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# Final text COMAR 26.11.19.26 & .26-1

effective September 28, 2015

.26 Control of Volatile Organic Compound Emi ssions from Reinforced Plastic Manufacturing.

A. Applicability.

(1) This regulation applies to reinforced plastic manufacturing at a premises where the total actual VOC emissions from all reinforced plastic ma nufacturing including tooling, touch-up, and repair is 20 pounds or more per day.

(2) The requirements in this regulation do not apply to pol yester resins used for tooling or touch-up and repair.

(3) The requirements in this regulation do not apply to any fiberglass boat manufacturing facility as defined in Regulation .26-1B(5) of this chapter.

B. Definitions. In this regulation, the following terms have the meanings indicated:

(1) "Clean-up material" means any material used in reinforced plastic manufacturing to clean parts, tools, equipment, and work areas.

(2) "Low styrene resin" means a polyest er resin that has a monomer content of 35 percent or less by weight as applied.

(3) "Monomer" means a low molecular weight organic compound that reacts with itself or other similar compounds to produce a polyester resin.

(4) "Non-VOC cleanup material" means a material that is used to clean products, tools, process equipment, and other equipment used in the manufacture of reinforced plasti c products and contains less than 5 percent VOC by weight or a material that has a VOC partial pressure not exceeding 0.74 pound per square inch.

(5) "Polyester resin (resin)" means a mixture of true esters dissolved in a polym erizable monomer such as

styrene.

(6) "Reinforced plastic manufacturing" means the curing of po lyester resins with fiberglass, inert fillers, or other

reinforcement materials.

(7) "Specialty resin" means a polyes ter resin used in special applicati ons involving high strength, corrosion

resistance, fire resi stance, or gel coat.

(8) "Tooling" means the production of molding tools such as shapes, matrixes, molds, or other instruments and utensils that are used during reinforced plastic manufacturing.

(9) "Touch-up and repair" means sma ll quantity use of polyester resin to repair minor surface damage or imperfections, where the total polyester resin used is less than 1 percent of the total quarterly polyester resin used as reported in §D(1) of this regulation.

C. Requirements.

(1) Except as provided in §C(3) of this regulation, a person subject to this regulation with ac tual VOC emissions of 20 pounds or more per day shall use low styrene resins.(2) A person subject to this regulatio n with actual VOC emissions of 100 pounds or more per day shall also use an improved application method such as:

(a) An airless or air-assisted airless spray gun;

(b) A low pressure nozzle;

(c) A pressure-fed roller or flow coater; or

(d) Some other nonatomized resin application technique.

(3) A person subject to this regulatio n who uses a specialty resin may not use a specialty resin with a monomer content exceeding 50 percent by weight as applied.

(4) A person subject to this regulation shall use non-VOC cleanup materials.

D. Record Keeping.

(1) A person subject to this regulation shall maintain records that provide the following information:

(a) A description of each polye ster resin material used; and

(b) The total weight and VOC content of each polyester resin material used quarterly.

(2) Records shall be maintained for not less than 3 y ears and made available to the Department upon request.

.26-1 Control of Volatile Organic Compound Em issions from Fiberglass Boat Manufacturing.

A. Applicability.

(1) This regulation applies to any fiberglass boat manufacturing facility where the total actual VOC emissions, before add-on controls, from all fiberg lass boat manufacturing is 15 pounds or more per day as determined on a monthly average.

(2) VOC emissions from polyester resins , tooling resins and gel coats, anc illary parts production, touch-up, cleanup, and repair are to be included in determining VOC emissions pursuant to §(A)(1) of this regulation.

B. Definitions. In this regulation, the following terms have the meanings indicated:

(1) Atomized Resin Application.

(a) “Atomized resin application” means a resin application technolog y in which the resin leaves the application equipment and breaks into droplets or an aerosol as it trav els from the application equipment to the surface of the part.

(b) “Atomized resin application” includes, but is not limited to, resin spray guns and resin chopper spray guns.

(2) Clear Gel Coat.

(a) “Clear gel coat” means a gel coat that is clear or translucent such that underlying colors are visible.

(b) “Clear gel coat” does not include tooling gel coats used to build or repair molds.

(3) Closed Molding.

(a) “Closed molding” means any molding proces s that has the following characteristics:

(i) Pressure is used to distribute the resin through the reinforcing fabric placed between two mold surfaces to either saturate the fabric or fill the mold cavity; and(ii) Clamping pressure, fluid pressure, atmospheric pressu re, or vacuum pressure ar e applied either alone or

in combination.

(b) “Closed molding” includes, but is not limited to, compression molding with sheet molding compound, infusion molding, resin injection molding (RIM), vacuum a ssisted resin transfer molding (VARTM), resin transfer molding (RTM), and vacuum a ssisted compression molding.

