# ORIGINAL· 1 1 

### MARYLAND DEPARTMENT OF THE ENVIRONMENT 2 

### AIRAND RADIATION MANAGEMENT ADMINISTRATION 3 4 5 

### PUBLIC HEARING CONCERNING 6 

### AMENDMENTS TO REGULATION .26, AND 7 

### PROPOSED NEW REGULATION .26-1, CONTROL OF 8 

### VOLATILE ORGANIC COMPOUNDS FROM FIBERGLASS BOAT 9 

### MANUFACTURING PROPOSED UNDER COMAR 26.11.19, VOLATILE 10 ORGANIC COMPOUNDS FROM SPECIFIC PROCESSES 11 

### 12 13 The hearing in the above matter commenced on 14 Tuesday, July 28, 2015, at the MOE Headquarters, 15 Montgomery Park, 1800 Washington Boulevard, Baltimore, 16 Maryland. 17 18 BEFORE: RANDY MOSIER, Hearing Officer 19 20 21 Reportedby: JenniferMetcalf

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-55552 1 A P P E A R A N C E S 2 3 ON BEHALF OF THE MARYLAND DEPARTMENT OF THE ENVIRONMENT: 4 RANDY MOSIER 5 Chief 6 Regulations Development Division 7 Air and RadiationManagement 8 Maryland Department of the Environment 9 1800 Washington Boulevard, Suite 730 10 Baltimore, Maryland 21230 11 12 HUSAIN WAHEED 13 Senior Regulatory and Compliance Engineer 14 Air and Radiation Management Administration 15 Maryland Department of the Environment 16 1800 Washington Boulevard, Suite 730 17 Baltimore, Maryland 21230 18 19 20 21

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-55553 1 I N D E X 2 3 Speaker: Page: 4 Opening Remarks, Randy Mosier, MDE 4 5 Hearing Statement, Husain Waheed, MDE 5 6 7 8 9 10 11 12 13 14 15 

### 16 17 18 19 20 21

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### P R0 C E E D I N GS 2 3 MR. MOSIER: Good morning. On behalf of the 4 Department of the Environment and the Air and Radiation 5 Management Administration, I would like to welcome you to 6 this public hearing. 7 My name is Randy Mosier and I am the Chief of 8 the Regulations Development Division for the Air and 9 Radiation Management Administration. I will serve as 10 hearing officer for today's hearing. 11 I would like to ask all of you in attendance 12 today to please sign in, if you haven't already done so. 13 This will help us to keep an accurate record of the 14 people who participate in the hearing. Also, copies of 15 our regulation proposal, support documents, and the 

### 16 Department's statement are available on the table for 17 your information. 18 This hearing concerns Air Quality Regulations 19 found in the Code of Maryland Regulations, Title 26, 20 Subtitle 11, Air Quality. The Secretary of the 21 Department proposes to amend Regulation .26, and to adopt



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### 1 new Regulation .26-1, Control of Volatile Organic 2 Compounds from Fiberglass Boat Manufacturing under COMAR 3 26.11.19, Volatile Organic Compounds from Specific 4 Processes. The proposed regulation adopts the U.S. 5 Environmental ProtectionAgency's (EPA's) Control 6 Techniques Guidelines (CTG) requirements for this source 7 category. 8 The purpose of this hearing is to give you the 9 opportunity to comment on this action. 10 The Opportunity for Public Comment for this 11 proposed action appeared in the Maryland Register, Volume 12 42, Issue 13, Pages 848 through 852 on June 26, 2015. 13 This public hearing was scheduled to begin at 14 10:00 am. It is now 10:12 and no one has come to attend 15 this hearing. Therefore, Mr. Waheed will submit his 16 hearing statement for the record. 17 MR. WAHEED: Let the record show that I am 18 submittingmy statement concerning the proposed 19 amendments to Regulation .26 and proposed Regulation .26- 20 1 under COMAR 26.11.19, Control ofVolatile Organic 21 Compounds from Specific Processes.

