P.1 

OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

68) ll-C-94 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:29 PM Sheet 68 of 343 
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f~l PACIFIC ENVIROrJMEMTAL SERVICES. INC. 

* 

ft*** 

Sr. 

3

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96 *>/.l9 

June 19,1998 

X7/-c_.-7-y 

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 

Mr. Gary Rodgers 

United Panel Incorporated 

Route 512 and Wildon Terrace 

Mount Bethel, Pennsylvania 18343 

Dear Mr. Rodgers: 

As you know, Pacific Environmental Services, Inc. (PES) is the contractor assisting the 

U.S. Environmental Protection Agency (EPA) in the development of national emission standards 

for hazardous air pollutants (NESHAP) for the reinforced plastic composites source category. I 

contacted you on June 5,1998, in order to update information concerning the continuous 

lamination and continuous casting processes at the Mount Bethel facility. You requested that 

any questions concerning the facility be submitted in writing. Therefore, we are submitting this 

letter to you with the enclosed list of questions concerning the Mount Bethel facility (see 

Enclosure 1). Your responses to tiiese questions will help us in the development of these 

standards. 

For your information, 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 2, 

PES has been designated an "authorized representative" ofthe Agency. 

If any ofthe information you submit in response to the questions in Enclosure 1 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: 

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 infonnation 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. 

WASHINQTON, D.C. • RESEARCH TRIANGLE PAR4C NC • LOS ANQELES. CA • CINCINNATI. OH 

6; 
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Mr. Gary Rodgers 

June 19,1998 

Page 2 

As we are in the midst of trying to finalize analyses for the continuous lamination and 

continuous casting processes, we request your response to this request by July 17,1998. We 

appreciate your assistance in our efforts to develop a standard for your industry. If you have any 

questions concerning the enclosed questions, please do not hesitate to contact me or the EPA task 

order project officer, Dr. Madeleine Strum, at (919) 541-2383. 

Sincerely, 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Kenneth R. Meardon 

Enclosures (2) 

cc: PES Project File 

Madeleine Strum, U.S. EPA 

a 
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ENCLOSURE 1 

Please answer the following questions. 

Question 1. Please provide the mime and address ofthe current legal owner ofthe Mount Bethel, 

Pennsyhrania, facility. 

Name of Legal Owner of Plant: 

Address of Legal Owner of Plant: 

Question 2. Is the Mount Bethel facility a major source under Section 112 of the Clean Air Act? 

Circle one: yes no 

A "major source" is defined, in part, as "any stationary source or group of stationary sources located 

within a contiguous area and under common control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year of 

any combination of hazardous air pollutants." 

Question 3. Does the Mount Bethel facility have a Title V permit? Circle one: yes no 

If yes, please provide a copy ofthe permit. 

Question 4. At the Mount Bethel facility, 

How many continuous lamination lines are there? 

How many continuous casting lines are there? 

Question 5. Have you performed any source testing on the continuous lamination line(s)? 

Circle one: yes no 

If yes, please provide a copy ofthe source test report. 

Question 6. Have you performed .any source testing on the continuous casting line(s)? 

Circle one: yes no 

If yes, please provide a copy ofthe source test report. 

^ > 
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ENCLOSURE 1 (continued) 

Question 7. Have there been any changes to the continuous lamination process that have occurred 

since 1993 (e.g., addition of lines, changes in collection and dispersion of emissions from the line, 

changes in the type of resins used)? 

Circle one: yes no 

If yes, please provide a brief description ofthe changes. Be sure to indicate when the changes have 

taken place. If source testing has taken place (see Question 5), please indicate the relationship ofthe 

source testing to these changes (e.g., the source testing occurred before any of these changes). 

H 
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ENCLOSURE 1 (continued) 

Question 8. Please provide a brief description ofthe continuous casting process. Please be sure to 

include information on the size ofthe wet out area, the area exposed to the atmosphere, and the type of 

ventilation used on or .around the process. 

^ 
P.7 

ENCLOSURE 1 (continued) 

Question 9. Please provide the following information on feedstocks for the most recent complete 

annual year. If you need more space (e.g., four different resin types are used), please copy the 

appropriate pages. Please also identify each type of resin you use (e.g., isophthsdic, flex, general 

purpose, etc.) 

Year: 

Resin Feedstock Example 

Continuous Lamination Process 

Stenni Stennex 

Continuous 

Casting Process 

Resin Usage (tons) 

Resin 1: 

Resin 2: 

Resin 3: 

150 

0 

0 

Weighted Average HAP Content Resin as received (%): 

Resin 1: 

Resin 2: 

Resin 3: 

38.1 

— 

— 

Weighted Average Styrene Content of Resin as received (%) 

Resin 1: 

Resin 2: 

Resin 3: 

25.1 

Weighted Average Methyl Methacrylate Content of Resin as received (%) 

Resin 1: 

Resin 2: 

Resin 3: 

13 

Total Styrene Added to Resin (tons) 

Resin 1: 

Resin 2: 

Resin 3: 

40 

Total MMA Added to Resin (tons) 

Resin 1: 

Resin 2: 

Resin 3: 

10 

//) 
P.8 

ENCLOSURE! (continued) 

Gelcoat Feedstock Example 

Continuous Lamination Process 

Stenni Stennex 

Continuous 

Casting 

Process 

Gelcoat Usage (tons) 

Clear 

Pigmented 

Tooling 

100 

50 

0 

Weighted Average HAP Content of Gelcoat as received (%) 

Clear 

Pigmented 

Tooling 

45 

38 

-

• 

Weighted Average Styrene Content of Gelcoat as received (%) 

Clear 

Pigmented 

Tooling 

38 

30 

-

Weighted Average Methyl Methacrylate Content of Gelcoat as received (%) 

Clear 

Pigmented 

Tooling 

7 

8 

-

Total Styrene Added to Gelcoat (tons) 

Clear 

Pigmented 

Tooling 

10 

5 

-

Total MMA Added to Gelcoat (tons) 

Clear 

Pigmented 

Tooling 

3 

1 

-

n 
P.9 

ENCLOSURE 1 (continued) 

Other Feedstock 

Filler (tons) 

Pigment (tons) 

Reinforcement (tons) 

Initiator (tons) 

Promoter (tons) 

Aggregate (tons) 

Centerstone (tons) 

Inhibitor (tons) 

Other. 

Other 

Other. 

Other. 

Other: 

Other 

Example 

250 

3 

60 

3 

0.5 

400 

400 

0 

Continuous Lamination 

Process 

Stenni Stennex 

Continuous Casting 

Process 

s 
P 10 

Enclosure 2 

*• fl \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

3 RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUAUTY PLANNING 

AND STANDARDS 

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 

under 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 01998 

Designation Expires: September 30, 2001 

S. Seitz 

Director 

Office of Air Quality Planning 

and Standards 

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