# Technical Support Document

Departme nt of the Environment 

## Amendments and New Adhesives and Sealants Regulations

Background

Adhesives, sealants, adhesive prim er, a nd sealant prim er are used in m a nufacturing, packaging, construction, and installation of disp arate m a terials such as m e tal, wood, rubber, plastic, ceram i cs, fiberglass and composites. An adhesive is any m a te rial used to bond two
surfaces. A sealan t is a m a terial with adhesive p r ope rties that is used p r im arily to fill and seal durably, openings between two surfaces. Volat ile organic co mpound (VOC) e m issions result
from evaporation of solv ents during surface preparation, transfer, application, drying and
clean ing operations. The solvents are mostly need ed to solubilize the adhesive, sealant, or prim er

m a terial for application. The so lvents prepare the surface to p r ovide a stro nger bond. In plastic pipe bonding, the solvent di ssolves the polyvinyl chloride pipe a nd reacts with the pipe to form a bond. Solvents used to clean th e surf ace before b onding and to clean the application equipm ent after bonding also contribute to VOC em issions. VOC e m issions from adhesives and sealants are prim arily from industrial and commercial opera tions such as general m a nufacturing, wood product m a nufacturing, upholstery shops, adhesives re tailers and architectural trades, such as building construction, floor covering installation and roof repair.

COMAR 26.11.19.15 Paint, Resin, and Adhe sive Manufacturing and Adhesive Application, has standards for honeycom b core m a nufacturing, footw ear m a nufacturing and spiral tube impregnating operations. Under COMAR 26.11.19.15C(4), General Em is sion Standards, up to 50 pounds per day of VOC e m is sions are allowed. A source that em its 50 pounds or more of VOC em issions must m eet 3.8 pounds per gallon VOC lim it or 80 percent overall control requirem ents. The Ozone Transp ort Comm ission (OTC) model rule for adhesives and sealants applie s to th e s ources that are covered by the ge neral em ission standards.

COMAR 26.11.19.30 Control of Volatile Organic Com pounds from Chem ical Production and Polytetrafluoroet hylene Operations contains requirem e nts for the control of

em issions from installations and also exem pts s m all source em issions from controls. Under this regulation, d i fferent control requ irements app l y if the em issio n s exceed either 20 or 5 0 lbs/day. At higher than 20 lbs/day em ission level, a VOC standard becom e s applicable. Above 50 lbs/day, controls are requ ired to be in stalled.

Purpose of Amendments and New Regulations

1 The prim ary purpose of this action is to: 1) am end COMAR 26.11.19.15 Paint, Resin, and Adhesive Manufacturing and Adhesive App lication and rem ove Section C(4) of this regulation; 2) am end COMAR 26.11.19.30 Contro l of Volatile Organic C o m pounds fr om Che m ical Production and Polytetrafluoroethylene Op erations to apply the regulations to fluoro polym er m a terials and exem pt very sm all operati ons that em i t less than 400 pounds a year from

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Martin O ’ Malley, Gov e rnor | Anthony G. Brown, Lt. Govern or | Shari T

. Wilson, Secr et

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yadhesive application; and 3) propose new regulations unde r C O MAR 26.11.35 Control of VOC

Em issions from Adhesives and Sealants. The OTC 2006 m o del rule for adhesi ves and sealants is based on the reasonably available control technology (RAC T) and best available retrofit control technology (BARCT) determ ination by the Calif or nia Air Resources Board (CARB) developed in 1998. The proposed regulations have the following requirem e nts:

A. Regulate the application of adhesives, sealants, adhesive primers and sealant prim ers by providing options for appliers to either use a product with a V O C content equal to or less than a specified lim it or to use add-on controls;

B. Standards for adhesives and sealants;

C. Standards for adhesive and sealant prim ers;

D. Standards for adhesives applie d to listed and other substrates;

E. Standards for cleanup solvents;

F. A VOC lim i t for surface preparation solvents ;

G. An alternative add-on control system re quirem e nt of at least 85 percent overall

contro l efficiency (captu re and destruction), by weight;

H. Provide exemptions for certain operations such as m e dical, aerospace

com ponents, undersea-based ship and weapons system s com p onents, electronic system s and subsystem s for defense and hom eland security and sm all containers;

