TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendments to — COMAR 26.11.15 C(4) Standards 

for Adhesive and Sealant Application for Specialty 

Electronic Systems and Subsystems for Defense and 

Homeland Security

Purpose of Action 

The purpose of this action is to repeal the general emission standard for adhesives under 

COMAR 26.11.19.15C(4) and replace it with the proposed source-specific VOC Reasonably 

Available Control Technology (RACT) emission limitation for the application of adhesives and 

sealants to specialty electronic systems and subsystems for defense and homeland security. This 

source category is exempt from requirements under COMAR 26.11.35. 

Background 

In 2008, Maryland established standards for adhesives and sealants under COMAR 26.11.35, 

“Control of VOC Emissions from Adhesives and Sealants”, based on the 2006 Ozone Transport 

Commission (OTC) model rule. The OTC rule was developed using the 1998 RACT and a best 

available retrofit control technology determination by the California Air Resources Board as 

guidance. 

Adhesives, sealants, adhesive primers, and sealant primers are used in manufacturing, packaging, 

construction, and installation of disparate materials such as metal, wood, rubber, plastic, 

ceramics, fiberglass and composites. An adhesive is any material used to bond two surfaces. A 

sealant is a material with adhesive properties that is used primarily to fill and seal durably, 

openings between two surfaces. The standards in COMAR 26.11.35 reflect the large scale use of 

adhesives and sealants for different materials. 

Adhesives used for specialty electronic systems and subsystems for defense and homeland 

security are developed, tested and manufactured on a small scale. The adhesives are unique and 

vary significantly, which makes it very difficult to establish any VOC content standards. In lieu 

of specific emission standards for VOCs in this source category, a VOC RACT emission 

limitation is established in this regulation. 

Sources Affected and Location 

These proposed amendments affect developers, testers and manufacturers of specialty electronic 

systems and subsystems for defense and homeland security. Affected sources are located in 

Ozone and PM nonattainment areas in Maryland. 

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Requirements 

This amendment establishes a RACT emission limitation for specialty electronic systems and 

subsystems for defense and homeland security. The amendment limits the discharge into the 

atmosphere to not more than 25 pounds per day of VOC from adhesive and sealant application, 

averaged over a monthly period. 

Basis for Emission Standard 

In the development of electronic systems, connecting the terminations of integrated circuit 

packages with patterns on the printed circuit boards is extremely important. A solder paste is 

used generally with a stencil along with methods like screening and dispensing. A majority of 

defects in electronic assemblies are caused due to problems in printing process or due to defects 

in the solder paste. In electronics systems design and development, different types of materials, 

processes and characteristics have to be tried before finalizing the specifications of the paste. 

Constant monitoring of the materials is required to maintain integrity of the process. Specialty 

electronic systems and subsystems for defense and homeland security have very limited 

tolerances and monitoring of materials becomes even more important for higher reliability. 

Varying material characteristics can have a significant impact on performance of electronic 

systems. Limiting the VOC content of solvents used has the potential to affect the performance 

characteristics of systems and subsystems for defense and homeland security. 

The Department’s analysis has shown that it is not cost effective to require controls at the 

average 25 pounds per day emission level. 

Expected Emissions Reductions 

The proposed action is designed to provide a RACT emission limitation for the application of 

adhesives and sealants in developing, testing and manufacturing of specialty electronic systems 

and subsystems for defense and homeland security. No emission reductions are expected from 

the proposed action because the emissions limit can be met without the addition or use of 

controls. 

Health Effects and Ground-Level Ozone 

The maximum potential benefit from an emission threshold for this category will be provided 

during the ozone season when VOCs readily combine with NOx to form the pollutant ground 

level ozone.

Economic Impact

The proposed action has no economic impact. 

Revision to Maryland's SIP 

DRAFT 2 12/16/2009 10:46 AM 
DRAFT 3 12/16/2009 10:46 AM 

This action will be submitted to the U.S. EPA for approval as a revision to Maryland's State 

Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal reasonably available control technology standards for this 

category. 

Comparison to Federal Standards 

There is no corresponding federal standard to this proposed action.