Appendix \

4

Baseline Characterization of Emissions

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 K Street, 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 1997
Baseline Emission Testing

Table of Contents

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 of the Report 1-10

2.0. RESULTS 2-1

2.1. Summary ofResults 2-1

2.2 Evaluation of Emissions from Con:inuing Trace Concentrations 2~6

2.3 CFAMold Results ,~ 2c10

2.4 Results of Gelcoat Application Tesdng : : 2-13

2.5 Results of Resin Lamination Testing ,..: 2-16

2.5.1 Emissions as Percent of Available Styrene 2-17

2.5.2 Flux Emissions 2-20

2.5.3 Normalized Emissions 2-21

3.0 CALIBRATION AND SAMPLING PROCEDURES : : 3-1

3.1 Process Procedures and Measlirerr.ems : 3-2

3.1.1 Application Procedures : 3-3

3.1.2 Spray EqUipment 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

Research Triangle Park. North Carolina 27709

August 1997
Baseline Emission Testing

Table of Contents

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 Test Enclosure 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 of the Report 1-1 0

2.0. RESULTS : 2-1

2.1 Summary ofResults , 2-1

2.2 Evaluation of Emissions from Continuing Trace Concentrations 2-6

2.3 CFAMold Results ,: 2-10

2.4 Results of Gelcoat Application Testing 2-13

2.5 Results of Resin Lamination Testing : 2-16

2.5.1 Emissions as Percent of Available Styrene 2-17

2.5.2 Flux Emissions 2-20

2.5.3 Normalized Emissions 2-21

3.0 CALIBRATION AND SAMPLING PROCEDURES 3-1

3.1 Process Procedures and Measurements : 3-2

3.1.1 Application Procedures : 3-3

3.1.2 Spray Equipment Calibration : 3-4

3.1.3 Gel Time 3-5

3.1.4 Styrene and Methyl Methacrylate Content ::.3-6

3.2 Emission Testing E.quipment and Procedures 3-7

iii D"., 1
Baseline Emission Testing

Table of Contents (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 of Material 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 Concentration Measurements 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 of Methods in Determining.Emissions .4:12

4.2 Gelcoat and Resin Flow Rate ;, 4-14

4.3 Air Velocity over Mold Surface ;, 4-15

4.4 Exhaust Flow Rate 4-15

4.5 Exhaust Air Temperature 4-17

4.6 Resin/Gelcoat Balance 4-17

4.7 Technical Systems Audit : 4-18

4.7.1 Total 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. 1
APPENDICES

APPENDIX A

APPENDIXB

APPENDIXC

APPENDIXD

APPENDIXE

APPENDIXF

APPENDIXG

APPENDIXH

APPENDIX I

BaseEr.e Emission Testing

Table of Contents (Continued)

,

,

,

,

Reference Methods

Construction of a Temporary Total Enclosure for Volatile Organic

Compound Emission Assessment During Manufacture of Fiberglass

Boats

Calculations

Procedure for and Results of Gel Time Determination

Material Safety Data Sheets·

Certifications for Gas Standards and Equipment Calibrations

Bag Standards

:Location and Results of Air Flow Over the Mold Measurements

Comparison of NMMA Results with Those from Other 5LUdies

v R"v. 1
Baseline Emission Testing

Table of Contents (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 of Material 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 Concentration Measurements .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 of Methods in Determining Emissions ,.. .4~12

4.2 Gelcoat and Resin Flow Rate : .4-14

4.3 Air Velocity over Mold Surface " : .4-15

4.4 Exhaust Flow Rate 4-15

4.5 Exhaust Air Temperature , 4-17

4.6 Resin/Gelcoat Balance 4-17

4.7 Technical Systems Audit : : 4-18

4.7.1 Total 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. 1
APPENDICES

APPENDIX A

APPENDIXB

APPENDIXC

APPENDIXD

APPENDIXE

APPENDIXF

APPENDIXG

APPENDIXH

APPENDIX I

Baseline Emission Testing

Table of Contents (Continued)

,

,

Reference Methods

Construction of a Temporary Total Enclosure for Volatile Organic

Compound Emission Assessment During Manufacture of Fiberglass

Boats

Calculations

Procedure for and Results of Gel Time Determination

Material Safety Data Sheets· .

Certifications for Gas Standards and Equipment Calibrations

Bag Standards

'"Loc.ation and Results of Air Flow Over the.Mold Measurements

Comparison of N'tvHvIA Results with Those from Other Studies

v Rev. J
Baseline Emission Testing

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 of Molds Used in Test Program l~9

Properties of Gelcoat and Resin Materials 1-10

Test Schedule 1-11

Summary of Test Results , :..,..2-2

Emissions Measured During Application of Resin to CFA Mold 2c11

-

Emissions from Gelcoating as Percentage of Available Volatiles 2-14

Total Emissionsfrom Getcoating Related to Mold Surface Area 2-15

Emissions Measured During Resin Lamination : 2-17

MeasurementsDuring Test Program , 3-1

Gel Time Results : 3-6

Styrene and MMA Contents : : 3-6 .

Acceptance Criteria for Concentration Measurements .4-2

Calibration Error Measurements for Total Hydrocarbon Analyzer : 4-3

Calibration Drift Measurements for Total Hydrocarbon Analyzer. 4-4

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

Method 18 Response Factors for Target Compounds ·..: .4-7

Gas Chromatography Calibrations (after April12) .4-10

Comparison of Emission Results by Two Methods :.:..: 4-12

"i Rev. 1
Baseline 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 of Balance Calibration 4-18

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

4-12 Results of Audit of Balance : .4-21

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

4-14 Results of Styrene Evaporation Tests : .4-23

vii p""" T
Baseline Emission Testing

LIST OF TABLES

Page

" 1-1 Parameters Studied ' 1-8

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

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

1-4 Test Schedule 1-11

2-1 Summary ofTest Results ,.. 2-2

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

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

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

2-5 Emissions Measured During Resin Lamination :.: 2-17

3-1 Measurements. During Test Program : , 3-1

3-2 Gel Time Results : 3-6

3-3 Styrene and MMA Contents : : 3-6

4-1 Acceptance Criteria for Concentration Measurements 4-2

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

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

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

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

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

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

vi Rev. 1
Baseline 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 of Balance Calibration "."." ".. """ " .. " ".. ".. '"" " "."" 4-18

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

4-12 Results of Audit ofBalance ""...."."" ... """ """" ... ".. ".".""".. "",," ..".."...,,," ".... 4-21

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

4-14 Results of Styrene Evaporation Tests .."".:.."""".""""" .. "".. """"".:"."".""... ".. 4-23

vii
LIST OF FIGURES

(

Baseline Emission Testing

Page

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

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

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

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

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

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

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

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

2-9 Comparison of Results by Test.. 2-19

2-10 Emissions from Besin Lamination as Flux Measurement... 2-20

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

2-12 Normalized Emissions from Resin Lamination : 2-22

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

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

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

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

viii Rev. 1
:.. Baseline Emission Testina . 0

ACKNOWLEDGEMENTS

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

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

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

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

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

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

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

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

for a test enclosure of its size;

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

lamination work during this program;

Ken Warren, U.S. Marine gelcoating specialist, who conducted all 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 the U.S. Environmental

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

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

systems.

