*>EPA
United States Environmental Protection Agency
Region 7
Enforcement and Compliance Assurance Division
Air Branch Inspection Report
Unannounced Partial Compliance Evaluation
Superior Home Products, Inc.
211 EdingerRoad
Wentzville, Missouri 63385
FRS# 110000442192
u
03
GO
Inspection Date(s):
September 12, 2023
I I L/'p Digitally signed by LUKE
LUrVIZ RODRIGUEZ
RODRIGUEZ E*™4
Luke Rodriguez, Inspector, EC AD, Air Branch
Authorized for Release by:
Digitally signed by
TRACEY CASBURN j^2%^RN
08:38:15-06'00'
Tracey Casburn, Air Branch Chief, EC AD
11201 Renner Boulevard
Lenexa, Kansas 66219
Page 1 of 11
-------
CONTENTS
INSPECTION OVERVIEW 3
INSPECTION OBJECTIVE 3
FACILITY CONTACT INFORMATION 3
FACILITY OVERVIEW 3
FACILITY OPERATIONS SUMMARY 4
FIELD ACTIVITIES SUMMARY 4
Measurement and/or Sampling Activities 5
INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS 7
TABLES
Table 1. PROJECT TEAM MEMBERS 3
Table 2. FACILITY CONTACT INFORMATION 3
Table 3. APPLICABLE REGULATIONS AND STANDARDS 3
Table 4. FIELD MEASUREMENT ACTIVITIES 7
Table 5. WORK PRACTICES STANDARDS REVIEW 8
FIGURES
Figure J. PID Monitoring Data 6
APPENDICES
A. Confidential Business Information (1 page)
B Receipt for Samples (1 page)
C Collected SDS (180 pages)
D Photographs (17 pages)
E Demonstration of Organic HAP Limits (4 pages)
F VOC and HAP Emissions (3 pages)
Page 2 of 11
-------
INSPECTION OVERVIEW
INSPECTION OBJECTIVE
The objective of the partial compliance evaluation (PCE) inspection was to determine
compliance of the facility with the Clean Air Act (CAA), specifically those requirements located
in the code of federal regulations at 40 CFR Part 63 Subpart WWWW, National Emissions
Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production. The
inspection was part of the U.S. Environmental Protection Agency's (EPA) Creating Cleaner Air
for Communities National Enforcement Compliance Initiative.
Table 1 lists the inspection team members.
Table 1. PROJECT TEAM MEMBERS
Team Member
Organization
Project Role
Lead Inspector Luke Rodriguez
EPA, Region 7, ECAD, Air Branch
Project manager (PM)
Robert Barnacle, Program Analyst
Missouri Department of Natural
Resources (MoDNR)
Sampling with Photo Ionization
Detector under direction of Luke
Rodriguez
FACILITY CONTACT INFORMATION
Table 2 lists the primary facility contacts.
Table 2. FACILITY CONTACT INFORMATION
Name, Title
Phone No.
Email Address
Chip Daggett, President
636-332-9040
cdaggett@suphome.com
Paul Bergmann, Vice President
636-332-9040
pbergmann@ suphome.com
FACILITY OVERVIEW
Superior Home Products, Inc. (Superior Home Products) began operation in 1994. The facility is
a reinforced plastic composites production facility which is a major source of styrene emissions
and is therefore an existing source subject to 40 CFR 63 Subpart WWWW. Superior Home
Products operates as a major source of hazardous air pollutants (HAPS) and was most recently
re-issued a Part 70 Permit on March 27, 2018 by MoDNR. According to the Superior Home
Products Title V operating permit, the facility is subject to the following regulations and
standards subject to review during this inspection (Table 3):
Table 3. APPLICABLE REGULATIONS AND STANDARDS
Code of
Standard Name
Federal
Regulation
Page 3 of 11
-------
Table 3. APPLICABLE REGULATIONS AND STANDARDS
Code of
Federal
Regulation
Standard Name
40 CFR Part
63
Subpart A, General Provisions
Subpart WWWW, National Emissions Standards for Hazardous Air Pollutants: Reinforced
Plastic Composites Production
F AC 11 JT¥ O PERATIONS SUMMARY
Superior Home Products manufactures cultured marble vanity tops, bathtubs, and wall surrounds.
The facility employs roughly 35 individuals in the manufacturing area and operates from 5 a.m.
to 5 p.m., 5 days a week. Section 63.5790(b) identifies the operations regulated under Subpart
WW WW. Of the operations listed, Superior Home Products operates an open molding line,
polymer casting, mixing, cleaning of equipment used in rei nforced plastic composites
manufacture, HAP containing materials storage, and repair operations on parts they also
manufacture.
FIELD ACTIVITIES SUMMARY
I arrived at the facility on September 12, 2023, and completed a drive by surveillance inspection.
