p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

44) IV-C-17 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 44 of 273 
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PES 

A MACTEC COMPANY 

Pacific Environmental S 

5001 South Miami Boulevan 

P.O. BOX 12077 

Research Triangle Park, NC 27709 

A-94-52 

IV-C-17 

Office: 919/941-0333 Fax: 919/941-0234 

Home Page: www.mactec.com 

February 22, 2002 

Mr. Glenn Miller 

GHM, Incorporated 

RRl,Boxl286A 

Qrwigsburg, PA 17961 

Dear Mr. Miller: 

! FEB 2 2 2002 

;TU,-A-.i**4L\\ 

6;y.' 

I spoke with Dennis Miller of your company on February 21,2002. Pacific 

Environmental Services, Inc., (PES) is the contractor to the U.S. Environmental Protection 

Agency (EPA) on the reinforced plastic composites (RFP) NESHAP. PES is currently assisting 

the EPA in preparing responses to public comments received on the proposed RFP NESHAP. 

One ofthe comments questions the feasibility ofthe proposed standard for tooling gel coats, 

which is equivalent to a tooling gel coat with a HAP content of 38 percent by weight. In order to 

respond to this comment, PES is contacting those facilities in our database that reported using 

tooling gel coats with HAP contents of 42 percent or less. Your facility in Orwigsburg, PA, was 

identified as one of these facilities. 

Attached is a list of questions that we would like answered in order for us to respond to 

the comments we have received on the proposed standard for tooling gel coats. Based on the 

responses, the final rule may have a standard that is the same ofthat proposed or that is less 

stringent (i.e., allow for the use of a tooling gel coat with a higher HAP content). Therefore, your 

help in answering the attached questions is very important to EPA's effort to promulgate a rule 

based on the best available information. 

If you have any questions concerning this request, please do not hesitate to contact me at 

919-941-0333. Our EPA Projectl^ead is Mr. Keith Barnett. He can be reached at 919-541-560-^5-

Please feel free to call him if you have any questions. If any ofthe information you can supply is 

considered to be confidential by your company, we can provide you with the procedures that are 

used to submit such information directly to the EPA. Thank you in advance for whatever help 

you can provide. 

Sincerely, 

Kenneth R. Meardon 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Enclosure 
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TOOLING GEL COAT RESIN QUESTIONS 

Please answer the following questions/provide the following information. Table 1 can be used 

for items 1 through 5 below. 

1. Please list each tooling gel coat you use at your facility, its supplier, and its HAP content as 

applied. 

2. Please identify whether the tooling gel coat is used for the production of molds or the repair of 

molds. 

3. Please identify the type of products produced by each type of mold. 

4. Please identify the life of each mold. For each mold type, how often can it be used before it 

needs to be reworked or discarded and a new one made to replace it. 

5. How frequently is each mold used (e.g., once a day, once a week)? 

6. Please describe briefly the finish characteristics associated with the products produced from 

each type of mold. For example, is the surface ofthe end product eventually covered in some 

fashion or is it the final surface that a consumer sees. 

7. Have you used tooling gel coats with higher HAP contents than the one(s) you are currently 

using? Ifyes, please briefly describe how the production/repair of molds has changed as the 

result ofthe change in HAP contents. 

"2, 
TABLE 1. TOOLING GEL COAT TABLE 

V * 

Tooling Gel Coat 

Identifier 

Example: 

Polydyne 151 Orange 

Supplier 

Polydyne 

HAP 

Content 

38 

Production 

or Repair? 

Production 

Types of Molds 

Produced/Repaired 

shower stalls, bath tubs 

Frequency of 

Use of a Mold 

once per day 

Life of Mold 

two months 

•*•