Finally. we wish to thank]ohn McKnight, the NMMA Project Manager. for his continued

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

ix Rev. I
Baseline Emission Testing

LIST OF FIGURES

Page

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

2-2 Emi~sions as Percentage of Available 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 of the CFA Mold ~.:.2-12

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

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

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

2-9 Comparison of Results by Test.. : .- 2-19

2-10 Emissions from Resin Lamination as Flux Measurement... 2-20 .J".

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

2-12 Normalized Emissions from Resin Lamination : 2-22

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

4-2 Method 18 Re~ponse Factors for Methyl Methacrylate : 4-7

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

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

viii Rev.l
Baseline Emission Testina . . 0

ACKNOVVLEDGEMENTS

The authors gratefully acknowledge U.S. r-Iarine for the use of their 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 their personnel. '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 of the temporary rotal enclosure, \vhich exceeded all expectations

for a test enclosure of its 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 that the program had

everything needed.

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

Protection Agency for funding the supplemental testing offlo\V chopper technology. We

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

systems.

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

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

\

Ix Rev. 1
1.0 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 of fiberglass boats, Testing was conducted in

accordance with the.Quality Assurance Project Plan For the National Marine

ManuFacturers Association Baseline Emissions Testing Project (QAPP) approved by

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

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

state regulatory authorities and other interested parties were also made during

testing.

The test program was designed to be as representative as possible

of actual fiberglass boat manufacturing. Testing was conducted at the

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

developmentfacility in Arlington, Washington, in an eJ).closure (inside a wooden . - ,

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 laminating procedures and

techniques typical of the industry. Experienced manufacturing personnel.

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

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

produce data for comparison with previous emission tests.

During this sampling program, Research Triangle Institute (RTI)

conducted a research program to ascertain the Viability of measuring emissions

1 1
Baseline Emission Testing

from lamination and gekoating operations using a mass balance approach, RTI's

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

and will be reported independently,

1.1 Background

,

(,

Within the past two years, several important sampling and analysis

programs have sought to 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 of large parts manufactured by

the marine industry.

Still, none of the tests to date adequately represent industry

practice or conclusively demonstrate the effeer of mold size and styrene content . - :..

6f resin on emissions, For'example, the results of this test program indicate that

the relationship between emissions ofstyTene as percerit"of available styrene in

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

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

square foot ofsurface area ofmold) but decreased normalized emissions

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

none of the previous tests included gelcoar containing methyl methacrylate

(MMA) , which is common in 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 of fiberglass boats. Testing was conducted in

accordance with the Quality Assurance Project Plan for the National Marine

Manufacturers Association Baseline Emissions 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 program was designed to be as representative as possible

of actual fiberglass boat manufacturing. Testing was conducted at the

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

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 program were 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 of the indusrry. Experienced manufacturing personnel

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

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

produce data for comparison \\ith previous emission tests.

During this sampling program. Research Triangle Institute (RTI) .

conducted a research program w ascertain the viability of measuring emissions

'-1 Rev.l
Baseline Emission Testing

from lamination and gelcoating operations using a mass balance approach. RTI's

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

and will be reported independently.·

1.1 Background

,

,.

Within the past two years, several important sampling and analysis

programs have sought to determine styrene emissions from open molding of

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

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

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

questions about the emission factors published in the EPA's compendium of , - emission factors, AP-42, especially for molding oflarge parts manufactured by

the marine industry.

StilI, none of the tests to date adequately repreSent industry

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

6f resin on emISsions. For example, the results of this test p;ogram indicate that

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

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

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

square foot ofsurface area of mold) but decreased normalized emissions.

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

none of the previous tests included gelcoat containing methyl methacrylate

(MMA), which is common in the boat b~ilding industry.

1-2
_____-AT

.NMMA

~.#JfII".6' Baseline _ Emission Testino0

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

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

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

difference between this technique and conventional spray up application is that

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

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

supplemental sampling was funded by the EPA through RTI.

This.,;tudy was designed to produce data fOF estimating emissions

from lamination ana gelcoating in fiberglass boat manufacturing plants. The

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

in compiling emission inventories and assessing permit needs or changes.

1.3 Testing

Sampling was completed by Darrell Doerle of Air-Tech

Environmental and John Stelling of Stelling Engineering. Testing was

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

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

Rp,\1 1
Baseline Emission Testing

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

experiments.

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

Mark Bahner of RTI. 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

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

determining emissions from fiberglass lamination.

.1.3.1 Test Enclosure

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

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

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

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

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

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

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

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

A description of the 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 air velocity across the mold surface was

comparable to that measured in the manufacturing ar:e'a.

The exhaust system for the entire model preparation room

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

enclosures) exhausting to a single induced draft fan. The fan had 20,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 of fiberglass boat manufacturing, specifically spray up gelcoat

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

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

this study. A technique comparable to hand lay-up found in the industry is the

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

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

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

difference between this technique and conventional spray up application is that

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

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

supplemental sampling was funded by the EPA through RTI.

This study was designed to produce data for 'estimating emissions - . .~. .

from lamination 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 of Air-Tech

Environmental and John Stelling of Stelling Engineering. Testing was

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

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

1-'l Rev.!
Bas=Hne Emission Tesdng

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

experiments.

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

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

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

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

of their program 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 of EPA 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 enclosure to allow technicians to ..

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

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

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

.were made'to enslfre that the air velocity across the mold surface was

comparable to that measured in the manufacturing area.

The exhaust system for the entire model preparation room

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

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

1-4 Rev.]
Baseline Emission Testing

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

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

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

the turnover through the large enclosure 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 spun fiberglass filter media. Air was supplied to the enclosure

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

on both ends. limiting the NDO associated with the inlet air 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 of the inlet air plenum were the only.

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

a TIE. representing only 0.043 percent of the total surface area of the enclosure. - - .~

Also. considering a'flow rate of 2.600 to 3.300 dm, the velocity at the NDO was

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

the enclosure was monitored continuously for hydrocarbon concentration during

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

other continuous monitoring data,

1.3.2 Process

.The polyester resin spray-up application process commonly useG

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

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

1-5 Rev.!
Baseline Emission Testing

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

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

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

fan pattern a short distance from the sprayfun. The mixture of the 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 of this

reinforcement. A Venus Gusmer G03 low-pressure slave arm internal mix

airless chopper gun equipped with a 5003 tip, typical of guns used in the

industry, was used for spray application ofresin and chopped glass during this

program.

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

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

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

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

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

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

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

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

of glass and resin mixture is more narrow.

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

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

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

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

Poly-Craft 755 airless air-assisted spray gun (eqUipped with a 0.026 tip size) was

used during this program.
Baseline Emission Testing

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

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

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

the turnover through the large enclosure u~ed for NMMA testing was

comparable to that in the manufacturing ar'eas 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 spun fiberglass filter media. Air was supplied to the enclosur~

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

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

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

and a zippered end for changing application equipment and molds between

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

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

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

Also, considering a 'flow rate of 2,600 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

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

other continuous monitoring data.

. 1.3.2 Process

.The polyester resin spray-up application process commonly used

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

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

Rev.l
Baseline Emission Testing

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

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

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

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

resin and choppec;l fiber is deposited on the'mold by the spraying action. Typical

of fiberglass boat manUfacture, woven roving (a fabric material) was used With

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

reinforcement. A Venus Gusmer G0310w-pressure slave arm internal mix

airless chopper gun equipped with a 5003 tip. typical of guns used in the

industry, was used for spray application of resin and chopped glass during this

program.

