p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

67) 11-1-67 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:23 PM Sheet 67 of 114 
P.2 

A.94.5'. 

11-'B- 6 7 

Baseline 

of Emissions 

Fiberglass Boat 

mmmm, 

mgmmjm-i 
P.3 

BASELINE CHARACTERIZATION OF EMISSIONS 

FROM FIBERGLASS BOAT MANUFACTURING 

FOR 

NATIONAL MARINE MANUFACTURERS ASSOCIATION 

Prepared for 

National Marine Manufacturers Association 

3050 K Street, N.W., Suite 145 

Washington, D.C. 20007 

Prepared by 

Stelling Engineering, P.A. 

1319 Arnette Avenue 

Durham, North Carolina 27707 

Air-Tech Environmental LLC 

P.O. Box 12353 

Research Triangle Park, North Carolina 27709 

Radian International LLC 

P.O. Box 13000 

Research Triangle Park, North Carolina 27709 

August 1997 

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/VMMA 

J&4&iBF4&' Base-line Emission THS t tnp, 

Table of Contents 

Page 

1.0 INTRODUCTION 1-1 

1.1 Background 1-2 

1.2 Purpose of Testing 1-3 

1.3 Testing 1-3 

1.3.1 Test Enclosure 1-4 

1.3.2 Process 1-5 

1.3.3 Sampling Methods and Procedures 1-7 

1.3.4 Molds 1-8 

1.3.5 Materials 1-9 

1.3.6 Schedule ....1-10 

1.4 Organization of the Report 1-10 

2.0 RESULTS 2-1 

2.1 Summary of Results 2.-1 

2.2 Evaluation of Emissions from Continuing Trace Concentrations 2-6 

2.3 CFA Mold Results .....2-10 

2.4 Results of Gelcoat Application Testing 2-13 

2.5 Results of Resin Lamination Testing 2-16 

2.5.1 Emissions as Percent of Available Styrene 2-17 

2.5.2 Flux Emissions ....2-20 

2.5.3 Normalized Emissions 2-21 

3.0 CALIBRATION AND SAMPLING PROCEDURES 3-1 

3.1 Process Procedures and Measurements 3-2 

3.1.1 Application Procedures 3-3 

3.1.2 Spray Equipment Calibration 3-4 

3.1.3 Gel Time 3-5 

3.1.4 Styrene and Methyl Methacrylate Content 3-6 

3.2 Emission Testing Equipment and Procedures 3-7 

iii Kov. 1 

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mm/T 

Baseline Emission Testing 

Table of Contents (Continued) 

Page 

3.2.1 Leak Check and Instrument Calibration 3-7 

3.2.1.1 Total Hydrocarbon Analyzer 3-8 

3.2.1.2 Gas Chromatograph 3-10 

3.2.2 Flow Rate Measurements 3-11 

3.2.3 Temperature 3-12 

3.2.4 Weight of Material Used 3-12 

3.3 Air Flow Over the Mold 3-13 

3.4 Mass Balance Styrene Recover}7 Check ...3-15 

3.5 Data Custody..... 3-16 

4.0 QUALITY CONTROL AND QUALITY ASSURANCE 4-1 

4.1 Concentration Measurements 4-1 

4.1.1 Total Hydrocarbon Measurements (Method 25A) 4-2 

4.1.2 Organic Compound Concentrations (Method 18) 4-6 

4.1.3 Comparison of Methods in Determining Emissions 4-12 

4.2 Gelcoat and Resin Flow Rate 4-14 

4.3 Air Velocity over Mold Surface 4-15 

4.4 Exhaust Flow Rate 4-15 

4.5 Exhaust Air Temperature 4-17 

4.6 Resin/Gelcoat Balance 4-17 

4.7 Technical Systems Audit 4-18 

4.7.1 Total Hvdrocarbon Measurement 4-19 

4.7.2 Weigh Cell Balance 4-20 

4.7.3 Flow Measurement , 4-22 

4.7.4 Styrene Evaporation Test 4-22 

iv IM'V. I 
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Baseline Emission Testinp, 

Table of Contents (Continued) 

APPENDICES 

APPENDIX A 

APPENDIX B 

APPENDIX C 

APPENDIX D 

APPENDIX E 

APPENDIX F 

APPENDLX G 

APPENDIX H 

APPENDIX I 

Reference Methods 

Construction of a Temporary Total Enclosure for Volatile Organic 

Compound Emission Assessment During Manufacture of Fiberglass 

Boats 

Calculations 

Procedure for and Results of Gel Time Determination 

Material Safety Data Sheets 

Certifications for Gas Standards and Equipment Calibrations 

Bag Standards 

Location and Results of Air Flow Over the Mold Measurements 

Comparison of NMMA Results with Those from Other Studies 

Rev. i 

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P.7 

NMMA „ , _ 

JS^tWaWatW Baseline Emission Testing 

LIST OF TABLES 

Page 

1-1 Parameters Studied 1-8 

1-2 Surface Areas of Molds Used in Test Program 1-9 

1-3 Properties of Gelcoat and Resin Materials 1-10 

1-4 Test Schedule 1-11 

2-1 Summary of Test Results 2-2 

2-2 Emissions Measured During Application of Resin to CFA Mold 2-11 

2-3 Emissions from Gelcoating as Percentage of Available Volatiles 2-14 

2-4 Total Emissions from Gelcoating Related to Mold Surface Area 2-15 

2-5 Emissions Measured During Resin Lamination 2-17 

3-1 Measurements During Test Program 3-1 

3-2 Gel Time Results 3-6 

3-3 Styrene and MMA Contents 3-6 

4-1 Acceptance Criteria for Concentration Measurements 4-2 

4-2 Calibration Error Measurements for Total Hydrocarbon Analyzer 4-3 

4-3 Calibration Drift Measurements for Total Hydrocarbon Analyzer 4-4 

4-4 Specific Compound Response Factors for the Total Hydrocarbon Analyzer 4-5 

4-5 Method 18 Response Factors for Target Compounds 4-7 

4-6 Gas Chromatography Calibrations (after April 12) 4-10 

4-7 Comparison of Emission Results by Two Methods 4-12 

v i Rev. 1 
P.8 

NMMA 

JSKktyWaW Baseline Emission Testinp, 

LIST OF TABLES (continued) 

Page 

4-8 Spray Equipment Data Summary 4-14 

4-9 Variability Measures for Flow Rate During Test Runs 4-16 

4-10 Results of Balance Calibration 4-18 

4-11 Audit Results for Method 25A Measurements 4-19 

4-12 Results of Audit of Balance 4-21 

4-13 Results of Flow Rate Audit ....4-22 

4-14 Results of Styrene Evaporation Tests 4-23 

vii Rev. 1 

'1 
P.9 

NMMA „ , r 

Baseline Emission Testing 

LIST OF FIGURES 

Page 

2-1 Summary Concentration Traces for Boat Lamination and Gelcoating 2-3 

2-2 Emissions as Percentage of Available Monomer 2-7 

2-3 Total Hydrocarbon Concentration Trace for NMMA-4-1 2-8 

2-4 Concentration v. Cumulative Mass Emissions (NMMA-4-1) 2-9 

2-5 Emissions from Lamination and Gelcoating of the CFA Mold 2-12 

2-6 Gelcoat Emissions as Percent of Available Volatiles 2-14 

2-7 Emissions from Gelcoating Related to Mold Surface Area 2-16 

2-8 Emissions from Lamination as Function of Available Styrene 2-18 

2-9 Comparison of Results by Test 2-19 

2-10 Emissions from Resin Lamination as Flux Measurement 2-20 

2-11 Average Emission Flux Measurements for Two Resins 2-21 

2-12 Normalized Emissions from Resin Lamination 2-22 

4-1 Method 18 Response Factors for Styrene 4-6 

4-2 Method 18 Response Factors for Methyl Methacrylate 4-7 

4-3 Method 18 Response Factors for Selected Test Days 4-8 

4-4 Comparison of Total Hydrocarbon Traces by Two Methods 4-13 

viii Rev. 1 
P.10 

/VMMA 

Baseline Emission Testinp, 

ACKNOWLEDGEMENTS 

The authors gratefully acknowledge U.S. Marine for the use of their facility in Arlington, 

Washington, for this program. They provided space, an outstanding facility for the 

program, an excellent enclosure (designed and constructed by U.S. Marine), and 

outstanding support by their personnel. We wish to specifically recognize the following 

people for their help in making the field work in Arlington such a success: 

Dennis Pearson, who, as our U.S. Marine site coordinator, provided constant oversight and 

help in scheduling space, personnel, molds, and materials; Dennis also spearheaded the 

design and fabrication of the temporary total enclosure, which exceeded all expectations 

for a test enclosure of its size; 

Larry* Dargitz, U.S. Marine's lead lamination training specialist, who conducted the boat 

lamination work during this program; 

Ken Warren, U.S. Marine gelcoating specialist, who conducted all gelcoating runs during 

the program; and 

Don Barnhill, who extended the invitation and ensured daily that the program had 

everything needed. 

We wish to express appreciation to Research Triangle Institute and the U.S. Environmental 

Protection Agency for funding the supplemental testing of flow chopper technology. We 

also appreciate the support of this program by the EPA through its audit of our technical 

systems. 

Finally, we wish to thank John McKnight, the NMMA Project Manager, for his continued 

support of this testing program before, during, and after the field work. 

ix R<-v. 1 
P.11 

NMMA 

Baseline Emission Testing 

1.0 INTRODUCTION 

Under contract to the National Marine Manufacturers Association 

(NMMA), Stelling Engineering, Air-Tech Environmental, and Radian 

International conducted testing in April 1997 to characterize baseline emissions 

from gelcoating and lamination of fiberglass boats. Testing was conducted in 

accordance with the QuaUty Assurance Project Plan for the National Marine 

Manufacturers Association Baseline Emissions Testing Project (QAPP) approved by 

the U.S. Environmental Protection Agency (EPA) in March 1997. A quality 

assurance (QA) audit was performed by the EPA during this program. Visits by 

state regulatory authorities and other interested parties were also made during 

testing. 

The test program was designed to be as representative as possible 

of actual fiberglass boat manufacturing. Testing was conducted at the 

U.S. Marine (Bayliner) fiberglass boat manufacturing, research, and 

development facility in Arlington, Washington, in an enclosure (inside a wooden 

model fabrication area) made available for this purpose. The volatile organic 

compounds (VOC) measured during this program were generated from 

operations identical to those in actual production, that is, using actual boat part 

molds, spray equipment, resins and gelcoat, and laminating procedures and 

techniques typical of the industry. Experienced manufacturing personnel 

conducted the lamination and gelcoating. Only a few runs incorporated a mold 

or spray techniques not typical of the industry; such runs were designed to 

produce data for comparison with previous emission tests. 

During this sampling program, Research Triangle Institute (RTI) 

conducted a research program to ascertain the viability of measuring emissions 

1-1 Rev.l 

0 
P.12 

WMMA 

Baseline Emission Testing 

from lamination and gelcoating operations using a mass balance approach. RTFs 

program was funded by the EPA's Office of Research and Development (ORD) 

and will be reported independently. 

1.1 Background 

Within the past two years, several important sampling and analysis 

programs have sought to determine styrene emissions from open molding of 

polyester resin fabricated parts. Most important among these studies were the 

studies conducted by RTI for the EPA and by Dow Chemical USA for the 

Composite Fabricators Association (CFA). The results from these programs raise 

questions about the emission factors published in the EPA's compendium of 

emission factors, AP-42, especially for molding of large parts manufactured by 

the marine industry. 

Still, none of the tests to date adequately represent industry 

practice or conclusively demonstrate the effect of mold size and styrene content 

of resin on emissions. For example, the results of this test program indicate that 

the relationship between emissions of styrene as percent of available styrene in 

the resin and increasing styrene content does not appear to be constant. Further, 

an increase in mold size resulted in increased flux emissions (pounds styrene per 

square foot of surface area of mold) but decreased normalized emissions 

(pounds styrene per 1000 lb resin per square foot of mold surface area). Also, 

none of the previous tests included gelcoat containing methyl methacrylate 

(MMA), which is common in the boat building industry. 

1-2 Rev.l 

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NMMA 

Baseline Emission Testing 

1.2 Purpose of Testing 

The primary project objective was to characterize total hydrocarbon 

(THC), styrene, and MMA emissions from the open molding process tiiat is 

representative of fiberglass boat manufacturing, specifically spray up gelcoat 

application and resin application. Hand lay-up, defined as the application of 

glass and resin that are mixed manually and applied by brush, was not part of 

this stud)7. A technique comparable to hand lay-up found in the industry is the 

use of a flow chopper, a glass chopper similar to the resin chopper gun but 

equipped with a low-pressure, non-atomized resin delivery system resembling a 

nozzle not unlike a shower head that exudes catalyzed resin. The principal 

difference between this technique and conventional spray up application is that 

resin atomization is avoided. Sampling during lamination using a flow chopper 

was conducted to augment the test matrix planned for this program; this 

supplemental sampling was funded by the EPA through RTI. 

This study was designed to produce data for estimating emissions 

from lamination and gelcoating in fiberglass boat manufacturing plants. The 

data and analyses reported in this document are intended to be useful to plants 

in compiling emission inventories and assessing permit needs or changes. 

1.3 Testing 

Sampling was completed by Darrell Doerle of Air-Tech 

Environmental and John Stelling of Stelling Engineering. Testing was 

coordinated with U.S. Marine personnel by John McKnight, NMMA's project 

manager. Larry Dargitz of U.S. Marine operated the resin application 

1-3 Rev.l 
P.M 

NMMA „ , _ 

Baseline Emission Testing 

equipment, and Ken Warren of U.S. Marine applied gelcoat for those 

experiments. 

Tests were also coordinated with Bob Wright, Emery Kong, and 

Mark Bahner of RTI. RTI conducted a study in an adjacent enclosure under 

contract to the EPA's ORD to measure emissions from the same lamination 

operations as conducted for this program but applied to a small panel. The goal 

of their program was to develop a simplified material balance approach for 

determining emissions from fiberglass lamination. 

1.3.1 Test Enclosure 

The testing was carried out at the U.S. Marine manufacturing and 

research facility in Arlington, Washington. The test area was located in a 

wooden model fabrication area where tool plugs are fabricated. A large test 

enclosure (20 ft by 45 ft by 14 ft) meeting the total temporary enclosure (TTE) 

requirements of EPA Method 204 (included in Appendix A) was erected in this 

27-ft by 50-ft area to accommodate tools (i.e., molds) ranging from 18 to 28 ft in 

length. Sufficient space was provided in the enclosure to allow technicians to 

work around the tool and to move the tool as needed to apply gelcoat and resin. 

A description of the TTE is contained in Appendix B. Natural draft openings 

(NDOs) were arranged in accordance with EPA Method 204. Measurements 

were made to ensure that the air velocity across the mold surface was 

comparable to that measured in the manufacturing area. 

The exhaust system for the entire model preparation room 

comprised a dual pick-up system at one end of the room (near the constructed 

enclosures) exhausting to a single induced draft fan. The fan had 20,000-cfm 

1-4 Rev.l 

/3 
P.15 

NMMA 

Baseline Emission Testing 

capacity, far more than needed to exhaust the two enclosures. At the start of the 

program, some of the pick-ups were closed to develop sufficient draw through 

the enclosures. The flow rate was balanced with both enclosures in use so that 

the turnover through the large enclosure used for NMMA testing was 

comparable to that in the manufacturing areas on site (i.e., about 16 room 

changes per hour). On-site checks in the production area verified this range. 

The enclosure was equipped with two 10-in. plena for exhausting 

the enclosure. Three-inch openings were installed ever)' 3 ft in each plenum and 

covered with spun fiberglass filter media. Air was supplied to the enclosure 

through a 12-in. plenum in the ceiling of the enclosure. This plenum was open 

on both ends, limiting the NDO associated with the inlet air plenum to 1.571 ft2. 

The enclosure was equipped with a door (which remained closed during testing) 

and a zippered end for changing application equipment and molds between 

tests. Thus, the openings on both ends of the inlet air plenum were the only 

NDOs. The openings in this plenum satisfied the requirements of Method 204 for 

a TTE, representing only 0.043 percent of the total surface area of the enclosure. 

Also, considering a flow rate of 2,600 to 3,300 cfm, the velocity at the NDO was 

at least 1,655 ft/min, also satisfying Method 204 requirements. Air coming into 

the enclosure was monitored continuously for hydrocarbon concentration during 

each test run in accordance with Method 204; these data were recorded with 

other continuous monitoring data. 

