i L 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

41) ll-E-1 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:04 AM Sheet 41 of 264 
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MEMORANDUM 

TO: Composite Products NESHAP Project File 

ESD Project #93/58 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: April 2, 1993 

L:\N027 

SUBJECT: Summary of March 23, 1993 Meeting with the Composites Institute of the 

Society of the Plastics Industry (SPI) 

This memorandum summarizes the meeting held on March 23, 1993, in the 6th 

floor conference room, EPA/Mutual Building, Durham, NC, from 9:30 to 10:45 a.m. 

Attendees at the meeting were as follows: 

Mr. John Schweitzer 

Ms. Madeleine Strum 

Mr. Jim Berry 

Mr. Greg LaFlam 

PURPOSE 

EPA:CPB 

EPA:CPB 

PES 

Technical Director 

Composites Institute, SPI 

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The meeting was held at the request of Mr. Schweitzer. The EPA's principal 

objective was to explain the NESHAP project to Mr. Schweitzer and to request his 

cooperation in collecting information on the plastic composites production industry. Mr. 

Schweitzer began by stating his belief that visits to a variety of facilities by EPA and 

contractor staff would be critical to understanding the industry and writing effective and 

equitable standards. He thought that a mechanism may be available to provide funding to 

EPA for this purpose. Mr. Berry said he would investigate the feasibility of this 

approach. 
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INDUSTRY 

Mr. Schweitzer said that there are approximately 10 companies tiiat manufacture 

the resins used in composite products. Some of these are Dow, Reichhold, Ashland, 

Aristech, and Interplastics. Major market segments of the industry include transportation, 

marine, construction, and others. Mr. Berry asked about relative resin use by segment, 

and Mr. Schweitzer said he could provide those figures. The largest use by product is for 

compression molded automotive body panels. 

The Composites Institute has 450 member companies, whereas the total number of 

composites production facilities may approach 10,000. Mr. Schweitzer said that the nonmember companies could be identified through customer lists of the raw material 

suppliers. 

PROCESSES 

In addition to styrene (which is the most prevalent), other monomer/diluents 

commonly used in composite resins include methyl methacrylate. (Mr. Berry asked how 

the physical properties compare between products made with styrene or alpha-methyl 

styrene resins; Mr. Schweitzer will check.) Mr. Schweitzer said alpha-methyl styrene 

was not likely to replace styrene to a significant degree due to its low production and, 

hence, higher cost. Acetone (not a hazardous air pollutant) has traditionally been the 

cleanup solvent of choice for this industry, but many companies have reduced or 

eliminated the use of acetone in favor of low-VOC cleaners. 

CONTROLS 

Mr. Schweitzer stated that some fabrication facilities have installed incineration 

devices to control organic emissions from their processes. However, for many facilities 

(especially smaller ones or those using open mold processes), the use of such control 

systems may not be technically or economically feasible. For these facilities, an 

incinerator would be the most expensive and sophisticated piece of equipment in the plant. 

Ms. Strum mentioned two types of control systems in use in Europe that may be 

applicable, Zeolite adsorbers and the Polyad system. Mr. Schweitzer, in responding to a 

comment about styrene vapor suppressants, said that these additives can interfere with 

interlaminar bonding and thus are considered infeasible for certain applications such as 

boat manufacture. 

TESTING 

Test data on styrene emissions from composite production processes are limited, 

although Mr. Schweitzer said that there is some information related to the pultrusion 

process. Also, plans have been made to enclose an open molding process and make 

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emission measurements. At this time, the Composites Institute refers its members to the 

emission factors in section 4.12 of AP-42, although they believe that the AP-42 figures are 

just estimates. 

OTHER AcnvrriES 

Mr. Schweitzer referred to California's South Coast Rule 1162, which prescribes 

engineering controls and product substitution measures to reduce styrene emissions. The 

SPI is in a second round of negotiations on this rule, and is also dealing with OSHA 

concerning permissible occupational exposure limits. 

INDUSTRY SURVEY 

Mr. Schweitzer volunteered to investigate the possibility of the Composites Institute 

sending a comprehensive survey to its member companies and to as many of the remaining 

companies in the industry as possible. This survey will request the information sought by 

EPA concerning processes, controls, and costs, etc., as well as additional information 

needed by the Composites Institute. A copy of EPA's generic information collection 

request for NESHAP development was provided to Mr. Schweitzer as a guide to some of 

the information desired. Ms. Strum said that she would send additional examples (such as 

the section 114 questionnaire for the aerospace industry NESHAP) to indicate the type of 

information sought. Mr. Berry indicated that EPA also has the option of sending a limited 

number of additional questionnaires to composites producers under section 114. Ms. 

Strum stressed that, in addition to summaries of the industry responses, EPA would need 

access to the raw response information in order to perform its own independent analyses. 

Mr. Schweitzer agreed to investigate making the actual responses available to EPA. 

CONTACTS 

Mr. Schweitzer mentioned some additional industry groups that may have 

information or wish to provide input, such as the Cultured Marble Institute, the Composite 

Fabricators Association, and the National Marine Manufacturers Association. A coalition 

consisting of the Composites Institute and these other three groups, known as CAMP 

(Clean Air Management Partnership), shares information conerning air issues for the 

industry. 

CONCLUSION 

The meeting ended with Mr. Schweitzer providing a reference handbook 

(Introduction to Composites) and several periodicals. He said he would place PES on the 
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subscription list for two periodicals he thought would be useful. He also recommended 

that SPI's July 1991 comments on EPA's preliminary draft list of categories and 

subcategories be reviewed for the industry's views on how the Agency should approach the 

regulation of this industry. Ms. Strum reiterated that she would provide additional input 

for the industry survey, and requested the opportunity to review and comment on the draft 

questionnaire before it is sent out. 

cc: John Schweitzer, Composites Institute 

Madeleine Strum, EPA