\ 

# Appendix 4 Baseline Characterization ofEmissions From Fiberglass Boat Manufacturers for NMMA, August, 1997 ,.'

### BASELINE CHARACTERIZATION OF EMISSIONS FROM FIBERGLASS BOAt MANUFACTURING FOR' 

### NATIONAL MARINE MANUFACTURERS ASSOCIATION

Prepared for National Marine Manufacturers Association 3050 KStreet, N.W., Suite 145
. Washington, D.C. 20007
Prepared by Stelling Engineering, PA 1319 Arnette Avenue Durham, North Carolina 27707

Air-Tech Environmental LLC 

### P.O. Box 12353

. Research Triangle Park, North Carolina 27709 Radian International LLC 

### P.O. Box 13000 Research Triangle Park, North Carolina 27709 August 1997Baseline Emission Testing 

### Table ofContents Page

, , 1.0 1NTRODUCTION**,~** , 1-1 1.1 Background 1-2 1.2 Purpose ofTesting 1-3 1.3 Testing 1-3 1.3.1 Test Enclosure 1-4 1.3.2 Process 1-5 1.3.3 Sampling Methods and Procedures , ,: 1-7 1.3.4 Molds : 1-8 1.3.5 Materials 1-9 1.3.6 Schedule : 1-10 1.4 Organization ofthe Report 1-10 2.0. RESULTS 2-1 2.1. Summary ofResults 2-1 2.2 Evaluation ofEmissions from Con:inuingTrace Concentrations**2~6** 2.3 CFAMold Results**,~** 2 c10 2.4 Results ofGelcoat Application Tesdng : : 2-13 2.5 Results ofResin Lamination Testing ,..: 2-16 2.5.1 Emissions as Percent ofAvailable Styrene 2-17 2.5.2 Flux Emissions 2-20 2.5.3 Normalized Emissions 2-21 3.0 CALIBRATION AND SAMPLING PROCEDURES : : 3-1 3.1 Process Procedures and Measlirerr.ems : 3-2 3.1.1 Application Procedures : 3-3 3.1.2 SprayEqUipment Calibration : 3-4 3.1.3 Gel Tilne 3-5 3.1.4 Styrene and Methyl Methacrylare Content.. ,:.3-6 3.2 Emission Testing EqUipment and Procedures :.: 3-7
iii

### BASELINE CHARACTERIZATION OF EMISSIONS FROM FIBERGLASS BOAt MANUFACTURING FOR' NATIONAL MARINE MANUFACTURERS ASSOCIATION

Prepared for National Marine Manufacturers Association 3050 K Street. N.W., Suite 145 Washington. D.C. 20007
Prepared by Stelling Engineering. P.A. 1319 Arnette Avenue Durham. North Carolina 21707

Air-Tech Environmental LLC P.O. Box 12353 Research Triangle Park. North Carolina 27709 Radian International LLC P.O. Box 13000 ResearchTriangle Park. North Carolina 27709 August 1997Baseline Emission Testing 

### Table ofContents Page
,, 1.0 INTRODUCTION : :•.................................................................. 1-1 1.1 Background 1-2 1.2 Purpose ofTesting 1-3 1.3 Testing 1-3 1.3.1 TestEnclosure 1-4 1.3.2 Process 1-5 1.3.3 Sampling Methods and ProcedureL...................................•....., 1-7 1.3.4 Molds.......................................................................................•.......: 1-8 1.3.5 Materials 1-9· 1.3.6 Schedule , 1-10 1.4 Organization ofthe Report 1-1 0 2.0. RESULTS : 2-1 2.1 Summary of Results , 2-1 2.2 Evaluation ofEmissions from Continuing Trace Concentrations 2-6 2.3 CFAMold Results ,: 2-10 2.4 Results ofGelcoat ApplicationTesting 2-13 2.5 Results ofResin LaminationTesting : 2-16 2.5.1 Emissions as Percent ofAvailable Styrene 2-17 2.5.2 Flux Emissions 2-20 2.5.3 Normalized Emissions 2-21 3.0 CALIBRATION AND SAMPLING PROCEDURES 3-1 3.1 Process Procedures and Measurements : 3-2 3.1.1 Application Procedures : 3-3 3.1.2 SprayEquipment Calibration : 3-4 3.1.3 Gel Time 3-5 3.1.4 Styrene and Methyl Methacrylate Content ::.3-6 3.2 Emission TestingE.quipmentand Procedures 3-7
iii D"., 1Baseline Emission Testing 

### Table ofContents (Continued) Page 3.2.1 Leak Check and Instrumept Calibration 3-7 3.2.1.1 3.2.1.2 Total Hydrocarbon Analyzer 3-8 Gas Chromatograph 3-10
3.2.2 Flow Rate Measurements 3-11 3.2.3 Temperature 3-12 3.2.4 Weight ofMaterial Used 3-12 .3.3 AirFlow Overthe Mold :3-13 3.4 Mass Balance Styrene Recovery Check 3-15 3.5 Data Custody , 3-16 4.0 QUALITY CONTROL AND QUALITY ASSURANCE 4-1 4.1 ConcentrationMeasurements 4-1 4.1.1 Total Hydrocarbon Measurements (Metho'd 25A) .4-2 4.1.2 Organic Compound Concentrations (Method 18) ; .4-6 4.1.3'. Comparison ofMethods in Determining.Emissions .4:12 4.2 Gelcoat and Resin Flow Rate ;, 4-14 4.3 AirVelocity over Mold Surface ;, 4-15 4.4 ExhaustFlow Rate 4-15 4.5 Exhaust AirTemperature 4-17 4.6 Resin/GelcoatBalance 4-17 4.7 Technical Systems Audit : 4-18 4.7.1 Total Hydrocarbon Measurement 4-19 4.7.2 Weigh Cell Balance : 4-20 4.7.3 Flow Measurement... : 4-22 4.7.4 Styrene Evaporation Test.. 4-22

iv Rev. 1APPENDICES APPENDIX A APPENDIXB

APPENDIXC APPENDIXD APPENDIXE APPENDIXF APPENDIXG APPENDIXH APPENDIX I BaseEr.e Emission Testing 

### Table ofContents (Continued)

,, ,, Reference Methods Construction ofa Temporary Total Enclosure for Volatile Organic Compound Emission Assessment During Manufacture ofFiberglass Boats Calculations Procedure for and Results ofGel Time Determination Material Safety Data Sheets· Certifications for Gas Standards and Equipment Calibrations Bag Standards :Location and Results ofAirFlow Over theMold Measurements

Comparison ofNMMA Results with Those from Other 5LUdies

v R"v. 1Baseline Emission Testing 

### Table ofContents (Continued) Page 3.2.1 Leak Check and**Instrume~t** Calibration 3-7 3.2.1.1 3.2.1.2 Total Hydrocarbon Analyzer 3-8 Gas Chromatograph 3-10
3.2.2 Flow Rate Measurements 3-11 3.2.3 Temperature , 3-12 3.2.4 Weight ofMaterial Used 3-12 3.3 Air Flow Over the Mold :..**:3~13** 3.4 Mass Balance Styrene Recovery Check : 3-15 3.5 Data Custody , , : 3-16 4.0 QUALITY CONTROL AND QUALITY ASSURANCE .4-1 4.1 ConcentrationMeasurements .4-1 4.1.1 Total Hydrocarbon Measurements (Metho'd 25A) .4-2 4.1.2 Organic Compound Concentrations (Method 18) .4-6 4.1.3" Comparison ofMethods in Determining Emissions ,..**.4~12** 4.2 Gelcoat and Resin Flow Rate : .4-14 4.3 Air Velocity over Mold Surface " : .4-15 4.4 ExhaustFlow Rate 4-15 4.5 Exhaust AirTemperature , 4-17 4.6 Resin/Gelcoat Balance 4-17 4.7 Technical Systems Audit : : 4-18 4.7.1 Total Hydrocarbon Measurement .4-19 4.7.2 Weigh Cell Balance : : .4-20 4.7.3 Flow Measurement... : :, 4-22 4.7.4 Styrene Evaporation Test... : 4-22

iv Rev. 1APPENDICES APPENDIX A APPENDIXB

APPENDIXC APPENDIXD APPENDIXE APPENDIXF APPENDIXG APPENDIXH APPENDIX I Baseline Emission Testing 

### Table ofContents (Continued)

,,
Reference Methods Construction ofa Temporary Total Enclosure for Volatile Organic Compound Emission Assessment During Manufacture ofFiberglass Boats Calculations Procedure for and Results ofGel Time Determination Material Safety Data Sheets·
. Certifications for Gas Standards and Equipment Calibrations Bag Standards '"Loc.ation and Results ofAir Flow Over the.Mold Measurements

Comparison ofN'tvHvIA Results withThose from OtherStudies

v Rev. JBaseline EmissionTesting

1-1 1-2 1-3 1-4 2-1 2-2 2-3 2-4 2-5 3-1 3-2 3-3 4-1 4-2 4-3 4-4 4-5 4-6 4-7 

### LIST OF TABLES Page t Parameters Studied ' 1-8 Surface Areas ofMolds Used in Test Program**l~9** Properties ofGelcoat and Resin Materials 1-10 TestSchedule 1-11 Summary ofTestResults , :..,..2-2 Emissions Measured During Application ofResin to CFA Mold 2 c11

- Emissions from Gelcoating as Percentage ofAvailable Volatiles 2-14 Total Emissionsfrom Getcoating Related to Mold Surface Area 2-15 Emissions Measured During Resin Lamination : 2-17 MeasurementsDuring TestProgram , 3-1 Gel Time Results : 3-6 Styrene and MMA Contents : : 3-6
. Acceptance Criteria for ConcentrationMeasurements .4-2 Calibration Error Measurements for Total Hydrocarbon Analyzer : 4-3 Calibration DriftMeasurements forTotal Hydrocarbon Analyzer. 4-4 Specific Compound Response Factors for the Total Hydrocarbon Analyzer 4-5 Method 18 Response Factors forTarget Compounds · ..: .4-7 Gas Chromatography Calibrations (after April12) .4-10 Comparison ofEmission Results by Two Methods :.:..: 4-12

"i Rev. 1Baseline Emission Testing 

### LIST OF TABLES (continued) Page 4-8 Spray Equipment Data Summary 4-14 

# . . 4-9 Variability Measures for Flow Rate During Test Runs .4-16 4-10 Results ofBalance Calibration 4-18 4-11 Audit Results for Method 25A Measurements 4-19 4-12 Results ofAudit ofBalance : .4-21 4-13 Results ofFlow Rate Audit , :.4-22 4-14 Results ofStyrene Evaporation Tests : .4-23

vii p""" TBaseline EmissionTesting 

### LIST OF TABLES Page

" 1-1 Parameters Studied ' 1-8 1-2
. Surface Areas ofMolds Used inTest Program 1-9 1-3 Properties ofGelcoat and Resin Materials 1-10 1-4 Test Schedule 1-11 2-1 Summary ofTestResults ,..2-2 2-2 Emissions Measured During Application ofResin to CFA Mold 2-11 2-3 Emissions from Gelcoating as Percentage ofAvailable Volatiles 2-14 2-4 Total Emissions from Gelcoating Related to Mold Surface Area 2-15 2-5 Emissions Measured During Resin Lamination :.: 2-17 3-1 Measurements.During TestProgram : , 3-1 3-2 GelTime Results : 3-6 3-3 Styrene and MMA Contents : : 3-6 4-1 Acceptance Criteria for Concentration Measurements 4-2 4-2 CalibrationErrorMeasurements for Total Hydrocarbon Analyzer .4-3 4-3 Calibration Drift Measurements for Total Hydrocarbon Analyzer :: : 4-4 4-4 Specific Compound Response Factors forthe Total Hydrocarbon Analyzer
......4-5 4-5 Method 18 Response Factors forTarget Compounds , .4-7 4-6 Gas Chromatography Calibrations (afterApril 12) 4-10 4-7 Comparison ofEmission Results by Two Methods : .4-12

vi Rev. 1Baseline Emission Testing 

### LIST OF TABLES (continued)

, Pacre <:> 4-8 Spray Equipment Data Summary" " .'"""""." """"".""""."." "
..""." 4-14 

# . ' , 4-9 Variability Measures for Flow Rate During Test Runs """""".""""""""""""".4-16 4-10 Results ofBalance Calibration "."." "
..""" "
.." "
.."
..'""" "."" 4-18 4-11 Audit Results for Method 25A Measurements ""
.."""""
..""""""""
.."
.."."""
.."4-19 4-12 Results ofAudit ofBalance ""
....".""
..."""""""
... "
.."."."""
.."",,"
.."
.."
...,,,""
....4-21 4-13 Results ofFlow Rate Audit..""
....."
....""""""""
.."
..."
.."
...."
.....""
..."
.."
.."
......".:.4-22 4-14 Results ofStyrene Evaporation Tests
.."".:
..""""."""""
..""
..""""".:"."".""
..."
..4-23

vii

### LIST OF FIGURES

( Baseline Emission Testing

Page 2-1 Summary ConcentrationTraces for Boat Lamination and Gelcoating.: 2-3 2-2 Emissions as Percentage ofAvailable Monomer.. 2-7 2-3 Total Hydrocarbon Concentration Trace for NMMA-4-1... 2-8 2-4 Concentrarion v. Cumulative Mass Emissions (NMMA-4-1) 2-9 2-5 Emissions from Lamination and Gelcoating ofthe CFAMold :.2-12 2-6 Gelcoat Emissions as Percent ofAvailable Volatiles , 2-14 2-7 Emissions from Gelcoating Related to Mold Surface Area 2-16 2-8 Emissions from Lamination as Function ofAvailable Styrene 2-18 2-9 Comparison ofResults byTest.. 2-19 2-10 Emissions fromBesin Lamination as Flux Measurement... 2-20 2-11 Average EmissionFlux Measurements for Two Resins : 2-21 2-12 Normalized Emissions from Resin Lamination : 2-22 4-1 Method 18 Response Factors for Styrene 4-6 4-2 Method 18 Response Factors for Methyl Methacrylate : .4-7 4-3 Method 18 Response Factors for SelectedTest Days .4-8 4-4 Comparison ofTotal Hydrocarbon Traces by Two Methods 4-13

viii Rev. 1:.. Baseline Emission Testina

. 0 ACKNOWLEDGEMENTS
The authors gratefully acknowledge U.S. Marine for the use oftheirfacility in Arlington, Washington, for this program. They provisied space, an outstanding facility for the program, an excellentenclosure (designed'and constructed by U.S. Marine), and outstanding support bytheir personnel. We wish to specifically recognize the follOWing people for their help in making the field work in Arlington such a success: Dennis Pearson, who, as our U.S. Marine site coordinator, provided constant oversight and· help in schedulingspace, personnel, molds, and materials; Dennis also spearheaded the
. design and fabrication ofthe temporary total enclosure, which exceeded all expectations for a test enclosure ofits size; Larry Dargitz, U.S. Marine's lead lamination training specialist, who conducted'the boat lamination work during this program; Ken Warren, U.S. Marine gelcoating specialist, who conducted all geltoating runs during the program; and Don Barnhill, who extended the invitation and ensured daily that the program had everything needed. We wish to express appreciation to Research Triangle Institute and theU.S. Environmental Protection Agency forfunding the supplemental testing offlow choppertechnology. We also appreciate"thesupport ofthis program by the EPA through its audit ofour tethnical systems. Finally. we wish to thank]ohn McKnight, the NMMA Project Manager. for his continued support ofthis testing program before, during, and afterthe field work.

ix Rev. IBaseline Emission Testing 

### LIST OF FIGURES Page 2-1 Summary ConcentrationTraces for Boat Lamination and**Gelcoating.~** 2-3 2-2**Emi~sions** as Percentage ofAvailable Monomer. 2-7 2-3 Tote) Hydrocarbon Concentration Trace for NMMA-4-1.. 2-8 2-4 Concentration v. Cumulative Mass Emissions (NMMA-4-1) 2-9 2-5 Emissions from Lamination and Gelcoating ofthe CFA Mold**~.:.2-12** 2-6 Gelcoat Emissions as Percent ofAvailable Volatiles 2-14 2-7 Emissions from Gelcoating Related to Mold Surface Area 2-16 2-8 Emissions from Lamination as Function ofAvailable Styrene 2-18 2-9 Comparison ofResults byTest.. : .- 2-19 2-10 Emissions fromResin Lamination as Flux Measurement... 2-20

.J". 2-11 Average Emission Flux Measurements forTwo Resins , 2-21 2-12 Normalized Emissions from Resin Lamination : 2-22 4-1 Method 18 Response Factors for Styrene .4-6 4-2 Method 18**Re~ponse** Factors for Methyl Methacrylate : 4-7 4-3 Method 18 Response Factors for Selected Test Days .4-8 4-4 Comparison ofTotal HydrocarbonTraces by Two Methods : 4-13

viii Rev.lBaseline Emission Testina
.
. 0 ACKNOVVLEDGEMENTS
The authors gratefully acknowledge U.S. r-Iarine for the use oftheir facility in Arlington, Washington, for this program. They provil;Jed space, an outstanding facility for the program, an excellent enclosure**(designed~and** constructed by U.S. Marine), and outstanding support by theirpersonnel. 'vVe \,.-ish to specifically recognize the folloWing people for their help in making the field work in Arlington such a success: Dennis Pearson, who, as our U.S. Marine sHe coordinator. proVided constant oversight and' help in scheduling space, personnel, molds, and materials; Dennis also spearheaded the
. design and fabrication ofthe temporary rotal enclosure, \vhich exceeded all expectations for a test enclosure ofits size; Larry Dargitz, U.S. Marine's lead lamination rraining specialist, who conducted·the boat lamination work during this program; Ken Warren, U.S. Marine gelcoating specialist, who conducted all gelcoating runs during the program; and Don Barnhill, who extended the invitation and ensured daily thatthe program had everything needed. We wish to express appreciationto Research Triangle Institute and the U.S. Environmental Protection Agency for funding the supplemental testing offlo\V chopper technology. We also appreciate"thesupport ofthis program by the EPA through its audit ofour tethnical systems. Finally, we wish to thankJohn McKnight, the NMMA ProjectManager, for his continued support ofthis testing program before, during. and after the field work.

\

Ix Rev. 11.0 INTRODUCTION Baseline Emission Testing



### Under contract to the National Marine Manufacturers Association (NMMA), Stelling Engineering, Air-Tech Environmental, arid Radian

" 

### International conducted testing in April 1997 to characterize baseline emissions from gelcoafing and lamination offiberglass boats, Testing was conducted in accordance with 

### the.QualityAssuranceProjectPlan For the NationalMarine ManuFacturersAssociation Baseline Emissions Testing Project (QAPP) approved by the U.S. Environmental Protection.Agency (EPA) in March 1997. Aquality assurance (QA) auditwas performed by the EPA during this program. Visits by. state regulatory authorities and other interested parties were also made during testing.
The test program was designed to be as representative as possible ofactual fiberglass boatmanufacturing. Testing was conducted atthe U.S. Marine (Bayliner) fiberglass boat manufacturing, research, and developmentfacility in Arlington, Washington, in an eJ).closure (inside awooden

. - , 

### model fabrication area) made available for this purpose. Tne volatile organic compounds (Yoe) 

### measured during this program were generated from operations identical to those in actual production, that is, using actual boat part molds, spray equipment, resins and gelcoat, and laminatingprocedures and techniques typical ofthe industry. Experienced manufacturing personnel. conducted the lamination and gelcoating. Only a few runs incorporated amold or spray techniques not typical ofthe industry: suchruns were designed to .. produce data for comparisonwith previous emission tests. During this sampling program, Research Triangle Institute (RTI) conducted a research program to ascertain the Viability ofmeasuring emissions

1 1Baseline Emission Testing from lamination and gekoating operations using amass balance approach, RTI's program was funded by the EPA's Office ofResearch and Development (ORD) and will be reported independently,
1.1 Background 

### , (,

Within the past two years, several important sampling and analysis programs have sought to detennine styrene emissions from open molding of polyester resin fabricated partS: Most important among these studies were the studies conducted by RTI for the EPA and by Dow Chemical USA for the " Composite Fabricators Association (CFA),The results from these programs raise questions about the emission factors published in the EPA's compendium of emission factors, AP-42, especially for molding oflarge parts manufactured by the marine industry. Still, none ofthe tests to date adequately represent industry practice or conclusively demonstrate the effeer ofmold size and styrene content

. - :.. 6fresin on emissions, For'example, the results ofthis test program indicate that the relationship between emissions ofstyTene as percerit"ofavailable styrene in the resin and increasing styrene content does not appear to be constant. Further, an increase in mold size resulted in increased flux emissions (pounds styrene per square foot ofsurface area ofmold) but decreased normalized emissions (pounds styrene per 1000 Ib resin per square foot ofmold surface area). Also, none ofthe previous tests included gelcoar containingmethyl methacrylate (MMA) , which is commonin the boat building industry.



