CONTROL OF VOC EMISSIONS FROM

FIBERGLASS BOAT MANUFACTURING MATERIALS

25 Pa. Code Chapter 129 

44 Pa. B. 4502 (July 19, 2014)

Environmental Quality Board Regulation #7-487

(Independent Regulatory Review Commission #3066)

Comment and Response Document

Bureau of Air Quality
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Control of VOC Emissions from

Fiberglass Boat Manufacturing Materials

On July 19, 2014, the Environmental Quality Board (Board, EQB) published a Pennsylvania 

Bulletin notice of public hearings and the written comment period on the proposed amendments to 

Chapter 129 (relating to standards for sources) for fiberglass boat manufacturing materials (44 Pa.B. 

4502). The proposed rulemaking would add provisions to Chapter 129 for the control of emissions 

of volatile organic compounds (VOC) from fiberglass boat manufacturing materials including open 

molding resins, gel coats and cleaning materials. The proposed rulemaking would establish VOC 

emission limitations and other requirements consistent with the reasonably available control 

technology (RACT) recommendations of the United States Environmental Protection Agency 

(EPA) 2008 Fiberglass Boat Manufacturing Materials Control Techniques Guidelines (CTG) for 

these sources in this Commonwealth. See Consumer and Commercial Products, Group IV: Control 

Techniques Guidelines in Lieu of Regulations for Miscellaneous Metal Products Coatings, Plastic 

Parts Coatings, Auto and Light-Duty Truck Assembly Coatings, Fiberglass Boat Manufacturing 

Materials, and Miscellaneous Industrial Adhesives, 73 FR 58481, 58483 (October 7, 2008). The 

EPA’s CTG document, Control Techniques Guidelines for Fiberglass Boat Manufacturing 

Materials, EPA 453/R-08-004, Office of Air Quality Planning and Standards, EPA, September 

2008, is available on the EPA’s website 

at: www.epa.gov/airquality/ozonepollution/SIPToolkit/ctgs.html.

The comment period opened on July 19, 2014, and closed on September 22, 2014. Three public 

hearings were held on the proposed rulemaking as follows:

August 19, 2014 Department of Environmental Protection 

1:00 PM Southwest Region Office 

Island Conference Room

400 Waterfront Drive 

Pittsburgh, PA 15222

August 20, 2014 Department of Environmental Protection 

1:00 PM Southeast Regional Office 

Schuylkill Conference Room

2 East Main Street 

Norristown, PA 19401 

August 21, 2014 Department of Environmental Protection

1:00 PM Rachel Carson State Office Building

Conference Room 105

400 Market Street

Harrisburg, PA 17105

 

This document summarizes the written comments received during the public comment period as 

well as those received from the Independent Regulatory Review Commission (IRRC). No

testimony was received during the public hearings. The Board invited each commentator to prepare 

a one-page summary of the commentator’s comments. No one-page summaries were submitted to 
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the Board for this rulemaking. Each comment is listed with the identifying commentator number 

for each commentator that made the comment. A list of the commentators, including name and 

affiliation (if any), can be found on page 4 of this document. 

The final-form regulation will be submitted to the U.S. Environmental Protection Agency (EPA) as 

a revision to the State Implementation Plan (SIP) upon final-form publication in the Pennsylvania 

Bulletin.

Copies of all comments received are posted on the IRRC web site at http://www.irrc.state.pa.us. 

Search by Regulation # 7-487 or IRRC # 3066. 

Acronyms used in this Comment/Response Document

PSATS – Pennsylvania State Association of Township Supervisors

VOC – Volatile Organic Compound
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Table of Commentators for the Environmental Quality Board

Control of VOC Emissions from Fiberglass Boat Manufacturing Materials

Rulemaking EQB #7-487

(IRRC #3066)

ID Name/Address

Submitted one 

page Summary 

for distribution

to EQB

Provided 

Testimony

1

Elam M. Herr

Asst. Executive Director

PSATS

4855 Woodland Drive

Enola, PA 17025-1291

no no

2

Independent Regulatory Review 

Commission (IRRC)

333 Market Street, 14th Floor

Harrisburg, PA 17101

no no

General Comment on Proposed Rulemaking

1. Comment: The Pennsylvania State Association of Township Supervisors (PSATS) wrote to 

IRRC, saying that the organization reviewed the Environmental Quality Board’s proposed 

regulation #7-487 (IRRC #3066) “Control of Volatile Organic Compound Emissions from 

Fiberglass Boat Manufacturing Materials” and concluded that it has no direct impact or financial 

cost to PSATS members. PSATS further stated that the proposed rulemaking would benefit 

PSATS members by controlling and limiting the volatile organic compound emissions from the 

air. PSATS wrote that, “Although our reading would indicate that the regulation is needed it does 

not directly impact our members so we will not be taking a position.” (1)

Response: The Board appreciates the comment and thanks IRRC for forwarding the comment to 

the Board. 

Clarity

2. Comment: IRRC recommended that the EQB clarify the requirements for sampling and testing 

in subsection (n) to provide for how often sampling and testing is to be conducted. (2)

Response: The Board agrees with IRRC’s recommendation. Language clarifying the timing and 

frequency of testing or sampling was added into final-form subsection (m) to address IRRC’s 

comment. Compliance of the monomer VOC content of the resin and gel coat materials must be 

demonstrated within 90 days of receipt of the Department’s written request. Testing of a VOC 

emissions capture system and add-on air pollution control device must be conducted one time every 

5 years starting from completion of the initial testing specified in the plan approval application

required under subsection (g).