p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

14) ll-B-9 

Docket Number: 

A-94-52 

Printed 7/3/2008 7:22:10 AM Sheet 14 of 57 
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13B,1 

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UNITEO STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK. NC 27711 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANOAROS 

I-£-<7 

SEP /I i.f\\ 

Mr. Mike Seymour 

Sr. Director of Process 

Development and Technical Services 

LASCO Bathware 

3255 East Miraloma Avenue 

Anaheim, CA 92806 

35 

-i'-.'-U-". 'i './ » 

^n,.^ '.'•! 

Dear Mr. Seymour: 

Thank you for your comments on the draft trip report sent to 

you on July 6, 1995, and for the updated copy of the emissions 

data attachment. Per your letters transmitting these items, and 

phone conversations with Madeleine Strum, we understand that 

there is no confidential business information contained in these 

documents. 

Enclosed for your records is a copy of the final report 

which was developed based on your comments. If you have any 

questions or additional comments, please contact Madeleine Strum 

at (919) 541-2383. 

Sincerely, 

Linda S. Herring 

Group Leader 

Coatings and Consumer Products Group 

Enclosure 
P.3 

MEMORANDUM 

DATE: August 31. 1995 

SUBJECT: Final Site Visit Report - LASCO Bathware, South Boston, Virginia 

ESD Project No. 93/58 

FROM: Madeleine Strum '*\%S^ 

TO: Project File 

I. Purpose 

To see a large open molding facility in the reinforced plastic composites industry which 

utilizes a thermal oxidizer for reducing styrene emissions on the resin spray up and gelcoat 

processes. 

II. Place. Date and Contact 

LASCO Bathware 

Virginia State Highway 931 

Halifax County Industrial Park 

P.O. Box 1177 

South Boston, Virginia 24592-1177 

Telephone: (804) 572-1200 Anaheim Office: (714) 993 1220 

Fax: (804)572-2067 Fax: (714)524-8784 

DATE: June 22, 1995, 10:00am - 2:30pm 

CONTACT: Mike Seymour, LASCO Bathware (Anaheim Office) 

III. Attendees 

Salahudin Bin-Yusif, Summer Intern, U.S. Environmental Protection Agency (EPA) 
P.4 

Daniel Boyd, Consultant to Lasco Bathware, Daniel P. Boyd and Company 

Curtis Demuth, Senior Environmental Inspector, Department of Environmental Quality, 

Commonwealth of Virginia 

Wanita Dunston, Summer Intern, U.S. EPA 

Scott Hartman, Plant Manager, LASCO Bathware 

Norman Kaplan, Chemical Engineer, U.S. EPA 

Stephen McNally, Director of Government Affairs, Composite Fabricator's Association (CFA) 

Carlos Nunez, Chemical Engineer, U.S. EPA 

Mike Seymour, Sr. Director of Process Development and Technical Services, LASCO Bathware 

John Schweitzer, Technical Director, Composites Institute 

Madeleine Strum, Environmental Engineer, U.S. EPA 

Attachment 1 contains a copy ofthe business cards of those persons who are not from EPA. 

IV. Discussion 

Information on plant emissions and emission controls is provided in Attachment 2, which 

is an updated version (sent by Mike Seymour on July 7) from that originally provided by LASCO 

Bathware before the site visit. This is discussed in more detai in Section V. 

The visit began with a general discussion ofthe LASCO Bathware company. The 

company operates eight facilities throughout the country - (1) Elizabeth Town, Pennsylvania; (2) 

Lancaster, Texas; (3) South Boston, Virginia; (4) Yelm, Washington; (5) Moapa, Nevada; (6) 

Anaheim, California; (7) Three Rivers, Michigan, and (8) Cordele, Georgia. Three ofthe facilities 

operate an incinerator (thermal oxidizer)—Tex^, Virginia and Pennsylvania. The South Boston, 

Virginia and Yelm, Washington plants have a full capacity production line; that is, they 

manufacture the full line of LASCO Bathware products. The 280 employees at the South Boston 

plant include 37 truck drivers. Other U.S. companies that produce the same type products and 

are of similar magnitude of production include AquaGlass, Carolina Classics and Jacuzzi. 

The plant currently operates two distinct product lines and is planning to add a third line. 

The two lines are: (1) gelcoat surfaced products (to be abbreviated GS line) and (2) acrylic 

surfaced products (to be abbreviated AS line). The third line will be the manufacture of acrylic 

surfaced jetted bathtubs. The GS line produces 400 units per day, 200 units per shift. There are 

two shifts (eight hours each) per day. The AS line produces 160 units per day, operating one shift 

(eight hours) per day. The plant operates five days per week, 50 weeks per year. 

The first operation viewed was the acrylic surface line thermo-forming process which 

produces the plastic shell, or surface layer, for the unitized (one piece) tub/showers. The process 

input is a flat rectangular thermoplastic sheet (manufactured by ICI Chemical Company). The 

sheet is directed into an oven where it is softened and automatically placed on the mold. The 

mold closes, a vacuum is pulled, and a fragile shell (unitized tub/shower unit) is lifted from the 

mold. No mold release is necessaiy for this process. It is presumed that there are no hazardous 
P.5 

air pollutants (HAP) emitted from this process. 

The acrylic thermoplastic surface layer is an alternative to the gelcoated surface layer. The 

acrylic layer is more durable and is able to retain its gloss over the conventional gelcoated surface. 

LASCO indicated that in the U.S. about 80% of tub/showers are made using a gelcoated surface 

as opposed to an acrylic surface, while in Europe the percentage is 10% gelcoat, 90% acrylic. 

The cost to produce an acrylic surfaced fiber reinforced part is approximately double that of its 

counterpart gelcoat surfaced part. One reason is that the raw material (acrylic sheet) is much 

more expensive than gelcoat. The cost to the consumer for the part is more than double. The 

acrylic surfaced part is easier for the consumer to maintain, in part because the surface layer is 

thicker than the gelcoat surfaced part (45 mils as opposed to 15 mils of gelcoat) and, is virtually 

non-porous. 

