p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

10) IV-B-10 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 10 of 273 
P.2 

A-f-f-sz. 

JV-&-/D 

TO: 

FROM: 

DATE: 

SUBJECT: 

F eo 2 T ?.C33 

EPA AIR DOCKET 

MEMORANDUM 

RFP Docket 

i. 

Pacific Environmental Services, Inc. (PES) 

June 14, 2002 

Changes made to the RFP NESHAP cost analysis since proposal 

In response to industry comments and updated data, we made a number of changes to the 

MACT database and the cost analysis calculations. The purpose ofthis memorandum is to 

document the changes to the cost analysis. The changes to the MACT floor database that impact 

the cost calculations are included as well. In addition, we have included discussion of some of 

the key changes suggested by commenters that were considered but not made based on our 

review ofthe data. The reader should refer to BID Volume II for a complete discussion of all 

comments received on the cost analysis. 

MACT FLOOR COSTING 

Mechanical NonCorrosion Unfilled and Filled 

At proposal, separate MACT floors were identified for mechanical non-corrosion unfilled 

and mechanical non-corrosion filled process groups. This was done in large part because at that 

time non-atomized resin application was not a suitable emission reduction measure when 

applying filled resins. Based on additional information collected between proposal and 

promulgation, we determined that non-atomized application is now a viable alternative for filled 

resins. As a result, we combined these two process groups and detennined one floor for the new 

mechanical non-corrosion process group. 

In addition, we updated the MACT floor determinations based on data corrections and 

updates received from individual facilities (detailed in Table 1), and we added additional 

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P.3 

A 

facilities to the database and removed facilities that are no longer in the reinforced plastics 

business (detailed in Table 2). Changes included updated HAP content, material usage, 

applicable process groups, and control technologies/efficiencies. We also replaced the Point 

Values with Unified Emission Factors for the appropriate process groups. The combination of 

these changes resulted in new MACT floors for several process groups. 

These changes do not involve direct changes to the costing assumptions and algorithms, 

but changes in the MACT floors and facility specific data do result in new cost numbers for the 

MACT floor and for the cost increment between MACT floor control and above-the-floor addon control requirements. 

Corrosion Resistant Centrifugal Casting MACT Floor Costs 

Only two facilities in the database fall under the corrosion resistant centrifugal casting 

process group: Fibercast with a HAP content of 47% and Raven Industries with a HAP content 

of 49%o. The MACT floor is 48%, the average of values for each ofthe two facilities. In the cost 

analysis for the proposed rule, neither facility was assigned any costs to achieve the MACT 

floor. In revisiting the analysis, we realized that this was erroneous. We should have assigned 

costs to Raven Industries for using a lower HAP resin that meets the MACT floor. In the revised 

cost analysis, costs were added for this facility following all ofthe same assumptions for costs of 

switching resins in other process groups, and the incremental cost used is $0,455, which was 

previously determined to be the cost for switching to corrosion resistant resin for any ofthe 

corrosion resistant process groups. 

Removal of Credit for Certain Control Techniques 

In the MACT floor determinations and cost calculations for proposal, two facilities in the 

Manual Non-corrosion resistant process group were given erroneously given emission reduction 

credit for vacuum bagging (i.e., Monarch Plastic and Shenandoah Fiberglass). That credit was 

removed in the revised floor determinations and cost calculations. 

Similarly, in the calculations for the proposed rule, Hydro Systems was given emission 

reduction credit for its carbon filter system in the manual tooling and tooling gelcoat process 

groups. During our review ofthe assumptions in the MACT floor determinations and cost 
P.4 

calculations, we reviewed the trip report to Hydro Systems and determined that the reduction 

credit was not appropriate because there is no way to calculate the reduction being achieved; so 

we removed the reduction credit. 

ABOVE-THE-FLOOR COSTING 

Permanent Total Enclosures 

Exhaust Air Flow Calculations 

The amount of exhaust air flow calculated from PTEs are based on two different 

methodologies. One methodology calculates the exhaust air flow by first sizing the PTEs and 

then calculating the exhaust air flow that meets the NDO and minimum air velocity criteria 

found in Method 204. The second methodology "back calculates" the exhaust air flow rate 

needed to achieve a specified maximum concentration in the air stream. The larger ofthe two 

calculated exhaust air flow rates is then selected to size and cost the add-on control devices. 

Changes, as discussed below, were made to both of these two exhaust air flow calculation 

methodologies. 

Natural Draft Openings. As indicated in the proposal BID, the size ofthe natural draft 

openings (NDOs) in permanent total enclosures (PTEs) for operations other than continuous 

lamination and casting were calculated as 0.2 percent ofthe total surface area for the PTE; for 

continuous lamination and casting, NDOs were calculated as 2 percent ofthe total surface area. 

EPA's five-point criteria for total enclosures allows openings up to 5 percent ofthe total surface 

area, but we found that reinforced plastics facilities typically have much lower percentages. 

After careful consideration, we determined that NDOs of 0.2 percent are probably not 

sufficient. The costing calculations were revised so that the NDOs are calculated as 2 percent of 

the total surface area for all processes (thus no change for continuous lamination and casting). 

Back Calculation and Maximum Concentration. The back calculation methodology 

uses, in part, a target maximum concentration to calculate the exhaust air flow rate. In the 

proposal cost calculations, we used a maximum exhaust concentration of 100 ppm HAP. Several 

commenters indicated that 100 ppm was too high. We reviewed the available data and the public 

comments and concluded that we had incorrectly characterized the exhaust concentration, which 

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P.5 

should have been somewhat less than 50 ppm. Based on this finding, we revised the cost 

algorithms to calculate control costs based on a "target" maximum exhaust concentration of 50 

ppm (as styrene). This target concentration matches the voluntary worker exposure limit that 

many facilities have committed not to exceed. 

PTE Sizing 

Several commenters expressed concerns that the PTE sizing algorithms in our cost 

analysis under estimated the size of PTEs that wo.uld be required at their facilities. We 

compared the facility-specific PTE size data from all facilities that submitted data against the 

PTE sizes predicting by our algorithms, which are driven by resin use and hours of operation. 

Although the comparison showed significant differences at certain individual facilities, the 

average size predicted by our algorithms was the same as the average ofthe facility specific data 

submitted over a large portion ofthe size range. (See Attachment A.) Obtaining facility-specific 

data for all facilities in the database would be an impossible task. We concluded that our 

algorithm is an acceptable predictor of PTE size; therefore, we did not change the PTE sizing 

algorithm in the cost analysis. (Note that the calculated PTE size for individual facilities might 

have changed since proposal. That is the result of updated resin use and hours of operation, not a 

change in the calculation methodology.) 

Annualization of PTE Costs 

As noted in the proposal BID, PTEs were annualized on a 30-year basis. Several 

commenters suggested that 30 years is not a reasonable "life" expectancy for PTEs used in the 

industry. We revisited the life expectancy of PTEs and concluded that 30 years is indeed longer 

than one would reasonably expect a PTE to last. Therefore, we changed the life expectancy for 

PTEs in the revised cost calculations to 10 years. 

CFA suggested that we change the interest rate from 7% to 10%. Based on feedback 

from EPA's economics group, our original assumption of 7% interest is reasonable; therefore, 

we did not change the interest rate in the revised cost analysis. 

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P.6 

Duct, Elbows & T's, and Damper Sizing and Control Device Costing 

The algorithms used to size ducts, elbows and T's, and dampers and to calculate the cost 

of control devices are only valid in specific ranges (diameters for ducts, elbows and T's, and 

dampers, and air flow rates for control devices). Where the algorithms estimate diameters or air 

flow rates for these equipment that are outside ofthe valid range, the cost equations have to be 

manually adjusted so that additional pieces of equipment within the valid range are used. For 

example, ifthe estimated air flow rate exceeded the upper range, multiple control devices instead 

of one were costed to keep the air flow rate to each control device at or below the upper range. 

A few of these manual updates were missed in the cost calculations supporting the proposed 

rule. In the revised cost analysis, all ofthe equations were reviewed and manually adjusted as 

needed to keep within the specified ranges. 

Utilities 

Fan Power 

In the cost analysis for the proposed rule, we calculated the electrical power consumption 

for rotary concentrators based on flow rates to the control device using a fan power equation 

developed by RTI. That equation was based on vendor quotes from Durr Environmental, Inc. 

According to the Durr representative (James Stone), their rotary concentrator systems without 

prefiltration have a pressure drop from six to eight inches and a combined fan and motor 

efficiency between 65 and 80 percent. (See Contact Report, Attachment B.) 

As an alternative, CFA suggested the fan power equation in the OAQPS cost manual 

using a pressure drop of 16 inches and combined fan and motor efficiency of 60 percent. This 

approach resulted in electrical consumption that is about 4 times higher than the RTI approach at 

the upper flow range with less difference at lower flows. We also looked at other pressure drops 

reported, and the value's reported by Durr seemed low in comparison. Therefore, we concluded 

that the pressure drops may have been underestimated in the proposal cost calculations. We 

changed the equation to reflect a 16 inch pressure drop across the entire system and a combined 

fan an motor efficiency of 60%>, as suggested by CFA. The revised cost analysis reflects this 

change. 

-5-
P.7 

Fuel Consumption 

CFA also suggested using the OAQPS fuel consumption equation instead ofthe RTI 

equation based on vendor data that we used. We considered CFA's suggestion and discussed the 

data with the vendor (James Stone from Durr Environmental, Inc). Based on our review ofthe 

data, we concluded that the RTI equation we used at proposal is appropriate and we did not make 

the suggested change. 

Utilitv Costs 

Several commenters expressed concerns that utility costs in the analysis are too high. We 

assumed an electricity cost of $0.0448/kWh and a natural gas cost of $3.24/1000 scfm. These 

costs are based on national averages reported by the Department ofEnergy. We believe that 

these costs represent the best available data and did not change the utility costs in the revised 

analysis. 

Other 

Hours of Operation 

In the cost calculations supporting the proposed rule, we assumed that all RFP facilities 

operate 6000 hours per year. We received numerous comments on this assumption and many 

commenters indicated that they do not operate that many hours. We obtained facility-specific 

operating hours for many ofthe larger facilities through comment letters and through a facility 

survey conducted by CFA. These facility-specific hours were used wherever they are available. 

(See Table 3 for a list ofthe facility-specific hours used in the cost analysis.) When facilityspecific data were not available, we assumed 2000 hours per year, roughly equivalent to one 

shift per day. Based on the comments and revised data we received, we believe 2000 hours per 

year is a better representation of actual practice in the reinforced plastics industry. 

Mixing Costs 

Compliance costs for mixing operations are driven by the need to cover mixers. In the 

cost calculations, the number of mixers, and thus the number of required mixer covers, is 

estimated for each facility based on the amount of material used annually ifthe actual number of 
P.8 

mixers was not available for a particular facility. Add-on control costs are also impacted by the 

amount of material used because PTE costs are calculated on the throughput. Our review ofthe 

cost calculations identified several instances where mixing costs did not accurately reflect all of 

the process groups for each facility because the material usage for certain processes was not 

added to the facility total. For the revised costs, we reviewed all processes at the each facility 

and updated the mixing calculations so that all processes were included in the facility total. 

Materials used for tooling, which were not previously included, were also added to the facility 

material usage totals. 

Although the assumptions for mixing costs did not change, the actual costs for 

controlling mixing operations did change as a result ofthe corrections and updates to the facility 

material usage. 

Costs for Facilities with Existing Control Devices 

The costs for the above-the-floor option for sources with existing control devices were 

revisited during the costing calculation revisions. The sources with existing control devices 

were identified and divided into two groups: those with control devices achieving at least 95% 

destruction efficiency and those achieving less than 95% destruction efficiency. 

For facilities with control devices achieving less than 95% efficiency, we assumed that 

the facility would require a new control device as well as new PTEs and ductwork for all process 

groups because the existing device might not have the capacity to achieve 95% control of these 

processes through modifications. The new control device was costed using the same 

assumptions that are used for facilities without any existing add-on control, but the operating 

costs were modified. For facilities with existing controls, we first calculated the operating costs 

based on the size and efficiency ofthe existing control device. Next we calculated the operating 

costs for the replacement control device. Finally, we subtracted the current operating costs from 

the predicted future operating costs so that the actual costs used in the analysis reflect the net 

increase in operating costs. This represents a change from the previous cost calculations where 

no adjustments to the costing were made for facilities with control devices less than 90%) 

efficiency. The costs for those facilities was calculated the same as they were for facilities 
P.9 

without control devices. We believe this change accurately reflects the incremental cost of 

installing and operating an add-on control device achieving at least 95% capture and control. 