1.3.2 Process 

The polyester resin spray-up application process commonly used 

in the boat building industry uses a "chopper gun" to apply a laminate. The 

chopper gun dispenses polyester resin, catalyst, and chopped glass fibers. 

1-5 Rev.l 
P.16 

NMMA n , _. 

Baseline Emission Testing 

Continuous strand fiberglass roving is fed to a chopper unit mounted on the 

spray gun and is cut into chopped fiber lengths of approximately 1.5 in. long. 

The chopped fiber is ejected from the chopper unit and is captured by the resin 

fan pattern a short distance from the spray gun. The mixture of the catalyzed 

resin and chopped fiber is deposited on the mold by the spraying action. Typical 

of fiberglass boat manufacture, woven roving (a fabric material) was used with 

resin application by spray gun and flow chopper for the addition of this 

reinforcement. A Venus Gusmer G03 airless air-assisted chopper gun equipped 

with a 5003 tip, typical of guns used in the industry, was used for spray 

application of resin and chopped glass during this program. 

Resin was supplied to the chopper gun and the flow chopper by a 

Venus Gusmer system at a pump ratio of 11 to 1. The methyl ethyl ketone 

peroxide (MEKP)/dimethyl phthalate (DMP) catalyst was internally mixed for 

both chopper gun and flow chopper, with the catalyst delivered by a slave pump 

system.- The flow chopper was also a Venus Gusmer design. The resin is 

delivered at a much lower pressure and no air is used to dispense the resin into 

the chopped glass. The glass is chopped into lengths using the same method as 

in the chopper gun, but because there is no atomizing air, the dispersion pattern 

of glass and resin mixture is more narrow. 

Gelcoat is applied in the boat building industry using a spray gun, 

typically an airless air-assisted spray gun. For this program, gelcoat was 

delivered to the spray gun using a Glas-Craft pump system at a pump ratio of 23 

to 1. Catalyst, delivered using a metered feed pump, was mixed externally. A 

Poly-Craft 775 airless air-assisted spray gun (equipped with a 0.026 tip size) was 

used during this program. 

1-6 Rev.l 

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NMMA 

Baseline Emission Testing 

Spray application was conducted using techniques common to the 

industry. This study was not intended to compare spray techniques. Therefore, 

skilled technicians from a manufacturing line operated the gelcoat and chopper 

guns in all tests, except those included to produce data that could be more 

directly compared to previous tests. 

1.3.3 Sampling Methods and Parameters 

Method 25A, continuous monitoring of THC, was used as the 

primary technique to measure emissions. From the Method 25A results, 

emissions were calculated using the measured THC concentration as propane, 

the molecular weight of propane, and the exhaust gas flow rate measured in 

accordance with Method 2. These results are presented in terms of THC 

emissions (as propane) for lamination or gelcoating. 

Speciation of styrene and MMA emissions (needed during 

gelcoating) was effected through Method 18 analysis using a gas chromatograph 

(GC) with flame ionization detector (FID). Method 18 analysis was conducted 

concurrent with the Method 25A monitoring. The Method 18 results were used 

primarily to establish the ratio of styrene emissions to MMA emissions during 

gelcoating. This ratio allowed partitioning of the THC emission rate (as propane) 

into styrene and MMA components. The Method 18 results were also used as a 

check on the Method 25A results. 

Other measurements made during this program included those 

variables determined from other studies to have more significant influence on 

emissions (Table 1-1). 

1-7 Rev.l 

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NMMA Baseline Emission Testing 

1.3.4 Molds 

Four molds were used in this program, three of which are boat part 

molds in actual use by U.S Marine. Two hull molds represented the typical size 

hulls common to the industry: an 18-ft runabout and a larger 28-ft cruiser. An 

18-ft deck mold for a bow rider model was used to represent a more convexshaped mold. The mold used during Phase I testing by the CFA was included in 

this program to provide data for comparison with the results of that previous 

study. Surface areas of these molds (Table 1-2), determined from engineering 

drawings and in previous studies, were used to calculate flux and normalized 

emissions. 

Table 1-1 . 

Parameters Studied 

•^"•Parameter 

Resin application method 

Tool shape 

Resin stvrene content 

Tool size 

Gel time 

Applied thickness 

Resin density3 

Resin percent non-volatile3 

Resin viscosity" 

Resin peak exotherm" 

Resin thixotropic index3 

Resin flow rate3 

Air flow rate 

Test Variable 

Yes (2) 

Yes (2) 

Yes (2) 

Yes (2) 

No 

No 

No 

No 

No 

No 

No 

No 

No 

Measured/Fixed 

Fixed 

Fixed 

Measured (vendor) 

Fixed 

Measured 

Measured 

Measured (vendor) 

Measured (vendor) 

Measured (vendor) 

Measured (vendor) 

Measured (vendor) 

Measured 

Measured 

1-8 Rev.l 

/7 
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NMMA 

Baseline Emission Testing 

Table 1-2 

Surface Area of Molds Used in Test Program 

^:--jyyy,: Mold; m^jJJJJWJJJy 

18-ft Deck 

18-ft Hull 

28-ft Hull 

CFA Phase I Mold (controlled spray) 

CFA Phase I Mold (uncontrolled spray) 

'£:;;?.£ 

171.09 

220.5 

454 

28.06 

37.28* 

^Uncontrolled spray of this mold inevitably coated flange extensions, effectively increasing the 

surface area of the final laminate structure. 

1.3.5 Materials 

Materials chosen for this program are typical of those used in 

fiberglass boat manufacturing (Table 1-3). Two styrene polyester resins were 

used, one with a nominal 35 percent styrene by weight content and the other 

with a nominal 42 percent styrene by weight content. The gelcoat was a white on 

white gelcoat containing nominally 32 percent styrene and 5 percent MMA. The 

formulations used are considered most representative of the range of resin 

styrene and gelcoat contents in the industry. Based on a survey of industry 

representatives, the marine industry uses gelcoat that contains MMA as an 

inhibitor to degradation by exposure to ultraviolet (UV) light. MEKP in a DMP 

base is the most common catalyst used in the industry for both gelcoat and resin; 

MEKP/DMP was used in this program. 

1-9 Rev.l 

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NMMA Baseline Emission Testing 

Table 1-3 

Properties of Gelcoat and Resin Materials 

Product number 

Manufacturer 

Styrene content, % 

MMA content, % 

Specific gravity 

Thixotropic index 

Viscosity, cps 

MEKP catalyst 

ratio 

Gel time, min 

Gelcoat 

954WP53 

Cook Composites 

and Polymers Co. 

32 

5 

1.32 

5.5 

LVF #4® 6 rpm14500 

2% 

16.5 

Resin 1 

80.654-NMMA 

Alpha/Owens 

Corning 

35.1 

0 

1.082 

4.9 

RVF #2® 20 

rpm-700 

RVF #2® 2 rpm3400 

1.5% 

23.22 

2% 

17.98 

Resin 2 

80.604-NMMA 

Alpha/Owens 

Corning 

42.2 

0 

1.09 

5.71 

RVF #2® 20 rpm700 

RVF #2® 2 rpm4000 

1.5% 

23.48 

2% 

18.70 

1.3.6 Schedule 

Testing was conducted from April 2 to April 19,1997. Set up at the 

site began March 30, continuing to April 1 (Table 1-4). One to three runs were 

made each day. Sampling was coordinated with the U.S. Marine personnel 

supporting the lamination and gelcoating operations and with RTI personnel 

conducting sampling in an adjacent Method 204 enclosure. 

1.4 Organization of the Report 

The complete report including all appendices and separately 

bound field data contains all data from the testing program. The text of the 

report is intended to stand alone to provide the essence of the results from the 

sampling and analysis program. This introduction (Section 1) provides a brief 

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NMMA Baseline Emission Testing 

Table 1-4 

Test Schedule 

Date Test Description Run 

2-Apr 

3-Apr 

3-Apr 

4-Apr 

4-Apr 

5-Apr 

5-Apr 

7-Apr 

8-Apr 

8-Apr 

8-Apr 

9-Apr 

9-Apr 

9-Apr 

10-Apr 

10-Apr 

10-Apr 

11-Apr 

11-Apr 

11-Apr 

12-Apr 

12-Apr 

12-Apr 

14-Apr 

14-Apr 

15-Apr 

15-Apr 

16-Apr 

16- Apr 

17-Apr 

18-Apr 

18-Apr 

19-Apr 

, NMMA-6-P 

NMMA-8-1 

NMMA-4-1 

NMMA-7-1 

NMMA-3-1 

NMMA-8-2 

NMMA-1-1 

NMMA-7-2 

NMMA-6-1 

NMMA-3-2 

NMMA-4-2 

NMMA-1-2 

NMMA-11-1G 

NMMA-11-1 

NMMA-14-1 

NMMA-13-1 

NMMA-11-2 

NMMA-6-2 

NMMA-14-2 

NMMA-13-2 

NMMA-11-3 

NMMA-5-1 

NMMA-2-1 

NMMA-5-2 

NMMA-2-2 

NMMA-16-1 

NMMA-15-1 

NMMA-16-2 

NMMA-15-2 

NMMA-12-1 

NMMA-9-1 

NMMA-12-2 

NMMA-9-2 

18-ft Deck Gelcoat 

28-ft HuU Gelcoat 

18-ft Deck 35 % Styrene Resin 

28-ft Hull 35 % Styrene Resin 

18-ft Hull Gelcoat 

28-ft HuU Gelcoat 

18-ft Hull 35 % Styrene Resin 

28-ft Hull 35 % Styiene Resin 

18-ft Deck Gelcoat 

18-ft HuU Gelcoat 

18-ft Deck 35 % Styrene Resin 

18-ft HuU 35 % Styrene Resin 

CFA Mold Gelcoat 

CFA Mold 35 % Styrene Resin 

18-ft Deck 35 % Styrene Resin - How Chopper 

18-ft HuU 35 % Styrene Resin - Flow Chopper 

CFA Mold 35 % Styrene Resin 

18-ft Deck Gelcoat 

18-ft Deck 35 % Styrene Resin - How Chopper 

18-ft HuU 35 % Styrene Resin - Flow Chopper 

CFA Mold 35 % Styrene Resin 

18-ft Deck 42 % Styrene Resin 

18-ft HuU 42 % Styrene Resin 

18-ft Deck 42 % Styrene Resin 

18-ft HuU 42 % Styrene Resin 

18-ft Deck 42 % Styrene Resin-Flow Chopper 

18-ft Hull 42 % Styrene Resin-Flow Chopper 

18-ft Deck 42 % Styrene Resin-Flow Chopper 

18-ft HuU 42 % Styrene Resin-Flow Chopper 

CFA Mold 42 % Styrene Resin 

28-ft HuU 42 % Styrene Resin 

CFA Mold 42 % Styrene Resin 

28-ft HuU 42 % Styrene Resin 

0402-01 

0403-01 

0403-02 

0404-01 

0404-02 

0405-01 

0405-02 

0407-01 

0408-01 

0408-02 

0408-03 

0409-01 

0409-02 

0409-03 

0410-01 

0410-02 

0410-03 

0411-01 

0411-02 

0411-03 

0412-01 

0412-02 

0412-03 

0414-01 

0414-02 

04.15-01 

0415-02 

0416-01 

0416-02 

0417-01 

0418-01 

0418-02 

0419-01 

1-11 Rev.l 
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NMMA 

Baseline Emission Testing 

introduction to the purpose of the testing and the schedule for completing the 

on-site activities. The results of the sampling program are presented in Section 2. 

Results are presented in tabular format and graphically to simplify review. 

Section 3 describes the methods used in the sampling program, including those 

used to quantify parameters not varied during the program, such as gel time and 

styrene content. Quality control (QC) measures and QA data are presented in 

Section 4. 

Data and material supporting the test report are contained in the 

appendices, as follows: 

• Reference Methods 

• Construction of a Temporary Total Enclosure for Volatile Organic Compound 

Emission Assessment During Manufacture of Fiberglass Boats 

• Calculations 

• Procedure for and Results of Gel Time Determination 

• Material Safety Data Sheets 

• Certifications for Gas Standards and Equipment Calibrations 

• Bag Standards 

• Location and Results of Air Flow over the Mold Measurements 

• Comparison of NMMA Results with Those from Other Studies 

Copies of all raw data generated by the GC and the THC analyzer, organized by 

day, and including pertinent process data (spray gun calibrations), have been 

bound separately for archive at NMMA offices. 

1-12 Rev.l 

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JkW0^aWatW Baseline Emission Testmg 

2.0 RESULTS 

The results of emission testing at the U.S. Marine site in Arlington, 

Washington, are presented in this section with comparison of the data between 

tests and with the results of the CFA Phase I studies; further comparison of these 

results with other studies is appended. The results are presented in terms of 

emissions as a percent of available compound (i.e., styrene, MMA, and total 

volatiles), as emissions per unit area of mold surface, and as normalized 

emissions, that is, emissions per unit mass of resin per unit area of mold surface. 

All calculations done for these analyses are appended (Appendix C), including a 

sample calculation showing the complete analysis of data from test runs. 

Results demonstrate that the enclosure constructed at the site 

provided good capture of emissions from the molding process and that all 

emissions were accounted for in the sampling. The .styrene evaporation tests 

demonstrated that the emission monitoring system provided a good measure of 

the actual losses. Testing of emissions from lamination of the box mold from the 

Phase 1 CFA studies demonstrated that the techniques used in the two studies 

(i.e., CFA's study and the portion of this study designed to reproduce some of 

the testing done in the CFA study) were comparable. Results of duplicate testing 

for each test case provided good closure, within the acceptance criteria specified 

in the QAPP. In accordance with the plans outlined in the QAPP, all tests of boat 

mold use were completed with only two runs. A third run was done for one of 

the test conditions to incorporate the CFA study mold. 

2.1 Summary of Results 

Table 2-1 presents the average values from the sixteen emission 

tests conducted at U.S. Marine's Arlington, Washington, site. Three of the tests 

-J> ~? 
P.24 

NMMA Baseline Emission Testing 

were conducted using the same box mold used by CFA/Dow during their 

Phase I studies (to provide data for comparison with those studies); all other 

tests were conducted using boat molds and procedures typical of U.S. Marine's 

boat manufacturing processes. The results of this study are taken as 

representative of industry practice. 

The amount of resin used per part during these studies was much 

greater than the amounts used in previous studies (Table 2-1). This relative scale 

of material use and measurement contributed to the consistency of results. 

Table 2-1 

Summary of Test Results 

Description"1 

CFA Gel 

18 Deck Gel 

18 Hull Gel 

28 Hull Gel 

CFA 35R 

18Dcvk35R 

18HuU35R 

28 Hull 35 R 

18 Deck 35R - FCb 

18Hull35R-FC 

CFA 42R 

18 Deck 42R 

18Hull42R 

28 HuU 42R 

18Deck42R-FC 

18Hull42R-FC 

Resin 

Use (lb) 

3.2 

20.0 

25.7 

65.7 

8.1 

124.6 

144.5 

354.4 

114.7 

141.7 

5.1 

111.8 

142.9 

304.2 

122.2 

154.9 

Emissions 

Styrene 

' 41.1% 

42.3% 

46.4% 

50.4% 

41.8% 

12.9% 

14.8% 

17.3% 

11.9% 

10.8% 

48.7% 

21.1% 

20.7% 

23.3% 

13.4% 

11.4% 

as Percent of Available 

MMA 

84.0% 

75.6% 

73.2% 

78.6% 

Volatiles 

46.9% 

46.9% 

50.0% 

54.3% 

41.8% 

12.9% 

14.8% 

17.3% 

11.9% 

10.8% 

48.7% 

21.1% 

20.7% 

23.3% 

13.4% 

11.4% 

Emission 

Flux 

flb/SF) 

0.0203 

0.0228 

0.0261 

0.0389 

0.0345 

0.0130 

0.0143 

0.0234 

0.0092 

0.0072 

0.0324 

0.0284 

0.0272 

0.0357 

0.0125 

0.0089 

Normalized 

Emissions 

(lb/1000 Ib/SF) 

6.36 

i.i 4 

1.03 

0.59 

4.89 

0.11 

0.10 

0.07 

0.08' 

0.05 

6.28 

0.25 

0.19 

0.12 

0.10 

0.06 

"See Table 1-4 for full description. 

^Application using flow chopper. 

The THC measurements made during this program serve as the 

principal basis for estimating emissions. Figure 2-1 presents summary 

2-2 Rev. 1 

2 3 
P.25 

NMMA Baseline Emission Testing 

Figure 2-1 

Summary Concentration Traces for Boat Lamination and Gelcoating 

2-l[a] - Spray v. How Chopper: 18 Hull and Deck - 35% Styrene Resin 

300 

5 250 

e 

£_. 

