Technical Assessment Report€¦ · Technical Assessment Report · on Emissions From Facilities...

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Technical Assessment Report · on Emissions From

Facilities Manufacturing Reinforced Plastics /Composites

Report No. EPD 94-02600

Prepared for:

Industrial Waste and Hazardous Contan1inants Branch Environmental Protection Division

Ministry of Environment, Lands and Parks

Prepared by:

O.N.C. St.Quinton, P. ENG Envirochem Associate

February 1994

@ Printed on Recycled Paper

TABLE OF CONTENTS

1.0 OBJECTIVE ........................................................... .

2.0 SCOPE .............................................................. .

3.0 RESPONSIBILITY ...................................................... .

4.0 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4. 1 Current Regulatory Regime in B.C. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4.2 Reason for New Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

5.0 DESCRIPTION OF EMISSION SOURCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5. 1 Raw Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5.2 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

6.0 EMISSION CHARACTERIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

7.0 EXPERIENCE IN OTHER JURISDICTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 7.1 Ontario . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 7.2 United States. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

8.0 ASSESSMENT OF EMISSION CONTROL METHODS AND TECHNOLOGIES . . . . . . . . . . 17 8.1 Volatile Process Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 8~2 Volatile Cleaning M~terials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 8.3 Particulate from Finishing Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 8.4 Fibre from Fibre Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

9.0 FINANCIAL IMPACT ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 . 9.1 Volatile Process Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 9.2 Volatile Cleaning Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 9.3 Particulate from Finishing Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 9.4 Fibre from Fibre Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

10.0 RECOMMENDATIONS................................................... 23 10.1 Regulatory Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 10.2 Pollution Control Objectives for RP /C Operations . . . . . . . . . . . . . . . . . . . . . . . 24 10.3 Permit Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 10.4 General P~rmi~ Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 10.5 Good Operating Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

11.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

LIST OF FIGURES

Figure 1: Production of Typical Unsaturated Polyester Figure 2: Typical Unsaturated Polyester Cross-linking Reaction

LIST OF TABLES

Table 1: Typical Components for Production of Unsaturated Polyesters Table 2: Typical Cross-Linking Agents and Catalysts Table 3: Resin Additives Table 4: Emission Factors for Uncontrolled RP /C Fabrication Processes Table 5: Typical Resin Monomer Contents Table 6: Typical Styrene Concentrations in Stack Exhausts Table 7: Summary of CARB RACT /BARCT for Facilities Manufacturing RP /Cs

LIST OF APPENDIXES

APPENDIX I Notes from Site Visits

APPENDIX II Estimation of VOC Emissions from B.C. RP /Cs Manufacturing

APPENDIX Ill Ranging Calculation for Emission of Particulate

APPENDIX IV Ontario Ministry of Environment Odour Impact Model for Styrene

APPENDIXV Summary by State of Regulatory Guidelines for Styrene

APPENDIX VI Determination of Reasonably Available Control Technology

and Best Available Retrofit Control Technology for Polyester Resin Operations

APPENDIX VII South Coast Air Quality Management District

RECLAIM Summary Recommendations

APPENDIX VIII Estimation of Cost of Acetone Work Practice Controls

APPENDIX IX Telephone Conversation Record Forms

4 5

4 5 6

12 12 12 16

FOREWORD

This technical assessment report was commissioned by the Ministry of Environment, Lands and Parks for the purpose of assessing the practices of the reinforced plastics/composites industry in British Columbia as they pertain to the discharge of emissions. to the environment as well as to review emission control practices in other jurisdictions that may be appropriate for implementation in British Columbia.

The findings and recommendations of this report are those of the author and do not necessarily represent the viewpoints or position of the Province of British Columbia.

93-6-28 TECHNICAL ASSESSMENT REPORT Page 1 Facilities Manufacturing Reinforced Plastics/Composites

1.0 OBJECTIVE

To provide recommendations for regulatory control of emissions from facilities manufacturing products from polyester and similar resins, with or without fibre reinforcement or fillers. These materials, often referred to as fibreglass or FRP (fibre reinforced plastics) are designated "reinforced plastics/composites" (RP /Cs) by the Society of the Plastics Industry, which will be the general term used in this report.

2.0 SCOPE

The industry intended to be controlled comprises all types of plants or facilities, manufacturing RP /Cs with or without reinforcing fibres, fillers or other additives. Types of facilities specifically included are those manufacturing parts and equipmentfortransportation (aircraft, automobile, boat, railway, recreational vehicle, and truck parts), industrial (corrosion-resistant ducting, electrical, fan, piping, structural, tank, and other process equipment) and home/recreational use (architectural mouldings, showers, tubs, surfboards, skis, helmets, etc.).

The emission controls discussed in this report are not intended to apply to plants manufacturing the resins, reinforcing fibres or other additives.

3.0 RESPONSIBILITY ·

The Industrial Wastes and Hazardous Contaminants Branch is responsible for controlling this industry sector.

93-6-28 TECHNICAL ASSESSMENT REPORT Page2 Facilities Manufacturing Reinforced Plastics/Composites

4.0 BACKGROUND

4.1 Current Regulatory Regime in B.C.

At the present time, air emissions to the environment from most facilities manufacturing RP /Cs are not individually regulated. Exceptions are a few facilities in the Southern Interior Region, and one facility in the Greater Vancouver area. While manufacturing of RP /Cs is not a separately identified industry in the Provincial Pollution Control Objective (PCO) documents, objectives that would likely be used for guidance can be found in the objectives for resin manufacturing [Ref 1] and miscellaneous [Ref 2] industries. Three levels are listed: Level A, for all new or proposed discharges; Level B, an interim level for existing facilities in the process of upgrading to Level A, and Level C, a level for immediate compliance, or compliance in the shortest feasible time, by existing facilities. The applicable A, B, and C levels are: 230, 345 and 575 mg/m3

a

for total particulate solids [Ref 1, Table Ill]; 200, 200, and 500b mg/m3 for styrene [Ref 1, Table Ill]; and, 102, 204 and 408 mg/m3 for hydrocarbons as methane [Ref 2, Table 1].

The facilities in the Southern Interior Region are regulated directly by the Ministry of Environment, Lands & Parks according to permits issued under the Waste Management Act, and the facility in the Greater Vancouver area, as delegated to the Greater Vancouver Regional District (GVRD) under section 19 of the Act [Ref 3]. The authority for regulation derives from the definitions of wastec and air contaminantd in section 1 (1) of the Act, and the provisions of section 3 which prohibit introduction of waste into the environment without appropriate authorization, of which a permit is one form.

Situations where facility emissions to the environment are currently regulated, have occurred as a result of public health concerns (usually triggered by odour emissions), or as a result of installation of ventilation equipment to reduce in-plant contaminant concentrations to levels acceptable to the Workers' Compensation Board (WCB). Principal contaminants of concern to the WCB are: styrene (8-hour permissable limit, 100 ppme); methyl ethyl ketone peroxide (ceiling value, 0.2 ppm), and to a lesser extent acetone (8-hour permissable limit, 1 000 ppm [Ref 4]). The WCB limits for styrene and acetone differ from the American Conference of Governmental Industrial Hygienists' (ACGIH) 1991-1992, 8-hour Time Weighted Average Threshold Limit Values (TWA-TLVs)t and are currently under review. Where multiple chemical exposure occurs, exposure is considered additive, unless known otherwise.

In addition, RP /C facilities using acetone for cleaning are subject to inspection by local fire departments, and may be subject to regulation under the Special Waste Regulation if generating more than 1 oo L in 30 days, or treating more than 5 L, of dirty acetone [Ref 6].

a

b

c

d

e

dry standard cubic metre; 20°C, 760 mmHg.

It is noted that 500 mg/m3 of styrene corresponds to 117 ppm. Since styrene carries a 9.2 subsidiary classification in the Transportation of Dangerous Goods Regulations, it could be argued that air contaminated at this level is special waste, and therefore subject to all the requirements of the Special Waste Regulation.

"waste" includes (a) air contaminants, (b) litter, (c) effluent, (d) refuse, (d.1) biomedical waste, (e) special wastes, and (f) any other substance designated by the Lieutenant Governor in Council, whether or not the type of waste referred to in paragraphs (a) to (e) or designated under paragraph (f) has any commercial value or is capable of being used for a useful purpose".

"air contaminant" means a substance that is emitted into the air and that (a) injures or is capable of injuring the health or safety of a person, (b) injures or is capable of injuring property or any life form, (c) interferes or is capable of interfering with visibility, (d) interferes or is capable of interfering with the normal conduct of business, (e) causes or is capable of causing material physical discomfort to a person, or (f) damages or is capable of damaging the environment."

concentration in parts of vapour or gas per million parts of contaminated air by volume at 2s°C and 760 mm mercury pressure.

styrene 50 ppm; acetone 750 ppm [Ref 5].


4.1.1 Direct Regulation by Ministry of Environment, Lands and Parks

Permits for the regulated RP /C facilities specify emission flowrates and operating periods, as well as general operating conditions relating to odours, disposal of waste acetone, bypasses, process modifications, etc. Contaminants are identified either generically as originating from fibreglassing operations, or specifically as styrene and particulate. Where identified, the maximum allowable discharge concentrations for these materials respectively are 200 mg/m3 (styrene PCO for Petrochemical, Resin and Paint Industries) and 229 mg/m3 (particulate PCO for Petrochemical, Resin and Paint Industries). In the case of two facilities applying for permits, letters of approval have been issued which specify in addition, sampling requirements and an ambient air quality objective of 70 µg/m3 which should not be exceeded.

4.1.2 Regulation by Greater Vancouver Regional District

The permit for the single RP /C facility regulated by the GVRD specifies: general operating conditions; solvent and resin usage reporting requirements; emission flowrates and contaminant concentrations; and, opacity and odour provisions. Styrene .and fibrous glass dust are the only specifically identified contaminants. The maximum allowable discharge concentrations for these materials respectively are 213 mg/m3 (1991-1992 ACGIH 8-hour TWA-TLV) and 100 mg/m3 (ten times the 1991-1992 ACGIH 8-hour TWA-TLV for nuisance dust). There is also an overall restriction on chemical contaminants having TLVs, which specifies that the sum of all emission-concentration-to-TLV ratios may not exceed ten. Stack opacity is restricted to 10%, and odours may not pass the plant boundary such that the District Director determines that pollution has occurred.

In addition to permit limits, the GVRD Air Quality Management Bylaw [Ref 7] sets administration and emissions fees for discharge of: nitrogen oxides; volatile organic compounds including methane; sulphur oxides; carbon monoxide; and, particulate in quantities exceeding specified limits.

4.1.3 Problem Areas

Styrene Odour

The main problems with RP /C facilities encountered by regulatory authorities are odour (and subsequent health) complaints from the public. These problems are often compounded by poor ventilation discharge design, and close proximity to other facilities or residential neighbourhoods.

Fibrous Glass Dust

Emissions of fibrous glass dust from finishing operations may be a problem in some instances.

4.2 Reason for New Regulation

There are several reasons why a new regulation is required:

(i)

(ii)

(iii)

(iv)

there are no specific regulations controlling this industry sector,

to provide consistent regulation across the Province, in accordance with the Ministry policy of regulating point sources on the basis of Best Achievable Control Technology (BACT),

to reduce emissions of volatile organic compounds (VOCs) in order to reduce ground level ozone concentrations in non-attainment areas (areas where the ozone levels exceed the Canadian air quality objective of 82 ppb; in B.C., principally the Lower Fraser Valley), and to prevent significant deterioration in other areas,

to provide a better basis for controlling some problem plants.


5.0 DESCRIPTION OF EMISSION SOURCE

Owing to the very diverse range of applications for RP /Cs, and the current unpermitted status of these facilities, an accurate count of production facilities in B.C. is not readily available. The 1991 B.C. Manufacturer's Directory [Ref 8] lists some 51 companies under the classification "Fibreglass & Fibreglass Products", although this number is known not to include all companies manufacturing RP /Cs (e.g. yacht builders, truck part manufacturer's, etc.). An industry contact indicates that there are perhaps 200 RP /C manufacturing operations in the Province, of which approximately one half are located in the Okanagan region. The industry is characterized by a large number of small operations (less than 1 O employees) with a few large operations (50 or more employees). Total provincial workforce is estimated at 2 400 employees.

Data from the Society of the Plastics Industry of Canada [Ref 9] suggest production during 1991 of approximately 1 O 000 Mg of RP /Cs in Western Canada. This number is consistent with the estimated 1991 B.C. production of 7 000 Mg, provided by another industry contact [Ref 10]. Both sources indicate that usage has decreased significantly (30% or more) during the current recessionary conditions.

RP /Cs are composite materials consisting of polyester, vinyl ester, or similar resins (40 to 60% by mass) and reinforcing, filling, or other additive materials. While a very wide range of products can be produced from the combination of available raw materials and processes, the basic production operation is the same in each case. An article with desired shape, and content of reinforcing, filling or additive materials, is produced while the resin components are liquid. An initiator causes the resin components to react with each other, so producing a solid, matrix product. In most cases some cutting, grinding or sanding is required as part of the finishing operations. In all cases clean up of personnel, work tools, and production equipment is required.

5. 1 Raw Materials

5.1.1 Resins

The resin components of a RP /C consist of "backbone", long chain unsaturated polyester, vinyl ester or similar molecules (approx 60% by mass) and smaller unsaturated cross-linking molecules or monomers. Production of a typical unsaturated polyester is shown in Figure 1 [Ref 11]. Table 1 shows some of the different chemical compounds that can be used for producing unsaturated polyesters [Ref 11 ]. Vinyl esters are shorter chain molecules with only two vinyl-ester groups at either end of the molecule. The backbone molecules are produced by resin manufacturers, rather than by the RP /C manufacturer. Polyesters are less expensive than other resins, and are used for general purpose applications. Vinyl esters are used where greater corrosion resistance is required, or in critical structural applications [Ref 12].

0 0 0 0 \\ II \\ II

n·C-0-C + 2n·HOH2C-CH20H + n-c-o-c ~ \ I I I

~ HC = CH

Saturated dibasic acid

(Phthalic anhydride)

Polyfunctional alcohol

(Ethylene glycol)

Unsaturated dibasic acid

(Maleic anhydride)

[

o o o o l II II II II -c C-0- CHrCH2-0- c C-0- CHrCH2-0-

\ I I I n ~ HC:CH

Unsaturated polyester

Figure 1: Production of Typical Unsaturated Polyester

Saturated Dibasic Acids Polyfunclional Alcohols Unsaturated Dibasic Acids

Phthalic anhydride Propylene glycol Maleic anhydride lsophthalic acid Ethylene glycol Fumaric acid Adipic acid Diethylene glycol

Dipropylene glycol Neopentyl glycol Pentaerythritol

Table 1: Typical Components for Production of Unsaturated Polyesters


An initiator (usually referred to as "catalyst" in the industry) is used to start a self-propagating exothermic polymerization reaction, between the unsaturated backbone molecules and the unsaturated cross-linking agent (monomer). The reaction rate is temperature sensitive, and heat may be applied to accelerate, or ensure completion of, the reaction. Formation of the cross-linked resin is shown in Figure 2 [Ref 11] (initiation not shown). Table 2 [Refs 11,13,14] shows some of the different chemical compounds that can be used as cross-linking agents and initiators. Styrene is the most commonly used cross-linking agent, and methyl ethyl ketone peroxide, the most common initiator.

0 0 0 0

0 Unsaturated II I II II II CH2=CH- ~ /; + polyester --7 (- CH2-CH2-0-C-CH-CH-C-O-CH2-CH2-o-C C-0-)n

I \ I .

Cross-linking agent (Styrene) o o :=b=o: /; o o

11 II I 11 (-o-c C-O-CH2-CH2-0-C-CH-CH-C-O-CH2-CH2->n

\ I II I

0 0 H-7-0H H-?- ~ /; Cross-linked

polyester resin

Figure 2: Typical Unsaturated Polyester Cross-linking Reaction

Cross-linking Agents Initiators (Monomers) (Catalysts)

Styrene Methyl ethyl ketone peroxide Methyl methacrylate Benzoyl peroxide a-Methyl styrene Cumene hydroperoxide Dicyclopentadiene 2,5-Dimethyl-2,5-bis(2-ethyl-hexanoyl-peroxy) hexane Vinyl toluene t-Amyl peroxy 2-ethyl hexanoate Vinyl acetate t-Butyl peroxy 2-ethyl hexanoate Diallyl phthalate t-Butyl peroxybenzoate Acrylamide t-Butyl peroxy maleic acid 2-Ethyl hexylacrylate 1, 1-bis(t-butyl peroxy) cyclohexane

Cyclic peroxyketal Di-(4-tert-butylcyclohexyl) peroxydicarbonate Lauroyl peroxide

Table 2: Typical Cross-Linking Agents and Catalysts

Although in most cases the resin supplier sells unsaturated resin pre-mixed with the cross-linking agent or monomer, the mix may also be produced by the RP /C manufacturer. Because styrene emissions are of concern to regulatory authorities, some resin formulations which reduce styrene emissions are now available in the U.S. These include low styrene resins (approx. 35% styrene by mass as opposed to 42% in conventional resins); resins with styrene partially replaced by alternate less volatile monomers (a-methyl styrene, vinyl toluene and dicyclopentadiene) and vapour suppressed resins (see Table 3).

5.1.2 Reinforcing Agents and Fillers

Most RP /Cs requiring reinforcement use glass fibres, although carbon and aramid fibres are used in high performance applications. Depending on the fabrication process, fibres may be incorporated into the product as: continuous or chopped strand roving (untwisted strands of multiple fibres); woven roving (fabric made from strand roving); woven cloth (fabric made from twisted yarn); milled fibres (short lengths of fibre); various types of mat (unwoven cloth made from continuous or chopped fibres), or a combination of these.

For some applications such as manufacture of synthetic marble tubs, no reinforcement is required, and various fillers are used. Examples of fillers are: calcium carbonate, talc, mica or small glass spheres [Ref 11].


5.1.3 Additives

Small amounts of a variety of other materials are used in RP /C operations for specific purposes. Examples and functions of such materials are given in Table 3.

Function Example Compounds Typical Usage

Cure retarder 2-4 Pentane dione

Fire retardant Antimony trioxide 3% based on resin Antimony pentoxide

Initiator stabilizer (MEK peroxide) Cyclohexanaone peroxide 40% of initiator mixture Dialylphthalate Dimethyl phthalate

Inhibitor (styrene) Hydroquinone ppm levels based on styrene

Pigment Titanium dioxide

Promoter Cobalt naphthanate Dimethyl aniline

UV Stabilizer - 1 % based on resin

Vapour suppressant Paraffin wax up to several percent based on resin Polymers Stearates

Table 3: Resin Additives

5.1 :4 Other Materials

Other materials used include: cleaners for personnel, and equipment (most commonly acetone in B.C., but increasingly emulsion-based and some alternate solvent-type materials in other jurisdictions); mould release agents or parting waxes (typically formulations of wax in petroleum distillate, alcohol, esters or ketones), and buffing compounds {abrasive powders in petroleum distillate).

5.2 Process Description

A variety of manufacturing processes are available for production of RP /Cs depending on the size, shape, physical characteristics, and production run of the final product. Processes differ according to the means by which the shape of the final article is formed, and the way in which the materials are applied.

Most processes use some type of mould to form the product being manufactured. The product may be built up on a single mould surface; confined between two matched moulds; pulled through a shaping die ("pultrusion"), or squeezed between rollers (continuous laminating). In some cases, an article may be fabricated of some other material, which is then strengthened with an overlay of fibre and resin (e.g. production of chemically resistant process equipment such as ducting, scrubbing towers, etc).

5.2.1 Single Surface Mould Processes

Single mould surface processes may utilize either male or female moulds. Since these processes generally produce one smooth surface {the surface in contact with the mould), and one rough surface, the selection of mould type depends on the application: for example, boats are produced in a female mould to give a smooth hull, whereas corrosion resistant tanks are produced on a male mould to provide a smooth interior chemical barrier.

While single surface mould processes are characteristically open (i.e. one surface open to the atmosphere), the specific application processes may in effect, be almost closed (e.g. some vacuum bag processing, moulding of filled resin, centrifugal casting, etc.).


General Process Steps

Mould Fabrication

A mould or form is fabricated. This is usually made from wood with a smooth plastic contact surface, although other epoxy or plaster type materials are used [Ref 15]. Moulds are usually used more than once.

Mould Preparation

A release agent is applied to the mould, usually with rags in a manner similar to waxing a car. Often, a single application of release agent suffices for several moulding operations [Ref 15]. In some instances mylar film may be used as an alternative to a release agent.

Resin Preparation

The degree of resin preparation depends on the application and the type of resin purchased. In some cases, no preparation is required, and the resin can be used directly from the container (typically drum, or semibulk container) in which it is purchased. In other cases, a specific formulation may be prepared utilizing one or more of the monomers given in Table 2, fillers listed in section 5.1.2, and/or additives listed in section 5.1.3. Initiator is added separately, usually immediately prior to application.

Ge/coat/Initial Resin Application

For most products, an initial unreinforced layer of resin specially formulated to provide a high quality surface finish (referred to as a gelcoat), is sprayed onto the prepared mould. Gelcoats are often pigmented. In chemical applications where corrosion resistance is more important than appearance, a corrosion liner of unreinforced resin is applied.

Resin/Fibre Application

One of the processes described below is used to apply resin and appropriate reinforcing fibre or filler. The requisite thickness is often built up in a series of layers for structural reasons, and to allow dissipation of the heat of reaction.

Finishing

Most processes require some type of operation such as cutting, grinding, or end trimming to finish the article after curing. Considerable resin/fibre dust may be generated during these operations.

Specific Resin/Fibre Application Processes

Hand Lay-Up

Hand lay-up is the simplest method of application. When the gelcoat (or a previous layer) has partially cured and become tacky, fibre cloth or mat is . manually laid over it, and then saturated with initiated resin mixture. Squeegees or rollers are used to press the layers together and remove entrapped air. Subsequent layers are added as required [Ref 16]. ·

93-6-28 TECHNICAL ASSESSMENT REPORT Facilities Manufacturing Reinforced Plastics/Composites

Spray-Up

Spray-up is similar to hand lay-up, except that a special chopper /spray gun is used to apply initiated resin and chopped roving to the mould. Different gun designs are based on the location of initiator /resin mixing, and the means of forming a directed spray pattern [Ref 16].

Vacuum Bag

Vacuum bag processing may be used to improve off-mould surface finish, increase the ratio of reinforcement to resin, and/or reduce emissions from the laminate surface. A flexible plastic sheet is placed over hand laid or sprayed laminate, and the edges are sealed to the mould. A vacuum is drawn under the sheet which compresses and smooths the laminate surface [Ref 16].

Pressure Bag

Pressure bag processing is similar to vacuum bag processing except that pressure is applied from above a flexible membrane, rather than from below [Ref 16].

Filled Resin Moulding

Synthetic marble consumer fixtures such as basins and tubs comprise a major proportion of filled resin RP /Cs. Numerous other articles such as cable junction boxes are produced by moulding of filled resins. Some filled resin moulding operations are almost entirely closed, especially if no gelcoat is applied.

Centrifugal Casting

Centrifugal casting is used to produce the hollow cylindrical portion of products such as ducting or tanks. Centrifugal force generated by rotation, is used to distribute resin and reinforcing fibre on the inside surface of a mould. Heating may be used to accelerate curing [Ref 16].

GELCOAT

ROTATING MOULD

Page 8

TO VACUUM

PRESSURE

GELCOAT

LAMINATE

93-6-28 TECHNICAL ASSESSMENT REPORT Facilities Manufacturing Reinforced Plastics/Composites

Filament Winding

Filament winding is used to produce the hollow cylindrical portion of products such as piping or tanks. A release agent (e.g. wax or mylar film) is applied to a mandrel, followed usually by spray application of a layer of resin without reinforcement (a "corrosion liner"), while the mandrel is rotated. After suitable curing of the initial resin layer, continuous strand roving that has been saturated in resin, is wound on to build up the required wall thickness. The workpiece is removed from the mandrel when cured, and finished as required. Fittings, or endpieces made by other processes may be attached [Ref 16].

5.2.2 Matched Mould Processes

CONTINUOUS STRAND ROVING

Page9

Matched or closed mould processes use pressure to form the product in the cavity between a pair of moulds. In some cases the pressure is applied by pressing the two parts of the mould together to form the final article, and in other cases, by forcing resin into the cavity once the mould is closed (resin injection or transfer processes). These two types of processes are illustrated by representative examples below. In either case, the article is formed under essentially closed conditions. Except for the application of resin and fibre, the general steps for matched mould processes are similar to those used for single surface mould processes. There are few RP /C manufacturers in B.C. using matched mould processes.

Cold Press Moulding [Ref 16]

Resin Injection or Transfer Moulding [Ref 16]

FEMALE MOULD

REINFORCEMENT

MALE MOULD

MALE MOULD


5.2.3 Non-Mould Based Processes

Pultrusion and continuous laminating are the two most important non-mould based processes.

Pultrusion

"Pultrusion" is used to produce long lengths of products having a constant cross-section. Continuous strand roving, mat or cloth is saturated in re.sin, and then pulled through a shaping die. Heating is usually used to initiate curing of the resin [Ref 16].

Continuous Lamination

Continuous lamination is used to produce sheet materials such as siding and roofing panels. Continuous mat or cloth is saturated with resin, sandwiched and squeezed between two layers of impervious film, and then cured. The film is stripped from the composite after curing [Ref 16].

