p.1 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

^__Tr3)||-E-186 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:11 AM Sheet 226 of 264 
P.2 

DEC-30-98 WED 1:08 PM LASCO BATHWARE FAX NO. 3604583375 ]• 2 

From: 

Date: 

Contact Report 

Shawn McKee, Pacific Environmental Services, Inc. (PES) 

September 2,1998 (Revised by Melanie Proctor, PES, based on Mr. 

Mullin's comments on December 30,1998) 

Contact: Mr. Kevin Mullin 

Company: Lasco Bathware (Tomkins Industries) 

Telephone Number: (360) 458-3900 

Fax Number: (360)458-3375 

Contact Summary: 

Mr. Mullin was contacted on behalf of the U.S. EPA to provide information about potential 

indirect costs associated with changing to a resin with a lower hazardous air pollutant (HAP) 

content, and implementing the usage of a vapor suppressant. Mr, Mullin is the plant manager for 

the Lasco Bathware plant in Yelm, Washington. In response to my questions Mr. Mullin indicated 

the following: 

When the plant began using lower HAP resins in their processes, the costs they incurred for 

raw materials increased approximately 3 percent overall. Changing resins did require testing of the 

products, but all of the testing was done in the corporate laboratories. This testing took an 

estimated 300 to 400 man-hours to complete. The company's resin suppliers also did a great deal 

of testing to expedite the resin change-over process. The plant, however, had a very large number 

of production problems. A total of 13 trials were conducted at a cost of $5,000 each. 

Lower HAP resins do have different material characteristics requiring the technicians 

spraying and laminating the parts to adjust their job performance. Laminators must be more 

cognizant of how their performance effects the quality of the part. Employees did not require any 

additional training beyond what is listed above due to the change. Each of Lasco Bathware's 

products is routinely certified every month, making additional certification due to the resin change 

unnecessary. 

Lasco Bathware's plant in Yelm, Washington also uses wax additives that act as vapor 

suppressants in their resins. Lasco has used vapor suppressants for years, but further testing was 

done on the lower HAP resins. No costs were incurred during the additional trials of the vapor 

suppressants because the test materials were supplied by the vendor. No additional testing of the 

products made with the resin containing vapor suppression additives was necessary. No additional 

training was necessary. Lasco Bathware did have some production problems due to delamination 

of products, but after changing the amount of additive being used, the problems were solved. The 

cost of materials has stayed the same for some processes, and increased by 5%-10% for others. 

INFORMATION IS ACCURATE UuJl^ 
P.3 

DEC-30-98 WED 1:08 PM LASCO BATHWARE FAX NO. 3604583375 P. 1 

LASC O BATHWAR E 

8 0 1 NORTHER N PACIFI C ROA D 

YELM , WASHINGTO N 9859 7 

PHONE:360-458-390 0 OR 800-444-512 6 

FAX:360-4 5 8-337 5 

FACSIMILE TRANSMITTAL SHEET 

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CHWJNI VA 

TROM: 

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COMPANY: DATE: 

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PAXNUMBER CNUMBER: 

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TOTALLNQ^OE^ NQ-PAOE W S INCLUDING COVER: 

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PHONE NUMBER: SENDER'S REFERENCE NUMBER: 

RE: YOUR REFERENCE NUMBER: 

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_TFC 

D URGENT _TFOR REVIEW D PLEASE COMMENT • PLEASE REPLY • PLEASE RECYCLE 

NOTES/COMMENTS: 

LO^ £ 

c^ \J **r 9 ' 

a «a (•£ A—^ Q^* I. 

to 

KEVIN MULLEN 

PLANT MANAGER 

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