Department of the Environment 

# Facts About...

COMAR 26.11.19. 2 6

- 1 Fiberglass Boat Manufacturing

0 3/02/2015

PURPOSE OF NEW REGULATION AND AMENDMENT

The new regulation COMAR 26.11.19.26

- 1

, Control of Volatile Organic Comp ounds from Fiberglass Boat Manufacturing

, adopts the requirements of the EPA’s Control Techniques Guidelines (CTG) for this category. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more

rest rictive standards. MDE proposes to adopt new volatile organic compound (VOC) limits, standards for application methods, and work practice requirements which are

consistent with the most recent CTG recommendations applicable to fiberglass boat manufacturing

. The new regulation affects manufacturers of fiberglass boats. COMAR

26.11.19.26

, Control of Volatile Organic Compounds from Reinforced Plastic Manufacturing

, is amended to exempt fiberglass boat manufacturing.

B ackground

The EPA first p ublished an asse ssment of VOC emissions from fiberglass boat manufacturing in 1990. This assessment evaluated VOC emissions from fiberglass boat manufacturing and p otential control options.

T he National Emission Standards for Hazardous Air Pollutants for Boat Manufacturi ng, 40 CFR part 63, subpart VVVV (2001 NESHAP) were promulgated in 2001.

Emission standards under t he 2001 NESHAP were for organic hazardous air pollutant s (HAP s ) based on low

- HAP resins and gel coats and low

- emitting resin application technology.

Califor nia and several other states ha ve specific regulations that control VOC emissions from fiberglass boat manufacturing operations, as part of their regulations for limiting VOC emissions from polyester resin operations.

In July 2008, the EPA published a ne w CTG for Fiberglass Boat Manufacturing

Materials. The CTG was developed based on the 1990 VOC assessment, the 2001 NESHAP, existing s tate VOC emission reduction approaches, and in consideration of

information obtained since the issuance of the 2001 NESHA P.

Requirement s

Resins contain ing styrene and gel coats contain ing both styrene and methyl methacrylate (MMA) are the main contributors of VOC emissions at fiberglass boat manufacturingfacilities

. The proposed standards are designed to reduce VOC emis sions during

fiberglass boat manufacturing operation s

. Not all the VOC s in the materials used are emitted to the atmosphere, as some of the VOCs are used in cross linking reactions of polymers and are retained in the finished material. Thus, an o verall re duction of VOC

content in production materials reduce s potential emission s from extraneous VOCs during the manufacturing process.

Cleaning activities other than surface preparation also occur at f acilities engaged in fiberglass boat manufacturing . Cleanin g materials are used to remove residue or other unwanted materials from equipment related to manufacturing operations such as molds and p rototypes , as well as the cleaning of application equipment , transfer lines and other ancillary equipment. These cleani ng materials are typically mixtures of VOC containing

solvents. The proposed regulation includes e mission control requirements for cleaning

materials consistent with those in the CTG.

Affected Sources

The proposed regulation affect s fiberglass boat man ufacturers

.

New Regulation and Amendment

COMAR 26.11.19. 2 6

- 1 is proposed to set the following standards for a fiberglass boat manufacturing facility with actual VOC emissions of 15 pounds or more per day:

Operation Application Method Monomer content (per cent by weight) Total Resin

VOC Content ( percent by weight )

Production resin Atomized resin

application (spray) 28 33

Production resin Nonatomized resin application 35 40

Pigmented gel coat Atomized or

nonatomized resin application 33 38

Clear gel coat Atomized or

nonatomized resin application 48 53

Tooling resin Atomized resin

application (spray) 30 35

Tooling resin Nonatomized resin

application 39 44

Tooling gel coat Atomized or

nonatomized resin application 40 45These monomer content limits are the same as those in the 2001 NESHAP. The

regulation also provides an alternative option of emission rates for monomers and non

monomers and exemptions for certain specific applications

.

The work practice requirements establish standards and record keep ing requirements for the usage of all VOC containing materials.

COMAR 26.11.19.26 Control of Volatile Organic Compounds from Reinforced Plastic Manufacturing is amended to exempt fiberglass boat manufacturing.

Impact on Ambient Air Quality

The proposed regulation set s sta ndards for fiberglass boat manufacturing operations

. Emissions of VOCs from fiberglass boat manufacturing o perations are expected to be reduced by approximately 40 percent nationally. M aryland only has one known source that may, on occas ion, assemble fiberglass boats from pre

- manufactured hulls and decks

. Therefore M aryland VOC emission benefits will be negligible

. The c oatings industry already has products available to meet VOC standards contained in the CTG and proposed regulation. The maximum benefit from VOC reductions will be provided during the ozone season when VOCs readily combine with NOx to f orm the pollutant ground

level ozone.

Economic Impact

The proposed new regulation adopt s the requirements of the CTG for fiberglass boat manufacturing

. EPA estimated the economic impact of th is regulation on a national level. Cost effectiveness is approximately $ 4,200 /ton of VOC controlled. Due to the limited number of affected sources, the economic impact in MD will be small.

Small Busi ness

The proposed regulation affect s fiberglass boat manufacturers . At a national level, EPA estimates the economic impact of using reformulated materials on small businesses is

low.

Submission to EPA as Revision to Maryland's SIP (or 111(d) Plan, or Ti tle V Program)

The proposed r egulation will be submitted to the U.S. EPA for approval as a revision to Maryland's State Implementation Plan.

Are there other State or federal requirements that apply to these sources?

The amendments and proposed regul ation adopt the requirements in EPA’s CTG for Fiberglass Boat Manufacturing

, July 2008

. There are no other federal reasonably available control technology standards for this category.