O 

U 

200 

150 

100 

50 

• .*-

 : • | t* * 

• • * T_L,,'

f

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1? ! ^ * i 

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^•^-- ^ 

0:00 0:28 0:57 1:26 

Elapsed Time 

1:55 2:24 

! 35R 

2:52 

•35RFC 

2-l[b] - Spray v. How Chopper 18 Hull and Deck - 42% Styrene Resin 

c 

c 

0:00 0:28 0:57 1:26 1:55 

Elapsed Time 

2:24 2:52 

; 42R-— 

3:21 

-42RFC 

2-3 Rev.l 
P.26 

Baseline Emission Testing 

2-l[c] - Spray: 28 Hull - Both Resins 

0:00 1:12 2:24 3:36 

Elapsed Time 

4:48 6:00 7:12 

35R -42R 

0:00 0:28 

2-l[d] - Gelcoating 

0:57 1:26 

Elapsed Time 

1:55 2:24 2:52 

•18 Deck Gel -18 Hull Gel -28 Hull Gel 

2-4 Rev.l 

C 
P.27 

NMMA 

aiW&*W-*tW Basehne Emission Testing 

concentration profiles for the testing conducted during the April 1997 

deployment. Each of the four frames presents THC concentration traces derived 

by averaging data from the individual test runs. This figure illustrates some of 

the differences in the data summarized in Table 2-1. 

For example, the data from sampling the exhaust during 

lamination of the 18-ft mold illustrates the differences between spray up 

application and application by flow chopper, as well as the increased THC 

concentrations in the exhaust noted when laminating with a higher styrene 

content resin (42.2 percent styrene). The data from the 28-ft mold lamination test 

show that, although the peak concentrations using the two resins were 

essentially the same, the concentration trace for the 42 percent styrene resin has 

broader peaks, corresponding to greater mass emission rates. 

The summary illustration of the gelcoat data shows the effect of 

geometry on the concentrations measured. The greater THC concentrations in 

the exhaust noted during lamination of the 28-ft mold are likely the result of the 

broader strokes used in gelcoating the part and the distance between the 

operator and the part during gelcoating. The atomized gelcoat remains airborne 

for a longer period of time, resulting in greater volatilization and emissions of 

VOC. The operator can stand closer tp the 18-ft hull and make shorter strokes to 

apply the gelcoat. Also, the operator can coat half of the 18-ft mold surface in a 

single pass, rather than the minimum two passes required to coat the 28-ft hull 

mold; this difference is noted in the differences in peak widths. Finally, the 18-ft 

deck mold is relatively flat, with complex geometry requiring the operator to 

work close to the mold surface and coat some portions of the mold by brush, 

reducing the amount of gelcoat atomized. 

2-5 Rev. l 

-2 L 
P.28 

NMMA 

aaWaWTrWatW Baseline Emission Testing 

The results presented in the tables and figures in this report reflect 

the exclusion from testing of emissions in the long, low-concentration "tail" in 

each THC trace for each run. This phenomenon has been noted in previous 

studies and was highlighted in the QAPP as a concern for completing this testing 

in a timely fashion. Section 2.2 presents the results from some of the early test 

runs that illustrate that elimination of the "tail" has little if any effect on the, 

results reported herein. 

All the data related to emissions from boat gelcoating and 

lamination derived from this NMMA testing program are summarized in 

Figure 2-2. This figure presents the results for all tests in terms of emissions as a 

percent of available monomer. As the results clearly indicate., emissions from 

gelcoating differ from those associated with resin lamination. Sections 2.4 and 

2.5 contain more detailed presentations of the results from gelcoating and resin 

lamination emission testing. 

2.2 Evaluation of Emissions from Continuing Trace Concentrations 

The QAPP included the evaluation of a cutoff concentration in the 

exhaust stream that would allow cessation of sampling before the concentration 

of THC in the enclosure exhaust reached the background concentration, 

provided at least 95 percent of total emissions were characterized before 

cessation of sampling. The first test runs were used for this assessment. The 

assessment determined that 95 percent of total emissions from lamination and 

gelcoat operations would be characterized by the time the exhaust concentration 

reached 75 ppmv as propane. Ceasing sampling at this concentration would 

reduce run sampling by about 1 hour per run, allowing more sampling runs per 

dav. 

2-6 Rev.l 

2, 7 
P.29 

NMMA Baseline Emission Testing 

Figure 2-2 

Emissions as Percentage of Available Monomer 

As it turned out, it was practical to continue the test runs until 

concentrations measured about 7 ppmv as propane. Because the background 

concentration was about 2-4 ppmv, the difference in concentration was about 

4 ppmv, relating to less than 2 ppmv as styrene and representing only 

0.2 percent of emissions. 

The assessment of the concentration trace for NMMA-4-1 

(lamination of an 18-ft deck with 35 percent styrene resin) illustrates this 

analysis. The concentration trace for run NMMA-4-1 (Figure 2-3) shows the 

typical pattern of concentration peaks and valleys as resin is applied 

systematically to the sides of the mold. Resin and glass are applied to the first 

side, and the mixture is rolled out to remove air bubbles. After the initial coat on 

this half of the mold begins to gel, the mold is rotated and the first coat is 

applied to the second side. After the coat on the second side begins to gel, the 

2-7 Rev.l 

•—? % 
P.30 

NMMA Baseline Emission Testing 

mold is rotated again and the second layer of glass and resin is applied to the 

first side, with some of the glass being woven roving. This process continues 

until the specified thickness is achieved. As part of the manufacturing 

procedure, each layer of glass and resin are rolled out. After the final coat of 

resin is applied and the peak exotherm of the polymerization reaction is 

achieved, the concentration of styrene in the exhaust stream begins to decrease. 

All the glass and resin were applied to this mold in about 1 hour. The styrene 

concentration in the exhaust stream decreased to near background levels in 

about 1 hour after that point. 

Figure 2-3 

Total Hydrocarbon Concentration Trace for NMMA-4-1 

NMMA-4-1 (18 Deck 35R) 

350 -r % ___^* 

5. _5TM®Tl&_.l ^_rjL 

J~ '-$<> •* nL P ^l_r Jr *__ 

s i l I lr X 

« 5 -00 - / ^ b J ^ %. 

tr ir. _L *¥ _ii ___*^ B L 

- ° fe P *_Li T JT >•_ S »* 150 - 0 \ f %„ 1 S ^ 

s | T «fcj *feJ__r i___ 

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 100TJ ^ ^ ^\&_. 

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*** 7! "-.""* : ""* •**•* • *r -r -r -r *r -r 

•K iK iH iH t-i ifi iri tri iri ifi in ifi ifi 

lf_ O — ^1 V. rf if; O — M ec rf if. 

-r <fi ii"i iK ifi ui u-i i 0; <d- 'O is Os 

.)0^o 

80*. 

• TO"?.. 

60% 

• 5<r.i. 

4 0 * 

30% 

20% 

10?6 

Cumulative Mass Emissions 

(percent) 

Time (PST) j-®—THC o (ppm) 

| -—•— Cumulative Mass Percent 

Because the THC associated with the latter part of the 

concentration trace (from 7 to 4 ppmv) represents about 0.2 percent of emissions, 

the emissions associated with sampling completely to background levels from 

the cutoff concentration were less than 0.015 lb. Even this amount represents a 

2-8 Rev.l 
P.31 

NMMA Baseline Emission Testmg 

worst case assessment (i.e., greatest emissions in the tail) because it assumes that 

emissions from all tests are the same, whereas the total emissions from 

laminating the 18-ft deck mold were less than the emissions from laminating 

either other part evaluated. The 0.015-lb total would represent a larger portion of 

emissions for smaller parts, however, such as those included in the previous 

CFA/Dow and EPA/RTI studies. 

Another approach to assessing an appropriate cutoff concentration 

is depicted in Figure 2-4, a plot of outlet concentration and cumulative 

emissions. This figure, developed from the same NMMA-4-1 test run, shows that 

95 percent of total emissions from lamination were quantified when the exhaust 

concentration decreased to about 75 ppmv as propane. 

Figure 2-4 

Concentration v. Cumulative Mass Emissions (NMMA-4-1) 

400 

Exhaust Concentration v. Cumulative Mass Emissions 

70% 75% 80% 85% 90% 

Cumulative Mass Emissions 

95% 100% 

2-9 Rev. 1 

iC 
P.32 

NMMA 

aaWT&WaWatW Baseline Emission Testing 

2.3 CFA Mold Results 

Part of the test matrix for this program included lamination of the 

mold used in the CFA Phase I study so that results of both studies could be 

compared. Testing was conducted using the 35 percent styrene and 42 percent 

styrene resins, nearly identical to the styrene contents in the resins used in the 

CFA Phase I study. The initial test run using 35 percent resin (NMMA-11-1R) 

was conducted using the techniques employed by experienced laminators 

during actual boat manufacturing. This approach resulted in lower emissions 

than those measured during the CFA study. To allow comparison to the CFA 

study, subsequent tests were conducted using methods that resulted in 

"uncontrolled" spray, including one run during lamination by a completely 

inexperienced operator (NMMA-11-2R), as evinced by the 10.1 lb of resin used. 

Although not included among the planned tests, one gelcoat run (NMMA-ll-lG) 

was also conducted by an experienced operator using good technique. 

The results of testing during coating of the CFA mold (Table 2-2 

and Figure 2-5) indicate an average loss of 38.0 percent of available styrene 

during lamination using 35 percent styrene resin (not using Run 11-lR in the 

average) and 48.7 percent of available styrene loss during lamination using 

42 percent styrene resin. The results show a higher degree of variabilit}' than the 

results for lamination on the boat molds, largely as a result of the high degree of 

variabilit}' in application technique for inexperienced operators and the 

influence of the resin weight measurement. The resin extraction equipment 

disproportionately affected the measurement of small quantities of resin use 

(Section 3.2.4). Although the results of the various test runs met acceptance 

criteria, they were not as consistent as the results of emission testing during use 

of boat molds. Emissions measured during CFA mold lamination in this study 

were about twice those of comparable tests from the CFA study. 

— 2-10 Rev. l 

3/ 
P.33 

NMMA Baseline Emission Testing 

Table 2-2 

Emissions Measured During Application of Resin to CFA Mold 

Run 

11-lG 

11-lR-Ctrl 

ll-2R-Unc 

ll-3R-Unc 

12-1R-Unc 

12-2R-Unc 

Material 

Gelcoat 

Resin 

Resin 

Resin 

Resin 

Resin 

Content 

37.0 

35.1 

35.1 

35.1 

42.2 

42.2 

Resin 

(lb) 

3.2 

3.5 

10.1 

6.1 

5.4 

4.73 

Percent 

of 

Available 

46.9 

30.6 

29.9 

53.6 

55.7 

41.7 

Flux 

(lb/ft*. 

0.0203 

0.0114 

0.0233 

0.0456 

0.0441 

0.0208 

Normalized 

(lbA0001b/ft2) 

6.36 

3.25 

2.31 

7.48 

8.16 

4.39 

Styrene losses were also considered in terms of emissions per unit 

area and normalized emissions. Average losses per unit mold surface area (flux) 

were 0.0268 lb/ ft2 and 0.0325 lb/ft2 for the 35 and 42 percent styrene resins, 

respectively. Normalized losses averaged 4.35 lb/1000 lb/ft2 for the 35 percent 

styrene lamination and 6.28 lb/1000 lb/ft2 for the 42 percent styrene resin. Like 

the results in terms of percent of available styrene, these results indicate greater 

losses from use of greater styrene content resins than would be proportional to 

the actual styrene content. The flux losses show a different trend, but 

comparison of the emissions in this format is inconclusive because of the only 

slight difference in averages and the difficulty in consistent resin weight 

measurement. 

In this test series of the program (i.e., using the CFA mold), 

emission measurements were not always comparable to the amount of resin 

used, i.e., the emissions as percent of available monomer was not always 

consistent. The equipment was set up to measure large quantities of resin and 

gelcoat continuously. The expected quantities were between 100 and 300 lb resin 

for each test run. The scale selected, therefore, had an accuracy of 0.5 lb, which 

was satisfactory for the boat lamination and gelcoating tests, but which did not 

2-11 Rov. 1 
Baseline Emission Testmg 

Figure 2-5 

Emissions from Lamination and Gelcoating of the CFA Mold 

CFA Mold - Emissions (% Available) 

D Styrene 

13 MMA 

D Volatiles 

CFA Gel CFA 35R CFA 35R CFA 35R CFA 42R CFA 42R 

0.050 -r— 

0.045 -— 

0.040 4— 

0.035 4— 

0.030 4— 

0.023 4- 1 

0.020 — 

0.015 —-

0.010 — 

0.005 — 

0.000 — -

CFA Mold - Emissions (lb/SF) 

CFA Gel CFA 35R CFA 35R CFA 35R CFA 42R CFA 42R 

9 o 

| 6.0 4 — 

£ 5 0 J 

o 

O . ,-t 01/ j a : 

«> '> 0 • 5 

(A 

I O.O--. 

CFA C* 

CFA Mold - Emissions (lb/100 0 lb Resin/SF) 

CFA 35 Ft Cr.\ 35K CFA 35R CFA 42R CFA 42 R 

2-12 Rev. 1 
P.35 

NMMA 

atS^SS^kjWatW Baseline Emission Testing 

prove to be adequate for measuring the small quantities of resin (on the order of 

only 3.5 lb) used to laminate the CFA mold. Thus, the precision of the scale used 

for resin and gelcoat led to some results from CFA mold testing that were more 

variable than results from boat testing. 

2.4 Results of Gelcoat Application Testing 

All gelcoat application was done to a uniform thickness of 20 mils 

with a gelcoat containing 32 percent styrene and 5 percent MMA. A preliminary 

test run (NMMA-6-P) was made using a U.S. Marine production gelcoat 

supplied by the same supplier for the test gelcoat. Although the production 

gelcoat had different styrene content (approximately 31 percent), the results 

generated were included in this report because they are very consistent with the 

other results from gelcoat testing in this study (Figure 2-6). 

Results for boat gelcoating are presented in terms of losses of 

slyrene, MMA, and total volatiles (Figure 2-6). The total emissions measured for 

the deck and two hull sizes are consistent (especially for styrene and total 

volatiles), with slightly greater emissions resulting from gelcoating the hulls, 

and the.greatest emissions resulting from gelcoating the larger hull (Table 2-3). 

The most notable finding of this testing is the relative contribution to emissions 

of the individual constituents in the gelcoat. From 60 to 80 percent of the MMA 

in the gelcoat is lost as emissions in the gelcoat process. MMA is more volatile 

than styrene and, thus, is lost at a much greater rate than the styrene. Only one 

test run resulted in MMA losses of less than 60 percent of available MMA. That 

run (NMMA-6-1) was discarded from the average values presented in Table 2-3 

as unrepresentative because of variability of the GC response factors. 

2-13 Rev. 1 

37 
P.36 

NMMA 

Baseline Emission Testing 

Figure 2-6 

Gelcoat Emissions as Percent of Available Volatiles 

0''. 4 

D Styrene 

BMMA 

• Volatiles 

fa 

c 

oo 

O 

Cite 

Table 2-3 

Emissions from Gelcoating as Percentage of Available Volatiles 

18-ft Deck 

18-ft Hull 

28-ft Hull 

Gelcoat Use 

(lb) 

20.0 

25.7 

65.7 

Percent of 

Available 

Styrene 

42.3 

46.4 

50.4 

Percent of 

Available 

MMA 

75.6 

73.2 

78.6 

Percent of 

Available 

Volatiles 

46.9 

50.0 

54.3 

The results from the first test run on the 18-ft deck after the 

preliminary test using gelcoat (the second run for the 18-ft deck) yielded a loss of 

available MMA that was substantially less than all other measurements made 

during all other gelcoat test runs, only about 25 percent compared with 60 to 85 

2-14 Rev. 1 

35 
P.37 

NMMA Baseline Emission Testinp, 

percent of available MMA. Excluding that one run (NMM A-6-1) provides an 

average MMA loss of 75.6 percent of available MMA, a value that is very 

consistent with the MMA loss values for the 18-ft and 28-ft hulls. The average 

styrene loss for this test was relatively unchanged as a result of excluding that 

one run; likewise, the total volatile loss was relatively unchanged, owing to the 

contribution of styrene losses to the total volatile loss. 

