p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

60) IV-C-33 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 60 of 273 
P.2 

REINFORCED PLASTIC 

COMPOSITES 

MACT STANDARDS 

DEVELOPMENT UPDATE 

A-94-52 

IV-C-33 

FPA AIR DOl W 

For the Composites Fabricators Association Annual Meeting 

September 26, 2002 

Keith Barnett, Project Lead 

Office of Air Quality Planning and Standards 

Emission Standards Division 

Minerals and Inorganic Chemicals Group 
P.3 

Outline 

Who is subject to this standard? 

What operations are covered? 

What if I manufacture fiberglass boats or 

boat parts? 

When do I have to comply? 

Major changes to proposed rule 

Am I a new or existing source? 

What standards must I meet? 

What are some of my options to meet 

standards? 

How do I calculate emission factors? 

How do I demonstrate initial compliance? 
P.4 

Who is subject to this standard? 

• You are subject to this standard if 

you: 

- Manufacture reinforced plastics 

composites at a facility that is located at 

a major source (10 tpy ofany one HAP 

or 25 tpy ofany combination of HAP): 

and 

- Use thermoset resins or gel coats that 

contain styrene 

• You are not subject to this standard 

if you: 

- Use less than 1.2 tpy of styrene 

containing resins and gel coats, or 

- Only perform research and 

development, or 

- Only repair reinforced plastic 

composites 
P.5 

What operations are covered and 

have some type of control 

requirements? 

Open Molding 

Closed Molding 

Centrifugal Casting 

Continuous Lamination/Casting 

SMC/BMC Manufacturing 

Pultrusion 

Mixing 

Storage 

Equipment Cleaning 
P.6 

What operations are covered, 

and have no requirements? 

Application, of mold sealing and release 

agents 

Mold stripping and cleaning 

Repair unrelated to your manufacturing 

operations 

Materials that do not contain resin or gel 

coat 

Personal activities not part of 

manufacturing operations 

Prepreg materials 

Non-gel coat surface coatings 

Research and development operations 
P.7 

What if I Manufacture Fiberglass 

Boats or Boat Parts? 

You are subject to the Boat Manufacturing 

NESHAP onlv if you manufacture boat 

hulls or decks, or molds for boat hulls or 

decks 

If you are not subject to the Boat 

Manufacturing NESHAP, you are subject 

to this rule 

If you are subject to the Boat 

Manufacturing NESHAP, but make parts 

that are not part of your boats, the non-boat 

operations are subject to this rule 

You may elect to place all operations under 

the Boat Manufacturing NESHAP if that 

results in equal or lower HAP emissions 
P.8 

When do I have to comply? 

Proposal was August 2, 2001 

Final rule publication date is part of 10 

year MACT settlement negotiations 

Existing major sources must comply within 

3 years 

New major sources must comply by 

effective date of final rule or startup, 

whichever is later 
P.9 

Major Changes to Proposed Rule 

The above-the-floor requirements have 

been dropped for existing open molding, 

pultrusion, SMC and BMC manufacturing, 

and mixing operations 

The point value equations have been 

replaced with the appropriate unified 

emission factor (UEF) equations 

We have revised existing source MACT 

floors based on comments received on the 

proposed rule 

- Two floors will require a slightly lower 

HAP content, three are slightly higher 

- We have combined the filled and 

unfilled noncorrosion resistant 

mechanical resin application operations 

types 
P.10 

What is a new Source? 

You commenced construction after 

August 2, 2001; and 

When you commenced construction, there 

were no reinforced plastic composites 

operations at the facility 

Note that the definition above includes 

moving an existing facility (We are 

overriding the General Provisions 

concerning moving sources) 
p.11 

What is an Existing Source? 

