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OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

24) 11-1-24 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:21 PM Sheet 24 of 114 
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ST^WT^CT MARYLAND DEPARTMENT OF THE ENVIRONMENT 

M U K

 25 °0 Broening Highway • Baltimore, Maryland 21224 

rawi-MS^i (410)631-3000 

Parris N. Olendening 

Governor 

Jane T. Nishida 

Secretary 

TO: 

FROM: 

MD AIR & RADIATION MANAGEMENT ADMINISTRATION 

2500 BROENING HIGHWAY 

BALTIMORE MARYLAND 21224 y \i W.\\ 

PHONE: (410)631-3255 

FAX: (410)631-3202 

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'Together We Can Clean Up' nocvcied P*oei 
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MDE "Pacta, /46<Mt... 

Maryland 

Department 

Environment 

CONTROL OF VOC EMISSIONS FROM 

REINFORCED PLASTIC MANUFACTURING 

COMAR 26.11.19.XX 

What is the primary purpose of this regulation? 

The purpose of this regulation is to establish Reasonably Available Control Technology (RACT) for 

reinforced plastic (fiberglass) manufacturing operations. The amended Clean Air Act and COMAR 

26.11.19.02G require unregulated major sources of volatile organic compounds (VOC), state-wide, 

to be subject to reasonable control requirements. Fiberglass manufacturing is currently not 

specifically regulated. This regulation was developed in cooperation with a fiberglass workgroup 

consisting of affected sources, trade associations, and material suppliers. 

Who is affected by this regulation? 

This regulation will apply to both major and non-major fiberglass operations. Fiberglass operations 

involve the application of polyester resins, fiberglass, and a solvent, usually styrene, on to a form or 

mold to produce a shape. Major sources fabricate products such as underground gasoline storage 

tanks and boats. Non-major sources fabricate small components such as pipe fittings or perform 

repairs such as boat repair. The Department has identified one major VOC source, one non-major 

but greater than 25 ton per year source, and numerous small sources that will be subject to this 

regulation. 

What is the source of emissions? 

Styrene, a VOC, is evaporated during the resin application operations. The amount of emissions is 

directly proportional to the size ofthe facility and the total volume of resin used. Acetone, now an 

exempt VOC, is the primary solvent used to clean equipment and tools, although the industry has 

increasingly used a less hazardous non-VOC substitute. The largest product fabricator had 1990 

emissions of 405 pounds per day of styrene (and 28 pounds per day of acetone). A typical small 

source has styrene emissions of 32 pounds per day (and 18 pounds per day of acetone). Small 

sources with VOC emissions less than 20 pounds per day are not subject to any requirements. 

What does the regulation require? 

The regulation will require the styrene content of general polyester formulations to not exceed 35 

percent and the styrene content for specialty resins to not exceed 50 percent. Furthermore, the 

regulation will require the use ofa non-VOC solvent for all clean-up operations. For sources with 

emissions greater than 100 pounds a day, the regulation fiirther requires the use of high transfer 

efficiency guns such as high volume low pressure (HVLP) spray guns. HVLP spray guns can 

significantly reduce resin use, thus reducing the amount of styrene emissions. As a general rule, 
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control devices have not proven to be cost effective because the final products are manufactured in 

large open rooms or buildings with high air flow. 

What are expected emissions reductions? 

The estimated 1990 state-wide VOC emissions from all sources in the category was 109 tons per 

year. There will be a combined estimated reduction of 33 tons per year from affected sources. 

What is the economic impact on affected sources? 

Reducing the amount of styrene m formulations will have little effect on the cost ofthe final products. 

The cost of an HVLP spray gun ranges from $600 to S900, however, there is a rapid pay offbecause 

the improved transfer efficiency reduces the amount of material used by 35-40 percent. Therefore, 

the overall anticipated impact on the effected industry is an eventual cost savings. 

What arc the additional benefits of this regulation? 

