ORIGINAL · 

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1 MARYLAND DEPARTMENT OF THE ENVIRONMENT 

2 AIR AND RADIATION MANAGEMENT ADMINISTRATION 

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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 

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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. 

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18 BEFORE: RANDY MOSIER, Hearing Officer 

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21 Reported by: Jennifer Metcalf 

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1 A P P E A R A N C E S 

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3 ON BEHALF OF THE MARYLAND DEPARTMENT OF THE ENVIRONMENT: 

4 RANDY MOSIER 

5 Chief 

6 Regulations Development Division 

7 Air and Radiation Management 

8 Maryland Department of the Environment 

9 1800 Washington Boulevard, Suite 730 

10 Baltimore, Maryland 21230 

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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 

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1 I N D E X 

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3 Speaker : Page : 

4 Opening Remarks, Randy Mosier, MDE 4 

5 Hearing Statement, Husain Waheed, MDE 5 

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1 P R 0 C E E D I N G S 

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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 Protection Agency'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 submitting my statement concerning the proposed 

19 amendments to Regulation .26 and proposed Regulation .26-

20 1 under COMAR 26.11.19, Control of Volatile Organic 

21 Compounds from Specific Processes. 

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2 Statement of the Air and Radiation 

3 Management Administration 

4 Department of the Environment 

5 for the Public Hearing Relating to Proposed 

6 Amendment to Regulation .26 Control 

7 of Volatile Organic Compounds from Reinforced Plastic 

8 Manufacturing and Proposed Regulation .26-1 Control 

9 of Volatile Organic Compounds from Fiberglass Boat 

1 0 Manufacturing under 

11 COMAR 26.11.19 Control of Volatile Organic Compounds 

1 2 from Specific Processes 

13 held on July 28, 2015 

14 Baltimore, MD 

1 5 My name is Husain Waheed. I am a Senior 

16 Re gulatory and Compliance Engineer with the Regulation 

17 Development Division of the Air and Radiation Management 

18 Administration, Maryland Department of the Environment. 

1 9 This public hearing is being held pursuant to 

20 the requirements of 40 CFR Section 51.102 and Secti ons 2-

2 1 301 et . seq. of the Environment Art i cle , Annotated Code of 

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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 

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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 boat manufacturing 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 

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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 Manufacturing Materials. 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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1 the manufacturing process. 

2 Cleaning activities other than surface 

3 preparation also occur at facilities engaged in 

4 fiberglass boat manufacturing. Cleaning materials are 

5 used to remove residue or other unwanted materials 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 cleaning materials are typically 

10 mixtures of VOC containing solvents. The proposed 

11 regulation includes emission control requirements for 

12 cleaning materials 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 reduced by approximately 40 percent 

17 nationally. Maryland only has few sources that may, on 

18 occasion, assemble fiberglass boats from pre-manufactured 

19 hulls and decks. Therefore, Maryland VOC emission 

20 benefits will be negligible. The coatings industry 

21 already has products available to meet VOC standards 

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1 contained in the CTG and proposed regulation. The 

2 maximum benefit 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 already been 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 in MD 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 Protection Agency as 

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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. 

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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 hearing was concluded) 

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1 3 

1 CERTIFICATE OF COURT REPORTER 

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3 I, Jennifer Metcalf, do hereby certify that the 

4 foregoing transcription was reduced to typewriting via 

5 audiotapes recorded by me; that I am neither counsel for, 

6 nor related to, nor employed by 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 . 

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16 JENNIFER METCALF 

17 Court Reporter 

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