Gelcoating results evaluated in terms of loss per unit mold surface 

area and normalized emissions (i.e., emissions per unit mass of resin per unit 

mold surface area) show some interesting trends (Table 2-4 and Figure 2-7). As 

would be expected, the emissions from the 18-ft molds are essentially equal, 

owing to nearly equal resin use and surface area. Normalized emissions appear 

to be inversely related to mold area, assuming the same thickness of the gelcoat 

is applied. Normalized emissions show the general trend of increasing emissions 

with decreasing mold surface area. This trend was also evident from the 

emission testing for resin lamination. 

Table 2-4 

Total Emissions from Gelcoating Related to Mold Surface Area 

18-ft Deck 

18-ft Hull 

28-ft Hull 

Gelcoat Use 

(lb) 

20.0 

25.7 

65.7 

Mold Area 

(ft2) 

171.09 

220.5 

454 

Emissions 

Ob/ft*) 

0.0228 

0.0261 

0.0389 

Emissions 

(lb/1000 lb/ft2) 

1.14 

1.03 

0.59 

2-15 Rev. 1 

35 
P.38 

NMMA Baseline Emission Testing 

Figure 2-7 

Emissions from Gelcoating Related to Mold Surface Area 

? 04? -

P C?f -

g •-•*- * " 

e

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OCi C -

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V 

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2.5 Results of Resin Lamination Testing 

Testing was conducted during lamination of three mold size and 

shape combinations selected to be representative of the majority of resin use in 

the industr}'. Because the quantities of resin used for each test are much greater 

than those used in previous testing, the results were very reproducible 

(Table 2-5). 

Figures are provided to illustrate the tabulated data. All tests are 

shown in the figures and are grouped by resin (styrene content) to allow 

comparison of the results across the different mold sizes and shapes. 

2-16 Rev.l 

3n 
P.39 

NMMA Baseline Emission Testing 

Table 2-5 

Emissions Measured During Resin Lamination 

Test 

18 Deck 35 R 

18 Deck 35 R FC 

18 Deck 42 R 

18 Deck42RFC 

18 Hull 35 R 

18 Hull 35 R FC 

18 Hull 42 R 

18 Hull 42 R FC 

28 Hull 35 R 

28 Hull 42 R 

Resin Use 

(lb) 

124.6 

114.7 

111.8 

122.2 

144.5 

141.7 

142.9 

154.9 

354.4 

304.2 

Percent of 

Available 

Styrene 

14.0 

11.6 

20.6 

13.1 

14.6 

10.5 

20.2 

11.1 

17.2 

22.9 

Emissions 

Flux (lb/ft*) 

0.0354 

0.0272 

0.0569 

0.0393 

0.0336 

0.0237 

0.0551 

0.0330 

0.0472 

0.0648 

Normalized 

(lb/1000 

lb/ft*) 

0.29 

0.24 

0.51 

0.32 

0.23 

0.17 

0.39 

0.21 

0.13 

0.21 

2.5.1 Emissions as Percent of Available Styrene 

Figure 2-8 presents the data for emissions as a function of available 

styrene. In each set of test runs for a given mold size and shape, the same pattern 

of emissions is seen: the emissions from the 42 percent styrene resin lamination 

are greater than the emissions from lamination using 35 percent styrene resin, 

and the use of a flow chopper to apply the resin does result in less emissions. 

The latter effect is likely the result of not atomizing styrene in the spray up 

process. Based on these measurements, the effect of flow chopper use on 

emissions is greater for the higher styrene content resins. 

The greatest emissions in terms of percent available styrene were 

measured for the larger mold size and the greater styrene content resin. An 

average loss of 23.3 percent of available styrene was measured from laminating 

the 28-ft hull with 42 percent styrene resin. Only 17.3 percent loss was measured 

for the same hull using 35 percent resin. Because this format of presenting 

2-17 Rev.l 

3? 
P.40 

NMMA 

Baseline Emission Testing 

Figure 2-8 

Emissions from Lamination as Function of Availabl e Styrene 

1 

1 

E ! 

1 1 

1 ! 

*= i 

3 ! 

*S i 

* <• 

c ! 

.2 lot — 

i 

f>°p — — — 

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„ J ? i i- * ; ;. I 1 1 1 £ £ 'i z 1 1 1 1 

;: S i s J. J i s 

emissions should account for differences in the resin styrene content, the results 

indicate that emissions are not directly proportional to resin styrene content, as 

might have been inferred from an emission factor based on percent available 

styrene. 

The comparisons become clearer when the same data are reviewed 

in terms of the various molds and tests for the different resins. Figure 2-9 

presents emissions as a percentage of available styrene in the resin for the two 

resins tested. One observation from these results is that emissions as a 

percentage of available styrene for a given styrene content in the resin increase 

with surface area of the mold for surface areas substantially greater (i.e., the 28-ft 

2-18 Rev.l 

J} 
P.41 

NMMA Baseline Emission Testing 

hull). This trend is apparent for the two styrene content resins tested. Also, the 

use of a flow chopper to apply resin reduces the percentage of available styrene 

emitted for a given mold size or shape. Greater reductions are noted for the 

greater percentage styrene content resin, but in general, reductions of 8 to 

45 percent are noted: from about 12.9 percent available to 11.9 percent available 

for the 35 percent styrene resin (18-ft deck) and from 20.7 percent available to 

11.4 percent available for the 42 percent styrene resin (18-ft hull). 

Figure 2-9 

Comparison of Results by Test 

i . 

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2-19 Rev.l 

-(0 
P.42 

NMMA Baseline Emission Testing 

2.5.2 Flux Emissions 

Emissions per unit area of mold surface (Figure 2-10) show the 

consistency of the runs made for testing and indicate general trends in the data. 

For example, emissions per unit surface area increase with the increase in resin 

styrene content. Also, the results are fairly consistent for the two 18-ft mold 

types, despite the difference in configuration. The hull is a concave mold and the 

deck (a bow rider design) has convex character. 

Figure 2-10 

Emissions from Resin Lamination as Flux Measurement 

c 

I 

ut 

O.OIO — 

o.oo? —- •— 

— 

— 

— 

— 

-

i 2 1 I * r. 5 5 | | i § jj jj v 5 | | jj | 

The same data, reduced to averages for each test set, are presented 

in Figure 2-11 for the two different styrene resins tested. These results again 

illustrate that emissions from the 42 percent styrene resin are greater than the 

2-20 Rev.l 

. ( 
P.43 

NMMA Baseline Emission Testing 

emissions from the 35 percent styrene resin lamination. In this case, because the 

mold surface areas are more nearly equal, flux emissions from the surface of the 

two 18-ft molds are almost equal. Figure 2-11 also shows that emissions from 

lamination using a flow chopper are less than the baseline cases. 

Figure 2-11 

Average Emission Flux Measurements for Two Resins 

-

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.D 

v>

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0.010 -j — 

0.005 -j — 

cc ec a o o a cctru o 

U-.blu-.b.b.CUftl'Nb . Ik 

« « « • **'»*£ £ •So^ca-e-B-ioi w 

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2.5.3 Normalized Emissions 

Figure 2-12 compares results from all resin lamination test runs 

presented as normalized emissions (mass of emissions per mass of resin per 

surface area). For both resins, the normalized emissions decrease with increasing 

surface area, indicated by the 18-ft deck to the 18-ft hull to the 28-ft hull. 

Normalized emissions were about 80 percent greater from lamination with 42 

percent styrene resin. Similar trends are noted for the emissions from lamination 

using a flow chopper; normalized emissions decrease with increasing mold 

2-21 Rev.l 
P.44 

NMMA Baseline Emission Testing 

surface area and are always less than the normalized emissions for the 

corresponding spray up operation. 

The differences between emissions generated using spray devices 

and those generated using flow choppers can be seen in Figure 2-1, which 

compares the concentration traces for 18-ft hull and deck mold lamination using 

two different styrene content resins and these two application methods. The 

difference in the concentiation profile is due to the application devices. The 

utility of the flow chopper in reducing the amount of styrene atomized in 

application is much greater for the higher styrene content resin. As Figure 2-1 

illustrates, the concentration tail after resin is applied is nearly identical for these 

two application methods. 

Figure 2-12 

Normalized Emissions from Resin Lamination 

2-22 Rev.l 

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Baseline Emission Testing 

3.0 CALIBRATION AND SAMPLING PROCEDURES 

The extensive battery of tests conducted and measurements made 

for this program includes those that were repeated routinely, either daily or 

during every test run, and those that were repeated only once or twice over the 

course of the whole program (Table 3-1). This section describes the procedures 

for all the tests conducted and measurements made during this program, 

including QC procedures (calibrations) and QA procedures followed to produce 

data for assessing the quality of the other measurements. The procedures are 

presented in terms of those associated with the process of manufacturing the 

part (i.e., hull or deck) and those associated with the measurement of emissions. 

Additional measurements (i.e., of air flow over the mold and styrene recover}7) 

and data handling are also addressed in this section. 

Table 3-1 

Measurements During Test Program 

Measurement 

THC Concentration 

Styrene (MMA) Concentration 

Wet Laminate Thickness 

Wet Film Thickness 

Styrene (MMA) Content 

Gel Time 

Resin Flow Rate 

Air Flow 

Air Temperature 

Exhaust Flow Rate 

Stvrene Recovery 

Resin/Gelcoal Weight 

Designation 

Method 25A 

Method 18 

Wet Mil Gauge 

Wet Mil Gauge 

Manufacturer's Method 

U.S. Marine Method 

Spray Gun Calibration 

Hot Wire Anemometer 

Exhaust Gas Temperature 

Vent Stack Air Flow Rate 

Material Balance/Method 25A 

Precision Balance 

Frequency 

Continuous 

Intermittent (6-15 min 

intervals) 

Each Test Run 

Each Test Run 

Per Batch Delivered 

Per Batch Delivered 

Pre/Post Test Daily 

For Each Mold 

Continuous 

One traverse set per test; 

continuous point 

measurement 

Pre/Post Program 

Pre/Post Test; continuous 

measurement 

Two test runs were made most test days; the number of tests 

completed in a day was dictated by the duration of the test and the availability 

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of material, molds, and personnel to construct the parts. On some days, only a 

single test run was completed, while on other days, as many as three test runs 

were completed. The procedures implemented most test days include the 

following: 

• Morning spray equipment calibration; 

• Morning leak check and calibration of the THC analyzer and the GC; 

• Measurements made during the test runs, including THC, styrene and MMA 

(using the GC), flow rate, weight of material (resin or gelcoat) used during 

the run, and temperature; 

• Post-test quality control measurements (calibrations); 

• Measurements for second test run (THC, styrene and MMA, flow rate, 

weight, and temperature); 

• Post-test quality control measurements; and 

• Evening spray gun flow rate calibration. 

Additional tests conducted include measuring the rate of air flow 

over the mold and mass balance styrene recovery checks (QA). 

3.1 Process Procedures and Measurements 

The procedures used to apply the resin were those used by the 

skilled U.S. Marine staff in applying gelcoat or resin/glass in the manufacturing 

operation. Resins and gelcoat selected for this program had characteristics 

typical of industry use and meeting the goals of this program (Section 1.3.5). 

Staff used to manufacture molds and to train lamination staff performed all 

gelcoating and lamination during this program. Additional personnel assisted 

when glass was rolled out or woven roving added to the mold. 

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Baseline Emission Testing 

3.1.1 Application Procedures 

After the morning calibrations were completed, monitoring of air 

flow was established, materials to be applied were weighed, and lamination (by 

spray up or flow chopper) or gelcoating of a part in the TTE commenced. Skilled 

operators applied resin and gelcoat as they would in normal production. The 

operators measured laminate and gelcoat thickness periodically as the material 

was applied, using a chop mil gauge for laminate thickness and a gelcoat mil 

gauge for gelcoat thickness. During the application of both materials, multiple 

readings were taken at three locations along the length of the mold as the 

operators fabricated the part. The operators did not record gauge readings but 

applied material to the desired thickness, in accordance with normal operating 

procedures. 

Gelcoat was applied using spray guns with a distance of 18-24 in. 

from spray tip to mold surface for smaller (18-ft) parts. The distance was greater 

for gelcoating the 28-ft hull mold, reaching 4-5 ft at the greatest distance from the 

application equipment to the keel of the hull. When gelcoating, a fog coat was 

applied first to one side of the mold and then a thicker layer was applied to 

bring the coating to a nominal thickness of 20 mils. Using typical gelcoating 

procedure, the operator checked the gelcoat thickness several times in at least 

three locations on each side of the mold to ensure uniform thickness. After one 

side was coated, the mold was rotated, and the process was repeated to coat the 

other half of the mold surface. Complex portions of some molds, such as 

encountered on the 18-ft deck mold, were coated using a cup and brush 

technique. These portions were typically inaccessible with the spray equipment. 

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A similar procedure was used to apply resin and glass to the 18-ft 

hull and deck and the 28-ft hull molds. In this procedure, though, a skin coat of 

resin and glass of about 90 mil thickness was applied first and allowed to cure 

almost entirely before applying additional layers of the laminate. Additional 

layers were then added by alternating resin/glass chop and resin/woven 

roving. The chopped glass was rolled out at ever}' layer. The laminate 

thicknesses for the hulls and decks were much greater than the laminate 

thicknesses used in previous studies. For example, a laminate thickness of 

414 mils was used in the bottom of the 28-ft hull (including three layers of 

woven roving, each about 48 mil thickness), and a thickness of 198 mils was used 

for the sides and transom of the same hull (including one roving). A 0.010-in. 

thickness gauge was used to make the measurements. 

3.1.2 Spray Equipment Calibration 

The spray gun resin or gelcoat flow rate was determined at the 

beginning of every test day and confirmed at the end of every test day, that is, 

before the first test and after the last test. The spray equipment flow rate was 

adjusted (resin pump pressure was adjusted and spray tip sizes changed) by the 

operator to provide the normal resin and gelcoat output for manufacturing 

operations, and the flow rate was recorded. The flow rate calibration consisted of 

spraying resin (or gelcoat) into a pre-weighed container for 15 seconds, 

recording the material weight, and calculating the rate in pounds per minute. 

For spray-up application, the glass content was adjusted to the required resin 

flow rate; after the resin flow rate was established, the chopper speed was 

adjusted to provide the proper glass ratio. The spray pattern was evaluated by 

the experienced operators by spraying resin and glass onto a cardboard panel. 

Adjustments were made based on the visual pattern to achieve the desired 

result. 

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Baseline Emission Testing 

The resin/gelcoat-to-catalyst ratio was calibrated by comparing the 

catalyst volume measurement to flow rate and adjusting the catalyst ratio by the 

slave pump setting. Both resin and catalyst are delivered to the applicator head 

by positive displacement pumps. Because the air-actuated piston pumps deliver 

a fixed amount of material with every stroke, the amount of catalyst delivered to 

the applicator head can be accurately set based on the stroke count. The amount 

of catalyst delivered to the applicator is very small compared with the amount of 

resin delivered, so the amount of resin is set first and calibration completed. 

Then the stroke count of the resin pump is set to the desired catalyst ratio. The 

catalyst ratio is adjusted after application of the skin coat and then these stroke 

count settings were maintained throughout each day. 

3.1.3 Gel Time 

Gel time was measured on site for each batch of resin used 

(Table 3-2). The procedure used to measure gel time (Appendix D) is the same 

procedure used by U.S. Marine in determining gel time for production resin and 

gelcoat. Gel time for gelcoat was determined using a 2 percent 925 clear catalyst 

(MEKP); a gel time of about 16.5 minutes is typical for the gelcoat. Two gel times 

are common for lamination, one for the skin coat and another for the bulk of the 

lamination. The skin coat gel time for the 35 percent styrene resin was about 

18 minutes using a 2 percent Red 925 MEKP catalyst; the remainder of the 

lamination was done using a gel time of about 23.2 minutes with a 1.5 percent 

Red 925 MEKP catalyst. The latter materials achieved a peak gel temperature in 

26 (for the 1.5 percent catalyst) to 34 minutes (for the 2 percent catalyst). 

Comparable gel measurements were made for the 42 percent styrene resin. 

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Table 3-2 

Gel Time Results 

Gelcoat 

Gel time @ 77°F 

35% Resin 

Gel time 

Gel time to 150°F 

Time to Peak Temperature 

Peak Temperature (°F) 

42% Resin 

Gel time 

Gel time to 150°F 

Time to Peak Temperature 

Peak Temperature (°F) 

1.5% Catalyst 

23:13 

6:05 

33:57 

350 

23:29 

6:17 

35:55 

320 

2% Catalyst 

16:30 

17:59 

5:06 

26:18 

360 

18:42 

5:05 

28:47 

352 

2,5% Catalyst 

15:38 

3:09 

22:11 

376 

16:38 

5:04 

27:08 

367 

3.1.4 Styrene and Methyl Methacrylate Content 

Styrene and MMA content of the resins and gelcoat used during 

this study were determined by the resin suppliers: Alpha/Owens-Corning for 

the resin and Cook Composites and Polymers for the gelcoat. Industry 

procedures were followed and certifications of styrene and MMA content 

provided (Table 3-3). Material safety data sheets with material certifications are 

in Appendix E. 

