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Boat builders EH&S Regulatory Update Nashville, TN December 5-7, 2005

Boat builders EH&S Regulatory Update Nashville, TN December 5-7, 2005. John McKnight, Director Environmental & Safety Compliance. Major Issues to Watch for 2006. Deadline is Coming for MACT Compliance Reports What’s Happening with Styrene?

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Boat builders EH&S Regulatory Update Nashville, TN December 5-7, 2005

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  1. Boat builders EH&S Regulatory UpdateNashville, TNDecember 5-7, 2005 John McKnight, Director Environmental & Safety Compliance

  2. Major Issues to Watch for 2006 • Deadline is Coming for MACT Compliance Reports • What’s Happening with Styrene? • Evaporative Emissions Requirements for 2007 and beyond

  3. What Is Styrene? • Clear, colorless liquid • Benzene ring compound • Found naturally in fruits, such as strawberries • Used in food packaging, electronics, tire manufacturing, reinforced plastic manufacturing (i.e. boats)

  4. What are the health effects of styrene?

  5. How does OSHA & EPA consider styrene? • OSHA • Material Safety Data Sheets • Permissible Exposure Limit • EPA • Toxic Release Inventory • Hazardous Air Pollutant • Volatile Organic Compound • IRIS Database

  6. U.S. EPA IRIS • Integrated Risk Information System (IRIS) • EPA electronic database which classifies health hazard data on chemicals • Styrene review (update) began in 1998

  7. What does IRIS do? • IRIS styrene assessment looks at non-cancer health effects as well as evaluating cancer potential • IRIS report will include reevaluations of the inhalation reference concentration (RfC) number for styrene, as well as the oral reference dose (RfD) number • Will also include EPA’s first formal carcinogenicityclassification for styrene

  8. 2. Composition/Information on Ingredients Ingredient CAS No Percent Hazardous --------------------------------------- ------------ ------------ --------- Styrene 100-42-5 90 - 100% Yes 3. Hazards Identification Emergency Overview-------------------------- DANGER! FLAMMABLE LIQUID AND VAPOR. HARMFUL IF SWALLOWED, INHALED OR ABSORBED THROUGH SKIN. CAUSES IRRITATION TO SKIN, EYES AND RESPIRATORY TRACT. AFFECTS CENTRAL NERVOUS SYSTEM, LIVER AND REPRODUCTIVE SYSTEM.J.T. Baker SAF-T-DATA(tm) Ratings (Provided here for your convenience) ----------------------------------------------------------------------------------------------------------- Health Rating: 3 - Severe (Cancer Causing) Flammability Rating: 3 - Severe (Flammable) Reactivity Rating: 2 - Moderate Contact Rating: 2 - Moderate Lab Protective Equip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD; PROPER GLOVES; CLASS B EXTINGUISHER Storage Color Code: Red (Flammable) -----------------------------------------------------------------------------------------------------------

  9. What may change in 2007? • EPA plans to update the IRIS database for styrene • Styrene could be listed as a suggested or likely human carcinogen.

  10. What would this mean to boat builders? • Greater employee and neighbor concerns • Lower fence line limits • Residual risk • State OSHA PEL

  11. What is NMMA doing to assist boat builders? • ACMA / NMMA / SIRC • Talking to EPA • SIRC PATG • Education information • Communication information • Styrene Workshops • www.styrene. org

  12. Evaporative Emissions from Boat Fuel Systems • What EPA is Planning to Propose • Results of the NMMA Test Program • Carbon canisters • Fuel, Fill and Vent Hoses • California 2007 SD/I fuel hose requirements

  13. Evaporative Emissions from Boats Refueling and spillage Diurnal, hot soak, and running loss Permeation through fuel tank and hoses

  14. Rulemaking Plans • Scope • exhaust and evaporative emissions • gasoline-powered engines/vessels • build on 2002 NPRM • Schedule • anticipate proposal this spring • final rule ~ 1 year later • Marine Evaporative Emissions • tank permeation • hose permeation • diurnal breathing losses

  15. Rulemaking Process • publish “Final Rulemaking” Implement FRM • gather information • meet with stakeholders • publish “Notice of Proposed Rulemaking” • lead time • certification Public Comment NPRM • public hearing • written comment period Pre- Proposal

  16. Tank Permeation Control • High Density Polyethylene (HDPE) • portable, PWC, and some installed fuel tanks • fluorination, sulfonation, Selar, multi-layer, alternative materials • Cross-Link PE • installed fuel tanks (low volume production) • barrier coating, multi-layer roto-molding, alternative materials, alternative constructions • Fiberglass • built-in installed fuel tanks • multi-layer construction • (Metal does not permeate)

  17. Hose Permeation Control • Multi-layer fuel hose • barriers used today in non-marine applications (Teflon, THV, FKM, etc.) • marine barrier hose available as well • can add barriers to current marine constructions • > 95% reduction in permeation possible • EPA Evaluating contribution vs. cost barrier layer reinforcement rubber cover

  18. Diurnal Breathing Loss Control • Portable fuel tanks • currently have manual seal without pressure relief • could use self sealing caps (1 way valve) • PWC • already have sealed systems with pressure relief valves • 1 psi ~ 50% reduction in-use from an open system • Larger fuel tanks • carbon canister in vent line • > 60% reduction with passive purge • negligible back-pressure • other technologies include • bladder fuel tanks • active purge canisters

  19. NMMA Summer 2005 Test Program • Carbon Canister Safety and Durability Study • Marine Hose Permeation Study • Fuel Hose • Fill Hose • Vent Hose

  20. Test Cases

  21. BWC Apparatus Temp Meter Purge Flow meter Vent Bubble Meter Butane Feed Flow meter Vacuum Pump Butane Vent Flow meter Butane Cylinder

  22. Summary • Testing showed no degradation in capacity due to moisture or liquid gasoline exposure • Regenerable carbon capacity was maintained throughout test period • Carbon capacity was unaffected by physical stresses associated with marine use • Carbon canisters did not affect performance of boats

  23. Future Work • Carbon canisters will be removed from boats and tested for particle size distribution, heel analysis, and capacity • Two canisters will remain on boats for long-term testing

  24. SAE J 1527 (Marine Hoses) specifies a weight loss method for measuring permeation. Our measurement configuration is shown below.

  25. Liquid Hose Grady White - MPI A1 3/8” ID Yamaha Four Winns Tiara - Shields A1 ½” ID Parker Advanced Material Tempo B1

  26. Our Fill Hose test configuration is shown with the 5 gallon container half-full of Fuel E10 is used.

  27. Fill Hose Grady White MPI Hard Wall A2 1 ½” ID Yamaha Four Winns Tiara MPI Hard Wall A2 2” ID Parker Advanced Material - NOVAFLEX

  28. Our Vent Hose configuration is shown in the photo. The drum is half-full of E10 fuel. A canister with marine grade carbon is vented to atmosphere

  29. Vent Hose Grady White - Shield B-Acol B2 Four Winns Yamaha Tiara - Shield Fire-Acol A1 Crestliner - MPI A1 Parker - Advanced Material

  30. Hose Permeation Summary • Current hose appears to be meeting new standard • Comparison tests of E10 and CE10 have been completed • Similar results with CE 10, slightly higher, but still well below 15 g/m2

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