AQ-2023-004-RULE338 REPORT TO THE BOARD OF SUPERVISORS.PDF

Air Quality Department 
301 W. Jefferson St., Suite 410  
Phoenix, Arizona 85003 
P: 602-506-6010 
E: AQMail@maricopa.gov 
 
 
Enhanced Regulatory Outreach Program 
Maricopa County Air Quality Department 
Notice of Public Hearing 
Subject:  
 
Rule 338 (Semiconductor Manufacturing) 
Date/Time:   
Wednesday, September 25, 2024, at 9:30 a.m. 
Location:  
 
Board of Supervisors’ Auditorium 
205 W. Jefferson St., Phoenix, Arizona 85003 
The Maricopa County Board of Supervisors is scheduled to conduct a public hearing to solicit 
comments on the proposed revisions to Maricopa County Air Pollution Control Regulations, 
Rule 338 (Semiconductor Manufacturing) and the proposed submission of the amended rule 
as a revision to the Arizona State Implementation Plan (SIP). 
You may comment on the proposed rule using the Enhanced Regulatory Outreach Program 
(EROP) online comment form. 
AQ-2023-004-Rule 338 (Semiconductor Manufacturing) 
The Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 338 to 
incorporate reasonably available control technology (RACT) controls for nitrogen oxide 
emissions generated during the semiconductor manufacturing process. In addition, MCAQD 
is proposing to revise some of the volatile organic compound controls in the rule to ensure 
the controls continue to implement RACT. 
Members of the public may attend the Board meeting in person or view the meeting online. 
Please check the Board of Supervisors’ website at least 24 hours before the date of the 
public hearing for instructions for remote access. Live video feeds are also available 
at www.maricopa.gov.  
For more information regarding this rulemaking, please refer to the Report to the Board of 
Supervisors attached to this notice and available on the EROP Active Regulatory Process 
webpage. A copy of the SIP submittal will be available at least 30 days prior to the hearing for

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public inspection at the offices of the Maricopa County Air Quality Department, 301 West 
Jefferson Street, Suite 410, Phoenix, Arizona 85003. The SIP submittal will also be available 
on the EROP Active Regulatory Process webpage at least 30 days prior to the hearing. In 
addition, copies of the Report to the Board of Supervisors and the SIP submittal can be 
obtained by calling 602-506-6010. 
MCAQD will take reasonable measures to provide access to department services to 
individuals with limited ability to speak, write, or understand English and/or to those with 
disabilities. Requests for language interpretation services or for disability accommodations 
must be made at least 48 hours in advance by contacting: 602-506-6443. 
MCAQD tomará las medidas necesarias para brindar acceso a los servicios del 
departamento a personas que no dominan el idioma inglés y/o personas con 
discapacidades. Las solicitudes de servicios de interpretación de otro idioma o 
adaptaciones para discapacitados deben realizarse con al menos 48 horas de anticipación 
comunicándose con: 602-506-6443.

Air Quality Department 
301 W. Jefferson St., Suite 410 
Phoenix, Arizona 85003 
P: 602-506-6010 
E: AQMail@maricopa.gov 
 
Executive Summary of the Report to the Board of Supervisors 
Prepared by Maricopa County Air Quality Department 
Board Hearing Date: 
September 25, 2024 
Case Number/Title:  
AQ-2023-004-Rule 338 (Semiconductor Manufacturing) 
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: 
The purpose of Rule 338 (Semiconductor Manufacturing) is to limit volatile organic 
compound (VOC) emissions from the semiconductor manufacturing industry. The last 
significant revision to the rule occurred in 1999. The U.S. Environmental Protection Agency 
(EPA) approved Rule 338 into the Arizona State Implementation Plan (SIP) on February 9, 
1998, finding the rule met reasonably available control technology (RACT) requirements for 
the control of VOCs. MCAQD is proposing to revise Rule 338 to incorporate RACT controls for 
nitrogen oxide (NOx) emissions generated during the semiconductor manufacturing process. 
In addition, MCAQD is proposing to revise some of the VOC controls in the rule to ensure the 
controls continue to implement RACT.  
On November 7, 2022, the EPA reclassified portions of Maricopa County as a moderate 
nonattainment area with respect to the 2015 8-hour ozone National Ambient Air Quality 
Standard. Sections 182(b)(2) and (f) of the Clean Air Act (CAA) require jurisdictions that are 
classified as “moderate” or higher nonattainment to implement RACT for all sources subject 
to an EPA Control Techniques Guideline (CTG) as well as for all non-CTG major sources of 
VOCs or NOx.  
In response to the reclassification, MCAQD identified all non-CTG major sources of NOx and 
VOCs and determined whether the sources are implementing RACT through compliance with 
local rules and permit conditions. During the analysis MCAQD identified a semiconductor 
manufacturing facility that is a non-CTG major source for both VOC and NOx emissions. The 
VOC and NOx emissions from the facility are regulated under a Title V permit through 
emission limits and work practices that have been demonstrated to meet lowest achievable

emissions rate (LAER) and best available control technology (BACT) requirements. LAER and 
BACT are generally considered more stringent than RACT. 
The permit conditions regulating the VOC and NOx emissions from the semiconductor 
manufacturing facility are not incorporated into the Arizona SIP. Sections 182(b)(2) and 182(f) 
of the CAA require VOC and NOx RACT requirements for non-CTG major sources in ozone 
moderate nonattainment areas be incorporated into the SIP. Therefore, the MCAQD is 
proposing to revise Rule 338 to ensure the rule implements RACT controls for both VOC and 
NOx emissions.  
Overview of Stakeholder Input and Staff Responses: 
MCAQD received written feedback from five (5) stakeholders. One (1) stakeholder expressed 
opposition and four (4) stakeholders expressed neither support nor opposition to the 
rulemaking. MCAQD evaluated the comments and drafted responses. The stakeholders’ 
comments and the MCAQD’s responses are included under Section 9 of the attached Draft 
Notice of Final Rulemaking. Copies of the stakeholders’ written feedback and comments are 
attached to this report. 
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Maricopa County 
Air Quality Department 
Planning and Analysis Division 
Report to the 
Board of 
Supervisors 
Rule 338 
(Semiconductor 
Manufacturing)
September 2024

Board of Health Meeting Date: 
July 22, 2024 
Board Hearing Date: 
September 25, 2024 
Case Number/Title:  
AQ-2023-004-Rule 338 (Semiconductor Manufacturing) 
Agenda Item: 
(Pending) 
Supervisor Districts: 
All Districts 
Applicant:  
Staff 
Request: 
Approve revision of Maricopa County Air Pollution Control 
Regulations, Rule 338 (Semiconductor Manufacturing) and 
approve submission of the revised rule as a revision to the 
Arizona State Implementation Plan (SIP). 
The purpose of Rule 338 (Semiconductor Manufacturing) is 
to limit volatile organic compound (VOC) emissions from the 
semiconductor manufacturing industry. The last significant 
revision to the rule occurred in 1999.  
MCAQD is proposing to revise Rule 338 to incorporate 
Reasonably Available Control Technology (RACT) controls 
for nitrogen oxide (NOx) emissions generated during the 
semiconductor manufacturing process. In addition, MCAQD 
is proposing to revise some of the VOC controls in the rule to 
ensure the controls continue to implement RACT. 
In addition to implementing RACT controls for VOC and NOx 
in Rule 338, MCAQD is proposing the following revisions: 
•
Broadening the applicability of the rule to process tool
operations.
•
Removing exemptions to avoid relaxations from the
Arizona SIP version of Rule 338.
•
Removing definitions for terms that are no longer
used in the rule.
•
Updating and clarifying language in Section 301
(Control of VOC Emissions from Semiconductor
Manufacturing Operations).
•
Enhancing solvent cleaning station requirements and
cleaning solvent specifications.
•
Adding operating and recordkeeping requirements for
Point-Of-Use (POU) Combustion Device.
•
Updating Emission Control System (ECS)
requirements to match other recently revised rules.
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•
Adding compliance schedule timeframes for ECS
installation at new or existing sources, ECS
modifications, and good combustion plan submittal.
Support/Opposition: 
MCAQD received written feedback from five (5) 
stakeholders. One (1) stakeholder expressed opposition and 
four (4) stakeholders expressed neither support nor 
opposition to the rulemaking. MCAQD evaluated the 
comments and drafted responses. The stakeholders’ 
comments and the MCAQD’s responses are included under 
Section 9 of the attached Draft Notice of Final Rulemaking. 
Copies of the stakeholders’ written feedback and comments 
are attached to this report. 
Staff 
Recommendation: 
Approve 
Board of Health 
Recommendation: 
Approve 
Additional Comments: 
This regulatory change is following the Enhanced Regulatory 
Outreach Program (EROP) Policy and workflow process. The 
County Manager briefed the Board of Supervisors regarding 
this rulemaking in February 2023. Stakeholder Workshops 
were held on April 4, 2023, and February 6, 2024.  
The Board of Health approved initiation of regulatory change 
on April 24, 2023, and a Notice of Proposed Rulemaking was 
posted on the EROP website on June 5, 2024. On July 22, 
2024, the Board of Health made a recommendation to the 
Board of Supervisors to approve the revisions to Rule 338. 
A newspaper notice of the Board of Supervisors public 
hearing will be published in the Arizona Business Gazette on 
August 22, 2024, and August 29, 2024. 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) 
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Language of proposed regulatory change or amendment 
(See the Draft Notice of Final Rulemaking) 
Strikethrough/underline of Draft Rule 338 
Clean version of Draft Rule 338 
Minutes from Board of Health meeting - April 24, 2023 
Minutes from Board of Health meeting - July 22, 2024 Pending
Copies of all written and electronic Stakeholder input 
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Maricopa County 
Air Quality Department 
Planning and Analysis Division 
Draft Notice of 
Final 
Rulemaking 
Rule 338 
(Semiconductor 
Manufacturing)
September 2024

Draft Notice of Final Rulemaking 
Maricopa County Air Pollution Control Regulations 
Regulation III – Control of Air Contaminants 
Rule 338 (Semiconductor Manufacturing) 
The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 338 
(Semiconductor Manufacturing). 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 Arizona Revised Statutes (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(B).
Preamble 
1.
Statutory authority for the rulemaking (A.R.S. § 49-471.05(1)):
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 (A.R.S. § 49-471.05(2)):
Name: 
Hannah Luke or Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
Address: 
301 W. Jefferson St., Suite 410 
Phoenix, AZ 85003 
Telephone: 
602-506-6010
Fax: 
602-506-6179
Email: 
AQPlanning@maricopa.gov 
Online: 
Submit a Comment 
3.
Rulemaking process (A.R.S. § 49-471.05(3)):
This rulemaking is following procedures identified in state statutes and the Maricopa
County EROP Policy.
County Manager Briefing: 
February 1, 2023
Return to list of attachments
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Initial Stakeholder Workshop: 
April 4, 2023 
Second Stakeholder Workshop: 
February 6, 2024 
Board of Health Meeting to Initiate Regulatory 
Change: 
April 24, 2023 
Notice of Proposed Rulemaking: 
June 5, 2024 
Board of Health Meeting to Recommend Approval 
to the Board of Supervisors: 
July 22, 2024 
Board of Supervisors Formal Meeting to Set 
the Public Hearing: 
August 21, 2024 
Board of Supervisors Public Hearing: 
September 25, 2024 
4.
Explanation of the rule, including the control officer's reasons for initiating the
rulemaking (A.R.S. § 49-471.05(4)):
The purpose of Rule 338 (Semiconductor Manufacturing) is to limit volatile organic
compound (VOC) emissions from the semiconductor manufacturing industry. The last
significant revision to the rule occurred in 1999. The U.S. Environmental Protection
Agency (EPA) approved Rule 338 into the Arizona State Implementation Plan (SIP) on
February 9, 1998, finding the rule met reasonably available control technology (RACT)
requirements for the control of VOCs.
MCAQD is proposing to revise Rule 338 to incorporate RACT controls for nitrogen oxide
(NOx) emissions generated during the semiconductor manufacturing process. In
addition, MCAQD is proposing to revise some of the VOC controls in the rule to ensure
the controls continue to implement RACT.
On November 7, 2022, the EPA reclassified portions of Maricopa County as a moderate
nonattainment area with respect to the 2015 8-hour ozone National Ambient Air Quality
Standard. Sections 182(b)(2) and (f) of the Clean Air Act (CAA) require jurisdictions that
are classified as “moderate” or higher nonattainment to implement RACT for all sources
subject to an EPA Control Techniques Guideline (CTG) as well as for all non-CTG major
sources of VOCs or NOx.
In response to the reclassification, MCAQD identified all non-CTG major sources of NOx
and VOCs and determined whether the sources are implementing RACT through
compliance with local rules and permit conditions. During the analysis MCAQD
identified a semiconductor manufacturing facility that is a non-CTG major source for
both VOC and NOx emissions. The VOC and NOx emissions from the facility are
regulated under a Title V permit through emission limits and work practices that have
been demonstrated to meet lowest achievable emissions rate (LAER) and best available
control technology (BACT) requirements. LAER and BACT are generally considered
more stringent than RACT.
Return to list of attachments
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The permit conditions regulating the VOC and NOx emissions from the semiconductor 
manufacturing facility are not incorporated into the Arizona SIP. Sections 182(b)(2) and 
182(f) of the CAA require VOC and NOx RACT requirements for non-CTG major sources 
in ozone moderate nonattainment areas be incorporated into the SIP. Therefore, the 
MCAQD is proposing to revise Rule 338 to ensure the rule implements RACT controls 
for both VOC and NOx emissions. 
In addition to implementing RACT controls for VOC and NOx in Rule 338, MCAQD is 
proposing the following revisions: 
•
Broadening the applicability of the rule to process tool operations.
•
Removing exemptions to avoid relaxations from the Arizona SIP version of Rule
338.
•
Removing definitions for terms that are no longer used in the rule.
•
Updating and clarifying language in Section 301 (Control of VOC Emissions from
Semiconductor Manufacturing Operations).
•
Enhancing solvent cleaning station requirements and cleaning solvent
specifications.
•
Adding operating and recordkeeping requirements for Point-Of-Use (POU)
Combustion Device.
•
Updating Emission Control System (ECS) requirements to match other recently
revised rules.
•
Adding compliance schedule timeframes for ECS installation at new or existing
sources, ECS modifications, and good combustion plan submittal.
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 (A.R.S. § 49-471.05(5)).
No studies were relied on in the control officer’s evaluation of the rule.
6.
An economic, small business and consumer impact statement (A.R.S. § 49-
471.05(6)):
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 (A.R.S. §
41-1055(A)(1)):
The purpose of this rulemaking is to revise Rule 338 to incorporate RACT level controls 
that will regulate NOx emissions generated during the semiconductor manufacturing 
process. In addition, MCAQD will revise some of the VOC controls in the rule to ensure 
the controls continue to implement RACT.  
(a) The conduct and its frequency of occurrence that the rule is designed to change
(A.R.S. § 41-1055(A)(1)(a)).
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MCAQD is proposing to revise Rule 338 to incorporate RACT controls for NOx 
emissions. Additionally, MCAQD is proposing to revise some of the VOC controls in 
the rule to ensure the controls continue to implement RACT. 
(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 (A.R.S. § 41-
1055(A)(1)(b)).
Due to Maricopa County being reclassified as a moderate nonattainment area with
respect to the 2015 8-hour ozone NAAQS, MCAQD identified all non-CTG major
sources of NOx and VOCs and determined whether the sources are implementing
RACT through compliance with local rules and permit conditions. During the
analysis, MCAQD determined that there is a semiconductor manufacturing facility
that is a non-CTG major source of VOC and NOx.
Although the VOC and NOx emissions from the semiconductor facility are regulated
under a Title V permit which demonstrates LAER and BACT requirements, the permit
conditions are not incorporated into the Arizona SIP. In order to comply with
Sections 182(b)(2) and (f) of the CAA, MCAQD is required to revise Rule 338 to
ensure the rule implements RACT for both VOC and NOx. Failure to do so could
result in sanctions and imposition of a Federal Implementation Plan (FIP) under the
CAA which could adversely affect Maricopa County.
(c) The estimated change in frequency of the targeted conduct expected from the rule
change (A.R.S. § 41-1055(A)(1)(c)).
MCAQD is proposing to revise Rule 338 to incorporate RACT controls for NOx
emissions. Additionally, MCAQD is proposing to revise some of the VOC controls in
the rule to ensure the controls continue to implement RACT.
A brief summary of the information included in the economic, small business and 
consumer impact statement (A.R.S. § 41-1055(A)(2)). 
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, 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 (A.R.S. § 41-1055(A)(3)). 
Name: 
Hannah Luke or Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
Address: 
301 W. Jefferson St., Suite 410 
Phoenix, AZ 85003 
Telephone: 
602-506-6010
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Fax: 
602-506-6179
Email: 
AQPlanning@maricopa.gov 
Online: 
Submit a Comment 
An identification of the persons who will be directly affected by, bear the costs of or 
directly benefit from the proposed rulemaking (A.R.S. § 41-1055(B)(2)). 
This rulemaking will directly affect facilities in Maricopa County who are conducting 
semiconductor manufacturing operations and are not exempt as detailed in Section 103 
of the draft rule.  
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 (A.R.S. § 41-1055(B)(3)(a)).
This rulemaking should not impose any new costs on 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
(A.R.S. § 41-1055(B)(3)(b)).
This rulemaking should not impose any new costs on any political subdivision of this
state.
(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 (A.R.S. §
41-1055(B)(3)(c)).
The proposed revisions related to VOC emissions will require a 90% overall capture 
and control of VOC emissions for facilities with actual emissions of 25 or more tons 
per year (TPY). Current Rule 338 requires an 80% overall capture and control of VOC 
emissions. There are 14 permitted facilities, excluding research and development 
operations, that have Rule 338 cited in their permit conditions. Among these 
facilities, actual emissions for eight facilities are below the threshold to require an 
ECS per Section 301.1 and would not be affected by the revised VOC control 
requirement. There are five permitted facilities that have BACT requirements, which 
is considered more stringent than the proposed RACT requirements in Rule 338. 
Finally, there is one permitted facility complying with the current 80% overall capture 
and control efficiency and the facility has not indicated the increased capture and 
control efficiency would create a financial impact. 
The applicability of Rule 338 is proposed to be broadened from photoresist 
operations to process tool operations. The current version of Rule 338 requires VOC 
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controls for photoresist operations; however, the proposed revisions will regulate 
process tool operations emitting VOCs. Photoresist operations is considered an 
activity within process tool operations. This will expand the scope of VOC emissions 
required to be captured and controlled per Section 301.1. After holding two 
stakeholder workshops and four working group meetings, stakeholder feedback has 
indicated there will be no substantial financial impact on affected businesses due to 
the broadened applicability. 
Two exemptions are proposed to be removed from the rule due to potential 
backsliding from the SIP version of Rule 338. Since these exemptions are not 
currently in the SIP, adding them could potentially lead to a rule disapproval by the 
EPA. Specifically, the aggregate of up to 55 gallons per year of material and 
excepted corrosive VOC exemptions are proposed to be removed from the rule. The 
removal of these exemptions has been discussed during stakeholder workshops 
and working groups, with stakeholders indicating this would not create any 
significant financial burden.  
The proposed revisions related to NOx emissions will not require any physical 
changes to business operations but may involve some additional recordkeeping 
requirements.  
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 (A.R.S. § 41-1055(B)(4)). 
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
(A.R.S. § 41-1055(B)(5)(a)).
This rulemaking will directly affect facilities in Maricopa County who are conducting
semiconductor manufacturing operations and are not exempt as detailed in Section
103 of the draft rule.
(b) The administrative and other costs required for compliance with the proposed
rulemaking (A.R.S. § 41-1055(B)(5)(b)).
For businesses with actual VOC emissions less than 25 TPY, there would be no
additional cost. For businesses with actual VOC emissions equal to or greater than
25 TPY, compliance with the proposed 90% overall VOC capture and control of
process tool operations could result in additional costs to comply with the new
requirement. The applicability of Rule 338 from photoresist operations to process
tool operations, as well as the increased overall VOC capture and control from 80%
to 90% could require some modifications to existing ECS. As previously mentioned,
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there have been two stakeholder workshops and four working group meetings to 
discuss significant changes to the rule. Stakeholder feedback has indicated that 
there will be no substantial administrative or financial impact on affected 
businesses due to the proposed revisions. 
The proposed revisions related to NOx emissions will not require any physical 
changes to business operations but may involve some additional recordkeeping 
requirements. 
(c) A description of the methods that the agency may use to reduce the impact on
small businesses (A.R.S. § 41-1055(B)(5)(c)).
i.
Establish less stringent compliance or reporting requirements in the rule for
small businesses (A.R.S. § 41-1035(1)).
In general, 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. The rulemaking does propose a
more stringent overall VOC capture and control efficiency of 90%, which was
previously 80%. There are 14 permitted facilities, excluding research and
development operations, that have Rule 338 cited in their permit conditions.
Among these facilities, actual emissions for eight facilities are below the
threshold to require an ECS per Section 301.1 and would not be affected by the
revised VOC control requirement. There are five permitted facilities that have
BACT requirements, which is considered more stringent than the proposed RACT
requirements in Rule 338. Finally, there is one permitted facility complying with
the current 80% overall capture and control efficiency and the facility has not
indicated the increased capture and control efficiency would create a financial
impact. Due to this information, this rulemaking should not impose any new or
significant burden on small businesses.
There are also proposed revisions relating to POU Combustion Devices, which
generate a significant amount of NOx, such as maintaining either the
manufacturer’s written instructions onsite or a good combustion plan. These
requirements are administrative and should not impose any new or significant
burden on small businesses.
ii. Establish less stringent schedules or deadlines in the rule for compliance or
reporting requirements for small businesses (A.R.S. § 41-1035(2)).
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.
Section 400 “Administrative Requirements” of Rule 338 is proposed to establish
a compliance schedule for different scenarios. Sections 401.1 through 401.3
provide timeframes for complying with the ECS requirements in Section 301.1,
and Section 401.4 provides a timeframe for the good combustion plan submittal.
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These timeframes were discussed during two stakeholder workshops and four 
working groups to ensure the proposed schedules are reasonable.  
iii. Consolidate or simplify the rule's compliance or reporting requirements for
small businesses (A.R.S. § 41-1035(3)).
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 (A.R.S. § 41-1035(4)).
This rulemaking does not impose any significant new design or operational
standards on small businesses and does not establish any significant new
reporting requirements for small businesses.
v. Exempt small businesses from any or all requirements of the rule (A.R.S. § 41-
1035(5)).
This rulemaking contains some exemptions as outlined in Sections 103 of the
draft rule.
(d) The probable cost and benefit to private persons and consumers who are directly
affected by the proposed rulemaking (A.R.S. § 41-1055(B)(5)(d)).
This rulemaking should not result in any significant costs for private persons and
consumers.
A statement of the probable effect on state revenues (A.R.S. § 41-1055(B)(6)). 
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 (A.R.S. § 41-1055(B)(7)). 
The purpose of this rulemaking is to revise Rule 338 to implement RACT level controls 
for both VOC and NOx at semiconductor manufacturing operations. Failure to do so 
could result in sanctions and imposition of a FIP under the CAA which could adversely 
affect Maricopa County. 
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 (A.R.S. § 41-1055(B)(8)). 
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Not applicable. 
7.
The proposed effective date of the rule (A.R.S. § 49-471.05(7)):
The proposed effective date of this rulemaking is September 25, 2024.
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 (A.R.S. § 49-471.05(8)):
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. 
MCAQD is in compliance with A.R.S. §§ 49-112(A) and (B). Rule 338 meets A.R.S. § 49-
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112(A)(1) by demonstrating that the rule is necessary to address a peculiar local 
condition, in that Maricopa County fails to meet the 2015 8-hour NAAQS for ozone. Rule 
338 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 semiconductor 
manufacturing industry. As there is no new fee or tax associated with this proposed 
rulemaking, the MCAQD also affirms that Rule 338 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(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:  
March 9, 2023  
Notice of First Stakeholder Workshop: 
March 20, 2023 
Notice of Second Stakeholder Workshop:  
January 23, 2024 
Notice of First Board of Health Meeting: 
 
April 10, 2023  
Notice of Proposed Rulemaking: 
 
June 5, 2024  
Notice of Second Board of Health Meeting: 
July 8, 2024  
(b) The following discussion addresses each of the elements required for a concise
explanatory statement, as prescribed by A.R.S. § 49-471.07(B):
i.
A description of any change between the proposed rule or ordinance, the final
rule or ordinance or notice of final supplemental rule or ordinance.
The following changes were made after the Notice of Proposed Rulemaking
was published on June 5, 2024:
1. Added subsection 102.3 under Section 102 Applicability. This section now
reads as follows:
“This rule does not apply to the solvent cleaning of equipment or parts that
is performed for purposes other than semiconductor manufacturing and
such activity shall be subject to requirements of Rule 331 (Solvent
Cleaning) of the MCAPCR.”
2. Revised subsection 103.4. The paragraph now reads as follows:
“Wipe Cleaning: Wipe cleaning is subject to the applicable requirements of
Rule 331 (Solvent Cleaning) of the MCAPCR.”
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3. Added the phrase “using the County’s public records request process” to
Section 501.3. This section now reads as follows:
“Records shall be made available to the Control Officer upon request by
members of the public using the County’s public records request process.”
4. Added subsection 501.4 under Section 501 and adjusted the numbering in
Section 501 as a result of the added subsection. This subsection reads as
follows:
“Records shall be kept on site at all times in a consistent and complete
manner.”
5. Added the phrase “smaller of either the length or” to Section 204. This
section now reads as follows:
“The freeboard height divided by the smaller of either the length or width of
the solvent cleaning machine.”
6. Revised subsection 103.1. The paragraph now reads as follows:
“Except for Sections 304, 305, and 501, this rule shall not apply to those
operations within a semiconductor manufacturing facility which are used
exclusively for one or more of the following: chemical or physical analysis,
determination of product quality or commercial acceptance, research and
development, or pilot plant activities. Such operations may be exempted
until the 12-consecutive month VOC emissions from all such exempted
operations reaches but does not exceed 7.3 tons. This exemption shall not
apply to a particular operation if the exemption is denied in writing by the
Control Officer.”
ii. A summary of the comments and arguments for and against the notice and
the county’s response to the comments and arguments.
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. MCAQD received written
comments from five (5) stakeholders. All of the comments were reviewed and
evaluated by MCAQD.
Comment #1:
Have received some comments about Rule 338 Section 301 that will be a large
issue regarding process tools that use acids, bases and VOCs that are
exhausted to non-VOC ECS and there is no longer capture/control efficiency
allowed as now that fabs have designed for. The definition of ECS requires only
using VOC control we believe. This includes some process tools that have
existing and future POU abatement units and exhausted to wet scrubbers. Can
we please add below for POU abatement unit discussion next week?
Return to list of attachments
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Response #1: 
Revisions to the definition of Process Tool in Section 210 were made to ensure 
the broadened applicability of the rule does not inadvertently require abatement 
of pollutants that aren’t suitable for VOC abatement devices.  
Section 210 reads as follows: “equipment used during the semiconductor 
fabrication process to perform various operations needed to make the final 
product. This does not include equipment that uses solvent in ashing, plasma 
etch, diffusion and chemical vapor deposition processes.” The italicized 
language was added to the definition of Process Tool to remove process tools 
emitting pollutants that are not suitable for VOC abatement from the VOC 
abatement requirements in Section 301.  
Comment #2:  
Thank you for incorporating our feedback into the draft rule. 
As for the suggested language in Section 301 we recommend the following 
clarifications: 
CONTROL OF PHOTORESIST VOC EMISSIONS FROM SEMICONDUCTOR 
MANUFACTURING OPERATIONS: An owner or operator of a semiconductor 
manufacturing operation that annually emits more than 25 tons of VOCs from 
aggregated photoresist and process tool operations that solely emit VOCs, 
prior to any emissions controls, shall maintain such operations under negative 
pressure per Section 503.3 route captured air to an approved emission control 
system (ECS), and meet one of the following requirements: 
301.1 Achieve at least 90% overall VOC capture and control of aggregated 
photoresist and process tool operations that solely emit VOCs, determined by 
applicable provisions in Section 503.3; or 
301.2 Route captured air to an approved emission control system (ECS) 
and achieve an outlet concentration less than or equal to 10 ppmv VOC 
concentration measured as propane, as determined by applicable provisions in 
Section 503. 
Response #2:  
MCAQD considered your comment and revised the section as follows: 
“301 CONTROL OF PHOTORESIST VOC EMISSIONS FROM SEMICONDUCTOR 
MANUFACTURING OPERATIONS: 
301.1 An owner or operator of a semiconductor manufacturing operation that 
discharges 25 or more tons of VOCs per year from aggregated 
photoresist and process tool operations, prior to any emissions controls, 
shall maintain such operations under negative pressure, per Section 
503.3 and meet one of the following requirements: 
a. Achieve at least 90% overall VOC capture and control of aggregated
photoresist and process tool operations, determined by applicable
provisions in Section 503.3; or
b. For VOC input-concentrations of less than 100 ppmvd (as propane) at
the inlet of the ECS, the control efficiency is satisfied if the VOC outlet
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concentration is less than or equal to 10 ppmvd (as propane), as 
determined by applicable provisions in Section 503.4.” 
Comment #3:  
In addition, we suggest the following changes to the draft rule: 
Section 401: The timeframe for achieving compliance is unclear. NXP will be 
installing a new VOC abatement that is already included in our permit 
equipment list as future and thus it will not require a minor modification. We 
are not sure if this qualifies as a new installation. If the new installation didn’t 
require a permit application it would be clear that this is a new installation. 
Perhaps the proposed section 401.1 could be changed to: 
a. Within 18 months of becoming subject to the ECS requirements in Section
301 of this rule, submit a compliance schedule and permit application (or
notification in lieu of permit application if already permitted as future
abatement) to the Control Officer.
b. Within 36 months of final permit issuance (or notification in lieu of permit
issuance if already permitted as future abatement), be fully compliant with
the ECS requirements in Section 301 of this rule and submit to the Control
Officer a complete source test report indicating compliance.
Response #3:  
MCAQD revised the rule language as suggested. 
Comment #4:  
Section 209:  SOLVENT: Any liquid or vapor which is used to dissolve, clean, 
strip, or remove impurities, coatings, contaminants, or films from surfaces or 
from internal spaces and voids. This includes, but is not limited to, developers 
and stripping agents. In addition to VOC-containing solvents, this also 
includes plain water and mixtures containing water. 
Response #4:  
Section 209 was renumbered to Section 212 and revised to read as suggested. 
Comment #5:  
Section 304.4: Good Combustion Practices for POU Devices: Operate and 
maintain equipment in accordance with the manufacturer’s written 
instructions for good combustion practices. 
Response #5:  
Section 304.4 was renumbered to Section 305.3 and revised to read as follows: 
“Operate and maintain equipment in accordance with the manufacturers or 
manufacturers authorized service provider written instructions for good 
combustion practices.” 
Comment #6:  
Section 305.1: 
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Replace “operation” with “operator” in ECS Requirements: An owner 
or operation operator of an emission control system (ECS) at a semiconductor 
manufacturing facility shall … 
305.1 a. – Add hydrogen as an option for fuel: Only use natural gas, 
butane, hydrogen or propane as fuel. 
Response #6:  
Section 305.1 was renumbered to Section 306.1 and revised to read as 
suggested. Section 305.1(a) was renumbered to Section 306.1(a) and revised 
to read as suggested. 
Comment #7:  
Section 501.4 b.: 
Good Combustion Practices: Maintain records of all maintenance and 
calibration activities related to POU devices maintenance activities related to 
good combustion practices of the POU devices. 
Response #7:  
Section 501.4(b) was renumbered to Section 501.8 and revised to read as 
follows:  
“An owner or operator of a POU Combustion Device shall comply with the 
recordkeeping requirements in Section 501.8(a) or Section 501.8(b): 
a. Manufacturer’s Operation and Maintenance: Maintain the following records
onsite and available to the Control Officer upon request:
(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary.
b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.”
Comment #8:  
Section 502.3: Suggest this change: 
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.  
Response #8:  
MCAQD considered your comment and revised the section as follows:  
“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 3 business days of the maintenance completion.” 
Comment #9: 
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DRAFT RULE 338 COMMENTS 
Section 207: POINT-OF-USE (POU) DEVICE 
Intel proposes the following definition of POU device, consistent with the 
November 27, 1995 United States Environmental Protection Agency (USEPA) 
letter to Tim Mohin (EPA Letter, Attachment 1), Maricopa County Environmental 
Services Department, Air Quality Division’s June 4, 2001 Optional Compliance 
Demonstrations Guidance (MCAQD Guidance, Attachment 2), and the scope of 
Rule 338:  
Section 207 proposed language: 
POINT-OF-USE DEVICE: A device that is installed in close proximity to process 
equipment, is a source of combustion which generates NOx, and is installed for 
the primary purpose of abating regulated air pollutants.  
Justification:  
The current draft definition of POU device seeks to expand upon the historical 
definition of POU in the USEPA Letter and MCAQD Guidance document 
referenced above by including equipment installed for safety and industrial 
hygiene purposes. 
Equipment installed for safety and/or industrial hygiene purposes are part of 
the process tool and are not air pollution control devices; they are defined as 
exhaust conditioners, not POUs, and are ‘considered by the EPA to be inherent 
to the process’. The EPA Letter provides ‘Criteria for Determining Whether 
Equipment is Air Pollution Control Equipment or Process Equipment’ and lists 
three questions to consider when making the determination: 
1. Is the primary purpose of the equipment to control air pollution?
a. No, the primary purpose of the equipment is for safety and/or
industrial hygiene.
2. Where the equipment is recovering product, how do the cost savings from
the product recovery compare to the cost of the equipment?
a. Not applicable.
3. Would the equipment be installed if no air quality regulations are in place?
a. Yes. The equipment installed for safety and/or industrial hygiene
purposes is only one part of the process tool and is a required part
regardless of air quality regulations. The equipment is interlocked with
the process chambers, therefore the process cannot operate unless
the equipment is in use.
Additionally, MCAQD’s Guidance, defines POUs as being ‘installed in close 
proximity to the process equipment and is installed for the purpose of abating 
regulated pollutants. The definition also states, ‘Normally, a POU is not 
interlocked with the associated process equipment.’ The equipment installed 
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for safety and/or industrial hygiene purposes does not meet the definition of 
POU because it is not installed for the purpose of abating regulated pollutants, 
and it is interlocked with the process chamber. Instead, MCAQD’s Guidance 
defines the equipment in question as exhaust conditioners because they ‘are 
used for safety and/or industrial hygiene purposes and are always interlocked 
to the process equipment’. 
The current draft definition of POU device, if left unchanged, would encompass 
over one thousand pieces of equipment at the Intel Ocotillo facility (soon to be 
~1,500 with the startup of Fabs 52 and 62). While Intel understands this is an 
ozone RACT rule which would include NOx emissions, the manner in which this 
draft Rule 338 seeks to do so presents a significant burden. The resources that 
would be required to track the POUs as currently defined and comply with the 
draft recordkeeping requirements on more than 1,500 pieces of equipment 
would be immense, and as Rule 338 is intended to satisfy RACT requirements, 
cost and practicality must be considered. Further, the emissions from the 
equipment in question are exhausted to downstream emission sources which 
are regulated for NOx and VOCs in our facility Permit. These Fab Emission 
points are subject to routine performance testing to demonstrate compliance 
with existing Permit limits.  
In summary, exclusion of equipment installed for safety and industrial hygiene 
purposes from the POU device definition, as was the historical approach by 
both the EPA and MCAQD, in conjunction with the proposed revisions to the 
subsequent sections highlighted below would make the requirements of this 
revised Rule more practically executable from the industry perspective.  
Response #9:  
The definition of Point-of-Use Device in Section 207 was renumbered to Section 
209 and revised to read as follows:  
“Point-of-Use Combustion Device: A device that is installed in close proximity to 
process equipment and is a source of combustion which generates NOx 
emissions.” 
Comment #10:  
Section 304.3: Monitoring Devices 
Intel requests that Section 304.3 be revised to the following: 
Monitoring Devices: For the ECS, provide, properly install and maintain in 
calibration, in good working order, and in operation, devices for indicating or 
recording temperatures, pressures, rates of flow, concentrations or other 
operating parameters required by the O&M Plan for determining if air pollution 
control equipment or other means of control are functioning properly. 
Justification:  
This aligns with the VOC abatement equipment requirements described in other 
parts of this revised Rule.  
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Response #10:  
Section 304.3 was renumbered to Section 306.3 and revised to read as follows: 
“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 and in operation 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 301.1 of this rule and is operated in accordance with the 
equipment manufacturer's specifications.” 
Comment #11:  
Section 304.4: POU Devices  
Intel requests that Section 304.4 be revised to the following:  
Operate and maintain equipment in accordance with the manufacturer’s or 
operator’s written instructions for good combustion practices.  
Justification:  
Intel’s New Source Review permit, approved by EPA and MCAQD in August 
2021, required the facility to complete a LAER determination. In the LAER 
determination, LAER of wet acid scrubbers was essentially equated to LAER of 
POUs since all of the NOx emitted from the wet scrubbers is from the POUs. 
The approved LAER determination stated the following:  
“Section 2.3: NOx LAER for Fab 52 and 62 Wet Scrubbers: 
Fab Wet Scrubbers: Good Combustion Practices and maintaining POUs per 
Intel Specifications”  
Based on the above, and because this was a LAER determination, Intel believes 
that following operator or manufacturer good combustion practices satisfies 
the RACT requirements.  
Response #11:  
Section 304.4 was renumbered to Section 305.3(a) and revised to read as 
follows:  
“Operate and maintain equipment in accordance with the manufacturers or 
manufacturers authorized service provider written instructions for good 
combustion practices.” 
Comment #12:  
Section 501.4 POU Device Recordkeeping:  
Intel requests that section 501.4 be revised to the following: 
a. Operations and Maintenance: Maintain the manufacturer’s or operator’s
recommended written instructions to minimize facility NOx and available to
the Control Officer upon request.
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b. Good Combustion Practices: Maintain records of activities performed to
demonstrate good combustion practices for POU devices.
Justification:  
There is no basis for stating that Preventative Maintenance (PM) performed on 
a POU device would lower NOx emissions. The POU units were designed to 
achieve the highest destruction efficiency of the target pollutant(s), but 
typically, this would not be NOx. Even changing recommended settings on a 
POU unit during a combustion-related PM could cause NOx emissions to be 
higher if any of the following parameters are adjusted:  

