— — • 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

12) ll-J-3 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:18:29 AM Sheet 12 of 36 

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Trail Wagons Inc. 

Fiberglass Division, Plant II 

P.O Box 2589 

Yakima, WA 98907 

Manufacturers of Chinook RV and Trail Wagons Vans 

(509)-452-5394 

FAX (509) - 248 - 9054 

CT-T-3 

December 21,1999 

Mr. Keith Barnett, Environmental Engineer 

United States Environmental Protection Agency 

Emissions Standards Division 

Mail Drop #13 

Research Triangle Park 

North Carolina 27711 

RE: RESPONSE TO OUTREACH INPUT PRIOR TO SBREFA 

Dear Mr. Barnett, 

Trail Wagons/Chinook, Inc., submits the following issues relevant to adverse economic impact to 

our small company should MACT, as drafted today, be implemented: 

• As a small manufacturing entity located in the hub of a predominately agricultural valley, Trail 

Wagons/Chinook, Inc., provides an alternative tax base, revenue generator, employer, and 

purchaser of raw materials. The competition in our labor pool is hops, apples and related stone/soft 

tree fruit, grapes, and the service sector. We aggressively pursue the potential entry level candidate 

from that competing pool and then train, mentor, shadow, and encourage retention at great expense. 

Over time, we have elevated the income, morale, and technical merit and ability of our employees. 

Relative to this industry (not just this valley), our benefits package is handsome including vacation, 

401K, medical, dental, vision, and a monthly bonus system whereby ALL employees have the 

opportunity to become eligible. Although contingent on market conditions, we provide year round 

employment in an otherwise seasonal work environment. Our current workforce stands at 145 after 

achieving an 87% growth factor during 1999. Since 1972 we have invested heavily towards the 

quatity of our product, facility, personnel, and most importantly the contemporary issue of our future. 

The MACT Standard as written has the potential to kill our effort. Not next year. Not when the 

market falters. Not when we are challenged by the industry giants. Now! Right nowll 

• In January of 1999, Trail Wagons/Chinook, Inc. relocated to a site approximately 2 miles from where 

it has been operating in two structures (20,000 square feet and 30,000 square feet) for 21 years. The 

new facility contains all of the manufacturing and assembly operations of the old facilities except 

those of FRP/Composites. The investment of the new facility is $3,500,000.00. From the old site, we 

have dismantled and reassembled the 30,000 square foot building at the new site for 

FRP/Composites operations. The scheduled startup for the new FRP facility is January 15th, 2000. 

The investment is the new FRP facility is $1,500,000.00. An additional $250,000.00 has been spent 

in the new FRP facility for an air handling system which will reduce the HAPs in the laminating 

portion (6,000) to under 50PPM. That expense includes compressed air, dryer, air vacuum for 

bagging (closed molding), backup air, modification or sprinklers and electrical for compatibility with 

the air handling system, etc. When computed to date, that investment pushes the window of the 

debt ratio towards the limit. This company is a sole proprietorship and $5,250,000.00 in less than 12 

months is already an extreme outlay. There will be no more lending. Period! 
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t 

In good faith and in advance of the EPA regulatory compliance issue(s), for OSHA compliance, for 

waste and anti-pollution issues, for economic reasons, Trail Wagons/Chinook, Inc. converted ALL of 

it's material application equipment to FLO-Choppers manufactured by Magnum Industries in July of 

1999. In the new FRP facility, Magnum Industries air motors will be installed on all of the Gel-Coat 

application equipment. The FIT (Fluid Impingement Technology) retrofit components have been in 

my office for a month and are ready for installation. Each of the Flo-choppers is $7,000, and the 

retrofit for each of the Gel-Coaters is $2,200.00. Within the past 18 months, our benevolence factor 

to Magnum will exceed $49,000.00, not including the O & M outlay for routine replacement. 

