UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: August 23, 2011

SUBJECT: T echnical Support Document for Delaware ‟s Adhesives and Sealants Rule

FROM: Gregory Becoat , Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez

, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND:

On June 9, 2009

, the Delaware Department of Natural Resources and Environmental Control (DNREC) submitted a revision to the Delaware State Implementation Plan (SIP ) that consists of Delaware‟s regulation for reducing volatile organic compounds (VOC) from commercially

- used adhesive and sealant products (Regulation 1141

– Limiting Emissions of Volatile Organic Compounds from Consumer and Commercial Products). The amendments are part of

Delaware ‟s strategy to achieve and maintain the 8

- hour ozone national ambient air quality standard (NAAQS) throughout the state

. The effective date of this regulation is April 11, 2009

.

A dhesives, sealants, adhesive primer, and sealant primer are used in manufacturing, packaging, construction, and installation of disparate materials such as metal, wood, rubber, plastic, ceramics, fiberglass

, and composites. An adhesive is any mate rial use d to bond two surfaces. A sealant is a material with adhesive properties that is used primarily to fill and seal durably, openings between two surfaces. VOC emissions result from evaporation of solvents during surface preparation, transfer, application, drying

, and cleaning operations. The solvents are mostly needed to solubilize the adhesive, sealant, or p rimer material for application. The solvents prepare the surface to provide a stronger bond. In plastic pipe bonding, the solvent dissolves the poly vinyl chloride pipe and reacts with the pipe to form a bond. Solvents used to clean the surface before bonding and to clean the application equipment after bonding al so contribute to VOC emissions. VOC emissions from adhesives and sealants are primarily from industrial and commercial operations such as general manufacturing, wood product manufacturing, upholstery shops, adhesives retailers and architectural trades, such as building construction, floor covering installation and roof repair.

The Ozone Tran sport Commission (OTC) States developed a Model Rule “ OTC Model Rule For2

Adhesives and Sealants” dated 2006 which was based on the 1998 California Air Resources Board (CARB) reasonably available control technology (RACT) determination. This RACT

determina tion applied to both the manufacture and use of adhesives, sealants, adhesive primers or sealant primers , in both industrial and manufacturing facilities and in the field. California Air Districts used this determination to develop regulations for this ca tegory. EPA addressed this source category with a Control Techniques Guideline (CTG) document for Miscellaneous Industrial Adhesives dated September 2008. This CTG was developed in response to section 183(e) of the Clean Air Act (CAA) requirement for EPA to study and regulate consumer and commercial products, which is included in EPA‟s Report to Congress, “Study of Volatile Organic Compound Emissions from Consumer and Commercial Products

– Comprehensive Emissions Inventory.” The section 183(e) miscellane ous industrial adhesives category was limited to adhesives and adhesive primers used in industrial and manufacturing operations and did not include products applied in the field. Therefore, the OTC Model Rule and State efforts in developing individual reg ulations preceded EPA‟s CTG for this source category and were broader in applicability. The OTC Model Rule for adhesives and sealants and Delaware‟s Regulation 1141 section 4.0 provisions compared to the CTG document for Miscellaneous

Industrial Adhesives dated September 2008 are discussed in Attachment A.

B . STATE SUBMITTAL:

New Regulation

- Regulation 1141 Section 4.0

– Adhesives and Sealants

Section 4.0 is a new regulation based on the OTC model rule that in turn was based on the CARB

model rule. Section 4.0 addresses adhesive, sealants, adhesive primers

, and sealant primers that are sold in larger containers and used primarily in commercial and industrial applications , which

include residential applications of these products, such as carpet, floor ing and roofing

installations.

This revision adds sub section 4.1 in order to establish applicability to any person who sells, supplies for sale, offers for sale, manufactures for sale, or uses or applies, on or after May 1, 2009, any adhesive, sealan t, a dhesive primer , or sealant primer within the S tate of Delaware.

The revision adds the foll owing definitions and terms in sub s ection 4.2 , relating to definitions for

new product categories : „„ABS welding adhesive or acrylonitrile

- butadi ene

- styrene weldi ng adhesive,‟‟ “adhesive,” “adhesive primer,” “aerospace component,” „„aerosol adhesive,‟‟ „„architectural sealant or primer,‟‟ „„automotive glass adhesive primer,‟‟ “CARB or California

Air Resources Board ,” „„ceramic tile installation adhesive,‟‟ „„CPVC p lastic or chlorinated polyvinyl chloride plastic,‟‟ „„CPVC welding adhesive or chlorinated polyvinyl chloride welding adhesive,‟‟ „„cleanup solvent,‟‟ „„computer diskette jacket manufacturing adhesive,‟‟ „„contact bond adhesive,‟‟ „„cove base,‟‟ „„cove bas e installation adhesive,‟‟ “cyanoacrylate adhesive,” „„drywall installation,‟‟ “exempt compound,” „„fi berglass,‟‟ „„indoor floor covering installation adhesive,‟‟ „„laminate,‟‟ „„low

