AQ-2017-008-RULE336-REPORTTOTHEBOARDOFSUPERVISORS-2021-08.PDF

Executive Summary
of the Report to the Board of Supervisors
Prepared by the Maricopa County Air Quality Department
Board Hearing Date: September 1, 2021
Case Number/Title: AQ-2017-008: Rule 336 (Surface Coating Operations)
Agenda Item: (Pending)
Supervisor Districts: All Districts
The Maricopa County Air Quality Department (MCAQD) complied with all statutory and county
policies throughout this rulemaking process. Per the Enhanced Regulatory Outreach Program
(EROP) Policy: “In addition to the required staff report, an executive summary of the report
including an overview of stakeholder input and staff responses will be provided to the Board of
Supervisors at least one week prior to any Board of Supervisors’ public hearing.”
Overview of the Report to the Board of Supervisors:
On May 4, 2016, portions of Maricopa County were designated as a moderate nonattainment area
with respect to the 2008 National Ambient Air Quality Standards for Ozone. Section 182(b)(2) of
the Clean Air Act requires jurisdictions that are classified as "moderate" or higher nonattainment to
implement reasonably available control technology (RACT) for all categories of volatile organic
compound (VOC) sources covered by a Control Technique Guideline (CTG) document as well as
all other major stationary sources of VOCs that are located within in the nonattainment area. The
U.S. Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that
a particular source is capable of meeting by the application of control technology that is reasonably
available considering technological and economic feasibility”. The EPA provides guidance on RACT
for VOCs through their CTGs, which offer State and local air pollution control authorities
information that assists in determining VOC-RACT for air quality rules. In addition, the EPA
reviews state implementation plan (SIP)-approved air quality rules from other air districts with
ozone nonattainment areas to assist in determining VOC-RACT for air quality rules.
In November 2016, Rule 336 was revised to implement RACT for sources of VOCs. The revised
rule was submitted to the EPA in June of 2017, as part of the SIP Revision for the Maricopa County
Air Quality Department Ozone Rules contained in the Arizona SIP. The EPA reviewed Rule 336
and provided the MCAQD with written rule approvability and rule improvement comments for the
rule. EPA staff informed MCAQD staff they would be using a conditional approval process to act
on Rule 336 and the MCAQD would need to draft a commitment letter outlining revisions to Rule
336 to address the rule approvability comments.
On January 28, 2019, the MCAQD submitted a Letter of Commitment for Conditional Approval of
the Maricopa County RACT SIP to the EPA. Later, on December 5, 2019, the MCAQD submitted
a supplemental commitment letter to address additional rule approvability comments MCAQD
received after the original commitment letter was submitted. Based on the commitment letters, the
EPA published a proposed conditional approval of Rule 336 in the Federal Register on January 28,
2020 (Docket ID; EPA-R09-OAR-2019-0423). The proposed conditional approval rulemaking was
available for a 30-day comment period, but no comments were received.

The proposed conditional approval references a Technical Support Document (TSD) which
includes a thorough review of Rule 336 and MCAQD’s commitments. The TSD outlines EPA’s
seven (7) official rule approvability comments (“rule deficiencies”) - which preclude full approval of
the rule into the SIP - as well as 12 rule revision recommendations, which are not currently the basis
for rule disapproval but are recommended for this current proposed rulemaking for Rule 336.
Revisions addressing both the EPA’s identified deficiencies and recommendations have been made
to the proposed draft Rule 336.
EPA’s final conditional approval was published on January 7, 2021. The effective date of the final
rule was February 8, 2021. If the MCAQD, through the ADEQ, submits the rule revisions that the
MCAQD has committed to submit within 12 months and the EPA approves the submission, then
the identified deficiencies will be cured and the rule will be approved as part of the Arizona SIP.
Revisions addressing the EPA’s identified deficiencies and recommendations have been made to
Rule 336 and are included in this report.
Overview of Stakeholder Input and Staff Responses:
The MCAQD received written feedback from three stakeholders. One stakeholder expressed
support and two stakeholders expressed “other” for the proposed changes and also provided written
comments. The MCAQD evaluated the comments and drafted responses. The stakeholder
comments and the MCAQD responses to the comments are listed below.
Comment #1:
[Our organization] submits the following comments on MCAQD’s proposed amendments to Rule
336 (Surface Coating Operations). [Our organization] is a voluntary, nonprofit trade association
working to advance the needs of the paint and coatings industry and the professionals who work in
it. Notably, [our organization] represents a variety of marine coatings manufacturers and active
ingredient suppliers who sell pleasure craft coating products in Maricopa County, Arizona. Above
all, [our organization] and its member companies are committed to safeguarding the environment by
providing only top-quality marine coatings to recreational vessel owners.
Since 2010, [our organization] has worked diligently with MCAQD, the U.S. Environmental
Protection Agency (EPA), and other industry stakeholders to come up with a solution on how the
county should move forward with handling the VOC limits for the three pleasure craft coating
categories. [Our organization] agrees that MCAQD should lower the following pleasure craft coating
VOC limits to comply with the limits in EPA’s CTG:
• Extreme High Gloss Topcoat: 490 g VOC/l or 4.1 lbs VOC/gal
• Finish Primer/Surfacer: 420 g VOC/l or 3.5 lbs VOC/gal
However, we urge MCAQD to consider retaining the VOC limit for the following pleasure craft
coating category:
• Antifoulant Coating – Non-Aluminum Substrate: 400 g VOC/l or 3.4 lbs VOC/gal
[Our organization] members require a reasonable amount of lead time to adjust formulations and
supply chain processes in order to ensure compliance with amended VOC limits, labeling, and
reporting requirements. [Our organization] believes that industry needs additional time to comply
with the proposed lowered limit for Antifoulant Coating – Non-Aluminum Substrate. Furthermore,
at the proposed EPA CTG level (330 g VOC/l), consumers will not have a wide range of options
for these types of products and the market will be limited. It takes many years to develop, test, and

register a new antifouling coating. A limit of 400 g/L will ensure that industry can provide a full
range of products for differing water types, application temperatures, and fouling conditions.
In addition, our member believes that the limit for All Other Pleasure Craft Coatings for Metal or
Plastic category should be increased to 490 g VOC/l or 4.1 lbs VOC/gal to align with the Extreme
High Gloss Topcoat category. These types of coatings are applied to small parts of pleasure crafts
and would benefit from a higher VOC limit to be efficient.
[Our organization] looks forward to working with MCAQD and other interested stakeholders on
Rule 336 and hopes that MCAQD will eventually make an informed decision that is in the best
interests of its residents.
Thank you for your consideration of our concerns and please let us know if you have any questions.
Response #1:
Thank you for providing comments on the draft revisions to Rule 336. Below is a response to each
concern provided in your comments.
The MCAQD has evaluated your comment about retaining the current pleasure craft coating limit of
400 g VOC/l for Antifoulant Coating (Non-Aluminum Substrate) and has determined this VOC
limit cannot be retained. Rule 336 is currently being amended to ensure the rule meets the
reasonably available control technology (RACT) requirements of section 182(b) of the Clean Air Act
for ozone nonattainment areas classified as Moderate. The MCAQD has determined the 330 g
VOC/l emission limit proposed for Antifoulant Coating (Non-Aluminum Substate) in the current
draft rule meets RACT. This emission limit is consistent with limits in EPA’s Control Techniques
Guidelines (CTG) for Miscellaneous Metal and Plastic Parts Coatings and emission limits in the
CTGs are generally understood to be equivalent to RACT emission limits. In addition, the 330 g
VOC/l emission limit matches emission limits in several current RACT-approved rules within EPA
Region 9. The MCAQD must ensure Rule 336 meets RACT requirements so the rule can be
approved into the Arizona State Implementation Plan (SIP). Failing to lower the current limit for
Antifoulant Coating (Non-Aluminum Substrate) could jeopardize this approval and could ultimately
lead to federal highway and offset sanctions for Maricopa County further down the road. Finally, the
EPA recommended the MCAQD lower this limit last year (2020) and we are moving forward with
this lower limit in order to comply with their recommendation.
The MCAQD expects these lower emission limits will be incorporated into the rule sometime in
August of this year (2021) so there is time for industry to come into compliance by using up coatings
that will not comply with the proposed new limits and slowly beginning to purchase new coatings
that will comply with the new limits.
The MCAQD has evaluated your comment about increasing the VOC limit of 420 g VOC/l for All
Other Pleasure Craft Surface Coatings for Metal or Plastic to 490 g VOC/l and has determined this
limit cannot be increased. This limit is consistent with the limits in the EPA CTG for Miscellaneous
Metal and Plastic Parts Coatings. As mentioned above, Rule 336 is currently being amended to
ensure the rule meets RACT requirements and emission limits in the CTGs are generally understood
to be equivalent to RACT emission limits. In addition, the EPA published the final conditional
approval of the 2016 version of Rule 336 on January 7, 2021 so it is now part of the Arizona SIP.
Once a rule is approved as part of the SIP it is very difficult to relax any requirement in a rule as it
may be viewed as backsliding. Backsliding may jeopardize approval of the rule which may lead, as
mentioned earlier, to federal highway and offset sanctions for Maricopa County further down the
road.

Also, the MCAQD has reviewed all violations of Rule 336 issued through our Compliance division
since the 420 g VOC/l limit was adopted in 2016 and has not found any enforcement issues for this
particular coating category in Maricopa County. Our Business Assistance Office is available to assist
the regulated community with any compliance-related concerns by offering education, training, and
courtesy site visits as needed.
Comment #2:
Our materials are typically well below 50 grams/liter in VOC content which is minimal compared to
the proposed limits. We respectfully request that UV/EB/LED materials be exempted from the rule
requirements. An exemption would be an incentive for businesses to voluntarily choose
UV/EB/LED technology resulting in additional emission reductions for Maricopa County.
Recordkeeping requirements are burdensome on businesses and in the case of UV/EB/LED
operations, are not crucial because the materials are well below the rule limits. Exempting energy
curable materials from overly prescriptive recordkeeping requirements will alleviate regulatory
burdens on the Maricopa County business community and benefit air quality.
Response #2:
Rule 336 currently includes an exemption for coating products that have a VOC content, minus
exempt compounds, of less than 0.15lb VOC/gal (18g/L), and this exemption (found in Section
102.4 of the draft rule) will be retained with the current rulemaking. Also, there is no permitting
requirement in Maricopa County for facilities that emit any regulated air pollutant in an amount less
than the permitting thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting threshold
is 0.5 tons per year). These exemptions are in place to encourage businesses to adopt products and
practices which limit impacts on air quality.
In addition, Rule 336 was conditionally approved as part of the Arizona State Implementation Plan
(SIP) earlier this year. Any relaxation of the provisions in the rule may be considered backsliding,
which may jeopardize the full approval of the Rule 336 into the SIP and potentially lead to federal
highway and offset sanctions for Maricopa County further down the road.
Comment #3:
We would very much appreciate the inclusion of a definition for energy curable materials in the rule.
We propose a definition like the one in SCAQMD rules:
ENERGY CURABLE MATERIALS are single component reactive products that cure upon
exposure to visible-light, ultraviolet light, or to an electron beam.
Response #3:
Thank you for providing the MCAQD with a good working definition for energy curable materials.
However, a definition is not necessary since the MCAQD is not including any additional provisions
regarding these materials into this version of Rule 336.
Comment #4:
The Environmental Protection Agency and the SCAQMD have long recognized that EPA Method
24 is not suitable for thin film UV/EB/LED Materials. Thus, [our organization] urges Maricopa
County to include ASTM D7767-11 as suitable test method for UV/EB/LED products subject to
Rule 336. We propose the following language: The VOC content of thin film Energy Curable
Adhesives and Sealants may be determined by manufacturers using ASTM Test Method 7767

Standard Test Method to Measure Volatiles from Radiation Curable Acrylate Monomers, Oligomers,
and Blends and Thin Coatings Made from Them.
Response #4:
Since ASTM D7767-11 is not currently an EPA-approved test method, the MCAQD cannot include
it in Rule 336. Adding a test method that is not EPA-approved to this rule jeopardizes EPA’s
approval of Rule 336 into the SIP. However, Section 503.2 of the rule does allow for the use of
alternative EPA-approved test methods. If ASTM D7767-11 is approved by the EPA in the future,
then it can be considered as a suitable test method.
Comment #5:
UV/EB/LED products have higher viscosities than conventional solvent products. The rationale
behind transfer efficiency requirements is to control VOC emissions that can take place during
spraying operations. But, given the fact that UV/EB/LED materials do not have emissions like
conventional solvent processes, facilities should not be required to the same level of regulation for
transfer efficiency purposes. We urge Maricopa County to exempt UV/EB/LED materials with
viscosities of 650 centipoise or above, from the transfer efficiency requirements of the rule. UV/EB
materials not only meet, but far exceed any proposed rule requirements and any added flexibility to
companies that choose these pollution preventive processes will encourage voluntary emission
reductions thereby furthering the County’s mission.
Response #5:
The MCAQD conducted research on facilities within Maricopa County that are currently using
energy curable coating materials. We found these facilities are able to comply with the application
methods listed in Section 302. As such, there appears to be no operational need to revise the transfer
efficiency requirements of Rule 336. Also, in order to exempt any new materials from the
application methods listed in Section 302, the MCAQD would have to submit a 110(l)
demonstration to the EPA showing such an exemption would not interfere with any applicable
requirement concerning attainment and reasonable further progress, or any other applicable
requirement of the Clean Air Act. It is not clear if the EPA would approve such a demonstration
and, if it was not approved, the added exemption could be seen as a relaxation of the rule. As
mentioned earlier, any relaxation of the provisions of the rule could jeopardize the approval of Rule
336 into the Arizona SIP.

Report to the Board of Supervisors
Prepared by the Maricopa County Air Quality Department
Board of Health Meeting Date: April 26, 2021
Board Hearing Date: September 1, 2021
Case Number/Title: AQ-2017-008: Rule 336 (Surface Coating Operations)
Agenda Item: (Pending)
Supervisor Districts: All Districts
Applicant: Staff
Request: Approve revisions to Rule 336 (Surface Coating
Operations) of the Maricopa County Air Pollution Control
Regulations and approve submission of the revised rule as a
revision to the Arizona State Implementation Plan (SIP).
On May 4, 2016, portions of Maricopa County were
designated as a moderate nonattainment area with respect to
the 2008 National Ambient Air Quality Standards for Ozone.
Section 182(b)(2) of the Clean Air Act requires jurisdictions
that are classified as "moderate" or higher nonattainment to
implement reasonably available control technology (RACT)
for all categories of volatile organic compound (VOC)
sources covered by a Control Technique Guideline (CTG)
document as well as all other major stationary sources of
VOCs that are located within in the nonattainment area. The
U.S. Environmental Protection Agency (EPA) defines RACT
as “the lowest emission limitation that a particular source is
capable of meeting by the application of control technology
that is reasonably available considering technological and
economic feasibility”. The EPA provides guidance on RACT
for VOCs through their CTGs, which offer State and local air
pollution control authorities information that assists in
determining VOC-RACT for air quality rules. In addition, the
EPA reviews SIP-approved air quality rules from other air
districts with ozone nonattainment areas to assist in
determining VOC-RACT for air quality rules.
In November 2016, Rule 336 was revised to implement
RACT for sources of VOCs. The revised rule was submitted
to the EPA in June of 2017, as part of the SIP Revision for
the Maricopa County Air Quality Department (MCAQD)
Ozone Rules contained in the Arizona SIP. The EPA
reviewed Rule 336 and provided the MCAQD with written
rule approvability and rule improvement comments for the
rule. EPA staff informed MCAQD staff they would be using

a conditional approval process to act on Rule 336 and the
MCAQD would need to draft a commitment letter outlining
revisions to Rule 336 to address the rule approvability
comments.
On January 28, 2019, the MCAQD submitted a Letter of
Commitment for Conditional Approval of the Maricopa
County RACT SIP to the EPA. Later, on December 5, 2019,
the MCAQD submitted a supplemental commitment letter to
address additional rule approvability comments MCAQD
received after the original commitment letter was submitted.
Based on the commitment letters, the EPA published a
proposed conditional approval of Rule 336 in the Federal
Register on January 28, 2020 (Docket ID; EPA-R09-OAR-
2019-0423). The proposed conditional approval rulemaking
was available for a 30-day comment period, but no comments
were received.
The proposed conditional approval references a Technical
Support Document (TSD) which includes a thorough review
of Rule 336 and MCAQD’s commitments. The TSD outlines
EPA’s seven (7) official rule approvability comments (“rule
deficiencies”) - which preclude full approval of the rule into
the SIP - as well as 12 rule revision recommendations, which
are not currently the basis for rule disapproval but are
recommended for this current proposed rulemaking for Rule
336. Revisions addressing both the EPA’s identified
deficiencies and recommendations have been made to the
proposed draft Rule 336.
EPA’s final conditional approval was published on January 7,
2021. The effective date of the final rule was February 8,
2021. If the MCAQD, through the ADEQ, submits the rule
revisions that the MCAQD has committed to submit within
12 months and the EPA approves the submission, then the
identified deficiencies will be cured and the rule will be
approved as part of the Arizona SIP. A description of the
rule, the specific deficiencies and recommendations identified
by the EPA, the MCAQD’s proposed revisions to address the
deficiencies and recommendations for the rule, and the draft
rule with strikethrough-underline are included in the attached
draft Notice of Final Rulemaking.
Support/Opposition: The MCAQD received written feedback from three
stakeholders. One stakeholder expressed support and two
stakeholder expressed “other” for the proposed changes.
Staff
Recommendation: Approve

Board of Health
Recommendation: Approve
Additional Comments: This rulemaking is following procedures identified in state
statutes and the Maricopa County Enhanced Regulatory
Outreach Program (EROP) Policy. The County Manager
briefed the Board of Supervisors regarding the rulemaking in
December 2017. The Board of Health Meeting to approve
expedited rulemaking occurred on April 23, 2018.
Stakeholder Workshops were held on March 8, 2018, August
22, 2018, October 24, 2019, and July 16, 2020. A Notice of
Proposed Rulemaking was posted on the EROP website on
January 27, 2021. On April 26, 2021, the Board of Health
made a recommendation to the Board of Supervisors to
approve the revisions to Rule 336.
A newspaper notice of the Board of Supervisors public
hearing will be published in the Arizona Business Gazette on
July 15, 2021 and July 22, 2021. This regulatory change will
take effect immediately upon approval by the Board of
Supervisors.
Presented By: Philip A. McNeely, R.G., Director
Prepared By: Planning and Analysis Division
Attachments: Preamble required by Arizona Revised Statutes (A.R.S.) § 49-
471.07 (See the Draft Notice of Final Rulemaking)
Summary of the proposed regulatory change (See Item 4 of
the Draft Notice of Final Rulemaking)
Analysis of input received during the process and how that
input was responded to (See Item 9 of the Draft Notice of
Final Rulemaking)
Language of proposed regulatory change or amendment (See
the Draft Notice of Final Rulemaking)
Strikethrough-underline Version
Clean Version
Minutes from Board of Health meetings
Copies of all written and electronic Stakeholder input
EPA Region IX Air Division Technical Support Document
Draft Negative Declarations

DRAFT NOTICE OF FINAL RULEMAKING
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 336: SURFACE COATING OPERATIONS
The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 336 (Surface
Coating Operations). The Control Officer is posting this Draft Notice of Final Rulemaking on the
Maricopa County Enhanced Regulatory Outreach Program (EROP) website as part of the Report to
the Board of Supervisors, in accordance with the Maricopa County EROP Policy. This notice
includes the preamble, as prescribed in A.R.S. § 49-471.05, and the full text of the rule, including the
intended actions to make new sections or amend, repeal, or renumber the sections of the rule. This
notice also includes a list of all previous notices posted on the Maricopa County EROP website
addressing the proposed rule and the concise explanatory statement prescribed in A.R.S. § 49-
471.07, subsection B.
PREAMBLE Return to list of attachments
1. Statutory authority for the rulemaking:
A.R.S. §§ 49-112, 49-474, 49-479 and 49-480
2. Name and address of department personnel with whom persons may communicate
regarding the rulemaking:
Name: Laura Jardieanu or Kimberly Butler
Maricopa County Air Quality Department
Planning and Analysis Division
Address: 3800 N Central Avenue, Suite 1400
Phoenix, AZ 85012
Telephone: 602-506-6010
Fax: 602-506-6179
Email: AQPlanning@maricopa.gov
Submit Comments At: http://maricopa.gov/FormCenter/Regulatory-Outreach-
17/Citizen-Comments-94
3. Rulemaking process:
This rulemaking (AQ-2017-008-Rule 336) is following procedures identified in state statutes
and the Maricopa County EROP Policy:
County Manager Briefing: December 2017
Stakeholder Workshops: March 8, 2018
August 22, 2018
October 24, 2019
July 16, 2020
Board of Health Meeting to Approve Expedited
Process Rulemaking: April 23, 2018

Notice of Proposed Rulemaking: January 27, 2021
Board of Health Meeting to Recommend
Approval to the Board of Supervisors April 26, 2021
Board of Supervisors Public Hearing: September 1, 2021
4. Explanation of the rule, including the control officer's reasons for initiating the
rulemaking: Return to list of attachments
Rule 336 establishes limits for the emission of Volatile Organic Compounds (VOCs) from
surface coating operations. Rule 336 applies to VOC-containing coatings as well as related
activities, such as coating preparation/mixing, coating application, and the cleanup of
coating application equipment. The MCAQD is proposing to revise Rule 336 to address rule
deficiencies identified by the U.S. Environmental Protection Agency (EPA) to secure full
approval of Rule 336 as a revision to the Arizona State Implementation Plan (SIP).
On May 4, 2016, portions of Maricopa County were designated as a moderate nonattainment
area with respect to the 2008 National Ambient Air Quality Standards for Ozone. Section
182(b)(2) of the Clean Air Act requires jurisdictions that are classified as "moderate" or
higher nonattainment to implement reasonably available control technology (RACT) for all
categories of VOC sources covered by a Control Technique Guideline (CTG) document as
well as all other major stationary sources of VOCs that are located within in the
nonattainment area. EPA defines RACT as “the lowest emission limitation that a particular
source is capable of meeting by the application of control technology that is reasonably
available considering technological and economic feasibility”. The EPA provides guidance
on RACT for VOCs through their CTGs, which offer State and local air pollution control
authorities information that assists in determining VOC-RACT for air quality rules. In
addition, the EPA reviews SIP-approved air quality rules from other air districts with ozone
nonattainment areas to assist in determining VOC-RACT for air quality rules.
In November 2016, Rule 336 was revised to implement RACT for sources of VOCs. The
revised rule was submitted to the EPA in June of 2017, as part of the SIP Revision for the
Maricopa County Air Quality Department Ozone Rules contained in the Arizona SIP. The
EPA reviewed Rule 336 and provided the MCAQD with written rule approvability and rule
improvement comments for the rule. EPA staff informed MCAQD staff they would be
using a conditional approval process to act on Rule 336 and the MCAQD would need to
draft a commitment letter outlining revisions to Rule 336 to address the rule approvability
comments.
On January 28, 2019, the MCAQD submitted a Letter of Commitment for Conditional
Approval of the Maricopa County RACT SIP to the EPA. Later, on December 5, 2019, the
MCAQD submitted a supplemental commitment letter to address additional rule
approvability comments MCAQD received after the original commitment letter was
submitted. Based on the commitment letters, the EPA published a proposed conditional
approval of Rule 336 in the Federal Register on January 28, 2020 (Docket ID; EPA-R09-
OAR-2019-0423). The proposed conditional approval rulemaking was available for a 30-day
comment period, but no comments were received. The proposed conditional approval
references a Technical Support Document (TSD) which includes a thorough review of Rule
336 and MCAQD’s commitments. The TSD outlines EPA’s seven (7) official rule
approvability comments (“rule deficiencies”) - which preclude full approval of the rule into

the SIP - as well as 12 rule revision recommendations, which are not currently the basis for
rule disapproval but are recommended for this current proposed rulemaking for Rule 336.
Revisions addressing both the EPA’s identified deficiencies and recommendations have been
made to the proposed draft Rule 336 (included in this notice). A link to EPA’s TSD is
located under Section 5 of this notice.
EPA’s final conditional approval was published on January 7, 2021. The effective date of the
final rule was February 8, 2021. If the MCAQD, through the ADEQ, submits the rule
revisions that the MCAQD has committed to submit within 12 months and the EPA
approves the submission, then the identified deficiencies will be cured and the rule will be
approved as part of the Arizona SIP.
Details about the EPA’s identified deficiencies and the MCAQD’s proposed remedies are
described below, followed by the EPA rule recommendations and the MCAQD’s proposed
revisions to address the recommendations.
Deficiency 1:
Section 300, Standards, Table 336-2 contains VOC content limits for the categories of End
Sealing Compound: Food or Beverage, End Sealing Compound: Non Food, Sheet Basecoat
(Interior and Exterior) and Overvarnish, Two Piece Can Interior Body Spray, Three Piece
Can Interior Body Spray, Two Piece Can Exterior Base Coat Overvarnish, and Two Piece
Can Exterior End (Spray or Roll Coat) which comply with the 1977 CTG, "EPA450/2-77-
008, Control of Volatile Organic Emissions from Existing Stationary Sources- Volume II:
Surface Coating of Cans, Coils, Paper, Fabrics Automobiles and Light Duty Trucks," May
1977, but are generally significantly higher than the same limits in currently SIP-approved
rules such as SCAQMD Rule 1125, Sacramento AQMD Rule 452, BAAQMD Rule 8-11,
and SJVUAPCD Rule 4604. Because the lower limits have been achieved in other areas for
some time, the limits in Rule 336 do not demonstrate current RACT. The MCAQD must
lower the VOC limits for these categories.
Remedy 1:
The MCAQD is proposing to revise Table 336-2 to lower the VOC limits for the following
can coating materials: end sealing compound, sheet basecoat (interior and exterior) and
overvarnish, two-piece can interior body spray, three-piece can interior body spray, two-
piece can exterior base coat and overvarnish, and two-piece can exterior end spray or roll
coat. The lower emission limits are consistent with current RACT, based on a comparison of
RACT rules in other nonattainment areas.
Deficiency 2:
Section 103.2 exempts Extreme Performance Coatings from the VOC limits when used on:
a) internal combustion engines components that are normally above 250°F during use or
b) items that are used at temperatures above 250°F that are included under various NAICS
codes for telecommunications equipment and are electronic products in space vehicles
and/or are communications equipment.
The 2008 Miscellaneous Metal and Plastic Parts (MMPP), 2007 Metal Furniture, and 2007
Large Appliance CTGs do not exempt Extreme Performance Coatings. In addition, Rule
336, Tables 336-1, 336-3, 336-5 contain the appropriate VOC content limits for this category
and are consistent with the CTGs. The MCAQD must remove the exemption or provide
justification for the Extreme Performance Coating exemptions.

Remedy 2:
The MCAQD evaluated the exemption for extreme performance coatings and is proposing
to remove the exemption from Rule 336.
Deficiency 3:
Section 103.5.e exempts Tactical Military Equipment coatings that are in a District-approved
permit based on a demonstration that no compliant substitute exists.
The rule does not define "Tactical Military Equipment" and the 2008 MMPP CTG does not
include this exemption. Evaluate deleting this exemption if Tactical Military-Equipment
Coatings can fall under other CTG categories which include performance standards for
"extreme performance" or "military specification" coatings.
Remedy 3:
The MCAQD evaluated the exemption for tactical military equipment coatings and is
proposing to remove the exemption from Rule 336.
Deficiency 4:
Rule 336 is missing the VOC limits and categories for "Motor Vehicle Materials" as is found
in Table 6 Motor Vehicle Materials VOC Content Limits of the MMPP CTG. Rule 336
Table 336-4 "Coating Limits for Business Machines" is missing the VOC limits and
categories for Automotive/Transportation Coatings as is found in CTG Table 4 for
"Automotive/Transportation and Business Machine Plastic Parts VOC Content Limits."
The missing categories also do not appear in Maricopa Rule 345 Vehicle and Mobile
Equipment Coating. The MCAQD must add these CTG categories and VOC limits to the
rule, or if appropriate, consider adopting a negative declaration for the entire CTG category
table.
Remedy 4:
To determine if any emitting facilities in these coating categories exist in Maricopa County,
the MCAQD conducted file reviews for each facility that is permitted to conduct surface
coating operations in Maricopa County. During this evaluation, the MCAQD reviewed a
variety of documents, including the permit, the technical support document for the permit,
emissions inventory reports, inspection reports, and source records. When necessary, the
MCAQD also conducted web searches and made direct contact with Permittees to
determine the scope of permitted surface coating operations in Maricopa County.
In accordance with Section 182(b)(2) of the Clean Air Act, MCAQD is proposing to submit
negative declarations to the EPA certifying that there are no emitting facilities in Maricopa
County for the following coating categories identified in the 2008 Control Techniques
Guidelines for Miscellaneous Metal and Plastic Parts Coatings:
- Business Machine Plastic Part Coatings
- Automotive/Transportation Plastic Part Coatings
- Motor Vehicle Materials
Deficiency 5:
Section 300, Standards, Table 336-1 contains VOC limits for the category “Other Metal
Parts and Products: Includes Non-Adhesive Coating, Adhesive, Adhesive Primer, Beaded
Sealant, and Caulking” which does not comply with the 2008 CTG, “EPA-453/R-08-003,
Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (MMPP)
September 2008. Because the limits for General One Component and General Multi

Component Coatings are lower in the CTG, the limits in Rule 336 do not meet the
presumptive RACT standard established in the CTG. The County must either lower the
VOC limits in this category, or provide an analysis demonstrating that its limits represent
RACT.
Remedy 5:
The MCAQD is proposing to remove adhesives and adhesive primers from the "Other
Metal Parts and Products" coating category in Table 336-1 (VOC Limits for Miscellaneous
Metal Part and Product Coatings). The MCAQD is also proposing to lower the VOC limit
for the "Other Metal Parts and Products" coating category to 340 grams VOC per liter (g/L)
for air dried coatings and 280 g/L for baked coatings.
Deficiency 6:
Section 300, Standards Table 336-3 contains VOC limits for “Flexible Plastic Parts and
Products” as well as “Plastic Parts and Products That Are Not Defined as Flexible.” These
categories are not in the 2008 MMPP CTG and contain higher VOC limits than some of the
existing categories in the CTG. The County must remove these VOC categories from the
rule or demonstrate why the “Flexible Plastic Parts and Products” and “Plastic Parts and
Products That Are Not Defined as Flexible” VOC limits meet current RACT.
Remedy 6:
The MCAQD is proposing to remove the following coating categories from Table 336-3
(VOC Limits for Miscellaneous Plastic Part and Product Coatings):
• Flexible Plastic Parts and Products (Basecoat, Clearcoat, Color Topcoat, and Primer);
and
• Plastic Parts and Products that are not Defined as Flexible.
Deficiency 7:
The County submitted a negative declaration for the industrial adhesive category, which is
covered by a CTG. However, a facility under the County’s jurisdiction and in the Phoenix-
Mesa ozone nonattainment area is using an adhesive covered by the CTG. Therefore, the
CTG must be fully addressed in Rule 336.
Remedy 7:
The MCAQD is proposing to incorporate administrative mechanisms and emission limits
that are consistent with RACT emissions limits established in the CTG for Miscellaneous
Industrial Adhesives and incorporated in other nonattainment areas.
In addition to remedying these 7 EPA identified deficiencies, the MCAQD is also proposing
revisions to address the 12 EPA rule recommendations as described below:
Recommendation 1:
Table 336-2 limits Coil Coatings to 310 g/L. Please consider reducing this limit to 200 g/L
consistent with other SIP rules. See Bay Area AQMD Regulation 8, Rule 11 and South Coast
AQMD Rule 1125. Alternatively, consider deleting this category since Maricopa County' s
RACT SIP contains a negative declaration for Coil Coatings.
Revision 1:
The MCAQD is proposing to revise Table 336-2 to lower the VOC limits for coil coatings
to 200 g/L (1.7 lb/gal).

Recommendation 2:
Section 204 Air-Dried Coatings (dried by the use of air or forced warm air at temperatures
up to and including 200°F (93.3°C) differs from the MMPP CTG's Appendix H definition
of Air-Dried Coating which states the coating is cured at a temperature below 194°F (90°C).
Please revise the definition to be consistent with the CTG definition.
Revision 2:
The MCAQD is proposing to revise the definition of Air-Dried Coatings to reflect a curing
temperature of below 194°F (90°C).
Recommendation 3:
Section 207 Baked Coatings (dried or cured in an oven in which the oven temperature
exceeds 200°F (93.3°C) differs from the MMPP CTG's Appendix H definition of Baked
Coating which states the coating is cured at a temperature at or above 194°F (90°C). Please
revise the definition to be consistent with the CTG definition.
Revision 3:
The MCAQD is proposing to revise the definition of Baked Coatings to reflect a curing
temperature at or above 194°F (90°C).
Recommendation 4:
Section 227 Extreme High-Gloss Coating contains a typographical error. Please correct the
reference to test method ASTDM D-523 by removing "D" to ASTM D523. Also, the 1999
version (D523-89 (1999)) has been approved for use so please consider revising the rule to
include the 1999 version.
Revision 4:
The MCAQD is proposing to revise the definition of Extreme High-Gloss Coating to
correct the typographical error and updating the ASTM reference to reflect the most recent
version from 1999.
Recommendation 5:
Section 228 Extreme Performance Coatings - consider expanding the definition to follow
the MMPP CTG Appendix H recommended definition (e.g., chronic exposure to corrosive,
caustic or acidic agents, repeated heavy abrasion etc.).
Revision 5:
The MCAQD is proposing to revise the definition of Extreme Performance Coating to
reflect the CTG definition, including the addition of language on chronic exposure to
corrosive, caustic or acidic agents, and repeated exposure to high temperatures and heavy
abrasion.
Recommendation 6:
Section 501.2.b Recordkeeping Please do not delete the word “coating” in the following
sentence: "Shall have the written value of the VOC coating content in one of the following
forms."
Revision 6:
The MCAQD confirmed with the EPA that this recommendation was made in error. The
MCAQD and EPA determined that the correct language should be “VOC content” as
indicated in the attached draft rule.