SHAPING HEAT PULLING

.=.~ ~\ \ DEW\OE MATORCLOTH lillll ~

IJlll 1111 111111

RESIN APPLICATOR

CARRIER SHEET

FINISHED STOCK

HEAT SOURCE SQUEEZE

ROLLER

CONTINUOUS~ STRAND ROVING, MAT OR CLOTH

/ ~

I 1111111111

1111111111

~

RESIN APPLICATOR

I FINISHED STOCK

.93-6-28 TECHNICAL ASSESSMENT REPORT Page 11 Facilities Manufacturing Reinforced Plastics/Composites

6.0 EMISSION CHARACTERIZATION

There are four main types of emissions from facilities manufacturing RP /Cs:

(i) volatile organic compou.nds (VOCs) from storage, handling, application and curing of process materials,

(ii) VOCs from storage, handling, use and disposal of cleaning materials,

(iii) particulate from workpiece finishing operations, and

(iv) fibres from handling and application of fibrous reinforcing materials.

These materials are typically emitted into the workplace, from which they may be transferred to the outside environment through mechanical or natural ventilation. Because most production operations consist of a repeated cycle of processing steps, and since the emissions occur almost entirely from specific steps, there are often significant variations in emission concentrations during the cycle.

6.1 Volatile Process Materials

Styrene is the main volatile process material emitted from RP /C production operations, for reasons of volatility and usage, Other materials are essentially non-volatile (unsaturated "backbone", reinforcing agents and fillers) or in such low quantities and concentrations (residual resin components, alternate cross-linking agents, initiators and additives) as to be negligible [Refs 11, 13].

The main source of styrene emissions is evaporation from fresh surfaces during resin application and curing. In spray-up processes, gross loss of sprayed resin may also occur, especially if extraction hoods are injudiciously designed or placed. As to be expected from mass transfer considerations, resin surface area, styrene concentration driving force at the resin/air interface, resin temperature and air velocity over the resin surface affect evaporation rate. The effect of surface area (difference between processes generating a large surface area by spraying or large exposed working area) and styrene concentration at the resin/air interface (difference between vapour suppressed and non-vapour suppressed resins) is shown in Table 4 [Ref 11 ]. Note that the factors in Table 4 are based on monomer usage (i.e. total resin usage multiplied by fractional content of monomer). Where possible, actual monomer content should be used. If not available, Table 5 gives representative average values for first order estimates.

Styrene emissions can also be expected from resin storage and handling operations. In B.C.,, many facilities receive and store resins in closed drums or semi-bulk containers (cubitainers) from which emissions should be negligible. Even where resins are stored in bulk tanks, emissions are estimated to be small compared to those from lamination and gelcoating operations [Ref 13]. However no data are available to quantify these emissions.

Depending on processes used, and specific plant configuration, there can be significant variations in stack concentrations of VO Cs. The range of variation is summarized in Table 6 [Ref 13]. Some local measurements of stack emissions (13.1 to 14.4 ppm [Appendix I] and 100 to 200 ppm [Ref 17]) fall within the ranges shown. Since styrene has a fairly low odour threshold9 , there are often complaints of odour emissions around RP /C manufacturing facilities.

Calculations in Appendix II indicate total provincial emissions of styrene from RP /Cs manufacturing to be about 170 Mg/a, with emissions ranging from almost zero for very small operations to about 2 Mg/a for a medium size operation and up to perhaps 20 Mg/a for the largest operations.

9 Range of "acceptable" values for detection of styrene: 17 to 1 900 ppb (72 to 8 090 µg/m3).

Geometric Mean N.r Odour Threshold (GMAOT) for detection: 140 ppb (596 µg/m3).

Compare with detection GMAOT for: acetone, 62 000 ppb; ammonia 17 000 ppb; ethanol 180 000 ppb; hydrogen sulphide, 9.4 ppb; methyl mercaptan 0.54 ppb; naphthalene, 38 ppb; phenol 60 ppb [Ref 18].

93-6-28 TECHNICAL ASSESSMENT REPORT Page 12

a

b

c

d

e

g

h

Facilities Manufacturing Reinforced Plastics/Composites

Process Resin Application Emission Gel Coat Application Emission Emission~ Factor Emission~ Factor

gfkg monomer Used Ratingb gjkg monomer used Ratingb

Non-vapour Vapour Non-vapour Vapour suppressed suppressedc suppressed suppressedc

Hand layup 50-100 20-70 c 260- 350 80 - 250 D

Spray layup 90 - 130 30-90 B 260- 350 80- 250 B

Continuous lamination 40-70 10-50 B d d -Pultrusione 40-70 10- 50 D d d -Filament windingf 50- 100 20-70 D d d -Marble casting 10 - 30 10-20 B g g -Closed mouldingh 10-30 10-20 D d d -

Ranges represent the variability of processes and sensitivity of emissions to process parameters. Single value factors should be selected with caution.

Emission factors are rated from "A" to "E". An "Pt indicates a value derived from multiple data sets, using a valid reference method or equivalent. An "E" indicates a factor of the least reliability, such as one based on a single questionable measurement, or extrapolated from a factor for a similar process.

Factors are 30 - 70% of those for non-vapour suppressed resins.

Gel coat not normally used in this process.

Resin factors for continuous lamination process as per Ref. 11. Factors lower than 12 g/kg have been demonstrated [Ref 19].

Resin factors for the hand layup process are assumed to apply.

Factors unavailable. However, when cast parts are subsequently sprayed with gel coat, hand and spray layup gel coat factors are assumed to apply.

Resin factors for marble casting (semi-closed process) are assumed to apply.

Table 4: Emission Factors for Uncontrolled RP /C Fabrication Processes

Resin Application Typical Resin Monomer Contentsa g/g Resin

Hand layup 0.43

Spray layup 0.43

Continuous lamination 0.40

Filament winding 0.40

Marble casting 0.32

Closed moulding 0.35

Gel coat 0.35

a May vary by at least ±0.05 g/g resin.

Table 5: Typical Resin Monom~r Contents

Industry or Process Minimum voe Maximum voe Concentration Concentration

ppm ppm

Boat building 1 24

Continuous lamination 2 1 100

Tank coating 82 405

Synthetic marble 10 22

Table 6: Typical Styrene Concentrations in Stack Exhausts


6.2 Volatile Cleaning Materials

Acetone is the main cleaning material currently used in B.C. in RP /C operations. It is considered convenient because of good cleaning action, low toxicity and cost, and ease of waste disposalh. Acetone is however a significant fire hazard.

There is little quantitative information concerning emissions of acetone. Two literature sources [Ref 11, 13] reference the same source (a staff report by the South Coast Air Quality Management District) indicating that emissions from cleaners can account for up to 36% of plant VOC emissions. Information from local operations suggest that this percentage could be even higher (see Appendix 11). As a rough estimate, emissions of acetone from manufacturing of RP /Cs are probably similar to the emissions of styrene from this industry sector-Le. about 170 Mg/a for the Province, with emissions ranging from almost zero for very small operations to about 2 Mg/a for a medium size operation and up to perhaps 20 Mg/a for the largest operations.

Other volatile solvent based cleaners include: methyl ethyl ketone, methanol, and methylene chloride [Ref 15]. While no emission data specific to these cleaners are available, visits to various RP /C operations suggest that little of these materials are used. Some operations have tried and rejected various alternate less volatile solvent (dibasic esters mixture) and emulsion based materials which are now used in the U.S.

6.3 Particulate from Finishing Operations

Most processes require some type of cutting or grinding operation to remove or smooth material round the periphery of the workpiece. Literature sources [Refs 11, 13, 15] make no mention of this type of emission. Calculations in Appendix Ill suggest a range of possible emission factors from 0.07 to 1.6 gram of particulate per kilogram of laminate manufactured. On a Provincial basis this translates to emissions in the range 0.5 to 1 o Mg/a.

6.4 Fibre from Fibre Application

Although fibre chopping equipment is identified as a source of fibre emissions [Ref 11], there is no quantification of such emissions. Potential for this type of emission is greatest in spray-up operations, where a portion, or all the fibre is projected through the air to the workpiece. In this case, use of filters, design and location of extraction hoods, and operator skill are variables that are expected to significantly affect emissions.

h Small operations typically allow the acetone to evaporate to a sludge, which then may or may not be sent for special disposal. Large operations usually have atmospheric stills which can be used to recover a portion of the acetone for reuse.


7.0 EXPERIENCE IN OTHER JURISDICTIONS

7.1 Ontario

There are no regulations in Ontario specific to RP /C manufacturing operations. Industrial facilities which discharge contaminants into the environment require a Certificate of Approval under section 8 of the Environmental Protection Act in order to operate [Ref 20]. In most cases, this approval is site specific, and requires that contaminant concentrations at a point of impingement do not exceed specified values. The specified values, and an air dispersion calculation procedure for determining these values are given in Regulation 308 [Ref 21]. The calculation procedures include provision to consider a whole building as an emission source which may pertain to RP /C manufacturing facilities if emissions occur from building openings rather than a stack. Contaminants of greatest potential relevance to facilities manufacturing RP /Cs are: acetone (48 000 µg/m3

); methanol (84 000 µg/m3); methyl methacrylate (860 µg/m3

); styrene (400 µg/m3

), and particulate less than 44 µm (100 µg/m3). ·

The allowable point of impingement concentration specified in Regulation 308 is selected as the lowest of criteria for protection of health and environment, or avoidance of odour nuisance. The 400 µg/m3 for styrene is based on avoidance of odour nuisance [Refs 22,23] and compares reasonably with values from other sources (see footnote g). According to more recent determinations by the Ontario Ministry of Environment, this level corresponds to detection of odour by 11 % of the population [Ref 24] (see Appendix IV).

7.2 United States

RP /C manufacturing facilities are not a specifically designated source category for which New Source Performance Standards have been set in the Code of Federal Regulations. However, they are potentially subject to provisions under the Clean Air Act Amendments of 1990 (CAAA), intended to maintain or achieve National Ambient Air Quality Standards (NAAQSs), or to control emissions of hazardous air pollutants (HAPs).

Maintenance of National Air Quality Standards

Areas where air quality is better than specified in the NAAQSs, are designated as "attainment areas", and controls are directed toward preventing significant deterioration (PSD). PSD review and application of best available control technology (BACT) is required for major sources (100 tons per year or more of any pollutant regulated by the CAAA) in attainment areas [Ref 25].

Areas where air quality does not meet the NAAQSs, are designated "non-attainment" areas, and are ranked by the severity of non-attainment. In these cases, states are required to file a State Implementation Plan, which sets out a program to achieve compliance with the NAAQSs, including measures to curtail emissions. The threshold for definition as a major source (i.e. the facilities subject to control), and the required control measures become more stringent as the degree of non-attainment increases. In the case of ozone nonattainment areas, the definition of a major source of volatile organic compounds varies from 100 tons per year in a marginal area to 10 tons per year in an extreme area [Ref 25].

Control of Hazardous Air Pollutants

A number compounds which may be emitted from RP /C facilities, have been designated as HAPs by the CAAA. The most important of these is styrene. Any source which emits 1 O tons per year or more of any single HAP, or 25 tons per year or more of any combination of HAPs, is defined as a major source. Major sources will be required to meet MACT requirements. MACT is defined as a stringency equivalent to the average of the best 12% of the sources in the category [Ref 25].


In addition to the technology-based standards, there may also be health-based standards. On a Federal level, the EPA is required to report to Congress by 15 November 1996 on the residual risk related to emissions of toxic air pollutants and will be required to promulgate residual risk standards, beginning in 2001, for sources of toxics which continue to pose a risk to health. In the meantime, individual states may apply (and may continue to apply) their own health-based standards [Ref 26].

For RP /C manufacturing facilities, there is a great deal of variation in the health-based standards. Some states such as Hawaii and West Virginia do not currently regulate styrene as a toxic air pollutant. Others such as Oklahoma and Wisconsin regulate styrene as a non-carcinogenic pollutant, with fence-line standards of 5 and 1.2 ppm respectively. Still others such as Kansas and Massachusetts regulate styrene as a carcinogen, both with a fence-line standard of 0.000 4 ppm. (see Appendix V for a summary by state of classifications and limits). Although the International Agency for Research on Cancer (IARC; Lyon, France) classified styrene in 1987 as a possible human carcinogen, subsequent reviews by other agencies (European Community Specialized Experts for Carcinogenicity, Mutagenicity and Teratogenicity, 1988; U.S. Occupational Safety and Health Administration, 1988; and, the National Institute for Occupational Safety and Health 1988) have not supported this classification [Ref 27]. Further research is in progress by various organizations and agencies.

7.2.1 California

California is considered to lead other states with respect to requirements for RP /C manufacturing facilities [Ref 28]. The state is divided into twenty one Air Quality Management Districts (AQMDs), which have the power to regulate air pollution from stationary sources in their jurisdiction, provided their regulations result in controls which are at least as stringent as those specified in the State Implementation Plan. The AQMDs are assisted by the California Air Resources Board (CARS), which has overall responsibility for coordination. In this capacity, CARS has produced a guidance document entitled "Determination of Reasonably Available Control Technology (RACT) and Best Available Retrofit Control Technology (BARCT) for Polyester Resin Operations" [Ref 29] (see Appendix VI). ·

The main emphasis of the RACT /BARCT determination is to prevent generation of emissions. With some specific exemptions, manufacturers of RP /Cs are given the choice between using processes and materials which result in reduced emissions, and using add-on controls. Table 7 summarizes the various provisions.

Any type of facility emitting one or more of designated substances is also subject to the Air Toxics "Hot Spots" Information and Assessment Act [Ref 30]. Smaller facilities Oess than 1 O tons per year of designated substances, and in some cases less than 25 tons per year) may be eligible for assistance in complying with the requirements of the Hot Spots act [Ref 31]. Under the regulations pursuant to this act, facilities are required to report annual emissions quantities of the designated substances, which are used to prioritize facilities into high, low or intermediate categories of potential incremental health risk to the surrounding community. Facilities in the high potential risk category are required to carry out a detailed risk assessment, and may be required to notify the public if the estimated incremental risk is deemed unacceptable.

In the case of RP /C manufacturing facilities, the situation is not clear at this time, partly because agencies are severely backlogged with assessments [Ref 32], and partly because styrene has been given a lower priority for assessment [Ref 33].

In addition to the above, a variety of general requirements not specific to RP /C manufacturing facilities are applicable in most AQMDs. Examples which may be applicable are: Permit to construct; Permit to operate; Particulate Matter Regulation; Nuisance Regulation, and Breakdown and Variance Procedures.


Process and Control Requirements - Use resina formulation with monomer»- content !; 35 per cent by weight, or - Use resin formulation with monomer content !; 50 per cent by weight for specialif resins, or - Use vapour suppresseda resins having weight loss of !; 60 g/m2, or - Use a closed mould systema, or - Use add-on control devices that achieve a maximum capture efficiency using EPA protocols and achieve a

destruction efficiency of at least 85% by weight. The overall efficiency of the control system shall be at least as effective in emission reductions as the level of control of complying resins.

Transfer Efficiency Requirement for Spray Application Processes - Use airless, air-assisted, high volume/low pressurea, or electrostatic spray equipment.

Oeaning Material Requirements - Use cleaning materialsa containing ~ 1.7 lb of voca per gallon (204 g/L), or - Use cleaning materials with initial boiling point greater than 190°C, or - Use a solvent reclamation system.

Storage and Disposal Requirements - Store all solvents and wastesa in closed containers, and - Dispose of all solvents and wastes properly.

Exemptions - Touch-upa and repair operationsa, or

- Application of pigmented gel coatsa that contain < 45 per cent by weight monomer, or - Application of clear gel coats that contain < 50 per cent by weight monomer.

Administrative Requirements

- Facility to comply with an implementation schedule, and

- Records to be kept of usages, inventories and properties of specified materials, and - Specific methods to be used for analysis.

a Definition of these terms provided in the RACT /BARCT determination.

Table 7: Summary of CARB RACT /BARCT for Facilities Manufacturing RP /Cs

Because of extreme ozone non-attainment, the South Coast AQMD generally has the most stringent source control regulations. The main regulation applicable to RP /C manufacturing facilities is Rule 1162. This rule contains substantially the same provisions as the CARS RACT /BARCT, since the RACT /BARCT was based on Rule 1162. However, the structure of these regulations may change, based on a major new initiative known as RECLAIM (REgional Clean Air Incentives Market). A copy of the summary recommendations document is provided in Appendix VII. It is proposed that companies will achieve their required emission reductions through a market-driven combination of add-on controls, product reformulation, and purchases of emission credits from other sources. Under this initiative, Equipment Permits would be replaced with Facility Permits, Emission Rates with Mass Emission Limits, and Retrofit Control Rules with Annual Emission Reductions [Ref 34]. While the South Coast AQMD feels that the use of trading can dramatically reduce compliance costs, industry lobbyists are deeply suspicious of the proposals: "While the program is portrayed to the public as an historic experiment in emissions trading, it is in fact primarily an effort to require massive new emission reductions that are not technically or economically feasible with current or foreseeable technology. The program's emissions trading features are merely an adornment on a fundamentally flawed proposal" [Ref 35]. -


8.0 ASSESSMENT OF EMISSION CONTROL METHODS AND TECHNOLOGIES


Control Technologies

In many RP /C manufacturing operations there are possibilities for reducing emissions of process VOCs through implementation of pollution prevention techniques, rather than by use of add-on controls. Various possibilities and their limitations are discussed below.

Low Monomer Resins

Monomer emissions may be reduced by reducing the monomer content of the resin as applied. Resins containing no more than 35% by weight of monomer have been developed, and are currently used for general purpose applications in the U.S. Reducing resin styrene content to 35% or less has been estimated to reduce styrene emissions from application and curing by 19% [Ref 13] to 40% [Ref 29].

However low monomer resins (35% or less) are more difficult to use and may not produce as strong a product as conventional resins. Hence the current generation of low monomer resins cannot be considered demonstrated for: applications requiring extreme strength such as power boat hulls; and, equipment for severe chemical or flame resistant service requiring specialty (vinyl ester, halogenated, furan, bisphenol A or isophthalic) resins. In addition, some types of gelcoating have not proven feasible with low monomer resins. U.S. data indicates specialty resins to comprise less than 10% of the resin usage [Ref 19], and gelcoats to comprise approximately 15% of resin usage [Ref 13].

Costs of low monomer resins are indicated to be similar to conventional resins in the U.S. [Ref 13].

Substituted Monomer Resins

Monomer emissions may be reduced by substituting monomers with lower vapour pressure, for part of the styrene. Typically 3% to 5% of the styrene is substituted with compounds such as vinyl toluene, or dicyclopentadiene. -It is noted that occupational exposure limits for dicyclopentadiene (5 ppm [Ref 5), 1 o ppm [Ref 4]) are significantly lower than for styrene, a-methyl styrene and vinyl toluene (all 50 ppm [Ref 5], or 100 ppm [Ref 4]). Achievable reductions in emissions during application and curing depend on the quantity and type of alternate monomers used, but are estimated to be around 20% [based on Ref 13].

Costs of substituted monomer resins are indicated to be approximately twice those of conventional resins [Ref 13].

Vapour Suppressed Resins

Monomer emissions may be reduced by adding a small amount of paraffin wax or other material, to form a film on the exposed resin surface. Use of vapour suppressed resins has been estimated capable of achieving reductions in emissions of 30% to 50% [Ref 13] or 70% [Ref 11). Some RP/C manufacturers already use such additives as a "surface inhibitor" to promote full curing of the outermost resin layer by excluding oxygen. However, vapour suppressed resins cannot be considered demonstrated for processes where the final product is built up in a series of layers, because both the surface film and the complete curing of the outer surface can reduce adhesion between layers (secondary bonding), causing delamination in service.

Costs of vapour suppressed resins are indicated to be 5% to 10% greater than conventional resins [Ref 13]. -


Closed Moulding

Closed moulding processes produce low emissions because there is little freshly exposed resin surface. However, this process is limited to specific applications, typically smaller articles which are mass produced. Reductions achievable depend on the process that is converted to closed moulding, but would likely range from 30% to 80%, based on emission factors in Table 4.

High Efficiency Spray Applicators

In spray application processes, a variety of techniques· can be used to maximize the deposition of gel coat or resin droplets on the workpiece. The following types of spray equipment are designated as high efficiency applicators in California [Ref 29]: airless (hydraulic pressure alone is used to generate spray); air-assisted airless (air is used to contain and direct, but not generate spray); high-volume low-pressure (operating air pressure is in the range 0.7 to 70 kPa gauge), or electrostatic (opposite charges imposed on the spray droplets and workpiece, cause the spray to be electrostatically attracted to the workpiece). Claims by competing equipment manufacturers make it difficult to assess possible emission reductions. However the reported variation in emissions between different types of high efficiency spray equipment (33% to 42%), suggests that elimination of any low efficiency equipment could result in dramatic emission reductions.

Although capital costs of high efficiency spray application equipment may be several times that of low efficiency equipment [Ref 10], the cost of high efficiency equipment is small in comparison to raw materials used [Ref 36], and may be recouped in raw material savings. It is known that at least one B.C. manufacturer of RP /Cs has found it cost effective to periodically update spray equipment on the basis of raw material savings alone.

Add-on Controls

In principle, incineration, adsorption, absorption, or condensation might be considered as applicable add-on control technologies. However, there appears to be general agreement [Refs 11, 13, 15,29] that in most cases such technologies are not well suited to emissions from facilities manufacturing RP /Cs. The main reason is that workplace ventilation to reduce worker styrene exposure, produces large volumes of air with low contaminant concentrations (see Table 6). In such cases, capital and operating costs are extremely high (USD 19 000/ton VOC removed for absorption, to USD 48 000/ton for incineration [Ref 29]), and treatment efficiencies relatively low.

Add-on controls would only likely be effective in specific situations where a low flow of more highly contaminated air could be treated separately from the main stream of ventilation air. An example might be treatment of emissions from gelcoating operations because these contribute a disproportionate quantity of emissions as indicated by Table 4. Since workers are often required to wear respirators for this operation, it is possible that greater enclosure could be used to more effectively capture emissions without compromising safety.

Of the technologies listed, only incineration can be expected to give worthwhile destruction efficiencies (90% or greater) at inlet concentrations less than 200 ppm [Ref 37]. However, even this technology may not be well suited to RP ;e manufacturing, because emissions are often generated on an intermittent basis.

Adsorption is not effective at low voe concentrations (typically less than 50% removal for inlet concentrations less than 200 ppm [Ref 37]. While some reduction of voe concentrations has been demonstrated for one RP ;e operation [Ref 13], polymerization of adsorbed styrene and fire hazards associated with adsorption of acetone are other concerns in the application of this technology.


laboratory studies have been conducted on various absorption (scrubbing) systems, but to date there are no known demonstrated applications [Ref 13].

Polymerization of styrene, and low collection efficiencies (typically less than 50% at 500 ppm inlet concentration [Ref 37]) are drawbacks of condensation.

One emerging technology which may eventually be applicable to RP /C operations is corona destruction. Benchscale experiments with contaminant streams containing less than 1 o ppm of a single VOC (including styrene), have shown destruction to below detectable limits. Corona destruction operates at atmospheric temperature and pressure, produces no residuals requiring further treatment, is not susceptible to poisoning by sulphur or halogen compounds, and has lower operating costs than adsorption or incineration [Ref 38].

Best Available Control Technology

It is considered that application of a combination of pollution prevention techniques as embodied in the California Determination of RACT /BAR CT for Polyester Resin Operations (reproduced in AppendixVI) is best available control technology for reducing volatile process emissions from RP /C facilities. The California determination published in January 1991, represents the culmination of an evolutionary process toward control of this industry sector based on Rule 1162 promulgated by the South Coast AQMD in 1987. It should be noted however, that not all techniques are applicable to all processes, and that in some cases at present, no prevention technique is applicable (e.g. filament winding of large tanks using specialty resins for corrosion resistant applications). There are indications that implementation of the South Coast AQMD Rule 1162 has spurred development of various types of low emission resins [Ref 19], and that further development can be expected. The need for certification of resins for some applications (e.g. underground gasoline tanks), restricts the immediate use of new resin formulations.

Because achievable standards are fractional reductions of emissions rather than absolute stack discharge concentrations, it is not likely that all emission problems associated with manufacture of RP /Cs would be resolved by adoption of this BACT alone. In particular, zoning, careful design of ventilation systems, and proper dispersion of residual emissions are considered necessary adjuncts if odour problems are to be avoided.

Environmental Impacts

Implementation of the pollution prevention measures recommended as BACT should not result in any negative environmental impacts. There is potential for reduction (but not elimination) of worker exposure, ozone formation and odours.

For operations adopting incineration as an add-on control, emissions of CO, C02 and NOx would tend to offset environmental advantages gained by destruction of voes. Likewise, carbon adsorption and absorption both produce residual materials for which disposal would be required.

8.2 Volatile Cleaning Materials


The main possibilities for reduction in emissions of cleaning VOCs are good work practices (including use ·of reclamation systems) and use of alternate emulsion and solvent based cleaners.

Work Practice Controls

Data from a survey of VOC controls for boat manufacturing has indicated that good work practice controls can reduce acetone use by an estimated 22% [Ref 13]. The controls consisted of use of closed acetone containers at work stations, and use of gloves or barrier creams by workers to reduce personal cleanup requirements. A system for issuing a daily ration of acetone to workers was identified as a key control requirement.