- solids adhesive, sealant or primer,‟‟ „„marine deck sealant or

marine dec k sealant primer,‟‟ „„medical equipment manufacturing,‟‟ „„metal to urethane/rubber3

molding or casting adhesive,‟‟ „„multipurpose construction adhesive,‟‟ „„nonmembrane roof installation/repair adhesive,‟‟ „„outdoor floor covering installation adhesive,‟‟ „„panel installation,‟‟ „„perimeter bonded sheet flooring installation,‟‟ „„plastic cement welding adhesive,‟‟ „„plastic cement welding adhesive primer,‟‟ „„plastic foam,‟‟ „„plasticizer,‟‟ „„plastics,‟‟ „„PVC plastic or polyvinyl chloride plastic,‟‟ „„PVC welding adhesive or polyvinyl chloride welding adhesive,‟‟ „„porous material,‟‟ „„propellant,‟‟ „„reactive diluent,‟‟ „„roadway sealant,‟‟ „„rubber,‟‟ „„SCAQMD

- South Coast Air Quality Management District,‟‟ „„sealant primer,‟‟ “sealant,” „„sheet rubber in stallation,‟‟ „„single

- ply roof membrane,‟‟ „„single

- ply roof membrane adhesive primer,‟‟ „„single

- ply roof membrane installation and repair adhesive,‟‟ „„single

- ply roof membrane sealant,‟‟ “solvent,” „„structural glazing adhesive,‟‟ „„subfloor

installati on,‟‟ „„surface preparation solvent,‟‟ „„thin metal laminating adhesive,‟‟ „„tire repair,‟‟ „„tire tread adhesive,‟‟ „„traffic marking tape,‟‟ „„traffic marking tape adhesive primer,‟‟

„„undersea

- based weapons systems components

, ‟‟ and „„waterproof resorci nol glue.‟‟

The revision adds sub section 4.3 es tablishes the requirements that on and after May 1, 2009, no person shall sell, supply for sale, offer for sale, manufacture for sale, or use or apply any adhesive, sealant, adhesive primer

, or sealant primer wi thin the S tate of Delaware with a VOC content in excess of the applicable VOC content limits specified in Table 1. Section 4.3 also specifies requirements for any person who uses or applies a surface preparation solvent or cleanup solvent or removes an adhesive, sealant, adhesive primer, sealant primer from the parts of spray application equipment.

As an alternative to the VOC limits established in Table 1 of section 4.0

, any person who use or apply adhesives, sealants, adhesive primers, sealant prim ers , surface preparation solvents

, or cleanup solvents have the option of using add

- on pollution control equipment rather than complying with the Table 1 limits. Requirements applying to air pollution control equipment include: an overall capture and con trol efficiency of at least 85 percent, by weight; the continuous monitoring of combustion temperature, inlet and exhaust gas temperatures and control device efficiency, depending upon the type of add

- on controls used; and the maintenance of operation reco rds to demonstrate compliance.

The SIP revision adds sub section s 4.4, 4.5

, 4.6

, and 4.7 in order to (1) specify exemptions for an adhesive, sealant, adhesive primer or sealant primer product

, (2) specify administrative and recordkeeping requirements , (3 ) specify compliance procedures and test methods and (4) specify registration and product labeling requirements

.

EPA evaluates that section 4.0 contains the required elements for a federally enforceable rule: emission limitations, compliance procedures and test methods, compliance dates

, and record keeping provisions. In comparison to the CTG, the OTC model rule and section 4.0 are applicable to all stationary sources including those applications that occur outside of the factory setting, which is, applied in the field. The OTC model rule and section 4.0 also regulate s the

VOC content and vapor pressure of surface

- preparation and clean

- up solvents for which the CTG did not make recommendations for other than including work practices.4

EPA recommends that wh en the States evaluate RACT as required by section 182(b) when implementing a revised 8

- hour ozone standard

, 1 that they review the VOC content limits for wood adhesives and evaluate the benefit of requiring improved methods for applying coatings regulated by section 4.0

.

Overall, the OTC model rule and section 4.0 : (1) r egulate s the same adhesives and adhesive primers as the CTG with the addition of regulating sealants and sealant primers, (2) a pplies to
additio nal stationary sources

, and (3) p rovide s for similar exemptions as the CTG recommends. Therefore, section 4.0 meet s the requirement of a RACT rule for the miscellaneous industrial adhesives CTG category.

C . CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements f or an acceptable SIP. New regulation

, section 4.0

“ Adhesives and Sealants ,” adopted by the S tate of Delaware will result in the reduction of VOC emissions from the affected sources and meets the applicable requirements of the CAA, and the applicable EPA r egulations, guidance

, and policy and can be approved.

