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The proposed NESHAP apply to aluminum boat manufacturing facilities performing the operations listed below:

B. What Pollutants are Regulated by the Proposed NESHAP?

The proposed NESHAP regulate the total HAP content in the materials used in each regulated operation. The proposed NESHAP do not set limits for individual species of HAP. The HAP emitted by boat manufacturing facilities typically include styrene, MMA, toluene, xylenes, methyl chloroform (1,1,1trichloroethane), MEK, nhexane, and MIBK. However, the total HAP content limit includes all HAP listed in section 112(b) of the CAA.

C. What Do the Proposed NESHAP Require?

The proposed NESHAP have various formats for the different operations being regulated. For open molding resin and gel coat operations, you must comply with a HAP emission limit that is calculated for your facility using MACT model point value equations, which are described in section II.D., for each open molding operation.

You can demonstrate compliance with the HAP emissions limit for your facility either by (1) averaging emissions with the MACT model point value equations, (2) complying with equivalent material HAP content requirements for each type of open molding operation, or (3) using an addon control device. The HAP emissions limit and equivalent HAP content requirements are the same for new and existing sources. You may use averaging for all of your open molding operations or only for some of them. For those operations not included in the emissions average, you must comply with one of the alternative provisions.

For resin operations, different HAP content requirements apply to atomized and nonatomized resin application methods. The HAP content requirements for open molding are presented in table 2 of the proposed NESHAP. If you use an addon control device to meet the emissions limit, the emissions limit is calculated using the MACT model point value operations and is in units of kilograms (kg) of HAP per megagram (1000 kg) of resin or gel coat consumed.

As stated above, you may use a combination of compliance options for the different resin and gel coat operations within your facility. For example, a hull production line may use several resins and gel coats. The skin coat resin may comply with the HAP content requirements, while you may decide to use the averaging approach to comply by averaging between the laminating resin and production gel coats. In another example, you could include in the average all production resins and pigmented gel coats at your facility, but decide not to include clear gel coat, tooling resin, and tooling gel coat. You could also use averaging to use a mix of atomized and nonatomized resin application methods but at different HAP contents from those in table 2 of the proposed NESHAP.

Other operations regulated by the proposed NESHAP would 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 zeroHAP solvents, but solvents used to remove cured resin or gel coat from equipment would be exempt. The containers used to hold the exempt solvent and to soak the equipment with cured resin and gel coat must be covered. Carpet and fabric adhesive operations must use zeroHAP adhesives. Aluminum boat wipedown solvents and surface coatings would be subject to HAP content limits. Aluminum boat spray gun cleaning operations would be subject to a work practice requirement. The NESHAP for these operations are the same for new and existing sources. The proposed NESHAP have no averaging compliance options for these operations. Today's proposed NESHAP contain the specific requirements for each operation regulated by this proposal.

Compliance with all of the emissions limits in the proposed NESHAP are based on a 3month rolling average except when an addon 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 3 months. When an addon control device is used, compliance is determined through a onetime test and subsequent monitoring.
D. What Is the MACT Model Point Value and How Is It Used In the Proposed NESHAP?

The MACT model point value is a number calculated for each open molding operation and is a surrogate for emissions. The MACT model point value is a way to rank the relative performance of different resin and gel coat emissions reduction techniques. This approach allows you to create control strategies using different resin and gel coat emissions reduction techniques. The proposed NESHAP provide equations to calculate MACT model point values based on HAP content and application method for each material that you use. These MACT model point values are then averaged and compared to limits in the proposed NESHAP to determine if your open molding operations are in compliance.

The MACT model point values have units of kilograms of HAP per megagram of resin or gel coat applied. It is important to note that the MACT model point values are surrogates for emissions, and the MACT model point value equations are used only for determining compliance with the emissions limit for open molding operations. The MACT model point value equations should not be used in other environmental programs for estimating emissions in place of true emission factor equations.

The MACT model point value equations account only for HAP content and application method. Other factors (including curing time, part thickness, and operator technique) can have significant effects on emissions, and these factors are not accounted for in the MACT model point value equations. Determining the HAP content of materials and the method of application is relatively easy, but it is difficult to determine the other factors. Therefore, these factors are not included in the MACT model point value equations.

