UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: July

14, 2011 SUBJECT: Technical Support Document

– State of Maryland

– Adhesives and Sealants Rule

/s/ FROM: Rose Quinto, Environment al Engineer

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez , Associate Director

Office of Air Program Planning

A. BACKGROUND On April 18, 2008 , the Maryland Department of the Environment (MDE) submitted revision s to its Stat e Implementation Plan SI P (Maryland SIP #08

- 02) to the Environmental Protection Agency (EPA) . These SIP revisions pertain to the control of volatile organic compound (VOC) emissions from Poly

tetrafluoroethylene (PTFE) operations (amending Regul ation .30 under COMAR 26.11.19) and from adhesives and sealants operations (adding Regulations .01

- .07 under a new chapter, COMAR 26.11.35). O n May 28, 2009, MDE submitted another revision to its SI P (Maryland SIP #09

- 01) amending Regulation .01 under COMAR 26.11. 35. In addition, on April 23, 2010, EPA received a SI P revision (Maryland SI P #10

- 06) amending the control of VOC emissions from paint, re sin, and adhesive manufacturing and adhesive and sealant application (Regulation .15A and C (4) under COMAR 26.11.19).

B. STATE SUBMITTAL The SI P revisions consist of the following: I . Amendments to COMAR 26.11.19.30

- Control of Volatile Organic Compounds from Chemical Production and Polytetrafluoroethylene Operations . Minor changes were made to headings of subsec tions to capitalize the first letter of one or more words to sections 26.11.19.30B (3

- 2), “Inorganic Chemical Production Installation” and (5) “Product Condenser.” Also under section 26.11.19.30B, the definition of “Poly tetrafluoroeth yl ene (PTFE)” was changed to “Fluoropol ym er material (FPM) , ” therefore, r eplacing the abbreviation “PTFE” to “FPM” throughout COMAR 26.11.19.30. Inaddition, under 26.11.19.30B, r ecodification of several definitions were changed to achieve uniformit y in2

the numbering

. S ec tion 26.11.19.30C(2) was amended to specify that a person who owns or operates an installation subject to the requirements of COMAR 26.11.19.30 will not be subject to COMAR 26.11.35 (Control of VOC Emissions from Adhesives and Sealants) provided that month ly records are maintained which demonstrate that VOC emissions from the application of all adhesives, sealants, adhesive primers, and sealant primers do not exceed 400 pounds per y ear; and adhesive manufacturing do not exceed 200 pounds per year. Section 26.11.19.30C(2) is also subject to some minor editorial amendments which do not change its meaning and to accommodate the addition of the exemption from COMAR 26.11.35 into the paragraph structure of this section.

II . New Regulation
- COMAR 26.11.35
- C ontrol of VOC Emissions from Adhesives and Sealants . Adhesives, sealants, adhesive primer, and sealant primer are used in manufacturing, packaging, construction, and installation of disparate materials such as metal, wood, rubber, plastic, ceramics, fiber glass 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 durabl y, openings between two surfaces. VOC emissions result from evaporation of solvent s during surface preparation, transfer, application, drying , and cleaning operations. The solvents are mostly needed to solubilize the adhesive, sealant, or primer material for application. The solvents prepare the surface to provide a stronger bond. In plastic pipe bonding, the solvent dissolves the poly

vinyl chloride pipe and reacts with the pipe to form a bond. Solvents used to clean the surface before bonding and to clean the application equipment after bonding also contribute to VOC emissions. VOC emissions from adhesives and sealants are primarily from industrial and commercial operations such as general manufacturing, wood product manufacturing, upholstery shops, adhesives retailers and architectural trades, such as building construction, floor c overing installation and roof repair. The Ozone Transport Commission (OTC) States developed a Model Rule “ OTC Model Rule For Adhesives and Sealants” dated 2006 which was based on the 1998 California Air Resources Board (CARB) reasonably available control technology ( RACT ) determination. This RACT determination applied to both the manufacture and use of adhesives, sealants, adhesive primers or sealant primers , in both industrial and manufacturing facilities and in the field. California Air Districts used this determination to develop regulations for this category . EPA addressed this source category

with a Control Techniques Guideline (CTG) document for Miscellaneous Industrial Adhesives dated September 2008. This CTG was developed in response to section 183(e) of the Clean Air Act (CAA) requirement for EPA to study and regulate consumer and commercial products, which is included in EPA’s Report to Congress, “Study of Volatile Organic Compound Emissions from Consumer and Commercial Products

– Comprehensive Emissions Inventory .” The section 183(e) miscellaneous industrial adhesives category was limited to adhesives and adhe sive primers used in industrial and manufacturing operations and3

did not include products applied in the field. Therefore, the OTC Mode l Rule and State efforts in developing individual regulations preceded EPA’s CTG for this source category and were broader in applicability

. The OTC Model Rule for adhesives and sealants and Maryland’s COMAR 26.11.35 provisions compared to the CTG document for Miscellaneous Industrial Adhesives dated September 2008 are discussed in Attachment A (see page 6 below)