Madeleine indicated that the manufacture of acrylic surfaced products can be considered a 

a source reduction (pollution prevention) measure over the manufacture of conventional gelcoat 

surfaced products because it involves both raw material and process changes which eliminate the 

use of gelcoat, a source of styrene emissions. The industry trade groups questioned this, since 

the gelcoat surfaced product is different from the acrylic surfaced product. Madeleine indicated 

that because the baseline for the industry is the manufacture ofthe GS products, the change from 

GS to AS may be considered source reduction. If the emission limits were to be posed in the 

units of quantity of styrene emitted per some unit of production, the AS would certainly provide 

credit as an emission reduction alternative. 

The next processes viewed were the resin spray up processes ofthe AS line and the 

gelcoat and resin spray up processes of the GS line. A schematic ofthe location ofthe processes 

and the associated exhaust stacks is provided in Attachment 3. All spraying of resin, chop and 

gelcoat is done in spray booths except for repair and touch up, which is done off-line. The air 

temperature in the spray booths and booth area is (at a minimum) 85 degrees Fahrenheit (F). In 

the winter, it is necessary to heat the air to reach this temperature. In the summer, the gelcoat and 

resin spray up lines operate with air temperatures in excess of 85 F (with no heating necessary). 

We first viewed the part ofthe AS line in which the resin/chop was sprayed onto the 

acrylic shell. .All emissions from this process are vented to the atmosphere (through stacks on the 

roof). The acrylic frames are manually placed on hangers on a mechanized overhead conveyer 

line. The piece is directed through the first spray booth where the first laminate (resin/chopped 

glass) is applied. The operator does not begin spraying until the part is in the middle section of 

the spray booth. A second operator rolls out the laminate (eliminating the air bubbles), and as the 

piece loops around the line on the conveyer, the laminate cures. When the piece enters the second 

AS line spray booth, a second laminate is applied. The chopper guns on the AS line are all airless 

air assist external mix spray guns. 

The two AS line resin spray booths are identical, and are back-to-back. Thus, the booths 

share common exhaust stacks. As shown in attachment 3, each is 72 feet long, with a 24-foot 
P.6 

pre-booth section, a 24-foot middle (where the spraying takes place) section, and a 24-foot 

section where roll out takes place. Each of these three sections has its own exhaust stack. Each 

ofthe three exhaust stacks is directed to the top ofthe roof to atmosphere. The spray booth is 

open on two ends (to allow the conveyer to go through). One "wall" ofthe spray booth consists 

of a long filter that collects the particulate/chopped glass overspray. The other wall ofthe spray 

booth is composed of a set of four interconnected systems of narrow vents (about three feet high) 

that exhaust fresh make up air into the spray booth. The operator was, in general, one and a half 

to three feet from the part while spraying, but did get as far as four feet away from the part. After 

roll out, the part continues on the conveyer, curing while on route to the second spray booth. 

Between 8000 to 12000 cubic feet per minute (cfin) air moves through each exhaust stack. 

Because one exhaust stack serves two booths, between 4000 to 6000 cfin air moves through 

each 24-foot section of each spray booth. The following schematic ofa cross section of one of 

the 24-foot sections displays the air flow design: 

Fresh air 

! • > 

* 

To roof exhaust stack 

8000-120,00cfm 

A 

A ^ 

< 

Fresh air 
P.7 

The face velocity of air over the part, (based on a 3-foot height, 24-foot width) ranges from 56 to 

83 feet per minute. 

Vapor suppressed resins are not used on this line (correction to Attachment 2 which 

indicates all resins used are vapor suppressed). They are not used because the first laminate 

would not bond to the acrylic surface (which is smooth). Vapor suppressed resins are not used 

for the second laminate due to the need for separate mixing and pumping equipment. 

We next toured the GS conveyorized line. .All spray guns on this line are airless (external 

mix). All resins used are vapor suppressed. There is no secondary bonding problem, as the chop 

and filler, in combination with the heated surface layer, provides sufficient bonding conditions. 

Madeleine noted that the preliminary results from the Research Triangle Institute (RTI) testing of 

vapor suppressed resins indicated that they reduce emissions by approximately 40%. It is not 

clear if the results of these tests are transferrable to LASCO's facility considering the fact that the 

experiments were done with non-filled resins and at a much lower temperature than that at the 

LASCO facility. Furthermore, it appears that vapor suppressents work differently with different 

resins, and it is not clear that the resin tested by RTI was the same as that used by LASCO. 

There are four spray booths on the GS line (gelcoat, barrier coat, first and second 

laminate). The third laminate is applied in the same booth as the second laminate. The first and 

second laminate booths are identical to those ofthe AS line (72 feet long with three distinct 24 

foot sections, and configured back-to-back), with the exception that the middle section ofthe GS 

booths are vented to the thermal oxidizer. The gelcoat spray booth is 34 foot long, with no 

distinct sections. .All spray emissions from the gelcoat booth are directed to the thermal oxidizer. 

The barrier coat spray booth also has no distinct sections. Emissions from the barrier coat spray 

booth are exhausted to atmosphere. The curing emissions, which are likely small relative to the 

spray emissions (especially for the vapor suppressed resins), take place after the mold leaves the 

middle section ofthe spray booth. It is presumed that, for the resin spray up booths, most of » 

these emissions are exhausted directly to the atmosphere through the roll-out area stack. 

We viewed an operator spraying a white gelcoat onto a mold. Because the mold was 

slightly higher than the operator, the spray gun had to be directed horizontally to the surface to 

reach the top surface ofthe mold (as opposed to the operator standing above the mold and 

pointing the gun perpendicular to the mold). We also viewed the addition of various 

reinforcements (plywood, balsa wood, corrugated paper) to the first and second laminate layers. 

