Boat Manufacturing NESHAP Workshop U.S. Environmental Protection Agency Office of Air Quality Planning and Standards

1. Boat Manufacturing NESHAP Workshop U.S. Environmental Protection AgencyOffice of Air Quality Planning and StandardsFebruary 8, 2002International Boatbuilders’ Exhibition & ConferenceFt. Lauderdale, FL

2. Objectives for this Workshop Review the requirements of the boat manufacturing rule. Provide some examples to help explain the requirements. Answer questions from industry and regulators. Provide you with information on additional resources.

3. SECTION 1.0 - OVERVIEW OF THE INDUSTRY

10. Resources for Estimating Styrene Emissions Links on EPA’s emission factor website: (http://www.epa.gov/ttn /chief/efdocs/) EPA/Office of Research and Development (ORD) model. Composite Fabricators Association (CFA) model. National Marine Manufacturers Association (NMMA) study.

11. National Baseline HAP Emissions(Based on 1996 EPA survey data)

12. SECTION 2.0 - OVERVIEW OF THE RULE Who? What? When? How?

14. Who is Covered? Your facility is subject if it meets both of the following criteria: It meets the definition of boat manufacturing facility. It is a major source of HAP.

15. Definition of a Boat Manufacturing Facility: Manufactures hulls or decks from fiberglass or aluminum; OR Assembles boats from pre-manufactured hulls and decks; OR Builds molds to make fiberglass hulls or decks.

16. What is a Major Source? Has the potential to emit: 10 tpy of a single HAP; OR 25 tpy of a combination of HAP.

17. Example: Is this facility a major source? FRP boat manufacturing: styrene emissions = 8 tpy. Aluminum boat manufacturing: various HAP = 10 tpy. FRP golf cart manufacturing: styrene emissions = 8 tpy.

18. Example: Is this facility a major source? FRP boat manufacturing: actual styrene emissions = 7 tpy Operating schedule is 8 hours per day, 5 days per week.

19. Can a facility obtain an area source exemption so it is not subject to this rule?

20. Fiberglass boat manufacturers: Resin and gel coat: Limit usage to 50 tons per year. Aluminum boat manufacturers: All solvents, coatings, and carpet and fabric adhesives: Limit usage to 20 tons per year. Area Source Exemption Requirements for Material and HAP Consumption

21. Fiberglass or aluminum boat manufacturers: Limit HAP consumption: 5 ton/year of a single HAP and 12.5 ton/year of all combined HAP. For all: Materials with limits must account for 90 percent of emissions. Keep records and calculations demonstrating compliance. Area Source Exemption Requirements for Material and HAP Consumption (Continued)

22. What Does the Rule Cover?

23. Regulated Operations in FRP Boat Manufacturing

24. Regulated Operations in Recreational Aluminum Boat Manufacturing

25. Aluminum coating operations on non-recreational boats (e.g., military or commercial). Research and development activities. Materials in hand-held aerosol cans. Other Operations Not Covered

26. HAP Content Limits: Open molding resin and gel coats. Carpet and fabrication adhesives. Aluminum recreational boat surface coatings. Work Practice Requirements: Non-atomizing (non-spray) resin application equipment. Covered resin and gelcoat mixing containers (55 gallons and up). Enclosed spray gun cleaners for aluminum boat painting. Rule Is Based on Pollution Prevention

27. Compliance Dates Existing Sources: August 22, 2004 New Sources: Upon startup Area => major sources: One year after becoming a major source, or August 22, 2004, whichever is later

28. Started construction after July 14, 2000. It is a major source upon startup. It is a completely new boat manufacturing facility where none existed immediately prior to the construction of the facility. What is a New Source?

29. Facility is built in 1990 and is emitting 40 tpy of styrene. Facility begins construction on January 31, 2002 and starts operating on July 31, 2002 and is emitting 30 tpy of styrene. Facility is built in 1995 and emits 7 tpy of styrene until 2004. On July 31, 2004, facility expands and begins emitting 15 tpy of styrene. Examples: What is the compliance date?

