p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

21) ll-B-16 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:11 AM Sheet 21 of 57 
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NON-CBI SITE VISIT REPORT 

TO: Project File 

Reinforced Plastic Composites NESHAP 

FROM: Melanie Proctor 

Pacific Environmental Services, Inc. (PES) 

DATE: August 14,1997 

SUBJECT: Site Visit - LASCO Panel Products, Florence, KY 

EPA Contract 68D10116, ESD Project 93/58 

PES Project N504 

.A-94-52 

1 x'*-l$ 

I. PWEPSe 

The purpose of this visit was to gain a better understanding of LASCO's wet area 

enclosure (WAE) and to discuss possible emission test scenarios to determine emissions firom 

continuous lamination operations. The visit was intended to identify emission test scenarios that 

would help to evaluate the effectiveness of WAEs on continuous lamination lines and determine 

the effect of process variables such as line speed, product thickness, styrene content, use of 

methyl methacrylate (MMA), and use of gel coat in continuous lamination operations. 

II. Place eg j P#g 

LASCO Panel Products 

8015 Dixon Drive 

Florence, Kentucky 41042 

September 11,1996 

III. PartjcipfflitS 

Kentucky Environmental Protection Agencv 

Mr. John Allen, phone number (606) 292-6411 

LASCO Pimel Product? 

Ms. Hilary North, Manager of Health, Safety and Environmental Quality 

Mr. Bruce Westbrook, Vice President of Engineering 
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LASCO Site Visit 

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PES 

Dr. Kenneth Meardon, Senior Environmental Scientist 

Ms. Melanie Proctor, Environmental Scientist 

Society of Plastics Industry/Composites Institute 

Mr. John Schweitzer, Technical Director 

U. S. Environmental Protection Agency (EPA) 

Dr. Madeleine Strum, Project Manager 

IV. General Facilitv Infonnation 

LASCO Panel Products and LASCO Bathware are divisions of Tomkins Industries, 

which is a publicly owned, 14 billion dollar holding company. Tomkins Industries owns a large 

variety of companies, including Smith and Weston Firearms, Dexter .Axles, Redwing Food, 

Gates Rubber, Interstate Bakeries, and Murray Bicycles. The U. S. headquarters for Tomkins 

Industries are located in Dayton, Ohio. Since Tomkins Industries is publicly owned, the 

company prepares an annual stockholder report, which contains annual sales information. Based 

on information from Mr. Westbrook, Tomkins' annual sales information is also available on the 

Internet. 

V. Wide Continuous Lamination Line 

LASCO has one wide continuous lamination line. CBI material deleted. Some sections 

of the enclosure are vented to ductwork connected to a stack which exhausts to the atmosphere. 

A diagram showing LASCO's wide line with the partial WAE (not including the gel coating 

section) and dimensions of openings in the enclosure is presented in Attachment 1. 

CBI material deleted. The resin application area is enclosed by an (CBI material 

deleted) enclosure, which has two emission pick up points that are vented to the atmosphere. 

The enclosure has an opening that is 3/4 inches tall at the beginning and 1-inch tall at the end of 

the enclosure to allow material to enter and exit the enclosure. The resin application enclosure 

also has openings at both sides ofthe enclosure that are about 12 inches tall and 12 inches wide 

to adjust the doctor bar. Ms. North explained that the openings to adjust the doctor bar could 

easily be closed. CBI material deleted. 

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LASCO Site Visit 

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Following the resin application enclosure is a (CBI material deleted) section ofthe line 

that is not enclosed. In this uncovered section, woven reinforcement can be applied to certain 

product lines. During the site visit, an approximately 1 foot wide woven material was being 

applied to both edges ofthe product. According to Ms. North, LASCO does not have any plans 

to enclose this section ofthe line. 

After the woven reinforcement is applied, another portion ofthe enclosure begins, which 

encloses the chopped glass application area. The enclosure for this section ofthe process is 

approximately 4 feet long and does not have ducts to vent emissions to the atmosphere. CBI 

material deleted. The chopped glass application enclosure has an opening that is 1-inch tall at 

the beginning and the end ofthe enclosure to allow material to enter and exit the enclosure. 

Rolls of fiberglass roving are located outside the enclosure. The fiberglass strands are fed into 

the enclosure to a cutting blade that chops the reinforcement into fine pieces. No air is pulled 

into or out ofthe enclosure where the chopped fiber is applied. 

CBI material deleted. 

The section ofthe continuous lamination line following the chopped glass application 

enclosure is currently not enclosed, but based on Ms. North's information an enclosure for this 

(CBI material deleted) section has already been designed and is currently being fabricated. 

LASCO expects to install this portion ofthe enclosure sometime next year. An overhead 

walkway crosses the continuous lamination line at the beginning and at the end of this open 

section ofthe line. Each walkway is approximately 30 inches wide. 

