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1 MARYLAND DEPARTMENT OF THE ENVIRONMENT

2 PUBLIC HEARING

3

4 STATEMENT OF THE

5 AIR AND RADIATION MANAGEMENT ADMINISTRATION

6 PROPOSED ADHESIVES AND SEALANTS VOC REGULATIONS

7 UNDER COMAR 26.11.35 AND

8 AMENDMENTS TO CONTROL OF VOCs FROM CHEMICAL

9 PRODUCTION AND POLYTETRAFLUOROETHYLENE INSTALLATIONS

10 UNDER COMAR 26.11.19.30

11

12 The hearing in the above matter commenced on

13 Wednesday, January 23, 2008, at the MDE Headquarters,

14 Montgomery Park, 1800 Washington Boulevard, Baltimore,

15 Maryland.

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17

18 BEFORE: DEBORAH RABIN, Hearing Officer

19

20 Reported by: Frank Quinn

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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 DEBORAH RABIN

5 Regulation Development Coordinator

6 Regulation Development Division - ARMA

7 Maryland Department of the Environment

8 1800 Washington Boulevard, Suite 730

9 Baltimore, Maryland 21230

10

11 HUSAIN WAHEED

12 Public Health Engineer

13 Air and Radiation Management Administration

14 Maryland Department of the Environment

15 1800 Washington Boulevard, Suite 730

16 Baltimore, Maryland 21230

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1 I N D E X

2

3 Speaker: Page:

4 Deborah Rabin, MDE 4

5 Husain Waheed, MDE 6

6 Joe Miedusiewski, EPDM 10

7 Bill Schneider, EPDM 12

8 Mike Ducharme, EPDM 19

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

2 (10:12 a.m.)

3 MS. RABIN: Good morning. On behalf of the

4 Department of the Environment and the Air and Radiation

5 Management Administration, we’d like to welcome you to

6 this public hearing.

7 My name is Deborah Rabin. I am the Regulations

8 Coordinator for the Department -- for the Air and

9 Radiation Management Administration. I will serve as the

10 hearing officer today for this 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 those who

14 attend the hearing. Also, copies of the regulation

15 proposal, the support documents and the Department’s

16 statement are available on the table for your

17 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 .30 under COMAR

22 26.11.19, Volatile Organic Compounds from Specific
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1 Processes, and adopt new Regulations .01 through .07

2 under a new chapter, COMAR 26.11.35, Control of Emissions

3 of Volatile Organic Compounds from Adhesives and

4 Sealants.

5 The purpose of this hearing is to give you an

6 opportunity to comment on this action.

7 The opportunity for public comment for this

8 proposed action appeared in the Maryland Register, Volume

9 34, Issue 26, page 2300, on December 21, 2007.

10 The hearing will proceed in the following

11 order. First, Mr. Husain Waheed will make a statement on

12 behalf of the Department and the Air and Radiation

13 Management Administration. After Mr. Waheed has

14 finished, I will call on any elected official or

15 government official who wants to make a statement. Then

16 I will call upon anyone else who indicated on the sign-in

17 sheet that he or she would like to make a statement.

18 When giving your statement, please come up

19 front, and identify yourself and your affiliation, and

20 give your statement loudly and clearly. Are there any

21 questions?

22 (No response.)
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1 MS. RABIN: I will now call on Mr. Waheed.

2 MR. WAHEED: Statement of the Air and Radiation

3 Management Administration, Department of the Environment

4 for the Public Hearing Relating to Proposed Adhesives and

5 Sealants VOC Regulations under COMAR 26.11.35 and

6 Amendments to Control of VOCs from Chemical Production

7 and Polytetrafluoroethylene Installations under COMAR

8 26.11.19.30 held on January 23, 2008, Baltimore,

9 Maryland.

10 My name is Husain Waheed. I am the Public

11 Health Engineer of the Regulation Development Division of

12 the Air and Radiation Management Administration,

13 Department of the Environment.

14 This public hearing is being held pursuant to

15 the requirements of 40 CFR Section 51.102 and Sections 2-

16 301 of the Environment Article, Annotated Code of

17 Maryland. It is also being held in conformance with the

18 State Administrative Procedures Act under the State

19 Government Article, beginning at Section 10-101.

20 Notice of this hearing appeared in the Maryland

21 Register on December 21, 2007; MDE’s website from

22 December 12, 2007 to January 23, 2008; Baltimore Sun on
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1 December 21, 2007; St. Mary’s Enterprise on December 21,