. Mr. Seymour noted that the room containing the spray booths is at negative pressure 

with respect to the outside, and that even with the make up air vents, about 1000 cubic feet per 

minute (cfm) of air is being pulled into the room through doors. 
P.8 

The next part ofthe tour was the thermal oxidizer which is located outside the building. 

There was no detectible odor outside ofthe facility (and we were only about 100 feet or so from 

the stacks on the plant roof which were exhausting emissions which did not pass through the 

thermal oxidizer.) The thermal oxidizer is made by Reeco and is rated for 95 to 99% efficiency. 

The plant uses 95% for its calculations. The thermal oxidizer was running at 1421 degrees 

Fahrenheit (F). It idles at 1000 F. The oxidizer is ofthe regenerative type (ceramic beads). The 

oxidizer has been in operation since plant start-up in 1986. It has needed maintenance, such as 

replacement of some valves. The incinerator at the LASCO Bathware Texas facility, also a Reeco 

regenerative type, needs to be replaced. (It has had a 10-year equipment life.) 

The flow rate through the thermal oxidizer is 17,000 cubic feet per minute (cfm). Based 

on a 77.34 lbs styrene per hour rate to the oxidizer (provided in Attachment 2) and an air 

temperature of 90 F, the concentration of styrene in the air directed to the thermal oxidizer is 

approximately 290 ppm (Note: the molecular weight of styrene is 104.14 grams per mote). This 

calculation is presented in Section IV of this report. The oxidizer inlet/outlet concentrations were 

never tested at the LASCO South Boston Plant. Results on destruction efficiency from the 

LASCO Lancaster Texas plant were used to estimate these, since this plant is identical to the 

South Boston plant. 

The next part ofthe tour was the pump room. The two "day tanks" in the pump room, 

which supply resin to the spray guns, are vented to the thermal oxidizer. The mixers, in which 

fillers were added to the resin, are vented to a dust collector, but not to the thermal oxidizer. This 

is a correction to the attachment, which initially indicated the mixing tanks were vented to the 

thermal oxidizer. 

The final part ofthe tour was gelcoat and resin storage room. Gelcoat is delivered to the 

spray guns straight from the drums. The resin is stored in tanks. There are two 5000 gallon tanks 

and three 10,000 gallon tanks; they are all vented to the thermal oxidizer. 

After the tour there was additional discussion ofthe LASCO Bathware operation. It was 

noted that LASCO had a relatively high tech process as compared to other operations that 

produced tub/showers. It was believed that the operation was also the most efficient in terms of 

time to produce the product. .An entire GS product takes only 120 minutes (from gelcoat spray to 

third laminate application). Each spray application takes between one to two and a half minutes; 

thus, the four spray applications take about ten minutes, and the time in between operations is 

about 110 minutes. 

With regard to comparing emissions from the AS to the GS lines, it was noted that before 

control, the AS styrene emissions were 22.82 pounds (lbs) per hour as compared with 105 lbs per 

hour from the GS line, and the GS line produces about twice as much. Later, that 22.82 lbs per 

hour was qualified as being a value from another plant, and that emissions were 22.82 lbs / hr 

divided by 663 square foot per hour = 0.0344 lbs per square foot. Based on the yearly square 

footage produced at the South Boston Plant, emisisons were about 127 lbs per hour. For the GS 
P.9 

line, emissions per hour are larger, but the square footage is considerably less. It was noted that 

ofthe 105 lbs per hour approximately 24 lbs per hour is attributed to the gelcoat operation. 

Because LASCO keeps track ofthe square footage of product, they can calculate their 

emissions per square foot. As provided in Attachment 2, LASCO produces 7,312,713 sq ft per 

year for the gelcoat surfaced production line and 7.385,197 sq ft per year for the acrylic surfaced 

production line. 

Dan Boyd presented information regarding styrene and the occupational exposure to 

styrene at the LASCO facility. (This is contained in attachment 4). 

IV Emissions/ Emission Reduction calculations 

Emission calculations and additional data on the resin/ gelcoat materials used are provided 

in Attachment 2. They are based on emissions testing which was performed on an identical plant 

in 1984 using Method 25. Mike Seymour provided a copy of this test report, which is in our 

Confidential Business Information office. 

Calculation of concentration of styrene at the inlet ofthe thermal oxidizer 

77.34 lbs/hr * lmin/17,000 ft1 * lftV2.83E-2mJ * lhr/60min * 454 g/lb = 1.2164 g/mJ 

1.2164 g/mJ * (82.06 cm3 atm/ mol K) *(305 K/1.0 atm)*(l mol/104.14 g) = 292 cmVrn3 = 

292ppm 

Calculation of emission reduction due to thermal oxidizer: 

Given (Attachment 2): 

Total styrene emissions per year = 125,572.9 + 254,305.3 = 379,878.2 pounds/ yr 

And, from the non- incinerated booths = 111,145.2 + 254,305.3 = 365,450.5 pounds/yr 

Based on a 95% reduction of emissions for the incinerated (oxidized) emission points, the overall 

emission reduction achieved by using the thermal oxidizer is 100% - 100%*[379,878/(365,450 + 

14,427/0.05)] = 42%. 

The amount of styrene destroyed is: 14,427/0.05 = 288,540 lbs/year = 144.27 tons per year. 

Calculation of emission reduction due to thermal oxidizer and use of vapor suppressed resins on 

GS line 

Assume that vapor suppressed resins achieve a 40% reduction over non suppressed. 

Assume 65% ofthe incinerated emissions are from the gelcoat (which is not suppressed), and 
P.10 

35% are from the laminating resin 

100% -100%*{379,878/[(1 ll,145.2/.6) +254305.3 +(.35)*(14,427/0.05/.6)+ 

(.65)*(14427/0.05)] } = 52% 

Calculation of emissions per unit of raw material used:. 

