x 165' L x 24' H 

Resin-50'Wxl65'Lx24' H 

(10,000 ft2 ofthe gelcoat and resin area is 40'H) 

Small parts - 40' W x 100' L x 24' H 

Barge cover process floor area - 20,500 ft2 

Barge cover process volume - 652,000 ft3 

UST 

Four UST molding stations - 85' W x 180' L x 24' H 

UST process floor area - 15,300 ft2 

UST process volume - 367,200 ft3 

Vertical tank (planned) 

85'Wxl80'Lx40' H 

Vertical tank process floor area - 15,300ft2 

Vertical tank process volume - 612,000 ft3 

The combined enclosed process floor area inside the Lamination Room at Massillon is only about: 

26% ofthe process floor areas for the Barge Cover operation at Proform 

15% ofthe process floor areas for the Barge Cover & UST operations 

11% ofthe process floor areas for the entire "large-part" operation (as planned) 

The combined enclosed process volume inside the Lamination Room at Massillon is only about: 

7% ofthe process volume for the Barge Cover operation at Proform 

5% of the process volume for the Barge Cover & UST operations 

3% ofthe process volume for the entire "large-part" operation (as planned) 

Page 4 of 13 

TJ 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

^ 

Characteristic 

Process HAP • 

emissions 

(PT1> 

AMM* Massillon 

Truck top 

Lamination - HAP (styrene) 525 tpy 

Painting- non-HAP VOC 500 tpy 

Total PTE (paint VOC & HAP) - 1,025 tpy 

Proform West Memphis 

Barge cover - EHAP (styrene) 58 tpy 

UST - HAP (styrene) 107 tpy 

Vertical tank - EHAP (styrene) 84 tpy 

Total PTE (HAP) - 249 tpy 

About 48% ofthe controlled emissions at Massillon are emitted from a painting operation that is not subject to the 

composites MACT and is relatively easy to capture in smaller commercial paint booths. 

Note that the UST operation is the only individual activity at Proform with a potential to emit (PTE) HAP that would 

be considered a large (greater than 100 tpy) operation, and only by a 7 tpy margin. By comparison, the lamination 

operation at ARE. Massillon, by itself, has a PTE that is more than five times greater than the large-plant threshold set 

by EPA. When combined with the painting emissions, the controlled PTE is more than 10 times greater than this 

threshold. This difference in PTE demonstrates two important consequences of part size: 

1. "Large" plants that produces small parts typically employ automated or semi-automated production lines. These 

production lines have high production throughputs contained inside much smaller floor areas and process volumes. 

The process emissions from these inherently more "compact" small-part operations can be captured in small process 

enclosures. This describes practically every composite facility that currently attempts plant-wide capture & control. 

2. Plants that produce large parts require much larger process floor areas and volumes in order to create enough 

production throughputs to reach the 100 tpy "new source" capture & control threshold. For example, even if the 

Lamination Room at ARE Massillon were capable of producing a barge cover part (which is not technically possible 

in its current configuration), the production throughput would be much less and the small amount of HAP emissions 

created in this hypothetical situation (perhaps 20 tpy or less) would not be sufficient to trigger new source MACT. 

For such a comparison to be accurate and useful, all three large parts produced at Proform (barge cover, UST, and 

Vertical tanks) must be built in the Lamination Room at Massillon, which is not technically possible. 

Page 5 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Characteristic A JUL Massgloii Proform West Memphis 

N j 

Ventilation 

-y, 

A f '. 

Truck top 

94,500 to 99,200 cfin from source test data 

nominal 100,000 cfm exhaust airflow control capacity 

50,000 cfm from the four paint spray booths 

(this exhaust airflow captures paint solvents, not HAP) 

50,000 cfm from the Lamination Room 

(this part ofthe exhaust captures the styrene HAP) 

Based upon the available information, the ventilation 

system at Massillon appears to work as follows -

A substantial part (perhaps more than 85%) ofthe process 

emissions are captured inside small open-ended "passthrough" type process enclosures erected around most of 

the production line in the Lamination Room (see previous 

Enclosure Descriptions). The small amount of emissions 

that escape from or are released outside of these small 

process enclosures, probably diffuse into the Lamination 

Room air, and then are eventually drawn back into the 

exhaust stream through the open ends ofthe booth and 

tunnel enclosures. 

