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OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

40) 11-1-40 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:22 PM Sheet 40 of 114 
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A-94-52 

OLYMPI C 

A I R POLLUTION CONTROL AUTHORITY 

909 Stealer-Kinney Rd. S.E.. Suite 1 • Lacey. WA 98503 

NOTICE OF DRAFT AIR PERMIT ISSUANCE 

PERMIT APPLICANT: 

ACTION 

Lasco Bathware 

801 Northern Pacific 

Yelm, WA 98598 

On February 7, 1997, pursuant to the federal Clean Air Art and Chapter 173-401 of the Washington 

Administrative Code, OAPCA will issue a draft Air Operating Permit (AOP) for Lasco Bathware Inc. Lasco 

operates a fiberglass reinforced plastics manufacturing plant located in Yelm Washington at the above stated 

address. 

BACKGROUND 

Facilities which are major sources of air pollution are required to obtain AOPs pursuant to Title 5 of the federal 

Clean Air Act. Major sources of air pollution are those which emit 100 tons per year or greater of any regulated 

air pollutant, 10 tons per year or greater of any hazardous air pollutant, or 25 tons per year or greater of any 

combination of hazardous air pollutants. The Lasco facility in Yelm is classified as a major source due to 

emissions of styrene, a hazardous air pollutant. 

Issuing the draft AOP is a first milestone in the three part process of issuing a Final AOP for Lasco. The draft 

AOP provides a complete pennit for public review. The purpose of this phase of permit issuance is to consider 

and document written and spoken comments from the general public, other agencies and from Lasco. regarding 

the draft AOP. After consideration of comments received on the draft AOP, OAPCA can issue a proposed AOP. 

The proposed AOP is the version that goes to EPA Region 10 for review and comment. After EPA's review and 

comment, OAPCA can issue the final AOP. 

LASCO's DRAFT PERMIT 

The draft AOP issued by OAPCA for Lasco Yelm contains enforceable conditions that will assure compliance 

with all air pollution control requirements which apply to existing operations and equipment at the facility. In 

addition, the draft AOP contains conditions which provide Lasco operational flexibility while promoting pollution 

prevention. The additional conditions contained in the draft AOP allow Lasco the flexibility to expand operations, 

install new equipment and to make modifications provided that plant-wide emissions do not increase above 

existing emission limitations and provided that certain other conditions are met. One such condition is that Lasco 

implement an approved Pollution Prevention (P2) program. Other additional conditions assure that the new 

equipment and modifications will comply with new source regulations including the requirement that new sources 

utilize best available control technology (BACT) and not cause or contribute to significant air quality impacts. 

(360) 438-8768 • 1-800-422-5623 • E-Mail OAI'CA @ wln.com • Home Page htlp:/Avww.wln.com/~oapca 

FAX'(360) 491-6308 
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Styrene Source Test Results 

forthe 

Lasco Bathware Facility 

in Yelm, Washington 

prepared for 

RECEIVED 

OCT 0 9 1996 

OARCA 

Mr. James A. Wilson 

Air Quality Control Specialist 

Olympic Air Pollution Control Authority 

909 Sleater-Kinney Road SE., Suite 1 

Lacey, Washington 98503 

on behalf of 

Lasco Bathware 

3255 East Miraloma Avenue 

Anaheim, Califomia 92806 

by 

%^qMdy 

Robert A. Haberlein, PhX>. — (f/D) 7. S 3 -~> 3 { ~7 

Engineering Environmental 

TwoFiskCircle (W SO-W7 V FAX 

Annapolis, Maryland 21401 

September 30,1996 

Z 
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Engineering Environmental 