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

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

peroxide (MEKP)/dimethyl phtiJalate (DivIP) catalyst was internally mixed for

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

system. The flovy chQpper was also a Venus Gusme! deSign. The resin is

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

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

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

of glass and resin mixture is more narrow.

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

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

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

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

Poly-Craft 755 airless air-assisted spray gun (eqUipped with a 0.026 tip size) was

used during this program.

l-h
Baseline Emission Testing

Spray application was conducted using techniques common to the

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

skilled technicians from a manufacturing 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 of THC, was used as the

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

emissions were calculated using the measured THC concentration as:propane,

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

accordance with Method 2. These results are presented in terms 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 establish the ratio ofstyrene emissions to MMA emissions during

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

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

check on the Method 25A results.

Other measurements made during this program included those'

variables determined from other studies to have more significant influence on

emissions (Tab!e 1-1).

1 7
1.3.4 Molds

Baseline Em;ss:on Testing

Four molds were used in this'Program, three of which 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 mold for a bow 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 to provide data for comparison with the results of that pre.ious

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

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

emissions.

Table 1-1

Parameters Studied

"',".. ,::.;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 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 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 measured THC concentration as.propane, .

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

accordance with Method 2. These results are presented in terms ofTHC

emissions (as propane) for lamination or gelcoating.

Speciation ofstyrene and l\EvlA emissions (r:eeded during

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

(GC) with flame ionization detector (FID).l'v1erhod 18.analysis was conducted

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

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

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

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

check on the Method 25A results.

Other measurements made during this program included those·

variables determined from other studies to have more significant influence on

emissions (Table 1-1).

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

IVHHA .JIJ1''''''- Baseline Emission Testing

1.3.4 Molds

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

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

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

18-ft deck moldJor a 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 of that previous

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

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

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

Air flow rate No Measured

'These parameters apply to reSIn and gelcoat.

1 Q
Baseline Emission Testing

Table 1-2

Surface Area of Molds Used in Test Program

Mold . Surface Area (ft2)

18-ft Deck 171.09

18-ft Hull , 220.5

28-ft Hull 454

CFA Phase I Mold (controlled spray) 28.06

CFA Phase I Mold (uncontrolled spray) 37.28'

'Uncontrolled spray of thiS mold mevltably coated flange extenslOns, effectively increasing the

surface area of the final laminate structure.

1.3.5 Materials

Materials chosen for this program are rypical of those used in

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

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

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

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

formulations used are considered most representative of the range of resin

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

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 catalyst used in the indusrry for both ge1coat and resin;

MEKP/DMP was used in this program.

1-9 Rev.l
Baseline Emission Testing

Table 1-2

Surface Area ofMolds Used in Test Program

--

- - Mold Surface Area (ftz)

18-ft Deck 171.09

18-ft Hull ,

.- 220.5

28-ft Hull , 454

CFA Phase I Mold (controlled spray) 28.06

CFA Phase I Mold (uncontrolled spray) 37.28"

"Uncontrolled spray of thIS mold inevitably coated flange extensions, effectively increasing the

surface area of the final laminate structure.

1.3.5 Materials

Materials chosen for this program are typical of those used in

fiberglass boat manufacturing (Table 1-3). 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 by weight content. The gelcoat was a white on

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

formulations used are considered most representative of the range of resin

styrene and ge!;coat contents in the industry. Based on a s~rvey of industry

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

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

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

MEKPIDMP was used in this program.

1-9 Rev.l
Baseline Emission Testing

Table 1-3

Properties of Gelcoat and Resin Materials

c

Gelcoat Resiin 1 Resi.n 2

Product number 954WP53 80.654-NMMA 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 RVF #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% 1.5% 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 2 to 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 adjacent Method 204 enclosure.

1.4 Organization of the Report

The complete report including all appendices and separately

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

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

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

1-10
Baseline Emissfon Testing

Table 1-2

Surface Area of Molds Used in Test Program

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

. surface area of the final laminate structure.

Mold , Surface Area (ft2)

18-ft Deck 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 of those used in

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

used, one with a nominal 35 percent styrene, by weight 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 of L'1e range of resin

styrene and gekoat. contents in the industry. Based on 2. s).!!"Vey of industry

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;

MEKPIDMP was used in this program.

1-9 Rev.l
Baseline Emission Testing

Table 1-3

Properties of Gelcoat 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 2 to 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 of the Report

The complete report including all appendices and separately

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

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

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

l-lD Rpv 1
Table 1-4

Test Schedule

Baseline Emission Testing

Date Test Description Run .

2-Apr NMMA-o-P 18-ft, Deck Ge1coat 0402-01

3-Apr NMMA-8-1 28-J't Hull 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-ft Hull 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-ft Deck 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-ft Deck 35 % Styrene Resin - Flow Chopper -0410-01

lO-Apr NMMA-13-1 18-ft Hull 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-ft 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-ft Hull 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-ft Deck 42 %Styrene Resin 0412-02

12-Apr -NMMA-2-1 18-ft Hull 42 %Styrene Re~in 9412-03

14-Apr NMMA-5-2 18-ft Deck 42 % Styrene Resin 0414-01

14-Apr NMMA-2-2 18-ft Hull 42 %Styrene Resin 0414-02

IS-Apr NMMA-16-1 18-ft Deck 42 % Styrene Resin"Flow Chopper 0415-01-

IS-Apr NMMA-15-1 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 % 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

1-11
Baseline Emission Testing

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

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

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

Section 3 describes the methods used in 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 of a Temporary Total Enclosure for Volatile Organic Compound

Emission Assessment During Manufacture of Fiberglass Boats

• Calculations

• Procedure for and Results of Gel Time Determination

• Material Safety Data Sheets . . • Certifications fOf Gas Standards and EqUipment Calibrations

• Bag Standards

• Location and Results of Air Flow over the Mold Measurements

• Comparison of NMMA Results with Those from Other Studies

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

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

bound separately for archive at 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-0 I

3-Apr NMMA-8-1 28-ft Hull Gelcoat 0403-01

3-Apr NMMA-4-1 1S-ft DecR 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 .

NMMA-8-2 28-ft Hull Gelcoat 0405-01

S-Apr NMMA-1-1 IS-IT Hull 35 % Styrene Resin 0405-02

7-Apr " NMMA-7-2 28-ft Hu1l35% Styrene Resin 0407-0 I

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-ft Deck 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-ft Hull 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-ft Hull 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-ft Hull 42 % StyTene Resin 0414-02

IS-Apr NMMA-16-1 18-ft Deck 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-ft Hull 42 % Sryrene Resin 041S-01

18-Apr NMMA-12-2 CFA ~[old 42 % Styrene Resin 0418-02

19-Apr NMMA-9-Z 28-ft Hull 42 % Styrene Resin 0419-01

1-11 Rev.!
Baseline Emission Testing

introduction to the purpose of the 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 of a Tempor","")' Total Enclosure for Volatile Organic Compound

Emission Assessment Duri'1g Manufacture of Fiberglass Boats

• Calculations

• Procedure for and,Results of Gel Time Determination

• Material Safety Data Shee:s

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

• Bag Standards

• Location and Results ofAir Flow over the Mold Measurements

• Comparison of NMMA Res:rlts with Those from Other Studies

Copies of ali 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 of emission testing at the U.S. Marine site in Arlington,

.vVashington, are presented in this section with comparison of the data betvve~n ,

, tests and with the results ofthe CFA Phase Jstudies; further comparison of these

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

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

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

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

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

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

Results demonstrate that the enclosure constructed at the site

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

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

demonstrated that the emission monitoring system provided a good measure of

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

Phase I CFA studies demonstrated that the techniques used In the two studies ,

(Le.. CFA's study and the portion of this study designed to reproduce some of

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

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

in the QAPP. In accordance with the plans outlined in the QAPP. all testsof boat ""

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

the test conditions to incorporate the CFA study mold.