For facilities with control devices achieving at least 95% efficiency, we assumed that a 

new control device would be needed for the processes that are currently uncontrolled because the 

existing control device might not have the capacity to accommodate air flows for additional 

processes. The control device sizing algorithms were modified for these facilities so that the 

control device is sized on airflow from the currently uncontrolled processes only, rather than the 

airflow from all processes, as we did for facilities without control devices. This represents a 

change from the previous cost analysis where we did not cost a control device or PTEs for 

facilities with a 95% efficient device. We believe this change accounts for the costs that 

facilities may incur if their existing controls cannot handle additional processes. 

Correction of Errors in Original Cost Calculations 

While updating the costing calculations, a number of errors were found in the 

spreadsheet that were corrected in the revised calculations. As a result of these changes, some of 

the specific cost values may have changed even though they are not related to any ofthe changes 

in assumptions or facility data. 

For facilities with existing control devices, the "uncontrolled emissions" were calculated 

as emissions after control. The algorithms for those facilities were corrected so that 

"uncontrolled emissions" reflects the level of emissions that would occur without the use ofthe 

control device. 

In some cases, the costs for PTEs were calculated incorrectly because wall and ceiling 

sizes were calculated incorrectly. This was the result of incorrect cell references to the assumed 

height, width, and length ofthe required PTEs. 

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Table 1. Facility Specific Changes to RFP Database 

Company 

Appalachian 

Plastics 

Process Group 

manual non-CR 

mechanical CR 

mechamcal non-CR 

Change Description 

added the facility to this 

process group 

changed resin use 

changed HAP content 

added flowcoaters for a 

portion of operation 

removed flowcoaters from 

this process group 

changed resin use 

changed HAP content 

New 

Value 

97.9 tpy 

40.6% 

23 tpy 

36.4% 

Old 

Value 

56.6 tpy 

39.3% 

20 tpy 

38.7% 

Source 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 
Table 1. Facility Specific Changes to RFP Database 

Company 

Appalachian 

Plastics 

Aqua Glass 

Adamsville 

Process Group 

filament winding nonCR 

filament winding CR 

mechanical non-CR 

filled 

gelcoat - pigmented 

Change Description 

changed resin use 

changed HAP content 

changed resin use 

changed HAP content 

added flowcoaters 

changed resin use 

changed gelcoat use 

New 

Value 

139 tpy 

30.8% 

29 tpy 

40.9% 

9027 tpy 

1041 tpy 

Old 

Value 

150tpy 

31.0% 

36 tpy 

53.8% 

10143 

tpy 

1170 

tpy 

Source 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Trip report; E-mail table from 

K. Barnett to K. Meardon 

Attachment C 

Docket No. A-94-52, IV-D-71 

derived from emissions data in 

letter from Aqua Glass, 10/1/02 

Docket No. A-94-52 IV-D-71 

derived from emissions data in 

letter from Aqua Glass, 10/1/02 

Docket No. A-94-52 IV-D-71 

-10-
Table 1. Facility Specific Changes to RFP Database 

Company 

Aqua Glass 

Klamath Falls 

ARE 

Massillon 

Process Group 

mechanical non-CR 

filled 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed reinforcement use 

changed filler use 

changed HAP content 

changed resin use 

changed gel coat use 

changed resin use 

changed reinforcement use 

New 

Value 

904 tpy 

1870 tpy 

30% 

1746.8 

tpy 

375 tpy 

1267.9 

tpy 

477.3 tpy 

Old 

Value 

507.1 

tpy 

1062.4 

tpy 

42.6% 

992.5 

tpy 

213 tpy 

5983.5 

tpy 

1002.5 

tpy 

Source 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

change based on old ratio 

derived from emissions data in 

letter from Aqua Glass, 10/1/02 

Docket No. A-94-52 IV-D-71 

derived from emissions data in 

letter from Aqua Glass, 10/1/02 

Docket No. A-94-52 IV-D-71 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

updated to be consistent with 

new resin use based on the 

original ratio 

-11-
Table 1. Facility Specific Changes to RFP Database 

Company 

ARE 

Massillon 

AREMt. 

Eaton 

Process Group 

gelcoat - pigmented 

tooling gelcoat 

mechanical non-CR 

filled 

gelcoat - pigmented 

Change Description 

changed filler use 

changed gelcoat use 

removed control 

changed resin use 

changed reinforcement use 

changed filler use 

added control 

changed gelcoat use 

New 

Value 

400.6 tpy 

458.86 

tpy 

0% 

102.6 tpy 

102.8 tpy 

32.3 tpy 

95% 

78.94 tpy 

Old 

Value 

6408.8 

tpy 

1572 

tpy 

95% 

1007.1 

tpy 

514.6 

tpy 

1078.1 

tpy 

0 

267 tpy 

Source 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

updated to be consistent with 

new resin use based on the 

original ratio 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

Docket A-94-52, II-B-26 

E-mail from C. Taylor to K. 

Barnett 1/30/05 

Attachment D 

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Table 1. Facility Specific Changes to RFP Database 

Company 

Bremen Glass 

Bristol 

Fiberlite 

CDR Systems 

Corp. 

(Corcoran, 

Waynoka, 

Palatka 

facilities) 

CDR Systems 

Corp. 

Corcoran 

CDR Systems 

Palatka 

Cedar 

Manufacturing 

Process Group 

tooling gelcoat 

mechanical non-CR 

unfilled 

manual non-CR 

manual non-CR 

manual non-CR 

tooling gelcoat 

Change Description 

changed HAP content 

changed HAP content 

moved from mechanical 

non-CR unfilled to manual 

non-CR process group 

(added resin use previously 

listed as mechanical to 

existing manual resin use) 

changed HAP content 

changed HAP content 

changed HAP content 

New 

Value 

42% 

38% 

35% 

35% 

46.7% 

Old 

Value 

39.9% 

28.2% 

33% 

36% 

44% 

Source 

New Facility Survey Table 

4/8/02 

Attachment E 

Phone call to Ashland 

Chemical from Madeline Strum 

12/03/96 

Attachment F 

E-mail from J. Schweitzer to 

K. Barnett 3/19/02 

Attachment G 

E-mail from J. Schweitzer to 

K. Barnett 3/19/02 

Attachment G 

E-mail from J. Schweitzer to 

K. Barnett 3/19/02 

Attachment G 

New Facility Survey Table 

4/8/02 

Attachment F 

_ — — 

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Table 1. Facility Specific Changes to RFP Database 

Company 

Contemporary 

Products 

Custom 

Fiberglass 

Molding Inc. 

GenCorp 

Great Lakes 

Plastics Corp. 

Hydro 

Systems 

Kohler 

Brownwood 

Process Group 

manual non-CR 

mechanical non-CR 

unfilled 

SMC 

mechanical non-CR 

unfilled 

manual tooling 

tooling gelcoat 

mechanical non-CR 

Change Description 

moved from mechanical 

non-CR unfilled to manual 

non-CR process group 

removed credit for flow 

coaters 

removed facility from 

calculation - facility has 

closed 

added credit for flowcoaters 

for 2/3 rds ofthe resin use 

removed credit for carbon 

filter system 

removed credit for carbon 

filter system 

changed HAP content 

New 

Value 

10.3 

200.7 

lb/ton 

(UEF) 

45.1% 

Old 

Value 

6.4 

354 

lb/ton 

(UEF) 

40% 

Source 

E-mail from J. Schweitzer to 

K. Barnett 3/19/02 

Attachment G 

E-mail from J. Schweitzer to 

K. Barnett 3/19/02 

Attachment G 

L. Lasher's research 

Letter from J. Laux, 2/8/00 

Attachment H 

See Trip Report to Hydro 

Systems. No way to calculate 

emission credit. 

New Facility Survey Table 

4/10/02 

Attachment I 

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•*• 
Table 1. Facility Specific Changes to RFP Database 

Company 

Kohler 

Brownwood 

Monarch 

Plastic Inc. 

Nordic 

Fiberglass 

(Warren) 

Plastic 

Development 

Co. 

Process Group 

mechanical non-CR 

pigmented gel coat 

manual non-CR 

mechanical non-CR 

mechamcal non-CR 

Change Description 

changed resin use 

added flowcoaters 

changed gelcoat use 

removed vacuum bagging 

credit 

changed HAP content 

added flowcoaters 

New 

Value 

1556 tpy 

16 tpy 

3.3 

38.5% 

124 

lb/ton 

(UEF) 

Old 

Value 

550 tpy 

10 tpy 

1.9 

48.5% 

354 

lb/ton 

(UEF) 

Source 

New Facility Survey Table 

4/10/02 

Attachment I 

Letter from M. Cassidy 9/25/01 

Docket No. A-94-52 IV-D-37; 

New Facility Survey Table 

4/10/02 

Attachment I 

New Facility Survey Table 

4/10/02 

Attachment I 

Credit was erroneously applied 

for this particular facility -

decision was made early on not 

to give credit 

Letter from W. Spidahl, 

2/13/00 

Attachment J 

(or docket no. when assigned) 

Letter from S. Allison, 2/15/00 

Attachment K 

(or docket no. when assigned) 

•15-
Table 1. Facility Specific Changes to RFP Database 

Company 

Shenandoah 

Fiberglass 

Products 

TompkinsLasco 

Anaheim 

Process Group 

manual non-CR 

mechanical non-CR 

filled 

gelcoat - pigmented 

Change Description 

removed vacuum bagging 

credit 

changed resin use 

changed HAP content 

changed filler use 

changed reinforcement use 

changed gel coat use 

changed HAP content 

New 

Value 

0.6 

4010.0 

tpy 

36% 

6254.2 

tpy 

863.1 tpy 

913 tpy 

36% 

Old 

Value 

0.4 

3136 

tpy 

47.7% 

4891 

tpy 

675 tpy 

761tpy 

36.4% 

Source 

Credit was erroneously applied 

for this particular facility -

decision was made early on not 

to give credit 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

•16-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco Cordele 

TompkinsLasco Cordele 

TompkinsLasco 

Elizabethtown' 

Process Group 

mechanical non-CR 

filled 

mechanical non-CR 

filled 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed resin use 

changed HAP content 

changed filler use 

changed reinforcement use 

changed gel coat use 

changed HAP content 

changed resin use 

New 

Value 

2856 tpy 

38.7 % 

4466.7 

tpy 

599.5 tpy 

725 tpy 

36% 

2532.7 

tpy 

Old 

Value 

1977 

tpy 

47.8 % 

3092 

tpy 

415 tpy 

470 tpy 

36.4% 

2125 

tpy 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L | 

-17-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco 

Elizabethtown 

Process Group 

mechanical non-CR 

filled 

mechanical non-CR 

filled 

gelcoat - pigmented 

Change Description 

changed HAP content 

changed filler use 

changed reinforcement use 

changed control level 

changed gel coat use 

changed HAP content 

changed control % 

New 

Value 

38.7% 

3939.0 

tpy 

780.7 tpy 

51.51% 

642.9 tpy 

36% 

77.6% 

Old 

Value 

47.7% 

3305 

tpy 

655 tpy 

47.5% 

541 tpy 

36.4% 

47.5% 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

-18-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco 

Lancaster 

TompkinsLasco 

Lancaster 

Process Group 

mechanical non-CR 

filled 

mechanical non-CR 

filled 

gelcoat - pigmented 

Change Description 

changed resin use 

changed HAP content 

changed filler use 

changed reinforcement use 

changed control level 

changed gel coat use 

changed HAP content 

New 

Value 

2910.0 

tpy 

38.7% 

4592.3 

tpy 

458.6 tpy 

37.83% 

712.1 tpy 

36% 

Old 

Value 

2259 

tpy 

47.7% 

3565 

tpy 

356 tpy 

43.5% 

556 tpy 

36.4% 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

-19-

•*• 

ho 
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco 

Lancaster 

TompkinsLasco Moapa 

Process Group 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed control % 

changed reinforcement use 

changed filler use 

changed control level 

changed HAP content 

changed resin use 

removed facility from floor 

calculation 

New 

Value 

77.6% 

1929.0 

tpy 

4778.8 

tpy 

92.2% 

36% 

3038.2 

tpy 

Old 

Value 

47.5% 

3974 

tpy 

9845 

tpy 

No 

control 

47% . 