2 2007; Cumberland Times-News on December 21, 2007;

3 Frederick News-Post on December 21, 2007; Salisbury Daily

4 Times on December 21, 2007; and The Washington Post on

5 December 20, 2007. Copies of these notices were

6 submitted for the record.

7 Copies of the proposed action and supporting

8 documents were submitted for review to the State

9 Clearinghouse and are also submitted at this time into

10 the hearing record. Copies were also made available for

11 public inspection at the Air and Radiation Management

12 Administration offices in Baltimore, Cumberland and

13 Salisbury and at all local health departments or local

14 air quality control offices.

15 The purpose of today’s hearing is to give the

16 public an opportunity to comment on the new Regulations

17 .01 through .07 under a new chapter, COMAR 26.11.35,

18 Control of VOC Emissions from Adhesives and Sealants and

19 proposed amendments to Regulation .30 under COMAR

20 26.11.19, Control of Volatile Organic Compounds from

21 Chemical Production and Polytetrafluoroethylene

22 Installations.
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1 Summary. The proposed regulations, Control of

2 VOC Emissions from Adhesives and Sealants under a new

3 chapter, COMAR 26.11.35, beginning January 1, 2009,

4 accomplish the following:

5 A. Set standards for the application of

6 adhesives, sealants, and adhesive primers and sealant

7 primers by providing options for appliers to either use a

8 product with a VOC content equal to or less than a

9 specified limit or to use add-on controls;

10 B. Establish standards for cleanup solvents;

11 C. Establish a VOC limit for surface

12 preparation solvents.

13 D. Provide for an alternative add-on control

14 system requirement of at least 85 percent overall control

15 efficiency (capture and destruction), by weight;

16 E. Provide exemptions for certain operations

17 such as medical and defense equipment manufacturing and

18 for small containers.

19 F. Require simplified records of materials

20 used and VOC content to be maintained for five years. 

21 More detailed records are required for non-compliant

22 products on material usage from persons who qualify for
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1 exemptions;

2 G. Require that VOC-containing materials must

3 be stored or disposed of in closed containers.

4 H. Prohibit the sale of any adhesive,

5 sealant, adhesive primer or sealant primer that exceeds

6 the VOC content limits;

7 I. Require manufacturers to label containers

8 with the maximum VOC content as supplied, as well as the

9 maximum VOC content on an as-applied basis when used in

10 accordance with the manufacturer’s recommendations

11 regarding thinning, reducing, or mixing with any other

12 VOC containing material; and

13 J. Prohibit the specification of any

14 adhesive, primer, or sealant that violates the provisions

15 of the proposed regulations.

16 The basis for the adhesive and sealant

17 regulations is a regional model rule developed by staff

18 of member states, including Maryland, and the Ozone

19 Transport Commission in 2006. The model rule itself was

20 based in large part upon the reasonably available control

21 technology (RACT) and the best available retrofit control

22 technology (BARCT) determination developed in 1998 by
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1 California Air Resources Board. Based upon a review of

2 those standards and comments received at public meetings,

3 the OTC states finalized a model rule suitable for

4 implementation in the Northeast in early 2007. The

5 proposed adhesives and sealant regulations reflect

6 amendments to the OTC model rule made by the Department

7 in response to comments received during the Maryland

8 stakeholder process.

