AQ-2023-003-RULE331 REPORT TO THE BOARD OF SUPERVISORS.PDF
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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 331 (Solvent Cleaning) 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 331 (Solvent Cleaning) 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-2023-003-Rule 331 (Solvent Cleaning) The Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 331 to remove a reasonably available control technology (RACT) deficiency identified by the U.S. Environmental Protection Agency so Rule 331 can be approved into the Arizona State Implementation Plan (SIP) as meeting RACT. MCAQD is proposing other revisions to the rule including lowering the VOC content limit in the definition of Low-VOC Cleaner from 50 grams of VOC per liter to 25 grams of VOC per liter as well as restructuring the rule for clarity purposes. In addition, MCAQD plans to replace SIP Rule 34, Sections F-K (Organic Solvents – Volatile Organic Compounds (VOC)) and current SIP Rule 331 with the revised rule to update the SIP and clarify regulatory requirements. 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. Page 2 of 2 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 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-2023-003-Rule 331 (Solvent Cleaning) 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: MCAQD is proposing to revise Rule 331 (Solvent Cleaning) to remove a reasonably available control technology (RACT) deficiency identified by the U.S. Environmental Protection Agency (EPA) so Rule 331 can be approved into the Arizona State Implementation Plan (SIP) as meeting 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 for ozone to implement RACT for all sources subject to a Control Techniques Guideline (CTG) as well as for all non-CTG major sources of volatile organic compounds (VOCs) or nitrogen oxides (NOx). In response to the reclassification, MCAQD determined Rule 331 does not meet RACT. Although Rule 331 is considered as stringent or more stringent than the two CTG source categories it is associated with, it contains an exemption that the EPA has determined is a deficiency. Rule 331 exempts all operations regulated by National Emission Standards for Halogenated Solvent Cleaning (40 CFR 63, Subpart T). This exemption precludes Rule 331 from satisfying the CAA Section 182(b)(2) RACT requirement. Section 182(b)(2) requires that RACT be implemented through SIP-approved rules and reliance on rules outside the SIP such as a National Emission Standard for Hazardous Air Pollutants (NESHAP) for the implementation of RACT is insufficient. NESHAPs are separate obligations under the CAA and may be less stringent than RACT if the NESHAP is outdated. Therefore, removing the NESHAP exemption will ensure Rule 331 meets RACT. In addition, MCAQD is proposing other revisions to the rule including lowering the VOC content limit in the definition of Low-VOC Cleaner from 50 grams of VOC per liter to 25 grams of VOC per liter as well as restructuring the rule for clarity purposes. MCAQD plans to replace SIP Rule 34, Sections F-K (Organic Solvents – Volatile Organic Compounds (VOC)) and current SIP Rule 331 with the revised rule to update the SIP and clarify regulatory requirements. Overview of Stakeholder Input and Staff Responses: MCAQD received written feedback from three (3) stakeholders. One (1) stakeholder expressed opposition and two (2) 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. 2 of 100 Maricopa County Air Quality Department Planning and Analysis Division Report to the Board of Supervisors Rule 331 (Solvent Cleaning) September 2024 Board of Health Meeting Date: July 22, 2024 Board Hearing Date: September 25, 2024 Case Number/Title: AQ-2023-003-Rule 331 (Solvent Cleaning) Agenda Item: (Pending) Supervisor Districts: All Districts Applicant: Staff Request: Approve revision of Maricopa County Air Pollution Control Regulations, Rule 331 (Solvent Cleaning) and approve submission of the revised rule as a revision to the Arizona State Implementation Plan (SIP). Rule 331 establishes limits for emissions of volatile organic compounds (VOCs) from solvent cleaning operations. Rule 331 applies to operations using VOC-containing solvents to remove impurities from exterior or interior surfaces. The Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 331 to remove a reasonably available control technology (RACT) deficiency identified by the U.S. Environmental Protection Agency (EPA) so Rule 331 can be approved into the Arizona SIP as meeting 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 for ozone to implement RACT for all sources subject to a Control Techniques Guideline (CTG) as well as for all non-CTG major sources of VOCs or nitrogen oxides (NOx). In response to the reclassification, MCAQD determined Rule 331 does not meet RACT. Although Rule 331 is considered as stringent or more stringent than the two CTG source categories it is associated with, it contains an exemption that the EPA has determined is a deficiency. Rule 331 exempts all operations regulated by National Emission Standards for Halogenated Solvent Cleaning (40 CFR 63, Subpart T). This exemption precludes Rule 331 from satisfying the CAA Section 182(b)(2) RACT requirement. Section 182(b)(2) requires that RACT be implemented through SIP-approved rules and reliance on rules outside the Maricopa County • Air Quality Department • Report the the Board of Supervisors 4 of 100 SIP such as a National Emission Standard for Hazardous Air Pollutants (NESHAP) for the implementation of RACT is insufficient. NESHAPs are separate obligations under the CAA and may be less stringent than RACT if the NESHAP is outdated. Therefore, removing the NESHAP exemption will ensure Rule 331 meets RACT. In addition, MCAQD is proposing other revisions to the rule including lowering the VOC content limit in the definition of Low-VOC Cleaner from 50 grams of VOC per liter to 25 grams of VOC per liter as well as restructuring the rule for clarity purposes. MCAQD plans to replace SIP Rule 34, Sections F-K (Organic Solvents – Volatile Organic Compounds (VOC)) and current SIP Rule 331 with the revised rule to update the SIP and clarify regulatory requirements. Support/Opposition: MCAQD received written feedback from three (3) stakeholders. One (1) stakeholder expressed opposition and two (2) 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 June 20, 2023, and December 13, 2023. The Board of Health approved initiation of regulatory change on August 28, 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 331. 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 5 of 100 change will take effect immediately upon approval by the Board of Supervisors. Presented By: Philip A. McNeely, R.G., Director Prepared By: Planning and Analysis Division Attachments: Preamble required by Arizona Revised Statutes (A.R.S.) § 49-471.07 (See the Draft Notice of Final Rulemaking) Summary of the proposed regulatory change (See Item 4 of the Draft Notice of Final Rulemaking) Analysis of input received during the process and how that input was responded to (See Item 9 of the Draft Notice of Final Rulemaking) Language of proposed regulatory change or amendment (See the Draft Notice of Final Rulemaking) Strikethrough/underline of Draft Rule 331 Clean version of Draft Rule 331 Minutes from Board of Health meeting - August 28, 2023 Minutes from Board of Health meeting - July 22, 2024 Copies of all written and electronic Stakeholder input Maricopa County • Air Quality Department • Report the the Board of Supervisors 6 of 100 Maricopa County Air Quality Department Planning and Analysis Division Draft Notice of Final Rulemaking Rule 331 (Solvent Cleaning) September 2024 Draft Notice of Final Rulemaking Maricopa County Air Pollution Control Regulations Regulation III – Control of Air Contaminants Rule 331 (Solvent Cleaning) The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 331 (Solvent Cleaning). 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 8 of 100 First Stakeholder Workshop: June 20, 2023 Second Stakeholder Workshop: December 13, 2023 Board of Health Meeting to Initiate Regulatory Change: August 28, 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 331 (Solvent Cleaning) is to limit volatile organic compound (VOC) emissions from solvent cleaning operations. The last significant revision to the rule occurred in 2004. MCAQD is proposing to revise Rule 331 to remove a reasonably available control technology (RACT) deficiency identified by the U.S. Environmental Protection Agency (EPA) so Rule 331 can be approved into the Arizona State Implementation Plan (SIP) as meeting 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 (NAAQS). Sections 182(b)(2) and (f) of the Clean Air Act (CAA) require jurisdictions that are classified as “moderate” or higher nonattainment for ozone to implement RACT for all sources subject to a Control Techniques Guideline (CTG) as well as for all non-CTG major sources of VOCs or nitrogen oxides (NOx). In response to the reclassification, the MCAQD reviewed all rules associated with a CTG source category to determine if the rules meet RACT. During the analysis, MCAQD determined Rule 331 (Solvent Cleaning) does not meet RACT. Although Rule 331 is considered as stringent or more stringent than the two CTG source categories it is associated with, it contains an exemption that the EPA has determined is a deficiency. Rule 331 exempts all operations regulated by National Emission Standards for Halogenated Solvent Cleaning (40 CFR 63, Subpart T). This exemption precludes Rule 331 from satisfying the CAA section 182(b)(2) RACT requirement. Section 182(b)(2) requires that RACT be implemented through SIP-approved rules and reliance on rules outside the SIP such as a National Emission Standard for Hazardous Air Pollutants (NESHAP) for the implementation of RACT is insufficient. NESHAPs are separate obligations under the CAA and may be less stringent than RACT if the NESHAP is outdated. Therefore, removing the NESHAP exemption will ensure Rule 331 meets RACT. Return to list of attachments Maricopa County • Air Quality Department • Report the the Board of Supervisors 9 of 100 In addition, MCAQD is proposing other revisions to the rule including lowering the VOC content limit in the definition of Low-VOC Cleaner from 50 grams of VOC per liter to 25 grams of VOC per liter as well as restructuring the rule for clarity purposes. MCAQD plans to replace SIP Rule 34, Sections F-K (Organic Solvents – Volatile Organic Compounds (VOC)) and current SIP Rule 331 with the revised rule to update the SIP and clarify regulatory requirements. 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 twofold. First, this rulemaking will revise Rule 331 to remove a RACT deficiency identified by the EPA in order to ensure the rule can be approved into the SIP as meeting RACT. Second, MCAQD plans to replace SIP Rule 34, Sections F-K with the revised rule in order to eliminate the regulatory gap where sources are subject to different federal and county rules for the same activity. (a) The conduct and its frequency of occurrence that the rule is designed to change (A.R.S. § 41-1055(A)(1)(a)). MCAQD is proposing to revise Rule 331 to remove a deficiency identified by the EPA in order to have the rule approved into the SIP as meeting RACT while also replacing SIP Rule 34, Sections F-K. (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 reviewed all rules associated with a CTG source category to determine if the rules meet RACT. During the analysis, MCAQD determined Rule 331 does not meet RACT. In order to comply with Sections 182(b)(2) and (f) of the CAA, MCAQD is required to revise Rule 331 to ensure the rule implements RACT. 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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 10 of 100 (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 331 to remove a deficiency identified by the EPA in order to have the rule approved into the SIP as meeting RACT while also replacing SIP Rule 34, Sections F-K. 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 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 that use VOC- containing solvents to remove impurities from exterior or interior surfaces and are not exempt as detailed in Section 104 of the draft rule. Partial exemptions apply to certain operations and application methods. A cost benefit analysis of the following: (a) The probable costs and benefits to the implementing agency and other agencies directly affected by the implementation and enforcement of the proposed rulemaking (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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 11 of 100 (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 political subdivisions of this state affected by the proposed rulemaking. (c) The probable costs and benefits to businesses directly affected by the proposed rulemaking, including any anticipated effect on the revenues or payroll expenditures of employers who are subject to the proposed rulemaking (A.R.S. § 41-1055(B)(3)(c)). For businesses currently using a low-VOC cleaner of 50 g/L, compliance with the revised Rule 331 may involve some additional costs related to purchasing Rule 331- compliant low-VOC cleaner of 25 g/L. For businesses that are complying with one of the solvent specification requirements in Section 302.1 or using solvent that meets the new 25 g/L VOC content limit, there would be no additional cost. 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)). Small businesses subject to this rulemaking are those facilities in Maricopa County that use VOC-containing solvents which do not fall under the exemptions in Section 104 of the draft rule included in this notice. (b) The administrative and other costs required for compliance with the proposed rulemaking (A.R.S. § 41-1055(B)(5)(b)). For businesses currently using a low-VOC cleaner of 50 g/L, compliance with the revised Rule 331 may involve some additional costs related to purchasing Rule 331- compliant low-VOC cleaner of 25 g/L. For businesses that are complying with one of the solvent specification requirements in Section 302.1 or using solvent that meets the new 25 g/L VOC content limit, there would be no additional cost. (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)). Maricopa County • Air Quality Department • Report the the Board of Supervisors 12 of 100 Most of the proposed revisions are intended to enhance or clarify Rule 331 and should not impose any significant new compliance requirements on small businesses. Proposed revisions to Rule 331 do not establish any significant new reporting requirements for small businesses. The rulemaking does propose lowering the VOC content limit for low-VOC cleaners from 50 g/L to 25 g/L. Outreach with affected stakeholders has been conducted, including two stakeholder workshops, citizen comment opportunities, and the proposed revisions were presented at two Board of Health public meetings on August 28, 2023 and July 22, 2024. During the rulemaking process, MCAQD has received one citizen comment related to the low-VOC cleaner limitation and determined that there would be no economic impact on the stakeholder who submitted the comment. There have been no further citizen comments notifying MCAQD that there would be any significant impact on small businesses due to the proposed revisions. 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 schedule requirements on small businesses and does not establish any significant new reporting requirements for small businesses. iii. Consolidate or simplify the rule's compliance or reporting requirements for small businesses (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. v. Exempt small businesses from any or all requirements of the rule (A.R.S. § 41- 1035(5)). This rulemaking contains partial and full exemptions as outlined in Sections 103 and 104 of the draft rule. (d) The probable cost and benefit to private persons and consumers who are directly affected by the proposed rulemaking (A.R.S. § 41-1055(B)(5)(d)). This rulemaking should not result in any significant costs for private persons and consumers. Maricopa County • Air Quality Department • Report the the Board of Supervisors 13 of 100 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 331 to remove a deficiency identified by the EPA in order to have the rule approved into the SIP as meeting RACT while also replacing SIP Rule 34, Sections F-K. Failure to remove the deficiency 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)). 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 14 of 100 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 331 meets A.R.S. § 49- 112(A)(1) by demonstrating that the rule is necessary to address a peculiar local condition, in that Maricopa County fails to meet the 2015 8-hour NAAQS for ozone. Rule 331 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 solvent cleaning industry. As there is no new fee or tax associated with this proposed rulemaking, the MCAQD also affirms that Rule 331 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: June 6, 2023 Notice of First Board of Health Meeting: July 7, 2023 Notice of Second Stakeholder Workshop: November 29, 2023 Notice of Proposed Rulemaking: June 5, 2024 Notice of Second Board of Health Meeting: July 8, 2024 Maricopa County • Air Quality Department • Report the the Board of Supervisors 15 of 100 (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. Revised the partial exemption for wipe cleaning in Section 103.1. The section now reads as follows: “Wipe cleaning is only subject to Sections 301.1 and 501 of this rule.” 2. Removed the categorical exemption previously listed under Section 104.1(e) regarding industries and cleaning operations that are not regulated by Rule 331 and adjusted formatting under Section 104. 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 214. This section now reads as follows: “The freeboard height divided by the smaller of either the length or width of the solvent cleaning machine.” ii. A summary of the comments and arguments for and against the notice and the county’s response to the comments and arguments. 