6259 

tpy 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

Policy decision that operations 

at this facility could not be 

universally applicable 
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco Moapa 

TompkinsLasco Moapa 

TompkinsLasco South 

Boston 

Process Group 

gelcoat - pigmented 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed gel coat use 

changed HAP content 

changed control % 

removed facility from floor 

calculation 

changed resin use 

changed HAP content 

changed filler use 

New 

Value 

683.7 tpy 

36% 

92.2% 

3171.5 

tpy 

37.7% 

4662.1 

tpy 

Old 

Value 

1596 

tpy 

36.4% 

0% 

2771 

tpy 

48.1% 

4079 

tpy 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

Policy decision that operations 

at this facility could not be 

universally applicable 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

-21-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco South 

Boston 

TompkinsLasco Three 

Rivers 

Process Group 

mechanical non-CR 

filled 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed reinforcement use 

changed control level 

changed HAP content 

changed control % 

changed gel coat use 

changed filler use 

changed resin use 

New 

Value 

824.6 tpy 

20.08% 

36% 

77.6% 

521.1 

4434.1 

tpy 

2845.2 

tpy 

Old 

Value 

709 tpy 

30.2% 

36.4% 

47.5% 

479 tpy 

4387 

tpy 

2815 

tpy 

Source 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

-22-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco Three 

Rivers 

TompkinsLasco Three 

Rivers 

TompkinsLasco Yelm 

Process Group 

mechamcal non-CR 

filled 

mechanical non-CR 

filled 

gelcoat - pigmented 

mechanical non-CR 

filled 

Change Description 

changed HAP content 

changed reinforcement use 

changed HAP content 

changed gel coat use 

changed resin use 

changed HAP content 

changed filler use 

New 

Value 

38.7% 

590 tpy 

36% 

718 tpy 

2928.6 

tpy 

36% 

4483.3 

tpy 

Old 

Value 

47.8% 

584 tpy 

36.4% 

685 tpy 

2754 

tpy 

30% 

4216 

tpy 

Source 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

updated to be consistent with 

new resin use based on the 

original ratio 

-23-
Table 1. Facility Specific Changes to RFP Database 

Company 

TompkinsLasco Yelm 

TompkinsLasco Yelm 

Venetian 

Marble 

Process Group 

mechanical non-CR 

filled 

mechamcal non-CR 

filled 

gelcoat - pigmented 

gelcoat - clear 

polymer casting 

Change Description 

changed reinforcement use 

changed control level 

changed HAP content 

changed control % 

changed gel coat use 

changed gelcoat use 

changed resin use 

New 

Value 

611.5 tpy 

14.79% 

36% 

77.6% 

548 tpy 

42.3 tpy 

540 tpy 

Old 

Value 

575 tpy 

no 

control 

36.4% 

0% 

603.7 

tpy 

<ltpy 

<ltpy 

Source 

updated to be consistent with 

new resin use based on the 

original ratio 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

derived from spreadsheet 

received from Lasco, 02/13/02 

Attachment L 

based on recent data available 

in the TRI database 

based on recent data available 

in the TRI database 

-24-
Table 1. Facility Specific Changes to RFP Database 

Company 

Xerxes 

Anaheim 

Xerxes Seguin 

All Facilities 

Process Group 

mechanical CR 

mechanical CR 

All process groups 

Change Description 

changed resin use to get 

emissions equal to 

comment letter 

changed resin use to get 

emissions equal to 

comment letter 

New 

Value 

354 tpy 

520 tpy 

Old 

Value 

94.7 tpy 

94.7 tpy 

Source 

derived from comment letter 

Docket No. A-94-52 IV-D-111 

derived from comment letter 

Docket No. A-94-52 IV-D-111 

the average ratios used to estimate reinforcement and filler use where data are not 

available were recalculated using the most up to date resin information. The ratio 

calculation was also modified to calculate a straight facility average ratio instead of a 

weighted average based on total resin use 

-25-

•o 
Table 2: Facilities Added to the RFP Database 

Company 

Able BodyShifferdecker 

Able Body7

th

 Street 

Alaglass Pools 

Aqua Glass -

McEwan 

ARE 

Massillon 

AREMt. 

Eaton 

AREMt. 

Eaton 

Process Group 

mechanical non-CR 

mechanical non-CR 

mechanical CR 

pigmented gelcoat 

mechanical non-CR 

mechanical non-CR 

unfilled 

mechanical non-CR 

unfilled 

mechanical non-CR 

unfilled 

Change Description 

added to process grp - resin 

use 

added to process grp - resin 

use 

added facility w/ nonatomization, 37.7%o HAP 

added facility with 37% 

HAP 

added to process group 

added resin use 

estimated reinforcement use 

added resin use 

estimated reinforcement use 

New 

Value 

750 tpy 

720 tpy 

1071tpy 

477.3 tpy 

160 tpy 

102.8 tpy 

Source 

Letter from K. Witt, 9/27/01 

Docket No. A-94-52 IV-D-50 

Letter from K. Witt, 9/27/01 

Docket No. A-94-52 IV-D 

New Facility Survey Table 

Attachment M 

New Facility Survey Table 

Attachment M 

Letter from Aqua Glass, 10/1/02 

Docket No. A-94-52 IV-D-71 

E-mail from C. Taylor to K. Barnett 

1/30/02 

Attachment D 

updated to be consistent with new resin 

use based on the original ratio 

E-mail from C. Taylor to K. Barnett 

1/30/02 

Attachment D 

updated to be consistent with new resin 

use based on the original ratio 

-26-
Table 2: Facilities Added to the RFP Database 

Company 

Emsig 

Fabwell 

Kohler 

(Spartanburg) 

Process Group 

Centrifugal casting nonCR 

mechanical non-CR 

unfilled 

pigmented gelcoat 

mechanical non-CR 

Change Description 

removed from 

database/floor calc -

facility closed Feb 2002 

added resin use 

HAP content 

FIT 

HAP content (wt. average) 

added gel coat use 

resin use 

HAP content 

non-atomization 

New 

Value 

2651.71 

tpy 

27.1% 

29.6% 

1288.71 

tpy 

3095 tpy 

38.4% 

(ave) 

Source 

New Facility Survey Table 4/08/02 

Attachment N 

New Facility Survey Table 4/08/02 

Attachment N 

New Facility Survey Table 4/08/02 

Attachment N 

New Facility Survey Table 4/08/02 

Attachment N 

New Facility Survey Table 4/08/02 

Attachment N 

New Facility Survey Table 4/10/02 

Attachment O 

New Facility Survey Table 4/10/02 

Attachment O 

New Facility Survey Table 4/10/02 

Attachment O 

-27-
Table 2: Facilities Added to the RFP Database 

Company 

Kohler 

(Spartanburg) 

MFG-NC 

MFG - Kansas 

MFG - Texas 

Process Group 

mechanical tooling 

pigmented gelcoat 

mechanical non-CR 

compression/ injection 

molding 

mechanical non-CR 

compression/ injection 

molding 

mechanical non-CR 

compression/ injection 

molding 

Change Description 

resin use 

HAP content 

gelcoat use 

HAP content 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

New 

Value 

1.7 tpy 

47% 

600 tpy 

37.45% 

(ave) 

Source 

New Facility Survey Table 4/10/02 

Attachment O 

New Facility Survey Table 4/10/02 

Attachment O 

New Facility Survey Table 4/10/02 

Attachment O 

New Facility Survey Table 4/10/02 

Attachment O 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

Letter from P. Bennett, 10/25/01 

Docket # A-94-52 IV-D-94 

-28-
Table 2: Facilities Added to the RFP Database 

Company 

Monaco Coach 

(Elkhart) 

Xerxes/ 

Proform -- W. 

Memphis 

Process Group 

mechanical non-CR 

unfilled 

manual CR 

manual non-CR 

manual tooling 

mechanical CR 

mechanical non-CR 

mechanical tooling 

tooling gelcoat 

Change Description 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

added to process group 

New 

Value 

Source 

Letter from K. Anderson, 9/28/01 

Docket No. A-94-52, IV-D-61 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, 10/29/02 

Docket No. A-94-52 IV-D-111 

-29-
Table 3: Revised Hours of Operation for Specific Facilities 

Facility Name 

A. R. E., Inc. (Mount Eaton) 

A. R. E., Inc. (Massillon) 

Able Body (Seventh Street) 

Able Body (Schifferdecker) 

AKER Plastics Co., Inc. (Plymouth, N Oak Rd) 

AKER Plastics Co., Inc. (Martinsburg) 

American Standard 

Aqua Glass Corp. (Klamath Falls) 

Aqua Glass Corp. (Adamsville) 

Aqua Glass (McEwan) 

Aqua Bath Co., Inc. 

Attbar Plastics, Inc. 

Fibercast Co. 

Fleetwood (Decatur - formerly Gold Shield) 

Fleetwood (Fontana - formerly Gold Shield) 

Hours per 

Year 

6100 

6100 

4000 

4000 

6000 

6100 

6000 

4000 

7115 

6000 

1750 

2000 

3000 

3000 

2025 

Basis 

Based on site visit. 

Based on site visit. 

Letter from K. Witt, Able Body Corporation, 9/27/01. 

Docket No. A-94-52 IV-D-50 

Letter from K. Witt, Able Body Corporation, 9/27/01. 

Docket No. A-94-52 IV-D-50 

Based on site visit. 

Based on site visit. 

Based on site visit. 

Letter from Aqua Glass Corporation, 10/1/01. 

Docket No. A-94-52 IV-D-71 

Letter from Aqua Glass Corporation, 10/1/01. 

Docket No. A-94-52 IV-D 

Letter from Aqua Glass Corporation, 10/1/01. 

Docket No. A-94-52 IV-D 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Letter from M. Howard, Fleetwood Enterprises, 10/18/01. 

Docket No. A-94-52 IV-D-82 

Annual Hours estimated based on data obtained from 

CFA survev (1/18/02). See Attachment P. 

-30-

V 

co 
Table 3: Revised Hours of Operation for Specific Facilities 

Facility Name 

Holiday Rambler Corp., Plant 36 &37 

Leer Midwest 

MFG - Molded Fiber Glass Co. (Union City) 

Syntechnics 

Tomkins - LASCO Bathware (Lancaster) 

Tomkins - LASCO Bathware (Elizabeth Town) 

Tomkins - LASCO Bathware (Anaheim) 

Tomkins - LASCO Bathware (Moapa) 

Tomkins - LASCO Bathware (Yelm 

Tomkins - LASCO Bathware (South Boston) 

Tomkins - LASCO Bathware (Cordele) 

Tomkins - LASCO Bathware (Three Rivers) 

Universal-Rundle Corp. (Ottumwa) 

Hours per 

Year 

2125 

2000 

7200 

2100 

6240 

6360 

6600 

6600 

6000 

4160 

6240 

6600 

2125 

Basis 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Letter from P. Bennet, Molded Fiberglass Companies, 

10/25/01. Docket No. A-94-52 IV-D-94 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Letter from G. Lowe, Lasco Bathware, 9/28/01. 

Docket No. A-94-52 IV-D-58 

Annual Hours estimated based on data obtained from 

CFA survev (1/18/02). See Attachment P. 

-31-

co 

r-o 
Table 3: Revised Hours of Operation for Specific Facilities 

Facility Name 

Universal-Rundle Corp. (Union Point) 

Universal-Rundle Corp. (New Castle) 

Xerxes/Proform (W. Memphis) 

Xerxes Corp. (Seguin) 

Xerxes (Hagerstown) 

Xerxes Corp. (Anaheim) 

Hours per 

Year 

2375 

2000 

4000 

4000 

4000 

4000 

Basis 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Annual Hours estimated based on data obtained from 

CFA survey (1/18/02). See Attachment P. 

Letter from C. Peterson, Xerxes Corporation, 10/29/01. 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, Xerxes Corporation, 10/29/01. 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, Xerxes Corporation, 10/29/01. 

Docket No. A-94-52 IV-D-111 

Letter from C. Peterson, Xerxes Corporation, 10/29/01. 

Docket No. A-94-52 IV-D-111 

-32-

*• 

CO 

CO 
P.34 

ATTACHMENT A 

PTE Size Analysis 

Pacific Environmental Services, Inc. 

1/8/03 

33 
P.35 

MEMORANDUM 

TO: RFP Docket 

FROM: Pacific Environmental Services, Inc. (PES) 

DATE: January 15,2003 

SUBJECT: PTE Size Analysis 

Many commenters expressed concern that the PTE sizing algorithms in the proposal cost 

analysis underestimated the size, and therefore the cost, of enclosures. Many commenters 

provided detailed information on dimensions of existing enclosures, booths, or other operations 

areas. We used the facility-supplied dimension data to calculate total enclosure volume and 

compared that volume to the total enclsore volume calculated for each facility using our original 

algorithms. We then calculated the percent change in estimated enclosure volume and plotted it 

against facility resin usage. This was done for 17 facilities. 