(c) “Closed molding” does not include:

(i) Processes in which a closed mold is used only to compact saturated fabric or remove air or excess resin from the fabric (such as in vacuum bagging); or

(ii) Open molding steps such as application of a gel coat or skin coat layer by conventional open molding prior to a closed molding process.

(4) “Fiberglass boat” means any type of vessel, other than a seaplane, that can be used for transportation on the

water, in which either the hull or deck is built from a co mposite material consisting of a polyester resin or other thermosetting resin matrix reinforced with fiberglass (glass fibe rs), inert filler or other reinforcing materials such as

fibers of carbon or aramid.

(5) Fiberglass Boat Manufacturing Facility.

(a) “Fiberglass boat manufacturing facility” means a facility that manufactures hulls or decks of fiberglass boats, assembles fiberglass boats from prem anufactured hulls and decks, or builds molds to make hulls or decks of fiberglass boats.

(b) “Fiberglass boat manufacturing facility” does not include a facility which:

(i) Manufactures ancillary parts for fiberglass boats (such as hatches, seats, or lockers) or boat trailers; and

(ii) Does not manufacture hulls or decks of fiberglass boats, assemble fiberglass boats from premanufactured hulls and deck s, or build molds for fiberglass boat hulls or decks.

(6) “Filled resin” means a resin to which an inert material has been added to change viscosity, density, shrinkage, or other physical properties.

(7) “Gel coat” means a thermosetting resin surface coating containing styrene (Chemical Abstract Service (CAS No. 100–42–5) or methyl methacrylate (CAS No. 80–62–6) that:

(a) Provides a cosmetic enhancement or improves resist ance to degradation from exposure to the elements;

(b) Does not contain any reinforcing fibers; and

(c) Is applied directly to mold surfaces or to a finished laminate.

(8) “Mold” means the cavity or surface into or on whic h gel coat, resin, and fibers are placed and from which finished fiberglass parts take their form.

(9) “Monomer” means a low molecular weight organic compound that reacts with itself or other similar compounds to produce a polymer such as a polyester or vinylester resin.

(10) Nonatomized Resin Application.

(a) “Nonatomized resin application” means any application technology in which the resin is not broken into droplets or an aerosol as it travels from the a pplication equipment to th e surface of the part.

(b) “Nonatomized resin application” in cludes, but is not limited to, flowcoaters, ch opper flowcoaters, pressure fed resin rollers, resin impregnators, and hand application by paint brush or paint roller.(11) “Non-monomer” means any low molecular weight orga nic compound that does not re act with itself or other similar compounds to produce a polymer and is assumed to be emitted fully as a VOC into the atmosphere.

(12) “Non-VOC cleanup material ” means a material that:

(a) Is used to clean produc ts, tools, process equipment, and other equipment used in the manufacture of fiberglass boats; and

(b) Either contains less than 5 percent VOC by weight or has a VOC composite vapor pressure of no more

than 0.5 millimeters of merc ury at 68 degrees Fahrenheit.

(13) Open Molding and Gel Coat Operations.

(a) “Open molding and gel coat opera tion” means any process in which th e reinforcing fibers and resin are placed in the mold and are open to the surrounding air while the reinforcing fibers are saturated with resin.

(b) “Open molding and gel coat operati on” includes operations in which a v acuum bag or similar cover is used to compress an uncured laminate to rem ove air bubbles or excess resin, or to achieve a bond between a core material

and a laminate.

(14) Pigmented Gel Coat.

(a) “Pigmented gel coat” means an opaque gel coat.

(b) “Pigmented gel coat” does not include tooling gel coats used to build or repair molds.

(15) Production Resin.

(a) “Production resin” means any resin used to manufacture parts for sale.

(b) “Production resin” does not include tooling resins used to build or repa ir molds, or asse mbly adhesives.

(16) “Pure, 100-percent, vinylester resin used for skin coats” means resins containi ng only vinylester resin and does not include any resin containing blends of vinylester and polyester resins.

(17) “Resin and gel coat mixing operation” means any opera tion in which a resin or gel coat is combined with additives that include, but are not limited to, fillers, promoters, or catalysts, and includes operations making putties or polyputties used to assemble parts of fiberglass boats and to fill gaps between parts.

(18) “Skin coat” means a layer of resin and fibers appl ied over a gel coat to prot ect the gel coat from being deformed by an additional laminate layer or layers.

(19) “Tooling” means the production of molding tools such as shapes, matrixes, molds, or other instruments and utensils that are used during ma nufacturing of fiberglass boats.

(20) “Tooling resin” means, for the purpos es of §C(1) of this regulation, the resin used to build or repair molds (also known as tools) or prototypes (also know n as plugs) from which molds will be made.

