UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: July 27, 2011

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

FROM: Gregory Becoat , Environmental Scientist /s/

Offic e of Air Program Planning

TO: File

THRU: Cristina Fernandez

, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND:

On January 12

, 2011, the Pennsylvania Department of Environmental Protection ( PADEP)

submitted a revision to the Pe nnsylvania State Implementation Plan (SIP )

. The SIP revision pertains to amendments to 25 Pennsylvania Code ( Pa. Code ) Chapters 121, 129, and 130 relating to general provision s, standards for sources , and standards for products . The SIP revision

amends t he existing regulation in section 129.51, relating to general and adds provisions under

new section s 129.77 and 130.701

– 130.708, relating to control of emissions from the use or application of adhesives, sealants, primers and solvents for the control of emissions of volatile organic compounds (VOC) from the manufacture, sale, use, or application of adhesives, sealants, primers, and solve nts. The revision also amends s ection 121.1

, relating to definitions

. The amendments are part of Pennsylvania‟s strate gy to achieve and maintain the 8

- hour ozone national ambient air quality standard (NAAQS) throughout the Commonwealth. The effective date of this regulation is December 25, 2010

.

B . STATE SUBMITTAL:

I

. Amendments to 25 Pa. Code Chapter 121

– Gener al Provisions

The revision amends the foll owing definitions and terms in s ection 121.1 , relating to definitions for clarity, style

, and format or to explain new product categories : “ adhesive,” “adhesive primer,” “aerospace vehicle or component,” “as appli ed,” “as supplied,” “cyanoacrylate adhesive,” “exempt compound or exempt solvent,” “sealant,” and “solvent.”

The revision adds the following definitions and terms in s ection 121.1 to explain new product categories: „„ABS welding adhesive or acrylonitrile

- butadiene

- styrene welding adhesive,‟‟2

„„aerosol adhesive,‟‟ „„architectural sealant or primer,‟‟ „„automotive glass adhesive primer,‟‟ „„CPVC plastic or chlorinated polyvinyl chloride plastic,‟‟ „„CPVC welding adhesive or chlorinated polyvinyl chloride wel ding adhesive,‟‟ „„ceramic tile installation adhesive,‟‟ „„cleanup solvent,‟‟ „„computer diskette jacket manufacturing adhesive,‟‟ „„contact bond adhesive,‟‟ „„cove base,‟‟ „„cove base installation adhesive,‟‟ „„diluent,‟‟ „„drywall installation,‟‟

„„fiber glass,‟‟ „„flexible vinyl,‟‟ „„indoor floor covering installation adhesive,‟‟ „„laminate,‟‟

„„low

- solids adhesive, sealant or primer,‟‟ „„marine deck sealant or marine deck sealant primer,‟‟ „„medical equipment manufacturing,‟‟ „„metal to urethane/rubber m olding or casting adhesive,‟‟ „„multipurpose construction adhesive,‟‟ „„nonmembrane roof installation/repair adhesive,‟‟ „„outdoor floor covering installation adhesive,‟‟ „„PVC plastic or polyvinyl chloride plastic,‟‟ „„PVC welding adhesive or polyvinyl ch loride welding adhesive,‟‟ „„panel installation,‟‟ „„perimeter bonded sheet flooring installation,‟‟ „„plastic cement welding adhesive,‟‟ „„plastic cement welding adhesive primer,‟‟ „„plastic foam,‟‟ „„plasticizer,‟‟ „„plastics,‟‟ „„porous material,‟‟ „„pr opellant,‟‟ „„reactive diluent,‟‟ „„roadway sealant,‟‟ „„rubber,‟‟ „„SCAQMD

- South Coast Air Quality Management District,‟‟ „„sealant primer,‟‟ „„sheet rubber installation,‟‟ „„single

- ply roof membrane,‟‟ „„single

- ply roof membrane adhesive primer,‟‟ „„sing le

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

- ply roof membrane sealant,‟‟ „„structural glazing adhesive,‟‟ „„subfloor installation,‟‟ „„surface preparation solvent,‟‟ „„thin metal laminating adhesive,‟‟ „„tire repair,‟‟ „„tire tread ad hesive,‟‟ „„traffic marking tape,‟‟ „„traffic marking tape adhesive primer,‟‟ „„underseabased weapons systems components

, ‟‟ and „„waterproof resorcinol glue.‟‟

II

. Amendments to 25 Pa. Code Chapter 129

– Standards For Sources of VOCs

The revision amends section 129.51(a) in order to include adhesives, sealants, primers

, and solvents covered by section 129.77 , entitled “Control of emissions from the use or application of adhesives, sealants, primers and solvents.” Section 129.51(a) provides an alternativ e method for owners and operators of facilities to achieve compliance with air emission limits.

