UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: April 5, 2016

SUBJECT: Technical Support Document

– Control of Volatile Organic Compound Emissions

from Fiberglass Boat Manufacturing Mater ials

/s/

FROM: Irene Shandruk, Physical Scientist

Office of Air Program Planning

TO: File

/s/

THRU: Cristina Fernandez , Associate Director

Office of Air Program Planning

A. BACKGROUND

S ection 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs)

for nonattainment areas must include reasonably available control measures (RACM), including reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) provides that for certain n onattainment areas, States must revise their SIPs to include RACT for

sources of volatile organic compound ( VOC ) emissions covered by a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of

attainment.

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and eco nomic feas i bility.” (44
FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA has addressed how

states can mee t the RACT requirements of the CAA

.

CTG s are intended to provide state and local air pollution control authorities information that should assist them in determining RACT for VOCs from various sources fiberglass boat manufacturing materials

. In developing CTGs, EPA, among other things, evaluated the sources of VOC emissions from this industry and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recomm endations for RACT for VOCs from various industry categories, including fibergl ass boat manufacturing

.2

EPA has not publi shed a previous CTG for fiberglass boat manufacturing materials, but did publish an assessment of VOC emissions from fiberglass boat manufacturing in 1990. The 1990 assessment defined the nature and scope of VOC emissions from fiberglass boat manufacturin g, characterized the industry, estimated per plant and national VOC emissions, and identified and evaluated potential control options. In 2001, EPA promulgated the National Emission Standards

for Hazardous Air Pollutants for Boat Manufacturing, 40 CFR par t 63, subpart VVVV (2001 NESHAP). The 2001 NESHAP established organic hazardous air pollutant (HAP) emissions

limits based on low

- HAP resins and gel coats and low

- emitting resin application technology. Several of the air pollution control districts in Ca lifornia have specific regulations that control VOC emissions from fiberglass boat manufacturing operations, as part of their regulations for limiting VOC emissions from polyester resin operations. Several other states also have regulations that address V OC emissions from fiberglass boat manufacturing as part of polyester resin operations . After reviewing the 1990 VOC assessment, the 2001 NESHAP, and existing

California district and other State VOC emission reduction approaches, and after considering

info rmation obtained since the issuance of the 20 01 NESHAP, EPA deve loped a CTG entitled Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (Publication No.

EPA 453/R

- 0 8

- 004 ; September 2008 ).

Description of Fiberglass Boat Manufacturing Materials

Th e CTG for fiberglass boat manufacturing materials provides control recommendations for reducing VOC emissions from the use of gel coats, resins, and materials used to clean application equipment in fiberglass boat manufacturing operations. T his CTG applies to

facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks (hereinafter referred to as “fiberglass boat manufacturing

facilities” ). R ecommendations in this CTG do not exten d t o facilities that manufacture solely parts of boats (such as hatches, seats, or lockers), or boat trailers, but do not manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks. If a facility

manufacture s hulls or decks, or molds for hulls or decks, then the manufacture of all other fiberglass boat parts, including small parts such as hatches, sea ts, and lockers is also covered.

EPA recommend s that the c ontrol approaches discussed in s ection VI of this C TG apply to each fiberglass boat manufacturing facility where the total actual VOC emissions from all fiberglass boat manufacturing operations covered by the recommendations in s ection VI of this CTG are equal to or exceed 6.8 kg/day (15 lb/day). An alter native equivalent threshold would be 2.7 to ns per 12

- month rolling period. Cleaning materials should be included in determining whether total

actual VOC emissions exceed this level. If a facility has add

- on controls, then emissions before

the add

- on cont rols should be used in determining if a facility meets this threshold.

EPA’s Recommended Control Options for Fiberglass Boat Manufacturing Materials

EPA’s 2008 CTG recommends that the following operations are covered: • Open molding resin and gel coat op erations (these include pigmented gel coat, clear gel coat, production resin, tooling gel coat, and tooling resin); • Resin and gel coat mixing operations; and • Resin and gel coat application equipment cleaning operations.3

EPA’s 2008 CTG recommends th e following VOC reduction measures: VOC emission limits

for molding resins and gel coats ; work practices for r esin and gel coat mixing containers ; and

VOC c ontent and vapor p ressure limits for c leaning m aterials

. Recommended VOC emission

limits for open molding resin and gel coat operations are shown in Table 1

.

Table 1 : Monomer VOC Content Limitations for Open Molding Resin and Gel Coat Operations

Materials Application Method Individual Monomer VOC

Content or Weight Average

Monomer VOC Content Limit (w eight percent)

Production Resin Atomized (spray) 28

Production Resin Nonatomized 35 Pigmented Gel Coat Any Method 33

Clear Gel Coat Any Method 48 Tooling Resin Atomized 30 Tooling Resin Nonatomized 39 Tooling Gel Coat Any Method 40

Alternatively, the applicable recommended limits in Table 1 above would be considered met if all materials of a certain type meet the applicable monomer VOC content limit for a specific application method on a weighted

- average basis, and each resin and gel coat did not c ontain more than 5 percent non

- monomer VOC. The weighted

- average monomer VOC content would

be determined based on a 12

- month rolling average. A facility would use Equation 1 found on p. 27 of Control Techniques Guidelines for Fiberglass Boat Manufacturi ng Materials (Publication No. EPA 453/R

- 08

- 004; September 2008 ) to determine weighted

- average monomer VOC content for a particular open molding resin or gel coat material.

