# Presentation: 033982

## Boat Manufacturing National Emission Standards for Hazardous Air Pollutants

- October 4 , 2001

## General Information

- Proposed on July 14, 2000 (65 FR 43842)
- Final rule signed by Administrator on 8/14/2001.
- Can be found on Federal Register website at http://www.access.gpo.gov/nara/ or at http://www.epa.gov/ttn/caaa/t3pfpr.html
- For information on applicability and rule determinations, contact the appropriate State or local agency representative
- For other information, contact Mark Morris at (919) 541-5416 or morris.mark@epa.gov

## The Boat Rule Applies if:

- You manufacture hulls or decks of boats from fiberglass or aluminum, or assemble boats from premanufactured hulls and decks, or build molds to make fiberglass hulls or decks
- You have the potential to emit 10 tons per year of one hazardous air pollutant (HAP) or 25 tons per year of a combination of HAP (i.e., you are a "major source")

## What Parts of a Boat Facility Are Covered?

- Open molding resin and gel coat operations (including pigmented gel coat, clear gel coat, production resin, tooling gel coat, and tooling resin)
- Closed molding resin operations
- Resin and gel coat mixing and application equipment cleaning operations
- Carpet and fabric adhesive operations
- Aluminum hull and deck coating operations

## What Parts of a Boat Facility Are Not Covered?

- Aluminum coating operations on aluminum boats intended for nonrecreational use
- Antifoulant coatings
- Assembly adhesives
- Fiberglass hull and deck coatings
- Research and development activities
- Mold sealing and release agents
- Mold stripping and cleaning solvents
- Wood coatings

## Compliance Dates

- For existing sources:  Approximately 9/2004
- For new sources:  Upon startup

## Standard for Open Molding Operations

- <date/time>

- Allowable HAP = 46(MR) + 159(MPG) + 291(MCG) 			+54(MTR) + 214(MTG)
- Where the numbers (46, 159, etc.) are "point values," M is mass of material, and the subscripts are:
- 		R  -  Production Resin
- 		PG-  Pigmented Gelcoat
- 		CG-  Clear Gelcoat
- 		TR-  Tooling Resin
- 		TG- Tooling Gelcoat

## Open Molding Compliance Options

- Compliant materials
- may average over rolling 12-month period
- Emissions averaging
- using point values
- Add-on control device

## Compliant Materials

| Operation | Application Method | Organic HAP Content (weight %) |
| --- | --- | --- |
| Production Resin | Atomized | 28 |
|  | Nonatomized | 35 |
| Pigmented Gelcoat | Any Method | 33 |
| Clear Gelcoat | Any Method | 48 |
| Tooling Resin | Atomized | 30 |
|  | Nonatomized | 39 |
| Tooling Gelcoat | Any Method | 40 |

## Compliant Materials

- If you always use materials meeting the limits in the table above, you only need to keep track of HAP content and application method
- If you use materials of varying HAP content, you would show compliance on a 12-month rolling average
- You need to keep track of HAP content, application method, mass of material used, and perform the rolling average calculations

## Emissions Averaging

- If you can’t meet a limit in the table above for a material, then you can compensate for that by going below the limit(s) for other material(s)
- Use point values
- Point values are a way to compare the emissions of different materials and different application methods
- Plug in organic HAP content into a formula to get a point value
- Point values have units of mass of HAP per mass of resin or gelcoat (kilogram HAP/megagram material)

## Emissions Averaging

- Point value example:
- Production resin with 35% organic HAP applied with a flowcoater
- Point value equation for this scenario is:
- 	0.014 x (HAP%)2.275
- So, 0.014 x (35)2.275 = 46

## Emissions Averaging

- "Actual" HAP = (PVR)(MR) + (PVPG)(MPG) + (PVCG)(MCG) + (PVTR)(MTR) + (PVTG)(MTG)
- Where the point values are calculated as above, M is mass of material, and the subscripts are:
- 		R  -  Production Resin
- 		PG-  Pigmented Gelcoat
- 		CG-  Clear Gelcoat
- 		TR-  Tooling Resin
- 		TG- Tooling Gelcoat

## Other Fiberglass Provisions

- Closed molding: no further reductions required
- Mixing containers (larger than 55 gallons) have to be covered
- Application equipment cleaning solvents must have less than 5% organic HAP
- Carpet and fabric adhesives must have less than 5% organic HAP

## Aluminum Coating Operations

- Emission limits:
- Wipedown solvents: 0.33 kilograms of organic HAP per liter of total coating solids applied
- Coatings: 1.22 kilograms of organic HAP per liter of total coating solids applied
- Can also meet a combined limit of 1.55 kg/l instead of the individual limits above

## Aluminum Boat Operations:Other Provisions

- Spray gun cleaning work practices
- Carpet and fabric adhesives must have less than 5% organic HAP

## Changes Since Proposal

- Research and development operations not covered
- Exemption for 100% vinylester skincoats
- Still have to be applied with nonatomized technology
- No more than 5% of total resin usage
- 12-month rolling average instead of 3-month rolling average