Moonlight strikes back

Industry Talk
1

Whoa what is going here?

A surfermag moderator has opened another can of worms about Greg?

http://forum.surfermag.com/forum/showflat.php?Cat=&Number=944284&page=0&view=collapsed&sb=5&o=&fpart=all&vc=1

surfermag, community, message boards, design forum

Title:

Has Greg Loehr opened up a glass shop in California yet?

This is strange . . . This one seems like “I’m scared and threatened I don’t know what to do, so I’ll use blind frustation”

But TFAD’s pretty cool. I don’t know personally know him, but he’s been really nice when responding to my posts.

The other day a kid was getting a board done at Pavel’s shop . . . Pavel himself was there. He asked about epoxy glassing. The kid wanted pu. He said he it was his last (the kid). I was astounded.

Wow, I didn’t think TFAD would post something like that.

2

[=1]

Quote:

[ 3]The other day a kid was getting a board done at Pavel’s shop . . . Pavel himself was there. He asked about epoxy glassing. The kid wanted pu. He said he it was his last. I was astounded. [/]

Are you saying Pavel is not doing PU anymore?

Also I read that thread and I cant speak for Greg and since the thread is for Greg to answer anything anyone posts is pure speculation. At a guess it would seem as blakestah posted that “look! there arent any sucessfull 100% epoxy operations therefore it cant be done so lets see Greg do it”

The overall tone is ad hominem…

For what its worth I know that Greg is tending to business right now and posting anything is not a priority at the moment.[/]

3

My question for Mr. Loehr is valid and does not represent the rest of the crew at Moonlight. He opened the can of worms first, I’m just trying to follow up.

4

I think the underlying but unspoken thought is when the EPA and the State of California takes your polyester resin away from you for you to do your job what will you do then. The regs are already there it’s just a matter of time especially if there’s other viable alternatives that the EPA will say you have available to use in place of Poly Resin/Styrene Monomer/Acetone.

Hopefully the shops you are asking about will be up and running full bore when the legislative hammer comes down. I bet they will be as the smell of money is hard to ignore you can already see it in the foam wars just starting. I’m sure we all here are hoping that the great glassing shops like Moonlight will be one of those surviving shops versus losing the business to some fly by night operator with no history in the business like you folks.

Greg’s in the right place at the time it’s a spot of no worries. He just has to concentrate on getting his productionoperation prepared for the tidal wave that will come so that he survives as well versus some big giant like Dow garbbing his piece of the pie. But then again maybe he won’t even care as long as his dream of finally getting over the fear of the epoxy hump comes to pass. He’d make more money down the road as a pay for play conversion consultant than being an production manager.

The foam was the start of it the resin will be next and who knows maybe the glass will follow if the Health people can find enough risk in the handling of it. I’m surprised some medical research facility hasn’t taken on the task of the environmental/human dangers of surfboard manufacturing, it could have a severely negative impact to insurance rates and zoning restrictions.

5
Quote:
I think the underlying but unspoken thought is when the EPA and the State of California takes your polyester resin away from you for you to do your job what will you do then. The regs are already there it's just a matter of time .

Please post the link to these regs from the EPA website, I coudn’t find anything.

6

Here’s a couple write-ups on the MACT 1162 I’m sure you can find more…

Standard

http://www.acmanet.org/ga/Proposed%20Standard%20for%20Estimating%20Emission%20Factors%20from%20Open%20Molding%20Processes%20BSR%20ACMA%20ICPA%20UEF-2.pdf

Small Business Impact

http://www.sba.gov/advo/laws/is_plasticrpt.html

I could be wrong but styrene emissions arte the problem but who knows.