. COMAR 26.11.35 is a new regulation based on the OTC model rule that in turn was based on the CARB model rule. COMAR 26.11.35 addresses adhesiv e, sealants, adhesive primers and sealant primers that are sold in larger containers and used primarily in commercial and industrial applications, that includes residential applications of these products, such as carpet, flooring and roofing installations. COMAR 26.11.35 is also applicable to those who sell, supply , offer for sale or manufacture for sale in Maryland; and any adhesives, sealants, adhesive primer or sealant primer for use in Maryland. In addition, it is also applicable to an y person who use s or applies any adhesive, sealant, adhesive primer or sealant primer for compensation within Maryland. This rule will not apply

to homeowners who may be using these products for home repair and renovations. The VOC limits apply to those products manufac tured for sale and used , on and after January

1, 2009 in Maryland and allows for the unlimited sell

- through and use of non

compliant products manufactured before January 1, 2009 provided they

contain a date or date code when they

were manufactured. These limits are identical to those in the OTC and CARB model rules. As an alternative to the VOC limits established in Table 1 of COMAR 26.11.35 , operators of stationary sources that use or appl y adhesives, sealants, or adhesive or sealant primers have the o ption of using add

- on pollution control equipment rather than complying with the Table 1 limits. Requirements applying to air pollution control equipment include: an overall capture and control efficiency

of at least 85 percent, by weight; the continuous monitoring of combustion temperature, inlet and exhaust gas temperatures and control device efficiency , depending upon the ty pe of add

- on controls used; and the maintenance of operation records to demonstrate compliance. COMAR 26.11.35 contains requireme nts for work practices, surface preparation and cleanup solvent composition. COMAR 26.11.35 also includes specific exemptions, as well as registration and product labeling requirements, recordkeeping requirements, and test methods and compliance procedure s. EPA evaluates that COMAR 26.11.35 contains the required elements for a federall y enforceable rule: emission limitations, compliance procedures and test methods, compliance dates and record keeping provisions. In comparison to the CTG, the OTC model rule and COMAR 26.11.35 are applicable to all stationary sources including those applications that occur outside of the factory

setting, that is, applied in the field. In addition, there are provisions that apply to the selling, supplying, offering for s ale or manufacture for sale in Maryland of adhesives, sealants, adhesive primers and sealant primers along with container labeling requirements and product registrations. The VOC content restrictions for these products apply to both their manufacture and application. Stationary sources also have the option of using add

- on control equipment that achieves 85 percent control. The OTC model rule and COMAR 26.11.35 also regulates the VOC content and vapor pressure of surface

- preparation and clean

- up solvents for which the CTG did4

not make recommendations for other than including work practices. EPA recommends that when the States evaluate RACT as required b y section 182(b) when implementing a revised 8

- hour ozone standard , 1 that they review the VOC content li mits for wood adhesives and evaluate the benefit of requiring improved methods for applying coatings regulated b y COMAR 26.11.35. Overall, the OTC model rule and COMAR 26.11.35: (1) R egulate the same adhesives and adhesive primers as the CTG with the add ition of regulating sealants and sealant primers, (2) Appl y to additio nal stationary sources and (3) P rovide for similar exemptions as the CTG recommends. Therefore, COMAR 26.11.35 meets the requirement of a RACT rule for the miscellaneous industrial adh esives CTG category

.
III . Amendments to Regulation .01 under COMAR 26.11.35 . Amendments to Regulation .01 limits the applicability of VOC standards for single

- pl y roof membrane installation and repair adhesives, single

- ply roof membrane sealants, and s ingle

- ply roof membrane adhesives primers according to the following schedules: (1) for the ye ar 2009, from May 15 through September 15; (2) for the years 2010 and 2011, from May 1 through September 30; and (3) on and after January 1, 2012. These amendme nts affect manufacturers, suppliers, installers and users of single

- pl y roofing materials. These amendments provide additional time for training and adaption to the use of new roofing adhesive materials. Roofing operations are performed at a lower rate d uring the non

- ozone season.
IV . Am endments to Regulation .15A and .15C(4) under COMAR 26.11.19. 15 “Paint, Resin, and Adhesive Manufacturing and Adhesive and Sealant Application . ” The SI P revision adds “sealant” to the title of Regulation .15. The S IP revision also adds definitions and terms to Regulation .15A used in the substantive provisions of this SI P revision: sealant, sealant application, and specialt y electronic systems and subs ys tems for defense and homeland securit y. Amendments to Regulation .15C(4) repeal the general emission standard for adhesives, and replacing it with the source

- specific VOC RACT emission limitation for the application of adhesives and sealants to specialty electronic s ys tems and subsy stems for defense and homeland se curity , therefore, this source category is exempt from the requirements under COMAR 26.11.35. The amendments limit the discharge into the atmosphere to not more than 25 pounds per day

of VOC from adhesive and sealant application, averaged over a monthly p eriod.