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 Return to list of attachments Maricopa County • Air Quality Department • Report the the Board of Supervisors 16 of 100 comments from three stakeholders. All of the comments were reviewed and evaluated by MCAQD. Comment #1: Below please find NXP’s input regarding proposed revisions to Rule 330 (Volatile Organic Compounds (VOCs)) and Rule 331 (Solvent Cleaning). We suggest the following modifications to the draft rules 330 and 331 to ensure consistency between these two rules as well as Rule 338 (Semiconductor Manufacturing): Modify section 502.3 of rule 331 to match section 502.3 in rule 330 and 338: 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 3 business days of the maintenance completion. Response #1: MCAQD evaluated your comment and agrees with the suggestion. The proposed language has been incorporated into the draft rule. Comment #2: I apologize in that I missed the initial outreach meeting on this rulemaking action. My comment pertains to the change in the definition of low VOC from 50 grams/liter to 25 grams/liter. This is quite a dramatic change to an already low VOC content, and I was not able to find any technical or economic analysis of this change. Unless this change can be shown to be both economically and technically feasible, it should not be made. Please provide the justification for this change showing that it is reasonable and there are products on the market that can accomplish the cleaning objectives at an affordable cost. Response #2: MCAQD evaluated your comment and will maintain the proposed VOC content of 25 grams/liter in the definition for “Low-VOC Cleaner”. Research conducted showed other districts classified as moderate nonattainment areas for the 8- hour ozone National Ambient Air Quality Standards have incorporated the 25 g/L VOC content standard in their solvent cleaning rules. Examples include Yolo-Solano Air Quality Management District – Rule 2.31 (Solvent Cleaning, revised July 14, 2021) and the State of New York, Department of Environmental Conservation – 6 CRR-NY 226-1.4 (Solvent Cleaning Processes and Industrial Cleaning Solvents, revised November 1, 2019). Furthermore, the 25 g/L VOC content standard has been implemented in solvent cleaning rules in the following districts: • San Joaquin Valley Air Pollution Control District - Rule 4663 (Solvent Cleaning, revised September 20, 2007) Maricopa County • Air Quality Department • Report the the Board of Supervisors 17 of 100 • South Coast Air Quality Management District - Rule 1122 (Solvent Degreasers, revised May 1, 2009) and Rule 1171 (Solvent Cleaning Operations, revised May 1, 2009) • Ventura County Air Pollution Control District - Rule 74.6 (Surface Cleaning and Degreasing, revised November 10, 2020) • San Diego Air Pollution Control District - Rule 67.6.1 (Cold Solvent Cleaning and Stripping Operations, revised February 10, 2021) • Antelope Valley Air Quality Management District - Rule 1171 (Solvent Cleaning Operations, revised August 21, 2018) • Sacramento Air Quality Management District - Rule 466 (Solvent Cleaning, revised October 28, 2010) The fact that many air quality districts, including districts nearby, have already implemented the lower standard indicates the availability of the products that comply with the proposed limit. In addition, MCAQD has received only one comment regarding the proposed revision (Comment #2) and through discussion with the commenter it was determined the commenter could comply with the Rule 331 solvent specification requirements through an alternative compliance option in Rule 331, using a conforming solvent. A conforming solvent is a cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) not exceeding 1.0 millimeter of mercury column (mm Hg). MCAQD conducted a survey regarding solvent usage among permitted facilities within Maricopa County from September 2021 through August 2022. Information was obtained during routine inspections for permitted facilities that conduct solvent cleaning operations. Results reflected the majority of the facilities conducting non-vapor cleaning operations (operations subject to the solvent specification requirements) used a conforming solvent to comply with the solvent specification requirements in Rule 331. Comment #3: 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. Response #3: During the Rule 331 and Rule 338 (Semiconductor Manufacturing) rulemaking processes, solvent cleaning provisions related to semiconductor manufacturing activities were proposed to be removed from Rule 338 and relocated to Rule 331. Comment numbers 3 through 6 were all received from Maricopa County • Air Quality Department • Report the the Board of Supervisors 18 of 100 stakeholders in the semiconductor industry when solvent cleaning provisions related to semiconductor manufacturing were proposed to be relocated to Rule 331. After working with EPA, affected stakeholders, and internal staff, it was decided to keep solvent cleaning provisions related to semiconductor manufacturing in Rule 338. Based on this information, there will be no revisions to Rule 331 related to semiconductor manufacturing operations. Comment #4: 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. Response #4: See Response #3. Comment #5: 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. Response #5: See Response #3. Comment #6: 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 that are most significant in Maricopa County and as discussed meeting the intent of the exemption? Maricopa County • Air Quality Department • Report the the Board of Supervisors 19 of 100 • 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? • In conclusion adding 3674 SIC Code to 103.3 may clarify the Partial Exemptions in Proposed New Rule 331, 103. Response #6: See Response #3. Exact Wording of the Rule MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III – CONTROL OF AIR CONTAMINANTS RULE 331 (SOLVENT CLEANING) INDEX SECTION 100 – GENERAL 101 PURPOSE 102 APPLICABILITY 308 103 PARTIAL EXEMPTIONS 308 104 TOTAL CATEGORICAL EXEMPTIONS SECTION 200 – DEFINITIONS 201 AGITATION, AGITATED 202 BATCH CLEANING MACHINE 203 BLASTING/MISTING WITH SOLVENT 204 CABINET STYLE CLEANING MACHINES 205 CARRY-OUT 206 CLEANING-SOLVENT Return to list of attachments Maricopa County • Air Quality Department • Report the the Board of Supervisors 20 of 100 207 CONFORMING SOLVENT 208 DEGREASER 208 DIP TANK 209 DRY SOLID 210 EMISSION CONTROL SYSTEM (ECS) 211 FILTRATION DEVICE 211 212 FLUSHING WITH SOLVENT 212 213 FREEBOARD HEIGHT 213 214 FREEBOARD RATIO 215 FULLY SUBMERGED 214 216 HEATED SOLVENT 215 217 IMPERVIOUS 216 218 IN-LINE CLEANING MACHINE (CONTINUOUS CLEANING MACHINE) 217 219 JANITORIAL CLEANING 218 220 LEAK 219 221 LOW-VOC CLEANER 220 222 MAKE-UP SOLVENT 221 MATERIAL VOC CONTENT 222 223 NON-CONFORMING SOLVENT 224 NON-VAPOR CLEANING MACHINE 223 ORGANIC COMPOUND 225 PARTS PER MILLION BY VOLUME DRY (PPMVD) 224 226 REFRIGERATED FREEBOARD CHILLER 225 227 REMOTE RESERVOIR CLEANING MACHINE (DEGREASER) 226 228 SEALED SYSTEM 229 SMALL CLEANER 227 230 SOLVENT 228 SOLVENT CLEANING MACHINE (CLEANING MACHINE) (DEGREASER) 229 231 SOLVENT/AIR INTERFACE 230 232 SOLVENT/AIR INTERFACE AREA 231 233 TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 232 234 VAPOR CLEANING MACHINE Appx I 235 VAPOR LEVEL CONTROL SYSTEM Maricopa County • Air Quality Department • Report the the Board of Supervisors 21 of 100 233 236 VOC CONTENT OF MATERIAL 234 237 WIPE CLEANING SECTION 300 – STANDARDS 301 GENERAL REQUIREMENTS FOR SOLVENT CLEANING OPERATIONS SOLVENT HANDLING REQUIREMENTS 302 NON-VAPOR CLEANING MACHINE REQUIREMENTS EQUIPMENT REQUIREMENTS FOR ALL CLEANING MACHINES 303 VAPOR CLEANING MACHINE REQUIREMENTS SPECIFIC OPERATING & SIGNAGE REQUIREMENTS FOR CLEANING MACHINES 304 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS SOLVENT SPECIFICATIONS FOR NON-VAPOR CLEANING AND DEGREASING 305 NON-VAPOR BATCH CLEANING MACHINES 306 NON-VAPOR IN-LINE CLEANING MACHINES 307 SPECIAL NON-VAPOR CLEANING SITUATIONS 308 EXEMPTIONS 309 REQUIREMENTS FOR AIR POLLUTION CONTROL EQUIPMENT AND ECS MONITORING EQUIPMENT SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE) 401 COMPLIANCE SCHEDULE SECTION 500 – MONITORING AND RECORDS 501 RECORDKEEPING AND REPORTING 502 ECS RECORDKEEPING REQUIREMENTS 502 503 COMPLIANCE DETERMINATION AND TEST METHODS APPENDIX TO RULE 331 VAPOR CLEANING MACHINES AND EMISSION CONTROL SYSTEMS Maricopa County • Air Quality Department • Report the the Board of Supervisors 22 of 100 Revised 07/13/88; Revised 06/22/92; Revised 06/19/96; Revised 04/07/99; Revised 04/21/04; Revised 09/25/13; Revised MM/DD/YYYY MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III – CONTROL OF AIR CONTAMINANTS RULE 331 (SOLVENT CLEANING) SECTION 100 – GENERAL 101 PURPOSE: To limit the emissions of volatile organic compounds (VOCs) from solvent cleaning operations. 102 APPLICABILITY: This rule is applicable to operations using VOC-containing solvents to remove impurities from exterior or interior surfaces. Compliance with the provisions of this rule shall not relieve any person subject to the requirements of this rule from complying with any other federally enforceable requirements. In such case, the more stringent requirement shall apply. In any instance where more than one of the requirements set forth in this rule may be applicable, the most restrictive requirement shall apply. 102.1 NSPS & NESHAP: 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 Maricopa County Air Pollution Control Regulations (MCAPCR). Solvents regulated by this rule may also be regulated by New Source Performance Standards (NSPS) in Rule 360 of these rules and/or National Emission Standards for Hazardous Air Pollutants (NESHAPs) in Rule 370 of these rules. 308.5 102.2 Vehicle Refinishing: Dip cleaning of vehicle or mobile equipment surfaces is subject to this rule. 308.1c(2) 102.3 Aerospace: Wipe cleaning of aerospace components is subject to Rule 348 (Aerospace Manufacturing and Rework Operations) of the MCAPCR these rules, whereas the cleaning of aerospace components in a dip tank or a cleaning machine is subject to this rule Rule 331. 102.3 Partial or conditional exemptions from this rule are set forth in Section 308 of this rule. 308.2 103 PARTIAL EXEMPTIONS from Section 300: The following are exempt from sections of Section 300 of this rule as noted: 308.2a 103.1 Wipe Cleaning: Wipe cleaning is only subject to Sections 301.1 and 501 of this rule. The provisions of Sections 302 through 307 of this rule do not apply to wipe cleaning. Recordkeeping Provisions in Section 500 of this rule do apply to wipe cleaning. Maricopa County • Air Quality Department • Report the the Board of Supervisors 23 of 100 308.2b 103.2 Small Cleaners: The provisions of Sections 301.3 through 302.4 303 through 307 of this rule shall not apply to any non-vapor small cleaners with either a maximum capacity of one gallon or less, or a liquid surface area of one square foot or less, except that these shall be covered when work is not being processed. cleaning machine (degreaser) or dip-tank fitting either of the following descriptions, except that these shall be covered when work is not being processed: (1) A small cleaner having a liquid surface area of 1 square foot (0.09 square meters) or less, or (2) A small cleaner having a maximum capacity of one gallon (3.79 liters) or less. 308.3 103.3 Standard Industrial Classification (SIC) Codes Exemptions from Section 302.1 304: The U.S. Government Printing Office “Standard Industrial Classification Manual, 1987” (and no future editions) is incorporated by reference and is on file at the Maricopa County Air Quality Department. The following SIC codes are exempt from Section 302.1 304 of this rule: a. Electronic products for space vehicles and communications equipment in Industry Group 366 (Communications Equipment): SIC codes 3661, 3663, and 3669. b. Industry Group 367 (Electronic Components And Accessories): SIC codes 3677, 3678, and 3679. c. Industry Group 376 (Guided Missiles And Space Vehicles And Parts): SIC code 3769. d. Non-furniture medical devices included in Standard Industrial Classification Industry Group 384 (Surgical, Medical, And Dental Instruments And Supplies): (SIC) codes 3841, 3843, 3844, or 3845, and products for internal use in 3842. The U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) “Standard Industrial Classification (SIC) Manual” can be found on the OSHA website at: https://www.osha.gov/data/sic-manual. 308.3(c) 103.4 Production processes having clean-room standards equal to or more stringent than clean room classification ISO 14644-1:2015 (Class 8) are exempt from Section 302.1 of this rule. class 100,000 (particles/m 3); and 308.3(d) 103.5 Low viscosity solvent used to clean an aerospace component if the Federal Aviation Authority, the U.S. Department of Defense, or a U.S. Military specification designates that the cleanliness of the component is critical to the flight safety of a complete aerospace vehicle are exempt from Section 302.1 of this rule. By January 1, 2001, Any such solvents shall be listed in a Maricopa County Air Pollution Permit, conditioned upon a sufficient demonstration by the user that no compliant substitute exists. 308.4 Comfort Fans: The Section 303.1(a) prohibition against fans and fan-drafts being close to cleaning machines does not apply to a totally enclosed cleaning machine that cannot be penetrated by drafts. Maricopa County • Air Quality Department • Report the the Board of Supervisors 24 of 100 308.6 103.6 Aerosol cans, squirt bottles, and other solvent containers intended for handheld use shall meet the requirements in Sections 301.1 and 500 of this rule. 308.7 103.7 A Low-VOC Cleaner is subject only to Sections 301.1, 301.2, 302.5(a), 501.5(a), and 501.6 301, 302, 307.1, 501.1(a), and 501.2 of this rule. 104 TOTAL CATEGORICAL EXEMPTIONS: This rule does not apply to: 102.2 a. 104.1 A solvent cleaning operation that is subject to or specifically exempted by an EPA State Implementation Plan (SIP) approved version of another rule within the MCAPCR Regulation III of these rules. b. 104.2 Janitorial cleaning. c. 104.3 Testing for surface cleanliness or the cleaning of laboratory equipment at the laboratory. d. 104.4 A cleaning-solvent that meets any of the following: (1) a. Is composed of at least 98% water by either weight or volume; or (2) b. Contains only water and material which is a dry solid before mixing with water; or (3) c. Has a VOC content not exceeding 20 grams per liter (0.17 lb/gal). 308.1 Categorical Exemptions: 308.1(a) Industries and cleaning operations that are not regulated by this rule include, but are not limited to, the following EPA approved versions of the VOC rules in Regulation III of these rules: (1) Dry cleaning with petroleum solvents (Rule 333); (2) Printing and graphic arts coating (Rule 337); (3) Semiconductor manufacturing (Rule 338); (4) Automotive windshield washer fluid (Rule 344); and (5) Architectural Coating (Rule 335). 308.1(b) 104.5 All operations regulated by the following NESHAPs are exempt from Rule 331: (1) National Emission Standards for Halogenated Solvent Cleaning (40 CFR 63, subpart T). This includes the de minimis amounts of solvent VOCs that are exempted by subpart T. All operations regulated by National Emission Standards for Perchloroethylene for Dry Cleaning Facilities (40 CFR 63, Subpart M). 308.1(c) 104.6 Exemptions for Qualified Operations: Cleanup of Coating-Application Equipment: Operations involving the cleanup of coating-application equipment that are subject to or specifically exempted by an EPA SIP-approved version of another source-specific rule within the MCAPCR Regulation III of these rules are exempt from Rule 331. Examples include Rule 336 (Surface Coating Operations and Industrial Adhesive Application Processes), Rule 342 (Coating Wood Furniture and Fixtures), and Rule 346 (Coating Wood Millwork). Maricopa County • Air Quality Department • Report the the Board of Supervisors 25 of 100 SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions shall apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of these rules. In the event of any inconsistency between any of the MCAPCR Maricopa County Air Pollution Control Rules, the definitions in this rule take precedence. 201 AGITATION, AGITATED: A means or state that moves cleaning liquid continuously back and forth, or up and down. This includes such motion created by sound waves, and to the splashing of a rinse stream operated at a pressure that creates a trajectory exceeding 2 feet along the horizontal plane intersecting the nozzle when the nozzle is at a 45° angle above the plane. Liquid motion incidental to a continuous entrance or withdrawal of objects undergoing cleaning is not agitation. 202 BATCH CLEANING MACHINE: A solvent cleaning machine in which individual parts or a set of parts move through the entire cleaning cycle before new parts are introduced into the solvent cleaning machine. A solvent cleaning machine, such as a ferris wheel or a cross-rod degreaser, that cleans multiple batch loads simultaneously and is manually loaded, is a batch cleaning machine. 203 BLASTING/MISTING WITH SOLVENT: Cleaning with an applicator that propels cleaning-solvent through the air with a pressure exceeding 10 psig (516 mm Hg), or that atomizes the solvent into mist and/or droplets. 204 CABINET STYLE CLEANING MACHINES: A solvent cleaning machines typically similar in design to domestic dishwashers that are completely enclosed except for optional stack and have their own reservoir and sump. 205 CARRY-OUT: Solvent carried out of a cleaning machine along with a part being removed from the cleaning machine. The solvent may exist as a liquid coating the part or the part’s hanger, or as a liquid entrapped in cavities and irregular surfaces or entrapped by capillary action within or on the part. 206 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). 207 CONFORMING SOLVENT: A cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) not exceeding 1 millimeter of mercury column (mm Hg). 208 DEGREASER: See SOLVENT CLEANING MACHINE. 208 DIP TANK: A container holding solvent used for dipping or coating an object. An object may be immersed in a dip tank, or it may be suspended in a vapor coming from the tank. 209 DRY SOLID: Any substance that appears and feels dry. Evaporating solids, all of which have a strong odor, are not included. 210 EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control Officer, to reduce for reducing emissions of volatile organic compounds. Such a system Maricopa County • Air Quality Department • Report the the Board of Supervisors 26 of 100 consists of an emissions collection system and an emissions processing subsystem. consisting of both a capture system and control device(s). 211 FILTRATION DEVICE: A filter composed of porous material (i.e., canvas bag) which collects and removes contaminants from solvent. 211 212 FLUSHING WITH SOLVENT: Introducing cleaning-solvent directly into the internal space(s) of an object or assembly using a hose or pipe. Rinsing the outside of an object or assembly and swishing an object or assembly in cleaning-solvent are not considered flushing with solvent. Such activities must comply with Section 301.3 303.1 of this rule. 212 213 FREEBOARD HEIGHT: 212.1 213.1 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, measured during idling mode. 212.2 213.2 In-Line Cleaning Machine: The vertical distance from the solvent/air interface to the lowest entry/exit point, measured during idling mode. 213 214 FREEBOARD RATIO: The freeboard height divided by the smaller of either the length or width of the solvent cleaning machine. The ratio of the solvent cleaning machine freeboard height to the smaller interior dimension (length, width, or diameter) of the solvent cleaning machine. 