In addition, it has been demonstrated that a significant portion of acetone used for cleaning can be reclaimed by atmospheric distillation. Some facilities in B.C. have already installed stills, and recover approximately 25% of acetone used [Appendix IJ. However, with acetone costing $1.00 - $1.50 per kilogram, recovery is not likely to be economic if evaporation is allowed as an alternative. -

Emulsion Cleaners

Several emulsion based cleaners are available in the U.S., with a limited number of products currently available in B.C. While emulsion cleaners can reduce acetone usage by 50% to 70%, the following drawbacks are noted: unsatisfactory performance for gelcoat and spray gun cleanup; increased time and effort required for cleanup; performance is best when cleaning solutions are heated to over 40°C; a final acetone rinse is usually required to prevent water contamination from damaging workpieces; and, alkalinity can cause skin reactions in sensitive individuals [Ref 13]. In view of these factors, employee acceptance is probably the greatest obstacle to use of emulsion cleaners.

Alternate Solvent Cleaners

A number of alternate solvent based cleaners are available in the U.S. These include formulations of: dibasic esters (DBE; a mixture of dimethyl succinate, dimethyl glutarate and dimethyl adipate); 7-butyrolactone and N-methylpyrrolidone (Ship Shape); and various terpenes. Manufacturers claim that moderate concentrations are reasonably biodegradable and that in the U.$1 these materials· alone are non-hazardous as waste. However, use of these materials is not wide spread, for reasons of cost and worker acceptance. It is therefore difficult to determine whether they can be considered demonstrated technologies, fully able to replace acetone.

In the case of DBE, it has been estimated that a 75% reduction of VOC emissions can be obtained if a total switch from acetone is possible [Ref 13}. It is noted that there have been some reports of workers suffering from blurred vision when using this material. In addition, low volatility may make recycling and disposal of residues difficult in B.C. In the U.S. vacuum distillation units are used for reclamation, and residues are usually incinerated.

Add-on Controls

Because acetone emissions are diluted by the air used to maintain styrene concentrations at acceptable levels, use of current add-on controls for treatment of acetone emissions are subject to the same limitations as noted in section 8.1.


It is considered that application of a combination of pollution prevention techniques as embodied in the California Determination of RACT /BAR CT for Polyester Resin Operations (reproduced in Appendix VI) is best available control technology for reducing volatile cleaning emissions from RP /C facilities.


Implementation of work practice controls for use of acetone, and reclamation of dirty acetone has potential for reduction of emissions of VOCs, without negative environmental impacts. Replacement of acetone with other cleaners has the potential for even greater reductions in voe emissions, but requires proper management of residues to prevent impacts on water quality.

A preliminary examination of available information suggests that these materials on their own would not be classified in Canada under the Transportation of Dangerous Goods Regulations. However, it is possible thatthe cleaning sludges could be classified as a result of contamination. In particular, contamination with unpolymerized styrene at a level greater than 100 ppm would cause the sludges to be classified, owing to the 9.2 subsidiary classification for styrene.


Experience in the U.S. with one emulsion cleaner (Res-Away), has determined that dried sludge residues are generally acceptable for disposal to sanitary landfill, and that liquid residues are acceptable for discharge to sewer where secondary wastewater treatment is provided. In this situation environmental impacts should be negligible. High pH and corrosiveness of liquid residues have been identified as problems where secondary treatment is not available, and have precluded use in such circumstances [Ref 13].

If not properly disposed, the alternate solvent cleaners could have water quality impacts, because they do not evaporate to the same extent as acetone. However, given the greater cost of these materials, it is unlikely that they would be used unless suitable reclamation facilities were available.



Cyclones, inertial separators, wet scrubbers, electrostatic precipitators and fabric filters are us~ for collection of particulate. Of these, cyclones and inertial separatdrs are low efficiency devices, and are usually used as pre-cleaners for upstream devices. Proper assessment of the other types of devices requires information on air flow rates, particle sizes and particulate loading, which does not appear to be available from literature on RP /C manufacturing. Based on observation of RP /C finishing operations, it is expected that fabric filtration would be the most appropriate technology, provided that sufficient separation from spraying operations is allowed to prevent capture of resin mist. In other applications, collection efficiencies in excess of 99% have been demonstrated.


Because of the lack of information, it is not possible to specify that fabric filtration constitutes BACT for control of particulate in RP /C operations.


It is not expected that there would be any negative environmental impacts from application of fabric filtration. At worst, polymerized resin dust would be collected for landfill disposal, rather being deposited in the vicinity of the RP /C manufacturing operation.



In principle, the same types of equipment discussed in section 8.3 could be used for collection of fibre from fibre application. However, because escape of fibre is only generally of concern in spray up operations, complications resulting from co-capture of overspray resin are likely. For this reason, and because fibres are relatively large, careful placement and use of replaceable filter pads over ventilation openings are considered the best option for controlling fibre emissions. It is not known what degree of collection could be obtained by these means.


Because of the lack of information, it is not possible to specify that use of replaceable filter pads constitutes BACT for control of fibre in RP /C operations.


Use of replaceable filter pads would increase the quantity of waste requiring disposal. Although appropriate disposal of filter pads would depend on contaminants captured, there is no reason to expect that special precautions would be required.

93-6-28 TECHNICAL ASSESSMENT REPORT Page 22 Facilities· Manufacturing Reinforced Plastics/Composites

9.0 FINANCIAL IMPACT ASSESSMENT


The financial impact of the recommended BAeT will depend on the particular means used to achieve compliance. Where pollution prevention techniques are used, the combination of alternatives and exemptions should mean that compliance costs are minimal.

Because of high cost (ranging from USO 19 000 per ton of voe removed by absorption to USO 48 000 per ton for incineration [Ref 29]), add-on controls are not recommended as BAeT.

However, as noted in section 8.1, it is unlikely that adoption of the recommended BAeT alone will be sufficient to eliminate problems of odour complaint, especially where emissions are not well dispersed. Costs for achieving proper dispersion are not addressed in detail in this assessment because dispersion does not qualify as BAeT (dispersion does not reduce a waste discharge), and because it can be argued that dispersion is required whether or not the recommended BAeT is applied. It is noted that capital costs for installation of a proper stack could vary widely (say $2 000 to $20 000 for a small to medium size operation) owing to the variety of variables involved, such as: emission flowrate; suitability or otherwise of existing equipment for modification; topography and location of other sources; structural requirements for supporting a stack, etc.

9.2 . Volatile Cleaning Materials

There should be little financial impact from the imposition of work practice controls. Estimates in Appendix VIII, indicate that any additional supervisory time to administer the controls would be reasonably offset by savings from reduced acetone usage.

The financial impact of requiring RP /C operations using 15 L/d or more of acetone to use reclamation would not be major, although installation of an in-house still can probably not be justified on the basis of savings alone. The cost of in-house reclamation is estimated in Appendix VIII to be about $4 ooo /Mg of voe removed.

In the U.S., it appears that at worst there are no cost savings through use of non-acetone cleaners, although manufacturers of some emulsion and alternate solvent cleaners both Claim cost savings [Ref 13]. In B.C., economics of use of alternate cleaners are likely to be influenced by three major factors: whether evaporation to dryness is acceptable for disposal of acetone sludges; availability of suitable vacuum stills to reclaim alternate solvents; and availability of facilities to incinerate still bottom sludges.


Little information was located regarding control of particulate .from finishing operations. It is understood however, that in small operations portable control systems similar to a vacuum cleaner attached to a grinding tool have been successfully used. At a cost of around $1 200 each, such controls should not have a major financial impact.


No cost information was located regarding control of fibre from fibre application. However, at some facilities visited, replaceable pads similar to furnace filters were placed over extraction vents. It is assumed that the · cost of such controls is not significant if they are currently being used in the absence of specific regulatory requirements.


10.0 RECOMMENDATIONS

10.1 Regulatory Approach

A flexible approach is required for regulating facilities manufacturing RP /Cs because of the wide range of sizes and types of operations. For this reason, a ''two-tiered" approach is recommended, in which all but the smallest operations are subject to a combination of emission limits and good operating practices, with only the significant emission sources controlled by permit. Since this industry sector is characterized by a large number of small operations, and a small number of large operations, use of this approach should provide a mechanism for control of problems, without adding excessive permit administration:

There are two possibilities for determining the size of operations subject to regulatory control: specification of resin usage quantities, or specification of volatile compound emission quantities. While the first alternative has the advantage of simplicity, the second alternative could be arranged to provide incentives for pollution prevention.

10.1.1 Facilities Requiring Permitting and Compliance with Good Operating Practices

Review of available information, and discussions with industry contacts suggest that 80% of emissions from the RP /C manufacturing industry sector are contributed by medium and large size companies, comprising perhaps 20% of RP /C manufacturing operations. Since a medium size company in B.C. may be characterized as using 18 000 to 90 000 kg/a of resin, it is suggested that the low end of this range be used as the resin usage threshold requiring permitting. In a typical spray-up operation, emissions of VOCs from a facility of this size would be approximately 1.7 Mg/a, split equally as styrene and acetone1. It is noted that this quantity is approximately equal to 5 kg/d of voes, which is the threshold for permitting set by the Greater Vancouver Regional District Air Quality Management Bylaw No. 725.

As indicated above, specification of a VOC emission threshold as opposed to a usage quantity, provides an incentive for medium and smaller industries to use less polluting production techniques. For example, a typical manufacturer eliminating use of volatile cleaners (acetone) could probably use almost 36 000 kg/a of resin without requiring a permit

10.1.2 Facilities Required to Comply with Good Operating Practices

Since facilities not requiring to be permitted, could give rise to odour problems, it is recommended that smaller facilities still be required to comply with good operating practices defined by regulations. However, to avoid regulation of hobbyists and other small users (Le users who are not RP /C production facilities), it is suggested that a lower limit of one tenth of the permitting threshold be set, below which regulations would not apply.

Assume: spray-up (emission factor 110 g/kg monomer from Table 4); resin containing 43% styrene (Table 5); and equal contribution to voe emissions from styrene and acetone (see section 6.2). Hence styrene emission = 18 000 x 0.43 x 110/1 000 = 851 kg/a Hence total VOe emission = 851 x 2 = 1 702 kg/a.


10.2 Pollution Control Objectives for RP /C Operations

The pollution control objectives discussed in this section should apply to all RP /C production facilities, whether permitted or not.

10.2.1 Styrene

As indicated in section 8.1, the pollution prevention BACT recommended does not specify achievable absolute stack discharge concentrations. Nevertheless, review of available data (e.g. Table 6 and Appendix I) suggests that the current PCO of 200 mg/m3 (46.9 ppm) for styrene from resin manufacturing plants is a reasonable objective. In the case of those processes indicated in Table 6 to generate high stack concentrations, it is likely that flow rates would be lower, thus making incineration more cost effective.

Since a stack concentration of 100 ppm styrene could be argued to constitute special waste, it does not seem appropriate to recommend a higher PCO for styrene. Conversely, demonstrated technologies producing lower stack concentrations are not available at the present time to justify a lower PCO.

10.2.2 Particulate

Although particulate control technologies specific to RP /C manufacturing facilities were not identified, experience with fabric filtration in other applications suggests that there should not be undue difficulty in achieving a PCO for particulate of 100 mg/m3

•

10.2.3 Odour

Since it is not possible to reduce stack concentrations of styrene below the odour threshold, dispersion of stack emissions is necessary to prevent odour complaints. Based on Ontario experience and data for styrene [Refs 21,24], it is suggested that 400 µg/m3 be set as the maximum permissable half-hour concentration at any point of impingement outside facility boundaries.

10.2.4 Other Objectives

Because of the large quantity of air required to control styrene levels, objectives for other contaminants would not appear to be necessary.

10.3 Permit Parameters

The permit parameters discussed in this section should apply only to permitted RP /C production facilities.

10.3.1 Air Quantity

In most cases, air quantities will be set by health and safety considerations, and will be process specific. As such, it is not possible to specify generic guidelines for air quantities. However, if there is a requirement for permit applicants to show that sufficient dispersion has been provided so as not to exceed a specified ambient air quality concentration, there will be an incentive to reduce overall emissions and air flowrates to a minimum.

10.3.2 Concentration Parameters

The permit should specify limits for VOC, and particulate. Correction to a specified oxygen concentration is not necessary unless incineration is used.

10.3.3 Other Limits

Standard clauses specifying control of dust and odour to within plant boundaries should be specified.


10.4 General Permit Conditions

The permit conditions discussed in this section should apply only to permitted RP /C production facilities.

10.4.1 Demonstrated Operation

Plant emissions are significantly affected by processing operations and production levels. For this reason, it would be desirable for a facility to be authorized only for the worst case conditions demonstrated in compliance testing. However, determining and testing of worst case conditions may not always be easy, and may require more than one test. Where appropriate, it is suggested that compliance testing should take account of as many of the following factors as possible: maximum production ratek (prorate results if product orders at the time of testing do not approximate maximum production/worst case); worst concurrent combination of operations (include gelcoat spraying, if used); highest resin monomer content; maximum processing temperature; ventilation conditions; and, operation of add-on pollution control devices (if any).

10.4.2 Testing Frequency

Since it is expected that in most cases emissions will depend on production variables rather than operation of add-on pollution controls, it is unlikely that routine testing beyond an initial compliance test will yield useful information. It is therefore recommended that testing be specified for permit demonstration and renewal; to demonstrate compliance in event of significant change in a process parameter (e.g. production rate, resin styrene content, new equipment, ventilation, etc) where results for previous testing suggest that compliance may not be achieved; and, "on demand" in the event of a persistent recurring problem.

10.4.3 Disper$iOn Modelling

It is recommended that permit applicants be required to show by dispersion modelling that a specified ambient air quality objective will not be exceeded, under maximum emission conditions. Such modelling should include the effect of other sources (fugitive emissions and/or neighbouring facilities) where applicable.

10.4.4 Use of Good Operating Practices

It is recommended that use of other good operating practices be incorporated by reference to regulations or good operating practices for all RP /C production facilities.

10.5 Good Operating Practices

10.5.1 BACT

It is recommended that facilities be required to apply BACT based on the California determination reproduced in Appendix VI. This BACT should be supplemented with the additional provisions described below: ·

Capture of Emissions

Operations giving rise to emissions should be performed within enclosures, ventilated at a rate sufficient to prevent escape of fugitive emissions. Where a building is used as the enclosure, the ventilation system should provide a capture velocity of 0.5 m/s at any openings to the exterior other than a stack (e.g. vents for makeup air), during the period of, and for 30 minutes following, application of resins (i.e. main access doors should be kept closed, and any doors needing to be opened during this time should be provided with vinyl curtains, double closures, additional ventilation, or other appropriate controls)

k The parameter best characterizing "production" rate is probably resin usage rate.


Restriction on Air Mixing

Use of air for mixing of resins (i.e. bubbling air through the resin) should be prohibited except where required for specific process reasons (oxygenation is used to prevent polymerization of some monomers), and then, only if the exit gases are treated to remove at least 95% of contaminants.

Restriction on Pressurized Transfers

The transfer of flammable or combustible liquids in a closed piping system by means of compressed air or other non-inert gas pressure should be prohibited. Use of inert gases for transfer, should be restricted to the conditions specified in article 4.4.10.6 of the National Fire Code of Canada [Ref 39] (requirements for construction, installation and testing of pressure vessels; use of pressure regulators and relief valves; and, means of automatically shutting off supply and bleeding gas pressure in event of fire).

Generator Registration

It should be noted that any facility generating more than 100 kg in 30 days of dirty acetone, is required to register as a special waste generator. Consideration should be given to drawing up a generic waste management plan serving as authorization under the Waste Management Act, to encourage on site reclaiming of acetone.

Particulate Collection

Facilities generating particulate should be required to install fabric filters or filter pads.

10.5.2 Dispersion

It is unlikely that the air quality standard suggested in section 10.2.3 can be met without proper dispersion of emissions. Permitted facilities should be required to install works sufficient to ensure that the specified air quality guideline is not exceeded, as demonstrated by the modelling studies (see section 10.4.3). Because non-permitted facilities would emit much smaller quantities, a generic dispersion design should be developed for these facilities, similar to that contained in the Antisapstain Chemical Waste Control Regulation'. Non-permitted facilities should then be given the option of installing works based on the generic design, or on modelling studies.

10.5.3 Zoning

If proper emission dispersion is used, zoning becomes less important. However, zoning controls are still probably necessary to prevent nuisance from fugitive emissions.

10.5.4 Record keeping and Reporting Requirements

It is recommended that all RP /C production facilities be required to keep a current list of resins and cleaning materials in use as per the California RACT /BARCT Determination. This includes the following as applicable:

resin, catalyst, and cleaning materials used,

the weight percent of voe in each of the resin materials, and the grams of voe per litre for the cleaning materials,

Emissions are required to be vented directly to the atmosphere by a stack, the top of which is at least 10 m above the ground and 5 m above the highest point of the roof of the building which houses the antisapstain chemical spray booth [Ref 40]. For RP /C manufacturing facilities, it is recommended that the design specify in addition: vertical discharge without raincap; a minimum discharge velocity (say 10 m/s); and, the top of the stack 5 m above the highest point of any building roof within a specified distance.


for approved vapour suppressed resins, the weight loss in grams per square metre during resin polymerization, the monomer percentage, and the gel time for each resin.

Permitted facilities should report usage of these materials to the Environmental Protection Division on an annual basis, whereas non-permitted facilities should for a period of two years have records available for inspection on request.

Estimation of voe Emissions from B.C. RP /Cs Manufacturing

Facility 1 Data:

O.StQ.

annual gelcoat and resin use, 36 206 kg annual acetone use, 2 608 kg

Assumptions: gelcoat usage 1 /7 of total resin gelcoat emission factor, 300 g/kg gelcoat styrene content, 35% resin emission factor, 100 g/kg resin styrene content, 42% all acetone is eventually emitted

Gelcoat styrene emission

Resin styrene emission

Estimated total styrene emissions

Estimated total VOC emissions

Acetone proportion of total VOC

Facility 2 Data:

average daily resin use," 3 500 lb (1 600 kg) monthly acetone purchases 2 400 L (1 900 kg)

Assumptions: resin emission factor, 100 g/kg resin styrene content, 42% 21 day working month all acetone is eventually emitted


Estimated acetone emission


Acetone proportion of total voe

[Appendix I] [Appendix I]

[Ref 13] [Table 4] [Table 5] [Table 4] [Table 5]

(36 206/7) x 0.35 x 300/1 000 543.0 kg/a (36 206 x 6/7) x 0.42 x 100/1 000 1 303.4 kg/a 543.0 + 1 303.4 1 846.5 kg/a (1.847 Mg/a) 1.846.5 + 2 608.0 4 454.5 kg/a (4.455 Mg/a) 2 608.0/4 454.5 0.585 or 58.5%


[Table 4] [Table 5]

1 600 x 0.42 x 100/1 000 x 21 x 12 16 900 kg/a (16.9 Mg/a) 1 900 x 12 22 800 kg/a (22.8 Mg/a) 16 900 + 22 800 39 700 kg/a (39. 7 Mg/a) 22.8/39.7 0.574 or 57.4%

K0061 92-11-19 92-12-4


11.0 REFERENCES

1 Ministry of Environment and Parks, Pollution Control Objectives for the Chemical and Petroleum Industries of British Columbia, Queen's Printer for British Columbia, Victoria, 1980.

2 Ministry of Environment and Parks, Pollution Control Objectives for Food-processing, Agriculturally Orientated, and Other Miscellaneous Industries of British Columbia, Queen's Printer for British Columbia, Victoria, 1987

3 Statutes of British Columbia 1982, Chapter 41, Waste Management Act, Office Consolidation, Queen's Printer for British Columbia, Victoria, 1990.

4 Workers' Compensation Board of British Columbia, Industrial Health and Safety Regulations, Richmond, 1 July 1980.

5 1991-1992 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conferen.ce of Governmental Industrial Hygienists, Cinncinnati, 1991.

6 British Columbia Regulations 63/88, Special Waste Regulation, Office Consolidation, Queen's Printer for British Columbia, Victoria, 1992.

7 Greater Vancouver Regional District, Air Quality Management Bylaw No. 725, 31 July 1992 8 Manufacturer's Directory 1991, Ministry of Finance and Corporate Relations. 9 Darrah, B., The Society of the Plastics Industry of Canada, Facsimile transmission to O.N.C. St

Quintin, 29 September 1992. 1 o Chapman, W., King Fiberglass Corp., Telephone conversation with O.N.C. St Quintin, 23 September

1992. 11 "Polyester Resin Plastics Product Fabrication", Section 4.12, Supplement B to Compilation of Air

Pollutant Emission Factors,AP-42, U.S. Environmental Protection Agency, Fourth Edition, September 1988.

12 Derakane Vinyl Ester Resins from Dow, Dow Chemical Company, Midland, 1983. 13 Assessment of VOC Emissions from Fiberglass Boat Manufacturing, U.S. Environmental Protection

Agency, EPA-600/2-90-019, May 1990. 14 WHMIS Manual and Material Safety Data Sheets, 2nd Edition, Gwil Industries, Burnaby, October

1991. 15 Guides to Pollution Prevention: The Fiberglass-Reinforced and Composite Plastics Industry, U.S.

Environmental Protection Agency, EPA/625 /7-91 /014, October 1991. 16 FRP: An Introduction to Fiberglas-Reinforced Plastics/Composites, Fiberglas Canada Inc, Toronto. 17 Lawrence, R. Worker's Compensation Board of British Columbia, Telephone conversation with

O.N.C. St Quintin, 7 October 1992. 18 Odor Thresholds for Chemicals with Established Occupational Health Standards, American

Industrial Hygiene Association, Akron, 1989. 19 Alexander, J.R., and Cassis, F., Letter to Ms Pat Leyden, Deputy Executive Officer, South Coast Air

Quality Management District, 26 February 1992. 20 Revised Statutes of Ontario 1980, Chapter 141, Environmental Protection Act, Office Consolidation,

Publications Ontario, October 1990. 21 Revised Regulations of Ontario 1980, Regulation 308, Office Consolidation, Publications Ontario,

October 1990. 22 Newdick, J., Ontario Ministry of Environment, Air Resources Branch, Telephone conversation with

O.N.C. St Quintin, 10 November 1992. 23 Bell, S., Ontario Ministry of Environment, Air Approvals, Telephone conversation with O.N.C. St

Quintin, 10 November 1992. 24 Nagy, G.Z., Ontario Ministry of Environment, Air Resources Branch, Odour Impact Model for Styrene 25 Buonicore, A.J., Theodore, L., and Davis, W.T. "Air Pollution Control Engineering", Air Pollution

Engineering Manual, Van Nostrand Reinhold, New York, 1992. 26 Shirley, B., State Update, State of the States, Styrene Information Research Council, Washington,

10 April 1992. 27 Boyd, D.P. et al., "Styrene: Perspectives on the Carcinogen Question", The SIRC Review, Volume

1, No 1, April 1990. 28 Cassis, F., Telephone conversation with O.N.C. St Quintin, 8 June 1992.


29 Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Polyester Resin Operations, Criteria Pollutants Branch, Stationary Source Division, California Air Resources Board, 8 January 1991.

30 Air Toxics •Hot Spots• Information and Assessment Act of 1987, Assembly Bill 2588, Part 6 to Division 26 commencing at Section 44300 of California Health and Safety Code, 27 September 1987.

31 Barcikowski, W., South Coast Air Quality Management District, Telephone conversation with O.N.C. St Quintin, 13 November 1992.

32 Gudlow, M., South Coast Air Quality Management District, Telephone conversation with O.N.C. St Quintin, 13 November 1992.

33 Lewis, D., Office of Environmental Health Hazard Assessment, Telephone conversation with O.N.C. St Quintin, 13 November 1992.

34 RECLAIM Summary Recommendations, South Coast Air Quality Management District, Spring 1992. 35 Timms, C.F., Jr, Heller, Ehrman, White & McAuliffe, Letter to Clients and Friends of the Firm Re: The

South Coast Air Quality Management Districrs Proposed RECLAIM Program, Los Angeles, 24 April 1992.

36 5th Edition Catalog, Venus-Gusmer, Kent, WA, 1988. 37 Environmental Protection Agency, Handbook: Control Technologies for Hazardous Air Pollutants,

EPA/625/6-91/014, Office of Research and Development, Washington, DC, June 1991. 38 Environmental Protection Agency, Corona Destruction: An Innovative Control Technology for VOCs

and Air Toxics, EPA/600/A-92/162, Air and Energy Engineering Research Laboratory, Research Triangle Park, 1992.

39 National Fire Code of Canada 1990, National Research Council of Canada, Ottawa, 1990. 40 Ministry of Environment, Lands and Parks, Antisapstain Chemical Waste Control Regulation. 41 OAQPS Control Cost Manual, Office of Air Quality Planning and Standards, EPA 450/3-90-006,

Research Triangle Park, January 1990.

APPENDIX I. Notes from Site Visits

1.0 1.1

92-12-4

GENERAL PLANT INFORMATION Name

SITE SURVEY NOTES

A/Janco International Environmental Products Ltd 1.2 Location/address

692 Derwent Way, New Westminster, BC, V3M 5PB 1.3 Contact

Mr Bernie Joyce

Page 1

Date of visit: 92-05-21

1.4 General Description (surroundings, prevailing wind, nearest residential neighbours, etc) Industrial area (Annacis Island); /nnova Envelope, north west side; steel fabricating shop south west side; industrial works north east side; rail line and Plastifab south east side; nearest residential areas over 1 km.

1.5 Hours of Operation 8 hour per day, 5 day per week

2.0 PRODUCTS 2.1 Types of Product (tanks, piping, boats, canoes, canopies, building materials, etc)

Various industrial parts, mainly fibre reinforced plastic components such as fans, ducting, ventilation hoods, etc.

