About Fiber Reinforced Plastic Manufacturing
Fiber-reinforced plastic (FRP), also known as fiber-reinforced polymer, reinforced plastics/composites, or fiberglass, is a composite material made of a polymer matrix reinforced with fibers. The polymer is usually an epoxy, vinyl ester, phenolic resin or polyester thermosetting plastic. The fibers are usually glass, carbon or aramid. In some processes, resin products are fabricated without fibers, such as synthetic marble. Fiber-reinforced plastics products have a wide range of application in industry, transportation, home, and recreation. Generally, the manufacturing of these FRP products has the potential to emit air pollutant emissions of volatile organic compounds (VOCs), Hazardous Air Pollutants (HAPs), and in some case, Particulate Matter (PM).
Sources that engage in the production of FRP products must calculate their potential to emit VOCs and HAPs (and sometimes PM). There are many ways to produce FRP products, therefore, a source must take into account the materials being utilized in the process, and the molding or casting methods used. The American Composites Manufacturers Association (ACMA), (formerly the Composite Fabricators Association (CFA)) worked with the IDEM, Office of Air Quality (OAQ) to develop emission factors for open molding systems. These Unified Emission Factors for Open Molding Composites [PDF] were revised and updated in October of 2009. Emission Factors for Closed Molding processes can be found in the U.S. EPA’s AP-42 (Section 4.4, Fifth Edition, Volume I). IDEM's Compliance and Technical Assistance Program (CTAP) uses these approved emission factors for calculating potential emissions for sources applying molding practices, and helps businesses understand the state and federal rules that they may be required to comply with for their individual processes.
CTAP is available to assist Indiana’s businesses engaged in stationary engines. Contact CTAP using the CTAP Partner Portal to request help. It will require setting up a free account through Access Indiana.
State and Federal Rules:
The Clean Air Act (CAA), as amended in 1990, mandates that emissions of 187 Hazardous Air Pollutants (HAPs) be controlled through regulation. The CAA mandated that the U.S. EPA target industries that potentially emit these regulated HAPs, and promulgate standards for these major categories through the National Emissions Standards for Hazardous Air Pollutants (NESHAPs). Two of the categories initially identified by the U.S. EPA related to FRP production were Reinforced Plastic Composites Production (RPC) and Boat Manufacturing.
Subpart WWWW—National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production
- eCFR Subpart WWWW - National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production
- 326 IAC 20-56 [PDF] Reinforced Plastic Composites Production (incorporates by reference 40 CFR 63, Subpart WWWW)
Subpart VVVV—National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing
- eCFR Subpart VVVV - National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing
- 326 IAC 20-48 [PDF] Emission Standards for Hazardous Air Pollutants for Boat Manufacturing (incorporates by reference 40 CFR 63, Subpart VVVV)
Guidance
Subpart WWWW:
- Initial Notification Form for FRP [PDF]
- National Emission Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production - Implementation Documents
- Reinforced Plastic Composites NESHAP Applicability Flowchart [PDF]
Subpart VVVV:
- Boat Manufacturing: National Emission Standards for Hazardous Air Pollutants (NESHAP)
- Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials
Calculating Emissions:
- Unified Emission Factors [PDF]
- Gelcoat Non-atomized Application Factors [PDF] (Table 1, 40 CFR 63, Subpart WWWW)
- Example Calculations for the Reinforced Plastic Composites Production NESHAP [PDF] (26 pp, 84 K, 12/2005)
Compliance Assistance Resources
- Health and Safety Guidance - Styrene Control [PDF]
- Compliance Guide for Small Businesses to the Reinforced Plastic Composites Production, 40 CFR 63, Subpart WWWW (September 2005) [PDF]
- Wisconsin DNR: Fiberglass Reinforced Plastics