TECHNICAL DOCUMENT

IN SUPPORT OF A PETITION

BY CROWNLINE BOATS, INC.

FORAN ADJUSTED STANDARD

December 2003·

Prepared for:

.Crownline Boats, Inc.

West Frankfort, Illinois

Prepared by:

Advance Environmental Associates, L.L.G.

300 S. Second Street

St. Charles, Missouri 63301
Table of Contents

Page

1.0 BACKGROUND : : 1

1.1 Business History of Cro\vnline Bo¥s, Inc 1

1.2 Crownline's Compliance History ' 1

1.3 Background Leading to the 8 lb/hr YOM Rule Compliance Issue 1

2.0 DISCUSSION OF THE BOAT MANUFACTURING INDUSTRY 2

2.1 Overview of Basic Fiberglass Boat Manufacturing Processes 2

2.2 Boat Manufacturing Proc'esses at Crownline Boats 4

2.3 New MACT Standard and Crownline's Compliance With the 8 lb/hr Rule 4

3.0 YOM AND HAP EMISSION SUM]\;lARY FOR CROWNLINE BOATS 5

3.1 Methodology for Calculating YOM Emissions from Gelcoat and

Lamination 5

3.2 YOM Emissions from Small Boat Parts and Final Assembly 10

4.0 INVESTIGATION OF COMPLIANCE ALTERNATIVES: METHODS FOR

REDUCING YOM EMISSIONS FROM BOAT MANUFACTURING 10

4.1 Method 1- Reduce VOMs in production materials : 10

4.2 Method 2 - Replace existing production methods with alteITlate

production methods 11

4.3 Method 3 - VOC Reduction Through the Application of Tail-End

Emission Control Equipment 16

5.0 QUAi"'lTITATIvE AND QUALITATIVE IMPACT OF CROWNLINE'S

OPERATIONS ON AMBIENT AIR QUALITY 20

5.1 Description of Ozone Impact Analyses ,~ : 20

Appendices

Appendi.,l

Appendi.,2

Appendix 3

Appendi.,4

Appendi.,5

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Background on Crownline's History, Products and Production

Methods

Photographs of Crownline's Operations

March 23, 2000 Letter from IEPA to Crownline Boats Concerning New

Emission Factors '

Baseline Characterization of Emissions from Fiberglass Boat

Manufacturers for NMMA, August, 1997

April 11, 2001 Letter to Don Sutton ofIEPA from AEA
Appendi, 6

Appendix 7

Appendix 8

Appendix 9

Appendi, 10

Appendix 11

Appendix 12

Appendi., 13

Appendi., 14

Appendi., 15

Appendi.,16

1663007.3

DRAFT

Development of Equations For Extrapolating NMMA Emission

Factors to Calculate Styrene and Methyl Methacrylate (MlYlA)

Emissions From the Application of Gelcoats and Resins to Boat Hulls

and Decks Considering Varying Boat Length and Other Variables

VOM Emission Calculations from Caulking, Adhesive and

Lacquer Operations

VOM Emission Calculations from Small Parts

Detailed Information About VEC Technology

. Spread Sheet Showing Cost Per Ton ofVOM Removed

Proposal from BioRem Techoologies, Inc.

Proposal from BacTee Systems, Inc.

. Proposal from DUff Environmental, Inc.

Proposal from MegTec Systems

Proposal from Frees, Inc.

Details of Crownline's Ozone Impact Analysis

11
1.0 BACKGROUND

1.1 Business History of Crownline Boats, Inc.

Crownline Boats, Inc. (Crownline) owns and operates a fiberglass boat manufacturing faciit\' undet

primary SIC code of 3732. Crownline's first boat rolled off the line on i\larch 23, 1991. _.I., that

time Crownline employed less' than 25 people. By 1991, Crownline had grown out of its , Whittington location and moved into a larger facility. By December 1994, Crownline's ne,,· sme-ofthe-art boat manufacturing plant was completed. ill! of Crownline's operations ha,-e beer: at this .

new location since then. The cunent facility is located approximately 1.5 miles south of dee town of

West Frankfort, Illinois along Illinois Srate Route 37 in an area that consists of residential and rural

properties. In addition to making an impact on the marine industry, Crownline has a150 positively

affected the local economy, and with 500-600 full-time personnel, is one of the large" em?lo\'ers in

Southern Illinois.

More specific information about Crownline's operations is presented in Section 2.0. _\1so. more

history and photographs ofsome of Crownline's key production operations and products are

located, in Appendices 1 and 2 to this document.

1."2 Crownline's Compliance History

Crownline has always strivedro comply with environmental, safety and health reguG.:ion5. In the

mid-1990's, they responded to odor complaints in the vicinity of the plant by installing ar: odor

reduction system. In addition, in order to meet OSH..A. worker styrene exposure limics, Crownline

installed a new ,-entilation system for worker protection and, as part of this installation, designed

the system to disperse air vented from the plant in order to reduce odors.

It continues to be Crownline's goal to comply with environmental regulations includi.."1g 35 HC

.§215.301 "Use of Organic Material" (the "8 Ib/hI Rule"). ,\ complete history of de'Cel0p:::lenrs

related to Crownline's compliance with the 81b/hI Rule is presented'in the following seccon of this

report.

1.3 Background Leading to the 8 Ib/hr 'lOM Rule Compliance Issue

In March, 2000, Crownline received a letter from IEPA informing them that the method for

calculating emissions for polyester resin product manufacruring processes had changed (see

Appendix 3). The IEP,\ had indicated that the pre,-ious l..'SEPA polyester resin produG

manufacturing process emission factors underestimate emissions and, therefore, should not be used.

However, IEPA agreed with the USEPA in that the new factors, developed by the :-\atiold j\[arine

Manufacturer's _\ssociation (NMlY.lA.) for fiberglass boat manufacruring, more accurareh- represent

emissions of styrene and other hazardous volatile organic air pollutants. Accordingk, the5e new

factors should be used to estimate 'lOM emissions. The letter also stated that "users mus' evaluate

these new factors for applicability to their own operations in order to determine which are the most

appropriate for accurately estimating emissions". .

Due to the complexity of the new factors and their desire to properly e,-aluate the new emission

factors for applicability to their boat manufacruring processes, Crownline contracted with a

consultant, Advance Environmental Associates, L.L.c. (AEA), to perform the necess:uy analyses.

Specifically, AEA evaluated the methodology for calculating Crownline's boat manufacturing

1663007.2
emissions and, using the nev·; emission factors, re-calculate 'emissions associated with the gelcoating,

resin lamination, and other boat production processes at the \V'est Frankfort plant that use VOr,!-

containing materials. Coincident wim me re-computing ofVOM emissions using me new emission

factors, AKA, also reviewed Crownline's Preliminary Draft Tide V Oper~ting permit. A review of

Crownline's draft Tide V operating permit identified that it clid not define the memod by which

Crownline will be expected to demonstrate compliance with me 8 Ib/hr Rule. .

Using the new emission factors thar were developed from a 1997 study by the NMi\L-\ and accepted

by IEPA and USEPA (See Appendi:, 4 for a copy of me 1997 study tided, "Baseline

Characterization of Emissions From Fiberglass Boat Manufactuting For National Marine

Manufacturers Association), d,e hourI\- emissions from certain of Crownline's operations

(application of gelcoat, resin, caulk, ~dhesi\-e, and lacquer to boat hulls, decks, and small parts) have

been computed. The results of these computations show that hourly emissions for certain parts of

Crownline's operations would exceed me 8 Ib/hr limit on a strict hourly basis.

In the event emissions calculations showed mar Crownline could not demonstrate compliance with

me 8 Ib/hr Rule on a strict hourly b~sis, Crownline decided to determine if any viable methods fm

reducing YOM emissions from meir operations exist and could be practically employed at their

facility. Accordingly, with AEA's assisrance, Crownline embarked on identifying and evaluating'

available methods. This analysis carefully ex~mined both the technical and economi~ feasibility of

possible process changes and me application of available and proven add-on air pollution controls.

While AEA conducted this analysis, Crownline sinmltaneously agreed to begin the process for

petitioning the Illinois Pollution Control Board ("me Board") for an adjusted standard. In

cliscussions with IEPA, Crownline decided thar pursuing an adjusted standard would be a yiable

option. IEPA concurred with this approach.

2.0 DISCUSSION OF THE BOAT i\LI\NUFACTURING INDUSTRY

This section discusses the boat manuhcruring industry in general and the various memods for

making boats. It also discusses me specific boat manufacturing technology used at Crownline and

the newly promulgated i\L-\CT Standard for me boat manufacturing industry.

2.1 Overview ofBasic Fiberglass Boat ManufaChIring Processes

There are two basic methods, or processes, that are used for fiberglass boat production in the

boating industry: 1) open molding; and 2) closed molding. Crownline, along with the vast majority

of boat manufactUrers in the U.S., uses an open molding process. There are a variety of memods

used in the general fiberglass producrs manufacruring industries (including the fiberglass boat

building industry), however, all are simply \"ariations of eimer ofthese two basic methods.

Typically, fiberglass boat manufactuting can be clivided into the following process steps:

• Mold fabrication, mold cleaning, wax application

• Gelcoat application (see Photos ;:;:1 - #4)

• Lamination (resin application, see Photos #5 & #6)

• Grind and Trim (see Photo ;:;:7)

• Woodworking

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• Upholstery installation (see Photo #8)

• Final Assembly (see Photo #9)

• Shipping

Photographs of Crownline's production operations are located in Appendi.." 2.

The gelcoat and lamination operations generate most of Crownline's VO,\[ emissions (the majority

of which consist of styre.ne). Accordingly, the overview of boat manufacturing technologies

presented in this section is focused on these two primary operations.

By far, the most Common method of production in boat building is the open molding method and

the method employed by Crownline. The open-molding process typically consists of applying

gelcoat and resin to a mold using an air-atomized spraying device, referred to as the applicator

"gun". An open molding operation means any process in which the resin (and!or gelcoat) is applied

to the mold in an area that is open to the room in which the application is made. Open molding

includes operations in which a vacuum bag or similar cm-er is used to compress an uncured laminate

to remove air bubbles or excess resin, or to achieve a bond between a core material and" lam.in:ate.

According to EPA's definition, a mold is deftned as the cavity or surface into or onto which gelcoat,

resin and, as appropriate, glassftbers are placed and from which finished ftberglass parts take their

form. 1

Styrene is emitted both during the application stage (the time period when the applied gelcoat or

resin is atomized and sprayed onto a mold) and during the curing period (the time it takes for the

sprayed material to convert from a liquid to a polymerized solid). Other VOMs besides styrene are

also emitted during gelcoat application (mostly methyl methacrylate), but these are emitted in

signiftcantly lower amounts due to the total amount (percentage) of the'se other organic constituents

that make-up the entire mass of the as'applied gelcoat material.

Most open-molding boat-building facilities use high ventilation rates t<> ensure that styrene le\-els are

kept below the OSHA worker exposure limit established by the Occupational Safety and health

Administration (OSHA). Since the cost of add-on emission control is a strong function of the total

airflow, these diluted air streams are extremely costly to control. Some facilities designate certain

areas for gelcoat or resin spraying to reduce the contamination of plant air. In these cases, a spray

booth equipped with a dry ftIter medium may be used to reduce particulate emissions, but diluted

styrene emissions are typically vented directly to the atmosphere.2

A closed molding process is one in which pressure is used to distribute the resin through the

reinforcing fabric placed between two mold surfaces to either saturate the fabric or ftll the mold

cavity. In the boat building industry, closed molding is used far less than open molding. Closed

molding can consist of various methods including compression "molding using a sheet molding

compound, infusion molding, resin injection molding (Rl?-.l), vacuum-assisted resin transfer molding

(VARThl), resin transfer molding (RTj\l), and vacuum-assisted compression molding. The closed

molding process does not emit as much styrene as the open molding process.

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2.2 Boat Manufacturing Processes at Crownline Boats

Crownline uses rhe open molding process to manufacture its custom boats. Fiberglass boats are

manufactured in pre-formed molds. The molds are first developed and constructed in rhe mold

fabrication shop.

