Fiberglass & Composite Manufacturing

 

Why Should My Business Try To Reduce Air Pollution?
Fiberglass and composite manufacturers generate hazardous and non-hazardous air emissions, solid waste, and water wastes. The emissions from processes and materials may also impact worker health and safety.

The most significant environmental concern is due to the use of resins and gelcoats during fabrication. These materials are considered hazardous substances and sources of toxic air emissions, primarily because of styrene content. Styrene is used as a reactive diluent in the fabrication process - it thins the polyester resin, and also provides the "bridge" to "crosslink" the polyester molecule chains. Styrene is a volatile substance, and a percentage of it escapes from the resin during application and curing phases. As it escapes from the resin matrix, it becomes an "air contaminant" that is regulated by SCAPCA and other health and safety and environmental agencies.

Other hazardous substances used in the fabrication process are resin catalysts, solvents, paints, thinners, foaming agents, and adhesive products.

Businesses that choose to minimize the use of traditional resins and solvents and change to low volatile organic compounds (VOC) and low hazardous air pollutant (HAP) products are moving in the same direction as federal, state and local regulations. The switch to these new materials not only decreases emissions, but may also reduce nuisance complaints from neighboring businesses and the public.

How Does SCAPCA Regulate Fiberglass and Composite Manufacturing?
All new air pollution sources, modifications to existing sources, and new or altered air pollution control equipment in Spokane County are required to obtain an approved Notice of Construction from SCAPCA prior to the construction, installation, establishment, or modification of the source, according to SCAPCA Regulation I, Article V. This includes chemical processes which release VOCs and HAPs into the air. Visit the previous menu for information on the Notice of Construction process and/or an application packet.

In addition, SCAPCA Regulation I, Article IV lists categories of sources that have been identified as having potentially significant air emissions. Businesses that fall into these categories, including fiberglass and composite fabricators, are required to register with SCAPCA unless an exemption is granted. SCAPCA regularly inspects registered businesses. Information on the registration process may be found in the previous menu.

What Does SCAPCA Look For During A Facility Inspection?
Periodically, a SCAPCA inspector will conduct an inspection of your facility. Your operations will be examined to verify compliance with local, state and federal air quality regulations.
  • Notice of Construction conditions of approval (if applicable)
  • Types of products and solvents used
  • Weekly/monthly product and solvent purchase/usage records
  • Material Safety Data Sheets (MSDS)
  • Equipment maintenance logs
  • Waste disposal manifests
  • Pollution prevention techniques and opportunities
  • Application equipment operation
  • Spray booth and filter condition, if applicable
  • Process techniques and controls
  • Clean-up procedures
  • Products and solvents storage
  • Waste storage
  • System air flow
Which Products Are Of Air Quality Concern?
Emissions from fiberglass and composite manufacturing include VOCs and toxic air pollutants. In the presence of sunlight, VOCs participate in a complex reaction with oxides of nitrogen to form ozone. Ozone is a strong irritant that attacks the lungs, makes breathing difficult, and irritates the eyes. Toxic air pollutants may be carcinogenic and have other potential health impacts.

The major toxic air pollutants emitted during fiberglass and composite manufacturing are styrene, methyl ethyl ketone peroxide (MEKP), methyl methacrylate, toluene, xylene and methylene chloride.

Air quality concerns include:

  • Resins and Gelcoats are hazardous because they contain VOCs and toxic air pollutants. Styrene, a common component of resin and gelcoats, is the main toxic air pollutant of concern. It also has a low odor threshold and may cause nuisances.
  • Initiators and catalysts are hazardous because they often contain the toxic air pollutants methyl methacrylate and MEKP.
  • Solvents such as acetone, methylene chloride, toluene, xylene, and various alcohols are toxic air pollutants and VOCs. Many solvents are probable carcinogens.
  • Paints and stains, thinners, adhesives, and foaming agents contain VOCs and may also contain toxic air pollutants. Waste streams containing VOCs and toxic air pollutants must be managed properly to reduce air emissions.

Why Should I Evaluate My Environmental Management Approach?
Your fiberglass and composite manufacturing shop can become both environmentally friendly and cost efficient by establishing an effective environmental management program. Good environmental management can limit some typical business expenses and help avoid environmental compliance costs.

In addition to reducing emissions to the air, your business can gain an economic edge by reducing waste management costs, improving worker safety, decreasing future liability, and increasing productivity.

What Technologies Can Help Me Reduce Air Emissions & Improve Efficiency?
Pollution Prevention (P2) is any practice that reduces or eliminates the creation of pollutants through increased efficiency in the use of raw materials, energy, water, or other resources.