Natural gas flow rate;

Temperature;

Air/Fuel ratio; and/or

The amount of nitrogen-containing compounds used in the manufacturing
process.
Response #12:  
Section 501.4 was renumbered to Section 501.8 and revised to read as follows: 
“a. Manufacturer’s Operation and Maintenance: Maintain the following records 
onsite and available to the Control Officer upon request: 
(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary.
b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.”
Comment #13:  
Here is our draft proposed revision to Rule 338. 
304.4. Good Combustion Practices for POU Devices: 
a. Operate and maintain equipment in accordance with the manufacturer’s or
operator's written instructions.  OR
b. On an annual basis, conduct a variability analysis of the normalized volume
of natural gas consumed per POU device.
Response #13:  
Section 304.4 was renumbered to Section 305.3 and revised to read as follows: 
“An owner or operator of a POU Combustion Device shall comply with one of 
the following requirements: 
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a. Operate and maintain equipment in accordance with the manufacturers or
manufacturers authorized service provider written instructions for good
combustion practices; or
b. Submit to the Control Officer for approval a Good Combustion Plan that
includes, at a minimum, the following information:
(1) Company name and address;
(2) A summary of POU combustion devices installed;
(3) A list and description of good combustion maintenance practices and/or
NOx emission monitoring methods; and
(4) A description of malfunction procedures and responses.”
Comment #14:  
Here is our draft proposed revision to Rule 338. 
504.1.c.  For good combustion practices demonstrated through the 
requirements of 304.4.b, record the results of the variability analysis. If the 
variability of natural gas usage per POU exceeds [xxx%] then perform an 
assessment and document: 
a. Changes to facility operations which accounts for the increase in natural gas
usage per POU; or
b. Any actions taken to return natural gas usage per POU to within the
established variability limit.
Response #14: 
Section 504.1 was renumbered to Section 501.8 and revised to read as follows: 
“An owner or operator of a POU Combustion Device shall comply with the 
recordkeeping requirements in Section 501.8(a) or Section 501.8(b): 
a. Manufacturer’s Operation and Maintenance: Maintain the following records
onsite and available to the Control Officer upon request:
(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary.
b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.”
Comment #15:  
According to the staff report, the Maricopa County Air Quality Department 
(MCAQD) is proposing to revise Rule 338 to incorporate Reasonably Available 
Control Technology (RACT) level controls that will regulate emissions 
generated during the semiconductor manufacturing process. In addition, 
MCAQD will review the VOC controls in Rule 338 and ensure the controls 
implement RACT. We are concerned that the proposed changes to Rule 338 do 
not take into consideration pollution prevention processes such as UV/EB/LED. 
RadTech believes that Rule 338 presents an opportunity for Maricopa County to 
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achieve voluntary emission reductions above and beyond those presently 
required in the rule, through regulatory flexibility that will encourage conversion 
to UV/EB/LED. In its current form, Rule 338 seems to focus on Emission 
Control Systems (ECS) as the only means of compliance. The one sided 
approach, unfairly excludes pollution prevention technologies such as 
UV/EB/LED and puts our businesses at disadvantage as compared to systems 
using conventional solvents with ECS. Thus, our organization cannot support 
the rule in its current form.  
Response #15:  
Rule 338 does not require facilities that emit less than 25 tons of VOCs per year 
to install an ECS. This emission threshold encourages alternative emission 
reduction methods, such as the use of materials with lower VOC contents. 
Facilities are not discouraged from utilizing alternative emission reduction 
measures as long as the activities comply with the provisions in Rule 338.  
Comment #16:  
Section 103.2—Exemptions  
Our materials are typically well below 50 grams/liter in VOC content. The rule 
groups materials ranging from 2 grams per liter to 100 grams per liter. We 
would suggest an intermediate VOC content of 50 grams per liter and 
respectfully request that UV/EB/LED materials with a VOC content of 50 grams 
per liter or less be exempted from 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. 
Response #16:  
Proposed revisions to Rule 338 include revisions to the exemption for low-VOC 
materials. The revisions are intended to make the low-VOC exemption in the 
proposed rule more closely match the low-VOC exemption in SIP Rule 338 to 
avoid backsliding concerns. SIP Rule 338 includes a partial exemption for 
liquids in positive photoresist processes which contain less than 10 percent 
VOC by weight and never exceed a temperature of 104° F. These materials are 
exempt from being included in emission calculations subject to positive 
photoresist control requirements, being controlled by an emission control 
system (ECS), and do not need to be included in determining the efficiency of a 
required ECS. 
Proposed language in Section 103.2 will partially exempt materials containing 
less than 10% VOC by weight if unheated, or less than 2.5% VOC by weight if 
heated, from Sections 301, 302, 303, and 306 of the rule. Should UV/EB/LED 
materials qualify for the partial exemption, then there will be minimal 
requirements to comply with the rule.    
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 
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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.  
Comment #17:  
Section 200—Definitions  
The rule narrowly focuses the definitions section on ECS. This approach does 
not take into consideration other technologies and may have the unintended 
consequence of giving a certain process an unfair competitive advantage. The 
rule should be technology neutral and include definitions for all available 
technologies. 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 #17:  
Thank you for providing the MCAQD with a definition for energy curable 
materials. However, a definition is not necessary since the MCAQD will not be 
including any additional provisions regarding these materials in Rule 338.  
Comment #18:  
Section 503—Compliance Determination  
This Section is especially problematic because Rule 338 does not specify a test 
method for energy curable materials in Section 504. The current rule language 
states:  
“When more than one test method is permitted for a determination, an 
exceedance of the limits established in this rule determined by any of the 
applicable test methods constitutes a violation of this rule.”  
The lack of clarity as related to acceptable test methods may put out the 
businesses we represent at risk of enforcement action by Maricopa County. We 
ask that Section 504 be clarified to include test methods for UV/EB/LED (see 
comments on Section 504).  
Response #18:  
If there are no suitable EPA approved test methods incorporated into Rule 338 
for UV/EB/LED products, an alternative approach is to use the Safety Data 
Sheet (SDS) or technical datasheets to verify the VOC content of the materials. 
This information is commonly relied on by MCAQD to determine compliance 
and has been used when determining compliance for UV/EB/LED coatings 
used at regulated facilities within the county.  
Comment #19:  
Section 504--Test Methods 
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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. The RadTech 
Association looks forward to working with Maricopa County on this rulemaking 
and would gladly provide any additional information your staff may need.  
Response #19:  
Since ASTM D7767-11 is not currently an EPA-approved test method, the 
MCAQD cannot include it in Rule 338. Adding a test method that is not EPA-
approved to this rule could jeopardize EPA’s approval of Rule 338 into the SIP. 
However, Section 504 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 #20:  
Proposed Rule 338 Language 
OPERATING REQUIREMENTS  
304.4. Good Combustion Practices for POU Devices: 
a. Operate and maintain equipment in accordance with the manufacturer’s or
operator's written instructions, or
b. On an annual basis, conduct a variability analysis of the normalized volume
of natural gas usage per POU device per day as outlined by Sections 304.4.b.i
through 304.4.b.iv.
  
i.
Establish and record the facility's normalized baseline natural gas usage per
POU device per day using the quantity of installed POU devices and the
associated natural gas design specifications or manufacturer's
recommendations.  
ii. On an annual basis, determine and record the facility's normalized natural
gas usage per POU per day using actual natural gas usage data for a single
month and the quantity of installed POU devices for that same month.
Calculate and record the percent change between the baseline and annual
natural gas usage per POU per day.  If the variability of natural gas usage
per POU exceeds [xx%], perform an assessment and record:
1. Changes to facility operations which account for the increase in
normalized natural gas usage per POU per day; or
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2. Any actions taken to return the normalized natural gas usage per POU
per day to within the established variability limit.
iii. The initial baseline shall be established within 6 months of adoption of this
Rule revision and the first variability analysis performed within 1 year of
adoption of this Rule revision.
iv. A new baseline shall be established and recorded every 5 years or when the
variability analysis exceeds the threshold set forth Section 304.4.b.ii and the
increase in natural gas usage per POU device per day is accounted for by
changes to facility operations, whichever comes first.
  
Response #20:  
Section 304.4 was renumbered to Section 305.3 and revised to read as follows: 
“An owner or operator of a POU Combustion Device shall comply with one of 
the following requirements: 
a. Operate and maintain equipment in accordance with the manufacturers or
manufacturers authorized service provider written instructions for good
combustion practices; or
b. Submit to the Control Officer for approval a Good Combustion Plan that
includes, at a minimum, the following information:
(1) Company name and address;
(2) A summary of POU combustion devices installed;
(3) A list and description of good combustion maintenance practices and/or
NOx emission monitoring methods; and
(4) A description of malfunction procedures and responses.”
Comment #21:  
Proposed Rule 338 Language 
MONITORING AND RECORDS   
501.4.c.  For good combustion practices demonstrated in accordance with 
Section 304.4.b, the Permittee shall maintain a record of the data required to 
perform the variability analysis and any subsequent assessments as required 
by Section 304.4.b.ii. The records shall be kept on site and made available to 
the Control Office upon request.  
Response #21:  
Section 501.4 was renumbered to Section 501.8 and revised to read as follows: 
“a. Manufacturer’s Operation and Maintenance: Maintain the following records 
onsite and available to the Control Officer upon request: 
(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary.
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b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.”
Comment #22:  
Please see attached for our proposed Good Combustion Plan to satisfy the 
draft Rule 338 language that we discussed in our last meeting.  We also have 
the following two comments [comment below and comment #24] on the 
proposed Rule language: 
304.4.b.(3) A list and description of all good combustion maintenance 
practices and/or NOx emission monitoring methods. 
Response #22:  
Section 304.4(b)(3) was renumbered to Section 305.3(b)(3) and revised to read 
as suggested. 
Comment #23:  
501.4.b Good Combustion Plan: Maintain a Good Combustion Plan as required 
in Section 304.4(b). The plan must be updated annually to contain current 
information. Any change from to the plan shall be documented. 
Response #23:  
Section 501.4(b) was renumbered to Section 501.8(b) and revised to read as 
follows: 
“Maintain a Good Combustion Plan as required in Section 305.3(b). The plan 
must be reviewed every year and updated as needed to contain current 
information. The annual review and any change to the plan shall be 
documented.” 
Comment #24:  
NXP does not object to removing the corrosive VOC exception as long as 
additional clarifications are made in section 301. 
•
We propose the following revision to the final statement in section 301. Any
VOC emissions not controlled per Section 301.1 or 301.2 shall be assumed
to have evaporated onsite unless records show that VOC-containing
material was sent offsite for legal disposal. Records of legal disposal 
include but are not limited to shipping papers or quantity discharged to 
sewage treatment works. 
•
In addition, please add to section 301 the following language which was
originally in section 502.3 “Emission factors acceptable to the Control
Officer are allowed to be used in calculating VOC emissions.”
Organic silicon compounds are not suitable to be abated by VOC abatement 
systems typically used by the semiconductor industry.  The exception for 
organic silicon compounds allows for exception of up to one ton per year.  At 
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NXP, the organic silicon compound material used is hexamethyldisilazane 
(HMDS). When treated by a thermal oxidizer, this material deposits silicon 
dioxide in the oxidizer and adversely affects the operation of the ECS. This 
exception allows for better operation of the ECS by diverting the HMDS to the 
house water scrubbers.  As the Title V thresholds for VOC decrease and the 
overall capture and control requirements increase, this exception will become 
more and more important. 
Response #24:  
MCAQD considered your comments and revised Section 301.2 to read as 
follows: 
“Any VOC emissions not controlled per Section 301.1 shall be assumed to have 
evaporated onsite unless: 
a. Records demonstrating otherwise can be provided to the Control Officer per
Section 501.7; or
b. The VOC emissions are accounted for in emissions calculations per Section
503.9.”
Additionally, Section 501.7 was revised to read as follows:  
“Sources complying with Section 301.2(a) shall maintain monthly records of 
the type, amount, and method of disposing of VOC-containing materials. 
Records of legal disposal include but are not limited to shipping papers or 
quantity discharged to sewage treatment works.” 
Comment #25:  
Upon further review of the latest version of the draft rule we have identified a 
couple of other clarifications/changes that we would like you to consider as 
part of the rule changes. 
We would like to ask about this statement in section 301.2: “… achieve an outlet 
concentration less than or equal to 10 ppmv VOC concentration measured as 
propane”.  
Since in our current air permit it is stated: “ … outlet concentration of less than 
or equal to 10 ppmv measured as methane”, we are wondering if this change 
(from methane to propane) is intentional. We believe it is not difficult to 
measure VOC concentration as propane or methane. We just want to make 
sure this change is intentional. 
Response #25:  
The decision to choose the outlet concentration measurement as propane 
rather than methane is due to the intent to implement RACT level controls in 
Rule 338. Setting the outlet concentration less than or equal to 10 ppmvd 
measured as methane would be three times more stringent than 10 ppmvd 
measured as propane due to 10 ppmvd as propane being equivalent to 30 
ppmvd as methane. 
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The Best Available Control Technology (BACT) Determination located on the 
MCAQD website details BACT for VOCs at a Semiconductor Manufacturing 
Facility as follows:  
“The control device shall achieve a VOC destruction efficiency of at least:  
1) 98.5% when the inlet VOC concentration is greater than or equal to 2,000
ppmv measured as methane; or
2) 97% when the inlet VOC concentration is greater than or equal to 200 but
less than 2,000 ppmv measured as methane; or
3) 90% when the inlet VOC concentration is less than 200 ppmv measured as
methane.
4) As an alternative to the destruction efficiency requirements of items 1) – 3)
above, the oxidizer shall achieve an outlet concentration of less than or equal to
10 ppmv VOC measured as methane.”
Ultimately, it was determined that “as propane” is less stringent than “as 
methane” and is more appropriate for the purposes of RACT. 
Comment #26:  
Modify the language in section 303.3 to: Convey VOC-containing materials from 
one location to another in closed containers or pipes or convey to sewage 
treatment works. 
As part of the wastewater permit compliance sampling, sites are required to 
have open flume sampling locations that allow for collection of a composite 
samples of wastewater discharge. As the wastewater passes through the 
flume, it is not in a closed pipe. 
Response #26:  
Section 303.3 was renumbered to Section 304.3 and converted back to current 
rule language and reads as follows: 
“Disposal of waste or surplus VOC-containing materials shall be done in a 
manner that does not promote VOC evaporation, such as, but not limited to, via 
sewage treatment works or having the waste hauled off-site in sealed 
containers.” 
Comment #27:  
Modify section 304.4 b. (3) to: A list and description of good 
combustion maintenance practices and/or NOx emission monitoring methods 
and; 
Response #27:  
Section 304.4(b)(3) was renumbered to Section 305.3(b)(3) and the language 
was revised as suggested. 
Comment #28: 
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Modify the new section 501.3 to:  Records of Disposal: Maintain records of the 
type, amount, and method of disposing of VOC-containing materials on each 
day of disposal. 
The NXP air permit currently requires monthly tracking of VOC disposal 
records. Shipping records are kept for each day material is shipped. For 
materials that are discharged to sewage treatment works, disposal estimates 
are made based on monthly usage records and emission factors acceptable to 
the Control Officer. 
Response #28:  
Section 501.3 was renumbered to Section 501.7 and revised to read as follows: 
“Sources complying with Section 301.2(a) shall maintain monthly records of 
the type, amount, and method of disposing of VOC-containing materials. 
Records of legal disposal include but are not limited to shipping papers or 
quantity discharged to sewage treatment works.” 
Comment #29:  
Modify section 501.4 a. (2) to: Records of any malfunctions and corrective 
actions, if necessary that could result in an increase of combustion emissions. 
Response #29:  
Section 501.4(a)(2) was renumbered to Section 501.8(a)(2) and revised to read 
as follows: 
“Records of any malfunctions that could result in an increase of NOx emissions 
and corrective actions, if necessary.” 
Comment #30:  
Modify section 501.4 b. to: Good Combustion Plan: Maintain a Good 
Combustion Plan as required in Section 304.4(b). The plan must be 
updated when needed annually to contain current information. Any change to 
the plan shall be documented.  If there is no change needed, annual update 
seems unnecessary. 
Response #30:  
Section 501.4(b) was renumbered to Section 501.8(b) and revised to read as 
follows: 
“Maintain a Good Combustion Plan as required in Section 305.3(b). The plan 
must be reviewed every year and updated as needed to contain current 
information. The annual review and any change to the plan shall be 
documented.” 
Comment #31:  
Couple of Rule 338 questions below. 
1. Does new 501.2c [previously 502.2(c)] apply any more as 10% VOC or less
exemption has been removed?
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2. New 502.1: the way it reads I believe is all items listed has to be done and
then more that is listed in O&M Plan. On flow rates, do not believe these
need to be done daily per EPA Methods 1 – 4 as accepted methods. Has
this been discussed before?
3. New 503.2: should 25A and 25B be listed in addition to 25 as approved
methods later on in rule?
Response #31: 
1. The language in previous Section 502.2(c) is proposed to be removed from
the rule. There is a partial exemption for Low-VOC Materials in Section
103.2, however, these materials are not exempt from the recordkeeping
requirements in Section 501. Previous Section 502.2(c) required annual
usage records for low-VOC materials and supporting documentation
reflecting the VOC content. Section 501.5 and 501.6 still require this
information.
2. MCAQD considered your comments and revised the provision as follows:
“On each day a required 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 which may include the
following, when applicable:
a. Flow rates;
b. Pressure drops;
c. Temperature; or
d. Other operating conditions necessary to determine if the approved ECS is
functioning properly.”
3. MCAQD considered your comment and revised the provision as follows:
“An ECS used pursuant to Section 301.1 shall be tested at least once every
five years using EPA Methods 18 (40 CFR 60, Appendix A-6), 25, 25A, or 25B
(40 CFR 60, Appendix A-7). VOC emission shall be measured and calculated
as propane.”
Comment #32:  
Just a couple of clarifications on the proposed changes to the exemptions. 
Intel was using the exemptions in Rule 338 
103.6 Wipe Cleaning: Wipe cleaning shall be subject to the solvent cleaning 
Rule 331 of the Maricopa County Air Pollution Control Rules and Regulations. is 
not subject to Section 300, but the usage of VOC-containing solvent for wipe 
cleaning is subject to the recordkeeping provisions of Section 500. 
Intel did not have to apply Wipe Cleaning to any standards in Section 300, but 
was required to the recordkeeping provisions of Section 500 
Response #32:  
Section 103.6 was renumbered to Section 103.4 and revised to read as follows: 
“Wipe cleaning is subject to the applicable requirements of Rule 331 (Solvent 
Cleaning) of the MCAPCR.” 
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The requirements for wipe cleaning activities in Rule 331 are solvent handling 
requirements (i.e., storage in closed containers, label containers, proper 
disposal) and recordkeeping requirements (i.e., current list, usage records, 
disposal records).  
Comment #33:  
103.7 APPLICABILITY OF RULE 331 Solvent Cleaning for Support 
Operations: The solvent cleaning of equipment or parts that is performed for 
purposes other than semiconductor manufacturing shall be subject to the 
solvent cleaning Rule 331 of these Maricopa County Air Pollution Control Rules 
and Regulations. 
We were using this exemption because we did not have any solvent cleaning of 
any other equipment besides those associated with semiconductor 
manufacturing. 
Will those exemptions be written into a revised Rule 331? 
Response #33:  
Section 103.7 was renumbered to Section 102.3 and revised to read as follows: 
“This rule does not apply to the solvent cleaning of equipment or parts that is 
performed for purposes other than semiconductor manufacturing and such 
activity shall be subject to requirements of Rule 331 (Solvent Cleaning) of the 
MCAPCR.” 
This provision is listed under Section 102 - Applicability. If your operation does 
not conduct any solvent cleaning related to Rule 331 (aside from wipe 
cleaning), then you will not be required to meet the applicable provisions in Rule 
331.  
Comment #34: 
Please see below for our proposed revisions to the Rule 338 language we 
discussed in the last stakeholder meeting...  If you have any questions, please 
let us know. 
301.3 Any VOC emissions not controlled per Section 301.1 or 301.2 shall be: 
a. assumed to have evaporated onsite unless adequate records
demonstrating otherwise can be provided to the Control Officer, or
b. accounted for in emissions calculations as approved by the Control Officer
and specified in the facility’s air permit requirements.
Response #34: 
Section 301.3 was renumbered to Section 301.2 and revised to read as follows: 
“Any VOC emissions not controlled per Section 301.1 shall be assumed to have 
evaporated onsite unless: 
a. Records demonstrating otherwise can be provided to the Control Officer per
Section 501.7; or
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b. The VOC emissions are accounted for in emissions calculations per Section
503.9.”
Comment #35:  
Please see below for our proposed revisions to the Rule 338 language we 
discussed in the last stakeholder meeting...  If you have any questions, please 
let us know. 
501.3 Records of Disposal: Facilities complying with Section 301.3(a) must 
maintain monthly records of the type, amount, and method of disposing of 
VOC-containing materials. Records of legal disposal include but are not limited 
to shipping papers or quantity discharged to sewage treatment works. 
Response #35:  
Section 501.3 was renumbered to Section 501.7 and revised to read as follows: 
“Sources complying with Section 301.2(a) shall maintain monthly records of 
the type, amount, and method of disposing of VOC-containing materials. 
Records of legal disposal include but are not limited to shipping papers or 
quantity discharged to sewage treatment works.” 
Comment #36:  
Thank you for making additional changes to the draft rule. As for the statement 
about acceptable records for demonstrating compliance with Section 301, we 
still feel that it’s important to make it clear that VOC emissions are allowed to 
be calculated based on approved emission factors. This is because 
emissions of some corrosive VOCs (which are no longer exempt from rule 338) 
can’t be calculated based on waste records. In our case these emissions and 
discharged amounts are based on calculations. We believe 
that either expanding the below statement or adding the following language 
(which was originally in section 502.3) “Emission factors acceptable to the 
Control Officer are allowed to be used in calculating VOC emissions.” to section 
301 would make this more clear. 
“Any VOC emissions not controlled per Section 301.1 or 301.2 shall be 
assumed to have evaporated onsite unless calculations accepted by the 
control officer or adequate records demonstrating otherwise can be provided 
to the Control Officer.” 
Response #36:  
MCAQD considered your comments and revised the provision to read as 
follows:  
“Any VOC emissions not controlled per Section 301.1 shall be assumed to have 
evaporated onsite unless: 
a. Records demonstrating otherwise can be provided to the Control Officer per
Section 501.7; or
b. The VOC emissions are accounted for in emissions calculations per Section
503.9.”
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Comment #37:  
In addition to our earlier comments (submitted on 10/2) which might be already 
included in the latest draft of rule 338 (presented in the meeting on 10/17 but 
not sent out yet), we would like to also propose a modification of the term 
“Process Tool” and “Solvent”. Upon further review of the draft rule and 
discussion with [a consultant] we’ve realized that the current definition of 
Process Tool could be interpreted as including all process tools that use VOCs. 
This would mean that even fluorinated gases like CH3F used in etch processes 
would fall under this rule. We believe this was not the intent of this rule as the 
statement in section 503.7 refers to “other VOCs” and further down in the same 
section “etchant VOC” is used as an example of the “other VOC”. 
PROCESS SOLVENT TOOL: Equipment used using solvent during the 
semiconductor fabrication process to perform various operations needed to 
make the final product. Some of these tools contain devices inherent to the 
equipment, which treat or condition exhaust gases as they leave the process 
chamber. 
SOLVENT: Any VOC-containing liquid or vapor which is used to dissolve, clean, 
strip, or remove impurities, coatings, contaminants, or films from surfaces or 
from internal spaces and voids. This includes, but is not limited to, developers 
and stripping agents. This does not include organic compounds used in ashing, 
plasma etch, diffusion and chemical vapor deposition processes. 
Response #37:  
MCAQD considered your comments and revised the definitions to read as 
follows: 
“PROCESS TOOL: Equipment used during the semiconductor fabrication 
process to perform various operations needed to make the final product. This 
does not include equipment that uses solvent in ashing, plasma etch, diffusion 
and chemical vapor deposition processes.” 
“SOLVENT: Any VOC-containing liquid or vapor which is used to dissolve, clean, 
strip, or remove impurities, coatings, contaminants, or films from surfaces or 
from internal spaces and voids. This includes, but is not limited to, developers 
and stripping agents.” 
Comment #38:  
Thank you for the update on the definition of Process Tool. 
For your questions regarding sections 305-307 and the Appendix, section 305 
is applicable and section IV of the Appendix (ECS Requirements) is likely 
applicable. As you mentioned earlier, cleanrooms are exempt from section 304 
(where ECS option is specified). However, per section 305, NXP would have to 
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rely on ECS requirements of section 304.2 to be able to use non-conforming 
solvent in equipment other than small cleaners (defined in section 308.2). 
This bring us to the first high level concern about the rule. NXP currently has an 
ECS regulated under Rule 338 that is designed for cleanroom conditions with 
very high total flow to abatement in order to maintain the cleanroom integrity. 
Prior to revisions to Rule 338, parts cleaning was covered by Rule 338 with 
usage and emissions aggregated for process and equipment parts cleaning 
operations. NXP would like to see an alternate compliance option that allows 
utilizing the ECS requirements in Rule 338 to demonstrate reductions of 
emissions generated during equipment parts cleaning covered by Rule 331. 
This is because Rule 331 appears to aim to keep the exhaust flows as low as 
possible which is not the case for cleanroom operations. We understand that 
this is likely the reason for the cleanroom exemption from section 304; 
however, NXP will likely utilize an ECS to demonstrate compliance with 
sections 302 and 305. We think it is very important that the ECS can operate 
with reference to one rule to ensure clarity and avoid any conflicts between 
requirements in different rules. In this case Rule 338 would be the primary rule 
for ECS requirements for semiconductor sites. 
Response #38:  
During the rulemaking process, solvent cleaning provisions related to 
semiconductor manufacturing activities were proposed to be removed from 
Rule 338 (Semiconductor Manufacturing) and relocated to Rule 331. After 
working with EPA, affected stakeholders, and internal staff, it was decided to 
keep solvent cleaning provisions in Rule 338. Based on this information, there 
will be no removal or significant modifications to solvent cleaning provisions in 
Rule 338.  
Comment #39:  
We also looked at section 501.2 (Usage Records) and found a related concern. 
We currently calculate VOC emissions from solvent cleaning based on mass 
balance of solvent cleaning chemicals used minus the waste shipped off site. It 
will be difficult to segregate usage only for equipment parts cleaning for the 
recordkeeping requirements of Rule 331. We would like to see the option of 
recordkeeping kept in conjunction with the Rule 338 recordkeeping 
requirements in lieu of Rule 331, section 501.2. 
Response #39:  
During the rulemaking process, solvent cleaning provisions related to 
semiconductor manufacturing activities were proposed to be removed from 
Rule 338 (Semiconductor Manufacturing) and relocated to Rule 331. After 
working with EPA, affected stakeholders, and internal staff, it was decided to 
keep solvent cleaning provisions in Rule 338. Based on this information, there 
will be no removal or significant modifications to solvent cleaning provisions in 
Rule 338.  
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Comment #40:  
A final high level concern we have is implementation of Rule 331 and Rule 338. 
Will these rules revisions be finalized at the same time? If not, will there be 
some time frame or exemptions from compliance until both rules are finalized? 
This is a wide sweeping change of Rule 338 that reassigns some 
semiconductor VOC cleaning operations to Rule 331. Both rules will have to 
work together for this to be successful. 
This summarizes our high level concerns with utilizing Rule 331 to regulate 
equipment parts cleaning operations at semiconductor sites. There are other 
specific areas of clarification that we will be addressing during Rule 331 
revision. 
Response #40:  
Currently, Rule 338 and Rule 331 are on the same rulemaking process timeline. 
During the rulemaking process, solvent cleaning provisions related to 
semiconductor manufacturing activities were proposed to be removed from 
Rule 338 (Semiconductor Manufacturing) and relocated to Rule 331. After 
working with EPA, affected stakeholders, and internal staff, it was decided to 
keep solvent cleaning provisions in Rule 338. Based on this information, there 
will be no removal or significant modifications to solvent cleaning provisions in 
Rule 338.  
Comment #41:  
We made some edits to your proposed text (scroll down to see edits in red). 
In summary the proposed changes are: 
•
Change Section 503.X “Formula for Mass Balance of VOC Emissions” to
“Formula for Determination of VOC Emissions” to allow for use of
emission factors in addition to mass balance calculations.
•
Delete (1-Wj) from the formula. The only difference between abated and
unabated emissions is the overall capture and control efficiency of VOC
for the specific control device.
•
Change “mass of VOC generated” to “mass of VOC emissions
generated” in the description of CVOCi and UVOCj to make it clear this is
the amount of VOC emitted.
•
Delete description of Wj because it’s not needed in the formula.
It’s difficult to concisely relay all of the reasons for these suggested changes. 
We are available to meet to discuss any questions you may have. 
Section 503.X Formula for Determination Mass Balance of VOC Emissions: 
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Where: 
VOC Emissions = The total sum of VOCs emitted to ambient air from all 
photoresist operations and/or process tools. 
CVOCi = mass of VOC emissions generated from the “I”th source of 
photoresist operation and/or process tool which is routed to 
a control device designed to destroy VOC. 
Ci = overall capture and control efficiency of VOC for the specific 
control device which the “I”th source of VOC emissions is 
routed to. 
UVOCj = mass of VOC emissions generated from the “j”th source of 
photoresist operation and/or process tool which is not routed 
to a control device designed to destroy VOC. 
Wj = fraction of VOC generated from the “j”th source of photoresist 
operations and/or process tool which is not routed to a 
control device designed to destroy VOC, that is shipped off-
site without being emitted to ambient air. 
Response #41:  
MCAQD revised the rule language in Section 503.9 as suggested. 
Comment #42:  
When we reviewed the proposed formula for our previous response, we 
recommended several clarification changes that are all interrelated. Whereas 
most VOC emissions are determined by calculating VOC used and subtracting 
VOC waste shipped off site (mass balance), this is not true of all VOC 
emissions at our site (and we believe this is true at other semiconductor sites 
as well). VOCs such as tetramethylammonium hydroxide (TMAH) developer are 
used in aqueous solution of less than 3% and the wastewater containing the 
TMAH is discharged to POTW. Air emissions of TMAH are calculated utilizing 
an emission factor specified in the Technical Support Document (TSD) related 
to the site air permit. There are other materials whose VOC emissions are 
calculated with emission factors specified in the TSD instead of mass balance 
as well. 
With this in mind, the first part of the proposed formula works only if the CVOCi 
is mass of VOC emissions generated (pre-abatement). Considering that the 
CVOCi parameter is reduced only by the capture and control efficiency of the 
VOC abatement, it is logical that the component being reduced is the amount of 
material sent to the VOC abatement (emissions). 
For similar reasons, the UVOCj should be the amount of VOC emissions that are 
not sent to VOC abatement (unabated VOC emissions). If UVOCj is VOC 
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emission, there is no need to subtract out the VOC waste component (Wj). This 
would already be done, if applicable, when calculating the VOC emissions. 
For these reason we proposed the following modification: 
Section 503.X Formula for Determination Mass Balance of VOC Emissions: 
Where: 
VOC Emissions = The total sum of VOCs emitted to ambient air from all 
photoresist operations and/or process tools. 
CVOCi =  mass of VOC emissions generated from the “I”th source of 
photoresist operation and/or process tool which is routed to 
a control device designed to destroy VOC. 
Ci =  overall capture and control efficiency of VOC for the specific 
control device which the “I”th source of VOC emissions is 
routed to. 
UVOCj =  mass of VOC emissions generated from the “j”th source of 
photoresist operation and/or process tool which is not routed 
to a control device designed to destroy VOC. 
Wj =  fraction of VOC generated from the “j”th source of 
photoresist operations and/or process tool which is not 
routed to a control device designed to destroy VOC, that is 
shipped off-site without being emitted to ambient air. 
Hope this provides more clarification. If needed, we are open to meet and 
discuss it further. 
Response #42:  
MCAQD revised the rule language in Section 503.9 as suggested. 
Comment #43:  
We have couple more suggestions for Rule 338: 
•
Since the definition of Process Tool includes equipment processing
photoresist, it appears there is no reason to specifically mention
photoresist operations in sections 301.1, 503.5 and 503.7. Thus we
suggest the phrase “aggregated photoresist and process tool
operations” is simplified to: “process tool operations”.
•
Since the good combustion plan is not expected to change frequently,
could section 501.7.b be modified to: Good Combustion Plan: Maintain a
Good Combustion Plan as required in Section 303.3(b). The plan must
be reviewed every year and updated as needed every year to contain
current information. Any change to the plan and the annual review shall
be documented
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Response #43:  
MCAQD revised the rule language as suggested. 
Comment #44:  
RadTech is pleased to comment on Maricopa County’s proposed 
amendments to Rule 338 –Semiconductor Manufacturing. We previously 
submitted written comments in July and made verbal comments at a recent 
public meeting. 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 including semiconductor manufacturing.   
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate. 
Instead, they are specifically formulated to react to energy (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/LED 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” 
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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.”   
Response #44:  
Thank you for submitting comments on draft Rule 338. After further review of 
your comments, MCAQD contacted South Coast Air Quality Management 
District (SCAMD) to obtain further information on regulatory requirements for 
UV/EB/LED coatings.   
MCAQD was informed that SCAQMD does have allowances for processes that 
use UV/EB/LED coatings to be exempt (SCAQMD Rule 219) from receiving a 
written permit; however, those exemptions are qualified exemptions. 
Limitations to the permit exemption include volume limits, VOC limits, and 
prohibition of toxics. SCAQMD recently included an allowance for a facility 
that installs UV/EB/LED curing equipment provided they do not make any 
other changes to the permitted equipment. That provision includes similar 
limitations for volume, VOC, etc.  
According to SCAQMD, the term “super-compliant” is not a South Coast 
regulatory term. They do have a Super-Compliant Architectural Coatings list to 
provide a platform for manufacturers to provide information on their low-VOC 
coatings. It is not a regulatory requirement but more of a service provided for 
coating manufacturers. Super-compliant is defined as containing less than 10 
grams of VOC per liter (regulatory VOC). Furthermore, many SCAQMD rules 
have VOC limits at or below 50 g/L, therefore SCAQMD would not consider 
coatings formulated to that VOC level to be “super-compliant.” SCAQMD is not 
aware of any UV/EB/LED coatings being included on that list.  
Lastly, in regard to the 2022 Air Quality Management Plan, SCAQMD does 
have a control measure to reduce VOC emissions from coatings, solvents, 
adhesives, and lubricant in Appendix IV. That control measure does mention 
UV/EB/LED as one of many technologies that can help achieve emission 
reductions.  
Comment #45:  
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 
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contain Toxic Air Contaminants and have no secondary adverse impacts such 
as emissions of greenhouse gases.  
Response #45:  
MCAQD discussed comment #47 with an EPA representative and the EPA 
representative informed MCAQD, to their knowledge, UV/EB coatings have not 
been required as Lowest Achievable Emission Reduction (LAER) in practice. In 
addition, the EPA representative informed MCAQD UV coatings have been 
mentioned in some Control Technique Guidelines (CTG) but haven’t been 
determined to meet Reasonably Available Control Technology (RACT).  
Comment #46:  
According to the staff report, the Maricopa County Air Quality Department 
(MCAQD) is proposing to revise Rule 338 to incorporate Reasonably Available 
Control Technology (RACT) level controls that will regulate emissions 
generated during the semiconductor manufacturing process. In addition, 
MCAQD will review the VOC controls in Rule 338 and ensure the controls 
implement RACT. We are concerned that the proposed changes to Rule 338 
do not take into consideration pollution prevention processes such as 
UV/EB/LED. RadTech believes that Rule 338 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. In its current form, Rule 338 seems to 
focus on Emission Control Systems (ECS) as the only means of compliance. 
The one sided approach, unfairly excludes pollution prevention technologies 
such as UV/EB/LED and puts our businesses at disadvantage as compared to 
systems using conventional solvents with ECS. Thus, our organization cannot 
support the rule in its current form.  
Response #46:  
Rule 338 does not require facilities that emit less than 25 tons of VOCs per 
year to install an ECS. This emission threshold encourages alternative 
emission reduction methods, such as the use of materials with lower VOC 
contents. Facilities are not discouraged from utilizing alternative emission 
reduction measures as long as the activities comply with the provisions in 
Rule 338. 
Comment #47:  
Section 103.2—Exemptions   
Our materials are typically well below 50 grams/liter in VOC content. The rule 
groups materials ranging from 2 grams per liter to 100 grams per liter. We 
would suggest an intermediate VCO content of 50 grams per liter and 
respectfully request that UV/EB/LED materials with a VOC content of 50 
grams per liter or less be exempted from 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.  
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Response #47:  
Proposed revisions to Rule 338 include revisions to the exemption for low-VOC 
materials. The revisions are intended to make the low-VOC exemption in the 
proposed rule more closely match the low-VOC exemption in SIP Rule 338 to 
avoid backsliding concerns. SIP Rule 338 includes a partial exemption for 
liquids in positive photoresist processes which contain less than 10 percent 
VOC by weight and never exceed a temperature of 104° F. These materials are 
exempt from being included in emission calculations subject to positive 
photoresist control requirements, being controlled by an emission control 
system (ECS), and do not need to be included in determining the efficiency of a 
required ECS. 
Proposed language in Section 103.2 will partially exempt materials containing 
less than 10% VOC by weight if unheated, or less than 2.5% VOC by weight if 
heated, from Sections 301, 302, 303, and 306 of the rule. Should UV/EB/LED 
materials qualify for the partial exemption, then there will be minimal 
requirements to comply with the rule.    
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.  
Comment #48:  
Section 200-- Definitions   
The rule narrowly focuses the definitions section on ECS. This approach does 
not take into consideration other technologies and may have the unintended 
consequence of giving a certain process an unfair competitive advantage. The 
rule should be technology neutral and include definitions for all available 
technologies. 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 #48:  
Thank you for providing the MCAQD with a definition for energy curable 
materials. However, a definition is not necessary since the MCAQD will not be 
including any additional provisions regarding these materials in Rule 338.  
Comment #49:  
Section 301.1—Control of VOC Emissions from Semiconductor Manufacturing 
Operations  
This section exclusively refers to Emission Control devices. While facilities 
emitting less than 2 tons per year are not included, it is not clear what 
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alternative technologies would be acceptable. We suggest adding language to 
explicitly state that UV/EB/LED technology can be used in lieu of add on 
emission control systems.  
Response #49:  
Rule 338 does not require facilities that emit less than 25 tons of VOCs per 
year to install an ECS. This emission threshold encourages alternative 
emission reduction methods, such as the use of materials with lower VOC 
contents. Facilities are not discouraged from utilizing alternative emission 
reduction measures as long as the activities comply with the provisions in 
Rule 338. 
Comment #50:  
Section 503—Compliance Determination  
This Section is especially problematic because Rule 338 does not specify a 
test method for energy curable materials in Section 504. The current rule 
language states: 
“When more than one test method is permitted for a determination, an 
exceedance of the limits established in this rule determined by any of the 
applicable test methods constitutes a violation of this rule.”  
The lack of clarity as related to acceptable test methods may put out the 
businesses we represent at risk of enforcement action by Maricopa County. 
Section 503.1(c) specifies the allowance of an ASTM method for waterborne 
materials. The same approach should be afforded to energy curable materials 
by including ASTM D7767-11. We ask that Section 504 be clarified to include 
test methods for UV/EB/LED (see comments on Section 504).  
Response #50:  
If there are no suitable EPA approved test methods incorporated into Rule 338 
for UV/EB/LED products, an alternative approach is to use the Safety Data 
Sheet (SDS) or technical datasheets to verify the VOC content of the 
materials. This information is commonly relied on by MCAQD to determine 
compliance and has been used when determining compliance for UV/EB/LED 
coatings used at regulated facilities within the county.  
Comment #51:  
Section 501—Recordkeeping and Reporting  
We request an exemption for UV/EB/LED from the unnecessarily burdensome 
requirements of Section 501. Maricopa County should provide incentives in 
the form of reduced recordkeeping and reporting, for facilities that go above 
and beyond rule requirements. This approach is a win-win because it will 
result in excess emission reductions for Maricopa County.  
Response #51: 
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Should the VOC emissions generated from the UV/EB/LED activities require 
an air quality permit, then minimal recordkeeping would be required. Examples 
include a current list of all VOC-containing materials subject to the rule, 
monthly usage of the materials, and disposal records for the materials. 
Businesses most likely maintain records very similar to these as part of their 
regular business practices.   
As previously mentioned, 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.  
Comment #52:  
Section 504--Test Methods 
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.  
Response #52:  
Since ASTM D7767-11 is not currently an EPA-approved test method, the 
MCAQD cannot include it in Rule 338. Adding a test method that is not EPA-
approved to this rule could jeopardize EPA’s approval of Rule 338 into the SIP. 
However, Section 504 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 #53:  
Proposed Rule 338  
Section 401.3 requires any modifications to ECS to be completed and unit 
source tested within 12 months of applicability. This timeline is too short for 
this requirement to add new emission control system (ECS) capacity, with Air 
Permitting, construction supporting ductwork within the cleanroom combined 
with external ductwork using steel and concrete. Construction projects 
timelines are for projects of this scale are in the 3-year timeframes. 
Response #53: 
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Addition of a new emission control system at an existing facility would be 
subject to the installation timelines in Section 401.2 which includes a 
requirement to complete construction and source test the new system within 
36 months of final permit issuance. The 6- and 12-month timeframes in Section 
401.3 are regarding modifications to an existing ECS. MCAQD added the word 
“new” to Section 401.2 to clarify the applicability of this provision. 
Comment #54:  
In this solvent cleaning evaluation, we discovered that semiconductor substrate 
R&D non-solvent cleaning wet plating (aqueous) tools would now be required to 
be connected to an ECS by Rule 338 vs. Rule 331 due to Rule 338 broadened 
applicability and the Vapor Pressure requirement in the Rule 331 defining a 
conforming solvent as ≤1 mmHg. Connecting these non-solvent cleaning wet 
plating tool sources to a ECS would result in high flow, low VOC concentrations 
in the exhaust leading to what we feel are counterproductive increases in NOx. 
Specifically, Intel’s current estimates from these tools is ~1,300 lbs./year VOCs 
requiring an additional ~10,000 cfm of exhaust connected to an ECS, which 
could potentially result in an additional ~8600 lbs. of NOx per year. We would 
like your comments of our analysis showing the expansion of the Rule 338 
applicability beyond photoresist operations that may now regulate many wet 
plating tools. These wet plating tools have water content slightly under 95% 
with relatively low VOC emissions but high NOx releases when connected to an 
ECS. 
Response #54:  
The wet plating tools may fall under the Quality Control and R&D Operations 
partial exemption in Section 103.1, as long as the 12-consecutive month VOC 
emissions do not exceed 7.3 tons. If the tools fall under the exemption, they 
would not be required to be connected to an ECS. 
In addition, the partial exemption for low-VOC materials, which was proposed to 
be removed at one point during the rulemaking, is going to be retained and has 
been revised as follows: 
“Materials containing less than 10% VOC by weight if unheated, or less than 
2.5% VOC by weight if heated, are exempt from Sections 301, 302, 303, and 306 
of this rule. The VOC content shall be determined pursuant to Section 503.7 of 
this rule.” If the wet plating tools qualify for the low-VOC exemption, they would 
not be required to be connected to an ECS. 
Comment #55:  
In a follow-up email from our meeting, it was requested that we provide 
additional detail on our concerns with proposed Rule 338 401.3 timeframes. 
Our suggested language for 401.3 b. with rational follows. 
•
Within 12 months after the facility becomes subject to the requirements
in section 301.1 of this rule, the owner or operator shall be complete with
ECS modifications for any existing ECS with existing infrastructure and
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existing capacity and perform “start-up” in accordance with Rule 270. 
Submittal to the Control Officer of a complete source test report 
indicating compliance shall be provided in the timeframes defined by 
Rule 270. 
•
Within 36 months after the facility becomes subject to the requirements
in section 301.1 of this rule, the owner or operator shall be complete with
ECS modifications for any new ECS requiring new infrastructure and new
capacity and perform “start-up” in accordance with Rule 270. Submittal
to the Control Officer of a complete source test report indicating
compliance shall be provided in the timeframes defined by Rule 270.
Any “reconstructing or adding on equipment” is in our experience considered 
new infrastructure and new capacity and would requires 36 months for 
construction completion. Intel Chandler has recently installed VOC Abatement 
units that can be used as an example of construction schedules for 
reconstruction or addition of equipment. There was a need to expand the VOC 
abatement capacity due to new tools supporting technology development. Intel 
semiconductor construction schedules are some of the most aggressive in the 
industry due to the time-to-market strategy driving product technology 
advancements. In this example assume that a “plan of record” (POR) ECS is 
selected. This POR means that ECS supplier selection with contracts in place 
with performance specifications, master design standards, operating 
specifications and any treatability studies needed. Otherwise, this can take an 
additional 6-9 months to develop an Intel POR ECS. A brief example of 
construction schedules follows. 
•
3-6 Months for Design Positioning / Programing, this may include
ductwork design and layout within the cleanroom.
•
18-30 Months for Design Construction – this may include ductwork
design and layout within the cleanroom and staging of construction to
avoid impacts to manufacturing operations.
We appreciate the opportunity to provide comments to these proposed rules 
and welcome future meetings for guidance and to discuss our concerns and 
considerations. 
Response #55:  
See Response #53. 
Comment #56:  
Suggested clarifications to the Proposed New Rule 338 existing language for 
exemption for R&D 
Semiconductor Substrate R&D non-solvent cleaning wet plating (aqueous) 
tools, previously shown in our letter dated 3/19 would now be required to be 
connected to an ECS by Rule 338 vs. 331. In our meeting we read Rule 338 
103.1 to exempt these tools because they are R&D. “research” and < 5 TPY can 
you please confirm. If you confirm this, then we recommend minor edits to Rule 
338 to make this clearer by; 
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
Defining R&D in Rule 338 SECTION 200 similar to the R&D definition found in
40 CFR § 63.11511(d)(2) (NESHAPS, 6W); “Research and development
process unit means any process unit that is used for conducting research
and development for new processes and products and is not used to
manufacture products for commercial sale, except in a de minimis manner.”
Note Intel SPTD is subject to this NEESHAP exemption as noted in our Air
Permit and TDS.

