Department of the Environment Maryland VOC Standards for Roof Coatings International Roof Coatings Conference July 17, 2014
Topics Covered Air Quality Overview OTC Process Existing MD VOC Regulations OTC Phase II AIM Next Steps and Schedule
The Current Ozone Standard Implemented by EPA in 2012 75 parts per billion (ppb) 8-hour average MD Attainment Plan to EPA in 2015 Comply with standard by 2018 Ozone is formed when NOx and VOC emissions react with intense summer sunlight 100 s of regulations implemented to reduce VOC and NOx emissions Local emissions greatly reduced and much improved air quality MD current focus is primarily on NOx Still need local controls and to address transport of pollution
1-Hour Ozone (ppb) 160 120 80 40 0 20 Annual PM 2.5 (ug/m 3 ) 16 12 8 4 17.1 152 147 143 137 126 Annual Fine Particulate 121 119 119 1997 1999 2001 2003 2005 2007 2009 2011 Cleanest Air in 30 Years 1-Hour Ozone 15.9 15.8 16.2 15.9 15.6 14.5 12.9 11.7 11.1 11.3 107 107 104 We still struggle to meet the current 75 ppb ozone standard and there is a tougher EPA standard on the way 41 42 41 41 8-Hour Ozone Daily Fine Particulate 39 94 93 91 89 93 1997 1999 2001 2003 2005 2007 2009 2011 37 35 33 30 29 29 120 80 40 0 50 40 30 20 10 Daily PM 2.5 (ug/m 3 ) 8-Hour Ozone (ppb) 0 2002 2004 2006 2008 2010 2012 2002 2004 2006 2008 2010 2012 0 p. 4
A More Focused Problem 1990 2005 2000 2010 p. 5
Addressing Local and Regional Emissions On August 6, 2013 - Approximately 30 states participated in a call to begin a technical collaboration on ozone transport in the East There was discussion and general agreement on beginning technical analyses of a scenario (called Phase 1 ) that would try and capture the progress that could be achieved if: The EPA Tier 3 and Low Sulfur Fuel program is effectively implemented The potential changes in the EGU sector from shutdowns and fuel switching driven by MATS, low cost natural gas and other factors were included The potential changes in the ICI Boiler sector driven by Boiler MACT and low cost natural gas were also included There was also general agreement that any strategies beyond Phase 1 would require Commissioner level discussions
COMAR 26.11.35 - VOCs from Adhesives and Sealants Adopted April 2008 with Effective date of January 1, 2009 Existing COMAR 26.11.35 contains VOC content limits for the following roofing categories: Nonmembrane roof installation/repair Single-ply roof membrane installation or repair Nonmembrane roof installation/repair (sealant) Single-ply roof membrane (sealant) Single-ply roof membrane (adhesive primers) Surface preparation and clean up solvents apply for single-ply roofing as well under 26.11.35.
Roofing Industry Amendment COMAR 26.11.35 adopted April 2008 with Effective date of January 1, 2009 Following adoption of the rule, we worked with the roofing industry to develop an amendment allowing for a winter time exemption lasting several years (ending 2012) Allowed roofing industry to develop adhesives, sealants, and adhesive primers that could meet the VOC standards and perform under cold temperatures Allowed time for operator training Amendment adopted as an emergency action effective January 1, 2009
Requirements of 26.11.35 Provides options for appliers to either use a product with a VOC content equal to or less than a specified limit or to use add-on controls Establishes standards for cleanup solvents Establishes a VOC limit for surface preparation solvents Provides for an alternative add-on control system requirement of at least 85 percent overall control efficiency (capture and destruction), by weight Provides exemptions for certain operations such as medical and defense equipment manufacturing and small containers
Requirements of 26.11.35 (cont.) Requires records of materials used and VOC content to be maintained for 5 years. Requires that VOC-containing materials must be stored or disposed of in closed containers Prohibits the sale of any adhesive, sealant, adhesive primer or sealant primer that exceeds the VOC content limits Requires manufacturers to label containers with the maximum VOC content as supplied, as well as the maximum VOC content on an as-applied basis Prohibits the specification of any adhesive, primer, or sealant that violates the provisions of the proposed regulations
Adhesives & Sealants Standards Roofing Category Nonmembrane roof installation/repair Single-ply roof membrane installation or repair Nonmembrane roof installation/repair (sealant) Single-ply roof membrane (sealant) Single-ply roof membrane (adhesive primers) VOC Limit 300 g/l 250 g/l 300 g/l 450 g/l 250 g/l
Recordkeeping List of adhesives in use Data sheets Catalysts, reducers or other components used VOC content as supplied VOC content as used Monthly volume used or MDE approved alternative compliance option
Emission Reductions OTC Model Rule estimates 64 to 78 percent reduction from uncontrolled levels. Maryland reductions based on lower range of estimate would be roughly 6 tons per day VOC in 2009.
OTC AIM II Model Rule Maryland's existing AIM rule, COMAR 26.11.33, has VOC content limits for several roofing coatings and primers OTC's AIM II rule, updated in 2011, adds an additional roofing coating category and lowers the VOC content limit for another The following outlines the amendments as a result of AIM II. Rules AIM II 26.11.33 Aluminum Roof Coatings 400 g/l NA Bituminous Roof Coatings 270 g/l 300 g/l Bituminous Roof Primers 350 g/l 350 g/l Roof Coatings 250 g/l 250 g/l
OTC AIM II Adoption Schedule Stakeholder process summer 2014 Air Quality Control Advisory Council December 8, 2014 Public Hearing April 2015 Adopted May 2015
For More Information: Regulations Development Division Air & Radiation Management Administration Maryland Department of the Environment 410-537-4219 1800 Washington Boulevard Baltimore, MD 21230-1718 410-537-3000 TTY Users: 1-800-735-2258 www.mde.state.md.us