BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

)

PETITION OF ROYAL FIBERGLASS

)

POOLS, INC. FOR AN ADJUSTED

)

AS 09-4

STANDARD

FROM 35 ILL. ADM. CODE

)

(Adjusted Standard - Air)

215.301

RESPONSES OF PETITIONER ROYAL FIBERGLASS POOLS TO QUESTIONS

FROM THE ILLINOIS POLLUTION CONTROL BOARD

Comes now Petitioner Royal Fiberglass Pools, Inc. ("Royal") and submits the following

responses to the questions from the Illinois Pollution Control Board (the "Board") attached to the

Hearing

Officer's Order of June 4,2009.

SECTION 28.1.c.

1. The petition on page

13

states, "By complying with the Composites MACT, Royal has limited

its

VOM emissions and also decreased the amount of solid and hazardous waste Royal

generates.

"

Would you please elaborate on Royal's reduction of solid and hazardous waste

resultingfrom compliance with MACT?

As part of MACT compliance, Royal converted its resin spray applicators to low-emitting

non-atomized applicators. The non-atomized applicators reduce the amount

of

overspray, and therefore the amount of solid and hazardous waste generated. Although

not required by the MACT standard, Royal has eliminated all colored backcoat gelcoats

and now uses

just white backcoat. This requires less flushing of the gelcoat lines, and as

a result, less waste gelcoat material is generated.

2.

If

granted, will the adjusted standard be submitted to USEPAfor inclusion in the lllinois SIP?

Royal cannot independently submit revisions to USEP A for inclusion in the Illinois SIP.

This decision and action is with the Illinois EPA.

l04.406(d)

3. Would you please provide a map indicating the location of the Dix Plant?

Maps showing the location of the Dix Plant were included in Exhibit 1 of the First

Amended

Petition. Also attached hereto are an additional map and aerial photograph

labeled

Exhibit A and Exhibit B, respectively.

4. The petition indicates that Royal's other manufacturingfacility is located in Louisiana.

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

(a)

Are there other states where Royal Fiberglass Pools, Inc. has similar manufacturing

facilities?

No. The only other Royal composite pool manufacturing facility is located

in Breaux

Bridge, Louisiana.

(b)

Do any of those states have state-specific limitations on VOM emissions beyond the MACT?

If

so, how does Royal Fiberglass Pools, Inc. address compliance in other states?

Royal is not aware

of any pounds/hour YOM emission limitation in Louisiana.

5.

Please describe the area affected What is the ozone attainment status of the county in which

the Dix

Plant is located? Is the ozone attainment status poised to be changed in the near future?

The Dix

Plant is located in Jefferson County. As of June 9, 2009, Jefferson County is in

attainment for all Criteria Pollutants. To our knowledge, the attainment status for

Jefferson County is not poised to change.

6.

In Section

2

of the Technical Document, the chart entitled ''January 2005: Monthly

HAPIVOClMACT Emissions Logfor the Royal Pools Dix Facility" was printed larger than the

page, so the table on the far right appears to have been cut off.

If

so, would you please resubmit

the table with the missing information?

While we have not included the referenced chart as an exhibit to the First Amended

Petition, attached for your convenience is this same chart for July 2009, labeled as

Exhibit

C.

7.

In general, the most recent data provided appears to be from 2005.

(a)

Would you please comment on any change in quantities or materials used since then?

This question is addressed in more detail in the First Amended

Petition. In short, there

have been some changes in quantities and materials. In particular, the facility is seeking

a production level

of 400-pools-per-year instead ofthe original 250 pools-per-year.

Further, the historical data for

2006,2007, and 2008 shows higher per pool material

usages than originally assumed from the

2005 data. Some of the increased usage is due

to a new two-part gelcoat finish that requires twice as much gelcoat. This new finish has

become quite popular and is now the standard finish demanded by most pool owners.

Also, Royal has more accurate information now than it did in

2005 about the amounts of

materials needed to make pools at the Dix facility.