In addition, within Rule 338, 103.1 replace the ref. “research” to “research
and development” to be consistent throughout Rule 338.
Response #56:  
The wet plating tools may fall under the Quality Control and R&D Operations 
partial exemption in Section 103.1, as long as the 12-consecutive month VOC 
emissions do not exceed 7.3 tons. Additionally, MCAQD added a definition for 
Research and Development and revised the rule language in Section 103.1 as 
suggested. 
Comment #57:  
Thank you for the review of the Rule 338 final changes today. 
I’ve noticed a minor typo in section 503.7 that I want to bring to your attention. 
The weight of all volatile compounds in the below formula should be depicted 
as Ws instead of Vs to be consistent with the other weights in this and other 
formulas. 
VOC CONTENT OF MATERIAL in pounds per gallon (lbs/gal) or grams per liter 
(g/l) = 
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Using consistently either pounds or grams in the calculations, where: 
 =       Weight of all volatile compounds in pounds (or grams), 
including VOC, water, non-precursor organic exempt compounds, 
and dissolved vapors 
Response #57:  
MCAQD revised the rule language as suggested. 
Comment #58:  
Thanks again for your efforts on Rule 338. If you could, would you please 
confirm that isopropanol vapor pressure at 20 C would be 33 mm Hg and meet 
Rule 338 Sections 302.2 and 303.2?  
Response #58:  
Section 303.2 allows the use of a cleaning-solvent having a VOC composite 
partial pressure that does not exceed 33.0 mm Hg at a temperature of 68° F 
(20° C). This allows the use of IPA as long as the vapor pressure does not 
exceed the aforementioned limit.  
Comment #59:  
I guess my question is more how the vapor pressure would be calculated by 
MCAQD for compliance? Would it be up to source then to provide this 
information? 
Response #59: 
MCAQD considered your comments and revised Section 501.5(b) as follows: 
Maintain the written value of the total VOC vapor pressure of each cleaning- 
solvent regulated by this rule in one of the following forms: 
(1) A manufacturer’s technical data sheet;
(2) A manufacturer’s safety data sheet (MSDS); or
(3) Actual test results.
Comment #60: 
MCAQD defines the “Freeboard Ratio” as the freeboard height divided by the 
width of the solvent cleaning machine. Arizona State University requests the 
definition of “freeboard ratio” be defined as the freeboard height divided by the 
smaller of either the length or width of the solvent cleaning machining. Revising 
the definition will alleviate any ambiguity concerning the definition of the width 
or design of a solvent cleaning machine when the length is smaller than the 
width. This language resembles many solvent cleaning or degreasing rules, 
such as South Coast AQMD’s Rule 1122, Solvent Degreasers or Delaware’s 
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Department of Natural Resources and Environmental Control’s Rule 1124, 
Control of Volatile Organic Compound Emissions. 
Response #60: 
MCAQD revised the rule language as suggested. 
Comment #61: 
ASU requests that the “Quality Control and Research and Development 
Operations" section exemption threshold be set at 7.3 tons per 12-month rolling 
period. This value is equivalent to the current 40 pound-per-day VOC level 
extended over a 12-month period. The exemption allows research and 
development operations the flexibility to meet the fast-paced and variable 
nature of semiconductor development. Additionally, this exemption should only 
apply to the research and development portions of the facility. 
Response #61: 
MCAQD revised the rule language as suggested. 
Exact Wording of the Rule 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 338 (SEMICONDUCTOR MANUFACTURING) 
INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
APPLICABILITY 
306 
103 
EXEMPTIONS 
SECTION 200 – DEFINITIONS 
201 
ACCEPTABLE TRACE VOC EMISSION 
201 
CLEANING-SOLVENT 
202 
202 
EMISSION CONTROL SYSTEM (ECS) 
203 
EXCEPTED CORROSIVE VOC 
204 
EXEMPT COMPOUNDS 
Return to list of attachments
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205 
203 
FREEBOARD HEIGHT 
206 
204 
FREEBOARD RATIO 
205 
HEATED SOLVENT 
206 
LEAK 
207 
PARTS PER MILLION BY VOLUME DRY (PPMVD) 
207 
208 
PHOTORESIST OPERATION 
209 
POINT-OF-USE (POU) COMBUSTION DEVICE 
210 
PROCESS TOOL 
211 
RESEARCH AND DEVELOPMENT 
208 
212 
SOLVENT 
209 
213 
SOLVENT CLEANING STATION 
210 
214 
STRIPPING 
215 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 
211 
216 
VOC CONTENT OF MATERIAL 
SECTION 300 – STANDARDS 
301 
CONTROL OF PHOTORESIST VOC EMISSIONS FROM SEMICONDUCTOR 
MANUFACTURING OPERATIONS 
302 
SOLVENT CLEANING STATION OPERATIONS USING SOLVENTS CONTAINING 
MORE THAN 10 PERCENT VOC 
303 
CLEANING-SOLVENT SPECIFICATIONS 
305 
304 
WORK PRACTICES – HANDLING, STORAGE AND DISPOSAL OF VOC-CONTAINING 
MATERIALS 
304 
305 
OPERATING REQUIREMENTS OPERATE CORRECTLY 
303 
306 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS 
OPERATION AND MAINTENANCE (O&M) PLAN REQUIREMENTS FOR ECS 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
COMPLIANCE SCHEDULE 
402 
CONTROL EFFICIENCY GENERALIZATION 
403 
APPLICABILITY OF RULE 331 FOR SUPPORT OPERATIONS 
SECTION 500 – MONITORING AND RECORDS 
501 
MONITORING DEVICE RECORDS 
502 
501 
RECORDKEEPING AND REPORTING 
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502 
ECS RECORDKEEPING REQUIREMENTS 
503 
COMPLIANCE DETERMINATION 
504 
TEST METHODS INCORPORATED BY REFERENCE 
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Adopted 11/16/92; Revised 06/19/96; Revised 04/21/99; Revised 09/25/13; Revised 
MM/DD/YYYY 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 338 (SEMICONDUCTOR MANUFACTURING) 
SECTION 100 – GENERAL 
101 
PURPOSE: To limit the emissions of volatile organic compounds (VOCs) and nitrogen 
oxides (NOx) from semiconductor manufacturing. 
102 
APPLICABILITY: 
102.1 This rule applies to: 
a.
The making manufacturing of any semiconductor device, including diodes,
zeners, stacks, rectifiers, integrated microcircuits, transistors, solar cells,
light-sensing devices, and light-emitting devices.
b.
This rule applies to All direct processing of the wafer/die from crystal growth
and wafer production through oxidation, photoresist operations, etching,
doping, epitaxial growth operations, circuit separation, encapsulation, and
those assembly and test operations related to semiconductor
manufacturing.
102.2 Rule 338 This rule does not apply to an accredited school that has an educational 
program in which semiconductors are either fully or partially made. However, this 
rule is applicable to schools that sell such semiconductor constructions for other 
than teaching and/or research purpose(s). 
102.3 This rule does not apply to the solvent cleaning of equipment or parts that is 
performed for purposes other than semiconductor manufacturing and such 
activity shall be subject to requirements of Rule 331 (Solvent Cleaning) of the 
Maricopa County Air Pollution Control Regulations (MCAPCR). 
102.4 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 the MCAPCR these rules. 
306 
103 
EXEMPTIONS: 
306.1 
103.1 Quality Control and R&D Research and Development Operations: Except for this 
rule's Sections 304, and 305, and 501 and subsections 502.1 and 502.2, this rule 
shall not apply to those operations within a semiconductor manufacturing facility 
which are used exclusively for one or more of the following: chemical or physical 
analysis, determination of product quality or commercial acceptance, research 
and development, or pilot plant activities. Such operations may be exempted until 
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the sum of daily 12-consecutive month VOC emissions from all such exempted 
operations reaches but does not exceed 7.3 tons 40 pounds (18.1 kg). This 
exemption shall not apply to a particular operation if the exemption is denied in 
writing by the Control Officer. 
306.2 An aggregate of up to 55 gallons per year of material not exempted by other 
provisions within this Section 306 is exempt from the VOC-control requirements 
of Section 301 if usage is logged monthly in a coherent manner and cumulative 
usage is calculated. 
306.3 
103.2 Low-VOC Materials: Materials containing less than 10% VOC by weight if 
unheated, or less than 2.5% VOC by weight if heated, are exempt from Sections 
301, 302, 303, and 306 of this rule. The VOC content shall be determined 
pursuant to Section 503.7 of this rule.   
The following provisions apply to materials with a VOC content of 10% or less as 
received by a facility; VOC content shall be determined pursuant to Section 503. 
Percent is either by weight or volume, as chosen by the operator. 
a.
Materials with a VOC content of less than 2 grams VOC/liter or less than 0.2
percent VOC are exempt from Rule 338.
b.
Materials with a VOC content of 0.2% to 10% VOC are exempt from Sections
301, 302, 303, 501, and 502 of this rule if the total quantity annually received
is updated annually pursuant to subsection 502.2c, and disposal is done
pursuant to all requirements within Section 305.
306.4 Excepted Corrosive VOC: 
a.
An excepted corrosive VOC is exempt from subsection 301.1 of this rule
under the conditions in subsections (1) and (2) following:
(1) An owner or operator choosing the control option in subsection 301.1 is
allowed to annually exempt an aggregated photoresist VOC total of up to
1 ton of excepted corrosive VOC emissions from all control device and
ECS requirements; and
(2) All excepted corrosive VOCs emitted in excess of the 1 ton (907.2 kg) per
year aggregated allowance in 306.4a(1) are directed through a control
device. No test of control efficiency shall be required for excepted
corrosive organic compounds in a control device.
(3) All excepted corrosive VOCs emitted in excess of the 1 ton (907.2 kg) per
year aggregated allowance in 306.4a(1) that are not directed through a
control device are subject to Section 301 and subsection 301.1 as
ordinary, non-exempt VOC.
b.
An excepted corrosive VOC is exempt from subsection 301.2 of this rule
under the conditions in subsections (1) and (2) following:
(1) An owner or operator choosing the control option in subsection 301.2 is
allowed to annually exempt from all control device and ECS requirements
1 ton of excepted corrosive-VOC emissions aggregated from photoresist
plus semiconductor cleaning; and
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(2) All excepted corrosive VOCs emitted in excess of the 1 ton (907.2 kg) per
year aggregated allowance in 306.4b(1) are directed through a control
device. No test of control efficiency shall be required for excepted
corrosive organic compounds in a control device.
(3) All excepted corrosive VOCs emitted in excess of the 1 ton (907.2 kg) per
year aggregated allowance in 306.4b(1) that are not directed through a
control device are subject to subsection 301.2 as ordinary, non-exempt
VOC.
306.5 
103.3 Organic Silicon Compounds: VOC emissions up to an aggregated annual 12-
consecutive month total of 1 ton of organic silanes and silicates, and any other 
organic compound of carbon and silicon, may be excluded by an owner or 
operator from being subject to the ECS control requirements of Section 301.1 if 
information from the manufacturer of the ECS indicates that such compounds 
adversely affect the operation of the model or type of ECS being used. 
306.6 
103.4 Wipe Cleaning: Wipe cleaning is subject to the applicable requirements of Rule 
331 (Solvent Cleaning) of the MCAPCR. Wipe cleaning is not subject to Section 
300, but the usage of VOC-containing solvent for wipe cleaning is subject to the 
recordkeeping provisions of Section 500. 
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 the MCAPCR these rules. In the event of any inconsistency between any of the 
rules within the MCAPCR Rules, the definitions in this rule take precedence.  
201 
ACCEPTABLE TRACE VOC EMISSION: Emission so dilute that less than 50 ppm or 220 
mg/M3 registers on a VOC detector when its probe is 1 inch (2.5 cm) from the surface 
of a potential VOC-emitter. Such detector shall be used pursuant to subsection 503.5, 
using EPA Test Method 21. 
201 
CLEANING-SOLVENT: Solvent used for cleaning that contains more than 2.0% VOC by 
weight and more than 20 grams of VOC per liter (0.17 lb/gal). 
202 
202 
EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control 
Officer, designed and operated in accordance with good engineering practice used to 
reduce emissions of volatile organic compounds. Such a system consists of an 
emissions collection subsystem and an emissions processing subsystem. 
203 
EXCEPTED CORROSIVE VOC: The following compounds emitted either from photoresist 
process(es) or from semiconductor cleaning processes: citric acid, acetic acid, 
methylsulfonic acid, and tetramethyl-ammonium hydroxide. Also included are the 
following categories of corrosive VOC emitted either from photoresist process(es) or 
from semiconductor cleaning processes: acidic VOC emitted by any organic acid having 
a pH of 2 or less in its most acidic aqueous state, and basic VOC emitted from a caustic 
organic solution having a pH of 12.5 or more in its most basic aqueous state. 
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204 
EXEMPT COMPOUNDS: For the purpose of this rule, the non-VOC, non-aqueous 
evaporating portion of a formulation; this necessarily includes all non-precursor organic 
compounds in addition to inorganic liquids and gases.  
205 
203 
FREEBOARD HEIGHT: The following measurement within the tank/basin of a cleaning 
machine, as determined during idling mode: 
205.1 
203.1 Batch Cleaning Machine: The vertical distance from the solvent/air interface to 
the least elevated point of the top-rim when the cover is open or removed. 
a.
Non-Vapor: The vertical distance from the most elevated solvent surface to
the least elevated point of the top-rim when the cover is open or removed.
b.
Vapor: The vertical distance from the least elevated point of the top-rim to
the point halfway between the highest and the lowest point of the cooling
coils.
205.2 
203.2 In-Line Cleaning Machine: The vertical distance from the solvent/air interface to 
the lowest entry/exit point. 
a.
Non-vapor: The vertical distance from the lowest entry/exit point to the most
elevated solvent surface.
b.
Vapor: The vertical distance from the lowest entry/exit point, to the point
halfway between the highest and the lowest point of the cooling coils.
206 
204 
FREEBOARD RATIO: The freeboard height divided by the smaller of either the length or 
width of the solvent cleaning machine. The freeboard height divided by the smaller of 
the inside horizontal length or the inside horizontal width of the cleaning machine’s 
evaporative surface area. 
205 
HEATED SOLVENT: Any cleaning-solvent which is heated by a device to a temperature 
exceeding 120° F (49° C) but does not exceed the solvent boiling point. 
206 
LEAK: A visible VOC-containing liquid leak at a rate of more than three drops per minute, 
or a puddle greater than one square inch.  
207 
PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express 
concentration that is corrected to a dry basis. 
207 
208 
PHOTORESIST OPERATION: A process for the application and development of 
photoresist masking solution on a wafer, including preparation (except primary 
cleaning), soft bake, develop, hard bake, stripping, and edge-bead removal., and can be 
generally subdivided as follows: 
207.1 Negative Photoresist Operation: A process where the maskant hardens when 
exposed to light or other process radiation, and the unhardened maskant is 
stripped, exposing the wafer surface for etching. 
207.2 Positive Photoresist Operation: A process where the maskant softens when 
exposed to light or other process radiation, and the softened maskant is stripped, 
exposing the wafer surface for further processing. 
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209 
POINT-OF-USE (POU) COMBUSTION DEVICE: A device that is installed in close 
proximity to process equipment and is a source of combustion which generates NOx 
emissions.  
210 
PROCESS TOOL: Equipment used during the semiconductor fabrication process to 
perform various operations needed to make the final product. This does not include 
equipment that uses solvent in ashing, plasma etch, diffusion and chemical vapor 
deposition processes. 
211 
RESEARCH AND DEVELOPMENT: An operation whose primary purpose is for research 
and development of new processes and products and that is conducted under the close 
supervision of technically trained personnel and is not involved in the manufacture of 
final or intermediate products for commercial purposes, except in a de minimis manner. 
208 
212 
SOLVENT: For the purpose of this rule, any VOC-containing liquid or vapor which is used 
to dissolve, clean, strip, or remove impurities, coatings, contaminants, or films from 
surfaces or from internal spaces and voids. This includes, but is not limited to, 
developers and stripping agents.  
209 
213 
SOLVENT CLEANING STATION: A workplace equipped to remove surface contaminants 
using a VOC-containing liquid or vapor solvent containing volatile organic compounds. 
This excludes photoresist stripping processes. 
210 
214 
STRIPPING: The removal of spent photoresist maskant from the product after etching, 
or the removal of oxide or other stencil agent from the product after diffusion, or any 
other removal of applied masking agent. 
215 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE): Within a 
solution or homogenous mixture, it is the sum of the partial pressures of all those 
components that are defined as VOCs, calculated according to the formula in Section 
503.8 of this rule. 
211 
216 
VOC CONTENT OF MATERIAL: The weight of VOC per volume of material, and can be 
calculated by: according to the formula in Section 503.7 of this rule. 
SECTION 300 – STANDARDS 
301 
CONTROL OF PHOTORESIST VOC EMISSIONS FROM SEMICONDUCTOR 
MANUFACTURING OPERATIONS: 
301.1 An owner or operator of a semiconductor manufacturing operation that annually 
emits 25 or more tons of VOCs per year from process tool operations, prior to 
any emissions controls, shall maintain such operations under negative pressure, 
per Section 503.3 and meet one of the following requirements: 
a.
Achieve at least 90% overall VOC capture and control of process tool
operations, determined by applicable provisions in Section 503.3; or
b.
For VOC input-concentrations of less than 100 ppmvd (as propane) at the
inlet of the ECS, the control efficiency is satisfied if the VOC outlet
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concentration is less than or equal to 10 ppmvd (as propane), as determined 
by applicable provisions in Section 503.4. 
301.2 Any VOC emissions not controlled per Section 301.1 shall be assumed to have 
evaporated onsite unless: 
a.
Records demonstrating otherwise can be provided to the Control Officer per
Section 501.7; or
b.
The VOC emissions are accounted for in emissions calculations per Section
503.9.
301 
An owner or operator conducting photoresist operations at a semiconductor 
manufacturing facility that annually emits more than 25 tons (22.7 Mg) of VOC from all 
photoresist operations combined, measured prior to any emissions control, shall reduce 
photoresist VOC-emissions or aggregated VOC emissions from both photoresist and 
cleaning-station processes using an ECS that satisfies the requirements set forth in 
either subsection 301.1 or 301.2 of this rule: 
301.1 Use an ECS to Control Photoresist VOC Only: 
a.
Achieve at least 80% overall VOC-control of photoresist VOC, including
capture and processing of photoresist VOC, as determined by applicable
provisions in Section 503; or
b.
The ECS shall capture at least 90% of all photoresist VOC and achieve an
hourly average stack concentration not exceeding 20 mg VOC/standard
cubic meter, as determined by applicable provisions in Section 503. Mass
loading of VOC is expressed as milligrams of non-methane organic carbon.
301.2 Use an ECS to Control Aggregated Photoresist VOC and Cleaning VOC: 
a.
Achieve at least 80% overall VOC-control of aggregated cleaning plus
photoresist VOC, including capture and processing, as determined by
applicable provisions in Section 503; or
b.
The ECS shall capture at least 90% of all cleaning and photoresist VOC
emissions combined and achieve an hourly average stack concentration not
exceeding 20 mg VOC/standard cubic meter, as determined by applicable
provisions in Section 503. Mass loading of VOC is expressed as milligrams
of non-methane organic carbon.
302 
SOLVENT CLEANING STATION OPERATIONS USING SOLVENTS CONTAINING MORE 
THAN 10 PERCENT VOC: An owner or operator operating a solvent cleaning station 
using a solvent containing more than 10% VOC by weight at a semiconductor 
manufacturing facility shall meet all of the following requirements unless the solvent 
cleaning station complies with Section 303.3 or 303.4: 
302.1 Solvent Cleaning Stations: A person shall not operate a solvent cleaning station 
that cleans semiconductor devices with solvents containing more than 10 
percent VOC content unless each of the following requirements in subsections 
302.1a through c are satisfied, or subsection 302.3 is satisfied. 
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a.
302.1 Each heated or unheated reservoir, sink, and container that transfers, stores, or
holds VOC-containing material shall be provided with a full cover. A cover shall 
remain closed except while production, sampling, maintenance, or loading or 
unloading procedures require operator access; and 
b.
302.2 All heated or unheated reservoirs and sinks holding VOC-containing materials
with a total VOC vapor-pressure exceeding 33.0 millimeters of mercury column 
(mm Hg) at 68° F (20° C) shall have a freeboard ratio greater than or equal to 1.0; 
and 
c.
302.3 Solvent flow of VOC-containing materials shall be applied in a continuous
unbroken stream and in a manner which shall prevent liquid loss resulting from 
splashing. 
302.2 
303 
CLEANINGUP-SOLVENT SPECIFICATIONS: An owner or operator person shall not use 
using a VOC-containing solvent material for the purpose of cleaning semiconductor 
manufacturing equipment at a semiconductor manufacturing facility shall meet one of 
the following unless the requirements in at least one of the following subsections 
302.2a through 302.2c are satisfied, or an ECS is used pursuant to subsection 302.3. 
This includes, but is not limited to, the cleaning of empty boats, quartz tubes, and other 
devices used to hold, contain, or process semiconductors. 
a.
303.1 Use a cleaning-solvent having a The VOC content of the fluid that does not
exceed 200 grams per liter (1.7 pounds per gallon) of material; or 
b.
303.2 Using a cleaning-solvent having a The VOC composite partial pressure that does
not exceed 33.0 mm Hg (0.64 psia) at a temperature of 68° F (20° C); or 
c.
The components being cleaned are totally enclosed during the washing,
rinsing, and draining processes such that there are no greater than
acceptable trace VOC emissions (ATVE) to the atmosphere during such
processes. ATVE means that less than 50 ppm or 220 mg/m3 VOC is
detected when determined according to subsection 503.5.
303.3 Use an ECS to capture and control VOC emissions in accordance with Section 
301.1 of this rule; or 
303.4 Use a sealed system that is an Air-tight or Airless Cleaning System, which is 
operated according to the manufacturer specifications and, unless otherwise 
indicated by the manufacturer, meets all of the following requirements:  
a.
Has a door or other pressure-sealing apparatus that is shut during each
cleaning and drying cycle; and
b.
Has a differential pressure gauge that always indicates the pressure in the
sealed chamber when occupied or in active use; and
c.
Any associated pressure relief device(s) shall be so designed and operated
as to prevent liquid cleaning-solvents from draining out.
302.3 Alternative Compliance for Solvent Processes: An the owner or operator of an 
operation is allowed to meet any and all provisions under subsections 302.1 and 
302.2 that apply to that operation by: 
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a.
Using an ECS that achieves an overall control efficiency as required under
Section 301 and that is operated pursuant to all applicable ECS requirements
of this rule; or
b.
Using an Air-tight or Airless system that both is sealed during cleaning and
drying and has a sealed, self-contained liquid-solvent recovery system; or
c.
Using only those materials in the operation that contain less than 100 g
VOC/liter or no more than 10.0 percent VOC by weight.
305 
304 
WORK PRACTICES – HANDLING, STORAGE AND DISPOSAL OF VOC-CONTAINING 
MATERIALS: 
305.1 
304.1 Store all VOC-containing materials in closed, leak free containers. Containers 
shall remain covered with a leak tight cover when not in use. All storage of VOC-
containing materials subject to evaporation, including the storage of waste 
solvent and waste solvent residues, shall at all times be in closed containers, 
except when contents are added or removed. 
305.2 
304.2 Containers in which VOC-containing materials are stored must have a legible 
label identifying the container’s contents. Containers shall be legibly labeled with 
their contents. 
305.3 
304.3 Disposal of waste or surplus VOC-containing materials shall be done in a manner 
that does not promote VOC evaporation, such as, but not limited to, via sewage 
treatment works or having the waste hauled off-site in sealed containers. 
304 
305 
OPERATING REQUIREMENTS OPERATE CORRECTLY: 
304.1 
305.1 Process Equipment: All active process equipment in which VOC-containing 
materials are used shall be operated and maintained in proper working order. 
304.2 
305.2 Leaks: Equipment with a VOC-containing liquid leak shall either be shut down 
prior to the next line shut down or within 24 hours of detection, whichever comes 
first.  An owner or operator shall repair leaks prior to returning equipment to 
operation.  
Liquids containing more than 0.2 percent VOC that leak at a rate of 3 drops per 
minute or more shall be repaired within 24 hours of detection, or the equipment 
shall be shut down until replaced or repaired according to the following schedule: 
Shut down prior to the next line shut down or within 24 hours of detection, 
whichever comes first. 
305.3 POU Combustion Devices: An owner or operator of a POU Combustion Device 
shall comply with one of the following requirements: 
a. Operate and maintain equipment in accordance with the manufacturers or
manufacturers authorized service provider written instructions for good
combustion practices; or
b. Submit to the Control Officer for approval a Good Combustion Plan that
includes, at a minimum, the following information:
(1) Company name and address;
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(2) A summary of POU combustion devices installed;
(3) A list and description of good combustion maintenance practices and/or
NOx emission monitoring methods; and 
(4) A description of malfunction procedures and responses.
303 
306 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS OPERATION AND 
MAINTENANCE (O&M) PLAN REQUIREMENTS FOR ECS: 
306.1 ECS Requirements: An owner or operator of an ECS at a semiconductor 
manufacturing facility shall: 
a. Only use natural gas, butane, hydrogen, or propane as fuel.
b. Operate the ECS in accordance with the manufacturer’s written instructions.
c. Ensure equipment is properly functioning in accordance with the most
recently submitted O&M plan.
306.2 Operation and Maintenance (O&M) Plan Required for ECS: 
303.1 
a. An owner or operator of a facility shall provide and maintain, readily available 
on-site at all times, (an) O&M Plan(s) for any ECS, any other emission 
processing equipment, and any ECS monitoring devices that are used 
pursuant to this rule or to an Maricopa County Air Quality pollution control 
Permit. 
303.2 
b. The owner or operator of a facility shall submit to the Control Officer for 
approval the O&M Plans of each ECS and of each ECS monitoring device that 
is used pursuant to this rule.  
303.3 
c. The owner or operator of a facility shall comply with all the identified actions 
and schedules provided in each O&M Plan. 
304.3 
306.3 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 and in operation 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 301.1 of this 
rule and is operated in accordance with the equipment manufacturer's 
specifications. 
Provide, properly install and maintain in calibration, in good working order, and in 
operation, devices for indicating or recording temperatures, pressures, rates of 
flow, concentrations or other operating parameters required by the O&M Plan for 
determining if air pollution control equipment or other means of control are 
functioning properly. 
303.3 
306.4 O&M Plan Responsibility: An owner or operator of a facility that is required to 
have an O&M Plan pursuant to Section 306.2 of this rule must fully comply with 
all O&M Plans that the owner or operator has submitted for approval, but which 
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have not yet been approved, unless notified otherwise by the Control Officer in 
writing. 
An owner or operator shall fully comply with each ECS O&M Plan that the owner 
or operator has submitted for approval, but which has not yet been approved, 
unless notified otherwise by the Control Officer in writing. 
306.5 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 the 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: 
401.1 ECS Installation at New Sources: For sources that commence construction after 
[revision date], compliance with the ECS requirements of Section 301.1 of this 
rule shall be achieved upon source startup. 
401.2 ECS Installation at Existing Sources: When a new ECS will be installed to achieve 
compliance with ECS requirements of Section 301.1 of this rule, an owner or 
operator shall comply with the following increments of progress and be in 
compliance with the requirements by the timeframe specified: 
a. Within 18 months of becoming subject to the ECS requirements in Section
301.1 of this rule, submit a compliance schedule and permit application, or
notification in lieu of permit application if already permitted as future
abatement, to the Control Officer.
b. Within 36 months of final permit issuance, or notification in lieu of permit
application if already permitted as future abatement, be fully compliant with
the ECS requirements in Section 301.1 of this rule and submit to the Control
Officer a complete source test report indicating compliance.
401.3 Modifications to Existing ECS: If it is necessary to modify an ECS by either 
reconstructing or adding on equipment in order to maintain compliance with 
Section 301.1 of this rule, an owner or operator shall comply with the following 
increments of progress and be in compliance with the requirements by the 
timeframe specified: 
a. Within 6 months of becoming subject to the ECS requirements in Section
301.1 of this rule, submit to the Control Officer a schedule for modification of
the ECS. The schedule shall show how the ECS is to be used to achieve full
compliance and shall specify dates for completing increments of progress.
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b. Within 12 months after the facility becomes subject to the requirements in
Section 301.1 of this rule, the owner or operator shall be complete with ECS
modifications and submit to the Control Officer a complete source test report
indicating compliance.
401.4 Good Combustion Plan Submittal: For sources that choose to comply with the 
requirements in Section 305.3(b) of this rule, an owner or operator shall comply 
with the timeframe specified: 
a. Existing Sources: Submit a Good Combustion Plan to the Control Officer no
later than 30 days after [revision date].
b. New Sources: Submit a Good Combustion Plan to the Control Officer upon
source startup.
401.1 Effective Date: This revised version of Rule 338 becomes effective on June 1, 
1999. 
401.2 ECS Schedule: Any owner or operator of a facility first becoming subject to the 
ECS requirements of Section 301 or Section 302 and intending to install and 
commence to use an ECS to comply with Section 301 or Section 302, shall 
submit for the Control Officer’s approval an emission control plan describing the 
ECS by the first day of the 4th month after the month in which such facility 
becomes subject to the ECS requirement. The plan shall show how the ECS is to 
be used to achieve full compliance. The plan shall specify dates for completing 
increments of progress, such as the contractual arrival date of new control 
equipment. The Control Officer may require a person submitting such emission 
control plan to submit subsequent reports on progress in achieving compliance. 
Any and all ECS used to achieve such compliance shall be in operation by 15 
months after the facility becomes subject to the ECS requirement. 
403 
APPLICABILITY OF RULE 331 FOR SUPPORT OPERATIONS: The solvent cleaning 
of equipment or parts that is performed for purposes other than semiconductor 
manufacturing shall be subject to the solvent cleaning Rule 331 of the Air 
Pollution Control Rules and Regulations. 
SECTION 500 – MONITORING AND RECORDS 
501 
MONITORING DEVICE RECORDS: Keep and maintain monitoring records as required by 
the O&M plan. 
502 
501 
RECORDKEEPING AND REPORTING: An Any person owner or operator subject to this 
rule shall comply with the following recordkeeping requirements: 
501.1 Records shall be retained for a period of five years. 
501.2 Records shall be made available to the Control Officer no later than five business 
days upon verbal or written request. 
501.3 Records shall be made available to the Control Officer upon request by members 
of the public using the County’s public records request process. 
501.4 Records shall be kept on site at all times in a consistent and complete manner. 
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502.1 
501.5 Current List: 
a. Maintain a current list of materials used in the manufacture of
semiconductors,: including coatings, adhesives, maskants, solvents, cleaning- 
solvents solutions, and any other VOC-containing materials regulated by this
rule. The list shall express VOC content in one of the following forms: State
the material VOC content of each in 
(1) Pounds VOC per gallon;
(2) Grams VOC per liter; or as a
(3) The percent VOC by weight along with the specific gravity or density
percent (percent by mass) of the material.
b. Maintain the written value of the total VOC vapor pressure of each cleaning- 
solvent regulated by this rule in one of the following forms:
(1) A manufacturer’s technical data sheet;
(2) A manufacturer’s safety data sheet (MSDS); or
(3) Actual test results.
502.2 
501.6 Usage Records: 
a. Maintain monthly records showing the type and amount of all VOC-containing
material used in semiconductor operations, except as modified by
subsections b and c following. This includes, but is not limited to, strippers,
maskants, and solvents. solvent materials and cleanup materials
b. Grouping by VOC Content: For purposes of recording usage, those maskants,
strippers, coatings, solvents or other VOC-containing materials that are of
similar type and similar VOC content may be given a group name and
recorded under that name. To the group name shall be assigned the highest
VOC content among the members of that group, rounded to the nearest 10th
of a pound per gallon, the nearest 1 g/l, or the nearest 1 percent. For each
grouping, the name of each material in the group and its material VOC content
must appear, along with the name of the grouping and its material VOC
content.
c. Update annually the usage of materials having a VOC content of 10.0% or
less. The results of an applicable test method, referred to in Section 504, or
data supplied by the material’s manufacturer suffices to demonstrate VOC
content of material for this purpose. If there is a discrepancy between the
manufacturer’s formulation data and the results of an applicable test method,
compliance shall be based on the results from the test method analysis.
502.3 
501.7 Records of Disposal: Sources complying with Section 301.2(a) shall maintain 
monthly records of the type, amount, and method of disposing of VOC-containing 
materials. Records of legal disposal include but are not limited to shipping 
papers or quantity discharged to sewage treatment works. 
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a. The Control Officer may account as VOC emissions to the atmosphere such
VOC as is not accounted for by an adequate demonstration of VOC
recordkeeping.
b. Emission factors acceptable to the Control Officer are allowed to be used in
calculating VOC emissions.
501.8 POU Combustion Device Recordkeeping: An owner or operator of a POU 
Combustion Device shall comply with the recordkeeping requirements in Section 
501.8(a) or Section 501.8(b): 
a. Manufacturer’s Operation and Maintenance: Maintain the following records
onsite and available to the Control Officer upon request:
(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and 
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary. 
b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.
502.4 ECS Recordkeeping: 
a. Make a continuous record of the times an ECS is used to comply with this
rule.
b. Maintain records of the O&M Plan’s key system operating parameters with
the frequency required by the Plan.
c. Maintain records of all maintenance performed according to the O&M Plan.
d. An explanation shall be entered for scheduled maintenance that is not
performed during the period designated in the O&M Plan.
502 
ECS RECORDKEEPING 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 a required 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 which may include the following, when applicable:  
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. 
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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 
3 business days 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: When more than one test method is permitted for a 
determination, an exceedance of the limits established in this rule determined by any of 
the applicable test methods constitutes a violation of this rule. 
503.1 Sample Analysis: The following test methods shall be used for determining VOC 
content. For routine information collection, the Control Officer may accept a 
manufacturer’s safety data sheet (MSDS), data certified by an officer of the 
supplying company, or test data for the product model of inquiry. 
a. The VOC content of materials having more than 10% solids by volume shall
be determined using the applicable EPA Reference Method 24 or 24A (40
CFR, Part 60, Appendix A-7).
b. The VOC content of solutions, dispersions, and emulsions that have no solids
or less than 5% solids shall be determined by Method 31 of California’s Bay
Area Air Quality Management District (BAAQMD), or by California’s South
Coast Air Quality Management District Method (SCAQMD) 313-91.
c. Solids-free solutions, in which all organic components are VOCs, may be
tested using ASTM D2369-10e1, “Standard Test Method for Volatile Content
of Coatings” Maricopa County Reference Method #100, “Total Organic Carbon
for Windshield Washer Fluids”, Maricopa County Air Pollution Control Rule
344 (April 7, 1999).
d. The VOC content of materials believed to have between 5 and 10% solids
shall be determined by EPA Method 24 (40 CFR 60, Appendix A-7), by
BAAQMD Method 31, or by the SCAQMD Method 313-91.
503.2 Emission Testing: An ECS used pursuant to Section 301.1 and/or Section 302 
shall be tested at least once every five years using EPA Reference Test Methods 
18 (40 CFR 60, Appendix A-6), or 25, 25A, or 25B (40 CFR 60, Appendix A-7), or an 
applicable submethod of such Test Methods. VOC emission shall be measured 
and calculated as propane carbon. 
503.3 ECS Efficiency Capture Efficiency: An owner or operator that complies with 
Section 301.1(a) of this rule shall demonstrate compliance using the following 
methods and equations: 
a. Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100 
Where, 
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EffO 
= Overall ECS efficiency expressed as a percentage; and 
EffCo 
= ECS control efficiency expressed as a percentage; and 
EffCa 
= ECS capture efficiency expressed as a percentage. 
b. The ECS control efficiency shall be determined by measuring the VOC content
of gaseous emissions entering and exiting the ECS using EPA Method 18 (40
CFR 60, Appendix A-6) or EPA Method 25 (40 CFR 60, Appendix A-7).
c. The ECS capture efficiency of an emission control device used to meet the
requirements of Section 301 or Section 302 shall be determined by mass
balance in combination with ventilation/draft rate determinations done in
accordance with subSection 503.54, or US EPA Test Methods 204, 204A,
204B, 204C, 204D, 204E, and 204F, (40 CFR 51, Appendix M). Verification that
all active hoods and ducts, when measured at any selection of any interior
place within them, are at negative pressure relative to adjacent, uncaptured
air shall suffice for routine and uncontested demonstration of capture
adequacy.
503.4 Alternative for Very Dilute Input: An owner or operator that complies with 
Section 301.1(b) of this rule shall demonstrate compliance by using EPA Method 
25A (40 CFR 60, Appendix A-7). 
503.4 
503.5 Ventilation/Draft Rates: Ventilation/draft rates shall be determined by EPA 
Methods 2, 2A, 2C, or 2D (40 CFR 60, Appendix A-1). 
503.5 Determination of acceptable trace VOC-emission, with reference to subsection 
302.2c, shall use a methane calibration standard. The detection instrument shall 
meet the requirements of EPA Test Method 21 (40 CFR 60). Use of the detection 
instrument shall generally meet the probe movement speed and probe 
orientation specifications of Method 21 for the exterior of piping, valves, tubing, 
connectors, and containers. Means other than described in Method 21 may be 
used for detector handling and positioning immediately above open liquids and 
within containers, ducts, and piping. A valid instrument reading under 50 ppm or 
220 mg/M3 using a probe positioned closer than 1 inch also demonstrates 
acceptable trace VOC emission. 
402 
503.6 Control Efficiency Generalization: An owner or operator is allowed the following 
option: 
402.1 
a. You may calculate the processing efficiency of an ECS processing 
subsystem, operated pursuant to subsection Section 301.1a, that also 
optionally controls other VOC in addition to photoresist process tool VOC, by 
assuming the same percentage efficiency as was calculated from testing the 
efficiency of controlling all input VOC. For example, if the capture/collection 
subsystem blends 150 lbs per hour of photoresist process tool VOC with 50 
lbs per hour of etchant VOC, and if the processor simultaneously reduces the 
150 lbs of photoresist process tool VOC to 15 pounds of VOC and 50 pounds 
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of etching VOC to 3 lbs of VOC, the processor will be credited with reducing 
the photoresist process tool VOC by 
91% = 100% x 1
15
3
150
50
−
+
+