2.2 Manufacturing Processes {hand layup, sprayup, continuous lamination, pultrusion, filament winding, closed or vacuum moulding, etc) Hand layup (very small, or awkward articles), and sprayup.

3.0 FACILITY LAYOUT

D ACETONE STORAGE

z 0 i=o: ::s 0 " -0· !z::c:: w >

~

I-z w > w 0 Ci.i -

TARPED RESIN APPLICATION

AREA

OFFICE

DERWENT WAY

92-12-4 SITE SURVEY NOTES Page 2

4.0 RAW MATERIALS

Material Product name Suppliers Usage Storage Dispensing

Resins

Polyester General King fibreglass 1 drum/mo 1 45 gal drum Mainly pumped direct from container. Some purpose resin or Gwil from small hand sprayer or painted for

gel coat

Derakane Gwil 100 gal/yr 5 gal pails As above

Monomers

Styrene King fibreglass 5 gal/yr 5 gal pail Into graduated cylinder

Catalysts

MEK peroxide Lucidol (30% King fibreglass - 1 gal/mo* In container By ratio to resin from plastic container on and 50%) resin pump, or squeeze bottle/graduated

cylinder for small quantities.

Fibres

1 1/2 oz, and 3 oz fab mat

Roving (20 oz)

Chopper strand

Cleaners

Acetone King fibreglass 1 drum/3 mo Drum in outside Hand pump from drum into poly pails, or block building; metal chopper gun cleaner reseNoir closed pails inside

Other

Fi re retard ant Antimony trioxide

Thickeners Talc; Cal;>osil

* Depends on temperature. -1% by volume at 70°F

92~12-4 SITE SURVEY NOTES

5.0 PROCESS 5.1 Mould Preparation

Not normally applicable - FRP work is mainly reinforcement of fabricated plastic items. 5.1.1 Mould type

As above. 5.1.2 Release agents

Parting wax if applicable. 5.1.3 Method of application

Waxed on and polished off, similar to car wax. 5.1.4 Enclosure

Tarped off area, with hood and floor ventilation from one side. 5.1.5 Emission controls

None (other than ventilation) 5.1.6 Cleanup (equipment and personnel)

Rags 5.1. 7 Waste recycling/disposal

Garbage 5.2 Resin Preparation

Page 3

Not normally required - in most cases pre-promoted resin is purchased. Some Derakane resins are not promoted. For spray application catalyst is added at the spray gun head.

5.2.1 Materials OMA and cobalt (promoters).

5.2.2 Measurement (proportioning and total quantity) Graduated cylinder if required.

5.2.3 Mixing Stirred.

5.2.4 Temperature Ambient.

5.2.5 Enclosure None.

5.2.6 Emission controls None, other than ventilation.

5.2.7 Cleanup (equipment and personnel) Acetone wash in 5 gal pail.

5.2.8 Waste recycling/disposal Bulk of acetone evaporates from collection drum. Residues accumulated and sent for disposal. Approx 3 years to accumulate 1 drum.

5.3 Gelcoat Application 5.3.1 Materials

Resin and catalyst. 5.3.2 Measurement (proportioning and total quantity)

Graduated cylinder. 5.3.3 Mixing

Stirred. 5.3.4 Temperature

Ambient. 5.3.5 Application

Preferably from air atomized pot sprayer (gives most even coating). Some painting. 5.3.6 Enclosure

None. 5.3. 7 Emission controls

None, other than ventilation. 5.3.8 Cleanup (equipment and personnel)

Acetone wash in 5 gal pail. 5.3.9 Waste recycling/disposal

Bulk of acetone evaporates from collection drum. Residues accumulated and sent for disposal. Approx 3 years to accumulate 1 drum.


5.4 Fibreglass Application Mainly using chopper gun. Some hand layup for small awkward items.

5.4.1 Materials Resin, catalyst and chopper strand.

5.4.2 Measurement (proportioning and total quantity) Adjustable slave pump on main resin pump to give desired ratio (1 to 2% catalyst by volume depending on temperature). Graduated cylinder for hand layup.

5.4.3 Mixing Static mixer in gun head for resin and catalyst. Fibre chopped by bladed wheel on head.


5.4.5 Application Airless spray.

5.4.6 Curing Ambient.


5.4.8 Emission controls None other than ventilation.

5.4.9 Cleanup (equipment and personnel) Burst of acetone through gun (- 1 sec). Acetone wash in 5 gal pail.

5.4.10 Waste recycling/disposal Bulk of acetone evaporates from collection drum. Residues accumulated and sent for disposal. Approx 3 years to accumulate 1 drum.

6.0 EMISSIONS REDUCTION 6.1 Raw Material Substitution

low monomer resins not investigated. alternate monomer resins (e.g. p-methyl styrene, vinyl toluene) not investigated. vapour suppressed resins not investigated. alternative cleaners (e.g. dibasic esters, emulsions) tried water diluted concentrate - not effective.

6.2 Process Modifications ' alternate application (e.g. air-assisted airless spray guns, brushing vs spraying) airless spray (Venus 9:1)

6.3 Operating Controls limitation on solvent issue none use of gloves yes covered containers lidded pails, not self-closing

92-12-4 SITE SURVEY NOTES

7.0 EMISSION CONTROL 7.1 System Operating Permit (copy if possible)

Do not have a permit 7.2 Emission Control Devices

Device Thermal oxidizer

Air flow rate

Design inlet cone

Design outlet cone

Capture efficiency

Discharge point (height, direction)

Adsorbent

7.3 Monitoring Data

Catalytic oxidizer

Periodically check cleanliness, speed, motor current draw flow rate no voes no

7.4 Operation startup/shutdown manual start, no interlocks equipment failure n/a cleaning (frequency, solvent use, etc) n/a complaints from public/other businesses

Page 5

Adsorber Extraction Fan (approx data)

5 000 cfm (17" inlet 14" x 15" outlet)

vertical stack, 6' above roof, ·no cap

none related to Coroban/Al!anco operations; some arising from operations at neighbouring steel (oil quenching of steel) and body shops

7.5 Costs

adsorbent disposal n/a

capital n/a operating n/a

1.0 1.1

1.2

1.3

1.4

1.5

1.6

2.0 2.1

2.2

3.0

92-12-4

GENERAL PLANT INFORMATION Name Canoe Cove Manufacturing Ltd Location/address 2300 Canoe Cove Road Contact

SITE SURVEY NOTES

Mr Donald Matheson (owner) or Mr Don Boyle (customer services)

Page 1


General Description (surroundings, prevailing wind, nearest residential neighbours, etc) Waterfront building adjacent to marina; Canoe Cove east side; marina (including Stonehouse Pub; some liveaboards within 200 m of facility) south side; Blackline Plastics north side (FRP repair operation); residential west side. Hours of Operation 7:00 am to 4:00 pm; occasionally afternoon shift in summer. Comments Mr Matheson feels that labour rates and regulations are forcing the industry out of Canada to locations such as Taiwan.

PRODUCTS Types of Product (tanks, piping, boats, canoes, canopies, building materials, etc) Yachts. Manufacturing Processes (hand layup, sprayup, continuous lamination, pultrusion, filament winding, closed or vacuum moulding, etc) Hand layup.

FACILITY LAYOUT

STONE HOUSE

PUB

N

ACETONE STORAGE

D L1J

MANUFACTURING ~

a:

~

CANOE COVE ROAD

CANOE COVE


4.0 RAW MATERIALS


Resins

Gel coat GWIL t 5 gal pails (isophthalic)

Prepromoted GWIL t 45 gal drums in resin* storage shed

I

Monomers

I I I I I I Styrenet GWIL 5 gal/yr?

Catalysts

MEK peroxide GWIL 1 to 2% of resin

I

Fibres

I I I I I I GWIL

Cleaners

Acetone Harcross Say 1/10 of 45 gal drums in Pumped into resin. acetone storage spring-closing Max 1Q'drum/yr fuel cans or

pails

Other

Release agent Oscar 500

Toluene** Harcross 45 gal drum in storage shed

Varsol** Harcross 45 gal drum in storage shed

* Promoted with BPO (?) and cobalt t In the past, annual production was typically 6 to 12 yachts, 42' in length. Current production

consists of fewer larger yachts. Typical usage for a 42' yacht would be 10 x 45 gal of resin and the equivalent of 5 x 45 gal of gel coat.

+ Occasionally used for cleaning or repairs. ** Not used in FRP operations (used for painting).

92-12-4

5.0 PROCESS 5.1 Mould Preparation 5. 1 . 1 Mould type

Female FRP mould - lasts 10 to 20 years. 5.1.2 Release agents

Wax - paste or liquid. 5.1.3 Method of application

Rag wiping. 5.1.4 Enclosure

None. 5.1.5 Emission controls

None. 5.1.6 Cleanup (equipment and personnel)

Negligible. 5.1.7 Waste recycling/disposal

Launder or garbage.


SITE SURVEY NOTES

Ge/coat + catalyst [initiator] (no thinners). 5.2.2 Measurement (proportioning and total quantity)

Gun proportions. 5.2.3 Mixing

In gun head. 5.2.4 Temperature

Shop ambient (oil heating to - 65°F when required). 5.2.5 Application

Airless spray gun. 5.2.6 Enclosure

5.2.7

5.2.8

None. Emission controls Two fans with 8" or 10" flexible ducting used to ventilate hulls during application of resins. Cleanup (equipment and personnel)

Page 3

Nozzles cleaned in acetone. Lines do not need to be cleaned, although recirculation used for gel sprayers to prevent internal seals from hardening.

5.2.9

5.3 5.3.1

5.3.2 5.3.3

5.3.4

5.3.5

5.3.6

5.3.7

5.3.8

5.3.9

5.3.10

Waste recycling/disposal Resin, dirty acetone to open drum in shed. Acetone evaporates, resin hardens. Residue to garbage. Fibreglass Application Materials Mat and roving only (no chopped strand). Measurement (proportioning and total quantity) Mixing N/A. Temperature Shop ambient. Application Cut to size and laid down. Resin sprayed on top. Curing Shop ambient. Enclosure None. Emission controls None, other than ventilation. Cleanup (equipment and personnel) As for gelcoat. Waste recycling/disposal As for gelcoat.


5.4 Resin Preparation 5.4.1 Materials

Resin and catalyst. 5.4.2 Measurement (proportioning and total quantity)

As for gelcoat. 5.4.3 Mixing

As for gelcoat. 5.4.4 Temperature

As for gelcoat. 5.4.5 Enclosure

As for gelcoat. 5.4.6 Emission controls

As for gelcoat. 5.4.7 Cleanup (equipment and personnel)

As for gelcoat. 5.4.8 Waste recycling/disposal

As for gelcoat.

6.0 EMISSIONS REDUCTION

6.1 Raw Material Substitution low monomer resins Not investigated. alternate monomer resins (e.g. p-methyl styrene, vinyl toluene) Not investigated. vapour suppressed resins

Page 4

Used to be used 20 years ago. Problem for boat building . . Suppressant layer (wax) has to be washed or ground off afterwards. alternative cleaners (e.g. dibasic esters, emulsions) Tried an alternative from GWIL (name?), but did not work.

6.2 Process Modifications alternate application (e.g. air-assisted airless spray guns, brushing vs spraying) Have replaced air atomized sprays with airless sprays. Cannot brush gelcoat because thickness of 25 mm needs to be built up in 5 mm layers. Brushing either produces layers which are too thick, or which brush off the waxed mould.

6.3 Operating Controls limitation on solvent issue No. use of gloves Yes, and masks. covered containers 1 gal tin for each worker (only 4 out of 30 do FRP application). Containers (holding perhaps 1 qt) generally covered with rag.



Do not know whether there is a permit. 7.2 Emission Control Devices

Device

~rflow rate

Design inlet cone

Design outlet cone

Capture efficiency


Adsorbent

7.3 Monitoring Data flow rate voes

Thermal oxidizer Catalytic oxidizer

Page 5

Adsorber Other 2 x fan

10" duct for each

Rain cap?

WCB officer is Bill McCaugherty (380-3418). Do not think that any sampling has been done. 7.4 Operation

7.5 Costs

startup/ shutdown N/A. equipment failure N/A. cleaning (frequency, solvent use, etc) N/A. complaints from public/other businesses Not aware of any current complaints. adsorbent disposal N/A.

capital N/A. operating N/A.


1.0 GENERAL PLANT INFORMATION Date of visit: 92-05~22 1.1 Name

Current Designs 1.2 Location/address

10124 McDonald Park Road, Sidney, BC, VBL 3X9 1.3 Contact

Messrs Campbell Black (president), Brian ?, Matthew Smith (vp marketing/sales, tour guide), Hank van der Griendt (production manager).

1.4 General Description (surroundings, prevailing wind, nearest residential neighbours, etc) Light industrial area; north side various industrial operations (e.g. lawn mower repair, etc) and racetrack beyond; west side various industrial operations (e.g. autobody, etc); south side warehousing and airport beyond; east side farm land; nearest residential area approx 0.5 km away across McDonald Park Road and Hwy 1 to the west. ·

1.5 Hours of Operation Most employees and parts of the operation 8:00 am to 4:30 pm; bagging 12:00 midnight to 6:00 am.


Kayaks, and some aircraft parts. 2.2 Manufacturing Processes (hand layup, sprayup, continuous lamination, pultrusion, filament winding, closed

or vacuum moulding, etc) · Vacuum moulding.

3.0 FACILITY LAYOUT

N

ACETONE STORAGE

D

ASSEMBLY &

FINISHING

STORAGE

(!} z :E us Cl) ..

MOULDING MEZZANINE

·--·-·· --···· SIDE VENT

l EXHAUST


4.0 RAW MATERIALS

* t


Resins

Gel coat GWIL -1 gal/boat* In pails Poured into -30 x 5 gal spray pots

Polyester -1V2 gal/boat* In drums Air pressure (some vinyl transfert to ester and pails. From Derakane) pails by wt.

Monomers

No pure monomer used

Catalysts

MEK peroxide DOM 30 GWIL 1to2%of In jugs From squeeze DOM 9 gelcoat or resin bottle (by vol)

depending on temp

Fibres

16 and 18 oz GWIL roving

Biaxial strip GWIL

Cleaners

Acetone GWIL 3 gal/week? 1 drum outside Gravity through Ask HvdG gate valve

Xylene* GWIL Ask HvdG

Other

Mould release GWIL agent Fire retardant Sealants and caulking agents

Product/On about 40 to 60 boats per month. Although not within the mandate of this assignment, site personnel were made aware that air pressure transfer can be hazardous if not conducted with proper safeguards. [See National Fire Code section 4.4.10.6 for required safeguards. Section 4.4.10.7 prohibits use of non-inert gas for transfer of flammable or combustible liquids.] Used in some applications to avoid residue left by acetone.

92-12-4

5.0 PROCESS 5.1 Mould Preparation

Manufactured from FRP. 5.1.1 Mould type

Vacuum mould 5.1.2 Release agents

F57 (wax type material) 5.1.3 Method of application

SITE SURVEY NOTES

Every 2-3 days, applied with cheesecloth. 5.1.4 Enclosure


None other than general ventilation. 5.1.6 Cleanup (equipment and personnel)

Wash for personnel, garbage tor rags. 5.1. 7 Waste recycling/disposal

None.


Resin and catalyst [initiator]. 5.2.2 Measurement (proportioning and total quantity)

Volume (resin) and squeeze bottle (catalyst). 5.2.3 Mixing

Stirring. 5.2.4 Temperature


High volume, low pressure spray gun. 5.2.6 Enclosure


None other than general ventilation; personnel wear gloves and respirator. 5.2.8 Cleanup (equipment and personnel)

Acetone bucket for gloves and gun. 5.2.9 Waste recycling/disposal

Dirty acetone - ask HvdG.

5.3 Fibreglass Application

Page 3

Vacuum moulded fibre applied as described below. Biaxial strip for sealing joint between two hull halves applied as hand layup.

5.3.1 Materials Roving.

5.3.2 Measurement (proportioning and total quantity) Cut as required.

5.3.3 Mixing N/A.

5.3.4 Temperature Inside ambient.

5.3.5 Application Laid over gelcoat. Covered with membrane and vacuum applied to position.

5.3.6 Enclosure Not applicable.

5.3. 7 Emission controls Not applicable.

5.3.8 Cleanup (equipment and personnel) Not applicable.


5.4 Resin Preparation and Application 5.4.1 Materials

Resin and catalyst [initiator]. 5.4.2 Measurement (proportioning and total quantity)

Weighing. · 5.4.3 Mixing

Stirring. 5.4.4 Temperature


Vacuum released, and resin poured over fibre cloth. Vacuum reapplied and resin worked into fibre by combination of vacuum and squeegee wiping action.

5.4.6 Curing Approx 2 hours at indoor ambient.

5.4.7 Enclosure Enclosed by plastic membrane.

5.4.8 Emission controls Evacuated by vacuum pump to general ventilation.

5.4.9 Cleanup (equipment and personnel) Minimal required.

5.4.10 Waste recycling/disposal Membrane mould closure to garbage. Excess resin (if any) collected in bottles and disposed to garbage when cured.


low monomer resins Ask HvdG.

alternate monomer resins (e.g. p-methyl styrene, vinyl toluene) Ask HvdG.

vapour suppressed resins Ask HvdG.

alternative cleaners (e.g. dibasic esters, emulsions). Ask HvdG.

6.2 Process Modifications alternate application (e.g. air-assisted airless spray guns, brushing vs spraying)

Use of vacuum moulding, and high volume/low pressure spray gun for gelcoat. 6.3 Operating Controls ·

limitation on solvent issue None.

use of gloves Use of gloves mandatory.

covered containers Generally covered with lids.



Ask CB. 7.2 Emission Control Devices

Device Thermal oxidizer

Air flow rate

Design inlet cone

Design outlet cone

Capture efficiency


Adsorbent

7.3 Monitoring Data flow rate

Catalytic oxidizer

Page 5

Adsorber Other (Fan)

Ask CB

South side, horiz at top of building

Ask CB. [Estimate flow rate at 5 000 cfm, based on area of side vent and guestimated face velocity.] voes

Workplace sampling done by WCB - ask CB for name of hygiene officer. 7.4 Operation

startup/shutdown N/A

equipment failure N/A

cleaning (frequency, solvent use, etc) N/A

complaints from public/other businesses None.

adsorbent disposal N/A

7.5 Costs capital

N/A operating

N/A


1.0 DISCLAIMER

2.0 2.1

2.2

2.3

2.4

2.5

3.0 3.1

3.2

4.0

The site survey recorded in these notes, was conducted purely as a means of familiarization with air emissions from the FRP manufacturing industry. No comment or lack of comment in these notes should be construed as an approval with respect to air emissions or any other regulatory requirements.

GENERAL PLANT INFORMATION Name /CL Engineering Ltd .

. Location/address 10111 River Drive, Richmond, BC, V6X 1Z2 Contact Mr Bill Prinz (Production Manager)


General Description (surroundings, prevailing wind, nearest residential neighbours, etc) North, North Arm of the Fraser River; west, Crane Woodcraft; south, residential (less than 0.25 km); east, vacant. Hours of Operation Normally 5 day week, 2 shift, 7 am to 11 pm; occasionally 3 shifts and/or weekends.

PRODUCTS Types of Product (tanks, piping, boats, canoes, canopies, building materials, etc) Mainly tanks and piping; some other miscellaneous corrosion resistant articles such as hoods. Manufacturing Processes (hand layup, sprayup, continuous lamination, pultrusion, filament winding, closed or vacuum moulding, etc) Filament winding, hand layup and sprayup.

FACILITY LAYOUT

FRASER RIVER (NORTH ARM)

DIRTY D ACETONE

STILL

N

ACETONE STORAGE

OTHER STORAGE

I

) FLANGE SHOP

...

c:::::J WINDING MACHINE

-+---+- DOORWAY

± - t

I ' --- -----

.. ...

~ D ~ :~ OFFICES (UPSTAIRS)

RIVER DRIVE

~ 0 FAN (VERTICAL DISCHARGE)

+o FAN (HORIZONTAL DISCHARGE)

±

..

~H

NOTES:

(I) NOT TO SCALE

EAST BLDG

(ll) MAY NOT SHOW ALL EXHAUST FANS


5.0 RAW MATERIALS

* t


Resins

Polyester Atlac 382 GWIL Cubitainers Bottom valve or Vibrin 1519 ) 2 000 pumped from top

) to Vinyl ester Derakane(s) GWIL ) 5 000 lb/day Drums Molasses valve or

pumped

Monomers

Styrene* GWIL 1-2 drums/month Drums Safety cans

Catalysts

MEK peroxide Lucidol GWIL Jugs Slave pump or jigger (batch)

Cumene GWIL Cans hydroperoxide* ) 1 to 2o/o

) depending on Benzyl GWIL ) temperature Tubs (paste) peroxide*

Rb res

Glass strand GWIL

Glass mat GWIL

aeaners

Acetone GWIL 12 drums/montht Drums Air-operated pump

Other

Fi re retardant* Sb20 3 GWIL 3% on resin, when used (1o/o of products)

UV stabilizer GWIL 1 o/o on resin (outer coat only)

Promoters Dimethylaniline GWIL Cobalt GWIL naphthanate

Fillers Fumed silica GWIL

Cure retarder 2-4 pentane GWIL dione

Occasional use on/ y Net usage, based on purchases of acetone. In addition, approximately one drum of acetone recovered per week by distillation. Note: These quantities of acetone suggest that !CL should be registered as a special waste generator (registration quantity of 100 L for class 3.1), and permitted as a treatment facility. Use of some alternatives to acetone may avoid the need for such registration and permitting.

92-12-4

6.0 PROCESS 6.1 Mould Preparation 6.1.1 Mould type

Mandrel. 6.1.2 Release agents

SITE SURVEY NOTES

Mainly mylar film, with waxing for some critical dimensions (e.g. forming of pipe joint "bell'J. 6.1.3 Method of application

Wrap or wipe. 6.1.4 Enclosure


Ventilation. 6.1.6 Cleanup (equipment and personnel) 6.1. 7 Waste recycling/disposal

To garbage. 6.2 Resin Preparation

Page 3

Most resin is prepromoted, in which case see sections 6.4 and 6.5 on FRP Application. Information following applies only to resins promoted in-house.

6.2.1 Materials Resin, dimethyl aniline, cobalt naphthanate, cure and/or fire retardants, UV stabilizers, etc.

6.2.2 Measurement (proportioning and total quantity) Additives added to resin drums.

6.2.3 Mixing Air-operated drum mixers and air sparging. No process requirement (e.g. oxygenation) for air sparging (unnecessarily releases volatiles).



6.2.6 Emission controls None.

6.2.7 Cleanup (equipment and personnel) None required.

6.2.8 Waste recycling/disposal Disposal of "empty" drums.

6.3 Corrosion Liner Application Corrosion finer is an initial application of pure resin without fibre reinforcement. Ge/coating very rarely used.

6.3.1 Materials · Resin and catalyst [initiator].

6.3.2 Measurement (proportioning and total quantity) Air operated pump for resin, with slave pump for catalyst.

6.3.3 Mixing Static mixer in gun head.


6.3.5 Application Spray.


6.3. 7 Emission controls Ventilation.

6.3.8 Cleanup (equipment and personnel) Acetone wash.

6.3.9 Waste recycling/disposal Acetone recycled (and evaporates). Floor cardboard to garbage (approx once per week).


6.4 Fibreglass Application (Filament Winding) Filament winding as described below. Layers of chopped strand applied by conventional sprayup.

6.4.1 Materials Resin, catalyst and glass strand.

6.4.2 Measurement (proportioning and total quantity) Air operated pump for resin, slave pump for catalyst, at rate as picked up by passage of strands through resin bath.

6.4.3 Mixing Static mixer in resin gun head. Extension piece on resin gun directs mixture to shallow bath through which strand is pulled.

6.4.4 Temperature Shop ambient.

6.4.5 Application Wound on with shuttling carriage.

6.4.6 Curing Shop ambient.


6.4.8 Emission controls Ventilation.

6.4.9 Cleanup (equipment and personnel) Acetone.

6.4.1 o Waste recycling/disposal Acetone recycled (and evaporates). Waste resin and stiff bottoms from recycling catalysed and disposed to landfill. Pipe ends to landfill.

6.5 Fibreglass Application (Non-Filament Wound Parts) Conventional hand layup and sprayup used for all non-filament wound parts-e.g. tank bottoms and heads, flanges, etc.)


low monomer resins alternate monomer resins (e.g. p-methyl styrene, vinyl toluene) Resins genera/ly specified by customer on basis of required product properties (usually corrosion resistance). vapour suppressed resins Problem with secondary bonding. Final coat (painted on) contains added wax as a surface "inhibitor" to exclude oxygen and so promote full curing. alternative cleaners (e.g. dibasic esters, emulsions) Have tried DBE. Workers did not like DBE. Problems with seeing double reported. Have not tried emulsions, but understand that cleanup is more labour intensive.

7.2 Process Modifications alternate application (e.g. air-assisted airless spray guns, brushing vs spraying) Airless spray guns only.

7.3 Operating Controls limitation on solvent issue None. use of gloves Yes, where contact involved. covered containers Generally, yes.

92-12-4 SITE SURVEY NOTES Pages


No permit, but are periodically in contact with GVRD concerning odour complaints from neighbours. Requirement to close doors during major winding operations is a response to these complaints (not completely successful).

8.2 Emission Control Devices

Device Thermal oxidizer Catalytic oxidizer Adsorber Other,.....Exhaust Fans

Air flow rate See table

Design inlet cone

Design outlet cone

Capture efficiency

Discharge point Generally horizontal, (height, direction) often at ground

level*

Adsorbent

* Have prevt0usly considered a stack discharge. Regulators felt that this would merely transfer the problem further afield.