(b)

If

possible, would you please submit information reflecting the most recent available data?

This is included in the Exhibit 2 to the First Amended

Petition.

(c)

Although the Technical Document Section

3

at page

5

states that 250 pools per year is a

more reasonable estimate than the

400 pools per year used in the CAAP P permit application,

would you please comment on any anticipated growth or change in operations.

---

As stated above, Royals now seeks 400-pools-per-year in anticipation of increased

demand after the recession ends.

It

is hoped that many of Royal Pools competitors will

go out

of business due to the recession, so Royal should enjoy increased market share.

(d)

Section

2

of the Technical Document on page

9

makes a calculation based on "Reducing the

maximum annual production rate from

250 to 200 pools per year ... " and comments, "Afacility-

wide production cap

of 220 pools per year would reclassifY the Dix Plant as a synthetic minor

source

-

the maximum emission rate would be

just under the major HAP source emission

threshold

of 10 tpy." Is Royal Pools considering revising their CAAPP Permit application to

reflect a production cap

of220 pools per year and a HAP emission threshold of 10 tpy?

No. In 2006, Royals Pools was informed by IEP A that lowering the production to 220

pools was not a solution to the compliance issue. Further, Royal is now a major HAP

source. According to EPA's "once-in-always-in" policy, Royal has no reason to lower

the emission cap to below the major-source threshold of 10 tpy single HAP.

8.

Royal Pools states that, "EPA explained that the annual emission rate and the facility CAAP P

status have no bearing on compliance with

35

lAC

215

Subpart K." TSD Section

4

at

2.

Would

you please comment on the maximum potential to emit on an hourly basis

if

production were

capped at 400 pools per year, or at 220 pools per year?

There would be no change in the maximum hourly rate at 400-pools-per-year versus 220.

While the total annual emissions depends on the number pools built per year, the hourly

rate is not affected by the total number

of pools produced. Even at an annual rate of 220

pools per year, the Dix facility could have a maximum hourly emission as high as when it

manufactures 400 pools per year.

9.

In Section

3

of the Technical Document on page

5,

the Pool Production Schedule indicates a

typical

work schedule of two pools per day during 100% full production, with the "greatest

hourly gelcoat process emission rate"

of

64.86

lb/hr. In Section

2,

the chart of "Hourly

Potential-to-Emit

HAP/VOCfor the Royal Pools Dix Facility/Maximum Hourly Baseline"

indicates maximum hourly usage

of

17.421

b VOM/hour for resin application,

36.781

b

VOM/hour

for gelcoat application, 0.08 lb VOM/hour for catalyst, plus

1

lb VOM/hour for mold

wax.

(a)

Would you please explain the difference in the "maximum hourly baseline" and the "hourly

potential-to-emit"

and indicate which the chart in Section

2

is depicting?

As stated above, the maximum hourly rate has changed since 2005. The referenced

charts are now obsolete.

Please see Exhibit 2 to the First Amended Petition.

(b)

Would you please indicate the overall maximum potential hourly VOM emissions?

The new maximum hourly rate is 156.7 lbs YOM per hour, which is referenced in the

First Amended

Petition. The maximum hourly rate assumes that the two largest pool

models would be gel coated at the same time. Although this would rarely happen, it may

occur a few times per year at peak production.

Since there is no practical way to monitor

and record hourly production activity, the maximum hourly rate is assumed for the worst-

---

case scenario. However, if the two smallest pool models were being gelcoated at the

same time, the

YOM emissions would only be 40 lbs per hour.

( c)

Since Royal can produce

2

pools per day at 100% full production, would you please

comment on the scenario that both pools would undergo gelcoat application during the same

hour?

This is the worst case operating scenario (from an emissions standpoint), especially at

two-shift

400 pools-per-year operations, and represents the greatest hourly emission rate.

Also,

"two-pools-per-day" is an average production rate assuming two-shift operation.

