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OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

J/ 

J$6) ll-E-190 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:11AM Sheet 230 of 264 
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Contact Report 

From: Madeleine Strum, U.S. Environmental Protection Agency 

Melanie Proctor / Robert Jemison, Pacific Environmental Services, Inc. 

Date: 

Contact: 

Company: 

October 6,1998 

Mr. Larry Burroughs 

Hydro Systems, Inc. 

Telephone Number: (805)584-9990 

Fax Number: (805) 584-8125 

EPA AIR DOCKET 

Contact Summary: 

Ms. Strum, Ms. Proctor, and Mr. Jemison asked Mr. Burroughs questions concerning the 

Hydro Systems, Inc. facility located in Simi Valley, CA. In response to these questions Mr. 

Burroughs indicated the following: 

The facility manufactures tubs and whirlpool baths. The facility employs approximately 65 

people and is not owned by another company or corporation (the facility is family owned). The 

facility operates for two shifts during a normal workday. The first shift is the normal production 

shift. The second shift is used to prepare molds and equipment for the first shift that will occur on 

the following day. 

Regular Production 

The facility uses spray-up to apply approximately 250,000 lbs per year of polyester resin in 

the fabrication of its products. The resin is filled with a lightweight filler blend (>50% by weight) 

and contains a vapor suppressant. The resin is appUed in a spray booth that is vented to a carbon 

adsorption system. Mr. Burroughs agreed to supply Ae actual resin usage for the 1997 calender year 

and the MSDS for the polyester resin used to fabricate the facility's products. 

The facility uses spray-up to apply approximately 20,000 lbs per year of polyester gel coat 

in the fabrication of its products. The amount of gel coat used by the iacility is decreasing as the 

facility is replacing its use of gel coats with acrylic sheet. The gel coat is applied in a spray booth 

thai is vented to a carbon adsorption system. The color of the gel coat applied by the facility is 

dependent on the product specification. Mr. Burroughs agreed to supply the actual gel coat usage 

for the 1997 calender year and the MSDS for the two most common pigmented gel coats used by the 

facility. 

Mold Manufacturing 

The facility uses hand lay-up (bucket and brush) to apply an unfilled, isophthalic resin in the 

fabrication of molds used by the facility. The facility also applies a tooling gel coat in the fabrication 

ofthe molds. Mr. Burroughs agreed to supply the actual tooling resin and gel coat usage for the 

1997 calender year and the MSDS for thg resiij^nd gel coat used to fabricate the facility's molds. 

INFORMATION IS ACCURATE' MUACU ii-ea-qg . 
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Contact Report 

Mr. Larry Burroughs 

October 6,1998 

Page Two 

Carbon Adsorption Svstem 

All of the resin and gel coat is applied in three separate spray booths that vent directly to 

three separate carbon adsorption devices (activated carbon panels). The gel coat booth is completely 

enclosed but the other two are open on three sides. The facility monitors the exhaust from the outlet 

of each carbon adsorption system for reactive organic compounds (ROC) using a HNU model PI 101 

photo ionization detector (PID). This monitoring is done once per shift and is for the purpose of 

ensuring that the activated carbon panels are not saturated. The activated carbon panels are 

considered saturated if the ROC level read by the PID is greater than 3.0 ppmv. 

When the carbon adsorption systems were first installed, the facility would have lo change 

the carbon filters approximately every two wfceks. This rate of carbon filter replacement is no longer 

necessary due to the following fectors: the reduction of the gel time ofthe resin from 8-10 minutes 

to 4-6 minutes, the gradual replacement of gel coat* application with the use of acrylic sheet, the 

change from an aluminum trihydrate based filler to a lightweight filler blend, the increase in filler 

loading from 36% to the current level of >50%, and improved airflow management. In other words, 

the facility has reduced the ROC loading to each ofthe carbon adsorption systems and as a result no 

longer has to change the carbon filters at such a frequent rate. 

The facility has not done EPA reference method testing at the inlet and outiet of the carbon 

adsorption devices to determine the overall level of control efficiency. The facility also has not 

conducted an emissions test using EPA Reference Method 25 A on the exhaust outlets ofthe carbon 

adsorption systems. However, in addition to the monitoring of the exhaust outlets discussed 

previously, the facility also uses the PID to monitor the ROC concentration in the shop including the 

areas where the chopper guns are used. If the ROC concentration detected is greater than 20 ppmv, 

the facility takes action to determine why the ROC concentration has reached this level. For 

example, this action would include checking the exhaust system fans to ensure that all fans are 

operational. 

INFORMATION IS ACCURATEwO^AJjCO ^J&dj U Qjjrfe ^ 1 \ - ? ^ - S £ 

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Hydro Systems FAX message 

50 Moreland Road, Simi Vallev. CA 93065 (805) 584-9990 FAX (805) 584-8125 

Date: Tuesday, November 24, 1998 

To: Robert M. Jemison @ Pacific Environmental Serv. (919) 941-0234 

From: Larry Burroughs 

Re: Contact Report 

Number of pages including this one: 3 

The two page Contact Report follows. I have signed both pages. I will send you 

the information on actual amounts of materials used and the MSDSs you 

requested in the mail. 

Please don't hesitate to call me if you have any questions. 

Regards, 

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