Statement of the Air and Radiation Management Administration
 

Department of the Environment
 

for the Public Hearing Relating to Proposed Amendments to Regulation .06
 

Control of VOC from Large Appliance Coating under
 

COMAR 26.11.19 Control of Volatile Organic Compounds from Specific Processes
 

held on August 4, 2010 Baltimore, MD
 

My name is Husain Waheed. I am a Senior Regulatory and Compliance Engineer with the 

Regulation Development Division ofthe Air and Radiation Management Administration, 

Department ofthe Environment. 

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

and Sections 2-301 et.seq. ofthe Environment Article, Annotated Code ofMaryland. 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 July 2, 2010;
 

MDE's website on June 22 - August 4, 2010;
 

Baltimore Sun on July 2,2010;
 

Saint Mary's Enterprise on July 2,2010;
 

Cumberland Times-News on July 2, 2010;
 

Frederick News-Post on July 2,2010;
 

Salisbury Daily Times on July 2, 2010; and the
 

Washington Post on July 1,2010.
 

Copies ofthese notices were submitted for the record.
 

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 Air and Radiation Management Administration 

offices in Baltimore, Cumberland, and Salisbury, and at all local health departments or local air 

quality control offices. 

The purpose oftoday's hearing is to give the public an opportunity to comment on 

proposed amendments to Regulation .06 under COMAR 26.11.19. 

Summary 

These amendments are necessary to incorporate the standards and requirements of 

Control Techniques Guidelines (CTG) for large appliance coating operations and the economic 

impact analysis has been conducted in the development ofthe CTG. 

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COMAR 26.11.19.06 is amended to set the VOC coating standard of2.3 pounds per 

gallon of coating applied (minus water) / 0.275 kilogram/liter of coating applied (minus water). 

Application of coatings on large appliances can only be conducted using one ofthe following 

methods: 1. Electrostatic application; 2. HVLP spray; 3. Flow coat; 4. Roller coat; 5. Dip coat 

including electrodeposition; 6. Brush coat; or 7. Other coating application method capable of 

achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying. 

The requirements ofthe regulation can be met by complying with the standard for VOC 

content of coating and using one ofthe options for application methods or achieving an overall 

capture and control ofVOC emissions from the large appliance coating installation through the 

use of control equipment which achieves an overall VOC emissions reduction of at least 90 

percent. 

Maryland's State Implementation Plan (SIP) 

This regulation will be submitted to the EPA for approval as part ofthe SIP. 

Consideration of Comments 

The Department will consider all comments before making a decision to adopt the 

proposed amendments. 

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