215 FULLY SUBMERGED: Any material or object which is maintained below the surface of the solvent with no portions exposed to the ambient air. 214 216 HEATED SOLVENT: Any cleaning-solvent which is heated by a device to a temperature exceeding 120° F (49° C). 215 217 IMPERVIOUS: Neither absorbing, adsorbing, nor allowing penetration through, by liquid or vapors. 216 218 IN-LINE CLEANING MACHINE (CONTINUOUS CLEANING MACHINE): A solvent cleaning machine that uses an automated handling system, typically a conveyor or automated arm(s), to automatically provide a continuous supply of items to be cleaned. The cleaned item leaves by a route different from its entry route. 217 219 JANITORIAL CLEANING: The cleaning of building or facility components to keep work areas in clean condition. Building or facility components include, but are not limited to, floors, ceilings, walls, windows, doors, stairs, bathrooms, furnishings, textiles, wash rags, uniforms, and exterior surfaces of office equipment. 218 220 LEAK: A visible cleaning-solvent liquid leak at a rate of three or more drops per minute, or a puddle greater than one square inch. The state or condition in which a cleaning-solvent, excluding a Low-VOC Cleaner, is allowed to seep or drip, or otherwise enters or escapes, at either of the following rate or magnitude: Maricopa County • Air Quality Department • Report the the Board of Supervisors 27 of 100 218.1 Three or more drops of liquid cleaning-solvent per minute; or 218.2 Any puddle of cleaning-solvent greater than 1 square inch. 219 221 LOW-VOC CLEANER: Any solution or homogeneous suspension that, as used, contains less than 25 50 grams of VOC per liter of material (0.21 0.42 lb VOC/gal) or is at least 95% water by weight or volume as determined by an applicable test method in Section 502 503 of this rule. 220 222 MAKE-UP SOLVENT: A cleaning-solvent that replaces solvent lost through evaporation or other means, and that is added to the solvent remaining in a cleaning machine (degreaser) to bring solvent quantity to the desired level. 221 MATERIAL VOC CONTENT: See VOC CONTENT OF MATERIAL. 222 223 NON-CONFORMING SOLVENT: A cleaning-solvent having a total VOC vapor pressure at 68°F (20°C) exceeding 1 millimeter of mercury column (mm Hg). 224 NON-VAPOR CLEANING MACHINE: SOLVENT CLEANING MACHINE (CLEANING MACHINE) (DEGREASER) Any liquid container and ancillary equipment designed to clean surfaces and/or remove surface contaminants using cleaning-solvents at temperatures that do not exceed the solvent boiling point. 223 ORGANIC COMPOUND: Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate. 225 PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express concentration that is corrected to a dry basis. 224 226 REFRIGERATED FREEBOARD CHILLER: A control device which is mounted above any cooling-water jacket or primary condenser coils, consisting of secondary coils which carry a refrigerant to provide a chilled air blanket above the solvent vapor/air interface to reduce emissions from the cleaning machine (degreaser) bath. 225 227 REMOTE RESERVOIR CLEANING MACHINE (DEGREASER): Any non-vapor cleaning machine (degreaser) in which the reservoir for storing the cleaning-solvent is completely separated by impervious surfaces from the sink or basin where cleaning is performed, except for a connecting tube or passage through which solvent returns to the reservoir when cleaning is stopped. 226 228 SEALED SYSTEM: An Air-tight or Airless Cleaning System that is operated and equipped pursuant to Section 302.1(c) 304.3 of this rule. 308.2b 229 SMALL CLEANER: A cleaning machine that has a liquid surface area of 1 square foot (0.09 square meters) or less or has a maximum capacity of one gallon (3.79 liters) or less. 227 230 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 28 of 100 surfaces or from internal spaces and voids. In addition to VOC-containing solvents, this also includes plain water and mixtures containing water. 228 SOLVENT CLEANING MACHINE (CLEANING MACHINE) (DEGREASER): Any liquid container and ancillary equipment designed to clean surfaces and/or remove surface contaminants using cleaning-solvents. 229 231 SOLVENT/AIR INTERFACE: 229.1 231.1 Non-Vapor Cleaner: The location of contact between the liquid solvent and the air. 229.2 231.2 Vapor Cleaner: The location of contact between the concentrated layer of solvent vapor and the air. 230 232 SOLVENT/AIR INTERFACE AREA: 230.1 232.1 Non-Vapor Cleaner: a. With Included/Integral Reservoir: The surface area of liquid cleaning-solvent that is exposed to the air. b. With Remote Reservoir: The surface area of the solvent sink or work area. 230.2 232.2 Vapor Cleaner: The area of the horizontal plane that is located halfway between the highest and lowest points of the primary condenser coils and which contacts the interior walls of the cleaning machine. 231 233 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 503.1(f) 502.3 of this rule. 232 234 VAPOR CLEANING MACHINE: Any batch or in-line cleaning machine in which solvent- vapor from boiling cleaning-solvent is utilized for cleaning an object. Appx I 235 VAPOR LEVEL CONTROL SYSTEM: A combination of a coolant sensing system and a vapor sensing system consisting of the following three sets of features: 235.1 A condenser flow switch and thermostat which shuts off the sump heat if either the condenser coolant stops circulating or becomes warmer than 85° F (29° C); and 235.2 A manually-reset safety switch which turns off the sump heater if the temperature sensor senses that the temperature is rising above the designed operating level at the vapor/air interface; and 235.3 A manually-reset switch which turns off the spray-system pump if the level of the vapor/air interface drops more than 4 inches (10 cm). 233 236 VOC CONTENT OF MATERIAL (MATERIAL VOC CONTENT): The weight of VOC per volume of material, as calculated according to the formula in Section 503.1(g) of this rule. Maricopa County • Air Quality Department • Report the the Board of Supervisors 29 of 100 234 237 WIPE CLEANING: That A cleaning method of removing contaminants from a surface by physically rubbing or automatically rubbing with a porous or absorbent material, such as a rag, paper, sponge, or cotton swab, moistened with a solvent. SECTION 300 – STANDARDS 301 GENERAL REQUIREMENTS FOR SOLVENT CLEANING OPERATIONS SOLVENT HANDLING REQUIREMENTS: An owner or operator subject to Any person to whom this rule applies must shall comply with all of the following: 301.1 Solvent Handling Requirements: All cleaning-solvent, including solvent soaked materials, shall be kept in closed, leak free, impervious containers that are opened only when adding or removing material. a. Porous or absorbent materials used for wipe cleaning shall be stored in closed containers when not in use. b. Each container shall be clearly labeled with its contents. 301.2 If any cleaning-solvent escapes from a container: 301.2(a) c. Wipe up or otherwise remove any cleaning-solvent that escapes from a container immediately if in accessible areas. 301.2(b) d. For areas where access is not feasible during normal production, remove any cleaning-solvent that escapes from a container as soon as reasonably possible. e. Disposal of waste or surplus solvent 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. 301.3 Unless records show that VOC-containing cleaning material was sent offsite for legal disposal, it will be assumed that it evaporated on site. 302 301.2 Equipment Requirements for All Cleaning Machines: Any person owner or operator who is operating a cleaning machine to which this rule applies must comply with all of the following: 302.1(a) a. Provide a leak free, impervious container (degreaser) for the solvents and the articles being cleaned. The VOC-containment portion shall be impervious to VOC-containing liquid and vapors. 302.1(b) b. No surface of any freeboard required by this rule shall have an opening or duct through which VOC can escape to the atmosphere, except as controlled by an ECS, or as required by OSHA. 302.2 c. Properly maintain and operate all cleaning machine equipment required by this rule and any of its emission controls required by this rule. 303 SPECIFIC OPERATING & SIGNAGE REQUIREMENTS FOR CLEANING MACHINES: 303.1 301.3 Operating Requirements for Cleaning Machines: Any person owner or operator who cleans with cleaning-solvent, other than a Low-VOC Cleaner, must comply Maricopa County • Air Quality Department • Report the the Board of Supervisors 30 of 100 with conform to all of the following operating requirements for cleaning machines: a. Fans: Do not locate nor position comfort fans in such a way as to direct airflow across the opening of any cleaning machine. This prohibition does not apply to a totally enclosed cleaning machine that cannot be penetrated by drafts. b. Cover: Do not remove any device designed to cover the solvent unless processing work in the cleaning machine or maintaining the machine. c. Draining: Drain cleaned parts for at least 15 seconds after cleaning or until dripping ceases, whichever is later. d. Spraying: If using a cleaning-solvent spray system, (1) Use only a continuous, undivided stream (not a fine, atomized, or shower type spray). (2) Pressure at the orifice from which the solvent emerges shall not exceed 10 psig and shall not cause liquid solvent to splash outside of the solvent container. (3) In an in-line cleaning machine, a shower-type spray is allowed, provided that the spraying is conducted in a totally confined space that is separated from the environment. (4) Provisions for exceptions to foregoing Sections 303.1 301.3(d)(1), (2), and (3) are provided for in Section 302.5 307 of this rule. e. Agitation: No person An owner or operator shall not cause agitation of a cleaning-solvent in a cleaning machine by sparging with air or other gas. Covers shall be placed over ultrasonic cleaners when the cleaning cycle exceeds 15 seconds. f. No Porous Material: (1) Do not clean nor use porous or absorbent materials to clean parts or products in a cleaning machine. For the purpose of this rule, porous or absorbent materials include, but are not limited to, cloth, leather, wood, and rope. (2) Do not place an object with a sealed wood handle, including a brush, in or on a cleaning machine. (3) Do not place porous or absorbent materials, including, but not limited to, cloth, leather, wood, and rope on a cleaning machine. g. Vent Rates: The ventilation rate at the cleaning machine shall not exceed 65 cfm per square foot of evaporative surface (20 m 3/min./m 2), unless that rate must be changed to meet a standard specified and certified by a Certified Safety Professional, a Certified Industrial Hygienist, or a licensed professional engineer experienced in ventilation, to meet health and safety requirements. h. Hoist Speed: Limit the vertical speed of mechanical hoists moving parts in and out of the cleaning machine to a maximum of 2.2 inches per second and 11 ft/min. (3.3 m/min.). Maricopa County • Air Quality Department • Report the the Board of Supervisors 31 of 100 i. Contamination Prevention: Prevent cross contamination of solvents regulated by Section 302.1 304 of this rule with low-VOC cleaners solvents that are not so regulated. Use signs, separated work-areas, or other effective means for this purpose. This includes those spray gun cleaning-solvents that are regulated by another source-specific rule within Maricopa County Rules of Regulation III these rules. j. Filtration Devices: If a filtration device (e.g., to remove oils, greases, sludge, and fine carbon from cleaning-solvent) is inherent in the design of the cleaning machine, then such filtration device shall be operated in accordance with manufacturer’s specifications and in accordance with the following requirements: (1) The filtration device shall be operated in accordance with manufacturer’s specifications. (2) The filtration device shall be maintained under the protective shelf in the wash basin, when applicable. 303.1(j)(1) (3) The filtration device shall be fully submerged in cleaning-solvent at all times during filtration. 303.1(j)(2) (4) When the filtration device is completely saturated and must be removed from the cleaning machine, the filtration device shall be drained until no liquid can flow from the filtration device. Draining and drying such filtration device shall be conducted in a sealed container with no exhaust to the atmosphere or work area. 303.1(j)(3) (5) After the filtration device is dry, the filtration device shall be stored in a closed, leak free, impervious container that is legibly labeled with its contents and that remains covered when not in use. Disposal of the filtration device shall be done in a manner that inhibits VOC evaporation and that is in compliance with appropriate/legal methods of disposal. 303.2 301.4 Signage Requirements: Any person owner or operator who uses cleaning- solvent, other than Low-VOC Cleaner, in any solvent cleaning machine (degreaser) or dip tank shall provide on the machine, or within 3¼ feet (1 meter) of the machine, a permanent, conspicuous label or placard which includes, at a minimum, each of the following applicable instructions, or its equivalent: a. “Keep cover closed when parts are not being handled.” (This is not required for remote reservoir cleaners.) b. “Drain parts until they can be removed without dripping.” c. “Do not blow off parts before they have stopped dripping.” d. “Wipe up spills and drips as soon as possible; store used spill rags [or ‘wiping material’] in covered container.” e. “Don’t clean porous or absorbent materials in this tank.” “Don’t leave cloth or any absorbent materials in or on this tank.” Maricopa County • Air Quality Department • Report the the Board of Supervisors 32 of 100 f. For cleaning machines with moving parts such as hoists, pumps, or conveyors, post: “Operating instructions can be obtained from _______,” listing a person or place where the instructions are available. 304 302 SOLVENT SPECIFICATIONS FOR NON-VAPOR CLEANING MACHINE REQUIREMENTS AND DEGREASING: 302.1 Solvent Specifications for Non-Vapor Cleaning Machines: [Operating requirements specifically for vapor cleaning machines are in the Appendix.] All cleaning-solvents, except Low-VOC Cleaners, used in non-vapor non-boiling cleaning machines shall comply with one of the following requirements Section 304.1 or Section 304.2 or Section 304.3, as follows: 304.1 a. Conforming Solvent: Use a cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) not exceeding 1.0 millimeter of mercury column (mm Hg), as determined by the standards described in Section 500 of this rule; or 304.2 b. ECS: Use an ECS to capture and process VOC emissions in accordance with Section 304 IV of the Appendix within this rule; or 304.3 c. Sealed System: Use a Sealed System that is an Air-tight or Airless Cleaning System which is operated according to the manufacturer’s specifications and, unless otherwise indicated by the manufacturer, meets all of the following requirements: (1) Has a door or other pressure-sealing apparatus that is shut during each cleaning and drying cycle; and (2) Has a differential pressure gauge that always indicates the pressure in the sealed chamber when occupied or in active use; and (3) Any associated pressure relief device(s) shall be so designed and operated as to prevent liquid cleaning-solvents from draining out. 305 302.2 Non-Vapor Batch Cleaning Machines: An owner or operator who operates a non- vapor batch cleaning machine shall comply with the following requirements (Low-VOC Cleaners are exempt from this section): Equipment requirements for non-vapor batch cleaning machines with remote reservoirs are set forth in Section 305.1 of this rule. Equipment standards applicable to non-vapor batch cleaning machines with internal reservoirs (non- remote) are set forth in Section 305.2 of this rule. Non-vapor batch cleaning machines with either remote or internal reservoirs that use cleaning-solvents that are either heated, agitated or non-conforming are subject to additional provisions set forth in Section 305.3 of this rule. 305.1 a. With Remote Reservoir: A batch cleaning machine with remote reservoir, including cabinet type(s), shall be equipped with all of the following: 305.1(a) (1) A sink-like work area or basin which is sloped sufficiently towards the drain so as to prevent pooling of cleaning-solvent. Maricopa County • Air Quality Department • Report the the Board of Supervisors 33 of 100 305.1(b) (2) A single, unimpeded drain opening, or cluster of openings served by a single drain for the cleaning-solvent to flow from the sink into the enclosed reservoir. Such opening(s) shall be contained within a contiguous area not larger than 15.5 square inches (100 cm 2). 305.1(c) (3) Solvent Return: Provide a means for drainage of cleaned parts such that the drained solvent is returned to the cleaning machine. 305.2 b. With Internal Reservoir (Non-Remote): A batch cleaning machine without a remote reservoir shall be equipped with all of the following: 305.2(a) (1) Have and use an internal drainage rack or other assembly that confines within the freeboard all cleaning-solvent dripping from parts and returns it to the hold of the cleaning machine (degreaser); and 305.2(b) (2) Have an impervious cover which when closed prevents cleaning-solvent vapors in the cleaning machine from escaping into the air/atmosphere when not processing work in the cleaning machine. 305.2(b)(1) (a) A cover shall be fitted so that in its closed position the cover is between the cleaning-solvent and any lip exhaust or other safety vent, except that such position of cover and venting may be altered by an operator for valid concerns of flammability established in writing and certified to by a Certified Safety Professional or a Certified Industrial Hygienist to meet health and safety requirements. 305.2(b)(2) (b) A cover is not required when an ECS is used in accordance with Section 304 IV of the Appendix within this rule. 305.2(c) (3) In the absence of additional applicable freeboard standards, freeboard height shall be not less than 6 inches (15.2 cm); and 305.2(d) (4) The freeboard zone shall have a permanent, conspicuous mark that locates the maximum allowable solvent level which conforms to the applicable freeboard requirements. 