p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

50) IV-C-23 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 50 of 273 
P.2 

PES 

A MACTEC COMPANY 

A-94-52 

Pacific Environmental S ];y_c_23 

5001 South Miami Boulevaro, 

P.O. BOX 12077 

Research Triangle Park, NC 27709 

Office: 919/941-0333 Fax: 919/941-0234 

Home Page: www.mactec.com 

Mr. Perry Bennett 

MFG Companies 

2925 MFG Place 

Ashtabula, OH 440-998-3524 

Dear Mr. Bennett: 

March 28,2002 

, 

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EPA AIR DOCKET 

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 /A /•% lis i r 

MAR 2 8 2002 

IB'. P.£*wtf-

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As you know, Pacific Environmental Services, Inc., (PES) is the contractor to the U.S. 

Environmental Protection Agency (EPA) on the reinforced plastic composites (RFP) NESHAP. 

PES is currently assisting the EPA in preparing responses to public comments received on the 

proposed RFP NESHAP. Several comments letters identify facilities that are not currently in our 

database, including your facilities in Texas, North Carolina, and Kansas. Attached are tables that 

we would like MFG to fill out in order for us to appropriately include these facilities in our 

database. I have filled in as much information as I could based on your comment letter for each 

facility on separate tables. In addition, I have included tables for the two MFG facilities we 

currently have in our database (Union City and Adelanto). A blank table is also provided. 

Please review the information in all five tables and correct it as necessary and then please 

fill in all remaining information. Please note that some ofthe information I have entered is 

incomplete (e.g., under "Process Grouping" I may have entered "open molding, mechanical" but 

have not indicated if it is corrosion-resistant or non-corrosion resistant, or if it is filled or 

unfilled). Where information is accurate, but incomplete, please be sure to complete the 

information. Also, I am sure I have not listed all ofthe applicable process groupings for each 

facility. I have tried to limit the information requested to that necessary for us to evaluate each 

facility's ranking and then to allow us to cost various control options. 

If you have any questions concerning this request, please do not hesitate to contact me at 

919-941-0333 or the EPA Project Lead, Mr. Keith Barnett, at 919-541-5606. Please feel free to 

call him if you have any questions. If any ofthe information you can supply is considered to be 

confidential by your company, we can provide you with the procedures that are used to submit 

such information directly to the EPA. Thank you in advance for whatever help you can provide. 

Sincerely, 

XlyyyO& 

Kenneth R. MeardVm 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Enclosure 
P.3 

Instructions for Facility Survey Table 

Facility Name and Location: Please enter the name used to refer to the facility for which the data are being reported 

and the physical location ofthe facility. 

Year for Which Data is Being Reported: Please use the most recent year for which you have the requested 

information. If that year is not representative of your production, then report a year that you consider representative. 

Hours of Operation: Please report the hours of operation for the year that corresponds to the data being reported. 

For example, the data in the table is for the year 2000, report the hours of operation for the year 2000, even ifthe 

hours of operation at which you are currently operating are different. 

Process Grouping: Select from the following list: 

manual, corrosion-resistant 

manual, non-corrosion resistant 

tooling resins, manual application 

mechanical, corrosion-resistant 

mechanical, non-corrosion resistant, unfilled 

mechanical, non-corrosion resistant, filled 

tooling resin, mechanical 

corrosion-resistant filament winding 

non-corrosion resistant filament winding 

pigmented production gel coats 

clear production gel coats 

tooling gel coats 

closed molding (compression and injection molding) 

resin transfer molding 

corrosion-resistant centrifugal casting 

non-corrosion resistant centrifugal casting 

continuous lamination/continuous casting 

polymer casting 

pultrusion 

SMC manufacturing 

BMC manufacturing. 

Material: Indicate the type(s) of gel coats and resins being used. If readily available, provide information on an 

individual gel coat and resin basis. 

Usage: List amount used in a representative year by group. If individual gel coats or resins are listed, then provide 

the amount used for each individual gel coat and resin reported. 

HAP Content: Include all HAP monomer (styrene, MMA, etc.) for when the material is applied. This would 

include any HAP added to the purchased resin or gel coat. If average weight percent is not readily available, show 

range. 

Application Technique: List each application technique used to apply the gel coats and resins. Include in 

parentheses after technique the percentage of each material applied using that technique. 

