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OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

69) ll-C-95 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:29 PM Sheet 69 of 343 
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/S§f PACIFIC ENVIRONMENTAL SERVICES, INC. 

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 

A 94 52 „ 

M r£ - 95 

Dr. Bob James 

Enduro Systems, Inc. 

Via Facsimile @(713) 869-9423 

Dear Mr. J<ames: 

During the month of April 19981 contacted you to obtain current information regarding the 

manufacture of plastic composites at the Velasco Scale Company facility located in Freeport, Texas. 

As I explained on the telephone, the EPA has been and still is collecting information about emissions 

of hazardous air pollutants (HAP) from facilities in the plastic composites industry. This information 

is currently being used in the standards development process pursuant to Section 112 of the Cle^ 

Air Act (CAA), as amended in 1990. The CAA requires that the EPA establish emission standards 

for all major sources of HAP that reflect maximum achievable control technology. 

In order to collect the data needed for the standards development discussed above, the EPA 

sent out a screening survey to facilities in the plastics composites industry in 1993. Velasco Scale 

Company submitted an industry screening survey to the EPA that provided information for the 

NESHAP development. Since PES obtained information that the Vel<asco Scale facility in Freeport, 

Texas was purchased by Enduro Systems, Inc., we contacted you to verify that certain information 

contained in the 1993 survey submitted by the Velasco Scale Company is still accurate. 

Per your request (during our telephone conversation) I am sending you information about 

PES's authority to collect information for the EPA. The EPA contracted PES under Contract No. 

68D60013 to obtain information about facilities in the plastic composites industry. Thus, as noted 

in Enclosure 1, PES has been designated an "authorized representative" ofthe Agency. 

The list of questions contained in enclosure 2 is designed to facilitate your company's quick 

response to this information verification request by asking only for the information pertaining to the 

manufacture of corrosion-resistant products using the filament winding process and the mixing 

operations conducted at your facility. If any ofthe information you submit in response to the list of 

questions in Enclosure 2 is considered by your company to be confidential business information 

(CBI), please indicate those portions of your response considered to be CBI and mail the entire 

response to: 

WASHINGTON. D.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH 
P.3 

Ms. Melva Toomer 

Office of Air Quality Planning and Standards 

CBI Manager 

411 West Chapel Hill Street, Room 944 

Durham, North Carolina 27701 

If none ofthe information in your response to this request is considered by your company 

to be CBI, please submit the response directly to me either through the mail 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. 

/%S*u^Sh. t 

Mehnie Proctor 

Project Lead 

2 Enclosures 

cc: PES Project File 

Ms. Madeleine Strum, US EPA 

2 

Is 
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Enclosure 2 

List of Questions 

Please answer the following list of questions for corrosion-resist<unt products (i.e. corrosion -

resistant tanks, pipes, etc.) produced using filament winding. Please use data from the 1997 

calender year, unless the filament winding practices your facility uses to produce corrosionresistant products have changed substantially since that time. 

1. For the filament winding process, how much resin was processed to produce corrosionresistant products in 1997 and which types of resins were used? 

2. For the resins discussed in question 1 above, what was the weighted average resin HAP 

content of those resins during 1997. Note: The EPA does not include filler, catalyst, 

promoters, reinforcement, and other additives in detennining resin HAP contents. 

Also, cany additional HAP that is added to the resin at the facility is included in the 

resin HAP content calculation. The equation to calculate the resin HAP content 

including any additional HAP added to the resin is shown below: 

a/ a in • D • _ Total Amount of HAP v ,„.„. 

% HAP in Resin = - X 100% 

{Total Amount of Resin) + (Total Amount of HAP) 

3. Which emission reduction or pollution prevention measures are used to limit emissions 

from the fil<ament winding process (i.e. low HAP resins, vapor suppressants, etc.)? 

4. Is the facility using any add-on control devices to reduce volatile HAP emissions? If 

so, which processes are controlled and what is the overall control efficiency of the 

device? Which type of add-on control device is being used? 

Are all resin mixing vessels at the facility closed or covered during mixing? If so, how 

would you describe the degree of coverage (i.e., fully sealed, no visible gaps, or 

openings)? If there are openings in the mixer covers, what are the dimensions? Does 

the facility apply a vacuum to the mixer and/or actively vent emissions from the mixer to 

the atmosphere or a control device? 

3 
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.ito sr«, 

I" *^*- \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

VSR, 

o RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUAUTY PLANNING 

ANO STANOAROS 

DESIGNATION OF AUTHORIZED REPRESENTATIVE 

FOR STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES 

(SECTION 111) AND SOLID WASTE COMBUSTION (SECTION 129), 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS 

(SECTION 112), AND FEDERAL OZONE MEASURES (SECTION 183) 

Under contract 68D60013, Pacific Environmental Services (PES) 

(prime contractor) and Alpha-Gamma Technologies, Incorporated, 

Environmental Quality Management, and Bennet King (subcontractors) 

are hereby designated Authorized Representatives of the Administrator 

of the United States Environmental Protection Agency for the purpose 

of assisting in the development of national emission standards for 

hazardous air pollutants under 42 U.S.C. 7412, standards of 

performance for new stationary sources under 42 U.S.C. 7411, solid 

waste combustion under 42 U.S.C. 7429, and Federal ozone measures 

tinder 42 U.S.C. 7511 (b) . 

This designation is made pursuant to the Clean Air Act, 

42 U.S.C. 7414. The United States Code provides that, upon 

presentation of this credential, the Authorized Representatives named 

herein: (1) shall have a right of entry to, upon, or through any 

premises in which an emission source is located or in which records 

required to be maintained under 42 U.S.C. 7414 (a) (1), are located, 

and (2) may at reasonable times have access to and copy any records, 

inspect any monitoring equipment or method required under 42 U.S.C. 

7414 (a) (1), and sample any emissions that the owner or operator of 

such source is required to sample. 

Authorized Representatives of the Administrator are subject to 

the provisions of 42 U.S.C. 7414 (c) respecting confidentiality of 

methods or processes entitled to protection as trade secrets, as 

implemented by 40 CFR 2.301 (h) (41 FR 36912, September 1, 1976). 

Date: MAR 2 01988 

Designation Expires: September 30, 2001 

5hn S. Seitz 

Director 

Office of Air Quality Planning 

and Standards 

H