UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania  19103

DATE:	April 5, 2016

SUBJECT:	Technical Support Document – Control of Volatile Organic
Compound Emissions from Fiberglass Boat Manufacturing Materials 

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:	File

			/s/	

THRU: 	Cristina Fernandez, Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

Section 172(c)(1) of the Clean Air Act (CAA) provides that state
implementation plans (SIPs) for nonattainment areas must include
reasonably available control measures (RACM), including reasonably
available control technology (RACT), for sources of emissions.  Section
182(b)(2)(A) provides that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of volatile organic
compound (VOC) emissions covered by a control techniques guidelines
(CTG) document issued after November 15, 1990 and prior to the area’s
date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as
“the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably
available considering technological and economic feasibility.” (44 FR
53761, Sept. 17, 1979).  In subsequent Federal Register notices, EPA has
addressed how states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control
authorities information that should assist them in determining RACT for
VOCs from various sources fiberglass boat manufacturing materials.  In
developing CTGs, EPA, among other things, evaluated the sources of VOC
emissions from this industry and the available control approaches for
addressing these emissions, including the costs of such approaches. 
Based on available information and data, EPA provides recommendations
for RACT for VOCs from various industry categories, including fiberglass
boat manufacturing.

EPA has not published a previous CTG for fiberglass boat manufacturing
materials, but did publish an assessment of VOC emissions from
fiberglass boat manufacturing in 1990.  The 1990 assessment defined the
nature and scope of VOC emissions from fiberglass boat manufacturing,
characterized the industry, estimated per plant and national VOC
emissions, and identified and evaluated potential control options.  In
2001, EPA promulgated the National Emission Standards for Hazardous Air
Pollutants for Boat Manufacturing, 40 CFR part 63, subpart VVVV (2001
NESHAP).  The 2001 NESHAP established organic hazardous air pollutant
(HAP) emissions limits based on low-HAP resins and gel coats and
low-emitting resin application technology.  Several of the air pollution
control districts in California have specific regulations that control
VOC emissions from fiberglass boat manufacturing operations, as part of
their regulations for limiting VOC emissions from polyester resin
operations.  Several other states also have regulations that address VOC
emissions from fiberglass boat manufacturing as part of polyester resin
operations.  After reviewing the 1990 VOC assessment, the 2001 NESHAP,
and existing California district and other State VOC emission reduction
approaches, and after considering information obtained since the
issuance of the 2001 NESHAP, EPA developed a CTG entitled Control
Techniques Guidelines for Fiberglass Boat Manufacturing Materials
(Publication No. EPA 453/R-08-004; September 2008).

Description of Fiberglass Boat Manufacturing Materials

The CTG for fiberglass boat manufacturing materials provides control
recommendations for reducing VOC emissions from the use of gel coats,
resins, and materials used to clean application equipment in fiberglass
boat manufacturing operations.  This CTG applies to facilities that
manufacture hulls or decks of boats from fiberglass, or build molds to
make fiberglass boat hulls or decks (hereinafter referred to as
“fiberglass boat manufacturing facilities”).  Recommendations in
this CTG do not extend to facilities that manufacture solely parts of
boats (such as hatches, seats, or lockers), or boat trailers, but do not
manufacture hulls or decks of boats from fiberglass, or build molds to
make fiberglass boat hulls or decks.  If a facility manufactures hulls
or decks, or molds for hulls or decks, then the manufacture of all other
fiberglass boat parts, including small parts such as hatches, seats, and
lockers is also covered.  EPA recommends that the control approaches
discussed in section VI of this CTG apply to each fiberglass boat
manufacturing facility where the total actual VOC emissions from all
fiberglass boat manufacturing operations covered by the recommendations
in section VI of this CTG are equal to or exceed 6.8 kg/day (15 lb/day).
 An alternative equivalent threshold would be 2.7 tons per 12-month
rolling period.  Cleaning materials should be included in determining
whether total actual VOC emissions exceed this level.  If a facility has
add-on controls, then emissions before the add-on controls should be
used in determining if a facility meets this threshold.

EPA’s Recommended Control Options for Fiberglass Boat Manufacturing
Materials

EPA’s 2008 CTG recommends that the following operations are covered:

• Open molding resin and gel coat operations (these include pigmented
gel coat,

   clear gel coat, production resin, tooling gel coat, and tooling
resin);

• Resin and gel coat mixing operations; and

• Resin and gel coat application equipment cleaning operations.

EPA’s 2008 CTG recommends the following VOC reduction measures:  VOC
emission limits for molding resins and gel coats; work practices for
resin and gel coat mixing containers; and VOC content and vapor pressure
limits for cleaning materials.  Recommended VOC emission limits for open
molding resin and gel coat operations are shown in Table 1.

Table 1:  Monomer VOC Content Limitations for Open Molding Resin and Gel
Coat Operations

Materials	Application Method	Individual Monomer VOC Content or Weight
Average Monomer VOC Content Limit (weight percent)

Production Resin	Atomized (spray)	28

Production Resin	Nonatomized	35

Pigmented Gel Coat	Any Method	33

Clear Gel Coat	Any Method	48

Tooling Resin	Atomized	30

Tooling Resin	Nonatomized	39

Tooling Gel Coat	Any Method	40



Alternatively, the applicable recommended limits in Table 1 above would
be considered met if all materials of a certain type meet the applicable
monomer VOC content limit for a specific application method on a
weighted-average basis, and each resin and gel coat did not contain more
than 5 percent non-monomer VOC.  The weighted-average monomer VOC
content would be determined based on a 12-month rolling average.  A
facility would use Equation 1 found on 

p. 27 of Control Techniques Guidelines for Fiberglass Boat Manufacturing
Materials (Publication No. EPA 453/R-08-004; September 2008) to
determine weighted-average monomer VOC content for a particular open
molding resin or gel coat material.