Since our educational visit to CFA at Chicago in October, 1999, we have pursued the retrofit and 

replacement of all of our mold carts to include overspray shields in an effort to reduce pollution, use 

less material, and reduce the size of the "footprint" left by resin which misses our molds in our open 

molding procedures. The expense, not including material for those carts, varies from $100 to $450 

for each of our small molds. The large molds expense also varies; the most expensive, including 

material, costs $4,500.00 each. We have not calculated the overall investment yet for our spray 

shields. 

In April of 1999 Trail Wagons/Chinook, Inc. began experimenting with lower styrene resins in an 

effort to reduce pollution. Time spent discussing change, experimenting, enjoying product failure 

and inferior structural performance at the expense of routine production was offset by increased 

worker output in a valiant effort buy rank and file to maintain status quo. The Main Plant never felt 

the pain but ownership paid the bill. It appears that our eariy pro-active posture will pay dividends. 

Today we are using a 34.7% monomer resin with more change on the way. In the very near future, 

we will be switching to a bulk storage and delivery system. I am in the process, at great expense, of 

visiting resin manufacturing and blending facilities to validate my recommendations to ownership and 

confirm that our "Lifetime" FRP guarantee (the only one in the industry) can be upheld. We intend to 

comply only if we can afford to stay in business. Meeting the new MACT Standard is more than 

merely capitol outlay and initial investment. There is, and has been much expense in research and 

development within our own facility to insure that the equality and integrity of our product is not to be 

sacrificed. 

Futhermore, we have just completed the identical exercise by researching, designing, and installing 

our interior air handling system in an effort to comply with OSHA. We traveled, we investigated, we 

put out for bid, and we have installed in our new FRP facility a Frees system. The volume of air 

(72,000cfm) and the density of HAPS (-50ppm) do not afford us an opportunity with today's 

technology to affordably install and operate a thermal oxidizer, incinerator, or afterburner. 

It is Trail Wagons/Chinook's intent to comply with the mandate of the U.S. congress. We have a 

highly marketable quality product. The manufacturing areas of our company use 100% U.S. made 

raw material. The assembly areas are close to 100%. The FRP facility represents 25% of the 

company. The regulatory financial drain we are currently experiencing and will probably experience 

in the near future, is predominantly occurring in the FRP operations. There is a break point and we 

are not encouraged by the potential adverse financial impact, which the MACT Standard processes. 

Trail Wagons/Chinook, Inc., has researched the possibility to either subcontract and/or relocate a 

portion of our FRP work in an effort to lower emissions at this facility. The consensus is that our cost 

of goods manufactured FOB our dock, would increase beyond an acceptable margin and that we 

would loose control of production and quality. 

Please bear in mind that the introduction of our afterburner research has been, to say the least, 

scary. It has completely disrupted the planning for certain factions of our company. For instance, 

the FRP facility is currently in a facility, which is also intended to be relocated to the new site in order 

to support the projected growth. That growth can only come with additional output. We cannot 

infuse capitol into growth when it is required for compliance. Cash flow from the sale of 

motorhomes, vans, suburbans, and pickups must be rolled into payroll, materials, and overhead in 

order to maintain current production. Additionally, this effort has cost an unprotected investment in 

time from our environmental compliance personnel, myself, and ownership. We should all be 
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devoting our efforts on safety, productivity, and growth, those items which bring forth advancement 

and revenue. 

If EPA does implement MACT as it is currently drafted, our question is "where are we left standing, 

where do we tum?" Now that we have met OSHA Standards by reducing the PPM to -50, the 

density is so low and the cfm so great (72,000), the existing technology to capture and control is 

terribly inefficient. In other words, the horsepower to weight ration is not good! 

What other technologies are available which are suited to our situation? 

In what form are we receiving investment credits or tax relief in the form of write-offs? 

What help is there and how do we get it? 

Who determines if we are in an economically depressed area, and does EPA have access to 

funding for relief? 

Again, as a small business, this proposal has the ability to stifle our operation. 

Sincerely, 

TrailJVagons/Chirjook, Inc. 

5ff Gaskell, Division Manager 

cc: John Switzer