; not 90%. 
402.2 
b. In calculating the processing efficiency of an ECS processing subsystem 
operated pursuant to subsection Section 301.12a for an ECS that controls, in 
addition to cleaning-solvent and photoresist process tool VOC, other VOC not 
addressed by subsection Section 301.12, it may be assumed that the ECS’ 
efficiency for processing the aggregate of cleaning-solvent plus photoresist 
process tool VOC is the same as that calculated from testing the efficiency of 
controlling all input VOC. 
503.7 Formula for VOC Content of Material: The VOC content of material shall be 
calculated by the following equation: 
VOC CONTENT OF MATERIAL as a percent =
W
W
W
m
s
w
es
W
−
−
 X 100% 
Using consistently either pounds or grams in the calculations, where: 
Ws   =
Weight of volatile material in pounds (or grams), including 
water, non-precursor organic compounds, and dissolved 
vapors 
Ww   
=
Weight of water in pounds (or grams) 
Wes   =
Total weight of non-precursor organic compounds in pounds 
(or grams) 
Wm   
=
Weight of total material in pounds (or grams) 
Grams of VOC per Liter of Material = 
VOC CONTENT OF MATERIAL in pounds per gallon (lbs/gal) or grams per liter 
(g/l) = 
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚
 
Using consistently either pounds or grams in the calculations, where: 
Ws  = 
Weight of all volatile compounds in pounds (or grams), including VOC,
water, non-precursor organic exempt compounds, and dissolved vapors 
Ww  = 
Weight of water in pounds (or grams)
Wes  = 
Weight of all non-precursor compounds in pounds (or grams) Total
weight of all exempt compounds in grams 
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Vm  = 
Volume of material in gallons (or liters)
503.6 
503.8 Formula for Total VOC Vapor Pressure (Equivalent to: VOC Composite Partial 
Pressure): The total VOC vapor pressure shall be calculated by the following 
equation: with reference to Sections 301 and 302. 
(
)(
)
PP
W
VP
MW
W
W
MW
W
MW
c
i
i
i
i
n
w
ej
ej
i
i
i
n
i
m
=
+
+
=
=
=
∑
∑
∑
1
1
1
18
Where: 
Wi
= 
Weight of the “i”th VOC compound in grams 
Ww  
=
Weight of water in grams 
Wej  
=
Weight of the “j”th non-precursor organic compound exempt 
evaporating compound in grams 
MWi  =
Molecular weight of the “i”th VOC compound in grams per gram 
mole, e.g., one gram-mole of isopropyl alcohol weighs 60 grams 
MWej  =
Molecular weight of the “j”th exempt evaporating non-precursor 
organic compound, e.g., 1 gram-mole of acetone weighs 58 grams; 1 
g-mole HCl =36.5 g
PPc
= 
VOC composite partial pressure at 68° F 20°C in mm mercury (Hg) 
VPi
= 
Vapor pressure of the “i”th VOC compound at 68° F 20°C in mm Hg 
18 
= 
Weight of one gram-mole of water 
n 
= 
Total number of different (dissolved) VOCs 
m 
= 
Total number of different (dissolved) exempt non-precursor organic 
compounds 
503.9 Formula for Determination of VOC Emissions: 
𝑉𝑉𝑉𝑉𝑉𝑉 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸= ෍(𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶)(1 −𝐶𝐶𝐶𝐶)
𝑛𝑛
𝑖𝑖=1
+ ෍(𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈)
𝑚𝑚
𝑗𝑗=1
Where: 
𝑽𝑽𝑽𝑽𝑽𝑽 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬 =  The total sum of VOCs emitted to ambient air from all process 
tool operations 
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𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪 = Mass of VOC emissions generated from the “i”th source of 
process tool operations which is routed to a control device 
designed to destroy VOC 
𝑪𝑪𝑪𝑪 = Overall capture and control efficiency of VOC for the specific 
control device which the “i”th source of VOC emissions is routed 
to 
𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼 = Mass of VOC emissions generated from the “j”th source of 
process tool operations which is not routed to a control device 
designed to destroy VOC 
504 
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 Rule 360 and Appendix G of the MCAPCR. 
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. 
The EPA test methods as they exist in the Code of Federal Regulations (CFR) (July 1, 
1998), as listed below, are adopted by reference. The other test methods listed here are 
also adopted by reference, each having paired with it a specific date that identifies the 
particular version/revision of the method that is adopted by reference. These adoptions 
by reference include no future editions or amendments. Copies of test methods 
referenced in this Section 504 are available at the Maricopa County Air Quality 
Department. 
504.1 EPA-Approved Test Methods Incorporated by Reference: 
a. EPA Methods 1 (“Sample and Velocity Traverses for Stationary Sources”) and
1A (“Sample and Velocity Traverses for Stationary Sources with Small Stacks
or Ducts”) (40 CFR 60, Appendix A-1).
a.
b. EPA Methods 2 (“Determination of Stack Gas Velocity and Volumetric Flow
Rate”), 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”), and 2D (“Measurement of Gas volumetric Flow Rates 
in Small Pipes and Ducts”) (40 CFR 60, Appendix A-1) All 4 of the foregoing 
methods are in 40 CFR 60, Appendix A. 
c. EPA Methods 3 (“Gas Analysis for the Determination of Dry Molecular
Weight”), 3A (“Determination of Oxygen and Carbon Dioxide Concentrations in
Emissions From Stationary Sources (Instrumental Analyzer Procedure”), 3B
(“Gas Analysis for the Determination of Emission Rate Correction Factor or
Excess Air”), and 3C (“Determination of Carbon Dioxide, Methane, Nitrogen,
and Oxygen from Stationary Sources”) (40 CFR 60, Appendix A-2).
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d. EPA Method 4 (“Determination of Moisture Content in Stack Gases”) (40 CFR
60, Appendix A-3).
b.
e. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions by
Gas Chromatography”) and its submethods (40 CFR 60, Appendix A-6). 
c.
f. EPA Test Method 21 (“Determination of Volatile Organic Compounds Leaks”)
(40 CFR 60, Appendix A-7). 
d.
g. EPA Test Method 24 (“Determination of Volatile Matter Content, Water
Content, Density, Volume Solids, and Weight Solids of Surface Coatings”) and 
24A (“Determination of Volatile Matter Content and Density of Printing Inks 
and Related Coatings”) (40 CFR 60, Appendix A-7). 
e.
h. EPA Methods 25 (“Determination of Total Gaseous Non-Methane 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-7).
f.
i. EPA Test Method 204 (“Criteria for and Verification of a Permanent or
Temporary Total Enclosure”), and related Methods 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). 
j.
EPA Method 320 (“Measurement of Vapor Phase Organic and Inorganic
Emissions by Extractive Fourier Transform Infrared (FTIR) Spectroscopy”) (40
CFR 63, Appendix A).
504.2 Other (Non-EPA) EPA-Approved California Air Resources Board (CARB) Test 
Methods Incorporated by Reference: 
a. California’s Bay Area Air Quality Management District (BAAQMD) Method 31
(May 18, 2005 April 15, 1992), “Determination of Volatile Organic Compounds
in Paint Strippers, Solvent Cleaners, and Low Solids Coatings”.
b. California’s South Coast Air Quality Management District (SCAQMD) Method
313-91 (February April, 1997), “Determination of Volatile Organic Compounds
(VOC) by Gas Chromatography/Mass Spectrometry (GC/MS)”.
504.3 EPA-Approved American Society for Testing and Materials (ASTM) Standard 
Incorporated by Reference: 
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a. ASTM D6348-12e1, “Standard Test Method for Determination of Gaseous
Compounds by Extractive Direct Interface Fourier Transform Infrared (FTIR)
Spectroscopy”.
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MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 338 (SEMICONDUCTOR MANUFACTURING) 
INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
APPLICABILITY 
103 
EXEMPTIONS 
SECTION 200 – DEFINITIONS 
201 
CLEANING-SOLVENT 
202 
EMISSION CONTROL SYSTEM (ECS) 
203 
FREEBOARD HEIGHT 
204 
FREEBOARD RATIO 
205 
HEATED SOLVENT 
206 
LEAK 
207 
PARTS PER MILLION BY VOLUME DRY (PPMVD) 
208 
PHOTORESIST OPERATION 
209 
POINT-OF-USE (POU) COMBUSTION DEVICE 
210 
PROCESS TOOL 
211 
RESEARCH AND DEVELOPMENT 
212 
SOLVENT 
213 
SOLVENT CLEANING STATION 
214 
STRIPPING 
215 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 
216 
VOC CONTENT OF MATERIAL 
SECTION 300 – STANDARDS 
301 
CONTROL OF VOC EMISSIONS FROM SEMICONDUCTOR MANUFACTURING 
OPERATIONS 
302 
SOLVENT CLEANING STATION OPERATIONS 
303 
CLEANING-SOLVENT SPECIFICATIONS 
Clean version of Draft Rule 338
Return to list of attachments
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304 
WORK PRACTICES – HANDLING, STORAGE AND DISPOSAL OF VOC-CONTAINING 
MATERIALS 
305 
OPERATING REQUIREMENTS 
306 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
COMPLIANCE SCHEDULE 
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING 
502 
ECS RECORDKEEPING REQUIREMENTS 
503 
COMPLIANCE DETERMINATION 
504 
TEST METHODS INCORPORATED BY REFERENCE 
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Adopted 11/16/92; Revised 06/19/96; Revised 04/21/99; Revised 09/25/13; Revised 
MM/DD/YYYY 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION III – CONTROL OF AIR CONTAMINANTS 
RULE 338 (SEMICONDUCTOR MANUFACTURING) 
SECTION 100 – GENERAL 
101 
PURPOSE: To limit the emissions of volatile organic compounds (VOCs) and nitrogen 
oxides (NOx) from semiconductor manufacturing. 
102 
APPLICABILITY: 
102.1 This rule applies to: 
a. The manufacturing of any semiconductor device, including diodes, zeners,
stacks, rectifiers, integrated microcircuits, transistors, solar cells, light-
sensing devices, and light-emitting devices.
b. All direct processing of the wafer/die from crystal growth and wafer
production through oxidation, photoresist operations, etching, doping,
epitaxial growth operations, circuit separation, encapsulation, and those
assembly and test operations related to semiconductor manufacturing.
102.2 This rule does not apply to an accredited school that has an educational program 
in which semiconductors are either fully or partially made. However, this rule is 
applicable to schools that sell such semiconductor constructions for other than 
teaching and/or research purpose(s). 
102.3 This rule does not apply to the solvent cleaning of equipment or parts that is 
performed for purposes other than semiconductor manufacturing and such 
activity shall be subject to requirements of Rule 331 (Solvent Cleaning) of the 
MCAPCR. 
102.4 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 the MCAPCR. 
103 
EXEMPTIONS: 
103.1 Quality Control and Research and Development Operations: Except for Sections 
304, 305, and 501, this rule shall not apply to those operations within a 
semiconductor manufacturing facility which are used exclusively for one or more 
of the following: chemical or physical analysis, determination of product quality 
or commercial acceptance, research and development, or pilot plant activities. 
Such operations may be exempted until the 12-consecutive month VOC 
emissions from all such exempted operations reaches but does not exceed 7.3 
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tons. This exemption shall not apply to a particular operation if the exemption is 
denied in writing by the Control Officer. 
103.2 Low-VOC Materials: Materials containing less than 10% VOC by weight if 
unheated, or less than 2.5% VOC by weight if heated, are exempt from Sections 
301, 302, 303, and 306 of this rule. The VOC content shall be determined 
pursuant to Section 503.7 of this rule. 
103.3 Organic Silicon Compounds: VOC emissions up to an aggregated 12-consecutive 
month total of 1 ton of organic silanes and silicates, and any other organic 
compound of carbon and silicon, may be excluded by an owner or operator from 
being subject to the ECS control requirements of Section 301.1 if information 
from the manufacturer of the ECS indicates that such compounds adversely 
affect the operation of the model or type of ECS being used. 
103.4 Wipe Cleaning: Wipe cleaning is subject to the applicable requirements of Rule 
331 (Solvent Cleaning) of the MCAPCR. 
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 the MCAPCR. In the event of any inconsistency between any of the rules within 
the MCAPCR, the definitions in this rule take precedence.  
201 
CLEANING-SOLVENT: Solvent used for cleaning that contains more than 2.0% VOC by 
weight and more than 20 grams of VOC per liter (0.17 lb/gal). 
202 
EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control 
Officer, used to reduce emissions of volatile organic compounds. Such a system 
consists of an emissions collection system and an emissions processing subsystem. 
203 
FREEBOARD HEIGHT: The following measurement within the tank/basin of a cleaning 
machine, as determined during idling mode: 
203.1 Batch Cleaning Machine: The vertical distance from the solvent/air interface to 
the least elevated point of the top-rim when the cover is open or removed. 
203.2 In-Line Cleaning Machine: The vertical distance from the solvent/air interface to 
the lowest entry/exit point. 
204 
FREEBOARD RATIO: The freeboard height divided by the smaller of either the length or 
width of the solvent cleaning machine. 
205 
HEATED SOLVENT: Any cleaning-solvent which is heated by a device to a temperature 
exceeding 120° F (49° C) but does not exceed the solvent boiling point. 
206 
LEAK: A visible VOC-containing liquid leak at a rate of more than three drops per minute, 
or a puddle greater than one square inch.  
207 
PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express 
concentration that is corrected to a dry basis. 
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208 
PHOTORESIST OPERATION: A process for the application and development of 
photoresist masking solution on a wafer, including preparation (except primary 
cleaning), soft bake, develop, hard bake, stripping, and edge-bead removal. 
209 
POINT-OF-USE (POU) COMBUSTION DEVICE: A device that is installed in close 
proximity to process equipment and is a source of combustion which generates NOx 
emissions.  
210 
PROCESS TOOL: Equipment used during the semiconductor fabrication process to 
perform various operations needed to make the final product. This does not include 
equipment that uses solvent in ashing, plasma etch, diffusion and chemical vapor 
deposition processes. 
211 
RESEARCH AND DEVELOPMENT: An operation whose primary purpose is for research 
and development of new processes and products and that is conducted under the close 
supervision of technically trained personnel and is not involved in the manufacture of 
final or intermediate products for commercial purposes, except in a de minimis manner. 
212 
SOLVENT: For the purpose of this rule, any VOC-containing liquid which is used to 
dissolve, clean, strip, or remove impurities, coatings, contaminants, or films from 
surfaces or from internal spaces and voids. This includes, but is not limited to, 
developers and stripping agents.  
213 
SOLVENT CLEANING STATION: A workplace equipped to remove surface contaminants 
using a VOC-containing liquid. This excludes photoresist stripping processes. 
214 
STRIPPING: The removal of spent photoresist maskant from the product after etching, 
or the removal of oxide or other stencil agent from the product after diffusion, or any 
other removal of applied masking agent. 
215 
TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE): Within a 
solution or homogenous mixture, it is the sum of the partial pressures of all those 
components that are defined as VOCs, calculated according to the formula in Section 
503.8 of this rule. 
216 
VOC CONTENT OF MATERIAL: The weight of VOC per volume of material, calculated 
according to the formula in Section 503.7 of this rule. 
SECTION 300 – STANDARDS 
301 
CONTROL OF VOC EMISSIONS FROM SEMICONDUCTOR MANUFACTURING 
OPERATIONS: 
301.1 An owner or operator of a semiconductor manufacturing operation that annually 
emits 25 or more tons of VOCs per year from process tool operations, prior to 
any emissions controls, shall maintain such operations under negative pressure, 
per Section 503.3 and meet one of the following requirements: 
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a. Achieve at least 90% overall VOC capture and control of process tool
operations, determined by applicable provisions in Section 503.3; or
b. For VOC input-concentrations of less than 100 ppmvd (as propane) at the
inlet of the ECS, the control efficiency is satisfied if the VOC outlet
concentration is less than or equal to 10 ppmvd (as propane), as determined
by applicable provisions in Section 503.4.
301.2 Any VOC emissions not controlled per Section 301.1 shall be assumed to have 
evaporated onsite unless: 
a. Records demonstrating otherwise can be provided to the Control Officer per
Section 501.7; or
b. The VOC emissions are accounted for in emissions calculations per Section
503.9.
302 
SOLVENT CLEANING STATION OPERATIONS: An owner or operator operating a solvent 
cleaning station using a solvent containing more than 10% VOC by weight at a 
semiconductor manufacturing facility shall meet all of the following requirements 
unless the solvent cleaning station complies with Section 303.3 or 303.4: 
302.1 Each heated or unheated reservoir, sink, and container that transfers, stores, or 
holds VOC-containing material shall be provided with a full cover. A cover shall 
remain closed except while production, sampling, maintenance, or loading or 
unloading procedures require operator access; and 
302.2 All heated or unheated reservoirs and sinks holding VOC-containing materials 
with a total VOC vapor-pressure exceeding 33.0 millimeters of mercury column 
(mm Hg) at 68° F (20° C) shall have a freeboard ratio greater than or equal to 1.0; 
and 
302.3 Solvent flow of VOC-containing materials shall be applied in a continuous 
unbroken stream and in a manner which shall prevent liquid loss resulting from 
splashing. 
303 
CLEANING-SOLVENT SPECIFICATIONS: An owner or operator using a VOC-containing 
solvent for the purpose of cleaning semiconductor manufacturing equipment at a 
semiconductor manufacturing facility shall meet one of the following requirements. 
This includes, but is not limited to, the cleaning of empty boats, quartz tubes, and other 
devices used to hold, contain, or process semiconductors. 
303.1 Use a cleaning-solvent having a VOC content that does not exceed 200 grams 
per liter (1.7 pounds per gallon); or 
303.2 Using a cleaning-solvent having a VOC composite partial pressure that does not 
exceed 33.0 mm Hg at a temperature of 68° F (20° C); or 
303.3 Use an ECS to capture and control VOC emissions in accordance with Section 
301.1 of this rule; or 
303.4 Use a sealed system that is an Air-tight or Airless Cleaning System, which is 
operated according to the manufacturer specifications and, unless otherwise 
indicated by the manufacturer, meets all of the following requirements: 
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a. Has a door or other pressure-sealing apparatus that is shut during each
cleaning and drying cycle; and
b. Has a differential pressure gauge that always indicates the pressure in the
sealed chamber when occupied or in active use; and
c. Any associated pressure relief device(s) shall be so designed and operated as
to prevent liquid cleaning-solvents from draining out.
304 
WORK PRACTICES – HANDLING, STORAGE AND DISPOSAL OF VOC-CONTAINING 
MATERIALS: 
304.1 Store all VOC-containing materials in closed, leak free containers. Containers 
shall remain covered with a leak tight cover when not in use. 
304.2 Containers in which VOC-containing materials are stored must have a legible 
label identifying the container’s contents. 
304.3 Disposal of waste or surplus VOC-containing materials shall be done in a manner 
that does not promote VOC evaporation, such as, but not limited to, via sewage 
treatment works or having the waste hauled off-site in sealed containers. 
305 
OPERATING REQUIREMENTS: 
305.1 Process Equipment: All active process equipment in which VOC-containing 
materials are used shall be operated and maintained in proper working order. 
305.2 Leaks: Equipment with a VOC-containing liquid leak shall either be shut down 
prior to the next line shut down or within 24 hours of detection, whichever comes 
first. An owner or operator shall repair leaks prior to returning equipment to 
operation. 
305.3 POU Combustion Devices: An owner or operator of a POU Combustion Device 
shall comply with one of the following requirements: 
a. Operate and maintain equipment in accordance with the manufacturers or
manufacturers authorized service provider written instructions for good
combustion practices; or
b. Submit to the Control Officer for approval a Good Combustion Plan that
includes, at a minimum, the following information:
(1) Company name and address;
(2) A summary of POU combustion devices installed;
(3) A list and description of good combustion maintenance practices and/or
NOx emission monitoring methods; and
(4) A description of malfunction procedures and responses.
306 
EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS: 
306.1 ECS Requirements: An owner or operator of an ECS at a semiconductor 
manufacturing facility shall: 
a. Only use natural gas, butane, hydrogen, or propane as fuel.
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b. Operate the ECS in accordance with the manufacturer’s written instructions.
c. Ensure equipment is properly functioning in accordance with the most
recently submitted O&M plan.
306.2 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.
306.3 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 and in operation 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 301.1 of this 
rule and is operated in accordance with the equipment manufacturer's 
specifications. 
306.4 O&M Plan Responsibility: An owner or operator of a facility that is required to 
have an O&M Plan pursuant to Section 306.2 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. 
306.5 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 the 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: 
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401.1 ECS Installation at New Sources: For sources that commence construction after 
[revision date], compliance with the ECS requirements of Section 301.1 of this 
rule shall be achieved upon source startup. 
401.2 ECS Installation at Existing Sources: When a new ECS will be installed to achieve 
compliance with ECS requirements of Section 301.1 of this rule, an owner or 
operator shall comply with the following increments of progress and be in 
compliance with the requirements by the timeframe specified: 
a. Within 18 months of becoming subject to the ECS requirements in Section
301.1 of this rule, submit a compliance schedule and permit application, or
notification in lieu of permit application if already permitted as future
abatement, to the Control Officer.
b. Within 36 months of final permit issuance, or notification in lieu of permit
application if already permitted as future abatement, be fully compliant with
the ECS requirements in Section 301.1 of this rule and submit to the Control
Officer a complete source test report indicating compliance.
401.3 Modifications to Existing ECS: If it is necessary to modify an ECS by either 
reconstructing or adding on equipment in order to maintain compliance with 
Section 301.1 of this rule, an owner or operator shall comply with the following 
increments of progress and be in compliance with the requirements by the 
timeframe specified: 
a. Within 6 months of becoming subject to the ECS requirements in Section
301.1 of this rule, submit to the Control Officer a schedule for modification of
the ECS. The schedule shall show how the ECS is to be used to achieve full
compliance and shall specify dates for completing increments of progress.
b. Within 12 months after the facility becomes subject to the requirements in
Section 301.1 of this rule, the owner or operator shall be complete with ECS
modifications and submit to the Control Officer a complete source test report
indicating compliance.
401.4 Good Combustion Plan Submittal: For sources that choose to comply with the 
requirements in Section 305.3(b) of this rule, an owner or operator shall comply 
with the timeframe specified: 
a. Existing Sources: Submit a Good Combustion Plan to the Control Officer no
later than 30 days after [revision date].
b. New Sources: Submit a Good Combustion Plan to the Control Officer upon
source startup.
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING: An owner or operator subject to this rule shall 
comply with the following recordkeeping requirements: 
501.1 Records shall be retained for a period of five years. 
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501.2 Records shall be made available to the Control Officer no later than five business 
days upon verbal or written request. 
501.3 Records shall be made available to the Control Officer upon request by members 
of the public using the County’s public records request process. 
501.4 Records shall be kept on site at all times in a consistent and complete manner. 
501.5 Current List: 
a. Maintain a current list of materials used in the manufacture of
semiconductors, including coatings, adhesives, maskants, solvents, cleaning- 
solvents, and any other VOC-containing materials regulated by this rule. The
list 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. Maintain the written value of the total VOC vapor pressure of each cleaning- 
solvent regulated by this rule in one of the following forms:
(1) A manufacturer’s technical data sheet;
(2) A manufacturer’s safety data sheet (MSDS); or
(3) Actual test results.
501.6 Usage Records: 
a. Maintain monthly records showing the type and amount of all VOC-containing
material used in semiconductor operations. This includes, but is not limited to
strippers, maskants, and solvents.
b. Grouping by VOC Content: For purposes of recording usage, those maskants,
strippers, coatings, solvents or other VOC-containing materials that are of
similar type and similar VOC content may be given a group name and
recorded under that name. To the group name shall be assigned the highest
VOC content among the members of that group, rounded to the nearest 10th
of a pound per gallon, the nearest 1 g/l, or the nearest 1 percent. For each
grouping, the name of each material in the group and its material VOC content
must appear, along with the name of the grouping and its material VOC
content.
501.7 Records of Disposal: Sources complying with Section 301.2(a) shall maintain 
monthly records of the type, amount, and method of disposing of VOC-containing 
materials. Records of legal disposal include but are not limited to shipping 
papers or quantity discharged to sewage treatment works. 
501.8 POU Combustion Device Recordkeeping: An owner or operator of a POU 
Combustion Device shall comply with the recordkeeping requirements in Section 
501.8(a) or Section 501.8(b): 
a. Manufacturer’s Operation and Maintenance: Maintain the following records
onsite and available to the Control Officer upon request:
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(1) Manufacturers or manufacturers authorized service provider
recommended operation and maintenance instructions; and
(2) Records of any malfunctions that could result in an increase of NOx
emissions and corrective actions, if necessary.
b. Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 305.3(b). The plan must be reviewed every year and updated as
needed to contain current information. The annual review and any change to
the plan shall be documented.
502 
ECS RECORDKEEPING 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 a required 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 which may include the following, when applicable:  
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 
3 business days 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: When more than one test method is permitted for a 
determination, an exceedance of the limits established in this rule determined by any of 
the applicable test methods constitutes a violation of this rule. 
503.1 Sample Analysis: The following test methods shall be used for determining VOC 
content. For routine information collection, the Control Officer may accept a 
MSDS, data certified by an officer of the supplying company, or test data for the 
product model of inquiry. 
a. The VOC content of materials having more than 10% solids by volume shall
be determined using the applicable EPA Method 24 or 24A (40 CFR, Part 60,
Appendix A-7).
b. The VOC content of solutions, dispersions, and emulsions that have no solids
or less than 5% solids shall be determined by Method 31 of California’s Bay
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Area Air Quality Management District (BAAQMD), or by California’s South 
Coast Air Quality Management District Method (SCAQMD) 313-91. 
c. Solids-free solutions, in which all organic components are VOCs, may be
tested using ASTM D2369-10e1, “Standard Test Method for Volatile Content
of Coatings”.
d. The VOC content of materials believed to have between 5 and 10% solids
shall be determined by EPA Method 24 (40 CFR 60, Appendix A-7), by
BAAQMD Method 31, or by the SCAQMD Method 313-91.
503.2 Emission Testing: An ECS used pursuant to Section 301.1 shall be tested at least 
once every five years using EPA Methods 18 (40 CFR 60, Appendix A-6), 25, 25A, 
or 25B (40 CFR 60, Appendix A-7). VOC emission shall be measured and 
calculated as propane. 
503.3 ECS Efficiency: An owner or operator that complies with Section 301.1(a) of this 
rule shall demonstrate compliance using the following methods and equations: 
a. Overall ECS Efficiency shall be determined using the following equation:
EffO = (EffCo x EffCa) / 100 
Where, 
EffO 
= Overall ECS efficiency expressed as a percentage; and 
EffCo 
= ECS control efficiency expressed as a percentage; and 
EffCa 
= ECS capture efficiency expressed as a percentage. 
b. The ECS control efficiency shall be determined by measuring the VOC content
of gaseous emissions entering and exiting the ECS using EPA Method 18 (40
CFR 60, Appendix A-6) or EPA Method 25 (40 CFR 60, Appendix A-7).
c. The ECS capture efficiency shall be determined by mass balance in
combination with ventilation/draft rate determinations done in accordance
with Section 503.5, or EPA Methods 204, 204A, 204B, 204C, 204D, 204E, and
204F, (40 CFR 51, Appendix M). Verification that all active hoods and ducts,
when measured at any selection of any interior place within them, are at
negative pressure relative to adjacent, uncaptured air shall suffice for routine
and uncontested demonstration of capture adequacy.
503.4 Alternative for Very Dilute Input: An owner or operator that complies with 
Section 301.1(b) of this rule shall demonstrate compliance by using EPA Method 
25A (40 CFR 60, Appendix A-7). 
503.5 Ventilation/Draft Rates: Ventilation/draft rates shall be determined by EPA 
Methods 2, 2A, 2C, or 2D (40 CFR 60, Appendix A-1). 
503.6 Control Efficiency Generalization: An owner or operator is allowed the following 
option: 
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a. You may calculate the processing efficiency of an ECS processing
subsystem, operated pursuant to Section 301, that also optionally controls
other VOC in addition to process tool VOC, by assuming the same percentage
efficiency as was calculated from testing the efficiency of controlling all input
VOC. For example, if the capture/collection subsystem blends 150 lbs per
hour of process tool VOC with 50 lbs per hour of etchant VOC, and if the
processor simultaneously reduces the 150 lbs of process tool VOC to 15
pounds of VOC and 50 pounds of etching VOC to 3 lbs of VOC, the processor
will be credited with reducing the process tool VOC by
91% = 100% x 1
15
3
150
50
−
+
+