Aftet the molds are denlopecl, rhey ate ptepated fSt rhe application of gelcoat. The molds, as

tequired, are cleaned ,,'ith a stripping solvent and then a wax teleasing agent is applied, The molds

are then mm'ed to one of four gelcoat boorhs fat rhe application of gelcoat using sptay guns. Air.

atomized guns ate used ac Crownline. The gelcoat area has 31 gelcoat sptay guns, some of which

ate stationary, some mobile (can be moved between boorhs). Gelcoat is applied to rhe mold to

prm'ide color and a smooth surface to rhe ourside of rhe fIbetglass boats. Patticulate emissions

from the overspray of rhe spray guns are conrrolled wirh panel ftlters built into rhe booths.

After the gelcoat has dried, the molds are moved to one of twenty-fom laminating stations. At the

laminating station, glass fibers,- polyester resin and a resin catalyst were previously applied to the

mold using a spray air-atomized chopper gun. To achie,e compliance with rhe Boat l\lanufact!,lring

i\-L\CT emission srandard (described below), as of early 2003, Crownline has replaced all ofits

atomized spra" chopper guns used for resin application with flow coat guns (i.e., low pressure.,

internal mi", non-atomized choppet guns). The lamination area has twenty-four flow coat guns. A

flow coat gun simultaneousl,' chops strands of glass fibers into predetermined lengths and coats the

glass fibers wirh resin as rue resin is discharged from the gun nozzle. The flow of tesin discharged

from the gun nozzle nor onk helps to coat the "chopped" glass fiber pieces, but also to

simultaneoush' deposit the resin droplets and resin-coated fibers onto the mold surface. The layer

of fiberglass and resin is rhen rolled out by hand to remm'-e any air bubbles that are sometimes

created in spray application process. After the desired amount of material has been applied to the

mold, it is then allowed to cure (harden) for some time before another layer is applied. Additional

layers of fiberglass and resin are applied as needed per the design of the boat model being built.

\'Ii'hen the laminating process is completed (all layers ha,e been applied and allowed to sufficiently

cure), the finished solid fiberglass part is remm-ed from the mold and rransferred to the grind and

rrim area of rhe plant. _-ill emissions from the gelcoat and laminating stations are exhausted to

armosphere "ia an elaborare ,-entilation system which moves approxinnately 400,000 cubic feet of air

every minute. This air ,'emilation rate is necessary to maintain the styrene concentration level below

OSHA worker exposure protection levels, Particulate emissions are controlled with panel filters

provided on each side of and along the length of the gelcoat area.

2.3 New l\1ACT Standard and Crownline's Compliance With the Sib/hr Rule

Beginning August 23, 200-1-, Crownline, like all other boat manufacturers in the U.S., must meet the

newly promulgated l'ational Emission Standards for Hazardous Air Pollutants for Boat

Manufacturing, 40 CFR Pan: 63 Subpart VVVV, (hereafrer referred ro as the "]\IlACT"). The nile . . requires that subject boar =nufacturers meet the "]\IfACT floor", which is the emission limitations

achieved by rhe best-periorming 12% of boat manufacturers in the nation. USEPA determined that

the iYlACT floor for boat manufacturers would not be air pollution control equipment since only

one facility in the counrry uses such equipment. As discussed furrher below, by complying wirh "the

iYL-\CT standard, boat manufacturers are expected to reduce styrene emissions by an average of

36%.

1663007.3 4
3.0 VOM AND HAP EMISSION SUMl'vIARY FOR CROWNLINE BOATS

Section 3.1 sets forth the calculation methodology and resulcs for VOl\{ and HAP emissions under

three scenarios. First, Section 3.1.1 discusses hourly VO),[ emissions from Crownline's gelcoat and

resin operations prior to implementing any l'vL\CT reductions (Crownline has already implemented

the l'vL'\CT requirements). Second, Section 3.1.2 discusses the hourly VO),[ emissions from

Crownline's gelcoat and resin operations for Crownline's currem operations (i.e., in compliance with

the l'vL'>.CT emission linutations). The lvL'>.CT compliance c,-lcuhtions are presented here since one

of the conditions of the 'Petition is to comply with the Boar :'bnufacturing ;'vL'>.CT. Third,

Section 3.1.3 discusses the hourly VOM emissions from CrO\mline's gelcoat and resin operarions if

Crownline were to comply with the Boat Manufacturing i\L'>.CT and the 8 lb/hr Rule (on a strict

hourly basis). Each of these scenarios is based on using the DOS[ current boat production dara for

Crownline's operations (using actual dara from January rhru Jul,- 2003 and esuapolared dara for

August rhru December 2003 by inserting the July production and material usage dara for these last

five months of 2003). Section 3.1.4 provides a summary comparison of the three scenarios.

Section 3.2 describes the VOM en1issions from the manufacrure of the small boar parrs and from

the final assembly operations (e.g., enussions from use oflacquer, adhesives, caullr, etc.)..

3.1 Methodology for Calculating VOM Emissions from Gelcoat and Lamination

3.1.1 VOM Emissions From Resin and Gelcoat Operations Prior to MACT

Implementation

To estimate styrene emissions from t\.vo processes at Crow~'1e:. a series of calculations 'were

performed using a basic formula. The rwo processes are (1) gelcoat application to boat hulls and

decks and (2) resin application to boat hulls and decks using air-aromized chopper guns.

Specifically, the en1ission calculations consist of the following equation and input data:

En1issions = Q x Fax Fe

\V'here, Q = quantity (amount by "'eigh,) of material applied to the part

(deck or hull mold)

Fa = fraction ofmaterial, as applied, that is sryrene (i.e., the rotal

styrene content, typically referred to as the amount of "avaihble*"

styrene)

Fe = fraction of available sryrene that is en1irred as a volatile organic

afrer application to the part (Dosed on NMi\L\ en1ission factors)

*- available styrene refers to the a...:.-r.ount present in the resin or gelCOat

material as-applied and is, therefore, available to react to form the desired

produel' (in the open molding process, a significanr amount of the tl"ai/able

styrene is not reacted because it eoaporates into the building room :iir and,

eventually, is emitted to atmosphe:e (ref: verbal communication "tim 11r.

John Stelling, Stelling Engineering, :'l:i.rch 21, 2002).

Important considerarions in the processes of gelcoat and resin application that affecr the amount

and rate of VOM released per unit time are presented belo\\'.

1663007.3 5
Q, Is the quanriry of material (gelcoat and resin) used to bUild each boat part for each boat model

produced. Gelcoat is applied to the parr (hull or deck mold) in a single application (using airatomized spray guns), thereby, crearing a single initial layer. However, laminate (resin) is applied to a

part in a series oflayers called "skins". The process involves application of a skin, followed by a

curing period before the next skin can be applied. This process is repeated until all of the skins

required to achie"e the desireq thickness ha,-e been applied (allowing cure time bet:\veen the

application of each skin.

For decks, 3 resin skins are typically applied. For hulls, 2-3 resin skins are applied, followed by a

separate application to bUild the boat floor. That is, the floor contains wood "stringers" (wood

boards that act like floor joists) that are att:lched to the hull at the point where the stringer meets the

hull Goint). Each stringer joint is constructed by fustbeing covered with fiberglass cloth and then

by being saturated with resin using an air-atomized chopper gun. The time it takes to apply one .

skin of resin to a small boat (e.g., 18 - 22 feet long), takes approximately 30-35 minutes. The time it

takes to apply a skin ro a large boat (24 - 29 feet long), is approximately 45 to 55 minutes. Howe"er,

regardless of boar size, no skin takes more than an hour to be applied. Gelcoat is also applied within

less than a one-hour time frame. The application times are largely dictated by the resin "kick" time,

which is the duration of time after applicarion when the resin begins to cure and become a solid.

The amount of material applied per skin ,anes. This variability occurs ptimarily with application of

the second skin. That is, the amount of resin that is applied to create the second skin typically

requires the greatest mass of resin regardless of boat sIze. It is also important to note that the

fraction of a,-ailable styrene in both gelcoat and resin that is emitted upon application to a mold is

largely a function of parr geometry (shape) and size (boat length). It is a known fact (from NMMA

data) that, of the total styrene content in me resin as applied, the fraction of styrene that is emitted

(versus that which remains with the solidi6.ed mass that makes up the part),is greater for the

building of boat hulls than it is for the bUilding of boat decks. Again, this is due to the fact that the

conc"'e geometry of the hulls cteates a larger average distance between the resin application device

("the resin gun") and the'part. Similarly, me fmcrion of available styrene that is emitted increases as

part length increases. 1.'sing NMi'vL\ data from Tables 2-3 and 2-5 (See Appendix 4), we identified

the simplest funcrion (a line) that would nL'l wough both points plotted for percent of available

styrene emitted from the application of resin ro two different sized hulls. Interpolarion of the

fraction of a.-ailable styrene emitted from gelcoat and resin application to decks and hulls is

presented on attached Exhibits 1 and 2 ofAppendix 6.

As presented earlier, the total amount of s,:.rene in the gelcoat and resin as applied is referred to as

"available srnene". However, only a fraction of the available styrene in these two materials is

emitted because the balance reactS to fo= the solid fiberglass matrL'C of the part being bUilt. In year

2000, Crownline used gelcoat that contained approximately 43% HAP (33.4 wt-% styrene and 9.65

Wt-% methyl methacrylate (Mi'vL\)). The resins used that year contained approximately 42 wt-%

styrene. The results of the calculations for estimaring hourly YOM (styrene/Mi'vL\) emissions from

the gelcoat and resin application processes at Crownline prior to implementing i'vL\CT requirements

are presented in Exhibit 3 of Appendi..,< 6. .

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3.1.2 Emissions From Crownline's Current Operations (Compliance With the MACT

Emission Limitations)

For this scenario ~.e., Crownline's operations in compliance with the i\L\CT emission limits), the

basic compuration used to estimare styrene emissions from application of gelcoat and resin to boat

decks and hulls was modified based upon following assumptions: (1) a reduced styrene content

resin is used (35 wt-% versus 42 w[-%); (2) a reduced,HAP coment (sryrene, MlYL'\. and other

volatile organic HAPs) gelcoat is used (33 \\'[_% versus. 43.2 wt-%); and (3) non-atomized spray

(flow-coat applicators) are used. To comply with lYlliCT, most boar manufacturers with open

molding operations nationwide will use these flow-coat applicators and low-HAP resins and

geleoats.

Based on these three assumptions, the following equation and input data were used to compute the .

YOM (styrene) emissions from the resin application process:

Emissions = Q x Fax Fe x FEe

Where Q = quantity of material applied, by weight

Fa = fraction of material that is styrene, or "available" styrene

Fe = fraction ofstyrene.that e\"aporates after application to a patt

Ffc = fraction of styrene emitted from flow-coater spray gun

The following discussion addresses important factors that affecr the amount and rate of

VOlvf released per unit time in the resin application process: -

• The fracti()n of styrene emitted from resin application using .air-atomized chopper

guns was determined using the data presented in Table'2-1 from the 1997 NMMA

study report (See Appendi.." 4). As of October 2001, Crownline began using a resin

with a styrene content of 35 wt-%, or less, (versus the previously used 42 wt,%) and

the emission factors used in the calculations were an interpolation of the data'in

Table 2-1 of the N:-.rj\,L-\. study report. Forgelcoat spray guns, the emission factors

were also taken from Table 2-1.

• The fraction ofsrHene emitred from resin application using flow-coat applicators

was determined using the dara presented in Table 2-1 from the 1997 NMlYlli study.

Per the NMlvlli Study, the emission reduction that can be achieved by replacing the

air-atomized chopper guns with flow-collr (non-atomized) applicator guns is 7.8%

for decks and 27% for hulls.

Estimates of hourly YOM emissions from Crownline's gelcoar and bmination operations in ,

compliance with the lYlliCT are set forth in Exhibit 4 ofAppendix 6. The hourly YOM emission

estimates shown in Exhibit 4 of Appendi.x 6 are conservative, since they assume 100% of the styrene

is emitted in the first hour. However, according to the NlYlliL-\ Study, only 70% of the styrene

emissions occur with in the first hour, \\'hi]e the remaining 30% occur subsequently. See Figure 2-3

ofAppendix 4.