8.3 Fan Air Flows

Exhaust Units

#9 Winder Exhaust

#11 Winder Exhaust

#2 Winder Exhaust

#17 Winder Exhaust

Sloped roof 48"

Roof exhaust fans, 4 units, 2 in each bay (#9 & #1) and (#17 & #2)

Flange shop fan

East building 2 tube-axial fans

Makeup Units

Makeup air #2 Winder



* All values approximate, based on fan suppliers data without ducting.

8.4 Monitoring Data flow rate None. voes Measured by WCB (Peter Villanyi).

Free Air Delivery* (cfm)

7 500

7 500

10 000

16 495

31 600

6187

8 000

10-14 000

7 500

7 500

7 500


8.5 Operation

8.6 Costs

startup/shutdown N/A. equipment failure N/A. cleaning (frequency, solvent use, etc) N/A. complaints from public/other businesses 2 to 3 per year. GVRD (Grant McGil/ivray) follows up complaints to determine if any unusual operations or occurrences took place. Occasionally, a drum of resin wilf polymerize, with considerable evolution of heat/smoking/unpleasant odour. adsorbent disposal N/A. other Cutting and grinding operations generate significant quantities of particulate. No particulate capture devices, as evidenced by layer of cream coloured dust distributed along the north side of the plant.

Acetone sti/f - approx 2 years old. capital $25 000 equipment (-$40 000 installed}. operating electricity + v.i man.


1.0 DISCLAIMER The site survey recorded in these notes, was conducted purely as a means of familiarization with air emissions from the FRP manufacturing industry. No comment or lack of comment in these notes should be construed as an approval with respect to air emissions or any other regulatory requirements.

2.0 GENERAL PLANT INFORMATION Date of visit: 92-06-11 2.1 Name

Marine Plastics Ltd 2.2 Location/address

2664, Bedford Street, Port Coquitlam, V3C 3K6 2.3 Contact

Messrs Don Hings, Peter Binley 2.4 General Description (surroundings, prevailing wind, nearest residential neighbours, etc)

Mixed industrial/residential: north, Coquitlam Glass; east, vacant for two blocks; south, residential. 2.5 Hours of Operation

Mainly 5 days per week, 7 am to 4:30 pm; occasionally additional shifts or days.


Large open mould parts, each 100+ lb: at the time of visit, production mainly of truck body parts (e.g. hoods, wind deflectors, etc.) Production has included items such as rail car covers.

3.2 Manufacturing Processes (hand layup, sprayup, continuous lamination, pultrusion, filament winding, closed or vacuum moulding, etc) Sprayup.

4.0 FACILITY LAYOUT

tu w a: t; 0 a: 0 u. 0 w m

LE~El':IQ

++DOORWAY

D INLET

0 EXHAUST

--

--

I D

OFFICES

D 0

I BAKE 0 OVENS

D 0

N

OsoLVENTS

~] COMPRESSOR

D

DACETONE/ CATALYST

D ACETONE STILL


5.0 RAW MATERIALS

I

I

* t + §

# ®

Material Product name Suppliers Usage Storage

Resins

Pre promoted GWIL 36 206 kg Mainly isophthalic Ashland 91-03-01 to 92-02-29 cubitainers, polyester resins Reichhold* some in drums and gelcoats

Monomers

I I I I Styrene/wax Airdryt 5 gal/yr?

Catalysts

MEK peroxide Lucidol 1 - 2% on resin Jugs

Benzyl V2 lb per year? Tubes peroxide

Fibres

I I I I Oeaners

Acetone 2 608 kg* 91-03-01 to 92-02-29

Other

PVA Mould release Minimal

Lacquer thinners§

Auto body putties

Silica fillers

Fire retardants#

Ethyl acetate©

Reqwres promotmg: mixed m 5 gal pat/ by volume, and then stirred Used to give tack-free surface Net usage, not including recycled acetone Surface wipe to inspect for porosity Usually use different resins where required (e.g. ferry or architectural parts) Catalyst diluent

Page 2

Dispensing

Direct from containers or from pressure pots for some colours

I I

Air pressure differential at gun controls rate

I I


6.0 PROCESS 6.1 Mould Preparation .

Male form made or supplied. Used to fabricate FRP female mould as per steps for part production. 6.1.1 Release agents

Te/ton spray. Initially five or six applications to condition mould surface. Thereafter, only required evef}' three or four parts.

6.1.2 Method of application Spray.


6.1.4 Emission controls None other than ventilation.

6.1.5 Cleanup (equipment and personnel) Minimal.

6.1.6 Waste recycling/disposal Minimal.


Ge/coat + catalyst [initiator}. 6.2.2 Measurement (proportioning and total quantity)

Air differential pressure. 6.2.3 Mixing

Turbulator in gun head. 6.2.4 Temperature

Shop ambient. 6.2.5 Application

Air assisted airless spray, Glascraft "air assisted containment" (AAC). 6.2.6 Enclosure


None other than general ventilation. 6.2.8 Cleanup (equipment and personnel)

Wash guns .and gloves in acetone. 6.2.9 Waste recycling/disposal

Acetone recycling on site (rate to be advised). Still bottoms evaporated to df}'ness and disposed with garbage.

6.3 Resin/Fibreglass Application Resin generally used direct from container. Reichhold resins require promoting. Some preparation when adding fillers for tool production. Air-operated mixers used.

6.3.1 Materials Resin, catalyst, and glass strand.

6.3.2 Measurement (proportioning and total quantity) Air pressure differential.

6.3.3 Mixing Turbulator with air injection in gun head.

6.3.4 Temperature Shop ambient.

6.3.5 Application Airless spray (but some air injected - see 6.3.3 above.

6.3.6 Curing Two stage post curing at 160°F and 230°F in enclosed bake oven (hot room). Direct flame heating of recirculated air.

6.3. 7 Enclosure None during application of resin/FRP. Enclosed during post curing.

6.3.8 Emission controls None during application of resin/FRP. Combustion of any emissions from post curing assumed to occur during direct flame heating of recirculated air.

92-12-4

6.3.9 Cleanup (equipment and personnel) As for ge/coat.

6.3.10 Waste recycling/disposal

SITE SURVEY NOTES Page 4

As for gel coat. Overspray (cardboard scraped every two to three days; changed approx every two weeks) and trim ends to garbage.


low monomer resins alternate monomer resins (e.g. p-methyl styrene, vinyl toluene) Customer specifies required resins. Strive for low styrene to reduce shrinkage. vapour suppressed resins Have conducted tests, but have not been satisfactory owing to problems with secondary bonding (significant requirement for strengthening ribs, etc.). Will continue to try alternatives as they become available. alternative cleaners (e.g. dibasic esters, emulsions) Have tried emulsion cleaners, but apart from lower effectiveness than acetone, also experienced problems of "water explosions" during post curing. Tried DBE: speak to Daryl Devries about experience.

7.2 Process Modifications alternate application (e.g. air-assisted airless spray guns, brushing vs spraying) Company has a policy of continuously "upscaling". Weights of all products recorded and compared against raw material usage, as a tool to improve manufacturing efficiency.

7.3 Operating Controls limitation on solvent issue No. use of gloves . Issued to all workers. Use not mandatory, and varies depending on type of operation being carried out. covered containers Yes-metal safety cans.


Obtained from GVRD. 8.2 Emission Control Devices

Exhaust fans. 8.3 Monitoring Data

Fan East Wall Duct*

Discharge rate 431.3 (std m3 /min)

Total particulate 0.7 (mg/m3)

Styrene cone (mg/m3)

61.4

Discharge point Vertical, with (height, direction) opening flap?

South Wall Duct*

126.7

0.7

55.7

Vertical with opening flap?

* Avera es based on sam fin g p g conductedb y

t converted to metric units. Not specified in permit.

North Wall Combined* GVRD Duct* Permit

92.3 650.3 627.0

0.9 0.7 t

55.9 59.5 t

Vertical with opening flap?

B.H. Leve/ton , )<Associates Ltd durin g June 19 77, and


8.4 Operation

8.5 Costs

startup/shutdown equipment failure cleaning (frequency, solvent use, etc) Not applicable. complaints from public/other businesses One notable incident in 1977 when residential neighbours claimed a variety of ill effects resulting from operations at the plant. Investigated and/or sampled by GVRD, WCB, Medical Health Officer and B.H. Leve/ton and Associates. Measurements showed low levels of emissions, from which MHO concluded that no health risk was posed by plant operations: odour was noted as a problem owing to the very low odour threshold for styrene. adsorbent disposal Not applicable.

capital $11 000 to $12 000 (?)for acetone recycling still. Number to be advised by Daryl Devries. operating

APPENDIX II. Estimation of VOC Emissions from B.C. RP /Cs Manufacturing

Estimation of VOC Emissions from B.C. RP/Cs Manufacturing

Faclllty 1 Data:

O.StQ.

- annual gelcoat and resin use, 36 206 kg - annual acetone use, 2 608 kg

Assumptions: - gelcoat usage 1n of total resin

gelcoat emission factor, 300 g/kg gelcoat styrene content, 35% resin emission factor, 100 g/kg resin styrene content, 42% all acetone is eventually emitted



Estimated total styrene emissions



Faclllty 2 Data:

- average daily resin use, 3 500 lb (1 600 kg)


[Ref 13] [Table 4] [Table 5] [Table 4] [Table 5]

(36 206/7) x 0.35 x 300/1 000 = 543.0 kg/a = (36 206 x 617) x 0.42 x 100/1 000

1 303.4 kg/a 543.0 + 1 303.4

= 1 846.5 kg/a (1.847 Mg/a) = 1.846.5 + 2 608.0

4 454.5 kg/a (4.455 Mg/a) = 2 608.0/4 454.5 = 0.585 or 58.5%

- monthly acetone purchases 2 400 l (1 900 kg) [Appendix I] [Appendix I)

Assumptions: - resin emission factor, 100 g/kg - resin styrene content, 42% - 21 day working month - all acetone is eventually emitted


Estimated acetone emission



[Table 4] [Table 5]

1 600 x 0.42 x 100/1 000 x 21 x 12 = 16 900 kg/a (16.9 Mg/a) = 1900x12 = 22 800 kg/a (22.8 Mg/a) = 16 900 + 22 800 = 39 700 kg/a (39.7 Mg/a) = 22.8/39.7

0.574 or 57.4%

K0061 92-11-19 94-1-11

Estimation of VOC Emissions from B.C. RP /Cs Manufacturing

O.StQ.

Provincial Emissions Assumptions:

annual RP /C production, 7 000 Mg percentage resin in products, 50% fraction of products using gelcoat, 0.70 gelcoat usage 1 /7 of total resin, where used gelcoat emission factor, 300 g/kg gelcoat styrene content, 35% resin emission factor, 100 g/kg resin styrene content, 42% acetone emissions, 50% of total emissions

Annual usage of resins

Annual usage of gelcoat

Annual usage of resins


and Resin styrene emission

B.C. styrene emissions

Total B.C. VOC emissions

[Refs 10]

[Guestimate] [Ref 13] [Table 4] [Table 5] [Table 4] [Table 5] [Calculations above, and Ref 13]

7 000 x 0.50 3 500 Mg/a 3 500 x 0.70/7 350 Mg/a 3 500 - 350 3 150 Mg/a 350 x 0.35 x 300 /1 000 36.75 Mg/a 3 150 x 0.42 x 100/1 000 132.3 Mg/a 132.3 + 36. 75 169.05 Mg/a, say 170 Mg/a 170/0.5 340 Mg/a

K0061 92-11-19 92-12-4

APPENDIX Ill. Ranging Calculation for Emission of Particulate

O.StO.

Assumptions:

Ranging Calculation for Emission of Particulate

manufacture of 20' (6.1 m) lengths of FRP piping, or manufacture of 100' (30 m) tanks cut thickness 1 mm for trimming each end, or material removal of 5 mm for trimming each end.

Greatest emission factor during removal of greatest amount of material from smallest object. · greatest emission factor 1 000 x 2 x 0.005/6.1 (trimmed at both ends)

1.6 g/kg

Smallest emission factor during removal of smallest amount of material from largest object. · smallest emission factor 1 000 x 2 x 0.001 /30 (trimmed at both ends)

0.07 g/kg

K0061 92-11-9 92-12-4

APPENDIX IV. Ontario Ministry of Environment Odour Impact Model for Styrene

St1Jre1:1e

ee

Compound: styrene iaternate Names:

1

CAS No.: [108-10-1] Density: o.so Molecular Weight~ 104 Supplier: Aldrich Grade: Gold Label Lot No.: Ol614EP stated Purity; 99.0%+

Odour Impact Model

Panel Test l 1 1 2 2 1 2 2

Geometric Mean Pooled "vah:te:

Detection 1300 1200 1400 1400 1300 1500

Hedonic Tone: unplec:tsant

Complaint 3400 µ,g/'IT13 4800 µg/m3 3400 µg/m3 3800 µ.g/m3 3800 µg/m3 5800 µg/m3

.1.09

'8

6

2

APPENDIXV. Summary by State of Regulatory Guidelines for Styrene

s I R c

tale A P R I L I 0, I 9 9 2

STATE OF THE STATES

Note: The states continue to be active in moving forward on air toxics initiatives, and in implementing the Federal Clean Air Act Amendments of 1990. The Clean Air Act Amendments regulate styrene emissions both as an unwanted ozone precursor and as an air toxic. Since styrene may react with other substances in the presence of sunlight to fonn ozone, styrene is regulated as a volatile organic compound (VOC) under the ozone non-attainment program. Under this regulatory program, states develop implementation plans limiting emissions of VOCs from various industrial operations.1

Styrene is one of the listed substances in the Clean Air Act Amendments. A major source is one which emits 10 tons per year of any one listed air toxic or 25 tons per year of any combination of air toxics. The Clean Air Act Amendments thus initially regulate toxic emissions through technology-based standards. However, EPA must report to Congress by November 15, 1996 on residual risk related to emissions of any air toxic. Beginning in 2001, EPA must promulgate residual risk standards for sources of air toxics which continue· to pose a risk to health.

In contrast to the technology-based emission standards which will be imposed by the Clean Air Act Amendments, many states currently regulate or are developing regulations of air toxics which establish health based emission standards.2 Typically, these state regulations establish fence-line standards for non-carcinogenic air pollutants based on an occupational exposure level such as the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) divided by a time adjustment and safety factor. For carcinogenic air pollutants, . states will usually develop fence-line standards based on an estimate of the carcinogenic potency of the substance (states frequently use EPA unit risk factors) and the level of risk which the state deems acceptable (usually one in one million).

Ironically, while the Clean Air Act Amendments seek to expedite regulation of air toxics by developing technology-based emissions limitations and postpone health-based regulation for 10 years, the states continue to impose health-based emission standards on sources of socalled toxic emissions. For the most part, the states have indicated that they will continue to regulate sources using their health-based emission standards during the period before the

S I H Cl A publi~ation of the Styrene lnforma.tion and Research Center (SIRC), a special purpose group of The Society of the Plastics Industry, Inc.

/ , J 1275KStreet,NW,Suite400Washington,DC20005, (202)371-5314 Fax(202)371-1784

. I I I

technology-based standards of the Clean Air Act Amendments are effective. Significantly, many states are expected to continue operating their health-based emission standards even after the MACT (Maximum Achievable Control Technology) standards become effective based on an unproven assumption that MACT will not protect their citizens from a residual health risk.

Several states have unpublished guidelines regulating styrene as a carcinogen. SIRC is working with these states to change their unpublished guidelines by showing that the scientific data does not support the regulation of styrene as a carcinogen. Many of these states rely on the HEAST, the Health Effects Assessment Summary Tables, as their mechanism to establish the health effects of chemicals. Now that EPA has agreed to remove styrene from HEAST as a B2 ''probable human carcinogen", SIRC will be able to readdress these states and request the removal of styrene from their list of carcinogens.

Members may obtain farther information on both the proposed and existing air toxics programs in their states by contacting Betsy Shirley, Director, SIRC at 2021371-5355. (Please note SIRC's new fax number: 2021371-1784).

Members are always encouraged to contact Ms. Shirley with relevant information on any state of which they have knowledge.

ALABAMA

The State uses fence-line guidelines for the regulation of new and modified sources of styrene. The State has established a daily guideline based on the ACGIH 1L V of 1.2 ppm and an annual guideline of 0.12 ppm for styrene. When the State implements the Clean Air Act Amendments it will discontinue use of the guidelines. Due to the pressing need to implement the Clean Air Amendments, the State has decided to discontinue development of its own air toxics program which would have imposed health-based standards on sources.

ALASKA

The State plans to begin proposing regulations in 1992 to implement the non-attainment and air toxics provisions of the Act. With the exception of a few petroleum industry issues, the State plans to be no more stringent than the Federal EPA. In keeping with the Federal mandate, Alaska's standards will initially be technology based.

ARIZONA

The State uses fence-line guidelines for the regulation of~ and existing sources of styrene. The State has established a 24-hour guideline of 0.4 ppm and a I-hour guideline of 0.8 ppm

2

ARIZONA CONT.

based on the ACGIH TL V divided by a time adjustment and safety factor. The state is not likely to abandon its present air toxics program when it implements the Clean Air Act Amendments, as it seeks to keep the program oriented towards health based standards, rather than technology driven.

ARKANSAS

Arkansas currently regulates ~ and existing sources of styrene. The State first performs a level I analysis which models ambient air levels for styrene at the fence-line to determine if they exceed 0.5 ppm. If the source fails the level I analysis the source may demonstrate that the fence-line concentration will not adversely affect health. If the source can not make such a showing it must implement control techniques equivalent to the Lowest Achievable Emission Rate (LAER). Existing sources are identified for control when their operating permits come up for renewal. New sources are regulated through construction permits. State implementation of the Clean Air Act Amendments will supersede Arkansas regulations in those areas where the amendments mandate Maximum Achievable Control Technology.

CALIFORNIA

The California Air Resources Board (CARB) and its counterparts at the Office of Environmental Health Hazard Assessment (OEHHA), formerly called the Department of Health Services (DHS), are continuing their review of both the exposure data and health effects of styrene as part of a

- lengthy review process which is expected to continue over the next 14-20 months. The two agencies are expected to present an initial proposal during 1992 which will encompass both sets of data. In a separate issue, CARB is tentatively planning a hearing for S~ptember 10, 1992, concerning new test methods for measuring styrene in ambient air.

COLORADO

Colorado is currently evaluating a draft air toxics regulation wbjch would regulate new and modified sources of 120 substances including styrene through the imposition of fence-line standards. The proposed fence-line standard for styrene of .00041 ppm is based on the incorrect assumption that EPA has classified styrene as a probable human carcinogen. In February 1992, SIRC submitted comments to the State which make clear that EPA has not classified styrene as a carcinogen and that the scientific data does not support Colorado's proposed fence-line standard for styrene.

3

CONNECTICUT

Connecticut currently regulates styrene as a non-carcinogenic air pollutant with a fence-line standard of 1 ppm. However, Connecticut has developed a list of prioritized substances for ··~· which the State plans to develop ambient air quality standards (AAQS). Styrene is the fourth ranked substance on the list due to the volume of styrene emitted and its classification on the prioritized list as a carcinogen. It appears that Connecticut relied on an EPA Office of Air Quality Planning and Standards draft document or the SARA Section 313 data, both of which list styrene as a carcinogen. SIRC will submit written information to the state showing that EPA has not classified styrene as a carcinogen in an effort to avoid a lower fence-line standard and a negative classification for styrene.

DELAWARE

A draft air toxics regulation published in April 1990 erroneously listed styrene as a carcinogen. SIRC has been working with the state to correct the error. The draft has been ·dramatically revised, and is expected to be published in the beginning of May 1992. The State was not willing to disclose the styrene classification at this time. The State is expected to hold public workshops and hearings by summer, 1992.

FLORIDA

Florida currently has guidelines for the regulation of new and modified sources of styrene. _ Styrene is not regulated as a carcinogen. The State has established an 8-hour fence-line guideline of 0.5 ppm and a 24 hour guideline of 0.12 ppm. Florida plans to promulgate a proposed air toxics rule in 1992.

GEORGIA

Georgia uses an ambient air guideline approach for controlling toxic emissions from new and modified sources. The State has established a fence-line guideline for styrene of 0.5 ppm. If a facility's fence-line concentration exceeds the guideline the State negotiates with the facility to install control technology to reduce the concentration.

HAWAII

Hawaii does not currently regulate styrene as a toxic air pollutant.

IDAHO

Idaho has guidelines for the regulation of new sources. New sources are incorporated into the air toxics program through construction permits. Currently, Idaho grants permits for reinforced

4

IDAHO CONT.

plastic manufacturers based on the application of Reasonably Available Control Technology (RACT). During the permitting of the most recent facility, Idaho required the use of low styrene emission resin as meeting the intent of RACT. Previously, the state had a fence-line guideline for styrene of 0.4 ppb which is based on an EPA draft classification of styrene as a probable carcinogen. However, after repeated SIRC contacts with state officials, Idaho abandoned this approach.

ILLINOIS

Illinois' latest air toxics proposal deletes styrene from the list of substances to be regulated. Styrene had been listed as a carcinogenic air toxic in a previous version of the proposal but was deleted in response to SIRC written comments and hearing testimony. SIRC submitted comments on the latest proposal and testified at a January 1992 hearing before the Illinois Pollution Control Board (IPCB) supporting styrene's deletion from the list. Unfortunately, the Illinois Environment Protection Agency (IEP A) continues to oppose the removal of styrene from the list.

INDIANA

Indiana will implement the Clean Air Act Amendments as they apply to regulation of styrene emissions. In the interim, the State controls ~ and modified sources through a permit review

~ process. Permit requirements for styrene emissions are based on the limitation of Volatile Organic Compound (VOC) emissions. The State has a fence-line guideline for styrene of .0004 ppm which is based on EPA' s HEAST designation of styrene as a probable carcinogen. However, the State does not use this fence-line guideline when establishing permit requirements.

IOWA

Iowa does not, at present, regulate toxic air pollutants. The State will implement the air toxics provisions of the Clean Air Act Amendments.

KANSAS

Kansas regulates new sources of air toxics. Currently, the State regulates styrene as a carcinogenic air pollutant in its permitting guidelines. These guidelines provide for a fenceline standard of .0004 ppm based on a draft internal EPA classification of styrene as a probable carcmogen. New sources failing to achieve the standard must install best available control technology.

After meeting with SIRC, Kansas agreed to reconsider its standard for styrene. Unfortunately, the State has determined to continue regulating styrene as a carcinogen.

5

KANSAS CONT.

The State is not expected to abandon its current air toxics program when it adopts the Clean Air Act Amendments. Further action by SIRC is under review.

KENTUCKY

Styrene is regulated under current rules as non-carcinogen with a fence-line standard of 5 ppm, assuming emissions do not exceed 40 hours per week, for new and existing sources. The State will cease using this limit when Clean Air Act implementation leads to technology based emission controls for categories of sources emitting styrene.

LOUISIANA

Louisiana promulgated a final air toxics rule on December 20, 1991, which raises the fence-line standard for styrene from .04 ppm to 1.2 ppm for new and existing sources in response to SIRC' s testimony at two public hearings and submission of extensive data. However, the rule continues to classify styrene as a "suspected human carcinogen" and '.'reproductive toxin." SIRC submitted comments on October 29, 1991, supporting the revised fence-line standard but objecting to the classification of styrene as a carcinogen.

MAINE

Maine does not consider styrene to be a high priority pollutant based on toxicity and the quantity emitted in the state. Maine uses a 24-hour ambient air guideline of 4. 7 ppm and an annual guideline of 0.005 ppm to negotiate licenses for ~ and modified sources. This is based on the ACGIH TL V divided by a time adjustment and safety factor. The State has a de minimis level of 10 lbs/hr, or 100 lbs/day. New sources are required to employ Best Available Control Technology (BACT), while existing sources must apply Best Practical Treatment (BPT).

MARYLAND

The State currently regulates styrene as a priority non-carcinogen with a fence-line standard of .5 ppm, based on the ACGIH TLV divided by a time adjustment and safety factor. New and existing sources are required to employ Best Available Control Technology for Toxics (T-BACT). Maryland has a response-based odor regulation that focuses on complaints. An advisory council is presently considering altering the criteria for listing toxic substances which IARC has determined to be carcinogenic. While no changes are expected in the immediate future, SIRC will continue to monitor the situation.

6

MASSA CHU SETTS

Massachusetts guidelines treat styrene as a carcinogenic air pollutant with an annual and 24-hour fence-line standard of 0.41 ppb and 27.21 ppb, respectively. New sources are subjected

-- to the control program through construction permits and are required to employ Best Available Control Technology (BACT) or technology which satisfies the Lowest Achievable Emission Rate (LAER). Existing sources are incorporated into the control program -through an emissions inventory process and citizen complaints, and are required to employ BACT.

MI CID GAN

- Michigan policy evaluates new sources through a permitting process based on a toxicity evaluation framework. The styrene carcinogenicity issue remains under consideration by the Michigan Department of Natural Resources (DNR). Before making a final decision, the DNR has decided to wait until the styrene carcinogenicity issue has been resolved within the U.S. EPA. In the meantime, the DNR Air Quality Division will continue to regulate styrene air emissions on the basis of odor threshold, while the Water Quality Division will continue to list styrene as a carcinogen.

MINNESOTA

Minnesota has guidelines for the regulation of new and existing sources of air toxics which the state plans to issue as a proposed rule in 1992. Although the guidelines regulate styrene as a carcinogen with an annual fence-line limit for styrene of .004 ppm, State officials informed SIRC that this limit is not used by the State when developing operating and construction permits.