(21) “Tooling gel coat” means, for the purposes of §C(1) of this regulation, the gel coat used to build or repair molds (also known as tools) or prototypes (als o known as plugs) from which molds will be made.

(22) “Total VOC Content (percent by weight)” mean s the sum of the monomer content (percent by weight) determined according to §D(1) of this regulation and of the weight percent of the non-monomer VOC determined by §D(3) of this regulation.

(23) Vacuum Bagging.

(a) “Vacuum bagging” means any molding technique in which the reinforcing fabric is saturated with resin

and then covered with a flexible sheet th at is sealed to th e edge of the mold and where a vacuum is applied under the sheet to compress the laminate, remove excess resin, or remove trapped air from th e laminate during curing.(b) “Vacuum bagging” does not include closed molding.

(24) “Vinylester resin” means a thermosetting resin contai ning esters of acrylic or methacrylic acids and having double-bond and ester linkage sites only at the ends of the resin molecules.

C. Requirements.

(1) A person who owns or operates a fi berglass boat manufacturing facility subject to this regulation shall:

(a) Not cause or permit the discharge into the atmosphe re of any VOC from resin and gel coat operations in excess of the following standards, except as provided in §C(3) of this regulation:

Operation Application

Method Total Monomer

Content (percent by weight) Total VOC

Content (percent by weight)

Production resin Atomized resin application (spray) 28 33

Production resin Nonatomized resin application 35 40

Pigmented gel coat Atomized or nonatomi zed resin application 33 38

Clear gel coat Atomized or nonatomi zed resin application 48 53

Tooling resin Atomized resin application (spray) 30 35

Tooling resin Nonatomized resin application 39 44

Tooling gel coat Atomized or nonatomi zed resin application 40 45

(b) Notwithstanding §C(3)(a) and (b) of this regulatio n, use nonatomizing resin application equipment when applying production resins (including skin coat resins) pursuant to §C(3)(a) of this regulation, and pure, 100-percent vinylester resins pursuant to §C(3)(b) of this regulation.

(c) Not cause or permit the discharge into the atmos phere of any VOC from any resin and gel coat mixing operation unless all mixing containers with a capacity equal to or greater than 208 liters (55 gallons), including those used for on-site mixing of putties and polyputties, have a cover with no visible gaps in place at all times except when material is being manually added to or removed from the container, or when mixing or pumping equipment is being placed in or removed from the container.

(d) Only use non-VOC cleanup materials.

(2) Alternative Compliance Option. In lieu of meeting the standards of §C(1)(a) of this regulation, a person who owns or operates a fiberglass boat manufacturing facility subject to this regulation may cause or permit the discharge into the atmosphere of any VOC from filled resins provided that such emissions do not exceed the following non-monomer VOC content and as-applied

monomer VOC emission rates calc ulated using the equation in §D(3) of this regulation:

Type of Filled Resin Monomer Rate in kg Monomer VOC per Megagram of Filled Resin as Applied Non-monomer VOC

Content Limit of

Unfilled Resin

Production 46 5%

Tooling 54 5%(3) Exemptions. The standards in §C(1)(a ) of this regulation do not apply to:

(a) Production resins (including skin coat resins) that meet specifications for use in military vessels or must be approved by the U.S. Coast Guard for use in the construction of lifeboats, rescue boats, and other life-saving appliances approved under 46 CFR Chapter I, Subchapter Q, or the c onstruction of small passenger ve ssels as regulated by 46 CFR Chapter I, Subchapter T;

(b) Pure, 100-percent vinylester resins used for skin coat s where the total quantity of such resins used is less than or equal to 5 percent by weight of all resin used at a fiberglass boat manufacturi ng facility on a 12-month rolling average basis, as reported in §E(5)—(7) of this regulation;

(c) Production and tooling resins, and pi gmented, clear, and tooling gel coat s, which are used for touch up and repair of parts or molds and which are used in quantities less than or equal to 1 percent by weight of all resin used at a fiberglass boat manufacturing facility on a 12-month rolling aver age basis, as reported in §E(1) of this regulation;

(d) Resins used in closed molding;

(e) Polyester resins used for tooling or touch-up a nd repair during a manufacturing process that is not fiberglass boat manufacturing;

(f) Coatings applied to fiberglass boats; and

(g) Adhesives used in the assembly of fiberglass boats.

D. Test Methods and Compliance Procedures.

(1) A person who owns or operates a fi berglass boat manufacturing facility subject to this regulation shall determine the monomer VOC content of any resin or gel coat applied at the facility using:

(a) South Coast Air Quality Manage ment District (SCAQMD) Method 312-91, Determination of Percent Monomer in Polyester Resins, revised April 1996; or

(b) Manufacturer’s formulation data.

