Boat Manufacturing MACT
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3. What does the Final Boat NESHAP Require of Emission
Sources?
The final NESHAP has various formats for the different operations
being regulated. For open molding resin and gel coat operations,
compliance with a HAP emission limit that is calculated for
a facility uses a MACT model point value equations (described
in section 4) Compliance can be demonstrated by a
facility with the HAP emission limit either by:
- Averaging
emissions with the MACT model point value equations,
- Using
HAP compliant materials
for each type of open molding operation, or
- Using an add-on control device.
The
HAP emissions limit and equivalent HAP compliant material
content limits are the same for new and existing sources.
Averaging
may
be
used for all open molding operations or only for some of
them. For those operations not included in the emissions
average,
compliance must be demonstrated with one of the alternative
provisions.
For resin operations, different HAP content limits apply
to atomized and nonatomized resinapplication methods. If
you use anadd-on control device to meet the emissions limit,
the emissions limit is calculated using the MACT model point
value equations and is in units of kilograms (kg) of organic
HAP per megagram of resin or gel coat consumed.
As stated above, a combination of compliance options for
the different resin and gel coat operations may be used within
a facility. For example, a hull production line may use several
resins and gel coats. A laminating resin that complies with
the appropriate HAP content limit can be used, but the averaging
approach for the skin coat resin and the production gel coats
can be chosen. In another example, the average of all production
resins and pigmented gel coats at a facility could be used,
but not include clear gel coat, tooling resin, and tooling
gel coat.
 Other operations regulated by the final NESHAP will be subject
to work practice requirements or HAP content limits. Resin
and gel coat mixing containers with a capacity of 208 liters (55 gallons) or
more must be covered. Routine resin and gel coat application equipment cleaning
operations must use solvents containing no more than 5 percent organic HAP, but
solvents used to remove cured resin or gel coat from equipment are
exempt. The containers used to hold the exempt solvent
and to clean equipment with cured resin and gel coat must be covered.
Carpet and fabric adhesive operations must use adhesives
containing no more than 5 percent organic HAP.
Aluminum recreational boat wipedown solvents and surface
coatings are subject to HAP content limits. Aluminum recreational
boat spray gun cleaning operations are subject to a work practice
requirement.
 Compliance
with the emissions limits in the final Boat NESHAP is
based on a 12-month rolling average except when an add-on
control device is used. At the end of every month, you determine
compliance for each operation based on the HAP content
and
material consumption data collected over the past 12 months.
When an add-on control device is used, compliance is determined
through emissions testing and subsequent monitoring.
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