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Boat Manufacturing NESHAP Workshop U.S. Environmental Protection Agency Office of Air Quality Planni

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Title: Boat Manufacturing NESHAP Workshop U.S. Environmental Protection Agency Office of Air Quality Planni


1
Boat Manufacturing NESHAP Workshop U.S.
Environmental Protection AgencyOffice of Air
Quality Planning and StandardsFebruary 8,
2002International Boatbuilders Exhibition
ConferenceFt. Lauderdale, FL
2
Objectives for this Workshop
  • Review the requirements of the boat manufacturing
    rule.
  • Provide some examples to help explain the
    requirements.
  • Answer questions from industry and regulators.
  • Provide you with information on additional
    resources.

3
SECTION 1.0 - OVERVIEW OF THE INDUSTRY
4
Approximate Major-Source Boat Manufacturing
Facilities Per State From 1999 TRI Data (SIC
3732)
3
5
2
3
3
1
5
4
6
3
2
1
7
3
7
3
8
1
12
1
5
8
1
2
2
1
8
1
1
32
5
Basic Steps in Building Fiber Reinforced Plastic
(FRP) Parts
1. Spray gel coat
2. Apply skin coat of resin and fiberglass
4. Remove cured part from mold
3. Apply more resin and fiberglass
reinforcements
6
Basic Polyester Resin Chemistry Styrene monomer
is both a diluent and a cross-linking agent.
CH2
CH2
Styrene Monomer
Polyester molecule
Peroxide Catalyst
CH
CH

Polyester molecule
Unsaturated Polyester Resin Molecules (Liquid)
CH
CH
Polyester molecule
Cross-linked Polyester Resin Molecules (Solid)
7
As styrene content increases, the fraction of
styrene monomer that is emitted increases.
100
(Conventional coatings 100 of HAP solvent is
emitted)
Available HAP emitted
(Data are presented only as an example.)
20
12
35
42
Resin or gel coat styrene content (Wt)
8
As styrene content increases, the styrene mass
emission rate increases exponentially.
84
(Data are presented only as an example.)
kg styrene emitted per Mg material applied
42
35
42
Resin or gel coat styrene content (wt)
9
Styrene Emissions Profile
Application
Roll-out
50
(Data are presented only as an example.)
Curing
Styrene Concentration (ppm)
25
75
30
0
60
45
15
90
Time (Minutes) Since Start of Application
10
Resources for Estimating Styrene Emissions
  • Links on EPAs emission factor website
  • (http//www.epa.gov/ttn /chief/efdocs/)
  • EPA/Office of Research and Development (ORD)
    model.
  • Composite Fabricators Association (CFA) model.
  • National Marine Manufacturers Association (NMMA)
    study.

11
National Baseline HAP Emissions(Based on 1996
EPA survey data)
12
SECTION 2.0 - OVERVIEW OF THE RULE
  • Who?
  • What?
  • When?
  • How?

13
General Information
  • National Emission Standards for Hazardous Air
    Pollutants NESHAP for Boat Manufacturing
  • 40 CFR 63, subpart VVVV, sections 63.5680, and
    following
  • Proposed rule published July 14, 2000 (65 FR
    43842)
  • Final rule published August 22, 2001 (66 FR
    44218)

14
Who is Covered?
  • Your facility is subject if it meets both of the
    following criteria
  • It meets the definition of boat manufacturing
    facility.
  • It is a major source of HAP.

15
Definition of a Boat Manufacturing Facility
  • Manufactures hulls or decks from fiberglass or
    aluminum
  • OR
  • Assembles boats from pre-manufactured hulls and
    decks
  • OR
  • Builds molds to make fiberglass hulls or decks.

16
What is a Major Source?
  • Has the potential to emit
  • 10 tpy of a single HAP
  • OR
  • 25 tpy of a combination of HAP.

17
Example Is this facility a major source?
  • FRP boat manufacturing styrene emissions 8
    tpy.
  • Aluminum boat manufacturing various HAP 10
    tpy.
  • FRP golf cart manufacturing styrene emissions
    8 tpy.

18
Example Is this facility a major source?
  • FRP boat manufacturing actual styrene emissions
    7 tpy
  • Operating schedule is 8 hours per day, 5 days per
    week.