Adhesives, sealants, adhesive primer, and sealant primer are used in manufacturing, packaging, construction, and installation of disparate materials such as me tal, wood, rubber, plastic, ceramics, fiberglass

, and composites. An adhesive is any mate rial used 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 prepar e the surface to provide a stronger bond. In plastic pipe bonding, the solvent dissolves the polyvinyl 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 b onding 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 t rades, such as building construction, floor covering installation and roof repair.3

The Ozone Transport Commission (OTC) States developed a Model Rule “ OTC Model Rule For
Adhesives and Sealants” dated 2006 which was based on the 1998 California Air Resource s Board (CARB) reasonably available control technology (RACT) determination. This RACT determination applied to both the manufacture and use of adhesives, sealants, adhesive primers or sealant primers , in both industrial and manufacturing facilities and i n the field. California Air Districts used this determination to develop regulations for this category. EPA addressed this source category with a Control Techniques Guideline (CTG) document for Miscellaneous Industrial Adhesives dated September 2008. Th is 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 Cons umer and Commercial Products

– Comprehensive Emissions Inventory.” The section 183(e) miscellaneous industrial adhesives category was limited to adhesives and adhesive primers used in industrial and manufacturing operations and

did not include products ap plied in the field. Therefore, the OTC Model Rule and State efforts in developing individual regulations preceded EPA‟s CTG for this source category and were broader in applicability. The OTC Model Rule for adhesives and sealants and Pennsylvania ‟s 25

Pa . Code Chapter 129.77 provisions compared to the CTG document for Miscellaneous Industrial Adhesives dated September 2008 are discussed in Attachment A

.

Section 129.77 is a new regulation based on the OTC model rule that in turn was based on the

CARB mode l rule. Section 129.77 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 ca rpet, flooring and roofing installations.

This revision adds s ection 129.77 in order to establish applicability to owners or operators that uses or applies at the facility, on or after January 1, 2012, an adhesive, sealant, adhesive primer, sealant prim er, or an adhesive or sealant product applied to the listed substrate at the facility subject to the VOC content limits in Table 1

. Section 129.77 also establishes that on or after January 1, 2012, owners or operators may not use or apply at the facility an adhesive, sealant, adhesive primer, sealant primer, surface preparation or cleanup solvent that exceeds the VOC

content limit in Table 1 . Section 129.77 specifies requirements for owners or operators of a facility that uses or applies a surface prepara tion 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 129.77 , operators or owners of a facilit y that use or apply adhesives, sealants, adhesive primers, sealant primers , 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 t o air pollution control equipment include: an overall capture and control 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 t he type of add

- on controls used; and the maintenance of operation records to demonstrate compliance. Section 129.77 contains requirements for proper storage and disposal, work practices, surface preparation and cleanup4

solvent composition. Section 129.77 also includes specific exemptions, as well as registration and product labeling requirements, recordkeeping requirements, and test methods and compliance procedures.

III. New Regulation

- 25 Pa. Code Chapter 130 Subchapter D

– Adhesives, Sealants,

Primers
, and Solvents General Provisions

.

The SIP revision adds section 130.701 in order to establish applicability to persons selling, supplying, offering for sale, manufacturing for sale, or applying for compensation in the Commonwealth of Pennsylvania, an adhesive, sealant, adhesive primer, sealant primer, an adhesive or sealant product applied to the listed substrate, a surface preparation solvent or cleanup solvent product, on or after January 1, 2012.

The SIP revision adds section 130.702 in order t o establish that persons may not sell, supply, offer for sale, manufacture for sale, or apply for compensation in the Commonwealth of Pennsylvania, an adhesive, sealant, adhesive primer, sealant primer, an adhesive or sealant product applied to the listed substrate, on or after January 1, 2012, which contains VOCs in excess of the applicable VOC content limit specified in Table 1. Section 130.702 establishes requirements for surface preparation solvent or cleanup solvent, removal methods, and proper
storag e and disposal. Section 130.702 also establishes that a person may not solicit the use of a product if application would result in a violation and specifies that a person may not add solvent to an adhesive, sealant, adhesive primer, or sealant primer in a n amount in excess of the applicable VOC content limit in Table 1.

