DAQ-2024-011735

DAQE-AN158670002-24

{{$d1 }}

Rodney Slade
Rockwell, LLC
786 West Spring Creek Place, Suite #5
Springville, UT 84663
[e-mail]

Dear Mr. Slade:

Re: Approval Order: New Approval Order for a Composite Window Well Manufacturing Plant
Project Number: N158670002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
20, 2024. Rockwell, LLC must comply with the requirements of this AO, all applicable state requirements
(R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Utah County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

October 31, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN158670002-24
New Approval Order for a Composite Window
Well Manufacturing Plant

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Rockwell, LLC - Springville Window Well Manufacturing

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

October 31, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN158670002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Rockwell, LLC Rockwell, LLC - Springville Window Well Manufacturing

Mailing Address Physical Address
786 West Spring Creek Place, Suite #5 786 West Spring Creek Place, Suite #5
Springville, UT 84663 Springville, UT 84663

Source Contact UTM Coordinates
Name: Rodney Slade 446,818 m Easting
Phone: [phone],448,411 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3089 (Plastics Products, NEC)

SOURCE INFORMATION
General Description
Rockwell, LLC (Rockwell) is requesting a new AO for an existing composite window well manufacturing
facility in Springville, Utah County. Rockwell uses a manufacturing process that uses polyester resin to
create window wells for the construction market. The manufacturing process includes the use of polyester
resin molds, curing ovens, and sanding and finishing operations.

NSR Classification
New Minor Source

Source Classification
Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
None
Project Description
Rockwell was previously operating under UAC R307-401-9, Small Source Exemption, and is expanding
operations. Rockwell uses a manufacturing process that uses polyester resin to create window wells for
the construction market. The manufacturing process includes the use of polyester resin molds, curing
ovens, and sanding and finishing operations.

DAQE-AN158670002-24
Page 4

Raw materials (parts) are measured and loaded into a mold. The mold is closed, and all emissions are
evacuated via a vacuum pump. The part in the mold is then transferred to a curing oven. Once cured, the
part is removed from the mold to be sanded and mounted. As part of the finishing process, an automotive
clear coat is sprayed over the window well.

Emissions from the process primarily come from polyester resin in the production of the window well and
from polyurethane clear coat and adhesive. The emissions from the resin come through vacuum pumps
and are removed from the building by turbines. The emissions from the clear coat and adhesive come
through a spray gun and are removed from the building by turbines. Both are filtered.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 800.00
Carbon Monoxide 0.56
Nitrogen Oxides 0.67
Particulate Matter - PM10 6.84
Particulate Matter - PM2.5 2.45
Sulfur Dioxide 0.01
Volatile Organic Compounds 16.63

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20
Styrene (CAS #100425) 10080
Change (TPY) Total (TPY)
Total HAPs 5.05

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
DAQE-AN158670002-24
Page 5

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Rockwell, LLC Composite Window Well Manufacturer
II.A.2 One (1) Paint Booth Finishing booth equipped with high-volume low-pressure (HVLP) spray guns Controls: Fabric filter II.A.3 Eight (8) Polyester Resin Mold Stations Controls: Vacuum system discharge to fabric filters and carbon filtration units
II.A.4 Six (6) Curing Ovens Maximum Rated Capacity: 0.1 MMBtu/hr (each) Fuel: Natural Gas II.A.5 Miscellaneous Process Boilers and Heaters Maximum Rated Capacity: Less than 5.0 MMBtu/hr (each) Fuel: Natural Gas
II.A.6 Sanding Equipment Control: Six (6) box fabric filters

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide Requirements and Limitations
II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
DAQE-AN158670002-24
Page 6

II.B.1.b The owner/operator shall use only natural gas in all fuel-burning equipment on site. [R307-401-8] II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers. [R307-401-8]

II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting, coating, resin mold operations, and/or cleaning) on site: A. 16.59 tons per rolling 12-month period of VOCs. B. 5.04 tons per rolling 12-month period of styrene. [R307-401-8]
II.B.1.d.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass balance method to
calculate emissions from evaporative sources. The owner/operator may use the following
equations with applicable units to comply with the mass balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed].
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed].

[R307-401-8]
II.B.1.d.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]
II.B.1.d.3 The owner/operator shall keep records each month of the following:
A. The name (as per SDS) of the VOC- and HAP-emitting material.
B. The maximum percent by weight of VOCs and each HAP in each material used.

C. The density of each material used.
D. The volume of each VOC- and HAP-emitting material used.
E. The amount of VOCs and the amount of each HAP emitted from each material.

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material.

G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons).

[R307-401-8]

II.B.2 Paint Booth Requirements
II.B.2.a The paint booths shall be equipped with HVLP spray guns or an equivalent method to control
VOC emissions. [R307-401-8]

DAQE-AN158670002-24
Page 7

II.B.2.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8] II.B.2.c The owner/operator shall install paint arrestor particulate filters, or equivalent, that are each
certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8]
II.B.2.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed paint arrestor particulate filters or equivalent. [R307-401-8] II.B.2.d The owner/operator shall comply with all applicable requirements of UAC Rule R307-342.
Adhesives and Sealants. [R307-342]
II.B.2.e The owner/operator shall comply with all applicable requirements of UAC Rule R307-353. Plastic Parts Coatings. [R307-353] II.B.3 Polyester Resin Mold Requirements
II.B.3.a The owner/operator shall equip each polyester resin mold with a vacuum pump discharged to a carbon adsorption filter to control emissions. [R307-401-8] II.B.3.b The owner/operator shall maintain and replace each carbon adsorption filter in accordance with
the manufacturer's recommendations and/or instructions. [R307-401-8]

II.B.3.c The owner/operator shall not use any resin that contains any HAPs except for styrene. [R307-401-8]
II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the Safety Data Sheet (SDS) for the resins. [R307-401-8]

II.B.3.d The owner/operator shall not operate the resin mold stations for more than 4,400 hours combined per rolling 12-month period. [R307-401-8]
II.B.3.d.1 The owner/operator shall:
A. Determine hours of operation by monitoring and maintaining an operations log.

B. Record hours of operation each day.
C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months.
D. Keep hours of operation records for all periods the plant is in operation.
[R307-401-8]

II.B.4 Sanding Requirements
II.B.4.a The owner/operator shall equip each sanding booth with particulate filters, or equivalent, to
control particulate emissions. All air exiting the booths shall pass through this control system
before being vented to the atmosphere. [R307-401-8]

DAQE-AN158670002-24
Page 8

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated August 20, 2024

DAQE-AN158670002-24
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Rockwell, LLC 15867 0002 - Page 1 of 2
FILER
Jeree Greenwood
[e-mail]
[phone]
FILING FOR
Daily Herald
Columns Wide:1 Ad Class:Legals
INTERIM AD DRAFT
This is the proof of your ad scheduled to run in Daily Herald on the dates indicated below. If changes
are needed, please contact us prior to deadline at [phone].
Notice ID: x5Bx5VJDRoSuJgh9SbzV | Proof Updated: Sep. 19, 2024 at 05:07pm MDT
Notice Name: Rockwell, LLC 15867 0002
This is not an invoice. Below is an estimated price, and it is
subject to change. You will receive an invoice with the final
price upon invoice creation by the publisher.
09/25/2024: Custom 101.64
Affidavit Fee 12.00
Subtotal $113.64
Tax %0
Processing Fee $11.36
Total $125.00
See Proof on Next Page
Rockwell, LLC 15867 0002 - Page 2 of 2
Daily Herald
Publication Name:
Daily Herald
Publication URL:
Publication City and State:
Provo, UT
Publication County:
Utah
Notice Popular Keyword Category:
Notice Keywords:
rockwell
Notice Authentication Number:
202409251742292540295
3429962642
Notice URL:
Back
Notice Publish Date:
Wednesday, September 25, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Rockwell, LLC Location: Rockwell, LLC - Springville Window Well Manufacturing -
786 West Spring Creek Place, Suite #5, Springville, UT Project Description: Rockwell, LLC (Rockwell) was previously operating under UAC
R307-401-9, Small Source Exemption, and is expanding operations. Rockwell uses a manufacturing process that uses polyester resin to
create window wells for the construction market. The manufacturing process includes the use of polyester resin molds, curing ovens, and
sanding and finishing operations. Raw materials (parts) are measured and loaded into a mold. The mold is closed, and all emissions are
evacuated via a vacuum pump. The part in the mold is then transferred to a curing oven. Once cured, the part is removed from the mold to
be sanded and mounted. As part of the finishing process, an automotive clear coat is sprayed over the window well. Emissions from the
process primarily come from polyester resin in the production of the window well and from polyurethane clear coat and adhesive. The
emissions from the resin come through vacuum pumps and are removed from the building by turbines. The emissions from the clear coat
and adhesive come through a spray gun and are removed from the building by turbines. Both are filtered. The completed engineering
evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the
State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal,
estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air
Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before
October 25, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will
also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing
will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise
an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient
information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: September
25, 2024 Legal Notice 13261 Published in the Daily Herald on September 25, 2024
Back

DAQE-IN158670002-24

September 23, 2024

Rodney Slade
Rockwell, LLC
786 West Spring Creek Place, Suite #5
Springville, UT 84663
[e-mail]

Dear Mr. Slade:

Re: Intent to Approve: New Approval Order for a Composite Window Well Manufacturing Plant
Project Number: N158670002

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Christine Bodell, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:CB:jg

cc: Utah County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN158670002-24
New Approval Order for a Composite Window
Well Manufacturing Plant

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Rockwell, LLC - Springville Window Well Manufacturing

Issued On
September 23, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN158670002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Rockwell, LLC Rockwell, LLC - Springville Window Well Manufacturing

Mailing Address Physical Address
786 West Spring Creek Place, Suite #5 786 West Spring Creek Place, Suite #5
Springville, UT 84663 Springville, UT 84663

Source Contact UTM Coordinates
Name: Rodney Slade 446,818 m Easting
Phone: [phone],448,411 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3089 (Plastics Products, NEC)

SOURCE INFORMATION
General Description
Rockwell, LLC (Rockwell) is requesting a new AO for an existing composite window well manufacturing
facility in Springville, Utah County. Rockwell uses a manufacturing process that uses polyester resin to
create window wells for the construction market. The manufacturing process includes the use of polyester
resin molds, curing ovens, and sanding and finishing operations.
NSR Classification
New Minor Source

Source Classification
Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
None
Project Description
Rockwell was previously operating under UAC R307-401-9, Small Source Exemption, and is expanding
operations. Rockwell uses a manufacturing process that uses polyester resin to create window wells for
the construction market. The manufacturing process includes the use of polyester resin molds, curing
ovens, and sanding and finishing operations.

DAQE-IN158670002-24
Page 4

Raw materials (parts) are measured and loaded into a mold. The mold is closed, and all emissions are
evacuated via a vacuum pump. The part in the mold is then transferred to a curing oven. Once cured, the
part is removed from the mold to be sanded and mounted. As part of the finishing process, an automotive
clear coat is sprayed over the window well.

Emissions from the process primarily come from polyester resin in the production of the window well and
from polyurethane clear coat and adhesive. The emissions from the resin come through vacuum pumps
and are removed from the building by turbines. The emissions from the clear coat and adhesive come
through a spray gun and are removed from the building by turbines. Both are filtered.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 800.00
Carbon Monoxide 0.56
Nitrogen Oxides 0.67
Particulate Matter - PM10 6.84
Particulate Matter - PM2.5 2.45
Sulfur Dioxide 0.01
Volatile Organic Compounds 16.63

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20
Styrene (CAS #100425) 10080
Change (TPY) Total (TPY)
Total HAPs 5.05

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in The Daily Herald-Legal Advertising Department on September 25, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

DAQE-IN158670002-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT
II.A.1 Rockwell, LLC Composite Window Well Manufacturer

II.A.2 One (1) Paint Booth Finishing booth equipped with high-volume low-pressure (HVLP) spray guns Controls: Fabric filter
II.A.3 Eight (8) Polyester Resin Mold Stations Controls: Vacuum system discharge to fabric filters and carbon filtration units

DAQE-IN158670002-24
Page 6

II.A.4 Six (6) Curing Ovens Maximum Rated Capacity: 0.1 MMBtu/hr (each) Fuel: Natural Gas II.A.5 Miscellaneous Process Boilers and Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr (each) Fuel: Natural Gas
II.A.6 Sanding Equipment Control: Six (6) box fabric filters

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements and Limitations II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use only natural gas in all fuel-burning equipment on site. [R307-401-8]
II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers. [R307-401-8] II.B.1.d The owner/operator shall not emit more than the following from evaporative sources (painting, coating, resin mold operations, and/or cleaning) on site: A. 16.59 tons per rolling 12-month period of VOCs. B. 5.04 tons per rolling 12-month period of styrene. [R307-401-8]
II.B.1.d.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8]
DAQE-IN158670002-24
Page 7

II.B.1.d.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]
II.B.1.d.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material.
B. The maximum percent by weight of VOCs and each HAP in each material used.
C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used.
E. The amount of VOCs and the amount of each HAP emitted from each material.

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material.

G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons).

[R307-401-8]
II.B.2 Paint Booth Requirements
II.B.2.a The paint booths shall be equipped with HVLP spray guns, or an equivalent method to control
VOC emissions. [R307-401-8]
II.B.2.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.2.c The owner/operator shall install paint arrestor particulate filters, or equivalent, that are each
certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8]
II.B.2.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed paint arrestor particulate filters or equivalent. [R307-401-8]
II.B.2.d The owner/operator shall comply with all applicable requirements of UAC Rule R307-342.
Adhesives and Sealants. [R307-342]
II.B.2.e The owner/operator shall comply with all applicable requirements of UAC Rule R307-353. Plastic Parts Coatings. [R307-353]
II.B.3 Polyester Resin Mold Requirements
II.B.3.a The owner/operator shall equip each polyester resin mold with a vacuum pump discharged to a carbon adsorption filter to control emissions. [R307-401-8]
II.B.3.b The owner/operator shall maintain and replace each carbon adsorption filter in accordance with
the manufacturer's recommendations and/or instructions. [R307-401-8]

II.B.3.c The owner/operator shall not use any resin that contains any HAPs except for styrene. [R307-401-8]
DAQE-IN158670002-24
Page 8

II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the Safety Data Sheet (SDS) for the resins. [R307-401-8] II.B.3.d The owner/operator shall not operate the resin mold stations for more than 4,400 hours combined per rolling 12-month period. [R307-401-8]

II.B.3.d.1 The owner/operator shall: A. Determine hours of operation by monitoring and maintaining an operations log. B. Record hours of operation each day. C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep hours of operation records for all periods the plant is in operation. [R307-401-8] II.B.4 Sanding Requirements
II.B.4.a The owner/operator shall equip each sanding booth with particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated August 20, 2024

DAQE-IN158670002-24
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-NN158670002-24

September 23, 2024

The Daily Herald
Legal Advertising Department
PO Box 717
Provo, UT 84603

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Daily Herald-Legal
Advertising Department on September 25, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Mountainland Association of Governments
cc: Utah County

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN158670002-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Rockwell, LLC
Location: Rockwell, LLC - Springville Window Well Manufacturing – 786 West Spring
Creek Place, Suite #5, Springville, UT
Project Description: Rockwell, LLC (Rockwell) was previously operating under UAC R307-401-9,
Small Source Exemption, and is expanding operations. Rockwell uses a
manufacturing process that uses polyester resin to create window wells for the
construction market. The manufacturing process includes the use of polyester
resin molds, curing ovens, and sanding and finishing operations.

Raw materials (parts) are measured and loaded into a mold. The mold is closed,
and all emissions are evacuated via a vacuum pump. The part in the mold is then
transferred to a curing oven. Once cured, the part is removed from the mold to be
sanded and mounted. As part of the finishing process, an automotive clear coat is
sprayed over the window well.

Emissions from the process primarily come from polyester resin in the
production of the window well and from polyurethane clear coat and adhesive.
The emissions from the resin come through vacuum pumps and are removed
from the building by turbines. The emissions from the clear coat and adhesive
come through a spray gun and are removed from the building by turbines. Both
are filtered.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before October 25, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: September 25, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN158670002 September 16, 2024 Rodney Slade Rockwell, LLC 786 West Spring Creek Place, Suite #5 Springville, UT 84663
[e-mail] Dear Rodney Slade,
Re: Engineer Review: New Approval Order for a Composite Window Well Manufacturing Plant
Project Number: N158670002 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Rockwell, LLC should complete this review within 10 business days of receipt.
Rockwell, LLC should contact Christine Bodell at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Rockwell, LLC does not respond to this letter within 10 business days, the project will move forward
without source concurrence. If Rockwell, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.
Approval Signature _____________________________________________________________ (Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N158670002 Owner Name Rockwell, LLC Mailing Address 786 West Spring Creek Place, Suite #5 Springville, UT, 84663 Source Name Rockwell, LLC - Springville Window Well Manufacturing Source Location 786 West Spring Creek Place, Suite #5 Springville, UT 84663
UTM Projection 446,818 m Easting, 4,448,411 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12
SIC Code 3089 (Plastics Products, NEC) Source Contact Rodney Slade
Phone Number [phone] Email [e-mail]
Billing Contact Rodney Slade Phone Number [phone] Email [e-mail] Project Engineer Christine Bodell, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted August 27, 2024 Date of Accepted Application September 10, 2024