30. Compliance Time-line: Existing Sources

31. Compliance Time-line: New Sources

32. SECTION 3.0 - FIBERGLASS BOAT MANUFACTURING OPERATIONS

33. Exemptions from Emission Limits Resins required to meet military specifications for use on military vessels. Resins approved by the U.S. Coast Guard for use in: life saving boats and appliances subject to 46 CFR subchapter Q small passenger vessels subject to 46 CFR subchapter T. 100-percent vinylester skin coat resins. Not to exceed 5 percent of the total resin used per year. Note: Exempt resins must be applied with non-spray (non-atomizing) technology.

34. Exemptions (Continued) Gel coats used for part or mold repair Not to exceed 1 percent of the total gel coat used per year. Solvents used to remove cured resin and gel coat from application equipment.

35. Examples How many tons of resin or gel coat are exempt at each facility? A facility uses 100 tons per year of resin; 7 tons are a 100-percent vinylester resin used for skin coats. A facility uses 20 tons per year of gel coat: 15 tons of pigmented gel coat; and 5 tons of tooling gel coat. 200 lbs (0.1 ton) of the tooling gel coat is used for mold touch-up and repair.

36. Resin and Gel Coat Compliance Options

37. No limit on HAP content of resin used for closed molding. No records needed. Process must meet the definition of closed molding. Closed Molding Requirements

38. Fabric and other reinforcements are placed between two mold surfaces. Mold surfaces could be rigid or flexible. Pressure distributes the resin throughout the mold and saturates the fabric and reinforcements. Pressure could be vacuum, clamping, or fluid pressure. Closed Molding Definition

39. Compression molding with sheet molding compound (SMC). Infusion molding or vacuum assisted resin transfer molding (VARTM). Resin transfer molding (RTM). Vacuum assisted compression molding. These are not closed molding: Vacuum bagging after the resin is applied. Gel coat and skin coat applied with open molding. Closed Molding Examples

40. Compliant Materials OptionBased On Each Material All materials in an open molding operation meet specific HAP content limits. Benefits: No compliance calculations Minimal recordkeeping.

41. HAP Content Limits for Resin and Gel Coat Operations

42. HAP Content Limits for Production Resin Vacuum Bagging Operations Limits are Derived from MACT Model Point Value Equations

43. Weighted-average HAP content determined monthly from the material used in each 12-month compliance period. Separate compliance determination for each operation. Benefit: You can use a mix of low-HAP and high HAP materials within an operation. Compliant Materials Option Based on Weighted-Average HAP Content

44. Weighted-Average HAP Content Example

45. Step 1: Total resin used is 100 Mg; 5 Mg of the vinylester skin coat resin (5% of total) is exempt

47. Step 3: Divide Mg HAP by Mg resin and multiply by 100%

48. HAP content of each material. Amount of each material used per month. Calculations performed each month to demonstrate compliance based on previous 12 months data. Records Needed for the Compliant Materials Option Based on Weighted-Average HAP Content:

49. Emissions Averaging  Emission limit and emission rate are 12-month rolling averages. Emission limit and emission rate may change every month.

50. Emissions Averaging Features Averaging does not need to include all operations. Averaging must be done using MACT model point values. MACT model point values: Are NOT intended for use as emission factors. MUST be calculated from the equations in the rule.

51. Emissions Averaging Implementation Plan Intended as a “road-map.” Submitted with notification of compliance status. Describes the operations included in the average. Describes HAP contents, application methods, other control methods. Includes calculations demonstrating future compliance. Kept on site and available for inspection. Submit any changes with the next semi-annual compliance report.

52. Calculating the Emission Limitation HAP limit = 46(MR) + 159(MPG) + 291(MCG) + 54(MTR) + 214(MTG) HAP limit = allowable HAP emissions (kg/year) Mi = mass of each material used, Mg (1 Mg = 1.1023 tons)

53. Calculating the Emission Rate HAP emissions = PVR(MR) + PVPG(MPG) + PVCG(MCG) + PVTR(MTR) + PVTG(MTG) HAP emissions = HAP emission rate (kg/year) PVi = point value for each material used, kg HAP/Mg material used (1 Mg = 1.1023 tons)

54. MACT Model Point value EquationsTable 3 to Subpart VVVV Example: Production resin, non-spray: kg HAP/Mg resin applied = 0.014(HAP%)2.275 Separate point value equations for resin based on: atomized or non-atomized application vacuum bagging with or without roll-out One equation for all gel coat operations