Table 3-3 

Styrene and MMA Contents 

Material 

Laminating Resin (35 R) 

Laminating Resin (42 R) 

Test Gelcoat 

Production Gelcoat (USM) 

Styre-de;:^*rtfent:;(wt.::;^;| 

35.1 

42.2 

32.0 

30.95 

:;::MMA^Coriferit:;(i^S%|! 

0.0 

0.0 

5.0 

4.95 

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Baseline Emission Testing 

3.2 Emission Testing Equipment and Procedures 

This section describes the equipment used to sample emissions 

from the enclosure and to measure other critical test parameters such as flow rate 

from the enclosure, temperature of the exhaust stream, and amount of resin 

applied. QC checks made on the sampling system are also presented in this 

section. 

Samples were collected from the enclosure's exhaust duct through 

Teflon® sample tubing at ambient temperature using a sample pump. This 

sample was fed continuously to a THC analyzer and to the GC used to speciate 

the organic compounds in the exhaust stream. The THC data were collected 

continuously and recorded in a computer data acquisition system (DAS) through 

a Dianachart data logger. GC data were collected separately. 

The following data were collected continuously: 

• TTE outlet THC concentration, 

• TTE inlet THC concentration, 

• Velocity pressure head in the exhaust duct, 

• Temperature of the exhaust stream, and 

• Weight of the gelcoat or resin used. 

3.2.1 Leak Check and Instrument Calibration 

Leak checks and bias checks were incorporated into the calibration 

and response factor procedures, respectively. Calibration gases were introduced 

at the probe inlet, and calibration responses were obtained using the same 

procedures as those used for sample responses. Certifications for all gas 

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Baseline Emission Testing 

standards are included in Appendix F. No vacuum leak checks were performed 

because any leaks, if present, would be small enough to be "calibrated out" and 

stable enough to have a negligible effect on post-test drift measurements. Any 

bias introduced by the system was similarly subsumed in the response factor 

determinations because they were performed with the entire sampling system. 

Instrument calibration checks were also made at the instrument 

and the results compared with the overall calibration checks made at the sample 

probe tip. The two sets of results were consistent, indicating that there was little 

or no bias in the sampling system. Checks by the EPA during their technical 

system audit verified the findings of the NMMA checks. 

3.2.1.1 Total Hydrocarbon Analyzer 

THC was measured at the outlet and inlet of the enclosure using an 

FID in accordance with EPA Method 25A (Appendix A). Analysis of the outlet 

gas stream was made using a Thermo Electron Model 51H THC analyzer. A 

Ratfisch Model 52RF analyzer was used to monitor THC content in the inlet air 

to the enclosure. A second Ratfisch was held on stand-by in case one of the other 

instruments failed. Both instruments were calibrated using the same procedure. 

Before testing each day, the calibration of the FID was verified 

using zero, low span (30 percent), mid-span (60 percent), and 90 percent span 

gases. Only one detection range, 1000 ppmv as propane, was used, which 

covered concentrations of styrene from 0 to approximately 416 ppmv. 

Calibration was simplified by using the DAS instead of recalibrating the two 

instruments. That is, instead of using adjustment potentiometers on the 

instruments themselves, the response signal to the DAS computer was adjusted 

in the computer program. This approach, which basically acknowledges that the 

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Baseline Emission Testing 

DAS is an integral part of the entire sampling, analysis, and data acquisition 

system, allowed more rapid calibration of the system each morning. An 

advantage, beyond mere simplification of the process, was that calibration 

incorporating the DAS allowed calibration of the entire system, including 

sampling lines, instrument, and data systems, incorporating potential biases 

created by sample extraction equipment, instrument response, and the DAS into 

a single system response. The acceptable calibration error of less than 10 percent 

was met for both instruments for all tests (Section 4.1.1). 

The FID was calibrated with propane. Instrument response factors 

were periodically developed for styrene and MMA by analyzing known 

concentrations of the target compounds in a manner identical to that employed 

for propane calibration. This procedure generated a correlation of relative 

response of the compounds on the THC instrument, a factor needed to compare 

the results of Method 18 sampling with Method 25A sampling. 

After the first test of the dav, the instrument drift of the analvzer 

•t at 

was checked using zero, 30 percent, and 60 percent span gases. When the drift 

was within the acceptable range, testing proceeded; otherwise, the instrument 

was recalibrated. The post-test calibration drift was recorded before any 

recalibration took place. The results of these measurements are reported in 

Section 4.1.1. 

Printouts of raw continuous emission monitoring data are included 

by run in the field data bound separately. Monitoring data printouts with 

reduced data are included with other calculations (Appendix C). 

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Baseline Emission Testing 

3.2.1.2 Gas Chromatograph 

Concentrations of the two specific organic compounds expected in 

the exhaust from the enclosure (styrene and MMA) were measured to provide 

speciation of their emissions during gelcoat operations and to provide a check on 

the Method 25A emission measurements using Method 18. Specific 

concentrations of styrene and MMA were determined using periodic 

measurements by GC using a Hewlett Packard Model 5890 with a Model 3396 

Series II integrator. A Supelco GP 10% l,2,3-tris(2-cyanoethoxy)propene on 

80/100 Chromosorb PAW column (1/8-in diameter X 6 ft long stainless steel) 

was used for these analyses. Hydrogen at 25 psi was provided to the instrument 

for the flame; air (at 33 psi) and nitrogen (at 50 psi) were also provided to the 

instrument to support the flame and as a carrier gas (35 cc/min) for the sample. 

The instrument was maintained at 130°C for all GC analyses. 

a/ 

Measurements and calibration were conducted in accordance with 

EPA Method 18 specifications (Appendix A). Sample gas was continuously fed 

to the GC using the sampling system from the enclosure exhaust duct. Part of the 

sample stream was sent to the THC analyzer, with another portion of the stream 

flowing to the GC. At least GC four measurements per hour were to be made in 

accordance with the QAPP; more often, data were collected every 6 to 8 minutes. 

The GC was calibrated according to Method 18 procedures using 

styrene and MMA to indicate the retention time and the area counts. Styrene gas 

standards in cylinders were used to provide styrene for these calibrations. MMA 

standards were prepared in Tedlar® bags (Appendix G) using the procedure 

detailed in Method 18. After establishing the retention time for styrene and 

MMA, the integrator was programmed to identify the two compounds (by 

retention time) and used the response factor determined daily to calculate the 

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concentrations of each compound. Area counts for the instrument responses 

were recorded and concentrations calculated off-line in spreadsheets. A linear 

relationship between concentration and area count was generated for each 

calibration to calculate concentrations. (These calibration "curves" are included 

with the calculations in Appendix C.) All chromatograms generated during 

daily tests have been bound separately with the other field data. Records and 

reductions for every run are included in Appendix C. 

Day to day calibration checks met the acceptance criteria or the 

instrument was recalibrated. Results of instrument calibration are presented in 

Section 4.1.2. The audit of the GC system that the EPA conducted is discussed in 

Section 4.7. 

3.2.2 Flow Rate Measurements 

Air flow rate from the enclosure was measured using EPA 

Method 2 protocols once per test. Flow rate was also monitored continuously at a 

single point in the TTE exhaust duct using a standard (Type L) pitot tube byrecording the velocity pressure head at the centroid of the duct. The pressure 

head was logged through the Dianachart data logger to the computer DAS with 

other parameters, such as temperature, resin weight, and THC concentrations at 

the inlet and outlet to the enclosure. The Method 2 velocity traverse was 

performed for each test run using the same standard pitot tube to monitor air 

flow through the duct. 

A velocity for each recorded THC measurement was calculated 

based on a ratio of the average pressure head readings. The constant velocity 

monitor reading at the time of the traverse was noted. This reading was scaled to 

the instantaneous reading (recorded in the DAS) and to the flow rate measured 

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AWJffi&PTttW Baseline Emission Testing 

using a complete traverse. The average of each calculated 1-min flow rate 

reading based on 1-min velocity head readings was used in calculating an 

average volumetric flow rate over the entire sampling period of the test run. The 

change in flow rate over the course of any test run was less than 3 percent. 

3.2.3 Temperature 

The type K thermocouple used for DAS and flow measurements 

was calibrated on site at two points: ice bath (32°F) and boiling water (212CF). 

Air temperature within the enclosure was monitored continuously at the location 

of the fixed pitot. Therefore, this temperature reflects the temperature at the 

sampling location rather than the temperature within the enclosure. Air flow 

velocities within the exhaust duct were approximately 30-35 ft/sec. The TTE 

exhaust temperature was therefore measured within two seconds of leaving the 

enclosure. The temperature of the well-mixed TTE exhaust provided a better 

measurement of the average TTE temperature than a single fixed point within 

the TTE because of the short retention time in the exhaust duct and the small 

temperature differential between ambient and exhaust air. The temperature was 

monitored continuously using the DAS calibrated at two points. 

3.2.4 Weight of Material Used 

The weight of the resin or gelcoat used during a test run was 

determined by weighing the container of material on a platform balance 

immediately before and after application to the mold. The balance was equipped 

with an analog output that allowed changes in weight to be tracked on the DAS. 

A small degree of variability in the weight measurement was noted 

during the testing on the CFA mold, where only 3.5 to 10 lb of resin were used. 

3-12 Rev. 1 
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Baseline Emission Testing 

The variability resulted from the movement of the ancillary equipment 

associated with the resin and catalyst delivery systems. As indicated by the 

weigh scale calibration checks (Section 4.6) and audit (Section 4.7.2), the scale 

met the desired performance criteria and provided accurate measurements of the 

resin and gelcoat use during testing on boat parts. 

The weight of the catalyst was determined from the resin (or 

gelcoat) weight and the established catalyst-to-resin ratio. These ratios were set 

based on stroke count of the positive displacement piston pumps used for both 

materials. The amount of catalyst was insignificant compared to resin or gelcoat 

use. 

The balance used to determine weight of resin and gelcoat used 

during lamination was calibrated by Weigh Tronics in Seattle before it was 

delivered to the site. All adjustments were made at the signal output and DAS; 

no adjustment was made to the scale that would have affected its calibration. 

Calibration certification is included with other certifications in Appendix F. 

Calibration of the scale was checked periodically during the testing 

program. These results are presented in Section 4.6. The precision and accuracy 

of the balance was checked during the on-site technical system audit conducted 

by the EPA. The results of this audit are presented in Section 4.7.2. 

3.3 Air Flow Over the Mold 

Air flow over the mold in the TTE was measured to enhance the 

documentation of the experiments conducted, but no adjustment was made to 

the rate of air flow through the enclosure based on the measurement. The more 

important adjustment was the flow rate through the enclosure to simulate the 

3 4 3 Rev.l 
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number of room volume exchanges found in the U.S. Marine production area (an 

P.58 

integral part of the TTE design). The velocities over the parts were measured 

merely to provide a record. 

To support the validity of the measured velocities over the parts, 

measurements were made (with a hot wire anemometer) early in the test 

program to determine the range of velocities over parts encountered in the 

production environment. Air flow velocities in a production lamination area 

used for laminating large boats and large parts for those boats ranged from 20-

25 ft/min near the air pick-ups at the exhaust plenum to 34-40 ft/min in the 

center of the lamination area. (In this production area, air was supplied through 

air handlers at one side of the room and exhausted from pick-up plena on the 

opposite side of the room.) Velocities near 200 ft/min were measured on covered 

molds (convex architecture) near the exhaust from the air handlers servicing the 

lamination area. This higher velocity was not typical in the lamination area. 

Measurements made in the testing enclosure showed that velocities 

of 20-24 ft/min were typical for the enclosure. These velocities were typical of 

measurements for induced draft environments, such as those found nearer the 

exhaust plenum in the lamination room. Measurements on the part (near the 

door to the enclosure) showed that the bulk velocity into the enclosure was 

approximately 40 ft/min. (Velocities at the NDOs to the TTE were much greater 

than the required 200 ft/min, as noted in Section 1.3.1.) 

Air flow over the mold was first evaluated for the 18-ft deck mold. 

Measurements at five locations on the mold surface ranged from 20-24 ft/min on 

the lower portion of the mold to 30-35 ft/min at the upper region of the mold, 

nearer the air intakes for the enclosure. Velocities were checked on the 28-ft hull 

mold at seven locations; velocities ranged from 20 to 36 ft/min. Measurements 

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were made parallel to the surface of the mold, where the maximum velocity was 

noted on the readout from the hot wire anemometer. Sketches from the log book 

showing locations of measurements and results are found in Appendix H. 

During the site audit by the EPA and its contractor Midwest 

Research Institute (MRI), air velocity measurements at the mold surface were 

made to verif}* that the velocity was in the range typical of the industry (and 

plant) practice. Measurements made by MRI (Appendix H) corroborate the 

measurements made on the molds. 

Velocities were not measured during each test or run. These 

velocities were not key measurements of the program; further, the velocities 

would not be expected to vary during the program because the flow rate 

through the enclosure was not a variable during this program and the geometry 

of the molds did not van'. 

3.4 Mass Balance Styrene Recovery Check 

In accordance with the QAPP, styrene evaporation tests (the towel 

tests) were conducted to evaluate the capture and recover}* of styrene by the 

sampling system. Two tests were completed, one at the initiation of the testing 

program and one at its conclusion. 

A covered container was loaded with a large pan, a collapsible 

clothes drying rack, towels, and a gallon of styrene and was weighed on a 

precision scale outside the TTE. (The scale used for this test was used by RTI in 

their testing to measure smaller quantities of materials.) The container was then 

placed inside the TTE, the rack erected in the pan, towels draped over the bars, 

and, with the flow rate and emissions being measured, the styrene was poured 

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Baseline Emission Testing 

over the towels and into the pan. A fan was used to induce flow over the towels 

and accelerate styrene evaporation. After about 30 minutes, the equipment was 

repacked into the container and the TTE allowed to clear of styrene (while 

emission monitoring continued). When emissions reached background 

concentrations, the container was removed from the TTE and reweighed. 

Emissions were measured using the THC analyzer and the GC 

during the first styrene recovery check, but using only the THC analyzer during 

the second. Recoveries are based on THC results, and the sampling system's 

capture and recovery of styrene was assessed by comparing the quantity of 

styrene evaporated (determined from weight loss of the container) with the 

quantity of styrene measured in the exhaust (calculated from the average styrene 

concentration and exhaust flow rate). The results of these tests, reported in 

Section 4.7.4, indicate good agreement between the measured evaporative loss 

and the measured mass emission quantity. 

3.5 Data Custody 

Because all emission measurements were made using continuous 

monitors that vent emission streams after analysis, no sample retention was 

necessary, or possible. Data collected in the field include gel time, spray gun 

calibration, quantity of resin material used, temperature of the exhaust, static 

pressure of the exhaust stream, pressure head of the exhaust stream, THC 

concentration of the inlet stream to the enclosure, THC concentration on the 

outlet stream from the enclosure, and concentrations of specific compounds in 

the exhaust from the enclosure. Test runs are designated by day, for example, 

0408-01 indicates the first run on April 8,1997. Test numbers are designated with 

"NMMA" prefix, for example, NMMA-l-1 indicates test condition 1, 

assessment 1 (Table 1-1). Thus, a test can be identified by date or by type using 

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the total description: 0405-01, NMMA-8-2 indicates a second replicate of a 28-ft 

hull gelcoating and was the first run on April 5,1997. 

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4.0 QUALITY CONTROL AND QUALITY ASSURANCE 

Quality control/quality assurance (QC/QA) guidelines outline 

pertinent steps to be followed during the production of gas composition data to 

ensure the reliability and acceptance of the data generated. QC, in the context of 

this report, refers to a system of activities designed to achieve a level of precision 

and accuracy as specified in the project plan. The QC procedures are targeted at 

maintaining a level of quality but in themselves are not a measure of the degree 

of quality achieved. QA, as used in this report, refers to the system of activities 

implemented to measure the effectiveness of the QC system. 