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The following table sets forth a break-down of the estimated VOM emissions from all of the

affected operations at Crownline for year 2003 (exrrapolated for August through December of 2003

using boat production and material usage data for July 2003).

Total YOM Emissions(!) Based on Crownline's Current Mode of Operation(2) - Using Year

2003 Boat Production and Material Usage Data(3) .

Emission Source YOM Emissions' (TPY)

Resin Application (Lamination) Areas 88.1

Gelcoat l'se Areas (Booths) 59.6

Subtotal 147.7

Other Areas·(where VO~1 containing materials are used) 52.1

TOTAL 199.8

(1) - Based on applicable N~L\!i\ emission factors;

(2) - Crownllne's current operations are in compliance with i\!i\CT emission standards (compliant

with emission limits computed using the i\L'\CT model point value method of compliance);

(3) - Reported values reflect level of YOM emissions assuming year 2003 boat production (number

. and model mi., produced during Jan-July of2003 and July 2003 data was used to exrrapolate

emissions for Aug-Dec of 2003);

(4) - Other areas include such operations as mold fabrication, grind & trim area (floor and stringer

installation), lacquer application, hull and deck tie-in, carpet installation and seat building (adhesive

usage), caulk application, resin storage, etc. See Section 3.2 for a more detailed discussion of these

operations and their VO~1 emissions.

3.1.3 YOM Emissions from Crownline's Operations if Crownline were to comply with the

8 lb/hr Rule on a Strict Hourly Basis.

This scenario estimates ,-OM emissions assuming that Crownline were to comply with the 8lb/hr

Rule on a strict hourly basis. This last scenario is based on a set of hypothetical conditions in order

to simulate compliance with the 8 lb/hr Rule (on a strict hourly basis) for all boat models. Under

this scenario a default value of 8 Ib/hr was artificially substimted for all boat models to estimate

what the annual level of VO\1 emissions would be if each of Crownline's gelcoat and lamination

operations (e.g., emissions from the application of each gelcoat layer and resin skin) were assumed to

equal 8 lbs/hr and, therefore, comply exactly with the limit of 8 lbs VOM/hr on a striCt hourly

basis. The calculations and assumptions used to develop the estimate of YOM emissions for this 3rd

scenario are presented in Exhibit 5 ofAppendix 6.

3.1.4 Summary Comparison of Annual YOM Emissions From Crownline's Operations For

the Three Compliance Scenarios

Table 3-1: Annual Emissions Comparison

From Crownline's Gelcoat, Lamination, and Othei1

) Production Areas For 3 Compliance

Scenarios(2)

Pre-lYlACT tvLA.CT 8lb/hr

245 200 144

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(1) - Includes VOM emissions from such production areis as Grind and Trim and Final Assembly)

(2) - Scenario 1 = Uses Y2003 Jan-July acmal boat production and material usage data and July 2003

data extrapolated for months ofAug - Dec 2003, but assumes K-\P/VOM content ofresins and

gelcoats at pre-I\L-\CT levels and use of atomized spray guns for resin application; Scenario 2 = Cses

the same boat production numbers and materials usage data and the same extrapolations as used for

Scenario 1, but uses actual K,\P/VOI\l content of materials acmall\- used during Jan-July of 2003

and actual conclition of all resin application being done using flowcoat guns; Scenario 3 =uses the

same boat production numbers and assumes that each resin and gelcoat application operation

(application of each gelcoat layer and each resin skin) emits exactly 8lb/hI. Each scenario includes'

the 2003 YOM emissions estimates from all other production areas (approximately 52 tons/yr),

As Table 3-1 clearly shows, when Crownline's gelcoat and lamination operations comply with the

I\L'\CT standard via use oflower HAP resins and gelcoat materials and installation of flowcoat

applicator guns in the resin application area, (i,e" compliance scenario 2) as shown in Exhibit 4 of

Appendix 6, Crownline will achieve significant reductions in total VOM emissions, If Crownline

were to comply exactly with the 8 lb/hr Rule on a strict hourly basis, annual YOM emissions (as

illustrated by scenario 3 presented as Exhibit 5 of Appendix 6) an adclitional reduction of ann11a1

YOM emissions would be achieved, However the third scenario is based on a hypothetical set of

conclitions that are not actually achievable without the application of emission control equipment,

As cliscussed in Section 4.3, this is not an economically feasible option,

However, ifit were technically possible for Crownline to demonstrate compliance with the 8 lb/hr

Rule on a strict hourly basis by changing the total rime frame over which each resin and gelcoat

application to each boar part is made (by applying the same total mass of resin or gelcoat, but over a

period of two Or more hours), Crownline could comply with the Rule (on a strict hourly basis), yet

emit the same total amount of VOMs on a daily (24-hr) and annual basis, That is, by extencling the

time frame over which resin skins and gelcoats are applied, VOM emissions would also be

clistributed over this longer period oftime, This hypothetical scenario would show Crownline to,

technically comply with the 8lb/hr Rule (on a strict hourly basis) but ",ithout realizing any true

reduction in total daily or annual YOM emissions, The following example helps to illustrate this

point:

Assuming an incli1ridual skin (or layer) ofresin or gelcoat (as now clictared by the no=al resin

reaction processes) takes one hour to apply and this resulrsin YOM emissions ofsay 14Ibs/hr, ifit

were possible to apply the same total mass of resin or gelcoat for an inclividual skin over a two hour

period instead ofjust one hour, the associated YOM emissions would comply with the ,8 lb/hr Rule

on a strict hourly basis (i,e,,7 lbs would be emitted in the first hour and 7 lbs in the next hour),

However, the total mass ofVOMs emitted for the entire day would be the same (14Ibs)

Consequently, compliance with the 8lb/hr Rule in this manner results in no real reduction in the

total daily or annual amounts ofVOMs emitted to atmosphere, 'This is one ofthe reasons why

Crownline believes that demonstrating compliance on a striCt hourly basis is neither practical' nor

necessary, However, by complying with the I\[ACT standard and no other measures, Crownline

achieves significant real reductions in the total amounts ofVOl\[ emitted from their operations on a

daily and annual basis,

1663007,3 9
3.2 VO]'vI Emissions from Small Boat Parts and Final Assembly

The gelcoat and bmination departments are not the only source ofVOM subject to the 8lb/hr

Rule. For each boat model, there are a number of small parts that are manufactured using the same

methods and materials as those employed for the manufacture of hulls and decks. In fInal assembly,

hulls and decks are sealed together and the small parts are installed to complete the boat. In this

assembly step, additional laminates are applied. The decks are fIrst moved to deck rigging where

carpet, headliner and upholstered patts are attached to the decks. YOM containing materials (i.e.,

adhesives and caulk) are used in this operation. From the carpet area, the hulls are then move to

engine assembly. After engine assembly, the finished decks from deck rigging are attached to the

hulls, fInal caulked and then moved to fInal assembly. The boats are then fitted with interiors and

miscellaneous hard'\vare.

Based on AEA/Crownline's calculations, some YOM emissions from Crownline's fInal assembly

operations (use of caulk/adhesive/lacquer) would not be in compliance with the 8lb/hr Rule on a

strict hourly basis. The current level ofVOM emissions from the fInal assembly operations which

exceed 81bs/hour on a strict hourly basis total approximately 14 tons/year. Data and sample .

calculations for fInal assembly area and small parts production are presented in Appendices 7 and

8, respectively.

4.0 INVESTIGATION OF COMPLIANCE ALTERNATIVES: METHODS FOR

REDUCING YOM EMISSIONS FROM BOAT MANUFACTURING

The opportunities available to the industry to reduce or avoid waste and pollution streams ate

emerging. This section presents various alternatives currently used by the fiberglass manufacturing

industry that potentially may be applied by boat builders for reducing YOM emissions from the boat

manufacturing industry. Some of these alternatives are currently in use by Crownline in order to

comply with the i\L\CT. The section is divided into three areas: 1) reduce VOMs in production

materials; 2) alternative manufacturing technologies; and 3) installation. of air pollution control

equipment.

4.1 Method 1- Reduce VOMs in production materials

Crownline has already reduced YOM emissions in its production materials. In complying with

tvIACT, Crownline has already reduced its total YOM emissions by a signifIcant amount (see Table

3-1 and Exhibit 4 of Appendix 6). The majority of the reduction has been realized by converting

to low HAP resins and gelcoats and, as discussed later in this document, by replacing the atomized

spray resin applicator guns with the flow coat guns.

Further reduction of styrene in the resins (below that needed to comply with MACT) is not feasible

because this would result in the loss of important physical characteristics of the manufactured boat

parts, thereby, significantly affecting the appearance, integrity and safety of each boat.

"Traditional" general-purpose (GP) orthophthalic polyester resins were widely used by the industry

into the early 1980's. These resins had approximately 44 - 48% styrene content by weight. By the

mid 1980's, DCPD (dicyclopentadiene) resins became popular because of cost-competitiveness and

improved cosmetics due to reduced shrinkage. DCPD blends currently have a slightly lower styrene

content. However, in 1988, rule 1162 (a South Coast Air Quality Management District VOC

1663007.3 10
regulation) required composite manufacturers located in a four county area in Southern California to

adopt resins with a styrene content no greater than 35%. The tough low profIle (TLP) resins, which

are available to meet rule 1162, have a 33.5 to 35% styrene content. Reichhold Chemical, a producer

of resins for the marine industry, indicates that the flexural fatigue properties deteriorate quickly

when styrene levels drop below 33.5%. Nevertheless, the future according to one resin supplier is

"no styrene". The styrene monomer will probably be replaced in the resin by a more

environmentally acceptable monomer. The replacement, however, will likely be more expensive and

require laminators to denlop new techniques to handle .the styrene-free resins.

Laminating with Low Styrene Resins - To reduce emissions and mm-e toward 1l.ACT

compliance Crownline voluntarily switched from 42.3 wt-% to 35 wt-% sryrene resins in midOctober of 2001. The most notable characteristic of the Imver styrene resins is the higher viscosity.·

This makes it more diffIcult for the resin to wet a surface and saturate glass fIber. Reichhold

indicates that the molding surface and glass fIber should be coated with resin and allowed to wet-out

45 s·econds before rollout to give the resin a chance to interact with the binders and surface.

Achieving good secondary bonding has also been mentioned as a problem because ofreduced

styrene b-els. This is due in part because the low styrene resin is less forgi,-ing of dust and

contaminants on the laminate surface. Therefore, more attention has to be paid to surface

preparation as well as following good wet-out procedures.

4.2 1Iethod 2 - Replace existing production methods with alternate production methods

4.2.1 Open Molding Methods 3 -

(1) Use offlowcoat chopperguns - A flow coat chopper gun is a fIberglass chopper similar

to the resin air-atomized chopper gun but equipped with a low-pressure, internal-mixed,

non-atomized resin delivery system resembling a shower head that discharges catalyzed resin

in a smooth, shower-like flow, rather than in a fIne mist-like spray that is typical of airatomized guns. The principal difference between this techniCJ.ue and conventional spray-up

application is that resin atomization is avoided. Crownline is currently using this method for

resin lamination in order to help comply with the new /lIACT standard.

(2) Use ofrollers for resin application - Like spraying systems, resin roller dispenser units

utilize a fluid pumping system to draw resins from drums or bulk distribution lines. This

pumping system also includes a separate, fully adjustable catalyst pump. These two pumps

supply the resin and catalyst to a static mixer. Since atomization is not required, resin

delivery pressures are well below 100 psi.

A study by Eastern Carolina Univerity3 noted that productivity was adversely affected and

reduced the savings realized. Other laminators have noted that the switch to resin rollers

requires some additional investment in work area design ·and handling equipment to suPPOrt

the static mi."er and supply lines. Again, Crownline's success in the mark~tplace depends on

effIcient boat production. This method will not work.

(3) Vacuum bagging- The vacuum bagging process begins with the application of a gelcoat

(using either atomized spray or flow coat) to the surface of the mold. Once the resin and

fIberglass materials are in place, the exposed area is covered by special layers of plastics,

1663007.3 11
which are sealed to the edges of the mold. Before the resin begins to cure, a vacuum is

dra\yn through one or more strategically located POrtS in the mold or the plastic cover.