55. Example: Is this facility in compliance based on emissions averaging?

56. Step 1: Calculate the Emission Limit HAP limit = 46(MR) + 159(MPG) + 291(MCG) + 54(MTR) + 214(MTG) HAP limit = 46(90+10) + 159(30) + 291(0) + 54(0) + 214(0) = 9,370 kg HAP

57. Step 2: Calculate the MACT Model Point Value for Each Operation

58. Step 3: Calculate HAP Emissions (kg/yr)

59. Step 4: Compare the HAP Emissions to the HAP Limit

60. The HAP content of each material. The amount of each material used per month. Monthly compliance calculations. An up-to-date copy of your implementation plan. Records Needed For the Emissions Averaging Option

61. Filled resins are mixed with an inert filler to reduce shrinkage and improve heat transfer. Most often used for building molds (tooling). Unfilled (neat) resin contains more styrene (e.g., 45%). Filled resins cannot comply based on the HAP content of the filled resin: Must use MACT model point values. Fraction of styrene emitted is higher than unfilled resin of same HAP content. What are Filled Resins?

62. Standards for Filled Resins Production resin: 46 kg HAP/Mg filled resin applied. Tooling resin: 54 kg HAP/Mg filled resin applied.

63. Calculating the MACT Model Point Value for a Filled Resin

64. Example: Is this filled tooling resin in compliance? (Limit = 54 kg/Mg) The resin has a HAP content of 46 percent. The resin is mixed 40 percent by weight with filler and applied with a flow coater.

65. Step 1: Determine the MACT model point value for the unfilled resin

66. Step 2: Calculate PVF PVF = 84.9 kg/Mg x (100 - 40% filler)/100 = 50.9 kg/Mg PVF is less than 54 kg/Mg. This filled resin is in compliance.

67. Example: Using Filled Resins in Emissions Averaging

68. Step 1: Calculate the Emission Limit HAP limit = 46(MR) + 159(MPG) + 291(MCG) + 54(MTR) + 214(MTG) HAP limit = 46(90+10) + 159(30) + 291(0) + 54(10) + 214(0) = 9,910 kg HAP

69. Step 2: Determine HAP Emissions (kg/yr)

70. Step 3: Compare the HAP Emissions to the HAP Limit HAP emissions = 9,560 kg HAP limit = 9,910 kg The operations included in the average are in compliance for this 12-month period.

71. Records Needed if Using Filled Resins HAP content of the neat (unfilled) resin. Amount of resin and filler used. Calculations demonstrating compliance based on the MACT model point value of the as-applied filled resin.

72. Using an Add-on Control Device Conduct a performance test. Conditions must represent maximum potential to emit. Measure total HAP emissions. Calculate the emission limit for the materials applied during test. Monitor operating parameters for the emission capture and control system. Establish operating limits for the capture and control system.

73. Using an Add-on Control Device (Continued) Continuously monitor operating parameters for compliance with operating limits. Submit semi-annual monitoring and compliance reports. Complete a startup, shutdown, and malfunction plan; submit SSM reports, if needed. Repeat performance test every 5 years with operating permit renewal.

74. Add-On Capture and Control System Testing Use EPA Method 25 to measure THC as a surrogate for HAP emissions or EPA Method 18 to measure HAP. Is the emission capture system a permanent total enclosure (per EPA Method 204)? YES: measure emissions at the stack only. NO: measure stack emissions and also fugitive emissions using a building or temporary total enclosure to capture fugitives.

75. Operating Limits for Add-On Emission Capture and Control Systems Thermal oxidizers: average combustion temperature during test. Permanent total enclosure: Face velocity of openings: 200 fpm into the enclosure. OR Pressure drop across openings: 0.007 in. H20 Capture systems that are not permanent total enclosures: Duct volumetric flow rate or static pressure during test. OR Pressure drop across openings during test.

76. Standards for Resin and Gel Coat Mixing Operations Applies to containers 55 gallons (208 liters) or larger. Must have a cover with no visible gaps in place at all times, except when: Manually adding or removing material. Inserting or removing pumping or mixing equipment. Inspect covers monthly. Keep records: Which containers are subject. Results of the inspections and any repairs made.