; not 90%. 
b. In calculating the processing efficiency of an ECS processing subsystem
operated pursuant to Section 301.1 for an ECS that controls, in addition to
cleaning-solvent and process tool VOC, other VOC not addressed by Section
301.1, it may be assumed that the ECS’ efficiency for processing the
aggregate of cleaning-solvent plus process tool VOC is the same as that
calculated from testing the efficiency of controlling all input VOC.
503.7 Formula for VOC Content of Material: The VOC content of material shall be 
calculated by the following equation: 
VOC CONTENT OF MATERIAL as a percent = 
W
W
W
m
s
w
es
W
−
−
 X 100% 
Using consistently either pounds or grams in the calculations, where: 
Ws   =
Weight of volatile material in pounds (or grams), including 
water, non-precursor organic compounds, and dissolved 
vapors 
Ww   
=
Weight of water in pounds (or grams) 
Wes   =
Total weight of non-precursor organic compounds in pounds 
(or grams) 
Wm   
=
Weight of total material in pounds (or grams) 
VOC CONTENT OF MATERIAL in pounds per gallon (lbs/gal) or grams per liter 
(g/l) = 
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚
 
Using consistently either pounds or grams in the calculations, where: 
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Ws  =
Weight of all volatile compounds in pounds (or grams), including VOC, 
water, non-precursor organic compounds, and dissolved vapors 
Ww  =
Weight of water in pounds (or grams) 
Wes  =
Weight of all non-precursor compounds in pounds (or grams) 
Vm  =
Volume of material in gallons (or liters) 
503.8 Formula for Total VOC Vapor Pressure (Equivalent to: VOC Composite Partial 
Pressure): The total VOC vapor pressure shall be calculated by the following 
equation: 
(
)(
)
PP
W
VP
MW
W
W
MW
W
MW
c
i
i
i
i
n
w
ej
ej
i
i
i
n
i
m
=
+
+
=
=
=
∑
∑
∑
1
1
1
18
Where: 
Wi
= 
Weight of the “i”th VOC compound in grams 
Ww
= 
Weight of water in grams 
Wej
= 
Weight of the “j”th non-precursor organic compound in grams 
MWi
= 
Molecular weight of the “i”th VOC compound in grams per gram 
mole 
MWej  =
Molecular weight of the “j”th non-precursor organic compound 
PPc
= 
VOC composite partial pressure at 68° F in mm mercury (Hg) 
VPi
= 
Vapor pressure of the “i”th VOC compound at 68° F in mm Hg 
18 
= 
Weight of one gram-mole of water 
n 
= 
Total number of different (dissolved) VOCs 
m 
= 
Total number of different (dissolved) non-precursor organic 
compounds 
503.9 Formula for Determination of VOC Emissions: 
𝑉𝑉𝑉𝑉𝑉𝑉 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸= ෍(𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶)(1 −𝐶𝐶𝐶𝐶)
𝑛𝑛
𝑖𝑖=1
+ ෍(𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈𝑈)
𝑚𝑚
𝑗𝑗=1
Where: 
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𝑽𝑽𝑽𝑽𝑽𝑽 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬 =  The total sum of VOCs emitted to ambient air from all process 
tool operations 
𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪 = Mass of VOC emissions generated from the “i”th source of 
process tool operations which is routed to a control device 
designed to destroy VOC 
𝑪𝑪𝑪𝑪 = Overall capture and control efficiency of VOC for the specific 
control device which the “i”th source of VOC emissions is routed 
to 
𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼𝑼 = Mass of VOC emissions generated from the “j”th source of 
process tool operations which is not routed to a control device 
designed to destroy VOC 
504 
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 Rule 360 and Appendix G of the MCAPCR. 
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. 
504.1 EPA-Approved Test Methods Incorporated by Reference: 
a. EPA Methods 1 (“Sample and Velocity Traverses for Stationary Sources”) and
1A (“Sample and Velocity Traverses for Stationary Sources with Small Stacks
or Ducts”) (40 CFR 60, Appendix A-1).
b. EPA Methods 2 (“Determination of Stack Gas Velocity and Volumetric Flow
Rate”), 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”), and 2D (“Measurement of Gas volumetric Flow Rates
in Small Pipes and Ducts”) (40 CFR 60, Appendix A-1).
c. EPA Methods 3 (“Gas Analysis for the Determination of Dry Molecular
Weight”), 3A (“Determination of Oxygen and Carbon Dioxide Concentrations in
Emissions From Stationary Sources (Instrumental Analyzer Procedure”), 3B
(“Gas Analysis for the Determination of Emission Rate Correction Factor or
Excess Air”), and 3C (“Determination of Carbon Dioxide, Methane, Nitrogen,
and Oxygen from Stationary Sources”) (40 CFR 60, Appendix A-2).
d. EPA Method 4 (“Determination of Moisture Content in Stack Gases”) (40 CFR
60, Appendix A-3).
e. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions by
Gas Chromatography”) (40 CFR 60, Appendix A-6).
f.
EPA Method 21 (“Determination of Volatile Organic Compounds Leaks”) (40
CFR 60, Appendix A-7).
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g. EPA Method 24 (“Determination of Volatile Matter Content, Water Content,
Density, Volume Solids, and Weight Solids of Surface Coatings”) and 24A
(“Determination of Volatile Matter Content and Density of Printing Inks and
Related Coatings”) (40 CFR 60, Appendix A-7).
h. EPA Methods 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-7).
i.
EPA Method 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).
j.
EPA Method 320 (“Measurement of Vapor Phase Organic and Inorganic
Emissions by Extractive Fourier Transform Infrared (FTIR) Spectroscopy”) (40
CFR 63, Appendix A).
504.2  EPA-Approved California Air Resources Board (CARB) Test Methods 
Incorporated by Reference: 
a. BAAQMD Method 31 (May 18, 2005), “Determination of Volatile Organic
Compounds in Paint Strippers, Solvent Cleaners, and Low Solids Coatings”.
b. SCAQMD Method 313-91 (February 1997), “Determination of Volatile Organic
Compounds (VOC) by Gas Chromatography/Mass Spectrometry (GC/MS)”.
504.3 EPA-Approved American Society for Testing and Materials (ASTM) Standard 
Incorporated by Reference: 
a. ASTM D6348-12e1, “Standard Test Method for Determination of Gaseous
Compounds by Extractive Direct Interface Fourier Transform Infrared (FTIR)
Spectroscopy”.
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1 
MARICOPA COUNTY BOARD OF HEALTH 
MEETING MINUTES 
Monday, April 24, 2023, at 3:00 PM 
4041 N. Central Ave. 
Floor 14 
Phoenix, Az 85012 
President MacMillan called the meeting to order at 3:02 p.m. 
ROLL CALL:        
Members Present:       
Debra Baldauff  
Don Cassano 
(virtual) 
Joanne Osborne 
Matthew Farber 
Paul Stander (virtual) 
Robert MacMillan  
Ex-Officio: Marcy Flanagan 
Members Absent: 
Supervisor Bill Gates 
Paula Banahan        
1.
CALL TO ORDER - 3:02pm
President MacMillan 
A. Roll Call
B. Call to the Public
Ms. Sampler informed all that there were no requests known to speak. 
DISCUSSION/ACTION ITEMS: 
2.
Elections
President MacMillan 
President MacMillan asked the board for a motion for the continuation of elections, moving the agenda item to 
the next board of health meeting adding that a review and amendments to the bylaws were needed. 
Motioned to approve moving the elections to the next board meeting and adding the bylaws as an agenda 
item. 
•
Motion - Mr. Cassano
•
Seconded - Ms. Baldauff
•
Motion passed unanimously
Return to list of attachments
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2 
3.
The appointment of Joanne Osborne 
 
 
 
 
 
Marcy Flanagan
The Board of Supervisors accepted the resignation of Kristen Acton from the Board of Health, representing
Supervisorial District 4. The resignation is effective as of February 2, 2023.
The Board of Supervisors approved the appointment of Joanne Osborne to the Board of Health,
representing Supervisorial District 4. The term of service will be from Board approval through December 31,
2023, completing the term of resigning Kristen Acton. (C-06-23-547-X-00).
4.
Approval of Minutes
President MacMillan 
•
Approval of the January 23, 2023 - Board of Health minutes
o
Motioned – Ms. Baldauff
o
Second – Mr. Cassano
o
Motion passed unanimously
5.
Public Health Finance
Scot Pitcairn 
A. 3rd Quarter Update – Fiscal Year 2023 Budget Status Report
B. Make a recommendation to the Board of Supervisors to approve the Public Health Fiscal
Year 2024 Budget Request as recommended by the Maricopa County Budget Office
Mr. Pitcairn’s report is based on revenues and expenditures as of 3rd quarter of Fiscal Year 2023 through March 
31, 2023, for the funds listed below. Public Health is also asking the Board of Health to make a recommendation 
to the Board of Supervisors to approve the Public Health Fiscal Year 2024 Budget Request Recommendation as 
proposed the Maricopa County Budget Office. The finance memo is attached to the agenda outlining all funds 
reported.  
•
Fund 100 – General Fund
•
Fund 265 –Public Health Fee Fund
•
Fund 293 – Justice Reinvestment Fund
•
Fund 296 – State & Local Recovery Funds/American Rescue Plan Act (ARPA)
o
COVID-19 American Rescue Plan Act Funds | Maricopa County, AZ.
•
Fund 297- Opioid Settlement Fund
•
Fund 532 - Grant Fund
Mr. Pitcairn extended a brief explanation of some funds to the members of the board. The agenda provides an 
outline of all funds for Public Health updates. 
A recommendation to approve Public Health Services FY24 Recommended Budget as proposed by the County 
Budget Office to the Board of Supervisors. 
A recommendation was made by - Ms. Osborne 
•
Seconded - Ms. Baldauff
•
All were in favor of the recommendation
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3 
6.
Environmental Services
Sylvie Donaldson 
A. 3rd Quarter Update – Fiscal Year 2023 Budget Status Report
B. Make a recommendation to the Board of Supervisors to approve the Environmental
Services Department (ESD) Fiscal Year 2024 Budget Request as recommended by the
Maricopa County Budget Office
Ms. Donaldson’s reported on ESD Budget Status as of Quarter 3 close for Fiscal Year FY23, for the funds listed 
below. ESD is also asking the Board of Health to make a recommendation to the Board of Supervisors to approve 
Environmental Services Department Fiscal Year 2024 Budget Recommendation as proposed by the Maricopa 
County Budget Office. The finance memo is attached to the agenda outlining all the funds reported.  
•
Fund 100 - County General Fund
•
Fund 290 – Environmental Tire Fund
•
Fund 506 – Environmental Fee Fund
Ms. Donaldson extended a brief explanation of some funds to the members of the board. There were no 
additional questions for any of the funds reported.  
A recommendation to approve Environmental Services Department FY24 Recommended Budget as proposed 
by the County Budget Office to the Board of Supervisors. 
•
A recommendation was made by - Ms. Baldauff
•
Seconded - Dr. Farber
•
All were in favor of the recommendation
7. Environmental Services Dept. Fee Waiver Applications –
Robert Stratman 
Request for Board of Health approval of twenty-two (22) fee waiver applicants
This quarter, the department reviewed twenty-two (22) fee waiver applications. Of the applications reviewed, 
staff determined that all meet the criteria outlined in the Maricopa County Environmental Health Code.  
As a reminder, only an operator of a charitable nonprofit establishment that operates to provide relief 
predominantly for the poor, distrgessed, or underprivileged may apply to the Board of Health for a waiver of a 
permit fee. A waiver of a permit fee may be granted only to the operator of an establishment that maintains a 
current 501(c)(3) tax-exempt designation from the Internal Revenue Service and who demonstrates to the Board 
of Health that payment of said fee will cause financial hardship.  
Applications for waivers of Temporary Food Establishment fees will be processed on a first come, first served 
basis in accordance with Chapter I, Regulation 5 a. of the Environmental Health Code. The Department shall only 
present a maximum of twenty-five (25) of such applications per event to the Board of Health. 
In addition, a waiver of fees associated with the administering and issuance of a food employee certificate (in 
compliance with A.R.S. § 41-1080) may be granted to a current student enrolled in a K-12 culinary arts school 
program or similar curriculum-based programs requiring food employee certificates. The sponsoring school 
district must demonstrate to the Board of Health that payment of said fee will cause financial hardship.  
Again, all fee waiver applications reviewed this quarter appear to meet the criteria. 
ESD provided a brief explanation regarding vendors at events and the fee waiver process adding that they 
receive approximately 150-200 permits annually. The Board had no additional questions, therefore, Mr. 
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4 
Stratman requested that the board approve the applications on the Fee Waiver Application Summary Sheet 
labeled P1 through P20; C1, and C2. 
Approval of the Fee Waiver Application Summary Sheet labeled P1 through P20; C1 and C2. 
•
Motioned – Dr. Baldauff
•
Second – Dr. Farber
•
Motion passed unanimously
8.
Air Quality Department
Greg Verkamp  
Kimberly Butler 
Mr. Verkamp and Ms. Butler appeared requesting approval of three rules. 
Approve expedited process rulemaking for the following rule: 
A. AQ-2022-006   Rule 100 (General Provisions and Definitions)
The U.S. Environmental Protection Agency (EPA) recently requested the Maricopa County Air Quality
Department (MCAQD) submit a Title V Program revision for approval. As part of the program revision
submittal, the EPA requested MCAQD make a limited number of revisions to Rule 100. The purpose of this
rulemaking is to make only the necessary revisions to the rule to address the EPA requests along with some
minor clarifications so the revised rule can be submitted to the EPA as part of the Title V program revision.
Air Quality conducted one stakeholder workshop in March and has not received any comments from
Stakeholders pertaining to Rule 100; therefore, the request is that the Board approve expedited process
rulemaking for AQ-2022-006.
Motion to approve the Expedited Process Rulemaking for Rule 100 (General Provisions and Definitions)
AQ-2022-006
•
Motioned – Dr. Farber
•
Second – Dr. Baldauff
•
Motion passed unanimously
Approve initiation of regulatory change for the following rules: 
B. AQ-2023-002 Rule 326 (Steelmaking Operations)
MCAQD is proposing a new rule, Rule 326, to implement reasonably available control technology (RACT)
controls to limit the discharge of volatile organic compound (VOC) and nitrogen oxide (NOx) emissions from
steelmaking operations. Upon adoption of the new rule, MCAQD will submit it as a revision to the Arizona
State Implementation Plan.
One Stakeholder workshop was conducted for both rules 326 and 338. Each rule requires their own motion
to be carried out.
Motion to approve the Initiation of Regulatory change for Rule 326 (Steelmaking Operations)
AQ-2023-002
•
Motioned – Dr. Baldauff
•
Second – Ms. Osborne
•
Motion passed unanimously
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5 
C.
AQ-2023-004 Rule 338 (Semiconductor Manufacturing)
MCAQD is proposing to revise Rule 338 to implement RACT level controls that will regulate NOx emissions
generated during the semiconductor manufacturing process. These controls are already incorporated in
most air quality permits for semiconductor manufacturing facilities in Maricopa County. In addition, MCAQD
will review the VOC controls in the rule and ensure the controls continue to implement RACT. Upon
adoption of the revised rule, MCAQD will submit it as a revision to the Arizona State Implementation Plan.
Motion to approve the Initiation of Regulatory change for Rule 338 (Semiconductor Manufacturing) AQ-
2023-004
•
Motioned – Dr. Baldauff
•
Second – Ms. Osborne
•
Motion passed unanimously
9.
Environmental Services Dept.  – Swimming Pool Advisory Committee Update
Gregory Epperson and 
Blanca Caballero 
Mr. Epperson provided the board with a brief update as it’s outlined in the Maricopa County’s 
Environmental Health Code, Chapter VI, Section 1, Regulation 13c.1(b). This is a discussion item, not an 
action item. Refer to MCESDs memo in the agenda. The Maricopa County Environmental Services 
Department (MCESD) consulted with the county’s counsel.  
The MCEHC requires SPAC members to be appointed by the Board of Health Chairperson (President) for a 
term of three (3) years. The SPAC consists of five members, who are residents of Maricopa County and 
citizens of the United States, and is composed of and consisting of a representative of the industries, 
trades, and professions as follows:   
1.
Swimming Pool Building Contractor
2.
Swimming Pool Service and Repair Contractor or Swimming Pool Industry Member
3.
Certified Safety Professional
4.
Professional Engineer
5.
Health Professional
MCESD requests the Board of Health Chairperson’s approval to appoint new committee members to the 
Swimming Pool Industry Member, Certified Safety Professional, and Health Professional categories for 
three years.  MCESD will be requesting the appointments by the Board of Health Chairperson (President) 
following this meeting via a memo with completed applications from the perspective members outlining 
their credentials and will request that President MacMillian appoint the new committee members to the 
Certified Safety Professional swimming pool, industry member and health professional categories for a 
term of three years as well as renew the terms of the swimming pool contractor for a term of one year 
and the professional engineer for a term of two years. 
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6 
Discussion Items 
10. Public Health Report
Marcy Flanagan 
A.
Human Resources
B.
Communications
C.
Infrastructure
D. Strategic Planning
E.
Programs
F.
Disease Update
G. Health Status/Community Health Needs Assessment (CHNA)
H. Heat Report
I.
Future Topic
J.
Covid Status Update
K.
C auris
Serena Bailey 
Dr. Flanagan advised the board that she would be focusing on two updates Covid and C auris for Public Health 
that she intends to share with the board of Supervisors and Executive Session in a couple of weeks. Serena 
Bailey is one of the Public Health Epidemiologists who will talk about C auris in more detail.  
A presentation slide was provided of the National COVID-19 case count to date, discussing the peak that 
occurred in late 2021 and early 2022 (Omicron variant). Dr. Flanagan reminded the board of the three waves 
Maricopa County experienced over the last 3 years. Before there was a vaccine, then things closed, then 
masking, and businesses begin to open again. Since then, nationally we had the Omicron variant and the 
Bivalent variant. Maricopa County Community transmission level is being reported as low, the Emergency Public 
Health declaration goes away on May 11. Overall declaration, President Biden ended that about a month ago 
which is separate from Public Health’s declaration, we can expect changes with free access to testing, 
treatment, vaccines, and in reporting as a result. Updates will be on Public Health’s webpage, but the 
community transmission will no longer be showing, and no more up to date recommendations for vaccines.  
Public Health for information. Diseases-We-Track 
C auris Update 
Serena Bailey presented an update on C auris (Candida auris). The CDC reports that it is a deadly fungal infection 
spreading at an alarming rate on the skin that can cause an infection and illness. A graph was displayed 
displaying the risk factors for developing the clinical disease. Public Health is currently providing the community 
with prevention methods and education, by screening, colonization screening, and identifying patients that 
identify with this disease. Take home points were shared with the board which lead to a brief discussion.  
The disease is very difficult to treat and typically affects VERY sick people with many medical conditions. C. auris 
does not pose a significant public health threat to most people in the community. Maricopa County Public 
Health will continue to monitor the disease. 
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7 
Announcements and Current Events 
President/ 
Board Members 
Board of Health member, Vice President Scott Celley passed away on Feb. 22, 2023. Scott was diagnosed with a 
Neurological disorder in late December 2022. A memorial Service was held in March, flowers were sent on 
behalf of all.  Mr. Celley was appointed by the Board of Supervisors in July 2019, serving almost 4 years on the 
Board of Health. Condolences were offered to his wife and family; his service on this board was much 
appreciated and he will certainly be missed. 
Maricopa County staff announcements 
•
Jen Pokorski – County Manager (formerly Assistant County Manager)
•
Darcy Kober – Assistant County Manager (formerly Director of Environmental Services Dept.)
•
Blanca Caballero – Executive Director, Environmental Services Dept. (formerly Deputy Director)
Adjournment  
President MacMillan 
There being no further business the meeting was adjourned at 4:47pm. 
•
Ms. Baldauff made a motion to adjourn the meeting,
•
seconded by Mr. Cassano
•
The motion passed unanimously.
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NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special 
parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
BOARD OF HEALTH MEETING AGENDA 
July 22, 2024 | 3:00-5:00 pm 
4041 N. Central Avenue, 14th Floor, Phoenix, AZ 
Legal Advice - A.R.S. §38-431.03(A)(3) 
The Board may vote to go into Executive Session for the purpose of discussion or consultation for legal advice with the 
attorney or attorneys of the Board on any matter listed on the agenda pursuant to A.R.S. §38-431.03 (A)(3). Members of 
the Board of Health will attend either in person or by telephone conference call. Members attending telephonically will 
be announced at the meeting. Agendas are available within 24 hours of each meeting in the Public Health 
Administration office at 4041 N. Central Ave., 14th floor, Monday through Friday between 8:00 a.m. and 5:00 p.m. 
ITEM 
TOPIC/ACTION 
TYPE 
PRESENTER 
1. 
Call to Order 
A. Roll Call
Members Present: Debra Baldauff, Matthew Farber, Cynthia Hardy,
Veronica Oros, Joanne Osborne, Lorenzo Sierra, Stefanie Schroder
Absent members: Supervisor Bill Gates, Robert MacMillan, Mary
Schraven
A quorum of (6) members was confirmed.
B. Call to the Public: There were no requests to speak.
Action 
President 
Osborne 
2. 
Approval of Minutes 
President Osborne asked the Board for a motion to approve the April 
22, 2024 minutes. 
•
Motion: Stefanie Schroder
•
Second: Cynthia Hardy
Motion status: Approved unanimously 
Discuss/ 
Action 
President 
Osborne 
3. 
Bylaws 
Request the Board of Health for a vote of support and concurrence to 
move the updated Bylaws to the Board of Supervisors (BOS) for 
approval 
President Osborne asked the Board for a motion to approve the 
current bylaws. 
•
Motion: Stefanie Schroder
•
Second: Cynthia Hardy
Motion status: Approved unanimously 
Discuss/ 
Action 
President 
Osborne 
  4. 
Acknowledgment of Officers 
Acknowledge the term of current officers through July 2025 
Discuss/ 
Action 
President 
Osborne 
Return to list of attachments
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NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special 
parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
President Osborne stated that herself, Joanne Osborne, will remain 
as President and Robert MacMillan will remain as Vice President until 
next voting session in July 2025. 
5. 
Executive Committee 
Nominate a physician member as the 3rd member of the executive 
committee. 
 
President Osborne nominated Dr. Matthew Farber. 
Discuss/ 
Action 
President 
Osborne 
6. 
Environmental Services Dept. Fee Waiver Applications 
Request the Board of Health approve fifteen (15) waiver applications 
 
This quarter, we reviewed fifteen (15) fee waiver applications. Of the 
applications reviewed, staff determined that all meet the criteria 
outlined in the Maricopa County Environmental Health Code.  
 
As a reminder, only an operator of a charitable nonprofit 
establishment which operates to provide relief predominantly for the 
poor, distressed, or underprivileged may apply to the Board of Health 
for a waiver of a permit fee. A waiver of a permit fee may be granted 
only to the operator of an establishment, which maintains a current 
501(c)(3) tax-exempt designation from the Internal Revenue Service 
and who demonstrates to the Board of Health that payment of said 
fee will cause financial hardship. 
 
Applications for waivers of Temporary Food Establishment fees will 
be processed on a first come, first served basis in accordance with 
Chapter I, Regulation 5 a. of the Environmental Health Code. The 
Department shall only present a maximum of twenty-five (25) of such 
applications per event to the Board of Health. 
 
In addition, a waiver of fees associated with the administering and 
issuance of a food employee certificate (in compliance with A.R.S. § 
41-1080) may be granted to the operator of an establishment which 
maintains a current 501(c)(3) tax-exempt designation from the 
Internal Revenue Service or to a current student enrolled in a K-12 
culinary arts school program or similar curriculum-based program 
requiring food employee certificates. The organization or sponsoring 
school district must demonstrate to the Board of Health that payment 
of said fee will cause financial hardship.  
 
Again, all fee waiver applications reviewed this quarter appear to 
meet the criteria.  
Discuss/ 
Action 
Robert 
Stratman 
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accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
 
I am happy to answer questions or if the Board has no questions, I 
respectfully request approval of the applications on the Fee Waiver 
Application Summary Sheet labeled P1 through P14 and C1. 
 
President Osborne asked the Board for a motion to approve the fee 
waiver applications. 
• 
Motion: Debra Bauldauff 
• 
Second: Stefanie Schroder 
Motion status: Approved unanimously 
 
7. 
Air Quality Department  
 
A. Air Quality Overview 
President Osborne asked if Maricopa County looks at the health of 
the residents every 5 years. 
Philip McNeely responded that the EPA reviews data every 5 years at 
a national level, not city or county level. 
 
President Osborne asked what our smart devices are really telling us 
when we receive notifications regarding the air. 
Philip McNeely responded that the notifications are basically telling 
us April through September the ozone is being affected more and try 
to stay indoors as much as possible. October through March the 
notifications are regarding the PM (particle matter) 2.5 levels (smoke 
and soot).  
 
President Osborne asked if there is a new air pollutant standard is 
coming. 
Philip McNeely responded the EPA is currently re-evaluating the 
2015 ozone standard and could lower it or keep it the same. 
 
President Osborne asked for clarification of the lack of submission of 
the SIP (State Implement Plan) regarding Ozone NAAQS because they 
couldn’t find a model that would move the needle.  
Philip McNeely responded that MAG did not submit the SIP because 
they have to conduct air modelling to show EPA that the region will 
meet the 70 ppb ozone standard at the monitors.  Currently, their 
model does not show that so they did not submit the SIP.  We need 
more scientific data from EPA to determine how to reduce the ozone 
concentrations. 
Discuss/ 
Action 
Philip 
McNeely 
 
Gregory 
Verkamp &  
Kimberly 
Butler 
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parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
 
President Osborne asked if the chip manufacturing falls into any of 
the current rules being presented today.  
Philip McNeely responded that one of the rules being presented 
today was to reduce VOC and NOX at chip manufacturers. 
 
President Osborne asked if a lot of the new manufactures will have 
to keep in alignment with the new rules being presented today. 
Philip McNeely responded that yes but good news is RACT is only 
Reasonable Available Controlled Technology and Intel uses a higher 
standard. They have to comply with current standards. 
 
B. Approve expedited rulemaking process for the following 
rule: 
 
AQ-2024-008 
Rule 203 (Emission Reduction Credit (ERC) General 
Requirements) 
 
The Maricopa County Air Quality Department (MCAQD) is proposing 
to create Rule 203 in an effort to consolidate general ERC 
requirements into one rule. In addition, MCAQD is proposing to 
include the application and certification provisions for ERCs created 
through traditional (permitted) sources in Rule 203. 
 
President Osborne asked the Board for a motion to approve Rule 203 
(Emission Reduction Credit (ERC) General Requirements) 
• 
Motion: Dr. Matthew Farber 
• 
Second: Debra Bauldauff 
Motion status: Approved unanimously 
 
 
C. Make a recommendation to the Board of Supervisors to 
approve the creation of the following rule: 
 
AQ-2023-002 
Rule 326 (Steelmaking Operations: Electric Arc Furnaces) 
 
MCAQD is proposing a new rule to implement reasonably available 
control technology (RACT) controls to limit the discharge of volatile 
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NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special 
parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
organic compound and nitrogen oxide emissions from steelmaking 
operations using electric arc furnaces.  
 
President Osborne asked the Board for a motion to approve Rule 326 
(Steelmaking Operations: Electric Arc Furnaces) 
 
• 
Motion: Stefanie Schroder 
• 
Second: Cynthia Hardy 
Motion status: Approved unanimously 
 
 
D. Make a recommendation to the Board of Supervisors to 
approve the proposed revisions of the following rules: 
 
AQ-2022-004 
Rule 330 (Volatile Organic Compounds) 
 
MCAQD is proposing to revise Rule 330 to clarify the applicability of 
the rule and update and restructure the rule.  
 
AQ-2023-003 
Rule 331 (Solvent Cleaning) 
 
MCAQD is proposing to revise Rule 331 to remove a RACT deficiency 
identified by the U.S. Environmental Protection Agency so Rule 331 
can be approved into the Arizona State Implementation Plan as 
meeting RACT. 
 
 
AQ-2023-004 
Rule 338 (Semiconductor Manufacturing) 
 
MCAQD is proposing to revise Rule 338 to incorporate RACT controls 
for nitrogen oxide emissions generated during the semiconductor 
manufacturing process. In addition, MCAQD is proposing to revise 
some of the volatile organic compound controls in the rule to ensure 
the controls continue to implement RACT. 
 
President Osborne asked the Board for a motion to approve AQ-
2022-004, Rule 330 (Volatile Organic Compounds), AQ-2023-003 
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NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special 
parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
Rule 331 (Solvent Cleaning), and AQ-2023-004 Rule 338 
(Semiconductor Manufacturing). 
 
• 
Motion: Debra Bauldauff 
• 
Second: Stefanie Schroder 
Motion status: Approved unanimously 
 
8. 
Public Health Updates 
 
A. 2024 Arizona Legislative Session Summary and Budget 
Overview  
Lorenzo Sierra asked what percentage of the overall funds are 
represented. 
Kellie MacDonald-Evoy responded that it’s approximately 1 billion 
Jeanene Fowler also responded that all cities and counties in the 
state sign the Want Arizona Agreement which determines how money 
can be used. 
 
Lorenzo Sierra requested website information on Opioid Settlement 
funds be sent to him. (An email with the link was sent to the Board Members on 
Tuesday, July 23, 2024.) 
 
B. Tobacco Update 
President Osborne asked when new data on the Arizona Youth Risk 
Behavior Survey will be released. 
Michael Wydra responded the information will be available 
September 2024. 
 
President Osborne asked for clarification of age to purchase 
cigarettes. 
Michael Wydra confirmed the age is 21. 
 
President Osborne asked if vapes are taxed same as cigarettes. 
Michael Wydra responded they are not, but the topic would have to 
go back to legislature in order to be included.  
 
President Osborne asked if there is anything Maricopa county can do 
to find more or better solutions for prevention and/or cessation. 
Michael Wydra responded to just keep working on getting the word 
out as much as possible.  
 
Discuss 
 
Jeanene 
Fowler  
 
Kellie 
MacDonald-
Evoy  
 
Michael 
Wydra 
 
 
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NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special 
parking arrangements, and other accommodations are available with 72 hours advance notice. If you require 
accommodations to participate in the above meeting, please contact Nicole Harden at the Public Health 
Administration Department. (480) 281-8374. 
President Osborne requested an agenda item be added to the next 
meeting to add an update from Tobacco after data is received in 
September 2024. 
9. 
Adjournment: 
President Osborne asked for a motion to adjourn meeting.  
• 
Motion to adjourn: Mary Schraven 
• 
Second: Stefanie Schroder 
• 
The meeting adjourned at 5:02 pm 
Motion status: Approved unanimously 
 
Action 
President 
Osborne 
 
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1
From:
Mike Sherer <msherer@trinityconsultants.com>
Sent:
Tuesday, April 11, 2023 4:01 PM
To:
Hannah Luke (AQD)
Cc:
Todd Martin (AQD); Anthony Damitio; Disha Gadre
Subject:
RE: Additional Item for MCAQD Rule 338 Call 
Thanks! 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, April 11, 2023 9:17 AM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Todd Martin (AQD) <Todd.Martin@maricopa.gov>; Anthony Damitio <Anthony.Damitio@trinityconsultants.com>; 
Disha Gadre <dgadre@trinityconsultants.com> 
Subject: RE: Additional Item for MCAQD Rule 338 Call  
Hi Mike, 
Thank you for sending me this informaƟon. I will be sure to add this to the list of topics to discuss for the work group 
meeƟng next week. Should you have any further topics, feel free to send them my way.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
Copies of all written and electronic Stakeholder input
Return to list of attachments
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2
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Tuesday, April 11, 2023 8:55 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Todd Martin (AQD) <Todd.Martin@maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com>; Anthony 
Damitio <Anthony.Damitio@trinityconsultants.com>; Disha Gadre <dgadre@trinityconsultants.com> 
Subject: Additional Item for MCAQD Rule 338 Call  
Hi Hannah. Have received some comments about Rule 338 SecƟon 301 that will be a large 
issue regarding process tools that use acids, bases and VOCs that are exhausted to non-VOC 
ECS and there is no longer capture/control efficiency allowed as now that fabs have designed 
for. The definiƟon of ECS requires only using VOC control we believe. This includes some 
process tools that have exisƟng and future POU abatement units and exhausted to wet 
scrubbers. Can we please add below for POU abatement unit discussion next week? Thanks, 
Mike. 
CONTROL OF VOC EMISSIONS FROM SEMICONDUCTOR 
MANUFACTURING OPERATIONS: An owner or operator of a semiconductor
manufacturing operation that annually emits more than 25 tons of VOCs from 
aggregated photoresist and process tool operations, prior to any emissions 
controls, shall maintain such operations under negative pressure per Section 
503.3, route captured air to an approved emission control system (ECS), and 
meet one of the following requirements: 
Draft Rule 338 Page 8 
301.1 Reduce the inlet concentration of VOCs to the ECS by at least 90% by 
weight or; 
301.2 Achieve an outlet concentration less than or equal to 10 ppmv VOC 
concentration measured as methane, as determined by applicable 
provisions in Section 503. 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
A picture containing drawing
Description automatically generated
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com  
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
CAUTION: This email originated from outside of the Trinity Consultants organization. Do not click links or open attachments unless 
you recognize the sender's name, sender's email address and know the content is safe. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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1
From:
Hana De Leon <hana.deleon@nxp.com>
Sent:
Tuesday, May 16, 2023 10:35 AM
To:
Hannah Luke (AQD); Kimberly Butler (AQD); Gregory Verkamp (AQD)
Cc:
Peggy Felice; Stephen Wagner; Mike Sherer
Subject:
RE: [EXT] Draft Rule 338 with Work Group Edits
Hello Hannah, 
Thank you for incorporating our feedback into the draft rule. 
As for the suggested language in Section 301 we recommend the following clarifications: 

CONTROL OF PHOTORESIST VOC EMISSIONS FROM SEMICONDUCTOR MANUFACTURING OPERATIONS: An
owner or operator of a semiconductor manufacturing operaƟon that annually emits more than 25 tons of VOCs
from aggregated photoresist and process tool operaƟons that solely emit VOCs,  prior to any emissions controls,
shall maintain such operaƟons under negaƟve pressure per SecƟon 503.3 route captured air to  an approved
emission control system (ECS), and meet one of the following requirements:
301.1 
Achieve at least 90% overall VOC capture and control of aggregated photoresist and 
process tool operaƟons that solely emit VOCs, determined by applicable provisions in SecƟon 
503.3; or  
301.2 
Route captured air to an approved emission control system (ECS) and achieve an outlet 
concentraƟon less than or equal to 10 ppmv VOC concentraƟon measured as propane, as 
determined by applicable provisions in SecƟon 503 
In addition, we suggest the following changes to the draft rule: 

SecƟon 401: The Ɵmeframe for achieving compliance is unclear. NXP will be installing a new VOC abatement
that is already included in our permit equipment list as future and thus it will not require a minor modificaƟon.
We are not sure if this qualifies as a new installaƟon. If the new installaƟon didn’t require a permit applicaƟon it
would be clear that this is a new installaƟon. Perhaps the proposed secƟon 401.1 could be changed to:
a.
Within 18 months of becoming subject to the ECS requirements in SecƟon 301 of this rule, submit a
compliance schedule and permit applicaƟon (or noƟficaƟon in lieu of permit applicaƟon if already
permiƩed as future abatement) to the Control Officer.
b.
Within 36 months of final permit issuance (or noƟficaƟon in lieu of permit issuance if already permiƩed
as future abatement), be fully compliant with the ECS requirements in SecƟon 301 of this rule and
submit to the Control Officer a complete source test report indicaƟng compliance.