For Crownline, the cost of vacuum bagging per boat would be too expensive because of the

number of different models of boats which Crownline manufactures. Also, the cost of

material to build a boat would increase substantiall)" because the plastic bags used to contain

the emissions can onl)" be used once. In add,ition, the time to build a boat will increase and

more employees will be required.

(4) Pre-preg- This technology involves taking pre-manufactured laminated sheets which are

laid into a mold to form the shape of a part. The sheets me often put into the mold,

completely enclosed in a plastic bag, heat is added and a vacuum is applied to the bag. For a

number of years fabricators of composite aircraft structures have relied on th~ use of these·

"prepreg" materials. Prepreg technology has not been used by small leisure boat

manufacturers.

Barriers to the more widespread use of prepregs include: the need for elevated temperalJJ.res,

the lack of vacuum ba&,oing experience at most fiberglass shops, the large amount ofsolid

waste from the bagging materials, which are only used once, the need for good process

control procedures, installation ,?f a refrigeration system to keep the pre-preg sheets cold

before installation to prevent premature cuting, and the longer time taken for laying down

the prepreg compared to spraying3. If Crownline used the Prepreg process, they would be

required to install a significant refrigeration system which would be unreasonable from a cost

perspective.

(5) In-house resin iInpregnation - This technology involves impregnating fiberglass cloth mat

(fed from a continuous roll) with resin by passing the cloth mat through a catalyzed resin

bath. The resin-impregnated cloth is then applied manually to the mold of the part being

produced (e.g., hull, deck, etc.).

For many fabricators, installation ofimpregnatot systemsmay require extensive modification

in the plant layout and production techniques. The units are more expensive than existing

spray applicators. Use ofimpregnators by builders ofsmall boats would appear to be

economically feasible only if the facility could be arranged so that the molds are handled in

an assembly line manner, or situated so that one machine could be easily positioned to feed a

number of molds'. As with pre-preg, this technology has not been used by leisure boat

manufacturers. It is not feasible for Crownline to make their boats in an assembly-line

manner.

(6) Controlled spraying- Controlled spraying is a work practice that is very effective in

reducingstyrene emissions from the open molding process. It is an emissions source.

reduction method, which benefits the manufacturing process, plant perso~nel, the

environment, and reduces cost. Controlled spraying reduces styrene emissions by incr.easing

material transfet efficiency through overspray minimization. There are three elements of

controlled spraying, which work together to reduce emissions: (1) operation of the spray

gun at the lowest functional fluid tip pressure which produces an acceptable spray pattern;

(2) operator training that teaches proper spray gun handling techniques; and (3) the use of

mold flanges to minimize spray off the mold edge. Crownline already employs controlled

1663007.3 12
spray application for applying gelcoat. This is accomplished through an employee training

program. Employees learn how to apply a controlled spray using various techniques learned

in this training program.

4.2.2 Clos~d Molding Methods J -

(7) RTil:f- Resin transfer' molding (RTi\1) is a pr9cess that begins with the application of a

gelcoat to one or both sides of the mold, depending on requirements. Glass reinforcing and

other materials, such as core stock, "re placed in the bottom-half of the mold. The mold

halves are closed and securely' clamped. After the mold is closed, catalyzed resin is injected

through one or more strategically located ports. Inlet ports and vents are normally located in

the top half of the mold.

Crownline has determ.ined that RTM is not feasible at their facility because the boat product

is too sensitive to damage during manufacture resulting in the scraping of numerous

damaged parts. Finally, retooling costs could be 20 times the current cost of conventional

tooling.

(8) Resin infusion - Resin infusion shares many of the characteristics of vacuum bag molding

and resin transfer molding (RThI) but is based on a patented resin distribution process. To

use the process lam.inators must acquire a license to use the patents and pay for training

covering some proprietary techniques. ""s withRThl, the costs of this process are expensive

due to increased labor and materials costs as well as increased facility, machinery and tooling

costs. For these reasons, Crownline does not feel that this technology will work at their

facility.

(9) VEC System - VEC Technology Description

At the request'ofIEPA, Crownline has in,-estigated a new technOlogy that is called VEC or

Virtual Engineered Composites. Genmar, Inc., a boat manufacturer, headquartered in

i\linnesota purchased this technology. IEPA has recommended this technology because it

believes that this technology can significandy reduce styrene emissions. A brief description

of the VEC Technology is included in this section but a more detailed one is found ill

Appendix 9.

TheVEC technology is a complex, patented, computerized system that manages the entire

injection molding process, including all equipment operations and the curing of resins. It

controls the elements of the process to elim.inate inconsistencies in the finished product.

The 'VEC process involves a patented flexible mold system: This system uses a thin

composite skin in the shape of the part to be produced that's mounted on a water-filled

pressure vessel, creating a low-pressure, closed-mold process. 4 .

Here are some other basic facts about the VEC Technology 4:

• Protected by 31 Patents

• Most boat building companies are either too small to take advantage of the system,

or are already wedded to other processes that would be too expensive to scrap

1663007.3 13
• Recendy opened an 8,835 m2 VEC boat bUilding facility - $22 million for equipment

and materials in the plant

• Level ofinvestment is far greater than the cost to get an open-mold boat building

operatlOn going

• Not good for building customized larger boats

Crownline has cOntactedGenmar and VEC technology owners to determine if it is possible

to implement the VEC technology at our Cr9wnline facility. The main issue tl:at Genmar is

dealing with conceming \'EC technology is whether they should license this technology to .

its competition. Genmar is promoting the licensing of the VEC technology to

manufacturers of Fiberglass Reinforced Plastic products other than boat builders. Genmar's

management does not believe it makes sense for them to license it to their competitors in

the boat building industr,.

In summary, the VEC technology appears to allow certain types of boats to be produced

with significandy reduced VOM (styrene) emissions. However, the initial capital cost of a

VEC system is extremely high when compared to traditional open molding manufactur0g

methods and equipment. _-\.150, since Genmar owns the patents for this technology and is

not willing to license it to their competitors in the boat manufacturing industry, it cannot be

considered a viable alternative regardless ofits ability to produce boat parts while

significandy reducing VO:\I emissions. -

4.2.3 Evaluation of Fiberglass Reinforced Plastic Manufacturing Technologies For

Application at Crownline Boats

For purposes of e,-aluating the fiberglass reinforced plastic (FRP) manufacturing technologies for

applicability to Crownline Boats' rrunufacturing operations, the variou;alternative production

methods listed above fall into one or more of three categories of reasons that define why these FRP

product manufacturing technologies cannot be practically applied at Ctownline. These three

categories are:

A. Prohibitively high re-tooling cost;

B. Would require Crownline to completely change irs production methods resulting in

drastically reduced production efficiency, thereby, requiring a far greater number oflabor

hours to complete the hull and deck of each boat. This would increase manufacturing costs

beyond that which could be recovered competitively in the price of the boat;

C. Significant loss of future sales caused by (a) diminished product quality (appearance,

perfo=ance, reliability, etc.); and/or (b) inability to produce the variety (broad number of

models and sizes) of boats that Crownline now has the ability to produce on a regular basis.

The following table identifies which of these three categories apply to each of the listed alternative

technologies. -

1663007.3

Category A

14

Category B Category C
Technology

Open Moldin? Methods

(1) Flow coat resin applicators - -

(2) Controlled sprayin?; - -T

(3) Roller Application - -..j -..j

(4) Prepre?; . 'i 'i -..j

(5) In-house resin impre?;nation -..j , -..j 'i

(6) Vacuum ba,~aing - ;J 'i

Closed Moldin" Methods

(7) Resin Infusion ;J ;J 'i

(8) RTM ;J ;J ;J

(9) VEC System ;JT T T

T - The VEC System is a proprietalY methodology owned by the Genmar Corporation and is only

available to non-competing fiberglass manufacturing companies ,-ia license from Genmar (not -

available to Crownline or any other boat manufacturer),

Please note, however, that the installation of flow coat chopper guns (under open molding methods)

and reducing gelcoat VOM content are both viable methods that can and are being used by

Crownline Boats to comply with t,L'\CT. Similarly, Crownline already switched to low styrene resins

(early in the Fall of 2001). Also, Crownline employs controlled spraying in its gelcoat operations.

This allows Crownline to reduce material usage, improve product quality and, concomitantly, reduce

styrene ermSSlOns.

The cost of each altemate manufacturing method aside, it is important to hote that, other than for

resin application using air-atomized chopper guns or flowcoat chopper'gun guns, there is no

quantitative data that we know of which accurately shows how much Styrene and/or VOM

emissions would actually be reduced if any of these methods were to be employed. The new

(NiYlliIA) emissions factors are based on carefully conducted emissions tests. But, these were

limited to the testing ofstyrene emissions from those facilities that use air-atomized chopper guns

and flow coat chopper guns for resin application. Therefore, even if Crownline could afford to

modify its plant to employ another manufacturing technology, there would be no assurance that this

would meet the Slb/hr Rule on a strict hourly basis as interpreted by IEPA.

Finally, all of the above-listed manufacturing methods are limited to the resin application process.

To our knowledge, there'are no gelcoat application technologies that could be feasibly employed to

reduce styrene/VOM emissions from Crownline's gelcoating operations except low-HAP gelcoats.

In summary, information on the use of altemate manufacturing methods/technologies strongly

suggests that, other than converting to flow coat chopper guns for resin application and reducing the

HAP content of the gelcoats to the 33% iYL'\CT compliance level (which Crownline has done),

respecti,-ely, there are no altemative manufacturing methods/technologies that can be used by

Crownline to comply with the Slb/hr Rule on a strict hourly basis.

4.3 Method 3 - VOC Reduction Through the Application oETail-End Emission Control

Equipment

1663007.3 15
4.3.1 Evaluation ofTail-End Emission Control Equipment For Purposes of MACT

Compliance

In developing the Boat Manufacturing NES!-L\P, USEPi'\. had a number ofstudies performed to

evalmte a variety of emission control technologies. The studies were done for the possibility of

serving as'the l\L\CT floor for ,I-LA.P emission reduction, The results of one such study are

presented in the report tided, ':AJSeJJI71ent ofSIyrene EJ11ission ControlJfor FRP/ C and Boat Building

InduJtn'eJ" EPA Contract 68-D1-0118, \Y/.A. 156, As 'a result of these studies, USEPA concluded

that none ofthe technologies should serve as the ]\,L\CT floor. USEPA concluded this based on the

following primary factors 2:

• Lf7ith one partial exception, no hoat mamladurers currentlY employ ClIIJ tailstack emission tontrol technologies to

redllt:e H-4.P emissions;

• The very high airflows needed byfadlities to tomply tvith OSHA'J requirement to maintain worker 8-hr

expoJ1Ire levelsfor JI)'rene make the tOJt ofemission controlsystems very high;

• &duttioJl ofH-4.P content ofresins, gelcoat and other matenals are achievable and can significantly redJlt, total

H-4.P emiJJionJ withoutplating an und1lefinandal b1lrden on the boat mamlactttn'ng ind1lstry. .

Having been an actively involved stakeholder in the lvLACT development process, Crownline agrees

with USEPA's conclusion. To arrive at their conclusion, USEPA examined a number ofVOC

control technologies. These included the following types of controls:

1. PreconcentratOr (both fluidized bed and rotary designs) with RTO Oxidation;

2. Catalytic Oxidation (with 0% heat recovery);

3. Condenser;

4. Carbon and polymer-based adsorption systems;

5. Thermal Oxidizer (with 0% heat recovery); and

6. Biofiltration.

4.3.2 Evaluation ofTail-End Emission Control Equipment For Specific Application to

Crownline's Operations

At Crownline's request, _-'lEA reviewed the applicability of these VOC emission control

technologies, taking into account physical and operational constraints specific to Crownline's

production facility. By doing so, AEA quickly narrowed the list of potential control technologies

from the six categories listed above to only oxidation using an RTO preceded by a pre-concentrator

system (to reduce total airflow that must be treated by the RTO); and biofiltration. AEA eliminated

the other control systems from further consideration for three primary reasons. These are, (1) the

very high air flow rate that would have to be treated from Crownline's operations (400,000 cErn - if

only the ventilation air from the gelcoat and lamination production areas were treated and possibly

as much as 654,000 cfm - if the ventilation air is also treated from the final assembly and other areas

where YOM-containing materials are used in significant amounts); (2) the low con~entration of

VOC's that would be present in the high volume air stream ~ess than 25 ppm); and (3) the presence

of particulate matter from overspray in the gelcoat and lamination areas that would contaminate.

certain control systems (e.g., carbon or polymer adsorption systems). The following discussion

describes how these three factors allowed AEA to justify eliminating certain control technologies

from further consideration for application to Crownline's operations.