77. Standards for Resin and Gel Coat Application Equipment Cleaning Operations Routine flushing and cleaning solvents: 5 percent HAP content limit. Removing cured resin and gel coat: no HAP content limit. Containers for HAP solvents 2 gallons or larger must have: A tightly fitting cover; and A Afreeboard ratio@ of at least 0.75.

78. What is “freeboard ratio”?

79. Demonstrating Compliance: Resin and Gel Coat Equipment Cleaning Operations Routine flushing and cleaning solvents: record the HAP content. HAP solvent containers: Monthly inspections of the covers. Record the inspection results and any repairs made to covers.

80. SECTION 4.0 - REQUIREMENTS FOR CARPET AND FABRIC ADHESIVE OPERATIONS Emission limit: 5.0 percent organic HAP by weight for each adhesive. Applies to both fiberglass and aluminum boat manufacturers. Does not apply to materials in hand-held aerosol cans. Record needed: HAP content of each carpet and fabric adhesive.

81. SECTION 5.0 - ALUMINUM RECREATIONAL BOAT SURFACE COATING OPERATIONS Emission Limits (units are kg HAP per liter coating solids): Compliance is based on a 12-month rolling average.

82. Exemptions from Aluminum Boat Surface Coating Limits

83. Aluminum Coating Spray Gun Cleaning Operations Comply with one of the following: Limit gun cleaning solvents to 5 percent HAP. Use an enclosed spray gun cleaner. Disassemble the gun and clean the parts in a vat. Force solvent through the gun without atomizing air and direct the solvent into a container.

84. Compliance Steps for Aluminum Coatings 1. Calculate kg HAP in wipedown solvents and coatings. 2. Calculate the liter of solids from the coatings. 3. Calculate the emission rates from solvents and coatings as kg HAP per liter coating solids.

85. Example: Calculate the emission rate for the wipedown solvents. 

86. Step 1: Calculate the kg of HAP in the wipedown solvents

87. Step 2: Calculate the liters of solids contained in the coatings

88. Step 3: Calculate the wipedown solvent emission rate 590 kg HAP ÷ 2,175 liters of coating solids = 0.27 kg HAP/liter coating solids Facility is in compliance with wipedown solvent limit of 0.33 kg HAP/liter coating solids

89. Example: Calculate the Emission Rate for the Coatings 

90. Step 1: Calculate the kg of HAP contained in the coatings and additives

91. Step 2: Calculate the liter of solids contained in the coatings

92. Step 3: Calculate the coatings emission rate 2,532 kg HAP ÷ 2,175 liters of coating solids = 1.16 kg HAP/liter coating solids Facility is in compliance with aluminum coating limit of 1.22 kg HAP/liter coating solids

93. Combined Rate = Solvent Rate + Coating Rate Example: Solvent rate: 0.40 kg HAP/liter coating solids Coating rate: 1.05 kg HAP/liter coating solids Combined rate = 0.40 + 1.05 = 1.45 kg HAP/liter coating solids Facility is in compliance with combined limit of 1.55 kg HAP/liter coating solid.

94. Recordkeeping for Aluminum Coating Operations Consumption (volume) of each wipedown solvent and coating. Organic HAP content of each wipedown solvent and coating. Solids content (by volume) of each coating. Density of each wipedown solvent and coating. Monthly compliance calculations based on the previous 12 months of data.

95. SECTION 6.0 - DETERMINING HAP CONTENT OF REGULATED MATERIALS Use an EPA-approved method. OR Rely on MSDS or other HAP-content documentation. Compliance determinations: EPA-approved methods prevail over MSDS, etc. Use upper limit of reported HAP ranges. 2.0% allowance for EPA methods vs. MSDS, etc.

96. EPA-Approved Methods for Resin and Gel Coat Materials EPA Method 311: HAP Analysis in Paints and Coatings by Gas Chromatograph. ASTM D1259-85: Standard Test Method for Non-volatile Content of Resins Assume that the volatile fraction is HAP.

97. EPA-Approved Methods for Aluminum Boat Surface Coating Operations EPA Method 311: HAP Analysis in Paints and Coatings by Gas Chromatograph. EPA Method 24: Determines VOC and water content in surface coatings. Assume that the non-aqueous volatile fraction is HAP.