Royal has a variety of pool sizes from small to large. The small pools take one to two

days to complete, the larger pools take more than two days to make from start to finish.

The maximum hourly rate

of 156.71bs ofVOM per hour referenced above is based on

two pools being gelcoated at the same time.

(d)

Does Royal Pools have an operating procedure in place that would limit gelcoat application

and curing to one pool at a time?

No. There is no such operating procedure is in place.

(e)

Would Royal Pools please comment on including such a limitation in the adjusted standard

conditions?

Royal strongly opposes such a limitation. This would cause an unacceptable bottleneck

in production and is not likely to reduce hourly emissions to any great extent. For

example,

if the Dix facility waited to gelcoat a second pool until after a first pool had

been gelcoated and cured, the first pool would be ready for application

of resin (while the

second pool was being gelcoated) which also generates

YOM emissions (as discussed in

Exhibit 2

of the First Amended Petition).

In

addition, such a limitation would make it

very difficult to produce

400 pools per year and would significantly increase production

costs.

It

would also be impractical for Royal to monitor and demonstrate compliance

with such a limitation on a continuous basis.

(f)

Would you please comment on including a condition in the adjusted standard limiting the

adjusted standard to Royal's current operations and limiting the maximum hourly VOM

emissions to 64.86Ib/hr?

The 64.86 lb/hr value is now obsolete. The new absolute worst-case maximum hourly

rate is

156.7Ibs/hr.

Since Royal anticipates that there will be a cap of 400 pools per year

in its permit, there is no need to also have a worst-case

lb/hour

limitation. As stated

above, emissions at this worst-case rate

or anything approaching it would be rare, only

happening at the times that two pools were being gelcoated at the same time.

In

addition,

such a limit would also impose additional, impractical monitoring and recordkeeping in

order to demonstrate compliance with such a provision.

10.

Would you please define MMA, AMS, DMP, MEK (MEKP) referenced in Section

2

of the

Technical Document.

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

These are common abbreviations for some of the process chemicals used throughout the

composites industry:

MMA

- methyl methacrylate

AMS - alpha methyl styrene

DMP - dimethyl phthalate

MEK

- methyl ethyl ketone

MEKP - methyl ethyl ketone peroxide

11.

In Section

2

of the Technical Document, the chart entitled, "Maximum Hourly Baseline:

Hourly Potential-to-Emit

HAPIVOCfor the Royal Pools Dix Facility" lists "Bondo" having a

I

2.57%

Styrene Emission Factor and a 100% Other VOC Emission Factor. The information

under

VOC Content (Styrene, MMA, AMS, Other), however, is blankfor Bondo.

Is

information

available on the

HAPIVOC content of Bondo? Since Bondo is not listed in the 2005 Monthly

HAPIVOCIMACT Emissions Logs, would you please comment on how seldom it is used?

The Dix Plant does not currently use Bondo, so this question is not applicable.

12. In AS 04-1, Crown line used booths equipped with dry jilter medium to reduce particulate

emissions; lower styrene-content gelcoat

(33.4%);

paneljilters built in each side of the

laminating area to control particulate emissions; tanks equipped with submerged inlets to reduce

splashing and release

ofVOMs whenjilling; andflow-coat spray gunsfor lamination to reduce

VOM emissions experienced with previous air atomized guns. (AS 04-1 Pet. at

5-6.)

Would you

please comment on the potential to employ such efforts at Royal's Dix Plant?

Royal Pools already employs all of these techniques. The gelcoats at Dix range from

24% to 38% styrene and 3% to

10% MMA. These are all MACT compliant.

104.406(e)

13.

The petition on pages

5-6

states, "Specifically, Royal investigated the following

alternatives:

(1)

reducing VOM content in production materials;

(2)

using alternative operating

procedures

and methods; and

(3)

installing add-on emission control technologies.

"

The

Technical Document Section

3

provides details of the evaluation of add-on emission controls,

however, details do not seem to be providedfor the other two alternatives mentioned Would you

please elaborate numbers

(1)

and

(2)

above?