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 2
SOURCE DESCRIPTION General Description
Rockwell, LLC (Rockwell) is requesting a new AO for an existing composite window well manufacturing facility in Springville, Utah County. Rockwell uses a manufacturing process that uses polyester resin to create window wells for the construction market. The manufacturing
process includes the use of polyester resin molds, curing ovens, and sanding and finishing operations.
NSR Classification: New Minor Source
Source Classification Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA Utah County
Airs Source Size: B Applicable Federal Standards None Project Proposal New Approval Order for a Composite Window Well Manufacturing Plant
Project Description Rockwell was previously operating under UAC R307-401-9, Small Source Exemption, and is expanding operations. Rockwell uses a manufacturing process that uses polyester resin to create
window wells for the construction market. The manufacturing process includes the use of polyester resin molds, curing ovens, and sanding and finishing operations.
Raw materials (parts) are measured and loaded into a mold. The mold is closed and all emissions are evacuated via a vacuum pump. The part in the mold is then transferred to a curing oven. Once cured, the part is removed from the mold to be sanded and mounted. As part of the finishing
process, an automotive clear coat is sprayed over the window well. Emissions from the process primarily come from polyester resin in the production of the window
well and from polyurethane clear coat and adhesive. The emissions from the resin come through vacuum pumps and are removed from the building by turbines. The emissions from the clear coat and adhesive come through a spray gun and are removed from the building by turbines. Both are filtered. EMISSION IMPACT ANALYSIS
All potential emissions of criteria pollutants and HAPs are below the respective modeling thresholds contained in UAC R307-410-4 and R307-410-5. Therefore, a modeling analyses is not required. [Last updated August 27, 2024]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 3
SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 800.00
Carbon Monoxide 0.56
Nitrogen Oxides 0.67
Particulate Matter - PM10 6.84
Particulate Matter - PM2.5 2.45
Sulfur Dioxide 0.01 Volatile Organic Compounds 16.63 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 20
Styrene (CAS #100425) 10080
Change (TPY) Total (TPY)
Total HAPs 5.05 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding New Emission Units
Polyester Resin Mold Stations: The polyester resin mold stations will have the potential to emit styrene, which is a VOC and HAP. The following control technologies have been identified as VOC and HAPs emissions control for
these types of processes: incineration technologies and adsorption technologies. Incineration is not technically feasible due to the low concentration of VOC and HAPs in the vent stream, and manufacturing companies being unable to offer proven incineration technologies for VOC and HAP removal from a resin mold process. Carbon adsorption is technically feasible. Therefore, the use of carbon adsorption filters is considered BACT.
Additionally, using a closed mold compared to open mold methods reduces emissions by as much
as 80%. Therefore, the molds will be closed during molding operations and the emissions will be removed via a vacuum pump. The DAQ considers this and the use of carbon filtration filters to be BACT.
Finishing Paint Booth: The finishing operations that take place within the paint booth will have the potential to emit PM10, PM2.5, VOC, and HAP emissions. Technologies to control PM10 /PM2.5 include electrostatic precipitators (ESP), particulate filters, and high-volume low-pressure (HVLP) spray guns. ESPs are considered technically infeasible for the spray booth as they are most effective on metals and items of high resistivity. Particulate fabric filters remove particulate matter via filtration. HVLP spray guns reduce PM emissions from paint application by increasing paint application efficiency.
HVLP spray guns result in better coverage and less material loss. The paint booth will be equipped with both HVLP spray guns and paint arrestor fabric filters or equivalent to reduce the overspray of clear coat. The filters or equivalent will each have a minimum 95% particulate control
efficiency. All air exiting the paint booth will be required to pass through the filters or equivalent control PM10 and PM2.5 emissions before being vented to the atmosphere. Additionally, the paint booth will be required to comply with a 10% opacity limit. Due to the low emissions of VOCs and HAPs, additional VOC and HAP control would not be cost effective.
UAC R307-342, Adhesives and Sealants, and UAC R307-353, Plastic Parts Coatings, will apply to the coating and finishing operations, which will limit VOC and HAP emissions from the process. The UDAQ considers the controls and measures listed above as BACT for the finishing operations
paint booth. Sanding Operations:
Once the parts are cured, they are sanded. Sanding is done using abrasive disc sanders to grind and smooth the mold parts. Because the sanding is not done via "abrasive blasting", PM10 and PM2.5 emissions are minimal (<0.00001 tpy, each). Due to the low volume of emissions, additional add-on control technologies are not cost-effective. However, Rockwell has elected to collect the dust from the sanding operation using six (6) 20" X 20" X 15" cube filters that are vacuumed out at the end of each shift. Therefore, the use of filters is considered BACT. Natural Gas-Combustion Equipment:
The facility will operate six (6) natural gas-fired curing ovens, each rated at 0.1 MMBtu/hr, as well as various natural gas-fired boilers and heaters each rated 0.24 MMBtu/hr. This equipment is

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 5
exempt under R307-401-10 as it is "Fuel-burning equipment in which combustion takes place at no greater pressure than one inch of mercury above ambient pressure with a rated capacity of less than
5 MMBtu/hr using no other fuel than natural gas...". Therefore, a BACT analysis is not required for this equipment. [Last updated September 12, 2024]

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 6
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Rockwell, LLC Composite Window Well Manufacturer II.A.2 One (1) Paint Booth Finishing booth equipped with high-volume low-pressure (HVLP) spray guns
Controls: Fabric filter II.A.3 Eight (8) Polyester Resin Mold Stations Controls: Vacuum system discharge to fabric filters and carbon filtration units

II.A.4 Six (6) Curing Ovens Maximum Rated Capacity: 0.1 MMBtu/hr (each) Fuel: Natural Gas
II.A.5 Miscellaneous Process Boilers and Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr (each) Fuel: Natural Gas
II.A.6 Sanding Equipment
Control: Six (6) box fabric filters
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements and Limitations II.B.1.a NEW The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10% opacity. [R307-401-8]

II.B.1.a.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use only natural gas in all fuel-burning equipment on site. [R307-401-8]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 7
II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers. [R307-401-8] II.B.1.d NEW The owner/operator shall not emit more than the following from evaporative sources (painting, coating, resin mold operations, and/or cleaning) on site:
A. 16.59 tons per rolling 12-month period of VOCs
B. 5.04 tons per rolling 12-month period of styrene [R307-401-8]
II.B.1.d.1 NEW The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.1.d.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed
from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8]
II.B.1.d.3
NEW
The owner/operator shall keep records each month of the following:
A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material
F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons) [R307-401-8] II.B.2 Paint Booth Requirements
II.B.2.a NEW The paint booths shall be equipped with HVLP spray guns, or an equivalent method, to control VOC emissions. [R307-401-8]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 8
II.B.2.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.2.c
NEW
The owner/operator shall install paint arrestor particulate filters, or equivalent, that are each
certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8] II.B.2.c.1 NEW To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed paint arrestor particulate
filters, or equivalent. [R307-401-8] II.B.2.d NEW The owner/operator shall comply with all applicable requirements of UAC Rule R307-342. Adhesives and Sealants. [R307-342]
II.B.2.e
NEW
The owner/operator shall comply with all applicable requirements of UAC Rule R307-353.
Plastic Parts Coatings. [R307-353] II.B.3 Polyester Resin Mold Requirements
II.B.3.a NEW The owner/operator shall equip each polyester resin mold with a vacuum pump discharged to a carbon adsorption filter to control emissions. . [R307-401-8]
II.B.3.b
NEW
The owner/operator shall maintain and replace each carbon adsorption filter in accordance
with the manufacturer's recommendations and/or instructions. [R307-401-8] II.B.3.c NEW The owner/operator shall not use any resin that contains any HAPs except for styrene. [R307-401-8]

II.B.3.c.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the Safety Data Sheet (SDS) for the resins. [R307-401-8] II.B.3.d NEW The owner/operator shall not operate the resin mold stations for more than 4,400 hours combined per rolling 12-month period. [R307-401-8]

II.B.3.d.1 NEW The owner/operator shall: A. Determine hours of operation by monitoring and maintaining an operations log
B. Record hours of operation each day
C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months
D. Keep hours of operation records for all periods the plant is in operation
[R307-401-8]
II.B.4
NEW
Sanding Requirements

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 9
II.B.4.a NEW The owner/operator shall equip each sanding booth with particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 10
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Is Derived From NOI dated August 20, 2024
REVIEWER COMMENTS
1. Comment regarding Source Emission Estimates and DAQ Acceptance:
The PTE was estimated from the following sources: natural gas combustion equipment (including curing ovens and miscellaneous boilers and heaters), new paint spray booth operations, and new resin molding operations.
Natural Gas Combustions:
Criteria pollutant and HAP emissions from the natural gas combustion equipment were obtained from EPA's AP-42, Fifth Edition emission factors in Section 1.4. GHG emission factors were obtained from 40 CFR 98 Subpart C.
Paint Spray Booth Operations: The PM10 and PM2.5 emissions from the paint spray booth coating operations were calculated using the number of spray guns and maximum paint usage or adhesive per spray gun. A transfer efficiency of 65% for spray coating was used, taken from instructions for painting/coating operations emission calculations by the Minnesota Pollution Control Agency. A control efficiency of 95% was applied for the cartridge filter system (or equivalent) controlling the spray coating booths. VOC and HAP emissions from the paint spray booth were estimated based on a mass balance calculation using SDS sheets for the coatings used in the operation.
Resin Molding Operations: The VOC and HAP emissions from the resin molding operations were estimated based on a closed mold process emission factor of 0.02 (Air Quality Management District (AQMD) Guidelines for Calculating Emissions from Polyester Resin Operations, 2019). Assumptions were based on using the "closed mold" technique and a maximum styrene content of 40% for the polyester resin. Emissions were based on a projected usage of 1,260,000 lbs of resin usage annually and a total of 4,400 hours of operation, annually. Sanding/Cutting Operations: Rockwell uses disc sanders to smooth down the final product. While this method results in less emissions than the "abrasive blasting" sanding method, AP-42 Section 13.2.6 Abrasive Blasting was used to determine emissions. Abrasive blasting controlled with a filter
results in 0.69 lbs of PM per 1,0000 lbs of abrasive used. Disc sanders are essentially sheets of sand paper, and thus have minimal weight. Total use of disc sanders was estimated to equate approximately 6 lbs annually. The corresponds to 0.0041 lb PM per year, or 0.000002 tpy of PM. [Last updated September 10, 2024] 2. Comment regarding NSPS and MACT Applicability: The UDAQ has identified no applicable NSPS and MACT standards for this manufacturing process. [Last updated September 4, 2024]
3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act applies to the following:
1. Any major source

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 11
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources
3. Any source subject to another standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants 4. Any Title IV affected source
This facility is not a major source, Title IV source, or subject to a standard under Sections 111 or 112 of the Act. There are no other reasons why this source would be required to obtain a Part 70 permit; therefore, Title V does not apply to this facility. [Last updated August 27, 2024]

Engineer Review N158670002: Rockwell, LLC - Springville Window Well Manufacturing September 16, 2024 Page 12
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations
CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard
NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
ECR23-040-1223
PRODUCT DESCRIPTION
TensorGrip P322 is an aggressive and fast-drying pressure sensitive adhesive designed to bond to a vast range of
substrates and maintain tackiness.
ADVANTAGES
• Very fast drying
• Long lasting high tack (pressure sensitive)
• Moisture and weather-resistant bond
DIRECTIONS FOR USE
• TensorGrip P322 is designed as a portable, self-
contained spray system for field or shop applications.
• Apply adhesive to one or both surfaces to be mated, at
80% to 100% coverage.
• Allow enough time (2-4 minutes or until dry to the touch)
for the adhesive to become tacky before bonding.
• Parts should be mated with as much pressure as
practical.
• Normal coverage required with web spray pattern is
approximately 80%; however, porous surfaces may
need a second coat. Initial bond is strong enough to
allow cutting or trimming immediately, although ultimate
strength is achieved in 1-3 days.
• Canister system will spray adequately above 60º F.
Canister system should be kept in warm area. In the
event that the canister gets abnormally chilled, freezes or
gives poor or sputtering spray, it should be warmed up
before continued usage. Warming canister by immersion
in warm water is recommended.
• Notice!!! Do not store at temperatures over 120º F.
CANISTER STORAGE/CHANGE OVER
• If you choose to leave the hose and spray gun on the
canister, leave the valve on the canister open. Do not
disconnect the hose/gun from the canister. Close and
lock the spray gun.
• To change or disconnect canister: turn canister valve
to the off position, spray out remaining adhesive left
in the hose, disconnect the spray hose and gun from
the canister.
• Reconnect the spray hose to a new canister of
adhesive. OR if you are NOT connecting to a new
canister, connect hose to canister of cleaning solvent
(sold separately) and spray out until liquid is clear
which indicates that the hose and gun is clean.
P322 FAST DRY
PRESSURE SENSITIVE ADHESIVE DATA SHEET
As part of our INDUSTRIAL range, P322 is a web spray adhesive designed for use in applications using the substrates listed.
• Will not attack polystyrene
• Full strength achieved in 24 hours
• No ODS (ozone depleting substances)
QUIN GLOBAL US
5510 F ST, Omaha NE 68117
PH: [phone] | [e-mail] | www.quinglobal.com
Polystyrene Foam Insulation Fabric
ECR23-040-1223
CHEMICAL TECHNICAL DATA
TYPICAL PROPERTIES
• Total Solids 26-32%
• VOC Content 552 g/L
• Color Clear, Green; Aerosols Green Only
• System Flammability Flammable Adhesive; Flammable Propellant
• Solvent System Flammable
• Dry time 2-4 mins dependent on temp & humidity
• Open time Long
• Shelf Life 18 months from date of manufacture
PACKAGING
• 650 ml Aerosol Can
• 22L Disposable Canister
• 108L Returnable Canister
• 216L Returnable Canister
DATA SHEET
QUIN GLOBAL US
5510 F ST, Omaha NE 68117
PH: [phone] | [e-mail] | www.quinglobal.com
STORAGE
HANDLING & STORAGE
• Consult Material Safety Data Sheet prior to use.
• Do not store at temperatures over 120°F/50°C.
• Avoid exposure to direct sunlight.
• Do not store directly on concrete floor.
• Always store above 60°F/15°C
• When connected, keep valve open and hose
pressurized at all times
• Always test our adhesives to determine suitability for
your particular application prior to use in production
DISCLAIMER OF WARRANTY: Quin Global makes neither warranty of merchantability or fitness for any use nor any other warranty, express or implied, in the sales of its products. Buyer assumes all risk and liability for the results obtained by the use of its products, whether used singly or in combination with other products.
P322 FAST DRY
PRESSURE SENSITIVE ADHESIVE
Revision date: 4/4/2017 Revision: 7 Supersedes date: 4/4/2017
SAFETY DATA SHEET
Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
1. Identification
Product identifier
Product name Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Product number USA
Recommended use of the chemical and restrictions on use
Application Canister Spray Adhesive
Details of the supplier of the safety data sheet
Supplier Tensorgrip
5710 F St
Omaha NE 68117
[phone]
[phone]
[e-mail]
Emergency telephone number
Emergency telephone Chemtrec: 1 800 424 9300
2. Hazard(s) identification
Classification of the substance or mixture
Physical hazards Flam. Aerosol 1 - H222 Press. Gas, Compressed - H280
Health hazards Acute Tox. 4 - H332 Skin Irrit. 2 - H315 Eye Irrit. 2A - H319 STOT SE 3 - H335, H336
Environmental hazards Aquatic Chronic 2 - H411
Human health The liquid may be irritating to eyes, respiratory system and skin. Symptoms following
overexposure may include the following: Headache. Dizziness. Nausea, vomiting.
Label elements
Pictogram

Signal word Danger
Hazard statements H222 Extremely flammable aerosol.
H280 Contains gas under pressure; may explode if heated.
H315 Causes skin irritation.
H319 Causes serious eye irritation.
H332 Harmful if inhaled.
H335 May cause respiratory irritation.
H336 May cause drowsiness or dizziness.
H411 Toxic to aquatic life with long lasting effects.
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Precautionary statements P210 Keep away from heat, sparks, open flames and hot surfaces. No smoking.
P211 Do not spray on an open flame or other ignition source.
P251 Pressurized container: Do not pierce or burn, even after use
P304+P340 If inhaled: Remove person to fresh air and keep comfortable for breathing.
P305+P351+P338 If in eyes: Rinse cautiously with water for several minutes. Remove contact
lenses, if present and easy to do. Continue rinsing.
P412 Do not expose to temperatures exceeding 50°C/122°F.
Supplemental label
information
AT(d) 31.4% of the mixture consists of ingredient(s) of unknown acute dermal toxicity.
AT(o) 31.4% of the mixture consists of ingredient(s) of unknown acute oral toxicity.
Contains Dimethyl Ether, Pentane, Acetone
Other hazards
This product does not contain any substances classified as PBT or vPvB.
3. Composition/information on ingredients
Mixtures
Dimethyl Ether 30-60%
CAS number: 115-10-6
Classification
Flam. Gas 1 - H220
Press. Gas, Liquefied - H280
Acute Tox. 4 - H332
Skin Irrit. 2 - H315
Eye Irrit. 2B - H320
STOT SE 3 - H335, H336
Pentane 30-60%
CAS number: 78-78-4
M factor (Acute) = 1
Classification
Flam. Liq. 1 - H224
Eye Irrit. 2A - H319
STOT SE 3 - H336
Asp. Tox. 1 - H304
Aquatic Chronic 2 - H411
Acetone 1-5%
CAS number: 67-64-1
Classification
Flam. Liq. 2 - H225
Acute Tox. 4 - H302
Acute Tox. 4 - H312
Acute Tox. 4 - H332
Skin Irrit. 2 - H315
Eye Irrit. 2A - H319
STOT SE 3 - H336
2/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
The full text for all hazard statements is displayed in Section 16.
4. First-aid measures
Description of first aid measures
General information Remove affected person from source of contamination. Place unconscious person on their
side in the recovery position and ensure breathing can take place. Get medical attention if any
discomfort continues.
Inhalation Move affected person to fresh air and keep warm and at rest in a position comfortable for
breathing. When breathing is difficult, properly trained personnel may assist affected person
by administering oxygen. Get medical attention.
Ingestion Get medical attention immediately. Never give anything by mouth to an unconscious person.
Do not induce vomiting. Move affected person to fresh air and keep warm and at rest in a
position comfortable for breathing.
Skin Contact Remove affected person from source of contamination. Remove contaminated clothing. Wash
skin thoroughly with soap and water. Get medical attention if any discomfort continues.
Eye contact Remove any contact lenses and open eyelids wide apart. Only remove contact lenses if the
person is conscious, coherent and they can remove them themselves If adhesive bonding
occurs, do not force eyelids apart. Continue to rinse for at least 15 minutes. If in doubt, get
medical attention promptly. Show this Safety Data Sheet to the medical personnel.
Most important symptoms and effects, both acute and delayed
Inhalation May cause coughing and difficulties in breathing. May cause eye and respiratory system
irritation. Overexposure may depress the central nervous system, causing dizziness and
intoxication.
Ingestion Aspiration hazard if swallowed. May be fatal if swallowed and enters airways. Ingestion may
cause severe irritation of the mouth, the esophagus and the gastrointestinal tract. May Cause
the following effects: Gastrointestinal symptoms, including upset stomach. Central nervous
system depression. Nausea, vomiting. Entry into the lungs following ingestion or vomiting may
cause chemical pneumonitis.
Skin contact May be absorbed through the skin. Product has a defatting effect on skin. The liquid is
irritating to eyes and skin. A single exposure may cause the following adverse effects:
Dryness and/or cracking.
Eye contact Causes serious eye irritation. Burns can occur. A single exposure may cause the following
adverse effects: Pain. Conjunctivitis, irritation, tearing. Prolonged or repeated exposure may
cause the following adverse effects: Irritation of eyes and mucous membranes. Prolonged
contact causes serious eye and tissue damage.
5. Fire-fighting measures
Extinguishing media
Suitable extinguishing media Extinguish with alcohol-resistant foam, carbon dioxide or dry powder.
Unsuitable extinguishing
media
Do not use water jet as an extinguisher, as this will spread the fire.
Special hazards arising from the substance or mixture
Specific hazards Pressurized container: Must not be exposed to temperatures above 50°C/120°F Containers
can burst violently or explode when heated, due to excessive pressure build-up. Vapors are
heavier than air and may spread near ground and travel a considerable distance to a source
of ignition and flash back.
Advice for firefighters
3/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Special protective equipment
for firefighters
Wear positive-pressure self-contained breathing apparatus (SCBA) and appropriate protective
clothing.
6. Accidental release measures
Personal precautions, protective equipment and emergency procedures
Personal precautions For personal protection, see Section 8. No smoking, sparks, flames or other sources of
ignition near spillage.
Environmental precautions
Environmental precautions Avoid discharge into drains. Contain spillage with sand, earth or other suitable non-
combustible material.
Methods and material for containment and cleaning up
Methods for cleaning up Stop leak if possible without risk. Eliminate all sources of ignition. No smoking, sparks, flames
or other sources of ignition near spillage. Provide adequate ventilation. Avoid the spillage or
runoff entering drains, sewers or watercourses. Absorb in vermiculite, dry sand or earth and
place into containers. Wash thoroughly after dealing with a spillage.
7. Handling and storage
Precautions for safe handling
Usage precautions Avoid contact with skin and eyes. Keep away from heat, sparks and open flame. Provide
adequate ventilation. Avoid inhalation of vapors. Use approved respirator if air contamination
is above an acceptable level. Container must be kept tightly closed when not in use. Use
explosion proof electric equipment. Avoid discharge into drains or watercourses or onto the
ground.
Advice on general
occupational hygiene
Do not eat, drink or smoke when using this product.
Conditions for safe storage, including any incompatibilities
Storage precautions Keep away from heat, sparks and open flame. Keep container tightly closed. Keep only in the
original container. Pressurized container: Must not be exposed to temperatures above
50°C/120°F
Specific end uses(s)
Specific end use(s)The identified uses for this product are detailed in Section 1.
8. Exposure Controls/personal protection
Control parameters
Occupational exposure limits
Dimethyl Ether
Long-term exposure limit (8-hour TWA): WEEL:US.AIHA = Workplace Environmental Exposure Level Guides 1000 ppm
Pentane
Long-term exposure limit (8-hour TWA): ACGIH 600 ppm
Acetone
Long-term exposure limit (8-hour TWA): ACGIH 500 ppm
Short-term exposure limit (15-minute): ACGIH 750 ppm
A4
Long-term exposure limit (8-hour TWA): OSHA 1000 ppm 2400 mg/m³
Ceiling exposure limit: NIOSH: National Institute of Occupational Safety and Health 250 ppm 590 mg/m³ vapour
4/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
ACGIH = American Conference of Governmental Industrial Hygienists.
A4 = Not Classifiable as a Human Carcinogen.
OSHA = Occupational Safety and Health Administration.
Exposure controls
Protective equipment