As shown in Table 1, the differences between the PTE estimates based on plant data and 

estimates from our original algorithms can be quite significant at individual facilities. However, 

the average sizes are about the same, especially at lower resin annual usages. For fhe 15 facilities 

with total annual resin and gel coat usage of less than 5000 tons per year, our original algorithms 

calculated an average PTE volume of 78,336 compared to an average PTE volume of 77,297 

using the facility-supplied data. Furthermore, the original algorithms overestimated the PTE size 

in 10 out ofthe 17 cases for which we had data to consider. 

Based on this analysis, we concluded that the original algorithms provide reasonable 

estimates for PTE sizes for the industry as a whole. 

3^ 
P.36 

Table 1 

Facility 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

0 

P 

Q 

Total Resin + 

Gelcoat Use 

(tpy) 

11,749 

1,248 

1,437 

2,757 

2,532 

2,912 

8,124 

3,369 

3,622 

3,476 

1,248 

2,429 

1,267 

1,248 

4,347 

3,201 

3,437 

Total Volume Using 

Proposal Sizing 

Algorithms 

(Cubic Feet) 

169,720 

71,392 

93,352 

79,872 

79,872 

79,872 

186,096 

88,512 

88,512 

88,512 

74,592 

79,872 

68,832 

71,392 

77,296 

77,296 

55,864 

Total Volume Using 

Facility Speciflc Data 

(cubic Feet) 

478,180 

337,000 

35,124 

23,940 

21,726 

57,870 

405,000 

128,016 

39,240 

33,040 

45,696 

53,208 

39,728 

153,576 

99,432 

25,872 

65,984 

Percent Change in 

Size 

182% 

372% 

-62% 

-70% 

-73% 

-28% 

118% 

45% 

-56% 

-63% 

-39% 

-33% 

-42% 

115% 

29% 

-67% 

18% 

35 
1/15/2003 

Percent Difference in PTE Size for Facility Specific Data Compared to Original Estimates 

400% 

350% 

300% 

250% 

E 

•§ 200% 

> 

UJ 

0) 

c 

« 

O 

150% 

100% 

50% 

0% 

-50% 

-100% 

• 

• 

• 

• 

• 

0 2000 4000 

* • • •• ' 

6000 

• 

8000 10000 

• 

12000 14( 

0% = oriainal estimate 

Resin Use (tpy) 

PTEchart 
P.38 

ATTACHMENT B 

Contact Report: James Stone, Durr Environmental 

By Melanie Proctor 5/11/01 

37 
P.39 

Contact Report 

From: Melanie Proctor, Pacific Environmental Services, Inc. (PES) 

Date: May 11,2001 

Contact: Mr. James Stone, Sales Manager r On-Site Programs 

Company: Durr Environmental, Inc. 

Telephone Number: (630) 587-9960 

Fax Number: (630) 587-9970 

Contact Summary: 

Mr. Stone was contacted to verify cost information previously provided to the Research Triangle 

Institute (RTI) for Durr Environmental, Inc. rotary concentrator systems. In response to Ms. Proctor's 

questions Mr. Stone indicated the following: 

The pressure drop in Durr rotary concentrator systems without any pre-filtration is between 6-8 

inches and the combined fan and motor efficiency is between 65 and 80 percent. The data provided to RTI 

in 1996 are for systems without any pre-filtration. Facilities generally need at least some pre-filtration, 

however, the amount of pre-filtration varies from facility to facility. 

The data provided to RTI show no step up in electrical consumption due to an increased pressure 

drop when switching from a recuperative to a regenerative oxidizer because the thermal efficiency ofthe 

regenerative oxidizer has been reduced from 95 to 90 percent to yield a higher stack gas temperature 

needed to desorb the volatile organic compounds (VOCs) from the carbon in the pre-concentrator. The 

lowered thermal efficiency reduces the pressure drop for the regenerative oxidizer. 

With regard to fuel use, Mr. Stone explained that facilities may choose a concentrator/recuperative 

oxidizer for flows less than 75,000 cfm and a concentrator/ regenerative oxidizer for flows at 75,000 cfin 

and above. He added that from a technology standpoint, a recuperative oxidizer could be used at any flow 

rate even at flows above 75,000 cfm, but for higher flow rates a regenerative oxidizer may be a better 

choice from an economical standpoint. Mr. Stone added that balancing operating and capital cost 

considerations will determine the customer's choice between a recuperative and a regenerative oxidizer. 

3? 
P.40 

ATTACHMENT C 

Table Prepared by Keith Barnett 

Based on Applachian Plastics Trip Report 

3<7 
| Kenneth Meardon - Appalachian Resin.xls 

P.41 

Page 11 

Application Method 

Mechanical-Atomized 

Mechanical-Atomized 

Mechanical-Atomized 

^ Mechanical-Non-Atomized 

Mechanical-Non-Atomized 

Mprhanical-Non-Atomized 

IVIvwl IOl MwGil l iu i i niw i i n^v*u 

Mechanical-Non-Atomized 

Mechanical-Npn-Atomized 

/ Mechanical-Atomized 

* Mechanical-Atomized 

Mechanical-Atomized 

/Filament Winding 

Filament Winding 

/ Filament Winding 

v Filament Winding 

Manual 

—>> Manual 

xiiM^

 Manua l 

Resin Type 

Corr 

ConConCorr 

Corr 

Corr 

Corr 

ConNCR 

NCR 

NCR 

Corr 

Quanity %HAP 

704 

2800 

14400 

7600 

75744 

1^7R 

/^53 ^cT^^ftT^ 

High Strength 

NCR 

NCR 

NCR 

NCR 

NCR 

27739 • 

195623 

14853 

30910 

1186 

46949 

42606 

15603 

58209 

232692 

45410 

278102 

1779 

5170 

5170 

12119 

i 

36 

39 

49 

41 

43 

36 

39 

35 

29 

40 

37 

43 

35 

29 

40 

37 

40 

40 

Weighted UEF Weighted 

HAP 

0.12956 

0.55822 

3.60694 

1.59286 

16.64933 

2.46155 

10.61808 

4.96294 

40.57947 

9.17457 

26.33496 

0.93467 

36.44421 

31.47379 

9.38180 

40.85559 

24.26472 

6.53142 

30.79614 

5.43139 

17.06411 

17.06411 

39.55962 

UEF 

154 

197 

340 

96 

102 

80 

89 

77 

47.32 

211 

168 

177 

133 

106.72 

160 

106 

123 

123 

0.6 

2.8 

25.0 

3.7 

39.5 

5 5 

24.4 

10.9 

112.3" 

15.0 

139.0 

4.3 

158.3 

< ^ 

-to«^> )3^ 

C is^.-vx129.2 

35.5 SJ f*Y\J3*-J-*a

-*-a* 

164.8*/ <to#'ZfruJ n 

89.3 

26.1 

115.4 

15.5 

52.5 

52.5 

120.5 

^irvtt^Aa-o Ip-Juu-i 

C G J 

Ho 
P.42 

ATTACHMENT D 

Email from Chuck Taylor to Keith Barnett (forwarded to Ken Meardon) 

1/30/02 
P.43 

Page T 

From: <Barnett.Keith@epamail.epa.gov> 

To: <KRMeardon@mactec.com> 

Date: 1/30/02 3:41PM 

Subject: A.R.E. Inc. Raw Material Usage 

Dear ken; 

We need to update the information for A.R.E. We have 1997 data from the 

trip report for Massillon, but we did not split the resin into filled 

and unfilled. We did not even list A.R.E. in the unfilled table. 

Probably it would be best to just use the 2000 data for Massillon and 

Mount Eaton. The 1997 data for Mount Eaton in the trip report would now 

be considered atypical. 

Keith W. Barnett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

barnett.keith@epa.gov 

— Forwarded by Keith Barnett/RTP/USEPA/US on 01/30/2002 03:25 PM 

Chuck Taylor 

<ctaylor@gtenvironm To: Keith Barnett/RTP/USEPA/US@EPA 

ental.com> cc: Ralph Gatti <rgatti@4ARE.com> 

Subject: A.R.E. Inc. Raw Material Usage 

01/30/2002 03:02 PM 

Keith... 

A.R.E. Inc. provided me the following information/data to forward to you 

concerning the use of resins and gelcoats at their two Ohio facilities 

during CY 2000: 

Massillon Facility: 

Gelcoat Spray-Applied 917,714 lbs H^? ^ 

Unfilled Resin Spray-Applied 2,142,714 lbs /•>-?! -^ M 

Filled Resin Spray-Applied 

Resin 2,535,700 lbs 12-b") SS fyy 

Filler 801,281 lbs MCk-bH rp ^ 

Mt. Eaton Facility: 

Gelcoat Spray-Applied 157,888 lbs ^ * ^ W 

Unfilled Resin Spray-Applied 320,865 lbs | ^ D , LJ 

Filled Resin Spray-Applied 

Resin 205,142 lbs | p'2 . ^ I 

qr 
P.44 

"fT-xeTine^ ""*-*—~-~~~ •••• --~—~ > —~~—~~~~~~-----^

 p

^e^ 

Filler 64,500 lbs 32. 2 S ftfM 

Let me know if you have any questions concerning these data... 

Also, what's the forecast for final adoption of this MACT? I've got 

people asking me ifthe 112(j) "MACT Hammer" will come into play... 

What can you tell me about this? I've got the same questions concerning 

the plastics parts coating MACT... Do you have anytyhing you can share 

about that MACT as well? 

Thanks, 

Chuck Taylor 

Principal Consultant 

GT Environmental, Inc. 

635 Park Meadow Road, Suite 112 

Westerville, OH 43081 

(614)794-3570 

(614)899-9255 FAX 

ctaylor@gtenvironmental.com 

43 
P.45 

ATTACHMENT E 

FAX from Kevin Maas to Ken Meardon 

4/2/02 

q^ 
I -

UJ 

UJ 

UJ 

U. 

PEARL 

Thtre-s Only Ont Trut Whirlpools) 

_ # of Pages: (including this cover sheet) cTO 

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> Company: 

> Facsimile: 

: ^Ar y!py\ fYWrA^ p 

FROM 

> Name: favUft uWl« 5 

> Company: 

MESSAGE 

«Kkn - rWe.' ^ vpUftT T fn-olA <A\a up . fc)'\Ji 

_k£AUQ £ _ 

If any of the pages are illegible or not received, please contact us at 763-424-3335 for re-transmission. 

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m 

m 

m 

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rvj 

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CvJ 

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rvj 

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Tooling Gel Coat 

^Tooling Gel Coal HAPContenl Production p Surface Characteristics of Finish** Frequency Re-work LfeofMol d 

Identifier Total or Repair "^ r Parts of Use Frequency 

Suoolier 

(Jrcnstw 

85-503940 

85-508050 

CMVOUT 

945YA058 

<bc«,vi**>-**\ 

B-M50 

Ferro CorporaUon 

Ferro Corporation 

Cook Composites 

HK Research 

39.94 

41.97 

46703 

42 

Production i 

Repair 

ProducUon 8 

Repair 

Production 8 

Repair 

Production 8 

Repair 

Tubs & Tubshowers 

Tubs & Tubshowers 

Tubs S Tubshowers 

Tubs & Tubshowers 

Class "A" Surface - Automotive 

Grade Finish 

Class "A" Surface - Automotive 

Grade Finish 

Class "A' Surface - Automotive 

Grade Finish 

Class "A" Surface - Automotive 

Grade Finish 

2.5 times 

per day 

2.S times 

per day 

2.5 limes 

per day 

2.5 limes 

per day 

Every 100 

parts 

Every 100 

parts 

Every 100 

parts 

Every 100 

parts 

Undetermined 

Undetermined 

Approximately 

12.000 Parts 

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The Ferro materials aiso contain a small amount or benzene according to Ihe MSDS sheets. The MSDS sheets also [ist Ihe total 

volatiles by weighl as being higher than the sum of styrene and MMA as shown in the tat. . 

,..,.*. . 'I 

^1 
P.48 

ATTACHMENT F 

Note from Bristol Fiberlite File 

Documenting phone call from Madeline Strum to Ashland Chemical 

12/03/96 

4~7 
P.49 

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C<xbfackad -to p& lo/^nqio co/Hoier 

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P.50 

ATTACHMENT G 

Email from John Schweitzer to Keith Barnett 

3/19/02 

M<\ 
P.51 

; Kenneth Meardon - Re: Updates to the database PageTJ 

From: "John Schweitzer" <jschwtzr@gte.net> 

To: <Barnett.Keith@epamail.epa.gov> 

Date: 3/19/021:59PM 

Subject: Re: Updates to the database 

Keith, the contact names and phone numbers are included in the reports at the end of my message 

(below). John 

— Original Message — 

From: Barnett.Keith@epamail.epa.gov 

To: John Schweitzer 

Cc: KRMeardon@mactec.com 

Sent: Tuesday, March 19,2002 1:44 PM 

Subject: Re: Updates to the database 

Please send your list of contact names and we will handle any follow up. 