The SIP revision adds section s 130.703, 130.704, 130.705, 130.706, 130.707 and 130.708 in order to (1) specify exemptions for an adhesive, sealant, adhesive primer or sealant primer produc t

, (2) specify recordkeeping requirements , (3) specify test methods , (4) specify registration and product labeling requirements and (5) specify compliance procedures.

EPA evaluates that sections 129.77 and 130.701

– 130.708 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 129.77 are applicable to all stationary sources includ ing those applications that occur outside of the factory setting, which is, applied in the field. The OTC model rule and sections

129.77 and 130.701

– 130.708 also regulate the VOC content and vapor pressure of surface

preparation and clean

- up solvents fo r which the CTG did not make recommendations for other than including work practices.5

EPA recommends that when 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 li mits for wood adhesives and evaluate the benefit of requiring improved methods for applying coatings regulated by sections 129.77 and 130.701

– 130.708.

Overall, the OTC model rule and sections 129.77 and 130.701

– 130.708: (1) r egulate the same

adhesive s and adhesive primers as the CTG with the addition of regulating sealants and sealant primers, (2) a pply to additio nal stationary sources and (3) p rovide for similar exemptions as the CTG recommends. Therefore, sections 129.77 and 130.701

– 130.708 meet 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 for an acceptable SIP. The amendments to section

121.1 “ Definitions ,” an d section 129.51(a) “Equivalency,” meet the applicable requirements of the CAA, and the applicable EPA regulations, guidance

, and policy and can be approved.

New regulation

, section 129.77 “ Control of emissions from the use or application of adhesives,

se alants, primers

, and solvents ,” adopted by the Commonwealth of Pennsylvania will result in the reduction of VOC emissions from the affected sources and meets the applicable requirements of the CAA, and the applicable EPA regulations, guidance

, and policy a nd can be approved.

Amendments to new regulation, 25 Pa. Code Chapter 130 Subchapter D “Adhesives, Sealants,

Primers and Solvents General Provisions

, ” will result in the reduction of VOC emissions from the affected sources and meets the applicable require ments of the CAA, and the applicable EPA regulations, guidance

, and policy and can be approved.

EPA approval of the SIP revision is recommended.

1 S ee 75 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 requisite protection of public health and welfare, respectively.6 ATTACHMENT A

OTC Model Rule for Adhesives and Sealants and Pennsylvania’s 25 Pa. Code Chapters 121, 129, and 130 Provisions Compared to the Control 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 mainta in the eight

- hour ozone standard and reduce eight

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

- specific administrative requirements and procedures. Pennsylvania‟ s adopted 25 Pa. Code Chapters 121, 129, and 130

are 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 CAR B determination were adopted in regulatory form in various air pollution 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 seala nt primers sold in the state; and (2) use restrictions that apply 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 ad dress adhesive and sealant usage at area sources. Emissions from 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 quality standard (NAAQS).

Control Techniques Guideline

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

- “ Control Techniques

Guidelines for Mi scellaneous 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 authorit ies information that should assist them in determining RACT for VOCs from miscellaneous7

industrial adhesive application processes. In developing this CTG, EPA, among other things, evaluated the sources of VOC emissions from miscellaneous industrial adhesi ves application processes and the available control approaches for 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 own determination as to what constitutes RACT for VOCs for miscellaneous industrial adhesive application processes in their particular nonattainment areas. The information contained in this do cument is provided only as guidance. This guidance does not change, 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 require ments 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 consist ent 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 applic ability criteria that differ from those recommended here [in this 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 cat egories 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

a pplicable to manufacturers, processors, distributors, or importers 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 recommend 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 u pon States

, upon regulation of end

- users and manufacturers, processors, 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. Applicability8

(1) The scope of the CTG is focused on industrial 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 indu strial adhesive application processes, including related cleaning 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 mo del 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 w ho: sells, supplies for sale, offers for sale or manufactures for 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 de finitions for those terms. The OTC model rule contains additional 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 whi le 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 appears 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 be a process that occurs at a manufacturing facility. The OTC model rule and section 121.1 regulate “tire retread” and defines the category in terms of manufacture and not the repair of a pun cture. Section 121.1‟ s definition is consistent with South Coast Air 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 “t ire retread” and “tire repair” processes, the OTC

model rule and section 121.1 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

u sed for cleaning application equipment, but the OTC model rule does make 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 adhesives9

category and are therefore not covered by this CTG, and (2 ) nonmembrane roof installation and 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 adhesives 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 t he 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 an d 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 ap plies 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 apply 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 se alant primer that has an applicable VOC content limit specified in Table 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 industr ial adhesive application processes, including related cleaning 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 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 sections 129.77 and