9 Amendments to COMAR 26.11.19.30 expand the

10 regulation to include fluoropolymer materials and

11 establish an exemption level for the applicability of

12 standards under COMAR 26.11.35 for adhesive application.

13 Maryland’s State Implementation Plan. These

14 amendments and new regulations will be submitted to the

15 U.S. Environmental Protection Agency as a revision to the

16 Maryland State Implementation Plan.

17 Consideration of Comments. The Department will

18 consider all comments before making a decision to adopt

19 these amendments and new regulations.

20 MS. RABIN: Would anyone like to comment on

21 this proposed action?

22 MR. MIEDUSIEWSKI: We would.
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1 MS. RABIN: Would you like to introduce

2 yourselves?

3 MR. MIEDUSIEWSKI: Yes. My name is Joe

4 Miedusiewski, and I’m here on behalf of the roofing --

5 Rubber Roofing Institute, an association called EPDM,

6 also known as ERA. I have two colleagues with me

7 representing the association, Bill Schneider and Mike

8 Ducharme.

9 I would like to begin by saying that for the

10 record we would like to discuss the products that in the

11 proposed regs are referred to from the California Air

12 Board. And while those products are available and they

13 work, in our opinion, in a temperature that’s conducive

14 to California, in Maryland, the Mid-Atlantic states and

15 Northeastern states, there is a temperature fluctuation.

16 And we believe that the performance of the

17 product below 50 degrees isn’t what it needs to be. And

18 given the significant number of square footage, I think

19 it’s 22 million square feet of rubber roofing on these

20 low sloped roofs that are put on on both commercial and

21 government buildings, we would suggest in our comments

22 today that there be some accommodation, at least in the
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1 short term, either until something else comes on board

2 that will perform in the colder temperatures, that in

3 Maryland when the temperatures do dip that the roofing

4 industry be allowed to use the higher VOC-emitting

5 adhesives for the rubber roof systems. So, that’s what

6 we’re here for today is to offer our suggestions and our

7 comments about the regulation.

8 I’m going to turn it over to people who are

9 much more technically qualified than I am and, again,

10 Mike Ducharme and Bill Schneider will address those

11 technical points.

12 MS. RABIN: Thank you.

13 MR. SCHNEIDER: Thanks, Joe. And thank you

14 very much for allowing us this opportunity today. My

15 name is Bill Schneider. I’m Carlisle SynTec’s manager

16 for R&D of EPDM systems, and Carlisle SynTec is a member

17 of ERA, which is the EPDM Roofing Association.

18 This association is a trade association that

19 represents manufacturers of EPM single-ply roofing

20 products, as well as their major suppliers. EPM has been

21 used as a roofing product from the early 1960s. Today,

22 EPM is the preferred roofing product in the Northeast and
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1 Mid-Atlantic and has been used for over 40 years with 20

2 billion square feet installed. On an annual basis, over

3 1 billion square feet of EPM is installed annually.

4 As has been mentioned by Joe, our concern is

5 with the OTC model rule for controlled VOCs of adhesives,

6 specifically the single-ply roofing adhesives, sealants

7 and primers. The OTC model rule is essentially identical

8 to a similar rule published by California Air Resources

9 Board in 1998. The provisions of the CARB -- the

10 resources board rule were adopted in regulatory form by

11 various pollution-control districts in the State of

12 California.

13 Although the CARB model rule is described in

14 the preamble of the OTC model rule to be a reasonably

15 available control technology, the CARB rule was developed

16 in a region of the United States with climatic and

17 economic factors that differ significantly from the

18 Northeast United States.

19 As part of my discussion here today, I’ll be

20 talking mainly on the technical aspects of single-ply or

21 EPM roofing and how the adhesive sealants are used and

22 then also get into a little bit of the climatic
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1 differences.

2 VOCs and modern low-slope commercial roofing

3 systems come primarily from three sources: splicing

4 adhesives, which are used to splice the edges of the

5 roofing membrane together; bonding adhesives, which are

6 used to bond the surface, the entire surface of a

7 membrane to substrates and walls; and sealants, which are

8 used to seal and flash edges and terminations along walls

9 and along other roof projections.