2.1 Summary of Results

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

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

?_l Rev. 1
Baseline Emission Testing

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

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

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

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

representative of industry practice. ,

,

,

,

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

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

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

Table 2-1

Summary 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 Deck 42R 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 Deck 42R-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. 1
Baseline Emission Testing

Figure 2-1

Summary Concentration Traces for Boat Lamination and Gelcoating

2-1Ia]- Spray v. Flow Chopper: 18 Hul~ and Deck - 35% Styrene Resin

:

"7 ~;. ... -:;;:]f'r: :"t! - 't .1' '"" - - "%"~ ~!~ ~'... 1 ' ... '....

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

:-. '- '. . '.

,. ,~'..

~... :.

0:28 0:57

.'1_-

.--.

300

0;-

" 250 "

'"

0

i5.

:: 200

"

'"-=" 150

.8

;:;

"

§ 100

0;

u 50 u

Elapsed Time 1------ 35R -35RFC I

2-1[b]- Sprayv. Flow Chopper: 18 Hull and Deck - 42% Styrene Resin

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

.. 300 -1-'-'---+._-+-----+-+--"=--1__-=-'-----+---+---+----1 '.. If250 +-:----=---l---~-.C-l-~__~,;_~,--'....-.--+1----+----+----1 - ,.;.. ~, - oF "'l" ,~_

200 -l-:.'-1-*-~~:..L~.----;'-..J,..'-.Jij~'=..l''-''--~-+--+---+-------1

: ~'f.. i.11 ......... - 150 +.;...4:-----.:l~~~=_i_+_--~~o_---i:.-1__---l---__j---__j

100 +.;:

I ~7L-f'oi:L::'~~~;ri"'---ll---l-~''!!''..;;,~-~..:.---+--_---I-_~ .

50 -....... 1

o~.~-l_---L~---l---1-~~~~......,..,==-- 0:00

500 ~~---;--~----"Js.----'---'-I ---,----------,---,

450 +----+_--~,-~,"'~...,.:_----+------+----+---+---

!". •

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

.

g 350 -h."!:..' '-~' .,;,:_.~',-I---...;,...I---...;~-_I_---_+_---_+---_+---- -

S

'"-="

e

"

8

§

u

u

Elapsed Time 1--'--- 42R ---42R FC I

2-3 Rev. I
Baseline Em'ssion Testing

2-1[e]- Spray: 28 Hull- Both Resins

700

I I I 600

"" I 0

B r 500 ,

Co • L

I ,. .~ . " ;.,.~ r j~-f~ ... !: 400 ..' ri'; t I

~l § • w ,. I ... I

'" "

300 .... I'----,

" · I ~, = ,. 0 .• I. [ u

u

"

0

200 " l'· ".......

' ';. :h~ u · • .,. ... j .. . ~= ".

~I \:\. :I: '\ \....d l- f-< I- \. ~. 100 ... ~~ , - --~ ~~~ . • I

I..

0

0:00 1: 12 2:24 3:36 4:48 6:00 7:12

Elapsed Time 1- - ~- - -35R 42R I

2-1[d] - Geleoating

900

800

<1\.,. ""

0 700 ,1ft g.

,.c.. 600 iJ!l Qo I a

§ 500 l.

" IA:~ .~

;; 400 'iI - i c

0

u 300 § +- -,,"\ '"' I u

u 200 ) ... 'f~ ;:; #' I ~~ ,

100

I W- "'-1.---

I 0

0:00 0:28 0:57 1:26 1:55 2:24 2:52

Elapsed Time

1- --- --18 Deck Cel 18 Hull Cel A 28 Hull Cell

-

2-4 Rev. 1
Baseline Emission Testing

concentration profiles for the testing conducted during the April 1997

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

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

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

For example, the data from sampling the exhaust during

lamination of the 18-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 peak concentrations using the two resins were

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

broader peaks, corresponding to greater mass emission rates.

The summary illustration of the gelcoat data show~. the effect of

geometry on the concentrations measured. The greater THC concentrations in

the exhaust noted during lamination of the 28-ft mold are likely the result 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 a longer period of time, resulting in greater volatilization and emissions of

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

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

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

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

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

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

reducing the amount of gelcoat atomized.

2-5 Rev. I
Baseline Emission Testing

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

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

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

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

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

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

results reported herein.

All the data related to emissions from boat gelcoating and

lamination derived from this NMMA testing program are summarized in

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

percent of available monomer. As the results clearly indicate, emissionsfrom

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

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

lamination emission testing.

2.2 Evaluation of Emissions from Continuing Trace Concentrations

The QAPP included the evaluation of a cutoff concentration in the

exhaust stream that would allow cessation of sampling before the concentration

ofTHC in the enclosure exhaust reached the background concentration,

prOVided at least 95 percent of total emissions were characterized before

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

assessment determined that 95 percent of total emissions from lamination and

gelcoat operations would be characterized by the time the exhaust concentration

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

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

day.

2-6 Rev. I
Baseline Emission Testing

Figure 2-2

Emissions as Percentage of Available Monomer

Emissions as Perc-ent of Available Monomer for Boat Tests

60%

..,.

• 50% E

0

c

0

E 40%

•

:c

'" 30%

••>ro

"0 20%

•

c 10"/0 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 L ~I = 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 7 ppmv as propane. Because the background

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

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

0.2 percent of emissions.

The assessment ofthe concentration trace for NMMA-4-1

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

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

typical pattern of concentration peaks and valleys as resin is applied

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

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

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

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

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

2-7 Rev. 1
Baseline Emission Testing

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

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

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

resin is applied and the peak exotherrn of the 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 of the

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

the emissions associated with sampling completely to background levels from

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

worst case assessment (Le .. greatest emissions in the tail) because it assumes that

2-8 Rev. 1
Baseline 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 of emissions 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 of percem of available styrene, these results indicate greater

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

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

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

slight difference in averages and the difficulty in consistent resin weight

measurement.

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

emission measurements were not always comparable to the amount of resin

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

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

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

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

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

2-11 Rev. 1
Baseline Emission Testing

Figure 2-5·

Emissions from Lamination and Ge1coating of the CFA Mold

CFAM old - Emissions (% ~vailable)

, 90% , 80%

:0• 70%

" 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-

••

E 10% r- '- f-- l- f-- l- I-- l- i-- l- i- 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

8.0 l--~

•

0: 5.0 l-- ,g

0

0 4.0 1-- r-~ 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. 1
Baseline Emission Testing

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

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

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

variable than results from boat testing.