305.3 c. Using Cleaning-Solvent that is Heated, or Agitated in a Non-Vapor Batch Cleaning Machine, or is Non-Conforming: If a non-vapor batch cleaning machine uses a cleaning-solvent at a temperature above 120° F (49° C), or agitates the solvent, or uses non-conforming solvent if allowed by Section 305.3(d) of this rule, then comply with one of the following: 305.3(a) (1) Remote Reservoir Cleaning Machines: For a remote reservoir cleaning machine, comply with Section 305.1 302.2(a) of this rule and one of the following: (a) Use a stopper in the drain whenever the sink or cabinet is empty of solvent and nothing is being handled in the sink; or (b) Cover the sink or cabinet whenever the sink or cabinet is empty of solvent and nothing is being handled in the sink. Maricopa County • Air Quality Department • Report the the Board of Supervisors 34 of 100 305.3(b) (2) Internal Reservoir Cleaning Machines: For an internal reservoir cleaning machine, comply with Section 305.2 302.2(b) of this rule and one of the following either Section (1) or (2) that follow: (a) A Water Cover: A floating layer of water (insoluble in the solvent) at least 1 inch thick, and a freeboard at least 6 inches above the top of the solvent shall be present; or (b) Freeboard and Cover: (i) The basin shall have a freeboard ratio of 0.75 or greater and an impervious cover shall cover the basin whenever work is not being processed; and (ii) If a non-conforming solvent is used, the cover shall be of a sliding or rolling type which is designed to easily open and close in a horizontal plane without disturbing the vapor zone. 305.3(c) (3) Cabinet Style: Keep a cabinet-style cleaning machine that it contains cleaning-solvent closed at all times, except when introducing or removing work from the machine. If blasting or misting with cleaning-solvent, also conform to the applicable requirements of Section 307 302.5 of this rule. 305.4 d. ECS Alternative: In lieu of meeting the requirements in Sections 302.2(a), 302.2(b), and/or 302.2(c) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. An owner and/or operator is allowed to meet the requirements of any one or combination of the requirements of Sections 305.1, 305.2 and/or 305.3 of this rule by operating an ECS in accordance with Section IV of the Appendix within this rule whenever any requirement of Sections 305.1, 305.2 and/or 305.3 of this rule is not met. 306 302.3 Non-Vapor In-Line Cleaning Machines: No person shall An owner or operator who operates a non-vapor in-line cleaning machine using cleaning-solvent unless it shall comply complies with Sections 306.1, 306.2, and 306.3 of this rule 302.3(a) through 302.3(e), or Section 302.3(f): 306.1 Features: a. Carry-Out Prevention: Equip the cleaning machine with either a drying tunnel or another means, such as a rotating basket, sufficient to prevent cleaned parts from carrying out cleaning-solvent liquid or vapor. b. Enclosed Design: An in-line cleaning machine shall be fully enclosed except for entrance and exit portals. c. Cover: During shutdown hours or if the cleaning machine is idle for more than 30 minutes, a cover shall be used to close the entrance and exit and any opening greater than 16 square inches (104 cm 2). 306.2 d. Minimized Openings: Entrances and exits should silhouette workloads so that the average clearance between parts and the edge of the cleaning Maricopa County • Air Quality Department • Report the the Board of Supervisors 35 of 100 machine opening is either less than four inches (10 cm), or less than 10% of the width of the opening. 306.3 e. Freeboard Ratio: The machine shall have a freeboard ratio greater than or equal to 0.75. 306.4 f. ECS Alternative: In lieu of meeting the requirements in Sections 302.3(a) through Section 302.3(e) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. An owner and/or operator is allowed to meet the requirements of any one or combination of Sections 306.1(b), 306.1(c), 306.2, and/or 306.3 of this rule by operating an ECS that controls VOC vapor from processes addressed by the requirement(s). Such ECS shall be operated in accordance with Section IV of the Appendix within this rule. 305.3(d) 302.4 Non-Conforming Solvent used in a Non-Vapor Batch or In-Line Cleaning Machine: A non-conforming solvent may be used in operations to which this rule applies, if at least one of the following is met: 305.3(d)(1) a. ECS or Sealed System: The emissions from the operation shall be controlled by an ECS per Section 304.2 302.1(b) of this rule or by a Sealed System per Section 304.3 302.1(c) of this rule; or 305.3(d)(2) b. Partial Exemption: The operation is exempted per Sections 103.1 and/or 103.2 308.2 of this rule; or 305.3(d)(3) c. Non-Vapor Batch Cleaning Machine: The operation is both exempted per Section 103.3 308.3 of this rule and complies with Section 305.3 302.2(a) or 302.2(b) of this rule, as applicable; or 305.3(d)(3) d. Non-Vapor In-Line Cleaning Machine: The operation is both exempted per Section 103.3 of the rule and for in-line machines, complies with all of Section 306 302.3 of this rule except Section 306.4 of this rule. 307 302.5 Special Non-Vapor Cleaning Situations: 307.1 a. Blasting/Misting with Conforming Solvent or Low-VOC Cleaner: Any person owner or operator blasting or misting with conforming solvent or a low-VOC cleaner shall operate and equip the device(s) as follows: (1) Equipment: The device shall have internal drainage, a reservoir or sump, and a completely enclosed cleaning chamber, designed so as to prevent any perceptible liquid from emerging from the device; and (2) Operation: The device shall be operated such that there is no perceptible leakage from the device except for incidental drops from drained, removed parts. 307.2 b. Blasting/Misting with Non-Conforming Solvent: Any person owner or operator shall use a Sealed System pursuant to Section 302.1(c) 304.3 of this rule for all blasting or misting with a non-conforming solvent. Maricopa County • Air Quality Department • Report the the Board of Supervisors 36 of 100 307.3 c. High Pressure Flushing: Cleaning systems using cleaning-solvent that emerges from an object undergoing flushing with a visible mist or at a pressure exceeding 10 psig, shall comply as follows: (1) Conforming Solvent: For conforming solvent, use a containment system that is designed to prevent any perceptible cleaning-solvent liquid from becoming airborne outside the containment system, such as a completely enclosed chamber. (2) Non-Conforming Solvent: Use a Sealed System pursuant to Section 302.1(c) of this rule for non-conforming solvent. 307.4 d. ECS Alternative: In lieu of meeting the requirements in Sections 302.5(a) and/or Section 302.5(b) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. An owner and/or operator is allowed to meet the requirement(s) of Section 307.1 and/or Section 307.2 of this rule by operating an ECS that controls VOC vapor from processes addressed by the requirement(s). The ECS shall be operated pursuant to Section IV of the Appendix within this rule. 303 VAPOR CLEANING MACHINE REQUIREMENTS: II. BATCH-LOADED VAPOR CLEANING MACHINES: III. IN-LINE VAPOR CLEANING MACHINES: Appx II, III (1) No person shall operate a batch in-line vapor cleaning machine, unless the machine meets National Emission Standards for Halogenated Solvent Cleaning (subpart T, Rule 370), as if the cleaning solvent in use were subject to subpart T standards. Appx II, III (2) No person shall operate a batch in-line vapor cleaning machine, unless the machine has a vapor/air interface Fahrenheit temperature no greater than 30% of the solvent’s boiling point temperature or no greater than 40.0°F (4.4°C), whichever is lower. Appx II, III (3) 303.1 General Equipment Requirements for Vapor Cleaning Machines: An owner or operator of a batch vapor cleaning machine or an in-line vapor cleaning machine shall ensure it is equipped with all of the following: Sections II(1) and II(2), III(1) and III(2) of this Appendix shall not apply, if a batch in-line vapor cleaning machine is equipped with all of the following: Appx II, III (3)(B) a. A Vapor Level Control System. Appx II, III (3)(D) b. Freeboard Ratio: A freeboard ratio that is greater than or equal to 0.75. Appx II(3)(F), III(3)(E) c. Refrigeration or ECS: Batch vapor cleaning machines or in-line vapor cleaning machines having any of the following descriptors an evaporative surface area equal to or greater than 10.75 ft² (1.0 m²), installed or subject to major modification after November 1, 1999, or having average monthly VOC emissions exceeding 31 pounds VOC per square foot of solvent surface area shall comply with Sections II(3)(F)(i), II(3)(F)(ii), or II(3)(f)(iii), III(3)(E)(i), III(3)(E)(ii), or III(3)(E)(iii) of this Appendix one of the following subsections: Maricopa County • Air Quality Department • Report the the Board of Supervisors 37 of 100 (1) A refrigerated freeboard chiller where for which the chilled air blanket temperature measured in degrees Fahrenheit at the coldest point on the vertical axis through the horizontal center of the vapor/air interface either shall be either no greater than 30% of the initial boiling point of the solvent, measured in degrees Fahrenheit, or no greater than 40.0° F (4.4° C), whichever is lower; or (2) A refrigerated condenser coil (in place of an unrefrigerated coil) having a minimum cooling capacity of 100% of the boiling-sump heat input rate and where for which the chilled air blanket temperature requirements pursuant to Section III(3)(E)(i) II(3)(F)(i) measured in degrees Fahrenheit at the coldest point on the vertical axis through the horizontal center of the vapor/air interface shall be either no greater than 30% of the initial boiling point of the solvent, measured in degrees Fahrenheit, or no greater than 40.0° F (4.4° C), whichever is lower; or (3) An ECS operated in accordance with Section 304 of this rule. IV of this Appendix. Appx II (3)(C), III(3)(C) d. Primary Condenser: A primary condenser that maintains an exit temperature not exceeding 85° F (29° C). Alternatively, a batch vapor cleaning machine may be equipped pursuant to Section 303.1(c)(2) II(3)(F)(ii) of this Appendix. Appx II(3)(G), III(3)(F) e. Water Separator: Water should not be visually detectable in the VOC- containing solvent exiting the water separator. Appx II (3), (4) 303.2 Batch-Loaded Vapor Cleaning Machines: An owner or operator shall ensure a batch-loaded vapor cleaning machine meets the requirements in Section 303.1 and all of the following: Sections II(1) and II(2) of this Appendix shall not apply, if a batch vapor cleaning machine meets all of the following: Appx II (3)(A) a. Cover: Equipped with an impermeable cover that is a sliding, rolling, fanning, or guillotine (bi-parting) type which is designed to easily open and close without disturbing the vapor zone. Appx II (3)(E) b. Lip Exhausts: Batch-loaded vapor cleaning machines with lip exhausts shall be controlled by an ECS. Appx II (4)(A) c. Workloads: (1) A workload shall not occupy more than half of the cleaning machine’s open-top area. (2) The workload shall not be so massive that the vapor level drops more than 4 inches (10 cm), when the workload is removed from the vapor zone. (3) The workload shall not be sprayed with cleaning-solvent above the vapor/air interface level. Appx II (4)(B) d. Carry-Out: Minimize cleaning-solvent carry-out by the following measures: (1) Orient the items being cleaned in such a way that the items drain easily after cleaning. Maricopa County • Air Quality Department • Report the the Board of Supervisors 38 of 100 (2) Degrease the workload in the vapor zone at least 30 seconds or until condensation ceases. (3) For manual loading/unloading, tip out any pools of solvent on the cleaned parts before removal. (4) Allow parts to dry within the batch vapor cleaning machine until visually dry. Appx II (4)(C) e. Startup and Shutdown: The following sequence shall be used for startup and shutdown: (1) When starting the batch vapor cleaning machine, the cooling system shall be turned on before, or simultaneously with, the sump heater. (2) When shutting down the batch vapor cleaning machine, the sump heater shall be turned off before, or simultaneously with, the cooling system. Appx II (4)(D) f. Blasting: Blasting in a batch vapor cleaning machine shall be done within a Sealed System or be controlled by an ECS. Appx II (4)(E) g. Records: Maintain records pursuant to Section 501 of this rule. An owner and/or operator operating a batch vapor cleaning machine shall keep records pursuant to Section 501 of this rule. Appx III (3), (4) 303.3 In-Line Vapor Cleaning Machines: An owner or operator shall ensure an in-line vapor cleaning machine meets the requirements in Section 303.1 and all of the following: Sections III(1) and III(2) of this Appendix shall not apply, if an in-line vapor cleaning machine is equipped with all of the following Appx III (3)(A) a. Cover: Within 10 minutes of turning off the solvent heating system, cover the entrance and exit and any opening greater than 16 square inches (104 cm2). Appx III (4)(A) b. Workloads: Entrances and exits should silhouette workloads so that The average clearance between parts and the edge of the in-line vapor cleaning machine opening is either less than 4 inches (10 cm) or less than 10% of the width of the opening. Appx III (4)(B) c. Carry-Out: Equip the in-line vapor cleaning machine with either a drying tunnel or another means, such as a rotating basket, sufficient to prevent cleaned parts from carrying out cleaning-solvent liquid or vapor. Appx III (4)(C) d. Startup and Shutdown: The following sequences shall be used for startup and shutdown: (1) When starting the in-line vapor cleaning machine, the cooling system shall be turned on before, or simultaneously with, the sump heater. (2) When shutting down the in-line vapor cleaning machine, the sump heater shall be turned off before, or simultaneously with, the cooling system. Appx III (4)(D) e. Records: Maintain records pursuant to Section 501 of this rule. An owner and/or operator operating an in-line vapor cleaning machine shall keep records pursuant to Section 501 of this rule. Maricopa County • Air Quality Department • Report the the Board of Supervisors 39 of 100 Appx IV (1) 304 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS: 304.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 302.1(b) of this rule, an ECS shall comply with one of the following: a. Overall ECS Efficiency: Operate an ECS that has an 85% overall VOC capture and control efficiency, determined by applicable provisions in Section 503.1(c) of this rule; or An Emission Control System (ECS) used pursuant to this rule shall consist of a hood or enclosure to collect emissions, which are vented to a processing device. The overall control efficiency (capture plus processing) of the system shall not be less than 85%. The capture system shall have a ventilation rate no greater than 65 cfm per square foot of evaporative surface (20 m 3/min./m 2), unless that rate must be changed to meet a standard specified and certified by a Certified Safety Professional, a Certified Industrial Hygienist, or a licensed professional engineer experienced in ventilation- system design, that concerns health and safety requirements. The ECS shall be approved by the Control Officer. b. Alternative for Very Dilute Input: 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), determined by applicable provisions in Section 503.1(d) of this rule. Appx IV (2), 309.1 304.2 Operation and Maintenance (O&M) Plan Required for ECS: 309.1a a. An owner and/or operator shall provide create and maintain (an) O&M Plan(s) for any ECS and any ECS monitoring devices used pursuant to required by this rule or pursuant to a Maricopa County Air Quality Permit an air pollution control permit in accordance with Section 309 of this rule. 309.1b b. Approval by Control Officer of Initial O&M Plan(s): An The owner and/or operator shall submit to the Control Officer for written approval the O&M Plan(s) of each ECS and each ECS monitoring device that is used pursuant to this rule. While the Control Officer is reviewing for approval the O&M Plan(s), an owner and/or operator shall comply with all the identified actions and schedules provided in each O&M Plan submitted for approval, unless notified otherwise by the Control Officer. After the Control Officer has issued written approval of the O&M Plan(s), an owner and/or operator shall continue to comply with all the identified actions and schedules provided in each O&M Plan. 309.1a c. A The owner and/or operator shall comply with all the identified actions and schedules provided in each O&M Plan. 309.1c Owner and/or Operator Revisions to Initial O&M Plan(s): If an owner and/or operator submits to the Control Officer revisions to the initial O&M Plan(s) and if such revisions have been approved in writing by the Control Officer, an owner and/or operator shall comply with the revisions to the initial O&M Plan(s). Maricopa County • Air Quality Department • Report the the Board of Supervisors 40 of 100 309.1d Control Officer Modifications to Initial O&M Plan(s): After discussion with the owner and/or operator, the Control Officer may modify the O&M Plan(s) in writing prior to approval of the initial O&M Plan(s). An owner and/or operator shall then comply with the O&M Plan(s) that has been modified by the Control Officer. 309.2 304.3 Providing and Maintaining ECS Monitoring Devices: An owner and/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 air pollution control equipment 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 304.1 of this rule and is operated in accordance with the equipment manufacturer's specifications. 304.4 O&M Plan Responsibility: An owner or operator of a facility that is required to have an O&M Plan pursuant to Section 304.2 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. 304.5 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 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. Appx IV (4) Test Methods for Determining Emission Control System Compliance: Test methods and compliance procedures for an ECS are in Section 502 of this rule. SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE) 401 COMPLIANCE SCHEDULE: 401.1 ECS Installation at New Sources: For sources that commence construction after [revision date], compliance with the ECS requirements shall be achieved upon source startup. 401.2 New Low-VOC Cleaner Limit: Upon adoption of this rule, an owner or operator using a low-VOC cleaner to comply with this rule shall discontinue purchase of materials that are non-compliant with the new low-VOC cleaner limit of this rule. The owner or operator may continue to use supplies of non-compliant low-VOC cleaner materials purchased prior to [date] until [six-month deadline date]. Maricopa County • Air Quality Department • Report the the Board of Supervisors 41 of 100 SECTION 500 – MONITORING AND RECORDS 501 RECORDKEEPING AND REPORTING: Any person subject to this rule 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. 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. 501.1 501.5 Current List: a. Maintain a current list of cleaning-solvents; state the VOC content of each in pounds VOC per gallon of material or grams per liter of material. b. A facility using any cleaning-solvent subject to the vapor-pressure limits of Section 302.1(a) 304.1 of this rule shall have on site the written value of the total VOC vapor-pressure of each such solvent, 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. 