Slyrene emissions will be reduced because ofthe reformulations and higher transfer efficiency spray 

guns. Styrene is a Class II Toxic Air Pollutant (TAP) and suspect carcinogen. Acetone emissions 

may be significantly reduced if the industry continues to use substitute clean-up material. Acetone 

is also a Class II TAP. Therefore, depending upon the clean up solvent used, there may be a 

significant reduction in TAPs from both styrene and acetone emissions. 

Are there other state or federal regulations that apply to this source category? 

EPA has not published any regulations for fiberglass operations; nor are there any pending MACT 

proposals. California is one of the few states regulating this industry. Some portions of this proposed 

regulation are similar to the Califomia rule. EPA recently placed acetone on the list of exempted 

VOCs. The Department is currently in the process of exempting acetone as a VOC. 

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July 13, 1995 

COMAR 26.11.19.XX 

Control of Volatile Organic Compound Emissions from Reinforced 

Plastic Manufacturing., 

A. Definitions. 

For the purpose of this regulation, the following terms 

have the meanings indicated: 

(1) "Clean-up material" means any material used in 

reinforced plastic manufacturing to clean parts/ 

tools, eguipment, and work areas. 

(2) "Low styrene resin" means a polyester resin that 

has a monomer content of 35 percent or less by 

weight as applied. 

(3) "Monomer" means a low molecular weight organic 

compound that reacts with itself or other similar 

compounds to produce a polyester resin. 

(4) "Polyester resin" (resin) means a mixture of true 

esters dissolved in a polymeriaable monomer such 

as styrene. 

(5) "Reinforced plastic manufacturing" means the 

curing of polyester resins with fiberglass, inert 

fillers, or other reinforcement materials. 

(6) "Specialty resin" means a polyester resin used in 

special applications involving high strength, 

corrosion resistance, fire resistance, or gel 

coat. 

(7) "Tooling" means the production of molding tools 

such as shapes, matrixes, molds, or other 

instruments and utensils that are used during 

reinforced plastic manufacturing. 

(8) "Touch-up and repair" means small quantity use of 

polyester resin to repair minor surface damage or 

imperfections, where the total polyester resin 

used is less than one percent of the total 

quarterly polyester resin used as reported in 

§E(l)of this regulation. 

B. Applicability and Effective Date. 

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July 13, 1995 

(1) This regulation applies to reinforced plastic 

manufacturing at a premises where the total actual 

VOC emissions from all reinforced plastic 

manufacturing including tooling, touch-up and 

repair is 20 pounds or more per day. 

(2) The requirements in this regulation do not apply 

to polyester resins used for tooling or touch-up 

and repair. 

C. Requirements. 

(1) Except as provided in §C(3) of this regulation, a 

person subject to this regulation with actual VOC 

emissions of 20 pounds or more per day but less 

than 100 pounds per day shall use low styrene 

resins. 

(2) Except as provided in $C(3) of this regulation, a 

person subject to this regulation with actual VOC 

emissions of 100 pounds or more per day shall: 

(a) Use low styrene resins; and 

(b) Use an improved application method such as: 

(i) an airless or air-assisted airless spray 

gun; 

(ii) a low pressure nozzle; 

(iii)a pressure fed roller or flow coater; or 

(iv) some other non-atomized resin 

application technique. 

(3) A person subject to this regulation who uses a 

specialty resin may not use a specialty resin with 

a monomer content exceeding 50 percent by weight 

as applied. 

(4) A person subject to this regulation shall use nonVOC clean-up materials. 

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July 13, 1995 

D. Recordkeeping. 

(1) A person subject to this regulation shall maintain 

records that provide the following information: 

(a) A description of each polyester resin 

material used; and 

(b) The total weight and VOC content of each 

polyester resin material used quarterly. 

(2) Records shall be maintained for not less than 

three years and made available to the Department 

upon request. 

F:\Schmitz\Fiberg\Fiber.reg