Recommendation 7:
Section 503.1.a.(1), 503.1.a.(2) and 503.2.f Compliance Determination: Please update
BAAQMD Method 31 (April 15, 1992) to May 18, 2005. The May 18, 2005 version is
approved for use in SIP rules.
Revision 7:
MCAQD is proposing to delete BAAQMD Method 31 because compliance with this rule is
based on VOC Regulatory (excluding water and exempt compounds) and BAAQMD
Method 31 does not exclude water and may or may not exclude exempt chlorinated
compounds. Therefore, this method is not appropriate for Rule 336. MCAQD is proposing
to replace any references to BAAQMD Method 31 in Rule 336 with other, more appropriate
test methods, such as EPA Method 24 in Section 503.1.a.(1), SCAQMD Method 313-91 in
Section 503.1.a.(2), and SCAQMD Method 304-91 in Section 503.2.f.
Recommendation 8:
Section 503.1.a.(2)(b) states for multi-component, polymerizing coatings, Method 24 shall be
modified to eliminate the post-mixing dilution-step. We recommend deleting the language to
modify EPA Method 24. Method 24 section 11.2 now provides instructions for multi-
component coatings. Method 24 shall be used along with ASTM D2369-10(2015)e1 for
multi-component, polymerizing coatings.
Revision 8:
The MCAQD is proposing to delete the language to modify EPA Method 24.
Recommendation 9:
Section 503.1.b refers to EPA Method 25 and its submethod. The appropriate methods
should be listed since some submethods such as Method 25C, Landfill Gases, are not
appropriate for coatings. See 503.3.a which also needs correcting. Alternatively, consider
changing the "and" to "or" and adding "as appropriate." (e.g., EPA Method 25 or its
submethods as appropriate.). Section 503.2, incorporation by reference is correct as written
and does not need to be changed.
Revision 9:
The MCAQD is proposing to include reference to the specific EPA submethods which are
applicable to this rule (submethods 25a and 25b) in all sections that refer to EPA Method 25.
Recommendation 10:
503.1.c Capture efficiency. Please modify to include the guidance document for capture
efficiency: e.g., The capture efficiency of an emission collection control system shall be
determined according to EPA's "Guidelines for Determining Capture Efficiency," January 9,
1995 and 40 CFR 51, Appendix M, Methods 204-204F, as applicable. See also 503.3.b. The
listed methods: EPA Methods 2, 2a, 2c, and 2d. Please change the "and" to "or". Ideally, the
rule should include an equation for capture and control efficiency. E.g., San Joaquin Rule
4604 Can and Coil Coating Operations Section 6.7.2.3.
Revision 10:
The MCAQD is proposing to revise this section to expand and clarify the methods to
determine capture efficiency by referencing EPA Methods 204-204f, EPA’s “Guidelines for
Determining Capture Efficiency”, and an option to use an equation based on mass balance
in combination with ventilation/draft rate determinations based on EPA Methods 2, 2a, 2c,
or 2d.

Recommendation 11:
503.2.b EPA Method 18. Please delete "and its submethods." Method 18 has no
submethods. See also 503.3.a.
Revision 11:
The MCAQD is proposing to remove “and its submethods” where Method 18 is referenced.
Recommendation 12:
503.3.c The listed methods: EPA Methods 2, 2a, 2c, and 2d. The "and" should be "or".
Revision 12:
The MCAQD is proposing to remove Section 503.3c but will replace “and” with “or” when
referencing these methods in Section 503.1c.
On May 1, 2020, after the EPA had published the proposed conditional approval of Rule
336 in the Federal Register, the EPA advised MCAQD to revise the VOC limits for three
pleasure craft coating categories (“antifoulant coating- non-aluminum substrate,” “extreme
high gloss topcoat,” and “finisher primer/surfacer”) to match the ones listed in the 2008
Miscellaneous Metal and Plastic Parts Coating CTG. During the 2016 rulemaking for Rule
336, those three coating categories were not matched to CTG due to stakeholder concerns.
At that time, the MCAQD reviewed the concerns and determined that higher VOC limits
for the three coatings constituted RACT for VOC operations in the Phoenix ozone
nonattainment area. The EPA recently determined the CTG limits to be RACT since there
are now coatings available that meet the CTG limits. The MCAQD is proposing to revise
the VOC limits for these three coating categories to match the CTG, as follows:
Table 336-7 336-6: Coating VOC Limits for Pleasure Craft Coatings
Coating Category g VOC/l lbs VOC/gal
Other Substrate Antifoulant Coating – Non-Aluminum Substrate 400 330 3.4 2.8
Extreme High Gloss Topcoat 600 490 5.2 4.1
Finish Primer/Surfacer 600 420 5.2 3.5
In addition, the MCAQD is proposing to revise the definition for Extreme High-Gloss
Coating to better differentiate the difference between those used for general coating
purposes (which have a reflectance of 75% or more) with those used for pleasure craft
coating purposes (which have a reflectance of 95% or more). The MCAQD is proposing to
update the definition for clarity, as follows:
EXTREME HIGH-GLOSS COATING: A coating when tested by the ASTDM D-
523 adopted in 1980 that shows reflectance of 75 or more (95 or more for pleasure
craft topcoats) on a 60° meter as determined by ASTM D523 (1999).
Additional revisions were made to address stakeholder and staff comments, which can be
discerned in the “strikeout and underline” version of the rule included in this notice and
described in all Stakeholder Workshop notices and workshop slides/presentations that are
posted on the EROP website.
5. Studies relied on in the control officer's evaluation of or justification for the rule and
where the public may obtain or review the studies, all data underlying the studies,
any analysis of the studies and other supporting material.

U.S. Environmental Protection Agency Region IX Air Division (2019). TechnicalSupport
Document for EPA’s Rulemaking for the Arizona State Implementation Plan Regarding
Rule 336, “Surface Coating Operations”,
https://www.regulations.gov/document?D=EPA-R09-OAR-2019-0423-0004
U.S. Environmental Protection Agency, “Control of Volatile Organic Emissions from
Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper,
Fabrics, Automobiles, and Light-Duty Trucks,” May, 1977,
https://www3.epa.gov/airquality/ctg_act/197705_voc_epa450_2-77-
008_surface_coatings(v2).pdf
U.S. Environmental Protection Agency, “Control of Volatile Organic Emissions from
Existing Stationary Sources – Volume V: Surface Coating of Large Appliances,”
December, 1977,
https://www3.epa.gov/airquality/ctg_act/197712_voc_epa450_2-77-
034_surface_coatings(v5).pdf.
U.S. Environmental Protection Agency, “Control of Volatile Organic Emissions from
Existing Stationary Sources – Volume III: Surface Coating of Metal Furniture,”
December, 1977,
https://www3.epa.gov/airquality/ctg_act/197712_voc_epa450_2-77-
032_surface_coatings(v3).pdf.
U.S. Environmental Protection Agency, “Control of Volatile Organic Emissions from
Existing Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts
and Products,” June, 1978,
https://www3.epa.gov/airquality/ctg_act/197806_voc_epa450_2-78-
015_surface_coatings(v6).pdf.
U.S. Environmental Protection Agency, “Alternative Control Techniques Document –
Surface Coating of Automotive/Transportation and Business Machine Plastic Parts,”
February, 1994, https://www3.epa.gov/airquality/ctg_act/199402_voc_epa453_r-
94-017_Coating_Automotive_Plastic_Part.pdf.
U.S. Environmental Protection Agency, “Control Techniques Guidelines for Industrial
Cleaning Solvents,” September, 2006,
https://www3.epa.gov/airquality/ctg_act/200609_voc_epa453_r-06-
001_ind_cleaning_solvents.pdf.
U.S. Environmental Protection Agency, “Control Techniques Guidelines for Paper, Film
and Foil Coatings,” September, 2007,
https://www3.epa.gov/airquality/ctg_act/200709_voc_epa453_r-07-
003_paper_film_coating.pdf.
U.S. Environmental Protection Agency, “Control Techniques Guidelines for Large
Appliance Coatings,” September, 2007,
https://www3.epa.gov/airquality/ctg_act/200709_voc_epa453_r-07-
004_lg_appliance_coating.pdf.
U.S. Environmental Protection Agency, “Control Techniques Guidelines for Miscellaneous
Metal and Plastic Parts Coatings,” September, 2008,
https://www3.epa.gov/airquality/ctg_act/200809_voc_epa453_r-08-
003_misc_metal_plasticparts_coating.pdf.

U.S. Environmental Protection Agency, “Control Techniques Guidelines for Miscellaneous
Industrial Adhesives,” September, 2008,
https://www3.epa.gov/airquality/ctg_act/200809_voc_epa453_r-08-
005_miscellaneous_industrial_adhesives.pdf.
6. An economic, small business and consumer impact statement:
The following discussion addresses each of the elements required for an economic, small
business and consumer impact statement, as prescribed by A.R.S. §§ 41-1055, subsections A,
B and C, and 41-1035:
An identification of the proposed rulemaking, including all of the following:
This rulemaking is proposing to revise Rule 336.
(a) The conduct and its frequency of occurrence that the rule is designed to change.
The MCAQD is proposing to revise Rule 336 to remedy deficiencies identified by the
EPA. This rulemaking is required to secure approval of Rule 336 into the Arizona SIP.
The revisions are explained in more detail in Item #4 of this notice.
(b) The harm resulting from the conduct the rule is designed to change and the
likelihood it will continue to occur if the rule is not changed.
The MCAQD is proposing to revise Rule 336 to remedy deficiencies identified by the
EPA. This rulemaking is required to secure approval of Rule 336 into the Arizona SIP
and avoid sanctions and imposition of a Federal Implementation Plan (FIP) under the
Clean Air Act.
(c) The estimated change in frequency of the targeted conduct expected from the
rule change.
The MCAQD is proposing to revise Rule 336 to remedy deficiencies identified by the
EPA. This rulemaking is required to secure approval of Rule 336 into the Arizona SIP.
As with other rules, the MCAQD will use education, outreach, and other compliance
assurance tools to increase the number of people in compliance with the revised rule.
The MCAQD strives to achieve the highest possible compliance rates.
A brief summary of the information included in the economic, small business and
consumer impact statement.
The economic, small business and consumer impact statement addresses each of the
elements required for an economic, small business and consumer impact statement, as
prescribed by A.R.S. §§ 41-1055, subsections A, B and C, and 41-1035.
Name and address of agency employees who may be contacted to submit or request
additional data on the information included in the economic, small business and
consumer impact statement.
Name: Laura Jardieanu or Kimberly Butler
Maricopa County Air Quality Department
Planning and Analysis Division
Address: 3800 N Central Avenue, Suite 1400
Phoenix, AZ 85012

Telephone: 602-506-6010
Fax: 602-506-6179
Email: AQPlanning@maricopa.gov
Submit Comments At: http://maricopa.gov/FormCenter/Regulatory-Outreach-
17/Citizen-Comments-94
An identification of the persons who will be directly affected by, bear the costs of or
directly benefit from the proposed rulemaking.
This rulemaking will directly affect facilities in Maricopa County that use VOC-containing
coatings and industrial adhesives listed in Tables 336-1 through 336-7 of the draft rule
included in this notice that are not more specifically regulated by another source-specific rule
within Maricopa County Rules 300 to 359 of Regulation III. Partial exemptions apply to
certain materials, coatings and application methods.
A cost benefit analysis of the following:
(a) The probable costs and benefits to the implementing agency and other agencies
directly affected by the implementation and enforcement of the proposed
rulemaking.
This rulemaking should not impose any new costs on the MCAQD or on any other
agencies affected by the proposed rulemaking.
(b) The probable costs and benefits to a political subdivision of this state directly
affected by the implementation and enforcement of the proposed rulemaking.
This rulemaking should not impose any new costs on political subdivisions of this state
affected by the proposed rulemaking.
(c) The probable costs and benefits to businesses directly affected by the proposed
rulemaking, including any anticipated effect on the revenues or payroll
expenditures of employers who are subject to the proposed rulemaking.
The MCAQD is proposing to revise Rule 336 to remedy deficiencies identified by the
EPA. This rulemaking is required to secure approval of Rule 336 into the Arizona SIP
for RACT and avoid sanctions and imposition of a FIP under the Clean Air Act.
Some businesses may need a permit or may need to revise their permit as a result of
proposed revisions to the applicability of the rule and to some of the VOC limits in the
rule. If a business needs a permit, the business will incur a permit application and
processing fee. If a business needs to revise their permit, the business will not incur a fee,
because the MCAQD will re-open their permit for cause.
For businesses using coatings or adhesives which fall under a category of coating or
adhesive where VOC limits are decreasing or are being established, compliance with the
revised Rule 336 may involve some additional costs related to purchasing Rule 336-
compliant coatings or adhesives. For businesses that are already using coatings or
adhesives materials which comply with these new limits, there would be no additional
costs.

A general description of the probable impact on private and public employment in
businesses, agencies and political subdivisions of this state directly affected by the
proposed rulemaking.
This rulemaking should have no impact on private or public employment in businesses,
agencies, and political subdivisions of this state.
A statement of the probable impact of the proposed rulemaking on small businesses.
The statement shall include:
(a) An identification of the small businesses subject to the proposed rulemaking.
Small businesses subject to this rulemaking are those facilities in Maricopa County that use
VOC-containing coatings and industrial adhesives listed in Tables 336-1 through 336-7 of
the draft rule included in this notice that are not more specifically regulated by another
source specific rule within Maricopa County Rules 300 to 359 of Regulation III.
(b) The administrative and other costs required for compliance with the proposed
rulemaking.
Some small businesses may need a permit or may need to revise their permit as a result
of proposed revisions to the applicability of the rule and to some of the VOC limits in
the rule. If a business needs a permit, the business will incur a permit application and
processing fee. If a business needs to revise their permit, the business will not incur a fee,
because the MCAQD will re-open their permit for cause.
For small businesses using coatings or adhesives which fall under a category of coating
or adhesive where VOC limits are decreasing or are being established, compliance with
the revised Rule 336 may involve some additional costs related to purchasing Rule 336-
compliant coatings or adhesives. For small businesses that are already using coatings or
adhesives materials which comply with these new limits, there would be no additional
costs.
(c) A description of the methods that the agency may use to reduce the impact on
small businesses.
i. Establish less stringent compliance or reporting requirements in the rule for
small businesses.
This rulemaking does not impose any significant new compliance requirements on
small businesses and does not establish any significant new reporting requirements
for small businesses.
ii. Establish less stringent schedules or deadlines in the rule for compliance or
reporting requirements for small businesses.
This rulemaking does not impose any significant new compliance requirements on
small businesses and does not establish any significant new reporting requirements
for small businesses.
iii. Consolidate or simplify the rule's compliance or reporting requirements for
small businesses.

This rulemaking does not impose any significant new compliance requirements on
small businesses and does not establish any significant new reporting requirements
for small businesses.
iv. Establish performance standards for small businesses to replace design or
operational standards in the rule.
This rulemaking is unlikely to impose any new design or operational requirements on
small businesses. Any design or operational changes that would result from this
rulemaking would be minimal, such as complying with operational requirements for
industrial adhesives in addition to those already required for surface coatings.
v. Exempt small businesses from any or all requirements of the rule.
This rulemaking contains some partial and full exemptions as outlined in Sections
103 and 104 of the draft rule.
(d) The probable cost and benefit to private persons and consumers who are directly
affected by the proposed rulemaking.
This rulemaking should not result in any significant costs for private persons and
consumers.
A statement of the probable effect on state revenues.
The rulemaking will not impose increased monetary or regulatory costs on other state
agencies, political subdivisions of this state, persons, or individuals so regulated. Without
costs to pass through to customers, there is no projected change in consumer purchase
patterns and, thus, no impact on state revenues from sales taxes.
A description of any less intrusive or less costly alternative methods of achieving the
purpose of the proposed rulemaking, including the monetizing of the costs and
benefits for each option and providing the rationale for not using nonselected
alternatives.
The purpose of this rulemaking is to revise Rule 336 to remedy deficiencies identified by the
EPA. This rulemaking is required to secure approval of Rule 336 into the State
Implementation Plan (SIP) for RACT and avoid sanctions and imposition of a Federal
Implementation Plan (FIP) under the Clean Air Act.
A description of any data on which a rule is based with a detailed explanation of how
the data was obtained and why the data is acceptable data.
Not applicable.
7. The proposed effective date of the rule:
The proposed effective date of this rulemaking is September 1, 2021.
8. Such other matters as are prescribed by statute and that are applicable to the county
or to any specific rule or class of rules:
Under A.R.S. § 49-479(C), a county may not adopt a rule or ordinance that is more stringent
than the rules adopted by the Director of the Arizona Department of Environmental Quality
(ADEQ) for similar sources unless it demonstrates compliance with the applicable
requirements of A.R.S. §49-112.

§ 49-112 County regulation; standards
§ 49-112(A)
When authorized by law, a county may adopt a rule, ordinance or regulation that is more
stringent than or in addition to a provision of this title or rule adopted by the director or any
board or commission authorized to adopt rules pursuant to this title if all of the following
requirements are met:
1. The rule, ordinance or regulation is necessary to address a peculiar local condition.
2. There is credible evidence that the rule, ordinance or regulation is either;
(a) Necessary to prevent a significant threat to public health or the environment that
results from a peculiar local condition and is technically and economically feasible.
(b) Required under a federal statute or regulation, or authorized pursuant to an
intergovernmental agreement with the federal government to enforce federal statutes
or regulations if the county rule, ordinance or regulation is equivalent to federal
statutes or regulation.
3. Any fee or tax adopted under the rule, ordinance or regulation does not exceed the
reasonable costs of the county to issue and administer the permit or plan approval
program.
§ 49-112(B)
When authorized by law, a county may adopt rules, ordinances or regulations in lieu of a
state program that are as stringent as a provision of this title or rule adopted by the director
or any board or commission authorized to adopt rules pursuant to this title if the county
demonstrates that the cost of obtaining permits or other approvals from the county will
approximately equal or be less than the fee or cost of obtaining similar permits or approvals
under this title or any rule adopted pursuant to this title. If the state has not adopted a fee or
tax for similar permits or approvals, the county may adopt a fee when authorized by law in
the rule, ordinance or regulation that does not exceed the reasonable costs of the county to
issue and administer that permit or plan approval program.
The MCAQD is in compliance with A.R.S. §§ 49-112(A) and (B). Rule 336 meets A.R.S. §
49-112(A)(1) by demonstrating that the rule is necessary to address a peculiar local condition,
in that Maricopa County fails to meet the 8-hour NAAQS for ozone. Rule 336 meets the
requirements of A.R.S.§ 49-112(A)(2)(b), in that Maricopa County is required by federal law
to revise existing rules to address RACT for the Surface Coating industry. As there is no new
fee or tax associated with this proposed rulemaking, the MCAQD also affirms that Rule 336
meets the requirements of A.R.S. § 49-112 (A)(3) and A.R.S § 49-112 (B).
9. List of all previous notices posted to the Maricopa County EROP website addressing
the proposed rule and a concise explanatory statement, as prescribed by A.R.S. § 49-
471.07, subsection B:
(a) List of all previous notices posted to the Maricopa County EROP website
addressing the proposed rule:
Notice Date of Posting
Briefing Notification to County Manager: January 26, 2018

Notice of Stakeholder Workshops: February 21, 2018
August 3, 2018
October 9, 2019
June 29, 2020
Notice of Board of Health Meeting to Approve
Expidited Rulemaking: April 6, 2018
Notice of Proposed Rulemaking: January 27, 2021
Notice of Board of Health Meeting to Make
Recommendations to the Board of Supervisors: April 12, 2021
(b) The following discussion addresses each of the elements required for a concise
explanatory statement, as prescribed by A.R.S. § 49-471.07, subsection B:
i. A description of any change between the proposed rule, the final rule or
notice of final supplemental rule.
The following changes to Rule 336 were made after the Notice of Proposed
Rulemaking was published on January 27, 2021:
1. The draft language in Rule 336 was revised to clarify that the application of all
industrial adhesives and industrial adhesive primers must comply with the
provisions in Section 302.1 and that alternative methods for all applications of
industrial adhesives and industrial adhesive primers must comply with Section
302.2b.
ii. A summary of the comments and arguments for and against the notice and
the county’s response to the comments and arguments. Return to list of attachments
The following discussion evaluates the arguments for and against the rule and
includes responses to comments received on the proposed rule or the preamble in
the Notice of Proposed Rulemaking. The MCAQD received written feedback from
three stakeholders. One stakeholder expressed support and two stakeholders
expressed “other” to the proposed changes and also provided written comments.
Comment #1:
[Our organization] submits the following comments on MCAQD’s proposed
amendments to Rule 336 (Surface Coating Operations). [Our organization] is a
voluntary, nonprofit trade association working to advance the needs of the paint and
coatings industry and the professionals who work in it. Notably, [our organization]
represents a variety of marine coatings manufacturers and active ingredient suppliers
who sell pleasure craft coating products in Maricopa County, Arizona. Above all,
[our organization] and its member companies are committed to safeguarding the
environment by providing only top-quality marine coatings to recreational vessel
owners.
Since 2010, [our organization] has worked diligently with MCAQD, the U.S.
Environmental Protection Agency (EPA), and other industry stakeholders to come
up with a solution on how the county should move forward with handling the VOC
limits for the three pleasure craft coating categories. [Our organization] agrees that

MCAQD should lower the following pleasure craft coating VOC limits to comply
with the limits in EPA’s CTG:
• Extreme High Gloss Topcoat: 490 g VOC/l or 4.1 lbs VOC/gal
• Finish Primer/Surfacer: 420 g VOC/l or 3.5 lbs VOC/gal
However, we urge MCAQD to consider retaining the VOC limit for the following
pleasure craft coating category:
• Antifoulant Coating – Non-Aluminum Substrate: 400 g VOC/l or 3.4 lbs VOC/gal
[Our organization] members require a reasonable amount of lead time to adjust
formulations and supply chain processes in order to ensure compliance with
amended VOC limits, labeling, and reporting requirements. [Our organization]
believes that industry needs additional time to comply with the proposed lowered
limit for Antifoulant Coating – Non-Aluminum Substrate. Furthermore, at the
proposed EPA CTG level (330 g VOC/l), consumers will not have a wide range of
options for these types of products and the market will be limited. It takes many
years to develop, test, and register a new antifouling coating. A limit of 400 g/L will
ensure that industry can provide a full range of products for differing water types,
application temperatures, and fouling conditions.
In addition, our member believes that the limit for All Other Pleasure Craft Coatings
for Metal or Plastic category should be increased to 490 g VOC/l or 4.1 lbs
VOC/gal to align with the Extreme High Gloss Topcoat category. These types of
coatings are applied to small parts of pleasure crafts and would benefit from a higher
VOC limit to be efficient.
[Our organization] looks forward to working with MCAQD and other interested
stakeholders on Rule 336 and hopes that MCAQD will eventually make an informed
decision that is in the best interests of its residents.
Thank you for your consideration of our concerns and please let us know if you have
any questions.
Response #1:
Thank you for providing comments on the draft revisions to Rule 336. Below is a
response to each concern provided in your comments.
The MCAQD has evaluated your comment about retaining the current pleasure craft
coating limit of 400 g VOC/l for Antifoulant Coating (Non-Aluminum Substrate)
and has determined this VOC limit cannot be retained. Rule 336 is currently being
amended to ensure the rule meets the reasonably available control technology
(RACT) requirements of section 182(b) of the Clean Air Act for ozone
nonattainment areas classified as Moderate. The MCAQD has determined the 330 g
VOC/l emission limit proposed for Antifoulant Coating (Non-Aluminum Substate)
in the current draft rule meets RACT. This emission limit is consistent with limits in
EPA’s Control Techniques Guidelines (CTG) for Miscellaneous Metal and Plastic
Parts Coatings and emission limits in the CTGs are generally understood to be
equivalent to RACT emission limits. In addition, the 330 g VOC/l emission limit
matches emission limits in several current RACT-approved rules within EPA Region
9. The MCAQD must ensure Rule 336 meets RACT requirements so the rule can be

approved into the Arizona State Implementation Plan (SIP). Failing to lower the
current limit for Antifoulant Coating (Non-Aluminum Substrate) could jeopardize
this approval and could ultimately lead to federal highway and offset sanctions for
Maricopa County further down the road. Finally, the EPA recommended the
MCAQD lower this limit last year (2020) and we are moving forward with this lower
limit in order to comply with their recommendation.
The MCAQD expects these lower emission limits will be incorporated into the rule
sometime in August of this year (2021) so there is time for industry to come into
compliance by using up coatings that will not comply with the proposed new limits
and slowly beginning to purchase new coatings that will comply with the new limits.
The MCAQD has evaluated your comment about increasing the VOC limit of 420 g
VOC/l for All Other Pleasure Craft Surface Coatings for Metal or Plastic to 490 g
VOC/l and has determined this limit cannot be increased. This limit is consistent
with the limits in the EPA CTG for Miscellaneous Metal and Plastic Parts Coatings.
As mentioned above, Rule 336 is currently being amended to ensure the rule meets
RACT requirements and emission limits in the CTGs are generally understood to be
equivalent to RACT emission limits. In addition, the EPA published the final
conditional approval of the 2016 version of Rule 336 on January 7, 2021 so it is now
part of the Arizona SIP. Once a rule is approved as part of the SIP it is very difficult
to relax any requirement in a rule as it may be viewed as backsliding. Backsliding may
jeopardize approval of the rule which may lead, as mentioned earlier, to federal
highway and offset sanctions for Maricopa County further down the road.
Also, the MCAQD has reviewed all violations of Rule 336 issued through our
Compliance division since the 420 g VOC/l limit was adopted in 2016 and has not
found any enforcement issues for this particular coating category in Maricopa
County. Our Business Assistance Office is available to assist the regulated
community with any compliance-related concerns by offering education, training,
and courtesy site visits as needed.
Comment #2:
Our materials are typically well below 50 grams/liter in VOC content which is
minimal compared to the proposed limits. We respectfully request that
UV/EB/LED materials be exempted from the rule requirements. An exemption
would be an incentive for businesses to voluntarily choose UV/EB/LED technology
resulting in additional emission reductions for Maricopa County.
Recordkeeping requirements are burdensome on businesses and in the case of
UV/EB/LED operations, are not crucial because the materials are well below the
rule limits. Exempting energy curable materials from overly prescriptive
recordkeeping requirements will alleviate regulatory burdens on the Maricopa
County business community and benefit air quality.
Response #2:
Rule 336 currently includes an exemption for coating products that have a VOC
content, minus exempt compounds, of less than 0.15lb VOC/gal (18g/L), and this
exemption (found in Section 102.4 of the draft rule) will be retained with the current
rulemaking. Also, there is no permitting requirement in Maricopa County for

facilities that emit any regulated air pollutant in an amount less than the permitting
thresholds listed in Rule 200, Section 303.1 (for VOCs, the permitting threshold is
0.5 tons per year). These exemptions are in place to encourage businesses to adopt
products and practices which limit impacts on air quality.
In addition, Rule 336 was conditionally approved as part of the Arizona State
Implementation Plan (SIP) earlier this year. Any relaxation of the provisions in the
rule may be considered backsliding, which may jeopardize the full approval of the
Rule 336 into the SIP and potentially lead to federal highway and offset sanctions for
Maricopa County further down the road.
Comment #3:
We would very much appreciate the inclusion of a definition for energy curable
materials in the rule. We propose a definition like the one in SCAQMD rules:
ENERGY CURABLE MATERIALS are single component reactive products that
cure upon exposure to visible-light, ultraviolet light, or to an electron beam.
Response #3:
Thank you for providing the MCAQD with a good working definition for energy
curable materials. However, a definition is not necessary since the MCAQD is not
including any additional provisions regarding these materials into this version of Rule
336.
Comment #4:
The Environmental Protection Agency and the SCAQMD have long recognized that
EPA Method 24 is not suitable for thin film UV/EB/LED Materials. Thus, [our
organization] urges Maricopa County to include ASTM D7767-11 as suitable test
method for UV/EB/LED products subject to Rule 336. We propose the following
language: The VOC content of thin film Energy Curable Adhesives and Sealants may
be determined by manufacturers using ASTM Test Method 7767 Standard Test
Method to Measure Volatiles from Radiation Curable Acrylate Monomers,
Oligomers, and Blends and Thin Coatings Made from Them.
Response #4:
Since ASTM D7767-11 is not currently an EPA-approved test method, the MCAQD
cannot include it in Rule 336. Adding a test method that is not EPA-approved to this
rule jeopardizes EPA’s approval of Rule 336 into the SIP. However, Section 503.2 of
the rule does allow for the use of alternative EPA-approved test methods. If ASTM
D7767-11 is approved by the EPA in the future, then it can be considered as a
suitable test method.
Comment #5:
UV/EB/LED products have higher viscosities than conventional solvent products.
The rationale behind transfer efficiency requirements is to control VOC emissions
that can take place during spraying operations. But, given the fact that UV/EB/LED
materials do not have emissions like conventional solvent processes, facilities should
not be required to the same level of regulation for transfer efficiency purposes. We
urge Maricopa County to exempt UV/EB/LED materials with viscosities of 650
centipoise or above, from the transfer efficiency requirements of the rule. UV/EB
materials not only meet, but far exceed any proposed rule requirements and any

added flexibility to companies that choose these pollution preventive processes will
encourage voluntary emission reductions thereby furthering the County’s mission.
Response #5:
The MCAQD conducted research on facilities within Maricopa County that are
currently using energy curable coating materials. We found these facilities are able to
comply with the application methods listed in Section 302. As such, there appears to
be no operational need to revise the transfer efficiency requirements of Rule 336.
Also, in order to exempt any new materials from the application methods listed in
Section 302, the MCAQD would have to submit a 110(l) demonstration to the EPA
showing such an exemption would not interfere with any applicable requirement
concerning attainment and reasonable further progress, or any other applicable
requirement of the Clean Air Act. It is not clear if the EPA would approve such a
demonstration and, if it was not approved, the added exemption could be seen as a
relaxation of the rule. As mentioned earlier, any relaxation of the provisions of the
rule could jeopardize the approval of Rule 336 into the Arizona SIP.
EXACT WORDING OF THE RULE Return to list of attachments
MARICOPA COUNTY
AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 336
SURFACE COATING OPERATIONS AND INDUSTRIAL ADHESIVE APPLICATION
PROCESSES
INDEX
SECTION 100 – GENERAL
101 PURPOSE
102 APPLICABILITY
103 PARTIAL EXEMPTIONS
104 TOTAL CATEGORICAL EXEMPTIONS
SECTION 200 – DEFINITIONS
201 200.1 ADHESIVE
202 ADHESION PRIMER
200.2 ADHESIVE PRIMER
203 200.3 AEROSOL CAN SPRAY COATING
204 200.4 AIR-DRIED AIR DRIED COATING
200 200.5 AIRLESS AND AIR-ASSISTED AIRLESS SPRAY
205 ALTERNATIVE APPLICATION METHODS

206 200.6 ANTIFOULANT COATING
200.7 APPLICATION EQUIPMENT
200.8 AS APPLIED
207 200.9 BAKED COATING
208 BUSINESS MACHINE
209 200.10 CAMOUFLAGE COATING
210 200.11 CAN COATING
211 200.12 CAN PRINTING INK
200.13 CERAMIC TILE INSTALLATION ADHESIVE
212 200.14 CLEAR COAT COATING
213 COATING APPLICATION EQUIPMENT
214 200.15 COIL COATING
200.16 CONTACT ADHESIVE
200.17 COVE BASE INSTALLATION ADHESIVE
200.18 CYANOACRYLATE ADHESIVE
215 200.19 DAY
216 200.20 DIP COATING
217 200.21 DRUM COATING
218 200.22 ELECTRIC DISSIPATING COATING
200.23 ELECTRIC-INSULATING AND THERMAL-CONDUCTING COATING
219 200.24 ELECTRIC INSULATING ELECTRIC-INSULATING VARNISH
220 200.25 ELECTROMAGNETIC INTERFERENCE (EMI)/RADIO-FREQUENCY
INTERFERENCE (RFI) SHIELDING
221 200.26 ELECTROSTATIC SYSTEM
222 200.27 EMISSION CONTROL SYSTEM (ECS)
223 200.28 END SEALING COMPOUND
224 200.29 ETCHING FILLER
225 200.30 EXEMPT COMPOUNDS
226 200.31 EXTERIOR CAN BASECOAT
227 200.32 EXTREME HIGH-GLOSS COATING
228 200.33 EXTREME-PERFORMANCE EXTREME PERFORMANCE COATING
229 200.34 FABRIC
230 200.35 FABRIC COATING

231 FILLER
232 200.36 FILM COATING
233 200.37 FINISH PRIMER/ SURFACER PRIMER/SURFACER
234 FLEXIBLE PLASTIC PART OR PRODUCT
200.38 FLEXIBLE VINYL
200.39 FLOOR COVERING INSTALLATION ADHESIVE (INDOOR)
200.40 FLOOR COVERING INSTALLATION ADHESIVE (OUTDOOR)
200.41 FLOOR COVERING INSTALLATION ADHESIVE (PERIMETER
BONDED SHEET VINYL)
235 200.42 FLOW COAT
236 FOG COAT
200.43 FOIL COATING
237 GLOSS REDUCER
238 200.44 HAND APPLICATION METHODS
239 200.45 HEAT-RESISTANT COATING
241 200.46 HIGH BUILD PRIMER/SURFACER
242 200.47 HIGH GLOSS COATING
240 200.48 HIGH PERFORMANCE ARCHITECTURAL COATING
243 200.49 HIGH TEMPERATURE COATING
244 200.50 HIGH-VOLUME, LOW PRESSURE (HVLP) SPRAY GUN
245 200.51 HIGHWAY VEHICLE
200.52 INDUSTRIAL ADHESIVE
200.53 INDUSTRIAL ADHESIVE PRIMER
246 200.54 INTERIOR BASECOAT
247 200.55 INTERIOR BODY SPRAY
248 200.56 IN USE OR HANDLED
249 200.57 LARGE APPLIANCE COATING
250 200.58 LOW PRESSURE SPRAY GUN
251 200.59 MARINE VESSEL
200.60 MASK COATING
252 200.61 METAL FURNITURE COATING
200.62 METAL TO URETHANE/RUBBER MOLDING OR CASTING ADHESIVE
253 200.63 METALLIC COATING

254 200.64 MILITARY SPECIFICATION COATING
200.65 MISCELLANEOUS METAL PART AND PRODUCT COATING
200.66 MISCELLANEOUS PLASTIC PART AND PRODUCT COATING
255 200.67 MOBILE EQUIPMENT
256 200.68 MOLD-SEAL COATING
200.69 MOTOR VEHICLE ADHESIVE
200.70 MOTOR VEHICLE GLASS BONDING PRIMER
200.71 MOTOR VEHICLE WEATHERSTRIP ADHESIVE
257 200.72 MULTI-COLORED COATING
258 200.73 MULTI-COMPONENT COATING
200.74 MULTIPURPOSE CONSTRUCTION ADHESIVE
259 200.75 ONE-COMPONENT COATING
260 200.76 OPTICAL COATING
261 OTHER METAL PARTS AND PRODUCTS
262 200.77 OVERVARNISH
263 200.78 PAN BACKING COATING
264 200.79 PAPER COATING
265 200.80 PLASTIC
200.81 PLASTIC SOLVENT WELDING ADHESIVE (ABS)
200.82 PLASTIC SOLVENT WELDING ADHESIVE (EXCEPT ABS)
200.83 PLASTIC SOLVENT WELDING ADHESIVE PRIMER
266 200.84 PLEASURE CRAFT
267 200.85 PLEASURE CRAFT COATING
200.86 POLYESTER BONDING PUTTIES
200.87 POROUS MATERIAL
268 200.88 PREFABRICATED ARCHITECTURAL COMPONENT COATING
269 200.89 PRESSURE SENSITIVE TAPE OR LABEL COATING
270 200.90 PRETREATMENT COATING
271 200.91 PRETREATMENT WASH PRIMER
200.92 PRIMARY BUSINESS ACTIVITY
272 200.93 PRIMER
273 200.94 QUALITY CLASS Q
274 REFRIGERATED GLASS DOOR COATING