Appropriate engineering
controls
This product must not be handled in a confined space without adequate ventilation. Avoid
inhalation of vapors and spray/mists. As this product contains ingredients with exposure limits,
process enclosures, local exhaust ventilation or other engineering controls should be used to
keep worker exposure below any statutory or recommended limits, if use generates dust,
fumes, gas, vapor or mist.
Eye/face protection Wear chemical splash goggles.
Hand protection Use protective gloves.
Other skin and body
protection
Wear appropriate clothing to prevent any possibility of liquid contact and repeated or
prolonged vapor contact.
Hygiene measures DO NOT SMOKE IN WORK AREA! Wash at the end of each work shift and before eating,
smoking and using the toilet. Wash promptly with soap and water if skin becomes
contaminated. Promptly remove any clothing that becomes contaminated. When using do not
eat, drink or smoke.
Respiratory protection Respiratory protection must be used if the airborne contamination exceeds the recommended
occupational exposure limit. If exposure levels are likely to be exceeded, use a half face mask
fitted with an organic vapor filter for short term low level exposures. For long term or high level
exposures, a supplied air respirator should be used.
9. Physical and Chemical Properties
Information on basic physical and chemical properties
Appearance Aerosol.
Color Clear. Green.
Odor Organic solvents.
Initial boiling point and range Not determined.
Flash point -41°C/-42°F Not specified.
Upper/lower flammability or
explosive limits
Lower flammable/explosive limit: 3.4 g/100 g Upper flammable/explosive limit: 18 g/100 g
Vapor pressure Not determined.
Vapor density Not determined.
Relative density .7087
Solubility(ies)Negligibly soluble in water
Volatile organic compound This product contains a maximum VOC content of 552.55 g/l.
10. Stability and reactivity
Stability Stable at normal ambient temperatures and when used as recommended.
5/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Conditions to avoid Avoid heat, flames and other sources of ignition. Avoid contact with the following materials:
Oxidizing agents. Reducing agents.
Hazardous decomposition
products
Fire creates: Vapours/gases/fumes of: Carbon monoxide (CO). Carbon dioxide (CO2).
Hydrogen chloride (HCl). Hydrocarbons. Aldehydes.
11. Toxicological information
Information on toxicological effects
Acute toxicity - oral
ATE oral (mg/kg)7,622.22
Acute toxicity - dermal
ATE dermal (mg/kg)16,768.89
Acute toxicity - inhalation
ATE inhalation (gases ppm)9,000.0
ATE inhalation (vapours mg/l)244.44
Toxicological information on ingredients.
Dimethyl Ether
Acute toxicity - inhalation
Acute toxicity inhalation
(LC₅₀ gases ppmV)
308.5
Species Rat
ATE inhalation (gases
ppm)
4,500.0
Carcinogenicity
Carcinogenicity Does not contain any substances known to be carcinogenic.
Specific target organ toxicity - single exposure
STOT - single exposure May cause respiratory irritation. Central nervous system depression. Skin and eye
irritation.
Aspiration hazard
Aspiration hazard No data available.
Medical Symptoms Central nervous system depression. Frostbite. Respiratory system irritation. Skin
irritation. Eye irritation.
Pentane
Acute toxicity - oral
ATE oral (mg/kg)100.0
Acute toxicity - dermal
ATE dermal (mg/kg)1,100.0
Acute toxicity - inhalation
Acute toxicity inhalation
(LC₅₀ vapours mg/l)
1,280.0
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Species Rat
ATE inhalation (vapours
mg/l)
11.0
Serious eye damage/irritation
Serious eye
damage/irritation
Irritation of eyes is assumed.
Germ cell mutagenicity
Genotoxicity - in vitro Ames Test Results: Negative.
Specific target organ toxicity - single exposure
STOT - single exposure May cause drowsiness or dizziness
Specific target organ toxicity - repeated exposure
STOT - repeated exposure Not classified as a specific target organ toxicant after repeated exposure.
Aspiration hazard
Aspiration hazard Entry into the lungs following ingestion or vomiting may cause chemical
pneumonitis.
General information Absorbtion of large quantities may cause: Dizziness. Euphoria. Agitation.
Convulsions. Narcosis.
Acetone
Acute toxicity - oral
Acute toxicity oral (LD₅₀
mg/kg)
5,800.0
Species Rat
ATE oral (mg/kg)500.0
Acute toxicity - dermal
Acute toxicity dermal (LD₅₀
mg/kg)
20,000.0
Species Rabbit
ATE dermal (mg/kg)1,100.0
Acute toxicity - inhalation
Acute toxicity inhalation
(LC₅₀ dust/mist mg/l)
76.0
Species Rat
ATE inhalation (vapours
mg/l)
11.0
Specific target organ toxicity - single exposure
STOT - single exposure May cause drowsiness or dizziness
Inhalation Mucosal irritations. Absorption.
7/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Ingestion Irritating. May cause nausea, stomach pain and vomiting. Aspiration hazard if
swallowed. Entry into the lungs following ingestion or vomiting may cause chemical
pneumonitis.
Skin Contact This product is moderately irritating. May be absorbed through the skin. Repeated
exposure may cause skin dryness or cracking.
Eye contact This product is strongly irritating. Risk of corneal clouding.
Route of exposure Inhalation Skin and/or eye contact
Target Organs Eyes
12. Ecological Information
13. Disposal considerations
Waste treatment methods
Disposal methods Dispose of waste to licensed waste disposal site in accordance with the requirements of the
local Waste Disposal Authority.
14. Transport information
Air transport notes Cargo aircraft only. <75kg
UN Number
UN No. (ICAO)3501
UN No. (DOT)3501
UN proper shipping name
Proper shipping name (TDG)Chemical Under Pressure, Flammable, N.O.S.
Proper shipping name (DOT)Chemical Under Pressure, Flammable, N.O.S.
Transport hazard class(es)
DOT hazard class 2.1
Transport labels
Packing group
Not applicable.
15. Regulatory information
US Federal Regulations
SARA Section 302 Extremely Hazardous Substances Tier II Threshold Planning Quantities
The following ingredients are listed or exempt:
Pentane
CERCLA/Superfund, Hazardous Substances/Reportable Quantities (EPA)
Acetone
Final CERCLA RQ: 5000(2270) pounds (Kilograms)
8/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
SARA 313 Emission Reporting
The following ingredients are listed or exempt:
Pentane
SARA (311/312) Hazard Categories
Present.
Dimethyl Ether
Acute
Health hazard
Pressure
Fire
Hazard
Pentane
All the ingredients are listed or exempt.
Acetone
Acute
Chronic
Health hazard
Fire
US State Regulations
California Proposition 65 Carcinogens and Reproductive Toxins
Ths product does not contain any chemicals known to the State of California to cause cancer, birth or any other reproductive
harm.
Massachusetts "Right To Know" List
Present.
Dimethyl Ether
Pentane
Acetone
Rhode Island "Right To Know" List
Acetone
Present.
Minnesota "Right To Know" List
Present.
Dimethyl Ether
Acetone
New Jersey "Right To Know" List
Present.
Dimethyl Ether
Acetone
Pennsylvania "Right To Know" List
Present.
Dimethyl Ether
Pentane
Acetone
Inventories
9/10
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Tensorgrip P322 Fast Dry Pressure Sensitive Adhesive
Canada - DSL/NDSL
DSL
Dimethyl Ether
Pentane
Acetone
US - TSCA
Present.
Dimethyl Ether
Pentane
Acetone
16. Other information
Revision date 4/4/2017
Revision 7
Supersedes date 4/4/2017
SDS No.20591
Hazard statements in full H220 Extremely flammable gas.
H222 Extremely flammable aerosol.
H224 Extremely flammable liquid and vapor.
H225 Highly flammable liquid and vapor.
H280 Contains gas under pressure; may explode if heated.
H302 Harmful if swallowed.
H304 May be fatal if swallowed and enters airways.
H312 Harmful in contact with skin.
H315 Causes skin irritation.
H319 Causes serious eye irritation.
H320 Causes eye irritation.
H332 Harmful if inhaled.
H335 May cause respiratory irritation.
H336 May cause drowsiness or dizziness.
H411 Toxic to aquatic life with long lasting effects.
ACA HMIS Health rating.Moderate hazard. (2)
ACA HMIS Flammability
rating.
Ignites easily. (3)
ACA HMIS Physical hazard
rating.
Normally stable. (0)
ACA HMIS Personal
protection rating.
B
The information in this Material Safety Data Sheet (MSDS) is believed to be correct as of the date issued. The manufacturer
MAKES NO WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTY
OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR COURSE OF PERFORMANCE OR USAGE
OF TRADE. Given the variety of factors that can affect the use and application of this product, many of which are solely within
the user’s knowledge and control, the user is responsible for determining whether the manufacturer of this product is fit for a
particular purpose and suitable for users’ method of use or application. It is essential that the user evaluate this product, not
the manufacturer, to determine whether it is fit for a particular purpose and suitable for users’ method of use or application
10/10
RockWell, LLC
Notice of Intent
Application

Appendix A

Process Description
(See attached flow diagram) First, raw materials are kitted and measured to the
correct quantity for the product being made. Then the raw materials are loaded into
a mold, and the mold is closed and evacuated via a vacuum pump. After the part has
cured, the part is removed from the mold. The part must then be sanded and
mounting holes drilled into it using pneumatic tools. Finally, an automotive clear
coat is sprayed over the well to give it additional UV protection. The molding
methods and application of clear coat are proprietary and considered confidential.

Emissions from the process come from polyester resin and catalyst in the
production of the window well and from polyurethane clear coat. The emissions
from the resin come through vacuum pumps and are removed from the building by
turbines. The emissions from the clear coat come through a spray gun and are
removed from the building by turbines. Both are filtered.

Raw Materials Used and Annual Usage 2017 to 2021
The following raw materials are used:

Material Manufacturer Purpose
DX 040-8086 RTM Resin* Polynt Composites USA Resin used as main
component
NOROX AZOX* United Initiators, Inc. Catalyst to harden resin
Rovicore Fiberglass Matt Chomarat Reinforcements Fibers to give strength to
resin
Tensorgrip P322 Fast Dry
Pressure Sensitive
Adhesive*
Quin Global Keeps fiberglass in place
Nonwoven Polyester Veil Freudenberg Performance
Materials
Provides cosmetic skin
Polyethylene Foam Various Manufactures To provide “I beam” effect
which adds strength at
minimal costs
PC-77731-DM Paint
Related Pigment
American Colors Tinting for resin
Polyurethane Clearcoat -
Flat
Axalta Coating Systems,
LLC
UV Protection
* See attached Safety Data Sheets

Operation Schedules and Production Rates

Rockwell’s production rates are cyclical and tend to be greatest in spring and
summer. These rates are also increaing over time over the last 15 years. However,
the last 30 months have been much more volitale.

0
10000
20000
30000
40000
50000
60000
70000
80000
Resin Usage in Pounds
0
200000
400000
600000
800000
1000000
1200000
1400000
Resin Usage in Pounds
Yearly Totals

Equipment Used in Process

The equipment used in the manufacturing of window wells includes in-house built
molds and various pneumatic and electric hand tools.
To aid in curing 6, Superior Radiant Products, SD09N, 99,000 BTU radiant heaters
are used.
Heating the office, production, and warehouse areas are 4, Lennox, LF24-300A-3,
241500 BTU gas furnaces.

The equipment used in handling of emissions from the polyester resin and catalyst
include:

• Welch 1937 Vacuum pump
• Soler & Palau USA, TXB16, 1/3 HP, belt driven tube axial fan
• RenewAire HE2XRT 2 @ 2 HP, air handler
• (6) Koch Filter Corp, 102-041-002, 12” X 20” X 1” Multi-Pleat filters
• (4) T4500 Industrial Maid Air Cleaners using 50 pounds each of
Hydrosil HS-AC Carbon

The equipment used in handling emissions from the polyurethane clear coat and
hardener include:

• (2) Soler & Palau USA, TDB 30, 3 HP, belt driven tube axial fans
• 90” X 96” wall of Filter Technologies, 14AGP2020100, Paint Arrestor
Pads, 15 Gram GX Media

Description of Products

Rockwell offers 2 series of window wells including the Rockwell 66, multi step
egress well and the Rockwell 42, non-egress well. These series come in different
heights. Rockwell also offers a Denali series of window well that is produced by
another company, A & P Solutions, in Puebla, Mexico. Rockwell sells covers and
grates which other companies produce.

Stack Parameters

The stack used for the polyester resin and catalyst is 36” diameter and 40” tall
(above the roof, 352” above grade). To prevent emissions from being re-introduced
into the building, the more powerful exhaust fan used on the polyurethane clear
coat and hardener is taller and measures 36” diameter and 144” tall (above the roof,
456” above grade)

RockWell, LLC
Notice of Intent
Application
Appendix C

Principle Emission:
Styrene from processing Polynt Composites’ 0408086-DT STYPOL 040-8086 using a “closed mold”
technique.
This product ranges from 36 to 40% styrene.
The industry-based emission factor from a closed mold process is 0.02.
Based on: http://www.aqmd.gov/docs/default-source/planning/annual-emission-
reporting/guidelines-for-calculating-emissions-from-polyester-resin-operations.pdf

There are 6 molds that can be operated at one time.
Each mold can consume up to 1050 pounds of resin in a day.
1050 X 40% = 420; 420 X 0.02 = 8.4 pounds of styrene emissions a day.
Rockwell, LLC is projected to consume 490,000 pounds of resin in 2024 with a total throughput of
emissions of:
490,000 X 40% = 196,000; 248,000 X 0.02 = 3920

Styrene Emissions Break Down:
Daily
Maximum
Weekly
Maximum
Monthly
Maximum
Yearly
Maximum
Last 12
Months
Per Mold 8.4 pounds 42 pounds 168 pounds 2016 pounds 656 pounds
Per Entire
Plant (6
Molds)
50.4 pounds 252 pounds 1008 pounds 12096 pounds 3,936 pounds

Possible sources of fugitive emissions include:
Off-gassing from post-curing parts
Spill of resin
Repair of window wells

Exact emissions from these sources are unknown.

The other emissions include those generated from polyurethane clear coat.
These includes:
• N-methyl-2-pyrrolidone

The clear coat has 69.80% solids by volume and 74.99% solids by weight.
Rockwell used 77 gallons of the clear coat over the last 12 months.

RockWell, LLC
Notice of Intent
Application
Appendix D

Emissions from Polyester Resin:

Note: The last 4 months of 2024, 2025, 2026, 2027, 2028, and 2029 are based on projected sales.

Note: The last 4 months of 2024, 2025, 2026, 2027, 2028, and 2029 are based on projected sales.
0
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Styrene Emissions in Pounds
Yearly Totals
020406080
100120140160180200
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Polyurethane Clear Coat Usage in
Gallons
Yearly Totals
RockWell, LLC
Notice of Intent
Application
Appendix G

Best technologies for the polyester resin and catalyst:
Rockwell already employs the best technology available for reducing emissions by utilizing closed mold
technology. Closed mold compared to the normal open mold methods used by other composite
manufacturers throughout the state reduces emissions by as much as 80%.
(http://compositesmanufacturingmagazine.com/2011/05/open-book-adopting-closed-molding/)
Maintaining Rockwell’s closed molds cost $105,670 in 2023 which reduces Rockwell’s emissions by 18,800
pounds that year.

$105,670 / 18,800 pounds = $5.62 per pound

In an ongoing effort to have the lowest emission possible, Rockwell has done comprehensive research to
understand what other steps may be taken. Two approaches have been identified. One is to use materials
that emit lower volatile organic compounds. The other is to use further emission reduction technology.

After extensive testing and research, Rockwell has found that using reinforced thermoplastics (including
products like Polystrand, Glass-mat Thermoplastics (GMT), and Direct Long Fiber Thermoplastics(DLFT)) offer
the benefit of reduced emissions. However, the surface finish of such products lack the cosmetic appeal
Rockwell is famous for. It may be possible to replace up to 60% of the polyester resin with this product.