1 S ee 75 FR 2938, January 19, 2010. I n this proposed rule, March 2008, based upon reconsideration of the primary and secondary ozone standards, EPA proposed to set different primary and secondary standards than those promulgated in March 2008 to provide requisite protection of public health and welfare, respectively.5

D . CONCLUSION S AND RECOMMENDED AGENCY ACTION The amendments to Regulation .30 ( COMAR 26.11.19.30) “ Control of Volatile Organic Compounds from Chemical Production and Polytetrafluoroethylene Operations ” meets the applicable requirements of the CAA, and the applicable EPA regulations, guidance and policy and can be approved. COMAR 26.11.35 “ Control of VOC Emissions from Adhesives and Sealants” adopted b y Maryland will result in the reduction of VOC emissions from the affected sources and meets the applicable requirements of the CAA, and the applicable EPA regulations, guidance and policy and can be approved. Amendments to Regulation .01 under COMAR 26.11.35 , and Regulation .15A and C (4) under COMAR 26.11.19, will result in the reduction of VOC emissions from the affected sources and meets the applicable requirements of the CAA, and the applicable EPA regulations, guidance and policy and can be approved. EPA ’s approval of the SIP revision s is recommended.6 ATTACHMENT A

OTC Mod el Rule for Adhesives and Sealants and Maryland’s COMAR 26.11.35 Provisions Compared to the Control Technique Guidelines for Miscellaneous Industrial Adhesives, September 2008

OTC Model Rule The Ozone Transport Commission ( OTC ) developed a model rule as part of a regional effort to attain and maintain the eight

- hour ozone standard and reduce eight

- hour ozone levels. States opting to promulgate rules based on this model rule will utilize State

- specific administrative requirements and procedures. Marylan d ’s adopted COMAR 26.11.35 “ Control of V olatile O rganic C ompound (VOC) Emissions from Adhesives and Sealants” is based on the OTC model rule. A reasonably

available control technology ( RACT ) determination prepared by the California Air Resources Board (CA RB) in 1998 forms the basis of the OTC model rule. In the y ears 1998

- 2001, the provisions of the CARB determination were adopted in regulatory form in various air pollution control districts in California including the Bay Area, Ventura County , Sacramento Metropolitan and San Joaquin Valley

. The provisions of this model rule limit emissions of VOCs from adhesives, sealants, adhesive primers and sealant primers. The model rule achieves VOC reductions through two basic components: (1) sale and manufacture restrictions that limit the VOC content of specified adhesives, sealants, adhesive primers and sealant primers sold in the state; and (2) use restrictions that appl y primarily to commercial and industrial applications. By reducing the availability

of higher VOC content adhesives and sealants within the State, the sales prohibition is also intended to address adhesive and sealant usage at area sources. Emissions from residential use of regulated products are addressed through the sales restrictions and si mple use provisions. The associated emissions reductions will be used as part of the State’s plan to attain and maintain the 8

- hour ozone national ambient air quality standard (NAAQS).
Control Techniques Guideline The Environmental P rotection Agency ( EPA ) addressed a portion of this category , adhesives and adhesive primers, in a Control Techniques Guideline (CTG) document

- “ Control Techniques Guidelines for Mi scellaneous Industrial Adhesive , EPA

- 453/R

- 08

- 005” in September 2008. ( See Docket number EP A

- HQ

- OAR

- 2008

- 0460 .) “This CTG is intended to provide State and local air pollution control authorities7

information that should assist them in determining RACT for VOCs from miscellaneous industrial adhesive application processes. In developing this CTG, EPA, among other things, evaluated the sources of VOC emissions from miscellaneous industrial adhesives application processes and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for miscellaneous industrial adhesives. States can use the recommendations in this CTG to inform their own determination as to what constitutes RACT for VOCs for miscellaneous industrial adhesive application processes in their particular nonattainment areas. The information contained in this document is provided only as guidance. This guidance does not change, or substitute for, requirements specified in applicable sections of the CAA or EPA’s r egulations; nor is it a regulation itself. This document does not impose any legall y binding requirements on any entity

. It provides only

recommendations for State and local air pollution control agencies to consider in determining RACT. State and local pollution control agencies are free to implement other technicall y - sound approaches that are consistent with the CAA and EPA’s implementing regulations” (CTG page 1). “When State and local pollution control agencies develop RACT rules, they may elect t o adopt control approaches that differ from those described in this document and/or promulgate applicability

criteria that differ from those recommended here [in this CTG].” (CTG page 3)

. EPA issued the CTG pursuant to the authority and to meet a require ment set by section 183(e) of the CAA. Section 183(e) directed EPA to list for regulation , those categories of products that account for at least 80 percent of the VOC emissions from consumer and commercial products in ozone nonattainment areas, and to sc hedule those categories for regulation in four groups. Section 183(e)(3)(C) further provides that we may issue a CTG in lieu of a national regulation for a product category

where we determine that the CTG will be “ substantial ly as effective as regulations ” in reducing emissions of VOC in ozone nonattainment areas. See for example, 64 FR 13422, March 18, 1999. EPA has revised the list several times. See 70 FR 69759, November 17, 2005; 64 FR 13422, March 18, 1999; and most recentl y, 71 FR 28320, May 16, 2 006. Under section 183(e), a regulation for consumer or commercial products is limited to measures applicable to manufacturers, processors, distributors, or importers of the solvents, materials, or products supplied to the consumer or industry . Section 1 83(e) does not authorize EPA to issue national regulations that would directly regulate end

