AQ-2013-002-RULE 345_EXECUTIVESUMMARYOFSTAFFREPORTTOTHEBOARDOFSUPERVISORS 2015-01-29.PDF

Executive Summary
Of The Report to the Board of Supervisors
Prepared by the Maricopa County Air Quality Department
Board Hearing Date: April 8, 2015
Case #/Title: AQ-2013-002-Rule 345
Agenda Item:
Supervisor Districts: All Districts
The Maricopa County Air Quality Department (department) complied with all statutory and county policies throughout this
rulemaking process. Per the Enhanced Regulatory Outreach Program 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: This rulemaking is proposing to restructure and revise content of
Rule 345 (Vehicle and Mobile Equipment Coating) to ensure that the standards and work practices for commercial vehicle
coating operations are clearly described. The standards in this rule describe limits for control of volatile organic compound
(VOC) emissions from the paints or coatings used by vehicle coating facilities. Providing a clear, concise, and understandable
rule for the owners and operators of vehicle coating facilities encourages compliance with rule requirements. The Phoenix
area is classified as Marginal nonattainment for ozone as determined by ambient air violations of the National Ambient Air
Quality Standards (NAAQS). Ozone is created when VOC emissions react in the presence of sunlight to form ground-level
ozone, a major component of “smog” which is hazardous to human health and the environment. The U.S. Environmental
Protection Agency (EPA) determined that automotive coating operations, such as the facilities regulated by Rule 345,
account for at least 80 percent of the VOC emissions in areas that violate the NAAQS for ozone such as the Phoenix Area.
Overview Of Stakeholder Input And Staff Responses: During the informal rulemaking process (Nov 2013-July 2014), the
department conducted three public workshops and addressed issues raised by both local and national regulated communities.
The formal rulemaking process consisted of a 30-day comment period (Oct-Nov 2014), during which the department
received comments from three Stakeholders: DeVilbiss, a manufacturer of vehicle coatings and equipment, Sinthium, a local
vehicle coating facility and the American Coatings Association (ACA). Their comments centered around spray-gun
requirements and limits (Rule 345, Section 303.1), spray-gun cleaning requirements (Rule 345, Section 303.2), recordkeeping
and reporting requirements for spray-gun transfer efficiency (Rule 345, Section 501.2), compliance determination for spray-
gun tip pressure measurement (Rule 345, Section 502.4), and a formula for determining the VOC limits of coatings (Rule
345, Section 503.1).
Stakeholders asked for clarification regarding whether or not facilities must actually perform spray-gun certification and the
type of documentation needed for such certification. The department is proposing to clarify in Rule 345 the compliance
certification and documentation required when using a certified spray-gun or an alternative application method. If a facility
uses a certified spray-gun, then the spray-gun will have to meet the definition of “high-volume low pressure (HVLP)” and
will have to meet the spray-gun tip pressure measurement test. The facility may be required to perform the spray-gun tip
pressure measurement test when spray-gun operations are outside normal operating parameters. The HVLP spray-gun
manufacturer should provide a device and instructions for measuring spray-gun tip pressure. If a facility uses an alternative
application method, which includes the use of new spray application technologies, then the facility will not have to perform
spray equipment transfer efficiency testing. The spray-gun manufacturer will provide third-party documentation of the spray-
gun transfer efficiency.
Stakeholders asked that Rule 345 allow for cleaning spray-guns without having to use a spray-gun cleaning machine. Rule
345 has always allowed spray-gun cleaning without the use of a spray-gun cleaning machine, if spray-guns are cleaned using
water or a cleaning mixture that is more than 50% by weight or volume. The department is proposing to clarify Rule 345
regarding which solvent cleaners a facility can use to clean spray-guns without having to use a spray-gun cleaning machine.
For example, under the proposed revisions to Rule 345, a facility would not be required to use a spray-gun cleaning machine
if it were using solvent cleaners that were less than 10 percent VOC, contained less than 8.0 percent by weight of VOC
(including water and non-precursor organic compounds), and had a VOC-vapor pressure below 35 mm Hg at 20°C (68°F). If
a facility opts to use such solvent cleaners, then such facility will not be required to use a spray-gun cleaning machine.

Stakeholders asked that the department retain the “VOC-multi” equation, because such equation matches that found in the
U.S. Environmental Protection Agency (EPA) National Rule for vehicle coating facilities. The “VOC-multi” equation allows
for calculating VOC when applying more than one coat of paint to a vehicle. The department is proposing to retain the
“VOC-multi” equation; however, the department is proposing to remove the automatic doubling of the clearcoat component
in the calculation. If a facility applies only one coat of paint to a vehicle, then the facility would only have to use this
equation once. If a facility applies more than one coat of paint to a vehicle, then the facility would have to use this equation
for each coat applied.