2.4 Results of Gelcoat Application Testing

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

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

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

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

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

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

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

Results for boat gelcoating are presented in terms of losses of

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 of this testing is the relative contribution to emissions

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

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

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

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

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

as unrepresentative because of variability ofthe GC response factors.

2-13 Rev. 1
Baseline Emission Testing

Figure 2-6

Gelcoat Emissions as Percent of Available 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 0<1) u 0 '5 S u 0_"=> • • I I I 0 0

:" :" :" :" :" "', '"

Table 2-3

Emissions from Gelcoating as Percentage of Available Volatiles

I

:;y,,':'~>, ;,f.~~:: ::,,' ",:~ ~." ."t'Percent of I, Percentof' " ':; Percent of,'

'., .' ::,~; .-~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-ft Hull 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 that was substantially less than all other measurements made

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

2·14
Baseline Emiss:D:l Testing

percent of available MMA. Excluding that one run (NMMA-5-l) provides an

average MMA loss of 75.5 percent of available MMA, a value that is very

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

styrene loss for this test was relatively unchanged as a result of excluding that , one run; likewise, the total volatile loss was relatively unchanged, owing to the

contribution of styrene losses to the total volatile loss.

Gelcoating results evaluated in terms of loss per unit mold surface

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

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

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

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

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

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

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

emission testing for resin lamination.

Table 2-4

Total Emissions from Gelcoating Related to Mold Surface Area

....... .'. qe1coat U~e .. Mold Area Emissions, .. ., Emissions· .. ; . (lb) ;, (ft2) .··'(lbtfti)<: '(lb/IOOO 1b1ft2)

18-ft Deck 20.0 171.09 0.0228 1.14

18-ft Hull 25.7 220.5 0.0251 1.03

28-ft Hull 55.7 454 0.0389 0.59

2-15 Rev. 1
Baseline 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

0.030

O.OH

0.020

0.015

0.010

O.OOS

0.000

'"

'" Oo~' "

(USlolj '" 00.' "

'" Oo~, "

G" l<ul1 "

'"

Hull "

'"

,.

Hull

G"

,.

Hull

G"

,.

..

,.

"

,..

...

2.5 Results ofResin Lamination Testing

Testing was conducted during lamination of three mold size and

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

the industry. Because the quantities of resin used for each test are much greater

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

(Table 2-5).

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

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

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

2-16 Rev. 1
Baseline 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 R FC 114.7 \11.9 0.0092 0.08

18 Deck 42 R 111.8 /21.1 0.0284 0.25

18 Deck 42 R FC 122.2 \1-3.4 0.0125 0.10

18 Hull 35 R 144.5 (14.8\ 0.0143 0.10

18 Hull 35 R FC 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 Percent of Available Styrene

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

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

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

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

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

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

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

emissions is greater for the higher styrene content resins.

The greatest emissions in terms of percent available styrene were

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

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

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

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

2-17 Rev. i
Baseline Emission Testing

Figure 2-8

Emissions from Lamination as Function of Available Styrene .

25'Y.

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

,

rH g 15% - - r- r- 1

I I • I

rl 0

'- - - - f- f- - - - '- - 10% - .r- r- - - r- rw

5" - - - r- r- r- - r- r-- - - - - r- r- r-Jr- rI 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

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

styrene.

The comparisons become clearer when the same data are revie\,ved

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

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

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

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

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

2-18 Rev. 1
Baseline Emission Testing

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

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

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

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

45 percent are noted: from about 12.9 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 of Re.sults by Test

25%

20%

"""•

E

0

c

0

E 15% ..,

.0

.E!

;;

>

I 10% I '0

'""-

M

C

0

-,;

M SOlo

E

w

0%

r--

r--~-

,...-

r-- -

-

- - - - e----- I---- - --..-: - -

- - r-- e--- - I---- I---- - - - . ••

0: " 0 UO

0:

'" u u. ";- ";- ~\ N N

'" •. ci: 0: 0: -5 ,. «

" ~I •., "

" '" M

'" .. -5

!2 N j! !2 « • 0 " !2 :l :l

2-19 Revo 1
NMMA

---- ~~-- Baseline Emission Testing

2.5.2 Flux Emissions

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

consistency of the runs made for testing and indicate 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-ft mold

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

deck (a bow rider design) has convex character.

Figure 2-10

Emissions from Resin Lamination as Flux Measurement

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- - - f- f- - f- .-

j . ! ! " • • . ! 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 that emissions from the 42 percent styrene resin are greater than the

2-20 Rev. 1
Baseline Emission Testing

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

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

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

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

Figure'2-11

Average Emission Flux Measurements for Two Resins

0.040

0.035

0.030

. u:- 0.025

0.020 c

o

.;;;

.-g 0.015

w

0.010

0.005

0.000

,

,

- -,--

-

- "

'-

. - ,- - - , - - - - - - - - - - f---- - - - - - - -

" ~I

~I " f.: "I on ':- '" ~I "'" " ":± ~i !l 0:

"0 " " ~I ., '" ,., ", on

0 ~, ;;;i M

~I "0 "0 = ~! -;; ., 0 0 -I

= . "

2.5.3 Normalized Emissions

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

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

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

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

Normalized emissions were about 80 percent greater from lamination with 42

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

using a flow chopper; normalized emissions decrease with increasing mold

2-21 Rev. 1
Baseline Emission Testing

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

corresponding spray up operation.

The differences between emissions generated using spray devices

and those generated using flow choppers'(fan be seen in Figure 2-1, which

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

two different styrene content resins and thesetwo application methods. The

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

utility of the 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

0.15 e0.10 l-~ f-- eQ.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 or twice over the

course of the 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 of the other measurements. The procedures are

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

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

Additional measurements (I.e., of air flow over the mold and styrene recovery)

and data handling are also addressed in this section.

Table 3-1

Measurements During Test Program

Measurement Designation Frequency

THC Concentration Method 25A Continuous

Styrene (MMA) "Conc.entration Method 18 ' ,Intermittent (6-15 min . intervals)

Wet Laminate Thickness Wet Mil Gauge Each Test Run

Wet Film Thickness Wet Mil Gauge Each Test Run

Styrene (MMA) Content Manufacturer's Method Per Batch Delivered

Gel Time U.S. Marine Method Per Batch Delivered

Resin Flow Rate Spray Gun'Calibration Pre/Post Test Daily

Air Flow Hot Wire Anemometer For Each Mold

Air Temperature Exhaust Gas Temperature ' Continuous

Exhaust Flow Rate Vent Stack Air Flow Rate One traverse set per test;

continuous point

measurement

Styrene Recovery Material Balance/Method 25A Pre/Post Program

Resin/Gelcoat Weight Precision Balance Pre/Post Test; continuous

measurement

Two test runs were made most test days; the number of tes~

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

3-1 Rev: 1
"Baseline EmissjOn Testing

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

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

were completed. The procedures implemented mDst test days include the

following:

• Morning spray equipment calibration;

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

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

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

the run, and temperature;

• Post-test quality control measurements (calibrations);

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

weight, and temperature);

• Post-test quality control measurements; and

• Evening spray gun flow rate calibration. "

Additional tests conducted include measuring the rate of air flow

over the mold and mass balance styrene recovery checks (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 or resin/glass in the manufacturing

operation. Resins and gelcoat selected for this program had characteristics

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

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

gelcoating and lamination during this prograr:n. Additional personnel assisted

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

3-2 Rev. 1
/YMMA

---- ..,..,..,.., Baseline Emission Testing

3.1.1 Application Procedures

After the morning calibrations were completed. monitoring of air

flow was established. materials to be applied were weighed, and lam.ination (by

spray up or flow chopper) or gelcoating o~ a part in the TIE commenced. Skilled

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

operators measured laminate and gelcoat thickness periodically as the material

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

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

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

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

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

procedures.