GELCOAT: Based on a gelcoat emission rate of 24 pounds per hour, 4000 hrs per year of 

operation, and a 95% overall gelcoat control efficiency, the emissions in lbs styrene per lb gelcoat 

used is: 24 lbs/hr * 0.05 * 4000 hrs/yr *(l/958,279 lbs gelcoat) = 0.005 lbs per lb. 

RESIN: Emissions from resins on the AS line are 254,305 lbs per year. Emissions from resins on 

the GS line are based on a before thermal oxidizer styrene emission rate 14,427/0.05 = 288540 lbs 

per year from laminating resin and gelcoat. Of that, 24*4000 lbs/year is gelcoat, which leaves 

laminating resin emissions (befor the thermal oxidizer) at 192540 lbs per year. Laminating 

emissions after the thermal oxidizer are 9627 lbs per year. Total resin emisisons are then 

111,145.2 + 9627 + 254,305 = 375077 lbs per year. Thus, 

{375077 lbs styrene/yr} * [l/(5,540,373)lbs resin/yr] = 0.068 lbs styrene per pound resin 

(unfilled) used. 

TOTAL: On a total resin/gelcoat material usage basis, emissions are: 

379,8781bs styrene /(5,540,373+958279) = 0.058 lbs styrene per lb resin+gelcoat 

Calculation of emissions per unit of production: 

Based on a production rate of 7,312,713 sq ft per year (GS) plus 7,385,197 sq ft per year (AS) = 

14,697,910, and a total emissions of 379,878.2 pounds/ yr, 0.026 lbs of styrene per square foot 

(109 g/m2) are emitted. 
P.11 

iT/tfeff/V^T I 

Composites •**703-524-3332 

H f Fabricators r*703-524-2W 

r& rAssociation 

Stephen McNally 

Dinctor d Government Main 

1735 North lynn Street. Suite 950. Arlington. Virginia 22209-2022 

John Schweitzer 

Technical Director 

1441 White Street 

Ann Arbor, Ml 48104 

(313) 668-4703 

fax (313)668-4708 

SI ADmimorTbeSodayafdieMmioladua-i-, loc 

Daniel P. Boyd, Ph.D. 

DANIEL P. BOYD tc COMPANY 

Wye -£}*>*. 

HaU \ y bland 

505 Wye HaH Dr. 

Qucenstown. MD 21658 

Phone (410) 827-6244 

FAX (410) 827-7589 

TEL: «>*-382-St20 

FAX 804-382-8123 

CURTIS L. DEMUTH 

SENIOR ENVIRONMENTAL INSPECTOR 

DEPARTMENT OF 

ENWRONMENTAL QUAUTY 

COMMONWEALTH OF VmSINIA 

LYNCHBURG AIR OFFICE 

7T01-OS TW8ERLAIS ROAO 

LYNCHBURG. VIRGINIA 24302 

PRINTED ON RECYCLED PAPER 

MTHWARE 

32SS East Miraloma Avenue 

Anaheim. CA 92806 

TEL (714) 993-1220. CXL 275 

FAX (714) 524-8784 

M. WM. "MIKE" SEYMOUR 

Sr. Director of Process Development 

and 

Technical Services 

LASCO 

BATHWARE 

Virginia State Highway 931 

Halifax County Industrial Park 

P.O. Box 1177 

South Boston. VA 24592-1177 

TEL (804) 572-1200 

FAX (804) 572-2067 

SCOTT HARTMAN 

Plant Manager 
P.12 

f^Ha^WA't °^ 

U.S. EPA / LASCO Bathware 

South Boston Plant Visit 

Thursday June 22,1995 

1. What is the number of employees at the South Boston facility? 

LASCO Bathware's South Boston facUity employs a total of 280 

people, which includes all management and office staff personnel, as 

well as, plant personnel and truck drivers. Our South Boston facility 

is also one ofthe top 10 employers within the South Boston, Halifax 

County area, with respect to total number employed. 

2. What is your latest calculation of styrene emissions and the 

methodology used? 

The methodology used in our detennination of styrene emissions is 

EPA Method 24A FID and EPA Method 25. Based upon the results of 

these tests and subsequent analysis, our latest calculations for 

styrene emissions at the South Boston facility are as follows: 

GELCOAT SURFACED PRODUCTION LINE - 7.312.713 soft Per Year 

Application/Process Booth Stvrene Pounds Per Year 

All Incinerated Booths 14,427.70 

All Non-Incinerated Booths 111.145.20 

Total Styrene Emissions/Year 125.572.90 #/Yr 

ACRYLIC SURFACED PRODUCTION LINE - 7.385.197 soft Per Year 

Application/Process Booth Stvrene Pounds Per Year 

All Non-Incinerated Booths 254.305.30 

Total Styrene Emissions/Year 254,305.30 

1° 
P.13 

3. What process type is involved in the manufacture of each product? 

South Boston's primary manufacturing site operates two (2) 

independent production lines, one (1) production Une dedicated to the 

manufacture of gelcoat surfaced fiberglass reinforced products (tubs, 

showers & unitized tub/showers) and, one (1) production line 

dedicated to the manufacture of thermoformed acrylic surfaced 

fiberglass reinforced products (unitized tub/showers). 

At our secondary manufacturing site, we operate a single production 

Une dedicated to the manufacture of thermoformed acrylic 

surfaced fiberglass reinforced products (Jetted tubs). 

The Open Mold spray-up process is utilized in the manufacture of all 

three (3) of our product lines. Additionally, the hand lay-up process is 

utilized in the construction of production molds/tooling and, in repair 

of any sub-standard manufactured product. 

4. What process types are being controlled? 

The Open Mold spray-up and hand lay-up processes are controlled 

and, no other composites processes are utilized in our manufacture of 

FRP products. 

5. What quantity of resin (per year) is used? 

Three (3) different resin products are utilized in the production of our 

three product lines. All three resin products are vapor suppressed. 