Asbestos was outlawed in the shipbuilding industry…

But no one has looked at sanded fiberglass dust maybe there’s not enough lawsuit material although there’s alot of dead industry guys who didn’t make it to their 60’s-80’s

7

Heres something on styrene exposure plus the OSHA limits on styrene in the workplace

The health effects of styrene are a major concern. One of the most common ways a worker is exposed to styrene is through the inhalation of indoor air that is contaminated. Other methods of exposure may include: living near industrial waste sites, eating a lot of food that has been packaged in polystyrene containers, and inhaling air that is contaminated with tobacco smoke . Low levels of styrene occur naturally on foods such as fruits, vegetables, nuts, beverages, and meats. (ATSDR) .

The effects of styrene on the body vary with the amount of exposure. Exposure to high levels of styrene fumes during a short time will most likely result in nervous system problems. These problems are depression, concentration problems, tiredness, muscle weakness, and nausea. You might also experience eye, nose, and throat irritation. Long term exposure to styrene through inhalation has been found to possibly cause leukemia. However, there isn’t much information about the effects of swallowing or touching styrene. We aren’t sure of the effects of styrene on the human body caused by low level , long term exposure. We do know that the effects to animals include liver, kidney, brain, and lung damage. With these adverse health effects present, industry is trying to protect its workers.(ATSDR) .

There are about 90,000 American workers that are potentially exposed to styrene. The unions are taking action to help ensure that a voluntary compliance program is carried out. The terms of the program were worked out through discussions between the industry, OSHA, the UAW, and United Steelworkers Health and Safety Departments. OSHA has deferred new rule-making for styrene because of this voluntary program. (On-the-Job) .

The program will voluntarily lower styrene exposure limits to the levels set by OSHA in its January, 1989 rule on permissible exposure limits for air contaminants. This rule stated that styrene concentrations were to be limited in the workplace air to 50 ppm for an 8-hour time-weighted average. The short term exposure limit (for 15 minutes) was established at 100 ppm. In a letter to OSHA the chairman of the Society of the Plastic Industry, Styrene Information & Research Center, and nine other industry officials declared willingness to comply with the lower limits. The voluntary compliance programs calls for periodic air sampling, respiratory protection, and engineering controls, where feasible, to achieve the voluntary limits. The industry also agreed to collect exposure data and submit that data to OSHA on a periodic basis. Under the 1986 EPCRA, releases of more than one pound of styrene into the air, water, or land must be reported annually and entered into the TRI. This shows that the industry is starting to look out for themselves as well as their employees. They save by catching these problems in two ways, worker compensations and law suits. So they not only decided to be nice, but they are still helping their company. (On-the-Job) .

This article gave details about styrene as a chemical, the health effects, and how the industry is taking care of problems in the workplace. The first three paragraphs showed that the chemical styrene is used in many different places and it’s uses. They also show how they can be hazardous to people and the environment. The next few paragraphs showed the effects of styrene on human health. It states the different problems when it is inhaled and how to treat them. The last few paragraphs show the progress that the industry is showing to meet the OSHA requirements in the workplace. The industry is also taking voluntary responsibility for their employees that have to work around styrene and are finding was to protect them.

Works Cited:

Environmental Health Center (EHC) http://www.nsc.org/ehc/ew/chems/styrene.htm (02/18/98).

Agency for Toxic Substances and Disease Registry (ATSDR) http://atsdr1.atsdr.cdc.gov:8080/tfacts53.html (02/17/98).

On-the-Job Health & Safety (On-the-Job) http://www.uaw.org/uawreleases/healthsafetynews/0697/069705.html (02/18/98)

This page was served out by ZBSoft’s ZBServer Pro

8

Too late for permits…

from http://www.compositesworld.com/ct/issues/2005/August/926

There is still time to apply for a Federally Enforceable State Operating Permit (FESOP). Also known as a “synthetic minor” air permit, this simplified air quality compliance option could enable your composites manufacturing facility to avoid the more complex and restrictive Reinforced Plastic Composites Maximum Achievable Control Technology (MACT) requirements imposed by the National Emission Standards for Hazardous Air Pollutants (NESHAP). But you must act now: Only nine months remain until the April 21, 2006 compliance deadline. Completing the permit process can take six to eight months. Facilities seeking hazardous air pollutant (HAP) synthetic minor status must obtain a final permit before April 21, 2006 because once a facility becomes subject to MACT, the facility is always subject to MACT.

