p.1 

OAR Box 1477 

Prepped by Ollie Stewart 

Document Number: 

27) II-J-18 

Docket Number: 

A-94-52 

Printed 7/31/2008 11:40:24 AM Sheet 27 of 36 
P.2 

Sent By: The, Blakeston Corporation; 803 655 7179j Feb-24-00 10:39; Page 2 

ALAGLASS POOLS 

Route 1 Box 393 

(Office) 803-655-5000 

(E-Mail) Pfelra2997(g)aoUom 

February 7, 2000 

Mr. Keith Bameu 

US EPA 

MD13 

RTP.NC 27711 

Dear Mr. Ban-ieii, 

1 am writing lo you to express my concerns and suggestions relative to thc forthcoming Maximum 

Achievable Coniroi Technology (MACT) regulations for industries that emit one or more hazardous nir 

pollutants. I am aware that you are thc EPA engineer responsible for thc establishment of this standard and 

that I should direct all of my comments directly lo you. I wj|] do my best to do that. 

BACKGROUND 

My wife and 1 purchased Alaglass Pools in May 1999 from a private owner who began ihe company in 

1987. Alaglass Pools is a manufacturer of fiberglass swimming pools for the in-ground swimming pool 

market with a single manufacturing plant located in rural Calhoun County, South Carolina. The acquisition 

was completed as a result of the effons of thc Small Business Administration io whom wc have a 

significant financial debt obligation to repay over the next decade. Alaglass employs 11 people with over 

65% minority representation. Very simply, wc are a small manufacturing company. 

Alaglass pools are constructed using the open mold manufacturing process. Upon acquisition we replaced 

all of lhe atomized mechanical resin application equipment with non-atomized flow coaler technology from 

Magnum Industries. The gel coal application is currently being applied with the older atomized mechanical 

application equipmenl; however, Alaglass will be replacing this equipment with non-atomized flow coater 

technology to be again purchased from Magnum Industries within the next 6 months. 

In an effort to better evaluate the emissions environment at Alaglass we conducted an open mold MACT 

feasibility assessment on February 4*. This assessment yielded lhe information contained below: 

In addition to thc below calculated point values, we also calculated the actual tonnage ol HAP currently 

RujuoafRoduct 

Oo-p 

Mxttricai Rrin/^ioforvTodlng 

NfedT-rtcal Rsrin /SpdicrfiorvTodlna 

fifed^ricai Rssin fif^iicsbort-TocllrQ 

QBI QS*. Rprcrted 

VgatftedAerage 

Toa 

Qart. Nte 

Resin Ur t 

Rtrwwil VAlue 

Lttf12tm (Rov) 

183000 23SKandF C 

3,-CB 25GtS0%s*r*dFC 

37,360 29Ee57%vriPC -

32,918 35530% 

257 

230^*0/0 

Mg. 

Teeh& 

MCI 

Und tow 

••fiCWHAP.rnach 

S&CKHW.mseh 

-17.9ft HAP, rreeh 

37.CW»K4P,*Triz8d 

Rart 

VHue 

Now 

170 

91 

187 

377 

137 

Ftecttto 

Naw 

Toch& 

ftMV 

Mj**|l0MCrHAP% 

MfctowTHAP-tt, 

MjgtowrWf c 

37.0% MAP, mech 

Now 

ran 

Valus 

91 

91 

187 

Z77(ea) 

127 

NavSaJOB 

MUCT 

Boer 

V&B 

ZB 

206 

206 

19 

182 

being emitted. Tliis information is displayed below: 
Sent By: The Blakeston Corporation; 803 655 7179; Feb-24-00 10:40; 

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Page 3/4 

Process/Product 

Group 

Mechanical Resin Application-Tooling 

Mechanical Resin Application-Tooling 

Mechanical Resin Application-Tooling 

Gal Coat, Pigmented 

Weighted Average 

Total 

Quant. 

Resin 

Processed 

Lbs/12mo. 

193.000 

3.406 

37,350 

32.918 

268.676 

Point 

Value 

Now 

170 

91 

187 

377 

Total Total 

HAP HAP 

Pounda Tons 

Emitted Emitted 

16,405 8.20 

155 0.08 

3,492 1.75 

6,205 3,10 

26,257 13.13 

ANALYSIS 

It appears that Alaglass Pools should be capable of meeting or exceeding thc maximum point value (floor) 

requirements on a weighted average basis for resin application as indicated in the first chart above. 

However, the new source MACT floor value for pigmented gel coal (19) could never be attained without an 

incinerator. Our open molds range in size up to 16' wide x 40' long x 8' deep, considerably bigger than a 

fiberglass tub or shower. Given ihe size of our molds there could never be a 100% collection scenario. 

This requirement is unreaUstic for all fiberglass swimming pool manufacturers who use pigmented gel coal 

to produce color in iheir manufacturing process and would eliminate ihc ability of Alaglass Pools to 

continue to produce fiberglass swimming pools in a new source envkonment. To the best of my 

knowledge, there are no fiberglass swimming pool manufacturers who use incinerators. Even with 

additional flow coat technology there will never be a new point value for pigmented gd coal, which could 

approximate a new source MACT floor value of 19. 

It appears to me that there is enough fiberglass swimming pool manufacturers lo create a subcategory hosed 

on class or type, which would greatly aid in the proper cataloguing of new source MACT floor values for 

pigmented gel coat applications. 

