P.1 

OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

42) ll-C-68 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:28 PM Sheet 42 of 343 
P.2 

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Wj PAaTCE4WIRO»0JJ=NTAL SERVICES. INC. 

3 I 

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Central Park West 

5001 South Miami Boulevard, Suite 300 

P.O. Box 12077 

Research Triangle Park, NC 27709-2077 

(919)941-0333 

FAX (919) 941-0234 

FAX COMMUNICATION 

A-94-52 

Date: 07/31/ 47 

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Name: 

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REFERENCE CODE: Moi. Ooo 

THIS COMMUNICATION COMPRISES / * PAGES INCLUDING THIS PAGE. 

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rtsfsss ij you r^y^^ ^ f%s etf*/*, ft,-* f*?j> /regWASHINGTON. O.C. • RESEARCH TRIANQLE PARK. NC • LOS ANQELES. CA • CINCINNATI. OH 

- I 
P.3 

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uszzj UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

§ VXiT v 2 RESEARCH TRIANGLE PARK. NC 27711 

S 

OFFICE OF 

AIR QUAUTY PLANNING 

ANO STANDARDS 

DESIGNATION OF AUTHORIZED REPRESENTATIVE 

POR STANDARDS OP PERFORMANCE FOR NEW STATIONARY SOURCES 

(SECTION 111) AND SOLID WASTE COMBUSTION (SECTION 129) , 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS 

(SECTION 112), AND FEDERAL OZONE MEASURES (SECTION 183) 

Under contract 68D60013, Pacific Environmental Services 

(PES) (prime contractor) and Alpha-Gamma Technologies, 

Incorporated (proposed subcontractor) are hereby designated an 

Authorized Representatives of the Administrator of the United 

States Environmental Protection Agency for the purpose of 

assisting in the development of national emission standards for 

hazardous air pollutants under 42 U.S.C.\7412, standards of 

performance under 42 U.S.C. 7411, and Federal ozone measures 

under 42 U.S.C. 7511 (b) . 

This designation is made pursuant to the Clean Air Act, 

42 U.S.C. 7414. The United States Code provides that, upon 

presentation of this credential, the Authorized Representatives 

named herein: (1) shall have a right of entry to, upon, or 

through any premises in which an emission source is located or in 

which records required to be maintained tinder 42 U.S.C. 7414 (a) 

(1), are located, and (2) may at reasonable times have access to 

and copy any records, inspect any monitoring equipment or method 

required under 42 U.S.C. 7414 (a) (1), and sample any emissions 

that the owner or operator of such source is required to sample. 

Authorized Representatives of the Administrator are 

subject to the provisions of 42 U.S.C. 7414 (c) respecting 

confidentiality of methods or processes entitled to protection as 

trade secrets, as implemented by 40 CFR 2.301 (h) (41 FR 36912, 

September 1, 1976). 

Date: 

Designation Expires: September 30, 1997 

Director 

Office of Air Quality Planning 

and Standards 

- z.-
P.4 " 1 

Enclosure 1 }Jfi/)£>\f C'i~?K/ 

Form Approved 

OMB No. 2060-0239 

Approval Expires: 03/31/95 

Public reporting burden for this collection of information is 

estimated to average 8.5 hours per response, including the time for 

reviewing instructions, searching existing data sources, gathering 

and maintaining the data needed, and completing and reviewing the 

collection of information. Send comments regarding this burden 

estimate or any other aspect of this collection of information, 

including suggestions for reducing the burden, to Chief, 

Information Policy Branch. PM-223Y, U. s. Environmental Protection 

Agency, 401 M Street, S.W., Washington, D.C. 20460, and to Office 

of Information and Regulatory Affairs, Office of Management and 

Budget, Washington, D.C. 20503. Include the OMB number in any 

correspondence. 

SCREENING INFORMATION REQUEST 

I. Instructions 

This information request is to be completed for facilities 

that manufacture reinforced plastic composites. The source 

category is defined as the manufacture of products using 

reinforced and/or filled plastic resin,, including "prepreg" 

or molded products. Fill out this information request as 

completely as possible from existing information sources. 

No additional monitoring or emissions testing is required 

by your company to respond to this request. 