### 1-2

# ------..- N;YiJ-fA 411T.I-I.JI!II1' Baseline Emission Testing 1.0 INTRODUCTION
Under contract to the National Marine Manufacturers Association (NMMA). Stelling Engineering, Air-Tech EnvironmentaL and Radian ,

### , International conducted testing in April 1997 to characterize baseline emissions from gelcoating and lamination offiberglass boats. Testing was conducted in accordance with the 

### QualityAssuranceProjectPlanfor the NationalMarine Manufacturers Association BaselineEmissions Testing Project (QAPP) approved QY the U.S. Environmental Protecrion.Agency (EPA) in March 1997. A quality assurance (QA) audit was performed by the EPA during this program. Visits by. state regulatory authorities and other interested parties were also made during testing.
The test programwas designed to be as representative as possible ofactual fiberglass boatmanufacturing. Testing was conducted atthe U.S. Marine (Bayliner) fiberglass boat manufacturing. research. and developmentfacility in Arlington. Washington. in an**enc~osure** (inside a wooden. model fabrication area) made available for this purpose. Tne volatile organic compounds (VOC) measured dUring this programwere generated from operations identical to those L'1 actual production. that is. using actual boat part molds. spray equipment. resins and gelcoat. and laminating procedures and techniques typical ofthe indusrry. Experienced manufacturing personnel conducted the lamination and gelcoating. Only afew runs incorporated amold or spray techniques not typical ofthe industry; suchruns were designed to produce data for comparison\\ith previous emission tests. During this sampling program. Research Triangle Institute (RTI)
. conducted a research program wascertain the viability ofmeasuring emissions

'-1 Rev.lBaseline Emission Testing from lamination and gelcoatingoperations using amass balance approach. RTI's program was funded bythe EPA's Office ofResearch and Development (ORD) and will be reported independently.·
1.1 Background , ,.
Within the past two years, several important sampling and analysis programs have soughtto determine styrene emissions from open molding of polyester resin fabricated parts. Most important among these studies were the studies conducted by RTI for the EPA and by Dow Chemical USA for the .' Composite Fabricators Association (CFA). The results from these programs raise questions about the emission factors published in the EPA's compendium of

, 

### - emission factors, AP-42, especially for molding oflarge parts manufactured by the marine industry. StilI, none ofthe tests to date adequately repreSent industry practice or conclusively demonstrate the effect ofmold size .and styrene content 6fresin on emISsions. For example, the results ofthis test p;ogram indicate that the relationship between emissions ofstyTene as percent ofavailable styrene in the resin and increasing styrene content does not appear to be constant. Further, an increase in mold size resulted in increased flux emissions (pounds styrene per square foot ofsurface area ofmold) but decreased normalized emissions. (pounds styrene per 1000 Ib resin per square foot ofmold surface area). Also, none ofthe previous tests included gelcoatcontainingmethyl methacrylate (MMA), which is commonin the boat**b~ilding** industry.

1-2_____ -AT .NMMA**~.#JfII".6'** Baseline Emission Testino

_ 0 

### 1.2 Purpose ofTesting
The primary project objective was to characterize total hydrocarbon (THe), styrene, and MMA emissions from:the open molding process that is representative offiberglass boat manufacturing, specifically spray up ge1coat application and resin application. Hand lay-up, defined as the application of glass and resin that are mixed manually and applied by brush, was not part of this study. A technique comparable to hand lay-up found in the industry is the use ofa flow chopper, a glass chopper similar to the resin chopper gun but equipped with a low-pressure, non-atomized resin delivery system resembling? nozzle not unlike a showerheadthat exudes catalyzed resin. The principal difference between this technique and conventional spray up application is that resin atomization is avoided. Sampling during laminationusing aflow chopper was conducted to augment the test matrix planned for this program; this supplemental sampling was funded by the EPA through RTI.
This .,;tudy was designed to produce data fOF estimating emissions from lamination ana gelcoating in fiberglass boatmanufacturing plants. The data and analyses reported in this document are intended to be useful to plants in compiling emission inventories and assessing permitneeds or changes.
1.3 Testing Sampling was completed by Darrell Doerle ofAir-Tech Environmental andJohn Stelling ofStelling Engineering. Testing was coordinated with U.S. Marine personnel by John McKnight, NMMA's project manager. Larry Dargitz ofU.S. Marine operated the resin application

Rp,\1 1Baseline Emission Testing equipment, and Ken Warren ofU.S. Marine applied gelcoat for those experiments.
Tests were also coordinated with Bob Wright, Emery Kong. and 

### , Mark Bahner ofRTI. RTl conducted a study in an adjacent enclosure under contract tothe EPA's ORD to measure emissions from the same lamination

.operations as conducted for this program but applied to a small panel. The goal oftheir program was to develop asimplified material balance approach for determining emissions from fiberglass lamination
.

.1.3.1 TestEnclosure
The testing was carried out atthe U.S. Marine manufacturing and research facility in Arlington, Washington. The test area was located in a woodenmodel fabrication area where tool plugs are fabricated. A large test enclosure (20 ft by 45 ft by 14 ft) meeting the total temporary enclosure (TIE) requirements ofEPA Method 204 (included in Appendix A) was erected in this
> . - . 27-ft by 50-ft area to accommodate tools (I.e., molds) ranging from 18 to 28 ft in length. Sufficient space was provided in the enclosure: to allow technicians to.' work around the tool and to move the tool as needed to apply gelcoat and resin. A description ofthe TIE is contained in Appendix B. Natural draft openings (NDOs) were arranged in accordance with EPA Method 204. Measurements were made to ensure that the airvelocity across the mold surface was comparable to thatmeasured in the manufacturing ar:e'a.
The exhaust system for the entire model preparation room comprised a dual pick-up system at one end ofthe room (near the constructed enclosures) exhausting to a single induced draft fan. The fan had 20,OOO-cfm

1-4 Pou 1_____ AT 

### ./yMMA '-'-'-.6' Baseline Emission Testing 

### 1.2 Purpose ofTesting
The primary project objective was to characterize total hydrocarbon (THe), styrene, and MMA emissions from !he open molding process that is , 

### representative offiberglass boat manufacturing, specifically sprayup gelcoat application and resin application. Hand lay-up, defined as the application of glass and resin that are mixed manually and applied by brush, was not part of this study. A technique comparable to hand lay-up found in the industry is the use ofa flow chopper, a glass chopper similar to the resin chopper gun but equipped with a low-pressure, non-atomized resin delivery system resembling a nozzle not unlike ashower head that exudes catalyzed resin. The principal difference between this technique and conventional spray up application is that resin atomization is avoided. Sampling during lamination using a flow chopper was conducted to augment the testmatrix planned for this program; this supplemental sampling was funded by the EPA through RTI.
This study was designed to produce data for 'estimating emissions

- .**.~.** . 

### from lamination ana gelcoating in fiberglass boat manufacturing plants. The data and analyses reported in this document are intenped to be useful to plants in compiling emission inventories and assessing permit needs or changes.
1.3 Testing Sampling was completed by Darrell Dberle ofAir-Tech Environmental andJohn Stelling ofStelling Engineering. Testing was coordinated with U.S. Marine personnel by John McKnight, NMMA's project manager. Larry Dargitz ofU.S. Marine operated the resin application

1-'l Rev.!Bas=Hne Emission Tesdng equipment, and Ken Warren ofU.S. Marine applied gelcoatfor those experiments.
Tests were also coordinated with Bob Wright, Emery Kong, and 

### , Mark Bahner of

### KrI. RTI conducted astudy in an adjacent enclosure under contract to the EPA's ORD to measure emissions from the same lamination operations as conducted for this program but applied to a small panel. The goal oftheir program wasto develop a simplified material balance approach for determining emissions from fiberglass lamination.
1.3.1 Test Enclosure
The testing was carried out at the U.S. Marine manufacturing and research facility in Arlington, Washington. The test area was located in a woodenmodel fabrication area where tool plugs are fabricated. A large test enclosure (20 ft by 45 ft by 14 ft) meeting the total temporar:: enclosure (TIE) requirements ofEPA Method 204 (included in Appendix A) was erected in this 27-ft by 50-ft area to accommodate tools (Le., molds) ranging from 18 to 28 ft in length. Sufficient space was prOVided in the enclosureto allow technicians to .. work around the tool and to move the tool as needed to apply gelcoat and resin. A description ofthe TTE is contained in Appendix B. Natural draft openings (NDOs) were arranged in accordance with EPA Method 204. !vleasurements

.were made'to enslfre that the air velocity across the mold surface was comparable to thatmeasured in the manufacturing area.
The exhaust system for the entire model preparation room comprised a dual pick-up system at one end ofthe room (nearthe constructed enclosures) exhausting to a single induced draft fan. The fan had 20,000-cfm

1-4 

### Rev.]Baseline Emission Testing 

### capacity. far more than needed to exhaust the two enclosures. Atthe start ofthe program, some ofthe pick-ups were closed to develop sufficient draw through the enclosures. The flow rate was balanced with both enclosures in use so that the turnover through the large enclosure**u~ed** 

### for NMMA testing was comparable to that inthe manufacturing areas on site (i.e., about 16 room changes per hour). On-site checks in the production area verified this range. The enclosure was equipped with two 10-in. plena for exhausting the enclosure. Three-inch openings were installed every 3 ft in each plenum and covered with spunfiberglass filter media. Airwas suppliedto the enclosure through a 12-in. plenum in the ceilingofthe enclosure. This plenumwas open on both ends. limiting the NDO associated with the inletair plenumto 1.571 ft2. The enclosure was equipped with'a door (which remained closed during testing) and a zippered end for changing application equipment and molds between tests. Thus. the openings on both ends ofthe inletair plenumwere the only. NDOs. The openings in this plenum satisfied the requiremEmts ofMethod 204 for a

### TIE. representing only 0.043 percentofthe total surface area ofthe enclosure.

- -**.~** 

### Also. considering a'flow rate of2.600 to 3.300 dm, the velocity atthe NDO was at least 1,655 ft/min. also satisfying Method 204 requirements. Air coming into the enclosure was monitored continuously for hydrocarbon concentration during each testrun in accordance withMethod 204; these data were recorded with other continuous monitoring data,
1.3.2 Process



### .The polyesterresin spray-up applicationprocess commonly useG in the boat building industry uses a "chopper gun" to apply a laminate. The chopper gun dispenses polyesterresin, catalyst, and chopped glass fibers,

1-5 Rev.!Baseline Emission Testing Continuous strand fiberglass roving is fed to achopper unit mounted on the spray gun and is cut into chopped fiber lengths ofapproximately 1.5 in. long. The chopped fiberis ejected from the chopperunit and is captured bY-the resin fan pattern a shortdistance from the sprayfun. The mixture ofthe catalyzed resin and choppec;l fiber is deposited on the'mold by the spraying action; Typical offiberglass boat manufacture, woven roving (a fabric material) was used with resin application by spray gun and flow chopper for the addition ofthis reinforcement. A Venus Gusmer G03 low-pressure slave arm internal mix airless chopper gun equipped with a 5003 tip, typical ofguns used in the industry, was used for spray application ofresin and chopped glass duringthis program. Resin was supplied to the chopper gun and the flow chopper by a Venus Gusmer system at a pump ratio of 11 to 1. The methyl ethyl ketone peroxide (MEKP)/dimethyl phthalate (DMP) catalystwas internally mixed for both chopper gun and flow chopper, with the catalyst delivered by a slave pump system. The flovy chopper was also aVenus Gusmerdesign
..The resin is delivered at a

### ~uch lowerpressure and no air is used to dispense theresin into the chopped glass. The glass is chopped into lengths using the same method as in the chopper gun, but because there is no atomizing air, the dispersion pattern ofglass and resin mixture is more narrow. Gelcoat is applied in the boat building industry using a spray gun, typically an airless air-assisted spray gun. For this program, gelcoatwas delivered to the spraygun using aPoly-Craft pump system at apump ratio of23' to 1. Catalyst, delivered using a metered feed pump, was mixed externally. A . Poly-Craft 755 airless air-assisted spray gun (eqUipped with a0.026 tip size) was used during this program.Baseline Emission Testing 

### capacity, far more than needed to exhaust the two enclosures. At the startofthe program, some ofthe pick-ups were closed to develop sufficient draw through the enclosures. The flow rate was balancedwith both enclosures in use so that the turnoverthrough the large enclosure**u~ed** 

### for NMMA testing was comparable to thatin the manufacturing ar'eas on site (i.e., about 16 room changes perhour). On-site checks in the production areaverified this range. The enclosure was equipped with two 10-in. plena for exhausting the enclosure. Three-inch openings were installed every 3ft in eachplenum and covered with spun fiberglass filter media. Air was suppliedto the**enclosur~** 

### through a 12-in. plenumin the ceiling ofthe enclosure. This plenum was open on both ends, limiting the NDO associated with the inlet air plenum to 1.571 ft2• 

### The enclosure was equipped with a door (which remained closed during testing) and a zippered end for changing application equipmentand molds between tests. Thus, the openings on both ends ofthe inletairplenum were the only
. NDOs. The openings in this plenum satisfied the requirements ofMethod 204 for a TIE, representing only 0.043 percent ofthe total surface.area ofthe enclosure. Also, considering a'flow rate of2,600 to 3,300 dm, the velocity at the NDO was at least 1,655 ft/min, also satisfyingMethod 204 requirements. Air coming into the enclosure was monitored continuously for hydrocarbon concentration during eachtest run in accordance withMethod 204; these data were recorded with other continuous monitoring data.

. 1.3.2 Process



### .The polyester resin spray-up applicationprocess commonlyused inthe boatbuilding industry uses a "choppergun" to 

### apply alaminate. The chopper gun dispenses polyesterresin, catalyst, and chopped glass fibers.

Rev.lBaseline Emission Testing Continuous strand fiberglass roving is fed to achopper unit mounted on the spray gun and is cut into chopped fiberlengths ofapproximately 1.5 in. long. The chopped fiber is ejected from the chopper unit and is captured bythe resin fan pattern a short distance from the spray

# run. The mixture ofthe catalyzed resin and choppec;l fiber is deposited on the'mold by the spraying action. Typical offiberglass boat manUfacture, woven roving (a fabric material) was used With resin application by spray gun and flow chopper for the addition ofthis reinforcement. A Venus GusmerG0310w-pressure slave arm internal mix airless chopper gun equipped with a 5003 tip. typical ofguns used in the industry, was used for spray application ofresin and chopped glass duringthis program. Resin was supplied to the choppergun and the flow chopper by a Venus Gusmer system at apump ratio of11 to 1. The methyl ethyl ketone peroxide (MEKP)/dimethyl phtiJalate (DivIP) catalyst was internally mixed for both chopper gun and flow chopper, with the catalyst delivered by a slave pump system. The flovy chQpperwas also aVenus Gusme! deSign. The resin is delivered at a much iowerpressure and no air is used to dispense the resin into the chopped glass. The glass is chopped into lengths using the same method as in the chopper gun, but because there is no atomizing air, the dispersion pattern ofglass and resin mixture is more narrow. Gelcoat is applied in the boat building industry using a spray gun. typically an airless air-assisted spray gun. For this program, gelcoatwas delivered to the spray gun using aPoly-Craftpump system at a pump ratio of23_ to 1. Catalyst, delivered using ameteredfeed pump, was mIxed externally. A Poly-Craft 755 airless air-assistedspray gun (eqUipped with a 0.026 tip size) was used during this program.

l-hBaseline Emission Testing


### Spray application was conducted using techniques common to the industry. This study was not intended to compare spray techniques. Therefore, skilled technicians from a manufacturing lire operated the gelcoat and chopper
, guns in all tests, except those included to produce data that could be mOre directly compared to previous tests.
1.3.3 Sampling Methods and Parameters
Method 25A, continuous monitoring ofTHC, was used as the primary technique tomeasure emissions. From the Method 25A results, emissions were calculated using the measured THC concentration as:propane, the molecular weightofpropane, and the exhaust gas flow rate measured in accordance withMethod 2. These results are presented in terms ofTHC emissions (as propane) for lamination or gelcoating. Speciation ofstyrene and MMA emissions (J;1eeded during

- - ,. . 

### gelcoating) was effected through Method 18 analysis using'.a gas chromatograph (GC) with flame ionization detector (FID). Method 18 analysis was conducted

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

primarily to establishthe ratio ofstyrene emissions to MMA emissions during gelcoating. This ratio allowed partitioning ofthe THC emission rate (as propane) into styrene and MMA components. The Method 18 results were also used as a checkon the Method 25A results.
Other measurements made during this program included those' variables determined from otherstudies to have more significant influence on emissions (Tab!e 1-1).

1 71.3.4 Molds Baseline Em;ss:on Testing

Fourmolds were used in this'Program, three ofwhich are boat part

• molds in actual use by U.S Marine. Two hui! molds represented the typical size hulls comrn'on to the industry: an 18-ft runabout and a larger 28-ft cruiser. An

18-ft deck moldfor abow rider model was used to represent a more cO:1\'exshaped mold. The mold used during Phase I testing by the CFA was in:luded in this program toprovide data for comparison with the results ofthat pre.ious study. Surface areas ofthese molds (Table 1-2), determined from engineering drawings and in previous studies. were used to calculate flux and normalized emissions. 

### Table 1-1 Parameters Studied

" ',"
..,::.;L::::,>, . 'Parameter·',
...;c .... ...i'Tes(VatiabIe 

# ....... ; ",; ..•..MeasurediFixed Resin aDDlication method Yes (2) FLxed Tool shaDe Yes (2) 

# . Fixed Resin StYrene conterit Yes (2) Measured (\'endor) Tool size . Yes (2) Fixed .. Gel time No Measured ADplied thickness No

. Measured Resin density' No Measured (vendoD Resin percent non-volatile' No Measured (vendor) Resin viscosity' No Measured 0:endoD Resin Deak exotherm' No Measured (vendor) Resin thixotropic'index' No Measured (vendor) Resin flow rate' No Measured Air flow rate No Measured 'These parameters apply to resin and gelcoat.Baseline EmissionTesting
Spray application was conducted using techniques common to the industry. This study was notintended to compare spray techniques. Therefore, skilled technicians from a manufacturing lire operated the gelcoat and chopper guns in all tests, except those included to produce data that could be**mcin~** directly compared to previous tests.
1.3.3. Sampling Methods and Parameters
Method 25A, continuous monitoring ofTHC, was used as the primary technique to measure emissions. From the Method 25A results, emissions were calculated using the measuredTHC concentration as.propane, . the molecularweight ofpropane, and the exhaust gas flow rate measured in accordance with Method 2. These results are presented in terms ofTHC emissions (as propane) for lamination orgelcoating. Speciation ofstyrene and l\EvlA emissions (r:eeded during gelcoating) was effected through Method 18 analysis

### using~a gas chromatograph' (GC) with flameionization detector (FID).l'v1erhod 18.analysis was conducted concurrent with the Method 25A monitoring. The Method 18 results were used

. primarily to establishthe ratio ofstyrene emissions to MMA emissions during

gelcoating. This ratio allowed partitioning ofrheTHC emission rate (as propane) into styrene and MMA components. The Memod 18 results were also used as a checkon the Method 25Aresults.
Othermeasurements made during this program included those· variables determined from other studies to have more significant influence on emissions (Table 1-1).



