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:
- 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.
- 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.
- Tip Pressure: The spray gun should be adjusted to the lowest
possible pressure that produces an acceptable fan pattern.
- 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.
- 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.
- 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.