EPA approval of the SIP revision is recommended.

1 S ee 7 5 FR 2938, January 19, 2010. I n this proposed rule, March 2008, based upon reconsideration of the primary and secondary ozone standards, EPA proposed to set different primary and secondary standards than those promulgated in March 2008 to provide requisit e protection of public health and welfare, respectively.5 ATTACHMENT A

OTC Model Rule for Adhesives and Sealants and Delaware’s Regulation 1141 section 4.0 Provisions Compared to the Con trol Technique Guidelines for Miscellaneous Industrial Adhesives, September 2008

OTC Model Rule

The Ozone Transport Commission (OTC) developed a model rule as part of a regional effort to attain and maintain the eight

- hour ozone standard and reduce eigh t

- hour ozone levels. States opting to promulgate rules based on this model rule will utilize State

- specific administrative requirements and procedures. Delaware‟s adopted Regulation 1141 section 4.0 is based on the

OTC model rule.

A reasonably available control technology (RACT) determination prepared by the California Air Resources Board (CARB) in 1998 forms the basis of the OTC model rule. In the years 1998

- 2001, the provisions of the CARB determination were adopted in regulatory form in various air

p ollution control districts in California including the Bay Area, Ventura County, Sacramento Metropolitan and San Joaquin Valley.

The provisions of this model rule limit emissions of VOCs from adhesives, sealants, adhesive primers and sealant primers. The model rule achieves VOC reductions through two basic components: (1) sale and manufacture restrictions that limit the VOC content of specified adhesives, sealants, adhesive primers and sealant primers sold in the state; and (2) use restrictions that appl y primarily to commercial and industrial applications. By reducing the availability of higher VOC content adhesives and sealants within the State, the sales prohibition is also intended to address adhesive and sealant usage at area sources. Emissions fro m residential use of regulated products are addressed through the sales restrictions and simple use provisions.

The associated emissions reductions will be used as part of the State‟s plan to attain and maintain

the 8

- hour ozone national ambient air qua lity standard (NAAQS).

Control Techniques Guideline

The Environmental Protection Agency ( EPA ) addressed a portion of this category, adhesives and adhesive primers, in a Control Techniques Guideline (CTG) document

- “ Control Techniques

Guidelines for Mi s cellaneous Industrial Adhesive , EPA

- 453/R

- 08

- 005” in September 2008. ( See

Docket number EPA

- HQ

- OAR

- 2008

- 0460 .)

“This CTG is intended to provide State and local air pollution control authorities information that should assist them in determining RACT for VOCs from miscellaneous6

industrial adhesive application processes. In developing this CTG, EPA, among other things, evaluated the sources of VOC emissions from miscellaneous industrial adhesives application processes and the available control approaches f or addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for miscellaneous industrial adhesives. States can

use the recommendations in this CTG to inform their o wn determination as to what constitutes RACT for VOCs for miscellaneous industrial adhesive application processes in their particular nonattainment areas. The information contained in this document is provided only as guidance. This guidance does not cha nge, or substitute for, requirements specified in applicable sections of the CAA or EPA‟s regulations; nor is it a regulation itself. This document does not impose any legally binding requirements on any entity. It provides only recommendations for State and local air pollution control agencies to consider in determining RACT. State and local pollution control agencies are free to implement other technically

- sound approaches that are consistent with the CAA and EPA‟s implementing regulations” (CTG page 1 ).

“When State and local pollution control agencies develop RACT rules, they may elect to adopt control approaches that differ from those described in this document and/or promulgate applicability criteria that differ from those recommended here [in thi s CTG].” (CTG page 3)

.

EPA issued the CTG pursuant to the authority and to meet a requirement set by section 183(e) of

the CAA. Section 183(e) directed EPA to list for regulation

, those categories of products that account for at least 80 percent of the VOC emissions from consumer and commercial products in ozone nonattainment areas, and to schedule those categories for regulation in four groups. Section 183(e)(3)(C) further provides that we may issue a CTG in lieu of a national regulation for a product category where we determine that the CTG will be “ substantial ly as effective as regulations” in reducing emissions of VOC in ozone nonattainment areas. See for example, 64 FR 13422, March 18, 1999. EPA has revised the list several times. See 70 FR 69759 , November 17, 2005; 64 FR 13422, March 18, 1999; and most recently, 71 FR 28320, May 16, 2006.

Under section 183(e), a regulation for consumer or commercial products is limited to measures applicable to manufacturers, processors, distributors, or importe rs of the solvents, materials, or products supplied to the consumer or industry. Section 183(e) does not authorize EPA to issue national regulations that would directly regulate end

- users of these products. By contrast, CTG are guidance do cuments that re commend RACT measures that States can adopt and apply to the

end

- users of products. See 73 FR 58481 at 58483, October 7, 2008. However, section 183(e) does not impose the same restrictions upon States

, upon regulation of end

- users and manufacturers, proc essors, distributors, or importers. Therefore, a State can regulate manufacturers, processors, distributors, or importers and end

- users of a product category for

which EPA has issued a CTG.