Open molding facilities will derive the greatest benefit from synthetic minor permits, because they are subject to more NESHAP compliance requirements than closed-molding operations. If an open molder can demonstrate that its emissions stay below HAP major source thresholds, it can drastically simplify compliance by complying with a synthetic minor permit in lieu of NESHAP requirements.

A synthetic minor permit limits HAP emissions to less than the major source threshold imposed by MACT. A facility may obtain a FESOP if its actual HAP emissions are less than the HAP major source threshold and its potential HAP emissions are greater than the threshold. For HAPs, the major source threshold is the potential to emit at least 10 tons per year (tpy) of any single HAP or 25 tpy of all HAPs combined. According to the U.S. Environmental Protection Agency (EPA), potential emissions must be calculated assuming that the facility is operating 24 hours per day, 365 days per year. The only way to reduce potential emissions is to obtain federally enforceable emission restrictions via a federally enforceable permit (such as a FESOP or Title V operating permit) or a federally enforceable regulation, such as a volatile organic compound (VOC) state regulation that is part of an EPA-approved state implementation plan.

There is one case in which FESOPs are not needed when potential HAP emissions exceed major source thresholds. Composite parts manufacturers with very low resin and gel coat usage rates are exempt from NESHAP requirements. If the total usage of styrene-containing resin and gel coat (combined) is less than 1.2 tpy, a facility is automatically exempt from the composites NESHAP.

If you determine that a synthetic minor permit is advantageous, then your goal is to obtain the least restrictive synthetic minor permit. Your facility should seek a permit that 1) caps emissions at the HAP major source thresholds (if possible), and 2) minimizes all other requirements. At the very least, the permitting authority will require your facility to demonstrate that actual emissions do not exceed the permit’s limits. The permit will include recordkeeping and reporting requirements designed to demonstrate compliance with the new permit’s emission limits.

<img src="http://www.compositesworld.com/ct/issues/2005/August/926-a.gif" alt="" class="bb-image" />

In addition, the synthetic minor permit will include several pages of boilerplate language. Each permitting agency has its own list of provisions regarding inspections, fees, permit modification and renewal procedures, noncompliance reporting procedures and legal provisions. As with Title V operating permits for major sources, this language is designed to notify synthetic minor facilities of all state and federal requirements that already apply to the facility. Well-written permits will provide the state or federal regulatory citation for each requirement.

Your facility should ensure that the synthetic minor permit clearly identifies and distinguishes between federally enforceable requirements and state-only requirements. When state-only requirements form the basis for the facility’s limit on potential-to-emit, the resulting emission limits must be identified as federally enforceable provisions. For example, a permit issued to a hot tub manufacturer by the Florida Department of Environmental Protection restricts emissions of a single HAP to 9.9 tpy and emissions of combined HAPs to 9.9 tpy. The 9.9-tpy combined HAP limit imposed by the Florida rule is more restrictive than the limit required under the federal 25-tpy major source threshold. In this case, therefore, the FESOP turns a state-only requirement into a federally enforceable requirement.

Permits issued by the Indiana Department of Environmental Management take several different approaches. For one composite parts manufacturer, an 8.8-tpy styrene emission limit applies to the entire facility. However, to avoid monitoring or estimating emissions from insignificant activities, the facility is required to demonstrate that total emissions from the company’s two significant styrene emission units do not exceed 7.2-tpy on a 12-month rolling basis. At another Indiana composites facility, facility-wide emissions are limited to below 10 tpy for a single HAP and below 25 tpy for combined HAPs.

