VOC rules challenge FRP processors.

Composites processors that use unsaturated polyester resins must soon report their emissions of styrene monomer to their state environmental authority. Sweeping new environmental regulations under Title V of the 1990 Clean Air Act amendments require EPA to certify programs in every state to limit emissions of volatile organic chemicals (VOCs) and hazardous air pollutants. To satisfy EPA, the states must require all major emissions sources (defined as ones likely to emit more than 10 tons per year of hazardous air pollutants - including styrene) to document their emissions and obtain state operating permits (see PT, Feb. '95, p. 83).

Although timetables vary state by state, the new rules will begin to take effect this year. In 1997, FRP processors face even more stringent MACT (maximum achievable control technology) regulations. Any new facility or modification to an existing facility that would increase emissions by more than one ton per year of styrene would require MACT. Exactly what MACT will be has not yet been defined by EPA.

PROCESSING EMISSIONS STUDY

In order to help processors apply for Title V operating permits, a comprehensive study was begun last month at Dow Chemical Co.'s Freeport, Texas, research facility. The study is designed to identify exact levels of styrene emissions from open-mold processing. The program is sponsored and managed by the Composite Fabricators Association (CFA), headquartered in Arlington, Va.

The test program is part of a coordinated effort of four industry groups (CFA, SPI, the National Marine Manufacturers Association, and the International Cast Polymer Association), known as the Clean Air Management Partnership (CAMP). The mission of CAMP is to provide a unified industry effort to work with EPA in developing emissions standards that will affect plastics.

Bob Lacovara, CFA technical director and head of the test project, describes it as the most precise, definitive styrene-emissions study ever undertaken for open molding. EPA officials will monitor tests that will be conducted under a rigid format of quality-assurance procedures. "In the past, no two studies on styrene air emissions could ever be compared," Lacovara says. "Our program will have approved and documented test procedures, sophisticated instruments, and highly controlled conditions."

Even though EPA isn't legally committed to using the results of the test program, Lacovara says a "basic understanding" exists that the test data will be recognized as the "best available" to help establish EPA's MACT styrene emission levels.

The first phase of testing is slated to be completed this month. This phase will establish baseline air-emission levels from open-mold fabrication methods such as spray-up, hand lay-up, and gel coating.

Phase two of the study will examine current technologies for reducing styrene emissions and how these methods can best be employed by processors. They include alternative processing methods (e.g., replacing spray guns with pressure-fed hand rollers), faster-curing resin formulations, and additive packages that can limit styrene emissions.

A third phase of CFA's test program will be to investigate new or experimental ways of reducing styrene emissions and to develop a computer model that would enable processors to calculate their plants' air emissions.

In the meantime, Steve McNally, CFA director of regulatory affairs, says processors may consult with CFA on strategies for limiting styrene emissions. An initial plant review includes such things as improving maintenance or repair of fluid-handling equipment; using closed-top resin containers for storage, operation, and purging; and improving employee training to prevent leaks and spills. A more ambitious review would involve evaluating reduced-emission processing methods or alternative resin formulations that speed up gel and cure times and/or include additives that inhibit styrene emissions.

ACETONE IS IN THE CLEAR

In the September 30, 1994 Federal Register, EPA proposed to exempt acetone from the VOC regulations, based on evidence that acetone contributes very little to smog. EPA also proposed to delete acetone from the list of hazardous substances subject to reporting under Section 313 of the Emergency Planning and Community Right to Know Act. If the latter proposal becomes final, processors will no longer have to report usage or emissions of acetone in their annual EPA Form R filings.

While no processor will object to reduced paperwork, implications of the other EPA proposal may be less welcome. State and local environmental officials and individual processors may no longer count on reduced acetone emissions (attained through switching-to non-solvent cleaners) to meet targets on overall VOC reduction. If acetone is removed from consideration, FRP processors in some localities may feel increased pressure to reduce other VOCs - e.g., styrene.