SecƟon 209:
o
SOLVENT: Any liquid or vapor which is used to dissolve, clean, strip, or remove impuriƟes, coaƟngs,
contaminants, or films from surfaces or from internal spaces and voids. This includes, but is not limited
to, developers and stripping agents. In addiƟon to VOC-containing solvents, this also includes plain
water  and mixtures containing water.

SecƟon 304.4:
o
Good CombusƟon PracƟces for POU Devices: Operate and maintain equipment in accordance with the
manufacturer’s wriƩen instrucƟons for good combusƟon pracƟces.

SecƟon 305.1:
o
Replace “operaƟon” with “operator” in ECS Requirements: An owner or operaƟon operator of an
emission control system (ECS) at a semiconductor manufacturing facility shall …
o
305.1 a. – Add hydrogen as an opƟon for fuel: Only use natural gas, butane, hydrogen or propane as
fuel.

SecƟon 501.4 b.:
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2
o
Good CombusƟon PracƟces: Maintain records of all maintenance and calibraƟon acƟviƟes related to
POU devices maintenance acƟviƟes related to good combusƟon pracƟces of the POU devices.

SecƟon 502.3: Suggest this change:
o
For each day or period the O&M Plan requires maintenance, the owner or operator shall make a
permanent record of the maintenance acƟons taken within 24 hours of the maintenance compleƟon.
Thank you 
Hana De Leon and Peggy Felice 
NXP Semiconductors  
1300 N. Alma School Road 
Chandler, AZ, 85224   
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, May 4, 2023 1:45 PM 
To: Michael.Aire@microchip.com; michael.mathis@jasolar.us; Peggy Felice <peggy.felice@nxp.com>; 
msherer@trinityconsultants.com; Tom.Ekren@asu.edu; leila.kabiri-badr@intel.com; gary.r.doria@intel.com; 
joyjones@tsmc.com; sandoval@tsmc.com; Hana De Leon <hana.deleon@nxp.com> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] Draft Rule 338 with Work Group Edits 
Good afternoon, 
Since our first draft Rule 338 work group meeting held on 4/18, we have been working internally to incorporate 
feedback into the draft rule. Attached please find the draft rule with changes in red. I would like to get your thoughts on 
the suggested language in Section 301 clarifying process tool operations that solely emit VOCs. If any other questions 
come up when reviewing the draft rule, please let me know.  
I will be sending out another doodle poll shortly to schedule our next meeting to discuss feedback. Thank you for your 
help during this process and I look forward to meeting soon! 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
Caution: This is an external email. Please take care when clicking links or opening attachments. When in doubt, 
report the message using the 'Report this email' button  
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1
From:
Cooper, Sarah <sarah.cooper@intel.com>
Sent:
Friday, June 9, 2023 4:31 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Aldrich, Sean D; Mutolo, Kristin L; D'Oria, Gary R; Kabiri-badr, Leila; Dupuy, 
Francesca; Mccurry, Craig
Subject:
RE: Draft Rule 338
Attachments:
Draft Rule 338_Intel Comments.pdf
Hi Hannah, 
Please see attached for Intel’s comments on draft Rule 338, and thank you for the opportunity to participate in the 
stakeholder process.  Have a great weekend!  
Thanks,  
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, May 24, 2023 2:10 PM 
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Aldrich, Sean D <sean.d.aldrich@intel.com>; Mutolo, 
Kristin L <kristin.l.mutolo@intel.com>; Cooper, Sarah <sarah.cooper@intel.com>; D'Oria, Gary R 
<gary.r.doria@intel.com>; Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Dupuy, Francesca 
<francesca.dupuy@intel.com> 
Subject: RE: Draft Rule 338 
Hi Craig, 
Thank you for the heads up. Once I receive your comments on the draft rule, we can schedule another meeting to go 
over them.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Wednesday, May 24, 2023 2:02 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Aldrich, Sean D <sean.d.aldrich@intel.com>; Mutolo, 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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2
Kristin L <kristin.l.mutolo@intel.com>; Cooper, Sarah <sarah.cooper@intel.com>; D'Oria, Gary R 
<gary.r.doria@intel.com>; Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Dupuy, Francesca 
<francesca.dupuy@intel.com> 
Subject: RE: Draft Rule 338 
Hannah, just wanted to give you a heads up.  Intel does have some comments on the latest version of the Draft Rule but 
have not had enough time to craft a unified response.  We can send you our comments by the end of next week.  But we 
do know we will at least have comments on the definition of a POU, Good combustion practices, and related 
recordkeeping.  We have about 1000 of these POU units with hundreds more getting added this year so the definition is 
clearly something that needs to be worked through as well as the recordkeeping requirements. 
Thanks, Craig 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, May 23, 2023 11:04 AM 
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Draft Rule 338 
Sounds good. Gary Doria and Leila Kabiri-Badr have been participants on this work group, but I will be sure to include 
you on any further correspondence.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Tuesday, May 23, 2023 10:44 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Draft Rule 338 
Thanks for the update Hannah.  Please make sure Intel is on the invite list for any Rule 338 revision meetings with 
outside stakeholders.   
Thanks, Craig 
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3
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, May 23, 2023 10:39 AM 
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Draft Rule 338 
Okay great, I will forward you the invitation. Attached is the most current version of the draft rule with recent changes in 
red, as well as the meeting agenda with proposed revisions from stakeholders (highlighted).  
If possible, please send me a list of items you would like to discuss tomorrow so we can begin working on solutions 
internally.  
See you tomorrow. 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Tuesday, May 23, 2023 10:35 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Draft Rule 338 
Yes please.  We have some comments we would like to share. 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, May 23, 2023 6:29 AM 
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Draft Rule 338 
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4
Hi Craig, 
The second workshop is not scheduled yet. We have been working with the work group to edit the draft rule with 
stakeholder feedback. The next work group meeting is scheduled for tomorrow at 3pm via Teams. Would you like me to 
send you an invitation?  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Friday, May 19, 2023 3:48 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Subject: Draft Rule 338 
Hannah, I was just wondering when the next workshop will be for Draft Rule 338.  We have some feedback from our two 
sites. 
Thanks, Craig 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
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June 9, 2023 
Hannah Luke 
Senior Planner 
Maricopa County Air Quality Department 
301 W. Jefferson St., Suite 410 
Phoenix, AZ 85003 
Dear Ms. Hannah Luke,  
As a stakeholder, Intel Corporation appreciates the opportunity to review and comment on Draft Rule 
338. Our comments are below.
DRAFT RULE 338 COMMENTS 
Section 207:  POINT-OF-USE (POU) DEVICE 
Intel proposes the following definition of POU device, consistent with the November 27, 1995 United 
States Environmental Protection Agency (USEPA) letter to Tim Mohin (EPA Letter, Attachment 1), 
Maricopa County Environmental Services Department, Air Quality Division’s June 4, 2001 Optional 
Compliance Demonstrations Guidance (MCAQD Guidance, Attachment 2), and the scope of Rule 338:  
Section 207 proposed language: 
POINT-OF-USE DEVICE: A device that is installed in close proximity to process equipment, is a source 
of combustion which generates NOx, and is installed for the primary purpose of abating regulated 
air pollutants. 
Justification: 
The current draft definition of POU device seeks to expand upon the historical definition of POU in the 
USEPA Letter and MCAQD Guidance document referenced above by including equipment installed for 
safety and industrial hygiene purposes.  
Equipment installed for safety and/or industrial hygiene purposes are part of the process tool and are 
not air pollution control devices; they are defined as exhaust conditioners, not POUs, and are 
‘considered by the EPA to be inherent to the process’. The EPA Letter provides ‘Criteria for Determining 
Whether Equipment is Air Pollution Control Equipment or Process Equipment’ and lists three questions 
to consider when making the determination: 
1.
Is the primary purpose of the equipment to control air pollution?
a.
No, the primary purpose of the equipment is for safety and/or industrial hygiene.
2.
Where the equipment is recovering product, how do the cost savings from the product recovery
compare to the cost of the equipment?
a.
Not applicable.
3.
Would the equipment be installed if no air quality regulations are in place?
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a.
Yes. The equipment installed for safety and/or industrial hygiene purposes is only one
part of the process tool and is a required part regardless of air quality regulations. The
equipment is interlocked with the process chambers, therefore the process cannot
operate unless the equipment is in use.
Additionally, MCAQD’s Guidance, defines POUs as being ‘installed in close proximity to the process 
equipment and is installed for the purpose of abating regulated pollutants’. The definition also states, 
‘Normally, a POU is not interlocked with the associated process equipment.’ The equipment installed 
for safety and/or industrial hygiene purposes does not meet the definition of POU because it is not 
installed for the purpose of abating regulated pollutants, and it is interlocked with the process chamber. 
Instead, MCAQD’s Guidance defines the equipment in question as exhaust conditioners because they 
‘are used for safety and/or industrial hygiene purposes and are always interlocked to the process 
equipment’. 
The current draft definition of POU device, if left unchanged, would encompass over one thousand 
pieces of equipment at the Intel Ocotillo facility (soon to be ~1,500 with the startup of Fabs 52 and 62).  
While Intel understands this is an ozone RACT rule which would include NOx emissions, the manner in 
which this draft Rule 338 seeks to do so presents a significant burden.  The resources that would be 
required to track the POUs as currently defined and comply with the draft recordkeeping requirements 
on more than 1,500 pieces of equipment would be immense, and as Rule 338 is intended to satisfy 
RACT requirements, cost and practicality must be considered.  Further, the emissions from the 
equipment in question are exhausted to downstream emission sources which are regulated for NOx and 
VOCs in our facility Permit.  These Fab Emission points are subject to routine performance testing to 
demonstrate compliance with existing Permit limits.   
In summary, exclusion of equipment installed for safety and industrial hygiene purposes from the POU 
device definition, as was the historical approach by both the EPA and MCAQD, in conjunction with the 
proposed revisions to the subsequent sections highlighted below would make the requirements of this 
revised Rule more practically executable from the industry perspective.   
Section 304.3: Monitoring Devices 
Intel requests that Section 304.3 be revised to the following: 
Monitoring Devices: For the ECS, provide, properly install and maintain in calibration, in good 
working order, and in operation, devices for indicating or recording temperatures, pressures, rates of 
flow, concentrations or other operating parameters required by the O&M Plan for determining if air 
pollution control equipment or other means of control are functioning properly. 
Justification: 
This aligns with the VOC abatement equipment requirements described in other parts of this revised 
Rule. 
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Section 304.4: POU Devices 
Intel requests that Section 304.4 be revised to the following: 
Operate and maintain equipment in accordance with the manufacturer’s or operator’s written 
instructions for good combustion practices. 
Justification: 
Intel’s New Source Review permit, approved by EPA and MCAQD in August 2021, required the facility to 
complete a LAER determination.  In the LAER determination, LAER of wet acid scrubbers was essentially 
equated to LAER of POUs since all of the NOx emitted from the wet scrubbers is from the POUs.   The 
approved LAER determination stated the following:  
“Section 2.3: NOx LAER for Fab 52 and 62 Wet Scrubbers: 
Fab Wet Scrubbers: Good Combustion Practices and maintaining POUs per Intel Specifications” 
Based on the above, and because this was a LAER determination, Intel believes that following operator 
or manufacturer good combustion practices satisfies the RACT requirements.  
Section 501.4 POU Device Recordkeeping: 
Intel requests that section 501.4 be revised to the following: 
a.
Operations and Maintenance:  Maintain the manufacturer’s or operator’s recommended
written instructions to minimize facility NOx and available to the Control Officer upon
request.
b.
Good Combustion Practices: Maintain records of activities performed to demonstrate good
combustion practices for POU devices.
Justification: 
There is no basis for stating that Preventative Maintenance (PM) performed on a POU device would 
lower NOx emissions.  The POU units were designed to achieve the highest destruction efficiency of the 
target pollutant(s), but typically, this would not be NOx.  Even changing recommended settings on a 
POU unit during a combustion-related PM could cause NOx emissions to be higher if any of the 
following parameters are adjusted: 

Natural gas flow rate;

Temperature;

Air/Fuel ratio; and/or

The amount of nitrogen-containing compounds used in the manufacturing process.
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Attachment 1 
November 27, 1995 United States Environmental Protection Agency (USEPA) letter to 
Tim Mohin 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 
RESEARCH TRIANGLE PARK. NC 27711 
OFFICE OF 
AIR QUALITY PLANNING 
AND STANDARDS 
NOV 27 1995 
Mr. Timothy J. Mohin 
Government Affairs Manager 
Environment, Health and Safety 
Intel Government Affairs 
888 17th Street Northwest, #860 
Washington, DC 20006-3939 
Dear Mr. Mohin: 
Thank you for the additional information you provided 
regarding the exhaust conditioners used in tool operations in the 
semiconductor industry. We agree with your assessment that, for 
potential to emit calculations, the exhaust conditioners should 
be considered as an inherent part of the process. 
Criteria for Determining Whether Equipment is Air Pollution 
Control Equipment or Process Equipment 
For purposes of determining a source's potential to emit, it 
is necessary to calculate the effect of air pollution control 
equipment. Current Environmental Protection Agency (EPA) 
regulations and policy allow air pollution control equipment to 
be taken into account if federally enforceable requirements are 
in place requiring the use of such air pollution control 
equipment. There are, however, situations for which case-by-case 
judgements are needed regarding whether a given device or 
strategy should be considered as air pollution control equipment, 
or as an inherent part of the process. The EPA believes that the 
following list of questions should be considered in making such 
case-by-case judgements as to whether certain devices or 
practices should be treated as pollution controls or an inherent 
to the process:. 
1.
Is the primary purpose of the equipment to control air
pollution?
2.
Where the equipment is recovering product, how do the
cost savings from the product recovery compare to the
cost of the equipment?
3.
Would the equipment be installed if no air quality
regulations are in place?
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2 
If the answers to these questions suggest that equipment 
should be considered as an inherent part of the process, then the 
effect of the equipment or practices can be taken into account in 
calculating potential emissions regardless of whether enforceable 
limitations are in effect. 
Analysis of the criteria for the semiconductor tools listed 
No information supplied to date by Intel suggests that 
product recovery by the exhaust conditioners is significant. That 
EPA believes that the first and third criteria are satisfied. 
Criteria 1. The exhaust conditioners described in your letter are 
small treatment systems that are local to the point-of-use of 
process tools such as etching and deposition processes. The 
primary purposes are to: (1) increase the uptime of the process 
tools, (2) to minimize safety hazards, and (3) to prevent 
impurities from entering other processes. 
Criteria 3. The information you have provided suggests strongly 
that air quality regulations are not the driving factor for 
installation of the equipment. Moreover, the fact that they are 
"interlocked” with the process chambers suggests that the process 
cannot operate unless the exhaust conditioner is in use. 
Therefore, based upon a review of the information presented 
the exhaust conditioners are considered by the EPA to be inherent 
to the process and can be considered in potential emission 
calculations without federally enforceable requirements. 
Cautions 
The above determination regarding the use of the localized 
exhaust conditioners in the semiconductor industry is case- 
specific. This determination is not intended to set a precedent 
for localized pollution control equipment for other source types 
without a similar case-specific review. 
While many types of point-of-use and interlocked treatment 
device may be considered as "inherent,” there does exist, of 
course, air pollution control equipment at semiconductor 
facilities that may not meet the above criteria. For example, a 
remote water scrubber located at the roof of a building would 
generally be considered an air pollution control device. 
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3 
If you have any further questions regarding this matter, 
please call Timothy Smith at (919) 541-4718, or Tony Wayne at 
(919) 541-5439.
sincerely, 
David Solomon 
Acting Group Leader 
Integrated Implementation Group 
cc: 
Chief, Air Branch, Regions I-X 
Regional PTE Contacts 
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Attachment 2 
Maricopa County Environmental Services Department, Air Quality Division’s June 4, 
2001 Optional Compliance Demonstrations Guidance 
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ENVIRONMENTAL SERVICES DEPARTMENT
AIR QUALITY DIVISION
1001 North Central Avenue, Phoenix, AZ 85004
(602) 506-6094
(602) 506-6985 (FAX)
OPTIONAL COMPLIANCE DEMONSTRATIONS
A GUIDELINE
FOR
SEMICONDUCTOR INDUSTRY
PART II, Procedure to Determine Requirement
for Operation and Maintenance Plan
Point of Use/Exhaust Conditioner Units
June 4, 2001
GENERAL
For point of use (POU) devices or exhaust conditioner (EC) units, the source shall follow the procedures
outlined below to make a determination whether the subject POU or EC would be required to:
•
Submit an Operation and Maintenance Plan (O&M Plan), or
•
Demonstrate Adequate Maintenance and Calibration (AMC), or
•
Conduct an Air Dispersion Modeling / Risk Assessment.
For the purpose of this procedure, the following definitions are provided as follows:
1. Definition: Exhaust Conditioner (EC)
In semiconductor manufacturing, a number of different process tools are used to perform the various
operations needed to make the final product.  Some of these tools contain devices inherent to the
equipment which treat or condition, the exhaust gases as they leave the process chamber.  There are a
variety of such exhaust conditioners used, but the primary intents are the same in all cases:
•
The exhaust conditioners remove solids from the exhaust stream, which prevents them from
deposition later in the exhaust duct.  Since downstream exhaust problems can actually impact the
manufacturing process, these devices improve process quality and reliability.
•
Use of these conditioners improves equipment uptime.  Without the exhaust conditioner, process
exhaust pumps will eventually fail.
•
Removal of the solids reduces the amount of system maintenance needed and avoids safety hazards
related to blocked exhaust ducts.
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Maricopa County Department of Environmental Services, Air Quality Division, Optional Compliance Demonstrations
Procedure, Part II, Procedure to determine requirement for O&M Plan
06/04/2001
2
•
Exhaust Conditioners (EC) are used for safety and/or industrial hygiene purposes, and are always
interlocked to the process equipment and/or feed materials.
2. Definition:  Point of Use (POU) Control Device
•
A Point of Use (POU) Control Device is installed in close proximity to the process equipment and is
installed for the purpose of abating regulated pollutants.
•
Normally, a POU is not interlocked with the associated process equipment.
3. Definition:  Adequate Maintenance and Calibration (AMC)
MCESD will accept “Adequate Maintenance and Calibration (AMC)” for a source with records to
demonstrate that the process and/or abatement instrumentation (which include at least the sensoring
devices that trigger the interlock shutdown system) has been properly maintained and calibrated per
manufacturer’s recommendations, or at least once a year per a written maintenance and calibration
program commonly adopted by the semiconductor industry, whichever is more stringent. The records
along with the maintenance and calibration program shall be available onsite upon inspection.
4. Definition: Regulated Air Pollutant (RAP)
RAP is any compound as defined in MCESD Rule 100, Section 200.90,
SPECIFIC REQUIREMENTS
1. No “Regulated Air Pollutants” (RAP) are involved
There will be no O&M Plan or AMC requirement for any POU or EC unit that controls non-RAP.
2. POU unit that is interlocked (shutdown) to the appropriate process equipment or EC unit
This is the case when an emission reduction is claimed.
•
An O&M Plan is not required in this case.  However, the demonstration of AMC on selected POU or
EC units must be presented.  This requirement may be addressed in the permit as part of the
conditions.  MCESD will review the final selection of EC or POU units to determine permitting
requirements.  For example, MCESD may require an AMC demonstration such as maintenance
records (e.g. when a sensor is calibrated or changed) for an arsine hydride gas EC.
•
The grouping of EC or POU units is allowed for the purpose of streamlining the AMC demonstration.
See Example below.
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Maricopa County Department of Environmental Services, Air Quality Division, Optional Compliance Demonstrations
Procedure, Part II, Procedure to determine requirement for O&M Plan
06/04/2001
3
Sample AMC for Exhaust Conditioners
Exhaust
Conditioner
Interlock Triggering
Parameter
Measuring Device
  a
PM/Calibration
Frequency
Wet Scrubber
Water Recirculation
Rate,
or Make-up Water
Rate
Flowmeter, Rotameter
Monthly
Oxidizer
Oxidation Chamber
Temperature
Thermocouple
Replaced Every Six Months
b
Cold Bed
(Adsorber/
Chemisorber)
Breakthrough Sensor
Electrochemical Cell,
Colorimetric Paper, FTIR
Cell, Conductivity Probe
Replaced Every Six Months
b
Hot Chemical Bed
Breakthrough Sensor
Electrochemical Cell,
Colorimetric Paper, FTIR
Cell, Conductivity Probe
Replaced Every Six Months
b
Reactor Systems
Power
Wattmeter, Drantz Meter
Varies
c
Particulate
Removal
Pressure Drop
Magnehelic, Photohelic
Varies
c
a These only represent examples and other monitoring devices could be used.
b Based on manufacturer’s recommendations.
c To be discussed during MCESD/Permittee meeting.
3. POU unit that is without an interlock shutdown system
When an emission reduction is claimed, an O&M Plan is required. A sample O&M Plan is attached as
Attachment 1 for reference.
4. The source claims no emission reduction
This is a case for a POU or an EC unit with or without an interlock system.  There will be no requirement
for an O&M Plan or AMC.
Modeling/risk assessment will be done at the point(s) of discharge to the atmosphere only. Modeling /risk
assessment shall demonstrate no exceedance of AAAQG threshold (May 11, 1999 version).  If the
subject constituent is not listed in AAAQG, threshold values from other states or air quality districts will be
accepted.  Threshold values of VOC from an area with an equal or more stringent non-attainment
classification are preferred.
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1
From:
Mccurry, Craig <craig.mccurry@intel.com>
Sent:
Wednesday, July 19, 2023 4:07 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Kimberly Butler (AQD)
Subject:
RE: Proposed Rule 338 Draft Comments
Here is our draft proposed revision to Rule 338. 
We can walk through the specifics tomorrow.   
304.4. Good Combustion Practices for POU Devices: 
a. Operate and maintain equipment in accordance with the manufacturer’s or operator's written
instructions.  OR
b. On an annual basis, conduct a variability analysis of the normalized volume of natural gas consumed per
POU device.
504.1.c.  For good combustion practices demonstrated through the requirements of 304.4.b, record the results of 
the variability analysis. If the variability of natural gas usage per POU exceeds [xxx%] then perform an assessment 
and document: 
a. Changes to facility operations which accounts for the increase in natural gas usage per POU; or
b. Any actions taken to return natural gas usage per POU to within the established variability limit.
More to come tomorrow, and an update on what we still need to complete to propose a variability analysis threshold. 
-
Thanks, Craig
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Mccurry, Craig  
Sent: Monday, July 17, 2023 1:52 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: RE: Proposed Rule 338 Draft Comments 
3 PM will work.  Thanks. 
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2
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, July 17, 2023 1:50 PM 
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: RE: Proposed Rule 338 Draft Comments 
Thank you for providing the slides!  
We have a schedule conflict with 2pm on Thursday. How does 11am or 3pm work? 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Monday, July 17, 2023 11:26 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: RE: Proposed Rule 338 Draft Comments 
The slides are attached.  We have a conflict at 10PM – would 2PM work for you? 
We are still doing some research on our systems capability surrounding natural gas so let me see where we are at on 
Wed and send some language if we are confident in the output. 
But on Thursday we can discuss our reasoning and data availability. 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, July 17, 2023 8:27 AM 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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3
To: Mccurry, Craig <craig.mccurry@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: RE: Proposed Rule 338 Draft Comments 
Hi Craig, 
Yes, we are available to meet Thursday 7/20 at 10am. If that works for you, let me know and I will send out a meeting 
invitation. Are you able to send us the proposed language prior to our meeting? 
I also wanted to see if you are able to send us the slides presented during the site visit conducted on 6/30? 
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Friday, July 14, 2023 12:10 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov> 
Subject: Proposed Rule 338 Draft Comments 
Hannah do you have some time next Thursday or Friday to discuss our proposed revisions to Rule 338?   Maybe 45min-
1hr. 
Thanks, Craig 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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1
From:
Gregory Verkamp (AQD)
Sent:
Tuesday, July 25, 2023 8:20 AM
To:
Hannah Luke (AQD)
Subject:
FW: Online Form Submittal: Citizen Comments
Attachments:
RadTech Public Comments Rule 338 072423.pdf
FYI 
Greg Verkamp 
Planning Supervisor 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-7141 C: 602-206-0564
E: Gregory.Verkamp@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Michele Ross (COA) <Michele.Ross@maricopa.gov>  
Sent: Tuesday, July 25, 2023 8:01 AM 
To: Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Will Adrian (AQD) <William.Adrian@maricopa.gov>; 
Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: FW: Online Form Submittal: Citizen Comments 
Hello, 
Please see citizen comment below and attachment. 
Thank you, 
Michele Ross 
Program Manager 
County Manager’s Office 
O: 602-506-0583 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: noreply@civicplus.com <noreply@civicplus.com>  
Sent: Monday, July 24, 2023 7:35 PM 
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (HSD) <Kathy.Semder@Maricopa.Gov>; Andy 
Linton (ENV) <Andy.Linton@Maricopa.Gov>; Bill Leal (DOT) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (PND) 
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov>; Michele Ross (COA) 
<Michele.Ross@maricopa.gov> 
Subject: Online Form Submittal: Citizen Comments 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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2
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-2023-004-Rule 338 (Semiconductor Manufacturing) 
Department 
Air Quality 
I would like to  
Express opposition 
First Name 
Rita 
Last Name 
Loof 
Organization 
RadTech International 
City 
Bethesda 
Zip 
Field not completed. 
Email 
rita@radtech.org 
Phone Number 
9092400866 
Phone Type 
Mobile 
Would you like someone to 
contact you? 
Yes 
Comments 
RadTech is opposed to the proposed changes to Rule 338 as 
detailed in the attached public comment letter. 
If applicable, attach 
supporting documentation 
associated with your 
comment. The only file 
types supported are MS 
Office and Adobe Acrobat. 
RadTech Public Comments Rule 338 072423.pdf
Email not displaying correctly? View it in your browser.  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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The Honorable Board of Health 
Maricopa County  
July 24th, 2023 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 338—Semiconductor 
Manufacturing—OPPOSE unless Amended  
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 338 –
Semiconductor Manufacturing. 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 including semiconductor 
manufacturing.  
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, they are 
specifically formulated to react to energy (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/LED 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. 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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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 Rule Language Changes 
According to the staff report, the Maricopa County Air Quality Department (MCAQD) is 
proposing to revise Rule 338 to incorporate Reasonably Available Control Technology (RACT) 
level controls that will regulate emissions generated during the semiconductor manufacturing 
process.  In addition, MCAQD will review the VOC controls in Rule 338 and ensure the controls 
implement RACT.  We are concerned that the proposed changes to Rule 338 do not take into 
consideration pollution prevention processes such as UV/EB/LED. RadTech believes that Rule 
338 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.  In its current form, Rule 338 seems to focus on Emission 
Control Systems (ECS) as the only means of compliance.  The one sided approach, unfairly 
excludes pollution prevention technologies such as UV/EB/LED and puts our businesses at 
disadvantage as compared to systems using conventional solvents with ECS.  Thus, our 
organization cannot support the rule in its current form. 
Section 103.2-- Exemptions 
Our materials are typically well below 50 grams/liter in VOC content.  The rule groups materials 
ranging from 2 grams per liter to 100 grams per liter.  We would suggest an intermediate VCO 
content of 50 grams per liter and respectfully request that UV/EB/LED materials with a VOC 
content of 50 grams per liter or less be exempted from 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.   
Section 200-- Definitions 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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The rule narrowly focuses the definitions section on ECS.  This approach does not take into 
consideration other technologies and may have the unintended consequence of giving a certain 
process an unfair competitive advantage.  The rule should be technology neutral and include 
definitions for all available technologies. 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.  
Section 503—Compliance Determination 
This Section is especially problematic because Rule 338 does not specify a test method for 
energy curable materials in Section 504.  The current rule language states: 
“When more than one test method is permitted for a determination, an exceedance of the limits 
established in this rule determined by any of the applicable test methods constitutes a violation of 
this rule.” 
The lack of clarity as related to acceptable test methods may put out the businesses we represent 
at risk of enforcement action by Maricopa County.  We ask that Section 504 be clarified to 
include test methods for UV/EB/LED (see comments on Section 504). 
Section 504--Test Methods 
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. 
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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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1
From:
Cooper, Sarah <sarah.cooper@intel.com>
Sent:
Monday, July 31, 2023 2:28 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Kimberly Butler (AQD); Mutolo, Kristin L; Mccurry, Craig; Aldrich, Sean D
Subject:
Rule 338 Proposed Language
Attachments:
Proposed Rule 338 Language.docx
Good Afternoon,  
Per our last call, please find our updated language proposal for Rule 338.  Talk with you later on this week. 
Thanks,  
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
133 of 200

Proposed Rule 338 Language 
OPERATING REQUIREMENTS 
… 
304.4. Good Combustion Practices for POU Devices: 
a. Operate and maintain equipment in accordance with the manufacturer’s or operator's
written instructions, or
b. On an annual basis, conduct a variability analysis of the normalized volume of natural gas usage
per POU device per day as outlined by Sections 304.4.b.i through 304.4.b.iv.
i.
Establish and record the facility's normalized baseline natural gas usage per POU device
per day using the quantity of installed POU devices and the associated natural gas
design specifications or manufacturer's recommendations.
ii.
On an annual basis, determine and record the facility's normalized natural gas usage per
POU per day using actual natural gas usage data for a single month and the quantity of
installed POU devices for that same month. Calculate and record the percent change
between the baseline and annual natural gas usage per POU per day.  If the variability of
natural gas usage per POU exceeds [xx%], perform an assessment and record:
1. Changes to facility operations which account for the increase in
normalized natural gas usage per POU per day; or
2. Any actions taken to return the normalized natural gas usage per POU
per day to within the established variability limit.
iii.
The initial baseline shall be established within 6 months of adoption of this Rule revision
and the first variability analysis performed within 1 year of adoption of this Rule
revision.
iv.
A new baseline shall be established and recorded every 5 years or when the variability
analysis exceeds the threshold set forth Section 304.4.b.ii and the increase in natural gas
usage per POU device per day is accounted for by changes to facility operations,
whichever comes first.
MONITORING AND RECORDS 
… 
501.4.c.  For good combustion practices demonstrated in accordance with Section 304.4.b, the 
Permittee shall maintain a record of the data required to perform the variability analysis and any 
subsequent assessments as required by Section 304.4.b.ii.  The records shall be kept on site and made 
available to the Control Office upon request. 
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1
From:
Cooper, Sarah <sarah.cooper@intel.com>
Sent:
Monday, August 28, 2023 2:23 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Kimberly Butler (AQD); Mutolo, Kristin L; Mccurry, Craig; Aldrich, Sean D; 
Todd Martin (AQD); Ryan Dalrymple (AQD); D'Oria, Gary R; Kabiri-badr, Leila
Subject:
RE: Rule 338 Proposed Language
Attachments:
Good Combustion Plan.pdf
Good Afternoon,  
Please see attached for our proposed Good Combustion Plan to satisfy the draft Rule 338 language that we discussed in 
our last meeting.  We also have the following two comments on the proposed Rule language:  
304.4.b.(3) A list and description of all good combustion maintenance practices and/or NOx emission monitoring 
methods. 
501.4.b  Good Combustion Plan: Maintain a Good Combustion Plan as required in Section 304.4(b). The plan must be 
updated annually to contain current information. Any change from to the plan shall be documented. 
Thanks,  
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
From: Cooper, Sarah  
Sent: Wednesday, August 16, 2023 3:28 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov>; Mutolo, Kristin L <kristin.l.mutolo@intel.com>; Mccurry, Craig 
<craig.mccurry@intel.com>; Aldrich, Sean D <sean.d.aldrich@intel.com>; Todd Martin (AQD) 
<Todd.Martin@maricopa.gov>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov>; D'Oria, Gary R 
<gary.r.doria@intel.com>; Kabiri-badr, Leila <leila.kabiri-badr@intel.com> 
Subject: RE: Rule 338 Proposed Language 
Good Afternoon,  
In preparation for tomorrow’s meeting, please find the following attached files: 

Intel’s initial comments on the draft Rule 338 (submitted 6/9/32)

Intel’s proposed Rule 338 language for an alternative compliance method, complete with a variability threshold
and additional supporting information

Sample calculations and formulas for the baseline value and variability threshold calculations
Looking forward to speaking with you all. 
Thanks,  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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2
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, July 31, 2023 3:30 PM 
To: Cooper, Sarah <sarah.cooper@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov>; Mutolo, Kristin L <kristin.l.mutolo@intel.com>; Mccurry, Craig 
<craig.mccurry@intel.com>; Aldrich, Sean D <sean.d.aldrich@intel.com> 
Subject: RE: Rule 338 Proposed Language 
Thank you for providing the proposed language. We will review internally and discuss further on Thursday. 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Cooper, Sarah <sarah.cooper@intel.com>  
Sent: Monday, July 31, 2023 2:28 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kimberly Butler (AQD) 
<Kimberly.Butler@Maricopa.gov>; Mutolo, Kristin L <kristin.l.mutolo@intel.com>; Mccurry, Craig 
<craig.mccurry@intel.com>; Aldrich, Sean D <sean.d.aldrich@intel.com> 
Subject: Rule 338 Proposed Language 
Good Afternoon,  
Per our last call, please find our updated language proposal for Rule 338.  Talk with you later on this week. 
Thanks,  
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
136 of 200

Page 1 of 3 
Good Combustion Plan for POU 
Combustion Devices 
Intel Corporation – Ocotillo Facility 
4500 S. Dobson Road 
Chandler, AZ 85248 
Facility ID: F000701 
Revision Date: August 2023 (Rev. 1)
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Good Combustion Plan for POU Combustion Devices 
Intel Ocotillo Facility  
Chandler, Arizona 
1. Summary of POU Combustion Devices Installed
Intel Corporation’s (Intel) Ocotillo Facility (Facility ID F000701), located at 4500 South Dobson Road in 
Chandler, Arizona, operates under a Title V Permit issued by Maricopa County Air Quality Department 
(MCAQD). Intel operates POU combustion devices to support its manufacturing operations and has prepared 
this Good Combustion Plan to satisfy the requirements of MCAQD Rule 338.   Table 1-1 below provides a 
summary of the installed POU combustion devices which are subject to MCAQD Rule 338.  
Table 1.1 - POU Combustion Devices 
POU 
Manufacturer  
POU Model 
Quantity  
Centrotherm
K4
200+
Ebara 
G5
70+
G6E
40+
G7
2+
Edwards 
iAtlas
550+
Legacy Helios 
5+ 
Legacy TCS 
10+ 
Legacy TPU 
50+ 
2. Maintenance Practices
Intel performs routine preventative maintenance (PM) on the POU combustion devices listed in Section 1 
above to ensure the equipment operates in accordance with good combustion practices.  The preventative 
maintenance is performed on the POU combustion devices at least annually.  For the purposes of this Good 
Combustion Plan, annual means no less frequently than 425 days from the previous maintenance event (365 
days + 60 days, consistent with manufacturers recommendations).  At a minimum, preventative maintenance 
performed annually for Centrotherm, Ebara, and Edwards POU devices includes verification and/or resetting 
of operational parameters to manufacturers recommended specifications. 
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Good Combustion Plan for POU Combustion Devices 
Intel Ocotillo Facility  
Chandler, Arizona 
3. Response to POU Combustion Device Malfunctions/Failures
For Intel’s POU combustion devices, a safety interlock is in place which isolates natural gas flow at the 
upstream valve manifold box in the event of a malfunction or failure of the burner/combustion components 
of the device.  Natural gas flow to the POU combustion device does not resume until corrective maintenance 
has been performed and the operational parameters returned to manufacturers recommended 
specifications.   
4. Revision History
Rev 
Rev Date 
Owner 
Rev Reason 
1.0 
August 2023 
Sarah Cooper/Kristin Mutolo 
Initial plan publication 
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Page 1 of 3 
Good Combustion Plan 
Intel Corporation – Ocotillo Facility 
4500 S. Dobson Road 
Chandler, AZ 85248 
Facility ID: F000701 
Revision Date: August 2023 (Rev. 1)
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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Good Combustion Plan 
Intel Ocotillo Facility  
Chandler, Arizona 
1. Summary of POU Combustion Devices Installed
Intel Corporation’s (Intel) Ocotillo Facility (Facility ID F000701), located at 4500 South Dobson Road in 
Chandler, Arizona, operates under a Title V Permit issued by Maricopa County Air Quality Department 
(MCAQD). Intel operates POU combustion devices to support its manufacturing operations and has prepared 
this Good Combustion Plan to satisfy the requirements of MCAQD Rule 338.   Table 1-1 below provides a 
summary of the installed POU combustion devices which are subject to MCAQD Rule 338.  
Table 1.1 - POU Combustion Devices 
POU 
Manufacturer  
POU Model 
Quantity  
Centrotherm
K4
200+
Ebara 
G5
70+
G6E
40+
G7
2+
Edwards 
iAtlas
550+
Legacy Helios 
5+ 
Legacy TCS 
10+ 
Legacy TPU 
50+ 
2. Maintenance Practices
Intel performs routine preventative maintenance (PM) on the POU combustion devices listed in Section 1 
above to ensure the equipment operates in accordance with good combustion practices.  The prevenative 
maintenance is performed on the POU combustion devices at least annually.  For the purposes of this Good 
Combustion Plan, annual means no less frequently than 425 days from the previous maintenance event (365 
days + 60 days, consistent with manufacturers recommendations).  At a minimum, preventative maintenance 
performed annually for Centrotherm, Ebara, and Edwards POU devices includes verification and/or resetting 
of operational parameters to manufacturers recommended specifications. 
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Good Combustion Plan 
Intel Ocotillo Facility  
Chandler, Arizona 
3. Revision History
Rev 
Rev Date 
Owner 
Rev Reason 
1.0 
August 2023 
Sarah Cooper/Kristin Mutolo 
Initial plan publication 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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1
From:
Hana De Leon <hana.deleon@nxp.com>
Sent:
Thursday, October 12, 2023 11:54 AM
To:
Hannah Luke (AQD); Kimberly Butler (AQD); Gregory Verkamp (AQD)
Cc:
Peggy Felice
Subject:
RE: [EXT] MCAQD Draft Rule 338 Update
Thank you 
Hana 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, October 11, 2023 3:41 PM 
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com>; Stephen Wagner <stephen.wagner@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Update 
Hi Hana, 
I apologize for the delayed response to your comments on Rule 338. We have been reviewing your feedback internally in 
anƟcipaƟon of talking about them during the work group meeƟng next Tuesday. In the event we are unable to address 
all the items below, we can set up a separate meeƟng aŌerwards to discuss further. I look forward to seeing you all next 
week.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Monday, October 2, 2023 12:23 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com>; Stephen Wagner <stephen.wagner@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Update 
Caution: This is an external email. Please take care when clicking links or opening attachments. When in doubt, 
report the message using the 'Report this email' button  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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2
Hello Hannah, 
NXP does not object to removing the corrosive VOC excepƟon as long as addiƟonal clarificaƟons are made in secƟon 
301.  