There appears to be a disconnect between the basis for determining annual emissions when comparing the definition of a HAP “major source” to frequently used FESOP requirements. As defined in U.S. Environmental Protection Agency (EPA) regulations, a “major source” of HAPs is determined on a “per year” basis. Typically, this type of emission trigger has been interpreted as the potential to emit during a calendar year. Consequently, it seems reasonable that FESOP provisions would require that compliance demonstrations be determined on a calendar year basis. However, many FESOPs require facilities to demonstrate compliance with synthetic minor emission limits on a 12-month rolling basis. In effect, the 12-month rolling compliance demonstrations included in the reinforced plastic composites NESHAP are bleeding into FESOPs.

Remember, the advantage of a FESOP lies in avoiding NESHAP requirements. If your permitting authority proposes 12-month rolling compliance demonstrations, ask the agency for the underlying state or federal requirement and point out that NESHAP requirements do not apply to your facility (that is the whole idea behind obtaining a FESOP). Aside from the extra recordkeeping and reporting work involved with 12-month rolling emission tallies, this compliance basis puts a facility at risk for more enforcement actions.

A good FESOP minimizes compliance requirements and allows maximum operational flexibility to the composites facility. However, the procedure for quantifying emissions should be clearly explained and should either specify emission factors or identify the resource from which emission factors can be obtained. Specifically, the permit should identify 1) insignificant emission units that will be excluded from emission calculations, 2) emission units to be included in the calculation, 3) emission control equipment and control factors and 4) emission calculation equations. With this detailed information, the facility can produce reliable figures for total emissions. Typically, permits will require facilities to maintain monthly purchase records for HAP-containing resins, gel coats and solvents, as well as Material Safety Data Sheets (MSDS) for each of these materials. In best-case scenarios, facilities will submit emission and compliance reports once a year. However, some permitting authorities require more frequent reporting.

To begin the FESOP process, you can obtain a FESOP application form by either calling your air quality permitting authority or visiting that agency’s Web site. Many state and some regional EPA office Web sites post online examples of synthetic minor permits for composite parts manufacturers. Although the information-gathering process for the application may seem daunting, don’t be deterred. If you miss out on obtaining a FESOP, your facility will go through an even more complex permitting process to obtain a Title V operating permit (assuming that you do not already have one).

9

rule 1162

<div style="text-align:right">(Amended December 7, 1990) (Amended August 2, 1991)(Amended July 10, 1992) (Amended May 13, 1994)(Amended November 17, 2000) </div><span style="font-weight:bold">

RULE 1162. POLYESTER RESIN OPERATIONS

(a) Applicability

This rule shall apply to all polyester resin operations that fabricate, rework, repair,

or touch-up products for commercial, military, or industrial use including, but not

limited to, boats, tubs, pools, shower enclosures, spas, bathroom fixtures, jigs,

tools, molds, air pollution control equipment, sewage treatment equipment,

storage tanks, transportation parts, and other industrial and consumer products.

(b) Definitions

For the purpose of this rule, the following definitions shall apply:

(1) AIRLESS SPRAY is a coating application system in which the coating

fluid is supplied to the gun under fluid pressure and air is not added to the

gun.

(2) AIR-ASSISTED AIRLESS SPRAY is a coating application system in

which the coating fluid is supplied to the gun under fluid pressure and air

is combined at the spray cap.

(3) CORROSION-RESISTANT MATERIALS are polyester resin materials

used to make products for corrosion resistant applications such as tooling,

fuel or chemical tanks and boat hulls.

  1. (4) EXEMPT COMPOUND is as defined in Rule 102.
    1. (5) FIRE RETARDANT MATERIALS are polyester resin materials used to
    2. make products that are resistant to flame or fire.
  2. (6) GEL COAT is a polyester resin surface coating, either pigmented or clear,

that provides a cosmetic enhancement and improves resistance to

degradation from exposure to the elements.

