# TECHNICAL DOCUMENT IN SUPPORT 

# OF A PETITION BY CROWNLINE BOATS, INC. FORANADJUSTED STANDARD

December 2003·

Prepared for:

.Crownline Boats, Inc. West Frankfort, Illinois

Prepared by: Advance EnvironmentalAssociates, 

### L.L.G. 300 S. Second Street St. Charles, Missouri 63301

### Table ofContents Page 1.0 BACKGROUND : : 1 1.1 Business History ofCro\vnline Bo¥s, Inc 1 1.2 Crownline's Compliance History ' 1 1.3 BackgroundLeading to the 8 lb/hrYOM Rule Compliance Issue 1 2.0 DISCUSSION OFTHE BOAT MANUFACTURING INDUSTRY 2 2.1 Overview ofBasic Fiberglass BoatManufacturing Processes 2 2.2 BoatManufacturing 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]\;lARYFOR CROWNLINE BOATS 5 3.1 Methodology for CalculatingYOM Emissions from Gelcoat and Lamination 5 3.2 YOMEmissions from Small BoatParts and Final Assembly 10 4.0 INVESTIGATION OF COMPLIANCEALTERNATIVES: METHODS FOR REDUCINGYOM EMISSIONS FROM BOAT MANUFACTURING 10 4.1 Method 1- Reduce VOMs inproduction materials : 10 4.2 Method 2 - Replace existing production methods with alteITlate production methods 11 4.3 Method 3 - VOC ReductionThrough the Application ofTail-End Emission Control Equipment 16 5.0 QUAi"'lTITATIvEAND QUALITATIVE IMPACT OF CROWNLINE'S OPERATIONS ON AMBIENT AIR QUALITY 20 5.1 Description ofOzone ImpactAnalyses**,~** 

### : 20 Appendices Appendi.,l Appendi.,2 Appendix 3 Appendi.,4 Appendi.,5

1663007.2 

### Background on Crownline's History, Products and Production Methods Photographs ofCrownline's Operations March23, 2000 Letter from IEPA to Crownline Boats ConcerningNew Emission Factors ' Baseline Characterization ofEmissions from Fiberglass Boat Manufacturers for NMMA, August, 1997 April 11, 2001 Letterto Don Sutton ofIEPAfrom 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 ofEquations ForExtrapolating NMMA Emission Factors to Calculate Styrene and Methyl Methacrylate (MlYlA) Emissions From the Application ofGelcoats and Resins to BoatHulls and Decks ConsideringVarying BoatLength and OtherVariables VOM Emission Calculations from Caulking, Adhesive and Lacquer Operations VOM Emission Calculations from Small Parts Detailed InformationAbout VEC Technology

. Spread Sheet Showing CostPerTon ofVOM Removed

Proposal from BioRem Techoologies, Inc. Proposal from BacTee Systems, Inc.

. Proposal from DUffEnvironmental, Inc.

Proposal from MegTec Systems Proposal from Frees, Inc. Details ofCrownline's Ozone ImpactAnalysis

111.0 BACKGROUND 1.1 Business History ofCrownline Boats, Inc. Crownline Boats, Inc. (Crownline) owns and operates a fiberglass boat manufacturing faciit\' undet primary SIC code of3732. Crownline's first boatrolled offthe line on i\larch 23, 1991. 

### _.I., that time Crownline employed less' than 25 people. By 1991, Crownline hadgrown outofits 

### , Whittington location and moved into alarger facility. By December 1994, Crownline's ne,,· sme-ofthe-art boat manufacturing plant was completed. 

### ill! ofCrownline's operations ha,-e beer: at this
. new location since then. The cunent facility is located approximately 1.5 miles south ofdee town of West Frankfort, Illinois along Illinois Srate Route 37 in an area that consists ofresidential 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 ofthe 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 ofCrownline'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 ofthe plantby 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 ofthis installation, designed the system to disperse airvented from the plantin orderto reduce odors. It continues to be Crownline's goal to comply with environmental regulations includi.."1g 35 HC

.§215.301 "Use ofOrganic Material" (the "8 Ib/hI Rule"). ,\ complete history ofde'Cel0p:::lenrs related to Crownline's compliance with the 81b/hI Rule is presented'in the following seccon ofthis report. 1.3 BackgroundLeading 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 polyesterresin productmanufacruringprocesses 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 notbe used. However, IEPA agreed with the USEPA in that the new factors, developed by the :-\atioldj\[arine Manufacturer's _\ssociation (NMlY.lA.) for fiberglass boat manufacruring, more accurareh- represent emissions ofstyrene and otherhazardous 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 ofthe new factors and their desire to properly e,-aluate the new emission factors for applicability to their boat manufacruringprocesses, Crownline contracted with a consultant, Advance EnvironmentalAssociates, L.L.c. (AEA), to perform the necess:uy analyses. Specifically, AEA evaluated the methodology for calculating Crownline's boat manufacturing

1663007.2emissions and, using the nev·; emission factors, re-calculate 'emissions associated with the gelcoating, resin lamination, and other boatproduction processes at the \V'est Frankfort plantthat use VOr,!- containing materials. Coincident wim me re-computing ofVOM emissions using me new emission factors, AKA, also reviewed Crownline's Preliminary DraftTide V**Oper~ting** permit. A review of Crownline's draft Tide V operating permitidentified 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 ofme 1997 study tided, "Baseline Characterization ofEmissions From Fiberglass Boat Manufactuting For National Marine Manufacturers Association), d,e hourI\- emissions from certain ofCrownline's operations (application ofgelcoat, resin, caulk,**~dhesi\-e,** and lacquer to boathulls, decks, and small parts) have been computed. The results ofthese computations show that hourly emissions for certain parts of Crownline's operations would exceed me 8 Ib/hrlimit on a stricthourly basis. In the event emissions calculations showed mar Crownline could not demonstrate compliance with me 8 Ib/hr Rule on a stricthourly**b~sis,** Crownline decided to determine ifany viable methods fm reducing YOM emissions from meir operations exist and couldbe 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 ofavailable and proven add-on 