MISSISSIPPI

In its permitting guidelines, Mississippi considers styrene to be a suspected carcinogen. Emissions are regulated through operating permits for existing sources and construction permits for new and modified sources. If a facility's ambient air level is 0.08 ppm or greater, the facility must implement control technology to reduce the ambient concentration. If a facility's ambient concentration is between 0.09 ppm and .0008 ppm, the permit board will decide on a case by case basis whether to grant a permit. If the ambient concentration is less than .0008 ppm, a permit will be granted.

MISSOURI

Missouri regulates ~and modified sources of styrene during the permitting process. The State has established a 24-hour fence-line guideline for styrene of 0.03 ppm based on carcinogenicity and derived from the Massachusetts standard. Upon implementation of the Clean Air Act Amendments, the State will abandon its present air toxics program.

7

MONTANA

Montana does not currently regulate toxic air pollutants. · However, the state does evaluate new sources through a permitting process. A new source emitting greater than 25 tons of any pollutant per year is required to obtain a permit. The source must also employ the Best Available Control Technology (BACT).

NEBRASKA

Nebraska only regulates nfilY and modified sources of styrene if they emit more than 75 pounds per day or 2.5 tons per year. Such major sources must install Best Available Control Technology.

NEVADA

Nevada regulates nfilY and existing sources of styrene with a fence-line standard of 1.2 ppm. The State does not consider styrene to be a carcinogen. Existing sources are incorporated into the control program upon renewal of operating permits. New sources are incorporated through construction permits.

NEW HA1\1PSHIRE

In a final rule published in 1990 styrene is listed to be of moderate toxicity, based on its carcinogenic effects. The State established a fence-line standard of 0.17 ppm based on the ACGIH 1L V divided by a time adjustment and safety factor. Upon implementation of the Clean Air Act Amendments, the State will maintain those regulations which are more strict. Further action by SIRC is under review.

NEW JERSEY

New Jersey has established permitting guidelines which list styrene as a carcinogenic air pollutant based on the EPA internal characterization of styrene as a group B2 probable carcinogen with unit risk factor of 5.7 x 10.7 µg/m3 in its HEAST.

The state conducts risk assessments for new and modified sources of styrene during the permitting process. If the screening step indicates that the proposed discharge poses an incremental risk less than or equal to 1 in 100,000 (less than or equal to .004 ppm styrene), the permit has passed the risk assessment and the permit should be granted. If, however, the screening step indicates a risk greater than 1 in 100,000 then the permit is subject to a more sophisticated screening method.

At this point, the threshold risk criteria become more stringent. If the incremental risk for the source is less than or equal to 1 in 1,000,000 (less than or equal to .0004 ppm styrene) after the second level screen, then the risk is determined to be negligible. If the risk is greater than 1 in

8

NEW JERSEY CONT.

1,000,000, the pennit application is forwarded to the Risk Management Advisory Committee (RMAC) for a case-by-case review. If the risk from the source is unacceptable (i.e., risk is greater than 1 in 10,000; ambient air concentration of styrene is greater than .04 ppm), then the RMAC will deny the pennit. For sources with predicted risks between 1 in 1,000,000 and 1 in 10,000, the RMAC will typically negotiate with the applicant to reduce the risk by lowering emissions or better dispersing the emissions.

SIRC met with state officials in October 1991, but were unable to convince them to cease regulating styrene as a carcinogen. SIRC is currently working to arrange another meeting with state officials. One issue SIRC will raise is that EPA has agreed that the forthcoming edition of the HEAST will not list styrene as a carcinogen. SIRC hopes to convince the state to change styrene's classification due to the fact that the New Jersey guidelines are based on the HEAST.

NEW MEXICO

New Mexico regulates new and existing sources with the potential to emit 14.3 pounds per hour or 28,400 pounds per year on a case-by-case basis. The State has established a fence-line standard for volatile organic compounds (including styrene) at 0.19 ppm, on a 3-hour average. When the State implements the air toxics provisions of the Clean Air Act it will not continue to apply the above standard unless it is more stringent than MACT.

NEW YORK

New York is presently considering draft guidelines for the control of air toxics including styrene. The draft guidelines classify styrene as a carcinogenic toxic air pollutant with ~ annual guideline concentration of 0.12 ppm and a short-term concentration of 12 ppm. New and existing sources are reviewed for compliance with the guidelines during the operating or construction pennitting process. If a source exceeds the guideline concentrations a pennit will not be granted unless the source and the State agree on appropriate emission control technology and techniques.

SIRC recently submitted comments on the draft guidelines to the State arguing that the classification of styrene as a carcinogen and the corresponding guideline concentrations are nbt supported by the scientific data for styrene. SIRC has learned that New York will have completed its evaluation of styrene-related issues by the time the new draft is published in 1992. Consequently, SIRC remains hopeful that styrene will be reclassified as a non-carcinogenic air pollutant.

9

NORTH CAROLINA

A final rule, effective February l, 1992, shifted the fence-line standard for styrene upward from 0.3 to 2.5 ppm, providing a 10-fold safety factor based on the no observable adverse effects level (NOAEL) for styrene. SIRC testified and submitted written comments in support of this change.

NORTH DAKOTA

North Dakota has guidelines for the regulation of new sources of toxic air pollutants including styrene. The guidelines list styrene as a non-carcinogen with a fence-line standard of 0.5 ppm. The State requires control technology for sources which can not meet the standard.

omo

Proposed draft guidelines, to be finalized by April 1992, will establish a fence-line standard of 0.7 ppm for new or modified sources of styrene. A 1-ton per year de minimis guideline has also been proposed. The draft guidelines originally listed styrene as a carcinogen based on a draft internal EPA document. After reviewing SIRC' s comments, which show that EPA has not classified styrene, OEP A has agreed to list styrene as a non-carcinogen with a fence-line standard based on the ACGIH TL V divided by 70. Ohio requires that new and modified sources employ the Best Available Control Technology (BACT). Once implemented, the Clean Air Act Amendments will take precedence over state policies.

An effort is underway in the State to create a toxic chemical labeling or "right-to-know" law similar to, but more demanding than, California's controversial Proposition 65. The proposal would require businesses to label products which contain chemicals that cause cancer or birth defects. The proposal does not currently list styrene as a substance of concern. A more detailed discussion of this proposal is provided in SPI's Issue Backgrounder (see attachment).

OKLAHOMA

Oklahoma regulates film:'.. and existing sources of styrene which emit 6 tons per year or more. Such sources must comply with a fence-line standard of 5 ppm.

OREGON

Oregon regulates new and modified sources of styrene emitting more than 393 pounds per 8 hours from stacks or 196 pounds per 8 hours of fugitive emissions. The State has established a fenceline guideline for styrene of .17 ppm based on the New York Air toxics permitting guidelines which list styrene as a carcinogenic air pollutant.

JO

PENNSYLVANIA

Pennsylvania requires best available control technology on new sources of air toxics including styrene. The State has no plans to develop any health based emission standards for air toxics.

RHODE ISLAND

The State regulates styrene as a Class C carcinogenic air pollutant with a fence-line standard of .007 ppm. New and existing sources emitting 10,000 pounds per year or more of styrene must comply with the state's fence-line standard to receive an operating or construction permit. The State requires new sources to employ the Best Available Control Technology (BACT).

SOUTH CAROLINA

In a final rule signed into law May 31, 1991, South Carolina classifies styrene as "low toxic." SIRC testified in 1991 against the original proposal which classified styrene as "highly toxic" with a fence-line standard of .25 ppm. The State now regulates new and existing sources of with a fence-line standard of 1.2 ppm based on the ACGIH TL V divided by a time adjustment and safety factor. The State has established a de minimis level at 1,000 pounds per month. However, a source is still required to report emissions, whether or not it actually exceeds the de minimis level. Upon implementation of the Clean Air Act Amendments, South Carolina will enforce those regulations which are more strict.

SOUTH DAKOTA

South Dakota does not currently regulate styrene as a toxic air pollutant.

TENNESSEE

Tennessee has guidelines for the control of ~ sources of air toxics. The State does not regulate styrene as a carcinogen. A fence-line guideline of 5 ppm is established for styrene. If needed to meet the standard, control technology is required on a case by case basis. Best Available Control Technology (BACT) is required of all major sources.

TEXAS.

The State bas a current fence-line regulation for styrene of 0.1 ppm based on odor/nuisance factors.

11

UTAH

Utah regulates new sources of air toxics on a case-by-case basis through the permitting process. The State regulates air toxics through fence-line standards based on the TL V/300 for carcinogens and TL V 1100 for non-carcinogens. Utah has not evaluated the carcinogenicity of styrene.

VERMONT

Despite SIRC efforts with state officials, styrene continues to be regulated as a Class II "hazardous air contaminant" with annual ambient air limit of 0.12 ppm. A state-mandated technology, most similar to the Best Available Control Technology for Toxics (T-BACT), is required to meet the fence-line standard. The State has set a de minimis level at 42.5 pounds ·~ per 8 hours. Further action by SIRC is under review.

VIRGINIA

The final rule requires facilities with styrene emissions of over 30 tons per year to comply with a fence-line limit of 0.1 ppm. If these facilities exceed ten times the fence-line standard (1 ppm) then engineering controls must be installed. These requirements apply to existing sources only upon request by the State. Consequently, there is no immediate obligation to comply with the new requirements. SIRC is currently working with affected sources in Virginia and the State to show that emissions from affected facilities do not endanger health and that the fence-line standard is inappropriately low.

WASHINGTON

Washington issued a final rule in July 1991 which establishes a fence-line sta.pdard of 0.17 ppm · for styrene, though it does not classify styrene as a carcinogen. The State. disregarded SIRC's written comments which argued that the scientific data for styrene does not support such a low standard. However, State law provides for the creation of a Science Advisory Panel which will consider petitions to delist substances from the air toxics program. SIRC is working with other interested trade associations to raise the fence line level for styrene in Washington's program.

WEST VIRGINIA

West Virginia does not presently regulate styrene as a toxic air pollutant. The State will regulate styrene when it implements the Clean Air Act Amendments.

WISCONSIN

Wisconsin currently regulates styrene as a non-carcinogenic toxic air pollutant with a fence-line standard of 1.2 ppm.

12

WYOMING

Wyoming regulates styrene emissions from new sources through their permit review program. The state requires best available control technology on new sources and compliance with a 1.2 ppm fence-line standard.

The federal air toxics program will require that all major sources of 190 substances listed in the Amendments install MACT.

FOOTNOTES

1. The regulation of styrene as an ozone precursor by individual states is not covered by this State Update. This document will instead be covered in a document currently under development by SIRC.

2. In addition, many states regulate pollutant emissions on the basis of odor. Typically, these regulations are enforced on a case-by-case basis when the state receives a complaint. The offending facility is usually required to abate the nuisance.

Attachment

13

APPENDIX VI. Determination of Reasonably Available Control Technology

and -Best. Available Retrofit Control Technology for Polyester Resin Operations

State of California AIR RESOURCES BOARD

DETERMINATION OF REASONABLY AVAILABLE CONTROL TECHNOLOGY AND BEST AVAILABLE RETROFIT CONTROL TECHNOLOGY

FOR POLYESTER RESIN OPERATIONS

Prepared by

Criteria Pollutants Branch Stationary Sourc~ Division

Approved by

the Technical Review Group of the

California Air Pollution Control Officers Associations

January 8, 1991

ACKNOWLEDGMENTS

This determination was prepared by the Air Resources Board staff in cooperation with th·e California Air Pollution Control Officers Associati·on's Technical Review Group Solvent Committee. We would like to particularly thank:

Principal Investigators

Eric Skelton, Chairman Abid Latif Peggy Vanicek John Estrem Natalie Zlotin Don Price Wayne Kino

Reviewed and Approved by

Thomas Evashenk Tuan Ngo

·.clerical Support

Theresa Dade Marline Hicks

Technical Review Group Solvent Committee

Sacramento Metropolitan AQMD South Coast AQMD ARB EPA San Diego County APCD Ventura County APCD Bay Area AQMD

Peter D. Venturini, Chief, Stationary Source Division Ronald A. Friesen, Assistant Chief, Stationary Source Division Dean C. Simeroth, Chief, Criteria Pollutants Branch Gary M. Yee, Manager, Industrial Section

Table of Contents

Contents

INTRODUCTION AND SUMMARY •.•..• !. .................................. 1

I. RACT /BARCT RECOMMENDATION ••••••.••••..•••••••••••.••••••••••. 1

II. CONTROL TECHNOLOGY ••..•••.••••..•.••••...•••••••••.••••.••••• 4

A. Low Monomer Resins ••..•.•••.•••.•••.•.•••.•.••••••• 4

B. Modifying Processes ••.•••.••••..•••..•••••.•••••••• 4

C. Vapor Suppressed Resins .....•••...•...•.....•....•. 4

0. Emission Control Devices ••••••.••••••.•••••••••••••• 4

III. IMPACTS •••••••..•••••.••••••..••••.•••••.•••••••••..•••••••.. 4

A. Economic ••••••••••••••••••••••••••••••.•••••••••••• 4

B. Emission Reductions ••••••••••••••••••••••••••••••• 5

C. Other Impacts •..•.••.•••••••.•••••••.•.•.••••.••••• 5

APPENDIX

A. RACT/BARCT DETERMINATION

B. APPLICABLE SUPPORT DOCUMENTS

INTRODUCTION AND SUMMARY

RACT/BARCT DETERMINATION FOR POLYESTER RESIN OPERATIONS

This document presents the determination of Reasonably Avail~ble Control Technology (RACT) and Best Avai-lable Retrofit Control Technology (BARCT) for polyester resin operations. Also, presented in this document is the basis for the determination, an overview of the control technology and cost-effectiveness, and associated economic and other impacts.

Polyester resin operations include the use of unsaturated polyester resins to fabricate or re-work a variety of products such as spas, tubs, pools, and boat hulls. These processes involve mixing, pouring, hand layups, impregnating, injecting, forming or spraying resins with fiberglass, filling, and other activities for the reinforcement of materials. Volatile organic compounds (VOCs) emissions result from these operations during evaporation of monomer when resins are applied and cured and from the use of clean-up solvents. Total statewide volatile organic compound emissions from polyester resin operations are estimated to be approximately 25 tons per day. Statewide implementation of the RACT/BARCT standards can reduce between 3 to 5 tons per day of volatile organit compounds.

The determination of RACT and BARCT for polyester resin operations is based on the recommended RACT and BARCT report by the Technical Review Group's (TRG) Solvent Committee of the California Air Pollution Control Officers Association. The Committee's recommendations are substantially derived from the South Coast Air Quality Management District's Ru.le 1162 and subsequent rules from the San Diego County and Ventura County Air Pollution Control Districts. These rules represent the most effective limits and available technology found in California. Upon evaluating the Committee's report, (see Committee's report and support documents in Appendix B) staff proposes that the determination of RACT and BARCT be the same level of control for polyester resin ~perations.

I. RACT/BARCT RECOMMENDATION

Staff recommends that the determination (see Appendix A) be defined as RACT/BARCT for polyester resin operations. As mentioned above, RACT and BARCT are the same level of control; therefore the requirements of the proposed determination applies to both. The determination has three basic requirements that apply to the process, clean-up and storage, and recordkeeping. Table 1 summarizes the determination of RACT/BARCT. The major requirements of the RACT/BARCT determination are briefly discussed in the following.

-1-

Table 1

Polyester Resin Operations RACT/BARCT Surrmary

Standards

Process and control requirements

o Monomer content ~ 35 percent by weight o Monomer content ~ 50 percent by weight for specialty2resins o Vapor suppressed resins wit~ weight loss of ~ 60 g/m o Closed-mold system o Add-on control devices that achieve a maximum capture efficiency

using EPA protocols and achieve a destruction efficiency of at least 85 percent by weight. The overall efficiency of the control system shall be at least as effective in emission reductions as the level of control of complying resins.

Transfer efficiency

o airless, air assisted, high volume low pressure or electrostatic spray equipment.

Cleaning material requirements

0 solvent contains ~ 1.7 lb voe per gallon ot solvent, or o has initial boiling point greater than 190 C, or o use solvent reclamation system

Storage and disposal requirements

o all solvents and wastes be stored in closed containeri and be properly disposed.

Exemptions

o Touch-up and repair o Pigmented gel coats that contain < 45 percent by weight monomer

or clear gel coats that contain < 50 percent by weight monomer.

continued

-2-

Table 1 (contd.)

Administrative requirements

o Compliance schedule

o Recordkeeping

Test methods

o Laboratory static test for polyester resin materials

o EPA method 25A 'for total hydrocarbons.

o EPA method 8240 for hydrocarbons in liquid.

o ASTM 03960-81 for volatile organics on paints and coatings.

o ASTM 01078-86 for boiling range of volatile organics in liquid.

o ASTM 02369-81 for hydrocarbons content using gas chromatograph.

o ASTM 03792-79 for water content using gas chromatograph.

o ASTM 04457-85 for exempt solvent using gas chromatograph

o ARB method 401 gravimetric purge and trap for volatile. organics.

o EPA guidelines for developing capture efficiency protocols

Note: < is less than or equal

-3-

RACT/BARCT DISCUSSION

Process requirements include the use of low monomer resins, vapor suppressed resins, or the use of closed-mold systems. These control strategies have lower voe emissions than conventional resin systems. In addition, high transfer efficiency spray guns such as airless, air assisted airless, or high-volume low pressure spray guns are required for all spraying operations. The spray equipment requirements may be modified in the future based on the study that the ARB will be sponsoring to develop a standard test method to determine transfer efficiency.

As an alternative to the process ~equirements, a facility may elect to control voe emissions by the use of add-on control devices that can achieve a combined capture and destruction efficiency as effective as the reduction efficiency of complying resins. Add-on controls must also achieve a maximum collection of fugitive emissions according to the EPA's "Guidelines.for Developing Capture Efficiency Protocols" and have a minimum destruction efficiency of at least 85 percent by weight. Note that it is not the intent of this determination to allow the use of bubbling or averaging of emissions to comply with the requirements of this determination. Compliance by bubbling or averaging of emissions are address in applicable district rules that apply to alternative emission compliance plans.

The criteria for clean-up and storage requires the use of low volatile organic compound solvents for clean-up purposes. However, a person can use clean-up solvents that exceed the standard provided the facility uses a reclamation system to recycle the solvents. For storage requirements, all resins, cleaning solvents, spent solvents, cleaning materials, wastes and unused materials containing volatile organic compounds shall be stored in closed containers and shall be properly disposed.

The criteria for recordkeeping requires daily recordkeeping of resin use, clean-up solvent use, and the content of volatile organic co~pounds in the clean-up solvents. Records shall be retained for 24 months.

The RACT/BARCT determination also provides an exemption for specialty resin applications and specifies test methods for the determination of compliance. The laboratory static test for resin materials is an integral part of the determination to demonstrate compliance.

II. CONTROL TECHNOLOGY

Volatile organic compound emissions from polyester resin operations can be reduced by using low monomer resins, modifying processes, using vapor suppressed resins, or by add-on emission control devices. The control technologies are briefly discussed below. More detailed discussions of these control technologies can be found in the TRG's Solvents Committee report and support documents contained in Appendix B.

-4-

A. LOW MONOMER RESINS

Low monomer resins that have no more than 35 percent by weight monomer content have been developed and are currently used. However, the use of low monomer resins requires special care during application to ensure that the desired product properties are not degraded. Use of low monomer content. resins can achieve approximately 40 percent emission reductions as compared to conventional resins. ·

B. MODIFYING PROCESSES

Volatile organic compound emissions can be reduced by modifying the process to reduce resin use. These modifications include the re-design of products, increase fillers and colorants, elimination of un-intentional waste during application, and conversion to closed-mold systems. Depending on a facility's existing method of application and the desired product, utilizing any or a combination of the described process modifications can substantially reduce the emissions from this source.

C. VAPOR SUPPRESSED RESINS

Vapor suppressed resins have been available for several years. To meet the 60 grams per square meter emission limit, manufacturers have typically added small amounts of paraffin wax to the resins. The purpose of this is to provide a surface film that coats the product and reduces the outward diffusion of monomer molecules which results in decreased emissions. However, for multi-layer applications, the wax layer may have to be physically removed before applying a new coat to ensure proper bonding.

D. EMISSION CONTROL DEVICES

In lieu of using complying resins, polyester resin operators can use add-on emission control devices. Four emission control devices were evaluated as options for use at polyester resin operations: incineration; absorption; adsorption; and condensation. These control technologies have been demonstrated to be highly effective in reducing volatile organic emissions when exhaust gas concentrations are relatively high. However, exhaust concentrations from polyester resin operations are typitally less than 1000 ppm which make these control technologies less effective and not cost-effective.

III. IMPACTS

A. ECONOMIC

Most polyester resin operators are expected to comply with the RACT/BARCT standards using complying resins. Vapor suppressed resins are slightly higher in price and require more careful process application than conventional resins. The industry estimates that vapor suppressed resins would cost approximately 2 to 3 cents more per pound than that of

-5-

conventional resin. The cost impact for facilities that use complying resins is expected to be minimal.

The cost of using control equipment is expected to be much more expensive. The South Coast Air Quality Management District estimates the cost-effectiveness of using control equipment to range from approximately $19,000 per ton ($9.50/lb) of voe emissions reduced for absorption to $48,000 per ton ($24/lb) for incineration. For small operations, the use of control equipment is expected to be cost prohibitive.

B. EMISSION REDUCTIONS

Implementation of the RACT/BARCT standards on a statewide basis is expected to result in a reduction of 3 to 5 tons per day of volatile organic compound emissions statewide.

C. OTHER IMPACTS

We have identified no adverse environmental impacts associated with the implementation of the RACT/BARCT standards with respect to global warming, plant and animal life, noise levels, land use, or natural resources. The reduction in emissions of VOCs should reduce ozone formation in the state as well as reduce the potential for odors.

-6-

APPENDIX A

DETERMINATION OF REASONABLY AVAILABLE CONTROL TECHNOLOGY AND

BEST AVAILABLE RETROFIT CONTROL TECHNOLOGY . FOR

POLYESTER RESIN OPERATIONS

DETERMINATION OF REASONABLY AVAILABLE CONTROL TECHNOLOGY AND BEST AVAILABLE RETROFIT CONTROL TECHNOLOGY FOR

POLYESTER RESIN OPERATIONS

I. Applicability

Except as provided in Section IV (Exemptions) this determination is applicable to commercial and industrial polyester resin operations.

II. Definitions

For the purpose of this rule, the following definition~ shall apply:

A. Catalyst is a substance added to the resin to initiate polymerization.

B. Cleaning materials include, but are not limited to, materials used for cleaning hands, tools, molds, application equipment, and work area.

C. Closed Mold System is a method of forming objects from polyester resins by placing the polyester resin material in a confining mold cavity and applying pressure and/or heat.

D. Control system includes a control device and a collection system.

E. Cross-linking is the chemical process of chemically bonding two or more polymer chains together.

F. t.Y..c.e. means to polymerize, i.e., to transform from a liquid to a solid or semi-solid state to achieve desired product physical properties, including hardness.

G. Executive Officer is the Executive Officer or Air Pollution Control Officer or his/her delegate of an air quality management district or an air pollution control district.

H. Fiberglass is a fiber similar in appearance to wool or cotton fiber but made from glass.

I. Gel coat is a polyester resin topcoat that provides a cosmetic enhancement and improves resistance to degradation from exposure to the environment.

J. Grams of voe per liter of.material is the weight of voe per volume of material and can be calculated by the following equation:

Grams of voe per liter of material = (Ws- WW - wes)/Vm

Where:

Ws = weight of volatile compounds in grams Ww = weight of water in grams Wes = weight of exempt compounds in grams Vm =volume of material in liters

K. Hjgh Volume-low Pressure means spray equipment used to apply coatings by means of a gun which operates between 0.1 and 10 psi air pressure.

L. Inhibitor is a substance used to slow down or prevent a chemical reaction.

M. Low-voe emissions resin systems are polyester resin materials which contain vapor suppressants to reduce monomer evaporation loss.

N. Monomer is an organic compound that combines with itself, or other similar compounds to become a cured thermosetting resin.

0. Polyester is a complex polymeric ester containing difunctional acids and alcohols dissolved in a monomer.

P. Polyester resin materials include, but are not limited to, unsaturated polyester resins such as isophthalic, orthophthalic, halogenated, bisphenol-A, vinyl-ester, or furan resins; cross-1 inking agents; catalysts, gel coats, inhibitors, accelerators, promoters, and any other voe containing materials in po1yester resin operations.

Q. Polyester resin operations are methods used for the production or rework of products by mixing, pouring, hand lay-up, impregnating, injecting, forming, winding, spraying, and/or curing unsaturated polyester resin.materials with fiberglass, fillers, or any other reinforcement materials and associated cleanup.

R. Polymer is a chemical compound comprised of a large number of chemical units and which is formed by the chemical linking of monomers.

S. Repajr is that part of the fabrication process that requires the addition of polyester resin material to portions of a previously fabricated product in order to mend minor structural damage.

T. ~ is any of a class of organic polymers of natural or synthetic origin used in reinforced products to surround and hold fibers, and is solid or semi-solid in. the cured state.

U. Specialty Resin is any halogenated, furan, bisphenol A, vinyl ester, or isophthalic resin used to make products for exposure.to one or more of the following extreme environmental conditions: acute or chronic exposure to corrosive, caustic, acidic, agehts, or flame.