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

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

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

application equipment to the keel ofthe hull. When gelcoating, a fog coat was . applied first to one side of the mold and then a thicker layer was applied to

bring the coat~ng to a nominal thickness of 20 mils. Using typical gelcoating .

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

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

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

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

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

technique. These portions were typically inaccessible with thi" spray equipment.

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

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

3-3 Rev.!
Baseline Emission Testing

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

almost entirely before applying additionallayers of the laminate. Additional

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

roving. The chopped glass was rolled out at every layer. The laminate

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

thicknesses used inprevious studies. For example. a laminate thickness of .

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

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

for the sides and transom ofthe same hull (including one roving). A O.OlO-in.

thickness gauge was used to make the measurements.

·3.1.2 Spray Equipment Calibration

The spray gun resin or gelcoatflow rate was determined at the

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

before the first test and after the last test. The spray equipment fiow 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 a pre-weighed container for 15 seconds,

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

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

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

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

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

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

result.

3-4 Rev. 1
Baseline Emission Testing

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

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

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

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

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

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

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

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

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

. , catalyst ratio is 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 each batch of resin used

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

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

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

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

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

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

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

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

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

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

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

3-5 Rev. 1
Baseline Emission Testing

Table 3-2.

Gel Time Results

Gel time to 150°F 6:05 5:06 3:09

367

5:04

27:08

Gel time 16:38

Gel time to 150°F

Peak Tern erature (OF)

Time to Peak Tern erature

Time to Peak Tern erature 33:57 26:18 22:11

3.1.4 Styrene and Methyl Methacrylate Content

•

Styrene and MMA content ofthe resins and gelcoat used during

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

the resin and Cook Compo~ites and Polymers for the gelcoat. Industry

procedures were followed and certifications 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 duct through

Teflon® sample tubing at ambienttemperature using a sample pump. This

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

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

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

a Dianachart data logger. GC data were collected separately.

The following data were collected continuously:

• TTE outletTHC concentration,

• TIE inlet THC concentration,

• Velocity pressure head in the exhaust duct,

• Temperature of the exhaust stream, and

• Weight of the gelcoat or resin used.

3.2.1 Leak Check and Instrument Calibration

Leak checks and bias checks were incorporated into the calibration

and response factor procedures, respectively. Calibration gases were introduced

at the probe inlet, and calibration responses were obtained using the sa..TIle

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

3-7 Rev. 1
Baseline Emission Testing

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

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

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

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

determinations because they were performed "ith the entire sampling system. ,

Instrument calibration checks were also made at the instrument

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

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

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

system auditverified the findings of the NMlvL4 checks.

3.2.1.1 Total Hydrocarbon Analyzer

THC was measured at the outlet and L'l1et of the enclosure using an

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

gas stream was made using a Thermo Electron l\lodel5lH THC analyzer. A

Ratfisch Model 52.RF analyzer was used to monimr THC c.cintent in the inlet air

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

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

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

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

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

covered conce:r;trations of styrene from 0 to approxini.ately 416 ppmv.

Calibration was simplified by using the.DAS inseead ofrecalibrating the two

instruments. That is, instead of using adjustrnem pOLentiometers on the

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

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

3-8 Rev. 1
Baseline Emission Testing

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

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

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

incorporating the DAS allowed calibration of the entire system, including

sampling lines, instrument, and data syste]TIs, incorporating potential biases

created by sample extraction equipment, instrument response: 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. Instrument response 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 of the compounds on the THe instrument. a factor needed to compare.

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

After the first test of the day. the instrument drift of the 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 took place. The results ofthese measurements are reported in

Section 4.1.1.

Printouts of raw continuous emission monitoring data are included

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

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

3-9 Rev. 1
/YMMA

---

1'1'1'1' Baseline Emission Testing

3.2.1.2 Gas Chromatograph

Concentrations of the two specific organic compounds expected in

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

sp'eciation of their emissions during gelco'lt operations and to provide a check on

the Method 25A emission measurements ~sing Method 18. Specific· , concentrations of styrene and MMA were determined using periodic

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

Series II integrator. A Supelco GP 10% 1,2,3-tris(2-cyanoethoxy)propene on

801100 Chromosorb PAW column (lI8-in diameter X 6 ft long stainless steel)

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

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

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

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

Measurements and calibration were conducted in accordance with

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

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

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

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

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

The GC was calibrated according to Method 18 procedures using

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

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

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

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

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

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

3-10 Rev.!
Baseline Emission Testing

concentrations of each compound. Area counts for the instrument responses

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

relationship between concentration and area count was generated for each

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

with the calculations in Appendix C.) AllJ:hromatograms generated during

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

reductions for every run are included in Appendix C.

Day to day calibration checks met the acceptance criteria or the

instrument was recalibrated.· Results of instrument calibration are presented in

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

. Section 4.7.

3.2.2 Flow Rate Measurements

Air flow rate from the enclosure was measured using EPA

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

single point in the TIE exhaust duct using a standard (Type L) pitot tube by

recording the velocity pressure head at ¢e centreid of the. duct. The pressure

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

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

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

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

flow through the duct.

A velocity for each recorded THC measurement was calculated .

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

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

the instantaneous reading (recorded in the DASj" and to the flow rate measured

3-11 Rev. I
Baseline Emission Testing

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

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

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

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

3.2.3 .. Temperature

.The type K thermocouple used for DAS and 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

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

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

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

exhaust temperature was therefore measured within two seconds of leaving the

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

measurement of the average TIE temperature than a single fIxed point within

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

temperature differential between ambient and exhaust air. The temperature was

monitored continuously using the DAS calibrated at two points.

3.2.4 Weight ofMaterial Used

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

determined by weighing the container of material on a platform balance

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

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

A small degree. of variability in the weight measurement was noted

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

3-12 Rev.!
Baseline Emission Testing

The variability resulted from the movement of the ancillary equipment

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

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

met the desired performance criteria and provided accurate measurements of the

resin and gelcoat use during testing on bO$lt parts..

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

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

based on stroke count of the positive displacement piston pumpsused for both

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

use.

The balance used to determine weight of resin and gelcoat used

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

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

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

Calibration certification is included with other certifications in Appendix F.

Calibration of the scale was checked periodically during the testing

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

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

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

3.3 Air Flow Over the Mold

, I

I

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

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

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

important adjustment was the flow rate through the enciosure to simulate the'

3-13 Rev. 1
Baseline Emission Testing

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

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

merely to provide a record.

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

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

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

production environment. Air floW velocities in a production lamination area

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

25 ftlmin near the air pick-ups at the exhaust plenum to 34-40 ftlmin in the

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

air handlers at one side ofthe room and exhausted from pick-Up plenaon the

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

molds (convex architecture) near the exhaustfrom the air handlers servicing the

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

Measurements made in the testing enclosure showed that velocities

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

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

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

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

approximately 40 ft/rnin. (Velocities at the NDOs to the TIE were much greater

than the reqUired 200 ftlmin, as noted in Section 1.3.1.)

