OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

5) ll-C-31 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:45:55 PM Sheet 5 of 343 

p.1 
P.2 

A-94-5Z 

^eo sr,,, 

SR o 

\ PRO^° 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

MAY 9 1996 

Mr. Stephen McNally 

Composite Fabricators Association 

1735 North Lynn Street, Suite 950 

Arlington, Virginia 22209-2022 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

tyS* EPAAIHDOCiXgr** 

Dear Steve: 

Thank you for your letter of April 11, 1996 regarding your 

concerns with the maximum achievable control technology (MACT) 

floor determinations for the reinforced plastic composites source 

category. We look forward to meeting with you and getting your 

ideas after we have completed further analyses and potential 

subcategorization of the open molding subcategory. We are also 

waiting for the Office of Research and Development to analyze the 

data from the "filled resin" study, as we have recently learned 

that these may affect the floor analysis. 

Before we get together, I wanted to address the issue of the 

LASCO facilities raised in your letter. We want to make sure 

that we have accurate data, so we are enclosing the data we have 

that led to the conclusions you have questioned. 

Enclosed are data that show that the LASCO facilities that 

have control devices use them to control not only the gelcoating 

operations, but also some resin operations. The 50/95 in the 

charts indicates that since LASCO does not know the capture 

efficiency for this particular process, it is assumed to be 

50 percent; the 95 indicates the destruction efficiency of the 

thermal oxidizer. The "control factor" values presented in the 

March 20, 1996 presumptive MACT meeting account for the extent 

that resin operations are controlled based on this data. Also 

enclosed is information provided by LASCO regarding the South 

Boston facility. We classified a barrier coat as a resin based 

on this information. We would be interested in a definition of 
P.3 

gelcoat versus resin that would take into account the formulation 

or chemical differences as well as the functional differences. 

Please let me know if there are errors in this information 

so we can incorporate the changes into the data base. 

Thank you, and we look forward to speaking with you soon. 

Sincerely, 

Madeleine Strum 

Coatings and Consumer Products Group 

2 Enclosures 
SENT BV-TOMKINS IND.. INC. 11- 1-30 iii-DiAM ;LA5C0 D/n-DNLiitLKtUll"' J1J -J41 *Uj6t1,rr T/4 

LASCO BATHWARE 

3255 east Miraloma Ave. 

Anaheim, CA. 92806 

F A X 

DATE: 

TO: 

FROM: 

RE: 

CC: 

COVE R 

November 1,1995 

Madeleine Strum 

USEPA 

M. Wm. Seymour 

LASCO Bathware 

S H 

TIME: 

PHONE: 

FAX: 

PHONE: 

PAX: 

Averaging (Control Status) Format 

G.Lowe 

E E T 

10:49 AM 

(919) 541-2328 

(919) 541-5689 

(714) 993-1220 

(714) 524-8784 

Number of pages induding cover sheet 5 

Message 

MadeleineHere is the best infonnation I have at this time. We did not pursue the 

variances in styrene content as a percent of the resins content when different 

on a plant by plant fcwsis. Instead we have talcen data on the relevant averages 

of the each process .area aa predicate within your chart 

Again there is some degree of variance in the cure factor (gr/m2) results 

between one process .area, or type, due to the differences in material 

processing viscosities, cure times and peak exothermic temperatures. However, 

we do have a-considerable amount of cure factor data based of the 1162 can Hd 

test, and we feel these results are fairly representative. 

Total (tpy) have t»en taken straight from or latest 1994 TRI reporting data 

sheets. 

If you have questions or need further information, please do not hesitate in 

contacting me. 

Thante, 

J > 
StNi tit- lOMKllXs UNU. . »INC. 'il -

 L~dO > i i • vJ-irtlU -L-nO^V ii/ i* UMJUIVJU-JJI I P.5 

Plant Moapa, NV. 