I. Applicability7

(1) The scope of the CTG is focused on indu strial adhesive application processes at facilities, i.e., stationary sources. The limits and requirements apply to facilities where the total actual VOC emissions from all miscellaneous industrial adhesive application processes, including

related cleanin g activities, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12

- month rolling period, before consideration of controls.

The OTC model rule is broader than the CTG and applies to processes below the 6.8 kg/day recommendation. It also applies outside of stationary source facilities when the adhesives are applied in the field.

(2) The OTC model rule is als o applicable to any person who: sells, supplies for sale, offers for

sale or manufactures fo r sale any adhesive, sealant, adhesive primer or sealant primer

. The CTG is not applicable to these people.

II. Definitions

Generally the OTC model rule and CTG use the same terms and definitions for those terms. The

OTC model rule contains additiona l definitions to address sealants and sealant primers and additional types of products. There are minor differences with some terms because the CTG focuses on the processes at a facility while the OTC model rule also incorporates prohibitions on selling, offering for sale and using products that can occur outside of a facility . There are some

instances where the CTG and the OTC model rule use different terms for the same process/product , but these are substantively the same.

Specific examples:

There app ears to be an inconsistency in the CTG with the category of tire repair and tire retread. Tire repair generally would not occur at a manufacturing facility, but at smaller operations in the field. The draft CTG used a term “tire retreading” which would b e a process that occurs at a manufacturing facility. The OTC model rule and section 4.0 regulate s “tire retread” and defines the category in terms of manufacture and not the repair of a puncture. Section 4.0 ‟ s definition is

consistent with South Coast Ai r Quality Management District (SCAQMD) rule 1168‟s definition of “tire tread adhesive.” The CTG was developed based upon SCAQMD rule 1168 and similar rules. Therefore, with regards to “tire retread” and “tire repair” processes, the OTC model rule

and sec tion 4.0 are consistent with those rules upon which the CTG founded its

recommendations.

The CTG does not distinguish between cleaning materials used for surface preparation and those used for cleaning application equipment, but the OTC model rule does ma ke this distinction.

The recommendations for roof membranes in the CTG do not extend to field applied materials,

because: (1) field

- applied adhesives are not part of the miscellaneous industrial adhesives category and are therefore not covered by this C TG, and (2 ) nonmembrane roof installation and8

repair adhesive

, and ethylene propylene diene monomer ( EPDM ) described in the comments received on the draft CTG are field applied products and are therefore not included in the

miscellaneous industrial adhesiv es category. To the extent the recommendations in the OTC

model rule sets limits for EPDM single

- ply roof membranes it makes a recommendation beyond

those in the CTG. It appears that the inclusion of “m otor vehicle glass bonding primer” in the

CTG covers a slightly broader cl ass of adhesives primers than “a utomotive glass adhesive primer.”

The OTC model rule includes wood in the definition of “porous material” while the CTG does not and has a separate limit for wood. The CTG‟s recommended definition was made in the absence of limits for sealants and sealant primers and specifically excludes wood from being considered a porous material.

III. Requirements

(1) The OTC model rule applies to any person who sells, supplies or offers for sale any adhesive

, sealant, adhesive primer or sealant primer manufactured on or after January 1, 2009 , or manufacture for sale any adhesive, sealant, adhesive primer or sealant primer in excess of the applicable VOC content limits specified in Table 1. The CTG does not a pply to people who sell or manufacture these coatings.

(2) The OTC model rule applies to any person who uses or applies (for compensation) any adhesive , sealant

, adhesive primer or sealant primer that has an applicable VOC content limit specified in Tabl e 1 that is not otherwise exempted

. The CTG only recommends application of the limits and requirements to facilities where the total actual VOC emissions from all miscellaneous industrial adhesive application processes, including related cleaning activiti es, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12

- month rolling period, before consi deration of controls. The OTC model r ule covers “field applied adhesives” which the CTG does not cover.

(3) Both the CTG and the OTC model rule have a table of content limits for the regulated products. See the comparison of table limits and discussion below.

(4) The CTG did not propose recommendations for VOC content or VOC composite vapor pressure limit s for cleaning materials. The OTC model rule and section 4.0 contained the following limits for cleaning materials:

a. Limits the VOC content of the surface preparation solvent to less than 70 grams per liter;

b. L imits the VOC content of surface prepar ation solvent used in applying single

- ply roofing to a composite vapor pressure, excluding water and exempt compounds, not exceeding 45 mm Hg at 20 degrees Celsius;9

c. L imits materials containing VOCs used to remove adhesives, sealants, or adhesive or

s ealant primers from surfaces unless the composite vapor pressure of the solvent used is less than 45 mm Hg at 20 degrees Celsius;

d. R equires spray application equipment be cleaned in enclosed cleaning system s using cleaning solvents with less than or eq ual to 70 grams of VOC per liter of material, or by soaking parts in closed systems using and a solvent if the composite vapor pressure of the solvent, excluding water and exempt compounds, is less than or equal to 9.5 mm Hg at 20 degrees Celsius.

