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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

5DII-C-77 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:29 PM Sheet 51 of 343 
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A-94-52 

|*' A \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| ^Sf-t I RESEARCH TRIANGLE PARK, NC 27711 

NOV 1 0 1997 

OFFICE OF 

AIR QUALITY PLANNING 

Ms. Hilary North \ X~~ I * AND STANDARDS 

LASCO Panel Products 

8015 Dixon Drive 

Florence, Kentucky 41042 

Dear Ms. North: 

Thank you for your cooperation during the source test that the U.S. Environmental 

Protection Agency (EPA) and our contractor, Pacific Environmental Services, Inc. (PES), 

conducted during May of this year. While assembling the process information collected during 

the source test, several areas associated with the process data were identified that need to be 

clarified or for which additional information is needed. These areas are identified in the attached 

enclosure. Tables 1 and 2 of this enclosure are being sent to you under the EPA's pending 

confidential business information procedures. Once the analysis ofthe source test results is 

completed, we will send you a copy ofthe results for your review and request at that time, 

identification of specific infonnation considered by LASCO Panel Products to be confidential. 

In addition, there is concern over the Jinalyticd results obtained on the resins samples 

collected during the source test. The results fiom the laboratory do not appear to be 

"reasonable." We would like to discuss with you any sample analysis that LASCO Panel 

Products has performed on resin samples to evaluate potential problems with the sample analysis 

that was conducted. We believe that it may be necessary to re-sample each ofthe six formula 

that were used during the source test. Mr. Dan Scheffel from the PES Cincinnati office will 

contact you regarding the samples and their analysis. ~> 

We appreciate your continuing assistance in our efforts to develop a standard for your 

industry and request your response to the information requested in the enclosure by 

November 21,1997. If this is not possible or if you have any questions concerning this request, 

please contact Madeleine Strum at (919) 541-2383 or Ken Meardon of PES at (919) 941-0333. 

Sincerely, 

Q^lr\Aj^ o> • \4o_ws 

Linda S. Herring 

Group Leader 

Coatings and Consumer Products Group 

Enclosure 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable •Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Poslconsumer) 

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Enclosure 

Please review Tables 1 and 2 for their accuracy (e.g., the correct resin formula are 

identified for each date and time that the source testing occurred). Table 1 identifies the date and 

time for each test run, the resin formula used and its calculated hazardous air pollutant (HAP) 

content, whether the resin was filled or not, the pigment formula and its density, and the roving 

type. Table 2 summarizes information on the HAP content ofthe six formulas that were used 

during the source testing and shows the calculation ofthe HAP content of each formula. The 

following are more specific requests needed to complete the process data evaluation. 

Request 1. The pigment formula for some of the formulas used was identified, but not for all. 

Please identify the pigment formula used for each ofthe resin formulas used during 

the source test. 

Request 2. PES did not obtain the pigment density for the pigments used. Please provide the 

pigment density for each ofthe pigments used in each ofthe resin formulas used 

during the source test. 

Request 3. The second table identifies the information on the recipes for each ofthe HAP 

formula used during the source test. Ple<ase review this table for accuracy and 

identify any errors. Also, PES notes showed several potential recipes for 

Formula 51 (e.g., one indicated filler and another indicated no filler). Please 

identify the correct recipe for Formula 51. 

Request 4. Please identify the filler type for Formula 51 (if it uses filler) and Formula 74. 

Request 5. Please identify the type of roving used during the runs on May 14 for Formula 88 

and the last three runs on May 19 when Formula 46 was used. 

Request 6. Please provide a copy ofthe Material Safety Data Sheet for each ofthe base resins 

shown in Table 2. 

Request 7. During the source test, three samples were taken from the product side and placed in 

your on-site laboratory. LASCO was to perform a burn analysis on these three 

s«amples. Please identify the status ofthe burn analysis. 

Request 8. Prior to the source test, PES and LASCO discussed the various parameters to be 

monitored and the data to be collected. One parameter that was to be collected was 

the thickness of the final products. It was agreed that PES would not attempt to 

measure the thickness ofthe final products, but rely on LASCO's in-house quality 

assurance data to obtain this information. Using the information in Table 1 that 

identifies the date and time when the source testing was conducted, please provide 

copies ofthe quality assurance data sheets that correspond to these dates and times. 

Alternatively, please provide a summary ofthe thickness data only that were 

collected during these dates and times. 

OAQPS/ESD/CCPG:mstrum/jeck(x7946):NCM(MD-13):10/27/97:MADELEINEl/lasco3b.wpf 

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Docket No. A-94-52 

Category II-B 

The following information is located in the confidential files ofthe Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This information is 

confidential pending final determination by the Administrator and is not available for public 

inspection. 

Lasco Panel, Florence, KY No date 

2 copies Enclosure 1 covering Source Testing; 4 pages 

CN-N801-6 

ESD 93/58