I will want to double check this (we are getting into another one of 

these going round and round making changes to the data base) and make a 

written record of the conversation so I have documentation if we are 

later challenged on these changes. 

Keith W. Bamett 

US/EPA OAQPS, ESD/MICG C504-05 

Research Triangle Park, NC 27711 

919-541-5605 

bamett.keith@epa.gov 

John 

Schweitzer To: Keith Bamett/RTP/USEPA/US@EPA 

<jschwtzr@gte cc: "Larry (LJ) Craigie" 

.net> <lcraigie@cfa-hq.org> 

Subject: Updates to the database 

03/19/2002 

01:28 PM 

Please 

respond to 

John 

Schweitzer 

Keith, below is the "raw data" from our contacts with some of the 

facilities in the new combined non-CR mechanical database. (These 

companies were contacted by Larry Craigie of the CFA Technical 

Department.) 

So 
P.52 

j Kenneth Meardon - Re: Updates to the database Page 2 \ 

In summary: 

1. Contemporary Products makes only very limited use of VSR and 

vacuum bagging, contrary to what's shown in the database. Also, 

they have a unique double-roll-out process that probably increases 

their emissions significantly (to an unknown level). They should 

be removed from this database (or their emission rate assumed to be 

"unknown"). 

2. CDR Systems (3 plants) does not use any mechanical 

application and should be removed from this database. 

3. Custom Fiberglass Molding has gone back to atomized 

application due to quality problems. The emission rate for this 

operation should be re-estimated based on atomized application. 

4. Livingston has stopped operations and should be removed from 

this database. 

5. Krueger International no longer does FRP fabrication and 

should be removed from this database. 

The database should be corrected, and the floor adjusted, to reflect 

this up-to-date information. Please let me know if you need us to 

provide more information, ask the sources to contact you directly, or et 

cetera. 

Thanks, 

John 

Contemporary Products, #8 

Steve McNally 

262 781 5130 

A) They do not use Vacuum bagging very much in fact almost none in the 

last 

two years. 

B) The only time they use a VSR is on a gel coat when it is applied to a 

fabricated part. 

C) They have a modified flow coater they use regularly but their process 

requires they 

wet and roll on the wet out table then move the wetted fabric to the 

mold 

where it is rolled again. This double rolling and moving the composite 

doubles the emissions from the roll out process. 

D) The database does not give them credit for VSR or vacuum bagging. 

Also 

it does not penalized hem for double roll-out process. 

CDR Systems, #"511,12,13 

Al Kaeding 

386 615 9519 

A) The styrene Spec fbr all plants is 35% max 

B) They quit using flow coaters due to quaiity problems instead they use 

manual application not spray guns. 

5' 
P.53 

tkenn'ed-Meadon-ke: Updates ,o ihe database Kgm 

**ggg£^^__£ggg*gg*g'g-g'^'g^QBHMH''''''''''''''|'''''''*''M'l'^ 

C) They do not use Vacuum Bag techniques in this process 

Custom Fiberglass Molding, Inc # 15 

Richard Discher (sp?) 920 867 2606 

A) Switched to HVLP (atomized) application in place of flow coaters due 

to 

quality an productivity problems. 

Livingston, Inc #16 

Bob Morgenstern 253 288 0520 / Cecelia Jackson 313 336 4182 

A) This plant was purchased by Cambridge Industries and soon went 

chapter 

11. 

B) Meridian Automotive bought this portion ofthe Cambridge assets. 

This 

plant located in Auburn Washington has been shut down. 

Krueger I ntemational #19 

Ray Roseneau 920 468-8100 X2664 / Laura Mischinski 920 496 6846 

A) Kl no longer performs FRP work at the Green Bay location. 

The Kl FRP mfg. at Gillette, Wl was sold to Wasacki and may still be 

doing 

FRP. 

FROM======================== 

John Schweitzer 

Sr. Director of Gov't. Affairs 

Composites Fabricators Assoc. 

voice 734.622.0162 

fax 734.622.0122 

jschwtzr@gte.net 

www.cfa-hq.org 

CC: <KRMeardon@mactec.com> 

5 ^ 
P.54 

ATTACHMENT H 

Letter from John Laux to Keith Bamett 

2/8/00 

S3 
P.55 

GLP 

Great Lakes 

Plastics 

Corporation 

P.O. Box 600 

Houghton County 

Airpark 

Hancock, Ml 49930 

906/482-3750 

FAX: 906/482-2585 

2/8/00 

Mi. Keith Bamett 

USEPA 

MD13 

RTP.NC 27711 

Dear Mr. Bamett 

Great Lakes Plastics Corporation is appreciative of tiie opportunity to express our concerns regarding the 

proposed MACT standards. 

Because of tiie variables within the composites industry including production technology, materials, and 

equipment suitable for each process, it is difficult to accept the "one size fits all concept". 

We in the tub and shower category would have some difficulty meeting the proposed standards mainly in 

the areas of equipment investment, suitable available materials and the additional cost for them, and of 

course the requirement to make a capitol investment to install equipment to meet the perquisites ofthe EPA 

in emission control, if we find ourselves in that category. 

We have worked very diligently over the past twenty-five years to produce a high quality product and 

cultivate a customer base that remains loyal today. The additional cost that we would have to absorb or 

pass on to the consumer would not permit us to remain in tiie market That is a fact. 

Examples of some of tiiese costs: 

New equipment - we have already introduced two flow coat-laminating guns in December at a cost of 

$15,000 we are considering a gelcoat system at this time also, and a third flow coater for laminating acrylic 

products. 

Resin - we have been quoted on low styrene resin costs that would equate to almost a $100^000 per year 

increase based on our current usage. This does not include gelcoat increases when we decide to make that 

transition; but a fair estimate would be an additional $30,000 to $40,000. 

Product quality - could be jeopardized because of modified or suppressed resins that would not work 

well in a two-coat process. We would be fearful of product failure and the cost and repercussions they 

present. 

Future Growth Potential - we would be required to remain under the 100 ton threshold which we 

present as a concem based on your proposal to control efficiency on facilities over that leveL This would 

be cost prohibitive and totally restrictive to our growth potential and customer commitment to our products. 

Introducing engineering devices such as absorbers or after burners would not be feasible at this point 

because ofthe enormous investment required. 

Throughout our composites histoiy we have staved to find methods and materials that have addressed the 

very concerns of EPA, as did most in our industry. We have achieved numerous successes and continue to 

seek otiier improvements as well. Our organization, "Composites Fabricators Association" has done 

comprehensive evaluations ofour processes and has shared this information with its members and witii 

EPA. The facts speak for themselves. It is our hope that EPA will consider all ofthe cuirent infonnation 

prior to establishing a final dictate. 

Manufacturers of Warm Ra 111 Moulded Bathing Modules 
P.56 

It is witii great anticipation that fhis entire industiy, which has struggled so hard and has achieved so much, 

awaits an informed and favorable consideration so that it may continue to flourish. 

Sincerely, 

leral Manager 

John J. Laux 

JL/sh 

SS 
P.57 

ATTACHMENT I 

Facility Survey Table Prepared by Mike Cassidy (Kohler Co.) 

Sent to Ken Meardon by email 4/10/02 

S(* 
P.58 

•jfRehneth Meardon- RPC MACTqljestionnaJre^Aprii02~doc " ''""" " Page 11 

April 10, 2002 

Kenneth R. Meardon 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Research Triangle Park, NC 27709 

Dear Ken: 

Subject: RPC MACT Questionnaire For Kohler Co.'s - Brownwood. TX Facilitv 

Attached is a table providing the information requested in your March 27, 2002 fax to me 

for Kohler Co.'s Brownwood, TX RPC fixture fabrication facility. This facility operates an FRP 

fixture plant and an acrylic fixture plant. I have listed the operating hours for each plant 

separately. 

The gelcoat resin is attributable to the FRP plant only. The bonding resin is attributable 

to the acrylic plant only. The general-purpose chop coat resin represents the total used in both 

plants. 

If you have any questions about this information, I may be contacted at 920-457-4441, 

extension 77263, or via e-mail at mike.cassidv(fl),kohler.com. 

Sincerely, 

Mike Cassidy 

Kohler Co. 

Enclosure 

57 
P.59 

j Kenneth iVfeardon - RPC^^ "Fage~2~| 

Facility Name and Location*. Kohler Co. - Brownwood. TX 

Hours of Operation*. Acrylic Fixture Plant: 3,480 hrs 

FRP Fixture Plant: 2,395 hrs 

Year for Which Data Is Being Reported: 2001 

FACILITY SURVEY TABLE 

Process Grouping 

Open molding: 

mechanical 

Open molding: filled, noncoirosion, mechanical 

Open molding: filled, noncorrosion, mechanical 

Material 

Pigmented gel coat 

General purpose 

chop coat resin 

Acrylic bonding 

resin 

Quantity 

Used (tpy) 

16 

1386 

170 

Average HAP 

Content 

(wt. %) 

36-45 

44-48 

36-39 

Application 

Technique 

Spray (100%) 

mechanical, non-atomized 

(impingement guns) 

(100%) 

mechanical, non-atomized 

(impingement guns) 

(100%) 

Other Enlission 

Reduction 

Technique 

none 

none 

none 

Color 

(gel coat 

only) 

All colors, 

including 

white 

NA 

NA 

5? 
P.60 

ATTACHMENT J 

Letter from Wayne Spidahl (Nordic Fiberglass, Inc.) to Keith Barnett 

2/13/00 

S<\ 
P.61 

ORDIC FIBERGLASS, INC. 

p.o. BOX 27 Warren, Minnesota 56762 

TELEPHONE: (218) 745-5095 E-MAIL: nordic@ruralaccess.net 

FAX: (218) 745-4990 www.nordicfiberglass.com 

February 13, 2000 

Mr. Keith Bamett 

US EPA 

MD13 ' 

RTP.NC 27711 

Dear Mr. Barnett, 

Nordic Fiberglass produces fiberglass equipment for the electiic utility industry. Our product consists of 

pad mount transformer box pads and different enclosures for electrical apparatus. As the utility industry 

upgrade their systems from over head power lines to underground lines the market will continue to grow. 

Our type of fiberglass products will play a pivotal role in not only new construction but also repair of 

current under ground wiring systems. There are two materials that could replace the fiberglass 5" tall 

transformer support pads, plastic and concrete but at this time there is no pads of greater height 15" to 32" 

inheight that can replace these products made of fiberglass. The taller products give better stability in the 

soil and allow for the cable to be coiled under the transformer.' In 1999, two1 large investor owned utilities 

switch from concrete flat pads to fiberglass box pads which tells rne of thecost effectiveness of using 

fiberglass over concrete. The reason that was given was diie to the long-tenn benefits of the fiberglass box 

pad. On tlie enclosure line we are seeing the utilities move from metal enclosures to fiberglass enclosures. 

There are 2 reasons I believe is causing this change, 1. In time metal will begin to rust and the utility will 

be required to repaint it. This will create unconuolled emissions 2. Becanse of tlie high dielectric strength 

of fiberglass is it safer for the general public than metal. Should the system ground fail on the metal 

enclosure the enclosure could become energized. Should this happen on the fiberglass enclosure, the 

dielectric strength is great enough to protect the system inside for most failures. 

Over the past 10 years we have been reviewing methods to reduce styrene emissions. I believe that .. 

source reduction is the answer, not control and capture equipment. During this time, we have been working 

on our fonnulations and equipment with different degrees of success and failure. 

In 1989 we switched over to a BPO cured resin which at first we thought gave us less emission but we 

could not substantiate. At this time our styrene levels were around 48-50%. I gave tlie direction to our 

resin suppliers to develop a lower styrene content resin. In the early development of these resins we had 

some large problems with the resins. However, in 1998 we were able to get two lower styrene resins to 

work one at 42% and one at 35%. When we drop below these levels the products begin to loose 

workability and too much strength is lost in the product due to the decrease in cross-linking or lack of 

styrene. 

On the gel-coats we are currently working on lower VOC gel-coats but there again the materials require the 

higher HAP level to gain the workability and required field perfonnance. 

We have reviewed many different molding techniques to include RTM and Vacuum molding. My feeling 

on these'systems is they will work if you can run your operation as a cost plus operations In today's 

climate this is hot an option. They were slow and had many limitations for higher volume production and 

to costly for lower volume production. 