(1994 - TRI Reporting Data - Unavailable) 

Material 

Resin 1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

BamerCoat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

Cpy) 

N/A 

N/A 

N/A 

CUre Factor 

with 

filler 

(g/m2) 

38.7 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

54.4 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

182 

202 

36.4 

HAP 

content 

w/o 

filler 

% 

47.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

0/0 

0/0 

070 

Application 

Method 

*• 

AS 

AS 

AS 

Plant YelnuWA. 

(1994 - TRI Reporting Data) 

Material 

Resin 1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

BamerCoat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

AS 

GS 

GS 

Quantity 

fay) 

2245 

267.8 

241.1 

603.7 

Cure Factor 

with' 

filler 

(g/m2) 

42.1 

39.4 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

57.5 

56.1 

44.8 

N/A 

HAP 

content 

with 

finer' 

% 

18.5 

21.6 

202 

36.4 

HAP 

content 

w/o 

filler 

% 

48.0 

49.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

070 

0/0 

0/0 

OA) 

. 

Application 

lUethod 

AS 

AAS 

AS 

AS 

4 
iDN l Dl • lUMMIVi UU». uno. 

TT I \73 * 11 • 'J—rui*—7\W~~~~—uJ II—uiuauiaTM^-

P.6 

Plant: 

Material 

Resin 1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

Barrier Coat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

AS 

GS 

GS 

South Boston, VA. 

(1994 - TRI Reporting Data) 

Quantity 

Opy) 

1.782 

795 

213.5 

479 

Cure Factor 

with 

filler 

(o/m2) 

42.1 

39.4 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

57.5 

58.1 

44.8 

N/A 

j 

HAP 

content 

with 

filler 

% * 

18.5 

21.6 

202 

36.4 

/ 

HAP 

content 

w/o 

filler 

% 

48.0 

49.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

50/95 

0/0 

0/0 

50/95 

Application 

Method 

*• 

AS 

AAS 

AS 

AS 

Plant Anaheim, CA. 

(1994 - TRI Reporting Data) 

Material 

Resin-1 

Resin 2 

Resin 3 

Resin 4 

F?esin5 

BamerCoat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

Opy) 

2838.3 

297.2 

760.5 

Cure Factor 

with' 

filter 

fe/m2) 

42.1 

32.7 

55.0 

Cure Factor 

w/o 

filler 

<g/m2) 

57.5 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

18.5 

202 

36.4 

HAP 

content 

w/o 

filler 

% 

48.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

0/0 

0/0 

0/0 

t 

Application 

Method 

•• 

AS 

AS 

AS 

6 
01-4*1 U l ' .Vl'lHlils J Ull^ . , 4t»v*. P.7 

Plant Lancaster, TX. 

(1994 - TRI Reporting Data) 

Material 

Resin 1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

Barrier Coat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

Cpy) 

2,069 

190.3 

556 

Cure Factor 

with 

filler 

(g/m2) 

42.1 

32.7 

55.0 

Cure Factor 

w/o 

filler 

<g/m2) 

57.5 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

18.5 

202 

36.4 

HAP 

content 

w/o 

filler 

% 

48.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

50/95 

070 

50/95 

Application 

Method 

AS 

AS 

AS 

Plant Elizabethtown, PA. 

(1994 - TRI Reporting Data) 

Material 

Resin-1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

Barrier Coat 

Gdcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

Gpy) 

1,897 

227.8 

541 

Cure Factor 

with' 

filler 

(g/m2) 

42.1 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

57.5 

# 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

18.5 

202 

38.4 

HAP 

content 

w/o 

filler 

% 

48.0 

45.0 

N/A 

Add-On 

capture/ 

control 

50/95 

50/95 

50/95 

t 

Application 

Method 

•• 

AS 

AS 

AS 

G 
OI_nl U l • IVIFUM44J iiuy . P.8 

Plant Three Rivers, Ml. 