130.701

– 130.708 contained the following limits for cleaning materials:

a. Limits the VOC content of the surface preparation solvent to less than 70 grams per liter;10

b. L imits the VOC content of surface preparation 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 C elsius;

c. L imits materials containing VOCs used to remove adhesives, sealants, or adhesive or sealant 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 applica tion equipment be cleaned in enclosed cleaning system s using cleaning solvents with less than or equal 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, exclu ding water and exempt compounds, is less than or equal to 9.5 mm Hg at 20 degrees Celsius.

(5) Both 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 weight. The OTC model rule includes additional provisions to insure that the control equipment is operated properly.

(6) Both the CTG and OTC model rule requi re 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 pr imers, sealant primers, surface preparation or clean

- up solvents.

(8) The CT G also recommends that 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 spray, flow coat, roll coat or hand application including non

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

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

. The CTG recommends appl ication methods with good transfer efficiencies for stationary facilities and does not make recommendations for field applied

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

IV. Exemptions and Exceptions

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

a. Adhesives, sealants, adhesive primers or sealant primers being tested or evaluated in11

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 manufacturer or supplier in containers with a net volume of 16 fluid ounces or less, or 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 manufactur e of aerospace or undersea

- based weapon
systems.

f. Solvent welding operations used in the manufacture 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 categories 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 model 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 recommended 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. S ome 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 bon d clear, polyester acetate laminate to wood with lamination equipment installed prior to July 1, 1992. Any

2 The latest listing of product categories regulated under section 183(e) of the CAA was published on May 16, 2006 (71 FR 28320).12

person claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance w ith this exemption and in accordance with section (V) of this rule.

In addition, t he CTG recommends that these sources be subject to the work practices

recommendation.

(3) The OTC model rule exempts total VOC emissions from all adhesives, sealants, adh esive primers and sealant primers used at a facility that are less than 200 pounds per calendar year, or 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, sealant 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 claiming exemption pursuant to this subparagraph shall record and maintain monthly operational records sufficient to demonstrate compliance. This is equi valent to 400 pound per year, while the CTG applicability starts at 6.8 kg/day (15 lb/day) or an equivalent 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 sections 129.77 and 130.701

– 130.708

.

(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 the VOC content limits and recording the key operating parameters for the control equipment that must be maintained for five ye ars. Any S tate rule for a CTG must contain monitoring and recordkeeping requirements.

VI. Compliance Procedures and Test Methods

Both the CTG and OTC model rule contain the same primary test methods and compliance procedures. The OTC model rule con tains 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.13

VII. Container Lab eling

The OTC model rule requires labeling of product container with the maximum or actual VOC content of the product along with information 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 limits for adhesives, sealants, adhesive primers sealant primers and adhesives applied to particular substrates. Where ther e is no comparable limit the column is left blank. In the CTG recommendation column, categories with brackets { } around them indicates there is a 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 adopted rules (CARB model rule) for which the

OTC model rule was based on.

Both the CTG and the OTC model rule were based o n the California rulemaking efforts for this category and the CTG also bases its recommended emission limits on the OTC model rule (see 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 Prime rs 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 manufacturing 850

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

Cove base installation 150 Cove Base Installation 1 5014



### OTC Model Rule CTG Recommendation

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 Veh icle Adhesive [Note H] 250

Motor Vehicle Weatherstrip
Adhesive [Note H] 750

Multipurpose
construction 200 Multipurpose Construction 200

Nonmembrane roof installation/repair 300

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

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

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

Single

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

- Ply Roof Membrane Installation/Rep air (Except EPDM) 250

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

Tire retread [Note A] 100

Perimeter bonded sheet vinyl flooring installation 660 {Floor Covering Ins tallation (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

M arine deck 76015



### OTC Model Rule CTG Recommendation

Nonmembrane roof installation/repair 300

Roadway 250
Single

- ply roof
membrane 450

Other 420

Adhesive Primers Adhesive Primer Application Processes

Automotive glass [Note G] 700

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

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

Single

- ply roof
membrane 250 Single

- Ply Roof Membrane
Adhesive Primer [Note B] 250

Traffic marking tape 150

Other [Note G] 2 50 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 Applica tion Processes 2 [Note E]

Flexible vinyl [Note H] 250 Flexible vinyl 250
Fiberglass [Notes F & H] 200
Reinforced plastic 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 25016



### OTC Model Rule CTG Recommendation

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 th e highest VOC emission limit is recommended as the limit for such application. The analogous provision in the OTC Model Rule is found 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 these rules set a limit for “tire repair” adhesives (as that term is defined in each of these rules) but rather set a limit for “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 whereas in the OTC model

rule this is to be understood from the sub

- heading.