(oO 

>>> Quality Products for the Electric Utility Industry << < 
P.62 

We have been moving our higher volume parts into compression molding using SMC and wet molding 

when cost effective. We will continue to move in this direction when it is cost effective and the volume of 

sales vvill support the capitol investment required. Hands down, these options optimize emission reduction 

technology at the source. 

One area that has received no attention is the use of robotic sprayers for applying the chopped glass and 

resin. We currently have two systems running and a third one on order. We are using the lower HAP resin, 

35%, on both systems because ofthe controls that we have with robotic spraying. Why is this not being 

addressed in the MACT standard as controlled spraying? I completely understand why the EPA would not 

want to accept controlled spraying tecluiiques with a manual system. But with a robotic system, once 

programmed correctly we have realized a large reduction in over spray and we know our transfer efficiency 

has increased which reduces emissions. The spraying is now done at the same distance from the mold 

every time. The tiiird system on order will have a closed loop so when the program is final the robot will 

control all movements and air pressures for the resin and chopped glass. If diis works like we believe it 

will, the first two systems will then be up graded to include the closed loop technology. Is it possible to get 

an explanation as to why the use of robotics is not being considered as controlled spraying? 

Overall, in the past ten years we have been up grading our operations to comply with the MACT standards. 

Should the EPA require for operations such as our to install any type of control or capture technology we 

would have no choice but to start closing our plants. We currently have 11 plants that total around 

100,000 square feet. Based on $500,000 capitol investment for each plant it would require, for us to invest 

$5,500,000. We have already researched this investment and have concluded that this type of investment, 

not to include die operational expense, would not be financially possible for Nordic at this time or in the 

fiiture. I also do not understand the full thought of the EPA. If fabricators install control and capture 

equipment you reduce the amount of styrene released by burning natural gas which also releases C02 to 

the environment. However, when you are buming natural gas you are also emitting nitiogen oxide. When 

styrene is emitted into the atmosphere it breaks down fairly fast and is also turned into C02. So what is 

gained but to use up more of an un-renewable resource, natural gas. I have not been able to find research 

information as to how much C02 that the styrene being emitted is estimated to release into the atmosphere 

opposed to how much the control or capture equipment would emit. Does the EPA have information 

pertaining to this? If not, this is something that I believe should be researched before capture equipment is 

installed. Also, what will die direct economic impact be to the fiberglass industry due to jobs losses oyer 

such a mandate? In our company it would directly affect all 130 employees that would be without a job. 

I look forward to your comments on the use of robotics. 

Sincerely, 

-y^ ~ 

Wayne L. Spidahl 

General Manager 

Nordic Fiberglassjnc. 

(ff 
P.63 

ATTACHMENT K 

Letter from Steve Allison (Plastic Development Co.) to Keith Barnett 

2/15/00 

6^ 
P.64 

Plastic 

flq Development 

Company 

West Fourth Street 

Post Office Box 4007 

Williamsport,PA 17701 

570.323.3060 

800.451.1420 

fax 570.323.8485 

http://www.pldevco.com 

pdcspas@pldevco.com 

pdcs^Qs 

February 15,2000 

Mr. Keith Bamett 

USEPA 

MD13 

Research Triangle Park, NC 27711 

Dear Mr. Barnett: 

This letter is to address the concerns we have over the new MACT 

standard. At Plastic Development Company, Inc., we manufacture 

fiberglass spas and baths. We start with a piece of cast acrylic sheet, 

which is vacuum formed and then backed with fiberglass for support. 

The environment that a spa is subject to, the chemicals, and high water 

temperature is very demanding. It is critical that there is a superior bond 

between the acrylic and substrate. Vinyl ester resins play a key role for 

us in that regard. The spa industry nation-wide has made the change to 

vinyl ester in the past five years, which has made on the whole a much 

more reliable product. Using resin other than vinyl ester or a low styrene 

vinyl ester which in my experience does not have the superior adhesion 

would drastically reduce the quality and performance ofthis product. 

You can see how imperative it is to use a strong bonding resin on the first 

laminate however the 2nd and 3rd laminate only need to have good 

structural characteristics. Low styrene resin are a possibility in this part 

ofthe process, but the manufacturer of these resin need to make these at a 

low cost and easier to work with than what is currently available. 

Alternative technology such as vacuum bagging will not work on spas 

due to the drastic irregular shape ofthis product. However, we have 

invested in the Flo Coater system by Venus Gusmer, which is working 

very well for us. 

If these rule changes are allowed without further investigation on the 

impact to the spa industry, the result could be possibly be a higher cost 

and lower quality product for consumers. 

Sincerely, 

></2^ 

Steve Allison 

Production Manager 

<o3 
P.65 

ATTACHMENT L 

Spreadsheets prepared by Lasco 

2/13/02 

^ 
6^ 

Plan l 

Anahei m 

Soul h Bosto n 

3 Rivers 

Lancaste r 

Cordel e 

Yel m 

Elizabethtow n 

Moap a 

Total 

Gelcoa t 

1,825,718 

1,042,255 

1,435,182 

1,424.177 

1.450,505 

1,095,018 

1.285.823 

1,367,468 

10,926,146 

% Styrena 

36% 

3 6 % 

36% 

3 6 % 

36% 

3 6 % 

3 6 % 

3 6 % 

UEF 

17.8% 

17.8% 

17.6% 

17.8% 

17.8% 

17.8% 

17.8% 

17.8% 

EMISSIONS PERCENT OF TOTAL EMISSIONS 

Pound a o f Resi n Usa d 

Emission s 

324.978 

185.521 

255.462 

253,504 

258,190 

194,913 

228 876 

243 409 

1,944,854 

46.4% 

Laminat e rati o 

7.084.439 

3.627.354 

5,061.102 

5,167,004 

5,095,450 

4,546.338 

4,523,798 

•'•. ••22 23 5 

40 528,720 

% Styren e 

36 0% 

39 0% 

39 0 % 

39 0 % 

390 % 

36 0 % 

39 0% 

36 0% 

[May 2000 - A >rtl 2001) 

uef 

4 0% 

4.5% 

4.5% 

4.5% 

4 5 % 

4 0 % 

4 5% 

4 0% 

Emission s 

283.378 

161,417 

225,219 

229,932 

226.748 

181,854 

201.309 

216.929 

1,726.735 

42.9% 

935,616 

437,069 

629,315 

652,960 

616.558 

541,448 

541,541 

553,078 

5.007.585 

367= 

36% 

3 6 % 

36% 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

U EF 

7.0% . 

* 7.0% | 

7 0 % 

7.0 % 

•7.0 % 

7 0 % 

7.0% 

7 0 % 

| 

B5 493 

30.595 

••••'. 052 

45.707 

43.159 

37,901 

37,908 

•:•' •• • 

H Tota l Emiaaion a 1 

673,848 

377,533 

524,733 

529,142 

528,096 

414,668 

468,093 

506.054 

350.531 4,022.170 

8.7% 100 % 

PLANTS WITH PARTIAL CONTROLS gelcoate d product s onl y 

Plant 

Sout h Bosto n 

Lancaste r 

Yel m 

Elizabethtown 

Moap a 

Gelcoat 

1.042,255 

1,424.177 

1,095,018 

1.285.823 

1,367,466 

Emission s 

185,521 

253.504 

194,913 

228.876 

243.409 

% Contro l Net Emission s 

77.6% 

77.6% 

77.6% 

77.6% 

9 2 2 % 

41,581 

56,817 

43.686 

51.298 

19.083 

Laminat e Resi n 

3.627.354 

5,167,004 

4.546.338 

4,523.798 

5.423,235 

Emission s 

161.417 

229,932 

181,854 

201,309 

216.929 

% Contro l 

46.1 % 

46.1 % 

23.0% 

"J5 1 % 

92.2% 

Net Emission s 

87,036 

123 97 9 

139 954 

108 546 

17 007 

iWCoa l 

437.069 

552,960 

541,448 

541,541 

653.078 

Emission s 

:-c -.'.••-: 

4 5 707 

3 7,90: 

37,908 

45 715 

% Contro l 

150% 

0 0% . 

. 0.0% 

77,6 % 

9 2 2 % 

Net Emisston s 

.'. 595 

45,707 

37.901 

B 496 

3.564 

Tota l Emission s 

159,212 

226,504 

221,541 

168,340 

3S.675 

% Controlle d 

57,8 % 

• 57.2 % 

46.6% 

* 64.0 % 

S2:; % 

Precast 

Gelcoat 

L a m 1 

Lam 2 

Phase 

Spray 

Cure 

Spray 

Cure 

Spray 

Roll 

Cure 

Spray 

Roll 

C u e 

Percent 

by Phase 

6 7 % 

3 3 % 

6 7 % 

3 3 % 

5 0 % 

2 5 % 

2 5 % 

5 0 % 

2 5 % 

2 5 % 

Anahei m 

Sout h Bosto n 

3 Rivers 

Lancaster 

Cordel e 

Yel m 

Elizabethtow n 

Moap a 

Acryli c Resin lbs/year FY2001 

no acrylic manufacturing 

2.278,638 pound s 

no acrylic manufacturing 

no acrvlic manufactunng 

no acrylic manufacturing 

769,379 pound s 

no acrylic manufacturing 

no acrylic manufacturing 

Estimate d captur e 

Gelcoa t (Moapa ) 

Gelcoa t 

Barrier Coa t 

1st Laminat e Resin (Moapa ) 

2nd/3r d Laminat e Resi n (Moapa ) 

1st Laminat e Resin 

2nd/3r d Laminat e Resi n 

Spra y 

9 6 % 

9 6 % 

96% 

9 6 % 

9 6 % 

9 6 % 

9 6 % 

Rol l 

na 

r.i-, 

na 

9 6 % 

9 6 % 

0 % 

0% 

Cure 

9 6 % 

5 0 % 

5 0 % 

9-6% 

9 6 % 

0% 

0% 

Tota l Captur e 

96.0% 

808 % 

80 3% 

96 0% 

96.0% 

48.0% 

48 0% 

% Destructio n 

9 6 % 

9 6 % 

9 6 % 

9 6 % 

9 6 % 

9 6 % 

06* 

Tota l % Controlle d 

92.2 % 

77.6 % 

92.2 % 

92.2 % 

46.1 % 

46 1 % 

1 METHOD 204 HAS NOT BEEN USED TO DETERMINE CAPTURE EFFICIENCY. 

2 DUE TO THE PUSH/PULL MAKE-UP AIR & EXHAUST SYSTEM AND THE CONVEYOR METHOD OF MOVING PARTS METHOD 204 

COULD NOT BE DESIGNED INTO THE PRODUCTION PROCESS UNLESS CONTROLLED AT 100% WITH GREATER AIR FLOWS 

3 ALL FUGITIVES ARE ESTIMATED AT 4% (FOR ALL PROCESSES) DUE TO THE EXTREMELY LOW AIR FLOWS AND/OR DIFFEREN 

OF MAKE-UP TO EXHAUST AIR FLOW RATIOS 

4 THE RTO @ YELM IS ONLY USED AS NEEDED TO STAY BELOW CAP OF 249 TPY 

5 Acrylic resin usage for same period = 2,278,638 lbs (South Boston) & 769,379 lbs (Yelm) 

6 Magnum FIT equipment operational at each plant approx. 

TIAL 

Anahei m 

Sout h Bosto n 

3 River s 

Lancaste r 

Cordel e 

Yel m 

Elizabethtow n 

Moap a 

DATE 

Jul-00 

Oct-01 

Sep-01 

Sep-01 

Aug-0 2 

May-01 

Apr-0 1 

Jul-00 

Mixin g Type 

Intema l 

Intema l 

Intema l 

Internal 

Internal 

Intema l 

Intema l 

Externa l 
^ 

^ 

PLANTS WITH PARTIAL CONTROLS gelcoated products only 

Plant 

South Boston 

Lancaster 

Elizabethtown 

Moapa 

Gelcoat 

1.042 255 

1.424.177 

1.285,823 

1.367.468 

Emissions 

185.521 

253.504 

228.876 

243.409 

% Control Net Emissions 

77 6% 

77.6% 

77.6% 

0 0% 

41.581 

56,817 

51.298 

243.409 

Laminate Resin 

3,627,354 

5 167 004 

4.523.798 

5 423,235 

Emissions 

589 445 

839,638 

735,117 

881.276 

% Control 

46 1% 

46.1% 

46.1% 

0.0% 

Net Emissions 

317 829 

452 733 

396,375 

881.276 

Barter Coat 

437,069 

652.960 

541.541 

653.078 

Emissions 

61,845 

92.394 

76,628 

92 41 1 

% Control 

0.0% 

0 0 % 

77.6% 

0.0% 

Net Emissions 

61 845 

92.394 

17.174 

92.411 

Total Emissions 

421.255 

601,944 

464,847 

1 217.096 

% Controlled 

• 49.7% 

•43.2% 

55.3% 

• 0 0% 

Process 

Gelcoti 

Lam 1 

Lam 2 

Phase 

Spray 

Cure 

Spray 

Cure 

Spray 

Roll 

Cure 

Spray 

Roll 

Cure 

Perceni 

by Phase 

6 7 % 

3 3 % 

6 7 % 

3 3 % 

5 0 % 

2 5 % 

2 5 % 

5 0 % 

2 5 % 

2 5 % 

Estimated capture 

Gelcoat (Moapa) 

Gelcoat 

Barrier Coat (Moapa) 

Spray 

9 6 % 

0% 

.--: Barrier Coat-- 96% 

1st Laminate Resin (Moapa) 0% 

2nd'3rd Laminate Resin (Moapa) 0% 

1st Laminate Resin 96% 

2nd/3rd Laminate Resin '6 

Poll 

na 

na 

na 

na 

0% 

0% 

0 % 

0% 

Cure 

0% 

5 0 % 

0% 

50% 

0 % 

0% 

0 % 

0% 

Total Capture 

0 0% 

808% 

0 0 % 

80.8% 

0.0% 

Q 0% 

48 0% 

48.0% 

% OestructJon | Total % Controlled 

0% 0.0% 

96% 77.6% 

0% 

9 6 % 

0 % 

0 % 

9 6 % 

9 6 % 

0.0% 

77.6% 

0 0% 

0 0 % . 