(1994 - TRI Reporting Data) 

Material 

Resin 1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

BamerCoat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

(tpy) 

2,535 

280.4 

685.1 

Cure Factor 

with 

filler 

(g/m2) 

4Z1 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

57.5 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

18.5 

202 

36.4 

^ 

HAP 

content 

w/o 

filler 

% 

48.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

0/0 

0/0 

070 

Application 

Method 

AS 

AS 

AS 

Plant Cordele, GA. 

(1994 - TRI Reporting Data) 

Material 

Resin-1 

Resin 2 

Resin 3 

Resin 4 

Resin 5 

Barrier Coat 

Gelcoat 1 

Gelcoat 2 

Gelcoat 3 

ID 

GS 

GS 

GS 

Quantity 

Cpy) 

1,814 

162.6 

470 

Cure Factor 

with 

filler 

(g/m2) 

42.1 

32.7 

55.0 

Cure Factor 

w/o 

filler 

(g/m2) 

57.5 

44.8 

N/A 

HAP 

content 

with 

filler 

% 

18.5 

202 

36.4 

HAP 

content 

w/o 

filler 

% 

48.0 

45.0 

N/A 

Add-On 

capture/ 

control 

%/% 

070 

070 

0/0 

1 

Application 

Method 

AS 

AS 

AS 

n 
P.9 

^HadhrYvLfvf

 c^~ 

U.S. EPA / LASCO Bathware 

South Boston Plant Visit 

Thursday June 22,1995 

1. What is the number of employees at the South Boston fadlity? 

LASCO Bathware's South Boston facility emphys a total of 280 

people, which Includes all management and office staff personnel, as 

well as, plant personnel and truck drivers. Our South Boston facility 

is also one of the top 10 employers within the South Boston, Halifax 

County area, with respect to total number employed. 

What is your latest calculation of styrene emissions and the 

methodology used? 

The methodology used in our determination of styrene emissions is 

EPA Method 24A FID and EPA Method 25. Based upon the results of 

these tests and subsequent analysis, our latest calculations for 

styrene emissions at the South Boston facility are as follows: 

GELCOAT SURFACED PRODUCTION UNE - 7.312.713 soft Per Year 

Application/Process Boom 

All Incinerated Booths 

All Non-Incinerated Booths 

Total Styrene Emissions/Year 

Stvrene Pounds Per Year 

14,427.70 T 

111.145.20 

125,572.90 #/Yr 

ACRYLIC SURFACED PRODUCTION UNE - 7.385.197 soft Per Year 

Application/Process Boom 

All Non-Incinerated Booths 

Total Styrene Emissions/Year 

Stvrene Pounds Per Year 

254.305.30 

254,305.30 

L e 
P.10 

3. What process type is involved in the manufacture of each product? 

South Boston's primary manufacturing ska operates two (2) 

independent production lines, one (1) production Bne dedicated to the 

manufacture of gelcoat surfaced fiberglass rein forced products (tubs, 

showers & unitized tub/showers) and, one (1) production line 

dedicated to the manufacture of merrnofbrmed acrylic surfaced 

fiberglass reinforced products (unitized tub/showers). 

At our secondary manufacturing site, we operate a single production 

line dedicated to the manufacture of thennoformed acrylic 

surfaced fiberglass reinforced products (jetted tubs). 

The Open Mold spray-up process is utilized in the manufacture of all 

three (3) of our product Ones. Additionally, the hand lay-up process is 

utilized in the construction of production molds/tooling and, in repair 

of any sub-standard manufactured product 

4. What process types are being controlled? 

77ie Open Mold spray-up and hand lay-up processes are controlled 

and, no other composites pmcesses are utilized in our manufacture of 

FRP products. 

5. What quantity of resin (per year) is used? 

Three (3) different resin products are utilized in the production of our 

three product lines. All three resin products are vapor suppressed. 