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

Measurements at five locations on the mold surface ranged from 20-24 ftlmin on

the lower portion of the mold to 30-35 ftlmin at the upper region ofthe mold,

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

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

3-14 Rev. 1
Baseline Emission Testing

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

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

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

During the site audit by the j2;PA and its contractor Midwest

Research Institute (MRI), air velocity measurements at the mold s.urface were

made to verify that the velocity was in the range typical of the industry (and

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

measurements made on the molds.

Velocities were not measured during each test or run. These'

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

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

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

ofthe molds did not vary.

3.4 Mass Balance Styrene Recovery Check

>

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

tests) were conducted to e'vah,rate the capture and recovery ofstyrene by the.

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

program and one at its conclusion.

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

clothes drying rack, towels. and a gallon 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 of materials.) The container was thEm

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

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

3-15 Rev. 1
Baseline Emission Testing

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

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

repacked into the container and the TIE allowed to clear ofstYrene (while

emission monitoring continued). When emissions reached background

concentrations, the container was removeel from the TIE and reweighed.

Emissions were measured using the THC analyzer and the GC

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

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

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

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

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

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

Section 4.7.4, indicate good agreement between the measured evaporative loss

and the measured mass emission quantity.

3.5 Data Custody

Because all emission measurements were made using continuous

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

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

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

pressure of the exhaust stream, pressure head of Ll}e exhaust stream, THC

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

outlet stream from the enclosure, and concentrations ofspecific compounds in

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

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

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

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

3-16 Rev. 1
\

Baseline Emission Testing

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

hull gelcoating and was the first run on AprilS, 1997.

3-17 Rev. 1
......,..,....,.

/VNNA

---- Baseline Emission Testing

4.0 QUALITY CONTROL AND QUALITY ASSURANCE

Quality controllquality assurance (QCIQA) gUidelines outline

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

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

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

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

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

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

implemented to measure the effectiveness of the QC system.

The QCIQA procedures implemented during this test program

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

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

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

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

quality objectives for critical measurements, as presented in Section 3 ofthe

QAPP.

4.1 Concentration Measurements

The measurements taken for the characterization ofTHC content of

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

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

ensuringcomparablity with those previous tests. Styrene and MMA

concentration measurements were made according to Method 18 procedures,

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

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

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

4-1 Rev. i
I

\

Baseline Emission Testing

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

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

Table 4-1.

Table 4-1

, Acceptance Criteria for Concentration Measurements

10 percent of calibration gas value'

25A Calibration Drift

18 Calibration Error

18 Calibration Drift

10 percent of calibration gas value

10 percent of calibration gas value

5 percent of calibration 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 present the results of the Method 25A calibration

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

Appendix C. Both assessments of instrument performance,were made before

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

acceptance criteria'presented in the QAPP. The results ofjnstrument drift

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

10 percentofpre-test values. Based on reView of these Method 25A calibration

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

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

than 10 percent.

Because Shirley Wasson of the ORD during her review of the

QAPP expressed concerns about the stability ofstyrene stored in cylinders, THC

instrument calibrations were performed using propane. Response factors were

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

4-2 Rev. 1
Baseline Emission Testing

Table 4-2

Calibration Error Measurements for Total Hydrocarbon Analyzer

(Percent Actual Gas Value)

Actual Gas Concentration (ppmv)

Inlet Instrument Outlet Instrument

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 0407·0 I 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. I
Baseline Emission Testing

Table 4-3

Calibration Drift Measurements for Total Hydrocarbon Analyzer

. (Percent Span)

Actual Gas Concentration (ppmv)

Inlet Instrument 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. 1
Baseline Emission Testing

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

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

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

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

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

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

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

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

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

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

the THe calibration and drift criteria.

Table 4-4

Specific Compound Relative Response Factors

for the Total Hydrocarbon Analyzera

'Relative response factor 15 the THe Instrument measurement dIVIded by the calrbratIOn gas

concentration. e.g., ppm propane/ppm styrene.

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 after each run to ensure that the

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

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

calibration gas concentration divided by the area counts from the chromatogram

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

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

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

was replaced, and the response factor variation was reduced (after 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.. 0.00003

..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 program have been used primarily to

determine the relative quantities ofstyrene and MMA emitted during

4-6 Rev.l
Baseline Emission Testing

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

of Method 2SA testing. The relative concentrations of these two compounds in

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

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

that the leaking valve had little or no effec,t on the 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--lllB-

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

§

"-

Analysis Number

Table 4-5

Method 18 Response Factors for 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. 1
Baseline Emission Testing

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

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

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

variability seen in the individual measurements, although the degree of

variability is lessened through the averages. The ratio of the response factors . .

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

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

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

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

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

for all other gelcoat test runs. Styrene results for that test n,m were consistent.

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

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

Figure 4-3

Method 18 Response Factors for Selected Test Days

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·05

c4.0&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 o

co

0.2 "

0.1

4-8 Rev; 1
Baseline 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 of gas concentrations. An

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

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

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

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

styrene and MMA in each sample analyzed.

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

measurements pertain only to styrene calibrations, because all gelcoating runs

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

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

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

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

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

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

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

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

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

concentration. Because the reported emissions were calculated from the

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

reported emissions.

4-9 Rev. 1
Baseline Emission Testing

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 post 9-2

I· 1072 122 11.046080 I.IOE-05 post 9-2

1073 122 10864040 1.12E-05 post 9-2

1074 122 11025512 1.11E-05 3.28 post 9-2

1075 59.2 5985747 9.89E-06 post 9-2

1076 59.2 5700285 1.04E-05 0.00 -17.44 post 9-2

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 of Methods in Determining Emissions

There is relatively good agreement between the results of the two

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

more divergent results were typically thoS'e involving smaller molds. Table 4-7 ,

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

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

Table 4-7

Comparison 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. I
Baseline Emission Testing

Certainly, the concentration measurements made using both

approaches yielded consistent results. The THC concentration trace for

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

measured styrene and MMA 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 of Total Hydrocarbon Traces by Two Methods

NMlV'.tA-7-1

.

.

'lI", 1\ .

- I .... M

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 gelcoat flow rates were determined at the start

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

flow rate check. Resin-to-glass 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·

Flow Rate (g/min) Percent Resin Glass Percent

Eouinment Date Pre test Post test 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 Air Velocity over Mold Surface

Air flow 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 addition to being difficult to assess

accurately, air flow 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 of lamination or

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

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

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

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

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

.previous studies using.parts ndt typical of boat building.

Measurements made during a technical system audit performed by

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

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

LabDratDry Spray BDDth at the u.s. Marine Facility in Arlington, 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 of the velocity measurement can be

assessed by observing the variability ofthe velocity head measurements (which

were accurate to within 0.005 inches of water) during the test. This yields an

assessment terms of percent which can be compared with the acceptable

criteria ofthe method. Variability measurements for all test runs are shown with

4-15 Rev. 1
Baseline Emission Testing

the test averages (Table 4-9). The overall average variability in flow rate for the

program was 2.9 percent, and no measure for a~ entire day was greater than

6.9 percent. The two instances of greatest variability were affected by the two

measurements on April 4, early in the program, when TTE exhaust filters had

been allowed to become partially blocked,and were first being changed during

the test runs.