E. When Must I Comply With the Proposed NESHAP?

Existing boat manufacturing facilities must comply within 3 years of the date the promulgated NESHAP are published in the Federal Register. New sources that commence construction after today's date must comply immediately upon startup or by the promulgation date, whichever is later.
F. How Do I Demonstrate Compliance With the Proposed NESHAP?

Unless you are using an addon control device, you must measure and record the HAP contents of all the materials regulated by the proposed NESHAP. You may determine HAP content using EPA Method 311, but you may also use documentation provided by the material manufacturer, such as a material safety data sheet (MSDS) or HAP data sheet to show compliance. Although you may use either EPA Method 311 or the manufacturer's documentation to show compliance, EPA will use EPA Method 311 results to
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determine compliance if they differ from the manufacturer's documentation.

Compliance with the HAP content limits is based on the weighted average HAP content for each material on a 3month rollingaverage basis. Compliance is determined at the end of every month (12 times per year) based on the past 3 months of data. To determine weightedaverage HAP content, you will also need to monitor and record the amount of each regulated material used per month, as well as HAP content.

If all of the material in a particular operation meets the applicable HAP content limit, then you would not need to record the amount of material used. Likewise, you would not need to perform and record any calculations to determine weightedaverage HAP content.

For open molding resin and gel coat operations, how you show compliance will depend on which compliance option you choose. For example, if you choose to average among several open molding resin and gel coat operations, you will have greater operating flexibility, but you will also need to do more recordkeeping and calculations to show compliance than if you comply with the HAP content limits. Also, you must complete an implementation plan for the open molding operations at your facility that are included in an averaging option. The implementation plan must describe the resin and gel coat materials you plan to use, their HAP contents, and how you will apply those materials so that you are in compliance. The plan must also include calculations showing that your choice of materials and application methods will achieve compliance.

You must keep records of the HAP content of all materials that are subject to HAP content limits. You must also keep records of the amount of material used and any calculations you perform to determine compliance using weightedaverage HAP contents or the averaging option for open molding operations. Every month, you must inspect the covers required by the work practice standards for resin and gel coat mixing containers and aluminum boat coating spray gun cleaners. You must also keep records of the results of these inspections and any repairs made to the covers. All records must be kept for 5 years (at least the last 2 years of records must be kept onsite).

Today's proposed NESHAP contain the specific monitoring, recordkeeping, and reporting requirements for each operation regulated by this proposal.
G. How Do I Demonstrate Compliance If I Use an Enclosure and an AddOn Control Device?

If you use an enclosure (such as a spray booth) and addon control, you must use EPA Method 204 to prove that the enclosure is a total enclosure. If the enclosure is not a total enclosure, you must use a temporary enclosure to measure the fugitive emissions from the enclosure and the control device. Stack testing is used to determine compliance with the emissions limit. You must use either EPA Method 25A to measure emissions as total hydrocarbons (as a surrogate for total HAP) or EPA Method 18 for specific HAP.

During and after the initial performance test, you must monitor and record certain control device parameters to ensure that the control device continues to be operated as it was during the test. For example, for thermal oxidizers, you must monitor and record combustion temperature and maintain the temperature above an allowable minimum value. The monitoring requirements for several addon control devices (including absorbers, adsorbers, and condensers) are contained in 40 CFR part 63, subpart SS, and are referenced in the proposed NESHAP. For other control devices not listed in subpart SS, you must identify parameters that demonstrate proper control device operation and have these parameters approved by the EPA. Monitored operating parameters must be kept within the allowable ranges to demonstrate compliance with the control device operating requirements.
III. Summary of Environmental, Energy, and Economic Impacts A. What Facilities Are Affected by the Proposed NESHAP?

There are approximately 119 existing facilities manufacturing fiberglass boats or aluminum boats that are major sources and would be subject to the proposed NESHAP. The rate of growth for the boat manufacturing industry is estimated to be five new facilities per year for the next 5 years.

