OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

20) ll-C-46 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:27 PM Sheet 20 of 343 

p.1 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 2771 1 

OFPICH OF 

Aia QUALlTf SCANNING 

AND STANDARDS 

A-94-52-

995 

tMs. Hilary North 

LASCO Panel Products 

8 015 Dixon Drive 

Florence, Kentucky 41042 

Dear Ms. North: 

Thank ycu for taking the time to explain and tour the 

continuous lamination process at LASCO Panel Products with us and 

your help in planning the test. This letter is to requesadditionai information to update the data base and to help with 

the test plan. These items were discussed during our visit. 

Enclosure 1 is a copy of the 1993 survey completed by LASCO 

Panel Products. Please provide updated information cn ycur 

facility after the addition of the wide panel line. In 

particular, we need the updated information for Table 1, "Feed 

Stocks". Please be sure to include methyl methacrylate as both a 

"thinner" and (if it is used) as an ingredient in any of the 

resins or gelcoats. Also, please verify that LASCO Panel 

Produces uses only one gelcoac and does not add any additional 

styrene or methyl methacrylate to it. In addition, it would be 

helpful if you would send the section of the material safety data 

sheet containing information on the ingredients of the gelcoat. 

In order to evaluate the product lines for which emissions 

testing might: be conducted, we need information concerning the 

tvoe of orcducts LASCO Panel Products produced in the 1995 

calendar year Enclosure shows the cype of information needed 

to evaluate che various emission test scenarios. If the table is 

not large enough to provide information about all of the produces 

LASCO produced in 1995, please make additional copies or changes 
P.3 

As you can see from the information requested in 

Enclosure 2, we need product recipes in order to help evaluate 

the hazardous air pollutant emission potential of the various 

products. If confidential business information (CBI) is 

involved, please indicate this and we will treat it according to 

CBI procedures outlined in the site visit confirmation letter 

dated August 30, 1996. This information is needed in a very 

shore time frame so we request your response to us by October 2, 

1996. Let me know if this poses a significant problem for you. 

Thank you again for your cooperation. Feel free to contact 

either myself at (919) 541-2383 or Melanie Proctor at Pacific 

Environmental Services, (919) 941-0333 if you have any questions 

regarding this request. 

Sincerely, 

Madeleine Strum 

Environmental Engineer 

Coatings and Consumer Products Group 

Two Enclosures 

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P.4 

(HKeA frbflUCl? For m Approved ' 

3k£ 

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 1 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 : Tomkins Ind. Inc. Lasco Panels 

3 
P.5 

B. Name of lega l operato r of plant, if differen t from 

legal owner: 

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

8015 Dixon Drive 

Florence , KY 41042 

D. Size of company: 

1. Approximate number of employees of th e business 

enterpris e tha t owns this plant , including where 

applicabl e th e parent company and al l 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): 

•>TH10 m. 

2. Number of plan t employees attache d t o the 

reinforced plasti c composites operation : 

JM '. : 

E. Name of plant : 

T.asrn Panel PfnHnpt s 

F. Address of plant : 

aniS T,-fvr,n HH W 

VlnrpnrP. TTT 4104? 

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

about the completed survey: 

Hra-tg Johnson 

0 

H. Title(s): 

Prnjert Enpyinger 

£^r., , f/ltffr\r+r*jfr 

I. Telephone number: 

<>ni-772-^1 «o fiOfi-^71-7770 

* • 
P.6 

III. Hazardous Air Pollutants 

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

Table 1. List al l known or suspected HAP's tha t 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 relativ e quantity of HAP emissions from 

each emission source. 

V. Miscellaneous 

Describe any factors not addressed in the above questions 

tha t might serve to distinguish your facilit y from others 

in this source category for purposes of developing a 

separate source category or subcategory and MACT standards. 

Most emissions ar e fugitive . The make-up air system and exhaust 

fans are at 6' leve l - Hooded vacuum systems exhaust a t 25' leve l 

on roof. Nearest residence to plant is in excess of one mile. 

A continuous lamination production operation is exteremly hard to 

categorize for emissions. The mass balance test ; heavily engineered, 

monitored and verified , is believed to be the most accurate measure-

-ment of MONOMER lose s for this type of "Reinforced Plastic s Composites" 

production.' 

b3104-2/65003 1 

*ij 
Too 

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TABLE 1. HAZARDOUS AIR POLLUTANTS 

0^ 

007, 

001 

0 ^ 0 

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a24 

Process: Continuous Lamination 

Feedstock s 

Styrene (used as thinner) 268 ton/y r 

Unsaturated Polyeste r Resin 9000 ton/y r 

Catalyst (Cumene Hydroperoxide) 92 ton/y r 

(Perkadox, Trigonox , Variquant) 30 ton/y r 

Pigment 500 ton/y r 

Fille r (Calcium Carbonate)Ot o 2050 ton/y r 

(Aluminum Trihydrate)^ 1/ ^ 330 ton/y r 

Fiberglass (Strand Roving) 2700 ton/y r 

Q Q<\ (Woven Roving) 300 ton/y r 

Products—final and intermediate 

Fiberglass Panels 15,000 ton/y r 

Byproducts (of process or control systems) 

Unused Resin (Catalyzed) 

Fugutiv e .Dust (Catalyzed) 

20 ton/y r 

unknown 

HAP constituent s 

Styrene 

Styrene (41% by weigljjt) 

Cumene (10% by weight) 