Barge cover - 88,000 cfm 

Three large push-pull crossflow area ventilation systems 

installed by Frees Inc! direct fresh air from supply 

plenums across the mold surface to exhaust plenums. 

Some ofthe process emissions are swept into this 

directed airflow, but a significant amount is released into 

the building space. Some of these building emissions are 

drawn back into the exhaust, but some are also lost 

through leaks in the building envelope and through open 

exterior doors. 

UST - 52,000 cfm 

An extraction duct draws building air into each open 

mold. This inward airflow captures and exhausts most of 

the process emissions inside the mold space. The 

assembly emissions are released in the UST building 

space and are eventually drawn into the molds or lost 

when the building doors are opened. 

Vertical tank (planned) - 52,000 cfm 

Local exhaust plenums positioned near the vertical mold 

mandrel will capture and exhaust a portion ofthe process 

emissions from these large parts. The other portion will 

be released into the building space, and will eventually be 

drawn back into the exhaust or will escape when the 

building doors are opened. 

Plants that produce large parts inside building enclosures typical rely upon push-pull area ventilation systems to 

control worker exposure to styrene vapor. These large push-pull systems are fundamentally different in both design 

and operation than small process enclosures such as spray booths and cure tunnels. The capture of emissions is not 

the main purpose of a large push-pull system, and these systems cannot achieve the high capture efficiencies that are 

possible with smaller process enclosures. Large push-pull systems also require greater airflows. For example, the 

50,000 cfm exhaust airflow at Massillon is only 28% ofthe 190,000 cfm plant-wide exhaust airflow (final) at 

Proform 

Page 6 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

o ^ 

: Characteristic 

Employee 

exposure 

A.E JJ* MassHIow 

Truck top 

The exact status of employee exposure at Massillon has 

not been revealed. 

However, in general, positioning the workers upstream 

near the supply-side ofthe each booth can readily 

minimize occupational exposure inside small-part 

production lines. For example, the "gun" operators can 

stand in the fresh supply airflow and spray across the 

mold towards the exhaust inlets. This technique is 

probably utilized at Massillon. 

Proform West Memphis 

Barge cover 

Due to the large size ofthe part, employees must 

routinely work all around and even on the part, including 

several "high exposure" areas near the downstream 

exhaust inlets. The present ventilation system is just 

barely able to meet the OSHA PEL and STEL for styrene. 

Any reduction in ventilation airflow or increase in 

confinement would likely cause the exposure levels to 

exceed the PEL or STEL and then require the use of 

personal respirators. 

UST 

Personal respirators are not needed inside the rotating 

UST molds or in the UST assembly areas. 

Vertical tank 

Due to the large size, outer mandrel molding surface, and 

extra filament winding equipment, the vertical tank 

operation also will need a push-pull ventilation system 

similar to the barge cover system to control exposures. 

It is more difficult to predict and control occupational exposures around large parts, and push-pull area ventilation is 

typically used. . A push-pull area ventilation system is designed to provide a directed flow of minimal ventilation air 

that conveys the styrene vapors generated in the work zone from the supply side towards the exhaust side ofthe 

ventilated area. Push-pull area ventilation systems are primary designed to protect workers against overexposure to 

styrene vapors, and are not intended to be efficient capture systems. The "push" air leaving the supply registers 

usually entrains a sigmficant amount ofthe nearby ambient building air as it travels across the work zone. Due to this 

entrainment, the flow of air moving across the work zone towards the exhaust side is greater than the flow from the 

supply registers. In many installations, a significant portion of this moving air can spill pass the exhaust inlets and 

recirculate back towards the supply registers. Most of this recirculating air is then re-entrained into the air flowing 

across the work zone, but a portion may escape into the general building space. The only way to prevent this escape 

to the building space would be to place the entire push-pull system inside a process enclosure. Due to the large area 

and volume, the only practical type of enclosure is a Building Enclosure. 