Resins: Pounds Used 

x Laminating Resin 3,523,593 lbs 

Barrier-Coat Resin -nerN/nonr 427,005 lbs 

CScrAicTmmatl^R^^ < .n^TcL.J 1.589.775lbs 

Total Resin ouppres^a 5.540.373 lbs 

(j^LC -TrfpfepocVJ 

6. What quantity of gelcoat (per year) is used? 

Total gelcoat pounds used equal: 

Gelcoat: Pounds Used 

Gelcoats 958.279 lbs 

Total Gelcoat 958.279 lbs 
P.M 

7. What percent filler is used? 

All LASCO facilities utilize in their manufacture of gelcoat surfaced 

reinforced products five (5) separate spray-up appUcations, with five 

(5) separate spray-up material formulations. The following is a 

breakdown of the five (5) spray-up applications and their respective 

formulation filler percentages. 

GELCOAT SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Application/Process Booth 

Gelcoat Spray-up 

Barrier-Coat Spray-up 

First Laminate Spray-up 

Second Laminate Spray-up 

Third Laminate Spray-up 

Formulation Filler Percentage 

25.00% (by mfg) 

55.00% 

61.00% 

63.00% 

60.00% 

The acrylic surfaced products manufactured, utilize two (2) spray-up 

applications witfi a single (1) spray-up material formulation in both. 

ACRYLIC SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Application/Process Booth 

First & Second Laminate Spray-up 

Formulation Filler Percent 

52.33% 

8. What is the styrene percent of the resin (after filler and/or additional 

styrene is added)? 

All LASCO facilities utiUze in their manufacture of gelcoat surfaced 

reinforced products five (5) separate spray-up applications, with five 

(5) separate spray-up material formulations. The following is a 

breakdown of the five (5) spray-up applications and their respective 

formulation styrene percentages. 

Note: The formulation styrene percentages were calculated 

using the most recent baseUne data supplied in the 

accompanying resin supplier QuaUty Control Reports and 

Material Safety Data Sheets (see Appendix A). 

II 
P.15 

GELCOAT SURFACED PRODUCTS 

As UsedfProcessed (sprayup): 

Anolhation/Process Booth Formulation Stvrene Percent 

Gelcoat Spray-up 36.41 % 

Barrier-Coat Spray-up 20.25% 

First Laminate Spray-up 18.72% 

Second Laminate Spray-up 17.76% 

Third Laminate Spray-up 19.20% 

The acrylic surfaced products manufactured, utilize two (2) spray-up 

applications with a single (1) spray-up material formulation in both. 

ACRYLIC SURFACED PRODUCTS 

As Used/Processed (spray-up): 

Application/Process Booth Formulation Stvrene Percent 

First & Second Laminate Spray-up 21.60% 

9. What is the styrene percent of gelcoat? 

The styrene percentage of the gelcoats supplied to the South Boston 

facility are 36.41 %, as stated in our suppliers most recent Quality 

Control Reports and Material Safety Data Sheets (see Appendix B). 

10. What percent resin supplied to the plant is used for each process 

(exclude compression molding)? 

As previously identified, LASCO utilizes numerous individual spray-up 

applications and formulations. Here is a percentage breakdown of the 

total pounds of resin thru-put by application/process booth. 

GELCOAT SURFACED PRODUCTS 

Application/Process Booth Pounds Resin Thru-Put by Percent 

All Gelcoats: Pounds Percent 

Gelcoat Film Spray-up Booth 958,279 100% 

\l 
P.16 

Barrier-Coat Resin: 

Barrier-Coat Film Spray-up Booth 427,005 100% 

Laminating Resin: 

1st, 2nd & 3rd Lam. Spray-up Booths 3,502,451 99.4% 

Repair/Rework Spray/Hand Lay-up 21,142 .6% 

ACRYLIC SURFACED PRODUCTS 

Application/Process Booth Pounds Resin Thru-Put bv Percent 

Acrylic Laminating Resin: Pounds Percent 

First Laminate Spray-up 794,887.5 50%- • 

Second Laminate Spray-up 794,887.5 50% 

1 1. What percentage of resin within each process type is associated with 

the use of an add-on? 

GELCOAT SURFACED PRODUCTS 

Application/Process Booth Percentage of Resin Thru Add-on 

Gelcoat Film Spray-up 

Barrier-Coat Film Spray-up 

Laminating Resin: 

First Laminate Spray-up 

Second Laminate Spray-up 

Third Laminate Spray-up 

Repair/Rework Spray/Hand Lay-up 

ACRYLIC SURFACED PRODUCTS 

Pounds Percept 

100% 

0% 

100% 

100% 

100% 

0% 

Application/Process Booth Percentage of Resin Thru Add-on 

First Laminate Spray-up 

Second Laminate Spray-up 

Pounds Percent 

0% 

0% 

14-
P.17 

12. What is the inlet concentration of styrene? Outlet? 

Based on our most recent data, the inlet concentration of styrene 

emissions to the incinerator is 77.34 pounds per hour. Outlet 

concentrations based on a 95% destmction efficiency is 3.87 pounds 

per hour. 

Note: The thermal incinerator is identified as a Reeco Re-Therm 

Model E Thermal Oxidation System. The Reeco incinerator is rated for 

an input of 17,345 SCFM @ 90 F. and lists a minimum destruction 

efficiency of 95%. The maximum destmction efficiency rating is 

99%. These destmction efficiency ratings were supported by Reeco 

Company data and actual field monitoring of a similar unit. 

13. What specific emission points in the process are being controlled by 

the oxidizer (e.g., storage tank (s), mixing vessels, etc.)? 