Resins: Pounds Used 

Laminating Resin 3,523,593 lbs 

Barrier-Coat Resin rvsWooor 427,00510s 

CSScrvlic Laminating Resin} < «^L J 1.589.775 lbs 

Total Resin 5 uppfeS ^ 5,540.373 lbs 

l$tf -bripfepocVJ 

6. What quantity of gelcoat (per year) is used? 

Total gelcoat pounds ust 

Gelcoat: 

Gelcoats 

Total Gelcoat 

}d equal: 

4 

Pounds Used 

958.279 Ihs 

958.279 lbs 
P.11 

7. What percent filler is used? 

All LASCO facilities utilize in their manufacture of gelcoat surfaced 

reinforced products five (5) separate spray-up applications, with five 

(5) separate spray-up material formulations. The following is a 

breakdown of the five (5) spray-up applications and their respective 

formulation filler percentages. 

GELCOAT SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Application/Process Booth 

Gelcoat Spray-up 

Barrier-Coat Spray-up 

First Laminate Spray-up 

Second Laminate Spray-up 

Third Laminate Spray-up 

Formulation Filler Percentage 

25.00% (by mfg) 

55.00% 

61.00% 

63.00% 

60.00% 

The acrylic surfaced products manufactured, utilize two (2) spray-up 

applications whh a single (1) spray-up material formulation in both. 

ACRYUC SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Apolication/Process Booth 

First & Second Laminate Spray-up 

Formulation Filler Percent 

52.33% 

8. What Is the styrene percent of the resin (after filler and/or additional 

styrene is added)? 

All LASCO facilities utilize in their manufacture of gelcoat surfaced 

reinforced products five (5) separate spray-up applications, whip five 

(5) separate spray-up material formulations. The following is a 

breakdown of the five (5) spray-up applications and their respective 

formulation styrene percentages. 

Note: The formulation styrene percentages were calculated 

using the most recent baseline data supplied in the 

accompanying resin supplier Quality Control Reports and 

Material Safety Data Sheets (see Appendix A). 

id 
P.12 

GELCOAT SURFACED PRODUCTS 

As Used/Processed (spray-up): 

AooBcathn/Process Booth Formulation Stvrene Percent 

Gelcoat Spray-up 36.41 % 

Barrier-Coat Spray-up 20.25% 

First Laminate Spray-up 18.72% 

Second Laminate Spray-up 17.76% 

Third Laminate Spray-up 19.20% 

The acrylic surfaced products manufactured, utilize two (2) spray-up 

applications with a single (1) spray-up material formulation in both. 

ACRYUC SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Application/Process Booth Formulation Stvrene Percent 

First & Second Laminate Spray-up 21.60% 

9. What is the styrene percent of gelcoat? 

7776 styrene percentage of the gelcoats supplied to the South Boston 

facility are 36.41 %, as stated in our suppliers most recent Quality 

Control Reports and Material Safety Data Sheets (see Appendix B). 

10. What percent resin supplied to the plant is used for each process 

(exclude compression molding)? 

As previously identified, LASCO utilizes numerous indivkiual spray-up 

applications and formulations. Here is a percentage breakdown of the 

total pounds of resin thru-put by application/process booth. » 

GELCOAT SURFACED PRODUCTS 

Application/Process Booth Pounds Resin Thm-Put bv Percent 

All Gelcoats: Pounds Percent 

Gelcoat Film Spray-up Booth 958,279 100% 
P.13 

Barrier-Coat Resin: 

Barrier-Coat Film Spray-up Booth 427,005 100% 

Laminating Resin: 

1st, 2nd & 3rd Lam. Spray-up Booths 3,502,451 99.4% 

Repair/Rework Spray/Hand Lay-up 21,142 .6% 

ACRYUC SURFACED PRODUCTS 

Application/Process Booth Pounds Resin Thru-Put bv Percent 

Acrvlic Laminating Resin: Pounds P_u__mt 

First Laminate Spray-up 794.887.5 50%- • 

Second Laminate Spray-up 794,887.5 50% 

1 1. What percentage of resin within each process type is associated whh 

the use of an add-on? 