(5) Bo th the CTG and OTC model rule provide for the use of add

- on air pollution control equipment instead of meeting the solvent content limits. Both require that controls reduce VOC emissions by an overall capture and control efficiency of at least 85% by weig ht. The OTC model rule includes additional provisions to insure that the control equipment is operated properly.

(6) Both the CTG and OTC model rule require work practices to minimize emissions from cleaning operations. The CTG recommendations are more detailed while the OTC model rule is more general.

(7) The OTC model rule prohibitions the specification of non

- complying adhesives, sealants, adhesive primers, sealant primers, surface preparation or clean

- up solvents.

(8) The CT G also recommends th at adhesive and adhesive primer s be applied using application methods with good transfer efficiency in conjunction with the use of low

- VOC content adhesives. Specifically, the CTG recommends the following application methods: electrostatic spray, HVLP spr ay, flow coat, roll coat or hand application including non

- spray application methods similar to hand or mechanically powered caulking gun, brush, or direct hand application), roll coat, dip coat (including electrodeposition), airless spray, air

- assisted ai rless spray, or other coating application method capable of achieving good transfer efficiency. (Fi nal CTG, Section VI.B., page 19 )

. The CTG recommends application methods with good transfer efficiencies for stationary facilities and does not make recomme ndations for field applied

adhesives and s ealants. The OTC model rule does not address application methods.

IV. Exemptions and Exceptions

(1) CTG and OTC model rule have similar exemptions for the following:

a. Adhesives, sealants, adhesive primers or sealant primers being tested or evaluated in any research and development, quality assurance or analytical laboratory.

b. Cyanoacrylate adhesives. c. Adhesives, sealants, adhesive primers or sealant primers that are sold or supplied by

the manufact urer or supplier in containers with a net volume of 16 fluid ounces or less, or10

a net weight of one pound or less, except plastic cement welding adhesives and contact

adhesives.

d. Processes using polyester bonding putties to assemble fiberglass parts at fiberglass boat manufacturing facilities and at other reinforced plastic com posite manufacturing

facilities.

e. In the assembly, repair and manufacture of aerospace or undersea

- based weapon
systems.

f. Solvent welding operations used in the manuf acture of medical devices.

(2) OTC model rule exemptions not in CTG:

a. Adhesives, sealants, adhesive primers and seala nt primers that are subject to S ta te consumer product regulation. State consumer product regulations generally regulate the

same cat egories as the Federal Regulation (of 40 CFR Part 59). Under section 183(e) the consumer products regulated by 40 CFR Part 59 can not be the same adhesive products and adhesive primers as those covered by the CTG, and, therefore this provision of the

OTC m odel rule merely clarifies that here is no double regulation 2

.

b. Adhesives and sealants that contain less than 20 grams of VOC per liter of adhesive or sealant, less water and less exempt compounds, as applied. This limit is less than any

limit recomme nded by the CTG.

c. Contact adhesives that are sold or supplied by the manufacturer or supplier in containers with a net volume of one gallon or less. Some California Air Districts have a similar size exemption but with additional conditions.

d. Tire repair operations, provided the label of the adhesive states " For tire repair only

. "

e. Plaque laminating operations in which adhesives are used to bond clear, polyester acetate laminate to wood with lamination equipment installed prior to July 1, 1992 . Any person claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance with this exemption and in accordance with section (V) of this rule. In addition, t he CTG recommends t hat these sources be subject to the work practices

recommendation. (3) The OTC model rule exempts total VOC emissions from all adhesives, sealants, adhesive

2 The latest listing of product categories regulated under section 183(e) of the CAA was published on May 16, 2006 (71 FR 28320).11

primers and sealant primers used at a facility that are less than 200 pounds per calendar year, o r an equivalent volume. Any person claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance.

(4) The OTC model rule exempts adhesives, sealants, adhesive primers, seala nt primers, cleanup solvents and surface preparation solvents provided the total volume of noncomplying adhesives, sealants, primers, cleanup and surface preparation solvents applied facility

- wide does not exceed 55 gallons per calendar year. Any person c laiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance. This is equivalent to 400 pound per year, while the CTG applicability starts at 6.8 kg/day (15 lb/day) or an equiva lent level such as 3 tons (6000 pound) per 12

- month rolling period.