19
Can a facility obtain an area source exemption so
it is not subject to this rule?
Area Source Options
Comply with area-source requirements in the rule
From your state obtain an area-source permit
with restrictions on your potential-to-emit
From your state obtain and comply with a Title V
(major source) operating permit
20
Area Source Exemption Requirements for Material
and HAP Consumption
  • Fiberglass boat manufacturers
  • Resin and gel coat Limit usage to 50 tons per
    year.
  • Aluminum boat manufacturers
  • All solvents, coatings, and carpet and fabric
    adhesives Limit usage to 20 tons per year.

21
Area Source Exemption Requirements for Material
and HAP Consumption (Continued)
  • Fiberglass or aluminum boat manufacturers
  • Limit HAP consumption 5 ton/year of a single HAP
    and 12.5 ton/year of all combined HAP.
  • For all
  • Materials with limits must account for 90 percent
    of emissions.
  • Keep records and calculations demonstrating
    compliance.

22
What Does the Rule Cover?
Boat Manufacturing NESHAP
Aluminum Boat Surface Coating Operations
Fiberglass Resin and Gel Coat Operations
Carpet and Fabric Adhesives
Resin and Gel Coat Mixing Containers
Aluminum Wipe-down Solvents Aluminum
Coatings Spray Gun Cleaning
Resin and Gel Coat Emission Limits
Application Equipment Cleaning Solvents
23
Regulated Operations in FRP Boat Manufacturing
Mold sealing and release agents
Skin coat resin application
Plug and prototype construction
Mold Construction
Production gel coat application
Resin and gel coat mixing operations
Tooling resin and gel coat
Laminating resin application
Structural core adhesives
Resin and gel coat equipment cleaning solvents
Structural grid installation
Flotation foam
Antifoulant coatings Wood coatings Hull and
deck coatings
Resin for taping and tabbing
Structural assembly adhesives
Carpet and fabric adhesives
Hull and deck assembly
Carpet and upholstery installation
Final assembly and rigging
24
Regulated Operations in Recreational Aluminum
Boat Manufacturing
Parts cutting and bending
Caulks and sealants
Caulks and sealants
Welding
Acid wash
Stretch forming
Heat hardening
Riveting
Aluminum wipe-down solvents
Surface preparation
Primers and topcoats
Spray gun cleaning
Painting
Antifoulant coatings Wood coatings
Carpet and fabric adhesives
Flotation Foam Pouring
Final assembly and rigging
Carpet installation
25
Other Operations Not Covered
  • Aluminum coating operations on non-recreational
    boats (e.g., military or commercial).
  • Research and development activities.
  • Materials in hand-held aerosol cans.

26
Rule Is Based on Pollution Prevention
  • HAP Content Limits
  • Open molding resin and gel coats.
  • Carpet and fabrication adhesives.
  • Aluminum recreational boat surface coatings.
  • Work Practice Requirements
  • Non-atomizing (non-spray) resin application
    equipment.
  • Covered resin and gelcoat mixing containers (55
    gallons and up).
  • Enclosed spray gun cleaners for aluminum boat
    painting.

27
Compliance Dates
  • Existing Sources August 22, 2004
  • New Sources Upon startup
  • Area gt major sources One year after becoming a
  • major source, or
  • August 22, 2004, whichever is
  • later

28
What is a New Source?
  • Started construction after July 14, 2000.
  • It is a major source upon startup.
  • It is a completely new boat manufacturing
    facility where none existed immediately prior to
    the construction of the facility.

29
Examples What is the compliance date?
  • Facility is built in 1990 and is emitting 40 tpy
    of styrene.
  • Facility begins construction on January 31, 2002
    and starts operating on July 31, 2002 and is
    emitting 30 tpy of styrene.
  • Facility is built in 1995 and emits 7 tpy of
    styrene until 2004. On July 31, 2004, facility
    expands and begins emitting 15 tpy of styrene.