We propose the following revision to the final statement in secƟon 301.
Any VOC emissions not controlled per Section 301.1 or 301.2 shall be assumed to have evaporated
onsite unless records show that VOC-containing material was sent offsite for legal disposal. Records of 
legal disposal include but are not limited to shipping papers or quantity discharged to sewage 
treatment works. 

In addiƟon, please add to secƟon 301 the following language which was originally in secƟon 502.3 “Emission
factors acceptable to the Control Officer are allowed to be used in calculating VOC emissions.”
Organic silicon compounds are not suitable to be abated by VOC abatement systems typically used by the 
semiconductor industry.  The excepƟon for organic silicon compounds allows for excepƟon of up to one ton per year.  At 
NXP, the organic silicon compound material used is hexamethyldisilazane (HMDS). When treated by a thermal oxidizer, 
this material deposits silicon dioxide in the oxidizer and adversely affects the operaƟon of the ECS. This excepƟon allows 
for beƩer operaƟon of the ECS by diverƟng the HMDS to the house water scrubbers.  As the Title V thresholds for VOC 
decrease and the overall capture and control requirements increase, this excepƟon will become more and more 
important. 
Upon further review of the latest version of the draŌ rule we have idenƟfied a couple of other clarificaƟons/changes 
that we would like you to consider as part of the rule changes.  
1.
We would like to ask about this statement in secƟon 301.2: “… achieve an outlet concentration less than or
equal to 10 ppmv VOC concentration measured as propane”. Since in our current air permit it is stated: “ …
outlet concentraƟon of less than or equal to 10 ppmv measured as methane”, we are wondering if this change
(from methane to propane) is intenƟonal. We believe it is not difficult to measure VOC concentraƟon as propane
or methane. We just want to make sure this change is intenƟonal.
2.
Modify the language in secƟon 303.3 to:  Convey VOC-containing materials from one location to another in
closed containers or pipes or convey to sewage treatment works.
As part of the wastewater permit compliance sampling, sites are required to have open flume sampling locaƟons 
that allow for collecƟon of a composite samples of wastewater discharge. As the wastewater passes through the 
flume, it is not in a closed pipe.  
3.
Modify secƟon 304.4 b. (3) to: A list and description of good combustion maintenance practices and/or
NOx emission monitoring methods and;
4.
Modify the new secƟon 501.3 to:  Records of Disposal: Maintain records of the type, amount, and method of
disposing of VOC-containing materials on each day of disposal.
The NXP air permit currently requires monthly tracking of VOC disposal records. Shipping records are kept for 
each day material is shipped. For materials that are discharged to sewage treatment works, disposal esƟmates 
are made based on monthly usage records and emission factors acceptable to the Control Officer.  
5.
Modify secƟon 501.4 a. (2) to: Records of any malfunctions and corrective actions, if necessary that could 
result in an increase of combustion emissions.
6.
Modify secƟon 501.4 b. to: Good Combustion Plan: Maintain a Good Combustion Plan as required in
Section 304.4(b). The plan must be updated when needed annually to contain current information. Any
change to the plan shall be documented.  If there is no change needed, annual update seems unnecessary.  
Thank you 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, September 20, 2023 11:39 AM 
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To: Hana De Leon <hana.deleon@nxp.com> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov>; Peggy Felice <peggy.felice@nxp.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Update 
Hi Hana, 
Thank you for the informaƟon. Since the Quality Control and R&D exempƟon is also included in the SIP Rule 338, we 
don’t anƟcipate the need to remove that exempƟon. In the event we are required to remove both exempƟons for 
corrosive VOCs and silicon compounds, can you provide some informaƟon on how that would impact operaƟons for 
NXP? We are hoping to gather some informaƟon when we discuss with the EPA. 
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Wednesday, September 20, 2023 8:07 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov>; Peggy Felice <peggy.felice@nxp.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Update 
Hello Hannah, 
NXP is currently uƟlizing exempƟons 103.1 (Quality Control and R&D OperaƟons), 103.4 (Corrosive VOC) and 103.5 
(Organic Silicon Compounds).  
If we could keep only two of the exempƟons we would like to keep the Quality Control and R&D OperaƟons and Organic 
Silicon Compounds exempƟons. 
Thank you 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, September 18, 2023 9:53 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] MCAQD Draft Rule 338 Update 
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Good morning,  
Since our last meeƟng on May 24th, we have been working with stakeholders and the EPA on the draŌ rule in 
anƟcipaƟon of a second workshop. Before we set up a third work group meeƟng, I would like to get some feedback 
regarding a certain topic.  
The EPA has menƟoned a potenƟal approvability issue regarding the exempƟons currently in Rule 338 and reflected in 
the draŌ rule (see aƩached). Specifically, there are more exempƟons in the draŌ version of the rule than are in the SIP-
approved version of Rule 338 (also aƩached for your review). This could create a relaxaƟon of the SIP and may 
jeopardize revised Rule 338 from being approved by the EPA if the exempƟons remain.  
Please review the aƩached exempƟons and let me know if you are uƟlizing any of them as we are considering removing 
them to ensure approval by the EPA.  
Also, we plan on sending an updated version of the draŌ rule out before the end of the month in anƟcipaƟon of our 
third work group meeƟng. I look forward to meeƟng with you all soon to discuss the changes to draŌ Rule 338.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
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From:
Mike Sherer <msherer@trinityconsultants.com>
Sent:
Monday, October 16, 2023 2:56 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD)
Subject:
RE: Rule 338 Questions
Thanks! 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
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Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, October 16, 2023 2:47 PM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 338 Questions 
Hi Mike, 
Yes I am geƫng ready to send out an updated version. I’m going to aƩach it to the calendar invitaƟon for the meeƟng 
tomorrow. You will get noƟfied shortly.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Monday, October 16, 2023 2:15 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: Rule 338 Questions 
Hi Hannah. Will there be a new draŌ based on recent changes for draŌ Rule 338 for call this 
Wednesday? 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
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Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.  
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, October 12, 2023 8:13 AM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 338 Questions 
Hi Mike, 
Just a couple of updates. We have decided to remove SecƟon 501.2(c) since the exempƟon is proposed to be removed. 
Regarding your quesƟon about SecƟon 503.2, we are working on this one with our performance tesƟng team to confirm 
whether we can add Methods 25A and B to this secƟon. I should have an answer on this one by Monday. Please let me 
know if you have any other quesƟons.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Monday, October 9, 2023 5:06 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 338 Questions 
Thanks! 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
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From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, October 9, 2023 9:23 AM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 338 Questions 
No, the same parameters will be listed under SecƟon 502.1. Here is what the proposed language would look like: 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
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E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Monday, October 9, 2023 9:18 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Mike Sherer <msherer@trinityconsultants.com> 
Subject: RE: Rule 338 Questions 
Thanks! Are you saying that these parameters will be removed and only what is proposed in 
O&M Plan will be tracked for cpompliance? 
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
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From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, October 9, 2023 8:51 AM 
To: Mike Sherer <msherer@trinityconsultants.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 338 Questions 
Hi Mike,  
Thank you for the feedback. Here are my iniƟal thoughts: 
#1: I will want to talk to Greg about this one before providing an answer. He is out of the office unƟl Wednesday, so I will 
get back to you on this one.  
#2: This has been brought to my aƩenƟon for my other rulemakings (R330, 331) and should’ve been updated in R338 as 
well. I will update the draŌ rule.  
The proposed language for 502.1 will read something along the lines of “On each day a required ECS is used at a facility 
pursuant to this rule, the owner or operator shall make a permanent record of the key system operaƟng parameters as 
required by the O&M Plan which may include the following, when applicable” 
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#3: I don’t see a reason to not include 25A and 25B in SecƟon 503.2. I will discuss with Greg when he gets back and let 
you know.  
I will touch base with you in a couple of days. 
Thank you,  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com>  
Sent: Thursday, October 5, 2023 10:55 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Mike Sherer <msherer@trinityconsultants.com> 
Subject: Rule 338 Questions 
Hi Hannah. Hope you are doing well. Couple of Rule 338 quesƟons below. Thanks, Mike. 
1. Does new 501.2c apply any more as 10% VOC or less exempƟon has been removed?
2. New 502.1: the way it reads I believe is all items listed has to be done and then more
that is listed in O&M Plan. On flow rates, do not believe these need to be done daily per
EPA Methods 1 – 4 as accepted methods. Has this been discussed before?
3. New 503.2: should 25A and 25B be listed in addiƟon to 25 as approved methods later on
in rule?
Mike Sherer 
Principal Consultant 
Trinity Consultants  
1661 East Camelback Road, Suite 290  |  Phoenix, Arizona  85016 
Mitel Office:  602-837-3692  
Cell:  480-773-5548  
Email:  msherer@trinityconsultants.com    
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you recognize the sender's name, sender's email address and know the content is safe. 
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you recognize the sender's name, sender's email address and know the content is safe. 
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From:
Hannah Luke (AQD)
Sent:
Thursday, October 12, 2023 8:33 AM
To:
Mccurry, Craig
Subject:
RE: MCAQD Draft Rule 338 Update
Hi Craig,  
I just leŌ you a voicemail so we can discuss this further. Please give me a call when you get a chance. 
Thank you,  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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Customer Satisfaction Survey
From: Mccurry, Craig <craig.mccurry@intel.com>  
Sent: Thursday, October 5, 2023 2:49 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov>; Aldrich, Sean D <sean.d.aldrich@intel.com>; Cooper, Sarah 
<sarah.cooper@intel.com>; Mutolo, Kristin L <kristin.l.mutolo@intel.com> 
Subject: RE: MCAQD Draft Rule 338 Update 
Hannah, just a couple of clarificaƟons on the proposed changes to the exempƟons. 
Intel was using the exempƟons in Rule 338 
103.6  Wipe Cleaning: Wipe cleaning shall be subject to the solvent cleaning Rule 331 of the Maricopa 
County Air Pollution Control Rules and Regulations. is not subject to Section 300, but the usage of VOC-
containing solvent for wipe cleaning is subject to the recordkeeping provisions of Section 500. 
Intel did not have to apply Wipe Cleaning to any standards in SecƟon 300, but was required to the 
recordkeeping provisions of SecƟon 500 
And also: 
103.7  APPLICABILITY OF RULE 331 Solvent Cleaning for Support Operations: The solvent cleaning of 
equipment or parts that is performed for purposes other than semiconductor manufacturing shall be 
subject to the solvent cleaning Rule 331 of these Maricopa County Air Pollution Control Rules and 
Regulations. 
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2
We were using this exempƟon because we did not have any solvent cleaning of any other equipment besides 
those associated with semiconductor manufacturing. 
Will those exempƟons be wriƩen into a revised Rule 331? 
Thanks, Craig 
Craig McCurry, P.E. 
Senior Environmental Engineer 
Ocotillo EHS 
W: 480 255 9481 
C:  602 617 9110 
craig.mccurry@intel.com 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Monday, September 18, 2023 9:53 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Draft Rule 338 Update 
Good morning,  
Since our last meeƟng on May 24th, we have been working with stakeholders and the EPA on the draŌ rule in 
anƟcipaƟon of a second workshop. Before we set up a third work group meeƟng, I would like to get some feedback 
regarding a certain topic.  
The EPA has menƟoned a potenƟal approvability issue regarding the exempƟons currently in Rule 338 and reflected in 
the draŌ rule (see aƩached). Specifically, there are more exempƟons in the draŌ version of the rule than are in the SIP-
approved version of Rule 338 (also aƩached for your review). This could create a relaxaƟon of the SIP and may 
jeopardize revised Rule 338 from being approved by the EPA if the exempƟons remain.  
Please review the aƩached exempƟons and let me know if you are uƟlizing any of them as we are considering removing 
them to ensure approval by the EPA.  
Also, we plan on sending an updated version of the draŌ rule out before the end of the month in anƟcipaƟon of our 
third work group meeƟng. I look forward to meeƟng with you all soon to discuss the changes to draŌ Rule 338.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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1
From:
Cooper, Sarah <sarah.cooper@intel.com>
Sent:
Friday, October 27, 2023 3:27 PM
To:
Hannah Luke (AQD)
Cc:
Kimberly Butler (AQD); Gregory Verkamp (AQD); Mutolo, Kristin L; Mccurry, Craig; Aldrich, Sean D
Subject:
RE: MCAQD Draft Rule 338 Work Group
Hi Hannah,  
Please see below for our proposed revisions to the Rule 338 language we discussed in the last stakeholder meeƟng and 
the answers to your solvent cleaning quesƟons (in blue).  If you have any quesƟons, please let us know. 
301.3 Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be: 
a.
assumed to have evaporated onsite unless adequate records demonstraƟng otherwise can be provided to the
Control Officer, or
b.
accounted for in emissions calculaƟons as approved by the Control Officer and specified in the facility’s air
permit requirements.
501.3 Records of Disposal: FaciliƟes complying with SecƟon 301.3(a) must maintain monthly records of the type, 
amount, and method of disposing of VOC-containing materials. Records of legal disposal include but are not limited to 
shipping papers or quanƟty discharged to sewage treatment works. 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons? Wipe cleaning only, using IPA

Where are the solvent cleaning machines located (i.e., clean room, repair shop)? All are within cleanroom space

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS? None, solvent cleaning operaƟons are routed to ECS.

What cleanroom classificaƟon does your operaƟon fall under?  Class 10
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Thanks, 
Sarah Cooper 
Environmental Engineer 
Intel Ocotillo EHS 
Cell: 480.430.6265 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Sent: Thursday, October 19, 2023 8:55 AM 
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2
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Draft Rule 338 Work Group 
Good morning,  
Thank you for aƩending the third work group meeƟng held virtually on October 17th for draŌ Rule 338. Based on the 
group discussion about proposed revisions, there are two main topics that need to be addressed: draŌ rule language in 
SecƟon 301 and solvent cleaning.  
Please review the following informaƟon and provide feedback by Friday, October 27th.  
SecƟon 301 Language 
Based on the discussion regarding SecƟons 301 and 501.3, we have draŌed some language to expand on the acceptable 
records for demonstraƟng compliance with SecƟon 301. Please provide any feedback on the proposed language. 
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
adequate records demonstraƟng otherwise can be provided to the Control Officer.” 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons?

Where are the solvent cleaning machines located (i.e., clean room, repair shop)?

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS?

What cleanroom classificaƟon does your operaƟon fall under?
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Please note that I will be out of the office starting Friday, October 20th and will return Monday, October 30th. Should you 
have any questions prior to my return, please reach out to Greg Verkamp.  
Thank you for your continued participation in the rulemaking process.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
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From:
Hana De Leon <hana.deleon@nxp.com>
Sent:
Friday, October 27, 2023 10:33 AM
To:
Hannah Luke (AQD); Gregory Verkamp (AQD)
Cc:
Peggy Felice; Mike Sherer; Stephen Wagner
Subject:
RE: [EXT] MCAQD Draft Rule 338 Work Group
Hello Hannah and Greg, 
Thank you for making addiƟonal changes to the draŌ rule. As for the statement about acceptable records for 
demonstraƟng compliance with SecƟon 301, we sƟll feel that it’s important to make it clear that VOC emissions are 
allowed to be calculated based on approved emission factors. This is because emissions of some corrosive VOCs (which 
are no longer exempt from rule 338) can’t be calculated based on waste records. In our case these emissions and 
discharged amounts are based on calculaƟons. We believe that either expanding the below statement or adding the 
following language (which was originally in secƟon 502.3) “Emission factors acceptable to the Control Officer are 
allowed to be used in calculating VOC emissions.” to secƟon 301 would make this more clear.  
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
calculaƟons accepted by the control officer or adequate records demonstraƟng otherwise can be provided to the 
Control Officer.” 
In addiƟon to our earlier comments (submiƩed on 10/2) which might be already included in the latest draŌ of rule 338 
(presented in the meeƟng on 10/17 but not sent out yet), we would like to also propose a modificaƟon of the term 
“Process Tool” and “Solvent”. Upon further review of the draŌ rule and discussion with Mike Sherer we’ve realized that 
the current definiƟon of Process Tool could be interpreted as including all process tools that use VOCs. This would mean 
that even fluorinated gases like CH3F used in etch processes would fall under this rule. We believe this was not the 
intent of this rule as the statement in secƟon 503.7 refers to “other VOCs” and further down in the same secƟon 
“etchant VOC” is used as an example of the “other VOC”. 
PROCESS SOLVENT TOOL: Equipment used using solvent during the semiconductor fabrication process to 
perform various operations needed to make the final product. Some of these tools contain devices 
inherent to the equipment, which treat or condition exhaust gases as they leave the process chamber. 
SOLV   SOLVENT: Any VOC-containing liquid or vapor which is used to dissolve, clean, strip, or remove impurities, 
coatings, contaminants, or films from surfaces or from internal spaces and voids. This includes, but is 
not limited to, developers and stripping agents. This does not include organic compounds used in 
ashing, plasma etch, diffusion and chemical vapor deposition processes. 
See below for NXP response to your quesƟons. 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons? Solvent cleaning operaƟons using IPA that are far from the ECS

Where are the solvent cleaning machines located (i.e., clean room, repair shop)? Clean room

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS? Solvent cleaning operaƟons using IPA that are far from the ECS
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
What cleanroom classificaƟon does your operaƟon fall under? Equal to or more stringent than class 100,000
parƟcles/m3
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Thank you 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, October 19, 2023 8:55 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] MCAQD Draft Rule 338 Work Group 
Good morning,  
Thank you for aƩending the third work group meeƟng held virtually on October 17th for draŌ Rule 338. Based on the 
group discussion about proposed revisions, there are two main topics that need to be addressed: draŌ rule language in 
SecƟon 301 and solvent cleaning.  
Please review the following informaƟon and provide feedback by Friday, October 27th.  
SecƟon 301 Language 
Based on the discussion regarding SecƟons 301 and 501.3, we have draŌed some language to expand on the acceptable 
records for demonstraƟng compliance with SecƟon 301. Please provide any feedback on the proposed language. 
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
adequate records demonstraƟng otherwise can be provided to the Control Officer.” 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons?

Where are the solvent cleaning machines located (i.e., clean room, repair shop)?

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS?

What cleanroom classificaƟon does your operaƟon fall under?
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
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report the message using the 'Report this email' button  
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o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Please note that I will be out of the office starting Friday, October 20th and will return Monday, October 30th. Should you 
have any questions prior to my return, please reach out to Greg Verkamp.  
Thank you for your continued participation in the rulemaking process.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
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From:
Hana De Leon <hana.deleon@nxp.com>
Sent:
Tuesday, November 7, 2023 11:34 AM
To:
Hannah Luke (AQD); Gregory Verkamp (AQD)
Cc:
Peggy Felice; Mike Sherer; Stephen Wagner
Subject:
RE: MCAQD Draft Rule 338 Work Group
Hello Hannah and Greg, 
Thank you for the update on the definiƟon of Process Tool.  
For your quesƟons regarding secƟons 305-307 and the Appendix, secƟon 305 is applicable and secƟon IV of the 
Appendix (ECS Requirements) is likely applicable. As you menƟoned earlier, cleanrooms are exempt from secƟon 304 
(where ECS opƟon is specified). However, per secƟon 305, NXP would have to rely on ECS requirements of secƟon 304.2 
to be able to use non-conforming solvent in equipment other than small cleaners (defined in secƟon 308.2).  
This bring us to the first high level concern about the rule. NXP currently has an ECS regulated under Rule 338 that is 
designed for cleanroom condiƟons with very high total flow to abatement in order to maintain the cleanroom integrity. 
Prior to revisions to Rule 338, parts cleaning was covered by Rule 338 with usage and emissions aggregated for process 
and equipment parts cleaning operaƟons. NXP would like to see an alternate compliance opƟon that allows uƟlizing the 
ECS requirements in Rule 338 to demonstrate reducƟons of emissions generated during equipment parts cleaning 
covered by Rule 331. This is because Rule 331 appears to aim to keep the exhaust flows as low as possible which is not 
the case for cleanroom operaƟons. We understand that this is likely the reason for the cleanroom exempƟon from 
secƟon 304; however, NXP will likely uƟlize an ECS to demonstrate compliance with secƟons 302 and 305. We think it is 
very important that the ECS can operate with reference to one rule to ensure clarity and avoid any conflicts between 
requirements in different rules. In this case Rule 338 would be the primary rule for ECS requirements for semiconductor 
sites.  
We also looked at secƟon 501.2 (Usage Records) and found a related concern. We currently calculate VOC emissions 
from solvent cleaning based on mass balance of solvent cleaning chemicals used minus the waste shipped off site. It will 
be difficult to segregate usage only for equipment parts cleaning for the recordkeeping requirements of Rule 331. We 
would like to see the opƟon of recordkeeping kept in conjuncƟon with the Rule 338 recordkeeping requirements in lieu 
of Rule 331, secƟon 501.2.  
A final high level concern we have is implementaƟon of Rule 331 and Rule 338. Will these rules revisions be finalized at 
the same Ɵme? If not, will there be some Ɵme frame or exempƟons from compliance unƟl both rules are finalized? This 
is a wide sweeping change of Rule 338 that reassigns some semiconductor VOC cleaning operaƟons to Rule 331. Both 
rules will have to work together for this to be successful.  
This summarizes our high level concerns with uƟlizing Rule 331 to regulate equipment parts cleaning operaƟons at 
semiconductor sites. There are other specific areas of clarificaƟon that we will be addressing during Rule 331 revision. 
Thank you 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, October 31, 2023 6:23 AM 
To: Hana De Leon <hana.deleon@nxp.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com>; Mike Sherer <msherer@trinityconsultants.com>; Stephen Wagner 
<stephen.wagner@nxp.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Work Group 
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Greg and I met with Mike yesterday to discuss your proposed changes to the draŌ rule. 
We will not have an answer regarding proposed language for SecƟon 301 unƟl we speak with the EPA. While the 
language is currently in Rule 338, it is not in the SIP.  
AŌer brainstorming with Mike, I am going to draŌ language for the process tool definiƟon to address the issue 
menƟoned in your original email. I will send you an update once I’ve completed the language.  
Based on the informaƟon regarding NXP’s solvent cleaning operaƟons, you would be parƟally exempt from Rule 331. 
The main requirements you would have to comply with are the equipment and operaƟonal requirements depending on 
the type of cleaning machines being used.  
Can you please review Rule 331 starƟng at SecƟon 305 through 307, and the Appendix (which is specific to vapor 
cleaning machines), and let me know which secƟons you would have to comply with? 
Please provide informaƟon by Tuesday 11/7.  
Thank you,  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hannah Luke (AQD)  
Sent: Monday, October 30, 2023 6:34 AM 
To: Hana De Leon <hana.deleon@nxp.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com>; Mike Sherer <msherer@trinityconsultants.com>; Stephen Wagner 
<stephen.wagner@nxp.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Work Group 
Hi Hana, 
Thank you for providing feedback on draŌ Rule 338. We will begin reviewing internally and get back to you shortly with 
some follow up comments.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
Caution: This is an external email. Please take care when clicking links or opening attachments. When in doubt, 
report the message using the 'Report this email' button  
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3
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Friday, October 27, 2023 10:33 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Peggy Felice <peggy.felice@nxp.com>; Mike Sherer <msherer@trinityconsultants.com>; Stephen Wagner 
<stephen.wagner@nxp.com> 
Subject: RE: [EXT] MCAQD Draft Rule 338 Work Group 
Hello Hannah and Greg, 
Thank you for making addiƟonal changes to the draŌ rule. As for the statement about acceptable records for 
demonstraƟng compliance with SecƟon 301, we sƟll feel that it’s important to make it clear that VOC emissions are 
allowed to be calculated based on approved emission factors. This is because emissions of some corrosive VOCs (which 
are no longer exempt from rule 338) can’t be calculated based on waste records. In our case these emissions and 
discharged amounts are based on calculaƟons. We believe that either expanding the below statement or adding the 
following language (which was originally in secƟon 502.3) “Emission factors acceptable to the Control Officer are 
allowed to be used in calculating VOC emissions.” to secƟon 301 would make this more clear.  
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
calculaƟons accepted by the control officer or adequate records demonstraƟng otherwise can be provided to the 
Control Officer.” 
In addiƟon to our earlier comments (submiƩed on 10/2) which might be already included in the latest draŌ of rule 338 
(presented in the meeƟng on 10/17 but not sent out yet), we would like to also propose a modificaƟon of the term 
“Process Tool” and “Solvent”. Upon further review of the draŌ rule and discussion with Mike Sherer we’ve realized that 
the current definiƟon of Process Tool could be interpreted as including all process tools that use VOCs. This would mean 
that even fluorinated gases like CH3F used in etch processes would fall under this rule. We believe this was not the 
intent of this rule as the statement in secƟon 503.7 refers to “other VOCs” and further down in the same secƟon 
“etchant VOC” is used as an example of the “other VOC”. 
PROCESS SOLVENT TOOL: Equipment used using solvent during the semiconductor fabrication process to 
perform various operations needed to make the final product. Some of these tools contain devices 
inherent to the equipment, which treat or condition exhaust gases as they leave the process chamber. 
SOLV   SOLVENT: Any VOC-containing liquid or vapor which is used to dissolve, clean, strip, or remove impurities, 
coatings, contaminants, or films from surfaces or from internal spaces and voids. This includes, but is 
not limited to, developers and stripping agents. This does not include organic compounds used in 
ashing, plasma etch, diffusion and chemical vapor deposition processes. 
See below for NXP response to your quesƟons. 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons? Solvent cleaning operaƟons using IPA that are far from the ECS

Where are the solvent cleaning machines located (i.e., clean room, repair shop)? Clean room
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4

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS? Solvent cleaning operaƟons using IPA that are far from the ECS

What cleanroom classificaƟon does your operaƟon fall under? Equal to or more stringent than class 100,000
parƟcles/m3
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Thank you 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, October 19, 2023 8:55 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] MCAQD Draft Rule 338 Work Group 
Good morning,  
Thank you for aƩending the third work group meeƟng held virtually on October 17th for draŌ Rule 338. Based on the 
group discussion about proposed revisions, there are two main topics that need to be addressed: draŌ rule language in 
SecƟon 301 and solvent cleaning.  
Please review the following informaƟon and provide feedback by Friday, October 27th.  
SecƟon 301 Language 
Based on the discussion regarding SecƟons 301 and 501.3, we have draŌed some language to expand on the acceptable 
records for demonstraƟng compliance with SecƟon 301. Please provide any feedback on the proposed language. 
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
adequate records demonstraƟng otherwise can be provided to the Control Officer.” 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons?

Where are the solvent cleaning machines located (i.e., clean room, repair shop)?

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS?

What cleanroom classificaƟon does your operaƟon fall under?
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o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Please note that I will be out of the office starting Friday, October 20th and will return Monday, October 30th. Should you 
have any questions prior to my return, please reach out to Greg Verkamp.  
Thank you for your continued participation in the rulemaking process.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
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1
From:
Hana De Leon <hana.deleon@nxp.com>
Sent:
Thursday, February 15, 2024 4:00 PM
To:
Hannah Luke (AQD); Kimberly Butler (AQD); Gregory Verkamp (AQD)
Cc:
Stephen Wagner; Peggy Felice; Mike Sherer
Subject:
RE: [EXT] RE: MCAQD Draft Rule 338 Work Group
This Message Is From an External Sender  
This message came from outside your organization. Please use caution when corresponding outside the county.  
Sounds good 
Thank you 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, February 15, 2024 1:16 PM 
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Hi Hana,  
We discussed your comments internally and have the following responses: 

Since the definition of Process Tool includes equipment processing photoresist, it appears there is no reason to
specifically mention photoresist operations in sections 301.1, 503.5 and 503.7. Thus we suggest the phrase
“aggregated photoresist and process tool operations” is simplified to: “process tool operations”.
o
We agree with your suggestion and will remove mention of photoresist from those sections.

Since the good combustion plan is not expected to change frequently, could section 501.7.b be modified to:
Good Combustion Plan: Maintain a Good Combustion Plan as required in Section 303.3(b). The plan must be
reviewed every year and updated as needed every year to contain current information. Any change to the plan
and the annual review shall be documented.
o
For Section 501.7(b), we propose the following updates: “Maintain a Good Combustion Plan as required
in Section 303.3(b). The plan must be reviewed every year and updated as needed to contain current
information. The annual review and any change to the plan shall be documented.”
Please let me know if you have any comments or questions on our responses.  
Thank you! 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
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report the message using the 'Report this email' button  
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2
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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Customer Satisfaction Survey
From: Hannah Luke (AQD)  
Sent: Monday, February 12, 2024 2:17 PM 
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Hello Hana, 
Thank you for your comments on draft Rule 338. We will be reviewing internally and get back to you with our responses 
soon.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Monday, February 12, 2024 8:53 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
 
Hello Hannah, 
We have couple more suggestions for Rule 338: 

Since the definition of Process Tool includes equipment processing photoresist, it appears there is no reason to
specifically mention photoresist operations in sections 301.1, 503.5 and 503.7. Thus we suggest the phrase
“aggregated photoresist and process tool operations” is simplified to: “process tool operations”.

Since the good combustion plan is not expected to change frequently, could section 501.7.b be modified to:
Good Combustion Plan: Maintain a Good Combustion Plan as required in Section 303.3(b). The plan must be
reviewed every year and updated as needed every year to contain current information. Any change to the plan
and the annual review shall be documented.
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Tuesday, January 9, 2024 10:49 AM 
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3
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: MCAQD Draft Rule 338 Work Group 
Hi Hana, 
We have discussed your feedback internally and determined that we agree with your proposed revisions to the formula 
and will incorporate them into the draft rule.  
The draft rule will be posted to EROP by January 23rd and the second stakeholder workshop will be held virtually on 
February 6th at 9 a.m. Please let me know if you have any questions.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Tuesday, January 9, 2024 7:31 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: MCAQD Draft Rule 338 Work Group 
 
Hello Hannah, 
Please see the below revised response for clarification purposes: 
When we reviewed the proposed formula for our previous response, we recommended several clarification changes 
that are all interrelated. Whereas most VOC emissions are determined by calculating VOC used and subtracting  VOC 
waste shipped off site (mass balance), this is not true of all VOC emissions at our site (and we believe this is true at other 
semiconductor sites as well). VOCs such as tetramethylammonium hydroxide (TMAH) developer are used in aqueous 
solution of less than 3% and the wastewater containing the TMAH is discharged to POTW. Air emissions of TMAH are 
calculated utilizing an emission factor specified in the Technical Support Document (TSD) related to the site air permit. 
There are other materials whose VOC emissions are calculated with emission factors specified in the TSD instead of mass 
balance as well.  
With this in mind, the first part of the proposed formula works only if the CVOCi is mass of VOC emissions generated 
(pre-abatement). Considering that the CVOCi parameter is reduced only by the capture and control efficiency of the VOC 
abatement, it is logical that the component being reduced is the amount of material sent to the VOC abatement 
(emissions).  
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𝑉𝑂𝐶 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠ൌ ෍ሺ𝐶𝑉𝑂𝐶𝑖ሻሺ1 െ𝐶𝑖ሻ
௡
௜ୀଵ
൅෍ሺ𝑈𝑉𝑂𝐶𝑗ሻሺ1 െ𝑊𝑗ሻ
௠
௝ୀଵ
 
For similar reasons, the UVOCj should be the amount of VOC emissions that are not sent to VOC abatement (unabated 
VOC emissions). If UVOCj is VOC emission, there is no need to subtract out the VOC waste component (Wj). This would 
already be done, if applicable, when calculating the VOC emissions.  
For these reason we proposed the following modification: 
SecƟon 503.X Formula for DeterminaƟon Mass Balance of VOC Emissions: 
𝑉𝑂𝐶 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠ൌ ෍ሺ𝐶𝑉𝑂𝐶𝑖ሻሺ1 െ𝐶𝑖ሻ
௡
௜ୀଵ
൅෍ሺ𝑈𝑉𝑂𝐶𝑗ሻሺ1 െ𝑊𝑗ሻ
௠
௝ୀଵ
 
Where: 
VOC Emissions = The total sum of VOCs emiƩed to ambient air from all photoresist operaƟons and/or process 
tools. 
CVOCi = mass of VOC emissions generated from the “I”th source of photoresist operaƟon and/or process tool 
which is routed to a control device designed to destroy VOC. 
Ci = overall capture and control efficiency of VOC for the specific control device which the “I”th source of VOC 
emissions is routed to. 
UVOCj = mass of VOC emissions generated from the “j”th source of photoresist operaƟon and/or process tool 
which is not routed to a control device designed to destroy VOC. 
Wj = fracƟon of VOC generated from the “j”th source of photoresist operaƟons and/or process tool which is not 
routed to a control device designed to destroy VOC, that is shipped off-site without being emiƩed to ambient 
air. 
Hope this provides more clarification. If needed, we are open to meet and discuss it further. 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, January 4, 2024 2:53 PM 
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com>; Ryan Dalrymple (AQD) <Ryan.Dalrymple@Maricopa.gov> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Hello Hana,  
Can you please provide some additional information regarding your suggestion to delete (1-Wj) from the formula? 
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Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hannah Luke (AQD)  
Sent: Thursday, December 14, 2023 7:34 AM 
To: Hana De Leon <hana.deleon@nxp.com>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp 
(AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Hi Hana, 
Thank you for your feedback on the formula. We will be discussing internally and get back to you with any 
questions/comments we have.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Wednesday, December 13, 2023 10:15 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Cc: Stephen Wagner <stephen.wagner@nxp.com>; Peggy Felice <peggy.felice@nxp.com>; Mike Sherer 
<msherer@trinityconsultants.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Hello Hannah, We made some edits to your proposed text (scroll down to see edits in red). In summary the proposed changes are: Change Section 503. X “Formula for Mass Balance of VOC Emissions” to “Formula for Determination  
 
Hello Hannah, 
We made some edits to your proposed text (scroll down to see edits in red).  
In summary the proposed changes are: 

Change SecƟon 503.X “Formula for Mass Balance of VOC Emissions” to “Formula for DeterminaƟon of VOC
Emissions” to allow for use of emission factors in addiƟon to mass balance calculaƟons.

Delete (1-Wj) from the formula. The only difference between abated and unabated emissions is the overall
capture and control efficiency of VOC for the specific control device.

Change “mass of VOC generated” to “mass of VOC emissions generated” in the descripƟon of CVOCi and UVOCj
to make it clear this is the amount of VOC emiƩed.