Table 4-9

Variability Measures for Flow Rate During Test Runs

. 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 on the

continuous,fixed point velocity head measurements) to vary based on filter

collection and other operations. The exhaust plena on both'longitudinal sides of

the enclosure were eqUipped with filter media (spun fiberglass air filters). Flow

rate decreased with time as these filters collected air-borne resin containing -

reactive styrene and MMA, which polymerized on the filter media. Periodically,

these filters were replaced to ensure more consistent flow rates through the

4-16 Rev. 1
Baseline Emission Testing

enclosure for all test runs. The build-up of material on the filters was one cause

of the variability in flow rate measured during the overall program. To some

smaller extent, this affected flow rate over the course of the test run, more so for

the larger articles which reqUired more resin. A second cause of the fluctuation

in flow rate was activity in the building where the enclosure was located. . .. Temperature was affected by the opening and closing of doors into the building.

Changes in the system operated by RTI also had some effect on the measurement·

of flow because both systems were connected to the same exhaust system at the

U.S. Marine facility. Changes made to accommodate their operation had some

effect on exhaust system pressure, thus affecting flow rate through the larger

enclosure.

4.5 Exhaust Air Temperature

As described in Section 3.2.3, enclosure air temperature was

monitored continuously using a type K thermocouple at the location of the fixed

pitot and the DAS, calibrated at two points. The accuracy ofthis measurement

was O.005°F (or O.O~Ol mY). Measurements of precision were not made during

the test program; however, literature suggests the precision oftype K

thermocouples, assessed in a laboratory environment, will yield a precision of

O.5°F,or within 1 percent ofthe measured values.

4.6 . ResiniGelcoat Balance

Balance calibration checks were often performed with barrels of

resin still on the platform and always performed without zeroing the balance.

Therefore, the calibration error was calculated in terms of percent of weight

change rather than the displayed weight value (Table 4-10). All calibration

results display a level of accuracy, measured as percent error, meeting the

4-17 Rev.l
Baseline Emission Testing

criteria of the QAPP (within 2Ib). Based on the maximum error measure of

0.2 percent and the high end of the 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 system was assessed through an

audit and styrene recovery tests. Audits of the THe sampling, balance, and flow

measurement systems were performed. The system audit was conducted by

4-18 Rev. 1
Baseline Emission Testing

EPA/OAQPS and its contractor MRI. The EPA/OAQPS audit will report on this

project, but the final report has not been released. Also, styrene recovery tests

(styrene evaporation tests) were performed in accordance with the QAPP.

4.7.1' Total Hydrocarbon Measurement . - ,

The results of the Method 25A system audit are presented in

Table 4-11. The audit gas was introduced.in two manners during the .

performance of the audit. One method involved fIlling a Tedlar® bag with the

audit gas and attaching it to the sampling probe. In the second method, the audit

cylinder was connected to the calibration system and the gas was introduced to

the sampling system in the same manner as all on-site calibrations were

performed; the propane audit was performed only with this latter method. Both

methodsyield resultS representative of the 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 on 4/15 and 2.318 on 4/16.

c. Test performed with audit gas in TedJar(E) bag.

d. Test performed with audit gas in vented cylinder.

Conversion of THC concentration to eqUivalent concentrations of

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

analyzer (Method 25A} on the day ofthe audit. Using the pre-test analysis by

Scott Specialty Gases (41.7 ppmv styrene), the analysis by THe analyzer was

about 12 percent low. However, on-site analysiS of the standard by GC indicated

4-19 Rev. 1
Baseline Emission Testing

that the concentration in the audit sample was only 39.7 ppmv. Although this

assessment does not meet the requirements of a protocol gas certification, the

results indicate that the certified value of the audit cylinder may be slightly low.

Comparing to concentration from this reanalysis of the standard shows that the

THC analysis was only 7.3 percent low, v.:ithin the criterion established for the

program. This low recovery does not appear to be a system malfunction. The

good results of the propane audit indicate the low results of the styrene audit

sample are not a result of sampling system bias (leaks). Further, procedures in

determining response factors included introduction of the gas at the probe; thus·

incorporating any system characteristics into the results. The results of the

styrene audit indicate the sampling system, as used in the performance ofthe

audit, .results in an under reporting of styrene concentrations by less than

10 percent at a 40-ppmv concentration, or about 3 ppmv styrene.

4.7.2 Weigh Cell Balance

The results of the weigh cell balance audit performed on April 16

indicate that greater than 5 percent error results when weighing less than 3000 g,

or approXimately 6.6Ib, on an empty scale (Table 4-12).Howev~r, testing was

conducted with a drum of resin or gelcoat or resin in place, meaning that the

scale was used during the test program in its normal operating range. The

results of the audit and the calibration checks (Table 4-10) demonstrate that even

small weight changes can be measured accurately through the weight range

experienced during this test program. Although the audit was conducted with

an empty balance, the calibration checks were conducted with both empty and

loaded scale (i.e., with a drum of resin in place). Data collected from the

calibration check using certified weights on April 8 indicate that a less than lIb

change in weight at an elevated balance response (512Ib) was accurately

quantified. These data indicate the balance was capable of accurately measuring

4-20 Rev. 1
Baseline Emission Testing

500-g (l.1-lb) changes in weight in the range of operation, well within

specifications of the QAPP (Le., 2Ib). Two data points from the audit can be

used to assess the precision of the weight measurements. The replicate weighing

performed at 57 and 157 lb indicate a precision of greater than 0.2 lb, also within

QAPP specifications.

Table 4-12

Results of Audit on Balance

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 of the flow rate audits were reported in the draft audit

report. Comparison of the audit results to the measurements made for the test

runs of the same days indicate goodagreeJIlent for velocities and flow rates

measured using Method 2 (Table 4-13). The preliminary velocity measurement

by hot wire anemometer made by the auditor on April 14 indicated a greater

velocity than calculated from pitot tube measurements. The differences are

attributed to the hot wire anemometer velocity being a point measurement

compared with an average velocity n;s1,1lting from the pitot t.ube measurements

and the presence of hydrocarbon in the stream, which can cause hot wire

anemometer velocity readings greater than actual velocities.

Table 4-13

Results ofFlow Rate Audit

l4-A r

l5-A r

Audit-hot wire

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 of styrene by the

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

program and one at the conclusion of the program. In both cases. the recovered

quantity of styrene met the acceptance criteria for a good system (±!O percent)

(Table 4-14).

4-22 Rev. 1
Date

Baseline Emission Testing

Table 4-14

Results of Styrene 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 of the system and its

operation because no testing had been conducted in the building and, therefore,

no background styrene in building air or booth air interfered with the results.

The results from the fIrst test showed excellent agreement between the measured

quantity ofstyrene evaporated from the apparatus (provided by RTI) and the

emissions determined by~easuringstack gas concentrations and flow rate. The

closure between these two measurements is not as close for the fInal test.

however. Although it is true that the flow rate through the enclosUre was greater

during the second test. the greater emissions measured ar~'attributed more to

the mold left in the enclosure after previous lamination testing. Although the

measured styrene concentrations were adjusted for the concentration in the

incoming air and attempts were made to account forthe background

concentration in the enclosure. it is likely that some of the styrene included in the

measured emissions may have been generated by the mold and part left in the

enclosure (Le .. residual curing emissions).

4-23 Rev. 1
AJl'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 HAP.· II 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