30
Compliance Time-line Existing Sources
December 20, 2001 Initial notification.
August 22, 2004 Begin collecting compliance data.
August 22, 2005 Determine compliance.
September 21, 2005 Notification of compliance
status.
Monthly Determine compliance based on the
previous 12 months of data.
Submit semi-annual compliance reports. (Periods
ending December 31 and June 30)
31
Compliance Time-line New Sources
120 days after startup Submit initial
notification.
Upon startup Begin collecting compliance data.
One year after startup Determine compliance.
One year and 30 days after startup Notification
of compliance status.
Monthly, determine compliance based on the
previous 12 months of data.
Submit semi-annual compliance reports. (Periods
ending December 31 and June 30)
32
SECTION 3.0 - FIBERGLASS BOAT MANUFACTURING
OPERATIONS
Fiberglass Operations
Open Molding Resin and Gel Coat Emission Limits
Application Equipment Cleaning Solvents
Resin and Gel Coat Mixing Containers
Closed Molding
33
Exemptions from Emission Limits
  • Resins required to meet military specifications
    for use on military vessels.
  • Resins approved by the U.S. Coast Guard for use
    in
  • life saving boats and appliances subject to 46
    CFR subchapter Q
  • small passenger vessels subject to 46 CFR
    subchapter T.
  • 100-percent vinylester skin coat resins.
  • Not to exceed 5 percent of the total resin used
    per year.
  • Note Exempt resins must be applied with
    non-spray (non-atomizing) technology.

34
Exemptions (Continued)
  • Gel coats used for part or mold repair
  • Not to exceed 1 percent of the total gel coat
    used per year.
  • Solvents used to remove cured resin and gel coat
    from application equipment.

35
Examples
  • How many tons of resin or gel coat are exempt at
    each facility?
  • A facility uses 100 tons per year of resin 7
    tons are a 100-percent vinylester resin used for
    skin coats.
  • A facility uses 20 tons per year of gel coat
  • 15 tons of pigmented gel coat and
  • 5 tons of tooling gel coat.
  • 200 lbs (0.1 ton) of the tooling gel coat is used
    for mold touch-up and repair.

36
Resin and Gel Coat Compliance Options
Closed Molding (Resin)
Compliant Materials
Emissions Averaging
Add-On Controls
Weighted Average
Each Material
HAP Content Records
No Records
HAP Content Records Usage Records Monthly
Calculations
Compliance Test Continuous Monitoring 5-year
Testing
HAP Content Records Usage Records Monthly
Calculations Implementation Plan
Periodic Reporting
Note A single facility may use more than one
compliance option.
37
Closed Molding Requirements
  • No limit on HAP content of resin used for closed
    molding.
  • No records needed.
  • Process must meet the definition of closed
    molding.

38
Closed Molding Definition
  • Fabric and other reinforcements are placed
    between two mold surfaces.
  • Mold surfaces could be rigid or flexible.
  • Pressure distributes the resin throughout the
    mold and saturates the fabric and reinforcements.
  • Pressure could be vacuum, clamping, or fluid
    pressure.

39
Closed Molding Examples
  • Compression molding with sheet molding compound
    (SMC).
  • Infusion molding or vacuum assisted resin
    transfer molding (VARTM).
  • Resin transfer molding (RTM).
  • Vacuum assisted compression molding.
  • These are not closed molding
  • Vacuum bagging after the resin is applied.
  • Gel coat and skin coat applied with open molding.

40
Compliant Materials OptionBased On Each Material
  • All materials in an open molding operation meet
    specific HAP content limits.
  • Benefits
  • No compliance calculations
  • Minimal recordkeeping.

41
HAP Content Limits for Resin and Gel Coat
Operations
42
HAP Content Limits for Production Resin Vacuum
Bagging Operations Limits are Derived from MACT
Model Point Value Equations
43
Compliant Materials Option Based on
Weighted-Average HAP Content
  • Weighted-average HAP content determined monthly
    from the material used in each 12-month
    compliance period.
  • Separate compliance determination for each
    operation.
  • Benefit You can use a mix of low-HAP and high
    HAP materials within an operation.

44
Weighted-Average HAP Content Example
45
Step 1 Total resin used is 100 Mg 5 Mg of the
vinylester skin coat resin (5 of total) is
exempt
46
Step 2 Multiply the HAP content by the Mg of
each resin used total the resin and HAP
47
Step 3 Divide Mg HAP by Mg resin and multiply
by 100
33.15 Mg HAP
HAP Content
x 100 34.9
95 Mg Resin
Facility is in compliance with 35 percent HAP
content limit.
48
Records Needed for the Compliant Materials Option
Based on Weighted-Average HAP Content
  • HAP content of each material.
  • Amount of each material used per month.
  • Calculations performed each month to demonstrate
    compliance based on previous 12 months data.