275 200.95 REPAIR COATING
200.96 SAFETY-INDICATING COATING
200.97 SHEET APPLIED RUBBER LINING ADHESIVE
200.98 SHEET BASECOAT
276 200.99 SHOCK-FREE COATING
277 200.100 SILICONE RELEASE COATING
200.101 SINGLE-PLY ROOF MEMBRANE ADHESIVE PRIMER
200.102 SINGLE-PLY ROOF MEMBRANE INSTALLATION/REPAIR ADHESIVE
(EXCEPT EPDM)
278 SMALL SURFACE COATING SOURCE (SSCS)
279 200.103 SOLAR-ABSORBENT COATING
200.104 SOLID-FILM LUBRICANT
280 200.105 STENCIL COATING
281 200.106 STRIPPABLE BOOTH COATING
200.107 STRUCTURAL GLAZING
282 200.108 SURFACE COATING
283 200.109 SURFACE COATING OPERATION
284 200.110 TEXTURE COATING
200.111 THIN METAL LAMINATING ADHESIVE
200.112 THREE-PIECE CAN
285 200.113 THREE-PIECE CAN SIDE-SEAM COATING SPRAY
200.114 TIRE REPAIR
286 200.115 TOPCOAT
287 200.116 TOUCH-UP COATING
288 TRANSFER EFFICIENCY
200.117 TRANSLUCENT COATING
200.118 TWO-PIECE CAN
289 200.119 TWO-PIECE CAN EXTERIOR END COATING
290 200.120 VACUUM METALIZING COATING
291 200.121 VINYL COATING
292 200.122 VOC ACTUAL
293 200.123 VOC CONTENT
294 200.124 VOC REGULATORY

200.125 WATERPROOF RESORCINOL GLUE
SECTION 300 – STANDARDS
301 SURFACE COATINGS AND INDUSTRIAL ADHESIVES
302 APPLICATION METHODS FOR SURFACE COATINGS AND
INDUSTRIAL ADHESIVES
303 CLEANUP OF APPLICATION EQUIPMENT
304 WORK PRACTICES – HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL
305 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS
SECTION 400 – ADMINISTRATIVE REQUIREMENTS
401 COMPLIANCE SCHEDULE VOC LIMITS ECS INSTALLATION
402 COMPLIANCE SCHEDULE O&M PLAN FOR NEW VOC LIMITS
SECTION 500 – MONITORING AND RECORDS
501 RECORDKEEPING AND REPORTING
502 ECS RECORDING REQUIREMENTS
503 COMPLIANCE DETERMINATION AND TEST METHODS

Revised 07/13/1988; Revised 09/21/1992; Revised 06/19/1996; Revised 04/07/1999; Revised
09/25/2013; Revised 11/02/2016; Revised MM/DD/YYYY
MARICOPA COUNTY
AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 336
SURFACE COATING OPERATIONS AND INDUSTRIAL ADHESIVE APPLICATION
PROCESSES
SECTION 100 – GENERAL
101 PURPOSE: To limit the emission of volatile organic compounds (VOCs) from surface
coating operations and industrial adhesive application processes.
102 APPLICABILITY: This rule applies to VOC-containing coatings and industrial adhesives
listed in Tables 336-1 through 336-7 of this rule that are not more specifically regulated by
another source specific rule within Maricopa County Rules 300 to 359 of Regulation III, as
listed in Section 104 of this rule. Additionally:
102.1 Surface-coating activities regulated under this rule include, but are not limited to,
the application of coating, coating preparation/mixing at the facility applying the
coating, and the cleanup of coating application equipment.
102.2 Industrial adhesive application processes regulated under this rule include the
application of industrial adhesives and industrial adhesive primers, preparation and
mixing of industrial adhesives and industrial adhesive primers at the facility
applying the industrial adhesive or the industrial adhesive primer, and the cleanup
of application equipment.
102.2 102.3 Section 103 sets forth partial exemptions for certain materials or uses employed by
a surface coating operation or an industrial adhesive application process subject to
this rule.
102.3 102.4 This rule is not applicable to coatings, industrial adhesives, or industrial adhesive
primers having a VOC content, minus exempt compounds, of less than 0.15lb
VOC/gal (18g/L) nor to solvents having a VOC content of material less than
0.15lb VOC/gal.
102.4 102.5 In addition to this rule, facilities may be subject to New Source Performance
Standards (NSPS) in Rule 360 and/or to National Emission Standards for
Hazardous Air Pollutants (NESHAP) in Rule 370 of these rules.
103 PARTIAL EXEMPTIONS:
103.1 Qualified Materials Exemption:
a. Leak-Preventing Materials: Sealants, caulking, and similar materials, excluding
industrial adhesives, used on the following substrates for the primary purpose
of leak prevention are exempt from this rule:
(1) Non-metallic substrates; and

(2) Substrates made post manufacture, such as, but not limited to, old joints and
seals on pipe and valve assemblies.
b. Certain Joint Fillers: Caulking and beaded sealants used to fill gaps or to fill joints
between surfaces are exempt from this rule, except those used in manufacturing
other metal parts and products or in the manufacturing of cans, and excluding
industrial adhesives.
103.2 Extreme Performance Coatings Exemption: Extreme performance coatings are
exempt from the VOC limits in Tables 336-1 through 336-7 of this rule but not from
any other sections of this rule when used under the following conditions:
a. On internal combustion engine components that are normally above 250F
(121C) during use; or
b. At temperatures above 250F (121C) on items that are both included under
the North American Industry Classifications System (NAICS) codes 334210,
334220, 334290, 334416, 334417, 334418, 334419, 334310 or 336419 and are
electronic products in space vehicles and/or are communications equipment.
103.3 103.2 Plastic Parts Coating Exemption: The following types of plastic parts coatings
are exempt from the VOC limits in Tables 336-1 through 336-7 336-6 of this rule
but are subject to the remaining provisions of this rule.
a. Touch-up and repair coatings.
b. Stencil coatings applied on clear or transparent substrates.
c. Clear or translucent coatings.
d. Coatings applied at a paint manufacturing facility while conducting
performance tests on the coatings.
e. Non-compliant Low usage coatings: After a sufficient demonstration by the
owner or operator that no compliant substitute coating exists, an owner or
operator is Non-compliant coatings are permitted to use no more than for use
if the annual aggregate usage does not exceed 50 gal/yr. gallons per year of an
individual non-compliant coating, and not exceeding 200 gal/yr gallons per
year total usage of all such coatings provided such coatings are approved for
use in a Maricopa County Air Pollution Permit. The owner or operator shall
update usage records of these coatings at the end of each month, pursuant to
Section 501.2 of this rule.
f. Reflective coatings applied to highway cones.
g. Mask coatings that are less than 0.5 millimeter thick (dried) and the area coated
is less than 25 square inches.
h. Electromagnetic Interference (EMI)/ Radio-Frequency Interference (RFI)
shielding coatings.
i. Heparin-benzalkonium chloride (HBAC)-containing coatings applied to
medical devices, provided that the total usage of all such coatings does not
exceed 100 gal/yr gallons per year per facility.

j. Business machine plastic part coatings:
(1) Texture coatings.
(2) Vacuum metalizing coatings.
(3) Gloss reducers.
(4) Adhesion primers.
(5) Electrostatic preparation coatings.
(6) Resist coatings.
(7) Stencil coatings.
103.4 103.3 Application Methods Exemption: The following coatings are exempt from
application methods in Section 302 of this rule but are subject to the remaining
provisions of this rule:
a. Metal part texture coatings.
b. Metal part touch-up and repair coatings.
c. Plastic part coating for airbrush operations using less than 5 gal/yr gallons per
year of coating.
d. Extreme high gloss coatings for pleasure craft surface coating operations.
103.5 103.4 Surface Coating Application Methods and VOC-Limit VOC Limit Exemption:
The following surface coating operations are exempt from Sections 301, 302, and
305 of this rule but shall comply with Section 303, 304, and 500 of this rule.
a. Aerosol can spray coating.
b. Low Usage of VOC Coatings Which Exceed VOC Thresholds for Coating
Categories Listed in Tables 336-1 Through 336-7 of this Rule: Non-compliant
coatings Coatings that exceed the VOC limits in Tables 336-1 through 336-6 of
this rule are permitted for use if the annual aggregate usage of all such coatings
does not exceed 55 gallons per year (208 liters/yr. per year) at a facility. The
owner or operator shall update usage records of these coatings at the end of
each month, pursuant to Section 501.2 of this rule.
c. A Small Surface-Coating Source: A facility that has less than a 2 ton/year VOC
a VOC emission limit, not exceeding 2 tons/year in a Maricopa County Air
Pollution Permit for surface coating operations regulated by this rule, in a
Maricopa County Air Quality Permit.
d. A Quality Class Q protective coating that is used on equipment, structures,
and/or components within a containment facility of a nuclear power plant.
e. A tactical military-equipment coating that is approved in a Maricopa County
Air Pollution Permit subsequent to a sufficient demonstration by the user that
no compliant substitute exists.
f. e. Large Appliance Coating:
(1) Stencil coatings.

(2) Safety-indicating coatings.
(3) Solid-film lubricants.
(4) Electric-insulating and thermal-conducting coatings.
(5) Coating application utilizing aerosol can spray coating.
g. f. Metal Parts Coating:
(1) Stencil coatings.
(2) Safety-indicating coatings.
(3) Solid-film lubricants.
(4) Electric-insulating and thermal-conducting coatings.
(5) Magnetic data storage disk coatings.
(6) Plastic extruded onto metal parts to form a coating.
g. Powder coating.
103.5 Industrial Adhesive Application Methods and VOC Limit Exemption: The
following industrial adhesive and industrial adhesive primer application processes
are exempt from Sections 301, 302, and 305 of this rule but shall comply with
Section 303, 304, and 500 of this rule.
a. Adhesives or adhesive primers being tested or evaluated in any research and
development, quality assurance, or analytical laboratory.
b. Adhesives or adhesive primers used in the assembly, repair, or manufacture of
aerospace or undersea-based weapon systems.
c. Adhesives or adhesive primers used in medical equipment manufacturing
operations.
d. Cyanoacrylate adhesive application processes.
e. Adhesives and adhesive primers packaged as an aerosol product in which the
spray mechanism is permanently housed in a non-refillable can designed for
handheld application without the need for ancillary hoses or spray equipment.
f. Polyester bonding putties used to assemble fiberglass parts at fiberglass boat
manufacturing facilities and other reinforced plastic composite manufacturing
facilities.
g. Adhesives and adhesive primers that are supplied in containers with a net
volume of 16 ounces or less, or a net weight of one pound or less.
103.6 Industrial Adhesive Small Source Exemption: Only the provisions of Section
501 of this rule shall apply to industrial adhesive application processes, industrial
adhesive primer application processes, and related cleaning activities where the 12-
month rolling total VOC emissions from all such processes are less than or equal
to 3 tons before consideration of controls.
104 TOTAL CATEGORICAL EXEMPTIONS: This rule does not apply to the following
operations:

104.1 Aerospace coating operations (Rule 348). Coatings, adhesives, and adhesive primers
listed in Tables 336-1 through 336-7 of this rule that are more specifically regulated
by another source specific rule within Maricopa County Rules 300 to 359 of
Regulation III, as listed below:
a. Aerospace coating operations (Rule 348).
104.2 b. Architectural coatings including buildings and erected structures (Rule 335).
104.3 c. Solvent cleaning or stripping a surface for coating or other purpose (Rule 331).
104.4 Marine vessel exterior refinishing (EPA 453/B-97-001).
104.5 d. Printing and graphic arts coating (Rule 337).
104.6 e. Semiconductor manufacturing (Rule 338).
104.7 f. Coating or refinishing a highway vehicle or mobile equipment Refinishing
assembled motor vehicles and/or motor equipment (Rule 345).
104.8 g. Coating wood furniture and fixtures (Rule 342).
104.9 h. Coating wood millwork (Rule 346).
104.2 Marine vessel exterior refinishing (EPA 453/B-97-001).
104.3 Adhesives and adhesive primers that are used for any of the following purposes:
a. Janitorial services and consumer use of janitorial products.
b. Maintenance and upkeep activities (e.g., building maintenance, general repairs,
welding, plumbing, and re-tarring roofs) provided these activities are not
conducted as part of a manufacturing process and are not related to the
source’s primary business activity.
c. Repair or maintenance shop activities not related to the source’s primary
business activity.
d. Field applied adhesives (e.g. plastic solvent welding cements used by plumbers to
join plumbing pipes on construction or repair jobs in the field, or adhesives that
are used to attach flooring materials during a construction or renovation project).
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions shall
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of
these rules. In the event of any inconsistency between any of the Maricopa County air pollution
control rules, the definitions in this rule take precedence.
201 200.1 ADHESIVE: A material used for the primary purpose of bonding two or more
surfaces together.
202 ADHESION PRIMER: A coating that is applied to a plastic polymer part to mote
the adhesion of a subsequent coating.
200.2 ADHESIVE PRIMER: Any product intended by the manufacturer to be applied
to a substrate, prior to the application of an adhesive, to enhance the bonding surface.
203 200.3 AEROSOL CAN SPRAY COATING: A coating sold in a hand-held,
pressurized, non-refillable container, of less than 22 fluid ounces (0.66 liter)

capacity, and that is expelled from the container in a finely divided form when a
valve on the container is depressed.
204 200.4 AIR-DRIED AIR DRIED COATING: A coating dried by the use of air or forced
warm air at temperatures up to and including 200°F (93.3°C) below 194°F (90°C).
200.5 AIRLESS AND AIR-ASSISTED AIRLESS SPRAY: Any paint spray
technology that relies solely on the fluid pressure of the paint to create an atomized
paint spray pattern and does not apply any atomizing compressed air to the paint
before it leaves the paint nozzle. Air-assisted airless spray uses compressed air to
shape and distribute the fan of atomized paint, but still uses fluid pressure to create
the atomized paint.
205 ALTERNATIVE APPLICATION METHODS: Any method approved by the
Administrator as HVLP-equivalent.
206 200.6 ANTIFOULANT COATING: A coating applied to the underwater portion of a
pleasure craft to prevent or reduce the attachment of biological organisms, and
registered with the United States Environmental Protection Agency (EPA) as a
pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (7 United
States Code Section 136).
200.7 APPLICATION EQUIPMENT: Any equipment including, but not limited to,
spray guns, wands, rollers, and brushes used to apply or cover a surface with a
coating, an industrial adhesive, or an industrial adhesive primer, for either aesthetic,
protective, adhesive, or other purpose.
207 200.8 AS APPLIED: The formulation of a coating immediately prior to its application
after the addition of all thinner, reducer, and other additives.
207 200.9 BAKED COATING: A coating that is dried or cured in an oven in which the oven
at a temperature exceeds 200°F (93.3°C) at or above 194°F (90°C).
208 BUSINESS MACHINE: A device that uses electronic or mechanical methods to
process information, perform calculations, print or copy information, or convert
sound into electrical impulses for transmission, such as:
208.1 Products classified as typewriters under SIC Code 3572;
208.2 Products classified as electronic computing devices under SIC Code 3573;
208.3 Products classified as calculating and accounting machines under SIC Code 3574;
208.4 Products classified as telephone and telegraph equipment under SIC Code 3661;
208.5 Products classified as office machines, not elsewhere classified, under SIC Code
3579; and (6) photocopy machines, a subcategory of products classified as
photographic equipment under SIC Code 3861.
209 200.10 CAMOUFLAGE COATING: A coating used, principally by the military, to conceal
equipment from detection.
210 200.11 CAN COATING: A coating either used in the production of metal cans applied to
the surface(s) of formed cans or a coating applied at a can making facility to the
surface(s) of flat metal sheets or strips that are formed there into cans at the location
where the coating is applied.

211 200.12 CAN PRINTING INK: A fluid or viscous formulation used in can printing that
imparts design, pattern, and/or alphanumeric symbols to a can.
200.13 CERAMIC TILE INSTALLATION ADHESIVE: An adhesive intended by
the manufacturer for use in the installation of ceramic tiles.
212 CLEAR COAT: A coating that lacks color or opacity or is transparent.
200.14 CLEAR COATING: A colorless coating which contains binders, but no pigment,
and is formulated to form a transparent film.
213 COATING APPLICATION EQUIPMENT: Any equipment including, but not
limited to, spray guns, wands, rollers, brushes used to apply or cover a surface with a
coating for either aesthetic, protection or other purpose.
214 200.15 COIL COATING: A coating applied to the surface(s) of flat metal sheets or strips
that is are formed into rolls or coils not used to make cans.
200.16 CONTACT ADHESIVE: An adhesive that is designed for application to both
surfaces to be bonded together, that is allowed to dry before the two surfaces are
placed in contact with each other, that forms an immediate bond that is
impossible, or difficult, to reposition after both adhesive coated surfaces are placed
in contact with each other, and does not require sustained pressure or clamping of
surfaces after the adhesive coated surfaces have been brought together using
sufficient momentary pressure to establish full contact between both surfaces. This
term does not include rubber cements that are primarily intended for use on paper
substrates or vulcanizing fluids that are designed and labeled for tire repair only.
200.17 COVE BASE INSTALLATION ADHESIVE: An adhesive intended by the
manufacturer to be used for the installation of cove base or wall base on a wall or
vertical surface at floor level.
200.18 CYANOACRYLATE ADHESIVE: A fast-setting, single component adhesive
containing cyanoacrylate compounds that cures at room temperature. Also known
as "super glue."
215 200.19 DAY: A period of 24 consecutive hours beginning at midnight.
216 200.20 DIP COATING: A method of applying a coating to a substrate by submersion
into and removal from a coating bath.
217 200.21 DRUM COATING: Coating of a cylindrical metal shipping container larger than 12
gallons capacity but no larger than 110 gallons capacity.
218 200.22 ELECTRIC DISSIPATING COATING: A coating that rapidly dissipates a
high-voltage electric charge.
200.23 ELECTRIC-INSULATING AND THERMAL-CONDUCTING
COATING: A coating that displays an electrical insulation of at least 1000 volts
DC per mil on a flat test plate and an average thermal conductivity of at least 0.27
BTU per hour-foot-degree-Fahrenheit.
219 200.24 ELECTRIC INSULATING ELECTRIC-INSULATING VARNISH: A non-
convertible-type coating applied to electric motors, components of electric motors,

or power transformers, to provide electrical, mechanical, and environmental
protection or resistance.
220 200.25 ELECTROMAGNETIC INTERFERENCE (EMI)/ RADIO-
FREQUENCY INTERFERENCE (RFI) SHIELDING: A coating used on
electrical or electronic equipment to provide shielding against electromagnetic
interference, radio frequency interference, or static discharge.
221 200.26 ELECTROSTATIC SYSTEM: A method of applying atomized paint by
electrically charging the coating and the object being coated with opposing charges.
A higher proportion of the coating reaches and coats the object than would occur in
the absence of a charge.
222 200.27 EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the
Control Officer, to reduce emissions of volatile organic compounds. Such a system
consists of an emissions collection system and an emissions processing subsystem.
223 200.28 END SEALING COMPOUND: A compound which is coated onto can ends and
functions as a gasket when the end is attached to the can.
224 200.29 ETCHING FILLER: A coating that contains less than 23 percent solids by weight
and at least ½ percent acid by weight, and is used instead of applying a pretreatment
coating followed by a primer.
225 200.30 EXEMPT COMPOUNDS: The federally listed non-precursor organic
compounds, which have been determined to have negligible photochemical
reactivity as listed in 40 CFR 51.100(s)(1) and in Appendix G of these rules.
226 200.31 EXTERIOR CAN BASECOAT: A coating applied to the exterior of a can to
provide protection for the metal or to provide background for any lithographic or
printing operation.
227 200.32 EXTREME HIGH-GLOSS COATING: A coating when tested by the ASTDM
D-523 adopted in 1980 that shows reflectance of 75 or more (95 or more for pleasure
craft topcoats) on a 60° meter as determined by ASTM D523 (1999).
228 200.33 EXTREME-PERFORMANCE EXTREME PERFORMANCE COATING: A
coating used on a surface where the coated surface in its intended use is at
temperatures consistently in excess of 250°F (121°C). A coating used on a metal or
plastic surface where the coated surface is, in its intended use, subject to one of the
following:
a. Chronic exposure to corrosive, caustic, or acidic agents, chemicals, chemical
fumes, chemical mixtures, or chemical solutions; or
b. Repeated exposure to temperatures in excess of 250°F (121°C); or
c. Repeated heavy abrasion, including mechanical wear and repeated scrubbing with
industrial grade solvents, cleansers, or scouring agents.
229 200.34 FABRIC: A textile material. Non-manufactured items from nature are not fabric
except for natural threads, fibers, filaments, and similar items that have been
manufactured into textile fabric material.

230 200.35 FABRIC COATING: A decorative or protective coating or reinforcing material
applied either onto or impregnated into textile fabric.
231 FILLER: A relatively non-adhesive substance added to an adhesive to improve its
working properties, permanence, strength, or other qualities.
232 200.36 FILM COATING: A coating applied in a web coating process on film substrate
other than paper or fabric, including, but not limited to, typewriter ribbons,
photographic film, magnetic tape, and metal foil gift wrap.
233 200.37 FINISH PRIMER/SURFACER: A coating applied for purposes of providing
corrosion resistance, adhesion of subsequent coatings, a moisture barrier, or
promotion of a uniform surface necessary for filling in surface imperfections. A finish
primer/surfacer shall have a wet film thickness of less than 10 mils as determined
by ASTM Method D 1212-85 D1212-85. A one-component finish primer is any
finish primer where the coating resin cures without the need for an added catalyst
or converter. A two-component finish primer is any finish primer where the
coating resin cures only when a catalyst or converter is added.
234 FLEXIBLE PLASTIC PART OR PRODUCT: A plastic part or product designed to
withstand significant deformation without damaging it for its intended use. Not
included are flexible plastic parts that are found on a can, coil, metal furniture, or large
appliance, or that are already a part of an aerospace component, highway vehicle,
mobile equipment, architectural building or structure, or a previously coated marine-
vessel.
200.38 FLEXIBLE VINYL: Non-rigid polyvinyl chloride plastic that contains at least
5% plasticizer by weight.
200.39 FLOOR COVERING INSTALLATION ADHESIVE (INDOOR): An
adhesive intended by the manufacturer for use in the installation of wood flooring,
carpet, resilient tile, vinyl tile, vinyl backed carpet, resilient sheet and roll, or
artificial grass. The term does not include adhesives used to install ceramic tile or
perimeter bonded sheet flooring with vinyl backing onto a nonporous substrate
like flexible vinyl.
200.40 FLOOR COVERING INSTALLATION ADHESIVE (OUTDOOR): An
adhesive intended by the manufacturer for use in the installation of floor covering
that is not in an enclosure and that is exposed to ambient weather conditions
during normal use.
200.41 FLOOR COVERING INSTALLATION ADHESIVE (PERIMETER
BONDED SHEET VINYL): An adhesive intended by the manufacturer for use
in the installation of sheet flooring with vinyl backing onto a nonporous substrate
using an adhesive designed to be applied only to a strip of up to 4 inches wide
around the perimeter of the sheet flooring.
235 200.42 FLOW COAT: A non-atomized technique of applying coatings to a substrate with
a fluid nozzle in a fan pattern with no air supplied to the nozzle.
236 FOG COAT: A coating that is applied to a plastic part for the purpose of color
matching without masking a molded-in texture. A fog coat shall not be applied at a
thickness of more than 0.5 mils of coating solids.

200.43 FOIL COATING: A web coating process which applies a continuous layer of
coating material on a foil substrate across the entire width, or any portion of the
width of a substrate to:
a. Provide a covering, finish, functional, or protective layer on the substrate;
b. Saturate a substrate for lamination; or
c. Provide adhesion between two substrate for lamination.
237 GLOSS REDUCER: A coating that is applied to a plastic part solely to reduce the
shine of the part and is applied at a thickness of less than or equal to 0.5 mils of
coating solids.
238 200.44 HAND APPLICATION METHODS: Application of coatings, industrial
adhesives, or industrial adhesive primers by non-mechanical, hand-held equipment
including, but not limited to, paint brushes, hand rollers, caulking guns, trowels,
spatulas, syringe daubers, rags, and sponges.
239 200.45 HEAT-RESISTANT COATING: A coating that must withstand a temperature of
at least 400°F (204°C) during normal use.
241 200.46 HIGH BUILD PRIMER/SURFACER: A coating applied for purposes of
providing corrosion resistance, adhesion of subsequent coatings, or a moisture
barrier, or promoting a uniform surface necessary for filling in surface
imperfections. A high-build high build primer/surfacer shall have a wet-film wet
film thickness of 10 mils or more as determined by ASTM Method D1212-85.
242 200.47 HIGH GLOSS COATING: A coating that achieves at least 85 percent
reflectance on a 60° meter when tested by ASTM D 523-89 D523-89.
240 200.48 HIGH PERFORMANCE ARCHITECTURAL COATING: A coating used
to protect architectural subsections and that meets the requirements of the
Architectural Aluminum Manufacturer Association's publication number AAMA
2604-05 (Voluntary Specification, Performance Requirements and Test Procedures
for High Performance Organic Coatings on Aluminum Extrusions and Panels) or
2605-05 (Voluntary Specification, Performance Requirements and Test Procedures
for Superior Performing Organic Coatings on Aluminum Extrusions and Panels).
243 200.49 HIGH TEMPERATURE COATING: A coating that is certified to withstand a
temperature of 1000°F (537°C) for 24 hours.
244 200.50 HIGH-VOLUME, LOW PRESSURE (HVLP) SPRAY GUN: Spray
equipment that is used to apply coating, industrial adhesive, or industrial adhesive
primer by means of a spray gun that operates at 10 psig of atomizing air pressure
or less at the center of the air cap. A permanently affixed manufacturer’s gun
identification or manufacturer’s gun literature shall identify and be proof of an
HVLP gun.
245 200.51 HIGHWAY VEHICLE: A vehicle that is physically capable of being driven upon
a highway including, but not limited to, cars, pickups, vans, trucks, truck-tractors,
motor-homes, motorcycles, and utility vehicles.
200.52 INDUSTRIAL ADHESIVE: An adhesive used as part of an industrial
manufacturing operation. For the purposes of this rule, industrial manufacturing

includes activities and operations classified within Division D (Manufacturing) of
the Standard Industrial Classification.
200.53 INDUSTRIAL ADHESIVE PRIMER: An adhesive primer used as part of an
industrial manufacturing operation. For the purposes of this rule, industrial
manufacturing includes activities and operations classified within Division D
(Manufacturing) of the Standard Industrial Classification.
246 200.54 INTERIOR BASECOAT: A coating applied to the interior of a can to provide a
protective lining between the intended contents and the metal shell of the can.
247 200.55 INTERIOR BODY SPRAY: A coating sprayed onto the interior of a can to
provide a protective film between the intended contents and the metal shell of the
can.
248 200.56 IN USE OR HANDLED: Actively engaging the materials with activities such as
mixing, depositing, brushing, rolling, padding, wiping or removing or transferring
material into or out of the container.
249 200.57 LARGE APPLIANCE COATING: A coating applied to a metal door, case, lid,
panel, or interior support part of residential and commercial washers, dryers, ranges,
refrigerators, freezers, water heaters, dishwashers, trash compactors, air conditioners,
evaporative coolers, and other similar products.
250 200.58 LOW PRESSURE SPRAY GUN: An air-atomized spray gun, which by design,
functions best at air cap pressures below 10 psig (0.7 bar), measured according to
Section 503.1(d) of this rule, and for which the manufacturer makes no public claims
that the gun can be used effectively above 12 psig (0.8 bar).
251 200.59 MARINE VESSEL: A tugboat, tanker, freighter, passenger ship, barge, or other
boat, ship or watercraft used for commercial purposes. This definition excludes those
boats used primarily for recreational purposes.
200.60 MASK COATING: A thin film coating applied through a template to coat a small
portion of a substrate.
252 200.61 METAL FURNITURE COATING: Furniture A coating applied to furniture
made of metal or any metal part which will be assembled with other parts made of
metal or other material(s) to form a furniture piece.
200.62 METAL TO URETHANE/RUBBER MOLDING OR CASTING
ADHESIVE: An adhesive intended by the manufacturer to bond metal to high
density or elastomeric urethane or molded rubber materials in a heated molding or
casting process.
253 200.63 METALLIC COATING: A coating that contains more than 5 grams of metal
particles per liter of coating as applied. Metal particles are pieces of a pure elemental
metal or a combination of elemental metals.
254 200.64 MILITARY SPECIFICATION COATING: A coating that has a formulation that
has been approved by a United States Military Agency for use on military equipment.
200.65 MISCELLANEOUS METAL PART AND PRODUCT COATINGS: Coatings
applied to a metal part or product, excluding the following types of coatings: can

coatings, coil coatings, metal furniture coatings, large appliance coatings, and pleasure
craft coatings.
200.66 MISCELLANEOUS PLASTIC PART AND PRODUCT COATINGS:
Coatings applied to a plastic part or product, excluding pleasure craft coatings.
255 200.67 MOBILE EQUIPMENT: Equipment that is physically capable of being driven
or drawn on a highway including, but not limited to, construction vehicles (such as
mobile cranes, bulldozers, concrete mixers); farming equipment (wheel tractor,
plow, pesticide sprayer); hauling equipment (truck trailers, utility bodies, camper
shells); and miscellaneous equipment (street cleaners, mopeds, golf carts).
256 200.68 MOLD-SEAL COATING: The initial coating applied to a new mold or a repaired
mold to provide a smooth surface which, when coated with a mold release coating,
prevents products from sticking to the mold.
200.69 MOTOR VEHICLE ADHESIVE: An adhesive, including glass bonding
adhesive, applied for the purpose of bonding two vehicle surfaces together without
regard to the substrates involved.
200.70 MOTOR VEHICLE GLASS BONDING PRIMER: A primer, used at a facility
that is not an automobile or light-duty truck coating facility, applied to windshield
or other glass, or to body openings, to prepare the glass or body opening for the
application of glass bonding adhesives or the installation of adhesive bonded glass.
Motor vehicle glass bonding primer includes glass bonding/cleaning primers that
perform both functions (cleaning and priming of the windshield or other glass, or
body openings) prior to the application of adhesive or the installation of adhesive
bonded glass.
200.71 MOTOR VEHICLE WEATHERSTRIP ADHESIVE: An adhesive, used at a
facility that is not an automobile or light-duty truck coating facility, applied to
weatherstripping materials for the purpose of bonding the weatherstrip material to
the surface of the vehicle.
257 200.72 MULTI-COLORED COATING: A coating that is packaged in a single
container, applied in a single coat, and exhibits more than one color when applied.
258 200.73 MULTI-COMPONENT COATING: A coating requiring the addition of a
separate reactive resin, commonly known as a catalyst or hardener, prior to
application to form an acceptable dry film.
200.74 MULTIPURPOSE CONSTRUCTION ADHESIVE: An adhesive intended
by the manufacturer for use in the installation or repair of various construction
materials, including drywall, subfloor, panel, fiberglass reinforced plastic (FRP),
ceiling tile and acoustical tile.
259 200.75 ONE-COMPONENT COATING: A coating that is ready for application as it
comes out of its container to form an acceptable dry film. A thinner necessary to
reduce the viscosity is not considered a component.
260 200.76 OPTICAL COATING: A coating applied to an optical lens.
261 OTHER METAL PARTS AND PRODUCTS: Any metal part or product, excluding
the following items that are made of metal: can, coil, furniture, large appliance,

aerospace component, metal foil, metal textile fabric, semiconductor metal, highway
vehicle, mobile equipment, an architectural building or structure, a previously coated
marine-vessel.
262 200.77 OVERVARNISH: A coating applied to a can to reduce the coefficient of friction, to
provide gloss, or to protect the finish against abrasion and/or corrosion.
263 200.78 PAN BACKING COATING: A coating applied to the surface of pots, pans, or
other cooking implements that are exposed directly to a flame or other heating
element.
264 200.79 PAPER COATING: A coating applied on or impregnated into paper, including, but
not limited to, adhesive, adhesive tapes, book covers, post cards, office copier paper,
and drafting paper.
265 200.80 PLASTIC: Substrates made from one or more resins and may be solid, porous,
flexible, or rigid. Plastics include fiber reinforced plastic composites. Any solid,
synthetic: resin, polymer, or elastomer, except rubber. Substrates made from one or
more resins, polymers, or elastomers, excluding rubber. Plastic substrates may be
solid, porous, flexible, or rigid. For the purposes of this rule, plastic film is considered
film; fabric and paper made of polymeric plastic fibers are considered fabric and
paper, respectively.
200.81 PLASTIC SOLVENT WELDING ADHESIVE (ABS): An adhesive intended
by the manufacturer for use to dissolve the surface of acrylonitrile-butadiene-
styrene (ABS) plastic, which is made by reacting monomers of acrylonitrile,
butadiene and styrene, to form a bond between mating surfaces.
200.82 PLASTIC SOLVENT WELDING ADHESIVE (EXCEPT ABS): An
adhesive intended by the manufacturer for use to dissolve the surface of plastic to
form a bond between mating surfaces. This term does not include adhesives used
to weld acrylonitrile-butadiene-styrene (ABS).
200.83 PLASTIC SOLVENT WELDING ADHESIVE PRIMER: Any primer
intended by the manufacturer for use to prepare plastic substrates prior to bonding
or welding.
266 200.84 PLEASURE CRAFT: Vessels which are manufactured or operated primarily for
recreational purposes, or leased, rented, or chartered to a person or business for
recreational purposes.
267 200.85 PLEASURE CRAFT COATING: A marine coating that is applied to or intended
by the manufacturer to be applied to pleasure craft.
200.86 POLYESTER BONDING PUTTIES: Mixtures of resin and filler that are
applied to reinforced plastic composite substrates and become part of the
composite structure.
200.87 POROUS MATERIAL: A substrate whose surface does not prevent penetration by
water.
268 200.88 PREFABRICATED ARCHITECTURAL COMPONENT COATING: A
coating applied to metal parts and products which are to be used as an architectural
structure.