After extensive prototyping, testing, and market analysis, DLFT had the best combined advantages of reduced
emissions, strength, and cosmetics. The equipment (including extruders and presses) needed to process
reinforced thermoplastics is estimated to cost over 4 million dollars in upfront costs and $130,000 a year in
ongoing costs. Because of Rockwell’s lack of capital to achieve this for the next several years this operation
has been outsourced to Puebla, Mexico. Rockwell has purchased 4 molds and a welding cell for
$2,343,613.42. Some of the ongoing costs are known and some are estimated, but it is believed to be about
$18,000 per year. If a 10-year horizon and the average of 7,500 pounds of styrene a year is used (based on
sales projections for the next 3 years), the cost per pound of styrene removal would be:

$2,343,613.42 / 10 years = $234,361,34 + $18,000 = $234361.34 / 7,500 pounds X 60% = 4,500 pounds =
$52.08 per pound.

After two pilot launches, Rockwell lunched the Denali product made, from DLFT, to the entire country and
Canada in June of 2024. This is expected to drive down the production of the polyester based product, but we
are hopeful that we can grow both products in the long term. As sales volume increases with this new
product the cost of emission reduction will get better.

Technologies that remove styrene from air are limited and not widely used. The most popular are absorption
in sacrificial medium and incineration. The best writing found during research came from the following web
page:

http://www.plasticseurope.org/Documents/Document/20100308111848-
EnglishCEFICpdf9Styreneabatementtechniques-20050913-002-EN-v1.pdf

Rockwell was unable to locate anyone offering incineration capability or expertise on a scale that made sense
for current or future production size and techniques. Companies like Eco Incinerator or Incinco Incinerators
lack expertise in the field of styrene removal and did not know if it would work.

The only technology, which was found to have a known track record of styrene removal, was using carbon
filtration as a sacrificial medium. Attached is the leading quote provider to Rockwell from Sentry Air Systems,
Inc. The up-front costs for one of these units, installed, was $8,679 in 2021 and would likely be $1,000 to
$3,000 more now.

Rockwell purchased two T4500 Industrial Air Cleaners for $13,036 in 2019 and then 2 additional units
October of 2021 for $17,358. The ongoing cost of replacement carbon filtration and disposal has been
$1,558.00 for the last 12 months. Each unit costs $389.50 per year. From lab analysis of the carbon after it
has been replaced, each unit is believed to remove 60 - 80 pounds of styrene a year. If the unit last 5 years on
this cost structure, the cost of styrene removal per pound would be:

$8,679.00 / 5 = $1,735.80 + $389.50 = $2,125.30 / 60 pounds = $35.42 per pound

Best technologies for polyurethane clear coat:

Similar technologies exist to remove the VOCs from the air emitted from the polyurethane clear coat;
however, these are much more commonly used. Some of the exact equipment quoted by Sentry Air Systems
could be used for this application. Sentry has experience dealing with polyurethane paints and offers test
data on removal rates, found on the web site:

https://www.sentryair.com/data.htm

Because of the reduced volume upfront costs would be lower, around $10,000 to $16,000, and ongoing cost
would represent only replacement filters because once the polyurethane becomes a solid it will no longer
emit VOCs. The ongoing cost would be from $700 to $1,200 annually.

Rockwell currently uses fiberglass filters to capture solids from the clear coat. These filters are replaced on a
change schedule that relies on a manometer, but on average it is about once a month. The exact amount of
emission reduction is unknown. Rockwell has spent $2,148.00 over the last 12 months on filters.

Safety Data Sheet
FOR INDUSTRIAL USE ONLY
UNSATURATED POLYESTER RESIN
Revision Date 3/19/2024
1. Identification
Product Name:UNSATURATED POLYESTER RESIN
STYPOL 040-8086
SDS Number:0408086B3
Product Use:Industrial
Manufacturer, Importer,
Supplier
Polynt Composites USA, Inc.
99 East Cottage Avenue
Carpentersville IL 60110
E-Mail: [e-mail]
Telephone For Emergency Transportation Information
CHEMTREC US Domestic [phone]
CHEMTREC International [phone]
For additional health, safety or regulatory information, call [phone]
2. Hazard identification
EMERGENCY OVERVIEW:May cause sensitization by inhalation and skin contact. Risk of serious damage to the lungs (by
aspiration).
GHS Classification
Carc. 2, Eye Irrit. 2A, Flam. Liq. 3, Skin Irrit. 2, Skin Sens. 1, STOT RE 1, STOT SE 3 NE, STOT SE 3 RTI
Symbol(s) of Product
Signal Word
Danger
GHS HAZARD STATEMENTS
Flammable Liquid, category 3 H226 Flammable liquid and vapour.
Skin Irritation, category 2 H315 Causes skin irritation.
Skin Sensitizer, category 1 H317 May cause an allergic skin reaction.
Eye Irritation, category 2A H319 Causes serious eye irritation.
STOT, single exposure, category 3, RTI H335 May cause respiratory irritation.
STOT, single exposure, category 3, NE H336 May cause drowsiness or dizziness.
Page 1 / 7
Date Printed: 3/20/2024 Product: 0408086B3
Carcinogenicity, category 2 H351 Suspected of causing cancer.
STOT, repeated exposure, category 1 H372 Causes damage to organs through prolonged or repeated exposure.
GHS LABEL PRECAUTIONARY STATEMENTS
P210 Keep away from heat/sparks/open flames/hot surfaces. No smoking.
P264 Wash … thoroughly after handling.
P280 Wear protective gloves/protective clothing/eye protection/face protection.
P281 Use personal protective equipment as required.
P321 Specific treatment (see … on this label).
P405 Store locked up.
P501 Dispose of contents/container to in accordance with local/regional/national/international
regulations.
P302+P352 IF ON SKIN: Wash with plenty of soap and water.
P303+P361+P353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with
water/shower.
P305+P351+P338 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if
present and easy to do. Continue rinsing.
P362+P364 Take off contaminated clothing and wash it before reuse.
P370+P378 In case of fire: Use dry chemical, foam, water spray to extinguish.
P403+P233 Store in a well-ventilated place. Keep container tightly closed.
P201 Obtain special instructions before use.
P260 Do not breathe dust/fume/gas/mist/vapours/spray.
P312 Call a POISON CENTER or doctor/physician if you feel unwell.
P308+P313 IF exposed or concerned: Get medical advice/attention.
P332+P313 If skin irritation occurs: Get medical advice/attention.
P333+P313 If skin irritation or rash occurs: Get medical advice/attention.
P337+P313 If eye irritation persists: Get medical advice/attention.
P403+P235 Store in a well-ventilated place. Keep cool.
GHS SDS PRECAUTIONARY STATEMENTSP240Ground/bond container and receiving equipment.
P241 Use explosion-proof electrical/ventilating/lighting/…/ equipment.
P242 Use only non-sparking tools.
P243 Take precautionary measures against static discharge.
P270 Do not eat, drink or smoke when using this product.
P363 Wash contaminated clothing before reuse.
3. Composition/Information on ingredients
Chemical Name CAS-No.Wt. %
Styrene 100-42-5 30 - 40
Hexanoic acid, 2-ethyl-, cobalt(2+) salt (2:1)136-52-7 0.1-1.0
4. First-aid measures
FIRST AID -EYE CONTACT:Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. If symptoms
persist, call a physician.
FIRST AID -INGESTION:If ingested, consult a physician. Do NOT induce vomiting. Aspiration hazard if swallowed -can enter
lungs and cause damage.
FIRST AID -INHALATION:Give oxygen or artificial respiration if needed. Remove person to fresh air. If signs/symptoms continue,
get medical attention.
FIRST AID -SKIN CONTACT:Wash with soap and water. Remove contaminated clothes and shoes. Get medical attention if
irritation develops.
5. Fire-fighting measures
Extinguishing Media:
Carbon Dioxide, Dry Chemical, Foam, Water FogSuitable
Water JetNot suitable
SPECIAL FIREFIGHTING PROCEDURES:Use full protective clothing. Use a properly-fitted, air-purifying or air-fed respirator
Page 2 / 7
Date Printed: 3/20/2024 Product: 0408086B3
complying with an approved standard if a risk assessment indicates this is necessary. Vapors may be ignited by heat, pilot lights,
other flames and ignition sources. Do not use a solid water stream as it may scatter and spread fire. Cool containers / tanks with
water spray. Self-accelerating decomposition may occur if the specific control temperature is not maintained. Vapors may accumulate in confined areas (basement, tanks, hopper/tank cars, etc.).
UNUSUAL FIRE AND EXPLOSION HAZARDS:No Information
6. Accidental release measures
ENVIRONMENTAL MEASURES:Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains and sewers.
Inform the relevant authorities if the product has caused environmental pollution (sewers, waterways, soil or air). Prevent entry into
waterways, sewers, basements or confined areas.
STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED:Dike to prevent entering any sewer or waterway.
Transfer liquid to a holding container. Ensure adequate ventilation. Evacuate personnel to safe areas. Remove all sources of ignition. Do not flush into surface water or sanitary sewer system. Contain spillage, soak up with non-combustible absorbent
material, (e.g. sand, earth, diatomaceous earth, vermiculite) and transfer to a container for disposal according to local / national
regulations (see section 13). Use non-sparking tools and equipment. Avoid breathing vapors or mists.
PRECAUTIONARY MEASURES:No Information
7. Handling and storage
HANDLING:Wear personal protective equipment. Use only in well-ventilated areas. Keep away from heat and sources of ignition.
Do not breathe vapors, mist or gas. Ground/bond container and equipment. Avoid contact with skin, eyes and clothing. Wash contaminated clothing before reuse.
STORAGE:Keep container closed when not in use. Store and dispose according to national, state and local regulations. Store in
cool well ventilated space away from incompatiable materials. Store contents under 100F (37.8C). Store drums with bung in the
upright position. Electrical equipment must be grounded; suitable for the classification of the area where it is installed and conform to
the National Electric Code (see NFPA 70).
HYGIENIC PRACTICES:When using, do not eat, drink or smoke. Regular cleaning of equipment, work area and clothing. General
industrial hygiene practice. Wash hands before eating, drinking, or smoking.
WORK PRACTICES:Put on appropriate personal protective equipment. Wash hands after handling chemicals and before eating,
drinking, or smoking. Read and understand entire SDS before handling chemical.
SPECIAL HANDLING PROCEDURES:Put on appropriate personal protective equipment. Eating, drinking, and smoking should be
prohibited in areas where this material is handled, stored, and processed. Keep in the original container or an approved alternative
made from a compatible material, kept tightly closed when not in use.
8. Exposure controls/personal protection
Ingredients with Occupational Exposure Limits
Chemical Name ACGIH TLV-TWA ACGIH-TLV STEL OSHA PEL-TWA OSHA CEILING
Styrene 10 ppm 20 ppm 100 ppm 200 ppm
Hexanoic acid, 2-ethyl-, cobalt(2+) salt
(2:1)
N.E.N.E.N.E.N.E.
Further Advice: MEL = Maximum Exposure Limit OES = Occupational Exposure Standard SUP = Supplier's Recommendation
Sk = Skin Sensitizer N.E. = Not Established
Personal Protection
\\pcusa-
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RESPIRATORY PROTECTION:When concentrations exceed the exposure limits specified, use of a NIOSH-approved
dust, mist and fume respirator is recommended. Where the protection factor of the respirator may be exceeded, use of
a full facepiece, supplied air, or Self Contained Breathing Apparatus (SCBA) may be necessary. Use a properly-fitted,
air-purifying or air-fed respirator complying with an approved standard if a risk assessment indicates this is necessary.
Respirator selection must be based on known or anticipated exposure levels, the hazards of the product and the safe
working limits of the selected respirator.
\\pcusa-cvfs01\!
carpentersville
SKIN PROTECTION:Wear suitable protective equipment. Wear chemical resistant footwear and clothing such as
gloves, an apron or a whole body suit as appropriate.
Page 3 / 7
Date Printed: 3/20/2024 Product: 0408086B3
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carpentersville
EYE PROTECTION:Ensure that eyewash stations and safety showers are close to the workstation location. Safety
glasses with side-shields. Wear chemical-resistant glasses and/or goggles and a face shield when eye and face contact
is possible due to splashing or spraying of material.
\\pcusa-
cvfs01\!
carpentersville
OTHER PROTECTIVE EQUIPMENT:Use good hygiene practices. Wash face and hands before eating, drinking, and
smoking. Eye wash and safety showers should be readily available.
\\pcusa-
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carpentersville
HYGIENIC PRACTICES:When using, do not eat, drink or smoke. Regular cleaning of equipment, work area and
clothing. General industrial hygiene practice. Wash hands before eating, drinking, or smoking.
9. Physical and chemical properties
Color:Clear Physical State:Liquid
Odor:Styrene Odor Threshold:No Information Available
Density, g/cm3:1.089 pH:No Information Available
Freeze Point, °C:No Information Available Viscosity:No Information Available
Solubility in Water:Insoluble Partition Coefficient, n-octanol/water:No Information Available
Decomposition Temp., °C:No Information Available Flash Point, °C / F°31 / 88
Boiling Range, °C:145 Explosive Limits, vol%:No Information Available
Vapor Pressure:No Information Available Auto-ignition Temp., °C:No Information Available
(See "Other information" Section for abbreviation legend)
10. Stability and reactivity
STABILITY:The product is normally supplied in a stabilized form. If the permissible storage period and/or storage temperature is
noticeably exceeded, the product may polymerise with heat evolution. Stable under normal conditions.
CONDITIONS TO AVOID:Burning may produce obnoxious and toxic fumes. Hazardous polymerization may occur. Keep product away from heat, sparks, pilot lights, static electricity, and open flame. Avoid improper addition of promotor and/or catalyst. Avoid
direct contact of MEKP catalyst with accelerator. If adding accelerator like cobalt drier, mix accelerator with base material before
adding catalyst.
INCOMPATIBILITY:Copper. Strong acids. Strong oxidizing and reducing agents. Free radical initiators. Metal salts.
HAZARDOUS DECOMPOSITION PRODUCTS:None under normal use.
11. Toxicological information
Practical Experiences
EFFECT OF OVEREXPOSURE -EYE CONTACT:Exposure may cause mild irritation. Symptoms may include stinging, tearing, and
redness.
EFFECT OF OVEREXPOSURE -INGESTION:May cause severe gastrointestinal disturbance with headache, nausea, vomiting and
diarrhea.
EFFECT OF OVEREXPOSURE -INHALATION:Inhalation may cause irritation to the respiratory tract (nose, mouth, mucous membranes). Prolonged, repeated or high exposures may cause central nervous system depression leading to headaches, nausea,
drowsiness, dizziness, and possibly narcosis. In extreme cases, may cause loss of consciousness. Ingestion of large doses may
cause headaches, dizziness, nausea, vomiting, and drowsiness. Exposure to component solvent vapor concentrations in excess of
the stated occupational exposure limit may result in adverse health effect, such as mucous membrane and respiratory system
irritation and adverse effect on kidney, liver and central nervous system. Irritating to skin.
EFFECT OF OVEREXPOSURE -SKIN CONTACT:Prolonged skin contact may defat the skin and produce dermatitis.
EFFECT OF OVEREXPOSURE -CHRONIC HAZARDS:Prolonged or repeated exposure may cause liver and kidney effects.
Repeated or prolonged exposure may cause central nervous system damage. Prolonged skin contact may defat the skin and
produce dermatitis.
CARCINOGENICITY:This product contains styrene classified by the International Agency for Research on Cancer (IARC) as 2A
Page 4 / 7
Date Printed: 3/20/2024 Product: 0408086B3
carcinogen.
This product contains styrene, which is listed in the NTP report on carcinogens.
This product contains chemical(s) categorized as ACGIH A3 -Confirmed animal carcinogen with unknown relevance to humans.
PRIMARY ROUTE(S) OF ENTRY:Eye Contact, Ingestion, Inhalation, Skin Contact
Acute Toxicity Values
The acute effects of this product have not been tested. Data on individual components are tabulated below:
CAS-No.Name according to EEC Oral LD50 Dermal LD50 Vapor LC50
100-42-5 Styrene 5000 mg/kg Rat 2000 mg/kg Rat 11.8 mg/L Rat
136-52-7 Hexanoic acid, 2-ethyl-, cobalt(2+) salt (2:1)N.I.>5000 mg/kg Rabbit N.I.
N.I. = No Information
12. Ecological information
ECOLOGICAL INFORMATION:Discharge into the environment must be avoided. Ecological evaluation of this material has not been
performed; however, do not allow the product to be released to the environment without governmental approval/permits.
13. Disposal considerations
DISPOSAL METHOD:The generation of waste should be avoided or minimized wherever possible. Disposal of this product,
solutions and any by-products should always comply with the requirements of environmental protection and waste disposal legislation
and any regional local authority requirements. Dispose of surplus and non-recyclable products via a licensed waste disposal
contractor. Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains, and sewers.
14. Transport information
SPECIAL TRANSPORT PRECAUTIONS:No Information
International transport regulations
Regulatory
Information:UN/NA Number Proper Shipping Name Reportable Quantity (RQ)Classes / PG
CFR UN1866 Class 3 PGIIIRESIN SOLUTION
IMO/IMDG UN1866 RESIN SOLUTION, flammable Class 3 PGIII
IATA UN1866 Class 3 PGIIIRESIN SOLUTION, flammable
15. Regulatory information
U.S. Federal Regulations:
CERCLA - SARA Hazard Category
This product has been reviewed according to the EPA ‘Hazard Categories’ promulgated under Sections 311 and 312 of the
Superfund Amendment and Reauthorization Act of 1986 (SARA Title III) and is considered, under applicable definitions, tomeet the following categories:
Flammable (gases, aerosols, liquids, or solids), Carcinogenicity, Skin Corrosion or Irritation, Respiratory or Skin Sensitization,Serious eye damage or eye irritation, Specific target organ toxicity (single or repeated exposure)
Chemical Name CAS-No.
Styrene 100-42-5
SARA SECTION 313:
This product contains the following substances subject to the reporting requirements of Section 313 of Title III of the
Superfund Amendment and Reauthorization Act of 1986 and 40 CFR part 372:
Chemical Name CAS-No.
Styrene 100-42-5
Page 5 / 7
Date Printed: 3/20/2024 Product: 0408086B3
TOXIC SUBSTANCES CONTROL ACT:
This product contains the following chemical substances subject to the reporting requirements of TSCA 12(B) if exported from
the United States:
No TSCA 12(b) regulated components exist in this product.
CALIFORNIA PROPOSITION 65 CARCINOGENS
WARNING: Cancer - www.P65Warnings.ca.gov
Chemical Name CAS-No.
Styrene 100-42-5
Ethylbenzene 100-41-4
Benzenamine, N,N,4-trimethyl-99-97-8
Benzene, (1-methylethyl)-98-82-8
Benzene 71-43-2
CALIFORNIA PROPOSITION 65 REPRODUCTIVE TOXINS
WARNING: Reproductive Harm - www.P65Warnings.ca.gov.
Chemical Name CAS-No.
Methanol 67-56-1
Benzene 71-43-2
International Regulations
Not listedAustralia inventory (AICS)Chemical
Inventories All components are listed or exemptedCanada inventory (DSL)
Not listedCanada inventory (NDSL)
Not listedJapan Inventory (ENCSC)
Not listedChina Inventory (IECSC)
Not listedKorea Inventory (KECI)
Not listedNew Zealand (NZIoC)
Not listedPhilippines (PICCS)
All components are listed or exemptedUnited States Inventory (TSCA 8b)
16. Other information
Revision Date:3/19/2024 Supercedes Date:10/24/2023
Reason for revision:Updated SDS Information
Datasheet produced by:Regulatory Department
HMIS Ratings:
Health:2 Flammability:3 Reactivity:1 Personal Protection:N.I.Chronic Rating:N.I.
Legend: N.A. - Not Applicable, N.E. - Not Established, N.D. - Not Determined, N.I. - No Information
Page 6 / 7
Date Printed: 3/20/2024 Product: 0408086B3
The information provided herein was believed by Polynt Composites USA, Inc. to be accurate at the time of preparation or prepared
from sources believed to be reliable, but it is the responsibility of the user to investigate and understand other pertinent sources of
information, to comply with all laws and procedures applicable to the safe handling and use of the product and to determine the
suitability of the product for its intended use. All products supplied by Polynt Composites USA, Inc. are subject to Polynt Composites
USA, Inc terms and conditions of sale. Polynt Composites USA, Inc. MAKES NO WARRANTY, EXPRESSED OR IMPLIED,
CONCERNING THE PRODUCT OR THE MERCHANTABILITY OR FITNESS THEREOF FOR ANY PURPOSE OR CONCERNING
THE ACCURACY OF ANY INFORMATION PROVIDED BY Polynt Composites USA, Inc, except that the product shall conform to
Polynt Composites USA, Inc. specifications. Nothing contained herein constitutes an offer for the sale of any product.
Page 7 / 7
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

1 / 27
SECTION 1. IDENTIFICATION
Trade name

: NOROX®AZOX

Manufacturer or supplier's details
Company name of supplier

: United Initiators, Inc.