49
Emissions Averaging
Compute facility-specific HAP emission limit
(kg/year)
Determine facilitys emission rate (kg/year)
If emission rate is less than emission limit,
facility is in compliance.
  • Emission limit and emission rate are 12-month
    rolling averages.
  • Emission limit and emission rate may change every
    month.

50
Emissions Averaging Features
  • Averaging does not need to include all
    operations.
  • Averaging must be done using MACT model point
    values.
  • MACT model point values
  • Are NOT intended for use as emission factors.
  • MUST be calculated from the equations in the rule.

51
Emissions Averaging Implementation Plan
  • Intended as a road-map.
  • Submitted with notification of compliance status.
  • Describes the operations included in the average.
  • Describes HAP contents, application methods,
    other control methods.
  • Includes calculations demonstrating future
    compliance.
  • Kept on site and available for inspection.
  • Submit any changes with the next semi-annual
    compliance report.

52
Calculating the Emission Limitation
  • HAP limit
  • 46(MR) 159(MPG) 291(MCG) 54(MTR)
    214(MTG)
  • HAP limit allowable HAP emissions (kg/year)
  • Mi mass of each material used, Mg
  • (1 Mg 1.1023 tons)

53
Calculating the Emission Rate
  • HAP emissions
  • PVR(MR) PVPG(MPG) PVCG(MCG) PVTR(MTR)
    PVTG(MTG)
  • HAP emissions HAP emission rate (kg/year)
  • PVi point value for each material used,
  • kg HAP/Mg material used
  • (1 Mg 1.1023 tons)

54
MACT Model Point value EquationsTable 3 to
Subpart VVVV
  • Example Production resin, non-spray
  • kg HAP/Mg resin applied 0.014(HAP)2.275
  • Separate point value equations for resin based
    on
  • atomized or non-atomized application
  • vacuum bagging with or without roll-out
  • One equation for all gel coat operations

55
Example Is this facility in compliance based on
emissions averaging?
56
Step 1 Calculate the Emission Limit
  • HAP limit
  • 46(MR) 159(MPG) 291(MCG) 54(MTR)
    214(MTG)
  • HAP limit
  • 46(9010) 159(30) 291(0) 54(0) 214(0)
  • 9,370 kg HAP

57
Step 2 Calculate the MACT Model Point Value for
Each Operation
58
Step 3 Calculate HAP Emissions (kg/yr)
59
Step 4 Compare the HAP Emissions to the HAP
Limit
HAP emissions 9,051 kg HAP limit 9,370 kg
The operations included in the average are in
compliance for this 12-month period.
60
Records Needed For the Emissions Averaging
Option
  • The HAP content of each material.
  • The amount of each material used per month.
  • Monthly compliance calculations.
  • An up-to-date copy of your implementation plan.

61
What are Filled Resins?
  • Filled resins are mixed with an inert filler to
    reduce shrinkage and improve heat transfer.
  • Most often used for building molds (tooling).
  • Unfilled (neat) resin contains more styrene
    (e.g., 45).
  • Filled resins cannot comply based on the HAP
    content of the filled resin
  • Must use MACT model point values.
  • Fraction of styrene emitted is higher than
    unfilled resin of same HAP content.

62
Standards for Filled Resins
  • Production resin 46 kg HAP/Mg filled resin
    applied.
  • Tooling resin 54 kg HAP/Mg filled resin
    applied.

63
Calculating the MACT Model Point Value for a
Filled Resin
(100 - Filler)
PVF PVU x
100
PVF The as-applied MACT model point value
for a filled production resin or tooling
resin. PVU The MACT model point value for the
neat (unfilled) resin, before filler is
added. Filler The weight-percent of filler
in the as-applied filled resin system.
64
Example Is this filled tooling resin in
compliance? (Limit 54 kg/Mg)
  • The resin has a HAP content of 46 percent.
  • The resin is mixed 40 percent by weight with
    filler and applied with a flow coater.

65
Step 1 Determine the MACT model point value for
the unfilled resin
PVU 0.014 x (46)2.275 84.9 kg/Mg
66
Step 2 Calculate PVF
  • PVF 84.9 kg/Mg x (100 - 40 filler)/100
  • 50.9 kg/Mg
  • PVF is less than 54 kg/Mg.
  • This filled resin is in compliance.