269 200.89 PRESSURE SENSITIVE TAPE OR LABEL COATING: A permanently tacky
adhesive that is applied to one side of a flexible strip of paper, backing material, or
other material, that is coated on one side with a permanently tacky adhesive which
will adhere the strip of material to a variety of surfaces with light pressure.
270 200.90 PRETREATMENT COATING: A coating containing no more than 12 percent
solids by weight, and at least ½ 0.5 percent acid, by weight, that is used to provide
surface etching, and is applied directly to metal surfaces to provide corrosion
resistance, adhesion, and ease of stripping.
271 200.91 PRETREATMENT WASH PRIMER: A coating that contains no more than 12
percent solids, by weight, and at least ½ 0.5 percent acids, by weight, that is used to
provide surface etching, and is applied directly to fiberglass and metal surfaces to
provide corrosion resistance and adhesion of subsequent coatings.
200.92 PRIMARY BUSINESS ACTIVITY: An operation to manufacture or repair an
item or product that will be sold to another entity, or an operation to manufacture or
repair an item or product that was previously sold to another entity. For the purpose
of this rule, primary business activity does not include the construction, installation,
maintenance, or repair of equipment that will be used at the manufacturing facility
and will not be produced for sale to other entities.
272 200.93 PRIMER: A coating applied directly to substrate for any one or combination of the
following purposes: corrosion prevention, protection from the environment,
functional fluid resistance, or adhesion of subsequent coatings.
273 200.94 QUALITY CLASS Q: A system, structure, coating, or other component that, if
defective or inoperable, could cause or increase the severity of a nuclear incident,
thereby imposing undue risk to the health and safety of the public.
274 REFRIGERATED GLASS DOOR COATING: A two-component coating or ink
used for the manufacturing of refrigerated glass doors that forms a decorative or
protective film and provides a substrate for bonding materials such as seals, spacers,
and sealants.
275 200.95 REPAIR COATING: A coating used to recoat the portion of a completed finish
that suffered post-production damage at the facility where the finish was applied.
200.96 SAFETY-INDICATING COATING: A coating that changes physical
characteristics, such as color, to indicate unsafe conditions.
200.97 SHEET APPLIED RUBBER LINING ADHESIVE: An adhesive or an
adhesive primer that is used to bond sheets or strips of rubber to metal equipment so
that such rubber sheathing directly contacts material received by the metal and so
protects the metal.
200.98 SHEET BASECOAT: A coating applied to a sheet of metal, which will be rolled to
form the cylinder of a three-piece can, to provide protection for the metal or to
provide background for any lithographic or printing operation.
276 200.99 SHOCK-FREE COATING: A coating applied to electrical components to protect
the user from electric shock. The coating has characteristics of being of low
capacitance and high resistance, and having resistance to breaking down under high
voltage.

277 200.100 SILICONE RELEASE COATING: A resin coating, the major cured portion of
which is contains silicone resin, having as its primary function the release of and is
intended to prevent food products from sticking to metal surfaces such as baking
pans.
200.101 SINGLE-PLY ROOF MEMBRANE ADHESIVE PRIMER: A primer
labeled for use to clean and promote adhesion of the single-ply roof membrane
seams or splices prior to bonding.
200.102 SINGLE-PLY ROOF MEMBRANE INSTALLATION/REPAIR
ADHESIVE (EXCEPT EPDM): An adhesive intended by the manufacturer for
use in the installation or repair of single-ply roof membrane. For the purposes of
this rule, a single-ply roof membrane is a prefabricated single sheet of elastomeric
material that is applied to a building roof using one layer of membrane material.
This definition does not include adhesives used to install roof membranes
composed of ethylene propylene diene monomer.
278 SMALL SURFACE-COATING SOURCE (SSCS): A facility from which the total
VOC emissions for all surface coating operations that are subject to this rule
without, or prior to, any emission control, is less than 2 tons/yr (1814 kg); as
demonstrated by both adequate records of coating and diluent use (according to
Section 501.2 of this rule) and a separate tally of the number of days each month
such coating operations occur.
279 200.103 SOLAR-ABSORBENT COATING: A coating with the prime purpose of
absorption of solar radiation.
200.104 SOLID-FILM LUBRICANT: A very thin coating consisting of a binder system
containing as its chief pigment material one or more of molybdenum disulfide,
graphite, polytetrafluoroethylene (PTFE) or other solids that act as a dry lubricant
between faying surfaces.
280 200.105 STENCIL COATING: An ink or a coating that is rolled or brushed onto a
template or stamp in order to add identifying letters, symbols and/or numbers.
281 200.106 STRIPPABLE BOOTH COATING: A temporary coating that is applied to spray
booth surfaces to receive the overspray and protect the surfaces, and which is
designed to readily be pulled off the substrate in strips or sheets, and disposed of.
200.107 STRUCTURAL GLAZING: The application of adhesive to bond glass, ceramic,
metal, stone or composite panels to exterior building frames.
282 200.108 SURFACE COATING: A liquid, fluid, or mastic composition that is converted to a
solid (or semi-solid) protective, decorative, or adherent film or deposit after
application as a thin layer. Surface coating is generally distinct and different from
impregnation and from applying adhesive for bonding purposes.
283 200.109 SURFACE COATING OPERATION: Preparation, handling, mixing, and
application of surface coating, and cleanup of application equipment and enclosures
at a facility where surface coating is applied.
284 200.110 TEXTURE COATING: A coating that is applied which, in its finished form,
consists of discrete raised spots of the coating.

200.111 THIN METAL LAMINATING ADHESIVE: An adhesive intended by the
manufacturer for use in bonding multiple layers of metal to metal, or metal to
plastic, in the production of electronic or magnetic components in which the
thickness of the bond line is less than 0.25 millimeters.
200.112 THREE-PIECE CAN: A can manufactured from a rectangular sheet and two
circular ends, where the metal sheet is rolled into a cylinder and soldered, welded, or
cemented at the seam.
285 200.113 THREE-PIECE CAN SIDE-SEAM COATING SPRAY: A coating sprayed
onto the interior and/or exterior of a can body seam on a three-piece can to protect
the exposed metal.
200.114 TIRE REPAIR: A process that includes expanding a hole, tear, fissure, or
blemish in a tire casing by grinding, gouging, or applying adhesive and filling the
hole or crevice with rubber.
286 200.115 TOPCOAT: The final, permanent, coating formulation that completes the finish on
a surface.
287 200.116 TOUCH-UP COATING: A coating used to cover minor coating imperfections
after the main coating operation. This includes touch-up coating that accompanies the
purchase of an object already coated with that coating.
288 TRANSFER EFFICIENCY: The ratio of the weight of coating solids adhering to the
part being coated to the weight of coating solids used in the application process
expressed as a percentage.
200.117 TRANSLUCENT COATING: A coating which contains binders and pigment
and is formulated
200.118 TWO-PIECE CAN: A can that is drawn and wall-ironed from a shallow cup and
requires only one end which is attached after the can is filled with a product.
289 200.119 TWO-PIECE CAN EXTERIOR END COATING: A coating applied to the
exterior end of a can to provide protection to the metal.
290 200.120 VACUUM METALIZING COATING: The An undercoat applied to the a
substrate on which metal is deposited using a vacuum metalizing process, or the an
overcoat applied directly to the metal film formed by a vacuum metalizing process.
Vacuum metalizing is the process of evaporating metals inside a vacuum chamber and
then bonding the metals to the desired substate substrate to achieve a uniform
metalized layer.
291 200.121 VINYL COATING: A decorative, or protective, coating or reinforcing coating
applied over vinyl-coated textile fabric or vinyl sheets.
292 200.122 VOC ACTUAL: The weight of volatile organic compounds minus the weight of
water and minus the weight of exempt organic compounds divided by the total
volume of the materials. Units of VOC Actual are in pounds of VOC per gallon
(or grams per liter) of material and shall be calculated using the following equation:
VOC Actual = ௐೞିௐೢି ௐ೐ೞ
௏೘

Using consistently either English or metric measures in the calculations, where:
weight of all volatile material in pounds (or grams), including VOC,
Ws =
water, non-precursor organic compounds and dissolved vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or grams)
Vm = volume of total material in gallons (or liters)
293 200.123 VOC CONTENT: The organic chemicals in a material that have a vapor pressure
at ordinary room temperature. This vapor pressure results from a low boiling
point, which causes large numbers of molecules to evaporate or sublimate from the
liquid or solid form of the compound and enter the surrounding air. The term
VOC content is a general term used throughout the rule and includes VOC, VOC
Actual, and VOC Regulatory.
294 200.124 VOC REGULATORY: The weight of volatile organic compounds minus the
weight of water and minus the weight of exempt compounds divided by the
volume of material minus the volume of water and minus the volume of exempt
compounds. Units of VOC Regulatory are in pounds of VOC per gallon (or grams
per liter) of material and shall be calculated using the following equation:
VOC Regulatory = ௐೞିௐೢି ௐ೐ೞ
௏೘ି௏ೢି ௏೐ೞ
Using consistently either English or metric measures in the calculations, where:
weight of all volatile material in pounds (or grams), including VOC,
Ws =
water, non-precursor organic compounds and dissolved vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or grams)
Vm = volume of total material in gallons (or liters)
Vw = volume of water in gallons (or liters)
Ves = volume of all non-precursor organic compounds in gallons (or liters)
200.125 WATERPROOF RESORCINOL GLUE: A two-part resorcinol-resin-based
adhesive designed for applications where the bond line must be resistant to
conditions of continuous immersion in fresh or salt water.
SECTION 300 – STANDARDS

301 SURFACE COATINGS AND INDUSTRIAL ADHESIVES: An owner or operator
shall comply with one of the following for all applications of surface coatings, industrial
adhesives, and industrial adhesive primers:
301.1 Meet Comply with the VOC limits in Tables 336-1 through 336-7 of this rule.
Coating limits are calculated as VOC Regulatory (as applied). Compliance will be
determined based on by comparing VOC Regulatory as Applied to the applicable
VOC content limit, as expressed in metric units. English units are provided for
information only; or
301.2 Operate an Emission Control System (ECS) in accordance with Section 305 of this
rule when applying a coating or an industrial adhesive that exceeds the applicable
VOC limits in Tables 336-1 through 336-7 of this rule. All VOC coatings,
industrial adhesives, and industrial adhesive primers used that exceed the applicable
VOC limits in Tables 336-1 through 336-7 of this rule shall be clearly labeled such
that coating-operators are informed that an ECS must be used during application
of surface coatings; or
301.3 Qualify for an exemption under Sections 103 or 104 of this rule.
Table 336-1: Coating Limits for Metal Parts and Products VOC Limits for Miscellaneous Metal
Part and Product Coatings
Coating Category Air Dried Baked
g VOC/l lb VOC/gal g VOC/l lb VOC/gal
Camouflage 420 3.5 420 3.5
Drum Coating, New, Exterior 340 2.8 340 2.8
Drum Coating, New, Interior 420 3.5 420 3.5
Drum Coating, Reconditioned, 420 3.5 420 3.5
Exterior
Drum Coating, Reconditioned, 500 4.2 500 4.2
Interior
Electric-Insulating Varnish 420 3.5 420 3.5
Etching Filler 420 3.5 420 3.5
Extreme High-Gloss 420 3.5 360 3.0
Extreme Performance 420 3.5 360 3.0
Heat-Resistant 420 3.5 360 3.0
High Performance Architectural 740 6.2 740 6.2
High Temperature 420 3.5 420 3.5
Metallic 420 3.5 420 3.5
Military Specification 340 2.8 280 2.3
Mold-Seal Coating 420 3.5 420 3.5
Multi-Component 340 2.8 280 2.3
One-Component 340 2.8 280 2.3
Pan Backing 420 3.5 420 3.5
Prefabricated Architectural Multi- 420 3.5 280 2.3
Component
Prefabricated Architectural 420 3.5 280 2.3
One- Component

Coating Category Air Dried Baked
g VOC/l lb VOC/gal g VOC/l lb VOC/gal
Pretreatment Coating 420 3.5 420 3.5
Repair 420 3.5 360 3.0
Silicone Release 420 3.5 420 3.5
Solar-Absorbent 420 3.5 360 3.0
Touch-up 420 3.5 360 3.0
Vacuum Metalizing 420 3.5 420 3.5
Other Miscellaneous Metal Parts and 420 340 3.5 2.8 360 280 3.0 2.3
Products Part and Product Coatings:
Includes Non-Adhesive Coating,
Adhesive, Adhesive Primer, Beaded
Sealant, and Caulking
Strippable Booth Coating 240 2.0  
Table 336-2: Coating Limits for Cans and Coils VOC Limits for Can and Coil Coatings
Coating Category g VOC/l lb VOC/gal
Can Coating
Can Printing Ink 300 2.5
End Sealing Compound 440 20 3.7 0.2
Sheet Basecoat (Exterior and Interior) and Overvarnish 340 250 2.8 2.1
Three-Piece Can Side-Seam Spray 660 5.5
Two and Three-Piece Can Interior Body Spray 510 440 4.2 3.7
Two-Piece Can Exterior (Basecoat and Overvarnish) 340 250 2.8 2.1
Two-Piece Can Exterior End (Spray or Roll Coat) 510 250 4.2 2.1
Coil Coating 310 200 2.6 1.7
Strippable Booth Coating (applies to both can and coil coating 240 2.0
categories)
Table 336-3: Coating Limits for Plastic Parts and Products VOC Limits for Miscellaneous
Plastic Part and Product Coatings
Coating Category g VOC/l lb VOC/gal
Electric Dissipating Coatings 800 6.7
Extreme Performance, Multi-Component 420 3.5
(2-pack coatings) (2-pack coatings)
Flexible Plastic Parts and Products
Basecoat 540 4.5
Clearcoat 540 4.5
Color Topcoat 450 3.8
Primer 490 4.1
Metallic 420 3.5
Military Specification, Multi-Component 340 (1 pack) 2.8 (1 pack)
420 (2 pack) 3.5 (2 pack)
Military Specification, One-Component 340 2.8
Mold-Seal Coating 760 6.3
Multi-Colored Coating 680 5.7

Coating Category g VOC/l lb VOC/gal
Multi-Component 420 3.5
One-Component 280 2.3
Optical Coatings 800 6.7
Plastic Parts and Products that Are Not Defined as 420 3.5
Flexible
Shock-Free Coatings 800 6.7
Vacuum Metalizing 800 6.7
Other Coatings, Multi-Component 420 3.5
Other Coatings, One-Component 280 2.3
Strippable Booth Coating 240 2.0
Table 336-4: Coating Limits for Business Machines
Coating Category g VOC/l lb VOC/gal
Fog Coat 260 2.2
Primer 350 2.9
Repair 350 2.9
Texture Coating 350 2.9
Topcoat 350 2.9
Touch-up 350 2.9
Strippable Booth Coating 240 2.0
Table 336-5 336-4: Coating VOC Limits for Metal Furniture and Large Appliances Appliance
Coatings
Air Dried Baked
Coating Category
g VOC/l lb VOC/gal g VOC/l lb VOC/gal
Extreme High Gloss 340 2.8 360 3.0
Extreme Performance 420 3.5 360 3.0
Heat-Resistant 420 3.5 360 3.0
Metallic 420 3.5 420 3.5
Pretreatment Coating 420 3.5 420 3.5
Refrigerated Glass Door Coating 480 4.0  
Solar-Absorbent 420 3.5 360 3.0
Other Coatings: Multi-Component 340 2.8 275 2.3
Other Coatings: One-Component 275 2.3 275 2.3
Strippable Booth Coating 240 2.0  
Table 336-6 336-5: Coating VOC Limits for Paper, Fabric, Film, Foil, and Vinyl Coatings
kg VOC/kg kg VOC/kg g lb
Coating Solids VOC/l VOC/gal
Coating Category
(lb VOC/lb (lb VOC/lb
solids) solids)
Fabric   350 2.9
Paper, Film, and Foil
Surface Coating 0.08 0.40  
(Including Adhesives,

kg VOC/kg kg VOC/kg g lb
Coating Solids VOC/l VOC/gal
Coating Category
(lb VOC/lb (lb VOC/lb
solids) solids)
Not Including Pressure
Sensitive Tape and Label
Coatings)
Pressure Sensitive Tape
and Label Surface
0.067 0.20  
Coating (Including
Adhesives)
Vinyl   450 3.8
Strippable Booth Coating   240 2.0
Table 336-7 336-6: Coating VOC Limits for Pleasure Craft Coatings
Coating Category g VOC/l lbs VOC/gal
Aluminum Substrate Antifoulant Coating – Aluminum Substrate 560 4.7
Other Substrate Antifoulant Coating – Non-Aluminum Substrate 400 330 3.4 2.8
Extreme High Gloss Topcoat 600 490 5.2 4.1
Finish Primer/Surfacer 600 420 5.2 3.5
High Build Primer/Surfacer 340 2.8
High Gloss Topcoat 420 3.5
Pretreatment Wash Primer 780 6.5
All Other Pleasure Craft Surface Coatings for Metal or Plastic 420 3.5
Strippable Booth Coating 240 2.0
Table 336-7: VOC Limits for Industrial Adhesives
Adhesive Category g VOC/l lbs VOC/gal
Specialty Industrial Adhesives
Ceramic Tile Installation 130 1.1
Contact Adhesive 250 2.1
Cove Base Installation 150 1.3
Floor Covering Installation (Indoor) 150 1.3
Floor Covering Installation (Outdoor) 250 2.1
Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 660 5.5
Metal to Urethane/Rubber Molding or Casting 850 7.1
Motor Vehicle Adhesive 250 2.1
Motor Vehicle Weatherstrip Adhesive 750 6.3
Multipurpose Construction 200 1.7
Plastic Solvent Welding (ABS) 400 3.3
Plastic Solvent Welding (Except ABS) 500 4.2
Sheet Applied Rubber Lining Adhesive 850 7.1
Single-Ply Roof Membrane Installation/Repair (Except
250 2.1
EPDM)
Structural Glazing 100 0.8
Thin Metal Laminating 780 6.5

Adhesive Category g VOC/l lbs VOC/gal
Tire Repair 100 0.8
Waterproof Resorcinol Glue 170 1.4
Other Industrial Adhesives Used to Bond*
Reinforced Plastic Composite 200 1.7
Flexible vinyl 250 2.1
Metal 30 0.3
Porous Material (Except Wood) 120 1.0
Rubber 250 2.1
Wood 30 0.3
Other Substrates 250 2.1
Industrial Adhesive Primers
Motor Vehicle Glass Bonding Primer 900 7.5
Plastic Solvent Welding Adhesive Primer 650 5.4
Single-Ply Roof Membrane Adhesive Primer 250 2.1
Other Adhesive Primer 250 2.1
* The applicable VOC limit for other industrial adhesives shall be determined based on composition of the substrates
that the industrial adhesive will be used to bond. If the industrial adhesive will be used to bond dissimilar substrates,
the higher VOC content shall apply.
302 APPLICATION METHODS FOR SURFACE COATINGS AND INDUSTRIAL
ADHESIVES:
302.1 An owner or operator shall use one of the following methods for all applications
of surface coating materials containing more than 2 pounds of VOC per gallon
(240 g/L), minus exempt compounds (VOC Regulatory as Applied), and for all
applications of industrial adhesives and industrial adhesive primers:
a. HVLP spray gun;
b. Electrostatic system;
c. A system that atomizes principally by hydraulic pressure, including “airless”
and “air assisted airless”;
d. Hand application methods, including but not limited to;
(1) Flow Coat;
(2) Roll Coat;
(3) Dip-Coating; or
e. An Alternative Application Method: Any method approved by the
Administrator as HVLP-equivalent.
302.2 An owner or operator is allowed to use an application method other than that
described in Section 302.1 of this rule:
a. For applications of surface coating materials containing less than or equal to 2
pounds of VOC per gallon (240 g/L), minus exempt compounds (VOC
Regulatory as Applied).

b. For applications of surface coating materials containing more than 2 pounds of
VOC per gallon (240 g/L), minus exempt compounds (VOC Regulatory as
Applied) and for all applications of industrial adhesives, and industrial adhesive
primers:
(1) If VOC emissions from the finishing application of surface coating
materials, industrial adhesives, and industrial adhesive primers are captured
and directed to an ECS complying with the provisions of Section 305 of
this rule; or
(2) If coating the inside of pipes and tubes with a wand-style applicator; or
(3) If using an airbrush or other small gun that has a reservoir capacity not
exceeding 250 cc (8.8 fl. oz.) and is used solely for detailing, lettering,
touch-up, and/or repair.
303 CLEANUP OF APPLICATION EQUIPMENT: An owner or operator shall comply
with the following when using VOC-containing material to clean application equipment:
303.1 Spray-Gun Spray Gun Cleaning Requirements:
a. Clean spray-guns spray guns without spraying or atomizing a solvent cleaner
with the gun.
b. Spray-Gun Spray Gun Cleaning Machine: Use a spray-gun spray gun
cleaning machine that complies with the following requirements unless the
owner or operator complies with the manual spray-gun spray gun cleaning
requirements in Section 303.2 of this rule.
(1) Spray-Gun Cleaning Machine-General Requirements General
Requirements for Spray Gun Cleaning Machines: The spray-gun spray
gun cleaning machine shall meet all of the following requirements:
(a) Be designed to clean spray-guns spray guns.
(b) Have at least one pump that drives solvent cleaner through and over
the spray-gun spray gun.
(c) Have a basin which permits containment of the solvent cleaner.
(d) Be kept in proper repair and free from liquid leaks.
(e) Be fitted with a cover.
(f) Be located on-site where the spray application occurs; and
(g) Be operated and maintained according to manufacturer’s or
distributor’s instructions.
(h) Porous Material:
(i) Do not clean nor use porous or absorbent materials to clean parts
or products in a cleaning machine. For the purpose of this rule,
porous or absorbent materials include, but are not limited to,
cloth, leather, wood, and rope.

(ii) Do not place an object with a sealed wood handle, including a
brush, in or on a cleaning machine.
(iii) Do not place porous or absorbent materials, including, but not
limited to, cloth, leather, wood, and rope in or on a cleaning
machine.
(i) Pressurized Air Lines: Pressurized air lines shall only be connected to
the spray gun cleaning machine if all of the following requirements are
met:
(i) The manufacturer’s operating manual for the gun cleaning
machine recommends the use of a pressurized air line during gun
cleaning;
(ii) The air pressure in the line does not exceed 10 psig or the
pressure recommended in the manufacturer’s operating manual
for the gun cleaning machine, whichever is lower;
(iii) The use of the air pressure line does not cause solvent to splash
outside of the gun cleaning machine;
(iv) The manufacturer’s operating manual for the gun cleaning
machine is available for the operator of the gun cleaning machine;
and
(v) The owner or operator of the gun cleaning machine makes the
manufacturer’s operating manual for the gun cleaning machine
available to the Control Officer upon request.
(2) Automatic Spray-Gun Spray Gun Cleaning Machine: An automatic
spray-gun spray gun cleaning machine shall have a self-covering or
enclosing cover feature that in the cover's closed position allows no gaps
exceeding 1/8 inch (3 mm) between the cover and the cabinet. This self-
enclosing feature shall be maintained and consistently cover or enclose to
these gap limits.
(3) Non-Automatic Remote Reservoir Cleaning Machine: A non-
automatic remote reservoir cleaning machine shall meet all of the following
requirements:
(a) Drain solvent cleaner from the sink/work-space into a remote reservoir
when work-space is not in use;
(b) Machine The reservoir shall not have cumulative total openings,
including the drain opening(s), exceeding two square inches in area; and
(c) The base of the sink/work-space may function as the reservoir's top
surface, as long as the fit/seal between sink base and reservoir
container allows the reservoir to meet the opening limits specified in
Section 303.1(b)(3)(b) of this rule.
303.2 Manual Spray-Gun Spray Gun Cleaning Requirements: An owner or operator
manually cleaning spray-guns spray guns shall comply with the following
requirements:

a. Disassembled spray-guns spray guns must be cleaned by non-mechanical,
hand-held method of application of cleaners.
b. If disassembled spray-guns spray guns are soaked they shall remain covered at
all times, except when the application equipment is being handled in the
container or transferred into or out of the container.
304 WORK PRACTICES-HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL: An owner or operator of any surface coating facility
operation, industrial adhesive application process, or industrial adhesive primer application
process shall store, handle, and dispose of VOC-containing material in a manner that
prevents the evaporation of VOC to the atmosphere. Work practices limiting VOC
emissions include, but are not limited to, all of the following:
304.1 Use and Storage: An owner or operator shall cover Cover and keep covered each
VOC-containing material which is not currently in use. An owner or operator shall
store finishing and cleaning Store all VOC-containing materials in closed or
covered leak-free containers.
304.2 Disposal of VOC-Containing Material: An owner or operator shall store Store all
VOC-containing materials intended for disposal including, but not limited to, rags,
waste coatings, waste brushes, waste rollers, waste applicators, waste solvents, and
their residues, in closed, leak free containers. The containers shall remain covered
with a leak tight cover, when not in use.
304.3 Minimize spills of VOC-containing coatings, thinners, and coating-related waste
materials.
304.4 Convey VOC-containing coatings, thinners, and coating-related waste materials
from one location to another in closed containers or pipes.
304.5 Containers in which VOC-containing materials are stored must have a legible label
identifying the container’s contents.
305 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS:
305.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 301.2
of this rule, an ECS shall be operated as follows:
a. Overall ECS Efficiency: The overall control efficiency of an ECS shall be
determined by multiplying the capture efficiency by the destruction efficiency
of the control device expressed as a percentage. An owner or operator, who
chooses to use an ECS instead of meeting the limits in Tables 336-1 through
336-7 336-6 of this rule and specified application methods, shall operate an
ECS that has a 90 percent overall ECS efficiency. An owner or operator, who
chooses to use an ECS instead of meeting the limits in Table 336-7 of this rule
and the specified application methods in Section 302 of this rule, shall operate
an ECS that has an 85 percent overall ECS efficiency.
b. Alternative for Very Dilute Input: For VOC input-concentrations of less
than 100 ppm (as methane) at the inlet of the ECS, the control efficiency is
satisfied if the VOC output is less than 20 mg VOC/m3(as methane) adjusted
to standard conditions.

305.2 Operation and Maintenance (O&M) Plan Required for ECS:
a. An owner or operator shall provide and maintain (an) O&M Plan(s) for any
ECS, any other emission processing equipment, and any ECS monitoring
devices used pursuant to this rule or to a Maricopa County Air Pollution
Quality Permit.
b. The owner or operator shall submit to the Control Officer for approval the
O&M Plans of each ECS and each ECS monitoring device used pursuant to
this rule.
c. The owner or operator shall comply with all identified actions and schedules
provided in each O&M Plan.
305.3 Providing and Maintaining ECS Monitoring Devices: An owner or operator
incinerating, adsorbing, or otherwise processing VOC emissions pursuant to this
rule shall provide, properly install and maintain in calibration, in good working
order devices described in the facility’s O&M Plan that indicate temperatures,
pressures, rates of flow, or other operating conditions necessary to determine if air
pollution control equipment the ECS is functioning properly and is properly
maintained. Records shall be kept pursuant to Section 502 of this rule which
demonstrate that the ECS meets the overall control standard required by Section
305.1 of this rule and is operated in accordance with the equipment manufacturer's
specifications.
305.4 O&M Plan Responsibility: An owner or operator of a facility that is required to
have an O&M Plan pursuant to Section 305.2 of this rule must fully comply with
all O&M Plans that the owner or operator has submitted for approval, but which
have not yet been approved, unless notified otherwise by the Control Officer in
writing.
305.5 Operation and Maintenance (O&M) Plan Contents for an ECS: An O&M Plan
for any ECS including any ECS monitoring devices shall include all of the
following information:
a. ECS equipment manufacturer;
b. ECS equipment model;
c. ECS equipment identification number or identifier that owner or operator
subject to this rule assigns to such ECS equipment when manufacturer’s
equipment identification number is unknown; and
d. Information required by Sections 502 and 503 of this rule.
SECTION 400 – ADMINISTRATIVE REQUIREMENTS
401 COMPLIANCE SCHEDULE VOC LIMITS ECS INSTALLATION: An owner or
operator installing an ECS as an alternative to complying with the VOC limits in Section
301.1 of this rule shall:
401.1 Emission Control System (ECS): An owner or operator installing an ECS shall:

a. 401.1 Implement all recordkeeping provisions, including Section 502 of this rule, upon
adoption of this rule.
b. 401.2 Announce the intention to use an ECS to Notify the Control Officer in writing if
the that an ECS is will be installed and used as an alternative to meeting the VOC
limits of Section 301.1 of this rule by [insert date – 3 months after rule adoption].
401.2 VOC Limits and Rule Requirements: Upon adoption of this rule, the owner or
operator shall discontinue purchase of materials that are non-compliant with Section
301.1 of this rule. The owner or operator has up to May 2, 2017 to complete use of
existing non-compliant materials already purchased. A schedule for phasing out non-
compliant materials shall be prepared and made available to an inspector upon
request. This schedule shall specify that only compliant materials will be used after
May 2, 2017.
401.3 Attain full compliance with all applicable standards in this rule by [insert date – 12
months after rule adoption].
402 COMPLIANCE SCHEDULE O&M PLAN FOR NEW VOC LIMITS: O&M Plans
for ECS equipment subject to this rule shall be revised/updated by February 2017. The
Control Officer shall notify the applicant in writing of approval or denial. Upon adoption of
this rule, the owner or operator shall discontinue purchase of materials that are non-
compliant with the VOC limits in Tables 336-1 through 336-7 of this rule. For materials that
are subject to a lower VOC limit upon adoption of this rule, the owner or operator may
continue to use supplies of non-compliant materials purchased prior to [insert date of rule
adoption] until [insert date – 6 months after rule adoption].
SECTION 500 – MONITORING AND RECORDS
501 RECORDKEEPING AND REPORTING: An owner or operator shall comply with the
following recordkeeping requirements:
501.1 Records shall be retained for five years and shall be made available to the Control
Officer without delay upon verbal or written request.
501.2 Current Lists: Maintain a current list of coatings, industrial adhesives, industrial
adhesive primers, cleaning materials or any other VOC-containing materials
regulated by this rule. The list:
a. Shall express VOC content in one of the following forms:
(1) Pounds VOC per gallon;
(2) Grams VOC per liter; or
(3) The percent VOC by weight along with the specific gravity or density.
b. Shall have the written value of the VOC coating content, in one of the
following forms. The documentation must provide accurate VOC content
values or be based on enforceable test methods as approved by the
Administrator to determine the VOC content.
(1) A manufacturer’s technical data sheet;
(2) A manufacturer’s safety data sheet (SDS or MSDS); or

(3) Actual test results.
c. Shall maintain include usage or purchase records as follows:
(1) Monthly: Records of the amount of VOC-containing materials purchased
or used shall be totaled by the end of the month for the previous month.
This includes, but is not limited to, all coating materials, all industrial
adhesives, all industrial adhesive primers, all materials added during
preparation of coatings or adhesives, all materials used to clean coating
application equipment, and all materials used to clean coating application
areas.
(2) Grouping by VOC Content: For purposes of recording usage, an owner
or operator may give VOC coatings, cleaners, and solvents of similar VOC
content (VOC Regulatory) a single group-name, distinct from any product
names in the group. The total usage of all the products in that group is
then recorded under just one name. In such a case, the owner or operator
must also keep a separate list that identifies the product names of the
particular solvents VOC-containing materials included under the group
name. To the group name shall be assigned the highest VOC content
(VOC Regulatory) among the members of that group, rounded to the
nearest tenth of a pound of VOC per gallon of material or to the nearest
gram VOC per liter of material.
d. Shall make the following listings for all coatings materials that have VOC limits
listed in Tables 336-1 through 336-7 of this rule:
(1) VOC Before Reducing: The VOC content of each coating, industrial
adhesive, and industrial adhesive primer as received, minus exempt
compounds. List the manufacturer’s final VOC content as mixed in the
proportions specified by the manufacturer.
(2) List Maximum VOC Content of Coating as Applied: For each coating,
industrial adhesive, and industrial adhesive primer that is thinned/reduced
or to which additive is introduced, record in a permanent log the VOC
content, (VOC Regulatory) after mixing the maximum amount of
thinner/reducer and other additives, as determined by the formula in the
definition of VOC Regulatory of this rule. This log will include the
following:
(a) The maximum number of fluid ounces thinner/reducer added to a gallon
of unreduced coating, unreduced industrial adhesive, or unreduced
industrial adhesive primer (or maximum g/liter) and the maximum fluid
ounces of every other additive mixed into a gallon of the coating,
industrial adhesive, or industrial adhesive primer; or
(b) The VOC content (VOC Regulatory) of the coating, industrial adhesive,
or industrial adhesive primer after adding the maximum amount of
thinner/reducer and other additives as determined by the formula in the
definition of VOC Regulatory in this rule.
e. Shall maintain include usage or purchase records for aerosol can spray coating,
including VOC content.

502 ECS RECORDING REQUIREMENTS: An owner or operator shall maintain all of the
following records in accordance with an approved O&M Plan for any ECS:
502.1 On each day an ECS is used at a facility pursuant to this rule, the owner or
operator shall make a permanent record of the key system operating parameters as
required by the O&M Plan including, but not limited to, the following:
a. Flow rates;
b. Pressure drops;
c. Temperature; or
d. Other operating conditions necessary to determine if the approved ECS is
functioning properly.
502.2 An explanation shall be recorded for periods of time an approved ECS is not
operating.
502.3 For each day or period the O & M Plan requires maintenance, the owner or
operator shall make a permanent record of the maintenance actions taken within
24 hours of the maintenance completion.
502.4 Corrective action taken, if any.
502.5 An explanation shall be entered for scheduled maintenance that is not performed
during the period designated for it in the O&M Plan.
503 COMPLIANCE DETERMINATION AND TEST METHODS:
503.1 Compliance Determination: The following means shall be used to determine
compliance with this rule.
a. Measurement of VOC content VOC regulatory of materials subject to Section
301 or Section 302 of this rule, excluding reactive industrial adhesives, shall be
conducted and reported using one of the following means shall be determined
using one of the following methods and shall be reported on the
manufacturer’s technical data sheet, the manufacturer’s safety data sheet, or on
an analytical report from an accredited laboratory:
(1) VOC content of coatings, solvents, and other substances having less than
5% solids will be determined by the test method in Sections 503.2(f) of this
rule (BAAQMD Method 31 [April 15, 1992]) or 503.2(g) (SCAQMD
Method 313-91 [April 1997]) of this rule. The method in Section 503.2(c)
of this rule (EPA Method 24);
(2) The VOC content of coatings or other materials having 5% or more solids
will be determined by the test method in Sections 503.2(c) (EPA Method
24), 503.2(f) (BAAQMD Method 31 [April 15, 1992]) or 503.2(g)
(SCAQMD Method 313-91 [April 1997]) of this rule. The method in
Section 503.2(g) of this rule (SCAQMD Method 313-91); or
(a) Plastisols, powder coatings, and radiation-cured coatings shall be cured
according to the procedures actually used in the coating process being
tested before final VOC-emission determinations are made.

