P.1 

OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

32) ll-C-58 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:28 PM Sheet 32 of 343 
P.2 

.+** **>*•. 

? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

A 9<5 2 

OFFICE OF 

AIR QUALITY PLANNING 

ANO STANDARDS 

JUN I 3 1995 

Mr. Scott Hartman, Plant Manager 

LASCO Bathware 

VA State Highway, 931 

Halifax County Industrial Park 

PO Box 1177 

South Boston, VA 24592 

Dear Mr. Hartman: 

.OCi" ZI 1539 

EPA AIR DOCKET 

As you know, the U.S. Environmental Protection Agency (EPA) 

is developing a national emission standard for hazardous air 

pollutants for the reinforced plastic composites industry. To 

assist our understanding of the processes, emission points, and 

emission reduction strategies, the EPA conducts site visits to 

facilities in the industry. We appreciate your efforts and those 

of Dr. Dan Boyd in arranging our visit to the LASCO facility. 

This letter is to confirm the visit by the EPA to the LASCO 

Bathware facility in South Boston, Virginia, on June 22, 1995. 

Madeleine Strum of the EPA discussed this visit with you on 

June 9, 1995. The following persons are planning to attend: 

Madeleine Strum, Norm Kaplan, Carlos Nunez, Richard Perry, 

Charlie Sedman, and a summer intern, Wanita Dunston. 

Enclosure 1 presents a list of questions which will be 

addressed during the site visit. Recognizing the lack of 

preparation time available to provide this information during the 

visit,, we can follow up on details at a later date. 

The authority for the EPA's information gathering is 

included in Section 114 of the Clean Air Act. Enclosure 2 

contains a summary of this authority. If you believe that 

disclosure of the information we request would reveal a trade 

secret, you should clearly identify such information as discussed 

in the Enclosure. Any information subsequently determined to 

constitute a trade secret will be protected under 18 U.S.C. 1905. 

If no claim of confidentiality accompanies the information when 
P.3 

/ ' 

it is received by the EPA, it may be made available to the public 

by the EPA without further notice (40 CFR, Part 2.203, 

September 1, 1976) . Emissions data, as discussed in Enclosure 3, 

cannot be considered a trade secret. 

Enclosure 4 summarizes the EPA's policies and procedures for 

handling privileged information and describes the EPA contractor 

commitments and procedures for use of confidential materials. It 

is the EPA's policy that compliance by an authorized 

representative with the requirements detailed in Enclosure 4 

provide sufficient protection for the rights of submitters of 

privileged information. 

The "following policies concerning liability should also be 

of interest to you: 

1. If a federal employee is injured in the course of his 

employment, he has compensation coverage from the government 

under the Federal Employees Compensation Act (5 U.S.C. 8108 et 

seq.); and 

2. If, due to the employee's negligence, property damage or 

personal injury to third parties occurs, the Federal Tort Claim 

Act (28 U.S.C. 1346) provides a means of fixing any liability 

upon the federal government. 

The Office of General Counsel has informed the EPA that a 

firm may not condition the EPA's "right of entry" upon consent to 

a waiver of liability and has instructed employees not to sign 

such waivers. If you have any question regarding this refusal, 

please contact Mr. Donnell Nantkes, Office of General Counsel, at 

202-382-4550. 

Sincerely, 

(yC/rsJU £4J<ZrXs*^g 

Linda S. Herring 

Group Leader, Coatings and 

Consumer Products Group 

4 Enclosures 

1^ 
P.4 

J » 

Enclosure 1 

QUESTIONS FOR LASCO Bathware. South Boston. VA 

1. What is the number of employees at the plant? 

2. What is your latest calculation of styrene emissions and the 

methodology used? 

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

4. What process types are being controlled? 

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

6. What quantity of gelcoat is used? 

7. What percent filler is used? 

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

additional styrene is added)? 

9. What is the styrene percent of gelcoat? 

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

process (exclude compression molding)? 

11. What percentage of resin within each process type is 

associated with the use of an add-on? 

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

13. What specific emission points in the process are being 

controlled by the oxidizer (eg. storage tank(s), mixing 

vessels, etc.)? 

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

to an add-on? 

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

reinforced composite plastic source category? If so, what 

percentage of the flowrate to the add-on is from the 

reinforced composites? 

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

17. What was the capital investment for the control device? What 

is the operating cost per year for this device? 

3