67
Example Using Filled Resins in Emissions
Averaging
68
Step 1 Calculate the Emission Limit
  • HAP limit
  • 46(MR) 159(MPG) 291(MCG) 54(MTR)
    214(MTG)
  • HAP limit
  • 46(9010) 159(30) 291(0) 54(10) 214(0)
  • 9,910 kg HAP

69
Step 2 Determine HAP Emissions (kg/yr)
70
Step 3 Compare the HAP Emissions to the HAP
Limit
  • HAP emissions 9,560 kg
  • HAP limit 9,910 kg
  • The operations included in the average are in
    compliance for this 12-month period.

71
Records Needed if Using Filled Resins
  • HAP content of the neat (unfilled) resin.
  • Amount of resin and filler used.
  • Calculations demonstrating compliance based on
    the MACT model point value of the as-applied
    filled resin.

72
Using an Add-on Control Device
  • Conduct a performance test.
  • Conditions must represent maximum potential to
    emit.
  • Measure total HAP emissions.
  • Calculate the emission limit for the materials
    applied during test.
  • Monitor operating parameters for the emission
    capture and control system.
  • Establish operating limits for the capture and
    control system.

73
Using an Add-on Control Device (Continued)
  • Continuously monitor operating parameters for
    compliance with operating limits.
  • Submit semi-annual monitoring and compliance
    reports.
  • Complete a startup, shutdown, and malfunction
    plan submit SSM reports, if needed.
  • Repeat performance test every 5 years with
    operating permit renewal.

74
Add-On Capture and Control System Testing
  • Use EPA Method 25 to measure THC as a surrogate
    for HAP emissions or EPA Method 18 to measure
    HAP.
  • Is the emission capture system a permanent total
    enclosure (per EPA Method 204)?
  • YES measure emissions at the stack only.
  • NO measure stack emissions and also fugitive
    emissions using a building or temporary total
    enclosure to capture fugitives.

75
Operating Limits for Add-On Emission Capture and
Control Systems
  • Thermal oxidizers average combustion temperature
    during test.
  • Permanent total enclosure
  • Face velocity of openings 200 fpm into the
    enclosure.
  • OR
  • Pressure drop across openings 0.007 in. H20
  • Capture systems that are not permanent total
    enclosures
  • Duct volumetric flow rate or static pressure
    during test.
  • OR
  • Pressure drop across openings during test.

76
Standards for Resin and Gel Coat Mixing
Operations
  • Applies to containers 55 gallons (208 liters) or
    larger.
  • Must have a cover with no visible gaps in place
    at all times, except when
  • Manually adding or removing material.
  • Inserting or removing pumping or mixing
    equipment.
  • Inspect covers monthly.
  • Keep records
  • Which containers are subject.
  • Results of the inspections and any repairs made.

77
Standards for Resin and Gel Coat Application
Equipment Cleaning Operations
  • Routine flushing and cleaning solvents 5 percent
    HAP content limit.
  • Removing cured resin and gel coat no HAP content
    limit.
  • Containers for HAP solvents 2 gallons or larger
    must have
  • A tightly fitting cover and
  • A Afreeboard ratio_at_ of at least 0.75.

78
What is freeboard ratio?
Diameter
Freeboard
Solvent
79
Demonstrating Compliance Resin and Gel Coat
Equipment Cleaning Operations
  • Routine flushing and cleaning solvents record
    the HAP content.
  • HAP solvent containers
  • Monthly inspections of the covers.
  • Record the inspection results and any repairs
    made to covers.

80
SECTION 4.0 - REQUIREMENTS FOR CARPET AND FABRIC
ADHESIVE OPERATIONS
  • Emission limit 5.0 percent organic HAP by
    weight for each adhesive.
  • Applies to both fiberglass and aluminum boat
    manufacturers.
  • Does not apply to materials in hand-held aerosol
    cans.
  • Record needed HAP content of each carpet and
    fabric adhesive.

81
SECTION 5.0 - ALUMINUM RECREATIONAL BOAT SURFACE
COATING OPERATIONS
  • Emission Limits (units are kg HAP per liter
    coating solids)
  • Compliance is based on a 12-month rolling average.