(b) In the case of multi-component, polymerizing coatings tested
according to Section 503.1(a) of this rule, Method 24 shall be modified
to eliminate the post-mixing dilution-step (that employs toluene or
other solvent). Instead, the mixture shall be spread by appropriate
technique to form a thin layer, occupying the entire bottom of the foil
pan. Techniques included in the method referenced in Section 503.1(b)
of this rule can be used as a guide for such spreading.
(3) The method in Section 503.2(f) of this rule (SCAQMD Method 304-91).
b. VOC regulatory of reactive industrial adhesives subject to Section 301 or 302
of this rule, shall be measured using the method in Appendix A of the
NESHAP for Surface Coating of Plastic Parts and Products (40 CFR 63,
Subpart PPPP) and shall be reported on the manufacturer’s technical data
sheet, the manufacturer’s safety data sheet, or on an analytical report from an
accredited laboratory.
c. An owner or operator that complies with Section 301 or 302 of this rule using
an ECS shall demonstrate compliance using the following methods and
equations:
(1) Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100
where,
EffO = overall ECS efficiency expressed as a percentage;
EffCo = ECS control efficiency expressed as a percentage; and
EffCa = ECS capture efficiency expressed as a percentage.
b. (2) The ECS control efficiency shall be determined by measuring the VOC
content of gaseous emissions entering and exiting an the ECS shall be
determined by either using the method in Section 503.2(b) of this rule (EPA
Method 18) referred to in Section 503.2(b) of this rule, or one of the
methods in Section 503.2(d) of this rule (EPA Method 25, 25a, or 25b) and
its submethod, referred to in. Section 503.2(d) of this rule.
c. (3) Capture efficiency of an ECS The ECS capture efficiency shall be determined
either by using one of the methods in Section 503.2(e) of this rule (EPA
Method 204, 204a, 204b, 204c, 204d, 204e, or 204f and its submethods) and
EPA’s “Guidelines for Determining Capture Efficiency (January 9, 1995)”, or
by using mass balance calculation methods in concert in combination with
ventilation/draft rate determinations made using one of with the methods in
Section 503.2(a) of this rule (EPA Methods 2, 2a, 2c, and or 2d).
d. Measurement of air pressure at the center of the spray gun tip of an air-
atomizing spray gun shall be performed using an attachable device in proper
working order supplied by the gun's manufacturer for performing such a
measurement. The device supplied by the gun’s manufacturer shall be in
proper working order and kept on-site at the location where the gun is used.

e. Temperature measurements shall be done with using an instrument with an
accuracy and precision of less than one-half degree Fahrenheit that is accurate
to within 0.5°F (0.25°C) for temperatures up to 480°F (250°C).
503.2 Compliance Determination-Test Methods Incorporated by Reference: The
following test methods are approved for use for the purpose of determining
compliance with this rule. The test methods are incorporated by reference in
Appendix G of the Maricopa County Air Pollution Control Regulations.
Alternative test methods as approved by the Administrator or other EPA-
approved test methods may be used upon prior written approval from the Control
Officer. When more than one test method is permitted for the same determination,
an exceedance under any method will constitute a violation. Copies of test
methods referenced in this section are available at the Maricopa County Air
Quality Department.
a. EPA Methods 2 (“Determination of Stack Gas Velocity and Volumetric Flow
Rate (Type S Pitot Tube)”), 2a (“Direct Measurement of Gas Volume Through
Pipes and Small Ducts”), 2c (“Determination of Stack Gas Velocity and
Volumetric Flow Rate in Small Stacks or Ducts (Standard Pitot Tube)”), and
2d (“Measurement of Gas volumetric Volume Flow Rates in Small Pipes and
Ducts”). All 4 of the foregoing methods are in (40 CFR 60, Appendix A).
b. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions
by Gas Chromatography”) and its submethods (40 CFR 60, Appendix A).
c. EPA Test Method 24 (“Determination of Volatile Matter Content, Water
Content, Density, Volume Solids, and Weight Solids of Surface Coatings”) (40
CFR 60, Appendix A).
d. EPA Method 25 (“Determination of Total Gaseous Non-methane Organic
Emissions as Carbon”), 25a (“Determination of Total Gaseous Organic
Concentration Using a Flame Ionization Analyzer”), and 25b (“Determination
of Total Gaseous Organic Concentration Using a Nondispersive Infrared
Analyzer”) and its submethods (40 CFR 60, Appendix A).
e. EPA Test Methods 204 (“Criteria for and Verification of a Permanent or
Temporary Total Enclosure”), 204a (“Volatile Organic Compounds Content in
Liquid Input Stream”), 204b (“Volatile Organic Compound Emissions in
Captured Stream”), 204c (“Volatile Organic Compound Emissions in Captured
Stream (Dilution Technique)”), 204d (“Volatile Organic Compound Emissions
in Uncaptured Stream from Temporary Total Enclosure”), 204e (“Volatile
Organic Compound Emissions in Uncaptured Stream from Building
Enclosure”), and 204f (“Volatile Organic Compounds Content in Liquid Input
Stream (Distillation Approach)”) (Appendix M, 40 CFR 51, Appendix M).
f. California’s Bay Area Air Quality Management District (BAAQMD) Method
31 (April 15, 1992), “Determination of Volatile Organic Compounds in Paint
Strippers, Solvent Cleaners, and Low Solids Coatings.” California’s South
Coast Air Quality Management District (SCAQMD) Method 304-91 (February
1996).

g. California’s South Coast Air Quality Management District (SCAQMD) Method
313-91 (April 1997) “Determination of Volatile Organic Compounds (VOC)
by Gas Chromatography/Mass Spectrometry (GC/MS)”.
h. EPA Test Method for Determination of Weight Volatile Matter Content and
Weight Solids Content of Reactive Adhesives (40 CFR 63, Subpart 63,
Appendix A to Subpart PPPP).
503.3 Test Methods for ECS: For coatings controlled pursuant to Section 305 of this
rule:
a. Measurements of VOC emissions from an ECS shall be conducted in
accordance with EPA Methods 18 or its submethods, or by Method 25 or its
submethods (40 CFR 60, Appendix A).
b. Capture efficiency of an ECS shall be determined by mass balance in
combination with ventilation/draft rate determinations done in accordance
with Section 503.3(c) of this rule or with US EPA Test Methods 204, 204a,
204b, 204c, 204d, 204e, and 204f (Appendix M, 40 CFR 51).
c. Ventilation/draft rates shall be determined by EPA Methods 2, 2a, 2c, and 2d
(40 CFR 60, Appendix A).

MARICOPA COUNTY Return to list of attachments
AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 336
SURFACE COATING OPERATIONS AND INDUSTRIAL ADHESIVE APPLICATION
PROCESSES
INDEX
SECTION 100 – GENERAL
101 PURPOSE
102 APPLICABILITY
103 PARTIAL EXEMPTIONS
104 TOTAL CATEGORICAL EXEMPTIONS
SECTION 200 – DEFINITIONS
200.1 ADHESIVE
200.2 ADHESIVE PRIMER
200.3 AEROSOL CAN SPRAY COATING
200.4 AIR DRIED COATING
200.5 AIRLESS AND AIR-ASSISTED AIRLESS SPRAY
200.6 ANTIFOULANT COATING
200.7 APPLICATION EQUIPMENT
200.8 AS APPLIED
200.9 BAKED COATING
200.10 CAMOUFLAGE COATING
200.11 CAN COATING
200.12 CAN PRINTING INK
200.13 CERAMIC TILE INSTALLATION ADHESIVE
200.14 CLEAR COATING
200.15 COIL COATING
200.16 CONTACT ADHESIVE
200.17 COVE BASE INSTALLATION ADHESIVE
200.18 CYANOACRYLATE ADHESIVE
200.19 DAY
200.20 DIP COATING

200.21 DRUM COATING
200.22 ELECTRIC DISSIPATING COATING
200.23 ELECTRIC-INSULATING AND THERMAL-CONDUCTING COATING
200.24 ELECTRIC-INSULATING VARNISH
200.25 ELECTROMAGNETIC INTERFERENCE (EMI)/RADIO-FREQUENCY
INTERFERENCE (RFI) SHIELDING
200.26 ELECTROSTATIC SYSTEM
200.27 EMISSION CONTROL SYSTEM (ECS)
200.28 END SEALING COMPOUND
200.29 ETCHING FILLER
200.30 EXEMPT COMPOUNDS
200.31 EXTERIOR CAN BASECOAT
200.32 EXTREME HIGH-GLOSS COATING
200.33 EXTREME PERFORMANCE COATING
200.34 FABRIC
200.35 FABRIC COATING
200.36 FILM COATING
200.37 FINISH PRIMER/SURFACER
200.38 FLEXIBLE VINYL
200.39 FLOOR COVERING INSTALLATION ADHESIVE (INDOOR)
200.40 FLOOR COVERING INSTALLATION ADHESIVE (OUTDOOR)
200.41 FLOOR COVERING INSTALLATION ADHESIVE (PERIMETER
BONDED SHEET VINYL)
200.42 FLOW COAT
200.43 FOIL COATING
200.44 HAND APPLICATION METHODS
200.45 HEAT-RESISTANT COATING
200.46 HIGH BUILD PRIMER/SURFACER
200.47 HIGH GLOSS COATING
200.48 HIGH PERFORMANCE ARCHITECTURAL COATING
200.49 HIGH TEMPERATURE COATING
200.50 HIGH-VOLUME, LOW PRESSURE (HVLP) SPRAY GUN
200.51 HIGHWAY VEHICLE
200.52 INDUSTRIAL ADHESIVE

200.53 INDUSTRIAL ADHESIVE PRIMER
200.54 INTERIOR BASECOAT
200.55 INTERIOR BODY SPRAY
200.56 IN USE OR HANDLED
200.57 LARGE APPLIANCE COATING
200.58 LOW PRESSURE SPRAY GUN
200.59 MARINE VESSEL
200.60 MASK COATING
200.61 METAL FURNITURE COATING
200.62 METAL TO URETHANE/RUBBER MOLDING OR CASTING ADHESIVE
200.63 METALLIC COATING
200.64 MILITARY SPECIFICATION COATING
200.65 MISCELLANEOUS METAL PART AND PRODUCT COATING
200.66 MISCELLANEOUS PLASTIC PART AND PRODUCT COATING
200.67 MOBILE EQUIPMENT
200.68 MOLD-SEAL COATING
200.69 MOTOR VEHICLE ADHESIVE
200.70 MOTOR VEHICLE GLASS BONDING PRIMER
200.71 MOTOR VEHICLE WEATHERSTRIP ADHESIVE
200.72 MULTI-COLORED COATING
200.73 MULTI-COMPONENT COATING
200.74 MULTIPURPOSE CONSTRUCTION ADHESIVE
200.75 ONE-COMPONENT COATING
200.76 OPTICAL COATING
200.77 OVERVARNISH
200.78 PAN BACKING COATING
200.79 PAPER COATING
200.80 PLASTIC
200.81 PLASTIC SOLVENT WELDING ADHESIVE (ABS)
200.82 PLASTIC SOLVENT WELDING ADHESIVE (EXCEPT ABS)
200.83 PLASTIC SOLVENT WELDING ADHESIVE PRIMER
200.84 PLEASURE CRAFT
200.85 PLEASURE CRAFT COATING

200.86 POLYESTER BONDING PUTTIES
200.87 POROUS MATERIAL
200.88 PREFABRICATED ARCHITECTURAL COATING
200.89 PRESSURE SENSITIVE TAPE OR LABEL COATING
200.90 PRETREATMENT COATING
200.91 PRETREATMENT WASH PRIMER
200.92 PRIMARY BUSINESS ACTIVITY
200.93 PRIMER
200.94 QUALITY CLASS Q
200.95 REPAIR COATING
200.96 SAFETY-INDICATING COATING
200.97 SHEET APPLIED RUBBER LINING ADHESIVE
200.98 SHEET BASECOAT
200.99 SHOCK-FREE COATING
200.100 SILICONE RELEASE COATING
200.101 SINGLE-PLY ROOF MEMBRANE ADHESIVE PRIMER
200.102 SINGLE-PLY ROOF MEMBRANE INSTALLATION/REPAIR ADHESIVE
(EXCEPT EPDM)
200.103 SOLAR-ABSORBENT COATING
200.104 SOLID-FILM LUBRICANT
200.105 STENCIL COATING
200.106 STRIPPABLE BOOTH COATING
200.107 STRUCTURAL GLAZING
200.108 SURFACE COATING
200.109 SURFACE COATING OPERATION
200.110 TEXTURE COATING
200.111 THIN METAL LAMINATING ADHESIVE
200.112 THREE-PIECE CAN
200.113 THREE-PIECE CAN SIDE-SEAM SPRAY
200.114 TIRE REPAIR
200.115 TOPCOAT
200.116 TOUCH-UP COATING
200.117 TRANSLUCENT COATING

200.118 TWO-PIECE CAN
200.119 TWO-PIECE CAN EXTERIOR END COATING
200.120 VACUUM METALIZING COATING
200.121 VINYL COATING
200.122 VOC ACTUAL
200.123 VOC CONTENT
200.124 VOC REGULATORY
200.125 WATERPROOF RESORCINOL GLUE
SECTION 300 – STANDARDS
301 SURFACE COATINGS AND INDUSTRIAL ADHESIVES
302 APPLICATION METHODS FOR SURFACE COATINGS AND
INDUSTRIAL ADHESIVES
303 CLEANUP OF APPLICATION EQUIPMENT
304 WORK PRACTICES – HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL
305 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS
SECTION 400 – ADMINISTRATIVE REQUIREMENTS
401 COMPLIANCE SCHEDULE ECS INSTALLATION
402 COMPLIANCE SCHEDULE FOR NEW VOC LIMITS
SECTION 500 – MONITORING AND RECORDS
501 RECORDKEEPING AND REPORTING
502 ECS RECORDING REQUIREMENTS
503 COMPLIANCE DETERMINATION AND TEST METHODS

Revised 07/13/1988; Revised 09/21/1992; Revised 06/19/1996; Revised 04/07/1999; Revised
09/25/2013; Revised 11/02/2016; Revised MM/DD/YYYY
MARICOPA COUNTY
AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 336
SURFACE COATING OPERATIONS AND INDUSTRIAL ADHESIVE APPLICATION
PROCESSES
SECTION 100 – GENERAL
101 PURPOSE: To limit the emission of volatile organic compounds (VOCs) from surface
coating operations and industrial adhesive application processes.
102 APPLICABILITY: This rule applies to VOC-containing coatings and industrial adhesives
listed in Tables 336-1 through 336-7 of this rule that are not listed in Section 104 of this rule.
Additionally:
102.1 Surface-coating activities regulated under this rule include, but are not limited to,
the application of coating, coating preparation/mixing at the facility applying the
coating, and the cleanup of application equipment.
102.2 Industrial adhesive application processes regulated under this rule include the
application of industrial adhesives and industrial adhesive primers, preparation and
mixing of industrial adhesives and industrial adhesive primers at the facility
applying the industrial adhesive or the industrial adhesive primer, and the cleanup
of application equipment.
102.3 Section 103 sets forth partial exemptions for certain materials or uses employed by
a surface coating operation or an industrial adhesive application process subject to
this rule.
102.4 This rule is not applicable to coatings, industrial adhesives, or industrial adhesive
primers having a VOC content, minus exempt compounds, of less than 0.15lb
VOC/gal (18g/L) nor to solvents having a VOC content of material less than
0.15lb VOC/gal.
102.5 In addition to this rule, facilities may be subject to New Source Performance
Standards (NSPS) in Rule 360 and/or to National Emission Standards for
Hazardous Air Pollutants (NESHAP) in Rule 370 of these rules.
103 PARTIAL EXEMPTIONS:
103.1 Qualified Materials Exemption:
a. Leak-Preventing Materials: Sealants, caulking, and similar materials, excluding
industrial adhesives, used on the following substrates for the primary purpose
of leak prevention are exempt from this rule:
(1) Non-metallic substrates; and

(2) Substrates made post manufacture, such as, but not limited to, old joints and
seals on pipe and valve assemblies.
b. Certain Joint Fillers: Caulking and beaded sealants used to fill gaps or to fill joints
between surfaces are exempt from this rule, except those used in manufacturing
other metal parts and products or in the manufacturing of cans, and excluding
industrial adhesives.
103.2 Plastic Parts Coating Exemption: The following types of plastic parts coatings
are exempt from the VOC limits in Tables 336-1 through 336-6 of this rule but are
subject to the remaining provisions of this rule.
a. Touch-up and repair coatings.
b. Stencil coatings applied on clear or transparent substrates.
c. Clear or translucent coatings.
d. Coatings applied at a paint manufacturing facility while conducting
performance tests on the coatings.
e. Low usage coatings: Non-compliant coatings are permitted for use if the
annual aggregate usage does not exceed 50 gallons per year of an individual
non-compliant coating, and 200 gallons per year of all such coatings . The
owner or operator shall update usage records of these coatings at the end of
each month, pursuant to Section 501.2 of this rule.
f. Reflective coatings applied to highway cones.
g. Mask coatings that are less than 0.5 millimeter thick (dried) and the area coated
is less than 25 square inches.
h. Electromagnetic Interference (EMI)/ Radio-Frequency Interference (RFI)
shielding coatings.
i. Heparin-benzalkonium chloride (HBAC)-containing coatings applied to
medical devices, provided that the total usage of all such coatings does not
exceed 100 gallons per year per facility.
103.3 Application Methods Exemption: The following coatings are exempt from
application methods in Section 302 of this rule but are subject to the remaining
provisions of this rule:
a. Metal part texture coatings.
b. Metal part touch-up and repair coatings.
c. Plastic part coating for airbrush operations using less than 5 gallons per year of
coating.
d. Extreme high gloss coatings for pleasure craft surface coating operations.
103.4 Surface Coating Application Methods and VOC Limit Exemption: The
following surface coating operations are exempt from Sections 301, 302, and 305
of this rule but shall comply with Section 303, 304, and 500 of this rule.
a. Aerosol can spray coating.

b. Coatings that exceed the VOC limits in Tables 336-1 through 336-6 of this rule
are permitted for use if the annual aggregate usage of all such coatings does not
exceed 55 gallons per year (208 liters per year) at a facility. The owner or
operator shall update usage records of these coatings at the end of each month,
pursuant to Section 501.2 of this rule.
c. A facility that has a VOC emission limit, not exceeding 2 tons/year for surface
coating operations regulated by this rule, in a Maricopa County Air Quality
Permit.
d. A Quality Class Q protective coating that is used on equipment, structures,
and/or components within a containment facility of a nuclear power plant.
e. Large Appliance Coating:
(1) Stencil coatings.
(2) Safety-indicating coatings.
(3) Solid-film lubricants.
(4) Electric-insulating and thermal-conducting coatings.
(5) Coating application utilizing aerosol can spray coating.
f. Metal Parts Coating:
(1) Stencil coatings.
(2) Safety-indicating coatings.
(3) Solid-film lubricants.
(4) Electric-insulating and thermal-conducting coatings.
(5) Magnetic data storage disk coatings.
(6) Plastic extruded onto metal parts to form a coating.
g. Powder coating.
103.5 Industrial Adhesive Application Methods and VOC Limit Exemption: The
following industrial adhesive and industrial adhesive primer application processes
are exempt from Sections 301, 302, and 305 of this rule but shall comply with
Section 303, 304, and 500 of this rule.
a. Adhesives or adhesive primers being tested or evaluated in any research and
development, quality assurance, or analytical laboratory.
b. Adhesives or adhesive primers used in the assembly, repair, or manufacture of
aerospace or undersea-based weapon systems.
c. Adhesives or adhesive primers used in medical equipment manufacturing
operations.
d. Cyanoacrylate adhesive application processes.
e. Adhesives and adhesive primers packaged as an aerosol product in which the
spray mechanism is permanently housed in a non-refillable can designed for
handheld application without the need for ancillary hoses or spray equipment.

f. Polyester bonding putties used to assemble fiberglass parts at fiberglass boat
manufacturing facilities and other reinforced plastic composite manufacturing
facilities.
g. Adhesives and adhesive primers that are supplied in containers with a net
volume of 16 ounces or less, or a net weight of one pound or less.
103.6 Industrial Adhesive Small Source Exemption: Only the provisions of Section
501 of this rule shall apply to industrial adhesive application processes, industrial
adhesive primer application processes, and related cleaning activities where the 12-
month rolling total VOC emissions from all such processes are less than or equal
to 3 tons before consideration of controls.
104 TOTAL CATEGORICAL EXEMPTIONS: This rule does not apply to:
104.1 Coatings, adhesives, and adhesive primers listed in Tables 336-1 through 336-7 of
this rule that are more specifically regulated by another source specific rule within
Maricopa County Rules 300 to 359 of Regulation III, as listed below:
a. Aerospace coating operations (Rule 348).
b. Architectural coatings including buildings and erected structures (Rule 335).
c. Solvent cleaning or stripping a surface for coating or other purpose (Rule 331).
d. Printing and graphic arts coating (Rule 337).
e. Semiconductor manufacturing (Rule 338).
f. Refinishing assembled motor vehicles and/or motor equipment (Rule 345).
g. Coating wood furniture and fixtures (Rule 342).
h. Coating wood millwork (Rule 346).
104.2 Marine vessel exterior refinishing (EPA 453/B-97-001).
104.3 Adhesives and adhesive primers that are used for any of the following purposes:
a. Janitorial services and consumer use of janitorial products.
b. Maintenance and upkeep activities (e.g., building maintenance, general repairs,
welding, plumbing, and re-tarring roofs) provided these activities are not
conducted as part of a manufacturing process and are not related to the
source’s primary business activity.
c. Repair or maintenance shop activities not related to the source’s primary
business activity.
d. Field applied adhesives (e.g. plastic solvent welding cements used by plumbers to
join plumbing pipes on construction or repair jobs in the field, or adhesives that
are used to attach flooring materials during a construction or renovation project).
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions shall
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of
these rules. In the event of any inconsistency between any of the Maricopa County air pollution
control rules, the definitions in this rule take precedence.

200.1 ADHESIVE: A material used for the primary purpose of bonding two or more
surfaces together.
200.2 ADHESIVE PRIMER: Any product intended by the manufacturer to be applied
to a substrate, prior to the application of an adhesive, to enhance the bonding surface.
200.3 AEROSOL CAN SPRAY COATING: A coating sold in a hand-held,
pressurized, non-refillable container, of less than 22 fluid ounces (0.66 liter)
capacity, and that is expelled from the container in a finely divided form when a
valve on the container is depressed.
200.4 AIR DRIED COATING: A coating dried by the use of air or forced warm air at
temperatures below 194°F (90°C).
200.5 AIRLESS AND AIR-ASSISTED AIRLESS SPRAY: Any paint spray
technology that relies solely on the fluid pressure of the paint to create an atomized
paint spray pattern and does not apply any atomizing compressed air to the paint
before it leaves the paint nozzle. Air-assisted airless spray uses compressed air to
shape and distribute the fan of atomized paint, but still uses fluid pressure to create
the atomized paint.
200.6 ANTIFOULANT COATING: A coating applied to the underwater portion of a
pleasure craft to prevent or reduce the attachment of biological organisms, and
registered with the United States Environmental Protection Agency (EPA) as a
pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (7 United
States Code Section 136).
200.7 APPLICATION EQUIPMENT: Any equipment including, but not limited to,
spray guns, wands, rollers, and brushes used to apply or cover a surface with a
coating, an industrial adhesive, or an industrial adhesive primer, for either aesthetic,
protective, adhesive, or other purpose.
200.8 AS APPLIED: The formulation of a coating immediately prior to its application
after the addition of all thinner, reducer, and other additives.
200.9 BAKED COATING: A coating that is dried or cured at a temperature at or above
194°F (90°C).
200.10 CAMOUFLAGE COATING: A coating used, principally by the military, to conceal
equipment from detection.
200.11 CAN COATING: A coating applied to the surface(s) of formed cans or a coating
applied at a can making facility to the surface(s) of flat metal sheets or strips that are
formed into cans at the location where the coating is applied.
200.12 CAN PRINTING INK: A fluid or viscous formulation used in can printing that
imparts design, pattern, and/or alphanumeric symbols to a can.
200.13 CERAMIC TILE INSTALLATION ADHESIVE: An adhesive intended by
the manufacturer for use in the installation of ceramic tiles.
200.14 CLEAR COATING: A colorless coating which contains binders, but no pigment,
and is formulated to form a transparent film.

200.15 COIL COATING: A coating applied to the surface(s) of flat metal sheets or strips
that are formed into rolls or coils not used to make cans.
200.16 CONTACT ADHESIVE: An adhesive that is designed for application to both
surfaces to be bonded together, that is allowed to dry before the two surfaces are
placed in contact with each other, that forms an immediate bond that is
impossible, or difficult, to reposition after both adhesive coated surfaces are placed
in contact with each other, and does not require sustained pressure or clamping of
surfaces after the adhesive coated surfaces have been brought together using
sufficient momentary pressure to establish full contact between both surfaces. This
term does not include rubber cements that are primarily intended for use on paper
substrates or vulcanizing fluids that are designed and labeled for tire repair only.
200.17 COVE BASE INSTALLATION ADHESIVE: An adhesive intended by the
manufacturer to be used for the installation of cove base or wall base on a wall or
vertical surface at floor level.
200.18 CYANOACRYLATE ADHESIVE: A fast-setting, single component adhesive
containing cyanoacrylate compounds that cures at room temperature. Also known
as "super glue."
200.19 DAY: A period of 24 consecutive hours beginning at midnight.
200.20 DIP COATING: A method of applying a coating to a substrate by submersion
into and removal from a coating bath.
200.21 DRUM COATING: Coating of a cylindrical metal shipping container larger than 12
gallons capacity but no larger than 110 gallons capacity.
200.22 ELECTRIC DISSIPATING COATING: A coating that rapidly dissipates a
high-voltage electric charge.
200.23 ELECTRIC-INSULATING AND THERMAL-CONDUCTING
COATING: A coating that displays an electrical insulation of at least 1000 volts
DC per mil on a flat test plate and an average thermal conductivity of at least 0.27
BTU per hour-foot-degree-Fahrenheit.
200.24 ELECTRIC-INSULATING VARNISH: A non-convertible-type coating
applied to electric motors, components of electric motors, or power transformers,
to provide electrical, mechanical, and environmental protection or resistance.
200.25 ELECTROMAGNETIC INTERFERENCE (EMI)/ RADIO-
FREQUENCY INTERFERENCE (RFI) SHIELDING: A coating used on
electrical or electronic equipment to provide shielding against electromagnetic
interference, radio frequency interference, or static discharge.
200.26 ELECTROSTATIC SYSTEM: A method of applying atomized paint by
electrically charging the coating and the object being coated with opposing charges.
A higher proportion of the coating reaches and coats the object than would occur in
the absence of a charge.
200.27 EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the
Control Officer, to reduce emissions of volatile organic compounds. Such a system
consists of an emissions collection system and an emissions processing subsystem.

200.28 END SEALING COMPOUND: A compound which is coated onto can ends and
functions as a gasket when the end is attached to the can.
200.29 ETCHING FILLER: A coating that contains less than 23 percent solids by weight
and at least ½ percent acid by weight, and is used instead of applying a pretreatment
coating followed by a primer.
200.30 EXEMPT COMPOUNDS: The federally listed non-precursor organic
compounds, which have been determined to have negligible photochemical
reactivity as listed in 40 CFR 51.100(s)(1) and in Appendix G of these rules.
200.31 EXTERIOR CAN BASECOAT: A coating applied to the exterior of a can to
provide protection for the metal or to provide background for any lithographic or
printing operation.
200.32 EXTREME HIGH-GLOSS COATING: A coating that shows reflectance of 75
or more (95 or more for pleasure craft topcoats) on a 60° meter as determined by
ASTM D523 (1999).
200.33 EXTREME PERFORMANCE COATING: A coating used on a metal or plastic
surface where the coated surface is, in its intended use, subject to one of the
following:
a. Chronic exposure to corrosive, caustic, or acidic agents, chemicals, chemical
fumes, chemical mixtures, or chemical solutions; or
b. Repeated exposure to temperatures in excess of 250°F (121°C); or
c. Repeated heavy abrasion, including mechanical wear and repeated scrubbing with
industrial grade solvents, cleansers, or scouring agents.
200.34 FABRIC: A textile material. Non-manufactured items from nature are not fabric
except for natural threads, fibers, filaments, and similar items that have been
manufactured into textile material.
200.35 FABRIC COATING: A decorative or protective coating or reinforcing material
applied either onto or impregnated into textile fabric.
200.36 FILM COATING: A coating applied in a web coating process on film substrate
other than paper or fabric, including, but not limited to, typewriter ribbons,
photographic film, magnetic tape, and metal foil gift wrap.
200.37 FINISH PRIMER/SURFACER: A coating applied for purposes of providing
corrosion resistance, adhesion of subsequent coatings, a moisture barrier, or
promotion of a uniform surface necessary for filling in surface imperfections. A finish
primer/surfacer shall have a wet film thickness of less than 10 mils as determined
by ASTM Method D1212-85.
200.38 FLEXIBLE VINYL: Non-rigid polyvinyl chloride plastic that contains at least
5% plasticizer by weight.
200.39 FLOOR COVERING INSTALLATION ADHESIVE (INDOOR): An
adhesive intended by the manufacturer for use in the installation of wood flooring,
carpet, resilient tile, vinyl tile, vinyl backed carpet, resilient sheet and roll, or
artificial grass. The term does not include adhesives used to install ceramic tile or

perimeter bonded sheet flooring with vinyl backing onto a nonporous substrate
like flexible vinyl.
200.40 FLOOR COVERING INSTALLATION ADHESIVE (OUTDOOR): An
adhesive intended by the manufacturer for use in the installation of floor covering
that is not in an enclosure and that is exposed to ambient weather conditions
during normal use.
200.41 FLOOR COVERING INSTALLATION ADHESIVE (PERIMETER
BONDED SHEET VINYL): An adhesive intended by the manufacturer for use
in the installation of sheet flooring with vinyl backing onto a nonporous substrate
using an adhesive designed to be applied only to a strip of up to 4 inches wide
around the perimeter of the sheet flooring.
200.42 FLOW COAT: A non-atomized technique of applying coatings to a substrate with
a fluid nozzle in a fan pattern with no air supplied to the nozzle.
200.43 FOIL COATING: A web coating process which applies a continuous layer of
coating material on a foil substrate across the entire width, or any portion of the
width of a substrate to:
a. Provide a covering, finish, functional, or protective layer on the substrate;
b. Saturate a substrate for lamination; or
c. Provide adhesion between two substrate for lamination.
200.44 HAND APPLICATION METHODS: Application of coatings, industrial
adhesives, or industrial adhesive primers by non-mechanical, hand-held equipment
including, but not limited to, paint brushes, hand rollers, caulking guns, trowels,
spatulas, syringe daubers, rags, and sponges.
200.45 HEAT-RESISTANT COATING: A coating that must withstand a temperature of
at least 400°F (204°C) during normal use.
200.46 HIGH BUILD PRIMER/SURFACER: A coating applied for purposes of
providing corrosion resistance, adhesion of subsequent coatings, or a moisture
barrier, or promoting a uniform surface necessary for filling in surface
imperfections. A high build primer/surfacer shall have a wet film thickness of 10
mils or more as determined by ASTM Method D1212-85.
200.47 HIGH GLOSS COATING: A coating that achieves at least 85 percent
reflectance on a 60° meter when tested by ASTM D523-89.
200.48 HIGH PERFORMANCE ARCHITECTURAL COATING: A coating used
to protect architectural subsections and that meets the requirements of the
Architectural Aluminum Manufacturer Association's publication number AAMA
2604-05 (Voluntary Specification, Performance Requirements and Test Procedures
for High Performance Organic Coatings on Aluminum Extrusions and Panels) or
2605-05 (Voluntary Specification, Performance Requirements and Test Procedures
for Superior Performing Organic Coatings on Aluminum Extrusions and Panels).
200.49 HIGH TEMPERATURE COATING: A coating that is certified to withstand a
temperature of 1000°F (537°C) for 24 hours.

200.50 HIGH-VOLUME, LOW PRESSURE (HVLP) SPRAY GUN: Spray
equipment that is used to apply coating, industrial adhesive, or industrial adhesive
primer by means of a spray gun that operates at 10 psig of atomizing air pressure
or less at the center of the air cap. A permanently affixed manufacturer’s gun
identification or manufacturer’s gun literature shall identify and be proof of an
HVLP gun.
200.51 HIGHWAY VEHICLE: A vehicle that is physically capable of being driven upon
a highway including, but not limited to, cars, pickups, vans, trucks, truck-tractors,
motor-homes, motorcycles, and utility vehicles.
200.52 INDUSTRIAL ADHESIVE: An adhesive used as part of an industrial
manufacturing operation. For the purposes of this rule, industrial manufacturing
includes activities and operations classified within Division D (Manufacturing) of
the Standard Industrial Classification.
200.53 INDUSTRIAL ADHESIVE PRIMER: An adhesive primer used as part of an
industrial manufacturing operation. For the purposes of this rule, industrial
manufacturing includes activities and operations classified within Division D
(Manufacturing) of the Standard Industrial Classification.
200.54 INTERIOR BASECOAT: A coating applied to the interior of a can to provide a
protective lining between the intended contents and the metal shell of the can.
200.55 INTERIOR BODY SPRAY: A coating sprayed onto the interior of a can to
provide a protective film between the intended contents and the metal shell of the
can.
200.56 IN USE OR HANDLED: Actively engaging the materials with activities such as
mixing, depositing, brushing, rolling, padding, wiping or removing or transferring
material into or out of the container.
200.57 LARGE APPLIANCE COATING: A coating applied to a metal door, case, lid,
panel, or interior support part of residential and commercial washers, dryers, ranges,
refrigerators, freezers, water heaters, dishwashers, trash compactors, air conditioners,
evaporative coolers, and other similar products.
200.58 LOW PRESSURE SPRAY GUN: An air-atomized spray gun, which by design,
functions best at air cap pressures below 10 psig (0.7 bar), measured according to
Section 503.1(d) of this rule, and for which the manufacturer makes no public claims
that the gun can be used effectively above 12 psig (0.8 bar).
200.59 MARINE VESSEL: A tugboat, tanker, freighter, passenger ship, barge, or other
boat, ship or watercraft used for commercial purposes. This definition excludes those
boats used primarily for recreational purposes.
200.60 MASK COATING: A thin film coating applied through a template to coat a small
portion of a substrate.
200.61 METAL FURNITURE COATING: A coating applied to furniture made of metal
or any metal part which will be assembled with other parts to form a furniture piece.
200.62 METAL TO URETHANE/RUBBER MOLDING OR CASTING
ADHESIVE: An adhesive intended by the manufacturer to bond metal to high

density or elastomeric urethane or molded rubber materials in a heated molding or
casting process.
200.63 METALLIC COATING: A coating that contains more than 5 grams of metal
particles per liter of coating as applied. Metal particles are pieces of a pure elemental
metal or a combination of elemental metals.
200.64 MILITARY SPECIFICATION COATING: A coating that has a formulation that
has been approved by a United States Military Agency for use on military equipment.
200.65 MISCELLANEOUS METAL PART AND PRODUCT COATINGS: Coatings
applied to a metal part or product, excluding the following types of coatings: can
coatings, coil coatings, metal furniture coatings, large appliance coatings, and pleasure
craft coatings.
200.66 MISCELLANEOUS PLASTIC PART AND PRODUCT COATINGS:
Coatings applied to a plastic part or product, excluding pleasure craft coatings.
200.67 MOBILE EQUIPMENT: Equipment that is physically capable of being driven
or drawn on a highway including, but not limited to, construction vehicles (such as
mobile cranes, bulldozers, concrete mixers); farming equipment (wheel tractor,
plow, pesticide sprayer); hauling equipment (truck trailers, utility bodies, camper
shells); and miscellaneous equipment (street cleaners, mopeds, golf carts).
200.68 MOLD-SEAL COATING: The initial coating applied to a new mold or a repaired
mold to provide a smooth surface which, when coated with a mold release coating,
prevents products from sticking to the mold.
200.69 MOTOR VEHICLE ADHESIVE: An adhesive, including glass bonding
adhesive, applied for the purpose of bonding two vehicle surfaces together without
regard to the substrates involved.
200.70 MOTOR VEHICLE GLASS BONDING PRIMER: A primer, used at a facility
that is not an automobile or light-duty truck coating facility, applied to windshield
or other glass, or to body openings, to prepare the glass or body opening for the
application of glass bonding adhesives or the installation of adhesive bonded glass.
Motor vehicle glass bonding primer includes glass bonding/cleaning primers that
perform both functions (cleaning and priming of the windshield or other glass, or
body openings) prior to the application of adhesive or the installation of adhesive
bonded glass.
200.71 MOTOR VEHICLE WEATHERSTRIP ADHESIVE: An adhesive, used at a
facility that is not an automobile or light-duty truck coating facility, applied to
weatherstripping materials for the purpose of bonding the weatherstrip material to
the surface of the vehicle.
200.72 MULTI-COLORED COATING: A coating that is packaged in a single
container, applied in a single coat, and exhibits more than one color when applied.
200.73 MULTI-COMPONENT COATING: A coating requiring the addition of a
separate reactive resin, commonly known as a catalyst or hardener, prior to
application to form an acceptable dry film.

