p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

55) IV-C-28 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 55 of 273 
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A-94-52 

IV-C-28 

Keith Barnett 

05/06/2002 01:34 PM 

To: jbarker@strongwell.com 

cc: jschwtzr@gte.net 

Subject: Preform Injection Data Summary 

Dear John: 

The attached file is a summary of the preform injection emission test data. One issue we need to 

address is what is the correct uncontrolled emission number. If we are going to make a case that 

preform injection is equivalent (more or less) to 95 percent control, we need to be sure we are using 

the correct "uncontrolled" number. I am not sure that the percent reductions in the attachment are 

based on the correct number. I hope we can discuss this further in out next meeting on May 23. 

But feel free to call me prior to the meeting. Also, I am faxing some information and discussion of 

the definition for preform injection. 

preform injection performance data summa 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

EPA AIR DOCKET 
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SUMMARY OF PREFORM INJECTION DATA 

1. Pultrusion Industry Council (PIC), Phase II Data 

— commercial ladder rail 

- conducted inside temporary total enclosure 

- air flow (exhaust) out ofthe TTE was kept at a level sufficient to meet EPA TTE 

design criteria 

— plant air flow at wet areas was 100 feet per minute 

Results: Total Hydrocarbon Analyzer Carbon Tube 

Baseline: 0.91 lbs per hour 0.75 lbs per hour 

with preform: 0.09 lbs per hour 0.09 lbs per hour 

% reduction: 90.11% 88% 

Using amount of styrene processed, THA baseline emission factor of 10.7% of 

available styrene and 1.06% with preform. 

2. Strongwell 

— air velocity at preformer, wet out area: 200 feet per minute 

— conducted in accordance with EPA Method 204 

— intake and exhaust air at openings: 400 feet per minute 

Results: Open bath: 76.59 ppm net emissions generated process 

With preform: 6.54 ppm net emissions generated process 

% reduction: 91.46% 

3. Werner 

- ladder rail 

- Emission factor of 1.86% of available HAP from all emission sources 

- Calculate emission factor of 1.37% of available HAP just from the pultruders 

- Derived using preform, but not independent of other P2 techniques and company's 

proprietary pultrusion process. P2 includes low monomer resins, minimizing 

dimensions of wet out area, minimizing air flow over wet area (approximately 25 

feet per minute), controlling temperatures to minimize monomer vapors, etc. 

4. Creative Pultrusions 

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 2. 
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- 1994 test generated am emission factor of 1.9% of available styrene 

- Pultrusion machine configurations as follows: 

- 5 with direct die 

- several with preform injection 

- several with air flow management of bath areas 

Test scenario representative of normal operations 

- Previous tests indicated higher emissions (around 4 to 5%) but may understate 

emissions as a total enclosure was not utilized. Changes between these earlier 

tests and the 1994 test included reducing size ofresin baths and wet areas and the 

use ofresin injection where feasible 

Since 1994 test, now use (1) air curtains to reduce air flow around wet area to 15 feet per 

minute, (2) covers on resin baths, (3) pre-form injection, and (4) direct die injection. 

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