Attachment l presents the list of hazardous air pollutants 

(HAP's) listed in Section 112 of the Clean Air Act. We are 

interested in obtaining information regarding each compound 

identified as a HAP that is used in or emitted by any 

operations, including fugitive emission sources, occurring 

from the manufacture of reinforced plastic composites. 

If you have any questions regarding this request, contact 

Ms. Madeleine Strum of the EPA at (919) 541-2383 or Mr. 

Greg LaFlam of PES at (919) 941-0333. 

Return this information request and any additional 

information to: 

Emission Standards Division (MD-13) 

U. S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Attention: Bruce C. Jordan, Director 

II. General Information 

A. Name Of lega l owner Of plant : Molded Fiber Glass Companies 

SU. - 3 
P.5 

B. Name of lega l operator of plant, i f different from 

legal owner: 

Molded Fiber Glass Company/Union City • 

C. Address of lega l owner/operator (please specify which): 

1601 W. 29th Stree t 

Ashtabula, Ohio 44004 

D. Size of company: 

1. Approximate number of employees of the business 

enterprise that owns this plant, including where 

applicable the parent company and all subsidiaries, 

branches, and unrelated establishments owned by the 

parent company (answer may be given using the 

following ranges: 0-100; 101-250; 251-500; 

501-750; 751-1,000; 1,001-1,500; and >1,500): 

751 - 1000 

2. Number of plant employees attached t o the 

reinforced plasti c composites operation: 

751 - 1000 ' 

E. Name of plant: 

Molded Fiber Glass/Union City Operations 

F. Address of plant: 

55 Fourth Ave. 

Union City, Pennsylvania 16438 ___ 

G. Name of contact(s) able to answer technical questions 

about the completed survey: 

•fo 

Grace Duffy 

H* Titl e (s): 

Administrator of Safety & Environmental Programs 

I. Telephone number; 

(814) 438-3841 

*$> - H 
P.6 

Spray/Layup 

III. Hazardous Air Pollutants 

Using the list of HAP's provided in Attachment 1, complete 

Table l. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Techniques 

For each HAP emission source (including storage, fugitive 

dust, transfer operations, process fugitives, stacks, and 

waste management), complete Table 2. Provide a brief 

description of any emission reduction measures in place and 

an estimate of the relative quantity of HAP emissions from 

each emission source. 

V. Miscellaneous 

Describe any factors not addressed in the above questions 

that might serve to distinguish your facility from others 

in this source category for purposes of developing a 

separate source category or subcategory and MACT standards. 

NUMBER OF GELCOAT BOOTHS 

^=—c — 

IfuTIBER'Q?SPRAY UP BOOTHS 

( ^ 

- 3 

--

; 5/8 

RESIN MAKEUP - VARIES DEPENDING ON 

STYRENE CONTENT -. VAIRES 

CLEAN UP MATERIALS - FRP 

DEPENDING 

TOOL AND ( 

CUSTOMER SPECIFICATIONS 

ON 

SUN 

TYPE OF 

CLEANER 

JOB. 

- SOLVENT FREE 

b3104-2/650031 

^ 3W -b~ 
P.7 

SPRAY/LAYUP 

TABLE 1 . HAZARDOUS AIR POLLUTANTS 

ooL 

Dot 

i?J 

Feedstocks 

WAX SOLUTION (970C940) 

GELCOAT 

RESIN 

OVi 

96 LB/YF 

102 TN/YR 

520 TN/YR 

CATALYST 

HAP constituents 

Products—final and intermediate 

COSTOM FIBERGLASS REINFORCED PRODUCTS FOR THE 

CONSTRUCTION INDUSTRY, PRODUCTS FOR WATER AND 

SEWAGE TREATMENT FACILITIES, ARCHITECTURAL FASCIA, 

AND TRUCK AND AUTOMOTIVE PARTS 

* THIS IS A JOB SHOP AND PRODUCTION VARIES DEPENDING 

ON ORDERS 

Byproducts (of process or control systems) 

FUGITIVE DUST 

(GRINDING, SANDING, DRILLING) 

UNREACTED SCRAP RESIN 

RESIN OVERSPRAY 

CLEANUP MATERIAL 

TONS/YEAR VARIES 

TONS/YEAR VARIES 

TONS/YEAR VARIES 

110 GALLONS 

L 

STYRENE (98% BY 

WEIGHT) 

