06-096 C.M.R. ch. 162, § 3 - Emission Limits

Owners and operators of fiberglass boat manufacturing operations subject to this Chapter shall comply with the applicable emission limitations in Sections 3(A) through 3(D) of this Chapter by the use of one of the following options: 1) low monomer VOC content resins and gel coats; 2) emissions averaging among different operations; or 3) the use of add-on emission control devices.

A. Low monomer VOC content option

1 The monomer VOC content limits used for any open molding resin and gel coat operations subject to this Chapter and any molding operations that do not meet the definition of closed molding, such as vacuum bagging operations, shall not exceed the monomer VOC limits established in Table 1:

Table 1

Monomer Volatile Organic Compounds Limits for Open Molding Resin and Gel Coat Operations

Material	Application Method	Monomer VOC Content Limits (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

2 Alternative compliance method. The weighted average monomer VOC contents for a specific application method meets the monomer VOC content limit using Equation 1:

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Where M_i = mass of each open molding resin or gel coat used in the past 12 months in an operation, in megagrams.

VOC_i = monomer VOC content, by weight percent, of each open molding resin or gel coat used in the past 12 months in an operation.

n = number of different open molding resins or gel coats used in the past 12 months in an operation.

B. Emissions averaging option

1 Any molding resin and gel coat operations that a facility chooses to include in averaging emissions among different operations to meet a numerical monomer VOC mass emissions limit rather than complying with the monomer VOC content limits established in Section 3(A)(1) of this Chapter shall use Equation 2 to establish a facility-specific monomer VOC mass emission limit on a 12-month rolling average basis:

Equation 2

Monomer VOC Limit = 46(M_R) + 159(M_PG) + 291(M_CG) + 54(M_TR) + 214(M_TG)

Where: Monomer VOC Limit = total allowable monomer VOC that can be emitted from the open molding operations included in the average, in kilograms per 12-month period.

M_R = mass of production resin used in the past 12 months, excluding any materials that are exempt, in megagrams.

M_PG = mass of pigmented gel coat used in the past 12 months, excluding any materials that are exempt, in megagrams.

M_CG = mass of clear gel coat used in the past 12 months, excluding any materials that are exempt, in megagrams.

M_TR = mass of tooling resin used in the past 12 months, excluding any materials that are exempt, in megrgarams.

M_TG = mass of tooling gel coat used in the past 12 months, excluding any materials that are exempt, in megagrams.

The numerical coefficients associated with each term on the right side of Equation 2 are the allowable monomer VOC emission rates for that material in units of kilograms of monomer VOC per megagram of material used.

2Any molding resin and gel coating operations that a facility chooses to include in averaging emissions among different operations to meet a numerical monomer VOC mass emission limit rather than to comply with the monomer VOC content limits established in Section 3(A)(1) of this Chapter shall use Equation 3 to demonstrate that the monomer VOC mass emissions from the operations included in the average do not exceed the emission limit calculated using Equation 2 from Subsection 3(B)(1) of this Chapter for the same period. This demonstration shall be conducted at the end of the first 12-month averaging period and at the end of every subsequent month for only those operations and materials included in the average.

Equation 3

Monomer VOC emissions = (PV_R)(M_R) + (PV_PG)(M_PG) + (PV_CG)(M_CG) + (PV_TR)(M_TR) + (PV_TG)(M_TG)

Where: Monomer VOC emissions = monomer VOC emissions from open molding operations included in the average, in kilograms per 12-month period.

PV_R = weighted-average monomer VOC emission rate for production resin used in the past 12 months, in kilograms per megagram.

M_R = mass of production resin used in the past 12 months, excluding any materials that are exempt, in megagrams.

PV_PG = weighted-average monomer VOC emission rate for pigmented gel coat used in the past 12 months, in kilograms per megagram.

M_PG = mass of pigmented gel coat used in the past 12 months, excluding any material that are exempt, in megagrams.

PV_CG = weighted-average monomer VOC emission rate for clear gel coat used in the past 12 months, in kilograms per megagram.

M_CG = mass of clear gel coat used in the past 12 months, excluding any materials that are exempt, in megagrams.

PV_TR = weighted-average monomer VOC emission rate for tooling resin used in the past 12 months, in kilograms per megagram.

M_TR = mass of tooling resin used in the past 12 months, excluding any materials that are exempt, in megagrams.

PV_TG = weighted-average monomer VOC emission rate for tooling gel coat used in the past 12 months, in kilograms per megagram.

M_TG = mass of tooling gel coat used in the past 12 months, excluding any materials that are exempt, in megagrams.

3 Any molding resin and gel coat operations that a facility chooses to include in averaging emissions among different operations to meet a numerical monomer VOC emission rate limit rather than complying with the monomer VOC content limits established in Section 3(A)(1) of this Chapter shall use Equation 4 to compute the weighted-average monomer VOC emission rate for the previous 12 months for each open molding resin and gel coat operation included in the average for use in Equation 3:

Click to view image

Where: PV_OP = weighted-average monomer VOC emission rate for each open molding operation (PV_R, PV_PG, PV_CG, PV_TR, and PV_TG) included in the average, in kilograms of monomer VOC per megagram of material applied.

M_i = mass or resin or gel coat used within an operation in the past 12 months, in megagrams.

PV_i = the monomer VOC emission rate for resin or gel coat used within an operation in the past 12 months, in kilograms of monomer VOC per megagram of material applied. The equations in Table 2 shall be used to compute PV.

Table 2

Monomer Volatile Organic Compounds Emission Rate Formulas for Open Molding Resin and Gel Coat

Material	Application Method	Formula
Production resin, tooling resin	a. Atomized b. Atomized, plus vacuum bagging with roll-out c. Atomized, plus vacuum bagging without roll-out d. Nonatomized e. Nonatomized, plus vacuum bagging with roll-out f. Nonatomized, plus vacuum bagging without roll-out	a. 0.014 x (Resin VOC%)2.425 b. 0.01185 x (Resin VOC%)2.425 c. 0.00945 x (Resin VOC%)2.425 d. 0.014 x (Resin VOC%)2.275 e. 0.011 x (Resin VOC%)2.275 f. 0.0076 x (Resin VOC%)2.275
Pigmented gel coat, clear gel coat, tooling gel coat	All methods	0.445 x (Gel Coat VOC%)1.675

C. Add-on emission control option. The owner or operator of any facility with molding resin and gel coat operations choosing to use add-on emission controls instead of complying with the monomer VOC content limits established in Section 3(A) of this Chapter shall:

1 Install control equipment to meet the monomer VOC limit determined by Equation 2 in Section 3(B)(1) of this Chapter, applying the mass of each material used during the control device performance test in Equation 2 to determine the emission limit (in kilograms of monomer VOC) that is applicable during the test, instead of using the mass of each material as it is established in Section 3(B)(1) of this Chapter;

2 Monitor and record relevant control device and capture system operating parameters during the control device performance test and use the recorded values to establish operating limits for those parameters; and

3 Monitor the operating parameters for the control device and emissions capture system and maintain the parameters within the established limits.

Notes

06-096 C.M.R. ch. 162, § 3