### airpollution controls. While AEA conducted this analysis, Crownline sinmltaneously agreed to begin the process for petitioning the Illinois Pollution ControlBoard ("me Board") for an adjusted standard. In cliscussions with IEPA, Crownline decided thar pursuing an adjusted standardwould be ayiable option. IEPA concurred with this approach. 2.0 DISCUSSION OF THE BOAT i\LI\NUFACTURING INDUSTRY This section discusses the boat manuhcruringindustry in general and the various memods for makingboats. It also discusses me specific boatmanufacturing technology used at Crownline and the newly promulgated i\L-\CT Standard for me boatmanufacturingindustry. 2.1 Overview ofBasic Fiberglass BoatManufaChIring Processes There are two basic methods, or processes, thatare used for fiberglass boatproduction in the boating industry: 1) open molding; and 2) closed molding. Crownline, along with the vast majority ofboatmanufactUrers in the U.S., uses an open molding process. There are a variety ofmemods used in the general fiberglass producrs manufacruring industries (including the fiberglass boat buildingindustry), however, 

### all are simply \"ariations ofeimer ofthese two basic methods. Typically, fiberglass boatmanufactuting 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

1663007.3 2• Upholstery installation (see Photo #8)

• Final Assembly (see Photo #9)

• Shipping Photographs ofCrownline's production operations are located inAppendi.." 2. The gelcoat and lamination operations generate mostofCrownline's VO,\[ emissions (the majority ofwhich consist ofstyre.ne). Accordingly, the overview ofboat manufacturing technologies presented in this section is focused on these two primary operations. By far, the most Common method ofproduction in boatbuildingis the open molding method and the method employed by Crownline. The open-molding process typically consists ofapplying gelcoatand 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!orgelcoat) is applied to the mold in an area that is open to the roominwhich the application 

### is made. Open molding includes operations in which avacuum bag or similar cm-eris used to compress an uncured laminate to remove air bubbles or excess resin, or to achieve abond 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). OtherVOMs 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) ofthe'se other organic constituents that make-up the entire mass ofthe 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 ofadd-on emission control is a strong function ofthe 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 ofplant 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 boatbuildingindustry, closed molding is used far less than open molding. Closed molding can consistofvarious methods including compression"moldingusing a sheetmolding compound, infusion molding, resin injection molding (Rl?-.l), vacuum-assisted resin transfermolding (VARThl), resin transfermolding (RTj\l), andvacuum-assisted compression molding. The closed moldingprocess does not emit as much styrene as the open molding process.

1663007.3 32.2 BoatManufacturing 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 ofgelcoat. 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 offour gelcoatboorhs fat rhe application ofgelcoat using sptay guns. Air. atomized guns ate used ac Crownline. The gelcoat area has 31 gelcoat sptay guns, some ofwhich 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 ofrhe fIbetglass boats. Patticulate emissions from the overspray ofrhe spray guns are conrrolled wirh panel ftlters builtinto rhe booths. After the gelcoathas dried, the molds are moved to one oftwenty-fom laminating stations. At the laminating station, glass fibers,- polyester resin and a resin catalystwere previously applied to the mold using a spray air-atomized chopper gun. To achie,e compliance with rhe Boatl\lanufact!,lring i\-L\CT emission srandard (described below), as ofearly 2003, Crownline has replaced all ofits atomized spra" chopperguns used for resin application with flow coat guns (i.e., lowpressure., internal 

### mi", non-atomized choppet guns). The lamination area has twenty-four flow coat guns. A flow coat gun simultaneousl,' chops strands ofglass fibers into predetermined lengths and coats the glass fibers wirh resin as rue resin is discharged from the gun nozzle. The flow oftesin 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 offiberglass 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 ofmaterial has been applied to the mold, itis then allowed to cure (harden) for some time before another layeris applied. Additional layers offiberglass and resin are applied as needed per the design ofthe boatmodel beingbuilt. \'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 ofrhe 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 ofair every minute. This air ,'emilation rate is necessary to maintain the styrene concentration levelbelow OSHA worker exposure protection levels, Particulate emissions are controlled withpanel filters provided on each side ofand along the length ofthe gelcoat area. 2.3 New l\1ACT Standard and Crownline's Compliance With the Sib/hr Rule BeginningAugust 23, 200-1-, Crownline, like all otherboat manufacturers in the U.S., mustmeet the newly promulgated l'ational Emission Standards for HazardousAir Pollutants for Boat Manufacturing, 40 CFRPan: 63 SubpartVVVV, (hereafrer referred ro as the "]\IlACT"). The nile

. . requires that subjectboar=nufacturers meet the "]\IfACT floor", which is the emission limitations achieved by rhe best-periorming 12% ofboat manufacturers in the nation. USEPA determined that the iYlACT floor for boatmanufacturers would not be 

### air pollution control equipment since only one facility in the counrryuses such equipment. As discussed furrher below, by complyingwirh"the iYL-\CT standard, boatmanufacturers 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 ofthe conditions ofthe'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 ofthese scenarios is based on using the DOS[ 

### currentboat production dara for Crownline's operations (using actual dara fromJanuary rhru

### Jul,- 2003 and esuapolared dara for August rhru 

### December 2003 by inserting theJuly production and materialusage dara for these last five months of2003). Section 3.1.4 provides a summary comparison ofthe three scenarios. Section 3.2 describes the VOM en1issions from the manufacrure ofthe smallboarparrs and from the final assembly operations (e.g., enussions from use oflacquer, adhesives, caullr, etc.)
.. 3.1 Methodology for CalculatingVOM 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 ofcalculations 'were 

### performed using a basic formula. The rwo processes are (1) gelcoatapplication to boathulls and decks and (2) resin application to boathulls and decks using air-aromized chopperguns. Specifically, the en1ission calculations consist ofthe following equation and input data: En1issions 

# = Q x Fax Fe \V'here, 

### Q = quantity (amountby "'eigh,) ofmaterial applied to the part (deck or hullmold) 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 ofavailable sryrene thatis en1irred as avolatile 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 andis, therefore, available to react to form the desired 

### produel' (in the open moldingprocess, asignificanr amount ofthe 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, StellingEngineering, :'l:i.rch 21, 2002). Important considerarions in the processes ofgelcoat and resin application that affecr the amount and rate ofVOM releasedper unit time are presented belo\\'.