Other Emission Reduction Technique: If you use add-on controls or any other technique to can be quantified for 

reducing emissions, please list and then show in parentheses the overall capture-and-control effectiveness. 

Color (gel coat only): For gel coats only, indicate for each gel coat one ofthe following: white/off white pigmented, 

other pigmented; or clear. 
Facility Name and Location: M*P*$- C^t-vic**-*. CA\U 

Hours of Operation: 

Year for Which Data Is Being Reported: iffil 

FACILITY SURVEY TABLE 

W 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

OptvMMoVa. »V\A, 

v

~\</\a.\AO*s*-v 

"^O*P\»>OV y l COdu> 

Material 

pigmented gel coat 

vinyl ester resin 

r*s-v\ 

T>t^t«4ci <f\ Cotiftl 

r<<**\ 

V^"i ^ 

4f\c&dr 

Quantity 

Used (tpy) 

500 

1000 

S2S.1. 

\OZ.O 

Average HAP 

Content 

(wt. %) 

46 

32-37 

41*/. 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: Page "2. 

Process Grouping 

Q>u_Kbre^O^ 

fcn^ 

Material 

5M^ 

uc/A 

tf^A 

Quantity 

Used (tpy) 

3.1 

Average HAP 

Content 

^wt . %) 

4 1% 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 
Facility Name and Location: Kr6? - tAcLeAcuu-d^p 

Hours of Operation: 

Year for Which Data Is Being Reported: 11^7 

FACILITY SURVEY TABLE 

^ 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

£bev>. tAA.o\*k*v\e\ i 

\A\tXV_\JO_\ 

\t\tcl&VMfiJL 

TooV^^^tocb 

Material 

pigmented gel coat 

vinyl ester resin 

re-s-tvs 

y^W^W ^loXt" 

TWA 

r<*3iv\ 

d el to<£\" 

Quantity 

Used (tpy) 

500 

1000 

Xo^ 

4b 

Average HAP 

Content 

(wt. %) 

46 

32-37 

3S£ 

^ 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: Page 2. 

• ^ 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 
Facility Name and Location: Mfc? ~ T^affis 

Hours of Operation: 

Year for Which Data Is Being Reported: 

FACILITY SURVEY TABLE 

^ 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

t3p*fc*AU^Vl-\v^> 

WV2O/**AK1O»A 

G>iMAf^««i>^v^wv>tSv 

Toeing r€SM 

Material 

pigmented gel coat 

vinyl ester resin 

-tD*5>l<YV9\V*SM 

^xhjesks- aA. Cocdc 

^pyifu re ^ 

Quantity 

Used (tpy) 

500 

1000 

Average HAP 

Content 

(wt. %) 

46 

32-37 

*z.% 

o% 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Ci°0*7o) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: rlfij? -Te-Cfl-S Page 2. 

<*} 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 

Tl 
Facility Name and Location: i\p6}~ T*>\lfl^,<u*vicg? WWiAS 

Hours of Operation: 

Year for Which Data Is Being Reported: 

-£> 

FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

A)-0v\ w^\a*v\a 

ltr*\ 

ToaWy-^s^ 

Material 

pigmented gel coat 

vinyl ester resin 

\ 

Quantity 

Used (tpy) 

500 

1000 

Average HAP 

Content 

(wt. %) 

46 

32-37 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 

1 
Facility Name and Location: Page 

O 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

._ 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 
Facility Name and Location: 

Hours of Operation: ' 

Year for Which Data Is Being Reported: 

FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

OtfAA UA.o\.Q.\>UH 

~\0d tac./'t'SiVN. 

Co**\* SSfi&K *Me\<L<*C\ 

(tn\ 

Material 

pigmented gel coat 

vinyl ester resin 

Quantity 

Used (tpy) 

500 

1000 

Average HAP 

Content 

(wt. %) 

46 

32-37 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: Mrp - ypr'fC^ (Aird\\Y\(\. Page 

f 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 
Facility Name and Location: 

Hours of Operation: 

Year for Which Data Is Being Reported: 

Co 

FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

Material 

pigmented gel coat 

vinyl ester resin 

Quantity 

Used (tpy) 

500 

1000 

Average HAP 

Content 

(wt. %) 

46 

32-37 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: Page 

- ^ 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 

i 

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