p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

19tf)ll-E-155 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:10 AM Sheet 196 of 264 
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A B 4 i d d Pl «t1c s R&D 2486192404 

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From: 

Date: 

Conuct: 

Company: 

Contact Report 

Robert Jemison, Pacific Environmental Services,|lnc. (PES) 

June 1 & 24,1998 

Mr. Vinod C. Shah 

The Budd Company - Plastics Division 

Telephone Number: (248)619-2294 

Fax Number: (248) 619-2404 

Contact Summary: 

Mr. Vinod C. Shah was contacted on May 14,1998 via telephone on behalf of the U.S. EPA 

to obtain infonnation pertaining to the use of nitrogen blanketing at facilities owned and operated 

by The Budd Company • Plastics Division. During the telephone conversation, Mr. Shah requested 

that Mr. Jemison submit a list of questions via fax and provide irdbTmanon about the nature and the 

scope of the project. Mr. Shah also indicated that he would like to have information about PES's 

authority to collect information for the EPA Mr. Jemison provided the requested information and 

list of questions to Mr. Shah on May 21,1998. On June 1,1998, Mr. Shah contacted Mr. Jemison 

and responded to the faxed hst of questions via telephone. The faxed list of questions is shown 

below with the responses of Mr. Shah in italics. 

List of Questions 

For the mixing and storage operations conducted at your facihty, please indicate the following-. 

1.) Do you use nitrogen blanketing for any reason during any of your mixing operations? If so, 

please describe carefully how this nitrogen blanketing process is conducted and state the 

reason for the nitrogen blanketing. 

Nitrogen Blanketing is used when mixing sheet molding compound (SMC) paste in Little Ford 

mixers at Budd Company facilities where SMC is manufactured A nitrogen/oxygen mixture 

is metered from a stationary 8500 lb capacity storage tank to the mixer via plastic tubing 

using a regulator and gas meter box. The gas contains approximately 96% nitrogen and 4% 

oxygen. The regulator sends this gas mixture to the mixer until the pressure equalizes at a 

pressure of approximately 3.5 ounces per square inch. The nitrogen blanket remains in place 

at this pressure during mixing. Nitrogen blanketing is conducted to prevent moisture from 

condensing on the resin which would significantly decrease the quality of the SMC 

manufactured by the facility. Nitrogen blanketing also hos the additional effect of reducing 

HA? emissions from the mixing process. 

INFORMATION IS ACCURATE V -J .511 
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. ____ 

Mr. Vinod C. Shah - The Budd Company 

June 1 & 24,1998 

Page Two 

2.) Do you use nitrogen blanketing in any of your resin storage containers for any reason? If so, 

please describe carefully how this nitrogen blanketing process is conducted and state the 

reason for the nitrogen blanketing. 

Nitrogen blanketing is Used on all resin storage _a_]_l using the same method and for 

the same reasons discussed in response to question I.) above. 

3.) Is your facility subject to any federal, state or local regulation or permit condition that 

requires die use of nitrogen blanketing? 

Mr. Shah indicated that while he thought that nitrogen blanketing was good engineering 

practice, he was not aware of any federal, state or local regulation or permit condition that 

required the Budd Company to use nitrogen blanketing. 

4.) Are you aware of the effects (if any) of nitrogen blanketing on HAP emissions from resin 

storage or resin mixing? If so, please discuss the effects of nitrogen blanketing on HAP 

emissions. Please indicate your source of infonnation for mis discussion. Information 

sources can be actual testing on mixers (or storage containers) with and without nitrogen 

blanketing or simply your personal experience and/or the experience of other individuals that 

work ax your facilities. 

Mr. Shah indicated that while Budd Company had not conducted any studies or emission 

testing, he felt that it was reasonable to assume that HAP emissions were reduced due to the 

nitrogen blanketing process, since the nitrogen would form a pressure blanket that could not 

readily be penetrated by the styrene vapors that would ordinarily be given off from the mixing 

process or from resin storage tanks. 

Mr. Shah noted that while nitrogen blanketing is used for the overwhelming majority of the resin 

mixing conducted by the Budd Company, the company occasionally uses two Cowles-type 

mixers for various reasons. Since these two mixers are open during mixing operations, the use of 

nitrogen blanketing is not feasible during their operation. As such, the nitrogen blanketing 

process is not used for these two mixers. 

INFORMATION IS ACCURATE ^'" ^ Q-* -

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