Any source that is not new 

Existing sources are not considered new as 

a result of reconstruction 

10 
P.12 

Overview of Controls to Meet 

Emission Limits 

Most existing sources must only 

meet the existing source floor 

- low HAP resins and gel coats 

- nonatomized application techniques 

- covering open containers, mixers, resin 

baths 

- add-on controls for continuous 

lamination/casting 

Existing sources with centrifugal 

casting and continuous 

lamination/casting operations that 

emit over 100 tpy of HAP must 

- Use add-on controls for both centrifugal 

casting and continuous 

lamination/casting (95 percent control) 

- Meet the same requirements as other 

existing sources for their other 

operations 

n 
P.13 

Overview of Controls to Meet 

Emission Limits (Con't) 

New sources with HAP emissions below 

the 100 tpy threshold meet the same limits 

as existing sources 

New sources at or above the 100 tpy 

threshold must control the operations 

below by 95 percent 

- OpenMolding 

- Centrifugal Casting 

- Continuous Lamination/Casting 

- Pultrusion 

- SMC/BMC Manufacturing 

- Mixing 

12 
P.14 

What is the 100 tpy HAP 

Emission Threshold and How Is 

It Determined? 

Sum emissions from the all operations 

potentially subject to 95 percent control 

prior to any add-on controls 

Calculate these emissions using 

- Unified emission factors 

- Other published emission factors 

- Site specific factors if based on 

emission test data 

13 

/A/P 
P.15 

Draft MACT for AU Sources 

Below Thresholds 

Operation 

Type 

Open 

Molding -

Corrosion 

Resistant 

and/or High 

Strength 

(CR/HS) 

Open 

Molding -

Non-CR/HS 

Open 

Molding -

Shrinkage 

Controlled 

Resins 

Specific 

Operation 

Mechanical resin 

Application 

Filament 

Application 

Manual Resin 

Application 

Mechanical resin 

Application (Filled 

or unfilled) 

Filament 

Application 

Manual resin 

Application 

Mechanical resin 

Application 

Filament 

Application 

Manual Resin 

Application 

Emission 

Limit 

(Ib/ton) 

112 

171 

123 

87 

188 

87 

354 

215 

180 

Allowable 

Resin HAP 

Content 

46.2 NonAtomized 

42 

40 

38.4 NonAtomized 

45 

33.6 

50 

Atomized 

50 

50 

14 
P.16 

Draft MACT for All Sources 

Below Thresholds (Con't) 

Operation 

Type 

Open 

Molding -

Tooling 

Open 

Molding -

Low Flame 

Spread/Low 

Smoke 

Products 

Centrifugal 

Casting 

Specific 

Operation 

Mechanical 

Resin 

Application 

Manual Resin 

Application 

Mechanical 

resin 

Application 

Filament 

Winding 

Manual Resin 

Application 

Non-CR/HS 

CR/HS 

Emission 

Limit 

(Ib/ton) 

254 

157 

497 

270 

238 

20 

25 

Allowable HAP 

Content 

(Weight %) 

50+ Nonatomized 

43 Atomized 

45.9 

60 

60 

60 

37.5 

48 

15 
P.17 

Draft MACT for All Sources 

Below Thresholds (Con't) 

Operation 

Type 

Open 

Molding -

Gel Coat 

Specific 

Operation 

Tooling Gel 

Coating 

Pigmented Gel 

Coating - White 

and Off White 

Pigmented Gel 

Coating -

NonWhite 

Clear Production 

Gel Coating 

CR/HS or High 

Performance Gel 

Coating 

Fire Retardant 

Gel Coating 

Emission 

Limit 

(Ib/ton) 

437 

267 

377 

522 

605 

854 

Allowable 

HAP Content 

(Weight %) 

40 

30 

37 

44 

48 

60 

16 
P.18 

Draft MACT for All Sources 

Below Thresholds (Con't) 

Injection/Compression Molding - Cover 

Charges 

Resin Transfer Molding - No 

Requirements 

Continuous Lamination and Casting - 58.5 

percent control 

Polymer Casting - No Requirements 

17 
P.19 

Draft MACT for All Sources 

Below Thresholds (Con't) 

Pultrusion - 60 percent control or wet area 

enclosure (except for large parts) 

Sheet Molding Compound - Nyloncontaining film, cover resin delivery to 

doctor box 

Equipment Cleaning - Cleaning materials 

may contain no HAP (except for closed 

systems) 