### , 

### ., D,."r 1J!/IIIT..tf8P""'"", IVHHA 

### .JIJ1''''''- Baseline Emission Testing

1.3.4 Molds
Fourmolds were used in this'program. three ofwhich are boat part , molds in actual use by U.S Marine. Two huil molds represented the typical size hulls common to the industry: an 18-ft runabout and alarger 28-ft cruiser. An 18-ft deck moldJora bow rider model was used to represent a more convexshaped mold. The mold used during Phase 1testing by the CFA was included in this program to provide data for comparison with the results ofthat previous study. Surface areas ofthese molds (Table 1-2). determined from engineering drawings and inprevious studies. were used to calculate flux and normalized el1!issions. 

### Table 1-1 Parameters Studied .• ';>X·i"parameter 

## ... I' ;TestVariable .ii
.. .··...·MeasilredlFixed 

### .

Resin application method Yes (2) Fixed Tool shape .. Yes (2) Fixed Resin styrene content Yes (2) Measured (vendor) Tool size Yes (2) Fixed Gel time No Measured Applied thickness No Measured Resin densitY' No Measured (vendor) Resin percent non-volatile' No Measured (vendor) Resin viscosity· No Measured (vendor) Resin peak exotherm' No Measured (vendor) Resin thixotropic index' No Measured (vendor) Resin flow rate' No Measured Airflow rate No Measured 'These parameters apply to reSIn and gelcoat.

1 QBaseline Emission Testing 

### Table 1-2 Surface Area ofMolds Used in Test Program Mold

. SurfaceArea (ft2) 18-ftDeck 171.09 18-ftHull 

### , 220.5 28-ft Hull 454 CFA Phase IMold (controlled spray) 28.06 CFA Phase IMold (uncontrolled spray) 37.28' 'Uncontrolled spray ofthiS mold mevltably coated flange extenslOns, effectively increasing the surface area ofthe final laminate structure. 1.3.5 Materials
Materials chosen for this program are rypical ofthose used in fiberglass boat manufacturing (Table 1-3). Two styrene polyester resins were used, one with a nominal 35 percent styrene by weight content and the other with a nominal 42 percent styrene by weight contem. The gelcoat was a,white on

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

formulations used are considered most representative ofthe range ofresin styrene and gekoat contents in the industry. Based on a survey ofindustry ." representatives; the marine industry uses gelcoat thar conta1ns MMA as an inhibitor to degradation by exposure to ultraviolet (lTV) light. MEKP in a DMp base is the most common catalystused in the indusrry for both ge1coat and resin; MEKP/DMP was used in this program.

1-9 Rev.lBaseline EmissionTesting 

### Table 1-2 Surface Area ofMolds Used in Test Program

-- Mold Surface Area (ftz)

- - 18-ftDeck 171.09 18-ftHull 

### , 220.5 

### .- 28-ft Hull , 454 CFA Phase I Mold (controlled spray) 28.06 CFA Phase I Mold (uncontrolled spray) 37.28" "Uncontrolled spray ofthIS mold inevitably coated flange extensions, effectively increasing the surface area ofthe final laminate structure. 1.3.5 Materials
Materials chosen for this program are typical ofthose used in fiberglass boat manufacturing (Table 1-3). Tv\"o styrene polyester resins were used, one with a nominal 35 percent styrene, by weight content and the other with a nominal 42 percent styrene byweight content.The gelcoatwas a white on white gelcoat containing nominally 32 percent styrene and.S percentMMA. The formulations used are considered most representative ofthe range ofresin styrene and ge!;coatcontents in the industry. Based on a**s~rvey** ofindustry representatives, the'marine industry uses gelcoat that contains MMA as an inhibitor to degradation by exposure to ultraviolet (UV) light. MEKP in a DMP base is the most common catalyst used in the industry for both gelcoat and resin: MEKP

### IDMP was used in this program.

1-9 Rev.lBaseline Emission Testing 

### Table 1-3 

### Properties ofGelcoat and Resin Materials

c Gelcoat Resiin 1 Resi.n 2 Product number 954WP53 80.654-NMMA 

# I 80.604-NMMA Manufacturer CookComposites ' Alpha/Owens Alpha/Owens and Polymers Co. Corning Corning Styrene content, % 32 35.1 42.2 MMA content, % 5 0 0 Specific gravity 1.32 1.082 1.09 Thixotropic index 5.5 4.9 5.71 Viscosity, cps RVF #2@ 20 RVF #2@ 20 rpmrpm-700 700 LVF #4@ 6rpm- RVF #2@ 2 rpm- RVF #2@ 2rpm14500
. 3400 4000 MEKP catalyst 2% 1.5% 2% 1.5%· 2% ratio Gel time, min 16.5 23.22 17.98 23.48 18.70
1.3.6 Schedule Testing was conducted from April 2to April 19, 1997. Set up at the' site began March 3D, continuing to April 1 (Table 1-4). One to three runs were. made each day. Sampling was coordinated with the U.S. Marine personnel supporting the lamination and gelcoating operations and with RTI personnel conducting sampling in an adjacentMethod 204 enclosure.
1.4 Organization ofthe Report
The complete reportincluding all appendices and separately bound field data contains all data from the testing program. The text ofthe report is intended to stand alone to proVide the essence ofthe results from the sampling and analysis program. This introduction (Section 1) provides a brief
1-10Baseline Emissfon Testing 

### Table 1-2 Surface Area 

### ofMolds Used in Test Program

'Uncontrolled spray ofthis mold lOevltably coated flange extensIOns, e:rectlvely lOcreasing the

. surface area ofthe final laminate structure. Mold 

### , Surface Area (ft2 ) 18-ftDeck 171.09 l8-ft Hull , 220.5 

### .- 28-ft Hull • 454 CFA Phase I Mold (controlled spray) 28.06

. CFA Phase I Mold (uncontrolled spray) 37.28a



## -
1.3.5 Materials
Materials chosen for this program are typical ofthose used in fiberglass boatmanufacturing (Table 1-3). Two styrene polyester resins were used, one with a nominal 35 percent styrene,by weight coment and the other with a nominal 42 percent styrene by weight content. The gelcoat was a white on white gelcoat containing nominally 32 percent styrene and 5 percent r.LvlA. The formulations used are considered most representative ofL'1e range ofresin styrene and gekoat.contents in the industry. Based on 2. s).!!"Vey ofindustry representatives, the marine industry uses gelcoat that conlains MMA 2.S an inhibitor to degradation by exposure to ultraviolet {U\1light. MEKP in a DMP base is the most common catalyst used in the industry for both ge1coat and resin; MEKP

### IDMP was used in this program.

1-9 Rev.lBaseline Emission Testing 

### Table 1-3 Properties ofGelcoat and Resin Materials

. Gelcoat Resin 1 Resi.n 2 Product number 954WP53 80.6J4-l'JMMA 

# I 80.604-NMMA Manufacturer Cook Composites, Alpha/Owens Alpha/Owens and Polymers Co. Corning Corning Styrene content, % 32 35.1 42.2 MMA content, % 5 0 0 Specific gravity 1.32

. 1.082 1.09 Thixotropic index 5.5 4.9 5.71 Viscosity, cps 

### 1\\1' #2@ 20 RVF #2@ 20 rpmrpm-700 700 :



### . LVF #4@ 6 rpm- RVF =.'2@ 2 rpm- RVF #2@ 2 rpm14500
. 3400 4000 MEKP catalyst 2% 1.5SS 2% 1.5%· 29f> ratio Gel time, min 16.5 23.22 

### I 17.98 23.48 18.70
1.3.6 Schedule Testing was conducted from April 2to April 19, 1997. Set up at the site began March 30, continuing to April 1 (Table H). One to three runs were made each day. Sampling was coordinated wim me U.S. Marine personnel supporting the lamination and gelcoating operadons and with RTI personnel conducting sampling in an adjacent Method 204 enclosure.


### 1.4 Organization ofthe Report
The complete report including all appendices and separately bound field data contains all data from the testirlg program. The text ofthe report is intended to stand alone to prOVide the essence ofthe results from the sampling and analysis program. This introduction (Section 1) provides a brief
l-lD Rpv 1

### Table 1-4 Test Schedule Baseline Emission Testing

Date Test Description Run
. 2-Apr NMMA-o-P 18-ftDeck Ge1coat 0402-01 

### , 3-Apr NMMA-8-1 28-J'tHull Ge1coat 0403-01 3-Apr NMMA-4-1 18-ft DecK 35 % Styrene Resin 0403-02 4-Apr NMMA-7-1 28-ft Hull 35 % Styrene Resin 0404-01 4-Apr NMMA-3-1 18-ftHull Ge1coat 0404-02 5-Apr NMMA-8-2 28-ft Hull Ge1coat 0405-01 5-Apr NMMA-1-1 18-ft Hull 35 %Styrene Resin 0405-02 7-Apr NMMA-7-2 28-ft Hull 35 % Styrene Resin 0407-01 8-Apr NMMA-6-1 18-ftDeck Gelcoat 0408-01 8-Apr NMMA-3-2 18-ft Hull Gelcoat 0408-02 8-Apr NMMA-4-2 18-ft Deck 35 % Styrene Resin 0408-03 9-Apr NMMA-1-2 18-ft Hull 35 % Styrene Resin 0409-01 9-Apr NMMA-ll-1G CFA Mold Ge1coat 0409-02 9-Apr NMMA-ll-1 CFA Mold 35 % Styrene Resin 0409-03 10-Apr NMMA-14-1 18-ftDeck 35 % Styrene Resin

- Flow Chopper -0410-01 lO-Apr NMMA-13-1 18-ftHull 35 % Styrene Resin

- Flow Chopper 0410-02 10-Apr NMMA-1l-2 CFA Mold 35 % Styrene Resin 0410-03 ll-Apr NMMA-6-2 18-ftDeck Gelcoat 0411-01 ll-Apr NMMA-14-2 18-ftDeck 35 % Styrene Resin

- Flow Chopper 0411-02 ll-Apr NMMA-13-2 18-ftHull 35 % Styrene Resin

- Flow-Chopper 0411-03 12-Apr NMMA-1l-3 CFA Mold 35 % Styrene Resin 0412-01 12-Apr NMMA-5-1 18-ftDeck 42 % Styrene Resin 0412-02 12-Apr -NMMA-2-1 18-ftHull 42 % Styrene**Re~in** 9412-03 14-Apr NMMA-5-2 18-ftDeck 42 % Styrene Resin 0414-01 14-Apr NMMA-2-2 18-ftHull 42 % Styrene Resin 0414-02 IS-Apr NMMA-16-1 18-ftDeck 42 % Styrene Resin"Flow Chopper 0415-01- IS-Apr NMMA-15-1 18-ftHull 42 % Styrene Resin-Flow Chopper 0415-02 16-Apr NMMA-16-2 18-ftDeck 42 % Styrene Resin-Flow Chopper 0416-01 16-Apr NMMA-15-2 18-ftHull 42 % St]Tene Resin-Flow Chopper 0416-02 17-Apr NMMA-12-1 CFA Mold 42 % Styrene Resin 0417-01 18-Apr NMMA-9-1 28-ft Hull 42 % Styrene Resin 0418-01 18-Apr NMMA-12-2 CFA Mold 42 % Styrene Resin 0418-02 19-Apr NMMA-9-2 28-ft Hull 42 % Styrene Resin 0419-01

1-11Baseline Emission Testing introduction to the purpose ofthe testing and the schedule for completing the on-site activities. The results ofthe sampling program are presented in Section 2. Results are presented in tabular format and graphically to simplify review. Section 3 describes the methods used in**th~** sampling program. including those 

### , used to quantify parameters not varied during the program. such as gel 

### time and styrene content. Quality control (QC) measures and QA data are presented in Section 4.
Data and material supporting the test report are contained in the

.appendices. as follows:

• Reference Methods

• Construction ofaTemporary Total Enclosure for Volatile Organic Compound Emission Assessment During Manufacture ofFiberglass Boats

• Calculations

• Procedure for and Results ofGel Time Determination

• Material Safety Data Sheets

. 

# . • Certifications fOf Gas Standards and EqUipment Calibrations

• Bag Standards

• Location and Results ofAirFlow over the Mold Measurements

• Comparison ofNMMA Results with Those from Other Studies Copies ofall raw data generated by the GC and the THC analyzer. organized by day. and including pertinentprocess data (spray gun·calibrations). have been bound separately for archive at NMMAoffices.

1-12 Rev.!

### Table 1-4 Test Schedule Baseline Emission Testing

Date Test Description Run Z-Apr NMMA-6-P**18-~t** Deck Gelcoat 040Z-0I 3-Apr NMMA-8-1 28-ft Hull Gelcoat 0403-01 3-Apr NMMA-4-1 1S-ftDecR 35 % Styrene Resin 0403-02 4-Apr NMMA-7-1 2S-ft Hull 35 % Styrene Resin 0404-01 4-Apr NMMA-3-1 18-f1 Hull Gelcoat 0404-02 5-Apr . 28-ft Hull Gelcoat 0405-01 NMMA-8-2 S-Apr NMMA-1-1 IS-IT Hull 35 % Styrene Resin 0405-02 7-Apr " NMMA-7-2 28-ft Hu1l35% Styrene Resin 0407-0I 8-Apr NMMA-6-1 IS-ft Deck Gelcoat 0408-01 8-Apr NMMA-3-2 18-ft Hull Gelcoat 0408-02 8-Apr NMMA-4-2 1S-ftDeck 35 % Sryrene Resin 0408-(}3 9-Apr NMMA-1-2 18-IT Hu1135 % Styrene Resin 0409-01 9-Apr NMMA-ll-1G CFA Mold Gelcoat 0409-02 9-Apr NMMA-ll-1 CFA**~fold** 35 % Styrene Resin 0409-03 lO-Apr NMMA-14-1 18-ft Deck 35 % Styrene Resin

- Flow Chopper "0410-01 lO-Apr NMMA-13-1 18-ftHull 35 % Styrene Resin

- Flow Chopper 0410-02 IO-Apr NMMA-11-2 CFA**~[old** 35 % Styrene**R~sin** 0410-03 ll-Apr NMMA-6-2 18-f1 Deck Gelcoat 0411-01 ll-Apr NMMA-14-2 18-ft Deck 35 % Styrene Resin

- Flow Chopper 0411-02 ll-Apr NMMA-13-2 18-ftHull 35 7, Styrene Resin

- Flow Chopper 0411-03 12-Apr NMMA-11-3 CFA Mold 35 % Styrene Resin 0412-01 1Z"-Apr NMMA-S-1 18-IT Deck 42 % Styrene Resin 0412-02 1Z-Apr -NMMA-2-1 IS-IT Hull 42 % Styrene Resin 0412-03 14-Apr NMMA-S-Z 1S-f1 Deck 42 % Sryrene Resin 0414-01 14-Apr NMMA-2-2 18-ftHull 42 % StyTene Resin 0414-02 IS-Apr NMMA-16-1 18-ftDeck 42 % Sryrene Resin'Flow Chopper 0415-01 IS-Apr NMMA-1S-1 18-ft Hull 42 % Styrene Resin-Flow Chopper 0415-02 16-Apr NMMA-16-2 18-ft Deck 42 % Styrene Resin-Flow Chopper 0416-01 16-Apr NMMA-15-2 18-ft Hull 42 % StyTene ReSin-Flow Chopper 0416-02 17-Apr NMMA-12-1 CFA Mold 42 % Styrene Resin 0417-01 18-Apr NMMA-9-1 2S-ftHull 42 % Sryrene Resin 041S-01 18-Apr NMMA-12-2 CFA**~[old** 42 % Styrene Resin 0418-02 19-Apr NMMA-9-Z 28-ftHull 42 % Styrene Resin 0419-01

1-11 Rev.!Baseline Emission Testing introduction to the purpose ofthe testing and the schedule for completing the on-site activities. The results of(he sampling program are presented in Section 2. Results:are pre?ented in tabular format and graphically to simplify review. Section 3 describes the methods used in**th~** sampling program, including those 

### , used to quantify parameters "oc varied during the program, such as gel time and styrene content. Quality comrol (QC) measures and QA data are presented in Section 4.
Data and materi=l supporting the test report are contained in the

.appendices; as follows:

• Reference Methods

• Construction ofaTempor","")' Total Enclosure for Volatile Organic Compound Emission Assessment Duri'1g Manufacture ofFiberglass Boats

• Calculations

• Procedure for and,Results ofGel Time Determination

• Material Safety DataShee:s

• Certifications for Gas Star,::ards and Equipment Calibrations

• Bag Standards

• Location and Results ofAirFlow over the Mold Measurements

• Comparison ofNMMA Res:rlts with Those from Other Studies Copies ofali raw data generaI::d by the GC and the THe analyzer, organized by day, and including pertinent process data (spray guncalibrations), have been bound separately for archive 

### cc**~'MMA** offices.

1-T2 Rev.l'-Ar'-AI' 

### /YMMA .JIII'.4'.4'.JIII' Baseline Emission Testing 2.0 RESULTS
The results ofemission testing at the U.S. Marine site in Arlington,

.vVashington, are presented in this section with comparison ofthe data**betvve~n** 

### , , tests and with theresults ofthe CFA Phase Jstudies; further comparison ofthese results with other studies is appended. The results are presented in terms of emissions as a percent ofavailable compound (Le., styrene. MMA. and total volatiles), as emissions perunit area ofmold surface, and as normalized emissions, that is, emissions per unit mass ofresin per unit area ofmold surface. All calculations done for these analyses are appended (Appendix C), including a sample calculation showing the complete analysis ofdata from test runs. Results demonstrate thatthe enclosure constructed at the site provided good capture ofemissions from the moldingprocess and that all emissions were accounted for in the sampling. The styrene evaporation tests demonstrated thatthe emission monitoring system provided a good measure of the actual losses. Testing ofemissions from lamination ofthe box mold from the Phase I CFA studies demonstrated that the techniques usedIn the two studies

, (Le
.. CFA's study and the portion ofthis study designed to reproduce some of the testing done in the CFA study) were comparable. Results ofduplicate testing for each test case provided good closure. within the acceptance criteria specified in the QAPP. In accordance with the plans outlined in the QAPP. all testsofboat "" mold use were completed with only two runs. Athird run was done for one'of the test conditions to incorporate the CFA study mold.
2.1 Summary ofResults
Table 2-1 presents the average values from the sixteen emission tests conducted atU.S. Marine's Arlington, vVashington, site. Three ofthe tests
?_l Rev. 1Baseline Emission Testing
were conducted using the same box mold used by CFA/Dowduring their Phase I studies (to provide data for comparison with those studies); all other tests were conducted using boat molds and procedures typical ofU.S. Marine's boat manufacturing processes. The results ofthis study are taken as representative ofindustry practice. 

### , , , , The amount ofresin used per part during these studies was much greaterthan the amounts used in previous studies (Table 2-1). This relative scale ofmaterial use and measurement contributed to the consistency ofresults. 

### Table 2-1 

### Summary 

### ofTest Results

CFA Gel' 3.2 41.1% 84.0% 46.9% 0.0203 6.36 18 Deck Gel 20.0 42.3% 75.6% 46.9% 0.0228 1.14 18 Hull Gel 25.7 46.4% 73.2% 50.0% 0.0261 1.03 28 Hull Gel 65.7 50.4% 78.6% 54.3% 0.0389 0.59 CFA 35R 8.1 41.8% 41.8% '0.0345 4.89 18 Deck 35R 124.6 12.9% 12.9% 0:0130 0.11 18 Hull35R 144.5 14.8% 14.8% 0.0143 0.10 28 Hull 35 R 354.4 17.3% 17.3% 0.0234 0.07 18 Deck 35R

- FCb 114.7 11.9% 11.9% 0.0092 0.08 18 Hull35R

- FC 141.7 10.8% 10.8% 0.0072 0.05 CFA 42R 5.1 48.7% 48.7% 0.0324 6.28 18 Deck42R 111.8 21.1% 21.1% 0.0284 0.25 18 Hull42R 142.9 20.7% 20.7% 0.0272 6.19 28 Hull42R 304.2 23.3% 23.3% 0.0357 0.12 18 Deck42R-FC 122.2 13.4% 13.4% 0.0125 0.10 18 Hull 42R-FC 154.9 11.4% 11:4% 0.0089 0.06 -See Table 1-4 for full description. bApplication using flow chopper. The THC measurements made during this program serve as the principal basis for estimating emissions. Figure 2-1 presents summary
2-2 Rev. 1Baseline Emission Testing 

### Figure 2-1 Summary Concentration Traces for BoatLamination and Gelcoating 2-1Ia]- Spray v. Flow Chopper: 18**Hul~** and Deck

- 35% Styrene Resin



# : "7**~;.** 

# ...-:;;:]f' r: :"t! - 't .1' '""

- -**"%"~ ~!~** **~'...** 1 '
... '
....

