## 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

- 4 87 (Independent Regulatory Review Commission # 3066 )



# Comment and Response Document

Bureau of Air Quality2 of 4 

### Control o f VOC Emissions f rom 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 f iberglass boat manufacturing materials ( 4 4 Pa.B

. 4502 ). The proposed rulemaking would add pro visions 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 Tec hniques 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 Tr uck 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

- 0 04, 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 1 9, 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 171 05

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 submitte d to3 of 4 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 th e IRRC web site at http://www.irrc.state.pa.us

. Search by Regulation # 7

- 4 87 or IRRC # 3066

.

Acronyms used in this Comment/Response Document

PSATS

– Pennsylvania State Association of Township Supervisors

VOC

– Volatile Organic Compound4 of 4 

### Table of Commentators for the Environmental Quality Board

Control of VOC Emissions f rom Fiberglass Boat Manufacturing Materials Rulemaking EQB #7

- 4 87 (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, 14 th 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 wil l 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 co ntrol 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)

.