46*1% 

46.1% 

1 METHOD 204 HAS NOT BEEN USED TO DETERMINE CAPTURE EFFICIENCY. 

2 DUE TO THE PUSH/PULL MAKE-UP AIR & EXHAUST SYSTEM AND THE CONVEYOR METHOD OF MOVING PARTS METHOD 204 

COULD NOT BE DESIGNED INTO THE PRODUCTION PROCESS UNLESS CONTROLLED AT 100% WITH GREATER AIR FLOWS 

3 ALL FUGITIVES ARE ESTIMATED AT 4% (FOR ALL PROCESSES) DUE TO THE EXTREMELY LOW AIR FLOWS AND/OR DIFFERENTIAL 

OF MAKE-UP TO EXHAUST AIR FLOW RATIOS 

i 
-J 

Plant 

Anahei m 

Sout h Bosto n 

3 River s 

Lancaste r 

Cordele 

Elizabethtow n 

Moapa 

Total 

Gelcoa t % Styren e 

1.825,718 

1.042,255 

1,435.182 

1,424,177 

1.450,505 

1.285.823 

1.367.468 

10 926,146 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

UEF 

17.8% 

• ' >:• « 

17.6% 

17.8% 

17.8% 

178 % 

17 8 % 

EMISSIONS PERCENT O F TOTA L EMISSIONS 

Pound s o f Resi n Use d 

Emission s 

324.978 

185.S21 

255.462 

253,504 

258,190 

228.876 

243.409 

1,944.854 

46 7 % 

Laminat e resi n 

7,084,439 

3,627,354 

5.061,102 

5.167.004 

5,095,450 

4.523,798 

5.423.235 

40528,72 0 

% Styrene 

42 6% 

39 0% 

390 % 

426 % 

39 0% 

42.6% 

36.0% 

[May 2000-Apri l 2001) 

uef 

4.5% 

4.5% 

4 5% 

H U H 

4 0% 

Emission s 

361.306 

161,417 

225,219 

263,517 

226.748 

230.714 

216.929 

1 867,704 

44.9% 

B 3 5 •'•.•-

437,069 

629,315 

652,960 

616,558 

541,541 

553.076 

5.007.585 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 6 % 

3 0 % 

U EF | Emission*., | 

:

 7.0% 65.493 

• •7.0% . 30,595 

7 0 % 44.052 

45.707 

43.159 

37,908 

7 0% - 45.715 

ToU l Emission s 

751,777 

377.533 

524,733 

562,728 

528,096 

497,498 

506,054 

350 531 4,163,089 

| 8.4 % 100 % 

PLANTS WITH PARTIAL CONTROLS gelcoate d product s onl y 

Plant 

Sout h Bosto n 

Lancaster 

Yel m 

Elizabethtow n 

Moap a 

Gelcoa t 

1,042,255 

1,424.177 

1,095,018 

1,285.823 

1,367,468 

Emission s 

185.521 

253.504 

194.913 

228,876 

243 •:: • 

% Contro l Net Emission s 

77 6 % 

77 6% 

776 % 

77.6% 

52 2 % 

41.581 

S6.817 

43.686 

51,298 

19,083 

Laminat e Resin 

3627,35 4 

5,167,004 

4,546,338 

4.523.798 

5.423.235 

Emission s 

161,417 

263.517 

181,854 

230.714 

216,929 

% Contro l 

46 1 % 

46.1 % 

23 0% 

46.1 % 

92 2 % 

Net Emission s 

87 035 

142 088 

139.954 

124.401 

17,007 

.:"•• •'••;•• 

652.950 

541,448 

541,541 

30.595 

45,707 

3,:-- 901 

37.908 

653,078 45,7 

% Contro l 

•O0% . 

0 0 % -

-•0,0 % 

-77:e% . 

92.2 % 

Net Emission s 

30 59? 

45.707 

37,901 

8,496 

3.584 

Total Emission s 

159,212 

244.613 

221,541 

184,195 

39,675 

% Controlle d 

. 57.8% 

56.5 % 

*. 46.6 % 

63 0 % 

82.2% 

Process 

Gelcoat 

Lam 1 

L a m 2 

Phase 

Spray 

Cun 

Spray 

Cure 

Spray 

Roll 

Cure 

Spray 

Roll 

Cure 

Percent 

by Phase 

6 7 % 

3 3 % 

6 7 % 

3 3 % 

5 0 % 

2 5 % 

2 5 % 

5 0 % 

2 5 % 

2 5 % 

Anahei m 

Sout h Bosto n 

3 River s 

Lancaster 

Cordele 

Yelm 

Elizabethtown 

Moap a 

Acryli c Resin lbs/year FY2001 

no acryhc manufacturing 

2,278.638 pound s 

n o acrylic manufacturing 

no acrylic manufacturing 

no acrylic manufacturing 

769,379 pound s 

no acrylic manufacturing 

no acrylic manufacturing 

Estimate d captur e 

Gelcoat (Moapa ) 

Gelcoa t 

Barrier Coa t (Moapa ) 

If • Barrier Coa t - 6 

1st Laminat e Resin (Moapa ) 

2nd/3rd Laminate Resin (Moapa) 

1st Laminate Resi n 

2nd/3r d Laminat e Resi n 

Spray 

'j>m.XX.-. 

9 6 % 

96% 

96% 

9 6 % 

9 6 % 

9 6 % 

•yy. 

Rol l 

I*****) 

na 

na 

na 

9 6 % 

9 6 % 

0% 

0% 

Cur e 

96% 

5 0 % 

9 6 % 

50% 

9 6 % 

96% 

0% 

0 % 

Tota l Captur e 

96 0% 

eo.B% 

96 0% 

80.8% 

96.0% 

96 0% 

48.0% 

48 0 % 

% Destructio n 

9 6 % 

9 6 % 

9 6 % 

9 6 * 

9 6 % 

9 6 % 

9 6 % 

9 6 % 

Total % Controlle d 

92.2% 

77,6% 

92 2 Jt 

92 2 % 

46.1 % 

4 6 1 % 

1 METHOD 204 HAS NOT BEEN USED TO DETERMINE CAPTURE EFFICIENCY. 

2 DUE TO THE PUSH/PULL MAKE-UP AIR & EXHAUST SYSTEM AND THE CONVEYOR METHOD OF MOVING PARTS METHOD 204 

COULD NOT BE DESIGNED INTO THE PRODUCTION PROCESS UNLESS CONTROLLED AT 100% WITH GREATER AIR FLOWS 

3 ALL FUGITIVES ARE ESTIMATED AT 4% (FOR ALL PROCESSES) DUE TO THE EXTREMELY LOW AIR FLOWS AND/OR DIFFERENTIAL 

OF MAKE-UP TO EXHAUST AIR FLOW RATIOS 

4 THE RTO @ YELM IS ONLY USED AS NEEDED TO STAY BELOW CAP OF 249 TPY 

5 Acrylic resin usage for aame period • 2,278,638 lbs (South Boston) t 769,379 lbs (Yalm) 

I 

6 Magnum FIT equipment operational at each plant approx 

Anahei m 

Sout h Bosto n 

3 River s 

Lancaste r 

Cordel e 

Yelm 

Elizabethtown 

Moapa 

DATE 

Jul-00 

Oct-01 

Sep-01 

Sep-01 

Aug-0 2 

May-01 

Apr-0 1 

Jul-00 

Mixin g Typ e 

Internal 

Internal 

Intema l 

Intema l 

Internal 

Internal 

Intema l 

External 

00 
Plant 

Anaheim 

South Boston 

3 Rivers 

Lancaster 

Cordele 

Yelm 

Elizabethtown 

Moapa 

Total 

EMISSIONS PEF 

Gelcoat 

1.825,718 

1,042,255 

1.435,182 

1,424,177 

1,450.505 

1,095,018 

1.285.823 

1.367.468 

10.926,146 

% Styrene 

:-% 

36% 

36% 

36% 

36% 

36% 

36% 

36% 

UEF 

17.8% 

17.8% 

17.8% 

17.8% 

17.8% 

17.8% 

17.8% 

17.8% 

CENTOFTOTALEM.SSIONS 

Pounds of Resin Used (May 2000 - A 

Emissions 

324,978 

185.521 

255,462 

253.504 

258,190 

194.913 

228.876 

243.409 

1 944.854 

46.7% 

Laminate resin 

7.084.439 

3,627,354 

5,061.102 

5,167.004 

5.095,450 

4.546,338 

4.523,798 

5,423,235 

40.528.720 

% Styrene 

42 B% 

39 0% 

39.0% 

426% 

39 0% 

36.0% 

42.6% 

36 0% 

4.5% 

4 5% 

4 5% 

4 0% 

4 0% 

pril 2001) 

Emissions 

361,306 

161,417 

225.219 

263,517 

226,748 

181,854 

230,714 

216,929 

1,867,704 

.44.9% , 

437,069 

629,315 

652,960 

616.558 

541,448 

541.541 

653,078 

5.007,585 

''*•"•. , 

36% 

36% 

36% 

36% 

36% 

36% 

36% 

UEF 

• - 7.0% k 

- 7.0% 

65,493 

30,595 

44,052 

45.707 

43,159 

37,901 

37,908 

45.715 

Total Emissions I 

751,777 

377.533 

524,733 

562.728 

528.096 

414.668 

497,498 

506.054 

350 531 4.163.089 

[_ 

100% -

PLANTS WITH P 

South Boston 

Lancaster 

Yelm 

Elizabethtown 

Moapa 

ARTIAL CONTR 

1,042,255 

1.424,177 

1.095.018 

1,285,823 

1,367,468 

OLS gelcoat 

185,521 

253,504 

194 913 

228.875 

243 409 

ed produc a only 

61 7% 

617% 

61 7% 

61.7% 

92.2% 

96.972 

74,560 

87,552 

19.083 

3,627,354 

5,167,004 

4 546,338 

4.523.798 

5.423.235 

161,417 

263,517 

181,854 

230.714 

216,929 

46.1% 

46.1% 

23.0% 

46 1% 

92 2% 

87.036 

142.088 

139,954 

124,401 

17,007 

437,069 

652,960 

541,448 

541,541 

653.078 

M I'' • Hti'-V'-rl 

45,707 1 45,707 

37.901 37.901 

37,908 ^^I^ H 14.501 

45.715 ^^^^ | 

188,598 - 50,0% 

284,768 v 49.4% 

252,416 **. 39,1% 

226,453 • 54.5% 

39,675 * 92.2% 

Process 

Gelcoat 

Lam 1 

Lam 2 

Phase 

Spray 

Cure 

Spray 

Cure 

Spray 

Roll 

Cure 

Spray 

Roll 

Cure 

Perceni 

by Phase 

67% 

33% 

67% 

33% 

50% 

25% 

25% 

50% 

25% 

25% 

Anaheim 

South Boston 

3 Rivers 

Lancaster 

Cordele 

Yelm 

Elizabethtown 

Moapa 

Acrylic Resin lbs/year FY2001 

no acrylic manufacluring 

2,278,638 pounds 

no acrylic manufacluring 

no acrylic manufacturing 

no acrylic manufacturing 

769,379 pounds 

no acrylic manufacluring 

no acrylic manufacturing 

Estimated capture 

Gelcoat (Moapa) 