Page 7 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Characteristic A.R.E. Massillon Proform West Memphis 

Enclosure 

descriptions 

-fc 

Truck top 

The laminate production line is enclosed within a row of 

spray booths and curing tunnels that have open ends. 

These booths and tunnels are housed inside a room 

enclosure in the plant building. The exterior building 

roof forms the room ceiling and the exterior building wall 

forms one ofthe room walls. Neither the ceiling nor the 

exterior wall has any outside openings. All ofthe NDOs 

are between the room and the inside ofthe Massillon 

plant building. 

The spray painting occurs inside small automotive spray 

finishing booths, which are also completely inside the 

plant building. 

Barge cover 

Due to the large size ofthe molds and presence of 

overhead impregnator equipment and cranes, barge cover 

production must occur inside a Building Enclosure 

Smaller process enclosures, such as spray booths, which 

have much higher achievable capture efficiencies, cannot 

be used. 

UST 

Due to the large size ofthe rotating mold fixture, space 

for access to the rotating equipment, and the need to 

assembly large sections together into very large finished 

tank parts, UST production must occur inside a Building 

Enclosure instead of smaller process enclosures 

Vertical tank (planned for future production) 

Due to the large size ofthe molds and space needed for 

the associated filament wind equipment, Vertical tank 

production will occur inside a Building Enclosure(instead 

of a spray booth enclosure with much higher achievable 

capture efficiency). 

The three types of large parts made at Proform must be built inside Building Enclosures, instead of smaller process 

enclosure that have much higher achievable capture efficiencies. 

Page 8 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

. Characteristic 

-

Enclosure 

(liraeasteas 

-

' 

: 

A.R.E. Massdlon 

The Lamination Room "total-enclosure" at Massillon 

measures: 

68'Wxl64'Lx25' H 

(11,200 ft2 and 278,800 ft3) 

PrOforai West Memphis 

Barge cover 

The Building Enclosure for the Barge Cover operation 

measures: 

140'Wx 266'Lx 24'H 

10,000 ft2 of this enclosure has a 40' H ceiling 

(37,200 ft2 and 1,052,800 ft3) 

UST 

The Building Enclosure forthe UST operation measures: 

85'Wx 180'Lx 24'H 

(15,300 ft2 and 367,200 ft3) 

Vertical tank 

The Building Enclosure for the planned Vertical tank 

operation measures: 

100'Wxl80'L x 40'H 

(18,000 ft2 and 720,000 ft3) 

Due chiefly to the difference in part sizes, the "small-part" Lamination Room enclosure at Massillon is only about: 

30% ofthe Building Enclosure for the Barge Cover operation at Proform 

21% ofthe Building Enclosures for the Barge Cover & UST operations 

16% ofthe Building Enclosures for the entire "large-part" operation (planned) 

Even more significant, the volume ofthe Lamination Room "total enclosure" at Massillon is only about: 

26% ofthe Building Enclosure volume for the Barge Cover operation at Proform 

20% ofthe Building Enclosure volume for the Barge Cover & UST operations 

13% ofthe Building Enclosure volume for the entire "large-part" operation (planned) 

Page 9 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Characteristic AJU&*. Massilfon Proform West Memphis 

< 

Barge cover - (1,376 fr open area) 

Two overhead doors that measure 28' W x 16' H 

Two overhead doors that measure 20' W x 12' H 

UST - (560 ft2 open area) 

Two overhead doors that measure 20' W x 14' H 

Vertical tank - (560 ft2 open area) 

Two overhead doors that measure 20' W x 14' H 

^ 

Enclosure 

openings 

•/, „«''.'.','/ / 

-„i'„/„„,',">,• 

Truck top 

The only "official" natural draft openings (NDOs) are 

four (4) 2' x 10' openings in one indoor wall ofthe 

Lamination Room for a total of 40 ft2 of open area. 

The room enclosure at Massillon does not have any exterior building doors. Presumably, all ofthe materials, 

component parts, and molds needed to operate a work shift can be housed inside the room enclosure. Theoretically, a 

small truck part only requires a ENDO opening of about 7' x 4' = 28 ft2 to exit the room enclosure. 