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-5555-"; i" , 6 

### 1 2 Statement of theAir andRadiation 

### 3 ManagementAdministration 

### 4 Department of theEnvironment 

### 5 for the Public HearingRelating to Proposed 

### 6 Amendment to Regulation .26 Control 

### 7 ofVolatile Organic Compounds from ReinforcedPlastic 

### 8 Manufacturing and ProposedRegulation .26-1 Control 

### 9 ofVolatile Organic Compounds from Fiberglass Boat 

### 10 Manufacturingunder 

### 11 COMAR 26.11.19 Control ofVolatile Organic Compounds 

### 12 from Specific Processes 

### 13 heldon July 28, 2015 

### 14 Baltimore, MD 

### 15 My name is Husain Waheed. I am a Senior 16 R egulatory and Compliance Engineer with the Regulation 17 Development Division of the Air and RadiationManagement 18 Administration, Maryland Department of the Environment. 19 This public hearing is being heldpursuant to 20 the requirements of 40 CFR Section 51.102 and Sections 2- 21 301 et.seq. of the Environment Article, Annotated Code of



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### www.ftrinc.net-(800)921-55557 1 Maryland. It is also being held in conformance with the 2 State Administrative Procedures Act under the State 3 Government Article, beginning at Section 10-101. 4 Notice of this hearing appeared in the: 5 Maryland Register on June 26, 2015. 6 Copies of the proposed action and supporting 7 documents were submitted for review to the State 8 Clearinghouse and are also submitted at this time into 9 the hearing record. Copies were also made available for 10 public inspection at the Maryland Department of the 11 Environment Air and Radiation Management Administration 12 offices in Baltimore and at the Air and Radiation 

### 13 Administration webpage titled "Air 

### &Radiation 14 Regulations Public Hearings, Meetings and Request for 15 Comments", from June 26, 2015 to July 28, 2015. 16 The purpose of today's hearing is to give the 17 public an opportunity to comment on the proposed 18 amendment to regulation .26 and proposed regulation .26-1 19 under COMAR 26.11.19, Control of Volatile Organic 20 Compounds from Specific Processes. 21 Summary

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-55558 1 The purpose of this action is to adopt the 2 requirements of the EPA's Control Techniques Guidelines 3 (CTG) for Fiberglass Boat Manufacturing. The new 4 regulation COMAR 26.11.19.26-1, Control of Volatile 5 Organic Compounds from Fiberglass Boat Manufacturing, 6 adopts CTG standards and requirements. States have the 7 flexibility to follow the CTGs or adopt more restrictive 8 standards. MDE proposes to adopt standards for volatile 9 organic compounds (VOCs), application methods, and work 10 practices which are consistent with the most recent CTG 11 recommendations applicable to fiberglass boat 12 manufacturing. Also COMAR 26.11.19.26 Control of 

### 13 Volatile Organic Compounds from Reinforced Plastic 14 Manufacturing is amended to exempt fiberglass boat 15 manufacturing. 16 The EPA first published an assessment of VOC 17 emissions from fiberglass boatmanufacturing in 1990. 18 This assessment evaluated VOC emissions from fiberglass 19 boat manufacturing and potential control options. The 20 National Emission Standards for Hazardous Air Pollutants 21 for Boat Manufacturing, 40 CFR part 63, subpart VVVV

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-55559 1 (2001 NESHAP) were promulgated in 2001. Emission 2 standards under the 2001 NESHAP were for organic 3 hazardous air pollutants (HAPs) based on low-HAP resins 4 and gel coats and low-emitting resin application 5 technology. In September 2008, the EPA published a new 6 CTG for Fiberglass Boat ManufacturingMaterials. The CTG 7 was developed based on the 1990 VOC assessment, the 2001 8 NESHAP, existing state VOC emission reduction approaches 9 such as California, and in consideration of information 10 obtained since the issuance of the 2001 NESHAP. 11 Resins containing styrene and gel coats 12 containing both styrene and methyl methacrylate (MMA) are 13 the main contributors of VOC emissions at fiberglass boat 14 manufacturing facilities. The proposed standards are 15 designed to reduce VOC emissions during fiberglass boat 