STYRENE (30-49% BY 

WEIGHT) 

AVG-34% 

STYRENE (10-80% BY 

WEIGHT) 

MEK (3% BY 1\ 

WEIGHT) 

'1V3 

UNREACTED STYRENE 

STYRENE 

STYRENE 

STYRENE 

METHYLENE 

CHLORIDE 

itxrrt 

-tt-o* -i 

\ 5 Lr 
P.8 

SPRAY/LAYUP 

TABLE 2 . HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

mo 

Emission Source 

Emission Reduction Techniques 

Type In 

Place 

(Date) 

Future 

(Planned 

Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

Storage: 

Resin Tanks (5) 

(1 empty) 

\3 3740 gal. 

(2) 4880 gal. 

5700 gal. 

509Q gal. 

Don't Know 

\ I 

Less than 0.1 

3C 

Fugitive Dust; 

Finishing 

Grinding 

Sanding 

Vacuum Filters April 1989 Less than 0.1 

tb 

ni 

Transfer 

Operations; 

Pouring Resin 

iV> 

Connecting Pump LineqAll resins trans 

ferred thru closdd 

lines to spray guns 

Covers are used 

on Transfer & 

Receiving Vessels 

^ 

b* 

Less than 0.1 

")(, 

Process 

Fugitives; 

Curing None 0.7 TPY 

^ 3 C •1 
P.9 

mo TABLE 2 (Continued) 

\j 

Emission Source 

Emission Reduction Techniques 

Type In 

Place 

(Date) 

Future 

(Planned 

Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

Stacks: 

35% Styrene Air 

Assist Airless 

Guns 

13 TPY 

3 

Waste 

Management: 

CLEAN UP 

FRP Tool & Gun Cleanjer 

Some Methylene Chlor Lde 

Scrap Resin 

Solvent Free None 

0.6 TPY 

Varies 

W 

Other, specify; 

Mixing 1 to 10 TPY 

^-> 

(a) If no figures are available, give estimate as one of the 

following ranges: 

less than 0.1 

0.1 to 1 

1 to 10 

10 to 25 

25 to 100 

greater than 100 

tons 

tons 

tons 

tons 

tons 

tons 

T\ -v 
P.10 

COMPRESSION MOLDING 

Of 

III. Hazardous Air Pollutants ' 

Using the list of HAP's provided in Attachment 1, complete 

Table 1. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Techniques 

For each HAP emission source (including storage, fugitive 

dust, transfer operations, process fugitives, stacks, and 

waste management), complete Table 2. Provide a brief 

description of any emission reduction measures in place and 

an estimate of the relative quantity of HAP emissions from 

each emission source. 

V. Miscellaneous 

Describe any factors not addressed in the above questions 

that might serve to distinguish your facility from others 

in this source category for purposes of developing a 

separate source category or subcategory and MACT standards. 

CLEANUP MATERIAL GPC-97 USED FOR LESS THAN 6 MONTHS AND NO LONGER 

USED. 

THIS IS A FAIRLY NEW OPERATION AND IS STILL BEING DEVELOPED. 

b3104-2/65003 1 

^ 5 -<\-
P.11 

TABLE 1 . HAZARDOUS AIR POLLUTANTS 

COMPRESSION 

MOLDING 

00| 

VdZ 

lf[ HAP constituents 

Feedstocks 

RESIN (E6006-5, 2036, Q6585) 

STYRENE MONOMER 

CATALYST26 TONS 

13 TONS 

VARIES 

Products—final and intermediate 

CUSTOM FIBERGLASS REINFORCED PRODUCTS FOR THE TRUCK 

AND AUTOMOTIVE INDUSTRY ' 

*THIS IS A JOB SHOP AND PRODUCTION VARIES DEPENDING 

ON ORDERS 

ose 

Byproducts (of process or control systems) 

FUGITIVE DUST " 

(GRINDING,"SANDING, DRILLING) 

UNREACTED SCRAP RESIN 

CLEANUP MATERIAL (GPC 97) 

(OO- ^T-^T 

STYRENE (28-34% 

BY WEIGHT) 

STYRENE (99% BY 

WEIGHT) 

MEK (3% BY WEIGHT) 