V. Touch-up is that portion of the fabrication process that is necessary to cover minor imper.fections.

W. Volatile organic compound (VOC) is any volatile compound of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, 1,1,1 trichloroethane, methylene chloride, trifluoromethane (HFC-23), trichloroflouromethane {CFC-11), dichlorodifluoromethane (CFC-12), trichlorotrifluoroethane (CFC-113, chlorodifluoromethane (HCFC-22), dichlorotetrafluoroethane (CFC-114), chloropentafluoroethane (CFC-115), dichlorotrifluoroethane (HCFC-123), tetrafluoroethane (HFC-134a), dichlorofluoroethane (HCFC-14lb), and chlorodifluoroethane (HCFC-142b).

X. Vapor suppressant is a substance added to resin to minimize the outward diffusion of monomer vapor fnto the atmosphere.

Y. Waste materials include, but are not limited to any paper or cloth used for cleaning operations, waste resins, and any spent cleaning materials.

III. Standards

A. Process and Control Reauirements

1. Any person operating a polyester resin operation shall comply with one or more of the following as applicable:

(a) Use polyester resin material with a monomer content of no more than 35 percent by weight as applied and as determined by the manufacturer's specification; or,

(b) Use specialty resin with a monomer content of no more than 50 percent by weight as applied and as determined by the manufacturer's specification; or,

(c) Use a resin containing a vapor suppressant, such that weight loss from voe emissions does not exceed 60 grams per square meter of exposed surface area during resin polymerization; as determined by Section VII. A or, ·

(d) Use a closed-mold system.

(e) Install and operate an emissions control system which is designed and opera~ed for the maximum collection of fugitive emissions from polyester resin material, according to the EPA's "Guidelines for Developing Capture Efficiency Protocols," and which system is approved in writing by the Executive Officer, and has a control device with a control efficiency of 85 percent or more on a mass basis as determined by VII. B. The overall emission reduction efficiency considering capture and control efficiency shall be equivalent or greater.than those emission reduction levels achieved by any requirement specified in Subsections (a), (b), (c)~ or (d) of this section.

2. For application of polyester resin materials by spraying operations, use only airless, air-assisted airless, high volumelow pressure, or electrostatic spray equipment as approved by the Executive Officer and operated in accordance with the manufacturer's recommendations.

B. Cleaning Materials Requirements

If cleaning materials contain more than 1.7 pounds of VOC per gallon of material as applied and as determined by VII. C, or where the initial boiling point is less than 190 degrees Celsius as determined by VII. D., use a reclamation system when such cleaning materials usage exceeds 4 gallons per day. The reclamation system shall operate with at least 80 percent efficiency. The solvent residues generated from on-site reclamation systems shall not contain more than 20 percent Voe by weight as determined by VII. G.

e. Storage and Disposal Requirements

1. Use closed containers to store all polyester resin materials, cleaning materials, and any unused voe-containing materials except when accessed for use.

2. Use self-closing containers for the disposal of all uncured polyester resin materials, cleaning materials, waste materials, and any un-used VOC-containing materials in such a manner as to effectively control voe emissions to the atmosphere.

3. Use closed containers to store all scrap materials resulting from cutting and grinding of freshly cured resins.

IV. Exemptions

A. The provisions of Section III shall not apply to touch-up and repair.

v.

B. The provisions of Section III. A.1. shall not apply to gel coats provided the monomer content shall not exceed 45 percent by weight. for pigmented gel coats and shall not exceed 50 percent by weight for clear gel coats.

Compliance Dates

A. A person who is subject to the requirements of this.determination shall be in compliance by ( within 12 months from the date of adoption).

B. Facilities operating prior to the effective date and which elect to install and operate an emission control system pursuant to the requirements of subparagraph C. 2. shall have a control system installed and operated by ( within 12 months from the date of adoption).

VI. Recordkeeping

Any person subject to this rule shall comply with the following requirements:

A. A person shall maintain, or have available~ a current list of resins and cleaning materials in use which provides all of the data necessary to evaluate compliance, including the following informa~ion, as applicable:

1. resin, catalyst, and cleaning materials used

2. the weight percent of voe in each of the polyester resin materials, and the grams of voe per liter for the cleaoing materials.

3. for approved vapor suppressed resins, the weight loss (grams per square meter) during resin polymerization, the monomer percentage, and the gel time for each resin.

B. A person shall have available records that provide the following information, as applicable:

1. the amount of each of the polyester resin materials and cleaning materials used during each day of operation.

2. volume of resin and cleaning materials used for touch-up and repair during each day of operation.

C. Such records shall be retained for the previous 24 month period and be available at the time of inspection.

VII. Methods of Analysis

The analysis of cleaning materials, polyester resin materials, and control/collection efficiency shall be determined by the appropriate test methods as follows:

A. Attachment A (Laboratory Static Test for Polyester Resin Materials for the determination of the resin voe weight loss.)

B. EPA Method 25A (Determination of Total Gaseous Organic Concentration Using .a Flame Ionization Ana 1yzer -- for the determination of VOC concentration at the exhaust and inlet of the air pollution control device).

C. EPA Method 8240 (GC/MS Method for Volatile Organics - for the determination of voe in liquid waste.)

D. ASTM D3960-81 (Determining Volatile Organic Content (VOC) of Paints and Related Coatings)

E. ASTM D1078-86 (Distillation Range of Volatile Organic Liquids - for the determination of voe boiling range of liquid.)

F. ASTM D2369-81 (Determination of Volatile Organic Compound Content using Gas Chromatography.

G. ASTM 03792-79 (Determination of Water Content using Gas . Chromatqgraphy.

H. ASTM 04457-85 (Determination of Exempt Solvents using Gas Chromatography.

I. Air Resources Board Method 401 (Gravimetric Purge and Trap - for the determination of voe in liquid and solid.)

J. EPA Guidelines for Developing Capture Efficiency Protocols.

ATTACHMENT

STATIC METHOD FOR DETERMINATION OF VOLATILE EMISSIONS FROM

POLYESTER AND VINYL ESTER RESINS

1. PURPOSE

1.1 This test is designed for the determination of volatile organic compound emissions of polyester and vinyl ester resins as received from the manufacturer, according to requirements of California's South Coast Air Quality Management District (SCAQMD) proposed Rule 1162 amendment published July 17, 1990.

1.2 This test allows fabricators using polyester and vinyl ester resins to monitor volatile organic compound emissions (principally styrene monomer) from resins used in the fabrication process. The results are to be reported as vol~tile organic compound losses in grams per square meter (gm/m ).

2. METHOD

The weight of a one gallon can lid filled with 100 gm of resin is accurately measured over a period of time. The measurement is made on resin catalyzed with peroxide initiators to determine weight losses attributed to monomer and other volatile organic compound emissions.

3. EQUIPMENT REQUIREMENTS

3.1 Controlled environment at 25° C and humidity of 50% R.H. If controlled environment is not available, report condition under which measurements are made.

3.2 Balance with an accuracy of 0.01 gm.

3.3 Draft free enclosure for balance. This can be achieved by placing the balance in a four sided enclosure that extends a minimum of eight inches above the top of the balance.

3.4 Gallon can lid with deep form sufficient to contain 100 gm of resin, having a normal diameter of 14.5 cm.

3.5 Certified or saljbrated thermometer capable of measurements accurate to 1 C.

3.6 Constant temperat8re bath controlled at 25°c to adjust resin temperature to 25 C.

3.7 Timer - capable to recording time to 0.1 min.

3.8 Paper clip - bent to approximately 90° angle.

3.9 Syringe or pjpette accurate to 0.1 ml for peroxide catalyst addition.

4. PROCEDURE

4.1 Weigh out 200 gm of prepromoted resin into a suitable dry and clean container. Wax cups should not be used for this test.

4.2 Cover container and pla&e in constant temperature bath and adjust resin temperature to 25 C.

4.3 Place balance in draft free enclosure.

4.4 Clean gallon lid with solvent, wipe dry and air dried and measure diameter to the nearest 0.1 cm.

4.5 Place gallon can lid on an inverted paper or plastic cup mounted on the balance pan. Position bent paper clip in the center of the gallon can lid. Record TARE WEIGHT to± 0.01 gm.

4.6 Take container with resin from water bath and add appropriate volumetric or weight measure of catalyst using syringe or pipette. Start timer.

4.7 Using stirring rod or thermometer, mix in catalyst for one minute.

4.8 Pour 100.0 ± 0.5 gm of catalyzed resin into can lid and record weight to± 0.01 gm. This is the INITIAL WEIGHT.

4.9 Using paper clip, determine when resin has hardened sufficiently to allow resin or lid to be lifted.

4.10 Record this as gel time.

4.11 Allow resin to harden in can lid and reweigh every 15 minutes until concurrent weighing agrees to within .05 gm. Record this as FINAL WEIGHT to ± 0.01 gm.

4.12 Procedure should b~ repeated until duplicate samples agree to the nearest 5 gm per m .

5. CALCULATION

5.1 Volatile Organic Compound Emissions Per Square Meter

Area of Sample in Square Meter = (diameter of lid in cm) x 3.14 200

Volatile Organic Compound Losses Per Square Meter = Initial Weight - Final Weight

Area of Sample in Square Meters

5.2 Percent Volatile Organic Compound Emission = Initial Weight - Final Weight x 100

Initial Weight-Tare Weight

6. REPORTING REQUIREMENTS

6.1 Ambient temperature. and humidity.

6.2 Resin identification and batch number.

6.3 Initiator system and amounts used.

6.4 Volatile organic -compound losses as grams per square meter.

6.5 Percent volatile organic compound emission.

6.6 Gel time under conditions of test.

APPENDIX VII. South Coast Air Quality Management District

RECLAIM Summary Recommendations

-South Coast AIR QUALITY MANAGEMENT DISTRICT 21865 E. Cooley Drive. Diamona Bar. CA 91765~4182 {71..1\ 395-2000

Dear Reader:

Southern California has long been known as the golden land of opportunity. ...\s we enter the 2 ~st cemurv. the chailernres of attaining dean ;iir and revitalizing the economy dominate the work or the District. Tomorrow's opportunity must be based on accompiishing our environmentai objectives at the lowest possible cost.

The District's commitment to doing its part to help the economy is captured in the . Governing Board's NEW DIRECTION campaign. The use of market incentives is one of the major components of the campaign.

Last year the Governing Board initiated a Feasibility Study of a Marketable Permits Program. The mission was to design a regulatory structure that would beat the performance of today's rules. The goals were tough: lower costs, increased flexibility and the attainment oft'.":= 1991 Air Quality Management Plan objectives. During this year, the Program's Steering and Advisory Committees have worked long hours with staff to investigate various alternatives. Five working papers later. an enforceable structure for a trading program has been developed by the District.

The regulatory program presented in this report will establish a Regional Clean Air Incentives ~farket. With this in mind. the new program has been given a new name - RECL\.L\f.

RECLAIM represents a bold departure from traditional command and control regulations. Companies will be allowed to achieve their required emission reductions of Reactive Organic Gases (ROG) and Nitrogen Oxides ('.'l'Ox) through: add-on controls, the use of reformulated products, and/or by purchasing excess emission reductions from other sources.

\Vith RECI-..\.IM, Southern California can transform the cost of clean air attainment into a ma: .-:et opportunity. Cleaning our skies was never assumed to be inc ··'!nsive; but with the use of trading, the cost can be dramatically reduced.

We can RECL-\IM clean air: and. we can RECL\IM a healthv cconomv. The changes presented in this report are revolutionary. Equipment Peimits are replaced with Facility Permits. Emission Rates are repiaced v..ith Mass Emission Limits. Retrofit Control Rules are replaced with Annual Emission Reductions. Paper records are replaced with high quality monitoring of emissions. All of the design components of RECLAIM combined represent a dramatic breakthrough in air pollution control.

\Ve look forward to your comments on RECL\IM and your participation in the rule development process.

PL:Ibv.

Executive Summary

Executive Summary

Overview

This paper presents the recommended design for the Regional Clean Air Incentives Market (RECL-\IM). RECL-\IM represents a :O,old cc~arture from traditional command and control regulations. Companies will be allowed to achieve their required emission reductions of Reactive Organic Gases (ROG), ~itrogen Oxides (NOx), and potentially Sulfur Oxides (SOx) through their choice of: add-on controls, the use of reformulated products, and/or by purchasing excess emission reductions from other sources. The regulatory changes presented in this repon· are revolutionary. Equipment Permits are replaced with Facility Permits. Emission Rates are replaced with Mass Emission Limits. Retrofit Control Rules are replaced.with Annual Emission Reductions. Paper records are replaced with high quality monitoring of emissions. All of the design components of RECLA.IM combined represent a dramatic breakthrough in air pollution control. This proposai is the result of a feasibility study conducted by District staff \l.ith input provided by the program's Advisory and Steering Committees.

Throughout the feasibility study, the following criteria have been used to analyze different progra·m options:

• Enforcement of emission reductions must provide confidence equal to or greater than the existing system;

• Emission Reductions (Air Quality) must be equal to or greater th~n the 1991 Air Quality Management Plan (AQMP) and future control plans:

• Implementation Costs must be less than the 1~91 AQMP:

• Job Impacts must be less than the 1991 AQ~f P: and

• Adverse Public Health Impacts should not result from implementation of the program ..

Format of the Paper

Figure EX-1 illustrates the organization of this paper.· Chapter 1 of this paper summarizes the background for the development of RECL-\I~. This chapter describes the different events ~hat led to the feasibility study and provides an overview of the feasibility study.

Chapters 2 through ~ 1 rovide the framework fr-:- ~ ECL~IM. ar.d present key design issues essential to ::. -~:irket-based regulatory prog:::-::. .::-· · .. : :·=asib: .. :: study progressec. :-::i.r.·.of the recommendations surrounding these Liesign isst.:-.:s have been refined. Discussions presented summarize the evolution of District staffs recommendations.

Fe:isibilily Study Summary E.X-1 March 1992

Executive Summary

Comments received from the Steering and Advisory Commmees relative to the uesign of the program are presented as Industry. Envirorune::t:ii. J.::a Other comments.

Chapter 6 summarizes the socio-economic :rnd air ~uaiiry impacts. as identified i:; \Vorking Paper #5. Chapter 7 summarizes issues for the rnie deveiopment orocess.

Figure EX-1: I Organization of

Feasibility Study Summary Paper

Proposed Scope of the Program

Chapter 2

Socio-Economic Impacts and. Air Quality Improvements Chapter 6

Permits! :

I = Baseline +

Proposed Emission Reduction Process

Chacter 3

Feasibility Study

Summary r ,

1'--~~ :::~. ~ J' • 0 ' .. .:..z·· ....... J _:...,

;g \;cosed Trading ll'_I""':~ Pro gram ~ Chacter 4

~ Proposed Enforcement.

Prosecution, and Backstops Chapter 5

Program Recommendations

RECLAIM is based on the concept of bubbling stationary sources at the facility level. limiting total mass emissions from the facility, and requiring each source to meet prescribed annual facility emissions targets. The acrual method of compliance would be up to the individual firm. including purchasing traded emissions. installing control equipment. using lower emitting material. or other techniques.

RECLAIM represents a significant change from the current regulatory system. Instead of specifying equipment- or process-specmc concentration limits. the program will impose mass emission. limits with a declining balance for all emis_=ion sources at a facility. A summary JI

of RECL\IM is provided below. !:I

For illustration. the basic structure of the program has been broken down into six questions.

··~~~

Feasibility Study Summary EX-:

Executive Summary

WHO will this program apply to?

I~

• District Permitted Facilities

• Possible Exemptions

RECL\.IM .,1.·iil cover those stationary sources that hold District permits for ROG. or NOx. The District is recommending that source categories that have typical annual emissions greater than or equal to 4 tons be inc .. :ded in the program. This wiil create a ROG market of approximately 2,000 facilities with 85 percent of the permitted erruss1ons. The NOx market will contain approximately 700 facilities, with 95 percent of the permitted emissions.

Based on comments received from the environmental community, the District recommends that electric utilities be included in REClAIM.

The business and environmental community have recommended that a market for SOx be considered in addition to the ROG and NOx program. Initfal staff analysis indicates that there are approximately 100 facilities in the Basin that ceuld be included in a S0

1

RECLAIM program. This universe would include refineries, electric utilities, and chemical manufacuturers.

Ultimately, the goal is to expand the initial market. The rules for the program will be designed to provide incentives for emission reductions from: mobile sources, area sources. and any stationary source not included in RECLAJ:M.

Several exemptions for RECLAIM are proposed. Certain essential public services. restaurants, dry cleaners, and gasoline dispensing facilities are recommendec for regulation through command and control rules. In addition, for those sources that generally emit less than 4 tons per year, a second phase of entry into the market will be assessed. Additional small source exemptions may also be considered, where it appears to be mor-:- cost-effe'.:::ve to regulate these sour.:--· through additional source specific rules.

Feasibility Study Summary

I

!I

:r 2,000 ROG ~· ., ·Facilities ·

: 700 NOx Faci:;ties

EX-3 \farch 1 ·:n:

Executive Summary .

WHAT pollutants ~ill be part of RECIAIM?

RECLA.IM covers ROG and ~O~. two important ozone tirec~:sors.- · rn addition. t0 these criteria pollutanrs. the District is considering so~ emissions :';om Stationarv <;Ources for inclusion in the program.

Fugitive emissions Vtill be inciuded in a facility baseline. However. credit for reduction oi fugitive emissions will only be allowed once standard. repiicable emission reduction methodologies have been deveioped.

NOx

• ROG

• Potentially SOx

No Toxics

HOW will the program work?

• Facilities Emission Caps

• Annual Rotes of Reduction ( 6% ROG, 8% NOX)

• Increased Monitoring

Baseline Allocations

!I

Site-specific toxic erruss1ons Vtill not be allowed to increase as a result of trading. Facilities will be required to comply with present and future source specific regulations for texic emissions. Reduction ·..:redits for ROG will not be differemiated "Jy compound. .:..ny facility increasing toxic emissions will be subject to the screening and review procedures in District Rule 1401 - New Source. Review of Carcinogenic Air Contaminants.

REClAIM will establish facility mass emission limits. Each year. the facility must reduce ROG, ~Ox and potentially .sox emissions by a specified rate of reduction. Since the faciiities will have increased compliance flexibility, the District will need to rely on improved monitoring and reporting methods to ensure compliance.

The "Baseline·· is the year-one mass emission limit for a facilir· -:llis benc:...:-nark numt·~=-·:stablishes the staning point for :!a.ch facifay's stair-step ·~see::: of emi~ · -e~:;cricr:.

During the .. ;urse of the feasibility study, ~ :mrnber of different Baseline r::opos;.... :ere assessed. The rollowing three chans illustrate the different proposals.

Feasibiliry Study Summary EX-4 ~farch 1992

~:cecutive Summary

Step one for all proposais is to recognize the 1993 AQMP emissions as the first point on the chart that establishes the overail rate of reduction :or attainment. For the purposes of this 3.nalysis. 1993 was selected as the eariiest possible year for the start or the program. (:'.'J'ote: the reference to the ·· 1993 AQ~P emissions .. means that the 1987 actuai reported emission inventory would be reduced five percent per year in accordance v.1th the 1991 AQMP.)

Step one is an important provision designea to preclude emission 'Jacksliding. Three possible higher starting emission points were considered:

• first increase represents actual reported emissions averaged over a three-year period (1989-1991), or

.A second increase represents highest actual reported emissions over a three-year period ( 1989-1991 ). or

* third .increase :-epresems permitted e:nissions r·or sources which have previously provided ~SR offsets.

These three higher starring poims are shov.n on the second two charts. (;-.rote: chartS are not to scale.)

In analyzing each alternative, staff and the program committees evaluated the issues of equity, air quality impacts, and administration. Alternative A recognizes a facility's higher historic (or permitted) emissions as granting them a right to a larger "fair-share" slice of the 1993 emissions pie. Alternative B uses the same ''fair-share" logiC as Alternative ~ but in addition provides a three year catch-up (or amortization) period. Under both alternatives, existing ERCs will be honored and reissued as a part of the Baseline.

In order to provide miximum equity. each facility's RECL.\.IM baseiine will be calculated under Alternative B. llSing permitted leveis for NSR sources ( * ). In order to reduce any potential air quality impacts. each individual facility v.111 have an accelerated rate of reduction in the first three years. Further. each facility's tradeable emissions will be limited to their 1993 share of the emissions inventory.

The three year cushion is designed to recognize today's current economic slump and provide the opportunity for incre::i.ses. in production. However, should a company decide that they do not need this cushion. and decide to sell excess emission reductions. then their facility permit emission cap wiil be automat,ically adjusted down to match Alternative A.

Fi~ _Jy, in order to mee~ federai requiremer. ·: may be necessary to "e! aside a percent o: the Baseli!i·~. ·1r establish a real-time acco:.;:::::~..: ·. "item. which .1U demonstr:-.:e the avaliability .,: ::ecessary offsets for ~ew Source Re·. :;;\.V. This issue 'Will require ; :.irther analysis.

Fe:isi'bility Sludy Summary E.X-5 March 1992

Executive Summary

I. ....

Baseline Allocation Alternatives Enuaa101'a

... , •OM•

tttJ 1••• 2010

Step One: 1993 AOMP e1T11aa•one reduced annually unu1 atta1n1T1ant

• . ... ..... , l•laa•••• I

1tlJ .... 2010

Alternallv• A: Higher emiaa1ona are prorated Dack to the eame atartlng

ttlJ 1••• 2010

point In 1993.

Annual Emission Reduction Rate

Alternative B: Program atarta with higher a11ue11ona. but catchaa up In tnrae yeara.

RECLAIM is designed to achieve air pollution reductions equivalent to the 1991 AQMP. Rates of reduction were calculated based on current :-.;ies with future effeetive compliance dates and future AQMP control measures.

ROG sources will be required to reduce ROG 5 percent per year from the initial baseline. This translates into approximately 5 .8 percent annual reduction from each year's ending balance for the first ten years. A second annual rate of reduction will be calctilated for the period 2000 to 2010. With a ROG annual reduction rate of approximately six percent. the Basin is l!xpected to meet the California Oean Air Act (CCAA) requirements for ROG emissions in 1994. 1997. and 2000.


: BASELINE +

E.X-6

!I

~i -1 Annual Rate i of Reduction i

I

I

March 1992

Execuuve Summary

~O'{ sources will be required to reduce approximateiy 8 percent per year from the initial baseline until 2005. The percent of annual reductions from each yeats ending balance v.iil be determined during rule deveiopmem. With an S percent reduction rate. state and federal ~O~ standards will be achieved by 1995. :ind federal P'-f:o standards will be achieved by 2005. Since the federal ·ozone standard would not be r::et until 2010. and the state ozone and P~10 standards will not be met until beyond 2010. additional NOx reductions may be needed.

Working Paper #5 indicated that the program may result in increased NOx emissions in the northern Orange County area and in portions of San Bernardino County. Additional consideration will be given to the NOx reduction rate. ...\ minor increase in the rate may be warranted.

A SOx program. although it would be much smaller in scope than the ROG or NOx programs. may meet or exceed air quality and puiJiic health goals and could result in decreased compliance costs for these industries than :he current regulatory program. ...\n emission reduction rate of approximately 8.5 percent ;:>er year from the initial 1994 baseline until the year :W05 would be needed to achieve equivaient emission reductions as the 1991 AQMP projects from the affected sources. The inclusion of SOx in REClAIM will be examined funher during rule development.

Facility Permits

Facilities under REClA.IM will be given a facility-wide permit that will detail all emission sources at the facility. This "bubble" permit will establish the facility mass emissions limit and specify the annual reduction targets for each of the next 10 years.

In addition to the emissions target. quarterly emission limits will be established for rhe facility, based on historical production limits for the facility. The permit will also define compliance. tracking, monitoring, and reporting requirements. Each Facility Permit \\1ill also include facility backstop measures ro identify actions that will result from noncompliance with.program requirements.

:I

11

:i ;j

;J

I

n Facility~ -a ~ f.: Permit : ~= : :i ROG: 6'11 : "- ~ •nnyally ~

€ ~ ~oz: e,. ~ ·~ E .\IU'IU&lly ~

• Emiaa1on Caoa

• Annual Rate of Reduction

Quarterly Limits

f\Aon1torrng Reauorementa

The permit is the glue ,;f RECWM. In order for the program to be enforceable. :ill emission reductions used to achieve annual c:n1ssio:. reduction targets will be handled ::.s amendments t·J ~he permit. Explicit require:-:-ie·ms · ;:irding ::-:iding may be needed · . ensure potential emission increases .:amply W1ti1 Dismcr Rule 1401. In addition, quarteny limits on Facility Permi~ will be adjusted ro reflect ;emissions trading activities. By using the Facility Permit as the benchmark for recording :ill emission reductions proposed for

Feasibility Study Summary EX·-:' ~arch 1992

E."C.ecutive Summary

trading, the compi.iance program v.iil be able to \·erify errussion reductions through field inspections and emissions monitoring.

Pursuant to Title V of the federal Clean Air Act. ::. ::ew application wiil be required at least every five years. The permit appiication will inciucie the facility's plans to accompi!5h their annual rates of reduction and compiy \l.ith the program. ...\nnual per;mit renewal v.ill be linked to submission of a facility emissions and ~ompliance repon · ~ith an associated emissions fee payment.