None 

None 

None 

None 

None 

None 

None 

None 

None 

X, 
TABLE 2. HAP EMISSIONS AND SOURCE REDUCTION MEASURES 

P.8 

6 

tt 

Z\& 

nio 

Emission Source 

Storage: 

Underground 

Storage Tanks (7) 

96,000 Gallons 

Fugitiv e Dust : 

Pane l Sawing 

(Production) 

Pane l Sawing 

(Cut Down) 

Bulk Mixing 

Transfer 

Operations: 

Pumping from * 

mixing pot to tabl^e 

Pumping from 

Bulk Mixer to 

mixing pot 

Pumping from tank 

t o mixing pot 

Proces s 

Fugitives : 

Curing on tabl e 

Emissio n Reductio n Technique s 

Type 

Conservatio n 

Vents 

Vacuum h°0-

Bag House 

Vacumn ' 

Bag House 

Vacumn fi 

Bae House 

"aake up ai r ) 

Sy s tems_^,— 

Vented to 

Atmosphere ^ 

Make up ai r 

Systems 

Vented t o 

Atmoshphere 

Puddl e 

Ventilatio n 

Hood Vented t o 

ALiuuyptrers-" — 

In 

Place 

(Date) 

New 

11/92 

1969 

1975 

1975 

1975 

1992 

1969 

1975 

1975 

1992 

1992 

1969 

1975 

1979 

Future 

(Planned 

Date) 

1994 

Total HAP 

Emission 

Estimate, 

Tons/Year 

(a) 

Less than 0. 1 

Less than 0. 1 

Less than 0.1 

None 

* 

* 

* 

63 * 

* 

* See Page 7 

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IV) 

.re? 

-7?/ ' 

TABLE 2 (Continued ) 

Emission Source 

Stacks: 

Curing ovens 

Make up air system 

Waste 

Management: 

Use aqueous 

cleaners 

Other , specify : 

Non-usable resin 

2,00 

Emissio n Reduction Technique s 

Type 

5^ 

Fully enclosed 

and vented to 

atmosphere 

Vented to 

atmosphere 

m 

w\ 

Make up air 

system 

Vented to 

atmosphere 

lib catalysed 

and disposed of 

1 ^.'f-e 

I n 

Plac e 

(Date) 

1969 

1975 

1969 

1975 

1992 

1969 

Futur e 

(Planned 

Date ) 

1994 

1994 

(a) If no figure s ar e available , giv e estimat e as 

followin g ranges: 

less tha n 0. 1 ton s 

0 . 1 t o 1 ton s 

1 t o 10 ton s 

10 t o 25 ton s 

25 t o 100 ton s 

greate r tha n 100 ton s 

* See page 7 

• \ m, 

Tota l HAP 

Emission 

Estimate , 

Tons/Year 

(a) 

* 

* 

None 

0.1 to 1 

one of th e 
P.10 

In March 1993, a mass balance protocol for emissions from a continuous lamination 

process was submitted to and approved by the state of Kentucky, Dept of Environmental 

Protection. 

Tests were performed on March 23, 1993 with results verified by KDEP. 

Average emissions was 1.59% of Styrene Monomer throughout. This includes all emissions 

related to production, start to finished product. 

Therefore total process; HAP emissions are shown under Process Fugitives in table 2 (page 5) 

Methyl Methacrylate and Cumene Hydroperoxide do not leave a continous lamination processremain in product 100%. 

./" *~ 

X 

CALENDAR 1992 EMISSIONS CALCULATIONS (FOR 2 EXISTING LINEfll ,3 

PRODUCT 

GP RESIN 

NPG RESIN 

FLEX RESIN 

FIREBLOCK RESIN 

ACRYLIC MOD RESIN 

DION RESIN 

THROUGHPUT 

7,569,495 

5,277,102 

4,251,045 

194,699 

92,197 

675.524 

MONOMER 

41.4 

41.0 

38.1 

38.8 

41.6 

45.5 

Sub Total 

VIRGIN STYRENE MONOMER 535,924 

Total 

CALENDAR 1992 EMISSIONS: # MONOMER X 1.59% / 2,000 = 

7,874,215 2C .0159 / 2,000 = 62.6 TONS PER YEAR 

MONOMER 

3,133,771 

2,163,612 

1,619,648 

75,543 

38,354 

307.363 

7,338,291 # 

535.924 

7,874,215 # 

EMISSIONS TPY 

CALENDAR 1992 EMISSIONS = 62.6 TONS 

41t 
ENCLOSURE 2 

Table of Product Information LASCO Panel Products for 1995 

O 

Product Description T044S of 

product 

produced 

Product 

Thickness 

wilhoul 

(jcl Coat 

(mils) 

Line 

Speed 

(li/min) 

Amount of 

gelcoat 

applied 

(gallons or 

pounds per 

batch -

please 

specify) 

Amount 

Resin 

applied 

(|HXIIKIS per 

butch) 

weighted 

average 

styrene 

content of 

rosin as 

supplied 

(%by 

weight) 

weighted 

average 

M M A 

content of 

resin as 

sttpplied 

(%by 

weiglit) 

Amount 

of styrene 

added as 

thinner 

(potutds 

per batch) 

Amount 

of MMA 

added as 

thinner 

(pounds 

per batch) 

Amount 

of filler 

(pounds 

per batch) 

Total 

Amount 

of glass 

chopped 

plus 

woven 

(pounds 

per batch) 

Amount 

of 

pigment 

(pounls 

per batch)