1663007.3 5

### Q, Is the quanriry ofmaterial (gelcoat and resin) used to bUild each boat part for each boatmodel 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 partin a series oflayers called "skins". The process involves application ofa skin, followed by a curing period before the next skin can be applied. This process is repeated until all ofthe skins required to achie"e the desireq thickness ha,-e been applied (allowing cure time bet:\veen the application ofeach skin. For decks, 3 resin skins are typically applied. Forhulls, 2-3 resin skins are applied, followed by a separate application to bUild the boat floor. Thatis, the floor contains wood "stringers" (wood boards that act like floorjoists) that are att:lched to the hull at the point where the stringer meets the hull Goint). Each stringerjoint 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 ofresin to a small boat (e.g., 18

- 22 feet long), takes approximately 30-35 minutes. The time it takes to apply a skin ro alarge boat (24

- 29 feet long), is approximately 45 to 55 minutes. Howe"er, regardless ofboar size, no skin takes more than an hour to be applied. Gelcoatis also appliedwithin less than a one-hour time frame. The application times are largely dictated by the resin "kick" time, which is the duration oftime after applicarion when the resin begins to cure and become a solid. The amount ofmaterial applied per skin ,anes. This variability occurs ptimarily with application of the second skin. Thatis, the amount ofresin that is applied to create the second skin typically requires the greatestmass ofresin regardless ofboat sIze. Itis also important to note that the fraction ofa,-ailable styrene in both gelcoatand resin thatis emitted upon application to a mold 

### is largely a function ofparr geometry (shape) and size (boatlength). Itis a known fact (from NMMA data) that, ofthe total styrene contentin me resin as applied, the fraction ofstyrene thatis emitted (versus thatwhich remains with the solidi6.ed mass that makes up the part),is greater for the building ofboat hulls than itis for the bUilding ofboat decks. Again, this is due to the fact that the conc"'e geometry ofthe hulls cteates a larger average distance between the resin application device ("the resin gun") and the'part. Similarly, me fmcrion ofavailable styrene thatis emitted increases as partlength increases. 

### 1.'sing NMi'vL\ data from Tables 2-3 and 2-5 (See Appendix 4), we identified the simplest funcrion (a line) thatwould nL'l wough both points plotted for percent ofavailable styrene emitted from the application ofresin ro two different sized hulls. Interpolarion ofthe fraction ofa.-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 ofs,:.rene in the gelcoat and resin as applied is referred to as "available srnene". However, only a fraction ofthe available styrene in these two materials is emittedbecause the balance reactS to fo= the solid fiberglass matrL'C ofthe partbeing 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 42wt-% styrene. The results ofthe 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 Exhibit3 ofAppendi..,< 6.
.**166300~.3** 6

### 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 ofgelcoat 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) areduced,HAP coment (sryrene, MlYL'\. and other volatile organic HAPs) gelcoatis used (33 \\'[_% 

### versus. 43.2 wt-%); and (3) non-atomized spray (flow-coat applicators) are used. To comply with lYlliCT, most boarmanufacturers with open molding operations nationwide will use these flow-coat applicators and low-HAP resins and geleoats. Based on these three assumptions, the following equationand 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 ofmaterial applied, by weight Fa 

## = fraction ofmaterial thatis styrene, or "available" styrene 

### Fe 

### = fraction ofstyrene.that e\"aporates after application to apatt Ffc

# = fraction ofstyrene emitted from flow-coater spray gun The following discussion addresses important factors thataffecr the amount and rate of VOlvfreleased perunit time in the resin application process: -

• The fracti()n ofstyrene 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 ofOctober 2001, Crownline began using aresin with astyrene content of 35 wt-%, orless, (versus the previously used 42 wt,%) and the emission factors used in the calculations were an interpolation ofthe data'in Table 2-1 ofthe 

### 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 inTable 2-1 from the 1997 NMlYlli study. Perthe 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 ofhourly YOM emissions from Crownline's gelcoarand bmination operations in , compliance with the lYlliCT are set forth in Exhibit4 ofAppendix 6. The hourly YOM emission estimates shown in Exhibit4 ofAppendi.x 6 are conservative, since they assume 100% ofthe styrene is emitted in the firsthour. However, accordingto the NlYlliL-\ Study, only 70% ofthe 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 abreak-down ofthe estimatedVOM emissions from all ofthe affected operations at Crownline for year 2003 (exrrapolated for August through Decemberof2003 using boatproduction and material usage data forJuly 2003).

Total YOM Emissions(!) Based on Crownline's CurrentMode ofOperation(2)

- Using Year 2003 Boat Production and Material Usage Data(3)
. Emission Source YOM Emissions' (TPY) Resin Application (Lamination) Areas 88.1 Gelcoatl'se Areas (Booths) 59.6 Subtotal 147.7 OtherAreas·(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 modelpointvalue method ofcompliance); (3)

- Reported values reflect level ofYOM emissions assuming year 2003 boatproduction (number

. and model mi., 

### produced duringJan-July of2003 andJuly 2003 data was used to exrrapolate

emissions for Aug-Dec of2003); (4)

- Other areas include such operations as mold fabrication, grind & trim 

### area (floor and stringer installation), lacquer application, hull and deck tie-in, carpetinstallation and seatbuilding (adhesive usage), caulk application, resin storage, etc. See Section 3.2 for amore detailed discussion ofthese operations and their**VO~1** 

### emissions. 3.1.3 YOM Emissions from Crownline's Operations ifCrownline were to comply with the 8 lb/hr Rule on a Strict Hourly Basis. This scenario estimates ,-OM emissions assuming that Crownline were to complywith the 8lb/hr Rule on a stricthourly basis. This last scenario is based on a setofhypotheticalconditions in order to simulate compliance with the 8 lb/hr Rule (on a stricthourly basis) for all 

### boatmodels. Under this scenario a defaultvalue of8 Ib/hr was artificially substimted for all 

### boatmodels to estimate what the annuallevel ofVO\1 emissions would be ifeach ofCrownline's gelcoatand lamination operations (e.g., emissions from the application ofeach gelcoatlayer and resin skin) were assumed to equal 8 lbs/hr and, therefore, comply exactlywith the limit of 8 lbs VOM/hr on a striCthourly basis. The calculations and assumptions used to develop the estimate ofYOM emissions for this 3rd scenario are presented in Exhibit5 ofAppendix 6. 3.1.4 Summary Comparison ofAnnualYOM 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 For3 Compliance Scenarios(2) 

### Pre-lYlACT tvLA.CT 8lb/hr 245 200 144

1663007.3 8

### (1)

- Includes VOM emissions from such production areis as Grind andTrim and FinalAssembly) (2)

- Scenario 1 

### = Uses Y2003 Jan-July acmal boatproduction and material usage data andJuly 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 ofatomized 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, butuses actual K,\P/VOI\l content ofmaterials acmall\- used duringJan-July of2003 and actual conclition ofall resin application being done using flowcoat guns; Scenario 3 