2:52 2:24 1:55 1:26 

# '- :-. '.



## . '. 

## ,.**,~'.. ~...**  :.

0:57 0:28 .'1_- 

# --. . 300 0;- 

## " 250 " 

## '" 0 i5. :: 200 

### " 

### '" 

## -= " 150 .8 ;:; 

# " 100 § 0; u 50 u

Elapsed Time 

# 1------ 35R -35R FC

# I
2-1[b]- Sprayv. Flow Chopper: 18 Hull andDeck

-42% StyreneResin

3:21 2:52 2:24 1:55 1:26 0:57 0:28 

# .. 300 -1-'-'---+._-+-----+-+--"=--1__-=-'-----+---+---+----1 

# '
.. If250 

### +-:----=--**-l---~-.C-l-~** __**~,;_~,** --'.
... -.

### --+1----+----+----1


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### i.11
......... - 150**+.;...4:-----.:l~~~=_i_+_--~~o_---i:.-1__---l---__j---__j** I

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### 'f 400**+-'-:"~'-'** :-'**-I----+I--''-'''---+------i--~-+_---+_----** 

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### ~',**-I---...;,...I---...;~-_I_---_+_---_+---_+----** 

# - S 

## '" 

## -= " e 

# " 8 § u u

Elapsed Time 

## 1--'--- 42R ---42R FC 

## I

2-3 Rev. IBaseline Em'ssion Testing
2-1[e]- Spray: 28 Hull- Both Resins 700 

### I I 

### I 600 

# " I " 0 r 

## B500 

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### L I 

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## I
2-1[d]

- Geleoating 900 800 <1\.,. 

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# ,1ft g. c.. 600 

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## 1-

-----18 Deck Cel 18 Hull Cel A 28 Hull Cell



## -

2-4 Rev. 1Baseline Emission Testing concentration profiles for the testing conducted during the April 1997 deployment. Each ofthe four frames presents THC concentration traces derived by averaging data from the individual test runs. This figure illustrates some of the differences in the data summarized in Table 2-1.
For example, the data from sampling the exhaust during lamination ofthe 18-ftmold illustrates the differences between spray up application and application by flow chopper, as well as the increased THC concentrations in the exhaust noted when laminating with a higher styrene content resin (42.2 percent styrene). The data from the 28-ft mold lamination test

. show that, although the peakconcentrations using the two resins were

essentially the same, the concentration trace for the 42 percent styrene resin has broader peaks, corresponding to greater mass emission rates.
The summary illustration ofthe gelcoat data**show~.** the effect of geometry on the concentrations measured. The greaterTHC concentrations in the exhaustnoted during lamination ofthe 28-ft mold are likely the result ofthe broader strokes'used in gelcoating the part and the distance:between the operator and the part during gelcoating. The atomized gelcoat remains airborne for alongerperiod oftime, resulting in greatervolatilization and emissions of VOC. The operatorcan stand closer to the 18-fthull and make shorter strokes to apply the gelcoat. Also, the operator can coat halfofthe 18-ftmold surface in a single pass, rather than the minimum two passes required to coat the 28-ft hull mold; this difference is noted inthe differences in peak widths. Finally, the 18-ft deckmold is relatively flat. with complex geometry requiring the operator to work close to the mold surface and coat some portions ofthe mold by brush, reducing the amount ofgelcoatatomized.

2-5 Rev. IBaseline Emission Testing The results presented in the tables and figures in this report reflect the exclusion from testing ofemissions in the long, low-concentration "tail" in eachTHC trace for each run. This phenomenon has been noted in previous studies and was highlighted in the QAPP as a concern for completing this testing in a timely fashion. Section 2.2 presents**th~** results from some ofthe early test runs that illustrate that elimination ofthe"tail" has little ifany effect on the results reported herein.
All the data related to emissions from boat gelcoating and lamination derived from this NMMA testing program are summarized in Figure 2-2. This figure presents the results for all tests in terms ofemissions as a· percent ofavailable monomer. As the results clearly indicate, emissionsfrom gelcoating differ from those associated with resin lamination. Sections 2.4 and 2.5 contain more detailed presentations ofthe results from gelcoating and resin lamination emission testing.


### 2.2 Evaluation ofEmissions from ContinuingTrace Concentrations
The QAPP included the evaluation ofa cutoffconcentration in the exhaust stream that would allow cessation ofsampling before the concentration ofTHC in the enclosure exhaust reached the background concentration, prOVided atleast 95 percent oftotal emissions were characterized before cessation ofsampling. The first test runs were used for this assessment. The assessment determined that 95 percent oftotal emissions from lamination and gelcoat operations would be characterized by the time the exhaust concentration reached 75 ppmv as propane. Ceasing sampling at this concentration would reduce run sampling by about 1 hourper run, allowing more sampling runs per day.

2-6 Rev. IBaseline Emission Testing 

### Figure 2-2 Emissions as Percentage ofAvailable Monomer

Emissions as Perc-ent of Available Monomer for Boat Tests
60%


### ..,. • 50% E 0 c 0 40% E • :c 

# '" 30% 

## •• > ro "0 20%
• 10"/0 c 0 

## •• • E 0% w .

r r- - r- 

### - r- - r- -



### - r- - r- - r- - r- - 

### - r- r- 

# m r- - - - 

## -I 

# r 

# l r <3 

# .. 0::

### ~I 

### '"**~i** 

### '" 

### '" c" u a**~! ~,**  <:: N N ci: " 

### " ;::1**~I ~I**  = L 

### ii

## ~I**~I** -< ± U' N U**~I** L u..1 '" 0: u N 0 0 NI '" N 

### -,

As it turned out, it was practical to continue the test runs until concentrations measured about 7ppmv as propane. Because the background concentration was about 2-4 ppmv, the difference in concentration was about 4ppmv, relating to less than 2ppmv as styrene and representing only 0.2 percent ofemissions.
The assessment ofthe concentration trace for NMMA-4-1 (lamination ofan 18-ft deck with 35 percent styrene resin) illustrates this analysis. The concentration trace for run NMMA-4-1 (Figure 2-3) shows the typical pattern ofconcentrationpeaks and valleys as resin is applied systematically to the sides ofthe mold. Resin and glass are applied to the first side, and the mixture is rolled outto remove air bubbles. After the initial coat on this halfofthe mold begins to gel. the mold is rotated and the first coat is applied to the second side. After the coat on the second side begins to gel, the mold is rotated again and the second layer ofglass and resin is applied to the
2-7 Rev. 1Baseline Emission Testing first side. with some ofthe giass being woven roving. This process continues until the specified thickness is achieved. As part ofthe manufacturing procedure. each iayer ofglass and resin are rolled out. After the final coat of resin is applied and the peak exotherrn ofthe polymerization reaction is achieved. the concentration ofstyrene in the exhaust stream begins to decrease. All the glass and resin were applied to this mold in about I hour. The styrene concentration in the exhaust stream decreased to near background levels in about I hour after that point. 

### Figure 2-3 Total Hydrocarbon Concentration Trace for NMMA-4-1
NM MA-4-1 (18 Deck 35R)

100% 90% 60% • c 70% 0 ;; • 60%

### ~E 50% • • • • 40% 

## " • 

# ·- 30% • '5 20% E 0 10% u 0% 0 m ;I ;;: ;;: ;;:



## " ;::; 

## " " ,;; ,;; ,;; 0 N M 

## " 0 :i 

## " " ,;; ,;; ,;; iri Time (PST) 400 350

> 300 E 250 

# rl." E,co • 7ii ;ij 200 " 

# rV _ 0 c "

0. 150 c 0 U 100 U 

### '" 0- SO

_____ THe 0 (ppm) -+- Cumulative M ass Percent
Because the THe associated with the latter part ofthe concentration trace (from 7 to 4 ppmv) represents about 0.2 percent ofemissions. the emissions associated with sampling completely to background levels from the cutoffconcentration were less than 0.015 lb. Even this amount represents a worst case assessment (Le
.. greatest emissions in the tail) because it assumes that
2-8 Rev. 1Baseline Emission Testing


### Table 2-2 Emissions Measured During Application ofResin to CFA Mold

, . Percent Resin 

### , of Flux Normalized Run . '
......., Mateiial Content (lb) 'Available (lb/ft2 ) • .(lb/lOOOlb/ft2) 11-lG Gelcoat 37.0 3.2 46.9 0.0203 6.36 11-1R-Ctrl Resin 35.1 3.5 30.6 0.0114 3.25 11-2R-Unc Resin 35.1 10.1 29.9 0.0233 2.31 11-3R-Unc Resin 35.1 6.1 53.6 0.0456 7.48 12-1R-Unc Resin 42.2 5.4 55.7 0.0441 8.16 12-2R-Unc Resin 42.2 4.73 41.7 

## I 0.0208 4.39 Styrene losses were also considered in**t~rms** ofemissions per unit area and normalized emissions. Average iosses per unit mold surface area (flux) were 0.0268 Ib/ft2 and 0.0325 Ib/ft2 for the 35 and 42 percent styrene resins. respectively. Normalized losses averaged 4.35 Ib/lOOO Ib/ft2 for the 35 percent styrene lamination and 6.28 Ib/1000 Ib/ft2 for the 42 percent styrene resin. Like the results in terms ofpercem ofavailable styrene, these results indicate greater losses from use.ofgreater styrene content resins than would be proportional to the actual styrene content. The flux losses show a differenftrend. but comparison ofthe emissions in this format is inconclusive because ofthe only slight difference in averages and the difficulty in consistent resin weight measurement.
In this test series ofthe program (i.e., using the CFA mold), emission measurements were not always comparable to the amount ofresin used. i.e., the emissions as percent ofavailable monomer was not always consistent. The eqUipmentwas set up to measure large quantities ofresin and. gelcoat continuously. The expectedquantities "iere between 100 and 300 lb resin for each test run. The scale selected. therefore. had an accuracy of0.5 lb, which was satisfactory for the boatlamination and gelcoating tests. butwhich did not 2-11 Rev. 1Baseline Emission Testing 

### Figure 2-5· Emissions from Lamination and Ge1coating ofthe CFA Mold
CFAM old - Emissions (%**~vailable)**


### , 90% , 80% 

### • 70% :0 

## " 60%**~-.::-** I--r-f-C-- OSlyrene 

## ; 50% lI- I-- I- IJMMA

- c 40% • 0 30% l- i-- l- I-- I- OVolaliJes c E .2 20% I-- l- f-- l- f-- l- I-- f- I-- l- i- • 

## •• r- '- f-- l- f-- l- I-- l- i-- l- i- E 10% w 0% : CFA Gel CFA 35R CFA 35R CFA 35R CFA 42R CFA 42R

CFA Mold· Emissions (Ib! SF)
0.050 0.045 I ,

.. 0.040 u:: 0.035 0.030 • 0.025 ;:== c 0 0.020 ;; • 0.015 .l....-...: I-- 'E w 0.010 .L- I-- 0.005

# +--

. I-- 0.000 

### , eFA Gel eFA 35R CFA 35R eFA 35R CFA 42R eFA 42R

CFA Mold - Emissions (lb/1000 Ib Resin/ SF)
9.0 8.0 u:: 7.0 

### '" "2**l--~** ;; 8.0 • 0: 5.0 l-- ,g**r-~** 0 4.0 1-- 0 0 3.0 l-- I--
• 2.0 l-- I-- c .2 1-- I-- • 1.0 

## '" E w 0.0 eFA Gel eFA 35R eFA 35R CFA 35R CFA 42R CFA 42R

2-12 Rev. 1Baseline Emission Testing prove to be adequate for measuring the small quantities ofresin (on the order of only 3.5 Ib) used to laminate the CFA mold. Thus, the precisionofthe scale used for resin and gelcoat led to some results from CFA mold testing that were more variable than results from boat testing.
2.4 Results ofGelcoatApplication Testing
All gelcoar application was done to a uniformthickness of20 mils with a gelcoat containing 32 percent styrene and 5 percent MMA. Apreliminary test run**(NMMA~6-P)** was made using aU.S. Marine production gelcoat supplied by the same supplier for the test gelcoat. Although the production gelcoat had different styrene content (approximately 31 percent), the results generated were included in this reportbecause they are very consistentwith the otherresults from gelcoat testing in this study (Figure 2-6).
Results for boat gelcoating are presented in terms oflosses of styrene, MMA, and total volatiles (Figure 2-6). The total emissions measured for the deck and tWo hull sizes are consistent (especially for styrene and total volatiles), with slightly greater emissions resulting froJ:Tl gelcoating the hulls, and the greatest emissions resulting from gelcoating the larger hull (Table 2-3). The most notable finding ofthis testing is the relative contribution to emissions ofthe individual constituents in the gelcoat. From 60 to 80 percent ofthe MMA in the gelcoat is lost as emissions in the gelcoatprocess. MMA is more volatile than styrene and, thus, is lost at a much greaterrate than the styrene. Only one test runresulted in MMA losses ofless than 60 percent ofavailable MMA. That run (NMMA-6-1) was discarded from the average values presented in Table 2-3 as unrepresentative because ofvariability ofthe GC response factors.

2-13 Rev. 1Baseline EmissionTesting 

### Figure 2-6 Gelcoat Emissions as Percent ofAvailable Volatiles

90% 

### , 80% - '
,
70% - I- -;:- • E 60% - f--- '- I- 0 c 

### - f- 0 E 50% - f--- 

### -- f-**f-~** o Styrene :1i '-



### - EMMA -" 

### - of- 

# " 40% - - f--


### - f- f- o Volatiles > 

### • 

## '" • 30% - 

### - f- f- - f- f- c 0 ';; • 'E 20% - - f- f- 

### - f--- f- w 10% - 

### - f- f- 

### - I- - 0% 

### - --+-'--- -4-- '-1-- --+-'--- '--- 

# .. .. .. .. '0 0; 

# .. 

# .. '" <: 

## "'- '" 

## '" '" '" '" 

## '" u. x " x x '5 S 0<1) u 0 u "=> • • I I I 0_ 0 0 :" :" :" :" :" 

### "', '"


### Table 2-3 Emissions from Gelcoating as Percentage ofAvailable Volatiles

I

# :;y,,':'**~>, ;,f.~~::**  

## ::,,'**",:~ ~."**  ."t'Percent of I, Percentof' " ':; Percentof,'

'., .'**::,~; .-~peJcoatUse;'**  ,:#cAvailable,'**.~y~il~bJl' :",Av!iila~le**  • " '. ,< .:. (lb) " <,' Styrene**~~MMA** i:-. "". Volatiles 18-ft Deck 20.0 42.3 75.6 46.9 18-ftHull 25.7 46.4 73.2 50.0 28-ft Hull 65.7 50.4 ' 78.6 54.3 The results from the first test run on the 18-ft deck after the preliminary test using gelcoat (the second run forthe 18-ft deck) yielded a loss of available MMA thatwas substantially less than all other measurements made during all other gelcoattestruns, only about 25 percent compared with 60 to 85

2·14Baseline Emiss:D:l Testing percent ofavailable MMA. Excluding that one run (NMMA-5-l) provides an average MMA loss of75.5 percent ofavailable MMA, avalue that is very consistent with the MMA loss values for the 18-ft and 28-ft hulls. The average styrene loss for this testwas relatively unchanged as a result ofexcluding that


### , one run; likewise, the total volatile loss was relatively unchanged, owing to the contribution ofstyrene losses to the total volatile loss. Gelcoating results evaluated in terms ofloss per unit mold surface area and normalized emissions (i.e., emissions per unitmass ofresin per unir mold surface area) show some interesting trends (Table 2-4 and Figure 2-7). As would be expected, the emissions from the 18-ftmolds are essentially equal. owing to nearly equal resin use and surface area. Normalized emissions appear to be inversely related to mold area, assuming the same thickness ofthe gelcoat is applied. Normalized emissions show the general trend ofincreasing emissions with decreasing mold surface area. This trend was also evident from the emission testing for resin lamination. 

### Table 2-4 

### Total Emissions from Gelcoating Related to Mold Surface Area



### ....... 

## .'. qe1coat**U~e** .. Mold Area Emissions,
.. ., Emissions·

.. ; . (lb) ;, (ft2) . ··'(lbtft

### i 

### )<: '(lb/IOOO 1b1ft2 ) 18-ftDeck 20.0 171.09 0.0228 1.14 18-ftHull 25.7 220.5 0.0251 1.03 28-ft Hull 55.7 454 0.0389 0.59

2-15 Rev. 1Baseline Emission Testing 

### Figure 2-7 Emissions from Gelcoating Related to Mold Surface Area

, -

r--

- r-- '-- r-- - 

# \



# ----I--a... 

# I i'-...

- O.OH

0.0'0
0,03S

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0.000 '" '" "**Oo~'** '" (USlolj " 00.' '" "**Oo~,** G" " l<ul1 '" " Hull '" 

### ,. Hull G" 

### ,. Hull G" 

### ,.



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,.

"

,

# ..

...

2.5 Results ofResin LaminationTesting Testing was conducted during lamination ofthree mold size and shape combinations selected to be representative ofthe majorityofresin use in the industry. Because the quantities ofresin used for each test are much greater than those used in previous testing, the results were very reproducible (Table 2-5). Figures are provided to illustrate the tabulated data. All tests are shown in thefigures and are grouped by resin (styrene content) to allow comparison oftheresults across the differentmold sizes and shapes.



### 2-16 Rev. 1Baseline Emission Testing 

### Table 2-5 Emissions Measured During Resin Lamination Emissions

, . .Percent of Normalized .' Test. ,'.' Resin Use Available (lb/1000 (lb) StVJ:..epe Flux (lb/ft2) lQ/ft2) 18 Deck 35R 124.6 (12.9 \ 0.0130 0.11 18 Deck 35 RFC 114.7 \11.9 0.0092 0.08 18 Deck 42 R 111.8 

### /21.1 0.0284 0.25 18 Deck 42 RFC 122.2 \1-3.4 0.0125 0.10 18 Hull 35 R 144.5 (14.8\ 0.0143 0.10 18 Hull 35 RFC 141.7 \10.8'; 0.0072 0.05 18 Hull 42 R 142.9 (20.7\., 0.0272 0.19 18 Hull42R FC 154.9 \11.4 ) 0.0089 0.06 28 Hull 35 R 354.4 17.3 0.0234 0.07 28 Hull 42 R 304.2 23.3 0.0357 0.12 2.5.1 Emissions as PercentofAvailable Styrene Figure 2-8 presents the data for emissions as a function ofavailable styrene. In each setoftest runs for a given mold size and shape, the same pattern ofemissions is seen:. the emissions from the 42 percent styrene resin lamination

" are greater than the emissions from lamination using 35 percent styrene resin, and the use ofa flow chopper to apply the resin does result in less emissions. : The latter effect is likely the result ofnot atomizing styrene in the spray up process. Based· on these measurements, the effect offlow chopper use on emissions is greaterfor the higher styrene content resins.
The greatest emissions in terms ofpercent available styrene were measured for the larger mold size and the greater styrene content resin. An average loss of23.3 percent ofavailable styrene was measured from laminating the 28-ft hull with 42 percent styrene resin. Only 17.3 percentloss was measured. for the same hull using 35 percentresin. Because this format ofpresenting

2-17 Rev. iBaseline Emission Testing 

### Figure 2-8 Emissions from Lamination as Function ofAvailable Styrene

. 25'Y.