1663007.3 16
A strict condenser system is neither technologically nor economically feasible for high flow, low

VOC concentration, air streams especially those that contain mL"ed solvents. Also, the VOCs in the

air stream to be treated would contain a variety of organic HAPs that could not be easily separated

for re-use. That is, the YOM emissions from the gelcoat area contain both MMA as well as styrene

and the YOM emissions from the flnal assembly area contain numerous other organics (such as

acetone). Condensers are typically used for applical>ions with low volume and high YOM

concentration air flow streams that consist of one cir two, easily recoverable and recyclable solvents.

Therefore, due to the high flow rate, low VOC concentration and the mL"ture of organics in the air

stream that would need to be treated from Crown!ine's boat production operations, a condenser

system is not a feasible control for Crownline.

A straight thermal oxidizer is not economically feasible due to the extremely high operating cost that

would result from heating 654,000 cfm of air to achieve the required destruction temperature of .

14500 F (very high fuel usage needed to attain operating temperatures high enough to thermally

convert the VOCs to C02 and water ,-apor).

. The presence of PM in the ventilation air stream to be treated would contaminate any of the carbon

or polymer-based absorption media unless a high efficiency particulate matter control system wer,

also installed. The additional cost of such a system makes any ofthe adsorption systems

economically infeasible.

Crown!ine's consultant, AEA, examined available emission control technologies for specific

applicability to Crown!ine's operations for purposes of complying with the 8 lb/hr Rule on a strict

hourly basis. This included obtaining cosr quotes from a select number of control system suppliers.

The vendor quotes were inserted into a spreadsheet developed by USEP.1-. USEPA's spreadsheet

was used in support of the study titled, "Assessment ofStyrene Emission Controls for FRP/C

andBoat Building Industries". The spreadsheet was downloaded from USEPA's website.

A cost per ton of pollutant removed was calculated for a rate of 654,000 cfm which includes

lamination and gelcoat areas and all other areas where YOM materials are used in significant

amounts. The results of the cost/ton estimates using the USEPA spreadsheet are summarized in

Table 4-1 which shows a comparison ofselected YOM emission control systems evaluated by

AEA.

As can be seen from Table 4-1, the cost per ton of controlled YOM for treating the air flow from

Crown!ine's operations ranges from approximately $35;000 to $58,000. Copies of the spreadsheets

used to compute these cost/ton ,-alues are presented in Exhibit 4 of AppendLx 6. These values

also assume a control efficiency of only 85% which is the level required to comply with the 8

lb/hour Rule on a strict hourly basis (35 IAC 215.302 (a), (b) or (c).

The up-front capital costs for the control technologies shown in Table 4-1 range from

approximately $ 7 million to $14 million and annualized cost for these same control technologies

range from approximately $4.5 million to nearly $6 million. The spreadsheets used to generate the

values presented in Table 4-1 are presented in Appendix 10. Copies of vendor quotes and related

information are located in Appendices 11-15.

1663007.3 17
Based upon these costs and the cost per ton values generated using the USEP},. spreadsheet, it is

reasonable to conclude that the installation of emission controls for Crownline's operations is not

economically feasible. It would not allow Crownline to remain competitive in a market where

CrownIine's competition operating outside of Illinois would not have to install such controls. As a

result, tail-end controls are not a feasible option regardless of which technology one may choose to

apply.

The primary reason for these high costs is the very large volume of air (654,000 cfm) that '\"ould

have to be treated in order to reduce the emitted VOM from these areas to achie\"e compliance with

the 8 lb/hour Rule on a strict hourly basis. This large volume of air is necessary to maintain

compliance with aSK-\.'s 8-hour worker exposure limit for styrene. In order to protect worker

health and safety in accordance with this OSHA requirement, approximately two years ago

Crownline installed a specially designed air flow management system. It is important to note that

this design took into account the feasibility of using methods to limit (reduce) the amount of air

needed to comply with the aSK-\. styrene standard. It was concluded, however, that to do so would

require CrownIine to dramatically re"ise its manufacturing methods and procedures. The cost of

these changes was found to be prohibitive. That is, besides the capital cost of the physical "

modifications, increased labor cOStS associated with the greater amount of time required to build

each boat hull and deck would go far beyond that which Crownline could competiti\"ely recover in

the price of the boat.

In summary, the application of tailstlck emission controls is not a viable method for reducing VOM

emissions in order to comply with the 8 Ib/hr Rule on a strict hourly basis. The ptimary basis for

this conclusion is the prohibitively high cost of such controls as a result of the high air ,"olumes

required to comply with the aSH..-\ 8-hour worker exposure limit for styrene.

1663007.3 18
TABLE 4-1

Crownline Control Technology Evaluation

Cost Per Ton ofVOM Removed ,

,

Cost Per Ton ofVOM

Control Technology Name & Vendor Removed

(For a flow rate of 654,000 cfin)

Preconcentrator with RTO Oxidation - Frees Quote 538,302

Rotary Concentrator with RTO Oxidation - MegTec Quote 534,917

Rotary Concentrator with RTO Oxidation - Durr Quote 538,973

Biofiltration System - BioRem Quote 545,318

Biofiltration System - BacTee Quote 558,166

Notes:

1. All cost estimates are based on spreadsheet created by USEP_A. as part of their srody "Assessment of

Styrene Emission Controls for FRP/C and Boat Building Industries" .

2. The equipment costs have been modified based on vendor quotes specific to Crownline's facility.

They have been scaled up based on the original quotes for 300,000 cfm to tow of 654,000 cfm)

3. S/ton are based on 85% control efficiency for each device

4. $/ton are based on Y2000 dollars .

5. Baseline YOM levels used in spreadsheet assume the NIACT compliance values for gelcoat, lamination

and final assembly emissions.

1663007.2
5.0 QUANTITATIVE AND QUALITATIVE IMPACT OF CROWNLINE'S

OPERATIONS ON AMBIENT AIR QUALITY

This Section presents a discussion of the impacts that Crownline's current operation has on the'

ozone formation in south-central Illinois. Based on compliance with the adjusted standard, as

opposed to complying with th.e rule of general applicability, it appears that the impact on ambient air

quality of VOM emissions from Crownline's operatipns is insignificant - does not cause any

measurable increase in the obser.ed ozone levels in south-central Illinois.

5.1 Description of Ozone Impact Analyses

The Ambient Air Quality (.-\..AQ) Impact Analysis was performed by .-\d\""ance Environmental

Associates (,-\EA), Crownline's air compliance consultant. This analysis examined Crownline's

impact on ozone formation in south central Illinois, using data from an ozone monitor located in

Dale, (Hamilton County5), Illinois (henceforth referred to as the "Dale monitor") as a basis. The

Dale monitor is located 25 miles ENE of the Crownline facility and is otherwise sited in a location

appropriate for determining impacts of Crownline's operations on outdoor ambient ozone levels. It

should be noted that the IEPA monitor was sited in its present location for reasons not related to

Crownline or any ofits operations.

The analysis, which is quantitative in nature, was performed by AE.-\ using a method developed by

USEPA. This method is tided, "VOC/NO, Point Source Screening Tables" by Richard D. Scheffe,

September 19886 For purposes ofthis report, it is referred to as the "Ozone Screening Method".

A copy of the substantive sections of this method is presented in Appendix 16.

The Ozone Screening Method is based on examining the short term (24hr) maximum amount of

VOCs and also the average annual amounts of both VOCs and NO, that the source in question

emits. Using this information, the method requires a computation to that establishes a reference

value for subsequent use in either of two tables that estimate the amount of ozone lil<ely to be

formed for different reference values. One table is designed for addressing impacts from sources

located in rural areas only and the other table is for sources in urban areas. This procedure produces

an ambient air quality ozone concentration value that is then added to the background air quality

levels measured at an ozone monitor considered to be representative of the area that can be

impacted by the VOC/NO, emissions from the source ofinterest. This combined value is then

compared to the National ,-\mbient Air Quality Standard (NMQS) for ozone (I-hour standard) of

0.12 ppm to determine if the impact will cause (or contributed significandy enough) to the

exceedance of this I-hour ozone standard.

After computing the amount of ozone predicted by the Ozone Screening Method, the results show

that the potential impact from Crownline's operations will not cause ozone concentrations at the

Dale monitor to exceed the NAAQS of 0.12 ppm. The maximum le\-el of ozone that the Ozone

Screening Method produced is 0.103 ppm (0.01 ppm contributed by Crownline plus 0.093 ppmthe 4th highest ozone level measured at the Dale monitor during 1999, 2000, and 2001 from data.

provided in Illinois EPA monitoring reports corresponding to these three years). A copy of the

calculations performed and assumptions used by AEA following the Ozone Screening Method ~e

presented in Appendix 16 to this document. .

1663007.2
REFERENCES

1. 40 CFR 63 Subpart VVVV - National Emission Standards for Hazardous Air Pollutants

for Boat Manufacturing - FR Vol. 66, No. 163 - Wednesday, August 22, 2001, Pgs 44232-

44250

2. "Assessment of Styrene Emission Controls for the FRP/C and Boat Building

Industries" EPA Contract 68-DI-0118, \VA. 156

3. "\V'aste Reduction Strategies for Fiberglass Fabricators", by D",-id Hillis and Darryl

Davis of Eastern Carolina University, which is posted on the Pacific Northwest Pollution

Prevention Resource Center website, Seattle, W/A (pPRC \Veb site is a joint project of the

\'<;'ashington State Department of Ecology and the Small Business Assistance Programs in

Alaska, Idaho, Oregon and Washington and is funded by grants from the U.S. Environ.rnental

Protection Agency.) Some of the descriptions in the Supporting document are from suppliers

and vendors of the technologies.

4. ''Virtual Engineered Composites: The Future ofFiberglass Manufacturing" - Genmar

Corporation \.vebsite - \V\v\v.geIunar.coln

5. Hamilton County Illinois Ozone Data, 1999-2000 - data obtained from rEPA - Bob

Swinford, Monitoring Section on August 15, 2001.

6. "Ozone Screening Method - "VOC/NOx Point Source Screening Tables" by Richard D.

Scheffe, September 1988.