# =uses the same boatproduction numbers and assumes that each resin and gelcoat application operation (application ofeach gelcoat layer and each resin skin) emits exactly 8lb/hI. Each scenario includes' the 2003 YOM emissions estimates from all otherproduction 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 oflowerHAP resins and gelcoat materials and installation offlowcoat applicator guns in the resin application area, (i,e" compliance scenario 2) as shown in Exhibit4 of Appendix 6, Crownline will achieve significantreductions in total VOM emissions, IfCrownline were to comply exactly with the 8 lb/hrRule on a stricthourly basis, annualYOM emissions (as illustrated by scenario 3 presented as Exhibit 5 ofAppendix 6) an adclitional reduction ofann11a1 YOM emissions would be achieved, However the third scenario is based on ahypothetical set of conclitions that are not actually achievable without the application ofemission 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 astrict hourly basis by

### changing the total rime frame overwhich each resin and gelcoat application to each boarpartis made 

### (by applying the same totalmass ofresin or gelcoat, but over a period oftwo Or more hours), Crownline could complywith the Rule (on a stricthourlybasis), yet 

### emitthe same total amount ofVOMs on a daily (24-hr) and annual basis, Thatis, 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 complywith the 8lb/hrRule (on a strict hourly basis) but ",ithoutrealizing any true reduction in total daily or annual YOM emissions, The following example helps to illustrate this point: Assuming an incli1ridual skin (orlayer) 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 totalmass of resin or gelcoat for an inclividual skin over a two hour periodinstead ofjust one hour, the associated YOM emissions would comply with the,8 lb/hrRule on a strict hourly basis (i,e,,7 lbs would be emittedin the first hour and 7 lbs in the nexthour), However, the totalmass ofVOMs emitted for the entire day would be the same (14Ibs) Consequently, compliance with the 8lb/hrRule 

### in this mannerresults in no realreduction in the total daily or annual amounts ofVOMs emitted to atmosphere, 'This is one ofthe reasons why Crownline believes that demonstrating compliance on a striCthourly basis is neitherpractical' nor necessary, However, by

### complying with the I\[ACT standard and no othermeasures, Crownline achieves significant realreductions in the total amounts ofVOl\[ emitted from their operations on a daily andannual basis,

1663007,3 9

### 3.2 VO]'vI Emissions from Small BoatParts and FinalAssembly Thegelcoat and bmination departments are not the only source ofVOM subject to the 8lb/hr Rule. For each boat model, there are a number ofsmall parts that are manufactured using the same methods and materials as those employed for the manufacture ofhulls and decks. In fInal assembly, hulls and decks are sealed together and the small parts are installed to 

### complete theboat. In this assembly step, additionallaminates are applied. The decks are fIrst moved to 

### deckriggingwhere carpet, headliner and upholstered patts are attached to the decks. YOM containing materials (i.e., adhesives and caulk) are used in this operation. Fromthe carpet area, the hulls are then move to engine assembly. After engine assembly, the finished decks from deckrigging 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 ofcaulk/adhesive/lacquer) would not be in compliance with the 8lb/hrRule on a stricthourly 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 presentedin Appendices 7 and 8, respectively. 4.0 INVESTIGATION OF COMPLIANCE ALTERNATIVES: METHODS FOR REDUCINGYOM EMISSIONS FROM BOAT MANUFACTURING The opportunities available to 

### the industry to reduce or avoidwaste andpollution streams ate emerging. This section presents various alternatives currently used by the fiberglass manufacturing industry thatpotentially may be applied by boat builders for reducing YOM emissions from the boat manufacturing industry. Some ofthese 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.ofair pollution control equipment. 

### 4.1 Method 

### 1- Reduce VOMs inproduction materials Crownline has already reduced YOM emissions in its production materials. In complying with tvIACT, Crownline has alreadyreduced its total YOM emissions by a signifIcant amount (seeTable 3-1 and Exhibit4 ofAppendix 6). The majority ofthe reduction has been realized by converting to low HAP resins and gelcoats and, as discussed laterin this document, by replacing the atomized spray resin applicatorguns with the flow coat guns. Furtherreduction ofstyrene in the resins (below that needed to complywith MACT) 

### is not feasible because this would result in the loss ofimportant physical characteristics ofthe manufactured boat parts, thereby, significantly affecting the appearance, integrity and safety ofeach boat. "Traditional" general-purpose (GP) orthophthalic polyesterresins were widely used by the industry into the early 1980's. These resins had approximately 44

- 48% styrene contentby weight. By the mid 1980's, DCPD (dicyclopentadiene) resins became popularbecause ofcost-competitiveness and improved cosmetics due to reduced shrinkage. DCPD blends currently have a slightlylower styrene content. However, in 1988, rule 1162 (a South CoastAir Quality ManagementDistrictVOC

1663007.3 10regulation) required composite manufacturers locatedin 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 meetrule 1162, have a 33.5 to 35% styrene content. Reichhold Chemical, aproducer ofresins 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 supplieris "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 of2001. The mostnotable characteristic ofthe 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 interactwith the binders and surface. Achieving good secondary bonding has also been mentioned as aproblem because ofreduced styrene b-els. This is due in partbecause the low styrene resin is less forgi,-ing ofdust and contaminants on the laminate surface. Therefore, more attention has to be paid to surface preparation as well as following good wet-outprocedures. 4.2 1Iethod 2 - Replace existing production methods with alternate production methods 4.2.1 Open Molding Methods 3 - 

### (1) Use offlowcoatchopperguns - 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 catalyzedresin in a smooth, shower-like flow, rather than in a fIne mist-like spray that is typical ofairatomized 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 of rollersforresin application

-Like spraying systems, resin roller dispenser units utilize a fluid pumping system to draw resins from drums or bulk distributionlines. This pumping system also includes a separate, fully adjustable catalystpump. 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 productivitywas adversely affected and reduced the savings realized. Other laminators have noted that the switch to resin rollers requires some additional investmentinwork area design·and handling equipmentto suPPOrt the static mi."er and supply lines. Again, Crownline's success in the**mark~tplace** depends on effIcient boatproduction. This methodwill notwork. 