- users of these products. By contrast, CTG are guidance do cuments that recommend RACT measures that States can adopt and apply to the end

- users of products. See 73 FR 58481 at 58483, October 7, 2008. However, section 183(e) does not impose the same restrictions upon States , upon regulation of end

- users and manufacturers, processors, distributors, or importers. Therefore, a State can regulate manufacturers, process ors, distributors, or importers and end

- users of a product category for which EPA has issued a CTG.8

I. Applicability (1) The scope of the CTG is focused on industrial adhesive application processes at facilities, i.e., stationary

sources. The limits and requirements apply to facilities where the total actual VOC emissions from all miscellaneous industrial adhesive application processes, including related cleaning activities, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equiva lent level such as 3 tons per 12

- month rolling period, before consideration of controls. The OTC model rule is broader than the CTG and applies to processes below the 6.8 kg/day recommendation. It also applies outside of stationary source facilities wh en the adhesives are applied in the field. (2) The OTC model rule is als o applicable to an y person who: sells, supplies for sale, offers for sale or manufactures for sale an y adhesive, sealant, adhesive primer or sealant primer

. The CTG is not applicabl e to these people.

II. Definitions Generally the OTC model rule and CTG use the same terms and definitions for those terms. The OTC model rule contains additional definitions to address sealants and sealant primers and additional ty

pes of products. There are minor differences with some terms because the CTG focuses on the processes at a facility while the OTC model rule also incorporates prohibitions on selling, offering for sale and using products that can occur outside of a facility . There are som e instances where the CTG and the OTC model rule use different terms for the same process/product , but these are substantivel y the same. Specific examples: There appears to be an inconsistency in the CTG wi th the category of tire repair and tire retread

. Tire repair generall y would not occur at a manufacturing facility , but at smaller operations in the field. The draft CTG used a term “tire retreading” which w ould be a process that occurs at a manufacturing facility

. The OTC model rule and COMAR 26.11. 35 regulate “tire retread ” and defines the category

in terms of manufacture and not the repair of a puncture. COMAR 26.11.35’s definition is consistent with South Coast Air Quality Management District ( SCAQMD ) rule 1168’s definition of “tire tread adhesiv e.” The CTG was developed based upon SCAQMD rule 1168 and similar rules. Therefore, with regards to “tire retread” and “tire repair” processes, the OTC model rule and COMAR 26.11.35 are consistent with those rules upon which the CTG founded its recommend ations. The CTG does not distinguish between cleaning materials used for surface preparation and those used for cleaning application equipment, but the OTC model rule does make this distinction. The recommendations for roof membranes in the CTG do not e xtend to field applied materials,9

because: (1) field

- applied adhesives are not part of the miscellaneous industrial adhesives category and are therefore not covered by this CTG, and (2 ) nonmembrane roof installation and repair adhesive , and eth ylene prop ylene diene monomer ( EPDM ) described in the comments received on the draft CTG are field applied products and are therefore not included in the miscellaneous industrial adhesives category . To the extent the recommendations in the OTC model rule sets limits for EPDM single

- pl y roof membranes it makes a recommendation beyond those in the CTG. It appears that the inclusion of “m otor vehicle glass bonding primer” in the CTG covers a slightly

broader cl ass of adhesives primers than “a utomotive glass adhesive pr imer.” The OTC model rule includes wood in the definition of “porous material” while the CTG does not and has a separate limit for wood. The CTG’s recommended definition was made in the absence of limits for sealants and sealant primers and specifically excludes wood from being considered a porous material.

III. Requirements (1) The OTC model rule applies to any person who sells, supplies or offers for sale an y adhesive, sealant, adhesive primer or sealant primer manufactured on or after January 1, 2009 , or manufacture for sale an y adhesive, sealant, adhesive primer or sealant primer in excess of the applicable VOC content limits specified in Table 1. The CTG does not apply to people who sell or manufacture these coatings. (2) The OTC model rule applies to any person who uses or applies (for compensation) an y adhesive , sealant

, adhesive primer or sealant primer that has an applicable VOC content limit specified in Table 1 that is not otherwise exempted

. The CTG only recommends application of the limits and requirements to facilities where the total actual VOC emissions from all miscellaneous industrial adhesive application processes, including related cleaning activities, at that facility

are equal to or exceed 6.8 kg/day (15 lb/day), or an equiva lent level such as 3 tons per 12