B. What Are the Air Quality Impacts?

The 1997 baseline emissions from the boat manufacturing industry are approximately 9,000 Mg/yr (9,920 tons/yr). The proposed NESHAP would reduce HAP from existing sources by 3,220 Mg/yr (3,550 tons/yr) from the baseline level, a reduction of 36 percent. Table 2 shows the amount of HAP reduced by each type of operation.
Table 2.National Baseline Emissions and Emissions Reductions for Each Type of Operation (1997 Data) Baseline emissions Potential emissions reductions Operation Percent of Mg/yr total Mg/yr Percent Production resin............................................ 5,320 59.2 2,020 38 Tooling resin............................................... 80 0.9 30 43 Pigmented gel coat.......................................... 2,440 27.0 330 14 Clear gel coat.............................................. 190 2.1 5 2 Tooling gel coat............................................ 40 0.4 7 19 Closed molding resin........................................ NE NE NE NE Resin and gel coat mixing................................... NE NE NE NE Fiberglass application equipment cleaning solvents.......... 130 1.5 130 100 Carpet and fabric adhesives................................. 543 6.0 540 100 Aluminum Wipedown Solvents.................................. 60 0.7 40 65 Aluminum Boat Surface Coatings.............................. 190 2.1 100 54 Totals................................................ 9,000 ........... 3,223 36 NE means ``not estimated.''

The proposed NESHAP will not result in any increase in other air pollution emissions. While combustion devices can result in increased sulfur dioxide and oxides of nitrogen emissions, we do not expect anyone to comply by
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installing new combustion devices during the next 5 years.

C. What Are the Water Quality Impacts?

We estimate that the proposed boat manufacturing NESHAP will have no adverse water quality impacts. We do not expect anyone to comply by using addon control devices or process modifications that would generate wastewater.

D. What Are the Solid and Hazardous Waste Impacts?

We estimate that the proposed NESHAP will decrease the amount of solid waste generated by the boat manufacturing industry by approximately 360 Mg/yr (400 tons/yr). The decrease in solid waste is directly related to switching to nonatomized resin application equipment (i.e., flowcoaters and resin rollers). Switching to flowcoaters results in a decrease in overspray because of a greater transfer efficiency of resin from flowcoaters to the part being manufactured. A decrease in resin overspray consequently reduces the amount of waste from disposable floor coverings, cured resin waste, and personal protective equipment (PPE) for workers. Disposable floor coverings are replaced on a periodic basis to prevent resin buildup on the floor. We estimate that solid waste generation of floor coverings will decrease by approximately 320 Mg/yr (350 tons/yr), and that cured resin solid waste will decrease by approximately 45 Mg/yr (50 tons/yr).

Decreased overspray from flowcoaters will result in a decreased usage of PPE, which also consequently reduces the amount of solid waste. Workers who use flowcoaters typically wear less PPE than when using spray guns because of the reduced presence of resin aerosols and lower styrene levels in the workplace. Because we did not have information on the many different types of PPE currently used, we did not estimate this decrease in solid waste.

Some facilities that switch from spray guns to flowcoaters may have a small increase of hazardous waste from the used flowcoater cleaning solvents. However, most facilities will not see an increase, and the overall impact on the industry will be small relative to the solid waste reductions. Nearly all flowcoaters require resin and catalyst to be mixed inside the gun (internalmix) and must be flushed when work is stopped for more than a few minutes. Externalmix spray guns do not need to be flushed because resin is mixed with catalyst outside the gun. Facilities that switch from externalmix spray guns to flowcoaters will use more solvent. Solvent usage should not change at facilities switching from internalmix spray guns to flowcoaters.

The most common flushing solvents are acetone and waterbased emulsifiers. Only a couple of ounces of solvent are typically needed to flush the mixing chamber and nozzle of flowcoaters and internalmix spray guns. We have observed during site visits that this small quantity of solvent is usually sprayed into the air or onto the floor coverings and allowed to evaporate.