### (3) Vacuum bagging- The vacuum bagging process begins with the application ofagelcoat (using either atomized spray or flow coat) to the surface ofthe mold. Once the resin and fIberglass materials are in place, the exposed area is covered by speciallayers ofplastics,

1663007.3 11

### which are sealed to the edges ofthe mold. Before the resin begins to cure, avacuumis dra\yn through one or more strategically located POrtS in the mold or the plastic cover. For Crownline, the cost ofvacuumbagging perboatwould be too expensive because ofthe number ofdifferent models ofboats which Crownline manufactures. Also, the cost of material to build aboat would increase substantiall)" because the plastic bags used to contain the emissions can onl)" be used once. Inadd,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 ofapart. The sheets me often putinto the mold, completely enclosed in aplastic bag, heatis added and a vacuumis applied to the bag. For a number ofyears fabricators ofcomposite aircraft structures have relied on**th~** 

### use ofthese· "prepreg" materials. Prepreg technology has notbeen used by small leisure boat manufacturers. 

### Barriers to the more widespread use ofprepregs include: the need for elevated temperalJJ.res, the lack ofvacuumba&,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 ,?farefrigeration system to keep the pre-preg sheets cold before installation to preventpremature cuting, and the longertime taken for laying down the prepreg compared to spraying3. IfCrownline used the Prepreg process, they would be required to install a significantrefrigeration systemwhichwould be unreasonable from acost 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 ofthe partbeing produced (e.g., hull, deck, etc.). Formany 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 ifthe facility couldbe arranged so that the molds are handled in an assembly line manner, or situated so that one machine could be easilypositioned to 

### feed a number ofmolds'. As with pre-preg, this technologyhas notbeen used by leisure boat manufacturers. Itis not feasible for Crownline to make theirboats in an assembly-line manner. 

### (6) Controlledspraying- Controlled spraying is awork practice thatis very effective in reducingstyrene emissions from the open molding process. Itis an emissions source. reduction method, which benefits the manufacturing process, plant**perso~nel,** 

### the environment, and reduces cost. Controlled spraying reduces styrene emissions byincr.easing material transfet efficiency through overspray minimization. There are three elements of controlled spraying, whichwork together to reduce emissions: (1) operation ofthe spray gun at the lowest functional fluid tip pressure which produces an acceptable spraypattern; (2) operator training that teaches proper spraygun handling techniques; and (3) the use of mold flanges to minimize spray offthe mold edge. Crownline already employs controlled

1663007.3 12spray 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 apr9cess that begins with the application ofa gelcoat to one orboth sides ofthe mold, depending on requirements. Glass reinforcing and other materials, such as core stock, "re placed in the bottom-halfofthe 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. Inletports and vents are normally located in the top halfofthe mold. Crownline has determ.ined that RTM is not feasible at their facility because the boatproduct is too sensitive to damage during manufacture resulting in the scraping ofnumerous damaged parts. Finally, retooling costs could be 20 times the current costofconventional tooling. 

### (8) Resin infusion

- Resin infusion shares many ofthe characteristics ofvacuum bag molding and resin transfermolding (RThI) butis based on a patentedresin 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 ofthis 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) VECSystem

- VEC TechnologyDescription At the request'ofIEPA, Crownline has in,-estigated anew technOlogy thatis 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 briefdescription ofthe VEC Technology is included in this section but amore detailed one is found 

## ill Appendix 9. TheVEC technologyis a complex, patented, computerized system thatmanages the entire injection molding process, including all equipment operations and the curing ofresins. It controls the elements ofthe 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 ofthe part to be produced that's mounted on awater-filled pressure vessel, creating a low-pressure, closed-mold process. 4
. Here are some otherbasic facts about the VEC Technology 4:

• Protected by 31 Patents

• Most boatbuilding companies are either too small to take advantage ofthe system, or are already wedded to otherprocesses thatwould 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 ofinvestmentis far greater than the cost to get an open-mold boatbuilding operatlOn going

• Notgood for building customized largerboats Crownline has cOntactedGenmar and VEC technology owners to determine ifitis possible to implement the VEC technology at our Cr9wnline facility. The main issue tl:at Genmaris dealing with conceming \'EC 

### technology is whether they should license this technology to
. its competition. Genmaris promoting the licensing ofthe VEC technology to manufacturers ofFiberglass Reinforced Plastic products other than boat builders. Genmar's management does not believe itmakes sense for them to license it to their competitors in the boatbuildingindustr,. In summary, the VEC technology appears to allow certain types ofboats to be produced with significandy reduced

### VOM (styrene) emissions. However, the initial capital cost ofa 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 boatmanufacturingindustry, it cannot be considered a viable alternative regardless ofits ability to produce boatparts while significandy reducing

### VO:\I emissions.

- 4.2.3 Evaluation ofFiberglass Reinforced Plastic Manufacturing Technologies For Application at Crownline Boats For purposes ofe,-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 ormore ofthree categories ofreasons that define why these FRP productmanufacturing technologies cannotbe practically applied at Ctownline. These three categories are: 

### A. Prohibitively high re-tooling cost; B. Would require Crownline to 

### completely change irs production methods resultingin drastically reduced production efficiency, thereby, requiring a far greaternumber oflabor hours to complete the hull and deck ofeach boat. This would increase manufacturing costs beyond thatwhich couldbe recovered competitivelyin the price ofthe boat; C. 

### Significantloss offuture 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) ofboats that Crownline now has the ability to produce on aregularbasis. The following table identifies which ofthese three categories apply to each ofthe listed alternative technologies.

-

1663007.3 

## CategoryA

14 

## Category B Category C

## Technology Open Moldin? Methods (1) Flow coatresin applicators


## - - 

### (2) Controlled sprayin?;

- -T 

### (3) RollerApplication

- -..j -..j 

### (4) Prepre?;
. 

### 'i 'i -..j 

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

### 'i (6) Vacuum**ba,~aing** - 

### ;J 

### 'i ClosedMoldin" Methods (7) 

### Resin Infusion ;J ;J 

### 'i (8) RTM ;J ;J ;J (9) VEC System ;JT T T



### T

- The VEC System is aproprietalY methodology ownedby the Genmar Corporation and is only available to non-competing fiberglass manufacturing companies ,-ia license from Genmar (not

- available to Crownline or any otherboatmanufacturer), Please note, however, that the installation offlow coat chopper guns (under open molding methods) and reducing gelcoatVOM content are both viable methods that can and are beingused by Crownline Boats to comply with t,L'\CT. Similarly, Crownline already switched to low styrene resins (early in the Fall of2001). Also, Crownline employs controlled sprayingin its gelcoat operations. This allows Crownline to reduce material usage, improve productquality and, concomitantly, reduce styrene ermSSlOns. 