200.74 MULTIPURPOSE CONSTRUCTION ADHESIVE: An adhesive intended
by the manufacturer for use in the installation or repair of various construction
materials, including drywall, subfloor, panel, fiberglass reinforced plastic (FRP),
ceiling tile and acoustical tile.
200.75 ONE-COMPONENT COATING: A coating that is ready for application as it
comes out of its container to form an acceptable dry film. A thinner necessary to
reduce the viscosity is not considered a component.
200.76 OPTICAL COATING: A coating applied to an optical lens.
200.77 OVERVARNISH: A coating applied to a can to reduce the coefficient of friction, to
provide gloss, or to protect the finish against abrasion and/or corrosion.
200.78 PAN BACKING COATING: A coating applied to the surface of pots, pans, or
other cooking implements that are exposed directly to a flame or other heating
element.
200.79 PAPER COATING: A coating applied on or impregnated into paper, including, but
not limited to, adhesive, adhesive tapes, book covers, post cards, office copier paper,
and drafting paper.
200.80 PLASTIC: Substrates made from one or more resins, polymers, or elastomers,
excluding rubber. Plastic substrates may be solid, porous, flexible, or rigid. For the
purposes of this rule, plastic film is considered film; fabric and paper made of
polymeric plastic fibers are considered fabric and paper, respectively.
200.81 PLASTIC SOLVENT WELDING ADHESIVE (ABS): An adhesive intended
by the manufacturer for use to dissolve the surface of acrylonitrile-butadiene-
styrene (ABS) plastic, which is made by reacting monomers of acrylonitrile,
butadiene and styrene, to form a bond between mating surfaces.
200.82 PLASTIC SOLVENT WELDING ADHESIVE (EXCEPT ABS): An
adhesive intended by the manufacturer for use to dissolve the surface of plastic to
form a bond between mating surfaces. This term does not include adhesives used
to weld acrylonitrile-butadiene-styrene (ABS).
200.83 PLASTIC SOLVENT WELDING ADHESIVE PRIMER: Any primer
intended by the manufacturer for use to prepare plastic substrates prior to bonding
or welding.
200.84 PLEASURE CRAFT: Vessels which are manufactured or operated primarily for
recreational purposes, or leased, rented, or chartered to a person or business for
recreational purposes.
200.85 PLEASURE CRAFT COATING: A marine coating that is applied to or intended
by the manufacturer to be applied to pleasure craft.
200.86 POLYESTER BONDING PUTTIES: Mixtures of resin and filler that are
applied to reinforced plastic composite substrates and become part of the
composite structure.
200.87 POROUS MATERIAL: A substrate whose surface does not prevent penetration by
water.

200.88 PREFABRICATED ARCHITECTURAL COATING: A coating applied to
metal parts and products which are to be used as an architectural structure.
200.89 PRESSURE SENSITIVE TAPE OR LABEL COATING: A permanently tacky
adhesive that is applied to one side of a flexible strip of paper, backing material, or
other material, which will adhere the strip of material to a variety of surfaces with light
pressure.
200.90 PRETREATMENT COATING: A coating containing no more than 12 percent
solids by weight, and at least 0.5 percent acid by weight, that is used to provide
surface etching, and is applied directly to metal surfaces to provide corrosion
resistance, adhesion, and ease of stripping.
200.91 PRETREATMENT WASH PRIMER: A coating that contains no more than 12
percent solids, by weight, and at least 0.5 percent acids by weight, that is used to
provide surface etching, and is applied directly to fiberglass and metal surfaces to
provide corrosion resistance and adhesion of subsequent coatings.
200.92 PRIMARY BUSINESS ACTIVITY: An operation to manufacture or repair an
item or product that will be sold to another entity, or an operation to manufacture or
repair an item or product that was previously sold to another entity. For the purpose
of this rule, primary business activity does not include the construction, installation,
maintenance, or repair of equipment that will be used at the manufacturing facility
and will not be produced for sale to other entities.
200.93 PRIMER: A coating applied directly to substrate for any one or combination of the
following purposes: corrosion prevention, protection from the environment,
functional fluid resistance, or adhesion of subsequent coatings.
200.94 QUALITY CLASS Q: A system, structure, coating, or other component that, if
defective or inoperable, could cause or increase the severity of a nuclear incident,
thereby imposing undue risk to the health and safety of the public.
200.95 REPAIR COATING: A coating used to recoat the portion of a completed finish
that suffered post-production damage at the facility where the finish was applied.
200.96 SAFETY-INDICATING COATING: A coating that changes physical
characteristics, such as color, to indicate unsafe conditions.
200.97 SHEET APPLIED RUBBER LINING ADHESIVE: An adhesive or an
adhesive primer that is used to bond sheets or strips of rubber to metal equipment so
that such rubber sheathing directly contacts material received by the metal and so
protects the metal.
200.98 SHEET BASECOAT: A coating applied to a sheet of metal, which will be rolled to
form the cylinder of a three-piece can, to provide protection for the metal or to
provide background for any lithographic or printing operation.
200.99 SHOCK-FREE COATING: A coating applied to electrical components to protect
the user from electric shock. The coating has characteristics of being of low
capacitance and high resistance, and having resistance to breaking down under high
voltage.

200.100 SILICONE RELEASE COATING: A coating which contains silicone resin and is
intended to prevent food products from sticking to metal surfaces such as baking
pans.
200.101 SINGLE-PLY ROOF MEMBRANE ADHESIVE PRIMER: A primer
labeled for use to clean and promote adhesion of the single-ply roof membrane
seams or splices prior to bonding.
200.102 SINGLE-PLY ROOF MEMBRANE INSTALLATION/REPAIR
ADHESIVE (EXCEPT EPDM): An adhesive intended by the manufacturer for
use in the installation or repair of single-ply roof membrane. For the purposes of
this rule, a single-ply roof membrane is a prefabricated single sheet of elastomeric
material that is applied to a building roof using one layer of membrane material.
This definition does not include adhesives used to install roof membranes
composed of ethylene propylene diene monomer.
200.103 SOLAR-ABSORBENT COATING: A coating with the prime purpose of
absorption of solar radiation.
200.104 SOLID-FILM LUBRICANT: A very thin coating consisting of a binder system
containing as its chief pigment material one or more of molybdenum disulfide,
graphite, polytetrafluoroethylene (PTFE) or other solids that act as a dry lubricant
between faying surfaces.
200.105 STENCIL COATING: An ink or a coating that is rolled or brushed onto a
template or stamp in order to add identifying letters, symbols and/or numbers.
200.106 STRIPPABLE BOOTH COATING: A temporary coating that is applied to spray
booth surfaces to receive the overspray and protect the surfaces, and which is
designed to readily be pulled off the substrate in strips or sheets, and disposed of.
200.107 STRUCTURAL GLAZING: The application of adhesive to bond glass, ceramic,
metal, stone or composite panels to exterior building frames.
200.108 SURFACE COATING: A liquid, fluid, or mastic composition that is converted to a
solid (or semi-solid) protective, decorative, or adherent film or deposit after
application as a thin layer. Surface coating is generally distinct and different from
impregnation and from applying adhesive for bonding purposes.
200.109 SURFACE COATING OPERATION: Preparation, handling, mixing, and
application of surface coating, and cleanup of application equipment and enclosures
at a facility where surface coating is applied.
200.110 TEXTURE COATING: A coating that is applied which, in its finished form,
consists of discrete raised spots of the coating.
200.111 THIN METAL LAMINATING ADHESIVE: An adhesive intended by the
manufacturer for use in bonding multiple layers of metal to metal, or metal to
plastic, in the production of electronic or magnetic components in which the
thickness of the bond line is less than 0.25 millimeters.
200.112 THREE-PIECE CAN: A can manufactured from a rectangular sheet and two
circular ends, where the metal sheet is rolled into a cylinder and soldered, welded, or
cemented at the seam.

200.113 THREE-PIECE CAN SIDE-SEAM SPRAY: A coating sprayed onto the interior
and/or exterior of a can body seam on a three-piece can to protect the exposed metal.
200.114 TIRE REPAIR: A process that includes expanding a hole, tear, fissure, or
blemish in a tire casing by grinding, gouging, or applying adhesive and filling the
hole or crevice with rubber.
200.115 TOPCOAT: The final, permanent, coating formulation that completes the finish on
a surface.
200.116 TOUCH-UP COATING: A coating used to cover minor coating imperfections
after the main coating operation. This includes touch-up coating that accompanies the
purchase of an object already coated with that coating.
200.117 TRANSLUCENT COATING: A coating which contains binders and pigment
and is formulated
200.118 TWO-PIECE CAN: A can that is drawn and wall-ironed from a shallow cup and
requires only one end which is attached after the can is filled with a product.
200.119 TWO-PIECE CAN EXTERIOR END COATING: A coating applied to the
exterior end of a can to provide protection to the metal.
200.120 VACUUM METALIZING COATING: An undercoat applied to a substrate on
which metal is deposited using a vacuum metalizing process, or an overcoat applied
directly to the metal film formed by a vacuum metalizing process. Vacuum metalizing
is the process of evaporating metals inside a vacuum chamber and then bonding the
metals to the desired substrate to achieve a uniform metalized layer.
200.121 VINYL COATING: A decorative, protective, or reinforcing coating applied over
vinyl-coated textile fabric or vinyl sheets.
200.122 VOC ACTUAL: The weight of volatile organic compounds minus the weight of
water and minus the weight of exempt organic compounds divided by the total
volume of the materials. Units of VOC Actual are in pounds of VOC per gallon
(or grams per liter) of material and shall be calculated using the following equation:
VOC Actual = ௐೞିௐೢି ௐ೐ೞ
௏೘
Using consistently either English or metric measures in the calculations, where:
weight of all volatile material in pounds (or grams), including VOC,
Ws =
water, non-precursor organic compounds and dissolved vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or grams)
Vm = volume of total material in gallons (or liters)
200.123 VOC CONTENT: The organic chemicals in a material that have a vapor pressure
at ordinary room temperature. This vapor pressure results from a low boiling
point, which causes large numbers of molecules to evaporate or sublimate from the

liquid or solid form of the compound and enter the surrounding air. The term
VOC content is a general term used throughout the rule and includes VOC, VOC
Actual, and VOC Regulatory.
200.124 VOC REGULATORY: The weight of volatile organic compounds minus the
weight of water and minus the weight of exempt compounds divided by the
volume of material minus the volume of water and minus the volume of exempt
compounds. Units of VOC Regulatory are in pounds of VOC per gallon (or grams
per liter) of material and shall be calculated using the following equation:
VOC Regulatory = ௐೞିௐೢି ௐ೐ೞ
௏೘ି௏ೢି ௏೐ೞ
Using consistently either English or metric measures in the calculations, where:
weight of all volatile material in pounds (or grams), including VOC,
Ws =
water, non-precursor organic compounds and dissolved vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or grams)
Vm = volume of total material in gallons (or liters)
Vw = volume of water in gallons (or liters)
Ves = volume of all non-precursor organic compounds in gallons (or liters)
200.125 WATERPROOF RESORCINOL GLUE: A two-part resorcinol-resin-based
adhesive designed for applications where the bond line must be resistant to
conditions of continuous immersion in fresh or salt water.
SECTION 300 – STANDARDS
301 SURFACE COATINGS AND INDUSTRIAL ADHESIVES: An owner or operator
shall comply with one of the following for all applications of surface coatings, industrial
adhesives, and industrial adhesive primers:
301.1 Comply with the VOC limits in Tables 336-1 through 336-7 of this rule.
Compliance will be determined by comparing VOC Regulatory as Applied to the
applicable VOC limit, as expressed in metric units. English units are provided for
information only; or
301.2 Operate an Emission Control System (ECS) in accordance with Section 305 of this
rule when applying a coating or an industrial adhesive that exceeds the applicable
VOC limits in Tables 336-1 through 336-7 of this rule. All coatings, industrial
adhesives, and industrial adhesive primers used that exceed the applicable VOC
limits in Tables 336-1 through 336-7 of this rule shall be clearly labeled such that
operators are informed that an ECS must be used during application; or
301.3 Qualify for an exemption under Sections 103 or 104 of this rule.
Table 336-1: VOC Limits for Miscellaneous Metal Part and Product Coatings

Coating Category Air Dried Baked
g VOC/l lb VOC/gal g VOC/l lb VOC/gal
Camouflage 420 3.5 420 3.5
Drum Coating, New, Exterior 340 2.8 340 2.8
Drum Coating, New, Interior 420 3.5 420 3.5
Drum Coating, Reconditioned, 420 3.5 420 3.5
Exterior
Drum Coating, Reconditioned, 500 4.2 500 4.2
Interior
Electric-Insulating Varnish 420 3.5 420 3.5
Etching Filler 420 3.5 420 3.5
Extreme High-Gloss 420 3.5 360 3.0
Extreme Performance 420 3.5 360 3.0
Heat-Resistant 420 3.5 360 3.0
High Performance Architectural 740 6.2 740 6.2
High Temperature 420 3.5 420 3.5
Metallic 420 3.5 420 3.5
Military Specification 340 2.8 280 2.3
Mold-Seal Coating 420 3.5 420 3.5
Pan Backing 420 3.5 420 3.5
Prefabricated Architectural 420 3.5 280 2.3
Pretreatment Coating 420 3.5 420 3.5
Repair 420 3.5 360 3.0
Silicone Release 420 3.5 420 3.5
Solar-Absorbent 420 3.5 360 3.0
Touch-up 420 3.5 360 3.0
Vacuum Metalizing 420 3.5 420 3.5
Other Miscellaneous Metal Part and 340 2.8 280 2.3
Product Coatings
Strippable Booth Coating 240 2.0  
Table 336-2: VOC Limits for Can and Coil Coatings
Coating Category g VOC/l lb VOC/gal
Can Coating
Can Printing Ink 300 2.5
End Sealing Compound 20 0.2
Sheet Basecoat (Exterior and Interior) and Overvarnish 250 2.1
Three-Piece Can Side-Seam Spray 660 5.5
Two and Three-Piece Can Interior Body Spray 440 3.7
Two-Piece Can Exterior (Basecoat and Overvarnish) 250 2.1
Two-Piece Can Exterior End (Spray or Roll Coat) 250 2.1
Coil Coating 200 1.7
Strippable Booth Coating (applies to both can and coil coating 240 2.0
categories)
Table 336-3: VOC Limits for Miscellaneous Plastic Part and Product Coatings

Coating Category g VOC/l lb VOC/gal
Electric Dissipating Coatings 800 6.7
Extreme Performance, Multi-Component 420 3.5
Metallic 420 3.5
Military Specification, Multi-Component 420 3.5
Military Specification, One-Component 340 2.8
Mold-Seal Coating 760 6.3
Multi-Colored Coating 680 5.7
Optical Coatings 800 6.7
Shock-Free Coatings 800 6.7
Vacuum Metalizing 800 6.7
Other Coatings, Multi-Component 420 3.5
Other Coatings, One-Component 280 2.3
Strippable Booth Coating 240 2.0
Table 336-4: VOC Limits for Metal Furniture and Large Appliance Coatings
Air Dried Baked
Coating Category
g VOC/l lb VOC/gal g VOC/l lb VOC/gal
Extreme High Gloss 340 2.8 360 3.0
Extreme Performance 420 3.5 360 3.0
Heat-Resistant 420 3.5 360 3.0
Metallic 420 3.5 420 3.5
Pretreatment Coating 420 3.5 420 3.5
Solar-Absorbent 420 3.5 360 3.0
Other Coatings: Multi-Component 340 2.8 275 2.3
Other Coatings: One-Component 275 2.3 275 2.3
Strippable Booth Coating 240 2.0  
Table 336-5: Coating VOC Limits for Paper, Fabric, Film, Foil, and Vinyl Coatings
kg VOC/kg kg VOC/kg g lb
Coating Solids VOC/l VOC/gal
Coating Category
(lb VOC/lb (lb VOC/lb
solids) solids)
Fabric   350 2.9
Paper, Film, and Foil
Coating (Including
Adhesives, Not
0.08 0.40  
Including Pressure
Sensitive Tape and Label
Coatings)
Pressure Sensitive Tape
and Label Coating 0.067 0.20  
(Including Adhesives)
Vinyl   450 3.8
Strippable Booth Coating   240 2.0

Table 336-6: VOC Limits for Pleasure Craft Coatings
Coating Category g VOC/l lbs VOC/gal
Antifoulant Coating – Aluminum Substrate 560 4.7
Antifoulant Coating – Non-Aluminum Substrate 330 2.8
Extreme High Gloss Topcoat 490 4.1
Finish Primer/Surfacer 420 3.5
High Build Primer/Surfacer 340 2.8
High Gloss Topcoat 420 3.5
Pretreatment Wash Primer 780 6.5
All Other Pleasure Craft Coatings for Metal or Plastic 420 3.5
Strippable Booth Coating 240 2.0
Table 336-7: VOC Limits for Industrial Adhesives
Adhesive Category g VOC/l lbs VOC/gal
Specialty Industrial Adhesives
Ceramic Tile Installation 130 1.1
Contact Adhesive 250 2.1
Cove Base Installation 150 1.3
Floor Covering Installation (Indoor) 150 1.3
Floor Covering Installation (Outdoor) 250 2.1
Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 660 5.5
Metal to Urethane/Rubber Molding or Casting 850 7.1
Motor Vehicle Adhesive 250 2.1
Motor Vehicle Weatherstrip Adhesive 750 6.3
Multipurpose Construction 200 1.7
Plastic Solvent Welding (ABS) 400 3.3
Plastic Solvent Welding (Except ABS) 500 4.2
Sheet Applied Rubber Lining Adhesive 850 7.1
Single-Ply Roof Membrane Installation/Repair (Except
250 2.1
EPDM)
Structural Glazing 100 0.8
Thin Metal Laminating 780 6.5
Tire Repair 100 0.8
Waterproof Resorcinol Glue 170 1.4
Other Industrial Adhesives Used to Bond*
Reinforced Plastic Composite 200 1.7
Flexible vinyl 250 2.1
Metal 30 0.3
Porous Material (Except Wood) 120 1.0
Rubber 250 2.1
Wood 30 0.3
Other Substrates 250 2.1
Industrial Adhesive Primers
Motor Vehicle Glass Bonding Primer 900 7.5
Plastic Solvent Welding Adhesive Primer 650 5.4
Single-Ply Roof Membrane Adhesive Primer 250 2.1

Adhesive Category g VOC/l lbs VOC/gal
Other Adhesive Primer 250 2.1
* The applicable VOC limit for other industrial adhesives shall be determined based on composition of the substrates
that the industrial adhesive will be used to bond. If the industrial adhesive will be used to bond dissimilar substrates,
the higher VOC content shall apply.
302 APPLICATION METHODS FOR SURFACE COATINGS AND INDUSTRIAL
ADHESIVES:
302.1 An owner or operator shall use one of the following methods for all applications
of surface coating materials containing more than 2 pounds of VOC per gallon
(240 g/L), minus exempt compounds (VOC Regulatory as Applied), and for all
applications of industrial adhesives and industrial adhesive primers:
a. HVLP spray gun;
b. Electrostatic system;
c. A system that atomizes principally by hydraulic pressure, including “airless”
and “air assisted airless”;
d. Hand application methods, including but not limited to;
(1) Flow Coat;
(2) Roll Coat;
(3) Dip-Coating; or
e. Any method approved by the Administrator as HVLP-equivalent.
302.2 An owner or operator is allowed to use an application method other than that
described in Section 302.1 of this rule:
a. For applications of surface coating materials containing less than or equal to 2
pounds of VOC per gallon (240 g/L), minus exempt compounds (VOC
Regulatory as Applied).
b. For applications of surface coating materials containing more than 2 pounds of
VOC per gallon (240 g/L), minus exempt compounds (VOC Regulatory as
Applied) and for all applications of industrial adhesives, and industrial adhesive
primers:
(1) If VOC emissions from the application of surface coating materials,
industrial adhesives, and industrial adhesive primers are captured and
directed to an ECS complying with the provisions of Section 305 of this
rule; or
(2) If coating the inside of pipes and tubes with a wand-style applicator; or
(3) If using an airbrush or other small gun that has a reservoir capacity not
exceeding 250 cc (8.8 fl. oz.) and is used solely for detailing, lettering,
touch-up, and/or repair.
303 CLEANUP OF APPLICATION EQUIPMENT: An owner or operator shall comply
with the following when using VOC-containing material to clean application equipment:

303.1 Spray Gun Cleaning Requirements:
a. Clean spray guns without spraying or atomizing solvent with the gun.
b. Spray Gun Cleaning Machine: Use a spray gun cleaning machine that
complies with the following requirements unless the owner or operator
complies with the manual spray gun cleaning requirements in Section 303.2 of
this rule.
(1) General Requirements for Spray Gun Cleaning Machines: The spray
gun cleaning machine shall meet all of the following requirements:
(a) Be designed to clean spray guns.
(b) Have at least one pump that drives solvent through and over the spray
gun.
(c) Have a basin which permits containment of the solvent .
(d) Be kept in proper repair and free from liquid leaks.
(e) Be fitted with a cover.
(f) Be located on-site where the spray application occurs; and
(g) Be operated and maintained according to manufacturer’s or
distributor’s instructions.
(h) Porous Material:
(i) Do not clean nor use porous or absorbent materials to clean parts
or products in a cleaning machine. For the purpose of this rule,
porous or absorbent materials include, but are not limited to,
cloth, leather, wood, and rope.
(ii) Do not place an object with a sealed wood handle, including a
brush, in or on a cleaning machine.
(iii) Do not place porous or absorbent materials, including, but not
limited to, cloth, leather, wood, and rope in or on a cleaning
machine.
(i) Pressurized Air Lines: Pressurized air lines shall only be connected to
the spray gun cleaning machine if all of the following requirements are
met:
(i) The manufacturer’s operating manual for the gun cleaning
machine recommends the use of a pressurized air line during gun
cleaning;
(ii) The air pressure in the line does not exceed 10 psig or the
pressure recommended in the manufacturer’s operating manual
for the gun cleaning machine, whichever is lower;
(iii) The use of the air pressure line does not cause solvent to splash
outside of the gun cleaning machine;

(iv) The manufacturer’s operating manual for the gun cleaning
machine is available for the operator of the gun cleaning machine;
and
(v) The owner or operator of the gun cleaning machine makes the
manufacturer’s operating manual for the gun cleaning machine
available to the Control Officer upon request.
(2) Automatic Spray Gun Cleaning Machine: An automatic spray gun
cleaning machine shall have a self-covering or enclosing cover feature that
in the cover's closed position allows no gaps exceeding 1/8 inch (3 mm)
between the cover and the cabinet. This self-enclosing feature shall be
maintained and consistently cover or enclose to these gap limits.
(3) Non-Automatic Remote Reservoir Cleaning Machine: A non-
automatic remote reservoir cleaning machine shall meet all of the following
requirements:
(a) Drain solvent from the sink/work-space into a remote reservoir when
work-space is not in use;
(b) The reservoir shall not have cumulative total openings, including the
drain opening(s), exceeding two square inches in area; and
(c) The base of the sink/work-space may function as the reservoir's top
surface, as long as the fit/seal between sink base and reservoir
container allows the reservoir to meet the opening limits specified in
Section 303.1(b)(3)(b) of this rule.
303.2 Manual Spray Gun Cleaning Requirements: An owner or operator manually
cleaning spray guns shall comply with the following requirements:
a. Disassembled spray guns must be cleaned by non-mechanical, hand-held
method of application of cleaners.
b. If disassembled spray guns are soaked they shall remain covered at all times,
except when the application equipment is being handled in the container or
transferred into or out of the container.
304 WORK PRACTICES-HANDLING, DISPOSAL AND STORAGE OF VOC-
CONTAINING MATERIAL: An owner or operator of any surface coating operation,
industrial adhesive application process, or industrial adhesive primer application process
shall store, handle, and dispose of VOC-containing material in a manner that prevents the
evaporation of VOC to the atmosphere. Work practices limiting VOC emissions include, but
are not limited to, all of the following:
304.1 Cover and keep covered each VOC-containing material which is not currently in
use. Store all VOC-containing materials in closed or covered leak-free containers.
304.2 Store all VOC-containing materials intended for disposal including, but not limited
to, rags, waste coatings, waste brushes, waste rollers, waste applicators, waste
solvents, and their residues, in closed, leak free containers. The containers shall
remain covered with a leak tight cover, when not in use.

304.3 Minimize spills of VOC-containing coatings, thinners, and coating-related waste
materials.
304.4 Convey VOC-containing coatings, thinners, and coating-related waste materials
from one location to another in closed containers or pipes.
304.5 Containers in which VOC-containing materials are stored must have a legible label
identifying the container’s contents.
305 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS:
305.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 301.2
of this rule, an ECS shall be operated as follows:
a. Overall ECS Efficiency: The overall control efficiency of an ECS shall be
determined by multiplying the capture efficiency by the destruction efficiency
of the control device expressed as a percentage. An owner or operator, who
chooses to use an ECS instead of meeting the limits in Tables 336-1 through
336-6 of this rule and specified application methods, shall operate an ECS that
has a 90 percent overall ECS efficiency. An owner or operator, who chooses to
use an ECS instead of meeting the limits in Table 336-7 of this rule and the
specified application methods in Section 302 of this rule, shall operate an ECS
that has an 85 percent overall ECS efficiency.
b. Alternative for Very Dilute Input: For VOC input-concentrations of less
than 100 ppm (as methane) at the inlet of the ECS, the control efficiency is
satisfied if the VOC output is less than 20 mg VOC/m3(as methane) adjusted
to standard conditions.
305.2 Operation and Maintenance (O&M) Plan Required for ECS:
a. An owner or operator shall provide and maintain (an) O&M Plan(s) for any
ECS and any ECS monitoring devices used pursuant to this rule or to a
Maricopa County Air Quality Permit.
b. The owner or operator shall submit to the Control Officer for approval the
O&M Plans of each ECS and each ECS monitoring device used pursuant to
this rule.
c. The owner or operator shall comply with all identified actions and schedules
provided in each O&M Plan.
305.3 Providing and Maintaining ECS Monitoring Devices: An owner or operator
incinerating, adsorbing, or otherwise processing VOC emissions pursuant to this
rule shall provide, properly install and maintain in calibration, in good working
order devices described in the facility’s O&M Plan that indicate temperatures,
pressures, rates of flow, or other operating conditions necessary to determine if the
ECS is functioning properly and is properly maintained. Records shall be kept
pursuant to Section 502 of this rule which demonstrate that the ECS meets the
overall control standard required by Section 305.1 of this rule and is operated in
accordance with the equipment manufacturer's specifications.
305.4 O&M Plan Responsibility: An owner or operator of a facility that is required to
have an O&M Plan pursuant to Section 305.2 of this rule must fully comply with

all O&M Plans that the owner or operator has submitted for approval, but which
have not yet been approved, unless notified otherwise by the Control Officer in
writing.
305.5 Operation and Maintenance (O&M) Plan Contents for an ECS: An O&M Plan
for any ECS including any ECS monitoring devices shall include all of the
following information:
a. ECS equipment manufacturer;
b. ECS equipment model;
c. ECS equipment identification number or identifier that owner or operator
subject to this rule assigns to such ECS equipment when manufacturer’s
equipment identification number is unknown; and
d. Information required by Sections 502 and 503 of this rule.
SECTION 400 – ADMINISTRATIVE REQUIREMENTS
401 COMPLIANCE SCHEDULE ECS INSTALLATION: An owner or operator installing
an ECS as an alternative to complying with the VOC limits in Section 301.1 of this rule shall:
401.1 Implement all recordkeeping provisions, including Section 502 of this rule, upon
adoption of this rule.
401.2 Notify the Control Officer in writing that an ECS will be installed and used as an
alternative to meeting the VOC limits of Section 301.1 of this rule by [insert date –
3 months after rule adoption].
401.3 Attain full compliance with all applicable standards in this rule by [insert date – 12
months after rule adoption].
402 COMPLIANCE SCHEDULE FOR NEW VOC LIMITS: Upon adoption of this rule,
the owner or operator shall discontinue purchase of materials that are non-compliant with
the VOC limits in Tables 336-1 through 336-7 of this rule. For materials that are subject to a
lower VOC limit upon adoption of this rule, the owner or operator may continue to use
supplies of non-compliant materials purchased prior to [insert date of rule adoption] until
[insert date – 6 months after rule adoption].
SECTION 500 – MONITORING AND RECORDS
501 RECORDKEEPING AND REPORTING: An owner or operator shall comply with the
following recordkeeping requirements:
501.1 Records shall be retained for five years and shall be made available to the Control
Officer without delay upon verbal or written request.
501.2 Current Lists: Maintain a current list of coatings, industrial adhesives, industrial
adhesive primers, cleaning materials or any other VOC-containing materials
regulated by this rule. The list:
a. Shall express VOC content in one of the following forms:
(1) Pounds VOC per gallon;

(2) Grams VOC per liter; or
(3) The percent VOC by weight along with the specific gravity or density.
b. Shall have the written value of the VOC content, in one of the following
forms. The documentation must provide accurate VOC content values or be
based on enforceable test methods as approved by the Administrator to
determine the VOC content.
(1) A manufacturer’s technical data sheet;
(2) A manufacturer’s safety data sheet (SDS or MSDS); or
(3) Actual test results.
c. Shall include usage or purchase records as follows:
(1) Monthly: Records of the amount of VOC-containing materials purchased
or used shall be totaled by the end of the month for the previous month.
This includes, but is not limited to, all coating materials, all industrial
adhesives, all industrial adhesive primers, all materials added during
preparation of coatings or adhesives, all materials used to clean application
equipment, and all materials used to clean application areas.
(2) Grouping by VOC Content: For purposes of recording usage, an owner
or operator may give VOC coatings, cleaners, and solvents of similar VOC
content (VOC Regulatory) a single group-name, distinct from any product
names in the group. The total usage of all the products in that group is
then recorded under just one name. In such a case, the owner or operator
must also keep a separate list that identifies the product names of the
particular VOC-containing materials included under the group name. To
the group name shall be assigned the highest VOC content (VOC
Regulatory) among the members of that group, rounded to the nearest
tenth of a pound of VOC per gallon of material or to the nearest gram
VOC per liter of material.
d. Shall make the following listings for all materials that have VOC limits listed in
Tables 336-1 through 336-7 of this rule:
(1) VOC Before Reducing: The VOC content of each coating, industrial
adhesive, and industrial adhesive primer as received.
(2) List Maximum VOC Content of Coating as Applied: For each coating,
industrial adhesive, and industrial adhesive primer that is thinned/reduced
or to which additive is introduced, record in a permanent log the VOC
content (VOC Regulatory) after mixing the maximum amount of
thinner/reducer and other additives. This log will include the following:
(a) The maximum number of fluid ounces thinner/reducer added to a
gallon of unreduced coating, unreduced industrial adhesive, or
unreduced industrial adhesive primer (or maximum g/liter) and the
maximum fluid ounces of every other additive mixed into a gallon of
the coating, industrial adhesive, or industrial adhesive primer; or

(b) The VOC content (VOC Regulatory) of the coating, industrial
adhesive, or industrial adhesive primer after adding the maximum
amount of thinner/reducer and other additives.
e. Shall include usage or purchase records for aerosol can spray coating, including
VOC content.
502 ECS RECORDING REQUIREMENTS: An owner or operator shall maintain all of the
following records in accordance with an approved O&M Plan for any ECS:
502.1 On each day an ECS is used at a facility pursuant to this rule, the owner or
operator shall make a permanent record of the key system operating parameters as
required by the O&M Plan including, but not limited to, the following:
a. Flow rates;
b. Pressure drops;
c. Temperature; or
d. Other operating conditions necessary to determine if the approved ECS is
functioning properly.
502.2 An explanation shall be recorded for periods of time an approved ECS is not
operating.
502.3 For each day or period the O & M Plan requires maintenance, the owner or
operator shall make a permanent record of the maintenance actions taken within
24 hours of the maintenance completion.
502.4 Corrective action taken, if any.
502.5 An explanation shall be entered for scheduled maintenance that is not performed
during the period designated for it in the O&M Plan.
503 COMPLIANCE DETERMINATION AND TEST METHODS:
503.1 Compliance Determination:
a. VOC regulatory of materials subject to Section 301 or Section 302 of this rule,
excluding reactive industrial adhesives, shall be determined using one of the
following methods and shall be reported on the manufacturer’s technical data
sheet, the manufacturer’s safety data sheet, or on an analytical report from an
accredited laboratory:
(1) The method in Section 503.2(c) of this rule (EPA Method 24);
(2) The method in Section 503.2(g) of this rule (SCAQMD Method 313-91); or
(3) The method in Section 503.2(f) of this rule (SCAQMD Method 304-91).
b. VOC regulatory of reactive industrial adhesives subject to Section 301 or 302
of this rule, shall be measured using the method in Appendix A of the
NESHAP for Surface Coating of Plastic Parts and Products (40 CFR 63,
Subpart PPPP) and shall be reported on the manufacturer’s technical data
sheet, the manufacturer’s safety data sheet, or on an analytical report from an
accredited laboratory.

c. An owner or operator that complies with Section 301 or 302 of this rule using
an ECS shall demonstrate compliance using the following methods and
equations:
(1) Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100
where,
EffO = overall ECS efficiency expressed as a percentage;
EffCo = ECS control efficiency expressed as a percentage; and
EffCa = ECS capture efficiency expressed as a percentage.
(2) The ECS control efficiency shall be determined by measuring the VOC
content of gaseous emissions entering and exiting the ECS using the
method in Section 503.2(b) of this rule (EPA Method 18) or one of the
methods in Section 503.2(d) of this rule (EPA Method 25, 25a, or 25b) .
(3) The ECS capture efficiency shall be determined using one of the methods
in Section 503.2(e) of this rule (EPA Method 204, 204a, 204b, 204c, 204d,
204e, or 204f ) and EPA’s “Guidelines for Determining Capture Efficiency
(January 9, 1995)”, or by using mass balance in combination with
ventilation/draft rate determinations made using one of the methods in
Section 503.2(a) of this rule (EPA Methods 2, 2a, 2c, or 2d).
d. Measurement of air pressure at the center of the spray gun tip of an air-
atomizing spray gun shall be performed using an attachable device supplied by
the gun's manufacturer for performing such a measurement. The device
supplied by the gun’s manufacturer shall be in proper working order and kept
on-site at the location where the gun is used.
e. Temperature measurements shall be done using an instrument that is accurate
to within 0.5°F (0.25°C) for temperatures up to 480°F (250°C).
503.2 Compliance Determination-Test Methods Incorporated by Reference: The
following test methods are approved for use for the purpose of determining
compliance with this rule. The test methods are incorporated by reference in
Appendix G of the Maricopa County Air Pollution Control Regulations.
Alternative EPA-approved test methods may be used upon prior written approval
from the Control Officer. When more than one test method is permitted for the
same determination, an exceedance under any method will constitute a violation.
Copies of test methods referenced in this section are available at the Maricopa
County Air Quality Department.
a. EPA Methods 2 (“Determination of Stack Gas Velocity and Volumetric Flow
Rate (Type S Pitot Tube)”), 2a (“Direct Measurement of Gas Volume Through
Pipes and Small Ducts”), 2c (“Determination of Stack Gas Velocity and
Volumetric Flow Rate in Small Stacks or Ducts (Standard Pitot Tube)”), and
2d (“Measurement of Gas Volume Flow Rates in Small Pipes and Ducts”) (40
CFR 60, Appendix A).

b. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions
by Gas Chromatography”) (40 CFR 60, Appendix A).
c. EPA Test Method 24 (“Determination of Volatile Matter Content, Water
Content, Density, Volume Solids, and Weight Solids of Surface Coatings”) (40
CFR 60, Appendix A).
d. EPA Method 25 (“Determination of Total Gaseous Non-methane Organic
Emissions as Carbon”), 25a (“Determination of Total Gaseous Organic
Concentration Using a Flame Ionization Analyzer”), and 25b (“Determination
of Total Gaseous Organic Concentration Using a Nondispersive Infrared
Analyzer”) (40 CFR 60, Appendix A).
e. EPA Test Methods 204 (“Criteria for and Verification of a Permanent or
Temporary Total Enclosure”), 204a (“Volatile Organic Compounds Content in
Liquid Input Stream”), 204b (“Volatile Organic Compound Emissions in
Captured Stream”), 204c (“Volatile Organic Compound Emissions in Captured
Stream (Dilution Technique)”), 204d (“Volatile Organic Compound Emissions
in Uncaptured Stream from Temporary Total Enclosure”), 204e (“Volatile
Organic Compound Emissions in Uncaptured Stream from Building
Enclosure”), and 204f (“Volatile Organic Compounds Content in Liquid Input
Stream (Distillation Approach)”) ( 40 CFR 51, Appendix M).
f. California’s South Coast Air Quality Management District (SCAQMD) Method
304-91 (February 1996).
g. SCAQMD Method 313-91 (April 1997) “Determination of Volatile Organic
Compounds (VOC) by Gas Chromatography/Mass Spectrometry (GC/MS)”.
h. EPA Test Method for Determination of Weight Volatile Matter Content and
Weight Solids Content of Reactive Adhesives (40 CFR 63, Subpart 63,
Appendix A to Subpart PPPP).