### . , r , 20,\,. r- r-



### , 

# rH g 15% - - r- r- 1 I 

### I • 

### I 

# rl 0 '- 

### - - - f- f- 

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### - .r-

10% - r- 

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5" 

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# J
r- r

### I I 

### I 

### I I I
0% I


### , , , ,



### - emissions should account for differences in the resin styrene content. the results indicate that emissions are not directly proportional to resin styrene content, as mighthave been inferred from an emission factor based on percent available styrene.
The comparisons become clearerwhen the same data are revie\,ved in terms ofthe various molds and tests for the different resins. Figure 2-9 presents emissions as apercentage ofavailable styrene in the resin for the two resins tested. One observation from these results is that emissions as a percentage ofavailable styrene for a given styrene content in the resin increase with surface area ofthe mold for surface areas substantially greater (Le., the 28-ft
2-18 Rev. 1Baseline EmissionTesting 

### hull). This trend is apparentfor the two styrene content resins tested. Also, the use ofa flow chopperto apply resin reduces the percentage ofavailable styrene emitted for a given mold size or shape. Greater reductions are noted for the greaterpercentage styrene content resin, but in general, reductions of8 to 45 percent are noted: from about 12.9 pen;,ent available to 11.9 percent available for the 35 percent styrene resin (18-ft deck) and from 20.7 percent available to 11.4 percent availablefor the 42 percent styrene resin (18-fthull)

0 

### Figure 2-9 

### Comparison ofRe.sults 

### by Test

25%

20% 

### """ • E 0 c 0 E 15% 

## .., .0 .E! ;; > I 10% I '0 

## '" "- M C 0 -,; SOlo M E w 0% r--**r--~** -

,...- r-- -

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# .. !2 N j! !2 « • 0 

### " !2 :l :l



### 2-19 Revo 1

# ---- NMMA**~~--** Baseline Emission Testing 2.5.2 FluxEmissions
Emissions per unit area ofmold surface (Figure 2-10) show the consistency ofthe runs made for testing and indicate**gener~l** trends in the" data. For example, emissions per unit surface aPea increase with the increase in resin styrene content. Also, the results are fairly consistent for the two 18-ftmold types, despite the difference in configuration. The hull is a concave mold and the deck (a bowrider design) has convex character. 

### Figure 2-10 Emissions from Resin Lamination as Flux Measurement**o.o~o ,---------~---,------~.~**  ..**7'-.-.2~-,:"".,,;;""-** ..**,.~.,...**

...-------'-------,

0.035 

### +- ---,- ---1

0.030 t---------------\ f------------I

0.025 +-----1 

### ". ! 

# j 0.020 +-----,---1 f1-----------1 1- 1 ------,---_-1

- f--- r f-----------j f0.015
. I--

O.DIO 1--' - 1--. f--T"T--1

0.000 

# . . 

# ! ! 

## l , 

## l , 

### , , f--- f- -

.- f--- f--- f--- f--- f--- f--- - r r

- f- f- f- f- - 

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# . ! ! " 

## • • 

# . ! 

### i 

# , • i 

### , 

# ! , 

# , , ! 

### , 

# , , 

# . , , , , ,

The same data, reduced to averages for each test set, are presented in Figure 2-11 for the two different styrene resins tested. These results again illustrate thatemissions from the 42 percent styrene resin are greaterthan the 2-20 Rev. 1Baseline Emission Testing emissions from the 35 percent styrene resin lamination. In this case, because the mold surface areas are more nearly equal, flux emissions from the surface ofthe two 18-ftmolds are almost equal. Figure 2-11 also shows that emissions from lamination using a flow chopper are less than the baseline cases. 

### Figure'2-11 

### Average Emission Flux Measurements for Two Resins

0.040 0.035
0.030

. u:- 0.025
0.020 c o .;;;

.-g 0.015

w 0.010 0.005 0.000 ,

,

- -,--

-

-

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. 

### - ,-

- - ,

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### ,., ", on 0**~,** ;;;i M**~I** "0 "0 =**~!** -;; 

### ., 0 0 -I = 

## . "

2.5.3 Normalized Emissions Figure 2-12 compares results from all resin lamination testruns presented as normalized emissions (mass ofemissions permass ofresin per surface area). Forboth resins, the normalized emissions**decreas~** with increasing

. surface area, indicated by the 18-ftdeck to the 18-fthull to the 28-fthull., Normalized emissions were about 80 percent greaterfrom lamination with 42 percent styrene resin. Similartrends are noted for the emissions from lamination using a flow chopper; normalized emissions decrease with increasing mold 2-21 Rev. 1Baseline Emission Testing surface area and are always less than the normalized emissions for the corresponding spray up operation.
The differences between emissions generated using spray devices and those generated using flow choppers'(fan be seen in Figure 2-1, which compares the concentration traces for 18-fthull and deckmold lamination using two different styrene contentresins and thesetwo application methods. The difference in the concentration profile is due to the application devices. The utility ofthe flow chopper in reducing the amount ofstyrene atomized in application is much greater for the higher styrene content resin. As Figure 2-1 illustrates, the concentration tail after resin is appliec:l is nearly identical for thl3se two application methods. 

### Figure**2~12** 

### Normalized Emissions from Resin Lamination

0.30

0.25**-~**

.0.20 

# r
e0.15**l-~** f-- 

### e0.10

Q.Q5 l- I-- I-- I-- f-- f-- f-- I-- i- 

## I··· II

- 0.00 

## I ! 

### , ! ! ! 

# , ! , 

### , .=. 

### ,

-

2-22 Rev. 1.."..."..."...". 

### !YMMA ",.,. Baseline Emission Testing 3.0 CALIBRATION AND SAMPLING PROCEDURES
The extensive battery oHests conducted and measurements made for this program includes those that were repeated routinely, either ciaily or during every test run, and those that**wen~** repeated only once ortwice over the course ofthe whole program (Table 3-1y' This section describes the procedures for all the tests conducted andmeasurements made during this program, including QCprocedures (calibrations) and QA procedures followed to produce data for assessing the quality ofthe othermeasurements. The procedures are presented in terms ofthose associated with the process ofmanufacturing the part (I.e., hull or deck) and those associated with the measurement ofemissions. Additional measurements (I.e., ofair flow overthe mold and styrene recovery) and data handling are also addressed in this section. 

### Table 3-1 Measurements During TestProgram Measurement Designation Frequency THC Concentration Method 25A Continuous Styrene (MMA) "Conc.entration Method 18 ' ,Intermittent (6-15 min



### . intervals) WetLaminate Thickness Wet Mil Gauge EachTest Run Wet Film Thickness Wet Mil Gauge Each Test Run Styrene (MMA) Content Manufacturer's Method Per BatchDelivered Gel Time U.S. Marine Method Per Batch Delivered Resin Flow Rate Spray Gun'Calibration Pre/PostTestDaily Air Flow HotWire Anemometer ForEach Mold AirTemperature Exhaust Gas Temperature ' Continuous Exhaust Flow Rate Vent StackAir Flow Rate One traverse set per test; continuous point measurement Styrene Recovery Material Balance/Method 25A Pre/PostProgram Resin/GelcoatWeight Precision Balance Pre/PostTest; continuous measurement Two testruns were made mosttest days; thenumber of**tes~** completed in a day was dictatedby the duration ofthe test and the availability 3-1 Rev: 1"Baseline EmissjOn Testing ofmaterial, molds, and personnel to constructthe parts. On some days, only a single test run was completed, while on other days, as many as three test runs were completed. The procedures implemented mDsttest days include the following:

• Morning spray equipment calibration;

• . Morning leak check and calibration ofthe THC analyzer and the GC;

• "Measurements made duringthe test runs, including THC, styrene and MMA (using the GC), flow rate, weight ofmaterial (resin or gelcoat) used during the run, and temperature;

• Post-test quality control measurements (calibrations);

• Measurements for secondtestrun (THC, styrene and MMA, flow rate, weight, and temperature);

• Post-test quality control measurements; and

• Evening spray gun flow rate calibration. "
Additional tests conducted include measuring the rate ofairflow over the mold and mass balance styrene recovery checks (9A).

"3.1 Process Procedures and Measurements
The procedures used to apply the resin were those used by the skilled U.S. Marine staffin applying gelcoat orresin/glass in the manufacturing operation. Resins and gelcoat selected for this program had characteristics typical ofindustry useand meeting the goals ofthis program (Section 1.3.5). Staffused to manufacture molds and to train lamination staffperformed all gelcoating and lamination during this prograr:n. Additional personnel assisted when glass was rolled out orwoven roving added to the mold.

3-2 Rev. 1

# ---- /YMMA
..,..,..,.., Baseline EmissionTesting 3.1.1 Application Procedures
Afterthe morning calibrations were completed. monitoring ofair flow was established. materials to be applied were weighed, and lam.ination (by spray up or flow chopper) or gelcoating**o~** a partin the TIE commenced. Skilled operators applied resin and gelcoat as they would in normalproduction. The operators measured laminate and gelcoat thickness periodically as the material was applied. using a chop mil gauge for laminate thickness and a gelcoatmil

.gauge for gelcoat thickness. During the application ofboth materials, multiple readings weretaken atthree locations along the length ofthe mold as the operators fabricated the part. The operators did not record gauge readings but applied material to the desired thickness. in accordance with normal operating procedures.
Gelcoatwas applied using spray guns with a distance of 18-24 in. from spray tip to mold surface for smaller (18-ft) parts. The distance was greater for gelcoating the 28-fthull mold. reaching 4-5 ft at the greatest distance from the application equipmentto the keel ofthe hull. When gelcoating, a fog coatwas


# . applied first to one side ofthe mold and then athicker layerwas applied to bring the**coat~ng** to anominal thickness of20 mils. Using typical gelcoating
. procedure. the operator checked the gelcoat thickness severaltimes in atleast three locations on each side ofthe mold to ensure uniform thickness. After one side was coated. the mold was rotated. and the process was repeated to coat the other halfofthe mold surface. Complexportions ofsome molds. such as encountered on the 18-ft deckmold, were coated using a cup and brush technique. These portions were typically inaccessible with thi" spray equipment.
A similarprocedure was used to apply resin and glass to the 18-ft hull and deck and the 28-fthull molds. In this procedure, though. a skin coat of
3-3 Rev.!Baseline Emission Testing resin and glass ofabout 90 mil thicknesswas applied first and allowed to cure almost entirely before applying additionallayers ofthe laminate. Additional layers were then added by alternating resin/glass chop and reSin/woven roving. The chopped glass was rolled out at everylayer. The laminate thicknesses for the hulls anddecks were much greaterthan thelaminate



### . thicknesses used inprevious studies. For example. a laminate thickness of
. 414 mils was used in the bottom ofthe 28-fthull (including three layers of woven roving, each about 48 mil thickness), and athickness of 198 mils was used for the sides and transom ofthe same hull (including one roving). A O.OlO-in. thickness gauge was used to make the measurements.
·3.1.2 SprayEquipment Calibration
The spray gun resin or gelcoatflow rate was determined at the beginning ofevery test day and corlfirmed at the end ofeverytest day, that is, before the first test and afterthe lasttest. The spray equipmentfiow rate was adjusted (resin pump pressure was adjusted and spray tip sizes changed) by the operator to provide the normal resin and gelcoat output**f~r** manufacturing operations, and the flow rate was recorded. The flow rate calibration consisted of spraying resin (or gelcoat) into apre-weighed containerfor 15 seconds, recording the material weight, and calculating the rate in pounds per minute. For spray-up application, the glass contentwas adjusted to the reqUired resin flow rate; after the resin flow rate was established, the chopper speed was adjusted to provide the proper glass ratio. The spray pattern was evaluated by the experienced operators by spraying resin and glass onto a cardboard panel. Adjustments were made based on the visual patternto achieve the desired result.

3-4 Rev. 1Baseline Emission Testing 

### The resin/gelcoat-to-catalystratio was calibrated by comparing the catalystvolume measurementto flow rate and adjusting the catalystratio by the slave pump setting. Bothresin and catalyst are delivered to the applicator head by positive displacement pumps. Because the air-actuated piston pumps deliver a fixed amount ofmaterial with every stroke, the amount ofcatalyst delivered to.
, 

### the applicator head can be accurately set based onthe stroke count. The amount ofcatalyst delivered to the applicator is very small compared with the amount of resin delivered, so the amount ofresin is setfirst and calibration completed. Then the stroke count ofthe resin pump is setto the desired catalystratio. The

. ,catalystratio is adjustedafter application ofthe skin coat and then these stroke count settings were maintained throughout each day.
3.l.3 Gel Time


### Gel time was measured on site for eachbatch ofresin used (Table 3-2). The procedure used to measure gel time (Appendix D) is the same procedure used by U.S.Marine in determining gel time for production resin and gelcoat. Gel 

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

### (MEKP); a gel time ofabout 16.5 minutes is typical for the gelcoat. Two gel times are common for lamination, one for the skin coat andanother for the bulk of·the lamination. The skin coat gel time for the 35 percentstyrene resin was about 18 

### minutes using a 2percentRed 925 

### MEKP catalyst; the remainder ofthe lamination was doneusing a gel time ofabout 23.2 minutes with a 1.5 percent Red 925 

### MEKP catalyst. The latter materials achieved apeakgel temperature in 26 (for the 1.5 percent catalyst) to 34 minutes (for the 2percent catalyst). Comparable gel measurements were made for the 42 percent styrene resin.

3-5 Rev. 1Baseline Emission Testing 

### Table 3-2. 

### Gel Time Results

Gel time to 150°F 6:05 5:06 3:09

367 5:04 27:08 16:38 Gel time Gel time to 150°F PeakTern erature (OF) Time to PeakTern erature Time to PeakTern erature 33:57 26:18 22:11

3.1.4 Styrene and Methyl Methacrylate Content



### • Styrene and MMA contentofthe resins and gelcoat used during this studywere determined by the resin suppliers: Alpha/Owens-Corning for the resin and Cook**Compo~ites** and Polymers for the gelcoat. Industry procedures were followed andcertifications ofstyrene and-MMA content provided (Table 3-3). Material safety data sheets with material certifications are in Appendix E. 

### Table 3-3 

### Styrene-and MMAContents**R_~.lMf~i1.~~$.n%.Gpl'em~~~B~~B~~J(~~~** Laminating Resin (35 R) 35.1 0.0 Laminating Resin (42 R) 42.2 0.0 Test Gelcoat 32"0 5.0 Production -Gelcoat (USM) 30.95 4_95

3-6 Rev. 1\

. 

### I Ar"Ar"Ar"Ar" 

### !YMMA 6'6'6'6' Baseline Ern:ssion Testing 3.2 Emission Testing Equipment and Procedures
This section describes the equipment used to sample emissions from the enclosure and to measure other critical test parameters such es flow rate from the enclosure, temperature ofthe exl;aust stream, and amount ofresin applied. QC checks made on the sampling system are also presented iTl this section. Samples were collected from the enclosure's exhaust ductthrough Teflon® sample tubing at ambienttemperature using a sample pump. This sample was fed continuously to aTHC analyzer and to the GC used to speciate the organic compounds in the exhaust stream. The THC data were collected continuously and recorded in a computer data acquisition system (DAS) through a Dianachart data logger. GC data were collected separately.
The following data were collected continuously:

• TTE outletTHCconcentration,

• TIE inletTHC concentration,

• Velocity pressure head in the exhaust duct,

• Temperature ofthe exhaust stream, and

• Weight ofthe gelcoat or resin used.
3.2.1 Leak Checkand Instrument Calibration
Leak checks and bias checks were incorporated into the calibration and response factor procedures, respectively. Calibration gases were introduced at the probe inlet, and calibration responses were obtained using the sa..TIle procedures as those used for sample responses. Certifications for all ges 3-7 Rev. 1Baseline Emission Testing standards are included in Appendix F. No vacuum leak checks were performed because any leaks, ifpresent, wouldbe small enough to be "calibrated out" and stable enough to have anegligible effect on pose-test drift measurements. Any bias introduced by the systemwas similarly subsumed in the response factor determinations because they were performed "ith the entire sampling system.
, Instrument calibration checks were also made atthe instrument and the results compared with the overall calibration checks made atthe sample probe tip. The two sets ofresults were consistent, indicatingthatthere was little or no bias in the sampling system. Checks by the EPA during their technical system auditverified the findings ofthe NMlvL4 checks.
3.2.1.1 Total Hydrocarbon Analyzer
THC was measured atthe outlet and L'l1et ofthe enclosure using an FID in accordance with EPAMethod 25A (AppendLx A). Analysis ofthe outlet gas streamwas made using aThermo Electron l\lodel5lH THC analyzer. A Ratfisch Model 52.RF analyzer was used to monimrTHC c.cintent in the inlet air to the enclosure. A second Ratfisch was held on seand-by in case one oftheother instruments failed. Both instruments were calibrated using the same procedure.
Before testing each day, the calibration ofthe FID was verified using zero, low span (30 percent), mid-span (60 percent), and 90 percent'span gases. Only one detection range, 1000 ppmv as propane, was used, which covered conce:r;trations ofstyrene from 0to approxini.ately 416 ppmv. Calibration was simplified by using the.DAS inseead ofrecalibrating the two instruments. That is, instead ofusing adjustrnempOLentiometers on the instruments themselves, the response signal to the DAS computer was adjusted
. in the computer program. This approach. which basicallyacknowledges thatthe
3-8 Rev. 1Baseline Emission Testing DAS is an integral part ofthe entire sampling. analysis. and data acquisition system. allowed more rapid calibration ofthe system eachmorning. An advantage. beyond mere simplification ofthe process, was that calibration incorporating the DAS allowed calibration ofthe entire system, including sampling lines, instrument, and data syste]TIs, incorporating potential biases created by sample extraction equipment, instrumentresponse: and the DAS into a single system response. The acceptable calibration error ofless than 10 percent was met for both instruments for all tests (Section 4.1.1).
The FID was calibrated with propane. Instrumentresponse factors were periodically developed for styrene and MMA by analyZing known
. concentrations ofthe target compounds in a manner identical to that employed for propane calibration. This procedure generated a correlation ofrelative response ofthe compounds on the THe instrument. a factor needed to compare. the results ofMethod 18 sampling with Method 25A sampling.
Afterthe first test ofthe day. the instrument drift ofthe analyzer was checked using zero, 30 percent. and 60 percent span gases. When the drift was within the acceptable range. testing proceeded; otherwise. the instrument was recalibrated. The post.test calibration 

### dr1ft: was recorded before any recalibration tookplace. The results ofthese measurements are reported in Section 4.1.1.
Printouts ofraw continuous emission monitoring data are included by run in the field data bound separately. Monitoring dataprintouts with reduced data are included with. other calculations (AppendixC).

3-9 Rev. 1

# --- /YMMA 1'1'1'1' Baseline Emission Testing 3.2.1.2 Gas Chromatograph
Concentrations ofthetwo specific organic compounds expected in the exhaust from the enclosure (styrene and MMA) were measuredto provide sp'eciation oftheir emissions during gelco'lt operations and to provide a check on the Method 25A emission measurements**~sing** Method 18. Specific·


### , concentrations ofstyrene and MMA were determined using periodic measurements by GC using aHewlett Packard Model 5890 with aModel 3396 Series II integrator. A Supelco GP 10% 1,2,3-tris(2-cyanoethoxy)propene on 801100 Chromosorb PAW column (lI8-in diameterX 6ft long stainless steel) was used for these analyses. Hydrogen at 25 psi was provided to the instrument for the flame; air (at 33 psi) and nitrogen (at 50 psi) were also provided to the instrument to supportthe flame and as acarrier gas (35 cc/min) for the sample. The instrumentwas maintained at 130'C for all GC analyses.
Measurements and calibration were conducted in accordance with EPA Method 18 specifications (Appendix A). Sample gas was continuously fed· to the GC using the sampling system from the enclosure exhaust duct. Partofthe sample stream was sentto the THC analyzer, with another portion ofthe stream flowing to the GC. Atleast GC four measurements per hourwere to be made in accordance with the QAPP; more often, data were collected every 6to 8minutes.
The GC was calibrated according to Method 18 procedures using styrene and MMA to indicate the retention time and the area counts. Styrene gas standards in cylinders were used to provide styrene for these calibrations. MMA standards were prepared in Tedlar® bags (Appendix G) using the procedure detailed in Method 18. After establishing the retention time for styrene and MMA, the integrator was programmed to identify the two compounds (by retention time) and used the response factor determined daily to calculate the
3-10 Rev.!Baseline EmissionTesting concentrations ofeach compound. Area counts for the instrument responses were recorded and concentrations calculated.'off-line in spreadsheets. A linear relationship between concentrationand area countwas generated for each calibrationto calculate concentrations. (These calibration"curves" are included with the calculations in Appendix C.) AllJ:hromatograms generated during daily tests have been bound separatelywith the other field data. Records and reductions for every run are included in Appendix C. Day to day calibration checks met the acceptance criteria or the instrumentwas recalibrated.· Results ofinstrument calibration are presented in Section 4.1.2. The audit ofthe GC system that the EPA conducted is discussed in

. Section 4.7.