501.2 501.6 Usage Records: a. Monthly: Records of the amount of cleaning-solvent purchased or used shall be totaled updated by the end of the month for the previous month. Show the type and amount of each make-up solvent and all other cleaning-solvent to which this rule is applicable. b. Annually: (1) Certain Concentrates: Use of concentrate that is used only in the formulation of Low-VOC Cleaner shall be updated at least annually. (2) Low-VOC Cleaner: An owner and/or operator need not keep a record of a cleaning substance that is made by diluting a concentrate with water or non-precursor organic compound(s) to a level that qualifies as a Low-VOC Cleaner if records of the concentrate usage are kept in accordance with this rule. c. Grouping by VOC Content: For purposes of recording usage, an owner or operator may give cleaning-solvents of similar VOC content a single group- name, distinct from any product names in the group. The total usage of all the products in that group is then recorded under just one name. (In such a case, the owner or operator must also keep a separate list that identifies the product names of the particular cleaning-solvents included under the group name). To the group name shall be assigned the highest VOC content among Maricopa County • Air Quality Department • Report the the Board of Supervisors 42 of 100 the members of that group, rounded to the nearest tenth 10th of a pound of VOC per gallon of material, or to the nearest gram VOC per liter of material. 501.7 Records of Disposal: Maintain records of the type, amount, and method of disposing of waste solvent. Records of legal disposal include but are not limited to shipping papers or quantity discharged to sewage treatment works. 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 required ECS: (IV, 3.A) ECS Operation and Maintenance Records: On each day that an ECS is used to comply with any provision of this rule, an owner and/or operator shall make a permanent record of the operating parameters of the key systems described in the O&M Plan. For each day or period in which the O&M Plan requires that maintenance be performed, a permanent record shall be made of the maintenance actions taken, within 24 hours of maintenance completion. An explanation shall be entered for scheduled maintenance that is not performed during the period designated in the O&M Plan. 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. (IV, 3B) 502.6 Other Records Required when Complying via ECS: An owner and/or operator using an ECS pursuant to this rule shall maintain, in addition to the records required by Section 501.5 501.1 of this rule, daily monthly documentation showing the VOC content of the solvent material and the amount added for makeup. 502 503 COMPLIANCE DETERMINATION AND TEST METHODS: When more than one test method is permitted for a determination, an exceedance of the limits established in the rule determined by any of the applicable test methods constitutes a violation of this rule. Maricopa County • Air Quality Department • Report the the Board of Supervisors 43 of 100 502.1 503.1 Compliance Determination: The following means shall be used to determine compliance with this rule. For routine information collection, the Control Officer may accept a manufacturers’ data sheet, data certified by an officer of the supplying company, or test data for the product model of inquiry. a. VOC Content: The VOC content of solutions, dispersions, emulsions, and conforming solvents (reference Section 207 of this rule) shall be determined by one of the following methods: (1) South Coast Air Quality Management District (SCAQMD) Method 313-91 as referenced in Section 503.3(a) 502.2(f) of this rule; or (2) Bay Area Air Quality Management District (BAAQMD) Method 31 as referenced in Section 503.3(b) 502.2(e) of this rule. ; or (3) Solids-free windshield washer solutions, in which all organic components are VOCs, may be tested using Maricopa County Reference Method #100, “Total Organic Carbon for Windshield Washer Fluids,” Maricopa County Air Pollution Control Rule 344 (April 7, 1999). This method should only be used for water-based solutions containing less than 5% VOC by weight. b. Vapor Pressure: Pursuant to Sections 304 and 207 of this rule, Determination of the total VOC vapor-pressure (VOC composite partial-pressure) in a cleaning solution shall be performed as follows: (1) For solutions known to be nearly or exactly 100% VOC, vapor pressure shall be determined by ASTM D2879-9796 as referenced in Section 503.4(a) 502.2(g) of this rule; or (2) For solutions for which is known the exact quantity and chemical makeup of each evaporating component that is not a VOC, ASTM D2879-9796 (referencing Section 503.4(a) 502.2(g) of this rule) shall be used (to determine the gross composite vapor pressure) in conjunction with calculations using the vapor pressure formula in Section 503.1(f) 502.3 of this rule. (3) When a solution’s exact species and proportions are known for all ingredients, the Control Officer may use the formula in Section 503.1(f) 502.3 of this rule in conjunction with standard reference texts or databases that provide the vapor pressure value of each constituent, or a combination of formula use and actual testing on real constituents (referencing Section 503.4(a) 502.2(g) of this rule). c. ECS Efficiency Compliance: An owner or operator that complies with Section 304.1(a) of this rule using an ECS shall demonstrate compliance using the following methods and equations: (1) Overall ECS Efficiency shall be determined using the following equation: EffO = (EffCo x EffCa) / 100 where, Maricopa County • Air Quality Department • Report the the Board of Supervisors 44 of 100 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. (1) (2) The ECS control efficiency shall be determined by measuring the VOC content of gaseous emissions entering and exiting the ECS using EPA Method 18, referenced in Section 503.2(e), or EPA Methods 25, 25A, and 25B, referenced in Section 503.2(f) of this rule. The VOC content of gaseous emissions entering and exiting an ECS shall be determined by either EPA Method 18 referred to in Section 502.2(b) of this rule, or EPA Methods 25, 25a, and 25b referred to in Section 502.2(c) of this rule. (2) (3) The ECS capture efficiency of an emission control device used pursuant to Section 304.2, Section 305.4, Section 306.4, and/or Section 307.4 of this rule shall be determined either by the methods in Section 503.2(g) 502.2(d) of this rule (EPA Methods 204, 204Aa, 204Bb, 204Cc, 204Dd, 204Ee, and 204Ff) or by using mass balance calculation methods in concert with the methods in Section 503.2(b) 502.2(a) of this rule (EPA Methods 2, 2Aa, 2Cc, and 2Dd), and EPA guidance document, “Guidelines for Determining Capture Efficiency”, January 9, 1995. d. Alternative for Very Dilute Input: An owner or operator that complies with Section 304.1(b) of this rule shall demonstrate compliance by using EPA Method 25A referred to in Section 503.2(f) of this rule. 502.1(d) e. Temperature Measurement: Temperature measurements made pursuant to Section 214 of this rule to determine if a cleaning machine contains a “heated solvent” shall be done with an instrument having an accuracy and precision of no less than within 1 degree Fahrenheit. 502.3 f. Formula for VOC Composite Partial Pressure (Equivalent to: Total VOC Vapor Pressure): The VOC composite partial pressure shall be calculated by the following equation: ( )( ) ∑ ∑ ∑ = = = + + = m j n i i i e e w n i i i i c M W M W W M VP W PP 1 1 1 18 where, i W = Weight of the “i”th VOC compound in grams w W = Weight of water in grams Maricopa County • Air Quality Department • Report the the Board of Supervisors 45 of 100 We = Weight of the “j”th non-precursor organic compound in grams i M = Molecular weight of the “i”th VOC compound in grams per gram mole, e.g., one gram-mole of isopropyl alcohol weighs 60 grams e M = Molecular weight of the “j”th non-precursor compound, e.g., 1 gram-mole of acetone weighs 58 grams c PP = VOC composite partial pressure at 20°C in mm mercury (Hg) i VP = Vapor pressure of the “i”th VOC compound at 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) non-precursor organic compounds 503.4 g. Formula for VOC Content of Solvent: The VOC content of solvent 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) Maricopa County • Air Quality Department • Report the the Board of Supervisors 46 of 100 VOC CONTENT OF MATERIAL in pounds per gallon (lbs/gal) or grams per liter (g/l) = W W W m s w es V − − Using consistently either English or metric measures in the calculations, where: Ws = Weight of all volatile material 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 organic compounds in pounds (or grams) Vm = Volume of total material in gallons (or liters) 502.2 503.2 EPA-Approved Test Methods Adopted Incorporated by Reference: The following test methods are approved for use for the purpose of determining compliance with this rule. The test methods are incorporated by reference in Appendix G of the MCAPCR. Alternative EPA-approved test methods may be used upon prior written approval from the Control Officer. When more than one test method is permitted for the same determination, an exceedance under any method will constitute a violation. The EPA test methods as they exist in the Code of Federal Regulations (CFR) (July 1, 2003), 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 502 are available at the Maricopa County Air Quality Department. 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). 502.2(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”) All 4 of the foregoing methods are in (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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 47 of 100 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). 502.2(b) e. EPA Method 18 (“Measurement of Gaseous Organic Compound Emissions by Gas Chromatography”) (40 CFR 60, Appendix A-6). 502.2(c) f. 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). 502.2(d) g. EPA Test Methods 204 (“Criteria for and Verification of a Permanent or Temporary Total Enclosure”), 204A (“Volatile Organic Compounds Content in Liquid Input Stream”), 204B (“Volatile Organic Compound Emissions in Captured Stream”), 204C (“Volatile Organic Compound Emissions in Captured Stream (Dilution Technique)”), 204D (“Volatile Organic Compound Emissions in Uncaptured Stream from Temporary Total Enclosure”), 204E (“Volatile Organic Compound Emissions in Uncaptured Stream from Building Enclosure”), and 204F (“Volatile Organic Compounds Content in Liquid Input Stream (Distillation Approach)”) (40 CFR 51, Appendix M) and EPA guidance document, “Guidelines for Determining Capture Efficiency” January 9, 1995. 502.2(h) h. EPA guidance document, “Guidelines for Determining Capture Efficiency”, January 9, 1995. 503.3 EPA-Approved California Air Resources Board (CARB) Test Methods Incorporated by Reference: 502.2(f) a. 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)”. 502.2(e) b. 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.”. 503.4 EPA-Approved American Society for Testing and Materials (ASTM) Standard Incorporated by Reference: 502.2(g) a. American Society for Testing and Materials (ASTM) Method D2879-9796, “Test Method for Vapor Pressure-Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope” (1996). Maricopa County • Air Quality Department • Report the the Board of Supervisors 48 of 100 SECTION 100 – GENERAL 101 PURPOSE 102 APPLICABILITY 103 PARTIAL EXEMPTIONS 104 TOTAL CATEGORICAL EXEMPTIONS SECTION 200 – DEFINITIONS 201 AGITATION, AGITATED 202 BATCH CLEANING MACHINE 203 BLASTING/MISTING WITH SOLVENT 204 CABINET STYLE CLEANING MACHINE 205 CARRY-OUT 206 CLEANING-SOLVENT 207 CONFORMING SOLVENT 208 DIP TANK 209 DRY SOLID 210 EMISSION CONTROL SYSTEM (ECS) 211 FILTRATION DEVICE 212 FLUSHING 213 FREEBOARD HEIGHT 214 FREEBOARD RATIO 215 FULLY SUBMERGED 216 HEATED SOLVENT 217 IMPERVIOUS 218 IN-LINE CLEANING MACHINE 219 JANITORIAL CLEANING Return to list of attachments Clean version of draft Rule 331 MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III – CONTROL OF AIR CONTAMINANTS RULE 331 (SOLVENT CLEANING) INDEX Maricopa County • Air Quality Department • Report the the Board of Supervisors 49 of 100 220 LEAK 221 LOW-VOC CLEANER 222 MAKE-UP SOLVENT 223 NON-CONFORMING SOLVENT 224 NON-VAPOR CLEANING MACHINE 225 PARTS PER MILLION BY VOLUME DRY (PPMVD) 226 REFRIGERATED FREEBOARD CHILLER 227 REMOTE RESERVOIR CLEANING MACHINE 228 SEALED SYSTEM 229 SMALL CLEANER 230 SOLVENT 231 SOLVENT/AIR INTERFACE 232 SOLVENT/AIR INTERFACE AREA 233 TOTAL VOC VAPOR PRESSURE (VOC COMPOSITE PARTIAL PRESSURE) 234 VAPOR CLEANING MACHINE 235 VAPOR LEVEL CONTROL SYSTEM 236 VOC CONTENT OF MATERIAL 237 WIPE CLEANING SECTION 300 – STANDARDS 301 GENERAL REQUIREMENTS FOR SOLVENT CLEANING OPERATIONS 302 NON-VAPOR CLEANING MACHINE REQUIREMENTS 303 VAPOR CLEANING MACHINE REQUIREMENTS 304 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 AND TEST METHODS Maricopa County • Air Quality Department • Report the the Board of Supervisors 50 of 100 Revised 07/13/88; Revised 06/22/92; Revised 06/19/96; Revised 04/07/99; Revised 04/21/04; Revised 09/25/13; Revised MM/DD/YYYY MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS REGULATION III – CONTROL OF AIR CONTAMINANTS RULE 331 (SOLVENT CLEANING) SECTION 100 – GENERAL 101 PURPOSE: To limit the emissions of volatile organic compounds (VOCs) from solvent cleaning operations. 102 APPLICABILITY: This rule is applicable to operations using VOC-containing solvents to remove impurities from exterior or interior surfaces. 102.1 NSPS & NESHAP: 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 Maricopa County Air Pollution Control Regulations (MCAPCR). 102.2 Vehicle Refinishing: Dip cleaning of vehicle or mobile equipment surfaces is subject to this rule. 102.3 Aerospace: Wipe cleaning of aerospace components is subject to Rule 348 (Aerospace Manufacturing and Rework Operations) of the MCAPCR, whereas the cleaning of aerospace components in a dip tank or a cleaning machine is subject to this rule. 103 PARTIAL EXEMPTIONS: 103.1 Wipe Cleaning: Wipe cleaning is only subject to Sections 301.1 and 501 of this rule. 103.2 Small Cleaners: The provisions of Sections 301.3 through 302.4 of this rule shall not apply to non-vapor small cleaners with either a maximum capacity of one gallon or less, or a liquid surface area of one square foot or less, except that these shall be covered when work is not being processed. 103.3 Standard Industrial Classification (SIC) Codes Exempt from Section 302.1: The following SIC codes are exempt from Section 302.1 of this rule: a. Industry Group 366 (Communications Equipment): SIC codes 3661, 3663, and 3669. b. Industry Group 367 (Electronic Components And Accessories): SIC codes 3677, 3678, and 3679. c. Industry Group 376 (Guided Missiles And Space Vehicles And Parts): SIC code 3769. Maricopa County • Air Quality Department • Report the the Board of Supervisors 51 of 100 d. Industry Group 384 (Surgical, Medical, And Dental Instruments And Supplies): SIC codes 3841, 3843, 3844, or 3845, and products for internal use in 3842. The U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) “Standard Industrial Classification (SIC) Manual” can be found on the OSHA website at: https://www.osha.gov/data/sic-manual. 103.4 Production processes having clean-room standards equal to or more stringent than clean room classification ISO 14644-1:2015 (Class 8) are exempt from Section 302.1 of this rule. 103.5 Low viscosity solvent used to clean an aerospace component if the Federal Aviation Authority, the U.S. Department of Defense, or a U.S. Military specification designates that the cleanliness of the component is critical to the flight safety of a complete aerospace vehicle are exempt from Section 302.1 of this rule. Any such solvents shall be listed in a Maricopa County Air Pollution Permit, conditioned upon a sufficient demonstration by the user that no compliant substitute exists. 103.6 Aerosol cans, squirt bottles, and other solvent containers intended for handheld use shall meet the requirements in Sections 301.1 and 500 of this rule. 103.7 A Low-VOC Cleaner is subject only to Sections 301.1, 301.2, 302.5(a), 501.5(a), and 501.6 of this rule. 104 TOTAL CATEGORICAL EXEMPTIONS: This rule does not apply to: 104.1 A solvent cleaning operation that is subject to or specifically exempted by an EPA State Implementation Plan (SIP) approved version of another rule within the MCAPCR. 104.2 Janitorial cleaning. 104.3 Testing for surface cleanliness or the cleaning of laboratory equipment at the laboratory. 104.4 A cleaning-solvent that meets any of the following: a. Is composed of at least 98% water by either weight or volume; or b. Contains only water and material which is a dry solid before mixing with water; or c. Has a VOC content not exceeding 20 grams per liter (0.17 lb/gal). 104.5 All operations regulated by National Emission Standards for Perchloroethylene for Dry Cleaning Facilities (40 CFR 63, Subpart M). 104.6 Operations involving the cleanup of coating-application equipment that are subject to or specifically exempted by an EPA SIP-approved version of another source-specific rule within the MCAPCR. Examples include Rule 336 (Surface Coating Operations and Industrial Adhesive Application Processes), Rule 342 (Coating Wood Furniture and Fixtures), and Rule 346 (Coating Wood Millwork). Maricopa County • Air Quality Department • Report the the Board of Supervisors 52 of 100 SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions shall apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of these rules. In the event of any inconsistency between any of the MCAPCR, the definitions in this rule take precedence. 201 AGITATION, AGITATED: A means or state that moves cleaning liquid continuously back and forth, or up and down. This includes such motion created by sound waves, and to the splashing of a rinse stream operated at a pressure that creates a trajectory exceeding 2 feet along the horizontal plane intersecting the nozzle when the nozzle is at a 45° angle above the plane. Liquid motion incidental to a continuous entrance or withdrawal of objects undergoing cleaning is not agitation. 202 BATCH CLEANING MACHINE: A solvent cleaning machine in which individual parts or a set of parts move through the entire cleaning cycle before new parts are introduced into the solvent cleaning machine. A solvent cleaning machine, such as a ferris wheel or a cross-rod degreaser, that cleans multiple batch loads simultaneously and is manually loaded, is a batch cleaning machine. 203 BLASTING/MISTING WITH SOLVENT: Cleaning with an applicator that propels cleaning-solvent through the air or atomizes the solvent into mist and/or droplets. 