Gelcoat 

'''Barrier Coat «PI 

1st Laminate Resin (Moapa) 

2nd/3rd Laminate Resin (Moapa) 

1st Laminate Resin 

2ndr3rd Laminate Resin 

Spray 

96% 

96% 

96% 

96% 

96% 

96% 

96% 

96% 

Roll 

na 

na 

na 

na 

96% 

96% 

0% 

0% 

Cure 

96% 

96% 

96% 

96% 

0% 

0% 

Total Capture 

96.0% 

64.3% 

96 0% 

64.3% 

96 0% 

96 0% 

48.0% 

48 0% 

% Destruction 

96$ 

96% 

96% 

96% 

96% 

96% 

96% 

96% 

Total % Controlled 

92.2% 

5 ! 7-Tm 

-J2 2% 

92 2% 

46.1% 

46 1% 

1 METHOD 204 HAS NOT BEEN USED TO DETERMINE CAPTURE EFFICIENCY. 

2 DUE TO THE PUSH/PULL MAKE-UP AIR & EXHAUST SYSTEM AND THE CONVEYOR METHOD OF MOVING PARTS METHOD 204 

COULD NOT BE DESIGNED INTO THE PRODUCTION PROCESS UNLESS CONTROLLED AT 100% WITH GREATER AIR FLOWS 

3 ALL FUGITIVES ARE ESTIMATED AT 4% (FOR ALL PROCESSES) DUE TO THE EXTREMELY LOW AIR FLOWS AND/OR DIFFERENTIAL 

OF MAKE-UP TO EXHAUST AIR FLOW RATIOS 

4 THE RTO @ YELM IS ONLY USEO AS NEEDEO TO STAY BELOW CAP OF 249 TPY 

5 Acrylic resin usage for same period = 2,278,638 lbs (South Boston) & 769,379 lbs (Yelm) 

6 Magnum FIT equipment operational at each plant approx. 

Anaheim 

South Boston 

3 Rivers 

Lancaster 

Cordele 

Yelm 

Elizabethtown 

Moapa 

OATE 

Jul-00 

Oct-01 

Sep-01 

Sep-01 

Aug-02 

May-01 

Apr-01 

Jul-00 

Mixing Type 

Intemal 

Internal 

Intemal 

Internal 

Intemal 

Intemal 

Internal 

External 
P.70 

ATTACHMENT M 

New Facility Survey Table 

Prepared by Alaglass Pools 

(a°\ 
2*7 

-J 

o 

Facility Name and Location: fJ»V*g-c\ \ g.s*a> p«>*>u 

Hours of Operation: 

Year for Which Data Is Being Reported: 2-0£* I 

•5" fcfr* jid&k.V- NEW FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

Material 

pigmented gel coat 

vinyl ester resin 

iASt G*C - CApfC 

Quantity 

Used (tpy) 

500 

1000 

32MHO 

q €. (cnS 

(^Z. to<& 

Average HAP 

Content 

(wt. %) 

46 

32-37 

MM-****/• 

3s-y0 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

UfeCtt/ AMU - ^ 

• 

Mjvie_ 

finrvte. 

Color 

(gel coat 

only) 

offwhite 

NA 

totfrnt 

t^A 

M/A 
P.72 

ATTACHMENT N 

New Facility Survey Table For Fabwell 

Sent By R. Berger to Ken Meardon 

4/8/02 

1\ 
P.73 

B f FABRICATING 

mm. SOLUTIONS 

18710 Maple aty Drive Phone- (574) 534-3447 

Goshen. In 46826 Fax- (574) 5344246 

Fax 

Phone: .'jjfjrTH' ^2arf=aW^ife- Date: 

Fax; 9/ 9 - 9V/ - ^ -a gV Pages; With Cover _ ^ 

7"*-
Facility Name aiid Locatioa: /-&& W^~. /y^RHx^L/jr^ryx/Q^ ^^/^i-r-^^ < 

Hours of Operation: 

Year for Which Data Is Being Reported: Z^>& / 

o 

Os 

NEW FACILITY SURVEY TABLE 

ai 

Q. 

•_z 

a 

u 

Ul 

3 ffl 

•I 

u. 

(M 

O 

O 

CM 

OD 

Q 

I 

Q: 

Q. 

cc 

Process Grouping 

Bxampfw 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, tilled 

Qpemfm M»!*i.j ^ 

Ma ferial 

pigmented gel coal 

vinyl ester resin 

?*ln<mmSTe_r ~ 

f

P

74yn-e_KrteJl 

Quantity 

Used ((py) 

SOO 

1000 

ZHT/.7I 

8Sf.S7 

H% tf 

Average HAP 

Content 

(wt. %) 

46 

32-37 

2/7*1 

ZC* 

3U.11 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

^GCWWmTizAL 

/lT-OA\jrz^> 

A\£C_MANJT£/I£_ 

Other Emission 

Reduction 

Technique 

none 

inc in erator (90% overall 

capture and control) 

Color 

(get coat 

only) ' 

ofhvhits 

NA 

A/4 

Q&Wffc&m. 

4&2*mz 

CO 

*. 

o 

IS3 

tmm. 

•z 

o 

o 

o 

cn 
P.75 

ATTACHMENT 0 

New Facility Survey Table for Kohler Spartanburg 

Sent By Mike Cassidy to Ken Meardon 

4/10/02 

7<f 
P.76 

April 10,2002 

Mr. Kenneth R. Meardon 

PACIFIC ENVIRONMENTAL SERVICES, INC 

Research Triangle Park, NC 27709 

Dear Ken: 

Subject: RPC MACT QUESTIONNAIRE For Kohler Co.'s - Spartanburg. SC Facilitv 

Attached is a table providing the information requested in your March 27, 2002 fax to me 

for Kohler Co.'s Spartanburg, SC RPC fixture fabrication facility. This facility operates an FRP 

fixture plant and an acrylic fixture plant. I have listed the operating hours for each plant 

separately. 

The gelcoat resins and tooling resins listed are attributable to the FRP plant only. The 

bonding resin listed is attributable to the acrylic plant only. The general-purpose chop coat resin 

listed represents the total used in booth plants. 

If you have any questions about this information, I may be contacted at 920-457-4441, 

extension 77263, or via e-mail at mike.cassidy(a),kohler.com. 

Sincerely, 

Mike Cassidy 

Kohler Co. 

Enclosure 

15 
Facility Name and Location: Kohler Co. - Spartanburg. SC Year for Which Data Is Being Reported: 2001 

Hours of Operation: FRP Fixture Plant: 8.040 hrs 

Acrvlic Fixture Plant: 2.128 hrs 

FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

Open Molding: 

mechanical 

Open molding: filled, 

Non-corrosion, mechanical 

Open molding: filled, 

non-corrosion, mechanical 

Tooling resin: 

mechanical 

Material 

pigmented gel coat 

vinyl ester resin 

Pigmented gel coat 

General purpose 

chop coat resin 

Acrylic fixture 

bonding resin 

Orange tooling resin 

Quantity 

Used (tpy) 

500 

1000 

600 

2950 

145 

0.2 

Average HAP 

Content 

(wt. %) 

46 

32-37 

35.4-39.5 

36-40 

45-48 

47 

Application 

Technique 

spray 

mechanical, nonatomized (100%) 

Spray (100%) 

Mechanical, nonatomized (impingement 

guns) (100%) 

Mechanical, nonatomized (impingement 

guns) (100%) 

Spray (100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

none 

none 

none 

none 

Color 

(gel coat 

only) 

Ofrwhite 

NA 

All colors, 

including 

white 

NA 

NA 

Orange 
\ l 

Process Grouping 

Tooling resin: manual 

Material 

Iso-tooling resin 

Quantity 

Used (tpy) 

1.5 

Average HAP 

Content 

(wt. %) 

47 

Application 

Technique 

Hand layup (100%) 

Other Emission 

Reduction 

Technique 

none 

Color 

(gel coat 

only) 

NA 
P.79 

ATTACHMENT P 

Survey of Hours of Operation 

Prepared by Ken Odette (CFA) 

1/18/02 

7?r 
P.80 

RFP Facilities for which Hours of Operation Are Needed 1/18/02 

Facility Name |C*ly |Slata |Contact Nam* (if availaole) Number 

Aqua Bath Co , Inc 

Attbar Plastics, Ina 

Bathcraft, Inc. 

Bremen Glas, Inc. 

Cor Tec Co. 

Custom Fibreglass Manufactunng Co 

Dixie-Pacific Manufacturing Co 

ED Industries, Inc. (Sportsman Pickup Covers) 

Eljer Plumbingware 

Emsig Manufacturing Corp 

i bercast Co 

Fiberglass Systems, Inc 

Fiber-Tech Industries, Inc, 

Fleetwood (formerly Gold Shield) 

G. W. Fiberglass, Inc. 

Nashville TN George McAllister-relired Mike Moran 

Vancouver WA Joe Volz 

Valdosia 

Bremen 

Washington Court House 

Long Beach 

Gadsden 

Rogersvllle 

Wilson 

New York 

Sand Springs 

Boisa 

Pendleton 

Fontana 

O'falkxi 

Glasgo Plastics, Inc Springfield 

Holiday Rambler Corp., Planl 36 and 37 I Wakarusa 

Jason Industries, Inc. 

Leer Midwest 

McCtarfn Plastics inc 

Miracle Recreation Co 

National Fiber Glass Products Inc 

S.WC Industries, Inc (Swirl-Way Div.) 

Shakespeare Co. 

Sherman Poles 

Specialty Plastics Associates. Ino 

Synlechnics (Trinity Marine) 

United Technologies Motor Systems 

Universal-Rundle Corp. 

Universal-Rundle Corp 

Universal-Rundle Corp. 

FACILITIES TO ADD TO DATABASE 

Prodesign 

MAAXUSA 

Pearl Manufacturing (MAAX) 

Kohler 

Elkhart 

Elkhart 

Hanover 

Monett 

Romeoville 

Henderson 

Newberry 

Estill 

Lakeland 

Paducah 

Columbus 

New Castle 

Ottumwa 

Union Point 

GA Uim Kutzli 

IN 

OH 

CA 

AL 

Mark Smith, Joe Prior 

Robert Edwards 

Glenn Tipton 

MO |Mlke Downie (Consultant-Brittney Inc.) 

NC | Phil Livermore 

NY ! Timothy Haskins - no longer thera 

OK Michael Thayer 

ID 

SC 

CA 

MO 

OH 

IN 

IN 

IN 

PA 

MO 

IL 

TX 

SC 

SC 

FL 

KY 

MS 

PA 

IA 

GA 

j 

Valdosta GA 

Spartanburg SC 

Larry Bearg, Gary Multanen 

Mark Howard 

William Tillman 

Kurt Anderson 

John Blme 

Kevin Parks (Consultant) 

Karl Katz 

Terry Branson 

Kelly Salach 

Dan Winfrey 

John Price 

J.W. Dubois 

C. Dennis Peek (Consultant) 

Melissa Wright no longer there(Plant); Tom 

Show (Corporate) 

D Pierce Epes 

Robert Walczak - no longer there 

Joe Perdue (Env, Coord). Bill Polzin (Plant 

Mgr) 

Donald Ellis 

ttMG>-3580 

912-333-080!, 

514-335-9400. 614-

3KM32-A454 

256-442-4513 

417-833-5050 (plant 

#417-753-6688) 

252-247-2384 

518-8267301 

918-245^651 

208 342-6823 

909-351-3905 

513 326-3602 

219-862-7347 

219-294-7595 

219-258 077," 

717-937-2241 

417-235-6917 x252 

708-257-3300 

903-657 -1436 

803-276-5504 

5-3131 

813-968-7722 

270-898-7303/901-

853-2450 

601-245-4367 

724-658-6686 

641-682-8515 

706-486-4133 

Hiram Rivf-m 229-247-2364 x227 

Plant Operating Hours 

7 hour shift/5 days per weak 

(*>am-4pm/5 days [Hir week 

no contact information 

bad phona numbers 

dtaconneetad 

left message 

disconnected 

medical office phone numb* 

planl ceased oi i 

1 shrft/5-6 days per weak 

7am-4pm/4-5 <1*iy*. pai wo.;k 

WTOng numbei 

.nm/5daya per week 

left message 

1 shitt/5 daya pel *• * 

disconnected 

Branson no longer there, left msg 

bad phona numb* 

Now Mansfield Plumbing, left message 

left message 

bad phone number 

6am-430pm/4 days per week 

bad phone numbor 

1 shift/5 days per week 

6am-2 30pm/5 days per week 

7am-4 30pm/5 days per week 

1°\