3.2.2 Flow Rate Measurements
Air flow rate from the enclosure was measured using EPA Method 2protocols once pertest. Flow rate was also monitored c.ontinuously at a single pointin theTIE exhaust ductusing a standard (Type L) pitottube by recording the velocity pressure head at ¢e centreid ofthe. duct. The pressure head was logged through the Dianachart data loggerto the computer DAS with other parameters, such as temperature, resin weight, and THC concentrations at the inlet and outletto the enclosure. The Method 2velocity traverse was performedfor each.testrun using the same standard pitottube to monitor air flow through the duct.
A velocity for each recorded THC measurementwas calculated
. based on aratio ofthe average pressurehead readings. The constantvelocity monitorreading atthe time ofthe traverse was noted. This reading was scaled to the instantaneous reading (recorded in the DASj" and to the flow rate measured 3-11 Rev. IBaseline Emission Testing using a complete traverse. The average ofeach calculated I-min flow rate readingbased on I-min velocity head readingswas used in calculating an average volumetric flow rate over the entire sampling period ofthe test run. The

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

3.2.3 .. Temperature

.The type Kthermocouple used for DAS and**flov~** measurements was calibrated on site at two points: ice bath (32°P) and boiling water (212°P). Air temperature within the enclosure was monitored continuously at the location ofthe fixedpitot. Therefore, this temperature reflects the temperature at the sampling location rather than the temperature within the enclosure. Air flow velocities within the exhaustduct were approximately 30-35 ft/sec. The 

### TIE exhaust temperature was therefore measured within two seconds ofleaving the enclosure. The temperature ofthe well-mixed 

### TIE exhaust provided a better measurementofthe average 

### TIE temperature than a single fIxed point within the 

### TIE because ofthe short retention time in the exhaust ductand the small temperature differential between ambient and exhaust air. The temperature was monitored continuously using the DAS calibrated at two points.
3.2.4 Weight ofMaterial Used
The weight ofthe resin or gelcmitused during atest run was determined by weighing the container ofmaterial on a platform balance immediatelybefore and after application to the mold. The balance was eqUipped with an analog output that allowed changes inweightto be tracked on the DAS
.. A small degree. ofvariability in the weight measurement was noted during the testing on the CFA mold, where only 3.5 to 10 lb ofresin were used. 3-12 Rev.!Baseline EmissionTesting The variability resulted from the movement ofthe ancillary equipment associated with the resin and catalyst delivery systems. As indicated by the weigh scale calibration checks (Section 4.6) and audit (Section 4.7.2), the scale met the desired performance criteria and provided accurate measurements ofthe resin and gelcoat use during testing on bO$lt parts.. The weight ofthe catalystwas determined from the resin (or gelcoat) weight and the'established catalyst-to-resin ratio. These ratios were set based on stroke count ofthe positive displacementpistonpumpsused for both materials. The amount ofcatalystwas insignificant compared to resin or gelcoat use. The balance used to determine weight ofresin and gelcoat used during lamination was calibrated by Weigh Tronics in Seattle before itwas delivered to the site. All adjustments were made atthe signal output and DAS; no adjustmentwas made to the scale that wouldhave affected its calibration. Calibration certification is included with other certifications in Appendix F.
Calibration ofthe scale was checked periodically during the testing program. These results are presented in Section4.6. The precision and accuracy ofthe balance was checked during the on-site technical system audit conducted by the EPA. The results ofthis audit are presentedin Section 4.7.2.
3.3 Air Flow Over the Mold

, I

I Airflow over the mold in the TIE was measuredto enhance the documentation ofthe experiments conducted, butno adjustmentwas made to the rate ofair flow through the enclosure based on the measurement. The more important adjustment was the flow rate through the enciosure to simulate the'
3-13 Rev. 1Baseline EmissionTesting number ofroom volume exchanges found in the U.S. Marine production area (an integral part ofthe TIE design). The velocities over the parts were measured merely to provide arecord.
To supportthe validityofthe measured velocities over the parts, measurements were made (with ahotwire anemometer) early in the test program to determine the range ofvelocities overparts encountered in the production environment. AirfloW velocities in aproduction lamination area used for laminating large boats and large parts for those boats ranged from 20- 25 ftlmin near the airpick-ups atthe exhaust plenum to 34-40 ftlmin inthe center ofthe lamination area. (In this production area, air was supplied through air handlers at one sideofthe room and exhausted from pick-Up plenaon the opposite side ofthe room.) Velocities near 200 ft/min were measured on covered molds (convex architecture) nearthe exhaustfrom the air handlers servicing the lamination area. This highervelocity was nottypical in the lamination area.
Measurements made in the testing enclosure showed that velocities of20-24 ft/min were typical for the enclosure. These velocities were typical of measurements for induced draft environments, such as those found nearerthe exhaust plenum inthe lamination room. Measurements on the part (nearthe' door to the enclosure) showedthatthe bulkvelocity into the enclosure was approximately 40 ft/rnin. (Velocities atthe NDOs to the TIE were much greater than the reqUired 200 ftlmin, as noted in Section 1.3.1.)
Air flow overthe mold was first evaluated for the 18-ftdeck mold. Measurements at five locations on the mold surface ranged from 20-24 ftlmin on the lowerportion ofthe mold to 30-35 ftlmin atthe upperregion ofthe mold, nearer the air intakes for the enclosure. Velocities were checked onthe 28-ft hull mold at seven locations; velocities ranged from 20 to 36 ft/min. Measurements 3-14 Rev. 1Baseline EmissionTesting
were made parallel to the surface ofthe mold, where the maximumvelocitywas noted on the readoutfrom the hot wire anemometer. Sketches from the log book showing locations ofmeasurements and results are found in AppendLx H. During the site auditby the j2;PA and its contractorMidwest Research Institute (MRI), air velocity measurements at the mold s.urfacewere made to verify thatthe velocity was in the range typical ofthe industry (and plant) practice. Measurements made by MRI (Appendix H) corroborate the measurements made on the molds.
Velocities were not measured during eachtest or run. These' velocities were not key measurements ofthe program; further, the velocities would not be expected to vary during the program because the flow rate through the enclosure was not avariable during this program and the geometry ofthe molds did notvary.
3.4 Mass Balance Styrene Recovery Check

> In accordance with the QAPP, styrene evaporation tests (the LOwel tests) were conductedto e'vah,rate the capture andrecovery ofstyrene by the. sampling system. Two tests were completed, one atthe initiation ofthe testing program and one at its conclusion.
A covered container was loaded with a:large pan, a collapsible clothes drying rack, towels. and a gallon ofstyrene and was weighed on a precision scale outside the 

### TIE. (The scale used for this test was used by RTI in their testing to measure smaller quantities ofmaterials.) The containerwas thEm placed inside the 

### TIE. the rack erected in the pan, towels draped overthe bars, and. with the flow rate and emissions being measured. the styrene was poured
3-15 Rev. 1Baseline Emission Testing
over the towels and into the pan. Afan was used to induce flow·over the towels and accelerate styrene evaporation. After about 30 minutes, the equipment was repacked into the container and the TIE allowed to clear ofstYrene (while emission monitoring continued). When emissions reached background concentrations, the containerwas removeel from the TIE and reweighed.
Emissions were measuredusing the THC analyzer and the GC during the first styrene recovery check, but using only the THC analyzer during the second. Recoveries are based on THC results, and the sampling system's capture and recovery ofstyrene was assessed by comparing the quantity of styrene evaporated (determined from weight loss ofthe container) with the quantity ofstyrene measured in the exhaust (calculated from the average styrene concentration and exhaust flow rate). The results ofthesetests, reported in Section 4.7.4, indicate good agreement between the measured evaporative loss and the measured mass emission quantity.


### 3.5 Data Custody
Because all emission measurements were made using continuous monitors thatventemission streams after analysis, no sample retention was . necessary, orpossible. Data collected in the field include gel time, spray gun calibration, quantity ofresin material used, temperature ofthe exhaust, static pressure ofthe exhaust stream, pressure head ofLl}e exhaust stream, THC concentration ofthe inletstreamto the enclosure, THC concentration on the outlet stream from the enclosure, and concentrations ofspecific compounds in thE? exhaustfrom the enclosure. Testruns are designated by day, for example, 0408-01 indicates thefirst run on April 8, 1997. Testnumbers are designated with "NMMA" prefix, for example, NMMA-l-l indicmes test condition 1, assessment 1 (Table 1-1). Thus, atest can be identifiedby date orby type using
3-16 Rev. 1\ Baseline Emission Testing the total description: 0405-01, NMMA-8-2 indicates a second replicate ofa 28-ft hull gelcoating and was the first run on AprilS, 1997.

3-17 Rev. 1

# ... ...,..,....,. /VNNA

---- Baseline Emission Testing 4.0 QUALITY CONTROLAND QUALITY ASSURANCE Quality controllquality assurance (QCIQA) gUidelines outline pertinent steps to be followed duringthe production ofgas composition datato ensure the reliability and acceptance**ofth~** data generated. QC, in the contextof this report, refers to a system ofactivities Clesigned to achieve alevel ofprecision and accuracy as specified in the projectplan. The QC procedures are targeted at maintaining a level ofquality but in themselves are not a measure ofthe degree ofquality achieved. QA, as used in this report, refers to the systemofactivities implemented to measure the effectiveness ofthe QC system.
The QCIQA procedures implemented during this test program were presented in the 

### QualityAssuranceProjectPlanfor theNationalMarine ManufacturersAssociation BaselineEmission TestingProject (QAPP), which was approved by the EPA before the on-site sampling program. This section presents the results ofthe measurements taken to demonstrate adherence to the data quality objectives for critical measurements, as presented in Section 3 ofthe QAPP.


### 4.1 Concentration Measurements
The measurements taken for the characterization ofTHC content of the TIE exhaust gas streamwere made according to the procedures ofEPA Method 25A; this approach was the same as that used in previous studies, ensuringcomparablity with those previous tests. Styrene and MMA concentration measurementswere made according to Method 18 procedures, Previous studies have notevaluatedresins containing MMA. Method 18 results are critical to speciation ofTHC from the gelcoattesting where these two species are measured. No other compound was identified in the Method 18
4-1 Rev. i

# I

\ Baseline EmissionTesting chromatograms. The QA measures and the acceptance criteria used for this test program, which were approved by the EPA in the QAPP, are presented in Table 4-1. 

### Table 4-1 , 

### Acceptance Criteria for Concentration Measurements
10 percent ofcalibration gas value' 25A Calibration Drift

18 Calibration Error 18 Calibration Drift 10 percent ofcalibration gas value 10 percent ofcalibration gas value 

### 5 percent ofcalibration gas value Note: Calibration error measurements were substituted for performance audits because no audit materials were prOVided for routine assessment. 4.1.1 Total Hydrocarbon Measurements (Method 25A)
Tables 4-2 and 4-3 presentthe results ofthe Method 25A calibration error and drifttests for all the testruns. Detailedresults are presented in Appendix 

### C. Both assessments ofinstrumentperformance,were made before and aftereach test. The calibration errors presented in Table 4-2 are within the acceptance criteria'presented in the QAPP. The results ofjnstrument drift assessments demonstrate similarresults; all post-test assessments are well within 10 percentofpre-testvalues. Based on reView ofthese Method 25A calibration assessments, all the data presented in this report are accurate to within 10 percentofthe values reported, with a Variability in precision ofno greater than 10 percent.
Because Shirley Wasson ofthe ORD during her review ofthe QAPP expressed concerns about the stability ofstyrene stored in cylinders, THC instrument calibrations were performed using propane. Response factors were then determinedfor instrumentresponse to styrene and MMA in terms of

4-2 Rev. 1Baseline Emission Testing Table 4-2 Calibration Error Measurements for Total Hydrocarbon Analyzer (Percent Actual Gas Value) Actual Gas Concentration (ppmv) Inlet Instrument OutletInstrument Date Test Run 0 15 30.4 45.5 0 29i 600 914 1604 IO-Apr NMMA-14-1 0410-01 N.A. 0.0 0.0 -0.7 N.A. 1.3 2.3 0.0 II-Apr NMMA-14-2 0411-02 NA 0.7 0.0 , -0.4 N.A. ·0.4 1.4 -2.1 IS-Apr NMMA-16-1 0415-01 N.A. 2.7 2.3 0.4 N.A. -0.8 -0.1 -3.4 16-Apr NMMA-16-2 0416-01 N.A. 2.0 2.3 0.2 NA -0.9 0.1 0.0 2-Apr NMMA-6-P Q402-01 N.A: 0.7 1.3 -1.5 N.A. -0.3 -0.7 -0.3 8-Apr NMMA-6-1 0408·01 N.A. -1.3 0.0 -0.4 N.A. 0.7 2.3 0.0 II-Apr NMMA-6-2 0411-01 N.A. 3.3 4.3 0.4 NA -0.5 0.3
. -0.1 3-Apr NMMA-4-1 0403-02 N.A. -0.7 -0.3 0.0 NA 1.8 3.0 0.2 a-Apr

_ NMMA4-2 0408-03 NA -1.3 0.0 -0.4 N.A. 0.7 2.3 0.0 H-Apr NMMA-5-1 0412-02 N.A. 2.0 1.3 0.2 N.A. -0.6 0.3 -0.1 14-Apr NMMA-5-2 0414-01 N.A. 2.0 1.3 0.2 N.A. 0.7 1.9 -1.2 10-Apr NMMA-13-1 0410-02 NA 0.0 -0.7 0.2 N.A. 2.0 2.8 -0.1 II-Apr NMMA-13-2 0411-03 NA 0.7 0.0 -0.4 N.A. -0.4 1.4 -2.1 IS-Apr NMMA-15-1 0415-02 NA 2.7 2.3 0.4 N.A. -0.8 -0.1 -3.4 I6-Apr NMMA-15-2 0416-02 NA 2.0 2.3 0.2 N.A. -0.9 0.1 0.0 4-Apr NMMA-3-1 0404-02 NA -1.3 -0.7 0.0 ·N.A. -0.3 -0.7 -0.3 a-Apr NMMA-3-2 0408-02 NA -1.3 0.0 -0.4 N.A. 0.7 2.3 0.0 5-Apr NMMA-l-l 0405-02 NA -4.7 -1.3 0.4 N.A. 2.5 4.8 2.8 9-Apr NMMA,I-2 0409-01 NA 0.7 0.3 0.2 N.A. -0.8 0.2 0.0 12-Apr NMMA-2-1 0412-02 N.A. 2.0 1.3 0.2 N.A. -0.6 0.3 -0.1 14-Apr NMMA-2-2 0414-03 NA ·2.0 1.3 .0.2 N.A. 0.7 1.9 -1.2 lO-Apr NMMA-13-1 0410-02 NA 0.0
. ·0.7 0.2 N.A. 2.0 2.8 -0.1 II-Apr NMMA-13-2 0411·03 NA 0.7 0.0 ·0.4 NA ·0.4 1.4 ·2.1 18·Apr NMMA·9·1 0418-01 NA 0.7 1.0 0.0 N.A. 0.0 0.0 -0.1 .1.7 I9-Apr NMMA·9·2 0419-01 N.A. .1.3 0.7 -0.4 N.A. ·0.7 0.8 0.1 3-Apr NMMA-8-1 0403·01 N.A. -0.7 ·0.3 0.0 N.A. 1.8
. 3.0 0.2 S-Apr NMMA·8·2· 0405-01 NA ·1.3 4.6 -4.8 NA 4.7 4.8 1.1 4-Apr NMMA-7-1 0404·01 NA ·1.3 ·0.7 0.0 N.A. 0.5 2.6 ·0.4 7-Apr NMMA·7·2 0407·0I NA -4.7 -3.9 0.7 N.A. 3.0 5.2 0.0 9-Apr**NMMA~II-1** .0409-03 NA 0.7 0.3 0.2 N.A. ·0.8 0.2 .0.0 lO-Apr NMMA·ll·2 0410·03 N.A. 0.0 -0.7 0.2 N.A. 2.cr 2.8 -0.1 12·Apr NMMA·ll·3 0412-01 N.A. -1.3 .1.3 ·0.9 N.A. 2.8
. 3.8 0.6 14-Apr NMMA·12·1 0417-01 NA 3.3 2.6 . 0.2 N.A.
. -0.1 0.7 -0.1 ·0.1 18-Apr NMMA-12-2 0418-02 N.A. 0.7 1.0 0.0 N.A. ·0.9 0.0 -0.1 .1.7

. .