1663007.3 21
Appendix 1

Background on Crowriline's History, Products

And Production Methods
"Ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page 1 of

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DECKBOATS

owners' dub rally about c.rownline glossary store

238 DB - 23' 7" Deck Boat

Private portable head enclosure with light, electric vent. openable screened port light· Galley with

sink and enclosed trash bin· Four speaker Sony stereo system with CD player· Insulated 25

Quart Igloo cooler' Anchor and rope locker· 10 gallon fresh water system

239 DB - 23' 7" Deck Boat

Open floor plan' Wraparound windshield' Plenty of storage space' SAS buckets with adjustable

driver seat height· Full helm instrumentation' Triple stepAhru areas at bow, starboard and

transom' Enclosed, lIght-equlpped head' Cockpit wet bar

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CUOOI ES

Model

owners' club rally about c.rownline glossary store

Photos

215 CCR - 21' 1" Cuddy Cabin

Fiberglass-lined cockpit· Two SAS flip-up bucket seats· Snap-in Berber carpeting' Cabin

galley' Privacy head compartment· Walk·thru transom' Step-up co'.·.· access' Extended swim

platform' Hidden stainless telescoping boarding ladder

230 CCR - 23' 0" Cuddy Cabin

Lots of cockpit and cabin room' Loads of standard features' V·

berth/seeting • Cushions' Courtesy lights with adjustable lighting' Gailey with slnk • Privacy

,head' Fresh water holding lank· Easily accessed cooler' Lots of storage room' Extended swim

platform

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'ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowridcrs :Pageloi

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CRUISERS

Model

owners' dub rally about crownlinE: glossary storE:

Photos

242 CR - 24' 1" Cruiser

OvemighUng, island hopping, Intercoastal cruising' Lots of cockpit and cabin spa.ce • On-board

features for easy summertime living Dual helm seats· Additional port side cockpit seating' Lshaped bench over engine compartment· Extended swim platform' Completely comfortable cabin

area

262 CR - 25' 10" Cruiser

Spadous deck and cabin areas' Premium Sony stereo with CD player and four

speakers' Extended swim platform with hidden stainless telescoping ladder' Two clothes

lockers· Cockpit cooler with drain· Privacy Curtains' Choice of designer fabrics

290 CR - 28' 11" Cruiser

Top of the line' Nothing Is sacrificed' Spadous deck and cabin areas' Full compartment of

necessities and amenities· Hull and powerplant designed for performance· Comfort and

convenience galore' Cockpit galley with wet bar • Compass and depth sounder· Roomy berth

amidships· US Coast Guard Approved· NIMMA Certified· Member of the ABYC

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Page 1 of

BOWRIDERS

owners' dub rally about. c:rownline . glossary stor~

Model

180 BR . 18' 0" BO\vrider

Loads of leg room ,and sto-rage • Adjustable bucket seats for pnot and navigator' Full

instrumentaUon • Smooth-handling reck-and-pinion steering' Sony Marine stereo with disc

player' Removable 25-quart cooler' Sunbrella canvas and full fiberglass bow I1ner

192 BR· 19' 1" Bowrider

Choice of 3 interior layouts· Dual SAS flip-up buckets at the helm· Ufetime warranted dash and

instruments· Anchor storage' Courtesy lights' Tinted wlndshield • Stainless foldIng

ladder' Walk-thru curtain' Lots of storage space· Lockable ski compartment and glove box

202 BR . 20' 2" Bowrider

NS'Nly designed upholstery pattern' Choice bf 3 interlor layouts' Sleek design and perfonnance

capab1l1ty· Impressive list of standard equipment· Just right for swimming, Iishing, sunning or just

plain wateHomping

202 LPX • 20' 2" Bowrider low~profi1e LPX pizazz version of the popular 202 BR • NI~blacl<, fully instrumented helm' NIblack passenger cockpit console· Smoked plexiglass wrap-around windshield' Stainless steel

recessed dockIng l1ghts a'nd rub-rail Insert • Checkerboard pattem side trim

210 BR . 20' 4" Bowrider

Room to enjoy all the pleasures of sport boating' All the Crownline conveniences' Walk-thru

transom' Swim platform' Two seating oplions • Full lifetime warranted Farie-gauged

instrumentation "

225 BR . 22' 5" Bowrider

Affordable family boat with flair - Fully Instrumented helm· Choice of 3 layouts with comfortable

seating and convenient storage' Swim platfonn' Open bow' Hidden stainless steel swim

ladder· New upholstery pattem in 34 ounce Nautolex marine vinyl

225 LPX - 22' 5" Bowrider

low-profile LPX pizazz version of the populer 225 BR • AJI-black. fully instrumented helm - AJI~

black passenger cockpit console - Smoked plexiglass wrap-around windshield' Stainless steel

recessed docking lig~ts and rub·rall Insert • Checkerboard pattem side trim

230 BR· 23' 0" Bov,rider

L-shaped interior layout with 2 SAS fHp-up buckets· Recessed cockpit doors W8lk~thru

windshield· Loads of weVdry storage' Wet bar' 1()..gallon fresh water system - Ughted portable

head with sink' 12V receptacle' Spaclous deck· Built-in swim platform· Ski towrall

266 BR . 26' 6" Bowrider

Gregarious giant with a fun-lovlng personality· Loads of standard features' Optlonal fill-in

cushions convert bow Into huge playpen' Vinyl small items storage bag and mesh damp Items

storage bag' Portable head compartment· Helm storage area

270 BR . 26' 1" Bowrider

Our newest model· Sleek and nimble' Quality components· Cockpit table and wet bar· 20-gallon

fresh water system - Two bullt~in coolers and a 25-quart portable cooler' Portable tonet enclosure

wlth en electric light, vent and sink

288 BR - 28' 8" Bowrider

Adjustable double helm seat· Full instrumentation with compass - Courtesy and compartment

lights - Cockpit wet bar' 12V refrigerator' Entlosed head with holding tank and"dock-slde pump·

out· Pressurized water system - Depth sounder' Two fire extlngulshers • C01 detector

Photos

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.Page 1 of·

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ABOUT CROWNlINE

about c.rownline glossary stOff.:

HISTORY

The first Crownlines were built in a very small manufacturing facility located in Whittington, Illinois. The upholstery shop

was situated separately in a vacant grade school gymnasium. The first boat produced, a 182BR, rolled off the line on

March 25, 1991. At that time Crownline employed less than 25 people and had yet to sign a definitive dealer.

By July 1991, Crownline had grown out of its Whittington location

and was forced to find a larger facility. The building used by the

Mark Twain Boat Company in West Frankfort, Illinois had recently

been vacated and Crownline chose this location for its next

temporary home. Three and a half years later, in December of

1994, Crownline's new, state-of-the-art boat manufacturing·plant.

was completed. This permanent facility was designed for better

production efficiency and additional capacity for increased

production requirements, allowing Crownline to continue its

phenomenal grow1h.

Since its begi~ning, Crownline has successfully introduced 34

dlfferent models ranging from a 17'6" open bow to a 33' cabin

cruiser. At present, Crownline has produced and shipped over

30,000 boats to dealers world-wide. Crownline's professional

dealer network consists of 150 marine establishments in the United

States, Canada, Europe, South America and most recently, .

Russia.

The company celebrates its 30.000 boat out the door.

In addition to making an impact in the marine industry, Crownline
ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders

has also positively affected the local economy, and with over 500

full-time personnel, is one of the largest employers in Southern

Illinois.

Page 2 of

MAN."-.G=MENT

<RO";'tNt..INE'S

HANAGEHENT TEolIH

Tim Cl:r.xton

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QUALITY FROM

THE INSIDE OUT

Crownline Boats, Inc. is a family-owned pleasure boat

manufacturer located in West Frankfort,lliinois. Founded and

incorporated in 1990 by the Claxton family, the ten year old

company is one of the fastest growing independently owned boat

manufacturers in the industry.

The boating business is no stranger to the Claxton family who has

logged over 40 years of successful boat manufacturing experience.·

Fred Claxton began his boat manufacturing career over 25 years

ago as an executive of one of the premier boat companies of that

era. After several years of successful service, he left this

established concern to create his own company. He built this

fiedgling new company into one of the marine industry's 'Top Ten"

in twelve short years. This company was sold several years agel

but the Claxton legacy endures with the inception and continuing

success of Crownline Boats.

The Claxton reputation immediately attracted several key

production managers who were instrumental in recruiting the

"cream of the crop" of Southern Illinois boat builders. These select

individuals have used their skiJIs and dedication to produce boats

of the highest quality which has been a major factor in Crownline's

success.

Original Company Philosophy

_ Design a boat that produces optinWrT1

performance

_ Set the standard with unique, contemporary

style that catches and holds the discerning eye.

_ Build it with the best materials and most skilled

boat builders available. '

_ Include in it the standard features the

experienced boater needs and wants.

_ Offer it at a price that even the first-time boater

can afford.

In ten short years, Crownline has grown into a

major international boat company with dealerships

throughout North America and as far away as

Russia. How? By giving you Virtually unlimited

choices as to how your boat is equipped and
'::>wnline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders

styled and by building boats with uncompromising

attention to details such as the ones illustrated

here.

Page 3 of 4

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The Inside Story. From the respected names of

the company's suppliers - Faria, PPG, Sony,

GenCorp - to the premium grade materials such

as Armorcote gelcoat and Sunbrella canvas,

Crownline gives you all the best. But even more

important to the company's success are people

like these, experienced and dedicated specialists

who know boat-building inside and out.

To contact us electronically, click on "contact" in the navigation bar at the top of your

browser screen. To reach us through phone, fax or mail:

Crownline Boats, Inc.

11884 Country Club Road
'ownline Boats' Sport Boats, Fishing Boats, Cruisers, Cuddys. Runabouts, Bowriders Page 4 0'

West Frankfort, IL 62896

618-937-6426 phone

618-937-2277 fax

GopY.right 2003 Crownllne Boats.
ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, BOWTiders Page 1 of2

owners' dub rally about crownlin£: glossary stOfE:

:ld a Dealer: IZip

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ABOUT CROWNLINE

THE CROWNLINE WAY OF BUILDING BOAT::;

At Crownline we know what

boaters want first and foremost: A

totally seaworthy craft they can

depend on. Then they want that

craft fitted to meet their needs

whether bowrider, deck boat,

cuddy or cruiser. And we give

them what they ask for by

beginning with flawless glass masters from which

individual hull and deck molds are made. Each master

Is painstakingly crafted to zero tolerance perfection

because the slightest ftaw would appear In every mold

and then be repeated In the final form.

The molds themselves are as meticulously prepared as the masters and as painstakingly cared for.

Deck molds are re-waxed after three forms are pUlled and hull molds after every four (these pulls are

called rotations). After every four rotations, the molds are stripped to their bare surface then re-waxed

to assure a ftawless exterior surface on each boat and no hidden structural ftaws. This is a program

notall boat builders follow. Masters, molds and forms are all prepared In a filtered, carefUlly controlled

environment, free of any minute alrbome particles.

In building the forms, Buffback gelcoat Is used below the

water line to provide blister resistance and Armorcote above the wateriine for

color-fastness. The overall result: Crownline's superior exterior finish in a wide

range of colors, including the difficult-te-produce deep hues many builders shy

away from.

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Following the gelcoat application, two vinylester.barrier coats are added for

further protection against blistering. laminates are then skillfully hand-applied

by experienced professionals according to the specifications for each model.

Pre-formed .

stringers of 100% XL-treated plywood are set in place in the

bottom of the newly formed hull. Encapsulated in fiberglass,

this system is warranted for Iffe. A fiberglass liner is then

affixed atop the stringers to form Crownline's fully insulated

and double-reinforced hull, unique within the Industry. Thafs

how the Crownline way of building boats begins. Form and

function start here and quality is built in as construction

progresses.

-c
line Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page 2 of 2

.)

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, ".

\

To enhance cockpit appearance, attractive, durable

28-ounce carpeting is seamless~' installed in one

piece. It is rubber-backed to hasten evaporation, Is mold, mildewand stainresistant and guaranteed to be UV-resistant for up to 3,000 hours.

OUf quality standards continue by gr..ing our

owners what they ask for, not in the ',',ay of

options, but as standard equipment. Tne concept·

is simple: By Including our most popular options

as standard, we're able to reduce their cost by

Increasing the volume of these popular

components installed on our boats. And all Crownline standard equipment is certified by

the National Marine Manufacturers Association for premium quality assurance. Every

boat we build over 19 feet is equipped with oUr shock absorbing bucket seat at the helm

(two on some models). There's also a tiit steering wheel, Sony stereo/CD souna system

Ind stand-up Bimini top. We also include chrome-aver-brass thru-huii fillings. pull-up midship cleats, and a solid brass

Iraln plug. Bow rails are crafted from 1-inch welded stainless steel, as is the.stem-mounted

ail with ski-tow-eye. Our deluxe middle deck band gel coat pattems is also standard. And all

models 20 feet and over come \',ith a full fiberglass

Ii.ner and snap-In carpeting.

Seat, bench and cushion upholstery, which is warrantied for 5 years against manufacturer

defects, is covered with a soft, supple 34-ounce heavyweight vinyl v,ith a tear-strength that

exceeds Industry standards by better than 20 percent.

But you're not limited to our· choices of materials or colors.