Resin Mixing and BMC Manufacturing -

Cover the mixers 

Resin Storage - Cover storage containers 

18 
P.20 

Draft MACT for Existing Sources 

at or above the 100 tpy Threshold 

For existing sources that emit 100 tpy or 

more of HAP combined from 

- Centrifugal Casting 

- Continuous Lamination/Casting 

The requirements are 95 percent control of 

the operations listed above 

The requirements for all other operations 

are the same as facilities below the 

threshold 

19 

/ cn 
P.21 

Draft MACT for New Sources at 

or above the 100 tpy Threshold 

• For new sources that emit 100 tpy or more 

of HAP from 

- OpenMolding 

- Centrifugal casting 

- Continuous lamination/casting 

- Pultrusion 

- SMC/BMC Manufacturing 

- Mixing 

The new source MACT is 95 percent 

control ofthe operations listed above 

Operations not listed above must meet the 

same requirements as existing sources 

20 
P.22 

Options to Meet Standards 

Open Molding and Centrifugal 

Casting 

You may average open molding 

operations, and separately average 

centrifugal casting operations (12-month 

rolling average) 

All operations of a specific resin type (CR, 

Non-CR, and Tooling) may use the same 

HAP content resin 

Operations subject to 95 percent control 

have alternative point value limits 

You may change compliance options 

21 
P.23 

Options for Meeting Standards 

Pultrusion 

Wet area enclosures, preform injection, or 

direct die injection to meet the 60 percent 

reduction requirement 

You may average across different 

machines for both percent reduction and 

times that covers or doors are open 

For averaging purposes, direct die injection 

and preform injection are assumed to 

achieve a 90 percent HAP emission 

reduction 

22 
P.24 

Options for Meeting Standards 

Continuous Lamination/Casting 

Can average lines 

Existing sources can elect to control only 

wet out area emissions by 95 percent 

Can meet an alternative emission limit of 

14.7 lb/ton (58.5 percent control level) or 

1.47 lb/ton (95 percent control level) 

23 
P.25 

How do I Calculate Emission 

Factors? 

Equations are presented in the rule, and are 

identical to current unified emission factors 

published by the CFA. 

Resin use may be based on purchase 

records if you can reasonably estimate how 

the resin is applied 

Resin HAP content may be based on 

MSDS or resin specification sheets 

Emissions are based on organic HAP 

content 

We have added provisions for normal 

manufacturing tolerances 

24 
P.26 

How do I demonstrate Initial 

Compliance? 

If you are using add-on controls, you must 

perform a compliance test prior to the 

compliance date 

Performance tests methods are EPA 

Method 18, 25, 25A 

The PTE must be certified using EPA 

Method 204 

If the PTE does not meet 204 criteria, you 

must test for capture using EPA Methods 

204B-204E 

25 
P.27 

How do I demonstrate Initial 

Compliance (Con't)? 

For emission limits - perform emission 

factor calculations as specified in the rule 

For work practice standards - submit a 

certified statement that the work practice is 

being performed 

For equipment standards - submit a 

certified statement that the equipment is in 

place and meet the requirements specified 

in the rule 

26 
P.28 

How Do I Demonstrate Initial 

Compliance for a PTE? 

Determine the equivalent diameters of all 

NDO and exhausts 

Determine the equivalent diameters of all 

NDO from HAP emission points and 

exhausts from NDO (must be at least four) 

Measure PTE surface area (AT) and NDO 

surface area (AN). The ratio of AT/AN 

must 0.05 or less. 

27 
P.29 

How Do I Demonstrate Initial 

Compliance for a PTE (Con't)? 

- Measure all exhaust flows (Q0) and all 

forced makeup air flows (Qj) using 

EPA Method 2. 

- Calculate the average NDO facial 

velocity as FV= (Q0 - QT)/AN 

- FV must be 200 fpm or more; or 

- measure pressure differential across 

enclosure 

- differential must be 0.007 inches of 

water or more 

28 
P.30 

How Do I Demonstrate Initial 

Compliance for a PTE (Con't)? 

Verify direction of flow is inward for 

all NDO using streamers, smoke tubes, 

or tracer gases 

If FV is 500 or more, inward flow 

verification is not required 

29