MARICOPA COUNTY BOARD OF HEALTH MEETING MINUTES
Monday, April 23, 2018 at 3:00 pm
301 W. Jefferson Street, 10th Floor
Phoenix, Arizona 85003
Board of Supervisors Conference Room
Vice President Hughes called the meeting to order at 3:05 p.m. Return to list of attachments
ROLL CALL:
Members Present: Members Not Present:
Don Cassano Kip Steill
Robert MacMillan Henri Cournand
Kristen Acton (via phone) Bill Gates
Nedra Halley
Don Hughes
Debra Baldauff
Ex-Officio: Max Porter
CALL TO THE PUBLIC:
Vice President Hughes announced that we have speaker slips for anyone wishing to speak on any action items.
Speakers will be called after the item is heard. Each speaker will have 2 minutes to speak.
DISCUSSION/ACTION ITEMS
1. Approval of Minutes: Vice President Hughes asked for a motion to approve the minutes from the BOH Meeting
held on February 2. 2018. Motion was made by Ms. Halley to approve the BOH minutes as presented. Motion
was seconded by Mr. MacMillan and all were in favor. The motion passed unanimously.
2. Fee Waiver Applications Ms. Jeannie Taylor
Ms. Jeannie Taylor presented thirty-three (33) fee waivers for review and consideration of approval. A summary
sheet document was provided.
Motion to approve the thirty-three (65) fee waiver applications was made by Dr. Baldauff, seconded by Mr.
MacMillan and all were in favor. The motion passed unanimously.
3. Approval of the Expedited Process Rulemaking for Rule 336 (Surface Coating Operations) Mr. Philip A. McNeely
Greg Verkamp
AQ-2017-008-Rule 336 (Surface Coating Operations): The Maricopa County Air Quality Department
is proposing to revise Rule 336 to address Environmental Protection Agency comments to ensure
the revised rule meets Reasonably Available Control Technology (RACT) requirements as
required by the Clean Air Act.
• Purpose: To limit the emission of volatile organic compounds (VOCs) from surface
coating operations
• Sources: Applies to a wide variety of sources
– Can Coating, Plastic Parts Coating, Metal Furniture Coating
• Requirements: Vary based on the substrate and the type of coating, but may include:
– Coating VOC Limits
– Application Methods
– Emission Control Systems

– Work practices for coating and cleaning
Purpose of Revisions:
• Change requested by EPA
• Maricopa County reclassified to a “moderate” ozone nonattainment area in 2016
• Required to implement Reasonable Available Control Technology (RACT) for sources of
VOCs
• Revised the rule to incorporate RACT
– Revised rule adopted in November 2016
– In July 2017, the EPA informed Maricopa County Air Quality Department
(MCAQD) the VOC limits for several categories of can coatings in the revised
rule did not meet RACT
• EPA requested VOC limits be lowered to meet RACT
• MCAQD is proposing to include the lower limits in the rule (Table 336-
2)
• New limits affect two facilities (same owner)
• Facilities already in compliance with proposed VOC limits
• Subject to more stringent federal regulations
• Change requested by a stakeholder
– After 2016 rulemaking was completed, a stakeholder contacted MCAQD
regarding the rule revision
– Further research determined a VOC limit for Sheet Applied Rubber Lining
Adhesives should be included in the rule
• MCAQD is proposing to include new limit in the rule (Table 336-1)
• New limit meets RACT
• New limit affects one facility
• Facility already in compliance with proposed VOC limit
• Minor changes to increase clarity and correct typographical errors
– Restructuring of some of the tables
Rulemaking Process:
• Workshop held on March 8, 2018
– No opposition comments received
• Held a conference call with EPA on March 21, 2018
• Received additional information from EPA on April 9, 2018
• MCAQD will conduct additional Stakeholder Workshops to address EPA comments
Expedited Rulemaking:
• To date, MCAQD has not received any opposition comments to the rulemaking
• MCAQD requests approval of expedited process rulemaking
There was 1 request for public comment received.
- Chris Andrews request to speak on this item. He came to ask for more time and from the presentation
he realized the item was only for the process not to approve the Rule.
Motion to Approve of the Expedited Process Rulemaking for Rule 336 (Surface Coating Operations) was made
by Mr. MacMillan, seconded by Mr. Cassano and all were in favor. The motion passed unanimously.

Discussion Items:
1. Public Health Report Max Porter and Dr. Rebecca Sunenshine
i. Human Resources
ii. Communication
iii. Infrastructure
iv. Strategic Planning
v. Programs
vi. Disease Update
vii. Future Topics
Dr. Sunenshine went over the following:
 Increase we have seen in STD’s and the reason costs have gone up.
 MCDPH Office of Preparedness and Response held a Point of Dispensing (POD) drill at Basha High School
in Chandler.
 Vaccination requirement changes (Shingles and Flu – non-egg based vaccine)
Max went over the following:
 Search for a new director
 WIC Program – case load reduced cut of $411,000 in program. WIC services virtually (eWIC)
 Vitals DAVE System – Funeral Home Partners
 TB Case being released back to her home as long as she remains compliant
 New Grant – Youth Mapping in Maryvale
 Omnibus bill
 Pending Teacher Strike & possible impact on services due to possible employee absence
ANNOUNCEMENTS AND CURRENT EVENTS
 Next meeting is July 23, 2018
ADJOURNMENT: There being no further business, motion to adjourn the meeting was made by Ms. Halley, seconded
by Mr. MacMillan and motion was passed unanimously. The meeting was adjourned at 3:56p.m.

MARICOPA COUNTY BOARD OF HEALTH MEETING MINUTES
Monday, April 26, 2021, at 3:00 PM
Virtual Meeting due to COVID-19 and social distancing guidelines
President MacMillan called the meeting to order at 3:00 p.m.
ROLL CALL:
Members Present: Members Absent: Kristen Acton
Supervisor Bill Gates
Debra Baldauff
Don Cassano
Paul Stander
Paula Banahan
Robert MacMillan
Robin Schaeffer
Scott Celley
Ex-Officio: Marcy Flanagan
1. CALL TO ORDER President MacMillan
A. Roll Call
B. Call to the Public
President MacMillan asked if there was anyone from the public that wanted to address the Board. Ms. Sampler
responded that there were no requests known to speak at this time and informed all that they would have the
opportunity to type them in the question section, to be acknowledged during or after the meeting accordingly.
DISCUSSION/ACTION ITEMS:
2. Approval of Minutes President MacMillan
President MacMillan asked for a motion to approve the minutes from the Board of Health (BOH) meeting held
on January 26, 2021. A motion was made by Mr. Celley to approve the BOH minutes as presented. Mr.
Cassano seconded the motion. The motion passed unanimously.
3. Approval of the Board of Health Bylaws and make a recommendation to the Board of Supervisors to
approve revisions President MacMillan
Members acknowledged receipt of the revised bylaws. A discussion was had concerning Article III Section 8;
Power and Duties, which advises that the Board shall review the Health Status report for Maricopa County
annually. Future agendas will include an annual discussion of the Public Health status and Ms. Flanagan will
update the board at a future meeting. A motion was made by Mr. Cassano to approve the BOH bylaws as
presented. Ms. Banahan seconded the motion. The motion passed unanimously.

4. Appointment of two members to the Board of Health Finance Committee President MacMillan
Article VI Section 2; Standing Committees advises that the finance committee shall consist of the President, Vice
President-Finance, two At-large members and one shall be a physician. President MacMillan asked members if
there was any interest in serving on the Finance Committee for 2 years. Current members were acknowledged,
Dr. Stander and Ms. Schaffer were appointed as finance committee members. A motion was made by Mr.
Cassano to approve the BOH bylaws as presented. Ms. Baldauff seconded the motion. The motion passed
unanimously.
5. Public Health Finance Update – 3rd Qtr FY21 Mr. Scot Pitcairn
Mr. Pitcairn provided the Board with an update of Public Health’s fiscal year 2021 – 3rd Quarter Budget Status
report for:
• Fund 100 – General Fund
• Fund 200 – Coronavirus Fund/CARES Act Funding
• Fund 265 – Special Revenue Fund
• Fund 532 - Grant Fund
(refer to agenda packet for PHS finance memo and report summary)
A discussion was had concerning Fund 200 to better understand the recovery ACT and spending. Mr. Porter
explained the CARES ACT funding extends to December 2021; however, funds are expected to be expended by
June 30. The recovery dollars were already added to the county for next year's budget. Ms. Bohn provided
additional insight. The intent is to have the monies fully spent by end of June; Maricopa County has prioritized
the pandemic response with said funds. The new American rescue plan act funds, Maricopa County is slated to
receive about 870 million, with the first half expected within the next two weeks, federal guidance will detail
how funds are to be used. Additional funds are expected for use for non-related pandemic events.
Arizona is expecting 4.8 billion, a lot of the funds are dedicated towards vaccines, contract tracing, and other
Public Health specific programs. It’s expected that a portion of said funds will flow down to Public Health
agencies. It’s expected that Public Health will have a lot of opportunities to put programs into place.
Mr. Porter further explained that a lot of the funds will be expended through the grant dollars coming into the
department. The above baseline general funds will be ongoing dollars year after year. Most of the funds will be
expended through the department. Some items are already established through the CARES ACT funding. The
budget office is recommending keeping those General Fund positions on an ongoing basis beyond the COVID
grant dollars.
President Macmillan asked if there was both a motion to approve the Public Health finance report and if
anyone wanted to make a recommendation to the Board of Supervisors to approve the Public Health FY22
budget request as recommended by the Maricopa County Budget Office. Ms. Schaffer made a motion to
approve the budget as presented, Mr. Cassano seconded the motion. The motion passed unanimously.
A recommendation for the Board of Supervisors to approve the Public Health FY22 budget was made by Ms.
Schaffer and seconded by Mr. Cassano. The recommendation passed unanimously.

6. Environmental Services Finance Update – 3rd Qtr FY21 Mr. Ryan Hautzinger
Mr. Hautzinger provided the Board with an update of Environmental Services fiscal year 2021 – 3rd Quarter
Budget Status report for:
• Fund 100 - County General Fund
o The fund is reporting under the YTD budget through Period 9 close FY21.
• Fund 290 – Environmental Tire Fund
• Fund 506 – Environmental Fee Fund
• Approval of FY 22 OMB Budget Request
o Fund 100 – County General Fund
o Fund 290 – Environmental Tire fund
o Fund 506 Environmental Fee Fund
There were no questions asked pertaining to the report as presented.
President Macmillan asked if there was both a motion to approve the Environmental Services finance report
and if anyone wanted to make a recommendation to the Board of Supervisors to approve the Environmental
Services FY22 budget request as recommended by the Maricopa County Budget Office. Mr. Celley made a
motion to approve the budget as presented, and Mr. Cassano seconded the motion. The motion passed
unanimously.
A recommendation for the Board of Supervisors to approve Environmental Services FY22 budget was made by
Mr. Celley and seconded by Mr. Cassano. The recommendation passed unanimously.
(refer to agenda packet for finance summary)
7. Air Quality Department – Make a recommendation to the Board of Supervisors to approve the proposed
revisions to the following rules:
A. AQ-2017-007
Rule 322 (Power Plant Operations)
Rule 323 (Fuel Burning Equipment from Industrial/Commercial/Institutional (ICI) Sources)
Rule 324 (Stationary Reciprocating Internal Combustion Engines (RICE)).
Mr. Verkamp explained each rule as presented. The department is proposing to revise these rules, to
address rule deficiencies identified by the EPA. Proposed revisions are required to secure the approval
of the rules as part of the Arizona State Implementation Plan under the Federal Clean Air Act. The
Department's also proposing revisions to address recommendations provided by the EPA, incorporate
revisions recommended by stakeholders and make revisions to improve and clarify the rules. The
department has held stakeholders’ workshops for all the rules to discuss the proposed revisions with
stakeholders’. Notices of the rulemakings were posted on the Maricopa County Enhanced Regulatory
Outreach Program website, for stakeholders to review and comment on the revisions.
The Air Quality Department received a public comment shortly before the posting deadline for their
reports, revisions to address the comment were forwarded to all board members earlier today.
Specifically, the department added language to Section 102.1 D regarding the applicability of the non-
road engine records requirement in Rule 324, basically narrowing it down to just those types of
engines that are kind of like generators. The department advised that they didn't want to be regulating
non-road engines such as backhoes and bulldozers. A revision to Section 502.6 of Rule 324 was also
made. It now reads as follows: An owner-operator of a non-road engine shall maintain the following

records for each non-road engine. A, date that each engine is brought to the stationary source, and B,
for are engines located at a stationary source greater than 14 consecutive days.
• Owners must maintain records of the make model, serial number, and rated capacity of the
engine.
• The date of each instance in which the engine is moved from its existing location, and the
reason why the engine was moved; and
• Fuel type and sulfur content of the fuel
The language “for engines located at the stationary source greater than 14 consecutive days”, was
added to limit the record-keeping requirement for those non-road engines such as rentals – so of
stakeholders not having to keep all these records for just a rental generator that came and went off on-
site, very quickly. The department spoke with the stakeholder who submitted this comment last week
and they were satisfied with the revisions that we made to address their concerns. Additional
discussions were had concerning ASU turbine and which rule their equipment falls under.
President MacMillan asked if anyone wanted to make a recommendation to the Board of Supervisors to
approve the revisions to Rule 322, as presented. The recommendation was made by Ms. Schaffer and
seconded by Mr. Cassano . The recommendation passed unanimously.
President MacMillan asked if anyone wanted to make a recommendation to the Board of Supervisors to
approve the revisions to Rule 323 as presented. The recommendation was made by Ms. Schaffer and
seconded by Mr. Cassano. The recommendation passed unanimously.
President MacMillan asked if anyone wanted to make a recommendation to the Board of Supervisors to
approve the revisions to Rule 324 as presented. The recommendation was made by Ms. Schaffer and
seconded by Mr. Cassano. The recommendation passed unanimously.
The Air Quality Department respectfully asks the Board to approve their request of a recommendation
to the Board of Supervisors to approve the revisions to Rule:
B. AQ-2017-008
Rule 336 (Surface Coating Operations)
A discussion was had about changes with Rule 336. The department had no oppositions or comments on Rule
336. The proposed rulemaking will be published as a part of the Report to the Board of Supervisors on the EROP
website for a public comment period before the public hearing.
President MacMillan asked if anyone wanted to make a recommendation to the Board of Supervisors to
approve the revisions to Rule 336 as presented. The recommendation was made by Ms. Schaffer and
seconded by Mr. Cassano. The recommendation passed. There was one Nye by Mr. Macmillan.
Air Quality Department requests Board of Health approval of the expedited process rulemaking for Rule
370.
C. AQ-2019-003
Rule 370 (Federal Hazardous Air Pollutant Program)
President MacMillan asked if there was a motion to approve the expedited process rulemaking for Rule 370 as
presented. Ms. Schaffer made a motion to approve the expedited process rulemaking for Rule 370 and Mr.
Cassano seconded the motion. The motion passed unanimously.

8. Fee Waiver Applications – Twenty-three (23) permit fee waivers Mr. Ken Conklin
Fee Waiver Application Summary Sheet and Fee Waiver Staff Report
(refer to agenda packet for memo and finance summary)
Mr. Conklin presented a summary of documents previously distributed to the Board on the 23 Permit Fee
Waiver applications and referred all to the Fee waiver Application Summary sheet and Staff Report, noting that
all 23 met the Maricopa County Environmental Services Health Code Chapter 1. Regulation 5. Only an operator
of a charitable non-profit establishment, which operates to provide relief to the solely distressed or
underprivileged my apply to the Board of Health for the waiver of a permit fee. A waiver may be granted only if
the operator maintains a current 501 (c)3 tax-exempt status. This demonstrates that the payment of the said fee
will cause financial hardship. The Board was asked to approve P1-P20 and C1-C3 on the fee waiver applications
submitted.
President MacMillan asked if there was a motion to approve the 23 fee waiver applications presented as P1
through P20 and C1 through C3. A Motion was made by Mr. Celley to approve the 23 fee waiver permits and
seconded by Mr. Cassano. All were in favor, the motion carried.
Discussion Items
9. Public Health Report Marcy Flanagan
I. Human Resources
II. Communications
III. Infrastructure
IV. Strategic Planning
V. Programs
VI. Disease Update
VII. Future Topic
Coronavirus/Covid-19 Pandemic Updates
National Summary
• Cases to date - 31,660,546
• 7 day case rate per 100,000 is - 132
• Death total – 566,494
Ms. Flanagan provided that the US today increased by 60, just over 62,000 new cases, 875 new deaths today.
Maricopa County Summary
• Cases to date
• 7 day case rate per 100,000 is – 78 (lower than National average) 67 per 100,000. So, our case
rate increased slightly over the past two weeks are positive cases.
• 6% PCR positive cases in Maricopa County

Maricopa County is slowly reaching herd immunity, and about 80% of adults, 65 and older have received at least
one dose of a vaccine.
• The daily average of vaccines is 30,000
• Higher incidence of ethnic minorities receiving the vaccine
• Uniting with local community partners to get residents vaccinated in hard-to-reach minority
populations.
There's still not a definitive percentage that we have to get to reach herd immunity, most reports advise
between 80-90 percent. There’s still a long way to go, appointments are declining, some people choose not to
receive their second dose.
Efforts to push getting vaccinated
• Maricopa County developing a Communications Department
• Both State and National level about are already in the works with communications
Vaccine Allocations
• Several States are beginning to turn down allotments due to their numbers of interest declining,
including Arizona.
• Smaller counties turned down allocations
• Increase in Maricopa County allocation with Johnson and Johnson vaccine
• FDA and CDC paused the Johnson and Johnson vaccine – a rare side effect of blood clots for
some individuals, production and vaccination resumed as of Friday, while the CDC, FDA, and
ACIP work on a case definition that will help further identify any potential cases.
• Fact sheets will be provided for the vaccine at appointments
Variants
• The most common variant in the world is the B-117 Lineage
• B-117 accounts for Forty-four percent of cases seen
• Variant B-1429 counts for about seven percent of all cases in California
• Common cases in Arizona are the B-117
• No new variants are known
Vaccine appointments - Maricopa County has a goal to bring vaccines to groups that have difficulty with
making or getting appointments. This includes those who may have mobility restrictions, vulnerable
communities' economic or cultural language disadvantages. A list is maintained to alert people of available
appointments, Maricopa County COVID-19-Vaccine-Locations which allows residents to be alerted of pop-
up events.
• Homebound individuals - Maricopa County is currently using the one dose Johnson and Johnson
vaccine.
• Group homes and behavioral homes are being vaccinated
• Farms – vaccine events are also ongoing (one dose vaccine)
• Pop up PODs in the Refugee communities Islamic and Asian Pacific Islander community
• Partnering with Arizona Partnership Immunization
• Assistance for those who have vaccine hesitancy in the communities can visit
www.whyimmunize.org

Mask Mandate
A discussion was had regarding masks and in-school learning and other Executive Orders. Maricopa County
businesses are mostly requiring masks.
• Masks are optional in schools’ districts
• Bulling is on the rise with those students who choose to mask up
• ADE is partnering with Maricopa County for discussions
• Masks are highly encouraged when you are unable to socially distance
• CDC recommends wearing face masks when you are unable to socially distance
• Maricopa County does not require a mask mandate
• Cities and counties had an option to require a mask mandate
• There was not a State-wide mandate
Supervisor Gates leads a discussion to allow for additional insight into Maricopa County mask mandates. Within
48 hours of Governor Ducey issuing an Executive Order about mask mandates, the Maricopa County Board of
Supervisor believed that that order effectively ended Maricopa County mask mandate. Maricopa County Board
of Supervisors never voted to end the mask mandates, however, as operations of law, the belief was that it
ended the mask mandate. All Maricopa County buildings require the use of masks. Discussions were had about
the pandemic.
MCDPHS - Annual Report
Non- related COVID-19 matters
• Public Health is focusing on data collections on health status in the community regards to health
changes since COVID-19
• Data from the Office of the Medical Examiner and Arizona State suggests an increase in overdose
deaths, it’s unsure whether it’s related to the virus.
• Data shows an increase in STD’s
(Refer to media recording for a recap of the report)
Announcements and Current Events President/
Board Members
Board members requests that a Public Health status report for 2020 be added to the agenda for discussion.
Board members were reminded that any agenda item or suggestion must be emailed to Ms. Sampler requesting
to add the topic the agenda.
Adjournment President MacMillan
There being no further business, Dr. Stander made a motion to adjourn the meeting and Ms. Schaffer seconded
the motion. The motion passed unanimously. The meeting was adjourned at 5:38 p.m.

Copies of all written and electronic Stakeholder input
Return to list of attachments

From: Kathy Semder (COA)
Sent: Friday, July 24, 2020 12:00 PM
To: Michelle Mada (AQD); Kimberly Butler (AQD); Gregory Verkamp (AQD)
Subject: FW: Online Form Submittal: Citizen Comments
Attachments: ACA Comments - Maricopa County AQD Rule 336.pdf
FYI – Please see the attachment for their comments.
Thank you,
Kathy Semder
Ombudsman
From: noreply@civicplus.com <noreply@civicplus.com>
Sent: Friday, July 24, 2020 11:01 AM
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (COA) <Kathy.Semder@Maricopa.Gov>; Andy
Linton (COA) <Andy.Linton@Maricopa.Gov>; Bill Leal (FCD) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (PND)
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (AQD) <Blanca.Caballero@Maricopa.gov>
Subject: Online Form Submittal: Citizen Comments
Citizen Comments
Each Regulatory Department is committed to providing opportunities for
stakeholder input regarding the adoption and amendment of all regulatory
requirements. Your input will be collected and forwarded to the appropriate
department. You will receive a written response from the applicable department
within two business days. We appreciate your comments and your time.
Case Number/Rule AQ-2017-008 Rule 336 Surface Coating Operations
Department Air Quality
I would like to Other
First Name Rhett
Last Name Cash
Organization American Coatings Association
City Washington
Zip 20001

Email rcash@paint.org
Phone Number 2027746092
Phone Type Work
Would you like someone to Field not completed.
contact you?
Comments Please see attached for comments from the American Coatings
Association (ACA). Thank you for your consideration.
Rhett Cash
If applicable, attach ACA Comments - Maricopa County AQD Rule 336.pdf
supporting documentation
associated with your
comment. The only file
types supported are MS
Office and Adobe Acrobat.
Email not displaying correctly? View it in your browser.

July 24, 2020
Maricopa County Air Quality Department
3800 North Central Avenue, Suite 1400
Phoenix, Arizona 85012
Dear Maricopa County Air Quality Department (MCAQD):
The American Coatings Association (ACA)1 submits the following comments on MCAQD’s proposed
amendments to Rule 336 (Surface Coating Operations). ACA is a voluntary, nonprofit trade
association working to advance the needs of the paint and coatings industry and the professionals
who work in it. Notably, ACA represents a variety of marine coatings manufacturers and active
ingredient suppliers who sell pleasure craft coating products in Maricopa County, Arizona. Above all,
ACA and its member companies are committed to safeguarding the environment by providing only
top-quality marine coatings to recreational vessel owners.
Since 2010, ACA has worked diligently with MCAQD, the U.S. Environmental Protection Agency (EPA),
and other industry stakeholders to come up with a solution on how the county should move forward
with handling the VOC limits for the three pleasure craft coating categories. ACA agrees that MCAQD
should lower the following pleasure craft coating VOC limits to comply with the limits in EPA’s CTG:
• Extreme High Gloss Topcoat: 490 g VOC/l or 4.1 lbs VOC/gal
• Finish Primer/Surfacer: 420 g VOC/l or 3.5 lbs VOC/gal
However, we urge MCAQD to consider retaining the VOC limit for the following pleasure craft coating
category:
• Antifoulant Coating – Non-Aluminum Substrate: 400 g VOC/l or 3.4 lbs VOC/gal
ACA members require a reasonable amount of lead time to adjust formulations and supply chain
processes in order to ensure compliance with amended VOC limits, labeling, and reporting
requirements. ACA believes that industry needs additional time to comply with the proposed lowered
limit for Antifoulant Coating – Non-Aluminum Substrate. Furthermore, at the proposed EPA CTG level
(330 g VOC/l), consumers will not have a wide range of options for these types of products and the
market will be limited. It takes many years to develop, test, and register a new antifouling coating. A
1 The American Coatings Association (ACA) is a voluntary, nonprofit trade association working to advance the needs of the paint and
coatings industry and the professionals who work in it. The organization represents paint and coatings manufacturers, raw materials
suppliers, distributors, and technical professionals. ACA serves as an advocate and ally for members on legislative, regulatory, and
judicial issues, and provides forums for the advancement and promotion of the industry through educational and professional
development services.
901 New York Avenue, NW – Suite 300 West | Washington, DC 20001 | 202-462-6272

limit of 400 g/L will ensure that industry can provide a full range of products for differing water types,
application temperatures, and fouling conditions.
In addition, our member believes that the limit for All Other Pleasure Craft Coatings for Metal or
Plastic category should be increased to 490 g VOC/l or 4.1 lbs VOC/gal to align with the Extreme High
Gloss Topcoat category. These types of coatings are applied to small parts of pleasure crafts and
would benefit from a higher VOC limit to be efficient.
ACA looks forward to working with MCAQD and other interested stakeholders on Rule 336 and hopes
that MCAQD will eventually make an informed decision that is in the best interests of its residents.
Thank you for your consideration of our concerns and please let us know if you have any questions.
Sincerely,
Katherine Berry Rhett Cash
Assistant Director, Sustainability & Environment Counsel, Government Affairs
kberry@paint.org rcash@paint.org

Subject: FW: Online Form Submittal: Citizen Comments
Attachments: RadTech Public Comments Rule 336.pdf
From: noreply@civicplus.com <noreply@civicplus.com>
Sent: Monday, May 3, 2021 2:00 PM
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (COA) <Kathy.Semder@Maricopa.Gov>; Andy
Linton (OBM) <Andy.Linton@Maricopa.Gov>; Bill Leal (OBM) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (OBM)
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov>
Subject: Online Form Submittal: Citizen Comments
Citizen Comments
Each Regulatory Department is committed to providing opportunities for
stakeholder input regarding the adoption and amendment of all regulatory
requirements. Your input will be collected and forwarded to the appropriate
department. You will receive a written response from the applicable department
within two business days. We appreciate your comments and your time.
Case Number/Rule AQ-2017-008 Rule 336 Surface Coating Operations
Department Air Quality
I would like to Other
First Name Rita
Last Name Loof
Organization RadTech International, North America
City Bethesda
Zip Field not completed.
Email rml93@verizon.net
Phone Number 909-240-0866
Phone Type Mobile
Would you like someone to Yes
contact you?
Comments Please see attached letter
If applicable, attach RadTech Public Comments Rule 336.pdf
supporting documentation
associated with your
comment. The only file
types supported are MS
Office and Adobe Acrobat.
Email not displaying correctly? View it in your browser.

Mr. Greg Verkamp
Planning Supervisor
Maricopa County Air Quality Department
3800 N. Central Avenue, Suite 1400 | Phoenix, AZ 85012
May 3rd, 2021
Re: Public Comments Rule 336—Surface Coating Operations
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 336 --
Surface Coating Operations.
Introducing RadTech and UV/EB/LED
RadTech International is the trade association for the Ultraviolet/ Electron Beam/Light Emitting
Diode (UV/EB/LED) industry. The organization represents over 800 members nationwide
involved in a myriad of markets ranging from solar panel manufacturing to finger nail polish.
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate. Instead, they are
specifically formulated to react to UV light or a beam of electrons. The nature of the process is
such that virtually no Volatile Organic Compounds (VOCs) are generated. The materials are
generally high viscosity and thus there are no regulatory concerns with generation of particulate
matter from spraying. Additionally, UV/EB processes are electric and thus do not produce
combustion contaminants such as NOx, SOx and Greenhouse Gases.
The South Coast Air Quality Management District has some of the most stringent air quality
regulations in the nation. In many of its rulemakings, the agency has recognized the
sustainability advantages, including energy efficiency, of ultraviolet and electron beam curing
technology. SCAQMD provides incentives to companies who convert to UV/EB through
exemptions from permitting and recordkeeping. The agency recognized UV/EB as Best
Available Control Technology for many industry sectors and the technology has recently been
included in the Statewide BACT Clearinghouse for the California Air Resources Board.
UV/EB technology meets the regulatory definition of “super-compliant” in the SCAQMD which
applies to coatings with a Volatile Organic Compound (VOC) content of less than 50 grams per
liter. RadTech holds a seat on the South Coast Air Quality Management Plan Advisory
Committee. Our Association provides input to the agency on how to achieve clean air goals and
implementation of UV/EB is one strategy which has been included in the Air Quality
Management Plan. The most recent AQMP now includes UV/EB as control strategy. According

to SCAQMD findings: “These programs may also provide manufacturers with incentives to
accelerate the deployment of cleaner technologies. Such an example is the use of energy-curing
technologies which includes ultraviolet light (UV), electron beam (EB), heat and light emitting
diode (LED) cured coatings.
The California State Senate has adopted a resolution recognizing the many benefits of ultraviolet
(UV) and electron beam (EB) technologies and the contributions of RadTech. The proclamation
acknowledges the “invaluable” contributions made by RadTech to the State of California and
beyond, and cites the Association’s ideals of community service. It commends RadTech for its
“outstanding commitment to improving the environment and economy through its programs.”
The Environmental Protection Agency has classified UV/EB technology as Lowest Achievable
Emission Rate. The EPA Control Techniques Guidelines documents state: “This technology is
gaining greater acceptance and, where applicable, achieves a near 100 percent reduction of VOC
emissions”.
With UV/EB technology, facilities can achieve emission reductions above and beyond those
required by even the most stringent of regulations. There is no need to install air pollution
control devices which may emit combustion contaminants such as Nitrogen Oxides or Sulfur
Oxides. The products do not contain Toxic Air Contaminants and have no secondary adverse
impacts such as emissions of greenhouse gases.
Requested Proposed Rule Language Changes
RadTecb believes that Rule 336 presents an opportunity for Maricopa County to achieve
voluntary emission reductions above and beyond those presently required in the rule, through
regulatory flexibility that will encourage conversion to UV/EB/LED.
Request for Exemption
Our materials are typically well below 50 grams/liter in VOC content which is minimal
compared to the proposed limits. We respectfully request that UV/EB/LED materials be
exempted from the rule requirements. An exemption would be an incentive for businesses to
voluntarily choose UV/EB/LED technology resulting in additional emission reductions for
Maricopa County.
Recordkeeping requirements are burdensome on businesses and in the case of UV/EB/LED
operations, are not crucial because the materials are well below the rule limits. Exempting
energy curable materials from overly prescriptive recordkeeping requirements will alleviate
regulatory burdens on the Maricopa County business community and benefit air quality.
Definition
We would very much appreciate the inclusion of a definition for energy curable materials in the
rule. We propose a definition like the one in SCAQMD rules:
ENERGY CURABLE MATERIALS are single component reactive products that cure upon
exposure to visible-light, ultraviolet light, or to an electron beam.