82
Exemptions from Aluminum Boat Surface Coating
Limits
  • Commercial and military (non-recreational)
    vessels
  • Antifoulant coatings
  • Assembly adhesives
  • Wood coatings
  • Materials in hand-held aerosol cans
  • Solvents used to prepare for decals or adhesive
    graphics

83
Aluminum Coating Spray Gun Cleaning Operations
  • Comply with one of the following
  • Limit gun cleaning solvents to 5 percent HAP.
  • Use an enclosed spray gun cleaner.
  • Disassemble the gun and clean the parts in a vat.
  • Force solvent through the gun without atomizing
    air and direct the solvent into a container.

84
Compliance Steps for Aluminum Coatings
  • 1. Calculate kg HAP in wipedown solvents and
    coatings.
  • 2. Calculate the liter of solids from the
    coatings.
  • 3. Calculate the emission rates from solvents and
    coatings as kg HAP per liter coating solids.

85
Example Calculate the emission rate for the
wipedown solvents.
86
Step 1 Calculate the kg of HAP in the wipedown
solvents
87
Step 2 Calculate the liters of solids contained
in the coatings
88
Step 3 Calculate the wipedown solvent emission
rate
  • 590 kg HAP 2,175 liters of coating solids
  • 0.27 kg HAP/liter coating solids
  • Facility is in compliance with wipedown solvent
    limit of
  • 0.33 kg HAP/liter coating solids

89
Example Calculate the Emission Rate for the
Coatings
90
Step 1 Calculate the kg of HAP contained in the
coatings and additives
91
Step 2 Calculate the liter of solids contained
in the coatings
92
Step 3 Calculate the coatings emission rate
  • 2,532 kg HAP 2,175 liters of coating solids
  • 1.16 kg HAP/liter coating solids
  • Facility is in compliance with aluminum coating
    limit of
  • 1.22 kg HAP/liter coating solids

93
Combined Rate Solvent Rate Coating Rate
  • Example
  • Solvent rate 0.40 kg HAP/liter coating solids
  • Coating rate 1.05 kg HAP/liter coating solids
  • Combined rate 0.40 1.05 1.45 kg HAP/liter
    coating solids
  • Facility is in compliance with combined limit
  • of 1.55 kg HAP/liter coating solid.

94
Recordkeeping for Aluminum Coating Operations
  • Consumption (volume) of each wipedown solvent and
    coating.
  • Organic HAP content of each wipedown solvent and
    coating.
  • Solids content (by volume) of each coating.
  • Density of each wipedown solvent and coating.
  • Monthly compliance calculations based on the
    previous 12 months of data.

95
SECTION 6.0 - DETERMINING HAP CONTENT OF
REGULATED MATERIALS
  • Use an EPA-approved method.
  • OR
  • Rely on MSDS or other HAP-content documentation.
  • Compliance determinations
  • EPA-approved methods prevail over MSDS, etc.
  • Use upper limit of reported HAP ranges.
  • 2.0 allowance for EPA methods vs. MSDS, etc.

96
EPA-Approved Methods for Resin and Gel Coat
Materials
  • EPA Method 311 HAP Analysis in Paints and
    Coatings by Gas Chromatograph.
  • ASTM D1259-85 Standard Test Method for
    Non-volatile Content of Resins
  • Assume that the volatile fraction is HAP.

97
EPA-Approved Methods for Aluminum Boat Surface
Coating Operations
  • EPA Method 311 HAP Analysis in Paints and
    Coatings by Gas Chromatograph.
  • EPA Method 24 Determines VOC and water content
    in surface coatings.
  • Assume that the non-aqueous volatile fraction is
    HAP.

98
Determining the Solids Content by Volume of
Aluminum Boat Surface Coatings
  • ASTM Methods D2697-86(1998) or D6093-97.
  • Information from the supplier or manufacturer of
    the coating.
  • Calculating the volume solids from the volume and
    density of volatiles.

99
Calculating the Volume Solids From the Volume and
Density of Volatiles
  • Solids 1 - (mvolatiles Davg)
  • mvolatiles total mass of volatile compounds
  • (including water), from EPA Method 24.
  • Davg average density of volatiles (including
  • water), from ASTM Method D1475-90,
  • the supplier, or solvent references.

100
Which HAP Must Be Included in HAP Totals?
  • All carcinogenic HAP present at 0.1 percent or
    more.
  • All non-carcinogenic HAP present at 1.0 percent
    or more.