GELCOAT SURFACED PRODUCTS 

Application/Process Booth Percentage of Resin Thru Add-on 

Pounds Percent 

Gelcoat Film Spray-up 100% 

Barrier-Coat Film Spray-up 0% 

Laminatino Resin: 

First Laminate Spray-up 100% 

Second Laminate Spray-up 100% 

Third Laminate Spray-up 100% 

Repair/Rework Spray/Hand Lay-up 0% 

ACRYUC SURFACED PRODUCTS 

Application/Process Booth Percentage of Resin Thm Add-on 

Pounds Percent 

First Laminate Spray-up 0% 

Second Laminate Spray-up 0% 

I 2-
P.1* 

12. What is the inlet concentration of styrene? Outlet? 

Based on our most recent data, the inlet concentration of styrene 

emissions to the incinerator is 77.34 pounds per hour. Outlet 

concentrations based on a 95% destruction efficiency is 3.87 pounds 

per hour. 

Note: The thermal incinerator is identified as a Reeco Re-Therm 

Model E Thermal Oxidation System. The Reeco incinerator is rated for 

an input of 17,345 SCFM <® 90 F. and lists a minimum destruction 

efficiency of 95%. The maximum destruction efficiency rating is 

99%. These destruction efficiency ratings were supported by Reeco 

Company data and actual field monitoring of a similar unit. 

13. What specific emission points in the process are being controlled by 

the oxidizer (e.g.. storage tank (sU mixing vessels, etc.)? 

GELCOAT SURFACED PRODUCTION UNE 

Production/Process Booth 

Gelcoat Film Spray Boom 

Barrier-Coat Film Spray Booth 

First Laminate Spray Booth 

Second Laminate Spray Booth 

Third Laminate Spray Booth 

Gelcoat Storage Room 

i. Mixing & Holding Tanks (GC & ACR) res ivuvb 

-fr MIX/A/6> +W/5 nor \j<tf\kA hmo/xircchr Lstp jrffi KPa 

ACRYUC SURFACED PRODUCTION UNE *--~^- T ^T 

Production/Process Booth Controlled Source & Percentage 

To Incinerator Percent 

First Laminate Spray-up No 0% 

Second Laminate Spray-up No 0% 

14. What is the capture efficiency for each emission point vented to an 

add-on? 

All LASCO plants operate with ventilation systems engineered to 

create a negative pressure, with respect to the outside atmosphere, 

within all spray-up and grinding booths and, again within the entire 

| 3 

TQ Incinerator 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Percent 

100% 

0% 

100% 

100% 

100% 

100% 

100% 
P.15 

plant production area. Moreover, the buildings are kept closed up for 

the most part. Therefore, it is our contention that the capture 

efficiency from each production emissions source point (spray-up 

application booms) is 100%. 

15. Is the control device used for any process not in the reinforced 

composite plastic source category? If so,.what percentage of the 

flow rate to the add-on is from the reinforced composites? 

777e thermal oxidizer in operation here, is solely used fbr the capture 

and destruction of styrene emissions originating fiom the spray-up 

and curing processes associated with reinforced composites. 

16. What is the volumetric flow rate dirough the control device? 

77;© Reeco incinerator is rated for an input how rate of 17,345 SCFM 

@90F. 

17. What was the capitai Investment for the control device? What is the 

operating cost per year for this device? 

7770 initial capital investment for the Reeco Incinerator was 

$ 738,092.00 in 1986 and began operation in December of that year. 

Operating costs do vary. However, fiom information pulled from our 

1995 plant performance data, the operating costs for gas and 

electricity were $ 105,582.50 and, maintenance costs were 

$ 14,983.20. 

Note: Currently, LASCO (Lancaster, Tx.) is undertaking a cost 

analysis to detemiine best long-term approach to either rebuilding or 

replacing Reeco Incinerator. Life expectancy without major rebuild or 

overhauling of the Reeco systems is approximately 8-10 years, i 

(A-