Test Method
The Environmental Protection Agency and the SCAQMD have long recognized that EPA
Method 24 is not suitable for thin film UV/EB/LED Materials. Thus, RadTech urges Maricopa
County to include ASTM D7767-11 as suitable test method for UV/EB/LED products subject to
Rule 336. We propose the following language:
The VOC content of thin film Energy Curable Adhesives and Sealants may be determined by
manufacturers using ASTM Test Method 7767 Standard Test Method to Measure Volatiles from
Radiation Curable Acrylate Monomers, Oligomers, and Blends and Thin Coatings Made from
Them.
Transfer Efficiency
UV/EB/LED products have higher viscosities than conventional solvent products. The rationale
behind transfer efficiency requirements is to control VOC emissions that can take place during
spraying operations. But, given the fact that UV/EB/LED materials do not have emissions like
conventional solvent processes, facilities should not be required to the same level of regulation
for transfer efficiency purposes. We urge Maricopa County to exempt UV/EB/LED materials
with viscosities of 650 centipoise or above, from the transfer efficiency requirements of the rule.
UV/EB materials not only meet, but far exceed any proposed rule requirements and any added
flexibility to companies that choose these pollution preventive processes will encourage
voluntary emission reductions thereby furthering the County’s mission.
The RadTech Association looks forward to working with Maricopa County on this rulemaking
and would gladly provide any additional information your staff may need.
Sincerely,
Rita M. Loof
Director, Environmental Affairs

Return to list of attachments
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION
Technical Support Document
for
EPA’s Rulemaking
for the
Arizona State Implementation Plan
Maricopa County Air Quality Department Rule 336
Surface Coating Operations
And
EPA’s evaluation of Maricopa County Air Quality Department’s Analysis of Reasonably Available
Control Technology for the 2008 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)
State Implementation Plan (RACT SIP) with respect to the volatile organic compound source
categories covered by the following Control Technique Guidelines (CTGs):
▪“Control of Volatile Organic Emissions from Existing Stationary Sources -Volume II: Surface
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks” (EPA-450/2-77-008, May
1977)
▪“Control of Volatile Organic Emissions from Existing Stationary Sources-Volume III: Surface
Coating of Metal Furniture” (EPA-450/2-77-032, December 1977)
▪“Control of Volatile Organic Emissions from Existing Stationary Sources -Volume V: Surface
Coating of Large Appliances” (EPA-450/2-77-034, December 1977)
▪“Control of Volatile Organic Emissions from Existing Stationary Sources -Volume VI: Surface
Coating of Miscellaneous Metal Parts and Products” (EPA-450/2-78-15 June 1978)
▪“Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (MMPPC)”
(EPA-453/R-08-003, September 2008)
▪“Control Techniques Guidelines for Metal Furniture Coatings” (EPA-453/R-07-005, September
2007)
▪“Control Techniques Guidelines for Large Appliance Coatings” (EPA 453/R-07-004, September
2007)
▪“Control Techniques Guidelines for Paper, Film, and Foil Coatings” (EPA-453/R-07-003,
September 2007)
Prepared by: Arnold Lazarus
Reviewed by: Doris Lo
December 2019

RULE IDENTIFICATION –
Agency Maricopa County Air Quality Department (MCAQD)
SIP Approved Rule 336 - Surface Coating Operations
Rule Revised - April 7, 1999
Submitted - August 4, 1999
EPA Approved - September 20, 1999 (64 FR 50759)
SIP-Approved There is no previous SIP-approved MCAQD RACT SIP for the
Analysis 2008 8-hour ozone standard.
Subject of this Rule 336 - Surface Coating Operations
TSD Revised – November 2, 2016
Submitted – June 22, 2017
Analysis of Reasonably Available Control Technology for the 2008
8-Hour Ozone National Ambient Air Quality Standard (NAAQS)
State Implementation Plan (RACT SIP) for Rule 336
Adopted - June 16, 2017
Submitted - June 22, 2017
Completeness
Complete by operation of law: December 17, 2017
Finding
BACKGROUND - The Maricopa County Air Quality Department (MCAQD) regulates
portions of Maricopa County and the cities of Phoenix, Mesa, Scottsdale, Tempe,
Chandler, Glendale, as well as 17 other jurisdictions and unincorporated County lands.
Part of the area regulated by MCAQD is included in the Phoenix-Mesa area designated as
nonattainment for ozone and classified as Moderate for the 2008 8-hour National
Ambient Air Quality Standard (NAAQS) (see 40 CFR 81.303, 81 FR 26699).
Rule 336 was revised as part of the MCAQD’s process to ensure that its rules meet the
reasonably available control technology (RACT) requirements of section 182(b) of the
Clean Air Act (CAA) for ozone nonattainment areas classified as Moderate. The June 22,
2017 submission from Arizona Department of Environmental Quality (ADEQ) to EPA titled
Analysis Of Reasonably Available Control Technology For The 2008 8-Hour Ozone National
Ambient Air Quality Standard (NAAQS) State Implementation Plan, (hereafter, the MCAQD
RACT SIP) contains the MCAQD’s analysis claiming to show that Rule 336 implements
RACT levels of control.
The purpose of Rule 336 is to limit emissions of volatile organic compounds (VOCs) from
various types of surface coating operations. Specific types of surface coating operations
addressed under Rule 336 include: Metal Parts and Products; Can and Coil Coating; Plastic
Parts and Products; Business Machine Coatings; Metal Furniture and Large Appliance

Coatings; Paper, Film, and Foil Surface Coating; and Pleasure Craft Surface Coating.
MCAQD revised Rule 336 to incorporate five categories for which EPA has issued Control
Technique Guidelines (CTGs), and to revise several other requirements including emission
control system control efficiency, work practices for handling and storage of materials,
exemptions, and recordkeeping.1
RULE SUMMARY - As discussed above, the purpose of Rule 336 is to regulate the
emissions of VOCs from surface coating applications. Rule 336 establishes VOC content
limits and workplace standards for surface coating operations. It also describes related
recordkeeping, reporting, and monitoring requirements; exemptions, and coating
operations with non-compliant materials using an emission control system.
Summary of SIP-approved rule:
The SIP-approved version of Rule 336, “Surface coating Operations” was approved in 1999
and regulated the surface preparation and coating operations for the following categories:
metal can and coil, metal furniture, large appliances, miscellaneous metal parts and
products, paper, film, fabric, vinyl, plastic, and other flexible parts and products.2 These
categories were covered by the following four CTGs listed in Table 1 below:
Table 1, CTG’s addressed by the 1999 SIP-approved revision of Rule 336
CTG Title EPA Number
Control of Volatile Organic Emissions from Existing
Stationary Sources -Volume II: Surface Coating of Cans, EPA-450/2-77-008,
1
Coils, Paper, Fabrics, Automobiles, and Light-Duty May 1977
Trucks
Control of Volatile Organic Emissions from Existing
EPA-450/2-77-032,
2 Stationary Sources-Volume III: Surface Coating of
December 1977
Metal Furniture
Control of Volatile Organic Emissions from Existing
EPA-450/2-77-034,
3 Stationary Sources -Volume V: Surface Coating of Large
December 19773
Appliances
1 See the MCAQD RACT SIP, Appendix 1: RACT SIP, Appendix A: RACT Analysis of CTG Source Categories, pp.
27-28.
2 64 FR 50759.
3 The September 20, 1999 FR notice only lists three CTG categories – the FR notice lists the CTG for “Metal
Furniture” but uses the CTG number for “Large Appliances.” This is an error in the 1999 FR notice. The listing
in Table 1 is correct.

Control of Volatile Organic Emissions from Existing
EPA-450/2-78-15
4 Stationary Sources -Volume VI: Surface Coating of
June 1978
Miscellaneous Metal Parts and Products
Summary of proposed rule revisions:
The MCAQD has revised Rule 336 to incorporate the following five CTG categories in Table
2 below:4
TABLE 2, CTGs addressed by the June 22, 2017 revision of Rule 336
CTG Title EPA Number
Control of Volatile Organic Emissions from Existing
Stationary Sources -Volume II: Surface Coating of EPA-450/2-77-008,
1
Cans, Coils, Paper, Fabrics, Automobiles, and May 1977
Light-Duty Trucks
Control Techniques Guidelines for Miscellaneous EPA-453/R-08-003,
2
Metal and Plastic Parts Coatings (MMPPC) September 2008
Control Techniques Guidelines for Metal Furniture EPA-453/R-07-005,
3
Coatings September 2007
Control Techniques Guidelines for Large Appliance EPA 453/R-07-004,
4
Coatings September 2007
Control Techniques Guidelines for Paper, Film, EPA-453/R-07-003,
5
and Foil Coatings September 2007
Rule 336 revisions include:5
• Raising the required emission control system overall control efficiency to 90%
• Including required work practices for handling, disposal and storage of VOC-
containing material
• Amending the VOC emission limits for surface coatings to be consistent with above
CTGs and other SIP-approved district rules
• Deleting an exemption for coatings used on tactical military equipment
4See the MCAQD RACT SIP, Appendix A: RACT SIP, pp. 27-28, and Appendix 2: NOTICES OF FINAL
RULEMAKING, pp. 143-178.
5 See the MCAQD RACT SIP, Appendix 1: RACT SIP, Appendix A: RACT Analysis of CTG Source Categories, pp.
27-28.

• Adding new work practices and clarifying existing work practices
• Streamlining recordkeeping provisions
• Updating test methods
• Addressing stakeholder comments on pleasure craft VOC surface coating limits by
adding limits for Extreme High Gloss Topcoat, Finish Primer Surfacer, and Other
Substrate Anti-Foulant Coating
EVALUATION CRITERIA – The following criteria were used to evaluate the submitted rule.
1. Enforceability – CAA § 110(a)(2)(A) requires SIPs to “include enforceable emission
limitations and other control measures, means, or techniques . . . as may be
necessary or appropriate to meet the applicable requirements of [the CAA].” In
addition, CAA § 172(c)(6) requires that nonattainment area SIPs “include
enforceable emission limitations, and such other control measures means or
techniques . . . as well as schedules and timetables for compliance, as may be
necessary or appropriate to provide for attainment of such standard in such area
by the applicable attainment date . . . .” The Bluebook (Issues Relating to VOC
Regulation Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the
Little Bluebook (Guidance Document for Correcting Common VOC & Other Rule
Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate
compliance with the CAA § 110(a)(2)(A) requirement for enforceability.
2. Stringency – SIPs must require RACT for each category of sources covered by a CTG
document as well as each major source of oxides of nitrogen (NOx) or VOCs in
ozone nonattainment areas classified as Moderate or above (see sections 182(b)(2)
and 182(f)). EPA’s CTGs listed in Tables 1 above are the relevant CTGs that Rule 336
must be evaluated against for stringency.
3. SIP Revisions – CAA § 110(l) prohibits EPA from approving any SIP revision that
would interfere with any applicable requirement concerning attainment and
reasonable further progress (RFP) or any other applicable requirement of the CAA.
In addition, CAA § 193 prohibits the modification of any SIP-approved control
requirement in effect before November 15, 1990, in a nonattainment area, unless
the modification ensures equivalent or greater emission reductions of the relevant
pollutant(s). This action involves a prior rule that was approved into the SIP in 1999.
Therefore, section 193 is not applicable.
EPA EVALUATION –A summary of our evaluation of the above three criteria follows.
1. Enforceability – The rule sets VOC content limits for all of the coatings (see Tables
336-1 through 336-7); work practice standards (see handling, disposal and storage

of VOC containing materials); and emission control system requirements. The rule
requirements and applicability are clear, and the monitoring, recordkeeping,
reporting and other provisions sufficiently ensure that affected sources and
regulators can consistently evaluate and determine compliance with Rule 336.
2. Stringency - Rule 336 addresses five CTG categories as discussed above. The coating
and exemptions and limits are found in Section 103 “Partial Exemptions,” Section
104 “Categorical Exemptions,” and Section 300 “Standards,” of the rule and we
have compared these limits and exemptions to the limits in the relevant CTGs as
well as other comparable rules in other nonattainment areas. Submitted Rule 336
was compared to South Coast Rule 1125 “Metal Container, Closure, and Coil
Coating Operations,” adopted on March 7, 2008, submitted to the EPA on April 6,
2009, and approved into the SIP on December 21, 2009 (74 FR 67821); Sacramento
Metropolitan Air Quality Management District Rule 452 “Can Coating,” adopted
September 25, 2008, submitted to the EPA on September 15, 2009, and approved
into the SIP on April 9, 2010 (75 FR 18068); Bay Area Air Quality Management
District Rule 8-11 “Metal Container, Metal Closure, and Metal Coil Coating,”
effective November 19, 1997, submitted to the EPA on March 28, 2000, and
approved into the SIP on September 18, 2000 (65 FR 56251); and San Joaquin Valley
Unified Air District Rule 4604 “Can and Coil Coating Operations,” adopted
September 20, 2007, submitted to the EPA on March 7, 2008, and approved into
the SIP on January 19, 2010 (75 FR 2796) for compliance with the RACT
requirements of CAA §182(b)(2) and §182(f). Most of the limits meet the CTG
requirements. However, EPA has identified several rule deficiencies (see “RULE
DEFICIENCIES” section below) concerning VOC surface coating limits and
exemptions that make Rule 336 less stringent than required by RACT. Once these
deficiencies are corrected through our conditional approval process, Rule 336 will
satisfy RACT requirements.
3. SIP Revisions – We have determined that our conditional approval of the submitted
rule would comply with CAA §§ 110(l) and 193 because the proposed SIP revision
would not interfere with any CAA requirements, including requirements for RFP
and attainment of the NAAQS.
RULE DEFICIENCIES – The following deficiencies preclude full approval of the rule into the
SIP. EPA has provided comments to MCAQD on these approvability issues.6
6 See July 6, 2018, October 24, 2018, and August 30, 2019 letters from Doris Lo, Chief, Rules Office, Air
Division, US EPA Region IX, to Philip A. McNeely, Director, Maricopa County Air Quality Department, Re: EPA
Comments on the Maricopa County Air Quality Department Rule 336 Surface Coating Operations and Re:
Additional EPA Comments on the Maricopa County Air Quality Department Rule 336 Surface Coating
Operations, respectively. EPA’s comments also include comments on the Industrial Adhesive Category,

1. Section 300, Standards, Table 336-2 contains VOC content limits for the
categories of End Sealing Compound: Food or Beverage, End Sealing
Compound: Non Food, Sheet Basecoat (Interior and Exterior) and
Overvarnish, Two Piece Can Interior Body Spray, Three Piece Can Interior
Body Spray, Two Piece Can Exterior Base Coat Overvarnish, and Two Piece Can
Exterior End (Spray or Roll Coat) which comply with the 1977 CTG, "EPA-
450/2-77-008, Control of Volatile Organic Emissions from Existing Stationary
Sources- Volume II: Surface Coating of Cans, Coils, Paper, Fabrics Automobiles
and Light Duty Trucks," May 1977, but are generally significantly higher than
the same limits in currently SIP-approved rules such as SCAQMD Rule 1125,
Sacramento AQMD Rule 452, BAAQMD Rule 8-11, and SJVUAPCD Rule 4604.
Because the lower limits have been achieved in other areas for some time,
the limits in Rule 336 do not demonstrate current RACT. The MCAQD must
lower the VOC limits for these categories.
2. Section 103.2 exempts Extreme Performance Coatings from the VOC limits when
used on:
a) internal combustion engines components that are normally above 250°F
during use or
b) items that are used at temperatures above 250°F that are included
under various NAICS codes for telecommunications equipment and are
electronic products in space vehicles and/or are communications
equipment.
The 2008 Miscellaneous Metal and Plastic Parts (MMPP), 2007 Metal Furniture,
and 2007 Large Appliance CTGs do not exempt Extreme Performance Coatings. In
addition, Rule 336, Tables 336-1, 336-3, 336-5 contain the appropriate VOC
content limits for this category and are consistent with the CTGs. The MCAQD
must remove the exemption or provide justification for the Extreme Performance
Coating exemptions.
3. Section 103.5.e exempts Tactical Military-Equipment coatings that are in a
District-approved permit based on a demonstration that no compliant
substitute exists.
The rule does not define "Tactical Military-Equipment" and the 2008 MMPP CTG
which we are including here for completeness, but we are not acting on the adhesives category in this
action and will address this CTG category in a separate action.

does not include this exemption. Evaluate deleting this exemption if Tactical
Military-Equipment Coatings can fall under other CTG categories which include
performance standards for "extreme performance" or "military specification"
coatings.7
4. Rule 336 is missing the VOC limits and categories for "Motor Vehicle Materials"
as is found in Table 6 Motor Vehicle Materials VOC Content Limits of the MMPP
CTG. Rule 336 Table 336-4 "Coating Limits for Business Machines" is missing the
VOC limits and categories for Automotive/Transportation Coatings as is found in
CTG Table 4 for "Automotive/Transportation and Business Machine Plastic Parts
VOC Content Limits." The missing categories also do not appear in Maricopa Rule
345 Vehicle and Mobile Equipment Coating. The MCAQD must add these CTG
categories and VOC limits to the rule, or if appropriate, consider adopting a
negative declaration for the entire CTG category table.
5. Section 300, Standards, Table 336-1 contains VOC limits for the category “Other
Metal Parts and Products: Includes Non-Adhesive Coating, Adhesive, Adhesive
Primer, Beaded Sealant, and Caulking” which does not comply with the 2008
CTG, “EPA-453/R-08-003, Control Techniques Guidelines for Miscellaneous
Metal and Plastic Parts Coatings” (MMPP) September 2008. Because the limits
for General One Component and General Multi Component Coatings are lower
in the CTG, the limits in Rule 336 do not meet the presumptive RACT standard
established in the CTG. The County must either lower the VOC limits in this
category, or provide an analysis demonstrating that its limits represent RACT.
6. Section 300, Standards Table 336-3 contains VOC limits for “Flexible Plastic Parts
and Products” as well as “Plastic Parts and Products That Are Not Defined as
Flexible.” These categories are not in the 2008 MMPP CTG and contain higher
VOC limits than some of the existing categories in the CTG. The County must
remove these VOC categories from the rule or demonstrate why the “Flexible
Plastic Parts and Products” and “Plastic Parts and Products That Are Not Defined
as Flexible” VOC limits meet current RACT.
7. The County submitted a negative declaration for the industrial adhesive
category, which is covered by a CTG. However, a facility under the County’s
jurisdiction and in the Phoenix-Mesa ozone nonattainment area is using an
7 Our October 24, 2018 comment letter included an additional comment about estimating and comparing
the mass of VOCs from this category. This comment is no longer applicable.

adhesive covered by the CTG. Therefore, the CTG must be fully addressed in
Rule 336.
ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION- The following
revisions are not currently the basis for rule disapproval but are recommended for the
next time the rule is amended. EPA has provided comments to the MCAQD on these rule
improvement recommendations.8
1. Table 336-2 limits Coil Coatings to 310 g/L. Please consider reducing this limit to
200 g/L consistent with other SIP rules. See Bay Area AQMD Regulation 8, Rule 11
and South Coast AQMD Rule 1125. Alternatively, consider deleting this category
since Maricopa County' s RACT SIP contains a negative declaration for Coil
Coatings.
2. Section 204 Air-Dried Coatings (dried by the use of air or forced warm air at
temperatures up to and including 200°F (93.3°C)) differs from the MMPP CTG's
Appendix H definition of Air Dried Coating which states the coating is cured at a
temperature below 194°F (90°C). Please revise the definition to be consistent with
the CTG definition.
3. Section 207 Baked Coatings (dried or cured in an oven in which the oven
temperature exceeds 200°F (93.3°C)) differs from the MMPP CTG's Appendix H
definition of Baked Coating which states the coating is cured at a temperature at
or above 194°F (90°C). Please revise the definition to be consistent with the CTG
definition.
4. Section 227 Extreme High-Gloss Coating contains a typographical error. Please
correct the reference to test method ASTDM D-523 by removing "D" to ASTM D-
523. Also, the 1999 version (D523-89 (1999)) has been approved for use so please
consider revising the rule to include the 1999 version.
5. Section 228 Extreme Performance Coatings - consider expanding the definition to
follow the MMPP CTG Appendix H recommended definition (e.g., chronic exposure
to corrosive, caustic or acidic agents, repeated heavy abrasion etc.).
6. Section 501.2.b Recordkeeping
Please do not delete the word “coating” in the following sentence: "Shall have the
written value of the VOC coating content in one of the following forms."
7. Section 503.1.a.(1), 503.1.a.(2) and 503.2.f Compliance Determination
8 Please see our October 24, 2018 comment letter.

Please update BAAQMD Method 31 (April 15, 1992) to May 18, 2005. The May 18,
2005 version is approved for use in SIP rules.
8. Section 503. l.a.(2)(b) states for multi-component, polymerizing coatings, Method
24 shall be modified to eliminate the post-mixing dilution-step. We recommend
deleting the language to modify EPA Method 24. Method 24 section 11.2 now
provides instructions for multi-component coatings. Method 24 shall be used
along with ASTM D2369-10(2015)e1 for multi-component, polymerizing coatings.
9. Section 503.1.b refers to EPA Method 25 and its submethod. The appropriate
methods should be listed since some submethods such as Method 25C, Landfill
Gases, are not appropriate for coatings. See 503.3.a which also needs correcting.
Alternatively, consider changing the " and" to "or" and adding "as appropriate."
(e.g., EPA Method 25 or its submethods as appropriate.). Section 503.2,
incorporation by reference is correct as written and does not need to be changed.
10. 503.1.c Capture efficiency. Please modify to include the guidance document for
capture efficiency: e.g., The capture efficiency of an emission collection control
system shall be determined according to EPA's "Guidelines for Determining
Capture Efficiency," January 9, 1995 and 40 CFR 51, Appendix M, Methods 204-
204F, as applicable. See also 503.3.b.
The listed methods: EPA Methods 2, 2a, 2c, and 2d. Please change the "and" to
"or". Ideally, the rule should include an equation for capture
and control efficiency. E.g., San Joaquin Rule 4604 Can and Coil Coating
Operations Section 6.7.2.3.
11. 503.2.b EPA Method 18. Please delete "and its submethods." Method 18 has no
submethods. See also 503.3.a.
12. 503.3.c The listed methods: EPA Methods 2, 2a, 2c, and 2d. The "and" should be
"or".
MCAQD COMMITMENT LETTERS – On January 28, 2019, the MCAQD transmitted a
commitment letter in response to the EPA’s rule approvability comments made in the
course of our evaluation, and on December 5, 2019, MCAQD transmitted a letter
modifying their January 28, 2019 commitment letter.9,10 Maricopa’s January 28, 2019
9 See January 28, 2019 letter from Philip A. McNeely, Director, MCAQD, to Mr. Misael Cabrera, Director,
ADEQ, RE: Request for Submittal of Letter of Commitment for Conditional Approval of the Maricopa County
Reasonably Available Control Technology (RACT) State Implementation Plan (SIP).
10 See Letter dated December 5, 2019 from Philip A. McNeely, Director, Maricopa Air Quality

letter (as modified on December 5. 2019) identifies EPA’s approvability issues, commits to
resolve outstanding approvability issues with specific enforceable provisions, and commits
to submit revisions addressing the approvability issues to ADEQ by a certain timeframe.
On February 25, 2019, the ADEQ submitted a letter from Timothy Franquist, Director, Air
Quality Division of Arizona Department of Environmental Quality to Michael Stoker,
Regional Administrator, USEPA, on behalf of MCAQD, confirming MCAQD’s Commitment
for Conditional Approval of the Maricopa County Reasonably Available Control
Technology (RACT) State Implementation Plan (SIP).11 ADEQ’s letter commits to submit
the revisions from MCAQD to the EPA by a certain timeframe. The following
commitments must be met in order for revisions to Rule 336 to be fully approved into the
SIP, and to fully meet the RACT SIP requirement for this source category.
1. The MCAQD commits to lower the VOC limits for the following can coating
materials: end sealing compound, sheet basecoat (interior and exterior)
and overvarnish, two-piece can interior body spray, three-piece can
interior body spray, two-piece can exterior base coat and overvarnish, and
two-piece can exterior end spray or roll coat. The lower emission limits will
be consistent with current RACT, based on a comparison of RACT rules in
other nonattainment areas.
Proposed VOC Limits for Coating Cans and Coils:
Coating Category g VOC/l lb VOC/gal
Can Coating
Can Printing Ink 300 2.5
End Sealing Compound 20 0.2
Sheet Basecoat (Exterior and Interior) and Overvarnish 250 2.1
Three-Piece Can Side-Seam Spray 660 5.5
Two and Three-Piece Can Interior Body Spray 440 3.7
Department to Ms. Doris Lo, Manager, Rules Office, Air and Radiation Division, U.S. Environmental
Protection Agency Region IX, 75 Hawthorne St., San Francisco, CA 94105, “RE: Supplemental Request
for Submittal of Letter of Commitment for Conditional Approval of Rule 324 (Stationary
Reciprocating Internal Combustion Engines) and Rule 336 (Surface Coating Operations).”
11 See Letter dated February 25, 2019, from Timothy Franquist, Director, Air Quality Division of Arizona
Department of Environmental Quality to Michael Stoker, Regional Administrator, USEPA, ”Re: Submittal of
the Maricopa County Air Quality Department’s Letter of Commitment for Conditional Approval of the
Maricopa County Reasonably Available Control Technology (RACT) State Implementation Plan (SIP),”
submitted via SPeCS for SIPs Portal. MCAQD’s commitment letter also includes a commitment for the
Industrial Adhesive Category, but we are not including that here because we are addressing this CTG
category in a separate action.

Two-Piece Can Exterior (Basecoat and Overvarnish) 250 2.1
Two-Piece Can Exterior End (Spray or Roll Coat) 250 2.1
Coil Coating 310 2.6
Strippable Booth Coating (applies to both can and coil 240 2.0
coating categories)
2. The MCAQD commits to evaluate the exemption for extreme performance
coatings. Following this evaluation, the MCAQD will either remove or constrain
the exemption. If a narrower exemption for extreme performance coatings is
included in the revised rule, the MCAQD will provide documentation justifying
the exemption is RACT.
3. The MCAQD commits to evaluate the exemption for tactical military
equipment coatings. Following this evaluation, the MCAQD will either
remove the exemption or require EPA approval of non-compliant military
specification coatings.
4. The MCAQD commits to evaluate the CTG categories for “Motor Vehicle
Materials” and “Automotive/Transportation Coatings.” Following the
evaluation of each category, the MCAQD will either submit a negative
declaration for the category or incorporate RACT emission limits for the
category.
5. The MCAQD commits to remove adhesives and adhesive primers from the
"Other Metal Parts and Products" coating category in Table 336-1 (VOC
Limits for Miscellaneous Metal Part and Product Coatings). The MCAQD
also commits to lower the VOC limit for the "Other Metal Parts and
Products" coating category to 340 grams VOC per liter (g/L) for air dried
coatings and 280 g/L for baked coatings.
6. The MCAQD commits to remove the following coating categories from
Table 336-3 (VOC Limits for Miscellaneous Plastic Part and Product
Coatings):
• Flexible Plastic Parts and Products (Basecoat, Clearcoat, Color Topcoat,
and Primer); and
• Plastic Parts and Products that are not Defined as Flexible.
7. The MCAQD commits to incorporate administrative mechanisms and
emission limits that are consistent with RACT emissions limits established
in the CTG for Miscellaneous Industrial Adhesives and incorporated in
other nonattainment areas.

EPA’s PROPOSED ACTION
Overall, we believe that the revisions are on balance SIP-strengthening. However, the
issues described above in the “Rule Deficiencies” section preclude the full approval of this
rule into the Arizona SIP. The MCAQD’s and ADEQ’s commitments to address these
deficiencies and submit a revised rule within one year of our final action of this submittal
allows the EPA to propose to conditionally approve the submitted version of Rule 336 into
the Arizona SIP. Therefore, we recommend proposing to conditionally approve Rule 336
into the SIP.
If the EPA approves a revised Rule 336 addressing the deficiencies above, we would be
able to certify that Maricopa County is implementing RACT for sources subject to this rule.
REFERENCES
1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,”
(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.
2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,”
(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.
3. Rule 336 “Surface coating Operations,” revised April 7, 1999; submitted August 4,
1999 and EPA Approved September 20, 1999 (64 FR 50759).
4. Rule 336 “Surface coating Operations,” revised November 2, 2016; submitted
December 19, 2016.
5. “Control of Volatile Organic Emissions from Existing Stationary Sources -Volume II:
Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks”
EPA-450/2-77-008, May 1977.
6. “Control of Volatile Organic Emissions from Existing Stationary Sources -Volume III:
Surface Coating of Metal Furniture” EPA-450/2-77-032, December 1977.
7. “Control of Volatile Organic Emissions from Existing Stationary Sources” -Volume
IV: Surface Coating of Large Appliances” EPA-450/2-77-034, December 1977.
8. “Control of Volatile Organic Emissions from Existing Stationary Sources -Volume VI:
Surface Coating of Miscellaneous Metal Parts and Products” EPA-450/2-78-15,
June 1978.
9. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts
Coatings” EPA-453/R-08-003, September 2008.
10. “Control Techniques Guidelines for Metal Furniture Coatings” EPA-453/R-07-005
September 2007.
11. Control Techniques Guidelines for Paper, Film, and Foil Coatings” EPA-453/R-07-
003, September 2007.
12. Bar Area Air Quality Management District Rule 8-11 “Metal Container, Metal
Closure, and Metal Coil Coating” state effective November 19, 1997, submitted to
the EPA on March 28, 2000, and approved into the SIP on September 18, 2000 (65

FR 56251).
13. Sacramento Metropolitan Air Quality Management District Rule 452 “Can Coating”
adopted September 25, 2008, submitted to the EPA on September 15, 2009, and
approved into the SIP on April 9, 2010 (75 FR 18068).
14. South Coast Air Quality Management District “Metal Container, Closure, and Coil
Coating Operations,” adopted March 7, 2008 submitted to the EPA on April 6,
2009, and approved into the SIP on December 21, 2009 (74 FR 67821).
15. San Joaquin Valley Unified Air District Rule 4604 “Can and Coil Coating Operations”
adopted September 20, 2007, submitted to the EPA on March 7, 2008, and
approved into the SIP on January 19, 2010 (75 FR 2796).
16. “Guidelines for Determining Capture Efficiency,” Candice Sorrell, Source
Characterization Group A (MD-19) Emission Monitoring and Analysis Division,
Office of Air Quality Planning and Standards, US EPA, Research Triangle Park, NC
27711, January 9, 1995.
17. Letter dated January 28, 2019, from Philip A. McNeely, Director, Maricopa Air
Quality Department, to Mr. Misael Cabrera, Director, Arizona Department of
Environmental Quality, “RE: Request for Submittal of Letter of Commitment for
Conditional Approval of the Maricopa County Reasonably Available Control
Technology (RACT) State Implementation Plan (SIP).”
18. Letter dated February 25, 2019 from Timothy Franquist, Director, Air Quality
Division of Arizona Department of Environmental Quality to Michael Stoker,
Regional Administrator, USEPA, ”Re: Submittal of the Maricopa County Air Quality
Department’s Letter of Commitment for Conditional Approval of the Maricopa
County Reasonably Available Control Technology (RACT) State Implementation
Plan (SIP),” submitted via State Plan Electronic Collection System for SIPs Portal.
19. Letter dated December 5, 2019 from Philip A. McNeely, Director, Maricopa Air
Quality Department to Ms. Doris Lo, Manager, Rules Office, Air and Radiation
Division, U.S. Environmental Protection Agency Region IX, 75 Hawthorne St., San
Francisco, CA 94105, “RE: Supplemental Request for Submittal of Letter of
Commitment for Conditional Approval of Rule 324 (Stationary Reciprocating
Internal Combustion Engines) and Rule 336 (Surface Coating Operations).”

Return to list of attachments
Maricopa County Air Quality Dept.
AQ-2017-008-Rule 336 Planning & Analysis Division
3800 N. Central Ave. Ste. 1400
Phoenix, AZ 85012
Negative Declarations for Three Coating Categories Listed in the 2008 Control Techniques
Guidelines for Miscellaneous Metal and Plastic Parts Coatings
In accordance with Section 182(b)(2) of the Clean Air Act, the Maricopa County Air Quality
Department (MCAQD) is proposing to submit negative declarations to the EPA certifying that
there are no emitting facilities in Maricopa County for the following coating categories identified in
the 2008 Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (EPA-
453/R-08-003).
Business Machine Plastic Part Coatings
This category includes coatings applied to business machines and coatings applied to any plastic part
that is or shall be assembled with other parts to form a business machine. Business machine means
any device that uses electronic or mechanical methods to process information, perform calculations,
print or copy information or convert sound into electrical impulses for transmission, including
photocopy machines (which are a subcategory of standard industrial classification number 3861 –
Photographic Equipment and Supplies) and devices listed in the following standard industrial
classification numbers:
 3572 – Computer Storage Devices
 3573 – Electronic Computing Equipment (no longer a valid SIC code)
 3574 – Calculating and Accounting Machines (no longer a valid SIC code)
 3579 – Office Machines, Not Elsewhere Classified
 3361 – Telephone and Telegraph Apparatus (no longer a valid SIC code)
Automotive/Transportation Plastic Part Coatings
This category includes coatings applied to plastic automotive or transportation equipment parts and
coatings that are applied to plastic components of automotive or transportation equipment parts.
These types of coatings are typically applied at facilities that fabricate or manufacture automotive or
transportation equipment parts. Coatings that are applied at a secondary facility after the part or
product has been manufactured or fabricated are also included in this category. This category does
not include vehicle refinishing coating operations (which are covered by a national rule). In addition,
this category does not include coatings that are applied during the production or assembly of
automobiles or light-duty trucks (which are addressed in the CTG for Automobile and Light-Duty
Truck Assembly Coatings).
Motor Vehicle Materials
This category includes glass bonding primers, adhesives, cavity waxes, sealers, deadeners,
gasket/gasket sealing materials, underbody coatings, trunk interior coatings, bedliners, weatherstrip
adhesives, and lubricating waxes/compounds that are used in the following types of operations:
 The production of vehicles other than automobiles or light-duty trucks
 The production of automobiles or light-duty trucks at facilities that are not automobile or
light-duty truck assembly plants; and
 The production of aftermarket parts for automobiles and light-duty trucks.
To determine if any emitting facilities in these coating categories exist in Maricopa County, the
MCAQD conducted file reviews for each facility that is permitted to conduct surface coating
operations in Maricopa County. During this file review, the MCAQD reviewed a variety of
documents, including the permit, the technical support document for the permit, emissions
inventory reports, inspection reports, and source records. When necessary, the MCAQD also
conducted web searches and made direct contact with Permittees to determine the scope of
permitted surface coating operations in Maricopa County.