Royal has ceased using clear gelcoat which has a higher YOM content than the white

gelcoat that Royal currently uses as its base component. In discussions with its supplier,

Royal understands that lower

YOM materials are not available for pool production,

because such materials do not provide the corrosion protection that is necessary for high

quality swimming pool parts. Royal is willing to use lower

YOM content gelcoat if they

can provide the same corrosion protection as the products Royal currently uses.

There are no alternative methods (e.g., closed mold process) for production

of such a

large composite part as an outdoor swimming pool.

---

14.

In Sec.

2

of the Technical Document, the chart entitled "Hourly Potential-to-Emit HAP/VOC

for the Royal Pools Dix Facility" lists the HAP/VOC content of the materials used. The petition

on page

7

states that the white gelcoat used contains the lowest feasible monomer contents of

28% styrene and

3%

MMA. Sections

2

and

3

also indicate 161,800 lb o/resin

(47.5%

styrene)

and 3136lb of MEKP Catalyst

(2%

MEK,

37%

DMP) were used in 2005. Did Royal Pools

investigate the availability

of or experiment with other lower HAP/VOC content materials?

If

so,

would you please document your efforts?

See response to question 13 above.

15.

Section

3

of the Technical Document on page 10 states, "Non-atomizing gelcoat equipment

is available that might reduce the gelcoat emission rate. However, the available non-atomizing

equipment will not provide an acceptable surface .finish

and has failed to reduce gelcoat

emissions as promised by the manufacturer." Would you please document your efforts to

evaluate the non-atomizing gelcoat equipment?

The non-atomized gelcoat equipment has been discredited by the South Coast Air Quality

Management District and the American Composites Manufacturing Association in

independent testing since they have been shown to have the same emissions as the

atomized gelcoat equipment.

16.

In the Federal Register, USEPA estimates there are approximately

435

existing major

source facilities that will be subject to the Federal rule

40 CFR

63

Subpart WWWW Annual

compliance costsfor all existing major source facilities were estimated

at

$21.5

million. This

included capital, materials, monitoring, recordkeeping, and reporting costs.

(68

FR 19381)

(a)

What costs has Royal incurred to meet the Federal rule?

Royal spent approximately $40,000 to upgrade it resin sprayers to non-atomized

applicators.

(b)

Has Royal estimated the additional compliance costs associated with monitoring,

recordkeeping

and reporting?

Royal incurred consulting fees of approximately $10,000 in establishing a system to

track, record and report its emissions under the MACT standard. Royal also incurs

ongoing consulting costs

of $1500 per year to track and report its emissions. In addition,

the legal fees and consulting costs Royal has incurred to seek an adjusted standard have

been significant.

104.406(0

17.

The petition on page two refers to "Royal's Initial MACT Notification Letter" being

contained in Section

2

of the Technical Document; however, the letter appears to be missing

from that Section. Would

you please provide a copy or indicate where

it

can be found in the

record?

Yes. Please see

Exhibit D

attached hereto.

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

18. Royal indicates that it meets the Composites MACT by ensuring that all resin containers are

closed when not in use

and that acetone (non-HAPlnon-VOC) is used in resin and gelcoat

cleanup.

(Pet. at

5.)

Royal also indicates that it uses a

28%

styrene monomer gelcoat that is

"state-of-the-art in low-HAP formulations

for swimming pool production.

"

Did Royal switch to

this gelcoat to comply with MACT?

The gelcoat materials that Royal was using were already MACT compliant, but Royal's

policy is to use the lowest HAP content materials that produce a high quality swimming

pool.

It

was this policy that caused Royal to use a lower YOM content white gelcoat.

19. Tltis question is addressed to botlt tlte petitioner and tlte Agency: The Air Quality Impact

Analysis

for ozone was performed based on the assumption that

25

tons per year would be the

maximum

VOM emitted and that the I-hour ozone standard is 120 ppb. However, there are no

limitations proposed

in the adjusted standard language.