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

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

- The term “Sheet

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

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

Both the OTC Model Rule and the CTG definitions for “Contact bond adhesi ve” 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. T he 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.”17

F. The CTG covers more materials with the broader definition of “ Reinforced plastic composite” than the OTC model rule if the latter considers “fiberglass” to means fine glass fibers in a plastic resin. But the OTC rul e defines “fiberglass” as a material consisting of extremely fine glass fibers; thus, a “fiberglass substrate adhesive” could be interpreted as meaning an adhesives used to bond glass fibers together or to another listed substrate. The OTC definition is

c onsistent 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 fiberg lass as “...any fiber reinforced plastic (FRP) surface that has fiber material set in a binding substance of plastic resins” which appears 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 Bonding Primer” both cover the same material or process the recommendation in the OTC model rule is more stringent. To the

exten t 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 un der the other primer category. The recommendation in the OTC model rule for applying an “Automotive glass adhesive primer” to automotive glass is clearly more stringent. However, recommendation in the CTG for “Motor Vehicle Glass Bonding Primer” would co ver primers applied to “ body openings ” prior to the application of glass bonding adhesives or the installation of adhesive bonded glass. Body openings may include substrates such as bare metal or plastic as well as the glass itself. To the extent the lim it for “other adhesive primers” covers “Motor Vehicle Glass Bonding Primers” other than those when applied to automotive glass, the recommendation 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 model rule covers these applications under the “Adhesives Applied to the Listed Substrate” and which limit applies. The app licable limit depends upon what substrates are involved. The OTC model rule allows compliance to the higher of two applicable substrate limits when bonding dissimilar substrates. In no case is an OTC limit for any “listed substrate” greater than that re commended 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 based upon comment that such limits could not be met for field applied EPDM. Some OTC States have limited the CTG

recommend ation for May 1 to September 30 for two years and then set the limit year

- round after

that.18

IX. Conclusions

The OTC Model rule and specifically, sections 129.77 and 130.701

– 130.708

, for adhesives and

sealants and the 2008 CTG for miscellaneous industr ial 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 with manufacturing operations that use these types of products. Whereas, the OTC model rule inclu des these sources as well as smaller operations, operations performed in the field and also regulation of the manufacture, distribution and sale of the products themselves. The OTC model rule also regulates sealants and sealant primers which are

not inclu ded in the CTG because they were not categorized with miscellaneous industrial

adhesives under section 183(e)

.

The CTG and the OTC model rule exemption categories are very simila r though some differences exist, but the CTG recommends that exempted operati ons 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 so very few emission reductions are missed by n ot 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 mod el 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 stringent, i.e. limiting clean

- up solvent vapor pressure and VOC content, and cleaning of spray appli cation 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 methods. Maryland ‟ s proposed rulemaking

states that 96 percent of the adhesive and se alant VOC emiss ions 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 that when the S tates evaluate RACT as required by section 182 (b) when implementing a revised 8 hou r ozone standard 3 , that they review and evaluate the benefit of requiring improved methods for applying coatings regulated by the OTC model rule and

3 See 75 FR 2938, January 19, 2 010; 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 h ealth and welfare, respectively.19

specifically, sections 129.77 and 130.701

– 130.708

.

Overall, the CTG and the OTC model rule emission limi ts 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 lin e

- 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 described in this document and/or promulgate applicability criteria that diff er from those recommended here.” (CTG p age 3.) For the most part the OTC Model rule and specifically, sections 129.77 and 130.701

– 130.708 , match the CTG‟s recommendations item by item. The OTC Model rule and specifically, sections 129.77 and

130.701

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

sections 129.77 and 130.701

– 130.708 , sets standards for clean

- up and su rface preparation 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, sections 129.77 and 130.701

– 130.708 , meets the requirement for RACT in this so urce category.