Address

: 555 Garden Street
Elyria OH 44035 USA

Telephone

: [phone]

Telefax

: [phone]

Emergency telephone

: CHEMTREC US (24h): [phone]
CHEMTREC WORLD (24h): [phone]

E-mail address of person
responsible for the SDS

: [e-mail]

Recommended use of the chemical and restrictions on use
Recommended use

: polymerization initiators

SECTION 2. HAZARDS IDENTIFICATION
GHS classification in accordance with the OSHA Hazard Communication Standard (29 CFR
1910.1200)
Flammable liquids

: Category 4
Organic peroxides

: Type D
Skin irritation

: Category 2
Eye irritation

: Category 2A
Skin sensitization

: Category 1
Reproductive toxicity

: Category 1B
Specific target organ toxicity
- single exposure

: Category 3 (Respiratory system)
Short-term (acute) aquatic
hazard

: Category 2
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GHS label elements
Hazard pictograms

:

Signal Word

: Danger

Hazard Statements

: H227 Combustible liquid.
H242 Heating may cause a fire.
H315 Causes skin irritation.
H317 May cause an allergic skin reaction.
H319 Causes serious eye irritation.
H335 May cause respiratory irritation.
H360 May damage fertility or the unborn child.
H401 Toxic to aquatic life.

Precautionary Statements

: Prevention:
P201 Obtain special instructions before use.
P202 Do not handle until all safety precautions have been read
and understood.
P210 Keep away from heat/ sparks/ open flames/ hot surfaces.
No smoking.
P220 Keep/Store away from clothing/ strong acids, bases,
heavy metal salts and other reducing substances /combustible
materials.
P234 Keep only in original container.
P261 Avoid breathing mist or vapors.
P264 Wash skin thoroughly after handling.
P271 Use only outdoors or in a well-ventilated area.
P272 Contaminated work clothing must not be allowed out of
the workplace.
P273 Avoid release to the environment.
P280 Wear protective gloves/ protective clothing/ eye protection/
face protection.
Response:
P302 + P352 IF ON SKIN: Wash with plenty of soap and water.
P304 + P340 + P312 IF INHALED: Remove person to fresh air
and keep comfortable for breathing. Call a POISON CENTER/
doctor if you feel unwell.
P305 + P351 + P338 IF IN EYES: Rinse cautiously with water
for several minutes. Remove contact lenses, if present and easy
to do. Continue rinsing.
P308 + P313 IF exposed or concerned: Get medical advice/
attention.
P333 + P313 If skin irritation or rash occurs: Get medical advice/
attention.
P337 + P313 If eye irritation persists: Get medical advice/ atten-
tion.
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P362 Take off contaminated clothing and wash before reuse.
P370 + P378 In case of fire: Use water spray, alcohol-resistant
foam, dry chemical or carbon dioxide to extinguish.
Storage:
P403 + P233 Store in a well-ventilated place. Keep container
tightly closed.
P405 Store locked up.
P410 Protect from sunlight.
P411 + P235 Store at temperatures not exceeding < 100 °F/ <
38 °C. Keep cool.
P420 Store away from other materials.
Disposal:
P501 Dispose of contents/ container to an approved waste dis-
posal plant.

Other hazards
None known.

SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS
Substance / Mixture

: Mixture
Chemical nature

: Organic Peroxide
Liquid mixture

Components
Chemical name CAS-No. Concentration (% w/w)
2,4-Pentanedione, peroxide 37187-22-7

>= 30 - < 35
N-Methyl-2-pyrrolidone 872-50-4

>= 25 - < 30
Acetylacetone 123-54-6

>= 1 - < 5
Hydrogen peroxide 7722-84-1

>= 1 - < 5
Actual concentration is withheld as a trade secret

SECTION 4. FIRST AID MEASURES
General advice

: Take off contaminated clothing and shoes immediately.
Call a physician immediately.
Never give anything by mouth to an unconscious person.
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If unconscious, place in recovery position and seek medical
advice.
Move out of dangerous area.
Show this material safety data sheet to the doctor in
attendance.
Do not leave the victim unattended.
Symptoms of poisoning may appear several hours later.

If inhaled

: Administer oxygen if breathing is difficult or cyanosis is
observed.
If breathed in, move person into fresh air.
If not breathing, give artificial respiration.
If unconscious, place in recovery position and seek medical
advice.
Keep respiratory tract clear.
If symptoms persist, call a physician.

In case of skin contact

: If symptoms persist, call a physician.
In case of contact, immediately flush skin with plenty of water
for at least 15 minutes while removing contaminated clothing
and shoes.
Wash contaminated clothing before re-use.
If on skin, rinse well with water.
If on clothes, remove clothes.

In case of eye contact

: In the case of contact with eyes, rinse immediately with plenty
of water and seek medical advice.
Remove contact lenses.
Protect unharmed eye.
Keep eye wide open while rinsing.
If eye irritation persists, consult a specialist.

If swallowed

: Call a physician immediately.
Rinse mouth thoroughly with water.
Keep respiratory tract clear.
If symptoms persist, call a physician.

Most important symptoms
and effects, both acute and
delayed

: Causes skin irritation.
May cause an allergic skin reaction.
Causes serious eye irritation.
May cause respiratory irritation.
May damage fertility or the unborn child.
sensitizing effects

Protection of first-aiders

: First Aid responders should pay attention to self-protection
and use the recommended protective clothing

Notes to physician

: Treat symptomatically and supportively.
SECTION 5. FIRE-FIGHTING MEASURES
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Suitable extinguishing media

: Water spray jet
Alcohol-resistant foam
Carbon dioxide (CO2)
Dry chemical

Unsuitable extinguishing
media

: High volume water jet

Specific hazards during fire
fighting

: Risk of explosion if heated under confinement.
Possible emission of gaseous decomposition products may
lead to a dangerous pressure build-up.
Avoid confinement.
Contact with incompatible materials or exposure to
temperatures exceeding SADT may result in a self-
accelerating decomposition reaction with release of flammable
vapors which may auto-ignite.

The product burns violently.
Flash back possible over considerable distance.
Do not allow run-off from fire fighting to enter drains or water
courses.
Vapors may form explosive mixtures with air.
Cool closed containers exposed to fire with water spray.

Specific extinguishing meth-
ods

: Do not use a solid water stream as it may scatter and spread
fire.
Remove undamaged containers from fire area if it is safe to do
so.
Use water spray to cool unopened containers.

Further information : Use extinguishing measures that are appropriate to local
circumstances and the surrounding environment.
Use a water spray to cool fully closed containers.
Collect contaminated fire extinguishing water separately. This
must not be discharged into drains.
Fire residues and contaminated fire extinguishing water must
be disposed of in accordance with local regulations.

Special protective equipment
for fire-fighters

: Wear self-contained breathing apparatus for firefighting if
necessary.
Use personal protective equipment.

SECTION 6. ACCIDENTAL RELEASE MEASURES
Personal precautions, protec-
tive equipment and emer-
gency procedures

: Follow safe handling advice and personal protective
equipment recommendations.
Beware of vapors accumulating to form explosive
concentrations. Vapors can accumulate in low areas.
Use personal protective equipment.
Remove all sources of ignition.
Never return spills in original containers for re-use.
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Treat recovered material as described in the section "Disposal
considerations".

Environmental precautions

: Prevent product from entering drains.
Prevent further leakage or spillage if safe to do so.
If the product contaminates rivers and lakes or drains inform
respective authorities.

Methods and materials for
containment and cleaning up

: Contact with incompatible substances can cause
decomposition at or below SADT.
Clear spills immediately.
Suppress (knock down) gases/vapors/mists with a water spray
jet.
To clean the floor and all objects contaminated by this
material, use plenty of water.
Soak up with inert absorbent material.
Isolate waste and do not reuse.
Non-sparking tools should be used.
Local or national regulations may apply to releases and
disposal of this material, as well as those materials and items
employed in the cleanup of releases. You will need to
determine which regulations are applicable.

SECTION 7. HANDLING AND STORAGE
Technical measures

: See Engineering measures under EXPOSURE
CONTROLS/PERSONAL PROTECTION section.

Advice on protection against
fire and explosion

: Take necessary action to avoid static electricity discharge
(which might cause ignition of organic vapors).
Keep away from heat and sources of ignition.
Use only explosion-proof equipment.
Keep away from open flames, hot surfaces and sources of
ignition.
Keep away from combustible material.
Do not spray on a naked flame or any incandescent material.

Advice on safe handling

: Open drum carefully as content may be under pressure.
Protect from contamination.
Do not swallow.
Do not breathe vapors/dust.
Avoid exposure - obtain special instructions before use.
Avoid contact with skin and eyes.
Avoid formation of aerosol.
Take precautionary measures against static discharges.
Never return any product to the container from which it was
originally removed.
Provide sufficient air exchange and/or exhaust in work rooms.
Avoid confinement.
Keep away from heat, hot surfaces, sparks, open flames and
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other ignition sources. No smoking.
Smoking, eating and drinking should be prohibited in the
application area.
Wash thoroughly after handling.
For personal protection see section 8.
Persons susceptible to skin sensitization problems or asthma,
allergies, chronic or recurrent respiratory disease should not
be employed in any process in which this mixture is being
used.

Conditions for safe storage

: Store in original container.
Keep containers tightly closed in a cool, well-ventilated place.
Store in cool place.
Contamination may result in dangerous pressure increases -
closed containers may rupture.
Observe label precautions.
Store in accordance with the particular national regulations.
Avoid impurities (e.g. rust, dust, ash), risk of decomposition.
Electrical installations / working materials must comply with
the technological safety standards.
Containers which are opened must be carefully resealed and
kept upright to prevent leakage.

Materials to avoid

: Keep away from combustible materials.
Keep away from strong acids, bases, heavy metal salts and
other reducing substances.

Recommended storage tem-
perature

: < 100 °F

< 38 °C

Further information on stor-
age stability

: Stable under recommended storage conditions.

SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Ingredients with workplace control parameters
Components CAS-No. Value type
(Form of
exposure)
Control parame-
ters / Permissible
concentration
Basis
N-Methyl-2-pyrrolidone 872-50-4 TWA 15 ppm
60 mg/m3
US WEEL
STEL 30 ppm
120 mg/m3
US WEEL
Acetylacetone 123-54-6 TWA 25 ppm ACGIH
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Hydrogen peroxide 7722-84-1 TWA 1 ppm ACGIH
TWA 1 ppm
1.4 mg/m3
NIOSH REL
TWA 1 ppm
1.4 mg/m3
OSHA Z-1
TWA 1 ppm
1.4 mg/m3
OSHA P0
Biological occupational exposure limits
Components CAS-No. Control
parameters
Biological
specimen
Sam-
pling
time
Permissible
concentra-
tion
Basis
N-Methyl-2-pyrrolidone 872-50-4 5-Hydroxy-
N-methyl-2-
pyrrolidone
Urine End of
shift (As
soon as
possible
after
exposure
ceases)
100 mg/l ACGIH
BEI
Engineering measures : Minimize workplace exposure concentrations.

Personal protective equipment
Respiratory protection

: In the case of dust or aerosol formation use respirator with an
approved filter.

Filter type

: ABEK-filter

Use NIOSH approved respiratory protection.

Hand protection
Material : butyl-rubber
Break through time : <= 480 min
Glove thickness : 0.5 mm

Remarks

: The data about break through time/strength of material are
standard values! The exact break through time/strength of
material has to be obtained from the producer of the
protective glove. Choose gloves to protect hands against
chemicals depending on the concentration and quantity of the
hazardous substance and specific to place of work.
For special applications, we recommend clarifying the
resistance to chemicals of the aforementioned protective
gloves with the glove manufacturer. Wash hands before
breaks and at the end of workday.

Eye protection

: Ensure that eyewash stations and safety showers are close
to the workstation location.
Please follow all applicable local/national requirements when
selecting protective measures for a specific workplace.
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Always wear eye protection when the potential for inadvertent
eye contact with the product cannot be excluded.
Tightly fitting safety goggles
Please wear suitable protective goggles. Also wear face
protection if there is a splash hazard.

Skin and body protection

: Select appropriate protective clothing based on chemical
resistance data and an assessment of the local exposure
potential.

Additional body garments should be used based upon the
task being performed (e.g., sleevelets, apron, gauntlets,
disposable suits) to avoid exposed skin surfaces.
Wear as appropriate:
Flame retardant antistatic protective clothing.

Protective measures

: The type of protective equipment must be selected according
to the concentration and amount of the dangerous substance
at the specific workplace.

Hygiene measures

: Avoid contact with skin, eyes and clothing.
Keep away from food and drink.
When using do not eat or drink.
When using do not smoke.
Wash hands before breaks and immediately after handling
the product.

SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Appearance

: liquid

Color

: colorless

Odor

: characteristic

pH

: No data available

Melting point/range

: No data available

Boiling point/boiling range

: Decomposition: Decomposes below the boiling point.

Flash point : 77 °C
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Method: closed cup

Flammability (solid, gas)

: Not applicable

Upper explosion limit / Upper
flammability limit

: No data available

Lower explosion limit / Lower
flammability limit

: No data available

Vapor pressure

: No data available

Relative vapor density

: > 1

Density

: 1.1 g/cm3

Solubility(ies)
Water solubility

: soluble

Partition coefficient: n-
octanol/water

: No data available

Self-Accelerating decomposi-
tion temperature (SADT)

: 60 °C
Method: UN-Test H.4
SADT-Self Accelerating Decomposition Temperature. Lowest
temperature at which the tested package size will undergo a
self-accelerating decomposition reaction.

Viscosity
Viscosity, dynamic

: No data available

Explosive properties

: Not explosive

SECTION 10. STABILITY AND REACTIVITY
Reactivity

: Stable under recommended storage conditions.
Heating may cause a fire or explosion.

Chemical stability

: Stable under recommended storage conditions.
No decomposition if stored normally.

Possibility of hazardous reac-
tions
: Vapors may form explosive mixture with air.

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Conditions to avoid

: Protect from contamination.
Contact with incompatible substances can cause
decomposition at or below SADT.
Heat, flames and sparks.
Avoid confinement.

Incompatible materials

: Accelerators, strong acids and bases, heavy metals and
heavy metal salts, reducing agents

Hazardous decomposition
products
: Irritant, caustic, flammable, noxious/toxic gases and vapours
can develop in the case of fire and decomposition

Irritant, caustic, flammable, noxious/toxic gases and vapours
can develop in the case of fire and decomposition

SECTION 11. TOXICOLOGICAL INFORMATION
Acute toxicity
Not classified due to lack of data.
Product:
Acute oral toxicity

: Acute toxicity estimate: 2,916 mg/kg
Method: Calculation method

Acute inhalation toxicity

: Acute toxicity estimate: 174.09 mg/l
Exposure time: 4 h
Test atmosphere: vapor
Method: Calculation method

Acute dermal toxicity

: Acute toxicity estimate: > 5,000 mg/kg
Method: Calculation method

Components:
2,4-Pentanedione, peroxide:
Acute oral toxicity

: LD50 (Rat): > 2,000 mg/kg
Method: OECD Test Guideline 401

Acute inhalation toxicity

: LC50 (Rat, male): > 13.1 mg/l
Exposure time: 1 h
Test atmosphere: dust/mist
Method: Expert judgment
Assessment: The substance or mixture has no acute inhala-
tion toxicity

Acute dermal toxicity

: LD50 (Rat): > 2,000 mg/kg
Method: Expert judgment
Assessment: The substance or mixture has no acute dermal
toxicity
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N-Methyl-2-pyrrolidone:
Acute oral toxicity

: LD50 (Rat): 4,150 mg/kg
Method: OECD Test Guideline 401

Acute inhalation toxicity

: LC50 (Rat): > 5.1 mg/l
Exposure time: 4 h
Test atmosphere: dust/mist
Method: OECD Test Guideline 403
Assessment: The substance or mixture has no acute inhala-
tion toxicity
Remarks: No mortality observed at this dose.

Acute dermal toxicity

: LD50 (Rat): > 5,000 mg/kg
Method: OECD Test Guideline 402
Remarks: No mortality observed at this dose.

Acetylacetone:
Acute oral toxicity

: LD50 (Rat): 570 mg/kg

Acute inhalation toxicity

: LC50 (Rat): 5.1 mg/l
Exposure time: 4 h
Test atmosphere: vapor
Method: OECD Test Guideline 403

Acute dermal toxicity

: LD50 (Rabbit, female): 790 mg/kg

Hydrogen peroxide:
Acute oral toxicity

: LD50 (Rat, male and female): 431 mg/kg
Method: Expert judgment
Assessment: The component/mixture is moderately toxic after
single ingestion.