(a)

Would you please comment on proposing a condition in the adjusted standard language that

would limit

VOMs to

25

tpy or less.

Royal Pools' current CAAPP application provides for a PTE of29.76 tons per year of

total YOM emissions. Royal does not object to a limitation in its Title V permit of 30

tons YOM per year.

(b)

Would you also please comment on proposing a condition that would require a reevaluation

of the adjusted standard

if

the ozone NAAQS is revised

In the event that Jefferson County is reclassified as non-attainment for ozone at some

future date, the impact on the Title

V permit at the Dix Plant should be minimal. Add-on

VOC emission controls satisfying reasonably available control technology ("RACT")

would still be cost prohibitive and the maximum VOC emission rate from the plant would

still have negligible impact on the ozone level in the regional air shed area. Under these

circumstances, a reevaluation would be

of little value.

20. Could you please indicate

if

Royal has made a demonstration of compliance with the

NESHAP regulations under 40 CFR Part

63

Subpart WWWWto USEPAyet? {40 CFR 63.5840}

Did USEP A respond to the compliance demonstration, and

if

so, how?

Royal has submitted all required initial and periodic NESHAP MACT demonstrations to

USEP

A.

USEP A has not responded to date.

104.406(g)

21. Tltis question is addressed to botlt petitioner and tlte Agency: The petition on page 10

states, "Royal understands that in 2005, EPA replaced the one-hour average ozone standard

with an eight-hour average standard, but believes the hourly calculation presented in the

attached

Air Quality Impact Analysis is useful given the obvious concerns about hourly

emissions that are reflected in the

8

lblhr Rule." As of March 2008, the primary ozone standard

was strengthenedfrom

0.08 parts per million (ppm), set in

1997

to a level of 0.075 ppm averaged

over

8

hours

(73

FR

16436;

March 27,2008).

---

(a)

Since the Air Quality Impact Analysis presented in the Technical Document Section

6

is

based on the previous ozone standard, would

you please provide an analysis of ozone impact in

terms

of the current ozone NAAQS?

Royal Pools believes that the impact is the same - negligible.

(b)

Is the Scheffe (Sept. 1988) procedure and table used in Royal Pool's Air Quality Impact

Analysis

(TSD Sec.

6)

the same for determining the ozone increment for either I-hour as well as

8-hour periods

of time?

Royal Pools believes that the Scheffe Table approach is the only practical and feasible

procedure for demonstrating compliance with the one-hour ozone increment. There is no

similar procedure at present for demonstrating compliance with an eight-hour average

limit.

(c)

Is the Scheffe (Sept. 1988) procedure still the USEP A recommended procedure?

USEP A has not published any guidance for showing ozone compliance for individual

sources, especially very small sources like the Dix Plant. The Scheffe Table approach is

the only available feasible procedure. Further,

USEP A has not provided any guidance for

showing compliance with an eight-hour average ozone limit.

(d)

Please comment on the results of the Air Quality Impact Analysis

if

the ozone increment

were

added to the 8-hour background air quality reading of the 4th highest measured ozone

concentration

from the past

4

consecutive years.

Royal does not have ready access to the 4-year data referenced above. Further, the

Scheffe Table approach, which is based on

USEPA's assessment of worst-case one-hour

ozone impacts, is not mathematically compatible with assessments

of eight-hour average

impacts. Finally, the current 8 lb per hour YOM limitation is a one-hour limitation,

which is also not applicable to assessments

of eight-hour average impacts.

(e) Has the IEP A provided any guidance in conducting the Air Quality Impact Analysis or

indicated appropriate measures

if

the ozone increment appears to cause or be contributing to a

violation

of the ozone NAAQS?

We are not aware of any guidance on assessment of ozone impacts provided by IEP

A.

