# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

## Amendments to — COMAR 26.11.15 C(4) Standards for Adhesive and Sealant Application for Specialty Electronic Systems and Subs ystems 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 lim itation for the application of adhesives and sealants to specialty electronic systems and subs ystems 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 a nd Sealants”, based on the 2006 Ozone Transport Commission (OTC) model rule. The OTC rule wa s developed using the 1998 RACT and a best available retrofit control technology determinatio n 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 mate rials 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 adhesi ve properties that is used prim arily to fill and seal durably, openings between two surfaces. The standards in COMAR 26.11.35 reflect th e large scale use of

adhesives and sealants fo r different materials.

Adhesives used for specialty electronic syst ems 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, te sters and manufacturers of specialty electronic systems and subsystems for defense and homela nd security. Affected sources are located in Ozone and PM nonattainment areas in Maryland.

1Requirements

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 desi gn and development, different types of materials, processes and characteristics have to be tried before finalizing th e specifications of the paste. Constant monitoring of the materials is required to maintain integrity of the process. Specialty electronic systems and subsystems for defens e and homeland security have very limited tolerances and monitoring of ma terials becomes even more important for higher reliability. Varying material characteristics can have a si gnificant impact on perf ormance of electronic systems. Limiting the VOC content of solvents us ed has the potential to affect the performance characteristics of systems and subsyste ms 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 devel oping, testing and manufacturing of specialty electronic systems and subsystems for defense and homeland secur ity. 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 comb ine with NOx to form the pollutant ground

level ozone.

Economic Impact

The proposed action has no economic impact.

Revision to Maryland's SIP

DRAFT 12/16/2009 10:46 AM 2DRAFT 12/16/2009 10:46 AM 3 This action will be submitted to the U.S. EPA fo r approval as a revision to Maryland's State Implementation Plan.

Other State or Federal Requirements

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

category.

Comparison to Federal Standards

There is no corresponding federal st andard to this proposed action.