10 Of the three product categories, two categories

11 already employ low VOC formulations throughout the U.S.

12 and North America. In the case of splice adhesives,

13 almost all of our EPM roofing seams are currently mated

14 using a 100 percent solids tape product. And, in fact, a

15 good percentage of this tape is applied in our factories

16 prior to it arriving at the rooftop.

17 In the case of sealants, low VOC 100 percent

18 solids products are both widely available and widely used

19 throughout North America. Given the widespread use of

20 the low VOC technologies for both splicing and sealants,

21 the remaining category, bonding adhesive, is the one that

22 is accountable for the overwhelming majority of VOCs
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1 produced in commercial roofing.

2 And the amount of VOCs generated by bonding

3 adhesives may vary with the type of roofing system. In

4 the case of single-ply membranes, the predominate

5 adhesives are contact adhesives. These adhesives are

6 sprayer-able applied both the membrane and the substrate,

7 and they’re allowed to dry, and then the surfaces are

8 mated together. These adhesives are composed of

9 polymeric resins and suspended in a variety of solvents.

10 The majority of the solvents in single-ply

11 bonding adhesive used today contain VOCs at rates higher

12 than the 250 grams per liter in the model rule. Examples

13 of these solvents include toluene, heptane and hexane. 

14 Because they volatize relatively -- at relatively low

15 temperatures, they allow for the effective application of

16 the single-ply roof membranes but in a relatively wide

17 temperature range, from freezing up to 100 degrees

18 Fahrenheit and beyond. Because of this wide useful

19 temperature range, bonding adhesives using high VOC

20 solvents are the preferred product choice for the

21 commercial roofing contractor.

22 Roof membrane bonding adhesives may also be
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1 formulated using low VOC solvents, including water. 

2 Because these solvents do not volatize at low

3 temperatures, their operating range is typically limited

4 to temperatures consistently at or above 40 degrees. In

5 addition, because they tend to volatize more slowly than

6 high VOC solvents, they are much more affected by ambient

7 conditions such as humidity and solar shading factors.

8 As an example, roofing membranes closed

9 partially to the sun and partially to the shade may

10 overdry in the sunlit surface while the shaded surface

11 remains too wet for installation. If the adhesive is

12 allowed to dry too long, the bonding may be weakened and

13 the overall ability of the roof system to resist wind

14 uplift is compromised. If the adhesive is too wet, the

15 membrane is installed, the roof will likely blister and

16 compromise the overall adhesion. As a consequence, the

17 effective use of these adhesives, even under optimal

18 temperature conditions, requires significant awareness,

19 training and experience on the part of the roofing crew.

20 Currently high VOC bonding adhesives dominate

21 the commercial roofing market. Shipping reports from EPM

22 Roofing Association members indicate that over 95 percent
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1 of all single-ply bonding adhesives sold in the U.S.

2 continue to employ high VOC formulations.

3 The only region in the country where low VOC

4 bonding adhesives currently dominate is the State of

5 California, where low VOC bondings have been mandated

6 since the late 1990s. This would appear to indicate that

7 customer preference will be difficult to change without a

8 mandated regulation; however, it also suggests that a

9 little learning, preparation or adaptation to the special

10 application requirements of low VOC adhesives has

11 occurred outside the mandated regions.

12 The comparison of the climate between

13 California and Maryland indicates both similarities and

14 contrasts. In our packet that we supplied to you folks

15 we’ve got some charts in there that show the comparison

16 max and min temperatures and also extreme temperature

17 ranges between Baltimore and Los Angeles and between

18 Hagerstown, Maryland and Oakland, California.

19 Just to summarize what those tables say,

20 basically during the summer months, June through August,

21 the highs and lows are pretty much identical. During the

22 late spring, early fall, the temperatures between the
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1 California cities and the Maryland cities begin to widen

2 as the average high and low temperatures in Maryland

3 decline below the averages for the California cities.