Delete descripƟon of Wj because it’s not needed in the formula.
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6
It’s difficult to concisely relay all of the reasons for these suggested changes. We are available to meet to discuss any 
quesƟons you may have. 
Hana and Peggy 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, December 13, 2023 6:28 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] RE: MCAQD Draft Rule 338 Work Group 
Good morning,  
Since the October 19 email requesƟng further informaƟon regarding SecƟon 301, we received your feedback and have 
taken it into consideraƟon. The consensus was that Rule 338 should conƟnue to include language which allows the 
accounƟng for uncontrolled VOC emissions by emissions calculaƟons approved by the Control Officer. We have been 
working to incorporate your suggesƟons while geƫng feedback from the EPA to finalize the proposed language. The EPA 
advised us to avoid including Control Officer discreƟon in the rule, and suggested we include a formula in the rule which 
would correlate to the emission calculaƟons being used. Taking EPA’s advice into account we created a calculaƟon to 
incorporate into the rule as seen below. 
The proposed language in SecƟon 301 would read as follows: 
301 CONTROL OF VOC EMISSIONS FROM SEMICONDUCTOR MANUFACTURING OPERATIONS: 
301.1 An owner or operator of a semiconductor manufacturing operaƟon that discharges 25 or more tons of VOCs per 
year from aggregated photoresist and process tool operaƟons, prior to any emissions controls, shall maintain such 
operaƟons under negaƟve pressure, per SecƟon 503.3 and meet one of the following requirements: 
a. Achieve at least 90% overall VOC capture and control of aggregated photoresist and process tool operaƟons,
determined by applicable provisions in SecƟon 503.3; or
b. For VOC input-concentraƟons of less than 100 ppmvd (as propane) at the inlet of the ECS, the control efficiency is
saƟsfied if the VOC outlet concentraƟon is less than or equal to 10 ppmvd (as propane), as determined by applicable
provisions in SecƟon 503.
301.2 Any VOC emissions not controlled per SecƟon 301.1 shall be assumed to have evaporated onsite unless: 
a. Records demonstraƟng otherwise can be provided to the Control Officer; or
b. The VOC emissions are accounted for in emissions calculaƟons per SecƟon 503.X.
The intent of the formula is to provide a general mass balance equaƟon that allows for flexibility in how uncontrolled 
VOC emissions are being calculated. The formula that would be referenced in SecƟon 301.2(b) would read as follows: 
SecƟon 503.X Formula for DeterminaƟon Mass Balance of VOC Emissions: 
𝑉𝑂𝐶 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠ൌ ෍ሺ𝐶𝑉𝑂𝐶𝑖ሻሺ1 െ𝐶𝑖ሻ
௡
௜ୀଵ
൅෍ሺ𝑈𝑉𝑂𝐶𝑗ሻሺ1 െ𝑊𝑗ሻ
௠
௝ୀଵ
 
Where: 
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VOC Emissions = The total sum of VOCs emiƩed to ambient air from all photoresist operaƟons and/or process 
tools. 
CVOCi = mass of VOC emissions generated from the “I”th source of photoresist operaƟon and/or process tool 
which is routed to a control device designed to destroy VOC. 
Ci = overall capture and control efficiency of VOC for the specific control device which the “I”th source of VOC 
emissions is routed to. 
UVOCj = mass of VOC emissions generated from the “j”th source of photoresist operaƟon and/or process tool 
which is not routed to a control device designed to destroy VOC. 
Wj = fracƟon of VOC generated from the “j”th source of photoresist operaƟons and/or process tool which is not 
routed to a control device designed to destroy VOC, that is shipped off-site without being emiƩed to ambient 
air. 
Please provide your feedback regarding the proposed language by December 22, 2023.  
We are planning to hold a second stakeholder workshop for Rule 338 in January, with the draŌ rule being posted to the 
Maricopa County Enhanced Regulatory Outreach Program website 2 weeks prior to the workshop date. Should you have 
any quesƟons, please let me know.  
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hannah Luke (AQD)  
Sent: Thursday, October 19, 2023 8:55 AM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Draft Rule 338 Work Group 
Good morning,  
Thank you for aƩending the third work group meeƟng held virtually on October 17th for draŌ Rule 338. Based on the 
group discussion about proposed revisions, there are two main topics that need to be addressed: draŌ rule language in 
SecƟon 301 and solvent cleaning.  
Please review the following informaƟon and provide feedback by Friday, October 27th.  
SecƟon 301 Language 
Based on the discussion regarding SecƟons 301 and 501.3, we have draŌed some language to expand on the acceptable 
records for demonstraƟng compliance with SecƟon 301. Please provide any feedback on the proposed language. 
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8
“Any VOC emissions not controlled per SecƟon 301.1 or 301.2 shall be assumed to have evaporated onsite unless 
adequate records demonstraƟng otherwise can be provided to the Control Officer.” 
Solvent Cleaning 
With solvent cleaning we are interested in knowing which solvents are being used in the semiconductor industry that 
cannot comply with the requirements in Rule 331. Below are some quesƟons to consider. 

Which solvent cleaning operaƟons are not vented to an Emission Control System (ECS) and what type of solvents
are used in these situaƟons?

Where are the solvent cleaning machines located (i.e., clean room, repair shop)?

What solvent cleaning operaƟons, aside from wipe cleaning, comply with the 33 mm Hg at 20°C (68°F) vapor
pressure limitaƟon in Rule 338, but cannot meet the 1 mmHg at 20°C (68°F) vapor pressure limitaƟon in Rule
331 and are not vented to an ECS?

What cleanroom classificaƟon does your operaƟon fall under?
o
SIP Rule 331 (see aƩached) SecƟon 308.3(c) includes a parƟal exempƟon from SecƟon 304 for
producƟon processes having clean-room standards equal to or more stringent than class 100,000
(parƟcles/m3).
o
SecƟon 304 includes the three compliance opƟons of either using a conforming solvent, ECS, or sealed
system. This exempƟon is proposed to be included in draŌ Rule 331.
Please note that I will be out of the office starting Friday, October 20th and will return Monday, October 30th. Should you 
have any questions prior to my return, please reach out to Greg Verkamp.  
Thank you for your continued participation in the rulemaking process.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
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1
From:
Michelle Mada (AQD)
Sent:
Tuesday, February 13, 2024 4:34 PM
To:
Michele Ross (COA)
Cc:
Kimberly Butler (AQD); Gregory Verkamp (AQD); Hannah Luke (AQD)
Subject:
RE: Online Form Submittal: Citizen Comments
Thank you. 
Michelle Mada 
Administrative Operations Specialist 
Air Quality 
Planning and Analysis 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-372-1465 C: 602-695-5890
E: Michelle.Mada@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: Michele Ross (COA) <Michele.Ross@maricopa.gov>  
Sent: Tuesday, 13 February, 2024 4:32 PM 
To: Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: FW: Online Form Submittal: Citizen Comments 
Please see the citizen comment below and attachment. 
Thank you, 
Michele Ross 
Program Manager 
County Manager’s Office 
O: 602-506-0583 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
From: noreply@civicplus.com <noreply@civicplus.com>  
Sent: Tuesday, February 13, 2024 4:10 PM 
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (HSD) <Kathy.Semder@Maricopa.Gov>; Andy 
Linton (ENV) <Andy.Linton@Maricopa.Gov>; Bill Leal (DOT) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (PND) 
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov>; Michele Ross (COA) 
<Michele.Ross@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.   
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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-2023-004-Rule 338 (Semiconductor Manufacturing) 
Department 
Air Quality 
I would like to  
Express opposition 
First Name 
Rita 
Last Name 
Loof 
Organization 
RadTech International 
City 
Chevy Chase 
Zip 
Field not completed. 
Email 
rita@radtech.org 
Phone Number 
909-240-0866
Phone Type 
Mobile 
Would you like someone to 
contact you? 
Yes 
Comments 
Please see attached public comment letter. 
If applicable, attach 
supporting documentation 
associated with your 
comment. The only file 
types supported are MS 
Office and Adobe Acrobat. 
RadTech Public Comments Rule 338 021324.pdf
Email not displaying correctly? View it in your browser.  
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The Honorable Board of Health 
Maricopa County  
February 13th, 2024 
Re:  Public Comments on the Initiation of Regulatory Changes to Rule 338—Semiconductor 
Manufacturing—OPPOSE unless Amended  
RadTech is pleased to comment on Maricopa County’s proposed amendments to Rule 338 –
Semiconductor Manufacturing.   We previously submitted written comments in July and made 
verbal comments at a recent public meeting.  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 including 
semiconductor manufacturing.  
Unlike conventional inks and coatings, UV/EB/LED products do not evaporate.  Instead, they are 
specifically formulated to react to energy (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/LED 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 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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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 Rule Language Changes 
According to the staff report, the Maricopa County Air Quality Department (MCAQD) is 
proposing to revise Rule 338 to incorporate Reasonably Available Control Technology (RACT) 
level controls that will regulate emissions generated during the semiconductor manufacturing 
process.  In addition, MCAQD will review the VOC controls in Rule 338 and ensure the controls 
implement RACT.  We are concerned that the proposed changes to Rule 338 do not take into 
consideration pollution prevention processes such as UV/EB/LED. RadTech believes that Rule 
338 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.  In its current form, Rule 338 seems to focus on Emission 
Control Systems (ECS) as the only means of compliance.  The one sided approach, unfairly 
excludes pollution prevention technologies such as UV/EB/LED and puts our businesses at 
disadvantage as compared to systems using conventional solvents with ECS.  Thus, our 
organization cannot support the rule in its current form. 
Section 103.2-- Exemptions 
Our materials are typically well below 50 grams/liter in VOC content.  The rule groups materials 
ranging from 2 grams per liter to 100 grams per liter.  We would suggest an intermediate VCO 
content of 50 grams per liter and respectfully request that UV/EB/LED materials with a VOC 
content of 50 grams per liter or less be exempted from 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.   
Section 200-- Definitions 
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The rule narrowly focuses the definitions section on ECS.  This approach does not take into 
consideration other technologies and may have the unintended consequence of giving a certain 
process an unfair competitive advantage.  The rule should be technology neutral and include 
definitions for all available technologies. 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.  
Section 301.1—Control of VOC Emissions form Semiconductor Manufacturing Operations 
This section exclusively refers to Emission Control devices.   While facilities emitting less than 2 
tons per year are not included, it is not clear what alternative technologies would be acceptable.  
We suggest adding language to explicitly state that UV/EB/LED technology can be used in lieu 
of add on emission control systems.  
Section 503—Compliance Determination 
This Section is especially problematic because Rule 338 does not specify a test method for 
energy curable materials in Section 504.  The current rule language states: 
“When more than one test method is permitted for a determination, an exceedance of the limits 
established in this rule determined by any of the applicable test methods constitutes a violation of 
this rule.” 
The lack of clarity as related to acceptable test methods may put out the businesses we represent 
at risk of enforcement action by Maricopa County.  Section 503.1(c) specifies the allowance of 
an ASTM method for waterborne materials.  The same approach should be afforded to energy 
curable materials by including ASTM D7767-11. 
We ask that Section 504 be clarified to include test methods for UV/EB/LED (see comments on 
Section 504). 
Section 501—Recordkeeping and Reporting 
We request an exemption for UV/EB/LED from the unnecessarily burdensome requirements of 
Section 501.  Maricopa County should provide incentives in the form of reduced recordkeeping 
and reporting, for facilities that go above and beyond rule requirements.  This approach is a win-
win because it will result in excess emission reductions for Maricopa County. 
Section 504--Test Methods 
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:  
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
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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. 
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 
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1
From:
Hannah Luke (AQD)
Sent:
Tuesday, February 13, 2024 4:27 PM
To:
Rita Loof; Gregory Verkamp (AQD); Kimberly Butler (AQD)
Subject:
RE: Maricopa County Rule 338  Public Comments
Good afternoon Rita, 
Thank you for your comments on draft Rule 338. We will evaluate your comments and get back to you soon.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Rita Loof <rml93@verizon.net>  
Sent: Tuesday, February 13, 2024 4:12 PM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: Maricopa County Rule 338 Public Comments 
Dear Hannah and Greg, Please see attached which I have also submitted via the web portal. Happy to discuss further, thanks. Rita Rita M. Loof Director, Environmental Affairs RadTech International rita@ radtech. orgrml93@ verizon. net909-981-5974909-240-0866  
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Dear Hannah and Greg, 
Please see attached which I have also submitted via the web portal.  Happy to discuss further, thanks. 
Rita 
Rita M. Loof 
Director, Environmental Affairs 
RadTech International 
rita@radtech.org 
rml93@verizon.net 
909-981-5974
909-240-0866 cell/text
www.radtech.org
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1
From:
Hannah Luke (AQD)
Sent:
Monday, February 26, 2024 8:04 AM
To:
D'Oria, Gary R
Cc:
Kabiri-badr, Leila; Zambrano, Oscar; Gregory Verkamp (AQD)
Subject:
RE: Intel Comments to MCAQD proposed Rule 330, 331, 338 20240223.pdf
Hi Gary, 
Thank you for providing Intel’s comments on Rules 330, 331, and 338. We will begin reviewing internally and get back to 
you shortly with suggested dates/times to meet and discuss further. Please let me know if you have any questions.  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: D'Oria, Gary R <gary.r.doria@intel.com>  
Sent: Monday, February 26, 2024 7:49 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Zambrano, Oscar <oscar.zambrano@intel.com> 
Subject: Intel Comments to MCAQD proposed Rule 330, 331, 338 20240223.pdf 
Hannah. Regretfully, I just now realized this didn’t get emailed Friday. . . Please let us know when you’d like to discuss our comments later this week, and perhaps suggest several times that may work on our calendars. Regards, Gary  
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Hannah. 
Regretfully, I just now realized this didn’t get emailed Friday...  
Please let us know when you’d like to discuss our comments later this week, and perhaps suggest several times that may 
work on our calendars. 
Regards,  
Gary D’Oria 
TD Environmental Engineer 
Intel Corporation | Chandler Campus 
(480) 241-4917
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EMAIL DELIVERY 
February 23, 2024 
Hannah Luke 
Air Quality  
Maricopa County Air Quality Department 
301 W. Jefferson St., Suite 410  
Phoenix, AZ 85003  
Email: Hannah.Luke@Maricopa.Gov    
RE: 
Intel Corporation Comments on MCAQD Proposed Rule 330, 331 & 338 
Dear Ms. Luke: 
Intel Corporation (Intel) submits the following comments on the Maricopa County Air 
Quality Department (MCAQD) proposed changes to Rule 338.  Intel operates semiconductor 
manufacturing in Arizona with 6 world-class fabrication (Fab) sites in operation and under 
construction at our Ocotillo Campus and world class research and development at our Chandler 
Campus. 
Intel, with many others has participated in the stakeholder process for MCAQD’s proposed 
rules and appreciates MCAQD’s willingness to discuss key issues of importance during the 
stakeholder process.  The Intel Chandler research and development (aka TD) facility has uses 
isopropyl alcohol (IPA) in open bath parts cleaning and in wipe cleaning. These uses and respective 
emissions are included in the air emissions inventory (AEI) and result in high volume low 
concentration mass emissions.  However, Intel believes the rulemaking may have significant, 
adverse consequences on the Intel Chandler Campus and feels it is necessary to submit additional 
company comments on these proposed rules. Some areas using IPA in this manner have very low 
emissions and are not currently equipped with an emission control system (ECS). Even in buildings 
that currently have an ECS, (e.g. CH4 building RTO) connecting these IPA using sources would 
result in significant increases in the total flow into the system from sources with low VOC 
concentration. Connecting these dilute sources will result in a higher flow, lower concentration 
stream which will increase the NOx emissions from the existing ECS and likely lower its overall 
removal efficiency. In addition, connecting these new VOC sources would result in significant 
increases in the total flow requiring additional capacity and a new ECS. Specific concerns follow. 
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Proposed Rule 330 
Based on our current Air Permit, the Intel Chandler campus is projected to have total pre-control 
emissions > 25 TPY VOCs.  The proposed rule 330 would require that the entire amount of this 
discharge must be connected to an ECS that meets 85% capture and control (excluding materials 
with < 20% VOC content or < 1 mmHg vapor pressure). The Intel Chandler TD operations may 
include wipe cleaning.  These operations are exempted from control requirements in the proposed 
rule 331 but would appear to require control in the rule 330 proposal. While 330 does state that it 
applies to sources not regulated by more source specific rules, Intel would like to clarify that the 
blanket provisions of rule 330 do not create a control requirement for wipe cleaning, as the 331 
provisions exempt wipe cleaning from control requirements.  Attempting to route wipe cleaning 
emissions to an ECS is not practical as this is performed across the factory in many locations. If 
these sources were connected to a ECS the result would be a very high flow, dilute exhaust stream 
driving significant increases in NOx that would likely exceed current Air Permit Limits.   
Proposed Rule 331 
In general, this rule could be made clearer and explicitly state the requirements for cleaning 
machines that can be done to avoid an ECS. In CH solvent “cleaning machines” are impacted as 
they don’t have a "remote reservoir" or non-remote internal reservoir".  Cleaning machines use 
IPA solvent with a volume > than 1 square foot and > 1 gallon with VP > than 1mm Hg. 
Attempting to route “cleaning machine” emissions to an ECS is not practical as these sources if 
connected to a ECS the result would be a very high flow, dilute exhaust stream driving significant 
increases in NOx that would likely exceed current Air Permit Limits. 
Proposed Rule 338 
Section 401.3 requires any modifications to ECS to be completed and unit source tested within 12 
months of applicability.  This timeline is too short for this requirement to add new emission control 
system (ECS) capacity, with Air Permitting, construction supporting ductwork within the 
cleanroom combined with external ductwork using steel and concrete.  Construction projects 
timelines are for projects of this scale are in the 3-year timeframes.  
TD Environmental Engineering, Environmental Health & Safety 
Intel Corporation | 5000 W Chandler Blvd  
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1
From:
D'Oria, Gary R <gary.r.doria@intel.com>
Sent:
Tuesday, March 19, 2024 3:23 PM
To:
Hannah Luke (AQD)
Cc:
Gregory Verkamp (AQD); Kabiri-badr, Leila; Zambrano, Oscar
Subject:
RE: MCAQD Rule 338 Comment 
Attachments:
Intel Chandler Campus Comments to MCAQD proposed Rule 330 331 338 20240319.pdf
This Message Is From an External Sender  
This message came from outside your organization. Please use caution when corresponding outside the county.  
Hannah. 
See aƩached second round of comments on the AQD Proposed Rules changes. Looking forward to discussions this 
Thursday. 
Thanks  
Gary 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Thursday, March 7, 2024 3:01 PM 
To: D'Oria, Gary R <gary.r.doria@intel.com> 
Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Rule 338 Comment  
Hi Gary, 
We met with the EPA and were able to discuss Intel’s comment on Rule 338 SecƟon 401.3. The EPA would like addiƟonal 
jusƟficaƟon on the requested Ɵmeframe increase. If possible, please provide supporƟng informaƟon that would 
demonstrate the need for the Ɵmeframe related to modificaƟons to an ECS.  
Would you be able to provide this informaƟon by next Friday 3/15, in addiƟon to the solvent cleaning machine 
equipment details? 
Thank you, 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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EMAIL DELIVERY 
March 19, 2024 
Hannah Luke 
Air Quality  
Maricopa County Air Quality Department 
301 W. Jefferson St., Suite 410  
Phoenix, AZ 85003  
Email: Hannah.Luke@Maricopa.Gov    
RE: 
Intel Corporation Comments on MCAQD Proposed Rule 330, 331 & 338 
Dear Ms. Luke: 
Intel Corporation (Intel) is providing a follow-up to our February 23, 2024, comments on the 
Maricopa County Air Quality Department (MCAQD) proposed changes to Rule 331 and Rule 
338. These comments are addressing concerns and considerations for the Assembly Test
Technology Development (ATTD) or Research and Development (R&D) at our Chandler
Campus. In this meeting we agreed to provide additional evaluations of the solvent cleaning
activities that are possibly impacted by the modifications in Rule 331§ 302.2 & 302.3.
As stated in the last comment letter, the current Air Permit limits the Intel Chandler campus to no 
more than 35 TPY VOCs. This is greater than the Proposed Rule 330 total pre-control emissions 
of no more than 25 TPY VOCs. The proposed Rule 330 would require that the entire amount of 
this discharge must be connected to an ECS that meets 85% capture and control (excluding 
materials with < 20% VOC content or < 1 mmHg vapor pressure). Rule 330 states that it applies 
to sources not regulated by more specific rules.  
In this solvent cleaning evaluation, we discovered that semiconductor substrate R&D non-
solvent cleaning wet plating (aqueous) tools would now be required to be connected to an ECS 
by Rule 338 vs. Rule 331 due to Rule 338 broadened applicability and the Vapor Pressure 
requirement in the Rule 331 defining a conforming solvent as ≤1 mmHg. Connecting these non-
solvent cleaning wet plating tool sources to a ECS would result in high flow, low VOC 
concentrations in the exhaust leading to what we feel are counterproductive increases in NOx. 
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2 
Specifically, Intel’s current estimates from these tools is ~1,300 lbs./year VOCs requiring an 
additional ~10,000 cfm of exhaust connected to an ECS, which could potentially result in an 
additional ~8600 lbs. of NOx per year.  We would like your comments of our analysis showing 
the expansion of the Rule 338 applicability beyond photoresist operations that may now regulate 
many wet plating tools.  These wet plating tools have water content slightly under 95% with 
relatively low VOC emissions but high NOx releases when connected to an ECS.  
Intel utilizes a number of “batch” cleaning machines, some of which use non-conforming 
solvents and are not small enough to be considered small cleaners.  However, it is our 
understanding that rule 331 would not require such machines to be connected to an ECS as 
section 302.c(4) states that a non-conforming solvent may be used if one of conditions “a” 
through “c” are met.  Part “c” of this section exempts certain SIC codes described in section 
103.3 including electronics manufacturing, which is the category Intel fits in.  Based on this it is 
our conclusion that batch cleaning systems would not be required to be connected to an ECS. We 
would appreciate your thoughts on if we’re interpreting this correctly. The Proposed Rule 331 
could appear to require that some in-line cleaning systems be connected to an ECS as section 
302.3 does not include the section 103.3 SIC Code exemption for in-line cleaning machines.  Our 
review of the semiconductor solvent cleaning equipment that use IPA and EtOH and covered by 
this Rule has identified requirements to connect to an ECS. Our estimates show that this could 
result in an additional 5000 cfm of exhaust connected to an ECS, which could potentially result 
in an additional ~2200 lbs. of NOx per year.  Intel’s current estimates of VOCs from these tools 
is < ~10,000 lbs./year, so this rule would result in generating 2200 lbs. NOx to remove this 
quantity of VOCs. 
In a follow-up email from our meeting, it was requested that we provide additional detail on our 
concerns with proposed Rule 338 401.3 timeframes. Our suggested language for 401.3 b. with 
rational follows. 
Within 12 months after the facility becomes subject to the requirements in section 301.1 
of this rule, the owner or operator shall be complete with ECS modifications for any 
existing ECS with existing infrastructure and existing capacity and perform “start-up” 
in accordance with Rule 270. Submittal to the Control Officer of a complete source test 
report indicating compliance shall be provided in the timeframes defined by Rule 270.   
Within 36 months after the facility becomes subject to the requirements in section 301.1 
of this rule, the owner or operator shall be complete with ECS modifications for any new 
ECS requiring new infrastructure and new capacity and perform “start-up” in 
accordance with Rule 270. Submittal to the Control Officer of a complete source test 
report indicating compliance shall be provided in the timeframes defined by Rule 270. 
Any “reconstructing or adding on equipment” is in our experience considered new infrastructure 
and new capacity and would requires 36 months for construction completion. Intel Chandler has 
recently installed VOC Abatement units that can be used as an example of construction 
schedules for reconstruction or addition of equipment. There was a need to expand the VOC 
abatement capacity due to new tools supporting technology development. Intel semiconductor 
construction schedules are some of the most aggressive in the industry due to the time-to-market 
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3 
strategy driving product technology advancements. In this example assume that a “plan of 
record” (POR) ECS is selected. This POR means that ECS supplier selection with contracts in 
place with performance specifications, master design standards, operating specifications and any 
treatability studies needed. Otherwise, this can take an additional 6-9 months to develop an Intel 
POR ECS. A brief example of construction schedules follows. 
•
3-6 Months for Design Positioning / Programing, this may include ductwork design and
layout within the cleanroom.
•
18-30 Months for Design Construction – this may include ductwork design and layout
within the cleanroom and staging of construction to avoid impacts to manufacturing
operations.
We appreciate the opportunity to provide comments to these proposed rules and welcome future 
meetings for guidance and to discuss our concerns and considerations.  
TD Environmental Engineering, Environmental Health & Safety 
Intel Corporation | 5000 W Chandler Blvd  
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From:
D'Oria, Gary R <gary.r.doria@intel.com>
Sent:
Monday, April 1, 2024 7:16 AM
To:
Hannah Luke (AQD); Gregory Verkamp (AQD)
Cc:
Kabiri-badr, Leila; TIM HIGGS
Subject:
Intel Follow-up from MCAQD Meeting 3/26/2024
This Message Is From an External Sender  
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Hi Hannah, 
From our discussions last week, we were to follow-up with you and Greg regarding the exemption for 
Substrates R&D Non-Solvent Wet Processing Plating tools (i.e., Substrate Packaging Technology Development, 
SPTD)  
Suggested clarifications to the Proposed New Rule 338 existing language for exemption for R&D  
Semiconductor Substrate R&D non-solvent cleaning wet plating (aqueous) tools, previously shown in our letter 
dated 3/19 would now be required to be connected to an ECS by Rule 338 vs. 331. In our meeting we read 
Rule 338 103.1 to exempt these tools because they are R&D. “research” and < 5 TPY can you please confirm. If 
you confirm this , then we recommend minor edits to Rule 338 to make this clearer by; 

Defining R&D in Rule 338 SECTION 200 similar to the R&D definition found in 40 CFR § 63.11511(d)(2)
(NESHAPS, 6W); “Research and development process unit means any process unit that is used for
conducting research and development for new processes and products and is not used to
manufacture products for commercial sale, except in a de minimis manner.” Note Intel SPTD is subject
to this NEESHAP exemption as noted in our Air Permit and TDS.

In addition, within Rule 338, 103.1 replace the ref. “research” to “research and development” to be
consistent throughout Rule 338.
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2
Suggested clarifications to the Proposed New Rule 331, language for Partial Exemptions in 103.3  

The SICs Codes for Industry Group 367 ( Semiconductor Operations) are not referenced in 103.3.  Both
Intel Chandler Campus and Ocotillo Campus are both SIC Code 3674, and we can assume that NXP and
TSMC are also 3674. Can you add SIC Code 3674 to 103.3 to include these Semiconductor Operations
thatare most significant in Maricopa County and as discussed meeting the intent of the exemption?

Also, in support of adding SIC Code 3674, the SIC Codes listed do not correspond with the 103.4 ISO
cleanroom requirements. In other words, the SIC Codes referenced in 103.3 do need the cleanrooms
referenced in 103.4.

Considering this current language above, in the 3/19 second letter where we incorrectly stated that
our R&D Batch cleaning was exempt due to 331 103.3 (i.e., SIC Code 3674 was missing), whereas we
should have referenced 103.4 (i.e., ISO).

Note, in 302.2c.(4) Non-Conforming Solvent references 103.3 (SIC) which does not include Intel
Semiconductors in the exemption and instead could replace 103.3 with 103.4 or add both 103.3 and
103.4?

Inconclusion adding 3674 SIC Code to 103.3 may clarify the Partial Exemptions in Proposed New Rule
331, 103.
As a reminder I’m on sick leave from 4/1 and returning to work 4/15 with Leila Kabiri covering for me during this time. 
Regards, 
Gary 
480.241.4917 
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1
From:
Hannah Luke (AQD)
Sent:
Thursday, May 16, 2024 9:52 AM
To:
Hana De Leon
Cc:
Kimberly Butler (AQD); Gregory Verkamp (AQD); Peggy Felice
Subject:
RE: [EXT] RE: MCAQD Draft Rule 338 - Work Group Meeting #4
Hi Hana,  
Thank you for attending the work group meeting. Good catch on Section 503.7. I have updated the draft rule: 
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
Facebook | Instagram | Twitter | YouTube | LinkedIn 
 
Customer Satisfaction Survey
From: Hana De Leon <hana.deleon@nxp.com>  
Sent: Thursday, May 16, 2024 9:34 AM 
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov>; Peggy Felice <peggy.felice@nxp.com> 
Subject: RE: [EXT] RE: MCAQD Draft Rule 338 - Work Group Meeting #4 
Hello Hannah, Thank you for the review of the Rule 338 final changes today. I’ve noticed a minor typo in section 503. 7 that I want to bring to your attention. The weight of all volatile compounds in the below formula should be depicted  
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2
Hello Hannah, 
Thank you for the review of the Rule 338 final changes today. 
I’ve noƟced a minor typo in secƟon 503.7 that I want to bring to your aƩenƟon. The weight of all volaƟle compounds in 
the below formula should be depicted as Ws instead of Vs to be consistent with the other weights in this and other 
formulas.  
Hana 
VOC CONTENT OF MATERIAL in pounds per gallon (lbs/gal) or grams per liter (g/l) = 
Using consistently either pounds or grams in the calculaƟons, where: 
  =       Weight of all volaƟle compounds in pounds (or grams), including VOC, water, non-precursor 
organic exempt compounds, and dissolved vapors 
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>  
Sent: Wednesday, May 15, 2024 2:13 PM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: [EXT] RE: MCAQD Draft Rule 338 - Work Group Meeting #4 
Good aŌernoon,  
In anƟcipaƟon of the work group meeƟng tomorrow, please see aƩached for the most current version of draŌ Rule 338 
(Semiconductor Manufacturing).  
Please note that there will not be presentaƟon slides uƟlized during the meeƟng. Therefore, there will be no slides sent 
out aŌer tomorrows meeƟng.  
Should you not be able to aƩend the meeƟng and have any quesƟons about the draŌ rule, please let me know. 
Thank you,  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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From: Hannah Luke (AQD)  
Sent: Monday, April 29, 2024 1:44 PM 
To: AQD Planning SM <AQPlanning@maricopa.gov> 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: MCAQD Draft Rule 338 - Work Group Meeting #4 
Good aŌernoon,  
The Maricopa County Air Quality Department held the second stakeholder workshop for draŌ Rule 338 (Semiconductor 
Manufacturing) on February 6, 2024. Since the workshop, we have been working with stakeholders and EPA 
representaƟves in anƟcipaƟon of a potenƟal rule adopƟon date for late September 2024. Due to feedback received, 
there have been some updates to the draŌ rule that we would like to noƟfy stakeholders of with an addiƟonal work 
group meeƟng.  
The work group will be held virtually on Thursday, May 16th at 9 a.m. The invitaƟon will be sent separately from this 
email. We plan to send the draŌ rule out for review someƟme prior to the work group meeƟng.  
For those of you who are unable to aƩend, there will be presentaƟon slides sent out via email aŌer the work group 
meeƟng.  
We will be available for any quesƟons you may have regarding the revisions. 
Thank you,  
Hannah Luke 
Senior Planner 
Air Quality 
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov 
[ Maricopa.Gov ] 
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This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the county.
From:
Mike Sherer
To:
Hannah Luke (AQD); Gregory Verkamp (AQD)
Cc:
Mike Sherer
Subject:
RE: Isopropanol Vapor Pressure at 20 C
Date:
Thursday, May 16, 2024 3:24:38 PM
Attachments:
image001.png
image002.png
Thanks! Looks good
Mike Sherer
Principal Consultant
Trinity Consultants
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014
Cell:  480-773-5548
Email:  msherer@trinityconsultants.com  
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Sent: Thursday, May 16, 2024 12:53 PM
To: Mike Sherer <msherer@trinityconsultants.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>
Subject: RE: Isopropanol Vapor Pressure at 20 C
Hi Mike,
Good point. This will need to be addressed in the rule based on the vapor pressure compliance methods.
We are thinking of adding language to Section 501.4(b) such as:
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Maricopa County Logo
Hannah Luke
Senior Planner
Air Quality
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov
[ Maricopa.Gov ]
Facebook | Instagram | Twitter | YouTube | LinkedIn
Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com> 
Sent: Thursday, May 16, 2024 10:18 AM
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>
Cc: Mike Sherer <msherer@trinityconsultants.com>
Subject: RE: Isopropanol Vapor Pressure at 20 C
Thanks Hannah. I guess my question is more how the vapor pressure would be calculated by MCAQD for compliance? Would it be up to source then to provide this information? Mike Sherer Principal Consultant Trinity Consultants 702 East Osborn Road,
 
Thanks Hannah. I guess my question is more how the vapor pressure would be calculated by MCAQD for
compliance? Would it be up to source then to provide this information?
Mike Sherer
Principal Consultant
Trinity Consultants
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014
Cell:  480-773-5548
Email:  msherer@trinityconsultants.com  
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.
From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> 
Sent: Thursday, May 16, 2024 10:02 AM
To: Mike Sherer <msherer@trinityconsultants.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>
Subject: RE: Isopropanol Vapor Pressure at 20 C
Hi Mike,
Thank you for attending the work group meeting. Regarding the use of IPA, Section 303 requires one of the following solvent specifications be met:
303.1  Use a cleaning-solvent having a VOC content that does not exceed 200 grams per liter (1.7 pounds per gallon; or
 303.2  Using a cleaning-solvent having a VOC composite partial pressure that does not exceed 33.0 mm Hg at a
temperature of 68° F (20° C); or
303.3  Use an ECS to capture and control VOC emissions in accordance with Section 301.1 of this rule; or
303.4  Use a sealed system that is Air-tight or Airless Cleaning System, which is operated according to the manufacturer
specifications and, unless otherwise indicated by the manufacturer, meets all of the following requirements: 
a.  Has a door or other pressure-sealing apparatus that is shut during each cleaning and drying cycle; and
b.  Has a differential pressure gauge that always indicates the pressure in the sealed chamber when occupied or in
active use; and 
c.  Any associated pressure relief device(s) shall be so designed and operated as to prevent liquid cleaning-solvents
from draining out. 
It is our understanding that Section 303.2 would allow the use of IPA as long as the vapor pressure does not exceed 33 mm Hg at 68 F (20
C). Please let me know if you have any further questions.
Thank you,
Hannah Luke
Senior Planner
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Maricopa County Logo
Air Quality
301 W. Jefferson St., Suite 410 Phoenix, AZ 85003
O: 602-506-6706 C: 602-526-4148
E: Hannah.Luke@Maricopa.Gov
[ Maricopa.Gov ]
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Customer Satisfaction Survey
From: Mike Sherer <msherer@trinityconsultants.com> 
Sent: Thursday, May 16, 2024 9:32 AM
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>
Cc: Mike Sherer <msherer@trinityconsultants.com>
Subject: Isopropanol Vapor Pressure at 20 C
Hi Hannah and Greg. Thanks again for your efforts on Rule 338. If you could, would you please confirm that isopropanol vapor pressure at 20 C would be 33 mm Hg and meet Rule 338 Sections 302. 2 and 303. 2? Thanks, Mike. Mike Sherer Principal
 
Hi Hannah and Greg. Thanks again for your efforts on Rule 338. If you could, would you please confirm that
isopropanol vapor pressure at 20 C would be 33 mm Hg and meet Rule 338 Sections 302.2 and 303.2?
Thanks, Mike.
Mike Sherer
Principal Consultant
Trinity Consultants
702 East Osborn Road, Suite 160  |  Phoenix, Arizona  85014
Cell:  480-773-5548
Email:  msherer@trinityconsultants.com  
Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com
Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly.
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Subject:
FW: Online Form Submittal: Citizen Comments
From: Michele Ross (COA) <Michele.Ross@maricopa.gov>  
Sent: Friday, July 5, 2024 1:59 PM 
To: Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; 
Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Will Adrian (AQD) <William.Adrian@maricopa.gov> 
Subject: FW: Online Form Submittal: Citizen Comments 
Please see the citizen comment below and attached letter. 
Thank you, 
Michele Ross 
Program Manager 
County Manager’s Office 
O: 602-506-0583 
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Sent: Friday, July 5, 2024 1:38 PM 
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (HSD) <Kathy.Semder@Maricopa.Gov>; Andy 
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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.   
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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-2023-004-Rule 338 (Semiconductor Manufacturing) 
Department 
Air Quality 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
196 of 200

2
I would like to  
Other 
First Name 
Tom 
Last Name 
Ekren 
Organization 
Arizona State University 
City 
Tempe 
Zip 
Field not completed. 
Email 
Tom.ekren@asu.edu 
Phone Number 
480-788-7278
Phone Type 
Mobile 
Would you like someone to 
contact you? 
Yes 
Comments 
Field not completed. 
If applicable, attach 
supporting documentation 
associated with your 
comment. The only file 
types supported are MS 
Office and Adobe Acrobat. 
Semiconductor Rule Changes SK.docx 
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Maricopa County • Air Quality Department • Report the the Board of Supervisors 
197 of 200

Electronically Submitted 
July 5, 2024 
Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
301 W Jefferson St., Suite 410 
Phoenix, AZ 85003 
RE: 
Arizona State University Comments in Response to Maricopa County Proposed Rulemaking 
Regulation II – Rule 338: Semiconductor Manufacturing 
Dear Ms. Butler, 
Arizona State University (ASU) appreciates the opportunity to comment on Maricopa County Air 
Quality Department’s (MCAQD) proposed revisions to Rule 338: Semiconductor Manufacturing.  In 
addition, ASU values Maricopa County Air Quality for its continued public outreach and workshops 
to better serve the community and regulated industry. 
Comment: Section 204: Freeboard Ratio 
MCAQD defines the “Freeboard Ratio” as the freeboard height divided by the width of the solvent 
cleaning machine.  Arizona State University requests the definition of “freeboard ratio” be defined 
as the freeboard height divided by the smaller of either the length or width of the solvent cleaning 
machining.  Revising the definition will alleviate any ambiguity concerning the definition of the 
width or design of a solvent cleaning machine when the length is smaller than the width.  This 
language resembles many solvent cleaning or degreasing rules, such as South Coast AQMD’s Rule 
1122, Solvent Degreasers or Delaware’s Department of Natural Resources and Environmental 
Control’s Rule 1124, Control of Volatile Organic Compound Emissions. 
Comment: Section 103.1: Quality Control and Research and Development Operations 
ASU requests that the “Quality Control and Research and Development Operations" section 
exemption threshold be set at 7.3 tons per 12-month rolling period.  This value is equivalent to the 
current 40 pound-per-day VOC level extended over a 12-month period. The exemption allows 
research and development operations the flexibility to meet the fast-paced and variable nature of 
semiconductor development.  Additionally, this exemption should only apply to the research and 
development portions of the facility. 
ASU appreciates the opportunity to comment on MCAQD’s proposed revision to Rule 338.  If you 
have any questions, please contact me at 480-788-7278 or Tom.Ekren@asu.edu. 
Sincerely, 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
198 of 200

Tom Ekren 
Sr. EHS Engineer 
Safety in the Built Environment 
Arizona State University 
Maricopa County • Air Quality Department • Report the the Board of Supervisors 
199 of 200

Maricopa County 
Air Quality Department 
Planning and Analysis Division 
Maricopa.gov/AQ