204 CABINET STYLE CLEANING MACHINE: A solvent cleaning machine typically similar in design to domestic dishwashers that are completely enclosed except for optional stack and have their own reservoir and sump. 205 CARRY-OUT: Solvent carried out of a cleaning machine along with a part being removed from the cleaning machine. The solvent may exist as a liquid coating the part or the part’s hanger, or as a liquid entrapped in cavities and irregular surfaces or entrapped by capillary action within or on the part. 206 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). 207 CONFORMING SOLVENT: A cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) not exceeding 1 millimeter of mercury column (mm Hg). 208 DIP TANK: A container holding solvent used for dipping or coating an object. An object may be immersed in a dip tank, or it may be suspended in a vapor coming from the tank. 209 DRY SOLID: Any substance that appears and feels dry. Evaporating solids, all of which have a strong odor, are not included. 210 EMISSION CONTROL SYSTEM (ECS): A system, approved in writing by the Control Officer, to reduce emissions of volatile organic compounds. Such a system consists of an emissions collection system and an emissions processing subsystem. 211 FILTRATION DEVICE: A filter composed of porous material (i.e., canvas bag) which collects and removes contaminants from solvent. Maricopa County • Air Quality Department • Report the the Board of Supervisors 53 of 100 212 FLUSHING: Introducing cleaning-solvent directly into the internal space(s) of an object or assembly using a hose or pipe. Rinsing the outside of an object or assembly and swishing an object or assembly in cleaning-solvent are not considered flushing with solvent. Such activities must comply with Section 301.3 of this rule. 213 FREEBOARD HEIGHT: 213.1 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, measured during idling mode. 213.2 In-Line Cleaning Machine: The vertical distance from the solvent/air interface to the lowest entry/exit point, measured during idling mode. 214 FREEBOARD RATIO: The freeboard height divided by the smaller of either the length or width of the solvent cleaning machine. 215 FULLY SUBMERGED: Any material or object which is maintained below the surface of the solvent with no portions exposed to the ambient air. 216 HEATED SOLVENT: Any cleaning-solvent which is heated by a device to a temperature exceeding 120° F (49° C). 217 IMPERVIOUS: Neither absorbing, adsorbing, nor allowing penetration through, by liquid or vapors. 218 IN-LINE CLEANING MACHINE: A solvent cleaning machine that uses an automated handling system, typically a conveyor or automated arm(s), to automatically provide a continuous supply of items to be cleaned. The cleaned item leaves by a route different from its entry route. 219 JANITORIAL CLEANING: The cleaning of building or facility components to keep work areas in clean condition. Building or facility components include, but are not limited to, floors, ceilings, walls, windows, doors, stairs, bathrooms, furnishings, textiles, wash rags, uniforms, and exterior surfaces of office equipment. 220 LEAK: A visible cleaning-solvent liquid leak at a rate of three or more drops per minute, or a puddle greater than one square inch. 221 LOW-VOC CLEANER: Any solution or homogeneous suspension that, as used, contains less than 25 grams of VOC per liter of material (0.21 lb VOC/gal) or is at least 95% water by weight or volume as determined by an applicable test method in Section 503 of this rule. 222 MAKE-UP SOLVENT: A cleaning-solvent that replaces solvent lost through evaporation or other means, and that is added to the solvent remaining in a cleaning machine to bring solvent quantity to the desired level. 223 NON-CONFORMING SOLVENT: A cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) exceeding 1 millimeter of mercury column (mm Hg). Maricopa County • Air Quality Department • Report the the Board of Supervisors 54 of 100 224 NON-VAPOR CLEANING MACHINE: Any liquid container and ancillary equipment designed to clean surfaces and/or remove surface contaminants using cleaning- solvents at temperatures that do not exceed the solvent boiling point. 225 PARTS PER MILLION BY VOLUME DRY (PPMVD): A unit of proportion used to express concentration that is corrected to a dry basis. 226 REFRIGERATED FREEBOARD CHILLER: A control device which is mounted above any cooling-water jacket or primary condenser coils, consisting of secondary coils which carry a refrigerant to provide a chilled air blanket above the solvent vapor/air interface to reduce emissions from the cleaning machine bath. 227 REMOTE RESERVOIR CLEANING MACHINE: Any non-vapor cleaning machine in which the reservoir for storing the cleaning-solvent is completely separated by impervious surfaces from the sink or basin where cleaning is performed, except for a connecting tube or passage through which solvent returns to the reservoir when cleaning is stopped. 228 SEALED SYSTEM: An Air-tight or Airless Cleaning System that is operated and equipped pursuant to Section 302.1(c) of this rule. 229 SMALL CLEANER: A cleaning machine that has a liquid surface area of 1 square foot (0.09 square meters) or less or has a maximum capacity of one gallon (3.79 liters) or less. 230 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. 231 SOLVENT/AIR INTERFACE: 231.1 Non-Vapor Cleaner: The location of contact between the liquid solvent and the air. 231.2 Vapor Cleaner: The location of contact between the concentrated layer of solvent vapor and the air. 232 SOLVENT/AIR INTERFACE AREA: 232.1 Non-Vapor Cleaner: a. With Included/Integral Reservoir: The surface area of liquid cleaning-solvent that is exposed to the air. b. With Remote Reservoir: The surface area of the solvent sink or work area. 232.2 Vapor Cleaner: The area of the horizontal plane that is located halfway between the highest and lowest points of the primary condenser coils and which contacts the interior walls of the cleaning machine. 233 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 55 of 100 components that are defined as VOCs, calculated according to the formula in Section 503.1(f) of this rule. 234 VAPOR CLEANING MACHINE: A batch or in-line cleaning machine in which solvent- vapor from boiling cleaning-solvent is utilized for cleaning an object. 235 VAPOR LEVEL CONTROL SYSTEM: A combination of a coolant sensing system and a vapor sensing system consisting of the following three sets of features: 235.1 A condenser flow switch and thermostat which shuts off the sump heat if either the condenser coolant stops circulating or becomes warmer than 85° F (29° C); and 235.2 A manually-reset safety switch which turns off the sump heater if the temperature sensor senses that the temperature is rising above the designed operating level at the vapor/air interface; and 235.3 A manually-reset switch which turns off the spray-system pump if the level of the vapor/air interface drops more than 4 inches (10 cm). 236 VOC CONTENT OF MATERIAL: The weight of VOC per volume of material, as calculated according to the formula in Section 503.1(g) of this rule. 237 WIPE CLEANING: A cleaning method of removing contaminants from a surface by physically rubbing or automatically rubbing with a porous or absorbent material, such as a rag, paper, sponge, or cotton swab, moistened with a solvent. SECTION 300 – STANDARDS 301 GENERAL REQUIREMENTS FOR SOLVENT CLEANING OPERATIONS: An owner or operator subject to this rule shall comply with all of the following: 301.1 Solvent Handling Requirements: All cleaning-solvent, including solvent soaked materials, shall be kept in closed, leak free, impervious containers that are opened only when adding or removing material. a. Porous or absorbent materials used for wipe cleaning shall be stored in closed containers when not in use. b. Each container shall be clearly labeled with its contents. c. Wipe up or otherwise remove any cleaning-solvent that escapes from a container immediately if in accessible areas. d. For areas where access is not feasible during normal production, remove any cleaning-solvent that escapes from a container as soon as reasonably possible. e. Disposal of waste or surplus solvent 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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 56 of 100 301.2 Equipment Requirements for All Cleaning Machines: An owner or operator who is operating a cleaning machine to which this rule applies must comply with all of the following: a. Provide a leak free, impervious container for the solvents and the articles being cleaned. The VOC-containment portion shall be impervious to VOC- containing liquid and vapors. b. No surface of any freeboard required by this rule shall have an opening or duct through which VOC can escape to the atmosphere, except as controlled by an ECS, or as required by OSHA. c. Properly maintain and operate all cleaning machine equipment required by this rule and any of its emission controls required by this rule. 301.3 Operating Requirements for Cleaning Machines: An owner or operator who cleans with cleaning-solvent, other than a Low-VOC Cleaner, must comply with all of the following operating requirements for cleaning machines: a. Fans: Do not locate nor position comfort fans in such a way as to direct airflow across the opening of any cleaning machine. This prohibition does not apply to a totally enclosed cleaning machine that cannot be penetrated by drafts. b. Cover: Do not remove any device designed to cover the solvent unless processing work in the cleaning machine or maintaining the machine. c. Draining: Drain cleaned parts for at least 15 seconds after cleaning or until dripping ceases, whichever is later. d. Spraying: If using a cleaning-solvent spray system, (1) Use only a continuous, undivided stream (not a fine, atomized, or shower type spray). (2) Pressure at the orifice from which the solvent emerges shall not cause liquid solvent to splash outside of the solvent container. (3) In an in-line cleaning machine, a shower-type spray is allowed, provided that the spraying is conducted in a totally confined space that is separated from the environment. (4) Provisions for exceptions to Sections 301.3(d)(1), (2), and (3) are provided for in Section 302.5 of this rule. e. Agitation: An owner or operator shall not cause agitation of a cleaning- solvent in a cleaning machine by sparging with air or other gas. Covers shall be placed over ultrasonic cleaners when the cleaning cycle exceeds 15 seconds. f. Porous Material: Do not clean porous or absorbent materials in a cleaning machine. For the purpose of this rule, porous or absorbent materials include, but are not limited to, cloth, leather, wood, and rope. Maricopa County • Air Quality Department • Report the the Board of Supervisors 57 of 100 g. Vent Rates: The ventilation rate at the cleaning machine shall not exceed 65 cfm per square foot of evaporative surface (20 m 3/min./m 2), unless that rate must be changed to meet a standard specified and certified by a Certified Safety Professional, a Certified Industrial Hygienist, or a licensed professional engineer experienced in ventilation, to meet health and safety requirements. h. Hoist Speed: Limit the vertical speed of mechanical hoists moving parts in and out of the cleaning machine to a maximum of 2.2 inches per second and 11 ft/min. (3.3 m/min.). i. Contamination Prevention: Prevent cross contamination of solvents regulated by Section 302.1 of this rule with low-VOC cleaners. Use signs, separated work-areas, or other effective means for this purpose. This includes cleaning-solvents that are regulated by another source-specific rule within Maricopa County Rules of Regulation III. j. Filtration Devices: If a filtration device (e.g., to remove oils, greases, sludge, and fine carbon from cleaning-solvent) is inherent in the design of the cleaning machine, then such filtration device shall be operated in accordance with the following requirements: (1) The filtration device shall be operated in accordance with manufacturer’s specifications. (2) The filtration device shall be maintained under the protective shelf in the wash basin, when applicable. (3) The filtration device shall be fully submerged in cleaning-solvent at all times during filtration. (4) When the filtration device is completely saturated and must be removed from the cleaning machine, the filtration device shall be drained until no liquid can flow from the filtration device. Draining and drying such filtration device shall be conducted in a sealed container with no exhaust to the atmosphere or work area. (5) After the filtration device is dry, the filtration device shall be stored in a closed, leak free, impervious container that is legibly labeled with its contents and that remains covered when not in use. Disposal of the filtration device shall be done in a manner that inhibits VOC evaporation and that is in compliance with appropriate/legal methods of disposal. 301.4 Signage Requirements: An owner or operator who uses cleaning-solvent, other than Low-VOC Cleaner, in any solvent cleaning machine or dip tank shall provide on the machine, or within 3¼ feet (1 meter) of the machine, a permanent, conspicuous label or placard which includes, at a minimum, each of the following applicable instructions, or its equivalent: a. “Keep cover closed when parts are not being handled.” (This is not required for remote reservoir cleaners.) b. “Drain parts until they can be removed without dripping.” c. “Do not blow off parts before they have stopped dripping.” Maricopa County • Air Quality Department • Report the the Board of Supervisors 58 of 100 d. “Wipe up spills and drips as soon as possible; store used spill rags [or ‘wiping material’] in covered container.” e. “Do not clean porous or absorbent materials in this tank.” f. For cleaning machines with moving parts such as hoists, pumps, or conveyors, post: “Operating instructions can be obtained from _______,” listing a person or place where the instructions are available. 302 NON-VAPOR CLEANING MACHINE REQUIREMENTS 302.1 Solvent Specifications for Non-Vapor Cleaning Machines: All cleaning-solvents, except Low-VOC Cleaners, used in non-vapor cleaning machines shall comply with one of the following requirements: a. Conforming Solvent: Use a cleaning-solvent having a total VOC vapor pressure at 68° F (20° C) not exceeding 1.0 millimeter of mercury column (mm Hg), as determined by the standards described in Section 500 of this rule; or b. ECS: Use an ECS to capture and process VOC emissions in accordance with Section 304 of this rule; or c. Sealed System: Use a Sealed System that is an Air-tight or Airless Cleaning System which is operated according to the manufacturer’s specifications and, unless otherwise indicated by the manufacturer, meets all of the following requirements: (1) Has a door or other pressure-sealing apparatus that is shut during each cleaning and drying cycle; and (2) Has a differential pressure gauge that always indicates the pressure in the sealed chamber when occupied or in active use; and (3) Any associated pressure relief device(s) shall be so designed and operated as to prevent liquid cleaning-solvents from draining out. 302.2 Non-Vapor Batch Cleaning Machines: An owner or operator who operates a non- vapor batch cleaning machine shall comply with the following requirements (Low-VOC Cleaners are exempt from this section): a. With Remote Reservoir: A batch cleaning machine with remote reservoir, including cabinet type(s), shall be equipped with all of the following: (1) A sink-like work area or basin which is sloped sufficiently towards the drain to prevent pooling of cleaning-solvent. (2) A single, unimpeded drain opening, or cluster of openings served by a single drain for the cleaning-solvent to flow from the sink into the enclosed reservoir. Such opening(s) shall be contained within a contiguous area not larger than 15.5 square inches (100 cm 2). (3) Provide a means for drainage of cleaned parts such that the drained solvent is returned to the cleaning machine. Maricopa County • Air Quality Department • Report the the Board of Supervisors 59 of 100 b. With Internal Reservoir (Non-Remote): A batch cleaning machine without a remote reservoir shall be equipped with all of the following: (1) Have and use an internal drainage rack or other assembly that confines within the freeboard all cleaning-solvent dripping from parts and returns it to the hold of the cleaning machine; and (2) Have an impervious cover which when closed prevents cleaning-solvent vapors in the cleaning machine from escaping into the air/atmosphere when not processing work in the cleaning machine. (a) A cover shall be fitted so that in its closed position the cover is between the cleaning-solvent and any lip exhaust or other safety vent, except that such position of cover and venting may be altered by an operator for valid concerns of flammability established in writing and certified to by a Certified Safety Professional or a Certified Industrial Hygienist to meet health and safety requirements. (b) A cover is not required when an ECS is used in accordance with Section 304 of this rule. (3) In the absence of additional applicable freeboard standards, freeboard height shall be not less than 6 inches (15.2 cm); and (4) The freeboard zone shall have a permanent, conspicuous mark that locates the maximum allowable solvent level which conforms to the applicable freeboard requirements. c. Cleaning-Solvent that is Heated or Agitated in a Non-Vapor Batch Cleaning Machine: If a non-vapor batch cleaning machine uses a cleaning-solvent at a temperature above 120° F (49° C) or agitates the solvent, then comply with one of the following: (1) Remote Reservoir Cleaning Machines: For a remote reservoir cleaning machine, comply with Section 302.2(a) of this rule and one of the following: (a) Use a stopper in the drain whenever the sink or cabinet is empty of solvent and nothing is being handled in the sink; or (b) Cover the sink or cabinet whenever the sink or cabinet is empty of solvent and nothing is being handled in the sink. (2) Internal Reservoir Cleaning Machines: For an internal reservoir cleaning machine, comply with Section 302.2(b) of this rule and one of the following: (a) Water Cover: A floating layer of water (insoluble in the solvent) at least 1 inch thick, and a freeboard at least 6 inches above the top of the solvent shall be present; or (b) Freeboard and Cover: Maricopa County • Air Quality Department • Report the the Board of Supervisors 60 of 100 (i) The basin shall have a freeboard ratio of 0.75 or greater and an impervious cover shall cover the basin whenever work is not being processed; and (ii) If a non-conforming solvent is used, the cover shall be of a sliding or rolling type which is designed to easily open and close in a horizontal plane without disturbing the vapor zone. (3) Cabinet Style: Keep a cabinet-style cleaning machine that contains cleaning-solvent closed at all times, except when introducing or removing work from the machine. If blasting or misting with cleaning-solvent, also conform to the applicable requirements of Section 302.5 of this rule. d. ECS Alternative: In lieu of meeting the requirements in Sections 302.2(a), 302.2(b), and/or 302.2(c) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. 