(7) GENERAL PURPOSE POLYESTER RESINS are materials that are not

corrosion resistant, fire retardant, high strength, vapor suppressed, or gel

coats.

(8) HIGH-STRENGTH MATERIALS are polyester resins which have casting

tensile strength of 10,000 psi or more and which are used for

manufacturing of high performance boats and skis.

1162 - 1

Rule 1162 (Cont.) (Amended November 17, 2000)

  1. (9) HIGH-VOLUME, LOW-PRESSURE (HVLP) SPRAY is a coating application system which is operated at air pressure of between 0.1 and 10 pounds per square inch gauge (psig) at the air cap of the spray gun.
  2. (10) MONOMER is a relatively low-molecular-weight organic compound such as styrene that combines with itself, or other similar compounds, by a cross-linking reaction to become a cured thermosetting resin.
  3. (11) POLYESTER RESIN MATERIALS are unsaturated polyester resins, such as isophthalic, orthophthalic, halogenated, bisphenol A, vinyl ester, or furan resins; cross-linking agents; catalysts; gel coats; inhibitors; accelerators; promoters; and any other material containing VOC used in polyester resin operations.
  4. (12) POLYESTER RESIN OPERATIONS fabricate, rework, repair, or touchup products for commercial, military, or industrial use by mixing, pouring, hand laying-up, impregnating, injecting, forming, winding, spraying, and/or curing by using unsaturated polyester resin materials.
  5. (13) PULTRUSION is a process where continuous roving strands are moved through a strand-tensioning device into a resin bath for impregnation and then passed through a heated die for curing.
  6. (14) REPAIR is that portion of the fabrication process that requires the addition of polyester resin materials to portions of a previously fabricated product in order to mend damage.
  7. (15) TOUCH-UP is that portion of the process that is necessary to cover minor imperfections.
  8. (16) VAPOR SUPPRESSED RESIN is a polyester resin material which contains additives to reduce VOC evaporation loss to less than sixty (60) grams per square meter of surface area as determined and certified by resin manufacturers.
  9. (17) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102.

(c) Requirements

(1) For each process, a person operating a polyester resin operation shall comply with either the material requirements or one of the applicable process requirements set forth below:

1162 - 2 

<span style="font-weight:bold"> <div style="text-align:left">Rule 1162 (Cont.) </span></div> <span style="font-weight:bold"> <div style="text-align:right">(Amended November 17, 2000) </span></div>   <div style="text-align:right">(A) </div>  <div style="text-align:left">Material Requirements </div>   <div style="text-align:left">A person shall not use a polyester resin material in a polyester </div>   <div style="text-align:left">resin operation which has a monomer content in excess of the </div>   <div style="text-align:left">limits specified in the Table below. </div><span style="font-size:6px">

Polyester Resin Materials General Purpose Polyester Resin Corrosion-Resistant Fire Retardant High Strength Clear Gel Coat Pigmented Gel Coat Monomer Content in Polyester Resin Materials as Applied (By Weight Percent)

35
48
42
48
50
45

(B) Process Requirements

  1. (i) The weight loss of polyester materials shall be less than four (4) percent when a closed-mold system is used.
  2. (ii) When a vapor suppressed resin is used, the weight loss from VOC emissions shall not exceed sixty (60) grams per square meter of exposed surface area during resin polymerization.

(iii) A pultrusion operation shall have covered wet-out baths. From the exit of the bath to the die all but 18 inches of the preform distance shall be enclosed to minimize air flow. The weight loss of polyester materials shall be less than three (3) percent in a pultrusion operation.
  1. (2) For spraying operations, in addition to complying with the requirements specified in paragraph (c)(1), a person shall use high-volume-low-pressure (HVLP), airless, air-assisted airless, or electrostatic spray equipment. For touch-up and repair, a hand-held, air-atomized spray gun which has a container for resin as part of the gun may be used.
  2. (3) Any person operating a polyester resin operation shall keep the resin materials in closed containers except when filling or emptying the container.
  3. (4) Solvent cleaning operations shall comply with Rule 1171 - Solvent Cleaning Operations.