### The cost ofeach altemate manufacturing method aside, itis important to hote that, other than for resin application using air-atomized chopper guns or flowcoat chopper'gunguns, there is no quantitative data that we know ofwhich accurately shows how much Styrene and/or VOM emissions would actually be reduced ifany ofthese 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 chopperguns and flow coat chopper guns for resin application. Therefore, even ifCrownline could afford to modify its plant to employ another manufacturing technology, there would be no assurance that this would meet the Slb/hrRule on a stricthourly basis as interpretedby IEPA. Finally, all ofthe above-listed manufacturingmethods 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 exceptlow-HAP gelcoats. In summary, information on the use ofaltemate manufacturingmethods/technologies strongly suggests that, other than converting to flow coatchopper guns forresin application and reducing the HAP content ofthe gelcoats to the 33% iYL'\CT compliance level (which Crownline has done), respecti,-ely, there are no altemative manufacturingmethods/technologies that canbe used by Crownline to complywith the Slb/hrRule on astricthourly basis. 4.3 Method3

- VOC ReductionThrough theApplication oETail-End Emission Control Equipment

1663007.3 

### 15

### 4.3.1 Evaluation ofTail-End Emission Control Equipment ForPurposes ofMACT Compliance In developing the Boat Manufacturing NES!-L\P, USEPi'\. had a number ofstudies performed to evalmte avariety ofemission 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 ofone such study are presented in the report tided, ':AJSeJJI71entofS Iyrene EJ11ission ControlJforFRP/ 

### CandBoatBuilding InduJtn'eJ"

### EPA Contract 68-D1-0118, \Y/.A. 

### 156, As 'a result ofthese 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 onepartialexception, no hoatmamladurerscurrentlYemploy 

### ClIIJtailstack emission tontroltechnologiesto redllt:e 

### H-4.Pemissions;

• The very highair flows needed

### by fadlities to tomply tvith OSHA'Jrequirementto maintain worker

### 8-hr expoJ1Ire levels forJI)'rene make the tOJtof emission controlsystemsvery high;

• &duttioJlofH-4.P contentof resins, gelcoatandothermatenalsare achievableandcan significantlyredJlt, total H-4.P emiJJionJwithoutplatingan und1le finandalb1lrden on the boatmamlactttn'ngind1lstry.
. 

### Having been an activelyinvolved stakeholderin 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 ofcontrols: 1. 

### PreconcentratOr (both fluidized bed and rotary designs) with RTO Oxidation; 2. Catalytic Oxidation (with 0% heatrecovery); 3. Condenser; 

### 4. Carbon and polymer-based adsorption systems; 5. Thermal Oxidizer (with 0% heatrecovery); and 6. Biofiltration. 4.3.2 Evaluation ofTail-End Emission Control EquipmentFor SpecificApplicationto Crownline's Operations At Crownline's request, _-'lEA reviewed the applicability ofthese VOC emission control technologies, takinginto account physical and operational constraints specific to Crownline's production facility. By doing so, AEA quickly narrowed the list ofpotential control technologies from the six categories listed above to only oxidation using an RTO precededby apre-concentrator system (to reduce total airflow that mustbe 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 thatwould 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

-ifthe ventilation airis 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 thatwould be presentin the high volume air stream**~ess** 

### than 25 ppm); and (3) the presence ofparticulate matter from overspray in the gelcoat and lamination areas thatwould contaminate. certain control systems (e.g., carbon orpolymer 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 16A 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 avariety oforganic 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 ofone cir two, easily recoverable and recyclable solvents. Therefore, due to the high flow rate, low VOC concentration and the mL"ture oforganics in the air stream thatwould needto be treated from Crown!ine's boatproduction operations, a condenser system 

### is not a feasible control for Crownline. A straight thermal oxidizeris not economically feasible due to the extremely high operatingcostthat would result from heating 654,000 cfm of

### air to achieve the required destruction temperature of
. 14500F (very high fuel usage needed to attain operating temperatures high enough to thermally convert the VOCs to C02 andwater ,-apor)
.

. The presence ofPM in the ventilation 

### air stream to be treated would contaminate any ofthe carbon

orpolymer-based absorption media unless a high efficiency particulate matter control system wer, also installed. The additional cost ofsuch a system makes any ofthe adsorption systems economicallyinfeasible. Crown!ine's consultant, AEA, examined available emission control technologies for specific applicability to Crown!ine's operations for purposes ofcomplying with the 8 lb/hr Rule on a strict hourly basis. This included obtaining cosr quotes from a selectnumber ofcontrol system suppliers. The vendor quotes were inserted into a spreadsheet developed by USEP.1-. USEPA's spreadsheet was used in support ofthe study titled, 

### "Assessmentof StyreneEmission ControlsforFRP/C andBoatBuildingIndustries". The spreadsheetwas downloaded from USEPA's website. A costper ton ofpollutantremoved was calculated for arate of654,000 cfm which includes lamination and gelcoat areas and all other areas where YOM materials are usedin significant amounts. The results ofthe cost/ton estimates using the USEPA spreadsheetare summarizedin Table 4-1 which shows acomparison ofselected YOM emission control systems evaluated by AEA. As can be seen from Table 4-1, the costper ton ofcontrolled YOM for treating the air flow from Crown!ine's operations ranges from approximately $35;000 to $58,000. Copies ofthe spreadsheets used to compute these cost/ton ,-alues are presentedin Exhibit4 ofAppendLx 6. These values also assume a control efficiency ofonly 85% which is the levelrequired to complywith the 8 lb/hourRule on a stricthourly basis (35 IAC 215.302 (a), 

### (b) or (c). The up-frontcapital costs for the control technologies showninTable 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 generatethe values presented in Table 4-1 are presented inAppendix 10. Copies ofvendor quotes and related information are located in Appendices 11-15.