( 5 ) The OTC model rule exempts adhesive, sealant, adhesive primer or sealant primer intended for shipment and use outside of OTC State s or in section 4.0

.

(6 ) The OTC model rule exempts any adhesive, sealant, adhesive primer or sealant primer that is controlled by add

- on air pollution control equipment.

V. Administrative Requirements

The OTC model rule contains detailed record keeping requirements for demonstrating compliance with t he VOC content limits and recording the key operating parameters for the control equipment that must be maintained for five years. Any S tate rule for a CTG must contain monitoring and recordkeeping requirements.

VI. Compliance Procedures and Test Meth ods

Both the CTG and OTC model rule contain the same primary test methods and compliance procedures. The OTC model rule contains additional references to other relevant standard test methods for both solvent analysis and for determining compliance of add

- on control equipment. Any S tate rule for a CTG must contain test methods for determining compliance.

VII. Container Labeling

The OTC model rule requires labeling of product container with the maximum or actual VOC content of the product along with in formation concerning thinning of the product.

VIII. Emission Limit T able The table below provides an analysis of the CTG recommended VOC emission limits for general and specialty adhesive application processes compared to the OTC model rule VOC content

l imits for adhesives, sealants, adhesive primers sealant primers and adhesives applied to particular substrates. Where there is no comparable limit the column is left blank. In the CTG recommendation column, categories with brackets { } around them indi cates there is a12

difference in a definition or provision which differs from the OTC model rule. Below the table
are series of “Notes” which discuss some of the differences between the OTC model rule and the

CTG and refer back to some of the California ado pted rules (CARB model rule) for which the

OTC model rule was based on.

Both the CTG and the OTC model rule were based on the California rulemaking efforts for this category and the CTG also bases its recommended emission limits on the OTC model rule (s ee CTG page 16, last paragraph). The CTG also states “we consider the limits in the OTC model rule to be representative of what sources in nonattainment areas nationwide can achieve technically and economically and have therefore adopted these VOC limits as our recommendations in the CTG. ”

Table 1. VOC Content Limits for Adhesives, Sealants, Adhesive Primers, Sealant Primers and Adhesives Applied to particular Substrates 

### OTC Model Rule CTG Recommendation

Category VOC content limit (grams VOC per
liter *) Category Recommende
d VOC
Emission

Limit 1 (g/l)

Adhesives Specialty Adhesive Application Processes ABS welding 400 {Plastic Solvent Welding (ABS)} 400

Ceramic tile installation 130 Ceramic Tile Installation 130
Computer diskette jacket manufacturi ng 850

Contact bond [Note C] 250 {Contact Adhesive} [Note C] 250

Cove base installation 150 Cove Base Installation 150
CPVC welding 490 {Plastic Solvent Welding (Except ABS)} {500}

Indoor floor covering
installation 150 Floor Covering Installation (Indoor) 150

Metal to
urethane/rubber molding or casting 850 Metal to Urethane/Rubber Molding or Casting 850

Motor Vehicle Adhesive [Note H] 250

Motor Vehicle Weatherstrip
Adhesive [Note H] 750

Multipurpose
construction 200 Multipurpose Construct ion 20013



### OTC Model Rule CTG Recommendation

Nonmembrane roof installation/repair 300

Other plastic cement welding 510 {Plastic Solvent Welding (Except ABS)} { 500 }

Outdoor floor covering
installation 250 Floor Covering Installation (Outdoor) 250

PVC welding 510 {Plastic Solvent Weldin g (Except ABS)} { 500 }

Single

- ply roof
membrane installation/repair [Note G] 250 Single

- Ply Roof Membrane Installation/Repair (Except EPDM) 250

Structural glazing 100 Structural Glazing 100
Thin metal laminating 780 Thin Metal Laminating 780
Tire Rep air [Note A] 100

Tire retread [Note A] 100

Perimeter bonded sheet vinyl flooring installation 660 {Floor Covering Installation (Perimeter Bonded Sheet Vinyl)} [Note C] 660

Waterproof resorcinol glue 170 Waterproof Resorcinol Glue 170

Sheet

- applied rubber
installation 850 {Sheet Rubber Lining Installation} [Note C] 850

Sealants

Architectural 250

Marine deck 760

Nonmembrane roof installation/repair 300

Roadway 250
Single

- ply roof
membrane 450

Other 420

Adhesive Primers Adhesive Primer Application Processes

Automotive glass [Note G] 70014



### OTC Model Rule CTG Recommendation

Motor Vehicle Glass Bonding Primer [Notes B and G] 900

Plastic cement welding 650 {Plastic Solvent Welding Adhesive Primer} [Note C] 650

Single

- ply r oof
membrane 250 Single

- Ply Roof Membrane
Adhesive Primer [Note B] 250

Traffic marking tape 150

Other [Note G] 250 Other Adhesive Primer [Note B] 250

Sealant Primers

Non

- porous architectural 250

Porous architectural 775

Marine deck 760

Other 750

Adhesives Applied to
the Listed Substrate [Notes E and H] General Adhesive Application Processes 2 [Note E]

Flexible vinyl [Note H] 250 Flexible vinyl 250
Fiberglass [Notes F & H] 200
Reinforced plasti c composite [Note F] [Note F] 200

Metal [Note H] 30 Metal 30

Porous material (Including wood) [Note H] 120 Porous Material (Excluding Wood) 120

Rubber [Note H] 250 Rubber 250

Other substrates [Note H] 250 Other Substrates 250

Wood 30

* The VOC content is determined as the weight of volatile compounds, less water and exempt compounds as specified in Section VI of this rule.