Acute inhalation toxicity

: Acute toxicity estimate: 1.5 mg/l
Exposure time: 4 h
Test atmosphere: dust/mist
Assessment: The component/mixture is moderately toxic after
short term inhalation.
Remarks: Based on harmonised classification in EU regulation
1272/2008, Annex VI

Acute dermal toxicity

: LD50 (Rabbit): 9,200 mg/kg
Remarks: No adverse effect has been observed in acute tox-
icity tests.

Skin corrosion/irritation
Causes skin irritation.
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Product:
Remarks : May cause skin irritation in susceptible persons.

Components:
2,4-Pentanedione, peroxide:
Species : Rabbit
Method : OECD Test Guideline 404
Result : No skin irritation

N-Methyl-2-pyrrolidone:
Species : Rabbit
Method : OECD Test Guideline 404
Result : Irritating to skin.

Acetylacetone:
Species : Rabbit
Result : No skin irritation

Hydrogen peroxide:
Result : Corrosive after 3 minutes or less of exposure

Serious eye damage/eye irritation
Causes serious eye irritation.
Product:
Remarks : May cause irreversible eye damage.

Components:
2,4-Pentanedione, peroxide:
Species : Rabbit
Result : Eye irritation
Method : OECD Test Guideline 405

N-Methyl-2-pyrrolidone:
Species : Rabbit
Result : Eye irritation
Method : OECD Test Guideline 405

Acetylacetone:
Species : Rabbit
Result : No eye irritation

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Hydrogen peroxide:
Result : Irreversible effects on the eye
Remarks : Hydrogen peroxide (H2O2), 35%

Respiratory or skin sensitization
Skin sensitization
May cause an allergic skin reaction.
Respiratory sensitization
Not classified due to lack of data.
Product:
Remarks : Causes sensitization.

Components:
2,4-Pentanedione, peroxide:
Test Type : Maximization Test
Routes of exposure : Skin contact
Species : Guinea pig
Method : OECD Test Guideline 406
Result : Probability or evidence of skin sensitization in humans

Remarks : Causes sensitization.

N-Methyl-2-pyrrolidone:
Species : Mouse
Method : OECD Test Guideline 429
Result : Does not cause skin sensitization.
Remarks : Based on data from similar materials

Acetylacetone:
Routes of exposure : Skin contact
Species : Mouse
Method : OECD Test Guideline 429
Result : Does not cause skin sensitization.

Germ cell mutagenicity
Not classified due to lack of data.
Components:
2,4-Pentanedione, peroxide:
Genotoxicity in vitro

: Test Type: Bacterial reverse mutation assay (AMES)
Method: OECD Test Guideline 471
Result: positive

Test Type: In vitro mammalian cell gene mutation test
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Method: OECD Test Guideline 476
Result: negative

Genotoxicity in vivo

: Test Type: In vivo micronucleus test
Species: Mouse (male and female)
Application Route: Intraperitoneal injection
Method: OECD Test Guideline 474
Result: negative

Acetylacetone:
Genotoxicity in vitro

: Method: OECD Test Guideline 471
Result: negative

Method: OECD Test Guideline 479
Result: positive

Method: OECD Test Guideline 473
Result: positive

Method: OECD Test Guideline 476
Result: negative

Genotoxicity in vivo

: Method: OECD Test Guideline 474
Result: positive

Method: OECD Test Guideline 483
Result: negative

Method: OECD Test Guideline 475
Result: negative

Method: OECD Test Guideline 478
Result: Equivocal

Test Type: DNA Repair
Species: Rat
Application Route: Oral
Result: negative

Species: Rat
Application Route: inhalation (vapor)
Method: OPPTS 870.5395
Result: negative

Hydrogen peroxide:
Genotoxicity in vitro

: Test Type: Bacterial reverse mutation assay (AMES)
Result: negative
positive
Remarks: Information taken from reference works and the
literature.
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Test Type: Chromosome aberration test in vitro
Method: OECD Test Guideline 473
Result: positive
Remarks: Information taken from reference works and the
literature.

Genotoxicity in vivo

: Test Type: Mammalian erythrocyte micronucleus test (in vivo
cytogenetic assay)
Species: Mouse (male and female)
Method: OECD Test Guideline 474
Result: negative
Remarks: Hydrogen peroxide (H2O2), 35%

Germ cell mutagenicity -
Assessment

: Based on available data, the classification criteria are not met.

Carcinogenicity
Not classified due to lack of data.
Components:
2,4-Pentanedione, peroxide:
Remarks : This information is not available.

Hydrogen peroxide:
Carcinogenicity - Assess-
ment

: Carcinogenicity classification not possible from current data.

IARC No ingredient of this product present at levels greater than or equal to 0.1% is
identified as probable, possible or confirmed human carcinogen by IARC.

OSHA No component of this product present at levels greater than or equal to 0.1% is
on OSHA’s list of regulated carcinogens.

NTP No ingredient of this product present at levels greater than or equal to 0.1% is
identified as a known or anticipated carcinogen by NTP.

Reproductive toxicity
May damage fertility or the unborn child.
Components:
2,4-Pentanedione, peroxide:
Effects on fertility

: Remarks: No data available

Effects on fetal development

: Remarks: No data available

N-Methyl-2-pyrrolidone:
Reproductive toxicity - As-: Clear evidence of adverse effects on sexual function and
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sessment

fertility, and/or on development, based on animal experiments

Acetylacetone:
Effects on fetal development

: Species: Rat
Application Route: inhalation (vapor)
Duration of Single Treatment: 13 d
General Toxicity Maternal: NOAEC: 200
Teratogenicity: NOAEC Parent: 400
Embryo-fetal toxicity.: NOAEC F1: 50
Method: OECD Test Guideline 414

Species: Rat
Application Route: inhalation (vapor)
Duration of Single Treatment: 13 d
General Toxicity Maternal: LOAEC: 400
Embryo-fetal toxicity.: LOAEC F1: 200
Method: OECD Test Guideline 414

Hydrogen peroxide:
Reproductive toxicity - As-
sessment

: No data available

STOT-single exposure
May cause respiratory irritation.
Components:
N-Methyl-2-pyrrolidone:
Assessment : May cause respiratory irritation.

Hydrogen peroxide:
Target Organs : Respiratory Tract
Assessment : May cause respiratory irritation.

STOT-repeated exposure
Not classified due to lack of data.
Components:
Hydrogen peroxide:
Remarks : No data available

Repeated dose toxicity
Components:
N-Methyl-2-pyrrolidone:
Species : Rat
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NOAEL : 0.5 mg/l
LOAEL : 1 mg/l
Application Route : inhalation (vapor)
Exposure time : 90 d
Method : OECD Test Guideline 413

Species : Rat
NOAEL : 3,000 mg/kg
LOAEL : 7,500 mg/kg
Application Route : Ingestion
Exposure time : 90 d
Method : OECD Test Guideline 408

Species : Rat
NOAEL : 6,000 mg/kg
LOAEL : 18,000 mg/kg
Application Route : oral (feed)
Exposure time : 28 d
Method : OECD Test Guideline 407

Species : Rabbit
NOAEL : 826 mg/kg
Application Route : Skin contact
Exposure time : 20 d
Method : OECD Test Guideline 410

Acetylacetone:
Species : Rat
NOAEL : 200 mg/kg
LOAEL : 805 mg/kg
Application Route : inhalation (vapor)
Exposure time : 9 d

Species : Rat
NOAEL : 100 mg/kg
Application Route : inhalation (vapor)
Exposure time : 90 d
Method : OECD Test Guideline 413

Species : Rabbit
NOAEL : 244 mg/kg
LOAEL : 975 mg/kg
Application Route : Dermal
Exposure time : 9 d

Hydrogen peroxide:
Species : Mouse, female
NOAEL : 37 mg/kg
Application Route : oral (drinking water)
Exposure time : 90 d
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

19 / 27
Remarks : Hydrogen peroxide (H2O2), 35%

Species : Mouse, males
NOAEL : 26 mg/kg
Application Route : oral (drinking water)
Exposure time : 90
Remarks : Hydrogen peroxide (H2O2), 35%

Aspiration toxicity
Not classified due to lack of data.
Components:
Acetylacetone:
No aspiration toxicity classification

Hydrogen peroxide:
Based on available data, the classification criteria are not met.

Further information
Product:
Remarks : No data available

Components:
Acetylacetone:
Remarks : Solvents may degrease the skin.

SECTION 12. ECOLOGICAL INFORMATION
Ecotoxicity
Components:
2,4-Pentanedione, peroxide:
Toxicity to fish

: LC50 (Danio rerio (zebra fish)): > 67.6 mg/l
Exposure time: 96 h
Test Type: semi-static test
Method: OECD Test Guideline 203

Toxicity to daphnia and other
aquatic invertebrates

: EC50 (Daphnia magna (Water flea)): 7.05 mg/l
Exposure time: 48 h
Method: OECD Test Guideline 202

Toxicity to algae/aquatic : EC50 (Pseudokirchneriella subcapitata (green algae)): 5.36
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

20 / 27
plants

mg/l
Exposure time: 72 h
Method: OECD Test Guideline 201

Toxicity to microorganisms

: EC50: 614 mg/l
Exposure time: 3 h
Method: OECD Test Guideline 209

N-Methyl-2-pyrrolidone:
Toxicity to fish

: LC50 (Oncorhynchus mykiss (rainbow trout)): > 500 mg/l
Exposure time: 96 h

Toxicity to daphnia and other
aquatic invertebrates

: EC50 (Daphnia magna (Water flea)): > 1,000 mg/l
Exposure time: 24 h
Method: DIN 38412

EC50 (Palaeomonetes vulgaris (Grass shrimp)): 1,107 mg/l
Exposure time: 96 h

Toxicity to algae/aquatic
plants

: EC50 (Desmodesmus subspicatus (green algae)): > 500 mg/l
Exposure time: 72 h

NOEC (Desmodesmus subspicatus (green algae)): 125 mg/l
Exposure time: 72 h

Toxicity to daphnia and other
aquatic invertebrates (Chron-
ic toxicity)

: NOEC (Daphnia magna (Water flea)): 12.5 mg/l
Exposure time: 21 d
Method: OECD Test Guideline 211

LOEC (Daphnia magna (Water flea)): 25 mg/l
Exposure time: 21 d
Method: OECD Test Guideline 211

Toxicity to microorganisms

: EC50: > 600 mg/l
Exposure time: 0.5 h
Method: ISO 8192

Acetylacetone:
Toxicity to fish

: LC50 (Fish): 104 mg/l
Exposure time: 96 h

Toxicity to daphnia and other
aquatic invertebrates

: EC50 (Daphnia magna (Water flea)): 25.9 mg/l
Exposure time: 48 h
Method: OECD Test Guideline 202

Toxicity to algae/aquatic
plants

: EC50 (Pseudokirchneriella subcapitata (green algae)): 83.22
mg/l
Exposure time: 72 h
Method: OECD Test Guideline 201

SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

21 / 27

NOEC (Pseudokirchneriella subcapitata (green algae)): 3.2
mg/l
Exposure time: 72 h
Method: OECD Test Guideline 201

Toxicity to fish (Chronic tox-
icity)

: NOEC (Pimephales promelas (fathead minnow)): 10 mg/l
Exposure time: 34 d
Method: OECD Test Guideline 210

LOEC (Pimephales promelas (fathead minnow)): 22 mg/l
Exposure time: 34 d
Method: OECD Test Guideline 210

Toxicity to daphnia and other
aquatic invertebrates (Chron-
ic toxicity)

: NOEC (Daphnia magna (Water flea)): 18 mg/l
Exposure time: 21 d
Method: OECD Test Guideline 211

Toxicity to microorganisms

: EC50: 107.6 mg/l
Exposure time: 3 h
Method: OECD Test Guideline 209

EC10: 13.2 mg/l
Exposure time: 3 h
Method: OECD Test Guideline 209

Hydrogen peroxide:
Toxicity to fish

: LC50 (Pimephales promelas (fathead minnow)): 16.4 mg/l
Exposure time: 96 h

Toxicity to daphnia and other
aquatic invertebrates

: LC50 (Daphnia pulex (Water flea)): 2.4 mg/l
Exposure time: 48 h

Toxicity to algae/aquatic
plants

: EC50 (Skeletonema costatum (marine diatom)): 1.38 mg/l
Exposure time: 72 h

NOEC (Skeletonema costatum (marine diatom)): 0.63 mg/l
Exposure time: 72 h

Toxicity to daphnia and other
aquatic invertebrates (Chron-
ic toxicity)

: NOEC (Daphnia magna (Water flea)): 0.63 mg/l
Exposure time: 21 d

Toxicity to microorganisms

: EC50 (activated sludge): > 1,000 mg/l
Exposure time: 3 h
Method: OECD Test Guideline 209

Persistence and degradability
Components:
2,4-Pentanedione, peroxide:
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

22 / 27
Biodegradability

: Result: Readily biodegradable.
Method: OECD Test Guideline 301D

N-Methyl-2-pyrrolidone:
Biodegradability

: Result: Readily biodegradable.
Method: OECD Test Guideline 301C

Acetylacetone:
Biodegradability

: Result: Readily biodegradable.
Method: OECD Test Guideline 301C

Hydrogen peroxide:
Biodegradability

: Result: Readily biodegradable.

Bioaccumulative potential
Components:
2,4-Pentanedione, peroxide:
Partition coefficient: n-
octanol/water

: log Pow: 1.1 (25 °C / 25 °C)
Method: OECD Test Guideline 117

N-Methyl-2-pyrrolidone:
Partition coefficient: n-
octanol/water

: log Pow: -0.46 (25 °C / 25 °C)

Acetylacetone:
Bioaccumulation

: Bioconcentration factor (BCF): 3.16
Remarks: Calculation

Partition coefficient: n-
octanol/water

: log Pow: 0.68 (40 °C / 40 °C)

Hydrogen peroxide:
Partition coefficient: n-
octanol/water

: log Pow: -1.57 (20 °C / 20 °C)
Remarks: Information refers to the main ingredient.
Calculation

Mobility in soil
No data available
Other adverse effects
Product:
Ozone-Depletion Potential

: Regulation: 40 CFR Protection of Environment; Part 82 Pro-
tection of Stratospheric Ozone - CAA Section 602 Class I
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

23 / 27
Substances
Remarks: This product neither contains, nor was manufac-
tured with a Class I or Class II ODS as defined by the U.S.
Clean Air Act Section 602 (40 CFR 82, Subpt. A, App.A + B).

Additional ecological infor-
mation

: An environmental hazard cannot be excluded in the event of
unprofessional handling or disposal.
Toxic to aquatic life.

SECTION 13. DISPOSAL CONSIDERATIONS
Disposal methods
Waste from residues : Dispose of wastes in an approved waste disposal facility.
The product should not be allowed to enter drains, water
courses or the soil.
Do not contaminate ponds, waterways or ditches with
chemical or used container.

Contaminated packaging

: Dispose of in accordance with local regulations.
Clean container with water.
Dispose of contents/ container to an approved waste disposal
plant.
Empty remaining contents.
Dispose of as unused product.
Do not re-use empty containers.
Do not burn, or use a cutting torch on, the empty drum.

SECTION 14. TRANSPORT INFORMATION
International Regulations
UNRTDG
UN number : UN 3105
Proper shipping name : ORGANIC PEROXIDE TYPE D, LIQUID
(ACETYL ACETONE PEROXIDE)
Class : 5.2
Packing group : Not assigned by regulation
Labels : 5.2
Environmentally hazardous : no
IATA-DGR
UN/ID No. : UN 3105
Proper shipping name : Organic peroxide type D, liquid
(Acetyl acetone peroxide)
Class : 5.2
Packing group : Not assigned by regulation
Labels : Organic Peroxides, Keep Away From Heat
Packing instruction (cargo
aircraft)
: 570
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

24 / 27
Packing instruction (passen-
ger aircraft)
: 570
IMDG-Code
UN number : UN 3105
Proper shipping name : ORGANIC PEROXIDE TYPE D, LIQUID
(ACETYL ACETONE PEROXIDE)
Class : 5.2
Packing group : Not assigned by regulation
Labels : 5.2
EmS Code : F-J, S-R
Marine pollutant : no
Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code
Not applicable for product as supplied.
Domestic regulation
49 CFR
UN/ID/NA number : UN 3105
Proper shipping name : Organic peroxide type D, liquid
(Acetyl Acetone Peroxide, <=42%)
Class : 5.2
Packing group : Not assigned by regulation
Labels : ORGANIC PEROXIDE
ERG Code : 145
Marine pollutant : no
Special precautions for user
The transport classification(s) provided herein are for informational purposes only, and solely
based upon the properties of the unpackaged material as it is described within this Safety Data
Sheet. Transportation classifications may vary by mode of transportation, package sizes, and
variations in regional or country regulations.

SECTION 15. REGULATORY INFORMATION
CERCLA Reportable Quantity
This material does not contain any components with a CERCLA RQ.
SARA 304 Extremely Hazardous Substances Reportable Quantity
Listed substances in the product are at low enough levels to not be expected to exceed the RQ
SARA 302 Extremely Hazardous Substances Threshold Planning Quantity
Components CAS-No. Component TPQ (lbs)
Hydrogen peroxide 7722-84-1 1000
SARA 311/312 Hazards

: Flammable (gases, aerosols, liquids, or solids)
Organic peroxides
Respiratory or skin sensitization
Reproductive toxicity
Skin corrosion or irritation
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

25 / 27
Serious eye damage or eye irritation
Specific target organ toxicity (single or repeated exposure)

SARA 313

: The following components are subject to reporting levels
established by SARA Title III, Section 313:

N-Methyl-2-
pyrrolidone

872-50-4
Clean Air Act
This product neither contains, nor was manufactured with a Class I or Class II ODS as defined by
the U.S. Clean Air Act Section 602 (40 CFR 82, Subpt. A, App.A + B).
This product does not contain any hazardous air pollutants (HAP), as defined by the U.S. Clean
Air Act Section 112 (40 CFR 61).
This product does not contain any chemicals listed under the U.S. Clean Air Act Section 112(r) for
Accidental Release Prevention (40 CFR 68.130, Subpart F).
This product does not contain any chemicals listed under the U.S. Clean Air Act Section 111
SOCMI Intermediate or Final VOC's (40 CFR 60.489).
Clean Water Act
This product does not contain any Hazardous Substances listed under the U.S. CleanWater Act,
Section 311, Table 116.4A.
This product does not contain any Hazardous Chemicals listed under the U.S. CleanWater Act,
Section 311, Table 117.3.
This product does not contain any toxic pollutants listed under the U.S. Clean Water Act Section
307
This product does not contain any priority pollutants related to the U.S. Clean Water Act
California Prop. 65
WARNING: This product can expose you to chemicals including N-Methyl-2-pyrrolidone, which
is/are known to the State of California to cause birth defects or other reproductive harm. For more
information go to www.P65Warnings.ca.gov.
International Regulations
Gefahrgruppe nach TRGS 741: II (German regulatory requirements)
The ingredients of this product are reported in the following inventories:
TCSI (TW)

:

On the inventory, or in compliance with the inventory

TSCA (US)

:

All substances listed as active on the TSCA inventory

AIIC (AU)

:

On the inventory, or in compliance with the inventory

DSL (CA)

:

All components of this product are on the Canadian DSL

ENCS (JP)

:

On the inventory, or in compliance with the inventory

ISHL (JP)

:

On the inventory, or in compliance with the inventory

KECI (KR)

:

On the inventory, or in compliance with the inventory

SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

26 / 27
PICCS (PH)

:

On the inventory, or in compliance with the inventory

IECSC (CN)

:

On the inventory, or in compliance with the inventory

TSCA list
No substances are subject to a Significant New Use Rule.