There's lots more for you to choose from in gel coat colors,

fabrics, vinyl. Even nub rails come in your choice of stainless

__ - -"--- steel or composite. --'

·-3

'"

But we understand the importance of individual preferences and thafs why we've

made available a full array of optional equipment that will let you custcmize your

own boat. From canvas, vinyl, instrumentation, trim; from cockpit to cabin,

Crownline lefs you do your way. You can also

choose from an assortment of performance

packages, entertainment systems. water

systems, and more. And whatever your optional

choices, tbe materials and equipfT,ent are NMMAcertified-your assurance of quality with the added

bonus of Crownline's enviable reputation of

complete customer satisfaction throu<:;hout your

entire ownership experience.

9.Q.QYl!9,1J~ © 2003 Crownllne Boats.

,.,', :.-

12/2/2003
'wnline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page I of 3

owners" dub rally about crownline glossary store

d a Dealer.!ZiP

mIIII....1:!lmI

ABOUT CROWNLINE

THE CROWNLINE COMMITMENT

Crownline was established nearly a dozen years ago on three

very simple and practical principles that from that time on

became a Crownline way of life.

• Build stem-drive sport boats of the h"ghest possible quality.

• Provide buyers with the fiexibility to customize these boats to

their individual tastes with an abundant offering of interior,

exterior, electronic and mechanical options.

• Bring these boats to the marketplace at very competitive

prices.

In living by these principles, we have gone from our start-up to

become one of the largest builders of stem-drive sport boats in

the industry. Reaching this level of excellence has taken the skill of our loyal and dedicated employees, the enthusiasm

and professionalism of our dealers and the disceming product-acceptance of our customers.

Now, with the introduction of our 2003 models and the first of our new

generation of boats, the 270 BR, we launch a new era in our brief, but

highly successful history in the boat-building business. Crownline is

now committed to becoming the "best in class", not only with our

products. but throughout our entire business operation. This

commitment is to our customers, our employees, and our dealers.

And, it is a commitment we promise to keep because we know that

our company will grow and prosper only in.direct proportion to our

manufacturing excellence and the health of these relationships.

Our Customers

OUf customers are the reason

we are In business, and we are

committed to their total

satisfaction during and after the

sale. The entire focus of our

business is to meet and exceed

customer expectations

throughout their entire

ownership experience.

As part of our customer

satisfaction efforts, we will. be

expanding our support of

regional ·Crowndezvous· where Crownline owners gather to enjoy assorted boating activities and to meet with Crownline

sales and marketing personnel.

We are also committed to the enhancement of our existing 'Owners' Forum" that wlll allow Crownline owners to talk about

their boats to each other as well as to prospective owners all across the country.
ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders

Crownline is determined to be the best in the business and to do whatever it takes to achieve this objective. To this end

we declare to our customers and to our prospective customers that:

• We will never deliver anything less than top quality products that represent "Best in Class" value.

• We are committed to paying attention to every painstaking detail in building our boats and in servicing our customers

because thars how great companies are separated from good companies.

• We want each of our customers to know that we take their business, tnust and loyalty very seriously. And that every day

we strive to exceed their e~pectations of the total Crownline ownership experience. ,

Our People

We are committed to providing our people with a safe and enjoyable ,,,%,_. ';::<il"i?\'·

WOrking environment, where their ideas, opinions, suggestions and rij7t~ 1 ~~ i.

recommendations for improving our products and their workplace are taken ~~~.,. " :.ttt-.,;-·

seriously. And from this ~nvironment comes the "esprit de corps" that drives ~y)~~' us to build our worid-class boats. We are committed to working together, ..

not only as a company, but to help our neighbors as well; to give something

back to our community and our country. Our latest effori waS the building of

"America's Pride". This special edition Crownline (202 BR) was sold in

auction arid the funds donated to the families of the victims of the

September 11 th terrorist attack. This project was conceived and acted on

by the enUre company and stands as a definition of the character and

quality of the people who build, sell and service our boats.

Our Dealers

Page 2 of

From our very beginning we have been committed to providing our dealers with the

finest possible products in terms of design, workmanship, quality, standard and

optional equipment. They, in tum, are committed to total customer satisfacUon during

the sales and delivery process as well as meeUng the service needs of their

customers after the sale. Our commitment to our dealers, and thus to their

customers, continues with our promise of "best in class" across our entire line.

including our next generaUon of prodUcts. We will never deliver anything less than

the finest boats that our skill, experience and ingenuity can produce. We will provide

our dealers with the "best in class" with unique styling, exceptional ride and handling,

external cosmetics and interior comfort. And, we will cOntinue to focus on being the

industry leader with regard to "tumkey" deliveries.

Kevin Riem

Director of Sales & MarkeUng

Director of Customer Service
'ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page I of:

od a Dealer; IZip go

mIIII...... owners' dub rally

ABOUT CROWNLINE

about <.t'owotilU!: gtossary storE:

FORM, FUNCTION AND GUARANTEED QUALITY , IN EVERY BOAT WE BUILD

. ,', ,: it-. . .

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The Crownline success story didn't juSI

happen. We've made "Best In Class" our

ultimate objective and we're well on our way

to achieving it.

a

lER#;- Every Crownline boat is buIlt to provide its

owner or operator with the maximum comfort,

convenience and operating effic'lency

possible within a given design, length and

beam. Crownline fonm and function begins an

the drawing board where all possibilities are

considered for each bowrider, deckbcal,

cuddy and cruiser we build. Because certain

optional items are regularly called for, they're

designed into our boats as standard equipment. Giving boaters more of what they want in standard equipment and

options to meet their special ne~s are just two of the reasons why, in 10 short years, we became and still are one of the

largest builders In the world of stem·drive·power~sport boats.

We are so sure of ourselves as boat buIlders and the value of our boats that our wanranties are right at the top of the

Industry's best: Stringers, deck and hull structures, upholstery, dashbcard and gauges, all are covered, all are transferable

(see chart). We further back our belief in ourselves and our boats by voluntarily adopting the training and processes

advocated by the National Marine Manufacturers Association (NMMA). We are also one of the small and exclusive group

of marine manufacturers who have eamed the designation "Marine Industry Certified", the seal of our. commitment to total

customer satisfaction. As a member of the MIC, we operate according to a professional code of conduct, offering only

NMMA-certified products as standard am! optional equipment. We provide our customers with a fonmal feedback

mechanism and much more to demonstrate our detenmlnation to make certain every Crownl;'ne customer is totally

satisfied with his or her boat throughout their entire ownership experience.

WARRANTIES TRANSFERRABLE

Stringers Lifetime t v'

Gauge Cluster/Gauges Lifetime' v'

Deck Structural S-year v'

Hull Structural S-year v'

Upholstery S-year tt v'

v

ttAgainst manufacturing defecl tAgalnst rol *Standard equipment

What is it abcut Crownline boats that makes them so

satisfying not only to owners, bUt to passengers as \VeIl?

Owners tell us time and time again that along with the overall

quality and styling, Ws the details: The weII-thought-<lut floor

plans, seating anrangements, storage areas, the placement

and quality of fillings, the broad choice of comfort,

convenience and utility optionsthe things that make each

__ ,, .1· I 1
'ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page 2 a

owner's boat specifically enjoyable.

For example, we know how important storage space is on a

boat and so, model by model, we search out ways to provide

storage for clothing, skis, marine equipment, ice*coolers, as

well as convenient starboard and port side wall storage and

drink holder~. With Crownllne, there's a place for everything

needed for day-trips, cruising or a couple of hours of fun on the , water.

NAUTOLEX'

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ThE:! Wise Cornpany, Inc

At the helm, the molded

Novatron dash comes equipped with stainless steel

bezeled Faria gauges with the cockpit featuring Taylor

Made curved tinted safety glass walk-through windshields.

Cockpit equipment includes LOWRANCE depth finder,

INSTA TRIM trim tabs and TeleflexiMorse steering system

with filt steering wheel and SONY sound systems. The

available 2 hole exhaust system Is by CORSA

PERFORMANCE. Gelcoat is by .Cook .

All of these components and materials are NMMA-eertified

in keeping with our promise of quality, dependability ans]

total customer safisfaction guaranteed with every boat we

Every one of our boats is

upholstered wllh durable 34

ounce Nautolex marine vinyl with the exclusive PreFixx

protective finish that resists stains, scuffs, grease, salt

water and other surface sailers. That Includes our WISE -

constructed bucket seats with the Attwood shockabsorbing systemwith quad-spring suspension, and

cushioned pressure points.

build.

c;(lpy~ight © 2003 Crownline Boats.
ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page 1 of

.-shape interior wtth two

~AS ffip-up bucket seats

STANDARD FEATURES

• Anchor and rON locker _

• At.Itomatic bilge pump VI.'manual override

• Canvas· Color-keyed Sur.brella TM stand-up bimini

top (,'{'Quick disconnect hardware), & boot wlo

connector

• Chroq~e/Brass t:-:ru-hull fltlirlgs

• Cleats - (6) S:S:cel 6·pul: U>J cleats

:-Cbckpl1 Wetbar

• CO; detector

• Courtesy Lign:,S

• Cur'/ed tinted safety glass wal":-lhru windshield

• Easy.a::.;c'ess insuiated Igloo 25 quart cooler

v,,'endosed sic:-age compa.....-:lent

• Easy transom cockpit entry

.. Elec:ric horn

• Engire Hour Me;e~

• Fib€,glass eng::1c cover

• Fire Extinguish-=-r

• Fresh water system· 10 gallon capacity

• Full ir.strumentat:on - S.'Steel bezeled Faria

Gauges wflifetrme war~anty ,

• Gelcoal • Two-tone Arrr.o;cote gelcoat (narrow hull

band/middle deck band) or solid Moonstone

• Glassliner - Fully integrated bow & cOckpit

Iiberglass liner

" Hidden S/Steel four step telescoping ladder

• In-floor lockable ski and kneeboard storage

w'hinged lid & removable rubber pad

• Inlerior Layout: L-shape w/Portslde storage ar:d

two adjustable f.ip-up bucket seatswiSAS

suspension

• Passenger grab handle assembly wfintegrated

drinl< holder

• Portable toilet, enclosed wmght, electric vent,

openable screened portlight and sink

• Pressure tre:ated wood wir.: transferable lifetime

warranty

cmD~ .. ...(tr~i

Shown in moonstone/ruby with gold diar.1Ond G:-aphics.

ft 12 PERSON: • UP: 18"/46Cm

1875 LBS /8501<g

- I DO'....N:32·/ • 59 GAL/223L 81Cm

• MAX HP: 425 D~::USE:18·

• 4200 LBS/1905Kg ~T BRIDG=. CLEARANCE:

60" /1.52M

Here's a bowrider with a mission: Comfort, convenience

and fun. Comfort with its L-shaped interior layout with 2

SAS flip-up bUckets, recessed cockpit doors, walk-thru

windshield and Bimini top. Convenience with ioeds of

weUdry storage space, wet bar, 25-q1. cooler, 10-galion

fresh water system, lighted portabie head with sink, and a

12V receptacle. Fun with a spacious deck, built-in swim

piatform (optional extended available), ski tow rail, and just

being on board.

"

\.

.~ .. •..\~~ ~;jI.i

:.

Starboard

-'"

storage

::ompartrnent and walkthrough door

Cooler storage

.::ompertment under the

cockpit wet bar

.ld a Dealer: IZip

~---:=-Y~

.." .·/~ I - ~,,:,'

.- I

r , I

"'-'

:onvenient portable heed

compartment with sink

and port ~ght
'ownline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders . Page 2 of

LOA: 23' 7M

BEAM: 102" 2.59M

Performance Benchmarks

E':lglne PHP Prop Choice

5.0 81 250 DuallP:o;J

5.7 EFI 260 OuaLP::c;J

350 MAG 300 Single/Pro;J

6.2 MPI 320 DualiPro;J

8.1 81 375 Dual/Prop

Speed Range

47 - 52

48 - 53

50 - 55

51 - 56

55 - 61

RPM Range

4400-4800

4400-4800

46,00-5000

4800-5200

4400-4800

• R::lck-3'1d·Pinion $\e~rj:)g

• Snap-in cockpit carpel

• S'5!eel bow. cockpit & ski 10\-'1 r<=lil

• S,'Steel Vents

• Swim Platform \lI!el Storage

• Tilt steering '.':heel

• r'Na-tier drin'.; ~olcers

·Performance may vary due to load, weather conditions,

elevatlon, propping, etc.