1162 - 3

Rule 1162 (Cont.) (Amended November 17, 2000)

  1. (d) Control Equipment In lieu of complying with the requirements of paragraph (c)(1) and (c)(2), a person may install and operate an emission control system which is designed and operated in accordance with guidelines published in the 20th Edition of the Industrial Ventilation Manual by the American Conference of Governmental Industrial Hygienists for the collection of fugitive emissions from polyester resin materials, and which system is approved by the Executive Officer’s designee, and has an overall capture and control efficiency of 90 percent or more on a mass basis.
    1. (e) Recordkeeping Requirements
    2. (1) A person subject to the provisions of this rule shall maintain daily records. Alternatively, records may be kept on a monthly basis provided the polyester resin process or equipment is not subject to a daily production limit or daily VOC limit in any applicable District rule(s) or permit(s). Such records shall be made available to the Executive Officer’s designee upon request and shall be kept for not less than two years. The records shall contain:
    3. (A) The manufacturer’s name, the type and amount of each of the polyester resin materials used; and
    4. (B) The weight (in percent) of monomer for all polyester resin materials, and, if adding VOC-containing materials to the polyester resin, the amount of VOC-containing materials, in grams, and the VOC content in grams per liter, of VOC-containing materials; and
    5. (C) For vapor suppressed resins, a certificate from a resin manufacturer for each resin type; and
    6. (D) For closed-mold and pultrusion systems, the weight loss (in percent) of polyester resin materials for each application.
    7. (2) Records for cleaning solvents subject to Rule 1171 - Solvent Cleaning Operations shall be maintained pursuant to Rule 109.
    8. (3) Any person using an emissions control system as a means of complying with this rule shall maintain daily records of all key system parameters, including hours of operation, temperatures, pressures and flow rates, that are necessary to ensure control efficiency requirements.
1162 - 4

Rule 1162 (Cont.) (Amended November 17, 2000)

(4) The records shall also contain the manufacturer’s name, type and amount of corrosion resistant, fire retardant, high strength materials and gel coats used.

  1. (f) Methods of Analysis The VOC content of each of the polyester resin materials shall be determined by using USEPA Reference Method 24 (Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of Surface Coating, Code of Federal Regulations Title 40, Appendix A, utilizing Procedure B of ASTM Method D2369), or the SCAQMD Method 304. The monomer content shall be determined by Method 312, and weight loss of polyester resin materials shall be determined by Method 309; and the exempt compound’s content shall be determined by Methods 302 and 303 in the South Coast Air Quality Management District’s (SCAQMD) Laboratory Methods of Analysis for Enforcement Samples.
    1. (g) Test Methods
    2. (1) The efficiency of the control device and the VOC content measured and calculated as carbon in the control device exhaust gases shall be determined by USEPA’s Test Method 18, or Air Resources Board (ARB) Method 422 for the determination of emissions of Exempt Compounds and USEPA’s Test Methods 25, 25A, or SCAQMD’s Method 25.1 (Determination of Total Gaseous Non-Methane Organic Emissions as Carbon) for the determination of total organic compound emissions. Emissions determined to exceed any limits established by this rule through the use of any of the above-referenced test methods shall constitute a violation of the rule.
    3. (2) The following classes of compounds: cyclic, branched, or linear, completely fluorinated alkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations; and sulfurcontained perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine, will be analyzed as exempt compounds for compliance with subdivision (e) at such time manufacturers specify which individual compounds are used in the coating formulations and identify the test methods, which, prior to such analysis, have been approved by the USEPA and the SCAQMD, that can be used to quantify the amounts of each exempt compound.
1162 - 5

10
Quote:
...Blakestah posted that "look! there arent any sucessfull 100% epoxy operations therefore it cant be done so lets see Greg do it"

But there are. And Greg’s involved.