22. This question is addressed to both the petitioner and the Agency: The Petition at page 12

states,

" ...

the daily amounts of VOM emitted by Royal's operations have a negligible impact on

ambient ozone levels

and would not cause a violation of the ozone NAAQS ...

"

Since Hamilton

County ozone monitoring stations already show exceedences

of the 8-hour ozone standard of

75

ppb

,

would you please comment on including a condition in the adjusted standard limiting Royal

Pools

VOM emitting operations on ozone action days where ambient conditions are likely to

exceed the

75

ppb 8-hour ozone standard?

Royal would be opposed to such a condition since it would be unworkable from a

logistical standpoint.

It

would require Royal to monitor every day whether the ambient

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

conditions are "likely to exceed" the ozone standard. This raises the question of what

"likely to exceed" means. More importantly, it would require Royal to then contact its

employees on a daily basis to inform them whether to come into work that day. This is

not a workable procedure in order for Royal to continue to operate at the Dix Plant.

23.

If

Royal were to experience a growth in production, could you please comment on how such

growth would affect the

VOM emissions on an hourly and 12-month average basis? Would you

please comment on including a condition in the adjusted standard that would limit the amount of

VOM emissions to a level consistent with the time Royal's adjusted standard petition was

submitted?

In its CAAPP application, Royal has requested a cap

of 400 pools per year. This level is

designed to accommodate growth in production which Royal hopes to achieve after the

recession is over. Royal's YOM emissions on an hourly basis and annual basis at a 400

pool per year production level are discussed above and in the First Amended Petition.

Royal would strongly oppose a limit in the amount

of YOM at a level consistent with the

time Royal's adjusted standard petitions was submitted. With the current recession, the

current level

of pool production is at its lowest in years.

Respectfully Submitted,

BRYAN

CAVELLP

By:

(n~

?} _

C;

___ -

~A.

Guariglia, MO

Ba~

Brandon W. Neuschafer, MO Bar #53232

One Metropolitan Square

211 North Broadway, Suite

3600

St. Louis, Missouri 63102

Tel. (314) 259-2000

Fax. (314) 259-2020

Attorneys for Royal Fiberglass Pools, Inc.

---

CERTIFICATE OF SERVICE

The undersigned certifies

tha~

.§}

copy of the foregoing First Amended Petition was served

upon the following parties on the

2naay of October, 2009:

Illinois Pollution Control Board, Attn: Clerk

100 West Randolph Street

James R. Thompson Center, Suite 11-500

Chicago, IL 60601-3218

Division of Legal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Attn: Charles Matoesian

-

---

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Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

---

VSE = vapor suppressant effectiveness (ACMA VSE test result)

Total

Total

Total MACT Material Usage

44,065

lb/mo

UEF = ACMA Unified Emision Factors

MMA = methtyl methacrylate

Styrene

MMA

HAP

VOC

Wt Ave MACT Emissions

133.8

lb/ton

NARA = Non-atomized resin

AMS = alpha methyl styrene

AMS/VT factor = 55% of styrene factor

2,862

146

3,008

3,208

Wt Ave MACT Limit

173.6

lb/ton

AGA = Atomized gelcoat

VT = vinyl toulene

Percentage of MACT Limit

77%

OK

MSDS

Monthly

Total

MACT

MACT

Percent

or

Material

Material

ApplicationMaterial

Resin

Other

AMS

Other

UEF

UEF

Other

AMS

Other

Other

AMS

Other

HAP

HAP

HAP

of HAP

CoA

Name

Classification

Process

Usages

VSE

Styrene

MMA

HAP

& VT

VOC

Styrene

MMA

HAP

& VT

VOC

Styrene

MMA

HAP

& VT

VOC

ContentEmissions

Limit

Limit

#

(lb/yr)

(lb/lb)

(lb/ton)

(lb/ton)

(%)