Consulting Services 

TABLE OF CONTENTS 

Executive Summary •..-.-..-.'. if.'.... : ...... ii 

ListofTables .... iv 

List of Appendices iv 

I Introduction I-l 

A. Purpose I-l 

B. Contents I-l 

II Source Test Narrative H-l 

A. General Procedures arid Equations H-l 

B. Preliminary Activities and Setup 11-7 

C. Remote Mixing Process Emissions H-7 

D. TestDay Activities H-8 

UI TestResults UJ-1 

A. Exhaust Stack How Rates UJ-1 

B. Styrene Concentrations UI-1 

C. Styrene Emission Rates JH-14 

D. Source Emission Factors JH-19 

1. Production Data UI-19 

2. Styrene Emission Factors UI-19 

IV Conclusions IV-1 

V Appendices V-1 

~ So^c t Tes-i- P«>t oc o I * — 

in 

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Engineering Enviroimiental 

Consulting Services 

List of Tables 

1 Spiked Charcoal Sorbent Tubes H-4 

2 Spiking Calibration Flow Data H-5 

3 Summary of Analytical Data 11-10 

4 Summary of Sampling Pump Calibration Data U.-12 

5 ExhaustFlowVorticity HI-2 

6a Stack 1 Traverse Data & Analysis , m-4 

6b Stack 2 Traverse Data HI-5 

6c Stack 3 Traverse Data & Analysis UI-6 

6d Stack 4 Traverse Data & Analysis UI-7 

6e Stack 5 Traverse Data & Analysis JH-8 

6f Stack 6 Traverse Data & Analysis UI-9 

6g Stack 7 Traverse Data & Analysis HI-10 

6h Stack 8 Traverse Data & Analysis IU.-11 

6i Stack 9 Traverse Data & Analysis UJ-12 

6j Stack 10 Traverse Data & Analysis UJ-13 

7 Reported Styrene Concentrations UI-15 

8 Styrene Emission Rates for the Gelcoat Line DI-18 

List of Appendices 

A Spiking Data Sheets 

B Vorticity Data Sheets 

C Traverse Data Sheets 

D Test Equipment Listing 

E Calibration Sheets 

F Lasco Bathware Production Data - CONFIDENTIAL TRADE SECRET 

G Technicians' Field Notes & Sketches 

H AML Sample Analysis Data Sheets 

I AML Analysis Documentation Package 

iv 

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i 

engineering Environmental 

Consulting Services 

Executive Summary 

SAMPLE RECOVERY 

The average recovery factor for the test samples was 1.05, which was well within the 

valid range of 0.70 to 1.30 for Method 18. 

VORTICTTY & EXHAUST FLOW RATES 

There was a noticeable amount of exhaust flow vorticity observed in the ten Gelcoat line 

stacks. However, the vorticity values were just within the Method 2 criteria, so the stack 

traverse measurements were not invalidated by vorticity errors. The total plant exhaust flow rate 

from the ten Gelcoat Line stacks was measured at 127,900 dscfm. 

GELCOAT LINE • 

The average styrene emission rates for the entire Gelcoat Line during the test period were 

145.7 lb styrene per hour and 1,221.1 lb styrene per shift. The average styrene emission factor y o 9 ° -<• 

for the entire Gelcoat Line operation during the test period was 0.288 lb styrene emitted per • A " 

pound of styrene monomer used. The styrene emission factor for the gelcoat process was 0.526 -> ^ -> 

lb styrene emitted per pound of styrene monomer used, which was excessively high when ' /6 Ecompared to other Lasco gelcoat operations. LiEkewise, the styrene emission factor for the 

barrier coat process was 0.452Tbltyrene emiTOd"'perp3imd"6F^^ ~> ^ £?%,... 

was also high when compared to other Lasco barrier coat operations. The average styrene "" 

emission factor for the lamination processes was 0.202 Vo styrene emitted per pounTb7styrciie~^ Jo ^ 

monomer used, which although higher than other Lasco lamination operations, was within the 

normal ranges reported at odier facilities. 

ACRYLIC LINE 

The estimated average styrene emission rates for the Acrylic Line (derived from the 

Gelcoat Line test data, less the gelcoat emissions) were 72.6 lb styrene per hour and 610.4 lb 

styrene per shift. Tne average styrene emission factor for the entire Acrylic Line operation was 

0.202 lb styrene emitted per pound of styrene monomer used. 

