1 Statement of the Air and Radiat ion Management Administration Department of the Environment for the Public Hearing Relating to Proposed Amendment to Regulation .26 Control of Volatile Organic Compounds from Reinforced Plastic Manufacturing and Proposed Regulation .26-1 Control of Volatile Organic Compounds from Fiberglass Boat Manufacturing under COMAR 26.11.19 Control of Volatile Organic Compounds from Specific Processes held on July 27, 2015 Baltimore, MD

My name is Husain Waheed. I am a Senior Regulatory and Compliance Engineer with the Regulation Development Division of the Ai r and Radiation Management Administration, Maryland Department of the Environment.

This public hearing is being held pursuant to the requirements of 40 CFR Section 51.102

and Sections 2-301 et.seq. of the Environment Article , Annotated Code of Maryland. It is also being held in conformance with the State Administrative Procedures Act under the State Government Article, beginning at Section 10-101.

Notice of this hearing appeared in the: Maryland Register on June 26, 2015.

Copies of the proposed action and supporting documents were submitted for review to the State Clearinghouse and are also submitted at this time into the hearing record. Copies were also made available for public inspection at the Maryland Department of the Environment Air and Radiation Management Administration offices in Baltimore and at the Air and Radiation Administration webpage titled “Air & Radiation Regulations Public Hearings, Meetings and Request for Comments”, from June 26, 2015 to July 28, 2015.

The purpose of today's hearing is to give the public an opportunity to comment on the proposed amendment to regulation .26 and proposed regulation .26-1 under COMAR 26.11.19 Control of Volatile Organic Compounds from Specific Processes.

Summary

The purpose of this action is to adopt the requirements of the EPA’s Control Techniques Guidelines (CTG) for Fiberglass Boat Manufacturing. The new regulation COMAR 26.11.19.26- 1, Control of Volatile Organic Compounds from Fiberglass Boat Manufacturing, adopts CTG standards and requirements. States have the flexibility to follow the CTGs or adopt more restrictive standards. MDE proposes to adopt standards for volatile organic compounds (VOCs), application methods, and work practices which are consistent with the most recent CTG recommendations applicable to fiberglass boat manufacturing. Also COMAR 26.11.19.26 Control of Volatile Organic Compounds from Rein forced Plastic Manufacturing is amended to exempt fiberglass boat manufacturing.

The EPA first published an assessment of VOC emissions from fiberglass boat manufacturing in 1990. This assessment evaluated VOC emissions from fiberglass boat2 manufacturing and potential control options. Th e National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing, 40 CF R part 63, subpart VVVV (2001 NESHAP) were promulgated in 2001. Emission standards under the 2001 NESHAP were for organic hazardous air pollutants (HAPs) based on low-HAP resins and gel coats and low-emitting resin application technology. In September 2008, the EPA published a new CTG for Fiberglass Boat Manufacturing Materials. The CTG was developed based on the 1990 VOC assessment, the 2001 NESHAP, existing state VOC emission reduction approaches such as California, and in

consideration of information obtained since the issuance of the 2001 NESHAP.

Resins containing styrene and gel coats cont aining both styrene and methyl methacrylate (MMA) are the main contributors of VOC emissions at fiberglass boat manufacturing facilities. The proposed standards are designed to reduce VOC emissions during fiberglass boat manufacturing operations. Not all the VOCs 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 overall reduction of VOC content in production materials reduces potential emissions from extraneous VOCs during the manufacturing process.

Cleaning activities other than surface preparation also occur at facilities engaged in fiberglass boat manufacturing. Cleaning materials ar e used to remove residue or other unwanted materials from equipment related to manufacturing operations such as molds and prototypes, as well as the cleaning of application equipment, transfer lines and other ancillary equipment. These cleaning materials are typically mixtur es of VOC containing solvents. The proposed regulation includes emission control requirements for cleaning materials consistent with those in

the CTG.

The proposed regulation sets standards for fiberglass boat manufacturing operations. Emissions of VOCs from fiberglass boat manufactur ing operations are expected to be reduced by approximately 40 percent nationally. Maryland only has few sources that may, on occasion, assemble fiberglass boats from pre-manufactured hulls and decks. Therefore, Maryland VOC emission benefits will be negligible. The coatings industry already has products available to meet VOC standards contained in the CTG and propos ed regulation. The maximum benefit from VOC reductions will be provided during the ozone season when VOCs readily combine with NOx to form the pollutant ground level ozone.

The proposed standards are not more restrictive than the federal CTG for fiberglass boat manufacturing. The proposed new regulation adopts the requirements of the CTG for fiberglass boat manufacturing. EPA estimated the economic impact of this regulation on a national level at a cost effectiveness approximately $4,200/ton of VOC controlled. The standards and requirements of the CTG have already been implemented in other states and as a result, cost of production of compliant materials has come down from initial phase of implementation. As the CTGs are implemented nationally, the costs of compliant materials are expected to be reduced

further. Due to the limited number of affected s ources, the economic impact in MD will be small.

Maryland’s State Implementation Plan (SIP)

This amendment and new regulation will be submitted to the U.S. Environmental Protection3 Agency as a revision to the Maryland’s State Implementation Plan.

Consideration of Comments

The Department will consider all comments before making a decision to adopt the new regulation and amendment.