I did not observe any opacity from the building or detect any odor. I made entry at the front door
at 8:45 a.m. and i ntroduced myself and Mr. Barnacle, presented my credentials, and provided my
business card to Mr. Paul Bergmann. I was given a facility safety briefing by Mr. Chip Daggett.
I conducted an opening conference during which I explained that the purpose of the visit was to
conduct an inspection to determine compliance with the OA.A. specifically, to determine
compliance with the conditions listed in Table 3.1 explained that after asking for some general
business information, I would observe work practices, process units, emission units, control
equipment and review associated records demonstrating compliance with the standard, permit,
regulation. I explained to Mr. Daggett that the facility could make a claim of business
confidentiality and provided him with a Confidential Business Information form (Appendix A).
Mr. Daggett did not make a claim of confidentiality.
I was given a facility tour by Mr. Daggett and Mr. Bergmann. I was asked to wear eye and ear
protection by Mr. Daggett during the facility tour as requi red by company policy.
I reviewed the condition of emission units regulated under 40 CI R 63 Subpart WW WW, the
operating status of the equipment, and any requi red record keeping for the equipment for
Page 4 of 11
-------
compliance with the regulations and permit conditions noted in Table 3 only. I obtained copies
of the records as indicated on the Receipt for Documents (Appendix B).
Sampling activities are described in the Measurement and/or Sampling Activities section
below.
I conducted a closing conference with Mr. Daggett and Mr. Bergmann. I provided the facility
with copies of the Confidential Business Information form and the Receipt for Documents and a
small business information sheet.
Observations and potential findings from the facility tour, and records review, and
sampling/measurement activities are noted in the Investigation Observation and Potential
Findings section below.
Measurement and/or Sampling Activities
The inspection team conducted photo-ionization sampling using a Photo-Ionization Detector
(PID) and recorded video using a FLIR Camera during the onsite inspection under my direction.
I did a bump test calibration of the PID with 100 ppm isobutylene immediately preceding the
facility walkthrough. Mr. Barnacle carried the PID during the facility walkthrough. We first
walked upwind of the facility to the parking lot across the street, then immediately downwind
and then inside the production area. I carried the FLIR Camera and recorded videos of several
vents on the exterior of the building.
All environmental measurement activities were performed in accordance with the EPA Region 7
quality system. I followed manufacturer and EPA processes for instrument calibration.
Instrument calibration was documented in the instrument's logbook.
Page 5 of 11
-------
250-i
- PID(ppm)(Min)
- PID(ppm}(Avg)
- PID(pprnKMax)
- PID{ppm}(Rea3)
09:23:43 09:33:35 09:33:23 09:43:11 09:47:53 09:52:46 09:57:33 10:02:21
Figure 1. PID Monitoring Data
Figure 1 shows the record of the PID sampling which occurred on September 12, 2023. The
bump test was completed at 9:25 a.m. 19 minutes later, at 9:44 a.m., I entered the facility. The
last photograph I took was at 9:59 a.m. and was inside the production area. I left the production
area shortly after that and shut down the PID. During the time I was in the production area, the
PID readings were above 100 ppm. According to the SDS for the Clear LOW VOC Gel Coat,
which contains 41% styrene, the OSHA PEL TWA: 100 ppm for 8 hours while the NIOSH REL
TWA: 50 PPM for 10 hours. This SDS is included in Appendix C.
Table 4 summarizes field measurement activities.
Page 6 of 11
-------
Table 4. FIELD MEASUREMENT ACTIVITIES
Location
Identifier
Date(s)
and Time
Method aiul/or Procedure1, and
Equipment
Measurer Name
Luke Rodriguez
9/12/23
Region 7 procedure: FUR ThermaCAM™ GasFindlR,
GF320, and Similar Infrared Cameras,
Equipment: FLIR, ThermaCAMrM, and S/N: 44401969
Luke Rodriguez
Luke Rodriguez
9/12/23
9:25 AM to
10:03 AM
Region 7 procedure: Safety and Sample Screening
Instruments,
Instrument giiide(s):
MultiRAE+ Multi-Gas Monitoring Equipment
Equipment: Honeywell, ppbRAE 3()()()+, SN:594-916195.
Robert Barnacle
1 The current version of each procedure, at the time of the investigation, was followed.
INVESTIGATION OBSERVATIONS ANP POTENTIAL FINDINGS
Ambient weather, site conditions and activities were documented in field records. All
photographs are attached as Appendix I). I made the observations described in this section
during the inspection. I discussed all observations with facility representatives during the
closeout meeting unless otherwise noted in the observation description.
These observations are not final compliance determinations. The EPA Region 7 Air Branch case
review team will make the final compliance determinations based on its review of this report and
other technical, regulatory, and facility information.