4-3 Rev. IBaseline Emission Testing Table 4-3 Calibration DriftMeasurements for Total Hydrocarbon Analyzer

. (Percent Span) Actual Gas Concentration (ppmv) InletInstrument Outlet Instrument Date Test Run 0 15 30.4 45.5 0 297 600 914 1604 to-Apr NMMA-14-1 0410-01 0.0 -0.4 -10 -4.2 0.0 -D.2 0.5 1.9 'U-Apr NMMA-I4-2 0411·02 0.0 -0.2 0.2 

### , -0.2 0.0 0.1 -0.3 -0.1

IS-Apr NMMA-16-1 0415·01 0.0 -0_6 -1.2 I N.A. 0.0 -0.6 -1.1 NA I6-Apr NMMA-I6-2· 0416-01 0.0 0.0 ·1.6 NA 0.0 -0.4 -0.2 NA 2-Apr I. NMMA-6-P 0402·01 -0.6 -0.8 N.A. 2.4 0.0 0.1 NA 0.6 g-Apr NMMA-6-1 0408-01 0.2 0.4 -2.2 N:A. 0.0 0.2 0.8 N.A. ll-Apr NMMA-6-2 0411-01 0.2 -0.8 -2.6 -0.8 0.0 0.0 0.6 -1.9 3-Apr "NMMA-4-1 0403-02 -10 -1.2 -1.6 -3.8 0.0 -0.2 -D.3 15 g-Apr NMMA-4-2 0408-03 0.0 -0.4 -1.8 -2.6 0.1 -0.2 0.0 2.1 12-Apr NMMA-S-l 0412-02 0.0 0.8 16 N.A. 0.0 -1.1 -1.6 NA 14-Apr NMMA-5-2 0414·01 -0.8 -1.4 -3.2 NA 0.0 -0.1 0.1 N.A. lO-Apr NMMA-13-1 0410-02 -0.4 -LO ·1.2 N.A. 0.0 -0.8 -1.1 N.A. ll-Apr NMMA-13-2 0411·03 -0.2 -0.4 -0.6 N.A. 0.0 -0,2 -D.3 NA

. IS-Apr NMMA-15-1 0415·02 0.0 -0.2 -1.2 N.A. 0.0 -D.6 -D.9 NA I6-Apr NMMA-lS-2 0416·02

. -0.2 -0.2 -1.4 NA 0.0 0.0 0.6 NA 4·Apr NMMA-3-1 0404-02 -1.6 ·1.2 ·1.0 NA 0.0 0.1 N.A. 0.6 a-Apr NMMA-3-2 0408·02 0.0 -0.2 -1.4 N.A. 0.0 -D.4 -D.3 'NA 5-Apr NMMA-l-r 0405·02 -1.2 10 1.4 NA 0.0 0.3 0.4 N.A. 9-Apr NMMA-J-2 0409-01 O.Q -0.6 -0.6 N.A. 0.0 -0.2 0.0 NA I2-Apr NMMA-2·1 0412-02 ·0.2 -0.6 -0.6 NA 0.0 -D.9 -1.5 N.A. 14-Apr NMMA-2-2· 0414-03 -0.2 -2.0 -2.6 NA 0.0 -0.1 0.1 NA 10-Apr NMMA-I3-1 0410-02 -0.4 -1.0 -.1.2 N.A. 0.0 -D.8 -1.1 NA ll-Apr NMMA-I3-2 0411-03 . -0.2 -0.4 -0.6 NA 0.0 -0.2 -D.3 NA 18-Apr NMMA-9-1 0418-01 -0.2 -0.2 -1.2 NA 0.0 NA 0.0 0.5 NA 19-Apr NMMA-9-2 0419-01 -1.0 -0.4 -2.0 NA 0.0 0.1 0.1 NA 3-Apr NMMA-8-1 0403-01 -1.2 0.8 NA NA 0.0 NA 0.5 N.A. 5-Apr NMMA-8-2 0405-01 -3.8 -0.8 0.8 N.A. 0.0 -D.6 0.0 16 4-Apr NMMA-7-1 0404-01 -0.2 -0.6 NA -1.8 0.0 -0.2 NA 2.3 7-Apr NMMA-7-2 0407·01 -2.6 0.8 -2.8 NA 0.0 0.4 -. 0.9 NA 9-Apr N1v1MA-ll-1 0409-03 -0.2 -1.2 -0.8 -3.0 0.0 0.0 0.4 -0.2 10-Apr NMMA'1l-2 0410-03 -0.4 -0.6 -D.8 NA 0.0 -0.4 -0.8 N.A. 12-Apr NMMA-U-3 0412-01 -0.4 -2.2 -0.6 N.A. 0.0 -0.1
. 0.5 N.A. 14-Apr NMMA-12-1 0417-01 -0.2 0.4 3.2 NA 0.0 0.1 0.5 1.3 NA IS-Apr NMMA'I2-2 0418-02 0.0 -0.4 -1.0 N.A. 0.0 0.2" 0.4 0.8 NA



### 4-4 Rev. 1Baseline Emission Testing response to propane. The response factors, determined for the outletTHe analyzer only, are listed in Table 4-4. The variation in instrument response factors serves as a measure ofthedayto dayprecision ofthe measurements as well as a correlation to styrene concentrations. The average relative response factor determined as the average ofthe dajly average relative response factors for seven days ofmeasurements, including values determined for all styrene calibration standards brought on site, is 2.40, with a standard deviationof0.053 (±2.2 percent). The issue ofdaily variation in response factors was not addressed in the QAPP and no criterion for data acceptance has been suggested. The standarddeviation ofthe responsefactors is within the precision requirement for the THe calibration and drift criteria. 

### Table 4-4 Specific Compound Relative Response Factors for the Total Hydrocarbon Analyzera

'Relative response factor 15 the THe Instrumentmeasurement dIVIded by the calrbratIOn gas concentration. e.g., ppm propane/ppmstyrene. Styrene THe Relative MMA THC Relative Concentration Response Response Concentration Response Response Date (ppmv) (pprnv) Factor (ppmv) (ppmv) Factor I-Apr 204 487.7 2.39 3-Apr . 45.8 62.7 1.38 7-Apr 204 506.8 2.48 9-Apr 122 300.1 2.46 9-Apr 204 490.3 2.40 12-Apr 204 468.5 2.30 12-Apr 59.2 148.4 2.51 15-Apr 59.2 138.5 2.34 16-Apr 59.2 137.6 2.32 19-Apr 59.2 141.5 2.39 139.6 166.8 1.19 19-Apr 122 304.3 2.49 Average 2.40 . 1.28

.

..

4-5 Rev. 1**-~~** IYMMA 

# .JI/If"'" Baseline Emission Testing 4.1.2 Organic Compound Concentrations (Method 18)
Method 18 calibrations were conducted every morning before starting a test run. Calibrations were checked aftereach run to ensure that the instrument remained in calibrationfor the test series. A measure ofcalibration is 

### , provided by the reSponse factors (Figures'4-1 and 4-2), which are simply the calibration gas concentration divided by the area counts from the chromatogram (i.e., the GC response). As the figures indicate, there was more variability in the response factors early in the sampling program. This variability resulted from leaking ofthe gas injection-valve during these early runs. On April 12, the valve was replaced, and the response factor variation was reduced (after fillalysis 

### No. 714). 

### Figure 4-1 Method 18 Response Factors for Styrene Response Factors for Styrene

-Method 18
. '0.00008 0.00007



# - 0.00006 0 t 0.00005 N 

## '" 0.00004 

## a 0 0.00003 0..



# ..II
........ 0.00002 0.0000 1 0 '¢' N c:: ::=

_ 0 -<(C-:-_(C t- r- c:c :c C':l C) I 

## I Analysis Number

Method 18 data for this programhave beenused primarily to determine the relative quantities ofstyrene and MMA emitted during
4-6 Rev.lBaseline Emission Testing gelcoating. The Method 18 results are also useful for comparison with the results ofMethod 2SA testing. The relative concentrations ofthese two compounds in the TIE exhaust is important. An assessment ofthe ratio ofthe average response factors for styrene and MMA before and after April 12 (Analysis No. 712) shows thatthe leaking valve had little or no effec,t onthe determination ofthe relative concentrations ofthese two compounds (Table 4-5) on average. 

### Figure**4~2**



### .Method 18 Response Factors for Methyl Methacrylate Response Factors for**~D.LA.** -Method 18
0.00016**.-----------~~---------------_,** 0.00014+-----------------11---------___1 0.00012**+-----------------II-------~-___1**

0.00004 0.00002 o 0.0001 

### +--,---------------,,-----------1

0.00006 +----,------,,-{\---.--If---Il--lll

# - B 

## '" 0.00008 +---------------II----;:--n § "-

Analysis Number



### Table 4-5 Method 18 Response Factorsfor Target Compounds**~1IJ!~_~~~~~~iI~~o~~~PtPJ1,~~~-illf£ljtl~1$t&~I_~:;:~~&1** Styrene 2.78E-05 U7E-OS MMA S.87E-05 2.27E-OS Styrene:MMA 0.473 0.516

4-7 Rev. 1Baseline EmissionTesting Daily response factor ratios were also assessed (Figure 4-3). Only those days when styrene and MMA results were needed. and the final check conducted on April 19, are presented in the assessment. The figure illustrates the variability seen in the individual measurements, although the degree of variability is lessenedthrough the averages. The ratio ofthe response factors 

# . . (importantin apportioning emissions to'styrene and MMA for gelcoating test runs) was relatively constantfor all gelcoat test days except April 3 and April 8. The results for April 3 appearto be consistent with other days; so the difference in response factor ratio did not appear to affectresults for that test. The results from April 8,however, indicate much lower concentrations ofMMA than noted for all other gelcoat testruns. Styrene results for that testn,m were consistent. with other measurements and Method 25Aresults were typical. The abnormally low reading for MMA is attributed to poor response for that calibration. 

### Figure 4-3 Method 18 Response Factors for Selected TestDays

2-Apr 3-Apr 4-Apr S·Apr a-Apr 9-Apr 1·1-Apr 19-Apr 1c::::::J9.yrene c:::::::JMMA "";-Syrene:MMA I 

## I 

# I 8.0E-05
7.0E-05
6.0E-05 

### , 0 " 

### • 5.0E·05c4.0&05 .9 " 

### • u. 3.oE-05 0 • c 0 c- 2.0E-05 • 0 

## " 1.0E-05
O.OE+OO**~------------,k,-------------.** 0.7
0.6
0.5 

### '" 

# .. " 0.4 ..s "
o 0.3 oco 

## " 0.2
0.1

4-8 Rev; 1Baseline Emission Testing The relative concentrations ofstyrene and MMA were determined using the following approach. Area counts based on chromatographic analyses were determined for each compound at varying levels ofgas concentrations. An average response factor was then determined for various gas standards. A point

.. to point calibration curVe was generated plotting area count against gas 

### , concentration assuming alinearfunction from pointto point. These calibration curves. (Appendix C) were then used to determine the relative concentrations of styrene and MMA in each sample analyzed.
Table 4-6 lists the QC measurements and theirresults. These measurements pertain only to styrene calibrations, because all gelcoating runs (i.e., the onlyruns involving MMA) had been completedby the time of equipment repair (April 12). Allthe pretest measurements ofprecision metthe criteria defined for this program (within 10 percent ofmean value). Drift exceeded the acceptance criteria ofless than 5percent ofpretest values on four days; all these events occurred at the 59.2 ppmv styrene level. Data comparisons made between GC and THC concentration measurements show a higherlevel of styrene measuredbythe GC than by the THC analyzer, largely because the THC. results are average results and the GC reports the concentration ofa grab sample, generally selected by the GC operatorto analyze temporal peaks in concentration. Because the reported emissions were calculated from the Method 25A results, driftin Method 18 measurements has no effect on the. reported emissions.

4-9 Rev. 1Baseline EmissionTesting 

### Table 4-6 Gas Chromatography Calibrations (after

### April 12) Analysis Concn Precision Date No. (ppmv) Area Count RF (%Mean) Drift Comment 12-Apr 713 59.2 5971597 9.91E-06 .Pre 5-2 714 59.2 6009331 9.85E-06 -0.31 Pre 5-2 12-Apr 729 59.2 5958909 ,9.93E-06 Post 5-2 730 59.2 6291424 ;9.41E-06 Post 5-2 731 59.2 6429882 9.21E-06 -1.09 Post 5-2 732 122 10977608 1.1lE-05 Post 5-2 I, 733 122 11537000 1.06E-05 -2.48 Post 5-2 734 204 16097608 1.27E-05 Post 5-2 735 204 14421208 1.41E-05 Post 5-2 736 204 21264480 9.59E-06 Post 5-2 737 204 19247328 1.06E-05 Post 5-2 738 204 19026992 I.Q7E-05 0.58 Post 5-2 12-Apr 759 59.2 5525818 1.Q7E-05 Post 2-1 760 59.2 5794490 1.02E-05 -2.37 Post 2-1

, 761 122 11881808 1.03E-05 Post 2-1· 762 122 10850096
. !.l2E-05 4.54 Post 2-1 14-Apr 768 0 352953 pre 5-2 769 0 203009 pre 5-2 470 59.2 4755664 i.24E-05 pre 5-2 471 59.2 4167498 l.42E-05 pre 5-2 472 59.2 4384538 1..3?E-05 -2.54 pre 5-2 473 122 9803558 1.24E-05 , pre 5-2 474 122 8547834 1.43E-05 pre 5-2 475 122 8905798 1.37E-05 -2.05 pre 5-2 476 204 16823296 1.21E-05 pre 5-2 477 204 ' 16883072 1.21E-05 pre 5-2 478 204 17030400 1.20E-05 -0.43 ore 5-2 14-Apr 796 204 17182512 !.l9E-05 post 5-2 797 204 16327544 l.25E-05 post 5-2 798 204 16258032 l.25E-05 3.18 nost 5-2 14-Apr 818 204 17429680 1.17E-05 post 2-2 819 204 16991360 1.20E-05 -0.59 post 2-2 820 59.2 5021901 !.l8E-05 post 2-2 821 59.2 5041053 1.17E-05 -15.07 post 2-2 823 0 0 824 0 0 IS-Apr 826 0 176395 O.OOE+OO pre 16-1 827 0 213703 O.OOE+OO pre 16-1 830 59.2 4179248 1.42E-05 pre 16-1 831 59.2 5030979 !.l8E-05 -9.25 pre 16-1 832 122 9615066 1.27E-05 pre 16-1 I, 833 122 9712975 1.26E-05 -0.51 pre 16-1 834 204 17192032 '1.l9E-05 pre 16-1 835 204 16329160 l.25E-05 2.57 pre 16-1 854 204 17244432 !.l8E-05 -2.87 post 16-1 855 59.2 4923560 1.20E-05 -7.27 post 16-1 875 59.2 4928013 1.20E-05 post 15-1 876 59.2 I 4053978 1.46E-05 0.54 postl5-1 877 59.2 4739386 1.25E-05 post 15-1

, 878 204 17330048 !.l8E-05 -3.35 nost 15-1

4·10 Rev. 1

### Table 4-6 (continued) Baseline Emission Testing

Analysis Concn Precision Date" 

### No. (ppmv) Area Count RF (%Mean) Drift Comment 16-Apr 879 0 0 pre 16-2 880 0 0 pre 16-2 881 59.2 4915139 . 1.20E-05 pre 16-2 882 59.2 4863680 1.22E-05 0.53 pre 16-2



### - 883 122 10776440 1.13E-05 pre 16-2 884 122 9171008 'r.33E-05 pre 16-2 885 122 10341320 '1.18E-05 pre 16-2 886 122 10572206 1.15E-05 -1.10 pre 16-2 16-Apr 905 59.2 4956816 1.19E-05 post 16-2 906 59.2 4863680 1.22E-05 -0042 post 16-2 910 0 660 0.00£+00 post 16-2 911 122 11027728 1.11E-05 post 16-2 912 '122 10367112 1.18E-05 -2.17 post 16-2 16,Apr 934 0 0 post 15-2 935 122 10505456 1.16E-05 postl5-2 936 122 10076096 1.21E-05 1.64 post 15-2 937 59.2 4985315 1.19E-05 post 15-2, 938 59.2 5178906 1.14E-05 -3.76 DOSt 15-2 17-Apr 939 0 0 pre 12-1 940 0 2044 pre 12-1 '941 59.2 4324157 1.31£-05 pre 12·1 942 59.2 4535176 1.31E-05 pre 12-1 943 59.2 4768189 I.14E-05 -2.50 pre 12-1 944 122 10597432 1.15E-05 pre 12-1 945 122 9772608 1.25E-05 4.05 pre 12·1 17-Apr 960 204 17712032 1.15E-05 post 12-2 961 204 18269232 1
.. 12E-05 -1.55 post 12·2 962 122 10231520 1.19E-05 -0.62 post 12-2 963 59.2 5499240 1.08E-05 post 12·2 964 59.2 5894784 1.00E-05 -18.30 Dost 12-2 18-Apr 978 0 1915 pre 9·1c 979 0 3089 pre 9-1c 980 59.2 5035434 1.18E-05 pre 9·1c 982 59.2 5181651 1.14E-05 -1.43 pre 9-1c 983 204 19345344 1.05E-05 pre 9·1c 984 204 18797024 1.09E-05 1.44 pre 9-1e 18-Apr 1018 204 18110944 1.13E-05 post 9-1 1020 204 19007808 1.01£-05 2.80 post 9-1 1021 59.2
. 5687642 I.D4E-05 -10.20 post 9-1 19-Apr 1035 59.2 4908355 1.21E-05 pre 9·2 1036
. 59.2 4736861 1.25E-05 1.78 pre 9-2 1037 204 18883424 1.08E-05 pre 9-2 1038 204 19033904 1.07E-05 -0040 pre 9-2 19-Apr 1'070 204 18327536 1.11E-05
. post 9-2 1071 204 18467392 1.10E-05 3.05 post9-2 I· 1072 122 11.046080 I.IOE-05 post9-2 1073 122 10864040 1.12E-05 post9-2 1074 122 11025512 1.11E-05 3.28 post 9-2 1075 59.2 5985747 9.89E-06 post9-2 1076 59.2 5700285 1.04E-05 0.00 -17.44 post9-2 19-APf 1077 59.2 5780963 1.02E-05· 0.01 Bias test 19-Apr 1078 6178867 MMABag7 1079 6176253 MMA Bag 7


### 4-11 Rev. 1.."
....**~AP** JVMMA

---- Baseline Emission Testing
4.1.3 Comparison ofMethods in Determining Emissions There is relatively good agreement betweenthe results ofthe two methods, with most ofthe measurements within 6-8 percent. The runs that had more divergent results were typically thoS'e involving smallermolds. Table 4-7 , presents a comparison ofthe results in terms ofpercent ofavailable volatile material. which for most ofthe testing was styrene only.


### Table 4-7 Comparison ofEmission Results by 

### Two Methods
Emissions (% Emissions (%

Available)

- Available)

- Date Test Description Metbod 25A Method 18 2-Apr NMMA-6-P 18 Deck Gel 47.0% 54.1% 4-Apr NMMA-7-1 28 Hull 35 R 15.7% 18.2% 7-Apr NMMA-7-2 28 Hull 35 R 18,8% 18.4% 8-Apr NMMA-6-1 18 Deck Gel 42.3% 43.1% 8-Apr NMMA-3-2 18 Hull Gel 54.2% 53.5% 8-Apr NMMA-4-2 18 Deck 35 R 16.1% 16.1% 9-Apr NMMA-I-2 18 Hull 35R 13.9% 13.2% 9"Apr NMMA-ll"IG CFA Gel 43.4% 39.0% 9-Apr NMMA-II-IR CFA 35R 29.8% 37,1% 10-Apr NMMA-14-1 18 Deck 35R

- FC 11.1 % 

# . 10.4% 10-Apr NMMA-13-1 18 Hull 35R

- FC . 10.5% 11.0% 10-Apr NMMA-11-2R CFA 35R 28.8% 26.8% ll-Apr NMMA-6-2 18 Deck Gel 45.2% 46.4% ll-Apr NMMA-14-2 18 Deck 35R

- FC 12.1 % 11.1% ll-Apr NMMA-13-2 18 Hu1l3SR

- Fe . 10.5% 10.9% 12-Apr NMMA-II-3R CFA 35R S2.0% 44.8% 12-Apr NMMA-S-I 18 Deck 42R 20.4% 14.1% 12-Apr NMMA-2-1 . 18 Hull 42R 22,3% 24.1% 14-Apr NMMA-5-2 18 Deck 42R 20.8% 22.4% 14-Apr NMMA-2-2 18Hu1l42R 18.2% 14.2% IS-Apr NMMA-16-1 18 Deck 42R.FC 12-2% 12.0% 15-Apr NMMA-15-1 18 Hull 42R-FC 11.6% 11.7% 16.Apr NMMA-16-2 18 Deck 42R-FC 14.0% 14.4% 16-Apr NMMA-15-2 18 Hull 42R-FC 10.6% 10.8% 17-Apr

- NMMA-12-1 CFA 42R 54.6% 44.8% 18-Apr NMMA-9-1 28 Hull 42R 22.8% Z,5.S% 19-Apr**NMM~-9-2** . 28 Hull42R 23.0% 23.5% 18-Apr NMMA-12-2 CFA 42R 39.2% 38.2%

4-12 Rev. IBaseline Emission Testing Certainly, the concentration measurements made using both approaches yielded consistent results. The THC concentrationtrace for Run NMMA-7-1 and an equivalentTHC concentration trace generated using measured styrene and MMA concentratioI)s and the response factors developed during this program (2.40 for styrene and '1.39 forMMA), although not identical, show fair agreement for the different FlDs (Figure 4-4). 

### Figure 4-4 Comparison ofTotal Hydrocarbon Traces byTwo Methods
NMlV'.tA-7-1



## .

. 

### 'lI", 

## 1\

. 

# M

- I 

## .... 

# rm/**.~** 

### . '"Ij 

## y i;.l 

# \ . 

## p?**.~** 

# ,

....

y 

# ,

.

.

I-I-M25A -e-MI8Eq 

### I 800
700 0- 

## a 600 Co 8 Co S500 Co .& § 400 300 

### = <3 200 100

o 8:38 9:50 11:02 12:14 Time (PST) 13:26 14:38 15:50

4-13 Rev. 1

### ~--- /YMMA

---- Baseline Emission Testing 4.2 Gelcoat and Resin Flow Rate' Spray gun resin and gelcoatflow rates were determined at the start and end ofeach test day (Table 4-8). A single assessmentwas made during each flow rate check. Resin-to-glass ratioswere assessed during the' initial resin

. . 

# . calibrations (Table 4-8).**Catalyst-to~resin/gelcoat** ratios were set according to the catalyst pump stroke rate. These ratios remained constant dUring testing. 

