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Statement of the Air and Radiation 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 Air 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 Reinforced 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 boat 
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manufacturing and potential control options. The National Emission Standards for Hazardous 

Air Pollutants for Boat Manufacturing, 40 CFR 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 containing 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 are 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 mixtures 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 manufacturing 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 proposed 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 sources, 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 Protection 
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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.