Aug. 23, 2004 is the fast-approaching compliance deadline for existing fiberglass boatbuilders who are subject to Boat Manufacturing Maximum Achievable Control Technology (MACT) regulations. Now is the time to plan emission control strategies and develop recordkeeping and facility inspection procedures. This column explains regulatory deadlines and provides tips for complying with MACT standards in 40 Code of Federal Regulations (CFR) Part 63, Subpart VVVV.

Information presented here applies to fiberglass boatbuilding facilities that 1) began construction by July 14, 2000; 2) are a major source of hazardous air pollutants (HAPs); and 3) use only low-emitting materials and application methods to meet open-molding MACT standards. "Major sources" are facilities that have the potential to emit 10 tons per year (tpy) of a single HAP or 25 tpy of combined HAPs (9.1 megagrams of a single HAP or 22.7 megagrams of combined HAPs).

Although Aug. 23, 2004 is the boat manufacturing MACT compliance deadline, facilities using low-emitting materials have an extra year before they are required to demonstrate compliance with emission limits. This gives facilities time to modify operations if initial emissions are too high. However, when Aug. 23, 2005 rolls around, facility operation data averaged over the previous 12 months must comply with emission limits. Thereafter, compliance must be determined each month, based on a 12-month rolling average of HAP content data.

Beginning on Aug. 23, 2004, facility personnel need to start recording compliance data shown in the accompanying table. Most of the data will be used to demonstrate compliance with MACT emission limits. In addition, inspection data documents compliance with required work practices. For example, resin and gel coat mixing containers must be visually inspected at least once per month to ensure that container covers have no visible gaps.

Before August 2004, facility personnel should identify every regulated material and determine its organic HAP content on a weight-percent basis. MACT regulations in §63.5758 provide five methods for determining organic HAP content. Most of the methods involve material testing, using analytical methods approved by the U.S. Environmental Protection Agency (EPA). However, the least-expensive approach is to use vendor-supplied information. Vendors may provide content information in terms of total organic HAP or on a chemical-by-chemical basis.

If specific chemical contents are listed in vendor information, you should first identify which chemicals are organic HAPs. To determine total organic HAP content, add up the HAP content percentages for every organic HAP chemical that accounts for 1.0 percent or more of the material. However, if the organic HAP is included on a list of carcinogens specified in 20 CFR §1910.1200(d)(4), you must add it into the total HAP calculation if the HAP accounts for only 0.1 percent by weight or more. If you have any questions concerning the organic HAP makeup of a material, call the material manufacturer and request more information.

After obtaining HAP content information, record the data along with the product name. Then compare the organic HAP content of all resins and gel coats to limits given in Table 2 to Subpart VVVV. Note that applicable limits for production resins and tooling resins depend on the application method being used, either atomized or nonatomized application. If each and every resin and gel coat organic HAP content falls below applicable limits, MACT compliance is simple. No further calculations are required to determine compliance because each resin and gel coat is compliant by itself.

When multiple resins or gel coats are used, a weighted average organic HAP content can be calculated for each combination of material type and application method. For example, all operations involving atomized application of production resin can be averaged together on a material-weighted usage basis. If 3,000 lb of 27 percent HAP and 2,000 lb of 29 percent HAP are applied using spray guns, the material-weighted average is 27.8 percent. This is slightly below the 28 percent limit given in Subpart VVVV's Table 2. Detailed instructions for compliant material averaging calculations are found in §63.5713.

If facility operations do not meet Subpart VVVV Table 2 limits, another compliance option is available. This option is based on a wider application of emission averaging across facility operations and involves point value calculations. These complicated calculation procedures are set forth in §63.5710. One advantage of point value calculations is the ability to average organic HAP content across resins and gel coats, as well as across different material application methods. If gel coat HAP contents exceed limits in Subpart VVVV's Table 2 but resin HAP contents fall below Table 2 limits, point value calculations may demonstrate facility-wide compliance.

Facilities can use both methods to meet MACT. A facility may base compliance on individually compliant materials in some operations while using point value calculations to demonstrate compliance for other operations. If point value calculations are used by a facility, it must develop and submit an implementation plan explaining which facility operations are included in the emission average.

Point value calculations are too complex to be described here. Fortunately, a software tool that automates point value calculations is available on EPA's Web site at www.epa.gov/ttn/atw/boat/boatpg.html. The "computation spreadsheet" also performs emission averaging calculations for materials that meet Subpart VVVV Table 2 HAP content limits on a group basis. This software and its user's manual were described in a previous "Composites & Compliance" column ( see CT August 2003 , p. 9).

Facility personnel should conduct a compliance trial run by late September 2004, based on the facility's operations during the first month following Aug. 23, 2004. In addition to providing an early indication of the facility's eventual compliance status, this exercise also will identify any gaps in recordkeeping. Facilities using point value calculations also should develop a draft copy of the implementation plan, which will be due on Sept. 21, 2005.

Although not required by Subpart VVVV regulations, continuing to calculate compliance each month using operational data going back to Aug. 23, 2004 ensures that there will be no surprises when official compliance reports must be submitted. With 13 full months between the initial compliance deadline and submission of official compliance demonstrations, boatbuilders have every opportunity to meet MACT.

Author's Note: As mentioned in February's "Composites & Compliance" column, this month's column was slated to explain EPA's eight-hour ozone implementation rule. However, due to schedule slips at EPA, the ozone implementation rule will not be finalized until Summer 2004.