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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

79) ll-C-105 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:30 PM Sheet 79 of 343 
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PACIFIC ENVIRONMENTAL SERVICES, INC. 

i* *>& 

» 

25 m\ 

ll-C- \05 

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 

October 29,1 

Mr. Bernard Brody 

Ashland Chemical Company 

P.O. Box 2219 

Columbus, OH 43216 

De«ar Mr. Brody, 

As I explained to you during our telephone conversation, the U.S. EPA and its contractor, 

Pacific Environmental Services, Inc. (PES), are in the process of developing a national emission 

standard for hazardous air pollutants (NESHAP) for the reinforced plastics composites industry. 

In order to collect the data needed for the NESHAP development, the EPA sent out screening 

surveys to facilities in the reinforced pieties composites industry. The EPA and PES are 

currently analyzing the survey information and verifying the data reported in these surveys. 

As part ofthe .analysis, we are gathering and comparing information about tooling resins; 

particularly those resins with a lower than average hazardous air pollutant (HAP) content. The 

low HAP tooling resins manufactured by Ashland Chemical Company (Arotool 2001 .and AME 

5000) are of particular interest because of their high heat distortion temperatures and general 

comparability to higher HAP resins. Although information about these resins from Ashland 

Chemical Company is essential to the analysis, direct information from reinforced plastic 

manufacturers successfully using the resins is also necessary. To expatiate the process of finding 

these manufacturers, a list indicating companies using these resins would be greatly appreciated. 

If this information is received by the U.S. EPA as confidential business information, it can not be 

released in any form that would indicate either the provider ofthe information or the companies 

named within. This information would be used to contact these users of low HAP tooling resins 

to inquire about their tooling resin usage. Ashland Chemical Company could in no way be ' 

indicated as the provider ofthe names ofthe manufacturers. 

In addition to the information about users of low HAP tooling resins two other sets of 

information about costs would be greatly appreciated. The first set of information is a list of 

prices and densities for low HAP tooling gel coats. Currently, low HAP would include any 

tooling gel coat containing 38.85% or less HAP. We would like to collect this data on the 

properties and costs for gel coats sold by Ashland Chemical Company in order to assess the CQSts 

that facilities would incur by switching from gel coats with a high HAP content4o a low HAP 

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WASHINGTON, D.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI, OH 

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content. When you select these high and low HAP gel coat pairs, we would like you to match 

the gel coat properties for each ofthe pairs as closely as possible and provide average list costs 

for each pair. Please provide as many of these gel coat pairs as possible. 

Second, as I mentioned during our phone conversation, we are attempting to do a cost 

analysis of switching from a non-vapor suppressed resin to a vapor suppressed resin. Although it 

is clear that there are many indirect costs involved, any direct price information that Ashland 

Chemic^ Company can provide would be helpful. This price information would be most helpful 

if it could be provided in terms of ^ 80 drum shipment. 

Any ofthe portions of information submitted in response to these questions that is 

considered by Ashland Chemical Company to be confidential business information should be 

clearly indicated and mailed directly to: 

Ms. Melva Toomer 

Office of Air Quality Planning and Standards 

CBI Manager 

411 West Chapel Hill Street, Room 944 

Durham, North Carolina 27701 

If any ofthe information in your response to this request is not considered by your 

company to be confidential business information, please submit the response directly to me 

either through the m*ail or through our fax number (919) 941-0234. 

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

(919) 941-0333 or the EPA task order project officer, Ms. Madeleine Strum, at (919) 541-2383. 

Thank you for your cooperation. 

Sincerely, 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Shawn A. McKee 

Environmental Scientist 

cc: Madeleine Strum, EPA