1 Emission limits are mass of VOC per volume of adhesive or adhesive primer, excluding water and exempt compounds.

2 If an adhesive is used to bond dissimilar substrates together, then the applicable substrate category with the highest VOC emission limit is recommended as the limit for such application. The analogous provision in the OTC Model

Rule is foun d in Section III. (3) of that rule.

Notes : A. The CTG is inconsistent with the State rules cited in Appendix B in that none of these15

rules set a limit for “tire repair” adhesives (as that term is defined in each of these rules) but

rather set a limit f

or “tire retread(ing) adhesives” which is the same as the 100 g VOC/liter limit in the OTC model rule (which is as expected since this rule is based upon one or more of the California rules).

B. The CTG has the words “Adhesive Primer” in its table wher eas in the OTC model

rule this is to be understood from the sub

- heading.

C. The CTG and OTC Model Rule use slightly different terms to cover the same processes or products.

- The CTG uses the term “Floor Covering Installation (Perimeter Bonded Sheet V inyl)” to cover what the OTC Model Rule covers as “Perimeter Bonded Sheet Vinyl.”

- The term “Sheet

- applied rubber installation” in the OTC Model Rule means the same thing as “Sheet Rubber Lining Installation” in the CTG.

- “Contact bond” adhesive and ““Con tact adhesive” would appear to be the same thing.

Both the OTC Model Rule and the CTG definitions for “Contact bond adhesive” are the same and both use “Contact adhesive” within this definition to refine its scope.

- The OTC Model Rule uses “Plastic Cement Welding Adhesive Primer” where the CTG uses “Plastic Solvent Welding Adhesive Primer” for the same product/process.

D. The inclusion of the category “plastic adhesive primer” in the Draft CTG was an error. This category has been removed from the final CTG.

E. The OTC model rule uses the term “Adhesives Applied to the Listed Substrate” where the CTG uses the term “General Adhesive Application Processes.”

F. The CTG covers more materials with the broader definition of “ Reinforced plastic composite” th an the OTC model rule if the latter considers “fiberglass” to means fine glass fibers in a plastic resin. But the OTC rule defines “fiberglass” as a material consisting of extremely fine glass fibers; thus, a “fiberglass substrate adhesive” could be inte rpreted as meaning an adhesives used to bond glass fibers together or to another listed substrate. The OTC definition is consistent with several California AQMD rules such as SCAQMD Rule 1168, Sacramento Metropolitan AQMD Rule 460; other California AQMDs do not define “fiberglass”

– e.g., San Diego County AQMD rule 67.21; however, Ventura County AQMD Rule 74

- 20 defines fiberglass as “...any fiber reinforced plastic (FRP) surface that has fiber material set in a binding substance of plastic resins” which appe ars to be the functional equivalent of the final CTG‟s definition of “Reinforced plastic composite.”

G. To the extent the OTC Model Rule limit for “Automotive glass adhesive primers” and

the recommendation in the final CTG for “Motor Vehicle Glass Bondin g Primer” both cover the16

same material or process the recommendation in the OTC model rule is more stringent. To the extent that the definition of recommendation in the final CTG for “Motor Vehicle Glass Bonding Primer” covers more processes or operations the recommendation in the final CTG would be more stringent except the OTC model rule may cover any additional products under the other primer category. The recommendation in the OTC model rule for applying an “Automotive glass adhesive primer” to automo tive glass is clearly more stringent. However, recommendation in the CTG for “Motor Vehicle Glass Bonding Primer” would cover primers applied to “ body openings ” prior to the application of glass bonding adhesives or the installation of adhesive bonded gla ss. Body openings may include substrates such as bare metal or plastic as well as the glass itself. To the extent the limit for “other adhesive primers” covers “Motor Vehicle Glass Bonding Primers” other than those when applied to automotive glass, the r ecommendation in the OTC model rule would seem to be more stringent.