Under the emissions averaging option, monomer VOC emissions from the open molding r esin and gel coat operations that a facility chooses to include in this emission average option would meet a facility

- specific monomer VOC mass emission limit (12

- month rolling average) that is determined using Equation 2 found on p. 28 of Control Techniqu es Guidelines for Fiberglass Boat Manufacturing Materials (Publication No. EPA 453/R

- 08

- 004; September 2008 )

. All resins and gel coats included in this option would also need to meet the recommended non

monomer VOC content limit of 5 percent.

The CTG rec ommend s that the emissions average be calculated on a 12

- month rolling average basis and determined at the end of every month (12 times per year). It further recommend s that

at the end of the first 12

- month averaging period and at the end of every subsequ ent month, a facility use Equation 3 found on p. 29 of Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (Publication No. EPA 453/R

- 08

- 004; September 2008 ) to show that the

monomer VOC emissions from the operations included in the a verage do not exceed the

emission limit calculated using Equation 2 for the same 12

- month period.

The formulas in Table 4 found on p. 30 of Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (Publication No. EPA 453/R

- 08

- 004; Septem ber 2008 ) calculate monomer VOC emission rates in kilograms of monomer VOC per megagram of resin or gel coat applied. The formulas for vacuum bagging with roll

- out are applicable when a facility rolls out4

the applied resin and fabric prior to applying the vacuum bagging materials. The formulas for vacuum bagging without roll

- out are applicable when a facility applies the vacuum bagging

materials immediately after resin application without rolling out the resin and fabric. VOC% = monomer VOC content as sup plied, expressed as a weight

- percent value between 0 and 100

percent.

If product performance requirements or other needs dictate the use of higher monomer

VOC materials than those that would meet the recommended emission limits in Table 1, a facility coul d choose to use add

- on control equipment to meet the emission limit

. However, instead of using the mass of each material used over the past 12 months in Equation 2, the facility would use the mass of each material used during the control device performance test in Equation 2 to determine the emission limit (in kg of monomer VOC) that is applicable during the

test

. If the measured emissions at the outlet of the control device (in kg of monomer VOC) are

less than the emission limit, then the facility would b e considered to have achieved the emission

limit.

Some facilities use resins to which fillers are added to achieve certain physical properties, particularly for building molds. The resins to which the filler is added have higher initial

monomer VOC conten t than standard production or tooling resins, but the addition of the filler

lowers the monomer VOC emiss ion rate from the filled resin. The CTG recommend s the use of Equation 5 found on p. 32 of Control Techniques Guidelines for Fiberglass Boat Manufactu ring

Materials (Publication No. EPA 453/R

- 08

- 004; September 2008 ) to adjust the emission rate for

filled resins under all three options recommended above for limiting monomer VOC emissions

from resins and gel coats. If a facility is using a filled product ion resin or filled tooling resin, it

w ould calculate the emission rate for the filled material on an as

- applied basis using Equation 5.

B. STATE SUBMITTAL

On March 2, 2016 , Pennsylvania Department of Environmental Protection (PADEP) submitted

to EPA a SIP revision concerning implementation of RACT requirements for the control of VOC emissions from fiberglass boat manufacturing materials. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt mo re restrictive

standards. Pennsylvania is adopting EPA’s CTG standards for fiberglass boat manufacturing

materials , including the emission limits found in Table 1 as well as all alternative options for calculating emissions discussed earlier in this Techn ical Support Document as well as in the

CTG itself

. The regulation is contained in 25 Pa. Code Chapter 129 (relating to standards for sources), and this SIP revision adds section 129.74 (control of VOC emissions from fiberglass boat manufacturing material s) to the Pennsylvania SIP

. In addition to adopting the CTG

standards discussed above, section 129.74 includes numerous terms and definitions to support the interpretation of the measures , as well as work practices for cleaning; compliance and monitoring requirements; sampling and testing; and record keeping requirements (all included in

section 129.74 of the Pa. Code )

This SIP revision also notes that the requirements of section 129.74 supersede the requirements of a RACT permit issued under sections 129 .91

- 129.95 prior to December 19, 2015 to the owner or operator of a source subject to section 129.74 to control, reduce, or minimize VOCs from a5

fiberglass boat manufacturing process, except to the extent the RACT permit contains more stringent requirement s

.

C. EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Pennsylvania has adopted all of the standards and requirements of the fiberglass boat manufacturing materials CTG and is revising the Pennsylvania SIP to reflect this addition

. Thus,

the SIP revision is approvable pursuant to sections 172(c)(1) and 182(b)(2) of the CAA. The SIP revision will reduce emissions of VOCs from fiberglass boat manufacturing operations. The

maximum benefit from th is addition will be provided during the ozone season when VOC s readily combine with NO
x to form ground

- level ozone. Therefore, this revision will help Pennsylvania attain and maintain the NAAQS for ozone

. EPA approval of the SIP revision is

recommended.