I. Require records of m a terials used and VOC cont ent to be m a intained for 5 years.

J. VOC containing m a terials m u st be stored or disposed of in closed containers;

K. Prohibit the sale of any adhesive, seal ant, adhesive prim er or sealant prim er which excee ds the VOC content lim its;

L. Manufacturers m u st label containers with the m a xim u m VOC content as supplied,
as well as th e m a xi m u m VOC content on an as-ap p lied ba sis when used in accordan ce with the

m a nufacturer’s recomm e ndations regarding thinning, reducing, or m i xing with any other VOC containing m a terial; and

M. Prohibit the specification of any adhesive , prim er, or sealant that violates the provisions of the proposed regulations.

Exemptions

2 Several adhesive and sealant applications and products are exem pt from the proposed regulations: tire repair , assem b ly and m a nufacturing of undersea-based ship and weapons

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Martin O ’ Malley, Gov e rnor | Anthony G. Brown, Lt. Govern or | Shari T

. Wilson, Secr et

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ysystem s components, specialty electronic syst em s and subs ystem s for defense and hom e land security, testing and evaluation associated with research and developm ent, solvent welding operations for m e dical devices, plaque lam i natin g operations, products or processes subject to other State rules, low-V O C products (less than 20 g/l), and sm all container adhesives subject to
the consum er products regulations. Addition a lly, the proposed regulations provide an exem ption for adhesive application operations at stationa ry sources that use less than 55 gallons per calendar year of noncomplying adhesives and for st ationary sources that em it not m o re than 200 pounds per calendar year of VOCs. A facility can claim exemption for on e of the two options, granted that the facility m eet the requirem ents. Adhesives and s ealan ts used by contracto r s a t a facility that do not m eet the st andards have to be included in this total for exem ption. This

exem ption has been r e ta ined to allow f acilities li m ited use of adhesives and sealants that do not

m eet the standards for s p ecific purp o ses. Additi onally, sm all containers are exem pt from the regulations as they are regulated under the consum er products regu lations and are m o stly used by
hom e owners and not co mmercial, in dustrial o rin stitu tion a l o p erations.

Sources that are subject to the requ irem ents of COMAR 26.11.19.15C(4) General

Em ission Standards and will be ex empt from the requirem e nts of COMAR 26.11.35 after the regulations becom e effe ctive would have to m eet the RACT requirem e nts as established by the Departm e nt. RACT requirem ents will be deve lop e d for specialty electronics system s and subsystem s for defense and hom eland security. Facilities that fall unde r SICs for electronic
system s such as 3671, 3672, 3812 and 3825 will be covered under the review.

Consum er products regulate d under COMAR 26.11.32 have st andards for adhesives and
sealants in sm all containers th at are exem pt from COMAR 26.11.35.

Medical devices subject to COMA R 26.11.19.31 Control of Medical Device Manufacturing are exem pt from the requirem e nts of COM A R 26.11.35 since they already m e et the RACT requirem e nts in COMAR 26.11.19.31.

Affected So urces

The proposed regulations apply to any pe rson who, on or after January 1, 2009, sells, supplies, offers for sale or m a nufactures for sa le in the State any adhesive, sealant, adhesive prim er or sealant p r im er for use in th e State. Th ey also apply to any person who uses or applies
for com p ensation any adhesive, seal a n t, adhes i ve prim er or se alant p r im er within th e State.

Sources subject to COM A R 26.11.19.30 Contro l of Volatile Organic Compounds from
Che m ical Production and Polytetrafluoroethyl ene Operations are exem pt from COMAR 26.11.35. RACT requirem e nts for these operatio ns are in CO MAR 26.11.19.30 along with the

exem pt operations such as the ones that em it less than 400 pounds a year from adhesive application. These sources have to m eet the re quirem ents of the regul ations for the general application of adhesives and sealants.

3 Medical devices subject to COMA R 26.11.19.31 Control of Medical Device Manufacturing are exem pt from the requirem e nts of COM A R 26.11.35 since they already m e et

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Martin O ’ Malley, Gov e rnor | Anthony G. Brown, Lt. Govern or | Shari T

. Wilson, Secr et

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ythe RACT requirem e nts in COMAR 26.11.19.31. Re quirem e nts of COM A R 26.11.35 apply for general uses of adhesives and sealants.