GELCOAT SURFACED PRODUCTION LINE 

Production/Process Booth Controlled Source & Percentage 

Gelcoat Film Spray Booth 

Barrier-Coat Film Spray Booth 

First Laminate Spray Booth 

Second Laminate Spray Booth 

Third Laminate Spray Booth 

Gelcoat Storage Room 

L. Mixing & Holding Tanks (GC & ACR) res luuyb \ 

-fT MiX//\/6 -hW/S not \jQjr.kA hMGi&rcUor istp -trip ncfiort) 

ACRYLIC SURFACED PRODUCTION LINE L ^ ' r ~ ^ 7 

Production/Process Booth Controlled Source & Percentage 

To Incinerator Percent 

First Laminate Spray-up No 0% 

Second Laminate Spray-up No 0% 

14. What is the capture efficiency for each emission point vented to an 

add-on? 

All LASCO plants operate with ventilation systems engineered to 

create a negative pressure, with respect to the outside atmosphere, 

within all spray-up and grinding booths and, again within the entire 

5> 

To Incinerator 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Percent 

100% 

0% 

100% 

100% 

100% 

100% 

100% 
P.18 

plant production area. Moreover, the buildings are kept closed up for 

the most part. Therefore, it is our contention that the capture 

efficiency from each production emissions source point (spray-up 

appUcation booths) is 100%. 

15. Is the control device used for any process not in the reinforced 

composite plastic source category? If so,.what percentage of the 

flow rate to the add-on is from the reinforced composites? 

The thermal oxidizer in operation here, is solely used tor the capture 

and destmction of styrene emissions originating from the spray-up 

and curing processes associated with reinforced composites. 

16. What is the volumetric flow rate through the control device? 

The Reeco incinerator is rated for an input flow rate of 17,345 SCFM 

@90F. 

17. What was tfie capital investment for the control device? What is the 

operating cost per year for this device? 

The initial capital investment for the Reeco Incinerator was 

$738,092.00 in 1986 and began operation in December of that year. 

Operating costs do vary. However, from information pulled from our 

1995 plant performance data, the operating costs for gas and 

electricity were $ 105,582.50 and, maintenance costs were 

$ 14,983.20. 

Note: Currently, LASCO (Lancaster, Tx.) is undertaking a cost 

analysis to detennine best long-tenm approach to either rebuilding or 

replacing Reeco Incinerator. Life expectancy without major rebuild or 

overhauling ofthe Reeco systems is approximately 8-10 years. 

it 
P.19 

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P.21 

/\TTflCH(^e^TH 

LASCO BATHWARE - SOUTH BOSTON 

Presentation for 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

DANIEL P. BOYD & COMPANY 

June 22, 1995 

/ 1 
P.22 

SUMMARY OF STYRENE PROPERTIES 

The properties of styrene, the industrial uses of the material, 

the fate of styrene in the environment, as well as styrene's 

health effects and odor properties are reviewed in this short 

summary. 

Styrene is a colorless, refractive, oily liquid. It is the 

simplest aromatic compound with an unsaturated side chain. 

Styrene has the chemical formula C6HSCH=CH2. 

This material is used to produce a multitude of useful products 

including pollution control equipment, fiberglass boats, 

recreational vehicles, car and body parts, tub and shower units, 

countertops, sinks, industrial pipe and storage tanks. It is 

also used to manufacture polystyrene products, synthetic rubber 

and commercial paints and coatings. 

Styrene is readily oxidized in the atmosphere by the predominate 

reaction with free hydroxyl radicals. The half life in the air 

from this reaction is approximately three hours. Based on this 

half life, styrene will be depleted from the environment in 

approximately twelve hours through further degradation into the 

benign products, carbon dioxide and water vapor. 

The potential health effects of styrene include neurotoxicity, 

irritation and suspected carcinogenicity. Styrene workers who 

are exposed to levels of 50 ppm for a working lifetime should not 

experience any adverse health effects. Styrene levels in the 

environment are orders of magnitude lower than those experienced 

in the workplace, hence no adverse health effects would be 

expected from environmental exposure. 

A comprehensive evaluation of styrene's potential carcinogenic 

properties has been conducted. From the results of those 

studies, no risk of cancer to the human population would be 

expected at levels associated with both occupational or community 

exposure. 

An odor detection limit has been experimentally determined for 

styrene. The geometric mean value is 0.3 ppm, and for 95% of the 

population, the most sensitive individual can detect styrene at 

0.02 ppm and the least sensitive at 4.8 ppm. 

Styrene is regulated based on its neurotoxic and irritation 

effects. Styrene has not been classified as carcinogenic by any 

agency of the U.S. Government. Of all other agencies on a world 

basis, only the International Agency for Research on Cancer 

(IARC) has classified styrene as "possibly carcinogenic to 

10 
P.23 

humans", its lowest ranking. IARC based its decision on limited 

animal data and a concern for the styrene metabolite, styrene 

oxide. 

Most states (37) do not regulate styrene as a carcinogen, and 

others (14) have no air emission limitations. However, several 

states continue to regulate styrene as a carcinogen, many citing 

outdated EPA documents that have more recently been updated to 

exclude a formal cancer classification.. 

Virginia regulates styrene in the air by using the ACGIH TLVs and 

applying a safety factor of 500. For styrene the annual maximum 

ground level concentration is 0.1 ppm. Virginia uses a one hour 

ground level concentration of 2.5 ppm. 

Fence line limits established by states who do not treat styrene 

as a carcinogen, for example Virginia, provide a comfortable 

margin of safety to assure protection of the public health and 

the environment. At these levels, however, a portion of the 

population will detect the odor of styrene in the environment 

some of the time. 

Based on an overall review of the world literature on styrene, 

and the occupational and environmental levels established by the 

world regulatory community, that data would support a finding 

that no health risks should be associated with styrene 

concentrations found in occupational settings and in the 

community. 

l\ 
P.24 

Level (ppm) 

STYRENE 

REGULATORY, TOXIC .AND ODOR LEVELS 

A COMP.ARISON 

Basis and Description 

Regulatory 

100.0 OSHA 8 hour Permissible Exposure Level 

200.0 OSHA 15 minute Short Term Exposure Level 

600.00 OSHA 5 minute peak 

Environmental 

0.24 

0.1 

2.50 

Advisory 

50.0 

50.0 

100.0 

100.0 

US EPA Reference Concentration - lifetime 

Virginia annual ground level concentration 

Virginia one hour ground level conc. 