CopyrigH.t © 2003 Crownllne Boats.
Appendix 2

Photographs of Crownline's Operations
Crownline Boats

Photo 1: Mold Preparation Prior to Gelcoat Application
Crownline Boats

·Photo 2: Gelcoat Application Booth
Crownline Boats

Photo 3: Gelcoat Application to Hull
Crownline Boats

Photo 4: Gelcoat Application to Deck
Crownline Boats
Crownline Boats
Crownline Boats

Photo 7: Grind and Trim Work
Crownline Boats

Photo 8: Upholstery
Crownline Boats
Appendix 3

March 23,2000 Letter from IEPA

To Crownline Boats

Concerning New Emission actors

.....",
JUN-07-2000 WED 04:48 PM EPA AIR PERMIT

, .

FAX NO. 2175245023 . P, 02

II.L1NOIS ENVIRONMENTAL PROTECTION Acr::--:CY

P.O. l10x 19506. Sr"INC:~Ii1 n, ILI.INtIIS &179·\·') S(';(,

THOM.....S V. SKINN:R, DllU:Cl0R.

'i

217/782-2113

H,LINOIS EPA ALERT

March 23, 2000

_.-----_.~--~--_._---_..-----_..----

Re: Changes in Method of Calculating E~issions

Dear Mr. Porwanche.r:

Illinois £PA.records indicaCe chat your facility operacio~£ i~clude

polyester rc~in prOduct manufacturing :processes. The USEPA h~s indicated

that previous USEPA polyester resin product manufaccuring pro~=ss.cmi~sion

factors greatly underestimate emission=:: and should not be t.I..;:;e:i. l\S ",Shown

on 'the att~ched copy of the USEPA W~b Page (Att~chment 1), t~~~e old

f~ctor9 have been remove.d from the USEPA database. Further, ~s stated in

thQ web page text, ~usera musc evaluate cheir own ~PPlicatio~ ~o dcf;~ine

t.he most. ;;J.ppropriate method of estimating emissions". In ;;J.dc':'tion;-"'~li"c'·

text indicat.es t.hat the USEPA has 'posced three sets of ~~te~i~ls whith'

documenC and malyze much of t.he recent data" obt.ained from r~c,;:nt·>:·~~;~·;;·

polyc~ter resin product manUfacturing proce~s emis·sion tescir:q. crP6J~:'~;_~

application of t.he augge~ted emission calculation procedure~ ~~o'~"~~~the . -""">''11.•1-

list.cO documents, emissions from spray-layup and hand lay-up ~ill b~;~r

eubstantially increas;ed. see At.tachment 2 for a comparison 0: t1".e-ThbW·.'.:

factors. \j?~f

It should be noCed that the new factors shown in l\CCachment. 2 are. ~~~t:

calculated values based upon specif"ic crit.eria, The~e value::> s:"loUi·a'·~not

be used direcCly to calculate e.missions~ Rather, emis::;ions 5;"cu1(f1f;,~,~~,i

calculated b.").sed upon tho procedures shown in the referenced :,:.~~~;~;~.

documentation.

;-"';'.

This notice is presented in

opportunity to eval~te the

~hould be noted that. future

che new fact.orc.

,.:';;'~~- :,

order to provide ',your company wi:r.. a..'1 ;-;~ .."

new methods of calculat.ing c:ni::;$'icca.:;::\tt-:,~_ '..=..:;~ ...::t;.'.;. ..

Illinois £PA det.erminations will t:e ba:s,e"d':upon '.,,:..-.,: ..

P>\IN1I-I) ON Rrc.."YClW PAI'If,: ':~-:/~"..

j.:~~~t,~
JUN-07-2000 WED 04:48 PH EPA ::rv

' .. ll. PERMIT . Ff.X NO. 2175245023 P, 04

READ ME file fo= kP-42 Section 4.4

npolyester Resin Plastic ?roductz Fabricationtt

March 3, 1999 Update

Section 4~4 of AP-~2 ~as removed frc~ this ~=b site as of 3/18/98 because

che emission facto=z p~esented in that seccion appeared to underpredict

styrene emissions f=o~ most polyezte~ resin operations. A nu~bcr of

individual site te.=.::,s and planned si:tldies F=-=formed over the past few

years lead to this conclusion. The user is rcfQrred to the Potentially

Useful for Err~ggicns EstimaLio~ - FYI page O~ this web site, where EPA has

posted three. sets of r.-.3.terials which docur..Q..';.t a.."1d analyze much of the

recant data. At tr.i.s :.ime, there is no "A?-o12 factor" or estimation

method for this category. As would be the caGe even if there were an

AP-~2 method, users ~st evaluate their o.~ appli~ation to determine ~he

mOGt appropriate method of estim~tir.g emi~zion~. In the case of pQrmit~,

sources are exp~cted. to use '"best a,,·ailabl-=:. d...!\ta ", not necessarily 1\P-12,

to detormine their emizGions (5ee C~~'6 ~te~oranda for Operating Permits

and New Source Revie~ (Title V) Policy and Guidan=e Web site. for

permitting policies). As detailad in the Introduction to AP-42, AP-42

emission factors are not provided as recc~~ended permit li~its.

The first 5et of l,l...at.erialsis a repo~t ent;"~led "Baseline Characterization

of Emissions from F{bc.rglasz Boat r<'.anufactuY"ing ll , prep~red by_ Stelling

Engineering, Air-Te=h ~~vironment~l, and Radian International for the

National M~rine M~ufacturers Association (~~). - The zecond set of

materials is a report. ent.itled llCFA Er;\issio:1 Nodels for the Reinforced

Pla~tics Industries". prepared by D~. Rober~ Haberlein of Engineering

Environmental on be~~lf of the Composite Fabricators As90ciation (Cr~),

the International C.=.st Polymer A.$sociation. and the Composites Institute-.

Thi~ reoort has aEs~ci~ted with it a zippe= file containLng three

diffe.rent spreadsh2:e.t. versions (Lotus, Exc-el,. and QUat tro) o! a

orie-variable" model which predicts e~iesions based on the ztyrene content

of t-he re~in. The third set of mate:::-ialr; is a nine-variable mode.l (/IFRP

Model, version 1.0~) d~veloped by R~5earch Triangle Institute for EPA's

Office of Re~earch and Development. along with a wordPerfect file

cont~iniog docurn~~tation of the data used ~o develop that model. A

two-page User's Guic~ to the FRP modal is also provided.

We would like to tUT2 ~ome or all of chis ~dterial into an AP-12 section

at Borne point. but ~c need to know ~hat woUld be most u~eful to ,you in

your applications, Y~at guidance should be p;ovided with any model, etc.

Your comment~ on tr.is material as it re.la-te.s -to an AP-4:2 section sh:ould be

addressed to: rya~.ro~~epa.gov.

F.PA Homa I OAR hO~= [ OAQPS Home I >TN Home [Search TTNWeb

CHIEF Home

http,//wwN.epa.gov!ttn!chief/c4S4.r.t~1

I Concact CHIEF

webmaster

March 10, 2999
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- NVS' NVS NVS

Date: December 1, :L9n J-1onor.ler-3S~2 Nonomer-38'r Nono:ne r 42 %'

Resin Non-Spr~y Layup] (ns) (Rmi8sions ~s a percent (%) at Available Monomer)

AP-42 (Deleted from AP-42 by USEPA) 5 - 10

l;PA!RTI ~A 14.2" - 15.45 NA

NJ-:MA 10.5 - 12.1 NA 10.6 - lq.O

CFAfi 9.6 - 17.7 NI\ 11.5' - 21.2

Range of New Data 9.60 - 21. 20 .

- ,

Rmisflion 1?a.ctor' Eln• 9 or a I·~inimum of 15. <,In

Resin Spray Layupll (0) (Rmisa-ions ll,B a percent (%) of Ava~lable Monomer)

AP-42 (Deleted from AP-42 by USEPA) 9 - 13

EPA!RTl 16.2\1 - 1.7,11 13.9 D - 27.1 20.GI< 20.5

NMMA 13.9 - 18.0 NA lB.2 - 23.0

Nl>"M:>!A (CFA HOLD") 28.8 - 52.0 NA 39.2 - 54.6

CFA 16 .1 - 23.3 NA 22.4 1

' - 38.0

Range of Now Data 13.9 - 38.0

Emisoion 1?4ctor' Eu~7 or .a J~inimum 0: 2.5.9

Bumm~ry of RmdsBion Data Results·

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Page 3

Footnotes:

NVS - Non-Vapor Suppre3sed~

Mo~omcr _ Monomer content of teat reoulto in percent by woight of ~enin.

Non-Spray Lay-up (ns), data does Dot include Continuous Laminationsj PultrusioQ; ['Iarble Casting; or Closed

["!aIding processes.

Non-Spray, data is based on flow coater range (Range of data for flow coater process was !3.9\ -14.6% oE

available monomer) .

Non~Spray, data is based,on pressure fed roller range (Range of data for pressure fed roller process was

14.5~ - 16.3% of available monomer).

1\11 CF/\ Non-Spray Lay-up data is bnncd on " bucket <loti brewh process.

CFA styrene content was 40% for data results~

EmisB~on Facto~ - Regionally accepted ao best available data when El iB equal t%r greater than thu

midpoint. 1\ny B\ Cu ••, ",oJ (Std) valuo belOW the midpoint will be required to use the midpoint as the cmiosion

factor. Any ei (n•• -.!J<') (Std) value ,above the midpoint N'i.ll represent that specific sources emission factor.

Facility specific teat data to determine emiosiono factors may supercede listed emission factors as best

available data, when approved on a caB~ by case basis.

(Std) = ns-l.07j 8-1.2Bj gc-~.l)

(See Document ~4)

8", [- 0.46365(TIl)+ 0.00265[SC)+ 0.00068(GT)+ O.00003(AF)-' 0,0320] (std)!(SC\1

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SC • Styrene Content, (~)

TH .= Thickness of Part,

GT

I\.F

Std

E 1:lA

Gel Time, (min)

Air Flow Rate, (ft/miol

."" Non-spray deviation' factor", 1.07

Emissions as a of avai~able mo~omer

(incbes)

-0

=.

00·
Page 5

..

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"

(Std ::: ~.28), This is a sta.'1dard deviation multiple for tbe sp:!:"ay e:nissions factor. Th~s multipl-e provides

greater accuracy for the respective equation by incorporating the Btatistical doviation of existing test

data. The (st-d) mUltiple is Umultipliec" by t~c £1 (r._. _. 'J c ) result to obtain the a:?propriate emissions

factor estimations.

Gel Coat (gc). da~a does not include Continuous Laminations; Pultrusiani Marble Casting; or Closed ~oldi!lg

processes.

EPA/RTI styrene content was 38.75t for data results.

Total mO:lomer of 37\" from 32'& .styrene + 5\ r1ethyl Me.thacrylate (J.'J1A.] Eor data results.

CFA styrene content was 40~ for data results.

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8"00 (- 5.34119(TH)+ o.ooOn(Scl+ O.00003(G·!')- O.OOOlO(GCP]+ O.00004(l\P)- o.OOG] (Stell/(nn)

GCF Gel Coat Flow, fIbs/min)

J\.P .. Air flow velocity. (ft/min)

GT

sc

TI[

Sts

Ellie

-= Gel Time, (min)

_ Styrene content, (~)

c Thickness, (inches)

• Standard Deviation for Gel-Cont • ~.13

·Emissions as a of available monomer

-r)

;:c:

:x

:z:

,::>

N

IStd "" 1.13}, This is a standard deviation mUltiple for the gel-coat emissions factor. This multiple

provides greater accuracy for the respective equation by incorporating the 5tat~atical deviatio~ o~ exiating

test data. The (otd) multiple is "multiplied" by the B 1 (0.,., g'c) result to obtain the appro~riate emiss~9ns

factor estimations.

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