Federal & even State regulations notwithstanding, the City of Santa Cruz (or maybe the County, I don’t know for sure) has put a moratorium on permitting any additional polyester glass shops.

About 2 years ago when Geoff Rasche (M10) wanted to build his own soup-to-nuts factory, they told him, sorry, no polyester.

So…he hired George Greene (Bob Miller’s old epoxy & sandwich glasser) and brought in Greg for consulting and Greg’s resin. Now, his boards (both EPS and PU foam) are all 100% Resin Research epoxy.

He complained at first, but now says its one of the best things that ever happened to his business - his boards are lighter, better performing, & longer lasting than his competitors’.

Its a familiar story - someone gets dragged into epoxy through no fault of their own, and ends up finding its actually better. Same story with Stretch and even now with Rich Harbour (see the harbour surf forum - he’s posted a lot recently about his results with heavier EPS and RR epoxy).

Greg’s resin is the only one these guys are all using. None of these guys is an industry lightweight.

11

opps sorry, I mean the kid said that was his last polyester.

Dudes thanks for the crazy (cool) info. That’s why I love sways. If I was stuck on an engineering mainly world, i’d be a groupie.

12

So… is 1162 a SCAQMD rule (applies only in Los Angeles area) or is it being adopted by the EPA (applies in USA)?

Looks to me like the former but I haven’t studied up on this stuff.

13
Quote:

So… is 1162 a SCAQMD rule (applies only in Los Angeles area) or is it being adopted by the EPA (applies in USA)?

Looks to me like the former but I haven’t studied up on this stuff.

I believe AQMD covers all of california.

14

Actually there are a lot of AQMDs in California, each with its own territory.

SCAQMD South Coast Air Quality Mgmt District = Smog control agency for all or portions of Los Angeles, Orange, Riverside and San Bernardino Counties

15

Google search seems to imply that all the AQMDs follow 1162

16

I don’t know, I’m not an expert in this area and it sure is confusing. But, I pulled up the Sacramento AQMD (just as a random search of one county) and didn’t find any reference to 1162 there. They have their own rule 465 that’s been there since 1998. (of course, they also have a rule for adhesives, and one for degreasing, and one for pretty much anything you can think of…)

Then I looked at San Diego AQMD web site, it also didn’t come up with any hits for 1162. They did have a reference to NESHAPS (National Emission Standards for Hazardous Air Pollutants) in the place where 1162 could have been (right before some rules numbered in the 1200s). So maybe San Diego uses the federal rules?

But I noticed in the article you posted (by the evironmental consultant) says:

If the total usage of styrene-containing resin and gel coat (combined) is less than 1.2 tpy, a facility is automatically exempt from the composites NESHAP.

1.2 tons per year sounds like a lot of boards to me. Thats 2400 pounds of resin. At about 10 pounds per gallon, that’s 240 gallons of resin.

So would small glass shops in San Diego (for example) be exempt??

17
Quote:

I don’t know, I’m not an expert in this area and it sure is confusing. But, I pulled up the Sacramento AQMD (just as a random search of one county) and didn’t find any reference to 1162 there. They have their own rule 465 that’s been there since 1998. (of course, they also have a rule for adhesives, and one for degreasing, and one for pretty much anything you can think of…)

Then I looked at San Diego AQMD web site, it also didn’t come up with any hits for 1162. They did have a reference to NESHAPS (National Emission Standards for Hazardous Air Pollutants) in the place where 1162 could have been (right before some rules numbered in the 1200s). So maybe San Diego uses the federal rules?

But I noticed in the article you posted (by the evironmental consultant) says:

If the total usage of styrene-containing resin and gel coat (combined) is less than 1.2 tpy, a facility is automatically exempt from the composites NESHAP.

