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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

t-E-153 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:10 AM Sheet 194 of 264 
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-- -" 05/19/98 11:30 FAX 715 234 6259 

t 05/19/98 12:02 ©19199410234 

F/G PRODUCTS INC 

PES RTP NC 

1^002 

BI 002/004 

From: 

Date: 

Contact: 

Company: 

Contact Report 

Robert Jemison, Pacific Environmental Services, Inc. (PES) 

May 13,1998 

Mr. Chadwick Nelson 

FG Products, Inc. 

Telephone Number: (715)234-2334 

Fax Number: (715)234-6259 

Contact Summary: 

Mr. Chadwick Nelson was contacted on behalf of the U.S. EPA to clarify information related 

to the manufacture of plastic composites at the FG Products, Inc. facility located in Rice Lake, 

Wisconsin. The infonnalion was provided to the EPA in a May 4,1998 letter from Mr. Nelson of 

FG Products. The infonnation was submitted in response to a request for information from Mr. 

Jemison via telephone on April 4,1998. In response to my questions Mr. Nelson indicated the 

following: 

The facility produces movable insulation panels for tractor trailer trucks. These panels are 

often custom made to different sizes and shapes in order to meet the needs of a particular customer. 

The company employs 50-55 people with approximately 15 people being involved in the actual 

spray lay-up operations. The company is primarily involved in the manufacture and sale of products 

composed at least partially of thermoset plastics (the products may or may not be plastic composites, 

depending the product). 

The facility uses atomized spray lay-up to apply an unfilled polyester resin in the fabrication 

of the movable insulation panels described above. The polyester resin applied using spray lay-up 

contains approximately 35.0% HAP by weight The facility's permit prohibits the use of any 

production (non-tooling) resin that contains more than 35.0% styrene by weight. The facility may 

purchase the same type or similar resins from different suppliers when convenient for the facility but 

the resins never contain more than 35% styrene by weight. The two MSDS sheets provided by the 

facility (marked general purpose resin #1 and general purpose resin #2) are simply general purpose 

MSDS sheets provided by two different manufacturers of the type of resin used by FG Products, Inc. 

and the stvrene contents shown are not the actual styrene contents as received from the 

manufacturers of the resins. As indicated in the spreadsheet provided by FG Products, Inc., the 

unfilled polyester resin used to produce the movable insulation panels accounted for 98.4% of the 

total resin used by the facility during the calender y&fy\991. 

INFORMATION IS ACCURATE 
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Contact Report 

FG Products, Inc. - Mr. Chadwick Nelson 

May 13,1998 

Page Two . 

The only HAP initially present in the unfilled polyester resins used to fabricate the movable 

insulation panels is styrene. No additional HAP is added to the resins during or prior to the 

fabrication process with the exception of small amounts of HAP that may (or may not) be present 

in iniriatois, promoters, and/or catalysts added to the resins. None of the unfilled polyester resins 

currently contain a vapor suppressant The facility did use vapor suppressants with their unfilled 

polyester resins at one time, but discontinued the use of vapor suppressants due to possible negative 

effects the vapor suppressants were having on other materials present in their products. 

, The faciliry uses atomi2ed spray lay-up to apply one pigmented (white) production gel coat 

in the fabrication of the movable storage panels discussed above. This gel coat contains 3 7.0% HAP 

by weight (32.0% styrene and 5.0% methyl methacrylate). The facility's permit prohibits the use of 

a pigmented production gel coat containing more than 32.0% styrene by weight 

The faciliry applies a pigmented (black) tooling gel coat using atomized spray lay-up in the 

fabrication of the custom molds used to create the movable insulation panels described above. This 

gel coat contains 47.39% HAP by weight (43% styrene and 4.39% methyl methacrylate). After the 

application of the pigmented (black) tooling gel coat, the facility applies a combination of an 

unfilled, isophthalic "skin coat" tooling resin and glass fibers to the mold in a thin layer 

(approximately 0.125 to 0.250 inches). This "skin coat" tooling resin is heal resistant and acts as 

a heat transfer buffer to protect the mold from the heat given off during the exothermic reaction that 

occurs when the unfilled polyester resin applied to the mold (during normal production) begins to 

cure. This heat transfer buffer is necessary because the transfer of an excess amount of heat may 

cause the mold to warp to an unacceptable degree. The "skin coat" tooling resin contains 43% HAP 

by weight and does not contain a vapor suppressant After the application and curing of the "skin 

coat" tooling resin, the facility uses atomized spray lay-up to apply polyester tooling resin as the 

final step in the fabrication of the custom molds. The facility adds aluminum trihydrate to the 

tooling resin to prevent shrinkage and warping during curing of the mold. This polyester tooling 

resin contains 50% HAP by weight (not including filler) and does not contain a vapor suppressant 

The only HAP initially present in either the filled tooling resin or the unfilled "skin coat" 

tooling resin is styrene. No additional HAP is added to these resins during or prior to the fabrication 

process with the exception of small amounts of HAP that may (or may not) be present in initiators, 

promoters, and/or catalysts added to the resins. 

No additional HAP is added to either the pigmented production or pigmented tooling gel 

coats during or prior to the fabrication process with the exception of small amounts of HAP that may 

(or may not) be present in initialois, promoters, and/or^catalysts added to the gel coats. None of the 

gel coats contain a vapor suppressant 

INFORMATION IS ACCURATE 

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Contact Report 

FG Products, Inc. - Mr. Chadwick Nelson 

May 13,1998 

Page Three 

All of the resin mixing conducted at this facility is done for the purpose of mixing filler into 

the tooling resin discussed above. The mixing is conducted inside 55 gallon drums by inserting a 

drill shaft through a hole in a wooden cover placed on top of the 55 gallon drum. The 55 gallon 

drum was opened at the top (i-e. the top of the drum was removed) prior to the start of the mixing 

operation. Approximately 90% of the open drum surface is covered by this wooden cover. The drill 

shaft is driven by a drill powered •with compressed air. The facility heats the 55 gallon drum using 

a heat strip placed around the bottom of the drum. The heat keeps the filled resin at a low enough 

viscosity to be transferred through closed lines from the 55 gallon drum to the spray guns. The 

facility does not actively (force) vent emissions from the 55 gallon drum by applying a vacuum to 

the drum. 

INFORMATION IS ACCURATE ^^Z<^^/^'/yU^pT 

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