Compliance

The largest obstacle facing tlie design of any market ince·ftive program is enforcement. Increased flexibility comes at the cost of higher ievels of assurance that the emission reductions are real. permanent. and enforceable. Compliance under RECLajM has five components:

1. ~ass balance ;:-~ission Caku!ations curre::!iy used to report emission fees. and evaluate permits tbased on the national standards of AP-42);

2. Emission Limits by type of equipment or product (based on source testing);

3. Real Time \fonitoring, for example. Continuous Emissions ~onitoring

Systems/Remote Terminal Cnits. credit cards with telephone reports. bar code readers. and scannable forms (different tools will be applicable based on the source, the process, and the pollutant);

4. Quarterly and Year End Accounting summaries of permitting, trading, and emission reports (described herein as APEP); and

5. Inspections and penalties.

The detailed requirements for each component will be different for ROG, NO'° and SOr In turn. the requirements will need to be fonher defined for individual types of sources. production lines, and processes. The first four of these components represent the protocol of verifying emission reductions at a facility.

ii l

I I

RECLAIM PROTCCCLS

:_.::lits ::iea1 :-:~oe

Mor.1:::r:r.g c~.:ir:er anc

·':'·:3r =~d

.:.c::":Jr.t1r:;

During the rule development process. the District \\ill establish a Protocol \Vorking Grm::· to funher refine Items l and 2. Item 3 is currently under research and development. Piiut project field tests \vill occur during the next year. Item 4 is also currently under comract development.

Fe3Sibility Study Summary E.X-S March 1992

Executive S wrimary

ROG Emissions i\fonitoring

Verification of ROG t!mission reductions is more complex than verifying NOx and SOx emission reductions. Cnder RECL..\IM. the ROG enforcement will require the following:

l. Emission Calculations which recognize the flow characteristics of each facility's process. including the effectiveness of control equipment (Note: most of this work is already accomplished and is based on the national standards of AP42);

2. Products certified and labeled for ROG content and uniquely labeled for tracking;

3. Monitoring of the amount of each ROG product used;

4. Monitoring of the effectiveness of control equipment;

5. Collaboration of monitoring with third party records. such as supplier invoices; and

6. Field inspection verification.

Each - RECLAlM ROG facility will be issued a District "credit" card. This card will be used to initiate each telephone entry of inventory information. Bar codes on products will be used to identify ROG content and to trace product flow. In certain instances Remote Terminal Units (RTUs) may be used to monitor the effectiveness of control equipment. ROG emissions 'Will be reported through a central computer at the District.

NOx Emissions Monitoring

In order to monitor actual NOx enuss1ons, Continuous Emissions Monitoring systems (CEMs) coupled with RTUs will be required for all large- and medium-sized NOx sources under RECL-\IM. This system of RTUs and CEMs will report into a central computer at the District. (This reporting technology is being proved for electric utilities under Rule 1135). Fuel flow meters and engine-hour meters can also be used to monitor NOx em1ss1ons. During rule development, the District 'Will determine those sources where CEMs/RTCs can be cost-effectively applied. For NOx sources where CEMs/RTIJs are not ..:est-effective. fuel flow meters will be required.

SOx Emissions Monitorin~

Similar to ~O'( emissions, actual SOx emissions will be monitored with CEMs coupled with RTUs. During rule development, the District will determine those sources where CEMs and RTUs can be cost-effectively applied.

Feasibility Study Summary E..X-9 March 1992

E.:c.ecucive Summary

Annual Permit Emission Program (APEP)

The District is currently developing the .-\nnuai Permit Emission Program (APEP). A.PEP is being designed to receive facility compliance repons for determining compliance with the emissions targets of · ·i REClAIM and other programs. receive .:

11

! eID1Ss1ons fees. renew permits upon determining compliance. issue notices of ii,·

\.iolation. imtlate field ::i.udits for :: noncompliance, compile emissions reports

ti

for air quality assessment. and audit APEP reports to identify errors.

\\'HEN will trades be allowed?

--

• Emission Reductions ere Traded

• Reductions Used in Quarter of Occurrence

• Use of Credits Requires Permit Amendment

The design of RECL\IM is based on an integrated system whfoh links the trading credit to the permit. and the permit to the compliance program. The simplicity of this system is designed to ensure compliance. Ownership of NOX' ROG. and SOx emission reduction "credits" will be reflected on the permit. Credits may be used for siting new sources and/ or achieving annual emission reduction targets.


RECL\IM is an emission reduction trading program. Reductions through add-on control equipment will be subject to: the determination of the - evaluation for compliance with District rules. including Rule l .+01. Reductions through nonphysical modifications will be handled through a simplified registration process.

:1 -~ ~11 ,, . c·-}~ 1 : ll· r·•n _-. "'"n. "'- • ......:.._ i 'I , - •. u·• - t . Ii" -! /~ ~ i

u ·i£11J i I -- ~· : :,...... ~I

I -=--1 •

l El --

E.X-10 March 1992

Executive Summary

Faciiities may sell emissions out of any quarter. Prior approval of trades will not be required. However. once ::i. .:redit is sold from a quarter. r.he :m1ss1on :-eductions must occur at the sellers facility ;:>rior to the start of that quarte:-. Thus. actual emission reductions must occur before credits for these reductions are used. In addition. the seller will be held responsible for compliance \vith their reduced permitted emission level.

The time interval for the trading unit will be integrated into the compliance determinations and !Jermit requirements. A.. quarterly limit is recommended.

Markets

.r---·===================================== .,

.,

·l

·i

Facility Permit Compliance

Although the District will not take a direct role in establishi.ng the market's structure. the District will examine ways to assist in the development of a successful market in the areas of efficiency, liquidity, and information dissemination. The District will establish an official tracking system to record all credit transactions, and support the development of market information channels to all participants.

WHERE can trades occur?

• ~ography

• Seasons

--

Tradeable credits '.vill have to be constrained for use by geography and the seasons of the year. Geography constraints will be necessary to comply with California Sensitive Zone requirements. To simplify trading. the present 38 source receptor areas used under Regulation XIII will undenrn consolidation. Further studv is . - . required to determine the ::i.ppropriate degree of consolidation.

The S€:.a! on~:: constraint will be necessary to prevent dum!Jin~ of non-,.ummer emissions into the summer ·:on;e seas...,n. Reductions fror:t seasr.:-:... ··er::::ons .ill be constr::ined re prevent winter emissions from increasing historic summer emissions. Some concern has been raised relative to the early liquidity of the market to support quarterly limits. · While liquidity is being established, some small margin of error may need to be allowed. This may

Feasibility Study Summary EX-11 March 1992

Execuuve Summary

be accomplished by using quane:iy limits on pe:;::m ;.:.nd e~sur:rnz ::-:10mg consistency between quarters instead oi months.

\VHY is this program being considered?

Todays regulatory system ploughs its \i.:ay t0 cie:.n ~ir :hrough :::. ,;iborious struggle or incremental rules. Through this process significant progress has been made. However, the battles ·are time consuming and continue to iocus on the few thousand sources currently under District permirs.

• Accelerated Emission Reductions

• Lower Costs

• Improved Public Hea1th

The goal of RECL.;JM !s to adopt one regulatory program that wiil both lower the costs of .:ompli:rnce and ensure demonstrable progress to clean air. In a Basin of roughly I.+ miilion peopie. it is· :moe:::nive :::at t~e dean :..:.ir commitment he oroadened to at.iditionai sources. Once RECL-\.IM is in place. expanding the market of permitted sources will be the second phase 9f work.

In 1989, the AQMP called for the development of one broad Best Available Retrofit Control Technology (BARCT) rule. Yet BAR CT was traditionally defined as being a=1 equipme:1t- or process-specific ree,:uirement. By standing back and redefining the goal in terms of mass emission reductions, this trading program provides accelerated BARCT for all RECIAIM facilities.

The 1991 AQMP introduced the concept of a .Marketable Permits Program (MPP) and outlined the skeleton of an idea that has now been deYe!oped into RECL.\.Ii\f. The measure in the AQMP cailed for an alternative regul:itory approach \vnich would assure. :it

a minimum. emissions reductions of 5 percent per year. RECL~IM meets that test ::md is consistent with the AQMP.

Although air quality goals can be met through tr::i,ditional rules and regulations, em;:iioyrn~ market-based approaches will reduce compliance costs. allow greater compliance tle.x.1bil!ry to affected sources. and can stimulate technological innovation. RECL..\.IM will provide incentives for sources to find cleaner and less expensive production technologies :rnd :(i

reduce pollution beyond required limits.

Feasibility Study Summary E.'X·l: Marc~ : n:

Executive Summary

Impact Analysis

Three models were used to assess the ;.1. impacts of RECL\IM compared to the

1991 AQMP relative to air quality impacts. public health impacts. and socio-economic impacts. A trading model was used to predict likely compliance and trading activities. The REMI model was used in

llllJ/MPACT ANALYSIS

an iterative fashion with the trading modei to evaluate socio-economic impacts. Trading model results were then used in the UAM model to determine the air quality impacts.

The following design issues were not re:1ected in rhe impact analysis:

• inclusion of electric utility boilers:

• higher initial baseline· and three-year catch up period;.

• restricting trades to quarters;

-·· ~. . . .

• exclusion of categories dominated by sources less than four tons per year;

• exclusion of certain essential public services; and

• mobile source credits.

Results of Impact Analysis

The results of the impact analysis is summarized below. The results of this preliminary analysis suggest that some adjustments to the initial program structure may be necessary to meet the criteria of equivalent emission reductions for NOx and to mitigate against a slight increase in PM10•

Air Quality and Public Health

• Peak regional ozone concentrations -will he similar to that projected in the 1991 AQMP. .

• Emissions of ROG and NOx will shift to_the east.

• Overall per-capita 0.::one exposure will be lov • .:r.

• PM10 concentrations will increase slightly in some areas.

Fcasibiliry Study Summary E.'X· 13

Executive Summary

Socio-Economic Impacts

• Basin-wide corr.piiance costs are iower :·or RECL.lJ~f reiative to the AQYfP in 1994 and 1997.

• Certain industries may have higher compiiance costs under RECL\1~1. These industries generaily represent small errussion sources ..

• Small sources 1 < 4 tons per year) should be considered for exclusion from the annual rate of reduction.

• There are higher opportunity costs associated with holding credits under RECIAIM than under the existing regulatory program .. Provisions should be incorporated in the design of the program to mitigate business flight. This issue will be funher analyzed during the rule development process.

~itigation of Potential Business Flight

Concerns have been raised that faciiity shutdov.ns may _increase under RECL~M .. adding to job loss. Some businesses may have additional incentive ro leave the Basin because of the profits from selling ti::eir emission allocation. The District is investigating this issue and evaluating the magnitude of this problem and possible alternatives for mitigation.

Three alternatives are described below to mitigate the potential impact of increased business flight resulting from RECIAIM:

• Alternative 1: Yfonitor shutdowns in the Basin. The ma1onty of equipment shutdowns have historically been used for on-sight mitigation through concurrent facility modifications. Facility have used internal emission reductions to offset new increases elsewhere in the facility.

• Alternative 2: T.1e business community has commented that an auction of a portion or all of the credits resulting from facility shutdowns could be held to fund job training programs.

• Alternative 3: The labor community has suggested that profits from the sale of credits generated from a facility shut down could be taxed. These funds could be used to fund job training for displaced workers.

Emission credits generared from equipment and facility shutdowns are an imponant source of future credits. Shutdown credits feed the process of technological innovation thorugh facility modernization. ~ew industrial growth has and c::i:; funher lead to job creation.

Additional analysis ~ill be conducted reiative to this issue during rule development.

Feasibility Study Summary ~{arch 1992

Executive Summary

Additional Program Recommendations

In addition to the basic foundation oi the program. the feasibiiiry study aiso addressed backstop provisions and the type oi market system necessary to support the trading aspectS of the program.

I :I !'

REC~M will give sources considerable fiexibility in emission reduction strategies. This flexibility requires enhanced compliance programs. Two types of backstop provisions are proposed - one for facilities and one for the program itself.

Facility Backstops

tllU BACKSTOP - 2 LEVELS

Facility • l'enames • lncreasea Emission Reducnons .

Program • Annual Audit

• Regiona1 Emiuions • Costs/ Jobs • Public Health

• 3YearAudil • Technology AdVancemenr

• Sunset Clouse

Program Backstops

Faciiity backstop measures are actions that will :-esult from non-compliance with RECLVM requirements. Violations of quarterly or annual limits \I.ill be considered a vioiation for each day oi the time period. In addition. facility backstops will require increased erruss1on reductions in the follo\lling year.

. Program backstaps are necessary to prevent backsliding in em1ss1on reductions and to evaluate the program's progress. RECL\lM is designed to ensure that no backsliding occurs by requiring the following:

• the initial baseline (1993) will meet 1991 AQMP progress requirements of a 30 percent reduction of the 1987 emissions inventory, although some initial adjustmentS may be needed;

• rates of reduction Vt-ill be established to prevent backsliding from AQMP progress in the early years;

• the ROG, NOX' and SOx rates of reduction will be equivalent to adopted regulations and state and federal Clean Air Act requirements:

• most housekeeping rules will remain in place: :ind.

• all existing control equipment will remain in place.

Feasibility Study Summary March 1992

Executive Summary

To evaluate the pen·ormance of the progra.-:i. annuai and three year audits are proposed. Each yea.r. an annuai evaiuation wouid be conducted to assess regional emissions. and socio-economic and public heaith impacts. b addition. a three-year audit is recommended to assess the advancement or new technoiogy. Adjustments to the program could be made after each of these audits .:o ailow for mid-course corrections. In addition. a three-year sunset clause is proposed for consideration \I.1th each three year audit.

The Backstop provisions of RECL.\.IM wiii be deveioped as pan of the basic administrative regulations for the program. Adequate Backstop provisions will go a long way to ensure the effectiveness of the program. Comments are requested on this issue.

Feasibility Study Summary EX-16 ~arch 1992

APPENDIX VllL Estimation of Cost of Acetone Work Practice Controls

Estimation of Cost of Acetone Work Practice Controls

1

O.StQ.

Assumptions: medium size operation work days per year, 250 acetone purchases, 3 000 kg/a (15 L/d) savings from work practice controls, 20% additional supeNisory time, 15 min/d cost of supeNision, $20 /h cost of operating labour, $10/h cost of maintenance labour, $15/h acetone cost $1.25 /kg proportion of acetone recycled, 30% installed still cost, $12 000 still life, 1 O a

Gross acetone usage

Cost of Work Practice Controls Cost of additional supeNision

Reduced acetone usage

savings

net cost per year

Cost of Reclamation Installed cost

Direct annual costs operating labour (0.5 x 250 x 1 O) maintenance labour (1 x 50 x 15) parts (100% of maintenance labour) utilities (allowance)

Total direct annual costs

Indirect annual costs overhead (60% annual labour + parts) admin, taxes, insurance (4% installed cost) capital recovery (10 a@ 10%)

Total indirect annual costs

Total annual cost

Reduced emissions from reclamation

savings

net cost

K0061 92-11-25 92-12-4

[Based on Appendix I: corresponds to - 4 USgal/d] [Ref 13) [Guestimate) [Guestimate) [Guestimate) [Guestimate] [Based on supplier costs] [Based on Appendix I and Ref 13) [Based on Appendix I) [Guestimate]

3 000/0.7 4 286 kg/a

250 x 15/60 x 20 == $1 250/a

0.2 x 4 286 857 kg 857 x 1.25 $1 071/a

:: 1 250 - 1 071 $179/a, or $209/Mg VOC removed

[Based on methods similar to those in ref 41) 12 000

1 250 750 750 100

2 850

1 650 480

1 953

4 083

6 933

0.3 x 4 286 1 286 kg/a 1 286 x 1.25 $1 607/a 6 933 - 1 607 $5 325/a, or $4 141/Mg voe removed.

APPENDIX IX. Telephone Conversation Record Forms

Ff process des19n Inc.

319-7531 Minoru Boulevard Richmond, BC, Canada, V6Y 1Z3 Tel: (604) 270-7356

FAX OPERATOR PLEASE DELIVER A_ COPY OF THIS FORM TO THE PERSON AT YOUR LOCATION, INDICATED BY THE ARROW IN THE LEFT MARGIN.

Fax: (604) 270-7365

TELEPHONE CONVERSATION RECORD FORM

BETWEEN: Oliver St Quintin Walter Chapman 596-1571 596-3697

DATE: 23 September 1992 AND: TIME: 11 :15 am PHONE: VERIFICATION: FAX: Sent COMPANY: King Fiber Glass Corp

13147 46th Avenue, Surrey OK as is

IBJ D D ADDRESS: OK with corrections

COPIES:

SUBJECT: B.C. Resin Market

survey of Okanagan valley from Penticton to Kami oops indicates market of $11-13 000 000 per year for all suppliers (KFGC, Gwil, Ferro, Reichhold, etc; includes glass as well as resin) coastal market of about $5 000 000 per year market fluctuates substantially according to economic conditions (know of one customer whose usage has dropped from >$1 000 000 two years ago, to about $300 000 today) estimate total present B.C. market at $15 000 000 per year 1 lb of finished material is approx 60% resin, 40% glass, and costs about $1 per lb

SUBJECT: Resin Emissions

starting to supply some vapour suppressed and low vapour resins some resins also include odour masks (e.g. peanut butter) note that styrene at low concentrations has odour similar to sewage pump stations understand that earth filters have been used in L.A. to control odours, and that exhausted earth is remediated with worms understand that in California, environmental authorities conducted a usage survey, and then imposed reported quantities as maximum usage allotments

SUBJECT: Equipment

KFGC recommend air assisted airless sprays instead of atomized air sprays spray is generated through hydraulic pressure, and air is used only to shape the spray pattern transfer efficiency with air atomization may only be 50%, but with air assisted airless can be closer to 90% Venus equipment supplied by KFGC has internal catalyst mixing in spray head (cost -CDN $9 000), to minimize escape of MEK peroxide (attacks protein) understand that external catalyst mixing is not permitted in L.A. understand that Glasscraft have created a gun with vortex/venturi tip, which has been accepted as equivalent to internal mixing (cost --:CDN $8 000) cost of gun using external mixing -CDN $4 500 to $5 000 cost of gun using air atomization -CDN $1 500 cost of air atomizing, two-quart spray pot -CDN $600 (similar to paint sprayer, but uses different tip)

SUBJECT: Cleaners

have tried various emulsion alternatives to acetone none seem to work as well imported small quantity of DBE, but suspended trials after Dupont issued skin adsorption advisory

SUBJECT: Waste Disposal

suggest contacting: James F. Andru, B.Sc. Everest Environmental Services Inc. 101-1965 West 4th Avenue Vancouver, B.C. V6J 1 M8 Tel: 739-8834 Tel: 738-9967

... 319-7531 Minoru Boulevard Richmond, BC, Canada, V6Y 123 Tel: (604) 270-7356

FAX OPERATOR PLEASE DELIVER A COPY OF THIS FORM TO THE PERSON AT YOUR LOCATION, INDICATED BY THE ARROW IN THE LEFT MARGIN. Fax: (604) 270-7365


BETWEEN: Oliver St Quintin Ray Lawrence 276-3200 276-3247

DATE: 7 October 1992 AND: TIME: 9:45 am PHONE: VERIFICATION: FAX: Sent COMPANY: WCB OK as is ADDRESS: OK with corrections

COPIES:

SUBJECT: Permissable Exposure Concentrations

Legal limits

Other

as per WCB handbook (i.e. 8 hr limits in ppm: styrene 100; acetone 1 000; methyl ethyl ketone peroxide 0.2) where multiple chemical exposure occurs, exposure has to be considered additive unless known otherwise, and an equivalent mixture exposure limit calculated do have some discretionary authority in application of limits, especially if recent information indicates a major difference from Handbook values (e.g. ethylene oxide): in such cases try for voluntary reductions standards are currently under review, with +994 g~g@~~~ target for publication

receive lots of complaints from neighbours of FRP shops currently working with GRVD (Steve Scoco (sp?) 436-6729) to assess situation of two facilities in Surrey results from these facilities are fairly typical of range encountered: hot tub plant controlled by local exhausts has in-plant styrene levels of 1 O ppm or less, and stack concentrations of 100 to 200 ppm; adjacent styrofoam plant has no styrene detected in-plant, but an odour problem may also wish to speak to Rex Eaton (276-3100) who heads up Regulatory Review Section, or Al Luck who heads up Research.

117-7431 Minoru Boulevard Richmond, BC, Canada, V6Y 1Z3 Tel: (604) 270-7356

FAX OPERATOR PLEASE DELIVER A COPY OF THIS FORM TO THE PERSON AT YQUR LOCATION, INDICATED BY THE ARROW IN THE LEFT MARGIN. Fax: (604) 270-7365


BETWEEN: Oliver St Quintin Dr Frank Cassis

DATE: 8 June 1992 9:00 am AND: TIME:

PHONE: 1 (213) 724-2440 1 (213) 720-1196 Ashland Chemical

FAX: COMPANY: ADDRESS:

COPIES:

SUBJECT: Control of VOC Emissions from FRP Manufacturing operations

Dr Frank Cassis: independent consultant, on retainer with Ashland for approximately 50% of time consult to private companies on fabrication methods and means of complying with regulatory requirements considered one of the two most knowledgeable people regarding composite plastics fabrication and emissions from such operations member of the Society of the Plastics Industry (SPI) and consultant for SPI consulting rate USO 75 per hour home address: 1680 North Redding Way, Upland, CA 91786

Regulation of fabricators in US: Washington State not as advanced as California 95% of useable information comes from California there is a California guideline for whole state, written in large part, and reviewed by FC California guideline will be gospel for other 48 states Rule 1162 just applicable to South Coast Air Quality Management District (LA) which has worst air quality problem in the nation Rule 1162 not practical nor necessary in St Louis guideline more useable in other states would not want a rule similar to 1162 to come out of BC

Possible working arrangements: if consulting assignment could be agreed, have 2 or 3 companies for which have consulted, and to which there would be no problem arranging introductions for a visit estimate that to assemble all background information used to draw up California guideline would take about 3 hrs ($225); to review proposal for BC guideline about 1 hour.

FAX OPERATOR 319-7531 Minoru Boulevard Richmond, BC, Canada, V6Y 1Z3 Tel: (604) 270-7356 Fax: (604) 270-7365

PLEASE DELIVER A COPY OF THIS FORM TO THE PERSON AT YOUR LOCATION, INDICATED BY THE ARROW IN THE LEFT MARGIN.


BETWEEN: Oliver St Quintin Wayne Barcikowski 1 (909) 396-3077

DATE: 13 November 1992 AND: TIME: 11 :00 am PHONE: VERIFICATION: FAX: Sent COMPANY:

1 (909) 396-2099 SCAQMD OK as is

IBJ D D ADDRESS: OK with corrections

COPIES:

SUBJECT: Application of Air Toxics "Hot Spots" Act AB2588 to FRP Facilities

AB2588 requires submission of emissions information has not added a great deal to available information, because District had a good feel for emissions even without the toxics program larger operations are submitting information on their own have hired a consultant to assist smaller operations submit required information to minimize burden, . and will also assist with define the health risks larger operations will have to do the health risk assessments themselves situation with styrene has been complex: suggest speaking to Office of Environmental Health Hazard Assessment for full story in summary, styrene classification has been changed, as a result of which it is unlikely that notification will be required to surrounding communities

FAX OPERATOR 319-7531 Minoru Boulevard Richmond, BC, Canada, V6Y 123 Tel: (604) 270-7356 Fax: (604) 270-7365


BETWEEN: AND: PHONE: FAX: COMPANY: ADDRESS:

COPIES:

SUBJECT:

TELEPHONE CONVERSATION RECORD FORM ·

Oliver St Quintin Michael Gudlow 1 (714) 396-2442 1 (714) 396-2099 SCAQMD

DATE: 13 November 1992 TIME: 10:30 am VERIFICATION:

Sent OK as is OK with corrections

Application of Air Toxics "Hot Spots" Act AB2588 to FRP Facilities

AB2588 requires companies to report information on emissions substances which require to be reported include styrene and acetone (revised list)

[ZJ D D

where health risks from emissions are estimated at greater than 1 in 1 000 000, requires notification of affected parties three schedules for reporting based on emission quantities (emission < 10 ton; 10 ton~ emission < 25 ton; emission;:::; 25 ton) SCAM OD is severely backlogged on work, and reporting for < 10 ton category is only coming in now (should have been 1991) will send revised list of substances, showing which are considered carcinogens

process des19n Inc.

FAX OPERATOR 319-7531 Minoru Boulevard Richmond, BC, Canada, V6Y 123 Tel: (604) 270-7356 Fax: (604) 270-7365



BETWEEN: Oliver St Quintin Dr David Lewis

DATE: 13 November 1992 AND: TIME: 3:00 pm PHONE: 1 (510) 540-3519

1 (510) 540-2923 VERIFICATION:

FAX: Sent COMPANY: Office of Environmental Health

Hazard Assessment OK as is

00 0 0 OK with corrections

ADDRESS:

COPIES:

SUBJECT: Health Concerns Status of Styrene in California

OEHHA has program for reviewing toxic air contaminants approximately some twenty chemicals have been through this process just starting to look at styrene-at very beginning of process under AB2588 ("Hot Spots" bill) facilities may be required to perform health risk assessment two lists of chemicals: those with chemical potency values determined by a thorough peer review process by California, EPA or other state agency; and those on a screening list there may be differences in individual districts, but in general:

if a facility emits a chemical on list one, a screening process will be required to assess whether there is potential for significant risk where there is significant potential risk, then a risk assessment is required if the risk assessment determines significant risk, then notification of public is required if a facility emits a chemical on the second list, risk assessment (and consequently notification) is not normally required

styrene is on screening list (i.e. at present time not required to consider styrene as a carcinogen)

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