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? Evaporative Emissions Requirements for 2007 and beyond

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)

What are the health effects of styrene?

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

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

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 carcinogenicity classification for styrene

2. Composition/Information on Ingredients Ingredient CAS No Percent Hazardous Styrene % 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)

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.

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

What is NMMA doing to assist boat builders? ACMA / NMMA / SIRC Talking to EPA SIRC PATG –Education information –Communication information Styrene Workshops org

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

Evaporative Emissions from Boats Refueling and spillageDiurnal, hot soak, and running loss Permeation through fuel tank and hoses

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

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

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)

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 rubber barrier layer cover reinforcement

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

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

Test Cases Boat ManufacturerTypeFuel Tank VolumeCanister VolumeTest Date(s) Four Winns17’ Open Bow24 gallon1.0 liter8/25 Four Winns18’ Open Bow32 gallon1.0 liter Crestliner17’ Open Boat24 gallon1.0 liter9/20 Crestliner18’ Open Boat31 gallon1.0 liter Crestliner23’ Pontoon25 gallon1.0 liter9/20 Crestliner23’ Pontoon25 gallon1.0 liter Four Winns19’ Open Bow50 gallon1.5 liter8/25 Four Winns21’ Open Bow50 gallon1.5 liter Four Winns27’ Cruiser85 gallon2.5 liter Century26’ Sportfisherman150 gallon4.0 liter8/16 Century26’ Offshore150 gallon4.0 liter Grady White23’ Offshore150 gallon4.0 liter9/16 Grady White30’ Offshore(2) 150 gallon4.0 liter8/4 & 9/15 Century29’ Sportfisherman300 gallon(2) 3.5 liter9/7

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

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

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

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

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

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

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

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

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

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/m 2