101
Which HAP are Carcinogens?
  • Defined by OSHA at 29 CFR 1910.1200(d)(4) using
    the following
  • National Toxicology Program, Annual Report on
    Carcinogens
  • (http//ntp-server.niehs.nih.gov/htdocs/8_RoC/K
    nown_list.html)
  • International Agency for Research on Cancer
    Monographs
  • (http//monographs.iarc.fr/)
  • OSHA Occupational Safety and Health Standards
  • (29 CFR part 1910, subpart Z, section
    1910.1003)
  • (http//www.gpo.gov/nara/cfr/index.html)

102
Determining HAP Content for Solvent Blends
  • Table 5 of subpart VVVV solvent blends with
    matching CAS number.
  • Table 6 of subpart VVVV aliphatic and aromatic
    solvent blends without CAS numbers.
  • EPA-approved methods prevail over HAP content
    from solvent blend tables.

103
SECTION 7.0 - COMPLIANCE REPORTING REQUIREMENTS
  • Semi-annual compliance reports required for all
    sources subject to the rule.
  • Each report includes the six 12-month averages
    calculated for that period (if applicable).
  • Each report is due 60 days after the end of the
    calendar half.

104
Compliance Reporting Timeline
Compliance Notification
Semi-Annual Compliance Report
Compliance date
Determine Compliance
Collect Data (12 Months)
105
Contents of the Compliance Reports
  • Company name and address.
  • Responsible company officials certification.
  • Date of the report and beginning and ending dates
    of the reporting period.
  • Any changes to the manufacturing process since
    the last compliance report.

106
Contents of the Compliance Reports (Continued)
  • A summary of applicable requirements and the
    emission level achieved
  • Compliant material HAP contents.
  • Weighted average HAP content (each 12-month
    period)
  • Emissions average HAP limit and HAP emissions
    (each 12-month period)
  • A statement of whether you were in compliance.
  • A description of any deviations, the source
    affected, and corrective actions.

107
SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL
PROVISIONS
  • 40 CFR 63 Subpart A - General Provisions
  • A framework for standards and other requirements
    under Section 112 of the Clean Air Act.
  • Eliminates repetition of information and
    requirements applicable to all NESHAP.

108
SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL
PROVISIONS (Continued)
  • Includes the following sections, among others
  • Applicability
  • Definitions
  • Compliance dates
  • Construction and reconstruction
  • Performance testing
  • Monitoring
  • Notifications
  • Recordkeeping and reporting
  • State authority and delegation

109
SECTION 8.0 - THIS RULE AND THE NESHAP GENERAL
PROVISIONS (Continued)
  • Individual rules may over-ride specific
    requirements in the General Provisions.
  • Table 8 to subpart VVVV lists
  • Which requirements of the General Provisions
    apply.
  • Which are over-ridden.
  • Which are addressed more specifically in the rule.

110
Example Applicability of General Provisions
111
SECTION 9.0 - RELATIONSHIP TO OTHER RULES
  • Reinforced plastic composites NESHAP
  • Proposed August 2, 2001.
  • Shipbuilding and repair (surface coating) NESHAP
  • Does not apply to recreational vessels (pleasure
    craft).

112
RELATIONSHIP TO OTHER RULES (Continued)
  • Wood furniture manufacturing NESHAP
  • Boat manufacturers are not covered.
  • Plastic parts and products surface coating
    NESHAP
  • Under development.
  • Miscellaneous metal parts surface coating NESHAP
  • Under development.

113
SECTION 10.0 - PERMITTING
114
SECTION 11.0 - Where can I find additional
information about this rule?
  • For applicability and rule determinations,
    contact your State or local agency.
  • EPA Regional Office contacts (Attachment C).
  • For other information, contact Mark Morris (919)
    541-5416 or morris.mark._at_epamail.epa.gov.

115
Resources on the Web
  • EPA Air Toxics Website - Boat Manufacturing
    NESHAP site
  • www.epa.gov/ttn/atw/boat/boatpg.htmlIMP
  • EPA National Compliance Assistance Clearing house
  • http//cfpub1.epa.gov/clearinghouse/
  • National Marine Manufacturers Association
  • http/www.nmma.org/index.asp?bhcp1
  • Professional Boatbuilder
  • www.proboat.com
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