### 16 manufacturing operations. Not all the VOCs in the 17 materials used are emitted to the atmosphere, as some of 18 the VOCs are used in cross linking reactions of polymers 19 and are retained in the finished material. Thus, an 20 overall reduction of VOC content in production materials 21 reduces potential emissions from extraneous VOCs during



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### 10 1 the manufacturing process. 2 Cleaning activities other than surface 3 preparation also occur at facilities engaged in 4 fiberglass boat manufacturing. Cleaningmaterials are 5 used to remove residue or other unwantedmaterials from 6 equipment related to manufacturing operations such as 7 molds and prototypes, as well as the cleaning of 8 application equipment, transfer lines and other ancillary 9 

### equipment. These cleaningmaterials are typically 10 mixtures ofVOC containing solvents. The proposed 11 regulation includes emission control requirements for 12 cleaningmaterials consistent with those in the CTG. 13 The proposed regulation sets standards for 14 fiberglass boat manufacturing operations. Emissions of 15 VOCs from fiberglass boat manufacturing operations are 16 expected to be reducedby approximately 40 percent 17 nationally. Maryland only has few sources that may, on 18 occasion, assemble fiberglass boats frompre-manufactured 19 hulls and decks. Therefore, MarylandVOC emission 20 benefits will be negligible. The coatings industry 21 already has products available to meet VOC standards

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-555511 1 contained in the CTG and proposed regulation. The 2 maximumbenefit from VOC reductions will be provided 3 during the ozone season when VOCs readily combine with 4 NOx to form the pollutant ground level ozone. 5 The proposed standards are not more restrictive 6 than the federal CTG for fiberglass boat manufacturing

. 7 The proposed new regulation adopts the requirements of 8 the CTG for fiberglass boat manufacturing. EPA estimated 9 the economic impact of this regulation on a national 10 level at a cost effectiveness approximately $4,200/ton of 11 VOC controlled. The standards and requirements of the 12 CTG have alreadybeen implemented in other states and as 13 a result, cost of production of compliant materials has 14 come down from initial phase of implementation. As the 15 CTGs are implemented nationally, the costs of compliant 16 materials are expected to be reduced further. Due to the 17 limited number of affected sources, the economic impact 18 inMD will be small. 19 Maryland's State Implementation Plan (SIP) 20 This amendment and new regulation will be 21 submitted to the U.S. Environmental ProtectionAgency as

ForTheRecord,Inc. (301)870-8025-www.ftrinc.net-(800)921-555512 1 a revision to the Maryland's State Implementation Plan

. 2 Consideration of Comments 3 The Department will consider all comments before making a 4 decision to adopt the new regulation and amendment. 5 6 MR. MOSIER: Thank you, Mr. Waheed. 7 As indicated in the hearing notice, the close 8 of the comment period is close of business today. 9 This will conclude the public hearing regarding 10 the proposed amendments to Regulation .26, and new 11 Regulation .26-1, Control of Volatile Organic Compounds 12 from Fiberglass Boat Manufacturing under COMAR 26.11.19, 13 Volatile Organic Compounds from Specific Processes. Let 14 the record reflect that it is now 10:14 a.m. and this 15 hearing is officially concluded. 16 (Whereupon, the hearingwas concluded) 17 18 19 20 21

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13 1 

### CERTIFICATE OF COURT REPORTER 2 3 

### I, Jennifer Metcalf, do hereby certify that the 4 

### foregoing transcription was reduced to typewriting via 5 

### audiotapes recorded byme; that I am neither counsel for, 6 

### nor related to, nor employedby any of the parties to the 7 

### case in which these proceedings were transcribed; that I 8 

### am not a relative or employee of any attorney or counsel 9 

### employed by the parties hereto, nor financially or 

### 10 otherwise interested in the outcome of the action

. 11 12 13 14 15 

### 16 JENNIFER METCALF 17 Court Reporter 18 

### 19 20 

### 21

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