4 In the early fall and late spring, both high

5 and low average temperatures for the Maryland cities fall

6 within the operating range for currently available VOC7 compliant membrane bonding adhesive technologies that

8 were mentioned previously. It should be noted that the

9 period from May through September, when average

10 temperature in the Maryland cities falls within the range

11 of current VOC-compliant bonding adhesive technology,

12 this coincides with the ozone season for the Northeast

13 United States as defined by the OTC.

14 The average temperature differentials between

15 the two states increases further, however, during the

16 late fall, winter and early spring, with average

17 temperatures for the Maryland cities declining, dropping

18 below 40 degrees Fahrenheit.

19 During the months from November through March,

20 average temperatures for the Maryland cities are either

21 well below or barely at the minimum operating

22 temperatures required for the current VOC-compliant
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1 membrane adhesive technology.

2 It should be noted that the period from October

3 through April when average temperatures in Maryland drop

4 below the range of current VOC-compliant technology falls

5 outside the ozone season for the Northeast United States

6 as defined by the OTC.

7 Even during most extreme events recorded, the

8 high and low temperatures in the California cities still

9 fall within the operating range of currently available

10 VOC-compliant technology. In Maryland, however, the

11 designated ozone months of May and September, which

12 appear to be hospitable to low VOC bonding adhesive in

13 terms of average temperatures may frequently experience

14 low temperatures well below the 40 degrees minimum for

15 successful application of such pieces.

16 I’ll turn it over.

17 MR. DUCHARME: Okay, I’ll pick it up from

18 there. I’m Mike Ducharme. I’m the Chairman of the EPDM

19 Roofing Association, as well as the Director of Product

20 Marketing for Carlisle SynTec. I would like to expand

21 upon what Bill Schneider has provided as testimony and

22 give you a little bit of additional background and then
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1 some recommendations that we think would provide

2 potential solutions for the seasonality issue.

3 As far as the roofing industry as a whole, it

4 used to be dominated by asphaltic products, build-up

5 roofing, as we call it in the industry, they used to be

6 the predominate roofing type used up through the ‘70s,

7 until we got into some of the oil shocks that occurred in

8 that mid-decade period. At that point, we started to see

9 some changes in product, the asphalt quality declined,

10 and they also started to insulate buildings more, and it

11 led to problems with the existing technology. And that’s

12 pretty much when single-ply took off and really increased

13 in usage.

14 It is now the dominate roofing type used in the

15 industry. And Maryland is no exception to that trend. 

16 The preference for more flexible, longer term products

17 really has appeal in this market because we do get into

18 some significant freezing temperatures, which varies from

19 what we experience in California.

20 Just to give you some statistics on that, in

21 the State of California, EPDM would account for about 2

22 percent of the volume put down; build-up would be about
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1 69 percent of that market. In the State of Maryland, the

2 asphaltic membranes are about 46 percent of the market,

3 and EPDM is 33 percent.

4 Three million square feet of EPDM are installed

5 in California, but it’s about 20 million square feet of

6 EPDM installed in this state, so, you know, it is a big

7 part of the roofing industry in the State of Maryland.

8 Maryland’s largest commercial roofing

9 contractors, one of the challenges we face, have received

10 no formal training in the usage of the low VOC adhesives,

11 and that’s a key issue. There are literally thousands of

12 contractors that would need to have some retraining. At

13 this point, we calculate less than 1,000 gallons of low

14 VOC product have been shipped into the State of Maryland

15 in 2007, so it’s still a small part of the product put

16 down.

17 Other issues that we feel are important when

18 evaluating this are the risks associated with roofing

19 technology. As far as wind exposure, roof systems have

20 to perform in very extreme winds. California, most of

21 that state is in a 70-mile-per-hour wind zone. Most of

22 the State of Maryland exceeds that. I think we’re in a
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1 90-mile-per-hour peak wind zone. And out towards the

2 coast, we even experience more severe winds than that, so

3 the forces that these roofs are put under are extreme,

4 and changes in technology represent a great risk. 