- month rolling period, before consi deration of controls. The OTC model r ule covers “field applied adhesives” which the CTG does not cover. (3) Both the CTG and the OTC model rule have a table of content limits for the regulated products. See the comparison of table limits and discussion below. (4) The CTG did not propose recommendations for VOC content or VOC composite vapor pressure limit s for cleaning materials. The OTC model rule and COMAR 26.11.35 contained the fol lowing limits for cleaning materials: a. L imits the VOC content of the surface preparation solvent to less than 70 grams per liter;10

b. L imits the VOC content of surface preparation solvent used in applying single

- pl y roofing to a composite vapor press ure, excluding water and exempt compounds, not exceeding 45 mm Hg at 20 degrees Celsius; c. L imits materials containing VOCs used to remove adhesives, sealants, or adhesive or sealant primers from surfaces unless the composite vapor pressure of the solv ent used is less than 45 mm Hg at 20 degrees Celsius; d. R equires spray

application equipment be cleaned in enclosed cleaning sy stem s using cleaning solvents with less than or equal to 70 grams of VOC per liter of material, or b y soaking parts in closed sy stems using and a solvent if the composite vapor pressure of the solvent, excluding water and exempt compounds, is less than or equal to 9.5 mm Hg at 20 degrees Celsius. (5) Both the CTG and OTC model rule provide for the use of add

- on air pollution co ntrol equipment instead of meeting the solvent content limits. Both require that controls reduce VOC emissions by

an overall capture and control efficiency of at least 85% by

weight. The OTC model rule includes additional provisions to insure that the co ntrol equipment is operated properl y. (6) Both the CTG and OTC model rule require work practices to minimize emissions from cleaning operations. The CTG recommendations are more detailed while the OTC model rule is more general. (7) The OTC model rule prohibitions the specification of non

- compl yi ng adhesives, sealants, adhesive primers, sealant primers, surface preparation or clean

- up solvents. (8) The CT G also recommends that adhesive and adhesive primer s be applied using application methods with g ood transfer efficiency in conjunction with the use of low

- VOC content adhesives. Specifically , the CTG recommends the following application methods: electrostatic spray , HVLP spray , flow coat, roll coat or hand application including non

- spray application methods similar to hand or mechanically powered caulking gun, brush, or direct hand application), roll coat, dip coat (including electrodeposition), airless spray , air

- assisted airless spray , or other coating application method capable of achieving good transfer efficiency . (Fi nal CTG, Section VI.B., page 19 )

. The CTG recommends application methods with good transfer efficiencies for stationary facilities and does not make recommendations for field applied adhesives and s ealants. The OTC model rule does not address application methods.

IV. Exemptions and Exceptions (1) CTG and OTC model rule have similar exemptions for the following: a. Adhesives, sealants, adhesive primers or sealant primers being tested or evaluated in any research and development, quality ass urance or anal yt ical laboratory

.11

b. Cy anoacrylate adhesives

. c. Adhesives, sealants, adhesive primers or sealant primers that are sold or supplied by the manufacturer or supplier in containers with a net volume of 16 fluid ounces or less , or a net weight of one pound or less, except plastic cement welding adhesi ves and contact adhesives. d. Processes using poly ester bonding putties to assemble fiberglass parts at fiberglass boat manufacturing facilities and at other reinforced plastic c omposite manufacturing facilities. e. In the assembl y, repair and manufacture of aerospace or undersea

- based weapon sy stems. f. Solvent welding operations used in the manufacture of medical devices. (2) OTC model rule exemptions not in CTG:

a. Adhesives, sealants, adhesive primers and sealant primers that are subject to S tate consumer product regulation. State consumer product regulations generally regulate the same categories as the Federal Regulation (of 40 CFR Part 59). Under section 183(e ) the consumer products regulated b y 40 CFR Part 59 cannot be the same adhesive products and adhesive primers as those covered b y the CTG, and, therefore this provision of the OTC model rule merel y clarifies that here is no double regulation 2

. b. Adhesiv es and sealants that contain less than 20 grams of VOC per liter of adhesive or sealant, less water and less exempt compounds, as applied. This limit is less than an y limit recommended by

the CTG.

c. Contact adhesives that are sold or supplied b y the manufacturer or supplier in containers with a net volume of one gallon or less. Some California Air Districts have a similar size exemption but with additional conditions. d. Tire repair operations, provided the label of the adhesive states " For tire repa ir only

. "

e. Plaque laminating operations in which adhesives are used to bond clear, poly ester acetate laminate to wood with lamination equipment installed prior to July 1, 1992. Any person claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance with this exemption and in accordance with section (V) of this rule.