RESINS

762 Polyester Resin

corrosion-resistant

NARA

0

0%

47.6%

0.0%

0.0%

0.0%

0.5%

12.23%75.0%

100%0.00%

100%

0

0

0

0

0

47.6%

116.5

113

103.1%

784 Vinyl Ester Resin

corrosion-resistant

NARA

11,300

0%

47.5%

0.0%

0.0%

0.0%

0.5%

12.23%75.0%

100%0.00%

100%

656

0

0

0

57

47.5%

116.2

113

102.8%

162 Unsaturated Resin

corrosion-resistant

NARA

27,340

0%

47.5%

0.0%

0.0%

0.0%

0.5%

12.23%75.0%

100%0.00%

100%

1,588

0

0

0

137

47.5%

116.2

113

102.8%

Total Resins38,640

GELCOATS

LHM2016 - white

corrosion-resistant

AGA

2,200

27.0%

3.0%

0.0%

0.0%

0.0%

44.51%75.0%

100%0.00%

100%

264

50

0

0

0

30.0%

267.1

605

44.1%

SAFAS colored gelcoats

corrosion-resistant

AGA

2,700

24.0%

4.0%

0.0%

0.0%

0.0%

44.51%75.0%

100%0.00%

100%

288

81

0

0

0

28.0%

249.3

605

41.2%

LHM9268 - gray

corrosion-resistant

AGA

525

28.0%

4.0%

0.0%

0.0%

0.0%

44.51%75.0%

100%0.00%

100%

65

16

0

0

0

32.0%

284.9

605

47.1%

LHM6937 - lite blue

corrosion-resistant

AGA

0

28.0%

4.0%

0.0%

0.0%

0.0%

44.51%75.0%

100%0.00%

100%

0

0

0

0

0

32.0%

284.9

605

47.1%

MG1617 - clear

corrosion-resistant

AGA

0

38.0%10.0%

0.0%

0.0%

0.0%

52.28%75.0%

100%0.00%

100%

0

0

0

0

0

48.0%

604.6

605

99.9%

asst tooling & patching

tooling gelcoat

AGA

0

39.0%

0.0%

0.0%

0.0%

0.0%

53.60%75.0%

100%0.00%

100%

0

0

0

0

0

39.0%

418.1

440

95.0%

Total Gelcoats

5,425

wt. ave.

25.6%

3.6%

NON-MACT MISC VOC/HAP MATERIALS

Catalyst

catalyst

320

0.0%

2%

100%

100%

0

6

Mold release

release

0

0.0%

100%

100%

100%

0

0

Mold cleaner

cleaner

0

0.0%

100%

100%

100%

0

0

Mold sealer

sealer

0

0.0%

100%

100%

100%

0

0

0.0%

0.0%

100%

100%

0

0

2,862

146

0

0

200

3,208lb/mo

Monthly VOC/HAP Emissions

Monthly MACT Calculations

VOC/HAP Emissions

(% by weight)

(% VOC/HAP by weight)

(lb/mo)

VOC/HAP Emission Factors

Royal Pools Dix Plant

Average VOC/HAP Contents

July 2009

Monthly VOC/HAP Emissions and

Composites MACT Compliance

Input values are shown in bold blue text

---

100 0-2

2..~O -C:CC~l.

()40RidD1312~~

(SIS) '266-

~

December 9, 2004

Director

Air and Radiation Division

EPA Region V

77 West Jackson Blvd.

Chicago,

II..

60604-3507

F f B ERG LAS S POOL S.

J

N C.

RE:

Royal Fiberglass Pools

Dix,n..

Subpart WWWW Initial Notification

Dear Sir or Madam:

------~

Please accept

the

enclosed infonnation as our initial notification to 40 CPR Pat164

Subpart WWWW: National Emission Standards for Hazardous Air Po]]:uOO:tts:.

Reinforced Plastic Composites Production.

We are confident that we

will

meet the standards for open molding usingcotrosl()n,

. resistant products with the HAP emission averaging option.

.

Jfyou have any questions, please feel free to contact me at 337-332-4386.

Thank you,

..---::---

.

.