NIOSH 10 hour Recommended Enviro Level 

ACGIH 8 hour Threshold Limit Value 

NIOSH 15 minute Recommended Enviro Level 

ACGIH 15 minute Short Term Exposure Limit 

Toxic Effect Levels 

100-200 Irritating to the eyes & nose 

200-700 Onset of signs & symptoms of inebriation, 

dizziness, drowsiness, nausea 

600-800 Strong & immediate irritation to eyes & 

respiratory tract 

Odor 

0.017 Lowest Level of Detection in literature 

0.304 Level at which 50% of panel detect odor 

0.318 Level at which 50% of panel detect odor 

1.90 Level at which 50% of panel detect odor 

25.0 Highest Level of Detection in literature 

99.0 Faint odor - not objectionable to subjects 

117.0 Moderately strong odor for one subject 

400.0 Disagreeable odor 

Reference 

29CFR1910 

29CFR1910 

29CFR1910 

IRIS EPA 

Virginia DBQ 

Virginia DBQ 

NIOSH 

ACGIH 

NIOSH 

ACGIH 

WHO, 1993 

ACGIH 

Patty 

Stalker 

Nagy 

Amoore 

Dravnieks 

Verschueren 

Stewart 

Stewart 

Spenser 

u 
P.25 

ENVIRONMENTS FATE OF STYRENE 

Styrene is readily oxidized in the atmosphere by free hydroxyl 

radicals and ozone (03) . The half-life of styrene in the 

atmosphere due to oxidation by hydroxyl radicals was estimated to 

be approximately 3 hours. The half-life of styrene due to 

oxidation by 03 was estimated to be greater than or equal to 9 

hours. Styrene is probably not removed in appreciable amounts 

from the air due to destruction by sunlight [ref 9] , through 

other photochemical reactions or by wet or dry deposition. 

The removal of styrene and its products from air proceed by a • 

series of reaction steps. Reaction with hydroxyl radicals (OH) 

is considered to be the major removal process for aromatic and 

aliphatic hydrocarbons in the air. Reaction with ozone also 

should be considered for the unsaturated aliphatics, and reaction 

with nitrate radicals for unsaturated aliphatics, the aliphatic 

aldehydes, and the phenols and cresols. The OH-aromatic 

hydrocarbon reaction, which is still not well understood, 

involves OH addition followed by opening of the aromatic ring to 

yield aliphatic dicarbonyl products. 

A recent review by Marchello on the fate of styrene in air 

provides the following important observations. 

(1) Styrene has a half life in the atmosphere of about 3 hours. 

(2) The dominant atmospheric removal process for styrene is 

reaction with the OH radical to produce formaldehyde and 

benzaldehyde. 

Formaldehyde is removed rapidly and has an atmospheric half 

life of 8 hours or less depending on climatic conditions. 

Benzaldehyde reacts to produce either peroxybenzoyl nitrate 

(PBzN) or 2-nitrophenol, or both. PBzN is produced when 

high levels of NO. are present. It converts rapidly to 2-

nitrophenol in the presence of excess NO. 2-nitrophenol 

reacts further or may be removed by physical processes. The 

estimated atmospheric lifetime of 2-nitrophenol is 14 hours. 

(3) Styrene has not been found to contribute to the atmospheric 

production of the eye irritant and phytoxic compound peroxyacetyl 

nitrate (PAN). 

(4) The eye irritant peroxybenzoyl nitrate, PBzN, is produced 

from styrene when significant levels of N02 are present, e.g. in 

areas of heavy vehicular traffic during daylight, such as rush 

hour traffic in highly urban areas. 

*Vb 
P.26 

Because of the rapid dispersion of styrene in the atmosphere from 

styrene manufacturing and using facilities, the levels of styrene 

found in the ambient environment are very small, in the microgram 

quantities. Likewise the levels of formaldehyde and benzaldehyde 

are equally small, all well below any known health effects levels 

by several orders of magnitude. 

Styrene has a very limited water solubility and a high volatility 

(high vapor pressure) at room temperature. Therefore, styrene is 

not likely to occur in drinking water at appreciable 

concentrations. A survey of 945 drinking water sites around the 

U.S. failed to reveal a single site containing styrene [ref 3]. 

Another study* of 102 surface water supplies and 12 ground water 

supplies also failed to find styrene. 

Styrene is quickly volatilized from surface waters. Studies have 

shown a half-life for styrene in surface water from 1 to *3 hours. 

Styrene is easily biodegraded by common soil and waterborne 

microorganisms. This biodegradation may occur either as an 

aerobic process or an anaerobic process. Aerobic biodegradation 

in soil is especially rapid. One study revealed that 87% and 95% 

of styrene added to the soil at a rate of 2.0 g/kg was converted 

to C02 in 16 weeks for sandy loam and landfill soil, 

respectively. At 5.0 g/kg, the conversion rate dropped to 75% 

for both soils. 