2 The latest listing of product categories regulated under section 183(e) of the CAA wa s published on May 16, 2006 (71 FR 28320).12

In addition, the CTG recommends that these sources be subject to the work practices recommendation. (3) The OTC model rule exempts total VOC emissions from all adhesives, sealants, adhesive primers and sealant primers used at a facility that are less than 200 pounds per calendar ye ar, or an equivalent volume. Any person claiming exemption pursuant to this s ubparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance. (4) The OTC model rule exempts adhesives, sealants, adhesive primers, sealant primers, cleanup solvents and surface preparation solvents provided th e total volume of noncomplying adhesives, sealants, primers, cleanup and surface preparation solvents applied facility

- wide does not exceed 55 gallons per calendar year. An y person claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance. This is equivalent to 400 pound per year, while the CTG applicability starts at 6.8 kg/day (15 lb/day) or an equivalent level such as 3 tons (6000 pound) per 12

- month rolling period. ( 5 ) The OTC model rule exempts adhesive, sealant, adhesive primer or sealant primer intended for shipment and use outside of OTC State s or in COMAR 26.11.35. (6 ) The OTC model rule exempts any adhesive, sealant, adhesive primer or sealant primer that is controlled by

add

- on air pollution control equipment.

V. Administrative Requirements The OTC model rule contains detailed record keeping requirements for demonstrating compliance with the VOC content limits and recording the key operating parameters for the control equipment that must be maintained for five y ears. Any S tate rule for a CTG must contain monitoring and recordkeeping requirements.

VI. Compliance Procedures and Test Methods Both the CTG and OTC model rule contain the same primary test m ethods and compliance procedures. The OTC model rule contains additional references to other relevant standard test methods for both solvent anal ys is and for determining compliance of add

- on control equipment. Any S tate rule for a CTG must contain test me thods for determining compliance.

VII. Container Labeling The OTC model rule requires labeling of product container with the maximum or actual VOC content of the product along with information concerning thinning of the product.13

VIII. Emission Limi t T able The table below provides an anal ys is of the CTG recommended VOC emission limits for general and specialt y adhesive application processes compared to the OTC model rule VOC content limits for adhesives, sealants, adhesive primers sealant primers an d adhesives applied to particular substrates. Where there is no comparable limit the column is left blank. In the CTG recommendation column, categories with brackets { } around them indicates there is a difference in a definition or provision which dif fers from the OTC model rule. Below the table are series of “Notes” which discuss some of the differences between the OTC model rule and the CTG and refer back to some of the California adopted rules (CARB model rule) for which the OTC model rule was base d on. Both the CTG and the OTC model rule were based on the California rulemaking efforts for this category and the CTG also bases its recommended emission limits on the OTC model rule (see CTG page 16, last paragraph). The CTG also states “we consider the limits in the OTC model rule to be representative of what sources in nonattainment areas nationwide can achieve technicall y and economically and have therefore adopted these VOC limits as our recommendations in the CTG. ”


### OTC Model Rule CTG Recomm endation Category VOC content limit (grams VOC per liter*) Category Recommended VOC Emission Limit 1 (g/l) Adhesives Specialty Adhesive Application Processes ABS welding 400 {Plastic Solvent W elding (ABS)} 400 Ceramic tile installation 130 Ceramic Ti le Installation 130 Computer diskette jacket manufacturing 850 Contact bond [Note C] 250 {Contact Adhesive} [Note C] 250 Cove base installation 150 Cove Base Installation 150 CPVC welding 490 {Plastic Solvent W elding (Except ABS)} {500} Indoor fl oor covering installation 150 Floor Covering Installation (Indoor) 150 Metal to urethane/rubber molding or casting 850 Metal to Urethane/Rubber Mo lding or Casting 850 Motor Vehicle Adhesive [Note H] 250 Motor Vehicle W eatherstrip 75014 

### OTC Model Rule CTG Recomm endation Adhesive [Note H] Mu ltipurpose construction 200 Mu ltipurpose Construction 200 Nonmembrane roof installation/repair 300 Other plastic cement welding 510 {Plastic Solvent W elding (Except ABS)} { 500 } Outdoor floor covering installation 250 Floor Covering Installati on (Outdoor) 250 PVC welding 510 {Plastic Solvent W elding (Except ABS)} { 500 } Single
- ply roof membrane installation/repair [Note G] 250 Single
- Ply Roof Membrane Installation/Repair (Except EPDM) 250
Structural glazing 100 Structural Glazing 100 Thin m etal laminating 780 Thin Metal Laminating 780 Tire Repair [Note A] 100 Tire retread [Note A] 100 Perimeter bonded sheet vinyl flooring installation 660 {Floor Covering Installation (Perimeter Bonded Sheet Vinyl)} [Note C] 660
Wa terproof resorcin ol glue 170 Wa terproof Resorcinol Glue 170 Sheet
- applied rubber installation 850 {Sheet Rubber Lining Installation} [Note C] 850

Sealants Architectural 250 Marine deck 760 Nonmembrane roof installation/repair 300 Roadway 25 0 Single
- ply roof membrane 450 Other 420
Ad hesive Primers Ad hesive Primer Ap plication Processes Automotive glass [Note G] 70015 