1.2 tons per year sounds like a lot of boards to me. Thats 2400 pounds of resin. At about 10 pounds per gallon, that’s 240 gallons of resin.

So would small glass shops in San Diego (for example) be exempt??

Keep in mind that California has some of the toughest enviormental laws. It would seem that every county is subject to some form of 1162.

Even if shops are eligible to be exempt from MACT neshap the article I posted talks about applying for title V permits to gain this exemption. Since the time to apply has long past that means shops are now subject to MACT neshap and a rigorus inspection process. My interpretaion is if you are inspected you better have all your ducks in a row.

18

The article you posted says that if you are exempt from the federal emission regulation (NESHAP) based on having less than 1.2 tons per year of resin use you wouldn’t need a permit to get that exemption (the facility is automatically exempt).

Seems to me that some people are trying to say that the strictest laws apply everywhere. That’s just not necessarily the case, unless every jurisdiction adopts them (or there are federal laws that cover the whole country). Nor should it be. Los Angeles air basin has a lot of concerns that just don’t apply to, e.g. Shasta County. Or most anywhere else in the world for that matter… It’s economically inefficient (and also basically illogical) to apply laws that suit the air concerns in LA to everywhere else.

19
Quote:

The article you posted says that if you are exempt from the federal emission regulation (NESHAP) based on having less than 1.2 tons per year of resin use you wouldn’t need a permit to get that exemption (the facility is automatically exempt).

Seems to me that some people are trying to say that the strictest laws apply everywhere. That’s just not necessarily the case, unless every jurisdiction adopts them (or there are federal laws that cover the whole country). Nor should it be. Los Angeles air basin has a lot of concerns that just don’t apply to, e.g. Shasta County. Or most anywhere else in the world for that matter… It’s economically inefficient (and also basically illogical) to apply laws that suit the air concerns in LA to everywhere else.

That seems to be correct,

If 1Gal of resin = 10lbs then 55gal in a drum you would need to use 4 drums a year to be exempt…if my math is correct thats 300 boards a year…thats pretty small to be exempt. Major glass shops pump out 100+ per week

And no im not saying the strictest laws apply eveywhere but just in general.

When I was looking into this issue I was looking at this as a single issue but after re reading Clarks final letter to the industry I realized its not one issue but MACT is just one part of the big picture. MACT, AQMD, OSHA, Fire dept, etc. etc…

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But no one has looked at sanded fiberglass dust maybe there’s not enough lawsuit material although there’s alot of dead industry guys who didn’t make it to their 60’s-80’s

My employer mines and distributes silica sand (among other products) to such industries as glass manufacturers, foundries, and sand blasters. I see no reason to suppose that the behavior of silica dust from sanded fiberglass would be substantially worse than the dust produced in those other pursuits. If a significant fraction of silica fines remained bonded to resin, it could be far more benign. The question of the long term effects of silica fines and silicosis at least have, in fact, been examined extensively by the EPA and the civil courts. Just last year an appellate judge named Janice Jack tossed a slew of class action silicosis lawsuits because lawyers had colluded with and paid off doctors for the wholesale manufacture of diagnoses with no medical basis. Those doctors and some of the lawyers may face perjury and other charges (as a sidelight, some of those same teams of lawyers and doctors were instrumental in the class litigation that finished off Johns Manville and the asbestos industry…). I’m neither a doctor nor a lawyer, but it does not appear probable to me that there are serious damaging effects from moderate exposure to silica dust alone. Obviously other conditions and exacerbating exposures (smoking, for one) could potentially influence the effect on a given individual.

“Industry guys who didn’t make it to their 60’s-80’s”. May I assume that many of those industry guys were also surfers? How many died of melanoma? What is the statistical relationship of life expectancy between surfers who never glassed, glassers who didn’t have a beach lifestyle, and individuals who did both? How does urethane/styrene/acetone exposure factor in? What about foam dust? Lots of questions, few answers…

-Samiam