The wide line has a second chopped glass application area, after the second walkway 

crosses the continuous lamination line. This second chopped glass application area is also 

enclosed (CBI material deleted). However, the second glass chopper has a smaller supply of 

glass roving and is used to produce product only about 5 percent ofthe time. The first glass 

chopper is not used when the second glass chopper is used. 

CBI material deleted. The blowers are located toward the end ofthe approximately 

4-foot long enclosure for the second chopped glass application area. 

CBI material deleted. This section has two emission pick up points close to the sides of 

the enclosure (CBI material deleted). The emissions from this portion ofthe process are vented 

to the atmosphere through the same central duct as the other enclosure pickup points. 

CBI material deleted. Gel coat is only applied to a small portion of products such as 

RV skin, which are panels used for recreational vehicles. CBI material deleted. 

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LASCO Site Visit 

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The gel coating section is (CBI material deleted) enclosed at the top and the sides. Four 

emission pick up points (two at each end ofthe enclosure) vent emissions from the gel coating 

enclosure to the atmosphere through the same central duct as the other enclosure pickup points. 

CBI material deleted. After the gel coated top film leaves the (CBI material deleted) 

enclosure, it moves down through an open vertical section (CBI material deleted). 

The wide line was added in 1994 and is located in a newly constructed section ofthe 

facility. Tlie wet area and the oven ofthe wide line are in two separate rooms that connect 

through an approximately 3-foot tall and 10-foot wide opening. Both rooms are also connected 

with each other, and to the rest ofthe facility, by fire doors, which are kept open for better access 

and to move materials back and forth. According to Ms. North, the fire doors can be closed and 

the opening between the room for the wet area and room for the oven can be made smaller for 

emissions testing to turn the wide line wet area room into a temporary total enclosure. The wet 

area room ofthe wide line has its own ventilation system containing two ducts for make-up air, 

one duct for outlet air, and emission pick up points in parts ofthe enclosure. 

As indicated previously, the air from the emission pick up points in the enclosure is 

vented to one central duct with a (CBI material deleted) fan. Ms. North contacted the vendor of 

the ventilation system to determine the air flow at each emission pick up point. The vendor was 

unable to provide that information (CBI material deleted). 

The products produced at the wide line (CBI material deleted) include products such as 

liner board, truck trailer liner, door skins, and RV skins. CBI material deleted. 

CBI material deleted. 

VI. Nanow Continuous Lamination Lines 

LASCO has two narrow continuous lamination lines that allow the production ofa panel 

(CBI material deleted). These two nanow lines were installed in 1967. CBI material deleted. 

However, Ms. North explained that the top and bottom gel coating section are never run at the 

same time. The lamination table of both narrow lines is subdivided into (CBI material deleted) 

heating zones (CBI material deleted). One ofthe nanow lines is used to run both corrugated 

and flat products, while the other narrow line only produces flat products. Both nanow lines use 

compaction rollers. CBI material deleted. 

The narrow flat line is located in a separate room connected to the rest ofthe facility by 

fire doors, which are kept open for material transfer. Similar to the wide line described earlier, 

the narrow flat line has (CBI material deleted) places where chopped reinforcement can be 

applied. CBI material deleted. 

i 
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LASCO Site Visit 

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CBI material deleted. During the site visit, the narrow corrugated line was producing a 

panel with a top gel coat layer. The gel coat layer applied to the film is very thin and due to the 

heat applied in the gel coating section, a large portion ofthe monomer in the gel coat is assumed 

to evaporate. CBI material deleted. 

VII. Ovens for the Continuous Lamination Lines 

LASCO's ovens for the continuous lamination lines are heated by (CBI material 

deleted) direct gas fired burners. The temperature ofthe ovens is variable and ranges (CBI 

material deleted) depending on the line and the product that is being produced. CBI material 

deleted. 

VIII. Resin Mix Area 

Ms. North pointed out that resin mix area, which is currently in the same room as the 

narrow corrugated line, is being redesigned (CBI material deleted). The new mixers will be 

located in a separate mix room. Presently, the resin that is stored in underground storage tanks is 

pumped through lines into the resin mix area into (CBI material deleted) containers. The 

pigment is dissolved in resin and received in 55 gallon drums. The drums are moved into the 

mix area by fork lifts and the dissolved pigment is added to the resin mix container. The filler is 

also added to the resin matrix in the mix area. CBI material deleted. During degassing, air is 

removed from the resin mix by agitating the resin mix and by creating a vacuum in the resin 

tank. CBI material deleted. 

IX. Possible Emissions Test Scenarios at LASCO's Wide Line 

The main objectives of emissions testing at LASCO are to determine emission reductions 

achieved by WAE and to determine the effect of process variables such as line speed, product 

thickness, styrene content, MMA content, and the use of gel coat in continuous lamination 

operations. During the site visit, various emission test scenarios were discussed. 

In order to determine the effectiveness ofa total WAE, the sections of LASCO's wet area 

that are currently not enclosed would have to be enclosed for testing purposes and the emission 

pick up points that are cunently vented to the atmosphere would have to be closed off. Ms. 