### OTC Model Rule CTG Recomm endation Motor Vehicle Glass Bonding Primer [Notes B and G] 900 Plastic cement welding 650 {Plastic Sol vent W elding Adhesive Primer} [Note C] 650 Single
- ply roof membrane 250 Single
- Ply Roof Membrane Adhesive Primer [Note B] 250 Traffic marking tape 150 Other [Note G] 250 Other Adhesive Primer [Note B] 250 Sealant Primers Non
- porous ar chitectural 250 Porous architectural 775 Marine deck 760 Other 750
Ad hesives A pplied to the Listed Substrate [Notes E and H] General Adhesive Ap plication Processes 2 [Note E] Flexible vinyl [Note H] 250 Flexible vinyl 25 0 Fiberglass [Notes F & H] 200 Reinforced plastic composite [Note F] [Note F] 200 Metal [Note H] 30 Metal 30 Porous material (Including wood) [Note H] 120 Porous Material (Excluding Wo od) 120 Rubber [Note H] 250 Rubber 250 Other substrates [Note H] 250 Other Substrates 250 Wo od 30 * The VOC content is determined as the weight of volatile compounds, less water and exempt compounds as specified in Section VI of this rule.

1 Emission limits are mass of VOC per volume o f adhesive or adhesive primer, excluding water and exempt compounds. 2 If an adhesive is used to bond dissimilar substrates together, then the applicable substrate category with the highest VOC emission limit is recommended as the limit for such applicatio n. The analogous provision in the OTC Model Rule is found in Section III . ( 3) of that rule. Notes : A. The CTG is inconsistent with the State rules cited in Appendix B in that none of these rules set a limit for “tire repair” adhesives (as that term is defined in each of these rules) but16

rather set a limit for “tire retread(ing) adhesives” which is the same as th e 100 g VOC/liter limit in the OTC model rule (which is as expected since this rule is based upon one or more of the California rules). B. The CTG has the words “Adhesive Primer” in its table whereas in the OTC model rule this is to be understood from the sub

- heading. C. The CTG and OTC Model Rule use slightly different terms to cover the same processes or products.

- The CTG uses the te rm “Floor Covering Installation (Perimeter Bonded Sheet Vinyl)” to cover what the OTC Model Rule covers as “Perimeter Bonded Sheet Vinyl.”

- The term “Sheet

- applied rubber installation” in the OTC Model Rule means the same thing as “Sheet Rubber Lining Ins tallation” in the CTG.

- “Contact bond” adhesive and ““Contact adhesive” would appear to be the same thing. Both the OTC Model Rule and the CTG definitions for “Contact bond adhesive” are the same and both use “Contact adhesive” within this definition to r efine its scope.

- The OTC Model Rule uses “Plastic Cement Welding Adhesive Primer” where the CTG uses “Plastic Solvent Welding Adhesive Primer” for the same product/process. D. The inclusion of the category “plastic adhesive primer” in the Draft CTG was an error. This category

has been removed from the final CTG. E. The OTC model rule uses the term “Adhesives Applied to the L isted Substrate” where the CTG uses the term “General Adhesive Application Processes.” F. The CTG covers more materials with the broader definition of “ Reinforced plastic composite” than the OTC model rule if the latter considers “fiberglass” to means fine glass fibers in a plastic resin. But the OTC rule defines “fiberglass” as a material consisting of extremel y fine glass fib ers; thus, a “fiberglass substrate adhesive” could be interpreted as meaning an adhesives used to bond glass fibers together or to another listed substrate. The OTC definition is consistent with several California AQMD rules such as SCAQMD Rule 1168, Sacr amento Metropolitan AQMD Rule 460; other California AQMDs do not define “fiberglass”

– e.g., San Diego Count y AQMD rule 67.21; however, Ventura County AQMD Rule 74

- 20 defines fiberglass as “...an y fiber reinforced plastic (FRP) surface that has fiber materia l set in a binding substance of plastic resins” which appears to be the functional equivalent of the final CTG’s definition of “Reinforced plastic composite.” G. To the extent the OTC Model Rule limit for “Automotive glass adhesive primers” and the recommendation in the final CTG for “Motor Vehicle Glass Bonding Primer” both cover the same material or process the recommendation in the OTC model rule is more stringent. To the17

extent that the definition of recommendation in the final CTG for “Motor Vehicle Glass Bonding Primer” covers more processes or operations the recommendation in the final CTG would be more stringent except the OTC model rule may cover an y additional products under the other primer category . The recommendation in the OTC model rule fo r appl yi ng an “Automotive glass adhesive primer” to automotive glass is clearly more stringent. However, recommendation in the CTG for “Motor Vehicle Glass Bonding Primer” would cover primers applied to “ body openings ” prior to the application of glass bo nding adhesives or the installation of adhesive bonded glass. Bod y openings may include substrates such as bare metal or plastic as well as the glass itself. To the extent the limit for “other adhesive primers” covers “Motor Vehicle Glass Bonding Primers ” other than those when applied to automotive glass, the recommendation in the OTC model rule would seem to be more stringent. H. Whether the recommendation in the OTC model rule is equal to, less stringent or more stringent than the recommendations in the CTG for these categories depends upon whether the OTC model rule covers these applications under the “Adhesives Applied to the L isted Substrate” and which limit applies. The applicable limit depends upon what substrates are involved. The OTC model ru le allows compliance to the higher of two applicable substrate limits when bonding dissimilar substrates. In no case is an OTC limit for any “listed substrate” greater than that recommended in the CTG for “Motor Vehicle Adhesives” and “Motor Vehicle Weath erstrip Adhesives;”as such, the OTC model rule would seem to be more stringent. I. The OTC Model rule applies a limit to ethylene propylene diene monomer (EPDM) roof membranes. The CTG excluded EPDM membranes from the VOC recommendation for “Single