Alaglass Pools currently docs not meet the HAP potential emissions requirement of 10 tons per year for any 

single HAP or 25 tons per year for any combination of HAPs. However, given Alaglass' projected growth 

in production there is a significant probability of qualifying as a major source within the next year. The 

five-year strategic growth plan, which was developed by Alaglass lo support its funding request to the 

Small Business Administration, depicted annual production growth necessary to meet its debt obligations to 

the Federal Government (Lender) and lhe Seller. Any significant truncation of Alaglass' ability to produce 

more units or any significant capital outlay required to nieeL new federal EPA demands would have 

catastrophic effects on the company's ability to meet its debt obligations to both the Small Dusiness 

Administration as well as lhe original Seller. 

In order tn meet the Company's financial long-term debt obligations, the Company must continue to grow 

both through production and employee expansion. New sources of production will have to be constructed 

in order to provide thc manufacturing means needed to meet these financial debt obligations. As a small, 

privately held business the Company does not have ready access to the capital markets as a source of 

odditional capital required to meet any capital expenditure requirements mandated by the EPA. For 

example, to meet thc projected 95% control requirement would require the acquisilion of an incinerator 

with $ 1,000,000 of initial investment capital and approximately $180,000 to $250,000 per year in operaling 

costs. This would be for only one new source sile. Styrene emissions have a half-life of approximately 

twelve hours but the nitrous and sulfuric oxides to be emitted by the incinerator would have a much longer 

and pervasive effect. 

The only source for capilal to meet this additional financial burden would be debt. Any federal EPA 

requirement that imposes upon the Company the responsibility to fund conlrol equipment (i.e. incinerators) 

to meet the 95% control requirement without a si/e threshold would incapacitate the Company rendering it 

unable to grow. The Company could not borrow the capital necessary to meet Ihe federal regulation and 

even if the Company could borrow thc capital, the Company would not be able to generate the additional 

cash flow through operations required to repay the lender. Companies of greater size and access to capital 

markets do nol have this dilemma; only small, privately held companies are affected. 
Sent By: The^Blakeston Corporation; 803 655 7179; Feb-24-00 10:40; Page 4/4 

Small, undercapitalized manufacturing companies, which comprise the greater percentage of manufacturing 

companies, do nol have access lo ready capilal and could not generate the additional cash flow required io 

repay additional debt incident to meeting EPA's 95% control requirements for new or reconstructed 

sources. Thc financial burden placed upon a small manufacturer would bc catastrophic and most likely 

eliminate many small manufacturers, ln the fiberglass swimming pool manufacturing market all of thc 

manufacturers are small. The impact of this federally mandated "no growth" strategy resulting from the 

proposed EPA requirement would eliminate many small manufacturers. 

The need for reasonable emissions regulations is understandable. However, such regulations cannot be 

enacted in such a manner that effectively promote a "no growth" strategy for privately held small 

businesses and serve only to accommodate the well capitalized larger publicly held companies. 

Thc weighted average poinl value methodology is reasonable and understandable and provides equal and 

fair opportunities for both private and publicly held manufacturers to meet the proposed new EPA emission 

requiremenis if it accurately reflects thc operaling environment of a targeted industry. The new source 

MACT floor of 19 for pigmented gel coat represents an unattainable standard; it cannot be anained without 

massive outlays of inaccessible capilal. The diversity of thc composites industry dictates a more equitable 

approach to this issue. 

In addition io the unattainability of the gel coat new source MACT standard, the 95% control requirement 

for new sources is unfair and severely penalizes small, privately held companies. The concept of a size 

threshold is reasonable and fair to both small and large manufacturers. Tt encourages small, independent 

companies to continue to invest and innovate in our industiy while it places maximum emphasis on ihe 

large well-capitalized manufacturers who emit greater tonnage of IIAP and can afford to conlrol it 

As you are well aware, the Clean Air Act of 1990, paragraph 1, section 112(d) states that the EPA "may 

distinguish among classes, types and sizes among sources". The mandate from Congress gives the EPA the 

latitude lo do so. 

Thc fiberglass swimming pool industiy is a young, vibrant and growing industry consisting of many small 

independent, privately owned companies who have no ready access to thc public capital markets, Any 

federal EPA requirement must bc fair and equitable to those small manufacturers as well as reasonable in 

thc interpretation of the mandate from Congress. 

RECOMMENDATION 

I am recommending two specific actions: 

1) That the EPA implement a 95% control requirement for all new and reconstructed sources with a 

size threshold of 95-100 tons annually of IIAP emissions. 

2) That the EPA utilize the existing source MACT floor for pigmented gel coat of 265 as the new 

source MACT floor standard either as an overall standard or for a newly created subcategory 

encompassing fiberglass swimming pool manufacturers. 

Mr. Bametl. the impact of your decision will have an overwhelming impact on my Company's ability to 

grow and remain a financially viable manufacturer. T hope that your final decision fairly reflects the 

operaling characteristics of the fiberglass swimming pool industiy and is constructed in auch a manner lhat 

all small, privately owned manufacturing companies can continue to grow and innovalc. 

I encourage you to contact mc directly if you have any queslions or if you require further amplification on 

any of the issues I have outlined above. 

P.4 

c 

Thank you for your assistance. 

Sincerely, 

I «***rdd.^W f< /«=: 

Paul M. (Monty) Felix 

President/CEO