1663007.3 17Based upon these costs and the costper ton values generated using the 

### USEP},. spreadsheet, itis reasonable to conclude that the installation ofemission controls for Crownline's operations is not economically feasible. Itwould not allow Crownline to remain competitive in a market where CrownIine's competition operating outside ofIllinois would not have to install such controls. As a result, tail-end controls are not a feasible option regardless ofwhich technology one may choose to apply. The primary reason for these high costs is the very large volume ofair (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 stricthourly basis. This large volume ofairis necessary to maintain compliance with 

### aSK -\.'s 8-hourworker 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. Itis important to note that this design took into account the feasibility ofusing methods to limit (reduce) the amount ofair needed to comply with the 

### aSK-\. styrene standard. Itwas 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 ofthe physical " modifications, increasedlaborcOStS associated with the greater amount oftime required to build each boathull and deckwould go farbeyond that which Crownline could competiti\"ely recoverin the price ofthe boat. In summary, the application oftailstlck emission controls is not aviable method forreducing

### VOM emissions in order to comply with the 8 Ib/hr Rule on a stricthourly basis. The ptimary basis for this conclusion is the prohibitively high cost ofsuch controls as a result ofthe high 

### air,"olumes required to comply with the 

### aSH..-\ 8-hour worker exposure limitfor styrene.

1663007.3 18

# TABLE 4-1 Crownline ControlTechnology Evaluation Cost PerTon ofVOM Removed , , 

### Cost PerTon ofVOM ControlTechnology Name & 

### Vendor Removed (For a flow rate of654,000 cfin) 

### Preconcentratorwith RTO Oxidation

- Frees Quote 538,302 

### Rotary Concentratorwith RTO Oxidation

- MegTec Quote 534,917 

### Rotary Concentratorwith 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 oftheir srody "Assessment of Styrene Emission Controls for FRP/C and BoatBuilding 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 of654,000 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 NIACTcompliance values for gelcoat, lamination and final assembly emissions.

1663007.2

### 5.0 QUANTITATIVEAND QUALITATIVE IMPACT OF CROWNLINE'S OPERATIONS ON AMBIENT AIR QUALITY This Section presents a discussion ofthe 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 ofgeneral applicability, it appears that the impact on ambient air quality ofVOM 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 ofOzone ImpactAnalyses The AmbientAir Quality (.-\
..AQ) ImpactAnalysis was performedby .-\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 abasis. The Dale monitoris located 25 miles ENE ofthe Crownline facility and is otherwise sited in alocation appropriate for determining impacts ofCrownline's operations on outdoor ambient ozone levels. It 

### should be noted that the IEPA monitorwas sitedin its presentlocation forreasons not related to Crownline or any ofits operations. The analysis, which is quantitative in nature, was performedbyAE.-\ using amethod developed by USEPA. This method is tided, "VOC/NO, Point Source ScreeningTables" by Richard D. Scheffe, September 19886 

### For purposes ofthis report, itis referred to as the "Ozone ScreeningMethod". A copy ofthe substantive sections ofthis method is presentedinAppendix 16. The Ozone Screening Method is based on examining the short term (24hr) maximum amount of VOCs and also the average annual amounts ofboth VOCs and NO, that the source in question emits. Using this information, the method requires a computation to that establishes areference value for subsequentuse in either oftwo tables that estimate the amount ofozone lil<ely to be formed for differentreference values. One table is designed for addressingimpacts from sources located in rural areas only and the other table is for sources in urban areas. This procedureproduces 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 ofthe area that can be impacted by the VOC/NO, emissions from the source ofinterest. This combined value is then compared to the National ,-\mbientAir Quality Standard (NMQS) for ozone (I-hour standard) of 0.12 ppm to determine ifthe impactwill cause (or contributed significandy enough) to the exceedance ofthis I-hour ozone standard. After computing the amount ofozone predictedby the Ozone Screening Method, the results show that the potential impactfrom Crownline's operations willnot cause ozone concentrations at the Dale monitorto exceed the NAAQS of0.12 ppm. The maximum le\-el ofozone that the Ozone Screening Methodproducedis 

### 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 monitoringreports corresponding to these three years). A copy ofthe calculations performed and assumptions used byAEA 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 AirPollutants for BoatManufacturing

- FRVol. 66, No. 163

- Wednesday, August 22, 2001, Pgs 44232- 44250 2. "Assessment ofStyrene 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 ofEastern Carolina University, which is posted on the Pacific NorthwestPollution Prevention Resource Centerwebsite, Seattle, W/A (pPRC \Veb site is 

### ajoint project ofthe \'<;'ashington State DepartmentofEcology 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 ofthe descriptions in the Supporting document are from suppliers and vendors ofthe 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 onAugust 15, 2001. 6. "Ozone Screening Method

- "VOC/NOx

### Point Source ScreeningTables" 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

nda Dealer:!Zip 

### go .....•



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- 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' Cockpitwet bar**~:;:;~;l~fj- ,~.'~.:-c;~:~**  

### $£;%**=~n Cqpyljg_lJ~**  ©2003 Crownline Boats.

### 'O\vnline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys. Runabouts, Bowriders
.Page 1 of

nd a Dealer.IZip 

# 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 

# I!!!!I.**~.**

,C:.o.pyright © 2003 Crown line Boats.

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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 overengine 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 ofthe 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 galleywith wet bar • Compass and depth sounder· Roomy berth amidships· US Coast Guard Approved· NIMMA Certified· Member of the ABYC

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ind a Dealer: !Zip go 

### 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 ofstorage space· Lockable ski compartment and glove box 202 BR

. 20' 2" Bowrider NS'Nly designed upholstery pattern' Choice bf3 interlor layouts' Sleek design and perfonnance capab1l1ty· Impressive list of standard equipment· Just right for swimming, Iishing, sunning orjust 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 ofsport 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 of3 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 ofthe 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 ofweVdry 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 ofstandard 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 watersystem - 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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# ABOUT CROWNlINE about c.rownline glossary stOff.:



### HISTORY The first Crownlines were built in avery small manufacturing facility located in Whittington, Illinois. The upholstery shop was situated separately in avacant grade school gymnasium. The first boat produced, a 182BR, rolled offthe line on March 25, 1991. At thattime Crownline employed less than 25 people and had yet to sign adefinitive dealer. By July 1991, Crownline had grown out of its Whittington location and was forced to find a largerfacility. 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 halfyears 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 networkconsists 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, Crownlineownline 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**.c',::,d~'l** L1ur1**CI~xton ~1dcr** **\'.~e .c·r::ld~'l** **n.:l.~'Dn:l1 W:~r.nc** 

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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 over40 years of successful boat manufacturing experience.· Fred Claxton began his boat manufacturing career over25 years ago as an executive of one of the premier boat companies of that era. After several years ofsuccessful 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 majorfactor 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 howyourboat is equippedand'::>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 of4

, .... ,- .. , J"l:e,nJJlc.n.ll ),J')'me Cer:.rl'::OIJIC'l**tn~;l':J:e TlJn"~Oflilol~** **~.'(O:I!** LI'Tlllo:l**S~rtl:Jwq** WJll.lI"II'/ 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 barat the top ofyour 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'



### WestFrankfort, IL 62896 618-937-6426 

### phone 618-937-2277 

### fax

GopY.right 2003 Crownllne Boats.