North thought that the plant could design arid construct such a temporary WAE for testing 

purposes. Mr. Schweitzer wondered if the current ventilation system may increase emissions and 

suggested that the test for the baseline case should be conducted without operating the current 

ventilation system. Ms. Strum added that, in the pultrusion study, the WAE-exhaust scenario 

showed a decrease in emissions over the baseline and this may be the case here as well. Ms. 

Strum agreed that the test program should investigate this scenario. Thus, an emission test would 

also have to be conducted with as much ofthe WAE removed or opened as possible. In order to 

evaluate the possible range of emission reductions achieved by the WAE, both ofthe above 

S 
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LASCO Site Visit 

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described scenarios, with and without enclosure, would have to be tested for a product with the 

highest expected emissions (highest styrene content, lowest line speed, and thinnest product) and 

the lowest expected emissions (lowest styrene content, highest line speed, and thickest product). 

The effects of process variables on emissions firom continuous lamination operations can 

be examined by testing LASCO's current partially enclosed process (for ease of testing) and vary 

one process variable at a time. The following test runs to determine the effect of process 

variables were discussed: 

Gel coat versus no gel coat 

MMA versus no MMA 

Thick panel versus thin panel 

Slow line speed versus fast line speed 

Low HAP versus high HAP resin 

Ms. North promised to discuss these proposed test scenarios with her management to 

determine if and to what extent testing can be done at LASCO to minimize the effects on 

production. Ms. North also promised to provide the EPA with a complete list of LASCO's 

products produced at the wide line containing information on the relative amount of each product 

produced, styrene content, MMA content, line speed, product thickness, and gel coat usage. This 

list of products and process infonnation for each product will help the EPA to determine which 

product runs should be selected for testing. 

X. Action Items 

LASCO promised to provide the EPA with the following information: 

1) Annual resin and gel coat usage for the entire facility for 1995. Please refer to the letter 

mailed to you on September 20,1996 for a better description of the information 

requested. (Received) 

2) The weight percent HAP content of each resin and gel coat matrix used, including HAP 

added at LASCO. The weight percent of HAP (e.g., styrene, MMA) of each resin/gel 

coat matrix is defined as the total amount (lbs) of HAP (styrene, MMA) in the resin/gel 

coat as supplied plus the amount of HAP (styrene, MMA) that is added to the supplied 

resin/gel coat by the facility divided by the weight ofthe resin/gel coat matrix. The 

resin/gel coat matrix only includes the resin/gel coat itself, the HAP (styrene, MMA) that 

is in the supplied resin/gel coat, and HAP (styrene, MMA) that is added to the supplied 

resin/gel coat by the facility. Filler, catalyst, promoters, reinforcement, and other 

additives are not included in the resin/gel coat matrix definition. The following equations 

show the calculations for determining the weight percent of styrene and MMA in a 

resin/gel coat matrix. 

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LASCO Site Visit 

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. . .. Total Amount of Styrene ,--. , 

% Styrene in Resin/gel coat Matrix = — X 100% 

(Total Amount of Resin) * (Total Amount of Styrene and MMA) 

m. ..... . -. • i i w _., Total Amount of MMA „ ..... 

% MMA in Resinlgelcoat Matrix = - X 100% 

(Total Amount of Resin) * (Total Amount of Styrene and MMA) 

This information has been received and further information was collected during a 

visit to LASCO on October 29,1996. 

3) Which HAP is/are in the gel coat used at LASCO? Please verify that LASCO Panel 

Products uses only one gel coat. (Information received. CBI material deleted). 

4) Complete list of LASCO's products produced including all products containing 

information on the amount of each product produced, styrene content, MMA content, line 

speed, product thickness, and resin, gel coat, filler, pigment, and reinforcement usage. 

Please refer to the letter mailed to you on September 20,1996 for a detailed Table ofthe 

information requested. (Collected during a visit to LASCO on October 29,1996). 

7 
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ATTACHMENT 1 IS CBI 

WIDE LINE AND PARTIAL WET AREA ENCLOSURE DIAGRAM 

7 
RECEIVED 

EPA. OAQPS CBIO 

RTP. NC 2771 1 

97AUG II PM2--2-4 

O ld 
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Docket No. A-94-52 

Category II-B 

The following information is located in the confidential files ofthe Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This infonnation is 

confidential pending final detennination by the Administrator and is not available for public 

inspection. 

Changed to CN-N801-2 Site Visit info for Lasco Panel, Florence, KY 

CN-N504-3 

|0 
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Docket No. A-94-52 

Category II-B 

The following information is located in the confidential files ofthe Director, Emission 

Standards Division, Office of Air Quality Planning and Standards, U.S. Environmental 

Protection Agency, Research Triangle Park, North Carolina 27711. This information is 

confidential pending final detennination by the Administrator and is not available for public 

inspection. 

Lasco Panel Products, florence, KY - (This is the Site Visit Material file: changed from CNN504-3 to CN-N801-2) 

1 Site Visit report dated 12/6/96; 10 pages 

CN-N801-2 

ESD 93/58 

K