The QC/QA procedures implemented during this test program 

were presented in the Quality Assurance Project Plan for the National Marine 

Manufacturers Association Baseline Emission Testing Project (QAPP), which was 

approved by the EPA before the on-site sampling program. This section presents 

the results of the measurements taken to demonstrate adherence to the data 

quality objectives for critical measurements, as presented in Section 3 of the 

QAPP. 

4.1 Concentration Measurements 

The measurements taken for the characterization of THC content of 

the TTE exhaust gas stream were made according to the procedures of EPA 

Method 25A; this approach was the same as that used in previous studies, 

ensuring comparablity with those previous tests. Styrene and MMA 

concentration measurements were made according to Method 18 procedures. 

Previous studies have not evaluated resins containing MMA. Method 18 results 

are critical to speciation of THC from the gelcoat testing where these two species 

are measured. No other compound was identified in the Method 18 

4-1 Rev.1 

(ol 
P.63 

/VMMA Baseline Emission Testing 

chromatograms. The QA measures and the acceptance criteria used for this test 

program, which were approved by the EPA in the QAPP, are presented in 

Table 4-1. 

Table 4-1 

Acceptance Criteria for Concentration Measurements 

Method 

25A 

25A 

18 

18 

Measurement J 

Calibration Error 

Calibration Drift 

Calibration Error 

Calibration Drift 

; Acceptance Criteria 

<_ 10 percent of calibration gas value 

< 10 percent of calibration gas value 

< 10 percent of calibration gas value 

< 5 percent of calibration gas value 

Note: Cabbration error measurements were substituted for performance audits because no audit 

materials were provided for routine assessment. 

4.1.1 Total Hydrocarbon Measurements (Method 25A) 

Tables 4-2 and 4-3 present the results of the Method 25A calibration 

error and drift tests for all the test runs. Detailed results are presented in 

Appendix C. Both assessments of instrument performance were made before 

and after each test. The calibration errors presented in Table 4-2 are within the 

acceptance criteria presented in the QAPP. The results of instrument drift 

assessments demonstrate similar results; all post-test assessments are well within 

10 percent of pre-test values. Based on review of these Method 25A calibration 

assessments, all the data presented in this report are accurate to within 

10 percent of the values reported, with a variability in precision of no greater 

than 10 percent. 

Because Shirley Wasson of the ORD during her review of the 

QAPP expressed concerns about the stability of styrene stored in cylinders, THC 

instrument calibrations were performed using propane. Response factors were 

then determined for instrument response to styrene and MMA in terms of 

4-2 Rev.l 

6 2 
P.64 

/VMMA Baseline Emission Testing 

Table 4-2 

Calibration Error Measurements for Total Hydrocarbon Analyzer 

(Percent Actual Gas Value) 

Date 

10-Apr 

11-Apr 

15-Apr 

16-Apr 

2-Apr 

8-Apr 

11-Apr 

3-Apr 

8-Apr 

12-Apr 

14-Apr 

10-Apr 

11-Apr 

15-Apr 

16-Apr 

4-Apr 

8-Apr 

5-Apr 

9-Apr 

12-Apr 

14-Apr 

10-Apr 

11-Apr 

18-Apr 

19-Apr 

3-Apr 

5-Apr 

4-Apr 

"-Apr 

9-Apr 

10-Apr 

12-Apr 

14-Apr 

18-Apr 

Test 

NMMA-14-1 

NMMA-14-2 

NMMA-16-1 

NMMA-16-2 

NMMA-6-P 

NMMA-6-1 

NMMA-6-2 

NMMA-4-1 

NMMA-4-2 

NMMA-5-1 

NMMA-5-2 

NMMA-13-1 

NMMA-13-2 

NMMA-15-1 

NMMA-15-2 

NMMA-3-1 

NMMA-3-2 

NMMA-1-1 

NMMA-1-2 

NMMA-2-1 

NMMA-2-2 

NMMA-13-1 

NMMA-13-2 

NMMA-9-1 

NMMA-9-2 

NMMA-8-1 

NMMA-8-2 

NMMA-7-1 

NMMA-7-2 

NMMA-11-1 

NMMA-11-2 

NMMA-11-3 

NMMA-12-1 

NMMA-12-2 

Run 

0410-01 

0411-02 

0415-01 

0416-01 

0402-01 

0408-01 

0411-01 

0403-02 

0408-03 

0412-02 

0414-01 

0410-02 

0411-03 

0415-02 

0416-02 

0404-02 

0408-02 

0405-02 

0409-01 

0412-02 

0414-03 

0410-02 

0411-03 

0418-01 

0419-01 

0403-01 

0405-01 

0404-01 

0407-01 

0409-03 

0410-03 

0412-01 

0417-01 

0418-02 

0 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

Actual Gas Conccntralion (ppmv) 

Inlet Instrument 

15 

0.0 

0.7 

2.7 

2.0 

0.7 

-1.3 

3 3 

-0.7 

-1.3 

2.0 

2.0 

0.0 

0.7 

2.7 

2.0 

-1.3 

-1.3 

-4.7 

0.7 

2.0 

2.0 

0.0 

0.7 

0.7 

-1.3 

-0.7 

-1.3 

-1.3 

-1.7 

0.7 

0.0 

-1.3 

3.3 

0.7 

30.4 

0.0 

0.0 

2.3 

23 

13 

0.0 

4 3 

-0.3 

0.0 

13 

13 

-0.7 

0.0 

23 

2.3 

-0.7 

0.0 

-13 

03 

1.3 

13 

-0.7. 

0.0 

1.0 

0.7 

-03 

4.6 

-0.7 

-3.9 

0.3 

-0.7 

-13 

2.6 

1.0 

45.5 

-0.7 

-0.4 

0.4 

0.2 

-1.5 

-0.4 

0.4 

0.0 

-0.4 

0.2 

0.2 

0.2 

-0.4 

0.4 

0.2 

0.0 

-0.4 

0.4 

0.2 

0.2 

0.2 

0.2 

-0.4 

0.0 

-0.4 

0.0 

-4.8 

0.0 

0.7 

0.2 

0.2 

-0.9 

0.2 

0.0 

0 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

N.A. 

Outlet Instrument 

297 

13 

-0.4 

-0.8 

-0.9 

-03 

0.7 

-0.5 

1.8 

0.7 

-0.6 

0.7 

2.0 

-0.4 

-0.8 

-0.9 

-0.3 

0.7 

2.5 

-0.8 

-0.6 

0.7 

2.0 

-0.4 

0.0 

-0.7 

1.8 

4.7 

0.5 

3.0 

-0.8 

2.0 

2.8 

-0.1 

-0.9 

600 

2.3 

1.4 

-0.1 

0.1 

-0.7 

23 

0 3 

3.0 

23 

0 3 

1.9 

2.8 

1.4 

-0.1 

0.1 

-0.7 

23 

4.8 

0.2 

0 3 

1.9 

2.8 

1.4 

0.0 

0.8 

3.0 

4.8 

2.6 

5.2 

0.2 

2.8 

3.8 

0.7 

0.0 

914 

0.0 

-2,1 

-3.4 

0.0 

-03 

0.0 

-0.1 

0.2 

0.0 

-0.1 

-1.2 

-0.1 

-2.1 

-3.4 

0.0 

-03 

0.0 

2.8 

0.0 

-0.1 

-1.2 

-0.1 

-2.1 

-0.1 

0.1 

0.2 

1.1 

-0.4 

0.0 

0.0 

-0.1 

0.6 

-0.1 

-0.1 

1604 

-1.7 

-0.1 

-1.7 

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/VMMA Baseline Emission Testing 

response to propane. The response factors, determined for the outlet THC 

analyzer only, are listed in Table 4-4. The variation in instrument response 

factors serves as a measure of the day to day precision of the measurements as 

well as a correlation to styrene concentrations. The average relative response 

factor determined as the average of the daily average relative response factors 

for seven days of measurements, including values determined for all styrene 

calibration standards brought on site, is 2.40, with a standard deviation of 0.053 

(±2.2 percent). The issue of daily variation in response factors was not addressed 

in the QAPP and no criterion for data acceptance has been suggested. The 

standard deviation of the response factors is within the precision requirement for 

the THC calibration and drift criteria. 

Table 4-4 

Specific Compound Relative Response Factors 

for the Total Hydrocarbon Analyzer3 

Date 

1-Apr 

3-Apr 

7-Apr 

9-Apr 

9-Apr 

12-Apr 

12-Apr 

15-Apr 

16-Apr 

19-Apr 

19-Apr 

Average 

Styrene 

Concentration 

(ppmv) 

204 

204 

122 

204 

204 

59.2 

59.2 

59.2 

59.2 

122 

THC 

Response 

(ppmv) 

487.7 

506.8 

300.1 

490.3 

468.5 

148.4 

138.5 

137.6 

141.5 

304.3 

Relative 

Response 

Factor 

2.39 

2.48 

2.46 

2.40 

230 

2.51 

2.34 

2.32 

2.39 

2.49 

2.40 

MMA 

Concentration 

(ppmv) 

45.6 

139.6 

THC 

Response 

(ppmv) 

62.7 

166.8 

Relative 

Response 

Factor 

1.38 

1.19 

1.28 

^Relative response factor is the THC instrument measurement divided by the calibration gas 

•.oiuentration, e.g., ppm propane/ppm styrene. 

4-5 Rev.l 

6 5 J 
P.67 

/VMMA 

4^aaWaWjtW Baseline Emission Testing 

4.1.2 Organic Compound Concentrations (Method 18) 

Method 18 calibrations were conducted every morning before 

starting a test run. Calibrations were checked after each run to ensure that the 

instrument remained in calibration for the test series. A measure of calibration is 

provided by the response factors (Figures 4-1 and 4-2), which are simply the 

calibration gas concentration divided by the area counts from the chromatogram 

(i.e., the GC response). As the figures indicate, there was more variability in the 

response factors early in the sampling program. This variability resulted from 

leaking of the gas injection valve during these early runs. On April 12, the valve 

was replaced, and the response factor variation was reduced (after Analysis 

No. 714). 

Figure 4-1 

Method 18 Response Factors for Styrene 

0.00008 

0.00007 

,_ 0.00006 

o 

"g 0.00005 

S 0.00004 

§• 0.00003 

e

 0.00002 

0.00001 

0 

Response Factors for Styrene - Method 18 

I 

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Analysis Number 

Method 18 data for this program have been used primarily to 

determine the relative quantities of styrene and MMA emitted during 

4-6 Rev. 1 

/ / 

iyric: 
P.68 

/VMMA Baseline Emission Testmg 

gelcoating. The Method 18 results are also useful for comparison with the results 

of Method 25A testing. The relative concentrations of these two compounds in 

the TTE exhaust is important. An assessment of the ratio of the average response 

factors for styrene and MMA before and after April 12 (Analysis No. 712) shows 

that the leaking valve had little or no effect on the determination of the relative 

concentrations of these two compounds (Table 4-5) on average. 

Figure 4-2 

Method 18 Response Factors for Methyl Methacrylate 

0.00016 

0.00014 

0.00012 

2 0.0001 

£ 0.00008 

e 

o 

a" 0.00006 

Response Factors for MMA - Method 18 

Analysis Number 

Table 4-5 

Method 18 Response Factors for Target Compounds 

Stvrene 

MMA 

StvrenerMMA 

JBtforeMrpiii 12 ' JJ 

2.78E-05 

5.87E-05 

0.473 

; = V:. Aft« April 12; 

1.17E-05 

2.27E-05 

0.516 

4-7 Rev.l 

6 7 
P.69 

NMMA Baseline Emission Testing 

Daily response factor ratios were also assessed (Figure 4-3). Only 

those days when styrene and MMA results were needed, and the final check 

conducted on April 19, are presented in the assessment. The figure illustrates the 

variabilit}' seen in the individual measurements, although the degree of 

variabilit}* is lessened through the averages. The ratio of the response factors 

(important in apportioning emissions to styrene and MMA for gelcoating test 

runs) was relatively constant for all gelcoat test days except April 3 and April 8. 

The results for April 3 appear to be consistent with other days; so the difference 

in response factor ratio did not appear to affect results for that test. The results 

from April 8, however, indicate much lower concentrations of MMA than noted 

for all other gelcoat test runs. Styrene results for that test run were consistent 

with other measurements and Method 25A results were typical. The abnormally 

low reading for MMA is attributed to poor response for that calibration. 

Figure 4-3 

Method 18 Response Factors for Selected Test Days 

S.OE-05 

1.0E-C3 

O.OE+00 

0.7 

0.6 

0.5 

0.4 

OL 

VJ 

0.2 

0.1 

0.0 

2-Apr 3-Apr 4-Apr 5-Apr 8-Apr !)-Apr 11-Apr 19-Apr 

Stvrene 'MMA' •Stvrene:MMA 

4-8 Rev.l 

&><£ 
P.70 

/VMMA 

Jrr*aW-&ZaW Baseline Emission Testing 

The relative concentrations of styrene and MMA were determined 

using the following approach. Area counts based on chromatographic analyses 

were determined for each compound at varying levels of gas concentrations. An 

average response factor was then determined for various gas standards. A point 

to point calibration curve was generated plotting area count against gas 

concentration assuming a linear function from point to point. These calibration 

curves (Appendix C) were then used to determine the relative concentrations of 

styrene and MMA in each sample analyzed. 

Table 4-6 lists the QC measurements and their results. These 

measurements pertain only to styrene calibrations, because all gelcoating runs 

(i.e., the only runs involving MMA) had been completed by the time of 

equipment repair (April 12). All the pretest measurements of precision met the 

criteria defined for this program (within 10 percent of mean value). Drift 

exceeded the acceptance criteria of less than 5 percent of pretest values on four 

days; all these events occurred at the 59.2 ppmv styrene level. Data comparisons 

made between GC and THC concentration measurements show a higher level of 

styrene measured by the GC than by the THC analyzer, largely because the THC 

results are average results and the GC reports the concentration of a grab 

sample, generally selected by the GC operator to analyze temporal peaks in 

concentration. Because the reported emissions were calculated from the 

Method 25A results, drift in Method 18 measurements has no effect on the 

reported emissions. 

4-9 Rev. l 
P.71 

WMMA 

mr\rV,tiFr%XkWa40tr ^SSrJSBSpjtSorjBSSF Baseline Emission Testing 

Table 4-6 

Gas Chromatography Calibrations (after April 12) 

Date 

12-Apr 

12-Apr 

12-Apr 

14-Apr 

14-Apr 

14-Apr 

15-Apr 

Anaivsis 

No. 

713 

714 

729 

730 

731 

732 

733 

734 

735 

736 

737 

738 

759 

760 

761 

762 

768 

769 

470 

471 

472 

473 

474 

475 

476 

477 

478 

796 

797 

798 

818 

819 

820 

821 

823 

824 

826 

827 

830 

831 

832 

833 

834 

835 

854 

855 

875 

876 

877 

878 

Concn 

(ppmv) 

59.2 

59.2 

59.2 

59.2 

59.2 

122 

122 

204 

204 

204 

204 

204 

59.2 

59.2 

122 

122 

0 

0 

59.2 

59.2 

59.2 

122 

122 

122 

204 

204 

204 

204 

204 

204 

204 

204 

59.2 

59.2 

0 

0 

0 

0 

59.2 

59.2 

122 

122 

204 

204 

204 

59.2 

59.2 

59.2 

59.2 

204 

Area Count 

5971597 

6009331 

5958909 

6291424 

6429882 

10977608 

11537000 

16097608 

14421208 

21264480 

19247328 

19026992 

5525818 

5794490 

11881803 

10850096 

352953 

203009 

4755664 

4167498 

4384538 

9803558 

8547834 

8905798 

16823296 

16883072 

17030400 

17182512 

16327544 

16258032 

17429680 

16991360 

5021901 

5041053 

0 

0 

176395 

213703 

4179248 

5030979 

9615066 

9712975 

17192032 

16329160 

17244432 

4923560 

4928013 

4053978 

4739386 

17330048 

RF 

9.91 E-06 

9.85E-06 

9.93E-06 

9.41 E-06 

9.21E-06 

1.11 E-05 

1.06E-05 

1.27E-05 

1.41E-05 

9.59E-06 

1.06E-05 

1.07E-05 

1.07E-05 

1.02E-05 

1.03E-05 

1.12E-05 

1.24 E-05 

1.42E-05 

1.35E-05 

1.24 E-05 

1.43E-05 

1.37E-05 

1.21 E-05 

1.21 E-05 

1.20E-05 

1.19E-05 

1.25E-05 

1.25E-05 

1.17E-05 

1.20E-05 

1.18E-05 

1.17E-05 

O.OOE+00 

0.00E+00 

1.42E-05 

1.18E-05 

1.27E-05 

1.26E-05 

1.19E-05 

1.25E-05 

1.18E-05 

1.20E-05 

1.20E-05 

1.46E-05 

1.25E-05 

1.18E-05 

Precision 

(%Mean) 

-0.31 

-1.09 

-2.48 

0.58 

-2.37 

4.54 

-2.54 

-2.05 

-0.43 

-9.25 

-0.51 

2.57 

Drift 

3.18 

-0.59 

-15.07 

-2.87 

-7.27 

0.54 

-3.35 

Comment 

Pre 5-2 

Pre 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 5-2 

Post 2-1 

Post 2-1 

Post 2-1 

Post 2-1 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

pre 5-2 

post 5-2 

post 5-2 

post 5-2 

post 2-2 

post 2-2 

post 2-2 

post 2-2 

pre 16-1 

pre 16-1 

pre 16-1 

pre 16-1 

pre 16-1 

pre 16-1 

pre 16-1 

pre 16-1 

post 16-1 

post 16-1 

post 15-1 

post 15-1 

post 15-1 

post 15-1 

4-10 Rev.l 

*7G 
P.72 

/VMMA Baseline Emission Testing 

Table 4-6 (continued) 

Date 

16-Apr 

16-Apr 

16-Apr 

17-Apr 

I7-Apr 

18-Apr 

18-Apr 

19-Apr 

19-Apr 

19-Apr 

19-Apr 

Anaivsis 

No. 