The large parts and large molds at Proform require commensurately larger door openings that must remain open for 

longer periods of time to allow for the passage ofthe large parts and molds. For example, the reported 40 ft of ENDO 

in the Lamination Room at Massillon are only about: 

3 % ofthe open door area for the Barge Cover operation at Proform (1,376 ft2) 

2 % of the open door area for the Barge Cover and UST operations (1,936 ft2) 

1.6 % ofthe open door for the entire "large-part" operation (2,496 ft2) 

The amount of exhaust airflow needed to create an average 200 fpm inward air velocity or -0.007 in.w.g pressure 

differential (as required to meet Method 204) through the outside doors at Proform is 500,000 cfm. If only half of 

these doors are open, about 250,000 cfm of extra airflow is needed. At a minimum, two doors are probably open at 

any one time, so at least 112,000 cfm of extra airflow is needed for the smallest doors. The total air flow needed to 

meet the Method 204 criteria at Proform, assuming only two large doors are open at a time, would be about 370,000 

cfm (190,000 cfm for the push-pull systems and 180,000 through the two large doors), as compared to the total 

exhaust air flow of 100,000 cfm employed at the ARE lamination room This assumes no wind. 

Page 10 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

•y 

E Characteristic 

Method 204 

A.R.E. Massillon 

Truck top 

The spray booths and curing tunnels inside the 

Lamination Room do not meet the Method 204 criteria. 

Instead, the room that contains these enclosures is 

designed to provide a means of compliance with Method 

204. 

The local state inspectors apparently waived the "closeddoor" criteria in Method 204 for at least two other larger 

8' x 10' doors during the testing at Massillon. This 

willingness to waive criteria may not reoccur at other new 

plant sites. 

All ofthe enclosure openings at Massillon, including the 

larger doors, open into the plant building space, and are 

therefore not directly affected by wind pressure. If these 

openings were in exterior walls, wind conditions could 

cause the airflow through these openings to reverse and 

flow out ofthe building. 

Proform West Memphis 

Barge cover 

The Barge cover operation must use a Building 

Enclosure (instead of smaller process enclosures with 

much higher achievable capture efficiency) that cannot 

meet the "closed door" criteria in method 204, and 

cannot maintain adequate negative pressure across 

leaking or open doors due to the influence of wind 

pressure. 

UST 

The UST operation also must use a Building 

Enclosure, because the rotating mold cannot meet four 

ofthe five Method 204 criteria. Further, the mold size, 

rotating mold design, and mold access requirements 

preclude the use of a smaller booth or room enclosure. 

The final assembly of tank sections into finished parts 

also requires a very large area. The necessary 

Building Enclosure cannot meet the "closed door" 

criteria for Method 204, and cannot maintain adequate 

negative pressure across leaking or open doors due to 

influence of wind pressure. 

Vertical tank 

The Vertical tank operation also will need a Building 

Enclosure. The mold mandrel size, worker access, and 

extra space for filament winding equipment preclude 

the use of a smaller booth or room enclosure. This 

Building Enclosure also will fail to meet the "closed 

door" criteria. 

Page 11 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

Characteristic A,BJL Massillon Proform West Memphis 

When the wind is blowing, open exterior doors become an insurmountable problem at Proform. Unlike the ENDOs and 

room doors at Massillon, the building doors at Proform must open to the outside atmosphere and therefore cannot 

resist the effect of wind pressure with mechanical ventilation. For example, according to ASHRAE, a typical 

rectangular building such as Proform has a wind velocity pressure coefficient value ranging from +0.50 to +0.80 

along the windward wall, -0.14 to -0.43 along the leeward wall, and -0.6 to -0.2 along the sidewalls parallel to the 

wind. For a 15 mph wind, the wind velocity pressure would be 0.109 in.w.g. and the wind pressure across an opening 

in the side or leeward walls could be as much as -0.065 in.w.g.. In order to meet the alternate -0.007 in.w.g. pressure 

differential criteria in Method 204, the building volume must be negatively pressurized to at least 0.007 + 0.065 = 

0.072 in.w.g. by the exhaust fan. The wall pressure along the windward building wall could be as great as -0.072 -

0.087 = + 0.159 in.w.g.. This presents Proform with two technical problems: 

1. Assuming that only side or leeward doors are opened, the minimum negative pressure throughout the building 

must be -0.072 in.w.g. to achieve the alternate -0.007 in.w.g. pressure differential criteria cited in Method 204. 