- Pl y Roof Membrane Installation/Repair” specialt y adhesives based upon comment that such limits could not be met for field applied EPDM. Some OTC States have limited the CTG recommendation for May 1 to September 30 for two y ears and then set the limit y ear - r ound after that.

IX. Conclusions The OTC Model rule and specificall y, COMAR 26.11.35, for adhesives and sealants and the 2008 CTG for miscellaneous industrial adhesives were developed to address the emissions of VOC from adhesives

. The CTG was develop ed with a restriction that it only applies to larger sources with manufacturing operations that use these ty pes of products. Whereas, the OTC model rule includes these sources as well as smaller operations, operations performed in the field and also regul ation of the manufacture, distribution and sale of the products themselves. The OTC model rule also regulates sealants and sealant primers which are not included in the CTG because they were not categorized with miscellaneous industrial adhesives under se ction 183(e)

. The CTG and the OTC model rule exemption categories are very similar though some differences exist, but the CTG recommends that exempted operations be subject to work practices. The OTC model rule does not include work practices. T he work practices benefit cannot be quantified and in these instances, generally appl y to lower usage source categories so18

very few emission reductions are missed b y not including these requirements. The OTC model rule contains an exemption provision which is in fact a de facto applicability level that equates to 400 pounds per year of VOC emissions which is less than the CTG’s yearly limit of 3 tons per ye ar. The model rule’s 400 pounds per y ear exclusion includes emissions from sealants and sealant primers and not just adhesives and their primers and therefore sets a lower numerical limit and includes more emissions subject to the applicability threshold. T he CTG recommended work practices for cleaning materials included more activities than the OTC model rul e. However, s ome of the OTC clean

- up provisions are more stringent, i.e. limiting clean

- up solvent vapor pressure and VOC content, and cleaning of spray application equipment; over all, the OTC requirements in terms of emission reductions are at least equi valent to or result in more emission reductions than the CTG

. The CTG makes recommendations for application methods be used in conjunction with the us e of low

- VOC content adhesives and adhesive primers to improve transfer efficiency . The OTC rule does no t specify

application methods. T he CTG recommendation goes to “stationary sources” above a cut

- off level only

. The OTC model rule was based on the CARB 1998 RACT and best available retrofit control technology (BARCT) determination for adhesives and s ealants which did not include the requirement for application methods. Maryland ’ s proposed rulemaking states that 96 percent of the adhesive and se alant VOC emissions in the OTC S tates fall into the area source category

. This would appear to limit the benefi t from improved transfer equipment. However, EPA recommends that when the S tates evaluate RACT as required b y section 182 (b) when implementing a revised 8 hour ozone standard 3 , that they review and evaluate the benefit of requiring improved methods for ap pl yi ng coatings regulated b y the OTC model rule and specifically , COMAR 26.11.35. Overall, the CTG and the OTC model rule emission limits are similar with the exception of general adhesive for wood applications. T he CTG recommends a 30 g/liter limit for the wood substrate category

whereas the OTC model rule covers wood under the “porous material” substrate category with a limit of 120 g/liter. It is recommended that when the S tates evaluate RACT as required b y s ection 182 (b) when implementing a revised 8

- hour ozone standard, that they review the VOC content limit for wood adhesives

. The CTG does not requi re S tate rules to match the line

- by

- line, item

- by

- item because it stated: “When State and local pollution control agencies develop RACT rules; they may elect to adopt control approaches that differ from those described in this document and/or promulgate applicability

criteria that differ from those recommended here.” (CTG p age 3.) For the most part the OTC Model rule and specifically , COMAR 26.11.35 , match the CTG’s recommendations item by item. The OTC Model rule and specificall y, COMAR 26.11.35 , requires the emission limitations apply to a wider universe of sources and to manufacturers and distributors of adhesives and primers. The OTC Model rule and specifically , COMAR 26.11.35 , 3 See 75 FR 2938, January 19, 2010; In this proposed rule, March 2008, based upon reconsideration of the primary and secondary ozone standards, EPA proposed to set different primary and secondary standards than those promulgated in March 2008 to provide requisite protection of public health and welfare, respectively.19

sets standards for clean

- up and surface preparation solvents in lieu of the application methods and all work practice recommendations in the CTG. Overall, EPA can conclude the OTC Model rule and specificall y, COMAR 26.11.3 5 , meets the requirement for RACT in this source category
.