Under the emissions averaging option, monomer VOC emissions from the
open molding resin and gel coat operations that a facility chooses to
include in this emission average option would

meet a facility-specific monomer VOC mass emission limit (12-month
rolling average) that is determined using Equation 2 found on p. 28 of
Control Techniques Guidelines for Fiberglass Boat Manufacturing
Materials (Publication No. EPA 453/R-08-004; September 2008).  All
resins and gel coats included in this option would also need to meet the
recommended non-monomer VOC content limit of 5 percent.

The CTG recommends that the emissions average be calculated on a
12-month rolling average

basis and determined at the end of every month (12 times per year).  It
further recommends that at the end of the first 12-month averaging
period and at the end of every subsequent month, a facility use Equation
3 found on p. 29 of Control Techniques Guidelines for Fiberglass Boat
Manufacturing Materials (Publication No. EPA 453/R-08-004; September
2008) to show that the monomer VOC emissions from the operations
included in the average do not exceed the emission limit calculated
using Equation 2 for the same 12-month period.

The formulas in Table 4 found on p. 30 of Control Techniques Guidelines
for Fiberglass Boat Manufacturing Materials (Publication No. EPA
453/R-08-004; September 2008) calculate monomer VOC emission rates in
kilograms of monomer VOC per megagram of resin or gel coat applied.  The
formulas for vacuum bagging with roll-out are applicable when a facility
rolls out the applied resin and fabric prior to applying the vacuum
bagging materials.  The formulas for vacuum bagging without roll-out are
applicable when a facility applies the vacuum bagging materials
immediately after resin application without rolling out the resin and
fabric. VOC% = monomer VOC content as supplied, expressed as a
weight-percent value between 0 and 100 percent.

If product performance requirements or other needs dictate the use of
higher monomer

VOC materials than those that would meet the recommended emission limits
in Table 1, a facility could choose to use add-on control equipment to
meet the emission limit. However, instead of using the mass of each
material used over the past 12 months in Equation 2, the facility would
use the mass of each material used during the control device performance
test in Equation 2 to determine the emission limit (in kg of monomer
VOC) that is applicable during the test.  If the measured emissions at
the outlet of the control device (in kg of monomer VOC) are less than
the emission limit, then the facility would be considered to have
achieved the emission limit.

Some facilities use resins to which fillers are added to achieve certain
physical properties, particularly for building molds. The resins to
which the filler is added have higher initial monomer VOC content than
standard production or tooling resins, but the addition of the filler
lowers the monomer VOC emission rate from the filled resin.  The CTG
recommends the use of Equation 5 found on p. 32 of Control Techniques
Guidelines for Fiberglass Boat Manufacturing Materials (Publication No.
EPA 453/R-08-004; September 2008) to adjust the emission rate for filled
resins under all three options recommended above for limiting monomer
VOC emissions from resins and gel coats.  If a facility is using a
filled production resin or filled tooling resin, it

would calculate the emission rate for the filled material on an
as-applied basis using Equation 5.

B.  STATE SUBMITTAL

On March 2, 2016, Pennsylvania Department of Environmental Protection
(PADEP) submitted to EPA a SIP revision concerning implementation of
RACT requirements for the control of VOC emissions from fiberglass boat
manufacturing materials.  EPA develops CTGs as guidance on control
requirements for source categories.  States can follow the CTGs or adopt
more restrictive standards.  Pennsylvania is adopting EPA’s CTG
standards for fiberglass boat manufacturing materials, including the
emission limits found in Table 1 as well as all alternative options for
calculating emissions discussed earlier in this Technical Support
Document as well as in the CTG itself.  The regulation is contained in
25 Pa. Code Chapter 129 (relating to standards for sources), and this
SIP revision adds section 129.74 (control of VOC emissions from
fiberglass boat manufacturing materials) to the Pennsylvania SIP.  In
addition to adopting the CTG standards discussed above, section 129.74
includes numerous terms and definitions to support the interpretation of
the measures, as well as work practices for cleaning; compliance and
monitoring requirements; sampling and testing; and record keeping
requirements (all included in section 129.74 of the Pa. Code)

This SIP revision also notes that the requirements of section 129.74
supersede the requirements of a RACT permit issued under sections
129.91-129.95 prior to December 19, 2015 to the owner or operator of a
source subject to section 129.74 to control, reduce, or minimize VOCs
from a fiberglass boat manufacturing process, except to the extent the
RACT permit contains more stringent requirements.  

C.  EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Pennsylvania has adopted all of the standards and requirements of the
fiberglass boat manufacturing materials CTG and is revising the
Pennsylvania SIP to reflect this addition.  Thus, the SIP revision is
approvable pursuant to sections 172(c)(1) and 182(b)(2) of the CAA.  The
SIP revision will reduce emissions of VOCs from fiberglass boat
manufacturing operations.  The maximum benefit from this addition will
be provided during the ozone season when VOCs readily combine with NOx
to form ground-level ozone.  Therefore, this revision will help
Pennsylvania attain and maintain the NAAQS for ozone.  EPA approval of
the SIP revision is recommended.

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