The following substance(s) is/are subject to TSCA 12(b) export notification requirements:
Acetylacetone 123-54-6

SECTION 16. OTHER INFORMATION
Further information

This material safety datasheet only contains information relating to safety and does not replace
any product information or product specification.
These safety instructions also apply to empty packaging which may still contain product residues.
The hazards on the label also apply to residues in the container.

Sources of key data used to
compile the Material Safety
Data Sheet

: Internal technical data, data from raw material SDSs, OECD
eChem Portal search results and European Chemicals Agen-
cy, http://echa.europa.eu/

Revision Date : 05/13/2024

Full text of other abbreviations
ACGIH : USA. ACGIH Threshold Limit Values (TLV)
ACGIH BEI : ACGIH - Biological Exposure Indices (BEI)
NIOSH REL : USA. NIOSH Recommended Exposure Limits
OSHA P0 : USA. Table Z-1-A Limits for Air Contaminants (1989 vacated
values)
OSHA Z-1 : USA. Occupational Exposure Limits (OSHA) - Table Z-1 Lim-
its for Air Contaminants
US WEEL : USA. Workplace Environmental Exposure Levels (WEEL)
ACGIH / TWA : 8-hour, time-weighted average
NIOSH REL / TWA : Time-weighted average concentration for up to a 10-hour
workday during a 40-hour workweek
OSHA P0 / TWA : 8-hour time weighted average
OSHA Z-1 / TWA : 8-hour time weighted average
US WEEL / TWA : 8-hr TWA
US WEEL / STEL : Short-Term TWA

AIIC - Australian Inventory of Industrial Chemicals; ASTM - American Society for the Testing of
Materials; bw - Body weight; CERCLA - Comprehensive Environmental Response, Compensation,
SAFETY DATA SHEET

according to the OSHA Hazard Communication Standard

NOROX®AZOX

Version
2.2
Revision Date:
05/13/2024
SDS Number:
600000000076
Date of last issue: 06/27/2022
Date of first issue: 12/16/2016

27 / 27
and Liability Act; CMR - Carcinogen, Mutagen or Reproductive Toxicant; DIN - Standard of the
German Institute for Standardisation; DOT - Department of Transportation; DSL - Domestic Sub-
stances List (Canada); ECx - Concentration associated with x% response; EHS - Extremely Haz-
ardous Substance; ELx - Loading rate associated with x% response; EmS - Emergency Schedule;
ENCS - Existing and New Chemical Substances (Japan); ErCx - Concentration associated with
x% growth rate response; ERG - Emergency Response Guide; GHS - Globally Harmonized Sys-
tem; GLP - Good Laboratory Practice; HMIS - Hazardous Materials Identification System; IARC -
International Agency for Research on Cancer; IATA - International Air Transport Association; IBC
- International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals
in Bulk; IC50 - Half maximal inhibitory concentration; ICAO - International Civil Aviation Organiza-
tion; IECSC - Inventory of Existing Chemical Substances in China; IMDG - International Maritime
Dangerous Goods; IMO - International Maritime Organization; ISHL - Industrial Safety and Health
Law (Japan); ISO - International Organisation for Standardization; KECI - Korea Existing Chemi-
cals Inventory; LC50 - Lethal Concentration to 50 % of a test population; LD50 - Lethal Dose to
50% of a test population (Median Lethal Dose); MARPOL - International Convention for the Pre-
vention of Pollution from Ships; MSHA - Mine Safety and Health Administration; n.o.s. - Not Oth-
erwise Specified; NFPA - National Fire Protection Association; NO(A)EC - No Observed (Adverse)
Effect Concentration; NO(A)EL - No Observed (Adverse) Effect Level; NOELR - No Observable
Effect Loading Rate; NTP - National Toxicology Program; NZIoC - New Zealand Inventory of
Chemicals; OECD - Organization for Economic Co-operation and Development; OPPTS - Office
of Chemical Safety and Pollution Prevention; PBT - Persistent, Bioaccumulative and Toxic sub-
stance; PICCS - Philippines Inventory of Chemicals and Chemical Substances; (Q)SAR - (Quanti-
tative) Structure Activity Relationship; RCRA - Resource Conservation and Recovery Act;
REACH - Regulation (EC) No 1907/2006 of the European Parliament and of the Council concern-
ing the Registration, Evaluation, Authorisation and Restriction of Chemicals; RQ - Reportable
Quantity; SADT - Self-Accelerating Decomposition Temperature; SARA - Superfund Amend-
ments and Reauthorization Act; SDS - Safety Data Sheet; TCSI - Taiwan Chemical Substance
Inventory; TECI - Thailand Existing Chemicals Inventory; TSCA - Toxic Substances Control Act
(United States); UN - United Nations; UNRTDG - United Nations Recommendations on the
Transport of Dangerous Goods; vPvB - Very Persistent and Very Bioaccumulative

The information provided in this Safety Data Sheet is correct to the best of our knowledge, infor-
mation and belief at the date of its publication. The information given is designed only as a guid-
ance for safe handling, use, processing, storage, transportation, disposal and release and is not
to be considered a warranty or quality specification. The information relates only to the specific
material designated and may not be valid for such material used in combination with any other
materials or in any process, unless specified in the text.

US / Z8

RockWell, LLC Notice of Intent Application
Appendix A Process Description (See attached flow diagram) First, raw materials are kitted and measured to the correct quantity for the product being made. Then the raw materials are loaded into a mold, and the mold is closed and evacuated via a vacuum pump. After the part has cured, the part is removed from the mold. The part must then be sanded and mounting holes drilled into it using pneumatic tools. Finally, an automotive clear coat is sprayed over the well to give it additional UV protection. The molding methods and application of clear coat are proprietary and considered confidential. Emissions from the process come from polyester resin and catalyst in the production of the window well and from polyurethane clear coat. The emissions from the resin come through vacuum pumps and are removed from the building by turbines. The emissions from the clear coat come through a spray gun and are removed from the building by turbines. Both are filtered. Raw Materials Used and Annual Usage 2017 to 2021 The following raw materials are used: Material Manufacturer Purpose DX 040-8086 RTM Resin* Polynt Composites USA Resin used as main component NOROX AZOX* United Initiators, Inc. Catalyst to harden resin Rovicore Fiberglass Matt Chomarat Reinforcements Fibers to give strength to resin Econotac 2 Spray adhesive* Airtech International, Inc. Keeps fiberglass in place Nonwoven Polyester Veil Freudenberg Performance Materials Provides cosmetic skin Polyethylene Foam Various Manufactures To provide “I beam” effect which adds strength at minimal costs PC-77731-DM Paint Related Pigment American Colors Tinting for resin Polyurethane Clearcoat - Flat Axalta Coating Systems, LLC UV Protection * See attached Safety Data Sheets Operation Schedules and Production Rates
Rockwell’s production rates are cyclical and tend to be greatest in spring and summer. These rates are also increaing over time over the last 15 years. However, the last 30 months have been much more volitale.

Equipment Used in Process The equipment used in the manufacturing of window wells includes in-house built molds and various pneumatic and electric hand tools. To aid in curing 6, Superior Radiant Products, SD09N, 99,000 BTU radiant heaters are used.
020000400006000080000100000120000 Resin Usage in Pounds
01000002000003000004000005000006000007000008000009000001000000 Resin Usage in Pounds
Yearly Totals
Heating the office, production, and warehouse areas are 4, Lennox, LF24-300A-3, 241500 BTU gas furnaces. The equipment used in handling of emissions from the polyester resin and catalyst include:
• Welch 1937 Vacuum pump
• Soler & Palau USA, TXB16, 1/3 HP, belt driven tube axial fan
• RenewAire HE2XRT 2 @ 2 HP, air handler
• (6) Koch Filter Corp, 102-041-002, 12” X 20” X 1” Multi-Pleat filters
• (4) T4500 Industrial Maid Air Cleaners using 50 pounds each of Hydrosil HS-AC Carbon The equipment used in handling emissions from the polyurethane clear coat and hardener include:
• (2) Soler & Palau USA, TDB 30, 3 HP, belt driven tube axial fans
• 90” X 96” wall of Filter Technologies, 14AGP2020100, Paint Arrestor Pads, 15 Gram GX Media Description of Products Rockwell offers 2 series of window wells including the Rockwell 66, multi step egress well and the Rockwell 42, non-egress well. These series come in different heights. Rockwell also sells covers and grates which other companies produce. Stack Parameters The stack used for the polyester resin and catalyst is 36” diameter and 40” tall (above the roof, 352” above grade). To prevent emissions from being re-introduced into the building, the more powerful exhaust fan used on the polyurethane clear coat and hardener is taller and measures 36” diameter and 144” tall (above the roof, 456” above grade)

3
2
'
0
"

3
2
'
0
"

3
2
'
0
"

20" X 12" TYP. INTAKE DUCT AT EACH MOLD (X6)
EXHAUST DUCTS 32' ABOVE GRADEEXHAUST DUCTS 32' ABOVE GRADEEXHAUST DUCTS 32' ABOVE GRADE
24" INTAKE DUCT24" INTAKE DUCT
A A
B B
C C
D D
E E
F F
G G
H H
J J
K K
L L
M M
N N
P P
R R
T T
24
24
23
23
22
22
21
21
20
20
19
19
18
18
17
17
16
16
15
15
14
14
13
13
12
12
11
11
10
10
9
9
8
8
7
7
6
6
5
5
4
4
3
3
2
2
1
1
DRAWN
CHK'D
APPV'D
MFG
Q.A
UNLESS OTHERWISE SPECIFIED:
DIMENSIONS ARE IN INCHESSURFACE FINISH:TOLERANCES: LINEAR: ANGULAR:
FINISH:DEBURR AND BREAK SHARP EDGES
NAME SIGNATURE DATE
MATERIAL:
DO NOT SCALE DRAWING REVISION
TITLE:
DWG NO.
SCALE:1:100 SHEET 1 OF 1
A0
WEIGHT:
DAVE H.8/24/17
ROCKWELL WINDOW WELLS
Plant Layout Emission Points
RockWell, LLC
Notice of Intent
Application
Appendix C

Principle Emission:
Styrene from processing Polynt Composites’ 0408086-DT STYPOL 040-8086 using a “closed mold”
technique
This product ranges from 36 to 40% styrene.
The industry-based emission factor from a closed mold process is 0.02.
Based on: http://www.aqmd.gov/docs/default-source/planning/annual-emission-
reporting/guidelines-for-calculating-emissions-from-polyester-resin-operations.pdf

There are 6 molds that can be operated at one time.
Each mold can consume up to 1050 pounds of resin in a day.
1050 X 40% = 420; 420 X 0.02 = 8.4 pounds of styrene emissions a day.
Rockwell, LLC is projected to consume 620,000 pounds of resin in 2022 with a total throughput of
emissions of:
620,000 X 40% = 248,000; 248,000 X 0.02 = 4,90

Styrene Emissions Break Down:
Daily
Maximum
Weekly
Maximum
Monthly
Maximum
Yearly
Maximum
Last 12
Months
Per Mold 8.4 pounds 42 pounds 168 pounds 2016 pounds 1036 pounds
Per Entire
Plant (6
Molds)
50.4 pounds 252 pounds 1008 pounds 12096 pounds 6,216 pounds

Possible sources of fugitive emissions include:
Off-gassing from post-curing parts
Spill of resin
Repair of window wells

Exact emissions from these sources are unknown.

The other emissions include those generated from polyurethane clear coat.
These includes:
• N-methyl-2-pyrrolidone

The clear coat has 69.80% solids by volume and 74.99% solids by weight.
Rockwell used 112 gallons of the clear coat over the last 12 months.

RockWell, LLC
Notice of Intent
Application
Appendix D

Emissions from Polyester Resin:

Note: 2023, 2024, and 2025 are based on projected sales.

Note: 2023, 2024, and 2025 are based on projected sales.
0100020003000400050006000700080009000 Styrene Emissions in Pounds
Yearly Totals
020406080100120140160180
Polyurethane Clear Coat Usage in
Gallons
Yearly Totals
RockWell, LLC
No-ce of Intent
Applica-on
Appendix C
Principle Emission:
Styrene from processing Polynt Composites’ 0408086-DT STYPOL 040-8086 using a “closed mold”
technique
This product ranges from 36 to 40% styrene.
The industry-based emission factor from a closed mold process is 0.02.
Based on: hUp://www.aqmd.gov/docs/default-source/planning/annual-emission-repor-ng/
guidelines-for-calcula-ng-emissions-from-polyester-resin-opera-ons.pdf
There are 6 molds that can be operated at one -me.
Each mold can consume up to 725.4 pounds of resin in a day.
725.4 X 40% = 290.16; 290.15 X 0.02 = 5.8032 pounds of styrene emissions a day.
Over the last 12 months, Rockwell, LLC is projected to consume 490,000 pounds of resin in 2017 with
a total throughput of emissions of:
490,000 X 40% = 196,000; 196,000 X 0.02 = 3,920
Styrene Emissions Break Down:
Possible sources of fugi-ve emissions include:
Off-gassing from post-curing parts
Spill of resin
Repair of window wells
Exact emissions from these sources are unknown.
The other emissions include those generated from polyurethane clear coat.
These includes:
•Alipha-c Polyisocyanate Resin
•Butyl Acetate
•Ethyl Acetate
•Ethylene Glycol Monobutyl Ether Acetate
The clear coat has 69.80% solids by volume and 74.99% solids by weight.
Rockwell used 75 gallons of the clear coat over the last 12 months.
Daily
Maximum
Weekly
Maximum
Monthly
Maximum
Yearly
Maximum
Last 12
Months
Per Mold 5.8 pounds 29 pounds 116.1 pounds 1,392.8
pounds
631.8 pounds
Per En-re
Plant (6
Molds)
34.8 pounds 174.1 pounds 696.4 pounds 8,356.6
pounds
3,790.8
pounds
RockWell, LLC
No-ce of Intent
Applica-on
Appendix D
Emissions from Polyester Resin:

Note: 2017, 2018, and 2019 are based on projected sales.

Note: 2017, 2018, and 2019 are based on projected sales.
Styrene Emissions in
Pounds
0
1250
2500
3750
5000
1/2/2016 1/2/2018 1/2/2020 1/2/22
Yearly Totals
Polyurethane Clear Coat
Usage in Gallons
0
25
50
75
100
1/2/2016 1/2/2018 1/2/2020 1/2/22
Yearly Totals
RockWell, LLC
No-ce of Intent
Applica-on
Appendix G
Best technologies for the polyester resin and catalyst:
Rockwell already employs the best technology available for reducing emissions by u-lizing closed
mold technology. Closed mold compared to the normal open mold methods used by other composite
manufacturers throughout the state reduces emissions by as much as 80%. (hUp://
compositesmanufacturingmagazine.com/2011/05/open-book-adop-ng-closed-molding/)
Maintaining Rockwell’s closed molds cost $71,850 in 2018 which reduces Rockwell’s emissions by
20,000 pounds a year.
$71,850 / 20,000 pounds = $3.59 per pound
In an ongoing effort to have the lowest emission possible, Rockwell has done comprehensive
research to understand what other steps may be taken. Two approaches have been iden-fied. One is
to use materials that emit lower vola-le organic compounds. The other is to use further emission
reduc-on technology.
Ajer extensive tes-ng and research, Rockwell has found that using reinforced thermoplas-cs
(including products like Polystrand) may offer the best reduc-on to emissions. However, the surface
finish of such products lack the cosme-c appeal Rockwell is famous for. It may be possible to replace
up to 60% of the polyester resin with this product. The equipment (including molds, ovens, and
presses) needed to process reinforced thermoplas-cs is es-mated to cost $950,000 in up front costs
and $30,000 a year in ongoing costs. If a 10-year horizon and the average of 7,500 pounds of styrene
a year is used, the cost per pound of styrene removal would be:
$950,000 / 10 years = $95,000 + $30,000 = $125,000 / 7,500 pounds X 60% = 4,500 pounds = $27.78
per pound.
Rockwell will con-nue to do research and is currently working with vendors to prove out materials
that have lower emissions. Rockwell has the goal of switching over to such a material by 2023.
Technologies that remove styrene from air are limited and not widely used. The most popular are
absorp-on in sacrificial medium and incinera-on. The best wri-ng found during research came from
the following web page:
hUp://www.plas-cseurope.org/Documents/Document/20100308111848-
EnglishCEFICpdf9StyreneabatemenUechniques-20050913-002-EN-v1.pdf
Rockwell was unable to locate anyone offering incinera-on capability or exper-se on a scale that
made sense for current or future produc-on size and techniques. Companies like Eco Incinerator or
Incinco Incinerators lack exper-se in the field of styrene removal and did not know if it would work.
The only technology, which was found to have a known track record of styrene removal, was using a
carbon filtra-on as a sacrificial medium. Rockwell has purchased 2 T4500 Industrial Air Cleaners for
$13,036. Ajer analysis of 4 samples, it has been found that the carbon needs to be changed out
every 6 months. From the sampling the lab has es-mated that the carbon has removed 0.15 - 0.18
pounds of styrene for every pound of carbon. Between the 2 units, there is 100 pounds of carbon.
That would mean that every year the carbon is removing from 30 to 36 pounds of styrene. The
carbon cost $3.22 per pound. Rockwell hired Mitch Haycock to study the waste stream of the carbon.
He found that the carbon could be disposed with normal solid waste resul-ng in negligible costs.
Assuming that the units last 5 years and need minimal maintenance, the total cost of styrene removal
using this method is:
$13,036 / 5 = $2,607 + $322 = $2,929 / 33 pounds = $88.76 per pound
Rockwell hoped this would be a more economical method of removing styrene. At this point, it would
appear the Polystrand offers a more impacnul, efficient way of reducing styrene.
Best technologies for polyurethane clear coat and hardener:
Similar technologies exist to remove the VOCs from the air emiUed from the polyurethane clear coat;
however these are much more commonly used. Some of the exact equipment quoted by Sentry Air
Systems could be used for this applica-on. Sentry has experience dealing with polyurethane paints
and offers test data on removal rates, found on the web site:
hUps://www.sentryair.com/data.htm
Because of the reduced volume upfront costs would be lower, around $10,000 to $16,000, and
ongoing cost would represent only replacement filters because once the polyurethane becomes a
solid it will no longer emit VOCs. The ongoing cost would be from $700 to $1,200 annually.
RockWell, LLC
No-ce of Intent
Applica-on
Appendix I
Relevance of NAAQS, SIP, NSPS, NESHAP Rockwell emissions:
From researching informa-on from the E.P.A., Utah Department of Air Quality, S.D.S.s
and reputable informa-on on-line, Rockwell believes there are no emissions of lead,
nitrogen dioxide, ozone, or suffer dioxide produced. However, Rockwell creates carbon
monoxide emissions from the use of natural gas in hea-ng systems. Rockwell rou-nely
maintains this equipment, so emissions are kept to a minimum. Rockwell u-lizes carbon
monoxide monitors throughout the plant, and these monitors have never sounded and
alarm or had a posi-ve reading. Rockwell also creates par-cle pollu-on by sanding and
cusng of materials. These processes all have air filtra-on currently in place.
Measurements have not been taken to quan-fy the effec-veness of this filtra-on.
According to the State of Utah's State Implementa-on Plan, Utah County has reach
NAAQS standards from 1994 on, through the State of Utah's maintenance efforts and
the 1991 S.I.P.'s environmental controls.
hUps://deq.utah.gov/Laws_Rules/daq/sip/docs/2016/01Jan/IX.A.
12_Utah_County%20.pdf
Rockwell believes that the New Source Performance Standards and Permisng
Requirements and Asbestos Na-onal Emissions for Hazardous Air Pollutants do not
pertain to both Rockwell's size or industry.
Rockwell further believes that it may increased emissions according to expected growth
of the company and not violate the NAAQS, State of Utah's SIP, NSPS, or NESHAP.
RockWell, LLC
No-ce of Intent
Applica-on
Appendix J
Emissions Impact Analysis:
Rockwell believes that the UDAQ does not require dispersion modeling and none has been done.
Rockwell is located in an industrial area in Springville and does not believe that any health threat is
generated from emissions.
RockWell, LLC
Notice of Intent
Application
Appendix G
Best Available Control Technology