### ownline Boats: SportBoats, Fishing Boats, Cruisers, Cuddys, Runabouts, BOWTiders Page 1 of2

about crownlin£: glossary stOfE: owners' dub rally :ld a Dealer:

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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 craftfitted to meet their needs whether bowrider, deck boat, cuddy or cruiser. And we give them whatthey askfor 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 afterthree 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 ofany 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 exteriorfinish in a wide range of colors, including the difficult-te-produce deep hues many builders shy away from.

Ilr·di**r~~·til,1** n;t1**l·ip~rgb** . .;s 2411'1. Wo\'en**l{\~\"i~** 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 ofthe newlyformed hull. Encapsulated in fiberglass, this system is warranted for Iffe. A fiberglass liner is then affixed atop the stringers toform Crownline's fully insulated and double-reinforced hull, unique within the Industry. Thafs howthe Crownline way of building boats begins. Form and function start here and quality is built in as construction progresses.



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### line Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page 2 of2



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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-resistantfor 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 ofthese 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 19feet is equipped with oUr shock absorbing bucket seat at the helm (two on some models). There's also atiit 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.nerand snap-In carpeting.

Seat, bench and cushion upholstery, which is warrantied for 5years against manufacturer defects, is covered with a soft, supple 34-ounce heavyweightvinyl v,ith a tear-strength that exceeds Industry standards by betterthan 20 percent. Butyou'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



## '" Butwe understand the importance of individual preferences and thafs why we've made available a full array of optional equipment that will letyou custcmize your own boat. From canvas, vinyl, instrumentation, trim; from cockpitto cabin, Crownline lefs you do yourway. You can also choose from an assortment of performance packages, entertainment systems. water systems, and more. And whateveryour optional choices, tbe materials and equipfT,ent are NMMAcertified-your assurance of qualitywith 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.

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### 'wnline Boats: Sport Boats, Fishing Boats, Cruisers, Cuddys, Runabouts, Bowriders Page I of3

about crownline glossary store owners" dub rally daDealer.!ZiP 

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# 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 ofthe largest builders ofstem-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 ofour dealers and the disceming product-acceptance of our customers. Now, with the introduction of our2003 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 onlywith our products. but throughout our entire business operation. This commitment is to our customers, ouremployees, 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 ofthese relationships. 

### Our Customers
OUfcustomers are the reason we are In business, and we are committed to theirtotal satisfaction during and afterthe sale.The entire focus of our business is to meet and exceed customer expectations throughout their entire ownership experience. As part ofour customer satisfaction efforts, we will. be expanding our support of regional ·Crowndezvous· where Crownline owners gatherto enjoy assorted boating activities and to meetwith Crownline sales and marketing personnel. We are also committed to the enhancement ofour 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 deliveranything 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** ofthe 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 projectwas conceived and acted on by the enUre company and stands as a definition of the character and quality ofthe people who build, sell and service our boats. 

### Our Dealers Page 2 of

From ourvery 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 oftheir 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 leaderwith 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 owners' dub rally 

# mIIII...... ABOUT CROWNLINE about <.t'owotilU!: gtossary storE:



### FORM, FUNCTION AND GUARANTEED QUALITY 

### , IN EVERY BOAT WE BUILD

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. '.**..*:.~~~-** The Crownline success story didn'tjuSI happen. We've made "Best In Class" our ultimate objective and we're well on ourway to achieving it.

a 

# lER#;- Every Crownline boat is buIlt to provide its owner or operatorwith 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 ofwhat 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 ofthe 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 ourwanranties are right at the top ofthe 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 bythe National Marine Manufacturers Association (NMMA). We are also one ofthe small and exclusive group of marine manufacturers who have eamed the designation "Marine Industry Certified", the seal ofour.commitment to total customer satisfaction. As a member ofthe 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-yeartt 

## 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-<lutfloor plans, seating anrangements, storage areas, the placement and quality offillings, 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 ora couple of hours of fun on the 

### , water. NAUTOLEX' '-4-- 

# attwood·**~ii·=~** SEATING

## mlf~~~' 

# Glirl"k'.\h."

I.!! LOWRANCE

# 1~7 

# mm 

# --= ThE:! Wise Cornpany, Inc

At the helm, the molded Novatron dash comes equipped with stainless steel bezeled Faria gauges with the cockpitfeaturing Taylor Made curved tinted safety glass walk-through windshields. Cockpit equipment includes LOWRANCE depth finder, INSTATRIM trim tabs and TeleflexiMorse steering system with filt steering wheel and SONY sound systems. The available 2 hole exhaust system Is byCORSA 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 ofour boats is upholstered wllh durable 34 ounce Nautolex marine vinyl with the exclusive PreFixx protective finish that resists stains, scuffs, grease, salt water and othersurface sailers. That Includes ourWISE
- 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 bowriderwith 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~** 

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# .- 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 ofCrownline's Operations

## CrownlineBoats

Photo 1: MoldPreparationPriorto GelcoatApplication

## CrownlineBoats

·Photo 2: GelcoatApplication Booth

## CrownlineBoats

Photo 3: GelcoatApplicationto Hull

## Crownline Boats

Photo 4: GelcoatApplicationto Deck

## CrownlineBoats

## Crownline Boats

## CrownlineBoats

Photo 7: Grind andTrimWork

## Crownline Boats

Photo 8: Upholstery

## CrownlineBoats

# Appendix 3 March 23,2000 Letterfrom IEPA To Crownline Boats Concerning NewEmission 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**_.-----_.~--~--_._---_**..

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## ---- 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-:,~_** '..=

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.. Illinois £PA det.erminations will t:e ba:s,e"d':upon '.,,:.

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P>\IN1I-I) ON Rrc.."YClW PAI'If,:**':~-:/~"**

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## JUN-07-2000 WED 04:48 PH EPA ::rv

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## PERMIT

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## 2175245023 P, 04

READ ME file fo= kP-42 Section 4.4 npolyester Resin Plastic ?roductz Fabrication tt
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 QUattro) 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"'0 ",.j U, 10 J

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- NVS' NVS NVS Date: December 1, :L9n**J-1onor.ler-3S~2** Nonomer-38'r Nono:ner 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"

- 15.4 5 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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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 E l 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._. _. 'Jc ) 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. '-0 C :z:

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U {Sec Document tl4} 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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