Sources that are subject to the re quirem ents of COMA R 26.11.19.15C(4) General

Em ission Standards and are exem pt from the requirem e nts of COMAR 26.11.35 after the regulations becom e effe ctive would have to m eet the RACT requirem e nts.

Record Keeping Requirements

Record keeping requirem ents include VOC content data, purchase records and quantity used for compliant products, research and deve lopm ent and for 55 gallon usage exemption. More detailed records are required when non-com p liant products are used for the 200 pounds per year

exem ption. These lim its apply facility wide. Adhe sives and sealants used by contractors at a facility need to be included in the total estim ate of the fac ility. W o rk conducted by contractors independently is accounted for in the total for the contractor. If e m issions exem ption is being used, it will be necess a ry to keep th e de tailed records to ju stify com p liance.

Control Technology

VOC e m issions from industrial adhesives and se alants can be controlled by reform ulation of adhesives, sealants, and cleanup solvents. If reform ulation is not feasible then the use of addon control is required. Refor m ula tion is a significantly m o re co st-effective control m e thod for
VOC e m issions from adhesives and sealants than add-on controls. Reformulation requires either
an increase in the solids content o r replacem ent of VOCs with water or ex em pt solvents. The
RACT VOC lim its for adhesives and sealants ar e based on products that have been used for application in the industry. Low-VOC and water- based adhesives som e tim e s require additional drying tim e , additional equipm ent and special t echnical requirem e nts. The low-VOC a nd waterbased adhesives m a y have slightly different pe rform a nce characteristic s. T o m e et cer ta in perform a nce characteristics, som e applications m a y require the use of add-on control equipm ent to continue using noncomplying products. The most commonly us ed methods of controlling VOCs are carbon adsorption and incineration. Cont rol equipm ent is required to m e et an 85 percent overall control efficienc y, which is the product of capture and destruction efficiency. Carbon adsorption and incineration system s achieve high control efficien cies but have large capital and o p erating cos t s.

Emissions Estimates a nd Reductions

EPA' s 2002 inventory is docum ented in "Sol vent Mass Balance Approach for Estim ating
VOC Emissions from Eleven Nonpoint Solv ent Source Categories. " The m e thodology for
industrial adhesives is de scribed in this report. Appendix E, page E-7, shows that the 2002 VOC

4 em issions for Maryland to be 6.65 tons/day for in dustrial adhesives and sealants. This is the value used as the starting point. The 2 002 em issi ons were projected to 200 9 taking into account anticipated employm e nt and population growth. The growth factor for em issions was taken into account, and the 2009 VOC e m issions from Maryland i ndustrial adhesives were calculated to be 7.26 tons/day.

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Martin O ’ Malley, Gov e rnor | Anthony G. Brown, Lt. Govern or | Shari T

. Wilson, Secr et

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yThe technical analysis conducted through the OTC estim ated that the m o del rule would
achieve em i ssion reductions corre sponding to about 64 to 78 per cent reduction from uncontrolled
levels. The em ission reduction estim ate for Maryland based on the lower end of this range is 5.66 tons/day of VOC in 2009.

Economic Impact

The cost of com p lying with the new require m e nts includes the cost of using alternative
for m ulations of low-VOC or water-based adhesi ves, sealants, adhesive prim ers, and sealant prim ers and cleanup products. CARB determ ined th at the cost-eff ectiveness of th eir adhesives regulations ranges from a savi ngs of $1,060 per ton to a cost of $2,320 per ton of VOC reduced. These costs are likely to be le ss in this region because som e of the costs are one-tim e research
and reform ulation costs that have already been incurred by m a nufacturers for products sold in
California. CARB also estim ates a cost-e ffectiveness of $9,000 to $110,000 per ton of VOC reduced for the use of add-on control equipm ent to com p ly.

L:\AQPlanning and Monitoring\Regulation Develo pm ent Division\Model Rules\Adhesives and Sealants\TS D \26-11-35 A&S TSD 12-12-07.doc

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. Wilson, Secr et

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