Fiberglass and composite fabrication activities that can benefit from P2 include:

  • equipment or technology modification;
  • process modifications;
  • reformulation or redesign of products;
  • substitution of raw materials; and
  • improvements in housekeeping, maintenance, training, and inventory control.

A variety of fiberglass fabrication technologies and materials have been evaluated to identify P2 opportunities. The evaluations, derived from the publication, "Waste Reduction Strategies for Fiberglass Fabricators", by David Hillis and Darryl Davis of Eastern Carolina University, and from suppliers and vendors of the technologies, can be reviewed on the Pollution Prevention Research CenterĘs web page (http://www.pprc.org/pprc/sbap/fiber/p2techs.html). Additional informational resources are listed at the end of this publication.

The technologies and/or opportunities are organized in two different categories - Process Methods and Equipment and Process Materials. For each technology, case studies from Northwest companies using the technology, as well as vendors selling the technology, are presented. They include:

Process Methods and Equipment:

  • Prepreg Fiber Reinforcing
  • In-House Resin Impregnation
  • Resin Rollers - Spray-less Application Systems
  • Flowcoaters and Flowchoppers
  • Vacuum Bag Molding
  • Infusion or SCRIMP Process
  • Infusion with a Semi-Rigid Cover
  • Resin Transfer Molding (RTM)
  • Rotational Molding of Small Tanks
  • Electrostatic Gel Coating
  • Controlled Spraying

Process Materials:

  • Low Styrene Resins (25-35% styrene)
  • Vapor Suppressed Resins
  • Catalysts
  • Laminating with UV Resins
  • Waterborne Gel Coats
  • Polyurethanes and Polyurethane/Polyester Blends
  • Acetone Substitutes
How Can I Optimize My Spraying Techniques?
Optimization of spray gun set-up and spraying technique is the first line of pollution prevention and source reduction in polyester/vinyl ester resin spraying operations. These methods provide a "win-win" scenario for mitigating styrene emissions while providing cost savings. It is recommended that all spray application equipment be optimized, and spraying techniques aimed at reducing overspray be adopted to achieve emissions reductions. Following are specific recommendations for spray application optimization:
  1. High-Volume, Low-Pressure Spray Guns: Use high transfer efficiency methods, such as HVLP spray guns, to increase the percentage of product deposited during surface applications. If you use application methods with high transfer efficiencies, preferably in excess of 65%, you will buy less raw material and save money.
  2. Spray Equipment Set-up: Spray tips should be sized for a specific application, in order to spray from between 12" - 18", or as close as reasonably possible, from the surface. The primary method for adjusting material flow rate is varying the spray tip orifice size. The fan pattern width is adjusted by selecting the appropriate orifice angle.
  3. Tip Pressure: The spray gun should be adjusted to the lowest possible pressure that produces an acceptable fan pattern.
  4. Spray Operator Training: Operator training is a critical part of the optimization plan. This training should include:
    • The use of proper spraying techniques;
    • An understanding of the function and proper set-up of spray equipment; and
    • An understanding of the effects of overspray.
  5. Spraying Technique: Handling of the spray gun is a critical element of optimizing the process. In simple terms, where the gun is "aimed" is very important. The following techniques are designed to minimize "off-spray" and reduce wet surface area surrounding the mold.
    • The spray gun should be held as close to the mold surface as possible, in consideration of the material output, fan pattern size, and size and configuration of the mold.
    • The fan pattern intercept angle should be maintained as close to perpendicular to the mold surface as possible.
    • The perimeter of the mold should be sprayed as accurately as possible, avoiding spraying off the edge to the greatest extent possible.
  6. Overspray Capture/Mold Edge Configuration: It is a distinct advantage to capture "off-spray" as close to the mold edge as possible. When considering the geometry of spray off the edge of the mold, the total wet surface area increases considerably as the "footprint" of the overspray area increases. It is recommended that a wide flange be incorporated at the mold perimeter, or an arrangement of masking the mold edge be used. The objective is to spray to the useful edge of the part and contain as much overspray as possible with the masking around the mold perimeter.

What Else Can I Do To Improve My Environmental Management?
A variety of practices will help your shop realize the benefits of effective environmental management. Consider the following suggestions:

Use Pollution Prevention Techniques
Be sure to keep informed of pollution prevention opportunities to identify ways to reduce air emissions and improve the quality of Spokane's air. In addition to using the ideas and pollution prevention references listed above, consider incorporating the following techniques into your manufacturing processes:
  • Use operator training to improve application techniques and reduce overspray.
  • Use non-atomizing application equipment, where feasible.
  • Use low-styrene or styrene-suppressed materials, where feasible.