(2) In the event of a conflict between the monomer VOC content of any resin or gel coat indicated by the

manufacturer’s formulation data and the re sults of a test using the method referenc ed in §D(1)(a) of this regulation, the test results shall be used for the purpose of determining compliance with this regulation.

(3) A person meeting the alternative emission rates in §C(2) of this regulation shall compute the as-applied monomer VOC emission rate for the filled production re sin or tooling resin, in kilograms monomer VOC per megagram of filled material, using the following equation:



### Where

PV F is the as-applied monomer VOC emission rate for the filled productio n resin or tooling resin, kilograms monomer VOC per megagram of filled material.

PV

u is the monomer VOC emission rate for the neat (unfilled) resin, before filler is a dded, as calculated using the formulas in the table in §D(4) of this regulation. Filler pct is the weight-percent of filler in the as-applied filled resin system.

(4) The monomer VOC emission rate for the neat (unfilled) resin, before filler is added, PV

u , shall be calculated using the formulas in the following table:Monomer VOC Emission Rate Formulas for Open Molding and Gel Coat Operations

Material Application Method Formula to Calculate the Monomer

VOC Emission Rate 1

Production resin or tooling resin Atomized resin application 0.014 x (Resin VOC%) 2.425

Atomized resin appli cation, plus vacuum bagging with roll-out 0.01185 x (Resin VOC%) 2.425

Atomized resin appli cation, plus vacuum bagging without roll-out 0.00945 x (Resin VOC%) 2.425

Nonatomized resin application 0.014 x (Resin VOC%) 2.425

Nonatomized resin app lication plus vacuum bagging with roll-out 0.0110 x (Resin VOC%) 2.275

Nonatomized resin app lication plus vacuum bagging without roll-out 0.0076 x (Resin VOC%) 2.275

Pigmented gel coat, clear gel coat, tooling gel coat All methods 0.445 x (Gel coat VOC%) 1.675

1 Where the resin VOC% is the monomer VOC content as supplied, expressed as a weight-percent value between 0 and 100 percent.

(5) A person meeting the alternative emission rates in §C (2) of this regulation shal l demonstrate the as-applied

non-monomer VOC content of re sins and gel coats using the test method prescribed in COMAR 26.11.19.02D(1), and for this purpose, resins and gel coat s shall be considered coatings .

(6) For the purpose of demonstrating that a cleanup ma terial is a non-VOC cleanup material, a person shall:

(a) Perform a test using the method prescribed in COMAR 26.11.19.02D(1), where the cleanup material shall be considered a coating; and

(b) Determine the com posite vapor pressure of organic-compounds in a cleanup material using the calculation prescribed in COMAR 26.11.19.02E(3).

E. Record Keeping. A person who owns or operates a fi berglass boat manufacturing facility subject to this regulation shall maintain for not less than 3 years, and shall make available to the Department upon request, records that provide the following information:

(1) A description of each polyester or vi nylester resin material used including:

(a) The manufacturer’s name;

(b) The type (e.g. production resin, production ge l coat, tooling resin, tooling gel coat);

(c) The amount of each of the polyeste r or vinylester resin materials used;

(d) The weight (in percent) of monomer for each polyester resin materials and filler or fillers used;

(e) The weight percent of VOC that is not monomer or th e total weight percent of the VOC content; and

(f) The type of application meth od used with each resin;

(2) On a quarterly basis, the total weight and the monomer content and VOC content of each polyester and vinylester resin material;

(3) On a quarterly basis, the total weight and the monomer content and VOC content of each polyester and vinylester resin material used under the exemption of §C (3)(a), of this regulation, including a description or identification (military specifications, 46 CFR Subchapter Q, or 46 CFR subchapter T) of the exemption;(4) On a monthly basis, the total we ight, monomer content, and VOC conten t of each polyester and vinylester resin material used for closed molding under the exemption of §C(3)(d) of this regulation;

(5) On a monthly basis, the total we ight, monomer content, and VOC conten t of each pure,100-percent vinylester resin used under the exemption of §C(3)(b) of this regulation;

(6) On a monthly basis, the tota l weight of all resins used;

(7) On a monthly basis, the total we ight of pure, 100-percent vinylester resins used under the exemption of §C(3)(b) of this regulation over the preceding 12 months divi ded by total weight of all re sins used over the preceding

12 months;

(8) On a daily basis, the to tal weight, monomer content, and VOC content of each resin used for touch up and repair of parts or molds under the exemption of §C(3)(c) of this regulation;

(9) For filled resins for which compliance is demonstrat ed under alternative compliance option of §C(2) of this regulation:

(a) The total weight and non-monomer VOC content of each polyester and vinylester resin material used; and

(b) The monomer emission rate comput ed in accordance with §D(3) of this regulation in kg monomer VOC per megagram of filled resin as applied.

(10) On a monthly basis, the total clean-up materials used.