7,4 
P.27 

LASCO BATHWARE-SOUTH BOSTON 

OCCUPATIONAL EXPOSURE TO STYRENE BY JOB CATEGORY 

December 1994 - June 1995 

Job Category 

1. Gel Coat Gun Operator 

2. Lamination Gun Operator 

3. Lamination Roller 

4. Barrier Coat Gun Operator 

5. Part Puller 

6. QC Technician 

7. Mixer 

8. Trimmer 

9. Waxer 

123.0 

90.4 

120.0 

79.4 

35.3 

37.0 

31.6 

46.0 

25.0 

Exposure (ppm) 

n=5 (88:199) 

n=17 (37-2671 

n=6 (92-142) 

n=5 (61-105) 

n=2 (32-39) 

n=4 (23-75) 

n=5 (15-44) 

n=l 

n=l 

Acrylic Line 

1. Lamination Gun Operator 

2. Lamination Roller 

25.0: n=l 

42.0; n=2 (41-43) 

£ * 
P.28 

LASCO BATHWARE - SOUTH BOSTON 

IMPACT OF INCINERATION ON STYRENE EMISSIONS 

Inc ON Inc OFF % Redction VA MGLC 

(in micrograms per cubic meter) 

1. Annual Average for 1984 37.03 62.17 

(fenceline to 1000m) 

40.0 426 

2. Annual Average for 1994 11.44 19.60 

(1200m to 2000m) 

41.6 426 

3. Annual Average for 1984 5.55 9.77 

(2500m to 5000m) 

43.2 426 

4. Hourly Maximum for 1984 1937 2317 

(fenceline to 1000m) 

16.4 10650 

5. Hourly Maximum for 1984 1506 2314 

(1200m to 2000m) 

34.9 10650 

6. Hourly Maximum for 1984 690 1176 

(2500m to 5000m) 

41.3 10650 

1.C 
TABLE II-3a Initial ISCST2 Modal Results for Plant A 

VERSION 92062 

MAXIMUM GROUND LEVEL CONCENTRATIONS 

(in micrograms/meter3) 

RECEPTORS: 

INCINERATOR 

STATUS: 

RUN #: 

YEAR 

1984: 

ONE HOUR 

MAXIMUM -

MAX ANNUAL 

AVERAGE -

1985: 

ONE HOUR 

MAXIMUM -

MAX ANNU.AL 

AVERAGE -

1986: 

ONE HOUR 

MAXIMUM -

MAX ANNUAL 

AVERAGE -

1987:' 

ONE HOUR 

MAXIMUM -

MAX ANNU.AL 

AVERAGE -

1989: 

ONE HOUR 

MAXIMUM -

-MAX ANNUAL 

AVERAGE -

Fence! 

100 m -

ON 

#1 

1,936.75 

37.03 

1,957.46 

37.83 

1,873.99 

30.16 

1,894.76 

' 37.68 

1,890.96 

42.68 

Line & 

- 1,000 m 

OFF 

#4 

2,317.32 

62.17 

1,957.46 

62.41 

2,733.30 

48.81 

3,086.00 

60.69 

2,506.95 

68.41 

1,200 m -

ON 

#2 

1,506.44 

11.44 

1,468.97 

9.78 

1,745.36 

10.95 

1,379.71 

10.00 

1,321.15 

11.45 

- 2,000 m 

OFF 

#5 

2,314.07 

19.60 

1,950.63 

16.96 

2,769.40 

18.73 

2,269.40 

17.06 

2,168.56 

19.85 

2,500 m -

ON 

#3 

689.68" 

5.55 

662.34 

4.65 

616.54 

5.00 

631.44 

4.37 

623.76 

5.29 

- 5,000 m 

•. OFF 

#6 

• 

1,175.94 

9.77 

1,123.88 

8.19 

1,061.86 

8.78 

1,093.84 

7.59 

1,144.98 

9.37 

NOTES: 

1. To convert from micrograms/meter3 to parts per million volumetric (ppmv) 

for styrene vapor divide the tables values above by 4,260. 

II-5 

11 
P.30 

REPROCESSING OF THE VASA DISPERSION MODELING 

FOR "PLANT A" USING 1984 MET DATA 

The previous styrene dispersion modeling performed for the Virginia Styrene 

Alliance (VASA) "Pliint A" (the Lasco Bathware South Boston, Virginia Plant) was 

reprocessed to detennine the influence of the plant's existing incineration equipment upon 

the maximum ground level concentrations (MGLC) of styrene vapor in the surrounding 

community. This reprocessing effort assumed that thc incinerator remained on (Run #7) 

and that the incinerator was turned off (Run #8). The six largest MGLC values (shown 

in micrograms per cubic meter) for these two runs using 1984 meteorological data are 

compared in Table 1 below. 

As shown, the incineration equipment appears to reduce the MGLC values around 

the plant by an average of about 40%. 

TABLE 1 Comparison of the 1984 Results for Run #7 and Run -#8 

RUN #7 

(M-g/m3) 

37.03 vs 

33.73 vs 

31.35 vs 

31.11 vs 

30.21 vs 

28.43 vs 

RUN #8 

(ug/m3) 

62.17 

54.59 

51.74 

50.90 

50.74 

48.51 

PERCENTAGE 

REDUCTION 

40% 

38% 

39% 

39% 

40% 

41% 

^

< 6 
P.31 

REPROCESSING OF THE VASA DISPERSION MODELING 

FOR "PLANT A" USING 1984 MET DATA 

The previous styrene dispersion modeling performed for the Virginia Styrene 

Alliance (VASA) "Plant A" (the Lasco Bathware South Boston, Virginia Plant) was 

reprocessed to detennine the influence of the plant's exisnng incineration equipment upon 

the maximum ground level concentrations (MGLC) of styrene vapor in the surrounding 

community. This reprocessing effort assumed that the incinerator remained on (Run #7) 

and that the incinerator was turned off (Run #8). The six largest MGLC values (shown 

in micrograms per cubic meter) for these two runs using 1984 meteorological data are 

compared in Table I below. 

As shown, the incineration equipment appears to reduce the MGLC values around 

the plant by an average of about 40%. 

TABLE 1 Comparison of the 1984 Results for Run #7 and Run #8 

RUN #7 

(M-g/m3) 

37.03 vs 

33.73 vs 

31.35 vs 

31.11 vs 

30.21 vs 

28.43 vs 

RUN #8 

(jig/m3) 

62.17 

54.59 

51.74 

50.90 

50.74 

48.51 

PERCENTAGE 

REDUCTION 

40% 

38% 

39% 

39% 

40% 

41% 

1st