302.3 Non-Vapor In-Line Cleaning Machines: An owner or operator who operates a non-vapor in-line cleaning machine using cleaning-solvent shall comply with Sections 302.3(a) through 302.3(e), or Section 302.3(f): a. Carry-Out Prevention: Equip the cleaning machine with either a drying tunnel or another means, such as a rotating basket, sufficient to prevent cleaned parts from carrying out cleaning-solvent liquid or vapor. b. Enclosed Design: An in-line cleaning machine shall be fully enclosed except for entrance and exit portals. c. Cover: During shutdown hours or if the cleaning machine is idle for more than 30 minutes, a cover shall be used to close the entrance and exit and any opening greater than 16 square inches (104 cm 2). d. Minimized Openings: Entrances and exits should silhouette workloads so that the average clearance between parts and the edge of the cleaning machine opening is either less than four inches (10 cm), or less than 10% of the width of the opening. e. Freeboard Ratio: The machine shall have a freeboard ratio greater than or equal to 0.75. f. ECS Alternative: In lieu of meeting the requirements in Sections 302.3(a) through Section 302.3(e) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. 302.4 Non-Conforming Solvent used in a Non-Vapor Batch or In-Line Cleaning Machine: A non-conforming solvent may be used in operations to which this rule applies, if at least one of the following is met: a. ECS or Sealed System: The emissions from the operation shall be controlled by an ECS per Section 302.1(b) of this rule or by a Sealed System per Section 302.1(c) of this rule; or Maricopa County • Air Quality Department • Report the the Board of Supervisors 61 of 100 b. Partial Exemption: The operation is exempted per Sections 103.1 and/or 103.2 of this rule; or c. Non-Vapor Batch Cleaning Machine: The operation is both exempted per Section 103.3 of this rule and complies with Section 302.2(a) or 302.2(b) of this rule, as applicable; or d. Non-Vapor In-Line Cleaning Machine: The operation is both exempted per Section 103.3 of the rule and complies with Section 302.3 of this rule. 302.5 Special Non-Vapor Cleaning Situations: a. Blasting/Misting with Conforming Solvent or Low-VOC Cleaner: An owner or operator blasting or misting with conforming solvent or a low-VOC cleaner shall operate and equip the device(s) as follows: (1) Equipment: The device shall have internal drainage, a reservoir or sump, and a completely enclosed cleaning chamber, designed to prevent any perceptible liquid from emerging from the device; and (2) Operation: The device shall be operated such that there is no perceptible leakage from the device except for incidental drops from drained, removed parts. b. Blasting/Misting with Non-Conforming Solvent: An owner or operator shall use a Sealed System pursuant to Section 302.1(c) of this rule for all blasting or misting with a non-conforming solvent. c. High Pressure Flushing: Cleaning systems using cleaning-solvent that emerges from an object undergoing flushing with a visible mist shall comply as follows: (1) Conforming Solvent: For conforming solvent, use a containment system that is designed to prevent any perceptible cleaning-solvent liquid from becoming airborne outside the containment system, such as a completely enclosed chamber. (2) Non-Conforming Solvent: Use a Sealed System pursuant to Section 302.1(c) of this rule for non-conforming solvent. d. ECS Alternative: In lieu of meeting the requirements in Sections 302.5(a) and/or Section 302.5(b) of this rule, an owner or operator may comply by using an ECS that is approved in writing by the Control Officer and meets the requirements in Section 304. 303 VAPOR CLEANING MACHINE REQUIREMENTS: 303.1 General Equipment Requirements for Vapor Cleaning Machines: An owner or operator of a batch vapor cleaning machine or an in-line vapor cleaning machine shall ensure it is equipped with all of the following: a. A Vapor Level Control System. b. Freeboard Ratio: A freeboard ratio that is greater than or equal to 0.75. Maricopa County • Air Quality Department • Report the the Board of Supervisors 62 of 100 c. Refrigeration or ECS: Batch vapor cleaning machines or in-line vapor cleaning machines having an evaporative surface area equal to or greater than 10.75 ft² (1.0 m²), installed or subject to major modification after November 1, 1999, or having average monthly VOC emissions exceeding 31 pounds VOC per square foot of solvent surface area shall comply with one of the following subsections: (1) A refrigerated freeboard chiller where the chilled air blanket temperature measured in degrees Fahrenheit at the coldest point on the vertical axis through the horizontal center of the vapor/air interface shall be either no greater than 30% of the initial boiling point of the solvent, measured in degrees Fahrenheit, or no greater than 40.0° F (4.4° C), whichever is lower; or (2) A refrigerated condenser coil (in place of an unrefrigerated coil) having a minimum cooling capacity of 100% of the boiling-sump heat input rate and where the chilled air blanket temperature measured in degrees Fahrenheit at the coldest point on the vertical axis through the horizontal center of the vapor/air interface shall be either no greater than 30% of the initial boiling point of the solvent, measured in degrees Fahrenheit, or no greater than 40.0° F (4.4° C), whichever is lower; or (3) An ECS operated in accordance with Section 304 of this rule. d. Primary Condenser: A primary condenser that maintains an exit temperature not exceeding 85° F (29° C). Alternatively, a batch vapor cleaning machine may be equipped pursuant to Section 303.1(c)(2). e. Water Separator: Water should not be visually detectable in the VOC- containing solvent exiting the water separator. 303.2 Batch-Loaded Vapor Cleaning Machines: An owner or operator shall ensure a batch-loaded vapor cleaning machine meets the requirements in Section 303.1 and all of the following: a. Cover: Equipped with an impermeable cover that is a sliding, rolling, fanning, or guillotine (bi-parting) type which is designed to easily open and close without disturbing the vapor zone. b. Lip Exhausts: Batch-loaded vapor cleaning machines with lip exhausts shall be controlled by an ECS. c. Workloads: (1) A workload shall not occupy more than half of the cleaning machine’s open-top area. (2) The workload shall not be so massive that the vapor level drops more than 4 inches (10 cm), when the workload is removed from the vapor zone. (3) The workload shall not be sprayed with cleaning-solvent above the vapor/air interface level. d. Carry-Out: Minimize cleaning-solvent carry-out by the following measures: Maricopa County • Air Quality Department • Report the the Board of Supervisors 63 of 100 (1) Orient the items being cleaned in such a way that the items drain easily after cleaning. (2) Degrease the workload in the vapor zone at least 30 seconds or until condensation ceases. (3) For manual loading/unloading, tip out any pools of solvent on the cleaned parts before removal. (4) Allow parts to dry within the batch vapor cleaning machine until visually dry. e. Startup and Shutdown: The following sequence shall be used for startup and shutdown: (1) When starting the batch vapor cleaning machine, the cooling system shall be turned on before, or simultaneously with, the sump heater. (2) When shutting down the batch vapor cleaning machine, the sump heater shall be turned off before, or simultaneously with, the cooling system. f. Blasting: Blasting in a batch vapor cleaning machine shall be done within a Sealed System or be controlled by an ECS. g. Records: Maintain records pursuant to Section 501 of this rule. 303.3 In-Line Vapor Cleaning Machines: An owner or operator shall ensure an in-line vapor cleaning machine meets the requirements in Section 303.1 and all of the following: a. Cover: Within 10 minutes of turning off the solvent heating system, cover the entrance and exit and any opening greater than 16 square inches (104 cm2). b. Workloads: The average clearance between parts and the edge of the in-line vapor cleaning machine opening is either less than 4 inches (10 cm) or less than 10% of the width of the opening. c. Carry-Out: Equip the in-line vapor cleaning machine with either a drying tunnel or another means, such as a rotating basket, sufficient to prevent cleaned parts from carrying out cleaning-solvent liquid or vapor. d. Startup and Shutdown: The following sequences shall be used for startup and shutdown: (1) When starting the in-line vapor cleaning machine, the cooling system shall be turned on before, or simultaneously with, the sump heater. (2) When shutting down the in-line vapor cleaning machine, the sump heater shall be turned off before, or simultaneously with, the cooling system. e. Records: Maintain records pursuant to Section 501 of this rule. 304 EMISSION CONTROL SYSTEM (ECS) REQUIREMENTS: 304.1 ECS Control Efficiencies: To meet the requirements pursuant to Section 302.1(b) of this rule, an ECS shall comply with one of the following: Maricopa County • Air Quality Department • Report the the Board of Supervisors 64 of 100 a. Overall ECS Efficiency: Operate an ECS that has an 85% overall VOC capture and control efficiency, determined by applicable provisions in Section 503.1(c) of this rule; or b. Alternative for Very Dilute Input: 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), determined by applicable provisions in Section 503.1(d) of this rule. 304.2 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 Plan(s) 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. 304.3 Providing and Maintaining ECS Monitoring Devices: An owner or operator incinerating, adsorbing, or otherwise processing VOC emissions pursuant to this rule shall provide, properly install and maintain in calibration, in good working order devices described in the facility’s O&M Plan that indicate temperatures, pressures, rates of flow, or other operating conditions necessary to determine if the ECS is functioning properly and is properly maintained. Records shall be kept pursuant to Section 502 of this rule which demonstrate that the ECS meets the overall control standard required by Section 304.1 of this rule and is operated in accordance with the equipment manufacturer's specifications. 304.4 O&M Plan Responsibility: An owner or operator of a facility that is required to have an O&M Plan pursuant to Section 304.2 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. 304.5 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 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: Maricopa County • Air Quality Department • Report the the Board of Supervisors 65 of 100 401.1 ECS Installation at New Sources: For sources that commence construction after [revision date], compliance with the ECS requirements shall be achieved upon source startup. 401.2 New Low-VOC Cleaner Limit: Upon adoption of this rule, an owner or operator using a low-VOC cleaner to comply with this rule shall discontinue purchase of materials that are non-compliant with the new low-VOC cleaner limit of this rule. The owner or operator may continue to use supplies of non-compliant low-VOC cleaner materials purchased prior to [date] until [six-month deadline date]. 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. 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 cleaning-solvents; state the VOC content of each in pounds VOC per gallon of material or grams per liter of material. b. A facility using any cleaning-solvent subject to the vapor-pressure limits of Section 302.1(a) of this rule shall have on site the written value of the total VOC vapor-pressure of each such solvent, 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. Monthly: Records of the amount of cleaning-solvent purchased or used shall be totaled by the end of the month for the previous month. Show the type and amount of each make-up solvent and all other cleaning-solvent to which this rule is applicable. b. Annually: (1) Certain Concentrates: Use of concentrate that is used only in the formulation of Low-VOC Cleaner shall be updated at least annually. (2) Low-VOC Cleaner: An owner or operator need not keep a record of a cleaning substance that is made by diluting a concentrate with water or non-precursor organic compound(s) to a level that qualifies as a Low-VOC Maricopa County • Air Quality Department • Report the the Board of Supervisors 66 of 100 Cleaner if records of the concentrate usage are kept in accordance with this rule. c. Grouping by VOC Content: For purposes of recording usage, an owner or operator may give cleaning-solvents of similar VOC content a single group- name, distinct from any product names in the group. The total usage of all the products in that group is then recorded under just one name. In such a case, the owner or operator must also keep a separate list that identifies the product names of the particular cleaning-solvents included under the group name. To the group name shall be assigned the highest VOC content among the members of that group, rounded to the nearest tenth of a pound of VOC per gallon of material, or to the nearest gram VOC per liter of material. 501.7 Records of Disposal: Maintain records of the type, amount, and method of disposing of waste solvent. Records of legal disposal include but are not limited to shipping papers or quantity discharged to sewage treatment works. 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 required 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. 502.6 Other Records Required when Complying via ECS: An owner or operator using an ECS pursuant to this rule shall maintain, in addition to the records required by Section 501.5 of this rule, monthly documentation showing the VOC content of the solvent material and the amount added for makeup. 503 COMPLIANCE DETERMINATION AND TEST METHODS: 503.1 Compliance Determination: Maricopa County • Air Quality Department • Report the the Board of Supervisors 67 of 100 a. VOC Content: The VOC content of solutions, dispersions, emulsions, and conforming solvents shall be determined by one of the following methods: (1) South Coast Air Quality Management District (SCAQMD) Method 313-91 as referenced in Section 503.3(a) of this rule; or (2) Bay Area Air Quality Management District (BAAQMD) Method 31 as referenced in Section 503.3(b) of this rule. b. Vapor Pressure: Determination of the total VOC vapor-pressure (VOC composite partial-pressure) in a cleaning solution shall be performed as follows: (1) For solutions known to be nearly or exactly 100% VOC, vapor pressure shall be determined by ASTM D2879-97as referenced in Section 503.4(a) of this rule; or (2) For solutions for which is known the exact quantity and chemical makeup of each evaporating component that is not a VOC, ASTM D2879-97 (referencing Section 503.4(a) of this rule) shall be used (to determine the gross composite vapor pressure) in conjunction with calculations using the vapor pressure formula in Section 503.1(f) of this rule. (3) When a solution’s exact species and proportions are known for all ingredients, the Control Officer may use the formula in Section 503.1(f) of this rule in conjunction with standard reference texts or databases that provide the vapor pressure value of each constituent, or a combination of formula use and actual testing on real constituents (referencing Section 503.4(a) of this rule). c. ECS Efficiency: An owner or operator that complies with Section 304.1(a) of this rule using an ECS shall demonstrate compliance using the following methods and equations: (1) Overall ECS Efficiency shall be determined using the following equation: EffO = (EffCo x EffCa) / 100 where, EffO = Overall ECS efficiency expressed as a percentage; and EffCo = ECS control efficiency expressed as a percentage; and EffCa = ECS capture efficiency expressed as a percentage. (2) The ECS control efficiency shall be determined by measuring the VOC content of gaseous emissions entering and exiting the ECS using EPA Method 18, referenced in Section 503.2(e) of this rule, or EPA Methods 25, 25A, and 25B, referenced in Section 503.2(f) of this rule. (3) The ECS capture efficiency shall be determined either by the methods in Section 503.2(g) of this rule (EPA Methods 204, 204A, 204B, 204C, 204D, 204E, and 204F) or by using mass balance calculation methods in concert Maricopa County • Air Quality Department • Report the the Board of Supervisors 68 of 100 with the methods in Section 503.2(b) of this rule (EPA Methods 2, 2A, 2C, and 2D), and EPA guidance document, “Guidelines for Determining Capture Efficiency”, January 9, 1995. d. Alternative for Very Dilute Input: An owner or operator that complies with Section 304.1(b) of this rule shall demonstrate compliance by using EPA Method 25A referred to in Section 503.2(f) of this rule. e. Temperature Measurement: Temperature measurements to determine if a cleaning machine contains a “heated solvent” shall be done with an instrument having an accuracy and precision of within 1 degree Fahrenheit. f. Formula for VOC Composite Partial Pressure (Equivalent to: Total VOC Vapor Pressure): The VOC composite partial pressure shall be calculated by the following equation: ( )( ) ∑ ∑ ∑ = = = + + = m j n i i i e e w n i i i i c M W M W W M VP W PP 1 1 1 18 where, Wi = Weight of the “i”th VOC compound in grams Ww = Weight of water in grams We = Weight of the “j”th non-precursor organic compound in grams Mi = Molecular weight of the “i”th VOC compound in grams per gram mole Me = Molecular weight of the “j”th non-precursor compound PPc = VOC composite partial pressure at 20°C in mm mercury (Hg) VPi = Vapor pressure of the “i”th VOC compound at 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) non-precursor organic compounds Maricopa County • Air Quality Department • Report the the Board of Supervisors 69 of 100 g. Formula for VOC Content of Solvent: The VOC content of solvent 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) = W W W m s w es V − − Using consistently either English or metric measures in the calculations, where: Ws = Weight of all volatile material 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 organic compounds in pounds (or grams) Vm = Volume of total material in gallons (or liters) 503.2 EPA-Approved Test Methods Incorporated by Reference: The following test methods are approved for use for the purpose of determining compliance with Maricopa County • Air Quality Department • Report the the Board of Supervisors 70 of 100 this rule. The test methods are incorporated by reference in Appendix G of the MCAPCR. Alternative EPA-approved test methods may be used upon prior written approval from the Control Officer. When more than one test method is permitted for the same determination, an exceedance under any method will constitute a violation. 