Control Your Inventory
Making sure that products purchased are the least likely to cause air quality concerns is an important first step. In addition, materials break down during extended storage time and become hazardous wastes. Consider incorporating the following into your purchasing procedure and inventory control:

  • Substitute non-hazardous and low VOC materials for hazardous materials whenever possible - make sure your purchasing agent knows the correct products to purchase.
  • Mark purchase date on containers and monitor inventory to assure that older materials are used first.
  • Order materials on an as-needed basis.
  • Discontinue use of methylene chloride and other highly toxic solvents. Other solvents are available that are less toxic.
  • Purchase the smallest amount of solvent and other chemicals to do the job; waste disposal costs for unused chemicals may be higher than the savings of buying materials in bulk quantities.

Keep Good Records
Record keeping is an important tool of environmental compliance. Keep detailed records of products of air quality concern used at your facility. Monthly logs should detail the products purchased, including the name and number of the product, and the amount of product purchased, with the appropriate quantity indicated (i.e., gallon, quart, pint). Remember that SCAPCA inspectors look for accurate records.

If you have received a Notice of Construction approval from SCAPCA, the conditions of approval may include limitations on annual process material usage. Do not use more than you are allowed. Be careful with multiple shifts. Modify your production to avoid penalties. If you are unable to modify your production, contact SCAPCA prior to exceeding limitations. SCAPCA will work with you on ways to increase production while staying in compliance.

Train Your Employees
It is important that employees are aware that the cost of a job is influenced by the quantity of materials used and how they handle materials that will become hazardous wastes when discarded. Consider the following when developing your employee training program:

  • Proper training can provide a safer and healthier workplace.
  • The importance of reading Material Safety Data Sheets (MSDS). These sheets provide a list of toxic and hazardous compounds and VOC content found in the products. Reading an MSDS before making a purchase could help avoid problems later.
  • The need to use a minimal amount of solvents or other chemicals.
  • An employee training program will also enhance public image for your business and reduce liability. It will also show your customers and employees that you are taking extra steps to make your workplace better.

Use Good Housekeeping Techniques
Good housekeeping can prevent spills, reduce air emissions, and assure efficient use of raw materials. The following good housekeeping practices should be considered for your shop:

  • Always keep containers with processing materials and solvents closed when not in use to prevent valuable materials from evaporating.
  • Always segregate wastes to increase recyclability. By mixing hazardous wastes with non-hazardous wastes, the entire volume may be considered hazardous waste, which increases disposal costs.
  • Designate one person to manage raw materials and to ensure that solvents and hazardous wastes are properly controlled.
  • If the materials have exceeded their shelf life, return them to the manufacturer or supplier.
  • Keep equipment in good working condition. Preventive maintenance and regular inspections for proper operation will reduce air emissions.
  • Minimize spills and use dry methods for cleanup whenever possible.
  • Be innovative, try new procedures and products. Be sure to call SCAPCA prior to any modifications to check on additional requirements.

Store Products, Solvents, and Wastes Properly
Tightly seal all containers of products, solvents, and wastes. Cans and drums should be equipped with tight fitting lids and should remain closed between uses to prevent evaporation. Large drums should have screw caps to cover the bung holes and should be opened only to empty or fill the drum. Use a pump or funnel when filling and make sure to close the drum completely when you are finished. Use funnels that screw into the bung of drums and have a lid that clamps down on top of the funnel for a tight seal.

All solvent laden rags and cloths, including those used to clean parts and spray equipment, should be stored in closed fireproof containers. Store and dispose of materials in accordance with local fire department, solid waste, and State Department of Ecology requirements.

Dispose and Recycle Wastes Properly
Try to eliminate, reduce, and/or recycle waste whenever possible. Never put hazardous waste into the dumpster or down the drain. Put all the hazardous wastes in one area, be sure to separate your waste storage area from your product storage area, and label each of your containers. Make sure you dispose of your waste according to the applicable hazardous waste laws.

Check Out Emerging Technologies
Ongoing research identifies new technologies that have the potential to provide high quality products and reduce air emissions. Check out some of the resources below for more information on fiberglass and composites research that may provide new ideas on how to improve your manufacturing process and products and help keep Spokane County's air clean.

Where Else Can I Find Information To Help My Business?
There are a variety of resources available that will help you learn more about ways to reduce air emissions and reduce environmental problems. Many of the following resources will also help you identify ways to save money and stay competitive:

Pollution Prevention Resource Center
The Pacific Northwest Pollution Prevention Resource Center has a comprehensive Business Assistance Network web site that has extensive information on fiberglass and composites regulatory information, new technologies/processes, new products, case studies/research results, vendors, industry experts, and publications. The networkĘs web site also has numerous links to additional information sources and industry trade associations.