-7f-tV3 

UNREACTED STYRENE 

STYRENE 

STYRENE 

tOfc-fo" 

TOlUENE«55% BY 

.,". ,** WEIGHT) 

. ••-.•

iJ>v.. -' • • 

-J$$££g£{>4'5% BY 

i-^ 7.-.--.*" HEIGHT) 

* • >»-iff. • 

-^s -10" 

ix.i-r-
P.12 

TABLE 2 . HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

Ot Emission Source 

Emission Reduction Techniques 

Type In 

Plac e 

(Date) 

Future 

(Planned 

Date) 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

l^ 

Storage: 

55 GAL. DRUM DRUMS KEPT 

COVERED UNLESS 

IN USE 

.1 

ll> 

Fugitive Dust: 

FINISHING 

GRINDING 

SANDING 

VACUUM FILTERS APRIL 1989 

3 

^ > ' . < 

Transfer 

Operations: 

POURING RESIN 

cyy 

COVERS ARE 

USED ON 

TRANSFER AND 

RECEIVING 

VESSELS 

.1 

7-7 

Process 

Fugitives; 

MOLDS NONE .45 TPY 

* PAGE 6 - SAME AS SPRAY/LAYUP 

^ Ho ~\\ -
P.13 

RTM 

III. Hazardous Air Pollutants 

Using the list of HAP's provided in Attachment 1, complete 

Table 1. List all known or suspected HAP's that are used 

in feedstocks, produced as intermediate or final products, 

or created as by-products of the process or control system 

within the defined source category operations. 

IV. Emissions and Source Reduction Techniques 

For each HAP emission source (including storage, fugitive 

dust, transfer operations, process fugitives, stacks, and 

waste management), complete Table 2. Provide a brief 

description of any emission reduction measures in place and 

an estimate of the relative quantity of HAP emissions from 

each emission source. 

V. Miscellaneous 

Describe any factors not addressed in the above questions 

that might serve to distinguish your facility from others 

in this source category for purposes of developing a 

separate source category or subcategory and MACT standards. 

THIS IS A FAIRLY NEW OPERATION AND IS STILL BEING DEVELOPED. 

b3104-2/650031 

> k m .-,-£> 
P.14 

M sO RTM 

TABLE 1 . HAZARDOUS AIR POLLUTANTS 

£m /? HA? constituents 

Qol 

Feedstocks 

RESIN (8438 10RT) 

PIGMENT (BLACK/GRAY) 

CATALYST DDM-9 

3 TONS STYRENE (41% BY 

WEIGHT) 

NONE 

MEK 

Products—final and intermediate 

CUSTOM FIBERGLASS REINFORCED PRODUCTS FOR THE 

TRUCK AND AUTOMOTIVE INDUSTRY 

*THIS IS A JOB SHOP AND PRODUCTION VARIES DEPENDING 

. ON ORDERS 

0% 

Byproducts (of process or control systems) 

FUGITIVE DUST 

'(GRINDING, SANDING, DRILLING) 

•UNREACTED SCRAP RESIN 

CLEANUP ."MATERIAL 

VARIES 

VARIES 

(3% BY 

WEIGHT) 

7 ff'M V 3 

UNREACTED STYRENE 

STYRENE 

STYRENE 

NONE . 

.-•V:->?.-r:^r-.-.-* ; 

• "Si**-'-*""*.' 

^ -13' 
"•••..'•: • 

5 

U\i . 

\ NOTABLE 2 . HAP EMISSIONS AND SOURCE REDUCTION 

A 

Tl 

Emission Source 

Storage: 

55 GAL. DRUM 

Fugitive Dust: 

FINISHING 

GRINDING 

SANDING 

Transfer 

Operations: 

POURING MIX 

Process 

Fuqi,tiYe s: 

RTM 

Emission Reduction Techniques 

Type 

COVERS KEPT ON 

UNLESS IN USE 

VACUUM FILTERS 

^1 

COVERS ARE 

USED ON TRANSFER AND RECEIVING VESSELS 

I n 

Plac e 

(Date) 

APRIL 1989 

Future 

(Planned 

Date) 

-

-

PAGE 6 - SAME AS SPRAYING/LAYUP 

MEASURES 

Tota l HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

.1 

.1 

.1 

STYRENE .07 TPY 

-IH ' 

P.15 

•