MIXING AREA (e-^ ^ W> / 

The estimated maximum styrene emission rates for the continuous and batch mixing 

processes were estimated to be 0.135 lb styrene per shift and 0.106 lb styrene per shift, 

respectively. These were neslisible amounts when comnared to the stack emissions. 

ii 

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OLYMPI C 

A I R POLLUTION CONTROL AUTHORITY 

909 Sleatei^Kinney Rd. S.E., Suite 1 • Lacey, WA 98503 

December 13, 1996 

Dave Dellarco 

Pollution Prevention Project Manger 

US EPA Region X 

Seattle, WA 98101 

Subject: OAPCA Review ofthe Lasco Stack Test Report 

Dear Mr. Diellarco: 

As you know, Lasco Bathware Inc., Yelm, WA was tested for styrene emissions on 8/26-

28/96. The test method was EPA Method 18 (40 CFR Part 60, App. A, Meth. 18, 

including Sec. 7.4 alternative NIOSH procedure - NIOSH Method 1501). We have 

finished our review ofthe test report, Styrene Source Test Results for the Lasco Bathware 

Facility in Yelm. Washington. The report is acceptable to OAPCA. The styrene emission 

factors from the test will be used in place of AP-42 factors for emissions which occur on 

or after January 1,1997. One copy ofthe stack test (without the appendix) is enclosed 

for EPA (Dave Dellarco) and one copy ofthe stack test (without the appendix) will be 

mailed to DOE (Bob Burmark). The appendbc is available, check payable to OAPCA, for 

$27.60 (276 p. * 0.10 $/p = $27.60). 

Emission Factors - Lasco Bathware, Yelm, WA 

Process 

Gelcoat 

Barrier Coat 

Laminates 

Acrylic 

Factor % 

52.6 

45.2 

20.2 

20.2 

Comment 

weighted average Laminate 1, 2, and 3 

defined as equal to Laminates 

(360) 438-8768 • 1-800-422-5623 E-Mail OAPCA@wln.com 

FAX (360) 491-6308 

G> 

Home Page http://www.wln.com/-oapca 
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«\ 

\ 

Our review concluded the following. 

1. The quality assurance checks for the stack sampling equipment, and the stack gas 

velocity measurements were acceptable. 

2. The recovery factors, which represent the desorption of styrene from the sample 

tubes in the laboratory analysis, were within the range required by Method 18. The 

average value ofthe recovery factor R had to be within 0.70 <, R AVG ^ 1.30. The average 

recovery factor for each stack was within range, except for 4 spike-sample sets. These sets 

were rejected in the report. Because ofthe redundancy of sampling, the objectives ofthe 

test were not compromised by the rejected samples. 

3. The measured styrene concentrations were adjusted by the R AVG value as outlined 

in Method 18, to give the reported styrene concentrations. 

4. The reported styrene concentrations and the amount of resin or gelcoat used 

during the test were used to calculate styrene emission factors. The amounts of resin or 

gelcoat used during the test and listed in the report are in agreement with the amounts 

observed by OAPCA during the test. 

5. No errors were found in a review ofthe emission calculations. Two typographical 

errors were found in the report. On the last line of p. H-6 the formula should read: "Shift 

Emission Rate (lb/shift) = "; on p. H-7 the second sentence should read: "...the Acrylic 

Line does not include any gelcoat...". The author ofthe report was contacted and agrees 

to these changes. 

Use ofthe factors will include the Annual Emissions Inventory, Compliance with 

LASCO's 12 month styrene limit, and the Air Operating Permit (AOP). 

Sincerely, 

James A. Wilson 

Engineering Aide 

cc: Charles Peace, OAPCA Executive Director 

Mark Goodin PE, OAPCA 

Rob Greenwood, Ross & Associates 

David Bray, EPA 

Rima Dishakajian, EPA 

Madeleine Strum, EPA 

Elizabeth Waddell, EPA 

Bob Burmark, DOE 

Tom Eaton, DOE 

Bob Goldberg, DOE 

Elena Guilfoil, DOE 

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