879 

880 

881 

882 

883 

884 

885 

886 

905 

906 

910 

911 

912 

934 

935 

936 

937 

938 

939 

940 

941 

942 

943 

944 

945 

960 

961 

962 

963 

964 

978 

979 

980 

982 

983 

984 

1018 

1020 

1021 

1035 

1036 

1037 

1038 

1070 

1071 

1072 

1073 

1074 

1075 

1076 

1077.-

1078 

1079 

Concn 

(ppmv) 

0 

0 

59.2 

59.2 

122 

122 

122 

122 

59.2 

59.2 

0 

122 

122 

0 

122 

122 

59.2 

59.2 

0 

0 

59.2 

59.2 

59.2 

122 

122 

204 

204 

122 

59.2 

59.2 

0 

0 

59.2 

59.2 

204 

204 

204 

204 

59.2 

59.2 

59.2 

204 

204 

204 

204 

122 

122 

122 

59.2 

59.2 

59.2 

Area Count 

0 

0 

4915139 

4863680 

10776440 

9171008 

10341320 

10572206 

4956816 

4863680 

660 

11027728 

10367112 

0 

10505456 

10076096 

4985315 

5178906 

0 

2044 

4324157 

4535176 

4768189 

10597432 

9772608 

17712032 

18269232 

10231520 

5499240 

5894784 

1915 

3089 

5035434 

51S1651 

19345344 

18797024 

18110944 

19007808 

5687642 

4908355 

4736861 

18883424 

19033904 

18327536 

18467392 

11046080 

10864040 

11025512 

59S5747 

5700285 

5780963 

6178867 

6176253 

RF 

1.20E-05 

1.22E-05 

1.13E-05 

1.33E-05 

1.18E-05 

1.15E-05 

1.19E-05 

1.22E-05 

0.00E+00 

1.11E-05 

1.18E-05 

1.16E-05 

1.21 E-05 

1.19E-05 

1.14E-05 . 

1.37E-05 

1.31 E-05 

1.24E-05 

1.15E-05 

1.25E-05 

1.15E-05 

1.12E-05 

1.19E-05 

1.08E-05 

1.OOE-05 

1.18E-05 

1.14E-05 

1.05E-05 

1.09E-05 

1.13E-05 

1.07E-05 

1.04E-05 

1.21 E-05 

1.25E-05 

1.08E-05 

1.07F.-05 

1.11 E-05 

1.10E-05 

1.10E-05 

1.12F.-05 

1.11 E-05 

9.89E-06 

1.04E-05 

1.02E-05 

Precision 

(%Mean) 

0.53 

-1.10 

-2.50 

4.05 

-1.55 

-1.43 

1.44 

1.78 

-0.40 

0.00 

0.01 

Drift 

-0.42 

-2.17 

1.64 

-3.76 

-0.62 

-18.30 

2.80 

-10.20 

3.05 

3.28 

-17.44 

Comment 

pre 16-2 

pre 16-2 

pre 16-2 

pre 16-2 

pre 16-2 

pre 16-2 

pre 16-2 

pre 16-2 

post 16-2 

post 16-2 

post 16-2 

post 16-2 

post 16-2 

post 15-2 

post 15-2 

post 15-2 

post 15-2 

post 15-2 

pre 12-1 

pre 12-1 

pre 12-1 

pre 12-1 

pre 12-1 

pre 12-1 

pre 12-1 

post 12-2 

post 12-2 

post 12-2 

post 12-2 

post 12-2 

pre9-lc 

pre 9-1 c 

pre 9-1 c 

pre 9-1 c 

pre 9-1 c 

pre9-lc 

post 9-1 

post 9-1 

post 9-1 

pre 9-2 

pre 9-2 

pre 9-2 

pre 9-2 

post 9-2 

post 9-2 

post 9-2 

post 9-2. 

post 9-2 

post 9-2 

post 9-2 

Bias lesl 

MMA Bay, 7 

MMA Ba(i 7 

4-11 Rev.l 

7/ 
P.73 

/VMMA Baseline Emission Testing 

4.1.3 Comparison of Methods in Detennining Emissions 

There is relatively good agreement between the results of the two 

methods, with most of the measurements within 6-8 percent. The runs that had 

more divergent results were typically those involving smaller molds. Table 4-7 

presents a comparison of the results in terms of percent of available volatile 

material, which for most of the testing was styrene only. 

Table 4-7 

Comparison of Emission Results by Two Methods 

Date 

2-Apr 

4-Apr 

7-Apr 

8-Apr 

8-Apr 

8-Apr 

9-Apr 

9-Apr 

9-Apr 

10-Apr 

10-Apr 

10-Apr 

11-Apr 

11-Apr 

11-Apr 

12-Apr 

12-Apr 

12-Apr 

14-Apr 

14-Apr 

15-Apr 

15-Apr 

16-Apr 

16-Apr 

17-Apr 

18-Apr 

19-Apr 

18-Apr 

Test 

NMMA-6-P 

NMMA-7-1 

NMMA-7-2 

NMMA-6-1 

NMMA-3-2 

NMMA-4-2 

NMMA-1-2 

NMMA-ll-l G 

NMMA-11-1R 

NMMA-14-1 

NMMA-13-1 

NMMA-11-2R 

NMMA-6-2 

NMMA-14-2 

NMMA-13-2 

NMMA-11-3R 

NMMA-5-1 

NMMA-2-1 

NMMA-5-2 

NMMA-2-2 

NMMA-16-1 

NMMA-15-1 

NMMA-16-2 

NMMA-15-2 

NMMA-12-1 

NMMA-9-1 

NMMA-9-2 

NMMA-12-2 

Description 

18 Deck Gel 

28 Hull 35 R 

28 Hull 35 R 

18 Deck Gel 

18 Hull Gel 

If. Deck 35 R 

18Hull35R 

CFA Gel 

CFA 35R 

18 Deck 35R - FC 

18Hull35R-F C 

CFA 35R 

18 Deck Gel 

18Deck35R - FC 

18Hull35R-F C 

CFA 35R 

18Deck42R 

18Hull42R 

18Deck42R 

18Hull42R 

18 Deck 42R-FC 

18Hull42R-FC 

18Deck42R-FC 

18Hull42R-FC 

CFA 42R 

28Hull42R 

28Hull42R 

CFA42R 

Emissions (% 

Available) -

Method 25A 

47.0% 

15.7% 

18.8% 

42.3% 

• 54.2% 

16.1% 

13.9% 

43.4% 

29.8% 

11.1% 

10.5% 

28.8% 

45.2% 

12.1% 

10.5% 

52.0% 

20.4% 

22.3% 

20.8% 

18.2% 

12.2% 

11.6% 

14.0% 

10.6% 

54.6% 

22.8% 

23.0% 

39.2% 

Emissions (% 

Available) -

Method 18 

54.1% 

18.2% 

18.4% 

43.1% 

53.5% 

16.1% 

13.2% 

39.0% 

37.1 % 

10.4% 

11.0% 

26.8% 

46.4% 

11.1% 

10.9% 

44.8% 

14.1% 

24.1 % 

22.4% 

14.2% 

12.0% 

11.7% 

14.4% 

10.8% 

44.8% 

25.5% 

23.5% 

38.2% 

4-12 Rev. 1 

7 2. 
P.74 

WMMA Baseline Emission Testing 

Certainly, the concentration measurements made using both 

approaches yielded consistent results. The THC concentration trace for 

Run NMMA-7-1 and an equivalent THC concentration trace generated using 

measured styrene and MMA concentrations and the response factors developed 

during this program (2.40 for styrene and 1.39 for MMA), although not identical, 

show fair agreement for the different FIDs (Figure 4-4). 

Figure 4-4 

Comparison of Total Hydrocarbon Traces by Two Methods 

\ ; 

i 

**t \ a 

c

 finn ' 

o 1 i 

-» ->nfi • T- A 

c 4nn ' r?Jr—! f^ftBa 

I ! \kXJM 

"" L. 1 11 > Y__Hk V 1 

5 I V: 1/ \ 1 

1 u ! 1 hw W ^ ""oo ; 1 2 if vti ^"" 1 J ¥ 5* 

0 '• * 

NMMA-7-1 

j 1 

• i 

1 1 

1 ' 

! i 

i f . 

i te. i I n B i \j[\ n \ i 1 1 

O \\ i 

1 ZL 4. i aJr RS ' 

j_^r i jRB 1 T! 

. .. 

1 * 

1 

1 

1 

8:38 9:50 11:02 12:14 13:26 14:38 15:50 

Time (PST) 

! — • — M25A —B—M18Eq | 

4-13 Rev. 1 

7.3 
P.75 

NMMA Baseline Emission Testing 

4.2 Gelcoat and Resin Flow Rate 

Spray gun resin and gelcoat flow rates were determined at the start 

and end of each test day (Table 4-8). A single assessment was made during each 

flow rate check. Resin-to-glass ratios were assessed during the initial resin 

calibrations (Table 4-8). Catalyst-to-resin/gelcoat ratios were set according to the 

catalyst pump stroke rate. These ratios remained constant during testing. 

Table 4-8 

Spray Equipment Data 

Equipment 

Spray gun/ 

Resin 

Flow 

Chopper 

Spray gun/ 

Gelcoat 

Date 

3-Apr 

4-Apr 

5-Apr 

7-Apr 

8-Apr 

9-Apr 

10-Apr 

12-Apr 

14-Apr 

17-Apr 

18-Apr 

19-Apr 

10-Apr 

11-Apr 

15-Apr 

16-Apr 

3-Apr 

4-Apr 

5-Apr 

8-Apr 

9-Apr 

11-Apr 

Flow Rate (g/min) 

Pre test 

2888 

2828 

2792 

2836 

2956 

2892 

3192 

3100 

2944 

3036 

2956 

2556 

3164 

3084 

1264 

1256 

1264 

1260 

1272 

1256 

Post test 

2916 

3092 

2896 

2776 

2784 

3100 

3096 

2992 

2904 

2784 

2668 

3388 

3072 

1256 

1260 

1264 

1268 

1276 

1260 

Percent 

Change 

1.0 

9.3 

3.7 

-2.1 

-5.8 

7.2 

-3.0 

1.6 

-4.3 

-5.8 

4.4 

7.1 

-0.4 

-0.6 

0.3 

0.0 

0.6 

0.3 

0.3 

Resin 

(S) 

327 

324 

148 

277 

301 

242 

222 

218 

378 

317 

300 

256 

222 

297 

406 

317 

Glass 

(ft) 

180 

128 

77 

149 

176 

127 

114 

117 

201 

152 

160 

148 

11.4 

158 

192 

162 

Percent 

Glass 

35.5 

28.3 

34.2 

35.0 

36.9 

34.4 

33.9 

34.9 

34.7 

32.4 

34.8 

36.6 

33.9 

34.7 

32.1 

33.8 

4-14 Rev. 1 

7v 
P.76 

/VMMA JaW&A~GF Baseline Emission Testing 

4.3 Air Velocity over Mold Surface 

Air flow over the mold surface was assessed twice during the test 

program. These measurements reflect a best assessment approach and no 

presumption of accuracy has been made. In addition to being difficult to assess 

accurately, air flow over the mold (i.e., velocity) was dependent on mold 

position in the TTE, a factor that changed every time a tool was brought into the 

enclosure or moved within the enclosure in the process of lamination or 

gelcoating. The velocities measured at the mold surface were consistent with 

measurements made over mold surfaces in the manufacturing area, taking into 

account that the TTE was designed for induced draft flow. Greater emphasis was 

placed on controlling air flow through the enclosure to reflect conditions found 

in the facility than on attempting to duplicate the velocities measured during 

previous studies using parts not typical of boat building. 

Measurements made during a technical system audit performed by 

MRI and the EPA were consistent with the measurements made during this 

program. Their findings are reported in MRI's Technical Systems Audit ofa 

Laboratory Spray Booth at the U.S. Marine Facility in Arlington, Washington (May 29, 

1997). 

4.4 Exhaust Flow Rate 

Air flow rate through the enclosure was measured and monitored 

as described in Section 3.2.2. Accuracy of the velocity measurement can be 

assessed by observing the variability of the velocity head measurements (which 

were accurate to within 0.005 inches of water) during the test. This yields an 

assessment in terms of percent which can be compared with the acceptable 

criteria of the method. Variability measurements for all test runs are shown with 

4-15 Rev.l 

JJ 
P.77 

/VMMA Baseline Emission Testing 

the test averages (Table 4-9). The overall average variability in flow rate for the 

program was 2.9 percent, and no measure for an entire day was greater than 

6.9 percent. The two instances of greatest variability were affected by the two 

measurements on April 4, early in the program, when TTE exhaust filters had 

been allowed to become partially blocked and were first being changed during 

the test runs. 

Table 4-9 

Variability Measures for Flow Rate During Test Runs 

Date 

2-Apr 

3-Apr 

4-Apr 

5-Apr 

7-Apr 

8-Apr 

9-Apr 

10-Apr 

11-Apr 

12-Apr 

14-Apr 

15-Apr 

16-Apr 

17-Apr 

18-Apr 

19-Apr 

Average 

Flow Rate Variabaity (%) 

Runl 

1.0 

2.5 

4.9 

2.2 

2.5 

1.4 

3.2 

2.3 

2.9 

4.3 

3.2 

3.3 

2.1 

2.5 

2.7 

2.3 

Run 2 | Run 3 

3.2 

8.9 

.1.2 

3.3 

3.5 

2.8 

4.5 

4.2 

2.4 

3.5 

1.7 

2.4 

1.8 

0.9 

3.0 

3.7 

3.7 

Average 

1.0 

2.9 

6.9 

1.7 

2.5 

2.2 

2.6 

2.7 

3.7 

4.1 

2.8 

3.4 

1.9 

2.5 

2.5 

2.3 

2.9 

Flow rates during the test program were observed (based on the 

continuous, fixed point velocity head measurements) to vary based on filter 

collection and other operations. The exhaust plena on both longitudinal sides of 

the enclosure were equipped with filter media (spun fiberglass air filters). Flow 

rate decreased with time as these filters collected air-borne resin containing 

reactive styrene and MMA, which polymerized on the filter media. Periodically, 

these filters were replaced to ensure more consistent flow rates through the 

4-16 Rev.l 

7 b 
P.78 

NMMA rx i raWa&J&a&P Baseline Emission Testing 

enclosure for all test runs. The build-up of material on the filters was one cause 

of the variability in flow rate measured during the overall program. To some 

smaller extent, this affected flow rate over the course of the test run, more so for 

the larger articles which required more resin. A second cause of the fluctuation 

in flow rate was activity in the building where the enclosure was located. 

Temperature was affected by the opening and closing of doors into the building. 

Changes in the system operated by RTI also had some effect on the measurement 

of flow because both systems were connected to the same exhaust system at the 

U.S. Marine facility. Changes made to accommodate their operation had some 

effect on exhaust system pressure, thus affecting flow rate through the larger 

enclosure. 

4.5 Exhaust Air Temperature 

As described in Section 3.2.3, enclosure air temperature was 

monitored continuously using a type K thermocouple at the location of the fixed 

pitot and the DAS, calibrated at two points. The accuracy of this measurement 

was 0.005°F (or 0.0001 mV). Measurements of precision were not made during 

the test program; however, literature suggests the precision of type K 

thermocouples, assessed in a laboratory environment, will yield a precision of 

0.5°F, or within 1 percent of the measured values. 