Unfortunately such negative building pressurization would translate into a +0.159 in.w.g. pressure differential across 

the windward wall and a corresponding 23 pound load on a typical leeward man-door (4 x 7 = 28 ft ). At this 

pressure, an outward-opening door is difficult to open for some workers, and an inward-opening door could be 

physical hazard as it flew open. However, the pressure of wind increases as the square ofthe wind speed, so a 30 mph 

wind speed has four times the effect on building pressurization. At 30 mph, the necessary minimum building 

pressurization becomes +0.617 in. w.g. and the force on a windward man-door becomes 89 pounds. The same 

windward door is now very difficult or even impossible to open outward for some workers and an inward door is a 

true danger. Even greater wind speeds than 30 mph will occur, causing even greater impacts than calculated above. 

2. When a large windward and a large leeward door are simultaneously opened, the building enclosure becomes a 

"wind tunnel" and mechanical ventilation can no longer contain all ofthe process emissions inside the building space. 

The building space is positively pressurized by the wind flowing into the building through the windward opening, 

causing the negative building pressure to become more positive. The exhaust fan can no longer provide sufficient 

negative pressure to maintain inward airflow through open side or leeward doors, and significant portions ofthe 

process emissions are lost through these door openings 

Page 12 of 13 
ENGINEERING ENVIRONMENTAL 

CONSULTING SERVICES 

Robert A. Haberlein, Ph.D., QEP 

In conclusion: 

The Proform plant, or any plant built to make large parts, cannot employ the same capture & 

control strategies that are used at the Massillon plant due to several fundamental technical 

difficulties posed by large-sized parts and molds. 

The large Building Enclosures needed to house the large-part operations at Proform are 

fundamentally different in both design and operation than the smaller process enclosures and 

room enclosure at Massillon. 

None ofthe large-part operations at Proform could fit into the room enclosure at Massillon. The 

room enclosure at Massillon would need to be several times larger in both floor area and volume 

to house the Proform operation. 

The large parts made at Proform require many complex lamination steps with correspondingly 

long production times. Some ofthe parts at Proform may stay in the mold for over ten hours. 

The complexity and time need to produce these large parts result in much larger process areas to 

achieve sufficient production throughput. Extra process space is needed to generate enough 

production throughput to become a "large operation." However, by virtue of size and associated 

production line efficiency, the small parts at Massillon are quickly produced in a compact 

process area, which results in high production throughput in a small space. These "small-part" 

circumstances are ideal for capture & control. 

The large parts at Proform also need special large molding equipment, such as the cranemounted impregnator, overhead work platforms, large rotating mold fixtures, and overhead 

cranes. This equipment requires additional workspace. By virtue of size, the small parts at 

Massillon do not require this extra equipment or workspace. 

The Proform plant must regularly open, and keep open for extended periods, several large 

exterior building doors to move materials, molds, and parts in and out ofthe process areas during 

production periods. The impact of wind pressure on these open exterior building doors makes it 

technically impossible to comply with Method 204. The room enclosure at Massillon does not 

have any exterior doors, and is not impacted by the wind. 

The Proform plant must use large push-pull crossflow area ventilation systems to control worker 

exposure to styrene vapor. This type of large open ventilation system has inherently lower 

capture efficiency. By virtue ofthe size ofthe truck top parts, Massillon is able to use smaller 

and tighter process enclosures that are housed inside a room enclosure with only 40 ft2 of NDO. 

The capture strategy used at Massillon is not practical for Proform. 

The Proform plant, or, again, any plant designed to make large parts using Building Enclosures, 

cannot meet Method 204. 

Robert A. Haberlein, Ph.D., QEP 

Engineering Environmental 

Page 13 of 13 ^ Y