Northwest Business Assistance Network
Pacific Northwest Pollution Prevention Resource Center
1326 Fifth Ave, Suite 650
Seattle, WA 98101
phone: (206) 223-1151
fax: (206) 223-1165
http://www.pprc.org/pprc/sbap/fiber.html

Industry Associations
Assistance from industry associations may help your business understand regulatory requirements and identify new techniques to help you stay competitive.

Composites Fabricators Association
1655 N. Ft. Myer Dr., Suite 510
Arlington, VA 22209
phone: (703) 525-0511
fax: (703) 525-0743
http://www.cfa-hq.org/

National Marine Manufacturers Association
200 E. Randolph Drive, Suite 5100
Chicago, IL 60601
phone: (312) 946-6200
http://www.gsn.com/iww/customers/NMMA/

Oregon Reinforced Plastics Association
3434 S.W. Water Avenue
Portland, OR 97201
phone: (503) 228-3387
fax: (503) 228-3388

Agency Assistance
A variety of non-regulatory assistance is available for small businesses with air quality questions. The purpose of these programs is to:

  • explain the air quality rules and recommend ways to comply;
  • provide free, on-site technical assistance visits;
  • help businesses estimate their air pollution emissions;
  • refer businesses to needed resources; and
  • provide information on potential sources of financing for compliance requirements.

For more information, refer to the contacts listed below.

Spokane County Air Pollution Control Authority
1101 W. College Ave., Suite 403
Spokane, WA 99201-2094
(509) 477-4727
fax: (509) 477-6828
e-mail: scapca@scapca.org
http://www.scapca.org/

Washington State Department of Ecology
N. 4601 Monroe, #100
Spokane, WA 99205-1295
(509) 456-2926
http://www.wa.gov/ecology/

U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-1200
http://www.epa.gov/

Available Documents
Numerous documents are available that may help your business. The following documents can be obtained by calling the indicated resource and referencing the document information.

Baseline Characterization of Emissions from Fiberglass Boat Manufacturing. National Marine Manufacturers Association (NMMA). 1997. Call (312) 946-6200 to order.

Pollution Prevention Annual Progress Report for the Fiberglass Reinforced Plastics Sector. Washington State Department of Ecology - Hazardous Waste and Toxics Reduction Program. 1997. To order call (360) 407-6752.

Guides to Pollution Prevention - The Fiberglass-Reinforced and Composite Plastics Industry. United States Environmental Protection Agency - Office of Research and Development. 1991. EPA document number EPA625791014. Call 1-800-490-9198 to order.

Evaluation of Pollution Prevention Techniques to Reduce Styrene Emissions from Open Contact Molding Processes. Research Triangle Institute and United States Environmental Protection Agency. 1997. EPA document number EPA-600/R-97-018A dated March 1997. Call the National Technical Information Services at 1-800-553-6847 to order and request Stock No. PB97-181440. There is a $21.50 charge.

Introduction to Composites: Composites Fabrication. Composites Fabricators Association. 1985-1998. Call (703) 525-0511 to order.

Phase I - Open Molding Styrene Emissions Test Project. Composites Fabricators Association. 1996. Call (703) 525-0511 to order.

Guide To Pollution Prevention: The Marine Maintenance and Repair Industry. Environmental Protection Agency. 1991. EPA document number EPA625791015. Call 1-800-490-9198 to order.

Assessment of VOC Emissions from Fiberglass Boat Manufacturing. United States Environmental Protection Agency. 1990. EPA document number 600290019. Call the National Technical Information Services at 1-800-553-6847 to order and request Stock No. PB90-216532. There is a $27.00 charge.

What Other Agencies Regulate Fiberglass and Composites Fabrication?

Some of the other agencies that regulate fiberglass and composites manufacturing include:

  • City of Spokane Fire Department, call 625-7000 for the inspector in your area.
  • County Fire Districts, check the phone book for the district in your area.
  • Spokane County Division of Building and Planning, call 477-3675 for information.
  • City of Spokane Construction Services, call 625-6300 forinformation.
  • Other city/town building and planning departments, check your local phone book for numbers
  • Washington Department of Labor and Industries, call 324-2600 for information.
  • Washington Department of Ecology, call 456-2926 for information.

Your operations are likely regulated by additional agencies. Refer to SCAPCA's information sheet - Common Environmental Permits Required in Spokane County.

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