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OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

15) I I-J-6 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 15 of 36 
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Peterson Products, Inc. 

Industrial Reinforced Plastics 

1325 Old County Road 

Belmont, CA 94002 

U.SA. 

(650)591-7311 

Fax: (650)591-7498 

/VVi-SZJanuary 6, 2000 

Office of Air Quality Planning and Standards 

Emission Standards Division (MD-13) 

Organic Chemicals Group 

Research Triangle Park, N.C. 27711 

ATTN: Keith Barnett 

Dear Mr. Barnett, 

I wish to thank you for the opportunity to have participated in the consultation meeting on 

December 14th, 1999 between EPA, SBA, and small business composite fabricators. I have 

submitted below my comments on the MACT proposal and how it affects my company. 

BACKGROUND 

Peterson Products is a small custom molding operation with 35 employees, founded in 1953, and 

family owned and operated. Since 1961 we have occupied a 43,000 square foot facility, (34,000 

under roof,) in Belmont, California. 

I have included a company brochure that describes the wide range of diversified product 

applications we become involved with. This translates into defining each unique application to 

determine the desired physical and mechanical property requirements. This in turn dictates 

gelcoat, resin, reinforcement, and various process considerations. 

Our most current product mix consists of composite parts from 1 to over 100 square feet in size 

and from a single prototype to over 100 of the same part on a monthly basis. Every part is 

gelcoated with HVLP (High Volume Low Pressure) type spray guns that do involve atomization. 
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All parts are laminated using either hand lay-up or spray-up or a combination of each. For hand 

lay-up applications, we utilize a non-atomized system to deposit the resin on the fiberglass 

reinforcement. For spray-up applications, spray guns that atomize the resin mixture are used. 

The reason mechanical atomization is still used for spray-up is because recently available 

flow/chop devices, (which do not atomize the material,) produce totally unacceptable results with 

vertical wall applications. 

COMPLIANCE BY AVERAGING 

In order to responsibly develop a viable compliance plan to meet the MACT draft as proposed, I 

feel we must comply with each individual floor point value. The option of averaging would be a 

poor choice for Peterson Products. 

Averaging, with our diverse customer/product base, volatile market fluctuations, and our small 

size, could potentially make us non-compliant overnight. 

Currently our largest account represents 60% of our total business. For this customer, we use a 

35% HAP resin mechanically applied (non-atomized). Loss ofthis client or even fluctuations in 

production would result in a compliant to non-compliant position by relying on averaging. 

MACT GELCOAT FLOOR VALUE 

A major hurdle to eliminating reliance on averaging is the MACT gelcoat floor value. At 30% 

HAP, it is too low. I can only assume this floor was developed from sources whose high 

throughput and specialized process(es) make the availability and use of this product possible. 

This is not the case with Peterson Products or the majority of the industry. Because of small 

purchase quantities dictated by special pigmentation, low production, and product performance 

requirements, this material is not available to us. 

In anticipation ofthe upcoming MACT requirements, I recently purchased a 34% HAP gelcoat 

which has not been tested yet, but noteworthy is the fact that it cost 26% more than the higher 

HAP gelcoat it would replace. 

I feel a 35% HAP floor for gelcoat is a more realistic goal and would make my company and the 

composites industry less reliant on averaging. 

NEW/RECONSTRUCTED SOURCES 

Because of the age and condition of our current facility, Peterson Products has initiated a 5-year 

plan to relocate. 
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At the December 14th meeting, it was conceded that it was not economically feasible for smaller 

(less than 100 TPY) businesses to meet the overall control of 95% emissions. For a company like 

Peterson Products at 10-15 TPY, it is totally out ofthe realm of consideration. 

In spite of this, the MACT proposal for new and reconstructed source requirements have no 

provisions for sources of different size. 

If this proposal, as written, becomes the final rule, it will effectively dictate a finite business life 

for my company and, over time, eliminate all small composite businesses in this country. 

There simply must be some consideration of size in this part of the rulemaking, applying the 

same economic rationale that was used for existing sources. 

In conclusion I would like to say that Peterson Products is working diligently to utilize all viable 

materials and equipment whose use will result in reduced emissions. 

I am in hope that the efforts of everyone involved in this rulemaking process results in a healthy 

environment for all our interests. 

Sincerely, 

ZpH>ra+rf/? 

Kenneth R. Anderson, 

Chief Executive Officer 
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• Compression Molding 

• Resin Transfer Molding 

• Hand Layup and Sprayup Molding 

• Casting 

• Machining 

• Custom Painting 

• Mold Making 

er$on f-^roclucts 

Reinforced Plastic Composites 

1325 Old County Road 

Belmont, California 94002 

U.S.A. 

FAX 415/591-7498 

415/591-7311 
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f 0 fi C E 0 PLASTI C C P 0 S I T E S 

Products fa energy*—meeting llie challenge qf physical and em ironm ni 

Electronic: Computer housings and keyboards 

Instrument cases 

I li-tecb speaker housings 

Medical: MRI. X-Ray and CAT scan 

machines 

Enclosures and patient beds 

Architectural: Building facades 

Planters 

Airport departure gate signs 

( orrosion: I [azardous waste containment 

pallets 

Plating tanks 

Agricultural sprayer tanks 

Peterson Products is committed to providing you the 

ultimate in experience, reliability and quahty < .'all us 

with vour project. 

!n ,ll Ulillisllll 
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IHII ! A l^eterSon [-^rocuiiLs 

Products for the electronics Industry 

EXPERIENCED PEOPLE 

Peterson Products has been recognized national!} for 

excellence in design and applications, reflecting the 

capabilities of a company that has devoted its total 

efforts to tlie development ol reinforced plasties 

technology 

Because of our efficient organization, we have the 

capabihty to respond both quickly and thoroughly to 

Our clients needs. This has resulted in ein excellent 

reputation tor meeting cost projections, mastering 

difficult design criteria, and delivering on schedule. 

Witii tliese Strengths, We are prepared te assist you in 

the design and engineering of your product Irom 

protohpe through production. This assures you 

the same quahty custom molded fiberglass 

product we have been supplying our clients 

since 1953. 

The best time to discuss som-project requirements is during the earlv desicn stages. This uill 

enable our stall to render advice on tolerancing, 

phvsical and mechanical property requirements, anc 

the selection of materials, 

RELIABLE MAT LIU ALS 

The unique properties ol reinforced plastic compos 

ites make them suitable lor a wide range "I product 

applications and oiiei advantages not to be found with 

other types oi construction. These advantages Include 

• 1 Ugh strength to weight ratio 

• High flexural strength 

• I Kgh resistance to environmenta] extremes 

• High resistance to chemicals andoth-t i corrosive 

environments 

• High degree of design flexibility parts 

nsolidation 

QUALITY PRODI (I S 

Our customers benefit from Peterson Products' 

experience in diversified product applications. 

These applications induct! 

Transportation: Railn iad signal equipment 

Truck cabs and bodi' 

Aircraft engine inlet covers 

Marine: Miscellaneous ship repairs 

I .ilemit containers 

Protective shaft w rap lor ships 

Prodtu I-- 'Imi i'n1 

i•,/. tluraliilUy />" 

tin i nh i IIIIIIIIII nl 

llullf.ll lj 
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I H E RICHES T QUALIT Y I N RE INfORCE O PLASTI C COMPOSITE S 

A j eter Son j^rociucLs