'

~

~~

Tony Hebert

General Manager

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

Control

Equipment

Since all emissions sources are

n.i81lnn&

plant. All emission roouct:lOI1lS

a~~lCnl

selection. Royal Pools

util~~;~~·:tEite

non-1ltomized

spray

VOC:

Styrene:

MMA:

2,650 Ibs

Dimethyl

Phthalate: 80 Ibs

MEK.:

16(}lbs .....

Acetone:

<Z3;2!J6:lJ>$> ..•

All emissions

were:~~Usmgthe

current Unified.. ...... .

the CF A. Please see Attachment C for a

sprjeaaSneet(:)i1iql~

emission factors.

'6l,e,'nc~.,er;reac~lfuag

major

~';gro,Wth..

As

suc~

Royal

$:)~l'~:

?fI~~.NE~SI-LA.J

Subpart WWWW

applies

to this

site. An

. . . .. .... .

.be

sent later this year or

major source threshold

bas been

exceeded.

The

facility currently meets the .J.Y ......

1'L:.._~

•.

standard using the averaging option.

Other Appljcable.Rules

EPCRA

Secf;i()ll31l1312

EPCRA

Section

313..

NSPS - 40 Subpart K

NESHAP .. -40 CPR Part 63 SuhpartWWWW

Annual Toxic Criteria Pollutant Report

Chemical Accident Prevention

.;:Yei

Yes .

No

Electronic filing - Received, Clerk's Office, Octobr 2, 2009

---

Royal Fiberglass Pools, Inc.

Dix, Illinois

Air Permit Application

Data

General DtlIa

Royal Pools is located

at

312 Duncan Road

~

Dix,

lllino~

Jefferson County. Please see

Attachment A for the contact and hilling infonnation.

.

Process Description

Royal

Pools fabricates fiberglass swimming pools and

spas

using the latest technology

in

resin and gelcoat

app1icatio~

high quality, corrosion resistance resins and gelcoats, and

hand lay-up.

Materio1 Usoge

Royal Pools requests to

be

pennitted to construct 400 pools per year using the following

materials:

Resin:

396,240 Ibs

~coat.

88,3101bs

MEKP: 7,6801bs

Acetone: 29,000 Ibs

Material Safety

Data

S".eets for

themateli~liste4above

are in Attachment B

Emission Sources

EmisSions are generated from the fabrication of swimming pools

and spas

which OCCurs

in a vented warehouse.

InsigniflCIlIIt Activities

I. 250 Gallon Diesel Tank - the vapor pressure of diesel is 0.009 psia making the

tank

an insignificant source of emissions.

2. 2 Propane Tanks - the propane tanks are under

pressure and

are not vented

3. Resin Storage Tanks - the resin is

stored

in a

tank

designed and patented by

Royal Pools. The

tanks

utilize and internal floating roof to

reduce

venting

and

air

to resin contact. As such, these tanks are insignificant sources of emissions.

---

ru

Cl

Cl

Cl

Cl

..D

ru

ru

iiiii~~~~~-=:>

Pos!agEl

JVAl~

Certified

Fee

Return Rec!ept Fee

(Endorsement Required)

Res!rlc!ad Delivery Fee

{Endorsement Required)

Talal Pcs!age

8<

Fees

$

, ;

,}:

..

. ..

I

ner-k\;.

KrJ.}V4Y

1--"'---'---1'~':'

...

::'.IZ"'.,~

...

<"l.

t....::.

$

__

....;~""

•••

"",;!:~

.....

1_....J112!lil04

Tony Hebert

General Manager

SSP 0 0

L S. INC.

._--

100Y22.~O-t)002

-

Al

[.,rOJ

1"'1

312

Duncan Rd.

LJ<--tVCl

l.liIV

Dix. IL 62830

. .

(618) 266-7089

..CFR

Part 63

~

Pollutants:

..

:ng

corrosion

Electronic filing - Received, Clerk's Office, Octobr 2, 2009