§63.5796 explains the emission factor equations in Table 1 to the rule and how they are used to
determine the organic HAP content of the materials used. In lieu of the equations, a facility can
use site specific organic HAP emission factors that are incorporated into the facility's permit
based on emissions test data. Superior Home Products uses the Safety Data Sheets (SDS)
provided by the manufacturers. These SDS are included as Appendix 0.
§63.5799 outlines the appropriate method for calculating a facility's organic HAP emissions. The
options include using an approved emission factor using the equations in Table 1 of the rule, an
emission factor approved by the EPA, or a performance test. Superior Home Products uses the
throughput of its various materials multiplied by the HAP content specified by the SDS and a
percent emitted value which comes from an industry group, the American Composites
Manufacturers Association (A.CMA). Compilation of Air Emission Factors (AP42) 4.4 Polyester
Resin Plastic Products Fabrication specifically references the A.CMA. document in the reference
note "h" as appropriate to use to estimate emissions.
Page 7 of 11
-------
§63.5805 identifies the standards a reinforced plastic composite production facility must meet in
(a) through (h).
(a) Not applicable as Superior Home Products does not have a centrifugal casting or a
continuous casting/lamination operation.
(b) All operations at existing facilities must meet the organic HAP limits in Table 3 to the
subpart and the work practice standards in Table 4 to the subpart. Superior Home
Products maintains a document which demonstrates that all operations meet the Table 3
Organic HAP emissions limits. This document is attached as Appendix E. The
requirements for work practice standards in Table 4 are copied below with comments on
the applicability or the facility's method of demonstrating compliance.
Table 5. WORK PRACTICES STANDARDS REVIEW
Equipment:
Configuration
Requirement:
Comments
1. A new or existing
closed molding
operation using
compression/injection
molding
Uncover, unwrap or expose only one charge per
mold cycle per compression/injection molding
machine. For machines with multiple molds, one
charge means sufficient: material to fill all molds
for one cycle. For machines with robotic loaders,
no more than one charge may be exposed prior to
the loader. For machines fed by hoppers,
sufficient material may be uncovered to fill the
hopper. Hoppers must be closed when not: adding
materials. Materials may be uncovered to feed to
slitting machines. Materials must be recovered
after slitting.
According to Mr. Daggett, Superior
Home Products does not engage in
any compression/injection molding.
2. A new or existing
cleaning operation
Not: use cleaning solvents that contain HAP,
except: that styrene may be used as a cleaner in
closed systems, and organic HAP containing
cleaners may be used to clean cured resin from
application equipment. Application equipment:
includes any equipment: that directly contacts
resin.
According to Mr. Daggett, Superior
Home Products only uses methylene
chloride, an organic HAP, to clean
cured resin from application
equipment.
3. A new or existing
materials HAP
containing
materials storage
operation
Keep containers that store HAP-containing
materials closed or covered except: during the
addition or removal of materials. Bulk HAP-
containing materials storage tanks may be vented
as necessary for safety.
According to Mr. Daggett, Superior
Home Products keeps all HAP
containing material storage covered
when not: in use. There is one bulk
resin tank which contains styrene
which is vented for safety. This is
visible in Photo 11 of Appendix D.
Photo 12 shows other HAP
containing material storage. I did not:
observe any materials which were
uncovered.
4. An existing or new
SMC manufacturing
operation
Close or cover the resin delivery system to the
doctor box on each SMC manufacturing
machine. The doctor box itself may be open.
According to Mr. Daggett, Superior
Home Products does not engage in
SMC manufacturing.
5. An existing or new
SMC manufacturing
operation
Use a nylon containing film to enclose SMC.
Page 8 of 11
-------
6. All mixing or BMC
manufacturing
operations 1
Use mixer covers with no visible gaps present in
the mixer covers, except that gaps of up to 1 inch
are permissible around mixer shafts and any
required instrumentation. Mixers where the
emissions are fully captured and routed to a 95
percent efficient: control device are exempt from
this requirement.
According to Mr. Daggett, Superior
Home Products uses 1 mixing
machine. The machine is completely
enclosed until the point: where the
product exits the mixer onto the
casting line. This mixing machine is
visible in Photo 8 of Appendix D.
7. All mixing or BMC
manufacturing
operations 1
Close any mixer vents when actual mixing is
occurring, except that venting is allowed during
addition of materials, or as necessary prior to
adding materials or opening the cover for safety.
Vents routed to a 95 percent efficient: control
device are exempt from this requirement.
According to Mr. Daggett, the mixer
does not: have any vents and
materials are added via enclosed
chutes.
8. All mixing or BMC
manufacturing
operations 1
Keep the mixer covers closed while actual
mixing is occurring except when adding
materials or changing covers to the mixing
vessels.
The machine is completely enclosed
until the point: where the product
exits the mixer onto the casting line.