The EPA does not have adequate data to predict the potential solvent waste impact from switching to flowcoaters. The magnitude of the impact depends on the type of gun currently used (internal or externalmix), the frequency of flushing, and the type of solvent used. However, because of the small amount of solvent used, and since most is allowed to evaporate, we believe the overall solvent waste increase will be small compared to the solid waste reductions.

E. What Are the Energy Impacts?

We estimate that energy consumption for new and existing facilities will not increase. No new or existing facilities are expected to install addon control devices to comply with the proposed NESHAP in the first 5 years after promulgation. One facility currently uses a thermal oxidizer to control some of their styrene and MMA emissions from fiberglass boat manufacturing operations. No increase in energy use is anticipated to comply with the proposed NESHAP.

F. What Are the Cost Impacts?

We estimate that nationwide annual compliance costs for the existing facilities will be $14 million. This estimate includes annualized capital costs and increased material costs for purchasing more expensive, lowerHAP materials. Annual costs also include monitoring, recordkeeping, and reporting costs. The estimated annual cost of reduced HAP is $4,350/Mg ($3,950/ton).

Table 3 shows the estimated costs to reduce emissions from the operations at the 119 major source boat manufacturing facilities regulated by the proposed NESHAP.
Table 3.Cost Impacts
Nationwide annual costs Type of operation (millions) in 1998 dollars Production resin (including nonspray equipment)......... 4.9 Pigmented gel coat...................................... 2.1 Clear gel coat.......................................... 0.05 Tooling resin........................................... 0.9 Tooling gel coat........................................ 0.1 Resin and gel coat new product testing cost............. 0.5 Fiberglass application equipment cleaning............... 0.3 Resin and gel coat mixing............................... 0.04 Closed molding resin.................................... 0 Aluminum and fiberglass boat carpet and fabric adhesives 2.5 and application equipment..............................
Aluminum wipedown solvent............................... 0.03 Aluminum boat surface coating........................... 1.0 Monitoring, recordkeeping and reporting costs........... 1.6
Total............................................. 14

The capital costs would be for purchase of new resin application equipment, resin mixer covers, and adhesive application equipment. The estimated cost of new resin application equipment (flowcoaters) is $6,000 per unit (includes flowcoater, hoses, and resin and catalyst pumps). The estimated cost of new adhesive
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application equipment is also approximately $6,000 per unit. The resin and gel coat mixer covers will be approximately $180 per year per container.

No capital costs are predicted for mold construction or aluminum boat surface coating operations.

G. What Are the Economic Impacts?

The EPA prepared an economic impact analysis to evaluate the primary and secondary impacts of the proposed NESHAP on the boat manufacturing market, consumers, and society. Because the
characteristics of boats vary greatly throughout the industry, we evaluated the market by assessing the impacts on six separate market segments of the industry, including: outboard boats, inboard runabouts/ sterndrive, inboard cruisers/yachts, jet boats/personal watercraft, sailboats, and canoes. The total annualized social cost (in 1994 dollars) of the proposed NESHAP on the industry is $13.0 million, which is 0.2 percent of total baseline revenue. Generally, the analysis indicates a minimal change in market prices and quantity of boats sold. Imports will increase negligibly, with a corresponding decrease in exports. The analysis also suggests a loss (at the maximum) of 48 employees out of the 51,500 employees in the industry. The impacts on specific market segments are summarized in the table below. Table 4.Economic Impact of Proposed NESHAP on Boat Market Segments Change in Change in market Boat market segment price output (percent) (percent) Outboard Boats................................ 0.1 0.3 Inboard Runabouts/Sterndrive.................. 0.1 0.1 Inboard Cruisers/Yachts....................... 0.0 0.0 Jet Boats/Personal Watercraft................. 0.0 0.0 Sailboats..................................... 0.1 0.2 Canoes........................................ 0.1 0.1

The analysis also predicts the number of facilities that would close as a result of the cost of complying with the proposed NESHAP. The EPA used market level information on total predicted change in quantity to infer how many plants would close if the quantity decrease was borne entirely by one (or more) facility. For example, if the market analysis predicts that 1,000 fewer boats are produced and the average facility produces 500 boats, then the impact is equivalent to two facility closures. Using this approach, the predicted reduction in quantity did not equal even one facility closure in any of the six market segments. While this does not mean that no facilities will close as a result of the proposed NESHAP, it does indicate that the proposed NESHAP have minimal total impacts, and that any facility closure will likely be the result of poor baseline cost conditions rather than a direct result of the compliance burden.
IV. Rationale for Proposed NESHAP