Best technologies for the polyester resin and catalyst:
Rockwell already employs the best technology available for reducing emissions by utilizing closed mold
technology. Closed mold compared to the normal open mold methods used by other composite
manufacturers throughout the state reduces emissions by as much as 80%.
(http://compositesmanufacturingmagazine.com/2011/05/open-book-adopting-closed-molding/)
Maintaining Rockwell’s closed molds cost $71,850 in 2018 which reduces Rockwell’s emissions by 20,000
pounds a year.

$71,850 / 20,000 pounds = $3.59 per pound

In an ongoing effort to have the lowest emission possible, Rockwell has done comprehensive research to
understand what other steps may be taken. Two approaches have been identified. One is to use materials
that emit lower volatile organic compounds. The other is to use further emission reduction technology.
After extensive testing and research, Rockwell has found that using reinforced thermoplastics (including
products like Polystrand) may offer the best reduction to emissions. However, the surface finish of such
products lack the cosmetic appeal Rockwell is famous for. It may be possible to replace up to 60% of the
polyester resin with this product. The equipment (including molds, ovens, and presses) needed to process
reinforced thermoplastics is estimated to cost $950,000 in up front costs and $30,000 a year in ongoing costs.
If a 10-year horizon and the average of 7,500 pounds of styrene a year is used, the cost per pound of styrene
removal would be:

$950,000 / 10 years = $95,000 + $30,000 = $125,000 / 7,500 pounds X 60% = 4,500 pounds = $27.78 per
pound.

Rockwell will continue to do research and is currently working with vendors to prove out materials that have
lower emissions. Rockwell has the goal of switching over to such a material by 2023.

Technologies that remove styrene from air are limited and not widely used. The most popular are absorption
in sacrificial medium and incineration. The best writing found during research came from the following web
page:

http://www.plasticseurope.org/Documents/Document/20100308111848-
EnglishCEFICpdf9Styreneabatementtechniques-20050913-002-EN-v1.pdf

Rockwell was unable to locate anyone offering incineration capability or expertise on a scale that made sense
for current or future production size and techniques. Companies like Eco Incinerator or Incinco Incinerators
lack expertise in the field of styrene removal and did not know if it would work.

The only technology, which was found to have a known track record of styrene removal, was using a carbon
filtration as a sacrificial medium. Attached is the leading quote provider to Rockwell from Sentry Air Systems,
Inc. The up-front costs of this system would likely be in the $20,000 to $40,000 range. Ongoing costs have not
been determined. The best supposition is that Rockwell would replace 3 filters 12 times a year and that each
filter would contain about 77.8 pounds of styrene. ETA Environmental and Univar were unable to provide a
quote on the proper disposal of the filters without having an existing waste stream to analyze.

Rockwell will purchase 2 T4500 Industrial Air Cleaners for $13,036. The ongoing cost of replacement carbon
filtration and disposal has been estimated at $380.00 a month. Each unit is projected to remove 500 pounds
of styrene a year. If the unit last 5 years on this cost structure, the cost of styrene removal per pound would
be:

$13,036 / 5 = $2,607 + $4,560 = $7,167 / 1,000 pounds = $7.17 per pound

Rockwell plans to buy 2 more units per year provided the cost and benefit are proven out.

Best technologies for polyurethane clear coat and hardener:

Similar technologies exist to remove the VOCs from the air emitted from the polyurethane clear coat;
however these are much more commonly used. Some of the exact equipment quoted by Sentry Air Systems
could be used for this application. Sentry has experience dealing with polyurethane paints and offers test
data on removal rates, found on the web site:

https://www.sentryair.com/data.htm

Because of the reduced volume upfront costs would be lower, around $10,000 to $16,000, and ongoing cost
would represent only replacement filters because once the polyurethane becomes a solid it will no longer
emit VOCs. The ongoing cost would be from $700 to $1,200 annually.

RockWell, LLC
Notice of Intent
Application
Appendix G
Best Available Control Technology

Best technologies for the polyester resin and catalyst:
Rockwell already employs the best technology available for reducing emissions by utilizing closed mold
technology. Closed mold compared to the normal open mold methods used by other composite
manufacturers throughout the state reduces emissions by as much as 80%.
(http://compositesmanufacturingmagazine.com/2011/05/open-book-adopting-closed-molding/)
Maintaining Rockwell’s closed molds cost $199,700 in 2021 which reduces Rockwell’s emissions by 30,000
pounds a year.

$199,700 / 30,000 pounds = $6.66 per pound

In an ongoing effort to have the lowest emission possible, Rockwell has done comprehensive research to
understand what other steps may be taken. Two approaches have been identified. One is to use materials
that emit lower volatile organic compounds. The other is to use further emission reduction technology.
After extensive testing and research, Rockwell has found that using reinforced thermoplastics (including
products like Polystrand, Glass Mat Reinforced Thermoplastic (GMT), and Direct Long Fiber Thermoplastics
(DLFT)) may offer the best reduction to emissions. However, the surface finish of such products lack the
cosmetic appeal Rockwell is famous for. It may be possible to replace up to 60% of the polyester resin with
this product. The equipment (including molds, ovens, and presses) needed to process reinforced
thermoplastics cost $2,200,000 in upfront costs and $50,000 a year in ongoing costs. If a 10-year horizon and
the average of 7,500 pounds of styrene a year is used, the cost per pound of styrene removal would be:

$2,200,000 / 10 years = $220,000 + $50,000 = $270,000 / 7,500 pounds X 60% = 4,500 pounds = $60.00 per
pound.

Rockwell launched this product in 2020 and has sold over 17,000 of this style of window well so far.

Technologies that remove styrene from air are limited and not widely used. The most popular are absorption
in sacrificial medium and incineration. The best writing found during research came from the following web
page:

http://www.plasticseurope.org/Documents/Document/20100308111848-
EnglishCEFICpdf9Styreneabatementtechniques-20050913-002-EN-v1.pdf

Rockwell was unable to locate anyone offering incineration capability or expertise on a scale that made sense
for current or future production size and techniques. Companies like Eco Incinerator or Incinco Incinerators
lack expertise in the field of styrene removal and did not know if it would work.

The only technology, which was found to have a known track record of styrene removal, was using a carbon
filtration as a sacrificial medium. Rockwell purchased 4 Industrial Maid AZTech Model T4500 air cleaners from
Filter Technologies. The up-front costs of this system, including shipping and installation, were $9,179.12
each for a total of $36,716.48. Ongoing costs are $1,960 per year. This includes power, carbon, and filters.

Hydrosil’s lab estimated that each pound of carbon absorbed from 0.15 to 0.18 pounds of styrene based on
changing the carbon out twice a year. Each unit holds 50 pounds of carbon. This is a total of 400 pounds of
carbon used. At 0.165 pounds of styrene removed, a total of 66 pounds are removed each year. If the unit
lasts 5 years on this cost structure, the cost of styrene removal per pound would be:

$36,716.48 / 5 = $7,343 + $1,960 = $9,303 / 66 pounds = $140.96 per pound

Best technologies for polyurethane clear coat and hardener:

Similar technologies exist to remove the VOCs from the air emitted from the polyurethane clear coat;
however, these are much more commonly used. Some of the exact equipment quoted by Sentry Air Systems
could be used for this application. Sentry has experience dealing with polyurethane paints and offers test
data on removal rates, found on the web site:

https://www.sentryair.com/data.htm

Rockwell has utilized two methods of producing VOCs from the polyurethane clear coat. The first method is
using fiberglass filtration the traps a percentage of the clear coat and allows it to solidify. The second method
is to use a water-based polyurethane that has less VOC's.

The water-based polyurethane emits 40% less VOCs than the previous oil-based polyurethane. In 2021, that
represents over 180 pounds of VOCs which cost an additional $9,193.30 compared to the oil-based clear
coat.

$9,193.30 / 180 pounds = $51.07 per pound

There is not a consistent, published percentage of VOCs that are removed by fiberglass filtration, but the
number is assumed to be under 20%.

Using 10%, in 2021, that would have represented about 27 pounds of VOCs. We spent $2,806.30 on filters in
2021.

$2,806.30 / 27 pounds = $103.94 per pound

Although there are other methods to try the volumes of polyurethane clear coat make most of them cost
prohibited. At this time there are no plans for further reduction.

Emissions Check
Summary of Emissions
PTE (ton/year)
Pollutant Combustion Coatings Resin Molds Sanding Total
Particulate Matter 0.01 7.99 -0.00 8.01
Particulate Matter ≤ 10 µm 0.05 6.79 -0.00 6.84 https://www.epa.gov/sites/default/files/20
Particulate Matter ≤ 2.5 µm 0.05 2.40 -0.00 2.45 https://www.epa.gov/sites/default/files/20
Sulfur Oxides 4.02E-03 --0.004
Nitrogen Oxides 0.67 --0.67
Carbon Monoxide 0.56 --0.56
Volatile Organic Compounds 0.04 11.55 5.04 16.63
CO2e basis 800 --800
Total Hazardous Air Pollutants 0.01 0.00 5.04 5.05
Paint and varnish is
Category 4(Table B.2-1.)
Table B.2.2
Partical distribution
PM10:<85 %
PM2.5:<30 %
Emissions Check
Combustion Equipment: Six (6) 0.1 MMBtu/ hr Curing Ovens and Four (4) 0.24 MMBtu/hr Process Heaters
Heat Input Capacity (MMBtu/hr) {Combined Units} =1.56
Heating Value of Natural Gas (Btu/scf)[1] =1,020
Natural Gas Throughput (MMscf/hr) =1.53E-03
Operating Hours (hrs/yr) =8,760
Pollutant Emission
Factor Units
Emission
Factor
Source
PTE
(lbs/hr)
PTE
(ton/yr)
Particulate Matter 1.90 lb/MMscf Reference 1 2.91E-03 0.01
Particulate Matter ≤ 10 µm[2]7.60 lb/MMscf Reference 1 0.01 0.05
Particulate Matter ≤ 2.5 µm[2]7.60 lb/MMscf Reference 1 0.01 0.05
Sulfur Oxides 0.60 lb/MMscf Reference 1 9.18E-04 4.02E-03
Nitrogen Oxides 100.00 lb/MMscf Reference 2 0.15 0.67
Carbon Monoxide 84.00 lb/MMscf Reference 2 0.13 0.56
Volatile Organic Compounds 5.50 lb/MMscf Reference 1 8.41E-03 0.04
Greenhouse Gases (GHGs)
CO2 53.06 kg CO2/MMBtu Reference 3 182 799
CH4 1.00E-03 kg CH4/MMBtu Reference 4 3.44E-03 0.02
N2O 1.00E-04 kg N2O/MMBtu Reference 4 3.44E-04 1.51E-03
GHGs (mass basis)182 799
CO2e basis[3]183 800
Hazardous Air Pollutants
Benzene 2.10E-03 lbs/MMscf Reference 5 3.21E-06 1.41E-05
Formaldehyde 7.50E-02 lbs/MMscf Reference 5 1.15E-04 5.02E-04
Hexane 1.80 lbs/MMscf Reference 5 2.75E-03 0.01
Polycyclic Organic Matter 1.90E-03 lbs/MMscf Reference 5 2.90E-06 1.27E-05
Toluene 3.40E-03 lbs/MMscf Reference 5 5.20E-06 2.28E-05
Arsenic Compounds 2.00E-04 lbs/MMscf Reference 6 3.06E-07 1.34E-06
Beryllium Compounds 1.20E-05 lbs/MMscf Reference 6 1.84E-08 8.04E-08
Cadmium Compounds 1.10E-03 lbs/MMscf Reference 6 1.68E-06 7.37E-06
Chromium Compounds 1.40E-03 lbs/MMscf Reference 6 2.14E-06 9.38E-06
Cobalt Compounds 8.40E-05 lbs/MMscf Reference 6 1.28E-07 5.63E-07
Lead Compounds 5.00E-04 lbs/MMscf Reference 1 7.65E-07 3.35E-06
Manganese Compounds 3.80E-04 lbs/MMscf Reference 6 5.81E-07 2.55E-06
Mercury Compounds 2.60E-04 lbs/MMscf Reference 6 3.98E-07 1.74E-06
Nickel Compounds 2.10E-03 lbs/MMscf Reference 6 3.21E-06 1.41E-05
Selenium Compounds 2.40E-05 lbs/MMscf Reference 6 3.67E-08 1.61E-07
Total Hazardous Air Pollutants 2.89E-03 0.01
Reference 1: AP-42 Table 1.4-2
Reference 2: AP-42 Table 1.4-1
Reference 3: 40 CFR 98 Table C-1
Reference 4: 40 CFR 98 Table C-2
Reference 5: AP-42 Table 1.4-3
Reference 6: AP-42 Table 1.4-4
[1] AP-42 Section 1.4
[2] PM10 and PM2.5 Emission Factors are assumed to be equal to Total PM Emission Factor
[3] 40 CFR 98 Table A-1
Emissions Check
Spray Coating Operations[1]
Process Information
Product
Description
Usage x Safety
Factor of 5%
(gal)
Density
(lb/gal) [3]
VOC
(lb/gal)
Solid
(%)[4]
Ethylene Glycol
Monobutyl Ether Acetate
(%)
Ethyl Benzene
(%)
Toluene
(%)
Polyurethane Clearcoat 210.00 9.18 0.00 75.00 0.00%0.00%0.00%*new clear coat - no HAPs or VOCs
Clear Coat Activator 150.00 9.09 2.75 6.34 4.00%0.00%0.00%*new clearcoat is water-cured and does not need activator
Adhesive 5000.00 5.91 4.62 26.00 0.00%0.00%0.00%*VOC content of 552.55 g/l.
PTE Summary
Total VOCs
(tpy)
Total PM
(tpy)[2]
Ethylene Glycol
Monobutyl Ether Acetate
(tpy)
Ethyl Benzene
(tpy)
Toluene
(tpy)
Total HAPs
(tpy)
11.55 7.99 0.00 0.00 0.00 0.00
[1]All Information taken from NOI
[2]Includes 95% control efficiency for fabric filters 23100 11.55
[3] New SDS (1.1 g/cm3)
[4] The clear coat has 69.80% solids by volume and 74.99% solids by weight. A transfer efficiency of 65% for spray coating was used, taken from instructions for painting/coating operations emission calculations by the Minnesota Pollution Control Agency
Emissions Check
Resin Mold Operations[1]
Process Information
Description
Usage x Safety Factor of
5%
(lbs)
Styrene Content
(%)
Emission Factor
Closed Mold Process*
Resin 1,260,000 40.00%0.02
PTE Summary
VOC/HAP
Emissions
(lbs/hr)[2]
VOC/HAP
Emissions
(lbs/yr)
VOC/HAP
Emissions
(tpy)
Amount of VOC/HAP
Controlled
(tpy)[3]
Hours of
Operation
Controlled
VOC/HAP
Emissions
(lbs/hr)[2]
Controlled
VOC/HAP
Emissions
(tpy)
Styrene TLV
(lbs/hr)[4]
Less Than
TLV?
9.69 10,080 5.04 0.00 4400.00 2.29 5.04 8.44 Yes
*Vertically Unrestricted Releases, <50 m
[1]All information taken from NOI
[2]lbs/hr emission rates calculated assuming 4400 operating hours per year for the resin mold stations
[3]Rockwell purchased two T4500 Industrial Air Cleaners for $13,036 in 2019 and then 2 additional unitsOctober of 2021 for $17,358. The ongoing cost of replacement carbon filtration and disposal has been$1,558.00 for the last 12 months. Each unit costs $389.50 per year. From lab analysis of the carbon after ithas been replaced, each unit is believed to remove 60 - 80 pounds of styrene a year.
[4]Taken from UDAQ's HAP air dispersion modeling guidance. Styrene TLV for vertically unrestricted releases less than 50 m from the property line used.
*http://www.aqmd.gov/docs/default-source/planning/annual-emission-reporting/guidelines-for-calculating-emissions-from-polyester-resin-operations.pdf
https://www.epa.gov/sites/default/files/2020-10/documents/13.2.6_abrasive_blasting.pdf
Abrasive blasting of unspecified metal parts, controlled with a fabric filter
EF:Total PM 0.69 lb/1,000 lb abrasive
**Source does not use abrasive blasting, but "sands" the material using sanding disks. Emissio
Total material used annually 450 disks
Total material used annually 6 lbs total
PTE SummaryTotal PM
(lb/yr)
Total PM
(tpy)0.0041 0.0000021
*Source uses a fabric filter
ns are therefore likely overconservative