5 Typically, as Bill mentioned, you know, these roofs have

6 been being installed for over 40 years. A change that’s

7 rapid within the industry represents great risk.

8 Another concern we have is the potential to

9 disrupt construction activity based on the seasonality

10 issue that low-VOC products cannot be installed in

11 freezing temperatures. So, the roofing contractors, who

12 today can work pretty much 12 months of the year, would

13 be restricted to the months where the low-VOC products

14 would work. So, it would bring roofing virtually to a

15 standstill in those winter months. You know, and that’s

16 a concern.

17 That would also have an impact on overall

18 construction because typically the roofing portion of the

19 project is one of the first aspects of a job taken on,

20 and that would hold back the other trades. So, it does

21 have some ramifications that would extend to the entire

22 construction industry.
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1 Based on that -- you know, as far as some of

2 our conclusions, we do as an association recognize the

3 need to take action to reduce VOC emissions, but we feel

4 the industry will require some accommodation to permit

5 contractors to be trained and to ensure that rooftop

6 performance is not negatively impacted.

7 At the time of year when ozone formation is of

8 greatest concern, especially during the peak ozone months

9 of July, August and September, temperature conditions are

10 generally suitable for the usage of the current low-VOC

11 bonding adhesive products without having any major impact

12 on roofing performance or practice.

13 During the colder seasons of the year when the

14 ozone formation is not a concern, traditional higher VOC

15 adhesives could still be made available. A two-season

16 approach may offer an effective optimization of the

17 competing goals of VOC reduction and effective roofing

18 practice.

19 What we would recommend is a seasonal approach

20 for the usage of the model for commercial roofing. What

21 we’d be recommending is permitting the use of the low-VOC

22 products during the ozone season months of May through
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1 September and then going to the higher VOC products in

2 the colder months of the year.

3 As an industry, if -- you know, with that

4 accommodation, I can assure you that we would continue to

5 work to develop solutions that would permit us to

6 eventually work away from this seasonal approach. I know

7 the manufacturers who are involved in the EPDM Roofing

8 Association are actively involved in R&D efforts and work

9 in their plants to gear up for production of products

10 that could meet these standards, but we are not there,

11 and we do need more time.

12 This type of approach would also give us the

13 opportunity to conduct training. I give you the

14 commitment of the EPDM Roofing Association that within

15 2008 we will embark on a training program to make people

16 more aware of the low VOC technology and get them ramped

17 up to start using these products so that when 2009 rolls

18 around they will be ready, but we do need a lot of time. 

19 There are thousands of contractors out there, and it will

20 take some time to reach all those contractors and get

21 them adequately trained.

22 That pretty much concludes my comments. We
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1 would take questions, or we wait until the end?

2 MS. RABIN: Well, typically we take all the

3 comments and then we respond to the comments in writing. 

4 And if you would like to have a copy of that, we can make

5 sure you get a copy of that, the response to comments

6 document.

7 MR. DUCHARME: Thank you.

8 MS. RABIN: Thank you very much for your

9 comments. Would anybody else like to comment on this

10 proposed action?

11 (No response.)

12 MS. RABIN: That will conclude the public

13 hearing regarding the proposed amendments to Regulation

14 .30 under COMAR 26.11.19, Volatile Organic Compounds from

15 Specific Processes, and new Regulations .01 through .07

16 under a new chapter, COMAR 26.11.35, Control of Emissions

17 of Volatile Organic Compounds from Adhesives and

18 Sealants. Let the record reflect that it is now 10:37,

19 and this hearing is officially concluded.

20 (Whereupon, the hearing was

21 concluded.)

22
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1 CERTIFICATE OF COURT REPORTER

2

3 I, Frank Quinn, 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.

11

12

13

14

15 

16 FRANK QUINN

17 COURT REPORTER

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