A. How Did EPA Determine the Source Category To Regulate?

The proposed NESHAP applies to fiberglass boat and aluminum boat manufacturing facilities that are located at major sources of HAP. Section 112(c) of the CAA directs us to list each category of major source emitting any HAP listed in section 112(b). Boat manufacturing (major sources only) was included on the initial list of source categories published on July 16, 1992 (57 FR 31576). The initial notice of the source category list stated that we would refine category descriptions during the rulemaking process, based on additional information available.

We redefined the category to include aluminum boat manufacturing facilities (64 FR 63025, November 18, 1999). The initial source category definition included only fiberglass boat manufacturing operations. We added aluminum boat manufacturing facilities to the source category because many of these facilities are major sources of HAP. Aluminum boats are defined as noncommercial, nonmilitary aluminum boats. Aluminum commercial and military boats are not included in the source category because the HAPemitting process in the construction of these boats (surface coatings) is regulated by the shipbuilding and repair NESHAP (40 CFR 63, subpart II).
B. What Pollutants Are Regulated Under the Proposed NESHAP?

The proposed NESHAP regulate total HAP, rather than individual HAP compounds. A standard for total HAP simplifies compliance and enforcement, compared with standards for individual HAP compounds. Moreover, the proposed NESHAP will affect the formulation of chemical products used by the industry. It is not reasonable to regulate the content of individual constituents in these complex mixtures. Styrene is the HAP emitted in the largest magnitude (about 87 percent of emissions). Other HAP emitted from boat manufacturing facilities include MMA, methylene chloride (dichloromethane), toluene, xylenes, methyl chloroform (1,1,1trichloroethane), nhexane, and MIBK. C. What Is the ``Affected Source'' and How Did EPA Select the Operations To Be Regulated by the Proposed NESHAP?

The affected source is the combination of all regulated operations at a single boat manufacturing facility. The following regulated operations are typically performed at fiberglass boat manufacturing facilities and are part of the affected source:

Carpet and fabric adhesive operations are performed at both fiberglass boat and aluminum boat manufacturing facilities and are part of the affected source at those facilities.

The following regulated operations are typically performed at aluminum boat manufacturing facilities and are part of the affected source:

These are the typical operations found at fiberglass boat and aluminum boat manufacturing facilities, and we were able to determine MACT for these operations. If a single facility
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manufactures both aluminum boat and fiberglass boats, the facility is a single affected source.

Mold sealing and release agents, mold stripping and cleaning solvents, solvents used to clean cured resin and gel coat from application equipment, wood coatings, fiberglass hull and deck coatings, and antifoulant coatings are not covered by the proposed NESHAP. See section IV.H. for the rationale for why these operations are not regulated by the proposed NESHAP.

We defined the affected source as the combination of all of these operations at a site to provide compliance flexibility. This broad source definition allows a manufacturer to determine compliance by averaging the HAP content of different products used throughout the facility within certain defined operations, and to use different application techniques as needed to meet product quality
specifications. This approach is consistent with the way that the HAP content and application data were analyzed to determine the MACT floor. D. What Is a New Affected Source?

A new affected source is any fiberglass boat or aluminum boat manufacturing facility that meets both of these criteria:

We selected this broad definition of new source for two reasons. First, the MACT for new and existing sources is the same, so there is no difference in emission control requirements for new and existing sources. Second, we concluded that it would be unreasonably costly to demonstrate compliance separately for both new and existing source operations that are located at the same site. Because the equipment is easily portable, it can be difficult to define exactly what would constitute a new line or operation. Also, it would be burdensome to monitor and record equipment and material usage for separate operations that were considered new and existing because the equipment is portable, and material is often dispensed from centralized bulk storage containers.