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 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). g. EPA Methods 204 (“Criteria for and Verification of a Permanent or Temporary Total Enclosure”), 204A (“Volatile Organic Compounds Content in Liquid Input Stream”), 204B (“Volatile Organic Compound Emissions in Captured Stream”), 204C (“Volatile Organic Compound Emissions in Captured Stream (Dilution Technique)”), 204D (“Volatile Organic Compound Emissions in Uncaptured Stream from Temporary Total Enclosure”), 204E (“Volatile Organic Compound Emissions in Uncaptured Stream from Building Enclosure”), and 204F (“Volatile Organic Compounds Content in Liquid Input Stream (Distillation Approach)”) (40 CFR 51, Appendix M) . h. EPA guidance document, “Guidelines for Determining Capture Efficiency”, January 9, 1995. 503.3 EPA-Approved California Air Resources Board (CARB) Test Methods Incorporated by Reference: a. SCAQMD Method 313-91 (February 1997), “Determination of Volatile Organic Compounds (VOC) by Gas Chromatography/Mass Spectrometry (GC/MS)”. Maricopa County • Air Quality Department • Report the the Board of Supervisors 71 of 100 b. BAAQMD Method 31 (May 18, 2005), “Determination of Volatile Organic Compounds in Paint Strippers, Solvent Cleaners, and Low Solids Coatings”. 503.4 EPA-Approved American Society for Testing and Materials (ASTM) Standard Incorporated by Reference: a. ASTM D2879-97, “Test Method for Vapor Pressure-Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope”. Maricopa County • Air Quality Department • Report the the Board of Supervisors 72 of 100 1 BOARD OF HEALTH SPECIAL MEETING MINUTES Monday, August 28, 2023 | 4:00-5:00 pm VIRTUAL ITEM TOPIC/ACTION PRESENTER 1. CALL TO ORDER: The virtual meeting was called to order at 4:04 pm A. Roll Call Members Present: Debra Baldauff, Paula Banahan, Matthew Farber, Supervisor Bill Gates, Cynthia Hardy, Robert MacMillan, Veronica Oros, Lorenzo Sierra, Paul Stander Ex-Officio: Marcy Flanagan Members Absent: Joanne Osborne • There was a quorum (6) of members. B. Call to the public: There were no requests to speak. President MacMillan 2. Appointments to the Board of Health Ms. Flanagan welcomed the newest members of the Board of Health whose appointments were approved by the Board of Supervisors. • Lorenzo Sierra, representing District 5. Term of service is August 9, 2023 through December 31, 2024. • Veronica Oros, member-at-large. Term of service is August 23, 2023 through December 31, 2024. • Cynthia Hardy, representing District 1. Term of service is August 23, 2023 through December 31, 2025. Marcy Flanagan 3. Continuance of Officer Term and Postponement of Elections (vote to continue at next board meeting) President MacMillan asked the Board for a motion for the continuation of elections, and continuance of officer terms, moving the agenda item to the next Board of Health meeting. • Motion: Lorenzo Sierra • Second: Dr. Paul Stander • Motion status: Approved unanimously President MacMillan 4. Environmental Services Department Fee Waiver Applications A. Request for Board of Health approval of (25) fee waiver applications Fee Waiver Staff Report and Board of Health Fee Waiver Application Summary Sheet Robert Stratman Return to list of attachments Maricopa County • Air Quality Department • Report the the Board of Supervisors 73 of 100 MARICOPA COUNTY BOARD OF HEALTH AUGUST 28, 2023 – MEETING MINUTES 2 This quarter the department reviewed twenty-five (25) 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 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. President MacMillan asked the Board for a motion to approve the Fee Waiver Application Summary Sheet. • Motion: Dr. Matthew Farber • Second: Dr. Paul Stander • Motion status: Approved unanimously 5. Air Quality Department Approve initiation of regulatory change for the three rules: Greg Verkamp explained that to initiate any changes to Air Quality rules, the Board of Health must approve the initiation process. It is one of the first steps in rulemaking. Stakeholder workshops were/will be held. • Supervisor Gates asked that Air Quality reach out to Merissa Hamilton who has expressed interest in the process. Kimberly Butler has provided Merissa with her contact information. Greg Verkamp/ Kimberly Butler Maricopa County • Air Quality Department • Report the the Board of Supervisors 74 of 100 MARICOPA COUNTY BOARD OF HEALTH AUGUST 28, 2023 – MEETING MINUTES resident MacMillan asked the Board for a motion to approve AQ-2022-003 Rule 313. A. AQ-2022-003 Rule 313 (Incinerators, Burn-Off Ovens, and Crematories) The Maricopa County Air Quality Department (MCAQD) is proposing to revise Rule 313 to clarify, update, and restructure the rule. Upon adoption of the revised rule, MCAQD plans to submit the rule to the U.S. Environmental Protection Agency (EPA) to replace Rule 35 (Incinerators) and the 2012 version of Rule 313 in the Arizona State Implementation Plan (SIP). • Motion: Dr. Matthew Farber • Second: Paula Banahan • Motion status: Approved unanimously President MacMillan asked the Board for a motion to approve AQ-2022-004 Rule 330. B. AQ-2022-004 Rule 330 (Volatile Organic Compounds) MCAQD is proposing to revise Rule 330 to clarify, update, and restructure the rule. Proposed revisions include clarifying the purpose of the rule, removing outdated provisions more thoroughly addressed in other MCAQD rules, and restructuring the rule to ensure consistency within the Maricopa County Air Pollution Control Regulations. • Motion: Dr. Debra Baldauff • Second: Dr. Matthew Farber • Motion status: Approved unanimously President MacMillan asked the Board for a motion to approve AQ-2023-003 Rule 331. C. AQ-2023-003 Rule 331 (Solvent Cleaning) MCAQD is proposing to revise Rule 331 to remove a Reasonably Available Control Technology (RACT) deficiency identified by the EPA so the rule can be approved into the Arizona SIP as meeting RACT. MCAQD is also considering other revisions to improve and clarify the rule. In addition, MCAQD plans to replace SIP Rule 34, Sections F-K (Organic Solvents – Volatile Organic Compounds (VOC)) with the revised rule to update the SIP and clarify regulatory requirements. • Motion: Dr. Matthew Farber • Second: Lorenzo Sierra • Motion status: Approved unanimously 6. Adjournment President MacMillan asked the Board for a motion to adjourn. • Motion: Paula Banahan • Second: Dr. Matthew Farber • Motion status: Approved unanimously The meeting ended at 4:38 pm President MacMillan 3 Maricopa County • Air Quality Department • Report the the Board of Supervisors 75 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 76 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 77 of 100 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. 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 78 of 100 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 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 79 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 80 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 81 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 82 of 100 Subject: FW: Comments for Rule 330 (Volatile Organic Compounds) and Rule 331 (Solvent Cleaning) Revisions From: Hana De Leon <hana.deleon@nxp.com> Sent: Tuesday, June 20, 2023 7:53 AM To: AQD Planning SM <AQPlanning@maricopa.gov> Cc: Peggy Felice <peggy.felice@nxp.com> Subject: Comments for Rule 330 (Volatile Organic Compounds) and Rule 331 (Solvent Cleaning) Revisions Below please find NXP’s input regarding proposed revisions to Rule 330 (Volatile Organic Compounds (VOCs)) and Rule 331 (Solvent Cleaning). We suggest the following modifications to the draft rules 330 and 331 to ensure consistency between these two rules as well as Rule 338 (Semiconductor Manufacturing): Modify section 502.3 of rule 331 to match section 502.3 in rule 330 and 338: o 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 3 business days of the maintenance completion. Modify section 503.2 of Rule 330 to be consistent with section 503.2 of Revised Rule 338: o The ECS control efficiency shall be determined by measuring the VOC content of gaseous emissions entering and exiting the ECS using the method in Section 504.1(b) of this rule (EPA Method 18) or the method in Section 504.1(e) of this rule (EPA Method 25). Modify section 503.3 of Rule 330 to match section 503.3 of Revised Rule 338: o The ECS capture efficiency shall be determined using one of the methods in Section 504.1(e) of this rule (EPA Method 204, 204A, 204B, 204C, 204D, 204E, or 204F) or by using mass balance in combination with ventilation/draft rate determinations made using one of the methods in Section 504.1(a) of this rule (EPA Methods 2, 2A, 2C, or 2D). 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. Hana De Leon Environmental Engineer NXP Semiconductors Return to list of attachments Copies of all written and electronic Stakeholder input Maricopa County • Air Quality Department • Report the the Board of Supervisors 83 of 100 Subject: FW: Online Form Submittal: Citizen Comments From: Michele Ross (COA) <Michele.Ross@maricopa.gov> Sent: Monday, 24 July, 2023 11:23 AM To: Will Adrian (AQD) <William.Adrian@maricopa.gov>; Michelle Mada (AQD) <Michelle.Mada@Maricopa.gov>; Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov> Subject: FW: Online Form Submittal: Citizen Comments Please see citizen comment below. 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 11:18 AM 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. 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-2023-003-Rule 331 (Solvent Cleaning) Department Air Quality I would like to Express opposition First Name Gary Last Name Jones Maricopa County • Air Quality Department • Report the the Board of Supervisors 84 of 100 Organization Printing United Alliance City Pittsburgh Zip 15237 Email gjones@printing.org Phone Number 4126574565 Phone Type Mobile Would you like someone to contact you? Yes Comments I apologize in that I missed the initial outreach meeting on this rulemaking action. My comment pertains to the change in the definition of low VOC from 50 grams/liter to 25 grams/liter. This is quite a dramatic change to an already low VOC content, and I was not able to find any technical or economic analysis of this change. Unless this change can be shown to be both economically and technically feasible, it should not be made. Please provide the justification for this change showing that it is reasonable and there are products on the market that can accomplish the cleaning objectives at an affordable cost. If applicable, attach supporting documentation associated with your comment. The only file types supported are MS Office and Adobe Acrobat. Field not completed. Email not displaying correctly? View it in your browser. Maricopa County • Air Quality Department • Report the the Board of Supervisors 85 of 100 Subject: FW: AQ-2023-003-Rule 331 Citizen Comment From: Gary Jones <gjones@printing.org> Sent: Thursday, August 3, 2023 11:20 AM To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> Cc: Sara Osorio <sosorio@printing.org> Subject: RE: AQ-2023-003-Rule 331 Citizen Comment Hi Hannah, Great! Please let us know when you get feedback from EPA on the draŌ rule revisions. Gary Jones Vice President, Environmental, Health, and Safety Affairs PRINTING United Alliance 10015 Main St., Fairfax, VA 22031 703-359-1363 | gjones@prinƟng.org From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> Sent: Thursday, August 3, 2023 2:13 PM To: Gary Jones <gjones@printing.org>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> Cc: Sara Osorio <sosorio@printing.org> Subject: RE: AQ-2023-003-Rule 331 Citizen Comment Hi Gary, Thank you for the addiƟonal informaƟon. As of right now, we are sƟll planning on keeping the alternaƟve vapor pressure limit in the rule. We hope to send the draŌ rule to the EPA soon for feedback. Should anything change that would need further discussion regarding graphic arts solvent cleaning, I will be sure to reach out to you. We will be having an addiƟonal workshop eventually which will cover any changes made to the draŌ rule since the first workshop. Please feel free to reach out to me with any quesƟons you might have. 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 86 of 100 Customer Satisfaction Survey From: Gary Jones <gjones@printing.org> Sent: Thursday, August 3, 2023 10:41 AM To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> Cc: Sara Osorio <sosorio@printing.org> Subject: RE: AQ-2023-003-Rule 331 Citizen Comment Hi Hannah and Gregory, When we had our call last week, one of the acƟon items I had was to follow up on the cleaning soluƟons used in the stand-alone cleaning equipment for prinƟng applicaƟons regarding the VOC content and vapor pressure limits. I went back and reviewed the email exchanges we had with NY State DEC when they revised their cold cleaning rule several years ago and they were clear that they could not meet the 25 gram/liter limit but could meet the 1.0 mm Hg vapor pressure limit. They were not able to idenƟfy any materials or combinaƟon of materials that could be used to meet the 25 gram/liter limit. In looking at the email exchanges, it was briefly menƟoned that this low VOC content level would force vendors such as them to consider alternaƟves such as using causƟcs, exempt compounds, or other low VOC chemicals. It was concluded that these approaches would not necessarily be compaƟble with the prinƟng components being cleaned or would pose serious safety concerns. Therefore, they were not explored. The inability to meet the 25 gram/liter limit is why we requested and received an interpretaƟon that these units would not fall under the cold cleaner regulaƟons and would fall under the prinƟng regulaƟons. Regarding the proposal to revise the cold cleaning requirements for Maricopa County, maintaining the 1 mm Hg vapor pressure opƟon is going to be criƟcal to allow these units to be purchased and used by prinƟng operaƟons. The 25 gram/liter limit will not be a viable opƟon. If the 1 mm Hg limit will be eliminated as an opƟon, we would request that an exclusion for this type of equipment be added to the regulaƟon. We can work with you on the language to be added if this were to occur. Please let us know if you have any quesƟons or need addiƟonal informaƟon. Gary Jones Vice President, Environmental, Health, and Safety Affairs PRINTING United Alliance 10015 Main St., Fairfax, VA 22031 703-359-1363 | gjones@prinƟng.org From: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> Sent: Monday, July 24, 2023 5:04 PM To: Gary Jones <gjones@printing.org> Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> Subject: AQ-2023-003-Rule 331 Citizen Comment Good aŌernoon Mr. Jones, Maricopa County • Air Quality Department • Report the the Board of Supervisors 87 of 100 We received your ciƟzen comment regarding draŌ Rule 331 and would like to set up a virtual meeƟng to discuss further. Can you please provide a couple of dates that you are available so we can get something scheduled? 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 Join us at PRINTING United EXPO! (Oct. 18-20, Atlanta) Connect with PRINTING United Alliance on Social Media: Twitter | LinkedIn | Facebook Contact PRINTING United Alliance for membership inquiries. Join us at PRINTING United EXPO! (Oct. 18-20, Atlanta) Connect with PRINTING United Alliance on Social Media: Twitter | LinkedIn | Facebook Contact PRINTING United Alliance for membership inquiries. Maricopa County • Air Quality Department • Report the the Board of Supervisors 88 of 100 Subject: FW: Intel Comments to MCAQD proposed Rule 330, 331, 338 20240223.pdf From: Hannah Luke (AQD) Sent: Monday, February 26, 2024 8:04 AM To: D'Oria, Gary R <gary.r.doria@intel.com> Cc: Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Zambrano, Oscar <oscar.zambrano@intel.com>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> 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 ZjQcmQRYFpfptBannerStart This Message Is From an External Sender This message came from outside your organization. Please use caution when corresponding outside the county. ZjQcmQRYFpfptBannerEnd 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, Maricopa County • Air Quality Department • Report the the Board of Supervisors 89 of 100 Gary D’Oria TD Environmental Engineer Intel Corporation | Chandler Campus (480) 241-4917 Maricopa County • Air Quality Department • Report the the Board of Supervisors 90 of 100 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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 91 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 92 of 100 Subject: FW: MCAQD Rule 338 Comment Attachments: Intel Chandler Campus Comments to MCAQD proposed Rule 330 331 338 20240319.pdf From: D'Oria, Gary R <gary.r.doria@intel.com> Sent: Tuesday, March 19, 2024 3:23 PM To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov> Cc: Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov>; Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; Zambrano, Oscar <oscar.zambrano@intel.com> Subject: RE: MCAQD Rule 338 Comment Hannah. See attached 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, ZjQcmQRYFpfptBannerStart This Message Is From an External Sender This message came from outside your organization. Please use caution when corresponding outside the county. ZjQcmQRYFpfptBannerEnd 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 93 of 100 E: Hannah.Luke@Maricopa.Gov [ Maricopa.Gov ] Facebook | Instagram | Twitter | YouTube | LinkedIn Customer Satisfaction Survey Maricopa County • Air Quality Department • Report the the Board of Supervisors 94 of 100 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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 95 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 96 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 97 of 100 Subject: FW: Intel Follow-up from MCAQD Meeting 3/26/2024 From: D'Oria, Gary R <gary.r.doria@intel.com> Sent: Monday, April 1, 2024 7:16 AM To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>; Gregory Verkamp (AQD) <Gregory.Verkamp@Maricopa.gov> Cc: Kabiri-badr, Leila <leila.kabiri-badr@intel.com>; TIM HIGGS <tghiggs@cox.net> Subject: Intel Follow-up from MCAQD Meeting 3/26/2024 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 ZjQcmQRYFpfptBannerStart This Message Is From an External Sender This message came from outside your organization. Please use caution when corresponding outside the county. ZjQcmQRYFpfptBannerEnd 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. Maricopa County • Air Quality Department • Report the the Board of Supervisors 98 of 100 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 Maricopa County • Air Quality Department • Report the the Board of Supervisors 99 of 100 Maricopa County Air Quality Department Planning and Analysis Division Maricopa.gov/AQ