98. Determining the Solids Content by Volume of Aluminum Boat Surface Coatings ASTM Methods D2697-86(1998) or D6093-97. Information from the supplier or manufacturer of the coating. Calculating the volume solids from the volume and density of volatiles.

99. Calculating the Volume Solids From the Volume and Density of Volatiles Solids = 1 - (mvolatiles ÷ Davg) mvolatiles = total mass of volatile compounds (including water), from EPA Method 24. Davg = average density of volatiles (including water), from ASTM Method D1475-90, the supplier, or solvent references.

100. Which HAP Must Be Included in HAP Totals? All carcinogenic HAP present at 0.1 percent or more. All non-carcinogenic HAP present at 1.0 percent or more.

101. Which HAP are Carcinogens? Defined by OSHA at 29 CFR 1910.1200(d)(4) using the following: National Toxicology Program, Annual Report on Carcinogens (http://ntp-server.niehs.nih.gov/htdocs/8_RoC/Known_list.html) International Agency for Research on Cancer Monographs (http://monographs.iarc.fr/) OSHA Occupational Safety and Health Standards (29 CFR part 1910, subpart Z, section 1910.1003) (http://www.gpo.gov/nara/cfr/index.html)

102. Determining HAP Content for Solvent Blends Table 5 of subpart VVVV: solvent blends with matching CAS number. Table 6 of subpart VVVV: aliphatic and aromatic solvent blends without CAS numbers. EPA-approved methods prevail over HAP content from solvent blend tables.

103. SECTION 7.0 - COMPLIANCE REPORTING REQUIREMENTS Semi-annual compliance reports required for all sources subject to the rule. Each report includes the six 12-month averages calculated for that period (if applicable). Each report is due 60 days after the end of the calendar half.

104. Compliance Reporting Timeline

105. Contents of the Compliance Reports Company name and address. Responsible company official=s certification. Date of the report and beginning and ending dates of the reporting period. Any changes to the manufacturing process since the last compliance report.

106. Contents of the Compliance Reports (Continued) A summary of applicable requirements and the emission level achieved: Compliant material HAP contents. Weighted average HAP content (each 12-month period) Emissions average HAP limit and HAP emissions (each 12-month period) A statement of whether you were in compliance. A description of any deviations, the source affected, and corrective actions.

107. SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL PROVISIONS 40 CFR 63 Subpart A - General Provisions A framework for standards and other requirements under Section 112 of the Clean Air Act. Eliminates repetition of information and requirements applicable to all NESHAP.

108. SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL PROVISIONS (Continued) Includes the following sections, among others: Applicability Definitions Compliance dates Construction and reconstruction Performance testing Monitoring Notifications Recordkeeping and reporting State authority and delegation

109. SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL PROVISIONS (Continued) Individual rules may over-ride specific requirements in the General Provisions. Table 8 to subpart VVVV lists: Which requirements of the General Provisions apply. Which are over-ridden. Which are addressed more specifically in the rule.

110. Example: Applicability of General Provisions

111. SECTION 9.0 - RELATIONSHIP TO OTHER RULES Reinforced plastic composites NESHAP Proposed August 2, 2001. Shipbuilding and repair (surface coating) NESHAP: Does not apply to recreational vessels (pleasure craft).

112. RELATIONSHIP TO OTHER RULES (Continued) Wood furniture manufacturing NESHAP: Boat manufacturers are not covered. Plastic parts and products surface coating NESHAP: Under development. Miscellaneous metal parts surface coating NESHAP: Under development.

113. SECTION 10.0 - PERMITTING

114. SECTION 11.0 - Where can I find additional information about this rule? For applicability and rule determinations, contact your State or local agency. EPA Regional Office contacts (Attachment C). For other information, contact Mark Morris (919) 541-5416 or morris.mark.@epamail.epa.gov.

115. Resources on the Web EPA Air Toxics Website - Boat Manufacturing NESHAP site www.epa.gov/ttn/atw/boat/boatpg.html#IMP EPA National Compliance Assistance Clearing house http://cfpub1.epa.gov/clearinghouse/ National Marine Manufacturers Association http:/www.nmma.org/index.asp?bhcp=1 Professional Boatbuilder www.proboat.com