Although some sources might be required to achieve compliance earlier under a narrower new source definition, the small emissions reductions do not justify the additional longterm compliance burden. E. How Did EPA Determine the MACT Floor for Existing Sources?

We determined separate MACT floors for each type of boat manufacturing operation based on data collected from about onehalf of the major source boat manufacturers. We received data through questionnaire responses from 54 fiberglass and 13 aluminum boat manufacturers, site visits to 10 boat manufacturers (9 fiberglass and 1 aluminum), and through telephone contacts and operating permits for several more boat manufacturers. The data collected from the fiberglass boat manufacturers represent both large and small companies, as well as power and sailboat manufacturers who build vessels ranging in size from small runabouts to large, luxury yachts. Therefore, we believe the data are representative of the fiberglass boat industry segment. Our database also includes all the major source aluminum boat manufacturers known to us; therefore, the database also accurately represents this industry segment.

Using the data collected from boat manufacturers, we determined separate existing source MACT floors for each type of boat manufacturing operation (e.g., open molding operations, carpet and fabric adhesives operations). For each operation, the facilities were ranked from lowest to highest emitting. Emissions were computed as a facilitywide average for each operation to account for the variety of materials within each operation that are required to construct a boat. For open molding resin operations (production and tooling), we estimated the HAP using the MACT model point value equations. This approach takes into account the combined effect of application method and the HAP content of the resins used, but is not an estimate of actual HAP to the atmosphere.

To determine MACT floors for the production resin operations, we evaluated open molding and closed molding as separate types of emission sources. Closed molding is a loweremitting operation than open molding, but at this time has not been demonstrated to be generally applicable for all types of boats. Boat manufacturers typically use closed molding to achieve specific product qualities, such as two finished sides, higher fibertoresin ratios, or higher production levels that cannot be achieved with open molding. Therefore, closed molding operations were not used in setting the MACT floor for open molding.

Also, we determined MACT floors separately for fiberglass and aluminum boat manufacturers because the regulated operations at these facilities differ. The one exception was for carpet and fabric adhesive operations, where the MACT floor analysis was based on a combined data set. Fiberglass and aluminum boat manufacturers both have carpet and fabric adhesive operations and use the same adhesives.

We determined MACT floors based on the median facility of the lowestemitting 12 percent for production resin, pigmented gel coat, tooling resin, tooling gel coat, resin and gel coat application equipment cleaning and carpet and fabric adhesives. For clear gel coat, closed molding resin, aluminum boat surface coatings, aluminum coating spray gun cleaning operations, and aluminum wipedown solvents, we used the median of the five lowestemitting facilities because we had data on fewer than 30 sources. We selected the median facility rather than the arithmetic average of the lowestemitting facilities in order to represent the performance of an actual facility.

A more detailed summary of the results of the MACT floor analysis, the data and the considerations used to determine the MACT floors for the boat manufacturing source category can be found in Docket No. A95 44.

F. How Did EPA Determine the MACT Floor for New Sources?

We believe that the existing source MACT floor also represents the new source floor. The existing source MACT floor represents the greatest degree of emissions reductions that is achievable under all circumstances within each particular operation regulated by the proposed NESHAP.

For new sources, the CAA requires the MACT floor to be based on the degree of emissions reductions achieved in practice by the best controlled similar source. A variety of chemical materials and application methods are available for each operation within the boat manufacturing source category. The suitability of these materials and methods depends on several product and manufacturing requirements. These requirements typically include part size and shape, strength, durability, production volume and schedule, product mix, color, and worker safety.

Therefore, an emission control option (e.g., HAP content and application method) that is applicable at one facility with a particular mix of these requirements may not be applicable at another facility with different requirements. While some facilities are using lowerHAP materials and techniques than represented by the existing source MACT floor, we do not
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believe that the lowestemitting options are universally applicable to all new boat manufacturers. Sometimes, the lowerHAP materials are used to produce particular colors and geometric shapes that do not represent the range of boats that are manufactured. Accordingly, the lowestHAP emitting facilities may not be using materials or techniques that can be used by new sources in all circumstances.