### Table 4-8 Spray Equipment Data Summary· FlowRate (g/min) Percent Resin Glass Percent Eouinment Date Pre test Posttest Change (g) (g) Glass Spray gun/ 3-Apr 327 180 35.5 Resin 4-Apr . 324· 128 28.3 5-Apr 2888 2916 1.0 148 77 34.2 7-Apr 2828 3092 '9.3 277 149 35.0 8-Apr 2792 2896 3.7 301 176 36.9 9-Apr 2836 2776 -2.1 242 127 34.4 lO-Apr 2956 2784 -5.8 222 114 33.9 12-Apr 2892 3100 7.2 218 117 34.9 14-Apr 3192 3096 -3.0 378 201 34.7 17-Apr 3100 31q 152 32.4 18-Apr 2944 2992 1.6 300 160 34.8 19-Aor 3036 2904 -4.3 256 148 36.6 Flow lO-Apr 2956 . 2784
. -5.8
. 222 114 33.9 Chopper 11-Apr 2556 2668· 4.4 297 158 34.7 IS-Apr 3164 3388 7.1 406 192 32.1 16-Aor 3084 3072 -0.4 3i7 162 33.8 Spray gun/ 3-Apr 1264 1256 -0.6 Gelcoat 4-Apr 1256 1260 0.3 5-Apr 1264 1264 0.0 8-Apr 1260 1268 0.6 9-Apr 1272 1276 0.3 I 11-Aor 1256 1260 0.3

4-14 Rev. 1

# ---- IYMMA 1'1'1'1' Baseline Emission Testing 4.3 AirVelocity overMold Surface
Airflow over the mold surface was assessed twice during the test program. These**measurement~** reflect a best assessment approach and no presumption of"accuracy has been made. IJ;1 additionto being difficult to assess accurately, airflow over the mold (i.e., velocity) was dependent

### On mold position in the TIE, a factor that changed every time a tool was brought into the enclosure or moved within the enclosure in the'process oflamination or gelcoating. The velocities measured at the mold surface were consistent with measurements made over mold surfaces in the manufacturing area, taking into account thatthe TIE was designed for induced draftflow. Greater emphasis was placed on controlling air now through the enclosure to reflectconditions found in the facility than on attempting to duplicate the velocities measured during

.previous studies using.parts ndt typical ofboatbuilding.
Measurementsmade during atechnical system audit performed by MRI and the EPA were consistentwith the measurements made during this program. Their findings are reported in MRI's 

### TechnicalSystemsAuditDfa 

### LabDratDrySprayBDDth at the 

# u.s. Marine FacilityinArlington, WashingtDn (May 29, 1997)
. 4.4 Exhaust Flow Rate
Air flow rate through the enclosure was measured and monitored as described in Section 3.2.2. Accuracy ofthe velocity measurement can be assessed by observing the variability ofthe velocity head measurements (which were accurate to within 0.005 inches ofwater) during the test. This yields an assessment terms ofpercentwhich can be compared withthe acceptable criteria ofthe method. Variabilitymeasurements for all test runs are shown with
4-15 Rev. 1Baseline Emission Testing 

### the testaverages (Table 4-9). The overall average variability in flow rate forthe program was 2.9 percent, and no measure for**a~** 

### entire day was greaterthan 6.9 percent. The two instances ofgreatestvariability were affectedby the two measurements on April 4, early in the program, when TTE exhaust filters had been allowed to become partiallyblocked,andwere first being changed during the test runs. 

### Table 4-9 Variability Measures for Flow Rate During TestRuns

. Flow Rate Variability (%) Date RunI Run 2 Run 3 ,. Average 2-Apr 1.0 1.0 3-Apr 2,5 3.2 2.9 4-Apr 4.9 8,9 6,9 5-Apr 2.2 1.2 1.7 7-Apr 2,5 2,5 8-Apr 1.4 3,3 1.8 2.2 9-Apr .3,2 3.5 0.9 2.6 10-Apr 2.3 2.8 3,0 2,7 ll-Apr 2,9 4.5 3.7 3,7 12-Apr 4,3 4.2 3.7 4.1 14-Apr 3,2 2.4 2,8 15-Apr 3,3 3.5 3.4 I6-Apf 2.1 1.7 

# . 1.9 17-Apr 2.5 2,5 I8-Apr 2,7 2.4 2.5 I9-Aor 2,3 2.3 Averal!e 2,9



### Flow rates during the test program were observed (based onthe continuous,fixed pointvelocity head measurements) to vary based onfilter collection and other operations. The exhaust plena on both'longitudinal sides of the enclosure were eqUippedwith filter media (spun fiberglass airfilters). Flow rate decreased with time as these filters collected air-borne resin containing

- reactive styrene and MMA, which polymerized on the filter media. Periodically, these filters were replaced to ensure more consistentflow rates through the
4-16 Rev. 1Baseline Emission Testing enclosure for all test runs. The build-up ofmaterial on the filters was one cause ofthe variability in flow rate measured during the overallprogram. To some smaller extent, this affected flow rate overthe course ofthe test run, more so for the larger articles which reqUired more resin. A second cause ofthe fluctuation in flow rate was activity in the building where the enclosure was located.

. 

# .. Temperature was affected by the opening and closing ofdoors into the building. Changes in the system operated by RTI also had some effect on the measurement· offlow because both systems were connectedto the same exhaust system at the U.S. Marine facility. Changes made to accommodate their operation had some effect on exhaust system pressure, thus affecting flow ratethrough the larger enclosure.


### 4.5 Exhaust Air Temperature
As described in Section 3.2.3, enclosure airtemperature was monitored continuously using a type Kthermocouple atthe location ofthe fixed pitot and the DAS, calibrated at two points. The accuracy ofthis measurement was O.005°F (or**O.O~Ol** mY). Measurements ofprecision were notmade during the test program; however, literature suggests the precision oftype K thermocouples, assessed in alaboratory environment, will yield aprecision of O.5°F,or within 1 percent ofthe measured values.
4.6 . ResiniGelcoatBalance
Balance calibration checks were often performedwithbarrels of resin still on the platform and always performed without zeroing the balance. Therefore, the calibration error was calculated in terms ofpercent ofweight change rather than the displayedweight value (Table 4-10). All calibration results display a level ofaccuracy, measured as percent error, meeting the
4-17 Rev.lBaseline EmissionTesting 

### criteria ofthe QAPP (within 2Ib). Based on the maximum error measure of 0.2 percentand the high end ofthe scale measurements (Le., 500 lb), the accuracy was within approximately 1 

### lb. 

### Table 4-10 , 

### Results ofBalance Galibration 

### Checks Tare Weight Initial Scale Scale Changei" Errof'(% Date (Ib) Reading (Ib) Response (Ib) Weight (Ib) ,Tare) 6-Apr 

### a 0.0 

### a 0.0 NA 500 0.0 500.1 500.1 0.02 300 0.0 300.1 300.1 0.03 100 0.0 100.1 100.1 0.10 8-Apr 

### a 0.0 -1.9 0:0 NA 100 0.0 98.1 100.0 0.00 200 0.0 197.9 i99.8 -0.10 300 0.0 297.8 299.7 -0.10 400 0.0 397.6 399.5 -0.12 500 0.0 497.5 499.4 -0.12 lO-Apr 

### a 201.7 201.7 0.0 NA 50 201.7 251.7 50.0 0.00 100 201.7 ' 301.7 100.0 0.00 200 201.7 401.7 200.0 0.00 IS-Apr 

### a 231.7 231.7 , 0.0 NA

, 100 231.7 331.7 100:0 0.00 200 231.7 431.9 '200.2 0.10

- 250 231.7 481.8 , 250.1 0.04 19-Apr 

### a 0.0 -1.33 0.0 NA 100 0.0 98.5 99.8 -0.17 200 0.0 198.7 200.0 0.02 300 0.0 298.7 300.0 0.01 400 0.0 398.8 400.1 0.03 500 0.0 498.7 500.0 0.01 100 0.0 98.9 100.2 ' 0.23 

### 4.7 Technical Systems Audit
The performance ofthe sampling systemwas assessed through an audit andstyrene recovery tests. Audits ofthe THe sampling, balance, and flow measurement systems were performed. The system auditwas conducted by

4-18 Rev. 1Baseline Emission Testing EPA/OAQPS and its contractorMRI. The EPA/OAQPS auditwill report on this project, but the final reporthas not been released. Also, styrene recovery tests (styrene evaporation tests) were performed in accordance with the QAPP.
4.7.1' Total Hydrocarbon Measurement

. - , The results ofthe Method 25A system audit are presented in Table 4-11. The audit gas was introduced.in two manners during the
. performance ofthe audit. One method involved fIlling aTedlar® bag with the audit gas and attaching it to the sampling probe. In the second method, the audit cylinder was connected to the calibration system and thegas was introduced to the sampling system in the same manner as all on-site calibrations were performed; the propane auditwas performed only with this latter method. Both methodsyieldresultS representative ofthe system performance
.



### . Table 4-11 AuditResults for Method 25A Measurements

39.7' 39.7 1000 999 Pro ane +0.1 a. Gas standard reported at 41.7 ppmv; on site analysiS by GC reported 39,7 ppmv. b. Response factor to styrene Is 2.289 on4/15 and 2.318 on 4/16. c. Test performed with audit gas inTedJar(E) bag. d. Test performed with audit gas in vented cylinder. Conversion ofTHC concentration to eqUivalent concentrations of

. styrene was done using daily relative response factors determined from the THC
.

analyzer (Method 25A} on the day ofthe audit. Using the pre-test analysis by Scott Specialty Gases (41.7 ppmv styrene), the analysis by

### THe analyzer was about 12 percentlow. However, on-site analysiS ofthe standard by GC indicated 4-19 Rev. 1Baseline EmissionTesting 

### that the concentration in the audit sample was only 39.7 ppmv. Althoughthis assessment does not meetthe requirements ofaprotocol gas certification, the results indicate that the certifiedvalue ofthe audit cylindermay be slightly low. Comparing to concentration from this reanalysis ofthe standard shows thatthe THC analysis was only 7.3 percent low, v.:ithin the criterion establishedfor the program. This low recovery does not appear to be a system malfunction. The good results ofthe propane audit indicate the low results ofthe styrene audit sample are not a result ofsampling system bias (leaks). Further, procedures in determining response factors included introduction ofthe gas atthe probe; thus· incorporating any system characteristics into the results. The results ofthe styrene auditindicate the sampling system, as used in the performance ofthe audit, .results in an underreporting ofstyrene concentrations by less than 10 percent at a 40-ppmv concentration, or about 3 ppmv styrene.
4.7.2 Weigh Cell Balance


### The results ofthe weigh cell balance auditperformed on April 16 indicate that greater than 5 percent error results when weighing less than 3000 g, or approXimately 6.6Ib, on an empty scale (Table

### 4-12).Howev~r, testing was conductedwith a drum ofresin or gelcoat orresin inplace, meaning that the scale was used during the testprogram in its normal operating range. The results ofthe audit and the calibration checks (Table 4-10) demonstrate that even small weight changes can be measured accurately through the weightrange experienced during this test program. Although the auditwas conductedwith an empty balance, the calibration checks were conductedwith both empty and loaded scale (i.e., with a drum ofresin in place). Data collected from the calibration check using certified weights on April 8indicate that aless than lIb change in weight at an elevated balance response (512Ib) was accurately quantified. These data indicate the balance was capable ofaccurately measuring
4-20 Rev. 1Baseline EmissionTesting 500-g (l.1-lb) changes in weight in the range ofoperation, well within specifications ofthe QAPP (Le., 2Ib). Two data points from the audit can be used to assess the precision ofthe weight measurements. The replicate weighing performed at 57 and 157 lb indicate a precision ofgreater than 0.2 lb, also within QAPP specifications. 

### Table 4-12 

### Results ofAudit onBalance Scale Net Scale Audit Response Scale Initial Response Difference Date Weight (g) (Ib) (lb) (lb) (lb) % Error 8-Apr' 3000 504.3 497.6 6.7 0.086 . 1.30 5000 508.7 497.6 ll.l 0.077 0.70 6000 510.9 497.6 13.3 0.072 0.55 6500 512 497.6 14.4 0.070 0.49 Scale Net Scale Audit Response Scale Initial Response ,Difference Weight (lb) (lb) (Ib) (lb) (lb) % Error 16-Aprb 0 -1.92 -1.92 0 0.00 NA 0.002 -1.94 -1.92 -0.02 -0.022 -1007.18

0.01 -1.96 -1.92 ' -0.04 -0:053 -402.39 0.04 -1.99 -1.92 -0.07 -0.105 -298.45

0.1 -1.86 -1.92 0.06 -0.086 -58.76 0.4 -1.65 -1.92 0.27, -0.096
. -26.22 2.6 0.55 -1.92 ' 2.47 -0.101 -3.91

7 5.06 -1.92 6.98 0.000 0.00 57 54.9 ' -1.92 56.82 -0.180 -0.32 157 154.74 -1.92 156.66 -0.340 -0.22 457 454.9 -1.92 456.82 -0:180 -0.04 357 355 -1.92 356.92 -0.080 -0.02 157 154.9 -1.92 156.82 -0.180 -0.11

57 55 -1.92 56.92 '0.080 -0.14

7 5 -1.92 6.92 -0.060 -0.86 2.6 0.5 -1.92 2.42 -0.15 -5.86 'Calibration check using certified.weights. bAudit using certified weights.

4-21 Rev. 1. j 

# .**~.** JY/Y/YA 

# -.1-- Baseline EmissionTesting 4.7.3 Flow Measurement
The.results ofthe flow rate audits were reported in the draft audit report. Comparison ofthe audit results to the measurements made for the test runs ofthe same days indicate goodagreeJIlentfor velocities and flow rates measured using Method 2 (Table 4-13). The preliminaryvelocity measurement by hot wire anemometer made by the auditor on April 14 indicated a greater velocity than calculatedfrom pitottube measurements. The differences are attributed to the hot wire anemometer velocity being apointmeasurement comparedwith an averagevelocity n;s1,1lting from the pitott.ube measurements and the presence ofhydrocarbon in the stream, which can cause hotwire anemometer velocityreadings greater than actual velocities. 

### Table 4-13 Results ofFlow Rate Audit
l4-A r
l5-A r Audit-hotwire**NMMA~5-2** NMMA-2-2 Audit- itot 

### NMMA-16-1 NMMA-15-l 3071 3053 

### 3157 3297 

### 3168 4.7.4 Styrene Evaporation Test
In accordance with the QAPP, styrene evaporation tests (the towel



### . . tests) were conducted to evaluate the capture and recovery ofstyrene by the sampling system. Two tests were completed, one atthe initiation ofthe testing·
. program and one at the conclusion ofthe program. Inboth cases. the recovered quantity ofstyrene metthe acceptance criteria for agood system (±!O percent) (Table 4-14).
4-22 Rev. 1Date Baseline Emission Testing 

### Table 4-14 Results ofStyrene Evaporation Tests
4/1/97 Material Losses (g) Temperature (OF) Flow rate (acfm) Average THC Concentration (ppriw) Duration (min) Measured Emissions (g) Percent Difference' 

### , . 1199 65.6
. 3017 117.8

66 1202 0.21 1095 66 3306 116.7.

59 1165 6.4 The fIrst test represents**th~** bestmeasure ofthe system and its operation because no testinghad been conducted in the building and, therefore, no background styrene inbuilding air or booth airinterfered with the results. The results from the fIrst test showed excellent agreement betweenthe measured quantity ofstyrene evaporated 

### from the apparatus (provided by RTI) and the emissions determined

### by~easuring stackgas concentrations and flow rate. The closure betweenthese two measurements is not as close for the fInal test. however. Although it is true thatthe flow rate through the enclosUre was greater during the second test. the greater emissions measured**ar~'attributed** more to the mold left in the enclosure afterprevious lamination testing. Although the measured styrene concentrations were adjusted for the concentration in the incoming air and attempts were made to account forthe background concentration in the enclosure. it is likely that some ofthe styrene included in the measured emissions may have been generatedby the mold and partleft in the enclosure (Le
.. residual curing emissions).

4-23 Rev. 1AJl'CgJC1'l'-JeJ'-JU4**~tack** Test

EPA Posts Boat builder MACT Floor Summary Tables on its Website Point value system approach also posted The results of the comprehensive surveys that EPA sent out to boat builders in November 1997 have been posted on the EPA's boat builder MAa(Maximum Achievable Control Technology) website. These spreadsheets identify twelve HAP (hazardous air pollutant) emitting boat building processes. By calculating the median of the top twelve percent for each of these processes, the draft MAG floor for existing sources can be identified. The facility ranked first on the spreadsheet is the draft MACT for new sources. The spreadsheets can be found on the EPA's website at www.epa.gov/ttn/uatw/coat/boatlboatman.html In addition to several other background documents, EPA has also posted the-draft MACT Model Point Value Tables, When finalized these tables will allow boat builders to use different combinations of emission reduction technology to achieve the standard. The tables can be found on the NMMA website at nmma.org/environmental/resources/home.html. NMMA is in the process of reviewing EPA's floor determinations and pooling our resources to represent the industry's position regarding these floors. These recent developments will be the focus of the upcoming Clean Air Task Force meeting at IMTEC and the topic of the upcoming NMMA seminar titled, "A Morning of MACT" to be held on October 15th at the Tampa Bay Boat Show. If you want information or registration material regarding -the seminar contact John McKnight in the Washington office or you can access background and registration information at the NMMA Environmental website. Point Values Summary 

## I EPA MACT Model Point Values1 

# I II Manual Resin Application 

## II Mechanical Resin Application**~I** (Hand Lay-Up/Bucket & Tool 

## II 

## II

HAP.· Application) Atomized Application Non-Atomized Application Icontentll Non-Vapor

## II Vapor 

## II Vacuum 

## II Non-Vapor

## II Vapor 

## II Vacuum 

## II Non-Vapor

## II 'Vapor 

## II Vacuu

## (~~.~y**I!suppressedllsuppressed21lBa~ging31lsuppressedllsuppressed21lBagging311suppr~ssedllsuppres5ed21 IBaggin**  I 26.0 43 28 

## II 24 

## II 74 

## II 48 

## II 41 

## II 43 

### I 28 

## II 24 

## I 27.0 47 31 

## II 26 

## II 81 

## II 53 

## II 45 

## II 47 31 

## II 26 I 28.0 51 33 

## II 28 

## II 89 

## II 58 

## II 49 

## II 51 33 

## II 28 I 29.0 55 36 

## II 30 

## II 98 

## II 64 

## II 54 

## II 55 36 

## II 30 

## I 30.0 

## II 60 39 

## II 33 

### II 107 

## II 70 

## II 59 

## II 60 39 

## II 33 I 31.0 

## II 64 42 

## II 35 

## II 117 

## II 76 

## II 64 

## II 64 42 

## II 35 I 32.0 

## II 69 

## II 45 

### II 38 

## II 127 

## II 82 

## II 70 

## II 69 45 

## II 38 I 33.0 

## II 74 48 

## II 41 

## II 137 

## I 89 76 

## II 74 48 

## II 41 

## I 34.0 

### I 79 52 

## II 44 

### II 149 97 82 

## II 79 52' 

## II 44

### =~85§==:**==5§5~= i=~47:==11=~16§0=**  104 88

### '1~=",8=,=5**===,,55~=11=4~7= =~90§==:** **==5~9:== i==§50~11=~17~3=**  112 95 

## II 90 59

### 11=5~0=

### =:,:96,::==:=~62~=i==§53~11=~18§5= 121 102 

## II 96 1==6=2=11=5§3=

### =~10~2~==§66§==i==§56~11=~19~9=**=~12§9=11** 109

### 1Ii====.lo~2==11 66

### 1I=5~6= _.=..:10:.::..8----J

__ 7",0,--_ ,----=-=59,--11 213 138 

## II 117
. 11,--..=:10,-,,-8------.J11_---'-'70'--_11--c5::.::9_ 

## I 350 I 36.0 I 37.0 I 38.0 I 39.0 10-10-2000