9. A new or existing
pultrusion operation
manufacturing parts. . .
i. Not allow vents from the building ventilation
system, or local or portable fans to blow directly
on or across the wet-out area(s)...
According to Mr. Daggett, Superior
Home Products does not: have a
pultrusion operation.
(c) Not applicable as Superior Home Products is not a new facility.
(d) Superior Home Products lias never reported more than 100 tons of HAP in a year. The
past 3 years of HAP and VOC emissions are included as Appendix F. The highest VOC
emissions during a consecutive 12-month period during the last 3 years occurred in the
12-month period ending March of 2021 and was 10.595 tons.
(e) Not applicable as Superior Home Products is not subject to paragraphs (a) or (c).
(f) Superior Home Products has never applied for an exemption from paragraph (e).
(g) Superior Home Products does have repair operations subject to § 63.5785 and complies
with '['able 3 by demonstrating that its materials meet the HAP emission limits. Table 4
does not have any specific applicable requirements to the facility's repair operations.
(h) Superior Home Products does not use an add-on control device to comply with this
subpart.
§ 63.5810 lists the options for meeting the standards for open molding and centrifugal casting
operations at new and existing sources. Superior Home Products uses an open molding operation
and complies with option (a) - that they demonstrate that individual resins or gel coats, as
applied, meet the applicable emission limits in Table 3. As noted above, the calculations that
Superior Home Products provided to demonstrate compliance with Table 3 are included as
Appendix E.
Page 9 of 11
-------
§ 63.5820 specifies the options for meeting the standards for continuous lamination/casting
operations. According to the definitions located at § 63.5935, Continuous casting means a
continuous process for fabricating composites in which composite materials are placed on an in-
line conveyor belt to produce cast sheets that are cured in an oven. Superior Home Products sets
up gel molds by hand, these are sprayed then cured in an oven. Following the gel mold, these are
hand pushed to the casting machine where they are set aside to dry. The units do not enter an
oven to cure following casting. Superior Home Products believes that this operation does not
meet the definition of a continuous casting operation.
§ 63.5830 applies to pultrusion operations. According to Mr. Daggett, Superior Home Products
does not engage in pultrusion operations.
§ 63.5845 specifies performance testing requirements. No performance tests are requi red for the
equipment in use by Superior Home Products.
§ 63.5855 requi res monitoring for add-on control devices. Superior Home Products does not use
any add-on control devices.
§ 63.5865 specifies additional requirements for continuous lamination/casting operations. As
explained above, Superior Home Products does not believe its casting process meets the
definition of a continuous casting operation.
§ 63.5870 explains calculation methodology for HAP emissions from a wet-out area. A. wet-out
area is not defined in the subpart. Mr. Daggett told me that there is no wet-out areas in use at the
facility.
§ 63.5875, § 63.5880, § 63.5885, and § 63.5890 are all applicable to continuous
lamination/casting operations. As explained above, Mr. Daggett does not believe that the
Superior Home Products operation meets the definition of a continuous casting operation in §
63.5935.
§ 63.5895 identifies continuous compliance requirements.
(a) Not applicable as Superior Home Products does not use an add-on control device.
(b) Superior Home Products does not monitor or collect any of the data identified under (b).
Page 10 of 11
-------
(c) Superior Home Products maintains records of the resin and gel coats in use, and their
organic HAP content.
(d) As noted in (d), facilities meeting compliance by demonstrating that the individual resins
and gel coats, as applied, meet the applicable emission limit, are not requi red to maintain
resin and gel coat usage records.
(e) Superior Home Products does not use any pultrusion machines.
§ 63.5900 identifies the methods to demonstrate continuous compliance with the standards in
(a)(1) through (4) and (b) and (c).
(a) (1) Superior Home Products does not use any add-on control equipment.
(2) Superior Home Products maintains an organic HAP emission factor value less than or
equal to the organic HAP emissions limit listed in Table 3 on a 12-month rolling average
and includes a statement that the individual resins as applied, meet the limits.
(3) Superior Home Products is subject to the emission limits in Table 3, not Table 7.
(4) A. review of the work practice standards found in Table 4 to Subpart WWWW is
included above in Table 5 to this report.
(b) Superior Home Products as not ever reported any deviations from the requirements in 40
CFR 63 Subpart WWWW.
(c) Requires that the emission limits and work practice standards apply at all times.
§ 63.5910 outlines reporting requirements. Superior Home Products submits a semi-annual
compliance report as an attachment to its Semi-Annual Part 70 Report. The compliance report
must include the information in paragraphs (c)(1) through (6). I reviewed a report which
contained all of this requi red information.
§ 63.5915 identifies records which must be kept by the affected facility. I reviewed the records
required under (a), (c) and (d) as part of this inspection. Records requi red under (b) are not
applicable to this facility.
End of report.
Page 11 of 11
------- |