Some facilities do use the lowerHAP materials or techniques for particular products. However, we have no data to precisely define the particular combination of requirements where these loweremitting options can be used and still maintain the minimum required strength and durability requirements of these products. These facilities, consequently, do not represent the new source MACT floor, and we are unable to establish subcategories for purposes of determining a more stringent MACT floor for new sources. The existing source MACT floor level of control is universally applicable to all boat manufacturers because it has been demonstrated at several different facilities that produce a range of products that represent the industry, and that use different combinations of materials and methods to achieve the emissions reductions. Therefore, the existing source MACT floor is achievable by all new sources and also represents the new source floor. G. Did EPA Consider Control Options More Stringent Than the MACT Floor?

Because no control options more stringent than the MACT floor are feasible for new and existing sources, we have determined that MACT for new and existing sources is the MACT floor level of control. We considered three potential options for MACT that might be more stringent than the MACT floors, but found that these options were not achievable. The options we considered were lowerHAP materials, zero HAP materials and addon control devices. The following analysis applies equally to new and existing source MACT.

As noted in the discussion of the new source MACT floor in the previous section, some facilities use materials with HAP contents lower than the new and existing source MACT floor. However, as also noted in that discussion, EPA does not have the data to define subcategories in which these lowerHAP materials can be used. Therefore, these lowerHAP materials are not a viable option more stringent than the MACT floor for new or existing sources.

For carpet and fabric adhesives, as well as resin and gel coat application equipment cleaning solvents, the new and existing source MACT floor is zeroHAP materials. In these two cases, zeroHAP materials are also MACT for new and existing sources because no more stringent level of control is achievable.

For the other operations regulated by the proposed NESHAP, no zero HAP substitutes are currently available. No zeroHAP substitutes for polyester and vinylester resins or gel coats have been demonstrated for largescale production boat manufacturing. The zeroHAP alternatives for aluminum wipedown solvents, such as acetone, are too volatile and flammable for this operation. No waterborne coatings or powder coatings have been demonstrated as substitutes for the solventborne coatings currently used in aluminum boat surface coating operations.

We also evaluated addon control devices. We are aware of one facility using a thermal oxidizer to control HAP from resin and gel coat operations in the manufacture of small jet boats. Thermal oxidizers are generally effective controls for HAP emission sources.

The experience of the jet boat facility with thermal oxidation suggests that thermal oxidation has not been effectively demonstrated as a control option for boat manufacturing. During the MACT analysis, no emission test data were available to us or to the State permitting authority to confirm the performance of this control device. Also, after several years of operation, the facility had not received an operating permit with an enforceable emission limit and was still operating under an extension of their construction permit.

Moreover, the facility with the thermal oxidizer uses restricted airflow to capture concentrated HAP near the surface of the molds. The restricted airflow management is feasible at this facility because the facility is dedicated to the construction of only two models of small jet boats, 4.4 and 5.5 meters (14.5 and 18 feet, respectively) long. The restricted airflow management was implemented with the intention to use robotics to apply some of the resin and gel coat.

The restricted airflow management as practiced at this facility would not be suitable for other facilities in the industry. All other facilities produce a variety of products and parts and must have the operational flexibility to change product mix over time. Restricted airflow management would not be feasible in operations where workers apply the resin and gel coat, and a range of different types of boats are produced.

Accordingly, we have concluded that thermal oxidizers have not been demonstrated for this industry. While theoretically feasible, we have no data to demonstrate the cost or the effectiveness of the thermal oxidizer at the air flow rates and HAP concentrations that exist at typical boat manufacturing plants.
H. Why Are Some Boat Manufacturing Operations Not Being Covered by the Proposed NESHAP?

The proposed NESHAP would not regulate the following operations:

FOR FURTHER INFORMATION CONTACT Mark Morris, Organic Chemicals Group, Emission Standards Division (MD13), U.S. EPA, Research Triangle Park, North Carolina 27711, (919) 5415416, morris.mark@epamail.epa.gov. For public hearing information contact Maria Noell, Organic Chemicals Group, Emission Standards Division (MD13), U.S. EPA, Research Triangle Park, North Carolina 27711, (919) 5415607.