4.6 Resin/Gelcoat Balance 

Balance calibration checks were often performed with barrels of 

resin still on the platform and always performed without zeroing the balance. 

Therefore, the calibration error was calculated in terms of percent of weight 

change rather than the displayed weight value (Table 4-10). All calibration 

results display a level of accuracy, measured as percent error, meeting the 

4-17 Rev.l 

7? 
P.79 

NMMA 

iPMorjM—xaaaaa MMt 

tsr.^raSr^sr 

Baseline Emission Testing 

criteria of the QAPP (within 2 lb). Based on the maximum error measure of 

0.2 percent and the high end of the scale measurements (i.e., 500 lb), the accuracy 

was within approximately 1 lb. 

Table 4-10 

Results of Balance Calibration Checks 

Date 

6-Apr 

8-Apr 

10-Apr 

15-Apr 

19-Apr 

Tare Weight 

(lb) 

0 

500 

300 

100 

0 

100 

200 

300 

400 

500 

0 

50 

100 

200 

0 

100 

200 

250 

0 

100 

200 

300 

400 

500 

100 

Initial Scale 

Reading (lb) 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

201.7 

201.7 

201.7 

201.7 

231.7 

231.7 

231.7 

231.7 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

Scale 

Response (lb) 

0 

500.1 

300.1 

100.1 

-1.9 

98.1 

197.9 

297.8 

397.6 

497.5 

201.7 

251.7 

301.7 

401.7 

231.7 

331.7 

431.9 

481.8 

-1.33 

98.5 

198.7 

298.7 

398.8 

498.7 

98.9 

Change in 

Weight (lb) 

0.0 

500.1 

300.1 

100.1 

0.0 

100.0 

199.8 

299.7 

399.5 

499.4 

0.0 

50.0 

100.0 

200.0 

0.0 

100.0 

200.2 

250.1 

0.0 

99.8 

200.0 

300.0 

400.1 

500.0 

100.2 

Error (% 

Tare) 

NA 

0.02 

0.03 

0.10 

NA 

0.00 

-0.10 

-0.10 

-0.12 

-0.12 

NA 

0.00 

0.00 

0.00 

NA 

0.00 

0.10 

0.04 

NA 

-0.17 

0.02 

0.01 

0.03 

0.01 

0.23 

4.7 Technical Systems Audit 

The performance of the sampling system was assessed through an 

audit and styrene recovery tests. Audits of the THC sampling, balance, and flow 

measurement systems were performed. The system audit was conducted by 

4-18 Rev.l 

? 7 

l '.al 
P.80 

NMMA Baseline Emission Testing 

EPA/OAQPS and its contractor MRI. The EPA/OAQPS audit will report on this 

project, but the final report has not been released. Also, styrene recovery tests 

(styrene evaporation tests) were performed in accordance with the QAPP. 

4.7.1 Total Hydrocarbon Measurement 

The results of the Method 25A system audit are presented in 

Table 4-11. The audit gas was introduced in two manners during the 

performance of the audit. One method involved filling a Tedlar® bag with the 

audit gas and attaching it to the sampling probe. In the second method/the audit 

cylinder was connected to the calibration system and the gas was introduced to 

the sampling system in the same manner as all on-site calibrations were 

performed; the propane audit was performed only with this latter method. Both 

methods yield results representative of the system performance. 

Table 4-11 

Audit Results for Method 25A Measurements 

Date 

15-Apr 

16-Apr 

Analyzer 

Measurement 

(ppmv OJHS) 

84.3 

85.3 

1000 

Result 

(ppmv as 

styrene) 

36.8 

36.8 

Gas 

Standard 

(ppmv) 

39.7* 

39.7 

999 

Compound 

Stvrene 

Styrene 

Propane 

Result 

(%) 

-7.3 

-7.3 

+0.1 

Notes 

b,c 

b,d 

d 

a. Gas standard reported at 41.7 ppmv; on site analysis by GC reported 39.7 ppmv. 

b. Response factor lo styrene is 2.289 on 4/15 and 2.318 on 4/16. 

c. Test performed with audit gas in Tedlar® bag. 

d. Test performed with audit gas tn vented cylinder. 

Conversion of THC concentration to equivalent concentrations of 

styrene was done using daily relative response factors determined from the THC 

analyzer (Method 25A) on the day of the audit. Using the pre-test analysis by 

Scott Specialty Gases (41.7 ppmv styrene), the analysis by THC analyzer was 

4-19 Rev.l 

7

a

, 
P.81 

NMMA 

Baseline Emission Testing 

about 12 percent low. However, on-site analysis of the standard by GC indicated 

that the concentration in the audit sample was only 39.7 ppmv. Although this 

assessment does not meet the requirements of a protocol gas certification, the 

results indicate that the certified value of the audit cylinder may be slightly low. 

Comparing to concentration from this reanalysis of the standard shows that the 

THC analysis was only 7.3 percent low, within the criterion established for the 

program. This low recovery does not appear to be a system malfunction. The 

good results of the propane audit indicate the low results of the styrene audit 

sample are not a result of sampling system bias (leaks). Further, procedures in 

determining response factors included introduction of the gas at the probe, thus 

incorporating any system characteristics into the results. The results of the 

styrene audit indicate the sampling system, as used in the performance of the 

audit, results in an under reporting of styrene concentrations by less than 

10 percent at a 40-ppmv concentration, or about 3 ppmv styrene. 

4.7.2 Weigh Cell Balance 

The results of the weigh cell balance audit performed on April 16 

indicate that greater than 5 percent error results when weighing less than 3000 g, 

or approximately 6.6 lb, on an empty scale (Table 4-12). However, testing was 

conducted with a drum of resin or gelcoat or resin in place, meaning that the 

scale was used during the test program in its normal operating range. The 

results of the audit and the calibration checks (Table 4-10) demonstrate that even 

small weight changes can be measured accurately through the weight range 

experienced during this test program. Although the audit was conducted with 

an empty balance, the calibration checks were conducted with both empty and 

loaded scale (i.e., with a drum of resin in place). Data collected from the 

calibration check using certified weights on April 8 indicate that a less than 1 lb 

change in weight at an elevated balance response (512 lb) was accurately 

— _ — — 

<*->... d u 
P.82 

NMMA Baseline Emission Testing 

quantified. These data indicate the balance was capable of accurately measuring 

500-g (1.1-lb) changes in weight in the range of operation, well within 

specifications of the QAPP (i.e., 2 lb). Two data points from the audit can be 

used to assess the precision of the weight measurements. The replicate weighing 

performed at 57 and 157 lb indicate a precision of greater than 0.2 lb, also within 

QAPP specifications. 

Table 4-12 

Results of Audit on Balance 

Date 

8-Aprd 

16-Aprb 

Audit 

Weight (g) 

3000 

5000 

6000 

6500 

Audit 

Weight (lb) 

: o 

0.002 

0.01 

0.04 

0.1 

0.4 

2.6 

7 

57 

157 

457 

357 

157 

57 

7 

2.6 

Scale 

Response 

(lb) 

504.3 

508.7 

510.9 

512 

Scale 

Response 

(lb) 

-1.92 

-1.94 

-1.96 

-1.99 

-1.86 

-1.65 

0.55 

5.06 

54.9 

154.74 

454.9 

355 

154.9 

55 

5 

0.5 

Scale Initial 

(lb) 

497.6 

497.6 

497.6 

497.6 

Scale Initial 

(lb) 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

-1.92 

Net Scale 

Response 

(lb) 

6.7 

11.1 

13.3 

14.4 

Net Scale 

Response 

(lb) 

0 

-0.02 

-0.04 

-0.07 

0.06 

0.27 

2.47 

6.98 

56.82 

156.66 

456.82 

356.92 

156.82 

56.92 

6.92 

2.42 

Difference 

(lb) 

0.086 

0.077 

0.072 

0.070 

Difference 

(lb) 

0.00 

-0.022 

-0.053 

-0.105 

-0.086 

-0.096 

-0.101 

0.000 

-0.180 

-0.340 

-0.180 

-0.080 

-0.180 

-0.080 

-0.060 

-0.15 

% Error 

1.30 

0.70 

0.55 

0.49 

% Error 

NA 

-1007.18 

-402.39 

-298.45 

-58.76 

-26.22 

-3.91 

0.00 

-0.32 

-0.22 

-0.04 

-0.02 

-0.11 

-0.14 

-0.86 

-5.86 

"Calibration check using certified weights. 

bAudit using certified weights. 

4-21 Rev. 1 

7/ 
P.83 

NMMA Baseline Emission Testing 

4.7.3 Flow Measurement 

The results of the flow rate audits were reported in the draft audit 

report. Comparison of the audit results to the measurements made for the test 

runs of the same days indicate good agreement for velocities and flow rates 

measured using Method 2 (Table 4-13). The preliminary velocity measurement 

by hot wire anemometer made by the auditor on April 14 indicated a greater 

velocity than calculated from pitot tube measurements. The differences are 

attributed to the hot wire anemometer velocity being a point measurement 

compared with an average velocity resulting from the pitot tube measurements 

and the presence of hydrocarbon in the stream, which can cause hot wire 

anemometer velocity readings greater than actual velocities. 

Table 4-13 

Results of Flow Rate Audit 

Date 

14-Apr 

15-Apr 

Test 

Audit-hot wire 

NMMA-5-2 

NMMA-2-2 

Audit-pitot 

NMMA-16-1 

NMMA-15-1 

Velocity (ftyinin) 

1930 

1738 

1728 

1787 

1866 _ , 

1793 

Flow Rate (cfm) 

3071 

3053 

3157 

3297 

3168 

4.7.4 Styrene Evaporation Test 

In accordance with the QAPP, styrene evaporation tests (the towel 

tests) were conducted to evaluate the capture and recovery of styrene by the 

sampling system. Two tests were completed, one at the initiation of the testing 

program and one at the conclusion of the program. In both cases, the recovered 

quantity of styrene met the acceptance criteria for a good system (±10 percent) 

(Table 4-14). 

4-22 Rev.l 

Jy 
P.84 

NMMA Baseline Emission Testmg 

Table 4-14 

Results of Styrene Evaporation Tests 

Date 

Material Losses (g) 

Temperature (°F) 

Flow rate (acfm) 

Average THC Concentration (ppmv) 

Duration (min) 

Measured Emissions (g) 

Percent Difference 

Towel-1 

4/1/97 

1199 

65.6 

3017 

117.8 

66 

1202 

0.21 

Towel-2 

4/19/97 

1095 

66 

3306 

116.7 

59 

1165 

6.4 

The first test represents the best measure of the system and its 

operation because no testing had been conducted in the building and, therefore, 

no background styrene in building air or booth air interfered with the results. 

The results from the first test showed excellent agreement between the measured 

quantity of styrene evaporated from the apparatus (provided by RTI) and the 

emissions determined by measuring stack gas concentrations and flow rate. The 

closure between these two measurements is not as close for the final test, 

however. Although it is true that the flow rate through the enclosure was greater 

during the second test, the greater emissions measured are attributed more to 

the mold left in the enclosure after previous lamination testing. Although the 

measured styrene concentrations were adjusted for the concentration in the 

incoming air and attempts were made to account for the background 

concentration in the enclosure, it is likely that some of the styrene included in the 

measured emissions may have been generated by the mold and part left in the 

enclosure (i.e., residual curing emissions). 

4-23 Rev. 1 

?3 
P.85 

STELLING ENGINEERING, P.A. 

1319 ARNrnrE AVENUE. DURHAM. NC 27707 

(919)4190395 FAX 489-2064 

MEMORANDU M 

To: Eric Goehl, ERG 

From: John Stelling^ 

Date: September 

Re: Correction Pages for NMMA Test Report 

Enclosed are correction pages 1-6 and 2-17 ofthe report on characterization of emissions 

from fiberglass boat manufacturing conducted in April 1997 for the National Marine 

Manufacturers Association (NMMA). These two pages correct information based on 

comments received this week. 

The Venus Gusmer equipment (spray and flow choppers) had been incorrecdy presented as 

airless air-assisted. Both pieces of application equipment are airless low-pressure design 

employing intemal mix. Also, the pump system used for the Binks Poly-Craft gelcoat gun 

was also a Binks Poly-Craft design and not the Glas-Craft design previously reported. 

Table 2-5 presents the results ofresin testing. This is a WORD table that did not get updated 

from some very preliminary data as we finalized the report. The replacement page presents 

the correct values in the table. The correct values had already been presented in the report in 

Table 2-1. 

Please call me with any questions. 

EG09047 

9-V 
P.86 

NMMA 

aWkWt&aW . Baseline Emission Testing 

Continuous strand fiberglass roving is fed to a chopper unit mounted on the 

spray gun and is cut into chopped fiber lengths of approximately 1.5 in. long. 

The chopped fiber is ejected from the chopper unit and is captured by the resin 

fan pattern a short distance from the spray gun. The mixture of the catalyzed 

resin and chopped fiber is deposited on the mold by the spraying action. Typical 

of fiberglass boat manufacture, woven roving (a fabric material) was used with 

resin application by spray gun and flow chopper for the addition of this 

reinforcement. A Venus Gusmer G03 low-pressure slave arm internal mix 

airless chopper gun equipped with a 5003 tip, typical of guns used in the 

industry, was used for spray application of resin and chopped glass during this 

program. 

Resin was supplied to the chopper gun and the flow chopper by a 

Venus Gusmer system at a pump ratio of 11 to 1. The methyl ethyl ketone 

peroxide (MEKP)/dimethyl phthalate (DMP) catalyst was internally mixed for 

both chopper gun and flow chopper, with the catalyst delivered by a slave pump 

system. The flow chopper was also a Venus Gusmer design. The resin is 

delivered at a much lower pressure and no air is used to dispense the resin into 

the chopped glass. The glass is chopped into lengths using the same method as 

in the chopper gun, but because there is no atomizing air, the dispersion pattern 

of glass and resin mixture is more narrow. 

Gelcoat is applied in the boat building industry using a spray gun, 

typically an airless air-assisted spray gun. For this program, gelcoat was 

delivered to the spray gun using a Poly-Craft pump system at a pump ratio of 23 

to 1. Catalyst, delivered using a metered feed pump, was mixed externally. A 

Poly-Craft 755 airless air-assisted spray gun (equipped with a 0.026 tip size) was 

used during this program. 

1-6 Rev.l 

?5 
P.87 

NMMA 

Baseline Emission Testing 

Table 2-5 

Emissions Measured During Resin Lamination 

\; 

JN 

/ 

- -lest 

18 Deck 35 R 

18 Deck 35 R FC 

18 Deck 42 R 

18 Deck 42 RFC 

18 Hull 35 R~ 

-18 Hull 35 R FC 

18 Hull 42 R 

18 Hull 42 R FC 

28 Hull 35 R 

28 Hull 42 R 

Kesin Use 

Ob) 

124.6 

114.7 

111.8 

122.2 

144.5 

141.7 

142.9 

154.9 

354.4 

304.2 

Emissions 

Percent of 

Available 

Styrene 

12.9 

11.9 

21.1 

13.4 

14.8 

10.8 

20.7 

11.4 

17.3 

23.3 

Flux (lb/ft*) 

0.0130 

0.0092 

0.0284 

0.0125 

0.0143 

0.0072 

0.0272 

0.0089 

0.0234 

0.0357 

Normalized 

(lb/1000 

ib/m 

0.11 

0.08 

0.25 

0.10 

0.10 

0.05 

0.19 

0.06 / 

0.07 

0.12 "•/ ' 

2.5.1 Emissions as Percent of Available Styrene 

Figure 2-8 presents the data for emissions as a function of available 

styrene. In each set of test runs for a given mold size and shape, the same pattern 

of emissions is seen: the emissions from the 42 percent styrene resin lamination 

are greater than the emissions from lamination using 35 percent styrene resin, 

and the use of a flow chopper to apply the resin does result in less emissions. 

The latter effect is likely the result of not atomizing styrene in the spray up 

process. Based on these measurements, the effect of flow chopper use on 

emissions is greater for the higher styrene content resins. 

The greatest emissions in terms of percent available styrene were 

measured for the larger mold size and the greater styrene content resin. An 

average loss of 23.3 percent of available styrene was measured from laminating 

the 28-ft hull with 42 percent styrene resin. Only 17.3 percent loss was measured 

for the same hull using 35 percent resin. Because this format of presenting 

2-17 Rev.l 

n