OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

76) ll-C-102 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:30 PM Sheet 76 of 343 

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l~l PACIFIC ENVIRONMENTAL SERVICES, INC. 

M-C-/02 

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. Jim Kutzli 

Bathcraft Incorporated 

Via Facsimile @(912) 245-0994 

Dear Mr. Kutzli: 

September 2,1998 

I spoke with you this morning to obtain information about the costs associated with changing 

to a vapor suppressed resin. As I explained on the telephone, the EPA has been and still is collecting 

infonnation about the costs associated with implementing a standard limiting the emissions of 

hazardous air pollutants (HAP) from facilities in the pl^tic composites industry. This information 

is currently being used in the standards development process pursuant to Section 112 of the Clean 

Air Act (CAA), as amended in 1990. The CAA requires that the EPA establish emission standards 

for all major sources of HAP that reflect maximum achievable control technology. 

Per your request (during our telephone conversation) 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 1, PES has been designated an "authorized representative" ofthe Agency. 

t 

The contact report in enclosure 2 is designed to give you the opportunity to verify the 

infonnation given over the telephone. Please change any information I may have recorded 

inaccurately. 

If you have any questions concerning this request, please do not hesitate to c^l me at (919) 

941-0333 or the EPA task order project officer, Ms. Madeleine Strum, at (919) 541-2383. Thank 

you for your cooperation. 

Sincerely, 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Shawn McKee 

2 Enclosures 

cc: PES Project File 

Ms. Madeleine Strum, US EPA 

WASHINGTON. D.C. • RESEARCH TRIANGLE PARK, NC • LOS ANGELES, CA • CINCINNATI, OH 

JL 
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Enclosure i , 

/ *1 \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

| _\_§S_7 ? RESEARCH TRIANGLE PARK. NC 27711 

^"X* * OFHCEOF 

AIR QUAUTY itANNWG 

ANO 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. 7S11 (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) (l), and sample any emissions that the owner or operator of 

such source is required to sample. 

Authorized Representatives of the Administrator axe 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 01928 

Designation Expires: September 30, 2001 

S. Seit sitz z '<_/ 

Director 

Office of Air Quality Planning 

and Standards 

2, 
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From: 

Date: 

Contact: 

Enclosure 2 

Contact Report 

Melanie Proctor, Pacific Environmental Services, Inc. (PES) 

September^ 1998 

Mr. Jim Kutzli 

Company: Bathcraft Incorporated 

Telephone Number: (912) 333-0805 

Fax Number: (912) 245-0994 

Contact Summary: 

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

potential indirect costs associated with implementing the usage of a vapor suppressant. In 

response to my questions Mr. Kutzli indicated the following: 

For Bathcraft Incorporated, using a vapor suppressed resin (VSR) adds slight addition to 

the cost of materials above that of a non-suppressed resin. Bathcraft Incorporated uses a wax 

suppressant. Fillers are also added to the resin, and act as additional vapor suppressants. 

No additional training was necessary for employees. Bathcraft Incorporated did 

experience a number of production problems over a several year period after beginning to use the 

VSR. The total cost ofthe production problems was approximately $10,000, which included 

rework, labor, and scrap. 

INFORMATION IS ACCURATE 

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