H. Whether the recommendation in the OTC model rule is equal to, less stringent or more stringent than the recommendations in the CTG for these categories depends upon whether

the OTC m odel rule covers these applications under the “Adhesives Applied to the Listed Substrate” and which limit applies. The applicable limit depends upon what substrates are involved. The OTC model rule allows compliance to the higher of two applicable subst rate limits when bonding dissimilar substrates. In no case is an OTC limit for any “listed substrate” greater than that recommended in the CTG for “Motor Vehicle Adhesives” and “Motor Vehicle Weatherstrip Adhesives;”as such, the OTC model rule would seem to be more stringent.

I. The OTC Model rule applies a limit to ethylene propylene diene monomer (EPDM)

roof membranes. The CTG excluded EPDM membranes from the VOC recommendation for “Single

- Ply Roof Membrane Installation/Repair” specialty adhesives b ased upon comment that such limits could not be met for field applied EPDM. Some OTC States have limited the CTG recommendation for May 1 to September 30 for two years and then set the limit year

- round after

that.

IX. Conclusions

The OTC Model rule and specifically, section 4.0, for adhesives and sealants and the 2008 CTG

for miscellaneous industrial adhesives were developed to address the emissions of VOC from

adhesives

. The CTG was developed with a restriction that it only applies to larger sources w ith manufacturing operations that use these types of products. Whereas, the OTC model rule includes these sources as well as smaller operations, operations performed in the field and also regulation of the manufacture, distribution and sale of the product s themselves. The OTC model

rule also regulates sealants and sealant primers which are not included in the CTG because they

were not categorized with miscellaneous industrial adhesives under section 183(e)

. The CTG and the OTC model rule exemption categor ies are very simila r though some differences exist, but the CTG recommends that exempted operations be subject to work practices. The OTC model rule does not include work practices. T he work practices benefit cannot be quantified and in these instances, generally appl y to lower usage source categories so17

very few emission reductions are missed by not including these requirements. The OTC model rule contains an exemption provision which is in fact a de facto applicability level that equates to 400 pounds per year of VOC emissions which is less than the CTG‟s yearly limit of 3 tons per year. The model rule‟s 400 pounds per year exclusion includes emissions from sealants and sealant primers and not just adhesives and their primers and therefore sets a lower numerical limit and includes more emissions subject to the applicability threshold.

T he CTG recommended work practices for cleaning materials included more activities than the

OTC model rule. However, s ome of the OTC clean

- up provisions are more strin gent, i.e. limiting clean

- up solvent vapor pressure and VOC content, and cleaning of spray application equipment; over all, the OTC requirements in terms of emission reductions are at least equivalent

to or result in more emission reductions than the CTG

.

The CTG makes recommendations for application methods be used in conjunction with the us e of low

- VOC content adhesives and adhesive primers to improve transfer efficiency. The OTC rule does not specify application methods. T he CTG recommendation goes to “stationary

sources” above a cut

- off level only. The OTC model rule was based on the CARB 1998 RACT and best available retrofit control technology (BARCT) determination for adhesives and s ealants which did not include the requirement for application metho ds. Delaware‟ s proposed rulemaking

states that 96 percent of the adhesive and se alant VOC emissions in the OTC S tates fall into the
area source category. This would appear to limit the benefit from improved transfer equipment. However, EPA recommends th at when the S tates evaluate RACT as required by section 182 (b) when implementing a revised 8 hour ozone standard 3 , that they review and evaluate the benefit of requiring improved methods for applying coatings regulated by the OTC model rule and specificall y, section 4.0

.

Overall, the CTG and the OTC model rule emission limits are similar with the exception of general adhesive for wood applications. T he CTG recommends a 30 g/liter limit for the wood substrate category whereas the OTC model rule covers wood under the “porous material” substrate category with a limit of 120 g/liter. I t is recommended that when the S tates evaluate RACT as required by section 182 (b) when implementing a revised 8

- hour ozone standard, that they review the VOC content limit for wood adhesives

.

The CTG does not requi re S tate rules to match the line

- by

- line, item

- by

- item because it stated: “When State and local pollution cont rol agencies develop RACT rules; they may elect to adopt control approaches that differ from those describ ed in this document and/or promulgate applicability criteria that differ from those recommended here.” (CTG p age 3.) For the most part the OTC Model rule and specifically, section 4.0 , match the CTG‟s recommendations item by

item. The OTC Model rule and specifically, section 4.0 , requires the emission limitations apply to a wider universe of sources and to manufacturers and distributors of adhesives and primers.

3 See 75 FR 2938, January 19, 2010; In this proposed rule, March 2008, based upon reconsideration of the primary and secondary ozone standards, EPA proposed to set different primary and secondary standards than those promulgated in March 2008 to provide requisite protection of public health and welfare, respectively.18

The OTC Model rule and specifically, section 4.0 , sets standards for clean

- up and surface

pr eparation solvents in lieu of the application methods and all work practice recommendations in the CTG. Overall, EPA can conclude the OTC Model rule and specifically, section 4.0 , meets the requirement for RACT in this source category.